I 15' IN THE COURT OF BENCH OF NEW BRUNSWICK TRIAL DIVISION JUDICIAL DISTRICT OF SAINT JOHN BETWEEN: CLARENCE AGNEW AND OTHERS, ?laintiffs - and - THE DOW CHEMICAL COMPANY, DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL UNIROYAL CHEMICAL LTEE., Defendants AND BETWEEN: JEAN VIVIAN AGNEW AND OTHERS, Plaintiffs and - THE DOW CHEMICAL COMPANY, DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL UNIROYAL CHEMICAL LTEE., Defendants IN THE COURT OF BENCH OF NEW BRUNSWICK TRIAL DIVISION JUDICIAL DISTRICT OF SAINT JOHN BETWEEN: AND BETWEEN: William B. Richards, Esq. Clark, Drummie Company Barristers Solicitors 40 Wellington Row Saint John, N.B. Telephone: 633-3800 CLARENCE AGNEW AND OTHERS, Plaintiffs - and - THE DOW CHEMICAL COMPANY, DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL LTEE., Defendants JEAN VIVIAN AGNEW AND OTHERS, Plaintiffs - and - THE DOW CHEMICAL COMPANY, DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL CHEMICAL LTEE., Defendants RECORD ON MOTION David M. Norman, Esq., Q.C. Hanson, Hashey Barristers Solicitors 400 Phoenix Square Fredericton, N.B. Telephone: 453-7771 Solicitors for the Plaintiffs Solicitors for?theIDefendants Douglas A.M. Evans, Esq., Gilbert, McGloan, Gillis Barristers Solicitors Q.C. Thomas O'Neil, Esq., Q.C. Barry O'Neil Barristers Solicitors 133 Prince William Street 85 Charlotte Street Saint John, N.B. Telephone: 634-3600 Saint John, N.B. Telephone: 633-4226 Solicitors for the Defendant Solicitors for the Defendants Chipman Inc. The Dow Chemical Company and Dow Chemical Canada Inc. I 1. Affidavits of Service of W. Andrew LeMesurier, sworn to January 14, 1993. 2. Notice of Motion dated January 8, 1993. 3. Affidavit of Jerry K. White sworn to January 8, 1993. i I I I IN THE COURT OF BENCH OF NEW BRUNSWICK TRIAL DIVISION JUDICIAL DISTRICT OF SAINT JOHN BETWEEN: CLARENCE AGNEW AND OTHERS, Plaintiffs - and - THE DOW CHEMICAL COMPANY, DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL CHEMICAL LTEE., Defendants AND BETWEEN: JEAN VIVIAN AGNEW AND OTHERS, Plaintiffs - and - THE DOW CHEMI CAL COMPANY DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL CHEMICAL LTEE., Defendants AFFIDAVIT OF SERVICE (FORM 188) I, W. Andrew LeMesurier, of the City of Saint John, in the County of Saint John and Province of New Brunswick, MAKE OATH AND SAY AS FOLLOWSJanuary, 1993, I served the defendant, Chipman Inc. with the attached document marked by leaving a copy with Douglas A.M. Evans, Q.C., at Gilbert, McGloan, Gillis, Solicitors for the defendant, Chipman Inc., at 133 Prince William Street, Saint John, N.B. 2. I was able to identify the person served by means of the fact that he is known to me. SWORN T0 at the City of Saint John, in the County of Saint John, in the Province of New Brunswick, this 14th day of January, A.D., 1993. BEFORE Miler.? Commissi\ ner of Oaths Being a licitor JOHN c. A NER Mm W. AnareQ?LeMesurier Hi. 11 .i IN THE COURT OF BENCH OF NEW BRUNSWICK TRIAL DIVISION JUDICIAL DISTRICT OF SAINT JOHN BETWEEN: CLARENCE AGNEW AND OTHERS, Plaintiffs agd THE DOW CHEMICAL COMPANY, DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL CHEMICAL LTEE., Defendants AND BETWEEN: JEAN VIVIAN AGNEW AND OTHERS, Plaintiffs and - THE DOW CHEMICAL COMPANY, DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL CHEMICAL LTEE., Defendants AFFIDAVIT OF SERVICE (FORM 18B) I, W. Andrew LeMesurier, of the City of Saint John, in the County of Saint John and Province of New Brunswick, -MAKE OATH AND SAY AS FOLLOWSJanuary, 1993, I served the defendant, The Dow Chemical Company and Dow Chemical Canada Inc. with the attached document marked by leaving a copy with Marilyn Patstone, Receptionist, at Barry O'Neil, Solicitors for the defendants, The Dow Chemical Company and Dow Chemical Canada Inc., at 85 Charlotte Street, Saint John, N.B. 2. I was able to identify the person served by means of the fact that she identified herself to me. . SWORN T0 at the City of Saint John, in the County of Saint John, in the Province of New Brunswick, this 14th day of . January, A.D., 1993. A i BEFORE ME- ft: 4&0 W. Andrew E??esurier \r Commission of Oaths Being a 801' citor JOHN C. WARNE I mm I lim' IN THE COURT OF BENCH OF NEW BRUNSWICK TRIAL DIVISION JUDICIAL DISTRICT OF SAINT JOHN BETWEEN: CLARENCE AGNEW AND OTHERS, Plaintiffs - and - THE DOW CHEMICAL COMPANY, DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL CHEMICAL LTEE., Defendants AND BETWEEN: JEAN VIVIAN AGNEW AND OTHERS, Plaintiffs - and - THE DOW CHEMICAL COMPANY DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL CHEMICAL LTEE., Defendants AFFIDAVIT OF SERVICE (FORM 18B) I, W. Andrew LeMesurier, of the City of Saint John, in the County of Saint John and Province of New Brunswick, MAKE OATH AND SAY AS FOLLOWS: 1. On the 8th. day' of January, 1993, I served ?the defendant, Uniroyal Chemical Ltd. /Uniroyal Chemical Ltee. with the attached document marked by leaving a copy with David Norman, Q.C., at Hanson Hashey, Solicitors for the defendant Uniroyal, at 400 Phoenix Square, Fredericton, N.B. 2. I was able to identify the person served by means of the fact that he identified himself to me. SWORN T0 at the City of Saint John, in the County of Saint John, in the Province of New Brunswick, this 14th day of 7 January, A.D., 1993. Z, fM/ BEFOREJ ME: 1 . ?g?lf?p W. Andrew LeMesurier Commissionir of Oaths Being a So icitor ?We. WARNER IN THE COURT OF BENCH TRIAL DIVISION OF NEW BRUNSWICK JUDICIAL DISTRICT OF SAINT JOHN BETWEEN: AND BETWEEN: NOTICE OF MOTION (FORM 37A) TO: The Defendants The Plaintiffs will apply to the Court of Queen's Bench Of New Brunswick at the Provincial Building at 110 Charlotte Street, 4th ?Floor, Saint John, N.B., on the 18th day of January, 1993, at 1:30 p.m. for an order that the CLARENCE AGNEW AND OTHERS, Plaintiffs - and - THE DOW CHEMICAL COMPANY, DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL UNIROYAL CHEMICAL LTEE., Defendants- JEAN VIVIAN AGNEW AND OTHERS, Plaintiffs - and THE DOW CHEMICAL COMPANY, DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL UNIROYAL CHEMICAL LTEE., Defendants AVIS DE MOTION (FORMULE 37A) DESTINATAIRE: Le demandeur (ou selon 1e cas) demandera a la Cour a (lieu pr?cis) le 19 a d'ordonner Statement of Claim be amended as set out in the affidavit of Jerry K. White, pursuant to Rule 27.10 of the Rules of Court. Upon the hearing of the motion the following affidavits or other documentary evidence will be presented: Affidavit of Jerry K. White, sworn to on the 8th day of January, 1993. You are advised that: you are entitled to issue documents and present evidence at the hearing in English or French or both; the plaintiffs intend to proceed in the English language; and if you intend to proceed in the other official language, an interpreter may be required and you must so advise the clerk at least 5 days before the hearing. DATED at Saint/\John, NB, this day of January, 1993. 24? if .. Solicitor for Plaintiffs, William B. Richards, Clark, Drummie Company A l'audition de la motion, les affidavits ou les authres preves litterales suivantes seront pr?sent?es: Sachez que: vous avez le droit d'?mettre des documents at de pr?senter votre preuve a l'audience en frangais, en anglais ou dans les deux langues; le demandeur (ou selon le cas) l'intention d'utiliser la langue at si vous avez l'intention d'utiliser l'autre langue officielle les services d?un interpr?te pourront ?tre requis et vous devrez en aviser le greffier au moins 5 jours avant l'audience. FAIT a le 19 Avocat du demandeur IN THE COURT OF BENCH OF NEW BRUNSWICK TRIAL DIVISION JUDICIAL DISTRICT OF SAINT JOHN BETWEEN: CLARENCE AGNEW AND OTHERS, Plaintiffs, - and - THE DOW CHEMICAL COMPANY, DOW CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL CHEMICAL LTEE., Defendants AND BETWEEN: JEAN VIVIAN AGNEW AND OTHERS, Plaintiffs, - and - THE DOW CHEMICAL COMPANY, DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL . CHEMICAL LTEE., Defendants A I A I I, Jerry K. White, of the City of Fredericton, in the County of York and Province of New Brunswick, MAKE OATH AND SAY AS FOLLOWS: l. I am a plaintiff in the above noted action and as such I have personal knowledge of the facts herein deposed to unless otherwise stated. 2. I am Executive Director of the Sprayers of Dioxin Association Health and Environment Inc. an association originally organized in 1984 for the purpose of investigating the health effects of phenoxy herbicides on employees of New Brunswick Electric Power Commission who sprayed herbicidal formulations for N.B. Power during the 19505 and 19605. 3. As Executive Director plaintiff in the above action, I also have acted as agent for the plaintiffs in the prosecution of this action, making all decisions in relation to hiring lawyers, and experts, negotiating with New Brunswick Electric Power Commission (now New Brunswick Power Corporation) in an attempt to settle the plaintiffs' claim against N.B. Power in a related action to this one. As well, I made all other necessary decisions in the case against Dow and Others. I have so acted as agent for the plaintiffs since 1984. 4. The pleadings in this case, which are substantial in volume, have been filed with the court. 5. This affidavit is for the purpose of supporting the plaintiffs' motion to amend their pleadings with respect to fraud as well as to plead res ipsa loquitor. 6. In November 1991 the plaintiffs applied to court for production of Dow Chemical's documents as set out in its Affidavit of Documents. The documents began to arrive in January 1992 as undertaken by Mr. O'Neil on behalf of Dow. At the present time Dow still has not made available to the plaintiffs all of its Schedule documents, although the plaintiffs have requested them several times, and Dow had undertaken to produce them as of January 1992. In fact there are still what I estimate to be 1200-1400 documents not made available as set out in Appendix of Schedule of Dow's affidavit. 7. The plaintiffs have received from Dow's Affidavit of Documents copies of 80 rolls of microfilm. Each roll has approximately 4000 documents on it. We have fully reviewed and hard cepied about 25 rolls. 8. On January 27th,1992, about two weeks before discovery of the plaintiffs began, the plaintiffs asked to delay discovery until they had a chance to review Dow's documents. the defendants objected and on motion the court refused the adjournment. 9. The plaintiffs made a request for copies of Chipman' Affidavit of Documents in June of 1992. The copies were not delivered until July 1992. 10. Uniroyal was served with a request for an Affidavit of Documents in May 1992. To date there has been no Affidavit forthcoming from that defendant. Attached hereto and marked as Exhibit is a letter dated November 27, 1992 from Clark, Drummie Company to Hanson, Hashey. I am informed by William B. Richards and I verily believe it to be true, that Uniroyal is to file their Affidavit of Documents in January 1993. Attached hereto and marked as Exhibit is a letter from David Norman, Q.C. to Mr. Richards inviting Mr. Richards to review the documents before the actual preparation of the Affdiavit. {3 11. As a result of the above, and as a result of the fact that several hundreds of further documents have been received from N.B. Power within the same time frame as described above, the plaintiffs were not previously in a position to properly and fully advance allegations in respect of fraud. 12. Attached hereto and marked as Exhibit is a copy of the proposed amendments to the Statement of Claim wherein fraud is alleged against the defendants as particularly set out therein and which allegations I verily believe to be true. 13. In respect of the proposed amendments the following documents are, I verily believe, evidence of the defendants' fraud as set out in the proposed amended claim: 1. Two letters to William B. Richards from Dr. Alastair Hay re PCBs, dated 3 NOvember 1992 and November 10, 1992 along with attached C.V. The letters express an opinion in respect of the hazards of chemicals used in the spray program and the non-disclosure by the defendants of those 7 hazards. 2. Pages 8 and 9 of deposition of V.K. Rowe, former Director of Toxicology for Dow Chemical Company and Assistant Director of Dow's Biochemical Research Laboratory. The testimony acknowledges Dow's early knowledge of chlorinated di or bi phenyls (P.C.B.s) and their toxicity. The testimony was taken in the case of Keister v. Dow, U.S. District Court, Eastern District of Arkansas, July 18, 1990. 3. Paper entitled Chloracne Dow Experience. This paper traces in chronological order Dow's history of Chloracne, along with the chemical agents in question. (Dow document 1289). 4. Report of Biochemical Research Laboratory, The Dow Chemical Company re Toxicity of 2,4,5 Trichlorophenoxy Acetic Acid, dated August 25, 1945 (Dow document 1172). 5. Two pages from Dow Brochure entitled Application Methods and Dosage for Dow Weed and Brush Killer Formulations in which Dow proposes the use of oil as a carrier. This is on. N.B. Power" microfilm files and. in. part reads as follows: Basal Bark Treatment 2nd paragraph Spray Mix: Use 4 gallons of Esteron 245 for every 95 gallons of fuel or kerosene or similar oil. Transformer oil has been used satisfactorily. Do not use water or oil-water emulsions for basal bark ML 1; 10. ll. 12. 13. treatment. Used transformer oil may be used if available. Esteron Brushkiller bottom of page, column and top of pagej 2nd column Fuel oil may be is questionable whether oil adds to the effectiveness of Esteron Brushkiller. In certain cases when application is made during the summer season with particular emphasis on wetting the stems and bark rather than the foliage, good results have been obtained. Letter to Mr. J.E. Guerette, New Brunswick Electric Power Commission from W.A. Stearman, Chipman Chemicals Limited dated 28 November 1956 proposing use of oil as carrier (N.B. Power files). Letter to James M. Cruickshank, Naugatuck Chemicals from P.C. Levesque, The New Brunswick Electric Power Commission, dated June 20, 1951 re use of oil in spray program. Letter to P.C. Levesque, The New Brunswick Electric Power Commission from James Cruickshank, Naugatuck Chemicals (owned by and defending this action as Uniroyal Chemical Ltd.), dated June 29, 1951 regarding the use of oil in spray program. Document prepared by The Dow Chemical Company entitled Brush and Weed Control on Railroad Rights of Way by Use of and dated January 26, 1953 indicating safety of product. Document entitled The New Brunswick Electric Power Commission Transmission Line R-O-W Maintenance Chemical Control Operation Instruction to Foremen indicating safety of product and mixture of herbicide with stove fuel or waste transformer oil. Page 14 from report of N.B. Power Herbicide Use (1955-64) prepared in 1984 re the sale of Brushkill and by the defendants to N.B. Power. Letter to Dr. Andrew G. Goesl, Texarkana, Arkansas-Texas from V.K. Rowe, The Dow Chemical Company dated July 12, 1955 indicating Dow's knowledge of extent of exposure by sprayers. Letter to Dr. Knecht, Boehringer Co. from Dr. Schmidt dated 14 November 1955 re hazards of (Dow document 1549). 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. Letter to L.L. Coulter, The Dow Chemical Company from V.K. Rowe, Biochemical Research Department, dated February 13, 1956 re hazards of oil as used in herbicide spray to human health. Letter to Mark: Wolf, Biochem. Research. Lab, The Dow Chemical Company from L.L. Coulter, Agricultural Chemicals Development, The Dow Chemical Company, dated March 20, 1959 requesting information on the toxicity of oil used in Brushkiller formulations. Letter to L.L. Coulter, Agricultural Chemical Development, The Dow Chemical Company from Mark A. Wolf, Biochemical Research Laboratory, The Dow Chemical Company, dated July 6, 1959 re effects of fuel oil in response to above referenced request. Memorandum to Mr. George Gagnon from J.E. Guerette, The New Brunswick Electric Power Commission re: Transformer Waste Oil and Oil Drums for use in spray program, dated October 28, 1959. Letter to Dow Chemical Company from German based C.H. Boehringer Sohn re The chlorakne. Preparation of Trichlorophenol, dated February 11, 1957 (Dow document 1750). The letter purports to assist Dow Chemical in solving its chloracne problem. Letter to Brigadier General Fred J. Delmor, U.S. Army Munitions, Army Chemical Centre, Maryland, from G.E. Lynn, Director of Registration Bioproducts Department, The Dow Chemical Company re Dow's stated position that and are non-toxic, dated April 22, 1963 (Dow document 1362) Letter to Dow Chemicals Company from C.H. Boehringer Sohn re chloracne, dated December 15, 1964 document 1286). The shared information was to be kept strictly confidential. (See attached english translation by W.B. Dow Chemical Company). Letter to Dr. Hans Merz, C.H. Boehringer Sohn from Walter B.N. Trapp, The Dow Chemical Company, dated January 28, 1965 re dangers of trichlorophenol and secrecy agreemetn between Dow Chemical and Boehringer. Memorandum L.G. Silverstein, The Dow Chemical Company, Industrial Hygienist re Hazard of Monsanto Acid, dated March 10, 1965. This memo indicates that the final product used as spray can be contaminated. Letter to Mr. John Stephens from Dr. R. Emmet Kelly (medical director at Monsanto Chemical Company) dated March 17, 1965 re extreme toxicity of dioxin received 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. from Dow Chemical. Letter from V. K. Rowe, Biochemical Research Laboratory, The Dow Chemical Company to Dr. Emmet Kelly and others dated March 19, 1965 re meeting of chemical companies. Letter to Mr. Paul Hoffman from Dr. R. Emmet Kelly dated March 30, 1965 re problem. Report on the Chloracne Problem Meeting on 3/24/65 from L. G. Silverstein dated March 29,1965. Letter to Ross Mulholland, Dow Chemical of Canada from V.K. Rowe, Biochemical Research Laboratory, The Dow Chemical Company' dated-June 24, 1965 re meeting of chemical companies. Document entitled The Chloracne Problem. - Biochem's Contribution dated 3/11/65. This is a brief history of Dow's experience with the toxic effects of its trichlorophenol process (Dow document 2868). Internal memo re trichlorophenol summary from J.D. Doedens, Chemicals Department, cc. V.K. Rowe, re chemical companies handling of trichlorophenol problems and Dow's secrecy agreement with Boehringer. Letter to C.A. Highhill, Plant from L.G. Silverstein, Biochemical Research Laboratory, The Dow Chemical Company, dated August 16, 1966 re testing for Chloracne. Letter to .K.E. Coulter, Midland Division. Research Development from Alex Widiger, Benzene Research Laboratory, The Dow Chemical Company, dated April 25, 1967 re Chloracne research program. The document indicates the slow progress being made in identifying the chloracnegens. It also indicates that Chloracne is just cosmetic evidence of serious systemic injury. Letter to W.J. McCoy, Bioproducts Sales, from V.K. Rowe, Biochemical Research Laboratory, The Dow Chemical Company, dated July 25, 1967. Document prepared by Biochemical Research Laboratory, The Dow Chemical Company entitled Chloracne Problem at Fort Saskatchewan Plant, Dow Chemical of Canada, dated 3/21/69. Dow document entitled Distribution of_Reported Adverse Effects Following Exposure of Field Workers and Applicators to Formulations, prepared circa 1978 (Dow document 5716). 14 35. Paper entitled A Dow Canada Backgrounder re The Risk in Spraying Herbicide dated June 30, 1982. 36. Pages 22 and 23 of a Cohort Mortality Study prepared by Sobeco Ernst Young, on behalf of the plaintiffs, dated October 1992 indicating excess deaths in cohort. The study has been served upon the defendants. 14. Attached hereto and marked as Exhibit are copies of the documents described above. 15. I make this affidavit for the purpose of requesting this Honourable Court to permit the proposed amendments to the plaintiff's claim as referenced. SWORN to at the City of Fredericton, in the County of York, in the Province of New Brunswick, this 8th day 1993. gym/1w; V?wwmk Commissioner of Oaths Being a Solicitor w_ Andrew LeMesurier THOMAS B. DRUMMIE. Q.C. DONALD F. MACGOWAN. Q.C. WILLARD M.JENKINS BARRY R. MORRISON FRANK F. HAMM WILLIAM B. RICHARDS NORMAN J. BOSSE W. ANDREW LEMESURIER SHERRIE R. BOYD J.GEORGE BYRNE TIMOTHY M. HOPKINS M. LISE ALLAIN CLARK. 8: COMPANY BARRISTERS AND SOLICITORS 40 WELLINGTON ROW SAINT JOHN. N.B. CANADA DENO P. PAPPAS. Q.C. WALLACE S. TURNBULL. Q.C. M. ROBERT JETTE TERRENCE W. HUTCHINSON PATRICK J. P. ERVIN L. PAUL ZED FREDERICK A. WELSFORD JOHN M. MCNAIR DONALD J. HIGGINS KAREN JOHN C. WARNER MICHAEL J.COMEAU COUNSEL MAILING ADDRESS: P.O. BOX 6350 STATION A SAINT JOHN. N.B. EZL 453 TELEPHONE: (506)633-3800 TELECOPIER: (5061633-381l PLEASE REFER TO: OUR FILE NO. RICHARD W. BIRD YOUR FILE NO. November 27, 1992 Messrs. Hanson, Hashey Barristers Solicitors Suite 400, Phoenix Square P.O. Box 310 Fredericton, N.B. Attention: David M. Norman, Esq., Q.C. Dear Sirs: -RE: Agnew and Others v. Dow Chemical and Others Further to our attendance in court I am calling upon you to deliver your client's Affidavit of Documents forthwith. In my view the affidavit should contain any and all marketing information and data which your client possesses vis?a-vis N.B. Power. It should contain any and all toxicological studies carried out by your client or in its possession in respect of the herbicides in question, dioxins and any toxicological studies in respect of the various recommended oils to be used as a carrier for the herbicide spray, including kerosene, fuel and diesel oil and transformer oil (PCBs). Uniroyal's affidavit should also contain reference to any correspondence with other chemical companies, governmental- agencies and departments, private companies or individuals in respect of the manufacture, marketing and/or use of and as well as any of the related chemicals or chemical compounds involved in the manufacturing process of the referenced herbicides. Customer complaints are also absolutely relevant. The above documents would include not just letters and correspondence but all internal corporate memos as well as laboratory notes, production logs and any other written, microfilmed, microfiched or computerized data. CLARK. DRUMMIE 8: COMPANY . 2 As well, the plaintiffs demand that this information not be restricted by the years of exposure. In other words, the plaintiffs are entitled to information which predates 1950 or which was produced after 1967 if in any way it relates to the issues between the parties. One of those issues which is of prime importance is the development of Uniroyal's knowledge and information in respect of the chemicals in question. I believe that Uniroyal_has had more than sufficient time to search its records and prepare the affidavit of documents. I would point out that Dow's affidavit of documents was filed in only a matter of several weeks after the Request was served upon Mr. O'Neil. In my mind Uniroyal has had an excessive amount of time to comply with the request. Yours truly, William B. Richards WBR/nrg HASHEY.Q.C. NORMAN.Q.C.IONTBARJ WHITCOMB. QC. HANSON.Q.C VAIL BOWLIN HATFIELD G.DICKSON WOODER MORRISONIN 5 BAR) FOSTER ICHARD BOWLEN RICHARD HENDERSON IONTBAR) WHALEN SARI MACLEAN FRENETTE William B. Richards 4a? ijb/ BARRISTERS a. SOLICITORS P. 0. BOX 310 SUITE 400. PHOENIX SQUARE FREDERICTON. NEW BRUNSWICK E33 4Y9 December 24, Clark, Drummie Company Barristers and Solicitors P.O. BOX 6850. Station Saint John, New Brunswick E2L 4S3 Dear Mr. Richards: . 1992 0 her mi 1 TELEPHONE (506)453-7771 FAX (506) 453-9600 PLEASE REFER TO OUR FILE NO 910983 Further to your letter dated December 22. it is entirely up to you when you take advantage of our invitation to see our documents. Yours truly SON. HASHEY David M. Norman The purpose of our invitation was to save expense and delay in preparation of an Affidavit of Documents. earlier you meet with me the better. Therefore, the ?4=l?t OFFICES IN FREDERICTON AND SAINT JOHN. NEW BRUNSWICK I MU IN THE-COURT OF BENCH OF NEW BRUNSWICK TRIAL DIVISION JUDICIAL DISTRICT OF SAINT JOHN BETWEEN: CLARENCE AGNEW AND OTHERS, Plaintiffs, - and THE DOW CHEMICAL COMPANY, DOW CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL CHEMICAL LTEE., Defendants AND BETWEEN: JEAN VIVIAN AGNEW AND OTHERS, - Plaintiffs, - and - THE DOW CHEMICAL COMPANY, DOW CHEMICAL CANADA INC., CHIPMAN INC., AND UNIROYAL CHEMICAL CHEMICAL LTEE., Defendants PROPOSED AMENDED STATEMENT OF CLAIM 35L THIRD AMENDED STATEMENT OF CLAIM 1. The plaintiffs are individuals with the capacity to sue and variously reside at the municipalities as referenced in Schedules and annexed hereto. 2. The plaintiffs' actions having cause number have been consolidated with the actions having cause number pursuant to an order of the Court of Queen's Bench on December 10, 1991. 3. The plaintiffs severally bring their actions in this proceeding pursuant to Rule 5.03 of the Rules of Court. 4. The defendant, The Dow Chemical Company, (hereinafter called "Dow Chem"), is a duly incorporated company having its head office in the City of Midland, in the State of Michigan, in the United States of America. 5. The defendant, Dow Chemical Canada Inc., (hereinafter called "Dow Can"), is a duly incorporated company having its head office in the City of Sarnia, in the Province of Ontario and at all times material was a subsidiary of Dow Chem. 6. The defendant, Chipman Inc., is a duly incorporated company having its head office at the City of Stoney Creek, in the Province of Ontario. 7. The defendant Uniroyal Chemical Ltd. /Uniroya1 Chemical Ltee. (Uniroyal) is a duly incorporated company having its head office in Elmira, Ontario and is joined as a defendant pursuant to an order of the Court of Queen's Bench dated December 10, 1991. 8. Between the years 1950 and 1967 the defendants manufactured, produced, distributed and/or sold to the New Brunswick Electric Power Commission herbicides, chemicals or chemical compounds of 2,4?dichlorophenoxy acetic acid (2,4-Dl and acid which contained 2,3,7,8 Tetrachlorodibenzo-p- dioxin 9. is a highly toxic impurity which is produced in the manufacture of the 2,4,5- herbicide which was sold to the New Brunswick Electric Power Commission as "Brushkiller" or "Silvex", and as a result of containing were rendered highly toxic and known to be so by the defendants. 10. Several of the plaintiffs and those individuals whose estates are represented by some of the named plaintiffs (collectively "the users"), whose names are set out in Schedule were employed by the New Brunswick Electric Power Commission variously between the years 1950 and 1967 as herbicide Sprayers whose responsibility it was to directly handle and apply the herbicides referenced in paragraph 7 to destroy brush on property owned or controlled by the New Brunswick Electric Power Commission. 11. The defendants had actual knowledge of the method of application of the herbicide chemical and knowledge of the manner of exposure of the plaintiffs to the herbicide. 12. The defendants knew but fraudulentlyadid not warn the users of the high toxicity and likely severe and detrimental health affects which could be contracted or experienced by those who came into physical contact with the herbicides, including respiratory and cardiovascular disorders, liver disease, as well as an increased risk of canoer, diabetes, fatigue, impotency, skin disorders such as chloracne and nervous disordersL_as well as death by chemical intoxication. 13. The users, not being warned of the potential hazards of the herbicides, failed to take precautions to avoid either the direct or indirect application to their persons, or ingestion of the herbicides. 14. As a result of their direct contact with the herbicides as described, the users were caused serious and debilitating personal injury or death. 15. As a result of the injurious toxicity of the herbicides the users have suffered significant special and general damages both pecuniary and non-pecuniary. 16. Several other plaintiffs, whose names are set out in Schedule are variously the spouses or children or legal representatives of deceased spouses or children (hereinafter called "Relatives") of the said users of the herbicide applied by New Brunswick Electric Power Commission. 17. The defendants took no precautions, nor made any attempt to safeguard, warn or protect the Relatives from serious injury or.death, being the likely consequences to those who used or had more than a casual contact with the said herbicides. The defendant Dow Chem and Dow Can fraudulently misled the public in respect of the toxicity of its herbicide product to human health. and as a result of such fraud kept critical data verifying herbicide toxicity from the plaintiffs to whom thev owed a dutv of care. The particulars of Dow Chem's fraudulent behaviour referenced above are as follows: by 1941 Dow Chem knew that highly chlorinated drocarbons includin ol chlorinated bi henols osed a otential serious health risk to humans uch as referenced in era a 12 above of which skin disorders such as chloracne were but 5 tomatic. Dow Chem knew in the 1934-1936 time frame that Dow Chem emplovees producing Dowicide contracted severe chloracne. This was a trichlorophenol based product. Dow Chem knew that in the mid 19403 some of its customers com lained to Dow Che about contracting dermatitis or chloracne from the use of Dow Chem's Dowicide 3 roduct a closel related compound to trichlorophenol based roducts. i Dow Chem knew that at its research lab at 172 Building 2,4,5 trichlorophenol residues caused some worker chloracne during or before 1955. Dow Chem knew that at its 199 Buildin the 2,4,5?Trichlorophenol process caused serious chloracne amongst its workers in 1964. Dow Chem knew that it had a revailin chloracne Droblem amongst its workers in the Dowicide lants in the 1950s and 19603 and be an research in 1966 on the problem. Dowicides were produced from hydrocarbons. Dow Chem knew 1957 that roduction temperature for trichlorophenol should not be raised above To increase production Dow Chem raised production temperature in 1963 in 199 Building which led to the formation of increased levels of dioxin in Dow Chem's herbicide. 20. (hi, Dow Chem's ZLA-D and 2.4.5-T. sold to N.B. Power, Were produced from chlorophenols and Dow Chem knew that the toxic characteristics of the trichlorophenol process was passed on to the herbicide. (1) By 1957 Dow Chem knew that unwanted chemical compounds being produced in the manufacturing process of 2.4.5-T were extremelv toxic and that these compounds were dioxins; and Dow Chem knew that dioxins, especially TCDD could cause serious health risks to humans. including,chloracne and liver disorders. Dow Chem's and were oil based. Dow Chem knew by 1956 that these oils were potential health risks to those who sprayed, were exposed to, and breathed the oil mists, and that such oils could cause disease or health conditions such as respiratory ailments, chloracne, liver disease and cardiovascular disease. Dow Chem organized and hosted a meeting of other chemical companies including Hooker Chemical Corporation, Diamond Alkali Company and Hercules- Powder Company in March 1965 for the purpose of promoting private self regplation in the production standards of and to forestall government regplation which Dow Chem feared due to the threat to human health of dioxin contained in 2.4.5-T herbicide. Deliberately and with reckless disregard for the plaintiffs'_health Dow Chem did not publicly or in any other manner disclose its experience, knowledge or information as referenced above to the plaintiffs, did not warn the plaintiffs of serious potential health risks from exaggure to its herbicide products, and continued to produce and market its products during the 19508 and 19605 to N.B. Power. The particulars of Dow Can?s fraudulent behaviour as referenced above are as follows: Despite having actual knowledge to the contrary Dow Can fraudulently maintained publicly, and to N.B. Power, as recently as Augpst 18th and 19th, 1982, that poses no serious risk to 26 _diabetes, fatigpe, impotency, skin disorders such as human health as set out in letters to The Daily News, a Halifax, Nova Scotia newspaper and to N.B. 2.93%. 1p; Dow Can had the same or similar knowledge as Dow Chem in respect to the toxicity of hydrocarbons, generally, and biphenyls, and dioxin specifically, but did not warn the plaintiffs in respect of the toxicity of these products as it had a duty to do. gig By reason of the foregoing Dow Chem apd Dow Can committed fraud against the plaintiffs in producing andgor marketing highly toxic chemicals to N.B. Power for use in its herbicide spray program, and in not warning the plaintiffs about the attendant hazards to ensure their safety, and by never warning them as such, which they had a We; 22; Such failure to warn the plaintiffs denied them the knowledge or information necessary to avoid exposure to the herbicide spray and oils, or having been exposed before 1967, it denied them the knowledge or information to seek Droper medical assistance after the fact of exposure, thereby causing them death and injury as referenced. 23. The defendants Dow Chem, Chipman Inc. and Uniroyal individually recommended to N.B. Power with reckless disregard for the plaintiffs' health, the use of either transformer oil, kerosene, fuel or diesel oil as a herbicide carrier in its spray program. Such proposals were made in 1952 by Dow Chem, 1951 and 1956 by Chipman Inc. and 1951 by Uniroyal. 24. The above referenced defendants knew that such oils were potentially extremely hazardous to human health and could cause respiratory and cardiovascular disorders, liver disease, as well as an increased risk of cancer, chloracne and nervous disorders, as well as death by chemical intoxication. 25. Except for experimental purposes dating back to 1951, N.B. Power used such oils as recommended, at various times from 1959 in its spray program. 26. The defendants committed fraud upon the plaintiffs Ey?deliberately and recklessly not warning them or disclosing to them the human health risk of exposure to these oils, and bygnever disclosing to or warning the plaintiffs as such which they had a dutygto do. 27. Such failure to warn the plaintiffs denied them the knowledge or information necessarygto avoid exposure to the herbicide spr_y and oilngor having been exposed before 1967, it denied them the knowledge or information to seek proper medical assistance after the fact of exposurgl thereby causing_them death and injury as referenced. 2g; As a result of the defendants' fraud the plaintiffs became exposed to the herbicides and oils referenced. They died or suffered serious injury to their health, the particulars of which have been provided to the defendants. 29. As well as a result of the defendants' fraud the plaintiffs could not have reasonably discovered their individual causes of action until sometime after June 301 1985 which was approximately three months after a prelimina_y mortality study was completed for the plaintiffs. 30. As a result of their family relationship with the users as described, the Relatives also had significant and regular contact with the herbicides and, as a result, suffered serious and debilitating personal injury or death, the particulars of which will be delivered to the defendants upon request. DJ 1. Furthermore, as a result of the negligence and fraud of the defendants, and the injurious toxicity of the herbicides and oils used, the Relatives have suffered special and general damages, both pecuniary and non- pecuniary. 32. The plaintiffs, therefore, severally claim against the defendants, in negligence and fraud both jointly and severally, as follows: general damages for personal injury caused by the herbicides containing special damages, the particulars of which will be delivered to the defendants at or before trial; Q3 - special and general damages for loss of past and future income; in respect of those plaintiffs representing the named estates, damages for wrongful death and for that purpose the plaintiffs rely on Sections and (2) of the Fatal Accidents Act, R.S.N.B., c. and amendments thereto; damages, including punitive and exemplary damages for perpetrating fraud on the plaintiffs. the plaintiffs also claim damages pursuant to Section 10 of the Medical Services Payment Act, R.S.N.B. c. and amendments thereto and the Hospital Services Act, R.S.N.B., c. and amendments thereto; (9) costs on a solicitbr/client basis; interest and such other relief as this Honourable Court deems just. 33. The plaintiffs plead and rely upon Section 2 of the Contributory Negligence Act, R. S. N. B. c. C-19, and amendments thereto, and further plead the doctrine of res ipsa loguitur in respect of the defendants? negligence. 34. As well, the plaintiffs seek a declaratory order from the court pursuant to Rule 27.0QL11) of the Rules of Court that notwithstanding the limitations period set out in the Fatal Accidents Act or the Limitation of Actions Act. that the plaintiffs' claims are not barred as a result of the fraud of the defendants. or anv of them. DATED at Saint John, N.B. FAIT a this ay of le 19 1992. thvv?? Mm-w/ William B. Richards Avocat du demandeur Name of Lawyer for Nom de l'avocat du plaintiff: demandeur: William B. Richards Name of firm: lieu) Clark, Drummie Company Business Address: 40 Wellington Row P.O. Box 6850, Station Saint John, N.B. EZL 483 'Telephone: 633-3800 Raison sociale (s'il a Adresse professionnelle: ?30 A. I) {xi/IV INDEX OF EXHIBITS Two letters to William B. Richards from Dr. in Alastair Hay re PCBs, dated 3 November 1992 and :56" November 10, 1992 along with attached C.V. The letters express an opinion in respect of the hazards of chemicals used in the spray program and the non?disclosure by the defendants of those hazards. Pages 8 and 9 of deposition of V.K. Rowe, former Director of Toxicology for Dow Chemical Company r?f and Assistant Director of Dow's Biochemical 51? Research Laboratory. The testimony acknowledges Dow's early knowledge of chlorinated di or bi phenyls (P.C.B.s) and their toxicity. The testimony was taken in the case of Keister v. Dow, U.S. District Court, Eastern District of Arkansas, July 18, 1990. Paper entitled Chloracne - Dow Experience. This _ty"f paper traces in chronological order Dow's history {cg of Chloracne, along with the chemical agents in question. (Dow document 1289). Report of Biochemical Research Laboratory, The Dow gwga Chemical Company re Toxicity of 2,4,5 dis? 1 Trichlorophenoxy Acetic Acid, dated August 25, 1945 (Dow document 1172). Two pages from Dow Brochure entitled Application 1% Methods and Dosage for Dow Weed and Brush Killer '?mV Formulations in which Dow proposes the use of oil (?Jmm 6? as a carrier. This is on N.B. Power microfilm files and in part reads as follows: Basal Bark Treatment 2nd_paragraph Spray Mix: Use 4 gallons of Esteron 245 for every 95 gallons of fuel or kerosene or similar oil. Transformer oil has been used satisfactorily. Do not use water or oil- water emulsions for basal bark treatment. Used transformer oil may be used if available. 31 10. ll. 12. 13. Esteron Brushkiller bottom of page, column and top of page, 2nd column Fuel oil may be is questionable whether oil adds to the effectiveness of Esteron Brushkiller. In certain cases when application is made during the summer season with particular emphasis on wetting the stems and bark rather than the foliage, good results have been obtained. Letter to Mr. J.E. Guerette, New Brunswick Electric Power Commission from W.A. Stearman, Chipman Chemicals Limitedr~f' dated 28 November 1956 proposing use of oil as carrier (N.B. Power files). Letter to James M. Cruickshank, Naugatuck Chemicals from P.C. Levesque, The New Brunswick Electric Power Commission, dated June 20, 1951 re use of oil in spray program. Letter to P.C. Levesque, The New Brunswick Electric Power (owned by and defending this action as Uniroyal Chemical Ltd.), dated June 29, 1951 regarding the use of oil in spray prOgram. Document prepared by The Dow Chemical Company entitled Brush and Weed Control on Railroad Rights of Way by Use of and dated January 26, 1953 indicating safety of product. Document entitled The New Brunswick Electric Power Commission Transmission Line Maintenance Chemical Control Operation Instruction to Foremen indicating safety of product and mixture of herbicide with stove fuel or waste transformer oil. Page 14 from report of N.B. Power Herbicide Use (1955-64) prepared in 1984 re the sale of Brushkill and by the defendants to N.B. Power. Letter to Dr. Andrew G. Goesl, Texarkana, Arkansas-Texas from V.K. Rowe, The Dow Chemical Company dated July 12, 1955 indicating Dow's knowledge of extent of exposure by Sprayers. Letter to Dr. Knecht, Boehringer Co. from Dr. Schmidt dated 14 November 1955 re hazards of (Dow document 1549). . Commission from James Cruickshank, Naugatuck :29 39- 14. 15. 16. 17. 18. 19. 20. 21. 22. Letter to L.L. Coulter, The Chemical Company from V.K. Rowe, Biochemical Research Department, dated February 13, 1956 re hazards of oil as used in herbicide spray to human health. we; ?w 2.4 I. Letter to Mark Wolf, Biochem Research Lab, The Dow 13:" Chemical Company from L.L. Coulter, Agricultural Chemicals Development, The Dow Chemical Company, dated March 20, 1959 requesting information on the toxicity of oil used in Brushkiller formulations. Letter to L.L. Coulter, Agricultural Chemical Development, The Dow Chemical Company from Mark A. 5-4 Wolf, Biochemical Research Laboratory, The Dow Chemical Company, dated July 6, 1959 re effects of fuel oil in response to above referenced request. Memorandum to Mr. George Gagnon from J.E. h? UJT Guerette, The New Brunswick Electric Power i?i? Commission re: Transformer Waste Oil and Oil Drums for use in spray program, dated October 28, 1959. Letter to Dow Chemical Company from German based C.H. Boehringer Sohn re The chlorakne. Preparation of Trichlorophenol, dated February 11, 1957 (Dow document 1750). The letter purports to assist Dow Chemical in solving its chloracne problem. Letter to Brigadier General Fred J. Delmor, U.S. MP1 Army Munitions, Army Chemical Centre, Maryland, from G.E. Lynn, Director of Registration. Bioproducts Department, The Dow Chemical Company re Dow's stated position that and are non-toxic, dated April 22, 1963 (Dow document 1362) Letter to Dow Chemicals Company from C.H. Boehringer Sohn re chloracne, dated December 15, i?5? 1964 (Dow document 1286). The shared information was to be kept strictly confidential. (See attached english translation by W.B. TrapP: Dow Chemical Company). Letter to Dr. Hans Merz, C.H. Boehringer Sohn fromfjg'. \tdf\ Walter B.N. Trapp: The Dow Chemical Company, dated?? January 28, 1965 re dangers of trichlorophenol and secrecy agreemetn between Dow Chemical and Boehringer. Memorandum L.G. Silverstein, The Dow Chemical Company, Industrial Hygienist re Hazard of 1?5 Monsanto Acid, dated March 10, 1965. This memo\??1 indicates that the final product used as spray can be contaminated. g33 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. Letter to Mr. John Stephens from Dr. R. Emmet Kelly (medical director at Monsanto Chemical Company) dated March 17, 1965 re extreme toxicity of dioxin received from Dow Chemical. Letter from V.K. Rowe, Biochemical Research Laboratory, The Dow Chemical Company to Dr. Emmet Kelly and others dated March 19, 1965 re meeting of chemical companies. Letter to Mr. Paul Hoffman from Dr. R. Emmet Kelly dated March 30, 1965 re problem. Report on the Chloracne Problem Meeting on 3/24/65 from L.G. Silverstein dated March 29, 1965. Letter to Ross Mulholland, Dow Chemical of Canada from V.K. Rowe, Biochemical Research Laboratory, The Dow Chemical Company dated June 24, 1965 re meeting of chemical companies. Document entitled The Chloracne Problem - Biochem' 5 Contribution dated 3/11/65. This is a brief history of Dow's experience with the toxic effects of its trichlorophenol process (Dow document 2868). Internal memo re trichlorophenol summary from J.D. Doedens, Chemicals Department, cc. V.K. Rowe, re chemical companies handling of trichlorophenol problems and Dow's secrecy agreement with Boehringer. Letter to C.A. Highhill, Plant from L.G. Silverstein, Biochemical Research Laboratory, The Dow Chemical Company, dated August 16, 1966 re testing for Chloracne. Letter to K.E. Coulter, Midland Division Research Development from Alex Widiger, Benzene Research Laboratory, The Dow Chemical Company, dated April 25, 1967 re Chloracne research program. The document indicates the slow progress being made in identifying the chloracnegens. It also indicates that Chloracne is just cosmetic evidence of serious systemic injury. 113 '17 :3 Letter to W.J. McCoy, Bioproducts Sales, from Rowe, Biochemical Research Laboratory, The Dow Chemical Company, dated July 25, 1967. Document prepared by Biochemical Research Laboratory, The Dow Chemical Company entitled 34 34. 35. 36. Chloracne Problem at Fort Saskatchewan Plant, Dow Chemical of Canada, dated 3/21/69. Dow document entitled Distribution of Reported 11152r"? Adverse Effects Following Exposure of Field Workers and Applicators to Formulations, prepared circa 1978 (Dow document 5716). Paper entitled A Dow Canada Backgrounder re The g? Risk in Spraying 2, 4, 5- Herbicide dated June 30, 1982. Pages 22 and 23 of a Cohort Mortality Study prepared by Sobeco Ernst Young, on behalf of theg?- plaintiffs, dated October 1992 indicating excess deaths in cohort. The study has been served upon the defendants. . NJ. 1 Kl,- 2 I \E' a on-g-L?uog #1 auosaz-quz a I1uaanmau 2151 gp-asna.. tuna; #394 a . .1 omtqulu may?: 5; mg; ,0 nova 23m ?(7161) CLz=szt non-1 at: :taan: 1 1951 purists: 'zL: unease on; 1311109 ?151 :1 paused-z 11-: sauatvqandtu mm a alumna; stratum mt: non a: um _.40 :Ixu1zu a: nannodxa 23:3: aatpuns; 30 list: tuna: 1-31: . ?tum-111 ??me :5 1:191:10: ?n aan?ta-IAI1 0: IOOHBB 119119! Bauhaus at 11:30 Is: mam'rp Etna an 1mm?: 11m 'sth .5 paatn130189 5: noun-a on: :0 =1as1za=anzlu=. (5:51Lanna-oz: ?8 stand-1 at man! an: cm: on; :0 sud-.2 mum no: (net) ug and at ten. ?50th pun mm: 1' II g: '19! 31 1n30?u 030- -q Ken 21 KZIA s; :1 put tags;- ma pm I main-41': 011:; pun-no; Mm 1-5 'litst) v-u' Jain: )918nc pun m1! car! once: ou-q: an ace . ?mmtwaam 81 10-0-1: 81:8 .Inu: on 903:813331 mods: and: 1-011-th man-m: mm 1. In?1aalh 8651:? O: 3 13313? cpaluarx 8 131111: 4M I 1 1?1: f. i 1-11 8183-1 .1181 as. 513 -5- 8.. nub. "Hasn?t? 4.7. .- . ?farvov'sematmsuuwmm 13.: 31 1nd(1931)). Ian importantly, marina: and his cello-guns also loot-d at PCB: in those.- tests and thy that o: the'mieuc chlorinated hydrocarbons thyme, uphanyumotm 'wd tar PCB) can "mm of. king tho lost toxic'tPag'I 12i- 1nc rut). In moth-r may; the author: :33 :?thus.h nutmofhtith (mammnkok. mounds tut-d maria-tan diphenyl chlorine amt-mt 65. 0 par cunt) was highly toxic em in low -- Emldnotbonisin . PCB: ten more toxic than wlxipntd in rats. Inca :uult o! thoir war! ii: nail-.1: heir-ku- and his 5. colleagues remand Iona occupational matur- W5 ?10er jhaxa chlorinated hand an animal fading and inhalation studiu. The Matias an to: (minke, amma'ru 21: 155(1339) nu first and My "an: publjmiaa was by .. Schwartz Public mun 25:53:; (1.935)) in chick no point-d out thut 'In addition to than i? . of. We poisoning have . Occurred may warren inhaling than tux-estrus]. these with the uhloro have ?whims of he then rum to 3mm 'cnnud by uncut chicane!) Peas'cauud skin and intern-.1 pram-u and this was Imam in 153: 3 min. (nmuzm admins?): say that the 'met patent or than chain-313, as tax as their acne-taming prop-nits concerned, or. the ?311me 1?9 prev-at occupational team when should ha mlosad'.1n additian the Warm: sham he gravid-d with clean elm-nu: and annex-clothe: duly. any, that chunld he sut?cicut facilitios so that undo tux-1m, and alum. simian should b0 provided to chi-ital: ?1th best. wishes digmiv. dio?rbanm.m1rlq of the qu,inpatona and 3'7 .n-I-unu-n l- n?Ju-_uwmwuu . Iridium I Richards Balzac]. Emu. 7 mart min i to 30115.13;th Ian Saint Join In: mink mm 1036?? 1992 but: 33.11 I 1.: scan as! not all All 3 mica}. amnion the urination-Lot uni:- herbicides in War-or oil. mm rmdud this prim-.10: in .1951; (21.111131: ado a similar 1'th in the 1950's. Tran-tuna: on Pol?hlorimt-d (Punt) mutt manila-hm lathe lat: 1330?s: that thus. chain-a1: not only annual the skin diam: alarm, liva- 01 ?initial rats and that they mu not: taxi: to the than tho chlorinated Chlorinatd - anoint-balms mu at that the to have bun tumult for tho duths o: 3 wax-km. i . um. um dioxin Dov had a chlaram prohlu for may you: noted-n 1934-5 3' sum. anthrakn mad unrest ?play-u producing Maids P. The chants-l1. involvud in this process are 80411:: and In the 1930's that. in: lacuna-7 can tanning exposure to I. emanated albumin-an. A-omotuhatmldamrtuhawhamahlmm? Instinct mart-ad to as barium- buys) was ?ported in tannin in 1.936.213: chain].- ranch-altar: ripen-d to be Davida:- (possibly Dovicidn - sodiu- - 3? I e-m?ew-hn- -rr- I e-e-e?v l? A e; and. Inthe contact-'3 Wtruhowioidos, emote-Mk chlorate-r2- . Aeevere gee of 1W1: leach-emereeycledetriohlml residue in glycol solvent outav?pro?uotioointhe zeso'eeno 1960M. At butane detected momettheauhrinqercupeny intenaunnyionse/ueedthemym tantalum. an 11 1.951 ?eet-timer Irate tonov the 2' ,s-triohlotophenol We the emote was identi?ed es 2,3,7,Hetreoh1mod1oein(oxior1n 1.957. Winger also More-d Doe ehout the need to keep the telnet-tore low in the triohlorophenol Higher- . teepereturee could leed to the ?otation o! more or the tried to the ion or triohlotoyhehol. 111.19? I by tuning the tap-rem of the Doe?s tut-microphone: vee known to neteriels oepeble of cloning ouoreone an to: heok ee 19?. . . faunas tree the triohloropheool me were tut-d tor ., poettive responee indicating that they hed the potential to - oontuiheted with dioxin ?ztvu notootil mother's? own enemas-unmanned" trichioropbeool developed cunt-em in 1364 thet Doe tooketepe to remedy the eltoetion. he xenon too the oath-eel: of ohlorecne wee ohenge in the trialorophenol Intermix-q Me deeigned to production: In 1965 Due convened a noret nesting of the variou- i ?111120323302! of. triohloropheeol and the 2, 4, herbicide ted: true it- to intern thee ehout the dioxin problem now wientlete explained thet the dioxin eonld he ten-ted over tree the triohlorophenel pt'ooeu into the tiniehed 2, herbicide which on sale. nae eel mime to avoid oblatm occurring in where of. the ?no, tau-Lola that it thieheppened,theeho1e2,l,5-T hehitend reetrlottve intention henoino the hen: aide, levee-e11 controlling it, wold toner-I. now said ?eet the dioxin centurion-Jen o: the herbicide elm-11d ml. pa: ?lillimuirL [any 2, 45 5-1? :orenletione on the eerket ?to 1.968 bu die eoid from other anteater-ere end one hetoh or: 100,000 lb 'tzoe We had dioxin level of between 3-7 exceeding this level. now purchased. - eithei: poteotiel to cause ohloreome in the sensitive rehbit- I. i - - 2J0 0: 3.4.54 did not boon-t public haulage until 1970. In 1969 m- Mantle. Ins-rel: mm apart noting that 2 At audnltuntimlnm. ?sunlight! 2h- misting on the sale of. 21? H, not any martian- that. it pound a hulth rm, baton this. nit-yum, Mamamxumm-mt?w . prom?. 1964/5. Dav had roach-ad clau- wlunu in. locating: in 1957 about the prohlu cm in tha menu.- rheumutthaminw prahl-nn Wind in 1357 and tin intonation ?manly Dov that: chum-am night not ho th- only mm o! to dioxin, but that internal injuriu? particululy to th- llm) light also m. lento:- . published in 1957. ?ax-liar history a: th- chlorinated - warning of uthcr. lm1,linjulcu. . r' {can simuly Chad Alastair Hanna. 0. Senior Lam in 911 Pathology at lauds . Nam: D-OB: Place of Huh: Namnaktv: Dim: won: A?dl?s?l Present W: Former Appoinmm: Socuties: Marital Status.- outshi as CUMULUM VITAE Wm AIL-clam! HIV .2111 Avril 19d? (Sh-now. Seoul-Ii British 35: Wm). WM - 1969 Hindu-Maw London 1973 mm at Chmn?u?l Pun-ah?: Old Mocha! School quIOdI Lied! L32 Uninrsiw Lecturer in Charmed Pathology I?m Apt! 1979 [Univ-airy of Loads) Lads. Hannah Fdlow - Zoological Soc. or! Landau-u 1.72 - New 1977 11??de Wufmm HIM, Ind Num'?un 7 Decanter 1977 - M1579 Socilw Bruits Plum-rundown! 5(3de Anaemia?! of Clinical Siam Bone ?Tooth 500'!? Smith Toxicoiomr Dcpanmcm Torn - D.D.B. 7.1.80 187? - Stir-Mfr: Jayme! Nature: Tnv?ling Scholar-hip thborship of UK Emu.? Memes! a Ioncomy Panel. Minm of Agricuimn Fisheries and Food. 1987 - dun. Advisory Comm on Handing. Drum-rm! of Trade and um Sent was-Much 1990. Working Camp on tho Asmara-n: Taxi: Chemicals MATCH) - Ham and Emmi" Seat 198w?. 4oz 1 IM efSeien?ficonL'mitVIluu. Hutu-ll Sam Emmi June ?SO-due. - Workin? Group to mm mm Crimi- wr 0mm Emma Lil-nits. Hutu-I and Safety Enwu'w. Doc ?DO-dun 1591. mm M) Working Waste. British Moira! Association. Dc 19834011991. 1991. Hum Watt! Indeun Huhh. Odom WM 1891. mm writ-d to hem Fellow of Collegian-t Win-Ii June 1991 Participant in Work! Hum WMWI Army for Banach on Gum: - Worksl-np an Hulth Risk: :4 Emma to marina-d Dibcuodio?m and Dibnnzufurans (January 1978}. Consum to United 3cm: Em'rrm! Protection Agency . on Health Fish: 0' MW mom: - Cincimlfti JUN 1933. (:0an to U?i?lld Suns swim Probation Agency on Hum Risks of Chlorinlu-d Dibemofur-ns - Cinmtti Mar 1905. (O 810' E?ccts of Aunt? on Ausuahn Panama! in Vietnam. SWIM. Austri- - July 1984. (3) Even \thu on who" of WW Vom in Agent Orange lawsuit in Nuw Yuk March/April 1984. Ewen wnnus on hum" of farm Monsanto in lawn-"n mm! Manama - CM?onm Virginia, Units-d Sum - Juiy 1 m. 1 MW. 3) Nnioiul Environmental hunch Counci ii) The Wollcome Trust "11 Tluol I I . . i) Name ii} Anni: of C1inical Biochen?sn 43? Dina-rs UM Saint! V) Jamil of Industrial With! I. . i) Stu-Flag Winthrop. of the rub :fgbaruznl In the mmaf 03m 1985- ?34.NDorIm with 13th ii) Upi?hn. hnstinl?on of the Prov-r: lion. Min-I'll Tun-mm. 19M. 122?.? arm: with Purh. Suturing Hath Cm: Imulioc?on of rob of mun-d mm on how- "it-'1 turnover. 1983-90. 529.000 with Punk. Sakai-u Carr. 2 mien-son or the ??aw of 0 mm Wop-moon an tun-mm of m. M1391-June 1993. LIBEWU mm mm Pm: Unto. current Renard! 3km Ii) lnm?guim of effect of haw mm on mum function Fun-m hr Association of Cormm?h 1989-501 1392. (ii) trunnion-ion of tho dhc: o4 toxin: on 'mumfunctianhI-nh. Financed!" Cut-Input? Trust. Oct 1990-5?: 1993. mm The that of tuna-Mia! and ambient: on the re?ll tubule. Dc: HOS-date Praia starch 2 awardld 2 command 3 war research puma but Mic-d 10 uric. up an vim- manual 3 students ?1601111:in "and: whats Ior of Medical Laboratory Seine-s. Emma Leeds Wutcm Hutm Amt-rum 3 mr 1982-5: MRC SW. 1986-89. Grim Scen??c Trust . E?ect of Tum on Imam: amnion in ads. ?12,500 Oct 9056?! 91 {13.000 31-5?! 92 Conan-Ilia man with Dr 5 Evans. Gm Fowduiw Pubic Attitudes to who - Dec 1950 a I. I drug. and to invasion. tho mmtm?w helm Mich may with Wm. Emmi-Jim fer WI Tom Service tor Lads Gar-mi in?murv (Iii-Ia mm 1384!. (ii) Membotof [1.68 Distict Health Authority Duns Advisory Emma. 1987'?. Murmur Luds City Ema?! Wm Router- Group Sea: 89- run) Mamba Dank City Gun-rel Milan? cm Round-In Hum Wash discharg- hom dour-3th: warm. in": 1. 5m We'd Cam. Oxford 1975. Compa?tive Aspect: of VII-min 0 man. 2 2nd Imomatioml Workshop on Calcilied Tissun. um: March 1986. untamed. Poulbh rob Mr yin-min in nmbnu- ?Mani 3. 3rd workman on Vitamin D. Asiomar Ca?iomia 1977. Paper wanted. ma?momgmm' 4. tnm?onal Aouncy for March on Cam-cu. Harbor of WM Grow to mm at Ghenzodioms much-runs. Lyem.Funu. Jmulrv W78. 5. 3d international Workshup on {11ch Tissues. Imnl Match 1988. Puper nut-mod: Vimn'n MWium in NW World P?muu'. a. mum: Eff-cu of mm me Hymm. Cmruroneo Grandad by New York mum of 5cm May 1379. Pap-r ?Accidm in T?d?omm m: a need in! rulinic mow tn main risk: to hemh'. 10. 11. ?12. 13. 14. 15. 16. 17. 18. 20] 21. Cumin-ad Dim and Horn-d Canaounds: hotel can the Environment. norm. Dam 1980 Pam mourned 'mm TCDD: the hut: . I . Human Ind Envirunnwnul Risks of mutilated Dion: and named mum. Arman. Virginia Omaha 1981. Murat-r of pm we 'Humn new Smitty of Chm-rim Sympodun on 0116 Seem. Leeds 1981. Pacer 9m ?Tho nah! consequences of mm: and who the herbicidc Herbicide in Wu: The low-?m Ecological and Human Cancun-ms, Ho Chi Mir-h Fm. Wynn-m Jan-m 19m. Fm puma-? an 'Expoml Todcdogr and - Uri-tad Sum: BMW Protection Mm. Malabar of Working (imp to ?Huhh Ann-morn 0mm for Pomrlorinmd cm. July 1983. American Chm-in! Sanity mm on 01W Dinah: and Dim-?Imam in tr- Tom in?rm-mm. Radiant D.C. August 1933. Paar mums: 'Tho moment of 2.3.7.8- T?radilondihnza-p dioxin'. naval Emma an the Use and Effects of Chennai Agent: on Austraian human! in me. Ewen My pin-mud ll 3-day honing in Aunt-h Jay 1984. Unit-d Suns PW w. Munber of Workim Group 19 We nun 'Hunh ?mm Document for Poiychlori-Iand Dhmm'. alumni. Ma? 1986. Ron! Society or Chemm Learn-rt. Uni-unity at Sussex. Newmber 1986. Paper :numd 'Chunical Will-far. in tho 1980's: I return to mnehu'. International! Symposium on Chen-rial Wyn-in. Subaru. Paris. Jammy 1989. PIW presented on 'Toxicdog?v of chemical warm: aaenu?. - Intornl?onal eminence 471 Cocoa Workers. Snonmnd by Ihous. Brazil. May 1989. hoot m: Toxicology of Pesticides used in coco- pmducn?on'. Institution of Occupational Screw and Hulth. SobvlLaods. October 1989. Pan panama: 'Exoosun mm: tor worn: arm-cm: tan or rrcuon. Scam: and the Total Mn Councii. Dundn April 1990. Papa-r mum-d: A roan: mt of cocoa and pu?a?du in Bruit: In thin-01h?; bind for Wu workm' Unind muons Mm?l haw-af?rm Mural-m of ml! working grow to rod-Joe moon for UNEP Scam 60mm! on W's-porn Ind th- Hurnun WW2 Gm. July 1930. 4a; ?in 22. Mum. W190. EMW and Squaw-?og WamDWouISius'. 23. Wind Suns Sam: Family! Rom Comm. In?ation In Prison! upon my It bun-room! PM scum-om Coflhuncc on Km Hm Washington D.C. Match 1991. Paper unsound: 'Chom'oll Wm moon ?may. 24. Symposium Scion and ?u Citizen. Nam-id Foundation. Manor-mar. June 1991- haunt-nomad: Working Scimitar: Ww'. 25. mm Wothshoo on Biotin Sunolros, w. North Cuo?na. Soombn1991. Paper m: dioxins in industry'- All; to Noti?er- 5:3me 6. Tooth Soc-owlAnoc?mim at Urinal Enoch-mu. 5mm to Don: o1 It Was 01 Edirburgthorim Wat llnM-rWde-? Holloway Cullen! (LonoonlMinw Cabot. Seminars at Hop! Hessian mustard-119mm: Hosoiul, madmanumn In?morvrf m1 mm Duo! 3! Marv (2:1!Nonhom Col-90 {Bu-tutor]. 4?7 11 Alas-sir Hly. Dwain! Saw-c: Lawns of and drown 265m. N.Y. a Lnndan. Pea-um Fun. August 1982. Recruited 1985. 7 a: 'hnMu-uhy. ?Wmvmaomhou. 'No Fun. No ma The than all and We! warfare. 1351?. Lumen. Hutch-3. Fabru'ry 1984. In mm. NthOfL NWISM. c) a? 'r?mrmm. 'Aw Hay. mommy. Wham mm 358?. W-JWBW1W1 Elm 1. Hay. A.W.M. Guam of vitamin tampon. In: Cahium Firm Hormones. Th. WW 0! 1h! 5131 mm con?rm. pp 405-407. Amati-dam. hm Macias 11975). 2. ?Hav. AWN. a Wm G. Rotation of mm trauma ms in Vim D: Bind-mint. Chantal lid ?nial Aim: timed to Catch? lint-bolls": m. by Nam-1. AMI. ct ID in 433-483. Barf-n Ind New Yak. Walter d! Gm, "377}. 3. ?Hay. Hm. Word. Sm, PA- Mm. RR. a. ran. L. The tbt'iw of its-ammonia? toalm the MmdehMDauicmNiuWA??iu?m Ed. by Homo. a 10314. huh I New York. Wain: do a. Homenmu MWS. ?Hly in 1981 EST Yutbook of Schne- 8. Team. Mcan-H?l pp 198-200. 5. AWM. Exposurn to TCDD: tho hum: risks in chlotimed diam: and ulna: compounds. Impact on the 51mm. Edit. hyO. Huanw. 91 aL pp 589-500. cm. Freudian). ?Hay. Mm. E.B.. Hum. A.G.. Crux-?ora. MA. 5 Stevens. PA. The mi: of anemia! Im acids in mm duper-dent com I Ibwntion in the maniac! Free. of 5th Min workshop. mein D: cranial bicehemiul and ?nial mm 01 calm mholiwn. Do 309-311. Darin N.Y. Warn-r do Gunner {1932) 7. Maun'r Fans-rim! rodent-av and mean: an overview 'rn H?blcidu in War. an long mm human and mum. Ed. by A.H. Wetting. 99131-166. London 8: Pfihdolphia. Tudor Francis 1984. 8. Cum. Bi?h Tnmn, Hay A.W.M. u. WI amnion and snowman: Sympal'ium mm in Hor?cidu in er. the Icon mm human and analogical com. Ed. AH. Wm. pp 153-155. London 5. Hum. Tam Frauen 1.64. 10. H. 12. 13. 14. Hay, Alana-H. ?Bioicuicll Wam' in SciJ?cch. Hm. Current issues in Scienco Tom. Edit. by Tum. pp. 182-164. Flute Pun. Landau 5 Sydney. "080- Mam. 'Ydlow Rain' '11 Sd.Ted1.?enu1. Gwen: isms in Scheme I: Tmony. Edit. by Jam Tm. London E. Fina Pius. 198?. ?Hcv. Absuir. "the limit: of p-(ioxin' in ?Chlor'nat-d Dimes and mm: in th- Toni Enviromm - Edit1334. 31:237-307. Huiin. Morgan. D.B.. Maris. A.H..Cbgg. C.. 09665.13 Hay. Hdun.J..Pmy, Mumm. C.J.. Shim. M. ?1an m.7um?mlmuf12mmal mmuihosmat. ansmt?dbv?o Barnum, TH. Norman&K.P. ?240-251(1985! ?Allstai HIV. Environmental Pollution. Ruin-w lrlide for 8.3.0 Domesday Prom Number 1986. Hey. A. A Parimumm Comm cm on Kurdish human nm.wu1inmDC27Fcb-1nry 1991. lit-Imus) MW 1. ?Hay. A.W.M.. Shut-it. A4. a Ray. W5. Some useful Was in ?in lam Jaumol of Labotltory hectic: an. ?33-43?. [1374). 'Hav, A.W.M. Pay, was. A simple mam-mam. Journal mummy name. 11. (wrbl. 'Hav. A.W.M. 5. Watson. G. Binding of 25-Moxyviumin Dz lo plum: pun-in in New Work! monkeys. Nature 235, 150 "975). 'Hw. A mm a! ZSMromhdecalc?trul in a New World Biochcm'tcal Jounu! 151, 193-198 (1975). Way. A. W. a. Watson. G. 25- Momma-ammo! in numb Compamivu Each-mm and Physiology. 538. 163-166 {19761. 'Hay. A.W.M. a. Wmn. G. The ohm manor; urchin of 25- in ?sh. We. rati?es and birds. Cmalrmiw Biochuninry Ind m. 535. 167-172 {1976). A.W.M. 5 Wm G. The bind-n9 of 25- and to tissue binding main: in a New Wodd me! an Old Work! mu. Comp-nth! WW If"! M. 5'53. 131-13? (1977!. 'Hay, A.W.M. Watson. G. Vitamin D: in ??ction. Comomu?u Biochemistry and Wm. 56!. 374-380 (1977}. 1+4? IOmin; in far 248. ZSWm-dacaid?iercl and 245. ZHWW m. Guam? ham and Widow. 535. 04811977]. aunts. G. met-Radius at Sam: U120. ?nial Chunks-v.25, 473-475 "979). May. A.W.M. Am In taint-om m: I mod for mimic um: maamhrisktohulm macaw of Sciatica. 329, 321-324 {1979}. 'Hay. A.W.M., Hamm. W. Sm. PA, Maw. EM. and F. WM. ins-Iliad May-dammit: vitamin min calcium Wu. Lipids. 15, 251-4 [1980). -Fiernim. .L. Occur. Hay. A.W.M., Morgan. DB 9. Pat-avid. Tubmumeia in Gama W. L. Hiccups Chic: Lam-match. 19, 135-141 "980). - Fm. J.J.. Cia'ld. J.A.. Count-r. EFL. Hay. Mom-n. DJ. Paranoid. Rana! mm OI-nagn will-nun mum damage cvtotoxic duos and WW- W. 3. 251-254 "980). -Christina Ernam Russell M. Young. D. Brian Morgan, Alastair WM. Hay. David Tara-Dow I When. Tubal! man 111 mm mm hmmaania. an: cram Act: .140, 231-238 ?10343. 'smm. um. H., 'Hay?. A.. Morgan. 0.3. a main. m. m- conuibmion of diam vitamin and sin-Ilium to 1b. ohm 2&an nun-uh in ma elderly. tibial Harmon. Human Nutrition 386. 191- 194 (1934). nemau, D.H.N.. Hav. A.. Wm. M. PJ.Ca1-ndon. EH06: of photon-many an alarm 25 viu-rnirl in ma. Biology Ofth! Normans. 225-227 (1904!. Newman. H.H.V.. Shahawv. M.. "in. AWN. I 0.3. Morph. The buwean vitamm 02. and D3 in the din Ind clam 25 OHDZ and 25 in My women In Britain. American Janna! Climual Nutri'ii?m?j, 750-764 (1385). ?Hay, A. (trunnion and in 5mm. F'hms lmamatinnat Journal of tho 0mm Socittv of Great Brink-1.5.2. 16-25 {1986! 0.5.. Menu. IL. Pat. B.K.. Hay. A. and MP. Faaiy. E?ect of induction. anush Journal of Ciniral Pharmacology. 744-7"! (1986). .Nadharni, 3.. Fan. 3.. awn. Fmri-ncn warn the usa of the Taxi-Lab TLC Sworn in sunning for morphimihu'oin abuaa. Annals of Chnicai Biochemistry. 25, 211-2112119871. 24'rudia. 0.. Abbas. s. mum at min-n! Whmimmlm. Waf??wal Society of 681-21198?. "mm. 5.. "in. AJVM- an. s. and u. Minn. Wlwahm. Amulsmm?iochen?m 25. 408410 um). uPuIa, T.. Birml. M. m. P.G.. Hay. A. Fan. Use or a manhoosu.mamwnd?y. cabin-amm?d Therm. .9, 540-345 mm. K. Wm. M. and Hm A.W.H. A raid hen-Elana! mum tor dmc?m mind?. Ambdahum?, 482- ?mam. K. Shun-b. MA. Sand-man M. Ind Hay. AWN Set-ring 10! 6mg: of male: horn Nd:- Gniul Cid-nil!" ?8-930 11ml. ?ww. x" Sanderson-I. Hay'. A. I. Rania. n. Muhadnm concentrations in plum and to dosage. anew 37 205-209 11991). -wo?f. May. A. a 9. Want Saliva. Ginicd Minn 37m 1374(1991} K.. HIV. A. 1. Mick. D. Git-dd Chum (Wen-port! (in wan. K.. HIVFun. M. Measuring cumin:- in truth-dam mail-num- m: an of I phnmahqiul indialtorw om mum Cilia! Pusan-eulogy is Tharp-nit: 199-207 {1991) Lloyd. 0.. 311! .Lbyd. D.L.L., Lloyd. M.M.. mum ELK. mum. A. indu?rial emu-null: the aim at avian-um! minis for mm chcoparhologiul ?ndings. The Sci-Incl of TM Total Emil-amt 83-96 ?1991 I. an. A. A new: magnum. 0! Cow- and We: in Brazil: An who-Inlay blend for Work-n. The Sci-nu of the Total Emirmm-em 395- 97-109 (1891). Wolff. K.. Hav. A.W.M. Ind Wick. J. Hum: mandate murmur and that rule in Madam dummcuion magma-m3. ?nial Ctr-mm {in ma). -Pum'te. 0., Hwy, A. a 5mm M. of SHD 386Lon mud MW in the human m. Mamas {in can). Edmih. Mum 35mg, km in 5m ?gm? I 28. . 29. 30. my. Vitamin ?Ham. Recon :1 3rd workshop on Vitamin D. Name 255, 17-18 {19771. 2. Hw. A.W.M. cm rich-u. Nature :19, 289119771. 3, Her. AMLM. 1'machbrudfbum-o-diom ?luau at Sumo. Disasters 1541. 239-308119771. 4. My. AMAM. ?unifying cumin-pom. NM. 23, 458-470 (19771 5. Hay, AWN. Ham-13nd E?vcn. Nam". 2.73. 533-534 119781. a. Aha-i1. Dicxin mm. Rm. 215. 304 [19731. 7. av. Alastair. Snow: Nomm yet. m1. 133-158l1978) B. Hly. A. Coma-25m of vitamin minim still musing. Nature. 213, sea-510119791. 9. Hay. Altmir. Shin mm. Nauru. 213. 375 (1979) 10 Hay. Alastair. Diun'n and on fish? Nauru. 111 (1980). 1 1 . Hay. Alum. New ?than? fur chlo?nmld dioxins. Nam. 2.35. 514-515 11981}. 12. Ha. Ala-air. mum 0: might and mm. Nam. 29?. 354 (1582). 13. Hay. A. this an what about movie? New Sci-mist. 33, No. 1316 99158-161 11982). 14. Hay. A.. Much. 8., Robinson. J.P. I. Ran. S. poise-1cm ham our Europa. NOW Sciatic! No.1296 pp. 630-635 (1982). 15. Hay, Munich At am with Mary. Semis: .191. 12-18 (1 RM). 16. Alumni Hay. New WM 12 February 1987. NI. 9. 63-56. 1 7. Alan-it Hey. How to may a unsung-n. Mm: 332. 782-783 {19881. . 18. Alastai- Hay. icvdinq 'm Wm: Mmagmmt. Vol. 19 [21 130-137 11990]. 19. Alastair Hay. Temnp Tm. for 1h: lam. Nature 350. SSE-556119911. 2mm '1 -F obinsun. J.P.. Murphy. 5.. A.W.M.. El Run. 5. The than of chemical mm. Sock-mun Pamphm, 38m: {1932) 2. ?mm HIV 6 Gas? Wright. Ono us not mum. The Can lor rue-wrung Fri-Ms a! the Ennh. (19891. - 3 IJanl Foam". Absuir I: Gco? Wright. Fashionable Wane: The Halt-up of I Roe-{den 5le Wm: ?Pruner. Lied: 46m (1990)- t. ~Wut'mu. A. Eu. Guam. J. Hly. awn. u. EmldethW- Ml?Ofmm}. 32 DH 111 comm. niacin-W to Nam. 7-minu 53 1, London. 2659p. Published August 1582- "as. a) 'sun Hunky. ?Alunir Huy Ind Suwn Ron. 'No Fin. No Things: The a! chain! and biological wot-fan. Pluto Puss. London 135:?. Pubiishod Fan-Irv 1984. bi Unit-d Sum. Publish-rs - Mona-w Hui-m Hus. Now Pun. Now York. Novun'bor 1934. :3 Jam Mn - - Tho En?oh Anna Uaon Ltd) August tsao. 31 -Ptur Him. Masai Hay. Nicol Mu. Dun WI sot-Iv: A Puticido Handbook. Frau. "991! 'm m. I. Helium. J.P., Murphy. 3., I. Race. s. The ?it-In of cranial mam. Spokesman lethIL 36:: ?19821 2. Omismtonouoh. ThoCloeforI-owoihg. Ff'lI'tdsloeEmh. 46:011339}. Jam Forshaw. Alastair Hay I. Glut? Wr'qm. nudism-oh Was-:11. Main-up at I Blem- Savo and Prosper. Loads. 46m (1930). Waning. A. En. 5A.. Goidbln. J. Hay. AWN. - Chemical Wagons and the Human Emirmmem. Report to the Emmy control at the UN Enviormm Program. My 1990 lh m1. I .5. El 1. -Sinc.ttir. AJ.. Film. Rn. A.W.M-, Watson. 6.. Cram. M.A.. Hart. Linoimic acid in Cowman minim. Proc.umr.5c.. 33, 49A (1974:. 2. A.W.M. the tampon ul' via-min in on can Punch. 139- 1?0 [1 9761. Nov. AWM. Vitamin transport in mm. mm: SocJArnt. m. 195 [1973). 41. Hay. A.W.M. A possibic min for in Ovulation. Proc. of tho 2nd Workshop on Cald?cd Tm?. mom. lch.M.d.5ci. 12, 31-32 [19761. 5. Hay, A.W.M. Vitamin DZ mabolis-m in New World I'm. of the 3rd lam-and Workshop on Calci?od Tissues. Israel 59th March 1973. a. A.W.M., tuning. M. 8. Watson. 6. Rick-t: and vitamin nut-bonsai in Proc.~uu.5oc. .12. 4211 11973: 7. Hay. Alastair. Vitamin A ?say to UNICEF. Foochix Disasters. 2. 62-84 ?9781. {Letter}. 8. u?ivors. Frontal. TLL. Junk. Hay. A.W.M. Vitamin in the nutrition of w! Cit. Pro:.Nutr.Scc. 13, 36A (1979?). 9. -C.Iro. A.D.. heard. not?. FL. Hay. Glnl, .I.M. A nodal. J. A comparison of [hi affect; of 25.26- - cifcrul 2?25ch on calcitonin aeration rate in wwn'n Maud pigs. Wow 35 I2). ?-55 10. 'Hav. Mamr. 5.3.. Hm. A.G.. Olwfurd. MA. 3. ILA. 9min. Mutant. 1.25- . Cid-urn absorption irhibitod by mint-I acid rm?c?on. Procudinos of Nutri.Soc. 33, 89A. {1980]. km Ho-v "run-?1c: PZI-otrtu Cm?i?! .n For your {11" unalou data that. touring our hormcmu curronL prtcu m1 Hrulhle. u-I but nun-It :u out-H" r? our Len. dun your Lyn} roman-?nu u. nun-m. I 1.1-th minced Intonation v11) arable you to mm a! your prubI-u. I have hard any ?null?nun r-urn About :mur pap-r Un Eulcna Hod Manual )ul aunt]: in Jul-ho" Til]. an ?11 recon-d. run r-qutr- my tuan-r In! -rul1.,r. plan. 1-: know and It will L17 to balp you out. Your: v.17 1nd,, GMIW mum. l. u. :mh' hf-tuk 11: ran. (ht-r10. Attmunnl Ir. Jau- I. Cruuhhuh .hlu than". a??o?tgrq Guiana. Luann Boar-311': u. ill. to that run for rum Last-r of lay 21 Id. i: '11! in plus? tn onpo?