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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;
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                    <text>Item D Number

05459

D Not Scanned

Author
Corporate Author

^.S. Department of Health and Human Services, Public

RBpOrt/ArtlClB TltlB

2 3 78

&gt; &gt; ' -Tetrachlorodibenzo-p-dioxin (TCDD, "Dioxin)

Journal/Book Title
Year

1984

Month/Day

January 23

Color

D

Number of Images

25

Descrlpton Notes

DHHS (NIOSH) publication NO. 84

Friday, March 15, 2002

Page 5459 of 5571

�January 23,1984

2,3,7,8-Tetrachlorodibenzo-p-dioxin
D,''dtoxin'')

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Public Health Service
Centers for Disease Control
National Institute for Occupational Safety and Health

�DISCLAIMER

Mention of the name of any company or product
does, not
constitute
endorsement . by
the
National Institute for Occupational Safety and
Health. •
. ,
v
- -

DHHS (NIOSH) Publication No. 84-104

�FOREWORD

Current Intelligence Bulletins are reports issued by the National Institute
for Occupational Safety and Health (NIOSH), Centers for Disease Control,
Atlanta, Georgia, for the purpose of disseminating new
scientific
information about occupational hazards. A Current Intelligence Bulletin may
draw attention to a hazard previously unrecognized or may report new data
suggesting that a known hazard is either more or less dangerous than was
previously thought.
Current Intelligence Bulletins are prepared by the staff of the Division of
Standards Development and Technology Transfer, NIOSH, (Robert A. Taft
Laboratories, 4676 Columbia Parkway, Cincinnati, Ohio, 45226) and are
distributed to representatives of organized labor, industry, public health
agencies, academic institutions, and public interest groups as well as to
those federal agencies, such as the Department of Labor, which have
responsibilities for protecting the health of workers. It is our intention
that anyone with the need to know should have ready access to the
information contained in these documents; we welcome suggestions concerning
their content, style, and distribution.
•

Because
of
the
recent
attention
given
to
human
exposure
to
2,3,7,8-tetrachlorodibenzo-£-dioxin V (TCDD, "dioxin") contaminated materials
and published reports on the toxicity x of TCDD, NIOSH staff consider
it
necessary to present a review of thex pertinent data and a summary of
findings related to the human hazard potential of TCDD. Because of the
compression in this bulletin of the voluminous literature on TCDD, it is
suggested that readers wanting to know more of the details of the reported
studies consult the appended references.

y Donald Millar, M.D., D.T.P.H. (Lond.)
Assistant Surgeon General
Director, National Institute for
.Occupational Safety and Health
Centers for Disease Control

�CURRENT INTELLIGENCE BULLETIN *40 -

2,3,7,8-Te trachlorodibeazo-£-dioxin
(TCDD, "DIOXIN")

January 23, 1984

ABSTRACT
In animals, 2,3,7,8-tetrachlorodibenzo-p_-dioxin (TCDD, "dioxin") causes
various systemic e f f e c t s at a wide range of exposure concentrations,
including
tumorigenesis,
itnmunological dysfunction, and teratogenesis.
•Studies of humans exposed to TCDD-contaminated materials suggest that TCDD
is the cause of observed chloracne, metabolic disorders (porphyria), and
other systemic problems and are suggestive of TCDD's ability to cause cancer.
TCDD occurs as a contaminant of materials such as 2,4,5-trichlorophenol
(TCP),
2,4,5-trichlorophenoxyacetic
acid
(2,4,5-T),
and
2-(2,4,5-trichlorophenoxy)propionic acid, (silvex).
Occupational exposure
may occur through contact with these materials during use or from the past
contamination of worksites. •
The National Institute for Occupational Safety and Health (NIOSH) recommends
that TCDD be regarded as a potential occupational carcinogen,
that
occupational exposure to TCDD be controlled to. the fullest extent feasible,
and that decontamination measures be used for TCDD-contaminated work
environments. This recommendation is based on a number of reliable studies
demonstrating TCDD carcinogenic!ty in rats and mice.
BACKGROUND
Physical
(TCDD)

and

Chemical

Properties

of

2,3,7,8-Tetrachlorodibenzo-p-dioxin

TCDD is one of a family of isomers known chemically as dibenzo-p_-dioxins.
The chemical and p h y s i c a l p r o p e r t i e s are s u m m a r i z e d in Table I.. TCDD is a
colorless crystalline solid at room temperature. It is sparingly soluble in
most organic solvents and essentially insoluble in w a t e r . TCDD is stable to
heat, a c i d s , and alkali and w i l l decompose when exposed to u l t r a v i o l e t
light, including sunlight [1].

�TABLE I

CHEMICAL AND PHYSICAL PROPERTIES OF TCDD [2,3]

CAS Registry No.:

1746-01-6

Empirical formula
Percent by weight

C
0
H
Cl

44.7
9.95
1.25
44.1

Molecular weight

322

Vapor Pressure mm Hg at 25 C C

1.7 X 10"6

Melting point, °C

305

Decomposition temperature,\*C
Solubilities, g/liter ;
. o-Dichlorobenzene "
.
"'" Chlorobenzene.
Benzene
-.
•
Chloroform
n-Octanol
Methanol
• "
Acetone
Water

. &gt;700
:

;.

."
.
- '"'
.

«4
0.72"
0.57
0.37
0.05
- 0.01
0.11
2 X 10'7

Formation and Use of TCDD
TCDD forms as a stable by-product or contaminant during the production of
TCP.
Run-away reactions at high temperature, in which excess TCDD was
produced, have occurred at TCP production sites in the United States and
elsewhere [4].
Normally, TCDD persists as a contaminant in TCP in
relatively small, variable amounts (0.07-6.2 mg/kg) [5].
TCP has been
utilized primarily as a feedstock for production of the phenoxy herbicides
2,4,5-T and silvex, resulting in the contamination of these products with
TCDD.
Production of 2,4,5-T and silvex ceased in the United States in
1979.
However, stockpiles of both products are still being distributed and

�used. TCP also is used in the production of hexachlorophene, a bactericide
and fungicide.
.
..
'
The combustion of 2,4,5-T can result in its conversion to small" amounts
( . ppt TCDD/1 ppm .2,4,5-T burned) of TCDD. Also, the burning or heating
06
of commercial and purified chlorophenates and pyrolysis of polyehlorlnated
biphenyls (PCBs) contaminated with trichlorobenzenes have resulted in the
production of TCDD [6,7]. The formation of TCDD from trace chemical
reactions in fires has been postulated but has not been verified [8,9].
Existing Regulations and Guides
No occupational exposure .standard exists for TCDD. The United States
Environmental Protection Agency (U.S. EPA) temporarily suspended or banned
most uses of 2,4,5-T and silvex in 1979, although their use was allowed on
sugarcane, orchards and for miscellaneous non-crop uses [10], On October
18, 1983 EPA published its intent to cancel registration of pesticide
products containing 2,4,5-T and silvex and to prohibit the transfer,
distribution, sale or importation of any unregistered pesticide product
containing 2,4,5-T or silvex or their derivatives [11].
Nature of Occupational Exposure to TCDD

s

It is not possible to estimate accurately the number of U.S. workers
currently at risk of exposure to TCDD. Occupational exposure to TCDD may
occur during production of TCP; in decontamination of worksites from prior
production or. use of TCP, 2,4,5-T, or silvex; from waste materials (such as
reclaimed oil) contaminated with TCDD; or from cleanup after fires in
transformers containing polychlorinated aroma tics.
Dust or soil particles contaminated with TCDD can remain airborne or
accumulate on indoor or outdoor work surfaces and may present a potential
exposure hazard. Exposure to TCDD as a vapor will normally be negligible
because of its low vapor pressure. Contact with TCDD-contaminated liquids
is possible through the handling of drums or tanks containing the liquid or
through dispersion of the liquid.

�TOXICITY .- . -

•-•: - '•,

•:.-,,;. :,&gt;,:• ••-...;:

Results of Studies of TCPD in Animals

--:"';

Acute and Chronic Toxicity '••'•
There Is wide variation in the dosage of TCDD required to cause death among
animal
species
(oral LD^Q
0.6-5,000 jig TCDD/kg body weight (bw))
[12,13], Progressive weight loss with death several weeks later is reported
to characterize the response in experimental animals after administration of
a, lethal dosage of TCDD [12,14,15]. Animals given single or repeated oral
dosages of TCDD of 0.1 to 25 ug/kg bw demonstrated increased liver weights
and lipid accumulation, thymic atrophy, and histopathological changes in
liver and thymus [12,16-18].
'•'-'•..
TCDD is reported to be at least three times more potent than any other known
compound in stimulating production of aminolevulinic acid synthetase (ALA),
the rate-limiting enzyme in porphyrin and heme synthesis [19,20]. Varied
effects on hematological functions have been reported in rats and mice dosed
with TCDD:
increased numbers of erythrocytes and leucocytes, increased
hemoglobin concentration,- decreased blood platelets in rats [21,22].,- and
decreased hemoglobin concentration in mice [23],

TCDD "administered - at dosages ' of :0.125-3. D u g "TCDD/g*. bw to mice 'and ' rats
induced fetotoxicity that 'included cleft 'pal* tes ;"*tid" kidney" anomalies
[24-26], intestinal hemorrhages ' and excessive tissue/organ fluid (edema),
and prenatal mortality [27,28]. • :-"
' •'•"'
Impairment of reproduction has been reported for rats "ingesting 0.01 ng
TCDD/kg bw/day.
Significant/'decreased fertility, litter size, number of
pups alive at birth, postnatal survival, and postnatal body weight of pups
were evident "in two successive'generations delivered-from male and female
rats that ingested TCDD 90 days prior to first mating,' during pregnancies,
and for the durations of time between pregnancies [29].
No significant
dose-related reproductive effects were observed in male mice treated with up
to 2.4 pg TCDD/kg bw/day and mated with untreated female mice [30,31].

Immunological Effects
TCDD induced .immunological function ' a l t e r a t i o n s , expressed by decreased
thymus-to-body weight ratios, in nursing newborn rats exposed through dosing
of the lactating mother [ 3 2 ] ,
Other reports have shown that pre- . a n d
post-natal maternal dosing of rats and mice with TCDD caused thymic atrophy

�and suppression of cellular
immunity in the offspring
[33],
TCDD
administered
intraperitoneally
or orally
to' mice
induced a strong
immunosuppressive effect on antibody production and cell-acquired immune
responses [ 4 .
3)

Mutagenic Effects
Results of mutagenicity tests are inconclusive.
In two studies TCDD was
mutagenic in Salmonella typhimurium TA 1532 without activation 135,36]. In
another study, which used a more sensitive mutant strain, Salmonella
typhimurium TA 1537, TCDD was not a mutagen [37]. There is weak evidence of
chromosomal aberrations in bone marrow of rats given dosages of 0.25 to
4 tig TCDD/kg bw [38,39].

Carcinogenic

Effects

Male rats fed dosages of 0.001 ng TCDD/kg bw/week for 78 weeks and
sacrificed at week 95 of the study showed a variety . of neoplastic tumors
(ear duct carcinoma; lymphocytic leukemia; kidney adenocarcinoma; malignant
peritoneal histiocytoma; skin angiqvsarcoma; hard palate, tongue and nasal
turbinate carcinoma) [ 0 . Female rats that had ingested TCDD for two years
4)
at a dosage of 0.1 ng/kg bw/day developed carcinomas of the liver and
squamous cell carcinomas of the lung,N hard palate, nasal turbinates, or
tongue [41],
Male and female rats orally dosed with 0.5 tig TCDD/kg
bw/week .for two years demonstrated neoplastic' nodules of the liver and
thyroid adenomas [42],
Male mice fed dosages of TCDD of 0.05 or 0.5 ng/kg/week for two years
developed liver cancer; female mice fed 0.2 or 2.0 ug/kg/week for the same
duration developed liver cancer and thyroid 'follicular cell adenomas [ 2 .
4]
TCDD applied to the skin of female mice for two years (0.005 ug/kg
bw/application; 3 days/week) resulted in a significantly higher incidence
(p=0.007) of skin cancers (f ibr'osarcomas) when compared to untreated
controls.
An increase in the same tumor type, although not statistically
significant (p=s0.084), was also observed in the male mice that received a
maximum dosage of 0.001 pg TCDD per application [43].

Human Health Effects
The only information on the health effects in humans from exposure to TCDD
is from clinical or epidemiological studies of populations who were
occupationally
and
non-occupationally
exposed
to
2,4,5-T
and
TCP
contaminated with TCDD. Because of the coincidental exposure to 2,4,5-T and
TCP and to other herbicides as well as to TCDD, it is not possible to

�attribute the observed health effects solely to TCDD exposure. To date, no
studies of humans include a quantitation of exposure to TCDD.
Chloracne and Other Systemic Effects
Chloracne is a chronic and sometimes disfiguring skin eruption caused by
exposure to halogenated aromatic compounds including TCDD. Chloracne is
possibly a result of systemic 'effects of these compounds, although it also
may occur as a contact dermatitis [44,45].
There are numerous cases of chloracne reported following accidental exposure
to chlorinated aromatic chemicals which were probably contaminated with TCDD
[46-48], The most notable recent exposure occurred in Seveso, Italy in 1976
[49]. In. most incidences of chloracne, there are a variety of signs and
symptoms (ranging from gastrointestinal disturbances to metabolic disorders)
which accompany the appearance of the skin eruptions and persist for varying
lengths of time [50-54].
Reproductive Effects In Humans
Reproductive effects resulting fr\&gt;m possible human exposure to TCDD are
-inconclusive. Data- on ;male workers -who applied agricultural sprays of:2,4,5-T- or who produced TCDD-contaminated materials are.consistent with the
animal data which suggest, no ^reproductive effects "in males from'. TCDD
exposure [55-57). To date, no study of reproductive effects in women or in
offspring of males or females with defined : exposure to TCDD has been
reported.
Studies of birth .defects in 'populations 'that may have been exposed
non-occupationally to TCDD have been conducted in Australia where a
correlation was observed between 2,4,5-T use and seasonal variation in the
rate of spinal cord and spine formation defects; no causal association could
be drawn [58], In a similar study in Hungary, an increased incidence of
congenital malformations including spine formation defects could not be
correlated with increased use of 2,4,5-T [59], A study based on incomplete
.fetal tissue samples from the Seveso, Italy population found no mutagenic,
teratogenic, or fetotoxic effects in 30 interrupted pregnancies and four
spontaneous abortions in women believed to have been exposed to TCDD [60],
A U.S. EPA study found a positive relationship between spontaneous abortions
and 2,4,5-T use in the Alsea, Oregon area [61]. The study, however, has
been severely criticized because of its numerous limitations:. inaccurate
comparisons of the study and control areas; inaccuracies in the collection
of data on spontaneous abortions; incomplete and inaccurate data on 2,4,5-T
usage; and failure to recognize that the rate o'f spontaneous abortions was
not greater than would be expected [62].

�Studies of Mortality and Carcinogenesis in Humans
Findings have been inconclusive, in many mortality studies of workers with
occupational exposure to TCDD-contaminated materials because of the small
size of the study population and concomitant exposures to other substances.
No excess mortality or tumor incidence was observed among Swedish railroad
workers exposed to unknown amounts of 2,4-D, 2,4,5-T, and other herbicides
but believed to have been exposed primarily to phenoxy acid herbicides for
at least AS days [ 3 . In a subsequent analysis of mortality in this group
6]
of workers, 45 deaths (49 expected) were observed in the total population.
A significant excess of tumors also was observed among those believed to be
exposed
primarily
to Amitrol®
(3-amino-l,2,4-triazole), a
suspect
carcinogen, as well as to phenoxy herbicides. Two cases of stomach cancer
(0.33 expected) were observed 'among those exposed primarily to phenoxy
herbicides [ 4 .
6]
Among Swedish forestry workers exposed to phenoxy herbicide preparations,
supervisors, who had more extensive exposure to herbicides than the other
forest workers, had a nonsignificant excess of deaths from all cancers.
Mortality associated with the presence of tumors was, however, lower "than
expected for the total group of exposed workers [65].
V

In a group of 74 workers involved in ^n accident during TCP production in
Germany, 21 deaths occurred during €he following 27 years. Seven (7)
malignant neoplasms vs. 4.2. expected and a significant excess of stomach
cancer (3 observed vs. 0.61 expected) were observed [ 6 .
6]
Several case control studies of cancer patients have yielded data on the
carcinogenic!ty of phenoxyacetic herbicides. Two studies were conducted in
Sweden following a clinical observation of patients with soft tissue sarcoma
who had previous occupational exposure to the herbicides [67]. The first
study of 52 cases of soft tissue sarcoma concluded that the sarcoma cases
were 5.3 times more likely than the 206 controls to have had occupational
exposure to phenoxyacetic acids (primarily 2,4,5-T and 2,4-D) [ 8 . The
6)
second study of 110 cases of soft tissue sarcomas indicated that this
population was 6.8 times more likely to have had exposure to phenoxyacetic
acids than the 219 controls [69], In neither study was it possible to
demonstrate the relative risk related to exposure to TCDD-contaminated
2,4,5-T because of the presence of impurities such as chlorinated
dibenzodioxins and dibenzofurans which were part of the phenoxyacetic
herbicides.
In other reports from Sweden, 11 of 17 patients with malignant lymphoma
reported occupational exposures to phenoxyacetic acids or chlorophenols

�[ 0 ? '\a case control study with .169 malignant lymphoma cases '-found a
7]
significantly higher occupational:.exposure to phenoxyacetic acids (primarily
2 4 5 T , ; . &amp;nd 2,4-D) associated'^ with the sarcoma cases than did - the 338
,,-.-'
controls. Analysis by individual'aiexbicide exposure was not possible [ 1 ,
7]
Two additional studies conducted in Sweden for colon cancer and nasal and
nasopharyngeal cancer did not demonstrate an elevated risk for occupational
exposure to phenoxyacetic acids [72,73].
Among four small groups of D.S* production workers exposed to TCP and
2,4,5-T a total of 105 deaths were observed [74-76]* In these, three deaths
were attributed to soft tissue sarcoma (43 times the number expected for
this age group of U.S. white males) [77]. "Later, four additional .cases were
reported to have soft tissue sarcomas [78-81], However, a detailed review
of work records and expert review of pathological tissue specimens have
shown only two of the seven cases with both confirmed exposure to TCP or
2,4,5-T and diagnosis of soft tissue sarcoma [82],
Summary of Toxicity in Animals and Humans
TCDD causes a variety of systemic3andimmunological .effects in animals with

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; Vliumans7f exposed tipv-ina teriVls'-i-^reported ;- to v bis ^contaminated • wi th';*TCpp^1iaye /";?
f
f
^•••'flaVAl nr\aA ~: **Ti1 rf^^fi r»nA "s"' anifl -""'-«+• Vio^*'-'^f e A rm e *•' f\f
cv'c+ovnf *» '"- ^^*^4 &lt;• ^\« 4 ^^ f»' '*•'-" ' C ^^^-"'""^4 .&lt;e» C*«*A / i; ^-

deve 1 oped ~" chlora cne * and'" other~ -sign's^: of systemic ppisbnlng".""'"' S of t~'^.tissue
sarcoma-'has been "observed in '-excess among workers exposed to phenoxy
herbicides. These data.are inconclusive regarding TCDD toxicity in -humans '
"because \-the populations studied :' had mixed exposures making : causal :
relationships between exposure "and : effect unclear. . The data are, however, : "
suggestive .of an "association •between exposure to phenoxyacetic herbicides
contaminated with TCDD and excess .lymphoma and.-stomach cancer. Attempts to
;'.. associate reproductive effects'with:..TCDD exposure are inconclusive.."because -;^
of the inadequately" defined -populations studied and the difficulties of "&gt;
defining exposure. '• Vc- ~.,.~~.-^^^ ,.,.&gt;•- • .. -.•;.-'•-;••
- ..-—_:. • --^--..::._ . . •-•,•

RECOMMENDATIOKS

,

'

. . .

There are several classifications for identifying a substance as a
carcinogen. Su,ch classifications have been developed by the U.S. National
Institute of 'Environmental Health Sciences, National Toxicology Program
[83], the International Agency for Research on Cancer [ 4 , and OSHA [8.5],
8]
NIOSH considers the OSHA classification the most appropriate for use 'in
identifying carcinogens in the workplace. This classification is outlined

�in 29 CFR 1990.103.* Since TCDD has been shown to carcinogenic in
experimental studies with rats and mice, and s'tudies are suggestive of an
association '-between human exposure to TCDD-contaminated materials and
carcinogenic!ty, NIOSH recommends that TCDD be considered as a potential
occupational carcinogen and exposure to TCDD in all occupational settings
should be controlled to the fullest extent feasible. While observations to
date do not confirm a causal relationship between TCDD exposure and soft
tissue sarcoma, they suggest a need for continued investigations.
Because of the variety of situations likely to be encountered in
TCDD-contaminated worksites, it is not possible to offer in this bulletin
detailed procedures for assessing exposures or decontamination. Based on
NIOSH hazard evaluations of TCDD-contaminated sites, the following general
guidelines are recommended until more specific procedures can be developed
[86,87],
Assessment of Exposure
Workers may be exposed to TCDD derived from a variety of sources: the
production of TCP, residues from prior production or use of 2,4,5-T or
silvex, waste materials contaminated by TCDD, or contamination resulting
from transformer fires. The first^step in assessing workplace contamination
should be environmental sampling to determine the presence of TCDD
contamination, keeping in mind the possible routes of exposure, with later
sampling conducted to define the quantity of TCDD in the environment. The
assessment may include sampling of soil and settled dust for TCDD, air
sampling for TCDD-contaminated particles, and wipe sampling of surfaces
.186,871.

*'"Potential occupational carcinogen' means any substance, or combination or
mixture of substances, which causes an increased incidence of benign and/or
malignant neoplasms, or a substantial decrease in the latency period between
exposure and onset of neoplasms in humans or in one or more experimental
mammalian species as the result of any oral, respiratory or dermal exposure,
.or any other exposure which results in the induction of tumors at a site
other than the site of administration. This definition also includes any
substance which is metabolized into one or more potential occupational
carcinogens by mammals."

�Decontamination and Worker Protection Programs .

..

Iti general, decontamination procedures must provide an organized process in
•which levels of : contamination.-a re reduced. ^.-. This requires containment,
collection, and disposal of contaminated solutions and residues generated
during the cleanup.
Separate
facilities
should be provided for
decontamination of large equipment.
Each stage of decontamination, such as gross decontamination and repetitive
wash/rinse cycles, should be conducted separately, either by using different
locations or by spacing in time. Personnel decontamination locations used
should be physically separated to prevent cross-contact and should be
arranged in order of decreasing level of contamination. Separate entry/exit
routes and locations should be provided for workers when it is necessary to
isolate them from different contamination areas containing incompatible
waste. Entry and exit points to these areas should be well marked and
controlled. Access to the decontamination area should be separate from the
path between the contaminated and clean areas. Dressing stations for entry
should be separate from re-dressing areas for exit.
Protective Clothing and Equipment;;;.,/:::;.....

. .,--..,

-r:.

--VV-""

'

-^

• Al.l;, workers who,. may|:i&gt;e; exposed &gt;to/;TCDD~ should^."be -equipped ; with "adequate "1
chemical protective^:clothing-vand^equipme^t to&gt;ensure their^.protection.5"-Cln";;.!, selection -of 'protective -.clothing,"; consideration should be ";given^to"' the -\'-.
-;.";;-:utilization of_disposable apparel;; due; to the iracer
^;;-;vof": clbthing.^...v •^:^^: V-^^^SS^^f*^^-' -'^'-^'^f-'
The protective apparel should consist of both outer and inner garments. The
outer1 garments should consist of-a . zippered coverall with attached hood and
draw string or elastic sleevesi~ gloves and closure boots." If exposure is to
particulate or dusty_the.coveralls, should be made of a'non-woven fabric .such
as spunbonded polyethylene, Tyyek®.. In cases of exposure to liquids, the
coveralls,, gloves'and boots should-Jbe made of chemically resistant materials
: such as disposable .laminates," e,g.,'_ Saranax* coated Tyvek*, or synthetic
elastomers such as butyl,. nitrile ,,or neoprene; rubber. The inner garments
should consist of cotton coveralls, .undershirts, undershorts, gloves, and
socks and should be disposed of after use'. The effectiveness of the
protective clothing should be evaluated -under simulated use conditions,
regardless of the type of clothing used. All disposable clothing should be
•placed in marked and approved containers and disposed of appropriately. All
reusable clothing and equipment should be thoroughly cleaned and checked for
residual contamination before reuse or storage.

10

�Respiratory Protection
The use of respiratory protection requires that a respiratory protection
program be instituted according to the requirements of 29 CFR 1910.134 [88]
and that the respirators have been approved by the Mine Safety and Health
Administration (MSHA) and by NIOSH. This program should include training on
proper fit
testing and use and procedures for respirator maintenance,
inspection, cleaning and evaluation.
For situations where TCDD contamination is low (e.g., exposure to dust
contaminated with low levels of TCDD), air purifying respirators should
provide sufficient protection until the extent and characterization of the
exposure can be determined.
Where quantities of materials highly
contaminated with TCDD have been released and have contaminated an area
(e.g., production accidents), all workers who may be exposed to TCDD should
wear respirators that consist of a self-contained breathing apparatus with a
f u l l facepiece operated in pressure-demand or other positive pressure mode.
An alternate method utilizes a combination Type C supplied air respirator,
with f u l l facepiece, operated in pressure-demand mode and equipped with
auxiliary positive pressure self-contained air supply.
Post-Decontamination Testing

v

\
The adequacy of the decontamination^ effort should be determined by
conducting follow-up sampling and analysis of • the contaminated areas and
protective equipment. This testing should be conducted as each area is
decontaminated and after the'entire facility has been cleaned.

11

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.

6*.

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Agency,
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Part

in

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"
^ -

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"•• -'
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'" T.'

'•' '•'•••

** «« •»

•• A A - - / - « * \ * s * * N ™i?- r.' ''-.**.'•_'. .

. .

"f

'.^I\-V-.'v t. .

....

' ' *"' '"• — • J

_,

'. .

'

":-" 'indueer -;. of '2tt de'lta-amindlevulinic'^ acid

T . _ ~s • . -"".' ^

** ' -

- • ".

,•*'»' "~ r~ • » * ; ' -

•-••-•

* •

.:! "

" synthetase.

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14

�24.

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27.

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CF-1

Teratogenicity
of
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"
"^

Perinatal
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30.

Lamb JC IV, Moore JA, Marks TA, ^-et al.: Development and viability
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vv

'

31.

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34.

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15

�i
"\'pf?sl&amp;A^^^ey^oia^Ti
m^&amp;^5(Sy^22-623

~.,y

'

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."^-^j^Xl-S;.:^.- •"&lt;-?/?-'v;~ ' .-, :;/ /'•"'"

37.f" ; Geiger
. LE,
Neal
RA:
Mutagenicity '
testing
of
2,3,7,8-tetrachlorodibenzo-£-dioxin
in
histidine
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._ ... ' . ' Salmonella typhimurium. Toxicol Appl Pharmacol 59:125-129 (1981).
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.'von :" micer/"and rats :.:exposed - to 2,3,7,8-tetrachlorodibenzo-p_-dioxin
-::&lt;TCDD).
In:
Hutzinger 0, ed.: Chlorinated Dioxins and Related
Compounds:. Impact on the Environment. Proceedings of a workshop,
Institute Superiore di Sanita, Rome, Italy, held 22-24 October

Carcinogenesis Bioassay ; of 2,3,7,8-Tetrachlorodiben.zo-£^-dioxiia (CAS
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(Dermal : S tudy).-^ U.S..;;.^
Department of .Health and Human Services, Public Health ~ Service,
National
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of
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82-1757,
(February 1982).
•.
•
44.
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Crow KD:

Chloracne.

Semin Dermatol 1(4){305-313 (1982).

' Jones EL, Krizek H: A technic for testing acnegenic potency in
rabbits, applied to the potent acnegen,
2,3,7,8-tetrachlorodiberizo
-p_-dioxin. J Invest Derma tol 39j 511-517 (1962).

16

�46.

May
G:
Chloracne
from
the
accidental
production
tetrachlorodibenzodioxin. Br J Ind Med 30;276-283 (1973).

47.

Goldmann PJ:
[Severe acute Chloracne.
A mass intoxication by
2,3,6,7-tetrachlorobenzodioxin]. Hautarzt 24;149-152 (1973) (Ger.).

48.

Reggiani G: Acute human exposure to TCDD in Seveso, Italy.
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_ L J L - . 1 T T 1 - | . __

.-

_1L_1_...LI

L.IUJiL

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of

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Arch
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Smith AH, Fisher DO, Pearce N , et al.;
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Townsend JC, Bodner KM, Van Peenen PFD, et al.: .Survey of
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Field B, Kerr C; Herbicide use and incidence of
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17

neural

of
N2

tube

�»55?- Rehder
-rr^sSdles"-'''lS^rcase8"y&gt;i;-bf -abortion connected/ with 1 the-" accident
vv
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at

Report of Assessment of a Field Investigation of Six-Year
Spontaneous Abortion Rates in Three Oregon Areas in Relation to
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6 ; ' ' " Wagner. S,"Witt JM^ Norris LA;.et al.:." A Scientific Critique "of. the
2"".'
7
EPA ALSEA' II Study "--"and "Report. "Environmental Health -Sciences
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63. ~ Axelson 0, Sundell Lt ;_._. Herbicide exposure, mortality, and tumor
;P ":';-&lt; incidence: "..-.»-..An ..epidemiqlogical ..investigation on Swedish railroad
^ : 7 v T e s . . .- —
^ ^ ^ o k r ..- • ! .-Work Environ •Health-;11:21-28. _( . 9 ,4
17X
's.tjjj-w-jy-^.^-y-.j-d^afc*^-,^^^..,..
"
•
.
- . . .

guv.i:'^v^i|%Harde^l^rL':^llMa^
^^S^i^'icids: --•A-cliiaical= observation.]^ Lakartidningen 7412753-2754;^(1977)'-^^g^
?'".:*.•'*':••:- (Swe. ) . - . • • ^^l:^-

" *

•': -- ^ V - V ',-.-.•/•—--

-• ••--:-::• '.- '"N' ""- -'"A- •:-;''': ^l™'^

68.

Hardell L, Sandstrom A: Case control study: S o f t tissue .-sarcomas
and exposure to phenoxyacetic acids or chlorophenols. Br J Cancer
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Eriksson M, Hardell L, Berg NO, et al.:
[Case-control study on
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chemical substances.] Lakartidningen 76;3872-3875 (1979) (Swe.).

18

�70.

Hardell L: Malignant lymphoma of histiocytic type and exposure to
phenoxyace tic acids or chlorophenols.
Lancet I (January 6):55-56
. (1979). v;:
,:•-.
.:.;•
..
' . - . -:,-&gt;, ... . •
V

71.

Hardell L, Eriksson M, Lenner P, et al. : Malignant lymphoma and
exposure to chemicals, especially organic solvents, chlorophenols
and phenoxy acids: A case-control study. Br J Cancer 43:169-176
(1981).

72.

Hardell L: Relation of soft-tissue sarcoma, malignant lymphoma and
colon cancer to phenoxy' acids, chlorophenols and other agents.
Scand J Work Environ Health 7:119-130 (1981).

73.

Hardell L, Johansson B, Axelson 0: Epidemiological study of nasal
and nasopharyngeal cancer and their relation to phenoxy acid of
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74.

Zack JA, Suskind RR: The mortality experience of workers exposed to
tetrachlorodibenzodioxin in a trichlorophenol process accident.
J_
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..

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.Ott MG, Holder BB, Olson R£:
A mortality analysis of employees
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Med 22(1):47-50 (1980).
.
• ' •'
.

76.

Cook RR, Townsend JC t Ott MG, et al. : Mortality experience of
employees exposed to 2,3,7,8- tetrachlorodibenzo-p_-dioxin (TCDD). J_
Occup Med 22(8);530-532 (1980).

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78.

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(March 1):618-619 (1981).

79.

Moses M, Selikoff IJ: Soft tissue sarcomas, phenoxy herbicides, and
chlorinated phenols. Lancet I (June 20):1370' (1981).

80.

Johnson FE, Kugler MA, Brown SM:
Soft
tissue
chlorinated phenols. Lancet II (July 4 ) : 4 0 (1981).

81.

Fingerhut MA, Halperin WE:
249(23):3176 (1983).

19

and

soft

Dioxin

tissue

exposure

and

soft

sarcoma.

and

tissue

Lancet JE_

sarcomas

sarcomas.

and

JAMA

�lsease? Control^ Ptibli^Beal th T Service^Sbepartaent 7 of
im^^Se^ic^liBef ore^the^ United JstktesljHo^e .^of.
Representatives/: Committee..^on Public ;'Works';-'and ~Y Transportatlonr
Subcommittee on Investigations and Oversight. (November 9,:-1983).
83.

:...

Matthews HB:
NTP Technical
Report
on
the
Toxicity
and
Carcinogenic! ty of Tris(2-ethylhexyl)phosphate (Gas. No. 78-42-2) in
F34A/N rats ..and BSCSFj; mice -(gavage" study), ..National Toxicology
Program, Research Triangle Park, North 7 .Carolina,' p. 4, (unpublished

.;... Supplement ;l^(1979)i.;x^4c. ~-P- " 7

-"-"rrsv.-- •;

- v-..&gt;;:-.&gt;,-4-.-:.---'.-.^.^:t5-^r ..,\ -

85. . Code of.Federal Regulations, U.S. Department of Labor, Occupational

5?m&gt;l&amp;&amp;*&amp;ECm&amp;£

e termina.ti OBfi rReport;
^^3L«sour

20

�CUMULATIVE LIST OF NIOSH CURRENT INTELLIGENCE BULLETINS

1.
2.
3.
4.

Chloroprene
Trichloroethylene (TCE)
Ethylene Dibromide (EDB)
Chrome Pigment

5.

Asbestos - Asbestos Exposure during Servicing
of Motor Vehicle Brake and Clutch Assemblies
Hexamethylphosphoric Triamide (HMPA)
Polychlorinated Biphenyls (PCB's)

6.
7.

-

4,4 f -Diarainodiphenylmethane (DDM)
Chloroform
Radon Daughters
Dime thylearbamoyl Chloride (DMCC)
Revised
12.
Diethylcarbamoyl Chloride (DECC)
13.
Explosive Azide Hazard
14.
Inorganic Arsenic - Respiratory
vV
Protection
15. - Nitrosamines in Cutting Fluids
v
,
**
Oi.
"16..- .Metabolic Precursors of a Known Human
"Carcinogen, Beta-Naphthylamine
:
17.
2,-Ni tropropane
.18.
Acrylonitrile
19.
2,4-Diaminoanisole in Hair and Fur Dyes
20.
Tetrachloroethylene (Perchloroethylene)
21.
Trimellitic Anhydride (TMA)'
22.
Ethylene Thiourea (ETU)
23.
Ethylene Dibromide and Disulfiram
Toxic Interaction
24.
Direct Black 38, Direct B l u e ' 6 , and
Direct Brown 95 Benzidine Derived Dyes
25.
Ethylene Dichloride (1,2-Dichloroethane)
.26.
NIAX Catalyst ESN
27.
Chloroethanes - Review of Toxicity
28.
Vinyl Halides - Carcinogenic!ty
29.
Glycidyl Ethers
30.
Epichlorohydrin
31.
Adverse Health Effects of Smoking and
the Occupational Environment
32. Arsine (Arsenic Hydride) Poisoning in
the Workplace
33. Radiofrequency (RF) Sealers and Heaters:
Potential Health Hazards and Their Prevention
34.
Formaldehyde: Evidence of Carcinogenic!ty
8.
9.
10.
11.

21

January 20, 1975
June 6, 1975
July 7, 1975
June 24, 1975
October 7, 1975
October 8, 1976

-

August 8, 1975
October 24, 1975
November 3, 1975
August 20, 1976
January 30, 1976
March 15, 1976
May 11, 1976

- July 7, 1976
- July 7, 1976
- August 16, 1976
- September 27, 1976
- October 6, 1976
-'-

December 17, 1976
April 25, :1977 "
July 1, 1977
January 13, 1978
January 20, 1978
February 3, 1978
April 11, 1978

- April 11, 1978
-

April 17, 1978
April 19, 1978
May 22, 1978
August 21, 1978
September 21, 1978
October 12, 1978
October 12, 1978

- February'5, 1979
- August 3, 1979
- December 4, 1979
- A p r i l 15, 1981

�ifeffid^P^^-^SSyry':!-.T-W•*•&gt; V"ft'j- gWaty-t. ,•*","'"•'.1' "
^

. "•"^^•irr»i«?*ft1'?-:*-^-ii*.= -*".'rJ^?**«1,-. ij&gt; -»'*v&gt;;- r%'/:if*,-3

^^^5i;|;r.-; Ethylene^ipxide- (E tfl)? ^ Evidence'C-of;.- :-f%
^~ ' ' ' T Carcinbgenicity ..-^~y£'?'^.^.^~z:-'': •:' """
Silica Flour: V S i l i c o s i s ' :
: ..
EthyleneDibromide (EDB) .
Revised
Vibration Syndrome
',
The Glycol Ethers, .with Particular
Reference to 2-Methoxyethanol and

(TCDD'isVDioxin"-)

NOTE:

- June 30., 1 9 8 1 - October 26, 1981
- March 29, .1983

- January 23, .1984

Bulletins #1 through #18 and #19 through #30 have been reprinted as
NIOSH publications,
#78-127 and #79-146 respectively, for
the
convenience of those that desire a complete series of Current
Intelligence Bulletins.
Distribution of these publications and
single copies of Bulletins #31 and later are available from NIOSH
Publications Dissemination, Division of Standards Development and
Technology T r a n s f e r , A676 Columbia Parkway, Cincinnati, Ohio 45226.

22

&lt;» U.S. GOVERNMENT PRINTING OFFICE: 1984—759-103/1038

�^._

CENTERS FOR DISEASE CONTROL

TjJATlpNAL.INSTITUTE FOR OCCUPATIONAL SAFETY, AND HEALTH
4616COLUMBIA PARKWAY. CINCINNATI. OHIO 45226

Third:: Class. Mall
"

Redistribution using indicia is illegal.

DHHS (NIOSH) Publication No. 84-V •
Va-f"

�</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>Pesticide and Toxic Chemical News</text>
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                <text>October 24 1979</text>
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              <elementText elementTextId="45976">
                <text>2,4,5-T, Silvex Cancellation Proceedings to Begin Jan. 22 at EPA</text>
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                    <text>Item D Number

°5258

D Not Scanned

Author
CorDOratB Author

2,4,5-Trichlorophenol Working Group, U.S. Environment

RODOrt/APtiClB TltlB 2,4,5-Trichlorophenol and Its Sodium and Potassium
Salts: Position Document 1

Journal/Book Title
Year

1979

Month/Day

February 28

Color

n

82

DOSCrfptOn Notes

EPA/SPRD-80/79. P881-103111

Friday, March 01, 2002

Page 5258 of 5263

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j ft

PB81-103111

2,4,5-Trichlorophenol and its Sodium and
Potassium Salts: Position Document 1

(U.S.) Environmental Protection Agency
Arlington, VA

28 Peb 79

Technical information Service

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REPORT DOCUMENTATION
___ PAGE
*

3. RecloUiitj* Accession

I. REPORT NO.

JP_A/S_PRD-_80/7?

^

4. Title and Subtitle

5. Report

2,4,5-Trichlorophenol end Its Sodium and Potassium Salts:
Position Document I

6.

7. Author(l)

B. Performing Organteatlufl Rept. No.

9. Performing Organization Name and Address

10. Prolect/Tssk/Work Unit No.

Special Pesticide Review Division
Environmental Protection Agency
Crystal Mall #2
Arlington, VA 22202

11. Contract(C) or Grant(G) No.

(0

X

(GJ

12. Sponsoring Organisation Name and Address

II. Typ« of Report &amp; Period Covered

U. S. Environmental Protection AGency
401 M St., S.W.
Washington, D.C. 20460

14.

IS. Supplementary Notes

&gt;«. Abstract (Limit: ZOO words)

Preliminary Risk Assessment: Examination of possible unreasonable risks
associated with uses of pesticide and a gathering of all available
information to determine whether or not this or any other risk does
exist. Initiates literature search and evaluates risk data. Limited
information on exposure to forecast extent of risk.

/

17. Document Analysis

a. Descriptor*

I

0606,0703,0504
b. ld»ntlll«rs/Open&lt;Ended Terms

c. COSATI field/Group
I . Availability SIMem»r&gt;:
I

Release Unlimited

I*. Security Claw (This Report,

JlnclUSlfJjSd

to. Seewliy Clan fthlt Page)
See ln&lt;truc(loni an Reverie

21. No. of Pages
M. P&gt;tc«
OPTIONAL FORM 271 (4-77)
(formerly NTIS-Ji)
Department el Commerce

�P881-1031U

2A5-T81CHLOBOPSEHOL
AND US SDDIQM AND POTASSIUM SALTS

POSITION

2f^,5-?richloroph8nol Weridag Group
Mwy H»«C8, Project Macagar
D.S. Errirocaantai Protection Agency

trmooucEO it
NATIONAL TECHNJCAL
INFORMAT1OM SERVICE
U.I. KfAKTMCNT Of COMMlfiCI
i«

�Page
Forward
I.

,,.

1

Background

2

X. Chendciil and Physical Characteristics
B. . Manufacturing Peaces* and Resulting Contaminants
1. Forsulation . « . . . * « . . . . . . . . . . . . .
..•.«..«...........
2. Type* of Dicodns
3* TCCD Content in Fornulattd Pesticides
C. Registrations, Uses, and Production
D. Tolerances
E. Metabolism, Degradation, and Residues
1. soil
a. 2,4,5-TC? and Its Salts

2
3
3
4
4
5
7
7
7
7

b. TOD

2. Water

*

8

•&lt;&gt;

9

a. 2,4,5-40? and Its Salts
b. TCBD

9

,

,.
.

... 10
..

3. Wildlife
a. 2,4,5-4X2 and Its Salts
b. TCCD

iO
10

*

10

1. Terrestrial Eecaystana
ii. Aquatic EcosysteBS
4. Plants

a. 2,4,5-TC? and Its Salts

b. TCCD

5. Anirais
a. 2,4,5-TC? and Its Salts
b.

TOO

,

„

TCCD

b.

,,..„.... 10
10
11

II.

Accidental Human Exposure

13
14
14
;

Regulatory History

15

21

Onoogenic Effects in Test AniaaLLs
1. 2,4,5-TC?
2. TCCO

a. '/an Miller Study
b. Preliminary Report:
Dow Chemical Company Study
c. Conclusion

14

18

HZ. Sunrary of 'Scientific Evidence Relating to
Rebuttzble Presuroticn
A.

x2
12
12

6. Humans
7. Anifiad. Products
a. 2,4,5-TC? and Its Salts
F.

1
1

,... U

21
21
22

22

..
-.

24
24

�Page
B.

Fetoteodc and Teratogenic Effects in Manrculian Specie* .... 26
...
1.
2.

3.

2,4,5-TCP
TCTO

a. Mice
b. Rats
c. Chide EBbryos
Exposure Analyses
a. Industrial Cooling Water Syattam
b. Paper and Pulp Mills
c. Leather Industry
d. Hospitals
e. ConfUuaicn

IV. Evidence not Sufficient to Support a Rebuttabla Presumption
A
B.

C.

27
28

28
34
40
41
43
49
SO
53
...6
..5
57

Mutagenic Effects of TCDD in Test Aninala
57
1. Studies Demonstrating the Mutagenic Effects of VXD .. 57
..
2. Studies in which Mutagenic Effects were not ocaerved .. 59
.
Other Effects of TCDD
59
1. Enzynatic Effects
5n
2. Toxic Effects on Humans
60
3. Toxic Effects on Other Manuals
61
4. Miscellaneous Toxic Effects
61
Other Effects of 2,4,5-TC? and Its Salts
62

�FOREWORD
All technical and f craniated 2,4,5-trichloropbenol (2,4,5-TC?)
products are contaminated in varying degree by &amp; byproduct of the
manufacturing procaaa, 2,3,7|8«tetrachloroclibenzi&gt;*£»dioxin (TOO). For
this reason all refer-mova to 2,4,5-TC? denote TCDD-contaainatad 2,4,5-TCP.
Humarous toxicity studies on purified TCDD are included in this position
document. Many of these studies were done in connection with another
pesticide, 2,U,5-triehiorcphencDeyacetie acid or 2,4,5-T, whicn ia manufactured frcm 2,4,5-TC?. 2,4,5-T, which is a candidate for rebuttable
presumption against registration, is the subject of a separate position

�I.

Background
A.

Cjbei^e«l_and..P_^i.ealj;.tjaracteri3tie3

2,i»,5-Trichloropbenol (2,4,5-TCP) and its sodiua (Na-2,4,5-TCP)
and potassium OC-2,4,5-TCP) salts are used as fungicides, algicides, and
bactarlcides (Weissberg aad Zinld, 1973; Pliomer et ai., 1973). The
empirical formulas for 2,4,5-TCP aad its sodium and potassium salts are
C H C 1 0 H , C H C l O N a , a B d C H C l C X , respectively. The structural
6 2 3
6 2 3
6 2 3
formulas of these compounds may be found in Figure 1. 2,4,5-TCF Is
also known by its trade name, Douicide 2; ths trade name of Na-2,4,5-TC?
Is Oovdcide B.

Cl

Na-2,&lt;»,5-TC?

at
K-2,4,5-TC?

F2GUJH 1. Structural formulas of 2.U&lt;g.7C?
"

and JM sodium ana potassium; salts

2,U,5-TC? is a fairly weaie acid and is considered to be the least
toxic of ti» cnloropnenols (Kirtc-Ctfcmer encyclopedia, 196^). The sodium
salt is slightly more toxic. 2,4,5-TCP occurs as gray flakes in subliaed
muss with a strong phenolic odor. Although 2,^,5-TC? ii relatively ino
soluble in water « 0.2 g/100 g water at 25 C), it is soluble in organic
solvents such aa alcohol, ether, and acetone. The sodium salt is more
o
soluble in water (113 g/100 g water at 25 C). 2,U,5-TC? has a aolecular
o o
weight of 197.^6 and a specific gravity of 1.678 (25 C/« C). Its
o
o
point is 2f2 C; the melting point is 60-70 C.
(2)

�8.

