GENTECH archive 8.96-97


Urgent Action - Monsanto GM Sugar Beet application

I received today a copy of this notice from the Cambridge Evening News on
16/1/97.  The deadline for submissions is therefore tonight.
The fax number for the DOE GMO department is 0171 276 8333.

Any submissions or comments would at least show we are watching them and
are concerned.

A few spicy details on Monsanto are included below to help you decide
whether this is an appropriate company to be playing God.



Public Notice

Monsanto plc, hereby give notice that they have applied to the Secretary of
State for consent to conduct field trials with genetically modified sugar
beet under section 111 of the Environmental Protection Act 1990.

The application is for a programme of releases and is made under commission
Decision 94/730/EC establishing a simplified procedure for the release into
the environment of genetically modified crop plants.

Sugar beet, which would normally be sensitive to the herbicide Roundup
Biactive (containing glyphosate) have been modified to express tolerance to
the herbicide.

The purpose of the trials is to assess during the period 1997 to 1999 the
performance of Roundup Biactivive to control weeds in the beet crop, the
tolerance of the crop to the herbicide, and the quality, yield and
agronomic characters of the beet Plants.  The trials will take place on
farmland near Cambridge and Lincoln, between planting in March-April and
harvesting in October-December.

Further information can be obtained from: Monsanto plc, Crop Protection, PO
Box 53, Lane End Road, High Wycombe, Buckinghamshire HP12 4HL.  Telephone
number 01494 474918.

Any comments to the Secretary of State should be addressed to the
Biotechnology Unit, Department of the Environment, Room A324, Romney House,
London SW1 P 3PY within 14 days of the date of this notice.

Monsanto - A glowing record:

Scientific American 11/96.


American trust scientists and doctors more than any other professionals,
but, recently, a number of leading scientists have expressed concern that
the credibility and effectiveness of science are being corrupted by money.
In order to maximize the profits of corporate investors, increasing secrecy
imposed on researchers is keeing valuable, and even potentially lifesaving
discoveries from reaching the public.

In times past, if a scientist discovered something exciting, he might run
down the hallways telling everyone about it. If a scientist kep quiet about
his or her work, it was so they could be the first to publish. Now,
important discoveries made under corporate-funded projects are sometimes
kept secret for many months, just to maximize corporate profits, or
minimize corporate losses. A good example is what happened during
Monsanto's campaign to gain acceptance for the controversial bovine growth

Scientists funded by Monsanto initially reported that cows given the growth
hormone only experienced a minor increase in udder infections.  But, when
independent researchers examined the data, they found that the previously
published reports had mysteriously only analyzed a part of the data.  With
a more thorough analysis, they found that cells associated wth infections
rose by about 20% in cows given the growth hormone. Because Monsanto
objected to publication of these damning results, the investigators had to
go on Canadian national television to get the news out to the public, and
the results have yet to be published.

Government funding for academic research has declined over the years, and
corporate funding has picked up some of the slack.  While it's good that
research continues to be funded, many corporations require scientists to
sign contracts delaying or even preventing the publication of any results
that will affect the bottom line - regardless of whether it deprives the
public of valuable information.  For example, when Boots Pharmaceutical
paid a researcher to compare its drug Synthroid, a synthetic thyroid
hormone, with three generic drugs, it was expected that the less expensive
generics would not be as effective. The investigation found, however, that
all were equally effective, and Boots refused to allow the paper to be
published bcause it would cergainly cut into their $600 million yearly
sales of the drug. Fortunately for the public, the matter was later brought
to light by the Wall Street Journal.

This material is presented for private discussion, research
and educational purposes only. (Fair Use: Sec 107; H.R. 2223)
Do not publish, broadcast or otherwise distribute this material
without prior written authority.

                         P A N U P S
                   Pesticide Action Network
                        North America
                       Updates Service

January 10, 1997

Monsanto Agrees to Change Ads and
EPA Fines Northrup King

Monsanto Co. agreed to change its advertising for glyphosate-
based products, including Roundup, in response to complaints
by the New York Attorney General's office that the ads were
misleading. Based on their investigation, the Attorney
General's office felt that the advertising inaccurately
portrayed Monsanto's glyphosate-containing products as safe
and as not causing any harmful effects to people or the
environment. According to the state, the ads also implied
that the risks of products such as Roundup are the same as
those of the active ingredient, glyphosate, and do not take
into account the possible risks associated with the product's
inert ingredients.

