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            <element elementId="50">
              <name>Title</name>
              <description>A name given to the resource</description>
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                  <text>Alvin L. Young Collection on Agent Orange</text>
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                  <text>&lt;p style="margin-top: -1em; line-height: 1.2em;"&gt;The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.&lt;/p&gt;&#13;
&lt;p&gt;For more about this collection, &lt;a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a"&gt;view the Agent Orange Exhibit.&lt;/a&gt;&lt;/p&gt;</text>
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              <text>0508</text>
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              <text>Series III Subseries I</text>
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                <text>Boraiko, Allen A.</text>
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                <text>National Geographic</text>
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              <elementText elementTextId="8043">
                <text>1980-02-01</text>
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                <text>The Pesticide Dilemma</text>
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                <text>health effects</text>
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                <text>crops</text>
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                <text>pest control methods</text>
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                    <text>Item ID Number

01251

Author

Darrow, Robert A.

CorDOratB Author

United States Army, Plant Sciences Laboratories, Fort D

ROpOrt/APtiClB TitlO Herbicides Used in Southeast Asia

Journal/Book Title
Year

1969

Month/Day

August

Color

n

Number of Images ie'
DOSCTlpton NotOS

Alvin L

Young filed this item under the category
"DDT/Human Toxicology and Environmental Fate";
Found in a file labeled "'Use of Herbicides in Vietnam
1961-1971', Presented to Educational Conference on
Herbicide Orange, May 1980." Prepared under contract
FD-2050-9-11078.

Thursday, April 26, 2001

Page 1251 of 1328

�'FOR OrrJCIAl. Udfc OlMLT

*. ~. *•

SAOQ-TR-69-11078

HERBICIDES USED IN SOUTHEAST ASIA

CO
CD
00

Robert A. Darrow
Kent R. Irish
Charles E. Hinarik
United States Army
Plant Sciences Laboratories
Fort Detrick
Frederick, Maryland 21701

TECHNICAL REPORT SAOQ-TR-69-11078
August 1969
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Prepared Under Contract FD-2050-9-11078

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San Antonio Air Materiel Area
Directorate of Air Force Aerospace Fuels
Kelly Air Force Base, Texas 78241

U£&gt;C

�-TOR OFFICIAL U3C ONLYSECTION VII
AERIAL SPRAY SYSTEMS AND APPLICATION

A.

AERIAL DISSEMINATION SYSTEMS
I. A/A45Y-I Interna1 pefoltant Dispenser

The A/A45Y-1 defoliant dispenser Is a nodular spray system
Cor Internal carriage in cargo aircraft. It has been used only in C-123
aircraft but is adapted for use in the C-130. Currently, only UC-123K
aircraft are used with the A/A45Y-1 system. Two gasoline-burning Jet
engines have been incorporated in this model to provide an additional
source of emergency power after spray dissemination.
Essential design features of the A/A45Y-1 dispenser are:
1,000 gallon tank
20 hp gasoline engine and pump
Operator's console with pump and spray release controls
Wing booms 17 feet long and 1% inches in diameter, extending
froa outboard engine nacelles toward the wing tips, with 12 check-valve
nozzles regularly spaced.
Tail boom 20 feet long and 3 inches in diameter, positioned
centrally near the aft cargo door, with four check-valve nozzles on each
end spcced At 6-inch intervals.
Nozzles are Spraying Systems Company check-valve bodies (3/8
inch) without nozzle orifices, the spray being emitted directly from the
open check valves*
Performance characteristics:
Aircraft speed

135 V.nots

Flight altitude
Effective swath width

ISO f.»rt
240 »'-at

Application rate

3 gallons/acre

Delivery rate
Spray droplets, HMD
Spraying time for 950 g?lions

250 gallons/minute
320 to 350 microns
4 minutes

Length of swath

10.4 statute miles
(16.7 km)

OFFICIALESE ONLY

�•fOR OFFICIAL USE ONLY2. UH-IB/D Helicopter Spray System (ACEINAUTICS)
; The AGRINAUTICS (formerly AGAVENCO) spray unit i* self-contained
and is suitable for use In the Army UH-1B and UH-1D, the US Navy 11IH-IE
and the US Air Force UH-1F helicopters. It can be installed in or removed
from the aircraft in a natter of minutes because it is nerely "tied down"
to installed cargo shackles, and no modifications are required for it* use.
The sprayer was designed for the dissemination of insecticides or herbicides.
Essential design features of the Sprayer-Pesticide, Helicopter
Mounted, UH-IB/D are:
200-gallon fiberglass tank
Cradle or support structure 10 x 4 x 3.5 ft
Externally mounted 6-bladed windmill pump
Spray booms 32 feet long vith positions for 56 nozzles
Weight of system, 200 pounds empty
Performance characteristics:
Aircraft speed
Flight altitude
Effective swath width
Maximum application rate
Spray droplets, HMD

50 to 90 knots
50 feet
100 feet
3 gallons/acre at 90 knots
150 to 300 microns

The UH-IB/D system has been used extensively by the Army in small*
area spray applications. Under field conditions, some difficulty has been
experienced with ORANGE in softening the paint on the aircraft tail
assembly and fuselage. Preventative measures include preliminary coating
of the aircraft with light grease and follow-up rinsing with diesel fuel
or kerosene.
3. Field Expedients
A number of "jerry-rigged" or field-expedient devices have been
developed for use in helicopters for snail area spraying of chemicals on
perimeter defenses, helicopter landing sites, and Vietcong (VC) crop
areas. These field expedients have ranged from a 55-gallon drum equipped
with spray bar for temporary mounting across the skids of a UH-IB/D
helicopter tc large devices for a CH-47 aircraft consisting of a 400-gallon
metal tank tv 500-gallon collapsible fuel bladder with power-driven fueltransfer pump and improvised boom.
As regular items of issue, such as the UH-lB/D Helicopter Spray
5:yetern, become readily available, the use of field expedients may be
discontinued.

'ICIAL USE OHI&gt;

�•TOR orneiAi use
B.

OPTIMAL CONDITIONS FOR AERIAL APPLICATION

The basic consideration in aerial application of liquid sprays for
vegetation control is to secure maximum deposition of the delivered agent
on the selected target. Exact placement of the spray on target is essential
to secure full advantage of the chemical and to prevent possible damage to
crops or other desirable vegetation in proximity to the'target area*
The following guidelines have been developed for RANCH HAND operations
with the A/A45Y-1 system:
1* Missions will be accomplished under inversion or neutral
temperature conditions with air temperatures not to exceed 85 F. ! These
conditions are usually obtained in early morning hours* Spraying' under
lapse conditions will result in upward movement of fine drops with con- sequent drift and reduction of deposit.
j
I

2. Winds should not exceed 10 mph at ground level. Lateral
displacement of spray droplets as affected by a crosswind of 3 mph is
shown in Table VII.
.
of
of
of
be

3. Spray should be released at 150 feet or lower. Spray droplets
ORANGE 100 microns in diameter require 2 minutes to fall a distance
150 feet. Under conditions of a 9-mph crosswind, the 100-micron drop
ORANGE may be laterally displaced 1,594 feet. A 300-micron drop will
shifted 183 feet from the line of delivery (Table VIII).

4. Mass median diameter (HMD) of the spray should be coarse (300
to 350 microns) to reduce the proportion of small drops available 1 to drift
off target. Small droplets (100 microns or less) are more effective than
large drops in producing herbicidal or desiccant effects. The selected
size is a compromise with effectiveness to reduce drift and secure
accurate placement on the target.
5. Delivery aircraft speed should be slow (130 to 135 knots) to
minimize droplet breakup from impingement of the airstream on spray at
the nozzle and to maintain a capability to stay on target with changes
in direction. Nozzle orifice tips have been removed from the A/A45Y.-1
system to maximize droplet size at this speed.
*.

6. Flight targets should be oriented in an inwind direction as
far as possible to reduce drift.
7. Spray applications should not be made during or immediately
preceding heavy precipitation. ORANGE, being insoluble in water, is
least affected by rainfall occurring immediately after spray application.
Effective amounts of ORANGE, BLUE and WHITE will be absorbed by the
foliage within 1 hour after spray deposit.

28

TOR OFFICIAL USE ONLY-

�TABLE VII.

Droplet
Diameter,
microns

EFFECT OF SPRAY DROPLET SIZE ON SPRAY DRIFT

Type of
Droplet
Brovnian
particle
Fog
Mist
Light rain
Moderate
rain

0.5

5
100
500
1,000*

No. of Droplets
per Square Inch
at 1 Gal. of
Spray per Acre

Distance Droplet
Time Required
Will Travel in
to Fall 10 ft. Falling 10 Ft. in
in Still Air
a 3-mph Breeze
6,750 minutes

&lt;•»

90000
,0,0
1,164
9

66 minutes
10 seconds
1.5 seconds
1.0 seconds

"

388 miles
3
409
7
4.7

miles
feet
feet
feet

.

* 1,000 microns - 1/25 inch.

TABLE VIII. RATE OF FALL AND DOWNWIND DRIFT OF ORANGE
FROM 150-FOOT ALTITUDE IN 3-, 6-, AND 9-MPH WINDS

Droplet Size,
microns

Rate of Fall,
ft /min

Time to Fall
150 ft, min

50
70
100
150
200
250
300
400
500

18
36
73
164
291
456
657
1,162
1,812

8.33
4.17
2.0
0.91
0.52
0.33
0.23
0.13
0.08

Feet of Lateral Drift
While Falling 150 ft.
in Crosswinds of:
3 MPH 6 MPH 9 MPH
0°
2,199 4,398 6,597 2 0
1,101 2,202 • 7 0
3 5 3 &gt;OOB
538 1,056
1,594 S&amp;&gt;»
240
720 -\ zffl&gt;
480
137
274
411
87174
261
122
183 V
61
102 1
34
68
42
21
63 -&gt;

C. SPRAY DRIFT ON DEFOLIATION MISSIONS AND PROXIMITY TO CROPS
Spray drift from defoliation missions may become a potential problem
when desirable crops are in close proximity to the target. The principal
factors influencing drift from spray applications are: droplet size,
height of release, and atmospheric conditions, principally horizontal air

29

�FOR orneiAi use ONLY
movement. In Table VIII, data are presented for the rate of fall and
amount of lateral drift of herbicide ORANGE under three crosswind velocities
on release from ISO-foot altitude.
Calculations for an assumed droplet spectrum for the UC-123K system
with 350-micron HMD showed that 88% of the total spray volume consisted
of droplets 200 microns or larger iu diameter.17 This portion of the
total spray delivered under a 9-mph crosswind would fall within 411 feet
of the aircraft flight path, giving a ground deposit of 1.4 to 3 gallons
per acre. Under the same crosswind conditions, droplets 70 microns in
diameter would drift a total distance of I kilometer (3,303 ft) from the
flight line. Again, on the basis of an assumed droplet spectrum, droplets
varying from 70 to 100 microns in size would give a total deposition
volume of only 0.032 gallon/acre from a single sortie. This rate of
deposition of ORANGE would cause herbicidal response only on the most
sensitive or susceptible crop plants. The deposition from dropletn 50
microns in size would be negligible, amounting to only 0.0012 gallon/
•ere for a six-sortie mission.
Thus, the most unfavorable conditions of a 9-mph crosswind, a
multiple-sortie mission, and spray droplets of 350 microns HMD should
give no drift damage to broadleaf crops at distances greater than I to
2 kilometers at a maximum. Rice and other grass crops will not be
affected by drift of ORANGE at distances greater than I kilometer.
Under the herbicide operation procedures for aerial spray applications
with the UC-123K. or UH-1B/D aircraft outlined in MACV Directive 525-1,18
the prescribed distances of defoliation targets from rubber plantations
and crop areas provide an adequate safety factor to avoid crop damage
from spray drift from defoliation missions. Strict adherence to these
procedures will insure proper application on the assigned target and
minimize the hazard of damage to nearby crops or rubber plantations.
In many instances of alleged crop damage due to drift, careful
examination has shown the damage to have been caused by leaking nozzles
or other malfunctioning of the spray system. Equipment should be carefully checked before and after each mission to prevent leaking or spray
deposition on ncntarget areas.
D.

VOLATILITY AND CROP DAMAGE

Two of the three herbicides in use in RVN, agents BLUE and WHITE,
are prepared as aqueous solutions of water-soluble solids. The active
ingredients are nonvolatile, and there is no vapor hazard associated
with their use.19

30

FOR OFFICIAL USE ONLY-

�TOR orneiAi use ONLY
In the field of vegetation control, the butyl esters of 2,4-D and
2,4,5-T in ORANGE are considered volatile. However, the vapor pressure
of these components and of ORANGE is less than 1 mm of mercury at 35 C
(Table XX). The physical chemist would regard ORANGE as essentially nonvolatile. In the tabular data presented, the values represent the temperatures at which vapor pressure of the material equals 1 mm of mercury. A
high value, such as that of butyl 2,4-D, thus represents low volatility.

i
\
TABLE IX. RELATIVE VOLATILITY OF COMMON CHEMICALS*
Temperature at which Vapor Pressure
Equals 1 mm of Mercury, C

Substance

Water

-17

Butyl Alcohol
Ethyl Glycol (permanent anti-freezc)
Naphthalene (solid moth balls)
Hexachlorobeneene
Kerosene
No. 1 Fuel Oil
Glycerine
Butyl 2,4-D
No. 2 Fuel Oil

- 1
S3
53
114
120
120
125
147
153

* Data from R.C. Wesst ( d ) Handbook of chemistry and physics, 49th
e.,
edition, Chemical Rubber Publishing Co., Cleveland, Ohio, 1968.
Because vapor pressure of ORANGE is extremely low and, under optimal
conditions, approximately 97% of the spray volume from the UC-123K system
is deposited on the ground or vegetation in less than ore minute following
release from the aircraft, it may be concluded that vapor released during
droplet descent represents an extremely small percentage of the entire
mass of herbicide sprayed. Thus, vapors arising during actual spray
operations are not a significant source of herbicide for crop damage
outside the target area. The greatest hazard of vapor damage occurs
under neutral conditions and near-calm winds. For this reason, it is
recommended that spray missions be carried out only under inversion
conditions insofar as the tactical situation permits.
The extent of vapor release from the vegetation after spray deposit
is not known. However, under lapse conditions, the vapor would rise above
the canopy and be dissipated. Under inversion conditions, the vapor would
be trapped within the forest canopy and further supplement the herbicide1
effect from absorption of spray droplets.

•EOR ornciAi use

:

�R OFFICIAL USE ONLY,
Observations of defoliation targets by competent personnel have
consistently shown sharp demarcations between the sprayed swaths and
adjacent unsprayed forest areas when spraying was conducted under conditions of minimal grour.d wind. If volatility of the sprayed herbicide were
significant, the boundaries of the sprayed swaths would be obliterated due
to lateral movement of vapor into the unsprayed areas under the normal daily
convections1 air movements. The sharp boundary cones of sprayed areas are
Chus indicative of a limited volatility response.
It is concluded that lateral movement of vapor from ORANGE is negligible
under ordinary conditions and that volatility of ORANGE is not significant
in causing damage to crops.

E. 'CALIBRATION PROCEDURES FOR AERIAL SPRAY SYSTEMS
Characteristics of the spray deposition pattern from aerial systems,
including mass deposit (gallons per acre), swath width, HMD, and droplet
spectrum, are determined by test flights on a calibration grid with
selected agents under simulated operational conditions.
Test flights are made inwind to provide data for effective swath
width and total deposit. Crosswind flights permit determination -of
HMD and droplet spectrum characteristics. Flights over the calibration
sampling grid should be restricted to neutral or Inversion conditions
with wind velocities not exceeding 3 to 8 knots, except for crosswind
flights. Parameters measured during test flights include flow rate (gpm)
and dissemination time to permit determination of total delivered volume.
If flow meters are not incorporated in the spray system, flow rate may
be determined in static or. ground tests.
1. Sampling Grid
Spray deposition samples are usually collected both on Kromecote
cards and on aluminum or glass plates at sampling stations placed at
regular intervals, in a line perpendicular to the flight path. Dye is
added to the agent to permit tpectrophotometric determination of deposit
from the aluminum or glass plate and to aid in visual determination of
drop size on the Kromecote cards.
In calibration tests conducted in 1968 with the A/A45Y-1 system,80
the sampling grid consisted of three parallel lines 5,000 feet long, each
row containing 297 campling stations. The central 1,000 feet of each line
had sampling stations at 5-foot intervals.
2. Mass Deposition and Droplet Spectrum
Total mass or spray deposition (in gallons 'per acre) is determined
for each sampling station by: (1) colorimctric or spectrophotometric
determinations of the dye deposit on aluminum or glass plates; ( ) visual
2

re* ernciAi USE ONLT

�-fOR OrriCIAL USE ONLY
counts of droplets by spot sizes on Kromecot* cards with appropriate
conversion to droplet volume or mass by means of spread factors; or
(3) visual estimate from Kromecote cards by comparison with standard
cards of varying deposition rates. Graphic plots of the deposition
pattern in relation to the flight path are used in determining effective
swath width. I
The droplet spectrum may be expressed as the number or volume of
droplets by site classes over the range of droplet size. Droplet diameter •
data may be obtained from the Kromecote cards. Card spot diameters (in
100-micron-diameter classes) may be converted to spherical droplet diameters
by use of predetermined spread factors. In the recent Eglin APB tests,80
a minimum of 75 spots were tallied for each sampling station for computations
of total deposit in droplets less than 100 microns, 100 to 150 microns, and
in excess of 500 microns in spherical diameter. The spread factor for
ORANGE in this ter&gt;t ranged from 2.441 at 100 microns to 7*957 for drops
6,000 microns in diameter.
3. Mass Median Diameter (HMD)
HMD is defined as the droplet size in microns below which one-half
the total recovered mass or volume of deposit occurs. It expresses the
mid-point in droplet size based on volume of spray deposited. Crosswind
flights that sort out droplet sizes according to distance from the flight
path are useful in measurement of HMD.
Approximations of HMD may be obtained by the spot D-max method,
selecting the largest drop in a measured series of 10 to 15 individuals
on Krotaecote cards from cr OF ..wind flights. The spherical drop D-max
computed from the spot diameter by the spread factor is then used in
estimating HMD by means of a conversion factor related to aircraft
speed.31 The conversion factor varies from 2.2 for slow speeds (80 mph)
to 2.5 for high-speed delivery systems (150 to 180 mph). The following
formula is used:
,1 .««, Spherical drop D-max
. Estlr. ted HMD « -• • • • • ' ' " •
Conversion factor
Direct calculation of HMD was obtained for data in the 1968 Eglin
Air Force Base tests by computing cumulative mass deposits over the full
range of droplet size classes based on actual tallies on inwind and
crosswind flights.
4.

Swath Width

Swath width for a specific aerial spray system, such as the A/A45Y-1,
varies with several factors, such as spray altitude, droplet spectrum and
HMD, inwind or crosswind conditions, etc. The most accurate determination
of swath width is obtained from direct inwind releases under inversion conditions with aircraft crossing the sample grid line at right angles.

•MR ornciAL use ONLY

�TOR OrnCIAL USE ONl¥
Effective'swath width is based on a minimum biologically effective
deposition rate for the agent or agents. For Southeast Asia conditions,
the minimum biologically effective deposition rate for ORANGE was established
at 1.0 gallon/acre.20 Effective swath width can be computed as the width of
a continuous swath equal to or in excess of this minimum deposit level.
5. Percentage Recovery
Percentage recovery represents the relationship between the amount
of spray material released from the aircraft and the amount actually
deposited on the ground at the sample line less the amount lost due to
drift and evaporation. In the 1968 Cglin tests, average recovery of
ORANGE was 82.74% for inwind flights and 72.36% for crosswind flights.80

�• FOR OFFICIAL U3C UMLI
SECTION VIII
GROUND DISSEMINATION SYSTEMS AND APPLICATION
A.

BUFFALO TURBINE

. ,
• *•••••

Various dissemination devices, as field expedients, have been used in
RVN for control of vegetation on limited areas. The Buffalo Turbine is
representative of one type of disseminator that is capable of disseminating
both liquid and dry chemicals and may be obtained from agricultural supply
houses in the Unite* States. One type of unit consists of a trailermounted, 50- or 100-gallon stainless steel tank with agitator, pump, turbine
fan and air-cooled gasoline engine. In operation, .the turbine fan generates
a high-volume, high-velocity airstream which is projected through a
restricted orifice and will develop an air blast with a velocity up to
150 mph and a volume of 10,000 cubic feet per minute. The chemical is
atomized into a fine mist when injected into this air bl&amp;st.
The Buffalo Turbine is adapted for roadside spraying and applications
on perimeter defenses. Application of ORANGE or BLUE may be made of
undiluted chemical or of 1:1 dilutions with diesel fuel (ORANGE) or
water (BLUE).
B. POWER-DRIVEN DECONTAMINATION APPARATUS (PDDA)

The PDDA is a self-contained spray system mounted on military vehicles
and was designed to disseminate decontaminating chemicals to eliminate
toxic agents. In the field, these units are usod for many purposes,
Including dissemination of herbicides. Several models of these decon
rigs are available in RVN, and all are adaptable for use on vegetation
control problems. The larger models have pumps capable of delivering
chemicals at rates of 35 to 60 gallons per minute at pressures up to
800 pounds per square inch. Delivery is through two hoses, with adjustable nozzles, located at the rear of the unit.
The PDDA units have been used effectively with available chemicals
to control vegetation on minefields, perimeter defenses, roadsides, etc.
For localized applications of chemical, BLUE may be diluted with 2 gallons
of agent in 50 gallons of water. ORANGE may be mixed with diesel fuel at
the rate of 5 gallons to 50 gallons of diesel fuel. Applications may be
made at volumes of 50 to 100 gallons of spray solution per acre as required
to completely wet the foliage.88

35

"Oft OFFICIAL

�. FOR OPPICIAL USE ONLY
/

SECTION IX

CONDITIONS INFLUENCING EFFECTIVE USE OF HERBICIDES
A. DEFOLIANT OPERATIONS
1. Tarpet Vegetation
Twer principal types of forest are recognized in RVN: (1) upland
forests, which vary from dense tropical evergreen to fairly open semideciduous types, and (2) lowland or mangrove forests. The basis for this
practical, simplified classification is the overall response to available
chemical agerts.
Upland forests usually consist or an overstory or dominant canopy
of trees varying in height and crown size with one or more intermediate
layers of smaller trees. The overstory trees may attain heights of 60 to
125 feet in high-rainfall areas and may consist of b.roadleaf evergreens or
seasonally deciduous species. The intermediate and understory vegetation
is often complex, with hundreds of species of shrubs, bamboo, palms, vines,
and small trees ranging up to 20 to 30 feet or more.
In disturbed or partially cleared upland forests, remnants of the
dominant overstory may remain with a dense secondary growth of suall trees,
shrubs and vines. Secondary forest or scrub and bamboo may develop
rapidly on abandoned cropland or areas wheie timber has been removed.
Response to defoliant agents in the upland type will vary with
the species mixtures and the complexity of the forest cover. Species
differ widely in their response or susceptibility to the systemic herbicides
ORANGE and WHITE. The long-term effectiveness of the defoliant treatments
will be influenced by the proportion of resistant species. With the exception of areas dominated by bamboo, upland forest vegetation can be effectively defoliated for a period of 4 to 12 months with a single application
of chemical. Repeat applications may be needed to maintain long-term
defoliation, particularly in multiple-canopy areas. Secondary forest or
scrub with a single canopy layer nay show better canopy penetration and
plant kill.
Lowland or mangrove forests are of two general kinds: those that
grow in standing water, usually within the limits cf mean high tide, and
those that grow s'tove the tidal limits but in marshy, poorly drained areas.
In either type, the trees tend to be uniform in height, varying from 25 to
65 feet. These forests have a limited number cf species, and an understory
or ground cover is usually lacking. Trees have prop and aerial roots that
Impede movement and visibility. Nipa palm, water coconut, and tall ferns
may occur near canal or river channel borders.

36

orriciAi use ONLY

�Mangrove forest shows excellent response to defoliation treatment
with ORANGE. Single applications nay give nearly complete kill so that'
repeat applications are not necessary. Nipa palm is generally slower in
reaction; it is readily defoliated by ORANGE but not by WHITE. In general,
ORANGE is preferred for defoliation in this forest type.
2. Selection of Agent

&lt;
ORANGE and WHITE nay be used for general long-term defoliation on
forest areas in which a rapid defoliation is not required. BLUE may be
used for more rapid but correspondingly short-term defoliation of woody and
grass vegetation. In general, WHITE shows a slower initial defoliation
response than ORANGE and a corresponding delay in rate of regrowth or
replacement vegetation. Discoloration or browning of foliage sprayed with
ORANGE is evident within one veek after application. WHITE is slower In
producing a visible plant response, requiring approximately 2 to 4 weeks
for noticeable browning of tropical vegetation.
The oil-soluble (ORANGE) herbicides are more effective under moist
and rainy conditions than are the water-soluble WHITE and BLUE. Oily
agents are not readily washed off the foliage and penetrate waxy leaf
surfaces more readily than do water-soluble agents.
Under temperate forest conditions, broadleaf deciduous forest
types nay be defoliated with ORANGE or WHITE. Evergreen conifer forests
are more susceptible to defoliation with WHITE than ORANGE.
3. Rate of Application
Application rates of 3 gallons per acre are used for defoliation
of tropical forest vegetation with agents ORANGE, WHITE and BLUE. Research
tests in Thailand indicated that ORANGE was effective on secondary growth
vegetation at 2.0 gallons per acre, but for general use the 3-gallon rate
is recommended. Under temperate forest conditions, application rates of
1 to 1.5 gallons per acre of ORANGE may be sufficient*
No advantage was found in increasing the rate of BLUE above 9 to
12 pounds per acre for rapid defoliation in tropical forest areas (Table IV),
4. Season, of Application
Agents ORANGE and WHITE are more effective as defoliants when
applied during the rainy or growing season. Both chemicals are systemic
herbicides and are more readily absorbed and translocated in the plant
system during periods of active growth. Under RVN conditions, some of
the trees become dormant and deciduous during the dry season and subsequently are less affected by these chemicals.

37

�Agent BLUE, as a desiccant or contact herbicide, has been found
to be effective during both rainy and dry seasons. BLUE nay be preferred
for short-term defoliation during the dry season.
B. I AKTICROP OPERATIONS
! Target Crops
•
Although extensive areas of RVN are under cultivation, selected
target areas are highly restricted in location and type of crop.
/

Upland rice grown in recent slaeh-and-burn areas in the highlands
area constitutes one of the principal target crops. Crop control operations are not conducted in the extensive areas of paddy rice In the IV
Corps or delta region.
2. Selection of Agent
Rice, corn and other cereal crops nay be effectively controlled
with agent BLUE.
Host broadleaf crops such as manioc, castor beans, soybeans, sweet
potatoes, garden beans, cabbage, peanuts, etc., are susceptible to treatment with ORANGE (see Section IV, A, 4).
3. Ratc of App4Icatton
Reconmended rate of application of BLUE and ORANGE in the UC-123K
system is 3 gallons per acre. This rate is considerably in excess of the
amount required &amp;s a lethal dosage but is used to provide compatibility
with alternative defoliation targets, which tuy be chosen as replacements.
For specific crop targets to be spr?y«*.d by helicopter systems,
the recommended rate of BLUE or ORANXJE i* 1 gallon per acre. Adjustment
to the normal delivery volume of 3 gallons per acre of the UH-lB/D system
may be made, if desired, by dilution of ORANGE with 2 parts of Diesel
fuel and dilution of BLUE with 2 parts of water per unit of chemical.
The recommended rates are considerably greater than required for
crop destruction or yield reduction. Effective control of rice can be
obtained with 1.0 pound/acre of BLUE and of most broadleaf crops with
similar rates of ORANGE. Application of BLUE at rates as low as 0.2S
pound/acre on rice will significantly reduce crop yields even though
the plants may remain green.

38

FOR OFFICIAL USE

�ron orriciAi USE ONLY
A. Season of Application
In general, chemical applications to crops should be nude during
the early growth stages prior to flowering and seed or fruit production* '•
Rice and most broadleaf crops should be treated before seed head produc- ';
tion. Root or tuber crops, such as potatoes, sugar beets and manioc,
show greatest yield reduction from application of chemicals during early
vegetative growth.
C. CRASS AND TOTAL VEGETATION CONTROL
1. Target Vegetation
For base camp perimeters, minefields, and lines of cooounication
with predominantly tall grass and woody sprout vegetation, BLUE is the
preferred agent of the chemicals currently available. Repeat applications
may be required at If to 2-month intervals to kill back regrowth.
Bulldozed or mechanically cleared areas with heavy regrowth of
woody sprouts may be treated with ORANGE at the standard application rates
with aerial or ground spray equipment.
Kenapon, a liquid formulation of dalapon, has received limited
trial under tropical conditions and shows promise as a systemic herbicide
for control of perennial grasses, such as elephant grass, vild cane, etc.
Further test work is needed to provide a recommendation.
2.

Rate of Application

Similar to those for defoliation, BLUE may be applied for grass
control at rates of 2 to 3 gallons per acre with aerial or ground equipment. ORANGE or WHITE may be used for woody plant control at similar rates.
3. Season of Application

Similar to requirements for defoliation.
D.

GENERAL RECOMMENDATIONS

A synopsis of general use recooraendations for vegetation control
agents in Southeast Asia is given in Table X.

39

�TABLE X.

Type of
Vegetation Control

SYNOPSIS OP USE RECOMMENDATIONS FOR HERBICIDES IN SOUTHEAST ASIA

Target
Vegetation

Agent

Rate,
gal/acre

ORANGE

3

Avoid proximity to rubber and crop
areas.

J)

WHITE

3

Avoid proximity to rubber and crop
areas.

H

BLUE

3

Short-term effect*

ORANGE

3

Preferred agent.

BLUE

3

Optional near crops.

BLUE

3

Use undiluted in C-123 system.

1

Dilute with 2 gallons of water for
total of 3 gallons per acre in
UH-IB/D system.

3

Use undiluted in C-123 system.

1

Dilute with 2 gallons of dlesel
fuel for total of 3 gallons per acre
in UH-IB/D system.

Defoliation

ET

Upland forest

Mangrove forest

&gt;
. *&gt;
.

—
^

o

Crop

n
D

^

Rice and grain
crops

Broadlcaf crops

Grass and Total
Vegetation

ORANGE

Restrictions on Use

Grasses

BLUE

3

Not effective on bamboo. •

Woody regrowth

ORANGE

3

More effective on sprouts I year
or more old*

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                    <text>00153
Author

Hoge, George F.

Corporate Author

Deprtment of the Army, U.S. Army Combat
Developments Command, Liason Detachment, HQ
USARV, APO San Francisco

Report/ArtiCiS Title

Tr

'P Report. 1st Air Cavalry Division, 11-14 Sep 67

Journal/Book Title
1967

September 19

D

Thursday, December 28, 2000

Page 153 of 157

�1OF FriE
US

Liaison Detachment, HQ
APO San Francisco
CDCCS-L?

96:

19 Se

T r i p Report - 1st Air Cavalry

TO:

of Doctrine,
trandsen, LTC
p!rtt0$ f
BeIvoi.r, Virginia
Officer,
Officer,
73504

H- 14

67.

ATTN: LTC lerrtogton, LTC
Fort Belvolr, Yirginia
A

™^

LTC

MAJ

7

*

An»r Agcncy, Fort I«O3cf
Artillery

Fort Sill,
tit O

Ftirt

31905

m

fi

1.
1st Air
tain

were:
» •?

2,

11-14 September,
the
Division. The
pwpose of £he ^ ^'^ ^^
of user
standardiatlen o£ MM 126
iteos.
O f this surw w l l l ^ wporfcej- fc
Other
;»» £ise
of
guns in
load of the
JL
of M79 CS ro«ds»
o£ aerlal
to the »8A3 tank, a«d otter
™
The

«

„

»ith
« _

TC wm Louise lie
LTC Jack
LTC Bradford
CPT
AJ
-ILT
SIC
2LT

c

-3
CO, 2ct Bn» 8th Cav
Qiv

C0» Cn 4, 14 Ba,
S-3, 1st
tst OBV 0i

10, Co A» im fcs

Pit Ldr, Co C,
2d Pit Ldr, Co A, 1st

5th

,laf

"

"

�3 f% f*

CDCCS-LV
au.,,fic A .
CJ--,,,,„.

~

,

Trip

-

- i s t Air Cavalry

1
9

11-14 Sep 6?

3- Observations. (Sub-paragraphs a, b. c, and e are
to questions from General

in

»»«««»«

a.
LTC
,
his
normally carried
o LA* wni.e on
and
More were a i r l i f t e d to
.he companies If
He stated the 90tei reeoiltess r i f l e was
preferred over the LAW for
destruction and
of night
positions
of its
and the
round. All persons
questioned stated the LAM was easily
from carrying throurfi
the jungle and had to be
after 2 or 3 days in order to get a
replacement. All persons also stated the LAW was not reliable in
wet weather
the electrical contacts
out, LTC Dashielle
apparently relt his greatest success in destroying
wnkers was when he had a platoon of tanks attached. The tanks used
*JBO, tracks, and hand
to destroy the
with very small
loss to
infantry. Captain
that his
'
the LAM during 4
he ««s lft COH»«id
They
tad appropriate targets, 9fca reeoilless were
in
kits by helicopter. These
preferred over the LA» beof
range and
round. The 16th Infantry
*«*
they
with
Major
the 9Qwn
round to be very
in cUarisw
aaa
He it&amp;l the same
on the UW us
J
,

b.
All companies take the MfeQ on
and
and
otner orrensive type operations, In all
it was
the
guns are attached to
sqyads. SfC
that
or reduced strength he usually had only two
rifle
ir, his platoon, When
about the
for
automatic rirepower in view of the
ef tte m§ ^^
persons replied that the
tf
and chat
were
rauni;;or. anc avoid
Th« 2d lmf
laf
^oint tr^r, -ay fire
and all
The
are employed in an
role
the
rf^*
- '"
toon crosses a clearing or
a
It is
at
as an
rifle

�ru'a UM iCoU. USE
CDCCS-LV

,

Trip Report .
c.

ist A i r Cavalry Dlvision

Infantryman's Load

. Whe" a b a t t a l i o r &gt; is on a search and destroy mission
r,panles normlly operate from a battalion oper.Ung ba« „

se ln

^, ^

lsc cavairy

&amp;0iQi

- ^^ «^»

* so d^r carries «f n T "'""T8 " ' "-"'
er «"««
and

,

ln8

2-3
ra'-or

•a,nc f * f

T

.*

an 2 W
2-5
stated he

d«

*

fc»»*ic»
two
gr
a^ oae ^^i of C

c*i

oo hu

t^ « for

Mwself

M79 CS

I
thus

it
nask.

-

ens o, water, 2 tragmentaticm

the

re^i^^^

for tte

range
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&lt;p&gt;For more about this collection, &lt;a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a"&gt;view the Agent Orange Exhibit.&lt;/a&gt;&lt;/p&gt;</text>
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                <text>Hoge, George F.</text>
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                    <text>13

Item ID Number
Author

Monroe, Frederick L.

Corporate Author
Report/Article TitlB

Tne

Effects of 2,4-D and Related Compounds on Plants

Journal/Book Title
Year

1965

Month/Day

Januar

Color

v

-/
v

Number of Images

32

Doscripton Notes

APGc-TR-65-7

Monday, November 13, 2000

Page 13 of 20

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THE EFFECTS OF 2,1-l-D AND RELATED COMPOUNDS ON PLANTS

By

Frederick L, Monroe, 2d Lt, USAF

CoA/wu

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�FOREVORtt
This report, APGC Project 8780, Task D2!4-57, was prepared during the
period July to November 196^. The information was acquired from the
Agricultural Library, University of "Florida and the Technical Library,
Air Proving Ground Center* The report was prepared as a result of a
meeting between the Air Proving Ground Center and Det ^, Research and
Technology Division, in which- n need for a compilation of this nature
was realized, A good example of the precautions taken by the Air Force
in their range efforts, this report is intended for use by the military
and civilian populations. Fanners and others who spray for weed control
will be particularly interested. A glossary of botanical terms is provided in this report for those who may not be familiar with the language.
This technical report has been reviewed and is approved.

J. E. ROBERTS
Major General, USAF
Commander

11.

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.ABSTRACT

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The effects of 2,n--D and related compounds on plants and animals, including
information concerning the sensitivity of plants, physiological action of
the herbicides, characteristic appearance of affected plants, and methods
of determining the herbicide on the plant are presented. 2,^-0 being the
most characteristic compound of the group is discussed in greater length.
It exerts its greatest effect in the rapidly gro-wing and differentiating
plant tissues. Cotton is the most sensitive major crop in the Northwest
Florida area. One ounce of 2,4~D evenly distributed over 35 acres will
seriously injure a cotton crop. For this reason, extreme care should be
taken during all herbicide spray operations and especially when such
chemicals as 2 ^ 0 "Silvex" and "Falone" are applied adjacent to cotton
,-,
fields. The use of mist-blower applicators should be limited to only
those cases when complete meteorological data and other information pertinent to drift control are available and indicate absolute safety.
.,
-Grasses being fairly tolerant to 2,4—D are not injured by a dosage of
1 Ib/acre. Tolerance of other crops is given. Six methods are given
for the extraction of herbicide from a sample of foliage. The characterization of the compound is then accomplished with a gas chromatograph,.

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�CONTENTS

I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.
XI.

INTRODUCTION
2,^-D AND RELATED COMPOUNDS
,
ANIMAL TOXICITIES
2,luD IN THE SOIL
;
2,lM) IN PLANTS.
LOCAL CROPS
'
EFFECTS OF 2,*UD ON COTTON
ATMOSPHERIC DRIFT EFFECTS OF 2,*UD
EFFECTS ON SELECTED CROPS
..
METHODS FOR DETERMINATION OF 2,UD.
SUMMARY
'
REFERENCES

..
.

APPENDIX I - TABLES
j|
APPENDIX II - DETECTION OF 2,^-D ON COTTON USING A GAS
CHROMATOGRAPH

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6
8
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10
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13
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19 .

�GLOSSARY

Apical'

Of the apex, at the tip.

Atypic

Not typical.

Auxin

A plant-growth regulating substance.

Cotyledon

The first leaf of a young seed plant.

Cuticle

A thin waxy lipoid covering on the plant.

Dicotyledon

A plant type with two cotyledons, most herbs, shrubs
and broadleaved trees. See Cotyledon.

i
,

-

Differentiation The process whereby simple cells become specialized.
Usually takes place in the meristems.
Epinasty

Twisting and curvature in plants as a result of unequal
growth rates.

v
Lipoid

Fat-like, fatty.

Lipoid System

Fatty tissues in a plant in"which organic esters are
found.

i

Meristem

I

See lipoid system.

The region in the plant where simple cells are found and
growth occurs. See differentiation.

Monocotyledon

A plant type with one cotyledon, most grasses. See
cotyledon.'

Phloem

A living vascular system which commonly transports food
downward in the plant. See vascular system.

Polysaccharide

A carbohydrate that can be hydrolized into two or more
molecules of sugar. See saccharide.

Prpphase

An early stage of cell division.

Stomates

A pore-like opening found in the leaves and stems of
plants through which carbon dioxide, water vapor, and
air can pass.

Saccharide

A sugar.

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�, GLOSSARY (Continued)

Surfactants

A compound which will stick to a surface and/or pause
another to stick when it normally would not.

i

Turgid

To have turgor pressure.

Turgor Pressure

The normal water pressure in a plant which keeps it
from wilting.

Vascular System

A specialized "pipe" system for the transport of fluids
in the plant. See phloem, xylem.

Xylem

A dead vascular system which commonly transports water
and minerals in the plant. See vascular system.

vli

See turgor pressure.

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INTRODUCTION.

2,4~D a)Kl the related compounds MCPA; sesonej 2,4-DEP or "Falone";
2,4,5-T; 2,4,5-TP or "Sl.lvcx" and 2,4-DB are selective herbicides against
broad-leaved dicotyledonous plants. 2,4-D being probably the simplest,
roost effective, and most characteristic compound of the group will be
.discussed in greater length with only comparative remarks concerning
special properties of the other related .compounds listed.

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II.

2,J)~D AND RELATED COMPOUNDS.

•

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The pure acid form of 2,4-D (2,4-dichlorophenoxyacetic acid) is a
white crystalline material, with, a molegular weight of 221.04 and a
.'
melting point: of 138~l4o°C. Its solubility in water at 22°C is 605 ppm;
at 50°C, 1.490 ppm, provided by V, H« Freed, Oregon State University.
The acid is insoluble in petroleum oils, fairly non-corrosive to metals,
'•
non-explosive, fire resistant, inexpensive, translocated in a plant,
.
|
' does not ctf L'ect greatly soil microorganisms, and is non-toxic to animals •
I
within limits. 2,4-D is often formulated as salts and esters in various
forms for use as a herbicide, depending on the conditions of intended
\
usage. '
•'
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The pure acid form of 2,4-D for instance is not ^applied as a water
spray because of its low water solubility. Troublesome calcium and magnesium precipitates which are difficult to remove will form ,in hard water,
clogging spray nozzles and filters. The ester formulations are not subject
to this difficulty. The pure acid is usually applied as a gifanular material. The salt forms of 2,4-D are soluble in water, however, and are used
7
l
when a water solution is desired. The ester formulations ari oil soluble
and may bo used in conjunction with aromatic oils to increase the herbicidal characteristics of the mixture. Dust formulations are made from
salt and ester forms but are. subject to serious wind drift, hence dusts
are not be'applied by airplanes.
An ester formulation may be made relatively volatile or non-volatile
depending on the basic alcohol used in the ester formation;' Recently,
the non-volatile esters, though more expensive, have come into greater
use because they offor less hazard to nearby 2,4-D sensitive crops. The
esters of 2,4-D are generally considered most toxic to plants because of
volatility, increased liooid-like wetting action, and compatibility with
the cuticle with a resultant increased efficiency of absorption. Lower
rates of application of the esters are possible with increased penetration of the woody species.
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The volatility of a 2,4-D ester has been studied by Staten to determine its significance.
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Abnormal growtli symptoms appeared in cotton plants
around a 12 inch diameter pan containing 800 ml of
a solution containing 10 ml of a 9 6 esterified
.$
2,4_D compound, for a radius of 25 to 30 feet. The '
pan was in direct sunlight and 373 plants were nffected by the vapor.1

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2,4,5-T (2,4,5-trichlorophenoxyacetic acid) is very similar to 2,4-D
in all respects except that it is more effective on woody'species that
are resistant to 2,4-D but less effective on many other plants. Mixtures
of the two are often used, since in combination they affect many more
species than the singular formulations.
MCPA (2-methyl, 4-chlorophenoxyacetic acid) is very similar to 2,4-D.
Its effectiveness varies on different species as does the effectiveness of
2,4-D but the correlation of species is not high, so that in conjunction
the two are effective on a broader range of species—-similar to 2,4-D and
2,4,5-T mixtures. MCPA has been studied extensively in Europe and is used
there for weed control in small grains, flax, and peas. It is a fairj.y
expensive compound in the'United States.
"
"""
"Silvex" or 2-(2,4,5-trichlorophenoxy) propionic acid, also called
2,4,5-TP, controls some plants that'resist both 2,4-D and 2,4,5-T, notably
chickweed, henbit, wild strawberry, some oaks and maples, and a number of
aquatic weeds.
I'
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4-(2,4-dichlorophenoxy) butyric acid (2,4-DB) has a low toxicity-to
most 'plants. It is converted to 2,4-D in the plant by a process known as
beta oxidation. Legumes make this conversion so slowly that there is
never sufficient 2,4-D to cause serious plant injury. Weed_ control is
thus affected in legumes. Other plants make this conversion rather
rapidly and are killed or damaged by 2,4-DB if subject to the effects
of 2,4-D.
'
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2,4-DEP or tris(2,4-dichlorophenoxyethyl) phosphite is sold as
"Falone." It is a viscous, oily liquid with a density of 0/96, and is
nearly insoluble in water.. It is soluble in aromatic hydrocarbons and
• slightly so in alcohol. It is considered relatively non-volatile and
is used where 2,4-D esters would present a hazard. ' 2,4-DEP is commonly
used for preemergent weed control and is effective for three to.seven
weeks. Moisture (rain water) in the soil slowly decomposes 2,4-DEPj to
2,4-dichlorophenoxyethanol and phosphorous acid. 2,4-dichlorophenoxyethanol and 2,4-D have similar effects in regard to seedling developrnont
and seed germination. Both compounds in the soil seem to be responsible
for the herbicidal effect observed.