Manufaetajr^^Pn^aa^a^
1.' Foraulatign

2,4,5-TCP la produced ccanercially by the alkaline hyrirolysia of
1,2,4,5-tetracnlorobenzene to 2,4,5-TCP. The reaction la carried out
o
under pressure at 180 C in the presence of aqueous aodlua hydroxide and
Mttanal (Kirk-Otaaer Encyclopedia, 1964; F&lt;ahbeiaf 1973)• 2,4,5-TC?
can be converted to ita aodium or patasaium aalta by the addition of
sodium or potaaaium carbonate.
Polychlorinated fMhon^p-^-^i ny^pa JTQ fonsed in *-^ oanufacturicg
proceaa of all cnloropnenola. However, tbe aoount formed ia dependent
on the degree to vdrteh tne tanperature sad greaaure are controlled during
production (Fiahbein^ 1973; Hilnea, 1971; SrhnU, 1968; ff1 ggr!nhottam at
al. 1963; Huelder and Shadoff, 1973)'
Aa especially toxic &lt;q.«gjnT 2(3i7tS-tetncnlorodibenzo^pj-dioxin
(TCDD), ia foraed during tta prcduction of 2,4,5-TC?. Aa can be anticipated, TCPD

hg&lt;

been ^a«y?gia^yi viltix "i \ syntnetic &lt;i*MC"i?'7rir*? derived

frcs 2,4,5-TC? (Kearney et al., 1973)• Thia includes the widely uaed
herbicide ana defoliant 2,4,5-T (2,4,5-trichloropnenaxyacetls acid).
Tm formation of 2,4,5-TC? and TCDD ia illustrated in Figure 2.
a

"•o««

Figure 2. Foraulation . of.2,4,5-TC? and TCDD

(3)

�2* Types, of Dioxins
There are many different dioxins; the particular dioxin produced
depends OQ the ohlorophsnols present (Poland and itende, 1976). Different
^""'
dioxina can be distinguished by the number and position of the chlorines
they contain. Chlorine atoms my b« attached at any of eight different
positions, creating a theoretical possibility of T5 compounds or isomers
(Crosalaod and Shea, 1973; Basra and Roddick, 1973)*
The toxicity of a dioxin varies with the position and number of
chlorines attached to the aromatic rings. Generally, the toxicity increases with increased chlorine substitution. Those dioxins that have
halogens at the 2, 3, and 7 positions are particularly toxic (Burger,
1973)* TCDD, which has.chlorine atoms at the 2, 3* 7, and 8 positions,
is considered the most toxic of the diorins (Sparschu et al.t 1971).
3» TCDD_Content in Fora?ilated Pegtieides
Although TCDD levels in 2,U,5-TC? have cot been monitored consistently over the years, these levels have been seasured in 2,U,5-T. Different satnufacturers produced 2,4,5-t with various 7C3D contents (Kearney
et al., 1 7 ) Samples of 2,4,5-T produced by one manufacturer frca 1966
93.
to 1968 often contained more than 10 ppm TCDD (Fiattein, 1973)• Because
there vas co^rera about tie extremely toxic effects of TCDD, manufacturing methods wore changed and carefully controlled to minimize its formation. By 1971 industry had reduced the amount of TCDD in commercial samples of 2,4,5-T to less than 1 ppa (Greig et al., 1973; Hussais et al.,
1972; Milnes, 1 7 ) Production conditions and the amount of contaminant
91.
in th« final product ar« now closely monitored by industry.

�2,4,5-TC? is available in both a technical and analytical fora.
Technical grade 2,1,5-TCP (Dowicide 2) currently contains 95&gt; active ingredient and 5* inert ingredients in which TOD ia present at a maxLinim
of 0.099 ppm. Technical grade Wa-2,H,5-TCP (Dowicide B) contains 855
Ka-2,^,5-TC? and 15* inert ingredients in which TCDD is present at a
marianim of 0.099 ppm (Dow Chemical Company Sales Specifications, 1976).
The «13ortn content in both of tbas* products does not exceed the limit
of 0.1 ppm reconmended by the Advisory Carrel ttee to tbe SPA Administrator on May 7, 1971.

To obtain a meaningful assessment of tbe levels of TCDD present
in tba environment and to determine tbe amount that could be accumulated
in tbe food chain, a sensitive analytical method bad to be developed that
could accurately, identify TCDD in parts per trillion. During ths past
10 years coosiderable advances have been made in this regard. Tbe analytical procedure that is currently considered the scat sensitive is.
gas-liquid e&amp;romatograpfay coupled with high resolution mass spectrcsetry
•

(National Academy of Sciences, 1977).
C. Registrations, Oaea. and Production
The largest u;- cf 2,4,5-TC? is as a starting material in the
manuf95cure of a series of industrial and agricultural chemicals, tbe
most notable of which is tba herbicide 2,^,5-T and its related products
including silver C2-(2,U,5-trichlorophencxy}propionic acid], rcnnel [0_,
2-diaathyl 0-&lt;2,U,5-trichlorophenyL)-pfeaspborothioate], and tfat baotcricide bexachlorophene.

(=).

�2,4,5-TCP and its salts are used in the textile industry to preserve emulsions used in rayon spinning and silk yarns, in the adhesive
induatry to preset*" polyvinyl acetate emulsions, in the leather industry aa a hide preservative, and in tha automotive industry to preserve
rubber gasknts. The sodium salt is used as a preservative in adhesives
derived from caaaia, as a constituent of natal cutting fluids and foundry
core washes to prevent breakdown and spoilage, aa a tactaricide/fungicide
in recirculating water in cooling towers, and as an algicide/sliaicide
in the pulp/paper manufacturing icduatry.
There are some minor uses of 2,4,5-TC? and its salts in disinfectants which are of major Importance relative to h"1*3" exposure. These
include use on swimming-pool-related surfaces; household sickroom equipment; food processing plants and equipment: food contact surfaces; hospital rccma; sickroom equipment; and bathrooms (tnelnrting shower stalls,
urinals, floors, ,and toilet bowls).
2,4,5-tC? and its salts lave been registered for peaticidal use
since 1943. Current EPA records indicate that 42 registrants have 9"
Federally-registered products and one State-registered product containing 2,4,5-TCP or its salts. These products are usually fonaulatad as
wettable powders, emulsifiable concentrates, dry powders, liquids, or
ball briquettes. Dow Oyn1.na] Company is tba major manufacturer of
technical grade 2,4,5-TCP (Dowicida 2) and Ha-2,4,5-TCP (Dowicide 3).
2,4,5-TCP and its salts are frequently sixed with other pesticides including pentachlorophenol, tetracslcrcpfcenol, and sodiua pentachlcropbenate.
(6)

�Stction 7(o) of the Federal Insecticide, Fungicide, and Rodentieide Act (FIFRA) requires asanufaeturers and formula tors to i-jbait to EPA
information on the production, sales, and distribution of their products.
According to Sections 7(d) and 10 of FIFRA, this information may not be
^"
csade available to the public. A confidential memo suonarising this information (Beece, 1977) has been sent to the Deputy Assistant Administrator for Pesticide Programs.
D*

Tolerances
There are no tolerances for 2,*,5-TCF, its salts, or TCSO in or

on fool crops. 40 CFR 180.302 does, however, establish a tolerance of
0.05 ppn bexaehloropnene in or on cotton seed (a nonhuaan dietary food
itea) and states that technical grade hexschlcropfaene shall not contain
more than 0.1 ppm 7C2D.
E*

Metabolism. DegradatiDn._ and Residues
No data baa been found on the nature of the degradation products

of 2,4,5-TCP. However, there is evidence that 2,4,5-TC? itself is the
metabolite or primary degradation product of a number of pesticides including 2,U,5-7, ailvex, ronnel, lindane, and benzene hexachloride (Watts
and Storfcerr, 1973; Crosby and Wong, 1973; Goto et a!., 1972; Leng, 1972).
1.

Soil
a. 2,t,5-TC? and Its Salts

Alexander and Aleea (1961) found that 2,U,5-7C? is persistent because it is resistant to microblal decocpositicn in certain soil populations. They also found that compounds containing a meta-sucstituted
chlorine (such as 2,^,5-TC?) were sere persistent than these that did net.
(7)

�These results were verified by Helling et al.f in 1973.
i
I

b. TCDD

Crosby et al. (1973) Irradiated 2,4,5-TCP tad its sodium salt
and found that they discolor*! rapidly but did not degrade into dioxins.
Kearney et al. (1972) Incubated 2,U,5~TC? in two types of soil for 70
days to determine wnstbar bacterial action might convert the 2,4,5-TC?
to TCDD. The fact that no TCDD was detected demonstrated that TCDD vas
not foraed under these laboratory conditions. Thus, TCDD is neither
foraed indigenously in soil (Kearney et al., 1972) nor produced biosynthetically from soils receiving applications of 2,4,5-T or 2,U,5-TC?
(Belling et al., 1973; Kearney et al., 1972; Kearney et al., 1973).
TCDD is a remarkably stable ccmpound in biological systems at
o
temperatures up to 700 C (Grassland and Shea, 1973; Piper et al., 1973).
It is also immobile in soil and tends to remain on the surface (Helling,
1971). TCDD degrades slowly in soil; it has. a half-life of 1 year
(Kearney et al., 1972; Belling et al., 1973).
In 1973, Woolscn et al. investigated the possibility that TCD
residues from old, extremely heavy 2,1,5-7 applications night still ycse
a threat to wildlife. They analyzed soil samples frca experlcental plots
of Ukfla"d sand in Florida that lad received massive doses of 2,^,5-T
(947 pounds 2,U,5-T/acre) by aerial application frcm 1962 to 1970. The
authors estimated that the- 2,4,5-T used at that time contained between
2 and 50 ppm TCDD. Twenty-five gram samples of 6-lncb increments of a
3-foot cere were taken in 1970. Mo TCCD residues were found in any of
the increments; the detection lisit was leas than 1 ppb. The autters

(8)

�bad estimated that there could be up to 2.1 ppa TCDD present in the soil
as a result of the aerial applications.

They felt that the absence of

daUctable TCDD residues could be explained by jeveral possibilities:
1) the 2,4,5-T applied contained less'than 2 ppm TCDD, 2) the TCDD moved
dwper than 36 inches into the soil, 3) the TCDD was decomposed in the
soil ptotocaemicaliy or biologically, or 4) wind erosion removed the TCDD
frcm the point of application. Bovever, TCDD is immobile in soil and the
likelihood of wind erosion or the amount of TCDD present being less than
2 ppm is remote. It Is most Likely that the TCDD photochemically degraded.
P11 Timer et al. (1973) found that TCDD is readily photolyzed under
certain conditions. Crosby and Wong (1977) found that herbicide foraulations containing TCDD on leares, soil, or glass plates lost most or all
of the TCDD in a single day of exposure to sunlight due principally to
photochemical dechlcrination. However, Crosby et al. (1971) found that
a filffl of "pure* TCDD on glass plates was not photodegraded when exposed
to sunlight for 14 days.
2. Water •
a. 2.4,5-TC? and Its Salts

2,4,5-TCP is soluble only in organic solvents such as alcohol,
ether, or acetone. The sodium salt is more soluble in water but less
soluble in organic solvents. However, acne of the uses of 2,4,5-TC?
and its salts could feasibly result in their reaching water bodies frcm
industrial effluents or fron coding tower water that is not in a closed
system.

(9)

�b. TCDD
Becaus« TCDD is roUaively isaobila in soil and soluble in water
at only 0.2 ppb, the possibility of ground water contamination ia virtually Bon-«xist&lt;mt and water transport is limited (Belling et •!., 1973;
Harvey, 1973).
A rteent National Academy of Science report (1977) stated that
TCDD has cevor been detected in drinking water; the limit of detection ia
the studies cited was in the parts per trillion. The report did note the
toxLcity of TCDD and its acceptable daily intake frca water (.0001 ug/kg/
-4
day), and suggested no-adverse-effect levels (7 x 10 ug/kg/day).
'

3.

WUdlifer
a. 2.U.5-TCP and Its Salts

No studies identifying 2,4,5-TCP residues in wildlife were found.
b. TCDD

i. Terrestrial Eeesystaa
To assess the ecolcgisal importance of chlorinated dicrina, Woolson
•

et al. (1973) examined tissues of 19 bald eagles (Ealiaeetaa leueecaptalua)
collected in 15 widely separate States. Ho TCDD residues were found; the
liait of detection was 50 ppb. Because eagles are at the top of a food
chain, the authors concluded that TCDD residues from past pesticide applications were not available to *-*&lt;-t food chain.
tl« Aquatic Ecosystess

Isensee and Jones (197?) conducted an expcriaent ia which TCDD
was absorbed on three different types of soil at concentrations ranging
free 0.001-7.^5 ppa. The soil was then placed in aquatic model eccsys-

�tana. TCDD acououlated in all organisms (mosquito fish, daptnid, duckweed, catfish, and snails). The amount of accumulation was directly related to the concentration of TCDD in the water (0.05-1330 ppt). Therefore, the authors concluded that under eertadn conditions TCDD residues
oould accumulate in fish or other aquatic organism.
Zitco (1972) was unable to detect calorlnaud dibenzodioxin residues in several aquatic animals Area various locations in Canada; the
Limit of detection ma 0.01-0.04 ug/g (ppa). The author concluded that
there is no detectable contamination of food by chlorinated
ios since the species analyzed are in high trophic levels of the aquatic
food efaain and serve as good indicators of envirooaratal conuctnation by
emulative ccspounds. However, analytical methods have Improved considerably since then and scientists can now detect dioxins in the parts per
trillion.
Matsufflura and Benezat (1973) found that TCDD pickup (biological
transfer) was low in brine sbriap and fish but hlfft in scsquito larvae,
which are bottom feeders. This led them to believe that TCD is not
Likely to accumulate in aquatic systems due to TCDD 'a lew solubility in
water.
Eaufhaan aad Meselson (1973) reported the presence cf TCDD is
fish acd crustaceans taken free four locations in Vietnam. Concentrations ranged frcn 18 to 810 ppt.
4, Placts
a. 2.U.5-TC? and Its Salts
So studies identifying 2,4,5-TC? residues is plants were fouftd.-

�b. TCDD

TOO was not detected la the seeds or mature plants of soybeans
or eata sprayed with TCDD or grown on solid contaminated with 60 ppb
TCDD. The Halt of detection was laaa than 1 ppb. Researchers concluded
tbmt plants do not absorb or tranaloeata TCDD fron aoll or leavos after
foliar application (Xsoosee and Jonas, 1971; Matauoura and Berezet, 1973) •
Crosby and Hong (1977) found thmt barbicid^ formulations containing known
anoints of TCDD tb&amp;t were exposed to natural sunlight on leaves, soil,
or glass plataa lost oest or all of their TCDD during a single day. They
felt W? uaa due principally to photocneoical dectlcrination. TCDD that
la sprayed on leaf surfaces can be readily washed off (Iseosee and Jones,
1971; Helling et al., 1973; Kearney et ai., 1973).
MatauBura and Benezet (1973) concluded that any translocates of
TCDD in the enrironBest would be H«H»^« to traces of the compound »d»
bared to son particles, dispersed hy the wind, or blolcji^ally transferred in aquatic environmnts.
•

5*
a. 2^.5-TCP and Its Salts
Mo studies on t£» metabolism of 2,U,5-7C? in laboratory anlml.i
were found.
b* TCDD

TCDD is •11T*1"«»-^1 frcm biological systeea principally through
the feces but also through the urine (Allen et al., 1975; Piper et al.,
1973; Vinopal and Caaida, 1973; Kia&amp;rough, 197U).
Rose et al. (1976) detected radioactivity only in the fec&amp;s of
(125

�14
rats adninistared a single oral dose of X ug/fcg C-labeled TCDO. Liver
14
and fat contained C-TCBO concentrations over 10 tints greater than

tbOM in other tissues exaeined 22 days after inge»tion. When oral doses
14
of 0.01, 0.1, or 1 ug C-TCCD kg/day were administered for 13 weeks, the
mjor route to excretion was ar^ain via the feces, in2 the half-life of
14
the &lt;MEDD in the rsta was 33.7 days.
14
In Sprsgua-Oawlay cm intubated with C-labeled TOO, only 4.51
of the radioactivity fron a single oral dose was eliminated through the
urine in 21 days, A large percentage of the radioactivity remaining in
the body at the end of this period was in the liver and over 90% was
within the adcmsoral fraction (Allen et * . 1575).
1,
In a preliminary feyott of a two-year chronic tcodcity feeding
study, Dew Gbeadcal USA (Traynor, 1977) reported the following residue
data for rats fed indicztad TOO doses: 24,000 ppt in liver and 8,100 ppt
in fat of famalas ingasting 2,200 ppt/d«y; 5,100 ppt in liver and 1,7C3
ppt in fat of feaales ingesting 220 ppt/day; and 540 ppt in liver and
fat of fenales ingesting 22 ppt/day. The preliminary report gives no
residue data for treated males, or for control of either sex.
5. ntuiWuij
the National Huamn Henitoring Program for Pesticides is currently
sampling human urine and analyzing theue sacpla* for silvex, ?,,4,5-T,
and 2,4,5-TC? through its cooperative arrangement with the EPA Health
and Nutritional Examination Survey II (Banes II project). The survey
is scheduled for oanpleticn in 1979. Sera preliminary t*sults that relate to 2,4,5-TC? residues in the first 400 of an esti&amp;atad 7,500 sact(13)

�pies era available These results are only tentative and of court* subject to change a« further data are received.
Of the initial swsqplaa analyzed, 1*66% have shown detectable
labels of 2,4,5-TCP with a madman aaount of 32.4 ppb. The arithmetic
mean is leas than 1 ppb. In addition, 32.69% of the sanplas hsv* shown
trace Mounts (&lt; 5 ppb) of 2,4,5-TCP. Residues of «^ia ccspcund nay
also be derived from the metabolism of other pesticides and fcrtn expecure to 2,4,5-TG? that was used as a disinfectant (Kutz, 1 7 )
97.
7. Animal
a. 2,4&gt;s/-TCP and
No infonaation is available on the presence of 2,4,5-TG? residues
in anianl products, Bcwever, in tests with cattle, sheep, and calves that
were fed diets containing 2,4,5-T and allvex, residues of 2,4,5-TC? were
detected in th« kidney, liver, tajscl*, fat, and milk (dark et al. 1975;
1976T Bjerke et al. , 1972) .
b.

Mhen beef fat samples that had been fortified with 2000 ppa 2,4,5o
1C? or its sodium salt were cocked at 500 F for 6-22 hours and analyzed,
no TCDD was found in any of the sasples. Th« limit of detection was 0.05
ppa (Watts and Stotherr, 1973) .
Eighty-five saqples o£ beef fat were analyzed for TCD content
under the auspices of the EFA Dioxin Xvp.\enBntation Plan (see d1 scission
p. 20). The beef fat sasples included 18 sascles from ccntroi areas
and 67 saoples from areas previously treated with 2,4,5-T. Nona of the
18 control sarplea had detectable amount of TCTO at a detection

(14)

�of 10 ppt. Of these 67 sasplas from areas previously exposed to 2,4,5-T,
one shewed • positive TCDD Isvul of $0 ppt; 2 appeared to have TOCO at
20 ppt; and 5 may have had TOO levels which singed from 5-10 ppt. The
values for these 5 staples were at or' talow the lind.ta of detection of
10 ppt.

Forty-three beef liver samples were analyzed and showed no TOCO
residues at a detection Unit of 10 ppt*
F.

Accidental Huran Exposure

In the cases of human exposure to 2,4,5-TC?, the only adverse
effects reported were caused by occupational exposure or accidents that
rod during the manufacture of chlcrinatad phenols or producss derived £iun then*
In 1949, intersndiary chemicals of the oanufacturing prccess were
released in a U.S. 2,4,5-T plant, this accident led to 117 eases of
chlcracne aseng exposed worXars (Whitaside, 1 7 )
97.
In 1953 there was? an accident in a Middle Rhine factory manufacturing 2,4,5-TCP from 1,2,4rS-tetrachlorobenzene. In addition to contracting
chloracne (Goldman, 1972), aany workers had liver cirrhosis, heart conplaints, and nervous system disorders, and were depressed (Bauer et al.,
16)
91.
In 1953, 31 esployees of a ganturg, Geraany, plant in which 2,4,5-7
wes made from technical 2,4,5-TC? contracted chlcracne and suffered the
physical and psychological syr^tons associated with it (Poland et al.,
1971). In 1961 Bauer et al. conclusively identified TCCO as the cause
of the chloracne.

(15)

�An explosion occurred in a 2,4,5-T plant in Aaaterism in 1963.
Six Months later, nine of the 18 &amp;en, who were attesting to cacontacinate the plant, developed chloracne. All of the nen had worn deep sea
diving suits* and all but one wore face soaks with goggles while working
in the plant. Of these nan, three died within 2 years. Tha nan without
the face mask or goggles was severely affected. Be was unable to walk
and is still undergoing treatment (Whitaside, 1 7 )
97.
In 1964, workers in a 2,4,5-T plant in the United States developed
chtocacne from exposure to TCXD (Poland et al., 1 7 )
91.
there was an explosion at the Coalite Ccacany's 2,4,5-TC? plant
in Great Britain in 1968. TCCD had aceidently been produced as the result of an exothermic reaction (Milnes, 1971; May, 1973). Seventy-nine
cases of chloracne were cayottad; many of then were severe.
In 1971 there was an accidental poisoning episcxw L* «!*« United
States that affected humans, horses, and other anisals. Waste oil contaminated with TCCD had baen sprayed on a riding arena to control dust..
Later analyses shewed that the arena contained TOT in concentrations
of 31.8 to 33.0 ug/g (Carter et al., 1975). Gaorener and Scott (1976)
found that the most irportant route of entry of dicxin into the body
was the skin. (This dees not preclude the effects of ingesting food
contaminated with dioxin from handling.) A 6-year-old girl was the
aost severely affected. She had an inflammatory reaction of the kidneys and bladder bleeding fiat was diagncsed as acute heocrrhagic cystitis with signs of focal pyelonephritis. Hisa less severely affected
persons developed diarrhea, headaches, nausea, polyarthralgias, and

(16)

�persistent akin lesions ( . . EPA, 1975). The girl moat affected was
US
thoroughly reexamined in 1976. Results indicated that all of her artginal symptom hai* completely disappeared. She had grown normally and
all tests, including a detailed neurological examination, were normal
(Beale et al., 1 7 )
97.
In July 1976, 2-10 pounds of TCDO were accidentally released in
the Seveso Region of Italy (Devse, 1 7 ) Host of the inhabitants were
96.
adversely affected. Seputia of immediate symptom atd indications of
ootiy long-term effects are just becoming available. The first overt reaction was the appearance of nunnrous burn-like lesions on many of the
inhabitants, These lesions generally receded. Whiteside ( 9 7 believes
17)
that they were probably caused by direct contact with the sodium hydroxide
and phenolic ceepcnents in the fallout. However, 2 1/2 months after the
explosion, an increasing number "it children and young pecnl* in the zone
nest affected began to develop synptoss of chlcrae-* on their faces and
bodies, a definite made of diootin poisoning. By Novecber 23 people had
of chloracne. This number rose to 38 by Decestoer and to
130 a year after the explosion. A nutcber of the victims exposed underwent a "ccrolcte change of character*; they became extremely nervous,
tired, needy, and irritable, and had a oaxfeed loss of appetite.
There were a *»ffl*j*r of Seveso woman who were pregnant at the tine
of the accident. Whiteside ( 9 7 reported that the total number of
17)
legal and illegal abortions performed as a result of the explosion preferably totaled 90. There were 51 spontaneous (as distinct from induced)
abortions. A survey conducted by an epideaiological comnissicr. has shewn

(17)

�that 183 babiaa ware delivered in the 2 Earths following the accident,
Eight cues of birth abnoatilitias have been noted anong babies born to
woman in the Sevuo area who were pregnant aft the tin* of the explosion.
However, Innil physicians have had,,difficulty relating those abnonaalities directly to the explosion because the incidence of birth abnormalities was not significantly higher than the nonanl incidence of abnormal
births (Whitsside, 1 7 )
97.
H. Regulatory History
The regulation of many polychlorinated ring compounds. has been
related to the presence of TOD as a contaminant in the '»'™»K't*\ product. Historically, regulation has focused on 2,4,5-7.
In October 1969, Bionetics Research Laboratory, a contractor for
the Rational Cancer Institute, released information on their large scale
screening of a nuaber of pesticides and industrial chemicals for nutaganicity, caurcinogenicity, and teratogenicLty. They found 2,4,5-7 to
be taratogenic in nice when 113 tna/lcg body weight was administered during early pregnancy. Birth defects included cleft palates and cystic
kidneys. On later examination researchers ascertained that the 2,4,5-T
was contaminated with apptuxlaately 30 ppm TCDD. This and other scientific studies suBcarized in this Section are fully discussed in Sections
XU and 1 .
7

On October 29, 1965, the President's Science Adviser responded
to the release of the Bionetics' rqxu.S. by announcing that a series cf
coordinated actions would be taken by several government agencies to restrict the use of the herbicide 2,4,5-T.

(IB)

�In early 1970, aniaal experiments confirrad that when the purest
«vau'&lt;*ble 2,4,5-T, which contained leas than 0.05 pern TODQ, was fed to
pregnant mica in large doses, the offspring would be malformed (Courtney
and Koore, 1971).
On April 15, 1970, the Secretaries of Agriculture; Eealth, Education and Welfare; &amp;nd Interior announced the suspension of the following
registrations of 2,4,5-T: all uses in lakes, ponds, or ditch banks; and
liquid femulations for use arcond the hone, recreational areas, and similar sites (USDA-PRD PR 70*1, April 20, 1970). A notice of cancellation of
•

registration was issued on Hay 1, 1970, for all granular 2,4,5-7 forsulaticns for use around the hone, recreational arena, and sisdlar sites, and
all 2,4,5-T uses en crops intended for huean consunpticn (USDA-PRD PR 7013, May 1, 1970).
On Septantcr 23, 1570, the Department of Agriculture issued a
Pesticide Registration notice stating that all products containing TCT
were in violation of FXE3&amp; because they constituted a possible hazard to
humans. Th* notice indicated that appropriate regulatory acticn would
be taken if TOO were found in any econcadc poison (USDA-PFD PR 70-22,
September 28, 1970).
On May 5, 1971, the Report of the Advisory Comittee to the S?A
Administrator reccseanded that use of 2,4,5-T be peraitted only under
certain conditions in forests, ranges, and righta-of-way providing:
1) that a limt of 0.1 pern TCDD be set for all future
production of 2,4,5-T;
2) that 2,4,5-7 be applied no acre than once a year

(19)

�at any one site; and
3) that 2,4,5-T be applied with caution so it will
not contaninate other areas where It may cone
•

into human contact.

.

«

•

. , - . . . ' '„•/ - - . - • • •

In July 1972 Dm Chemical Company obtained an injunction against
EPA. The Court of Appeals for the 8th Circuit overturned this injunc- '
tion in 1S73. EPA withdrew cancellation and information gathering proceedings initiated against 2 4 5 T and related oajgiamJs on June 24, 1974,
,,due to the Agency's inability to monitor food for residues of TCDD with
the necessary analytical precision.

'

In July 1974 EPA held a Dioxin Planning Conference in Washington,
D.C. Participants of the public meeting discussed data analysis, analytical methodology, toxicology, and acnitoring. There was an emphasis on developing analytical methodology for detecting TCDD in parts per trillion.
As a result, the Agency promulgated the Pinrin Implementation Plan (DIP) to identify a preferable analytical method to monitor human and environmental samples for TCDD residues in tb« low parts psr trillion (ppt) range.
*

DIP consisted of a short-tarn monitoring ptojidiu involving beef fat
and liver samples and a broad 2- to 5-year research plan. The Environmental Defense Pund, the Departmssnt of Agriculture, and Dew Chemical Ceapany participated in the monitoring program, which utilized iaproved analytical methodology capable of detecting TCDD in the parts per trillion
range.

. ' .

. " .' .

.

' ' ..

- •

On-going TCDD studies under the DIP include: an analytical method
validation study to produce statistically defensible data; monitoring for

(20)

�residues in human milk in the Pacific Northwest; additional beef fat residue studies; additional technical pesticide residue studies; and an «nvinaraasntai monitoring program for TQ3D residues in soil* water/ and biota.
IH. Sunggry of Scientific_ Evident RelatJjrvg to Retauttable Presumption
A. Cneogenie Effects in Test Animals
40 OR Section 1 2 1 ( ) ( ) U ( ) provides that a rebuttabl* pre6.1a 3()A
•waption shall arise if a pesticide's ingredient(s), aetabolite(s}, or .
degradation product ( ) . induces oncsgenic effects in experimental mans..
na 1,inn species or in man as a result of oral, inhalation or dermal exposure...* Section 162.3(bb) defines the tarn oncaganie as "the property
of a substance or a mixture of substances to produce or induce benign or
malignant tuner fewaticn in living animals."
1. 2,4,5-*CP
Because all 2,4,5-TC? contains a certain accunt of TCED, any reference to 2,4,5-TC? denotes a product that is contaminated. As a result,
all the information used to assess 2,4,5-TC? in relation to Section 162.11
risk criteria is derived frcn studies in which the test substance was
2,4,5-TCP contaminated with TCED. The Agency Knows of no data relating
to pure 2,4,5-TC?.
The National Cancer Institute tested 2,4,5-TC? for carcincgeniciry
(Znnes et al., 1369). Two hybrid strain of mice [(C57BL/&amp;x£2H/Anf)F and
1
(G57BL/6xAKR)F I were given a single subcutaneous injection of 1000 rrn/
1
Jcg 2,4,5-TCPAg ( 7 pure, contaminant not specified) in corn oil when
9%
the mice were approximately 28 days old. Mo significant difference in
tumor frequency was found between the 2,4,5-TC? treated groups and the
control mice at necrccsy.
(21)

�In a short-term study on BHC (benzene bexachloride} iscmers and
their metabolites including 2,4,5-TCP, Goto en al. (1972) fed twenty
5-veek-old mala XCEKfCL mice a diet containing 600 ppra 2,4,5-TQP (contaminant in 2,4,5-TCP not specified) each day for 6 months. They observed no unusual weight increases in the hearts, kidneys, or livers of
treated ode* as compared to the controls. No tumors were noted in the
nice fed 2,4,5-TCP although malignant and benign tumors were noted in
the livers of mice fed technical BHC, alpha-BHC, beta-SBC, and gacma-ac.
The EPA Carcinogen Assessment Group (QG) judged these studies
inadequate for assessing the cncscenic potential of 2,4,5-TC?. The
Noticing Group concurs.
2.

TCP

a. Van Miller Study
A recent pe?«r by Van Miller et al. (1977) reports the results of
a 2-year feeding study with Sprague—-awley rats. Groups cf 10 rats were
administered a diet containing TCZD in one of the following csncentra-12
ticns: 0, lf 5, 50, and 500 parts per trillion (ppt, 10 g TCSD/g food),
-9
and 1, 5, 50, 500, or 1000 parts per billion (ppb, 10 g TCD/g food).
LaparotCBdes were perf orsad on all surviving rats during the 65th
week. Biopsies were performed fran all tumors observed. Rats were maintained on the diet for 78 weeks and w-re then placed on the control diet.
Surviving rats were killed at 95 vwecs. Complete necropsies were done
at this time and tissue samples wers mcrcscspically examined. Special
staining methods were used as an "aid in the diagnosis of neoplasms."
Food intake was significantly lower in rats that ingested SO, 500,

'22:

�or 1000 ODD TCDD than U was in the control animals. AH of the rats
administered these doses died between the second and fourth weeks of
treatment.
At the sublethal doses, there were,toxic and tuoorigenie effects.
Three of the 10 deaths which occurred in the 5 ppb dose group were at*
tributed to aplastic anemia. One aninal in the 500 pot group had severe
liver infarction. The overall incidence of neoolasras in the six experimental grouos was 381 (23/60), compared with no lesions or 01 (0/10) in
the control group. This difference is statistically significant.

Neo-

plastic nodules and cholangiocarci nomas of the liver were observed in 4
of 10 rats (40?) that ingested 3 ppb TCDD (two animals had both neoolastic
plastic nodules of the liver and cholangiocarcinomas). One rat, (101)
in the grouo that ingested 1 ppb had a carcinoma compared to none of
the controls. Heoatic tumors were not found in rats administered the
other doses (Table 1).
I/
TABLE 1. Liver tumors in rats that ingested TCDD"

Rats With
Neoolastic
Modules
No. *

Rats with

0

0/10 0

0/10 0

0/10 0

1

0/10 0

1/10 10
2/
2/10 20~

1/10 10
2/
4/10 40~

Dose, oob

5
I/
?/
~"

4/10

2/
40"

Cholangiocarci nomas
NO.

*

Rats With

Nodules plus

Carcinomas
No. "•

Data from Van Miller (1977).
Two animals had both neoolastic nodules of the liver and
cholangiocarci nomas.

(23)

�Benign and wlignant tuners developed in rats ttiat ingested 5,
50, or 500 ppt and 1 or 5 ppb TCDD, ccq»ared to none in ttva control rats.
Twentytfajree of the rats (46%) in these 5 groups had tuners. Nineteen
of these tats (57%) that died in die 6 groups fed subecute level* of
TCDD bad nedplastic alterations. Three rats that ingested 5 p$b died
of aplastic anemia.. Caretncins were observed in the ear duct, kidney,
and liver. Three retrqperitoneal histiocytcnas were described as netastasizing to the lungs, kidney, liver, and skeletal nuscul&amp;ture. Statistically significant increasea in tuners at all sites were found in the
rats fed 5, 50, 500, 1000, and 5000 ppt as ccceared with the central animals (p • 0.05) (Table 2).
b. Preliminary Reuort: Dow Chfnienl Caneanv Studv
The Dew Chemical Coopany has just ceopleted a chronic toxidty
study of TCED with 472 Sprague-Cwley rats (Traynor, 1 7 ) Fifty rats
97.
of each sex were maintained for 2 years on diets which contained 0.001,
0.01, and 0.1 ug TCSVkg body weicht/day. This dose is equivalent to
approximately 22, 210, and 2,200 =pt in the diet. Eighty-six rats of
each sex were maintained on a central diet. Table 3 lists the tuners
found.
c. Conclusion
The Working Group has concluded that there is evidence to indicate that TCXD can produce cncogenic effects in rats. Since 2,4,5-TC?
contains TCOD (at a nuxirun areunt of 0.099 pent), a rebuttable presunrtion against the registration of 2,4,5-TC? products has arisen because
of the cnceeenic effects of its ccnczstLrant, TCTC.

(24)

�/

T&amp;8LE 2. Benign andrmalignant .tamer* in rata that ingested TCDD"

Dose

y

Ho. Turoca

Benign

'—

Malign*.re Total

0

0

0

Ippt

0

0

Sppt

1

50 ppt

Rata with T

No.

0

0/10 0

0

0/10 0

5

6

5/10 50

2

1

3

3/10 30

500 ppt

2

2

4

4/10

Ippb

0

5

5

4/10 40

Sffb

8

2

10

7/10

3/
4/
T/
J/

7/
8/
S/

1

40

70

Data from Van Miller (1977).
Rats administered 50, 500, and 1000 peb were all dead within 4 weeks.
Fore? mala rats that were ua«d aa controls for anotbar study w«n recaivssd at th« sane tic* a* tha cats in this study and kapt under identical conditions. "Sxty did not haw nacplasat whan '*il'«" at 18 nonths.
BITM rata di«d of aplastic anastia.
Gm rat had scror* livar infarction.
Ona cat had an car duct cardncm and lynphccytic laulcaaia.
Ona rat had an adanacareinaBfli (kidnay).
Cm cat had a malignant histioe/tona (ratroparitonoal).
Ona rat had an angicoarcstn (skin).
CM rat had e Laydig call adtncoa (tastis).
Qna rat had a fiibroaavcani (nuscla).
CM r?it had a aquanous call tumor (skin).
OnC' rat had an astirouytcca (brain).
Or« rat had a fibroma (striated nuscle).
Cna rat had a careinam (skin).
One rat had an adenocarcincaa (kidney).
One rat had a sclerosing sacdncna (testis).
One rat had a cholangiocareinoaa and malignant histiocytoaas (retroperitoneal).
Cna rat had an angiosaroana (skin).
One rat had a glictxUstcca (brain).
One rat had a nalignant histiocytona (retrcceritsneal).
One rat had a squancus call tuner (lung) and a nccoXastic nodule (liv«r),
TWO rats had cholanqioaurcinanas and necplastic nodules (liver).
Three rats had squanous cell tucora (lung).
One had a necplastic nodule.

(25)

�3. Tuners in SprsgueHJewuey rats that intmted TCCP

Dose, pet

x-"'

0

0

22

0

210

Bepatoctnnlar Modules

&amp;

Squaaous Call Carcinana
Alveolar flyperplasis

3/
Squatnous Cell Carcinoma

2,200

I/

Data from the pgnHnrinary report of tfa« Dew Cbndcal Conpany Stucy,
1377.

2/ Bardjsalat* squaeous dsll cardnams WKPB obscrTvd Ln one fanale rat.
3/ Squaoous coil cardncBU wct« obaKrvod in th« lung/ bart^alate/nasal
turSlnatas, or tongu*.

B. y»totg»ie arri_?arateg&gt;gue___Egftcas in Maeralian Soteiaa
40 CFR 162.n(a)(3)(ii)(B) provides that a rttbuttabl*
tion shall arise if a pesticide's ingredients "...(p)roducea any other
chronic or delayed toxic effect in test animals at any dosage up to a
lev*!, as determined, by the Administrator, which is substantially higher
than that to vni.ch humans can reasonably be anticipated to be exposed,
talcing into account arple margins of safety.*
Drteyotoxic effects are considered to denote all transient cr
n*nt taodc effects induced in an entryo or fetus, regardless of
the nechzm-lta of ^action. Ciese effects include teratceenicity, nertal-

(26)

�,*__

�2. TCDD

A number of studies on the embryotoxicity of TCDD indicate that
there are two major types of toratogenic effects generally associated
with teat animal a receiving doses of TCDD during pregnancy: cleft palates in nice and Iddaay anomalies in rats and nice. TCDD is also fetotoxic in these species.
a. Hice
The first evidence that TCDD night represent a reproductive hazard
to humnn appeared in 1970 in a Bionetica Research Institute study which
reported that 2,4,5-T was teratogenic (Courtney et al.t 1970). When a dosage of 113 ng/kg 2,4,5-T was administered to AK nice on days 6 to 15 of
pregnancy, 49} of the fetuses were deforced. Cleft palates, cystic kidneys, and fetal mortality were the cannon anomalies found. However, analysis using gas chromatcgraphy later showed that the 2,4,5-T used in the
Sianetics study was contaminated with 27 * 8 ppm TCDD. The question of
whether dioxin rather than 2,4,5-T caused these adverse effects was raised.
Courtney and Moore (1971) studied the enbryotoxic and teratcgenic
effects of TCDD in three strains cf pregnant nice (Table 5). Test aniaala
were administered 1 and 3 ug TCDD/kg body weight sutcatanecusly in solutions of 100% DMSO (dimethylaulfoxide) an days 6-15 of gestation. DMSC
was administered as the control. TCDD produced cleft palates in all three
strains of mice. In the CD-1 nice 305 of the litters (3/10) had fetuses
witt cleft palates at 3 ug/kg as compared to 05 of the controls (0/9).
Seventy-one percent cf the litters cf C5731/6 mice (5/7) had cleft palates
at 3 ug/jcg iccy weight as copared t&amp; CS (0/23) of tne ccntrcis. Twenty-

�two percent ( / liters) of the DBA/2 nice also bad cleft palates at this
29
sane dosage as compared to OJ ( / 3 of the controls. The authors also
02)
found a marked iocrtase in the incidence of IcLtaey anomalies in all mice
atralas (Table 5 . There was a dose-related response in the CD-1 mice.
)
One strain of inbred mice, C57B1/6, which was'especially sensitive, developed kidney anomalies in all seven 0 0 ) of the litters as compared to
0}
9J ( / 3 in the controls. Although TCDD produced a significant increase
22)
in the ratio of maternal liver weight to body weight in the inbred nice
strains (C57B1/6 and DBA/?/, the CD-I (randomly bred) mice were not significantly affected. TCDD had no effect on fetal mortality, fetal
weights, or maternal weights at the doses administered.
In another study in which six dicxlns were administered subcutaneous! y and orally to CD-1 mice, Courtney (1976) found TCSD to be the
scat fetotoxic and teratogenic by either route of exposure at all dose
levels tasted. On days 7-16 of gestation, TCDD was adaiaistared orally
at 2S-WO ug/kg/body weight and subcutaneously at 25-200 ug/lcg/bcdy
weight. The results are given in Table 6.
Mortality per litter increased with the dose and reached 97* (cral)
and 76S (subcutaneous) in the litters administered TCDD, as compared with
a mortality of 6 and 14*. in the oral and subcutaneous control groups, respectively. The most common anomalies observed were cleft palates and
malformed kidneys. All cf the fetuses in the 200 and 40C ug/kg (cral)
and 200 ug/kg (subcutaneous) groups exhibited cleft palates as cccpared
to 0* af the controls. Cf the fetuses in the 200 ug/kg (oral) group,
?CC* had Idiney salfunctises as cczparad to '* of the controls. Other
(9
2)

�M

TAIH.fi 5.

Smannry of the teratogenlg effects of TCDD In mice and rata

Dose,
Strain

ug/kg

l.lttera Affected/
Live Llttera
Cleft Palate
Kidney Anomalies
No.
No.
\
*

Average Fetuses
Affected/Live Llttera
Kidney Anomalies
Cleft Palate
No.
No.
%
i

NICE
CIM

DHA/2
C5701/6

0 (DHSO) 0/9
1
1/9
3/10
3

0
11
30

3/9
5/9
10/10

0 (DHSO) 0/23
3
2/29

0
22

0 (DHSO) 0/23
5/7
3

0
71

0
22

100

0/9
2/9
1/10

to

1/9
169
./
6.5/10

11
51
65

3/23
8/9

13
69

0/23
1/9

0
11

1/23
1.8/9

*
20

2/23
7/7

9
100

0/23
267
./

0

37

1/23
3/7

13

0/9
0/6

0
0

33
56

4

RATS

CD

0 (DHSO) 0/9
0/6
05
.

0
0

0/9
1/6

0
67

J/ Data frou Courtney and Moore (1971).

(30)

0/9
1.8/6

0
30

�I/

TABLE 6. Fetotoxio and teratogenJo effeota of TCDO in CD-I nice"

Dose,
ug/kg/day

Abncraal Ancaalies/Total Fetuses
Average Fetal Average No.
Route of Ad- hortality/
Abnoroal
Cleft
Kidney Ano- Club
ministration l.ltter, £
Fotusea/Lltter Palate, % nalies, %
Foot, %

25
50
100
200
400

oral
oral
oral
oral
oral

6
13
11
87
97

25
50
100
200

subcutaneous
subcutaneous
subcutaneous
subcutaneous

36
56
72

5% antsole
com oil

oral

1.6
8.1

8.3
1.5

3
19
66
100

subcutaneous

3
7
13
11

01
.

too

100
50

6.7

53
58
95
38

17

1

j,

76

3.5
3.1

82
79
85
100

6

0.8

0

11

0.2

0

50
.

( . ml)
01
WISO

3*
72
71

I/ Data froa Courtney (1976).
?/ ItttSO = dimethylsulfoxlde

(31)

50
11
0
18

�anomalies observed ware bydrccepbalus, open «ye, and club foot. Edema
and patachlae were also observed in f«tus«s administered the high doses*
Responses appeared to be dose-related. Subcutan*cus injection produced
greater responses than did oral administration.
Moore et al. (1973) tlso found that TCDO caused fetotoxio and teratogenic rtspotties in C57B1/6 nice at a dose level as low as 1 ug/kg administered on days 10 through 13 of gestation. Compared with C% incidence (0/27} in the control litters, W (15/16) of the treated litters
exhibited kidney anomalies and 195 (3/16) had cleft palates. At 3 ug/'/cg
the tnrlrttnra of thes« ancmalies ma 1005 (U/1U) and 365 (12/TO, respectively.
Keubert and Dillcann (1972) tasted the ambryotosic and teratcgenic
effects of TOD in NMHI mice. In one test pregnant mice wore given varying doses of TCDO (0.3~9 ug/kg) by intubation on da/s 6-15 of gestation.
Results are shown in Table 7. Very high eabryomoruiity was observed, as
expressed by the percent of fruitful wcmfas shawiMg evidence of resorptions.
At 9 ug/kg, all viable litters (3/3) evidenced i-esorptions; 675 (6/9) cf
all litters bad total reserptions. Oil control values war« 32 and 05
for litters with resorptions and litters with total resorptions, rsspectiveJLy. Cleft palate was observed in all of the litters and 825 of the
fetuses at 9 ug/kg; comparable oil control vaiuis were 6 and 0.75, respectively. Statistically significant (p &lt; 0.01) proportions of the fetuses evidenced cleft palate at 3, *.5, and 9 u^/kg (3, 13, and 825, respectively) when compared with the oil control.
In another test in which high doses of TC2D wers given orally or. a

(32)

�TABLE 7. &amp;tbfwtMo_aBd_taratcg«ale affects of TCDD on NMHI alee
2/

DOM,""
us/kg
0
Oil
0.3
3.0
4.5
9.0
90
.*

Litters Affected/Viable Litters
Hesorptions
Cleft Palate
Ho.

2

No.