-nns nu Ian. 1-. and rm:- Inn In? La- ?ninth. um. Mun Mu has and". thwuuhunuuo?m at ?wart?at. at an. ink" an 1 not. ?In Ha on. up In 11.3.1? Jan meu. ?pad that am mu m. an. I. no ?it ?ll-bar. If. lat-rum; I ."nnr ?thug um. um All .4 a nrrlar. I. N14 small? any r-u can cupply on to not can [?l?ir'll'tn? tan plum of apn- uluum. uni-u J. bl). I. 6. ?1 all brush but. um all-an a our Int-r ?nuthat?) to: all.? u! mm- It apmr- ?at up In. a pun-o I nu. am:- at. a Inu- uu an a nut to than 7nu. man?n. .. - - 2 - {hr y?ur Int-ru.: In this nutter. bun vary truly. .m mural-?1 Emmi; mm Jv" L1 ?g 87 The following is a transcript of Document 2484-2485, from the Power Affidavit of Documents 92. Naugatuck Chemicals Division of Dominion Rubber Company Limited Letter to: (The New Brunswick Electric Power Commission) Fredericton, New Brunswick. Attention: Mr. P.C. Levesque, Superintendent of District operations Gentlemen: Thank you for your letter of June 20th the use of brush control Herbicides. In your letter you ask for information of materials to when preparing ten gallon quantities of spray solution with oil as a carrier. This will depend to a coverage that you can obtain from the nozzle with(out) equipped. I believe we mentioned in an earlier letter (that the) Shawinigan Water a Power, when using waste transformer oil were able to coverage with 10 gallons per acre of brush, However, when of fuel oil, the same nozzle applied -- gallons of oil mixture per acre of brush. We would suggest that you first (determine) large an area can be covered with -- gallons of oil, for determining how many gallons would be required for (an acre). (When this) determination has been made, you would then be able to (tell) to lnix in ?the quantity' of oil to cover one acre, recommendation of 1/2 to 1 gallon of (transformer) will find that quantity of oil and that you will have to (add) from 1 quart to two quarts 10 gallon amount of oil. With .regard to the (waste transformer) experimental quantity, we should (point) out (that) oil and therefore can be tested only in a water (carrier). You mention that your water of chemical to 10 gallons of water, and that a (10) gallons of the solution is applied to an acre and that apply one gallon of brush - bane to the acre. In a of carrier does not have too much influence on the resulting and the important factor is the amount of or two that is applied over a certain area, Since the water, or the matter is simply a carrYing agent to aid in dispersing the evenly over the area. Where the foliage is dense, naturally (you would be) required to .A Naugatuck Chemicals Continued June 29, 1951 ssure proper wetting and penetration into the (inside) leaves grush being sprayed. When using a water Spray on 8 to 10 foot tall brush (it is) usually necessary to employ from 100 to 150 gallons of water to adequately cover one acre of brush, when using oil it is possible to cover one acre Page 2 with particles (drums or dump) of brush. (certain) (Yours very truly.) NAUGATUCK CHEMICALS (James A. Cruickshank) (Sales Manager - Agricultural Chemicals Eastern Division) Jam. A. Cruickshank/dgh The above was deciphered by Alastair Hay 16th August 1992. .- - . 1 . . . ?1 n...gqregh?zrima, (Q1016. NJ ~071 AVCXF S11 3.4 rump? .. .L..P roan.) ?03+nb .. 11? 49cm 0.2% \Wq mf+u?3f+i$ J63 ?1 -1 r1. Twpnoch.)1u U11 0? die}. Cy m?pJ chTs) r1131. 5.. C, 9pm.?? +0 .1 . .. nanwUP Aral? 4.51 not.) Orv?.11?) 131.. 304.19 (LO: 1 1 1. ?Madurai-Rm. F1 23+.euab.? .I Erna r?if? MEWLV r1913. cud o; 1+2: ,3 . - [.31 .0 (up?T7. 1% POVEV . :51.anan_ ,3 L1 LIP ?ciaP a? Pwlru 1 1 11 I 1 IUPSOWZ 9? mug nip ?n L. ?uh/v.21 . 1/ . (We Coca.? ?#5410,? ATAHW . .. TL 015 WP nae-?PL a 1 . .M . [v.1 r91. Orr?Tu)? rap ?oucranp Tamar?) w. fr. Sign: 40? (10.3.4. ..3 >1P.n1q.vbb+.+.w 4. ?runkw? ?11.11am: ...23 >1P+4n1f rt; AL 4:10.21 11% Jag +0 1 n1; _Ouniznv: 9301.91 9+ +0 A. 1 95*; 2.2 ..6.40 AP (I. +012.? oD_1_ n1 (1.74.11 A._nclud..rmv . 491 9.1+ .714 in?? i.zb1..F,r 51.913114 1112.5.. +1 11 121 >111. cirrupco; 1+ r3? . 1r) 4 Chaim La: 30+ #00 215/1 1.03:1 1.) gr Ann?s?fr.? PJL *lnh'1 ?r of OW T110 4.er 2 J??ffL pr (chunks ZIPTPH b-:Povgj PL Carob-1 51. Tran .n LPpufx Dna+c?n1= [011; . To ?rms?r _u .10 [Pihau Faraway} _ToLov . A CribCwTA: Tan?F1. 3v 1? ?Dam Gnu ?Jugk (unhi- "Juan. 1?1] ?15? USQAI {far-n a-f L: :chUn?? (our 0A3. ?In. a} LFML. bald-n uh-n all .1 fink-LU: ?lac?nf one. c.r.fa__ ~4qu Quqhg LruL\Iulu 4 1? (fatal Nahto? w" Naugatuck Chemicals Lo-uc- 0' Dov-m- o- .ubbc- [on-O? rk at. a . .dsiw . . e-rata'gw .. . . . i'f?lif't??- Kim-L1L-?ri ?Il...-- . . "um.Vntru: h-rbj? bu. . . ff in ltt'il' I'll I :90] we." pr- . . 1? Izzh a Tm- up? . . act-u' 'ur-rao Hut -0r: rm n-r-t- at?! - vg- "1.1 na-IlprI-l. hallo a roundup-I .1 ?rho.- "o Pc-Ir, Ih-r al. I 'n .- 'wnru'c Olin fl) n! arr" hunt. t?r' rm) !u-0 - 1-1' ?u -.. .411?: c! 1' ilu?w . . - . 'lt? Mr? I: u? car. '0 ar-rw-I u- -- u- - . :rr burni?nr L.) my mud: 9? f?ll"l - a! .. has Iron ya; I HM than I. hv if - .. 'onlt lat-v- 1-4l1 nii'u' ?rm?math? ?f u' .v-I or I I'll: ?'id in! .I l'rdlr-n a-vtl?t Ill-r. u' - - pun-HIE}. Q?ull -II "1 -.I-- - . I?ll an! t'rrl?ur- 'Ir l- In un'ar 4" '"I'Ill'if'l'l'nl' VHIrlc'll - I-.- 1! - on: uqtlli'm'." -. . ?Ucall nI-rl'o 290-?. 1'Icn?n - Irrh 1H- "Pain-w". I. .err. . of can-Jr tint [no our?? why-1v -- 2- 9-011? - . - ml Us Inlil'AHIcpil-d a art-In air-q, - .t ?v - . nan-r llul'lr I ra 71:1, arm-K - all In Ilapruv -nuI-"uly Fr- f: Hquln! tn noun-- r-w-nr with; o-I-l Hun u- I-ol ?huh in"! but?: arm-1. udng 0 Into: Orr!) on I lo 31' tall i 4 anally raw-our} tn uni-In, he. m: In l'i' 1-le ?hp-I'Lr-un. lb- vanII..- I In 1 p' ?"015 "-4174 I -.-. - . - - . - . ? .. . .MHJ I a. .I .Illhh-?rrl I .-.. . n. 2.. 0--., Ills- . 10 6365 - Lur'w MIDLAND CRI x" i OCT 3 1930 BY or LED 23,541- mm, CANADA 26. 1953. Wham: W'mm Emu counm?ig 0803001 M00 . ban [been with can-tract 0mm, 01th.:- by EB \l nhctin hrbicidos, 2.3-1: an: 23,54 hnvu bun watchman-31mm m. Impala: m1 discus- Iith you this Inning. ?mthitm round tut-mottbummumolio An publnhod usual. as than an a: 2,1; Menorah-amt? Bow CONFIDENTE cats, 17:. biz-icy, shaman ?mu-hm. Murmumsdz??Dmmd m. m1 amt: rights at 1-: anus-191:6. mm?m?mml?dmm?th2,h?DM minim-1. 2mm Acid (2.1554!) Ill ammuz.um2.h.sammruvhm carnalinl??T-Ig??. Wanner-r. I 880800 unn?rudri?tsotwdna-IW. Mudumummommttam brush. manna-tin m?m. In 1951 I. hid antral Man {new {0f un?t-?W' 3.12.: ?min mm U.8.1n1953. 680800 1 M00 cm or mama: - 2.1m: 1m 2,3154- m: hm. m1. mm, 2,1L-Dmml, emu-1n! ull. nun-cumin: um. (lam. 021131. Lao-m, W1. wl, m-octyl. mucus-human n. running "to. d? and 2.4.54! In to he mm: antral. 01:13:11. inn-ml. butyl and hauntin- Dowlc??a??mnm] In amwmuarmw. 1.0!me Son-Mm Stuns: mammudsuun. 060300 1 M00 am 2,11.? um 24.3.54- cms?uocm saws-mama. ?stamina-tumul- mum?'m. . W. ?manumemmu-ntmt amen-am. ail. DOW oc??maram Mal-Dramatz??D-z??arumxgm m. 1mm m_ mmumnmawam-mmomp- mt. ?gauntlet-ops. MWch-Ionplmung. 6. 3mm 2.11.54 wmu?mmumnamwz.mm wth?hanrc?f-MW . Wt. hath-cans. Anon. -mehudnnm. mam.mcm1wtom-mw. 4mm Low 033%.; ?nng 2?5sz ?ling? L. 111m Arman-mutual: ?awammaw. rum-4W?. Miamthma?n mun-wag luxww-uum-mmw. 100300 "mu a, mum Warn-15m. wmmumwum. inch-norm. mummn .Sd'umcft-cti [0w M- ext-Int, nuns crops. nods. ?Walnut-triad Iith alt-nun 2,4,54. 3.3319113, '6m11?m1m193p 1m. ?York. has tin-romeowmmambbetx 860800 ?remnants-autumnal? I man-Io: I one: thorium: (1) 1-4. m. (3) - mum-cu (3) phi-manhunt? (5) old m. (6) mat-I. (T) drain-ins. (8)1760! My (my 1nd), (9) was rude:- ans. Pu! M.- I I @w con?nanmk ow; DOW 1002mm gagg?g?gg?bg Engagiir?uul?n??ni gag?ruu??glc??vmqig??g?u h??auavg?ai?iu?-B?gu?a hm. guardian-?u ga?gla .BBE-ud?maoum Ru?ag??u?E-?oloq?lg?g . It ?u??a?R-??io?ghuga?a B?gulu?lu.u?nq?8??ua hn?u?u?n 92 an Jun-nun? 3% no.3- .5 .3333 Banana- 8-5 n55 3538 3.33m .hu? auugnah?uulu?n?huau?ulqu?gn gag Bad 3 Enough?8 653.5 1.2:1 alien-urine. last ammdmumupuwu? af?rm-alum. cumumpu-manu mum?. Antwan-alimwbo arena-um tum-um. nun'tq-attomm .meunmm. mmxmunuuw,imtmarmm, aqua-nu: M. mummamm. bum.1tw Santana-hm? nthism. I 960800 cum Cutting now PT iao?g?lg??pi?umougnomou?. ERR. Eg?g?e??o??n 3.65.09.59.38. ?v?hnwongnlupu Huang ?ugii?iggn?g ?B?dw?g?niti?g??lung?n? gape-annual? Eg?gg?gl?a? 35%. R?lagagpn? mmnomou. Egkg?lggnag guEu?Eho-?Epnu?nauvo?n-Enn? entail. 0003001 MUG E2 3P Hr?. Uni-?1} 4 .. - INTRODUCTIQH: In recent years miny lurre utilities bot.h in Conud. and the Unit.ed otates, as Hell as for of: Australia, hsve experimented th cerioin tyies of chemicals uhic cutteil and eradicate all or most tyges of woody rrowth lound on transmission line rights-of- -wey. Most or the utilities round that by use of thin chemical treatment they could ever a period or a few years, almost completely stamp out .11 woody growth on their rights-orwuoy. .. :5535 The chemical es epposed to mechanical skirtin cutting kills the trees, plants and bushes to and including the roots, thus there is no regrowth. This means that the right-of-vsy does not have to be periodically reskirted. On the basis of the above information the Connission carried out an experiment.ul pro reams of their own during the late spring, summer and ear 1 fall of 1950 end 1951. _Results obtained were encouraging and the Commission has now embarked on a small scale spraying programme. JR An average crew should be made up Grew Complement: was follows Foreman Truck driver Utility sen (Mixers, relief sproyers, water carriers) 6? Spray-sen The Foreman and truck driver should be temporary or 1? per-snout Commission employees. The other men are to be casual or local labor. 7 - knapsack (?ressure tank type sprayer: with brass . 1. or copper tanks. ost suitable of the types tried to date has Ibsen the Dobbins Sprayer). of rubber replace-est rte for these sprayers ends ass #0 Carried as well es one or we rs yin; at IdisIe type eeseieere length oItj-ru 4&3} ialjr I5. e_ I. . . . "330.1311 f. $59? :1 1 - ?aquntzed "Jrh?fu c4? h? used f?r mix). 6 5 gallon contuim?rs (fur carrying later all]. - Jater buckets. to - L5 gallon drums, with taps. 6 - Single bitted axes (for cuttiny largo truss). Large funnels. 50' metallic tape. to 500' - Aluminum tie wire. 1 - Large thermos Jug. 1 - 1 pint measure. SPRAYING MATERIALS: 2:5-0 liquid 5 gallon cans haunts powder 25 lb. packages 2 D: To be used for normal growth oxcludinr the . following specios- all ovarlzroens, naplo and song bramblos.s 2 L-D- {liquid} 5 gallon cans To be used where largo number of svorgroens, napln or brambles are oncountsrod. -l}j Annato: To be usad for treating (in the poudorod for!) any cut stumps. EILLUBE Ono pint of 2 to 10 gallons allons or water. Anna 0 used dry or b. to gs lon actor. Ono pint of 2, L- to 10 sllons of stovo or fuel all. On. pint gallons of stovo or N01 all. innate not solubls in oil. I??hh uauw? numb-4L. EPEECIS RAIL: Parnissibie to spray dry growth one huur -e!ter rain. - Chemical will be effectiVe nu 111 growth sprayed one 'hour prior to All growth nut eprayed one hour prior to rainfall must be reepreyed. UATEE AND OIL HIIES: Any reasonably clean water may be ueed in preparing the mix. 1f dirty water is used it will be roth to clog the nozzles and other arts at the eprnyer. If water ie not available on the ?ht-uF-way it may be.truckeJ tn the nearest spot accessiblu to tun right-of-way in L1 'nllon . drums and cerried to the mitinn point in the 5 r13 on' 1, containers. If a stout stick is aweliahie the 4 gellan containers can he hung from the stick and with the ends of the stick carried on the shoulder: of two sen the enter can easily be carried DVPP rough terrain. If it ie not felt to he economicei to tr\neport later to the mixing point oil may be used in the air. A greater coverage can be obtained with a eaaller amount of oil then ?een be obtained with water, using the some enuunt or chemical. Ueing eater coverane can ueunily (depending on donnity of Jith oil growth) be obtaineJ with 7 pint: ur the chunicel. the name can be obtained uninn pintm er the cheuicel. For Renarel hnuthr cast of the vi! 1! prohibitive. Any trye of Iirht oil can he used including eaete transforhe?_o . . 513150 The mixing point 15 eimply any location on the right- or?vay where the chemical spray is mixed and ehould be located so that the man spraying can refill thuir sprayere with a minimum lose of time. UQE OE TIE Ui?g: The tie Hire in cut in sufficiently lung to epen the width of the right-or-way and in then strung ecroee the ripht-ef-wey at 10 or L0 root interval. to eub divide it. One or two aprnyere then work in each sub- division and are thus enebieJ to give their area couple!- covere e, i.e. they work from one lieit to unether and then eove rear wire ahead . .- .. Tho Spravvra cur CurrIr-i H. the Mark ?in pm;- i- ?handlo :gttatod.unt?- it "pum;s thJ'. tuls py{n? tho 3 pressure 13 azfliciuntlv hull? 'c r1\? i five heavy gf? H111 star u; Fur auvurni accuLla tn} .4 aprgy, Thu . a few pump: as! the luuhilr wili xuu1.1y bu n1'rir1v1: brln? it up again the pressure {Illa off. . Care should bu Min-m lo anturuta ?11 ?in 1am? put of th' growth and any large uthm nran. Frau ihose 1rn1l th- lanL curricu Lho 1's uhuso 7hr actual E111 placc. I Um enhacutitra?mf Should.a larg? nmuunL u. ?spray coma contact with 1h? skin 1! lhnul1 InnoJlntoiy b. washed off. Bartram. Cure uhnui-l In: march-ml In tub aura that neither CUMCanrttuJ nur Ill rotgag-ms: Liff If an largl trans are cut the atunpu ah i spread Hit ?aumatc. nuld b. l?hdf?lly - 22m: The fine a ray nus a tundancy to drift.und intr-nc cur. should be uand aprayiuu near {urn crop: and ornamental shad. trout I8 can b. injurious and oven If it in not the public in qu ck to blame unknown to than for I crap or tree blight. Largo quantlciuu or spray 1n brooks, atronnl or ditches can do barn some diatancu fro: the operation. .ygv- . Cattle or othar animals that night food on V. station which has been a rayed will lufrcr no 111 offactn run 11, ?nor in it hurlfu to riah. m: arn a raring will not and in not arr-clpd Th. first a ?111. bin 13 dun to Inn, fncturl the salt ?0 [iv- A 100$ {:prauinont or which in the sheltering or on. bush or plant by? For this rollon and othcru, 1? to acct-nary to do qr}, pp.? troutucnt follow-up during pcrhapl ?hl hilt ..Jr?? . . p??grwv?f?wy ?9?"Hvxwabuinaani??lb?i?xu? - -- ~,qrm?g - - 3 . ?ma?nu- The 3Prasula 11- c.rr'r4 n-"Jr' nu hian}6 Hid. It 'y-lx 9 Lara.hv .xr Hzal :2 1' ..-. Mun-rt: - H11: 32-.) I a l'eH pumps 'tu- bf'UU'. ?i?Hl- Cure aha-11.! hr t'aknn 2n suturm? Ill :tt-If'y t' Lhu Hrovth ?nd Fr.n Ihu:~ a. lam. {Lu L?Lrsniuu! nun. . L- .. 111 takes placeJhuul-I '1 MIN-- Hm incl.? spray I: Fry! "m UH. nil-ul- I off. 54-5! l?o-str l-g- m?i?hul' .torJ .7 Ln!? all an?. I - In sure that eyes. rut the Mung-.1 all-an}! In (7.. If any larae traps ur? spread with DRIEI: The Finn 1:15 :1 tendency tn drift. and OlirM?-tll?0 should he used sprayinr nqu turn crops and shade up thu can DH ov-n If 11 In not Hm public 15 quick Ln b.-mn unkuuwl Um:- ror a crop or tree blight. STREAMB: Larva qu1n1111ua vr array In ur lrri;1tl~n ditches can do harm some distance from the Syraylhr ur-r-tznu. 10110 ?ngers: LiatLle or onr animals Hun mirm. rem! ullj?vna?ln?lnll which has been afrayud H111 suffer nu ll! ofrvril nor in it hurnfu to rich. The fire! oars all! not Ind la not to give a 100% 111. +n1s ta dun tn many factors tho Inc! pruninunt of which 10 the Ihnltertn: of on. bush or plant by tnathor. For thin runaon and others, it 1: nocosuary to do lpot troatmont follow-up during tho noxt Lao ycurt. 1v . . ?by .Aifu?ai?- . a- . ins-v. 7mm? . I Tilt: \Ly :1 Spraying. Tn:. full crew. Thu do deLPrf.r4:? [In these f rts ?re h? to Oht?ln. it be tnurouglly {Ewahdd mrr?g; 54.22115; It is not eCun?516I1 the L0 rSvo font. Jitiyrl?. in a;r?y rx-hts-cf-Uay . - . . . - Ha J-?J?urhs'?L-lkifs46- IcIll'squ?Dj'qU Lo \q5?I 14 - 393393152 1955 030 1956 6200 1957 6011 1956W 3635 1959 1670 1960 1173 1961 1693 1962 1266 1963 1601 1966 2396 ESTIMATES OF MOUNI AND VALUE OF IIERBICIDE USED Ml) CONFIRMED ESIIHAIED POUNDS or ESIIHAIED ACIIVE GALLONS 0r INGREDIENI CONCENIRAIE 6,500 563 23,100 2,000 22,100 10,900 9,200 6,500 0,200 1,025 7,000 075 7,700 963 13,200 1,600 cost or (CIL) PURCHASES HAIERIAL useo GREEN caoss CHIPHAN Tl? v. Ir. 2 6,700 (5.10? - - 7 26,200 ?Hrs? 23,200 5,900 6,300 0,600 . 7,300 a 3,300 0,100 - 6,200 16,100 11,000 16,000 l4170 Coanrmed purchase: of BrusthII. All other flgures represent purchases from companies, but not confirmed purchases of 61?} Ml) POSSIBLE SUPPLIERS ?9554961? NAUGAIUCK 1 ,000 1 ,000 I30 2,100 1,500 3,700 200 1,200 TOIAL I 13,200 2??$kx3 16,600 20,030 5,060 (loo 9,070 70?? 3.1.00 3400 13,000 1'0500 16,700 $500 31?m 105?? - .4.ed ?w THE now CHEMICAL COMPANY Rial-5N3 MICHIGAN July 12. 1955 Daniel-Harrell Clinic Hedical Arts Building 317 State Line Avenue Texsrxana, Arkansas-Texas smug-l M00 Dear Dr. 008811 Mr. R. A. Crandall or our Agricultural Chemical Division at St. Louis has asked me to reply to your letter or June 25th addressed to that office. I an very sorry to hear that you have a patient who is sur- fcring from mild hepatitis following use or our Estcron 2&5. Our studies of'the toxicology of this material have been con- ducted on laboratory.eninals and livestock, and Ihile mild hepatic have occurred, the dosages in all cases have been rather massive and by the oral route. Furthermore, ef- fects upon the hepatic or renal systens seened to appear only arter.rather large doses rare given and after other more dres- tic streets Inch-es nuctonia, anorexia, and gastritis?were ex- perienced" 'Thns, ir?the patient had stalloled the material in substantial Innunts, it could not be unreasonable to ex- pect some transient hepatic and perhaps kidney ianry to follow other primary It is recognized, of course, that such experimental work is suggestive but not conc.usive as -ar as human subjects are concerned. - As_you are probably aware, we have manufactured and sold Estcron 2n; and related materials for several years. Millions of gallons have been used and nany people have been errosed. To 0.: hnonledge, there has never been a case of syste: -c toxicity to these materials except perhaps where it has been swallowed accidentally or with suicidal intent. An occasional. case o: dernati tis has been reported, but in most of these cases, the diluent oil (fuel oil or icerosene) has been shown to be the caisative agent i T.e Sl""?ficance of this plant and field experience is not ap- 9:5ciated not one realizes that there are nar.y canton . this country and abroad ?has enployee: do little I30 Dr. Andrei 9- 9??5l 2 July 12, 1955 ?pply these materials. It is not unusual for these else buncve their clothing wet with the material for hours a men to ester d?y, He, of course, do not recommend such prac- ffi; do our best to discourage it, but nevertheless, it' 53:3 occur- Ir view of our laboratory findings and the experience we have we doubt very nuch if the application or Esteron 235 by van: patient could have been in any way related to his hepati- E13. 1 am sending a copy of your letter together Iith a copy or this reply to Dr. E. E. Bay, Director or our ledicsl Department, and thereby will ask.bim to contact you directly Iith his Opinions in the matter. I: we can be of any further assistance, please do not hesitate to contact an. Sincerely yuurs, V. E. Rowe 2-280 Building enc. P.S. I am enclosing a reprint entitled, "Summary of Toxicologi- cal Information on and Type Herbicides and Evaluation of Their Hazards to Livestock Associated with Their Use." Recogniz c; that this information does not apply directly to human beings, we believe it is indica? tive of the type of thing which can be expected. V.K.Crandall H. L. Smith G. J. Hilliams 91991.2: 1 M00 Municipal Hospital Kassel Kassel, l4 Nov T955 Medical Department Your? Wit" 2 Dr, Knecht Boehringer Co . ingelheim . 74?17 L?J?b?m? COPY A sumnary of our observations of the six cases of trichlorophencl intoxication we examined, reveals the following: All cases did not come immediately, but only after considerable time after the toxic effect, to our attention. Therefore, acute damage to the liver could no longer be observed or evaluated. The observed :hanges in the liver was completely identical in all patients and there is no doubt that there was a certain amount of liver damage induced by the toxin, although apparently minor and with good prognosis. Al to the prognosis, however, it must be cautioned that the time of observation was too short to form a definite opinion. The present late pictures after poisoning show increased pigment deposits in the liver cells, whereby the pigment is primarily iron free and there is a reaction of the Kupfer cells. There are only minor fibrotic . changes in the liver, that is only a slight thickening of the normally present periportal tissues, but not of the type of tissue growth typical of the chronic hepatitis or beginning cirrhosis. Cell damage was only found in the described case (Hammer). However, in the case of Exel, there was a viral hepatitis, "possibly because of decreased resistance of the organ towards? invading viruses. To completely evaluate the pigment, it must be mentioned that we found in the case of Cleres, during later examination, that a part of the previously iron-free pigment now contained iron. This continue our pivsozsl M00 0 - - :32. . -2- earlier belief about the nature of the pigment, nameiy that there is a case of masked protein-iron binding, i.e. a precursor of hemosioerosis. Due to the identity of the pictures in six patients, we definitely conciude that there is an efiect of on the liver. He can therefore admit new patients from your company for observation only if you definiteiy insist. However, we do think it advisabie to perform a liver biopsy on one or two of the examined cases in about-3-4 nonths,in order to observe the course of the condition. 0 With best greetings s/Dr. Hiidhirt Dr.'Schmidt 2379039! M00 .. . Etait"anke2haus Eassel Medizinische Abteilun; Kassel,ien 1s.11.? Herrn . Ingelhein Wenn wir somit einmal zusammenfassen,was nix bei den bishe untersucnten 6 Fallen mit T:ichlorphenolintoxikation gesen haben,so ergibt sicn folgendes: samtliche Falls kamen nicnt unmittelbar,sondern ers: mach lin- gerem Intervall mach der Toxiaeiwizkung zu uns.Infoigedes:ea waren akute Sch?digungen.der Lebe:,nicnt men: an schen uni auc: nicht zu erwar?en.Die beobachtete Veranderung der Lebe: was bei allen Patienten y?llig identisch und lass: garkeinen Zwei? . fel dar?ber aufkommen,da? es tats?chlicn zu einer gewissen Sena; - digung der Leber durcn die Toxineinwirkung gekozzen ist,aller- dings van offensichtlidh nu: geringem Umfang?und gunstiger . Prognose.Allerdings muB hinsicht?icn der Prognose noch die Ein? Bchr?nkung zur Vorsicnt gemacnt werden,daB die Becbacntuzgszei- ten noch zu kurg sigd,um ein endg?ltiges Utteil abgeben zurgannen. ?4 Die jetZigen_Spatbilder mach Tricnlorpnenolversiftung zeichen sich dutch eine Vegmenzte Pigmentablagerung in den Leberzelles aus,wobei das Pigment vorwiegend Eisenfrei ist and auss?r?eg?urch eine Beaktion der Kupf?epschen Sternzellen.Dabei sind immernu: geringf?gige fibrofische Veranderungen in?er Leber,d.h. nu: eine Vers?arkung des schon normalerWeise vorhandenen I periportalen reindegewebes vorhanden ,aber nicht van de: art (0 11 einer ?indegewebsvermehrung,wie sie uur chronischen Hepatitis 'oder zur beginnenden Cirrhose gehbrt.Eine hat sicn nu: in dem jetzt bier oben bescnriebenen tall (Fall Hammer)ge- funden.Allerdings ist as 33 bei fall Exel intercurrent zu einer - Enfgepfropften Hepatitis gekomnen,m?glicherweise durch eine ge? wisse iesistenzminderung das Organs gegen?ber-einem Virusbefall. Schliesslich ist noch f?r die Einsch?tzung des Pigments wicntig daB wir bein Fall Cleres bei der Hachpunktion gefunden naben,da? jetzt ein Tail de??vEf?Et eisenireien Pigmentes eisqugitig ist. Dies best?rkt unsere schon fr?here Auf?assung ?bEE?die Rift: I dieses Pigments,dass es-sicn dabei um eine maskierte Biseneiweiss? . verbindung,also um eine Vorstufe von Haemosiderien 'Ihfolge de; Indentitit de: Bilder bei'allen 6 f?tle?menescheint use von unserer seite her die Eedeutung der wrichlorphenolein? wulcung auf die Leber gelzl?rtd'lir warden daher neue Patienten :3 age Inrem Betrieb nu: damn noch zur zeobacntung Sie gen: spezieilen Wert darauf legen.Dagegen erscneint es uns 4 zwecnm?ssig,wenn in etwa 5-4 Housman nocnmals der eine ode: dar? andere der bisher untersuchten Falle zu einer neuerlichen Kon- und Leberbiopsie hierher kennen kEnite,damit wir den weiteren Verlauf dieser Binge beobacnten k?nnen. Hit beater kollegiale: Empfehlung gez. ersoas - menmm vDr.chmidt ?lyre-cs (A THE Dow CHEMICAL company mouse HICHIOAN 141-5 February:l3; 1933 53:1cultumlrs..eoicals Development American legion Building so: Fletcher 919199 I .. . your letter of January 25th you report that at the meet- ??ing of the need Society of America, New York City, Januar" gy??fn andS it was disclosed that Esteron Brush Killer and -?f-?steron 235 are being applied to vegetation using orchard - 1; 3 operating at pressures in the range of 150 to 500 - {and that _the composition applied consists generally or to ?J~E?yx6 quarts of the active agents plus 10 to 20v gallons of oil 'jtemuleified with 30 to 90 gallons of water. '_He have no in; creation relative? to the health hazards asso- . slated to such applications, but certainly the possibility and possible consequences of inhaling these fine droplets . of this composition chould'be considered. We do know that ,.certain oils can, when inhaled as a mist, cause serious respiratory embarrassment. Whether this will be a factor a'in application or a material such ss-that described above 2-is unknown to us. If this were strictly on application of . oil alone we would be particularly concerned and would ;gsuggest that persons applying such material employ a respira- :?tor designed for the removal of such mists. I question, ,howsver, whether this will be necessary in view of the ;ylargs volume or we or being applied. There is no doubt, .. however, that the operators should be instructed to avoid breathing this mist. I believe, however that this method njof application should be carefully watched to see whether any adverse effects occur in individuals making such ap- plic ations. For the time being then. it is my recommends- tion that we do not recommend this manner of ap,r:lication, but keep our eyes open and ark firms applying material in this way to watch for any evidence or respiratory diffi- culties. If such appear, then I believe that we should -tako a positive approa:h and recommend the scarier of? ap- respiratory protection. -- ~ruiu-. a: i?l rep rot that I cannot be more specific at this time with Nancwt to this Ila-art!? 15$? fr - \?q.xri .. It . -- t? . II I THE Dow COMPANY CW1 1:3 7 '4 MIDLAND I .I March?20,i1959 Me rk Rolf MAR 23 1953 Biochem Research Lab fr 634 Biochem, Res. Lab. Dear Hark'f?l' .I i?g_f By review of our conversation this morning (March 18) f- - regarding the relative toxicity of 1 1/2 to 2 gallons of Forron 2#5 in 100 gallons of water or Forron Brushkiller ?93 ?-at'the'same concentration in water, as compared with Esteron Brushkiller G. S. in an oil- water emulsion, we would like to outline theI field situation and our needs as we see Iit. :v It is a common practice on the utility right- of-ways to use 1 gallon of Esteron Brushkiller 0.8. or Esteron 2145 0.8. plus 10 galons of cil? this oil could be either 'No. or 2 fuel oil or kerosene in 89 gallons of water I . for a total of 100 gallons of mix. This mixture is used because it gives quick, uniform knockdown, does a little better Job on conifers and actually has been I promoted by some companies because it is dramatic - enough that it is easy to sell.? Nonetheless it is being used very commonly and our products are used in this I manner when the customers decide they want to use oil. The.use of.this oil has a number of problems; in the first place it costs money, it is difficult to mix with Esteron CLS. and water, it is messy to handle, it is hard to obtain, and it requires additional trucking facilities to handle the large volume of raw material to be imported. We have been shooting at a formulation which would essen- I tially give the early uniform brown-out and kill of the oil-Esteron Brushkiller mix without having all of the disadvantages and handling problems of oil. These formula? I tions which Chem Engineering Lab has come up with are Forron Brushkiller and Forron 245. You have indicated to us that Forron formulations used in this manner are somewhat more toxic to the handler than the Esteron 285 or Erteron Brushkiller formulations and 'the question naturall comes up as to what is the relative :hazard of the Forron formulations with theI oil- wateIr . . 31:55 3?2" it? .3 2.1- '47. -1 .32., - '1.iout Mr. Mark Wolf March .20: -1959 Page 2f.l3iip .. . . . Combinations. Specifically, we would like to know what the relative handling hazards are of or 2 gallons of Forron 2&5 or.Forron Irushkiller-per 100 gallons of water or as compared with 1 gallon hateron Brushkiller 0.8. or Esteron 245 0.8. plus 10 gallons of one of the above oils,.plus 89 gallons of water. This should, of course, ;'include skin irritation, irritation, possibly inhala- tion and any other tests which you think might be pertinent. fag.- r: -- ':_This infornation can be important to us in furthering jour Forron program and in counseling our customers proper- ye?1y in the use of oil-water mixtures with our present brush- killer'formulations.' He would appreciate your checking this Yours Very truly, 9 I A L. Coulter Agricultural Chemicals Development .. - . . . ., . . . . .839199 1 M00 (fa/W 1956 L. L. Coulter Agricultural Chemical Development Abbott Road Building The following compositions were tested on rabbits. They were applied as received and were as follows: Composition Reference Number Esteron Brush Killer 1 gal.- 3-23-59 - Fuel Oil 10 gal. R. B. V. Water 89 gal. Esteron Brush Killer 1 gal. 3-24-59 Water 99 gal. Forron Brush Killer 2 gal. 3?2u-59 Water 100 gal. R. E. V. Esteron 2,h,5 OS 1 gal. 3-23-59 Fuel Oil 10 gal. R. E. V. Water 89 gal. Esteron 2145 as - 1 gal. 3-2u-59 a Water 99 gal. 12. E. v. Form!) 2H5 2'gal. 3-2?4-59 A Water 98 gal. R. E. V. The test rabbits were?shaved 5 to 7 days prior to test initiation. Each rabbit had bandaged onto the Shaven and healed skin, a fresh sample of three of the compositions in as widely Separated locations as possible each day, five days a seek for one to ten applications. At the time of the application, the skin response was observed and recorded. To facilitate the comparison, the first three compositions were tested on two rabbits and the last three on two other rabbits. 989091. MOO 2 The results show that Esteron Brush Jiller and Esteron 2,h,5 05, when diluted with water only, were the least irritating of the test materials. In these tests, th-se materials caused essentially no irritation. Forron Brush Killer and Forron 2,h,5 when diluted with water were shown to be more irritating than the Esteron 089091. materials diluted with water. The response was that of mild ir- ritation accompanied by mild scaliness when repeated prolonged con- tact occurred. 0n the other hand, the Esteron Brush Killer and the Esteron 2,h,5 OS, diluted with water agg_fuel oil, were shown to be markedly irritating and damaging on prolonged or repeated contact. These materials caused a burn upon an hour skin contact on rabbits. Thus it is apparent that the Esteron formulations to which was added fuel oil must be considered much more irritating than either the Forron or Esteron formulations diluted with water;_& If you have any questions concerning the above, I shall be glad to discuss them with you. Mark A. Wolf Biochemical Research Laboratory 633 Building Phone HE 6-2776 HY It l?h?lk. c0. 8-13-32 October 28. 1959 Memorandum to Mr. George Gagnon Re: Waste Oil and Oil Drums Oil Drums A part of the stores yard on Hughes Street. Devon, has been set aside for the movements of oil drums. These have been marked by painted signs attached to the yard fence. The first pile of drums on the left hand side of the main gate is marked TRANSFORMER OIL These are drums which have no refund value but which have at one time contained good transformer oil. These should not be used for any other purpose except to handle good or salvageable transformer oil. Salvageable transformer oil means oil that can be filtered. These drums should not be contaminated unnecessarily because they are at a premium and extremely useful when planning power transformer moves or maintenance jobs. These drums should he returned when borrowed for such jobs. The second pile of drums is marked OIL These drums have no refund value and have been contaminated by material which is detrimental to good transformer oil. These may be used only for the purpose of storing waste oil. The third pile of drums is marked These contain waste oils which is intended for use in the chemical control operation. Any type of waste oil (cleaning oil, dumped transformer 011, old lubricating) is worth saving for this purpose. Such waste oil may be put in front of this pile. on skids. bung side up. -Prom time to time the filter press operator will visit the site and pump the waste oil from any refundable drums he will Mo 1' . .. a c- I lilil -. che 2 TO - Mr. George Gagnon [ind there into non?refundable drums-from the pile marked contaminated oil drum. thus retaining a refundable drum for circulation. Once empty, these re?undable drums shall he left at the site for stores personnel to pick up and return to the supplier for retunda. Haste Oil Waste oil in well worth saving for the chemical control operation. It is recommended that people who have waste oil to dispose of should pick up empty drums from the pile marked to collect it. Arrangements could be made with the etore7s personnel to have any waste oil transported to this site. Waste oil for this purpose may include: Transformer oil which is not considered worth filtering. Residual cleaning tluida such as varsol. etc. (3) Oil engine lubrication oil. Uncontaminoted transformer oil which can be filtered should not be brought to this site. but must be kept in some other location until reconditioned by the filter press operator. J.H. Transmission Maintenance Engineer. c.c. P.C. Levesque N. Grundy L.H. Dargavel R. Heatherington C.J. McKinley . Trank G. Lawlor D. Knight . Thomas MI 1.750 1 151 C. H. Bookinger Sohn 22b beie en Rhein Ger-meet; Dou Shauna}. compare -. . 1714 Eastman Rd- . Eidlend. zuohigan .- . . - use .. February 19:37 me- rerIs Dr. . . Re! The ehiorekee. negation of reiehloephenel o. c. . . Genthmal? ?Ff, .- . . we hereby refer to our 1985 correspondence on the ebeve subject. At that time were kind. Ieneugh to there yeueI - apex-1131109 with no. . .. . 137819 mm . Since our mm work on avoiding chlerekee exciton hen cone to a type 01? conclusion, we ehould like to make the result: avail. e?ole to you and are that by attachinIIgI a short description, . We hope thet we heve been able te give you, by. neehn or this . a explanation, a. contribution to the assurance 01' the . .4: triehlarerhenm acetic acid and that the eentr1butienI 3111. also be of intereet to rent 51' . . - smears}; @946 FROM SUDFI HEQLTH 8. TD v1633?814 [3.82 k374i? ?"75 - 213 (H: .cg 1"5 raga-z"! :1me 22. 1963 mug-die? General Fred J. Eelzor (3) U. 8. Amy Innitions Agency C-fi?ieo of tho Comedies General U. S. Department of Defense May Chantal Center. Ihrwlond Dear General nelson At the request of Dr. Warren c. 31183-1, Agricultural Research Service, United States Department or Amioulture, we are supplying herewith three copies or the infomotion available to no concerning the toxicity of 2.5543 (mil-dichlorepzmeoay acetic acid) and 2.4.54: ace-tie acid). True information was promoted by Dow for a petition to the Food and Drug; Administration requesting a tolerance for 253-!) in eopwauo. {Incidentelr the tolerance of 5 We a: reqlestcd was established by the Included in this infomtion are references 8 and 9 which give date on the toxicity or 2,21,5-23. In addition to this information we 1mm like to also mention that we have been manufacturing; and for eve:- ton yearn. To the heat or our knowledge, none or the nor-moon in. these factories: have shown any ill effect: on a remit of ueztmc with thoeo ohmioale. Further. many millions or pounds of those chemicals have been used here and abroad without causing. a single provea case or illness to livestock.- Tizere have been 1! row euwlainto and alleged illnesses in human due to a, hat-lever, we have never been convinced that these instances heroin foot caused by the chemical. la View of the 103: toxicity observed in other mama) species, one believe them canoe have been related to ink-D by coincidence.- ?03 moan :mprax mchD?mE 3 $3me v.8 .. - an: A can ?some vuoncoau and Eon 3 PS. manna on 3030 RES. .3593 33553339 so 55 mag on oppchon td?umu 3 dc axonougw can: Haywan no as ?puma pgnunpou on ?.393 Bug?onzaon RE noun. 2a and mung .no 393 ?an 333 ?ac. nun ?35" ?an unhoapnuob so 363.59 a? do on savanna? M94 3:335. . NW 5.. I a. 345 5303?. on 393330: 502.853 gnaw nun 00a Uri! ?ranch-0nd no yaw-?0* ?omovo>o .2: a. mcunoug 4. n. Can .. 3.x @342 FROM 5009 HERLTH 8. EWIRDWENT TO 16333812 .83 GEE) 196 CL Elli CHEMISCHE FABRIK {3 Postuuhm: CJIJnhi-?nr Sch. 8 Jun-thi- n: Mui- ziialouu . . b- nun-um DOW Chemicals Company nun-mm. McCain-both" Midland Michigan MIG-nun! A Hummu? . . . magmas-1.5mm.? WWu?hNuJu Hal pm we nu: at Un-n mm vs. Una: an. 3 am Rhein ohm/o. den 15.12.1964 Ii - .. Sehr seem-to Barren, ?brand cine; k?rzlichen Besuche: Ihrer Barren Dr. Trepp, Luce]: and Bll??teut animator! wir aimn uncut. in "lam die 130119111115 an chlorntnomncn uric- starts 301:1. die Folgoruncon ru: die betrichliche Arboitsweise inasmuch buohriebon 81nd. Kerr Silvorstoin zoigto alarm:- Int-runs. an Uberluaung ulna- Exemplar: Mason 30- r1ahtos. . 2:7. Bis houba babel: wir den Inhal?c diesel! Borichtaa unseat-1151b unset-ea Kaunas Mommies: zur Kenntnis aesobon, I1: beaonderan Hart darn! latch, die del Tctrachlorbcnaodioxin nicht alumna bazaar?: word-n an luau:- i 310 nbor don sluichen Hit-Ester! an. dun In": . ??Mc?lorph-mI-Won mun, habcn "viz' un?s Ihnon diesel: Box-1cm; ?bcrlusen. Uir machton 81.: that mum-111030;: chemo 6.1- Mon. Ihnan boron: marathon-n Vortuhrennmtorltsen strong var-tunnel: zu behandeln und nmarhalb Inn:- Firm mamas: zur Ignatius :u bringen. Hir button. can de?r beniegende Box-1cm (Var-Inch. Aurtin- dun; du but dor 2.4. au?rotendan Chlor- aha-meat?) van 12.9.1956 Innon bu. dor Lawns 1111's: Chloralcne- prom.? mulch loin viz-d and . \uneoz-QK.? thJ?-r-Ms? (3:18:13mi: traumncnen Grits .43i33--" aw.num) --. ., -. Mb I FROM 5009 HEQLTH 8. ENVIRONWENT TB December 15, 1964 I I company 0. chemical 31:113. a swan v.3:iv Honored mum? During a brief Visit with your mascara. Dr. Trapp, Luock and Silverstein we mentioned a scientific report, in which the Isolation of chloraone active substances as well 1u1ons concerning operating procedures are hilly as conO Hr. s1lvorstein showed an interest in this and ribsd. 3333a for a copy or this report. until now we have disclosed the content of ant. to no outs as we a aoh a special a nun: extraordinary danger of the to there 0. tetrachlorobcnzodioxin is not generally known. However, since you have isolated the same material from the by- products (oil) or your Trichlonophsnol procoss to have chosen to turn this report over to you. We would ask you, however, that you commit yourselvos to management policy of strict confidence with respect to this interaction and that you would disclose it to no on: outside or your. firm. We nope that the enclosed report (Experiments on the determination (isolation) or excitsrs in the production or acid) at Dec. 9, 1956 :111 n. or use to you in the solution or your chloracno problem and we remain with postings C. H. BGEERINUEH EDEN Dr. Kudszus Dr. Mort Attach-d 2520:: ?anol'afvo? 16333812 P. 34 Bfiatouu 9098991 . MIDLAND DIVISION January 25? 1965 MIDLAND. MICHIGAN CONFEENTIAL Herrn Dr. Hans Merz Director of Production C. H. Boehri nger Sohn Ingelheim am Rhein West Germany Dear Dr. Merz: very much appreciated the opportunity to talk with you yesterday and I have summarized below our understanding of the essential elements of our conversation, as you suggest ed. At the outset I explained to you that there were four Dow people on three telephones here. I then introduced Mr. Silverstein, Dr. Henry Tolkmith, who would be on hand to handle any necessary translation, and finally, Mr. Dylewski, an engineer concerned wi the development of a new process for 2, 4 ,5-Trichlorophenol. we then began with a series of medical questions posed by Mr. Silverstein. Silverstein: 1. We have isolated and identified a symmetrical and an isomer of tetrachlorodibenzodioxin. The symmetrical isomer is (German notation) and the is Limited animal experimentation indicates that the isomer is much less active. Have you any information on the relative activity of these two isomers? Answer: "No, we stopped research - it was too dangerous" 2. Do you have any liver biopsy specimens available for our M. to study? Answer: "No, since we have had no new cases for seven years. 3. Have the liver function tests or kidney function tests used on your chloracne cases been published anywhere? Answer: "Do not know". - h? ?1?2?73?1 Zfialoun 0 M7 Dr. Hans ?3:2 -2- 1-28.65 Did you note any increased incidence of diabetes in your chloracne patients, or did any diabetics with chloracne suffer aggravation of their diabetic condition? Answer: "No cases of diabetes were found". 5, Did you study catechol amines or ketosteroids in your chloracne cases? Answer: ?Do not Know". 2r. Merz said that he would check further into those questions which were answered above as ?Do not know". Dylewski (Engineer): He explained that we are considering a distilled grade of 2,4,5?Trichlorophenol as part of our product requirement. Dr. Merz reiterated that.Boehringer's management had decided not to distill this material because of the danger of the formation of chloracne inciting materials. Mr. Dylewski was nevertheless interested to hear more about Boehringer's experience with the distillation and thereupon proceeded to describe his proposed procedure and to invite Dr. Merz's comments. The procedure involves acidification of the aqueous phenate with either or 3280? to a pH of 4.5-5.5 followed by separation of the oil from the salt brine, washing of the phenolic oil with water, drying by vacuum distillation and finally distilling of the without fractionation in a graphite still. Dr. Merz said that they formerly distilled in.copper equipment operating with a sump temperature in the range of Chloracne inciters were formed presumably because of residual cations (Na) in the phenol which produced Na trichlorophenate thus leading to the formation of dioxin compounds. Mr. Dylewski asked if Dr. Herz could name a particular concentration of salt below which it would be safe to operate a distillation. Dr. Merz would not name a tolerable level but suggested that a water extraction could be better affected by use of a retainer solvent such as methylene chloride or chlorobenzol for the 989899 1 ?cu-?b .- - '1 Hans Merz -3- 1-28-65 Dr- Trapp asked Dr. Merz to describe how functions to produce a better quality product. Dr. Merz replied that traps carbonate which is an impurity in the caustic. Dr. May: was asked if he knew what the material of con- Struction of the reactor autoclave was, and he replied, ?Iron, or common steel". 3: closing, Dr. Trapp informed Dr. Merz that we had not yet received the secrecy agreement papers from Boehringer and Dr. Merz said that he would check immediately on this :ecause he was certain that they were completed and had assumed that they had been mailed. wir danken Ihnen noohmals fur Ihre weiterer Unterstutzung, Dr. Merz. ll nit freundlichen grussen; I 7/4/11997/5 Qalter B. Trapp Assistant Director Benzene Research Laboratory 474 Building bc: Hamburg Office (crate/mine) a. A. dries: S. U. Dylewski L. Silverstein LEQBQQI M00 *dgu-lu-w I ?rw . ?5'?sz ['30qu ??235. - o" 1:33? nub-HI .33. ?33 30, 1905 - TO I..- u. 3. 831'2', ".ntzraasiczal :11 J, ans J. U. U1??13,Ch131sa1 ?Jles, LZJ D. 33333, 83100 1331313230 031L.1, u? BailJing H. u. PoinJaar, 32311013 AEJ D.C., ED. MI. 4-4-78,- 9-79 :2 c: 9. 3. ?iley, 3? 33131 Ch:11calu 3-1L s, n23 ~4 J. C. Tuchr, End: 231:: Jeniqu Ma J, 523 to O: c: BGOPQO Mog c. O. ?uzcanreathzr, 6-3. 63:3. P. 2:13., 258 BuiiJia; E. 0.9JOJ1133, 6333319 ChaJ. Products Eep3., 172 LailJiE 1. C. Har'J laid: 820L133, 833 Building 3. 3. L513, Jioprcdusta 2332:2332: ,DioproJazts 0512:? 1. P. L-alssy, Bio oarsau ts K. Hansen, Uioprcs:ots lea. Uloprz?schc Costa 6. E. LJ1J, Bioprc:J Blopfc?uats 02312? c. 3-133, PraJ. Qual. ?1'J1eea,172 831101;,- U. M. 0111. 310; BiopsoJLcta C;-ntes H. J. 2320 Dioprtd-Js:811os, ?1zpchastJ Cane H. o. Bio acts Bioprcsusts 6:120? J. D. 633313313 23:23:3212, n33 D. E. Ple"ahar,21oprosuets Department, is .CJL eta Ceaswz U. 3:93:13 D1 earodocto Deca"t:anz ,Bioaecduata 03153? U. J. Ceria, Diopchao .3 Sales 91: pradcecs Costs? H. N. 213319 31:35:331231 nesea9=:J Labora.ory,1701 Uuzldirg V. K. RzJa, D151J211cal Rose area Laboratory, 1701 82110133 ?.1232 5523 - I- - I. --nH?u . - LJ: CJ lotJ J3 2.LES have 33532333 to sever-L in e: 33L :3 u? ten :39 ce1t in 0:21391. T313 confizca nalyJis to? d,_331. B-Je?-3calnqs uh: oh found in av r2313; about IUTQJJ. This material presents a definite hazard which would Panlre all the precau: ?a .a used .n 1 9 and 339=Buildiagc oreveat injury, 1? it -a process Jd at 2J7.Bu11d1ng. Don's involvezeae in shipping this caterlal to nzve?dale 010 Uoodbury also concerns :2 There is a aerial to risk to $331? employ eea, esoaciolly sin; they are probably unaware of the problem and are probably taking no Tnero is no assurance that the .9 final p. -csL eta U111 be free a? contamination. The available evidence 901 9:0 to tho opposite. In my opinion the 1? p: o?uazs should not he sold until ankwal tests obs: these p-oJus ta to be free of a significant hazard fro1 the and "elated materials. Mo . 1.1-. find-Iv. f. ..UHHQ UN .OF (L .m - .u .lLb ll. hut-I.- . a. ?IJ-atiilud Illr\\ll.l\u.l ?oo lot-I- I. lhn-sl. x; 3 lil"\ I a. I. .-. II-vl'uull ulk. . [.Ut.? GGOPQO .M00 It: I?o..lill alV-w 8t. tools. lurch 17. 1965 Hr. John Stephan: Inclooed la a sample or Mom 0 chin Ina received tron Dow Chemical Company, and-according to than 1: 1a the loot toxic coopouod they have ever exporlenced. It presumably la toxic by akin contact, a; I'll aa by inhalation. According to Dow lt la loo tines as toxic aa parathion. It la, llknulac, capable of causing an lacopacltatlng chloraooa. I would recooaend that extreme care be uaed in handling; that dilutlooa be made under a hood: and that all equlp- tent be rushed out lunedlataly. or dlapoaad or. trace amounta or thla (200 ppb) have cauaed chloraone 1n rabblta, according to how. this 1a bolas given to you to method or analyzing tor this compound in our 2,h,5-r. I with you would save acne o: it for no, as we would like to do some biological ovaluatlon_alao. . Ileaae call no it you have any queatlona. -3. met telly, n. D. one. . I . JJULZ -r 3f,?I'ai'Ch 19 1 1965 Emmet Kelly, M.D. Mr. Francis Kennedy - Medical Director _Plant Manager :7 1 11 MonsantO'Chemica-l Company Diamond Alkali Campany 800 North Lindbergh Boulevard 80 Lister Avenue t. Louis 65, MissOuri Newark, New Jersey .- Dr. E. Vilkenfeld Dr. Ed Chandler Technical Superintendent 'Technical Service Hooker Chemical Corporation Diamond Alkali Company - Niagara Falls, New York 300 Union Commerce Building .Cleveland, Ohio - Hooker Chemical Cor;oration Chief Toxicologist . Niagara Falls, Haw York Hercules Powder Company . Delaware Trust Building . Hilmington 99, Eclaware . Gentleoen: I . Mr. Raymond'Verhoeze - Dr. John P. Prawley .1 as writing this same letter to each of you. E'have talked I with some of you and you have indicated the other persons within your own organizations who should be present. f- As per these telephoned conversations, I an inviting each'oi? you to come to Midland to discuss the toxicological problems caused by the presence of certain highly toxic impurities in certain samples of 2,4,5-trichlorophenol and relatedvoaterials.; As I told all of you with who: I haVe talked. we have-been 1? doing analytical and toxicological research on this problem- and wish to share our findings to date with all the producers - of 2,h,5-trichlorophenol for the sole of lessening I any hazards to health that might be attributed to this and related products. . . . -. II ~0ur discussions will deal-only with the toxicolOgical and - 7 analytical aspects of the problem. We will not discuss manu- facturing know-how; sales, or anything else not dealing with .. II the PrOblems or health. . It is our hope'that through this meeting, we will'scquire a I better understanding or the problem and that each coopany L: [65 "111- then proceed independently as it sees fit to institute I-have- -reserved a room for each of you at the 'Hidland Country _after lunch:harch l9, 1955 I such self- -imposed controls on its production as are necessary" to insure the safety of its products. Enclosed is a copy or an analytical nethod our Analytical Laboratory has developed. Perhaps you would like to?havs I your look it over before coming here. Our analyst u'ill be available to .discuss the method with you. Club for the night or March 23, 1965. when you arrive at the._ ,airport serving Midland Bay City and Saginaw, get the Midland limousine and it will take you' directly to the Country Club. .1 suggest that we all meet'in the lobby at 7:30 A.H. for break- fast and then we will come .to our laboratory for our. discussions.' I believe we can complete our discussions by lunch tine so that reservations for your return trips can be made for any tine I .- If any of you'have any questions, please call Sincerely yours,. 27/66va . . . V. K. Rowe -. - . Biochemical Research Laboratory _u 5 - -i -) 1701 Building -. -- Phone ME 5-2375 . - - -..JLF Area code 517 . I . I . .: Win/3d .- . To Dr 0 ?rauley Please bring another person along if you wish. is reserved{51% any or. ?-vndunununai $5 lawman-L nun . . no: 5333 on ?noun-nu. no can bu. uuak 3:5. . . gugPOEpug??a?ngnga?n?uu??qonlua . walnu- uiu. 53385333. nun moan?. (and guns. . 315 Sign not ?own on. 453. 398.33. U. 333 ?Bu 5. ?2525.3. gunnin- Iun Pu ?but. ?3.x IE. 93533 En ER In.? En run unl- can wanna Sudan. gnu?.- nouagubunuol._ an nuns-Boa no H.353. En an: (I. 33.93 Eu Hmong 6033a . 93 non Eur 81% 35a. p: 832503 now ?own g5. 93:" "not. 3.3g: unmask. uwuo roan. no doubt: nuun 9n . 15H: E9 ?033 (0E v. ?and 33?. no man was can on". $533. on. now than: uh can snub-ace an: 93.3 59 wanna En aha an (can scan hula-n Ina- annual "and no 28 pa .8 can and? an! 5 05. 259305 Hagan? pan ?can tau." no E3 9. 2.5933 on Eu .993 Eon-3n pmaun. . .924 w- as 50an ?and ?don ?Juana non an no no Eu. wan Nunavut on (an an on. can add: ?and. En. 3.2.8.9. naught land we a. vouch? ?pagan. ?and ?Snowing. an nub vo - vegan ?unknown? r6. 93.3.03. 15h. undo?. .902 For. ?noun and ?0 ?ag 2.052.. an spand- pnneo no? 5 non." nub? no no gag ?nun 3 noun.? ?0 an 05 on 9? 3653 EE owns r393. can 9.. ?own-on pan 3.. 661.3. 5 a50- HEEH 19c. scanners Eu ?Havana 5 .55.?de Hon 39953.25. a. Ham" 5.33 P. fill! 3w pow CHEMICAL COMPAW W. Elohl?n lurch 29, (I. Bode Biochenical Research laboratory 1101 Building Riley J. 0. Tucker n. N. Smiley J. H. Harris 3 L. D. Grant H. H. Peinauer C. 0. B. C. Stsehlin; I. C. Anttuts C. I. Otis . U. P. False: K. I. Hansen a. 'e B. Ce Hoff .. I. n. Gill N. J. HoCoy I. O. Uiltss J. D. Doedens n. Pletoher K. C. Ban-om . V. L. Corbin H. n. ?oyls D. D. Irish B. 3. "older, I.D. 5* Jo I. P.t.rREPORT ON THE CRLORACNE PROBLEM MEETING ON 3/!h/55 [a 1 Present: Dr. J. Hilkenfeld and -- . Raymond Verhoeze, Hooker Chemical Corporation . hr. Francis Kennedy and - Dr. Ed Chandler, Diamond Alkali Company Mr. C. L. Dunn and Dr. John I. Frauley, Hercules Powder Company V. K. recapped the Dow situation in terms or the problem and the initial studies by Toxicology and Environmental Research Laboratory regarding the in-plant eituation. He expanded this in general terms to the study or end products, ours and other peoples. He made reference to emetrical He referred to the evidence tor'unknoun egens. ere were some queetions from the group about the unknowns. He (Don) were not sble to answer these questions except to review the evidence for their existence in the process samples and end products. IO D.C-. ED. 4-4- 7 8; DOW AGREEMENI 9-79 no? i I. K. Bawo lech 29, 1955 Dr. Holdor roviawad tho Iodicai aido of tho Dow axporianooi ho aaid that no now hava 60 to 10 of individuala with chioracna rongin, tron two aavaro to Iowa vary oiid caaoa that waro di ricult to diagnoao. lo ahowod aiidaa of tho aoro iha Ilidaa waro oxcluaivaiy viawa of tho racoa of tho Individual. attiictad. Ho daocribad in fair dataii tho appoaranca of tho indivi- duoia aontioning tho blackhoada apociticaiiy. no than roviawad tho clinical atudioa that aro ba aada on thoao People with aophaaia on tho livor function alto. Ho Ian- tlonod tho aingla livar biopay that haa boon takan and ocudiod in which tho iivar wac noraai although tho aan had a rathor pronouncad or chloracna. Dr. ?oidar olao oantionad tho incidanoo of tatiguo tho attiictad opia aa coin; tho onl cthor aigniticant ing in thoaa to . la touchod brior 1 on tract-ant indicating that voriouo topical tract-onto woro not particularl? ottoctiao. no doacribad tho cycling or thia diacrdor individualo who had boon lotaiy roaoved tron oauro. Io aontionod that ao-a r. lowo arc approaching and or thoir troublo two or two and coo-halt :aara artor onaat of tho akin dia- ordor. no alao daacribod 'acuto chloracna' which ia an acuto inriaanatorr condition that appaaro conaidorablg than tho nornal chloracno in individuala and appaarc Iftor pro- nouncod oingia owpoauro. Tho acuto chloracoo ahowa up within a raw daya ct oxpoauro. Dr. Holdor aontionad tivo to oight doya opaoiricaily. thoro woo conaidarablo by tho group on tho akin diaordar itaair. Tho nookar roproaantativaa rolatod olporionco or akin condition thirty yaara attar axpo? aura. Thoir woro noro to tho Dowicido buwpa which now hoa axpariancad in that thora woro la a boila or largo bu-po rathar than tha aultitudo of ackhoada and oruptiona which Dow ia oaaing in tho currant caaoa. Dr. aadok chowad alidoa of aara and livora or rabbita that had boon oxpoaad to tho oylnotrical tatrachloro- -dibontodioain. Ho tho pathology in dataii which i wil not attanpt to aun-orito. V. K. nantioncd tho atudiaa in which tho rabbit oara hava boon traatod with TCBD in bonxono or corn oil and than waahod with coop and wator at Varioua ti-o intorvaia latar. It oapoauro occura for var, long, waahing dooa iittio good. ?o briariy aontionad tho oral atudioa but without dotaii. Silvoratoin daacribad tho plant otudy on waahing or contamination from tooia and aurfccaa. Thia atudy indicated that bonxana. acatono and Chlorothana NU wora aftaclivo in roaoving tho contaminant tron tooia and that datcrgont and wator with acrubbing action could cioan up tooia and aquipaont. Sumo anaucd on tho uac (1956me .. .-..- - . . .4?oi 2.. 'thI?lhoo darlna .. - I. K. nova or data out and uatar and tho polnt soda agoln that atron; :grubbl actlon for thla approach to bo Harold 0111 than tho anolyalo tor totrachloro-p- dlbanaodloxln by vapor ohrooatography. Ha llatad tha llolt or on varioua ootarlola. Ha oontlonad tha oll ahlch ha datlnad aa a non-aaponltlabla ulxtura or ohtcro anlaolaa totraohlorobanaana and trl- ohlorobanlanol tho llolt of tor man In um ootarlal la 10 PEI. Tho ll-lt la 1 pp. for I ?-tr - ?0001. and (or his-1 told, althar aoatlo or prop onto. ppi?ll?l?var1 poak. Ha Ion- tlonad that ha night aatloota 0.5 ppo ln Iona tnatanoaa but to ba oonoarvatlva tho anoljat raporta (l tr tha paak dooa not up to tha qulta a laval of ppo. rho analytical problao haa not [at baan-aolvad for tho r-Aold aatara. Tho ganaral rooadura uaad for tha t-Aclda la to axtract tho about 20 gra-o ulth chloroforo (about to lltara), tlltar tho chloro on- to aollda and uaab alth an aqual voluoa of n/lo cauatlo to raoova any aoldlo ootarlala. who chlorofor- axtract than la oonoantratad b1 avaporatlon to ona-tanth tho VOILDOI thua, tho concantratlon of tha dloxln In tho ohlorotorn bo tan tlooa hlghar than ln tha aa-pla. Hhan tha anolyala la oonductad on trl- ohlorophenol. tho Iotarlal la dlaaolvad ln K/l cauatlc to tha altant of 10!, and thla aolutlon la than axtraotad ulth tho chloroform and handlad aa abo;a. I quoatlon aakad about tho of dataotora othor than tho Ila-o lonltatlon uhloh la apaolflad In tho laboratory Irlta-up for thla analyala. haa not trlad tha oloro dataotcr bacauaa hoo axparloantad Ilth alactron capturo. Ha atatad that thaoratlcally thla unlt ahould not provlda an: .raatar ln In actuollty ha found a ln but thorn Ira uaually too non, ohlorlnatad apaclaa praaont uhlch no, aaturato tha alactron captura call uhoaa racovary lo too alou to ha of praotlcal uaa. Ha aummorlaad by aay- In; that tho all?ht In la not Iorth tho affort to al toh fro- tlaoo lonlzatlon to alactron captura. a quaatlon aakad about how the axtraotlon la parforiod. atatad that It la parrornad In a ulda Iouth bottla on a ahakar for ona hour. It not oan- tloncd, but It to tho that thla la ona at room to-poraturt.l Ha oontloncd that aplkad aamplaa hava boon . 2: I. or.? sx' - tit-?4. . . .- sin-- :11, 3 ?Aw: rl . - - 5t?: "Jo-(br- - - I I 53-4-15 . . .. a?3igsazig4 .53' 3..- . os? o, I .. r?ugh-:ond tho rocovory runs-d tro- 90 to 100 cont. Lug or ooivont to tho notoriol being ?tr-bod - A I Joel: on thio otop io not orltlool ocoordin; to am. ?l'holl' Ionto otondord procoduro ll 20 [run 01' .0 "Huh" '1 ~r to or chloroforn. On trichlorophonol u-olu Irol??ul- 2? -.: .--.-.. or gro-o of phonol io cmvortod to phonoto -- out 10 ?You? to Ni concontrotion in rotor. Tho phonoto oolutlon io "trot-d lath with 20 of chloroform to oinllo oxtrootlm Tho chloroform io thon oonoontrotod oo thot tho oonconution or tho dloxln um b. ton m: in tho oruln-Il "010- mm In ito quootion or volotility or dloxin ooloo DP ond oom outed thot he found ho oon diotill o-diohiorobonoono not tro- totuichlorohonlodlculii. llo ooid that in MI opium thoro tho on to ovoid dlotillm to 9:13 . I I mbll' of tho group oo?atod It Iolploo 0f 1933"" out a ovoiloblo. Tho onouor on no ond 100 thou vidod to ono of tho from eta-pony. Huh hod boon (ivon to Dr. Roll: of Mom. in A quootion or ioborotory ooi?oty in tho onol tiool work? up ond tho hoolo of looting oiny [lovoo no port: untlonod. rolotlvo prooidod to tho group. 36:101.? . of contoninotod loborotory notorlolo Ind plont ?lth notorioio woo Ho pontionod thot Doo hurno oo-o . - bolt o-ounto or auto. Hot-old om ototod thot hlo i. enter, otudy or co-buotion thot 99.96 por oontd? lo tho dtoxin woo humod ot Boo'c. Ho nu . oo oo i'oit thot our prootioo of homing o-ounto or . 1 . tho dioxin woo ooi?o ono. beau ri V. I. thou outiinod tho ?roJoot in which lont ou- produoto not oontionod Horo opi od ulth on onounto tho man. Tho oglko uoro opiit [tn-tho of chockin; our ono ytlool procoduroo for Ioro ond oorroiotin; rooulto oith tho oothd. oir or I Tho quootlon ol? opociricotlon, quolity control opoclrl-tlon ootl thot to, woo roiood ond H0 uoro ookod if no could .lvo lovolo on or dioxin oontooinotlon which uoro pomiooiblo llolto. tho I. l. nontlonod thot ot no oro min; Ioro with: confidonco of 1 pp- in oonploo. Thoro woo o0:- Tho on tho probloo ol' ouotouoro tiniohod po- Toni ducto undor for doolroblo conditiono heolth outrol . Ion than no con provido our workmen in our own piont. Thu- to ho ogroo-out olon; tho [r0up that no could at - ofl?ord to ooil contolinotod producto. n" Bio- 110 007/ V. I. loo-a 5 - lurch 29. 1955 Jack retereon then the data rroo animal experi- oonte uein; puro oil-otriool tetrachlorobenaodioxin. Doeea ranaina Iron 2 porto por billion to 1000 rta par aillion or tetrachlorobonaodioaln in benzene had eon adminiaterod to tho rabbit ear. in halt caeea 0.1 ll por day. Both eingle end oultiple oxpoeuroo have boon atudied and Initlvle elpoeuroa adainiaterod on a five daya por nook beeio. 'l'ho ei itioant tootoro in the atudy aro dole, tho nuober or eppl cationa and the deyo on expoauro of the aniaolo. Tho roepouae ahich io reported in tho [roo- ob- arrvation or the condition of tho rabbit'a ear by the Thin doeo not include pathological tin-dingo -- thoro ia not onough data in thia area 0 Tho levol 0' "Wom- ronaea tro- nono through very alipht, alight, alight to aoderate, moderate aoderote to aevero, aevero, and extra-oi; aevara. Jaok indicated to tho group that thoro ia not a aha definition between theoo oata?orioa or relponoe and indica ad alao that thoro io ao-o dit ioulty 1? thie or reoponoe. He deeoribed tho roa onoe tron oinale a lice lone to tho rabbit ear tiratn at P?rtl por ail ion thoro a oevere roa in eight dayag at to porta per utilion there a all; looponae in 6?10parta por aiilion thore nae no rooponoe. Thole teate uero run on ainglo rabbita and without aeehing tho aaterial oft. Jack then tho nultiple a piicetion data which ho took froa hio anor of t?ie data. Tho important pointe that ho node tro- thia data were tirat that at tho li-it of VPC oenoitivity T"POnae In: bo produced. in other Iorda, ovon it tho Vic doeo not detect ICED, an animal reeponoe etill occur. ?ia aaoond i-portant point that tho induction period for raoponao averaged about ten dayo on tho eni-ala in tho atudiea. Thar. a brief than about tho air aa-plea that hero taken in tho lant. Silver-tein oentioned that air oa-plea have oun activity on tho animala. The de?ree ot raaponae ia a ight and tho nunber or eenpleo that ehou activity to anal out of tho total number taken and tho amount of air that nuet bo eaapiod ie very ouch larger than tho a-ount a non noruolly broathea in an eight hour day. Tho locating adjourned. Tho group then procaadod to tho Toxicology Laboratory to view eono or the teat eninalo. They uero ohoun rcaponoea of varIing inteneity and thoee Hora deacribcd. Thie dononatrat on appeared to have ooneldereble Bioche-icai Laboratory 1101 Building [03:ejl - - a?q: . . 3:4" 0 D- -v {Eitoo 8'75 1 I u. I. A a mmvmum-MM 9 ?mnnumuu I. 110?!- m, a bi- Imf m.mm?mm m. mmwunu.m un.mun. a: num . mmunmumzu . . . :u "mum ?t um?HIWHtm - n: mulnwn I. IO: MC nmumau.nu mwmm.anw .m .11 {1 00w CONFIDENTIAL Ishsger ts' webs-issl cf caisson . lsroiss cm. In Assaults: was 1 here not been neglecting your rsquest for inrorustioo to use is discussing the sthect prohies sith Isugstucx And the Co-Op. 1 have hseo strsied, hosever, hecsuse the sethods hsvo hoes sod sre is the process or being olesrsd end . rsproducsd. sxpect than say dsr. but anther ssit longsr. gagu;nt I should sdvise you or the situstioh.- sill send you copies of these sethods ss soon ss they heoo-e svsilshle. . 1. regsrd to the oversll prohles. so otto-oting to do possihle to svoid possihlo or chlor- gans in say spoliostione involving the or uso of tri- ehlorophehol. trithlorophehoxyscetio soid sad its dorivutivos. is you sell thou. se serious eitustion in our opsruting?_ tecsuse or ooutssinstioo or 2.l.5-trichlorooheooi sith i-ourities. the sost sctivs or shich is 2.3.7.8-tetrsohloro- dihessodiosis. This ssterisl is toxic; it hse trssehdous potential for producing chlorscne systesic in- :urv. .1: it is present is the trichlorophenol. it sill he ssrried through into the scid sod into the esters sad hence into torsulstions shich to he sold to the puhlio. One of the things shich se to svoid is the oocurrshos of say sons in I so concerned hers sith per- sons sho sre using the ssterisl on dsilr. rspested Issis such es custos operstors us: use it. 1; this should occur. the shole 9.1.5-1 industry sill he h-rd hit sad I sould sxpect rostricti legislstioo, either hsrring the ssterisl or putting vorr rigid eootrols upon it. This is the Isis sh: se so coo- eerosd se up our son house tron sithih. rsther biting sossons tron sithout do it for us. In this ssr. so Ivorosch the prohiee is es orderly ssnoer. l: the produoero sod hsodlere or this ssterisl sill cocooroto. thero is so rinses shy se osunot get this prohlcs under strict control had ?bir?br hopefully svoid restrictive legislstios: is other sords.? 1? ?0 Drectice good citisesshio. it the present tile. se 'f opinion ssterisl oohtsihihg no totruohlorooihenso- dioxin sith certainty of you does not proseht.sh sporsol- :51. to consusersz lihssies. so do sot helievs euoh {dottrisl eohstitutes significsht to persons sorting in Add 1 ?guy:- ":10 1m 1114?" u: mum" gau 01? In: 3 m1 uteri '0 - 1 mm 1W '91? .0 ??1113" In? #1191. canny-1? our nun-dun on 1111: can sum-19011:: or "11671:; 0:11.? cap-361:1 to product 1111: :rp-o 1.1101 no la nun-9:131; :a mutant" 01'- umggu lb?! added :0 has. u:cr111l. ?11. bu: 1: I111 be aux-A1 ?13:15: 11087- 00w CONFIDENTIAL Juno :965 1' or A314 nun. can: 11' your 51; saga-1n wen Go-Op 9131:1111:- ?ms: :51. pron.- :uck In" and huf??u :23? :o co- :0 111411114 when 11111 In :53: 3 annual :80 ?guz- 1n 40:111. 111:1: than and show the! uj?hl'. 13:11-93:04 or unused. v. z. hc' nub-31:11 luau-ch lab-1111:1317 1701 3.111413: 3 6-2376 '08. "147 8:31ch:11 3:11.11: - ma '1 3?71. '0 ?3130? K. ?70?012020 ?P?apandcnu Dado:- no uremia: J7 m: :11 no: 1187 ?unsung to I14: our problcl 1nd?- . buy or and. bu: In :It'tanl! do an: :9 Inn any 31:11.3:1033 grin 11111:: U111 can. ??uuggw apex-=1? :0 bacon Jun? 13 :o "014 :1113. I trust an: 11:11 11111 be 31.1131?. 13 r9111- a: :81: pruu': CL- 1: could 11111? ?bu-nan? 11' 1: an :ncu lay H11: 10?? to real-61:11:66. Ibo-a. 01:35-31: :0 amen-1 1111:1140 at Don. -- . - . LI W. J- . ?Mu W?d/ lop/?lnrn 710 18 012 - .D?zu H/rrmr a7: CHLORACNE PROBLEM - CONTRIBUTION 770131;? THE File: - oil/.5 5C swans? th?w An outbreak of chloracnenin the trichlorophenol process t: rn. in 199 Building and in 3&9 Building has resulted in approximately no cases of chloracne in Dow peeple.' The outbreak'was precipitated primarily by a series of process changes which increased the pro- duction of a chloracne-producing impurity in trichlorophenol. Increased exposure to operating and to maintenance personnel also contributed. Much effort by persons in the Analytical laboratory, the Toxicology Laboratory, and the Environmental Research Laboratory has resulted in the isolation and identification of one impurity which is capable of having caused the difficultyland has .3130 resulted in control of the exposure situation so that no new cases of chloracne have appeared in the last four months. Some important questions remain to be answered. There is evidence that other compounds than the one already isolated and identified and studied are capable of producing chloracne. Their significance in the trichlorophenol process is not yet known. Chloracne is a skin disorder characterized by the appearance of black:heads and small bumps. These appear first'on the face of the individual affected. Depending upon extent of exposure, the skin -disorder may spread to other parts or the body. Infection and 'irritation of the skin rash may cause enough discomfort 95-4Hnr -l in time lost from work. This he ened in two mum]. to 1'35 11: a? - pp of the trichlorOphenol.cases. The materials known to cause chloracne in humans are usually chlorinated complex organic molecules. The compound isolated from trichlorophenol caustic insoluble oil is eggeedioxin (symmetrical). This compound and others which have been shown to cause chloracne have also been shown by animal tests and some human experience in other companies to produce liver damage if the exposure . is:more extensive. Thus far, no liver injury has been detected by clinical examination of the affected Dow people. Inc aspects of the ailment are distinctive and somewhat frustrating. First, there is a latent period of approximately two months after sufficient exposure before the disorder is evident on the person. Secondly, once a person has contracted chloracne. the recovery period is from about six months to two years for the cases which Dow has encountered. In some instances, the Europeans have encountered recovery periods as long as five years beforecthe man was completely free of th' chloracne. 