Carol Van Strum 7493 East Five Rivers Road Tidewater, Oregon 97390 Telephone: (503) 528-7151 . Telefax: (503) 528-7105 June 10, 1993 South County Courier P.0. Box 1030 Waldport, Oregon 97394 To the Editor: I read with interest the letter of Monsanto Company?s George H. Heywood, which you ran on June 8, 1993. Mr. Heywood expounded at length on the safety and virtues of Monsanto products Roundup and Rodeo, and claimed that an article by LCWW inaccurately described the hazards of Roundup. Why Monsanto Company would hire as a spokesman a person so ignorant of Monsanto?s own research and other scien? tific studies on Roundup is a question only Monsanto can answer. Mr. Heywood, for example, claims that the surfactant added to Roundup is not a spermicide. As reported in and elsewhere, the surfactant in Roundup, POEA, is one of a class of chemicals developed as spermicidal agents. Monsanto's own rabbit study conducted at Industrial Bio?Test Laboratories showed that one of Roundup's more severe effects was atrophy of the testes. If the poor little bunnies' scrotums were falling off, I would view that as a spermicidal effect. If Mr. Heywood would like to conceive children without testes he is welcome to make the attempt, but our families should not be used as Monsanto?s experimental animals. Presumably, Monsanto paid Industrial Bio-Test Laboratories precisely so it would not have to use human beings as test subjects. Monsanto's studies done at IBT also found giant multi~ nucleated cells in the testes of rabbits exposed to Roundup, suggesting a hazard of birth defects, mutations, and cancer. Mr. Heywood may be comfortable with the prospect of giant, multi- nucleated cells in his own testes, but roadside residents sub? jected to the same risk without their knowledge or consent might not be so sanguine. If Mr. Heywood is concerned about LCWW's "credible sources" for its information on POEA, he might start by reading Monsanto's own Material Safety Data Sheet on Roundup, which warns workers handling Roundup that the product contains POEA, identified by OSHA as a hazardous chemical. Roundup is so "safe" that it has become a popular means of suicide in Japan. Roundup suicides have enabled Japanese doctors to determine that a lethal dose for an adult human is less than 210 milleliters, and that the Roundup surfactant POEA is the primary cause of toxicity. Mr. Heywood's statements about the 1,4?dioxane contaminant of Roundup apparently came from the same fictional source as his pronouncements on POEA. Mr. Heywood proclaims categorically that 1,4?dioxane does not cause cancer. The International Agency for Research on Cancer has unequivocally classified 1,4-dioxane as a cancer-causing agent in animals. It has not been classified as a human carcinogen only because no human experiments have been done. Would Mr. Heywood be willing to volunteer as an experimen? tal test'subject, or does he prefer instead to use our children as the guinea pigs for this known cancer?causing chemical? Mr. Heywood says that Monsanto has found no detectable levels of 1,4-dioxane in Roundup. Mr. Heywood might be better informed if he read the experimental data that Monsanto submitted to the U.S. Forest Service, showing that Monsanto has in fact detected 23 parts per million 1,4?dioxane in Roundup. Mr. Heywood?s statement that 1,4?dioxane is found in 35,000 consumer products suggests that Monsanto is enjoying a healthy profit from exposing all of us to this known carcinogen from so many different sources. Adding the 1,4-dioxane in Roundup to these 35,000 exposures is "not a cause for concern" to Mr. Hey? wood, but people involuntarily subjected to Roundup exposure may not share his indifference. Understandably, Mr. Heywood prefers to talk about other Monsanto herbicides, such as Rodeo, which do not contain POEA or 1,4?dioxane. But Roundup pg; Rodeo is what the state intends to use on our roadsides. Before we expose our children, ourselves, and our environment to Roundup, perhaps we should all read the precautions on Monsanto?s Material Safety Data Sheet for Roundup: OUT OF REACH OF CHILDREN. CAUSES SUBSTANTIAL BUT TEMPORARY EYE INJURY. HARMFUL IF INHALEDEYES OR BREATHE SPRAY MIST OR GET IN OR ON CLOTHING. WEAR GOG- GLES, FACE SHIELD OR SAFETY GLASSES. WASH THOROUGHLY WITH SOAP AND WATER AFTER HANDLING. REMOVE CONTAMINATED CLOTHING AND WASH BEFORE REUSE. DO NOT APPLY DIRECTLY TO WATER, TO AREAS WHERE SURFACE WATER IS PRESENT OR TO INTERTIDAL AREAS BELOW THE MEAN HIGH WATER MARK. DO NOT CONTAMINATE WATER WHEN DISPOSING OF EQUIPMENT WASHWATERS. . . . THE SURFACTANT COMPONENT OF ROUNDUP HERBICIDE IS REPORTED TO CAUSE IRRITATION.TO THE EYES AND SKIN AND MAY CONTRIBUTE TO THE IRRITATION POTENTIAL REPORTED FOR THIS HERBICIDE. INGESTION MAY PRODUCE GASTROINTESTINAL IRRITA- TION, NAUSEA, VOMITING AND Mr. Heywood's "credible sources" for information about Roundup apparently do not include his oWn employer, Monsanto Company the same bastion of corporate responsibility that gaVe us Agent Orange, PCBs, and dioxin. If Mr. Heywood wishes to chal- lenge the credibility of others, he should do his homework first. Sincerely, Carol Van Strum ?To P?up NMLL, ll so. nswel?S Roadside spraying is not just Demandla?er to Margaret Info Clari?ed intended to keep drainage ditches Tg?? an open 8 Th: rcecent ago?; PUbliSizfd ":12 gig free of weeds, as stated article, but is also designed to in g, our May d25th Ef?e gigs: titled ."Roadside spraying prompts improve the ?ow of surface water off you ad ress warning issued by LCWW the pavement and reduce endin 5 re ing of the defoliant Emit-D (goo?sigting of about 50 percent Agent Orange) up the Yachats River. Margaret, you reminded us of the inevitable insidious effects that this spraying will have on. the bald eagles, our water suppites and we human beings. You posed some very reasonable questions about the very unreasonable policy of spraying now and asking questions it is too late. Your closing statement was, "Please as questions of our government-before it's too late!? . Margaret, if Nature couid' write letters or speak to those in the government who would again unieash this toxic defoliant upon her, she might say, "Please listen to me before it's too iate. Ask yourseives a few questions about contained severai and high inflammatory statements regarding Roundup herbicide' made by Monsanto. Your readers deserve to know the facts about this product. Roundup is known throughout the world for its favorable environmentai characteristics, such as its ability to degrade into naturally occurring elements such as carbon dioxide and its low toxicity. in fact, another (the active ingredient in Roundup) herbicide formulation-- Rodeo--is used by conservation groups and ecoiogists to control invasive piants and restore fragile native habitat in delicate applied to plants in standing water; ecosystems such as estuaries and however Rodeo has an aquatic wetlands. approval from the EPA and is used Roundup has been ,ln the to control undesirable vegetation in marketplace for it) years and wet ditches and around bridges. contains one of the iargest Both Roundup and Rodeo were databases in the world, with over vegetation that may impede visibility and contribute to the potential for fires from vehicle exhaust systems. Roadside sprlaying aiso keeps rootbound weeds from damaging pavement, which costs taxpayers money, and it aids in reducing the amount of time workers spend doing maintenance along our highways, where physical injuries can result from mowing and vehicles. Studies have shown that mowing can destroy animai and bird nests, and in some cases actually harm wildiife habitat. - it is true that Roundup cannot be the irreparable damage .you've aiready done in the past With your defoliants before you do it again . Sadly, her words and pleas would fell upon deaf ears. For the government has no ears and certainly no heart where matters of conscience, expedience and money meet. Money and expedience will most certainly win out. i speak from twenty years of experience with this painful reality. You see Margaret, i'm not a bald eagle nor an endangered species. i am a victim of Agent Orange. Perhaps, in a sense, i am an "endangered species". But the government hasn't listened to me, nor to the questions in the voices and hearts of thousands like me. i fear that whether it be a patch of jungle up the Central Highlands or a patch of trees up the Yachats River, if it's expedient for the government then the inhabitants are expendable. (Acceptable Losses) So my message to you and others who are concerned about the spraying of the defoliant 2, 4-D up the Yachats River is this: Don't simply ask questions. Demand answers and demand accountability "before it is too iate?. Don Pearce, Viet Nam vet Waldport H5 400 studies regarding health and environmental effects. This comprehensive database was reviewed by the us. Environmental Protection Agency (EPA) when it classified the active ingredient in Roundup and Rodeo herbicides, as Category E, or "non- cancer causing to humans?. The other categories used {by the EPA in assessing evidence or carcinogenicity are A through with being the most favorabie. The surfactant in Roundup also has been extensively tested and is the same soapy substance found in shampoos. The trace constituent mentioned in your article, i, 4? dioxane, is present in about 35,000 household products including cosmetics, shampoos and soaps. it aiso occurs naturally in tomatoes and shellfish. This constituent is not a human carcinogen and is not a cause for concern. in the case of Roundup, an improved manufacturing process has reduced the level of t, 4-dioxene to a non- detectabie status in the formuiation. r-?i tested prior to being registered for . this kind of use, and those tests took place over an 8 to 10 year period. Re-testing continues after a product is registered, so that effectiveness and safety considerations are constantly being assessed. The last piece of misinformation that i want to address is that the surfactant in Roundup is used as a spermicide. This false statement alone is enough to make your readers question the validity of all the other statements in the article provided by the LCWW. The misinformation contained in this article does your readers a disservice. in the future, i would strongiy suggest that you verify the information that this group provides you with several other credible sources. it i can help you with questions about our products, or recommendations for credible sources, please give me a caii. George H. Heywood Corvaiils ?cu?f?lfl C?un?I-y Crag-(Jan jam {993 ?awems 3229922355 0F woos-name WTEEIALS 51:1- N. trams Sax V6110 Remand) 'qs? x; Flash p: 1e1 uel 22%; autoign temp: Incomp: Air; decaborane(14); nickel; sulphide trioxide; CAS RN: 123911 mf: 04.11302; mw: 88.12 Colorless liquid. pleasant odor. mp: 12?, bp: 101.l?. lel uel 22.2%, ?ash p: (CC), (1: 1.0353 autoign. temp.: vap. press: 40 mm 25.2?. vap. d: 3.03. SYNS: DIETHYLENE maxim: moxme DIETHYLENE amen 0x101!) 