mid-fifties, workers in factory after factory producing 2,4,5-T and polychlorophenolic compounds have been afflicted with chloracne after absorbing apparently only minute amounts of the dioxin contaminant; their symptoms have been described in several medical papers as including liver damage, nervous and mental disorders, depression, loss of appetite and weight, and markedly reduced sexual drive.

A few weeks ago, when a reporter approached an official in Dr. DuBridge's office for information on 2,4,5-T he was told that he would be given White House cooperation "only to a certain extent," because the official didn't want "wild speculation" stirred up. He cited as an example of "wild speculation" the recent controversy over the birth-control pill, which, he said, had “caused millions of women to get hysterical with worry." The reporter replied that he didn't think the analogy between 2,4,5-T and the Pill was a particularly good one, for the reason that a woman using the Pill could employ alternative methods of contraception, whereas a Vietnamese woman exposed to herbicidal spray put down by the American military had no choice in the matter.

But perhaps the comparison between 2,4,5-T (and its dioxin contaminant) and commonly used pills is worth pursuing. Suppose that such a dangerous substance as dioxin were found to be contained in a pill offered for human consumption in this country, and suppose that the contaminant were present in such minute amounts that an adult following the prescribed dosages might ingest a hundredth of a millionth of a gram of the contaminant per day. There is no doubt whatever that, according to existing Food and Drug Administration standards, the F.D.A. would immediately ban production and sale of the pill on the ground that it was highly dangerous to public health; in fact, the amount of such a potent contaminant that the F.D.A. would permit in a pill under the agency's present policy on toxicity would almost certainly be

zero.

While 2,4,5-T, with or without the dioxin contaminant, doesn't come in pill form, it may be worthwhile to try to calculate, on the basis of a hypothetical pill, how much 2,4,5-T (and dioxin) a Vietnamese woman living in an area sprayed by the American military might ingest in a day. It has already been calculated by reputable biologists that, if one takes into account the average amount of 2,4,5-T sprayed per acre in Vietnam, and also takes into account a one-inch rainfall-such as is common there-after a spraying, a forty-kilo (about eighty-eight-pound) Vietnamese woman drinking two litres (about two quarts) of 2,4,5-T-contaminated water per day could be ingesting about a hundred and twenty milligrams (about a two-hundred-and-fiftieth of an ounce) of 2,4,5-T a day. If the 2,4,5-T contained the dioxin contaminant at a level of one part per million-which is what the Dow people say is the maximum amount present in the 2,4,5-T they are currently producing-the Vietnamese woman would be absorbing a little over a tenth of a microgram of dioxin per day, or ten times the amount of dioxin entering the system of an adult from the hypothetical pill that the F.D.A. would certainly find dangerous to human health. Further, if this Vietnamese woman were to conceive a child two weeks, say, after the spraying, the weight of the dioxin that by these same calculations would have then accumulated in her system (the evidence thus far is that dioxin accumulates in mammalian tissue in the same manner as the chlorinated hydrocarbons, such as DDT) would be more than the weight of the just-fertilized ovum. Considering the existing evidence of the frightening degree of teratogenicity of the dioxin in chick embryos and its highly toxic effects on mammalian fetuses, the presence of this much dioxin in a mother's body at the very beginning of a human life surely has ominous implications.

Now, what about the safety of 2,4,5-T itself? Admittedly, the dioxin contaminant seems to be a residue from one stage of its manufacture. But if by some future chemical miracle the very last trace of dioxin could be removed from the finished 2,4,5-T, would the resultant "pure" 2,4,5-T be harmless? The fact seems to be that even then 2,4,5-T, as produced in this country, would have to be viewed with suspicion, for the breakdown products of 2,4,5-T, when subjected to heat and other conditions, are themselves capable, according to a number of responsible biologists, of producing dioxin. Given this potential, the ultimate folly in our defoliation operations in Vietnam was possibly achieved during 1965 and 1966, when the military made large-scale efforts in two defoliated areas to create fire storms-that is, fires so huge that all the oxygen in those areas would be exhausted. The apparent intention was to render the soil barren. (A fire storm would also, of course, have the result of burning or suf

focating any living beings remaining in the area.) Operation Sherwood Forest, conducted in 1965, was an attempt to burn a defoliated section of the Boi Loi Woods. In October, 1966, the military began Operation Pink Rose, a similar project. Neither of the projects, in which tons of napalm were thrown down on top of the residue of tons of sprayed 2,4,5-T, succeeded in creating the desired effect; whether they released into the atmosphere dioxin produced by the breakdown products of the 2,4,5-T will probably never be known.

