GENTECH archive 8.96-97
Monsanto - 'A company of swindle'?
- To: email@example.com
- Subject: Monsanto - 'A company of swindle'?
- From: firstname.lastname@example.org (Alan Watson)
- Date: Tue, 21 Jan 1997 15:03:22 +0100
- Content-Type: text/plain; charset="us-ascii"
An interesting memo (without a date) that was posted to the dioxin
listserver today by Joe <email@example.com>. Would you buy a used
chemical from this company ? Or even a 'new' soya bean?
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON D.C. 20460
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE....
SUBJECT: Criminal Investigation of Monsanto Corporation - Cover-up of
Dioxin Contamination in Products - Falsification of Dioxin Health
FROM: Cate Jenkins, Ph.D., Chemist Regulatory Development Branch
(OS 332) Characterization and Assessment Division.
TO: John West, Special Agent in Charge Office of Criminal
Investigations Center U.S. Environmental Protection Agency Building
53, Box 25227 (303) 236-5100 Kevin Guarino, Special Agent Office of
Criminal Investigations National Enforcement Investigations Center,
As per our meeting yesterday, I am summarizing information available to me
supporting allegations of a long pattern of fraud by Monsanto Corporation.
The fraud concerns 2,3,7,7-tetrachlorodibenzodi (dioxin) contamination of
Monsanto's dioxin-exposed workers. You indicated that you would contact me
regarding the specific documents which would be useful to your
SIGNIFICANCE OF MONSANTO'S DIOXIN FRAUD
You stated that pursuing a criminal prosecution against Monsanto would
require a prior determination of the significance of the fraud. In order
for proceedings to be initiated by EPA, the fraud would need to have
affected the regulatory process at EPA and Monsanto would need to have
knowingly submitted the falsified data and health studies to EPA in order
to affect the regulatory process.
Monsanto has in fact submitted false information to EPA which directly
resulted in weakened regulations under RCRA and FIFRA since these
regulations do not take into account tetrachlorinated dioxin contamination
in trig, tetra, and pentachlorophenols, as well as 2,4-dichlorophenol and
its phenoxy acetate (2,3-D, a currently used herbicide). In addition,
Monsanto's failure to report dioxin contamination of the disinfectant in
Lysol has prevented any ban or other alleviation of human exposures to
dioxins in this product.
The Monsanto human health studies have been submitted to EPA by Monsanto as
part of public comments on proposed dioxin rules and Agency-wide dioxin
health studies are continually relied upon by all offices of EPA to
conclude that dioxins have not caused cancer or other health effects (other
than chloracne) in humans. Thus, dioxin has been given a lesser
carcinogenic potential ranking, which continues to be the basis of less
stringent regulations and lesser degrees of environmental controls. The
Monsanto studies in question also have been a key basis for denying
compensation to Vietnam Veterans exposed to Agent Orange and their children
suffering birth defects from such parental exposures. (1)
Monsanto would not be able to support a claim that independent researchers
were responsible for the falsifications, because Monsanto personnel
compiled all data utilized by these researchers. In addition the National
Institute of Environmental Health Sciences partially funded one of the
Monsanto studies in question providing a basis for charges of the
fraudulent use of governmental funds.
DIOXIN CONTAMINATION OF MONSANTO PRODUCTS
Monsanto covered-up the dioxin contamination of a wide range of its
products. Monsanto either failed to report contamination, substituted false
information purporting to show no contamination or submitted samples to the
government for analysis which had been specially prepared so that dioxin
contamination did not exist.
The earliest known effort by Monsanto to cover-up dioxin contamination of
its products involved the herbicide used in Vietnam Agent Orange (2,4, 5-
trichlorophenoxy acetate, 2,4,5-T). Available internal Monsanto
correspondence in the 1960s shows a knowledge of this contamination and the
fact that the dioxin contaminant was responsible for kidney and liver
damage, as well as the skin condition chloracne."
Early internal Monsanto documents reveal that samples of 2,4,5-T
and other chlorinated herbicides and chlorophenols submitted to the U.S.
Department of Agriculture in the 1970s were "doctored." In other words,
highly contaminated samples were not submitted to the government, and
Monsanto samples of penta tetra-, tetra-, tri-, dichlorophenol, and
associated herbicides never contained tetrachlorinated dioxins. These
analyses were subsequently adopted by EPA in a 1980 publication and were
used without any data from other sources as the basis for 1984 regulations
under RCRA. As a result, these regulations do not control the chlorophenol
phenoxy acetate products as acutely hazardous due to their contamination of
Monsanto also submitted assertions to EPA that process chemistry
preclude the formation of tetrachlorophenol or its phenoxy acetate.
Evidence from the Kemner v. Monsanto proceedings revealed that
chemistry claimed by Monsanto was not always used. In fact, off-
specification dichlorophenol, known to be contaminated with
tetrachlorinated dioxin, was being used as a feedstock to make
pentachlorophenol and other chlorinated products. The result of this
alternate synthesis route is the introduction of dioxins as a
EPA also relied on these "process chemistry" arguments by
Monsanto as a
basis for not regulating most chlorophenols and 2,4-D for their
tetrachlorinated dioxin content.