"1

23/95

24

6

21/65

32

7/13
16/24

54
67

6/95
4/65
0/13
7/24

5/12

42

6/12

50

3/3

100

100

3/6

50

3/3
5/6

6
0
29

. 83

1/ Data, froa Seunert and DJ
I (92.
17)
2V Dose adaiaistered on days 6-15.
J/ Dose adoiniatered on days 9-13.
day of gtstation, Heubert and Dillaann (1972) observed tba same
type of effects on eaiapynaertality and the incidence of cleft palate. Tie
autfcars adndclaterad 23 and 45 ug/kg TCDD on day 6. The nay1,im,an effect
on mortality (reaorption in 100} of t£&gt; riabie litters) waa seen in the
oice administered 45 ug/icg. tbe highest Incidence of daft palate (71*
of viable litters) was noted at 45 ug/kg on day 11. Control values were
24} for litters with rescrpticn and 6} for litters with cleft palates.
Sodtn et al. (1976) studied the teratagenicity of TCDD la. C7-1
sice. Dosages of O.C01, C.01, 0.1, 1, ace! 3 ug TC2D/kg bcdy wnigst/cay

(23) '

�were administered by gavage on days 6 through 15 of gestation. The percentage of resolutions per iaplantation was significantly higher than It
vita in the controls only in the 1 ug/kg group. The incidence of daft
palates in tta 1 and 3 us/kg dose groups was significantly higher tfcan
it VMS in the controls (Table 8). At 3 ug/kg there was also a significantly greater incidence of litters that had fetuses with bilateral dilated renal pelvlses than there was in the controls. The authors concluded that the no-effect level for taratogenic effects from TCDO was
0.1 ug/kg/d&amp;y.
Neubert et al. (1973) found that TCDO was highly embryocoxie and
fetotoxic in nice, extrapolating from a dose-response curve, they estimated the E33 for cleft palate in fetuses was 40 ug/kg/day. The co50
effect level during days 6 to 15 of gestation was estimated to be 2 ug/
kg/day for NHRZ mice. No pronounced fetal mortality was observed vtsen
3 ug TCDD/kg body weight was adoisistered on days 6-15 of pregnancy
(Table 9);
b. Rats
Sparschu et al. (1971) studied the teratogsnicity of TCCC in
Sprague-Cawley rats. TOD was administered orally in concentrations of
0.03, 0.125, 0.5, 2, and 8 ug/kg/day on days 6-15 of gestation. _ There
was a high incidence of fetal mortality. At 8 ug/kg/day all fetuses
(100?) were resorted as compared to 63/309 (20%) in the controls. Fetal
weights were depressed in the 0.125, 0.5, and 2 ug/kg/day groups. The
occurrence of this effect was statistically significant in all groups
except the females administered 0.5 ug/kg. Most of the abnormalities
*T

�_$/
TABLE 8. getptoKJo and toratOBgnto effeota of TCDp in CP-1 Hloa"

Dose,
ton/kg

Incidence. of Cleft
Palate in Litters/Live
Llttora
too.
*

Lit tens with
Reaorbed Fetuaea/
Live Litters
No.
I

0

0/34

0

25/34

74

0/34

0

001
.0

2/41

5

30/41

73

0/41

0

0.01

0/19

0

17/19

89

0/19

0

01
.

1/17

6

16/17

94

0/17

0

21
21
21

16/19

95

1/19

11/14

78

4/14

1.0

4/19

3.0

10/14

Utters with Dilated
Renal Pelviaaa/Liva
Littera
%
No,

x

5

aT7

I/ Data from Saith et al. (1976).
?/ Statistically different from the control by the Fishera exact probability teat (p &lt; 0.05

(35)

�TABLE 9. Occurrence of cleft palate in offspring of mice fed TCDD

Str*m

CD-I

DBA
NMRI
C57B1

Dose,

ug/lcg
0
3
0
3
0
3
0
3

Cleft Palates/Total
Fetuses Examined, %

&lt; 0.3
3
&lt;1
4

0.7

3
&lt; 1
22

Affected Litters/
Total Litters
NO.
%

0/29

0

3/10

30

0/23

2/9

0
22

10/160
7/2U

6
29

0/23
5/7

0
71

I/ Data, from Keubert et al. ( 9 3 .
17)

noted were intestinal benorrtagea. No adverse effects were noted in the
fetuses whose mothers were fed 0 0 ug/kg/day. Table 10 sbows the dose/
.3
response relatiocship. The authors concluded that TC3D induced a high
level of maternal and fetal toxicity and that 0.03 ug/kg/day vaa the noeffect level for fetal and embryotoxic effects in rats.
Khera and Huddick (1973) studied the effect of TCDD on reproduction in Vistar rats. In tha first test, rats were orally administered
0.125-1 ug TCDD/kg on days 6-15 of gestation. Observations of visceral
lesions showed a dose-response relationship at 0 2 ug/Vcg and above;
.5
slight decreases in fetal weight were also seen (Table 11). Postnatal
effects of prenatal exposure to TCDD were studied by allowing offspring

(36)

�10. Intestinal hemorrhages In offsprin

of Sraue-Dawley rats fed TOD*

—
Doa*,
ug/k$/day

Fetuses Affected/ • Liters Affected/
Fetuses Examined - Litters Exanined
%
No.
i
NO.

Q (control)

0/246

0.03

0/115

0.125
0.5
20
.

0
0

0/24

0

0/10

0

18/127

14

7/10

70

36/99
4/7

36
57

10/12

83

2/4

50

8.0

-

-

.

-

V Data frcn Scarschu et al. (1971).

of treated data to bo roared by untreated dams until waning. Reduced
survival, body waigbt, and reproductive ability in tba progeny were observed after tfca notters were treated with 0.5 and 1.0 us/kg. Ho fa totoxic effects were observed at 0.125 ug/kg.
la a second experiment rats were treated orally with 1-16 ug TCDD/
kg body weight/day on days 6-15 of gnstation. ' Doses of U ug/kg of Qors
producod maternal torLcity and 100% eabrycesartalitr/. Fetal weight, nunbar- of live fetuses per litter, and incidence of visceral lesions were
all adversely affected by treatment. The incidence of skeletal anon 1! a*
was comparable to that in the controls at all dcse levels testad. The
authors concluded that oral treatsent of pragnant Wlstar rats with 0.25
ug (or aore)/kg/day on days 6-15 of gestation results in adverse effects

�BU&amp; i i.

i«rTBl.OPRn.lC BJ:itrcta

ATeraga Ho.
Liva Fatuaaa/
__ Ltttar

Dosa,
us/Teg

01 iuuu in NUT•*r rats

Fatusaa with
Sctlatal Anomalita/
Total No. Examined

Av*rag«
Fatal
Wai£btv S

No.
TEST T

Fatusas with Microaocpic ViscenL Lasiooa/
Total No. Examined

J

No.

%

Dntraatad
Control

lfl.7

4.82

5/107

5

0/13

0

Control

11.0

4.51

21/116

18

o/u

0

0.125

10.6

4.64

3/121

2

0/38

0

0.25

10.9

4.79

6/109

6

1/33

3

0.5

10.5

4.46

10/105

10

3/31

10

1.0

9.3

4.10

6/81

7

3/10

30

7

0/10

0

y

.

T£5T II

Untreated
Control

11.5

4.68

Treatad""
Control

9.8

4.77

9/09

10

0/10

0

1.0

6.5

4.17

7/80

9

3/6

50

2.0

6.0

3.31

7/57

12

3/7

43

4,0

0

-

-

-

8.0

0

-

-

-

16.0

0

-

-

-

y

8/116
*

I/ Data from Khara and Rudclick ( 9 3 .
17)
?/ Anisola - corn oil.

(28)

�en cat develfifxdent.
Courtney and Moore (1971) studied the teratogenicity and anbryotoslcity of TOO in CD cats. TCDO was fldndnitftared stibcutanecusly in
solutions of 100% CK50 on days 6-15 of gestation. DSHD was adsdnistarad
-w tbr control. Kidney anmaUaa were found in four of the six Utters

($7%) whose dan wore administarad 0.5 ogAg as coopered to Ot (0/9) in
tha controls* Results also shewed that TCQD did not causa an incraasa
in fatal mortality, fatal weight, or cleft palatas in tha fatusas. Tibia
5 sunorizas tha results of tha study.
Dow Qiendcal QSA (Traynor, 19T7) eenducxsd a thpaa ganataduai raproductiTw study OB Spragua-Dawlay cats continuously fad tha aquivalant of
0.001, 0.01, cc 0.1 ug TCDD/Tcg/day. A pealindnary caport dtas caducad
fartility and littar survival in f cats as tha raascns for discontinuing
0
-tha 0^ ugAg dcaa Lwalj significantly caducad fertility was also cbMrvad at 0.01 ug/fcg. "Claarly erLcJant" indications of todLcity at 0.01
ugA? ananq f and £ lifetsrs, included «"•"•*• littar size at birth, plus
2
3

dacsaaaad survival and growth of nacnatas. Dilated canal pelvis was ob-

served in each of tha three f cats at 0.1 ug/kg which survived to adult1
need. Incraaiwd frequency of this anosaly was also seen acong weanlings
at lever doseat howweir, a dose-related or generational cacralaticn could
not be nuta. in sunnaxy, Qow concluded that "the reproductive capacity
of cats ingesting TCDD was clearly affected at dose levels of 0.01 and
0.1 ugAg per day, but not at 0.001 ugAg par day, through three successive generations." The preliminary ntpcrt did not include the nuoerical
data necessary for Agency cvaluaticn. Analysis will continue as these
available.
(35)

�In aunauy, atudiaa how astabliahad that TCED in fietotoxLc and
tacatoganie at dQaas aa low m 0.2S uqAq in tha rat {Xhara and Ruddidc,
1973) and at 0.3 ug/k&lt;3 in th* sous* (Ncubaet and BiiiBam, 1972). Tabla
12 lists th« no-*ff act lav«la £cr taxmtogjanicLty in tuba and aioa fiecm
1CDO. Ho tatotoaiie or taxatoganic affacta haw bean obaarvad at doaaa
ofi 0.03 aq/log in tats (Sparxlm «t aJL , 1971) and 0.1 ug/kq In ode*
(Sadtfa, 1976).
c. Chicic Etabtyoa

Bui Hoi «t al. (1971) aatablishad that 0.02 ugAq TCED causad
Laiau^jmiic affacts in chid? artacyca. Bowaa at al. (1973) and Vatratt
(1970) oonfiioBBd thair nwults. TSjay found abnotamlitiaa in tha baaks,
ayaa, and faat of chide
12. Summary of jronrff act, leromla for turataganaais ftrem 2,3,7f 8-T
Soadm

Routa of
Adainistrsti.cn

""^SS/daT^'

Rat
Heum
Ran

SC

sc

&lt; 0.2
&lt; 1.0

Oral

0.125

Rat

Oral

0.03

tiaubatt and DilLnan
(1972)

MOUM

Oral

&lt; 0.3

Smith at al.
(1976)

Housa

Oral

0.1

lijjj^j%^Fl*mBai&gt; •^••jj^ ^•nnv^B

(1971)

Xhan And Ruddidc
(1971)
Spatschu at aJL.
(1971)

SC • Subcutanaeusly
(40)

�3. Pj^panre Analysis
Zn order to datannine whether a rebuttafaie presuBXJtion should be
inuad based on reproaucti-ow and fetotoxic effects, pursuant to Section
162.U(a)(3)(UHB), the Mocking Group nat determine whether or not an
asple amrqdr. of satat. exists batman th« levels of 2,4,5-TCP or ita
salts and/or TCCD which produce reproductive and fatotoxic effects* and
thai l«vel(s) to which that pnpuljtim at risk (wocan of child-bearing
age) on tmasonably ba anticipatad to b* aaeposad.
Social changaa ewer the list few yeaxaf however, have giwi
M
*

wonn the opportunity for aBploynent in axeaa) that were once considered
open only to nan. Since wonan of child-bearing age are new employed
in all types of occupations, they have beoane part of the pnpnlatlcn
«t risk with potaRtisl exposure to 2,4,5-TO», its salts and/or TOD.
Zn ociiet" to deteodne whether an aople nsrgin of safety fixists,
the Worfcing Group oust first dstaxaine hew auch 2,4,5-TC5 (or salts) &amp;
weasm guild be exposed to. Both inhalaticn and desnal exposure routes
•
were exsBine*i«
Fear each of these analyses, the Working Group assumes a woman
to weigh 6C kg. de following calcuLiticns are based on an exposure
analysis for 2,4,5-TCP, its salts and TCD perfCEaMd by EPA's Criteria
and Evaluation Olvislcn.
For purposes of this oialysis, the Working Group ccnsidered
currently registered uses where the possibility of exposure to 2,4,5TC?, its salts and/or TOO existed.
Large quantities of 2,4,S-TC? and its sodiua and potassium salts
(41)

�arc used in industrial and otbar navHwjriailturil pesticide forsulatians
for controlling bacteria and fungi. The following industries ara tha
largest UMts of forflulated products containing 2,4,5-TCP and its
and potMsiuB salts* axil ing towers; papar and pulp ««4U nystaa*;
and leather processing; adscallanaous industrial and institutional uses,
disinfactant UM.
To « Large extant most of the above industries use the sodivan salt
of 2,4,5-TCP because of its higher water solubility. About 10-151 of the
ceamereLai products for these uses contain 2,4,5-TO? itself. The aonmer-

terrnchlrn-eptianol, and lower Ghlorophenols, as well as other active ingredientsf organic solvents? and eaulsifiers. K contaminant in 2,4,5"
TO-c^isaining pesticides is 2,3,7ra-tatrachlorodibanzo-p^iijoxin (TCD)
which is currently piasaut up to a "••*l*ftM concentration of 0.1 pen
(Crosby et aL,, 1373).
To astisBta human expeauri to 2,4,5-TCP or its salts in the above
four aejcr use pettecnsr •vsilable piihlithed literature vow ocrrniltrad.
It shnald be noted that exoasura data for 2,4,5-TC? or its salts was
iimnrjiiyy^ii^ fi''*f tht &lt;v*«-&gt;tp»»^i^p* 1 Safety and Heall*^ ^*ftjp^ fLyjtion

in the aforementioned industries. However, by making certain

aasuroticnif astisataa of potential bunetn ejctxaure to 2,4,5-TC? or its
salts and TCTD can be nee. Such estimtea of human exposure in tarsa
of derael and inha.lar.1an exposure are described in four sections of
this analysis, specifically addressed to the major use patterns.
(421

�For the purpose of this analysis, it is assuaed that. the pant"
traticn of 2,4,5-TCP or its salts and TCDD into the hunan slcin has a
value of about 10%. This is similar to th* p*nttn.ti^t value of several
other chlorinatad hydrocarbons which is about 7-15% (Maibach and Feldtaan,
1974). it is also assuped that the TOO oaiLent in omwrcial 2,4,5TC? or its salts is at a neadrua of 0.099 ppa. For the purpose of this
analysis a anxisum figure of 0.1 ppn TOGO is used. Lung absorption of
TOD by inhalation is a«sunad to be 100%.
SOMMKEf
this reyuHJ. rtiscosaeii levels of fcunan exposvna to 2,4,5-TC? or
its salts end TCDD that can be expected at specific use sites. The
estimated values for TCDD darnl and inhalation exposure to wcnen are
suBBKEized in Table 13. Table 14 shove the estiseted espcsuxe to 2,4,5TC? and/or its salts. Because of the pnsalMe texutogenic effects frcm
TCDD, this analysis is predicated on the basis that the wodcers are wo*

oen even though many of the positions that my reiult in exposure are
held by sen. Ho eatisBtes of total individuals tiat oey be •xpesed are
available at this tiae.
a. Exeegure Analyiiia^Jter 2.4, 5-7.C? or...ita_._Salta_in
Injuarcelal Cooling viacar .Sv-acagq
There are two types of cooling tower water system in industry,
one totally enclosed and the other open to the atoospnere. A typical
enclosed cooling water system usually contains water storage tanks connected to an application muiifold? watar cirailatfts between a storage
reservoir, chiller, «nd open gutters below the point of application such

(43)

�1'AIUf 13.' Ihimsn «xpcgtiro levels to

*
Product
Niniier

Use
Site

Microtj. a/kq body wt/day NlcrograasAg body wt/day
ften..&gt;l Exposure
Inhalation Exposure

Iniistrial

Water System

Product B

Viper t Pulp Hills

Product C

feather

Product D

-6
0 3 x 10
.7
-6
1.4 x 10
Hi
0.2 x 10
-6
4.9 x 10

Hospital- Applicators Product B

-6
7 x 10

Cooling Toner

Product A

-6
2.3 x 10
-6
9.0 x 10
-6
5 5 x 10
.
-6 .
0.7 x 10

Non-Industrial

- Patients

Product B

-6
0 8 x 10
.8
-6
0.49 x 10

* Product refers to exasples of cooaercial fonulation discussed in the text of
this report under specific use site.
Product
A
Ii
C
D
K

t 2,4,5-TCP or Ha 2,4,S~rep
7.2%
85%
15%
17.5%
2.32%

(sodium salt)
(soditn salt)
(tridilorq4ienal)
(sodium ^alt)
(sodhn salt)

(44)

�YAJU£ H. ifcgaan exposure levels to 2,4,5-TCP and/or ita salts

Use
Site

Product
tiwlier

Milligram A 9 body wt/day MllligraieaAg body vt/day
Dental Exposure
Inhalation Exposure

Industrial
Cooling Tower

Product A

0.0037

0.023

Hater Systems

Product 0

0.014

0.0903

Paper i. Pulp Hills

Product C

0.092

0.055

leather

Product D

0.049

0.087

lloispital- Applicators Product B

0.07

0.009

- Patients

Product B

0.005

* Product refers to exanplea of oowerclal fonulation discussed In the text of
tliis report under specific use site.
ITodiict

I 2,4,5-TCP or Ma 2,JfS-TCP

A
n
C
11

7.2%
85%
15%
17.5%

(eoditn salt)
(sodiu* salt)
(tridilorrphenol)
(aodiiM salt)

K

2.32% (sodium salt)

�«* dias, Enl.Ung «LUs, ate. KURD* system uaually contain 20,000100,000 gallons of oaolant. At tha point of application conaidarabla
loaaaa occur so make-up watar is constantly pumped from tha
watar storage tanks. Tha cooling watar system ara ganarally wry larga
Such systems, called "cooling towers", ara found ia heavy industrial BMn
ufacturing aitas cSs&amp;linj with mi, 11 tons of gallons of watar. Thasa latga
an cSaai^ad eo provide a larga avaporatiw «rrf«ca '*ara watar
owtr baat atthangan. Ibay an usually built outsidt of tha
producBion hulJtMngs, but natintananoa workacs and cooling tcwar oparatocs mild ba aaqpoaad to this cooling watar.
In both situaticnsr ragmrdlaaa of taa siza of th« gaoling watar
an naadad ta maintain a dwn syatan.
Oan an a larga mmitmr of 'jjitnmi\'r^*1 algicidaJL f^n \n\\im*i*f*tit
uxuwnjad for conling tswar acplicatica which contain 2,4,5-TCS or its
salts. In some cconsreUl fcoulBticns, it is noted that 2,4,5-TG? and/
car its .adta an the only active ingredients. Fear nest products 2,4,5?G&gt;, or its sndium and potassium salt, is used in conjunction with pentachicrccoenol, tertian and potassium pentachlorcchenate, and other calorophenols. PenttK&amp;lccephenol and its SAlts an used whenever a wood preservative effect is needed in cooling towers. In the gaoling tcwar systaBB, the pesticide- is periodically added to maintain an effective algicidal concentration.
Factory workers, in the vicinity of the cooling water systems and
the cooling tower, an potentially «*n@ssd ts 2,4,5-TC? or its salts and
(46)

�its isgurity TOGO by dermal contact or inhalation. Open investigation,
it was learned that autcoatic altering davieas an generally used to add
thu 2,4,5-'rCP-cctttaifling pesticide,
Txo specific pesticide fccaulaticn products an considered fear the
purpoMB of estimating th« levels of exposure. According to libel data,
the percent concantraticn of tachnical Ka 2,4,5^TCP in th« product and
th« conoentrmticn laval of to* product nccnntndad for «ffactivcnass is:

of Technical Na 2,4,5-TC?

Product \

7.2%

Product B

83%

Reconnended
Product t'se
Concantraticn
300 ppa

Q.SS ltos/1000 gal

Na 2,4,5TC? Active
22 ppa

87ppa

Zt is Humnmd that nsintananca wockazs and cooling ifsmur cpvr
cnnld bi •spcaad to soot daead contact with th« coaling watar. It is
«timted that possibly 100 ml/day of cooling watar omld com in contact with a person, tta Na 2,4,5-TC? content in each ml of cooling water
is «i^»l»»^f and than, based on an assumed skin penetration rat* of 10%
for Na 2,4,5-TC?, the desnal* exposure for a 60 fcg woman to this ccnccund
is estiSHtad as follows:
Product A
For Product A the content of Na 2,4,5-TC? in the treated cooling
water is 22 ppa or 22 rog/1. Therefore, the 100 ml that might contact the
skin per worker per day will contain 2.2 mg of Na 2,4,5-TC?. Since the

�penetration of the pattidLda into the bucan body is assumed to be 10%,
tba desaal exposure to Ka 2,4,5-TCP can ba estinav.ed to be: 2.2 mg x 10%
•f 60 kg • 0.0037 mg/kg/day. Oennal exposure to TCCO will then be 0.00037
-6
-€
ng (Q.0037 ng/fcg/day x 0.1 x 10 ) or 0.37 x 10 ug/fcg tody wt/day.
Product B

water treated with Prcducr. B contains 87 mg/1 of Ma 2,4,5TC?. Cne hundred ml of this gaoling water, the quantity estimated to contact the skin per worker par day will contain 8.V nsg Ma 2,4,5-TC?. Since
tha penetration of tha pesticide into the human body is rated at 10%, the
derffltl exposure to Ka 2,4,5-TC? is estiaatad to be 8.7 x 0.1 (10%) r 60 kg
• 0.014 agAg/day. Dermal exposure to TCDD will then ba 0.014 axj x 0.1 x
-€
-6

10

or 1.4 x 10 ugAg body wt/day.

11* Inhalation _Sxeosure
While working in and around cooling towers for apprcxi&amp;ateiy 2
noun a day, workers are subject to inhalation exposure fzcs pesticLdea
added to moling water. Because of the high evaporation rate it la assumed that the air a woricar will breathe in the exiling tcwer will have
o
2
100% relative huaidity at 20 C. Under these conditions, 1 r*. cf air cantains 17.3 grata of water. It is assumed that the pesticide is carried
into the ai^ in proportion to its concentration in the coaling water.
Product A
If tha Ma 2,4,5-TC? content is 22 cgm or 22 nc/l, and tr.a rreath3
ing rate is 1.8 m hr; then, &amp; 60 kg worker will receive the fciicwing

3
3
exposure 0.0173 I/D x 22 rag/1 x 1.8 m /hr x 2 hrs r 60 kg or C.OZ3 me/'
-€
kg/day Ha 2,4,5-TCE&gt;, which iroliea a dose of 0.023 x .1 x 10 cr 2.3 x
-3
10 ug TCZD/kg/day.
(48)

�Product B
A« above, the exposure to Product % in calcuiatad as follows:
3

3

0.0173 I/B x 87 ag/1 x 1.8 » /hr^t 2 hrs £ 60 kg or 0.0903 ag/fcg/d»y Na
-6
-6
2,4,5-ICP which is equivalent to 0.0903 x 0.1 x 10 or 9.03 x 10 ug
TCDD/tog/dsy.

Analysis for 2rJ,!HPC? and its Salts in
Pulp Induarry
Paper and pulp "*n? us« oannsrcial fcmilations containing 2,4,5TCP or its &amp;*ltJ for q»tznll1ng baetati* and fungi. In this walyais
products raccomtndad for vfaita water and atoeic svstata of t±e
mills, and the onnnarelal products usad in pulpr P^pv,. and papar
board natufactoring haw bacn studied. 2b« eyoical caamrrial prcdue:
raoaimooJad for the control of bacteria and fungi in tha abova processes
contains 15% 2,4,5-TG1 by woight with the cornispcnding TO33

tapurit?.

CustOBaarily, the- paaticicii is added directly to the system using a metering device.ELxccsurs
Product C (15% 2,4,5-TCP) is added to pulping systaea at the rate
of 0.825 lb/1000 gallons under the cost demanding conditions. T&amp;s is
equivalent to approxiiatvely 100 ppn of the fomilaticn and therefore,
15 ppm 2,4,5-^rCP.
Workers in pulp/paper mi Its periodically take samples to ccnitct
the process f cr quality control. Assumirw sailing is done hourly and
each tint the worker vwts one hand (10 ml); then, an exposure of 80 al/
day is pcmaible. A 60 Jo? worker could then be exposed to 0.08 I/day x
15 og/1 x 0.1 (ahsc ration) r 60 kg or 0.002 TO 2,4,5-TC?Ag/day. TCC
(49)

�-6
-6
exposure would then be 0.002 x 0.1 x 10 or 0.2 x 10 ug TODOAg/day.
(ii) Inhalation Exposure
At the exposed tank areas, open conveyors, and q?an-spurting lo-

caticna, tha mill wozkar will bt exposed to ccntaadjiatsd air. It is «•o
tuned that conditions of 100% relative humidity and 20 C prevail. In that

3
case tha air would contain 17,3gran water/to . If it is assumed that

the pesticide ia present in the sane proportion as the prccorticn in th«
process water, then so, inhalation can be ca lariat nd. this would represent a worst case situation as salts at* generally not fdatil*. Using
3
a value of 15 Ffm (15 ngA) and the venter's breathing rate of 1.8 m /hr,
3
3
tho worker would be exposed to 1.8 m /hr x 15 tng/1 t . 1 3 1/te • 0.47 tog
07
It ia reasmaola to atsunt that during an 8-bcur shift,
tha wodcmr will be exposed at least 7 hours to mill spray and contaminated air at specific locations. On this oasis, tue inhalation exposure
(100% absorbed) to 2,4,5-TC? for tha f=rX«r having a body weight cf 60 to?
will be 0.47 mg/hr x 7 hrs ± SO^or O.QbS ngA? tody weight/day. Based on
a TOO eentant of 0.1 pern in 2,4,5-TC?, the inhalation of TC2D by the fac-«
-€
tory worker is 55 ug x 0.1 x 10 or S.5 x 10 ug TOBAg/day.
d. Ettoaure. analysis ...for 2,4,5-&lt;Jg_ in the Leather Industry
According to Anderson (li-76&gt; * fungicides and bactericides that
contain 2,4,5-TC? or its salts can be used at any stage of operation requiring control of fungi or bacteria: however, it is scat commonly used
in the tanning pixoeaa. Open evaluation of all the processes dealing
with the preparation of hides and tanning operations, i.e. tanning, soaking, bating, bean house washing, and fleshing and washing, it is evident
(50)

�that several workers constantly handle wet leather and wash waters used
in the leather treating process, which contain anti-bacterial and antifungal agents to cope with the heavy (growth of bacteria and fungi. Data
s"
on exposure levels of pesticides in tanneries are not available; however,
it isCTMonahleto make the following ajuuznpticns.
1. Then is a percentage of workers exposed to pesticide-*
containing water. The difference in the exposure is

•

based on specific tannery operations which nay vary in
the- pesticide amaunt and frequency. TJie tanning and
fleshing/washing operation appear to provide the neat
2. It has been observed that a person wearing gloves and
an apron could possibly get the diluted formulation on
exposed skir areas during certain operations. Each time
a worker is wet in that manner, approximately 50 ml of
water containing small quantities cf organic substances
could reach the exposed skin surface. The penetration
of 2,4,5-TCP through the skin is assumed to ba 10%.
i. Deraal Exposure
For the purposes of estimating the decnal exposure of factory
era in the leather industry/ a representative pesticide product
used in tanneries is considered. This product contains 17.5% of sodium
2,4,5-tridilarcphenata (Product D). The label directions of the product
tnd a dilution of the camareial foraulaticn at a rate of 1 pound
per 1000 gallons of water. This is equivalent to 0.021 tog/ml of Ha 2,4,5-

(51)

�TCP in tha procaaa water:
1 lb/1000 gal " 0.454 gn/gal - 454 »9/g*l x 17.5% N* 2,4,5-TCP
7 3,705 nl/gal or 0.021 nn/al !Ia 2,4,S-TO?
Baaed on the aaawnption that during the flashing and waahing aper*tion (tba worst case) in tba leather in&amp;istsy, *** wosfcar oanlrt poe*ibly
ba exprased to 1400 oil of the process water containing the pair id da par
day.

Further, baaad on tfaa assumption that tba pamtration of tba Ma

2,4,5-TO ixtta tba buman body ia 10%, Ma 2,4,5-TC? aapoaura ia aatintad
to ba 0.1 (10%) x 1400 ml x 0.021 ag/nl - 2.94 nsg Ha 2,4,5-^2/day, Tha
avaraga body waight of a woman wotJcar ia aaaumai) ta ba 60 tag, tban a woman taonary wodcar wniLrt raoaiv* a darxoal vxpoaura of 2940 ug * 60 »
49 ug Ka 2,4,5-4CP/1cg body waight/di^'. An additional factor of 0.1 x
10

-6

converts this to tha TOJ} axpoaurax

-6

4.9 x 10 ug TCDDA9 body wt/iay.

SladlMrly, tba daraal axposur* to tCDD for tba tanning cparation
in which aporajdJBatal? 200 ml tnstaad of 1400 ml sight contact a wodcar,
-6
rawilts to 0.7 x 10 ugAg tcoo of body wt/day. This ranga of valua*,
-6
0.7 to 4.9 x 10 ug ICDD/lcg/day, is ealoilatitd en tha total quantity of
traatad water centactad par pataon/day by axpoaura to different typaa of
oparationa.
ii. Inhnlatlrn Eaxaura
In tanneriea, workara will ba expowd to watar vapor from tank* and
o
orooaaaing wits. If 100% humidity and 20 C conditions prevail, than tha
3
air will contain 17.3 gm/ra . it ia aasuwrf that tha braatbing rata is
3
1.8 m /hr and that tha paaticida ia praaant in tha air in tha satna prcportion aa in tha procaas watar. then, a 60 kg worker could bo exposed to

(52)

�3
3
17.3 ml/a x 0,021 tsj/tal x 1.8 m /br x 8 hr T 60 leg « 0.087 ng Ha 2,4,5-6
OTAg/day. TOD txpcwm would «qual 0.087 x 0.1 x 10 or 0.0087 x
-6
-6
10 »g or 8.7 x 10 vag/kg/day.

«. ftqaatun Analyaia foe 2,4 ,5-TCPJ ,08*3 in^Heapltals,
(1) jntrodiacdxan
Expovun i* wtisntxJ in this walyaia for puticldt footulaticra
ufaich ax« UMd aa disinfectants in hospitals. TbtM ccnmiccial products
QMd aa dLainfacttantaAacttaclciriM contain 2,4,5-TC? or its salts (sodiua
and potaaaiiaa), otiwc activ* ingradiantsf arri imrts. Th«M ccnoarcial
product:! ar« concantzatun for whicb ths nanulactumr pnacribas a sp«dgic dlluticn ratio in watar prior to application. To wtinmta quantitatively how mcb TCCD in Ha 2f4r5^TCP may ba t*lsas«d into ttie bos, tfa« usaga pattorn o£ topical connarcial cestidda
flanaiUtiona that contain Ha 2,4,5-TC? which an racoamindad tor hospital USA haw hMn ooraidarad. For this purpoM, data on a conDtrcial
paaticid* fomilaticn is sucmxizad balow.
Pteduct,
Product E

* Ha 2,4,5^rCP
2.32%

•

Rftcomwnded
Pilaticn

Ma 2,4(5-/IC?
e?AQO eal

1:123

68.6

gallona of auch a ^JjlAitfd solution will ^ni'iyin 0.78 gallons of
product. Sinca Product E contains 2.32% Ita 2,4,5-TC?, 100

gallons will contain 0 0 8 gallons Na 2,4,5-TC?. There ara 3,785 gn/
.1
gal (density o£ 1), and therefore 68.6 grans of Na 2,4,5-TCP an prein 100 gallons.
153)

�rs4j

�-«

TCCO tba exposure would ba O.ff? ng 2 iOOO ug/mg x 0.1 x 10

-6

or 7 x 10 tig

tCDO/tog/dsy.
Ul« Inhalation
hospital workers and patients braatba the air In tba hospital warda and wade area* It is recognized that because of the restful oanditiona of tba patients, they haw* a aonevbat lower breathing
rat*, while tba 1 wpital worker nay havt a higher breathing rate.
For tba gurpoaaa of estinting tta ralativa- quantity of TC33 ralaaa«, it is aeaumad that SO patianta occupy aaniprivata ttxaa having
3
a ^olianatric spaca of appr09dfflBtaly 60 a /room (20 ft x 10 ft x 10 fit) .
tha volumtxic air spaca of tha beapital wing with 10 «ploywta is «a3
tiaatad to b* sppradsaitaly 1800 m which IncluriM tha 25 patiant rccea,
3
3
(1500 a } corridor, and naceasary supj^oct araa (300 m ). For tha size
of tba borpital wing and intoanoendad air vantilatica of 1800-2400 ft /
3
tar/pczscn (approxiiaataly 60 n ) (Air Quantitia* for v«ntllatim» 7th
ad. ) , tba total ^r*5*!**** air ^oliaa foe an 3-hour pariod «*^'W ba 60 n
3
(ventilation) x 60 (patiants and aBploymM) x 3 (hr/day) or 28,800 a .
Of tha 100 gallons of disinfectant applied, about one cop per
or 6.25 gallons (100 cups) will ba distributed in the hospital
wing interior. Ibis quantity contains 0.043 gm Ma 2,4,5-TCP/cup x 100
-6
cups or 4.3 gm Ma 2,4,5-4C?/lQO cups or 4.3 x (0.1 x 10 ) gm TOE or
-6
0.43 gm r 10 gm TCZC/10C
Since it i* estirattad that in a water solution, 22% of the TCTO
-€
volatilize baton drying, it is assumed that 251 x 0.43 x 10 gm

(55)

�-6

(ajtsunt of TCEC/100 cups diluted formilation) or 0.108 i 10 ga TCDD is
volatilized. Based on the total circulated air volisnt Cor an 8-hour
3
- 6 3
period, 28,800 a , them 3.7 x 10 ug/m would be available. (0.108
-«
3
-12
3
- 6 3
x 10 r 28,800 a • 3.7 x 10 &lt;jm TCCD/m or 3.7 x 10 ug/n .
3
If the breathing rate of the psti«nts is 1.0 a /nr and that of
3

the workers i« assumed to be 1.8 a /hr, then the exposure &lt;n»lrf be:
3
-6
a. Hospital worker (60 kg)* 1.8 a /hr x 8 br x 3.7 x 10 09
3
-6
TCDD/a r 60 tog or 0.88 x 10 ug TGCDAg/day.
3

b. Hospital worker (60 teg)t 1.8 a /hr x 8 hr x 4.3 gm TCP/
100 cups x 25% volatilization r 28,800 n r 60 kg • 0.00895 ag

Ha 2,4f5-TCPAg/&lt;i«y.

3
-€
e. Bospital patient (60 kg): 1.0 a /hr x 8 hr x 3.7 x 10 ug
3
-€
ICCD/m «f 60 kg or 0.49 x 10 ug TCDDAg/8 hrs.
3
d. Bospital patient (60 kg): 1.0 a /hr x 8 hr x 4.3 go TCP/100
cups x 25% volatilization f 28,800 m &lt;? 60 kg • 0.00497 rag
Ma 2,4,5-TCP/kg/day.
£. Concluaions

The sun of the dermal and inhalation exposures to TCDD (per Table
13, page 44) wire compared to the TCCO no-adv«rse-ef£ect level for toratogenicity and fetotoxicLty, 0 0 ugAg body weight/day (Spanchu et al.,
.3
1 7 ) The difference between this no-adverse effect level and the cal91.
culated exposure represents an adequate margin of safety. However, preliminary data (Traynor, 1 7 ) indicates the no-effect level nay be one
97
order of negnitude lass.
The dental and inhalation exposures for 2,4,5-TCP or its salts ( e
se
Table 14, page 45) were also compared to the no-adverse-effect level for
(56)

�fatotosicity, 0.9 ng/teg beady waight/day (Haubart and Diltaann, 1972) .
Since tha diffaranca batuwn this no-advana-stffact laval and tha calculatad axpcBura did not rapraaant an adaquata wargiii of aafaty, tha working Gtccp raceBiaa»da isauanot of a wabuttatole graauoptian againat registration baaart on fatoeoxicity. the Working Gcoup roalizaa that this daciaicn ia baaad on only ona taat paKfcand in 1971.

Iba 2,4,5^rO? uaad

in thia taat waa spacifiari aa baing of analytical grada frcn a conpany
ia Switzarland with no TOX contant apacif iad. iba tachnology for nanufacturirg 2,4,5-TC? vita lev TOD content, aa vmll aa tha capability for
tha idantiCicatian a£~lcw Irmla of TQ33, probably waa not aa advancad in
1971/1977 aa it ia today.
Tha Working Group nquaats ragiatzanta and othar intarastad par*
sons, wbo hava coam«u or relevant data regarding 2,4,5-TOVTCCD, exposura aatdsaataa and nargina of safaty to sutmit suc&amp; inf onoaticn to tha
ftqancy..

IV. Evidfnca ttot Sofiicient to Sutxott a Retauttabla PreargPticai
&amp;• Mutagenic Sff ecta of TCTD in Tsat
40 CTR 162.11 provides that a rebuttaela preaarption shall arise
i£ a paaticida'a ingrBdient(a), netatolite(a), or dagradaticn prcduct(s)
"(i)ndocsw outaganic «£2actar aa datanninad by cultitaat •vidanea." lha
ganatic affacts of TCTD hava baen studied by aavaral raaaarchers. Sana
of tha tasta sutigaat that thia dioxin ia a cutagan.
1, Sj3^riaa.,Dgtu»»trating.i.j±g.ffltaeenic Effects of TCCD
Buaaain at al. (1372) evaluated tha mt*r"i4,j activity of TC33 (99%
puxa) en thr«a different okrobial taat systns. In tha first study 7CCD
(57)

�si^nif icartttly increased tba incidanca of reverse nutations in Escherehia.
ogli Sd~4 Administered 2 og/ni TCDO from streptonycin dependence to straptonycin indnptndence. Ibis, was the only date at which nutations were
clearly cbserwd. No details of toe expertnantal protocol were given and
statistical OTtboos were apparently not employed in assessing the data.
tttt second test by Hussain studied reverse nutation from histidim
dependence to hiatidiia indspendence in. Salmonella tvghiaurium strains
T3V 1532 and m 1530. TOT was positive in Sk 1532 but negative in IX
1530. thifl indicates that TOO acts as a franashift nutacen. ld-170
was used an a positive control in the test with TA 1532. Ho positive
or iMgatiTO controls were tested in TA 1530.
In tho third tast, Bussain observed slight prophaee induction in
E^ goli K-39. Hc*ewer, data from this tast were difficult to evaluate
becaiVM the solvent used, DMSO, causes «*""l«r effets.
A pralintLnary la^otc: en the chrcncscnal analysis of hospital patients exposed to TOD in the accident at the Semaso, Italy, faessry was
• ,-^.^ntad at a Departnant of Health, Education, and Welfare tanting on
October 12, 1976 (Pertsl, 1 7 ) An increased nutcber of chrcocsomal le97.
sions (gaps, cnroratidic and chrcnoscmal braaks and rearrangecatnts) were
observed in the somatic cells of the 2- to 28-year-old malts and females
testad. Cytogenetic studies of tissues frcm the therapeutic abortions
perloanad on woman who were exposed to TCSD during the accident indicated
that there was chrcnDsonal damage to e»it* in matamal peripheral blood
and placenta! and fatal tissues. Uiese preliminary results wera based on
a *"?U nunber of sanplas and no specific data is available at this tis».
(53)

�.1. Studies, in Whichi Mutagcnie Eff e^ta Wet* ttot Obaetyed
and Roddick (1973) conductad dominant lethal tMta in which
ode Wiatar rats received TCQD at doaages of 4 and 8 ugAg/day. The
studies indicated that ro dominant lethal autaticra KTQM daring the
33 days paattrMtaant. The period examined corresponded to poetneiotic
stages of spennetogeneais.
A cytoganatic screening stud; of tha effects of TCCD on tha bona
narrow calls of nala nilrn-na Murrkil rats wax perfconad by tha Food and
Drug Adadnistraticn (Green, 1975) . Two separata axparlnants were perf ecoad. Tha fiat waa a mltiple doaa. test in which 10 ugAg/day was
adadnistarad by iAtubaticn daily for S consecutive days. In tha second
taatf single deaea of 3, 10, and 15 ugAg ICED were administered intraparitcnaally and 20 ugAg (tha highest cose) waa adsdniatayad orally.
Thara waa no evidence firm these studies to indicate tnat 'ru^i produced
cftooanatie dneg* in tha bona narrow of these oala rats. Tcodcity,
which waa indicatad by a slight weight loss, waa noted in tha rata that
received a single dose of 15 or 20 ugAg &gt;;ch« highest dcse levels) . This
suggested that the dose level nay have been too lew.
Therefore, the Working Group concludes that, although there is
sane evidence that TCDD is a nutagen in aicrcbial syatesa, the data is'
not sufficient to fora the basis of a rcbuttoble presuocticn. Additional
infcrmtian or studies en the nutagenic effects of TGCO should be submitted to the Agency for further review.
B.

Other Effects cf TC2D

1.
\4hether there is a relationship terueen the effects of TCX and
(59)

�dunical eareinogerasis has bMn the subject o£ ceveral studies. Marquardt
et aJU (1974) feund awidenca that aryl hydrocarbon bydrcxylase (ABB) is
strongly involved in chattical careinogenesis i^cause nany chaaically nonreactive: oaayounda oust ba metabolized by cellular ewtyines b*f ore they
can act as carcinogens. Buu-Boi «t al. (1371) found that even in very
lew dona TOO could greatly disturb tba&lt; «Rzynatic chazactar of «n organism «a do CBTtain typical atrcinopnie subatancas (a.g., banco/a/
pyrcna ind p^liitartbylaniinoazobBnzana).
In a papar on ME, Kauri at al. (1974) statad that TOO itsalf
is not a potant carcinogan in orlca. However, tha txtant to whidi the
synargistic action of TO3D and 3^nttbyid5oi«nthr«na (MC) produces cancar in different strains of adea is directly proportional to the increaae in hydroxylase activity and assort at art cytcchroM P-45C content.
Tljey raportad that the basal enzyme activity might corraJLata with the
enzyme activities that onild be inrtuoid by either TCDD of MC. Ibey
found TC2D to ba 40 to 60 tiaea acre potent as a indueer of ABB in coltured human lynphocytas tban was MC. Poland and Glover (1974) &amp;&amp;c*ed
that TCED is a^proxinately 30,000 timM itore potent than MC as an inducer of ABE in rat liver.
2. Ttacic Effects on Hunams
Thera are several adverse effects that occur in huaans as a result of exposure to TCDD. The nost well known is chloracne, a severe
and persistent disease of the skin that is very difficult to cure (S&lt;±ulz,
1957). Porphyria cutanea tarda (PCS) is another disease that is caused
by exposure to TCDD and of tan aceenpanies chloracne (Bleiberg, 1964).

(60)

�PCS is a defect of hepatic prophyri* tagt.abnlisra caaracterijid jy an overproduction of poqphyrins, fragility and ptotosensitivity of the skin*
hyptxpigaantaticn, hiraatism, and neurological and intestinal disorders
(Poland and Kande, 1976).
3. Toxic Effeeta on Other Mannada

MMBMMHMIIMWMMMMnM«M**IMNIM«Mn*M«MiaMMMMMWMM«MMMMrlW*

ttw «xtma§ tcaddty of TOO to a variety of animal spades hasbeen well docuuented (Abelaon, 1970; Buu-Boi et aJU, 1971; Jtoee et al.,
1976; Farqubwson et aJU&gt; 1958; Uigginbothaa et al., 1968; Milne*, 1971;
Spaxscbu et al., 1971). The £0 for TCCD is aa Ian as 0.6 no/kg
50
body weight in tae guinea pig (Table IS).
TMLE 15. LD-50 values for TCTD
Aniral

U&gt;50,uaAq

Ref arenas

Guinea, pig

0.6

Spvcschu et al. (1971)

Babbit

10

Scfaulz (1968)

Hat
Female
Male

22
45

Schwetz et al. (1973)

Mouse

114

Vos et al. (1974)

Dog

1000

Scfewnts et al. (1973)

4. Miscallaneous Toxic Effects
Many wseartAers haw found the-liver to be the main target for
the toxic action of TCCD. Liver necrosis (Norbadc and Allan, 1973;
Courtney and Moora, 1971), stimulation of hepatic ncLcrracaal enzyir«s

(61)

�(Piper et al. , 1973; Gupt* «t «!., 1973), and th* formation of nultinuclaate psrenchynel calls (Craig et al* , 1573) an exaspi*s o£ the
wry adverse effects also attributed to TOO toposura.
Chick edena factor (Eiggenbotham et «Ju, 1263), severe weight
lour atrophy of the thywua, and Induction of nenatic and renal micrcsona! drag metabolizing enzymes (Fowler et al, , 1373) art SOD* additional
adwcM effacts tiiat haw bean noted*
C. Other _Eff8c±3 of . 2, 4, Vrc?_ and, ita Salta
Technical gracte 2,4,5-TCP can irritate the eyes, akin, nose, and
throat* Depending on the degree of expcoure, ocular damag* nay include
burn of the conjunctiva! membrane, severe conjunctiva! swelling, slight
to QOderate iritis , and cornea! daaacp. dose exposed to 2,4,5-TC? have
ccntractcd chlcracne aad porphyria carda. Hswev«r, these effects were
attributed to the presence of fCED as a contaminant (Schulz, 1963). The
toxic properties of Na-2,4,5-TCP ars similar to tbose of 2»4f5-TG» but

% ,

are scoewhat uuie
The ID for 2,4,5-TO? has been established at ccncentraticns vary
50
ing fircra 820 to 2960 mg/k? body; weight in the cat. No ncnreversible
logical changes were noted at the doses cited. The acute feeding studies
with both 2,4,5-TCP and its sodlun sale are sunnarized in Table IS.
et &amp;L (1961) administered a single dose of 1-3.98 g/
kg 2,4,5-TC? (97-98% pure) by intubation to mala rats. The acute OTA!
LD was ^Iml^fH to be 2.96 g/kg/bcdV weight, a finding whidi led the
SO
authors to conclude that 2,4,5-TC? is low in era! toxicity.
In a 3-aonth study *« authors fed rats 0 (cantrol), 0.01, 0.03,

(62)

�TAM£ 16. Snanaty of acute effects of 2,4,5-TCP and tta sodium gait on rata

Chemical

Route of
Mninistration

taq/}f.q bod/ weight

Reference

2,4,5-TCP

oral

2960

KoColHster et al.
(1961)

2C4,5-TCP

oral

820

Deiduaarm (1943)

2,4,5-TCP

oral

2460-2830

Dow Chealcal Co&amp;pany

2,4,5-TCP

oral

620-835

Delchmnn and Mergard
(1348)

2,4,5-TCP

intraperitoneal
injection

355

Fatquharaon et al.
(1958)

2,4,5-TCP

tuibcutaneous
injection

2100-2260

Deichnxcu'A and Mergard
(1948;

Ma 2,4,5-TCP

oraf

1620-1870

Dow Chemical Co0(^any
(1976)

(63)

\

�0,1, 0.3 or 1 9 2,4,5-TCPAg body weight in th« diet for 98 days. Bats
•nintainad at the 1 gAg/day level had only alight pathologic changes in
the liwr and kidneys, the kidneys showed oodatmtad degenerative changes
in the epithelial lining of the convoluted tubules and early proliferation of the interstitial tissue. The effects of 0.3 gAg/day were milder
than those at 1 g/fcg/iay. r - adverse effects were noted in either mala
or fonale rats naintained at 0.01, 0.03, or 0.1 9/fcg. The authors concluded that 2,4,5-TO? is low in acute oral teaddty to rats when administered in their diet for a period of 13 days.
In repeated feeding tests (20 oral doses in 28 days), the authors^
adMRistaxed doses of 2,4,5-TC? ( . 0 , 0.01, 0.1, and 0.5 gAg) to rab001
bits by intubation. There were wry slight kidney changes in rabbits administered 0.1 gAg, and wry alight kidney and liver changes in those
given 0.5 gAg. Ho pathologic changes were observed in rabbits in
the two lowest dose groups.
2,4,5-TCT and its sortium salt caused no davoal effects en guinea
pigs (Dugois and Colcnt, 1957), and oaV a slight reddening of rabbit skin
after brief exposure and mild to ooderata chemical burns after longer
exposures (Dow Chemical Cowany, 1976). Refined 2,4,5-TO? also did not
cause caloracne or other adverse effects in rabbits (Kirxoig and Schulz,
1 5 ) Bather it was the TOD fomad in the alkaline hydrolysis of .
97.
1,2,4,5-tatratilorccenzene into 2,4,5-TCP that produced caloracne.
Bladonan et al. (1953) determined that the LD for 2,4,5-TC? on
50

the green water plant (I/cna miror) was 1 6 ag/litar. The authors de.5
fired the ID as xhe concentration which caused chlorosis in 50% of the
50

(64)

�plant fronds.
Antr and Xli (D74) atudiad th« cytnlr^ical «ffacts of 2,4,5-TG?
on th« raicaii, pollan viability^ mi yi*ld of Vleia faba plants that
bad bMn t^nyad or wbow laadi had betn.toalod in tte Oiaoicad.