There are also less spectacular ways in which conditions suitable for the release of dioxin in Vietnam may have been created. For example, after areas accessible by road have been defoliated, woodcutters move in to chop up the dead timber, which is then carted off to nearby towns and sold as firewood. Large quantities of it are said to have been entering Saigon for years. Since the fires are customarily tended by Vietnamese women, and since many of them are certainly pregnant, the hazards to health and to the lives of unborn children surely cannot be ignored.

In the United States, the potential hazards from the present use of 2,4,5-T are considerably less than they are in Vietnam. In the first place, the recommended concentrations of 2,4,5-T for spraying here are, as I have pointed out, about a thirteenth of what the Vietnamese population is sometimes subjected to. And, in the second place, a great deal, if not most, of the 2,4,5-T that would otherwise have been sprayed on American crops and grazing areas has for several years been sent to Vietnam. However, the shortage of 2,4,5-T in this country does not necessarily mean that the potential hazards are at a minimum. The substances known as the trichlorophenols and compounds of pentachlorophenol, which officials of the F.D.A. believe may be chemical precursors of dioxin under certain thermal and other conditions, are used widely in the manufacture of a large variety of consumer products, ranging from paper to laundry starch and hair shampoo. Dow Chemical puts out a whole line of polychlorophenolic chemicals known as Dowicide Products. Monsanto Chemical also puts out a line of pentachlorophenol substances, known as Penta Compounds. Since a very great many consumer products wind up being burned sooner or later, and since the polychlorophenolic compounds are suspected of being capable, under particular thermal and other conditions, of releasing dioxin, the alarming question arises whether, and to what extent, dioxin is being released into the environment through the atmosphere. Pentachlorophenol, used in certain herbicides, is readily decomposed in sunlight, and in its breakdown process a number of products, including chemical precursors of chlorodibenzo-p-dioxin compounds, are produced. Because of these factors, a whole range of pesticides, as well as of herbicides, now must come under suspicion of producing dioxin compounds.

Although the chemical companies that manufacture 2,4,5-T have long taken pride in pointing out that 2,4,5-T itself is quite readily decomposable in soil, the crucial matters of how stable the dioxin contaminant is and to what extent it is cumulative in animal tissue have apparently been neglected. Consequently, the fact that traces of compounds virtually indistinguishable from dioxin have already been detected in this country in the human food chain—in the livers of chickens and in edible oils-clearly indicates that dioxin should be considered a hazard to man. Why, under all these inauspicious circumstances, the production and the use here and in Vietnam of 2,4,5-T has not summarily been stopped by the United States government is hard to understand.

Sincerely,

DEAR MR. MCCARTHY: The Secretary has asked us to reply to your letter of February 3, 1970, requesting whether the Food and Drug Administration has information indicating that 2,4,5-T is now safe to use.

No tolerances have been established for residues of 2,4,5-T in food or feed crops. The whole matter of the safety of this herbicide, when its use results in a residue in or on a food crop, is currently under evaluation. This evaluation will be completed as expeditiously as possible. We are enclosing a Fact Sheet explaining the status of 2,4,5-T at this time.

We shall promptly inform you of our decision upon completion of the evaluation of 2,4,5-T.

Sincerely yours,

M. J. RYAN, Acting Director,

Office of Legislative Services.

FDA FACT SHEET

U.S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE,

PUBLIC HEALTH SERVICE,

FOOD AND DRUG ADMINISTRATION,
"Washington, D.C.

* 2,4,5-T *

2,4,5-T (2,4,5-trichlorophenoxyacetic acid) has had extensive registered use as a defoliant and weed killer. It has also been registered by the U.S. Department of Agriculture as a pesticide chemical (herbicide) on a no residue basis on a few certain selected food crops for some years, primarily for weed control of pasture and rangeland.

TOXICITY

A research study recently completed under contract to the National Cancer Institute on a commercial lot of 2,4,5-T showed that the feeding of this material to rats and mice produced abnormal birth effects on the embryos.