0101:5141: (rouse) (ITALIAN) Drown-1.4 (DUTCH) mom-1.4 (GERMAN) TOXICITY DATA: 3 eye-hmn 300 ppm/15M skn-rbt 515 mg open MLD eye-rbt 21 mg eye-gpg 10 ug MOD orl-rat 185 NIOSH JG 8225000 P-DIOXAN (0213011) 1,4-moxaua moxme (manor!) DIOXYETHYLENE amen surname amen NCI-CO36B9 Tamuvono-P-moxm mumnao?lA-moxm CODEN: 28,262.46 12/17/71 AJOPAA 29.1363,46 JPPMAB 11,150.59 NCI-CG-TR- 80.78 orl-mus gm/kg/90W- NCI-CG-TR- 80,78 skn-mus gm/kg/GOW- EVHPAZ 5,163.73 BETA orl-rat orl-rat 01cm 24,164.70 NCI-CG-TR- 30.73 80.78 BJCAAI 24,164.70 INCIAM 35.949.65 AMIHAB 20,445.59 PHRPAG 452023.30 7.22.75 29MAR77 KBAMAJ 11.53.77 EJCAAH 9,237.73 111mm 21,173.39 KBAMAJ 11.53.77 1919911117 6.342.47 111mm 21,173.39 HHTAB 21.173.39 ucns" 12/17/71 JOHYAY 35,540.35 orl-mus orl-rat orl-rat . ihl-hmn ppm=UNS ihl-_hmn 5500 ppm/ 1 EYE ihl-hmn ppm/3D orl-rat mg/kg ihl-rat gm/m3/2H ipr-rat mg/kg orl-mus mg/kg ihl-mus gm/m3/2H ipr-mus nag/kg orl-cat rug/kg orl-rbt mg/kg skn-rbt mg/?kg ivn-rbt 1500 mg/kg orl-gpg mg/kg JIHTAB 23,259.41 Aquatic Toxicity Rating: Carcinogenic Determination: Ani- mal Positive 11,247.76. TLV: Air: 25 (skin) 4,154.80. Toxicology Review: BNYMAM 54,413.78; 27ZTAP 3.59.69. OSHA Standard: Air: TWA 100 (skin) (SCP-G) FEREAC 39.23540,74. DOT: Flammable Liquid. La- bel: Flammable Liquid FEREAC 41.57018,76. Occupa- tional Exposure to Dioxane recm std: Air: CL 1 ppm/ 30M NCI Carcinogenesis Bioassay Com- 1227 pleted: Results Positive: Mouse, Rat NCI: NTP Carcinogenesis Bioassay Com- pleted: No Report-Data Insuf?cient. Manual of Analytical Methods? VOL 1 127, VOL 3 S360. Re- ported in EPA TSCA Inventory. 1980. EPA TSCA 8(a) Preliminary Assessment Information Pr0posed Rule FERREAC 45.13646.80. THR: An exper CARC, ETA. A UNS. EYE. HIGH humn ihl. MOD orl. ivn, ipr. ihl. LOW skn. orl. ipr. effects from 5500 for min. Exposure of animals to come of 0.1 to 3% of dioxane vapor causes irr of the eyes and nose. followed by narcosis and/or pulmonary edema and death. The irr effects probably provide suf?cient warning. in acute exposures. to enable the workman to leave exposure before he is seriously a??ected. On the other hand. repeated exposure to low conc has resulted in human fatalities. the organs chie?y. affected being the IiVer and kidneys. Death resulted from acute hemorrhagic nephritis. The hepatic lesion consists of an acute central necrosis of the lobules. The - brain and lungs may show acute edema. In acute exposures. the signs and consist of irr of the eyes and naso-pharynx. which may later subside. to be followed by headache, drowsiness. dizzi- ness. and occasionally nausea and vomiting. In chronic exposures. there may be loss of appetite, nausea and vomiting. pain and tenderness in the abdomen and lum- bar region. malaise, and enlargement of the liver with- out jaundice. There may be changes in the blood pic- ture. Further exposure may result in suppression of urine. followed by uremia and death. Fire Hazard: Dangerous, when exposed to heat or ?ame; can react vigorously with oxidizing materials.? Explosion Hazard: When exposed to ?ame or by chemical reaction with oxidizers. Violent reaction with (H2 Raney Ni). To Fight Fire: Alcohol foam. C02. dry chemical. ., DITHIOPHOSPHATE). CAS RN: 16270863 NIOSH TD 7526000 . mf: CmngOstS? mw: 456.56 SYNS: ms-Zj-r?moxxneormmb nonrrmox'rs) mosmonoorrmorc ACID, s,s as- TER, TRANS- TOXICITY DATA: 3 CODEN: sou-rat mg/kg TXAPA9 5,605.63 unit-mam mg/kg 3OZDA9 -.373,7l THE: HIGH scu, unk. See also esters. Disaster Hazard: When heated to decomp it? emits very tox fumes of POI and CAS RN: 766154 NIOSH JH 0525000 mf: 05111202; mw: 116.13 221 2 PHOSPHINIC ACID cough and sputum. Coma or convulsions may precede death. Most cases recover without aftereffects. Chronic poisoning, characterized by anemia, bronchitis, gastro- intestinal disturbances and visual, speech and motor disturbances, may result from continued exposUre to very low cone. Fire Hazard: Very dangerous, by spont chemical reaction. Explosion Hazard: Mod, when exposed to ?ame. Reacts violently with air, BCls. C120. HNOs. NO, NCla, N03, N20. HN02, 02, (K Explosive Range: Not known. Disaster Hazard: Dangerous; when heated to decomp it ?emits highly tox fumes of can react vigorously with oxidizing materials. To Fight Fire: C02, dry chemical or water Spray. PHOSPHINIC ACID mf: mw: 66.00 SYN: Hvrornosruonous ACID THR: 'No tox data. Redox reaction is explosive. Disaster Hazard: When heated to decomp it emits tox fumes of PHOSPHOARGININE, nitrosated NIOSH SZ 5999000 CODEN: GANNAZ 65.45.74 TOXICITY DATA: mmo-sat 40 mmol/L THR: MUT data. Disaster Hazard: When heated to decomp it emits tox fumes of ACID NIOSH CI 9469000 mf: mw: 255.14 SYN: PALA TOXICITY DATA: 3 unit-mus 12 mg/kg/(7D preg) ipr-mus mg/kg (8D preg) ipr-mus mg/kg (8D prcg) unk-hmn mg/kg THR: An exper TER. Disaster Hazard: When heated to decomp it emits very tox fumes of and P03. PHOSPHONIC ACID, MONOMETHYL ESTER CAS RN: 13590711 NIOSH SZ 9620000 mf: mw: 96.03 SYNS: METHYLESTER xvseunv FOS- FORITE (CZECH) TOXICITY DATA: 2 skn-rbt SO mg/24I-I SEV eye-rbt 50 ug/ 24H SEV orl-rat 1740 rug/kg CODEN: APTOD9 TJADAB 22,311.80 TJADAB 22,311.80 DRFUD4 6,152.81 (CZECH) CODEN: 2BZPAK -.2l4,72 ZBZPAK -.214,72 282PAK -,214,72 THR: MOD orl. Skn, irr. See also esters. Disaster Hazard: When heated to decomp it emits tox fumes of PHOSPHONIUM IODIDE NIOSH TA 2350000 mf: mw: 161.91 Tetragonal, colorless, deliques mp: sublimes 18.5?; d: 2.86; vap. press: 40 mm 16.1?. 760 mm 625?: THR: HIGH via or] route. Rapid heating causes detona- tion. Violent reaction with bromates. chlorates, iodates, H102, Disaster Hazard: When heated to decomp it emits very tox fumes of and PHOSPHONIUM PERCHLORATE mf: mw: 363.5 THR: A very explosive salt which cannot be dried. HIGH orl. A powerful irr. CAS RN: 1071836 NIOSH MC 1075000 mf: mw: 169.09 SYNS: ROUNDUP TOXICITY DATA: 3-2 CODEN: orl-rat L050: 1568 mg/kg TXAPA9 45,319.78 ipr-rat rug/kg TXAPA9 45,319.78 orl-mus mg/kg ipr?mus mg/kg orl-rbt mg/kg orl-rat mg/kg ipr-rat mg/kg orl-mus 1581 mg/kg ipr-mus LDSO: 130 mg/kg THR: HIGH ipr; MOD orl. Disaster Hazard: When heated to decomp it emits very tox fumes of NO, and TXAPA9 45,319.73 TXAPA9 45,319.73 7.6.78 TOLEDS TOLEDS TOLEDS TOLEDS PHOSPHORAMIDE MUSTARD CAS RN: 1566150 NIOSH TD 25300700 mf: mw: 320.24 SYN: ACID, CYCLO- HEXYLAMMONIUM SALT TOXICITY DATA: 3 mma-esc 1 mmoi/L ipr?mus mg/kg (11D preg) ipr-mus TDL03270 rug/kg (11D preg) TER ipr?mus 154 mg/kg (11D preg) see-rat=emb 50 ug/L .. dud-mus=leu 150 umol/ cyt-ham =ovr 200 umol/L 26,108.80 . sce-ham30vr 10 umol/L 26,108.80 THR: MUT data. An exper TER. CODEN: JTEHDG 3,637.77 TJADAB 4,141.71 TJADAB 4,141.71 TJADAB 4,141.71 ENMUDM 2,302.80 MOPMA3 19,331.81 cad Ndlmill 2.?be La'nEl-l SEE EBS aN?Hd uotsm meg/mag .5499 ?,on MQNSANTO MATERIAL SAFETY DATA Fans 1 0M MONSANTO COMPANY arm N. LINDBERGH ST. LOUIS. MO 63167 EMERGENCY PH. N0. (CALL (314) 694-4000 DA TE PREPA RED: Febhmr}; 1992 NAME HEHBIQIDE 5 bnoouct' IDENTIFICATION EPA Registratlon Number: 524-445 Synonyms: Nona Chemical Name: Not Applicable. Formulated Produot Active Ingredient: N-(phosphonomothyl) glycine, in tho Iorr'n of its isopropylamine salt Inert lngrodionts: 3mg - 1 00.0% *Contains 480 grams per liter or 4 pounds per gallon of the active ingredient in the form ot its isopropylamine salt. EQtrivolont to.356 grams per "terror 3 pounds per U.S. gallon of the acid, OAS 899.110.: Not Appliwble. Formulated "Product CA3 Reg. No. Active Ingredient: oor Proper Shipping Name: Not Applicable . 1 DOT Hazard Class/LO- No.: Not Applicable 1 DOT Label: Not Applicablo Roponablo Quantity (no) Under Not Applicable U.S. Surtnco Freight Classi?cation: Weed killing compound. N.O.I.B.N. SARA Hazard Noti?cation Hazard Categorios Under Criteria of SARA Title Rules (40 CFR Part 370): Immediate Section 313 Toxr'o Chemicotfs}: Not Applicable} Hazardduo Ghomloal(a) Under OSHA Hazard Communication Standard: This product containsl as components. the substances listed below which are identi?ed as hazardous chemicals under the criteria 0! the OSHA Hazard Communication Standard (29 CFR 51910.1200): Ethoxylatod Tallowaminos. GAS Reg. No. 61781-262 WARNING STATEMENTSI Keep-out of roach cl children. SUBSTANTIAI. BUT TEMPORARY EYE HARMFUL IS PROHIBITED . SEE INDIVIDUAL CONTAINER LABEL FOR HEPAGKAGING LIMITATIONS PRECAUTIONAHY MEASURES Do not get in or breathe spray r'niat or got in orpn clothing. Wear goggles. face shield or anxiety glasses. . Wash thoroughly with amp and water arter handling. Remmro contaminated clothing and wash before reuse. DU apply diruoliy to water, to areas where surfaoo water is present or to intertidal areas: below the mean high water mark. . . . Do not contarttinatu water when disposing of equipment woohwators. I I I EMERGENCY AND FIRST AID pnepeounes FIRST AID: . IF IN EYES: Immediately tlush with plenty oi water lor at least 15 minutes. Get medical . attention. IF ON SKIN: Immediately ltush with plenty oi water. Remove contaminated clothing. . Wash clothing betore reuse. IF SWALLOWED: This product will produce gastrointestinal irritation. Immediately dilute by swallowing water or; milk Get medical attention. . IF INHALED: Remove individual to trash air. Get medical attention it breathing ditticulty develops. NOTE: For additional human emergency ?rst aid or treatment guidance call collect anytime. day. or night (314) 694- 4000 OCCUPATIONAL CONTROL PROCEDURES EYE PROTECTION: Wear chemical Splash goggles during mixinglpouring operations or other activities in which contact with undiluted herhidde is likely to occur. SKIN PROTECTION: In cases in which prolonged or repeated skin contact with ROUNDUP herbicide may occur . long-sleeved shirt. long pants and chemical protective 9. rubber) gloves are recommended. Wash hands and contaminated skin otter handling. Clothing soaked with a eelution ol herbicide should be removed and laundered beiore reuse. RESPIRATORY PROTECTION: Rewiratery protection should not be required ior normal use and handling. During periods at abnormal exposure to heavy spray or mist, use approved equipme at for pesticide vaporlmist' Ia reocmmended.1he respirator uco limitations specified by or the manufacturer must be observed. VENTILATION: No special precautions lit? recommended. AIRBORNE EXPOSURE LIMITS: Product: Herbicide - 100% by wt. OSHA PEL: None established AGGIH TLV: None established Ethoxylated Tallowamine . OSHA-PEL: None established ACGIH TLV: None established FIRE ROTECTION INFORMATION Flash Point: - Method: To; Closed Cup . Media: Water spray, loam. dry chemical or CO or any Class extinguishing agent. Spec Ial? Fire Fig Procedures: Fire ?ghters and others who may be exposed to vapors or products oi combustion should wear a cell-mntained breathing apparatus and full protective clothing. Equipment should be thoroughly cleaned after use. Unusual Fire and Explosion Hazards: None. REACTIVITY DATA . Stable tor atheist 5 yamc under normal conditions at warehouse storage. Heated iadlities art-J rIul "attuned. Incompatibility: Spray oolutionc of this product ahauid be mixed. atomd 01' applied uniy in stainless steel, aluminum; ?bergleac, plastic and plastic-lined containers. DO NOT MIX. IQTEIRE OR APPLY THIS PRODUCT OR SPRAY SOLUTIONS OF Ti iN GALVANIZED on UNLINED (EXCEPT STAINLESII STEEL) on SPRAY TANKS. Thie product or spray coiudone of this product react with such containorc and tanks to produce hydrogen gee which may Iorm a l-ughly combustible goo minturu This gas ntiJItLIIo Wold Ilaelt on explode. causing serious poremai' Iniury. it ignited by open ?ame sper?r?t welder' a torch Iighiod cigarette or Ott'to'r Igniti?n souruu Hazardous Decomposition Products: None. . Hazardous Docs not occur. This product can read with L-IIustiI: (basic) Irtuturiuia to liberate heat. This is not a poiymoma?on but rather a olmrnicai neutralization in an acid Milan MATERIAL SAFETY DATA 4 HEALTH EFFECTS SUMMARY The lollowing lnlorrnation aummariaea human experience and reaulta ot actentiito Inveatlgationa reviewed by health proteaalen- ala tor hazard evaluation oi herbicide and development at Precautionary Statementa and Occupational Control Procedures recommended in this document. EFFECTS OF EXPOSURE . Dermal contact and Inhalation are expected to be the primary routes cl occupational expoaura to HOUNDUP herbicide. Direct contact with this material may cause temporary irritation and Prolonged contact with ROUNDUP may cause akin Irritation. Ingestion of ROUN DUP haa been reported to produce gastro- Inioatlnai discomiort with irritation oi the mouth. nausea. vomiting and diarrhea. Oral Ingestion of large quantities ot concentrated product has been reported to reauit In hypotonalon and pulmonary edema. TOXICOLOGICAL DATA . Data lrorn laboratory studios conducted by Hon-onto with herbicide are summarized below: Single ctrpoaure (acute) atudlea indicate: Oral . Terrie (Fiat LDW - 5.000 Oral- Practically Nontortio (Mouse - >5.000 mail-lg) Dermal a Practically Nontoaic (I-?tabbit - a5.000 trig/liq) inhalation -Slightiy Toxic - 3.18 mg/I) Irritation - Moderately Irritating (Rabbit) Skin irritation - irritating (Hobbit. 