2,4,5-

TCP had no significant «££act on tfat pollan noth«r-^alls and no harnful
•If act on

(65)

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                    <text>item D Number

°5798

Author

Brennan, Margaret

CorpOratB Author

Veterans Administration, Central Office Library

D Not Scanned

Report/Article TitlB ^ Pathfinder on Herbicides, Including Phenoxy
Herbicides and Associated Dioxins or "Agent Orange"
Bibliography of VA Central Office Library Holdings
including Vertical File Collection

Journal/Book Title
Year

1983

Month/Day
Color

D

Number of Images

3S

Descrlpton Notes

GPO 900-188

Tuesday, April 02, 2002

Page 5798 of 5840

�Veterans
Administration
Presents

A Pathfinder o Herbicide
Including
and Associate

�"AGENT ORANGE"

Bibliography of VA Central Office
Library Holdings including Vertical
File Collection

Compiled By
Margaret Brennan
July 1983

�Agent Orange was a herbicide, or defoliant, used in Vietnam to kill unwanted
vegetation and to defoliate trees Which otherwise would have provided cover from
which the enemy could attack American personnel. Agent Orange was a reddishbrown liquid made of two chemicals, 2,4-D and 2,4,5-T. Both chemicals have been
used widely throughout the world since the 1940's by farmers, foresters and
homeowners. Ihe herbicide was called "Agent Orange" because it was shipped to
Vietnam in orange-striped barrels VA Pam 601.
Beginning in 1978 a concern was expressed that the veterans exposed to Agent
Orange when it was used in Vietnam between 1965 and 1971 might be subject to
delayed health effects fron the exposure. These concerns were based on the
fact that one of the chemicals, 2,4,5-T contained minute traces of a toxic
chemical, dioxin (TCDD), which contaminated the herbicide during the manufacturing
process. The contaminated dioxin is of concern because animal studies have shown
it to be toxic to certain species. Like other toxic substances, dioxin has
produced a nunber of serious conditions among laboratory animals VA Pam 601.
The information on the following pages is a comprehensive list of the holdings
in the VA Central Office Library pertaining to 2,4-D, 2,4,5-T, an the particular
dioxin, TCDD, and its possible effects on humans.
Subject Headings under which books on Agent Orange can be located in most card,
book, and online catalogs, include the following:
AGENT ORANGE (highly relevant)
DIOXTNS (highly relevant)
TETRACHLORODIBENZODIOXrN (highly relevant)
HERBICIDES — TOXICOLOGY (relevant)
HERBICIDES — ENVIRONMENTAL ASPECTS (relevant)
PESTICIDES ~ TOXICOLOGY (relevant)
DEFOLIATION (related)
HERBICIDES — VIETNAM — WAR USE (related)

�BOOKS;

WA Ashton, Floyd M. Mode of Action of Herbicides. New York: Wiley;
240
1973. *Includes Bibliography.
A84
1973
SB Bovey, Rodney W. The Science of 2,4,5-T, and Associated Phenoxy Herbicides.
951.4
New York: Wiley; 1980.~""~*Includes Bibliography.
B66
1980
DS Buckingham, William A. Operation Ranch Hand; The Air Force and Herbicides
559.8
in Southeast Asia, 1961-1971. Washington, D.C.:Office of Air
.C5
Force History, U.S. Air Force, 1982. *Includes Bibliography.
B82
1982
WA Carson, Rachel Louise. Silent Spring. Boston: Houghton Mifflin; 1962.
240
*Includes Bibliography.~
C321
1962
WA Fuller, John Grant. The Poison That Fell From The Sky. New York;
465
Berkley Pub. Corp.; 1979, c!977T
F966p
1979
OP Health Effects jjfHajlogenal^
Edited by William
341
j. Nxchofson and "John A. Moore. New York: New York Academy of
H9
Sciences; 1979. *Includes Bibliography.
H434
1979
SB Herbicides; Chemistry, Degradation, andMode of Action. Edited by
951.4
P.C. Kearney and D.D. Kaufman. — 2nd edition, revised and
H538
expanded. New York: M. Dekker, c 9 5 c 9 6 *Includes
!7-!7.
1975-76
Bibliography.
RD Linedecker, Clifford L. Kerry, Agent Orange and an American Family.
796.R93
New York: St. Martins Press, 1982. *Includes Bibliography.
L56
1982
WA McEwen, Freeman Lester. The Use and SignificanGe of Pesticides in the
465
Environment. New York: "Wileyf 1979. *Includes Bibliography.
M412u
1979
UB dhl, Micheal. GI Guinea Pigs. New York: Playboy Press; 1980.
369
*Includes Bibliography.
U35
1980

�WA Whiteside, Thomas. The Pendulum and the Toxic Cloud; The Course of
240
Dioxin Contamination.NewHaven:Yale University Press; 1979.
W587p
*Includes Bibliography.
1979
AuPIOVISUALS;

WA Agent Orange; A Search For Answers (Motion Picture). Veterans
240
Adnanistration^Medical Center, St. Louis, MO. — Washington,
Age
D.C.: Veterans Administration; 1981. 1 reel, 30 minutes:
1981
sd., co.; 16mm.
WA Agent Orange; A Search For Answers (Vidoerecording). Veterans
240
Administration Medical Center, St. Louis, MO. — Washington,
Age
D.C.: Veterans Administration; 1981. 1 cassette, 30 minutes:
1981
sd., col.; 3/4 inch.
WA Reports on Agent Ojraneje (Videorecording). Television Broadcasts copied
240
by Information "Service, 1978.
Rep
BIBLIOGRAPHIES;

VF

Bryan, Gordon. Agent Orange; An Introduction for Veterans, Librarians,
and Students; 34 annotations with additional sources, addresses,
and phone numbers. Terre Haute, Indiana; 1981.

W

U.S. Environmental Protection Agency. Numerical Listing of EPA Testiirpnies
and Exhibts1-40. Washington, D.C.: U.S. Environmental Protection
Agency ;T980.

W

Veterans Administration. "Agent Orange" A Selected Bibliography.
Second edition. California: ^terans Administration; 1980.

HEARINGAND CONFERENCE PROCEEDINGS;

FICHE
Agent Orange: Exposure of Vietnam Veterans. Hearing before the
81-H501-52
Committee"on Veterans' Affairs, U.S. Senate, Ninety-sixth
Congress, second session, September 25, 1980. — Washington,
D.C.:
KF
26

V4

1980i
CD
405
A355
1973

U.S. G.P.O., 1980. Y4.In8/4:96-229.

Agent Orange Update and[Appendix, Agent Orange1 Activites (part II).
Hearing before"the Committee on \feterans Affairs, U.S. Senate,
Ninety-sixth Congress, second session, September 10, 1980.

Washington, D.C.: U.S. G.P.O., 1980. *Includes Bibliography.
C3ilprpdioxins--Origin and Fate, Etcyl H. Blair, editor. Washington:
American Chemical Society, 1973. (Advances in Chemistry
series, 120). A symposium sponsored by the Division of
Pesticide Chemistry at the 162nd meeting of the American
Chemical Society, Washington, D.C., Sept. 16-17, 1971.
*Includes Bibliography.

�SB
951
C648
1977

W

Controlled-Release Pesticides Symposium,. New Orleans, 1977.
Sponsored by the Division of Pesticide Chemistry at the 173rd
meeting of the American Chemical Society, New Orleans, LA.,
March, 21-22, 1977.

Current Status of Agent Orange Studies; Hearing Before the Sub* committee on Oversight and Investigations of the Ninety-seventh
Congress, first session, May 6, 1981. Serial No. 97-22.

WA
671
D595
1976

Dioxin Tbxicological and Chemical Aspects. Edited by Flaminio
Cattabeni, Aldo Cavallaro, Giovanni Galli. New York: SP
Medical &amp; Scientific Books: distributed by Halsted Press,
1978. Papers presented at a workshop organized by the
Institute of Pharmacology and Pharmacognosy, University of
Milan, Italy; Oct. 23, 1976.

1
0

196
P38
D57
1978

Disposal and Decontamination of Pesticides; A Symposium.
Sponsored "by"the Division of Pesticide Chemistry at the 174th
meeting of the American Chemical Society, Chicago, Illinois,
August 29-September 2, 1977. Washington: ACS, 1978.
*Includes Bibliography.

•
^
194.5
E26
1976

Ecological Consequences of the Second Indochina War. Stockholm
International" "Peace" Research institute. — Stockholm:
Almqvist &amp; Wiksell, 1976. *Includes Bibliography.

WA
240
F48
1980

Field Vforker Exposure During Pesticide Application. Proceedings of
the Fifth international Vforkshop of the Scientific Committee
on Pesticides of the International Association on
Occupational Health, the Hague, the Netherlands, October 9-11,
1979. New York: Elsevier Scientific Pub. Co., 1980.

FICHE
79-H761-9

Herbicide 1
"Agent Orange". Hearing before the Committee on Veterans Affairs, House of Representatives, Ninety-fifth
Congress, second session, October 11, 1978. Y4.V64/3:H41.

WA
240
H918
1983

Human and environmental risks of chlorinated dipxins and related
compounds!Edited by Richard E. Tucker, Alvin L. Young,
and Allan P. Gray. Proceedings of an international symposium
on Chlorinated Dioxins and Related Compounds, held October 25-29,
1981 in Arlington, VA. New York: Plenum Press, 1983.
*Includes Bibliography.

FICHE
Involuntary Exposure to Agent Orange and Other Toxic Spraying.
80-H501-95
Hearing before the Committee on Veterans Affairs, House
of Representatives, Ninety-sixth Congress, first session,
June 26 - 27, 1979.

Y4.In8/4:96-139.

FICHE
Issues Concerning Viefanam Veterans. Hearing before the Committee
81-H761-49
on Veterans "Affairs, House of Representatives, Ninety-seventh
Congress, first session, July 16, 1981. Y4.V64/3:97-32.

�FICHE
Legislation to Improve Medical Programs administered by the Veterans'
81-H761-35
Administration (H.R. 2157, H.R. 2953, H.R. 2999) Hearing
before the Committee on Veterans Affairs, House of Representatives, Ninety-seventh Congress, First session, April 28,
1981. Y4.V64/3:97-21.
Cfl
545
P4
M42
1974.

Mechanism of Pesticide Action; A Symposium Sponsored by the
Division of Pesticide Chemistry at the 167th meeting of the
American Chemical Society, Los Angeles, California, April
2-3, 1 7 . *Includes Bibliography.
94

FICHE
Oversight Hearing to Receive Testimony on Agent Orange. Hearing
81-H761-10
before the Committee on VeteransT Affairs, Ninety-sixth
Congress, second session, July 22, 1980. Y4.V64/3:T28/980-2.
FICHE
80-H761-9

Oversight.Hearing...to Receive Jtest.ijpny on Agent Qcarige. Hearing
before"rffie"Committee on Veterans' Affairs, Ninety-sixth

Congress, second session, February 25, 1980. Y4.V64/3.T28
3
.^'*£$. ..,ffig Q ^ ^ J^uc^t^on Conference on Herbicide
^
Orange (2nd). Washington, D.C., May 28-30, 1980. Washington,
D.C.: Veterans Administration; May 1980. Also available
from NTIS PB82-119017.

FICHE
Scient i f ic Community Report on Agent Orange. Hearing before the
81-H761-12
Conmittee on Veterans' Affairs, Ninety-sixth Congress,
second session, September 16, 1980. Y4.V64/3:Sci2.
FICHE
81-H763-9

Veterans' Health Care Act of 1981. Hearing before the Committee
on Veterans' Affairs, Ninety-seventh Congress, first
session, May 19, 1981. Yl. 1/8:97-79.

FICHE
81-PL97-72

Veterans' Health Care, Training, and Small Business loan Act
~o±'1981. Public Law ""Announcement," Nihety-s'eventii Congress,
first session, November 3, 1981.

FICHE
Veterans Health Program Extension .and, Improyement Act of 1979.
79-PL96-151
Public Law announcement, Ninety-sixth Congress, first
session, December 20, 1979.
FICHE
80-S761-4

VA Health Resources and Programs Extensions and Appendix: ;
Agent Orange Activities. Hearing before the Committee
on Veterans HSffairsTtj .S . Senate, Ninety-sixth Congress,
first session, April 10, 1979. Y4.V64/4:H34/12.

FICHE
82-S761-3

Veterans' Programs Extension and Improvement Act of 1981 .
Committee before the Committee on Veterans' Affairs,
U.S. Senate, Ninety-seventh Congress, first session,
April 30, 1981. Y4.V64/4-.V64/27.

FICHE
81-S763-3

Veterans' Programs Extension and Improvement Act of 1981.
HearTngs^efbre't^el^ommittee on Veterans' Affairs, U.S.

Senate, Ninety-seventh Congress, first session, May 15,
1981. Yl. 1/5: 97-89.

�FICHE
81-S761-7

Vietnam Veterans' Readjustment, Part I. Hearings before the
Ccmmittee on Veterans' Affairs, U.S. Senate, Ninety-sixth
Congress, second session, January 25-26, 1980. Y4.V64/4:
4:V67/ll/pt.l.

FICHE
81-S761-7

Vietnam Veterans' Readjustment, Part II. Hearings before the
Ccmmittee on Veterans' Affairs, U.S. Senate, Ninety-sixth
Congress, second session, February 21, March 4, May 21, 1980.
Y4.V64/4:V67/ll/pt.2.

VF

Veterans Administration. Advisory Cormittee on Health-Related
Effects of Herbicides. Transcript of Proceedings.
Washington, D.C.
First Meeting: June 11, 1979
Second Meeting: September 24, 1979
Third Meeting: December 12, 1979
Fourth Meeting: April 23, 1980
Fifth Meeting: August 6, 1980
Sixth Meeting: November 6, 1980
Seventh Meeting: February 4, 1981
Eighth Meeting: May 5, 1981
Ninth Meeting: August 19, 1981
Tenth Meeting: November 19, 1981
Eleventh Meeting: February 25, 1981
Twelfth Meeting: May 13, 1982
Thirteenth Meeting: August 31, 1982
Fourteenth Meeting: November 30, 1982
Fifteenth Meeting: February 24, 1982

VF

Veterans Administration. Annual Report to the Veterans! Administration
Advisory Ccmmittee on^Healt^-Related Effects of Herbicides for;
calendar year 1979
calendar year 1982
Note: Annual reports are only required when one or more of the hearings
during a calendar year are closed to the public. No report
exists for 1980 or 1981.

GOVERNMENT PUBLICATIONS:

VA 601

Agent Orange; Informa.t.ipn for Veterans Who Served in Vietnam.
I'feshingtonr'D.cn 1982. Three pieces (green, blue, brown).

VA 601

Veterans Administration. Agent Orange Review; Information for
Veterans who served in Vietnam. Vfeshington, D.C.
Volume 1, #T - November 1982
Volume 2, #1 - April 1982
Volume 2, #2 - June 1983

^
240
R454
1981

Review of Literature on Herbicid^
and'Associated. Diojans. Washington, D.C.: Veterans
Administration,~Deptr~bf Medicine and Surgery, 1981.
Volume 1: Analysis of Literature
Volume 2: Annotated Bibliography

6

�DS
559.8
C5
U54
1979

United States. General Accounting Office. U.S. Ground Troops in
South Viejbnam wsre in.Areas Sprayed with Herbicide Orange
Vfesnington, D.C.: U.S. General Accounting Office, 1979.

TECHNICAL REPORTS;

VF

Akerman, D. and others. At-sea Incineration of Herbicide Orange
Onboard the; M/TVulcans. Prepared for Industrial Environmental Research Laboratory, Research Triangle Park, North
Carolina. Redondo Beach, California, 1978. Also available
from NTIS 281-690.

W

Batteson, Fred D. Jr., Don D. Harrison, and John D. Morgan.
Field Studies of ^ldli&amp;^&lt;^^'^_':iX3X) Contaminated Soils,
1975.

VF

Carmelli, Dorit, et al. A Case-control Study of the Relationship
Betwsen Exposure to 2,4-D andSppntanepus Abortions in Humans;
ffinal Report. Prepared for the National Forest Products
Association and the U.S. Dept. of Agriculture-Forest Service.
August 1981.

W

Esposito, M.P., T.O. Tiernan, and Forest E. Dryden. Dipxins.
Research reporting series, Environmental Protection Agency.
Cincinnati: Industrial Environmental Research Laboratory,
Office of Research and Development, U.S. Environmental Protection
Agency, 1980. *Includes Bibliography.

W

Fee, D.C., et al. Analytical Methodology for Herbicide Orange.
Aerospace Research Labs, Wright-Patterson AFB, Ohio
Systems Research Labs Inc., Dayton, Ohio. Final Report
December 72-December 74; May 1974.
Volume 1: Determination of Chemical Composition
Volume 2; Determination of Origin of USAF Stocks

^
240
H434
1981

The Health Effects of "Agent Orange" and Polychlprinated Dioxin
C&amp;ntann^anTs'; fectinica^Rejyrt. Prepared by the Council
on Scl!elitifTc~Affairsr Advisory Panel on Toxic Substances.
Chicago, IL; Dept. of Environmental, Public, and Occupational Health, American Medical Association, 1981. *Includes
Bibliography.

WA

Lamb, James C., John A. Moore, and Thomas A. Marks. Evaluation of
2: ,j4-dich3Lorophenpxyacetic acid (2,4-D), 2,4,5-trichlorophenoxy^cetic'acid r2",4,5-T), and 2,3,7,S-tetrachlor^ibenzo-p-dioxin
(TCDD) tojdcity in CSFBL/6 MICE; Reproduction and fertility
^treated male nice and.evaluation of "cogential malformatipn
in tfielr "offsjgc^in£. Research Triangle Park, NC: National
Toxicology Program: Research Triangle Institute, 1980. (NTP80-44) *Includes Bibliography.

�W

Lavergne, Edward A. Study of the Feasibility of Herbicide Orange
Oilorinolysis. "Prepared for the Off ice of Research and
Development, Envirormental Protection Agency, Painsville,
Ohio. Diamond Shamrock Corporation, July 1974. Also available from OTIS PB-286705/9ST.

QZ
202
L857
1978

long-term hazards of polychlorinated dibenzpdipxins and polychlorinated
dibanzoforans. Joint NIEHS/IARC Wbrking Group Report. Lyon:
International Agency for Research on Cancer, 1978. (IARC Internal
technical report; 78/001) *Includes Bibliography.

W

Mullison, Vfendell R. Public Concerns about the Herbicide 2,4-D.
Dow Chemical U.S.A., Agricultural Products rtepartanent,
Public Affairs, Michigan: 1981.

SB
970.4
U5
N37
1980

National Research Council. Regulating Pesticides; A Report..
Prepared by the Committee on Prototype Explicit Analysis for
Pesticides, Environmental Studies Board, Commission on
National Resources, National Research Council. Washington,
D.C.: National Academy of Sciences, 1980. *Includes
Bibliography.

W

National Toxicology Program. Technical Report on the carcinogenesis
of Bioassay of 2,3,7,8- tetracM^
1746-01-6) in psbprne-Meaidel rats and B6 C31F, ffa.ce (Gayage
Study). Bsthesda, ~MD:U.S. JDept of Health and Human Services,
Public Health Service, National Institutes of Health, February
1982. (NIH Pub #82-1765; NTP-80-31)

W

National Toxicology Program. Technical Report on the carcincgensis
of Bioassay of 2,3,7,8-tetracM
01-6 PSwfss^ebsteF Mice (Dermal StudyT Bethesda, MD: U.S.
Dept. of Hea"rth~and Human IServTces,' Public Health Service,
National Institutes of Health, February 1982. (NIH Pub #82-1757;
NTP-80-32).

W

Review of U.S. Air Force Protocol: Efcideraiolpgica^
of Health Effects in Air Force Personnel Following E&amp;posure
to Ilerbicide; (Grange;. National Research Council, Committee
on Toxicology, Washington, D.C.: May 1980. Also available
from NTIS AD-A085 105/5.

W

Thomas, T.J., et al. Land Based Environmental Monitoring at
Johnston Island-Disppsal of 'Herbicide Orange.Battelle
Columbus Labs, Civil and Environmental Engineering Development Office, Tyndall AFB, September 1978. Also available
from NTIS AD-A076 025/6.

CP
545

The Toxicology, j^yirprariental Fate, and Human Risk of Herbicide
Orange" andTits Associated bibxTnT Final ^Report. Brooks AFB,

T6
1978

Texas: USAF. Also available from NTIS. AD-A062 143/3.

�VP

Young, Alvin L. Agent Qrange at the Gcpssroads of Science and
Social Concern. Air Command and Staff College, Maxwell AFB,
AL, May 1 8 . *Includes Bibliography. Also available from
91
NTIS AD-A102 611/1.

VF

Young, Alvin L. Ecological.Studies on a Herbicide-Equipment
Test Area (TA C~52A) . Eglin AFB Iteservation, Florida;
Air Force Armament Laboratory, Program 5154-02, January
1967-ltovember 1973, 1974.

WA
240
F252
1976

Young, Alvin L. , et al. Fate of 2, 3, 7, S-Tetrachlorodibenzo-ydioxin (TCDD) in the Environment; Summary and Decontaminatipn RecaiTOendations^ Prepared of HQ Air Force Logistics
Command, Wright-Patterson AFB, Ohio, 1976.

W

Young, Alvin L., Charles E. Thalken, and William J Cairney.
Herbicide Orange Site Treatment and Environmental Monitoring;
Summary and Report ^ccnaTenj3atipns for Naval Cgristructipn
Battalion Center/ Qjlfport, MS. USAF Occupational and
Environmental Health laboratory, Brooks AFB, Texas.
November 1979.

W

Young, Alvin L. , Charles E. Thalken, and William E. Ward. Studies
of the Ecological Impact of Repetitive Aerial Applications
of HerbTcTdes on jbheT Ecosystem of Ttest Area C-52A, Eglin AFB,
Florida, f9T5. *fncludes Bibliography.

W

DeSylva, Donald P. and Harding B. Michel. National .Research
Council. Division of Biological Sciences. Committee on the
Effects of Herbicides in Vietnam. The Effects of Herbicides
in South Vietnam. Washington, D.C.l National Academy of Sciences.
Part Af Summary and Conclusions
Part B: Working Papers: Effects of Mangrove Defoliation
on the Estuarine Ecology and Fisheries of South
Vietnam.
Part B: Working Papers: The Effects of Herbicides on the
Mangrove of South Vietnam.
Part B: Working Papers: Estimating the Highlander
Population Affected by Herbicides.
Part B: Working Papers: The Ecological Pole of Bamboos
in Relation to the Military use of Herbicides
on Forests in South Vietnam.
Part B: Working Papers: An Historical Survey of the
Development of Herbicides.
Part B: Working Papers: The Ecological Role of the
Fern ( "Acrostichum Aureum") in Sprayed and
Unsprayed Mangrove Forests.

�Part B: Working Papers: Molluskes as Indicators of the
the Effects of Herbicides on Mangroves in South
Vietnam.
Part B: Working Papers: Economic Stress and Settlement
changes.
Part B: Working Papers: Uses of Herbicides in Tropics
and Subtropics.
Part B: Working Papers: Epidemiological-Ecological
Effects: Studies on Intact and Deforested
Mangrove Ecosystems.
Part B: Working Papers: Effects of Herbicides on Soils
of South Vietnam.
Part B: Working Papers: Persistences and Disappearance
of Herbicides in Tropical Soils.
Part B: Working Papers: Air-Photo Studies of the
Pung-Sat.
Part B: Working Papers: Perceived Effects of Herbicides
used in the Highlands of South Vietnam.
Part B: Working Papers: The Location of Herbicide
Missions and Rickey's Informants in South
Vietnam: An Appraisal.
Part B: Workings Papers: Studies of the Inland Forests of
South Vietnam and the Effects of Herbicides Upon
Those Forests.
Part B: Working Papers: Beliefs, Attitudes, and Behavior
of Lowland Vietnamese.
Part B: Working Papers: Models of Herbicide, Mangroves,
and War in Vietnam.
Part B: Workings Papers: Air-Photo Inventory of the
Rung-Sat.
ADDITIONAL SOURCES OF INFORMATION:

Advisory Committee on Health Related Effects of Herbicides
Veterans Administration Central Office
810 Vermont Avenue, N.W.
Washington, D.C. 20420
Telephone: (202) 389-2214

10

�Agricultural Products Department
Dew Chemical Company
9001 Building
Midland, Michigan 48640
Telephone: (517) 636-4826
Division of Enivronmental Sciences

School Of Public Health
Columbia University

60 Haven Avenue, BI
New York, New York 10032
Telephone: (212) 694-3464
National Toxicology Program
National Institute of Environmental Health Sciences
P.O. Box 12233
Research Triangle Park, North Carolina 27709
Telephone: (919) 541-3267
National Veterans' Task Force on Agent Orange
P.O. Box 3324
Country Fair Station
Champaign, Illinois 61820
Telephone: (217) 384-6544
Toxics Clearinghouse
Environmental Action Foundation
724 Dupont Circle Building, N.W.
Washington, D.C. 20036
Telephone: (202) 659-9682

11

�JOURNAL ARTICLES;

Ahmed, Parid E., Ronald W. Hart, and Neil J. Lewis. "Pesticides induced DNA
damage and its repair in cultured human cells". Mutation Research, 1977;
42(2): 161-74.
"Air Force backed as proper Agent Orange Study Agency". U.S. Medicine,
15 August 1980.
"Air Force will study men who sprayed Agent Orange". Journal of the American
Medical Association, 11 January 1980; 243(2): 102-3
Albro, P.W., et al. "Newer methods in the analysis of polychlorinated biphenyls
(PCB's). (Abstract). Environmental Health Perspectives, October 1977;
246.
Ali, S. Maqsood and Mukhtar Ahmad Kunjaki. "Special conmunication: Aflatoxin
the deadly poision". Journal of the Pakiston Medical Association,
September 1978; 28(9):135-7.
Allen, J.R. and J.P. Van Miller. "Health Implications of 2,3,7,8-tetrachlorodibenzo-p-dioxin exposure in primates". Environmental Science Research,
1978; 12: 371-79.
Allen, J.R., et al. "Morphological changes in monkeys consuming a diet
containing low levels of 2,3,7,8-tetrachlorodibenzo-p-dioxin". Food and
Cosmetics Toxicology, 1977; 15: 401-10.
Allen, J.R. et al. "Reproductive effects of halogenated aercmatic hydrocarbons
on nonhuman primates". Annals of the New York Academy of Sciences,
31 May 1979; 320: 419-25.
Axelson, Olav, et al. "Herbicide exposure and tumor mortality: an updated
epidemiological investigation on Swedish railroad workers". Department
of Occupational Medicine, University Hospital; Linkoping, Sweden.
Axelson, Olav and Lennart Sundell. "Herbicide exposure, mortality and tumor
incidence. An epidemiological investigation on Swedish railroad workers".
Scandinavian Journal of Wbrk, Environment and jffealth, 1974; 11(1): 21-8.
Babbitt, B., et al. "Effects of 2,4,5-T on human chromosomes". Genetics,
1972; 71(3 part 2).
B'age, Gertrud, Eva Cekanova, and K.S. Larsson. "Teratogenic and embroyotoxic
effects of the herbicide Di-and Trichlorophenoxyacetic acids (2,4-D and
2,4,5-T)". Acta Pharmacologica et Toxicologica, 1973; 32(6): 408-16.
Bahn, Anita K., et al. "Melanoma after exposure to PCB's". (Letter to the
editor). , New England Journal of Medicine, 19 August 1976; 450.
Barr, Mason Jr. "Summary of the workshop on perinatal and postnatal, defects
and neurologic abnormalities from chemical exposures". Annals of the
New York Academy of Sciences, 31 May 1979; 320: 458-72.

12

�Bauer, H., K.H. Schultz, and V. Speigelberg. "Occupational poisoning in the
production of chlorophenol compounds". Archly fur fewerbepathplogie und
Qewerbehygiene, 1962; 18: 538~55.
Baughraan, Robert and Mathew Meselson. "An analytical method for detecting TCDD
(Dioxin): Levels of TCDD in samples from Vietnam". Environmental Health
Perspectives 1973; 5: 27-35.
Beale, Mary G., et al. "Long term effects of dioxin exposure". Lancet,
2 April 1977; 1(8014): 748.
Beatty, Patrick W., W.K. Vaughn, and R.A. Neil. "Effect of alteration of rat
hepatic mixed-function oxidase (MFO) activity on the toxicity of 2,3,7,
8-tetrachlorodibenzo-p-dioxin (TCDD)". Toxicology and Applied Pharmacolpgy,
1978; 45: 513-19.
Beatty, Patrick W., et al. "Effects of 2,3,7,8-tetrachlorodibenzo-p-dioxin
(TCDD) on mammalian cells in tissue cultures". Toxicology and Applied
Pharmacology, 1975; 31(2): 309-12.
Beatty, Patrick W. "Studies of metabolism and possible mechanisms of toxicity
of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) on mammalian cells in
tissue cultures." Toxicology and Applied Pharmacology, 1975; 31(2):
309-12.
Beatty, Patrick W. "Studies of metabolism and possible mechanisms of toxicity
of 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD)." Dissertation Abstracts
International, Section B; Physical Sciences and Technology, 1978; 38i(8);
3665.
Beck, Joan. "Emotional struggle on Agent Orange." Akron Beacon Journal,
24 March 1980.
Becroft, D.M.O. and M.N. Bates. "The safety of the herbicide 2,4,5-T."
(Letter to the editor). New Zealand Medical Journal, 13 July 1977; 35-6.
Benedetto, Anthony V. and James S. Taylor. "Porphyria cutanea tarda" Cutis,
April 1978; 21(4): 483-88.
Berkley, Mary C. "Neuropathy following exposure to a dimethylamine salt of
2,4-D." Archives of Internal Msdicine, 1963; 111: 351-2.
Bernstein, Joan Z. "Interagency work group to study possible long-term health
effects of phenoxy herbicides and contaminants; meeting." Federal Register,
29 August 1980; 45(170): 57782-3.
Berry, David L., et al. "Studies with chlorinated dibenzo-p-dioxins, polybrominated bephenyls and polychlorinated biphenyls in a two-stage system
of mouse skin tumorigenisis: potent anticarcinogenic effects." Annals
of the New York Academy of Sciences, 1970; 320: 405-14.
Berwick, Philip. "2,4-Dichlorophencxyacetic Acid poisoning in man: some
interesting clinical and laboratory findings." Journal of the American
Medical Association, 9 November 1970; 214(6): 1114-7.
13

�Beyer, Karl-Heing. "TCDD das aktuelle gift." Deutsche Apotheker-Zeitung,
1976; 116(37): 1345-7.
Black, Martin M. "Selection of Dermatology: Eosinqphilie spongiosis with polycythamia rubia vera." Proceedings of the Royal Society of Medicine/
February 1977; 70: 139-40.
Bleiberg, J., et al. "Industrially acquired porphyria." Archives of Dermatology,, June 1964; 89: 793-97.
Boeri, R., et al. "Preliminary results of a neurological investigation of the
population exposed to TCDD in the Seveso Region." Rev. Pat. Nerv. Ment.,
1978; 99: 111-28.
.
Boffey, Philip M. "Herbicides in Vietnam: AAAS study finds widespread
devastation." Science, 1971; 171: 43-7.
Bogen, Colbert. "Agent Orange and skin rash - A different experience." (Letter
to the editor). Journal of the American Medical Association, 11 April
1980; 243(14): 1422-3;
Bogen, Gilbert. "Symptoms in Vietnam veterans exposed to Agent Orange."
Journal of the American Medical Association, 30 November 1979; 242(22):
"23917
' ~~
Bonaccorsi, Aurora, Roberto Fanelli, and Gianni Tognoni. "In the wake of
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34

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36
GPO 900-188

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Huddle, F. P.

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Science Policy Research Division, Legislative Referenc

RODOPt/ArtiClB TltlO A Technology Assessment of the Vietnam Defoliant
Matter, A Case History: Report to the Subcommittee on
Science, Research, and Development of the Committee
on Science and Astronautics, U. S. House of
Representatives, Ninety-First Congress, First Session

Journal/Book Title
Year
Month/Day
Color
Number of Images

Augusts
D

o

Friday, March 01, 2002

Page 5167 of 5263

�ALV1N L. YOUNG, Major, USAF
'Consultant, Environmental Sciences
V'"

fllVFM

I- iYCUNQ

[COMMITTEE PKIHT]

- A .'TECHNOLOGY ASSESSMENT

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VIETNAM 'DEFOLIANT MATTER
A CASE HISTORY..

REPORT
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TO THK

.'.SUBCOMMITTEE ON'SCIENCE, RESEARCH, AND
•"•'•• •-''• •'••••"'• :;:.":" DEVELOPMENT
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OF THE

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COMMITTEE QN SCIENCE AND ASTRONAUTICS
"^ U.S. HOUSE OF REPRESENTATIVES
NINETY-FIRST CONGRESS
FIRST SESSION
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PREPARED BV THF, '

SCIENCE POLICY EBSEA-RCH DIVISION
&gt;.---v/:i?- •"*-" " LEGISLATIVE REFERENCE SERVICE
--j.-'cV"--""-!-?-.- - • 'LIBRARY OF CONGRESS]
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Serial P

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AUGUST 8, iSGO

• Printed for thetise of the Committee on Science arid Astronautics
•"''* :\ ~-l:-l-*."l- *-:. "".'- XT.S-.GOVERNMENT PRINTING OFFICE

&gt;!Q

�n5B; &lt;
COMMITTEE OX SCIENCE AND ASTRONAUTICS

LETTER OF TRANSMITTAL

OEOUOE P. MILLE U, California. Chairman
X K. TEAGUK, Tcias
JAMES O. FULTON,
Kl'H K. KAIiTJI, J.£l»nesota
CHARLEij A. MOSHKR, Ohio
&lt; JIKCHLEK, West Virginia
RICHARD I/. ROUDEBUSII. Indiana
;r.ro Q. DAUOAIUO. Connecticut
ALPIION/,0 BELL, California
!&gt;• W. DAVIS. Geort-la
THOMAS M. PELLY, Washington
,'MAS N. DOWNING, Virginia
JOHN W. WYDLKK, New York
: I). WAGGONNEK. JB., Louisiana
GUY VANUEK JAGT, Michigan
.' 1'L'QUA. Kiori-Ja
LAIUtY WINN, JR., Kansas
&gt;i'.GE K. BROWN, JR., California
' JKRKY L. PETTI3, Cnllfornla
:I.E CABELL. Texas
D. K. (BUZ) LUKENS, Ohio
:TI;AM L. PODELL, NCT York
ROBERT PRICE!, Texas
I'NE N. ASP1NALL, Colorado
LOWELL P. WEICKEK, JR., Connecticut
' A. TAYLOn, North Carolina
LOUIS KKEY, JR., Florida
;i(Y HULSTOSKI, New Jersey
BARRY M. GOLDWATER, Jr.., CaUfonaSa
lIOBIAGGI. New Tor!:
ivS W. SYMINGTON, Missouri
, - ARD I. KOCU, New York
. CHAELICS F. DUCANDER, £zpcutive D tree tor and Chief Counsel
JOHN A. CARSTAUPUKN, Jr., CA'e/ Clcrft and Counsel
PHJLIPB. TEAQEE, Counsel
FKA.NK R. HAMMIW,, Jr., Counsel
Vf. H. BOONE, rec/micol Cons«!!ant
JAMES E. WILSON, Technical Connultant
RICIIABDP. HI.NES, Staff Consultant'
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HAROI-D A. Gour.n, Technical Consultant
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PHILIP P. DICKINSON, Technical Consultant " '"
WILLIASI G, WELLS, Jr., Technical Consultant
JOSEPH M. FELTO.V, Counsel
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K. GCILD NICHOLS, Jr., Staff Consultant
ELIZABKTU S. KEKNAN, Scientific Research Aseittant
FRANK J. GIROOX, Clerk
DE.VJS C. QOIOLET, Publication} Clerk
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K. SHCLLAW, Aeslslant Publications Clerk
JAM EH A. Ross, Jr., Minority

Staff

SUBCOMMITTEE ON SCIENCE, RESEARCH, AND DEVELOPMENT
EMILIO Q. DADDARIO, Connecticut, Chairman
"• W. DAVIS, Georgia
ALPIIONZO BELL, California
3. WAGGONNEU, JR., Louisiana
CIIARLKS A. MOSIIEK, Olilo
iVR K. BKOWN, Jd.. California '
D. E. ( B U Z ) LUKENS, Ohio

,K CAHKLL. TPIUS
:KAM L. POL-ELL, New York

..&gt;W, SYMINGTON, Missouri

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LARKY WINX, JK., KHIIMM
JERRY L. PUTT-IS, California

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HOUSE OF KEI'RK?EN'TATI\XS.

Coanirrm: ox SCIF.XCKAXD ASTRONAUTICS,
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Washington, D.C., Augusts, 1969.
Hon. GEORGE P. MILLER,
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Chairman, Committee on Science and Astronautics,
House of Refn^esentatvues, "Washington, D.C.
DEAR MR. CHABOIAX: The Subcommittee on Science, Research, and
Development is carrying on a continuous study of technology assessment—seeking the best means of providing for the Congress an early,
warning of the unanticipated hazards or benefits from applications
of science.
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Tho process of technology assessment can best be seen -with reference
- to historical episodes, but the record of such episodes is often incomplete! If we are to&amp;ecure a. useful working knowledge of the elements
oif the process, it is expedient for us to take opportunities to observe
.closely those episodes which chance makes accessible. It was for this
reason that the subcommittee commissioned the study "Technical Information for Congress" by the"Science Policy Research .Division—A
-documentation-of 14 important case histories'which-had attracted, con-gressional attention since World War II.
This report is a 15th case history. It has special significance for
Congress in. the technology assessment context, since it represents a
conflict which is current but which has developed a sufficient history
.to give it perspective and meaning. It is distinguished from the other
case histories in that the assessment was performed by the scientific
community itself, and outside of the Halls of Congress.
We are'dealing here with the controversy over the military uso of
chemical defoliants and herbicides in Vietnam. The issue contains all
. the elements that complicate such assessments: a difficult problem of
ecological impact, clouded by the political controversy surrounding
the Vietnamese conflict it.«e-l f."

The report transmitted herewith does not address itself to the merits
of the issue; .it does not judge the propriety or impropriety of the
military use of herbicides. Instead, it centers upon the- process by
.which tho American Association for tho Advancement, of Science
undertook to assess tho ecological effects of the military use of chemical
defoliants -and herbicides in a zone, of activity. The cooperation of the
.participants in tho assessment was, of course, indispensable to the
study, and wo were most fortunate that they fully appreciated the
professional nature of tho proposed inquiry and were unstinting in
providing the documentation for it.
At my dmv( ion, the Legislat i ve- Reference Service secured the status
of observer to tho prom'ilings..Frwu this vantage, point tho study is
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�ssessment in a ^^HFuit can guide similar projects in the future. It
,-ill aid tho variora^roups who are developing'teclmology assessment
apabilities for the legislative branch, and in other institutions.
Sincerely yours,
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EMIUO Q. DADDARIO\,
• kairrnan, Subcommittee on Science, Research, awl Development.

LETTER OP SUBMITTAL
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T H E LIBRAKY o r CONORKSS,
•LEGISLATIVE EEI-TREKCE SERVICE,
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' Washington, D.C., July 30,19G3.

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Hon. EMILIO Q. DADDAIUO,
Chairman, Subcommittee 'on Science, Research, and Development,
Committee on Science and Astronautics, House of Rcprcsenta-'
fives, Washington, D.C.
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•DEAR MR. DADOAIUO: The report submitted with this letter results
from arrangements made at your direction to follow the prepress of
the American Association for the Advancement of Science in its investigation of'the environmental effects of defoliation in Vietnam. Mr.
Richard A. Carpenter, Assistant Chief of our Science Policy ll^carch
Division, sought permission from the major participating organizations in early 19G7,for LRS to act as an observer of the a^'.-^ment
process as it took f^lace. In this way, the problems and successes of
assessment methodology could be more accurately ascertained than by
the usual ex post facto examination. Wo, of course, made it clear to all
parties that the LRS had no interest in the defoliation-ecology question itself but only in how the assessment was.car.ricd out.
'." 'The cooperation of-the following persons and their associates made
.the report possible:
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. ' Don K. Price, dean, John Fitzgerald Kennedy School .of Government, Harvard University.
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Dr. Dael Wolfle, American" Association for the Advancement- of
Science.'
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Rodney W.. Nichols, Office of the Director of Defense, Ucsearcli
and Engineering.
Dr. William B. House, Midwest Research Institute.
John S. Coloman, Xntiona'l Academy of Sciences.
Tin1, report was written by Franklin P". Huddle, of the. Science Policy
Research Division. Tn view of Dr. Huddle's earlier authorship of tho
study, "Technical Information for Congress," the present report can Ixs
regarded as in a sense supplementary to that longer work, dealing
with a similar kind of problem but in the hands of a distinctly different group.
Tho Legislative- Reference Service is gratified to have the opportunity to participate in this illuminating series of analyses of tlie complex
problem of accommodating our society to the changes wrought by modern science.
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-...:.._ - .-•-"Sincerely yours,
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LESTMI S. JAYSOX,
Director, Legislative Reference Service.