3n moo/WOO 4 ?Wmeuu ., TOXICOLOGY RESEARCH In 19ul, Adams, Irish, Spencer and Rowe.of the Biochemical Research Laboratory published a paper in Industrial Medicine on'The 1:111 ReSponse of Rabbit Skin to Compoungs Reported to Have Caused Acneform Dermatitis?. They described the-enemal test using the rabbit ear, which has been extremely valuable in the studies or compounds which may cause chloracne in humans. The rabbit appears to be very sensitive to such compounds,'but it is non-specific, that is, the folliculitis ;:hich occurs in rabbits does not identify the particular agent. Another 'shortcoming of the rabbit test is the period of time necessary for the folliculitis to develop. There appears to be an induction period? or approximately one week for the dioxingrhereafter abbreviated Td?zs) to produce folliculitis in rabbits regardless of the severity of exposure. There is damn evidence that produce folliculitis in_rabbits with a shorter induction period. Before a particular test sample is exonerated, the test is run for four weeks of repeated daily application to the rabbit's ear. 7 1 In lth, research in the Benzene Research Laboratory prOduced a severe case or chloracne and toxicology studies on animals showed that the probable culprit was a chlorinated double ether prOduced from the experimental solvent being studied. At this time. samples from the tricmoroPhenol process were also studied and the caustic insoluble .oil was shown to be active by the rabbit ear test. There was no human experience with chl?racne in the trichlorophenol production group at (cl-A - that tim?? Th?fproduct was shown to be inactive by animal tests.v In 1955, a number of German manufacturers or trichlorophenol and at least one French company had human experience with chloracne that caused them to shut down-production plants and to study the problem. their studies contributed ?2151 to the medical {picture ending?"- to process improvements, but not much to the toxicology of?th-e situatior The Germans a: isolateadthe T631) and (go. some limited animal studies on it and on some chlorinated dibenzorurans (diphenylene oxides) but this "as/very limited amount or work. ?I?ney -did even less 1m evaluatgn .9 we exposure; of their people which led to the injuries. ?7 In 1957/ a series of process samples were acquired from 199 and 399 mildings and tested on animals. The tests indicated that the caustic insoluble oil and coil reactor. product in 199 Building were active and that the tar from the color stills in 3149 Bandingwas also active. 'Ihe precautions first recommended in 19145 were re-emphasized. There was still no human injury-in the trichlorOphenol pr?cess. About 1956, impurities in trichlorophenol produced by and IDOUMOU v?f Hooker were isolated and studiei by animal test and shown to be inactive 'Wne. Over the years, some samples or end prOducts such as Silvex. I. Egonnel, and 2,1: S-T acid have been tested on animals and in no case i was chloracne activity detected in .these products. rL process if In 1952, supervision of 199 Building sent/sanplesni?rom the then existing process and from a pilot run We?? the a decrease in the caustic W3. ?Ihese samples were tested on animals and again I 1 ?5 -pr - 5 - the caustic insoluble oil was shown to be active but no more active in the new process than in the old. The Biochem report reiterated the ecautions necessary in handling the oil and the change was made at 199 guilding. There was still no human injury. When the chloracne outbreak occurred in early 196h, many more process samples were tested on animals with particular attention to the caustic insoluble oil. Two samples of this oil were dramatically those tested before or since. These two samples killed the rabbits when applied at the same concentration as has normally been used. The oils had to be diluted to 0.1% concentratio before the animahssurviVed and showed folliculitis. The normal test concentration of caustic insoluble oils up to that time had been 10$ dilution. Subsequent studies on the T0313 haves?ji?icated that the amount of TCBD in these two samples of oil isfnot sufficient to cause the death of the animals.t?ln July of 1964, the rabbit ear test was used for the first time on wipe samples of the building equipment and surfaces at 199 Building. The wipe tests indicated extensive I contamination of 199 Building. This test has been repeated periodically: 'to the extent that over 600 animal testg1have been run since last Julyavi (,directly related to the chloracne problem. 7 1 A representative oil sample was selected in August l96h to be fractionated in order to isolate and identify the chloracne-producing 1mPurities.?b8kelly of the Analytical lab isolated a number of fractions which were identified,among them the TCBD, which was also by SRElly fromkbenzodioxin. The tw materials were identical ig?tseae 91' infraredyandqzelting point", and both showed extreme activity on the 5 m-Azn ?345 g' It?? 9H mnoMOG .. I '6 Other fractions indicated little or no ctivity the animals rabbits' (v .., Hm cit. ar? . 77? The isolated material was utilized by VP to standardizes method for I I detecting this impurity. Harold Gill's group in the Analytical to has consistently improved the sensitivity in process Labora ?ail/Mk! Lac" I samples so that at .the present about 1 ?(014 TCBD may be detected in various process samples. However, the animal studies have indicated# L. that rabbits are sensitive to TCBD down to approximately upo I repeated application to the ear. The rabbit test remains the most sensitive method of detecting acnegenic activity. ?new, fingle .- application studies on TCBD indicate that parts per million are necessary for a response so that we does provide a first step in I evaluating the hazard from TCBD specifically.? ny wipe samples and l/ a or . I ch mated I of acti ty, how er; ?ank Varr: wipe samples with no detectable TCBD but subs?axial amounts of unknowns many have shownractivity on the animals tnajn canton: be accounted for by the 10w level of-diox-i-rr-which may be present. chlori ted dibenzoi?urans' we-e :st- . on -- u--ls .yet \Res a 9-: g1?) ?j?Sh' acnege c' EC V1 Y- The 83mg *Qy :1y\\y g" . i \v?kkax??w.? -. wbxx?g a . \girli 2.71 I) i ?1 -7- purified and tested ain on animals The Do ibili exist that th se - Tc are pos bilit has ot en inve?st?m'gat as yet- More detail on the results of process sample and wipe sample testing on animals will appear in the sections under specific building .811. IUOUMOO - Studies are not? in progress on Dow and productsj?and those of other manufacturers for acnegenic activity. Thus far, no Dow and products have shown activity on animals while some other manufacturers end products are showing activity on animals as well as detectable- dioxin by VPC analysis.- The Analytical Laboratory and the Toxicology Laboratory are presently conducting a project to determine the .nalytical and animal test limits of sensitivity for TCED in various products from-trichlorOphenol. This project is aimed at - 713335 developing a quality control specification for-the-dtoxin in consumer products. 122 BUILDINQ The first animal test: on trichlorophenol process material: was conducted in 1935, at which time the caustic insoluble mil was shown to be active. Precautions were recommended at that time. The secOnd animal test took place in 1957. The caustic insoluble oil was again active and the coil reactor product was also active. Other -- Process samples were not active. Precautions were recommended again for handling the oil. . . A - 3 - In 1955, the C. H. Company in Germany asked for information from the Givaudan Corporation, which company referred the request to Dow. A letter describing the hazards and precautions for safe handling of 2,h,5-trichlorophenol was sent to 35:1nger with a data sheet from Biochem enclosed. The letter answered seven specific questions regarding our own plant experience. In 1957. Bcginger sent Dow and all other known trichlorophenol manufacturers a letter describing the research on chloracne in the trichlorOphenol process. The letter described the danger points in the process and the limits which had to be observed in order to avoid producing acne exciter in and tn 2,h,5-T acid. A temperature limit of for the reactx?h was In 1962, the above?meatieaed?animal test indicated that the ct emphasized by Boringer. caustic insoluble oil from a 73% caustic process and from a 2h$ caustic I process were the same intfhat they both produced folliculitis on animals [hfc?ng'l C. about the same order of response. The Biochem report reiterated 1 the precautions but stated there was no evidence of increased hazard in'i . II In July 1963, 199 Building started up on new tetrachlor?ipenzent the new processWhichmcaused linep kaygging problems and increas exposure of Personnel according to thersuperintendant. In November and December of 1963, the Plant ran at capacity. The caustic insoluble oil production was above normaIand the oil was drawn off more was also being ?ampled resularly. The samples were taken.to theflab for freezing point; anEleis. The temperature at which the plant process was run was also . BIT IOOUMOG fr 3/ a d? . -) 1n: the first medical report of the case of 0? January ?196?: I Laborato survey by the Environmental Research ryinitia chloro henol anger? tit-11 e/Ope?ato? Job was studied closely and a report - Marianas; changes in the procedure and in personal ued on 2/5/54 re 1? habits Same changes in the oil draw-orf equipment and lens ?75 re were already initiated before the Bwironmental Research procedu under wav- In the spring 0f 195?: process equipment changes survey 80? - 733?; made by the Phoenix Sprinkler Company and at this paint, the caustic insoluble 011 sample-3 which lilled the animals were taken at the plant. ?1n July 1954, the fifSt Wipe samples were taken. Thebuilding was found to be extensively contaminated. Some air sampling was begun at this No activit was found in the air samples.:FIn August 19616, We . ?me 712133;, .. 7113.2: 2. detected he oil was fractionated, Mum?- 7P f4-u;bl7' isolated and identified, and was also In ?an-31 of 1964/. 67:54: Meme?W Phoenix Sprinkler men, some area shOp people, and more 199 Building employees developed chloracne. Wipe samples indicated continued contamination. Extensive clean-up measures were undertaken. Wipe samples showed improvement but not complete eliminatiOn ?of the contamination. Err?Wm.? In late Qctober l96h, there was .a flare-up?of some existing chloracne cases in 199 Building people. This was brought on by enposure to hot fumes from a screen in the phenate product line. Animal tests showed-that this phenate was active and that the screen residue was extremely active. This phenate went to 3149 Building and is the probable cause of the . ['73 I . .the safety precautions which were used were satisfactory. These - 10 - rev/l" three cases which eventually appeared in 3H9 Buildingf?7about November 1 1953? very stringent safety precautions were instituted in 199 Building. These included a full-time health supervisor oa=:l3y whose Job was to review each and every maintenance or installation 5::n.to specify the detailed safety procedures which the men should follow. Clean-up activity continued and extensive modifications-of equipment and the building of an enclosure the process took place in November and December or l96?. see-essay hundreds-of outside personnel were involved.' Wipe tests indicated improvementcin the contamination situation and air samples.EE==a showed no activity on. the animals.? . - In 1965, the full-time health supervision continues. analysis is now being used for quality control or the phenate leaving_ the building. Wipe tests show substantial.improvement. However, air samples are beginning to show activity on the animals, although i only one air sample thus far has shown detectable dioxin by 230 3 analysis. A very significant factor is that to the present date, there; have been no new cases of chloracne since the institution or the full-ti health supervision and extreme safety precautions. Two cases have appeared at Medical since that date, but both or these have shown that the individuals were in the area and had possible exposure prior to the: November data. Since the induction period in-people is about_ two i I months, and it is now approximately tgcne months since the heightd/of 3?t1V1tY in 199 meth the many outside personnel, there is evidence that precautions are being continued on Jobs in 199 Building. IZI T?nn?A?? ?am? - 3kg BUILDING Sodium trichlorophenate from 199+fuilding is received-hy?d? J-m 339 Building where it is neutralized, a tenefold con- centration of the material to provide crude trichlorOphenol. This ?aw "wet feed" is.bact through a drying column; the "dry oil" is then distilled in two color stills. i} The first animal tests run o?L349/samples in 1957 indicated activity only in the tar from the color stills? This was mild activity, less than that demonstrated by the caustic insoluble oil at 199 Building Similar samples taken in early 196? again showed the tar from the color stills to be active. Samples taken in October 196h showed activity in the wet dry oil and againIthe tar from the color stills. The product was still not active.on animals. Samples taken in November 1964 showed activity again in the wet he dry oil and the product ass inactive. The degree of activity in the crude materialp?uas less than that in the October samples. i The conta hated phenate the end of I ?was October 19614/\was prolgessed by 3149 Building. 2?11") pipe fitters and 7an operator at 319$: early 140de cleanfg lines and changf?g-valves in lines which had carried the contaminated phenate. The actual exposure that brought on chloracne in the 3&9 - 9 Building personnel .is not definitely established but this is the most i 11k61y situation which could have caused it. i In early November, Clare Bailey, 3&9 BuildingJEuperintendent, issued a written sheet describing precautions to be taken because of the . 321 Innu M00 - 12 - otential hazard. This resulted from the 19 experience and was promulgated on Bailey?s initiative 85 8 Precautionary measure. About the first or this year, 1965, objections by workmen to working in 3&9 caused the adoption of full-scale protective measures in that building in regard to the trichlorOphenol process. Further complaints caused the extension of such precautions to the entire reactor room, including the bisphenol process. Wipe tests eventually indicated that the bisphegglnie'free or contamination. In fact, only limited areas of the trichlorophenol section show contamination.' Clean-up and further wipe tests are being delayed until process equipment has been moved to a new location outside the work area of 3&9 Building. Extensive clean-u; will be necessary in the alleyway behind 3&9 because of contamination ?rOm the trichlorophenol tar. A health supervisor is now stationed at 349 Building and full being taken on any Jobs where exposure is-possible. Onlf WW three cqhesqhave shown up at 3&9 thus far, none since the incident in early November. '1 Composite samples of finished trichlorOphenol from 3&9 have 'been run on animals at either a 10% or 1% concentration in'Dowanol;EM. Under these conditions, no finished product from 3u9 has shown activity i on animals. Quite recently, VPC has succeeded in loweringtiensitivity or four TCBD in trichlorOphenol to about 1 ppm. They have since ana1Yzed some retainer samples and found some with detectable plus-unknowns that appear in the same place as the chlorinated benzorurar Theae samples were extracted with chloroform for analysis. ?The chlororoi 3?remiss. when?iiaced on rabbits'ears, are showing activity :3 - 13 - Another tar, the catch-all tar in 3&9, has shown some slight activity on animals. This is the residue from catch-all distillation for 265 Building. The "catch-all" material itself did not show activity 1/313 I?nnM The tar from the dichlor still was not active. Tar, onude product and final product from gnowicide process a currently being studied 1r_ . 2: on animals. 4knowicide 3? in the past has bee mgarded as a potential chloracne-producing material. 257 BUILDING Finished trichlorOphenol from 3&9 is processed in 267 Building to 2,h,5-T acid and to 2,h,5-T esters. Pracess samples taken in early 1965 showed no activity with one exception. The residue from the sodium salt filter press showed slight activity on the s?Wrab?i?ear. ZWipe?to-s-te in 267 Building are still in progress but show no activity at this date. - man experience in 261?wmuld-indicat no problez in the past, a- but the ..- exposur?re?I WW pmoblems if contaminated materials are processed at 267 Building. 262 BUILDING . A number or Doyicides are produced and packaged in 265 Building. BentachlorophenOI, tetrachlorophenol, and others are among the products.' Pents- and tetra- have long been known to be capable of causing chloracni -5%B)%uman expeztence at 265nth indicated no particular problem; onlym la zona? occasional case through the years has been reported at Medical. At the esent time, two individuals, an Operator and pipe fitter, have been A - 1n - reported to have mild cases of chloracne. Process samples are currently being studied on the animals. - No ?1pe testing has been done as yet at 265 266 BUILDING Three cases of chloracne have been reported from 266 Building. None of the processes or materials in 266 Building have been known to cause chloracne in the at. I a proximity to the Dowicide lant nee?-5 ,ui.li JDro 4h - tests in 266 Building cess samples??g?the parahydroxybenzaldehyde process have also been tested on animals since the most significant case is in an Operator on this proces None of the process samples were active; only one wipe test @313 the nobilu elevator in the warehouse section)was active on_aninals. This elevator has been decontaminated and painted. It is difficult to explain the contact which resulted in these three cases of ohloracne. 206 BUILDING i This building has three cases of chloracne in Operators who hav~ worked on the finishing and packaging end of the 6X process} 6x has bee i known as a chloracne-producing material for many years. The cases in th? building were reported to Medical in the middle of 1963. Study of the a finishing end, distillation and drumming-off of 6X, indicated numerous I sipportunities for exposure. The process was not running on 6x itself, bu "l on ?unocuou jfterial using the same equipment and the circumstances as i the Xe . {he Hipe tests were made of the equipment and area but no, 6X was detected in any place. dfz? m. h?process equipment'has been idler ipe tests on-Lt indicate- [an i . 'l i 93.! .. i175 i It 1 in the last two years, approximately?? Many of these samples have demon- - 15 - 61 contamination. This equipment 18 presently being cleaned up for . other sex-quagrecaotions are being taken. The anicide 3 process will soon be moved, in its entirety, to 206 Building. Plans have been made to study it thoroughly in its tial operation in 206 Building. 205 Buildins 1?3 a neighbor of 199 Building and m: this reason ini the question 0f neighborhood contamination from 199 was investigated by means on wipe tests in spots likely to have been contaminated by 199 effluents. None of these wipe tests were active. Some wipe tests at 199 itself indicated a rather quick drop?off of activity with distance from i the vent on the roof of 199 which was the source of roof contamination at that building. 1603 BUILDING ?k Bradley's groan in Research Laboratory has been . studying variations orrtrichlorophenol process. Two or the group contracted severe cases of chloracne about two and one-ha1t years ago as the result of exposure during laboratory runs. There former work area in 29h Building and their present work area in 1603 Building were wipe tested and no active samples were found in either place. I laboratory samples have been submitted by this group occasionalf I 'strated activity on the animals. i I 1:714 BUILDING '7 VidiBEr?B group inABenzene Research lab has been studying the II ~"rrent trichlorophenol process. Ripe samples have been taken of the work areas in 473 Building. Those that have been completed showed no 1 931 1000M On I 5. - 15 - actiVity' BUILDING The Haste Disposal Department handles the caustic insoluble 011 from 199 Building and the tar from 3&9 Building, both of which are active. Wipe samples have been taken in the tar burner area. Soil samples were also tested and wipe samples or the vertical tar burner are in process., Some activity was found on an area around the tar burner. Waste Disposal has been advised of necessary precautions. Other possibly contaminated effluents have been discussed with the Haste Hater group of Waste Disposal and arrangements made for necessary precautions when calied for by work on waste disposal lines. Larry Silverstein Ma?cb 10, 1965 L/im'tl? Jd L211 V30 .s A. 225 "an/I. $53? . . LORO SCUMAR . innate-1 mantis-191131115. PGZBIOMOG .- ub?msnenoi and derivatives an: Dow hot-assets). I. Hercules .D.arnond and Hooker. Dow and Hooker isolate and 11151111 the trtt'nlorophenol prior to sales and use and analvses of samples =9 oF-the: 1 sales products show n__o exciter present. It 15 suspected that 2 Hercules also distills the trichlorophenol as samples of their 2, Ii, S-T 1.1 Diamond and Monsanto do not isolate the tri- <9 .Lort. to purify it, but make all derivatives from the sodium salt. 5 o. Monsanto 2, 4.5-1? acid shows 3 - 8 ppm. exciter, and analyses of Diamond's sodiumtrichlorophenate shows 8 - 24 ppm. exciter. II. .1 T-Znowledge of Toxicologg T".l .ere are publications in the medical journals alleging chloracne respo nso from 2, 4 5- acid and derivatives. Based on 0111 dam we can readily see such a reSponse can occur from imoure 2, 4, ths' 2, Q, S-T will not give this reSponse. We can identify one- of- :he so walled exciters as 2, 3, 7, 8-tetrachlorodibenzodioxin. It has seen isolated iron: the Dow trichlorophenol operation and has been ivnthesized. Chemical structure and biological activity of each has been an?; mod. it is one of the most toxic materials known causing not only 5.1111 leshns but also liver damag . We have demonstrated pos.tive ac.ior. ?732 parts per billion and equivocal results at _-0_parts per biLio.-. .. 1 We have din: :ioped a quantitative analytical procedure .vhich will analyze for the anchor at 1.0 ppm. sensitivity. Over 500 53.1an3 have been analyzed and biologically checked to date. We have also 'solated and identi?ed the tetrachlorodibenzodioxin and it is presently Leing checked for biological activity. In addition to the identifiable materm ls. VPC shows some 15 additional compounds which are of unknown activity and identity. Further research is required to 1501111.: 11.. 1:11? these materials to determine their significance. The miss i' this entire study is that the re is no quantitative relationship to 11111111 reopense and human response at the present time. - LE. Contacts with Trigger-omen o1 Producgrs V. K. Rowe has had telephone conversations with the Medical Di rectOr. - .nd Assistant Medical Director at and the Chief Toxicol 0325?. at We. Rowe has discussed the problem and has given them our methods. These men want to follow th1ough on this problen. are in favor of a meeting with all the trichlorophenol product. Since Rowe has no contacts at Mend jaguar-1d,, Lou Corbin o: .. .taproducts Sales will make these contacts requesting their designate: get touch with V. K. Rowe. This will be done March. 1,1965. Rowe wi- :Tet ass the problem, them to the meeting. and offer our -..ethods. IV. nosed Me 't of?l?. ce .. A race. or the trichlorophenoi producers is t: -nt..tively scheduled [55/ On March 11 ?965 in Midland. The Chief Toxicologisth ..Ied?ical Director," 0" Mecical Cc eultant and a fro. . and company will- attend. .1113 agenda will be. . I - A . 16773813. 3.35 'Kaf'. :yu- nti??eJ-x 1.. ..-. -2. Ci) . 1. Dow review the literature on the subject. a 2. Dow discuss the toxicological data we have to date. :2 3. Dow to sell the group on the?tdea the industry must police itself or the government will. 4. It the producers accept this philosophy, decide if we should and who should go to the appropriate federal government agencies. V. Status with Boe l' 0 Ge - a. In December 1964, Dow sent a team to Boehringer of Germany to discuss the ehloracne problem. Boehringer had the same problgm, solved it, and have Operated 5 years safely. In Germany a. verbal secrecy agreement was made to the e?ect that all oral and written process know-how received from Boehringer would be held secret by Dow for 10 years and Dow would pay $35. 000 Ior it: use. The team received Boehrinser's process details and ?owsheets while in Germany and various - pieces of corresPondence since they returned. Our new plant is designed on the basis of this Mow?how. At the present time written. legal secrecy agreemem is being negotiated. cf .. J. D. Docdens Chemicals De artment March 1, 196 ch. cc: V. K. Rowe - . .. 'l-u-e - I o. . . Jib'W??n?vP t?il' c.5591" .. .-. - - . fur-7 - - -- ?nu-Lt- rat?a1 'ztu-u-s-M?muu- - - - 433" MIDLAND, Michigan August 16,1956 c. A. Highhill 2,4- -3 Plant u89 Building -- - where the trouble starts. Because of the concern aces: run anir3l tests on the lack of hazard, even if Mesa 3. SilverStei Biochemical Research 1791 Building Mum cc: E. C- F. C. AmStutz, Herbicide Sec F. I. Chase, 2, B. B. Holder, .D A. w. Uilson Safety V. K. Row.e Biochemical sters :ne LaboranrrStaehling, Org. Chem. 258 Building tion, ?ul Building Echucts, 409 Building Medical Department, 60? Building Department, Research Laboratory 4V- Buildi: I would like samples from your fir st run with 2 trichlorophenol in tne?direct ?at er process. The animal test will detect the presence of onlzracne- -produ:ing compounds. a Please send me a sample of? the final product and any intermediates that you think be tested. If activity is detected, the intermediate may tell us I think we should for a time prove first tests are negative. .- us? I63 II: all! .ll" wage." THE Dow CE-IENIICAL COMPANY minus DIVISION UgliV? S?ja April 25, 196r . K. E. Coulter - EEQ Midland Division Research a Development .7 3: - 555 Building .. . 4: ?gs neynh CHLORACNE RESLARCH .. . . ?9 History of Chloracne Incic?ences at Dow: -g Historically, Dow Chemical has been involved in chloracnc - incidences ever since Dow began the production of chlorog?1.nols. At first, the cortercial troduction of chlorophenols was 'eondu.ctcd at 206 Building. During the period 1934- 36 was a severe outbreak among the employees which resulted in . an unsuccessful lawsuit. The chloracne incidents were tzaeed back to poor working conditions and th .e manufacture of Desicide P. The manufactt.re of Dowicide has since been - terminated. New and improved working facilities for the I Douicide group were constructed at 265 Building in 1940. the lat 1930's, Wes toesser in 20A lab got a serious ?;;.chloracne att-ch from ch:crinated diphenylene oxide. Drastic -1 :treatnents were used to cuze this incident and no further were was done on this series of compounds. It is suspected that many of the eher inciden-es of chloracne are caused by .chlorinated diphenyler oxides or analogues thereof. Jg..;yq.r.1n the next ten years, another unfortunate situation occurred in tk.e chloracne situation. Some of the Dow customers comp- ained :ige?wf abaut dermati is end/or ch3.oracne from the use of Dow' tb993l+ Dowicide 3- I understand :inancial adjustments were made an 01er production of Dowicide '5 terminated. A purified material 01 related structure is-no. sold as Dowicide 31 and 32. During the period lab?55, the product (di'phenyl oxide. crlorinated to the hexa lc:vel) has manufactured at 206 Building and at least one severe case of chloracne occurred because of this product. The production of 6x has been terminated. In the research lab at 172 Building, there were some cases of_ chloraene from research exposures. In one case, a severe case resulted from the recyclins of residues from the manufacture of S-trichlorophenol using glycol as a solvent. In another - case, several nild cas es occurred hydrolyzing using aqueous caustic at high temperature. The Chemical Phy: ics_ 1e.b had several incidences of chloracne from the recycling of . caustic insolubles in the alcoholic caustic hydrolysis of . tetrachlorohenzene. - v? Fr: - aw?ecause of the prevailing existence of chloracne in the Dowicide _;;"plants and a sincere desire to reduce or eliminate this, research pr ;"_factorily. _to experience chloracne incidences in their employees1963: the hydrolysis step at 199 Bui?d?r was modified for'economy and safety reasons from the use of 100; caustic to 23% caustic. Tne rabbit test for chloracnigens in the caustic insolubles obtained from a pilot run at this time indicate that the test response for chloracnigens showed no difference between caustic insolubles obtained by either procedure. ring the latter part of 1963, the production department, in order to increase capacity, raised the reaction temperature and increased the throughput. This meant that more caustic insolubles were -produced, and more Dempster loadings had to be made. This meant that employees had more exposures to the caustic insolubles, and the caustic insolubles due to the higher temperature had larger concentrations of chloracnigens. Thus the higher concentration of chloracnigens and the more frequent exposure caused many mild incidences of chloracne in 199 Building and two severe cases In 1966, a new process (Boehringer) was put into operation using a batch reactor at low temperature, and so far has operated satis- '1 After they started up their Dowicide plant, the Canadians began In Midland: more than half of the Dowicide employees have chloracne of varyin5= intensity and it is impossible to say when or where these incidenc - ;.oecurred. . - ,.Research Program in Progress for Chloracne Reductionr ZL-IJ. has been initiated in 1966 on this problem. Progress has been due to the complexity of the problem. The problem involves risolation and determination of the identity of the chloracnigens. . After being properly identified, work can progress on its reductic or elimination in the process. '~In commenting on chloracne, we must keep in mind that chloracne-x .is a cosmetic evidence of the attack and serious liver damage. is an invisible effect of the attack. Rabbit ear tests are a positive sensitive method of determining the chloracne activity of chlorophenol impurities. Present Knowledge of Chloracnigens: Compound Activity 2,3,7,8 Tetrachloro - Very positi' Cll-e - Not active Cls-7 - Possibly some cpds. actin Cl, - Not active Very active a . 'Activitz -Very active C11_f. - Unknown activity 5 C11-2 4 Unknown activity - Ola-5 - Some very active -Liki 614-5 - Some activity? '61; -.Some activity glained'chloracne activity: Some Midland batches: are mild --. . 'l__ia - Many Canadian batches are mi: 73'"f reactive _w Dowicide -.-- .r All sludges are active ."Compound bin-.11 All decompositions are ac?* . - Some have activity Midland Research Prozram on Chloracne: I. - The following chloracne activity fractions are being examined I I for isolation, identification, and minimization of chloracne activity. Unfortunately, due to shortage of technical help, the program is proceeding quit slowly. - l. Dichlorophenol still residue. 2. Pentachlorophenol process samples. 1- a; Dowicide 6 and 7 "active" batches. .. [We b. Dowicide . sludge. '1 c. Dowicide scrubber sludge. . ?f The method of research is to?first concentrate the sample (remove r; 7? -chlorophenols); then fractionate by chromatography; test fraction on rabbits, then further fractionate by chromatography, then test fraction on_rabbits; etc., then determine structure by micro ?Yanalysis; then determine method of analysis in original sample- and then investigate process changes which will minimize the chlori acnigens in the process. -- The Benzene Research Lab_and the Biochem Research Lab are collabora- ting in this project. The Benzene Research Lab does the chemical research and the Biochem Research Lab does the testing on the rabbits on their charge. a: i. _?Uf 1 Alex Widiger Benzene Research Laboratory "474 Building H. Haberstroh #7h Bldg. C. Sauers, #75 Blc.g. L. Bender, 172 . . C. Staehling, 258 Bldg. . Silverstein, l70l Bldg. . - 1,bxrr- 15.1957 13 5'2. . . . -- Corbin. rm!- 7 -. - 9131:2315 - - - .- - 4 1. 11.19.91}. ?53: .: - 2-2. .. 931:. mm?. 11.12.. 607 . camp/am; 51". Laws. 1.1501111: I .. f: nan-.3? z. 3151?. . 3. Meta-,- -: .a 'rhat a. 3221'. L4. 5. . . pgg?py 2! ias-Jgnl -16 tulled' .. cw indicating that. 111:}? - - . bad had an -cc132-1 :19: ?and with the manufacture :11 m. 1:10:2- -. pun-11. and tiny his: 501:! .c Imp-n 61th wE-g?: 11:: 12611,": was" cider-11:11:. Tut-5r woa?srrd 11 we could advice than: :p I .- _-madiu1 stature. I 331597. Win than 1:11:11! 51:. .- .- Eucgicy and with him nadicai narrate of tin pmbiem. _1215 my undamlaadirg 1: cm 11:15." 112:: {Jacki-J). . 1111.311": 12.11: 1.13 ahead 11-. chunk: try a! 1:11: 1:222:131. 131' - i, - - that. be (:1.ch m: In 11:53:11 It? 3851-5 thin 11:13.. "'22?'23 .1. a 35513: rpm-L317 7 J'Iuctc'ay 1:81:11 1:19. to 3M1 and-111 we Essa- about chmrarna cans"! by 1131-211 .121 materials non-echzed with f. .. rmnuh?nma :1 from ten-a; ?.arabanlc..o. I - .. -- 15.12:: 11110.91- c-:La1n circa-1111351112. c.1111}: 1a.: nut do?: -- - the (2111.311: 12:91:11: 01!: cauLl tannin 1:31:51: ammo amount: a! :1 . . 12.131117 13:1: bub-32113:? wa 1111:! 1335:1311?! an 2. 3. 7o 5'5. . 1 1:12 :1-1:d to 111:1 tun: this mazes-131 I '_ij ran: an mama? systemka?y. ha 1: was also an 3 ?ctau cbhraccogan.' 11:51:11:- :d that any has been manna; somi' i? .11 or tax: ccmiclng unis-.111: wbc- ?211 oparawua so! on! a! coma}. - and Ch: 11:11:21.3! e1 1119: 3:511:11 or 11 2:311:35 011.: a hot 33:11:13?? [in -- . ;13:H:u3113 that 1.1-1.1: and 1-3301: :1 13:1 Ind caused thala- 4131:1127. I 1016 21.11:: I 11111 11.11 11:11:51 1.11.: 9:110 was caused by 215- 522;; 5.3523 amok?. by. 1912.22 11.171151: gar-germ: 91-33223 12113131391081; flail?: ?Tilt-In Ih. vIolnalaor. .1 car'I know-.- hunt: or 53-411. at lean. Bicep you Informal. It you have any quaszieaa or 9:13- . .- . .-. lluIIn-rr do maII contact . 5-, ROW. (2) [1:91- I F. foessar -.-.-.- .y?lur? E. Disco -2- 25. .35? (-p?rfh?y Hr. Ewhiay Ind aakad L2. ?31.213: ban a; (39:33 L?s: m? and .Jr. Laid at Indicated t: [11: :23 :23: ?3.23 extrema [adding aha use ?1335: can: =23 8-3733 and - its-pinion. H3 Owned aurprlaad Ihat ea 9:513 a?mzd cub ?cu-veto man-urea. but I ?hunted that cab pmma wan we bounced nonseary. H- mm ?and I: ham: Li I Ituugh thy lcouid clean up It: ?autumn-d equal-paws: an?. 1 tag: :3 ._ooInI an oasgmm to Ian biz-:3 LEM mean: can Its-wow! I: can}: Inn. simply buss.? I: uould If.) mandai. canals; E: c: zccr' mains. and dapcaia ?least-hath This ca: um ct: my I: as? 75:! II II. he 0 3:05:06 acruhting down 12:. eguipmaa' win 3:333:11, or . . - I when?. Iain-and that Ibis could I: be :36. 01:3: ?233 all - m-crssary pracau?an: mu taken to prevent ?=th #45 poo-?x - . I mqgened that ha assay or Ink: cam-5:13! of the eqniweas ta d?ermino the damn: a! csnlamlnation. I I113: this sharia In due.- boioxc and hitter the clean-up. liq 0:232] 1:137: cub assays - could be Rude. 1 ixu?iirgwd It: him Ihal we Ind developad a 5:92.08 I31 catalysis! and Mac uao-d bloI-agicai 493:: nmponlaa a rabbit oaz. Ho aid no! ask me for details of than procedural). a: I tiid not give Ital-a to him. _hthca ookvd Ins-are I: could infarmzzic: abaui chlaracm. and I Vququorcd Io sand him cuplva of paragon: ch: published Iiuratur- which I anO-Ihiu anal beer. Can. comrraalloni with .19. buxhiay mn- WILJD I3: [rams-I: at our of Ibn pran-vm. Tb: Inks-mane!) as It: plays! 01?;ch activuy us pump- oven Iona Ila-1n was gaan In th- ucbar {we-data? - m? IricIiIordphanoI out a yearngo. This ?39 basauao II on! ri?e?37 app: rem Inn-3173.2. nucklay bad male 23:33.12; of Ibn teak-6:031:51 {opens 01 his prom-m. had In nomad tor mam. can. I would hair-v nip-nod Ia and Ihnm Io 'Owsv: v. 01:40 In 6.8 not. I naeInturmauon In 05 any vale; to you. butli-o oi i Ira-ant: . 4e - 31%? I -. ?liai- . I - Chloracae 1'11: ?if? l?h C). I4 mums. MICHIGAN July 25. 1967 OOGQN1.. 14:60Bioprodocte Sele5.1123?. ?42. '1 a - - 13': cc: W. L. CIoIrhiIh. IBPC 1??2'33; - .. I I ehprechte very much your note of 7/17/67 to. which you informed me .I . I. that some Diamond mterhl he. opporeotly caused serious akin prob- 2 . lune "11?38 the mterm. 11:11 you don; with report thet recently eppeered in the South Ame rim met-stare which .etetee the: materiel; o1 thi- nature have tho been noted to have I i. 3231 caused unnu- IdIu?cultiee. II encloIeILng a copy of this publication ., :10! WOImuon. "3 . - - "g-J-hihr 'n?z It would opp-er that our predictions of low yarn ego ere hegtnning j: to come to gnu. unfortunately. Frenkly.I I emI IIrnlIghIty glad that we ?frtookthepoel?oovedld ..-.I- . 3E3 . 2? .1 4.1-.- 293954? retina to IhIeIep meII beet can . -. . I $27-2; . v. x. I 7. Biochemical Research Lehoretory 7v . '1303 Building . 2: - I 3? . bcc: . K. Rowe (2) - - -- 5.3? Correepondence :j3 . - - - ??tf5?1" unmouwmt?rz!* -w-pp-uw:qe-yq .. def-~13. W?n? 058 pi u?tha quyt/ I DEUCE Biochemical Research Laboratory The Dow Chemical Company ACNE PROBLEM AT File: T2.l-18-2 PLANT. Date: 3/21/69 OW CHEMICAL OF CANADA By: L. G. Silverstein .ned Date "hecked W1 Date 3. 6 7r :3 . co PROBLEM Workmen in Fort Saskatchewan have experienced chloracne. 'here may be another skin rash problem related to the weed killer peration but this has not been diagnosed definitely by a physician. FINDINGS An acnegen was found to be present in some process samples, Specifically the Dowicide product in the reactor and the Dowicide product at the packaging location. In addition, a sample of crude dichloroohenol showed slight to moderate activity, and the caustic insolubles in the Liquor settling tank showed severe acnegenic_activity in the rabbit test. No acnegenic activity was found on a series of wipe tests taken in the and weed killer building. Laboratory studies on the decomposition of chlorinated phenols nave indicated the definite pnssibility of an acne hazard from overheated or decomposed materials. - RESTRICTED: for use within The Dow Chemical Company only. CONCLUSIONS There is not enough exposure during normal operations to active materials to explain the degree of chloracne seen in workmen at Fort Saskatchewan. The housekeeping observed and in the wipe samples I collected 6699M Mile"! during my visit in October of 1965_indicated satiSfactory housekeeping in the penta and weed killer plant. Unusual exposure from maintenance or clean-out of equipment such as the dryer, or from accidents such as overheating of the dryer may have caused the severity of skin reaction noted in tne workmen. Personal cleanliness is of primary importance in avoiding skin problems and minimizing their severity once encountered. The instructions on the second pag _e of the operator' 3 manual for tr? Saskatchewan should be Follo-xed conscientiously. "Dow wil. provide a complete change of clothing for each operator, each day- This clothing including shoes, hats and gloves must he left in the lockers proviced. To assure adequate cleanliness and hygiene, a shower must be CHARM by each operator prior to -s leaving the Company 0?9mises at the end of each shift." 'scussions ring my visit in 1965, indicated that D: :edure had been relaxeu an at least not enforced by W9 g} uoervision. It is my firm opinion that this is the most 3 important step that management can take toward improving the situation. ea Anv unusual exposure should require immediate and thorough shower and change of clothes from the?skin out to minimize the probability of inJury. If exposure to airborne fume or dust, for example from the dryer during clean-out, is to be encountered, an air supplied hood should be a required item of clothing._ Men should not be allowed to work in the evicinity of such an unusual exposure unless they too are protected from inhalation of the airborne material. 2 6. A clinical definition of the skin rash described by Kasanovich would be very helpful in determining if there is a second problem on the weed killer side.' Skin condition of the workmen afflicted should be followed clinically in order to determine if progress is being made in eliminating the skin condition. I I 00b9MMr11 pentachln 1 .T For: HasnatCIewan ?perienced an outbren? cf 5 A series of wipe are sum-nari :ed in Table 2. All es indicating that at the ti me of the The milc activity the lac of the acti vity in wipe samp cf the most likely exposure: that .. (f ifficult to rationalize workmen at Saskatchewan if that is, to the normal Drftess ;f the 0? ant. on the other hanz, s? {-01 ubl es in the Liquor ?er to decomposition prcduct of 2 2::r nwn-u, 1' . a?l- p?1cess samples Fr-m ?;rt Saskatchewan tests in t? sur?er t? process an: the sever: T'1?nh?313 ?-PscorQr-?P: - '9 - . "gowlcide tumps.' La 2 skin condition 25 . blackheads and burns "heparint on the face of cha?aCtE ized a . a? 5 .3 +na=v?oual afflicted, some: mes :preacirg to other parts the bod:. The ccn--tion need .0. many geaoccup pat :ohal hazard :h the owicioes, ruthenate).- plant has its nurmmen. Test 3 on -re zed i.n nable l. -: 133 atchewan plant we"? Free of activity hruseaeeping was good. perJct samples, and nius the physical nature the solid Dowicide make in of the chloracne in exposu"e was "routine," normal operation - rhse to thevcaustiv - .3 uf animal response laboratory study I 5 4 e? ?n Table 3 indicate the pcssibilitv that nonroutine sumr?F+Z ?es to Uverneated homicide cr Tame: either duri expcsu - dr' tr resicce in cl 1. . malfunction o? the c.3er c. -1 -ue - ean ?g out the cryE' oerhaos cleaning out the Liquqr settling tank . - ?av have brrught on the nrcnouncec in the persons affected. From the descriptinn cf his rash tv Peter Kasanorich related t; the weed killer .l .5 w- law there may be a seccnc sh-? operation. This needs clarifying by a clinical examination of men. According to Peter Kasanovich the rash appears and .deabpears rather and is related to worxing and being off work on week-ends. This is not characteristic of chloracne. It does sound like a rash Which occurred in Midland many years ago and was associated with nroduction. When a bleaching step 'was added to the 2,u-D prcress to remove ud'? and color the rash disappeared along with improvement of the product. Careful attention to nousexeeoing and personalcleanliness may eliminate this problem. T) I h!e ,mber 0 Ud Samgle DC Fr?om reactor 50% in bottoms From 50% in CHCI3 "ector effluent From bottom nut 20, 50% in Illed still [jwnn?J?Eu 94K In CHCL4 Prude i?arn0, Still Same, ;ul mi ed dichlr" tank fines In FHFIQ 'a heads in (?"713 35?10% from rcactor 50:26 in CHCI3 tn batCh 10? 50% in CHCI3 Unolled penta From Flaker (65h05) Same, 50% in GHCI3 Pentn :Eanwv, Same, Animal [gilucggus None 31 None NI None. None. None None N-er Name None H-nc ?l?Mvd NHHQ Slight ?lizht Slight SFSEML i?ht Slight Peanunses IiurWI Yes Yes Yes Yes l?Yes Mb. Appl. I ?.131: EQUrmnre nu TChh/gm [[19 $13.31;? a '7 tested 100; dw' 5 1 100%_ (18} 3? (1 100%, a? St? (1 100% n' 3(4 (1 1001_ n' 5? ln?? dn? 1? lgr)1 (31' -. 11 100% ca! 0} 1? HM 1001 MW 6 du1 45/. 13 100% d1! Mi?? II. r?dl I QC 3 Hill Lf?. .Hm>m? ?Lump .LOprocm>? dub: c0 :mam m: mm.?mb .wmavcmn rd? ncotu II noo?h nccovm .n on m?nEmm .Luu?n tCOUmm .mOwum no moavcmc mm:rm: .ampm? ucoomm on umLau .Hamnucmm .Ame cyan vmeruu r; wruum LJOHH umL?L II I..mu I . r?I mu? Lm?nhx (I) GI .mumuu__ trauma .mm?vcwn I- no umwxn?: .aoLw wy.m quumwc 0 Ca mmavcmn . 4.0Luc0c II Lw3va a? .Epzz :ptuu .ncnmor. name xnmu m.LoumLmoo . ?appero mno-cucmm .E;oz :op.wun ?pawn .nrnm Etna 0, Log? .umaucmr I- LopuwwL mucwa II 2me m.Luu?Lmnu .ubryn memnu no mm1.:mx .Hun annmm wuumn c4 :Upmg nF(ED. .wnmvum,p . .5 Huang u..~wnmw :mmc mo.u .n Lem: mm >Hu> . I .Ecun meou? =umpJu: .hw ?Lamwr cucr:3746404 'hiALIIHLWJILI . I I I (U I II rut/I. II Jutd II if) (E) able 3. SamoLe umber STUTIES ax 0? CHLORC nu. Aopi./ -Rabb1t samole ?escrietion Yo. Pays- Resnonse Sodlu? 2,3-dich-cropnenate residue 13/19 Moderate Endium 2,3-dichlorophenate fume condensate 13/22 Scdium o-chlurcehenate. fume condensate l-?2l 31-32: rowicide fume canden?nte 7/11 severe :pwicide fume czndensate LL Cl Severe Sudium 2,u-dichlorcnhenaze conzrel Nnne Sodium 2,H-dichlorenhenate held 7 hours at 35/2? None Sodium 2,h-dichluroohenate held 7 hours at ?/11 Slight Dowicide 16/22 None Ecwicide held hours at ll/lh Slight Dowicide residue from overheated sample from 205 Fuilding, below grate in fluid bed dryer 12/13 Mooerate 90:29:21. Milt; DISTRIBUTION OF REPORTED ADVERSE EFFECTS FOLLOWING EXPOSURE OF FIELD WORKERS AND APPLICATORS TO FORMULATIONS SOURCE YEAR OF EPISODE NO. OF CASES GOLDSTEIN ET AL (31) 1955 3 MONARCA a BI VITO (S5) 1960 1 TODD (30) 1960 1 BERKLEY a MAGEE (11) I 1961 1 TSAPKO (81) . 1966 . GROUP WALLIS ET AL (87) 1966 1 PA661AR0 ET AL (53) 1972 1 OTLQ 5&9! A00 HUMAN EXPOSURES TO PHENOXY HERBICIDES, CHLORINATED PHENATE 8 T.C.D.C. COMPOUNDS PHEN. HERBICIDES ACCIDENTAL EXPO. PURE PHEN. TRACE RITA HIGH T.C.D.D. HIGH T.C.D.D. NITH PURE HERBICIDES T.C.D.D. (0.1 1-39 TCP (N0 PHEN.HERB.) T.C.D.D. INFREOUENT REPETITIVE INFREQUENT EXPOSURE EXPOSURE EXPOSURE VI A NONE . RURAL INDUSTRIAL NONE NORXERS NATIVE) SEVESO FIELD 3,000+ UNKNONN (200 CHLORACNE) INOUSTRIAL (1950-1978) If}! MOST APPROPRIATE POPULATION FOR PHENOXY HERBICIDE STUDY 1,500 (800 CHLORACNE) MOST APPROPRIATE POPULATION FOR T.C.D.D. STUDY 09gzch?DO 520! SEVESO NEN INFORMATION RELATING TO TCDD HUMAN EXPOSURES FETAL NASTAGE NO SIGNIFICANT EFFECT TUCHMANN-DUPLESSIS - REGGIANI IMMUNOLOGY NO CHANGE IN IMMUNOGLOBULINS POCCHIARI OR 8 CYTOGENETICS NO DAMAGE TO PERIPHERAL PARLIAMENT COM- NORMAL FETAL TISSUE MATERNAL BLOOD MISSION REGGIANI CANCER NO DATA AS YET 11w DOWuuzmsz NOILDNHASAU BSHSAUV 03130d38 DOCUMENTED HUMAN HEALTH EXPERIENCE PHENOXY HERBICIDES N0 EFFECT 0.5 21 ASSOULY, 1951 2.0 SINGLE DOSE SEABURY, 1962 LETHAL EFFECT >80 NIELSON ET AL, 1955 >2000 DUIDLEY 8. THAPAR, 1972 0993604400 ?075 DOCUMENTED HUMAN HEALTH EXPERIENCE - PHENOXY HERBICIDES MORBIDITY FINLAND MORTALITY SWEDEN FINLAND REPRODUCTIVE--TERATOGENICITY AUSTRALIA NEW ZEALAND RIIHIMAKI (1978) AXELSON (1977) HARDELL (1977) RIIHIMAKI (1978) GOVT. REPORT (1978) REPORT (1978) 4? (NEUROLOGI CAL) EEG FINDINGS - POOR STUDY CA CONFOUND. AMITROL. CASE REPORTS TUMOURS NO 4? MORTALITY NEGATIVE NEGATIVE 908 }3 IE :3 C) . Aavnowwnd oxaava' AENHIH - 3190101vw3H HHAIW SEHAZNH TVNHONHV - - NSIWOSVLEN oanau wvaaHdlaad - - EHBILVA oanan 13A31 3300 ONISVJUDNI - 3N3VHOTH3 - HINS - '30w 9 3x33? 9 - I 3iw313As wvuanaa -. . 816T - 056T SLNSUIDJV GNV WVIHLSHUNI GU31 GELHENHDOU . 1 War .p-W-h-qnu ?F'l'v 0F DISEASE -- .- - ease; a: EFFECTS 1-8 WEEKS -- - mass 1 .. I 2003 207 ER . 0 uni-Inn . 9F mm ALL mu 10' mm: EXPOSURES HAVE RECOVERED FROM 8R IN 1-2 YEARS EXPOSURE - I .. .4 nun - ..-v1In- 1- I 0F EFFECT -- CAN-ONLY EXTRAPOLATE FROM ANIMAL DATA UNKNOWN 20?? Gsasz'mMOO . .m?mao . W. . .. ?-45.3 - I 5CD - mo CASES WORLD-HIDE SINCE 1930's . .3: ?vi-A" H- I. .I: - I Iltii II ii. abmunazeOo - . - .1: limit? ?9.55at! muons . . . . - ?ism EXPERIEII mum IIBICATE svumzsaam -- - AT BEST ONLY A HEAK CARCINOGEN CASES HAVE HAD OVER-EXPOSUE -- HAVE NOT SHOWN ANY OBVIOUS CA EPIDEHIC NEE STUDIES NEEDED l' A snug-u. I .r-?MLr. EUR . - u-b- -2 mums one?: mum PETABOLIC a 34'sz manna: CARDIAC EFFECTS -REUNIDGICN. owes FATIGUE - mans . OURACNE ND EFFECT - -- ?131 aDow Canada Contact; Stephenson 519?330?3500 i 10 nada Inc. "an: Wolski Chem ca a K'Pfgwaox 1012. Sarnia. Ont. N7T7K7 Contributors. Dr. Richard v. I June 30. 1982 (as reported in Need Science Socier o; eno 155 . of America "Newsletter" October IE neeas - RISK IN 5?an 2.4.5?1' EERBICIDB Environmental activist group! hav- been demanding the ban of on the premise that it increases the risk of developing tumors. Dr. Richard Wilson, a Harvard scientist, disputes the 2,5,5-1? and tumors theory, however, he recently calculated the risks associated with spraying and found that if a person worked at applying with a backpack sprayer for 5 days a week, 4 months a year for 30 years his/her chances of develOping a tumor would be 0 1. per? million. Those conditions would represent a probable exposure level far greater than the general populace, even if they lived in a spray zone. In comparison, other risks associated with developing a tumor are: Chancea Per Million Sunbathing 5,000.0 1,200.0 Being in a room with a smoker 10.0 Drinking one can of diet soda uith saccharin/dsy 10.0 Drinking milk with aflatoxin or eating four tablespoons of peanut butter/day 10.0 Drinking one can of beer/day 10.0 Eating 1/4 lb. charcoal broiled steak/week 0.4 I Smoking cigarettes DOW CHEMICAL CANADA INC. Modeland Road. PO. Box 1012, Sarnia. Ontario, N7T 7K7 August 19, 1982 Mr. T. S. Thompson, Epi? Public Affairs Hanager . [lfL 1 New Brunswick Electric Power Commission 4 527 King Street Fredericton, New Brunswick E33 4x1 Dear Mr. Thompson:' The attached letter and documents pertaining to the safety of phenoxy herbicides were sent yesterday to the enclosed list of Atlantic Provinces daily and weekly newspaper editors as well as two magazines covering the region. Nb broadcast media were covered because the complexity of the information does not lend itself to 60-second explanations. The letter of transmittal is self-explanatory. The point is that there is a great deal of scientific evidence attesting to the safety of these products and there is no substance to alarmist claims. Please feel free to use the information enclosed in any appropriate manner. Extra copies of any item are available by calling my office in Sarnia (519-339-3131), our agricultural chemicals sales representative in our Halifax sales office (902-429-5623). or write to either location. We hope our initiative will lead to more balanced news coverage of the safety issue and result in a better informed public. Yours very truly. Harold H. Major Manager, Government Relations Agricultural Chemicals Ikan Man?uy? - - au- DOW CHEMICAL CANADA INC. Modeland Road, PO. Box 1012. 'Sarnia, Ontario, N7T 7K7 Augus 18 1982 News Editor The Daily News 4&6 Main Highway Halifax, N.S. 259 Dear Sir: Recently the phenoxy herbicides and have been ?in the news? in the Atlantic Provinces because of allegations that their use for brush and weed control in forestry and on right?of-ways involves significant risk to human health and the environment. These pressures have resulted in some suspensions of proposed herbicide applications until ?further study? can be undertaken, particularly in Nova Scotia. That has unfortunately strengthened some people's belief that the risk may indeed be real. In viewr of the current controversy, we thought you might like to have information ?which summarizes what the world's scientific community knows about the health and environmental impact of these two herbicides. We also thought you might be interested in knowing the relative risk that these compounds pose versus other risks people readily accept. In actual fact, so much is known about the effect of these two herbicides after more than thirty years of research and use that it is reasonable to say they pose thousands of times less risk to human health than sunbathing, for example! The herbicide most recently* in question is a Dow product which, in its concentrated form before dilution for use, is 62 percent 2.4?0. 40 percent a small~amount of an emulsifier, and the rest light furnace oil. This concentrate is diluted for actual spraying at ground level by mixing it with about 140 times its volume of water. This is a low volatile formulation which minimizes evaporation and drift. It isn' necessary for you to read all the information enclosed (just skim the summaries and conclusions sections) to gain an insight into the huge 504? of data that exists on the effects of 2, 4-D and 2, a, S-T. threover, application rates embody an additional hundred-fold safety factor. *Trademark of The Dow Chemical Company Ql?o August 18, 1982 Page 2 If I can help you understand and interpret all this science for your readers, please give me a call collect (519-339-3599) in Sarnia. Yours very truly, - . . L70 Luu?1.h~ I D. R. Stephenaog Director of Corporate Communications lkan Enclosures: (1) ?The Risk In Herbicide? Dr. Richard Wilson, Harvard University, as reported in Need Science Society of America newsletter, October '81. Dow Canada Backgrounder #155, June '82. (2) Summary Of Pertinent Facts? - Backgrounder #159, Dow Canada, July '82 (supported by a bibliography of 135 literature references). (3) ?The Phenoxy Herbicides, Second Edition? Published by the Council for Agricultural Science and Technology, August ?78 (Note Summary on pg. 1, para's. a 5). (Cites over 190 literature references). (A) ?What 56 world-Renowned Scientists From Eight Nations Say About The Safety of The Herbicide - Backgrounder 0160, Canada, July '82 (based on the results of the June '79 three-day Diapute Resolution Conference On 2,6,5?1, Arlington, Virginia. Journalists can obtain a copy of the complete lOZ-page report from Dow Canada). (S) ?The The Herbicides 2.4-D And - Forestry Commission Bulletin 157, United Kingdom, 1977; by D.J. Turner, et a1, (Cites 2A2 literature references). (Note Summary on and conclusions on pgs. (6) ?On the Matter of Dioxins In Our Environment" - Backgrounder #131, Dow Canada, December 1980. 2:4. ?g/vsm YOUNG - - RESULTS FOR ALL CAUSES OF DEATH Results of the analyses for all causes of death combined total mortality) are set out below, for the total cohort, and for two sub-groups of the total cohort, namely those with year ?rst sprayed of 1959 or later and those with year first sprayed of 1958 or earlier. These two sub-groups were selected since there is evidence which suggests that diesel oil and used transformer oil was routinely mixed with the herbicide in 1959 and later years. If this is the case, these two sub- groups would have been exposed to a different range and mix of toxic agents. Total Cohort The SMR for the total cohort, for all durations since ?rst exposure to the herbicide, is 154 (CI 126 to 188). based on 98 actual deaths versus 63.55 expected. The corresponding results broken down by durations since ?rst exposure to the herbicide are set out in Table 1 below. 511% 23 YOUNG I TABLE 1 ACTUAL AND EXPECTED DEATHS, FOR TOTAL COHORT, BY DURATION SINCE FIRST EXPOSURE Deaths Duration A?aal mm 8MB 0 - 4 6 4.47 134% 49% - 292% 5 - 9 8 5.95 134% 58% - 264% 10 - 14 12 7.91 152% 79% - 266% 15 - 19 14 9.95 141% 77% - 237% 20 - 24 19 11.09 171% 103% - 267% 25 - 29 25 10.32 242% 157% - 358% 0 - 9 14 10.42 134% 73% - 225% 10 - 19 26 17.86 146%' 95% - 215% 20 - 29 44 21.41 206% 150% - 277% 30 and over 14 13.86 101% 55% - 170% 25 and over 39 24.18 161% 114% - 220% 20 and over 58 35.27 164% 125% - 214% 15 and over 72 45.22 159% 125% - 201% All durations 98 154% 126% - 188% 63.55 Therefore, for the total cohort, statistically signi?cant excess mortality is observed for all causes of death for all durations combined (SMR 154, CI 126 to 188), for durations 20 to 24 years (SMR 171, CI 103 to 267), 25 to 29 years (SMR 242, CI 157 to 385), 20 to 29 years (SMR 206, CI 150 to 277), 15 years and over (SMR 159, CI 125 to 201), 20 years and over (SMR 164, CI 125 to 214) and 25 years and over (SMR 161, CI 114 to 220). SMOGER ASSOCIATES A PROFESSIONAL CORPORATION California Office: ATTORNEYS AT LAW El Texas Office 1333 North California Blvd, Suite540 14800 Quorum Dr, 314119550 Walnut Creek, CA 94596-4521 Dallas, TX 752406745 (Z??mwm anmn%8m9 March 10, 1994 Paul Merrell, Esq. 7493 East Five Rivers Road Tidewater, OR 97390 Re: Moyer v. Dow Dear Paul: Enclosed for your information find copies of miscellaneous documents regarding the above case. Should you have any questions or comments regarding any of the enclosed, please advise. Very truly yours, SMOGER ASSOCIATES Cerson H. Smcger (?lag ENC . Kenny Crump, 01/26/94 at 8:00 a.m. Ruston, LA Dow Representatives 03/09/94 beginning at 9:00 a.m. (4) Midland, MI Andrey Watson 03/09/94 9:00 a.m. Bay City MI Herbert Nigg, 03/14/94 9:00 a.m. Orlando, FL Benjamin Holder 03/16/94 9:00 a.m. Punta Gorda, EL John Doull, 03/22/94 at 9:00 a.m. Kansas City, STILL TO BE SET Harold Gill Marguerite Leng Donald McCollister UPCOMING HEARING 03/14/94 1:30 p.m. Plaintiff?s Mbtion for Additional Relief Motion to Compel Dow?s Compliance with Court Order dated 03/19/91 and Defendant?s Motion for Reconsideration of Order Compelling Discovery and Motion to Intervene and Protective Order before Judge Hauser, set by Dow MOYER V. DOW 836.1 RDS INDEX OF FILE 3PLEADINGS 3-1 V01. V01. A-3 Vol. A-4 Vol. A-s V6142 A-6 Vol} A-8 Vol. A-9 Vol. A?lo Vol. A-ll Vol. A-12 Vol. 10 ll 12 As of February 9, (01/05/89 (06/22/89 (08/29/89 (01/22/90 (04/17/90 (08/03/90 (04/18/91 (05/30/91 (10/18/91 (05/01/92 (12/01/92 (03/01/93- 06/21/89) 07/24/89) 01/03/90) 03/23/90) 07/05/90) 04/18/91) 05/30/91) 10/15/91) 03/26/92) 11/30/92) 02/25/93) A-13 SPECIAL PLEADING SECTION A. B. C. MEMOS B-l Main B-2 Info B-3 Info Dow's Renewed M/Compel Bob Meyer?s statements Dow?s Pet. for Writ of Common Law Cert. Statements) Moyer?s Appeal of SJ for Occidental Memo File re re Helena Pennwalt CORRESPONDENCE V01. V01. V01. V01. V01. V01. V01. V01. V01. V01. 0 (11/21/88 (1/2/90 - (03/29/91 (10/01/91 (01/22/92 (04/01/92 (09/01/92 (11/01/92 (02/01/93 12/21/89) 3/28/91) 09/30/91) -01/21/92) 03/31/92) 08/31/92) 10/31/92) 01/31/93) 02/28/93) 1994 (Bob Moyer?s (03/01/93 03/23/93) Vol. 11 (03/24/93 06/30/93) Vol. 12 (07/01/93 01/31/94) Vol. 13 02/01/94 0000000000000 LONHO DEPOSITIONS (see for Practice Video Depos) A Statement of Robert Moyer (3/20/89) 0-1 Statement of Robert Moyer (4/29/89) D-2 A Robert Moyer (2/13/90) Vol. I Robert Moyer (2/13/90) Vol. II D-2 Robert Moyer (2/14/90) Vol. Robert Moyer (2/14/90) Vol. IV D-2 Exhibits to Deposition D-2 Robert Moyer - Video Deposition Ken Swanson Dw4 A Keshav Setaram (2/27/89) Eghibits to Deposition D-5 Nick Sassick (3/22/89) D-6 G.K. Carpenter (3/22/89) Recorded Conference Call Among RDS, Dr. Epstein, Dr. Ellenbecker and Dr. Clapp (11/21/90) . D-8 Recorded Meeting of RDS, Robert Moyer, Dana Kinney and Ken Swanson (11/3/90) D-9 Dana Kinney Telephone conference w/Bob Moyer 4/91 D-11 Telephone conference w/Dr. Samuel Epstein Statement of Bob Vincent D-13 Videotaped Deposition of Robert Moyer (7/31/91) Questions for Bob Moyer for Deposition D-15 Andy Price D-16 TCF between Heidi Garwood Dana Kinney D-17 VACANT D-18 VACANT Bobby Joe Pace - Helena Chemical Co. Rep. D-20 John Endicott D-21 Dr. G. L. Eilrich with exhibits D-22 F. 0. Hicks D-23 Larry Silverstein D-24 Dr. Karl Krumel D-25 VACANT D-26 Leon Humphrey Statement Witness) D-27 Willis Walker.Statment Witness) D-28 VACANT D-29 Suzanne George Moletz Statement Witness) D-30 Bob Num Statement Witness) EXPERTS E-l Samuel Epstein, M.D. Daniel Teitelbaum, M.D., P.C. E-2 (A) Time Diaries (B) Agent Orange Package from Dr. T. Lennart Hardell, M.D. 123 mtubamxfmimtum II I I I II IJPJH Uthtd h)h'0 E-16 E-17 E-18 E-19 E-20 E-21 E-22 E-23 E-24 E-25 E-26 Deposition of Dr. Hardell Moyer v. Dow Deposition of Dr. Hardell in HERR v. CAROLINA LOG BUILDINGS. INC. of 5/7 a 8/90 Exhibits to Hardell's depo. of. 5/7 8/90 Deposition exhibits of Dr. Hardell in PERKINS v. NORTHEASTERN LOG INC. Dr. Richard Clapp Possible Additional Experts Dr. Michael Ellenbecker Larry A. Platt, Bernard F. Pettingill, Julian Coggin, M.D. Linda Jennings William C. Hinds, Prof. Environmental Health Sciences David L. Eaton (includes depos from other cases) (exHibits to Eaton depo in 3rd cabinet by RFB) Dr.*A1an Smith Herbert Nigg, Kenny S. Crump Annette M. Shipp Carl 0. Schulz (with publications from V. A.) Leonard Chiazze, Jr. Trial Consultants, Inc. (TCI) Dr. V. K. Rowe (includes depos from other cases) Susan M. Daum, M. D. (Environmental Occupational Medicine) - William 0. Russell, M. D. Ellen Silbergeld, Jay Burke Pro?Forma Subpoena Duces Tecum for Expert Witnesses John Doull, FINANCIAL INFORMATION 3; CLIENT ooqmo'lwaI?I Income Tax Returns Medical Expenses Structured Settlement Proposals Pre-Bill Settlement documents re: Atochem Asgrow Settlement documents re: Woodbury Settlement documents re: Chevron Settlement documents re: Pennwalt Asgrow BACKGROUND FROM CLIENT (see for Employment Records) Client Authorization Forms Histories Compiled by Robert Moyer Birth and Marriage Certificates Grandparent?s Death Certificates Miscellaneous from Client 217? G-7 G-8 G-9 G-ll Power(s) of Attorney Last Will Testament Estate of Robert William Moyer, II Death Certificate of Robert Moyer Kim Moyer, (letters from client, etc.) Medical Bills and Insurance information from Kim Moyer (11/11/93) RECORDS m:n::m:F::mznar' H-ll H-12 H-13 H-14 H-15 H-16 H-17 H-18 H-19 H-ZO H-21 H-22 H-24 H-26 H-27 H-28 H-29 H-30 Richard R. Andrews, D.D.S. Walter Cerrato, M.D. Florida Technological University Health Service Geisinger Medical Center James C. Giebink, M.D. Kenneth s. Graff, M.D. Jess Parish Memorial Hospital Frederick Kadushin, Richard M. Levine, M.D. Medical Toxicology Partnership Jose Ortiz, M.D. John G. Penn, M.D. Larry A. Platt, Radiation Therapy Centers of Brevard, Inc. Radiation Therapy Centers of Brevard, Inc. Dr. Rojas/Dr. Ortez Shands Hospital James N. Spivey, M.D. D.S. Springfield, M.D. Ben Storey, M.D. Fred H. Widerman, D.D.S. M.D. Anderson Hospital Stephen Mamus, M.D. Sunshine Physical Therapy of Brevard, Inc. (Shirley Bratton, P.T.) Craig-P. Jones Orlando Regional Medical Center Triangle Laboratories Aetna Life Insurance - Aetna/Prudential Med. Visting Nurse Association Client's Medical Files INVESTIGATION I wNI?l Investigation Investigation by Vincent Ins. Adj. Skinner Investigation JURY INSTRUCTIONS J?l Proposed Jury Instructions 4 Payments EMPLOYMENT RECORDS K-l K-Z K-3 K-4 FPL records of Robert Moyer Orange County records of Robert Moyer Orange County records of Kenneth Swanson Orange County records of Dana Kinney ARTICLES L-l n-z L-4 L-5 L-7 L-9 L-12 L-13 L~l4 L-15 L-16 L-17 L-18 L-19 L-20 L-21 L-22 L-23 Causation Prejudgment Interest Dow - Protective Orders Motion to Dismiss and Motion to Transfer Miscellaneous Workaroduct Info re Publications Etc re Toxic Tort/Prod Liab Litig Articles re Defense of Toxic Tort/Prod Liab Litig Memos of Law for 8/31/89 Hearing Articles re Toxic Tort/Prod Liab Litig AFTL "Secrets of the Tort Masters" Health Effects Assoc. w/Exposure to Herbicides (Ag. Org. Sci. Task Force Review of Sci. Literature) 4/90 Articles re 2-4D from Law Firm that had Case Product Liability Statute of Repose Product Liability Statute of Limitations Relation Back Doctrine, Adding a new party to an existing CIA Toxic Tort - Tactics Articles on Real Limits of Expert Testimony Punitive Damage General Summary Judgmt. Rules and Cases Federal Preemption Cases (FIFRA) Cited by 3d DCA FIFRA Fed. Cases No Preemption Found Failure to Warn Issue Old Cases L-23a Failure to Warn Current Cases L- 24 L-25 L-26 L-27 L-28 L-29 L-30 L-3l L-32 L-33 Notebook 1 - Motions in Response to Plfs' 4th Amd. Complaint Notebook 2 - FIFRA Related Federal Statutes United States Environmental Protection Agency Motions for Recusal Statute of Repose Survival Tactics Cippolone Liggett GrounJ Inc., 60 U.S.L.W. 4703, 06/24/92 Sixth Amended Complaint Fed. Presumption/Failure to Warn Outdated Research 21(4) FIFRA Preemption Recent Cases L-35 Production of Documents (Young v. Santos), etc. L-36 FIFRA AS AMENDED L-37 Admissible Scientific Evidence L-38 "Claim It Yourself" Michele Saadi (book in library) L-39 Papas v. Uniohn Co. Amended Statement of Claim (Fraud) filed in Canada L-41 Junk Science Argument RESEARCH ARTICLES (see for articles rec'd from and/or written by Experts) M-l General Information oanancer "Perspectives on the Safety of by CAST M-3 TV Transcripts Newspaper articles re chemicals and cancer Databases re chemical research M-6 Information obtained from databases Research on epithelioid sarcoma Herbicides their link to cancer; Soft Tissue Sarcoma Herbicides their link to cancer; 2-4D Herbicides their link to cancer; Agent Orange M?ll Herbicides their link to cancer; misc. chemicals M?lz Herbicides their chemical components M-l3 EPA studies on chemicals (misc. articles): A. Chapter 1 -Disposition Pharmacokinetics B. Chapter 2 - Mechanisms of Toxic Actions (same as A.) C. Chapter 3 - Acute, Subchronic Chronic Toxicity (same as A.) D. Chapter 4 - Immunotoxic Effects (same as A.) E. Chapter 5 - Reproductive Developmental Toxicity (same as A.) F. Chapter 6 - Carcinogenicity of TCDD in Animals (same as A.) G. Chapter 7 - Epidemiology/Human Data (same as A.) H. Chapter 8 - Dose-Response Relationships (same as A.) I. Estimating Exposure to Dioxin-Like Compounds J. Scientific Reassessment of Dioxin M-14 Guide for Registration of Pesticides containing Bendiocarb (pub. by EPA) M-15 Transcript/Hearings on Effects of on Man Environment M-16 Book/Soft Tissue Sarcomas in Adults Children 237 M-17 M-18 M-19 M-20 M-21 1M-22 m?23 m-24 M-25 M-26 M-27 M-28 M-30 M-3l M-32 M-33 M-34 M-35 M-36 M-37 M-38 M-39 M-4O M-42 M-43 M-44 M-45 M-46 M-47 Book/Procedures to Estimate Risks from Exposure to .Mixtures of Dibenzo-p-dioxins Dibenzofurans Book/Weed Science Principles Practices Book/Getting Well Again Executive Summary re Chemical Sensitivity (Rpt. comm. by New Jersey Dept. of Hlth.) Locations of Major Producers of Chlorophenols and Their Derivatives Pesticide Exposure and the Role of the Physician Diquat Research Non?Hodgkin? and Exposure to Phenoxyherbicides, Chlorophenols, Fencing Work, and Meat Works Employment: a Case-Control Study A Case Control Study of Non-Hodgkin? and the Herbicide 2, 4-Dichlorophenoxyacetic Acid (2, 4- D) in Eastern Nebraska (Zahm) A Case Control Study of Soft?Tissue Sarcoma A Case?Referent Study of Soft- -Tissue Sarcoma and Hodgkin's Disease Odor vs. Exposure: Does Smell Indicate Harm? Endothal Articles NIOSH Current Intelligence Bulletin 40 (2,3,7,8 - Tetrachlorodibenzo-p - dioxin (TCDD, "dioxin") Chemical Research (L 4, 5? (Cancer Mortality Among Workers in Chemical Plant Contaminated with Dioxin) Cancer Mortality in Workers Exposed to 2,3,7,8- Tetrachlorodibenzo-p-dioxin NIOSH Publications Catalog Pesticide Exposure Article listing furnished by Edward N. Willey, M. D. Toxic Peripheral Neuropathy Article listing furnished by Edward N. Willey, M. D. Dioxin articles Use of Hair Coloring Products the Risk of Multiple Myeloma 8: Chronic Leukemia. American Journal of Public Health, Shelia Hoar Zahm, American Journal of Public Health July 1992 (Public Health Policy; Environment/Occupational Health) "Risks to Human Health Associated with Exposure to Pesticides at the Time of Application the Role of the Courts", Brett Potter. Toxicology - General Environmental Illness Environmental Chemical Overexposure Occupation-Induced Posttraumatic Stress Disorders Agent Orange - Review of Scientific Literature Cancer Mortality':h1 Workers Exposed ix: Chlorophenoxy Herbicides and Chlorophenois Book/Of Acceptable Risk, William W. Lowrance Ground Applications of Forestry Herbicides, USDA Forest Service 1% M-49 Defendant's Analysis of Chemicals Used in 1976 1977 (exhibits to Eaton's depo) M-50 Lies Contempt: Dioxin Agent Orange by Liane Clorfene Casten (from Zumwalt) unpublished unfinished book M-51 Cancer Mortality Study (01/91) Fingerhut M-52 Herbicides and Cancer (Morrison, Wilkins, Semenciw, Mao Wigle; Journal of the National Cancer Institute - (This is a key article). 