4-hr exposure): DOT Skin Corrosion - Not Corrosive (Rabbit. 4-hr exposure) No skin irritation. allergy or phoioallergy was reported in human volunteers following repeated skin exposure: no skin irritation or photoirritation was reported with single skin exposure. No skin allergy was observed in guinea pigs letlowing repeated skin exposure. repeated skin exposure (3-week) to herbicide at 5 times the intended use concentration. severe skin irritation and systemic toxic effects (deatti. reduced food consumption. body weight loss and testicular ellects) were observed in rabbits. Slight to moderate skin irritation was the only eiiect in rabbits treated with 3 times the intended use concentration. Systemic toxic eliects at 5 titties use concentration were considered to be a secondary response to the stress of severe skin irritation. to which rabbits are particu- larly sensitive. rather than the result at direct systemic toxicity. There was no evidence at cholinesterase inhibition in dogs (single oral doses}. Minor nasal Irritation was observed toilewing repeated inhalation (?t-weeks) oi a 33% ROUNDUP herbicide solution by rats. When herbicide was applied to skin at rhesus monkeys. an extremely low emountii.8%) at the active ingredient was absorbed. . . COMPONENTS Data lrom laboratory atudiea conducted by Monsanto and treat the scienti?c literature on components at ROUNDUP herbicide: tsopropylamine Salt cl thphosate . Data from studies with a tormulation comprised at 62% isopropylamine salt at (MON the lollowing: MON 0139 was practically nontoxic orally {rats} or alter skin application (rabbit?s). it was nonirritating to rabbit eyes and practically n?onirritating to rabbit skin. In repeat dosing studies (6-month). dogs ted men 0189 exhibited slight body weight changes. Following repeated skin exposure (3 week) to MON eras. skin irritation was the primary effect in rabbits. Additienel toxicity inlorrnation is available on the active herbicidal ingredient cl MON 0139. which has been tested in mutapenicity. teratcgen?rcity. reproductive. acute. subchronio and chronic toxicity studies. - Surtactant . The suriaotant component oi herbicide is reported to cause irritation to the eyes and skin and may contribute to the irritation potential reported lot this herbicide. ingestion may produce gastrointestinal irritation. nausea. vomiting and diarrhea. PHYSICAL DATA Appearance: Clear. viscous ember solution. pH: 4.4 4.9 Odor: Practically odorless to slight amino litre odor. - apecitlo Gravity (Water :a 1): Li? NOTE: lhese physical data are typical values based on material tested but may vary from sample to sample . Typical values should not be construed as a guaranteed analysis at any specific lot or as items. SPILL, LEAK s. DISPOSAL SPILULEAK: Observe protective andaalety precautions when cleaning up Soc Occupational Control Procedures. Liquid spills Oil or other impervious surfaces should beioantained or dikert. and should be absorbed with tittiipulgile. bontonite or other absorbent clays. Collect contaminated absorbent. place in plastic-lined motel drum and dispose at in. accordance with instructions provided under DISPOSAL. Thoroughly scrub ?oor with a strong industrial type solution and rinse with water. Liquid spills that 5031? in") the ground 5'10?? 5? ring-up. Piailbci in plastic-lined motel drums and disyrt?rrtr'rr'i ill in accordance with ins tructiens provided under DISPOSAL. - - '1 MQNSANTQ MATERIAL SAFETY DATA . - - vacate?- SPILL, LEAK 8i DISPOSAL INFORMATION Observe all protection and safety precautions when cleaning up spills see Decepational Gontrol Procedures. Liquid spills on floor or other imperviOus surfaces should be contained or diked. and should be absorbed with artepulgite. bentonite or other absorbent clays. Collect mntemineted absorbent, place in plastiolined metal drum and dispose of in accordance with instructions provided under DISPOSAL. Thoroughly scrub floor with a strong industrial type detergent solution and rinse with water. Liquid epiile that soak into the ground should be dug-Lip. placed in plastic-lined metal drums anddisposod ct in accordance with instructions provided under . Leaking containers should be "separated from non-leakers and either the container or its contents translerred to a plastic- lined drum or other non-leaking container. Dispose of leaking container in, accordance with instructions provided, under DISPOSAL Any recovered spilled liquid' should be similarly collected and disposed of. Do not contaminate water. foodstuffs. feed or seed by storage or disposal. DISPOSAL: Wastes resulting Item the use ct this product that cannot be used or chemically reprocessed should be disposed of in a land?ll approved ior pesticide disposal or in accordance with applicable Federal, state or local procedures. Emptied container retains vapor and product residue. Observe all labeled seteguarde until container is cleaned reconditioned or destroyed. DO NOT our on WELD ON on NEAR THIS CONTAINER. 5 Metal Drums; Triple rinse container. Then otter for resycling or reconditioning. or puncture and dispose of in a sanitary land?ll. or by other procedures approved by state and local authorities. Metal guilt; Triple rinse emptied bulk containers. Then otter tor recycling or reconditioning or disposal in a manner approved by state and local authorities. Plastic Drums Do not reuse container. Return container per the Monsanto container return program. it not Mulls; returned. triple rinse container. than puncture and dispose of in a sanitary land?ll. or by incineration. or. if allowed, by state and local authorities. by burning. it burned. stay out of smoke. DATE: February. 1992 SUPERSEDES: August. 1989 M808 800012114 3 (preyiously Mommas) I a ton nocrrlotm. NON-auanoencv INFORMATION. CALL: 1-300-332-3111 i. Although the Intonation and recommendations oet tor-1h herein {hereinafter 'Intormatlon') are presented In good faith and believed to bl Gutrtt??l on Of tit! date hdrooi. Monsanto Company make; no representations as to the completeness or accuracy thereof. Information Is supplied upon the condition that the persons receiving same will make their own determination as to Its suitability-tor their purposes prior to use. In event will Monsanto Company be responsible tor damages of any nature whatsoever resulting from the use at or reliance upon information. NO REPRESENTATIONS OR WARRANTIES. FXPRESS OR IMPLIED. 03" - FITNESS i' on A PARTICULAR PURPOSE OF ANY OTHER NATURE ARE MADE HERFLINDEB WITH RESPECT I or re our onunocompeny MbUerl INFORMATION PROFILE U. S. on Artatctuttutn Healthy Forests Make A World 01? Difference liontts'r SlilWlL'li. Ntilt?l?llWliSl? lit-anon This information pro?le is produced by the Forest Service, Paci?c Northwest Region, for employees, forest workers. and for the public. It provides information on forest and land man. agement uses, environmental'and human health effects. and safety precautions for the herbicide and its formulations. A list of de?ni- tions is included in Section of the informa- tion pro?le. For general information on herbicide use by the Forest Service. refer to the PNW Region Treatment Methods Pro?le for Herbicides. 1. BASIC INFORMATION Cosmos: Nme: CHEMICAL. NAME: N~(phosphonomethyl) glycine PRODUCT Names: Roundup?, Rodeo?. Accord?D Herbicide REGISTERED Use ?General Use" FORMULATIONS: Commercial products generally contain one or mere inert ingredients. An inert ingredient is anything added to the product other than the active plant-killing ingredi- ent. The names of inert ingredients are not usually listed on the label. The contents of three sate formulations are listed below: Rodeo?? (53.5 and water Accord?! and water 8.5 Roundup?! related orgat acids of lsoprOpylamine polyethoxylated tallow entitle surfat tent and water RESIDUE Assn Mmons: Gas?iquid chromatogra phy and high performance liquid chromatOgraphy methods are available for residue assay. labora- tory tests. an average of 80% of lotOwn concentrations was recovered (Cowell, 1986). II. HERBICIDE Uses Rants-rattan FORESTRY, RANGELAND, RIGHT-OF- Uses: Planting site preparation. conifer release, forest nurseries, rights-of-way and facili- ties maintenance. and noxious weed control. OPERATIONAL DETAILS: Target Plants: is used to comm grasses, herbaceous plants, including deep rooted perennial weeds, brush. some broadle; trees and shrubs, and some conifers. sate does nor control all broadleaf woody plants. Tinting is critical for effectiveness on some broadleaf woody plants and conifers; Mode of Action: is applied to foliage. It is absorbed by leaves and rapidly moves through the plant. prevent the plant from producing amino acids that an the building blocks cf plant proteins. The plant. unable to make proteins, stops growin: and dies. is metabolized or broke down by some plants. while other plants do. nor break it down. AMPA (aminomethyl- phosphonic acid) is the main break-down product of in plants. From Gang Hale Deu./Gaia Uisian PHONE Ha. .Ala: 1Vulttlalcilization: does not evapo- rate easily. Potential for By-Products from Burning ol' Treated Vegetation: Major products from burning treated vegetation include phosphorus AK. pentoxide,_acetoniuile, carbonldioxide and water. Phoi??i?i?bi? pontoxide forms phospho- ric acid in the presence of water. None of these compounds is mm to be a health hazard ut the levels which would be found in a vegetation fire. -IV. ECOLOGICAL EFFECTS Non-Tanner anautsms: Soil Microorganisms: Most studies have shown no adverse effects on soil microorgan- isms. including soil nitrogen cycling processes (PBS. 1984). One study found a reduction in nitrogen-?xation by clover planted 120 days after was applied. The authors eduld nut conclude whether the. reducdon was due to direct effects to the bacteria, or on plant processes that support nitrogen ?xation (Eberbach and Douglas, 1983). Plants: Contact with non-target plants may injure or kill plants. Aquatic Animals: is no more than toxic to ?sh, and practically non- toxic to aquatic invertebrate animals. It does not build up (bioaccumulate) in ?sh. A mis- printcd concentration in fish ?llets in one published study has caused confusion (Foltnar. I984). The Rodeo?fonnulations are pracdcally nonvtoxic to freshwater ?sh and aquatic invertebrate animals. The Roundup? formulation is moderately to toxic to freshwater ?sh and aquatic invertebrate animals. and its formulations have not been tested for chronic effects in aquatic animals. Acute toxic levels are: V. HEALTH EFFECTS TESTING . 