�CONTENTS
Letter of tr/insmittal
'Letter of submittal
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I. Introduction
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Development of potent new organic herbicides
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Second thoughts about the virtues of herbicides and other pcstioi des
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II. Evolution of the military herbicide program.,..
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Development of herbicide warfare in Vietnam
Full-scale military use of herbicides, 1900-60
Decisionmaking arrangements for military, uses of herbicides in
Vietnam
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III. Criticism of herbicide warfare
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IV. Role of the AAAS in iwsedsing war use of herbicides
Organizational structure of the AAAS
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AAAS council's action on Pfeiffer resolutiori
. Implementation of the 1906 AAAS resolution on herbicides
Implementation of recommendations of thci AAAS ad. hoc committee
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Implementation of recommendation for ecological field investi••'/
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gations..:
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The Midwest Research Institute study of Ideological effects of
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herbicides
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• .". Cross-pressures within AAAS, December-January, 19G7-6S
National Academy of Sciences review of MRI report
., , ' . • ! . ' Review of MRI report by National Academy of Sciences....,.-- .
•'•'' ... ' '•"&gt; 'Press reception of the'MRI report..1.-....IL,'1
'..".J.'._•.•-. ".
i .Assessment of MRI report by AAAS board of directors....
'.'-• ' • • • ; • Exchanges of AAAS correspondence with State, Defense, and
' ' ' j • United Nations
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'• • State Department attempt at herbicide assessment
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. . • U.N. actions after appeal from AAAS
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. Renewed AAAS appeal for field ecological investigation
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.-• . ' Apparent reduction in AAAS concern over herbicides in 1069
D.r. Pfeiffer's volunteer .herbicide assessment expedition
V. Conclusions and observations
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TABLES
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Estimated extent and cost of chemical weed control in the United States,
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Composition and characteristics of inilitary lierbicides
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Estimated area herbicidally truated in South Vietnam through 196S
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APPENDIX

III
V
1
2
4
7
9
15

17
22
28
29.
29
31
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33
34
35
38
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4446
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53
56
58
61

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15

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Appendix A:
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• Draft of pending section of manual on use of herbicides for military
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67

�I.; INTRODUCTION

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A new military technology of defoliation by aerial spraying of herbicidal chemicals was introduced in 19C2 into the Vietnam conflict.
The teelmology was called into play as a means of saving lives—pro.tecting troops, shipping, and aircraft from ambush from the- jungle
cover; it was also used to complicate the adversary's logistics—to
deny guerrillas their sources of food from remote garden plots by the
spraying of these crops from the air with crop-destroying chemicals.
These uses of technology were condemned as immoral by virtue of
their nonspecificity; as contravening tacit international policy against •
chemical and biological warfare, as crossing a threshold beyond which
lay the threat of mass destruction by chemical and biological weapons;
they were also challenged .on the more technical grounds that the
generous tise of these potent Chemicals over wide areas by insufficiently
trained military personnel might wreak serious and lasting injury to
a region's ecology.
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• The role of U.S. scientists' and their professional organizations in
calling for technological assessment of military uses of herbicides, and
in participating in such anj assessment, was determined by Representative Emilio Q. Daddario' as being a suitable subject ior this study.
Its purpose, accordingly, was not intended as a judgment of the merits
. of the decision -respecting military use-of herbicicUv,-but to illuminate
"the complicated process within a large, interdisciplinary organiza• tion of scientists by which a political issue with a scientific content
was passed in review. Many (such issues come before the American
Association for the Advancement of Science. Activist groups continually strive to compel the association to take a stand on other political
issues they care deeply about.! The effectiveness of the association as
.a policy-supporting organization, and the question as to the proper
role of scientists in pursuing political .issues, are central elements of
the study.
!
The relevance of the study as a subject of interest to the Congress
derives from a number of related considerations. In it. the Congress
can find its function of technology assessment being attempted by a
group of concerned citizens, mostly with scientific qualifications. The
problems encountered by this group in performing its assessment can
be regarded as "the other side-of the coin." The pressures and thought
processes of the group mirror those, of the Congress, and provide a
convincing demonstration of the difficulties of the task, even when it is
not accompanied bv the larger responsibility of the Congress for lawmaking in the public interest, and when, on the other hand, the participants enjoy some extent of.special training in the subject matter
in question.
Another relevant, aspect is the preoccupation of the Congress in 1%9
with environmental quality. Much pending legislation, and many
(1)
32-405— CO- — 2

�ini uniL-t m^^^^Hu mans iragiju environment, me uunc'sMnes
[^countered by a pBrcssional group in ordering and resolvingcriTEs'onlental issues related to the massive and repeated application of ferbiides in Vietnam serve ,1 useful warning: and object lesson as to the
cod for systematic,, objective, nnd deliberate approaches on the part,
f the Congress in dealing with legislation aimed at tho prcscrraltaon
r restoration of environmental quality in the United JStates.
In the study ''Technical Information for Congress," it. vras ptKiatod
nt. that "In the 'management of a. political issue, with substantial sciitifie or technological content, the political issue is always larpstr in
'•ope than the scientific question within it." The study suggested tiiat
In principle, the scientific question needs to be dealt with first." Sfore\"er, it was important that, the .scientific question be. "carefully fctsned
&gt; that the answer to it p rondos a useful and significant piece ofevicnco. for guidance, in the consideration of the broader political issue.*'.
';;-3 present study enlarges indirectly on this point by revealing" sthe
;;:vme difficulty encountered by a, technically oriented group in sep: icing out the technical issue, and defining it in manageable terms. It •
rves notive, by inference, that a politically oriented group -\uwnld
uwrience even greater difficulty in separating tho technical from tthe
&gt;Htical issue for analysis and decision.
of Potent New Organic Herbicides
Agricultural research in the 1930's had identified a roup of plant.
••rnones that regulated plant growth. By 1939, 54 differentsubsteaices
•.•;•:: listed that had this effect. The most, powerful of these was ttlie..
.epical 2,4-dichlorophenoxyacetic acid, later nicknamed "2,4-D."
he chemical synthesis of this compound was describee) in the Isteraire in June 1941. Experimenters often observed that in overdose of
•;e of these plant hormones injured and even killed plants. OSK re.1 rcher, E. J. Kraus, head of the botany department of the University
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Chicago, suggested in a letter to two of his co-workers, in Angusf
'41, that the^o compounds might be useful as weed killers.
Karly results in his researches led Kraus to bring this promising mew
t-haoiogy to the affonf ion of n committee of the National A en demy of
•it-TWS-National Kese:uv,h Council under tho direct ion of
&lt;stvk, established at. the rc&lt;|uest of Socivtary of War Henry L.
:; to provide advice on all aspects of biological warfare. Kraus wrote
.•if "il&gt;c toxic properties of growth-regulating substances for t3ie«3c:u.'fion of crops or tho limitation of crop production'' nu^ht Iws of
f«&gt;:vst to ih(&gt; eommilt&lt;x\ K x p o r i m o n t n l rosoaivh in (!) is field
It
formally l»r&lt;&gt;u&gt;;ht under an A n u v oo
oontrni't
s-'tty of Chion^*, in I:1!,'*, In cvnijunction with tins worSt, a
•• u--U p!,v:r,u&gt;\ \\;
muJoi-wav rtf tho Kvvasvh station of

was intensified as of possible use in the "island-hopping"' car
Gen. Douglas MacArthur. The method of clearing landing urca.-s of
foliage at that time,j\vas by saturating them with high explosive shell
bombardment by naval artillery- Kraus reported verbally on his research progress'to tho "ABC" Committee of the Academy of Sciences
in February 1943, and .submitted a preliminary written report to the
committee March .8, describing his experiments. Camp De trick, Md.,
had been establish as a research center for biological warfare research
in November 1042; in January 1944, the Army decided to make her- bicido research a major program at this center. Nearly 1.100 substances
were tested there, under the, direction of Kraus with A. Q. Nonnan.
However, "The chemicals were never used abroad, and the war terminated before we could get the materials in the field."z
At the conclusion of World War II, Secretary of War Robert P. Patterson released a letter report from Merck, describing biological warfare research conducted by the United States. Merck cited as an important accomplishment of this program, the testing of "the effects of
more than 1,000 different chemical agents 'on living plants." Later
Merck was quoted^ as stating that "only the rapid ending of the war
prevented field trials in an.active theater of synthetic agents that
would, without injury to human or animal life, affect the growing
crops and make them useless."
In April, 1944, the emphasis.of the research at Beltsville shifted.
Detrick had a vigorous, war-oriented program underway. So the Belts-;
..'ville group'returned to their earlier interest in 2',4-D as a weed killer.
In June 1944, in'an article in the Botannical Gazette, Mitchell, in association with Charles L. Hamner (another former student of Kraus),
suggested publicly for tho first time that 2,4-D had "some importance
in connection with the differential killing of weeds." 3 Another report
in this journal in December 1944 elaborated on this work. The chemical was found highly toxic to bindweed, dandelion, and other broadleafed plants, while-leaving lawns (bluegrass) unharmed. The public
interest in the. new herbicide was intense. In 104 "&gt;, the American Chemical Paint, Co. marketed the first systemic herbicide under the brand
name "Weedone." Other companies were soon licensed to produce- the
• material. Tests that year revealed that the new chemical was indeed
a revolutionary discovery. The toxicity level of tho new chemical, for
man and animals was i n vest i era tod, and determined to bo low enough
to make the chemical acceptable for general use as a wocd killer. Lists
of weeds killed by 2,4-D lenirfhenod. Costs dropped from !?12.."&gt;0 a
pound in 10 14 to SO'.'iO a pound in Ifl.'O, The material was easy to handle.
noncorrosivo, and effective in uso. Production went up fast: 017,000
«C. &gt;:. MlimrU-. "Crop nirtvMn rvrii!i«!tv&gt;n Prosrnm." PnwMlncs &lt;&gt;f tho Third rvMi.-u
Hon rmif-ivmv. Atic. in j j . Tl'ii.V p. II. Tlu&gt; ro&lt;t of th!&lt; luwnnf t.- li;&gt;«ist on an .'irtlclrp,v (ialo K, iVtorHon. "Ttio Dlsi-owry niul IVvplopnn'nt of ",4-n", Affrioaihiral lil*t&lt;&lt;rr
(vnj, -!t, No. ,X Jnl,v 10c!T&gt;,

s*
• ft ^v..»f

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&gt;

Substnnws."

�o.ur.ds in 10-15, 5,460,000 in 10-1G, -and'more than 14 million by .1050.
'he author of .thj^^fcipr concluded:'
Ironically, 20 yc.^^^Kr Knius had suggested it to the National AcacEemy of
clonces, 2,4-D becjSiWi too! of chemical warfare, * * * Developed t'&lt;»x war,
;t vi^sijtiod for agriculture, the U.S. military at last found application ifor its
•snrributlou to the development and testing of 2,4-D.4

A survey of the domestic use of herbicides in the United States, conucteJ by the Department of Agriculture, reported in August. 1005,
•;U in tl'ie year 1062 a total of TO million acres was treated (see table
), at a cost of more than $270 million. The report note that by 19G2,
bout 100 herbicides in G,00 formulations were available. The rate of
creased use was such that acreages treated would continue to clkmble
i 10 years. (Actually, they leveled off at about 120 million acnes by
C35.)'
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BLE l.-ESTIMATED EXTENT AND COST OF CHEMICAL WEED CONTROL IN THE UNITED STAGES, 1962

Crap or area

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25,302
5,433
2, 827
' 18,931
940
8
• •
310
15
• .
362
25
2,665
- 20 •
439
29 .
S51
-'.
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.'
171
-. 2 .
16• ' • ' - - 30
.1
26
21
.267

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:---.--..tS

. .,«
- - • :e-is
• •.-iisi
r:;;
- t-jrs

...

_

:-,
; f.-.;ts and nuts

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;~!crnls

15 28 '.
45

15

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!;r~s
;:!».-!&lt;}

V:jj.'jii;f...V.~IIIIIir"
Tc^a!

Total acreage Harvested acretrealed
aja trealed
(thousands).
• (percent)

States reporting
(number)

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20

31
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38. 8 • . 557,600
16,805
34.9
10,835
' 10.2
,• '29,579
23.5
••
6,250
' •
53.0
' 2,565
22.0
' . 2,237
.. . 32.8
5, 258
.' 23.1
• ,-.
2.416
: .. •. 16.1
35.5 : -' . 8,634
' . - • ' . 12.4
•
•:•• 1.1
:
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:
187
V. ' ' 4 . 6 ' •'.'
650
: - . - . - • 27.0
• 2,397
9.7

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51
672
.. - 412
4,714
2,262
'
274 ..
3,612 ..
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70,6£7

Total cost, all
herbicides and Averajprast per
applications
:K'i. all
(thousands)
treatments

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J2.28
3.09
•3.83
1. 56
6.65
8.27
'
6.18
1.97.
-5. 50
.•
9. 09
. •5.95
, • -••• 7. 12 .'6.23
' '
. •••• ,25.00
.8. 93
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•:-,:• .-'w - •'&gt;

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969
.15,368
• 1.794
' ' 13,340
6,265 . •
' '.3- •. .
••*' ' 2,752
83,714

24.8
8. 4

5

. -

41

270,746

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'19. 00
22. 86
8.69.
2. 83
2.77
10.04
.23. 18
3.86

£j:luc&gt;s (ores! planlinjs a n d noncrojland.
• ' : . ' , • • • ; •
Kry.: U.S. Department of Agriculture. Aiiricultural Rosearch Servics and Federal Extension Service. "Crops Rraeirch;
t?i of Etient and Cost of Vsced Control and Specific Weed Problem}." (Aug. 1955, ARS 34-23-1), p. 3.

'."on&lt;ZT~ftf&gt;ughfs About the Virtue* of Ilerliicidfifs and Other Pestwldes
The explosive rate of acceptance of the new technology eventually
ve rise to apprehensions as to its possible adverse side cllects. A. techlogical assessment of the domestic use- of herbicides— and of jwjsti!e,s in general — *ivas triggered by tlio appearance in 1002 of an am fluHal popular bo;1; by Kachel Cai-son, titled "Silent Spring." This
u&gt;k described disadvantageous consequences of pesticides, incliudingf
a possibility of tho toxicity of somo of thorn to man or animals, ftheir
long-term biological (e.g., pathogenic, carcinogen icr and
c) efTects, and the ways in which postic-ides reached beyond
"The Dl-scovery and Development of 2,4-D." Op. clt., p. 253.

their intended target organisms to strike down others m&lt;a
sometimes insufficiently appreciated. This last type of e&lt;'"
logical damage caused by pesticides—was emphasized .
book. Although Miss Carson reserved her most severe criticisms for
insecticides, she did not spare the weedkillers:
The legend that the herbicides are toxic only to plants and so pose no threat
to animal li£e has been widely disseminated, 'but unfortunately it is iios
true (p. 41).
[Arninotriazole] is rated as having relatively low toslcity. But in the long run
its tendency to cause malignant tumors 01" the thyroid taay lie far more significant * * * (p. -13).
Among the herbicides are some that are classified as 'mutagens," or agents
capable of modifying the genes, the materials of heredity. We are rightly.appalled
by the genetic effects of radiation; how, then, can we be indifferent to the saiae
effect 5u chemicals that we dis.senunatwl widely in our environment? (p. -13.)
• * * * The whole elo.sely knit fabric of life has been ripped apart (p. C7&gt;.
[By this "shotgun approach to nature"] the spraying also eliminates a great
many plants that were.not its intended target (p. 67).
* * * The wholesale broadcasting of chemicals would be .seen to be more
costly in dollars as well as infinitely damaging to the long-range health of the
landscape and to all the varied interests that depend on it (p. 09).
The most widely used herbicides are 2,4-1), 2,4,5-T, and related compounds.
Whether or not these are actually toxic is a matter of controversy. People spraying their lawns with 2,4-D and becoming wet with spray have occasionally developed severe neuritis and even paralysis * * *. It has. been shown experi• mentally to disturb liie basic physiological process of respiration, in the cell, and
to imitate X-rays in damaging the chromosomes (p. 75).
•[Fruit flies] developed mutations so damaging as to be fatal oa exposure to oae
of the common herbicides * * * (pp. 100-191).
The full maturing of whatever seeds of malignancy have been sown by these
chemicals Is yet to come (p. 201).5

-.• • Various-technological-assessments -were serin' motion'by the Carson
book, or took place concurrently with it. A series of reports were
issued by a committee on pest control and wildlife relationships of
the National Academy of Sciences-National Research Council.6 The

lengthy investigation was conducted by the Government Operations
Committee'of the Senate, culminating in a final report, July 21, l!H'&gt;t&gt;.
Tho conclusion of this report otiers perhaps .the best consensus available^ on the broad question of whether or not herbicides (and other
pesticides) should bo used, and if so under what circumstance;;. It
recommended that the present regulatory system should !« strengthened to prevent unintentional contamination of-thc environment, That
• Knclit'l Carson. Silent Spring. (Greenwich, Conn. Kiuvcstt Publications. Inc 10S2
100(1.) -'ill p. phut Index.
.
• N a t i o n a l Academy of Sciences. Committee on t'cxt Control nnt! Wildlife Uclatlotichlps.
"A Symposium on IV-t Control anil Wlltlllfv Kvlntlunxlilpn." By Committee on Pent Control and \ V I I &lt; t l l f i &gt; ili'latlonslilpK. Mar. 10, lOfil. 2,1 pp. (Piinl. SOT) : "I'est Control antl
Wildlife Ki-lalluiiNliljis." Pt. 1 : "Evaluation of Pesticlili-Wlltlllfe l'robl«-m«." (li)(i!J), 2S pn
( P u h l . ftl'O-A) ; I't. 2: "1'ullcy anil I'twilimiH for 1'tint Control" (IOC,:;), 5.'! pp. (J'ubl,
02(»~I1) ; and I't. 3: "HMi-aroli Needs" (iuii:&lt;), 2S pp. (I'nbl. Iti'u-C). (Wanhiiigtun, H.C..
JNntlwial Academy of Si'lerit/i'H.)
7
U.S. I'ri'Hldi-tit'a Hdviivc Advisory Committee. "Cue of I'estlclilen." Tho WJiltc House
May tn. it»«:i.
""KfTeetH, 1,'tn'H, Control, anil Itefearcli of .\irrli'ul(\tr«l IV
'«&lt;•«." (A report tty mirVi&gt;y« mid I t i v t ' H t l p i t l n i i K HtnlT.l April 1H, lliiin. Hi'pr"&gt;hici'&lt;l i n . ' •.. t'&gt;&lt;i.i;rt'ss. IIiMis«'. Comnilttri; tin ApiiroprlritloiiH, Jd'iiartmi'at of .Vv'rii'iiltiifi' Aj&gt;!'?&lt;ii4..'»i&lt;t!i&lt;» f«r H»ilti. H"'iiriiif."M
before a Hiitifoinmllti'tf of tlnr • • * pt. 1, bUlh Cuiig,, Snt »«•»«. (W&lt;t»lil»jitua, U.S. Uuveruiut'iit t'rliitlin; Office, 1000).

'

' '

.

.

"
•

'

•

.

&amp;
V,

�Fcck'rai programs of jh'.-t control should be coordinated more closely,
timr, lieulth WCJM^IS relevant to pesticide's should ho expanded, and
that scientific ^^B'h into the effects of pesticides should he stepped
up to provide ^H^0 adequate. basis for future national policy.9
As a result, tiffin, of the apprehensions rinsed by the Carson hook,
the need vras recognized for more closely controlled use of herbicides,
and for more penetrating research into the ecological consequences of
their u?e. At the same time, it became more fully appreciated that thebenefits conferred by this use, and the extent of reliance on it for icgrieulturejn a technologically oriented society, could not easily bc»:'f oregone. Use would continue, but under measured control that would be
further refined as knowledge of adverse effects became more precise.
It was during this same period of technological assessment of the
domestic u?e of pesticides general!}', that the military use of herbicides
L-egan and expanded in Vietnam. This &gt;vas perhaps not the first time
that defoliant, chemicals were used in counter-guerrilla warfare. 10 However, their use in Vietnam certainly appears to have been n
unprecedentr-d in terms of its extensiyeness, scope, and systematic nsi
nature of
appl i cation for military objectives.
As the military use of defoliants in Vietnam intensified, various
_
questions were ra'ised_by groups, and individuals in the United States
concerning the. morality, the legality, and the possibly adverse longr &gt;nge consequences, of the program. The rest of this study describes, in

governing body and with the Department of Defense, (d) the efforts
of the Department of Defense to perform its. own assessment of the
technology, (e) the subsequent efforts of scientists to perfect their as-sessment, and (/) the present status of the defoliation assessment. The
study .concludes with a statement summarizing the observations to be
drawn from this case as an example of technological assessment moti-'
rated by a large professional society, relative to national science policy.

II. EVOLUTION OF THE MiLITAKY HERBICIDE
PKOGI1AM
The close of World War II was the signal for a varis^^f small
insurgent uprisings throughout the world, usually characterized by
informal .or guerrilla forces in challenge- of existing governmental
authority. These occurred in Greece, Malaya, Cliina, Cuba, Tndoncsia|.j
the Philippines, the Congo, Cyprus, Algeria, and elsewhere.
In some- respects, the- British camgaign against the guerrillas in
Malaya served -as a prototype of the later conflict in Vietnam, in that
.it was to combat a Communist-inspired uprising in a jungle area of
Southeast Asia, with an essentially colonial economy, employing weapons of terror against a technologically sophisticated adversary. An important difference was that in Malaya the guerrillas were not in contact with an outside source of logistic support .and had no sanctuary.
Tactics of counter-guerrilla warfare in Malaya, accordingly, were
concentrated on: (a) keeping the guerrillas separated from the civilian
noncombatant population by fortifying and protecting villages, (I)
keeping military pressure on guerrillas to wear them down, and_(&lt;?)
denying the guerrillas sources of food.11 Despite a vigorous campaign,
. however, thejMalayan guerrilla war cost the British heavily in wealth,
and dragged,on for a decade..
Early in his administration, President Kennedy was motivated by
the first Cuban crisis and other manifestations of political instabilitv
in developing countries to increase the U.S. capability in dealing with
"guerrilla forces, insurrections, and subversion." Such-a. capability
would entail a general strengthening of military resources of anthropological, cultural, -and other social .science data.in relevant areas of,,
the -world. In Shis March 28, 19G1, message on the Defence'budget, the
- President said that the U.S. interests were threatened by limited guerrilla warfare such as had brought Castro to power in Cuba. To counter
the threat of being "nibbled to death,1' as the President expressed it,
the United States needed to strengthen the capability for lower levels
of intensity of Conflict. ". •
;
.
. .
To meet oxir own extensive commitments and needed Improvements in conventional forces, 1 re'commend the following: A strengthened capacity to meet limited
and Kuerrillii warfare » * * V/e need a greater ability to deal with guerrilla
forces, insurrections, and subversion."

Within limits, the British experience served as a guide to the
'.Government forces in South Vietnam, and to their U.S. military
» Several references stress the I m p o r t a n c e of denying (,*iierrill:i* sources of fivxi. Ynt
example, Lt. Col. Unwliind S. N. Mans w r o t e : "The most !&gt;ui.'i.'essfiil operations in Mnla.vn
"were those aimed itt d e n y i n g liny form of food supplies to t h y (RiierrilUis J," (flNoj "As
'{heir fooil caches were reduced, the [(jm'rrlllasl crew more and more dcspentte. They took
risks that exposed them to SKurlty Force retaliation . . , Lack of food often forced .1
( S i K i r r l l l n ) to surrender." ("Victory 111 Mnlaya," I n : I.t. Co!. T. X. Creoiie ( e d . &gt; . The
Guerrilla — Anil How To Fk'ht Him.. .Selections from the M:ir!ne Corps G;ui'lte. (Frederick
*
'
A. Praeprer, New York. ItillS, I*riie&gt;:er I'uperhnckg), pp. lU-t-325. Joseph P. Kut^er also
The
stresses t h i s theme : "The tftierrllins started to t&gt;'?\ the pressure of th?
• dlMlenlty of u m l n t f t l i i t n K local Kiipp'y lines n f t e r the relocation of the junplo f r l n i n ireilu&lt;:0'l them to depemlin^' upou crops ralseil In Jungle elertrin^s. The i.i^t presented the
British nlr linn with suitable targets. The HAP w u u l i l ohserve' the urea Hiut nt 'he propitious moment dampen the spirits of tht; helea&gt;?uerej t,'»err!ll«s by s p r n y l n ^ the fn.iil
plots with polmui or stttlnt; nllre a llelil ntmnt to be hiirve«fe«l." ( I n : "Irr«'K&gt;i!'ir Wart'arc
iu 15
Transition." M i l i t a r y A f f a l r x . (Vol. X X I V . No. ;t Fall, lldio), p, 121.)
I'resldiMit John F. KiMinedy. Special inessn^-e to the CVnt;r&gt;:xs on thi; it»fen«e bu'ltret.
'In I'ubllc I'lipers of the t'ri'KlriVnlK — John F. Kennedy, 1001. (Washlngtoa, U.S. Oor- eminent i'rliitlni; Oltlce, ll)(&gt;2), p. 236.

�supubrtcrrtf,"iiT the "cleVv'. "nicnl of strategy and tactics in the Vietnamese war, Ai^ng the important differences wore the fact that the
guerrillas in U^^tter war were able to concentrate in larger force
unit?, to ovei^^Billage redoubts, and then retreat to sanctuaries
in the jungle, ^Rh Laos, Cambodia, or north of the demilitarized
zone (DM2). The rice growing areas in the delta country, south and
east of Saigon, were abundant sources of food on which the whole
country depended;_ these sources could bo denied to the guerrillas only
by physically holding the area and taking custody of the crops as they

cHu-ed areas to supplement their supplies of food from above the
jDMZ.^These plantings were similar to the slash-and-burn agriculture
'.••: 'irionally practiced by the indigenous Montagnard population in
' • '.-ria.
• ..-ties of the guerrilla forces in South Vietnam in general involved
r-,_ • ' . ; ; ' f u l use of jungle cover and the merging with the local pxopular.~ -:i, as iu Malaya. There were roadblocks, with systematic taxing of
:;-yre.lers; retreats to elaborate underground strongholds in tine fore-^s; ambushes along roads; sniping at river traffic from the bush;
kidnappings, assassinations, and terrorist demonstrations. Logistic
transport took place.at night, or under the forest cover; use was made
a&gt; sanctuary of neighboring territory formally denied to defending
troops of the.Republic of Vietnam.
V . , . -*.

_\-'J i I V

i^j^ivVlV^

» J » . l J^y-Wi. V .

.1 A ' / » * ^ V &amp;1. i

\J±1

JLXtl^tlllJJtJI.

I J

O.V/VJ J..

JL J. U^3i.U.tMJ V

IX *:rn advised President Kennedy that "the forces of International
Communists now arrayed a a i n s t us are more than we can meek with
t:-.-;_ resources at hand. We must have further assistance from the .
I .:fcd States if we are to win the war now being waged against us."
(.'.. December S, the U.S. State Department issued a report describing
i '....• pattern of guerrilla activity in South Vie.tna.rn, the increased use
o: rerror tactics, the support received from North 'Vietnam, and the
V:-:- of Laos as a base and logistic supply route. Shortly afterward, on
I-r!&gt;ruary 3, 1%2, the. American Military Assistance Command (Vietn i i a ) was established to supervise American military personnel and
coordinate joint planning; by mid- 1962, U.S. military forces In the
ait-a reached the number of "12.000.
Popular disaffection with the Diem regime, during IOCS, culminated in its overthrow by a military coup, November l; sfoortly
before the assassination in the United States of President Kennedy.
At the end of the year, President Johnson after consultations, with
Defense Secretary McXarnara and CIA Director McCone, assured the
new government of continued U.S. -support. Tins position was confi.-inod by jointjresolution of Congress, signed August 10, 19G4, asserting that the United States was "* * * prepared, as the President
determine.", to take all necessary steps, including the use of armed
force. to assist any member or protocol state of the Southeast Asia
Collective Defense Treaty requesting assistance in defense of its freedom," (Public Law 88-108). This resolution became law 8 days after

"~tnu 'lonkiu liuii incident iii winch the; U.h.S.
attacked by three North Vietnamese torpedo boat--. BonibL^ .strikes
against North Vietnamese objectives by U.S. planes bcgj^BbPe-bru-,
ary 1965, and a U.S. Marine battalion landed in Vietm^^HLrch 9.
Thereafter, the war escalated in intensity, with progre^^ely increased U.S. participation. U.S. forces in Vietnam grew from about
23,000 on January 1, 1965, to about 181,000 at the end of that year;
by the end of 1967, they numbered 480,000.
' The essential failure of the village redoubt approach to pacification
in 'South Vietnam meant that increased emphasis would new! to be'placed on other aspects of strategy found effective in the Malayan
counterinsurgency campaign (the closest prototype), and that additional new techniques would also be needed. Use of herbicides _ to
remove foliage along thoroughfares as cover for ambushes, which
may have been used in a small way in Malaya, become an important
part of U.S. practice in Vietnam. The harrying of guerrilla forces,
and" attempts to encircle guerrilla strongholds,_ required both aeriul
reconnaissance and close ground support of military forces; removal
of protective cover of foliage was helpful in both cases. Finally, the
denial of food, which had definitely played such an important role
iii the British Malayan campaigns, was extremely difficult in the
Mekong Delta region, which was generally a food-surplus area. However, in the areas west and north of Saigon, the population was more
sparse and food production much less abundant: in these areas, it
seemed feasible to develop the strategy of destroying subsi5teri.ee crops
of the guerrillas, thereby increasing the burden on the logistic supply
coming .from North Vietnam.^Beginning in 19G1_, herbicides grew to be
- a n important element in Vietnamese counterinsurgency,
Development of Herbicide Warfare in Vietnam
Experiments with defoliant and desiccant chemicals as herbicides
had continued at Fort Detrick, after World War II. Some 1-2,000
chemicals had been tested and the most promising 700 screened in
greenhouse and field tests. Some of them had been tried out on tropical
vegetation in Puerto Rico. An extensive test, over an area of 4 square
mileSj had been conducted at Camp Drum, N.Y. Finally, "a variety_of
chemical agents were shipped to the Vietnamese military authorities,
and from July 1961 to April 19C2, a preliminary series of defoliation
trials were conducted under the guidance of J. W. Brown." The program was then halted, pending an assessment of its military eU'ectiveness. These tests showed that -2,4-D and 2,4,5-T (see table '2) were
effective defoliants when .applied during a period of active growth; in
addition, cacodylic acid sprayed from aircraft showed promise for use
against riceficlds, While further tests were being conducted bv U.S.
military forces and under contract, in Thailand, Texas, and Puerto
Rico, Vietnamese military forces and U.S. planes spraved jmhgrove
and nipa palm vegetation along canals and roads east or Saigon, with
considerable improvement reported .'in overhead visibility of the
ground." •
.
|.| n

,

nl

'i

' '

•

"Mill report, op. Clt, pp. 113-115.

fla-IOB—00-

•

•'

•

�ana or limited potential effectiveness.

.
Exeerpts:

TABLE 2.-COMPOSITION AND CHARACTERISTICS OF MILITARY HERBICIDES

Agent

Composition

Pounds per
jallon AE Purpose

n-Butyl ester 2.4-D, 50 percent(vveiglit)....
n-Butyf ester 2,4,5-T, 50 percent (weiaht).

4.2
3.7

n-Eutyl eslsr 2.4-D 50 percent (weight)...
ti-Butylestef 2 1,5-1,30 percent(woigM)..
Isobuty! sster 2,4,5-T, 20 percent (weight)..

Oran£*

4.2
2.2

Total.
While
CTsrdon 101)
Total.
S'u;
(f-ii/tar 5SM)

forfeit,

brush.

8.9_

Tout.
Purr's

General defoliation;
broad-leafed crops.

General defoliation; interim- agent used
' interchangeably with oranse.

8.9
Trf-isoprapanalamiiie 531(2,4-0
Tri-isopropanateminesJltpicIoram-

2.0
Forest defoliation; long-term jangle
. 54 . control, brush suppression!.

2.54
Sodi'jm cscodylate, 27.7 percent
Ffee c.3cod&gt;iic acid, 4 8 percent
Water; soii.'um chloride, bol

3.1

Rapid defoliation (short durctiion); Jrassy
plant control, rice destruction.
-

Source: MidAcst Research Institute. "Assessment of Ecological Effects of Extensive or Repeated Use of Hterbicides."
3) W. 3. House «t 2!. Final report, Aug. IS-Dec. 1, 1967. (Hereinafter called "MRI Report".) Sponsored fc# Advanced
?-jifvcMPisiKtsAsi.-iiy of the Department of Defense, ARPA Order No. JOSS. MRI Project No. 3103-8 (Midv/esit Research
'

There is no riuestion but what you can have nn effective defoliate. The
is £5 n&lt;! in i; one ihitt is fait enough acting to make it militarily worthwhile.
(Qiv/siion: [Its use in guerrilla warfare) would not appear to have to&gt;o 'great
- • &gt;:ai&lt;:a or b-5 of too great importance . . . ; is that correct?) (Answer: Xes sir;
• .&lt;..•&gt;• er tlu'.rc are methods of doiiiic this with chemical compound*. 'Amfl •oh" an "
-•• &gt;.-rir: sen trt! basis, we have demonstrated that wooded areas can be stripped of
': iU.i^e. This work was done as part of our antic-fop program.)
- •
. * * * "'lie quantity of matt-rial to cover an area —well, you cnn sec that they
';.,-'- rf -rilly .small —but when it comes to a number ot square miles, the nuanber of
i-'i r-""£ aiik-s that can iojri.stically bo covered here, as far as our researcih work
i&lt;i&lt; uncovered, a re vtry few.
•
'
itr. J'LI/OD. As a strategic weapon, this has no value?
•-.
, . . ,. " •
One-nil STUUBS. Xo, sir.
' •
.
'
.
Mr. FLOOD. But, I could particularly V.AO that to advantage in jungle warfare,

o&gt;::aiiii&gt;t?

Ofiicr.il STCMS. Whf-n it comes to ,a very limited operations, sir, we baive the
chwjii'-a! today that can do that kind of work.
i Question : How long does it take after it is applied to have effect?) ( Ajnswtr :
L'n.'ortiinately, it takes too Ion;;, This requires some 2 or 3 days.) "

Not long after the above exchange took place, preliminary tests
were underway in Vietnam. According to one account—
AmPritti'H defoliation effort in Vietnam bcptn modestly in late IfXJl. Six'C-123
transport planes, traditionally wed for tarrying soldiers, flew into South Vietnam
,'.-.'•;:» Clark Kit-Id in the Philippines and were outfitted with special tanksKicarry:.\_;' JO.iXK; pounds of defuliarit, enough to cover 300 acres.
. - ..... —
The planes flt-vv CO flights in IfXJl and 107 in l'M2 HH oxi&gt;crlinent.s continued.
1
A toral of ] 7,000 acres were sprayed in 10C2."
.
,".
,
'•U.K. Conerffs, House. Committee on ,Appr«i&gt;rlnt!on« for 10(12, Itonrltij;a bi'C»re the
S'.ibcommltt'1!' nt tho . . . f'nrt 4, Iti-m'iirrh. Ifi'VchiptiK-nt, Test, urn] ICvnlnutlmi, H7(lli Cong.
!.•&lt;£ B-SS. &lt;WnKlilni;ton, U.S. ()»vfrnini&gt;nt I'rintlni: Ollli'c, l i K J l ) , p. 2:11.
" A r t n r o P. (ionznlfi!. Jr. " I x - f o l l i i t l u n — A Cootrovcrnlnl it. H. Mission In Virttniim."
Data (Vol. 13, Oct. 1!M!8), p. 1,1. Acc-orilliii,' t» ri&lt;ronlH of tlio Dfiinrtrni'iit of R)!ie Air
Korce, no operational nitufing -wna diint' In 1U01 nltnoiixh BOIIIC ti-Kt nt'tlvlllrn wnre con1uct&gt;*il &lt;iIo»K ranal.s anil roml* nt-ar riulK-on. Ojicrittlonal eprayliiR of C(IH1 cccnm wux
carried O B t l u 1UG2.
'

bell, stated that among the new techniques employed agaT^Pne Yietcong was defoliation from the air-—"* * * a chemical means of stripping leaves from the foliage that hides Vietcong movements in thickly
wooded areas." The report continued: "Known Vietcong bases will be
surrounded by bare stretches where the guerrillas will find it difficult
to move undetected from their hideouts, which are often underground.""
.'
' Further explanation of the program appeared in a story datelinea
January 11, 1902. It indicated that the implementation of defoliation
efforts had been delayed pending resolution of "the question of how
to publicize this form of chemical warfare * * *."
The spraying now is expected to bojdn soon, following a formal announcvmpnt
approved by high official* of both countries. The announcement declares that the
chemical operation is intended to "improve the country's economy by permitting
freer communication as well as to fuciiitate the Vietnamese Army's task of ket.'i^
ing these avenues free of Vietcong- harassments." 1T

A.week later, it was announced by "a high South Vietnamese
official" that the' program had begun. A 70-mile road from Saigon
to the sea had been sprayed "to remove foliage hiding Communist
.guerrillas" and "defoliant chemicals would also be sprayed on^Yictcorig plantations of manioc and sweet potatoes in the highlands." The
. account said that "The exact locations of these plantations have already
been plotted by aerial surveys" and tests had been made that showed
that "* * * Manoic and sweet potatoes die 4 days after having been

Saigon, under the bvline of Homer Bigart, reported that. ''The United
States has shied away from plans to starve out Communi.-n guerrillas
by spraying chemicals on .rebel-controlled manioc and riceiields."
The roluctanee to join the'crop-killinj,' program urged by the South Vietnamese
is believed b.'isi-d on American sensitivity to the possibility that accusations
would be made that Americans took part in chemical warfare."

A story appearing in the Bankok World, Februaiy 24, 1%2. attrib' uted to a "spokesman'' for the "U.S. Defense Department" stated that:
"Commercial weed killer has been sent to-South Yietnam in an amount
adequate to accomplish the purpose of clearing Jungle growth along
highways and trails." The "spokesman" was further quoted as saying,
in answer to a question: "Xo, the chemical has not been u.-ed for crop
destruction."
Apparently, after these first experiments with herbicides, there was
a lull in the program, while military assessment was made, of their
effectiveness. One indication that tlie experiment had not been au
ITN,.\V York Tim.'* (.Ian. \'2. I H H 2 » . p. .1. (Thi- IVp.irtmfnt of I&gt;ff.-n*n tukos K-M;" w i t h
the Now York flmi-H Intorpri-lntluii that ni&gt;ra?ln£ prfsf"'"" »'*&gt;•« Uclsyttl by cousldmItoiiH of piilillcri'latloiiK.)
'• New York Tlicu'M. (J»n. 10, 10&lt;12), (). 4.
» New York Tlm»&gt;», (.Inn. -tf, 1!")-), J&gt;. 1.

�presented in a study by the Agi
cultural Research Service of the U.S. Department of Agriculture,
under contract to Advanced Research Projects Agency of the Department of Defense, February IOCS. This study reported:
Some forested areas in Vietnam, wore sprayed with 'herbicides in the early
lOiW's in riu effort to reduce the amount of obscuration by vegetation. The results
were particularly good on mangrove in coastal areas and along canals. Results on
evorgrc-en. rain forests and upland semideciduous forests left much to be desired.
Consequently, a team of military and civilian experts reviewed the operational
si-ray program and made recommendations for improvement. Since there -was a
c'-.-.zrth ot information available about the response of tropical woody plants to
2:-rMc:O.Ds, a research program was recommended that would answer soiaeioif the
c.-: r'.-.-al problems Involving the defoliation of tropical forests.21

•'."Hiring March 1062, Roger Hilsman, a-senior adviser in the State
.: xu'tment, visited Vietnam and on his return prepared'a. number
f-.i :uemorandums on current issues, one of which was the use of de:'. •'.''Silts—a device that, he said, "had political disadvantages" and was
of doubtful benefit. Excerpts from a later statement by Hilsman on
this period are as follows: .
'
•
rv-foliants * * * were new. They were chemical weed killers, which had been
ht-rbly developed in the United States and were widely used, for example, to kill
7...urotation along the rights of way of power lines. The military headquarter* in
Saigon thought that these defoliants would bo idoal for clearing the undwlurusti
along the sides of road- where the Vietcong laid their ambushes and for diss.troyLv.; crops in areas ui&gt;: •:• Vietcong domination, and General Taylor and the Joint
Chiffs of Staff agrec-d. The State Department view, on the other hand, was that..
the political repercu^ions would outweigh any possible gains. Defoliation was ..
just too reminiscent of gas warfare. It would cost us international political
support, and the Vietcong would use it to good propaganda advantage as an
fcsampie of the American making war on the peasants. My own-feeling was that
at a much, much later stage, when the Vietcong had been isolated frona the
population and were attempting to grow their own food in the mountainss, the
advantages might be significant.
•
'
[HUsrnan questioned the advantage of defoliants either- to deny food, to sruerri'liis or to rernovfc cover for ambushes at the time in Question.] * * * As for
removing the cover for ambushes while in Vietnam I had flown down a stretch
o' r-'iad than had been used fur a test and found that the results wore not very ,
;::.[Ti'.-sivc. * • • Later, the senior Australian military representative In Salion,
Colonel Sr-rong, also pointed out that defoliation actually aided the anilmwhi-rs— "
if the vegi'tation was close to the road those who were ambushed could take cover
cni'-kly; wbc-ti it was removed the guerrillas had a bettor field of fire. But the
&gt;'utif&gt;n.il Security Council spent tense sessions debating the matter."

Military assessment of defoliants a-ppears to have involved such
questions as the feasibility of developing techniques by which large,
slow-moving and low-flying aircraft could traverse cnemy-occajpiod
jungle terrain without being shot down: *,he selection of else appro-.
prio-to chemicals for particular kinds of foliage to be stripped of
leaves; tho timing of the spray missions in relation to the local rain- .

fall pattern, and local wind conditions, in addition to military tactical
requirements; and the survey of the urea to be sprayed^•jyermine
tho risk and extent of inadvertent damage to crops and t^^^Bplantations. This learning process coincided with internal in?ta1«PPR within
tho Saigon government, and the gradual enlargement of U.S. military
personnel serving as advisers to the field foives of the (/ovtnmiCT.t.
Mesmwhile, separate experiments in U.S. territoiy, and in Tliailand.
helped toward perfecting the. techniques of application. In. particular,
the. military authorities,!/! the United States wore concerned over tho
various timelags in defoliation evidenced by the different species of
. plants to which the sprays were appj ied.
Evaluation of the proposed military uses of defoliant Chemicals
.by the Department of State, judging by the Hilsman discussion, involved the impact of world opinion on U.S. foreign relations. The
various work orders by the Advanced Ke?earch Projects Agency
'(ARPA) of the Department of Defense to the Department.of Agriculture had to do initially with the military effectiveness of the chemicals. Later on, questions were explored as to residues in plants and
in the soil (March 5, 1063); however, in these initial stages no significant emphasis appears to' have boon placed on the need for .research
concerning the long-range effects of herbicides on the ecology;
The. Department of Agriculture studies for ARPA inclulied («)
vegetation of Southeast Asia: Studies of forest types, December IT'O."*;
(Z&gt;) forests of Southeast Asia, Puerto Ilico, and Texas, published September 10GT: and (c) response of tropical and subtropical woodr plains
to chemical treatments, February IOCS. •
'
]
To prepare the first report, Fred H. Tschirley. Crops Research Divi'sion, Agricultural Research Service, USDA, visited Thailandjdunng
December 1063 to January 106-i, and December 1064 to February IDf;:,.
In Tliailand he was assisted by Thai forestry experts, and particularly
Mr. Tern Smitinand, taxonqmist in the Royal Forest Department
'of Thailand. The purpose of this first reconnaissance was to identify
• tho characteristic types of foliage growing in wooded areas of ^oatheast Asia. ,.
' ' ' '•&amp;'•...-':
•• ••
- -.
• !
Tho second report fronf'USDA-to AliPA was a comparative study
of forests in Soutluvist As|a in .comparison with forests in Puerto
Rico and Texas. The to re wo'Fd to this study states:
. !
* * * Information on the floristic coin]&gt;ositton and structure of a particular
forest type, occurring under tropical, subtropical, or temperate C"ndi!i&lt;&gt;:is, is
essential for comparative purpose, nnd is of value to tho ecolo^'i&gt;tt fur»sfcr,
KCOKrnjihor an&lt;l others. In brief, vegetation is the suinination of climate, coil
tyjK'S, and general conditions in a particular onvironnu-tit.
Throughout tho report, emphasis is placed on analogous and nnotnalous
features of the forests of Southeast Asia. Puerto Rico, and Texas. This comparison is based principally on investigations conducted by the author [l.iowMyn
Williams] throughout-Thailand at Intervals during 1SXJ3 to i;xk*&gt;: in 1 Tnorto
Bieo In April 11K13 and June liKIO; and in eastern Texas in September 10«',«&gt;. Other
studios, osiKH'ially on sctMlling.s apivaring in succcssional growth, wore con.lui'tcd
in I'uorfo Kico hy J. A. Duke- during llKiS to ISKiO.

Tiie third report, eoinpilod hy Tschirley, described the results of
experiments with herbicides in Puerto IJico and Texas, and interpreted
tho effects in relation to military objectives in Vietnam.
An indication of tho development of the scientific aspects of tho
program is provided by .tho summary of successive work orders ami

�-AUI-.-V urucr i^^^m LISSUOU j.in. ;ju, i:x&gt;;ij was established for a 2-year
orl. The objecfl^^Pl ttic work in College Stntion. Tex., were to: "Discover
d evaluate new herbicides and principles for killing trees, brush and other
leration; develop methods of evaluating herbicides on different species of
ody vegetation; develop methods and principles for improved application
chniques; ami dotcrmiue effects of promising- herbicides." The. objectives of
research in Puerto llieo were to: "Conduct advanced evaluation of pronnlslns;
decides for killing tropical and subtropical vegetation ; and determine optimum
::\f&gt;s and rates of application, distribution patterns, formula Lions and im.xihircs
-r :no&gt;n effective use of herbicides." The objectives of the taxonomie investijjai'fj-z were to: "Obtain sufHcieut botanical information so that correlations can
l^ ta:ide .lietween vegetation indigenous to COXUS ami Puerto Rico, and Southf:-st.\.*ia. "
•
AIlPA Order Xo. 424 was extended for an additional year by amemlionent
Xo. :! dated March 5. IOC,". Additional objectives of the research were to:
(1) K;uph:}«ize effects of environment on behavior and effectiveness of tierE&gt;ieiues a nil persistence of control including residues in soils and plants. {2)
study secondary succession of vegetation -following different herbicidal treatment.' as related to "visibility," (3) correlate the results of defoliation in. Texas
an.j Puerto Rico, (4)-investigate methods for improving absorption, translocate:, and a-ctivity of herbicides and defoliants, and (5) compare the penetration
: s-.-raj-!» through a forest canopy that is obtained from a cableway system with
1
. - • ( obtained from aircraft.
A st-cond extension was granted by amendment Xo. 3, dated March 29, lOdC.
.'urins: the final year of the project, increased emphasis was given to the effects
••" vavironment on herbicidal effectiveness, the composition and frequency of
'.'.c-Tessional species following herbicidal treatment, the effect of defoliation and
:u:;-;-i-ient regeneration on -the degree of obscuration, and herbicidal residues.
r. !&lt;•&gt;• h plants and soiN.
The interrelation &lt;••' data from the fields of taxonomy, ecology, weed science.
UK! engineering have been extremely valuable during the course of this project.
Ft is axiomatic- that the breadth of a study determines the.extent to'which
i.ifa developed from that study can be extrapolated. For example, a great deal
&gt;" research han rn-ea done on the control and defoliation of woody plants in
eapvT-nte zones. Information was available regarding which herbicides were
nost effective, what rates should be used, and when treatments should bo
r:adir, Hut no one could extrapolate that information to a tropical evergreen
ores': with any degree of. as.si;rnnce. In like manner, penetration of a spray sola*
;
on through a forest canopy wviild be expected to be different for a desert s=3mib .
ormntion, a coniferous fore it, a temperate deciduous forest, arid a tropical •
•ri-rgrecn forest. Once the effective herbicides, the penetration of spray solu-.
;&lt;&gt;!;.-•. and the taxonomtf affinities of several diverse vegetative types are known,
xtr.ij^iation of that inforiiiar.ion to entirely new areas win he made with much
r;&lt;&gt;rv assurance. Thus, the correlated efforts of taxonomists,.engineers, and iveed
'•&gt;r.ti.sts in the AIU'A project has provided information that can be allied
••;th reasonable assurance 0on a worldwide basis, rather than being restricted
••• UK.- area of investigation.

By July lDo'5, flic main emphasis in military research in horbieidos
v;is on shortening the reaction time, of plants treated. However, the
'-c!nif»!oj/v was so new—for military purposes—that precise perform';.-*• -'Kvifif-.-ifions had not bwn developed. As ono civilian scientist
xpn-.-^ed it:
'
.'
• • . ' . .
It iroos without saying that the materials must he applicable by grimiul and
Jr fpray. Miat they mi'^t be logisticaily feasibk;, anil tliat they must be- uou** U.S. Pi-p.-irtmi-nt of A i f f l c u l t ' i r c . A e r l f i i l l u r n l Ki'itcnrch Sorvlci'. KcHcnrch Ki-port . .
......in-c "f Trn|iji-i)l nfi'l S t i l i l r i i j i l n i l Wdnil.v I'Jiuif.s ti&gt; Clii'inli'iil Tri'iitnirntH. Ciinii't'i'it tiy
f'-'l If. T"&lt;-h!rl"v. Crojrn H'"&lt;ouri-li Division. ISHKCM] on Iti'scnrrli C'miliicti'it tiv I,. V. JHOIIHI-.
( al. IJniliT AUI'A Onlcr No. 101. A d v i i n c p i l Hi^carcli I'riiJ'-i'tH Aci-ncy, U.S. I&gt;i'|uir««iout
[ r)cfrii«i', CJC-W-C7. I-'i-tiruury JOfiS (U.S. I&gt;i!{iitrtniCiit &lt;&gt;f AKrlcnltiirc, 1(I«S), pji. 4-5.

irt-'i;i, LU me usuai luiniary-nuiusinai couaiioratioa * * *. in t
do not have rigidly specified characteristics. I have stated t-oinu o r o broad
requirements that a successful defoliating chemical should have but. within th«
general framework wo will accept and use materials that will do a job for u&gt;.
In a few years it may be that we will come up with more definite .specifications* * *.«
. .