2M-53 Report to the Secretary of the Dept. of Veterans Affairs on the Assoc. Between.Adverse Health Effects and Exposure i to Agent Orange, by Special Asst. Admiral E. R. Zumwalt, Jr., 05/05/90 Veterans Agent Orange - Health Effects of Herbicides Used in Vietnam by Institute of Medicine 1993 EPA - Prog. tc Reassess Pesticide Risks Disease Diagram M-57 General Risk Assessment M-58 Pesticides - General ATTORNEYS NOTES AND DRAFTS N?l Attorneys Notes and Drafts N-2 Draft of from Woodbury (6/12/89) N-3 Rough Drafts of Answers to te OTHER CASES (ENTIRE SECTION IN 3RD CABINET BY RFB) Greenhill v. Dow A Greenhill?s RTP to Dow Dow's Interrogatories Transcripts Davis v. Dow Shoecraft v. Dow, Case No. CIV 74-662-PHX CAM Agent Orange MDL 381 (Docket Sheets) Agent Orange - Product Liability litigation IL S. District Court Eastern District of New York U1htkoH+4F4H Edward A. Metcalf Depo (from SODA) N. Dr. Van Murray Sim Depo 0. Dr. Robert A. Darrow Depo P. Frank J. Vocci Depo Q. Benjamin Harris Depo R. Plaintiff?s Pre-Trial Order with attachments S. Diamond Shamrock's Log of Documents Identified ix: Response to Plaintiff's Interr to Def. (First Wave) Exhibit Canadian Litigation Against Dow (Documents RDS obtained from Jerry White during visit in 10/92) AGNEW DOW. ET AL.. (Canadian Litigation rec?d from SODA) VERTAC (from SODA) Arkansas (from SODA) PHOTOGRAPHS, VIDEOS AND SLIDES P-l3 P-l4 Photographs Practice Depo of Robert Moyer Day in the Life Film of RObert Moyer Video Deposition of Robert Moyer (Volumes 1, 2 3) (9/6&7/90) (COPY) Photographs from Orange County M.D. Anderson Slides Video Statement of Robert Moyer (7/91) Pre?Amputation Photos of Robert Moyer Interview with Kim Moyer Day in the Life File of Robert Moyer (12/02/91) Bobby Danny Video Settlement Documentary (03/92) Day in the Life of Robert Moyer (04/92) Settlement Documentary (brochure)- Updated (05/06/92) DISCOVERY PRODUCED BY US I from Helena (5/16/89) from Helena (5/16/90) from Woodbury (6/4/89) from Asgrow (6/28/89) from Dow (7/24/89) from Asgrow (10/3/89) N/Compliance (4/2/90) (AETNA RECORDS) ReSp/Order Compelling Photos (4/17/90) from Dow (1/5/90) N/ComplianCe (12/17/90) (Drs. Thompson, Jones, Freed, Mamus and Cerrato) Ans/Dow Interrogs (2/18/93) RECORDS PRODUCED BY DEFENDANTS (also by Orange County and other sources) R-l Orange County - Bid Sheets Correspondence (obtained by client) (139 ?sci?! 6rd 8 R-4 33-5 3-7 R-8 R-9 Orange County - Original Response to Subpoena D.T. (the important records consists of several folders not individually indexed) Charts re: Chemicals Purchased by Orange County in 1976 1977 Orange County - Contracts for Purchase of Chemicals (1984 - 1988) Orange County - Records on Herbicides used after 1977 Orange County - Documents produced for Asgrow Dow - Krumel Arnold Report (not obtained from Dow?) Ken Swanson?s Journal (copy original in Dow's Response to our Requests (7/18/91) Orange County - Water Quality Records (BY 0 1 aamtnaamtn?amtnuamcn I 5-13 8'14 8-15 8-16 3-17 5-18 TRAN I I II mmuh-UNH 00 Company) Arjay Inc. Applied Biochemists, Inc. Asgrow Chevron Ciba?Geigy Citco Dow Helena Monsanto Pennwalt Rhodia Southern Mill Creek Products, Inc. Thompson Hayward Transvaal 3M Corp. Other Companies Diamond Shamrock Chemical Company SCRIPTS Transcript of Hearing (8/31/89) Transcript of Hearing (12/4/90) Transcript of Hearing (4/2/91) Transcript of Hearing (4/24/91) Transcript of Hearing (01/09/92) Transcript of Hearing (09/25/92) Re: Pl. M/Sub. Party M/File 6th Amended Complaint Transcript of Hearing (10/02/92) Re: Dow?s Motion to Appoint Commissioners Our Motion to Quash (Teitelbaum) Transcript of Hearing (11/23/92) Teitelbaum Production Transcript of Hearing (01/05/93) Our M/Modify Teitelbaum 23f T-10 Transcript of Hearing (01/26/93) Dow/s M/Strike Paragraphs of 6th Amended Complaint Transcript of Hearing (03/01/93) Dow? 5 Motion to Strike Expert Witness; Pltf. Motion to Modify Court?s Prior Ruling; Pltf. Motion for Rehearing DOCUMENTS RECEIVED FROM JOHN BETTS U-1 Davis v. Dow Exhibits 1- 277 IR Attachment to Memo of 11/13/91 - Exhibit List of Documents Attachment to Memo of 11/13/91 - Supplemental List of- of Legal Documents Legal Documents, Exhibits #1 - XVI Exhibits #1 - 25 on Dow? 5 Publications and Hype on Herbicides Supplemental List of Exhibits on Dow? 5 Publications and Hype on Herbicides Keister v. Dow Exhibits #1 - 49 Memo of 11/28/91 on Review of Documents Attachment to Memo of 11/28/91 U-3 Newman v. Exhibits #1 - 20 Memorandum of 11/29/91 Attachment to Memo of 11/29/91 U-4 Memo of 11/30/List of Documents from Memo of 11/30/91 with exhibits #1 - 10 The Dow Story - Don Whitehead Memo re: Canada Trip from John Betts with documents EXHIBITS - GOLD FOLDERS Asgrow?s (4/30/90) Asgrow?s (4/30/90) Asgrow?s to All (4/30/90) Monsanto?s (5/4/90) Monsanto?s to All (5/4/90) Monsanto?s (5/4/90) Helena?s (5/11/90) Helena?s (5/11/90) Helena?s to All (5/11/90) Woodbury's to All (5/15/90) Woodbury?s (5/15/90) Woodbury?s Ans to INT (5/23/90) -11? 23%- .9 X-14 t) .1, 0h X-15 X-16 X-17 X-18 X-l9 Ex- -20 X-21 X-22 X-23 X-24 X-25 X-26 X-27 X-28 X-29 X-30 X-31 X-32 X-33 X-34 X-35 X-36 X-37 X-38 X-39 X-4O X-41 X-42 X-43 Dow?s (5/29/90) Dow?s (5/29/90) Dow?s to All (5/29/90) Chevron?s (6/1/90) Chevron? to All (6/1/90) Occidental?s to All (8/3/90) Occidental?s Ans to Set of Ints from (8/3/90) w/Supp Filing of Resp to Ints (8/14/90) (signature page) Video Depo of Robert Moyer (Original Tapes - Volumes 1, 2 3 9/6&7/90) Video Depo of Robert Moyer (Original Transcript 9/6&7/90) MOnsanto? Resp/Pl. 2nd RTP (04/09/91) Video Deposition of Robert Moyer (7/31/91) (Original) Plaintiff?s Ans. to 2nd Set of Rogs from Occidential (01/09/92) Plaintiff's Ans. to 3rd Set of Rogs from Dow (01/09/92) Dow? 5 Response to RTP from Plaintiffs (02/05/92) Plaintiff?s Ans. to 2nd Set of Rogs from Dow (01/03/92) Bobby Joe Pace - Helena Chem. Co. Rep. Deposition Dow' Resp. to P1. Expert Rogs (05/21/92) Voir Dire Deposition of Herbert Nigg, Depo of Verald Keith Rowe Allan Smith's Depo Dow's Expert Rogs to Plaintiff (02/18/93) 'Dow?s Response Objections to Plaintiff?s Supplemental Interrogatories (12/18/92) Dow?s Response to Plaintiff?s Request to Produce (12/18/92) Occidential's Interrogatories to Plaintiff (01/18/93) Helen Answers to Pltf. Interrogs (4/24/91) Closing Argument Kenny S. Crump original depo with exhibits Carl 0. Schulz, Ph. original depo (03/05/93) with exhibits David Lee Eaton original depo (12/15/92) exhibits in 3rd cabinet by RFB Helena' Ans to Expert Interrogatories (03/31/93) _12_ g2j53 MISCELLANEOUS Noamti?thcaN u:m~qoxu:pcunap Z-l3 Z-14 Z-15 Z-16 2-17 2-18 Z-19 Z-ZO Z-21 Z-22 Z-23 Z-24 2-25 Z-26 I 27 Mediation File Demand Letter Gerson Smoger, Esquire Other Chemical Incidents in Area Defense Strategy Folder John A. Betts ATLA Exchange Advertisements "Defending Toxic Tort Litigation Tenth Annual Toxic Tort Seminar Court papers pending action Status of Discovery printout Freedom of Information Request Occidental Annual Report (1987) Original court papers from defendants. Newspaper article re sprays Dow Financial Statements Questions for Dow Experts Mock Jury Task Force Index Demo from Gallant SODA Canada Boehringer (from SODA) DCA - 5th District Anonymous Chemical Safety Survey Experts/witnesses used by Dow in other cases Map-Michigan Post-Trial Interviews (from California Plaintiffs? Steering Committee on Implants) Consent to Employ Appellate Counsel (Caruso, Burlington) Q34 JNITED STATES ?7 COURT EASTERN DISTRICT OF YORK In re PRODUCT LIABILITY LITIGATION 79-c?747 7943?2752 CVL80-2207 CV-80-2280 CV-80-2284 CNL8O-244O EXHIBITS Ronald D. Rossani CV-80-3256 CV481-1296 CVF81-2719 CV481-522 cv;81?2349. CVF81-2725 CV981-662 19100 Tysons Landing Court McLean, VA 22102 FILED UNDER SEA. cv?21-991 cv?81?2339 cv?ez-ozoa CV-82-77S CV-82-3619 cv-22?1142 cv?e3?13os cv?83?4024 cv?a3-403o cv>84~1222 cv?84?1880 MDL NO. as? FOR RECORD 9 [966 sr?FD -BS-C . SC-JECT: Phunu Call {rum Hr. Nayne LSAF Kviiy Field, Re Vi51c of Dow Personnel Texas Dnu l5 nnu.praposing new formulation: 2.1 lb acid uquivaien: bury! 2 450 2.1 lb acxd equxvalent bury! 1.0 lb acid pxcloram Saw recueSted approval. Vandervencer statud Lnat of formuiactons was Army Dav peepie plan to go to Richmond to sell thalr ncu 1v BSA. .l .: I. da- .rbll?g . t5:e? that Crops Divisxon has no mune 1' ?aui: izvid test :ne Answe: was null-I: . -. .ae Vanderventc: that new fo:=uiatzon ;as a. g: 'ouemgn: :ve: Tataan 101 but :ore acziye 1n: Had ass caui? - "c one zaEZon ta reduceujcg;s:ic cziatz and anuid De gossibie T'aa" 235 $5 pxclaram per gallon. This would be a such mare - erzuiazadn- I 'l I, I zit/? C. E. HIRARIK :095 Division 'D:31r;Duti3n: 31::513 Sciences Lab. C. Bartlet: 3 Zr. 3. H. Brown . a. Bunker _Jr. Darrow . H. Demarce - R. Erank at. K. Icish. P5300 Dr. C. Trucheluc Lt. Col. Cravell, ACSPOR u. Darrell, ACSFOR x: E. Hamory, AHC 3310? 50rd, 0233 - Lt. Crea, Egl?n AFB .. . 23cc I ECT. 51? on- Sue; Production of Herbicides James Coucll. 15 5C?tenber 1966 .U 1. Dr. .3: qutae and Dr. Dow Chemical Co_pan_y,_v131_tled Cropa Division on September 1906 to diacuas_?roposed n_eu formulation of Tordon. 2. Dou would like to offer as a replacementjor_9?ange. a mixture of herbicides, with the roilouing composition per gallon: 2.15 lb 5. e. butvl 2.6-3 a - ll . 0 t.15 19 t. e. outv. gsty??itlornm. . 1.:t10u Viscositv oil LA Oil 331501 - 1he aoove :ixture coulc ne mace by 3n: uranae. at. of. iscoctyl ester of piciora: an: . at. 0:1. 3. 3r. Hi?tsc cfiercc us 5539 33110: .s free for testing RVhlor Thoilnnd. Si we can not orcrate in these tho areas. he decline: :Lezr offer out Statec that ue would UL: inc: 1: :ney cOuic ntuct tooth in Hawaii. -c are presentlr assistin: tne: in..ocat:ng a suitaole test area :nrougt reorge iota. Cross SiVision Lonsuitan: inc reaices in naaoi.. L. 3.1:5e state: the: ocrwcen tne *rescr: en: June 292?: tnere n: a of 1.255.353 gal: of Granve;~42he nan - :recurcr-n: o? Grange a: tn: rate c: 428.336 polaxaontn c: a :Otl. of routnf? 3 2:11:33 3313. can not suzri? more than 3.2 gallone_of Cranrc. coeratiag at pea? caoncity an: diverting all of tne procuc: to the zilitarr. I the annual canmereial requirement to: act: in 13.5 zillion 1:5 the military requirement is 21.5 zillion lbs, or a total of lbs. however. tne tatal anticipated US annual countity of aCid in expecteo to be 15 million lbs. considereoly below tne military requirement. leaVing none for civilian use. The bou.?reeport plant will be producing 250.000 lblco. of Toroon etid. s. 6. Dow's current production of acid is 560,060 lb/mo. @533 C. E. HIHAR Chief. Crops Division I I u. Refract-s 1.115. Dr. brown Dr. Darrow Dr. Truchclut Office, ATTN: Hr. Irish . -.-- 7; . 222mm 7c: man - Utah. d'uH-U .. . . 7 Octobur 1356 SC Intel?=4: ion Provided by Hajot?jiiulahy 1. 1110 following inform-3:105 was provided by ?do: Aorospacc Fuels, San Antonio lit Hat-r101 Aral, Kali; Air Force Disc. Tana: 0347 October 1950. - 2. On or about 24 September three 'Dcm called on Col. Hagan, USAF. and offered him a new for ovaluszion 1n Viot Ham. Col. Hagan tun offen- stating that. 1: us: :24: Amy's: responsibility to evaluate and recomcnd herbicides for us: in Viezxcicpa, but. he called in three Amy officers to talk to the Dow One at the Arc-y officer: was ?410: Lord, th- mu a: - the o;hn: two we: no: known to H330: Hulcahy. 3. of?cers are reported to ban stated that: ?lm hm: - 25:: .ulatic: sounded good and they are rcpozted ta have accepted 1: {or Col. Vegan stated that if the Arm-7 ?nished. to do this he would Dy arranzing an air 11:: and 11: asked the I?m pcoplc {or - :ic: on the nuzbc: _of packages, that: weigh: and cube. 5. Etc-J provided: he 1nform:.on in I. lit': at and 23 Lents-.59: 199a - cl: .3: 1:0 ?233, "gar?: to nut to panama evaluation pron: ?17. C. 51229 than Dov has also been pr?ni'urm: Antonyms Full to 41: 2.1.3: :42: 22 drugs at the av farmlatzcn. I fag/um c. 3mm: 'Qahi. Craps 211:1an 2132;136:1011! - 7 . . 21-. Darts-J 7 10b; - 11.3.3 11:. 111351? 2??niuu tholv - - - I I II a Hat: .- VI a U) 3 WOOCI woos, a . ?2rP581151 Ia? H- o, 1963 ?xc?amara .I I A o- VI McNamara ylan -oout- 1?MIDLAND. NE T. - .5. I?r MICHIGAN H723 0 I9 In :1 ct if ?5'4 (1 5'3. 3. 3.). 5 at!? II H11 a riit?t; HitYl': (I flg_ nigh30.:r515on; 3.03;;13 [Ju -u x: :3 u] at, ?mLi' waJH .H rrw'u H'sw Pldu H- Fwd? ?uo -urdun-w wt! - (t a,kq?gw u-Qu: tint--: gird w: In '1 017 I 11---: ?-an? .bun. cv'q EJEBENCN quc .1 on .5 At?suusg ?1 s. BTU Auzdmog up :uznv Id. ?mzu pszzoog .a a c? DIEMOH ?aI auxq uuag uosn?aa EiuentAsuuag I:ra? 1-Ila ?In. I: II. I :Ir?n II I: IZII I:r-Iwo I- II II. II II- I IIUIMH IIInn-:5I ll Ium:Imou.m II1II1I-II) ?quII, II.IIII. II. I.) .II ItHIDIJII .II r117 IJUHlawn-13.":(OWN 04Iamn I?ll qul we? n. 3 :3 Kiwi IIUUN II. a InCJID llmumr ..- In H) h\ .H rl ("In an 1? .. .2101 3-: (11(lol- 0 (U0 ,lFHHOI 'if, I'll 01-0-0..- I. .I 0; um -l nun,? (H II Cl ,ol'vll1'14 .1 h] I: I I Fl?! H1mm mlwnounnm unu ?n Camrmm Em .M v1H1 1:1. I I II I1I I lnl-I-IuloI .II I. I I mann?ruenu nu HHN1 ?:0pmnn. 3 111111 11 111 11:11:Uu :11. Hun 1H. 1Hn?HUM IHM Lhrl??.II IIHII II I. II I, II lull I.Ilu I H. IL I.Iu\ru?unud no(?Inn-?U II. ?th . It. I?t? I .. tun ?mm ommu unawHHUUmw 21. 1Jnun nmumuanm nu? . 0n Duncan nmma run1 un?nvuon no vnnunuuw ..ounumm n.uur11u1n.L. 1 ..1nnw mo- mo: no 131--:uo 1mm ou::mm nnwn1 nv1d no 1U11. 11 on E1r~1ou uu111zu man ?can. rw1m Evan nu?uwuwm,nvru run LL nu cm ?1Hkun Muwwuum o1rnco mmnum1 o1ruur o1 nojoz 5.14 . . . z. 3:115 33:3 . acrIZJ adv-5L ud?C?H chum-1.8 till-.31 Egan. nu? ?a mi 3mm .5 mantra EE run Pan.- ..quuhnn d4 .3..- nu .?huukuhut ?Iguana. rumba. nun anudH?nd nu. ?wanna. om .. an .. KT: PHH ?dunk: numun. Fr; ndunuand 0511??. ??aunt 0H tangvuu. pun. dE ?bin? 51 Hun - ud?hhunnqnu nu Eu a. can. .. 3. TEL dun ?mania"? ?PgtJ?. Em 5m. HEM. Pam. Ga ?133an no? a ?gun. ?Hyunun 0H nun." (Bub. .. nun ?gun? an NHL ?ung. Adv ?an nIJgPum -11 Ea?n?qu?ugg?u? RE any-"454g nun 03.3. 55 JEFF a nag nag 9?3..qu n" ?ruJu nunuwnn Lana ERA uh unnumhbnu Hum $3.51.?an uPnuEn 1.53?. nu. Ir.? nou?lund ?nd nu 3km. unudhu. In." ?#3an 1.9133. nun _.nudnuxlwm onupndn. and. Fan-Hun a aura numb?. ?aw nduulwna. Hun nun .un ?was.? Maugham. .3. 1.03..er ?gnu-nun.? nun?nun ?L??no nun d4 an. on (UHF. ?3 Fauna nu. .unduouan. ?ung 9.4 ul ?Shawna. and?: uh ?uh an out." manor-u 31E sauna-1M a P5. a? uth and and wanna w: 9+ "Evan! udumlnu and ?cargo. "?auntgida on ?Us 31.0.4 an nv?. F154 .51.th madame? can? and. and vs wanna! Ldugnn 00.1 nun tdn?nu?um. onuunnu. ?a ?Anti aha "Ha?urn" uuhn nu nag a. ?drug? ?u sugar unan- nu pun. wad-Pr. mug uh nun-Pun an; 9% kn.? En PM andnanuLLnn ?nun . ?an. an? ?and": on? 9.: End an .90 mega and. CL 353.13an Edmund? ?on Nunany unmnu nun ud?uPrnu 2n owhnuj 9.033.; ?Manna ?13nd Suntan no can 09333.. nun. n? ?Tana? Ankh.? ?snag nag? ?0 mg nun nun mh?du d4 xoauulluun? 5g nu? 33?..?an Edam. Pan 3 ?can. .11.. .. PP. an Mancunian? Cal Hug ?aw quantum Evan nuan??u Em 10 nun nun n31. Hun. aha 0533900 3. Ha Iguana. . a! ?Uh-Igno- It'd- {?pq?N I gigW'n?m I - lul- . I smarts-5} - (tum. 1' sis. f. -?Lr .-.-. . .. :Jen-0~1141"?? 3 I l' I (?31.33 [in 4i:- '9 - . . ?3 ?:51 run ?r'o 3. a-J 4. Ill. ii" . .. If? .3. ~332[93-433 .9 3" ..- . .-. . 1:1}3 ft" A: 57' 11? 15; 3.3a?: -119iv-ss-s-s-r-?s . grew-L. cricTsi'oUri-23??: . ?it saws. ?nsg-?i?v-psm Jim--. Essa-.15; n. a un.? 33s.: . Mfa?r? a 1 ;h ingpulnts - :ns- 3, . .- "r l?SEat?Si'?sm P3 f?a C'al'i', Cor?ps'f??ii3:353 +4 as 0. $3th .5 If'i' y? IQ) ?uff-hia?gbl . . ,?'11 Av '4 Q5 25:15.1' r. m?J .51 $35.15" -. . i -. 1' Tan. .. - 353.12 2-23. 111s- - . . ?2 aunt-354,21 C.) ARCH. It" - it?. ~31: ?l?i-?Ffr' 31'- s? 'al 1?22] 7- -. . .25. - at? 3. Frat} . . . . [Niki-5E?. . .. . 1'4. J. . If . huihu- - . - - 9- Mfrs-?3; - ss i saws-star}: "in I .- ff. 5 I If i 2255555555 535555553553 5.535" 2* 2'2 ?2222:2242: 122- 22 2 -- :22. 22-2 I . 'Ir' .1 2 ..1- I 23 .2 2 7. 11?3"" -: ?2591'1'nuhh?: 3* Fun!- 222" 212225-222: mu '2 I magnum? $222,224.52. ?3 ?25' 5M: .5 2.: ?33 ?5 551555551": 532?? L. Ea?f? 32322212212225 332 35:59:22,515? r'k? \v 55;; ?m5? :535'355. 51:; wit? n'iw?u'vr -. - LIIFII .2 a. .. hlql?' I I ?nt it v.11hih' u. . It"? t1f?i?tr 14"? Err! (Inif??. is L513: . v.Jags .15.22 .2: 52:212-52- 5?5 3 222? .2. 2 ~22. %%I?m5w . 2 - I ?4 [?3ng 31%: 1" 53jun-.U Fargqh?gf1:5" '1 I i: . 541?: {\icf P3 7 3. . . . ?52354.02?: 1.3.1 {?5162 r: 555 3 '33" 5'55" :1 3? 0'22?? 5?35?: 55575255552? '5 3?5 r55 22"? 4? 2., - 22-22% . 43.2.2 gt? 5? 2'35 I 5555?? 5 5.534575 5353+ 51:41:42 .- 89-2-1373.er I I 5 ill I ?353133?5'5" \i?Tf. 153-9 2- Fur. . {5 5H: 56? 2'12' $2518 I ??52 5538? 523825353 29.2222222723 gap-:2: 2222232252222 22.2220 22:3722-2222235. . 'r I n: - "fimr 2 I: .I I1 I I ?lth." - in?; in: . Im.m2-'lai~o HEILIIHI -.- I3 '5 Q?lt J) -cf'56. I I 5 '1 l. 5515? CW '55 ?fty.? 275-712.: . 5 ?2?2 3! ?5 53?. I 2 3' 5' I 55565?? 531'. 3' ?"355?5?5?4 ?15:35:: ??22913: 2:22-12 12:222.: 2 mam-'2: i ?Im' 5 .. 75?5'5552'522 2.2225222" 5'5? 2? mhmw- .. 22:: 2 2, 2: 2::222 2.. I I 5 3" In? IEI17:; 1- if" 3-2 2 33220:,- - . .353 0.53573 2 1 - I. -, (fag-'4. .- 5 F: .0 i .1133If.) . 05% Iii" .1 .3 min?. '3 55g?5?f I [3:33:15222'5 27231.? 5.8252223,16 :6 'ri. #332th 5 I ?In: ~12. 9,223.22: Ci": I . .- 32~22. 2322222: 5?5 "5 I 5?5" '5 5 x-ng (131." it"? ?5 2:22: an. 2021-4-45 22-1. v; ,uPiaf. \lno?u .- 2 1? '22; a II ?3 I 50? -?llm - [If . A I . 1?7115555")- 302-. 01 om U221: .?vai .4: 'o'm 5 50'5?" "a 3? 3I '11 :11? ?11 :21 ?1'22 . :u3053101 '32 1 v'l 3 5'12: ?v 2: 325221222222 2'22" :22: 222222-223 ~22? 22.22.225055555135255": 3? 2. 2 LI 31313.55?25.9555. I "3-25" 2121:1422?: Jar. Ida-?4 .. at;- 8 "yr. 2.1 I 1555f 4-{392122 2, 7: 2. '1 5 322" Iml 3.35 gaa??m :5 1-. 2,4,5. jugslat-?if3.3233? migmjd- Mg (9 3321.121 1111 .a'JEVL?wjpi? "?757. 51-51? "14:537-1- An? 0 . ?shag r; amaiffg 2115155 ?3*?qu ii: if": ?55??rhti27'1?: 0' :1 I I 92' #51555? 5555 0250-1515! 4:225: 22222-23 5:02:35? ?5222:5252: 23221." 2.25.23: . a-d? :Ijgt sat-z, EI- I 1-. . I 0:30Enskn I If?? .. 'ihla'kglj" 11b15lb. -4. 411.115.? 1' in. 7-2-NW) .45? .Un i?dh Ur. 21.n- . as; .4 ".19 . I. l, 2?22? .12: 4 H. 5392' 35:34 -. 22. @2253, :54" v.m?m Hut 3 I: m" 5,137 l" (Eng; :rx?l'l 'Et I?ll a 1 -. - ?vrl 5251,81 '5 ?$995015? 4 {121 ?5254 '5 Arm.? 7" 312:5?? .I- . 9:75:17 52"? 552:" '2 21:2 2 2222.22 2 . 2:22 . 222.. 2 I . . 38963;? 5:3 tit?" "??L?E'Ll?lv'i .1 3,455?, :45? i?hiiJL-Ht' .7. "h??lhz?t m?d?uls? [Ll It?" "?ll-F U1 . 219333:?: tn . . . 2. .23. "Ina"; . I 6 - .0 {$554.52[?11 0 '1 33" L0 23:95411.if.loI.uI I. I .-.. I'll . E-t-I'"$13339": - . ?4?5 . . @923 Secondly, we need materials that will act rapidly. As General Deluge: . stated, it 'is premature a: this time to say that these caterials should act within an hour or a day or none other finite unit o? time but we certainly' vent tha to act as'rapidly es possible. I know that this factor vill he discussed in more detail later. land I will any on more about it at this time. :1 It goes without saying that the eaterials cant be applicable by ground and air spray) that thev crust oe Tojistically feasible aocT the: tnev trust oe nontoxic to humans and livestock in the area affected. Hot only should these materials he tetra-tic, but it seem to me that it is important that they not have any-cosmetic effect. for ezareale, a esterial had a marked rad fluorescence and a timber of- people were obviously stained by the material, then at: teary night deriVe considerable propaganda value from this he: even - though the individuals were not in any v'sy injured by the mterial. Jr: a very real seneeJ thigro-zrae in defoliation is a little bit uni?ue with respect to the usual niliun-induattial collaboration. Ordinarily, in military 9e have a oilitezj concejt that leads to the statement of: 7 military reguireneng, technice characteristicagperfmanee soecifica tions, and other strictly delizited aspects. in this program we do not have rigidly pacified characteris tics . have stated same of the bro-ad requiresents ?fev veers but at the met 'He simply solicitTthe assistance of in Eat a success?fill aefol?tin; tacit-sf should have, out within this general tremors we vill aod?use eaterials that'vill the: we will come _z.1th core definite a cifiea i findij materials canTe used successfullv Within the reaao-Mhlv broad and general guidelines. that General Deli-core has stated and the: have re- _peated. - -- . . . .1: has been both a pleasure and a brivilege' to speak to you gent1e=en this morning. I know that I speak for all of us who have responsibility in this program when I say that we are most gratified at the very wonderful response industry has shown and we are confident that your interest end your capability will lead to success in this prograe. lea . . a a .I?when . a I 5' I "Juli-"l J..- - Na 195; ?3.52 mm m: swans?auhti .31EST 33131131132 3 v, x. *0 mm - 26? Mildly: - ?tn. g'fygigzii?j', - 8 . (?ft ?he m1: ImL'Imdon 2,1! and has rm Ghana-v6 53:; to 1:23.196: an 1:317:13 for 2.3.7.6 .- am: :31 hold to diam: tr: dioxin addition to .pgaL'Im um. I: decide-d to lit :1 . grep-u: . :11 of warm: to: the dioxin Ln Dow production of mm. 2:53:91? ?n madam 1.6 mm helm. . - - - amt? if; 11: 2:117:11 for tho 2.3.1.8 61m 13m:- sill be an - ?aids; amt: m: car shim Emu-tad . tori. 5. 3mm betas-u the uni: cur LI minced. Obtaining 7.41:: .5 i i and a: tit: anus?31.: will by the mmumtw a: . Wt. pawn-calLam 33:71- qua-t) of Marion M10 7111 - v.1 mto?moparta. ran-1cm run. b. m: up Enron! 0111 for are 61am mmu. tart - .1 t=n I111 ho 8m to 1:317 ?umtam. Pm than will be realm. . - spot ml- be 01th:? that not dried said, m, 11: night be admablo to 31mm? than 5min Mum - tannin. Dry and no: nus-s animus ?u darn not cram-am run than and when this com 1: I111 be main!) th- at am. 1:29 cat-.110 or we: an: #111 be submitted to the 11!: mm 1: 33,5? ?111 ha crud 1n the 111- amulatin: cm. The 011m 533:; 1:31:91: um than: be sent tn the gunman? 111nm: abort. .1 cm or 0111: am anal 1: am he nut to annual, 55:; aunt-stain . - . '2Lyhu?'i'mn .. _?u?au . . . . . 1.1. 213"?? 1- Twig-{213; 2: - . 1921332223911;- '44 m-l-l?m? I: E-?ifugf?g; {"9533 331177: Vii-i . 1.1-1: 1&1 -, . .-.-- - t. chi-1691? 53.9111. WM (?g-Lg 12?" a u- I - . mom .smxacr IO NM4CTIOH m; m. ML 4-4-73. AGM 9 g??hli?g? . . .9 .0 PI. 'I'qrf: :n-O . -..I .--.Zr.? -.. HHL alt-J . . 6' 1371.5 {Pg-v.53..t'Tl?u-W 3-m-?lhjW..soulo . 't31: ?73" x? '1 0 ?Wm, LICKDad! '3 g" a; . 3-5; 33 3?3: ?49ng a. was 5% gag . a ?pun 1.3 '53? ?5 ?3r" . 33 3 - . 55:3 "a 35 E5. 3 5% ?:sang, 0.255on." on g. a - mun-u Inn Inunuu?l ?l-I I u-u .- . 4mm U05 00223924 macaw?.33?. I.O.Lrln. tiara)! umq. :bmnan . QCQ EUEQ I .Ur 20. me ??ll I WW mm. . lug rImI HI. IHUnmounHaIHInIuIn hard mm .. I92090NH PI anJnL HM Io dam amnmw?hn H03 0% u~d.ml dmIIun rhounnIumII Ion Im. man I .H?m IIHHU omu um nmu mnI Imu mu uIm 05m Maul wotmu OIL Dunn on ?mu MomuHIIm mu onnuu?? anumanu m. Hum M.M.H.mInmuHanHoHnnuwmuu Ink IIMU Hm mmumeImn MHUU \h DJIL In nwwonuMnHUI 9 Ir; IOII quII In I m. mmumnw . .qumuH qununnHumIHUIuImunHII. mm om: onwm on omrmvum mmdmum mwhu meUnnmm Hunzm I mmuuwmm ow onunmhuhumI MUM ow. nnHu bun mInuwu um nmUnpmn an no unmdmun NIH meJ nonnmnu Jn unbmw ?nun. Imhwu h?uuw.u. now inmu nHmmu mp? mnIHUUqu tun? Howunzmn nu nuunIuWOII 2mm?. Unmanmm IJ I mm no UumamnI mNIu nun" nu. onuINWImImm mIduIUqu FIQUV ?nimlm~ WHO. I k. PUUNINI: EHHUIHHNUN any pm?umuwwu Ian Ju HnnI. Honuuwuhnu nummx. nmwuhouunw. OI mnnudwpmu Adv mmunInmI no HCHH numb. onmImmnona ?zwu HmmUGUmm . . Mow mNUHwnnu I down. ow mnnudmwmun. a gaunuhuu on. wmnInu. anhumon man nn?um3%. 0d mnnuqmlmII. . . . -Amv m. u. Upo?h?moa pun nonvmuw. OI mn.r.:wlm3uI MO 0 83mm . . . m1 Wn?m 00.x 93.0.38 4.0 noun 03m? :52: 033mm: 309:: Emc.__Q I . MCIJN mm. mem I. I 20?. 20 um? . II Huumnn 0H HummI Inu HOH .ZFJF Em HhmanHmIn an wmumNHnI. HHva 3 nay. GOHNHU OIU.. 0. omHI IanU U.. udmmH d?nHums H5 IU .tHnU m?nvI MHW nmunH.ICmm mmwommudhm . . . . . . NW. udI voHnu n?Hn?omoHu.?I m0\m0 Hmm?~ muuiH?wdeI?mn?qH AHHOH m. . . any. ODHIIJ vaNmud UH mmeo on m0\mu .Hmm? .n?HIInuoHu. E. HbudH?Hmun Nun - nun . a mNu..NHanmm:.. .uNnHu OHH anHoH?. I "Mm AI HHOU 7n Io . IILPILHPJ. IAOV. .2 moHranu. .UHmmOHdm Ho OI monHII. rI?Ho? um Hu.oNn- HHan OI nNanI .. . uImW . nouanHnHu ?Dam: ImHUNHmhuum MNmonI a . Mao . . . INN Ian HNnmuIum mnNu d?unHm .. m?nh Hmmdo?mm 0H NI mom oI Hm anH.N H.o 0% wrNquIn .3 H00 0H m.m.4.an? Iann . .2. MNW HMNHUH mmnanU m.mu?umI PHI :0 NH. ddHannH Ho HHwa. Mow. UHchm ?0 av . . a Hucmnn Hbdo mam nnHIiNnomHNH. I I nu m. mHoomn?ImHu 0H Nun mUNwm HOH 05m uncH. ?Um uOchIon Ha omnnI ncum Nan .WN. .thMJ H0. 0 on dam Hung Ho?Hua?Hom donnHm. anUmH WHHN BHucnmu. 1.0.1 any anIm Nb IaHu u.mH. QHN: Nu on "Um Ill. n?HnHomou Nu UomuHUHm Hana nEOIo?bnm donn HmHim HEN NNO I..U I. .Hp?ommiub. . . nmv.>nn mm HHSOH r. OOPMOU do . mHnUmOn Nun Hm pd?dmm nzonm PROVomunuuw?mm no?. . .. 0 .m m. a?mx O. In. On "Um .Hmwmu. mm. Hm Ooumvuwm HIIOO dumb. Zonm. doHch. . . . WWHIJNOOMWIO do PJI..OOM Pu- . .. .Jmkm ru 2H3. no m. 0m doHOUm Oonmu ucmu. 1. 3 . Hun" .IIPI mownnIInu Imu mu.?O mnu._m van. . .OM. T: BLOOM u. .0 HIOIOHI.IOI mun meunumm 0.. m. 3.9m 931.5 . m?ozu m. ?nhunm?mb. . GWHnuHmanuHanamnImI .rwuunu OI Hum mm". OH. . uh ..HHI . . .U nmum mum? 0.. ?Wm . . . RNOHNOIMIQHOHHII. "Um Hum nu. Hum Ow?nnhunmummz .OHWINsUs?Ism ?mrl Wnra OI UPIWIJIIO hnnuumnu.IL Nnn?umnu. OH. HOFOO Im mu: OH. HmImrIcm. . 0.. .H. 20.28 . .. va QHN 393 .oFJa no .Om OmnnwunIHII -.. . unnthIO Hm mm. I (D Iwm ..muH ..I Inn . I 052033 mm?z?oa .uc?una 00:3. 032. 083%.. 3.032 Emg? C:mm:0:. 2.0.. 20. mm? . . Page. I - June 22, 1965 MES-1.65.11. .- E?s-1265 (fluro) has been found to work well as a staticnary phase. It also is available from Will-c133 Instment and. Research} Creek, Califcmia- Any aggd which has dissolves: in?ahe chloroform-extract 2:13: be it will the chromatcgrapnic analysisLOf the 2. dioxin- 12_. smalrtical Lab?ratcrf Reference: . - 'l G21, E. Datamation of Capable of Causing.Chlaroacne in Process Samples by Gas-Licuid mw.6l'r.19, November 30, 1961+. ?5 .Silverszzein, Corzx?caticn. {cg Tittany, P. Analytical Laboratories, Book.9,._ c. .3: 92., 102315 1?32. A. Tiffany - I. E. E. Gill Analytical Laboratories - . 57:1.- Euilding 1' .- 12.93CONFIDENTIAL Disclosure Rest'rictedPursuant 5: ?1 To Court Order. "Agent ,le Qrange" Product Uabildy SD ngan?on. MDL No. 381 0? anupduau FIGURE I -Attenuation 1 $1455.11 2,3,?7 enzo-p-dicxi 114.4 micrograms Disclosure Restricted Pur5uant To Court Order. "Agent \_0range" Product Liabudy Ltrgation, MDL No. 381 755% . - - - - - ;i . June 22, I965 .- Attenuaticn 32 10 FIGUR2.5 -ppn - 5.1:3: Attenuation . _w.65.11 . benz?-p-diczih a; imnu? .I- an NH 1" I Disclosure Restricted Pursuant To Court Order. "Agent Orange" Product Liabimy DIR: l1- .3 ?carbon a 41uhaanu Curm 1.0300 die .rualhnuu ball aqursonl :1 "(tutu an: an hu?u??huu .3?qu unurvnuoanatun;uxn as ?can? aboa.r uudn cnacunn and an tn. v: we. nun onuLOS L250 la. Shut-5 Uta ?Bunyan nuauun E1. dahk??t ?an-pl. ho nun-40:2 DC. ?or. rhlr.? .tu?ut [banana 2.3 Mn .?rnc?r 35on :u 9300.2? 3.5 agnooa a? on usage": art. uno.n?n unuhns an?.u .3 unnu urthuu . can .- .han nucu cu .nn Ln. L239. .363.- 3.52 :10 L30 Itru 0: ohm in. I?u. nu .nu Eta-Dmmcou .NMVuLlrLIb.urnuv?n 2.1.. nu: and: In 44:. Logan . -.-.. 3. m. .n .I- in: but uanCtoo luau?.5 .- ?00 9.50 IUdanz ?u 0? U. .runtc urn .Liuno nuns 0.5.. Oahu nu ut?nto a mu to . unwraunbnhuu v.3. .Mau rah? no on! nun I U?dha?r?u ??nd??undhn?. Fund Cu it". the?? go ua?auun Sudan?: ?noun 0.. "Haunt:- ruu .5 tour .5 on no. "swoon-nun I. .nuuaohr. nun-n25 . ocaoadb- vnuvon an. no!" ?09?qu Out-3 no ulanuu vcuu and. no nob .L-ucoa .34: Linunh nan .23 2.3 ?2.3 uuonuu .9uwnuoLn-L Una-o nnuuob an": 41;. 2.1. .9413 can nuaunuz?u ?Luann-.0 nuunaan on" .3 In: on agar-nous? Lou noninf? usa noon nu .uhunun thin It?u .. dud-.10 can?C1" inand ho Anni-.96 Inn unnuunuat . an 52. 93.3.9 1I u .I. . . 1 ulflulur?nulvhc .IHM A mm in. . . .?IIvIl-llill . ol0.0.. Anna-nah n3 . unamrlcoluhshnulhEmhh?uoaunu .: an.Inci. Adtl-an.h in? .3 IL: can? ?g?a?anal?u?lu?lbrkuu: ion-r..- . ?Quechua? . was Urn-nu .252. .u rhuhL ISL used: a Palm qun to Du.?uvu?ru.u oc? 14 I Isa Dru" I o. . fir. 1?1. Legal] - 3.331]. hk.b.-f I npnuhscn DEPARTMENT Hssculrzs IL. 1" "Dan 5.57? CENTER Dr. 1-1, A. Taves- Mr. A. Z. Conner Wilmington, Delaware IJune 13,'1966 arm??ns. E. 13. memoir. beam-.mr .each are listed on the_outside_of_the_gontainer. Ehe_ . FROM: J. J. scab, mm 310}: FORTIPIED SAMPLES FOR TESTS In accordance with your letter of November 18,? 1965, the samples listed below are being sent to you for transmittal to Dr. Oettel of Badische, for use in the bioassay tests. Approximately_lo grams of each sample (except for the pure dioxin sample) is included. The samples are packed in four shipping containers, and the contents of individual samples are also clearly identified with an appropriate label. have indicated which samples heraldinzin_addgd to them: but??ave not shown the. abel. IT?you wish to provide Dr. GetteI_with this information, it is included in the attached list._ It would be useful to point out to Dr. Oettel that the samples from-Group 3 and Group 6 are more easily sampled if heated as 'indicated. . JJF/cbb Attachment Mr. E. E. Christofano Page 1 June 13, 1966 '2232222222 SAMPLES PREPARED FOR BIOASSAY TESTS- (1) Standard 2,h,5 Acid With added Dioxin Samnle Designation . - gum. Dioxin Ad?ed 214867-4161 x14867-h1-2 2 X1u867-91-3 . 5 x14867-u1-? 10 th867?41-5 .- 20 (2) Plant Grade 2, ,5 acid with Known Diem Sample Issignation Ikppm. -Dioxin x15280-56-8 -Ij 3. 215280-56-9 J) Plant Grade Sodium Trichlorophenate with Added Dioxin Fortification is based on a Consent,-- ., . -Samole Designation .. 156m. Dioxin- .'115280-5.7- i . 13.0 to aids in ng(L)lDioxin Sample - 2H3 7.8 tetrachlorodibenzo-p-dioxin - Ibsignated 215286-56-10. Ethyl hexyi ester or 2, ,n?z with added dioxin (truth-Rhap awen-o Fortification is based on il? 244,5 Samole Designation ?ppm. Dioxin 315280-56-1 - 2 X15280-56-3 a 5 '15280-56(6) Hon-sapo6ifiable fraction from wash solvent still. Designated x15280-56?7. This sample contains unr eacted tetrachlorobenzene and relatives, anisol of trichlorophenol and related phenols, toluene and a small amount of Sidwell. believes this is 193 here the dioxin end in are Storing -21.- in -2 ?r-nmt? day. TD melt. DwoancouPANY - EXHIBIT .1. E*h'b (:me I 37 Hesse k?L A . . Wilmington, Delaware Fr ?5 .1, ?1 3'7? 7/ August 1965 .7, - . riff. - M. 19: DR. 1.31m, RESEARCH amazon 3/ more; J. arrow, ANALYTICAL 911':st ANALYSIS 0? 2J his-'1' ACID Raft? run 'D?onni' . Attached 13 a tamer: of the analytical date. obtained to date on gr current graduation 2.11.5-1' M16 *rom the Jacksonville Pfent. Alec ineluded are the mun stained for three Ram? samlea. At lease duplicate mania: - have been performed on each sample; this includes individual and workup prior to gas chromtomphy. Values - enclosed by brackets repreaent multiple injections of the sane extract. lbe values rted for the are? are calculated on an as received been. do not Lame the actual content, I feel these results for the Half? samlee 1:91: a greater sensitivity than we have damnetmtee to date. The? are 31ml: the values calculated ?rm a gimp r6399? oz; the_ GC ammo music nal vol-k. wel??a?i?hg fo'?h?icatiee and recovery. be completed before mah.m&e13 is 51m to a different! between 0.2 and o. 4 13.9.3. Portlona of angles curmt mleLto which imam amounts of anm ?3 The remaining samba of 2A 8:16 matted by Japlcaenville should be cowleted shat-?y. ?3:12:59 results will be comcated to you, as well as Dau' a findings, as soon Ian available. ?549 Eff/egg - 9316 Dr. ?0 Attach 1E page 1 VALUES won SAMPLES 0F 2.q.5-T ACID AND Mu . . Sample Acid? Designation Date pup m. Dioxin Lot . u-15-65? 3. 6. 2 .9, 3.0. 3. 2. 3.0 I August 2C. 1965 . Value ,32 Lot 6-1-6-15a651 2.3. 2.6. 3.2..3.6. 3.3 Lot 2 3.7. 219' Lot QFT. 2.5 Current 7-7-65 1.1, 1558 . 1 Batch 26W .63, .11) . "55343387-9532f11111 . .. 1. ?.111 LEVI 0.1111100.920.. 0. 39.000 .- - . x100.032 1 0901-1 00.009000. 001.600 0010165007.2 I .32. .1 . . 11.111 . . .. ?0.00. . . . .. .1 11..11H1mmI.1.1.10. 1 1. I 1.1 1 umnwmoquu-Hlms .. .1 111.1..1I11 mm . .. . .1-. .1 w. .. 1.. 1...uwhtk11.1 1 I I 11.1.? .11. . 000.939.05.00 ..1 11n111111111 . . . - . . 1 .. .11. ..1.. . . . .. .u 11.. .. .. .1. 01111.61 111.9111. 0.11.1 0.0.1.0011 100,0th0 09. 011009.909 EHQHI u. . . 1.1.. 1111? ..1. in .. .. .. 111.100. .1.. 1 11.11.01.011. .1 100191.110 .1. .. 0.109000. .. .1 010.91.11.11 . 1. 1.111.1111H.I.UII I I I 1 . 1.1.1 . I ..n111H1..1 . 11-11.1011 .1110.? .. wag 30001I?ll-111i ..H.1111 . ..1 . 111.111.111.111}. ..1. 11. 01.? ?again?000 Hum 10100.0- 0.000010000000000 0w. 000. 110.09.10.30. . 090.00 0.0 0001009005119 00000000000000.0000. 1.0.009ng 0000000050 0010. 000.0100. 000001000001 11 . . .1I11. 1I1I.11I1J.11 1.11.1.1111. 13.1 1 .. . 00900?.me .0000. 000900000000 00%. 00000000000000. 0.003.100.0000 ..1. u. 00.0. .0000. .. 002w. .00. 000- 00900000 N. ..110. 00 .00WH040.. M000. 1110.0- 10.5000 00000000000000 0.0011. 000.. 0 00.0 09000200 0.10. 000 mwomnn?ub .- . . 00.90.019.100 000. .moto?tum I1.II11II.I I .II I. I. 1 111-a1?- m.1 .I111In111l 1QI1IHII 1 I.II.I I. . 1 II. ..II I. .. 11111.31-.. . .1 .1.1 .1 :0100 90.000.00.00. 0.0.9.0..?110000050000003. 00000 000.00.. -1 - 00.090.00.900 00.. 0000.09. 001000.000. .. 0 909000. .00. 00 .000 .00 000000.091 . . 1II11-II. . . 111.0000. .00.. .0I11.1 11.1 I II.1..I.1.11 11.1.1 I1 1. 1.111. I II. 0.111 1 1111.131? 10H41?I1qxnhu? :41?le .IMII 1 . . - 1. 1..1. I 11 1 . I I1.1 .1.. . 111.110 11I - 0.10 . .. 0.1...Mama 1 1 .1. I11 In?111.11.191 .11I11 1.1I1I1II1 ..1-.II I1I1 I.11 I II..I.1 I.II1I 113.111" 1 11 1. . .1.IHII1II I I .-.H0100 00019009100000.0000 000000.00 ?00.90 00 00.00000. 0.2 00.100 00900009000000 ..om 0000.09 0.0000500010000000 0.00 0090010000100 nnqnoguwm--p? (11' 'y't 1" 4. . 1-. "ul- l? 42Ena?lulp?':ou'l . . I '1 Li;- 'Il?mth i" ?i . bos? mar?" - 411?s?? I . 113? I. Ii' m'a'm? 31:13:10: .- trans 5:133:95 5.2: 5 511?}? Emits-9113112231 l??an _.sa.rn? 592d. 339;;9 pun-.anqneafam; 1-59. sn' .g'aqlzat?qxsso? Ed'?li?p'. 83' . 3o s'aznssa: d5 112113.321" 2. 2 Q. $1530 a - -. 39' 3'1. :15: 3mm: 23' 02. .-I ?1348 .L?Patpfeaz 7-. a 11:03:? gen-rgs'aaxa . a is m. . 18am, - 3'61;- ?roqoa'rv' on "503'. 3. 7.39 acn' ?3:11.10 sm?q .1 UT: 11:19. :p3 31199 {an 31-54931" -,30 3:9qu 33:1 qa'm'txadx 91-3: 78129 . . "oh . '5'34- mod- _?35 II. . a -I- -I.. z'p'euopseaaq- 13:11 q. a" 2' I 23"" -.- . 31-33?tam . 0iams'sa'z - 4- - -. iacp, a. - . r. samssazd: 1 -. .. tans-.2? :5 Swamps-I 169??: Adam; _pm?rrorreqqau: a: . 4- .9. 5'1: ?.23 h. . 3 if aims - - apt-?51 mama?! - 33? yr. a: figmtiqm-Tatnc :ggr-1939mqoxoanma; 1.1112: 339.4 12's.: . .. o. 4-- ap?nea-Ii' Iii-D .1. 138353-3113. . 1. I . 81203-421: .?papzog .- "79111-5 3325 mm g! tip-1:5; :O-?amig? "$3174 1315 I 11:5 18$ ?373,379? 9 _amixq'enssazci1m ?pa: smog-1c; 812'? 535 .9313: 368? .I 3-3.. I [1.531.113 1 5; an?, I1- 11': ?Jr?f? th'rfr'n? 2291'? ?33 n? i?u?fsa - T1111 .- a qnpo: gm? q_ . mad??m-E?q ?22m . ?nk .- "31? . . 5:$5.915 mm "on. o: WJAJ . Hun?"?ung on JM "no . WEE ?3383 .33. .l.n.?..b??Lm.BoWI ... Hn uH handounauabun?jnunuan?a ?30033 .vouunuu?nu :unuua?nudnau?du? Fag now? an? af?x an hoga? Ha unuq?? a vu?onou and- 313335.338EE3 . .. . . an. . goon E5350 ?haunt. 3 nag?.393 u??um?uua $3 .339." ?351mm: ago? tunabqn ?muo?g?a?uog?a?g?n? . . . 3m? 3 69.3%? 3 Hannah". 38 o?u .85 Efren.? nuh?aum 25m .H .b ?ubuhnpn I. In +5..ng - Ethibi'l? 9E: DOW CHEMICAL COMPANY . . mums, MICHIGAN m. . . gebruary 3, 1967 3.JOHuu0d g? ma?yf - m: if 49 ?,2f To: c: cc: L. Corbin D. E. Pletcher J. H. Gowell From: V. J. HoCoy?Z?Uh/ THOMPSON CHEEICAL theme; 31?: Mr. H. S. Buckley of Thompson Chemical phoned Howard Sheldon February 2, indicating that he believed they . -- - ., He indicated that they already have two- men affected and believe that they may have two more employees that appear to be affected as well. be re using Hooker's tetrachlorohggaene to make t_eir I tr rop eno . I Buckley was askinz 1: Dow woglg have Iqr_oedical treatment for their We do not competitor as but EElieve that any adGIEe would be in order. It you concur, he would appreciate a phone call and his number is Area Code 314, JE 5-6608. 1k (05' 1?1? .Pr. Ewan. mu. AI . ?llf ?.Lhmmuumxnf u? - - 93? 2f?. .. ul . I . .h.n Xbunc . 2.1. 3 3 a 54 11'. ?2'1 fig-3 . ?glint-JV l- (L u. . ?war-G? 1.11.14 . .. . I I n4. 111.111?. 11111.11Vk??l 1 - . ?fi?uanumuu?vx .. Jaw- - ii?uyft?'. Jilin . 1011 . I. . I \M?l . . . .wfl. . . blur; . gig; 114111.111? .1. 1 - ?gh?u; 1.. 1 I?1th! a mm Smumxm .. . WFUIJHH 4.1.. . 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Maw whit) ,u??uhua?h. . . 3-;c . a- - - frE'ZO'rJVr?cwz ~312'21gm.? ..?Jigsaw-:2 CAL ?3.3.6-1141 rectum-y -11 196:- m? - .- 3. following participated 115134551011 t-E $55.26: an if, ,ramwmm??z??; $4314316- rwem - ..4: . f. - 1693. Dir?ct?t of Hm*kstaag il? 73? 3:333; General Sales E36626: . r? ;9 (3.. w. L. Corbin, 6: 22166253216}.- 210:3..65 551:3 3.63336: 7- Hatr13, Sale: Hanager, Chemicals 3- C. Tucker) Product 36163 Haa63?13 Industrial CheaicalsL E;-c c. 3- Ousr Manager, Flats: 5616:1671" Digit; a; 13.5: 5-. Hr. L. Silverstein, 31063631631. Hr. aces Doedeas.. Chemicals Depaztcauz- (P*odcct-vr) R. J. rm bible, General Sales H?nagar._ at. Innis 525166 6 -- magma. _12iv:! nterearzce 62- .6 and that: . 1' EU rcdu: chloracr Ha: L's-change tn: cm?iticns af hydra 1;.513 c?f enra- nzene to tricnlor-oghcnol, the layer-iv: ro- duction rate to. at 2?5" of 316 2:612" taken to AN ia-DTS?m output of chlorat..cger-: :66 tiara-1&1 and inch is d?'ing. gore; trod-4:: 1311 units and taking a studly oi opticua pvoductian car-151310118. 553:. Silverstein Stated that: an all-but-effoz't was 316-163 2366 taint-66"? . Frescnc: of chloracnegsna in of 2:1 Etch had been retained. He said. the pethod being used was sensitive The latest anal-1:631 nether: not: v-c. 152.1: written app} an older mrmmao?Lm, we: ?9 Also, Silverstein presented- :3 OHPSOD-u?rdard fbll?pe: entitled ?The Prenarazim: of Irichlarophencxyacetic Actd Fermaticm of. Excitcrs." He afferec to ac" uaint Thompson-?38 1, gym? with the W1M?J?ngau in z? chlaracnesmss .I ?hty would vzs1: Midland, Hichigan. - ?11V?3r51?81n 81.30 stated. that the chemical or gm: chro-atograph1c 13 or analysis for c'hlcraczw not 3.1151 :5 as t__he __aqip_al 3(9? Utthod Involved r?C?i w'TEn ?qute an1n~?rn? tn r35: ?t ears.' w?WIJ-Whun-WHm-m. "hnwriCruz-@3111: mp. ?m w- 'uru \1?Awa. 3" ?q Lb? 1.7.0.1211) 3: CLWLUVHA re LLAQ (I ?if. 3: ?Mfg; . 21,12ij "f?uhaz?g ,kavwaxLxs 5 ?t 0::qcsred that in ed?ftion to nding scmeonc itsa can analytical departafnt GE Thompson?Ezyuex i to Instr Dou' 5 ts: mzthod, that zgpva;sd a :ncu?trial 1: c1 :0 51% 2 Eva. 56 v~ntioncd that '77 E. E: Eva: gas rzapnnsiblz is: hagl-h cf D?g_g_pgg?gctn. 2 at 1: ed that n- :3 cf an: new 51.ndings rsgar?ing pgoducrioa were hci.ng tried cut in :ne plant, an? by Ftbruar3 15 be {:pdctea an indication if it uoul? r?zuic -n icy-revtuen: i: q-11lify and also in ?7 291321 of trichloraphawai ptc?uce?. Ea c?z=ed hat va' tr ?3 5&7591 in the 1nishe_? fc*: -2 p} z; no dct_cc:ab1 cnzunr a: a? chioraC? Frown. He said that f??faucz didw :cva~iu 30:1 Hapl bug that in method of ..- handling the 5:111 bottc25 bad to be developed. 25 let that a reduccd Leduction rate nc::sl) eight remain in c?fecf thtt$ a: four corths wales: a break through accuzrcd. . . b?*n2 gt?s?a? . this did no: prev: in be the case, I. because of the glass: ccuplete dg?truct?nn ei tr .e plan: by fiz?: 93:. He said. he was .=m53 Hh?ch ma consume: zr_1o of Ebgse gre_s dby t7 the quality of -aw? a trichlorophcnol, ES well as by their repeated statements the: Don haL= never had any if Problem with chlorecne ?109 thei: trichlorophe n91. the result of Drw?t trichloraphennl cu1:.t3 and regpld, in'o . a cantract ?likifc?a?nnwza Wli?2? . 2, also 52 atcd that he felt had a firm contra; with ?ow for to 1 mill ian_ Pounds of :1 in 1965. Be 361d only exceptions acts of God, Far: floud; 5t:1kes, or 5C?1dencs? He f-1t none of tad 02::rrtd, and that DUN was obligated t? n-Hayuard' It: 11::mcnte or to stand any 1 uses if 1 Mn?iayuard by erct:aing elsewhere at h?ghcr price 3. Ho tad.cat94 I 1: rcptarcd likely th51: Th cc-Dsc -HavLa:d cou1d_- furch?3;_ - 1-h: caul? mxrnishAgbout 10 tipkagtz of laooctyl {3 .ijtcr of zlh.5-.scpson menticncd that. under the of" t?L?Dpson-Hawlfd 5 .1. trich13:c phenol contrec: kl: Hay;:rd ?03 tn b? charged I3F3 . He Doihuid I i I I r?Itcm:: 393 carid ?Hr. Grant agraad this was raadc~t- .. . 7 . a 5;-c . . 5 Grg?: said he felt first ?rublem be: takin car: cf customers [2and antprisc could 2.1ir requirc- . 7. a- I 5 513?; nanS. he c-1d Dow did not ?cel_they could co this ecu he was qu1:c pleaszd that Tha=?xcnu?ayuzrd had been care successfulVarious ucvs c5 handlin the GE hath ?boc-son-Eavvacd and Dee I- - .. . . f} ucrc discussed. E33 Thcc?zcn suggestec that it might be to attain 2.4.54? acid its: ?c?santc, ship it D93 :3 be ccnvert. ?gt-731 . a - .- . . 5 fl: {fa-ll we I 'u -. my): I ff} into catcr, and than ship back tc Thompson-Hayward than for 'Hu'aard to buy the ready-c362 cater Eros It was dectded that ch15 Bould be evaluated, but that the-cast important point an: :6 take care of the requirements. 312 Boedcn: indicated that conversion of the acid night he the least'cXpeuaive route. '1 - In a crivate discussion Hr. Grant told Hr. Tho son that staff would not his aacic any Iig?ilggy, but that Don was a company that vantcd to be fair and would try their best to work out a ?31: sctilcacnt for Incapscn-Hayward to cave: losses resulting Erna Dow's inability to supply'TCP. Hr. Grant felt that should seek to cover its needs for acid or equivalent Ere: other acute . . 55 la?g LS Dcu'a zupply aituarion rzcaincd uncc:tz!:. It was agreed that Thor?son?HayRard would give furthc: consideration :5 the purchase of requires: :5 oi esters from other sources and .f then discuss :hc saute: furtnc: with Hinbiclc. Also, all contact: With Dow prefcrably should bc hacdlc? through Hr. Einbiole. Lindlay S. Bc?tlzy . .. - Fcbtuary_15, 1955 DEFENSE SUPPLY AGENCY DEFENSE GENERAL SUPPLY CENTER RICHMOND, VIRGINIA 232m II nun t? . 33 January 1953 SUBJECT: - filauclfiuaLiun ma 7 Nov 67 TO: Izo..u.mnd1ng Officer sum (55.01:) Hr. Burr-3n .:uqucst your comments on the cunr'gs b, Jaw Chemical Company to specification AFPID dated . - . - . . .1: in attached letter. . 1 ?nal 431532: F. LLIHS Contracting Officer Dircgcoratc 9E Procurman and PruducLion . - . lu' u. (5'71. r: f- "3 graying: f'Oi- ?Eli-M lair-?17 am; emu.? at WI {31 In: 2.5-1, Nu? '9 30-1 Label. 1. numb?: no tu?o La mun. an: SORK: .31. It.- In." {In an. ?3 .11 ?ls-5L2 huh um: Auk must:- 4 ,4-0 In! 1.10.. . PM hat: (in: ~Lumt1m eat no a. {Map opay no new: ?anus: nu: can 55 In La gallon a: an.? un.? hunk 53H tun-.5: daze-Ln". 2. Menu-cu mtt?umhnbiam' taxmuttm 5163. 514233515 guru?rmuh flu-W :mjudos noun-J: of that ?can: at 2.5-9? in an gallon 3f unwr- are arrivals!? in balhlc?dl ?Limit, Lu 46:1? Laval-n: In one 5:11? 01 Teams 1.51. Amman 33 was): par an.? of. 2 64-822 A 5-1? "to" ?a u: and minty?11:31. Arr _n_qu__IFu_ ?31:51 a;?apliahh ?rotujxm 1E_Im.__zau 1min: a: nun Lanai?: counts-are In at: p: Ina-a It Lamas hen-h nu? 0.1. 81m 911m at 105 to c: a sauce 91? um. 5mm smut? at: ?Hm a: 71:33; 181 provide the can. chip.- of hfulutm in EYE the 95 Fund: 0? an: 18 4mm tn dune gum at m. 3. bot-Llumtatm when (ha) gun gallon-I cl lawn: Int. rt? 5? ?Ho-stir. no line- pill-m ocmjn?jf?. ?'hfla gunman mu mum m1 15 minus: u- flan-shun coo-uh- city ecu-halt than quanta a! 4411: nan-dies; mind in Wm WM 2 Incla C. 5. mm Chin? Crops this?: Dinlthela: Cal-Indus Oiih?cr 7mm: ?node: In. huh. rum. Myth. hr. Ill-non. ?53 ms. Herd. GCED LI: M. cum I'll. Hilton. we. 81'. Van-inverter. an91th m. G. 2. hackle! . - m. a. 9. Donate: C51 J. I. haul. - "1 3.1571 Jim-art? 3% ?53' l?pogvl 0? I ?a sum. at .- .l?f ht Coll-In? an [Ido- a [Unto-q Inn-11 II- Men Minn-u 'umn Hutu-'1 no. ?may lit ?whoWm- 55lira-m- I in. - r: .5 nun-m .. I ?Jinn-Hui. \a vor"vn~\ ?ol 10 03?50- .utu.? Malta-1- . -W ?n-I RM ESQG Im?o-Iu . . CONNOI (ID 3: wwr?" via-q 0? I..- 0- 9: van-9- 3-01 7 - - inn-nan ?Mun-my '0 I I. I'll! Down an am: I . .-.. (gum lg; San-T ESTER . ?2 Lbl. o: 9.4- I) am! 2 Phi. at .4 .5- Icld Equlvalenls Par Gallon Acml mo trunun- BY 0 - .la' . .?gmlx; l. -- ww- mmrasvmm, me. fruMnro-r-?t kl . MKAHSAS End-match" ?nu-lg!" 72075 . unnsm' we 5 1 nu. muwrmelm":- II- .I nun?n? I I I_ocoma-us an, np 23:: (9 HOWE ?Mo? ..31 ?55? 5:55 ?51 55565 ?F?x ?55?1435535 55"? NW i ?ll-r: .I. Jail. Jilin-14" 1f!? .I . aw m5 414Mg.ru l. nu . I. ..I (an.Klo. Ian I . A .I Kiri ?\fj m3" 5:133 3:31:33 In? an}! ?ff' I IfAir-tun14:1? ?gab? I I . UV 1b @3313 I [2'51 ?Bu I - 'T?l?633$ iIsaxM - Live 33 It? IEZII In?- 35A Iii" .ILLITII VI Iii: Inky. If?? 5J1: ?33 m'IrI I. . .I-, . . .. .. . .-. *"123guy.5959 If?; r} I I I of? 1.332333% a. It?? 4?33rtr'?itM13. 3 I - 3'13. . 3n ?a?cz?u II 3 35% 'L'ia not .illei St) TORDON l0! MIXTURE is recommended for use on utility right- -ol ways to control unwanted brush such as aspen_ bai Jan sari-i, birch blackberry. elm, hickory, honeysuckle laciist, _maple, oak, pine, poison oak, sassafros, spruce, wild cherry, wild rose and many other woody plant speCies. USE BIEICTIOHS UscI' gallon of TORDON IIOI MIXTURE in gallons of water and apply as a drenching spray to woody plants, up to 6 or 8 feet tall, after the foliage is well developed. Saray should tnomughly wet all plant parts including foliage. stems .. and root collar mg conditions in humid areas application made up to 3 For hard to kill species Such as ash and oak Since TORDON herbicide a minute quantities may chi; growing and darrnant perii I. otherwise permit Tainan; taming it to ble plants nor tocontacrsusc ?owers. grapes fru trees i types including soybeans plants Applications by air; . pain; rs should be carried at 1. from drift. DO not apply grapes or other desirable also spray the soil around the roar collar Under good graw- "if ejsprays are less likely to drifI Nicoritaminate water used it weeks before lrost is usually effective Hawever_ application - purpose; Do not i made when the foliage has lost its normal green color and Vigor may not _QtVe satisfacmry results . 7 NOTE TORDON mi uixruiis will not mix on. INGREDIENTS: ?Hf tic ?Rwanda-line ?it 10.2% at? all the hilwadzn 3 salt 39.6% INEIT INGIIDIINTS 50.1% ACID EQUIVALENTS21.2% {Kn-v- oil-Jo- the Maui TOIWH {lb-[160 Printed tn in Iebruary I964 REPLACES SPECIMEN LAIEL JUNE 1963. THE ONLY COPY CHANCE CGCIINS A INCRED- IENT STATEHENT . glizers, seeds insecticides, lui cause of the difficalty at and other equipment tollm TOICQH .sjV?? min?"umit": I p?iu?aE-is? PBHCAUYIOHS is rbiCIde olnd 2 4 are highly potent, even !5 maycousc dome-x to plants during both want periods VIM-relate. do not apply or l0] warrant or spray mIst con- lminole soil use? It 'grow desirable suscepti- I-ntoct Sascieptul'nk l-lants such as vegetables, uit trees. Earner-motels, cotton, beans at all .- yay-beans and other desIrable broadleaved ans by mustang ground mas and hand dis- lcarried 043! only when there Is no hazard -opply by In the viciml?y of cotton, desirable susceptible vegetation Coarse drift. . Do not allow the maternal to er I. {d Irr-gation drinking or other I. Do not store near food feedstuff fertI- ticId-es, lungIr- aim or other pesticides Be- ticulty oli thry'outhy cleaning Sprayers went fella-sinng Its use for application of such equipment should not be used mama for applying other materials to desirable plants Shipping containers Shauld not be rc-used for other materials which may be applied tr desirable plants. Note Be sure that all use of IOI MIXTURE can- farms to local regulations. IF SWALLOWED CAUSES IRRITATION MAY CAUSE SKIN Avoid Contact with Eyes, Skin and Clo-thing - Ill can 04 cure-ct. Hut-h qt: and this with" plenty of not": Win-adieu! aunt-ha. gnu-l1 cahuiutul and Inn-d- tel-cu HI- an. OUT OF THE IIACH OF CHILDIIH AND ANIMALS NOTICI Seller makes no warranty of any'kind. express or Implied, concerning the use of fins product 'Buyer os5ume?s all risk of use Or handling. whether In accordance With or not u. 5. Patent No 2,453,983 . A164 31;??g DOW MIDLAND. MICHIGAN DIVISION (-57 . 394 . HERCULES INCORPORATED {/13 1:11:99 - rELePHoiqr any-556418? . October 25, 1967 if Mr. W. E. Vandeventer SAAMA Attn: Kelly AFB Texas 7825} San Antonio. Texas Dear Mr. Vandeventer: Under separate cover we have sent you four (4) copies of proposed Specifications for product ORANGE. .Ve believe these are both practical and sufficiently rigid to be acceptable to industry and to the government agency concerned. Attached to' each 'o?f'the four copies is a'set of'auscilliaryjnotes presenting supplemental information for those portions where the change or addition seemed to require a. bit of explanation. There may he some points which merited explanation but didn't get it; if so, please let me know and we will provide it. We would appreciate any comments you may have and stand willing to discuss any or all parts. . It certainly was a pleasure to have you visit in Wilmington with us. We felt it was a very constructive meeting and appreciated the opportunity to exchange thoughts on this very important matter. Please call me if you have any questions or wish clarification on any points. Very truly yours, ,7 M, R. B. Scott . Director of Development Attachments RBS:alc 8% ?ml? Uri-H? I at" crew-rho "vaIrH-v . . "?11 1; I -L. r. 73:18?; sir "5:53 1an K9 3.1 r; 361.5 operation. These perhapsmeritfurther consideration. 2.2 Other Publications The reference to the Association of Official Agricultural Chemists (AOAC), Tenth Edition, 1965 was omitted since the proposed Specifications do not include the Cl assay procedure. 4. 4. 2 For Test Lot sizes would generally be expected to be less'than 545 .55-gallon drums due to physical limitations. for tankage and mixing equipment, thus lot size was cut off at that point. For those instances '_where lot size exceeds 545 drums, the Sample Size would be determined - by multiplying the Lot Size by O. 015. 4. 5.2. For Test Alternative sampling procedures were contemplated but not included. For example. a snap sample from each of several drums of a. lot. put together in one sample centainer would result in only one? actual sample for analysis. thus reducing the number of analytical determinations required; only one duplicate set 'need be run. generally. Also some thought was? given to collecting a representative sample by compositing several samples taken during the filtering step. or during 1 Composition . 7 - The infrared spectrophotometric procedure for determination of n-butyl 2. 4-D ester and n?butyl 2,4. S?Tester contents is covered in paragraphs under the 4. 6. heading. Word has been passed on to us that the Philadelphia laboratory has been quite happy with the method and it has worked well in their hands. We believe it will be an 7 eminently satisfactory method with regard to accuracy. precision, simplicity and time per analysis. 6. 3 Information A few additional notes ?covering other relevant aspects of ORANGE have been included. Although flash point, freezing point. and viscosity should not be specifications, these characteristics are de- sirable to know, for guidance put-Eases. October 24. 1967 e. nu. quu-- on I r1 32% m. F59 October 24, I967 MILITARY SPECIFICATION DEFOLIANT: ORANGE 1. SCOPE AND CLASSIFICATION I. 1 Scone. This specification covers one type of defol'iant. l. 2. Classification. Orange is a mixture of equal parts by weight of_ technical n?butyl 2,4-dichlorophenoxyacetate (n-butyl and technical n-butyl 2. 4, 5-trichlorophenoxyacetate (n?butyl 2. 4. S-T). 2. I APPLICABLE DOCUMENTS 2.1 Government Documents. The following documents, of the issue. in effect on the date of invitation for bids or request for proposal. form - . a part ?ofthis specification to the extent specified herein. SPECIFICATIOBJS AND STA NDARDS FEDERAL -, Drums: Metal. SShGall'on (For shipment - of non-corrosive material). FED-STD-595 - Colors. MILITARY MIL-STD-IOS - Sampling Procedures and Tables for inspec- tion by attributes. (Copies of specifications and standards required by suppliers in connection with Specific procurement functions should be obtained from the procuring activity or as directed by the contracting officer.) I .- - H.- u-I? - In? v?w?wqw- v? In . (Tm-1.5 - MIL- . I I I 2.2 Other Publications. The following documents form a part of this Specification to the extent specified herein. Unless otherwise .1 specified the issue in effect on the date of invitation for bids or request . for proposal shall apply. AMERICAN SOCIETY FOR TESTING MATERIALS (ASTM) . ASTM Standards ?13664 - Method of Test for Neutralization Number I . by Potentiometric Titration. Dl533 Method of Test for Water in Insulating Liquids (Karl Fischer Method). (Application for copies should be addressed to American Society for Testing Materials. 1916 Race St. . Philadelphia 19103.) UNITED STATES PHARMACOPEIAL CONVENTIONthe Pharmacopeia of the United States of America (USP) Sixteenth Revision, 1960. std..- ?i - (Copies of the USP may be obtained from the Mack . Publishing Company, Easton, 18042.) anus-Ln? pna - UNIFORM CLASSIFICATION COMMITTEE Uniform Freight Classi?cation Ratings, Rules. and Regulations. (Application for copies of these freight classification rules should be addressed to the Uniform Classification Committee, 202 Union'Station. Chicago, Illinois 60606.) 3. REQUIREMENTS 3. 1 Material. 3. Com osition. The composition of the defoliant. "Orange" shall approximate :1 5003-5070 mixture by weight of technical n-bulyl - - I n?I-uh-I- u-m?n-o?u?q I. 93 Baez - (573.17 MIL- and technical n-butyl 2. 4, S-T esters. The percent by weight of technical n-butyl 2, 4-D and the percent by weight of technical n-butyl 2, 4, present in the mixture shall each be 47. 5 percent minimum when tested as specified in 4. 6. 1 etseq.: the total content of technical n-butyl 2. 4-D and n-butyl 2,4. S-T present i1; the mixture shall be 95 percent by weight minimum. 3. 1.2 Appearance. The defoliant shall be a clear, amber to dark red-brown colored liouid. . --iT XMAS 3- 2 M- ORANGE - The free mineral acid content of the defoliant shall not be WHENLD greater than 0. 5 percent and - - The total free acid of the defoliant shall not be greater than 1. 5 percent, when tested as specified in 4. 6. 2. 3. 3 Undissolved Matter. The defoliant shall be completely soluble and shall gag; gg of undissolved matter when tested as specified in 4. 6. 3. 3. 4 ZlMoi?sture Content. The moisture content of the .defoliant shall not be greater than 0.2 percent when tested as specified in 4. 6. 4. 3.5 Specific Gravity. The specific gravity of- the defoliant shall not be less than 1275 nor more than 1. 295 at 20/20 C. When tested as specified in 4. 6. 5. 3. 6 Weightper Gallon. The weight per U. 5. gallon of the defoliant shall be not less than 10. 62 nor more than 10. 79 pounds. The-weight per gallon shall be calculated by multiplying the specific gravity. observed in 3. 5, times 8.- 33. 3. 7 Preproduction Sample. When specified in a contract or purchase order, a preproduction sample of the defoliant shall be submitted for examination and tests. 4. I QUALITY ASSURANCE PROVISIONS 3247 151-8 MIL- 4.1 Responsibility for Inspection. Unless otherwise specified in the contract. or purchase order, the supplier is responsible for the performance of all inspection requirements as specified herein. Except as otherwise specified. the supplier may utilize his own facilities or any commercial laboratory acceptable to the Government. The Government'reserves the right to perform set forth in the specifications ?here such inspections are necessary to assure supplies and services confer-n .n to prescribed requirements. 4.2 Special Provisions. 4. 2. 1 Alternative InSpection. The supplier may utilize any alternative inspection procedure which will insure equal or better assurance of quality by submitting a written proposal, with justifica- tion. and obtaining written approval from the Government prior to instituting the procedure. In caseof dispute the procedures of this specification shall govern. 4. 2.2 Objective Evidence. The supplier shall provide evidence acceptable to the contracting officer that the requirements of section 3. and 5. have been satisfied. Ta 4. 3 A lot shall consist of the defoliant mixture. produced by one manufacturer under essentially the same manu- facturing conditions and with no changes in -material_, with the following additional limitations: When produced by a continuous process. the defoliant mixture producedwithin a 24-hour period shall constitute a lot. When produced by a batch process, each batch shall constitute a lot. When the defoliant mixture cannot be identified with either of the above conditions. all defoliant mixture offered for acceptance at one time shall constitute a lot. 4. 4 Sampling. MIL- 4.4.1 For Examination. Sampling shall be conducted in accord- ance with 4.4. 2 For Test. Sample containers shall be taken at random from each lot as follows: Lot?Size Sample Size 1 Container - 1 2?275 Containers . . 2 276-545 Containers i" 3 The sample size for lots exceeding 545 55-gallon drums shall be determined by multiplying the number of containers in the Specific lot by 0. 015. The number resulting. l. 5 percent of the number of containers. represents the number of sample containers which should be taken at random for examination. 4. 5 In5pection Provisions. 4.5.1 For Examination. The preparation for delivery shall be examined in accordance with the classification of defects and MIL- 105. 4.5. 2 For Test. Two separate. 250- ml samples shall be re-- moved from each sample Container and placed in a clean. dry- container labeled to identify the lot and the container from uhich it was removed. Each sample shall be tested as specified in'4. 6. 4. 5. 3 Classification o?Defects. 4.5.3.1 Preparation for Delivery (Section 5). Categories Defects Acceptance Standard Critical: blone defined Major: I ADL l. 0 percent defective lOl Container closure incorrect .102 Mar?king?in?correct or illegible -. - 5' - I l- ?un. (3"?f350 4.6 Tests. Tests shall be conducted as follows: -. 4.6.1 Composition. .yw- 4.6.1.1 Method. This method is based upon infrared absorption at 12.5 microns (800 cm for the 2, 4- ester and 8.8 microns (1135 cm for the 2, 4, 5- ester. Both absorpticn bands are 'associated with the substitution on the aromatic ring. ?"W?jl?v Known mixtures of the and 2.4, 5-1? ref: rence standard esters are used to calibrate the spectrophotometer. This isgdone because a base?line shift is noted when the two components are mixed. 4.6.1.2 Apparatus. 1E (1) Infrared Spectrophotometer Becizman IR-4. or equivalent. . (2) Absorption cells, sealed. 0.1 mm. light path. with I a sodium chloride (NaCl) windows. Two are required. 4. 6.1. 3 Reaeents. Carbon disulfide (c521. 'Acs Reagent Grade or Spectre-Grade. .. ill I 4. 6.1. 4 Reference Standards. 1' (1) n-butyl ester. Federal Reference Grade. (Z) n-butyl 2.4. 5-T ester, Federal Reference Grade. . 4. 6.1. 5 Calibration of IR Spectrophotometer. 1'5: Weighaccurately sufficient amounts-of each reference standard ester into lOoml volumetric flasks to give the following known mixtures: EStcr 2l4l 0- 45 0.55 3. gig0.45 3. ?h :TJI'Trfxi {u A supply of each of the Federal Reference Standard esters may be obtained upon request directed to the Contracting: Officer. 6 . Cn' It.? ?11" 1 .. $21. 390 in}? i a i - (his ht MIL- Add carbon disulfide to the mark, stopper and mix care- full . Avoid loss of CS by improPer closure exPansion by heat from handling. 4.6.1.5.1Ca1ibration'for Ester. Using a pair of 0,1 mm. NaCl sealed cells, obtain the Spectrum of each of the known-i mixtures from 13. 5 microns (742 cm. to 11. 5 microns (870 cm. - versus (C52 contained in the reference beam of the spectrophotometer using standard instrument conditions. Determine the absorbanceAA** {or each of the known mixtures by drawing a tangent baseline from 12. 75 microns (785 cm. to 12. 30 microns (815 cm. and measuring the difference in absorbance from the baseline to the maximum at 12. 55 microns (800 if . Plot a calibration curve of these values for the AA versus the mg. lml. of the 2. 4-D ester in each known mixture. ?4.6.1.5.2 Calibration for 2, 4. 5-1? Ester. Using the same pair or sealed NaCl cells, obtain the Spectrum from 9. 5 microns (1050 cm. to 8 'microns (1250 cm. for each known mixture versus an approxi- . mately 48 to 50 mg. lml. solution of reference standard ester in C52 in the photometer reference beam usingstandard instrument conditions. r? o; u. -- 1 sir?'? ll Determine the absorbance A A for each of the known mixtures as follows: - - - .1 gay ?am-uh?) 4.5? I (113s cm.'1) A8.65/a. (1160 cum-1) u. a where A8. 8 is the observed absorbance for the C52 3 solution of the known mixture at 8.8 microns . ii and A8. 65 .. is the observed absorbance of the same solution at 8. 65 microns. Plot a calibration curve of the values for AA versus the mg. Iml. of 2.4. S-T ester in each of the known mixtures. Figure 1, (4.6.1. 5. 3) illustrates the infrared spectrum of atypical sample of "Orange. amt: Figure 2. (4. 6. l. 5.4) illustrates typical calibration curves I. . LICFIIDDL JIHIFIF . - ...lnu - . -..- F.-. . . . - .F: ..-.. - -.- -. .F - . . . IWII I .m II I MIMI . I I . IIQ.I.II II.I00 I mo?m.? .mll IIu?ul - . II I I .-I.I..-F-.. -.-..FIIFII-.. . I I. Hannah-HEN. -JH..IHWL. - ..- I -..-.-.- .- .- . T.- ..-. .- . - - . IHIIluIII.u.l II.- ul IHII I I .I I II I -.T.. .. .-F. . -I..I - JIM-F- .- -.-: . .. . .. F. . . . -..I .. .I .. .. -.FILII. .II IIPII II . IMII hllm-Ilgr. -1- - -..I-..-. .. .- F--. W1 . ...-I. ..-I. .-.. LII.-L. . . . FF..- . . -- IthIIl ..T w- . mud-HF.? .-.. - I..-.F- --.-I..- - ..-- -- - .-.--.L..- -.TTF-.. -..--..-.--..-.-. -- ..I .1 F--F- -.. - . -- . ..I.-- . -.. ..-- - - F.-. - . I..- . - . - -.. .-.F- ml -mn. HUN. --FLI .. I 1T.I.I-- I.IIF- .-..-.-..F.IF--F-. rim-L.-. .-.-1.17...II.I. I. Id luII . . -FLL- .- -. --.-LIFLI -.F- .-.-F_Ilhlull? IIHII I II IIHDII --.. -..-II.Fm. . . -..-3..-: - . -- .. I .. II .I II1-.--.21.-.- M- .. 1 --F. T. .-..-.FFI..FF.-.. F. .-- F- -..- -.--..-I..- -. M- . -. I- --.. H- . . .H nwm?nHU- . 1.. . --.. . - .-.-I..- MW-.F- -.F nil-?HM? - F.- .-.-F w. . HHUU MAL H0.5388 . . .. T. .. -. m. . owcmuo . .. . I ..- . . . -FIF ..Ho ..:fpooam. ?our-Can . . . . -.-. ..- . . I F- . .-.. .. IWLI . - . .F.FI ..-..F-Fsumm& 00II..I-.. I I .I I ..IIrunI.. ..I. .I I.I I.I..I.I.I I..I-. I..-...-- ..-. .. . I.I..-. . -. I . - .-. ..- ..I. .9Ill. I.II . . I .- II. ..II I..I. u.ull .HII ..IIIIHII. .uI.II I. IIIII.I.I..III. I.I.II I ..I I I I..I I I I I. I .Inlh. I I.I .I.I...I I.I.I I. .II.. II-I. . II.I I.I.I I LII. I ..I. - I.I.I.le'blum..II.I I-II . I I I .NInIunI.III..III.I II. ImlI I.II.I I ..II I. I II I.I-.I?l. .II-I ..I.. "InllulIII.II II I II ININI I. .II.umum .I.. . I. I II. .II I.I.I .II I.. ?inII II. .I. II Im ?Ialuid I.II.N.IHIH I.II.IIIIHI II I.II..II....I. .. .. .II.I. I..MIJII I I I. T. I. .. mil. .I. lIIh IILIIIIJI .I.-..I..II.II.I..I001.ImImId. I ..I HI .I I. .-.. .I .I. .I- .u ..lI ..I- .lull I . .II II..I.. ...I11?" I ..L 14!. .. . TIIC . ..I.U I. . ..I/nl Il....I. I.l..l I'l?lluI.II-I.LL.II..II.. . . .I..-. I .. .-.-II. I.. . ..I- ....I .IMII . I .II I.I-II II I.II....I.I. .I I. II..I.I.'03 NJDILJIO I I . .I. .. I..-.. . . .I-.I. .I.III.I.II.I-II..I.II.I. I II. I.I . I.I. I.II..: aruw?omon. .ucauo-.-; II II II.I. JNCVI KHIIL .II-H.uanhh:..:- .I ..I-..I.a..mImMm. ?an. I ..I I II I.IINI. cam . ol??i'J?er 4. 6.1. 6 Procedure for "Orange"- The procedures outlined in 4. 6.1. 6.1 and 4. 6.1. 6. 2 should be applied in duplicate to the sample of Orange. 4. 6.1. 6.1 Ester Content. Weigh accurately a sufficient amount of the Orange defoliant to give a solution that contains 100 mg. Iml. (1. 0 g. in 10 ml.) in carbon disulfidc. Obtain'the Spectrum of this 'solution from 13.5 to 11. 5 microns using the same NaCl cells and instrument conditions as outlined under 4.6.1. 5.1 and 4. 6.1. 5. 2. Calculate the A A for the ester in the same manner as described under 4. 6.1. 5. 1. Using the values of AA obscured. read the corre5ponding amount of mg. Iml. of ester present in the Orange solution from the 2.4-D calibration curVe. Calculations: rng. Irnl. of 2.4-D ester found x100 70 2.443 Ester in, Orange mg. Imi. ?Orange in sample sol. .. .- -I In-? Where trig/ml. of ester found v'alueread frorn' calibration curve. . 5 4.6.1. 6. 2 2. 4. Ester Content. Prepare a comoensating solution of the ester reference standard containing from 45 to 50 mg.'lm1. . in carbon disulfide. approximately equal to the concentration of 5 ester calculated to be present in the Orange test solution. Obtain the spectrum of the sample solution of Orange from 9. 5 microns to 3. 0 microns versus the prepared compensating solution of ester in the reference beam. using the same NaCl sealed cells and instrument conditions as outlined under 4. 6.1. 5.1 and 4.6.1.5.2. Calculate the AA for the 2.4. S-T?ester in the same manner as described under 4. 6.1. 5. 2. Using the observed AA value. read the corre5ponding value of mg. Iml. of 2.4. ester from the calibration chart. .- . g'uljv'. -v Jaw-.uric.) Calculations: mg. lrnl. of 2,4. S-T ester found 100 a I 2.4.5-T - mg. Iml. Orange in sample sol. in Orangiter where mg. Iml. of 2.4. S-T ester found value read from the calibration curve. 4. 6. l. 7 Precision of ?viethod. The? .5,c cont?. dance level for a - single determination by this method' is i 1.8% for each ester; for the average or duplicate analyses the 95?? 0 Confidence level would be 1' 1.3.0. 4. 6. 2 . Free Acid. Determine the free mineral acid and total free acid present in the deioliant using the apparatus and procedure for strong acids specified in ASTM Standard Test Method D-664 or any other standard method. using grade isopropyl alcohol or USP ethyl alcohol as the solvent and 0. 33 sodium hydroxide as the titrant. . Titrate first to a pH of 3.5 and record the volume (V) of - alkali used. Then continue the titration to pl?I 7.5 and record the total volume (VI) of alkali- used.- Calculate the percent free mineral acid and the percent total {nee acid using the formula: - f5 - - A1: 22.10 A2522where A1 is the percent free mineral acid (calculated Acid) A2 is the percent total free acid (calculated, as 2. 4-D Acid) is milliliters milliliters normality of NaOl?i solution ?i is weight in grams of sample taken for the test. 22.10 is the appropriate factor of the molecular weight of 2.4-D Acid. . {at 33? WW In- r35; hi . I I I MIL- I 4, 6_ 3 . Specific Gravity. Determine the Specific gravity of the Egg: sample by means of a suitable hydrometcr. pycmometer or other standard g} procedure which is accurate to four significant figures. Perform the . ?3 test after cooling or warming the sample?to g? a 4. 6.4 Undissolved Matter. Dissolve 10 parts of the sample by - i volume in 40 parts of reagent grade benzene (C6146). Thoroughly a! agitate or stir the mixture and visually examine the solution for evidence of undissolved matter. 00h" 4. 6. 5 Moisture Content. Determine the moisture content of the sample in accordance with ASTM Standard Test Method s43 or any other standard Karl Fischer method, using methanol as the solvent. PREPARATION FOR DELIVERY Packing. 5. 1:1 Level A (surface tran5portable only). The mixture shall be packedin a SS-gallon drum conforming to type 11 of Drums shall not affect not be affected?by the material contained. . 5.1. Level A (air transportable). 'The mixture "shall be packed .- in a SS-gallon drum conforming to ICC 17C r'equirements. Interior and - exterior surface preparation and finish shall be as Specified in Drums shall not affect nor be affected by the material co:.cained.- . . . . 5.1. 3 Level C. Fifty-five gallons of mixture shall be packed in a manner to insure carrier acceptance and safe delivery at destina- Containers shall be in accordance with Uniform Freight - 5 9S0 tion. Classification Ratings, Rules. and Regulations. or regulations of other carriers applicable to the mode of transportation. Drums shall not affect nor be affected by the material contained. . 3E THEY . .- . LEAKED 5.2 Marking. Bach'drum shall be marked in accordance with ?15. instructions from the appropriate government agency plus one orange SONGS band. approximately three inches wide. encircling the drum at the center Lidiaig'r line (between the rolling hoops). The orange color used shall match as closely as possible No. 32246 of Fed-Std-595. as .1 til 5. 3 Identification Marking. Each drum shall be marked as A specified in 5. 2 and in addition-shall include the manufacturerbatch number"'Jr .I-we' Ju .- 6, NOTES . 5 I 6.1 Ordering, Data. Procurement documents should specify -the following: Title, number and date-of this specification. Level of packing required. Whether air transportable drums are required (see 5.1). . Preproduction requirements (when rcq' ired). 1. Quantity required - 2. Time allowed for submission of samples for Government test and evaluation after award of contract. 3. - Name and address of test facility when testing is performed by the Government. 7 4, ,Shipping instructions when-applicable. I 5. Time required for the Government to notify '3 the supplier whether or not to proceed ?lth production. . 6.2 Batch. A batch is defined as that quantity of material which has been manufactured by some unit chemical process or subjected to some physical mixing operation intended to make the final. product substantially uniform. 6. 3 Information. Nieterial otherwise meeting the speci?ca- tions set forth herein for "Orange" will exhibit the following character? istics. approximately: . Flash Point: The flash point as determined by the Tagliabue Open Cup Method lies above since no ?ashing occurs up to and including this temperature. 11 I'm 33?? -. we - MIL- Freezing Point: Orange will tend to freeze below -260F. when permitted to stand at that temperature for several days. Seeding or agitation at this temperature will speed up the relatively slow process of Viscosity: The viscosity in centipoise of Orange has the approximate values at the temperatures given: - 4.0 cp.: - 2.9 Cp.: 2.5 cp. This information is deemed useful in consideration of use and handling of the material. 