Further investigation of the 2,4,5-T used in the feeding studies established that the material used contained a significant amount of one of more impurities called dioxins produced during the manufacture of 2,4,5-T. Improved manufacturing processes are claimed by one manufacturer to have reduced the dioxin impurities to insignificant amounts.

The dioxins are of concern because they are known to be extremely toxic to poultry and to have produced severe skin irritation to workers in plants exposed to dioxins inadvertently during the manufacture of other chemicals. At present a number of research studies are underway in both government and commercial laboratories to determine if the reported birth defects of the earlier study are due to 2,4,5-T itself, the dioxin impurities, or a combination of the 2,4,5-T and the dioxins.

Additional investigations are underway to improve our ability to detect very small amounts of dioxins in samples of 2,4,5-T and to determine whether other commonly used pesticides chemically related to 2,4,5-T contain significant amounts of the dioxin contaminants. Drinking water supplies are being tested for the presence of 2,4,5-T and other possible environmental sources of these chemicals studied, but no results are available at this time.

The USDA announced on February 6, 1970, that it is investigating 17 commonly used pesticides chemically related to 2,4,5-T to determine whether they contain hazardous amounts of these toxic contaminants.

FOOD IN THE UNITED STATES

The Food and Drug Administration is continually engaged in examining samples of individual foodstuffs for residues of pesticides above the safe tolerances established under the Miller Pesticide Amendment. In addition, FDA purchases food in the markets of several cities, prepares the food in the quantities and combinations typical of the diet of an average 19-year-old male, and determines the amounts of the several pesticides that might be actually ingested in the typical diet of a heavy eater.

Of 5300 food samples tested for 2,4,5-T residues during the last four-year period, 25 samples indicated trace amounts (less than the 0.1 p.p.m. limit of accuracy of present analytical procedures) and 2 samples showed higher residues. 0.19 p.p.m. 2,4,5-T was detected in one sample of milk taken in 1965 in New England, and one sample of sugarbeets from Ohio in 1966 showed 0.29

p.p.m. 2,4,5-T. The milk had been distributed before analysis was complete and processing of the sugar-beets removes the chemical. If food is found to contain finite residues of 2,4,5-T, it is subject to removal from the market.

STATUS OF 2,4,5-T UNDER THE FEDERAL FOOD, DRUG, AND COSMETIC ACT

No finite tolerances have been established for residues of 2,4,5-T or the dioxins in food. In the absence of established tolerances any detectable amount of either chemical in food would make the contaminated food illegal and subject to seizure if found in the channels of interstate commerce.

A petition was filed in December, 1967 requesting the establishment of tolerances of 0.2 p.p.m. for residues of 2,4,5-T on apples, barley, blueberries, corn, oats, rice, rye, sugarcane, and wheat. Neither the petition as originally submitted or as later supplemented provided data to support affirmative action and the petitioner withdrew his petition on December 29, 1969, as provided for under the pesticide regulations.

Petitions to establish a safe tolerance level for residues of 2,4,5-T in food may again be submitted to the FDA in the future. However, any such submission must include scientific research data to resolve the questions that have been raised concerning toxicity of 2,4,5-T and the dioxins.

CONCLUSION

The Department of Health, Education, and Welfare is continuing investigations to determine the potential hazards from the possible presence of residues of 2,4,5-T and dioxins in foods, water, and other environmental sources to which the public may be exposed.

It is to be emphasized that there is no tolerance for 2,4,5-T in food today; the testing of food over the past several years has revealed no significant problem of food contamination.

Appendix 5

PROBE INTO USE OF HERBICIDES BY CONGRESSMAN RICHARD D. MCCARTHY.

D-N.Y.

Globe, Ariz., February 13, 1970

Ladies and gentlemen, I think we should begin. I am Congressman Richard D. McCarthy, and the hearings will come to order.

For more than a decade scientists have had serious misgivings about the widespread use of herbicides and pesticides in the environment. The late Rachael Carson warned of the risk of the use of herbicides, whose effects were either harmful or unknown.

In the United States 120 million acres each year are sprayed with herbicides for the clearing of railroads, for brush control, for watershed management, and for other purposes. One of these is known as 2,4,5-T. It was developed and perfected at Fort Detrick, Md., the army's chief Biological Warfare Research Center. The herbicide 2,4,5-T, and 2,4-D, a related herbicide, collectively account for some 83 million pounds of production per year-that was the figure in 1968.