During the first 5 years of defoliant use, the rato of increase was slow.
In 1901, only.GO missions were flown; 107 occurred in 1002. However,
by the latter part of 19C5 the rate of use began to increase sharply. (See
tableS.) .
. '
'
j
.

TABLE 3.—ESTIMATED AREA HERBICIOALLY TREATEO IN SOUTH VIETNAM, THROUGH 1053 &lt;
.

"

' •

•

(Figures in square mils:!

. Year
1962
1903 .,
1964 ...^
196S
1966
1967
1968

Defoliation
„.,'

...:

&gt;.

.-....•

Total!'......

.'.
...

.,

. ,.

'

I

J.,

„
..

8
39

130

240
1,160
2,320
• 1,980

.-.

• ' •

5.877

Crop attic'*

Total itti
sprayel

I

' •

(!)

U

9
33
Ui
343

103
158
343
100

1.3iS
2.6G3
2,083

726.

6.603

1
Source: Letter to Representative McCarthy from Legislative Liaison, Department ol the Air Force, Mi-/15,13S3.
'Less than 1.
&gt; These figures do.not represent total acreaje soray
figures calculated from missions flown, tank capacity,
is estimated at about 60 percentof the indicated total. t 1 seres
,
; about 2,540,000 acres anj tiic tolal amount of trsalment applied is aSout 4,226 ,BOO acres.

Full-Scale Military Usa of IlerWaidcs^ 19G6-G9
•
• • By 1967, herbicide usage in Vietnam began to level off. However,
military procurement of "defoliant chemicals continued to climb, to
build a stockpile of reserves for the future.- 3 According to au oflU'ial
statement about the program, released in Saigon:
Jiy December,' 10G2, Kan'ch Hand [code name of the aerial defoliation program
unit] had completed two iiew project*. These were the defoliation of canals and
rivers In the south and a pass south of Qni Nhon.
In IOCS lines of communications targets included a powerline from Daliit to
Saigon, the railroad from Saigon to I'han Thict, and other highways and canals.
Bcx.-au.se ground tire and hits to aircraft were increasing, the Ranch Hand unit
experimented with spraying at night with lighting provided by llaro ships and
by moonlight alone. These operations were dj.seonthnied mainly iKK'nust- of the
small chance of rescue in the dark.
DofoUatiou derations increased in 10G-I, and hits on aircraft became more frequent until on April 30, one aircraft was hit 14 times, and the copilot was
*• 17.S. Anrij-. Itlo!o»rl''ril T.nhonttnrli-s. CY&lt;&gt;[« Hivlslon. rrdr.'ptHncn of the First Defoliation Coiifcn-ni'i'. .Ttilj- 2U-IIO. ltir,:l. Itioliiulcil I/ihoriitorlvn. i-'cirt Dotrk-k. Marylivtul. Compllod hy Vi'Mtn /.. Miittle. M n n i l n r y l i n i t . AD SML'TXT 1). pp. 1.1. til.
»lii'clnnliii; A p r i l 1. 11IU7, lullltar.v rnti'il onlrrn pri&gt;-i'ni|it'Mi priiituetinn of 2.4.5-T f.ir
use w l f t i 2,4 -I&gt; t» proiliicc "(^riLri^n" ticrtiU'ldo, t h e most r&gt;xti'iiHli-r'ly ijii'd cli^mlciil &lt; i i ' f o l i n n t
In V l i ' t n n i n , AH p r o i l i U ' t i o n liu'r^M^ciI :nul tnUHai'.v rt'qiilri'nionrs slacktriU'it. ;1i&lt;* cotitrolx wort*
lifted d u r i n g A p r l l - M i i y , IDfiS. They WITP t h &gt; ' » rt'xtureil, and n i l Jinn 1 production wi-i.t to
i n l l l t i i r y piiri'linsiTs. TlHTi-iifti'i-, n i l o c i i i l u n w n s p n r t l n l . and hy mld-I'i-C'-mhcr, Ifti! 1 *, t h n
controls wcro t e r m i n a t e d . Slnro ttn-n. tin* i n l l U u r y H« i rvtrt^ havi* p t i r f h i i ^ t - d no hi'rt'!&lt;*M«?
nt nil. A c t u a l t&gt;xt&gt;i'ndiluri'!&lt; fur m i l i t a r y h&lt;&gt;rl&gt;!r!d&lt;&gt; rose from .flu,.") n i U l l n i i In the (lii'jil
101)(I to $45,2 million In l''.Y. 07, and rcnuiliicd ntiuut nt that Irvi't fur nnother

�\v(.&gt;..:nde-I. At this t^e operations \vere discontinued for mililarj" reassessment,
tbcr vivtv ri'siiiri'^^^^ly with increased sorties prosr.'imed.
A srii'liial iuci^^^H sorties continued during 19C-"&gt;. and in nud-Xovertiber the
Kaneh Hand uu^^Hr almost doubled as three additional aircraft and crews
arrived from the UfiHed States."

In the spring of 19G5 the first systematic program of aerial spraying
to destroy food crops was begun in Vietnam. A story datolined 'December 20 from Saigon, under the byline of Charles Molir, in ilio New '
York Times described this program as having begun "last spring." It
was ':a politically delicate subject." According to the story, "officials
say that no herbicide [i.e.; crop destroying] missions have beers, flown
or will bo flown in heavily populated areas"' (such as the Mekong
I.'olta). The missions were "aimed only at relatively small areas of
major military importance where the guerrillas grow their o«rn 2r
food
or wheiv the population is willingly committed to their cause-/' By
early March 19G6, crop destruction had become an important pliase of
counterguerrilla. activity. A statement was made, public by the Department of State, March, £), reporting that some 20,000.acres of crops had
Been ctascroyed to deny food to guerrillas. The areas involved were
dexribed as remote and thinly populated, and "known from Intelli70nee sources to be occupied by Vietcong military units." The .state:-.fc also described precautions being taken in the crop-defoliation
..'mm to avoid adverse effects on noncotnbatants:
."..•* herbicides used are rr'-.'ifoivic and not dangerous to man or onieanl life.
".': !:;:ul is not affected for fi:r ir« use.
~';-e Yiotcong and n.-iy innocent persons in the area are warned of the gd.iimed
a't.oa. Tney arc; asla-sl to leave the area. They are promised food and Eocv.3 treatii'. nt v.'hen they move out Tlio.se who have moved from Yietcons territory for
uiJ.s reason havo b&lt;?&lt;;n fed and eared for.25
'
''
""'•". .
..

By Sfptember I960, the defoliation spraying program by aircraft,
again?t forest cover had been extended near the DMZ.-'J By the end of
rl:-it month, the possibility of defoliating jungle growth withLn the
j/M% itself was reported to be under consideration by the ..Joint Chiefs
or Staff'. It was also reported that Gen. William. C. Westrnors-1 and,
C-mrnander of U.S.'.Forces in South Vietnam, had asked for Presi-:&gt;,'.","!a! approval to'u.se herbicides to 30
defoliate 50 square miles of the
;ii?:_r!e-covered mountains of tluiDMZ.
By early IOCS, the program had been well established for botli reno •,-;•.! of jungle cover and crop destruction. The31Department of DerVr,.-e released statistics covering the year 19G2-G7. At about thi.* same
ti.'iif-, it was announced that the Air Force was "preparing to slump
10 million gallons of vegetation and crop-killing poison over South
Vicrnam in the year beginning in July" of 19GS~f&gt;f). The chemicals required would cost $70.8 million. The report concluded: "FHgfots of
'-* At rcp"'t''&lt;l !D: T«k««M Oka. "Tight Controls Pinpoint DffoHntlon." CtrlBtlais ^So-lcnco
Sf-oif.r. ur.ir. 2S, J O C ' l i . p. 4.
^O'hari"* .Mohr, "U..S. Spray PJaacs Dcstfoy KIce In Vietcong Territory." Sew i'orfc
r:-'..--. (J)'-c. 21. l!n;3). p. 1.
" 'V.H. TcllH of C'rop Dctitructlon In South Vietnam." N'ow York Times. (Starch 1&lt;S. IflfiO),
&gt;. (&gt;.
" T.R. In ncfnllatlon NVnr nnffer Zone." (Story fiatellncd Silicon, Scptembnr-sa.) Ni'W
lork TliiiPd. CSi-pt. 24. l!)(5&lt;J).j&gt;. 2.
kv
'Krnnt-I,!i&gt;(&gt; T;n!t« Hnck I)i-f»!Iiitlon." New York Times (Story DatcllawJ DaruuEK, Sept.
!S) ! New York Tlmps. {O.'t. 2, 1!HIO). p. 7.
* "(;.H. To KxiiunU I&gt;cfulltition la South Vietnam." \Va»hln«ton Post. &lt;May 13. IOCS).
&gt;. A-17.

Air Force C-123's equipped with 1,000-gullou &lt;
tanks began in 1962 with a modest 107 missions. Chemical OL
have continued to escalate, however, and by 1%G, U.S. pfl
flying more than 3,000 spray sort ics a year." '•' ^^^
In actuality, the military use of herbicides in Vietnam^Tached
its peak in the fiscal year 19G7, and declined somewhat in each of the
following 2 years. Whether or not in response to the cautions expressed
by Dr. Tschirley of the U.S. Department of Agriculture (see pp. f&gt;051) and Dr. Pfpvft'er of the University of Montana (see p. GO) there
was evidence of an increased military restraint in herbicide usage.
The complex mechanism of defoliation target selection that had
evolved to apply the expanding criteria of suitability (?f-e p. IS sq.)'
provided opportunity to bring these cautions to bear on military herbicide operations. Moreover, with increasing experience, the military
services themselves had become better able to judge both the values and
the limitations of herbicide application. By May ipC9, the Department of the Army was preparing to issue a new manual of instruction
on herbicides for troop use. (See app. A for text of the draft.) In addition, the Department of the Air Force was soliciting a contractor to
perform work looking toward the "ultimate goal" of a "handbook for
Air Force base civil engineers with worldwide recommendations for
effecting vegetation control."33
DecinoMnaking Arrangements for Military 'Uses of Herbicides in
Vietnam
The complex political situation in Vietnam has resulted in numerous difficulties in U.S. support of .the Republic- of Vietnam (RVX).
Military and political decisions are complicated by three Pels of cir:
cumstances: (l)'by the informal nature of the undeclared war. wir.ii
its mixture of regular and irregular troops confronting RVX and
•supporting U.S. forces; (2) by the mixture of economic motives in
•which the progress of the KVJS" toward economic and political 'Sovereignty by replacing a colonial economv •..with... self-controlled . 3 ~ * ^ ,"
a i i i'
economy
»'
»
f •» I* i
i -j
, .*, •
_„• n
t

quiring coordination with U.S. military
against.guerrilla and North Vietnamese forces.
The use of herbicides in support of military objectives is similarly
complicated by these sots of circumstances. Although extensive U.S.
military forces have l&gt;een brought into the territory over which IJVX
asserts "sovereignty, the role of these forces is as invited assistance in
support of a friendly nation. Accordingly, the use of herbicides, a
novel form of military technology, has required two-sets of formal
military approval. In addition, since U.S. objectives in the area encompass not only military but also'economic and sociopolitical goals,
the actual field plans for usage of herbicides for military purposes
has required review for military, economic, and sociopolitical eti'ects.
""U.S. To Increase War Use of Crop-Killing Chemically." Washington IVst (Mai 10,
lOilK), pt),
" "KMiOiirch and Development Sources Sought." Commerce Business Daily. (Mar. 2$,
1000), p. 0.
32-405—-OU--

�Insofar asU.S^HJlitary forces are concerned, the All-Service, Mannal of Armed I^^A Doctrine for Chemical and Biological Weapons
Employment a^^^pefenso34 specifies that "The President &lt;rf • the
United States nmKes the decision to.employ CB weapon?." Also, "'The
ileeision for U.S. forces to use chemical and biological weapons rests
with the President of the United States." It adds35
that "commanders urecurrently authorized to use .* ,* * defoliants." Defoliant is defined
in this manual as "a chemical used to remove prematurely the loaves :
from plants." "
'
.
'
• • . - . . '
. '
Although the President, of the United States received, an it acceded
to, :i request from the. IIVX for the uset&gt;f herbicides, the policy was
?.~t- Mished at'the outset that proposals for defoliation actions would
[•-; initiated, by the Vietnamese people, locally, and would be reviewed
!-y l.-oth military and economic group?, and by both United States and
Republic of Vietnam authorities. A statement issued by the Depart-,
:•: ' 'if Defense, late, in 1%7, describes in general terms the naodus.
\.--^ ••• rii involved in. this program, as follows:
U i* the jK&gt;!icy of the Government of Vietnam to take every possible s'tep to
r.Lif-:- the prod'^-tinn of fowl for its people. It is the policy of the United Suites
to assist tue Vietnamese in this effort. Many steps have been tak»-« in tlae past
in thi.s direction—through the import of fertilizer, the introduction of new strains
• &gt;! livestock, improved growing teehiuques, and other methods. As a result of the.
r •••.-r.t Honolulu conference and the visit to Vietnam of Secretary Freeman arid
:;m of agricultural experts, new and. more intensive efforts are lieing" mndcr• ; •:: in this direction.
&lt;;•• question has been asked how can we and the Vietnamese fry to increase
-.-•! production, on. the one hand, while defoliating trees and destroying:-crops,
j.i the other. First, these, two matter.-* should he separated.
Defoliation has been used to deprive Communist guerrillas wlipw? poss-uhle- of
r-*»vf-r and concealment. It is used along roads, railroads, and canals wh&lt;we the
V'lefi.-ong. have regularly taken advantage of thick foliage to set up amRnishes
.-.jninst both military and civilian traffic. It is used against remote Vic.teotss hase
i ?-,:.-: where, the Communists have used thick natural cover to conceal! their
f-.--av.My fortified training and recoupment centers. It is used against laiowiu trail
rni]r--s winch the Communists have used as supply channels for men and weapons
in South Vietnam.
.
.
In some cases, herbicides have been used to destroy crops in remote- areas
!•••::;: occupied by the 'Victeong. Tlie areas affected are known to be nsscd to
;•.- .cliir-e fix&gt;d for Vietcong m i l i t a r y units in the area. In war, food is as &lt;essen::al to the effectiveness of u military u n i t as its weapons and flmuimiUiora.
Several things should be noted in this connection. The areas nfleeted Biy this
::.:!r(-'l crop destruction program are remote and thinly populated. Tlwey fire
:.:"-.v;i from intelligence soun-es to be occupied by Vietcong military iiuifts. The
• ••••'. -ifli-x used are no-itoxic am! not dangerous to man or animal Jjfe. Th«- land
- •'.'•it :i fleeted in terms of f u t u r e u.se. The Vietcong and any innocent pcrwons in
- .- ari-ri arc warned of planned action. They- are asked to leave the urt&gt;;*v. 'They
:•• promised f&lt;cid and good treatment when they move out. T!in«&lt;&gt; wl«» have
- .;v.'d f n u n Vietv-.-jng territory for this reason have been fed and '('anil ifor.
A scfoml j K i i a t — a l l defoliation nnd crop destruction actions ane initialed liy
:.i- Vietn:i:;n'.-f themselves, lisually a district or province chief who has located
iri nr.-ii f.f's;i&lt;nvn Vietcong oc'-npation. .
Tie- run-raff and te&lt;-iiri(&lt;-,il capnbiiity for this program are IiiwJy Ani&lt;e.ri&lt;-aii
•i.-nj.ly tK-&lt;-:Mj&gt;(; the Vietnamese do not yet. have the personnel arsil oquFifluneiit
•-rivwiry. I'.nt tlien- is Vietnnmese participation at every stage anil tlm iiiiil.ijitive
'••r all sueh programs Is entirely Vietnamese.1"
« F M 101- (O/NPW SflfrWAFMaRB-S/I-KMO 3, DnimrtmontH of (lie Artny,
in&lt;l Ilio Air Kon'p, April, 10(14, p. 3.
" l!.i&lt;l.. p. 4.
M
l w - [ i t i r i n i e n t f&gt;f DcfpnNc. "TJifi U«&gt; «f Dffollunti in Vietnam." (Oi
act hln-ft. No ilntc.)

Navy,

. A. news account, of this program of target selection
early in 19GG, described it as follows:
Setting up targets is a ticklish diplomatic business. Xo
eitljer United States or Vietnamese'army commandi-r.s, but if an Aai»rieai;
wants a target sprayed, he-has to pass the recommendation on to a Vietname-e
officer, wliO goes over I he target with the province chi&gt;-f. TiK-n tlif- refommenil.-ttion goes to the Vietnamese Army's general staff in Saigon and, if approved, the
request is sent on to the intelligence section of t h e U.S. Military •Assistance
Command—Vietnam in Saigon.1"
•
•
t

In pnu.'tiee, requests for approval of herbicide targets'.proved up
fr\vo parallel chains of command. Specific approval or disapproval actions are required at each level of both chains. One is the Army of
HVX chain which requires approval of the district and province chief,
and three other levels, before being, submitted to the U.S. 'Military
Assistance Command—Vietnam (MAC-V). The other is the U.S.
chain, which runs through district adviser, sector adviser, divisional
senior adviser, and corps senior adviser, before going to MAC-V. Approval by these officials carries with it the assurance of approval by
local civilian U.S. technical authorities (AID, etc.) at These levels. At
headquarters, MAC-V,. the target requests, countersigned up both
chains, are coordinated, with Joint Staff intelligence, Joint Staff operations, the Chief of Stall, the Embassy, U.S. AID, and two civil affairs
groups—the civil 1 operations revolutionary • development support
(COUDS)_ and the psychological warfare'directorate (MAC-PD).
Coordination is managed by MAC-V ofiice 20:&gt;. Only when approval
lias been completed may the proposed target be scheduled."
• An" indication of the scope of information needed to accompany a
target-request.is the following "Checklist, for Defoliation Requests"
prepared f o r u s e i n this process:
• ' • . . .
CHECKLIST FOR DEFOLIATION REQUESTS*

;

1. Overlays or annotated photographs depicting the exact area.
2. Target list:
.
,
.
. .
'
(a) Area—Province and district.
. - . ( &amp; ) UTM Coordinates.
.. ' .
:' .
(17) Length and width.
• , (il) Number o f hectares.
. - •
" . ' . - •
(c) Type of vegetation.
.
3. Just ideation:
'.
•
.. ,
' .. •
{«) Objectives and military worth.
'
-. '
(6) Summary of incidents.
• \
4. Psywar annex (prepared by sector) :
'•
:
. • ( &lt; / ) U-allets. •
.\ • •
(fc) Loudspeaker tex.ts.
,.
1
C, Civil aft'uirs annex (prejiared by sector) :
••
(a) No crops within one km.
(l&gt;) Contingency plan to provide food or money to families whose crops
ure. accidentally damaged by the defoliation Deration.
0. Certification by province chief:
,.
•
(&lt;/) I'i'oviiXT chief nppi'ovul.
. . .
(l&gt;) Indomnltieatiou will he made [by IIVX] for accidental damage to
.crops, • • • '- •.; .•'
.
..

A major consideration in decisions to approve u proposed target for
^rbicido application is whether it accomplishes a military objecfivo
In V l i ' l n n i n , " N n l t n n n ) OliMTViT, vol. 5. no. 0,
i-me
« W Pi-mien " l i i --d i H u M n iir ti
I'N'liriMiry '.'«, l!&gt;iirt. &lt;.iimti'il In M l i t lti-|»&gt;rt. Oi&gt;. clt.. p. 12(1.
liifoniiiitlon pruvliltnl liy Dr. M l n n r t k , May 5, i'.KKl.
"Source : Mlineotjriipli »hcct HU[&gt;i&gt;llcil l&gt;y Pr. Mlniirlk.

.,
3-1-.

�for its adverse_eiu-ets on the economy of the .country. There appeal's
tci be no question but that the program has injured the economy—
'-.' rough iiitidvertent damage to rubber plantations, injury to tiinber
.';--:\~. and'tlrift onto food crops, for example. Inadvertent damage is
r : ; .'.rently inescapable. However, it is reported that complaints of
'-,'. .i vet-tent damn go, collected and reported by U.S. AID, which
;.-.r"icr -were numbering some 30 a month, had'been reduced to 3 a
r&lt;cv!-th by early 1D09.SO
Constraints on the program are imposed by physical circumstances.
[\-foliation is most effective during the growing season, and is much
• •- effective and slower at other times. The type of foliage to be at-'

•'• ;-iilons (32.25 pounds) per acre. It is delivered by 10
aircraft flying at
.-r altitude of 150 feet, at an airspeed of 130 knots.- To avoid drift
-.:"!' for spraying during early morning hours "while inversion tem•••--M ture. gradient, 1prevails and the wind speed is still low (does not
:: c-dSknots).'"
'
As to the rate of application of herbicide, Dr. Minarik has said:
T; is potent herbicidnl mixture [i.e., ORANGE] is being applied without
';••.-. •• -Q ; but this is necessary to reduce the number of sorties required to. •
--.: .in area, of a. given size or to state it conversely, to maximize the area
• -.-.:•;.: jt-r mission. '
. . . . . .
Ti:n.v- gallons per acre deposit is employed. We-would prefer to u.se less i f • could get uniform deposition, but in these dense jungle areas where there :
. !j be 300 tons of veg'/tatlon per acre, this is the minimal effective volume.
".;» Z gallons contains 2-t pounds of herbicide on an acid equivalent basis. This''"
i-rii dosage rate is also a requirement since much of the vegetation consists '
r tr«c-.-3 100 to 1ZQ feet tall.'- .
-

Military assessment of the program lias been sustained throughout,
nd has received the participation.of both scientific staff people in •
lie. Pentagon, and military, and civilian personnel in Saigon. An .
coount of the course of this assessment was recently reported in
lie following terms:
-'
.• •
Prior to operations in Vietnam the DOD sponsored research by tlie Departi-ijt of Agriculture in Southeast Asia, I'uerto Rico, and Texas, to ascertain
;t- effects of massive herbicide use on analog vegetated areas. This research.
. suited in two rather lonjrthy rei&gt;ort.s [which wen?] :
.
"Foiv.sts or Southeast Asia, Iii&lt;-rto Itlco, and Texas." U&amp;DA Report
CK-32-trr, September 1007, AD-W-IOTO.
"Research Kfport—Kesi&gt;onso of Troplnil and Sub-Tropical Woody Plants
to Cheinic-al Treatments." US DA Report CR-1S-07, February, IOCS,
'
' • "

Based on those studies, and nr...-it the knowledge, t h a t the use of
of millioiin of pounds of lurrbield-- in the United States over 20
stiirtliiiK adverse effects, the l.'nited States proceeded with the
gram for the purpose of increasing visibility in heavily forested
nmbTish along roads and canals and to increase ground and aerl:iWP^veilUiii'.-e
of Victcong hideouts.
The use is restricted to South Vietnam, -always with the approval ami
usually at the request of South Vietnamese authorities. ISeqm-sts for approval
are considered at s(fveral levels of military and civilian authority, both Vic-rnainese and United States. In all cases approval of the province ehi.-f, and
the central government is required.
Realizing that the area of I'niK-term ecological effects of massive u.«e of
herbicides was not very well known, the DOI&gt; siwn^ored a study in 1007 to
collect the available information. This study is * * * as follows:
"Assessment of Kcologicsil Effects of Extensive or Repeated Use of Herbicides", Midwest Kesearch Institute, Kansas City, Mo., December l'J&lt;J~,
AD-S24314.
. The study dealt largely with the effects of herbicides in the United States,
whore massive, repeated use has been carried out for the i&gt;iu'i&gt;o&gt;es of crop, rang*-,
and pasture management, right-of-way maintenance, and 'control of weeds in
. waterways and miscellaneous areas. * * *
We requested the National 'Academy of Sciences to review this report for
accuracy and completeness, which they did. The report and the review were then
sent to the American Association for the Advancement of Sciences for consideration by the Board df Directors . * * *
Subsequent. to this effort, Ambassador Bunker of the U.S. mission in Saison
convened a group to consider all aspects of the herbicide operation. * * » The
technical study contributory to [the release of data by the mission] was informed by Dr. Frerf Tschirley of USDA, who published his findings in Science,
yoluine 103, February 21, 1000. He has recommended that ecologic research be
conducted in Vietnam after cessation of hostilities, that continuing assessment
be made in Vietnam, and that defoliation be conducted in strips or checkerboard
' patterns to leave undefoliated areas for seed source and wildlife habitat. His
.'recommendations were endorsed in principle by Ambassador.Bunker. * * * "

. Indications are available, that the"sereeninc:.T&gt;roee?s for a'-^'-'u-ul
of herbicide targets is more than pro forma. There arc many assertions that no aerial herbicide spraying has been conducted in the large
. delta area south and east of .Saijron. and no evidence has l«en i»und to
the contrary. Also, according: to Dr. Minarik. a number of province
chiefs have given a general disapproval to spraying within their jurisdictions. Crop spraying has been sharply reduced in IOCS-GO. Reports
of complaints or damage claims are also at a lower level than formerly.
Tlie.se circumstances seem to suggest that military use of herbicides has
become, increasingly selective and t h a t controls are in etl'ect, subject to
many different sets of criteria at. different levels of review.
Tho extent to which m i l i t a r y control in the field of the use of herbicides is responsive to policy direction from the Oflioe of the Secretary
of Defense, and the, exlent- to which this policy direction has been responsive to technical studies undertaken under the. stimulus of criti•cisms of tiie program by outside scientists, are matters of pure- speculation. However, it is evident that the. program has received a great
deal of oflicial review at many levels, and also that it has been the subject of a wide rango of expressions of concern by many scientists. Tho
record of these expressions of concern' is surveyed in tho two chapters
tO follow.

« C. i-:. Ml.inrlk. "The C«c of [lerblrldfs in VIMrinui." Paper delivered hofore N'ortbi'astcrn
ff-'l (.1-111 ru! Conference, New Ynrk City, Jim. IttiiH
" I &gt; n i f t Imuniir.l nn uno of clivintral nh'vnM, rliaptor on "Antlpliiat Aifitnt OncriiUonu.
I'-i'I" ',, ' 1 '&lt;- |lIll 'V'l Aspt-clK" MS slimmed by Dc[in.rtr.ifut ot UeCcuge. N'o Uate.
*• ilin.irlk. Op. clt., p. 4.

n

u
t.'.'ttf'f frcitis It. I,, Iliirrls. TVptity APsNI'ntit Dln-cfor (Clicmlcnl Ti-i'liniiln«y).
to 1'MlVssor CimrlON Tuwin% Dcjiixnmrnt uf 1'lu'slcn, University ot California, at
Apt. 23, HHJ!J.

�IJL CIUTICIBM'OF HERBICIDE WAKFAKE
| Various gi
•j^^^were found for expressions of disapproval of the
I use of defoliail^^HSnicals in Vietnam, when directed against guerrilla
i crops, or jungh^Wver. The earliest criticisms questioned the military
1 effectiveness of the technology, and the risk of inadvertent injury t&lt;
1 Vietnamese crops and plantations. For example:
a » ^ ^ - - -

* * Our chemical warfare people have been very unhappy for the last 4 or
I "&gt; years about the whole operation. * * * Defoliation is no new gimmir3£ with
.
...
„,„.....,....
j./1-iuiiiuKm is
Kinimir
a tin- Army Chemical Corps. They have come here ami shmvn no t,i..(n~,^ rtiad toij
1 the Army
Corps. They
here and shown us pictures ~-..i
us that in some areas it was not effective. It was not tactically successful."
I
An early protest by scientists against military uses of herbicides was
| contained as an addendum to a statement on biological and chemical
jl weapons-adopted by the Federation of American Scientists, at a spring
| 100-i meeting of the FAS Council. After urging "nofirstitae.?' of
| chemical and biological weapons, and discussing these at some length,
I the statement concluded:
'

.
,
r
a e o a n g aigents
h.:ve t'OL-a used to destroy protective cover have boon continued by reprawentaI tivt-s of the Department of Defense. These charges give rise to the broader fmpli|e,iriou that the United States is using the Vietnamese battlefield as a psrovlng
I fi'-.iurifl for chemical and biological warfare. * * * We are * * * opposed to
je.':;vr:nientatlon on foreign soil, and also feel that such experimen-tation laivoly-|:r'~ citizens of other countries compounds the moral liability of such actions.'* - •
I Later, when anticrop K.-.--J of defoliants had been adopted as a policy
| in Vietnam, a prou;.-:t was addressed specifically against this practice .
I by a group'of 29 scientists from the Boston area, under the, 'leadership' '" "••
| of John Kdsall, professor of biochemistry at Harvard University, in '
;
January 1966. However, the remedy sought by the protesters was the
,
e proesers was te

abolition of the use of defoliants. The group appealed to the
President "* * * to proclaim publicly that the use of such cheaiical
1 weapons by our Armed Forces is forbidden, and to oppose their use
I'.'y the South Vietnamese or any of our allies."' According to thcr
|-*V.-:raent—
•
.
'
.*•,'
3 Kr.-n if it can bo shown that the chemicals are not toxic to man, such tactics
•.I;.-- barbarous bccausi? they are indiscriminate; they represent an attack OTI the
I 1 :. riff population of the region where the crops are destroyed, combatants and
if i •:,,T&gt;jjib.itnnts alike. [Moreover, such attacks would serve as a] precedent for
I !.•• «:.•?(; of .-cir.-iilnr but even more dungcroti.s chemical agents against our allies
fJTj-i our.xdves. Chemical warfare is cheap; small countries can practice it &lt;cffeeI'ivp.'j- against us and will probably do so if wo lead the way. In the long raw .the
|;-.- ,it .•.-iK-h weapons by United .States is thus a threat, not an asset, to ouar na|i'.f;.-il security ,**

| During the latter half of 19fiG, a move was initiated within tho
;,.-. •i.-iber.-Jiip of the American Association for the Advancement of
?-'• ii-iiro (AAAS) to formulaic and adopt a policy concerning rnuliI ;;ry use of herbicides. The lengthy process of assessment by the AAAS
I
-J " I'.S. CII.'I^T '•(•». Ilnnxe. Coti»iillti&gt;c on Appropfjjitlnris, Drjinrtuii'nt of IVIVn.so Apffiritj.'l.-ifl'ii.i) f...-- I'.n/ii. IIcnrlniTH brtotf u Kiiticniiiinlttfc of tlin . . Tnrt 5, l!«\sp;tr«:li. IVuu-liip.?•:?:.-.•. To«t. .in 1 1 3«s-».
! &gt;:,!, iti'i.o) :&lt;{&gt;. Hrniiiallon. Svith CuiiK,, lut KPH*. ( Wunhhitttou, U.S. Oovi.Tuuu-Ht 1'riaitlni;
•1 -!--(. (OirtolH-i- I l i C j ) . on Itlolodcal and Clirmlcnt Warfare." Ilutlclln of the Atomic Stdcn•"•K.'.H Stati'iiif-nt. |. [i. 4C--1T.
ij
I « "Mcieri(!.Nt* i'rot.'st Viet Cruji Diwtruotloii," Science (Jan, 21, J!)0(i), |), 300,

is the subject of the following section of this study. The remainder of
the present section will give illustrative examples of ^Ife protest,
movements, during 1967. and after, that lent prominemj^^HiH is.sne.
A more broadly based protest of scientists against "ai^B^akt-ning
of the worldwide prohibitions and restraints on the use of chemical
and biological (CB) weapons" was expressed in a letter to Pn-sirlcnt
Johnson, September 19, I960, by 22 scientists from 12 diil'erent edu'-ational institutions (seven Xobcl laureates). This group related to ' ; CIJ
weapons" the "large-scale use of anticrop and 'nonletlwl' antipersonnel chemical weapons in Vietnam." Tliis activity was seen as a "dangerous precedent" because "no lasting distinction seems feasible between
incapacitating and lethal weapons or between chemical and biological
warfare." These chemical and biological agents formed a "continuous
spectrum" such that "if the restraints on the use of one kind of CB
weapon are. broken down, the use of others will be encouraged." Ac-.
cordingly, the group urged the President to—
"Institute a White House study of overall government policy, regard i:ig CB
weapons and the possibility of arms control measures * * *."
.
"Order an end to the employment of antipi-rsomiel and anticrop chemical
weapons in Vietnam."
"Reestablish and categorically declare the intention of the United States to
refrain from initiating tho use of chemical and biological weapons." */

Both lists contained the names of four members of the faculty of
the Harvard University biological laboratories. These were: .£oim
E&lt;lsidL Matthew ^ S. ^fcsolson Keith..
Po'ter .
were -'crecTTfecl, late Tr7 10GG, with^collecting tiie
signatures of more than 5,000 scientists as cospo'nsors of the

' Adviser. "The originators sent out 50 to 100 letters and the Federation of American Scientists sent letters asking' its 2.500 mombers to
get signatures, tho men explained." 40 Among the signatories of the
petition were IT Xobcl laureates and 120 members of the .National
Academy of Sciences. Those prosontiny tlm petition were Meselson,
Edsall, and Paul lJ&gt;oty of Harvard, and Irwin C. Gnn?alus of the
University of Illinois. 50
_ I n midsummer 10(17, Kdsall again attacked ant'uTop clieniii-iils. His
views appeared in Scientist and Cili/cn, a* journal ptiblislu-d by tho
committee for environmental information, St. T.ouis. Mo., in a special1
issue addressed to the subject of chemical and biological wurfaiv. II*
asserted that "fateful p^ol'u'V dec|sioiys,iregar(liii'ig .X.l.!g-(.to-yj.'io|)-UiciiLaiiil
l^^L.o.I_fxliCmL^AiiindJmib4d^4-^^^

n mv

.

confront us and olhi-r

peoples throughout tho world/' The immediacy of such doi'isions, li«»
went on, "largely arises from tho use, by our own Armed Forces in
""SclcntUtrt Speak Out On CK Woupons," H u l l . -tin of tin- Atomic Scientist*
. p.. .'!!&gt;..
" "C»--Knt&lt;-rln« Wcilue," Th« Nntlnn. (.Tan. 1rt. inr,r&gt;, p. (IS.
•
'
-• :
•"".1000 Scl'-iitlsts Asl&lt; Hun (in (ins) In Vli-tiiiim." WiiHlilinrton Post. (Feb. 1.1, tOi'.T).
. A-'l.
1
*&gt; "Chemical u»J I!lolo«lcnl Wiirfaro IVtltlon." Science. (Fc-b, 17, 11)0"), p. SIS.

�Vietnam, of ^
' gases in military operations, and of defoliants
.and herbicic"*
destroy crops in areas under control of the Viet.
lu the
of the journal, Jean Mayer, professor of nutrition
at Harvard University, attacked the use ofmh^ii)icj^l£|_jtfi^d.ejitrj
cro
l;£Ji!L!k!L!l?J£^^
?'c.ili£U£. °J 4Lll^X^'an^211lllilii2i1':; IJ-e contended that military services, TiiclutlTiTg even~"\ lefnamesIT'guerrinas, had better medical care
than civilians, and-also "Vieteong soldiers may * * * be expected to
fret the fighter's share of whatever food there is." He drew parallels.
from instances of military blockade in history, and asserted that "food
denial in war affects the fighting men least and last, if at all, and is,
therefore, unsuccessful unless accompanied by military victories by
the blockaders. It is hardest on civilians, particularly children and
the elderly; -where economic class divisions are sharp, it is particularly hard on the poor." "
Another article in the same special issue of Scientist and Citizen, by.
* When we intervene in the ecology of a region on a massive scale, we
&gt;et in motion an irreversible chain of events which could continue to affect.
;;.'_&gt; agriculture and the wildlife of the 'area—and, therefore, the people,
-!..•-. 5 after t h e war Is over.
•'
.•
. - .
.

Gali'ton referred in his article to a letter which he as one of 12 plant
hysiologists had written to President Johnson (and that had been
c--produccfl .1in the ii._
January 19G7? • ,.f -i Bioscience, •p. -.10): this letter
issue of • 1 1 i •
_•&lt;
j.!,_j.
...:.... . . .
11

concentration of toxic herbicides, or of toxic reaction products with
the- soil, in food chains; soil erosion from contatnin.it^Hfcdl bared
of foliage; wide-scale self-poisoning of plants by toxic P'j^^H' stimulated by the herbicide; injury to fish and wild iiiaimnalsjcjprdeliiyed
toxicity. .
In summary, the Galston-article concluded:
' We fire too ignorant of the interplay of fonvs in efolo^icnl i&gt;rolil'. p rns to know
ho\v far-rc;ic)iiiiK and how lasting will be tin; (•h.-inyc's'in tc-ol'Cfy brouxlic about
by the wi'd'-spreitd sprayijis of herbicides in Vietnam. Tlio-c clia)is&lt;".&lt; jn.;y include immediate harm to people i t i - t h u sprayed areas and limy extend to .-ftri'/us
and lasting damage to soil and ngriculture, rendering more dillicult Kouth
Vietnam's recovery from war, regardless of who is the "victor.":l
. The association of herbicides with chemical or biological warfare,
germ warfare, poison gas, and other "inhumane" weapons was p^n.'erally characteristic of the numerous letters to the editor and as.-om15on protests during this period, attacking the use of defoliant
chemicals in the counierguerrilla program in Vietnam. To an indeterminate extent, of course, these protests reflected a generalized dis-'••*
• • - IP -...i T T C «
..*.t~'.~.^t.'&lt;

in "arms control and disarmament" as a new uueiieciutu uiscipune.
and the development of criteria to limit the kinds of weaponry used
in .war or used a^ "deterrents"; difficulties "were encountered in distinguishing between the military use of herbicides to gain military
advantage and the use. of various chemicals having direct physiologica"!
effects on nvnvrplevant to warfare, and particularly those frum-mr
within the scope, of the Geneva Protocol of 102.V?
•

'•. tbitants, according to Galston, were the alleged toxicity of cacodylic
:;.[: " injury to crops from drifting spray or volatility (there ifave
•'••! about 500 complaints or requests for compensation filed with
.ifjik-t chiefs for transmission to the- province chief in one urea alone);
"John T. K&lt;!*a!t. "Introduction." Scientist and Citizen. (Vol. 9, No. 7, 1067), AugustS'-rt-ml.vr. p. 113.
"Jean Mayer. "Starvation as a Weapon." Scientist and Citl/en. Op. cit., pp. 110, 121.
"Throughout the course of the technolog!&lt;;al assessment of military use of herliiddes
In V i e t n a m , one element at Issue was the toxicity of these chemicals to tnan and animals.
Czro'lyllc acM was hlnKlKl out because it contains the element, arsenic, within Its complex
E:'-:ecuhir structure. Since most itrsenlc-containing compounds are highly tosle to man
&amp;i.d anin:.il^. the a-^urnptlon WUH made that caeodyllc aeid had this characteristic. However,
t';^ i f K I Ki'i-irt, a f t e r snrveylnff tl.e l i t e r a t u r e on this point, ohservcd (p. 1C-I) : "In the
&lt;••!,.'ninatinr. of th« potc-ntlnl toxicity hazard for this compound, \ve are jmrtlcularly
l~. ; , r ..,,.-.,j (,y the ]v,w oral tuxlr-lty." Dr. Tsehlrley, In his report at SalK"ii (see pp. SO-'U'),
g i : t-- c'-inparittlvtt lethal dosage rates of "ARent Blue" (coDtiilnitii; &lt;ir&gt; percent cacodylic •
aci'li and "asiilrin." The terms he used were "I-D")!)" or nveniKC lethal dose In mllllKrnmx
t.f chemleiil p*-r kllngram of bo&lt;Iy wi-lfht. The Hfruro for "Itluu" IK 2000; the figure for
" A « p l r i n " M 177.".. In his report nt .Siil«mi fin "Toxlclly of Ilerlilclile.H in f'se in ICV.N."
I'r. Min.-crlif asserted t h a t it wa.s "currently helnj; em|ilciye&lt;l nt a rate no higher than !»..T
[and thi-rcfnre]. It i» safe"to assunif'thttt there, w i l l hi; no harm to nmu
or anlRi.-cU nt tin
rat. •*."

/ . . • ! • ,

f

1 .

, .

• -I

.
.-&lt;, sum mi- 1^.1 m.n. , .,t v^. t&lt;&gt;n..&gt;i^
employed were in common use in th.c United States. (The rationale
was similar to that used to justify the employment of tear gas (CS)
against guerrilla forces; this kind of agent was, in fact, in general
use by civilian police forces throughout the world as an antiriot agent.)
.Some confusion was contributed, however, by the imprecision of
military usage of terms. Thus, the Joint Chiefs of Staff Dictionary 8 *
defmes'herbicidc as "a chemical oomnouud which will kill or
include? "omplants." Chemical warfare is extended, by definition, to incl
* *''
7&gt;lovment of chemicals * * * to create a military advantag
.
Biological war faro is defined as "employment of living organisms,
toxic biological products, and plant growth regulators to product- death
or casualties in man, animals, or plants or defense against such action."
&lt;" Arthur W. Galstnn. "rhnnjrinir the T.nvlrontuent." Scientist nnd Citizen, op. cit..
i. 12.'t-120. Pr. Gcilxhm wns* professur of biolocy at Yole tlulvvrslty. imst presiitent of
e American Society of I'lnnt I'hyMologlsts, ami pri-shlent-olect of the Botanical Siieiety

. illspi-rxm] In nature, rind oceurs n a t u r a l l y in the Koli nt rnteu milistiintlnlly higher
thnn thnt cnntriiiuteil hy thf- siiriiyinj,' of areas at the rate of !&gt;.;) pounds per iicre, the
additional nrnenlc from caeodyllc: uciU can apparently be regarded an trivial.
lilclrth - J oiv.n t Chief* of R t a f f . Dlctlonarv of T'nited Ktatea M i l i t a r y Term* for Joint
w
U.S.
i
(Short Title: J O ) . (\VanhlnRton, D.C., U.S. Government PrlnttiiK Oillue, August 1,
JC'S 1'ub. 1.
'

�Clearly, by th&amp;?e definitions, herbicides arc, both chemical and biological \vaVf:n"e &amp;£«.^|fcj[Iowever, the same definitions would also esncom- .
pass the use of^^Bcieidcs to control typhus epidemics in relocated
refugee camps.^d^
On the other hand, it can be plausibly asserted that the use of .tear
gas to flush guerrillas from tunnels to face hostile bullets; or ifee denuding of foliage that conceals guerrillas from hostile fire, are both
forms of chemical warfare with ultimately lethal consequences. In
tluvo two cases, the chemicals are not the, direct cause of defttla, but,
:-:ui l&gt;e regarded as an accessory before the fact. Acceptance or-condemnation of chemical defoliants on legal or moral grounds therefore
ap;x?ars to hinge on whether those judging the action find the conflict;
iu-i-lf acceptable on legal or moral grounds.
Evaluation of the anticrop program appeal's to have followed somewhat the same rationale. The "scorched earth" policy in warfare tends
:o l&gt;e praised when conducted by one's allies—for example, the
[J.S.S.K. in World War II—and condemned when practiced by/one's
i-iversary—for example, the pollution of wells and waterholes daring
: i
:&gt; withdrawal of the Turks from Arabia in World War I.
The introduction of the concept that belligerents share a responsi".'••: for preserving the ecology of the area of conflict is a very
' -.--; development. Presumably it is an outgrowth of several con••;iry trends: (a) the concept of limited war for limited cJbjec'. ,•- . generally regarded as made necessary by the development of
;•••• uiously destructive nuclear weapons that enable nations possess-.
r.g them and their means of delivery to inflict "unacceptable" &lt;da-in-'
.ge on other nations in a general war for unlimited objectives; (&amp;'| the
nonr.ous potency of modern chemicals, whether used in military cam- " "."':
iaign.s or for civilian pursuits; (c) the increased concern .of scientists . ,
•&gt;r the protection of the total world environment-to preserve its bsafeit- ' :.'
h&gt;ijity for mankind at largo, and (d) the recognition that the human
•opulufion of the earth is expanding at a rapid rate, and is now ffore. ••;• n to IJQ approaching the limits of the capacity of the earth to sustain . • .
In.-re.isingly, the-criticism_ of the military herbicide program in
"u-tiiiuii by some U.S. scientists has focused on the ecological issue,
f was .-tressed by Galston in his article for Science and Citizen. Tt -vvas
;&lt;j main question considered by the AA AS (as discussed in the auction
f _tins study to follow). A strongly worded, forensic stutemerai in
'•ientisf. and Citizen in mSd-1%8 elaborated on this theme with
:.~rv.-_t to piclorain, a newly developed herbicide- being iutrotlmcetl
t military use iu Vietnam. The article stressed the unmatched potency
f the herbicide, its longevity and uncertain fate in the soil, the d:taiger
* its migration either along food chains or watorl&gt;orne, the possibility
uit if.s extensive application to tropical soils would expose therm so
; to cause luterization (i.e., a process by which some kinds of soils in
iC Tropics when exposed to the sun become infertile and too Shard
&gt; plo\v)j ami tl i;it. death of trees would cause t!ie death of many ami-.
;tl species. Concluded the article: "The military upped for [i.e^-of]

!-n for
this herbicide is obvious; pilots-spraying it don't have to
reapplication. Bub the Vietnamese farmer wants to re^
Also ill 19G8, Professor.Galston took his case against
r y use
ngdom.
of' herbicides to the scientific community of the United
In an article in the British journal, Xew Scientist, he declared that
"The United States, which was the first arid so far the only nation, to
use nuclear energy 1'or military purposes, has recently become the first
and so far the only nation to use m war chemicals directed against
rowing plants." The eiiects of this action, lie said, were unknown and
gro
possibly disastrous:
-One must conclude [he wrote] that the ecological consequences of the widespread use of herbicides Iri Vietnam are unpredictable. We are certainly. rtoina
some damage to the ecology of Vietnam; just how much and how long lastin
will bo discovered only after the "experiment" has .boon completed."