6.4 Precaution. IMPORTANT. For procurement of herbicide for use on lands owned by, or otherwise managed as military installations, use Federal Specification 0-H-200. jefoliant procured .by this specification must not be diverted to domestic use. ?m CUSTODIAN: PREPARING ACTIVITY: Project'No. 1380- 12 nun- g- . - nu-?I h-I'lc. m?sv?y?r . ntI-O?-p?I-nm-u-u? ?Il? . I I . ?t?izi . - - MO?b-raillDeule-nrd 5 5 .leui .M.sseuri 63255 tam 01mg 4-1090 3 . t3 . - f0 nai4?\ t? 7 January JO, 19aJ 49", -c.b Col. Edward C. Bartlett, USAF Director, Procurement and Production Defense Supply Agency Defense General Supply Center. Richmond, Virginia . as: RFP Dsn-hoo-68?3-3785 dated 22 December 1967; proposal q: Monsanto Compan1;in response thereto dated 15 January 1963; Monsanto company dated January 19, 1958 and DQSC teletype received January an, 1958. - Dear Colonel Bartlett: . -- - Q?s: - -- . I This letter will detail'the clarifications requested by ydu in referenced DGSC wire with respect to Paragraphs and u.1.1 or ASPID Geno-1 dated 7 November 1967. a I. ?t PURCHASE DESCRIPTION 0? ORANGE FSC 681:0"~ Requirements . - 3.1.1 - esters is on an ac eauivaience as.s--na .3 5e'Io?er'ana should be agreed-to by Monsanto. ZThe specification states that purity of N-Butyl _;cation shall be_98.0? minimum by weight. Assuming ?assay on an acid equivalence basis is intended, this?limit should be stated as 97.65 minimum because the original specifi? cation gave total acid equi?alence as 80-82; 100 a 92:should be clear that Quritx of the N-Butvl if E?e Iatter, .13. I .11.: .- .3 R??l 1'7 - 31? . mam-.15. Io-Ir 72115;] 2?61. 11 31.1%; aha 3% {?33 '1 Col. Eduard J. Bartlett January 30, 19$? b. Purity of 99.03 minimum acid equivalence basis is not correct. MEL-??51lh74Providcs acid and 78 85 100 97.5% minimum. In addition, under of this same paragraph 3.1.1 it is stated that acid equivalence shall be not less than 79.93 nor more than 80.0?. This percentage range is impractical because 79.76% is theoretical: The 79.95 figure may represent a typographical error; the Defense Department may have intended 79.0-80.05. Although the 79.0-30.0? range differs from we can accept Then 70 100 93.755 E6 minimum assay acid equivalence basis. 3.2 Finished Mixture (Orange) 3 2.2 - Free Acid The specification provides that the maximum free acid calculated as 2,h-D acid be dropped to 0.5% by weight. This requirement will lengthen the manufacturing process, resultingfin?lewer:prod??tton. '"The limit should be 1.0? mafimum. If the 0.55 figure was intended to reduce corrosion, there e111 be no difference in corrosign_to 'aircraft when spraying Orange containing or 0.55 free (weak- one on record as objecting to reducing the acid equivalence of ester to 0.5% max. and- the acid?equivalence of finished Orange to 0.5% max._ The max..lim1t does not allow for any hydrolysis during storage and H. Quality Assurance Provisions h.l.1 Composition I There is not enough detail here. wegagree_t?_assay by IR_or the?spectephotometer or equivalent equipment are not given. In addition, the acceptability limits by instrumentation for the two esters are not stated. ,We propose that limits for these two esters not be absolute, but be stated as follows: (1) True, technical Butyl 2,h-D ester by inatrumentation range hS-hg?; - (2) True Butyl 2,u,5-T ester range or the assay limits of the two esters could be stated on a technical basis, either percent by weight or percent by volume. The attached correspondence between C. H. Russell, Monsanto a?esser, U. S. sleiogieaj:paboratory, ?hrt_Detriegi_?azyl?pd, will help clarify instrumental assay limits of Orange. The attachments are C. H. Russell's letters ?t 10?? as .. . .. . I .Ia .-.-.. .121. am. @3me .WMWM. an. Iin?m-II. . I f? . M. In. .It. ..If - .. 1-3.13.4.-.. .. .Mm?? . .. I. n.gkw.%na .. . .. 3.4.. ruff . . - . .. ..- I 0.5.1.9.. amuIerr?nnvL. . . . 41:11 .I . Rru..- ..- .. (?Vikkw?ht .3451. ..uquI. .. ..am In. ..MHVI . - 31?? 1.1.1.3. ..-.U. -.lduwiwumu?. . -- - I 83.5fm .. . - . ..mhumrun?ig? r3335? in?nium531..u3uuonu.hnr4dn?.w..1a?s. - 111113.131. PJIHM .- . .. . . . - .. - . . . . - . .. . . Iuh . .II .I. . .IJI. I 31.514?II."lI1lluI 11.wa .34.. 3.0 \lLuL I Ill. .. .. . I) Hahn..@3531 ?Inirl?. - tyf?ll I I . r.Ill. .. ?Lr3.3{vim?m?m?ummw?m??n . II..A. ?giflaw-Yh..InWHILE\I1..J. .W?Muhuuhuluqhh?wh . i 5.. . ??nrul . .- .O. BID N0. Changes necessary to pczait compliance 0? praduct under specifications for: HERBICIDE - ORANGE Page 5L_Item 1.1.1; paraeraph a. After the word "weight?, add assay may be performed by aaponification-back Pace 6, Item b. Change the last line to read not be less than 72.01 nor more than 50.01 and assay may be performed by aaponification-back Pace 7J_Item Viscosity. technical esters and nothing can be done to control viscosity. hwEliminate cowpletely. The product is a_mixture nge 7. Item 3.7.1: Total Acid Ecuivalcnt (:15 2.4.0 Acid). rChange "91.01 minimum by height" to read minimum by submitted to The Due Chemical Company For review, was reissued under date of June 10, 1967 with the above change.) Page 7J Item Composition. Eliminate completely. Infrared determination of comgoaition is not accegt??le 31nCe no definition of the sfana?raa to Be wave Ie t? tQTbe usea, ana t?e Iimlts oi acceptance Eg?n=agreed Eug?m. Page 71 Item Free Acid. Change ")11 alcohol? to read ethyl . l0? :ang' Attachment t1 Bid No. -h-!7Eh age Pave FL Item Pearcuts, paragreoh Eliminate entire paragraph and substitute ethyl, 951 neutral. Page 8 Item Pracedure In the firat paragraph, change ?)17 isopropyl alcohol? to read "-357. ethyl alcohol-w Page Item A. 1. 3 Viscosity1 Brorkfield method. Eliminate completely for the reasona ouI_lined under 3. 2. 3. Page 10. Eliminate completely as it is a duplication of Page 5. Page 1/41 PACKING Change the second sentence from "Each drum to contain 55 gallons of product.? to drum to contain 550 pounds of (This is the standard by which The Dow Chemical 93 all contracts In: orange to date. It 18 not keIt that the change to a would accomplish what is desired by the military. A .. . The Dow Chemical Company Midland, Michigan hB?bO 13: GR \lC) . i 1/19/68 w: ?x"wwa HI. 5 mn mung. ?7 v?r? 11!. -tv. . .. n? I'm-cue loo cud-Its..- Wilma?urn no. - it? a al'th I I. -.I man-unto I W-i'lnn'l h?rh c'r LU 3 L13 Has: 19er EEFLPL .- 5 '1 Int?u mvnonr- up I n-lu gal-l.? Dc. zit-I-o I .. J. - 1000 can?nu" - 2001] j? DtrI-rlul.ur u! Plutun -nl l?ruaut'uur 1" 3' ?In: RP. p? H. 1 a Gen-Ina: .Jpph Cane-u -. 0 7.11 '8 I Richmond Vulcm. 2.32:0 191d . (ma- rooa (on: a can.? no- iva-f nun-n ADC: mu r. . . v.30- Her:-1ee, Inc. hep-:tmem ?Hf-w 910 "um 9112138153, :3:an 19599 I -- wm.ul? con?? i .n Ogr-b?mH-A?rl 'su-e Sam-dun amtI i Ctric!, 0. 5:4 7HTE "?ux-13min, 11. 191.01 MAS-R $5351.01 ?mu-mun hum-Mum Flaunt- Ian-noel .. .. RANKE I. I no smgalmao 61 63 06 151 sol-30c WJ-jg' (ll/?g mar: .IHe-cu1e9.1n.. i Jacksonville. I isn?ms com. EMMA (51.03;- Ark. 7217 CW1 11.? 7Fvan! . I 1h? [EH-am) . - 5 qua I- you; o- co-ninn I Emu-lacun- noun-u- ll-a?u-u-VI?d-qv 'IIu?n- nm? h? td?boun can but! to". ?-mhm?h? "nan?am w? on. 0-mo? a" a w?v- .- .- Hub-- OLPLIEI BLOII- (II to 'o?rc; I I - then?I char-I I I, M9 CD 404'- "W'mo?l' Tl u" I mainly-urn?, I - I- M?Lw?u-vn- mob??nym?sump?wu?u?au a?nnh?nm?bh?Wh?nc?MPit-3a255- 1' inch .. v' I 3.: . #131" 1.1' .- 1.. I 13-? =muganh . 6ch h? h. .0.- u'u, u? I no a an: II-G #4115? To .. her-r? I -.-. m. counmnlou - I ti .. 4 (brag-up. HF 2r" -1- mn - gia'U-Jml', - er?lv?l - m. um: all" on: now-n 1, I I I I- nah-a.? . 'r . (5-.- I I . . I 15322112. urn. 11h: 1'13" 11:. -er {he :antnr'. :r em; 23? tel. Lh-- thereat', v.2 933122;:- thi?. a: "he ?21: . I I I I all gap; 12; :?zu-eizhe. thiz centred: 2. fro-e 1r. iezim, enter-1:1 or 'er'rzanestit en; 2-3.1 the ruin-.5 an." all ether requirements 01' thi: cantr-(ii) the presermtian, gating, en whim, 6.51 the ere-panti:n for and :et?ud 9f shipment :1 :ueh supplies 1.11.1 eenfzz': 'Ji??h the Rant-cents of this The Contracting Officer 21:11 ,3 written nadiCe to th hue-entice in party-am 31? this chum-.- via-.111 :ne yeah the contract. I - I ieter-Jmed in deem-innate vith the ncplieehle sen-411:2: ?xedmu except p5. herein. For sapling precedes, ?the supplies: ie'Liveg-ei under this centre-2t. The site at the! ample searing specified in the contract far the qudntity of -ectian Hun-ant? 52:211.; results my be ejected. c: uz; shipmerr: o?.her sepplie: centeinei in other animate geven tho are net" meent st the point of :?einepectim-z, . de: muomtiz .or_ she guamjremaqa?c?zwz' original 15:12:11.1: late use the use Let lize 15 an oasis-.1 iaepe?uicn. "i cite:- sic-tiee o: em breech c: uu-nntiee in pregnant: a: this herein, the Contracting Officer exercise one or o: the ?quire en equitable udaustaent in the . up; 41:7: screen the stezlies mine-i under- thi: ch21! I 3-5111) rent-ire the Cantnc?-Jr to sea-?er. tr" :ur?lie: the continental "nitc-I State: aft: gar-met :r magnet: i - I 3 return thu: :uprlir: .j-rzmo-a under tnir elnuro; to a! uni cometian or ?ninety-rm. 1 311?": ?tum, c'r-rr-ticu 3r the eon C?ztrectar or In: tr - last 1 I I . 4 13:12:91; e425! breech . I Contemee of uupplie: or part: thee-ear subject to arr-an: action shell be ined Ln?thq Otficer new. coup ?w 2311 be the: red-41:2: by purplien on vhidl: vars-ems! -r ,sanliee initbe see:- such 'Juppli :the euepues retaining u-e clause 0.3 uteri-.1364 liq-ring optima: at 3 pm: designte replace all no 6'9:sz (ii) at ntmetor's expanse ant. . return naneonfernim: :u;;.lies to the 1'31- carreetiop replacement: I t1; the mg cc:- stall I rhtur'. he sum-11?: an: an: sue-l: run-1:73: var-L124: in :heil be borne the anti-get ur-v-zr. tic. "intruder": list-111231! :?geh char-re an" at. "311. f' the 931? .:ue.1 Pure-c131 15' :hiyren'. 1-6-22?: t1. 3 . hurt-Jim. {an'r this - -v-ect the iszAT. 51.2! . . . @2er m3B2- bj.z;um adr- . .n . .. 3.44:. 25.1.2: . J. f. . 1ft, Mu . {4m um 3:14?: I-IJ- 1-4?1 Moo; .msiiInn? if its. 5 . . .343K35 r?E . . REQUEST FOR AND RESULTS OF TESTS 3' SECTION FOR TEST I i. ,SOKLftaildcr 83107 Deienoe Personnel Support Center R. G. Knott 2800 South EO?ch Street DCASR - Detroit Attn: Dir/Tech Opnc, Lab Div Room 31L, Federal Building Philadelphia 19101 E_y City, Michigan h?706 FHIHI CONTRACTOR AND ADOREII MANUFACTURING PLANT HAM: AND The ,Dow Chemical Company . The Dow Chemical Company Midland, Michigan Labuo Midland, Michigan comm r- 0 Human BSA-100 68- c- 6163 I. END ITIH ANCHOR PROJECT I. SAMPLE 7. LOT NO. .- ILAIOH FOR IUBHITTAQ 0. DATE Hun-cu urncn' Herbicide ("Orange") 30 73h828 Verification Testinng/29/~3 L4 IO- To It TIITLD IOI. IUI- ll. QUANTITY l2. IF-CC. AMEND. AHDIOR DRAWING HO. AND I HITTIO ILNTID j: It?l. 70H IAHPLI I DATK Same as 5. 1-8 oz Bottle _8200 gal per u. rune-nan: rnou on sonnet u. smchurl-Tc-?ricoo I u. out. wwanF-nn: Tang/I 1 Source P.P. lD/99/b8 0. ?nott QAA Ia. AHOIDR Irccuc??iiu?non: A?lb??'?uv 50-50 (by volume) or n-bu ?ll-D and 6 {Ci/t" 8 l7. BIND REPORT 0' 10 FQILED QCL. SECTION OF TEST I. uni-mu; a. on: 4.4L . it. 1771:4216 37 v" . 7mm? - 7?71. c; 2761.9?va Jon-ac?, (14.1.. . "67v? Mac 73:0 but Dr Fir-3cm" .5 icii -- . i/Gaor- -c k. ?auctf/PJU :2 NOV 03 D- . fIIf Huron-Act: 08 .1. DD 1222 human no ton-1 In.- I u?Isu II acumen: I ?3 . f? ?maximum incl-Joli.? I ?586 a mun?um? rum. - DEFENSE SUPPLY AGENCY DEFENSE GENERAL SUPPLY 23219 um: DSA hoo-65-0-6163, ma moso-a-losho ED: osmium-?gm (awn) uA?aG?? . mm. W. J. Eaton/q Kelly AFB, 13:13.3 782k]. 1. Attached. laboratcz'y test report 0-8221 indicates ham or 8200 gallons of herbicida to meat the blend. ratio. 2. Your car-zest: on acceptability ,or subject material is [Ha-27? 1 ?nal - - V. hm Cantracting Officer Directcrate at Mat and Man . 1708 :53 WE: i he.? (351? - I 3W Cutoujgmgiio? 68121 .110: cavity 20?no?c I Acid (By Height) 1 . 2 :_1.M1d BQuivalent 1. 2 (ll 2? 40) ;ht Gnllon 2 position I by vol: 2, 0-D A, 5-I-o The Don Coupa?Y_ OutcrISple Units Test Result! 1.289 0.0 (2) 93.67 10.74 49.1 44.6* 1.289 93.01 10.74 a9 .0 09.5 . 1.275 to 1.295 0.5 ?ax 90.0 min 90.0 max 10.70 1 0.00 20?c 50 1.5 50 1.5 '??EK-p?urtp I In . 21%; - .7 7138632 FOR comm 5mm Subject: Herbicides 1. 0n 8 Sep 1967. 01? __advised that. the Hercule; plant, Jacksonville, Arkansas. which produces Craig? HEfbicide, had __bea'n_ shut dam due to _a_qualit robin: CT was diciurbed since The shut daid? dawned on 29 iug were not advised until 8 Sap 1967. 2. Since we (OQT) had not heard of any problem, I contact? Hr. Burton (BSA) an 8 Sop 1967 to find out dataila or problem. The Iall?uing infor- mation was obtained: a. Mon 01? the Orange herbicides taken by inapecjgr touted at Failadalg laboratory showed producf 1391 to ELIMQHW b. BSA advised DGSC (Hr. Bills) of problem and 13630 undated the Jacksonville plant closed on 29 Aug 1962; four box caravan! to a Manet s-e W?i mum. 3. :15. Bumm an advice can today (11 Sup 1967) a: camctivo actions taken to assure delivery a: cpecuicaticn mteml. b.0105?. Beatty) was advised Sep 1967 of information obtained from Pk'?nmm 31:15:11an delay.? . a! - Mada: E. VW Chemist/021? can?u? q? -. ?uiiu can." u" .- . 3.. I Imim?h?mu I BQW 3 . I In". In'uJ-Id: I '3 auw IU ,AIizism-I? Sol! Foumulolion?Q?I?j-T Acid EquivoIcnI 40 'oun J-D- ?v THE SELECTIVE CONTIIOL OF BROAD-LEAVED WEEDS IN RICE h- u. on! . .r-O sunk u\ . - noun uh I ou-l- all .ul? funny Wu?! lulu-I vIl unnu- I II.- MEIER pu Sandra 4) I Fan-nu- Wad l-llou to ?0 uh I- I..ut hm. I and In noun-rd lo Oil.-.. - - - tfi? h" oI 13.54"] 119' ?n m' I-r will?. ?l mu". ?In-'2 Itrun-?II Inn-mun at". . . Inn I.I.I .. .n I. 0! gun" a . [Qua-Ind .0 rui?tnl Inch-0e (nn?uflm:mu 0: nun-I. I un h I ll: 14-! un 0' vol? . of ?uu?l! hon .4 [nu-um hon-gullmomI.Ilrl A-ul "nu-l out 5.. .1 mt.- - I mucrpan-u! II In "who um um II on"! "glam? Illa-I?I 6 I - 7h. Inn-oh. on ?In" I. nun-Io ul'uhdh, un-I-I In I ?noun on who urn-om. pun-uI-m-u'w I Ill I-ul Innml m- I luno-IhuI-u. Much Jullu u-u JI on l-Muul ?no. '0 ?Mu.Iqulf chqI[1th IOQMNJOII annual ell [1,5 I ham. WI hung ?wading"Uh-".mud Inn y-auu to noun?lm-l yl -ulfl In: In. dull. lI-, mu Imam-mung un ?All1?5" WWII ?lm-I'd lo nul Ilu' Hu- It II-llInn. and Inn". IN Inlet-u ul 0' gal?. mm ?gamma .. In?. I I I I . 0-.) I. . on. tun-cu u- pol-n] -l l. Apply DHHU IIU plan-ll-n lune. all . a noun a. In wudl on In] I'll Do In I CIDII Iml'?"huuh 9 ?nl-?g -dh ?duhany! I- II- uu-II0H. ulul-u- huh hurl-mt I ghmuI-I I I . I .. WIID IICEI 'uul I. I. n" D'v"'o I II 9-4 Ionian-ll] )2 . I II ll". IIqu but -Iulh u- I I ul-I-I In . unmq. Inn-on pun? an "no, ii ul?uu - . - .Fi" . I?m-n 13:? I .u I, mTIIE DOW IIEIVI ICAL PA ,qu i Km" ?Immune! 5 I ml I not. I Iu-l It'll-II II. -I In In. u'm?Nu uchilf.Ital-m MIDLAIVID DIVISIW Dunnmm" Imam, Inn-u- PI. A Inn? h. on I-04 in Folly. I hunch-l unnu- hum POI AI W?ll I'll? II nun-mm" HII ml. running til urn alum II Ind I-I II-Iuld mhuum um an In nu mm rhII'. In, II "murum ghoul II min'Ihu In[pun II In II munmull-1 . nun! II ull??l I II on Mmhip II-uw In? WI ml Irr- lulu II I Mull II II CI-II MI Manly, I II runI'll? II I ?Ilulm Ind um. mun mum-I. Ianbut" ul nun-II II nu Inn I ?In I'll". IIqul mint lullI'll, Iu 1mm, bu Ir-l II II lnllunn mluulln In"! Ilnl "mum. In mlul II hm. Imu an I II nun-InInna" II . I ?Hill "2"mm. I'll? mum udI I InI-Idutl lull I II II ?um mm In quII II II In an at I [Ilqu IIHII u-ml II mum. I-I mu I-II. ml I II I linoInlr Mul- 1-0! nu II Innm In an M. MSI ?Ir-l I 1 muMIMI I 1? mm Id will. I Il'In}! 23? f9? 1w! I?luI In. oI-wny, [own Iangoloml GD . HERCULES and Ior oIlm UNI. "raw . *5 IIEIHIICID LOW 4T ?1 . I I LHAIALJ CAUTION: READ [mm [Ann mn rnuzxuuonsIMa-nuhI-Ioonullt UK Io 4? IV. 1.1 5 MIJI II 52'. IOIAL loo um . . MADE BY I 1 :1 up!? CHEMICALS ICES DEPARTMENT HERCULES POWDER COMPANY I. up; Il?ll yquUII I. llu?l, "1mm?. I-Iml. (oIIu?. II IMII IuthIn-I. Iv ?mul- II IMI nun-ml nu, Mt". 1"qu Ia bomhuIl Ir pun?. mm! b- "mind In UN II (Mum I1 In (Ion pup-Inn? II Ium plInlI hold .I up", IpaI'. I-Mch II Ill-l1 II lrl?. plInII In. "pan from 1M pro-dud In" Inlu-I lhI mono quucllhu fun In ?lhI '1?me II In. Ipylluluon. 00 In, body rum I1 cIcI Iop?uhon. nun-r1 cl Iqulwan It II Md IMUIMII Inu- Imou?nu .I IN. In" IImp-aurlly 'H?l'l'lIfllUcl'I Ind HIM [to-MI. no no! am uh In Hint [In-no. Iuch II Ila". In IumpublI II IN Inumul Ind mu In monk: It gnu Ialq "huh In V-Inun I mu "pile-lion. DO NM (MI oral-Id mu harm?1. I-I-IJI, Inn-mm" oI 00 Innuud- Ind In Imdllu?l Du Ipug you Ipmod MmlmI-J IMI plodu? In: purpI-I MI DolmumanI Inomn hut "on IN IN I. It Indium-I II Wu". unluII In. Loan In! wry I wlqu dand- HUI Inf: no. Maid CAUTION 90qu In" lieu In? h- Mlh-I Ip-Iy mm Do noI In.- mnIIu II I nu. Iran. (Iolnln' "th Iyn um um um Ind prom? [no II rum II Mun" roan" in" II and unlm In", Iona-luau om which tnI-wlInuIIl no (onllol, In no nnI lull- .Ib-uly II IMI pvmlan In Ilon lmI pvt-Ian I. um .lIlmI-I noun or and In": II ImnIIh-Illy IOI Inn at tun-I0 Ill. Ind an Inl. alodu'l hhlull' ?Io-Inn? mm dll-?lonll a nu. -- .HI I. In- ?Mud ennui-II Iv- - - 3:Ill?. .. .. . aI-Iuoo frInch Ia U.n.n. "01187 7 . .. din. I.i tuck LII.- lord?oh. L1 'Ihl null. I-Iov r- 9-H 1% . . . In? IWNHMil IIHLhI-yh-n-Iy?c?k AIR: I. Ill-I I-un "In 1010 II mum-I I..- m- In hen can.? hum-m- o-w-Hl loan and val Irv-a MIMI I-?-Iol Incl-?hug cur-rt Inn on In." hue" and mII-or-n II I. In puma": dl rm- r-d Irv-h mm"! In?! In cum nId-u In?. huh, ha-vNII and II-n'u IMI-I thirst-'1. hon-hon! Nlimyl Noun-Ins?, rm on!" In out, tow-m Inn \on'hql a? Ira-d g-no-ol In? I.-. unto-II 01 one: wohot to "I'll! l? Iva-I-g- -I own-MI on MI I. IN in" lIth 30 3" p'IInnr It'd llr-nlly mg. .I IN only .1 .II In." ININ.I ll InInqu-II. 1" -I --I. IN lull" U. I) nag. I I00 I. \0 Inn-n on "vl?lm . Inl-Ilmn nulh I IN urn-nu on Ila-(luv. I?u'l'?lhl '0 ..II out W. 0 .ll' to Tl- ml II an" Inhlumonhl II am" AND MILLER ICon1-.al 1an 4. 9'3 found: For Gallon Ol 'llII lluiyl Tolal Add Equlvalcnl 0 PoundI Pu Gallon For 1930 Control ol Mall EIaod-Lcnvad Annual and Many Woody and llubaceom t-IlIIol-?o {noun 'Iopwlo. and all II Il- ?log-I, In: ha. lo u In Ir". Inwlv In" dam-m3 Inm- mI-h Ion-n an" mpg-run Isl-on. Mgalqw?-I IN I lug \wIIh run! oln- IM- mo". mg.? no I. no I'll-I Ila? run-Mu ?In! HI. II Ol?h 3-?qu u) I. M0 lull ?I'l'o'rl Mala n- l'-l Inner I IcnoI I- Isl-Io mm may I. gun-"I I. au-IIr-nnl. In my .nI Idea I. In! Dun can own by .llp?" ll Imlm at ?hi! I ImugI-hlo (Inn IAIK ?unk ng won? II. 0.. hem! pun-H In JI ?on? n ~l I. . .l I It? gnawI'll-h lull" ?0 In .nl'mn gun. la 1 an"! all nil OI 3. 1?4' I. 'I'Igold My W-IP- lulmq upon" ?only? 9' .. Ill"! on-uol ml n. H: ?0 - I4 Innu- mm In I- It l-"our. pull-?huh Uni In". Ira. ugly-n- un Ila. II nollnutla on ya.? I-cuh ?lIb. 3'!!le [II-lune. duh-pull In on. II-I uni-n Inn-u Ulla-I chimed Huron. and \llIn' (on IIVII II hauls-l hum II ml Iul . round I In. In! lawn-In. s. I'ma Io o-o-n-l on?! "-01 4' IIll I .l'l ?Iql In! on lain l-I-lmu. I luvWk"! Iqolh I. Iran ?-nq 6 lo I loql'lullI Jul '1 Ilwp? n-?I 'Id-o I. .l 4 ..30 Q. II nl In Ipll-yul ff (Incl ?Inch-gm. unponl Dub, ?Hand .0 Ir" IN-uuql-l nun-I Ipl?'ll' Ion- .n-pl Inc. I OH a. math but It" I I "Inn hull An I . "ml. Au .1, "In ..WumImeshM-IMW ILL-H 1.511ij .- - ul- LA I - -- Akb- ?ll] 5?mg>@ WAIHINOI 00 MI I'll? 30-50 d'cn?r II, .- ?hl'vlu Donn" II I. name Inlo (?\Inu lulh ?grief-In llo-v-I lIul' pm. Inn-'5'. Incl count-I. I. LI 0 .I-d and MI run-II Inn-y {pug-mu. I. an" .nl. I-nu Inn Inwulc 0! In. new, may cow Ion-a lulu] dunnin NIH rah-Inc and dame-I '41de Koon- we I .c In. II dull Auo-i-nalg In. I. Iii-U .0 II I. line I. In halo-d luv-II In. trr?lml r-o' I-lwu ?gnaw-tn. "my, pal (narrow-luau Illnv?llm .. .. mm"! nul n1!" ludl Il?lr Man nun-c amour-ls of LC I. Igule-olohl' "In o- plor-I haun- ?-l?cully II "Whammy mun-v .qu run" u?a-f IN. run-Ml ruff-Maul .l-Iwnl run l1 ?on lot n, nu"! In, II up agricullual II-I r1 term-MI would be uu. lo- homllh' 5. I. viollullon II \u-I and walk-uh If II ?In Io Hall I (II-null o'Ilnilull our-l .l .l.ll.n In MAT CAUH SKIN Avnll Coll." "Ila oI CloIl-lu' no acum-Iv Il nn. Had a In! "ha p-adul Inn" all II uu out-Mm. In?. .- not M. IN Harv-at - t?I >8 WUQ 'Waummumumymu t?lwIMi-.udu'n'n' lu-o I'qlulm' II. gum-Ir lg lu?hII uul gl- Inl NC 1190."! I. 1? can I- I "will man". In In unho- .Il??l .- Imw- '20I?ll [elu- In" 'If'l and! 0 ?nal Int I. um- It"; In I In? MIIl-Ilr-r'l II Mun-mu! luou- I'm COMFAEJY .o lm .I qu loll" Iumh can be wand mo I ?0 MIDLAND MICHIGAN 0 th OF um. Maul but - "calm-I? II Iw-l In 'ullm-II cl 01 II MN: v-Iv r'i AlkLg-?l Innulaotutad. mmcem 2-) has not Mnuluctutod or whipped alnra 1910. - atlclora aa abovn on tha tolleulng Veto attached to the product. the label Ia undo: tavlrlon [or ll Ind vhan the product la again a In 1?10 [3009883 VJLIUD HOMER :uhl-lt' [at Canal a' h'ao'al. l1. Valal?ih' him a! 1.. II. 1.1.3.1 to!? At? Ian-kahuna 1 Vocal. p" Galina '03 0' Of AND Til", AND Ina-01v?! .LhaW-?a Add. In?- lava 3? Add. Mil-u ?ml Inn! Irk- taoq Olitnloo Mani?Iain Lunmumu am IUJ-N and [ilk Book-lulu Na. IIOJII 3101'". Yul?I I-I a" glad-m hw? pan-av. blow ad an 5-H. I cub?a; u- WM In? ?rm-0g 94 along chub a; II I. a?'u?a?a In nun-Ian. Hun-y a'l new and bark tau-u ma, ?0 I- uh auq hut-Inna aim, awn. Incl. hawk", an: Hal. ?lo-dun alto, alt-hwy. ?a Who-q. Iowa-Alia. baud. H. MW. Inn-hos a?cal ?aw-mo-U? ?In. Yup-n la 9-. Ina-lac than0-. Ion-ta Mia-a and l. I. by. w. AVOID [0110' IOOVI DIHCYIDNI IIVIH [all Inch an) r?al ha" a-dra'laJ Wh- ~ldw?wo?kudw. In U.I.LLVISIDHS an (11 women or nun-tumult! rm "Delmar cm! {lole' women or ILCIHIMIOI no. axn lAttlen, \53 3L (I) tiw'ct luau-durum "lu?vhal?-arwdlu radium?mu. Ivan-Aha. MM ?an-aaodhn-?u-ha-nuu ao-mm an! noun". hm we. a-u-h hm "a In Idle" M1 Jun?! loo-u car-a maul l-a-a .1 air-a and In .1 9' It hood: all vow-u! ans-v5 ca HI NH nth-H wot-u wk ?an?nun auaahu and ?nal. a'u-a tr? on to "Mo-cl urn-l so! unav- at. rd m-Ma U-a 1h DIM-ail! $901.. Howl-no. Inch-kn ado"! nutmm. ro-? haw?autu- I In! cal, and "an Io eh 'jo'ba0'1fml" QJh-a II aha an Ign'hnal al Hill A 04. at lava-arc nu! WNW. ?unk can-n non-\ galalaw! an', hi at av Had Maud-h glint-q In IN ?and '1 null-rd mm- corona Lad. ml Ina-Jung M1 to NH 1m .l-cana "In. anal numb-q .- Im-o'l a II. 1" la Ina-Hulda. O?l .0 tin-fa Lat now-n an? "an M. Apt-H a! 0?1 tau-?u. uh uh?. owe-a; pun-?I, 9a MM-aa amt-n ohm?u .- gnu?m ?nal-u .- ?v?al unnum- l- can, out. a that we. .- mr MM?aInaN'hhM 'I-Ilol?m . WAINIHO cog-nun. I?D-van. your, that nun-v- omega-M phr- ?Huh'mvdW'wh-h comma-7min!- ohunydcum rw-mhm Hon-Hr- chum-malanLG-l NWWmI-uhnqu?RMI-Mua?w Mara-H "ha-My an!? awn-l rouMMm-nluudlww Dania-I'M. HwhoI-Muwu Ont-Moll: aura-nu DO n! "are Cantu-x, and a- lr-fa'h T. *0 F. 0' Hlm'l? . MUTECU MAY Ava? Conical Ina, I?ll! an] Chills. KEEP OUT REACH OF ILDIIH Incl-u Ia how-u OH hon-a "nan. wd?oanhl Mmdo?dwvw?Mhm?h 0.1? Pvt-la H. Lilli". IJIIJII '4 1.14] mu Dov: comm? MIDLAND 999st [?1.00 ?ow. .- .h-oa-l?a-gq-u?n. . (J Mu Micah: luau-ram 0' I, l- BEWI polo?! um .. .. II ?in?rm-duke It? 0' I: I I?lrllIw-omvroulh II I.- (II '3 h" Wm.? II l" n? AIM. I'dvd?nh In? .. - Io 5 ?cl hut. so n- I II. (.4. I A Io'hh-lhn Mo IIUIH Hull 3. "(waded luv no In gov-halting Lube- and coed, plank .Io-ohn' In 0' In". Ionhoud road. u. ondoidu cod luduhlol II a?oulvo on we}! (in 0: upon .In hood and ?Inuolmg mai- Mel?, ull Vioginiu (Hopi! Hadbouy humped? .ol uild clung uldovbonf luvgl Dung. mot-go '5ch poilon Ivy on non, wood, and Inbouovl allo-od lo "and oh" uniting II ?In! I). agilo'ud one?! INN-O .9 cill an! ani- and I'Hw'd no! In 1 H.-. bowl Ipmn II in no! veto-mOnJvJ Ion "Ionic. . lop woody gun-INIn" uh" 'orl'lqo I. will ?Input van-g a Jun-duh" "In" (unit-mine; I cl VION p" 100 gallon. bu!" Cov'lnq' would In Io? and all pad. 0' IM plea". Includin' II 1 . ZPLACES LABEL TUHIUMIY. mcwotu In ("mum to :vlsco. 'oncu owns" NI NONI: mo ucnumou ADDED. HI 33 hm. . .. RESTRICTION OH ADDED. on BUSH WLLE "In? and In", Ikould In lIuroo'My IN "Hey "who own", .m In hon nodt "on all" IlI-ouiuw- lollo dual-Mal In Ike Iptln' Ion 0".th llnlul no, ouull duolh' (In, coolhgt. Undo! 'oo-J [Io-win. coo-Jilin?, In Ion-h! one". mod. up to CM.- -ooh Balm. In" hill at. Illulln. [Appllu?lon lolo nun-n" and {all In an. mom. 'ndvl??' and (Klein-o. II Inna-dad] Spvuyl-q Ion" In! "uh atom-cl gun-v calm and cl.? nor Ml .Iro (onlvol. lap-o! appliqu- Ilo-u no; he In M. gro-lh (lo-clog: PRICAUHONI Do we! apply IIUSH l?lil (finally lo, omen-5n pom-H II I. (am. late unlau wilh nq?oblu. Ila-cu. quip". huh "on. omoaontoh. lol'on all". duholnio p'nnll which on. "niilioo no! pun" ""07 tonIuInSn' II I. dull! gala ?mm. ?at-"oval! mmulo qounlillog .I IIuv ?no, mny? can" Inlay [Coau- "Hon on In. um, I. (hill I Auoldinglf, appHmIlonl by ?ltplunc, ground ?91 and hand Jim-mun than? mules! 00' Only uh"! "it" no hula"! lam dd". 0. Incl qonlonh?nn dud." an!" und damn"! pulrl'HlI Do NH ?on now hulliun H'Odl. bunk-doc or lung; (Moo (undo. anew-II 0' I I I Acid and I I D- NH In Ila. loll moi lc?nuo-ily Inhibit loud conduct-on p'nnl gto-IH Inouu 0 Ike "icvliy vl Ike-ouohl' donning ?Hay". and gnu" hill. 1,1,5! Bad 1.. Immu'uHOnII MRI In?pmnl lkoo'cl Hal Mod '00 hond'in' applying n'nltullucpl duos-?ush Ship- ping natal-cu Ilw-ld no! ?u to uni In any mloclol which -m be uppilod '0 Julcouc regal-flan, ?65. NOTICE - ?an'l 1-) -comnou~ MANY snow: or men. nnuan AND ?nnono'LEAvm In 1w. Ikul no and uni?ed. cl "a 0' product 1.1.1 Involulionu, Conny" your ogllc-?lwol Ugo-1 of equal In tin-bl. VIOH IIUIH HUI. llpoul I. "Hrocli?j may uni-"In. Shodd ?no, 'toduoll' I. IN.- lumpqroluu and uh bolt-O rill]. 00 MI no Jinn .0 Inca ?nduow-o?u?mgmmamu :iu. 4/ OUT 0? REACH OF CHHDEEN CAUSES 0' SKIN AND Do No! OII In [you Avoid Conn-Id Kiln and In (on 0' "man .an. IE. -HJ Huh "n .lih Plonl' no!" for 0' ho" II bin-la. nnr? gol l?lJ-co' and. ?in ?Elk loop plenty 0 uolu. Iona-o and bollrl I. D. no! S'Ill 0v. 0' .I ckl'dlgn?lgqa ?ninglt Icllu auto-H It. p.540 y. p. all raw-no ou-cJ 0- Ib-o lob-l do- use! I. occult-II o-I Int-thou I-JI- Don-?0' uo-Juluo-Q Lu ILL. 9., "no-guru-Joe. un?t-1 Io?. Ian clan?cl .- 9.4.- oo-J-lu-n Incl M-muy 0-4 hvu' Ont-No 0-, HI u- THE DOW CHEMICAL COMPANY MIDLAND. MICHIGAN 48840 I I I I HAM. SPECIMEII EABEE _n FORM THE CONTROL OF MANY SPECIES OF TREES, BRUSH AND BROADLEAVED WEEDS AND FOR THE SELECTIVE.CONFROL Allin Inn-Jinn Sell el 1. I 5- At? IquInIe-l 40.5 25 A OI It.? {0 hand! an Gallon VEON 145 II In! an In tmlrallmg and hDOdf plan" own-inc In I-ghi-ol-wan, Ionum?em. dutch. bnnh. mound" and II is cumin on Inch wet-n upon. Ide. bloclhony, elm, luau. held and IOII maple, out. oIoanI. IVY. Inuollm, Van-mu Heep", w-Id cheny and Imld you. a: we" a; many other needy and hnbaccom wech. II allowed lo ?and all" Inn-no il mun bl contend ago-n uuinq, VEON 235 inbanl \playl. II II no! Io: Iclccuu use In (Iopt. DIRECTIONS Spray woody growth up lo 6 an Ire! loll ahu Iolmqa in well duvrlunrd. uunq a [may containinq I oI VIOH MS or! IOO gallum ol Cunt-Ian: Ihoulul he tum- plI-Ie and all porn OI Ih plull. Ioliqc, Ihul ?can and huh, tho-dd he Ilnovauthr wIl Inlay. Inuln own", In? be ?blamed Ilom appluluhom mode won all" mun Imum Iul-uue dechuIImenl in NI: "Irina. Will! gIIud olom'm? (and-luau and ode-mun Io-l may he Ina-la up In 1 lo I huh nmmul dale Il plan" om cum-Iv gun-mo. In. ?II-clue Ianlnul may Inull dunno hul, dIy wooihn. Renal may In mu gIOwlh devalued. _r - WARNING. Do not apply VION 245 oIhemne II In come Inlo (O?lutl mu. llowtn, ouopn, lIu-I hm. tolhm of olhn plan? me urn-Inc lo OHII ?ul luluv I'm" (O?Iommq II Io onlo "Inn. \Inu (In-u (II We ?Nor fray tome InIuOy ICnan. "no? me Iru lo II, ?IIllIu l_ numml um and Imnd lw Inuit-II (ml only wI-rn lI-ru.? no IIomId On "In. (onlommnle uh'julaul?l or quI-I mm] In: dun-uh: Inn- powt. Du nol mar II Ihlurn, OI tld?. [Henna unlaunh nl In "no may II-I-II qI-Im-unI-on or plunI Beta-Inc oI dIlIucully (II-mum} ?non-n oml ullIeI I-nII-Imu-nl ?w I unlh 1,-lj-I' rump- ml'nl In! "\hI Inn (II umulpm, "um Mull-pun" llul be u- u-,cJ In: any mulrllul ulm II In." lu- nHIIu-d ch-mhle u'geldlum. a! and I?Il'l'lfill? bl 0' tonlmm lo lot oI Con-mil your nl Ul?l'l" II II-lml. 2 l' I'oI-u'. In l'urnml I- -e quIm-II Irml (onJ mI-nl lI-muu-Il-l [II-lou- uuno 90 NEEDS RICE HOVICI main no oI any Ilnd, Ilpl?l or Incl-rd. mn- uunmq Inc 0' Hm 0m." ouumu all Ink on a: In du?hotu 0' WARNING csuus mnIIAnou orIuIH AND 00 In! In Ana-I unlul In?. ?In all In ol (unlul un.l.lulrd run-II lull". "th 'yl?I uI'wol? ol I5 mum!" and on med-col uo-JI wan aml ol Rum)?: and hmlam-nach Ie-u?l' Do nul Inn-0' ccnrummuII-I mun. THE DOW CHEMICAL COMPANY CONTROL IN RICE: Treat a to 0 ueeka after emergence of the ride. ling when plants have emerged above water surface and are erect. :ozimately 5 to 7 gallons of water per acre. 'Ivv'v?T" .r?r'v?r 1? Inn" i A where For bent beaulta ueeda .uhould be young Iva-I I. HIDIAND. MICHIGAN i MIDLAND owmon I In U.S.A. I 1'F-Wr3'r r'vr Ir' '1 nl". 2:11? Use 1 to 2 pints of Venn and actively growing. treat between 7 and 9 weeks :ttor 245 In I IJIEII I Lata" weeds ouch as Mexican weed and curly ludilgn, up t? 3 pints of Venn 255 per acre nay I.c bv? vivid may en - anom II: WEED AND BRUSH KILLER A General Wood and Brunh Conuol Formulation I0t Invented EmuIanns ~01an- oucmoq mm Mom-?- tic-l 0 no Inn-a UIDA low-duh. ?a sum rum no- ?our-l not Kiwi-n1 mm d- you. rd mil-In in. WI "hood; nun-nu I In. cud-won. pun-H .- ?an. and hub. ounce mun-y low-I Mun. nut-In. I- on 1? can n- "and ?not-not UM jug. thh' ?an o" In? In. Obit-HI. [Io-"In no! will" a" 0? would. hunk-n ..luuhlon' . Mun um! non-uh am. hth? out! shun-v. to. ?no vul- banana?- Inuhu Mu" IWH .b-uh ?In Inca-ow (?0'31 .04- rum-u. owl Hm my Ind DMCTIONS a Hm ?Hm! (I II ?nu-m I. "a I non ?twin-.- Dirk mall .00? ?114' W. I to- .u nun I-qh an l h{umdl MIDI. vow-1 luau. unn- Ian I "Ina-Q .0 but I'M-wt II ?1 rI-l Vll'm (I null OHM fur-U. ll W'hunk ?In . FWI and tau-Hm Inl on rv-nal r-rl lawn-u l-I-lmom-u not-1 a- ?qua-m I. I 0 I I ur-I'nl Nun-v! luck I. uh" an"! mun-In two! I rev-? all luv! In I. I M. ud leoI-nl II. In luv-uni cl I'm-u d-luu'l I. In! 40 tu? Nun-1 .4 ul In? the foul ooh-u- -n urn-W rncwomms mun bu! um IN and: huh moi-m. OHMII . you roam. ?mun? ulna-I Mun-can" inn-dau- Egg mun-lac null-ulna Jun-1M? Rich-1 Hui?Io I. I at.? by up" Ind "and ad?- .004 mulmuwdodwllo?ltl who [Mud-tom and "4:00 Maui-o. no.4 gar-M two-o..? nun n. .4 ?Ir-Nun- N.- on comm! "qua-n until '4 new. luv-M In up" luluhuh. In too-rod In: In? lv-o- own an.- nun-non. no. .- dunno-d 5? ?Hr-alum. duo-u tor-mood" Nun-?Ii ?maid? 10 huh-u in mm rm. woo-.0 til-d bung-ducal um haunt-mun II ?Hm-m welt-t- um I 'Md .0. Viral-Iv!- dunno i Gonna-d I'm-n (I nu! dunno-um bro-Mm'Nrde-OI??c-aup-?M Inc-u. O-uu-?l?u-?tl-I-ufl-C 00-0..-.- I-I?u-u hit-I. Mule. nun-I urn-Inn an? to urn-o the oo- cum-d an burnt nut-gill!? lulu liq-? n. ?nun-o" I'd. Fund VINHH LI val. u-"I-n on ?nu-"4 innit-on 0 "our!? [vino-d luv-1 ?at-M I In anon he won um IN GI and wow-1 0. newt-haul by (I hr! mu um! ?emu?n. 4 (on: No Iw'ul Inch yurIoI-h VH0. 'ud nnp'inll'l tour! a- UIMI unm- wr-u one!- In man-n I. I D. l "no Inna? nun may to win tun-n 0mm. Q-IM IN run-m1 h-mom Noun-m by who nap-on- "mpg. about". that" one. ?an um. Mull hr!- an! In run" a "(My canon uh- nu-?-Io ivy-Quin twat-tal- 00 My Inf-c- Ina-p. hall nouns-m any one my 0. mun-v- yin-n run?v1 h- c-Mv-H m. nu IN CHM ?vi-vyJo?wwuh an In! hon .- rlpuu 0. 0" (mp-now bI-?u?o duh-1 I on. and Orv-uh: pup-ma Do not gluon-u- 0-4.. non-run hare-cu '0 0-0-1 I. hurl-h do an! "an lum- In". 0-h- pruned lull (qr-Mm: I-u do" In. Ill-o uni?ed wort-'1 OI Odor-W ?um. uni 09-44". um um Omit-M Elvin-int? Cal-H not-noon. .C-olv?' 0-. IM rob-'0- I018. lyed?lmd (huh-(oi. MI. \1 If? (I "an 0-51-ng won-J our-1 cow-?Mull Fry and 1'er vulv- Ila-u 1! (I I uiulln?lo?tl mam-mWW-Iunmqn-b-m Iii-?mug 0H I'll In motor! In? Hut-H all nu, and-m oluvm-I an Coll-M lo I 'Iron Fin-1- l-uo-Ic-I 0-?ng Ion?.0 5. II. rug- Mn. 51"? (I Huh-o u?uuh on. an In? IMW nun. in". and-?ohm (In mu .I-t Inn?u an um. [um u-h lulu *Qudulo I Coo-u no In. nu, a. an Mll?Iov-th-?Q In. pcnuoll? shy-.1! Chant". Ind Duo-out! No." 10W nun-II Donne nou'n run-rim. uni-run. Maw-0rd ?menu won? "ad-HI alIo- cu Imh OI dou? No I .4 Duo-u- Bud-o. r-d-nu um" and raw-4' "Nu-u- hay-n. an.? on run?- on? Orr-I pm- mail-o has rm.? 1 In: I. huh Io-p out 0' lulu shall-o r-l led! at: on CAUTION KEEP OUI OF OF CHILDREN MAY CAUSE SKIN WHAHON MAY BE IIAHMTUL '7 SWALLUWED Avoid Com-c1 with (vol. Skin and Cindi-'1 ulna I0. r?cno-?u-I touch?av ?q luv-o r?nvur?luu?w D-a-v?I-u Ian-unpr? ?rt-r l-pv'oh ?WI-"vo- memvw-u "Mum?1min?? huh-?II- II-tu THE DOW CHEMICAL COMPANY MIDLAND, MICHIGAN 48640 ?4 h?l? WHEN Him- 999ng [?nal Zrop Are; 1: 763i ESTERQN For the Control of Many Broadleaf Weeds, Hlerbaceo Perennials and Woody Plants Susceptible to LABEL Grass Pastures, Certain Crops and Non-( .H-s nous. INGREDIENTS: 20.89. 2.4-0 Acid Equivalent 63. 33?6 pounds per gallon E.P.A. Registration No. 464-279 .. USE DIRECTIONS Use 51': herbicide to control crown. oar.c.'e.io.- henb-t. Eochia. Iambsquarters, marsheldcr. mutlordt. peppergrass, pigweed. plantain ragweed, shepherdspurse, thistles. velch. wild rod-sh. and many other broadleal v-eec: wtlhoul iniury to most established grasses.- altO lot (O?lrol Ol 2.4-5 susceptible vvooc.? plants such as coastal sage. sandsage. elderberry. hazel. locust. poison oals. sumac an: willow-r. Use in small grains. corn. sorghum, grass seed crops. pastures. rangeland and non- crop areas. Apply ESTERON 76 BE as a water or oil spray during warm weather when weeds or bra; are actively growing. Application under drought conditions alters will give poor result, Use low spray pressure to minimize spray drill. On cropland and along roadsides. do n: exceed 20 psi pressure. Apply enough spray volurl'te to provide unilorm coverage ol wee: and bruth_ usually 5 to 20 gallons per acre by ground eQuipr-nent and 3 to 5 gallons by ai: cralt. Higher gallonage may be used if desired to improve spray coverage and to reduce tr. hazard lrorn spray drilt. . Generally, the lot-er dosages recommended on this label will be satisfactory for young succulent growth al sensitive weed species. For less sensitive species and under condition- where control is more difficult. the higher dosages will be needed. For crop uses. do not In: I-ith oil or other odiuvants unless specilicolly recommended on this label. Deep-roote- perennial needs such as Canada thistle and lield bind?eed and many woody plants usuall require repealed appliCations lar maximum control. Do not apply ESTERON 76 BE wher Spray drill may contact nearby susceptible crops or other desirable plants or may cor. laminate water for irrigation or domestic'use. Do not apply in the vicinity of 2.4-0 sensi tive crops or ornamental plants since vapors from this product may cause iniury to suc.? crops or plants. Read and follow all Use Precautions given on this label. NOTE: If there are uncertainties concerning special local use situations or specilic crc; variety tolerOHCes to 2.4-0, consult local Extension Service or University Specialists lor advice TO PREPARE THE SPRAY: (1) Fill the spray tank about hall lull with water. then add the re quired amount of ESTERON 76 BE. with agitation. and linally the rest ol the water. NOTE ESTERON 76 BE in water forms an emulsion which tends to separate unless the misture i Irept agitated. (2) ll oil is added. lirst min the ESTERON 76 BE and the oil and then add 1h: mixture to the water with agitationdl?lowevet. with adequate agitation. the oil can be adder after the ESTERON 76 BE is mined in the water if strong agitation is provided. l3) ll straigt oil is used. a solution is larmed and separation does not occur Do not allow any water to gc into the oil- herbicide mixture to avoid larmation ol an invert emulsion. WEED CONTROL IN SMALL GRAINS NOT UNDERSEEDED WITH A NOTE: Water' recommended to make up the 'spray. ll .ail is used. there is a greater risls ol crop iniury an of spray drift. Do not permit dairy animals or meat animals being linished lor slaughter larage or graze treated grain fields within 2 weeks alter treatment. Spring Wheat and Barley: Apply to 3/5 pint per acre by air or ground equipment. A t, pint per acre rate of ESTERON 76 EE is an average dosage. ellective on many needs. when grain is in lull tiller stage (usually 4 to 8 inches tall) but belore the boot stage an ?uhen weeds are small. Do not apply belore ihe tiller stage nor from early boot to the dour; stage. Higher totes (up to l? pints per acre) may be reguired to control certain weeds b: crap iniury may result. Winter Wheat and Rye: Apply to '32 pint per acre in the spring at the lull tiller stag but in?ate the early boot stage. See more complete use directions under Spring Whec and Barley. Spring Seeded Cull: Apply pint per acre at the lull tiller stage but belore the ear! boot stage. Cats are less tolerant to 2.4-0 than wheat or barley and are more liiely to some injury. especially il higher rates (V2 to 3/3 pint) are used to control dill-cult weed Preharvest Treatment: Apply 3/3 to pints per acre vvl'len grains are in the hard daug stage to control large weed; that may interlere v-rith harvest. Best results will be-obtoine when soil moisture is sullicient to cause succulent weed gro-th. NOTE: Do not leed treate straw to livestock. WEED CONTROL IN CORN: Use one at the lollouing three programs: Preemergence: App to 23/: pints per acre to soil anytime alter planting but belare Corn emerges. Do n: use on light sandy soil. Emergence: Apply pint per acre sust as corn plants are breolm ground. Postemergence: Alter emergence of corn. use '1 pint per acre. Application at l. to 7/3 pint per acre may be needed lor malirnufn control ol some weeds but such rates a: more likely to injure the com. corn is aver 8 inches tall. use drop nestles to keep the all the corn foliage as much as possible. Do not apply tram the tassel-n9 to dough stage not use with oil. atratme er adruvonts Crop inluty is more lilsely to occur il corn is gran-in rapidly?under high temperature and high soil moisture conditions. To reduce breakage stalls lrom temporary brittleness caused by 2.4 D. delay cultivation lor to ?3 days all: treatment NOTE. Hybrids vary in response to and same are .ass', insured Spray oni varieties known to be tolerO?l ID 2.4-0 Contact seed company and Eslension Service We: Specialists lor this inlormot-on 1'25 39?5 In:h? IDIO. I'll?. tr Ira-I: s? .. . bul ml"? ?lie-rise increased. Do not use with ml or other adiuva'nts. Do not treat belore the sorghum Is 5 inches tall not during the boot, llowering or early daugh stages. ll sorghum is taller than 8 inches. use drop nozzles to keep the all the loliage 0? much as passIble. Temporary crap "?07 under (andrtians al high soIl moisture and high 'empumw?? vd'leli" 3" '0 2.1-0 and some hybrIdI are Quite 59"" ?n 7 'o'ic'l? be '0 33-0. Contact seed company and Extension semi" Weed Specialists l? 0? lap?? in lhe vicinity al cotton. saybeons and other 2 4-D suscept: -bie plants. WEED CONTROL GRASS SEED CROPS: Use to 1 pint per acre in the amaunl ol water required lar umlorm application by air or graund equipment Apply to established stands in spring harm the tiller to early boat stage. Do not spray in boot stage. New spring seedings can be treated with the lower rate alter the grasses have at least live leaves. Perennial weed regrowth can be treated in the lull. BRUSH CONTROLIN RANGELAND AND GRASS PASTURES BY AIR OR GROUND EQUIPMENT: NOTE: Do not graze dairy animals on treated areas within 7 days alter ap- plication. The following treatments will iniure or kill legumes so use only where loss ol legumes can be tolerated. Do not apply on newly seeded areas until grass is well estab- lished. Do nol apply lrom early boot to milk stage when grass seed production is desired. Broodleal Weeds: To control bitter-weed, broom-eed. croton, docks, lochio. marshelder, muskthistle and others. use 2V: to 3 pints of ESTERON 76 BE per acre in the amount of water needed lar un'ilorm application ll the weeds are young and growing actively 1V: to 2 pints per acre will provide control of many species. Deep rooted perennial weeds may require repeated treatments in the same year or In subsequent years. Chaparral Brush Species: To control chamise. manzanita. buclbrush, coastal sage and certain other chaparrol species. use 1V: to 2 quarts per acre in to ID gallons of water. A gallon ol oil per acre may be included in the spray mixture lor added ellectiveness. For ellective control, the brush must be lulty lealed out and growing actively when sprayed. Retrearment may be needed. Big Sagebrush: Use IV: to 2 Quarts per acre in 2 to 3 gallons gallons at giLwater emulsion 'sproy. For ellective control the sagebrush should be in lull foliage and growing actively when sprayed. WEED CONTROL IN NON-CROP SUCH AS LAWNS, ROADSIDES, VACANT DRAINAGE BANKS: Apply I to 2 quarts of ESTERON 75 6E per acre in the amount al water needed lor unilarm application. Usually IV: quarts per acre provides good weed control under average conditions. Treat when weeds are young and growing well. Do not use on gall greens nor on dichandra or other braadleol herbaceous ground covers. Do not use an creeping grasses such as bent and St. Augustine except lor spot treating, nor on .newly seeded turl until grass is well established. Reseeding ol treated areas should be delayed lollawing treatment. with spring application, reseed in'the loll,- with tall applic_atian, reseed in the spring. legumes are usually damaged or killed so do not treat areas where the legumes are desired. Deep- rooted perennial weeds may require repeated treatments in the some season or in subsequent years. PLANT CONTROL IN NON-CROP AREAS: To control species susceptible to 14-0 in right-al-ways, lenceraws, Jaadsides, and along drainage ditchbanks, spray brush up to 5 to 8 leer tall alter spring foliage is well developed, using 2 to 3 quarts of ESTERON 76 BE in 100 gallons al' water and wetting all parts al the brush including laliage, stems and bark. This may require up to 400 gallons ol spray for adequate coverage ol solid stands of brush. Make application in such a way as to prevent drift ol the spray all the area being treated. Spraying can be ellective at any time up to 3 weeks belore lrast as long as soil moisture is sullicient for active growth of the brush. less ellectire control may be obtained during hot dry weather when soil moisture is de?cient and plants are not actively growing. Oil or wetting agent may be added to the spray, il needed lot increased ellectiveness. For more resistant species and lar general control ol mined brush, use ESTERON Brush Killer or ESTERDN 245 herbicide. SPOT TREATMENT: To control broadleal weeds in small non-cropland areas with a hand sprayer, use pint of ESTERON 76 BE in 3 gallons ol water and spray to thoroughly wet all weed loliage. Keep spray nsi-Iure agitated to prevent separation. use PRECAUTIONS Do not apply ESTERON 76 BE herbIcide directly to, at other?use permit It to come into con- tact with cotton, grapes, lrurl trees, vegetables, llowers or other desirable crop or orna- mental plants which are sensitrve to 2.4-0 herbicide Do not perm-t spray to dust onto them, since even eery small quantities al the spray. may not be can cause severe iniury during both grow-rig and dormant periods Use coarse sprays to drIlt With ground eqqun'Ient, spray can be lessened by Ieeptng the spray boom as lor- as possible; by applyIng 20 gallons or more ol spray per one: by usrng no more than 20 pounds spraying pressure with ?or Ian at lloodrng llat Ian nortle tips, by spray-n9 when velactty is low; and by all sp_raytng when erreeds 6 la 7 rmles per hOul Do not apply with hollow cane-type at other naz'tlcs that produce a lure-droplet spray aIrcralt applicatron, drIlt can be reduced by apply-n9 a m-n-mum al 5 gallons at saruy per acre. by usIng no more than 20 paunds spray pressure at the nottles. by usIng noctles which produce a coarse spray pattern, and by spray-n9 only when the wind velacrty Is less than 5 miles per hour. \Zr. c; 132 uncl- It UIUWNIS IUUHCIIO OI ornamental plants. This it c: high-volatile 2.4-0 ester lormulotion. Vapor: from thig product may injure ?usceptible plants growing nearby. Do not use in or near a greenhouse Enceuue amounu of it?; herbicide In the soil may tempurorily inhibul seed germination or plant g-o?Ih This product is taxi: to lish. Keep Out of lakes. streams and pondt. Do not apply when rung? is likely to occur. Do not contaminate woler by cleanmg ol eqtuprnent or d-sposnl of -oslei. Do not contaminate urigotion ditchet DI voter ulcd lo: OffingIO? or domes tic purpoies. To avoid intury lo deiiroble plants, do not handle or apply other agricultural chem-colt y-ilh the some equipment uned lot ESTERON 76 BE except as on ll'lls label, This product can be stored in on unheated building but do not Hate neor aeeds, infect-odes. or lungicides. ll e-posed to ternperaluret. it should be warmed to at least 40 and mixed thoroughly belore using. Do n0! reu-ie cantainer Diipose of empty containers by punching holes in them and burying with waste in non-cropland away horn water supplies or follow olliciol local recommendationt lat conlainer disposal. local condition? may affect the use of herbicides. Consult yaw State Agricultural Eapenment Station or Ellension Service weed specialists lot advice in elecling treatments iron this label to best in local CO?dllionL Be sure that use of this product conforms to all applicable regulations. Apply this product only in apecitied on this label. CAUTION KEEP OUT OF REACH OF CHILDREN HARMFUL IF SWALLOWED MAY CAUSE IRRITATION Avoid Contact with Eyes. Skin and Clothing NOTICE: Seller aarronn that the product cor-lord? In in chemical deutiphon and iec-io-oc-bly la la: Ihe pv'pmtl slated on the label when used in accordance direct-om undev normal coed-horn ol me. but neither Inn warranty not any other can-only ol MEECHI-NIABHHY or FITNESS FOR A ?3 IICULAI PURPOSE. "are? or unpl-ed. euendi to the we of mu producl contrary Io label unuutl-OM. or under abnormal conditions, or under no! aemonooly loreseeuble Io gallon and buyer cis- w-ie. the anti a! an, unit we. .THE ?pow CHEMICAL COMPANY AND sulsuoum?s ?sauna. RICHIGAH 43340. USA zumcn, mzenuuo Hours xouo. acc "co?iut. GABLES. FLORIDA 33134. USA SARNIA. ONTARIO. CANADA . Call?? 0? Cum 3&0 lull"! all- It- 0 Pout II -. I -I.I II I.I V. IL- 1 Inn-Illa? In.? .I th-I g-Iu-I II h-hI. QIJ unl- 0-. "Hull" .I .II . dunk-I. Ion I I I IIQIHIR 500 InluI. I II I II I run?- I- II II Idv." I In a. .0qu Innin?. II IN In.? non-?I am II - .-I. dun II. Inn .ugI. no .I Ih I. I hull InII-I I I 0? (an"I?I-.I I'Jinn I. ["05 It 0' I'l . I ..-- I.-I. o-l . Iu-l' II [II-?l-Oiv I- I uu' I InkI?ll'v 0 w. pug-.L-unI-I-I (u-I II.. I -. II "q lu?llh -Ina"It. hon04.I.. Jun I0 I- DI 55.135 5m .It- Il'l II In! II..- I5.55 5.0m 5555.555 5.55. 555.755: 55.555 I 0 FII-JI 251.10 PII OIHII ??He. . n" Dunn [I'??lulf 'l '5 I I. I 'L'I-qul {gun-run .pun-.. .I . . . .. InfOno-I u' II Ogl?l'Haul I . 'Mn? Inf"?ng IMO-F. ".lwo-l- - in: 13.31" '53I?ll. . Inn";- in?a-n-II- I - . "qua-I.- 00- I.-. 5.153135 .55 .4 23 24 25 .1. UNITED STATES DISTRICT COURT Deposition of: WILLIAM J. Product Liability Litigation MC CARVILLE TRANSCRIPT of testimony as taken by and befcr; MARGAR vi J. TSILHABER, a Certified Shorthand Reporter and Notary Public of the State of New Jersey and new York, at the offices of TONNLEY 5 a UPDIKE, 405 Lexington Avenue, New York, New York, on'Friday, February 11, 1983. . I 405 Northfield Avenue West Orange, New Jersey 07052 (201) 731-9QGG 3&2, MoCarville - direct . I 95 A. Yes. Q. Thereafter did you eyer hear from anyon that your product was being and had been used in Viet'Nan? A. Yes. Q. When did you hear it for the firsn time A. My recollection; sometime in the early seventies. Q. Were you surprised? A. I don't recall one way or the other. 0. Do you remember having any feeling at a ?when you hired for the first time that that produc - 7v" ?wa MR. SABETTA: Objeotion to the form;? A. _Did'I have any feeling at all? 0. Any feeling one way orthe other or any feeling of surprise or shock. MR. SABETTA: Objection to the form. Q. Any emotional reaction at all. A. I guess it explained why they bought so much, yes. Q. Did you have that question oi why they bought so ?nch for a number of years? A. Not physically, no. I l3 0. When you say I guess it explained why 9 3&3 WOGG and spine?! certified shonhond repo?ers &McCarville - direct I 95- they bought 5o mUCh, you as the director of prodL wanted to sell as much as possible presumably. I that true? A. Wanted to sell as much as we could in resPon to the government request. Q. Your answerUis you did want to sell as .much as possible. Wasn't that your job?_ Isn't't true? A. - The government was a customer. 0. Your job wasn't to sell as much of any product that you manufactured as you could? Since this was a ?roblem, a-CUStcmer that I couldn't influence, I responded. Q. In any event, sometime in the early seventies your question as to why there was so mu of~this product sold was answered. is that corre A. My recollection, yes. Q. You found out that it was being used i Viet Ham. Is that correct? A. Yes. Q. When you talk about the early seventie was that after 1973 or from the period of, say, to '73? A. I don't recall exactly when. At one point 59f UNITED STATES DISTRICT EASTERN DISTRICT OF NEW YORE. HDL No! 381 In re Deposition of: CECIL H. RUSSELL Product Liability Litigation TRANSCRIPT of testimony as taken by and before NANCY C. BENDISB, a Certified Shorthand Reporter ar Notary Public'of the_5tate of New Jersey; at the - MARRIOTT, St. Lauis, HiSsouri, on Monday, 2. 71983! commencing at 9:30 in the forenoon; 405 Northfield Avenue Wee} Orange, New Jersey 07052 (ZUI) 731-9666 132 8?1 302:7 - '4 Pa?i?or? ror~f~?nn Russell 55 you've spoken about before, but what have you published for Monsanto? A. 'Well, the three fertilizer blending articles and the Scotts standard method of analysis. Q. .Anything else? A. Nothing in the literature. Q. Well, that's what we?ll be talking about, about publishing that would be in the literature. A. Yes. And when you say you published private- matters, I'm trying to ascertain what you mean, sir? 7A. Well, the private natters would be procedural. Q. What do you mean, sir?? 1% I Processes, manuals of operation, that sort of _thing. I Q. 'And did any of those privately published 'articles have to do with phenoxy herbicidesthose -- rA. 'Correction. Specifications. 5 Q. He;ll'talh about that. You created thew? specifications for Orange 1, did_you not? MR. SABETTA: Objection to the form. V53 0. - Did you create the-specification for Orange 1? 3mg [right? .3 C. Russell MR. SABETTA: Objection to the form. A. I wrote it, my version of it. Q. Well, when you say you wrote your version of it, was not your version the one that was then inCorporated into MIL MR. SABETTA: Objection. A. They were the same. Q. And your,version that you created was created before the MIL spec, was it not? MR. SABETTA: Objection. A. No. 9. Was your ver?ion that_you created created after the MIL Specs? A. Wt. I don't remember'who. We worked together, more or less. ;When you say we, who do you mean? A. Couple of gentlemen from the.military. Q. Colonel Bartlett, is he one? A.h That don't sound-like it. They came_here but I don't speoifically remember their names. They were. chemists. Q. Government chemists who came_to Monsanto, \B?i A. . Yes. .. 3&7 gnu?- UNITED STATES DISTRICT CC EASTERN DISTRICT OF NEW HDL No. 381 In re. Deposition WESLEY R. KOS Product Liability Litigation TRANSCRIPT of testimony as taken by and bef THOMAS L. LA Certified?Shorthand Reporte A. and Notary ?ublic of the State of Neo Jers?y, at TREASURE INN, Daytona Beach; Florida, on I I Pfiday, the 27th day of January, 1984, commencin 10:09 in the forenoon. 405 Northfield Avenoe West Orange, New Jersey 07052 (201) 731-9666 302% W000 and sDinelli certified shorthand tepo?ers 10 11 '13 14VFenner . 109 MR. WHITE: Objection: A. That's my understanding of'the directed order yes. 0. In other words, it logically follows an: it can be assumed that in the event a chemical company does not choose to make the herbicide, it could refuse. I I . MR. BURKE: Objection. A. My understanding is yes. Q. In y0ur earlier testimony, you stated, and it was shown in exhibits, that terminetion letters were distributed on or about December 16th, 1958, for contracts r? _0r telegrams, I think it was ?t wes done by TWX. Q. Do you recall, thereafter, if any 'contracts for the Herbicide Orange were?negotiatgd zbetween the Government and any of the chemical companies after December 16. 1968? A. No, sir, I don't recall any. 0.. Had there been any such negotiations, would you have been involved in each and every one or ?0u1d_somebody else possibly have negotiated? A. Someone else could have been; I would have 3&3 been the most likely one, I would say. - W090 and spine!? amen-M ?mum", ll}. 10 11 12 1_3_ Koster I 1 producing Agent Orange or any company producing th components thereof? I don't remember specific cases of any such thing,_but I think Miss Lewis did that as a matter of course. Q. _Do-you recall her ever indicating such appeal underway? MS. BOLGER: Objection. A. Would you repeat the question? 0. Do you euer recall her specifically saying to you that chemical company A has appealed . . directive order A. I can?t recall any specific instance of that} 5 HR. TYRRELL: '0bjection. Q. If a company was not producing the products required by the Department of Defense, would the Defense Production Act of 1950 as amende require that they begin production if such a directive or rated order'was issued? MR. GOLDSTEIN: Objection. It calls ?0 a legal conclusion. TIRRELL: Objection. at -. I A Q. may answer. A. I can_answer it.J,There was an understanding that I had in those years which I can't define rig' mama and minem certified shorthand renone'rs 340 4-1 . ?u?llKoster .. 1 now, and can?t remember them as to whether a compa . JII- . . if they did not be forced to make a given pro normally make it. My recollection is that we coul 'not. 0. Sir, you retired in 1970? A. Two. Q. And in 1972 was-Miss Jane Lewis still working with you? A. She changed jobs at some time. I can't recal whether it was before I retired or after. She mov to another place in the department. Q. Would it have been close to 1972'if it . . was before, do you recall? I:would say it would have been that she would have still been in the department through all this period here which goes up to September or October 1968. I don't think she made any move before that Q. What about between 1968 and 1972, do-Yc recall? A. No. That's the area I'm not sure of. 'She me have still been there in that time and I don't kno 0. Sir, you have no specific recollection ever discussing chloracne with Jane Lewis, do you, sir -- . r3 HR. GOLDSTEIN: Objection. . 3d! H- A?r' - I UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK PRODUCT LIABILITY LITIGATION MDL #381 (:Lyq?iig? 8fi Vvvs.? ALL CASES DELCARATION OF JOHN A. RICHARDS I, John A. RiChards, being duly;sworn, depose and state that based on the records, files and documents to which I have access, control and Supervision, the following is true to the best of my knowledge, information and belief; (1) (2) I am Director of the Office of Industrial Resource Administration, an office in the International Trade Administration of the U.S. Department of Commerce. Formerly, wedgere named_the foice of Industrial Mobilization. since 1968, I have been employed in numerous capacities within this office. a) 'The Defense Production Act of 1950, as amended, (50 U.S.C. App. 2051 et. seq.) authorizes the President fto require that performance under contracts or orders (other than contracts of employment) which he deems necessary or appropriate to promote the natiOnal defense, shall take priority over performance under any other Contract or order, and, for the purpose of assuring such priority, to require acceptance and performance of such contracts or orders in preference to othgr contracts or orders by any person he finds capable of their performance." I. Executive Order 10480, as amended, 3 CFR 962 (1949-l953 comp.), 50 U.S.C. App. 2153, delegates'authority with respect to all materials and facilities except petroleum, gas, solid fuels, electric power, food, transportation, storage, port facilities, and distribution of fertilizer and farm equipment, through the DireCtor of the Federal Emergency _Management Agenby to the Secretary of Commerce. Department of Commerce Organization Order 10-3 (45 641, January 25, 1980) provides for the organization and" assignment of functions and delegations of authority including certain authorities of the Defense Production Act of 1950, as amended, to the Under secretary for International Trade. International Trade Administration Organizatign and Function Order No. 41-1 (45 FR 11562, February 22, i930) provides that the Office of Industrial Mobilization shall? perform national defense and mobilisation functions, including administration of a system of priorities and allocations to guarantee an adequate supply of strategic, critical, and other products and materials for defense and defense-supporting activities authorized by the Defense Production Act of 1950, as amended. The Defense Materials System Reg. 1, as amended, and Defense Priorities System, Reg. 1, as amended, (recently combined into the Defense Priorities and Allocations System (15 C.F.R. Part 330 et. al.i but previously cited as 32A CFR Parts 621-662) establish an operating system under which 37 3 (3) allocations and priorities are administered in order to keep defense programs on schedule. . The Department of Commerce in BDC Del. 1 (41 FR 13641) (now Office of Industrial Resource Administration) delegated to the Secretary of Defense authority to place and authorize others to place mandatory acceptance orders. (9) The above items 2(c) through set_forth the delegations of authority under the Defense Production Act of 1950, as amended, within the Department of Commerce, and to the Department of Defense by the Department of Commerce, as they currently exist. During the period September 20, 1966, through September 18, 1968, the following delegations were in effect: . 1) Department of Commerce Order 152 (October 10, 1953) - 13 an 5503, as revise; 29 FR 5403. 7 2) :National Production Authority Reg. 2, as amended, (March 23, 1953) 13 FR-1684. 73) Defense Materials System Reg. 1, as amended, (December 2, 1959) 24 FR 9595. 4) Business and Defense Services Administration Del.. 1, as amended, (May 31, 1960) 25 FR 5788. a) On September 20, 1966, the Defense Supply Agency, of the Department of Defense, Cameron Station, Alexandria, Virginia, requested assistance from the Business and_pefen?e Sggyic Administration, (now the Office of Industrial Resource Administration), to obtain and accelerate the delivery of the herbicide defoliant "Orange." lq, 9? 344 (4) b) In response to this request for special priorities assistance, Mobilization on March 24, 1967, issued directives_t2 producers of defoliant "Orange" (Diamond Alkali Company, Dow Chemical, HerCules Incorporated, Monsanto Company, Thompson Chemicals), to. accelerate rates of delivery of "Orange." Also the Office of Industrial Mobilization issued directives Chemical Corporation, a producer of tetraChlorobenzene and 'trichlorophenol which are intermediates used to produce "Orange," for shipment of these intermediate chemicals to the above listed defoliant manufacturers and to Uniroyal Ltd. (Elmira, Canada). The above listed United States producers of "Qrange" and intermediates used to produce "Orange" were further directed to provide the Department of Commerce with a - .. report of production, shipments against rated orders, inventories, and production capacity for "Orange," and for intermediate products. c) On September 183 1968, the above listed producers of defoliant, were notified that the March 24, 1967 directive requiring shipment of defoliant "Orange" and intermediates was rescinded. a) Prior to the time in which the cited directives were issued, Department of Commerce officials were aware that the chemical companies mentioned above were already in production of herbicides used for defoliation purposes_(See e.g. attached letter of Dow Chemical dated March 29, 1967). ?(421 SR 315/ Therefore, the purpose of the directives to those companies Were to accelerate production from already existing company production rates to accelerated production rates which met the requirements of the Department of Defense. b) At the time the Office of Industrial Mobilization issued its directives to each of the producer's of "Orange," the directive required the companies to notify the Business and Defense Services Administration if they were unable to accelerate production as directed. Our files do not reveal that any company, which was directed to accelerate?m production, appealed to this Department on the basis that the company did not produce "Orange" or could not increase production. Some Companies responded that they could comply with the directives if sufficient qu entities of production Iv materials were supplied. I declare under penalty of perjury that the above is true and correct. Date: 4M #:1371qu WWAPC hn A. Rich??rds g-u-I- ?5 l?xL 3% UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK I14 RE PRODUCT LIABILITY LITIGATION ALL CASES . A. . (vkpv? ITI ORANGE ?Vin?Iv?! DECLARATION OF ALVIN L. YOUNG I, Alvin L. YoungJ being duly sworn, depose-and state that based on the records, files and documents to which I have access, contr knowl (1) 01 and supervision, the following is true to the best of my edge, information and belief: I am a Senior Staff Scientist (AFSC 2616) with themggited States Air Force, currently detailed as Senior Policy AnalySi of the President, WashingtonJ D.C. Since 1968, Ijhave served as an expert for the government in areas of science (2) related to the military h?rbicide Agent Orange. Specific areas of expertise include formulation, equipment design, application, military use, dioxin contamination, environment; fate, toxicology and human risks to exposure. Agent Orange, as formulated and procurred for the Department of Defense, consisted of approximately a 50:50 mixture of the normal?butyl esters of 2,4?dichlorophenoxyacetic acid and 2,4,S-trichlorophenoxyacetic acid. The product was formulated to contain_approximate1y 8.6 pounds active ingredient (acid equivalents of and per gallon of liquid. Thus the product contained roughly 4 pounds of each herbicide in the acid form. Hist 37'? (3) The herbicides and have been commercially available and widely used since the late 1940's. Numerous formulations including the iso-butyl and normal-butyl ester formulations were used commercially in the United States prior to, during, and after the use of Agent Orange in Vietnam. In the 1960 Farm Chemicals Handbook, formulations of the normal-butyl ester of containing 4 and 6 pounds per gallon active ingredient were recommended for weed control in Wheat and other field grains. In the same handbook, formulations of the normal?butyl esters of both and (as a mixture) were recommended for brush control on rangelands and in reforestation. Typically these latter formulations contained the active ingredient at 4 and 6 pounds per gallon. As late as 1980 normal?butyl esters of 2, 4? were commercially available (DOW ESTERON 7683} containing 6 pounds (acid equivalents) per gallon. Analyses in the early 1970?s of archived samples of commercial formulations of and archived samples of Agent Orange shOwed similar levels of dioxin dixoin) contamination (See Young, A.L. et a1. 1978. The Toxicology, Environmental Fate, and Human Risk of Herbicide Orange and Its Associated Dioxin, Air Force Technical Report OEHL 78-92). I declare under penalty of perjury that the?a ove i trua and . .ur-r - if 3. .. - 8L1) THE DOW CHEMICAL COMPANY MIDLAND. MICHIGAN August 9, 1967 Albert M. Kligman, M.D. . Department of Dermatology Hospital of the University of 36th and Spruce Streets Philadelphia, 19104 Dear Dr. Klig'manz' I have your note of a few weeks ago and apologize for not answering it sooner. We do want you to come to Midland to present a progress report on the work that you have done with the acnegens. At the present time I- do not know when will be a good time. I hope we can work it in early this fall. Is the re any time when it would be best for you or any time when it would be impossible for you? If you will let me know the answer to these questions, I will do my best to fix a date. In answer to your question I do not know whether acnegens have been found to be carcinogens and I did not know that carcinogens were potent acnegens. lam very interested, however, and should like to discuss this matter further with you. We're looking for- ward to your visit. My best personal regards. Sincerely yours, V. K. Rowe Biochemical Research Laboratory 1803 Building ks cc: Corre5pondence K. Rowe (Z) - .. 0 266210?. 