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�Sesone (sodium 2,H-dichlorophenoxyethyl sulfate) like "Falone" does
not harm plants by direct contact but depends on soil water to hydrolize
it to the active compound 2,il--dichlorophenoxyethanol, which in turn is
often oxidized to 2,iul). It is an amorphous solid and is hydrolized under
_aeid conditions and by the soil organism Bacillus Ceres var mycoides.
III.

ANIMAL TOXI CITIES.

The animal toxicity of the 2,^-D compounds is fairly low. A single
oral dose of to g of 2,Jl--D would be needed to produce an LD5O in a l80-lb
man. Small doses of a gram or so have little or no effect when taken for
a week or more. Different animals have been tested, with an LD50 in a
single oral dose ranging from 300-1000 mg/kg of body weight. LD5ofs for
the different 2,4-D like compounds fall into this range. Injury at lower
doses usually consists of skin and eye irritation. .At usual plant-control
dosejs 2y^-D does not reduce the number .of soil organisms. At heavier rates
some are inhibited and others stimulated. Anaerobic organisms are not
affected significantly and may be stimulated.
IV. 2,luD IN THE SOIL.
has an effect on modulation of the common bean that greatly
affects the vigor of the plant. Very small amounts drastically cut the
number of nodules, but 2,li— D up to rates of 200 Ib/acre does not affect
the Rhizobia bacteria. The response is therefore largely a plant response.
See Table 1 for data on the bean plant -responses to 2,4-D.
Microorganisms have a definite relation to the persistance of 2,U-D
in the soil, and are of major importance in decomposition of the chemical.
Low rates of 2,4-D will decompose in one to four weeks in warm wet soil;
spray strength solutions lose their strength in four to seven weeks. Dry
or frozen soils will not decompose the chemical quickly. Light sandy soils
do not decompose 2,*u-D as effectively as heavy clays with a high percentage
of organic matter. There is no cumulative build-up of 2,4-D in the' soil
from year to year. Adaptive enzymes appear to be involved in this decomposition.2
At constant rates, 2,^-D is more effective on sandy soils. than heavy
clays. This fact is presumably dependent on the adsorptive capability of
the soil.3 Rainfall has a profound effect on the persistence of 2,*u.D in
the soil. A study of the persistence of the chemical in the soil was
conducted using cotton plants as bio-indicators. The data is summarized
in Table 2. Results indicate that 2,^-D either leaches or is inactivated
in wet soil probably through decomposition and adsorption. "The application

3

�of 1 ml of a 50 ppm solution to'the soil around the cotton seedlings
resulted in less injury than the application of 0.1 ml of a 1 ppm solution to the cotyledons."3 At constant rates, 2,4-D is less effective in
the soil than when applied directly to the plant.
Plant roots most readily absorb the polar forms of 2,4-D whereas
the leaves absorb the non-polar forms. Surfactants increase the efficiency of foliar absorption. In most cases 6-12 hours is necessary for
a plant to absorb a lethal dose of 2,4~D prior to rain. The oil-like \
esters resist washing from the plant and are therefore fairly "rainresistant."

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2,4-D IN PLANTS.

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2,4-D is then translocated within the plant downward through the
phloem as a food metabolite, upward through the xylem as .a watersoluable ion, and transversly in the lipoid system as an ester. An excessive application of 2,^-D will kill cells locally and not- injure the '"•rest of the plant. Since translocation throughout the plant is necessary
for a complete kill, smaller doses of 2,4-D are desired and ultimately
more effective. Most effective treatment of plants occurs when large
amounts of food are 'being moved to the root system for storage, in late
spring or early fall. A number of low-rate applications then are more
effective than jare heavy applications. Soil moisture favors rapid translocation, A number of studies have been made with radioactive carbon to
find translocation rates.4 Alligator weed, for example, translocates
2,4-D through the phloem at the rate of 4.2 cm/hr. The method used to
determine this rate was by measurement of the bending of the stem,

&gt;- '

In general, all plants are susceptible at germination, but differences
rapidly become apparent. "Plants gain tolerance with age but generally are
most susceptible during periods of rapid growth.
Regarding a mode of action for 2,4-D, the Botanical Review states that
the youngest and most turgid leaves absorb the chemical, best. The entry of
radioactive 2,4-D into a grassy leaf (millet) and a bean leaf proceeds-at
the same rate. There is also no difference in plants in the metabolic rate
of 2,4-D in susceptible and non-susceptible plants. A high correlation
between susceptibility and translocation out of a leaf has been found;
" . 2 $ of the applied dose migrated out of bean, soybean, and cotton
..5
leaves in 24 hours, but only 1$ out of oats, wheat, and rice leaves."2
The meristem of the non-susceptible varities then is subjected to much
less 2,4-D than the meristem of the susceptible species.
2,4-D in the plant, in addition to decomposition, is also rendered

�ineffective by forming neutral complexes -with certain cell constituents.
The plant apparently possesses a number of seemingly different mechanisms
by which inactivation of 2,4-D can take place. It is significant that
2,luD in the plant is much more stable than the natural auxin, indoleacetic
acid.
seems to have a remarkable persistence in plant tissues. 2,**—D
injury often appears in perennial plants the following season. There seems
to be particularly critical periods in a plantTs development. Sometimes
for instance, an application made in the fall produces a striking effect
next -spring. Applications made at other .times, however, fail to produce
any noticeable effects. It is important to distinguish between "(a) persistence of 2,^-JD in plant tissue and (b) delay in visible expression of
effects of 2,4~D.»5
The auxin 2,^-D not being broken down by the plants normal metabolic
system as is indoleacetic acid, causes "an increase in total auxin level
in the plant. It is presumed that it is this increase that is responsible for the herbicidal effect of 2,1+~D. As an auxin, 2&lt;.,k~D exerts its
effect largely in the meristems of the plant and affects differentiation.
2,4-D has been observed to block the prophase stage in an onion root. A
treated plant produces a tumorous distortion of tissues, atypic organs,
and eventually dies if a high enough concentration is present. It folloys
that any auxin in high quantities would function as a herbicide providing
it can produce a high auxin content in the plant and correspondingly, is
not subject to metabolic reduction to an ineffective compound.2
Parenthetically, 2,^-D increases the protein and .decreases the sugar
content of potatoes. These changes may be significant in that an increased
disease resistance has been observed. 2,^~D increases the use of both
readily available and stored food in the plant so that a slow starvation
takes place in conjunction with the various deformations. (See Reference
kf p. 1J2-135.) Auxin-treated foliage is preferred by Japanese beetles.
Cane treated with 2fk~D is preferred by sugar beet bores. This indicates
that the 2,4~D does indeed penetrate the foliage of even non-susceptible
species. (Radioactive carbon tests also substantiate this fact.) Corn
treated with 2 ^ becomes more palatable for field mice. In California,
,0
sheep ate Centaurea Solstitictlis only after it was sprayed with 2,^-D,
and poisonous ^Corium maculatum though usually avoided" was eaten by cattle
after it was sprayed causing the cattle to die.
-i
Although total plant weight and total sugar content decrease rapidly,
there is a slight increase in the percentage of polysaccharides about one
week after treatment. This percentage increase lasts for about three
weeks. It is possible that the animals prefer those aforementioned plants

�because of the Increase in sugar content. 2,^~D slows the production of
sugar; therefore, the food reserves of the plant become the sugar source
•with resultant starvation of the plant. The nitrogen percentage also
rises above the check (or normal control plant),' but most of this rise
is attributed to plant weight loss and not to nitrogen increase.
/'
Because small amounts Ojf 2,k~D can .cause such profound changes within
the plant's many interrelated systems, it has long been suspected that it
affects the enzyme- systems. Findings indicate, however, that there is no
simple explanation.

I
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i

causes the stomates of plants to close with an effect directly
proportional to the dose. The subsequently reduced carbon dioxide intake
arid transpiration rate could account in part for the slowed food (sugar)
production in the plant. A suffocation of the photosynthetic process
takes place. Apparently^ as a result of the closure of the stomates, the
turgor pressure increases. This increased pressure coupled with the other
physiological changes observed in the plant combine to cause an unusual---^
brittleness.
causes plants to twist and curl as a result of different rates
of growth and differentiation. Roots, stems, and leaves are often twisted
and malformed. 2,4-D is found in greatest concentrations in the meristematic tissues of the plant where it exerts its greatest effect. Lateral
meristems are inhibited, whereas comparatively, the apical meristems are
not. The areas of greatest growth are affected the most.
VI. LOCAL CROPS.

'

Okaloosa County's seven most important crops are, in order of
decreasing acreages: corn, soybeans, yelvet beans, cotton, hay crops,
wheat, and oats. Walton County statistics are comparable, with the
exception of peanuts which would rate just before velvet beans in the
above list. Soybeans and velvet beans seem to be increasing acreagewise in Okaloosa County.6 These crops are all affected to some extent
by 2,^—D» Particularly sensitive to 2,JI—D is the cotton crop. The
legwnes are also generally sensitive. Oats and wheat, being monocotyledons are less affected than the others. Tomatoes are probably the
most sensitive of all familiar plants, being used extensively in bio~
detection methods.
VII.

EFFECTS OF 2,h-D ON COTTON.

In a study at the Texas Agricultural Experiment Station in
using the Stoneville 2B variety of cotton, it was found that 1 oz of

�could cause serious damage to all the plants in a 35-acre area if
distributed uniformly. Much lighter applications, however, resulted in
much foliage distortion without an appreciable effect on the set of bolls
or the seed cotton yield. Intermediate application rates produce a profound distrubance within the plant, cause chemical variations, and reduce
total yield.

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The quantitatively significant facts of the Texas study appear in
Table 3. The table has a column showing percentage reduction in weight
of the main stalk leaves. The development of leaves on the branches was
not affected as greatly. The main-stalk leaves developed normally only
when the plants were nearing maturity. The plants that had been treated
with the 10 and 20 ppm solutions produced longer branches. The vegetative
branches were affected more than the fruiting branches, perhaps a result
of the fairly early treatment so that plant recovery was significant here.
(See Table **-.) Leaf injury did not then necessarily lower the final '
yield.7 Table 5 contains data from another related study. It can be
seen from Tables 3 and 6 that amounts used in weed control, i.e., 20 to
80 oz/acre (1^-5 Ib/acre) would completely destroy a cotton crop.7
In a Mississippi study the least susceptible stage of cotton was
found to be after most of the bolls were already on the plant. With a
0.001 Ib/acre application there was no appreciable effect on the yield
of seed cotton even though it did produce significant injury to the
leaves. (See Tables 6 and 7 ) Moderate leaf malformations at the
.
seedling stage did not lower the yield, but a decrease in stem growth
did. Earlier contamination of the crop and greater severity of damage
result in a greater delay of crop maturity, 2,^-D damage has been shown
to be transmitted into the seed produced by affected plants.8
As the season advances boll weevils and worms become an important
factor. Delayed maturity of a cotton crop would subject it to attack by
these pests. Increased efforts in insect control would then be recommended to protect the crop,
A study at the State College of Mississippi regarding the relative
effects of 2,1uD, 2,4,5-T and MCPA, showed that on the Coker 100 wilt
variety of cotton, 2fk~.T&gt; had the greatest effect on reducing the yield.
In the first part of the season up till the blossom stage 2 , D damage
*^
will affect the yield of seed cotton. During'the blossom and boll stages,
the damage appears .in progeny seedlings. See Table k for data on these
subjects.9
The appearance of 2,*)—D damaged cotton leaves varies, of course, with
many factors, viz., dosage, length of time since treated, meteorological

�conditions, etc. The'leaves first begin to ruffle and roll at-thc'mff
Progressively more severe dfunti;jo results f.n an epinnstic effect. La
that grow on the plant after treatment arc narrow, deeply lobed, and
closely and thickly veined—~nn effect of the inhibition of the
meristem in the leaf. The stems swell and fprm galls as the cortex
Secondary roots are often formed. Lateral stems forming later are .
affected.10 (See Table 6 for treatment rates and their effects.)

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VIII. ATMOSPHERIC DRIFf EFFECTS OF 2,*UD.
In recent years there have been instances that involved 2,^-D .
from places of application to neighboring crops, notably cotton. In
Tennessee, cotton was injured by a fine liquid spray 2-| mi away. In
report from Texas in the summer of 19*1-7, £fh-.D injured cotton fields
found 15 to 20 mi from .fields dusted with airplanes. The airplanes i
have passed closer than this to those affected fields but the damage
the fields, was uniform, indicating that the dust must have traveled a
distance ojf at least 10 mi.11
According to a table in Phytopathology,5 water droplets about flw?
microns in'diameter can drift over three mi in falling 10 ft when the
•velocity of the wind is 3 mph. The dust particles used on the rice 1ft
Texas ranged from 4 to l6 microns in size and could have been released
from the leaky container into the air at altitudes of 100 to 200_ft wh»'€
the airplane was turning. With winds possibly up,to 10 mph the dust
have drifted even further than the 15 to 2Q.-»mJ, distance mentioned.
Reference !2 for further meteorological data regarding deposition
,
of small particles in different velocity winds. It is interesting to
that one of the weeds, Caperonia Palustria found in the rice fields, also often found unaffected among badly damaged cotton plants.
IX. EFFECTS ON SELECTED CROPS.
Legume crops while not as sensitive as cotton are generally subject'
to damage by 2 ^ . Application rotes of 1/2 Ib/acre generally control
,0
weeds in such species as ladino and white clover and lespedeza with on?..y
slight vegetative injury. Rates up to k- Ib/acre however will kill the£#'
legumes.
The tolerance of peanuts to 2,'uD is generally 1-|- Ib/acre although
slight damage will occur with no -reduction in yield. The hydrolizabl**
compounds "Sesone" and "Falone" are often applied to peanut crops with
good results. By the time the peanut plant appears above the ground, arf
extensive root system has already developed. The 2,J4~D type herbicide
(see earlier discussion concerning "Falone") that is formed by the

8

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�hydrolization then will not leach deeply enough into the soil to kill the
peanuts, but adequate weed control is affected. „
•
Common bean plants are sensitive to 2,4—D and are generally damaged
at.-a 1/2 Ib/acre concentration. A more sensitive reaction to 2,4-D by
common beans can be measured by observation of the nodule formation.
Concentrations of 0.07 Ib/acre totally inhibit nodule formation. The
nitrogen—fixing Rhizobium bacteria found in nodules can tolerate rates
of 200 Ib/acre and are not affected but do not live in the plant depriving
it of an important nitrogen source. See Table 1 for data regarding beans
and 2,4-D.

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Pea plants react to 2,4—D in much the same way as the beans do. Compared quantitatively, however, the vegetative reaction of peas is more
severe and the nodule reduction is less severe at identical rates of 2,4—D.
Clover and alfalfa react in a similar manner. 0.03 Ib/acre gave
slight injury to clover but reduced the nodulation percentage to zero.
0.003 Ib/acre reduced the nodulation of alfalfa by 30$. Another legume,
soybeans, seems to be tolerant _to 2,4-D up to rates of 2 Ib/acre.
-

^J

The grasses and monocotyledonous plants in general are quite resistant
to 2,4-D for specific reasons mentioned earlier. Corn for example is
generally tolerant to 2,4-D at rates up to 1^- Ib/acre. At this rate
injury to corn on sandy soil has occurred. If applied for pre-emergence
treatment on sandy soil heavy rains may result in injury. Varietal dif—
ferences in tolerance have been observed but are quite small. Better
herbicides than 2,4-D are available for controlling weeds in corn.
One-half pound per acre of 2,4-D applied in early spring increased
wheat yields due to weed kill in these varieties: Coastal, Knox, Atlas 66,
Atlas 50, Redhart, and Thome. Premergent applications on oats at the rate
of 0.6 Ib/acre increased yields due to weed kill in the following varieties:
Appier, Delta Red, and Carolina Red. Similarly, a barley crop is benefitted by 3/4 Ib/acre post-emergent applications; rice tolerates 1/2 Ib/acre
applications except at flowering time; pasture plants tolerate 1 Ib/acre
. applications; lawns tolerate 1 1/2 Ib/acre of 2,4-D; cane tolerates 1 3/4
Ib/acre; sorghum is tolerant to 1/3 Ib/acre when the plant is 4-12 inches
high but is more susceptible in. other stages of more rapid growth.
Certain garden vegetables are fairly sensitive to 2,4-D. 0.15 lb/
acre caused permanent damage to beets; 0.2 Ib/acre seriously damaged
spinach; 0.1 Ib/acre seriously damaged turnips. Although 0.3 Ib/acre
causes noticeable-damage on onions, it takes 2.0 Ib/acre to cause severe
damage. Tomatoes are more sensitive than cotton.

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�X*

METHODS FOR DETERMINATION OF

A method for detecting 2,H~D compounds on foliage by either chemical
or physical me.ans is of interest. Analytical procedures are given in
Appendix I. Chromatography and infrared spectroscopy would seem to be
the best methods to use. Table 8 gives Rf values of 2/^-D and 2,i|-,5~T
with different solvent systems for paper chromatography. The R^ value 'is
the fractional distance' a compound will •'move up a paper with the solvent *s
distance taken as the whole.
XI*
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SUMMARY.

'
2,4~D and a number of related compounds are systemic herbicides
capable of causing extensive damage to susceptible plants at fairly low
application rates. The auxin-like characteristics of the compounds make
this low-application high-damage effect possible. 2,^-D being an auxin
affects most greatly meristematic tissue in which growth and differentiation are taking place. The resultant appearance of the 2,luD affected
plant may be- twisted, have ruffled leaves, seriously malformed leaves,
split and malformed steins, or may die, depending on the dosage received.
Dicotyledonous plants in general are quite susceptible to 2,4-D.
Tomatoes, cotton, and some legumes are very susceptible to even trace
quantities of the chemical. Monocotyledonous plants are generally nonsusceptible to 2,}UD at rates of 1 Ib/acre or more. 2,'4-D generally
does not affect other living organisms at this dosage rate except for
-some bacteria.
When plant injury occurs, considerable interest is generated in
determining the cause of the injury. The methods given enable one to
characterize the 2 ^ and related compounds present in and on the plant.
,0

10

�REFERENCES

1. Staten, Glen; J. Am. Soc. Agron., No. 38 Pt. 1, p. 5^
2. Van Overbeck, J.; "Auxins"; The Botanical Review Vol 25 No. 2,
(Apr-Jun 1959).
J5.

Brown, Glair et al; La. Agricultural Exp. Sta. Bulletin k-26; ( 9 8 .
1^)
.
h. Klingman, Glen C.; Weed Control; As a Science; John Wiley &amp; Sons,

.Inc. (1961).
5. Tukey, H. B.; "On the Persistence of 2,^-D In Plant Tissue"; Science
112:282-3 ( 9 0 .
15)
6. U. S. Census of Agriculture, Florida Counties ( 9 9 .
15)

./

7. Dunlap, A. A., Engle, D. R.; "Responses of Cotton to 2,^-0" Texas
Agricultural Exp. Sta. Bulletin No. 713 CSep 1 ^ )
99.
8. Goodman, V. H.; "2,^-D Injury to Cotton" Mississippi Agricultural
Exp. Sta. Circular No . 185 .
•,
&gt;
9. Goodman, V. H.; '"The Yield and Progeny Seedlings Responses to Treatment with 2,^-D; 2,U,5~T and MCP"; Southern Weed Conference Sixth
Proceedings (1953).
. »
10. Magill et al; Air Pollution Handbook; McGraw - Hill Book Co. Inc
. (96.
15)
'
«

11. Dunlap, A. A.; "2,^-D Injury to Cotton from Airplane Dusting of
Rice;" Phytopathology Vol 38 Part 2 ( 9 8 .
1^)
12. Nou, Juri V., Capt, USAF; A Procedure for Estimating Downwind
Deposition of Small Spray Droplets; APGC~TR-6^66 (unclassified)

13. J. Am. Soc. Agrons 39 ( ) 52 ( 9 7 .
l:
1^)
™"
-l'i-. Games, Harry and Goodman, V.H.; "Responses of Cotton to 2,^-D";
Mississippi ^Agricultural .Exp. Sta. Bulletin
15. Lcder and Leder, Chromatography, Elsever Publishing Co., N. Y. (1957).
3.6. Spcctor, Wm. S.; Handbook of Biological Data; W. B. Saunders Co.,
Philadelphia 1956).
\
11

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O . f ^ l Y . f O W e 1 ^
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APPENDIX I
/

TABLES

Table 1. Effects of 2,k~D on Common Beans When Grown in Treated Soil.
Table 2. Cotton and 2fk~D Dust, Leaching in Soil by Rainwater.
Table 5. 2,*uD Applied as em Amine Salt to Stoneville 2B Variety Cotton.
Table h. The Yield of Seed Cotton From Plots Treated With 0.1 Ib/acre
of 2,^-D or 2,U,5-T at One of Four Stages of Plant Development Expressed
as a Percentage of the Average of the Untreated Checks.
ji
Table 5. The Effects of 2,luD on Cotton in a Study at Bpton Rouge.
Table 6. Responses of Cotton to 2,U«D,
Table 7. A Comparison in the Yield of Seed Cotton From Plots Treated in
the Seedling Stage With Three Rates of 2,4-D Expressed as a Percentage of
the Untreated Check.
/
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Table 8. Rf Values for 2,iM) and 2,^,5-T in Three Solvent Systems for
Paper Chromatography.
,

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�TABLE 1. EFFECTS OF 2 ^ ON COMMON BEANS WHEN GROW IN TREATED SOIL.
,D
Average No.
Nodules/Plant

i

2, UD Ib/acre

.

56.6

General Plant Reactions

0

Seed failed to grow

18.3

0

Seed failed to grow

9.1

0

IK 6

o

Seed grew, plant dwarfed

2.5

0

Secondary roots, cotyledons
malformed

1.1

0

Secondary roots, cotyledons
malformed

0.6

0

6 in. tall, secondary roots,
first true leaves

o.

6 in. tall, secondary roots,
first true leaves

0.075

0 .

11 in. tall, leaves normal

0.037'

10
.

11 in. tall, leaves normal

0.018

2A

11 in. tall, leaves normal

0.009

5.3

11 in. tall, leaves normal

2.3
^0

11 in. tall, leaves normal

-0.15

\

0.0

/

Seed failed to grow

Reference 13

TABLE 2. COTTON AND 2 ^ DUST, LEACHING IN SOIL BY RAINWATER.
,D
2,iu-D Rate
Ib/acre

1
0.1
0.01
Reference 3

Appearance of Plants After
2 in. of Rain
1 in. of Rain
Malformed

Normal
Normal

Normal
Normal
Normal

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TABLE 5. ' , ~ APPLIED AS AN AMINE SALT TO_STONEVILLE 2B VARIETY COTTON.
24D
Calculated
amount of
pure acid
equivalent
of 2,lk.D
applied
per plant

Applied
as ppm
IT C\

n«^u

solutions

by
dipping
one leaf

Reduction
in weight
of main
stalk
leaves

Injury

w

Og)
0.0

0
1
5
10
20

002
.0
0.01
0.02

0. Oil-

None
None
Mild
Significant
Severe

0

. ——.

Increased
Height
()
*
0
, ,
—

77

__^

700

, ito

27

.
—

1 oz
dosage
per X
acres*

,
—

38

70
35

^Assuming 20,000 plants per acre
Reference 7

TABLE *K THE YIELD OF SEED COTTON FROM PLOTS TREATED WITH 0.1 LB/ACRE OF
2,lt-D OR 2,11-,5-T AT ONE OF FOUR STAGES OF PLANT DEVELOPMENT EXPRESSED AS
A PERCENTAGE OF THE AVERAGE OF THE UNTREATED CHECKS.
Stage

2,lt-D
()
*

Seedling
Square
Early Blossom
Boll

16
53
32

79

Reference 9

15

2,^,5-T
W
64
91
83
82 '

�.TABLE 5. THE EFFECTS OF 2,4-D ON COTTON IN A STUDY AT BATON ROUGE,
0.1 ml of ppm Quantity 2 4 0 applied
,solutions
per plant (microgram)

Effects (Injury)

0.01

001
.0

None

0.1

0.01

None

0.5

0.05

2-3 leaves, normal in k weeks

10
.

0.1

4-5 leaves, recovery in 8 weeks

10.0

10
.

Deformed, no recovery in 8 weeks

25,0

2.5

Deformed, no recovery in 8 weeks

50.0.

'.5.0

Deformed, no recovery in 8 weeks •

Reference J5

TABLE 6.
Treatment rates of
pure acid equivalent
of 2 4 D applied
,~
(Ib/acre)

RESPONSES OF COTTON TO 2 4 D
,-.

Effect

0.1

Severe epinastic response in one day, stunted
plants for several weeks.

0.01

Similar to above, not as severe, branched profusely, many malformations.

001
.0

Very mild symptoms, complete recovery in one or
two weeks.

Reference

�TABLE 7. A COMPARISON IN TPIE YIELD OF SEED COT.TON FROM PLOTS TREATED IN
THE SEEDLING STAGE WITH THREE RATES OF 2,k-D EXPRESSED AS A PERCENTAGE OF
THE UNTREATED CHECK.
Rate Ib/acre

Yield %

0.1

16

0.01
0.001

68
99

Reference 9

TABLE 8. Rf VALUES FOR 2,4-D AND 2,4,5-T IN THREE SOLVENT SYSTEMS FO.R
PAPER CHROMATOGRAPHY.

Compound

2^
,D
2,^,5-T

Butanol,
Proponic
Acid, Water

0.83
0.76

Reference 15

17

Isopropanol,
Ammonia, Water

0.91
0.9^

Phenol, Water

0.67
0.80

�APPENDIX II
**

DETECTION OF 2^UD ON COTTON USING A GAS CHROMATOGRAPH
Cassilrs Method
De Vriesr Method
'The Acetonitrile Method
U.S. Department of Agriculture's Method
A Method for Obtaining 2,^-0 Esters From Plants
The Gutenmann and Lisk Method

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�THE CASSIL METHOD

i

In this (method) 100 gm of chopped foliage is extracted V.v- '
of 2:1 benzene/isopropanol solution by tumbling for 1/2-1 hr. '-K
is filtered arid the alcohol is removed by water extraction in A
10 ml of this extract is dried with anhydrous' sodium sulfate ^V
Nuchar Attaclay added and swirled for 30 sec. The solution i.«
once and injected.

DE VRIES' METHOD

100 grams of finely chopped material is extracted in a
Waring blender with koo ml of 3:1 hexane/isopropanol for 3 mini ''
mixture is poured from the blender cup into a separatory furmo! '•'•'
about 50 ml of distilled water through a funnel containing a #1"'"'
plug. When no further isopropanol can be smelled (six 100-ml w^ '
water), the solution is concentrated to a final volume of 100 fn I «
is passed through a 60/100 mesh Florisil column, with the samp I'1 '
washed then with an additional Uo ml of hexane. 10 ml aliquots- *'•'
analyzed by electron capture.

THE ACETONITRILE METHOD

.
The hexane extract referred to in the method by De Vries
tioned into acetonitrile by successively washing the hexane S&lt;"&gt;
with acetonitrile in a separatory funnel. Four 10-ml portion*
tonitrile are used for a 25-ml aliquot of sample. The pooled
extracts are then dried over sodium sulfate and evaporated toa stream of warm air. The residue is taken up in 3 ml of a
trifluoride solution. This solution is warmed in a boiling W
2 min continuously swirling. The methanol is evaporated and
is taken .up in hexane and the methyl esters injected into thematograph.

20

�U.S. DEPARTMENT OF AGRICULTURE'S METHOD

This method consists of blending 100 gm of chopped leaves in a Waring
blender for 3 min with 20 ml of 10$ sulfuric acid in ethanol, 150 ml
diethyl ether, and 50 ml of petroleum ether. The solution was decanted
and the leaf mass extracted 3 times with 100 ml of 3:1 diethyl ether/
petroleum ether. These combined extracts are washed with 100 ml of
aqueous ^ sodium bicarbonate. The aqueous layer containing the herbicide
is extracted 2 times with 50 ml of chloroform, the pooled extracts are
then taken to dryness. The residue is methylated with methanol—boron
trifluoride solution as previously described, the methyl esters taken to
dryness, taken up in petroleum ether and injected for analysis.

A METHOD FOR OBTAINING 2,4~B ESTERS FROM PLANTS

.'

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For obtaining the esters an aliquot of the ester extracts of the
foliage (from the U.S. Department of Agriculture's method) is concentrated
to near dryness. It is then put through a Florisil column using petroleum
ether to wash the sample in. The pesticide is leached with 100 ml of 15$
ethyl ether in petroleum ether. The leachate is concentrated to 25 ml
and washed, by shaking in a separatory funnel four times with 25 ml portions
of 80$ acetonitrile in water. The washings are .combined, 100 ml of water
added, and this aqueous solution back—extracted into petroleum ether using
3 teaspoonsful of sodium chloride. Ths petroleum ether layer is then dried
in sodium sulfate and again put through a Florisil column. The pesticide
is leached from the column with 100 ml of 10$ ethyl ether in petroleum
ether, concentrated to dryness, taken up in a small volume of petroleum
ether and injected into the gas chromatograph.

21

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�THE GUTENMANN AND LISK METHOD

In this method, 25 grains of chopped foliage is transferred to a
Waring jar, 1 ml of 85$ orthophosphoric acid is added and 80 ml of acetone.
The sample was blended for 2 rain, filtered through a coarse sintered glass /
funnel stopped with a glass wool plug. The glass wool stopper serves to
catch the plant solids.. The filtered (residue) is rinsed with two 20 ml
portions of acetone, each time compressing the sample with the bottom of
a 50 ml beaker to squeeze out the remaining acetone. The volume of the .
filtrate is reduced to approximately 75 ml and transferred to a 100 ml
volumetric flask. The...(beaker) sides are washed down with acetone and
these washings are added to the 100 ml volumetric flask. The final
volume is adjusted to 100 ml with acetone.
One ml of the acetone solution is transferred to a 10 ml volumetric
flask and evaporated in an air stream. 3 ml of methanol~boron trifluoride
reagent is added and the flask held in a boiling water bath for 2 rain with
frequent swirling. The flask is cooled, 1 ml of hexane is added and solution made up to volume with 2$ aqueous sodium sulfate at which time the
flask,is shaken vigorously for 30 sec. . The hexane layer (is) injected
for analysis.
*

22
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APGC-TRr-65-7
INITIAL DISTRIBUTION

1
1
1
1
.,1
2
2
2
1
2
1
2
2.
2
1
2
2
1
'1
1
3
1
1
2
2
1
1
6
1
1
.2

Dir ARPA
Hq USAF (AFCIN-3K2)
Hq USAF (DDR&amp;E)
Hq USAF (AFMSG)
Hq USAF (AFORQTA)
Hq USAF (AFRDDE)
Hq USAF (AFORZTS)
Hq USAF (AFORQ)
Hq USAF (AFORZTA)
Hq USAF (AFRAFC)
Hq USAF (AFXPD-NI)
Hq USAF (AFOSR)
Sec/AF (SAFRD)
Sec/AF (SAFOI)
OSD (OSD-CT)
OAR
AFSG (SCS-6)
AFSG (SCT»)
AFSC (SCCPR)
AFSG (RAND Liaison Off)
RTD (RTNW)
ASD (ASJ)
ASD (ASJT)
ASD (ASCPT)
ASD (ASUSR)
ASD (ASZFM)
ASD (ASZB)
FTD (TDEWA)
SEG (SETSF)
AFLC (MCSWI)
AMD (MRMPD)

2

\*s

2
3
3
'1
1
1
1
1
1
1
3
1
1
1
1
2
2
2
2
2
5
2
1
2
2
2
k
1
2
2
2
2

AMD (AMR)

2
2
2
1
5
2
1
1
3

2
CINCSAC (DPLBF)
1
MATS (Dir OPS)
1 AUL
1
AU (Warfare Sys Sch)
1
AU (Army-Navy Mil Advis Gp)

SSD (SSAPD)
BSD (Proj 75)
ESD (ESO)
AFCRL
TAG (DORQ)
TAG (DPLTR) '
TAG (DOOP)
TAG (TFW-R&amp;D)
SAG (SUP-3)

ADC (ADORQ)
USAFE (Dir OPS)
PACAF (PFORQ)
. OOAMA (OOY)
OOAMA (OOYP)
OOAMA (OOYPP)
OOAMA (OOYS) ,
OOAMA (OOG) .!!
OOAMA (OOYDP)
SAAMA (SANUSE)
ATG
ATC (TSOR) :
ATC (ATTAT-S)
3^15 Tech Sch (TS-OS)
il-520^CCR Tng Wg (DOTF-RD) .
Armed Forces College
Industrial Col of the Armed Forces
National War College
Medical Svc !J&gt;ch (Radiobiology Br)
USSTRICOM (J~5 Dir)
AFSC STLO I
AFSG STLO USNOTS
US Army Mat Command (AMC PM-NBC)
USA Foreign Science &amp; Tech Ctr
Edgewood Arsenal
Edgewood Arsenal (Commodity Eng Div)
CRDL
Combat DevcOommand
US Engr R&amp;D Lab (STINFO BR)
USA LIMITED WAR LAB
USA MUCOM
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USA Biological Labs
Desert(Test Ctr (AMCPM-DETI)
USA CBR Combat Dev Ctr

�APGC-TRr.65-7
i

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USNOTS (Code ltf)36)
US Nav Sch CMD
Dir MCLFD (Fire Spt Div) MCS
USMC (R&amp;D)
USMC Ln Off (USA Aviation Bd)
The Mitre, Corp
Research Analysis Corp
Univ Penn Irist for Coop Rsch
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�^.1"1^;fi,-.*.' ^ j t ^ f v V
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.'?&amp;

UNCLASSIFIED
Security Classification

DOCUMENT CONTROL DATA - R&amp;D
(Security claaaillcatlon ol title, body ol abstract and Indexing annotation mil fit be entered when thu overall report is c l a s s i f i e d )
\. O R I G I N A T I N G ACTIV/ITY (Corporate author)
2a. REPOR1 SECURITY C L A S S I F I C A T I O N

Air Proving Ground Center
Eglin Air Force Base, Florida

UNCLASSIFIED
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3. REPORT TITLE

THE EFFECTS OF 2,1»-D AND RELATED COMPOUNDS ON PLANTS
4- DESCRIPTIVE NOTES (Type ot report and Inclusive dates)

Final Report (July - November
Monroe, Frederick L, 2d Lt, USAF
6- REPORT DATE

7a.

TOTAL NO. OP

PAGES

7 fa. NO. OF R E F S

16

January
8 a. C O N T R A C T OR G R A N T NO.

9-e. O R I G I N A T O R ' S REPORT NUMBERfS,)

b. PROJECT NO.
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'•Task No.

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13- ABSTRACT

The effects of 2,*uD and related compounds on plants and animals, including information concerning the sensitivity of plants, physiological! action of the herbicides
characteristic appearance of affected plants, and methods of determining the herbicide on the plant are presented. 2 ^ 0 being the most characteristic compound of
,the group is discussed in greater length. It exerts its greatest effect in the
rapidly growing and differentiating plant tissues. Cotton is the most sensitive
major crop in the Northwest Florida area. One ounce of 2,k-D"evenly distributed
over 55 acres will seriously injure a cotton crop. For this reason, extreme care
should be taken during all herbicide spray operations a....d especially when such
chemicals as 2,^-D, "Silvex" and "Falone" are applied adjacent to cotton fields.
The use of mist-blower applicators should be limited to only those cases when
complete meteorological data and other information pertinent to drift control are
available and indicate absolute safety. Grasses being fairly tolerant to 2,^-D
are not injured by a dosage of 1 Ib/acre. Tolerance of other crops is given.
Six methods are given for the extraction of herbicide frdm a sample of foliage.
The characterization of the compound is then accomplished with a gas chromatograph.

DD

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01142
Westing, Arthur H.

Corporate Author
Report/Article Title Statement of Dr. Arthur H. Westing, Chairman, Biology
Department, Windham College, Putney, VT

JOUrnal/BOOk TltlO

Hearings Before the Subcommittee on Energy, Natural

Year

197

°

Month/Day
Color
Number of Images
DOSOrlptOn Notes

n

91

Alvin L Youn

9filed this item under the category
"Human Exposure to Phenoxy Herbicides and TCDD";
also included in these pages in the Statement of Dr.
Paul Kotin, Director, National Institute of Environmental
Health Sciences

Thursday, April 05, 2001

Page 1142 of 1180

�FFECTS OF 2,4,5-T ON MAN AND THE ENVIRONMENT
IEENVIR01
/15FF

HEARINGS
iBEFOKK TUB

SUBCOMMITTEE ON ENERGY, NATURAL
RESOURCES, AND THE ENVIRONMENT^
f

n

''( , - /

OF TIIE

" "-^COMMITTEE ONCOMMERCE/UNITED STATES SENATE
NINETY-FIRST CONGRESS
SECOND SESSION
ON
EFFECTS OF 2,4,3-T ON MAN AND THE ENVIRONMENT
AI'RIL 7 AND 15, 1JI70

Serial 91-60
Printed for tlic use of the Committee on Commerce

It*

U.S. GOVERNMENT PRINTING OFFICE
45-362

WASHINGTON : 1970

�76

AFTERXOOX SKSSIOX
Senator HART. The committee will be in order.
Resuming this afternoon, our first witness is Dr. Arthur H.
Westing. Dr. Westing is chairman of the Biology Department of
Windham College in Putney, Vt.
STATEMENT OF DR. ARTHUR H. WESTING, CHAIRMAN, BIOLOGY
DEPARTMENT, WINDHAM COLLEGE, PUTNEY, VT.
Dr. WESTTXG. Senator Hart, I consider it a privilege to be able to
testify before your committee. Actually, I am very pleasantly surprised that vou and your staff show such tolerance toward me
despite a fairly questionable record with respect to your state.
First of all', most of the year I lived in Michigan, I devoted to
spraying your forests with 2,4,5-T, and perhaps even worse, when I
left Michigan I took with me one of your most desirable natives as
my wife.
Senator HART. I don't know whether that makes an even trade or
nor.
Dr. WESTIXO. All the time I was listening to this morning's testimony and realizing how muddled the situation was with respect to
the medical and public health aspects and the legal and administrative aspects. T kept thinking that those aspects were crystal-clear in
relation to the aspects that I am going to try to talk about, and that
is the impact of 2.4,5-T on the environment.
It is sncli a difficult field to cope with because ecology is still
really in its infancy, particularly when it comes to the study of the
full impact of a toxic introduction to the environment.
To judge from the popular press, our nation is on the brink of
environmental disaster. Ecology lias achieved some sort of a mystical
significance to many people, and a whole new vocabulary has
emerged overnight utilizing that wonderful avant-garde prefix
"eco."'
Over and over again we are being reminded of our collision
course with "ecocatastrophe" leading to "ecodeath." We are told that
we have to really use drastic "ecotactics;" a Senator like you should
Ije using aggressive "ecopolitics." The whole world is being challenged to accept a protocol on "ecocide." And I suspect that psychiatrists are very soon going to be diagnosing "econeuroses."
Actually, the unhappy truth of the matter is that, there may well
be good cause for concern over the future of man's environment. It
is being assaulted from all quarters with a gusto that is hard to
grasp. Man has habitually ignored the impact that he has had on
the environment, the environment that all of us depend upon for our
well-being and survival. Western man has always considered himself
master of his surroundings. Until the present, with far smaller numbers and very ineffectual technology, this self-delusion made very
little difference.
But today we are introducing a great diversity of chemicals into
our environment in vast, continuing, and exponentially increasing
quantities. Among these chemicals, pesticides are worthy of particu-

�T

K.

lar scrutiny because of their potential ability to decimate certain
classes of living organisms, and thereby to 'upset the balance of
nature—to disrupt what the ecologist refers to as the "ecosystem."
I shall here limit my remarks to the potential dangers to the environment that might be expected from the excessive or otherwise
incorrect use of one such substance: 2,4,5-T.
As \ve have heard this morning, this compound has recently
gained a degree of notoriety owing to its massive military use in
Vietnam despite the suspected ability of it, or an associated impurity, to cause birth defects.
'I need not refer you to Thomas Whiteside's article on this subject
which really is a beautiful expose of the current legal, administrative, and other associated problems. (New Yorker, 7 February and
14 March 1970). Now, to speak briefly on the current use of 2,4,5-T,
it is one of a class of potent herbicides or plant killers, the one
preferred by utility employees, foresters, range managers, and farmers, and by our armed forces in Vietnam for the destruction of
unwanted woody vegetation. It is one of a class of growth-hormonemimicking herbicides whose close chemical relatives include 2,4-D,
MO PA. and Silvex. 2,4,5-T was developed during the earlv 1940's
(as a possible chemical warfare agent) and came into widespread
domestic use during the mid-1950's. In 19C4, some 13 million pounds
of 2,4,5-T were manufactured in the United States. About a million
of these pounds were applied to about 3 million acres of U.S. croplands, another million pounds were sprayed on perhaps 80,000 acres
of forest lands in Vietnam, and most of the remaining 11 million
pounds were presumably used domestically on an undetermined
number of acres of noncroplands. This morning we were vividly
reminded that a small portion of this is also used by home gardeners.
Now, these are the 1964 figures. Although I am not sure of the
current ones, I understand that the domestic use of herbicides in
general has been increasing at a compounded growth rate of 10 percent per annum.
•2,4,5-T is commercially available in a number of formulations of
which the most important are the oil-soluble esters and the slightly
less effective water-soluble amines. Whereas the amine formulations
are very low in volatility, some of the ester formulations are relatively high and others are relatively low. The low volatility esters
arc actually somewhat more effective than the high volatility ones,
but they are also slightly more expensive. 2,4,5-T is also available in
combination with 2,4-D, a mixture which is known domestically as
"brush killer" and by the military as "agent orange."
The 2,4.5-T is effectively applied either to the foliage of unwanted
woody vegetation from ground- or aircraft-mounted spray rigs, or to
their stems by a variety of techniques.
Domestically, it is very often applied highly diluted by oil or
water, although some domestic techniques of individual application
oill for strong concentrations.
fn Vietnam, it is aerially applied in totaly undiluted form.
Recommended broadcast dosages—these are domestic recommendations—range from one-half to three pounds of active ingredient per

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78

acre. At these levels of one-half to three pounds per acre, the 2,4,5-T
is quite selective, killing many species of broad-leafed woody plants
and sparing most grasses and conifers. At the high rates the military use in Vietnam—which is about 13 pounds per acre, together
with as much again of 2,4-D—it becomes far less selective and kills
a high proportion of the vegetation.
In their silvicultural applications, foresters do some aerial spraying, but often resort to individual application to unwanted trees.
However, in range improvement and in the control of vegetation on
rights-of-way, and in Vietnam, application is mainly or entirely
from the air.
Overall, the domestic applications average out to about one-third
to one-half pound per acre treated.
That is a very brief summary of the use of 2.4.5-T,
Now T would like to spend a few minutes on the potential dangers
from the use of 2,4.5-T. I am limiting my remarks, by and large, to
the dangers to the environment since the medical and public health
aspects were covered previously, and I understand will be covered
by subsequent speakers.
Senator HART. Doctor, as you leave the use section and before you
get into these potential dangers, can you describe for the record—I
think it has not yet been stated in layman's language for the record—
what the bush or tree or grass or area of earth surface looks like
when this is applied to it. you say 1 to 3 pounds an acre.
Dr. WESTTXO. That is right.
Senator HART. If you can in language describe for the reader and
me what it looks like. I frankly have not seen it.
Dr. WESTING. Stretching my memory back to the Upper Peninsula.
Senator HART. The beautiful Upper Peninsula.
Dr. WESTixti. I might interject here that a lot of pioneering work
in aerial forest spraying was actually done in Michigan. The leaves
on unwanted oaks or maples very rapidly turn brown, within a
matter of ?&gt; or 4 davs. Tn 5 days they start showing signs of shriveling up. They usually hang on that way for 6 to 8 weeks, and perhaps longer; so, one sees a lot of trees that have brown, shriveled up
leaves. If conifers are intermingled, they show no damage, so they
stand out like green thumbs, and a good bit of the forest floor stays
green: grasses and so on stay green, ferns and so on will turn
brown: pome plants stay green and others do not. depending upon
the type. What it looks like really in this country is as if fall had
just decided to come a fcwrinonths early.
Senator HAKT. How would you describe the same scene if there was
applied to it the 13 pounds per acre which you say is the current
application on the average in Vietnam ?
Dr. WivSTivr;. It is actually about 2r» or 2fi pounds. It is 13 of
2.4.5-T plus another 13 of 2.4-D.
Senator HAITI'. The picture you described
-•
Dr. WKSTIXO. Was for one to two pounds.
Senator HART. Of 2.4.5-T only ?
Dr. WKSTIXU. Right.
I havo not seen an area myself that lias boon hit this heavily. Init
I have seen pictures. Within a very short period of time, all the