I've long been concerned with the widespread use of these herbicides in Vietnam. Each day some 100 tons are dropped on South Vietnam, and scientists for many months have been concerned about the adverse ecological effects of this herbicidal inundation.

Last summer in the course of my inquiry into the Army's germ and gas warfare policies, I learned that a study, by the Bionetics Research Laboratories for the National Cancer Institute showed that the herbicide 2,4,5-T produced birth defects in rats and mice.

When the conclusions of this study were known, the President's science adviser, in October, announced a ban on the herbicide beginning January 1, 1970, unless the F.D.A. had found safe legal tolerances. I was distressed 11 days ago to learn that contrary to the White House's announcement, the Department of Agriculture continues to authorize the use of 2,4,5-T in the United States. It's incredible to me that someone, or some people should have succeeded in overruling the science adviser to the President of the United States.

We know from the thalidomide experience that if we are going to err, we should err on the side of caution, and not on the side of danger. It is my firm conviction that such chemicals should not be used unless full tests show that they are safe. It is also incredible to me that this herbicide, which has been in existence since its development some 25 years ago at the Germ Warfare Research Center, still has not been fully tested for its teratogenic effects on human beings-that is, its power to produce birth deformities.

We know that it produces birth deformities in test animals under laboratory conditions, and we continue to receive reports from Vietnam that civilian women living in this heavily defoliated area are bringing forth deformed offsprings.

The Saigon Press has reported on these in considerable detail.

Now, we have the allegations, and complaints emanating from here, Globe, Ariz. It is my hope that my investigation into these complaints and allegations will assist me in continuing my inquiry into this whole matter. I wish to determine how the White House was overruled, and why it is that we continue to use this herbicide despite the warning signals that have arisen.

As the great French scientist physiologist, Claude Banard, once said, "True science teaches us to doubt, and ignorance to refrain."

I want to welcome all the local State and Federal officials who are in attendance. I hope to have a chance to meet with you personally during our visit.

Our first witness is Prof. Arthur W. Galston, a professor of biology from Yale University.

Doctor Galston.

Professor Galston, I wonder if, for the record, you would identify yourself, and your background, and particular expertise in the matters under inquiry. Dr. GALSTON. Very happy to do that, Congressman.

I'm currently a professor of biology at Yale University. I'm also lecturer in forestry, and director of the March Botanical Gardens at Yale. I've been a professor of plant physiology for about 27 years. I was trained at the New York State College of Agriculture at Cornell University.

I did my graduate work at the University of Illinois, where I earned a Ph.D. degree in 1943. I then went to work for the emergency rubber project for the U.S. Government, located at Cal-Tech. During World War I was agricultural officer for U.S. Navy Military Government on the Isle of Okinawa. I then worked at Cal-Tech for 10 years, and I've been at Yale for the last 15 years.

I've published books in the area of plant physiology, and I have over 100 articles in the subject.

Congressman MCCARTHY. For the record, Doctor Galston, I wonder if you could give us a scientific information about the herbicide under investigation. DR. GALSTON. Congressmen, what I'd like to do is to give you and the audience here some appreciation of the feeling of a large number of scientists as exemplified in this report recently delivered to the Secretary of Health, Education, and Welfare, Finch.

It is called, "The Report of the Secretary's Commission on Pesticides and Their Relationship to Environmental Health." It's dated December 5, 1969, and was prepared by the distinguished panel shared by Doctor Emil Mrak, the chancellor emeritus of the University of California at Davis.

It included many academic people, and also the vice presidents of two important companies, Dow, and Eli Lilly, both of whom manufacture herbicides and other pesticides in wide use.

The Commission takes note of the fact that there are now more than 400 different kinds of chemicals which are being used as pesticides to combat insects, fungi, weeds, and other predators.

Our modern agriculture and highly technicalized food production activities demand that we do use chemicals in agriculture.

I'd like to make it clear that I'm not alining myself with people that say, "Stop all chemicals." That's ridiculous in this day and age. We are dependent upon chemicals, and we have to keep using them.

Nonetheless, some of these chemicals are terribly noxious when introduced into the environment.

All of us are now familiar with the fact that DDT may be more of a bane than a boom. It has become global. Even a penguin picked up on an ice flow in Antarctica is full of DDT, and that was 400 miles from the application of