61?? MOYER FILE MEMORANDUM TO: RICHARD SCHULER FROM: JOHN BETTS SUBJECT: REVIEW OF EXHIBITS AND PRODUCTION DOCUMENTS FROM EEISIEB V. DOW IN MARK OFFICES (JONES GRANGER LAW FIRM) IN HOUSTON, TEXAS (NOVEMBER 18 - 20, 1991) DATE: NOVEMBER 28, 1991 This litigation involved the tracking down of the corporations responsible for t?ma worst. dioxin. disaster le the United States. Dow Chemical, along with vertac and its Jacksonville, Arkansas predecessor Hercules Powder Company, were named in a lawsuit filed by 183 former workers at the chemical plant and their families. The suit was styled Keister v. Dow and maintained that Chemical, through its ongoing supply of herbicides to Vertac, with the full knowledge of their potentially detrimental effects, shared the guilt for health problems that the workers had suffered. Back in 1965, at a secret meeting called by Dow Chemical at its Michigan headquarters, Hercules, Diamond Shamrock, and Hooker Chemical met to determine how to handle the mounting adverse health. effects caused. by? the dioxin present. in 'their' products. The greater problem for these chemical companies was in deciding where they could dump these highly concentrated dioxin wastes being created at several tons per week at each production facility. They decided to place these wastes in 55 gallon drums at the Hercules Jacksonville plant by burying the dioxin?filled drums in unlined pits at the plant site or carting them off to a nearby city dump, where unwitting residents sometimes bought the "used" 55-gallon drums from the dump?s manager txa burn trash-in. Some of the Agent Orange waste was simply hosed into Rocky Branch Creek which ran into a neighborhood to the south. In the years to come, this process became the worst hazardous waste situation known in the U.S., more serious than Love Canal, N.Y. and Times Beach, Missouri. Babies were dying and adults were succumbing to sudden disease in the three neighborhoods that bordered these sites in Jacksonville, Arkansas. This litigation led to the discovery of gross neglect and mismanagement by federal and state governments and the hidden involvement of multinational corporations and foreign entanglements. Once loyal plant workers and chemists who had aided their companies in these coverups, were now Coming forward and testifying to everything that had happened over the years. In the neighborhood bordering the Jacksonville facility, residents vmnxa saying tx: visitors, ?welcome 1X) cancer alley.? Jack Park, a 23-year resident of this neighborhood and head of the Herecules chemical laboratory testified that bulk chemicals of the agent orange herbicides were brought in. by' the train carload from Dow Chemical and also Hooker Chemical (the company .Q?o responsible for Love Canal). Park, who was tested as having the highest levels of chemicals in his blood, had tried to get a court order to do a door-to-door evaluation of all the neighborhood residents. He pointed to spots in his driveway where hydrochlorh: acbd had eaten away the cement from contaminated rain water. Park said the plant used a pound of hydrochloric acid for every pound of herbicide produced. He pointed out grape plants gnarled and twisted with mutation, and told of his next- door neighbor who was dying of liver cancer. A 71 year-old resident who had lived two blocks from the plant since 1946 conducted her own survey within a four block radius of her home and discovered from her list of 50 deaths in recent years, most of them had been cancer victims. Another 17 of her neighbors were undergoing chemotherapy and other cancer treatment programs for various forms of cancer. Since no state or federal agency would agree to conduct an official study of the area?s cancer rate, local residents were the only monitors. Hazardous?chemicals expert Dr. Samuel Epstein testified "the only real way to cope with this issue is to have a high?level congressional inquiry that would investigate not only the role of the chemical industry, but also the EPA, the state and the industry's consultants.? Hercules Inc., who had manufactured 25% of the Agent Orange used to defoliate the Vietnamese jungles, was being sued by Vertac Chemical who had run the plant for the last 16 years. Then in an attempt to duck its legal obligations, Vertac suddenly transferred (in 1987) its assets into a series of newly formed corporations and left Arkansas. This is where Dow Chemical entered. the picture. Headquartered. in_ Midland, Michigan, 'with 50,000 employees worldwide, the multinational had for years been both Hercules? and Vertac?s main supplier of chemicals, many of which were at one time sold under the Dow label, but manufactured at the Jacksonville plant site. When Vertac pulled out of Arkansas and tried to hide its holdings, Dow counter?sued Vertac for millions in default damages on chemicals they had delivered to vertac for the continued manufacture of their products. It turns out that Dow, who made $11 billion in global revenues in 1987, was tied in behind the scenes with several jointly-owned chemical companies worldwide, with most of their assets hidden in Swiss holding company accounts. Vertac was an acronym for the names of four chemical companies that had merged in 1976, but initially set up by former executives of Union Carbide. Majority ownership was traced to a wealthy Italian named Vittorio de Nora who made his home in Geneva, Switzerland and had made his fortune in the electrochemical segment of the industry. At a Milan-based company he had established more than 50 years ago, de Nora had pioneered a process used in making chlorine, the basic building block of chlorohydrocarbon herbicides that had been developed by Dow Chemical. To protect themselves from possible patent lawsuits, de Nora set up companies all over the world that could be financially isolated and sat on most of their board of directors. Executives moved back and forth between these major companies held by de Nora including the "big five" in the U.S. which are Dow, Monsanto, Diamond Shamrock, Uniroyal, and 3?3! Thompson-Hayward Chemical. Anytime decisions had to be made in the U.S., it was Dow Chemical who called the shots. The major Japanese chemical interests also entered the g?cture, but this just goes on and on. When herbicides were banned in April of 1970 for most domestic uses and finally banned completely in 1979, Dow simply changed labels and registration certificates and continued to sell the banned products as hidden "inerts" in other companies herbicide products. They also created a new Agent Orange under the label of Esteron 245C herbicide and sold it through their Mexicc> City facilities to third. world countries, 'who turn spray these banned chemicahs on agriculture pmoducts that are sold in most U.S. markets. For a few more years, up until late 1983, Dow slipped their .Agent Orange product out under the Esteron 2453B label. Due to an accidentally discovered contaminant batch of this label by a curious midwest distributor, Dow at first tried to hide it from the newly reorganized EPA administrators, and finally had 1x3 cease pmoduction under the Esteron 245BE label and go to the exported Esteron 245C label. The documents and exhibits I was able to locate came from 26 "banker file boxes" that were selected by Mark Kressenberg from a warehouse load of total boxes, some in Arkansas, some in Memphis, Tennessee, and the rest in Houston. There were still several key exhibits he wanted me to look at, but the EPA has had custody of many of the boxes while doing their own investigation on Dow Chemical for several months now. The key exhibits I copied included the original patents for by Dow; the actual production formulas used by Hercules and Vertac at the Jacksonville plant and sold under the Dow Label; the minutes of the famous "1965 Country Club Secret Meeting" called by Dow at their Midland headquarters to decide how to deal with the dioxin problem; key Agent Orange litigation documents including experts testimony, the Plaintiff?s Memorandum on Causation, and many excellent research papers connecting the role: of with 'various disease processes including various forms of cancer. Also included are several years of memos and letters between the chemical companies, mostly Dow, trying to decide how to handle their dioxin problem. without having it exposed to the nedia, the public or the EPA. See the attached exhibit list to this memorandum for all the documents I obtained. 3?88? high; Regards dioxin as weakly carcinogenic, weakly mutagenic, very fetotoxic and teratogenic, that is with experimental animals; Frawley will testify to his knowledge of the extreme toxicity Harold Gill Richard Hickman of dioxin, his knowledge of the relationship between the manufacturers and the government, and that Hercules itself sold to the military in 1965 that contained an average of 3 dioxin; his knowledge of propensities of dioxin to inflict harm long prior to the March 24, 1965 meeting between manufacturers, and the fact that no one at Hercules, to his knowledge, informed the government of the risk involved. Manager, Operations, Analytical Laboratory, Dow Chemical, Midland, will testify concerning fact that he was advised in approximately August, 1964 that dioxin was contained in the was stream of TCP manufacturing process at Dow and in the Butyl esters of He developed Dow?s analytical method dated 12/22/64, for determining presence of dioxin in caustic insoluble of waste stream of process. Estimated time plaintiffs' examination less than 1/2 day; defendants' exmination unknown, but estimated at one hour or less. Route 4, No. 10 Yocum Road, Rogers, Arkansas, Dow?s former government sales manager, deposed 12/1/83, who, between 1963 and 1970 had eight men contacting government selling Dow's products will offer testimony concerning Dow's marketing efforts to sell herbicides to the government, his knowledge of dioxin, failure to warn the government; the Dow sales process and bids for government business; pricing procedure; Transcript of deposition V. A. 24 Benjamin B. Holder Harry Holland F. Gerard Vada Hukill John Jennings Lynne Keller Van A. Kelly Eugene R. Kenaga Dow employee re 70,11. 5203 Bloomfield St., Midland, Michigan; Dow's Medical Director; to testify as to knowledge of chloracne incidents at Dow before, during and after 1964; contentions re; notification of "appropriate? governmental officials; his opinion that there has not been demonstrated a "no minimum effect level" in dioxin exposure, and, adversely under cross, on causation theories; failure to warn; knowledge of toxicity of TCDD. 1604 Angus Court, Crafoward, Maryland; Friend of Lambiotte's; health and damages witness; testimony 1 hour total. 220 W. Tyler, Magnum, Danny Jordan's in-laws, will testify as to effect of Dan?s injuries and those of his children; approximate total testimony 2 hours. Apt.B, 12 Lansdowne Avenue, Lansdowne, Pa.,High School friend of George Ewalt who was in Vietnam at same time and knows his medical problems will testify to exposure on damages issues; total testimony 1 1/2 hours. 208 Brasewood, Austin, Tx 78704; Friend of Danny Jordan?s who will testify to health and damages issues; total length of testimony 1 1/2 hours. . Attempting to locate, in Philadelphia, Pa., was with Ewalt in Vietnam will testify concerning exposure and damage .issues; total estimated length of testimony 2 hours. 1281 N. Wagner Road, Essexville, Michigan; environmental persistence, toxicity; knowledge of dioxin and herbicides in the environment; failure to warn; V. A. 25 93? Taves, Milton Arthur Treisback, Arthur L. Leng, Marguerite as Director of Laboratories and Licensing; Ph. D. in chemistry; Director of Development from 1964 through mid-'70s. Will testify to his knowledge of and that it contained dioxin. Claims to have no knowledge of cooperation between Hercules and Dow re testing of dioxin; Examination by plaintiff, less than 1/2 day; examination by defendants brief, perhaps less that 1 hour. 210 N. Spring Road, Wilmington, Delaware; Personal services contract with Hercules; Organic chemist, Ph. research manager of research division for 16 years, beginning in 1964; The question of detecting and measuring the amount of dioxin in first came to his attention in March, 1965. He directed the work of John Ford. Never communicated with other companies or with the government regarding the dioxin contamination problem; will testify as to keeping the government ignorant of their own testing inadequacies which was to advantage of Hercules; knew that government did not know of dioxin and avoided telling them; Plaintiffs' examination approximately 1 hour; defendants examination estimated at 1/2 hour or less. 2502 Landon Drive, Chalfonte, Wilmington, Delaware; Deposition not yet completed and transcript not yet received. . Jacksonville, Arkansas Plant Manager for Hercules 1968-72; Chemical engineer; Testimony concerning Hercules' manufacture of Agent Orange, phenoxy herbicides, generally concerning his knowledge of dioxin, toxicity and health hazards; detection and reduction methods; sales to the government. 1714 SyiVan Lane, Midland, Michigan: Research Associate, Dow Chemical; Will testify concerning the V. A. 29 3a: Silverstein, Larry registration process and department at Dow; her responsibilities working with Donald D. McCollister, and what information the Company did and did not afford the Federal Government concerning the toxicity of herbicides and dioxin; Reference her deposition; stated in one document that ?our not informing the government is what got us into all this trouble in the first place." Total length of testimony less than 1/2 day. 5409 Mason Street, Midland, Michigan: Employed. by Dow in the capacity of an Industrial Hygienist from 1955 to 1979, when he left to become the Manager of Industrial Hygiene for Dow Corning Corporation; was an Industrial Hygienist that attended a great many "Exciter problem" meetings at Dow referrable to the dioxin contamination of the 199 building and the dioxin contamination of and Agent Orange; Was the author of numerous documents identified as exhibits including minutes of the March 24th, 1965 meeting at Dow among Industry representatives at which the toxicity of dioxin was discussed, a document entitled "Hazards of Monsanto T?acid" and others; plaintiffs believe Mr. Silverstein should be ordered produced as an employee in View of the substantial control and connection maintained over him by Dow as an owner of the Dow Corning Company, by whom Mr. Silverstein ,claims to be employed. Has substantial factual knowledge of the events of 1964,65 and beyond relative to health problems, the actions of the co-workers at Dow, and claimed contacts with governmental "authorities" in the form of State of Michigan officials, and alleged attendees at medical conferences at the University of Michigan from time to time. Total length of testimony 1/2 day. V. A. 30 Donald McCollister 5522 Whitehall Street, Midland, Michigan; now Director International Regulatory Affairs, Health and Environmental Sciences for Dow Chemical Company; has been employed by Dow since 1942 when he was hired as an organic chemist and was part of the Toxicology Research Laboratory until 1967 and thereafter dealt in the registration process with respect to the relevant herbicides; was the immediate supervisor of Ms. Marguerite Leng; has expertise in toxicology of herbicides and facts concerning what information was given to the United States Government from time to time; expected length of plaintiffs' examination is less than one half day . and expected length of defendants' examination less than one quarter day. - V. A. 31 DONALD HORNIG PAUL DOTY MELVIN CALVIN FRED FALANA CAPT. FARMER 16 LONGFELLOW PARK, CAMBRIDGE, MASS. Special Assistant to the President for Science and Technology and Director of the Office of Science and Technology in the Executive Office. Also Chairman of Federal Counsel for Science and Technology and Chairman of PSAC (1964-69). Did not understand health hazards of dioxin in the mid-60's. Not generally discussed. Whether this witness is produced live or through deposition excerpts awaits ruling of Court. 4 KIRKLAND DRIVE, CAMBRIDGE, MASS. Assigned to PSAC's Pesticide Panel and Chaired the Civil Defense Panel. From 1965 to 1970, was a consultant for arms control and disarmament to the National Security Counsel. Whether this witness is produced live or through deposition excerpts awaits ruling of Court. 2683 BUENA VISTA WAY, BERKELEY CALIF. Dow Chemical company Director who learned of dioxin in 1964 or 1965 at a Board of Directors' meeting. The subject was never discussed at PSAC, however. Whether this witness is produced live or through deposition excerpts awaits ruling of Court. Address to come; as a member of Danny Ford's unit, Fred Falana will testify to the various locations which their unit was assigned, including recently defoliated areas traveled to by vehicle and often by foot, as well as the conditions of their unit in these various locations in Vietnam. Less than 1/2 day total testimony. Address to come; Captain Farmer will testify to the assigned locations of Danny Ford's unit, including the defoliated areas V. A. 33 Plaintiffs respectfully submit the following list of be presented for the use of deposition testimony in conformity with paragraph of the Magistrate's Pre-trial Order No. 17. Graydon Holdeman 2006 Manor Drive, Midland, Michigan; retired employee, receives pension from Dow; last employed Feb. 28, 1977; plaintiffs' reserve the right to demand the production of this witness at trial; relevant testimony concerns the development of the product specifications for- the herbicides by Holdeman at Dow, the similarity between the so-called government specifications, the fact that industry actually developed the specifications for the basic herbicides; in the event the testimony is presented by deposition, transcript of Nov.30, 1983, (objections to be ruled upon). Lawrence Eugene Dotson c/o Foote Mineral Company, Kings Mountain, North Carolina (residence address not available through transcript); Lawrence Dotson was the Technical Services Engineer at Nitro from 1961 through 1965, and was the Production Supervisor, supervising the 2,4,5~ plant from 1965 through 1967. He was employed by Monsanto from 1958 through 1969. During the time that he Production Supervisor, responsible for production Yi\ 337 Never heard of anyone in Monsanto ever informing the Govt. up until 1970 of the potent' .5 1.0.4.. UL He proposed a program in 1965 to reduce the amount of dioxin in and this was tested in January of 1969. Dioxin is extremely toxic and he has felt that way since he first heard of dioxin. He wrote to certain personnel that dioxin was highly toxic, advised people to use extreme caution in handling it. Attended a meeting at Dow with Elmer Wheeler and John Mason in 1970. The meeting was concerned with dioxin and potential risk associated with dioxin and Dow's desire to have an industry effort to study the program. At a meeting in January of 1969 Udell acknowledgd that if you made the product safer and reduced the dioxin it would take longer to produce and Monsanto would get less of it. He said that the decreased production is the price that must be paid for the decreased dioxin conentration. Transcript of May 4, 1983; ,l .390 Charles P. Zorsch 3- 18- p97, 1110- 25- ,p98, 111-7&19- 25- l1-2&20- 23- ,p106; p101 111-15,p1 0 auw?I 1 1 3 119- 10&18- 22- ,p109, 111? ?21,p110, ,p112, 111 -487 ,p114, 112- 3&6- 10; l11?13&16, p116, 119- 25- p117- p11 7,p119m1?0, 111 -5 p122,1113-19- ,1114- 24p ,p129, 1113- 28- ,p130, 1114- 2 124, 1116- 24- ,p135, 112- 6 p137,1112- -p144, 125- p145, 111- 23- ,p146, 1120- 25 ;p147, 112- 16Ep150, 113- 23-p156 111-16 &20-p158, 1115- 20;p165, 112- 16- ,p167Route5 Box 30, Pacific, Missouri Born - April 20,1910 Employed by Monsanto for 21 years 1950-1971. He receives $288/month as a lifetime pension from Monsanto. He was Assistant Manager of Pesticides from1950-1960. Manager of Formulated Pesticides Sales, including and from 1960 - 1963. From 1963?1970 he was the Product Supervisor, Agricultural Division. He was supervisor of and sales. Never heard of chloracne problems at Nitro until latter 1960's. But never asked anyone either what happened at Nitro in 1948 or what the causes of the worker health problems were. Never knew what chloracne was at Monsanto for 20 years. It was Quality Control's obligation to inform a customer if any product that was sold contained a contaminant. Cecil Russell was his superior. Dr. Hoffman was the Manager of the Division. The sole products he was resonsibile for as product supervisor from 1963 to 1970 were and Quality Control was responsible for the quality of the product. New Agent Orange as being used in Vietnam and assumed U.S. Govt. was 329/ Ray D. Holmes employee; He also wanted to sell Tordon as opposed to Agent Orange for the reason that Tordon was a patented Dow product; Deposition transcript of Novwember 16, 1983; &11-12. 11021 Abbot Avenue, Sun City, Arizona: SuperviSor of Building 199 at Dow Chemical, Midland Michigan, from approximately 1938 to 1965, which manufactured sodium trichlorOphenate, a precursor chemical to 2,4,5?Trichlorophenol; he will testify as to the process used at Dow for manufacturing 2,4,S-Trichlorophenol,and to the certain manufacturing changes which took place at the Dow Chemical Company with regard to the TCP it produced; the changes increased the temperature and pressure of the reaction and, as a result, increased the amount of diosin in the waste stream and in the end product; Holmes will testify that he and others in the 199 building contracted chloracne and to the steps that were taken to sanitize the building after the contamination was discovered in 1964; excerpts from the deposition of March 23, 23?? Warren Crummett (D) William F. Falsey (D) George C. Kempson producing Orange and says perhaps he did see documents which indicated that. Russell was- "possibly? involved in writing the specifications. Acknowledges that Russell "perhaps he could have" indicated to him that Russell was so involved. Does not remember when he approved the specifications whether he compared the Government specifications and the Monsanto specifications. Doesn't recall whether the specifications call for production of dioxin. If he knew that following specifications would have produced an acutely toxic by-product, the production would not have been approved. Transcript of January 20, 1984: p.49 L. 6-25; p.46 L. L. 22-25; p.53 L. 1-16; p.54 L. 7-20; p.57 L. 3?25; p.58 L. 1-15; p.59 L. 12-25; p.60 L. 1-25; p.61 L. 1-2; p.61 L. 21-25; p.62 L. 1-5; p.63 L. 12?25; p.64 L. 1-25; p.65 L. 1-25; p.66 L. 1-23; p.67 L. 6-25; p.68 L. 1-25; p.69 L. 1-25; p.70 L. 1-24; p.72 L. 13-25; p.73 L. 1?25; p.74 L. 1-25; p.75 L. 1-25; p.76 L. 1-25; p.77 L. 21-25; p.78 L. 1-25; p.79 L. 1-4; p.81 L. 15?25; p.82 L. 2-25; p.83 L. 1-25; p.84 1?24; p.86 L. 1-25; p.87 L. 1-25; p.88 L. 1-25; .99 L. 9-18; p.101 L. 2?22; p.103 . 19-25; p.104 L. 1-25; p.105 L. -8. 808 Crescent Drive, Midland, Michigan; Dow scientist; evidence concerning Dow liability issues. Time constraints have made it impossible to abstract the deposition of Mr. Crummett; Leave is asked to include excerpts in amended Pretrial Order. 6706 Lakeview Drive, Lake City, Michigan; Time constraints have made it impossible to abstract the deposition of Mr. Falsey; Leave is asked to include excerpts in amended Pretrial Order. 143 South Gore, Webster Groves, 3?73 William Ralph Nummy work for our department." Job was to try to develop new areas of government business, and did so. Aware of the manufacture and develOpment of Involved in testing of for brush control purposes. Claims not to have been aware of dioxin, and attended meetings with government representatives during relevant periods; Traveled to Washington, D.C., Edgewood Arsenal and Saigon regarding government's use of defoliants, and recommended use of Tordon to Believed Tordon less toxic than Never told any government employee about health problems among workers at Dow in the plant; Excerpts of the transcript of December 13, 1983, include p. p.13, 15 LL4-22, p. 5, p.22, p. 23, p. p.25, p.26, p.28, p. 1-25; p.31, p.34, p.36, 711 West Meadowbrook Drive, Midland, Michigan; former employee of Dow, now works for a company known as Doan Resources Company; worked for Dow Chemical for over 30 years, leaving as Vice-President of Merrell Dow .Laboratories in Cincinnati; Excerpts from the deposition of October 28, 1983 that may be used include; p.7, 1-25; p. 10, p. 16, LL 13-251-15; p.27, p.28, LL 1-25; p. 29, LL p.30, p.33, p.34 LL 9?13&17?18; p. 44, p. 45, LL11-14, 16-191?15, 25; p.49, LL 1?25; p. 50, LL 1?12 16-25; p. 51, LL 1?10 13,24,25; p. 1?14Melvin Calvin 56, all; 57, all; 58, all; 59, all; 60, 1-16; 61, 5?8; 63, 12?25; 64, 1-22; 65, 15-25; 67, 23?4; 68, 1?2, 24525; 69, all; 70, 1-11; 81, 9-17; 132, 8?24; 134, 1-25; 135, 1-25; 136, all; 137, all; 138,_all; 139, 1-15. 2683 Buena Vista Way, Berkeley, CA. Deposed on November 9, 1983, and December 2, 1983. A Nobel-Prize winning chemist who was both a member of PSAC from 1963-66, and a member of the Dow Board of Directors from 1964-75. As a member of the Dow Board he was informed in 1964-65 that dioxin was in the Dow However, never revealed this information to PSAC since he was never asked. 25, 3?25; 28, 16-25; 29, 1-25; 30, 1-22; 38, 7-25; 39, all; 40, all; 45, 46, 20-25; 47, 1-7; 49, 18?25; 50, all; 51, all; 52-54, all; 55, 1-20; 67, all; 68, 1-9; 84, 10?25; 85, 1-16; 89, 9-20; 93, 10?13, 19-25; 98, 14-22; 99, 21-25; 100, 2-22; 101, 8-11; 118, 17-25; 119, 3-25; 122, 18?22; 128, 16-22; p130, 8-19, 25; 131, 1-16, 19-25; 133, 18-21, 23?25; 134, 18-25; 135, 1?5; 143, 2?7; 164, 15-25; 168, 19-25; 169, all; 170, 1-2; 173, 9-25. ?Treating Physicians of Plaintiffs: Dr. Dr. Dr. Dr. Dr. Gianferro El Child George Wilson ?Joan Hurlock Salkind Treating physician for George Ewalt Treating physician for George Ewalt II II II Locations-of 'Hajor Producers of Chlorophenols and Their Derivatives CHEMICAL PRODUCER acid and esters Alco Chem. Corp., Philadelphia, 'Amvac?Chem. Corp., Los Angcles, CA Chempar, Portland, OR 'Diamond Shamrock Corp., Tuscaloosa, AL Cleveland, OH 'Dow Chemical, U. S. A., Midland, HI Fallek-Lankro Corp., Tuscaloosa, AL GAP, Linden, NJ 'Guth Corp.,- Hillside, IL Hercules, I'nc., Jacksonville, AR Imperial, Inc., Shenandoah, IA Miller Chem., Whiteford, MD Monsanto, Co., Sauget, 11. North American Phillips Corp., Kansas City, KS 'PBI-Gordon Corp., Kansas City, KS Rhodia, Inc., Portland, OR St. Paul, MN St. Joseph, MO 'Rhone?Poulenc, Inc., Portland, OR 'Riverdale Chem. Co., Chicago Heights, IL Rorer-Amchem, Fremont, CA St. Joseph, MO Thompson Chemical, St. Louis, HO Union Carbide Corp., Ambler, PA 'Velsicol Chem. Corp., Beaumont, TX Bayport, TX Vertac, Inc., Jacksonville, AR Hoodbury, Orlando, FL I, If 2,14,5-1? Chempar, Portland, OR Diamond Shamrock, Cleveland, OH IDow Chem., 0.8. 11., Midland, MI Hoffman-Taft, Inc., Springfield, HO Monsanto Co., Sauget, IL North American Phillips Corp., Kansas City, Ks PEI-Gordon Corp., Kansas City, KS Rhodia Inc., Portland, OR St. Joseph, MO 'Riverdale Chem, Co., Chicago Heights,n. Rorer-Amchem, Ambler, PA Fremont, CA St. Joseph, HO Jacksonville, AR u-9 3% IABLE 4-2 (cont.) CHEMICAL PRODUCER 3, It, (cont .) Libs-T derivatives Silvex esters and salts Ronnet Erbon 'HexachlorOphene and salts 2,3,9,6-tetrachlorophenol PCP and salts Thompson Chem., St. Louis, HO Union Carbide Corp., Fremont, CA St. Joseph, HO Ambler, PA Vertac, Inc., Jacksonville, AR 'Dow Chem. U.S.A., Midland, MI Hercules, Inc., Jacksonville, AR North American Phillips Corp., Kansas 'Riverdale Chem. Co., Chicago Hts., IL Vertac, Inc., Jacksonville, AR 'Dow Chem. U.S.A., Midland, HI 'Dw Chem. U.S.A., Midland, HI Givaudan Cgp? Clifton, NJ Diamond Shamrock Corp., Cleveland, OH Dow Chemical, U.S.A., Midland, MI GAP Corp., Linden, NJ Hercules, Inc., Jacksonville, AR Hooker Chem., Niagara Falls, NY Merck and Co., Inc., Rahaay, NJ Halco Chem. Co., Chicago, 11. north Eastern Pharmaceuticals, Verona, HO Roberts Chem., Inc., Hitro, UV Rhodia, Inc., Monmouth Junction, NJ Vertac, Inc., Jacksonville, AR City, KS 'Dou Chem. U.S.A., Midland, MI Sanford Chem, Port Neches, TX J.E. Baxter and Co., San Mateo, CA Dow Chem. U.S.A., Midland, MI ICC Industries, Inc., Dover, 0H Monsanto Co., Sauget, IL Ralco Chem. Co., Chicago, 11. 'Reichhold Chem, Inc., Tacoma, WA Sanford Chem., Port Reches, TX ?Vulcan Materials Co., Wichita, KS :Sources: Esposito at al., 1980; sax, 1982; U.S.I.T.C., 1982 Company name: indicated with an asterisk are the major producer: of chlorophenols and their derivatives at the present time. 14-10 #31- IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR ORANGE CASE NO: CI 89-8657 DIVISION: 32 PFEIFFER ROBERT w. MOYER, II and KIM MOYER, his wife, Plaintiffs, vs. DOW CHEMICAL COMPANY, et al., Defendants. THE DOW CHEMICAL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS TO ALL DEFENDANTS 1. If you supplied any Diquat, Hydrothal or Silvex to Orange County during the years 1974 through 1977, please produce the following: a. All documents pertaining to your purchase of said chemicals from the manufacturer or intermediate supplier; b. All invoices for said chemicals; c. All correspondence between the manufacturer and your company; d. All documents pertaining to your sale of said chemicals to Orange County, Florida; e. Any complaints received by you regarding the above chemicals, or any documents evidencing any dissatisfaction in any way whatsoever with the above chemicals: f. All documents forwarded to you by the manufacturer regarding the above chemicals, the use of such chemicals, the application of such chemicals, the warnings on such chemicals, or related to any defects in such chemicals that were sent to you at any time whatsoever and not limited to the four (4) years set forth above: g. any manuals, instruction sheets, informational sheets, labels or other documents pertaining to the use, application, effectiveness, instructions, or composition of said chemicals. ANSWER: The Dow Chemical Company objects to this request on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence to the extent that it seeks information concerning which plaintiff has not alleged that he was exposed to or injured from in his complaint and to the extent it requests information about Diquat and Hydrothal, which Dow never manufactured. Without waiving these objections, Dow states that it does not have any records indicating it sold products to Orange County during the years 1974?1977. 2. If you are a manufacturer as opposed to a supplier, please produce the following for the years 1974 through 1977 pertaining to Diquat, Silvex or Hydrothal: a. All documents pertaining to your manufacturing of said chemicals; ANSWER: Dow objects to this request on the grounds that it is vague, ambiguous, irrelevant, overly broad and unduly burdensome. b. All invoices or documents pertaining to the sale of said chemicals; ANSWER: Dow objects to this request on the grounds that it is irrelevant, ambiguous, overly broad, unduly burdensome and is not limited to geographical location. Without waiving this objection, Dow refers the plaintiffs to its Response to Request No. l. c. All correspondence between the supplier or your wholesaler and your company; ANSWER: Dow sold its products to a large number of independent wholesalers and distributors throughout the country during the time period in question. Therefore, Dow objects to this request on the grounds that it is irrelevant, immaterial, overly broad and unduly burdensome. d. All documents pertaining to your sale of said chemical to your supplier or wholesaler or other entity; ANSWER: See reSponse to Request 2c. e. Any complaints received by you regarding the above chemicals or any documents evidencing any dissatisfaction in any way whatsoever with the above chemicals; ANSWER: See Dow?s Response to Plaintiffs? Request for the Production of Documents to Dow, Number 25. f. All documents forwarded by you dealing with the application of said chemicals, the warnings on such chemicals, or relating to any defects in such chemicals or the use of such chemicals that were sent out at any time whatsoever and not limited to the four years set forth above; ANSWER: See Dow?s Response to Plaintiffs? Request for the Production of Documents to Dow, Number 21. g. Any manuals, instruction sheets, informational sheets, labels, or other documents pertaining to the use, application, effectiveness, instructions or composition of said chemicals. ANSWER: See Dow?s Response to Plaintiffs? Request for the Production of Documents to Dow, Nos. 21 and 22. ?7?00 Dated: Uniondale, May 29, New York 1990 Respectfully submitted, RIVKIN, RADLER, BAYH, HART KREMER By: 604/ 0,41% g??J.r1Etego anleyl ierce EAB Plaza Uniondale, NY 11556?0111 (516) 357-3000 CARLTON, FIELDS, WARD, EMMANUEL, SMITH CUTLER, P.A. By: Daniel C. Johnson 1601 CNA Tower Post Office Box 1171 Orlando, FL.32802 (407) 849?0300 DOWELANCO By: David G. Wilkins Quad Three 9001 Wessleyan Avenue Suite 300, Third Floor Indianapolis, IN 46268 Jim IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR PALM BEACH COUNTY. CASE NO. CL89-97-AD ROBERT W. MOYER, II and KIM MOYER, his wife, Plaintiffs, vs. DOW CHEMICAL COMPANY, CHEVRON CHEMICAL COMPANY ORTHO AGRICULTURAL CHEMICALS DIVISION, AGCHEM DIVISION - PENNWALT CORPORATION, HELENA CHEMICAL COMPANY SOUTHERN MILL CREEK PRODUCTS CO., INC., THE UPJOHN COMPANY, ASGROW FLORIDA COMPANY, a subsidiary of the UPJOHN COMPANY, WOODBURY CHEMICAL COMPANY, FUTURE HORIZONS, INC., LANDIA CHEMICAL CO., JLB INTERNATIONAL CHEMICAL, INC., THE MONSANTO COMPANY, DIAMOND SHAMROCK, INC., Defendants. THE DOW CHEMICAL RESPONSE TO FIRST SET OF INTERROGATORIES TO DOW General Obiections The Dow Chemical Company objects to each interrogatory to the extent it seeks information regarding since plaintiffs? complaint does not allege exposure to that chemical. Dow also objects to each interrogatory to the extent it requests information relating to products which Dow never manufactured, specifically Diquat and Hydrothal. ?Li/70? Kl, 403 1. Please give the name, official position, address, duties and responsibilities, and longevity with the company of the person or persons answering these interrogatories, ANSWER: David G. Wilkins Attorney DOWELANCO Indianapolis, Indiana 2. Has Dow Chemical Company ever manufactured Hydrothal, Silvex or Diquat? If so, please state the following: ANSWER: See General Objections. Without waiving that objection, Dow states that it has manufactured and Silvex products. A. Over what period of time and at what location or locations? Dow objects to this interrogatory on the grounds that it is not reasonably calculated to lead to admissible evidence since the manufacturing location is irrelevant and because it is not limited to a relevant time period. Without waiving these objections, Dow states that it manufactured and SilveX during the 1974-77 time period. B. Were any of these chemicals ever sold to Orange County, Florida, and if so, please list the dates, quantities sold, and prices of sale. Dow objects to this interrogatory on the grounds that it is overly broad in that it is not limited to the relevant time period. Without waiving this objection, Dow states that it has no record of having sold any of the listed chemicals/products to Orange County during the years 1974?77. C. If you did not sell directly to-Orange County, Florida, have you sold any one or all of these chemicals to any retailers or wholesalers located 403 within the State of Florida and, if so, please list the names, dates, and quantities of sale. Dow objects to this interrogatory on the grounds it is overly broad and unduly burdensome and is not limited to a relevant time period. 3. If you have not manufactured Silvex, Hydrothal, or Diquat, did you ever purchase any of those chemicals for resale? A. From whom did you purchase these chemicals, giving names of the manufacturer, names of any intermediate supplier, dates of acquisition, amounts purchased, and cost. B. Did you ever sell said chemicals directly to Orange County, Florida and, if so, give dates of sale, amount of chemical sold, and price of sale. C. Have you ever sold these chemicals to any other supplier or wholesaler who in turn furnished these chemicals to Orange County, Florida? If so, please state the names of the companies, the amount of chemicals sold, the dates of sale, and the dollar value of sales. ANSWER: Dow is unaware of ever having purchased Hydrothal or Diquat for purposes of resale. 4. Have you ever published or printed any warnings regarding the use or application of the chemicals Silvex, Hydrothal and Diquat? If so, please attach copies of said warnings to these Answers to Interrogatories. ANSWER: Dow objects to this interrogatory on the grounds that it is overly broad and unduly burdensome and is not limited to a relevant time period. Dow further objects on the grounds that plaintiffs have not identified any specific Dow product or Silvex product upon which Dow can respond. Dow reserves the right H04 to supplement these responses when and if plaintiffs identify specific Dow products. 5. Please identify each and every claim, lawsuit and/or dispute in which you have been involved concerning the above chemicals since the year 1967. a. Please state the caption of every claim, lawsuit and/or dispute listed in the above question along with the case number; b. Please state where every claim, lawsuit and/or dispute listed above was filed and the date it was- filed. ANSWER: Dow objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, is not limited to a relevant time period and is not reasonably calculated to lead to the discovery of admissible evidence. Dow further objects to this interrogatory to the extent it seeks information concerning chemicals and/or products not manufactured by Dow. 6. Please identify each and every expert witness used in any prior lawsuit who has given either deposition or trial testimony involving the chemicals Diquat, Silvex and Hydrothal, including their name, address and telephone number. ANSWER: Dow objects to this interrogatory on the grounds that it is irrelevant, immaterial, overly broad, unduly burdensome, is not limited to a relevant time period, is unintelligible and is not reasonably calculated to lead to the discovery of admissible. evidence. Dow further objects to this interrogatory to the extent it seeks information concerning chemicals and/or products not manufactured by Dow. 1/052 7. Please identify by name, position, address, telephone number, and length of time of service with your company the following: a. Each and every person who has ever testified on behalf of your company while an employee with you in any case involving a claim of defect or any other problem with Silvex, or Diquat. Testimony means by way of deposition or trial testimony. ANSWER: See response to Interrogatory No. 6. Dated: Uniondale, New York May 29, 1990 Respectfully submitted, RIVKIN, RADLER, BAYH, HART KREMER By: anley?Pierce EAB Plaza Uniondale, NY 11556-0111 (516) 357-3000 CARLTON, FIELDS, WARD, EMMANUEL, SMITH CUTLER, P.A. By: Daniel C. Johnson 1601 CNA Tower Post Office BOX 1171 Orlando, FL 32802 (407) 849-0300 DOWELANCO By: David G. Wilkins Quad Three 9001 Wessleyan Avenue Suite 300, Third Floor Indianapolis, IN 46268 . I IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR ORANGE COUNTY. CASE NO: CI 89-8657 DIVISION: 32 PFEIFFER ROBERT W. MOYER, II and KIM MOYER, his wife, Plaintiffs, vs. DOW CHEMICAL COMPANY, et al., Defendants. THE DOW CHEMICAL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS TO CHEMICAL COMPANY General Objections The Dow Chemical Company objects to each of plaintiffs? requests for production of documents to the extent it seeks documents or information related to products which Dow never manufactured, specifically Diquat and Hydrothal. Dow also objects to each request to the extent it seeks information regarding on the grounds that plaintiffs? complaint does not allege that plaintiff was exposed to or injured by 1. Any and all letters, memoranda, documents or writings of any character made by DOW CHEMICAL COMPANY toxicologists or other employees relating to any toxicological organic chemical research, inquiries, investigations or studies in connection with the formation and/or manufacturing of Silvex, Hydrothal, Diquat or prior to 1978. ANSWER: Dow objects to this request on the grounds that it is vague, ambiguous, overly broad, unduly burdensome and is not limited to a relevant time period. 2. Any and all letters, memoranda, or other documents related to any organic chemical research, study or experiments with chlorinated Xanthones or chlorinated Phenols prior to 1978. ANSWER: Dow objects to this request on the grounds that it is overly broad, vague, ambiguous, not understandable, unduly burdensome, not limited to a relevant time period and is not reasonably calculated to lead to the discovery of admissible evidence. 3. Any and all letters, memoranda, reports or other documents regarding any study done in connection with DOW CHEMICAL COMPANY workers who used or were exposed to DOW CHEMICAL Hydrothal, Diquat, or Silvex prior to 1978. ANSWER: Dow objects to this request on the grounds that it is irrelevant, immaterial, overly broad, unduly burdensome, not limited to a relevant time period and is not reasonably calculated to lead to the discovery of admissible evidence. 4. Any and all letters, memoranda, reports or other documents relating to any study done by Dr. Holder or other -2- 405/ physicians or toxicologists in connection with DOW CHEMICAL COMPANY workers who used or were exposed to DOW CHEMICAL Hydrothal, Diquat or Silvex between 1967 to the present. ANSWER: Dow objects to this request on the grounds that it is irrelevant, overly broad, unduly burdensome and not confined to a relevant time period. Without waiving these objections, Dow is unaware of any studies by Dr. Holder currently in its possession which are responsive to this request and which pertain to the products involved in this case. 5. Any documents relating to or referring to the identity, occurrence, concentration, or potential toxicity of any contaminants or impurities that may have been present in DOW CHEMICAL products, products, Silvex products, Hydrothal products, or Diquat products or in DOW CHEMICAL acid raw material, raw material, Diquat raw material, Hydrothal raw material or Silvex raw material, from 1967 to present. ANSWER: Dow objects to this request on the grounds that it is overly broad, vague, ambiguous, not confined to a relevant time period, uses undefined terms, is unduly burdensome and is not calculated to lead to the discovery of admissible evidence because plaintiffs have no means of showing that the Dow product(s) the plaintiff was allegedly exposed to, if any, contained contaminants or impurities. 40? 6. Any documents relating to or referring to the identity, occurrence, concentration, or potential toxicity of any contaminants or impurities that may have been present in DOW CHEMICAL products, products, Hydrothal products, Diquat products or Silvex products or raw materials from 1967 to the present. ANSWER: See Dow?s Response to Request No. 5. 7. All of DOW CHEMICAL COMPANY Toxicology files relating to Hydrothal, Diquat and Silvex, between 1967 and the present. ANSWER: Dow objects to this request on the grounds that it is overly broad and unduly burdensome and not confined to a relevant time period. 8. Any and all letters, memoranda, reports or other documents resulting from research, inquiries, investigations or studies, which reveal contaminants or impurities in DOW CHEMICAL Hydrothal, Diquat or Silvex which occurred during the manufacturing or other process between 1967 and 1977. ANSWER: ee Dow?s Response to Request No. 5. 9. Any and all letters, memoranda, reports or other documents in connection with DOW CHEMICAL 4/0 2,4,5eT, Hydrothal, Diquat or Silvex which relate to impurities in the manufacturing or other process which impurities include but are not limited to aromatic hydrocarbons and hydrocarbon impurities including but not limited to 2,3,7,8, Tetrachlora Xanthone during the years 1967 and 1977. ANSWER: Dow objects to this request on the grounds that it is overly broad, vague, ambiguous, unintelligible, not confined to a relevant time period and unduly burdensome. 10. Any and all letters, memoranda, reports or other documents in connection with Xancene compound which is part of DOW CHEMICAL Hydrothal, Diquat or Silvex between 1967 and 1977. ANSWER: Dow objects to this request on the grounds that it is overly broad, vague, ambiguous, unintelligible, not confined to a relevant time period and unduly burdensome. 11. Any and all letters, memoranda, reports or other documents in connection with research, inquiries, investigations or studies relating to the presence in DOW CHEMICAL 2,4? D, Hydrothal, Diquat and/or Silvex of the substance Octochloro Xanthone between 1967 and 1977. ANSWER: Dow objects to this request on the grounds that it is overly broad, vague, ambiguous, unintelligible, not confined to a relevant time period and unduly burdensome. 12. Any and all letters, memoranda, reports or other documents relating to the presen-e of any carcinogen i1 DOW CHEMICAL Hydrothal, Diquat and Silvex between 1967 and 1977. ANSWER: Dow objects to this request on the grounds that it is overly broad, vague, ambiguous, not confined to a relevant time period and unduly burdensome. Dow further objects on the grounds that it makes the assumption that Dow?s products are or contain carcinogens, which Dow denies. 13. Any and all letters, memoranda, reports or other documents relating to any carcinogenic effect or propensity in DOW CHEMICAL Hydrothal, Diquat or Silvex between 1967 and 1977. ANSWER: Dow objects to this request on the grounds that it is overly broad, vague, ambiguous, not confined to a relevant time period and unduly burdensome. Dow further objects on the grounds that it makes the assumption that Dow?s products are or contain carcinogens, which Dow denies. 14. That certain report, document or writing made by or to a Mr. K.L. Krummel relating to organic chemical research, inquiries or investigations in connection with the formation of and/or manufacturing of dated approximately October 27, 1978. ANSWER: Dow objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. 15. That certain report, document or writing made by or to a Mr. K.L. Krummel relating to organic chemical research, inquiries or investigations in connection with the formation of and/or manufacturing of dated approximately 1978. ANSWER: See Dow?s Response to Request No. 14. 16. Any and all letters, memoranda, documents or writings of any character pertaining to the sale of Hydrothal, Diquat or Silvex to any supplier supplying Orange County, Florida, during the years 1974, 1975, 1976 and 1977. ANSWER: Dow objects to this request on the grounds that it is overly broad, vague, ambiguous and unduly burdensome. Dow further objects on the grounds that Dow is unaware of the names of persons or entities who purchased Dow?s products from independent retailers and wholesalers and cannot respond to the request as phrased. Dow does not have any records in its possession which indicate that Dow sold or Silvex directly to Orange County for the years indicated. 17. All invoices for purchase of said chemicals listed above. ANSWER: See Dow?s Response to Request No. 16. -7- 4/3 18. All correspondence between the manufacturer and your company for the chemicals listed above. ANSWER: This request is not applicable to Dow. 19. All documents pertaining to your sale of the said chemicals to Orange County, Florida. ANSWER: See Dow?s Response to Request No. 16. 20. Any complaints, correspondence or documents of any kind received by DOW CHEMICAL COMPANY regarding Hydrothal, Diquat or Silvex or any documents evidencing any dissatisfaction in any way whatsoever with the above chemicals. ANSWER: See Dow?s Response to Request No. 16. Dow further objects on the grounds it is not limited to a relevant time period. 21. All documents which you forwarded to any wholesaler, supplier or purchaser of Hydrothal, Diquat or Silvex regarding the use of such chemicals, the appliCation of such chemicals, the warnings on such chemicals, the labels on such chemicals, or related to any defects in such chemicals that were sent out at any time whatsoever and not limited to the four (4) years set forth above. ANSWER: Dow objects to the request on the grounds that it is overly broad and unduly burdensome, vague, ambiguous and not limited to a relevant time period. Dow further objects on the 41? grounds that plaintiffs have not identified any specific Dow product or Silvex product upon which Dow can respond. Dow reserves the right to supplement these responses when and if plaintiffs identify specific Dow products. 22. Any and all manuals, instruction sheets, informational sheets, labels, or any documents pertaining to the use, application, effectiveness, instructions or composition of Hydrothal, Diquat and Silvex. ANSWER: See Dow?s Response to Request No. 21. 23. A list of all employees with names, addresses and telephone numbers who were involved in the manufacturing, distribution or management of the division manufacturing Hydrothal, Diquat and Silvex during the years 1967 through 1977. ANSWER: Dow objects to this request on the grounds that it is irrelevant, overly broad, unduly burdensome and not reasonably calculated to lead to admissible evidence. Without waiving these objections, Dow states that Robert Flannery was involved in the sale of Dow?s and Silvex products during the years 1974* 1977. 24. Any flow charts, diagrams, or systematic representations of the chain of authority or command for the division or section of the division or section of the company responsible for the manufacturing, distribution or had other responsibility with regard to Hydrothal, Diquat and Silvex. ANSWER: Dow objects to this request on the grounds that it is irrelevant, overly broad and unduly burdensome, not limited to a relevant time period and is not reasonably calculated to lead to the discovery of admissible evidence. 25. Any computer lists, letters, memoranda, documents or writings of any character evidencing a list of each and every claim, lawsuit and/or dispute in which DOW CHEMICAL COMPANY has been involved regarding Hydrothal, Diquat and Silvex listing the following: a. Please list the caption of every claim, lawsuit and/or dispute as well as the case number requested in this request. b. Please provide a list that indicates where every claim, lawsuit and/or dispute was filed and the date it was filed. ANSWER: Dow objects to this request on the grounds that it is irrelevant, immaterial, vague, overly broad, unduly burdensome and is not limited to a relevant time period or factual scenarios to cases involving allegations similar to those of the plaintiffs herein. Without waiving these objections, Dow is currently compiling a list of lawsuits brought between 1974 and 1977 in which Dow was named by the plaintiff as a manufacturer of or Silvex and in which the plaintiffs allegedly experienced a soft tissue sarcoma due to exposure to Dow?s product. Dow will produce this list to the plaintiffs in the near future. Dated: Uniondale, New York May 29, 1990 Respectfully submitted, RIVKIN, RADLER, BAYH, HART KREMER KM By: Jpseph J. LOrtego StanleyP Lerce EAB Plaza Uniondale, NY 11556?0111 (516) 357-3000 CARLTON, FIELDS, WARD, EMMANUEL, SMITH CUTLER, P.A. By: Daniel C. Johnson 1601 CNA Tower Post Office Box 1171 Orlando, FL 32802 (407) 849-0300 DOWELANCO By: David G. Wilkins Quad Three 9001 Wessleyan Avenue Suite 300, Third Floor Indianapolis, IN 46268 4/4 es? 191??) ROBERT W. MOYER, II and KIM MOYER, his wife, Plaintiffs, vs. DOW CHEMICAL COMPANY, et al., Defendants. IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND ORANGE COUNTY, CASE NO. CI 89 8657 OCCIDENTAL CHEMICAL OF FILING RESPONSE TO FIRST SET OF INTERROGATORIES DIRECTED TO OCCIDENTAL Defendant, OCCIDENTAL CHEMICAL CORPORATION through its undersigned counsel, hereby notifies all counsel of record of filing its Response to Plaintiffs' First Set of Interrogatories directed to Occidental served contemporaneously herewith. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail this gird day of August, 1990 to all counsel on the attached service list. RIVKIN, RADLER, KREMER, P.A. Joseph J. Ortego, Stanley Pierce, .EAB Plaza Esquire Esquire Uniondale, 11556?0111 CARLTON, FIELDS, WARD, SMITH CUTLER, P.A. Post Office Box 1171 Orlando, (407) 849?0300 Attorneys for Defendant OCCIDENTAL CHEMICAL CORPORATION By: ?74k3\ Florida 32802 Daniel C. Johnson Florida Bar No. 522880 EMMANUEL, HM, LIST OF COUNSEL Roger Lutz, Esquire Holland Knight, P.A. Post Office Box 1526 Orlando, Florida 32802 Daniel J. McGrath, Esquire Popham, Haik, et al. 4100 One Centrust Finan. Ctr. 100 SE 2nd Street Miami, FL 33131 Ronald L. Harrop, Esquire Gurney Handley, P.A. Post Office Box 1273 Orlando, FL 32802 Joseph J. Ortego, Esquire Rivkin, Radler, et al. EAB Plaza Uniondale, NY 11556?0111 Richard D. Schuler, Esquire Schuler, Wilkerson Halvorson, Suite Barristers' Building 1615 Forum Place West Palm Beach, FL 33401 Sheila DeCiccio, Esquire Lowndes, Drosdick, et al. Post Office Box 2809 Orlando, FL 32802 David S. Batcheller, Esquire Kelley Drye Warrent 2400 Miami Center 100 Chopin Plaza Miami, FL 33131 Stephen W. Beik, Esquire Hannah, Marsee, et al. 225 E. Robinson Street Suite 505, Landmark Ctr. II Orlando, FL 32801?4303 Kathleen L. Petrilli, Esquire Legal Dept. - Pennwalt Corp. Three Parkway - Pennwalt Bldg. Philadelphia, PA '19102 P.A. d?r? IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA CASE NO. CI 89 8657 ROBERT w. MOYER, II and - A KIM MOYER, his wife, Plaintiffs, vs. DOW CHEMICAL COMPANY, CHEVRON CHEMICAL COMPANY ORTHO AGRICULTURAL CHEMICALS DIVISION, AGCHEM DIVISION PENNWALT CORPORATION, HELENA CHEMICAL COMPANY SOUTHERN MILL CREEK PRODUCTS CO., INC., THE UNJOHN COMPANY, ASGROW FLORIDA, a subsidiary of the UPJOHN COMPANY, WOODBURY CHEMICAL COMPANY, FUTURE HORIZONS, INC., LANDIA CHEMICAL CO., JLB INTERNATIONAL CHEMICAL, INC., THE MONSANTO COMPANY, DIAMOND SHAMROCK, INC., Defendants. OCCIDENTAL CHEMICAL RESPONSE TO FIRST SET OF INTERROGATORIES TO OCCIDENTAL GENERAL OBJECTIONS Occidental Chemical Corporation objects to each interrogatory to the extent it seek information regarding since Plaintiffs' Complaint does not allege exposure to that chemical. OCC also objects to each interrogatory to the extent it requests information relating to products which OCC never 4A0 manufactured or resold, specifically, Silvex; Diquat: an Hydrothal. 1 1. Please give the name, official position, address, duties and responsibilities, and longevity with the company of the person or persons answering these interrogatories. ANSWER: John Endicott Attorney in Fact for Occidental Chemical Corporation Dallas, Texas 2. Has Occidental Chemical Company ever manufactured Hydrothal, Silvex or Diquat? If so, please state the following: ANSWER: See General Objections. OCC also objects to this interrogatory to the extent it seeks information concerning products manufactured prior to 1974 or after 1977. Without waiving these objections, OCC states that it did not manufacture during the years 1974?1977. A. Over what period of time and at what location or locations? ANSWER: OCC objects to this interrogatory on the grounds that it is not reasonably calculated to lead to admissible evidence since the manufacturing location is irrelevant and because it is not limited to a relevant time period. Without waiving these objections, see above. B. Were any of these chemicals ever sold to Orange County, Florida, and if so, please list the dates, quantities sold, and prices of sale. #94 OCC objects to this interrogatory on the grounds that itt is overly broad in that it is not limited to the relevant time period. Without waiving these objections, see above. 3i C. If you did not sell directly to Orange County, Florida, have you sold any one or all of these chemicals to any retailers or wholesalers located within the State of Florida and, if so, please list the names, dates, and quantities of sale. 2 ANSWER: OCC objects to this interrogatory on the grounds it is overly broad and unduly burdensome and is not limited to a relevant time period. Without waiving-these objections, see above. 3. If you have not manufactured Silvex, Hydrothal, or Diquat, did you ever purchase any of those chemicals for resale? ANSWER: See General Objections. OCC also objects to this interrogatory to the extent it seeks information concerning products manufactured prior to 1974 or after 1977. Without waiving these objections, OCC states that during the years 1974? 1977 OCC entered into an operating and management agreement with Chemical Land of New Jersey. Under that agreement, Chemical Land manufactured which was sold or shipped to other companies who used that to produce final products bearing OCC's name. Additionally, OCC's predecessor, Diamond Shamrock Corp., sold products containing during the years 1974?1977. A. From whom did you purchase these chemicals, giving names of the manufacturer, names of any intermediate supplier, dates of acquisition, amounts purchased, and cost. AHEHEB: See General Objections. OCC also objects to this. interrogatory to the extent it seeks information concerning products manufactured prior to 1974 or after 1977. Without ii waiving these objections, OCC states that it will attempt to determine the source of the chemicals if and when plaintiff specifies a particular OCC product to which he alleges exposure.4 B. Did you ever sell said chemicals directly to Orange County, Florida and, if so, give dates of sale, amount of chemical sold, and price of sale." ANSWER: See General Objections. OCC also objects to this interrogatory to the extent it seeks information concerning products manufactured prior to 1974 or after 1977. Without waiving these objections, and after a diligent search, OCC states that it is unaware of any records in its possession regarding sales of this product to Orange County. C. Have you ever sold these chemicals to any other supplier or wholesaler who in turn furnished these chemicals to Orange County, Florida? If so, please state the names of the companies, the amount of chemicals sold, the dates of sale, and the dollar value of sales. ANSWER: See OCC's response to Interrogatory No. BB. 4. Have you ever published or printed any warnings regarding the use or application of the chemicals Silvex, Hydrothal and Diquat? If so, please attach copies of said warnings to these Answers to Interrogatories. ANSWER: OCC objects to this interrogatory on the grounds that it is overly broad and unduly burdensome and is not limited to a relevant time period. OCC further objects on the grounds that 4&3 plaintiffs have not identified any specific OCC product upon which OCC can base a response. Without waiving these objections, OCC reserves the right to supplement these responses when and if plaintiffs identify a specific OCC product. 5. Please identify each and every claim, lawsuit and/or dispute in which you have been involved concerning the above chemicals since the year 1967. a. Please state the caption of every claim, lawsuit- and/or dispute listed in the above question along with the case number; b. Please state where every claim, lawsuit and/or dispute listed above was filed and the date it was. filed. ANSWER: OCC objects to this interrogatory on the grounds that it is overly broad and unduly burdensome and is not limited to a relevant time period. OCC further objects on the grounds that plaintiffs have not identified any specific OCC product upon which OCC can base a response. Without waiving these objections, OCC reserves the right to supplement these responses when and if plaintiffs identify a specific OCC product. 6. Please identify each and every expert witness used in any prior lawsuit who has given either deposition or trial testimony involving the chemicals Diquat, Silvex and Hydrothal, including their name, address and telephone number. ANSWER: OCC objects to this interrogatory on the grounds that it is irrelevant, immaterial, overly broad, unduly burdensome, is not limited to a relevant time period, is unintelligible and is not reasonably calculated to lead to the discovery of admissible evidence. OCC further objects to this interrogatory to the extent 494% it seeks information concerning chemicals and/or products not manufactured by OCC. Without waiving these objections, OCC reserves the right to supplement this response when and if plaintiffs identify a specific OCC product. 7. Please identify by name, position, address, telephone number, and length of time of service with your company the following: a. Each and every person who has ever testified on_? behalf of your company while an employee with you in any case involving a claim of defect or any other problem with Silvex, Hydrothal or Diquat. Testimony means by way of deposition or trial testimony. ANSWER: OCC objects to this interrogatory on the grounds that it is overly broad and unduly burdensome and is not limited to a relevant time period. OCC further objects on the grounds that plaintiffs have not identified any Specific OCC product upon which OCC can base a response. Without waiving these objections, OCC reserves the right to supplement these responses when and if plaintiffs identify a specific OCC product. Dated:r ';0rlando, _August?3,F Respectfully submitted, .J RIVKIN, RADLER, BAYH, HART KREMER Jo . anP 3P1 Unlon ale, 11556- 0111 (516) 357? 3000 CARLTON, FIELDS, WARD, EMMANUEL, SMITH CUTLER, P.A. CK Dd?iel C.1Johnson 1601 CNA Tower Post Office Box 1171 Orlando, FL 32802 (407) 849-0300 Attorneys for OCCIDENTAL CHEMICAL CORPORATION 4? Fm I 1- :5 5v- )Cj un-g . i . 5 I. 5,45 1-2} rf . 554i! J- 1-. Manday; ?uly eanas ma}, ?313 3; 1% Thursday, 3&1? 14: 1??4 a?vaa?, July 19 1%94 .3 i ta 51?. ?Vrhti $a?a?l Jaly i3; ig?? E3209 KER. 4* Lil t5:- I-ij?. 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Vu.. as a .. on}. .-.. um; .1 "Wu..s. 1. . 13.? andumif.? .. .. ?351.- ifEmma.1.il_ .. . .. . .. .. .. .. . ..H. .w .m .-.. ?Mr4n.( mud .5. .M .. Pr.? a 33r1..-. . .n . .. .. . .. may!? in?. haw .. r. q. :1 W. 17H IHH [ill?[H 4 3? 1'2. ,I?i A Is m- 193 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA ROBERT W. MOYER, II, and CASE NO. CI 89 8657 KIM MOYER, his wife, Plaintiffs, vs. DOW CHEMICAL COMPANY, et al., Defendants. OCCIDENTAL CHEMICAL NOTICE OF FILING RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS TO ALL DEFENDANTS Defendant, OCCIDENTAL CHEMICAL CORPORATION through its undersigned counsel, hereby notifies all counsel of record of filing its Response to Plaintiffs' Request for Production of Documents to All Defendants served contemporaneously herewith. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail this Z?ih day of August, 1990 to all counsel on the attached service list. RIVKIN, RADLER, KREMER, P.A. Joseph J. Ortego, Esquire Stanley Pierce, Esquire .EAB Plaza Uniondale, NY 11556?0111 CARLTON, FIELDS, WARD, EMMANUEL, SMITH CUTLER, P.A. Post Office Box 1171 Orlando, Florida 32802 (407) 849-0300 Attorneys for Defendant OCCIDENTAL CHEMICAL CORPORATION 1 Daniel C. Johnson Florida Bar NO. 522880 By: mm a 12m LIST OF COUNSEL Roger Lutz, Esquire Sheila Deciccio, Esqu Holland Knight, P.A. Lowndes, Drosdick, at Post Office Box 1526 Post Office Box 2809 Orlando, Florida 32802 Orlando, FL 32802 David S. Batcheller, Kelley Drye Warrent Daniel J. McGrath, Esquire Popham, Haik, et al. 4100 One Centrust Finan. Ctr. 2400 Miami Center 100 SE 2nd Street 100 Chopin Plaza Miami, FL 33131 Miami, FL 33131 Ronald L. Harrop, Esquire Gurney Handley, P.A. Hannah, Marsee, et al Post Office Box 1273 225 E. Robinson stree Orlando, FL 32802 0 1 1" is al. Esquire Stephen W. Beik, Esquire Suite 505, Landmark Ctr. II 3 Orlando, FL 32801~4303 Joseph J. Ortego, Esquire Kathleen L. Petrilli, Esquire Rivkin, Radler, et al. Legal Dept. Pennwalt Corp. EAB Plaza Three Parkway - Pennwalt Bldg. Uniondale, NY 11556?0111 Philadelphia, PA 19102 Richard D. Schuler, Esquire Schuler, Wilkerson Halvorson, P.A. Suite Barristers' Building 1615 Forum Place West Palm Beach, FL 33401 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR ORANGE COUNTY. CASE NO: CI 89-8657 fl DIVISION: 32 PFEIFFER ROBERT W. MOYER, II and KIM MOYER, his wife, :Plaintiffs, vs. DOW CHEMICAL COMPANY, et al., Defendants. OCCIDENTAL CHEMICAL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS TO ALL DEFENDANTS 1. If you supplied any Diquat, Hydrothal or Silvex to Orange County during the years 1974 through 1977, please produce the following: a. All documents pertaining to your purchase of said chemicals from the manufacturer or intermediate supplier; b. All invoices for said chemicals; c. All correspondence between the manufacturer and your company; d. All documents pertaining to your sale of said chemicals to Orange County, Florida; e. Any complaints received by you regarding the above chemicals, or any documents evidencing any dissatisfaction in any way whatsoever with the above chemicals; f. All documents forwarded to you by the manufacturer regarding the above chemicals, the use of such chemicals, the application of such chemicals, the warnings on suCh chemicals, or related to any defects in such chemicals that were sent to you at any time whatsoever and not limited to the four (4) years set forth above; g. any manuals, instruction sheets, informational sheets, labels or other documents pertaining to the use, 6?23 application, effectiveness, instructions, or composition of said chemicals. AHEHEB this request on the grounds that it is overly broad, unduly Occidental Chemical Corporation objects to burdensome and not reasonably calculated to lead to the discovery of admissible evidence to the extent that it seeks information concerning which plaintiff has not alleged that he was;? exposed to or injured from in his complaint and to the extent it requests information about Diquat, Hydrothal and Silvex, which OCC never manufactured. Without waiving these objections, OCC states that after a diligent search, it is unaware of any records in its possession indicating it sold products to Orange County during the years 1974-1977. 2. If you are a manufacturer as opposed to a supplier, please produce the following for the years 1974 through 1977 pertaining to Diquat, Silvex or Hydrothal: a. All documents pertaining to your manufacturing of said chemicals; ANSWER: OCC objects to this request on the grounds that it is Vague, ambiguous, irrelevant, overly broad and unduly burdensome. Without waiving-these objections, see OCC's ReSponse to Request No. 1 . b. All invoices or documents pertaining to the sale of said chemicals; ANSWER: OCC objects to this request on the grounds that it is irrelevant, ambiguous, overly broad, unduly burdensome and is not 43?? limited in respect to time or geographical location. Without waiving this objection, OCC refers the plaintiffs to its Response to Request No. 1. ti o. All correspondence between the supplier or your wholesaler and your company: ANSWER: sold its products to a number of independent wholesalers and distributors throughout the country during the time period in question. Therefore, OCC objects to this request on the grounds that it is irrelevant, immaterial, overly broad and unduly burdensome. d. All documents pertaining to your sale of said chemical to your supplier or wholesaler or other entity: ANSWER: See.response to Request 2c. e. Any complaints received by you regarding the above chemicals or any documents evidencing any dissatisfaction in any way whatsoever with the above chemicals: ANSWER: OCC objects to this request on the grounds that it is overly broad, vague and ambiguous. Without waiving these objections, OCC reserves the right to supplement this response when and if plaintiffs identify a specific OCC product. f. All documents forwarded by you dealing with the application of said chemicals, the warnings on such chemicals, or relating to any defects in such chemicals or the use of such chemicals that were sent out at any time whatsoever and not limited to the four years set forth above; ANSWER: OCC objects to this request on the grounds that it is overly broad, vague and ambiguous. Without waiving these d3! objectiongichC?reserves the right to supplement this response whe?%andsif?plaintiffs identify a specific OCC product. Eig. Any manuals, instruction sheets, informational {1 sheets, labels, or other documents pertaining to the use, - application, effectiveness, instructions or composition of said? chemicals. OCC objects to this request on the grounds that it is overly broad, vague and ambiguous. Without waiving these objections, OCC reserves the right to supplement this response when and if plaintiffs identify a specific OCC product. Dated: Orlando, Florida August_3, 1990 Respectfully submitted, RIVKIN, RADLER, BAYH, HART KREMER Uniondale, NY 11556-0111 (516) 357-3000 FIELDS, WARD, EMMANUEL, SMITH CUTLER, P.A. BY: C:_Johnson 1601 CNA Tower Post Office Box 1171 Orlando, FL 32802 (407) 849-0300 Attorneys for OCCIDENTAL CHEMICAL CORPORATON 6?3} IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA CASE NO. CI 89 8657 ROBERT w. MOYER, II, et al., Plaintiffs, vs. DOW CHEMICAL COMPANY, et al., Defendants. OCCIDENTAL CHEMICAL NOTICE OF SUPPLEMENTAL FILING TO RESPONSE TO INTERROGATORIES Defendant, OCCIDENTAL CHEMICAL CORPORATION, through its undersigned attorneys, hereby gives notice of its supplemental filing of the attached Verification which relates to its Answers to Interrogatories previously filed. The undersigned hereby affirms the original Verification has been served to Plaintiff's counsel this date. CARLTON, FIELDS, WARD, EMMANUEL, SMITH CUTLER, P.A. Post Office Box 1171 Orlando, Florida 32802 (407) 849-0300 Attorneys for Defendant OCCIDENTAL CHEMICAL CORPORATION re? By: Emil? Dani?IIC.?johnson Florida Bar No. 522880 I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail this lq?' day of August, 1990 to all counsel on the attached service list. Attorney 433 I, JOHN ENDICOTT, hereby verify that I have read the foregoing Answer to Interrogatories and state they are true and correct to JOHN ENDICOTT the best of my knowledge. Sworn to and subscribed before me this day'of August, 1990. n: ,upC-Jmm. (xii-[HS 2-3 I 43* Roger Lutz, Esquire P.A. Holland Knight n$$:nn IUDL- ULJ. DUK Orlando, Florida E?f 1 1340 32 LIST OF COUNSEL 802 Daniel J. McGrath, Esquire Popham, Haik, et al. 4100 One Centrust Finan. Ctr. 100 SE 2nd Stree Miami, FL 33131 Ronald L. Harrop Gurney Handley Post Office Box Orlando, FL 328 Joseph J. Ortego Rivkin, Radler, EAB Plaza Esquire P.A. 1273 02 Esquire et a1. Uniondale, NY 11556-0111 Richard D. Schul Esquire Sheila DeCiccio, Esquire Lowndes, Drosdick, et al. Post Office Box 2809 Orlando, FL 32802 David S. Batcheller, Esquire Kelley Drye Warrent 2400 Miami Center 100 Chopin Plaza Miami, FL 33131 Stephen W. Beik, Esquire Hannah, Marsee, et al. 225 E. Robinson Street Suite 505, Landmark Ctr. II Orlando, FL 32801-4303 Kathleen L. Petrilli, Esquire Legal Dept. Pennwalt Corp. Three Parkway Pennwalt Bldg. Philadelphia, PA 19102 Schuler, Wilkerson Halvorson, P.A. Suite Barristers' Building 1615 Forum Place West Palm Beach, FL 33401 43 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR ORANGE COUNTY CASE NO: CI 89-8657 DIVISION: 32 PFEIFFER ROBERT W. MOYER, II and KIM MOYER, his wife, Plaintiffs, vs. DOW CHEMICAL COMPANY, et al., Defendants. DEFENDANT THE DOW CHEMICAL Defendant The Dow Chemical Company responds to Plaintiffs' Insurance Interrogatories as follows: 1. State whether there is was in existence any policy of liability insurance which would or might inure to the benefit of the Plaintiff(s) herein, by providing for payment of a part of or all of any judgment rendered in favor of the Plaintiff(s) against any Defendant or against any other person, firm or corporation who is or may be liable to the Plaintiff(s) by reason of the casualty described in the Complaint, and if the answer is state as follows to EACH such policy of insurance known or believed to exist by you or your attorneys: The name and address of the insurer on each such policy. The name and address of each named insured on each such policy. The limits of liability in such policy as might be applied to any one Plaintiff by reason of any incident and the total limits of liability to all persons by reason of any one incident. 