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leaves look brown and shriveled up and within a matter of perhaps
two to three weeks most of the leaves drop off the trees, vines, and
shrubs.
This, of course, is the reason why the military spray these herbicides and sprays them in such heavy dosages, in order to get as
.rapid a leaf defoliation as possible. But in the process of getting
rapid defoliation, there is a high degree of kill, which is an
unhappy corollary. I am not sure if this is really intended: it happens, particularly in certain types of vegetation.
Subsequently, grasses, bamboos, and a variety of other weeds grow
back fairly rapidly. So. after several months you see lots of large
dead trees and then a very heavy new undergrowth.
Senator HAUT. You say the tree does die?
Dr. WESTIXD. Well, it depends upon the species, Senator Hart.
Mangroves would be killed bv one application in Vietnam whereas
Home other trees might not l&gt;e killed unless they were sprayed a
second time. A single spraying seems to kill about 10 percent of the
trees. There is a great diversity of tree species there.
I have flown over areas in southeast Asia that have been sprayed
once and it seems that roughly one tree in eight or 10 is dead.
If these were sprayed a second time 6 months later, perhaps two out
of three trees would be dead, or maybe even more.
Senator HART. Thank you.
Dr. WESTIXC. T wish now to touch upon some of the potential
dangers to the environment from the use of 2.4,5-T, and I am speaking again primarily domestically. The dangers can arise not only
from the '2,4,5-T itself, but also from its contaminants, (such as were
discussed at great length this morning), from its additives, (and
there are endless kinds of additives: wetting agents, emulsifiers,
stickers, penetrants. thickeners, humectants. spreaders, etc.). from its
carriers or diluents, (such as fuel oil. kerosene, seal oil), and from
its degradation products (or perhaps degradation products arising
from subsequent burning). All of these various possibilities I shall
lump together for purposes of my comments here, just calling them
•2.4.5-T.
The dangers from the use of 2.4.5-T need not be confined to the
site of application, but can be carried elsewhere by wind, either as
liquid or as vapor, or carried elsewhere by water, cither surface
water or ground water. Moreover, the potential dangers are not conliuwl to the, time of application, but last, of course, until the 2,4.r&gt;-T
degrades to the level of insignificance. Under wet and warm field
conditions, one of the advantages of 2.4,5-T is that it breaks down
within a matter of several weeks. 0 or 8 weeks perhaps. But under
dry and cool conditions, this may take well over a year. Furthermore, the rate of degradation in the groundwater may also be very
slow.
The dangers from the use of 2,4,5-T can result from damage to
plants, damage to animals, both higher and lower, possibly from
damage to microorganisms, and from direct and indirect combinations of these effects.
I shall elaborate very briefly on some of these possibilities.
The most spectacula'r effect of 2.4,5-T—when used as recommended
domestically—is, of course, on certain classes of plants, particularly

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but not exclusively the broadleafed woody vegetation. In selectively
destroying such plants and sparing others, the species composition of
the treated area is altered, the overall diversity of species is reduced,
and the total mass of living things is probably diminished. And such
changes are considered by ecologists to be an unstabilizing and
therefore detrimental influence on an ecosystem. In other words,
they make the balance of nature more precarious.
A properly functioning, relatively undisturbed ecosystem owes its
stability—indeed, its very integrity—to a highly complex set of
interactions amongst all of its many living and nonliving components. Nutrients cycle and recycle from the soil up through the
interlocking food chains and back again to the soil. Population
levels of the many component plants, animals, and microorganisms
are kept in balance by a staggering multitude of predator/prey,
host/parasite, and other long-established interactions of mutual
dependency.
As soon as a toxic factor such as 2.4.5-T intrudes upon this highly
complex, totally interacting system, a certain amount of the so-called
ecological buffering action (of the many inherent checks and balances) is lost, and things start going wrong. Erosion may be accelerated, particularly in hilly terrain and even more particularly when
streamside vegetation is killed. This effect, together with a reduction
in the total mass of the living component of an ecosystem inevitably
leads to a loss to the area of vital nutrient materials. Especially following heavy or repeated applications, the result is a steady decline
in the productivity of the treated ecosystem—something that may
take it centuries from which to recover.
On top of this there are all sorts of subtle things that can go
wrong. For example, a continuing supply of available nitrogen—one
of the elements essential to all life, and often in short supply—depends to a large extent on the presence of certain 2,4.5-T sensitive
plants, whose r&lt;v:ts play host to various microorganisms crucial to
this process.
Actually, there has been some evidence of this occurring in the
Pacific Xortliwest. where ponderosa pines are the crop tree and
alders arc being removed by 2.4.5-T as weeds, with a resulting loss
to the area of available nitrogen.
Additionally, the birds and other animals that depend upon the
2.4.5-T decimated plants for food or cover are placed at a great disadvantage and may be partially or even completely eliminated from
a treated area.
The direct toxicity of,2.4.5-T to most higher animals is known not
to bo very severe, particularly at the recommended rates of application. Ilowvor. that there is also potential danger in this regard is
suggested by its known effects on humans. The U.S. Department of
Agriculture categorize 2,4.5-T as "mildly" irritating to the skin in a
standard dermal response rating, and as "moderately" toxic when
ingested. In fact, one oan onote the following precaution from the
product label: "Do not contaminate irrigation ditches or water used
for domestic purposes:" nnd also the following warning: "Causes
irritation of skin and eyes."
Moreover, in aquatic habitats, the death of trout and some other
fish has been reported when 2.4.5-T is applied at recommended rates

�81

for weed killing. Certain crabs, shrimps, and mollusks are also
harmed by low concentrations of 2,4,5-T.
The adverse effects on wildlife are not limited to the ones already
alluded to. Some plants exposed to sublethal doses of 2,4,5-T (or
2,4-D) start producing abnormally high levels of nitrates (and in
some cases there has been a suggestion of even cyanide). It has been
noted with livestock that when such plants are ingested, the excess
nitrates are converted to nitrites, toxic or even lethal to the animals.
Another occasional result of 2,4,5-T application is that naturally
poisonous, and usually avoided, plants are made attractive to animals as a result of 2,4,5-T spraying; and then the animals feed on
these newly attractive plants ancf are poisoned.
The known ability of 2.4.5-T to cause chromosomal damage in
some plants and the fact that in some animals it, or an associated
impurity, results in deformed offspring when ingested during pregnancy, suggest that the plant and animal populations thus affected
will be less able to cope with their environment.
All of these debilitations that I have been cataloging, and additional ones that I have not. do harm not only to the affected species,
but, of course, thereby also to the ecosystems of which they are a part.
Since man is also a part of nature, I can bring out here once
again for emphasis that there is strong reason to suspect that 2.4.5-T
or an unavoidably associated impurity, the dioxin we have been
hearing about this morning, 2,3,7,8-tetrachlorodibenzo-p-dioxin (or,
by the way. a dozen or so closely related compounds all coming
under the name of dioxin). are now known to be highly terato^vuic.
In other words, they result in malformed offspring when ingested
during pregnancy. Tjntil this issue is clarified. I think it should go
without saying that the use of 2,4.5-T both domestically and in Vietnam be restricted to locations and amounts that would preclude its
possible human ingestion.
Well, let me now make a few concluding remarks.
Senator HART. Doctor, I think it would be wise if we interrupt
briefly for a recess. That was a signal that sounded for a vote. I
think this is the time to suspend.
(Short recess.)
Senator HAKT. Doctor, with luck we will finish before there is
another vote.
You were just about to begin with your conclusions.
Dr. WESTING. It is possible that I have been painting somewhat
too grim a picture of the domestic use of 2,4,5-T. But I have no particular fears that detailed exposition of its safety and benefits can be
left to the herbicide manufacturers and others. So, I figure that
what I am describing here from the environmental standpoint is one
side of the picture, and let the manufacturers tell us the other side.
Senator HART. Let me react to that, but very briefly. It is not
inappropriate or a matter of surprise, nor in my book, should it be
the basis of criticism, if the manufacturer of the"product describes it
in glowing terms if society and its government permits him to
market it. If those responsible for the protection of the health of the
society conclude that he can market the product with those claims,
then why get mad at him? Why don't we get mad at the society's
institutions?

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Dr. WF.STIXO. I agree.
Senator HART. You can't have it both ways, if I make myself
clear.
Dr. WESTING. Yes. I certainly am in full sympathy with this. I
think the harden falls upon our regulatory agencies.
Senator HART. Clearly.
Dr. WKSTIXG. I don*t think Dow is the culprit here at all. It is
FDA and USDA. and so on.
Senator HART. This goes beyond the immediate product line we
are talking about. This goes to the marketplace and the role of
society in protecting itself, establishing regulations where needed,
and enforcing them as established.
Dr. WESTING. I would certainly have to admit that the vast successes of productivity upon which our nation's current ailluence
hinges, depend to a large extent upon the use of pesticides such as
•2.4.5-T. And it seems clear that the use of pesticides will continue,
perhaps even unabated, without a highly unlikely downward trend in
our population, and. even more particularly, in our collective desires
and demands.
However, the time scorns to be fast arriving when certain precautions must be taken so as not to overload our environment with
such potent pollutants. A number of suggestions are thus in order to
forestall the need for a basic change in our way of life.
First of all. research efforts should be expanded on several fronts.
Effective cultural and biological controls of pest species should be
sought and developed with renewed vigor. With respect to the pesticides themselves, highly selective and rapidly degrading ones should
be aimed for.
In the light of the current -2.4.5-T affair. I must add here that all
pesticides, existing and potential, must be rigorously tested prior to
their general release for possible toxicity. carcinogcnicity. teratogcnicity. and mutagenicity to humans: and additionally, for possible
adverse effects on livestock, on wildlife, on game, on fish, and on
other components of the ecosystem.
With respect to 2AJ&gt;-T, its use—in my considered opinion—must
be limited to areas remote from human habitation. Control of vegetation on rights-of-way must be regulated with particular care since
utility, transportation, and other rights-of-way are by their very
nature frequently close to civilization. I want to emphasize here,
Senator Hart, that one of the major uses of 2.4.5-T—one of its preferred uses—is in woody vegetation control along rights-of-way.
This is a major place where 2.4.5-T is likely to impinge upon human
habitation, to come in contact with civilization.
Broadcast applications, where safely remote from human habitation, should not exceed 3 pounds per acre: and where spraying covers
extensive areas, unsprnycd zones should be loft as oases for wildlife,
and so forth.
Repeat applications should be controlled, perhaps to intervals of
5i years or more. Aerial broadcast spraying should be avoided where
possible, and alwavs avoided near bodies of water, in favor of spot
applications, or individual applications.
In those areas where aerial spraying is permissible, the highly volatile (though cheaper) formulations should be banned completely.

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The low volatile formulations are not only more effective as herbicides, but they are also much safer with respect to the problem of
drift and volatilization.
Aerial spraying should be confined to relatively windless periods
(wind speeds of less than 5 mph) and to air temperatures of less
than 85 degrees. Only nozzles equipped with course sprays should be
used. The cleaning of spray equipment or the dumping of excesses
near lakes or streams must be avoided; and getting rid of the empty
cans and so on&lt;should be limited to sanitary land-nil dumps or similarly safe locations.
To insure all of the above, State and Federal regulations should
be tightened both for manufacturers and users, and educational
efforts increased with the aim of minimizing unnecessary or excess
application. Our flagrant misuse in Vietnam should be halted immediately (sec, e.g.. my article in the Friends Journal of 1 April 1970).
Finally, I wish to stress, once again the complex and as yet little
understood nature of our environment. The study of ecosystems as
such is still in its infancy. And since hormonal herbicides have been
in general use now for only two decades or less, we simply are not
yet able to predict the full range of potential disasters that their
unrestricted use may inflict upon us and all other living creatures
with which we share this small world.
Senator HART. Doctor, for all its brevity, this is a very helpful
statement.
I have a couple of questions that I would like for you to react to.
You tell us in dry and cool conditions it may take well over a
year for 2,4,5-T to degrade. I think you were here this morning. The
Department of Agriculture is not in agreement with that statement.
Can you give us some evidence for your statement, or refer us to
sources that are in agreement with your statement?
Dr. WESTING. To my knowledge, there has been'-precious little
research done on the life of 2.4,5-T in the environment. I am aware
of one study that was done in a forest environment in which it was
shown that 2,4,5-T degraded to insignificance in a matter of several
months, as I recall.
On the other hand, it has been well established, and it is clearly
known, that 2,4-D—a compound similar to 2,4,5-T—degrades much
more rapidly than 2,4,5-T. It has been demonstrated a number of
times that under dry conditions, 2,4-D can persist in the environment and have detrimental effects for as long as a year or a year
and a half after application. From this I infer that 2,4,5-T, which is
more persistent than 2,4,5-D, would have at least a similar life under
dry conditions.
Senator HART. Then, adopting your reasoning, it would mean that
under those conditions, 2,4.5-1 might be found on food that is
served months after the spraying of the crop; is that correct ?
Dr. WESTING. I have no direct information, but one could surmise
that this could happen. This is a possibility.
Senator HART. 'Whut would you think the possibility of 2,4.5-T's
capacity is to persist within the organism, plant or animal, which
had ingested it, including the human?
Dr. WESTING. I have no first-hand knowledge on this whatsoever;
so I prefer not to try to answer it.

�84

Senator HART. You would agree that it is impossible to say it is
not possible?
Dr. WESTING. The likelihood is there. As far as I know, it may
persist, or even build up in the human body. Some other chemicals
that arc fat soluble (as are the ester formulations of 2,4,5-T) are
known to deposit and be stored in the fatty tissue of humans; so, it
is highly possible that 2,4,5-T does this, but I simply do not know
whethe/it does or not.
Senator HART. You suggest that use of 2,4,5-T be limited to areas
remote from human habitation, and that it should be restricted in
other respects. Does that mean that you would feel that Dr.
DuBridge s suggestion that pesticides be deregistered for food use,
assuming there can be no tolerance level set by FDA doesn't go far
enough ?
Dr. WESTING. '2,4.5-T as it is commercially available with its
impurities, is a s-tbstancc that should not have any food tolerance at
all. It should have zero tolerance, at least given the current state of
knowledge.
Certainly, the suggestion made this morning by— I think it was
Mr. Well ford — that its use should be curtailed severely, or suspended until we clarify this whole issue is one that I fully support.
I think that 2.4.5-T is probably a safe chemical to use at the low,
recommended doses in areas remote from human habitation. I don't
think it need be banned under such conditions in the forest environment. or on range lands.
O:; t!&gt;o other hand, along power line rights-of-way. railroad
rigi.rs-of-way. and so on. that get near houses, I think there should
be severe restrictions.
Senator HART. What about proximity to crops?
Dr. WESTING. Food crops?
Senator HART. Yes.
Dr. WESTING. I think that certainly for the time being, it should
not be registered for use on food crops *and not be used near them.
Senator HART. In these areas that you have described where 2,4,5-T
has been applied you have said that some of the birds and animals
that depend on the plants that have been destroyed may be eliminated. Which birds and which animals are likely to be affected?
One way to answer that I suppose is any that are in that area, but
I am trying to find out if some are and others are not affected.
Dr. WESTING. I wish I could give you some spectacular answer
about bird X or Y having become extinct as a result of the use of
2.4,.VL\ but I cannot. I can quote a recent statement made by a British authority on pesticides, Dr. N. W. Moore, director of the Monks
Wood Experimental Station in England :
The use of 2,4-D and 2,4,5-T to control scrub by roads and in woods reduces
the essential habitat of almost all British land birds, which, because they are
survfvirs o* the original forest faun.11, are sMH dependent on trees and bushes.
(Advances in Ecological Research 4:108;

To judge from this statement Dr. Moore is concerned over the fate
of the native British birds as a result of the routine use of these herbicides.
In this country there is an extensive program over many tens of
thousands of acres in the West of sagebrush control in which herbi-

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cides of this nature arc used, primarily 2,4-D. There is some evidence that the sage grouse population has been depleted: at least the
hunters are not as happy as they used to be.
I have to warn you, Senator Hart, this is one area where the herbicide proponents will jump up and say that there are a number of
clear cases where the use of herbicides has actually benefitted wildlife populations.
Senator HART. I made an interjection earlier to say that if we are
jroing to get mad at somebody let's gel mad at ourselves first of all
as a people for not recognizing dangers and setting down the laws
that will prohibit the marketing of certain things, but equally true,
of course, is that the producer is obligated, absent any explicit regulation, to make truthful representation about its product—again, I
am thinking not of chemicals alone but anything—and report factually the experience that has come to his attention to whatever
public agency there is that is expected to make the judgment for all
of us as to whether that product in fact should be marketed. So. if
they jump up and explain it is good for us, I hope, they will not do
•jo unless they can explain why.
You noted, among other things, in your conclusion that we should
expand research, attempting to develop other controls of pests. What
development do you imagine would be fruitful ?
Dr. WKsrrxo.' Well, the main thrust of alternatives to the use of
insecticides lias been to introduce predators or diseases of the insect
pests. This same approach can also be used with herbicides such as
:&gt;.4.r&gt;-T. Plant pests arc a little less amenable to this sort of an
approach, but one could push ahead on research on possible virus
diseases or fungus diseases or insect enemies of weed species.
I am familiar with one success story in this regard. A serious
weed in the Northwest is St. Johnswort. and a beetle (Ghrysolina)
has been introduced from Australia that feeds on (lie'St. Johnswort,
in a highly successful alternative to chemical herbicides. This genoral type of approach should be exploited to the greatest extent possible.
There are all kinds of other possibilities. Just in forestry, for
example, closer spacing of crop trees shades out certain weeds. You
ran go back to a greater emphasis on some of the mechanical methods that are now avoided because of the high cost of labor: mowing,
weeding (pulling out the weeds or cutting them down), burning.
Flamethrowers are used in certain instances and even controlled
(ires. These methods have a much more selective effect on the actual
weed and a minimum of lasting untoward side effects.
If chemicals are to be used, the forester's approach of individual
application is far preferable to the utility and range manager's
npnronch of broadcast spraying from"the air.'
'So. there are a variety of alternatives available. With just the
rlijrhtest amount of urging, the, slightest realization that there is a
necessity to worry, these alternatives would at least be explored. In
t!i&lt;&gt; past it had never even been realized that there were possible ill
ride effects to the use of herbicides.
Senator HART. Now. you have lectured us quite thoroughly on the
dangers inherent in changing the ecological pattern. Yet every one

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86

of these alternatives that you talk about suggests similar dangers
and some additional ones.
The Australian beetle is not native to the Northwest. I take it, but
you are going to bring Australian beetles in. The flamethrower is
not really an altogether acceptable
Dr. WESTING. There is a history of introducing something to
combat a pest and thereby introducing a worse pest, so there has to
be some very careful preliminary testing and evaluating before this
approach is'used. With this in mind, it is safer to use something like
a virus than it is to use something like an insect or a fungus because
the virus one will be far more host-specific and therefore will not
switch to an alternate host after it does its job and then become a
pest in its own right. This is a danger that has to be kept in mind.
With regard to the pesticides, I suggested that we keep searching
for much more highly selective ones. The problem with 2.4.r&gt;-T is
that although selective in a certain sense it still is relatively unselective and kills lots of things that you do not want it to kill. This is
the sort of thing that has to be watched out.for.
Senator HART. I must admit that I got the impression clearly this
morning that the existence of a realistic alternative to some of these
things might help to convince the Department of Agriculture to
take action: that is if they knew they had a realistic alternative,
maybe the evidence which the Department now says is not sufficient
to alarm them might have higher credibility.
I don't know whether I make myself clear.
Dr. WESTIXO. Yes; that is why it is important to mention that
there are possible alternatives or at least that a goodly research
effort should be aimed in that direction, to provide possible alternatives. We have come to depend upon the chemicals to such an extent
that I think other possible control methods have become less interesting.
Senator HART. T think it should be said, and not necessarily as a
direct criticism of anybody, but humans are humans and if there is
some acceptable alternative for what would otherwise be a decision
that would put a lot of heat on the fellow making the decision, it
would be much easier to make and somewhat unconsciously perhaps
the existence of an alternative might change the attitude of some of
these individuals.
Mr. Bickwit.
Mr. liioKwiT. Part of your evidence for the persistence of 2.4.5-T
under certain conditions' for over a year stems from experiments
establishing the persistence of 2.4-D. I'think for the record we ought
to have some reason why you can jump from evidence of the persistence of 2,4-D to conclusions about the persistence of 2.4.f&gt;-T. Can
you meet the argument that the 2.4-D evidence might show that 2.4D is just more persistent than 2.4,5-T?
Dr. WESTIXC,. No. I think one could be on completely safe ground
in sa;ving that 2,4-D is considerably less persistent than 2,4,5-T. 2.4D will degrade under normal, moist environmental conditions in a
matter of weeks. 2,4,5-T is perhaps twice as persistent. There are a
lot of studies to show that 2,4-D degrades more readily than 2,4.5-T:
lots of short-term experiments have shown this. I am not familiar

�- ....... 87

with any definitive long-term 2,4,5-T studies. It is very reasonable to
assume that as long as 2,4-D will, under dry conditions such as you
find in Idaho, have harmful effects on crops a year or more after use
that 2,4,5-T would also.
Senator HART. Doctor, thank you very much. It was a helpful
paper.
The signal a few moments ago indicated another roll being called
in the Senate. I apologize to Dr. Kotin, but we will have to take
another recess, and I will be back just as soon as I can get on the
roll.
(Recess.)
Senator HART. The Committee will be in order.
Our concluding witness on this first day of hearing is the Director
of the National Institute of Environmental Health Sciences, Dr.
Paul Kotin.
STATEMENT OF DR. PAUL KOTIN, DIRECTOR, NATIONAL INSTITUTE
OP ENVIRONMENTAL HEALTH SCIENCES
Dr. KOTIX. Mr. Chairman, I am privileged to be here today
engaging in the practice of one of my most pleasant responsibilities— that of discussing the programs and plans of the National Institute of Environmental Health Sciences of which I am Director.
Our Institute is a newcomer in the executive branch; we have been
in existence since 15)06. achieving the status of National Institute of
Environmental Health Sciences only in January 1969.
This activity started as a small segment of the Department of
Health, Education, and Welfare's effort in environmental health in
response to recommendations made by several public advisory committees during the late 1950's and early 1960's. These .committees—
starting with one chaired in 1958 by Dr. Stanhope Bayhe-Jones and
concluding with one headed in 1965 by Dr. Detlev W. Bronk— repeatedly emphasized the necessity of establishing within the Public
Health 'Service an organization dedicated to performing fundamental research into the real and potential effects of human health
wrought by a rapidly changing environment.
The decision of the Surgon General in 1966 that this research program be located within the National Institutes of Health—that Federal agency responsible for building the Nation's base of fundamental biomedical, health-related research— made clear the mission
envisioned for our program. That mission was and is :
F'irst, to determine the magnitude and significance of the hazard
to man's health from long-term exposures to low-level concentrations
of chemical, physical, and biological agents in the environment; and
second, to elucidate the underlying mechanisms of adverse response
with the hope that principles and generalizations would be identified
to provide a scientific base for criteria upon which control agencies
could set standards for protective and preventive measures.
During the present (1970) fiscal year, Congress and the President
have authorized $17,730,000 to be expended in the conduct of this
program.
Since you may be familiar with other programs of the 'National
Institutes of Health, I would like to take just a moment to point out

�f
K.

88

to you some ways in which we are similar to other parts of Kill
and some ways in which we differ. I might preface this by saying
that we are similar to other NTH research components in more ways
that we are different.
Like the other research institutes of NIH, our mission reflects two
very important principles of operation: (l)We are in business primarily to add to the fundamental knowledge and understanding of
environmental agents which as biomedical hazards immediately or
ultimately affect human health.
In other words, we are concerned about the what and how of
health effects first and foremost in human beings. That we must also
understand that what and how of the complex constituents of our
environment in order to perform the primary task is obvious.
Nevertheless, it is the results in humans which is of overriding
concern to us. M) Tho responsibility for taking direct action to control or eliminate the hazards which we must identify resides in other
components of HEW.
I hasten to emphasize that we do not consider our job clone until
our findings are made available to the appropriate components of
Government. To accomplish this, we maintain effective, close, and
continuing relationships with the Environmental Health Service, the
Food and Drug Administration, the Department of Interior, the
Department of Agriculture, the Federal Trade Commission, and
other agencies with control responsibilities.
The reasons for the distinction between fundamental research and
co-^rol powers are, I think, important. First, the urgency in the
need for control measures requires research directed to answering
today's questions with today's techniques.
There is. however, an equally, or perhaps more, important need
for research directed to questions having long-range implications
extending for decades and perhaps even generations into the future.
It is in response to this need that our Institute's program is
designed.
While techniques frequently used in attacking these two sets of
questions are similar, the orientation and end points stand in sharp
contrast.
Second, freedom from control activities permits us to devote our
total effort to research.
Third, control activities are performed by experts in an environment in which the guidelines for operation are completely dedicated
to this responsibility.
Fourth, our relationship with industries, communities, and individuals is ono based exclusively on scientific grounds rather than one
of regulation, monitoring, and enforcing.
Finally, our inputs to control agencies are objective and provide
an impartial basis for the very real practical considerations which
must be faced in formulating and inaugurating control measures.
As noted, the fruits of our work are promptly forwarded to
appropriate Government agencies for use in the pursuit of their mission with virtual simultaneous publication in professional journals
rather than in the popular press.
This practice assures that our findings are subject to the scrutiny

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89

and critical review of other researchers who have an opportunity to
i perspective for you.
I would now like briefly to tell you in somewhat greater detail
some of the things we are"doing, why we are doing them, and how
we come to be involved in the resolution of the problem which is the
subject of these hearings.
Speaking quite broadly, the NIEHS program attempts to employ
a wide spectrum of scientific disciplines and bring them to bear on
real and potential human health problems resulting from:
1. Changes in the makeup of the environment in consequence of
technological progress and industrialization;
2. Changes in the size and characteristics of the population; and
3. Changes in the character of interactions between these two.
In order to best understand the significance of changes in the
makeup of the environment, we employ the disciplines of analytical
and synthetic chemistry, pharmacology, and of biophysics.
In "order'to better understand our changing population and the
subtle interactions of new and changing environments on people, we
employ the sciences of epidemiology, biometry, pathology, nnd toxicology.
In order to establish the mode, and mechanisms of interactions, we
employ all categorical divisions of scientific inquiry with special
emphasis on comparative biology to assure maximum relevaiuv of
research data to man.
These varied resources and methods have so far been brought to
bear in programs studying the potential health hazards of:
Natural products including fungal contaminants of food; fibers
and polymer dusts, asbestos and nberglas; alpha radiation; trace
metals (such as lead) and their compounds; hydrocarbons and their
reaction products; tobacco smoke; and pesticides and pesticide
synergists (includingherbicides).
" In all of these studies we are concerned with the effects of longterm exposures to low levels of concentration because these are the
usual characteristics of exposure during life in the environment we
have created for ourselves.
Effects are likely to be gradual in appearance, and most commonly
the result of interactions of numberous agents combining in additive, synergistic, or antagonistic manners.
To dissect these complexities we must identify interactions at all
levels from the intracellular organelle to the whole organism.
Our goals include determinations of threshold for response, effects
of repetitive exposures, effects of storage of the agents in living
organisms, and the roles of such host factors as age, sex, antecedent
or concurrent illness, nutrition, behavioral characteristics, and genetic make-up.
It may seem that our approach is somewhat complex, but it must
IK; so in order to resolve the complex problems wrought by the
changes in our environment intrinsic to technological progress.
We have attempted, in the process of establishing the program of
the Institute during the past 3 years, to maintain a measure of flexibility amid this essential complexity to provide for response to

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90

unanticipated problems. Our current efforts in response to concern
over the widening use of herbicides is in a way a case in point.
You are aware, I am now certain, that the recently completed
study which revealed information about the toxicity of the herbicide
2.4,5-T, in fact, was initiated by the National Cancer Institute in
196:5.
As indicated earlier, our Institute was not in existence at that
time. However, I was the scientific director for etiology in the
Cancer Institute at that time, and along with members then and now
on my staff played a leading role in the initiation of the research
contract with Bionetics Research Laboratories, Inc., which yielded
the information under discussion.
Very briefly, that study was undertaken primarily to identify any
potential carcinogenic (cancer causing) or tcratogenic (birth defect
causing) agents in a wide variety of pesticides and allied compounds
in commercial use.
We also anticipated that the study would provide data on which
to develop improvements in pur methods for identifying carcinogenic agents and hopefully identify any correlations that might
exist between the carcinogenic and teratogenic capabilities of single
specific compounds.
Pesticides were selected for inclusion in the study on either of two
bases; First, a projection of the potential extent of their use in
terms of their utility in the community; and: second, a judgment as
to potential carcinogenicity by virtue of chemical structure or metabolic fate.
In consequence, some 86 pesticidal products—including insecticides, fungicides, and herbicides—were subjected to controlled, longterm studies on mice. As had been intended from the start, the study
continued through the 1060's.
In the interim, the then Division of Environmental Health
Sciences was established, and I was asked to become its first director. In agreeing, I was granted approval to take with me one or two
key staff members—scientists, as it happened—who had also been
associated with the Bionetics contract.
Since intensive programing and developmental responsibilities
faced my staff and me during the first years of our Institute, we
were quite satisfied to leave the management of the Bionetics pesticide study in the able hands of our successors in the Cancer Institute. Furthermore, it should be recalled that the one major basis for
the study was quite clearly related to the mission of the Cancer
Institute, the identification of cancer-causing agents in the environment.
Upon completion of the study in early 1069, the Cancer Institute
released the results of the study. The results of the teratogenic studies were released to the Mrak Commission immediately as they
became available. The popular press took intense interest in the findings reported, and pressures developed for more complete information on several of the pesticides included in the study.
The herbicide 2.4.5-T came under special scrutiny because its use
is especially widespread, particularly in military operations in Vietnam. Word that the Bionetics study had shown this chemical com-

�91

pound as "causing significantly more deformities than expected" was
especially alarming in some quarters.
Dr. Endicott, then director of National Cancer Institute, requested
that NIEHS staff familiar with the study in question, and also
familiar with teratogenicity and pesticide chemistry generally, be
assigned to data analysis and interpretation. NIEHS assumed sole
responsibility for the statistical analysis of the very large volume of
data.
During the early stages of the now public discussion, it was
pointed out by the Dow Chemical Co., a major supplier of 2,4,5-T,
that the materials used in the Bionetics study were significantly different than those which had been supplied by Dow since 1965.
It is certainly true that the 2,4,5-T used in the study contained
significantly larger amounts of an impurity, dioxin. This impurity is
highly toxic and its presence occurs incidental to minor alterations
in the reaction conditions during the manufacture of 2,4,5-T.
Dow Chemical Co. scientists contended that it was the dioxin
derivative rather than the 2,4,5-T which had caused the deformities
in test animals. A sample of the original 2,4,5-T used in the Bionetics study was analyzed nnd was found to contain 30 parts per million of this dioxin compound.
In consequence, it became necessary to restudy the situation to see
whether the virtually rio-longer-existmg impurity in 2,4,5-T could be
Ill-Id responsible for the adverse effects.
In order to verify the possible role of dioxin, NIEHS brought its
available resources to bear and undertook an accelerated program of
research.
Pure 2,4,5-T—and by pure, I mean that which is now in the marketplace with a dioxin concentration of less than one tenth of a
part per million—has been made available to us and recently we
received the dioxin in pure state so that experiments can be repeated
with the pure material, as well as with a combination of the two
ingredients.
Those studies are now underway. As indicated in prior discussions
with the subcommittee staff, the results of this research are not yet
.'iiiplcte. At such time as they are, in the very near future, we will
v pleased to supply them to this committee.
I would be happy at this time to answer any questions of the committee regarding the mission of NIEHS or the circumstances lead':".« to our current study of 2,4,5-T.
Senator HART. Thank you, Doctor. It was thoughtless of me—I
j-nnild have suggested, since you commented on having a sore throat
ivforc, that you not read the statement, but merely put it into the
TM'Ol'd.

15ut I think as long as you were able to get through it, it helps all
f us to hear it, rather than waiting for the printed record.
( ) n this business of the study, do you Know when the National
('.nicer Institute received its first data from Bionetics suggesting
::.at 2.4.5-T was teratogenic?
Dr. KOTIN. I can't tell you offhand, but I would be very happy to
_vt it for the record, sir.
. The information was subsequently received for the record:)
45-362—70-

7

�jr.

92
"In June of 1966, we received the first data indicating that 2,4,5-T administered by injection at a dose of 113 rag/kg of body weight produced teratogenic
effects. In May of 1968, data indicated teratogenic results from oral administration of 2,4,5-T at a dose of 113 mg/kg of body weight."

Senator HART. We would appreciate that, and it will be made a
part of the'record. I am under the impression that it was sometime
m 1066. In a sense I guess that's about the time you departed the
premises?
Dr. KOTIX. Exactly.
Senator HART. Let's assume that the date is June 1966, that being
the time the first data was received from Bionetics by the Institute.
Do you recall when the final report came ont ?
Dr. KOTIX. Yes, the final report, in 1009—late 1968 and early
1000, as I recall. A little over a year ago. as I recall.
Again, I can't be sure of that, but I would be pleased to get the
exact date. I had left the Institute.
(The information was subsequently received for the record:)
"Hionetics supplied a draft "final" report in September of 1968. Questions
raised by NIH required additional work by Bionetics and subsequent revisions
of the report. Bionetics completed this work and submitted a truly "final"
report in September of 1969."

Senator HART. The NIEHS report—when did that come out ?
Dr. KOTIX. The final report was last fall, when we were providing
the results of our statistical analysis, and the data on the tcratogenicity to the Mrak Commission.
Senator HART. If it develops that the June 1066 date is the time
that the National Cancer Institute got its first data from Bionetics,
and the final report by NIEHS came out in the fall of 1969, why in
the world did it take so long to come up with the information for
that final report ?
Dr. KOTIX. I really can't answer that, other than to say that at
the time the National Institute of Environmental Health Sciences
was asked by Dr. Endicott to provide the statistical and analytical
competency for the review of the data, the work was done very
promptly. In fact, we didn't even wait until the end of the report to
make the information available to the Mrac Commission.
As each little increment of information that represented a part of
the total became available, this was made immediately available to
the Mrak Commission, and the Food and Drug Administration.
Senator HART. I am trying to get these dates clearly fixed, if I
can. You state that NCI released the results of the studv in early
1969. Was this the preliminary report of Bionetic's findings i?
Dr. KOTTX. No, sir; this. I think, represented the first report in
which conclusions were published, both in the scientific literature
and in the Journal of the National Cancer Institute, as well as made
available to the various responsible government agencies.
The really important aspects of the conclusions, the necessity for
voluminous work—there were some 86 compounds—the National
Cancer Institute justifiably felt that in-house staff should at least on
a random basis review the data. There was much, much new information that heretofore had been unknown. And just the histological
review of the slides from the autopsicd animals, the statistical analy-

�93

sis of data from a scries of experiments in which multiple species
were used, multiple doses were used, were terribly time-consuming.
So that all I can do is vouch for the commitment of resources it
took from the National Institute of Environmental Health Sciences
to do its little share, provide its little share of the total.
Senator HART. Doctor, I am going to ask Mr. Bickwit to continue
with these questions. We have reviewed them prior to the hearing,
and I will remain, using the time to read a memorandum that
explains what this vote, that was just signaled is all about. I hope by
the time he finishes, and I finish this, we will have the answers.
Dr. KOTIX. I hope I don't disturb you.
Mr. BK-KWIT. I'm frankly not clear on the major dates that arc
involved here, the dates that you received the Bioneties information,
the date that you came out with your first report on it, and the date
that you came'out with your final report on it.
Now, if I'm right in thinking that those are relevant dates, could
von tell me what those dates are?
Dr. KOTIX. Right. Well, the dates are relevant. I think it was,
again, the date I oflVred for the record, which I don't remember
olfhand, is the date the Cancer Institute received the Bionctics
report.
You will recall Dr. Falk and our associates instigated the Bionctics study? and it wasn't a personal contract with us. It was with the
Cancer Institute.
So the report went to the Cancer Institute and I don't know when
they received that.
Fundamentally, the only reason I suspect that we would have
gotten involved at all in terms of the Bionetics report, as distinct
from our own commitment by virtue of our mission in this, was the
fact that Dr. Endicott. did have a need for a tremendous amount of
statistical and chemical analytical competency, and it was more than
he had available in the Cancer Institute.
So I can give the date at which the material was forwarded to us.
This was in 1968, and again. I will get the date for the record. But
it was—actually, the material was forwarded to us coincidental with
the request to get involved with some of the analyses.
Mr. BICKWIT. About when in 1968 ?
Dr. KOTIX. I will be happy to give you the exact date for the
record, sir.
(The information was subsequently received for the record:)
XIEIIS performed analyses of the raw data between January and
June19G9.
Mr. BICKWIT. Then you released reports periodically?
Dr. KOTIN. To the Mrak Commission only, and to the relevant
(iovcrnincnt agencies.
Mr. BICKWIT. About how many reports were there?
Dr. KOTIX. These were not formal reports, but they were presented quite informally—we finished the analysis of the White Swiss
Mouse data, the C-57 black data, the DBA data.
We checked the statistical significance of the differences between
test and controls, between the various dose levls, between the various modes of admission. So that, rather than adorn the data with

�94

prose, we just gave them the statistical material with the listings of
the conclusions.
Mr. BicKwrr. So. whenever you had anything of any importance,
it went to Mrak.
Dr. KOTIX. Promptly.
Mr. BICKWIT. Your final report came out in the fall of 1969, is
that right?
Dr. KOTIX. Yes, we have submitted a paper for publication in the
journal Science which relates our analysis on the teratogenicity of
2,4,5-T, and it should be appearing shortly.
Again I would be happy to make a preprint copy of the manuscript available for the Committee if you desire.1
Mr. BK'KWIT. Thank you. That wduld be fine.
Now, if you got your information sometime in 1968, and we don't
know when, let's assume it was late 1968, and it took until the fall
of 1969 to come up with a final report, why did it take that length
of time?
Dr. KOTIX. Just the difference between, the magnitude of the job
and the availability of professional resources within our institute.
At that time, our Biometry branch consisted of two professional
biometricians at the doctorate level. This staff was involved in a
series of studies including one on the relationship of asbestos to lung
cancer, and another on a quantification of the hazard to uranium
miners. This limited staff had to be literally redeployed in order to
perform the necessary analyses of the Bionetics data.
Mr. BICK\VIT. On the carcinogenicity studies, when did you get
the information from Bionetics?
Dr. KOTIX. We really didn't, other than as information. It came
as part of the same report. But the analysis of the carcinogenicity
study remained entirely within the Cancer Institute, since it was
clearly relevant to their mission and responsibility as the National
Cancer Institute.
Mr. BICKWIT. You were not responsible for analyzing that?
Dr. KOTIN. No, sir.
Mr. BICKWIT. You have stated the results of the teratogenicity
studies were released to the Mrak Commission immediately when
they became available. I am sure you are familiar with Mr.'Whitesidc's allegation that Dr. Samuel Epstein of the Mrak Commission,
had a great deal of difficulty acquiring information on the studies.
I wonder if you could reply to this allegation? If you are not
familiar with it
Dr. KOTIX. I am familiar with the allegation. I read it in the
story in the New Yorker, of course.
No. I think that we, are probably speaking of two different things.
There was. at no time, the necessity for the requesting of any information from us. There was a mechanism for the forwarding of the
information to the Mrak Commission; the best evidence that this
allegation is not so in another sense is that the head of our Biometry
Branch, Dr. David Gaylor, was on the Mrak Teratogenicity Committee, the very committee to which the data were being supplied.
&gt; Sco P. ns.

I

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95
So, essentially it would be denying his own data to his own committee if this were so.
Do you follow me.
Mr.'BicKwnvI am sorry, I don't.
Senator HART. I am going to have to interrupt again, I am sorry.
I hoped we could avoid the necessity of holding you, but I will miss
the vote.
I will not be able to return as promptly as I like, because I must
remain on the floor to get something done, a matter that will be
voted on tomorrow.
So, we will have to recess in the very unhappy condition of not
knowing exactly when I will get back, but as quickly as I can.
(Recess.)
Senator HART. We will resume, and with better luck than we have
been having in the last hour or so, maybe we can conclude before the
next vote is signaled.
Mr. BtcKwiT. I believe the last statement which you made I had
some difficulty with.
Dr. KOTIX. What I was saying was that Dr. Epstein and Dr.
Gaylor were on the same teratogenicity panel of the Mrak Commission, and each meeting they held Dr. Gaylor brought the data
up.
So the only information Dr. Epstein might have asked for that he
did not get were data that just were not complete. But certainly in
relation to the teratogenicity, I cannot conceive of any available
data that would not have been made available.
Mr. BICKWIT. Was the final Bionetics report made available to the
Mrak Commission when they asked for it?
Dr. KOTIX. It is my impression that it was. And again they would
not have come to us, because the final report was the property of the
National Cancer Institute, as the contracting institution.
Mr. BICKWIT. If they did come to you. would you have had
authority to give it to them ?
Dr. KOTIX. Actually, I suspect I would have picked up the phone
and asked Dr. Enclicott who was responsible, and I would have
gotten authority for it because the information contained in it was
germane to the Mrak Commission. But again I would emphasize
that the final report of any contractor wowd not include the interpretation and the analysis of the data. This was not part of the purchase.
Mr. BICKWIT. I realize that, but if Dr. Epstein of the Mrak Commission had asked you for the final Bionetics report, without an analysis from NIEHS, you would have furnished it to him
immediately?
Dr. KOTIX. I would have furnished it to the Mrak Commission.
Mr. BICKWIT. Would you not have furnished it to Dr. Epstein ?
Dr. KOTIX. The data itself ?
Mr. BICKWIT. Yes.
Dr. KOTIX. Uninterpreted ?
Mr. BICKWIT. Yes.
Dr. KOTIX. Oh, I probably would not have, no.
Mr. BICKWIT. Why not?

