1965 internal document Dow Chemical
Subject: Fw: 1965 internal document Dow Chemical
Date: Fri, 8 Mar 2002 07:23:41 -0500
From: Stephen Tvedten <steve@getipm.com>
Organization: Get Set Inc. (www.getipm.com)
To: Paul Helliker <phelliker@cdpr.ca.gov>
Director, State of
California, Department of Pesticide Regulation
cc: Christine Whitman whitman.christine@epa.gov
Dear Mr. Helliker, I thought you might like to read the following:
For release and publication or web posting - Don Sarten New
Legible transcript of Dow Confidential Document originating
from
Received
Ross Milholland DOW CONFIDENTIAL
ManagerBioproducts
Dow Chemical of Canada DOW 747096
Sarnia Canada MM069799
2,4,5-TRICHLORPHENOL, THE "T" ACIDS, AND ASSOCIATED ALKALOIDS
I have not been neglecting your request for information to
use in discussing of the subject problem with
I have been stymied, however, because the analytical methods have been changed and are in the process of being cleared and reproduced. I expect them anyday, but rather than wait longer, I thought I should advise you of the situation. I will send you copies of these methods as soon as they become available.
In regard to the overall problems, we are attempting to do everything possible to avoid the possible occurrence of chloracne in any applications or handling involving the use of trichlorophenol, trichlorophenoxyacetic acid and its derivatives. As you well know, we had a serious situation in our operating plants because of contamination of 2,4,5,-trichlorophenol with impurities, the most active of which is 2,3,7,8,-tetrachlorodibenzodioxin. This material is exceptionally toxic; it has a tremendous potential for producing chloracne and systemic injury. If it is present in the trichlorophenol, it will be carried through into the T acid and into the esters and hence into formulations which are to be sold to the public. One of the things we want to avoid is the occurrence of any acne in consumers. I am particularly concerned here with persons using the material on a daily, repeated basis such as custom operators may use it. The whole 2,4,5-t industry would be hard hit and I would expect restrictive legislation, either barring the material or putting very rigid controls upon it. This is the main reason why we are so concerned that we clean up our own house from within, rather than having someone from without do it for us. In this way, we can approach the problem in an orderly manner. If the producers and handlers of this material will co-operate, there is no reason why we cannot get this problem under strict control and thereby hopefully avoid restrictive legislation; in other words, let us practice good citizenship. At the present time, we are of the opinion that material containing no tetra- chlorodibenzodioxin with a certainty of 1 ppm does not present an appreciable hazard to consumers; likewise, we do not believe that such material constitutes a significant hazard to persons working in plants handling such phenol, T acid, or T acid esters.
I might add that we are continuing our research on this particular problem from the standpoint of studying the other impurities which may have the capacity to produce this type of reaction. Also, we are attempting to quantitate the effects of the known acnagens when added to base materials. This work is progressing well, but it will be several months before we have a completed story.
I would urge again that if your big customers such as Co-Op
and
I trust you will be very judicious in your use of this information. It could be quite embarrassing if it were misinterpreted or misused.
V.K. Rowe
Biochemical Research Laboratory
1701 Building
DX 6-2376
VKR/jd
cc: L. Silverstien
C. Otis
Grady Holdeman
F. Asstuzz
G. Goergoa
M. Moyle
Y. Falsey
V. K. Rowe (2)
T17 .
correspondence
P.S. Under no circumstances may this letter be reproduced, shown, or sent to anyone outside of Dow.
VKR
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