As part of the agreement, Monsanto will discontinue the use
of terms such as "biodegradable" and "environmentally
friendly" in all advertising of glyphosate-containing
products in New York state and will pay $50,000 toward the
state's costs of pursuing the case. The Attorney General has
been challenging the ads since 1991.

Monsanto maintains that it did not violate any federal, state
or local law and that its claims were "true and not
misleading in any way." The company states that they entered
into the agreement for settlement purposes only in order to
avoid costly litigation.

According to a 1993 report published by the School of Public
Health at the University of California, Berkeley, glyphosate
was the third most commonly-reported cause of pesticide
illness among agricultural workers. Another study from the
School of Public Health found that glyphosate was the most
commonly reported cause of pesticide illness among landscape
maintenance workers. (Both studies were based on data
collected between 1984 and 1990.)

In the first nine months of 1996, Monsanto's worldwide
agrochemical sales increased by 21% to US$2.48 billion, due
largely to increased sales of Roundup.




      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 2,3,7,8-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


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.


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
tetrachlorinated dioxins.

          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
this process
          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
was only
          made aware of the cross contamination problem in the event that
2,4-D was
          made on equipment previously used to make 2,4,5-T. Thus, EPA
again was
          subverted from promulgating adequate regulations for products
other than
          2,4-D that were cross-contaminated with dioxins.

          Members of the Canadian Parliament recently directed
investigations by
          the Royal Canadian Mounted Police and government scientist into
the dioxin
          contamination of disinfectants such as Lysol containing Monsanto's
          Santophen (ortho-dichloro-para-phenol), and directed laboratory
analyses of
          existing stocks. This disinfectant uses the ortho-dichlorophenol,
          above, as a feedstock, which would introduce any dioxins present
into the
          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.


          As you indicated today, demonstrating criminal fraud in the
          epidemiological studies performed by Monsanto on its
dioxin-exposed workers
          would necessitate bringing in appropriate groups in EPA capable of
          performing scientific study audits.(3) You indicated, however,
that NEIC
          did not believe this would be a barrier to the investigation. The
          are a few key instances where obvious fraud was utilized in the
conduct of
          these studies:

          Dr. Raymond Suskind at the University of Cincinnati was hired by
          to study the workers at Monsanto's Nitro, West Virginia plant.
Dr. Suskind
          stated in published studies in question that chloracne, a skin
          was the prime indicator of high human dioxin exposures, and no
other health
          effects would be observed in the absence of this condition.
          studies by Suskind, however, indicate the fallacy of this
statement. No
          workers except those having chloracne were ever examined by
Suskind or
          included in his study. In other words, if no workers without
chloracne were
          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
effects of
          exposed citizens, if these persons did not exhibit chloracne.

          The results of Dr. Suskind's studies also were diluted by the
fact that
          the exposed group contained not only individuals having chloracne (a
          genuine, but not the only effect of dioxin exposure), but also
all workers
          having any type of skin condition such as chemical rash. The
workers could
          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,
Dr. Suskind
          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
symptoms "had

          All of the Monsanto dioxin studies also suffer another fatal
flaw. The
          purported "dioxin unexposed" control group was selected from
other workers
          at the same Monsanto plant. An earlier court settlement revealed
not only
          that these supposedly unexposed workers were exposed to dioxins,
but also
          to other carcinogens. One of these carcinogens, para-amino
biphenyl, was
          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
former Monsanto
          employees were too ill to travel to participate in the study.
          refused to use the attending physicians reports of the illness as
part of
          their study, saying that it would introduce inconsistencies.
Thus, any
          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.
Each of
          these misrepresentations and falsifications always served to
negate any
          conclusions of adverse health effects from dioxins. A careful
audit of
          these studies by EPA's epidemiological scientists should be
obtained as
          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
Institute of
          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
examined as
          an aggregate group.(7)

          Please do not hesitate to contact me regarding documents to
support your
          investigation, which include testimony and evidentiary documents
from the
          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
of the
          submission of the fraudulent data and studies by Monsanto to
support the
          rulemaking process under RCRA and other EPA authorities.

 Alan Watson C.Eng                           _\\|//_
 Oakleigh                                   (' O^O ')
 Wernffrwd                             ==|=ooO=(_)=Ooo=|==
 Gower                                   !     ACT     !
 Swansea   SA4 3TY                       !     NOW     !
 UK                                      !     FOR     !
 Tel: 01792 851599                       !    CLEAN    !
 Fax: 01792 850056                       !  PRODUCTION !