�96
Dr. KOTIX. Essentially the data arc crude data that require interpretation, and essentially the implications, the results of the report,
are the conclusions, and the responsibility for those conclusions
would have been ours.—that is. the responsibility of the NIII.
Mr. BICKWIT. These data. I understand, did raise doubts, about
the teratogenicity of 2,4,5-ff.
Dr. IYOTIX. You mean, rather than raise doubts, established the
experimental teratogenicity of this. After the data were analyzed,
yes.
Mr. BicivAvrr. You are saying that you do not believe that a
member of the teratology panel of the Mrak Commission should
have the right to examine those data unalyzed?
Dr. KOTIN. Oh. not at all. All I am trying to say is the data
themselves, short of total package, once the data were analyzed, and
conclusions made, then by no stretch of the imagination would the
date be withheld from anybody.
Mr. BifKwrr. But unanaly/ed. he should not be entitled to look at
them?
Dr. KOTIV. I do not t h i n k so. no. sir.
Mv. Bi&lt;: KWIT. Should anybody other than the organization entrusted with the analysis of the data be entitled to look at them?
Dr. KOTIX. Oh. surely. Mr. Hart's Committee, or there are a
whole spectrum of responsible agencies.
Mr. Bu KWIT. Could you list those agencies that would be entitled
to look at this data?
Senator Jl.uir. You arc inquiring about before analysis?
Mr. Krncwrr. Yes.
Dr. KOTIX. The hierarchy above me. as a lowly director of an
institute, the director of N I I I . The Surgeon General, the Secretary
of IIK\V. all of the way up. any member of the legislature, any
member of the executive branch, with the authority, surely.
Mr. r&gt;K KWIT. But you would not want to allow a nongovernmental scientist with sonic expertise in the field to look at this data ?
Dr. KOTIN. Again, there is no flat yes and no. There are many
instances when we call people in nongovernmentally to look.
Mr. BICKWIT. What I am asking you to do is draw the line. I
know i! is hard, but you have excluded one nongovernmental scientist. I would like to know how you formulate your opinion in deciding who should be excluded and who should be included.
Dr. KOTIN. That is a matter of judgment. How much help I think
we can get from them, how much help we can provide them.
Mr. BICKWIT. Is that the only basis for your decision ?
Dr. KUTIN. I would have to think. I suspect that is the major one.
We have crude data a.nd what we try to do is get the best expertise.
We have everything from advisory committees to councils to study
sections to consultants to the institutes, who are not Government
employees, who arc on call at all times and who are used rather consistently, particularly by a young institute like our own. (we are 3
years old: our £17 million budget, when contrasted with the $150plus million budget of the larger well established institutes is probably as good an indication of our size as anything.)
I think a corollary of our small size is the great consistency with
which we get outside help in terms of consultation. We just had a

�97

task force that spent 3 weeks preparing a consultative guide, as it
were, for the Institute. So there is no tendency on our part at all to
treat anything that we get as cither clandestine or in any way not
open to scrutiny. In fact, as I said in my testimony, I made a special
point that, scientific scrutiny is something that we insist on in all of
our data before we accept it as fact.
As our critical mass at NIEHS enlarges, we will probably be
more certain. But we arc a small outfit and we use outside consultants a lot. So in answer to your question specifically do I feel categorically that data should not be seen by outside scientists, not at all.
There arc instances where you call them in and they sec it initially
with us. as it were, around the table for the first time.'
Mr. BICKWIT. On the pro side you arc weighing the potential
helpfulness of the scientist who would be asking to see the data.
Dr. KOTIX. Oh, no. Also what he can contribute to the maximum
utilization of the data. In the years I have been in NIH when there
arc implications of the data that affect other executive branches, or
have socioccononiie implications, the people who you try to get help
from sind provide help to are judged on an individual basis. This is
really so.
Mr. BicKwrr. What is on the other side? In formulating your
opinion what is it that would keep you from giving the information
out ?
Dr. KOTIX. Number one. concern over data where the interpretation would be such that we would want our interpretation to be on
the record at the time the data were made available. That would be
one example.
Another example, where there is some question we have about the
data ourselves, so we want to go back and verify techniques, verify
the workbooks from which the reports were made. And in fact this
was done in this case. So there are lots of reasons. Not as many as on
the other side, but you just have to do it on an individual basis,
decide what is the. best way to get maximum returns from the data.
Mr. BiotwiT. With respect to Dr. Epstein, a member of the teratology panel of the Mrak Commission, would you ride out the possibility of his being able to contribute to the utilization of this material? '
Dr. KOTIX. Yes.
Mr. BICKWIT. Could you elaborate on that?
Dr. KOTIX. Fundamentally it is a matter of judgment. I felt at
that time that the data themselves needed analysis for the reasons I
mentioned, that the conclusions were integral to the data because
again the mere fact that you had chi square indicated there that the
significance was in large measure determined by statistical methods.
It wasn't a situation where, as the data amply attest, an all or
none response occurred, where all of the controls did one thing, all
of the test animals did the other. There were statistical differences.
There were differences in degree and intensity and in time. These
had to be determined by statistical techniques.
Senator HART. Doctor, I will be brief in my thanks, since I am
under the compulsion of another vote signal.
(The information referred to on p. 94 follows:)

�98

TERATOOKMC EVALUATION or 2,4,5-T
ABSTRACT

The herbicide 2,4,5-T (2,4,5-trichlorophenoxyacetic acid) has been shown to
be teratogenic and fetocidal in two strains of mice using either subcutaneous
or oral routes of administration, and in one strain of rats by oral administration. The incidences of both cystic kidney and cleft palate were increased in
the C57BL/6 mice as well as the incidence of cleft palate in the AKR mice.
The incidence of cystic kidney was also increased in the rats. In addition, an
increase In liver to body weight ratio in the mouse fetus and the occurrence of
bemorrhaglc gastrointestinal tract in the rat fetus suggest that this compound
also has fetotoxic properties.
The chlorinated herbicide 2,4,5-T (2,4,5-trlchlorophenoxyacetic acid) is used
extensively for weed control (1). However, there have been relatively few
reports concerning its pharmacologic and toxicologic properties in animals
(2,3). Indeed, there are no data available concerning the effects of this compound on the developing embryo and fetus. Therefore, this report evaluates the
teratogenic and fetotoxic potential of 2,4,5-T in mice and rats (4).
Breeding colonies of C57BL/6 and AKR strains of mice were established at
Blonetics Research Laboratories, Inc., to supply the mice. For the study, breedIng was by random mating. Detection of a vaginal plug indicated day zero of
pregnancy. Rats were procured from the Holtzman Co., with known insemination dates. Detection of sperm indicated day zero of pregnancy. All animals
received chow and water ad libitum.
2,4,5-T (5) was administered by one of two routes, subcutaneously or orally.
A solution of 2,4,6-T in 100% dlmethylsulfoxide (DMSO) in a volume of 100
/il/mouse was used for each subcutaneous administration. For oral administration by gastric intubation, 2,4.5-T was suspended in a honey solution (honey:
water, 1:1) and volumes of 100 /d/mouse and 200 /«l/rat were used.
In the studies with the C57BL/6 strain, 2,4,5-T was administered daily
beginning on the sixth day of pregnancy and continuing through the 14th day
or from the 9th through the 17th day. The mice were sacrificed on the 18th
day of gestation for examination. In the studies with the AKR strain, 2,4,5-T
was administered daily beginning on the 6th day of pregnancy and continuing
through the 15th. These mice were sacrificed on the 19th day of gestation. The
rats were treated on the 10th through the 15th and sacrificed on the 20th day
of gestation.
Upon sacrifice both mothers and fetuses were examined carefully. In addition, about one-third of the mouse fetuses were stained with alizarin red S in
order to detect skeletal anomalies.
Tables 1 through 3 contain data on fetal mortality, abnormal litters, abnormal fetuses per litter, fetuses with cleft palate, fetuses with cystic kidney,
maternal weight gain, and maternal and fetal liver to body weight ratios. The
following conventions were observed in compiling these data. If a fetus was
either dead or resorbed, it was regarded as a dead fetus. A fetus was classl-,
fled abnormal if it was alive and had at least one anomaly (regardless of
tyi&gt;e). .Similarly, a litter was classified as abnormal if it contained one or more
abnormal retuses. A fetus was said to have a cystic kidney if at least one of
its kidneys was affected. In calculating the maternal liver/body weight ratio,
maternal body weight was defined as the difference between the weight of the
animal on the day it was sacrificed and the gravid uterus weight. Finally, the
maternal weight gain was defined as the difference in the corrected maternal
body weight on the day it was sacrificed and its weight on day zero of pregnancy.
The percentages for fetal mortality, abnormal fetuses, fetuses with cleft
palate and fetuses with cystic kidney were computed by first obtaining the percent for each litter and then calculating the average of these percentages.
The percentage of abnormal litters provides a measure of the prevalence of
abnormal fetuses across litters, while the percentage of abnormal fetuses per
litter gives an indication of the prevalence of abnormal fetuses within litters.
In this report, the control animals are those that were on a large study
during the 3-year time period in which 2,4,5-T was evaluated. The data from
the DMSO and honey treated control groups were compared with the data for
the non-treated control group. Then the results from animals treated with
2,4,5-T in either DMSO or honey were compared to the appropriate control

�99
diita. Standard corrected 2x2 chi-square tests (6) were used to compare the
results of 2,4,5-T treated animals with the appropriate control data for the
proportion of litters containing abnormal fetuses.
The distribution of the percent of abnormal fetuses per litter for 2,4,5-T
treated litters was compared with the appropriate control distribution by use
of the non-parametric Mann-Whitney U-test (6). Also, this test was used for
comparing the percent fetal mortality, cleft palate, cystic kidney, and enlarged
renal pelvis iwr litter. This test requires that the proportion of dead or abnormal fetuses per litter is independent from litter to litter, but requires no
assumption about the frequency distributions of these proportions.
Initial analyses of the data indicated that occurrences of anomalies among
fetuses within litters were correlated. That is, anomalies were not randomly
distributed across all litters but tended to cluster within litters. Many litters
possessed no anomalies whereas all of the fetuses in some litters were abnormal. Since fetuses within the same litter tend to be more alike, pooling the
dutn across litters before iwrformlng statistical tests is not appropriate. The
experimental unit (7) is that entity to which treatments are applied, in this
case the pregnant animal. Hence, nil calculations of averages and all statistical tests were performed on the Independent responses of the experimental
units (litters).
The administration of DM8O or honey to mice or rats did not adversely
affect the development of the fetuses. The incidence and type of naturally
occurring anomalies observed in the DMSO and honey treated animals did not
show «n increase compared to the non-treated group. The alizarin stained
fetuses of tho control mice showed very few skeletal anouiolies. No skeletal
anomalies were detected by staining in the treated mice. For both mice and
rats, there were no differences in the average number of implantations in the
control and experimental litters. A few values for treated animals were less
tli.-m those of their appropriate controls. None of these differences were statistically significant including the 3% fetal mortality observed in the C57BL/6
mice receiving a 21.5 mg/kg dose of 2,4,5-T reported in Table 1. This value of
Wfc reflects a period of low fetal mortality (9%) observed in the control mice
during the initial few months of the study. This difference in mortality is not
statistically significant. There were no other significant changes in these control data during the 3-year period.
As shown in Table 1, the administration of 2,4,5-T to C57BL/6 mice on days
0-14 at a dosage level of 113 mg/kg produced significant increases in percent
of abnormal litters and percent of abnormal fetuses per litter. The anomalies
produced by 2,4,5-T were almost exclusively cystic kidney and cleft palate.
Similar results were obtained regardless of whether the compound was administered subcutaneously or orally. A dosage level of 46.4 mg/kg administered
orally did not produce a significant increase in fetal mortality or an effect on
palatal development, but did cause a significant increase in the percentages of
fetuses with cystic kidney. Administration of 2,4,5-T subcutaneously at a
dosage level of 21.5 mg/kg did not affect the vlsnbility or development of the
fetuses. Thus, a dose-response relationship for the fetociclal and teratogenic
properties of 2,4,5-T in mice is suggested for both routes of administration.
It was also observed that in mice treated with 2,4,6-T on days 6 through 14,
there was a significant decrease in the incidence of naturally occurring anomalies. These consist of microphthalmia followed by anophthalmia and are in
accord with other C57BL/6 colonies (8). Although the fetuses from mice
treated on the C-14th days had fewer naturally occurring anomalies, the
fetuses from mice treated on the 9th to 17th days did exhibit these anomalies.
Thus, it appears that the interval of days 6 to 9 of gestation is one of the sensitive periods of development with respect to 2,4,5-T. Two other sensitive
periods are during development of the palate and kidney since they are so
highly affected. The occurrence of these two anomalies are statistically
unrelated.
In the study where 2,4,5-T was administered on the 9th to the 17th day of
L'cstation with the C57BL/6 mice, maternal and fetal liver weights were determined. As seen in Table 2, this treatment produced a significant increase in
maternal and fetal liver to body weight ratios. The significant increase in fetal
liver to body weight ratio reflects both an increase in fetal liver weight and a
decrease in fetal body weight The significant increase in the liver to body
weight ratio suggests a change in activity of drug metabolizing enzymes of the

�1

100
endoplasmie rctieulum which has been studied (9). Again, the Mann-Whitney
U-test was used to compare the animals administered 2,4,5-T with the appropriate DMSO control mice.
Thus, in the C57BL/6 mice, 2,4,5-T is fetocidal, teratogenic and capable of
producing an increase in the liver to body weight ratios.
Treatment of mice of the AKR strain with 2,4,5-T in honey produced a signiflcnnt increase in fetal mortality. The incidence of cleft palate was increased
with both routes of administration. However, 2,4,5-T did not produce an
increased incidence of cystic kidney in this strain. There was no effect of
2,4,5-T administration in this strain on the maternal weight gain with either
route of administration. However, the maternal liver to body weight ratio was
increased using either route of administration.
In addition, hybrid litters resulting from mating C57BL/6 females with
AKR males were evaluated. The administration of 113 mg./kg in DMSO from
days 0 through 14 of gestation produced a high incidence of both cystic kidney
and cleft palate. There was no effect on maternal weight gain.
The oral administration to rats of 2,4,5-T at a dosage level of 10.0 or 4C.4
mg/kg on the 10th through the 15th day of gestation produced a significant
increase In fetal mortality (Table 3). The two lower dosage levels, 4.6 and 10.0
rng/kg produced a significant increase in the percentage of abnormal fetuses.
These fetuses displayed a high incidence of cystic, kidney. At the highest dose
level, 46.4 mg/kg, the marked increase in fetal mortality reduced the population of live fetuses to a small sample. However, cystic kidneys were observed.
In a limited study, the administration of 2,4,5-T at dosage levels of 21.5 or
46.4 mg/kg from the 6th through the 15th day of gestation was highly fetocidal.
At all dosage levels studied in the rat, hemorrhaglc gastrointestinal tracts
were observed in the fetuses. The percentages of fetuses per litter with liemorrhagic gastrointestinal tracts showed a dose-reponse relationship: i.e., 3%,
50%, and 83% at doses of 4.6, 10.0 and 46.4 mg/kg, respectively. Xone were
observed in the fetuses from the control animals. Drill and Illrntzkn (2i have
reported that dogs which received 2,4,5-T in the diet showed some necrosis and
Inflammation of the intestinal mucosa. The hemorrhaglc gastrointestinal tracts
observed in the rat fetuses is probably a toxic effect of 2,4,6-T on the fetal
organ as opposed to a developmental defect.
In conclusion, these studies show that 2,4,5-T adversely affects the development and viability of the mouse and rat fetus.
TABLE l.-TERATOGENIC EVALUATION OF 2,4,5-T IN MICE

Compound

Vehicle

Number
Dose
of
(mgkg) litters

Percent of fetuses per
Average
litter with—
Percent
number
Percent
Percent abnormal
live
fetal
fetuses' mortality/ abnormal fetuses' Cleft palate
Cystic
kidney
litters
litter
litter
litter

C57VL« STRAIN TREATED DAYS 6-14
Nontreated..
Control
Control
2.4.5-T
2,4,5- T
2.4,5- T
2,4,5-T

None
DMSO
Honey
DMSO
DMSO
Honey .
do

None
None
None
21.5

113.0

46.4
113.0

72
IDS
32
6
18
6
12

5.8
5.5
7.1
7.7
4.4
8.5
4.8

38
42
41
50
386
-MOO
1 100

31
8
377

19
24
0

42
8
347

11
12
14
12
357
= 37
»70

71
30
3 100

26
29
15

5
4
0
329
355

1

0
0
)22
&gt;23

0
Ml
&gt;33
'48

C57BL/6 STRAIN TREATED DAYS 9-17
Nontreated.
Control
2.4,5-T

. None..
. DMSO..
DMSO..

None
None
113.0

10
10

5.1
6.1
7.7

36
23
11

0
160

AKR STRAIN TREATED DAYS 6-15
Nontreated
Control
Control
2.4,5-T.
2,4,5-T

..
...
..
..
..

None
DMSO
Honey
DMSO.. .
Honey

None
None
None
113.0
113.0

i Statistical Significance Level=0.10;

58
72
12
14
7

7.1
6.9
8.8
6.9
5.3

16
15
9
23

371

i 100

-'Statistical Significance Level-0.05;

&lt;}
0
328
355

&lt;\
1
0

3 statistical Significance Level=O.OI.

�101
TABLE 2.-LIVER WEIGHT STUDY: 2,4,5-T ADMINISTERED DAILY AT 113 MG/KG SUBCUTANEOUSLY IN OMSO
FROM THE 9TH THROUGH THE 17TH DAY OF GESTATION IN C57BL/6 MICE
Maternal

Fetal
i reaimeni

—
Liver wt.
(ems)

Nontreated
OMSO
24,5-T

Body wt.
(gms)
.810
.818

i Statistical significance level - 0.10.

:

.058
.056

'.738

Wt. tain
(6ms)

».076

.047
.046

t.05?

•..

Liver wt./
Body wt.

Statistical significance level - 0.05.

]

Liver wt.f
Body wt.

6.00
5.99
4.65

.069
.068

'.120

Statistical sigiiilicance level - 0.01.

TABLE 3.-TERATOGENIC EVALUATION OF 2,4,5-T IN RATS
Percent of fetuses per
litter with—

Average

Compound
Nontreated
Control
2,4,5-T.
2,4,5-T
245-T

Vehicle
. None
.. Honey......
do
do.
...do

Doss
(nig/kg)

Number
of
litters.

live
Percent abnormal
fetal
fetuses/
fetuses/ mortality/ abnormal
litter
litter
litters
litter

None
None
4.6

7

9.9

14
g

8.7
8.2

10.0
46.4

7
6

i Statistical Significance Level =-0.10.

7.1
2.7

11
12
J28
359

• Statistical Significance Level -0.05.

Enlarged

renal
pelvis

Cystic
kidney

43

9

9

0

57
88

12
136

12
18

* 46

17
27

.1!
130
33

86
67

60

&gt; Statistical Significance Level =0.01.

REFERENCES AND NOTES

(1) Atulus, L. 3., The Pltyxiology and Biochemistry of Itcrlticiilrx, Academic
1'rww, New York, 1904.
(2) Drill, V. A. and Hiratzka, T., Arch. Industrial Hygiene Occu/«rfional
Mcd. 7, 01, 1953.
(3) Howe, V. K. and Hymns, T. A., Am. J. Vet. Res. 15, C22,1934.
(4) These results are from a large study designed to screen selected compounds for teratogenic effects in mice which was performed at the Bioneticfl
Research Laboratories, Division of Litton Industries, under contract numbers
I'H 43-04-57 and PH 43-07-735 from the National Institutes of Health.
During the performance of this study, Dr. Courtney was a staff member of the
Bionetics Research Labs., Inc., and Dr. Folk was a member of the National
Cancer Institute.
(5) 2,4,5-T was produced by the Diamond Alkali Co., 98%, Tech., m.p. 149151°.
(0) Snedccor, G. W. and Cochran, W. G. StattxUcal Methods, 6th cil., Iowa
State Univ. Press, Ames, Iowa, 1967.
(7) Kempthorne, O., The Design and Analysis of Experiments, Wiley. N.Y.,
11)52.
(8) Kalter, H., Teratology 1, 193, 1908.
(9) Courtney, K. D. (In preparation).
Note added in proof:
The sample of 2,4,5-T used in this study contained approximately 30 ppm of
•.',3,7,8-tetrachlorodibcnzo-p-dioxln (dloxln) (10). Dioxin as well as purified
•_',4,5-T are currently being evaluated for their teratogenic and fetotoxlc potential.
(10) We thank Dow Chemical Co., for the analysis of 2,4,5-T.
K. Diane Courtney
D. W. Gaylor
M. D. Hogiin

H. L. Palk

National Institute of Environmental Health Sciences, National Institutes of
Health, Post Office Box 12233, Research Triangle Park, N.C. 27709
R. R. Bates
I. Mitchell
National Cancer Institute
National Institutes of Health
Hethesda, Md. 20014

�102
Senator ir.\KT. Arc there any additional questions?
Mr. liicKwrr. No, Mr. Cliairman.
Senator HAKT. If any arise we will submit them in writing and
receive the replies in the record.
I appreciate the cooperation of everyone through the day, and
apologi/e for the erratic scheduling this afternoon.
(The following was subsequently received for the record:)
U.S. Snows SIGNS OF CONCERN OVER EFFECT is VIETNAM OF O-YEAR
PKFOUATIOX PKOGKAM
(Hy Ralph Klumenthai, special to the Xc\v York Times)
SAIGON. South Vietnam, March H— Many South Vietnamese who live adjacent to areas that are being defoliated by spray from United States planes nre
convinced that any ailments or misfortunes that they suffer are related to the
sprayings.
There is no proof that they are right about the effect of the chemical sprays
on the human body, but neither is there any assurance that they are wrong.
Although the defoliation program, organized and run by the United States,
has boon In operation for nearly nine years the, full effect of the chemicals on
animal and human life remains largely undetermined.
The United States military command says the program, which is designed to
strip plant cover from areas occupied by the enemy and to destroy crops that
might yield him food, has covered about 0,000 of South Vietnam's (&gt;0.3i»0
square miles.
U.S.

TEU.MS IT VALUABLE

The United States command says the program has proved its military worth.
"It has contributed materially to the security of units operating in the field by
increasing their visibility from the ground as well as the air," the command
said.
About 13 per cent of the program has been directed against crops, presumably food grown by and for the enemy. Because of the drifting of defoliants
and tin- difficulty of assessing the results on the ground, It is virtually impossible to say how much of the crop has been destroyed by the chemicals, but it
would not appear to be a significant part of the country's capacity. It has
brought hardships, however, to individual farmers.
A f t e r year* nf assuring the South Vietnamese that. Ibis extensive spraying
was harmless to animals and humans, United States officials arc showing signs
of concern over recent reports the the chemical sprays may have some littleunderstood and alarming effects.
PANEL STUDYING EFFECTS

In the last several months, rejwrtedly on instruction from Washington, the
United States military command and the United States Embassy have formed
u speeinl committee to review the effects of the defoliation program, especially
on humans.
The sensitivity of the issue has foreclosed official comment, but according to
Informed sources the science advisory office of the command is responsible for
gathering data in interviews and tests that embassy officials will then evaluate.
Tin- South Vietnamese Government regards the entire subject as taboo. Vietnamese newspapers have been suspended for publishing articles about birth
dt'lWts allegedly attributed to the defoliants, and the public Health Ministry
dei-Une* tii pnwide any statistics on normal and abnormal births.
However. the concern felt union; the Americans is shared by many South
Vietnamese scientists. phy.sir-ians. health officials and villagers Interviewed in a
three-week survey of the effects of the program.
OfiH-rs of the United r-tiiH-s command are aware of the allegations of birth
ili-fi-et.H lint iin-y gi;n(:r:illy discount the reports.
Uesjponsil.l'? South Vietnamese- scientists and officials say they know virtually ,
notliiiiL- almiit the effects of the chemical sprays.

�103
Saigon's leading maternity hospital, Tudu, from which rumors of an increase
of abnormal births emanate periodically, has not even compiled annual reports
of statistics for the last three years. Recent monthly figures show an average
of about 140 miscarriages and 150 premature births utnoug approximately 2,800
pregnancies, but the hospital is not prepared to say whether this represents an
increase nnd, if so, what Hie cause might be.
A high Agriculture Ministry official said: "I don't think the Americans
would use the chemicals if they were harmful."
He conceded that hfs ministry had made no tests and asserted that his
experts had been unable to get any information about the defoliants from the
Defense Ministry, which considers such data secret. The main defoliant compounds and some information about them are available in the United States.
Last Oct. 29, President Nixon's science adviser, Dr. Lee A. Du Bridge,
announced that as u result of a study showing that one of the defoliants used,
2,4,5-T, had caused an unexpectedly high incidence of fetal deformities in mice
and rats, the compound would henceforth be restricted to areas remote from
population.
That directive appears to be ambiguous In South Vietnam for military
spokesmen assert that 2,4,5-T continues to be used only in "enemy staging
areas"—by definition populated regions.
DEFOLIANTS WERE CONCEALED

Don That Trinh, Minister of Agriculture from November, 1!K&gt;" to May, 1UC8,
and for 10 years professor of agronomy at Saigon University, said that while
he was minister, the Defense Ministry "would try to conceal the defoliant
products from me."
"I did not believe In defoliation," he added.
According to one of the Vietnamese directors of a Government research laboratory In Saigon: "We didn't know anything before the United States started
spraying. It was only when we received complaints from the livestock people
that we started getting Interested." But, he added, there are still no Vietnamese studies.
Even the village of Tauhlep, 20 miles north of Saigon, on which 1,000 gallons of defoliants were jettisoned on Dec. 1, IOCS, has not been the object of
attention or study.
An American C-123 flying out of Blenboa air base, Northeast of Saigon,
developed engine trouble shortly after takeoff. To lighten the craft, the pilot
sprayed the full load of chemicals over Tanhlep and nearby Blnhtrl in 30 seconds instead of the usual 4 minutes 30 seconds, which spreads the defoliant at
the rate of three gallons an acre in unpopulated areas.
The defoliant involved, according to the United States command, was a 50-50
mixture of 2,4-Dichlorophenoxyacetate, or 2,4-D, and 2,4,5-Trichlorophenoxyacetate, or 2,4,5-T, in an oil base. It is one of three compounds the
military says It uses here, the others being a Dow chemical product called
Tordon 101, a mixture of amlne salts of 2,4-D and Plcloram, and an arsenic
compound of cacodyllc acid.
No physicians visited Tanhlep to examine the people after their exposure,
which, like eight similar emergency dumpings since 196&amp;—some over unpopulated forests—was not made public by the United States command.
A United States Air Force medical team visited Binhtrl shortly after the
spraying and, according to American district officials, found the villagers had
suffered no ill effects. There was no later Inquiry.
Mrs. Trail Thi Tien of Tauhlep, hwo says she has four normal children. Is
convinced that the malfunction of her son, who still looks like a newborn at 14
months of age, "must be due to the chemicals I breathed."
Her neighbors, Mrs. Nguyen Thl Hal and Mrs. Tong Thi An, blame the
spraying for the fact that their children, one year and 20 months old respectively, still crawl Instead of walk.
Nguyen Van Nhap, a farmer, complains of suffering bouts of fever, sneezing
and weakness.
"I was working In the field when the spray came down," Mrs. Tien said
through an interpreter. "I felt dizzy, like vomiting and had to stay in bed
three or four days."
Many other villagers reported feeling the same sensations as Mrs. Tien, but,
except for the two children described as retarded in learning to walk, no other

�104
Trim Van Dang, a farmer in neighboring Blnhtri, recalled that three days
after the spraying two villagers, Tarn Ten and Mrs, Hal Mua, died after suffering respiratory difficulties and trembling. The next day, he said, a third villager, Mrs. Hal Nuc, died after showing similar symptoms. Mr. Ten was an old
man and could have been expected to die soon anyway but the two others, Mr.
Dang said, were middle-aged and seemed healthy.
Such complaints ure not limited to Tanhlep and Binhtri, where villagers
were admittedly exposed to concentrated doses of defoliant—though just how
concentrated has not heen established.
In Blenhoa city, 10 miles from Tanhiep, any defoliant In the air drifts down
from the heavily sprayed battle areas to the north.
Dr. Nguyen Son Cao says he finds a clear correlation between the days when
there is spraying and the number of patients who come in with respiratory ailments, mostly sneezing and coughing.
Dr. Cao, who has been practicing in Blenhoa for 21 years, said he had also
noticed that in the last two to three years the number of miscarriages among
his patients had doubled.
"These women are convinced they are the victims of the chemicals," he said.
"I only suspect there could be a relationship. This suspicion is very well
known. The Increase in miscarriages is very obvious, very significant"
However, the manager of another clinic reported no increase in miscarriages
over the last several years.
Any Increase in miscarriages has many possible explanations: perhaps the
deterioration of the dally diet, the cumulative effect of the hardships of war,
population and economic movements that register statistics of only certain
groups, or air pollution, of which the defoliant chemicals are a part.
Appendix 2
DEFOLIANTS, DEFORMITIES: WHAT RISK?
Dr. Jackie Verrott is fascinated and horrified by what has now become an
everyday sight at her FDA toxicology lab in Washington, D.C.: several white
leghorn chicks struggling to get to their feet and then finally walking—on their
knees. Besides slipped tendons in their legs, some of the chicks have cleft palates
and beak deformities. All this has heen wrought by injecting fertilized eggs with
an ethnnol solution containing just 2.5 micromicrograms (or 50 parts per trillion)
of i!,3.t;.7-tetrachlorodiben;!0-p-dioxln, a contaminant in 2.4.5-trichlorophi'noxvacetlcacid r2,4.5-T).
Over the past nine years, 40 million pounds of this defoliating herbicide
have been sprayed in very heavy concentrations across at least five million
acres of Vietnam to destroy crops and expose the enemy. By MWN'S reckoning,
some 30 million pounds have been spewed out in lesser concentrations during
just the past five years across perhaps 30 million acres of range, forest, and
farmland (not to mention home gardens) in the U.S—an area three times the
size of Tex us.
Thus, Dr. Verrett's preliminary findings are not just of interest to poultrymen. The 11 crippled chicks in her study were among 15 survivors of a clutch
of 25 eggs. I n the unhatched chicks, Dr. Verrett found pronounced evidence of
chick edema—swollen tissues, cysts on the back, necrotic livers, and the same
deformities the live birds have. The FDA researcher is diluting the dioxln content to try to find a "no effects" level. In another brood, she has produced a
similar pattern of birth defects with just 2^ parts per trillion of dloxln,
1/400,000 the 1 ppm found In currently marketed products. Now she's experimenting with .25 parts per trillion. (The work is so politically sensitive that
she doesn't even know the origin of the 2,4,5-T involved and feels "like I'm in
the CIA.")
When told that HEW Secretary Robert Finch is doubtful about the applicability of the chick embryo work to human risk, Dr. Verrett snapped, "I know,
I know, but. the only time Bob Finch sees eggs Is when he eats them for
breakfast."
While Dr. Verrett labored in the lab early this month, Dr. Samuel Epstein,
chief of toxicology at Children's Hospital Medical Center in Boston, was out in
Globe, a foothill town In southeastern Arizona, to evaluate reports of toxic and

�105
tenitogenic effects attending the spraying of 2,4,5-T and Its chemical cousin, 2(2,4,5-Trichlorophenoxy) proprlonic Acid (Silvex) in adjacent Tonto National
Forest These reports have disturbed the nation and drawn experts to the
scone.
ODD EFFECTS AROUND GLOBE

In Globe, Dr. Epstein saw two goats and a duck with leg deformities similar
to those in Dr. Verrett's chickens, and studied the histories of sick people.
"It's impossible to say for certain whether the claimed symptoms and effects
urc attributable to the spray," he said. But at the same time he lashed out at
the U.S. Forest Service for risking the contamination of water sources against
its own policy, for contributing to drift by using water as a 2,4,5-T solvent,
and for falling to post the area before spraying.
MWN found that the Department of Agriculture keeps such casual tabs of
•.',4,5-1' spraying that It would take officials a week just to find which of the 33
nation;! I forests besides Tonto have been bombed with the two million pounds
Forest Service has jetted out over the past six years. "But Interior uses more
tlmn we do," said one official. Replies an Interior spokesman, "We used only
44,232 pounds last year."
In the Globe area, the Forest Service has sprayed 2,4,5-T and Silvex four of
the past five years to promote growth of grass in a burned-over section and to
eliminate chaparral. But most 2,4,5-T use is unmonltored. The defoliant is
bought by ranchers and private foresters and it's pretty much up to them
what happens to it.
Human teratogeniclty Is the chief worry; it is fairly well known by now
that Dr. Verrett's work is not the first study to dramatize the risk. Yet MWK
learned that the U.S. doesn't keep nationwide birth-defect figures.
Dr. Edward Burger of the government's Office of Science and Technology
docs not seem worried by this absence of monitoring and supervision, nor,
Indeed, about the risk of 2,4,5-T teratogenicity. Dr. Burger, technical assistant
to Presidential science advisor Lee A. DuBridge, acknowledges that a study
done by Bionetics Research Laboratories for the National Cancer Institute
showed last March (It was suppressed for six months) that nearly all
offspring of mice and rats given 2,4,5-T early in gestation at the relatively
high levels of 21.5 nig/kg or 46.4 mg/kg were born dead or deformed—in some
cases with no eyes, with cleft palates, and cystic kidneys and enlarged livers.
Kven at 4.G mg/kg dosage, 39% of the animals were born malformed.
The OST expert is more familiar than most with the high-level decisionmaking that went into Dr. DuBrldge's declaration October 29 that on the basis
ot the Bionetics study, the use of 2,4,5-T in populated areas would be
restricted. Dr. DuBridge said Agriculture would, by Jan. 1, 1970, withdraw
licenses for its use on crops (corn, bluberries, peaches, pears, and several leafy
vegetables) unless the FDA found that the residue was negligible and humans
were tolerant of it.
Dr. Burger explains that the FDA missed this deadline for a number of reasons. First, Dow Chemical Co., a major maker, of 2,4,5-T, discovered last
December that the sample used by Bionetics contained 27 ppm of the tetrachloro dloxln instead of the "less than 1 ppm" Dow says is in its product. So the
study is now being re-run with a Dow sample at Dow labs in Zlonsvllle, Ind.,
and Midland, Mich., and at the National Institute Environmental Health Sciences.
Xext, says Dr. Burger, even after the teratogenic potential is re-evaluated In
a rodent model, the disappearance rate of the contaminant in the animal blood
stream must be determined and calibrated with that in human volunteers. He
concludes: "The possibility of exposure to 2,4,5-T, vls-a-vis the small teratoircnlc risk, is certainly not sufficient at this time to justify wiping .the chemical
off the market."
Comments Associate FDA Commissioner for Science Dale Lindsay: "Dr.
DuBridge had no damned business setting a tolerance deadline. Our marketliasket surveys for 1908 and 1969—thousands of samples of 120 foods and vegetables are constantly being assessed—show only five recoveries of 2,4,5-T—
three from leafy vegetables at negligible levels, plus one from milk, and one
from meat at the .01-mg level.
"Ynt if we had to set. a tolerance today It would be zero. The trouble with
this very active dioxiu contaminant is that while it may be a known quantity
in a product, you can't extract it in the same quantity."

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Harvard microblologist Matthew Meselson is worried for the same reason—
and many others. Dr. Meselson—appointed last year by the American Association for the Advancement of Science to head a 2,4,5-T evaluation projectsays: "The tetrachloro dioxin represents just one of 12 or 13 ways the
chlorine atoms can arrange themselves on a benzene ring to form dioxin molecules. How do we know about the hexa, hepta, and octychlors, or about how
persistent the tetrachlor itself is? Moreover, I'm very concerned about the
dloxlns that might be formed by unreacted trichlorphenol [2,4,5-T precursor]
when the product is exposed to heat If it were taken up by plants or wood
and these were burned, you'd get more dioxln. Finally, I'm bothered by the
bizarre mental effects suffered by German workers making 2,4,5-T. I say when
in doubt, stop it."
Dr. Julius Johnson, vice president and director of research for Dow, regards
these concerns as speculative. "If we thought 2,4,5-T was harming anybody
we'd take it off the market tomorrow," he says. "We've been dedicated to
cleaning it up ever since 1904 [when the contaminant was linked to an outbreak of chlor-acne in Dow workers at Midland]." Dr. Johnson says it would
take a 200-degree jolt to produce reaction of dioxin, and the contaminant disappears within hours under ultraviolet light. So far, he adds, Dow tests show
that its 2,4,5-T has no teratogenic effect on rats at a dosage of 24 mg/kg and
on rabbits at 40 m.s/kg. But how about Dr. Verretfs new findings in the chick
embryo test? The Dow executive confesses surprise. "But I'm confident," he
says, "that we'll be safe when we propose a new specification for all 2,4,5-T
products of .1 ppiu of dioxin."
Safety also assumes gauges of teratogenicity in the population, however.
FDA's Dr. Lindsay spoke with certitude when he told MWN that "the National
Institute of Neurological Diseases and Stroke has recorded birth defects for
some 15 years and would be telling: us if they were on the rise." He's wrong.
Dr. Heinz Berendes, chief of NINDS' perinatal research branch, admits dolefully that "no nationwide data are available on frequency or incidence of malformation."
Adds Yale biologist Arthur Galston: "It's shocking, but absolutely no studies
have been made in Vietnam either. There have been reports of birth defects in
Saigon papers since last June but hospital records haven't been made available."
State Department officials say they know of no policy whereby such data
would be classified or withheld. Significantly, however, Dr. Malcolm Phelps,
chief of the Vietnam medical section of the Agency for International Development, says he is acting on a recent White House request to collect figures on
teratological occurrences in Vietnam civilian hospitals.
As for all the toxic effects reported by Globe residents after the June 8-11
spraying—a helicopter released 035 gallons of Silver, 30 of 2,4,5-T, and 20 gallons of a combination called "Orange" over 1,900 acres of forest—an MWN
reporter Inquired into the histories of 18 patients with four of the five doctors
who treated them, and checked on the two crippled goats, the crippled duck, a
bleeding bull terrier, and two other dogs with pneumonia. Net result: two
strongly suspected herbicide poisoning cases linked to the spraying, and one
"definite." There's one-year-old Paul McCray, who lives on the edge of Tonto
National Forest and whose father drove the family right up to the 'copter
landing spot during spraying. The boy has had respiratory attacks and convulsions. Phoenix pediatrician W. Scott Chisholm finds Paul has lymphositosis,
with a white cell count twice normal.
The second suspected case, a smeltery worker named James Andrews who
has complained of a numbe'r of symptoms associated with herbicide poisoning
—nausea, muscle weakness, vertigo, numbness, and stabbing pain—is vouchsafed by Dr. Granvllle Knight of Santa Monica, Calif. In the third case, that
of Mrs. Billee Shoecraft, Dr. Knight says he has found 2-4-D In tissue.
Dr. Bernard Collopy would not label the muscle spasms and stabbing pain
suffered by potter Robert McKusick, owner of the defective goats and ducks,
as herbicide-related. Dr. William Bishop would not credit the chest pains of
Bob McCray, father of little Paul, or his wife's tingling fingers and toes, as
2,4,5-T or Silvex poisoning. And veterinarian F. I. Skinner hadn't seen any of
the animal cases.
Sums up Dr. Bishop: "There's a good possibility some of the human cases
are related to spraying, but symptomatic connections aren't connections and

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I'm no toxlcologist. People here are emotional and each morning wake up with
new nails pounded into their palms. What's needed Is solid scientific investigation. All I hope is they don't leave us hanging in the air (or the next 20
vears."
Appendix 3
(From the New i'orkcr, Feb. 7, 1070)

A REPORTER AT LARGE: DEFOLIATION
By Thomas Whiteside
Late in 1901, the United States Military Advisory Group in Vietnam began,
us a minor test operation, the defoliation, by aerial spraying, of trees along
the sides of roads and canals east of Saigon. The purpose of the operation was
to increase visibility and thus safeguard against ambushes of allied troops and
make more vulnerable any Vietcong who might be concealed under cover of
the dense foliage. The number of acres sprayed does not appear to have been
publicly recorded, but the test was adjudged a success militarily. In January,
1962 following a formal announcement by South Vietnamese and American
officials that a program of such spraying was to be put into effect, and that it
was intended "to Improve the country's economy by permitting freer communication as well as to facilitate the Vietnamese Army's task of keeping these
avenues free of Vietcong harassments," military defoliation operations really
got under way. According to an article that month in the New York Times, "a
high South Vietnamese official" announced that a seventy-mile stretch of road
between Saigon and the coast was sprayed "to remove foliage hiding Communist guerrillas." The South Vietnamese spokesman also announced that defoliant chemicals would be sprayed on Vietcong plantations of manioc and sweet
potatoes in the Highlands. The program was gathering momentum. It was
doing so in spite of certain private misgivings among American officials, particularly in the State Department, who feared, first, that the operations might
open the United States to charges of engaging in chemical and biological warfare, and second, that they were not all that militarily effective. Roger Hilsuiait, now a professor of government at Columbia University, and then Director of Intelligence and Research for the State Department, reported, after a
trip to Vietnam, that defoliation operations "had political disadvantages" and,
furthermore, that they were of questionable military value, particularly in
accomplishing their supposed purpose of reducing cover for ambushes. Hllsman
later recalled in his book, "To Move a Nation," his visit to Vietnam, in March,
1902: "I had flown down a stretch of road that had been used for a test and
found that the results were not very Impressive. . . . Later, the senior Australian military representative in Saigon, Colonel Serong, also pointed out that
defoliation actually aided the ambushers—if the vegetation was close to the
road those who were ambushed could take cover quickly; when it was
removed the guerrillas had a better field of fire." According to Hilsman, "The
National Security Council spent tense sessions debating the matter."
Nonetheless, the Joint Chiefs of Staff and their Chairman, General Maxwell
Taylor, agreed that chemical defoliation was a useful military weapon. In
1962, the American military "treated" 4,940 acres of the Vietnamese countryside with herbicides. In 1963, the area sprayed increased five-fold to a total of
24,700 acres. In 1964, the defoliated area was more than tripled. In 1965, the
1964 figure was doubled, increasing to 155,610 acres. In 1966, the sprayed area
was again increased fivefold, to 741,247 acres, and in 1967 it was doubled once
again over the previous year, to 1,486,446 acres. Thus, the areas defoliated in
Vietnam had increased approximately three hundredfold in five years, but now
adverse opinion among scientists and other people who were concerned about
the effects of defoliation on the Vietnamese ecology at last began to have a
hraklng effect on the program. In 1968, 1,267,110 acres were sprayed, and in
1969 perhaps a million acres. Since 1962, the defoliation operations have covered almost five million acres, an area equivalent to about twelve per cent of
the entire territory of South Vietnam, and about the size of the state of Massachusetts. Between 1962 and 1967, the deliberate destruction of plots of rice,
manioc, beans, and other foodstuffs through herbicidal spraying—the word
••deliberate" is used here to exclude the many reported instances of accidental
45-302—70