413s Mag.2? tees Fez Rodeo! Roundup Species Accord L050 L050 fish to 26 invertebrate 930 4 to 37 Terrestrial Animals: is practi- cally non-toxic to birds and manunals. It is practically non-toxic to bees. Acute toxic levels are: Species L050 bobwhite quail 3.850 mg/kg bee >100 nil? and its formulations have not bee tested for chronic toxicity on wildlife species Testing on laboratory mammals of and its formulations is reported in Seetion V. Threatened and Endangered Species: may be a hazard to endangered plants if it is applied to areas where they live. EPA identi?ed '76 Species that may be endan- gered by use. including 74 plant. . one mad- and one beetle species. The data below are results of laboratory animal studies. For the Environmental Pro. tendon Agency has evaluated those studies during the registration process. For Roundupaformula- tion, the ?ndings are from Monsanto studies citet in the Material Safety Data Sheet. The Rodeae?an Accordafonnulations, which cousin of and water only, are not expected to cause. any greater health effects than concentrated sate. - . These data are used to make inferences relative tt human health. - PHONE NU. 523 925 4138 ?From Gary Hale Dev./Gaia Uision Mag.2? 1993 pg3 .r in. tEs?i" 93" . 't u- 5? (Rnraooucrtonmevawmmivram Ems or Emeline 'ro Foamsmo The EPA and the PNW Region FEIS used a NOEL of 10 based on observed kidney effects in rat pups. The PNW Region FEIS evaluated the testing as marginally adequate for these effects. Hogan HEALTH Erasers Acorn (POISONING): Reported Effects: Most incidents reported in humans have involved skin or irritation in workers after exposure during mixing, loading or application of giyphosate formulations. Nausea and dizziness have also been reported after exposure. Swallowing the Roundup?formulation caused mouth and throat irritation, pain in the abdov men. vomiting. low blood pressure, reduced urine output. and in some cases, death. These effects have only occurred when the concen- trate was accidentally or intentionally swal- lowed. not as a result of the proper use of Roundup?! The amount swallowed averaged 100 milliliters (about half a cup). Cancun: Reported Effects: There are no reported cases of long term health effects in humans due to or its formulations. POTENTIAL son onaasa: HEALTH East-ms mom lunar INGREDIENTS CONTAINED nu ma Foamucareo Pnoouc'r: Inert ingredients found in may include water and a surfactant (polyethoxyiated tallowamines). The surfactant is an irritant and skin irritant. Water is non-taxic. The only inert ingredient in Rodeomor Accordwis water. Pnonnms: - The Roundup?fortnulation is moderately toxic, and may cause skin irritation and irritation. Since Accord?and Redeo'icontain water as the only inert ingredient. health effects are assumed be no greater than those for pure HEALTH Emma Assume-mu CONTAMINAHTS: contains the contaminant ?nitroso (NNG) at 0.1 or less.- The poten- tial for NNG to cause cancer is unknown. The EPA has not assessed the health risks of NNG. No carcinogenic effects were observed in tests oi the EPA concluded these tests were evidence of noncarcinogenicity and Ghali, 1991). a known cancer- causing agent. is a common contaminant of ethoxytated surfactants. The EPA decided that reported trace levels of 1,4-Dioxane in the Roundup?formulation were not likely to rear in unreasonable adverse health effects. More recently. Monsanto reports that 1,4aDioxane contamination has been further reduced to 23 parts per million . (Monsanto reference Hana-m Earns-ts Assocrn'rno OTHER Fonstumnons: Some formulations of also contain ti herbicides or dicamba. The information it this pro?le only applies to Informa- tion pro?les for and dicatnba will describ the properties and potential effects of those cities. None of the pro?les on individual herbicides fu describe the potential for health or environment effects from the formulations containing multip herbicides. Additional information on the props tiesand potential effects of these formulations will be prepared before they are used in the PN Region. u-Ia' tiloorg ?dlE uau.xua1a U151on No. Pancammst Public opinion about herbicide use in general ranges from a perception that herbicides are completely safe. to a perception that they are very hazardous. A full range of opinion is available 1n the PNW Region FEIS. The PNW has contracted to produce a bibliography of recent anecdotal and scientific accounts, and an analysis of reported 2" isomer health effects. This Information Pro?le'?. will be updated to re?ect the results of these reviews as needed. VII. Sararr Paacaurrons SIGNAL Wono AND DEFINITION: Roundup?! WARNING - Causes irritate tion. Harmful if swallowed. May cause skin irritation. Rodeo?! CAUTION - May cause irrita- tion. May be harmful if inhaled. Accord?: CAUTION - May cause irrita- lion. PnOretirrva Paacaorrorts son Avoid contact'with eyes. skin or clothing. Avoid breath- ing vapors or spray mist. Wash thoroughly with soap and water after handling. Mantcar. TREATMENT Pnocanunss (Ammorss): There is no speci?c antidore for treat For exposure to the eyes. flush with plenty of water for at least 15 minutes. Get medi- cal attention. For exposure to the skin. flush skin with plenty of water. In case of emergency, call your local poison control center for advice. HANDLING, STORAGE AND DISPOSAL: is corrosive to unlined steel and galvanized steel. Do not mix. store or apply in galvanised Steel or unlined Steel containers of spray tanks. is stable under normal storage condi? tions for at leasr 5 years. Wastes should be dis- posed of in a land?ll approved for pesticide disposal or according to federal. state. and local 5 3 LEI 01 413E Mag.2? 1993 P34 rules. Do not contaminate water. food. animal feeds or seed by storage. EMERGENCY (Sr-11.1.) l-lazartns sNo Paocssunrts: Spills that soak into? the ground should be dug up and put in plastic lined drums for disposal. Spills on floors or Other hard surfaces should be contained or diked. An absorbent clay should be used to soak up thespill. The contaminatefd,..i . absorbent should be put in plastic lined rhe'iai timers. Drums ofl contaminated soil should be disposed of in a landfill approved for pesticide disposal or according to federal. state and local rules..Do not contaminate water. food. animals feeds or seeds by disposal. In case of a large spill. call CI-IEMTREK at 1-800-424-9300 for advice. Desmrnoss acute toxicity - the amount Of a substance. as a single dose. to cause poisoning in a test animal adsorption - the process of attaching to a surface avian - of, or related to. birds hioaccumulate - the uptake of a chemical by an organism from its environment carcinogenicity - ability to cause cancer dermal - of, or related to. the skin formulation - the form in which the pesticide is supplied by the manufacnuer for use trill treatment - a hill of overlapping axe cuts is made tluough the bark of a tree. and the injured surface is painted or sprayed with herbicide half-life - the time required for half the amount of substance to be reduced by natural processes herbicide - a subStance used to destroy plants or to slow down their growth LC50 - the concentration in air or water which will kill 50% of the subjects Loss - the dose which will kill 50% of the subiws From 1! . Garg Hale Uision PHDNE No. I 533 925 4135 i Folmar Dr. Leroy (2., 1.1.5. Department of Com- meme} National Oceanic and Amosphen'o Administration. 1984. Error in Published in Fish Fillets. Personal Communication to Dr. Robert A. Campbell. Khan, Shahamat U., and Young, J. Christopher. 1977. N-Nitrosamine Formation in Soil from the Herbicide Journal of Agri~ cultural and Food Chemistry 25: no. 26 pp. 1430-1432. Newton, Michael. et a1. 1984. Fate in an OregouFor-cst Ecosystem Journal of Agricultural and Food Chemisn'y 32. no. 5: pp. 1144-1151. O?Brien. Mary H. Pesticide Fact Sheet: Roundup?: Northwest Coalition for Alterna- tives to Pesticides. 1987. For more information on contact your local Forest Service o?ice Revised November. 1992. This lnfomstion Pto?le is based on the Pesticide Fae: Sheet" developed by Information Ventures. Inc., under USDA Forest Service Contract Number 53-3187-104. Mag.2? 1993 PES info clarified The recent article published in the South County Courier on May 25th titled "Roadside spraying prompts warning issued by contained several incorrect and high in?ammatory statements regarding Roundup herbicide made by Monsanto. Your readers deserve to know the facts about this product. Roundup is known throughout the world for its favorable environmental characteristics, such as its ability to degrade into naturally occurring elements such as carbon dioxide and its low toxicity. in fact, another giyphosate (the active ingredient in Roundup) herbicide formulation-- Rodeo-4s used by conservation groups and ecologists to control invasive plants and restore fragile native habitat in delicate ecosystems such as estuaries and wetlands. Roundup has been in the marketplace forl 19 years and contains one of the largest databases in the world, with over 400 studies regarding health and environmental effects. This comprehensive database was reviewed by the US. Environmental Protection Agency (EPA) when it classified the active ingredient in Roundup and Rodeo herbicides, as Category E, or 'non- cancer causing to humans?. The other categories used by the EPA in assessing evidence or carcinogenicity are A through with being the most favorable. The surfactant in Roundup also has been extensively tested and is the same soapy substance found in shampoos. The trace constituent mentioned in your article, i, 4- dioxane, is present in about 35,000 household products including cosmetics, shampoos and soaps. it also occurs naturally in tomatoes and shell?sh. This constituent is not a human carcinogen and is not a cause for concern. in the case of Roundup, an improved manufacturing process has reduced the level of t, 4-dioxane to a non- detectabie status in the formulation. p-?T Roadside spraying is not just intended to keep drainage ditches free of weeds, as stated in the article, but is also designed to improve the flow of surface water off the pavement and reduce vegetation that may impede visibility and contribute to the potential for tires from vehicle exhaust systems. Roadside spr?aying also keeps rootbound weeds from damaging pavement, which costs taxpayers money, and it aids in reducing the amount of time workers spend doing maintenance along our highways, where physical injuries can result from mowing and vehicles. Studies have shown that mowing can destroy animal and bird nests, and in some cases actually harm wildlife habitat. it is true that Roundup cannot be applied to plants in standing water; however Rodeo has an aquatic approval from the EPA and is used to control undesirable vegetation in wet ditches and around bridges. Both Roundup and Rodeo were tested prior to being registered for this kind of use, and those tests took place