Earlier, Galston, had denounced U.S. plans to "prison the_son'^so
as to denude completely the vegetation from a strTp~^r7ancr"goTTig
entirely across Vietnam from east to west.
This mamnade desert [he wrote] separating Xorth from South Vietnam, ami
presumably serving to prevent infiltration, could have ecologically cata-strophical
consequences which cannot at present be envisioned.
In summary, we'are too ignorant of the interplay of forces in ecological
problems to know how far reaching and how lasting will be the changes in ecology brought about by, the widespread spraying of herbicides in Vietnam. These
changes may include ^immediate harm to people in the sprayed areas and may
extend to serious and lasting damage to soil and agriculture, rendering more
difiicnlt'South Vietnam's recovery from war, regardless of who is the "victor.""
K
George J{. Ilnrvey nnd Jay D. Mann. "Plcloram la Vii-tnum." .Si'lftiti.-'t ami Citiztn
. (September, 10CS1. pp. 165-171. Tills article ivas subsequently an.ilyyod Ui tletnil !&gt;y *'::£.
• incmbi'in of Dow Chemical Coniiiany. producers of filcl-iram'. ThVy t-luir^iHl that the a u t h o r s
hull been guilty of "inference, misquotation, uml m i s i n t t r p r e t a t i o n of ptibli.-h.tj scifniltlc
dutii." For example, the article dcclnrvil that "A vbccp was killeil by a dive of tliirty-six
milligrams of plcloram mixeo! with 2,-1-D.: However, the reference cited as a u t h o r i t y f'»r
•this statement reported tlint 11 sheep h.-ul bec-a treated with Ji'j mllllirrnins of plclor.\m
' mixed w i t h l.'!-J milllKmins of 2,4-1). per kilogram of bo.ly weight, with 5 daily treatmeut.-i.
The results of tills experiment were that of tbe 11 sheep so treated, all became sick and
4 died. Assuming t h n t tlie average bndy weight of a slieep n*as 2S kiloL-nims, t h i s would
amount to a totnl ingestlon of 5,000 milligrams o£ plcloram and SH.iiiH) niniifrrams of
2,4-D «V('r n 5 day period. (Source of the tinnlvslH : J!. C. Byrd. Marguerlt.- I.euc, J. II.
Davidxon, E. E. Kenaga and J. C. Hansen. "Critique of Ficloram in Vletuaru." {DowChemical Com pan v.) September, 10i!.&lt;. p. 11-12.
" A r t h u r W. Gal.ston. "Military Uses of Herbicides In Vietnam," Xcw Scientist (June IS,
.10(58). pp.
flRft-SS-J.
•
•
"Arthur W. Galston. "Herbicides In Vietnam." The New Republic. (Nov. 20, 3907), p. 21.

�' IV. BOLE OMHE AAAS IX ASSESSING WAR USE OF
.' ; ^A
HERBICIDES
. •
The AmericamKsociation for the Advancement of Science was
organized in Philadelphia, Se.ptembei"20, 18-18, by a group consisting
mainly of ideologists and natural scientists. Its objects were initially
to promote scientific intercourse, stimulate and direct scientific research, and "procuro for tho labours of scientific men, increased facilities and a wider usefulness." In 1000, Science magazine became tho
official publication of the association. As American science expanded,
specialized societies proliferated in new fields of research, and many '
of these became affiliated with AAAS: indeed, most had been organized at annual meetings of the parent institution. By 19G9, the total
membership of AAAS was put at 120,277 and the total membership
of the affiliated societies and academies of science exceeded 7 million.
In 1046, the association adopted a new (fifth) constitution that »edefined its objectives as:
.
* * * to further the work of scientists, to facilitate cooperation among; tliem,
to improve the effectiveness of science in the promotion of human welfare, and to
increase public understanding and appreciation of the importance and pciomise
of the methods of science in human progress.

Regional divisions of AAAS were established including one for
the Pacific i-egion in 1915. It was at a meeting of the Council of the
Pacific Division, June 15, 1966, that the issue of war use of. fcerbi-'
cicles first entered the formal policy deliberations of the AAAS. AJ;
^

It proposedli resolution 'fwTcoiisiderauolTBy:"fnTcouncil} wKicli. read':'
Whereas xinits of tho U.S. Department of Defense have used both chemical and
Inolojricnl warfare agents (as defined by U.S. Department of the Army, TMS-216)
In nj.--r;if.!ons against enemy forces in Vietnam; and
Vi'terL-as, tba effect of these agents upon biological systems in warfare- 5s not
AW.va to the scientific community; and
'
•
\\1iereas. the scientific community has a responsibility to be fully informed
•at these asent-s arid their use in warfare because they are a result of senentilic'
rest-arch: Therefore b e i t
.
. ' . . ' .
- -

1. The Pacific division of the AAAS establish a committee of expert* in
the field of biological and chemical warfare to study the u.se of CW HVU&amp; BW
agents In Vietnam with tho purjwse of determining what agents ha we bcn»n •
used, the exti-nt of their use, and the effects on all biologic-ill systemts that
might have been affected.
2. That the above committee make n public report of their findings Jit the
next meeting of the Pacific division of the AAAS.
'

The minutes of the meeting reveal that the Pfeiffer resolution Iliad a
mixed reception, Eventually, the council decided to refer if—without
recommendation—to the national office of AAAS. Even this decision .
was controversial—being carried by a 9-to-5 vote with several abstentions. During debate on the resolution, members of the council &lt;ques- ;•
t.ioned the propriety of having the action taken at a regional meeting,
viewed tho issue as more properly one for treatment by the National
Academy of_Sciences, and rejected the proposition in the, resolution
that the Pacific division had tho means to conduct field iuvestigaitions
in Vietnam. .
.
• •

Orrjaniaatitinal Structure of the AAAS ' '
The AAAS is a complex federation of scientists u!
societies, designed primarily to facilitate the exchange
information. It has six classes of members, general arid administrative
officers, a council, 21 sections (organised by scientific discipline). 245
aflil iated scientific organizations, 4h associated academies of science, and
nine committees.
A difficulty in appraising the effect of an action "taken by theAAAS". is that there are many'levels at which views can !x&gt;, expn;s~&lt;;d,
but no ready means to obtain ft consensus of the entire mernl&gt;ership.
The large membership of AAAS exists mainly to receive the organization's periodical, Science. Only "fellows," who constitute some
18 percent of the total membership', are eligible to become'officers.
The council of tho AAAS, consisting of some 530 memtais, is not
elected from tho AAAS membership at large. It includes officers of the
AAAS (elected by the council);''officers of the sections; two representatives each, named from those affiliated societies with more than
100 members; one representative, from each affiliated academy of
science; and a number of others. Although the members of the council
may in general terms be regarded as spokesmen for the disciplines.
or groups they represent, ihev are not literally "elected representa'.tives'.'of the AAAJrJ membership;
.
.
The board of directors of AAAS, which is the "legal representative^
of the association, consists of the president-elect, the president, and the
past president; eight other fellows; and (ex-oi'icio) the executive officerand tho trensmtr of AAAS. Tho px-ofllno of!ii--(&gt;iM pre ii-inxiinted by
-the board; the regular' members of the board-are elected by the council.
•'_• Positions on issues can be taken by the board, the council, one-of the
•nine committees, by requesting affiliated societies and academic to
express their views, or conceivably by, referring an issue to a vote of
the entire AAAS membership. The board meets four times a year, and
can adopt actions at these meetings. The council meets annually (between Christmas and Xew .Year's), and takes up issues at these
meetings. '
' '
•
The president of AAAS is chairman of the council. Quo of the nine
committees deals with council affairs: its chairman is the presidentelect of AAAS, who serves in this capacity for a year before becoming
president. Among the duties of this committee are to "rtveive or iniiiate, coordinate, and advise on reports of council committees, resolutions, or actions submitted for consideration by the council."
AAAS Councils Action on Pfciffcr Resolution
As president-elect of AAAS, Mr. Don 1C. Price, dean of tho Kennedy School of Government, Harvard University, wti.s chairman of
tho connnittoo on council affairs in the fall of 10GC. In this capacity,
he received Professor Pfein'or's resolution. During tho yearend meetings of AAAS, in Washington. D.C., the committee on council affairs held a public meeting, at "syhich PfeiiTer and others spoke on tho
subject of tho proposed resolution. A f t e r this open session, the committee in an executive session decided to modify tho resolution before

�IV. RCXT,E £E THE AAAS IX ASSESSING WAR USE OF
;
^A
HERBICIDES
The AmeriSKVssociation for the Advancement of Science wasorganized in Philadelphia, September 20, 18-18, by a group consisting
mainly ofi.ceologists and natural scientists. Its objects were initially
to promot't- scientific intercourse, stimulate and direct scientific research, and "procure for tho labours of scientific men, increased facilities and a wider usefulness." In 1000, Science magazine becurae the
official publication of tho association. As American science expaiaded,
specialized societies proliferated in new fields of research, and many '
of these became affiliated with AAAS: indeed, most had been organized at annual meetings of the parent institution. By 19G9, the total
membership of AAAS was put at 120,277 and tho total membership
of the affiliated societies and academies of science exceeded 7 million.
In 1!HC, the association adopted a new (fifth) constitution that nedeiine-d its objectives as:
* * * to further the work of scientists, to facilitate cooperation among tliein,
to improve the effectiveness of science in the promotion of human welfare, and to
increase public understanding: and appreciation of the importance and pwomise
of the methods of science in human progress.

Regional divisions of AAAS were established including orae for
the Pacific region in 1915. It was at a meeting of the Council of the
Pacific Division, June 15, 1900, that the issue of war use of laerbi-'
cides first entered the formal policy deliberations'of the AAAS. AJ; ^
th5s_jn£^.jiig, the, secretary presented a communication froniELJJV. *
proTessor orlsooloifvTfTlicrCniversity oOlontaiia.
iFproposedTa resolutioiTfor coiisTcIe"rauoirf&gt;yTIie couiicT17'\viricli read:
i*"*"?"^' -——-••-p •--— "i"

•• ••&gt;'•**«..-..-*—^Wg—&lt;»«-.•-.."—.-&lt;-!•*•-»• • •i—i-^-.i.».....'.^^.»—~.y^...»i..».-.•&lt;•»..—.. ^ , ,

Whereas units of the U.S. Department of Defense 'have used both chemical and
Moiogical warfare agents (as defined hy U.S. Department of the Army, TM3-21G)
i" operations against enemy forces in Vietnam; and
"Whereas, the effect of these agents upon biological systems in warfare is not
known to the scientific community; and
•
•
.
Whereas, the scientific community has a responsibility to 'be fully informed
ft these agents and their use in warfare because they are a result of-scientific'
restart-h: Therefore be it
'
.
Rcsolccd, That—
'
.
1. The 1'acific division of the AAAS establish a committee of experts 5n
the field of biological and chemical warfare to study the use of CW awd BYV
a grunts in Vietnam with the purjxwe of determining what agents havw been used, the extent of their use, and the effects on all biological systems that
might have been affected.'
2. That the above committee make a public report of their findings ;at the
next meeting of the Pacific division of the AAAS.

The minutes of the meeting reveal that the Pfeilter resolution liad a
•mixed reception. Eventually, tho council decided to refer it—without
recommendation—to the national office of AAAS. Even this derision
was controversial—being carried by a 9-to-5 vote with several abstentions. During debate on the resolution, members of tho council: ques-

Organizaticinal Structure of the AAAS
The AAAS is a complex federation of scientists
societies, designed primarily to facilitate the exchang _
information. It has six classes of member*, general and adinini.-frutive
officers, a council, 21 sections {organised by scientific discipline). 24.".
affiliated scientific organizations, 4S associated academies of science, and
' nine committees.
A difficulty in appraising the. effect of an action "taken by tho
AAAS". is that there are manylevels at which views can l&gt;e expressed,
but no ready means to obtain a consensus of the entire'membership.
The large membership of AAAS exists mainly to receive the organization's periodical, Science. Only ''fellows," who constitute some
18 percent of the total membership', are eligible to become'officers.
. Tho council of the AAAS. consisting of some 530 memlxjrs, is not
elected from the AAAS meimVrshi'p at large. It includes officers of the
. . AAAS (elected by the council); ofTicei-s of the sections; two rc-pre. seuttitives each, named from those affiliated societies with more than
100 members; one representative from each affiliated academy of
science; and a number of others. Although the members of the council
may in general terms be .regarded as spokesmen for the disciplines
/vrtL or groups they represent, they are not literally "elected repre.-enta3^6 . . • tives" of the AAAirJ membership.
The board of directors of AAAS, which is the "legal representative"
of the association, consists of the president-elect, the president, and the
past president; eight other fellows; and Cex-oHicio) the executive o.Ticer
and the treasurer of A A A S . Thf px-nfllcin officers nre u-nrx&gt;intt'd by
'••the board; thfe regular members of the- board- nre elected by the eounril.
•' ' Positions on 'issues can be taken by the board, the 'council, one. of the
•nine committees, by requesting affiliated societies and academies to
express their views, or conceivably by referring an is^ue to a vote of
tho entire AAAS membership. The board meets four times a year, and
can adopt actions at these meetings. The council meets annually (between Christmas and Xew '.Year's), and takes up issues at these
meetings. '
'
•
The. president of AAAS is chairman of the council. One of the nine
committees deals with council affairs: its chairman is the presidentelect of AAAS, who serves in this capacity for a year before becoming
president. Among the duties of this committee, are to "receive or initiate, coordinate, and advise on reports of council committees, resolutions, or actions submitted for consideration by the council."
A A AS Council's Act fan on Pf differ Resolution
As president-elect of AAAS. Mr. Don K. Price, dean of the Kenairman of
ne dy School of Government, 1 larva rd University, was cha
tho committee on council affairs in the fall of 10GO. In this capacity,
ho received Professor Pfeill'or's resolution. During tho yearoml meetings of AAAS, in Washington, D.C.. Jtlu&gt; committee, on council affairs held a public mooting, at which Pfeiil'or and others spoke on the
subject of 'tho proposed resolution. After thi.s open sessi
'
the committee in an executive session decidod to modify tho resolution before

in Vietnam.

•r.

�introducing; i t a s new business before the council. 60 The resolution as
redrafted' by^fc^committee had received PfeifTer's approval.151 Its
text at that
&gt;ad as follows:
Whereas mo&lt;f?Hr"seier!ce and technology now give men unprecedented power
to niter his environment and affect the ecological balance of this planet; smd
Whereas the full impact of the uses of biological and chemical agents- te&gt; modify
the environment, whether for peaceful or military purposes, is not fully known;
and
Whotviis the major users of these agents on ft scale sufficiently large to modify
the ecological balance are now the governments of this and other countries: Be
it
Rcxolrctl. That the American Association for the Advancement of Science—
(1) Expresses its concern regarding the long-range consequences of the
use of biological and chemical agents which modify the environment; and
(2) Establishes a committee to study all aspects of such use, starting with
the effects of chemical nnd biological warfare agents, and periodically to .
report its findings through appropriate channels of tho association ; and
(3) Volunteers its cooperation with public agencies nnd offices of ffovernn:ent for the task of ascertaining scientifically and objectively the full implications of major programs and activities which modify the environment
and affect the ecological balance on a large scale.*J

Tlie. resnon.-e of the council to the amended resolution was. later
described by Mr. Price, as follows:
' • •'
After I Introduced the resolution on behalf of the Committee on Council Affairs,
and told of our discussions^vith you and your approval of the text which we had .
;&gt; iopted. there followed a long nnd rather.vigorous debate. The key points an that
•:'. -Sate were as follows :
On motion of Bentley Glass two amendments were voted in the next to tlie last
I'-irLigraph of the resolution: the first deleted the words "all aspects of" and the
nd siiiintitutrd "including" fur "starting with." Oa the- former point IJentley
that no committee could study all aspects of so tremendous a problem, n n d -$-*
• particularly urged that such a committee not undertake to deal with the politi- -.
'1 aspects of, for example,.biological and chemical warfare. Dr. Rapoport and I •
•-!: .•irgu^l against this interpretation, holding that it should be possible to study
'••••i'ifically the political aspects as well as—although perhaps not as objectively
•.. •; rigorously as—any other. Thnt particular amendment I bc-lieve carried more
..:-.-;i- others thought that the whole field was an impossibly broad one rather
.-:. br-cjiu&gt;-(! anyone wl.shed to exclude any particular aspect of tho ppohlcrn.
.- &lt;-.t!:er revision (the substituting of "including") wds defended on tlie argu• • thar fhf commit tee's hands should not. be tied with respect to its owra judg- • .-. r.f priorities and that the council itself should not prejudge the f.^siie of
.-;:ii-s. Both of these amendments were carried by a vote that was so over• !::ilng tli.'it no one demanded a specific count.
i'•,'.•!&gt;. a cotiiii-il member whose name I do not know, objected to the identifying
' "t!,f» crovernments of this nnd other countries" as tho principal offender*,, fin tho
•-•MMt-nt that industrial corporations and, indeed, private citizens and private
.."::-r.bi!(..i were responsibl" for much of the pollution of the environme-ait. He
.•••—.I,to .strike out t!if&gt; third "whereas."
Ar:,l again this motion was carried by a very heavy majority.
Thrt-o, Ted Byerly of the Department of Agriculture then moved to tuMc the
:?:re resolution, denouncing it as watered down nnd weasel worded, but adding
.f—-If I remember his language accurately—ho did riot like the original resolui f referring to your own) any better. The vote on this was close enough KO that
• :-ouM not make a suf!i&lt;-ir&gt;ntly accurate count from the platform on a sKaow of
:-•'•; but had to appoint toilers to walk down the aisles to be certain. But tho.
• :!»jr '.it table lost and the amended resolution was then carried although by a
• v tli.sr seemed to me re:: ",'i;U'ly close.
l
YiiiJf T fim sure you v.v.ubl him- preferred not to have these several amu'iid- '
i-cf* uiii'i;.t&lt;-d, I am Inclim-,1 to think that—judging from the close vote- which
«"rx-(f.T Inm rrire- In t'ti-llTrr. Jnn. S. 10(17. It in IVnri Price's rcoullcrtlon Mint he
!;.&lt;'i]sM-i| tli.- m i i t l f - r w l i l i I'r(&gt;f''«snr I'Mffi-r nfti&gt;r fhft opr-n hcarlnu nn&lt;l li'forc ttw Com,;U.-P nii-i'tin^. nn.i dint PMffT l«-ft (own (»&gt;fnrc tlic Council inPctlnff.
" Ix'ttr-r fn.m I'fclffor. to I'rl'-&lt;&gt;. Di'C. 27, tOC.n.
"iflniHrs &lt;i£ the Mectlre of lhc AAAS Council, VTnshlngtoQ, D.C., Dec. 30, 11)00, (&gt;p. 7-8.

prevented the tabling of the amended resolution—the nmendimg^^-ere necessary to the passage of the final vote. I am sure that a number 0j^^Hl' !ik&lt;; Hrtitley Glass would liave voted against the unarnendcd resolution,^^•Kreut many
more against the resolution in your original form. There is sf^ffi a. question
whether compromises are worth it in order to get something pas.st.'d, but I hope
that you will feel that something useful may yet come out of this effort."

In reply, Professor Pfoiffcr professed himself "pleased" with the
final product." The closeness of the division on final adoption of the
twice-amended resolution by the council is indicated by the vote: li"&gt; to
approve and 95 opposed. In its final form, as approved, the resolution .
read:
Whereas modern science and technology now give'inan unprecedented power to
alter his environment and affect the ecological balance of this phuiot; and
Whereas the full impact of the uses of biological and chemical agent-; t&lt;i modify
• th'e environment, whether for peaceful or military purposes, is not fully known:
Be it
'
Jffevolved, That the American Association for the-Advancement of Science—•
•'..' • (1) Expresses its concern regarding the long-range consuluences of the
' u s e of biological and chemical' agwiw which modify the environment; and
(2) Establishes a committee to study such use, including the effects o£
'' chemical and biological warfare airents, and periodically to report its findings
through appropriate channels of th-- association ; and
(3) Volunteers Its cooperation w i t h public agencies and offices of government for- the task of ascertaining wifntifieally and objectively the full implications of majon programs and activities which modify the environment and
affect the ecologfcal balance on a large scale."1

Implementation of the 19GG AAAS Resolution on Ilerliciths
In its final form, the resolution dealt primarily with the issue _of
environmental impairment oa a prloV.al b;i:i::,;-.::;! only very icor/r.darily
with military -use- of herbicides-. Also, while Pfcifi'er had ?ou&lt;rhi'ajy ..
actual scientific field investigation by qualified ecologies under AAAS
sponsorship in Vietnam, the AAAS Council had lx?en content to_e.\pre.ss concern over the lon&lt;r-riui[re consequeni.-es of the use of chemical
and biological agents (whether public or private) that modify the
environment, to establish a committee to study the jreneral question,
.-and to volunteer AAAS's cooperation with the Federal Government
to identify implications of major programs that "modify the environment and sv fleet'the ecological balance on a large scale." °'3
The council action on the amended PfeitVer resolution wa-? re|&gt;orted
tothe AAAS membership without any particular emphasis."7 The first -.
implementing; action in response to the, resolut ion was the formation by ;
the AAAS board of directors of an ad hoc committee on environmental :.
alteration, during; its nuTtiag March. 11-1*2, 10t&gt;7. The committee was
M
Letter from Price to Pfelffer, Jim. 3. liW. Op. clt.
' &lt;« Letter from Pfclffor to Price, Jitn. i). ISMiT.
"Minutes of the Mcotlng of the AAAS Council, Washington, D.C., Dec. 30, 1000, Op.
clt. p. 1).
.
*&gt; In comment on tlie foreeiilnc: ncctlon, hy letter of July 7, IfldO, to Mr. R. A. Carpenter.
Dt'iin Price. KiiKgcHtH ttint the forek'olni; ncconnt of AAAS (lelilicrnfhiiis. wlillc "accurate
«« f u r ns It KOCH," Is "mlsleadlni; In tliiit It tells the xtor.v only from the point &lt;&gt;f view
of V l o t n n m nnd Dr. Pfelffer." Hn olmiTtvs tlint rniuiy nienitiers of the AAAS K&gt;:iril hel&lt;l
the view Hint the Association for nevi;ral yenrs liinl lieeii concerned &amp;* to tli» rel-iHon of
deletion tn e n v i r o n m e n t a l |&gt;rnt&gt;IcniM unit K«W the I'fc'llTer resolution &lt;u fnllini; Into tlilsi
context. In retrospect, Peiiu Trice continues, •" * • I'crHiinitlly, I t h i n k It w.1.i i inl^tiiiir&gt;
to combine- the two lH«ue» (puiern! coitivrn for envli-oinneritnl iiolllitlon ninl 'th' *(."i'lal
jiroblem of V i e t n a m ) . " Moreover, tin; new'swortliy nspect of the I n t t e r t&lt;«ni» c.-iu-'e.l n
d l d p r i i p o r t l o n n t e uiiioun.t of n t t e n t i o u to he R i v e n It. AH Denn Trice snyn: ••• • • The
iicwnpiiper covernp- Iprnoreil (he Hear I n t e n t of tho Council am! portrayed the re«»Iiitli&gt;n
(is If It hud hoen nlmeil nt the V l e t n n m war."
*&gt; Duel.\Vollle ( A A A S executive olllcer). "AAAS Connc-lt Meeting, 10«0," Science. (Feb.
1007), |&gt;l&gt;. HRS-HflO.

�chaired by Dr. Rene Pnbos, Rockefeller University. Its members
included Pfjjjj^r and Mayer, who had been active in the herljicido
issue. Whe^^Hid hoc committee reported, in Alay, it recommended
e.scablishmc^^Hr a continuing AAAS "Commission on the Consequences of Environmental Alteration," and discussed three examples of.
problems with which the commission should be concerned. These were
chemical agents, chemical fertilizers, and waste recycling. The com-'
mission should have as its objectives the. improved management of information and education on environmental factors, and the design of
large-scale controls and emergency measures relative to major aspects
of environmental impairment.
.
'.
"With respect to "chemical agents" the Dubos committee identified
four of importance: pesticides (to control hicppf.^ Imi-KJnM,^ /+« ~—
_
^^.i.nnnju u^vma {iv iacmuue Harvesting and to improve visibility). The committee recommended that studies of the use of these
agents be made "in selected areas where massive programs ar« ia
progress." In particular: "In Vietnam such agents are being introduced
most intensive!v; therefore this is a region where the ecological eU'ectsniay be expected to be most marked."
- ' . r

&gt;3

Tho recommended studies [said the report] would involve continuing review,
collection, and analysis of information and reporting of findings of the ecofojdeal
c&lt;&gt;!is=equfnces of such massive intervention (for example, effects on nutritioa and
h'.-ukli, decree of aceutmilaticfn of the chemical agents in various links of the food
chuia. shifts in distribution of animal and vegetable species, patterns of recovery
0. trees and other organisms). The short-term consequences should not be ne•-•; ••.!•.•&lt;! ia uK-su studies, Lut sj»xi.-il attention should be given to lohjj-turm &lt;ow~. :'.:,:l changes, for altogether too little attention has so far been given to thelojig-':.,
'.-•:• f-CV'cts of massive intervention in tho environment.- • ; ." ' - - " : '
•• -""•

The committee offered a number of suggestions as to ways in which
tae proposed Commission should conduct its affairs..In particular, it. •
.-aid:
'
-'
'• •
Oa occasion, it may be desirable for the Commission -to make arrangementsr.&lt; have studies conducted by others. We recommend that the board of diwtorsf&lt;&gt;: AAAS] consider requesting the National Academy of Science to arrange acoririiiuin^ study and scientific record of the effects of chemical and biological warf:;rf n^'.;;its on soil, biota, and human health.
.
'

However, one member of the committee, E. W. Pfeiffer, took e.wep- '•
I ~-'.i to tliis suggestion. In a separate, "minority" statement, he said he'
;: i not believe that the National Academy of Sciences was "a truly
^:.i!i-pi-iv!'.:nt organization of scientists" Iwcanso it liad been identified' .
[ I.-i Si-it'.':ce. Jan. 13,11)071 as a "source of advice for the biological warf ifv tii'ort * * * and !iud also been involved in a postdoctoral research
••.•Hou-ship program sjKjnsoivd by Fort Detrick" ['!)iological warfare
•• ^&gt;arcli center], for which candidates were "screened by the. Academy''' .
.:•.'[ "permitted to describe themselves as having received a, NAS-XJJC
V'iowsljip."
. ,
-•' . : • . '•'
'ir-pfemrntalion of Recommendations', of the AAAS Aff Hoc
nuttr.c
•
•
receipt of the ad hoc commiltoc's report, tho AAAS board! of
•s at its meeting in June 1007- decided to divide tho general
t into two parts; one was tho general question of tho cotisef

qucnces of environmental alteration, and the other the specific question
of the use of chemical and biological^warfare agents jjjjjjetnam. The
Board, voted to ask the AAAS Committee on Science J^^HjPromotion
of Human Welfare to "assume continuing responsibi^pRr tidvishig
tho board concerning developments, actions, or proposals for action
that appear likely to result in major alterations of the environment,
and from time to time, as tho committee considers appropriate, to
recommend-that the board appoint special commissions for the study
of particular actions or proposals." The, board would then "appoint
groups of persons especially qualified .in each such urea selected for
• study and report."68 The board itself agreed to^accept responsibility
for the next stage of action on the specific question ol military herbicide use in Vietnam.
Implementation of Recommendation for Ecological Field Investigations
With respect to "the more specific question of the use of chemical
and biological warfare agents in Vietnam," the board recognized
that "no effective study of the effects of such agents could be carried
out in an active theater of war without military or other official per. mission and sponsorship." It therefore instructed the AAAS president
(Don Price) and the executive officer (Dael Wolfle) to urge appropri. ate officers of the federal Government to arrange for a thorough study
under official auspices. Accordingly—
•
• Conferences on this proposal were held' with Frederick Belts, who is Chairman of the Defense Science Board as well as President of the National Academy
of Sciences; Donald Hornig', Director of the Office of. Science and Technology;
and Donald MacArthur and Rodney W. Nichols of the staff of Robert S. ilcNamara, Secretary of Defense.-Following-these conferences, the AAAS pi'e*i-" dent wrote to Secretary McXamara, urging that a study by an independent sci.. eutific institution or committee of both the short- and, long-range effects of the
military use of chemical agents, which modify the environment be authorized and
undertaken.*

The letter to Secretary McXamara recognized that "decisions regarding the use of [chemical agents which modify the environment]
in various circumstances must'be made in-the light of tactical and
strategic considerations: but. that nevertheless, tile "consequences of
.their use may have such long-range social, economic, and political consequences,, both in Vietnam and on the world scene, that the problem
warrants study under tho highest responsible political auspice?." The
letter suggested that the National Academy of Sciences-National Research Council would be an appropriate institution for this purjxw;
an independent commission responsible to the Secretary of Defense or
to the President's Science Advisory Committee would be an acceptable
alternative. Tho letter concluded by offering "any assistance it "could
in such an undertaking, either bv sharing in its formal sponsorship, or
'• by advising in the selection of tFiose who are to carry out the studv." ro
. The AAAS letter of September 13, 10G7, was answered by Dr. John
S. Foster, Jr., Director of Defense Research and Engineering, Se'p.'" Circular Ictfir from Dncl Wollle, executive officer, AAAS, to members of tlic AAAS
Coiinr-ll, Xov. 1, 1VX17.
•* Idem.
*" Letter from I'rtco to Secretary McN'amurn, Sept. 13, 10C7.

32-405—00-

�;j ember '20. First, he. dealt with the present state of knowledge convi'tTning tile Jj^fe^- or long-term ecological impacts" of the use of
?&gt;J'ierbicidc5 oi^^^liant chemicals in Vietnam: Whether such impacts
/Jrxisted, and ^Bmer they were detrimental or advantageous, he said,
"j-vas not definitively known. Then he went on—

ment of herbicides for military rise; and (c) a generally sound reputation for. technically reliable work in chemically on^j^kl research.
According to the report, the contract ran from Augus^^HjDecember
. 1,19G7.'1
' ^^
Tho work statement for the MRI contract read as follows:

Qualified scapntists, both inside and outside our Government, and in the governments of othnr nations, have judged that seriously adverse consequences will
:»t oi-our. I'nless we li:ul confidence in those judgments, we would not continue'
these materials.
'
•

The contractor .shall review available data nnd information cori'-eniing the
ecological consequences of extensive and/or repeated me of lif.'i-bi&lt;-id(.v. Primary attention will be Riven to ^,-l-di&lt;-hloroj&gt;!icrioxyafetif arid, 2,-!-.~&gt;-trk-h!o:-ophenoxyacetir: iifid (including their various forms .such as tlic Jj'ityli-.stur.-)),
cncodyllo acid, and Tordon (trade; niiinu of Dow Chemical Co.). TJ:tta to b&lt;; v&gt;.:'viewed includes published literuUi're, but other source* Mjr-h a.s Federal dcjiartnients and industries must be used to the fullest extent.

- 'A

In view of the uncertainties remaining, Dr. Foster said ho had
iht&gt;a two steps. One was to commission a ''leading nonprofit research
'.&gt;titufi&gt; to thoroughly review and assess all current data in this
old." The other was to request the National Academy of Sciences';\tional Research Council to assemble a group of professionally qual;
:-.l experts to "review the results of the study and to make np:-.v|;r;.-:.v recommendations concerning it." Dr. Foster made clear
•••••! :-e expected no definitive answers from these actions. Instead,
.oy should be considered the first of a number of necessary steps.
:.0 itudy he hud commissioned should provide—
(1) A comprehensive compilation of available information;
(2) An assessment of the current information gaps;
(3) Inferences concerning any possible ecological impacts; and
(4) A ba=is for planning.
•'•
.' • .
Upon completion of this effort, Dr. Foster suggested, there should
'. a consultation concerning its findings between the Department of
•._-fr:;?e. and the AAAS leadership., in order to define next steps to
- t-ikc-n. The report was scheduled to be completed by mid-Deeernber,
.• t-.-iable i^.-i--examination-by the AAAS-Council and board-of di: rors in advance'of the association's annual meeting. - .
Dean Price responded for the AAAS board, October 2fi. He expressed
."vificution that the contractor's report and the National Academy of..
•''•jioes review would both Ixi available before the AAAS Council
'.- ting in New York City, "between Christmas and New Year's."
-• also asked Dr. Foster to elaborate on the"sources of informed
•inion that hud led to the conclusion by the, Government "that
:-in;i~Iy adverse consequences would not occur from the current use
' herbiHde.s and defoliants." In reply, November 10, Dr. Foster said
e conclusion derived from a "consensus of informed opinion" of
rue 50-70 individuals, in the absence of "hard data." Nevertheless,
; .-aid, "we remain convinced that our judgments were, and arc. reanable and take account of all significant data."
' •-* Midwext liezeMf'-.h Institute Ktudy of Ecological Effects of Ile.rlricidcs
Tlie selection of u contractor to perform (he function envisioned
• Dr. "Foster in his letter of September 20 had already been eoincfod at that time. The contractor was tho Midwest Research Insti.te, located in Kansas City, Mo. The qualifications of the. con tract or
*:.i-luded: (a) general familiarity of its personnel with tho chemistry
•f&gt;f herbicides, as u result of earlier work for the Food and Drug Ad|!iinistration on tho establishment of standards for pesticide residues
7m foodstuffs; (b) absence of any past participation in tho develop-

Simultaneously with the research project underway at Midwest I!e• search Institute, the staff of the AAAS were undertaking a bibliographic research program of their own, in response to instructions
from the board of directors at the fall meeting. Letters were sent to
about 100 organizations and individuals requesting bibliographic lists
on the subjects of herbicides and defoliants. This action was in connection with the 19GG council resolution "that the association undertake
a study of the long-range consequences of the use of biological and
chemical agents which modify the environment, [.and that if.] report
periodically its findings, and volunteer its cooperation with public
' agencies and ofiices of government for the task of ascertaining scientif• ically and objectively the full implications of major programs and activities which modify the environment and afi'ect the ecological balance on'a large scale."" Although the A A A S oflire in Y\*a.-iiiugTon,
D.C., accumulated considerable bibliographic information in response
to this request,'no further action was taken with specific reference to
'; these 'data;.' One of the respondents.-in fact, observed that "Your re•'.quest for information simply duplicates the eil'orts of the Midwest
• -Research Institute." ™
.
Cross-Pressures Within AAAS, Decembci^-Janunry. 19G7-GS
. The MRI report had not been available to the board by the time the
AAAS convened in New York City for its annual meeting. At the
AAAS Boa'rd meeting, Docembor 29, it became known that the committee on science in the promotion of human welfare, under the chairmanship of Dr. Margaret Mead, had concluded that it had more than
enough work already before it, and that the importance of the environ• mental issues identified by tho Dubos committee warranted the establishment by AAAS of a now permanent committee. Accordingly, the
board at this same meeting decided to establish a new permanent committee. on environmental alteration "and proceeded on the spot to name
ii few members (sonic at least of whom were in the room.") 74 The now

work on tli" roiiuostcil ns^
" Kxtniet from HAniplc Irttcr, nmoni? ft roup sfnf out NOV. 7. l!&gt;ft(, rfpro&lt;1uci&gt;il In Mr&gt;mo&gt;
r n n i l u m to A A A S Jtiinnl of Director*, I&gt; . 21, 11)07. by WilHnm T. Knbixeh.
" "-'•' p. ;t.

: from rrlcc to Cnrpenter, July 7, 1009. Op. clt

�committee, was instructed to "cany on a continuing evaluation of the
iinplicatj-on^^echnolo^ical intrusion oh environmental processes and
their inten^^Bp with human population ; and, in view of the previously exi*HM&amp; concern of council regarding the use of chemical
and blologicaOigents in Vietnam and elsewhere, to request the com-'
mitteo
committee
Barry Commoner of "Washington University, and Dr. Athelstan F.
Spilhaus, president of the Franklin Institute, initially named as members, with others to be appointed later. The board action \yas reported
:
to the council a day or two later.
Since the MRI report had been delayed, the council and the board of
directors would be unable to participate in a review of it at the time
of their convention in New York, at the end of 19G7. It was apparently,
understood that tho two issues, which the board had sought to separate,
could be brought together onco more within the purvue of the new
Committee on Environmental Alteration, if the committee desired this;
however, the committee had the option of dealing only with broader
and le?s controversial issues of environmental degradation.7? Apparently there was a good deal of pressure on the new committee not
only to'deal with Vietnamese herbicide usage, but to make it priority
business. Before the MKI report was made available to AAAS, the
new committee ran into a snag. Several week's-after its formation, the
chairman, Dr. Goddard, resigned, as did Dr. Spilhaus. As reported in
Science:
•
.
_
.
'
.
.
Both cited extensive professional commitments as' the reason for their resig-'
nation,--though Goddard, in a--telephone-interview with Science, added, • "no fwmT was my appointment announced tiian I started getting pressures from all
directions. The emotional overtones were terrific.""
. '
;• ' ,

Criticism was aldo expressed over the selection of members of tho .
committee."
'
' - ' . . •
•
'
Dr. Goddard sent his letter of resignation, as chairman and rnemJx&gt;r of the Committee on Environmental Alteration, to President Price'
of_AAAS, January 24, IOCS. The letter illustrates'the need for firm,
objective leadership in the face of the cross-currents, pressures, and
c-L'kulties confronting a science-oriented committee handed a heated
~ T!io precise rolo eipectod of Urn new committee wltli respect to the Vlctnnmcsc
-•;*•. nr. i ."a t&lt;* whf.-thf-r or not It wn* a part of the broader onvironnient.il Issue, Is a "mutter
" :i; ^--.-; : '.';it!'&gt;ri." In coinment on this s i t u a t i o n , D:ifl Woltlo h;iH oxpl.'tlnod that j* t tlte
..--.i-.-r:!/-,-. K)i",8, niWtlnff, the Board oC the A A A S "certainly intended ti&gt; combine th&lt;* lirrhl•:•• I.-.-.-.- nml the more Ee.'iornl nmttvra u n d e r tho sumo committee." lie adds : "TScis do-!-. p. wns, I t h i n k , a ivronj; one. It d e p n r t e i l f r n m the earlier decision of t h e It.i.ird to
'
.i-m Sf[&gt;;irate, ft po.-dllon to wMi:h the U&lt;\'ird returned at ittf March IOCS mp^Un^."
l l f . a l &lt; - t r r r to .Mr. R. A. Caroenter, Science Policy Kcserch Division, LecUHUive Iti-'fcrcnce
iw, J i i l v jo. irn;;&gt;.)
D. S.. Gei-enhftg. "D'.foll.-itton : A A A S Study Delayed by Rcalgniitions from ComiriUtee."
, (Vol. jr.O, L'.'i Feb. liHiS), p. S57.
'
"Thus, Cfcarl'- &lt;;. Wilt/or, Colorado State TTnlverslty, cornplnlued t h u t "It Rooms that
T n ,
Jr.fil.'idii.-iis were cho.--i-n p r l i n r i r i l v on the han[n of tlu-lr active political Involveira.i'nt In
ere
A A S riff-sirs." lie K»;;i:'-sted t h a t "tlie fact t h a t an i n d i v i d u a l la concerned about t» civen
In no way ' i i u i l l M i M him to n.ake j u i l t r m e n t K on that problem." He uls&lt;&gt; rxproiwii the
i,&lt;* "''.hit the jjowi* s t r n c i u r u in the A A A S will take a second look at this rornmiUcti ftml
.ii:r«: t h a t »t least one i n d i v i d u a l w!:o \n competent In the scientific nspects of ciM'inleftl
.irf.in; -will he lnrMiided us a votinj; uioinbcr * * *." (Letter to tho editor. Scientific He!xrch (Mar. IS, l O O S J . p . B.)

political issue. Because of the bearing of the letter oni tL^vliola probtern of technological assessment in a political envirom ^Hbc bour of
ie b
the letter is reproduced in its entirety, as follows:
DKAB Dox: This is to inform you that I am resigning as a m^iahfr'and chair• man of tho AAAS Committee on the Alteration of the Knvironruwjc. It i.s with
great rehietanco that I hiive cwue to this conclu.sion. TJie decision was not an
easy one to make and was based on two factors. Out- i.s that of severely limited
tijae: 1 .should iiavo realisii'd earlier that the enormous dwuanils rcijuin.-il of tin;
chairman of the committee would conflict witli my heavy m-iuZeniii; jidmijji.'-tra. tive duties at the university. The other i.s t h a t o f - t h e VSetnain issuer already
this issue is creating treinendous pres.surt'.s f»r tlie committee, not only more
time consuming and diflieult but wiiieh will also endanger U.s v»-ry purj'o.-e.
' iWhen we set up the committee we were concerned with intellfC'tual and practical problems of environmental alteration, whether they resulted from the i»&gt;i&gt;ulation explosion, from modern industry, from automobiles, from thy overuse of
jtpsticldes and herbicides, or from the excessive use of agricultural fertilizers.
The AAAS was concerned that it should not become directly involve*! in itoUtir-s
arid that it had a role to play in pointing 1 out to the public and the Government
' ways in which scientific .knowledge should be the liii.si»- for governmental action.
It also recognized that we were going to have to deal with tin; i»rohl"in which
has arisen in Vietnam due to the use of chemical agents, particularly lierbict(I"&lt;,
by the Department of Defense. However, we did not wane the basic life of the
' committee to be OTerwhelmed by this particular problem.
• '•
It appears that I was naive concerning the political pre-s^nrf* In relation, to
the Vietnam problem. Someone, probably someone connected with rh« Depart"
inent of Defense, leaked the report of the JJid'.vest Rr-'-'enreli I n - i t i t u t i - to fin 1
New York Times evtn though the report has been denied to the AAAS until the
National Academy of Sciences evaluates it. It is clear tli.it it is going to be
extremely difficult to obtain an impartial view of the report.
One might think chat professional scientists would not expect the ci-mmtrtee
to reach conclusions before it has received scientific evidence, but this i« clearly
not the case. The correspondence reaching my desk, and t.lie telephone'Crti!-• —
• niany of them from very "distinguished .scientists—iiidie.T'e"'that "many poodle
nave prejudged the issue before-any commiitfe can be formed. Ouj&lt;: t !vr.-? are
. trying to determine the composition of the committee arid the concliwir&gt;n&lt; tiian
it will reach. If this seems exaggerated, I would refer one to Luther Carter's
• article in Science, January 12, IMS.
Anyone who knows me knows that I would be unwilling to chair a committee
that would either whitewash tiie Department of Defense or would reach conclusions before scientific evidence was presented to i t ; I would also be unwillins
to servo on a committee that j 'was organized in advance to condemn the De-'
partment of Defense without adequate data. Though I have serious doubts of
the military necessity, or the morality of the American participation in Vietnam.
if I am to serve on a AAAS committee I must do so as a five agent. The r«&gt;!itical
climate within the membership of the AAAS is such that I do nut believe that
nn Impartial study can be made. I am al&lt;o afraid t h a t tin; Vietnam war and
the emotions that it creates makes dilHenlt any attempt to really evaluate tho
other important problems of tho alteration of the environment.
I reali/.e that my delay In reaching these conclusions has caused difficulties
for the AAAS. I can only wish it every success and IIOJH' thut a committee can
•be set up that can be of value not only to the AAAS but to American society.
With my best wishes to the officers and directors of the association,
Sincerely yours,
.'•
' ..
.
DAVID R. GoDb.uio.

Tho article by Luther «T. Carter to which Dr. Gmldard referred in
his letter was an attempt to specify tho task of the n.o\v Committee,
on Environmental Alteration, and to indicate tho nature of the challenges that faced it. It opened by stating that the- first order of business of tho committee would bo "the ecological impact of chemical

�agents U'-ecl^BK"ietnam and elsewhere.'* Factors in this consideration
would be t^^Bl! study and the NAS-NRC review of it. The_j&gt;ositions of th^Ppartment of Defense and leading critics of herbicides
in war were identified. One item of criticism of the cpmmittee «cited
by the article was tlvat of Dr. Pfeiffer. According to Carter: .
Pfoiffor fi-cls that, \\-hilo the new committee is chaired by David R. Gtoddard
mvost of tlio University of Pennsylvania) rather than by Dubos, it is essentially
fc;:tUu!ation of the iul hoc comiuittoo under a new name. His confidem:« in it
l'.'i be greater, he said, if among (lie members to bo added are people wach as.
i'^on ;it&gt;it two Harvard contributors to Scientist and Citizen's issue on ctuemicnl
ril warfare—John T. Kdsall, a biological chemist, aud Jean Maj'er, a
and specialist on the history of public health.
.
' '•

in his article, observed that among the members of the
'wore Barry Commoner, who had been a leader in the
information movement, in which Pfeifl'er also had been
Two other members—Dubos and Athelstan Spillmis—were
of the science advisory board of Scientist and Citizen, official
public-lit ion of the Scientists' institute for Public Information- Also
in the article. Carter had volunteered the editorial comment that not

confine Tthemselves to recommending further studies or action by
others." «
Xational Academy of Sciences Review of .MRI Report
The haste with which the MRT report was pressed to completion' is
.-Mrgested by the method of its delivery. On November 7,1967, the jSTAS .
P.sriel met. with personnel from MRI and the Oflice of the Dissector
f'! De-fense Research and Engineering, at which time copie's of chapters
1. 2. ?,. and 5 were turned over for analysis by the Panel. Then, on
D*'''V!i:ber 1. MRI mailed directly to the NAS Panel members complete
'••i-.Mu-s of the report. However, according to the later recollection of
V-'iliiam B. House, director of the Biological -Sciences Division, Mid•\.--~i Research Institute, the institute was dissatisfied with the appear;•&gt;.::•&gt;•• of the document, which had been typed on one side of the- page
only, making it voluminous in size. Copies of the revised report were
r.'i-cived by O.D.D.R. &amp; K. on December 20. These were sent, to the'.NAS
J Panel to replace the earlier copies. On January 31, IOCS, the NAS Panel
; Import was rer-eived by O.D.D.R. &amp; E., and on February 15, th? MRI
| report was made available for distribution by the Defense Docunawnta:
:| t;on Centora.s a method of public release.
| The review of the MRI report by the National Academy of Sciences
j (NAS) apparently beer*in Novemlmr 7 and was completed by Jatuwary
-i : '|, lOHS. In the mi-untune, however, as Dr. Goddiml had indicated in
| his letter of resignation, &lt;i discussion of the MRI report's findings had
: uppenred in the New York Times :' weeks earlier, and had apparently
|
;.f stimulated further excitement over the issue.'Treatment of the report
port
-,'oy the NAS was some what noncommittal.
I TGI*" I'D ''jr S\n~'nri*r'

r&gt;Vw A A A S

"Commlttco to Study Cliemicul Dcfiillnntfi.-

The report itself was a substantial volume, 3C9
referencing 147 persons as_ information sources, — :
1,500 items of bibliographical references. The re
ing findings: 79

aultilithed,
iges listing
the follow-

(1) Direct ecological conscrjuence of herbicide use in Vietnam wns tb£ destruction oC vefe'etation, setting a region back to an earlier stage 'of development,
from which the process of restoration would then occur.
. (2) Food chains of fauna mid heterotrophic; plants would be altered. 1
(3) I'hytotoxicity of herbicides in the soil wa:s not a con.-udrration. nor were
letluil toxicity to humans or wildlife, or concentration of deleterious chemical*
in food chains.
(4) Data on chronic toxicity were incomplete.
(5) Data on aquatic environmental effects of herbicides were inconclusive
:and niixed — some favorable and some unfavorable.