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spraying of Vietnamese plots—Increased three hundredfold, from an estimated
741 acres to 1221.312 acres, and li.v the end of 1969 the Vietnamese cropgrowing
area that since 1002 had been sprayed with herbicides totalled at least half a
million acres. By then, in tunny areas the original purpose of the defoliation
had been nil but forgotten. The military had discovered that a more effective
way of keeping roadsides clear was to bulldoze them. But by the time of that
discovery defoliation had settled in as a general policy and taken on a life of
Its own—mainly justified on the ground that it made enemy infiltration from
the North much more difficult by removing vegetation that concealed jungle
roads mid trails.
During all the time since the program began in 1961, no American military
or civilian official has ever publicly characterized It as an operation of either
chemical or biological warfare, although there can be no doubt that it is an
operation of chemical warfare in that it involves the aerial spraying of cheinlcnl substance* with the aim of gaining a military advantage, and that it Is an
operation of biological warfare in that it is aimed at a deliberate disruption of
the biological conditions prevailing in t\ given area. Such distinctions simply
do not appear in official United States statements or documents; they were
long ago shrouded under heavy verbal cover. Thus, a State Department report,
made public in March. 1900, saying that, about twenty thousand acres of crops
Iti South Vietnam had been destroyed by defoliation to deny food to guerrillas,
described the areas involved as "remote and thinly populated," and gave a
firm assurance that the materials sprayed on the crops were of a mild and
transient potency: "The herbicides used are nontoxic and not dangerous to
man or animal life. The land is not affected for future use."
However comforting the statements issued by our government during seven
years of herbioidal operations in Vietnam, the fact is that the major development of defoliant chemicals (whose existence had been known in the thirties)
and other hcrbicidal agents came about in military programs for biological
wnrfnro. The direction of this work was set during the Second World War,
when Professor E. .T. Kraus, who then headed the Botany Department of the
University of Chicago, brought certain scientific possibilities to the attention of
a committee that had been set up by Henry L. Stiinson, the Secretary of War,
under the National Research Council, to provide the military with advice on
various aspects of biological warfare. Kraus, referring to the existence of hormone-liUe substances that experimentation had shown would kill certain plants
or disrupt their growth, suggested to the committee in 1941 that it might be
interested in "the toxic properties of growth-regulating substances for the
destruction of crops or the limitation of crop production." Military research on
herbicides thereupon got under way, principally at Camp (later Fort) Dctrick,
Maryland, the Army center for biological-warfare research. According to
George Merck, a chemist, who headed Stimson's biological-warfare advisory
committee, "Only the rapid ending of the war prevented field trials in an
active theatre of synthetic agents that would, without injury to human or
animal life, affect the growing crops and make them useless."
After the war. many of the herbicidal materials that had been developed
ami tcst&lt;'(l for biological-warfare use were marketed for civilian purposes and
used by farmers and homeowners for killing weeds and controlling brush. The
mo.st powerful of the herbicides were the two chemicals 2,4-dlchlorophenoxyacetic acid, generally known as 2,4-D, and 2.4,5-trichlorophenoxyncetic acid,
known as 2,4,5-T. The direct toxicity levels of these chemicals as they affected
experimental animals, and, by scientific estimates, men, appeared then to be
low (although these estimates have later been challenged), and the United
States Department of Agriculture, the Food and Drug Administration, and the
Fish and Wildlife Service all sanctioned the widespread sale and use of both.
The chemicals were also reported to be shortlived in soil after their application. 2.4-D was the bigger seller of the two, partly because it was cheaper, and
suburbanites commonly used mixtures containing 2,4-D on their lawns to control dandelions and other weeds. Commercially, 2,4-D and 2,4,5-T were used to
elfiir railroad rights-of-woy and power-line routes, and, in cattle country, to
get rid of woody brush, 2,4,5-T being favored for the last, because it was considered to have a more effective herbicidal action on'woody plants. Very often,
however, the two chemicals were used in combination. Between 1945 and 1963,
the production of herbicides jumped from nine hundred and seventeen thousand pounds to about a hundred and fifty million pounds in this country;

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since IOCS, their use had risen two hundred and seventy-one percent—more
limn double the rate of Increase in the use of pesticides, though pesticides are
still fur more extensively used. By I960, an area equivalent to more than three
jier cent of the entire United States was being sprayed each year with herbicides.
Considering the rapidly growing civilian use of these products, it is perhaps
not surprising that the defoliation operations in Vietnam escaped any significant, comment in the press, and that the American public remained unaware of
Mic extent to which these uses had their origin in planning for chemical and
biological warfare. Nevertheless, between 1941 and the present, testing and
experimentation in the use of 2,4-D, 2,4,5-T, and other herbicides as military
weapons were going forward very actively at Fort Detrick. While homeowners
were using herbicidal mixtures to keep their lawns free of weeds, the military
\vcre screening some twelve hundred compounds for their usefulness in biological-warfare operations. The most promising of these compounds were testsprayed on tropical vegetation in Puerto Rico and Thailand, and by the time
fullscale defoliation operations got under way in Vietnam the U.S. military
Mud settled on the use of four herbicidal spray materials there. These went
under the names Agent Orange, Agent Purple, Agent White, and Agent Blue—
designations derived from color-coded stripes girdling the shipping drums of
i&gt;ncli type of material.. Of these materials, Agent Orange, the most widely used
•is a general defoliant, consists of a fifty-fifty mixture of n butyl esters and of
•J.4-D and 2,4,5-T. Agent Purple, which Is interchangeable with Agent Orange,
consists of the same substances with slight molecular variations. Agent White,
which is used mostly for forest defoliation, is a combination of 2,4-D and
1'icloram, produced by the Dow Chemical Company. Unlike 2,4-D or 2,4,5-T,
which, after application, is said to be decomposable by micro-organisms in soil
over a period of weeks or months (one field test of 2,4,5-T in this country
showed that significant quantities persisted in soil for ninety-three days after
iipjillcation), Picloram—whose use the Department of Agriculture has not
authorized in the cultivation of any American crop—is one of the most persistent herbicides known. Dr. Arthur W. Galston, professor of biology at Yale, has
described Picloram as "a herbicidal analog of DDT," and an article in a Dow
Chemical Company publication called ''Down to Earth" reported that in field
trials of Picloram in various California soils between eighty and ninety-six
and a half per cent of the substance remained in the soils four hundred and
sixty-seven days after application. (The rate at which Picloram decomposes in
tropical soils may, however, be higher.) Agent Blue consists of. a solution of
ciicodylic acid, a substance that contains fifty-four per cent arsenic, and it is
used in Vietnam to destroy rice crops. According to the authoritative "Merck
Index," a source book on chemicals, this material is ''poisonous." It can be
used on agricultural crops in this country only under certain restrictions
imposed by the Department of Agriculture. It is being used herbicidally on
Vietnamese rice fields at seven and a half times the concentration permitted
for weed-killing purposes in this country, and so far in Vietnam something like
live thousand tons is estimated to have been sprayed on paddies and vegetable
tit-Ids.
Defoliation operations in Vietnam are carried out by a special flight of the
l-.'th Air Commando Squadron of the United States Air Force, from a base at
Itieii Hoa, just outside Saigon, with specially equipped C-123 cargo planes.
Kuril of these aircraft has been fitted out with tanks capable of holding a
thousand gallons. On defoliation missions, the herbicide carried in these tanks
is sprayed from an altitude of around a hundred and fifty feet, under pressure, from thirty-six nozzles on the wings and tall of the plane, and usually
several sprny planes work in formation, laying down broad blankets of spray.
The normal crew of a military herblcldal-spray plane consists of a pilot, a copilot, and a technician, who sits in the tail area and operates a console regulating the spray. The equipment is calibrated to spray a thousand gallons of
lierbicldal mixture at a rate that works out, when all goes well, to about three
gallons per acre. Spraying a thousand-gallon tankload takes five minutes. In
an emergency, the tank can be emptied in thirty seconds—a fact that has particular significance because of what has recently been learned about the nature
of at least one of the herbicidal substances.
The official code name for the program Is Operation Hades, but a more
friendly code name, Operation Ranch Hand, is commonly used. In similar fashion, military public-relations men refer to the herbicidal spraying of crops sup-

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posedly grown for Vietcong use in Vietnam, when they refer to it at all as ;\
"food-denial program." By contrast, an American biologist who is less than
enthusiastic about the effort has called it, in its current phase, "escalation to a
program of starvation of the population in the affected area." Dr. Jean Mayer,
the Harvard professor who now is President Nixon's special adviser on nutrition, contended In an article In Science and Citiscn in 1907 that the ultimate
target of herl'ieidal operations against rice and other crops in Vietnam was
"the weakest element of the civilian population"—that is, women, children, and
the elderly—because in the sprayed area "Vietcong soldiers may . . . be
expected to get the fighter's share of whatever food there is." He pointed out
that malnutrition is endemic in many parts of Southeast Asia but that in wartime South Vietnam, where diseases associated with malnutrition, such as
beri-beri, anemia, kwashiorkor (the disease that has decimated the Blafran
population), and tuberculosis, are particularly widespread, "there can be no
doubt that if the (crop-destruction) program is continued, (the) problems will
grow."
Whether a particular mission involves defoliation or crop destruction, American military spokesmen insist that a mission never takes place without careful
consideration of all the factors involved, including the welfare of friendly
inhabitants and the safety of American personnel. (There can'be little doubt
that defoliation missions are extremely hazardous to the members of the
planes' crews, for the planes are required to fly very low and only slightly
above stalling speed, and they are often targets of automatic-weapons flre from
the ground.) The process of setting up targets and approving specific herblcidal operations is theoretically subject to elaborate review through two parallel
chains of command: one chain consisting of South Vietnamese district and
province chiefs—who can themselves initiate such missions—and South Vietnamese Army commanders at various levels; the other a United States chain,
consisting of a district adviser, a sector adviser, a divisional senior adviser, a
corps senior adviser, the United States Military Assistance Command in South
Vietnam, and the American Embassy in Saigon, ending up with the American
ambassador himself. Positive justification of the military advantage likely to
be gained from each operation is theoretically required, and applications with
such positive justification are theoretically disapproved. However, according to
one of a series of articles by Elizabeth Pond that appeared toward the end of
1967 in the Christian Science Monitor:
"In practice, [American] corps advisers find it very difficult to turn down
defoliation requests from province level because they simply do not have
sufficient specific knowledge to call a proposed operation into question. Arid
with the momentum of six years' use of defoliants, the practice, in the words
of one source, has long since been "set in cement"
"The real burden of proof has long since shifted from the positive one of
justifying an operation by its [military] gains to the negative one of denying
an operation because of [specific] drawbacks. There is thus a great deal of
pressure, especially above province level, to approve recommendations sent n|&gt;
from below as a matter of course."
Miss Pond reported that American military sources In Saigon were "enthusiastic" about the defoliation program, and that American commanders and
spotter-plane pilots were "clamoring for more of the same." She was given
firm assurances as to the mild nature of the chemicals used in the spray operations :
"The defoliants used, according to the military spokesman contacted, are the
same herbicides . . . as those used commercially over some four million acres
in the United States. In the strengths used in Vietnam they are not at all
harmful to humans or animals, the spokesman pointed out, and in illustration
of this he dabbed onto his tongue a bit of liquid from one of ... three bottles
sitting on his desk."
As the apparently Inexorable advance of defoliation operations in South
Vietnam continued, a number of scientists in the United States began to pro.test the military use of herbicides, contending that'Vietnam was being used, in
effect, as a proving ground for chemical and biological warfare. Early in I960,
a group of twenty-nine scientists, under the leadership of Dr. John Edsall, a
professor of biochemistry at Harvard, appealed to President Johnson to prohibit the use of defoliants and crop-destroying herbicides, and called the use of
these substances in Vietnam "barbarous because they are indiscriminate." In
the late summer of 1966, this protest was followed by a letter of petition to

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president Johnson from twenty-two scientists, Including seven Nobel laureates.
The itetltlon pointed out that the "large-scale use of antlcrop and 'nonlethal'
antipersonnel chemical weapons In Vietnam" constituted "dangerous precedent"
in chemical nnd biological warfare, nnd it asked the President to order it
$topi&gt;ed. Before the end of that year, Dr. Bdsall and Dr. Matthew S. Meselson,
li Harvard professor of biology, obtained the signatures of five thousand scientists to co-sponsor the petition. Despite these protests, the area covered by
defoliation operations in Vietnam iu 1967 was double that covered in 1900, and
the acreage of crops destroyed was nearly doubled.
These figures relate only to areas that were sprayed intentionally. There is
no known way of.spraying an area with herbicides from the air in a really
accurate manner, because the material used Is so highly volatile, especially
under tropical conditions, that even light wind drift can cause extensive
damage to foliage and crops outside the deliberately sprayed area. Crops are
so sensitive to the herbicidal spray that it can cause damage to fields and gardens as much as fifteen miles away from the target zone. Particularly severe
accidental damage is reported, from time to time, to so-called "friendly" crops
in the III Corps area, which all but surrounds Saigon and extends in a rough
square from the coastline to -the Cambodian border. Most of the spraying in
111 Corps is now done in War Zones C and D, which are classified as free fire
/.onos, where, as one American official has put it, "everything that moves lu
Hones C and D is considered Charlie." A press dispatch from Saigon in 10G7
,|iioted another American official as saying that every Vietnamese farmer in
fliii* corps area knew of the defoliation program and disapproved of it. Dr.
(iiilston, the Yale biologist, who is one of the most persistent critics of American policy concerning herbicidal operations in Vietnam, recently said in an
interview, "We know that most of the truck crops grown along roads, canals,
.-mil trails and formerly brought Into Saigon have been essentially abandoned
because of the deliberate or Inadvertent falling of these defoliant sprays:
ninny crops In the Saigon area are simply not being harvested." He also cited
reports that in some instances iu which the Inhabitants of Vietnamese villages
have been suspected of being Vietcong sympathizers the destruction of food
crops bus brought about complete abandonment of the villages. In 10GO, herbicidal operations caused extensive inadvertent damage, through wind drift, to a
very large rubber plantation northwest of Saigon owned by the Michel In
rubber Interests. As the result of claims made for this damage, the South Vietnamese authorities paid the corporate owners, through the American military,
nearly a million dollars. The extent of the known Inadvertent damage to crops
in Vietnam can be Inferred from the South Vietnamese budget—in reality, the
American military budget—for settling such claims. In 1907, the budget for
this compensation was three million six hundred thousand dollars. This sum.
however, probably reflects only the barest emergency claims of the people
affected.
According to Representative Richard D. McCarthy, a Democrat from upstate
Xow York who has been n strong critic of the p'rogram, the policy of allowing
applications for defoliation operations to flow, usually without question, from
the level of the South Vietnamese provincial or district chiefs has meant that
these local functionaries would order repeated sprayings of areas that they
had not visited in months, or even years. The thought that a Vietnamese district chief can initiate such wholesale spraying, in effect without much likelihood of serious hindrance by American military advisers, is a disquieting one
to a number of biologists. Something that disquiets many of them even more is
what they believe the long-range effects of nine years of defoliation operations
will be on the ecology of South Vietnam. Dr. Galston, testifying recently
hefore a congressional subcommittee on chemical and biological warfare, made
these observations:
"It has already been well documented that some kinds of plant associations
subject to spray, especially by Agent Orange, containing 2,4-D and 2,4,5-T, have
Leon irreversibly damaged. I refer specifically to the mangrove associations
that line the estuaries, especially around the Saigon River. Up to a hundred
thousand acres of these mangroves have been sprayed. . . . Some (mangrove
areas) had been sprayed as early as 1961 and have shown no substantial signs
at recovery. . . . Ecologists have known for a long time that the mangroves
lining estuaries furnish one of the most important ecological niches for the
completion of the life cycle of certain shellfish and migratory fish. If these
plant communities are not in a healthy state, secondary effects on the whole

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Interlocked web of organisms art- bound to occur. . . . In tlie years nheml the
Vietnamese, who do not have overabundant sources of proteins nn.vliow. are
probably going to suffer tlletarily because of the deprivation of food in the
form of fish and shellfish.
"Damage to the soil is another possible consequence of extensive defoliation.
. . . \Vo know that the soil is not a dead, inert mass but, rather, that It is a
vilmint, living community. . . . If you knock the leaves off of trees once, twice,
or three times . . . you change the quality of the soil. . . . Certain tropical
soils—and It has been estimated that in Vietnam up to fifty per cent of all the
soils fall into this category—are laterizable: that is, they may be irreversibly
converted to rock as a result of the deprivation of organic matter. . . . If ...
you deprive trees of leaves and photosynthesis stops, organic matter in the soil
declines and laterization, the making of brick, may occur on a very extensive
scale. I would emphasize that this brick is Irreversibly hardened: It can't be
made back into soil. . . .
"Another ecological consequence is the invasion of an area by undesirable
plants. One of the main plants that invade an area that has been defoliated is
bamboo. Bamboo is one of the most difficult of all plants to destroy once it
becomes established where you don't want it. It is not amenable to killing by
herbicides. Frequently it has to be burned over, and this causes tremendous
dislocations to agriculture."
Dr. Fred H. Tschirley, assistant chief of the Crops Protection Research
Branch of the Department of Agriculture, who made a month's visit to Vietnam In the spring of 1908 in behalf of the State Department to report on the
ecological effects of herbicidal operations there, does not agree with Dr. Galston's view that laterization of the soil is a serious probability. However, lie
reported to the State Department that in the Rung Sat area, southeast of
Saigon, where about a hundred thousand acres of mangrove trees had been
sprayed with defoliant, each single application of Agent Orange had killed
ninety to a hundred per cent of the mangroves touched by the spray, and he
estimated that the regeneration of the mangroves in this area would take
another twenty years, at least. Dr. Tschirley agrees with Dr. Galston that a
biological danger attending the defoliation of mangroves Is an invasion of virtually ineradicable bamboo.
A fairly well-documented example not only of the ecological consequences of
defoliation operations but also of their disruptive effects on human life was
provided last year by a rubber-plantation area in Kompong Cham Province,
Cambodia, which lies just across the border from Vietnam's Tay Xinh Province. On June 2, 190!), the Cambodian government, in an angry diplomatic note
to the, United States government, charged the United States with major defoliation damage to rubber plantations, and also to farm and garden crops in the
province, through herbicidal operations deliberately conducted on Cambodian
soil. It demanded compensation of eight and a half million dollars for destruction or serious damage to twenty-four thousand acres of trees and crops. After
some delay, the State Department conceded that the alleged damage might be:
connected with "accidental drift" of spray over the border from herbicidal
operations in Tay Nlnh Province. The Defense Department flatly denied that
the Cambodian areas had been deliberately sprayed. Late in June, the State
Department sent a team of four American scientists to Cambodia, and they
confirmed the extent of the area of damage that the Cambodians hud claimed.
They found that although some evidence of spray drift across the Vietnamese
border existed, the extent and severity of damage in the area worst affected
were such that "it is highly unlikely that this quantity could have drifted over
the border from the Tay N'inh defoliation operations." Their report added,
"The evidence we have seen, though circumstantial, suggests strongly that
damage was caused by direct overflight." A second report on herbicidal
damage to the area was made after an unofficial party of American biologists,
Including Professor E. W. Pfeiffer, of the University of Montana, and Professor Arthur H. Westing, or Windham College, Vermont, visited Cambodia last
December at the invitation of the Cambodian government. They found that
about a third of all the rubber trees currently in production In Cambodia had
been damaged, and this had happened in an area that normally had the highest latex yield per acre of any in the world. A high proportion of two varieties
of rubber trees in the area had died as a result of the damage, and Dr. WestIng estimated that the damage to the latex-producing capacity of some varieties might persist for twenty years. Between May and November of last year,

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latex production in the affected plantations fell off by nn average of between
tlilrty-flve and forty per cent. According to a report by the two scientists, "A
largo variety of garden crops were devastated in the seemingly endless number
of small villages scattered throughout the affected area. Virtually all of the . . .
local inhabitants . . . depend for their wellbeing upon their own local produce. These people saw their crops . . . literally wither before their eyes." The
Cambodian claim is still pending.
Until the end of last year, the criticism by biologists of the dangers involved
in the use of herbicides centered on their use in what were increasingly construed as biological-warfare operations, and on the disruptive effects of these
chemicals upon civilian populations and upon the ecology of the regions in which
they were used. Last year, however, certain biologists began to raise serious
questions on another score—possible direct hazards to life from 2,4,5-T. On
October 20th, as a result of these questions, a statement was publicly issued
by Dr. Lee DuBridge, President Nixon's science adviser. In summary, the
statement said that because a laboratory study of mice and rats that had been
given relatively high oral doses of 2,4,5-T in early stages of pregnancy
"showed a higher than expected number of deformities" in the offspring, the
government would, as a precautionary measure, undertake a series of coordinated actions to restrict the-use of 2,4,5-T in both domestic civilian applications and military herbicidal operations. The DuBridge statement identified the
laboratory study as having been made by an organization called the Bionetics
Research Laboratories, In Bethesda, Maryland, but gave no details of either
the findings or the data on which they were based. This absence of specific
Information turned out to be characteristic of what has been made available to
the public concerning this particular research project. From the hesinnin;:. it
seems, there was an extraordinary reluctance to discuss details of the purported ill effects of 2,4,5-T on animals. Six weeks after the publication of the
DuHridge statement, a journalist who was attempting to obtain a copy of the
full report made by Bionetics and to discuss its details with some of the government officials concerned encountered hard going. At the Bionetics Laboratories, an official said that lie couldn't talk about the study, because "we're
under wraps to the National Institutes of Health"—the government agency
dint commissioned the study. Then, having been asked what the specific doses
of 2,4,5-T were that were said to have increased birth defects in the fetuses of
experimental animals, the Bionetics official cut off discussion by saying.
-You're asking sophisticated questions that as a layman you don't have the
equipment to understand the answers to." At the National Institutes of
Health, an official who was asked for details of or a copy of the study on
2.4,5-T replied. "The position I'm in is that I have been requested not to distribute this Information." He did say, however, that a continuing evaluation of
die study was under way at the National Institute of Environmental Health
Sciences, at Research Triangle Park, North Carolina. A telephone call to an
i.nicer of this organization brought a response whose tone varied from wariness of downright hostility and made it clear that the official had no intention
nf discussing details or results of the study with the press.
The Bionetics study on 2,4,5-T was part of a series carried out under contract to the National Cancer Institute, which is nn arm of the National Institutes of Health, to investigate more than two hundred compounds, most of
them, pesticides, in order to determine whether they induced cancer-causing
changes, fetus-deforming changes, or mutation-causing changes in exiierimental
.uihnals. The contract was a large one&gt; involving more than two and a half
million dollars' worth of research, and its primary purpose was to screen out
suspicious-looking substances for further study. The first visible fruits of the
Hlonetics research were presented in March of last year before a convention of
ihe American Association for the Advancement of Science, in the form of a
study of possible carcinogenic properties of the fifty-three compounds: the findings on 2,4,5-T were that it did not appear to cause carcinogenic changes in
tlie animals studied.
Ily the time the report on the carcinogenic properties of the substances was
presented, the results of another part of the Bionetics studies, concerning the
[erotogenic, or fetus-deforming, properties of the substances, were being compiled, but these results were not immediately made available to biologists outside, the government. The data remained—somewhat frustrating!?, in the view
of some scientists who had been most curious about the effects of herbicides—
,,iit of sight, and n number of attempts by biologists who bad heard about the

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teratological study of 2,4,5-T to get at its findings appear to have been
thwarted by the authorities involved. Upon being asked to account for the
apparent delay In making tills Information available to biologists, an official of
the National Institute of Environmental Health Sciences (another branch of
the Nntioiiiil Institutes of Health) has declared, with some heat, that the
results of the study Itself and of a statistical summary of the findings prepared by the Institute were in fact passed on as they were completed to the
Commission on Pesticides and Their Relationship to Environmental Health, a
scientific group appointed by Secretary of Health, Education, and Welfare
Robert Finch and known—after its chairman, Dr. E. M. Mrak, of the University of California—as the Mrak Commission. Dr. Samuel 8. Epstein, chief of
the Laboratories of Environmental Toxicology and Carcinogenesis at the Children's Cancer Research Foundation in Boston, who was co-chairman of the
Mrak Commission panel considering the teratogenic potential of pesticides,
tells a different story on the availability of the Blonetics study. He says that
he first heard about it in February. At a meeting of his panel in August, he
asked for a copy of the report. Ten days later, the panel was told that the
Nntioiiiil Institute of Environmental Health Sciences would be willing to provide a sf:itisrical summary but that the group could not have access to the full
report on which the summary was based. Dr. Epstein says that the panel eventually got the full report on September 24th "by pulling teeth."
Actually, as f;ir buck as February, officials at the National Cancer Institute
had known, on the basis of a preliminary written outline from Bionetlcs, the
findings of the Bionetlcs scientists on the fetus-deforming role of 2,4,5-T. Dr.
Richard Bates, the officer of the National Institutes of Health who was in
charge of coordinating the Bionetlcs project, has said that during the same
month this information was put into the hands of officials of the Food and
Drug Administration, the Department of Agriculture, and the Department of
Defense. "V\"e bad a meeting with a couple of scientists from Fort Detrick,
and we informed them of what we had learned," Dr. Bates said recently. "I
don't know whether they were the right people for us to see. We didn't hear
from then', again until after the DuBridge announcement at the White House.
Then they railed up Mild asked for a copy of the Bionetics report."
At the Department of Agriculture, which Dr. Bates said had been Informed
In Febrn.iry of the preliminary Bionetics findings, Dr. Tschirley, one of the
officials most intimately concerned with the permissible uses of herbicldal compounds, says that he first heard about the report on 2.4.5-T through the
DuBrid.se announcement. At the Food and Drug Administration, where appropriate officials had been informed in February of the teratogenic potential of
'J.4.5-T. no new action was taken to safeguard the public against 2,4,"&gt;-T in
foods-tuffs. In fact. It appears that no action at nil was taken by the Food and
Drug Administration on the matter during the whole of last year. The explanation that F.D.A. official* have offered for this inaction is that they were
under instructions to leave the whole question alone nt least until December,
because the matter was under definitive study by the Mrak Commission—the
very group whose members, as it turns out, had such extraordinary difficulty
in obtaining the Bionetlcs data. The Food Toxicology Branch of the F.D.A. did
not have acce«s to the full Bloneties report on 2,4,5-T until after Dr. DuBridge
issued bis statement, at the end of October.
Thus, after the first word went to various agencies about the fetus-deforming potential of 2,4,5-T. and warning lights could have flashed on in every
branch of the government and in the headquarters of every company manufacturing or handling it, literally almost nothing was done by the officials charged
with protecting the public from exposure to dangerous or potentially dangerous
materials—by the officials in the F.D.A.. In the Department of Agriculture, and
In the Department of Defense. It is conceivable that the Bionetics findings
might still be hidden from the public if they had not been pried loose in midsummer through the activities of a group of young law students. The students
wen- members of a team put together by the consumer-protection activist
Ralph Nader—and often referred to ns Nader's Raiders—to explore the labyrinthine workings of the Food and Drug Administration. In the course of their
Investigations, one of the law students, a young woman named Anita Johnson,
happened to see a copy of the preliminary report on the Bionetics findings that
had been passed on to the F.D.A. In February, and its observations seemed
quite disturbing to her. Miss Johnson wrote a report to Nader, and in September sbo showed a copy of the report to a friend who was a biology student at

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115
Harvard. In early October, Miss Johnson's friend, in a conversation with Professor Matthew Meselson, mentioned Miss Johnson's report on the preliminary
Bionetics findings. This was the first that Dr. Meselson had beard of the existence of the Bionetics study. A. few days previously, he had received a call
from a scientist friend of his asking whether Dr. Meselson had heard of certain stories, originating with South Vietnamese journalists and other South
Vietnamese, of an unusual incidence of birth defects in South Vietnam, which
were alleged to be connected with defoliation operations there.
A. few days later, after bis friend sent him further information, Mr. Meselson decided to obtain a copy of the Bionetics report, and he called up an
acquaintance in a government agency and asked for it He was told that the
report was "confidential and classified," and inaccessible to outsiders. Actually,
In addition to the preliminary report there were now in existence the full Bionetics report and a statistical summary prepared by the National Institute of
Environmental Health Sciences, and, by nagging various Washington friends.
Dr. Meselson obtained bootlegged copies of the two latest reports. What he
read seemed to him to have such serious implications that he got in touch
with acquaintances in the. White House and also with someone in the Army to
alert them to the problems of 2,4,5-T, in the hope that some new restriction
would be placed on its use. According to Dr. Meselson, the White House people
apparently didn't know until that moment that the reports on the adverse
effects of 2,4,5-T even existed. (Around that time, according to a member of
Nader's Raiders, "a tremendous lid was put on this thing" within government
agencies, and on the subject of the Bionetics work and 2,4,5-T "people in government whom we'd been talking to freely for years just shut up and wouldn't
say a word.") While Dr. Meselson awaited word on the matter, a colleague
of his informed the press about the findings of the Bionetics report. Very shortly
thereafter, Dr. DuBridge made his public announcement of the proposed
restrictions on the use of 2,4,5-T.
In certain respects, the DuBridge announcement is a curious document. In
its approach to the facts about 2,4,5-T that were set forth in the Bionetics
report, it reflects considerable sensitivity to the political and international
issues that lie behind the widespread use of this powerful herbicide for civilian and military purposes, and the words in which it describes the reasons for
restricting its use appear to have been very carefully chosen:
"The actions to control the use of the chemical were 'taken as a result of
findings from a laboratory study conducted by Bionetics Research Laboratories
which indicated that offspring of mice and rats given relatively large oral
doses of the herbicide during early stages of pregnancy showed a higher than
expected number of deformities.
"Although it seems improbable that any person could receive harmful
amounts of this chemical from any of the existing uses of 2,4,5-T, and while
the relationships of these effects in laboratory animals to effects in man are
not entirely clear at this time, the actions taken will assure safety of the
public while further evidence is being sought."
These actions, according to the statement, included decisions that the
Department of Agriculture would cancel manufacturers' registrations of 2,4,5-T
fur use on food crops, effective at the beginning of 1970, "unless by that time
the Food and Drug Administration has found a basis for establishing a safe
legal tolerance in and on foods," and that the Departments of Agriculture and
the Interior, in their own programs, would stop the use of 2,4,5-T in iwpulated
ureas and in all other areas where residues of the substance could reach man.
As for military uses of 2,4,5-T, the statement said, "The chemical is effective
in defoliating trees and shrubs and its use in South Vietnam has resulted in
reducing greatly the number of ambushes, thus saving lives." However, the
statement continued, "the Department of Defense will [henceforth] restrict the
use of 2,4,5-T to areas remote from the population."
AH this sounds eminently fair and sensible, but whether it represents a
candid exposition of the facts about 2,4,5-T and the Biouetics report is debatable. The White House statement that the Bionetics findings "Indicated that
offspring of mice and rats given relatively large oral doses of the herbicide
.luring early stages of pregnancy showed a higher than expected number of
deformities" is, in the words of one eminent biologist who has studied the Bionetics data, "an understatement" He went on to say that "If the effects on
experimental animals are applicable to people it's a very sad and serious situa-

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tion." The actual Bionetics report described 2,4,5-T as producing "sufficiently
prominent effects of seriously hazardous nature" In controlled experiments
with pregnant mice to lead the authors "to categorize [it] as probably dangerous." The report also found 2,4-D "potentially dangerous hut needing further
study." As for 2,4,5-T, the report noted that, with the exception of very small
subcutaneous dosages, "all dosages, routes, and strains resulted in increased
incidence of abnormal fetuses" after its administration. The abnormalities in
the fetuses included lack of eyes, faulty eyes, cystic kidneys, cleft palates, and
enlarged livers. The Bionetics report went, on to report on further experimental applications of 2,4,5-T to another species :
•'Been use of the potential importance of the findings in mice, an additional
study was carried out in rats of the Sprague-Dawley strain. Using dosages of
31.5 and 40.4 mg/kg [that is. dosages scaled to represent 21.5 and 40.4 milligrams of 2.4,5-T per kilogram of the experimental animal's body weight] sus(tended in so i&gt;er cent honey and given by the oral route on the Gth through
15th days of gestation, we observed excessive fetal mortality almost SO per
t-ont i and a high Incidence of abnormalities in the survivors. When the beginning of mlmintstratiou was delayed until the 10th day, fetal mortality was
somewhat less but still quite high even when dosage was reduced to 4.C ing/kg.
The incidence of abnormal fetuses was threefold that in controls even with the
smallest dosage and shortest period used. . . .
Ir seems inescapable the 2,4.5-T is terutogenic in- this strain of rats when
given orally at the dosage schedules used here."
Considering the fetus-deforming effects of the lowest oral dosage of 2,4,5-T
used In Bionetics work on rats—to say nothing of the excessive fetal mortality
—the White House statement that "relatively large oral doses of the herbicide
. . . showt-d a higher than expected number of deformities" is hardly an accurate description of the results of the study. In fact, the statistical tables presented as part of the Bionetics report showed that at the lowest oral dosage of
2.4.5-T given to pregnant rats between the tenth and fifteenth days of gestation thirty-nine per cent of the fetuses produced were abnormal, or three times
the figure for control animals. At what could without much question be
described as "relatively large oral doses" of the herbicide— dosages of 21.5 and
40.4 milligrams |&gt;er kilogram of body weight of rats, for example—the percentage of abnormal fetuses was ninety and a hundred per cent, respectively, or a
good bit higher than one would he likely to deduce from the phrase "a higher
than expected number of deformities." The assertion that "it seems improbable
that any nerson could receive harmful amounts of this chemical from any of
the existing uses of 2.4.5-T" also appears to be worth examining for this is
precisely what many biologists are most worried about in relation to 2,4,5-T
and allied substances.
It *eems fair, before going further, to quote a cautionary note in the
DuBrirtge statement: "The study involved relatively small numbers of laboratory rats and mice. More extensive studies are needed and will IH&gt; undertaken,
At best it is difficult to extrapolate results obtained with laboratory animals to
111:111 — sensitivity to a given compound may be different In man than in animal
species. . . ." it would be difficult to get a biologist to disagree with these
seemingly sound generalities. However, the first part of the statement doc*
imply. :\t least to a layman, that the number of experimental animals used In
the Bionetics study had been considerably smaller than the numbers used to
test commercial compounds other than 2,4.5-T before they are approved l)jagencies such as the Food and Drug Administration and the Department of
Agriculture. In this connection, the curious layman could reasonably begin
with thi( recommendations. In 10t&gt;3. of the President's Science Advisory Committee on the use of pesticides, which proposed that companies putting out pesticides should be required from then on to demonstrate the safety of their
products by means of toxlcity studies on two generations of at least two
warm-blooded mammalian species. Subsequently, the F.D.A. set up new testing
requirements, based on these recommendations, for companies producing pesticides. However, according to Dr. Joseph McLaughlin, of the Food Toxicolosy
Branch of the F.D.A., the organization actually requires applicants for permission to sell pesticides to present the results of tests on only one species
(usually, in practice, the rat). According to Dr. McLaughlin, the average
number of experimental animals used in studies of pesticides is between eighty
and a hundred and sixty, including animals used as controls but excluding litters produced. The Bionetics studies of 2,4,5-T used both mice and rats, and

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117
their total number was, in fact, greater, not less, than this average. Including
controls but excluding litters, the total number of animals used in the 2,4,5-T
studies was two hundred and twenty-five. Analysis of the results by the
National Institute of Environmental Health Sciences found them statistically
"significant," and this is the real purpose of such a study: it is meant to act
MS a coarse screen to shake out of the data the larger lumps of bad news.
Such n study Is usually incapable of shaking out anything smaller; another
kind of study is needed to do that.
Thus, the DuBrldge statement seems to give rise to this question: If the
Hionetlcs study, based on the effects of 2,4,5-T on two hundred and twenty-five
experimental animals of two si*cles, appears to be less than conclusive, on the
ground that "the study Involved relatively small numbers of laboratory rats
n ud mice,'' what is one to think of the adequacy of the tests that the manufacturers of pesticides make? If, as the DuBridge statement says, "at best it is
difficult to extrapolate results obtained with laboratory animals to man," what
is one to say of tiic protection that the government affords the consumer when
the results of tests of pesticidal substances on perhaps a hundred and twenty
r;its are officially extrapolated to justify the use of the substances by a population of two hundred million people—not to mention one to two million
unborn babies being carried in their mothers' wombs?
The very coarseness of the screen used in all these tests—that is, the relatively small number of animals involved—means that the bad news that shows
up in the data has to be taken with particular seriousness, because lesser
rllVcts tend not to be demonstrable at all. The inadequacy of the scale on
which animal tests with, for instance, pesticides are currently being made in
ilils country to gain F.P.A. approval is further indicated by the fact that a
fetus-deforming effect that might show up if a thousand test animals were
used is almost never picked up, since the studies are not conducted on that
si-ale; yet if the material being tested turned out to have the same effect,
quantitatively, on human beings, this would mean that it would cause between
throe and four thousand malformed babies to be produced each year. The teratogenic effects of 2,4,5-T on experimental animals used by the Bionetlcs people,
however, were not on the order of one in a thousand. Even in the case of the
lowest oral dose given rats, they were on the order of one in three.
Again, it is fair to say that what is applicable to rats in such tests may not
IK- applicable to human beings. But it is also fair to say that studies involving
rats are conducted not for the welfare of the rat kingdom but for the ultimate
protection of human beings. In the opinion of Dr. Epstein, the fact that the
J.4.5-T used in the Blonetics study produced teratogenlc effects in both mice
and ruts underlines the seriousness of the study's implications. In the opinion
nt' Dr. McLaughlin, this is even further underlined by another circumstance—
Hint the rat, as a test animal, tends to be relatively resistant to teratogenlc
effects of chemicals. For example, in the late nineteen-flfties, when thalidoinide, that disastrously terntogenic compound, was being tested on rats in oral
dosages ranging from low to very high, no discernible fetus-deforming effects
were produced. And Dr. McLaughlin says that as far as thalidomide tests on
rabbits were concerned, ''You could give thalidomide to rabbits in oral doses at
itftwccn fifty and two hundred times the comparable human level to show any
••uiiipiimble teratogenic effects." In babies born to women who took thalidouiiili', whether In small or large dosages and whether in single or multiple dosiisrcs. between the sixth and seventh weeks of pregnancy, the rate of deformation was estimated to be one in ten.
liwiuisi? of the relatively coarse testing screen through which compounds
like pesticides—and food additives as well—are sifted before they are
approved for general or specialized use in this country, the Food and Drug
Administration theoretically maintains a policy of stipulating, us a safety
factor, that the maximum amount of such a substance allowable in the human
.lirt range from one two-thousandth to one one-hundredth of the highest
dosage level of the substance that produces no harmful effects in experimental
animals. (In the case of pesticides, the World Health Organization takes n
more conservative view, considering one two-thousandth of the "no-effect" level
in animal studies to be a resaonsable safety level for human exposure.)
According to the standards of safety established by F.D.A. policy, then, no
human being anywhere should ever have been exposed to 2,4,5-T, because in
the Jlionetics study of rats every dosage level produced deformed fetuses. A
-no-effect" level was never achieved.

�us
To make a reasonable guess about the general safety of 2,4,5-T for human
beings, as the material has been used up to now, the most appropriate population area to observe Is probably not the relatively healthy and well-fed United
States, where human beings are perhaps better equipped to withstand the
assault of toxic substances, but South Vietnam, where great numbers of civilians are half-starved, ravaged by disease, and racked by the Innumerable horrors of war. In considering any potentially harmful effects of 2,4,5-T on human
beings in Vietnam, some attempt has to be made to estimate the amount of
2,4,5-T to which people, and particularly pregnant women, may have been
exposed as a result of the repeated defoliation operations. To do so, a comparison of known rates of application of 2,4.5-T in the United States and in Vietnam is in order. In this country, according to Dr. Tschirley, the average recommended application of 2,4,5-T In aerial spraying for woody-plant control is
between three-quarters of a pound and a pound per acre. Therre are about five
manufacturers of 2,4,5-T in this country, of which the Dow Chemical Company
Is one of the biggest. One of Dow Chemical's best-sellers in the 2,4,5-T line is
Esteron 245 Concentrate, and the cautionary notes that a drum of Esteron
bears on its label are hardly reassuring to someone lulled by prior allgeatlons
that 2.4.5-T is a substance of low toxlclty:
"Caution—may cause skin irriation. avoid contact with eyes, skin, and clothing keep out of the reach of children."
Under the word "warning" are a number of Instructions concerning safe use
of the material, and these include, presumably for good reason, the following
admonition:
"Do not contaminate irrigation ditches or water used for domestic purposes
Then comes a ''notice":
"Seller makes no warranty of any kind, express or Implied, concerning the
use of this product. Buyer assumes all risk of use or handling, whether in
accordance with directions or not."
The concentration of Esteron recommended—subject to all these warnings,
cautions, and disclaimers—for aerial spraying In the United States varies wltli
the type of vegetation to be sprayed, but probably a fair average would be
three-quarters to one pound acid equivalent of the raw 2,4,5-T per acre. In
Vietnam, however, the concentration of 2,4,5-T for each acre sprayed has been
far higher. In Agent Orange, the concentrations of 2,4.5-T have averaged thirteen times the recommended concentrations used in the United States. The
principal route through which quantities of 2,4,5-T might be expected to enter
the human system in Vietnam is through drinking water, and in the arens
sprayed most drinking water comes either from rainwater cisterns fed from
house roofs or from very shallow wells. It has been calculated that, taking
into account the average amount of 2,4,5-T in Agent Orange sprayed per acre
in Vietnam by the military, and assuming a one-inch rainfall (which is quite
common in South Vietnam) after a spraying, a forty-kilo (about eighty-eightpound) Vietnamese woman drinking two litres (about 1.8 quarts) -of contaminated water a day could very well be absorbing into her system a hundred and
twenty milligrams, or about one two-hundred-and-flftieth of an ounce, of 2.4,5-T
a day: that is. a dally oral dosage of three milligrams of 2,4,5-T per kilo of
body weight. Thus, if a Vietnamese woman who was exposed to Agent Orange
was pregnant, she might very well be absorbing into her system a percentage
of 2.4.5-T only slightly less than the percentage that deformed one out of every
three fetuses of the pregnant experimental rats. To pursue further the question of exposure of Vietnamese to 2.4,5-T concentrations In relation to concentrations officially considered safe for Americans, an advisory subcommittee to
the Secretary of the Interior, in setting up guide-lines for maximum safe contamination of surface water by pesticides and allied substances some time ago.
recommended a concentration of one-tenth of a milligram of 2,4.5-T in one litre
of drinking water as the maximum safe concentration. Thus, n pregnant Vietnamese woman who ingested a hundred and twenty milligrams of 2.4.5-T In
two litres of water a day would be exposed to 2,4.5-T at six hundred times tlie
concentration officially considered safe for Americans.
Moreover, the level of exposure of Vietnamese people in sprayed areas is not
necessarily limited to the concentrations shown in Dr. Meselson's calculations.
Sometimes the level may be far higher. Dr. Pfelffer, the University of Montnnn biologist, snys that when difficulties arise with the spray planes or tlie
spray apparatus, or when other accidents occur, an entire thousand-gallon load
of herbicidal agent containing 2.4,5-T may be dumped in one area by moans of

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the thirty-second emergency-dumping procedure. Dr. Pfeiffer has recalled going
along as an observer on a United States defoliation mission last March, over
the Plain of Reeds area of Vietnam, near the Cambodian border, during which
the technician at the spray controls was unable to get the apparatus to work,
and thereupon dumped bis whole load. "This rained down a dose of 2,4,5-T
that must have been fantastically concentrated," Dr. Pfelffer has said. "It was
released on a very watery spot that looked like headwaters draining into the
Mekong River, which hundreds of thousands of people use? In another
instance, he has recalled, u pilot going over the area of the supposedly
••friendly" Catholic refugee villages of Ho Nai, near Bien Hoa, had serious
engine trouble and dumped his whole spray load of herbicide on or near the
village. In such instance, the concentration of 2,4,5-T dumped upon an inhabited area in Vietnam probably averaged about a hundred and thirty times the
concentration reccommended by 2,4,5-T manufacturers as both effective and
safe for use in the United States.
Theoretically, the dangers inherent in the use of 2,4,5-T should have been
removed by means of the steps promised in the White House announcement
hist October. A. quick reading of the statement by Dr. DuBridge (who is also
the executive secretary of the President's Environmental Quality Council) certainly seemed to convey the impression that from that day onward there
would be a change in Department of Defense policy on the use of 2,4,5-T in
Vietnam, just as there would be a change in the policies of the Departments
of Agriculture and the Interior on the domestic use of 2,4,5-T. But did the
White House mean what it certainly seemed to be saying about the future military use of 2,4,5-T in Vietnam? The White House statement was issued on
October 20th. On October 30th, the Pentagon announced that no change would
be made in the policy governing the military use of 2,4,5-T in South Vietnam,
ht-cause—so the Washington Post reported on October 31st—"the Defense
Department feels its present policy conforms to the new Presidential directive." The Post article went on:
"\ Pentagon spokesman's explanation of the policy, read at a morning press
briefing, differed markedly from the written version given reporters later.
"When the written statement was distributed, reporters were told not to use
the spokesman's [previous] comment that the defoliant . . . Is used against
oiiemy 'training and regroupment centers.'
"The statement was expunged after a reporter asked how use against such
centers conformed to the Defense Department's stated policy of prohibiting its
use In 'populated areas.1"
But the statement wasn't so easily expunged. A short time later, it was
made again, In essence, by Rear Admiral William E. Lemos, of the Policy
IMniw and National Security Council Affairs Office of the Department of
Defense, In testimony before a subcommittee of the House Foreign Affairs
Committee, the only difference being that the phrase "training and regroupment centers" became "enemy base camps." And in testifying that the military
was mounting herbicidal operations on alleged enemy base camps Rear Admiral Ijcmos said:
•'We know . . . that the enemy will move from areas that have been sprayed.
Therefore, enemy base camps or unit headquarters are sprayed In order to
make him move to avoid exposing himself to aerial observation."
If one adds to the words "enemy base camps" the expunged words "training
and regroupment centers"—centers that are unlikely to operate without an
accompanying civilian population—what the Defense Department seems
actually to be indicating Is that the "areas remote from the population"
against which the United States is conducting military herbicidal operations
are "remote from the population" at least in part because of these Derations.
As for the Blonetlcs findings on the teratogenic effects of 2,4,5-T on experimental animals, the Department of Defense indicated that it put little stock in
the dangers suggested by the report. A reporter for the Yale Daily News who
telephoned the Pentagon during the first week in December to inquire about
the Defense Department's attitude toward its use of 2,4,5-T in the light of the
Itionetics report was assured that "there is no cause for alarm about defoliants." A week or so later, he received a letter from the Directorate for
Defense Information at the Pentagon which described the Bionetlcs results as
based on "evidence that 2,4,5-T, when fed in large amounts to highly imbred
and susceptible mice and rats, gave a higher incidence of birth defects than
was normal for these animals." After reading this letter, the Yale Daily A'eie*