8 (FICC- 1/56 The relationship, if any, between each named insured on each such policy and any named Defendant in this cause. The policy number of each such policy. The name and address of any person, firm or corporation"additional insured? under such policy by reason of the incident described in the Complaint, and the relationship, if any, between such "additional insured" and any named Defendant in this cause. Whether or not any insurer has notified any insured that said insurer or any other person, firm or corporation must pay a part of or all of any judgment before the insurer must make any payment; if so, what payment must be made and by whom before the insurer must make payment. Whether or not any insurer has notified any insured that said insurer claims that there is or may be no coverage under the terms of the policy of insurance involved, and if the answer is describe the reason given for the claimed lack of coverage or failure thereof as stated by said insurer (identifying same) to said insured (identifying same) and state the date of such notice. NOTE: If such policy defense is withdrawn or waived, this sub~paragraph need not be answered. Are you protected against the type of risk sued hereon by any: (1) Reinsurance? (2) Excess insurance? If your answer to either of the subdivisions of the proceeding interrogatory is in the affirmative, for each such coverage state: (1) The name and address of the insurer. (2) The number of the policy. (3) The form of insurance. (4) The effective dates of coverage. (5) The amount of coverage. 2 (6) The name and address of the named insured. (7) The name, address and telephone number of the person(s) or entity that has possession of the policy and the reinsurance or excess insurance clauses. ANSHEB: Please find attached as Exhibit A which is Dow?s answer to Plaintiff's interrogatory regarding liability insurance. Additionally, Dow answers as follows: Dow states there is no relationship between each of the named insured and any named Defendant in this cause. Dow objects to this interrogatory sub?part on the grounds that it is vague and unintelligible. Dow does not understand this interrogatory sub?part. No. No. No. (2) Excess. The information is included in Exhibit A. The information requested is listed above (6) The Dow Chemical Company 2030 Dow Center Midland, MI 48674 (7) John C. Gorte, Manager, Liability Insurance The Dow Chemical Company 2030 Dow Center Midland, MI 48674 (517) 636?3202 ?7?36? if. -Ciy//J )ji?e? David G. Wilkins DOWELANCO Quad Fourth Floor 9002 Purdue Road Post Office Box 681428 Indianapolis, IN 46268-1189 (317) 871-8435 Mae My opq?j? Alan F. Wagner {1 CARLTON, FIELDS, WARD, EMMANUEL, SMITH CUTLER, P.A. 215 South Monroe Street, Suite 410 Tallahassee, FL 32301 (904) 224-1585 Counsel for Defendant The Dow Chemical Company 457 CERTIFICATE OF SERVICE The undersigned hereby certifies that a copy of the foregoing Answers to Plaintiff's Insurance Interrogatories ha??p:?n served upon the following counsel of record this ?u day of May, 1991: Richard D. Schuler, Esq. SCHULER, WILKERSON HALVORSON Barristers Building, Suite 4D 1615 Forum Place West Palm Beach, FL 33401 Counsel for Plaintiffs Daniel C. Johnson, Esq. CARLTON, FIELDS, WARD, EMMANUEL, SMITH CUTLER, P.A. Firstate Tower Post Office Box 1171 Orlando, FL 32802 Co?Counsel for The Dow Chemical Company David S. Batcheller, Esq. KELLEY, DRYE WARREN 2400 Miami Center i 100 Chopin Plaza Miami, FL 33131 Counsel for Chevron Chemical Company Ronald L. HarrOp, Esq. GURNEY HANDLEY, P.A. Post Office Box 1273 Orlando, FL 32801 Counsel for Atochem North America, Inc. formerly known as Agchem Division Pennwalt Corporation Kathleen L. Petrilli, Esq. Legal Department PENNWALT CORPORATION Three Parkway, Pennwalt Building Philadelphia, PA 19102 Counsel for Pennwalt Corporation W0 Roger Lutz, Esq. HOLLAND KNIGHT Post Office BOX 1526 Orlando, FL 32802 Counsel for Helena Chemical Company Daniel J. McGrath, Esq. R. Benjamin Reid, Esq. Paul T. Reid, Esq. KIMBRELL HAMANN, P.A. 799 Brickell Plaza Suite 900, Brickell Centre Miami, FL 33131?2805 Counsel for The Monsanto Company and Southern Mill Creek Products Co., Inc. Stephen W. Beik, Esq. HANNAH, MARSEE, BEIK VOGHT Post Office Box 536487 Orlando, FL 32853?6487 Counsel for the Woodbury Chemical Company John A. Reed, Jr. Esq. Shelia Gupta DeCiccio, Esq. LOWNDES, DROSDICK, DOSTER, KANTOR REED, P.A. 215 North Eola Drive Post Office Box 2809 Orlando, FL 32802 Counsel for Asgrow Florida Company and the Upjohn Company WW?gfw?a Alan F. Wagner 4w STATE OF INDIANA COUNTY OF MARION David G. Wilkins, being first duly sworn, deposes and says that he is the Staff Counsel, Legal Division of DowElanco. While he does not have personal knowledge of all the facts recited in The Dow Chemical Company's Answers to Plaintiffs' Insurance Interrogatories in the case of ROBERT W. MOYER. II and KIM MOYER vs. THE DOW CHEMICAL COMPANY. ET ALL, the information contained in these Answers have been collected and made available to him by others. These Answers are true to the best of his knowledge and belief based upon the information made available to him, and that, therefore, the statements made in these Answers are verified on behalf of The Dow Chemical Company in this litigation. A David G. Wilkins Staff Counsel Legal Division DowElanco Sworn to me and subscribed before me in my presence on this day of May, 1991. 622179,, 2- Qua?4?2) Cathy EJCSipole, Notafy Public residing in Hamilton County My Commission Expires October 16, 1994 EXHIBIT A 443 Yes. Name: Self retained Address: Named Insured: Not applicable Limits: $400,000 each person Limits: $2,400,000 each occurrence Number: Policy period: April 1, 1976 to April 1, 1977 Name: Aetna Casualty Surety Company Address: 151 Farmington Ave. Hartford, CT Named Insured: The Dow Chemical Company and any Domestic or Foreign Corporation in which it owns or may own, directly or indirectly, more than 50% of the combined voting power. Includes Cordis Dow Corporation. Limits: $100,000 each person excess of $400,000 each person. Limits: $100,000 each occurrence excess of $2,400,000 each occurrence (8) Number: Policy period: April 1, 1976 to April 1, 1977 effective 10/1/76 policy amended to: Name: Aetna Casualty Surety Company Address: 151 Farmington Ave. Hartford, CT Named Insured: The Dow Chemical Company and any Domestic or Foreign Corporation in which it owns or may own, directly or indirectly, 4W (C) (C) (C) (1) more than 50% of the combined voting power. Includes Cordis Dow Corporation. Limits: $600,000 each person excess of $400,000 each person. Limits: $100,000 each occurrence excess of $2,400,000 each occurrence. Number: Policy Period: April 1, 1976 to April 1, 1977 Name: Dorinco Reinsurance Company Address: 2030 Willard H. Dow Center Midland, MI Named Insured: The Dow Chemical Company, Cordis Dow Corporation and any Domestic or Foreign Corporation in which either owns or may own, directly or indirectly, more than 50% of the combined voting power. Limits: $400,000 each person Limits: $2,400,000 each occurrence Number: 5001 Policy Period: April 1, 1977 to April 1, 1978 Name: Aetna Casualty Surety Company Address: 151 Farmington Ave. Hartford, CT Named Insured: The Dow Chemical Company and any Domestic or Foreign Corporation in which it owns or may own, directly or indirectly, more than 50% of the combined voting power. Includes Cordis Dow Corporation. Limits: $600,000 each person excess of $400,000 each person Limits: "$100,000 each occurrence excess of $2,400,000 each occurrence Number: Policy Period: April 1, 1977 to April 1, 1978 Effective 1/4/78 policy amended to: Name: Dorinco Reinsurance Company Address: 2030 Willard H. Dow Center Midland, MI (C) Named Insured: The Dow Chemical Company, Cordis Dow COrporation and any Domestic or Foreign Corporation in which either owns or may own, directly or indirectly, more than 50% of the combined voting power. Limits: $1,400,000 each person Limits: $3,400,000 each occurrence Number: 5001 Policy Period: April 1, 1977 to April 1, 1978 Name: Aetna Casualty Surety Company Address: 151 Farmington Ave. Hartford, CT Named Insured: The Dow Chemical Company and any Domestic or Foreign Corporation in which it owns or may own, directly or indirectly, more than 50% of the combined voting power. Includes Cordis Dow Corporation. Limits: $600,000 each person excess of $1,400,000 each person Limits: $100,000 each occurrence excess of $3,400,000 each occurrence Number: Policy Period: April 1, 1977 to April 1, 1978 Name: The Home Insurance Company, et a1. Address: 59 Maiden Lane New York, NY Named Insured: The Dow Chemical Company and Dow Corning Corporation and any Domestic Corporation in which either or both owns or may own directly or indirectly 50% or more of the combined voting power, and any Foreign corporation in which either or both owns or may own directly or indirectly more than 50% of the combined voting power; and Korea Pacific Chemical Company. For the purpose of this insurance, Subsidiary Companies and Corporations owned by Subsidiary Companies and Corporations of t?ua Named Insured shall be 4% (C) (1) included as Insureds ii? the percentage of ownership is in accordance with the above. Limits: $124,895,000 each occurrence excess of primary insurance Limits: $124,895,000 each occurrence excess of primary insurance Number: HEC4973974 Policy Period: June 11, 1975 to June 11, 1978 Effective 6/11/76 policy amended to: Name: The Home Insurance Company, et a1. Address: 59 Maiden Lane New York, NY Named Insured: The Dow Chemical Company and Dow Corning Corporation and any Domestic Corporation in which either or both owns or may own directly or indirectly 50% or more of the combined voting power, and any Foreign Corporation in which either or both owns or may own directly or indirectly more than 50% of the combined voting power; and Korea Pacific Chemical Company. For the purpose of this insurance, Subsidiary Companies and Corporations owned by Subsidiary Companies and Corporations of the Named Insured shall be included as Insureds if 'the percentage of ownership is in accordance with the abpve. Limits: $110,795,000 each occurrence excess of primary insurance Limits: $110,795,000 each occurrence excess of primary insurance Number: HEC4973974 Policy Period: June 11, 1975 to June 11, 1978 Effective 9/25/76 policy amended to: Name: The Home Insurance Company, et al. Address: 59 Maiden Lane New York, NY Named Insured: The Dow Chemical Company and Dow Corning Corporation and any Domestic Corporation in which either or both owns or may own directly or indirectly 50% or more of the combined voting power, and any Foreign Corporation in which either or both owns or 44"? (C) may own directly or indirectly more than 50% of the combined voting power; and Korea Pacific Chemical Company. For the purpose of this insurance, Subsidiary Companies and Corporations owned by Subsidiary Companies and Corporations of the Named Insured shall be included as Insureds the percentage of ownership is in accordance with the above. Limits: $109,720,000 each occurrence excess of primary insurance Limits: $109,720,000 each occurrence excess of primary insurance Number: HEC4973974 Policy Period: June 11, 1975 to June 11, 1978 Effective 10/2/76 policy amended to: Name: The Home Insurance Company, et al. Address: 59 Maiden Lane New York, NY Named Insured: The Dow Chemical Company and Dow Corning Corporation and any Domestic Corporation in which either or both owns or may own directly or indirectly 50% or more of the combined voting power, and any Foreign Corporation in which either or both owns or may own directly or indirectly more than 50% of the combined voting power; and Korea Pacific Chemical Company. For the purpose of this insurance, Subsidiary Companies and Corporations owned by Subsidiary Companies and Corporations of the Named Insured shall be included as Insureds ii? the percentage of ownership is in accordance with the above. Limits: $109,560,000 each occurrence excess of primary insurance Limits: 4$109,560,000 each occurrence excess of primary insurance Number: HEC4973974 Policy Period: June 11, 1975 to June 11, 1978 Effective 11/24/76 policy amended to: Name: The Home Insurance Company, et al. Address: 59 Maiden Lane New York, NY 4% (C) (C) Named Insured: The Dow Chemical Company and Dow Corning Corporation and any Domestic Corporation in which either or both owns or may own directly or indirectly 50% or more of the combined voting power, and any Foreign Corporation in which either or both owns or may own directly or indirectly more than 50% of the combined voting power; and Korea Pacific Chemical Company. For the purpose of this insurance, Subsidiary Companies and Corporations owned by Subsidiary Companies and Corporations of the Named Insured shall be included as insureds if the percentage of ownership is in accordance with the above. Limits: $108,560,000 each occurrence excess of primary insurance Limits: $108,560,000 each occurrence excess of primary insurance Number: HEC4973974 Policy Period: June 11, 1975 to June 11, 1978 Effective 12/15/76 policy amended to: Name: The Home Insurance Company, et al. Address: 59 Maiden Lane New York, NY Named Insured: The Dow Chemical Company and Dow Corning Corporation and any Domestic Corporation in which either or both owns or may own directly or indirectly 50% or more of the combined voting power, and any Foreign Corporation in which either or both owns or may own directly or indirectly more than 50% of the combined voting power; and Korea Pacific Chemical Company. For the purpose of this insurance, Subsidiary Companies and Corporations owned by Subsidiary Companies and Corporations of the Named Insured shall be included as Insureds ii? the percentage of ownership is in accordance with the above. Limits: $108,720,000 each occurrence excess of primary insurance Limits: $108,720,000 each occurrence excess of primary insurance Number: HEC4973974 Policy Period: June 11, 1975 to June 11, 1978 Effective 6/11/77 policy amended to: 4m (C) (C) Name: The Home Insurance Company, et al. Address: 59 Maiden Lane New York, NY Named Insured: The Dow Chemical Company and Dow Corning Corporation and any Domestic Corporation in which either or both owns or may own directly or indirectly 50% or more of the combined voting power, and any Foreign Corporation in which either or both owns or may own directly or indirectly more than 50% of the combined voting power; and Korea Pacific Chemical Company. For the purpose of this insurance, Subsidiary Companies and Corporations owned by Subsidiary Companies and Corporations of the Named Insured shall be included as Insureds if the percentage of ownership is in accordance with the above. Limits: $107,195,000 each occurrence excess of primary insurance Limits: $107,195,000 each occurrence excess of primary insurance Number: HEC4973974 Policy Period: June 11, 1975 to June 11, 1978 Effective 8/3/77 policy amended to: Name: The Home Insurance Company, et al. Address: 59 Maiden Lane 7 New York, NY Named Insured: The Dow Chemical Company and Dow Corning Corporation and any Domestic Corporation in which either or both owns or may own directly or indirectly 50% or more of the combined voting power, and any Foreign Corporation in which either or both owns or may own directly or indirectly more than 50% of the ?combined voting power; and Korea Pacific Chemical Company. For the purpose of this insurance, Subsidiary Companies and Corporations owned by Subsidiary Companies and Corporations of the Named Insured shall be included as Insureds if the percentage of ownership is in accordance with the above. Limits: $106,720,000 each occurrence excess of primary insurance Limits: $106,720,000 each occurrence excess of primary insurance Fi? Author m: Code Letters Report no. nuts I. 3. sun;- 14!. misc A13 maw?wgm. a. 195! Title and Summary: sclaticn and nti b1; Acne ems from the Csustic-Ensc uble Ecgticg gr. 5133 Ego. from the 2 -?1?rich Process 1. . - Possible acnesens in the products fro- the 2 process have been isolated and identified. kin sensitivity tests on rabbits (performed at the Biochemical Research Labore- tor-y) have positively shown to be by far the most severe skin irritant soon; the group or [VlI-p . . mJ/km' 51-111: . compounds identified. I cmmcasm. - ssarscr to mmnou - tic. ED- ML 4-4-70. gamma 9.79 . Resesrch 13 mum ma?a Ill-H mun-m - I. 3. Bradley 3. II. Inc. F. Slumber; x. 8. coultsr A. heck I. 3. Trans 'h':?618.1? 0.1. accrues I. 3. son I. Irish" L. I. Greene i. J. Potts R. I. '0 3. ?wattHolt-es I. c. achcitsc 8Shreder #Silverstsin 4. n. - 1.. 3. sun- .. LL. 1, DCM CHEMICAL CORP. ROLL #4 . I 3 .?uls? 4 'wmfurther activity in this area until 1957. '1 -1- . A. --.- distillation residue from the caustic insoluble portion of - the process shown to cause severe folliculitis on in rabbits was fractionated by preparative thin-layer chromatography (TLC). Identification of these separated components was ends by ele- Iental snaiysis,? ebullionetric nolecular weight, infrared and uses spectra. The major component which comprises approximately to percent of the_distillation residue (0.65 of the undistilled caustic insolubles) -was positively identified an extremely toxic compound and known acnegen (2.3). Preparation of this compound by the chlorination of dibenso-p-dioxin provided unanti- suous structure identification. Eight additional possible concerns were ,separsted, identified, and submitted for tests on rabbits. solubility studies did not produce a solvent in which the solubility exceeded 0.2 percent. An analytical method, hLH.6?.l9, has been developed by 3. Hi Gill for the determination of the acnegen in caustic insoluble camp es. . - 1.1mm sums! ow Tetrachlorodibenco-p-dioxin was first prepared by hagatti in 1880 (II). However, the reaction route was somewhat ambiguous. Ile- mental analysis, solubility characteristics and high nelting point did agree with the proposed structure. The literature (G.A.) indicated Gaston (5) prepared and reported a . melting moint of 320'-325 curhey also reported it caused chloracne. Another paper (6) reported this conpomd was harmful to nan and beast. 'ijooitc, Ucda, and Narisada (7) prepared this ound and reported a neltina point of 2958c. Occupational chloracne 2) was observed in 31 workers engaged in the production of at and its. transformation to acid and its esters. the active acnegen was isolated and proved to be 2.3 1.8-tetrachloro- dibeneo-p-dioxin. retrachloro end trichloro dibensof?urans were also found to be active. a technique (3) for testing the ecnesenio potency . of 2.3 on rabbits was described recently. heating the sodiun-sslt- of houreat-aso-log O. waltim point.? 295 -3oo'c. 2.3.1.8-mcmcomuc-p-umx . i'he conpound was prepared according to the procedure of Sander-am. Stochan. and Gaston (5). Eight grams of dibcnso-p-dicxin was dis- solved in 15 of chlorofore. i?race anounts of ferric chloride and iodine were added and the suture was chlorinated at n'c. for twohours. was continued for five hours at the boiling point of chloro: fore. the insoluble product was filtered off and four tines tron anioole. . - - . . "vii? 3. 2 now mama. coap. ROLL #4 Malta - . -- '40! 12 c1 of: lie?61;? c1 .0). Dibenzon-dioxin - . I p-dloun The' compound had melting point or 303-305?0. end gave the analysis glove Table l. Purity es estimated by infrared examination use on I - rm 1 . ANALYTICAL DATA ma mm 2.3.7.8-mmc1monoommzo-p-nionn Auelzsis Pound . hooretioel Berton, 5 I343). If; min-Ea: 1 I211 ?Io less no. 320- . . holeoulsr, vs. 319 1.91 mun: Point ans-305%. Infrared nomination - agreed with isolated heteriel 'lIees spectroeooQists use 35 for the etoeio weight of chlorine scumurv or . VARIOUS swim . Because of the problem in removing 2 3.1.8-tetreehlorodihenso-p- dioxin tro- verious surreoes end equipaeh the eolutili or thie eon- ouhd use detereihed in eeverel solvents .03 minutely 5-30 on. of . be mi use placed in eeoh or ten. 1 . voluntrie About 018119; . or the respective solvents were edded end the eelutions placed on were etese both for tour hours. he: were then elloved to equili- . hrete et roo- tenpereture overnight. All solutions hed eolid phase - to exclude the possibility of an r-setm-eted solution. the: ION then euteittod to Ii. II. dill rer ces- iquid ehroeetogrephie enelysit Alter filtering. one ul. of the setureted solution use inJeoted into - git-liquid ehroeetogreph end eoqzsred with in ohlorororn. luhilities ere given in able 2. -- - 1- ?3 3 now CHEMICAL CORP. ROLL #4 - 1 . 11/3/51?) . - .- - - - Interest was shown in the solubility of the acnesen in the caustic 3 insoluble solution. Therefore a caustic-insoluble mixture was prepared. In order to have the components completely solublized room temperature, the 1,2,h-trichlorobenzene concentration bid to be higher than normal. mite 2 LOBSBOM sowmur! or 2 in unions sonvms er 25?c. .: . Solvent Solubility. ml. It. greent o-Dichlorobenzene 0.18 - 0.1! Chlorobenzene .080 . 2 Perchloroethylene .068 . . 3 'geh1orofron.32; .33; ?zen. I ?9 '3 . Acetone .009 .011 1 (.01 (.01 gczhanol .335 .001. a a? <0 (.NOS I Caustic-Insoluble: . .eh .16 nus caused detector fouling and a better value could not be obtained However, solubility does not exceed 0.01 percent. Composition of caustic insolubles: . up 1,2,h-trichlorobenaene 2.1! ,s-trichloroanisole lo} . 2.53-dichloroanisole -- . 5g - dinctlul other - .- - 11.5-dichlorocatechol dinethyl other ?a . MS-dichlorotwdroquinone ?ii-ethyl other . EXAMINATION or cavern-Insomnia mm 658 . - caustic-insoluble residue 658, which produced severe folliculitis - - on rabbits was studied initially. rec examination of the sample on ma. silica gel 0 with 1M chlorofors in n-hexane developnent and iodine detection indicated the presence of one maJor, tuo minor, and two trace components. Three hundred as. of this sample was then applied to five prepa- retire (1.0 an. silica gel 0) TLC plates. After development uith 103 - chloroforo - hexane solution. three fractions were scraped from the plate These included a niddle fraction (Riddle) containing the component, and fractions shows (he) and Iere desorbed from the now CHEMICAL CORP. ROLL #4 . filtering, and ?4 [1/8/99 -1, 4w in#43? 4k .. ..-- the residues were taken up with 1041. portions of benzene and 3 submitted to K. J. Olson of the Biochemical Research laboratory for rabbit testing. An additional solution containing 300 as. of residue 658 in 10 ll. of benzene was also submitted. Therefore, the tracticno . which contains the ?mean should cause a reaction equivalent to theta: or the unfractionated sample. Rabb'it tests indicated that the Top fraction caused severe rom- 'oulitis on rabbits as did the untraetionated saaple. Gas-liquid chro- .natographio examination or this fraction by ll. 11. (Jill showed the presence or a component having the same retention time as 2.3.7.8-tetrs- ohlcrodibenso-p-dioxin . . nun-ram CHROMATOGRAPHY (P - DISTILIED FRACTIONS OF onmnc mm a. ll. dill or the Analytical Laboratory 57!! Building, had a 11.3 kg. sample of caustic insoluble sanple 567 distilled in the East Analytical Distillation Laboratory. Ten distillation fractions, to- gether with a residue fraction were collected. mesa distillation fractions were tested on rabbits and round to give -a slisht to aoderate reaction. However, the distillation residue produced an extremely severe reaction. - . Distillation fractions 8,9. and 10 were eassined by no on u. silica gel with 255 chloroform-hexane development. All' three tracticns. were essentially the sane with about seven components visible. . traction 8 was separated into its achr components by preparativs.? 3- 1'18. Components were identified by their infrared (8) and ass (9) spectra. Their identities are listed in 'i?able 3. rm 3 . cmromrrs 1n nxsumnou mono): a net - . . ensue museums sums 667 . Omnent uo. 0mm: Identig - . e? dies 1 other - . . I - dine 1 other . i . - 2. 5 . secbutyl ether Since none or these compounds is known as an acnesen and fraction 8 caused only a sodorste reaction on rabbits. it was concluded that an acnesen was carried over in the distillation. ihc distillation residue which had been shown to cause a severe . reaction was examined by The under the cane conditions as fraction 8. ., Apprcaiaately ten ccapcnents were observed. it was also noted that a . considerable amount or this residue was chloroform-insoluble. this insoluble naterial comprised Ill percent or the residue. utter recry- . stallisin; a portion or this residue twice from anisole, the product pow CHEMICAL cone. ROLL #4 u/gm-s . .. 494 front travels) required higher concentrations of chloroforsave an analysis listed in Table h. It was concluded that the uatcrial was positively The product was examined by sass and infrared spectro- metry to exclude or indicate the presence of other si ificsnt insoluble components. Five to ten percent of ms 31 was found. This component is identified later in this report. 603158 TABLE II ANALYTICAL DATA FOR CHLOROFORH Insomnia IMPURITY IR DISTILMTION RESIDIE Analgis Found dibenso-p-dicxin carbon, l5.2 hydrogen, i 1J2 1.25 Chlorine, 5 113.5 .0 Mass No. 320 320 Molecular Ht. 313 321-97 Infrared Examination Identical Melting Point - 303-3090. 303-305??- The chloroform-soluble portion of the residue was fractionated by preparative 1'11: on 1.24m. silica gel or with 255 chloroforn in n?hexane. I-?inal purification of the coup nents was made with 10 to 75$ chloroform?hexane solutions. Those components having letter values (distance the component travels divided by the distance in n-hexsnc and vice versa. Because some of the components was contiguous on the TLC plate several passes Here required to obtain pure compounds. In some instances. a near-pure compound by it: could be from chlorofers or n-hexane. light components were isolated in this unner. These were sub- aitted to K. J. Olson for rabbit testing at the 0.17. level. hrtions of these sasples were also sent to 1.. 3. ?estover (9) for sass spac- analysis. R. A. Nyquist for infrared examination the hicro Laborato for elemental analysis and nolecular Height determination (ebul ionctric . Fro- the analytical results. structures Here assigned to coeponents. Listed below: are the structure for the components formerly designated by their 3 values. Purity determinations. in general. were node by gas-liq id ohrosatographv a. dill). . 06113 - Cl DCM CHEMICAL CORP. ROLL #4 [1/3 disethyl ether . nomm momma on mm . . mm 1 32-1? 2.1:.35. I,6-Diohlororeeoroinol dimethyl ether 10 hoderete ether 13 x'a-Dichloro-x-uethoxyphenyl x-triohloro-x-uethomhenyl ether 6 . 7 ';None 6 7 None 10 ill Moderate ether 18 25 None x-triohloro?x-nethoxyphenyl ether 6 1 . None Lb) 3 1 . Extremely Severe 8 ll! Hoderete to . Severe e) ?reeted at the 15 level. i etenderd emple ie being rerun to eliminete the poeeibility I that true imritio be certain: reaction. . 1 . i'eete have: not been completed. (6) A mined temple 56-1) is being tested. r~ a: because of the proximity of the the plete. thie eenple oonteine 1-25 or the very active component . The reeuite or rebbit teete met be considered in View ol50?. . 8 - analysis and comparison of a prepared standard. Bight additional . R. A. Nyquist, L. B. Hestover, and o. J. Kallos of the Cheaical CONCLUSION Nine components have been isolated from a distillation 'residue of the caustic insoluble portion or the 2,I,5-trichloro- phenol process. The major component evtq?) in this residue has 'been-shown to cause severe tolliculitis in rabbits. It has been positively identified as by possible acnesens were isolated, identified and tested. they showed varying degrees or activity, however, none were as active as the naJor component. Solubility studies in nine solvents did not produce one solvent in which solubility exceeded 0.25. ACKNOHLEDGEHENT The author would like to acknowledge the generous help of Physics Research Laboratory for structure determinations. a. I. Gill 0: the Analytical Laboratory for gas chromatographic analysis. K. J. Olson or the Biochemical Research Laboratory for acnesenio testing, and the Micro Laboratory for the many elemental analyses. waited? N. I. Skel Dow CHEMICAL CORP. ROLL #4 11/3 /a7~8 9. Dow CHEMICAL CORP. ROLL #4 - Bolsters-eh, u. Helmet-Hertz, 19, No. 57(1.958) ., gage, 3., and Narisade, IL, thuslku, mam, - (19 Chemical Physics Laboratory, 1603 3.11161COMPANY AND LITERATURE REFERENCES skeny, n. n. 1111159 pp. 1-78. Special s?ruces Laboratory. 571% Building Kiwis. J. and Schulz K. H. Demtolosicn 11:, 51:0 (1957). . Jones L. and Krizek, 3., J. Invest. Dermatol. 32. 511-15 (i962): Magatti, 9., n. 13 227 (L380) Sendemnn, m, Stockuann, 11., and meten. 3.. Chem. Dev. 690?2 (1957) - Sender-menu, 11., Casten, 3., Kraut-13? 11., and Planer, J., Nyquist, n. A. Report: 16689, 166922, 166938. 161128. 16728", 167313. Chemenl Physics Research about cry. 1603 Build. an. Heatwer, L. 3., and Kanos. o. J.. Reports 166?l35, 166h6l, 11/? Aqua a C. i 4? THE DOW CHEMICAL MEDLAND DIVISION 6 1.69989? 1 M00 L. . Chamberlain Egecutive Research 506 Building w. H. Haberstroh . - G. G. Goergen R. c. Sauera . - . 5. SUBJECT: micmoaorh'snoz. RESEARCH . The following is a summary of the problem concerning hlorophenol-Chlorecne and the various attacks on the problem by currently active research units. I have also included several suggestione_ for work beyond that imzediately planned. I: you have suggestions or queerions concerning this problem pleaee contact the writer VEry truly yours, - -. -- - ibii?ti :7 no benzene *search Laboratory #74 3111an3 10 333.11 Disclosure Restricted Pursuacgt To Court Order. ?Agent \1 I 16 Qragae" Product Liabilzty thrgation. MDL No. 381 13 . . -1- The Problem: N. -- To design a manufacturing process for 2 . which is economical and safe particularly from the standm QQMworkers'?xposure to chloracne exciters. . . The Chemistrl: Cl OCHc3303 - m? 1* (?5329 1 330 4- NaCl . ii. ?04 KCal/m'ol AH -38 KCal/nbl - 3 Known chlorscne exciters found as impurties: s: I?l c1 1c1?? . . 11:11 a NIT. c: 2 ,3p7gB-Tetrachloro- 2, 3.7.96'retrachloro- dihenzodioxin ?dihenzodioxin 21? Conditions which minimize Dioxin formation: 3'3 I- was; . . solvent - 1* Conditions which favor higher rates of conversion: - 1. Higher Temperatm-es 2. Non-aquecms solvent However; the disadvantage of the non-aqueous solvent system is the precipit ation of NaCl which can plug a tube reactor. with this information in mind, the following alternatives . are seen: .7 i While we have original Dov date on temperature. this inforuetieu 1e .0.- Disclosure Restricted of the know-how which we have purchased and is subject to 3 '6 Order. ?@?Seereer .. e' Product Uabiuy Litigation, MDL No. 381; . 2; Procedure 1/19-II. Continuous Process A. Aqueous solvent 1 1. Complete conversion on 2. Incomplete -conversion C3 a wi recycle CC -b separate hydrolysis of anisole E: B. Non-Aqueous Solvent L: - 1. Complete conversion - :h 2. Incomplete conversion 7L9 a recycle . . separate hydrolysis of anisole I.TL c. Other solvent systems i _Some of the other solvents that have been tried on this reaction include: - It is entirely possible that some other solvent or 73?? solubilizer might produce desireable results. Diozane u.s. has not been tried and it stable at high pH and?nIlSO' could be interesting. D. Other miscellaneous variables: 'Some other variables which have been studied in *3 the Benzene Research Laboratory include: l/lc/GS-E . - 5-15.. v. "??iohj - Disciosure Restricted Pursu? To Court Order. "Agent Orange" Product Liabil.ty Litigation. MDL No. 381 u. -3- In order to tacilitate the design or a reactor the Sense. .e Research Laboratory (Widiger Poffenberger, Nettara and . ree hourly technic ianss is gathering various data (kinetic. phase. calorimatrig an; analytical) on part II A above, the aqueous solvent . k) continuous system. This is viewed a pbdee as the alternative most likely to succeed the soonest. =55 Skelly and Gill at 57# Analytical Laboratory have I laid acne excellent ground work tor the analysis of chloracne exciters. We are continuing to work with C: then to learn more in this area. 2% ?The Chemical Physics Laboratory (Ken Bradley, Art .gg rhel and assistants) is working on II B, the non- aqueous system. Bradley feels that his.kinetic and conyersion data are nearly complete and that the salt problem can be worked out. The engineers thus far have not viewed this approach with enthusiasm.. Bradley also has one or two long range ideas for alternative processes but these are not mature enough to spend time on now. No one is looking further at II although the Benzene Research Laboratory expects to do more on this at a later date. If another laboratory would like to take a fresh look at the problem, I would suggest this area. . Anyone getting into this work should be sure to brief himsel: thoroughly on the potential danger of the chloracne exciters. and how they are formed and handled. . . 'f .3. 'rrapp - . 1-26-65 CONFIDENTIAL Disclosure Restricted Pursuang To Court Order. ?Agent \1 Orange" Product Uabiisty LitigationProcedure #x) M1ant-tors -E CHEMICAL COMPANY MIDLAND Lassa-ascent ..-- I. -- - a- yaw ;--:erstein, Dr. Hem if. a . as: :edical questions posed by Mr. Silverstein. of Production canr?J-er Sohn -- a: Rhein outset I explained to you that there were four Dow CONFIDENTIAL nu appreciated the opportunity to talk wit you -. ay and' i have sum-.arized below our understanding .e essential elements of our conversation, as you ?t 995999 1, Mll? pie on' three telephones here. I then introduced Mr. who would be on hand to - die any necessary translation, and finally, Mr. Dylewsm, ensineer oonce-..ed the develoonent of a new process ,S-Trichl orophenol. we then began with a series of Silverstefm: isomer of tetrachlorodibenzodionin. The have isolated and. identified a symmetrical and an . the unsymetrical is we stopped research - i \nl yo: have any liver biopsy specime or 3.3.?3 to study? Anew r: "No, since we have had no no years. see 'ns er: no tknow". :e the li"er function tests or strzetrical isomer is 3, 6 7" (German notation) and Limited animl e?nperu: entation indicates that the isomer is rash less active. Have you any i-tnrmation on the relative activity or these two isome- on your chloracne cases been published anywhere . Disclosure Restricted Pursuant To Own Order. "Agent . ?1 Orange" Product Liability, 5 litigation. MDL 381 - c; {/73 Eans.?erz -2- 1-23-65 Did 3 note an? increased incidence 9! diabetes in your chloracne patients, or did any diabetics with chloracne suiier_ ?grayation of their diabetic ondition? - 5. Did you study catechol anines or ketosteroids in your . chloracne cases? Answer: ?Do not know". Ear: said that he would check further into those questions wh.ch were answered above as "Do not know".- cBrierski (Engineer): is explained that we are considering a distilled grade or 2,4,5-Trichlorophenol as -t of our product requirement. 98 jar: reiterated that.Eoehringer's management had decided not to distill this material because of the danger or the fornation of chloracne inciting materials. - Dru Bylawski was nevertheless interested to hear more about Ecehringer?s experience with the distillation and thereupon acceded to describe his proposed procedure and?to invite . rz's comments. - 3r. Her: said that they fornerly distilled in copper equipnent operating with a sump temperature in the range or lSG-lso?c. Chloracne inciters were formed presumably 3, because or residual cations (Na) in the phenol.which produced Ra-trichlorophenate thus leading to the formation of dicxin compounds. Er. Dylewski asked if Dr. Merz could nane-a particular concentration or salt below which it would be 31:: to operate a distillation. Dr. Mere would not name sol rable level but suggested that a water extraction said he better aifected by use of a retainer solvent such a nethrlene chloride or chlorobenzol for the CONFIDENTIAL Disclosure Restricted Pursue? To Court Order. ?Agent :11 Orange" Product Liabili W. thlgation, MDL No. 331' SI t?rocedure I I 15)ng .. - . A .I 1.. I t- Dr. Hans-Men -3- - 1-28-?dl- - I _Dr. Merz was asked if he knew what the material of con? struction_o? the reactor autoclave was, and he replied, ?In closing, Dr. Trapp informed Dr. Merz that we had not yet received the Secrecy agreement papers from Boehringer and Dr. Merz said that he would check immediately on this because he was certain that.they were completec and had assumed that they had been mailed. . . 2.398991 Milli Wir danken Ihnen nochmals Ihre weiterer Unterst?tzung, Dr. Merz. . . . . nit freundliche grussen, a . 7,56alter B. Trapp . .. .. . Assistant_Director a . Benzene Research Laboratory . . . . #74 Building . 7 . . . - .. 1-7-.-. he: Hamburg Office (Grate/tube) . 3? G. -A. criesSilverstein . - - CONFIDENTIAL Disclosure Restricted Pursuant?! To Court Order. ?Agent 2:1 Orange" Product Liability CC Litigation. MDL No. 38i Procedure 475 'Research and Dev. )pment I c-l-I? DIVISION January 28, 1965 Coulter Midland Division 566 Building cc: R. c. Sauers W. H. haberstroh__ SUBJECT: C. H. BOEPIRDWGER SCI-IN CONTRACT [21939.9 1 M00 a In December, 196% we agreed verbally with the Boehringer Company to pay them for process information on Concerning the terms, they agreed that we would pay them only after we were satisfied that we had solved our problem. The Eoehringer people have been extremely cooperative and genuinely concerned for our problem from the standpoint of the potential for human suffering. It is my feeling that we have reached a-point where we should pay Boehringer either in part or in whole. Our analyses of their samples? show <10 dioxin and after considerable study of all the data they have furnished I feel that we can be confident that they have provided valid information. 'Furthermore, I am confident that they will continue to cooperate with us even if we are no longer holding a check over their head. Therefore, I.would suggest that we arrange to pay them . either! immediately with the remainder coming along in about six weeks, or the entire shot. Between these alternatives I personally prefer the latter because I see no reason to imply that we feel a need to hold a check over their head in order to get further information if needed. Again, I am completely confident that they will continue to cooperate with us even after being paid in full. CONEIDENTIAL Disclosure Restricted Pursuant To con. Under. ?Agent Orange" rroduc?. Ltngunun. IVEUL No. 381 Procedure 1? :33 53. 17 We - K. 3. Coulter -2- 1-28-55 ugge3t_that we sho?ld tell then when we bay them that we are 5 tisried that they have provided information Egg tr we need for safe operation but that we may still :55 . want to consult further with them.as our work proceeds. Please contact me it you have further questions or en 63:28:25. .Vez'y tzt-L-zr yours?first-:1" eenzene Research laboratory 474 Building den CONFIDENTIAE Disdosure Restricted Pursu?lt To Com Order. ?Agent Orange" Product Liability ngauon, MDL No, 381. .00181/7'] Procedure 3: a: c: Herrn Dr. Hans Merz no Director of Production C. H. Boehringer Sohn Ingelheim am Rhein West Germany Dear Dr. Merz: We are pleased to be able to send you approximately 20 g. of a chloracnegen-containing chloroanisole oil which we hope will be useful to you for rabbit experiments. An analysis of this substance shows about 0. 85 by weight of 2.3.6.7- (your numbering) tetrachlorodibenzo-p?dioxin. It may be of interest to you that this material caused moderate folliculitis on a rabbit ear after two applications. The material was applied as a 3p (by weight) solution in benzene. Herr Silverstein says that he is con1_dent that a single applica- tion would have caused the same result. The sample. identified as #558 oil, is leaving today via air- mail. Best personal regards. Sincerely yours, ,Nalte*>3 Trapp Assistant Director Benzene Research Laboratory T- . ?55 1 . CONFIDENTIAL be: Hamburg-Office (Gro te/Disclosure Restricted Pursuant ?1 L. Silver: 1381:: To Court Order. "Agent \1 Orange? Product Liabmty Q3 Litigation, MDL No. 381 It: I) Procedure {1638991 M00 19 77.-., - . . -.1ArmDr. Hans HerBoehringer Sohn 1 . .-: Irgelhei: an Stein '2 - 2 - Host Ger-.33.? 2 I '2 Dear Dr . Her: We were pleased to learn that our sample of chloranisole 0.1 sa:?e1y. as reported in your letter or February 23. 1965. The chemical analyses of your samples of Ra Trichlorophecate solution ani theh isole oil have been completed and these result 3 are enclosed. .- We expect to cocclete some interestisg ani:a1 testing on these materials - - in about two weeks and will send those results as soon as we have then. I an enclosi-v a description of our gas ctrozatotraphy method. . . 0-- u. Ear:- Silverstein has g-ven :e a copy of "Toxicological Properties of - . Trichloroben: no" for you and this is enclosed also. . . Kirdest personal regards. - - . Sincerely, . Walter Trap . --2 22 -- - - . Disclosure Restricted Furs-.553 if? 51? - '3 - To" Court Order. _.0range? Product anb. Mal-73?: . .?Utigauon. No.93Procedure ?ii. I - 1.3-3" ANALYSIS 05' Your 2 1: ,5-Trichlorophenate Solution Vt II. -b The phenate solution was acidified, the resulting, oil layer amounting to 17% of the sampl . The 'lights" shoWn in the analysis include dichloroanisole, 2, 4 trichloroanisole and three dichlorodimethoxybenzenes. Any 2 6-Trichloro- _uff7ggr Phenol?isuincluded in the S-Trichlorophenol peak. "Component. - -- Weight Percent "Lights" 2 4- 2.9 Ui.? Dichlorophenol . . 8 Water 1.1+ - 85,7 2, 4 ,S-Trichlorophenol - 91.8 .- CR 2? Methoxy-u, 5-dichlorophenol 0.3 Methoxy 2, 5-dichlorophenol 2 7 S-Uethoxy-E, 4-dichlorophenol 213? 5?7 and 2,3,6,8-T3tra-? chlorodibenzo-p?dioxin 0.5 p.p.m. (Threshold - . . . 0 2? F133) The Anisole Fraction 3' o?Dichlorobenzene 0.1 pnnichlorobenzene .. .22222,. . . 2:22224232 1,2,k-Trichlorohenzene - . 21.0 1,2, 3- Trichlorohenzene 0.1 -1, 3, Tetrachlorobenzene 0.7 - Dichloroanisoles 9.1 Trichloroanisole 61.0 22222:: Catechol and Hydroquinone- - dimethyl ethers - 7 3.3 .J .Resorcinol dimethyl ether 4chlorod*benzo-p-dioxin - .10 pp) mam ANALYSIS - - - mt}. 35-47-922; 'v'This work is in progres; and will be forwarded to you later. 22 . - - Disclosure Resiricfed Pursua?D - To Court Ogden Agent . . - . Orange" Product Liab:hty :21 - .. .- Litigatiom 381 3.13.1; Procedure._- . 2. -. is. Sr-?ftr; . -- . Procedure Orange? Prbunf LIlabll-Ty . 22 17W em; w?e ANALYSIS oF cAus'FIc OIL AND 2, FENCL are . COFIIPCSITION BY - I 1: The following analysis may be made on 2,4,5-trich19rophenol 7- - ~hy The following conditions are used: ?r;igm_- Column .12 feet 1/4 inch SS - ?.FaIckingI - 30% Sorbitol in Chromosorb 80/100 mesh . 1 2 Temperature: on column, 250' c. on . . inJection port - 3 3 I Detector Hydrogen flame or thermal conductivity '?igg?z - .Sample Size: Dependent on detector used 34E?n?;: - IHelium or - - . Nitrogen Adjusted so that the 2, 4 ,5 trichloro- .., t9 1 2 Flow ..1 phenol retention time is 16 to 18 minutes. _Using the above conditions, the following components may be .4Eth? determined, if present. They are listed in order o?.elution. l; p-Di?hlorobenzene I: - 1 2 -Trichlorobenzene 1:2:4, 5-Tetrachlorobenzene; as one component uqa 2,5 and 3, 4-Dichloroanisole - as one component 2,4,5- Trichloroanisole _3 2,5- Dichloro-l, 4-dimethoxybenzene 3 Figgj?jgj 4,5- Dichloro-l ,2-dimethoxybenzene - 5-dimethoxybenzene . - .-Dichlorophenols (2, 4-2 ,S-and 2, 6-). 2,4,6-Trichlorophenol . Liig?Jr 2,3,6-Trichlorophenol I 2,4,5-Trichlorophenol - .. 4,5-Dichloro-2-methoxyphenol 4?Dichloro-S-methoxyphenol . dmrw??a?m?? - 2 ,5-Dichloro?4-methoxyphenol as one component . . Furni?: %3 4- ichlorophenol, if present, a Ears with 2, 4 S-tri- luzfii chlorophenol. A represeIntativeI chrIomatogram is attached. .- -- -Analysis of caustic insoluble oil or anisoles. is performed usiIng the following cIondit iIons: _um 3Column L: 8 feet 1/8 inch SS - PackingI . 20% Carbowax 20M alkaline on .. .- - TChromosorb 60/80 mesh - .. .. Temperature: Programmed - 100? C. to 230? C. at i: 4 C. per minuIte. 250I oniinJecItion I .-. -. 1;;Detector Hydrogen flame or thermal conductivity - Sample Size: Dependent on or used: CONFIDENTIAL 3. . i . Pursr?z . -f . To 'Court. Order at I - o-Dichlorobenzene . . i . m-Chloroanisole - -'vffp-Chloroanisole - cc: 2, 4- Trichlorobenzene . -ia7J25; 1, 2, B-Triohlorobenzene - - 9 2, 4-D1chloroanisole - x,x-Dich1oroanieole -- - 1, 2 4-Tetraohlorobenzene 33Ig?7 2, 4 ,5-Tr1ch1oro?nisole II - 7 - 5?;51? 4,5-Dich1oro-L2- emethozybenzeneg as one component. I -- 4, 6-D1ohloro-1, 3-dimethoxyhenzenIe . IA Irepresentat?. ve chromatoaram.is incluoedEIL- I.I II-IILI - - II. . ..Igzr: .. The Dow Chemical Company ma?, . I . Imdland, Michigan - I II.- I.IIU 3:13-1:72 - . 1:13;: ?11-?55" II .7 .-. he 15mm or I .Nitrogen Adjusted so that the 2, 4 5- trichloro- at! Flow - anisole retention time is about 28 minutes. Components are eluted .in the following order, 1: present. ?Im-Dichlorobenzene - - .g '1.ququ ?e??f-U-apgdon..-. . - .- -- . I..thlIgIaUO?I Till: INC) PM .3- Item-6.4 or vacuum-"h" CONFIDENTIAL IDiscIo's'ure. Restri Pat-34?; To Cour} QIrIdet. .- Orange: Room? L?ia?: Bugle-~13; . c. In: or. II In'u'vI'I Procedu}eI 23 -- - Wm,? mg W- I gags?: - I. - i?'rt'?fl'3?4 r' - a? I 5 nun-55:40 31e- .?nikslbf??h?l . . I - .. 2?42 .. - 39,'mr?a?f- i - ?3 I -(THE Dow CHEMICAL COMPANY 21 .k?I - i -. ammo M). robruary 23, 1965 King,? OLA. menu-.2, utr?rlsc .. rmnuamr Hi, 195Presen Burons . z. 0113 I v. Carma Insult: I it? 3 n. n. Hoyxo I. c. sun-nun: 2 Ear. D. E. PlIlchor 1? . :2 if?! cc: J. D. Doodcns on: Introducud Um mun-n: by Indicaun: nu: roam. .. I ?14. - . tutor-auon indlcau-s "Esau-r" nay In present. 4- in Don mourneucls ls concerned 1133-". about lcm, lorauluuora, ?Hus, roam-L. - I Ind Erbun. This n:eung ls to roviuv sums at our inc-lad? a! this subject. pulcntizl hazards, pos?lhlo 0110:: on Do: 13.130, luul inailcauons90:31:31. quarantine. Thusu In?: dcculons an to be . - nad- vuhuut constuernuon or ccunumc Impact. Suanlrizknz pant V. K. 531d Our had 1 . no chloracnc problems hunted In producuan I for 25 years until process char-.35 u-yrc In the :prln_: I of 196.. has-d on rah-arch mturnauon acruhulalctl H?.u . yearn, sou" [dons have brun put Inguth-r regarding the hind; 1 cor-pounds which :hm ?so to this problln. The 251,53? 1 has Men pruuy vc;l cslabhshed a conunknant. Alau. than l5 no. lnu?lcauon I at tho possibla presence at the 2.3.1.9 and two i other canpanant: I: "Unkno-n 30. um. "UnknoH0710 and that lhu rabbll. test drtert at It: I 1 .. ull dcu'ck pr": 0: Hu- 2.3.7.5- 3" dloxln In Also, VPC detect ammr. 5.0 hp2,4,5-7 acid. (Dy phunu on .: Hoyle mutated to nu vrner mu n. no! tun. Ina: VCP :5 f. in! detect 1.0 ppn.) 3" . . . I A?s; In sample:- tron In llu- pf'i?dl?. I a: 5 d1. lg" dioxin was luund In in?! 21-39 Md;. I ?5 if: id; .53: . usln: tho annual luv-t. Tho ananal has: Inn ?Idat'Jl-rul sane .- .1 4'1; unruly on: ha-Iplc Inn-r cn'u- n-rrn-wnlud ?gs: 1?52: Inpunucs renew-d T-achl prorcne-tnu_lrm?vi-3321'- :Sz?wgawj . . 2.x! 21; . 'Nuwe?. ?Vrt {in?! -. iri? I. a .h . rah", Gr .43? . :3 l? 3 ?Lin II I a. Viv?754,gain - sax-139 .15.. .flf .ilr {3?4 ul?. 1 a Izrs? A. ?i In? - 3'7? iarhvbig: - 9L .- .5 'rzi?. i .25 v-a usetwigs,? "?15 - - . ma. . ?E?Wam-epc?h . Batting of 11-its1or analytical methods and corrllation o! VPC Ind soisal data are not coaplots. . an; lightaon applications at 4 in r-pro-onts tho thrushold {or aoisai reaction. ol'. Ton oxposufrs pp: in TCP gives a niid traction. Ont exposure at 40 pp: in TCP gavs a positiro reaction. It is oncouraring to not. that exacting tests h1Vo indicatod no ovidonco o!.iivcr dAnago is exposed operators. It is: agreed that Eovc should save ahead with contact with 0.5. Public Hoaith Sgrvico and Dopartsont of Agriculture roare? acotstivas as soon as our scientific data is hotter correlatod. Tull coop-ration will be altered'as ruxards analytical. and toxicological.internation. rev-lied. Also,_contacts are to ba nado with other conpanioa who naautacturc trichioropnunol, Eorculos, and Hooker. in tonsanto on February 19, outnblishod contacts, care or discussions. on this probiea. 1: VII agreed that V. testing, Proc-ss details are not to be Diazund. Monsanto, Ro-o planned to contact his counterpart lhcre he does not hav- ho will suggest that Luv Corbin take Thonpsan-Hayvard do not Iako tricnioro? phonoi but are aware or and have been in discussion with Do: Poul shqud servo as Dow contact for any inquirioszvhich com. to anyone in Dow regarding tha "Exciter" problca. A1505'ano is to surve as a local point and advis- rogardin: possible hazards which any rcsu}! from tho 531? 0! trichlornpn-noi derived btoproducts unzii this situaticn is tuily resolved. Staohling Summarized analytical data on process o! trichiorophonoi as ?0110vs: der?wr' Calc'd as Dioxinll Unknown Bat. No.1 x953: Juno (1 Oct. 3 195?: rcb. 2 June 3 Sept. 25: Hov. 3 Doc. 3: 1965: Jan.1 a Feb.8 10L Yeh.?511133:11.'jp I I . 9; if}? x, 9* C32 {gag rli. Th Huhl . ?99 tut nan-Huron putwnunoa ?Inn aria. tun Hall oBiochcnicsi Research Laboratory, 1701 Euilding HAZARD OP HOHSAHTO 1619 Rabbit ear tests on twelve lots or Monsanto 2,h,5 acid have ahohn underste to severe response in eight cases at ten per cent concentration in ethanol. This continna VTC analysis for which was found in concentrations averaging about 10 ppa. This naterial presents a definite which would require all the precautions used in 199 Building and 3&9 Building to prevent injury. if it is processed at Building. Dow's invoivenent in ahippin: this asterisl to hiverdale and Hoodbury also concerns Is. There is a definite risk to their saployees. especially since they are probably unaware of the problem and are prohably taking no precautions. There is no assurance that their final products sill be free or contamination. The available evidence points to the osposita. In 3: opinion their producte should not he sold until aninal tests shoe these products to be free or a significant hazard tram the tot?schleroditentcdicxin sh: related_oaterials. street vs m- H. Torin? 4.1744413 nus-m 4 .IJIL unmann54" 43,31? 455"? ?7441? 35? H5414: 4344.- 3.5 "?344 44.414543?: . 343-2 I ?41: I It Aria?: 1 h? :55? INNIVJ .44. ?5?444'4?5?34'hsgg; 444- 44447344444444 4w. WNW: .Wf . 3? I, $355310 1.. JIL- ri?ff'l' ?352,454 'rr" .. - 129928 31?- I: I . .. 344-?! Jr." 5 54? [34:24.43 ,2 "354.3 =5 44??=i44 ?H?d 2? ?1 El; I. I "tn. ., . P115 W?th?J 31" I-I 7.74.1? - 1T. 5.16;. if" . . 4 ?1th . . 4,444; 42444 44553555555553 '4 ~44? 34Ju- 5'41? 545.55? ?5?15; 15-44 ..I . ?35 ($5511.54. \i '4 - . . :3?5?5515'1'34. 418? ?53? 4'45? 43-444" '4 94555? 45514?5Wf?444 4444: 41544-314 3.44:4 44414344. . 4" 4 34;; 4424 45 ?g 4 .44 g: 44 4444445.; 44:44,. 4. :34 454,- 44-4.; 445444443 3542-5-53 dad?s? [241?? l_4 inf? .II 595'55'51?5?5254?1f4 ",4??st1 - ig?g 445439;; ?5155'. 5 it? .. .r 3;?4?434 254.142.1591.- 3.444.441): a; I 353.- - 4.4-4: ,4 . {4494441 Jew-w; -w - .-.. ?-496 a ?Ohm tom 25. 1965 J. c. motor 1. II. liorrio II. I. roinouor I. o. atoohiiu c. I. Otio 3- 32IoCoy II. o. Iiitoo J. D. Doodono D. I. Iiotohor I. c. Ion-om I. L. con-bio II. I. Iloyio '0 no 3. '0 Iono J. I. rotor-on I. I. aodok of am a omen mm (ll Vii/55 Dr. Ir. llr. Dr. Dr. J. Iilkonroid onll Roy-om Vorhooto, liooltor Corporation Pronoio Ionnody ond Id chon?or, Biolond Alhii Coupon: c. 1.. Dam and John I. troll?. Ilorcuioo Pandor- Coupon: V. I. neoppod tho Don oituotion in tor-o or tho proble- ond tho initioi otudioo by Toxicology ond Environs-onto]. iohorotory rout-din; tho in-piont oituotion. lIo ?voodoo thio in gonoroi tor-o to tho otudy or ond produoto, ouro ono othor poopioo. Ilo node rotoronoo to omtriooi oro-o-dihont ioxin. llo rotors-o6 to tho ovidonco for ?n quootiono tro- tho group obout tho who-tho. Ho (boo) Ioro not ohio to onouor thou quootiono outth to ruin tho ovidonoo for thoir oxiotonoo in tho mpioo ond ond produoto. - 5mm IO I: 3-2mm lie. to. m. 4-4-71. nova-5m AGREEMENI 9-79 Tux now CHEMICAL 896639;; 1 o; . I v. a. Rule - 2 - "Inn 29. 1965 on- lolder reviewed the nedical aide or the Dow exportation .ha?c?aid that we now have approximately 60 to 10 cooac or individuala with chloraone rang tron two aevora cacao to cone vary aild cacao that were di rioult to diognoca. Ila ahowed alideo or the aura drc-atic none. The alideo were axolucivaly viewa or the taoac oi? the individualo o?'licted. lie deocribed in fair detail the appearance or the indivi- dualo aantion the blaclmaadc he then reviewed the cl ioal ctudieo that are be nude on theae people with cqahoola co the liver tunotion ate. Ila cen- tnonad the cingle liver biopoy that hao been taken and o'cudiad in which the liver wac nonal although the an had a rather pronounced can or ohloraone. Dr. holder alao nantioned the incidence of fatigue no: the af?icted {3910 aa being the other oigniticant ing in theae to la touched brief on tractnant indicating that variouo topical treat-ante were not particular artective. Ila doccribad the cycling or thic dioorder individualc who had been letoly-renovod tron ocure. Ila nenticned' that cone to love are approaching and or their trouble two or two and one-half yecro otter onoat or the akin dic- ordar. Ila alao 'acuta chloraono' which ia an acute inrlc-tory condition that appaara oonaidarably aomr than the nonal chloraone in individualc and cppaarc otter pro- nounced tingle aapocure. the acute ohloraooa ahcwc up within a tow dayc ct axpocura. Dr. lloldor nanticnad five to eight dayc epaoii'ioally. there vac ocncidarabla by the group on the chin dicordar itaoir. I[he hooker repracantativac related experience or akin condition thirty yearc after expo- cure. ll'hair cacao were nore oinilar to the Dowioide Me which Dow hoe experienced in that there were lo a boilc or large bupa rather than the aultitude or nail aokhcada and eruptiona which bow to ceelng in the current cacao. Dr. nodal: showed alideo of care and ?livore ct rcbbito that had been aapooed to the cyaaeatrioal totrochloro- -dibencodioxin. at: dicouagd the pathology in detail which I wil not atta-pt It?? .- V. I. nentioned the ctudieo in which the rabbit care have been treated with in benzene or corn oil and than waahad eith coap and water at varioua tine intervalc later. It expcoure occurc for very long, waching doeo little good; Ila alao briefly cautioned the oral ctudieo but without detail. Silvorctoin deocribod the plant otudy on wcching or contooination tron toolc and aurtocac. 'l'hia atudy indicated that bancane, acetone and Chlorothena no were effective in raaoving the contaminant tron toolc and alao ??t?r8ont and water with ccrubbing action could clean up toolc and equipment. Sana enaued on the ace 8? I 100.9? than-Io I Vlhroh29,1965 or datonont- ano uatar and tho point oado again that Itm aoruhhi aotion tor thia approaoh ._to ho . lion-old thou tho analyaio for totraohioro-p- dihonzodiozin hp vopor phaao ohrollatogrophy. Ila iiatod tho iiait or oonaitivity on variouo aatoriaio. Ila nontionod tho oil which ho dotinod ao a non-uponitiahio nixtuoo or ohioro totraohiorohonzono and tri- ohiozohonzonoa tho 11-4: of oonoitivity tor IBID in thia notariai io 10 pr. ?lho iinit ia 1 pp- tor phuuoi. and for 2 Aoid. oithaz aootio or prop on o. ?t-?iTI?Ihoo dot .- or: diooarnihio poak. Ila Ian- tionod that ho Ii?! anti-ta 0.5 pp. in aono inotonoao but to ho tho anoint roporto (1 it tho pooh not noaouro up to tho quito ioontitiah ion]. or 1 pp. 'lho omittiooi prohiol haa not pot hoon-aoivod for tho r-ooio ootoro. i'ho (anon! for tho ?ra-loioo io to oxtra tho ooapio {a ital-ii: about 20 groaa with ohioroi?orn about to hill liton). tiitol- tho ohio on to noon ooiida and ooah zith an oquai volt-o or [/10 oauotio to anon on: aoidio ntoriaia. i'ho chlorofor- oztzaot thou io oonoontratod hp ovaporotion to mo-tonth tho originoi Volt?: thua, tho oonoontration of tho diozin in tho ohiorotorl 8 ii ho ton ti-oa high?- than in tho original ao-pio. Ilhon tho analyzia io oonduotod on tri- ohiorophonoi. tho natariai ia in oauotio to tho oztont or M, ond thio aoiution io thon axtraotod uith tho ohlororon and handiod aa indicatod ahou. A ouoation aohod about tho utilization of dotootoro . othor than tho tin-a ionization uhioh ia apooitiod in tho Analytical laboratory lrito-up for thio anolyoio. om haa not triod tho lion-o dotootor haa ozporinontod oith alootron oopturo. Ila otatod that thio unit ahouid not provido any grootor inoroaao in aanaitivity. In actuality ho tome a aiiaht inoroaao in aonaitivity hut thou aro too any ohlorinatod uhioh up aatuzato tho oiootron capturo uhoao in too aiol to ho or praotioai uoo. Ilo ounarizod hp aar- ina that tho inoroaao in oonoitivitp io not Iorth tho ortort to on toh tron tiana ionization to oiootron oapturo. A quootion aakoo about how tho oztraotion ia portornod. om otatod that it ia porter-oil in a uido south hottio on a ahaltor tor ono hour. it too not non- zionoo, hut it ia tho that thia ia ona at roon tooporaturo.) Ila Iontionod that opikod aa-pioa hava hoon 19663! gag H7 I..AI nanthiewe cent. the :etio oi' eolvent to the Interiel being extruted cn.thier etep ie not criticel eccording to dill. i'heir etenderd. procedure it 20 gren- oi' eenple end to nillilhrw of chloroform On trichlorophenol eeoplee ciricellg. to grene of phenol ie converted to phenete -- ll: percent ecncentretion in weter. The phenete eolution ie extredad with 20 nillilitere ct chlorofor- in cingle?extrectim -'ihe chloroform ie ccmentreted ec thet the ccncentation or the dioxin will be ten tiled thet in the originel mic. l'he queeticn oi? of dioxin ceue up end Inniddill etetr?l thet he fond he eon dictill o-dichloroteneene .7 n1- tetrechiorotencodiexin. lie eeid thet in hie opihlee the eecret woe to ovoid dietilling to A ne?er oi' the group eeked it couples or etenderd Munro eveiiehle. ?lhe enewer wee gee end no ewlee weren- vided to one or the re tro- eech cm. eelple hed previously en iven to Dr. Kelly 01' m) I oueetion or ichoretory ee etv in the cool icel work- up end the tonic preoeution oi' weering viny glovee woe nentioned. Infarction reletive to the gioveq we used woe provided to the group. Diepocel or contenineted iehorotorp neteriele ond plent neteriele wee He nentioned thet now hurno .e cull enounte or weete. lien-old dill etcted hie lb oretory etudy or oonhuction ehowed thet 99.96 per centd? the dioxin eenple not burned at doo?c. he deecrited w. we hit thet our prectice or burning enell elm-Ito of dioxin wee core one. V. I. then outlined the roJcct in which plont produote not nentioned 1 none were epiked with more: enounte the m. The I ilte eenplee were epiit twthe purpose of checking our one yticel proceduree for recur: end correlating reeultc with the nethd. 'i'he queeticn or epecii?icetion, queiitv control epecitiution thet ie, wee reieed end we were eeked it we could give levele of dioxin conteninetion which were pemieeihle linite. V. I. nentioned thet et we ore ueing Iero with: confidence or 1 pp- in unplee. There wee eo- on the prohien of cuetowere tiniehed po- ducto under tor deeirehie conditione hcelth outrol then we?ceg. provide our work-:2. in our own plent. Thu egrec-ent enong rou thet we could let: eti?ord to cell contenineted produgte2-. ?gg??aprtagf1'1: 2. {?91 oocu ri ?Iher were eir of ecti tho wen deec Bio- 110 V. I. hole - 5 - 395 i5 - Jeok htareon then the data tron aniaal experi- ?nenta uaing pure ey?etrloal tetrachlorobenaodioxin. ranging tron 8 parta per billion to woo gerta per nillion or tetrachlorobenaodloxin in benzene had ean adainieterad to the rabbit ear. noaage in noat 0.1 al per day. aingle and nultiple expoauraa have- been atudied and Iultiple expoeurea adniniatared on a five dare per ueek baeia. the ei ioant taotora in the atudy are doae, the unberora loationeandthadayaonexpoeure otthe aninale. me uhioh ?reported in the groaa ob- arrvaticn or the'qa?ltion or the rabbit'e ear b1 the toxioologiate. ?le not include tothologioal tindinge -- there ia not on? data in thie area line level of reaponee rangee tro- none through very alight, alight. alight to noderete. moderate nodarate to aevere. eevere. and extre-ely eavere. Jeok indicated to the group thet there it not a aharp definition between oate oriea or reaponae and indicated alao that there it use ioulty in graphiu thie or raaponae. Ila daaorited the rec onee tru eingla a lioa lone to the rabbit ear tiretl at 1 parte per nil ion there no a eevere reaponae in eight dare; at to perta per there a alight reaponaa In eleven dareparta per aillion there no recpmaa. Il'heae teata were run on aingle rabbita and without nothing the nterial on. Jack than the uultiple a lioation data uhich he tool: tro- hia anor graph of ie data. i'ha lnportant pointa that he made tron thle data Here tirat that at the linit or no aenaitivity a aevere raaponae an: be produced. In other uorda, even it the vet doaa not detect ICED. In rattan-c In! Ittll Ilia aeoond inportant point on that the induction period for raaponae averaged about ten dare on the anlnela in the etudiee. there a brief than about the air that rare taken in the Silvaratein nentioned that eone air aa-plea have a activity on the anianla. 'l'he degree oi? reeponee ia alight and the nunber' or eeaplea that ahoe aotivity la call out or the total number taken and the anount or air that not be aaepled ia very nuoh larger than the eaount a non nor?ll: breathea in an eight hour day. ?l'he heating Ice adjourned. The group then proceeded to the toxicology Laboratory to vleu or the teat aninala. 'rhey uere ehoun reaponaee or varying intenaity and theae uere deecribed. Thia detonatraticn appeared to have oonaiderable l-pp lioohenioal heaearoh Laborato 1101 Building was.? 896880 . 'e 00875 V. I. In. lurch 29, 1965 an participants and to awn-auto Ion tin ?out. and Ill wanted that tho: atom Inn-u and at to common thun- mutant to unm- utoty walnut out ("any quality control) for un- mum not. In this In that tin and mm In it. own Humanity. of Don't effort to It.? than any a .. In um toll uhotlm- taco-planned our sullen. due! I he! attuned until our effort and the tumult mind?.*Fvll.ih? - . April 1, 1965 Dow Chemical International S.A. Beethovenstrasse 32 8002 Zurich, Switzerland _Attention Mr. Peter Koopmann - Manager Bio-Products Sales Dear Peter; I am enclosing a copy of a letter covering the trans- mittal of the completed contraCt and financial settle- ment to C. H. Boehringer Sohn. Our agreement with them calls for payment of\ to them at such time that we are satisfied that we have solved our chloracne problem, whether we use their know-how or not. It is our judgement in Production and Research that we have reached such a point. Paying them at this time will be a signal to them that we are no longer in trouble. I have been informed that my choice of words in answering Dr. Doll's letter did not set well with you. I hope that you will accept my?personal apology on this. My intent was to emphasize the secrecy agreement as an obvious reason for your lack of in- formation. Let us hope that the entire incident may dissolve away as new problems and business opportunities command our and their atte??~n. Best personal regards, Walter B. Trapp Benzene Research Laboratory 474 Building . mak all." 55?15 ma. on. 2.: boszniLcha '1 .. VIA RCA . YOUR Discusswn Rtsazr or THE SERIOU 3253 OF OUR HEALTH OR OF THE - All-no.6 COI. HELP THAT ALL OF YOU AT BOEHRULGEIR HAVE BEEN TO US. LIE HAVE COMMUNICATION ON THIS WITHIN OU3 COMPANY BECAUSE 'r?wm Ay??g?gg?a cm: seems; or THIS KOIOPMIANNI LL07 ARE TO THE YOU ALLD IAIIRE PLEASED TO LEARN THAT IT IS READY. LIE ARE MOVING AHEAD SOLUTIO OF OUR PROBLEM ARE ANXIOUS TO COMPLETE OBLIGATLON TO YOU. in 2.64:4 DOW CHEMICAL COMPANY .xumou cm "Lanna-Lunar? 7 FILE COPY I '11 OF HILL FOLLOW. IR I coanlALL?rx. I WALT- #711777-3" 1U . . ?g CONFIDENTIAL Disclosure Restricted Pursuant ff To Court Order. "Agent Orange" Product Liability 4 Litigation. 381.. a- DOW CHEMICAL COMPANY aware: . -. I aunt-nun - ., -- . I I. - IIHLAID "e . - . g. nan Islholland DOW CONFIDENTIAL 3 I Ianager .3. - .9. Ion Cheelcal of Canada is larnla. Canada 115 mus-momma!" rat com. All: mm 2 I have not heen your request tor lntoreatlon to 2; to dlecueelng the ethect nrohlee elth hugatuck and the a; I have heen atreled. hecauae the eethoda c? have heen changed and are 1n the or helng cleared and . reproduced. I expect thee any day. hut rether than ealt longer. I thought I ehould adrlae you c: the 1 e111 tend - goo coplee or theae eethoda aa econ as they hecone aeallahle. I II regnrd to the overall prohlee. ee are to do pcaalhle to avoid the poeelhle occurrence of chlor- none In an, the or one or trl- chloronhenol. cold and lta derivatleea. I II you eell thou, ee had a eerloua eltuatlon to our operatlng te heceuce of contaelnatlon of elth rltlea, the eoct actlee or ehlch 1e 2.3.1.8-tetrechloro- dlhentodloxln. rhla eaterlal la exceptionally toxlc: lt haa a potentlal for produclng chloracne and ureteelo 1h- Jure. l: lt le present to the lt he earrled through lnto the acld and lnto the eetere and hence into toreulatlone ehlch are to he cold to the nuhllc. One ot the ehlch ee eant to aeold lo the occurrence of an: acne ln conauoere. 1 an concerned here ulth per- eone eho are ustng the eoterlal on a dallr. repeated heela ouch ae cuatoe operetore ear lt. l: thla thould occur. the ehole lnductry he h'rd and I uould expect legltlatlon. the eaterlal or very eohtrole upon lt. lo the ealn reaaon eh: on are to con- ?eerned that no clean up our oen houae tron rather than havlng true elthout do lt tor ua. 1n thle ear. no can approach the peohlee to an orderly nanner. I: the producere and handlere or'thla eeterlal cooperate. there to no eh: ee cannot get nrohlee under control and therehy hopefully aeold leglclatlon; to other eorde. let ua nractlce good At the tlne. ee are of the onlolon that eeterlal no tetrechlorodlhenro- dtoaln elth a or_l one doea not an anorect- ahle haaerd to conounere; llheelee. ee do not that euch Interlal eonatltuteo a to pereone to Iv" G?dFi I. ~150th 2., 1965 giants handling such phenol. 2 acid. or 2 acid Inightm mthat no aro continuing our on this tarticuiar prohicn tron tho standpoint of studying tho other uritics which nay have tho capacity to produce this typo ?roaction. Also, no arc accounting to quantitata tho of- rocts o: tha tho-n sch-sons ?hon added to has. natariais. this nor! in progrossing v.11. hut 1t ni11 ho sovora1 nonths hororo no have a cospictcd story. 1 souid urge again that it your hi: cuntoncro such as eo-Op and Isucstuck have particular question: about this prohica that you invite then to con- to Iidiand uhcro no ho to discuss the nattcr in dotaii nith than and shou than that no have 1sarned. Ho cro not in any nay sttenptin; to hid. our prohics under a heap of sand. but so cartainiy do Int Iant to hnvo any situation: arise which I111 cause tho roguiatory agencies to hcconn rostrictivc. Our urinary ot- Joctivc is to avoid this. I trust that you to very :udicious in your use or this 'ihtornation. 1t couid he quit. caharrassin; it it noro nis- or aisuscd. '0 to h. liochssicai hssarch Laboratory 1101 nuiiding II 6-2376 Wad cc: L. Siivcrotcin c. Otis Grady aside-an Anctuta O. lo '0 '3 ?0 (2) n7.?12.2? I 2.81 ?hdcr no circa-stances any this letter he rooroducod. shoun. or cent to anyone outside of Don. I I (mm M00 -- -7 - - 1-47?1? .co rials-blow CHEMICAL COMPANY _7 68010;- MIDLAND DIVISION October 21. 1965 W. C. Timm These are the points that I made in the presentation this morning to Ben and Max. We spent considerable time yesterday with Bechtel reviewing their performance generally and speci?cally on the Trichlorophenol job. They have gone back to the New York oi?ice and will have a review of their estimate on Trichlorophenol completed this Friday; in terms of a three to four months relief on the completion date. Bechtel sees the situation rapidly worsening with the mo st problems likely to occur in 1966. Contracts with expire in May of 1966 and additional costs can be expected at that date. 'We challenged Bechtel on their performance generally in the location and speci?cally on their estimate on this job. There was no great encouragement by Bechtel on a substantial reduction. We believe their estimate is high and that there is a good possibility of building this plant for less than? and will make an all out effort to do so but the board's decision should be based on the I at this time. - Our engineering will be completed by December 1. We have spent . now and are spending at the rate of\ per-week. It is too late to make design changes. Equipment is in route or too far advanced in fabrication to allow changes. We are now scrutinizing not installing parts of the plant and yet have the capacity in the range of pounds. We will cut back on the if. the economics are favorable. I stressed to Ben the seriousness of one more incident in the phenol plant and the e??e ct that this would have on our Divisi :L'on saooer generally and our over-all relations with the Union. Disclosure Restricted Pursuant To Court Order. ?Agent Orange" Product Liaou.ty Litugauun, MDL No. 381 C1.9.4.0600 Procedure - I (3 SE- . W. C. eTunznw 7 - 2 - .October 21, 1955 0 Be: sge asked wha: c: the additional costs had on economics T:ichlo:ophenol and also on 2, 4. He asked about the basis of the eeonom?cs. He asked c? and the amoungs rbazque have asked id: at various-times. He asked-how mud: capital will be written off on: bocks as a result of ob solating our Triablorophenol facilities. He asked the efie ass on costs of this inc-:eased expenditare on bci?. Trichlorophenol and Z, 4. 