DOW CONFIDENTIAL DOCUMENT 1965

March 8, 2002

For release and publication or web posting - Don Sarten New Zealand

Legible transcript of Dow Confidential Document originating from Sarnia

Canada.

Received

June 24, 1965

Ross Milholland DOW

CONFIDENTIAL

Manager

Bioproducts

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 Naugatuck and the Co-Op.

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 Naugatuck

have particular questions about this problem that you invite them to come to

Midland where we will be glad to discuss the matter in detail with them and

show them what we have learned. We are not in any way trying to hide our

problems under a heap of sand, but we certainly do not want any situations to

arise which will cause the regulatory agencies to become restrictive. Our

primary objective is to avoid this.

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 . 4-12-20

correspondence

P.S. Under no circumstances may this letter be reproduced, shown, or sent to

anyone outside of Dow.

VKR

March 9, 2002

How old is this document? This is old news. 2,4,5-T was an active part of

Agent Orange, as well as early residential weed killers (Weed-B-Gone). This

document worries about acne from 2,4,5-T. Check the EPA web site and learn

of the reclassification of dioxin (2,3,7,8-tetrachlorodibenzodioxin) as a

carcinogen.

----Original Message Follows----

From: cavegrl777@...

undisclosed-recipients:;

Subject: [] DOW CONFIDENTIAL DOCUMENT 1965

Date: Fri, 8 Mar 2002 16:32:57 EST

For release and publication or web posting - Don Sarten New Zealand

Legible transcript of Dow Confidential Document originating from Sarnia

Canada.

Received

June 24, 1965

Ross Milholland DOW

CONFIDENTIAL

Manager

Bioproducts

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 Naugatuck and the Co-Op.

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.