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reporter again telephoned the Pentagon, and asked, "Does [the Department of
Defense] think defoliants could be affecting embryo growth in any way in
Vietnam?" The Pentagon spokesman said, "No." And that was that. The experimental animals were highly susceptible: the civilian Vietname.se population,
which even under "normal" circumstances Is the victim of a statistically incalculable but clearly very high abortion and infant-mortality rate, was not.
Nearly a month after Dr. DuBridge's statement, another was issued, this one
by the President himself, on United States policy on chemical and biological
warfare. The President, noting that "biological weapons have massive, unpredictable, and potentially uncontrollable consequences" that might "impair the
health of future generations," anuouncced it as his decision that thenceforward "the United States shall renounce the use of lethal biological agents
and weapons, and all other methods of biological warfare." Later, a White
House spokesman, In answer to questions by reporters whether this included
the use of hcrbiddal, defoliant, or crop-killing chemicals in Vietnam, made It
clear that the new policy did not encompass herbicides.
Since the President's statement did specifically renounce "all other methods
of biological warfare," the reasonable assumption Is that the United States
government does not consider herbicldal, defoliant, and crop-killing operations
against military and civilian populations to be part of biological warfare. The
question then-fore remains: What does the United States government consider
biological warfare to consist of? The best place to look for an authoritative
definition is a work known as the Joint Chiefs of Staff Dictionary, an official
publication that governs proper word usage within the military establishment.
In the current edition of the Joint Chiefs of Staff Dictionary, "biological warfare" is defined as the "employment of living organisms, toxic biological products, and plant-growth regulators to produce death or casulaties in man, animals, or plants or defense against such action." But the term "plant-growth
regulators" is nowhere defined in the Joint Chiefs of Staff Dictionary, and
since a certain technical distinction might be made (by weed-control scientists,
for example) between plant-growth regulators and defoliants, the question of
whether the Joint Chiefs consider military defoliation operations part of biological warfare is left unclear. As for "defoliant agents," the Dictionary
defines such an agent only as "a chemical which causes trees, shrubs, and the
other plants to shed their leaves prematurely." All this is hardly a surprise to
anyone familiar with the fast semantic legerdemain Involved in all official statements on biological warfare, in which defoliation has the baffingly evanescent
half-existence of a pea under a shell.
To find that pea in the official literature is not easy. But it is resonable to
assume that if the Department of Defense were to concede officially that
"defoliant agents" were in the same category as "plant-growth regulators" that
"produce death . . . in plants," it would thereby also be conceding that it is in
f'nct engaging in the biological warfare that President Nixon has renounced.
And such a concession seems to have been run to earth in the current edition
of a Department of the Army publication entitled "Manual on Use of Herbicides for Military Purposes," in which "antiplant agents" are defined as
"chemical agents which possess a high offensive potential for destroying or
seriously limiting the production of food and defoliating vegetation," and goes
on "These compounds Include herbicides that kill or inhibit the growth of
plants: plant-growth regulators that either regulate or inhibit plant growth,
sometimes causing plant death. . . ." The admission that, the Department of
Defense is indeed engaging, through its defoliation and herhicidal operations
in Vietnam, in biological warfare, as this is defined by the Joint Chiefs and as
it has been formally renounced by the President, seems Inescapable.
Since the Dull ridge statement, allegations, apparently originating in part
with the Dow Chemical Company, have been made to the effect that the 2,4,5-T
used In the Bionetics study was unrepresentative of the 2,4,5-T generally produced in this country, in that It contained comparatively large amounts of a
certain contaminant, which, according to the Dow people, is ordinarily present
In 2,4,5-T only In trace quantities. Accordingly, It has been suggested that the
real cause of the teratogenlc effects of the 2,4,5-T used in the Hlonetics study
may not have been the 2,4,5-T Itself but, rather, the contaminant in the sample
used. The chemical name of the contaminant thus suspected by the Dow people
is 2,3,6,7-tetrachlorodibenzo-p-dloxin, often referred to simply as dioxin. The
2.4.JI-T used by Bionetics was obtained In 19C5 from the Diamond Alkali Company, now known as the Diamond-Shamrock Company and no longer In the

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husiness of manufacturing 2,4,5-T. It appears tlmt the presence of a dioxin contaminant in the process of manufacturing 2,4,5-T is a constant problem among
nil manufacturers. Three years ago, Dow was obliged to close down its 2,4,5-T
plant in Midland, Michigan, for several months and partly rebuild it because
of what Dow people variously described as "a problem" and "an accident."
The problem—or accident—wits that workers exposed to the dloxin contaminant during the process of manufacture came down with an acute skin irritation known as chlor-acne. The Dow people, who speak with considerable pride
of their toxlcologlcal work ("We established our toxicology lab the year Ralph
Nader was born," a Dow public-relations man said recently, showing, at any
rate, that Dow Is keenly aware of Nader and bis career), say that the chloracne problem has long since been cleared up, and that the current level of the
(lioxtn contaminant in Dow's 2,4,5-T is less than one part IK.T million, as
opposed to the dloxin level in the 2,4,5-T used in the Bionetics study, which is
alleged to have been between fifteen and thirty parts per million. A scientist
at the DuBridge office, which has become a coordinating agency for information having to do with the 2,4,5-T question, says that the 2,4,5-T used by Bioni'tics was "probably representative" of 2,4,5-T being used in this country—and
invsuiuiihly in Vietnam—at the time tt was obtained but that considerably less
of the contaminant is present in the 2,4,5-T now being produced. Evidently, the
degree of dloxin contamination present in 2,4,5-T varies from manufacturer to
manufacturer. What degree of contamination high or low, was present In the
quantities of 2,4.5-T shipped to .South Vietnam at various times this spokesman
didn't seem to know.
The point about the dioxin contamination of 2,4,5-T is an extremely important one, because if the suspicions of the Dow people are correct and the cause
of the fetus deformities cited in the Bionetics study is not the 2,4,5-T but the
dloxin contaminant, then this contaminant may be among the most teratogenlnill.v powerful agents ever known. Dr. McLaughlln has calculated that if the
dioxin present in the Bionetics 2,4,5-T was indeed responsible for the teratosreiilc effects on the experimental animals, It looks as though the contaminant
would have to be at least ten thousand times more teratogenically active in
rats than thalidomide was found to be in rabbits. Furthermore, it raises
alarming questions about the prevalence of the dioxin material In our environment It appears that under high heat the dloxin material can-.be produced in
•i whole class of chemical .substances known as triohlorophcnols and pcntafhlorophenols. These substances include components of certain fatty acids used in
detergents and in animal feed.
As a consequence of studies that have been made of the deaths of millions
nf young chicks in this country after the chicks had eaten certain kinds of
chicken feed, government scientists are now seriously speculating on the possibility that the deaths were at the end of a chain tlmt began with the spraying
of corn crops with 2,4,5-T. The hypothesis is that residues of dioxin present in
the 2,4,5-T remained in the harvested corn and were concentrated Into certain
byproducts that were then sold to manufacturers of chicken feed, and tlmt the
dioxin became absorbed Into the system of the young chicks. One particularly
disijuieting sign of the potential of the dioxin material Is the fact that bioassays made on chick embryos in another study revealed that all the embryos
nvrc killed by one twenty-millionth of a gram of dioxin per egg.
Perhaps an even more disquieting speculation about the dloxin Is that 2.4.5-T
may not. be the only material in which it appears. Anmiik' the compounds
that several experienced biologists and toxicologists suspect might contain or
produce dioxin are the triehlorophcnols and in-ntachlorophcnols, which are
rather widely present in the environment in various forms. For example, a
number of the trichlorophenols and pentachlorophenols are used as slime-killing agents in paper-pulp manufacture, and are present in a wide range of consumer products, including adhesives, water-based and oil-based paints, varnishes and lacquers, and paper and paper coatings. They are used to prevent
vliine in pasteurizers and fungus on vats in breweries and are also used in
hair shampoo. Along with the 2,4,5-T used In the Bionetics study, one trichlor.iphciiol and one pentachlorophenol were tested without teratojfenic results,
lint. Dr. McLaughlin points out that since there are many such compounds put
,.iit by various companies, these particular samples might turn out to be —by
the reasoning of the allegation that the 2,4,5-T used by Bionetics was unu.ually dirty—unusually clean.

�JF.

122
Dr. McLaughlln tends to consider significant, in view of the now known
extreme toxicity and possible extreme teratogeniclty of dioxin, the existence of
even very small amounts of the trichlorophenols and pentachlorophenols in
food wrappings and other consumers products. Since the production of dloxin
appears to be associated with high-temperature conditions, a question arises
whether these thermal conditions are met at any stage of production or subsequent use or disposal of such materials, even in minute amounts. One of the
problems here seems to be, as Dr. Epstein has put it, "The moment you introduce something into the environment it's likely to be burned sooner or later—
that's the way we get rid of nearly everything." And most of these consumer
products may wind up in municipal incinerators, and when they are burned,
the thermal and other conditions for creating dioxin materials may quite possibly be met. If so, this could mean a release of dioxin material into the entire
environment through the atmosphere.
Yet so far the dioxin material now suspected of causing the fetus-deform ins
effects in experimental animals has never been put through any formal teratologicul tests by any company or any government agency. If the speculation
over the connection between diosin in 2,4,5-T and the deaths of millions of
baby (.-hicks is borne out, it might mean that, quite contrary to the assumptions mude up to now that 2,4,5-T is rapidly decomposable in soil, the dioxin
material may be extremely persistent as well as extremely deadly.
So far, nobody knows—and it is probable that nobody will know for some
time—whether the fetus deformities in the Bionetics study were caused by the
2,4,5-T itself, by the dioxin contaminant, or by some other substance or substance* present in the 2.4,3-T, or whether human fetuses react to 3,4,5-T in the
same way as the fetuses of the experimental animals in the Bionetics study.
However, the experience so far with the employment of 2,4,5-T and substances
chemically allied to it ought to be instructive. The history of 2,4,5-T is related
to preparations for biological warfare, although nobody in the United States
government seems to want to admit this, and it has wound up being used for
purposes of biological warfare, although nobody In the United States government seems to want to admit this, either. Since 2,4,5-T was developed, the
United States government has allowed it to be used on a very large scale on
our own fields and countryside without adequate tests of its effects. In South
Vietnam—a nation we are attempting to save—for seven full years the American military has sprayed or dumped this biological-warfare material on the
countryside, on villages, and on South Vietnamese meua and women in staggering amounts. In that time, the military has sprayed or dumped on Vietnam
fifty thousand tons of heriblcidc, of which twenty thousand tons have apparently been straight 2,4,5-T. In addition, the American military has apparently
made incursions into a neutral country, Cambodia, and rained down on an
area inlmbired by thirty thousand civilians a vast quantity of 2,4,5-T. Yet in
the quarter of a century since the Department of Defense first developed the
biological-warfare uses of this material it has not completed a single series
of formal teratological tests on pregnant animals to determine whether it has
an effect on their unborn offspring.
Similarly, officials of the Dow Chemical Company, one of the largest producers of 2,4,5-T, although they refuse to divulge how much 2,4,5-T they are and
have been producing, admit that in all the years that they had produced the
chemical before the DuBrldge statement they had never made formal teratological tests on their 2,4,5-T, which they are now doing. The Monsanto Chemical
Company, another big producer, had, as far as is known, never made such
tests, either, nor, according to an official in the White House, had any other
manufacturer. The Department of Agriculture has never required any such
tests from manufacturers. The Food and Drug Administration has never
required any such tests from manufacturers. The first tests to determine the
teratogenic efforts of 2,4.5-T were not made until the National Institutes of
Health contracted for them with Bionetics Laboratories. And even then, when
the adverse results of the tests became apparent, it was, as Dr. Epstein said,
like "pulling teeth" to get the data out of the institutions involved. And when
the data were obtained and the White House was obliged, partly by outside
pressure and publicity, to act, the President's science adviser publicly presented the facts in a less thnn candid manner, while the Department of
Defense, for till prnetieal pur|H)NCH, Ignored the whole business and announced
UN liileiillmi (if Knlng &lt;&gt;» doing wlnit. It. hud been doing all along.

�123
Tliorc have been a number of reports from Vietnam both of auiuial abortions
and of malformed huiuuu babies that are thought to have resulted from spraying operations in which 2,4,5-T was used. But such scattered reports, however
well founded, cannot really shed much more light on the situation. The fact is
that even in this country, the best-fed, richest, and certainly most statisticsminded of all countries on earth, the standards for testing materials that are
put into the environment, into drugs, and into the human diet are grossly
inadequate. The screening system is so coarse that, as a teratology panel of
the ilrak Commission warned recently, in connection with thalidomide, "the
teratogenlcity of thalidomide might have been missed had it not produced malformations rarely encountered." in other words, had it not been for the fact
tliat very unusual and particularly terrible malformations appeared iu an
nlivious pattern—for example, similarly malformed babies in the same hospital
at about the same time—pregnant women might still be using thalidomide, and
lesser deformations would, so to speak, disappear into the general statistical
background. As for more subtle effects, such as brain damage and damage to
the central-nervous system, they would probably never show up as .such at all.
If such risks existed under orderly, normal medical conditions in a highly
developed country, how is one ever to measure the harm that might be done to
iiuhorn children in rural Vietnam, in the midst of the malnutrition, the disease, the trauma, the poverty, and the general shambles of war?
DEPARTMENT OF AMPLIFICATION,

A'cto York, March 5, 1910.

The EDITORS,
The .Veto Yorker

DEAR Sms: In an article that appeared in The New Yorker on February 7th, I
wrote that Dr. Lee DuBridge, the President's science adviser, issued a statement last October at the White House saying that because a laboratory study
had shown a ''higher than expected number of deformities" in the fetuses of
mice and rats exposed to the herbicide 2,4,5-T, agencies of the United States
government would take action to restrict the use of that substance in this
country and in Vietnam, where it was being used in extensive military defoliation operations. This action, Dr. DuBridge announced, would include the canirllatlon, by January 1st of this year, of Department of Agriculture permits
for the use of 2,4,5-T on some American food crops unless the Food and Drug
Administration had by then been able to determine a safe concentration of the
herbicide in foods. Dr. DuBridge further announced that the Department of
Defense would thenceforth "restrict the use of 2,4,5-T to areas remote from
the population" in Vietnam. His statement added that these actions and others
••will assure the safety of the public while further evidence [of the alleged
harmful effects of 2,4,5-T] is being sought"
Four months have passed, and 2,4,5-T is still being used as widely as ever.
The Department of Agriculture has yet to cancel its permits for the use of the
herbicide on food crops in this country, and the Department of Defense is continuing to use it in populated areas of Vietnam. In the meantime, officials of
the Dow Chemical Company, which is one of the largest producers of 2,4,5-T,
have been maintaining that the samples of 2,4,5-T used in the study cited by
Dr. DuBridge, which was done by the Bionetics Research Laboratories, of
liothesda, Maryland, were uncharacteristic of the 2,4,5-T currently being proiliiced, because the material tested by Bionetics—which did not come from
I low—was contaminated to an unusual extent by a toxic substance identified
:is symmetrical 2,3,6,7-tetrachlorodibenzo-p-dloxin. This contaminant, usually
i-alled clioxin, was alleged by the Dow people to be present in the Bionetics
samples at a concentration of approximately twenty-seven parts per million,.
•i ml they claim that the 2,4,5-T that Dow is currently producing contains the
liiuxiu contaminant in concentrations of less than one part per million. The
IMV people maintain that their currently produced 2,4,5-T does not appear to
have the effect of deforming rat fetuses. In January, a Dow official told the
lH&gt;|i:irtment of Health, Education, and Welfare, ''We strongly urge that action
.•.HiccrnliiK the status of 2,4,o-T be held in abeyance until [Dow's] testing program Is completed [in] April." The United States government's failure so far
(„ [ilncc (he promised restrictions on the use of 2,4,5-T in this country may in
t .art lie attributed to this plea,
•in :io2—70
»

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Because of the seriousness of the Issues involved, it seems to me that the
government's failure to act on the use of 2,4,5-T here and in Vietnam calls for
much fuller public discussion. Even though the dloxin contaminant may now
be present in 2,4,5-T in what the Dow Chemical Company apparently considers
to t»e no more than tolerable amounts, the substance is of such potency that its
release even in small concentrations must prompt deep concern. In the presumably more heavily dioxin-contaminated samples o£ 2,4,5-T that were used in
the Bionetics work, the smallest dosages of 2,4,5-T that the test animals were
given caused extensive deformities in fetuses. In more recent studies of the
dioxin contaminant, conducted by Dr. Jacqueline Verrett, of the Food and
Dm? Administration (who earlier was responsible for revealing the carcinogenicity of cyclamates), extensive teratogenic, or fetus-deforming, effects were
discovered in chick embryos when the dioxin, or a distillate predominantly
consisting of it, was present at concentrations of little more than a trlllionth
of i\ grain per gram of the egg. The magnitude of this effect on chick embryos
may be gathered from the fact that, according to Dr. Verrett's studies, the
dioxin appears to be a million times as potent a fetus-deforming agent as the
notorious terutogen tlmlidomide was found to be in tests on chicks. Of course,
diick embryos are far down the biological ladder from human fetuses, and
they arc also extremely sensitive to many substances. But even if, for theoretical pin-noses, we n•• 1 uced the teratogenic power of the dioxin, as shown in Dr.
Vern'tt's chick-embryo studies, approximately a million times, we would still
luive to consider that we were dealing with a .substance as teratosrenieally
potent as tlmlidomide. That the United States government permits the presence, even in minute amounts, of such a substance in herbicidal mixtures to be
sold for til-raying on food crops and on suburban lawns—where some of the
chi-niicaI may enter shallow wells and other drinking-water supplies—is hardly
reassuring. And it is particularly disturbing when one reflects that in the
quarter of a century in which 2.4."&gt;-T was used prior to Dr. DuBridge's
announcement not a single regulatory agency of the United States government,
not the Department of Defense—which has been spreading huge quantities of
2.4.-"-T on vast areas of Vietnam—and not. as far os is known, the researchers
for any one of the half-dozen large American chemical companies producing
the material had ever so much as opened up a pregnant mouse to determine
whether 2,4,5-T or the dioxin contaminant in it did any systemic or pathogenic
harm to the fetus. Several studies of the sort are now under way, but the
United States government still seems to take the position that the 2,4,5-T produced !&gt;y Dow and other large chemical companies should be considered innocent until it is proved to be otherwise. Meanwhile, 2,4,5-T is being sprayed on
certain crops and on areas where it may come into contact with human beings,
rattle, and wildlife. In Vietnam, it is still being sprayed by the military in
concentrations that average thirteen times as great as those that the manufacturers themselves recommend ns safe and effective for use in Oils country.
It is true that the teratogenicity of dioxin—as distinct from dioxin-contaminured 2.4.5-T—has not yet been established in tests conducted on experimental
animals of mammalian species. However, the direct toxic, or bndy-poisoning,
effei-ts—;:s distinct from fetus-deforming effects—of dioxin are known to lie
very high both in animals and in human beings. In past studies on rats, dosages of forty-five milMonths of a gram per kilo of the mother's body weight
h:ive been found to kill fifty per cent of the offspring. When dioxin was given
orally to. pregnant rats in recent tests, it was found, on preliminary investigation, to kill all fetuses with dosages of eight millionth* of a gram per kilo of
the mother's body weight, and to damage fetuses with dosages of a half-mil.
Month of a grum per kilo.
, Further, the effects of dioxin on human beings, even in small dosages, are
known to be serious. In the past, in plants manufacturing 2,4.5-T an Illness
called chloracne seems to have been widespread among the workers. In the
mid-sixties. Dow was obliged to close down part of a 2,4,5-T plant in Midland.
Michigan, for some time because about sixty workers contracted chloracne as a
result of contact with dioxin, which seems to be always present in varylnc
decrees during the process of manufacturing 2,4,5-T and in the finished 2,4,S-T
itself. The symptoms of this disease include extensive skin eruptions, disorder?
of the central nervous system, chronic fatigue, lassitude, and depression. Workers at n 2.4.5-T plant, in New Jersey run by another company suffered similar
symptom* in the mid-sixties, and nix years Inter some of them were reported
to ii&lt;- .-til! -iifTcring from tlm &lt;:ffWts of tlj&lt;.- disease. In Oc-ruiany. since tht

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mid-fifties, workers in factory after factory producing 2,4.3-T and polychlorophenolie compounds have been afflicted with clilorucne 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'soffice 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 hididn'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 i
and commonly used pills is worth pursuing. Suppose that such a dangerous
substance as dioxin were found to be contained in a pill ottered for human
consumption in this country, and suppose that the contaminant were present in
such minute amounts that an adult following the prescribed dosages miirhi
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 Admin-1
istration standards, the F.D.A. would immediately ban production and sale or
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 lie 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 it
one-inch rainfall—such as is common there—after a spraying, a forty-kiln
(about eighty-eight-pound) Vietnamese woman drinking two litres (about tw&lt;&gt;
quarts) of 2,4.5-T-contamlnated water per day could be investing about i:
hundred and twenty milligrams (about a two-hundred-and-flftleth of an ounce i
of 2,4,5-T a day. If the 2,4,5-T contained the dioxin contaminant at a level &lt;&gt;r'
one part per million—which is what the Dow people say is the maximum
n mount 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 Mirne ra!i-;:!atlons 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) wouid be more than the weight of the
just-fertilized ovum. Considering tho existing evidence of tin- frlghtPiiinv
degree of teratogenlcity of the dioxin in chick embryos and Its highly toxic
effects on mammalian fetuses, the presence of this much dioxin in n mother's
body at the very beginning of a human life surely has ominous implication?.
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 he 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 t«
he viewed with suspicion, for the breakdown products of 2.4,5-T. when suljoeted to heat and other conditions, are themselves c-apable. amirdlnsr to ;i
munlier of responsible biologists, of producing dioxin. Given this potential, the
ultimate folly In our defoliation operations In Vietnam was possibly achieved
•luring 1965 and 19GC, when the military made large-scalp efforts in two defolinted areas to create fire storms—that Is. fires so huge that all (be oxygen in
those areas would be exhausted. The apparent Intention wjs to render flii- soil
barren. (A fire storm would also, of course, have the result of burning or suf-

'•

'

L

!
|
i
;

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126
focatiug any living beings remaining in the area.) Operation Sherwood Forest,
conducted in 1965, was an attempt to burn a defoliated section of the Boi Lot
Woods. In October, 1966, the military began Operation Pink Rose, a simitar
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 dioxlu produced by the
breakdown products of the 2,4,5-T will probably never be known.
There art- also leas 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 lu 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 thun they are in Vietnam. Jn 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 grout deal, if not most, of the 2,4,fi-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 us 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 Dowlclde 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-dioxiu 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 snll,
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,
THOMAS WHITESIDE.
Appendix 4
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE.
PUBLIC HEALTH SERVICE,
FOOD AXD DRUG ADMINISTRATION.
Rockville, Md., March IS. 1970.
Hon. RICHARD D. MCCARTHY,
House of Representatives,
Washington, D.C.
DEAR MB. MCCAHTHT: The Secretary has asked us to reply to your letter of
February 3, 1970, requesting whether the Food and Drug Administration has
- "•-» "» * I.T &lt;&lt;! now safe to use.

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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 ns 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,
"IVtuhington, B.C.
* 2,4,5-T *
2,4,5-T (2,4,"&gt;-trichloropheiioxyacctlc acid) tins had extensive registered use
as u defoliant nnd 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 tind 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 culled dioxins produced during the manufacture of 2,4,.r&gt;-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 USI1A announced on February 6, 1070, 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 IX THE UNITED STATES

The Food and Drug Administration is continually engaged in examining
wimples 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 Ift-year-old male, and
determines the amounts of the several pesticides that might be actually inposted in the typical diet of n heavy eater. 1
Of fiJttiO food sam!il&lt;-s tesn-d fur 2)4..^-'l' residue* ''tiring the Inst four-year
period, y&gt; sample* indicate!! trace amounts (less than the 0.1 p.p.m. limit of
accuracy of present analytical procedures) and 2 samples showed higher residues. 0.10 p.p.m. 2.4,5-T was detected in one sample of milk taken in 1065 in
New England, and one sample of sugarbeet.s from Ohio In 190C showed 0.20

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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 TUB FEDERAL FOOD, DRUG, AND pOSMETIC ACT

No finite tolerances have been established for residues of 2,4,5-T or the dioxIns iti 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, 1907 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, ami wheat. Neither the petition as originally submitted or as later supplemented provided data to support nlHrmntlve action and
the petitioner withdrew his petition on December 29, 1!W&gt;9, as provided for
under the pesticide regulations.
Petitions to establish a safe tolerance level for residues of 2,4.5-T in food
may atrr.ln !&gt;o «nhmitto:| to the FDA in the future. However, nny 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.
COJfLt'SIOS

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 RICIIAI:I&gt; M. MCCARTHY.
D-N.Y.
Globe, Ariz., February 13, 1070
Ladies and gentiemen. 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 IOCS.
I've long been concerned with the widespread use of these herbicides in Vietnam. Each day some 100 tons nre dropped on South Vietnam, and scientists
for many months have been concerned about the adverse ecological effects of
this herhiddal 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 Blonetics 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,
1!)70, 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 2,4.3-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.

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129
We know from the thalldomlde experience that if we are going to err, we
should err on the .side of caution, and not on the side of danger. It IK 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 23 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,
;iml your background, and particular expertise In the matters under inquiry.
})r. GALSTOX. 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 i&gt;r&lt;&gt;fossor of plant physiology for about 27 years. I was trained at the New York
State College of Agriculture at Cornell University.
f did my graduate work at the University of Illinois, where I earned a I'h.D.
degree In llit.'J. I then went to work for the emergency rubber project for
the U.S. Government, located at Cal-Tech. During World War 1 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.
DK. GAI.STON-. Congressmen, what I'd like to do Is to give you nnd 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, 1900, and
was prepared by the distinguished panel shared by Doctor Emll 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 fill Lilly, both of whom manufacture herbicides and other |&gt;estlcldes 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 techniealisied 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
tli.ia a boom. It has become global. Kven a penguin picked up on ,-in ice flow in
Ant.irctlca Is full of DDT, and that was -100 miles from the application of

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DDT. and wo know that DDT causes oversized livers, and alteration of the
steroid metabolism lu everyone's genes.
This Commission agrees unanimously that DDT must be phased out as
quickly us possible as a pesticide.
With that as a background, I think it's perfectly clear that as scientific
information develops, we are going to want to examine every pesticide for its
possible harmful effects on man and his domestic animals, and his environment.
Here I must digress to tell you about the changes that have occurred In our
concept of what constitutes adequate testing for a compound of this kind.
It used to be that simple toxicology tests were conducted. A laboratory
animal, such as a mouse or a rat was fed a certain amount of chemical. If
that animal showed serious symptoms, the teratogenleity was calculated on the
base of how many milligrams per kilogram of body weight of this material
produced the toxic effects.
We now have tables which tell us roughly how toxic given materials are.
Now. based on that kind of test. 2.4.5-T, for example, is not terribly toxic,
it's only a mildly toxic compound in the order of 2 to 700 kilograms milligram
of body weight cause toxiclty.
If. however, you use more subtle tests, you find out that 2.4,5-T may be more
dangerous.
Among these tests are: Does the compound cause cancer? That takes a much
more serious look than simply feeding and watching the dying of animals.
Secondly, do the compounds cause genetic effects, that is, does it break chromosomes, or cause mutations.
Thirdly, does the compound cause birth abnormalities. The word to describe
that is teratogenics: that is the formation of monsters.
Now, this report which I have alluded to has as Its last chapter, a chapter
on teratology, and I'd like to read you just a little bit out of this chapter, and
out of the summary which is written here, which gives you my concern.
"All currently used pesticides should be tested for teratogeniclty In the near
future in two or more mammalian species chosen on the basis of the closest
metabolic and pharniacologic similarity to human beings possible. Pesticides
should be tested at various concentrations Including levels substantially higher
than those to which the human population are likely to be exposed. Test procedures should also reflect routes related to human exposures. Apart from the
obvious route of ingestion. attention should be directed to other routes of exposure, including inhalation exposures from pesticide aerosols and vaporizing
pesticide strips used domestically, and exposures from skin absorption. Parenteral administration is an appropriate test route for pesticides to which
humans are exposed by inhalation, or for pesticides, which are systemically
absorped following ingestion.
"The use of currently registered pesticides to which humans are exposed and
which are found to be teratogenic by suitable test procedures In one or more
mammalian species should be immediately restricted to prevent risk of human
exposures."
I'd like to repeat that: "Currently registered pesticides to which humans are
exposed and which are found to be teratogenic by suitable test procedures in
one or more mammalian species should be Immediately restricted to prevent
risk of human exposure. Such pesticides, In current use. Include—" I'll skip a
lot of names, 2.4-D and 2.4.5-T are listed.
Here's the Government's most distinguished panel saying that there is evidence that 2.4,5-T'has-produced teratogenic effects in one or more mammalian
species, its use should be restricted immediately. They also said no new pesticide found to be teratogenic. should be used only In circumstances where risk
of human exposure is minimal.
Congressman MCCARTHY. What's the date of that report, Professor?
Dr. GALSTOX. December 5, 19C9, it's now only 2 months old, Congressman,
and It says a scientific group, or commission should be charged with the
responsibility for continued surveillance of the whole problem of pesticide teratosonosls.
Now. the problem of determining whether a problem is teratogenic, whether
it's given rise to birth defects is terribly complicated. If you do a laboratory
test where yon have one group of mice getting the chemical, and one group
not. there's no problem to determine teratogenicity. By this kind of test it has
been determined that 2,4.5-T as tested is one of the most teratogenic chemicals

�131
known. Even as little as 4*6 milligrams per kilo of body weight have trebled
the rate of abnormal production in mice and in rats a 113 milligrams per kilo
of body weight lias produced 100 percent abnormal litters, and 70 percent
abnormal individuals in those litters.
Congressman MCCARTHY. I wonder if you could translate those figures into
what a human being would lie likely to receive In the United States, or in
Vietnam.
•Dr. GALSTO.V. Well, if you take the lowest of those figures, 4',i milligrams
per kilogram of body weight, and you say you have a GO-kilogram woman,
that's 110 pounds which is about the average weight of a Vietnamese woman,
rlien she needs to digest only about 200 milligrams total to have a teratogenic
dose, 100 milligrams [&gt;er day. Now, we are spraying agent orange, which is a 1
ro 1 mixture of 2,4-D, and 2,4,0-T, in Vietnam at the rate of 2TO pounds per
:icre. I should note that is 10 times what we used locally.
Congressman McCAimir. What would it be in Arizona?
Dr. GALSTON. I think our Forestry friends could tell us, it is in the order of
two pounds per acre.
Congressman MCCARTHY. Wo will get to that with them today or tomorrow,
hut that's about the range 1
Dr. GAI.STO.N. At the Vietnam dose rate, if you assume a 27-pound per acre
sprayed, followed by a 1-inch rainfall, which is normal for that region
and you know that the rainwater is collected oft the roof, or stored in cistern.*.
dt gotten from very shallow wells, then a woman need only consume less than
3 quarts of water per day in combined drinking and cooking operations to
receive that teratogenic dose.
I have calculated on this basis that it's possible that in Vietnam people have
ln«en given this kind of teratogenic dose.
Congressman MCCARTHY. Doctor, let me ask you this. Here we have the Bioni'tics Research Laboratory test which showed that 2,4,5-T is teratogenlc in
n-st animals, mice and rats. Is it teratogenic in human beings—do we know?
Dr. GALSTON. One doesn't know for sure whether it's teratogenic in human
beings, one doesn't experiment with pregnant women, feeding some of them
1',4,5-T, and not feeding others. That would be inhuman, we do not tolerate
that kind of experimentation, but the paragraph I was about to read here in
fact deals with this.
It snys there are two ways that you can determine whether a chemical is
teratogenic. "First, chemicals or other agents may be administered to experimental animals to determine whether they induce prenatal damage. Secondly,
iitul on a post hoc basis, human populations may be epidemlologicully surveyed
to detect geographical, or temporal clusters of unusual types of frequencies of
congenital malformaties. Combinations of these approaches are likely to insure
c.-iiiy detection and identification of teratogenic hazards."
Congressman MCCARTHY. Now, to your knowledge, has that been done in
Vietnam, or is it contemplated, is the American Association for the Advancement of Science going to do what you just read?
Dr. GALSTON. I think it's shocking that there are absolutely no studies on
the possible terntogenlcity of these chemicals either in Vietnam or in this
country. That is why it's so important to gather data from places like globe,
iiml from places like the Saigon area to attempt to correlate, if it's possible to
do so, the use of any particular pesticide with the appearance of any birth
;iiniormalitics, or any physiological malfunctions.
Congressman MCCARTHY : Doesn't the commission's study recommend that no
herbicides like this be used until we are sure that it doesn't produce effects in
human beings?
Dr. GALSTON. That's correct, the Commission recommends that given the suspicion that these materials are teratogenic, given their widespread use, but
•.•iven also our wide dependency on these things in agriculture, we should
immediately restrict the use so that we only use these herbicides where it is
absolutely necessary to do so, and where there is no possibility of contact with
human organisms. I believe that is the safe policy when you think you may be
doing harm. You stop until you find out whether you are in fact doing harm.
Congressman MCCARTHY. Do you have any Information that you could give
for the record here, which would suggest why The White House ban never
went into effect? I have a letter here which I received Just prior to leaving
Washington, which needs further clarification. It is from Mr. Ned D. Bnyley,
director of science and education for the Deportment of Agriculture in

�132
response to a letter I'd addressed to Secretary Hardin, asking why The White
House ban didn't go into effect. Among other things, here's what he said.
"Now, data submitted to D.H.E.W., Department of Health, Education, and
Welfare, relevant to this position is that the 2,4,5-T, used in the bionetics study
contained about 27ptm of
Dr. GAI.STOX. Dioxln Is the way it's usually referred to.
. Congressman MCCARTHY. It's t-e-t-r-a-e-h-1-o-r-o-d-l-b-e-n-z-o p-a-r-a diosin
Dr. GAI.STOX. Tetrachlorodlbenzo para dioxiu.
Congressman MCCARTHY. A highly toxic contaminant.
Dr. GAI.STOX. Yes.
Congressman MCCARTHY. I'm going to seek further clarification that one of
the reasons the ban was lifted was this discovery. Now, do you know anything
about this in the course of your inquiry?
Dr. OALSTOX. Yes, Congressman, I became aware of this new development—
2,4,5-1' is a chemical synthesized from the renctnnte that are put together in a
vehicle. Depending on the method of synthesis, and the temperature of synthesis, you may or may not get certain impurities formed in that reaction that
accompany the 2,4.5-T which is realized out of the reaction fixture. One of the
impurities i.s tctrachlorodibenzo-p-dioxin.
X'i\v, there's previous Information that this compound is a highly no\!&lt;ins
material. There have been several factory and laboratory accidents in which
peo;&gt;le exposed to this compound have developed very severe blistering, loss of
sensation, and respiratory troubles. The Germans have had a similar expi-rlen'-e.
SD !fs natural when you have a report of this kind about the toxii-lty of
•_'.4..~-T. to i!ii|ii!re whether the effect is due to the chemical itself, or tn the
im;.urif.v;
Congressman MCCARTHY. Does it matterV
Dr. f!ALSTON. I'll piake this statement.
1 t h i n k !t &lt;io&gt;&gt;s matter in the long run. Congressman, because if it's the
impurity, then in the future we can learn possibly how to make the chemical
witlioi!' the impurity, arid continue Its use.
C.-in?rrc.--''i::;.:i MCCARTHY. I've read in the long article by Mr. WhltcMde in
the liiti'-r issue of New Yorker Magazine, at least he made the point that you
can't make 2,4,5-T without getting some dioxin.
Now. is that right?
Dr. UALSTON. That's correct, I don't know if any sample that has less than a
part per million of dioxin, so all of the 2,4,5-T that has been sprayed both at
home and abroad has some dioxin.
The question is: Can you lessen the dioxin level down to the point where it
is no lonwr so dangerous?
Congressman MCCARTHY. Is there any other way that dioxin can lie produced after it's sprayed?
Dr. OAI.STOX. Oh, yes. even if you sprayed 2.4.5-T without any dioxin it
might form chemicals in this Arizona sunshine. Putting nil that light energy in
1 could easily imagine compounds like the dioxin being formed.
If there were a little fire somewhere, that's just the condition which would
form the dioxin from 2,4,5-T. The only hard data on the teratogenicity of
2.4.5-T are right in this book that I have. There are no date which tell me. or
anybody else, that it's the dioxin and not the 2,4.5-T that's respo:isii&gt;!e for
there teratogenic effects.
I've hrd telephone conversations with people who have nlleml this,
Congressman MCCARTHY. Who are they?
Dr. GAT.STOX. Well, one of them i« a member of this Commission. Doctor
Julius Johnson of Dow who is an old friend of mine, and 1 think lie is very
terribly concerned about tills development. Naturally, he would be since Dow
is the manufacturer of some of this, and he told me that there are tests going
on now which are not finished. He said he would not care to quote the data as
of the present moment.
Congressman MCCARTHY. Mr. James Hansen of the Dow Chemical Co. visited
my office last week and alluded to, I assume, the same tests.
Dr. GAT.STO.V. Yes.

Congressman MCCARTHY. That the Dow Co. itself was carrying out the following-up on this possibility that it is the dioxin.
Now, in this lotter from Mr. Bayley he said new data submitted to D.H.E.W.
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Well, it sounds as If It's the snine thing. What I don't understand is lio\v
Hie Dow Chemical Co. could, in effect, by intervening, countermand, or negate
White House orders.
Now, have you discussed this with any other people in the Government, or
outside the Government?
Dr. GALSTON. I have not, Congressman. I don't have any information on how
this operation came about. I would only say that to me it's unthinkable that,
in absence nf hard dnta, and to protect the lives and welfare of people in the
country, I don't see how this order could fail to be enforced.
We must be safe before we are sorry. I would say let's get the facts before
we resume spraying with this 2,4,5-T and at the present time there are no published data that I, or any other scientists have seen, that would say that
2,4,5-T Is not the culpable agent I think it's very peculiar that the orders of
Doctor DuRrldge are not being followed by the Department of Agriculture and
the Department of Interior. The Department of Defense, said it announced
Immediately it would not follow this directive.
Congressman MC-CAUTHY. That's right. The next day on October 30th. the
spokesman for the Department of Defense contradicted the DuBrldge order in
a verbal briefing to newsmen. He said that the 2,4,5-T would continue to be
sprayed in training and regroupment areas where obviously populated areas,
nnd'of course as you know it has been sprayed in rubber plantations in Cambodia, which are also populated.
Well, Professor Galston, I appreciate very much your testimony here.
Dr. GAI.STOX. Do you mind if I make one more brief statements
Congressman MCCARTHY. No, please do.
Dr. G ALSTON'. As a biologist, I'm terribly concerned about this because I
believe in herbicides, I want to see that they continue to be iwcd. I'm afraid
there may be overreaction on the part of the public. I would like to say that
there are probably ways that we can safely use these compounds, mid the first
recommendation of this Commission— I would like to read you just two paragraphs. short ones, because they outline to me what would be a .safe procot'.ure.
It says: "A new Interagency agreement is needed to strengthen cooperative
action among the Department of Health, Education and Welfare, U.S. Department of Agriculture, and the T'.S. Department of Interior, to protect public
health, and the quality of environment from pesticides danger provided by the
Secretaries of H.K.W. and Interior, as well as Agriculture, should be required
for all pesticides registration, pesticide use determined by any. of tbe three
Secretaries to be hazardous should be restricted, or eliminated.
"The agreement should further require the continuous review of new scientific Information on pesticides now In use with the formal reviews made years after initial registration, and subsequent formal reviews by the tiiree
agencies at 5-year intervals."
That seems to be loudly, essential for the continued safe use of pesticide*
and It's coupled with the establishment of a national testing center for pestii-idoH. which Is also recommended, I would say that we would be well on our
way for the safe use of pesticides.
Congressman MCCARTHY. Do yon think it's proper to delegate to the .".liinufnctiirer of such a chemical the responsibility for testing its teratogenk-lty and
oardnogenicity?
Dr. GALSTON. Well, you can certainly accept the data that are contributed l.y
the manufacturer as relevant to the solution of the problem. I think these
people have shown necessary testing laboratories which give honest data, but I
would not depend on those alone. I would want to see the FDA or some other
aspiiey Independently test these same compounds also, under completely different conditions. That's only a scientific rule, you don't believe anything anybody
tells you, it has to be confirmed once or twice before you can believe it.
I would certainly hope the FDA, or some other agency, HEAV would continue conducting further tests on these toxic chemicals.
Congressman MCCARTHY. And not really solely on the research of Dow. or
i ,i her ma nnfootiirers ?
Or. GALSTON. That's correct.
Congressman MCCARTHY. I'rofessor. I wonder If you would be kind enough
to sit with us here, I'd like to use you as a resource person when we have the
ntlior witnesses.
Our next. witness Is Mr. John PlMwWi, Assistant Regional Forester, from
All&gt;u&lt;iuernue.

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Is lie in the room?
If you would IK- seated and identify yourself for the record, and your
responsibilities in areas under scrutiny here.
Mr. PIU.OVICH. Yes, sir, I'm John Plerovich, Assistant Regional Forester in
Albuquerque, X. Mex. My resiionsihilities related to this matter arc in connection with (lie complaints we've received here at Globe, and the. overall evaluation of our Chaiuirral program, and our Chaparral program guidelines.
The jirimary reasons tiie Forest Service is here today is because this is a
Forest Service project. I think that we need to he cognizant of such hearings
us this, and \ve do try to keep informed through the literature of regulatory
rules and concerns*.
In fact, we share quite deeply the concern of the people in this community
with their environment, \ve wouldn't want to do anything that would jeopardize their safety.
They're our neighbors, we also live here.
At the same time, we've been asked repeatedly to announce that we would
not spray a sain in the Globe area, and like Doctor Galston. I think that we
wouldn't want ro overreact at this time. So we've said that such an announcement would be premature, we have our own studies going forward, and that
these studies must be resolved before we can reach decisions oil herbicide's
use. or on the Chaparral program.
In addition ti&gt; that, we believe that it would be also unwise to base decisions
on herbicides used particularly from the current allegations, or suspicions here
in tliis area.
These matters need to be studied deeply, and we hope to have them studied
deeply, and frankly welcome this inquiry because it will help to daylight some
of the areas of concern.
That's essentially our position. Mr. Congressman. I'd be glad to answer any
questions you might, have.
Congressman MCCARTHY, Thank you very much.
In the course of my study, I have come into possession of documents that
have been exchanged between the Department "f Agriculture and citizens in
the area. Here Is one from John A. Williams for the Task Group, U.S. Department i&gt;f Agriculture, Forest Service. Are you familiar with Mr. Williams?
Mr. PIEROVICH. Yes, I am.
Congressman MCCARTHY. Is he an associate of yours?
Mr. PIEROVICH. He works in our regional office.
Congressman MCCARTHY. Is he here today?
Mr. PIEBOVICH. No. he's not.
Congressman MCCARTHY. I'd like to read you some of the things that he
says: "Paul Hoffin (phonetic) called n Dow Chemical representative at Davis,
Calif., and requested information about Silvex. This man called Supervisor
Courtney later and indicated that a publicity release was being prepared for
submission to the news media concerning the known toxiclty of Silvex. This if
accepted and used by the news media will go a long ways towards improving
the situation, and dispelling the fear of Silvex as a highly toxic, or poisonous
agent."
He then goes on to say In his conclusions, "We are fully convinced that
many of the people in this area honestly believe they were heing subjected to
a highly toxic and extremely poisonous compound with a high degree of persistence and one which would increase In concentration in the water supplies,
and in the bodies of humans, and animals. These ideas are not in any way
supported by research findings."
Now. that is dated July 22. 1000. and if T just would ask Professor Galston
when was the Tiionetics study brought to light?
Dr. GALSTON. It was handed over to the Department of Health, Education,
and Welfare in December of IOCS, to the best of our knowledge.
Congressman MCCARTHY. So that to the best of your knowledge, the Department of Agriculture
Dr. GAT.STOX. Might have had access to that information.
Congressman MCCARTHY. Actually, the tests were run in 1007. Now. Mr. William* obviously either did not know about the Bionetlcs report, and T would—
I would ar----f&gt;pt that. I don't think he did just from the tone of the letter, but
I'll ask you to comment
NOW. which do you think it was?