Another Monsanto document introduced as evidence in the above
shows cross-contamination of a range of Monsanto products with
tetrachlorinated dioxins by the following mechanism: The same
equipment is used without cleaning for all chlorinated phenolic
In 1984, when promulgating the dioxin regulations under RCRA, EPA
made aware of the cross contamination problem in the event that
made on equipment previously used to make 2,4,5-T. Thus, EPA
subverted from promulgating adequate regulations for products
2,4-D that were cross-contaminated with dioxins.
Members of the Canadian Parliament recently directed
the Royal Canadian Mounted Police and government scientist into
contamination of disinfectants such as Lysol containing Monsanto's
Santophen (ortho-dichloro-para-phenol), and directed laboratory
existing stocks. This disinfectant uses the ortho-dichlorophenol,
above, as a feedstock, which would introduce any dioxins present
disinfectant. In a 1984 letter to the Canadian government, Monsanto
asserted that their disinfectant contained no dioxin. This was later
refuted by testimony by Monsanto's chemist.
FRAUDULENT DIOXIN HEALTH STUDIES
As you indicated today, demonstrating criminal fraud in the
epidemiological studies performed by Monsanto on its
would necessitate bringing in appropriate groups in EPA capable of
performing scientific study audits.(3) You indicated, however,
did not believe this would be a barrier to the investigation. The
are a few key instances where obvious fraud was utilized in the
Dr. Raymond Suskind at the University of Cincinnati was hired by
to study the workers at Monsanto's Nitro, West Virginia plant.
stated in published studies in question that chloracne, a skin
was the prime indicator of high human dioxin exposures, and no
effects would be observed in the absence of this condition.
studies by Suskind, however, indicate the fallacy of this
workers except those having chloracne were ever examined by
included in his study. In other words, if no workers without
ever examined for other health effects, there is no basis for
that chloracne was "the hallmark of dioxin intoxication."(4) These
conclusions have been repeatedly utilized by EPA, the Veterans
Administration, etc., to deny any causation by dioxin of health
exposed citizens, if these persons did not exhibit chloracne.
The results of Dr. Suskind's studies also were diluted by the
the exposed group contained not only individuals having chloracne (a
genuine, but not the only effect of dioxin exposure), but also
having any type of skin condition such as chemical rash. The
have had no or negligible dioxin exposures, but they were
included in the
study as part of the heavily exposed group. This fact was
revealed only by
the careful reading of the published Suskind study.(5) Further,
utilized statistics on the skin conditions of workers compiled by a
Monsanto clerical worker, without any independent verification.(6)
Dr. Suskind also covered-up the documented neurological damage from
dioxin exposures. At Workers Compensation hearings, Suskind
denied that the
workers experienced any neurological health effects. In the
Kemner, et al.
v. Monsanto proceedings, however, it was revealed that Suskind
had in his
possession at the time examinations of the workers by Monsanto's
Dr. Nestman, documenting neurological health effects. In his later
published study, Dr. Suskind denied the continuing documented
health effects suffered by the workers, falsely stating that
All of the Monsanto dioxin studies also suffer another fatal
purported "dioxin unexposed" control group was selected from
at the same Monsanto plant. An earlier court settlement revealed
that these supposedly unexposed workers were exposed to dioxins,
to other carcinogens. One of these carcinogens, para-amino
known by Monsanto to be a human carcinogen and it was also known that
workers were heavily exposed.
Another Monsanto study involved independent medical examinations of
surviving employees by Monsanto physicians. Several hundred
employees were too ill to travel to participate in the study.
refused to use the attending physicians reports of the illness as
their study, saying that it would introduce inconsistencies.
critically ill dioxin-exposed workers with cancers such as
lymphoma (associated with dioxin exposures), were conveniently
from the Monsanto study.
There are numerous other flaws in the Monsanto health studies.
these misrepresentations and falsifications always served to
conclusions of adverse health effects from dioxins. A careful
these studies by EPA's epidemiological scientists should be
part of your investigation.
The false conclusions contained in the Monsanto studies have recently
been refuted by the findings of a recent study by the National
Occupation Safety and Health (NIOSH). This NIOSH study, recently
by Dr. Marilyn Fingerhut for review, found a statistically
increase in cancers at all sites in the Monsanto workers, when dioxin
exposed workers at Monsanto and other industrial locations were
an aggregate group.(7)
Please do not hesitate to contact me regarding documents to
investigation, which include testimony and evidentiary documents
on-going Kemner v Monsanto litigation, earlier litigation in West
brought by the Monsanto workers, ongoing investigations by the
government internal Monsanto documents, as well as documentation
submission of the fraudulent data and studies by Monsanto to
rulemaking process under RCRA and other EPA authorities.
Alan Watson C.Eng _\\|//_
Oakleigh (' O^O ')
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