over an 8 to to year period. Re-testing continues after a product is registered, so that effectiveness and safety considerations are constantly being assessed. The last piece of misinformation that i want to address is that the surfactant in Roundup is used as a spermicide. This false statement alone is enough to make your readers question the validity of all the other statements in the article provided by the LCWW. The misinformation contained in this article does your readers a disservice. in the future, i would strongly suggest that you verify the information that this group provides you with several other credible sources. if i can help you with questions about our products, or recommendations for credible sources, please give me a call. George H. Heywood Corvallis 59:41?14 Conant-7 Iona; Responds i read with interest the letter of Monsanto Company's George H. Heywood, which you ran on June 8, 1993. Mr. Hewood expounded at length on the safety and virtues of Monsanto products Roundup and Rodeo and claimed that an article by LCWW inaccurately described the hazards of Roundup. Why Monsanto Company would hire a spokesman, a person so abysmaily ignorant of Monsanto's own research and other scientific studies on Roundup is a question only Monsanto can answer. Mr. Heywood, for example, claims that the surfactant added to Roundup is not a spermicide. As reported in The Journal of Toxicology and Applied Pharmacology and elsewhere, the surfactant in Roundup, POEA, is one of a class of chemicals developed as spem?ricidai agents. Monsanto's own rabbit study conducted at industrial?s Bio-Test Laboratories showed that one of Roundup?s more severe effects was atrOphy of the testes. if the poor little bunnies' scrotums were falling off, i would view that as a effect. if Mr. Heywood would like to 3 conceive children without testes he . . is welcome to make the attempt, but I dur families should not be used as Monsanto ?3 experimental animals. Presumably, Monsanto paid industrial Bio-Test Laboratories precisely so it would not have to use human beings as test subjects. Monsanto's studies done at also found giant motif-nucleated cells in the testes of rabbits exposed to Roundup, suggesting a hazard of birth defects, mutations - and cancer. Mr. Heywood may be comfortable with the prospect of giant, multi-nucleated cells in his own testes, but roadside residents June 15, 1993 - South County Courier Page 9 subjected to the same risk without their knowledge or consent might not be so sanguine. if Mr. Heywood is concerned about LCWW's credible sources' for its information on P054, he might start by reading Monsanto's own Material Safety Data sheet on Roundup, which warns workers handling Roundup that the product contains POEA, identified by OSHA as hazardous chemical. Roundup is so 'safe' that it has become a popular means of suicide in Japan. Roundup suicides have enabled Japanese doctors to determine that a lethal dose for an adult human is less than 210 milliliters and that the Roundup surfactant POEA is the primary cause of toxicity. Mr. Heywood's statements about the 1,4-dioxane contaminant of Roundup apparently came from the same fictional source as his pronouncements on POEA. Mr. Heywood proclaims categorically that 1,4-dioxane does not cause cancer. The international Agency for Research on Cancer has unequivocally classified 1,4-dioxane as a cancer causing agent in animals. it has not been classified as a human carcinogen only because no human experiments have been done. Would Mr. Heywood be willing to volunteer as an experimental test subject, or does he prefer instead to use our children as the guinea pigs for this known cancer causing materials? Mr. Heywood says that Monsanto has found no detectable levels of 1,4-dioxane in Roundup. Mr. Heywood might be better informed if he read the experimental data that Monsanto submitted to the us. Forest Service, showing that Monsanto has in fact detected 23 parts per million 1,4-dioxane in Roundup. Mr. Heywood's statement that 1,4-dioxane is found in 35,000 consumer products suggests that Monsanto is enjoying a healthy profit from exposing all of us to this - known carcinogen from so many different sources. Adding the 1,4- dicxane in Roundup to mess 35,000 exposures is 'not a cause for concern" to Mr. Heywood, but people involuntarily subjected to Roundup exposure may not share his indifference. Understandabiy, Mr. Heywood prefers to talk about other Monsanto herbicides, such as Rodeo, which does not contain POEA or 1,4- dioxane. But Roundup-mot Rodeo-- which is what the state intends to use on our roadsides. Before we expose our children, ourselves and our environment to Roundup, perhaps we should all read the precautions on Monsanto's Material Safety Data Sheet for Roundup: 'Keep out of reach of children. Warningi Causes substantial but temporary injury. Harmful if not get in eyes or breathe spray mist or get in or on clothing. Wear goggles, face shield or safety glasses. Wash thoroughly with soap and water after handling. Remove contaminated clothing and wash before reuse. Do not apply directly to water, to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment surfactant component (POEA) of Roundup herbicide is reported to cause irritation to the eyes and skin and may contribute to the irritation potential reported for this herbicide. ingestion may produce gastrointestinal irritation, nausea, vomiting and diarrhea.? Mr. Heywood's "credible sources? for information about Roundup apparently do not include his own employer, Monsanto Company--the same bastion of corporate responsibility that gave us Agent Orange, PCB's and dioxin. if Mr. Heywood wishes to challenge the credibility of others, he should do his homework ?rst. Carol Van Strum Five Rivera Roundup, Vision, POEA. and 1.4-Dioxane: Why Full Formulations Are the Problem By Mary O?Brien When a letter by four Japanese emergency medicine professionals appeared in the February 6. 1988 issue of the American medical joure rial. The a Washington tox- icology consultant. David Monroe. took note. The Japanese authors were noting that an ?inert ingre- dient? in the herbicide formulation Roundup [rather than the identified ?active" ingredient. ac- counts fer the acute toxicity they had found in patients poisoned [some fatally) by Roundup included gastrointestinal pain and vomiting. swelling of the lungs arid pneumonia. reduction of blood pressure. clouding of con- sciousness. and red blood cell destruction. The so-called "inert ingredient.? polyoxyethyleneamine actu- ally refers to a family of chemicals.2 It is added to Roundup and Vision her- bicide formulations as a surfactant. an ingredient that will help evenly spread the active ingredient. on target plants. The Japanese rasearchers noted that the acute lethal dose of POEA is less than one-third POEA is three times as taxicl that of Roundup, and that POEA beloags to a class of surfactants that have been reported to cause adverse gastrointestinal and central nervous system effects and damage to red blood cells. Mm): O?Brien is staff scientist for the Northwest Coalition for Alternatives to Pesticides land editor of the journal of Pesticide Reform. formo may be reached c/o General Delivery; Prince Rupert. British Columbia iVAj (604) 624-5611. David Monroe may be reached at BO. Box 309; Stanwood. WA 98292; {206) 387?6987. 14- As POEA does not appear on the Roundup label [supposedly prov tested. as an inert. frOm public disclosure under the U.S. pesticide law. the Federal Insecticide. Fungi- cide and Rodenticide Act or FIFRAI. Monroe first learned of its presence in Roundup through theLoncet letter. ?The so-called ?inert ingredient?. . actually refers to a family of chemicals. Where There?s POEA. Here May Be 1.4-Dl0xarre Monroe recalled a U.S. Environ- mental Protection Agency memorandum that discussed the presence of 1.4?dioxane in turn poly- alkoxylated polyamine products (used in cosmetics and as an antistatic agent in textile treatments) manufac- tured by the Henkel ('Jorporation.a Knowing that PDEA is a pclyalkoxy- lated amine. Monroe suspected that 1.4-dioxane might be present as a contaminant of POEA. The 1980 EPA memo notes that ?Like many polyethylene glycols. 1.4-dioxane. . .can produce toxic ef- fects in the kidney and liver (in humans)." The liver and kidney damage ?can occur regardless of the route of 1.4-dicxane exposure [inhala- tion. oral ingestion. andJOr skin ap- plicatlonl." Moreover. the memo noted that a National Cancer Institute bioassay had found that 1.4-dioxane induces hepatdcellular adenomas (kidney tu- mors) in female rats. squamous-cell carcinomas of the nasal turbinates (nasal cancer) in both sexes of the rats. and hepatocellular carcinomas (kidney cancer) in both sexes of mice tested. A 1982 EPA memo in Monroe's files . also discussed 1.4?dioxane as being present in dichloroethyl ether. The memo notes that the International Agency for Research on Cancer ,hadsreported in .1976 that 1.4-dioxane produces tumors of the liver and gall bladder in guinea pigs and that it is "active as a promoter? in a 2-stage mouse skin carcinogenici- ty study [increasing the incidence of skin tumors when applied after The IA RC indicates that evidence is ?Sufficient? to know that 1.4-dioxane' causes cancer in animals5 and 'the U.S. Environmental Protection Agen- cy regards 1.4-dioxane as a probable human carcinogen}i lasting Vision far 1.4-Dioxane Learning of Monroe?s concerns regarding the potential of POEA con- tamination by 1.4-dioxane. British Columbia researcher jorma Jyrk- kanen arranged for testing of Vision. an herbicide formulation marketed in Canpda by Monsanto. Vision. like Roundup. contains and POEA. A 250 ml sample of Vision was'volunteered by Kim Hayworth in silviculture at the Ministry of Forests Office in Terrace. BC. and shipped by a Fishery Officer via loomis to CAN- TEST laboratories in Vancouver for analysis.? The CANTEST labOIatory demoted- 350 parts per million {ppm} l.+diox? ane in Vision using a purge and trap method. Identification and quantita- tion 'were performed by gas chroma- tography and mass spectrography.B The 350 1.4-dioxanc in Vision is equivalent to 0.35 percent? The 1982. EPA memo regarding 1.4-di- oxalic had been prompted by concern that 11.4-dioxane had been found in ether at 0.42. percent and 0.55 percent. Under ?comments! recommendations? in the memo. the EPA noted that the manufacturer of OF PESTICIDE REFORM I VOL. 9. N0. 4 Correction: The 350 1.4-dioxane in Vision is equivalent to 0.035 percent. . 1v?lysio phat-t, hay-41??Aricl . W. the contaminated dichloroethyl ether ?reported that its employees and customers were being noti?ed of the presence of 1,4?dioxane in dichloro ethyl ether. In addition, the company reported that its current safety precautions include 'body-proteetive clothing and boots, protection, and ndonitormg of air levels of dichlorOethyl ether.? The Secrecy ofRoimdup and Vision Toxins . . Users of Roundup and Vision. are not lnfonned that the formulation contains either POEA or 1.4-dioxane. Roundup is widely used by home- owneref ?wearing no particular pro-' festive elothing. and the label merely . states. ?'Avoid Contact. with eyes. skin, and clothing because of possible [eye and skin] irritation." The presence of 1,4?dioxnne in Vi- sion {and presumably in Roundup} is a classie example of the following: 1. Full fermulations, ?inert" ingre- dients, contaminants, not merely the so-ealled "active" ingredient. can cause cineer and other adverse chron- ic effeetsi their tamingiroa'ea. . ing for chronic toxicity is indefensible. 