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Mr. PIEROVICH, First of all, Mr. Williams was heading a group for a general
survey of the effects here in the Globe area at the request of the Forest
Supervisor, and after the initial complaints. We've had subsequent studies go
forward, one of these coming out as a second tusk force report which is somewhat more in depth. Mr. Williams' information was then of a general nature
for an initial report for the forest supervisors. Williams himself is not an herbicide man. Mr. Boffin is, and his reason for talking with the Dow was to get
more information.
The second question you've nsked regarding the Bionetics study was not
known to these people, and only known to a few people within the Forest
Service but the word of mouth communication that took place following the
review of the Bionetics study for publication.
This has precipitated a lot of discussion among the .science community, and
in the
Congressman MCCARTHY. Are you alluding to the Whlteside article in New
Yorker Magazine?
Mr. PIEROVICH. No, that's the most recent and clarifying article, at least I
found it very informative.
Congressman MCCARTHY. When did you first learn about the Bionetics findings on tcratogenlcity ?
Mr. PIEROVICH. I personally learned about it in November when I was
assigned to this problem area, and 1 learned about it through reading in the
literature, seeing the discussions among others.
Congressman MCCARTHY. Was the present science advisors ordered ban ever
transmitted to you, or here in the urea?
Mr. I'IKKOVICII. We were furnished a policy statement from the Secretary of
Agriculture in December which referred to the DuBridge statement.
Congressman MCCARTHY. Did you take that as a directive not to continue
using 2,4,5-T?
Mr. PIEROVICH. We understood it to be directed towards crops, and that it
wns not at that time being restricted In range-land use. However, we could
infer from this, and from discussions with our Washington counterparts, we
learned that there were other studies underway on this compound, and as you
perhaps have noted, we did defer our chaparral program in October. The last
spraying on this project was in June, and these events have unfolded since
that time.
It's currently our position here in this region not to use herbicides until
some of these matters are researched. The studies that are underway should
be most helpful to us in this regard.
"••
Congressman MCCARTHY. I think there's a little confusion about just what
the DuBridge announcement banned. Doctor DuBridge said—this is October 29,

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That 2,4,5-T would be prohibited for use on American agricultural products
after January 1, 1070, until the Food and Drug Administration could develop
information showing that it could be used with safety.
Dr. DuBridge also announced that the use of 2,4,5-T in Vietnam would be
restricted in areas remote from population.
'
Mr. PIEROVICH. This Is where we found our references to the crop production
area, and the Secretary has interpreted this way. As I said the ban on crops
Is in effect at this time, and as near as we can tell we are also examining the
future of the 2,4,5-T as It is compounded today.
Dr. GALSTOX. Congressman, could I make a comment here?
Congressman MCCARTHY. Yes.
Dr. GALSTOX. I was unable to understand why when Dr. DuBridge issued
this statement he did not also take care to specify prohibition of usi- in
regions where 2,4,5-T might find its way into drinking water. For example,
supposing you are using 2,4,5-T to clear shrubs from under a power line, and
thnt power line is going through a town where people have wells, and they
draw water from these wells. Don't we need to know if the 2,4,5-T is going to
seep down In the water cable and get to these people? It seems to me applying
the ban to the food crops is only a halfway measure.
Mr. PIEROVICH. I think we need to be concerned by this, and this is why we
monitor water from treatment areas. It's significant in this Globe area. Our
reference—or the Federal water quality control criterion of one-tenth part per
million, this level has never been reached in any of the water analyzed that
we've had run, or had been brought to our attention.

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Congressman MCCARTHY. You say you received the directive November
Mr. PIF.ROVICH. \Ve received the Secretary's explanatory information In
December as I recall.
Congressman MCCARTHY. Were you ever advised that the ban had been suspended?
Mr. I'IEROVICH. No, sir.
Congressman MCCARTHY. So the last you had was the DuBridge directive?
Mr. I'IEROVICH. Yes, and a statement from our Secretary to agriculture agencies of which we are, telling us that 2,4,5-T was not to be used in crops, and
incidentally, the Secretary has added to his statement that we would use alternative methods whenever these are available and practical, and is stressing
witliiu tin1 department n use of uonchemical means where these arc available
to us.
Now. this is all developments since the last spraying here at Globe, I hope
this is clear.
Congressman MCCARTHY. Are you spraying In other parts of your region?
Mr. PIEKOVIOH. Xo, sir, and we have no plans to spray during current, or the
comiHi! fiscal year nt this time.
Now. if wo have some break-throughs, I'm sure we will be talking about
this. Again, it wmild be premature to say.
Congressman MCCARTHY. What's the basic rationale behind the spraying here
at «:iol.ev
M;1. I'lr.iit.vu-H. You metin
Congressman MCCARTHY : What's the purpose of it?
Mr. PIKROVICH (continuing) : The purpose of the project. This is the part ot
the region, and the Tonto National Forest chaparral management program.
This program lias many objectives for—it' I may take a minute—lire is a very
common ingredient in the life history of chaparral, and in trying to brim;
management to Chaparral Forest, we have excluded lire, or we are using lire
by prescription, rather than have the chance of holocaust. In doing this, we
attempt to bring a break to the fuels in large continuous masses by developing
grassy ridge ~o|i.-. or grassy openings. These have other advantages for ;'e.&gt;;&lt;!e
w!io want to use the forest, and for game.
It happens that the project here in the area was a water-yield project. We
have learned through research at the 3-Bar experimental area, ami particularly t h a t we can substantially reach the flow of .streams, particularly in the
winter months where the vegetation is not using the amounts of water that
chajuirrnl vegetation does.
Now. herbicides were used here at Globe partially because of the known
flooding potential of these streams, and that they also know that lire over a
large area could cause floods. So rather than use prescribed lire as initial
treatment, herbicides were used.
We have plans to use some small amount of fire to continue our work here.
Congressman MCCARTHY. Doesn't it say right on the container that this
should not be used over water?
Mr. I'ir.RovicH. That's correct, and as the project Instructions were followed
here, the applicator pilot was to interrupt his spray everytime he passed a
major stream channel.
Congressman MCCARTHY. "Interrupt his spray." you mean from a helicopter?
Mr. I'IEROVICH. From his helicopter, yes.
Congressman MCCARTHY. Do you think that is that the answer?
Mr. PiKKovrcH. Well. I think it's quite practical, sir.
Congressman MCCARTHY. Well, wind might carry. Aren't there restrictions
under the circumstances in which you use it?
Mr. PIF.UOVICH. First, let me explain in spraying this area the primary pattern would in? along, or parallel, or to a water course so that it isn't necessary
to turn valves off as you may each time he crosses at the creek, l-ut he was
going to be crossing streams at the same time he has been spraying. So he
would be than instructed to interrupt the spray before making such a crossing.
Some drift did occur into the bayous, we have found some of the Sycamores in
the Kollner area, the tops have been hit. We don't feel that a substantial
amount of herbicide came to the water course, and the pilot was instructed
not to apply this over water.
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Congressman MCCARTHY. Are they instructed only to spray when the wind is
blowing at a certain mile per hour'.'
Mr. 1'iBUovicii. Yes, that's right.
Congressman MCCARTHY. What is It, eight '!
Mr. PIEKOVICH. In some projects it's 5-mlles per hour, in this case it was 10.
Congressman MCCARTHY. Tea?
Mr. L'lERovii-H. Yes.
Congressman MCCARTHY. Is that rigidly adhered to?
Mr. PIBHOVICH. Well, I would hope that It is, here we are depending on other
people to do our work, but we have a project area officer, and this project hud
n project area officer who works from the helispot where the copter is operating, using a pocket anemometer, and as he noticed the wind picking up lie
would Hike the pricket anemometer out and keep track of the gusts. Whenever
It r. pin-ouches 10-mlies per hour, the project would be shut down.
1 have records here with me of the shut-down on this project, it1 you are
Interested.
Congressman MCCARTHY. Von are undoubtedly aware that some of the residents in the area charge that .spraying went on in much stronger wind velm-itles?
Mr. 1'iKiiovicii. Yes, sir. I am. and I am aware that there has been drii'ts.
and we arc attempting to identify how i'ur this drift went. In the task force 'J
report, we identified a visual effects drift line, we are currently working on
iiu'rared titterpreiution, and I would be very happy to furnish you with a map
which delineates how far the dead vegetation that shows up. That's not available to see by the naked eye.
Congressman MCCARTHY. That would be very good to fill out the record. I
would like to have that documentation very much.
Dr. GALSTOX. Do you mind if I ask a question at this point?
As a scientist. I'm interested in following up one line of questioning here.
T!ie bciieii'S t'uitt. &lt;me wishes to derive from this program lias to do with
increase:! water How'.'

In part.

Dr. &lt;iAi..s'rox. And the other part is, I presume, to have a more accessible
and manageable terrain where the Chaparral vegetation Is?
Mr. I'ICKOVICU. That's a good generalization among other things. We would
like the esthetic qualities of the area to be an indication.
Dr. ('! ALSTON. l.)o you see any deleterious consequences of partial denudation
of the hillsides where Chaparral is growing?
Mr. PIBUOVICH. It's not our intent to denude the hillside.
Dr. GALSTOX. I said partial.
Mr. I'lEKovicii. In the course of making a conversion, one often has to take a
compromise, and we do compromise to the extent that we will —say for example, in burning— taking out an area, we will burn only so long a slope here
because any more we would have an overflow of plants and water, and erosion
while it is bare from burning, it is an opportunity for a torrential thunderstorm, or wind to cause erosion. But this is also one of the compromises that a
farmer must make when he plows his field.
Dr. GAI.STOX. And this is something you think you can keep under pretty
good control with applied herbicides?
Mr. I'IKKOVICII. In this case we used herbicides for that reason, yes.
Dr. (SAI.HTOX. Was there any measurement for the relevant erosion rates
before and after herbicide use in a given area?
Mr. TiKisovR-H. In the 3-Bnr area this is being noted at this time. The studios have been in progress for some time, I don't have those data with r.v.'. but
[ could find them for you.
Dr. OALSTON. I, personally, would be very Interested in having thos? data.
It's been my impression that some programs have been gone Into fiiirl.v massively without the comfortable feeling that there's a lot of scientific data
behind the original studios to tell us that this is really what we ought to do.
and in calculating returns per acre, in terms of where we've applied. T t h i n k
we have to have a negative quantity in there for possibly deleterious eiTccts.
that possibly are not measured.
Congressman MrPArTiiy. I'd be eager to see those.
Mr. PIKHOVICII. I'd lie happy to furnish them for you. I t h i n k something we
have going right now, you may notice in the statement we've furnished you,

�138
we are looking at alternatives, and tolerable levels, and we are approaching
that very thing using projects t h a t have been installed as a basis for arriving
at this.
Congressman MCCARTHY. On that I wonder if I could ask you, are you now
giving license* for the use of Knron?
Mr. I'lKuuvieii. We five no licenses for chemical uses. The answer would be
ii&lt; &gt;.
Congressman MCCARTHY. I see. From whom do they get these licenses?
Mr. riEKOvicn. The use of chemicals is done by—in our case, the approval of
a project proposal by a regional and national pesticide committee. Once the
forest officer who has a project wants to apply a herbicide he prepares a
formal proposal, it's submitted to our regional committee, if they approve, to a
national committee. And I'll tell you right at this point, our committee won't.
iii&gt;i"'"\v such a :isc. but we don't license,
('i.ngrossiiian .MC&lt;'AI:TIIY. \W!I. t h a n k you very much.
*V;II you In; available today an&lt;! tomorrow?
Mr. I'lKKovicH. Yes, sir, 1 will, as will the ranger and the acting supervisor
here.
Congressman MCCARTHY. Thank you very much.
Our next witness is Dr. F. I. Skinner, veterinarian from Globe.
Is Dr. Skinner here?
Dr. Skinner. I'm pleased to have a veterinarian testify in light of recent
Indications that the use of 2,4 ..*-T spray may have had harmful effects on
animal fetuses. 1 wonder if you would, for the record, identify yourself, your
biu-k;;round and experience.
Iir. S K I N X K R . I am Dr. Skinner, local veterinarian, I've been in the area 14
years, graduate of Kansas State University with a degree of T.B.M..
Now. these are my people, and I've lived amongst them. Now, any questions
you'd like to ask I'll try to answer.
Congressman MC-CAUTHY. Would you recommend the use of this Silvex
Kuron spray after tests have shown that is has teratogenlc effects on animals?
Dr. S K I X X K R . No, I wouldn't recommend it. without further study, further
research.
Congressman MCCARTHY. You think it should be stopped until
Dr. S K I X X E K . Yes. sir.
Congressman MCCARTHY. You have some question about the Bionetics findings of the effects of this on animals?
Dr. S K I X X K R . I'm a clinician, I'm not research. I have not seen any effects
of a n i m a l s in this area—definitely, clinically. Xow, as I say I'm not a
research. I'm a clinician. I don't set myself up to be an expert on it, but I've
not seen any abortions, malformations of fetuses in this area that I can clinically say it was caused by Silvex, or 2,4-D. or pesticides.
Congressman MCCARTHY. As I understand it, and we hope to hear from
others, that there have been allegations made that the 2,4.3-T sprayed did
cause malformation in animals.
Dr. SKix.NF.it. I cannot speak for those. I have not seen them myself.
Congressman MCCARTHY. You did not. Were you ever asked to examine the
animals in question?
Dr. SKIXXEU. No, sir.
Congressman MCCARTHY. You were not
Dr. SKINXER. No. sir.
Congressman MCCARTHY. So that you just don't know?
Dr. SKIXXF.R. I don't know. I don't pretend to know.
Congressman MCCARTHY. All right. Well, maybe they will be calling on you.
Dr. S K I X X E R . I hope so.
Congressman MCCARTHY. Well, thank you very much. Doctor Skinner.
Dr. S K I X X K H . Thank you. Congressman McCarthy.
Coir-Tessniau MCCARTHY. Our next witness we'd like to call is Mr. Robert
McKnsiak.
Mr. McKnsiak?
Mr. SKOMP. Sir, I represent Mr. McKusiak as an attorney, and he's
requested that he be called later. Can you pass him at this time? He wants to
pass at this immediate time.
Consressman MCCARTHY. Surely.
In t h a t event we'd like to call Mrs. Billee Shoecraft.
Mrs. Shoecraft, I wonder if you'd identify yourself for the record, and

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Mrs. SHOECBAFT. Billee Shoccraft, Ice House Canyon, Glolie. Ariz.
Congressman MCCARTHY. And if you would it'll us a little bit about how long
you've lived here, iiuil your own experience with the chaparral spray programV
Mrs. SHOECIIAFT. We have been In the area since 19-17—Mr. Shoecraft a little
longer than that.
Congressman MCCARTHY. I wonder If you could tell us about your experiences with the spray program, and some of the correspondence you've had
with the various agencies of government In this connection.
Mrs. SHOECRAPT. I'd be glad to, thank you.
We first became aware that they were going to spray a chemical, which they
asserted was harmless
Congressman MCCARTHY. You say. "they"
Mrs. SHOECRAFT. The Forest Service.
Congressman MCCARTHY. U.S. Forest Service?
Mrs. Snomi.UT. night, In 1905. They had published in Hie local paper a
news Item dated August the 10th, 1905, In which they said the herbicide will
he 2,4-1), and 2,4,5-T mixed with diesel oil, and water. The diosel oil will serve
as a weight factor to insure against wind drift. Neither 2,4-D or 2,4,5-T itharmful to birds, insects, fish, wildlife, or humans.
Congressman MCCARTHY. Do you have a date and name on that?
What was the publication, what newspaper is it?
Mrs. SHOECKAFT. From the Arizona Record.
Congressman MCCARTHY: Of what date?
Mrs. SHOECRAKT. Of August the l!)th, 1065.
1 also have the typed-up version when lie initiated at that time from which
he deleted the word. "I anticipate honest Inquiry from many individuals and
groups concerning the project. I also anticipate adverse criticism and harassment from those who devote their lives to criticizing and harassing."
I forgot to read the part where he invited the general public to conic and
see them spray.
If you are as curious as I am, you will want to drive up and watch the
oiwration. I hope you will.
Again, 1 read from the report Xo. 16, Georgia Forest Research Counsel,
Macon, Ga., 1965. On page 28 it says, "Possible harmful effects: 2,4-D and
2,4,5-T have a low toxicity, although spray applications leave no toxic residue,
a tolerance of five parts per million has been established on or in apples,
citrus fruits, asparagus, pears, and quinces. We can find nothing in the
Department of Agriculture to back this up."
Then, they further said, "Since some persons may be allergic to the oil in
the herbicide mixture, skin contact should be avoided, and when treatments
are used a respirator is also a desirable piece of safety equipment.
Congressman MCCARTHY. Who is saying this?
Mrs. SHOECRAFT. This is from the Southwestern Forest Experiment Station.
Forest Service, U.S. Department of Agriculture, Asheville, X.C.
Congressman MCCARTHY. And the day on that, please?
Mrs. SHOECRAFT. The date on this was 1005. It further says—after mentioning the respirator, the odor, or vapors may bring on a case of nausea. The
Forest Service Health and Safety cautioned that 2,4-D and 2,4,5-T are mildly
poisonous, and flammable in an oil base. However, we were Invited to come
and see the spray.
Congressman MCCARTHY. Do you have any more documents that cast some
Mrs. SHOKCHAFT. Oh, I've many.
I have here this little item that was given to us, there were a few missing
l&gt;ages, H only had four, so I got in touch with Dr. Holston (phonetic) at
Hellcville. Md., bec:iuse tills is the U.S. Department of Agriculture, and I wondered where the rest of the pages were. .So Dr. Holston from Belleville mailed
me a package in which was included the rest of it. it totaled 2r&gt; pages, and
this concerning the toxicity of some organic herbicide to cattle, sheep, and
chickens. It tells about some of the things that they found In relation to the
herbicides that we've been sprayed with. We don't know exactly because the
reports have varied, but they have said they used 2,4-D, 2.4,fi-T, and Sllvex.
They further said It one form, then the tests showed different forms. I quote:
-\Ve concluded—that the enlargements were caused by the chemical reaction of
the diluted herbicide formulation. The ecropsy—the liver was enlarged and
viable. The kidneys were congested. A small abcess was found in the parotid
45-3C2—70
10

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140
lymph node. In one year that developed a swelling in the region related to the
chemical reaction. Associated other lymph nodes of the body were often
enlarged and hemologic."
Congressman MCCARTHY. Mrs. Shoccraft, I wonder if just for the record, \ve
might just interrupt you briefly. I would like to ask Professor Galston if he
would explain the difference between Silvex Huron, 2,4,5-T, and 2,4-D just for
the record.
Dr. GALSTOX. These are very closely related materials, and I think from the
toxicology point of view, and from the points of view—the presence of any of
these impurities like the dioxln we were talking about, they would all be in
the same bag.
2,4-D Is 2.4-dichlorophenoxyacetic acid, 2,4,5-T has one more, that is 2,4.5trichlorophenoxyacetic acid, and Kuron is simply a trade name for a similar
preparation that I believe is a Dow product.
Is that correct, I don't whether the foresters here would
Mr. PIEROVICH. Yes, that's correct.
Congressman MCCARTHY. Is there anything significantly different between
2.4.5-T and SilvesV
Dr. GALSTOX. I would say none whatsoever from the point of view we are
talking about. The toxicity would not be due to the length of the chain, but
due to the fluorinated aromatic nucleus, as a chemist would call it.
Congressman MCCARTHY. Mrs. Shoecraft, I realize you have many documents, and we would like if we could to have any of these you would care to
submit for thu record.
Mrs. SHOECRAFT. I'd be glad to.
Congressman MCCARTHY. Would you, this would help very much.
Mrs. SIIOECKAFT. Yes.
Congressman MCCARTHY. However, now, if there are any particularly salient
quotations that—without being overly lengthy, you think should go into the
record at this point, we would like to have those.
Mrs. SHOECKAFT. May I submit Farmers Bulletin Number 213S, U.S. Department of Agriculture, issued April 1001, slightly revised. August 10C.9, referring
to what their rules are oil what the wind velocity should be.
Congressman MCCARTHY. What does that say?
Mrs. SnoECRAtT. It says. ''Apply the spray when the wind velocity is less
than 0 miles per hour, and the air temperature is 90° or less. Again use a
coarse spray
"
They did not use a coarse spray, they used a flue spray. "Use a slowly
vaporizing formulation."
They did not use a slowing vaporizing formulation, they substituted water
fur oil in a v e ry small amount and released it at very high altitudes on a very
lint :,nd windy day, and they kept no records—weather records on the job.
Congressman MCCARTHY. Can you substantiate those points?
Mrs. SHOWRAFT. Yes, I c:sn.
Congressman MCCARTHY. How?
Mrs. SIIOECRAFT. I'm reading from file Xo. 2520, and it states in this lefthand corner to the file, it's from William H. Moehn, district ranger.
Congressman MCCARTHY. How do you spell that?
Mrs. SUOECRAFT. M-o-e-li-u, district ranger, date July 11, 19H9. subject: Water- .
shed protection, Kellner Russell chemical maintenance, fiscal yi-ar IOCS).
This memo is a resume of the fiscal year 1909. iu.ilnten.ice project.
"The M&gt;r.iyini: done on June s. 0. 10. and 11, U)C9. were started at (!:40 a.m.
on Sunday. June -S, and the hilltop located on the Icehouse C;;nyon Trail, at
•; :ol a.m. after the third loud was through, the pilot flew to the O.C.C. Camp
to choc-!; his spray. When he landed Mr*. Show raft arrived and told him some
of rh:- s;iray lunl landed "U her. The pilot returned at the hill at 7:14 a.m. ami
said somi'ime should u'o tfilk to IIH-.
"I left th&lt;; spray job at that time and did not locate Mrs. Shoecraft."
In f;:et. r r:\llKl Washington on the third day. but they didn't find me, but
fl.:-y pn;i'.d have if they had looked.
"I left the spray job and we continued to spray from the helispot until
K&gt;:."7 i!.:n. when we landt-d :it the hclispot the wind w.is coming out of the
Knst frim 0:40 a.m. to 10 :.VT a.m.. we l^it and went to the Final Road lielispot
aii&lt;l iifgiin to spray. Wo contiuue&lt;l to spray until 15.05 a.m.. nt which time the
wind reached 10 miles per hour plus, and we shut down. We resumed spraying

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at 5:OS p.m. when the wind dropped below 10 miles per hour and continued on
until 7 :35 i&gt;.m.
"On July 0. the first load was off the ground at 5:35 p.m. We continued to
spray until 10:18 p.m., at which time we shut down because of winds In excess
of 10 miles per hour. We did not spray anymore on the 9th.
"We started at «:02 a.m. on June 10, 3 days after Mrs. Statecraft had notified, ami Hew until 11:15 a.m., wheu wind forced us to shut down. We did not
spray anymore on the 10th.
"On June 11, we started at 5:18 a.m., and flew until the project was completed. A total of 977 gallons of Silvex was used at a rate of 2 pounds acid,
equivalent per acre. The total rate per acre was 8 gallons. 1,000 acres were
treated. We did not keep weather records on this project.
"The wind .speed and direction at the Globe Ranger Station at 1 p.m., each
day of the spray job are listed on the next pages, and it shows on June 11, a
speed of 16 miles per hour southwest.
"Signed and stumped by William H. Moehn."
Congressman MCCARTHY. So that even in his own records he acknowledges
that he exceeded the limits that had been set?
Mrs. SHOECRAFT. Yes, he did. I refer further to the Department of the
Army's Circular 33061. I have a letter here from Representative Steiger's
office, to apply back in 120 days, but I didn't choose to apply in 120 days. I
called the Adjutant General's office, I said we needed it now, I'm one of the
victims. I was informed l.y the Department Office that they sent it out to the
printer's. My suggestion was you either get it from the printer's, or you get a
copy, I need it now. I received It in £ days.
In this it refers to the formulation which they call. Orange, and it says that
it is one part •J.-l.-VlVnnd one part 2.4-D. I have before me a letter datei! October (!, llHil). from the U&amp;DA. in Phoenix. The branch of the Forest Service, the
Tonto National Forest Service, signed by Mr. Jenkins for Mr. E. E. Cortney,
Forest Service. lie says:
Dear Mrs. Sinn-craft, following Is a list of chemicals purchased by the Tonto
Koresr as re&lt;iuevtr&lt;l by you. The mixture was two gallons chemical with seven
mid one-half gallons per acre. In a few cases more water was used, and all of
them are J.4-1) and 2,4,'i-T.
.Since I was curious because there was no Silvex, I further proceeded to say
who bought the Silvex, and I was finally informed by Mr. Moore at Salt River
Project they made the decision to purchase the Silvex. They did not purchase
it. as they said in the Forest Service. They have lied, it's the only word I'd
like to use because it's lying when It covers things when they "know better.
Congressman MCCARTHY. I wonder if you could submit those documents to
Mr. Riddleberger for our records'/
Mrs. SUOECRAFT. Ail right.
Congressman MCCARTHY. And if you are available we hope to go out this
afternoon and tour the area.
Mrs. SHOECHAFT. He pleased to.
Congressman MCCARTHY. Thank you very much.
We would like to move on now and hear from Mr. McKusiak.
Mrs. SUOECRAFT. I had requested analysis that were done on our plant back
In September before another task force is to arrive, which I understand Is
next week. I've spoken with Mr. Tschirley this morning, he called, I told him
before I wanted anymore samples taken I would like the reports of what they
took In September. They seem to be still evaluating these water samples we
sent in. and for your Information I just learned this morning the samples
t;i!cen from our own drinking water last week are still highly contaminated,
:ind I suppose I'm the first human to go on record to be able to say that they
hiive now found 2.4-D in my pound of flesh, and that was as of this morning
from two different labor;ilories.
Congressman .MrC.vinnY. That's important, could you elaborate on that? Do
you have those laboratory findings?
Mrs. SIIOEORAFT. These were found in the G.II.T. Laboratories in California,
the other laboratory I'm not even aware of the name where the samples were
sent.
Congressman MCCARTHY. What's that, G. H.
Mrs. SHOECRAFT. That's the laboratory where the Department of Agriculture,
|i.&gt;:.-for Hemtim (phonetic* had recommended that the samples be sent on the
plant life originally. There will be a longer report on it this afternoon.

�V
K.

Congressman MCCABTUY. We will cheek that out. Did you mean to Imply
that a biopsy has boon applied on your tissues, and 2.4-D has been fovind in
your-—.Mrs. SIIOECHAFT. As of tills morning they were not complete.
Congressman MCCARTHY. Thank you very much.
We'd like to cull Mr. McKu.--i:ik now.
Mr. McKusiak. d« you care to In- accompanied by counsel? If yon do, it's
perlVrlly all right.
Mr. SKOMP. We IICVM no ubjectlon.
Congressman Me .iiiv. All right. Mr. McKuslnk. I wonder would you identify yiiurself for t!;.- '.ecord. please, your name and your background, and how
long you've resided here.
Mr. McKrsiAK. I'm Robert McKusiak. and I've been nn Artist in tile and
mosaic for some L"J years. I have a background prior to that time, and since
th.-it time also in science. I majored in chemistry In college.
Congressman MCCARTHY. What was that?
Mr. McKusiAK. University of Arizona. I do not hold a degree.
Congressman MCCARTHY. How long have y«n resided here?
Mr. McKrsiAK. I've lived in this area since 1032 with the exception of the
time that I attended the University of Arizona.
Congressman MCCARTHY. Now. T wonder if you would verbally give us n generalization of your experience with the Forest Service .spray program?
Mr. McKusiAK. My experience with the Forest Service spray program really
didn't come into being fully until 1969 following the June spraying. Well, let
me back up, it came Into being in nbout May 31, .19CS. I was nwnre prior to
that time that they had been spraying, but I was not aware that the things
that they were spraying were particularly harmful. I had seen unusual effects
taking place, but I didn't know what to attribute them to.
Congressman MCCARTHY. What unusual effects, could you cite a couple?
Mr. McKcstAK. Yes, one in particular which I would prefer that Mrs.
McKusiak documented for you because that's her field, and not mine, but specifically in 19(56, in May of I960, the brown pewee population, these are birds
that live in our canyon area, suddenly started dying in great numbers in our
yard. We have a waterer that birds come to, and there were birds nil over
during May which had matter in their eyes, and seemed to be having respiratory trouble, and were dying, and at that time we continued spraying it.
Congressman MCCARTHY. You don't happen to have any photographs of that,
do you?
Mr. McKusiAK. No, I don't, I would prefer on a, discussion of birds to have
Mrs. MeKusiak go into this because that was her field. But. in 1968, on the
81st of May. I was up at my property where I get my clay, it's private land in
the area that was sprayed, it was included in the area sprayed. I had my wife
and three children, and the two dogs up there, and the spraying was taking
place down canyon. The helicopter came up the canyon, we have a stock pond
that was between us and the edge of the property, so to speak, and the helicopter came up the canyon and made a turn southerly, in other words, it made
a right-angle turn toward the mountains, and it approached. We were waving
our arms because we didn't want to be sprayed. He made a turn and he was
so close to us, and the spray descended upon us, and upon the pond, and upon
our kids and dogs, and so forth. At that time we weren't really aware that
anything was wrong with it except we both rushed home, my wife and I have
both had headchcs from It.
Congressman MCCARTHY. The pond, Is that drinking water?
Mr. Mt.-KrsiAK. This is a pond which is used for livestock water, but It's on
private land.
Congressman MCCARTHY. Now, you heard undoubtedly the Forest Service say
that they stopped spraying when they would get over a stream, but they didn't
over a pond. I suppose that would be obviously important?
Mr. McKusiAK. It's Incorrect that they stopped over streams, they sprayed
directly over three different semipermanent streams that I know of, and one
permanent.
Congressman MCCARTHY. Did you see that yourself?
Mr. McKusiAK. I saw them spraying in this area over it, and the devastation continues right down to the edge of the stream, it's quite visible.
Congressman MCCARTHY. Will we be able to see that this afternoon?
Mr. McKusiAK. I'm sure you will.

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143
Congressman MCC.VISTHY. I think it's very Important.
Mr. McKusiAK. Onu canyon In particular In I'JiiS when I was .sprayed with
iiiy family on our property, and wo did have Illnesses and have had illnesses
thereafter, continued since this time. This imrticular little canyon, when they
Ili-w up toward us—which has a permanent stream In it, and they flew right
up the fiiiiyini to the poml. it's a stream that seeps out from the pond, and has
never been dry.
Congressman MCC.\I:THV. I wonder if you would, for the record, tell us about
changes in livestock, and other animal life on your farm, which you would
attribute to this spraying.
Mr. McKi'siAK. I really don't have a farm to correct the record, I have
many different animals, my wife keeps ornamental fowl, she is an arehooornitliologist. and she works with archeological birds, and she keeps files of various types for comparative work, and also for our own enjoyment.
\Ve have 10 or 12 milking goats that we have had for Hi, or 17 years. We've
kept a small population of them, and in the last - years we have had a
number of our mi'k goat* bear kids, they have from two to three offspring a
year, each goat, and a number of these have borne deformed offspring. When I
say deformed, I'm referring generally to their bends, their heads were born
iualnlmiK.il, and malformed in some cases their bodies, but generally their
heads.
We have one goat which is already Iteen covered by the news media, but we
have one goat which wasn't as malformed as the others. We have kept it alive
simply because people were denying such things happening. I would say most
uf the offspring that were born were born either dead, or deformed, or both.
Most of them who were born deformed were born dead. Ill other words, the
.-mlmal mlsciirrled deformed offspring.
Congressman MCCARTHY. Did you ever ask Dr. Skinner to come out and look
at these animals?
Mr. McKusiAK. Xo, I don't believe I've ever discussed these animals with
Dr. Skinner until just recently, but Dr. Skinner and I are good friends, nnd
\\-e have from time to time called him to ask how much dosage to gi\v an
animal if we were going to give them a shot. Some of our animals from lime
ni time have suffered from pneumonia, or things of this type. For example,
many of our fowl in birth have died. I'm referring specifically to geese, and
ducks, and some chickens, and many of them have died, and we found by
giving them a shot of com-biotic, it's a penecillin streptomycin, I believe, comhination, by giving them a shot, usually we could save them. These fowl would
come down with what seemed to be pneumonia. There are many other people
in the canyon whose fowl done the same thing.
We found by giving them a shot we could save them. We called Dr. Skinner
to find out what the correct dosage would be, and we generally didn't call
hack telling him it came out.
Congressman MCCARTHY. Well, Mr. McKusiak, I know we could go on for
some time, but we have to adjourn shortly, but we will be with you this afternoon.
Mr. McKusiAK. I would like to make one other comment, if I could, for the
record.
Congressman MCCARTHY. Surely.
Mr. McKusiAK. I was talking about 196S when we were sprayed on our own
property, and our own dogs following this spraying, we went home and
washed, but our own dogs that were with us, two of them became ill immediately with what we considered to be pneumonia, at that time we didn't assoi-inte it really with the spray, we didn't think about it, and we gave the clogs
—we tried to call Dr. Skinner and he was out of town, and we gave the dogs
iiim-htotics for this, and r believe It was the next day we called Dr. Skinner,
lie was back, nnd my wife checked with him and she checked the dosage she
had given them, nnd he said it was twice too much, and give them half as
much ngain. and we did., and the dog survived. It would have died if we had
not given him the medication.
Congressman MCCARTHY. You still have the two dogs?
Mr. McKusiAK. Neither are malformed or anything, one of them has never
hceii quite well, it's never been well. It wheezes a lot
One other thing, there are many families In the canyon and many families
in Globe arid Miami who have dogs that are bleeding from all body openings.

�144
We have Uogs of this type, and people who have had dogs die from this, we
could put you in contact with.
Congressman MCCARTHY. We would like to have that information.
Well, thank you, Mr. McKusiak. We'll look forward to seeing you this afternoon.
This hearing will stand adjourned.
Congressman MCCARTHY. The hearings will conic to order.
I've just received the following letter from the White House which I wish to
read into the record at this point. It's from the Science Adviser to the President of the United States, Dr. Lee A. DuBridge.
"The White House, February 10,1970.
"Dear Mr. McCarthy: This will acknowledge your February 3rd letter concerning 2,4,5-T, the October 29th announcement that you referred to was a
statement &lt;..f the ac'ion-? tliat were planned to be taken by the various units of
the Federal (J:u&gt;rna.ent in relation to the 2,4.5-T. It was not a directive to
agencies i'or the simple reason that statutory responsibility for these decisions
rest in the sepurak- aswncips.
••I'm sure that l&gt;y ww yon have heard from the Department of Agriculture.
1 appreciate your '•&gt;«&gt; &lt;in the desirability of an investigation of reports of
I'ir'li. nf :na!f;&gt;r;:i'.&gt;i! chil.lrcn In Vietnam. By copy of this letter I'm calling
your views m s.».-!v:ary laird's attc-ntton since this area is primarily ills
responsibility.
"As in L'.i-I). this compound is being reviewed along with otlier compounds
beliix singled nut as requiring additional study in the Bionet.ics records to
which you referred."
Sitriii'd. "!.»•&lt;• n PuBridse. Science Adviser to the President."
I'd !:i;e to contrast this with a statement as it was issued cm October 29
wlicre Iiulii'id^-. 1 said tli.it the Defense Department will restrict use of 2,-1.5-T
to *•!„• areas iv:ii&lt;&gt;te from population, that the Agriculture Department will
ciiii'vl registration «f 2.-T-D for food crops effective January I. 1070. The
Pc-nirtmoiit of ABri'-ulturc and Interior will stop using 2,4.5-T in their own
!".. : Mi's in p'lpulpted areas, or where the residues from use could otherwise
re;;:!: man. That the Department of Health, Education, and Welfare will eoinpli-T" action on a tolerance for 2,-4.3-T, the residues 0:1 foods prior to January
1, 1070.
This is obvior.s'y a retreat from the position taken by the White House in
October 29. As I r.-a 1 the statement at that time it was in the form of a directive that t!ie de'iarriijnnts will do such and such, now we find that the White
House is backing ••:':' from this, and is saying that the statutory authority rests
with the aceiicit1.-.
It seems to nip that the President of the United States has authority—the
nlt':nntp authority ov«r theso agencies, and I repret very much that the President's JSciom-c A:V-'iser has seen tit to retreat from the decision of October 29.
\v!,'.l: I !n&gt;lU-v" \v;\.- t)ii? \v;.-y one. The use o* this particular chemical should
be banned pending tests.
On the plus side I'm delighted to be Informed last night, and it's reported
today in the press, that the distinguished Senator from Michigan. Philip Hart
has announced he will hold hearings on 2.4.5-T. He asked Secretary Hardin.
Secretary of Agriculture. Robert Finch, Secretary of Health. Education, awl
Welfare, and DuBridge to testify on March 11. This is further evidence to me
that the compound's effects require additional evaluation, and I expect that I
will testify myself before this Senate Subcommittee when they have hearings.
I will make that request.
I should also anii''iu&lt;)c(' that a report on my investigation will be prepared in
consultation with Dr. Oalston, and will be issued at the earliest prut-tuni
point.
Now. wo would like to bear nga'n from Mr. Pierovich of the Forest Service.
Is lie here?
Mr. PIEROVICH : Yes. sir.
Congressman MCCARTHY : I would like to say for the record, which I just
said on the radio station here, tb.it I have been very favorably impr"s---i-&lt;1 ii\
the oooppration of the Forest Service. I think that anybody who has any vmatferine of knowledge about this whole thing must realize that this is soinpthirjr

�145
transcending individual agencies out in the field, that we are talking here about
national policy, and what is done out in the field really is a result of decisions
made at a much higher level, and to try to focus responsibility on a field unit
j think is really to carry this too far. I've been most impressed with your
cooperation, and that of your colleagues, Mr. Pierovlch, and I want you to
know that we appreciate it very much, and our report will so indicate.
I understand you would like to elaborate on the statements you made yesterday.
Mr. PIEBOVICH. Thank you, Mr. Congressman, for your kind comments, and
also for the way you've conducted this hearing. I think the Forest Service is
'pleased with the way the hearing has gone. There are some significant elements of Forest Service concern that I felt should be made a part of the
record this morning, and I'll read essentially from that statement.
First of all, the Forest Service has used phenoxy herbicides, but not since
the nationwide controversy broke last fall. In fact, the last use of herbicides
on the Kellner Russell project was June 11, 1069. and to the best of my kncwledge, the last use of any herbicide by the Southwestern National Forest was
the August, 1900, on the Gilii National Forest in New Mexico.
Second, it's apparent there are several persons In this area who believe
there are unknown, or suspected characteristics of these herbicides which niiiy
have caused them damage, and this is of concern to us.
Three, it's apparent we must continue our efforts to ascertain the extent of
drift levels of herbicide residues, and the definite relationships between herbicides over environmental factors and the responses of plants and animals in
this area.
These studies are to be made public when they're completed.
Lastly, the extent oC continued deferment of herbicide use in the Chaparral
program is dependent upon the outcome of our studies nnd of tin- I V i n r t incut's investigation of these matters.
Congressman MCCARTHY : Thank you very much. 1 wonder if you c&lt;&gt;ui'l fcr
the record, repeat what you told me yesterday relative to the drift of the herlifcide over streams, and into adjacent private property, and what step*. should
this be resumed, assuming that, it &lt;-an be shown to lie safe, what steps W"u!d
he needed to correct that?
Mr. PIEROVICH. At this point, this will be my own opinion, but I first mentinned to you yesterday that our instructions to ti,p applicator jii'ot were to
interrupt his spray application when he crosses streams, we had.definite flans
for the project here to call for application away from the open water, and
main stream courses. 1 do believe there was some drift into this stream course
ns evidenced by some top kill on the Sycamore* on the stream bottom. Then1
lias been drift from the project area onto private property which we have
established so far as the visual effects are concerned, and from this I'm &lt;-ertain that we will be developing new guidelines to both assure that the herbicides that we might apply in the future are confined to the project area, and
tn assure the safety of the public.
One definite indicator in this is that it would be desirable to use a much
more restrictive windspeed in application.
Does that answer your ouestlon, .«ir?
Congressman MCCARTHY: Yes, hut what wind velocity do you think would be
sife?
Mr. PIEROVICH: I wouldn't want to speculate at this time, but we do have a
Lvneral rule of 5 miles per hour, and we know that herbicides were applied
l-ere to 10 miles per hour, and we see new development in the herbicide aprilirntion field, the use of inverts has become more and more popular, and with
•anno corrective work recently done Is this area I feel this will help us a srr'-nt
.!c:«l.
r.jngressman MCCARTHY: Another point Hint T definitely sympathize with
yon nbout is difficulty you have of getting information. I think the fact that
••»M weren't apprised of the Rionetics Research Laboratory finding on teratoLvnlelty until late last year suggests a problem in communications bere. and If
you have any sugeestlons for new legislation TV1 be irrateful. Do you feel you
cot enough information from AVashlncton on such .subjects?
Mr. PiF.iinvTf-n. I feel Hint in all of our—tlio ex.-hsingc of Information Is a
vi-ry complex thing today. \Ve do make ourselves available to conferences with

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people- in these fields. Our technicians In herbicide work attend meetings regularly on this matter. We are expected to keep ourselves informed. The literature has been quite full of the controversies on 2,4,5-T, and we have been
aware of the developing controversies.
The most heulthy thing that could happen in this area would be a definite
summary of literature that our technicians could refer to. There are abstracts
available, now. Imt, the combination of inputs from the universities and from
the various departments of government in one abstract bulletin would bo helpful to us.
Congressman MCCARTHY. Do you have anything to add, Mr. Plerovlch?
Mr. I'IEROVICH. No, I don't, sir.
Congressman MCCARTHY. Thank you very much, we appreciate it.
Mr. 1'iKiiovifii. Thank you.
Congressman MCCARTHY. Our next witness is Dr. Puul Martin from the University of Arizona.
Dr. Martin, I understand you are accompanied by Dr. Russell?
Dr. MARTIN. That's right.
Congressman MCCARTHY. Would you like him to sit with youV
Dr. MARTIN. Yes.
Congressman MCCARTHY. Dr. Russell, would you care to join Dr. Martin?
Dr. Martin, we appreciate your being here. I wonder if you would Identify
yourself and Dr. Russell for the record, your background and your particular
interest in this?
Dr. MAUTIX. I'm Paul S. Martin, University of Arizona. Department of Geology. I had training as a professional ecologist, and with me is Dr. Stephen
Russell who is a zoologist in the biology department in the University of Arizona. Ills special interest is In birds.
Congressman MCCARTHY. Thank you. Dr. Martin, I wonder before the record
If you would tell us about your Involvement with the spraying project, and
any conclusions that you reached, based upon your analyses.
Dr. MAUTIX. Well, I'm not involved in the spraying project, and I'm not a
herbicide export. I have no research experience with herbicides. I do have
interest in the vegetation of Arizona. I've spent years studying its fossil pollen
records, but the interest I had in Globe was In first seeing if indeed there was
any effect on vegetation as a result of herbicide treatment that had been
called to my attention. I have come up on four separate trips to visit the area
that was sprayed, and see what little I could of the community.
Congressman MCCARTHY. How long did you spend on these trips?
Dr. MARTIN. These were 1-day visits.
Congressman MCCARTHY. How many did you make?
Dr. MAKTIN. Four. As a result of seeing the area, and talking to some of the
people in the area. I was curious to see if just what degree the community
might have boon affected by this. I wasn't prepared to believe that people, or
animals could be affected by herbicide sprays because the little I heard indicated that those who work with herbicides stand underneath the spray plane
and are occasionally drenched by the chemicals, and don't suffer ill effects.
So it seems incredible that people in this community could be complaining of
such an effect, but they were.
Indeed as a result it seemed to me that It was important to listen to them
and try to understand what they were saying, and try to come to terms with
the only observers who witnessed an event that wasn't supposed to have happened.
It also seemed to me that some of the people involved in the work with herbicides were unprepared for this sort of experience, they weren't even listening
to the complaints. So I presumed to do that.
Congressman MCCARTHY. And what did you find in the course of your four
trips?
Dr. MARTIN. There is one other person that's involved in what I'm going to
say next. I don't know if she's here or not.
Within the last month a student from Massachusetts by the name of Miss
Adelaide Frlck and she was willing to go on a door-to-door basis, and interview
people in the community apart from the ones that I talked to.