5 Harald Bosscher C: to. Disclosure Restricted Pursuant To Court Order. ?Agent \1 Orange" Product Liamuty CT. Litigation, MDL No. 381 C?m Procedure - M- I. - Mam 6 a. 711W ?nut-II- . - .. 4 - ALBERT KLIOMAN .0 P?s U-wl- '1 .1 lulu-Arum 30": AHD msna 0 IA 0? 5.1 RECEIVED June 22. lfiob JUN 231950 . Mr. V. K. Rowe. Blochemical Research Laboratory 1701 The DOU- Chemical Company deland. Mtc'mgan i'l'l'CC-l. Dear PL: Now that I have collected the detatled data. tt 1! evxdent that the tetra- chlorodtbenzo-p-dtoxm study was by no means a tiny or df?atr. This study was supervtsed by one of my graduate he kept swing me negattve read?out throughout the many months of study. Ipersondl)? saw the luchCI? the last two groups which recetved the htgbest doses. The skeletal report I nent was further reduced from the very bony sum- mation he gave me. lwas hopeful that the report might be aired to the signi?- cance of the results. I almost sent you a letter saytng. "We the work you ordered and found nothing". (I guess those happy days are gone). Wherever the subgect could not be followed for st: weeks owing to sudden dtucharge. or to dectstone. detatled data are deleted. lam grteyed that so has been learned. especully unce practtcally the Whole grant ?as spent tn laboratory work. was a dtscouragmg every good wash. Irematn I-oaoo MOO Very smcerely yourn. .4.Ir AME.- 1: Enclosure DCW CORP. #15 'Albert M. l?bg?an. M. D. I an; :?rr7:.Jlt-l' 1? ?11s a I . 1w?. 's .- 7? .r l. Method' ?l tn The were separate groups often healthy adult males. - Each group recetved a different total dose rangmg from 0.2.43. to 8.0.13, EFF The test material was dissolved in 50/50 chloroform-alcohol. the appropriate ref? Each group was smdted Ln No phases; the first consisted oi a smgle dose: -, After a bro-week rent. the same total dose was gtven in equally dnnded doses. 1 i ?23? A . . .141? . volume was placed in a glass cylinder and the solvent evaporated to a stream "In Ida: I I I para-m - . H. '1 .v Akin!? 4., 1. of ?owing ear. The stte was covered by a gauze square for twenty-four a {In I my I hours. The dAtly repeated doses were to the same stun stte. The applications were made to the forehead on half the subjects and to the rend-back on the remain- ing half. One week after the emgle dose. and 3-4 days after the {mad daily dose. the Iollo?wtng tests were done: CBC. BUN. SCOT. ALKALINE and in the second phase only. The aim was examined weekly for s'u weeks after the last doseeach phase. the subjects were exammed by an tntermst (or stuns o! systemtc Wm}; f?g. illness. in: a Results- -: The treated sites remetned normal durms the and {or BL: weeks thereafter. There was not the evxdence of acne. etther on the forehead or the back. CHEMICAL CORP. - ROLL #15 ment. AMKII Result. . . . DOW CHEMICAL CORP. conlmued. .. A: the dosage level. #15 igemc and was not harmful to the subjects. I I No subJect developed which The ltboruorv values were unaffected. 1 ll could be related to the treat- the tent agent gave no ev1dence of bemg acne- 77;, Re Ipe cdull) lubn'utted. A. g. .3 Dub .33 Albert M. King-nu. 14.13. - .. Ii? $1 e11: {w?jvi? il?l', _}ll4 1, - Hi" ?991* [1359 4'9 4133" (5 5h" I: II I Erg?rrf?? II, 14" I. #133" ?lls-1'11;: - IV: I. r?g?I -, 3'1 . :Tr'f?n - . MIDLAND 1961 0 4E) -. . rum 3. DLnon 32;;?23 3:23-9:13" Depth-nan: DOW 7518723 '3 L- L. Corbin. DE . D. 13. Plath-r. BPC 3.1.. 1 n. emu. up: -, W. J. M:Coy. DPC - a. 11. mm". 607 i 'moupson cmzmux. company. 57. LOUIS. museum .6 h. - ., (h Yo'brury 1?61. W. J. H?Coy Intern-ad nu ?at: Mr. S. Chunks! lad uLL-d Dow ban-Ileana an! they $25" 3:39:53? as u_ um?: ?sum?: rub a? 17231.? phi-.3. and that day but um. man-um: uh! they tho-ugh: no ',anm. The; vandal-.611? can? mmbrognrdu .1135" 51:73: nudist.) pru?co. Icomuod Dr. Molar. who than an? 34!. 1" i' with him main! Lap-01:15 o! prom-m. wf E?E'??lh Ll my from Dr. Hr. nun-y than -. "and 13131:; am chemistry oi this maul-ht. and Dr. Ham" 2 1-3369. smut? an: be contact an Ln "and to "nun; as.? am. .g?r-o?i?r i ?v -- I?nm-yawov- - - I On or than Fobtn-ry 1 Mr. nuchlay cullAbout calcium nuad by cod-u: with mum? uncut-d - i {5.1 . the mad-nun cl humorophonol from 1 . tau Men 0.1! ands: cart-la whlc? I did not daurlbo. 3.5.1: . . the can?: {archbi- olln could contain coonldanblu uncut: at I 513??" 'vny um; um ?Mme. had sch-um? z. 3. 7. a- A Wort-?bolsodlnh. I Micah?! to him that L33. math! . but 091? "than.? teal: spunk-1.11. bu: so. .ll. ago?romoly A. ?all cuomou. Ho Lndlulod that they hid boon distilling pom . - - .11.- Ol LII: can? label." than Lb. opal-ILL"- ?91 on o! consul. 1 I .84 tau-avid ?that spilled or vp-Luhd 0d,: 50! lunch". Ha. - - . Lb- twnoo had up". at salad? in! dud :utr - - scan as. canan" mam-ma prune: an - . - - ?mw-mz??waaMr:? ?dd-15$- .AQ. (J?s?lar. . .15. 1967 Aryan-u" Mr. Buck!" had naked Dr. Holdu- ho- to up tho oq?pawnt. etc? and Dr. Hold-u indicatnl to him that he must tab. C- curin- pnnulonu. including the use at rubbcr lulu And gun-o tI-d 1.5.3 noplruon. Ha nomad uurprlood tint we would :0:an nut 93 - - mot. muoupl. but I roller-tad that lurb pucluuonl won whit .. . ?county. It; thus install to know I though-t thoy aid-437:? - - mu chi.- up th- commLA-Jud oqu-Ipcmn with ?nun. I m: at 1111. you! an obllgatioo In all him that than: nu the vent thing he could 3 no. 013917 hum It would walnut? the nut-rill. can-1n; It to ?xin- and (Enroll olnuho n. Th1. was not nu ?y ta got his?? I 31". ?Quad Ictubbln; down tho oqulpmont with doterpnt or - Ooh-nu. 1 Maud um um. could b. don"county procauuonl ur- uhn to prnont contact in: tha I "luau-d um b0 aluy or uh .lpc "mph. ?the equips-aunt to ?at-min th- :10ng of commutation. 1 luggoattd that thin Ibex-dd hul- ho dan- Inlaro and that tho clue-up. H. huh-d how such only. 53,- .- m? 5. nude. 1 taunt-:1 to him that us had arr-Loy"! I ma?a-4 of Cit: - Manly-Ila and ?so and Melanin! omplaybg I ubbit Bo ?115 not .32 for 63911- 01th:" pun-dun. I d? than hum-2. '2 . ., In tho: um who" he could ?nd taromuo. won :Noncno. 1 manic-9:06 to and Mr: coplaa e! Fania-at stud-s (turn my publhtud 1 i, if "?3an run 1 had. and m. rm bun dam$313.1; (mot-unca- with Mr. Budd-y van with]: th- tnaororh 0! our. . - . - dicta-1:195 tb- probhm. Tho lubtmatlon on activity as: g:bpa :73: has :25 an. 511.". :3 9a other paoduorn . .. i; OI war a year ago. This In. bonanza It quickly pra?u that Mr. Bunny bod UIUI nod-rounding of th- tonttologkal i . aspect- 01H. probhm. Had he Ink-d for math-Jr. Itc. . Iqu luv- . _s agracd to and than: to him. Noun-r. that. be null not. 1 no - ?ft-II? to values-Jr. I's 1 0 EH on Law whether thin taint-manor! 1. ol? nay vdua to you. but It i will. at 1050!. hoop you Luann-d. 1! you have Any ?painting. or on;- . i [0011511. (or hutbar action. plans. do not hunt. to contact moRon-ugh about": I TWA-23.20 - .: dill? Chloracnc ?In 1 r. Ya . . Carrel-pondonco .. ., -. . ft'ij v' .. '?owmm?_ 7! ""ra?vl? as. . 4:53}? . - . [y MELANIE Fobvury 196? 25.5.. - run?: a. mm. ?1 $1394., .. gigs-caut- heparin-uni (t ?big-3?, .s --.-, ?21 -- en L. Corbin. DPC D. C. Fletch-r. BPC '5 I. ll. Govt?. BK hf. W. J. McCoy. DPC (oi, . D. n. Holder, 607 ruoursan (141:3qu company. 57. LOUIS. MISSOURI. Eff, -I. j. -- Ch Fobrurr I. "67. W. J. McCoy lnIormad an that I. Mr. H. 5. a! Thompon Ila-ll ullud Dov that they 33 "fa?fgf?h? lead-on! unlocks-d .115 the man-hm. oI?H-lchlon- 'rngB-Fj phi-d. nid that day has! um. runs-uh day than!? us .chloncao. my uncured l1 wt could nd-rlu than Lb "and to 5?33?" new pm?ca. I. contact?! Dr. Holder. who than called Mr. :51: eaau?hyllad?qcu1d with hln: undies! upon. a! premium. ,?gwgg', Riga In my Hanna-?ag from Dr. ?out: an Hr. nanny than ?and 3131:. about lb- ehnmlatty at this ninth]. Ind Dr. Humor 3 {35941-32933, mm Ill! he come: no in "pro to m. a or 35003 1 31!. Dustin, ?11196 no no. that to luau about chloral.- uund by come! manta!- 3??th ulth i . the mad-?an uhhlonpbonol tron: I to? Man that nadir cart-In which I did to: churn?, '3'11'2: - . [tho {n?oln?o could coahh consular-bl. nmouu 0! Iii?'2?? wry may um um ma mum? z. 1. 7. a- 21.; Morodholuodluln. I halal-d to Na: that thin muzhl va- only mun-011 Ink spunk-Ur. bu no an oxil?omllf chin-Lemon. Ho hunted um they had boo: distilling ?an - 011.- 9! Cat: cannula; uluolu than Lh- oponuou p! on o! coda-d. 56512?: and md? O?hll' apl?ul or 39:3th out: A hot Idochh. HI t2. tuna. sud upon at u-Jaoloo ha] and Shah . - - W?a??wc?lw.? ?l to? Ida?to n'saz- tub-r by other mural) proud la n? Iain)". -- - - - 1 .. Mw- - - . --I 533. . ?1 u?itIDh-b-b.1107.? ?county. Ha than watt-d to know I thought tiny - an? clan up tho cant-Inhaled nqnipmant with than. I hit at thil point an obligation to toil him that nun: In? tho worst thing he could '9 i w. hot-nu it would volattliu tho mat-rial. can-tn; It to 834 clan-horn. Th1- uno not tin my tn got rid 3:.75- all Lt. Ho Imuud down tho equipment with detergent or ?inn". 1 that uu- could be don. In and. uun that all "canary puma-Lion- ur- uk-n tn prawns cont.? with the pupil. I ?mutual! ho nnuy or an iipo sample. at tho to tutor-ml.? tho dogs-n of .t luggontod that should tn don- botnu and nan clean-up. Ha nulud how annular. ?13: .- would ho undo. I Maui to him that nu 5nd anointed In 0! i . ?up? n? u" ?My cmplayta; nhbtthe" prawn". 31,. g: 1.5-kb. j? . - . ., 2'14Ws'??l . :JhP-n' us than him vb". bl could nu Information about :Moncnn. Ind 1 . ?Smut-d to and Mn topics of pertinent from publish?! #531 118.0qu inch I land. had this bu bun do?. - ?ag: taut-ration. with Mr. Hulda; nu tho tum-nth 0! our. . ?din-anion of tho prohhm. Tho information on the physiological activity a: 3:13;; war. has than 517". tn tha other pauduoun 732-?) 0? trickier-97h?! war a you- nln. Thin no beans. it quickly 5'11, Ivan-t Mr. Backlog ind Littl- of tin nip-ct- at problun. Had he anhcd {or mthodo. etc. . i would tun latncd to ?and than: to him. linen be It.? notulna-3r. I don't tann- thin information I. of may vnlun to you. but it .. warm-laVin-An 3. Dunn n-Z- H. 1967 . . . 2 .- . . App-"Ill! Mr. Suki-r hid llkod Dr. ltoldor bo- tn Glenn up tho ?3 oqdpuunt. ate? and Dr. holder ludiutul to um that he must talu c1 . null-uni pnuulonn. including tho un- ol rubbvr null. And .luvnn r? un?t-stun. Ho nomad am u. wont "command nut: 0? - non" :nuaupn. but 1 nit-null that curb precaution. vor- what :3 - - I ..5- I111. at lat-t. has; you Litton-nod. If you in" any quantionn or On;- soul?. for nctton. plans! do not to contact ma..- Runs-ch about." "U'zo d1" Chloracne ?Correspondoncn . -- - - -- -, .. - - - p1! 94'rfili (:lilihllt:l\l. Ii 2 a . 'lmuxn, norms 0- February 3, 1967 --auF .2. cc: . .. rbi: . . D. E. Fletcher I . J. H. I Pros: I. J. i a mnpsos CHEMICAL mummy ST. LOUIS, utssom: a Ir. I. 5. Buckley of Howard . Sheldon February 2, inditattr; that he thlOVhd [hwy have a severe chlaracnu azth away 0! esployees. He indicated that they airwady have r.u sen affected and believe that they may have tun mare caployees that appear to be allected as Hulk. The; 5 :re using Hacker's to gate their 1 1 . Buckley '33 asking 1: Dow vould have any rucamnendatlons . i tor Iedlcal treatment for employees. le do not 5 reel friendly taward thas competignr as tar as businuhs are but believe that any advice 5 rauld be in order. I: you concur. he vauld . a phone call and his nunhmr 15 Area Code 314, 5-6508u?77.$2.?ie'yLl- 'ui?li? '11? frme?u?s-v fezrofwcg my {19 .IU rut now CHEMICAL COMPANY :nu . sumo to w; - not Iuildiug . . - ~00" liidland. Iliuhi an 4-7.. DOW. EPA acumen 9.79 Doc-Ibo! 10. ?9 I. I. Ilair lanagar of and Duvulopuaut Agricultural Dapart-ant 00! J. c. J. I. Johnaou D. D. IcColiiatar I. tho followin ia a to rt of tha talaphona call tro- Dr. Iurgar tha no of Icianca and tachnology, which you ratarrad to lo. Dr. Iurgar told no that ha waa awara of tha wiait that Dr. Johnson had nada to Dr. Dulridga ooncarning tha a.a.s-r rohlal. Dr. lurgar indicatad that ha waa intaraatad in aura of tha dataila ooncarning tha tarato- logical taata which Dow waa going to conduct. Ia wantad to know tha atatua of tha taata. i told him that tha rat atudr would to oonduotad tirat and that tha rata wara on hand and haiug acolilatad. fha brooding would atart on Dauaahar 15th. tha doaing oi tha anilala about air daya latar. and tha would ha tahan tron anilala aaoriticad hoginn tha wuah of January 5th. I told him that ahurtl altarwur groaa ohaarvationa would lihaly ha awailah a hut that tho hiatopathologic at tho aolt and tha olaarin of tha to: ohaarvatiou of ahalatal davalopuant taka aawaral hora waaha. alao indiuatad that a aiuilar taat would ha conductad with rahhita and that could not ha atartad until aowatiaa in January. but that wu hopad that tho whola job could ha tiniahad and raportad in April. Dr. Iurgar waa intaraatad in o! tha dataila oi tha taata including tha nuabar of aniaala to ha uaad. I told hia that I would aat our lulan Iaalth Laboratoriaa to iurniah hin with a aat of tha protocola. callad Dr. Iohinaon but ha ia in Iaahington thia waak. I did talk to Dr. Holallo. la aaid that Dr. Iohinaon had tha propoaad protocola with bin in anticipation of a wiait Si 0008899 o: tho national Iclanca at laloloh. not?: aodlanap?olla .?la coin! to to hava Dr. lob! 1 ?t to tooth with an and Impala If cap at of tho protoco; on ho aallod (to. to Dr. lunar. (or. loblnaon all? Iota: In tho day and mango-auto vat-a lada to hm tho oatorlal typad 1n tho oztlco and da- Ila-and to no. largo: by at. aloo aantod to tool! about tho oaapla uhlch Ito can no . I told his that tho oolplo had boon takon (to. our molar plant rodoctlon that It had boon too ohaolcal an and a hlo-uaay aathod and tho ran to ahouod lt aoato our opocltloatlon o! containing than no of tho ornatrlcol totrochlorodlhanao- aro-dlonln. Ia olao aantad to know who tho todocau o! .lA-l' told u- Dov, lonaanto. lar oa and Mam-Hayward. Io than non-ted that tho nag-la ahlch Ilonotlca uaod no I author loom and 1 aald, goo. 1: It no tho out had hoan daaorihod in tho llonotlca '30" on oat-chow? olnco that an Iron nla-ond-l all. who to no longor in tho of mulaotulng 2.4.5-1. lo vantod to know 1! than would ha to toport during tho contoo of tho a rlaantotlon and I told Ml. a. than would, and ha an tho: Ioold vary loch llko to tart to?data on tho of tho toota. I tapllod vo could glad to hoop a o?lca informal. hr. loo-ad loot cordial and lntorootad. Ia Iada nolao unorthatoqooatthaIIC'l'aok Iotooladotom to aatand tho tlaa hoyond January 1. 1910. to: oonaldoratlon at tho poutlon ropoolog tolarancoa o! lovavar. . tho natnro and In! of hla lurch! loodo ?no to aoapoct ha la a ?1 hopotu lg aupport of tho moo-t. hr. lo aa tolloual Dr. word 1. humor . ?(loo 0! lclanca and tochuolon lucotlva at tho Proaldont uncut!" otflco laohlogton, D. c. 2030? lto tclancaa Ila tolaphona to (101! I . at Iagolatory lalatlona Ag, 000870 <#543; - - I 952: - - g, 4.2 12-51 -- "soassmiwr_?r4. om - 7 1 THE oow CHEMICAL COMPANY (3- i . 9000 Building Midland. Michigan 0 December 10, 1969 Blair :3 - Manager of Research and ?9 Development as 2 Agricultural Department Hansen 2 J. E. Johnson I: I D. D. HcCollister i R. 2. Naegilgn . . c, . The (allowing is a report of the telephone call from Dr. Burger of the Office at Science and Technology. which you reierred to on. Dr. Burger told me that he was aware of the visit that Dr. Johnson had made to Dr. Duaridge concerning the problem. Dr. Burger indicated that he was interested in learning more 0! the details concerning the terato- logical tests which Dow was going to conduct. He wanted to know the status or the tests. I told him that the rat study would be conducted first and that the rats were on hand and being acclimated. The breeding would start on December 15th. the dosing of the animals about six days later, and the ietuses would be taken from animals sacriticed beginning the week of January 5th. I told him that shortly . 99:: afterwards some gross observations would likely be available dug.lyw?gg but that the histopathologic examination of the sol: tissues 7 .{Eg and the clearing of the fetuses for observation of skeletal . i development would take several more weeks. i also indicated that a similar test would be conducted with rabbits and that these could not be started until aonetiue in January. but that we hoped that the whole job could be finished and reported in April. Dr. Burger was interested in some or the details 9! the tests including number of animals . to be used. I told his that wouls 'st our human Health ape 35- Laboratories to furnish him with a se. the protocols. - I called Dr. Robinson but he is in Hashington this weak. .E?gr" I did talk to Dr. Holsllo. He said that Dr. Robinson had i I- the proposed protocols with him in anticipation ot a visit - .rnr . . . . . - - . gal-,sun-see . - . Pno,? cl..aa?gt3 . . I'u . cu". 3-. 'h ?1.1mm: ?3 59-9 I F-u . - .213n?? 4. 6.5-- . E-r ?io 45'. ea. gig eye-t . 5'5: . 5 I ?Iri, 1T7 ?1 varBlair 02- December lo. 196! Thursday to Dr. Paul lotin at the Laboratory of the Rational Institute of Environmental Health Science at Raleigh, North Carolina. Indianapolis is going to try to have Dr. Robinson get in touch with me and hopefully copies of the protocol can be mailed tron Hnshinqton to Dr. Burger. (Dr. Robinson called me later in the day and arrangements were made to have the material typed in the Hashington olflce and de- livered to Dr. Burner by nessenger.l Dr. Burger also Hahtod to know about the sample which we. uare using. told him the sample had been taken from our regular plant production, that it had been assayed by two chemical methods and a bio-assay method and the results showed it meets our specification of containing less than 1 pp: of the symmetrical He also wanted to know who the producers of were. i told him Dov, Monsanto. Hercules and Thompson-Hayward. He then remarked that the sample which Bionetics ured was Iron another source and I said, yes, if it Has the same as had been described in the original Bionetics report on carcinogens; since that sample was Iron Diamond-Alkali. who is no longer in the business of manufacturing He wanted to know if there would be progress to report during the course or the experimentation and I told him. yes. there uould. and he said they would very much like to be kept up-to-dnte on the progress of the tests. I replied we would be glad to keep his oilice interred. Dr. Iurger seemed most cordial and interested. He aade no mention at the request the NAC Task force made to FDA to extend the tine beyond January l. 1970. for consideration of the petition proposing tolerances of However. the nature and timing of his inquiry leads one to suspect he is 'buildinq a tile'. hopefully in support of the request. Dr. aurqor's.aGCress is as follous: Dr. Edward J. Burger Oltice of Science and Technology Executive Oftite of the President Bsecutivo Office Iuildinq Uashinqton, D. 20506 "is telephone A 6 Ver nt Regulatory helstiona Lite Sciences 1: (202) ?95-3506. DESESE MOO ?In-Fi- - ammo?; . . ..- mfrwa'q?yre? ?e mutt-m - ?answerer. ue-enevelJuly 9. mo huma- b. not): . It. 3. I. ?Ill-m the bu Che-teal be: Bill? 17? mm. I161.- ?an in: It. Encounter: m. atom to mucu- Io. nous puma-g teleteece e! pp he negligible resume of the herbicide sum on mlee, yeete. prunes. rice and meme. u. your Letter at June 29. 1910. Miami analyses e! [on e! ellvex produced by the Don Che-lee! coupon, in 1967. [958 null 1969 showed no detectable mounts (leu than pp.) 0! ?ace rely yours. . hm II. Deter, Jr. Mel-Lea of Regulations and Nucleus Control. Of?ce of Gus-plume lureeu of foods end Pesticides cc: . Pesticide: Ieguletion Dlvleton. . 2 MS, USDA .. -r RECEIVED JUL 1 315?; I. u. '32. on non-no. .1. ?258qu oanoo an arc gang-on 6.0. in. in! In: .I ?335.. .009 no r. c. 3133-3 ?05. plan?.0: 5 such-0.. no on are 9! v3.72roan: at. door on coo-Iron C. at. on?q nirvan- 12. pl g. . .uu all area: nur- ao gnu.- proan Id 1-: on On ?to: '35. r. as no 3-2.: nr. Inn: la 333 an". la. no: law canola-a or. 1838:. a It: llron Id on I [nut in} fauna-II" rut-ungo- II 0.35 . II no in?! i. nun-90.5.. {alluring-38hemevu? 66w CHIHICAL COHPANY hunt-u tuna-log bd- 9. ma: norm mm a II I?ll M1311 m. Indy is ?signed to ?than "acquaint-y o! the barbie?. 1.5.54 1- "but ?an attain-rod oully during the of Wu (day 6 thread: by 1 of caution). A. Prue-dun; 1. mu}. But;- Icmty In" virgin (-11. rabbits will be and in an only. the by of mutation v1.1.1 to matured day 0 . of pouttn and on]. shiatsu-tin of tho an int- - dry and continue through day of ?nation. I-Itq?IINNdethuyOWyvudIua-ldfu lulu .111 to ?unload by a do? rim-null? ?all: mt mum. 6min. at ant-1 will .- bu?: . -1 ?301 - ?325 control (Vehiclc) - ?so In. but. will I. don:- an - ?33! and i7 pron-inn do? ?u - ?370 nut-(Lulu; a 1mm u?bu a! "Rm. 0 I. tut Inc-rut hot ?and um to omit? by h. Canny. W. adult. ho '11! in Mt? he on! - mm? ?1191.. Gumt- v1.11 nut? to "um. 96152.8 MOO i Q. W1 hint. - lull: nun-u. virgin 1-10 dbl-o rabbits duh-d fru- Iho lu- Ch-iul m. lulu. mam. will It?. ?in U111 in ?hunt? haul-l I. 190111?! Kinda-r . no. and conditioned a lint-L- of that prior to In. I Int-h .111 aunt-u I ?Hill ?but an: and In: dam: conditioning and tuna; periods. Imus- ll! ?in I?l to arti?cially Mud. 8- :11! to hunted by In. of an "uncut min and ?land hr land-stun with ??01th Oahu-I an to by 8 I131. 1 QM tart-m Injection 0! '1th hut-uh; tau-? ur- jun: prior to man. I Pro-hum?and duly during pou- - . tun for up. datum drug ?toot. Inna-1 H7 Inuit: an to on mutu- Gun 0. 6. .l I. hot-hum on pantie?man ?that?. and hm? will to mat-cu man. A: an u- out tom will to mind (or m1 mucus and tho toll-htd- 0! um ?Infusion-u umuwcmumgs-rnmuun .umu. out van. an to mm In nary-m but. dour-tn out-viva! nu. 3. but met- hu-iu ch huntin- mid .11 tom will in d?d all. "and 1- ?hat. tutu will. be - a?jucd to no? and lo- Initiatio- visceral I than eluted at out-oi ?a ?turn red for i ?1 man. unmade?: cud other Itudtu - 7 U111 in. (Ilium1.6?me haul Elma c. mun. . Mun! by: i . . . 37-. L. Ema. 37in. 5.Ina. nun-nu a. tutu-kc an. 89 6&?5 . -- - au- DOS. nzwzarr nOZurz< wrists! Frat-n ?Emu: J. near6.1.1.35 5.: IS: urn-q. ?nun?I. ta: up near-east. "no 1:20 at: :03 57.3. - unruaEssa :3 u; 0.03. .. 3:0 ur- :35 nia. 02:21.. E. no. 3. I. .3. 2.4.3.3; flan?!? an ?-2.57 .13 no 1.: :30 .L nu: 195.2271. :33? .1 3n r301. m5nvqsure:- . oolr?lal LI 1 . 51315.. Kahuna. . . A. 11111.911119J at. a?\in?ruruIM-l . .1 ob. .11.. \r a. . . . Hal. ..wm k? I - as." . $24 3 3; if. 1L. Ff-Jl furl. . . . . {fataa?j? .lv -. . - .13.o_u .- . ?gh-399 ~uo-Z: ?u an? lam?won q- Too-au- 290 13"? H?wt?- 3 2 .3i, 'hlf?eu- f? 'l a - a Ida. ud?'u?xg 11dud-Navy4.. .17.AcmfallI714 2?32 -- '4 . l. f; [1.1 ?1 1-woo-1435.. ?3174' 3 . 35? - Hm?? . .. . Hf}. -. lig?'fnfitff?dbw?a. mar-M00 an G?ngit-??. w? 5'31? 1 Hr. 11? .25" kpf-h ft," ?l?i??lp (mgr-1r.) (if; . i . ?.173?Kiwi?? I, J-?nilwliexb - - 1 'Tk'i??a . Qa?a?i.? 9:51! 333'. . ub?453:.- 1 1 If 1 . fry", gas-3 r453 . 7w. .. ., awr- w-rwmmu ., . . ?13, i . 111: I., .1 .3: Skit4?11- a'J?f 1? . E35 1: ?31" -- -. - {:11 m. x'j'riv? 511$. 3) {1,va . 7?53.th ipr 1.4.413?! 4.11 3.444.. .. lean sumaf?x}: . FE . .. Fault-?Eb.o?hvlno . .klomW??4.14MB. .4. a . .- nun: mic: . 3: 51.: 13 E35 .- 20:5; envy?J51: u?ff'" 9 .5). {a hhu; aim.? .4 .2 .2. .3 .n :75: .6 527:3}. . cm,nk hb?rcaz ..oo 31; . 1 if?? :36. . 1.0 choU.uE:.:< rmood a ??tgm in? *4'5 ir. 2' .- Faun-c ?0503.455. no uu;:uan no Data ?5.00 no 3-0 . non :9220uEu301n ma .3. 413.: can run aim?: ut??nu?z Inn-n 0 ?13; ..E lull 3.. . 1: 13 .7327. r: . ?Ouuc3_u1.anuum uuzlunn 340 .0 tun-G v.22.-.4. .I - un?? Lil-p ..qumm?wqfh?k 5-3? 1 11m Hang-1 [uh-I511 'u'tv" 1- ?kl" ."N?ul ?nial: Mfr-J; hw\ I dung)!? tare-4.1+ gr?! fogw ?3351? W?l? 113111.11, 111 @513: .. I rm1.. .551 15' 5; 1x5.A. Eff? 5? {nth-J?Uqf? .. 1111;? {zii?i'l fight? 13;, If! 3&1 . 9'9: Fq? ?it Fl I uoWTle ii(it2:211.1113 ski"?1511amaze "1.952..-.- .3 g. u. r311at?? fa; FL mum-mu ?mm-0mm ma 4mm; k. t. .. Our Ir. ?ll: that ?has,? incl-dull. M: ?llet-?an of mid-nilAnn nit-1 hunt which you int-Ill to held. I did not fill in this bear. Plan and macaw-mum dioxin on It. unusual and can. Infanthumil- It. htulM?IMuIIfmm-Mul mm mm- cf In": 0! (In ?can man be ulvd. 1 mom can.? mo learn-l II will have the "rim 2.4-0 In! .l.5-T nun ambit form un?- at that till. Mr no!- for an Intention and an sale you an outing I. for I. Sims-?y yum-I. L. full. I'll. o. Associat- Mutter for about?: luau-18:4: - 00 868K [4&5 n; '7 I . 000833 Tr 4; 3 THI pow cannon]. COMPANY ?00! lulldihg lidland. Illichigaa January ll, 1910 Mam - 53:15-21 To ac. to. ML 44-76, DOW, EPA AGREEMM 9-79 SEZSZOMOO I. I. llair I. I. toning I. l. Irowor L. J. Lippi. I. I. Crow-ate D. D. Ideolliator Ll.hmm?a - -a l. I. Gotaandanor J. c. lanoon J. I. Johnaoo Dr. Jolioa Johnaon haa aakad that coordinato and loop a or all of 1.4.3-2. and ailvor (inoluding dorlwatiwoa) that aro during tho oorront aurgo of toratoloqloal lntoroat to invootigatora who wiah to conduct thair own taata. loo Lippio haa boon inatructod not to - roloaao any until ho haa oloarod than through Io. will arrango for through Jia Pornandoa. Ji- ll initiato all ohoaical will initiato It will not land any oa until wo aro oartaln that tho: loot Dow apoclticatiooa. I havo aot up a rocord ayatoa that inoludoa a rocord of idontitication, tho lothoda uaod one tho conaiqnaa- Io would orator to aupply only two typoa of aalploal that root Dow apooificationa. or (2) laboratory ratoranoo atandarda or vary high purity. rho laboratory rataronoo atandarda will quito likoly havo to ho apociolly aynthoalrod. turitiod and analyrod by aovoral aothoda to oatahliah idont ty and purity. Invaatioatora ahould ho aakod to carofully calculato tho aaoonta of tho laboratory rotoronco atandarda (and thoir dorivatlvoa) noodod for thoir taata. Thoy will ho linitod ln aupply. aa thoy aro difficult to proparo in quantity. Tho aanplo liaitod. ?f la quito Only aillqra- quantitioa aro availahlo. Ho will . .. . . . .- . . 53GEZBZOMOG 3. I. nm: at January 21. 1910 Mn V. I. Ian cunt-at luv-suntan who want to an till. one? to work out than- speci?c require-nu. A nut?: o! to 300 gram of ?ch applied no hope [7 Ion nipple. Agricultural Manuela Count, Deal lullaby. II will also prom? all orders. Attach? .111qu or a mating ham-n Portland?. Ootundmr. and to discu- nun. otc. concerning this Int-r. In tor: blade? at. Iclm Attach-at s. n. Utah. cm: n. 574 V. nui??, 1003 W. D. 57-! J. D. . 1710 L. Dunn,1803 1.086 (EFL- - -ogii Lufi?: G. E. Lynn, 9005 r. c. Lem-m, mo CRH5). 500 upon ML 8155-1212-0215 mu Ur??s "out: i92?9m__ son 2. 3, 7, 0? TETRACIILORODIBENZO- P- uma-nu E11..- .. 3 The determination 0! various physical constants tor 2,3, tetraclilorodibenzo?p-djoxin (dioxin) and 2,4, acid were requested relative to the use at and 2,4, 5-T esters (orange herbicide) In Vietnam. The results are summarized ?9 below in Table l. c. 5. Table :3 mlnliility oi 2,3 7, B-Tetraehiormlibenzo-p-dioxin in Various Solvents at .1: Evan! So__l__ubl_l_tiy, g. /l00 g. solvent or Weight PeTcen 0. 14 Chlorobenzene 0. 072 Benzene 0. 057 Chloroiorm 0. 037 Acetone 0. Oil n-Octanol 0. 00-18 Orange Herbicide 0. 058 d) Metlnanol 0. 00) Water 0. 00000002 (b c) (all N. E. Skelly, ALS 57- 474, Dec. 8, 1964, 574 Bldg. Nen data Calculated as pp?u - 0.2 Calculated - 580 . . .. . . I. 9] fr. . - N. Sin-Hy era-at nu ?4997 our. {#14 7_ z" ~17- 01086 L59 - April I3, 1910 AL 14-693 Table 2 SolubilityI ol 2, 4, -Trichloiophenoxyacetlc Aeld Water and n-itexane at 25 Selvent g. liOO g. aolve_n_t or-WeII?Il T?ereent? Water 0. 0044 n-ltexane 0. 0022 Partition Coef?cients tor 2,3, 7,8- Tetrachtorodlbenzo-p-dtoxin cDioxtn (Water) chexin Octane!) foggy 0. 00010 cDioxtn (Benzene) ?Cnleulated value, see "Partition in the Expert- mental SI-etlon Removal ot Herbicide Orange irom Corrugated Run! with a Simulated One Inch Rainfall Orange herbicide spiked with 10 dioxin was applied eorrugated looting material at the. level of that used in Vietnam (24 acre, 0. 2? The routine matI rial was sprinkled with 2. 2 gallons (10 ?lms) oi simulating a one inch ratntall. A multicolored oll ?lm was noted on the surlacc ot the recovered water. Following chlorolorm extraction, the Orange herbicide con- centration present In the water was louml to be (UV determination), 0.125;; or . 1259/11?! 100 12"; of the amount applied Orange lterbiI- Me in Water - 12.5 .IppnI The dioxin level from the spila- would be 1 pg. Since the total sample was only this was insulin-tent at present [or a dioxin determination. lloII'I-I'ei, it the Iiiu:.iII mum ?to II p; mi and the dioxin II. as lI-Io II it it? run! in the 5 mm I aim (bog mm. oi II .- April I3, 1970 -3- AL 14-09:: the Orange herbicide, the maximum amount of dioxin that could be theoretically present in the water would be $000015) ppm. Theoretical Level of Dioxln That Could be Present in Water it Orange Herbicide is Saturated with Dioxln A saturated solution of dioxin in Orange herbicide was prepared. This was analyzed according to the methods developed by II. it. Gtii et. at. As reported In Table i, the solubility of dioxin in Orange herbi- Fl'de-TE 580 ppm. It the dioxin were present in Orange herbicide at the limit of solubility, and it the herbicide was dissolved in the water at the 5 level, the amount oi dioxin in the water would be 0.0063 ppm. However, this value would exceed the solubility of dioxin in water which is 0.0002 (0.2 ppb). Solubility of Dioxin Solubility determinations were made by warmlm the solvent to its boiling point or which ever was lower. Mg. amounts of a) was added and the solu- tion was placed on a mechanical shaker overnight. Solutions were allowed to stand a minimum of six hours beio re they were littered through cellulose (tor aqueous) or avicel (tor organic) 0.45 it Milli- pore litters. Conceal rations in organic solvents were determined by direct Injection into a gas chromatograph. Solubility of the dioxin in water was accomplished by extracting 1400 ml oi a saturated solution with 30 ml at benzene. This was evaporated to a Volume ol 0. .1 ml. The extract was then examined by gas chromatography. Partition Coettictents F?iity ml of water and an equal volume at the organic immisc- lble solvent were warmed on the steam bath. Mg. amounts of the dioxin were added and the mixture was placed on a mechanical shaker overnight. The respective layers were allowed to for 48 hours. They were then liltered as described previously. The organic phases were analyzed directly by gas chromatography while the aqueous phases were extractul e. ith tu?o ml of blorotorin. These chloroform extracts were then analysed by gas chromate;raphy. 1. so! Aprll 13, 1970 Al. 14-698 Since the solid-[lily of dioxin in n-oetanol is limited (48 ppm) and the solubility of n-oeianol in water is poor (300 ppm), there was not suliicient dioxin: present in a concentrated extinct of the aqueous phase to obtain an absolute dioxin com-cnlration. There? lore, a theoretical partition coetlicirnt was calculated on the basis oi the actual concentration of dioxin lound In the n-oclanol layer and the theoretical amount In the aqueous layer based on dioxin solubility in n-oetanol and n-octanol solubility in water. Therefore this value should only be considered an approximatlon. The gas chromatography [mi-lion of this work was carried out by l-T. and D. Roberts of the Gas Chromatography Section tor which they deserve eonaidcral-le credit. all! STUDY nxammnonx- - 1A. 335.531" .1. coucguhol?o-aaua a. Doug: It?llvlo. 1 0' not I. II-ltll. all. 0-. CI 0' mean 0?60.- A aupla of haxachlorodibonao-p-dioxin (95% pure) was moivad tro- A. I. ?0th of tho and auhaittod to tho Biochuical luau-ch Laboratory to: ?valuation aa a ohloraonogon. than 0.0051. solutions of the teat lat-rial. on. in din-Moms). am the othar in chloroform var. praparod. lac-h solution was ap- puod to tho inner surface of 3 rabbit oara. 5 days pot wool: tor 4 each at a doaa of 0.1 Illday. lath tut aolutiona Mood chloracna All akin contact with an out oat-rial be avoidod. - - .a - DOW CHEMICAL USA. alumna acnoaunuue November 8. 1978 Irving J. Selikoff. H.D. Environmental Science Laboratory Ht. Sinai School of Medicine 100th Street and New York. H.Y. 10029 Dear Dr. Selikoff. It was good to talk to yOu yesterday. This letter is to confirm with you that Dow scientists are pleased to accept your invitation to come to Ht. Sinai and present a seminar on phenoxy herbicides on Hednesday. December 20. l978. It is my (our) understanding that you wish us to present the scientific data we have on 2.4-0. 2.4.5-T and related substances. The purpose is to acquaint you and your staff with the data so that you will be better able to plan and execute the proposed epidemiologic study in the Pacific Northwest. The people we have selected to present the seminar are: - - John Davidson. Technical Advisor to the Director of Research and Development. Agricultural Chemicals Deparuoent. Bernard Schwetz. Director of Dow's Toxicology Research Lsooratory in Health and Environmental Research. Richard Kociba. Head of Pathology in the Toaicology Research Laboratory. Benjamin Holder. Medical Director for Dow USA and Director of Biomedical Research in Health and Environmental Research Harren A. Drunnett. Technical Hanager of Analytical Labora- tories. V. R. Rowe. Director of Toxicological Affairs. Health and Environ- . mental Sciences (1 nay cone along as moderator or whatever). You asked if we had a objection to your inviting a few scientific colleagues fro: such aces as and H10. Certainly not. . 82 . . IJCIV IUDLJL I l. J. Selikoff 4- November 3. 1978 I mentioned to you that Halter Helvir. Jr. H.D.. H.P.H. and of the Institute of Rural Environmental lie?h. Colorado State University at Fort Collins might well be uilling tacontribute. Dr. Melvin is well informed and has had a uealth'of hull experience in the phenoxy herbicide area. He served with the Air Force!? many years and has been directly involved in Viet Ham. with the dispul of the Air Forces' controversial inventory of Agent Orange. with thelveso incident and presently is engaged in or epidaiological study of some sort in the Oregon-Hashington area. - You asked what papers Your people cald benefit from reading before the seminar. 1 suggest the folloding: Toxicology of Phenoxy lierb?irides and Hazard Assessment of their Use in Reforestation by Fall: ll. Dost. 2. Long-term Hazards of Polydlorinated Dibenzcdioxins and Poly- chlorinated Dibenzofurans. lull-:0 - IARC Technical Report No. 78/00]. a report of the Jd'at Sorting Group. 3. Chlorinated Phenoxy Acids ad Their Dioxins. Ecology Bulletin lie. 27 iron Royal Swedish todemy of Sciences. C. Ramel 4. Embryo Problems Posed by Seveso Accident. ll. Tuchrann- . Duplessis. H.D.. LeConcouusltedical 44. Nov. 26. l977. have included copies of the Titlemge of the first three of these so as to help in identification. Thereare. of course. hundreds of papers but these reviews will give a good oerall perspective and references to specifics. 1 am enclosing a copyof a translation of number A because I did not expect that you had seen ttor might not be able to get it in time and I do think it is iwortant. 1 rope I have answered all the ouestins you asked. If you have specific item you would like to have discuss. let one know and I will do our best to include then. Hith best personal regards. V. K. Rowe. Sc. Director. l?oxico ogical Affairs Health and Enviromental Science 1803 building 636-2375 Lilair P. Behring Enclosure . k: I. Holder J-Iavidson R. lociba tbonalds I. Sch-lat: a_ back on December zo.. Hill It later. DW CHEMICAL CORP- ROI-L #3 889880 IMOM -. - 83 - - 5'12? be! now we are planning to take the Don plane 130752 ?tt?:l. . I 161mm or - - mnmo-r-moms .. "all?. '0 A. SOUTH: museum P. J. Baum . 012mm. BIOLOGY Rum Elmo. Human - .l?li?lzld?f. {Uh-f: ?l 1.4: J. l. [xenon C. G. Gaul. Ihm Ileana llama: no Bantam Cum llonmut. luolm THE CHEMICAL EMMY DOW CHEMICAL. U.S.A. T108 January 25. 1979 D. Hoerger. 2030 mu D.C . 5.3. 4-. - . . A all 9.7? H. Blair. 2020 k. D. Moss. 9008 8. Crunnett. 574 H. 0. Morris. 9008 E. Donalds. 9008 R. 0. Olson. 607 H. Gentry. 900] E. S. Parsey. 834 A. 5c_hy_g_t_z, 1303 GNEDIIQEIKD 8. Holder. 2030 . Jantz. 9008 . Johnson. 2040 . Jones. 900i Leng. 9008 . Hintz. 680 . Huelder. 9008 L. L. Smith. 9008 H. J. Traynor. 2030 A. J. Vogel. l710 S. J. Vranish. 9008 J. H. Heseloh. 9008 C. S. Hilliaus. 9008 thf?nr?? NEH YEAR FOR 1979 CHLORINATED DIOXIN ISSUE MANAGEMENT Accomplishments Successfully defended the use of 2.4-0. 2.4.5-T and silven in states where the opposition attempted to pass legislation that would ban or restrict use of these products. 2. identified local legal counsel in geographic areas of greatest controversy and aided in their becoming sufficiently well informed so they can defend the position of Dow as well as user groups. 3. Supplied a l2 volume document to EPA in response to the_rist rebuttal portion of the RPAR on 2.4.5-1. Benefit responses fro- nore than 2.500 users were received and logged in by the EPA Federal Register office. i. The Dow Hidland 2.i.5-T production group de-onstrated the ability to consistently produce 2.i.s-T with less than 0.05 pp: icon. Progress was node in having Dow 2.1.5-7 production facilities outside the 0.5.A. produce 2.i.5-l foraulations with less than 0.05 pp- 1000. S. The long tern feeding and reproduction study on rats with 2.0.5-1 was completed. the full report was submitted to as part of the 2.0.S-T RPAI risk rebuttal. this. in addition to the 1000 study on rats fulfills Dow's agreement to conduct long-ter- studies on these two chewicals. s. The Council for Agricultural Science and technology (cnsn revised- the Phenoay Herbicide report and an appropriate press conference was held in Rashington. 0.0. to annountC the revision. A favorable new! ite- resulted in 0.5. News and L'orld Report. AV "II-Iliad no:- me E. H. Blair. et a1. January 25. l979 7. After the minister of health in the State of VictOria. Australia declared a ban on 2.4-0 and an intensive investigation was conducted. The final favorable report exonerating the chemicals was distributed to user groups all over the world. A similar report resulted from New Zealand after investigations were conducted in that country. 8. Improved analytical methods for 2.3.7.8-TCDD and other chlorinated dioxins resulted in reports to the Hichigan 03R and u.S. EPA regarding fish from the Saginaw basin. A preliminary study entitled 'Trace Chemistries of Fire? presented the findings of a Task Force from the ?ichiganioivision investigating the probable source of the TCDD found the sh. 9. Antiherbicide groups in Minnesota. California and British Columbia exerted considerable effort to force some type of legislation to ban or restrict 2.4-0 in these areas. To date their efforts have been successfully resisted. l0. Several publications reporting on the health effects resulting from the Seveso. Italy incident appeared. Translations were made of these studies and they were distributed to appropriate people. ll. Preparations were undertaken to gather the necessary information to defend The Dow Chemical Company from the claims of Vietnam veterans regarding Agent Orange. l2. After several years of legal discussion the Charlotte Taylor product liability case involving 2.4.5-T and silve: was settled for $250 to C. Taylor and $250 to her daughter. The initial claim was for $5 million. now CHEMICAL CORP. ROLL #4 I BE i C: CD 2:3 . Jk? . kits/Ag? I ?E?urger CKDREP. liC?LIa E. H. Blair. et al. -3- January 25. I979 Plans 1. Continue a vigorous defense for the registered uses of 2.4-0. 2.4.5-T and silvex worldwide. 2. Encourage the holding of a scientific conference that would provide a means of bringing together research investigators and presentation of latest findings on Such a conference would also serve as a vehicle for the preparation of witnesses for an anticipated hearing as a result of the RPAR decision on 2.4.5-1. 3. Prepare for an anticipated RPAR on silvex. An exposure study for the lawn application of this herbicide is underway. a. Make the necessary preparations for Dow production and analytical facilities to lower the TCDD specification in and silvex containing products worldwide if this becomes necessary. 5. Continue the collaboration with the 0.8. Environmental Protection Agency Dioxin ImplementatiOn Plan Committee in the analysis of environ-ental sauoles of fat and mothers milk for TCDD. Also cooperate with National Forest Products Association on a mothers nilk study in the Pacific Northwest. 6. Although it appears that 2.4-0 has been removed from the EPA list. it could appear again if the antiherbicide forces apply sufficient pressure. in light of this possibility. steps are being taken to gather the necessary information to defend 2.4?0. - wl. ll. Davidson Agricultural Products a. J. i Agricultural Products .L f. toe sup-e2?? 43- .. 3.2: .: . DOW CHEMICAL U.S.A. 1 h? I 1 i 9.. MC. Com 57.. roses?T teasing-r All-315! 3" "1 "use use health 3nd Environmental lesearchl?l'oaicologv Research L141 7 O. 0 7 [he .. noto'ric_o__oaie Studies Involvig (11:99)! 33 g; - in Mice and Rabbit: IN FULL Wu] .- R. P. Shut-m1 It. J. Kociba and P. J. GehrinL mum. Jake. I .1 ?1 1m Dun-"T MA I g?tdga 2m Q'nm. Dame Ta REFERENCES isos- fen-o: Cl? NUMBER .I I MOVE-I 8332-21-1. m-n-z. 3311-21-3. EEK-214. llshu-nthMoe?n-IMI C: mm :1 Issac-antes? nuns" mm couctunout- Hale nice and New Zealand mite rabbits were given orally 0. 0.01. 0.1. 1 Id 10 of (TCDD) for a period up to 8 weeks. The nice were sacrificed at 2. and a weeks of exposure. Another group of nice and rabbits was inmculated with an antigenic mixture containing tetanus toaoid and Frcunds sdjuwant to evaluate the induced insane reactivity. Splenic lyephacytes were cultured in vitro with or without the agents (phvtoheneulutinin and poheweed nitogen) and the incorporation oi u-thynidine was neasured as an indi- catioa of relative blast formtice. Lesions attributable to were found prisaril) in the liver of nice and to sent extent in the thyme of both species. In nice. the thynie changes were pronounced at A weeks after EDD exposure but not at I seeks. Exposure of saintls to m. even at the lowest level (0.01 uclksiwh). caused a aarkcd increase in the thynidine uptake by splenic The blastogeuic response to phytonitogens was decreased at high levels oi exposure. Est inatien of euros i-unoglobulins indicated an increase at lee levels and parted decrease at high levels oi EDD exposure. 1an exposure also reduced the sums antitetauus concentrations in both species and reduced the skin reactivity to tuberculin and the antibody producing cells in the popliteal lyaph nodes oi rabbits. Insults indicate that few at low levels e! exposure causes en enhance-eat oi ire-mu responsiveness siailar ?that produced by antigenic substances. l?mcsuppression occurs at toxic levels of man exposure and an adaptation to this eitect is suggested. T3 3.: tin-sum 1 CHEMICAL CORP. ROLL #4 6' rue pow CHIMICAL cournuv Michigan larch 10. l9o5 h. Riley. Sgecial Che-itela Salee, AEB c. Tucker. nduetrial Salea, Aha l. sliley. International Balee, in: U. Harrie. chenicel Belee. ARI B. Grant, Balee Adniniatration, b7 Building H. reinauer, Chenicala Deportlent, in! o. Hutchenreuther. Org. Chen. Prod. 258 Building c. ataehling. Organic Chen. Producta Dept.. l7: Building C. iaatutt, herbicide Section, ea: Building B. Otle. Bioprodueta Department, Bioprodueta Center I. Palaey. Bioproduete Departnent. Bioproducta Center . Y. ?anaan, Bioproducte Balea. Bioproduota Center B. Lynn, Bioproducta Department, Bioproducte Center c. Hort. Chen. Brod. Quel. Servioee, 172 Building' l. dill. Bioproducta Departaeht. Bioproducte Center J. McCoy. Bioproducte Selea, Bicproducto center . a. Uiltae. Bioprodueta Depertnent, Bioproduete Center D. Doedene. Cheaicala Department, sun 2. Bletcher, Bioproducte Depertnent, Bioprodutta Center I. c. Berrona. Bioproducte Depertaant. Bioproducta center U. L. Corbin, Bioproducta Salea. Center 1 Biochemical Laboratory. 1701 Building one;>Bioehonicel Research Laboratory, 1701 Building HAZARD OP IDHSANTO ICED Rabbit eer test: on tvelve lot: or Monsanto 2,b,5 acid have ahohn moderate to aevcrc response in eight caaee at ten per cent concentration in ethanol. Thin conrirnn tor which can found in concentration: averaging about 10 ppm. H?lr'h?h? This neteriai presents a definite hazard Ihich would require all the precautions ueed in 199 Building end 389 Building to prevent injury. if it i: proceeoed at Building. Don't involvement in ahippin: this material to liverdele and Uoodbury also concerns no. There it a definite risk to their enployeer. especially ainne they are probably unaware of the problen and are probably taking no precautions. There it no endurance the: their finel produeta I111 be free of contanination. The available evidence pointa to the oppoaite. In my opinion their producta ahould not be aold until eninel teeta show three products to be free or aicniricant notaro rrna tr: tetrachleroditenzcdioxin and releted,nnteriala ub? "Plum-?W I . . ,5ng 131% ?754455: 1314 -. .- . a? . .1 1 - ?fnra - . - 3?53 43:53:.? iCEm? i? I $1er CC ?Jf?p: 35.. 'E'eh rut-PI {Wig}: 39.3. .4533 ?Ir. 36?? . 4C . - N311 Swag; "trC?C? .C I a, C?l' -, 73an 1 129928 [l?az ,2 55 $3333.45 :3 h- HI 5? CCrumud-w 5545-5; ?a I 1555?04ji?? gt: - I C, - ?if if? 352? 'hl dag-5": 41-5-2. {1 :1 wan-I; 1? I -- ?lt?h- CC: I ii? ICC 9.333;. l? . #33; PC: Cf'u" LC. rr-gizC ,?Cnl Ada-M ?m Tc,? :93 a. Q, mm. liohipn 1-1703! 29a 1955 J. .1. II. I. c. Iona - I. n. om II. .o at '11t.? 3' D. I. l'latohar K. '0 LI cor.? '0 DC DC J. I. fatal-ooh 8. mm oa omen mam mum on yak/65 Mount: Dr. Ir. llr. Dr. If. Dr. J. Uilkanfald and factor Barrio . Iainauar dtoahlinc 0t ia Hanson loft lloCoy Doodano Don-om horlo lloldar. ILD. dodok 1' "Is" 3 pow cuamucm. COMPAM I m! l. CD IO (D Hamid Varhoata, nookar Chanical Corporation . WM Pronoia Kannody and Id mndlar, Diamond Alkali Col-pan: c. In Dunn IM John I. Malay. Harculaa Poudor Coupon: . MW 9 V. I. racappad tho Dow aituation in tor-a of tha proble- ond tho initial atodioa by Toxicology and Environ-anal laboratory rant-din; tho in-plant aituation. Ila outpandad thio in canaral tar-a to tha atudy or and produota, mm and othor paoplaa. LI gnguloro-D-dibantgloxin. for main goal. Isl-our about tho unhwa . Ila soda rotoronoa to amtrlool Ila ratarrad to tho aaidonca ra Iona quaationo tron tho Ha (Don) not ahlo to ohauar thou qoaationo auapt to raviaa tha avidanca tor thair oxiotanoa in tho procaoa and and produota. CONFIDB - JECI ID I: 3510! ID. NJ. 4-4-7.) AGREEMENI 9-..-. . . 3.27. ??111 . no .1 a. . 111;; . - I 'n -2- Dr. lloidor rovionod tho nodicoi aido .ho?a?hid that no not havo approainata indiiriduaio with chloraono ran; ocno van niid caooa that non di ti -J Ih?h 29o 196? of tho Don oxporionool 11 60 to 10 or tron two aovoro caaoa to unit to dianoao. Ila ahoond oiidoa of tho noro dronatio i'ho aiidoa noro onoinaivoiy viona oi' tho taooa of tho individualo arriiotod. Ila dnacrihad in fair dotaii tho appoaranoo or tho indivi- duaill nontion tho hiaolthoada apooii?ioaily. lo than ruin-ad tho oi atudioa that an ho nado on than poopllo nith owl-ail on tho iivor tunotion ata. llo nan- tiomd tho niacin 11m biopsy that haa boon takon and ltudilnd in which tho iitor naa nor-oi although tho nan had a rtthor pronounood noon at ohioroono. nontionod tho inoidonoo of i?otiauo ano aa hoin; tho oni othor ainiticont I Dr. Iloidor tho ottiiotod in: in thoao to lo t'ouchad trio: 1 on troatnont indicating that variouo topical troatnonto noro not ottootivo. Io doaorihod tho cycling or thin diaordor individua in who had boon iotoiy-ronovod tron oouro. llo nontionod' that aono to ion an approaching and or thoir trouhio too or two and coo-hair yoara attor onaot of tho akin dia- ordorr. Ho doaorihod 'aouto ohioraono' nhioh ia an aouto in?a-atory condition that a an oonaidorohi: aoonar than tho nonni in indivi and appoara attor pro- nomcod ainsio oxpoouro. 'l'ho aouto ohioraono ahoua up nithih a torn duo of axpoouro. Dr. loidor nontionod tivo to night dun Shara naa oonaidorahio hr tho Tho lookor roproaontativoa ramtod oxporionco of akin condition thirty yoora attor upo- aurn. 1'hoir caaoa noro noro oiniiar to tho hunpa nhinh non haa anporianoad in that thorn worn in hoiia or largo hupa rathor than tho nuititudo or anaii aohhoada and oruptiona nhich Dan in aooin; in tho ourront Dr. aadok ahouod aiidoa or oara and livora of nbhita that had hoon to tho aynnotrioai totraohioro- -dihontodioxin. tho pathoioc in dotaii nhioh 1 oil not attonpt ulnar o. V. I. nontionod tho atudioa in which tho rabbit oara havo hooen troatod uith 'ian in hantono or corn oil and than nith noon and notor at varioua tina intorvaia iator. it napoouro occura tor var-1 long, uaahin; dooa iittio good; ho hriotiy nontionod tho orai atudiaa but nithout dataii. Silvantoin doaorihod tho plant atudy on naahin. of oontonination tron tooia and aurtocoa. Thio atudy indicatod that homona, acotono and Chlorothono nu noro otll'activo in ranoving tho contaminant tron tooia and that dotcrsant and uator nith acruhhin; action could ciaan up tooia and oquipnont. Sana onauod on tho Camp on tho akin dioordor itooii?. f3 Er?l . ?tter: tint we tint ugo out an: en! magmas and urn-n dadm my: to mama-n mango a: {khan-1:. . we; -. - wax-tam want. .. . H. 321,. . I. lii'suh, ?3 if?; II also mother" ?anon for Ill ?g ?g .mg. snail?: a: m: 1-: mm? the rabbit teat; 1:11.11le .. 9W mat. In a. what?- cont-min?. Wu manhunt: it 1* .em but I patent Gunman. we.xthanrm,v will mun-3* or: hou- f' relate in In to having mthern 1am: It ?lm. and m. net-?- r; - cum; .dnn't ma ta ?J?Wmm 1 tn be our:- or ?ab amt mm the?? Ans-n m. . Dr. J??nm mar. M11: to m: with: ?at mama tmcu .Inr this which ma twin!? to:- ?3:111:19 m. - lurch 11, 1965 II ?135"" - I'l .- 3'31?" "9ft I153: . I'm. Jana . 12?31110311?. 5332'? numehiowdibmt?-E ?lth. . m? -- 'ng '11? 9'11?. . . .. 1 "um; '1'11? "Irv . - - - Mn an: "ethic! 1"!"qu Mien: Meal: :2 find Incoming to than it: 1: the has: ?#311209an a: hm?. Ewe:- .. ?amed It pawn-?ll mum?: am cent?: in 1 by any: 55M mm. 15?: 1&0 tI .-. "u toxin maths?; 11:13! 3.5 {353353.213 an 13115191121515.1213 e3 cram 1.3.131. .. I1 I "31:31 - Ironic! namnd- ?1.31; can used 3:1'fhin'dugg . that ho nae ?nd-:1 I hand and mat-3:311:11 hint he wished we maintain-1y. or updud a 313111 in mm? a! thin {and mm) hnfu named -I1I35 rah but}, vacuuming tn ham jI- m. 1: bring tinn- -tu you 55 illibm? the ?that! 6.9 analyzing In: this imam: inn ?1'23; ~15 - I kill: ,1 twin 3.13:1; 55 do 3m Mela-1:11 "alutdnn and?! . . ?"134 FE 1133:? an 11' 3913139713 In: quantumWar-4:5, - I. . Inf- . 1 Haf' . I . I .21? . - r-E- ,-.: ?il- 1:1" -.. -..--. .11 .F: . 1: $2 ?1:437; 1h. 1? ?uf: 0- I: "Ir 1.44:- "!rcd" - a . J. . 5?53EA. LI.- hm? II I Ith?n El I A If? .nv-"E . 41-12" 'Ehl:96, . II 'r li'lrl I i I la.II 13?3" 3' - . . :3 'Ilnhj u? 1.3+ .. .7394, u. I in?! but: a ?H?l?l?lut 1.lttiltnd?ul far pr?due1n? chlurtenl and lyttoutn ins .. Inf-'31: it. 1: trunnion-banal. 11: I111). {Lad-5'25: Imam Inc: 1' uh! uttsh um-I sicutte- If-d-?E?c? H. II 43.32:? grillSiam . II I?ij??puu'c" '13. a; what Tull.- Map?ff? ., a: ?l . - 'uiI''Jl IBI- H?s .. -I 114:: . - u- TFLE . . .Iq I harm-macaw? or} m. Imam 'r It? mun: In.? In was: and ?u In" but ?flint. hour-r. hum thy-Tail. in: utm- ?pm-a; I up?: than a: hut tubu- I chums: 3 than? 1dr!" {at ?tutu-II. Tum lira-1m? In Mum er than ?and. arm :1 thin hum humus. In "and to mm: pron?. In 'Itmtm tn on penul- to amid :11! will?! Mum-rim: at aunt-- uu LII hulking the mm I: If traw- acid and derivativisn-, n11 m, In hut I "rim than.? in our manta-.1 . -: .z - Hun-4 if nut-ulna? of 2.1.5-tr1cuumb-u1 with . .-: nun. cm: mum at which 1! 2.3-7cB-utmh1nn-u this ?can! it. bu I, fur-luau?: which In mm. mint! vhich but. to th?'weu?inei if my on: who i? using eh: intuiti- qa'a opt-nun In: In ?a uh?-f indunnv will. In and hit. I would we: Huts-tun mmum ?that BIL-ring cumin mu It. m1: :3 tin-nu ?Hugh:- Hun non-I Inn-41m.? nun ?u Ian-Hm tra- uuhou: Iva-u. I?m? ?#232,353nun-?mun.? I gamma none-mans!? Int:- an? "Inn? 11' ?1:1th.: incur." mud. . l_ I 553:5; i . .- . ragrum-1n or ?InnI?m-h ?mun-1m:- than m; in 1" ?mutmfn??zt?u ?Dmn? . If! 3~94 THU 11:55 CLHETDH . P-a1 . twang-199.2- m- a: mum sum HEALTH 3 Ewimwam Tu . .- 4633:1313 . Fr? . . I 4 - '53- I x'Hi. 'ir- Win-"l. Dow Chemical Company Hi? 5 .Hidian? Michigan nan; Il?? Honored Gentlemen: IFH- . ?-1f NDurln; ohriof Visit H1th.your monograi Brig Tr;% "ax Imam and annuum 1n motio?od' mun??o vapor-? which tho isolation or ohldru?hof nueivo' substanoon alvvull nozoonoluoionl oonoornl?g i Hoaorihod. Hr. Silvirohoin q? '1Hhorooh ~ahgyaa?od tor oopy or: this . ntil now Ha buto dtoolouod tho oontondgomofdlnorr dtuzo?: or .thbi 13 not gihorlilinm .I-r?nwnvo?; nines on that isolated Hind unhor 1' from .tho hon.? ipr ?ne 3 [oil of your TriohlooI honol to havo5?. . to turn this over you. ?Hh' would ask ?jH ?r 1 (however. that you Gonmit g?uraolvoaI' to i monagm ?g 0: Itr o: cantldonno I1 ralpooh to this information. and: at you outla- Ito no one out-01:11: or 3691? ?1.le 51:55 - We ho po that sh: EH5 cold uraoort (Exparimontam Wtha determination gloolattHH Morgana Hx?itorl 1n thoq. production or ?54! no of Doc. 9. 1955 '11! ha of:? non to on in tho solution or your thorIono prohlmm Ihd . a: ram: 0* . trawl; 31-?th - . 5: "5 HuhAttnohud Hagar"951 71": I I . . '.1gll 'l 1 I - . - osmw3'?? 3 so .3541if?! . til;- Cilf?51??.1156. l- I. . ?Ire 'run-l win-rpm- - . - J~uu? .. . Egan? . . 3? . Mr. H.K. Nason-M.0. 317 c. From COMPANY - Mr. 3.3. Soden-Nitro . Mr. L.C. Weger-Nitro - St . Louis .9 MO 30) June 12, 1956 1'0 Dr. R. Emet Kelly Reference - 7 CHLORA CASES AT BADISCHEN ANILIN M.Med1cal'DePt- smwa DUE ICHLORPHENOL Persons Present: Dr. H. Oettel Dr. H. T. Hofmann A. Palm w. Soenksen (Plant Supt., part-time) Date On the 17th of November, 1953, Badische was producing a batch of trichlorphenol from tetrachlorbenzene when the process exceeded control pressure and temperatures similar to our incident at Nitro. No one Was injured at the time. Within one week, as clean-up was being carried out, the first cases of chloracne developed. Fifteen or sixteen cases (6 serious)-developed within the next 1?2 months and additional cases showed up during the next 10?12 months until there was a total of 50L60 cases. ?p I did not see our most Severe Nitro cases nor have I seen photographs of these cases. The photographs of the worst Badische cases show horrible skin eruptions with nearly blister-like welts and some ulcera- tion where infection ensued. Areas involved included the face, neck, arms, and upper half of the body. It is my impression that their 3 severe cases were much worse than ours. In addition to the skin mani- a festations, their men reported all the additional as exper- - iences in our workers, i.e, fatigue, vertigo, loss of libido, painful Joints, etc. About ten days following the incident, and after initial clean-up, Dr. Oettel was asked to expose animals to the workroom atmOSphere. Rab- bits (in open wire cages) were placed in the operating area for 24-?8 hours. There were no obvious which developed in the animals until one week after exposure - when they died. Autopsy showed liver necrosis. Oettel thought there might be virus infection or.some other cause for death until he exposed additional animals in the department, others in cages suspended inside the ?decontaminated? autoclave, and some in the adjacent department. All died within 1-2 weeks following 'exposure. Subsequently, animals placed in the cages which had pre? viously been in the department died of liver necrosis. A thorough systematic investigation has isolated impurities in the . trichlorphenol process (or residues) which will cause tne same effects in rabbits. Liver necroSis will develop in rabbits at the following doses of the indicated materials: 15?20 mg. of pentachlor naphthalene 1 mg. of chlorinated diphenyl oxide 0.1 mg. of residue from trichlorphenol distillation 0.01 mg. of residue fraction from trichlorphenol (above 3 1 5 5 7 9 55?: Irv-e 7-: r~ .. .- Nul- . I . Dr. Oettel believes that the most potent chloracnogen is a compound- somewhat similar to chlorinated diphenyl oxide, but - '015 . . probably with additional oxygen atoms in the molecules. He has cor- responded with DonnIrish at-Dow who either reached the same conclusion independently or, in mentioning the potential of chlorinateddiphenyl oxide, influenced Oettel?s reasoning. _Oettel believes, further, that this impurity can show up in the production of any chlorinated phenols and is probably responsible for any chloracne which has been_due allegedly to chlornapthalenes, pentachlorphenol, chlorinated biphenyls, etc. Dr. Oettel has no faith in any animal skin tests for isolating chlor- acnogens. He was very interested in Kettering's work and was not aware of the publication referred to in Dr. Suskind?s first report and which describes the cyclic skin development in new-born rats. (Refer- ence: Parnell, J.P.: Postnatal Development and Functional Histology of the Sebaceous Glands in the Rat, Am. J. Anat., Bis?l, l9h9). He is convinced that the Bromsulphalein test reported in the attached reprint is significant. In this regard, Badische routinely uses this test on each batch of trichlorphenol which they now purchase from.Bayer, and refuses to accept material which fails to pass the animal tests. (I also learned at Bayer that they haveexperienced chloracne during the production of trichlorphenol but ?have now liCked the problem? according to Dr. Hansen (chemist - Research Director At Elberfeldlg Badische has been able to reproduce in the laboratory the conditions which lead to the incident such as theirs and ours at Nitro and was quite surprised that we had not been able to do so. I was not given the Nitro process information, temperatures and pressures, but if I had had this information I am sure that I could hare obtained Badische's. One of their chemists, a Dr. Palm, sat in oh our dis- cussions and was prepared to go into details. He did mention that "with 3 mols of trichlorphenol, methyl alcohol, and alkali, and a tem? perature of the process gets out of control. His remarks are in quotes because he does not speak English and I?m not certain of his remarks. Dr. Oettel would be very happy to receive samples of any of our- materials for investigation. He would like particularly: (1) Samples of any of the materials involved in our 1949 incident including tetrachlorbenzene, trichlorphenol, or Na salt and any residues from the autoclave or material cleaned from the equipment and structural members. (2) Trichlorphenol (or Na salt) from-regular production. (3) Any samples from raw materials, intermediates, and final product which may have been involved in our cases which -developed during our normal production in the years following the in tial incident. 1351233} . 015580 as - .- -3- He would be happy to exchange freely any and all information with us and Kettering. It was my suggestion that this be direct with Dr. Suskind to eliminate "third parties.? He would routinely send carbons of any correspondence to us and we could request Dr. Suskind to do likewise. It is my opinion that this might save unnecessary duplication of eff_ort and expense. In addition, Kettering might obtain. valuable information to further their investigation involving human volunteers. I left with Dr. Oettel copies of the following: (1) The five (5) reports from the Industrial Hygiene Foundation vrhich discuss their rabbit ear tests. (2) Kettering's report - "Clinical and Environmental Survey at Nitro, 1953." (3) Kettering' 5 report - "Environmental Survey Carried Out In- Building 30, Monsanto Chemical Company at Nitro, February 2, 1955.' we reviewed thoroughly Mr. Heger' 5 excellent "?Hia?ory of Chloracne" which he sent to me with covering memo dated May 15, 1956, and which included descriptions of Kettering' 5 reports on their human and animal research. I did not give Dr. Oettel a copy of this account because I did not have permission to do so. As a result of my visit, it may be desirable to edit this report somewhat and add further process information before forwarding this to Badische. Any specific recommendations are implied in the above narrative account of my visit to Badische and must be based on an agreementthat full and complete exchange of information with Badische is desirable and possible. Elmer P. Wheeler EPw:dh Attachment 015581 56? CONFERENCE AT KETTERING LABORATORY Kettering Laboratory Cincinnati, Ohio B.A.S.F. Ludwigshaven, I PRESENT: R. R. Suskind M.D. H. Germany B. P. Wheeler Monsanto L. C. Weger - Monsanto This conference was arranged to share information between Badische,' Monsanto and the Kettering Laboratory on chlor-acne. In the case of both Badische and Monsanto, the incident of chlor?acne followed the violent decomposition of a batch of trichloro~phenate in process. The Monsanto incident occurred March 8, 1949 and the German incident in December, 1953. Both cases were followed in a period of days or weeks by an outbreak of chlor-acne of epidemic prOportions. Following the Monsanto incident Dr. Suskind and the Kettering Labora tory have done extensive studies into the problem. Dr. Suskind reviewed,in some detail,work and studies which were carried out. In ?x the beginning, Dr: Suskind related tests and studies made on four of the more severe acne cases and presented pictures of the individuals involved together with photo micrographs of skin biopses showing acne lesions. Dr. Oettel presented similar photographs and photo micrographs of German cases which compared very closely with those from Monsanto. It appeared that the German cases may have been more severe with regard to the skin disturbances. It was also apparent. that the residual scarring was a good deal more pronounced. Dr. Suskind described in some detail, animal tests continued by skin application and by inhalation using both sodium TCP on a 015582 #1 11?f?r-pv w-r? IC- 5561 .t -2- variety of animals including rabbits, rats (adult and baby), cats, . dogs and guinea pigs, etc. While in many of the experimental animals evidence of toxicity was manifest, there was no chlor-acne' ?developed. Dr. Suskind and Dr. Oettel both agreed that the -so called "rabbit ear test", as developed and described by Messrs. Adams, Irish, Spencer and Rowe, is unrealistic and non?reproduceable. Since none of the very extensive animal experiments were successful in the production of acne, a decision was made to employ human volunteers in an attempt to find a means of evaluating the acnegenic? potential of various process materials. In the first of these experiments, Halowax 1014 (a known acnegen) was chosen as a control. This was applied as a 20% application in "plastibase" an ointment essentially of 5% Polyethylene in mineral oil. Halowax in this experiment was compared to 245T and both materials were applied to the forearm of the human volunteers and kep??in contact with the forearm on a continuous basis. Extensive liver function tests were conducted every other day and the volunteers were examined daily by a qualified physician who was particularly mindful of possible liver changes. In 2 to 3 days, redness develOped in the Halowax exposures and in 10 days there were some follicular changes terminating in actual lesions. There was no evidence of skin changes in the QHST exposures. Acne was produced only locallylin the sight of exposure in every case, that is, there was no systemic change. (At other hospitals with large scale tests, using Halowax, acne was produced in all.cases_except people above the age of 70.1 In no case was there any change in liver functionsFa- boo 015585 HM -3- In a later series of experiments, Dr. Suskind described how three -materials submitted by Monsanto were compared with Halowax using the technique described above. The materials from Monsanto were all sodium triphenolate prepared as follows: 1) Normal sodium TCP from a plant Operation 2) Sodium TCP made from distilled triphenol 3) Sodium TCP made from trichlorophenol purified by the Diamond Alkali technique (dilution, filtration, precipitation and washing) In this experiment acne was produced in the Halowax control cases and in the cases exposed to the normal plant produced sodium no acne develOped in the cases exposed to the treated TCP samples in the concentrations used. Dr. Suskind stated that the evolution of chlor-acne is very similar to Acne Vulgaris. Dr. Oettel and Dr. Suskind agreed that massive doses of Vitamin units per day) are effective in Acne Vulgaris. Vitamin therapy was unsuccessful in the Monsanto cases. Dr. Oettel was of the opinion that treatment was too late and stated that they have found that massive doses given in the very early signs of chlor?acne have often resulted in complete clearing of in 2 to 3 weeks. Dr. Suskind stated that there is evidence that peOple develop ache from inhalation or ingesting of Halowax and Dr. Oettel agreed that acne need not come from percutaneous absorbtion but also may be systemic in origin. "Dr. Suskind stated that in the Monsanto cases the skin problem was not disabling but the many other such as vertigo, aching muscles, own? I. 5(9? - ?4 015584 Tn ppo?m'NE ORDER ?gg and headaches were. In close checking the varying secondary (once termed bizarre) it developed that all of the typical were common'to both the German and Monsanto cases with the exception of and intolerance to cold. 'Dr. Oettel stated that materials such as Halowax and trichloro- phenol are not in themselves acnogenic but that the offending con- taminant is an "oxidate". Residues from the Badische decomposition have been extracted and elemental analyses made of the extracts (carbon, hydrogen, chlorine, oxygen). Following this, a series of oxygen bearing,chlorine bearing ring hydrocarbons were and checked for animal toxicity, using rabbits. Comparative acute toxicity of four of the compounds are as follows: 1) triphlorOphenol - greater than 1 gram per kilogram 2) tetrachloro naphthalene - 50 mg per kilogram 3) tetrachloro diphenylene oxide - 0.1 mg per kilOgram 4) tetrachloro diphenylene dioxide 0.005 mg per kilogram The latter compound (also called tetrachloro diphenyl dioxane) checks more closely by elemental analysis with the extract of the residues from the decomposition. Dr. Oettel is convinced that this is the active agent. They have developed a liver function test for rabbits which involves a micro determination of BrOmsulphalein retention. This _is used as a control test on purchased trichlorophenol (feeding l.gram of the sample per kilogram of body weight to each of three rabbits). If there is no more than 5% of BSP retention in 5 days, the material is )proved for processing. Dr. Oettel stated positively that there had been no cases of chlor- -acne in the QMST Operation. . . . . 12:55 14-. Jii? 015585 SURJEV .1 1. 7: ?3 at -5- e?gsn a later conversation while returning to st. Louis, it deve10ped at Badisohe "orks did not on "n yea; early in the hydrolysis as in the case of both Monsanto and Diamond Alkali, but was in_the stripping of excess methanol following the hydrolysis when the batch was dehydrated and decomposed. The decomposition pressure was relieved through normal pressure relief devices and the autoclave was also left full of a mass of coke so hot that it was "gleaming?. Badische has been able to reproduce the decomposition of NAJTCP by dehydration in the presence of iron. (This appears to still leave unexplained the type of decomposition experienced by Monsanto and Diamond Alkali.) Dadische no longer produces TCP but purchases trichloro-phenol from 5% Syer and uses the BSP test for acceptance or rejection of each lot. Bayer professes to have had no chlor-acne but Dr. Oettel doubts their veracity. Dr. Oettel stated that Baehringer in Ingelheim, Germany had' a slight decomposition in sodium TCP production and have had many cases of chlor-acne for many years. Their trichloro?phenol gave high results (positive) by the BSP tests. Dr. Oettel volunteered to run BSP tests for Monsanto on samples which we might forward to him. Mr. Wager agreed to have responsibility for following up on this work. 015586 5t? 7M