2. The current classification by the EPA of POEA as a "List 3" inert in- gredient, (?inert of unknovm toxi- city"), Subject neither to listing on the label nor toxicological testing re- quirements. is indefensible. .. Estimating the toxicity of gly- phosate alone is meaningless when a full formulation: Roundup. Vi- sion) containing POEA, 1,4?dioxane. and other unlisted ingredients and contaminants is the mixture to which peeple and' the environment will be exposed; . . . What you don't know can hurt you. References 1. Seweda. Yusuke.? Yoshikazu Nagai, Marathi Ucyarno, end Isotoshi Yam:- moto. 1968. Probable to?city of surface- ective agent in commercial herbicide containing . The 'Lancet 1 [85801:299. 2. November 11. 1989 letter from "Joanna. Curtis, Canadian Centre for Occupatiogal Health and Safety. to Jorma 3. Memorandum from Frank Rover, Chief, Chemical Hazard Identi?cation Branch, . Environmental Protection Agency. Merenda. Director. Assessment Division, regarding Status Report BEHQ-0230-03315 Ind 03365.]uly21.1980. - _Iuternationel Agency for Research on . Cancer, World Health Organization..1976. mnosmphe on the evaluation of ear- .- cinogenie risks to humans 11:247-256. - international Agency for Research on Cancer. Werld?liealth Organlration. 1982. monographs on the evaluation of the carcinogenic risk of chemicals to humans. ?Minimal 4. -- - - . 5. Environmental 'Proleetion Agency. . - 1936. Methodology for evaluating poten- till mchogenicity in support of report- able qulntity adjustments pursuant to - Chitin-A Section 102 [draft]. A64.- Cited in Canadian Centre for Hanoi health and Safety Hazardous '51; tonnes Datebook printout {1989}. . . . Joann. 5, 1989. New concern: about potential contention- tion of forestry herbicide Vision by the probable human and con?rmed animal carcinogen Ind liver and kidney twin. Lit-dime. Unpublished paper. '7 a. Ltd. October 5. 1989.1mended October 10. 1939. Analysis of liquid elm.- ple for volatile organics. File no. 8490K: Suite 200; 1523 West 3rd Ave. Vancouver. BC 118. 9. Monsanto Cempeny. 1980. Technical bulletin for itemur?lln?1 herbicide. JOURNALOF emotion REFORM 1 WINTER 1990 . 15 Monsanto uouemto AGRIBULTUML 2130 Professional Dr.. I200 Rosavi?e, CA 95661-3399 Specialty Crops - (918) 784-7768 Industrial 8. Greens - Fax Number - [916) 784-1878 February 26, 1991 Kay Rumsey C1474- {h?uu Salami Didrr?d; LET . 86310 N. Modesto aim 717W Was-13 We): Eugene, OR 97402 Dear Ms. Rumsey: Thank you for your inquiry concerning the ingredients in our Roundup? Herbicide. I would-like to reiterate my comments during our'telephone conversation, and provide some additional information concerning the product, its ingredients, and the trace contaminant that you asked about. Roundup herbicide is composed of the "active" ingredient, (formulated as the isopropylamine salt to aid in . solubility), and surfactant (POEA: polyoxyethylene amine), and water. Roundup is perhaps the simplest formulation of herbicide on the market that requires no other additives or special mixing. It is mixed and sprayed in water, and the equipment is cleaned with water. When Roundup is sprayed onto the undesirable vegetation, the surfactant helps to penetrate the waxy layer on the leaves. Without the surfactant, the spray would run off the vegetation and the weeds would not be controlled. Once the spray dries, the Roundup is held to the leaves, and slowly moves throughout the plant to the actively?growing points, where it disrupts several of the plant's metabolic pathways. It has no effects on animal metabolism at levels of use anywhere near comparable to normal weed control applications. - If Roundup is sprayed on the soil or drops from the foliage to the soil, it is bound very by the electrical charges on the soil particles. It is then inactive and will not be taken up by plant roots, nor will it leach into groundwater. The microbes in the soil metabolize the product, with the final . . release as carbon-dioxide and water. This process is rapid, with a half-life of approximately 45-60 days, depending mainly upon temperature. I'll describe each of the components of Roundup in greater detail: composed of the simplest of the amino acids (glycine), a phosphonate group made up of phosphorous and oxygens, and a methyl group of carbon and?hydrogens, this is a very simple molecule that breaks down rapidly. All of the a unit 0! Monsanto Company components are easily metabolized and utilized in the growth of bacteria and fungi. It would not be expected to last long in soil, and in fact does not. While it is in residence in the soil, it is tied up so that it is biologically inactiVe. is active in several pathways, but not in animal metabolism." i Surfactant: the ?surface active agent" (surfactant) in Roundup is a polyethoxylated tallow amine, one of many members of a class of chemistry called polyoxyethylene amines (POEA). There are literally hundreds of these kinds of surfactants, many of which are used in agricultural products, cosmetics, and other areas. They are plentiful, inexpensive, have a wide variety of uses, and do not pose significant toxicological concerns at the rates used in these products. . we are often accused of having "secret" ingredients. The only thing we prefer to protect are the trade names, suppliers and prices we pay for any of our ingredients. Knowing these, our competitors in the marketplace would have a much easier time duplicating our products and perhaps taking some of our business. We prefer to maintain the names and prices as "trade secret". Any other information is available, and has been supplied to State and Federal authorities, as well as to anyone who asked for it, for some years. In fact, if considerable information on safety, toxicity, and environmental fate of any product was not made available, the authorities would not allow its sale and use. The procedure for registration of these products is complex, and strict, and serves to protect the consumer as well asithe proprietary nature of the business. The surfactant in Roundup was found to have a contaminant called 1,4?dioxane approximately ten years ago (take care to not confuse 1,4?dioxane, with "dioxin", an entirely different chemistry of much greater toxicity. There is no dioxin in Roundup). The levels of contaminant in the surfactant were low, and when formulated into Roundup herbicide were considerably diluted. When Roundup is mixed and sprayed, it is diluted once again. The Federal EPA and State agencies were advised of the contaminant, and it was concluded that the level of 1,4-dioxane did not pose a hazard. Since this was the case, we took no further action at that time. More recently, inquiries such as yours have suggested concern about the presence of any possible risk, and we have directed our suppliers to eliminate 1,4-dioxane from the raw material they provide to us. Their production technology has sucbessfully reduced levels to those below any reasonable consideration of risk. For example, the EPA level of risk of canoer being "insignificant" is one in one million. A recent analysis of l,4~dioxane at levels hundreds of times higher than what is present in a Roundup spray solution show that the risks to applicators is literally thousands of times less than "insignificant", even to mixers and applicators, (those at greatest calculations are generally made on a "worst? case" basis. Once the spray operation is complete, the risk to passers?by (in your case, the school children) becomes lower still, as the contaminant is degraded and no longer present on vegetation. These risk assessments were made assuming that applicators worked continuously, spraying high rates of dup. It is unlikely that a school maintenance worker would even a hundredth of the amount used in the calculations. Clearly, the maximum possible exposure of a child to 1,4- ?1oxane from such spraying is very small and provides an almost .4fincalculable low risk. 'l The toxicology of 1,4-dioxane is such that at is not considered by any regulatory authority to be of significant It is present in mere than 35,000 other products that contain surfactants, including cosmetics used directly on the skin, and is allowed to be present even in foods at levels much higher than those that occurred in Roundup spray solutions in past years. I beg that you not be concerned with this material. It is not present in significant quantities in Roundup. . The nature of any concentrated surfactant is such that care muSt be taken in its use. Surfactants by their very chemistry are harmful to delicate membranes such as those around the eyes and in the respiratory system. The effect of the surfactant is that it degrades fatty and waxy tissues. The result may be irritation and breakdown of the tissue itself. That is why we recommend the use of gloves and goggles when mixing any agricultural products, regardless of the toxicity of the actiVe ingredient. Most such products contain a surfactant, or a surfactant may be added during mixing of the spray solution. Generally, the effects of surfactants become less when they are diluted to the used in spray solutions, and.after the spray has dried on the weed foliage, they degrade relatively quickly. They should not pose a problem to anyone in the vicinity of a recent spray. Specific to the surfactant in Roundup herbicide, the POEA breaks down rapidly, again by microflora, does not accumulate, and is of such low toxicity that it is well below levels of concern even at the highest rates recommended for use. We have performed toxicity tests on the surfactant as well as with Roundup herbicide, and regulatory officials agree that there is no undue risk in its use. In fact, when tested for skin irritation against some common household products, Roundup was found to be somewhat less-irritating than baby shampoo. Here again, any degree of risk associated with the surfactant would fall primarily to those doing the mixing, loading of equipment, and spraying the material, and as we discussed earlier, the use of common?sense safety practices brings any such risk to nearly nil. You mentioned that you have received information that the "inert" ingredients in Roundup are more toxic than the "active" ingredient, That is,a reasonable statement; given theivery low toxicity of few materials are less tax 0. i We have chosen the POEA surfactant to be the "inert" ingredient in Roundup because we want our product to provide the best possible weed control for our customers. We have for many years tried to find surfactants that provided better performance and have been unable to do so. Roundup is the premier product for the uses for which it is intended. Properly used, it provides minimal risk to the user, to bystanders and passers-by, or to anyone who may enter the area after the spray operation is complete. All of this is documented, with data on file with appropriate authority, all of it is available for inspection by anyone, and all of it has been inspected repeatedly by competent technical eXperts. - We'have offered repeatedly to discuss our products with anyone having genuine_concerns.? The opportunity to do so is . appreciated, and in those cases where, as in your situation, the interest is sincere, we generally find receptivity to our data and our positions. Where there is no sincerity and the concern is not genuine, I become wary of a secondary agenda that no amount cf science will address. I beg you to consider the sources of your information carefully, myself included, and to act on facts rather than emotion and fear. . 