�147
Congressman MCCARTHY. Excuse me, is Miss Frick present?
Dr. MARTIN. I liave the results, a summary of her door-to-door investigation
in the area, the purpose was to see if there complaints coming from any other
source other than the individuals that I talked to. The trips that I'd made up
here and the design was to on a door-to-door basis talk to approximately 50
people in the canyons close to the sprayed area, and to another 50 over in
Crestwood, which I believe is east of Globe at a further—at a point further
remote from the area that, was sprayed.
So what Miss Frick did was then conduct a door-to-door interview with
people close to the sprayed area, and another group of 50 further away from it.
Congressman MCCARTHY. What did she find, do you have the report? We
would like to have that for the record.
Dr. MARTIN. I'd be glad to give you a copy.
Congressman MCCARTHY. Would you care to summarize it?
Dr. MARTIN. I'll simply read about a paragraph from the report that summarized it, and of course, the individuals are not identified in this report, and the
complete questionnaire is not represented here, simply the highlights of it.
There arc three key questions, two that have to do with personal health,
and one that has to do with livestock. It turned out that few people do have
livestock in either—neither the spray area, or in Crestwood, but quite a
number have pets. This is what she found.
Regarding pets, 13 cases in which animals were effected, and one must presume some relationship to spraying although in no individual case perhaps
could this be directly proved.
This is the experiences of people living in this community who know the
nature of the community, and then feel that something has happened that's a
little bit out of the ordinary.
Thirteen cases in which animals acted, three kittens lost; two dogs lost:
infertile eggs, one; rabbits not breeding, two; chickens not laying, one; burro
lost, one; sick dogs, three reports.
Now, as far as people are concerned near the spray area, 23 of 56 indicated
Illness over the past 2 years which may IIP spray associated. Some people had
absolutely nothing wrong with them, or were not concerned. They thoughr that
those that were complaining were imagining it happened, an event that had no
bearing in the real world, that it was in the minds of the people reporting.
Other reported, and we're quite convinced that their experiences were
related to the events of last June, or earlier when herbicide spraying had hap0(1.

Of the 23 reporting illness, 21 were reporting breathing difficulties. Many of
these are attributed to the times of spraying. Some are attributed to smelter
smoke, there's no avoiding the fact that this area that experiences a good deal
of smelter smoke. Some of these people may be reporting an effect that is
indeed caused by smoke, I don't know.
There were five reports of serious diarrhea, including one entire family.
Tour reports of chest pains, including one false heart attack, one report of
roughing of blood, one report of subnormal temperature. Two reports of numb
pain in arms; two reports of hemorrhaging; two reports of irregular periods;
one report of miscarriage; two others by hearsay.
Fifty-six people interviewed, 42 mentioned some damage to plants, although
the purpose of this questionnaire was not to consider plant damage.
Now, in Crestwood at a great distance from the
Congressman MCCARTHY. Was the interviewer able to determine If such complnlnts were prevalent before the spraying began?
Dr. MARTIN. I don't know how one would do that. In fairness to the people
in the Forest Service who have worked with this project, one simply can't conduct a scientific experiment at this point in time. All we can do is talk to the
people who were the observers, or ones—or residents in the area, and while
tlioir memories are still hopefully fresh, recover some Information, Just having
to fake them at their word.
Congressman MCCARTHY. Let me Just clarify. Is the interviewer ascribing
these conditions to the spraying based on the interviews with the people? Do

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148
they- say that these phenomena results were the results of the spraying, or
don't they know?
Dr. MARTIN. Yes, some of them would rather not say. The question was in
effect, "Have you experienced any sickness which might be related to herbicide
spraying of this area."
It's a leading question in part. It's not a question that denies any ignorance
of the fact that herbicide spraying had taken place in the area.
I am sure there arc* many faults of a questionnaire of this sort that a professional psychologist would recognize.
Congressman MCCARTHY. Let me say as a point of Information, we will
shortly have put into the record a scientific data of the results on human
being,&lt; of 2,4,i&gt;-T, which I think you will find bear a similarity to phenomena
you've just described.
1 wonder if you would go beyond Miss Frick's survey to give us benefit of
your own observations of what you saw, and if you were able to reach any
conclusions about the effects of the spraying on either humans, vegetation, or
animals? ,
I&gt;r. MARTIN. Well, the effects on vegetation Impressed me as ones that have
to !...• watched over a period of time. Again, tills problem of who's to make.the
investigation, and how it's to bo conducted are important. The incident is over,
iiiul in the minds of some local people, hopefully will never occur again.
Tiit? problem is. what really happened? I was up on four separate trips, or 4
si-ii.iratc (lays, 1 snw .some thine? that I have, not seen in Arizona vegetation
before. Such as the presence on Century plants of flowering way out of season,
atn! immature new plants going on the old stocks of old ones without normal
set:-.! being set.
1 understand that this particular species of Century plant is known to do
that, and other botanists have seen such a feature.
The area that was sprayed, not all plants are dead in It. Some species like
Manzinita are remarkably resistant up to this point.
The effectiveness of the treatment Is doubtful. The areas of spray aren't
de,i;l.: The effects of spray on the outside areas on different plants have to lie
wat-- :t-d over a period of time to fully appreciate the change in phenology, the
cluiiuos of flowerng time, the change of time when the leaves appear, and
when they fall, the way the tradition of plants may be as far as overall
cror.-th is concerned, and if one wants to demonstrate the herbicide-caused
i-ffi-ct mi vegetation. It's also necessary to take iii'.o consideration all the other
environmental variations that aren't under control either, such as rainfall and
tei.. ••••nuure.
&lt;','ji!*re.ssman MCCARTHY. But, you did find evidences of drift outside the
privet area?
Dr. MAITIN. Yes.
r-mgressmnn MCCARTHY. Did you find evidences of 2,4,5-T in any of the
:ifl.&lt;:!ci.:it streams, or did you seok to find it?
Dr. MARTIN. Xo, I collected samples only from within the project area, soil
sju-.jj.U's «ind water samples.
PonsressnuHi MCCARTHY. You found evidences of 2,4.5-T in the water you've
co!!ecfpd within the project area?
Dr. MARTIN. The .samples that I collected and submitted to n laboratory in
Citllr'ornja came back w'.tli a report of the presence of 2.4-D. and smaller
ut:ioii!its of 2.4.5-T.
ronsrt'ssm.'in MCCARTHY. In the wafer?
!&gt;• MAHTI.V. Th'V" was a truce in the water, there was up to one part per
n'i'!;»!i In tlie s,.il of 2.4-D.
rvn.rressiitaii MCCARTHY. Is there anything that you or your colleague could
:!••!•! wli|e!&lt; would !&gt;•:• I'ertlneiit to our Inquiry?
Dr. M.U:TIX. T would make one recommendation, and then if Steve Russell
h.-i- r'liyth'nv he would c-ire to mid.
Tl:e ro:-«i!»men'i::t!nn wwirt simply lie that hospital records, doctors' records,
tin- vi'N-rlnnry record.* of t!ios.&gt; doctors and veterinarians In the Ololie area be
it'i'if dver very carefully by proper professional people.
f'":!;:r"ssman MCCARTHY. At tl-nt Milnt T think we should put into the
r-v.'T'! a -nemo of rnnvcrsition with Mr. Peter Riclrtleborger of my atn ft*, and

�r
149
Dr. Grantvllle Knight, M.D., 2901 Wilshlre Boulevard, Suite 345, Santa
Monica, Calif.
This conversation took place on February 0, 1970.
Dr. Knight informed Mr. Rlddleberger that he has two patients under his
rare from Globe, Ariz. While his examination is not complete, he is of the
opinion that their malady Is associated with the recent spraying of Sllvex containing 2,4,o-T by the U.S. Forest Service. Dr. Knight is of the opinion that an
investigation is warranted, and offered to submit a statement of his findings
upon completion of his examination subject to the approval of his patients.
Miss Frick Is here now, and I wonder if she could sit next to Dr. Martin
aad Doctor, if you would be good enough to reread that portion alluded to?
Dr. MARTIN. This simply summarises the interviews that Miss Frick condueled in the canyons that is Kellner Canyon, Russell, Sixshooter, and Icehnuse. Fifty-six interviews In that particular area, and some people who had
-rrious complaints to make were not considered in this Interview.
Wiiat I found just in tabulating what her questionnaire revealed was that
'_T! of i'O individuals indicated illness over the past 2 years, which may be
sjirny associated, 21 individuals reported breathing difficulties, many of these
:ire attributed to the -times of spraying, but not all. .Some were attributed to
smelter smoke.
There were five reports of serious diarrhea, Including one entire family.
Mi.ss Fitic-K. Yes.

Dr. MARTIX. Four reports of chest pain, including one false heart attack;
•me report of coughing of blood; one report of subnormal temperature.
Two reports of pains, or numbness in arms; three reports of uterine heniorrliaging: one report of a miscarriage.
There were two others that I thought were hearsay, but I wasn't sure had
nvilly occurred in family that you Interviewed, and then finally all the questionnaires wasn't directed to plant damage, there were 42 people interviewed
who mentioned at least some damage to their plants in that area.
Now. the Crestwood account shows much less effect, and this is what "lie
might expect because of the distance further away from the area of spray.
Congressman MCCARTHY. Doctor Russell, Is there anything that you would
add to the record here that would be helpful?
Dr. RUSSELL. I don't think I would add to the record, but I'm in agreement
with Dr. Martin's statement.
Congressman MCCARTHY. You are, you've studied the information he has
available?
Dr. RUSSELL. I have seen much of the general information, but I've conducted no Investigation of my own into it.
Congressman MCCARTHY. Thank you, Gentlemen, and Miss Frick, very much.
I'd like to now recall Prof. Galston.
Doctor, as we discussed here I understand you have some scientific data on
the effects on human beings of 2,4,5-T. I wonder if you would cite the source
• if this information, and the findings?
Dr. GALSTOX. Mr. Congressman, I'm very happy to present this Information
i'cffiiuse in the course of my wanderings around on this day I have found that
i-ci-Mln individuals tend instinctively to disapprove any allegations of direct
damage to human beings or animals.
Now, as I hoped I made clear yesterday, very small doses of 2,4,5-T can
iviisc birth abnormalities in laboratory animals, and that is now actively
under Investigation, and we've discussed to see whether it might be due to this
impurity called dioxln, or whether it was due in fact to the chemical.
But now, the question is, can we actually produce an effect on mature individuals, let us say male individuals, totally apart from pregnant females bear:ML' embryos In uteri, and I should say that there Is a fairly sizable respectaMe scientific literature on this, and if one looks in a variety of sources,
ii.vhuling the sort of encyclopedia of clinical toxicology by Gleason and Coughlin. and can find citations to many articles, and I have reference to a few
1,00'.

X«w. 2,4-D can produce, if it's administered in very massive quantities, it
,«ui produce death In the small animals, and there are even a -few cases

�150
recorded of its having produced very severe symptoms in man. The best data,
however comes from 2,4,5-T, and I would like to read to you a brief account
of an urticle published in 1050 by T. Flint entitled "Dermatitis mid Kidney
Damage Ascribed to Weed Killer 2,4,5-T."
Flint relates an episode involving two .sisters, age 4 and 6 years, who had
played tor several hours in a yard which had been sprayed heavily a short
time before with the Ortho brand of 2,4,5-T, brush killer. This was used for
the control of poison oak.
This spray contained 15.4 percent of the isopro ester of 2,4,5-T in an oil
base.
Now, I should mention parenthetically, I don't have the exact data at hand,
but Huron contains much more than that, I believe in excess of 60 percent of
this same ester.
The next day both girls exhibited generalized erythema—reddening of the
skin—and edematus swelling of the oral and vaginal mucous membranes.
The pulse rate and body temperature were not elevated, but both children
were described as appearing slightly toxic. The limbs and eyelids were slightly
swollen as the mucous membranes of the mouth were inflamed. On the 3d day
there were signs of kidney damage. Albumen was noticed in the urine. There
wiis no evidence of liver injury, the urinary abnormalities persisted for about
2 weeks, but 2 months later tin* urine specimen* for both patients were
normal.
Now, there are other reports in which 2.4-D, and 2,4,5-T are alleged to have
caused toxic effects on the nervous system as measured by the electroencephalogram. That is after ingt'stlon, there was &amp; desynchronization of the electrical activities of the nervous system, I bring these points up only to reinforce the fact that no chemical is completely innocuous. Some individuals are
more sensitive than others, and some may require a big dose, and some a
small dose to have these abnormal effects produced, but I share with Dr.
Martin the view that when jieople appear and say that they have been
adversely affected by these chemicals, immediate and adequate attention
should be given to the possibility that these reports will furnish yet additional
data to supplement the rather large amount of scientific data already existing.
Congressman MCCARTHY. Thank you. Dr. Galston. I wonder if you could—
give us your observations after your inspection of the sprayed area, and the
area where it drifted.
Is there anything that you at this point care to have in the record?
Dr. GAUSTOX. Well. I'll say a few words. I want to make it perfectly clear
that after 24 hours In Globe, Ariz., I don't want to pose as an expert either on
the program, or the effects on vegetation, or on people, but as.a biologist working in this area, thure. is some conclusions I think I can make which point out
the need for still further investigation, and everything I say should be held In
that light.
What did I see on my brief trip yesterday? Well, I would classify them in
several categories.
Number 1, at the helispot. overlooking the picnic area, I observed and
smelled residues, there was no doubt that you could smell residual diescl oil
which was primarily the carrier for the herbicide which had been splashed
during the loading operation onto the helicopter.
Now, if you could smell It, there was a good deal around, and that would
Indicate that there are definitely residues in certain selected areas, how much
there was I can't say, how much there might be in the soil, or in the water, I
cannot say, but It seems to me that I could smell evidences at various points
In my trip. So that there probably are residues here and there, mid those
could serve as a continuous supply of leaching. I suppose, info t!i&lt;? wntors of
the area, one should not discount that possibility.
The second category was definite plant damage, and the plant damage was
both the desired plant damage in the canyon, and undeslred plant damage in
the vicinity of homes, which was due to the drifting. I assume, the herbicide.
In the canyons we could see, ;md these wen- pointed out to me by some of
our Forestry friends who were with mo, the deslr»"l killinj,' of such'plants its

�151
Mnnzanita and Oak, and the desired persistence of what they considered more
desirable plants such as gerardia.
Now, I suppose a question could be raised as some of the local residents
have been raising undesirable, and desirable, according to whose criteria, and
l,y what Judgmental values. Manzanita and Oak do live on these hillsides, they
do transpire to water, and I suppose their killing is desini'tle in the contention
of wanting to avoid the evaporation of water. Whether after you are all
through with the operation and plant to grass, which is lite stated objective of
tliis clearing observation, ,v»u ure going to save very much water, I'm not sure,
and whether, in fact, the esthetics of the environment will be improved
another stated objective of this operation Is also I'd say open to question, I
would think it would be a very useful operation for those groups charged with
making policy to hold some public hearings at which citizens could come with
their points of view. I think a lot of this fracas is due to poor interchange of
information between official agencies, and the citizens. If there had been open
honrings, and announcements, this Is what we intend to do, this is why we are
doing it, and this is how we are going to do it, and have objections recorded
at the time, a lot of. the acrimony that's built up here might have been
avoided.
Now, so fur as the .damage of plants around homes, there la no doubt about
it, it lias occurred. I have seen it, and as a plant physiologist, I could testify
that this is typical damage due to herbicide drift. I think that this points up
:i lesson when you discharge herbicides from the nozzles of spray on a helicopter, you are getting an assortment of droplet sizes, the big drops are going to
fall quickly, the small drops are going to be carried for longer distances. I
think until the technology is Improved, the so-called invert sprays is one possibility here, and new types of booms for spraying are another, it seems to me
that* it's very unwise to spray In areas where homes are so intimately associated with the forest and woodland, that you are trying to control. You cannot
pinpoint the spray, you cannot keep It out of the water, and you cannot prevent Inadvertent spray damage to the nearby residences, and I would say that
there arc certainty many sprays in the country where the application of aerosol sprays is a highly beneficial practice.
From my cursory look here that I would say the intervening of house and
the canyons in which spraying Is desired, is so intricate that the .slightest miscalculation, the slightest air movement, the slightest malfunctions of the spray
equipment would lead to damage to the property, and I don't know how that
could be worked out technically, and I would want assurance that those problems are looked into.
I think the people whose plants have been damaged ought to be compensated
in some way because the damage has been considerable around some homes,
and I think it's unfair to expect these people to bear the brunt of this kind of
inadvertent drift operation.
Now, I did see damaged animals, and I talked with humans who alleged
that they were adversely affected.
All I can say here is the damage is there, and spray operations did occur,
hut I know of absolutely no scientific evidence which would link the spray
o|&gt;eration to the damage, and I think the people who showed me the damaged
animals showed it to me in the spirit that this could be a consequence of
spray operations, but they weren't sure, and certainly I'm not sure, but unlike
some people I would not immediately offhand say this Is ridiculous. It could be
as I have shown from my previous reading from this scientific compendium,
and I could document further a lot of the symptoms that people are reporting
here have been reported for massive doses of 2,4-D. So we should not leave the
possibility that this did occur, but a much more scientific information is
required.
My overall view after one day of looking around is one of puzzlement. I
wonder why it's desired to initiate this kind of an operation in this kind of an
environment. The stated objective is to improve water runoff, and water runoff
will benefit, I presume, the citizens of a nearby urban area, Phoenix, which is
growing rapidly, and which has a lot of water requirements, and their water

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�152
requirements will grow as the years go by. We know this is an arid area—by
the way, not being an Arizona resident, and not being a politician, I perhaps
could say some things here which a lot of people were thinking, but haven't
brought forth.
Truly, water is going to be wilting in this area for others. So far as I can
see unless nuclear technicology makes it available on a massive scale, which I
don't foresee, if you take water from this area to give to another area, you
are, in fact, robbing Peter to pay Paul. If you are robbing water from here,
you are going to partially change the kind of vegetation, perhaps you are
going to denude S":ne of the areas in order to increase the runoff, this involves
a. comparative set of rules. Whose object is going to be gored here, whose
Interests are paramount? Well, clearly cities are not going to be able to grow
indelinltely, we are going to have to put some limit on them, we know, for
example, that the city of Los Angeles got into a lot of trouble with smoke
because there are just too many people there. In the same way cities in the
Southwest may have to limit their size ultimately based on the number of
jieonle they can support on the amount of water resources there are. The
try in &gt;! to t;ike evt-ry amount of water out of the Country brings a possibility
of .-i very serious question.
Now that President Nixon among others Is calling for a campaign to restore
the environment, it might be that we would want to look at this whole project
in the context of what we are doing to the entire State, and to the entire
countryside.
Finally, I would like to merely renew my suggestions that the people who
formulated this policy, who set up this whole, spray program should identify
themselves, and should request the contributions of the citizenry as an input
to this whole program.
1 think that policy should not be made without question. This is a democratic society in which citizens have responsibility to Interest themselves In
the niiikinit of policy, and—my faith in the American people, and in their
&lt;!&lt;•&gt;! re to run tlieir own country has been to a certain extent reinforced by
scfi-r.' a group of amused citizens here out to protect their rights.
T,i;i?ii; you very much.

r..:ii:!'".--si!!:in MCCARTHY. Thank you, Doctor Galston. I think the points you
i:.:ii;c ;ir&lt;- valid. One that I would just enlarge on a hit Is that I am presently
wnrKiii:: on legislation to be established to support a National Growth Policy,'l
vl:!n.; j-Tiiwth has to he commensurate with the resources and of course, in this
&lt;•,;-•:•. w-iler is a critical resource.
! -"..uli.! conclude these hearings now with a couple of observations. I think
it's important to know that 2,4,5-T was developed at the Army's chief Germ
Warfare Research Center at Fort Detrick, Md. My experiences in investigate
th&lt;- Army's chemical and biological warfare programs, and policies, has not
&lt;'!:• ourased me about some of the actions that have been taken, without taking
Into consideration some of the unforeseen consequences. For instance, when
they wanted to dispose of waste from nerve gas production at the Rocky
Mountain arsenal near Denver, they first dumped this material into ponds on
the arsenal's property. They didn't expect that it would find Its way out They
thought it would !&gt;P just absorped in the water on the pond. It wasn't, it was
carried out into adjacent streams, and the neighboring countryside, and killed
among other things livestock and 6 square miles of sugar beets.
They then dug a deep well and figured the best way to dispose of it was by
dumping it deep into the earth. That set off 1,500 earthquakes in the Denver
area, some of them up to six on the Richter scale, and caused great alarm in
the community. They finally had to pull out this material, and of course the
earthquakes stopped.
'
Then, they thought they should ship it across the entire United States. They |
thoueht this would be safe. Scientists later said it would risk the lives of !
thousands of people, the plans also called for dumping this large quantity of !
nerve sas nml other materials into the Atlantic Ocean. They thought that
would be safe.
Scientists later said it could destroy all marine life in 600 cubic miles of tho
Atlantic Ocean, with a cataclysmic effect on ocean's production cycle.

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153
Now, I cite these instances not in reproaching the Army, or the C.B.W.
establishment, but I think that this particular program has a questionable
record*
We find 2,4,5-T developed by the Army's Germ and Gas Warfare establishment, 25 years ago to this date. We do not know for sure whether it will produce birth defects in human beings, I find it unwise to say the least to use
such a substance without being sure that it is safe. For some reason the
burden of proof seems to be on me and my colleagues in the sense that the
attitude is, "we'll keep using it until you can prove it unsafe." Well, I quarrel
with the basic assumption, I think that it should be just the reverse, I don't
think that any toxic substance whether herbicide, pesticide, drug, whatever,
should be used, sold in the United States until it can be shown that it is not
harmful to human beings, that it doesn't produce cancer, or birth defects, or
genetic effects.
One would think that we have learned from the Thalidomide experience, but
apparently we haven't
I also find it incredible that the Dow Chemical Corp. could have succeeded
in helping reverse an order from The White House.
Now, I read this section from the statement of October 20 wherein the President's science adviser said that certain agencies of Government, the Department of Defense, the Department of Interior, the Department of Agriculture
would do certain things, will inaugurate a new policy. Now we have the letter
received today from The White House addressed to rue, advising me that TutWhite House is backing off from this directive, and is saying that the statutory responsibility resides with the individual agencies.
I* find it personally unconscionable that in light of the Bionetics findings,
and the scientific data cited by Doctor Galston this morning about the proven
effects of 2,4,5-T on females, that this substance would be continued to be used
&lt;ni wide scale in the United States, and for that matter in Vietnam where
i-ven larger quantities are used.
I welcome the U.S. Senate Subcommittee on Investigation into this. I will
invparc a full report which will appear In the public documents that will be
&lt;l&gt;-vi;lo|K&gt;d as a consequence of our trip will be made available to not only the
Senate Commerce Committee, but appropriate other committees of the Congress, as well as to the study of the American Association for the Advancement of Science under the directorship of Professor Messelsoii of Harvard.
We finally conclude by thanking the officials who have been most uel;&gt;ful.
and to the residents of Globe who have been mos-t hospitable, and I would
hojie that this experience here might have effects far more reaching th.in tin.small area of Globe, Ariz., and that perhaps as a result at least in part of
what we have discovered here, that we will stop using 2,4,5-T nround tinworld until we can run a series of tests that show that it is not harmful to
tliis generation, and to the next generation.
Thank you very much.
Appendix 6
ALBUQUERQUE, X. MEX., February S6, Wi&lt;),
Hon. RICHARD D. MCCAKTHY,
Jloune of Kci&gt;re*entt.tticc«,
Wnaliington, D.C.
DEAR MR. MCCARTHY: Thank you for your letter of February 10 and fr.r the
opportunity to furnish additional documents or .statements for the record of
your hearing In Globe.
FOB THE RECORD REGARDING WINDS

In my testimony I promised to furnish you with additional data on windspeeds during the 1009 spray project. While wimlspeed was mensural 1-y tinProject Air Officer who used a pocket anemometer, no record of observations
was made. He did, however, maintain a record of application flight tiuivs

�T

K.

154
which sliows when the work was shut down due to winds exceeding 10 miles
per hour. The following table summarizes these important times from this
record:
Time

Date

Remarks

1505 Shutdown (wind exceeds 10 m.p.h.).
1703 Resume operations (wind below maximum).
1935 End operation for day.
1018 Shutdown (wind exceeds 10 m.p.h.).
End operation for day.
1115
Do.
1250
Do.

JuneS, 1969..
June 8,1969...
J u n e S . 1969...
June9.1989...
June 10,19S9.
June! 1,1969

Because allegations of "sale winds'1 during application have lieen made, it is
of intctvst to compare the above shut-down times with winds recorded at the
Ololie Fire Weather Station. The Globe Station records are for observations
made only once daily at 1300 hours, but do not indicate the presence of "gale
winds" on any day of the project. These 1300 hours observations are as follows:
Date
June 8
June9
June 10
June 11

Direction
_ . . . . ,
-

—.

;

-

SW

SW
W
SW

Speed (m.p.h.)

5
16
U
16

As can be seen from the two tables, the only day on which applications
extended beyond 1300 hours was June 8, when the 1300 hours observation was
only 5 miles per hour. The June 11 shut-down time of 1250 hours would tend
to infer that winds did possibly exceed 10 miles per hour when compared with
the 1300 hours observation of 16 miles per hour. Ranger Mochn has stated
that winds did not exceed 10 miles per hour in the area of the spray application, and this is quite possible since spray work was high up in Russell Gulch,
In the lee of sheltering mountains to the Southwest, on that date.
OTHER ITEMS FOB THE RECORD

Additional copies of the Forest Service Interim Position Statement and of
the map showing the limit of infrared detection of dead and distressed vegetation (as of October 1969) are enclosed for the record.
As I recall. Professor Galston asked for additional information on the 3-Bar
research studies related to water yield. Since the Interim Position Statement
digests these, I suggest that the Statement will serve for the record, but would
be glad to arrange for you or for Dr. Galston to receive a copy of the rough
draft of the manuscript referenced in the Statement.
Since the herbicide container converted to a trash barrel, and found in Kellner Canyon during your field tour, became a matter of importance to the
press, the following additional information may serve as a useful insertion for
the record: (1) The Dow Chemical Company label does not specify that the
container be destroyed (copy of specimen label enclosed); (2) As a matter of
good practice, we prefer that all pesticide containers not be reused, and when
it was found that trash barrels were being made of the containers by the
Globe District, the Regional Forester directed by memorandum on January 29
that all Southwestern Region Ranger Districts discontinue such uses;'(3)
Ranger Moehn, in response to the Regional Forester's direction, had all such
trash barrels picked up earlier in the week of your visit; (4) presence of the
container in the creek at the Kellner recreation area cannot be explained by
District personnel who were in the area and had not seen it prior to your fluid
tour; (5) the container had been washed with water and detergent prior to
painting for use as a trash barrel.

�-f.

155
Also on your field tour, there seemed to be some misunderstanding regarding
application of herbicide to the live stream in Kellner Canyon. While the
stream was (lowing when you were in the area, it was not a lire stream at the
point visited nt the time of application. We do not deny that some herbicide
may have drifted to live streams, as evidenced by some tip damage to trees in
the Kellner Recreation Area where there was a live stream, but that drift
actually reached the water has not been established.
While the Interdepartmental Panel of Scientists headed by Dr. Fred H.
Tschirley arrived following your hearing, their findings are of sufficient importance to the matter under consideration, that we desire to have the enclosed
press release issued by them inserted in the record.
It was a pleasure working with you and Mr. Riddleberger during your visit,
(f the Forest Service can be of any further assistance, please let us know. We
\vlll appreciate receiving three copies of the hearing record when available.
Sincerely,
JOHN M. PIEKOVICH,
Assistant Regional Forester.

(J.36Z 0 - 7 0 - 1 1

�V

t

156

FOREST ssRViC'-: iKTiaRiK POSITION:
KUS32LL GUM: II^RSICIDJ: SPKAY PROJECT AI:D
REGION CKAPARKAL PROGRAM, February 9, 19YO

jg.C:-grour&gt;d 0:1 Kellner Canyon-Russell "ulch Project
The Kellner Canyon-Russell Gulch Project is a part of the Chaparral
Manaeement Program of the Tonto National Forest. The prisary object! YS
of this project is to improve water yield, but other profraa objectives
and resulting benefits are inttnjed to ce rest as well. Improved
v;ater yield and other Chaparral Program objectives are discussed below.
This projec- was initiated in 1965 following extensive local discussions
and a press relccss vhicLi appeared in the local papor. Kather than
the uoual practice of applyinr; pros -^ri coil fire us the initial treatment, her'idciuos ware ucsd. This was because of the known tendency
for strsa:.-.s In t,':-.is area to pro«uc2 flash floods; herbicide treatment was considered to b-3 unlikely to contribute to flooding, whereas
lar;,e areas trea^ed by fire could.
Chemicals used in this project are listed by year of use in Tablt 1,
which is appsnded. These r.re all Federally Registered Compounds
and were applied in '.;eepin2 with the laws and label instructions
governing their saf2 use.
Following the 1969 Application of Harbicide, Tonto Forest Supervisor
Robert Courtney received a complaint in the form of a petition
bearins 15^ signatures of people in and near Globe, Arizona. Following
the initial complaint, Courtney requested a team of qualified individual;
to visit tho area for a general assessment of alleged herbicide
damage. This team reported sose limited damage to vegetation on
certain private properties.
Chaparral Mana.':eraent Objectives •
Objectives of managing chaparral on the Southwestern National Forests
are to:
1. Improve water quality and yield throurjh reductions of the
pCitorAial for snoir.-jntaiiori follovinr; vilflfire and through
r'.-O-'j-.lc/r.r, : - ov'i:.o--.ra.'.srir?.-,iir. Icsios v'r.sr* r.o-;.C.C::a^ior.
..
.•; ;". -.•.-. ^r.v:.%.rri_ zvr.-i -.r.rv;-;.-.
'

r&amp;r.r-i fro:.-. si\-&amp;r^.-.-U~s ;;r=.53 tr.i isr. c-rss-s xs r.=--v;- rejro
chaparral, to relic stands of nature chaparral.

I

�157
3. To Improve vllalifa habitat through creation of additional
e&amp;i'.e effect and through rr.aintenanco of vi^or and new growth
in desira'ole apacios.
I*. To reduce the hi^h costs of protecting cliaparral from wildfires
through the establishment of breads in heavy fuel continuit;-,
ma!:iriG it more poosible to avert fires of conflagration proportions.
5. To increase forarjo production for wildlife and livestock
through the release of native grasses and the establishment •
of new grass stands.
6. To improve access for both the obssrvcr of wildlife and the
hunter through a system of near-primitive roads to strategic
fire; control locations and through the openings that will
result in treated areas.
It is intended that each of the above objectives will be mat through
Multiple Use Coordination Procedures. These require that regardless
of the pri;.*iry purpose oi' any project, proper consideration V&lt;e ^iven
to other forest uses and values. Because of the intense interest in
i.n:provins Southwestern water quality and yield, both Federal watershed
Management and cooperator funds have been ratde available for this wori:
as a primary purpose. Each of the objectives of chaparral management
is fairly well unacrstooa sy the interested public except for this one
of improvement in water yield. Even sorr.e exports have, until recently,
discounted the potential for aupnentin'j water supplies through alteration
of shrub cover in the chaparral type.
Much of the research leading to improved understanding of the potential
for additional water has Ix-cn done on the 3-Ear Experimental. Watersheds
near Roosevelt Dan on the Ton to National Forest, Work there was be^un
in 1956. Two reports from this work are of particular interest.
Pase, C.P., and P. A. Incebo, 1965, "Burned chaparral to crass:
early effects on water and sedircent yields from two granitic
soil watersheds in Arizona," Proceedings Ninth Annual Arizona
Watershed S"nposiun, It pp illuo.
Hibbert, Alden R., Unpublished 1970 l-.'anuscript on file with
Rocky Mountain Forest and Ranee Experiment Station: "Increases
in strcaitjflow vary with rainfall after converting brush to
?r.i latter report is cited because it contains data not previously
available which are regarded as more reliable (due to additional years
.-:' streamflow ir.casuro:::2nt) and which indicate greater proiiise of
• -roved water yields than previously e::pectcd. Increases due to
.-./.orshed treatment have varied fro;u 1.5 area inches to lU.O area
--;-.;s. The two test watersheds averuced an increase in water yield,
'.-r *.hj period 1959 through 1969, of from U to 6 area inches.

�f.

158

Pro.'-ross and Direction of Studies — The Kallnar Canyon-Russell Gulch Proje
Tas.: Force; Ho. 1 ancl Ho. 2 (Cor^leted '.o!.
•'r')
Tne first two -loans to e::anine the area were concerned with visually
detectable effects of the 1909 herbicide application. Due to tha
similarity of soao insect and dssease symptoms to syi:;ptor.is of herbicide
effects, the second team included specialists in cntor.olo^,' and plant
patholo;;.' . It was on the basis of this team's findings that many
plants allayed to be daia^ed from herbicide drift were determined to
be affected ': other causes.
.y
It should be noted that while all complainants have been advised of
Forest Service clais-for-daKa^e procedures, only one formal claim has
been filed. T'.is dais was not for properties identified as damaged
in the TasU Force ilo. 'd Report, and has thus been disallowed.
Infrared. Photograph:- and Interpretation for
DistrjMad Va :;e jail on \'.Jofl; in Frorrass)
While the second Tas:: Force reported that some visually detectable
herbicide drift hr.d occurrsd frovr. the 19 S9 spray project, extending
approximately one-fourth r:.ile north of the project, their assessment
did not include previous years' effects, nor was it concerned with
delineation of tha sprayed area as a whole.
In order to nore accurately define tha limits of herbicide effect on
plants froa all years of sprayin;;, aerial infrared photography has
been employed. Interpretation of these aerial photo.jraphs has r.ade
possible a preliminary delineation of the exterior boundary of destressed
and dead vegetation. Doth the visually defected drift line reported
by Taslc Force No. 2 and the External limit of Infrared-detected
dintressf-d and dead ve-otation are shown on the appended PICIJj&gt;vnJ.ARY
ftp.p. It is important to note that internal exclusions have not been
delineated and that field verifications are not yet completed for
the infrared interpretation .
Enviror.nontp.1 Effects (v/6rU in Progress)
V7ori; is underlay in this stud;: to assess the total effect of the
Kellner Canyon-Russell Gulch Project on the environment . Sor.e of
the key considerations included in this st^dy are listed below,
1. Possible furth-.-r evidence of drift of herbicide spr.T-s
_
thrcu ii 3UJ:. '.vjr '.•icJ.cio r.!s:L:'.U':s a3 are s.rxziv'z i;'. JOll
s_a:.:plo3 :'.o:-..; o^'
..''O'{^ faroa. Initial soil oa-.plin;;
was within
projec-c ana on two transects toward the

�159

northeast corner of the project. This corner was selected
as the best to test the hypothesis that soil residues from
drift mir;ht bo found, since prevailing winds are from the
Southwest.
Initial laboratory analysis reports have indicated low
concentrations of Silvex and 2, U-D at sons locations
(maxittua detected concentration off the project to date is
0.16 p.p.m. Silvc::). Especially at these low levels
of concentration, it is possible that other sources of
contamination nay induce "backcrour.d" which could lead to
erroneous conclusions. . For this reason, we are proceeding
to cross-check analysis procedures while, at the sane time,
widespread sampling north of the project is scheduled.
It would be premature to reach any conclusion regarding
drift at this tine.
2. Herbicide levsls in water samples. Water sampling and
analyses have besn underway for soae tine. Project methods
called for intsrruption of application at all stream channel
crossings, and as far as we have been aole to determine,
no herbicide was applied directly 'io water. Some soilleachine and runoff is to be expected. All samples we have
taken, or ta!:en by private individuals and brought to our
attention, are less than the Federal water quality criterion
of 0.1 p.p.m. I/
3. Effect of Treatment on Esthetics. While it is evident the
dead vecieta'&amp;ion over this area is not pleasinj, our concern
here is with the ne::t needed steps to actually provide
enhancement of the scenic resource. It is sometimes necessary
to tolerate temporary degradation of the appearance of an
area as a cost of ultimate improvement. This study is
intended to better define tolerable limits, explore alternatives, and recommend treatments to completion. Concurrently,
we are assessing the past, present, and projected fire
hazard in order to build conflagration'control concepts
into the landscape design.
1». Effects on Animals and Plants. Initial observations by
wildlife experts have shown no narked effect upon wildlife.

Surface water criteria for public water supplies table appearing in:
V.'ater Quality Criteria issued as a report to the Secretary of
Interior, April 1, lJo-3, and published by tho Federal Water
Pollution Control Administration.

�160

On the other hand, repeated clair.s have attributed varied
maladies of hurnnns and animals to the project's herbicide
sprays. Iiackin1; private nodical histories or other solid
bases for evaluation, we believe it more sound to rely on
published results of laboratory tests. These are to be
used in determining expected effects on aninals for rotes
of application used. Yet to be published laboratory
results are needed to complete tnis otudy as it relates to
animals.
A further consideration of this study is that for proper
perspective, all of the environmental influences on the area
tmst be weighed. Two examples help to brine this ns°d to
focus. One is the frequent presence of suoke fro;-.i nearby
sir.oltoriro operations, especially when an inversion and
northwest winds combine to produce a thicl: accumulation in
tlio '. asin north of the Piv.al Mountains. The other is
household and iniuotr-ial uses of herbicides which may
have Induced additional residues into the affected area.
While neither -ho effect of possible air pollution in the
area nor tbs possible contamination by other herbicide uses
ara known, their importance as suspect environmental effects
cannot be discounted.
FOREST S£R'/I_g^ P03ITIQ:j
We share deeply the concern of the people in this area with their
environment. The Forest Service has no intention of persuins a course
which will adversely ai'fcct the health and safety of its Kational
Forest neighbors, nor which will porranently detract from the scenic
or other qualities of the Forests.
It is our position that ths studies we have underway, as well as
the outcome of public !:;oetincs concerned with herbicides and with
the overall conduct of the chaparral program, must dsterraine the
ultimate decision on dofsrir.ent. For this reason, we believe it
would be prenaturs to state at this tine either when the deferment
coy je lifted, or vrhat new juiaelir.es will be followed.
It is our further position that it would be unwise to base decisions
on the future use of the herbicides employed, solely upon alleged or
suspected effects in th3 vicinity of the Kellner Canyon-Kussell Gulch
Project. There are tsany environmental influences operating in this
ar^a which must be better understood. Also, many of the questions
raised about these chemical cor;.pou;xis can i,-e resolved only through
carefully controileJ laborator.. exporimento.

�161

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�-f.

163

PRESS RELEASE - February 20, 1970
Government Interdepartmental Panel of Scientist!

The panel i« carefully examining the evidence collected during
it* visit. The study vill continue and vill include analyse* of
the numerous samples of blood, soil, vater, fruit and plants for
the herbicides, a possible contaminant (dioxln), as veil as various
agent* producing disease in man, animals and plant*. Kovever, to date,
v* can summarize a fev of our findings as follows:
1. The application of herbicides in the Final Mountains near
Globe, Arizona vas made by the Tonto National Forest starting in
196$. The most recent application of the herbicide vas .made by
helicopter on June 6, 9, 10 and 11, 1969.
2. The materials used in the treatments in 1965, 1966, 1968 and
1969 included 2.U-D, 2,1»,5-T, and silvex. These chemical* came
from different sources. In 1969, 30 gallons of 2,1»,5-T produced by
the Hercules Chemical Company and 935 gallons of silvex produced by
the Dov Chemical Company vere used. The silvex is reported by Dov
Chemical Company to contain less than 1 ppm of the dioxin. Analyses
vill be made of silvex and the other herbicides for dioxin and the
active herbicide ingredients.

�V

K.

164

3. There are reports of the aircraft flying over private properties
but not spraying; and other reports of the herbicide being applied
Just outside the project area. There is clear evidence of drift of
the herbicides on a number of plants on some of the nearby properties.
k. Human illnesses have been reported by several residents in the
Globe region. Many of the residents vith complaints vere interrieved
by a medical member of the panel. These are complaints that commonly
occur in the normal population; the eye irritation in one Individual
may be related to the spraying. Nine doctors serving the area of
Clobe vere interrieved and there vas general agreement that there
had been no significant increase in human illness related to the
spraying. Eovever, blood samples vere obtained and additional
studies are planned to verify or rule out this possibility.
5. Reports from the vildlife specialists indicate no significant
effects on birds, deer, and other vildlife. There are reports of
reductions of birds on a fev properties but there are other reports
that bird and other vildlife populations in and near the project area
are normal.
6. Information obtained from owners of livestock and observations
of animals did not indicate any illnesses that do not commonly occur
in other regions. It is doubtful that the spraying of the herbicides
or dloxin caused the afflictions in the goat and duck because the
goat vas born before the treatment and the duck vas batched about k
•lies avay from the treated area.

�1
"

s.

165

T. There vas evidence of voody plant mortality from root rot,
and also viaible damage to certain yard trees from several kinds
of Insects and voodpeckers or sapsucfcers. Other plant Injuries
vere observed that appeared to be caused by lov soil moisture,
air pollution and unusual soil properties.
8. The phenoxy herbicides folloving normal use dd not usually
persist for more than 8 months in soil and vater. Additional
analyses are la progress to determine the presence or absence of
herbicides.'

Senator HART. We are adjourned to resume on the 15th of this
month in this room.
(Whereupon, at 5:15 p.m., the Subcommittee was adjourned, to
resume on April 15,1970.)

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                  <text>Alvin L. Young Collection on Agent Orange</text>
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                  <text>&lt;p style="margin-top: -1em; line-height: 1.2em;"&gt;The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.&lt;/p&gt;&#13;
&lt;p&gt;For more about this collection, &lt;a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a"&gt;view the Agent Orange Exhibit.&lt;/a&gt;&lt;/p&gt;</text>
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                <text>Westing, Arthur H.</text>
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                <text>Hearings Before the Subcommittee on Energy, Natural Resources, and the Environment of the Committee on Commerce; United States Senate, Ninety-First Congress, Second Session on Effects of 2,4,5-T on Man and the Environment</text>
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                <text>Statement of Dr. Arthur H. Westing, Chairman, Biology Department, Windham College, Putney, VT</text>
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        <name>ao_seriesIII</name>
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