2 You are aware of the medical reports of human injury due to intentional ingestion of Roundup, and I assure you that we.find these situations regrettable. Certainly it is possible to cause human injury with Roundup herbicide, but clearly you understand that it is only under the most extreme and deliberate misuse that such injury occurs. There are no such reports of injury caused by proper use of Roundup herbicide. . Roundup has been used in agricultural, industrial, landscape - beautification, and maintenance programs for nearly twenty years. We have completed all of the testing required by regulatory agencies throughout the world, and have gone beyond that to providing one of the most complete data bases on safety and' environmental_fate that exists today. These tests are supported by nnumerable University trials, and the entire toxicology pac age has been reviewed by independent panels of_noted scientists. All agree that Roundup and its related products are among the safest materials available for their intended uses, and that risks from their use are negligible. . All of our safety and environmental fate data are available for scrutiny. We are quite proud of the science behind Roundup, and appreciate the opportunities to discuss it. 3 The concerns you expressed.about the use of Roundup in your school system are appropriate, and I thank you for your' . willingness to obtain-additional information before making your recommendation. I hope my remarks have been helpful. If I may be of further service, please do not hesitate to contact me. If you'wish, I would be pleased to visit with you and your committee at your convenience to discuss this further. Sincerely, .r?xg? Dr. Jon H, Arvik Manager, Environmental Affairs Monsanto . ENVIRONMENTAL FATE OF THE TALLUH AHINE SURFACTANI THENIY ETHYLENE OXIDE UNITS 1 I In order to ascertain the environmental fate of the polyethoxylated tallow amine surfactants as utilized in the Visionm and Roundup formulations, [Monsanto has conducted a series of biodegradation, plant uptake, and C-distribution studies. this surfactant comprises 15% ?of the Vision ?*and Roundup' herbicide formulations. golscussmu: .-- The polyethoxylated tallow amine surfactant was biodegraded rapidly _by the _microflora present in three representative soil types (Spinks sandy loam, Ray silt loam, and Drummer silty clay loam). Little or no degradation occurred under sterile conditions. The degradation under non-sterile conditions was extensive, 2d-31% 1?00; in seven weeks, from all three soil ;types. The continued evolution of substantial ?4002 even after two weeks ?incubation is considered an indication that intermediate "glycolate" or ?"glycerate" metabolites are formed and directly incorporated into the 'microflora thus the 1 C02 output is a measure of the complete metabolism of tagged natural product pools. Sterile shake flasks experiments showed considerable solubilization in water after 7 days. the detectable half life of the polyethoxylated tallow amine surfactant with 20 ethylene oxide units in the shake flask system is less than one week, and may be as: '.short as 1? 2 days. Corn and soybean plants grown -in soil treated with 14lit-labelled surfactant 'showed 10a?c content (0.04-0.3310f applied C), levels _cf comparable Emagnitude to control. plants grown nearby that could only become labelled ?by soil microfloral degradation of the surfactant to and refixation. lhe plants grown in the 1dC-labelled surfactant treated soils :showed a consistent pattern: (1) a natural product spread very similar to ?tha control plants, (2) no detectable chlorof'Orm soluble u?C activity labove that of the controls. Detailed natural product chromatographic ,schemes have been applied to the treated and control plants' and .{demonstrated similar patterns. the basic fractions from the natural 'product fractionation have been purified on DEAE cellulose and -corresponded_ to control plant patterns. The.initial acidic fractions have also shown further detailed chromatographic similarities. Extraction and chromatographic data clearly indicated that no more than 5% of the maximum 33% C-activity taken up by the plants could be starting surfactant, and that less than 1% of the 0. 33% is more likely the maxim 1 ?activity attributable to unchanged Surfactant. - mm? .1. - - .eForoarProre-c?on Prodocrs? In . 2 "Ihe polyethoxylated talluw amine surfactant appeared to? be totally degraded in soil and greater than 95% and possibly more than 995 of t?e?C found in plants grown in soil containing the carbon~la labelled surfactant was attributable to natural products based on chromatographic and extraction. data. it was concluded that no detectable residues or the surfactant will develop in crops treated pro-plant or in crops following post?harvest treatment with this polyethoxylated.tallow amine surfactant containing formulation. Aquatic degradation of 0.05 and 0.1 concentrations of the surfactant was also examined under aerobic conditions at in the dark under both non-sterile and sterile (Hillipore filtration) canditions in three natural water types (lake-pH 4.6; pond-pH 7.4; river-pH 7.8). the metabolic fate of the surfactant was monitored weekly by measuring released [lg Considerable evolution was observed in non~sterile natural waters. ?Sterilization -of these natural waters by Hillipore filtration drastically reduced the rate of i?coz release. thus. sterile natural waters containing the1?Celabelled sorfactant released only 0-0.273 of the applied ?4c?eetivlty as ?4002 over a two week period, while the non-sterile waters released 7:4 to 15.3% of the applied -activity i as 802 in the same time period. These data verify that 1?802, the major metabolite of this polyethoxylatad tallow amine surfactant is.generated . microbially as previously foUnd in'the aerobic soil studies. . The results of aerobic dissipation of 14C-sucrose plus the surfactant and 1 ?sucrose in natural water demonstrated that the microflora of the employed natural waters was active under the conditions of these studies ?and that the surfactant had no adverse effect on the microflora. Aquatic {degradation of C-sucrose and plus surfactant generated 50 to er the applied ee? 02 over 7 weeks. The initial burst ?of 1?00? followed by a sharp reduction in 14C02 output is typical eof 4C?sucrose microbial degradation. These findings are in agreement "with the results reported in the soil degradation study of the surfactant. Shith regard to the rate of dissipation. the most rapid degradation 'occurred in lake water, pH 4.6, with 52% and 47% of the Surfactant EmetaboliZed to Ozrover 14 weeks. Pond water, pH 7.4, and river water. pH? 7.8, displayed a slower C02 evolution rate with accumulation of 38 to 405 1?CUzin 14 weeks. The maximum half-life of the polyethoxylated tellow ?amine surfactant in all three natural waters was estimated to be 3?4 weeks based an anion texchange chromatography. However, further-examination of the surfactant fraction (isolated from the anion exchange chromatography) . by high voltage electrophoreses analysis indicated that this fraction contained additional acidic metabolites. Based on this data, the actual half-life of the dissipation of the surfactant is probably considerably lees than 3-9 weeks. The total recovery of applied ht-activity after 14 weeks aerobic incubation. ranged from 88 to 99%. As part of this overall accountability, .36 to 52% of the applied1?t was released as?4802, 7 to 29% has .bound to'natural water sediments, removed by filtration.I and 21 remained soluble in the filtrate. Less than 10% of initial 1?Ceactivity? after 7 weeks incubation, and only 2 to 6% after it weeks was identified as the unchanged surfactant by anion exchange chromatography. -3- For the aquatic fate studies in natural waters separation by anion exchange chromatography indicated acidic 14C-metabolite's and 2-6% of unchanged surfactant after 14 weeks incubation. However, further examination by high voltage electrophoresis of the isolated fraction revealed acidic material co-eluting with the surfactant during anion exchange chromatography. The metabolite fractions (isolated by anion exchange chromatography) were further analyzed by high voltage electrophoresis and identified by their electrophoretic behavior as carboxylic acids. Cassidy and Hire (3.. Chromatogr., 82 (1976), 737-794) have also investigated .polyoxyethylated surfactants and identified mixtures.of carboxylic acids as their decomposition products. Carbon diOxide, the major degradatiOn product (38-52%) was identified by release from Ascarite traps and ra-trapping as phenethylamine garbonate/carbamate, which imposes a fair degree of specificity that the measured as 002. . "it? regard to the concern expressed for the tendency of the POlyEthoxrl?ted tallou amine Surfactants to ?form N?nitrosoamines under agronomic or forestry use conditions, this tendency is considered remote b858d upon; (1) the previously completed environmental fate. studies canducted with these surfactants, (2) the fact that the bees amine structure is tertiary, as well as, (3)-the extensive amount of data which has been acquired by Monsanto in addressing the potential for the formation of in the use of the Roundup. formulation. In the latter C886. extensive residue and metabolism investigations conducted by Monsanto which included; (1) formulation analysis, (2) crop metabolism and animal metabolism studies. (3) field applicator exposure 8tUdi63. (4) residue analysis of field?grown_crops from preplant and post-directed uses of Roundup? herbicide have demonstrated that was not a detected metabolite of in any of these investigations. - . The absence of residues in these studies which would have ?involved formation from the secondary amino zwitter ionic compOund, in the environment indirectly supports the suggestion that the potential. for the formation of Nsnitrosoamine derivatives of the polyethoxylated tallow amine surfactants,-a tertiary amine structure, in the environment should not be a major concern. Based upon the results of these environmental fate studies with the polyethoxylated tallow amine surfactant, the use of this?material in the application of Vision 7? or Roundup-herbicides should not pose a risk to _the environment. Vision is a trademark of Monsanto Company. Roundup is a registered trademark of Honsanto Company. - Forest Protection Products J. Sixth Annual Fleport Ion. Carcinogenq Summary 1991 - US. DEPARTMENT OF -- HEALTH AND HUMAN SERVICES . Publlc Health Ser?vlce Prepared for the NATIONAL INSTITUTE OF ENVIRONMENTAL HEALTH SCIENCES Research Trlangle Park. NC 2??09 By Technical Resources. Inc. Floclwille, MD 2085?. Under Contract Number N01 ES 3 5025 CONTENTS Introduction Substahou or groups ot substances, and medical treatmonta that are known to no carcinogenio.* Allatoxlns 4-Amln0biphenyl Analgesic Mixtures Containing Phonacetin Arsenic and Certain Arsenic Compounds Asbestos Azathioprlne - Benzene Benzidlne and Technical-Grade Chloromethyl Methyl Ether 1 .4-Buianodiol Dlmeihyiaulfonato (Myloran) Chlorarnbuclt 1~nitroaouraa Chromium and Certain Chromium Compounds Conlugatod Estrogens Cyclophoaphamldo Erlonlto Malphalan Mathoxoalon with Uttravloloi A Therapy (PUVA) Mustard Goo 2-Naphihylarnlna Thorlum'Dloxido Chlorlda Substances or groups of and medical ttoatmonto which may reasonably be anticipated to he carolnogona." Aoataldahydo 2-Acaiyiamlno?uorena Aowlamlda Page 74 79 Aorylonitriie Adriamyoin . z-Amlnoamhraqwnone o-Aminoazotoluene 1 ?Amino-2-meihylanthraquinone Amlirole Hydrochloride BenzolriChloride Beryllium and Certain Beryllium Compounds Biaohioroeihyl Nlirosouree Bromodlohloromeihane 1,3-Butadlene Buiylaied Hydroxyanieole Cadmium and Certain Cadmium Compounds Carbon Tetrachlorlde Chlorendio acid . Chlorinated Parallins (C12. 60% Chlorine) (CCNU) Chieroiorm 4-Chlorovo-phenylenediamine C.l. Basic Hod 9 Monohyoroohlorlde Cleplalln p-Creeldine Cuplerron . Daoarbazlno DDT . 2.4-Dlamlnoanlsole Sullale 2.4-Dlamlnoioluene 1.2-leromoeihano (EDB) 1,4-Dlohiorohonzene and Dihydrochloride 1,2-Dlohloroe1hanl Dichloromeihohe (Methylene Chloride] (Technical Grade) Dlepoxybuiane Dita-aihylhexyliphlhalate Dleihyl Sullale Ether 3,3'4nlmoihoxybenzidine and 4aDlmetnylamlnoazobenzeno 104 105 108 111 114 120 124 125 128 129 132 134 135 137 133 1:39 141 142 144 146 149 151 156 159 162 165 163 171 172 177 179 180 182 Chloride 1 Dlnjalhyl Sullale Chloride 1,4?Dioxane Direct Black 38 Dlract Blue 6 Estrogens (Not Ceniugated): Eelradlol-l 7 Estrogens (Not Coniugated): Estrone Estrogens (Not Coniugated): Ethinylestradlol Estregene (Not Coniugatad): Mestranol Ethyl Acrylate Ethylene Oxide Ethylene Thlourea Ethyl Methanesultonate Formaldehyde (Gas) Hexachtorobenzene Hydrazlne and Hydrazine Sultate Hydrazonhnzene Iron Dextran Complex Reported]: (Chlorducond) Lead Acetate and Lead Fhoephete Lindane and Other Hexechtorocyctohexane learners (Propylenelmlne) (2-chloroaniline) (MECCA) 4-d?-Methylenebls (N,NadlmethyIJbenzenemlne and its Dihydrochloride Methyl Methaneaullonate Metronldazdle Ketone erex Nickel and Certain Nlckel Compounds Acid Nltroten Nitrogen Mustard Hydrochloride Z-Nllropropane -- N-Nitr030di-n-bulylamine N-Nitrosadlethanolamlne 134 136 187 189 191 192 195 197 200 202 204 208 208 210 212 218 221 222 228 230 - 232 285 237 238 240 242 245 247 250 25269 272 273 275 2.78 231 N?N?rosodlethylamlna --282 N-N?rosodlmelhylamlne 236 290 N-N?mso?N-ethyluroa 291 4-(NaNitroso methylarnino)-1 293 N-thso-N-malhylurea 294 297 N-N?rosomorpholine 298 N-N?rosanarnlootina 300 N-N?msoplperldine . 302 N-N?rosopyrrolldine .. 304 N4Nitrososarcoslne 305 Noralhtatarone 307 Ochratoxln A 309 4.4%0xydlanllina 31 1 Oxymelholone 312 Phenacetln 314 Phenazopyridine Hydrochloride 316 Phenoxybenzamlna Hydrochloride 317 Phenytoln 3.19 Polybrominaled Blphenyls 321 Blphenyls 323 Ammatlc Hydrocarbons. 15 Listings 327 Benzlalanthracano Benzolbj?uoranihene Bomotmluoramhene Benzolk?luofanthena Banzalalpyrene leenzlamlacrldina leanztaMacddine leenzla,h anthracana 7H-leenzolc.alcarbazole lesnzolampyrana Dibenzolaleyrane . Precamazlna Hydrochloride 334 aas 1.3?Propano Sunona 339 vi B-Propiolactone Propylene Oxide 343 Propylihiouracil 346 Reserpine 348 Saccharln 351 Sairole 354 Selenium 355 Silica. (Respirabla) 357 Quartz Cristoballte Sireptozolocln 364 Sullallalo 366 (TCDD) 367 Tetrachluroelhylene (Percmoruelhylene) 371 Thioacelamide 374 Thiourea 37a Toluene .Diisocyanate . 37a o-Toiuidlne and o-Toluidine Hydrochloride 332 Taxaphene 335 2.4.6-Trichloraphenol 337 Sul?de 339 391 Urethane . 393 Occupational exposures with a technological process that are known to be carclnoqanlc. Coke Oven Emission: 397 Scots. Tara. and Mineral Oils 399 Helerencea 4'12 Acronyms and Abbreviatluns 456 unite oi Meaauromunt 460 Dellated cnemlcals 431 For the purpose of this Report. "known ru?trninqgenl? de?ned the evadencelrpm human silldies indicate: that Ihnra in a neutral to the substance and human cancer. as thew substances for relationship expulure #b For the purpose 0! this Report substances 'which an . . . romanably be arms: at to a carcinogen: are de?ned as these for which rhare'it at limited evidence all Madgegenl?sw humane or sufficient evidence ul carcinogenicity In experimental animals. I vii INTRODUCTION Cancer is the second most common cause of death in the United States. One in every tour Americans will suiter trom cancer sometime during their one in every live will die from cancer. In 1984. more than 450.000 Americans died oi cancer 198.6). in addition to the physical and emotional eutiering caused by cancer. this disease may cost the Nation as much as $39 billion each year in lost production and income. medical expenses. and research resources. For these reasons. the American public is ooncemed about cancer and cancer hazards. especially about ways to prevent the occurrence or decrease the incidence oi cancers. Contrary to popular belief. cancer is not one but many diseases which may have dillerent causes. Many scientists believe that irom one-third to two-thirds of all cancers may be associated with the environment in which we live and? work. in this context. the environment is understood as "anything that interacts with humans, including substances eaten. drunk. and smoked: natural and medical radiation: workplace exposures: drugs: aspects ol sexual behavior: and substances in air. water. and soil (OTA. 1981)." Somercuiturat and behavioral patterns. apart from delined habits ol smoking and alcohol consumption. may signi?cantly inttuence the development oi tumors in the gastrointestinal tract. breast. uterus. and prostate. These aspects ol social environment. personal behavior. and habits are sometimes called "litestyie." Although we rarely know the environmental iactors and conditions which are responsible tor the development ol specitic cancers. in some cases we are beginning to have some understanding. For example. we now know that the way loads are prepared and cooked. or new they are stored and preserved. can greatly sheet the incidence oi cancers in any population. It is the hope oi many scientists in these iields that much oi the cancer associated with the environment may be avoidable perhaps by some changes in "lifestyle." Development of cancer also depends on "host iactors." Host iactors are attributes at human organisms associated with individual dillerences in the risk cl developing a speci?ed cancer. A host tactor may be associated with reduced tlsit at a cancer. not only with increased risk (Cole. 1932). Examples oi host iactors are Immunological and endocrine lunclicns. status. genetic age. and sex. all oi which can interact with one another and with the way the host handles the carcinogen how the 'host absorbs. distributes or stereo. metabolites. and exercise the carcinogen (Benson 8- 198m. Americans. concerned with the relationships between their environment and cancer. have asked tor inlormetion about substances that cause or might cause cancen community Mental Health Extension Centers Act oi 1070. [Amendments] 1 9 . c3? I $635.: "2 N549 rd 0 .h V) - U: 3.5: - 3% ?54raceUI-r-seal 2 er? Pit m. i on .1133 . reg-?. arm his: ?3 Se 2; ii 5 33%- 3 tram? ?'E'ebi??ww #950 3 11? l' I $119: I. tr. 3.53 ng W54 BE ri?es Pl Helga: eug ?3023:3 3HJ. INTRODUCTION Cancer is the second most common cause of death in the United Statee. One in every lour Americans will'suller cancer sometime during their Iiietime: one in every We will die from cancer. In 1984. more than .450,000 Americans died oi cancer (NCHS. 1986). In addition to the and emotional sullering caused by cancer. this disease may cost the Nation as much as $39 billion each year in lost production and income. medical expenses,.and research resources. For these reasons. the American public la concerned about cancer and'cancer hazards. especially about ways to prevent the occurrence or decrease the incidence oi cancers. a . .147" ?It? Sawat'ia, Yusuke, Nagai, {4335513111 {jg-Yam! and Isotoshi Yamnoto. 1988. Probable toxicity of Surface Active Agent in commercial herbicide containing The Lancet. February 6. -. PRORABLE TOXICITY OF . . .- AGENT IN COALMERCIAL HERBICIDE CONTAINING herbidde?Roundup? his stunned much mention.? a replacement for plnqull. but it too it mic. 56 can of 10mm? were reported in japan betuem June. IBM. and Mirth. 1986. An analysis of the clinical ?ndings suggest: than it is the surface-sewn: agent POEM rather than 1mm ingredient of the herbidde (gimme) that mum toxicity. There were 24 "?115.24 retrial-:3. and 8 patients seat and the mean one was 47 years (n 43). 9 died. The mean mm! of roundup ingested was about 120 ml (104 ml non-fatal, 206 ml ?nal) 48 use: were attempted suicides and 3 Wu: accidents (all infants), in the other 5 the were unknown. The mm clinical ?ndings were: throat, abdominal pain, and vomiting were noted in almost all cases with haemorrhage and paralytic ileus in serious uses. Endoscopy (in 7 cases) revealed erosion of the phannx, oesophagus. and stomach. Some cases with no What examined in hospital later had hamlernesis and melacm that lasted several days. Necropsy of those Who died within 48 of ingesdon revealed erosion, neeroeis, and ham-mrrhage of the jejunum and ileum, and a large arm of mucous membrane extending [torn the ilomewm to the large intesune. Rerpr'ratmy?Pulmonary oedema (3 cases) and severe pneumonia (2). Cardmmadar.?Oligurie, smut-in, and hypotension in all fatal cases. and transimtly in the smivors too. Mainrmanor of blow pressure and urine output required Hussite infusions of ?uids. Carnal mum mtm.?Moderzte clouding of in some cases. mtylase and white cell count were inn-eased; case-s tested had I se'mm total bilimbin above 0 9 mg?dl and raised heme dehydrogenase actiw'ty. Hauntilysis probably explained these abnOrmaIitie-s. Serum electrolyte: were normal The clinical picture in acme roundup toxicity was thus one of hypovolsu'nie shock. lehosate inhibits an enzyme in the of aromatic amimacids in plants." Animals have di?'ermt shildnuc acid pathways and roundup has been assumed to be Safe, on the basis ofmimal toxicity experimmrs with sly-phonic. However, roundup also domain: was POEA. and our experience of toxicity with such surfacmu us to reassess the toxicity of roundup. The median lethal dose of POEA is less than one?third that of mundup and its naive Also. this class of surface acrive agents has been reported to cause gastrointestinal Ind and hamlysis.? indiating that it is the surface active ingredimt that causes the toxicity of this herbicide. Furthermore, 2 other patients, who ingested I surface active agent {shampoo and a spreading agent} developed hypovolaemia, generalised oedenu, pulmonary oedema. gastrointestinal stupor, and Munch-sis, and I af?rm: died The clinical picture in these 2 cases was strikingly similar to that in roundup-induced toxic reunions. ?i'USUitt-z Yosmmt; NAGAI Mm" Munster UEYAMA Kantian-?hi. mm. 890 1m I 501081-11 I. ("washed E. Ariana! The Pretend! [.13th9 Lee-idem Bu?m?u. IQS. 2 Same-richer: HC, Amman N. The herbicide is avian inhibitor 01' 5131919)th Burglar-n 8.1151 Ru (1mm 1mm: lien-I! Crubb TC. Did LC. Cher Sui-lit: an die toxicity dedeupcl Tor?'d?p? PW 1 4- B?hrm DA, 60mm Dtobedt HP, rt The tonic-rho I'll hick-bed [km of Lanteeh 9 fl bur-il cite-l. I new apart-wield agent Tuned ml. Pdn?-Hm-quw at. I. Camber.? dbl: ?rst: und whines-uni? Tauzju] hr. \?M'?hul T?mm Mt thit?afrl ml; mm 862.2 Ebi 2139 3H1