The report then identified four important areas of uncertainty that
. remained:
(1) The effect of . 2,4-1) and 2,4,.&gt;-T on water quality.
'(2) The possible threat to mammals and birds already approaching extinction.
(3) Micrometeorological effects of forest denudation.
!
(4) Possibility &lt;jf exposing lateritic soils, such as to result in tlif-ir hard&gt;nins
-•and infertility. .
•

Reoicw of MRI Report by National Academy of Sciences
In accordance &gt;vith the understanding between the O.D.D.Tv. &amp; E.
staff and the board of directors of AA'AS, the NAS Review Panel
was to comment, on "the thoroughness ;i:.d accuracy with which the
scientific literature relating to herbicides and their ecological e:"
. had been examined and evaluated.''
•
•;.-' The NA.S assessment (presumably drafted by .the Gluiirinau o!: the
Review Panel)'1" noted that the Panel had not functioned as a committee "in the usual sense'' because they "did not have an opportunity to
meet as a group after the final report was made available." They had,
however, provided specific comments and advice on early drafis of
•chapters in the report and, after completion of the first full dhift,
.submitted corrections, suggestions for deletions and additions, laud
general comments." The consensus of the Panel was as follows:
(1) Midwest Hosearch Institute Iws done a creditable job of culUrtin^ corrt&gt;t-tly abstracting, and citing much of the relevant published InfiTiiintitin, although, under the cifi-unistiuuvs, tin- report could not In- expected to covi-r in
u truly &lt;-ompreluM&gt;sive way so vast a literature. '
(2) Of necessity, the preponderance of the matt-rial deals with herbicides as
tUi&gt;y are used in vegetation matia^i'iuent in a diversity of situations and environments. On this general topic, abundant data are available. However, the M.-U-Utitic literature provides markedly less factual information on the ecological cmisenuciuvs of. herbicide use and particularly of repeated or heavy herbicide
applications. The Midwest Kesrurch Institute report correctly iviUrts this
disparity.

In transmitting the. report to Dr. Foster, January 31, IOCS, the
Pivflident of the National Academy of Sciences, Frederick Seitz,
' TnrnphrftMi'd from MRI report, Op c l t . , pp. 2nO-2!&gt;2.
"Tin- iviuiol WIIH Hinlri'd hy l&gt;r. A. S. Crjirtu, ViilvrTstty of Cullfornln at tinvli. Mem1v&gt;r« wrc : Or. K c l t l i C, HiirroiH. illrcctur. I'lunt Science Ilowiirrh rind IVvi-lupmcDt,
I)&lt;iw CliiTiilrul C&lt;». : l&gt;r, lUfiiiint Kfliri'iiH, ili-tuirtiiK'ni »C *ite«tiatny nn,\ pliint irftu'tlfs.
« l n l v . of M l n i i . : l &gt; r . W l l l l u i n S. lti&lt;iuiliiKlii)ir. i l i ' i m r t i H i - i i t of tx'tany, Unlv. of Mii.-!i. ; Dr.
W l l l l n m K. Kurtlfk, {tcpiirtinnat of farm rni|'«, ()n-i;»n Htuti- i'nlv. ; nnj Dr. Wiirr.in C.
Sluiw, crop roxi'iircll illvlnton, A c r l c u l t i i r n l IteMcnrcli Scri-liv. U.S. IVpt. of Agrlcu'tute.
Th«.M!&lt;I ri-port w«n Hiihmtttitl to the 1'rcnlUctX ot.tlie N'.VS. Jun. 29, IOCS.

�expressed the view that "it is clear that the compilation of this report
is onl
-'ep in investigating furl her fc3ie ecological effects of
^^^ herbicides. Some research in this area is now under
but WiK more 'needs to be clone." Dr. S«*itz indicated that "the .
Academy will be glad to participate in any useful way in the planning
and promotion of such research."
Attached to the Panel report were 16 excerpted comments by mem| bers, not individually identified, that the chairman judged tp be
"informative and illuminating." These are briefly summarised as, •
follows:
•
• • . , . - ,
A good job, particularly considering the short time in which they had to- .
conduct the- study and prepare the manuscript.
There is a need for short-form [ecological] studies [including determination
of residues in
fish].
•
.
.
* * * A substantial report in the restricted time available * * *. However,
the re]x&gt;rt cannot be considered a complete compilation of the available scientific
literature on herbicides or the ecological consequences of herbicide tisasc .
Unfortunately in ecological evaluations quantitative conclusions must in
c:fi-t instances ?:ve way to qualitative judgments Erased on past experience.
'Questioned the "areas of uncertainty" cited by tlie MUI report.)
.'T'ifferencc'in biomass betwen Vietnam and temperate regions exaggerated.)
"; l:e entire section evaluating the major ecological 'Questions and making a
j, :,'ment on each one is sound in all respects. It is conservative, yet not ex^ x-'ively so. * *.* The problem of soil laterixation [rsiay not be real].
I am very favorably impressed by this entire section of evaluation.
* * * Reasonably accurate and fairly comprehensive Teview of the literature.
(Ho-wovor, noted that there was a dearth of literature directly pertinent to- th? title of the MIU report.)
Kcological consequences of herbicide use, which is the main theme for the
nianu&lt;=cript, suffers most from the inadequacy of the Jtuforiuation available to- , .
actually present an assessment.
.
„
..
-•• . . ' : " .
* * -* A more adequate job could have'been done in reviewing current researchuii'lr-r way to strengthen infonnation on ecological nspt'-cts eff herbicide use.
I
(Tlie report did not consider a wide array of ;';:'-&gt;j-?efs !by the Department of '
I ---. -,-r;-:ulturi! bearing directly on the relationship oH ii'-rlijcMcs to the environment.) _ '*
'- ' *" An enormous number of hours researching the literature, and developing' .
| ; -.i.k^round understanding of tlie field of herbicides. * * * Put together as a .
j r- :•. :li entirely of knowledge gained -through literature review without a working-.
I J-.-i'.-kground in the field involved. (Frequent oversitaplsffications but.reasonably.
I thorough and authentic.)
'
-^ (Evaluation by XAS is based on currently used fceirlncides.)
'I (Ic.suflkient knowledge available about movement antS persistence of picloram
S : M S'.-ils and water.)
.
'.";•.
ii {Concern for lateralization is exaggerated;'soils aze not laid bare.by her*
H-iddes.)
.
'
- ' •
••• -

rf the MRI Report
'
'
\
. ;\'. .
\ Ta the professional press, the if RI report had a&gt;. smixed reception. Dr..
11'red IT. T.-;cliirley, an authority on herbicides with the U.S. Depart- .
'if! -\';i of Agriculture (Assistant Chief, Crops Protection Branch, Agri.if::.]rund Kc.-'oarch Service, USDA), called it a we33-done literature re- '
fvlew but "disappointing localise its direct applicability to Vietnam
.|i.-i so tenuous."S1 Ecologjst JFnuik E. Egler, who Iiad pioneered in the
.}u-e of herbicides in Connecticut, comp In ined of the study'that "NcitJier • .
•the published literature, nor the scientific knowledge allow us to make,
~-y,\ afif^-ssment of long-term ecological effects of extensive or repeated
i:..-« of herbicides."" Howard T. Odum, of the University of North
j—
.
'"litvlewH," Kcotogy (Vol. ^f•, No. 6), p. 1212.

'

. .-

'

Carolina,83
observed that "Data on Vietnam ecosystems are not in this
volume." Science News titled a description of th^H^I study "The
Nondefinitivelleport." 8l
^^H
'
deception by the general press was also diffusecl^BFinconclusJve.
' i

-i r

J.I.- -.,...,...* 4-1.,,f *!-.„,

Vietnam." 0 " INCWSWCCK wits jnun; »A^U^.II&gt;. jji^u. ,. t ^.. v..^ ......^..v.v-voluminous report in hand, neither the. Pentagon nor the AAAS is
• likely to be satisfied entirely." in fact, the article continued, "Thy real
evaluation—in the field—must await a quieter and safer time for scientists in Vietnam." 80
Thomas O'Toole, in the Washington Post, had his story headlined
"Defoliation Threatening Viet Wildlife." 87 William Hhies r story in
'the Washington Evening Star, was headlined "Defoliation Study a'Bit
Hazy—Vietnam effects unclear."ss
A succession of headlines- in the Xew York Times illustrates the
equivocal effecti of the ^Mill study. _ Thus, on January*^T./\a preliminaryY*4. -»
i i
»j. 1 . 1 t. , „
.i',.,,-.^,/] ,.-^_. 1
T ii,, .,/] J»T
?

ew Victim or me n ar, xuaiuiue/ -; It is possible that much of the news comment about j:he report was
j prepared on the basis of a short summary of its contents prepared by
'Dr. llaywai'd of the oflice of the Director of Defense Ittseuivh and
, jEnghveerhur find released' arpun'd"February .1', ls"&gt;GS. The full 'Mill •
I report and'jt.he accompanying XA-S analysis were hot releaied' until
'February la.
- •
" : . '
In the .opinion, of Dr. House, "* * * The, press, at least to my knowledge, [were] addressing themselves to a release before the report itself
was available. Although it mentions in the release that it was a 3t59•'.pago "state-of-the-knowledge.'! survey, 1 feel that some of the comments conun'g from the press might, have been slanted in a diu'erent
way if they-;had been reporting directly from the report itself. The
report carried a considerable amount of factual data and our pliilos. ophy in approaching this problem could not be adequately expressed in
a 41/j-pago summary." 03
.
By the latter part of February'IOCS, there was a good deal of confusion as to the status of the "technological assessment'' that the AAAS
had undertaken in response to Dr. Pfeiil'er's communication, Thisstato
"Idcm.
« vol. n:i. 24 TVb. inn&lt;». p. iss.
» (Kch. 2.'(, 1110S), p. 70.

.

» (Fob. so, i n n &lt; 5 , |&gt;. no.
« h-'ch, 11, inns), p. A-l. .
* (Jan. SI, 11)08), p. A-7.
» (Jim. 7. 10OS), p. 3.

*&gt; (I'Vb. 1.1, lunsi, p. 4.
•1 (Fi'h, IS. I'.H'.Sl. II. 5.
« (Vc-ti, an, uxts&gt;. p. o.

*» Jitter to Mr. Cnriicntcr, op. clt.

�.

,v
•|
•jf
.'4
.f
$
4
.'-'
$
•'3
:Jj

formexl to inviSJ^Po us&lt;\s of cli'omlcal and biological agents. I'feiffer haw offered'
to servo and is now planning to bring pressure on the association, to spoEwor an
extensive symposium on the subject. The Scientists' Institute for Public Inferjjujtian in Xcu' York will be eulistod by I'fciiTer, nltlioug'i another group—Thysiciiitis for Six-ial Hfsjvnisiliility—has already offered to help. This group tos had'
exivrieuro of firsthand Held research in Viotnam, having visited hospitals there.
If the AAAS won't, sensor the symposium, said I'feifl'er, another organMationlike the International Red Cross or the World Health Organization will be-'
approached. ''The symiwiinm would hopefully stimulate people to go iflito the''
fit?Id and get data on the effects of herbicides. This should include Vietnam in1
areas which are not continually under fire," Pfeiffer said."

I Thus, by the. first, half of 1968, the problems of conducting a teehno$ logical assessment by a large association of scientists had been identi3 fled as complex and formidable.
3 There, was the importance attached by many leaders of the scientific
| community to the preservation, of the canons of scientific objectivity,
.5 which meant avoiding resolution by scientists of technical issues into•I which a considerable element of political controversy had entered.
: | There was the problem of screening out of the controversy the bias
4|of those who were opposed to all forms of participation by the United'
t|8tates in the Vietnamese conflict, and who rejected out of hand the•"^defoliation program as merely one- more Manifestation of a program
Jfto which they objected on broader, political'grounds.
:•* There was the tendency of some scientists to recrard the orgainiza:

'•-i'

•

.. . 1

. . - 1_ . •

IT-..

f

: 1

• •&gt;

.

.

/.

-r^

»

^

. .

'; a conspiracy to defend and justify programs simply on grounds'
•r&gt;; ;hort-tenn military expedience. .:^ There was the fundamental difficulty that the sciences "contributing: Jo- -ecology u'cre insufficiently developed to permjt definitive findings
|i- to the long-range impact of herbicides even. in the United States
Js-.-here they had beeji used for more than two'Vlecades; so that an
"|i -:&gt;--?ment of repeated and possibly heavier application of herbicide
in an altogether different ecology, under the hazardous coiidi•\i\--:\&lt; of a diffused guerrilla warfare, posed insuperable problems of
•J/^nitive assessment.
I An assessment of the use of herbicides in Vietnam required (ft)
•"'Vrvincial resources to mount an expedition, (I) military support for
,,|' t f » gain entry to the combat area and receive protec
protection wliilo
' j r n ' j f - t n g its onsite examination, and (f&gt;) stafling by recognised
'-'-iontists unconnected with any aspect of the defoliation program to
-tablish objectivity and maintain credibility. It. had l)ecome apparent
|i:rit tho-MRI report was only the first step toward such an assessJi''nt. Wljilti it had eliminated- a number of questions it 'had raised
•'|r underlined others. Hut there ii[)peared to be a growing consensus.
" ' . further investigation w a s needwl.
.-

J

" SclenUDc Research (Feb. 19, 1008), p. 12.

,.J _l^n r r —

^^^^

There have been outright attempts to kill the project couiplete^^^ v,-&lt;-nt on].
Are American scientists capable of making an inderxmdent study or not? So
far the situation has been up in the air. You cannot get the AAAS board of dire-ctors to commit themselves to'such a study, am] I don't think the average AAAS
member knows that the study was ever being considered.
. He regarded the use of defoliant chemicals in Vietnam as a "burning '
issue" and said: "I hope the new committee can send a. group to Vietnam, and that it will include people who are concerned with this
. issue."K
•
, '
•
-.
Dean Price saw the role o£ AAAS somewhat differently:
' .
Our role is far from finished [he said]. This i» a slow process. My own opinion
is that we had the choice between the kind of operation that would call for
n. large staff and large sums of money to do firsthand field research. The AAAS
has never done this. We operate by committees and review field work done by
others. To do Held work In the combat zone is even more difficult.
We could have mounted a protest movement which would have achieved
little and which would have been opposed violently by the overwhelming majority
of our member*. The other way was to get the best scientific study done, and
then have a committee of hard scientific competence to review it1*

When tho MRI report, and the accompanying assessment by XAS,
reached the oflices^f AAAS, early in February, the association was
unable to take any immediate action because there was no continuing
group in session. However, in March, the board of directors met
and voted to accept directly the responsibility to review the Mill
• report. Arrangements were made to have copies of both th« report
and the NAS assessment, provided'to all members; in addition, the'
AAAS staff, was asked to send copies to a number of consultants to
secure their comments and advice.97
•
The precises function of the AAAS in relation to the MM report
is not clear. From the point of view of most board members, the- important question was^the broad, long-range condition of tlu&gt; human
environment. The military use of herbicides in Vietnam was decidedly
secondary. Tho latter issue was also so inflammatory that any AAAS
committee asked to study both the general environmental condition
.and the specific issue of Vietnamese herbi.cide usage, would be under
great pressure topical primarily with the- secondary issue. Experience'
had shown tho diflieulty of organizing u committee willing to accept
both.issues.
'
Onco tho Mill report had been received, the board decided- to
accept direc.t responsibility itself for the assessment of the report and
of the Vietnamese herbicide issue. It was not accidental that a number
of board memlxjrs were qualified as biologists or ecologists, specifically
""'Chemical War: a hot potato for AAAS," Scientific Research (Jan. 22, lOOS), p. H.
. •i Theno wore Bent t«» members of the DiiUos Committee, ami of tho Committee on Science
" Idem.
In tin- I'romutliin of Human W e l f a r e ; they iiNo WITH Kent to nine presumed authorities in
tho Ili'M. of whom only three rrttirttnl tliclr comments before the June nwtiui; of (be
Board, Ho.wever, at the .Tune/ meotliiR the Hoard received the benefits of extciuU-il com. Ou;niH from llnrnlit Coolldno, executive director of tin- 1'acillc Science Hoard, whu had hrcn
In Vietnam a few motitlm earlier, and hud met with Vk'tnamcHe HClcntletM IntcrcstvU In
tin; ecological cffcctH of the m l l i t i i r y Mac of hfrblcltlcH.

�( f u - v . Giiiiiiionc'r, Huagland, Steinbach, and T h i m a n n ; the biologic
soien.v.-; h^e always been strongly represented in AAAS membership
and Kv^flwp, although nol necessarily the particular sulxfeciplines
(tropid^^Blogy, plant metabolism, weed chemistry, an&lt;I control
proeesse^Wc.) most precisely germane to the MRI report and the
related Vietnamese issue. On the other hand, the board members '
reasoned that the board itself could not escape ultimate responsibility for any.report generated by the committee of the AAAS, because the public, release of any such report would require board review
and approval in any case. Moreover, the issue was regnrdetl ..as less
technical than of a'general scientific-political-organizational nature.
' The issue was what AAAS should do about the MRI report, rather
than the scientific task of designing a field study of the consequences
of the use. of herbicides in Vietnam. Finally, the board could, If necessary, obtain the advice of a technical. committee or of individual
consultants, in handling the matter. Distribution, of the MRI report,
as described above, would facilitate this.
•
Assessment of MR f Report by AAAS Board of Directors
In mid-July IOCS, the Board of Directors of the AAAS issued its
own policy statement on the use of herbicides in war. The statement
took the form of a review of the MRI report, together with'tlse XAS
commentary on it. The board almost unanimously issued a basic statement, accompanied by three supplementary-statements by "some members of the board of directors," and a separate dissenf by a single board
member who preferred an entirely different analytical approach.
In the basic statement, the board expressed t-h'e conviction that
"many questions concerning the long-range, ecological influences'/of y "
chemical herbicides remain unanswered.;" One of these was the extent :
of long-term deleterious-effects of the forest defoliation in Vietnam.''- : '
They also questioned the use of arsenicals on crops and the "ultimate
route taken by arsenical compounds in plants, soil, aiWl animaJs.w Accordingly, (hey did not '"'share the confidence expresses! by the TVj-wutment of Defense * * * that seriously adverse consequences win not
occur as a result of the use of herbicidal chemicals in Vietnam, insofar
as arsenical compounds are concerned.'' They also took account of the
"serious concern expressed by scientists in Vietnam 'over long-term
environmental consequences of the military use of herbicides." Be- '
cause of the uncertainties in available, evidence of these consequences,
said the board, "such charges cannot now be answered unequivocally."
Accordingly, the board recommended—
\
That a field study he undertaken under tho auspices nnd direction of the
T'nited Xntions, with the participation of Vietmtmpse scientists arwl scientists
ir'/m other countries, find with cooperation, support, nnd protection prorhtwl !&gt;y
I-he contending forces In the area. This study, which could well ho supplcHsr.-jited
&gt;.'&gt;• pxi*'rim&lt;-;if;il work els"when&gt;, should provide n detailed environmental tin- • .
.'jjys-is of the lonff-njiijre effects of the agents used and of tho steps necessary to
.-; r-ure optimum future prodinMrltf of tho environment for the welfare of its ., '•
i.-.h.ii'itarirs.
-. .
•
•
•...._....
- ."". .
Further, we nrjre that the maximum possihle, nmourit of relevant data be .
released from military security, so that the scieritistw conducting the studf anay
kiioyv the
r-mjiloyed. arcnn affected, the ngent.s used, the dates applied, nnd the dwiages

We express especial concern about tho nsc of arsenical hprbl^kg! in Vietnam,
and urge that their use be suspended, if it has not already U^^HJopiff'd. mull
the ultimate fate of the degraded arsenical compounds cai^^^Kre reliably
determined.
•
^^J
We recognize the difficulties involved in the proposed field study: however, it
.is our hope that the feasibility of such a study may be increased as a re-ult of
the current peace talks ijj| 1'aris.
Finally, we hope the' recommended study can bo initiated promptly and we
proffer the good offices of the association in helping to plan it and to publicize
its findings.1"
'

One.' supplementary statement, by Messrs. Commoner, ITolton, and
• ' Steinbach, declared that the herbicide program, should be stopped because (a) U.S. experience was not relevant, in view of the higher do=ajre
levels in military use; (&amp;) the chemicals inhibited the formation of
nitrogen-fixing nodules in leguminous plants; and (c) might cause
widespread chromosomal, damage among plants. Moreover, the use of
herbicides raised serious moral and political questions whiHi "Ought
to bo carefully considered in the present national debate on the morality and political wisdow of the war i n Viet nain. 90
A second supplementary statement, by Messrs. Roberts and Tliimann, took specific exception to the first supplementary statement, and
held that "the use of 2,4-1) and 2,4,5-T for defoliation of forest cover
probably represents a military device for saving lives that has an tui• precedented degrefc of harmlessness to the environment." in!'
A ^ third supplementary statement^ by Messrs. Glass, Hoagland,
ilolton, Klopsteg, Price, Kees, Rieser, Roberts, Steinbach, and "\Volile,
agreed that United Nations sponsorship of. the recommended study
• would be desirable, but insisted that "iix case such a course of action .
•'is not politically feasible for the United Xations,'theU.S. Govm-maent
should reserve the option of initiating and supporting such a study
..through some private institution or special panel of independent
observers." m
A fourth supplementaiy statement', by John A. YTheeler, a juiclear
physicist, expressed the view that 20 years of ecological research would
not produce "an order-of-nmgnitude increase in the available iuformat ion," and that enough was already known for the immediate jwlicy
decision. He recommended greater effort in disseminating herbicide
information, issuance by tho United Nations of limits on arsenical
herbicides, U.S. research on herbicides in the. United States, and ac• ceptance of tho existing situnf ion in Vietnam in which the local people
had tho responsibility for deciding tho military use or nouttse of
herbicides.10;
A clarifying exchange regarding this action by the AAAS board
appeared subsequently in the pages of BioSciencc, the journal of the
. American Institute of Biological Sciences. Prof. A. Carl Leopold, of

»» 11)1(1., p. 2.Vi.
Iil.'tn.

�ti:o Department of Horticulture at Purdue University, in an editorial
stareme-m aj^^^ t h a t t!ie cil'oets ot' military herbicide use should be
studied; bi^^Bacted strongly airuinst the position taken by Messrs.
Commoner JpPFon, and Steinbach: "* * * With 500,000 American
men in a killing war in Vietnam, to assert that this herbicide cannot
Iv used in protecting them, when we use f&gt;7 million pounds of it per
year in our own country, is fantastic.'' 103 The three AAAS board.
nu v mlK&gt;rs whoso, position Leopold questioned, replied in a joint statement in the December issue of the same, journal. They referred to Dr.
Fu-tcr's assurance to the AAAS board, by letter of September 29,19GT,
(1) Qualified scientists, both inside and outside our ^Government, and in the
governments of other nations, have judged that seriously adverse consequences
will not occur [from the military use of herbicides].
(~2) Unless we had confidence in these judgments, vwe would not continue to
employ these materials.
•
'
.
.

The respondents insisted that what was involved was scientific judgment : whether the use of herbicides by the military services would in
fact, have serious long-term ecological consequences. They went on
to suggest that the Leopold editorial "* * * reflects confusion re-.
garding the role of scientific judgment in the social issues which
involve substantive questions of a technical nature."
Kvery technology [their statement continued] involves benefits and hazards;
scientific evidence is required to evaluate the extent of (fee hazard associated with
a given benefit. However, a judgment which determines whether the estimated
hazards outweigh the estimated benefits is not a scientific matter. Such a judgment
must be made by an individual on ethical grounds, and Ivy a society on the basis
•:&lt;f political decisions, which it i.s to be hoped, reflect ilic moral views of that
society. It i.s i/erhn]« useful to point out that the Ooveniisaent of the United States,
has already forsworn the use of certain weapons in Vietnam that might con- .
'•civably, in the short run, save the lives of some U.S. soldiers: nuclear weapons.
The present question i.s whether the chemical weapons now in use in Vietnam
ought to fall under a .simi'.ur proscription. Leopold is, o€ course, free to express
his own view &lt;in the moral Judgment, but he, and other responsible members of
•In- scientific commur;ity, also have an obligation to refra.it] from confusing their
own moral judgment with scientific fact.10'
,.
• • • -

of AAAS Correxpowhncp, with Stale. Defoitsc, and United
• Nations .
'
. • - •
Following the AAAS board meeting, lot tors were sent out "July 19,
|]Oi;,S, over the .signature of Dr. Dael WoHle, e.woutive ofiicer of the
f AAAS, to the Secretaries of State and Defense, and to the Secretary
:]' (t-iH-ral of t!ie United Xations. The letter io list- Secretary General
rransmifU'd a cojjy of the statcmont by the Ixwrd of directors, and
fn-k-ed that consideration be given to the, proim^n] that (he Uniled
Xah'ons assume responsibility for a study of the long-term effects of
jthf 1 . u-c of flii'inii'iil hei'bicides on the ecology of Vietnam, This, said
it : ic Ictft-r, would be a ''means of insuring objectivity and iutjTnatiniiiil
|;&gt;artiri|iafinn "' * V The response, August 5, signed by .lost' KolxiF'f-nnoft. fixU-r Secretiiry fieneral for Special Political All'airs, indi•atcd that, the Socivlury Cioiu'rul oll'ered assunmcos " * * * that the
|.iatt4T of Hicmiral and bacteriological weapons 5s receiving his very.
i-ioHc attention."
•
8, vol. IS. No. !)), p. «53.
i," KiuSclmrv, (Ijrcrmbnr, JfKJS), p. 1007.

The response of the Department of State, dated Septea^er 3, signed
by Charles E. Bohlen, .Deputy Under Secretary, to^BLte of the
fact that "there are differences of opinion on the use o^^Kn chemicals even among the members of this distinguished grou^r l^ivcalled
'that limited studies, already made by Government • agencies, had
"failed to reveal serious ecological disturbance.-;/"- It. acknowledged,
however, that "the ultimate ell'ect, of these herbicides c"in_ be determined definitively only by-long-term studies." Accordingly it favored
• such a long-term study in Vietnam. However— ' .
Such studies in combat areaH are.'obviously difficult at present. The United
States will be happy to cooperate in responsible long-term investigations of thi.s
• type as soon as practicable. The participants should be selected on the basis of
their scientific competence to insure acceptance by tbe .scientific community.

, The AA AS letter to the Secretary of Defense expressed "ratification
at the MR I survey. .But it noted "that "* * * on .a number of points
information is lacking or insufficient."
• .
The [AAAS] board has concluded that a study should be conducted of the
long-term effects of the use of chemical defoliants on the ecology of Vietnam, and
• has proposed that that study bo carried out under the U.X. auspices. A majority of
the members of the board have added a supplementary recommendation that th««
United States assume responsibility for such a study if the United Xations is
unable to do so.

gn
t eip
the AAA|S board,1 and repeated the earlier assurance that herbicides
..would not be used if competent opinion found them to have scriou.slv
seri
adverse-consequences. The.letter continued— • ' • •-.-- - - -. •
•* * * Vife.have continued to gather data and to repvaUiate-aU available data
and technical judgments. While th^re are a number of scientific. i|Uc&gt;tii&gt;:i&gt; left
unanswered by available studios. I those fiuestions apparently \\uiiiil ;n&gt;f be
answered Iff additional, short-term investigations. On balance, wo continue to be
• confident tjiat the controlled use of jherbicUU-s will have no long-term tvola^u-ul
• impacts inimical to the ix&gt;ople and interests of South Vietnam.
Before we started the herbicide program in Vietnam, we siwnt a year studying
the effects I of. herbicides on experimental plots in South Vietnam. \\V hud ai.-&gt;
compiled n botanical survey of South Vietnam, a copy of which is attached. On
several occasions we have sent scientists, both from DOO and the IVi&gt;:ir;tiient
of Agriculture, to South Vietnam, to search for evidence of adverse ecological
change. 'Tlie Department of State and AID hnve also made evaluative surveys
utilizing consultants from universities, the Department of Ai:ricuUiin&gt;, and
the U.S. Forest Service. To date, ail of the reports of these surveys indicate no
evidence of serious adverse ecological effects.
. Systematic scientific investigation in combat zones is virtually imixis-ible.
Substantial military protection I i required to secure an area for meaningful study.
Therefore we have devoted effort to studies' of analogous areas. \\V .-upporfed the
Department of Agriculture in a fi-year study of herbicides in areas nf Puerto llieo
and Texas which are similar to areas of South Vietnam; a copy of the ivixn-t on
those Investigations is also attached.
Wo have boneliltod from the-experience of others. For example, ur.-onica!
herbicides have been used extensively in nibbor and oil-palm plantations In
Malaysia for over 20 years nt application rates 5 to i&gt; time* in i«xivs.s of timse
used In South Vietnam, apparently without adverse eil'ects. The ar.-enical we
'have used,(dimethyl ursinio acid) I.s one of tin- least t«xic of herbicides to
mammals.
Wo are, -of course, continuing our Investigations and Mirvcyn. 1 believe we
have consistently taken n responsible and o|M'timinded approach to the herbieido program of the Department of !&gt;efenve. As SMMUI i\* iwaceful condition's
return to Vietnam, niul M.v.stomati'.' scientific Investigation becomes feasible, we
will support additional stud ION in nil ways that im« legal and proper.
'

�t Attempt at Herbicide Assessment
ion that seems relevant to the calls for an immediate
ly of the effects of repeated use of herbicides on the
logy was an assessment under State Department
Vietnamese
auspices in Saigon during'September IOCS. Apparently no single
vector was responsible for motivating this assessment; rather, it was . '
the culmination of a number of unrelated developments:
The request, by the, AAAS board of directors that brought in
the United Nations, as well as the Department of State;
The. fact that Dr. Fred IT. Tschirley of Oae U.S. Department of
Agriculture, at the request of the Department of State, had niado
ecological observations earlier in the year In some areas of Viet-..'
na?n where herbicides had been used;
_
_. • '
The fact that the AAAS board of directors was still in c'om" munication with the Department of Defense on the herbicide
issue;
•
'
. ' . •
The apparent concern of officials of tine Agency for Inter- '. national Development. (AID) over occasional instances of inadvertent damage to crops from military herbicide spraying.
operations;
. .
The drumfire of propaganda from Hanoi and Peking, charging
1
the use of "poisonous ' herbicides (which tiae Yietcong guerrillas
apparently accepted at face value) ; .
The possibility that "world public opinion" had been influenced
by Communist allegations that required contradiction from well- •
. documented sources:
• ••
•' "1
The possibility that South Vietnamese officials and public.re-. ;
""'qtiired some degree of formal reassurance.
.
. . •'.•';"•.."'""•','.!
Apparently, the herbicide program in Vietnam had been. subj
jected to repeated reviews and assessments within the official U.S. '..
ini-sion to Vietnam. A report by Elizabeth Pond .in the Christian
S'"'-'-nce Monitor, in late 1067, noted that in the spring of that year,
" Fallowing damage to rubber trees and to fruit trees, the military command reportedly ran a reassessment of its program and banned some • ' .
of the more volatile herbicides it had been iisuig and extended the .
radius of prohibited operation? around plantations." A more extensive
a.-.--:--^ment was in progress in December 19G7. According to the story .
from Miss Pond, "no one. in the mission questions the use of defoliants .
where military gains are clear cut and accompanying agricultural
looses are, minimal." However, there was nneasJmess "about the actual
practice of defoliation, about the. doctrine and guidelines under which
it i.s carried out." A subjective .indicator cited \Va.s t h a t "One American
••ifTiciul i;i II i Corps, the hardest hit of any of the corps by unintended
fallout, {rave the -judgment that virtually every Farmer in that, corps
knows of the defoliation program and disapproves of it." Accordingly,
there was an apparent need for "some workable rule, of thumb for
measuring potential military gain against potential economic, and . '
political loss." The economic officials, sho said, '"have asked recently '."•'"
for a technical study on tho potency and duration of effectiveness of
some of the chemicals used." In addition, the mission oflicials—
* * • would likf&gt; to run « cheek on the guidelines ttfvf In use on defoliation
operations. They would like to reconsider the permillcij margin of error, the ad-

ju«tmpnt to changed conditions due to time lags between conceptio:
of operations, and duration of authorization—-currently 1 year.
They would like to find out how much the danger of low-alti
the other delicate controls needed in mixed forest-cropland a

execution
»
ug affects

The more extensive.'assessment by the Department of State that
took place during, 1968, under the sponsorship of Ambassador ELs.worth Bunker, was reported in Saigon by the U.S. niiikion, September
J18; the text of the basic press release was as follows;
.

In keeping with tho U.S. mission's policy of continually monitoring the U.S.
jrole In Allied herbicide operations iix South Vietnam, Ambassador Ellsworth
Bunker established a special interagency committee earlier 'this year to make a
comprehensive review of the program. The herbicide program, which is under
the overall direction, of the GVX and supportf.-d by U.S. military and civilian elements, has been an integral part of the allied military effort. The committee's
tusk was to asses.s'the military benefits of the program in relation to its economic
costs arid to shidy its effects upon tho ecology of the country. The review indicated that in. general herbicide operations in Vietnam have been accomplished
without significant damage to the ecology of the country and that the military .
benefits in terms of lives saved and other factors have far outweighed certain
known adverse economic effects. The committee, however, recommended certain
steps to reduce some of the economic costs as noted below.
Assisting the committee were a number of scientific and technical experts,
pome of whom were brought from the United States for this study. Among them
was Dr. Fred H. Tschirley, an authority on tropical ecology who is with the U.S.
Department of Agriculture. He conducted a separate investigation of the ecological consequences (Jf the defoliation in Vietnam. The full.text of this study
is attached to this press release.
• '
According to the findings of the committee, the use of herbicides around base
perimeters, along lines of communication, and against enemy infiltration routes,
staging and base areas has, both in terms of offensive and defensive action., reduced the number of men and amount Of equipment required for combat mission.*.
•.secured..material and facilities, and, most.importantly, helped .to save.the,lives.
.of many Vietnamese and Allied personnel.
. • .
-- '
.
' •
The military benefits of the use of herbicides against enemy food sources ia
food-scarce highland areas.in I, II. Ill corps, tho only areas where such o;&gt;er::tions are conducted, was more difficult to assess. There was, however, considerable evidence that food shortages for which herbicide operations were partly
responsible, have created logistical problems for the enemy by causing him" to
divert h u m n n and other resources to noncombat activities.
Kfonomic costs were found to be sizable. The principal cost was in lost or
j damaged timber reserves and merchantable timber, particularly in war s-.nno P
[ where security conditions have not permitted salvage efforts. There were other,
'. minor economic losses for accideutal damage to various crops due to spray or
! vapor drift, equipment failure, and emergency jettisoning of herbicides. "The
.committee cutisideivd it within the capability of the GV\ and tho USd, however.
; to reduce and eliminate some of the economic costs of the program, prin«.-ii&lt;aliy
'through salvage operations and reforestation.
i Tims, In weighing the overall costs, problems, and unknowns of the herbicide
'programs against the benefits, the committee concluded that the latter outweigh
the former and that the programs should be continued,
(Also available for information to interested correspondent* are copies of
wveral other papers prepared for the committee on a mimlier of technical subjects, including spray drift, the toxieity of herlUeliles used In Vietnam, urn! the
persistence of herbicides In soil and water.)' -

Query Response

.

.

....If asked about implementation of Tachirley's recommendations and/or other
information concerning program controls and execution, we would respond, as Is
necessary and appropriate t h a t : (a) Yes, controls and methods of execution of
herbicide programs were reviewed ; (6) Xo repeat no deficiencies were found that
.
&lt;Dec. 27,

rnnil. "V.S, Oillelals Review Vlut Defoliation." Christian Science Monitor.
'

�.(rf) Details
involve seeuri

ng controls and tlie implementation of herbicide, programs
rmution mill tantiot be discussed.

Accompanying tlie ofiicial 'press release at the Saigon briefing were a
• number of papers that liad been prepared earlier. Three of jt|he.ge were
unclassified. One. was a detailed report by Dr. Tschirley—"An Assessment of Ecological Consequences of tlie Defoliation Program in Vietnam," duted'April 12. l!)GS.10li The other two, both by T&gt;r..C. E. Minn,rik, director of the plant science laboratory and Dr. K. A. I&gt;;irrow,
Chief of the Plant Physiology Division, Department of the Arinv,
Fort Detrick, Mel., -\verc: "Toxicity of Herbicides in Use'in IIVX,"
dated April 3, and "persistence of Herbicides in Soil and Water,"
dated April C.
The, Tschirley paper enumerated the scope of his investigation as
follows:
'
'.
. .
•'
.
The mangrove vocational complex was viewed from a helicopter overflight of
the-Rung Sat Special /.one fRSSZ) on March 18, IOCS. Defoliation of-the mangrove in the B.SSX was started in IMG, but most of the defoliation flights were
iii.ido after June 1007. A mangrove area on the Ong Doc River that hsul boon
sprayed in 1002 was viewed from a C-123 overflight on April 7, 100S.
Scmidfciduous forest in war zones C and D were surveyed from a C-123 on
Marcli 23, 100S. A more detailed aerial survey was made on March 27, 10«J8 from
a high-wing Porter aircraft. Helicopter flights were also made over many of the
same arc-as, and some now areas, in the course of being transported to and from
specific areas that were surveyed on the ground.
Ground surveys weru made from Special Forces camps located at Thien Xgon,
Kamni, Tong Is Chom, and Bn L&gt;op from March 2f) to April 1. IOCS, inclusive.
Several hours were spent in the fore,&lt;;t at each local ion, to assess &lt;ie foliation,.
ivfoliiition, sueccssionril patterns, and to get a feel for the possible effect.-; of the •
defoliation on wildlife. In addition to the personal observations, nien at the camps
•were, questioned regarding the effect of defoliation on their operation, their irnpri-ssions about the. relative difficulty of human movement in the forest (a roughmeasure of the density and composition of the ground story vegetation), and
M.shlinss tlioy had mitdo of wildlife.
.
•
Aerial and ground surveys were concentrated in war zones C and D twcause
l.irgn' areas have been sprayed with defoliant in those- zones. Portions of C and
P zones have been sprayed 2 and 3 times. There are no,other areas in Vietnam
where such large, blocks have been treated or that have been treated so intensively
'an exception to that statement: would be the DM/). Thus, tho ecological eonsequences of the defoliation program would bo expected to he most evident and
!i:'»st easily defined in those areas. War zones O and D were also acco.islhle for
neris&lt;i survey.* and tho location of Special Forces camps afforded the opportunity
nt elose observation from t h o ground.
'
- . A concluding introductory remark is necessary, This report can in no sense lie
considered a complete, authoritative assessment of tho ecologio effects resulting
from defoliation of forest canopy. The conclusions readied are judgments based
*~,n prior experience and the 7iecessari!y few observations that were poss'lile. in
an area of war activity within the time frame demanded.
'"• Substantial)? fills unint- par&gt;«T npponrnil umlcr tin- tltlo "nofnllntlon In VMnnm," '
SH»nri« (vol. lO.'J. Fcii. 21, Ififi!)). pp. 770-TSO. ,\n I m p o r t n n t a i l i l l l l d n to (.lie Science'
nrtii-le, not Inclinlc'l with tlif pnpi-r r"lf;iK«'il In .Siil^'nn, WIIH a &lt;;ondu&lt;1inj* Kcolinn of
M &gt;
r» o*&gt;innji'n(Jji11f&gt;n'*" -whlrli rnnil:
.
- " ( 1 ) Tli" (Ic.-irnMlity nt &lt;"-&lt;i)n«lc rcscnrch In V l f t n n m n f t c r tlio wnr cndu' onnnot hn
ovr'f(»inj&gt;hrt i -iroij. Tiin r*"&lt;cnr«'li vhoiiM IM- iKlmlulHtnr/ 1 '! t l i r n t i1y h nn i t w t l h i t l o n t h ^ t t will
futivMr r n n t t i i i i l l y ntiil briMiltli for the r^^'virch prnKrnm. Tin oppordinlty of p H t n M l x h l n j :
ocolnclo. ri-nrnn li iui'li&gt;r f l i p f n t p r n n t l ' i i i n l Ill'ilnclcnl I'mtstnm K l u m l i l lif&gt; i&gt;xplor&lt;'&lt;!.
"(2) Ci.ritlnnitiit nssi'HMni'iit «f (!»• ili-fnllntlmi program nt It nffi'i'lH fori'Htry nrul wntcr'h'-tl v.iliirK vlioiilil do mnili: Cirnuwt oKxi-mitlmiH nri&gt; lin«f (Ic.ilril!&gt;]'', h u t ncrlnl "llrvcyn
during various nfusnua ol the ycur will c n i i t r l b u t o much Knod l i t f u r i n n l l o u " (p, 7Kri).

A. Climatic cffcctx

.

.

^^^V

Alleged effects of defoliation on climate assessed as follows: preeipituiiun. no
effect; ground twiU'Orature. increa.-cd ; wind .-•[let.-d at ground level, higher. Swttinary : no great effect on higher plants and animals; "might temporarily ai'ft-cv
lower life forms more dependent on specific microcliuiatic niche.s for growth iitn!
.survival" (pp. -11-42).
'Ji. KffcrtH

mi x&amp;lU

Kxpresscd fears of laterization (conver.sion of soli to hardened,- infertile form)
assessed as follows: only about 30 percent of Vietnamese soils satisfy the condition forlaterization. "I'nrter natural conditions Jaterix.ation is a long-UTii; pro-os.
The process is speeded up when soil is exposed to direct solar radiation and wind.
• I do not find it, reasonable that the. defoliation program in Vietnam would hastenthe laterization process significantly because bare soil docs not result from
defoliation" (p. 44).
Possibility of soil erosion : information insufficient for assessment (p. 44).
• Possibility of destruction of soil microorganisms: "* * * should have no detrimental effect" (p. 45). ' •
•
•.
•
C, Effects on plant and animal populations
(1) Mangrove forcat '
Trees wore killed: "20 years is a conservative estimate of the time 'needed for
this forest to return to its original condition" (pp. 40—17).
."There has been a steadily incnvasing fish catch." [This .-•ncrge.sf.s that in mangrove areas] the acjujtic food chain has not been. seriously disturbed'' (p. 4S&gt;.
"It is reasonable to assume that there has been some reduction in bird nvj.ulation" [but proportionately loss than tho ratio of area treated to total area]
(p. 40).
"Kffects on other forms of animal life are unlaiown. but surely the popi Ration
of invertebrates jn particular has been reduced." [Hut wot 'to the ' point of
'
'
"• -

(2), Semidccl'iluoua forest
.
'
- •
'
'
Actual area treated is S.140 square kilometers, plus 4€rt square kilometers of
mangrove forest: this is 10.2 percent of total forest area. Of this, about 10 percent
'was treated 2 or 3 times. Area studied had been retreated mn-it intensively.
[However, this was the dry season, and "there could not have been :\ wor*e time
to assess the ecologic impact" on semideciduous forests.] For single treatir.cnr.
no "great or lasting effect" was found, but multiple treatment would liavo •'.•» far
'greater effect," '[There is little knowledge about relative susceptibility &lt;-l' tf&gt;rvfi
species in Vietnam to herbicides, or about natural regeneration in tropical
.forests.] (Pp. -10-.-.3.)
:
"The greatest danger resulting from repeated defoliation treatments in Vietnam
is that such areas \viil be invaded by bamboo" (p. rifi).
"Tho greater the number of lierbicid.'il treatments the greater the harm to
animal populations" (p. &amp;S).

Tho report on herbicide toxirity repeated the fitulitip* rollcvted by.
the Mill report respect in&lt;r 2,4-1) and 2. t,'&gt;-T. It found "no syneririi-tic
toxicities" in animals as a result of iisim;- these- mixtures. However, tineffect of "orange" (a combination of these two herbicides) nii«rht be
fatal to fish under some conditions, although."there have l&gt;ven no ivports of fish k i l l attributed to herbicides." With respect to
acid, it was "currently boiiiff employed at a vute no hifjhor than O.."/
pounds per acre, [and accordingly] it is safe to assume that there will
bo no harm to man or animals at tlie.-e use rates. Tlie hijrh tolerance of
rats, other laboratory animals nnd tish to this herbicide pla&lt;'«» it in a
safer category than h'erbicideoran^e. With respect to pu'lonuu "white"

�4 was not to b^Mhssidered toxic or hazarctous to luunans, animals or .
&gt;f--h at the use ^^^ieing employed in Vietnam."
-;| The- report c^PR-bicide persistence in soils and water identified
jleloram as the most persistent. However; "In Puerto Rico tests, the
|iKmnt of chemical remaining 6 to 12 months after direct application
--.'•vji the soil of picloram in amounts four to six times greater thantlsat
* VD L.UHUI iiii. vi ui uciui t&gt;uv;ui m^ icoio uii r&gt;uno AI VMII ^» v AW » ii

jjrovinccs taken from'1966 to 19G7 defoliation targets, no persistence
;:|f herbicide, was found 11 to 17 months after single and double applications of white." Agent orange was not persistent in soil, and the
-.;-J!t-'mk"\ls "disappear in 1 -to 3 months at the rates of application
"fj.-ed in I?VX." Agent blue was "rapidly absorbed and inactivated in
'I'ils" so that "susceptible crops can be planted directly in soils witliin
' fevr days after application of eacotlylic acid at rates greater than the
gallons per acre, used in 11VX."
The. reception among '''concerned" U.S. scientists of the data released
t Saigon by Ambassador Ellsworth Bunker's interagency committee
•as not well documented. Dr. Barry Commoner called it "pretty bad."
. The conclusion I reach [Commoner is quoted P.S saying] Ss that the people
.isho distribute the defoliants don't know what they are doing. If the. evidence
s
;'.s gathorc-d from, the air the damage must he-pretty had.107
The interagency study received comparatively little mention at tlic
&gt; A AS meeting in Dallas, toward the end of the year. In particulai*,
':l|&gt;-. PfeifYer, who had been insistently calling-for a field study in
•|'ietnam of ecological effects of herbicide use, appeared not to regard
ft';---; Bunker assessment as meeting Ms requirements.
' •. •
yj ~f&gt; tied Nation* A ctiorm After A ppeal from A A AS
- ' '.
| Two actions with possible relevance to the AAA.S request did occur
. | . thf. United Nations in the fall of 19G8. One was the adoption \vith:
'I'.it objection by the General Assembly of a resolution that proposed
Jo convene in 197-2 a United Nations Conference"on Human Environ,;|;ent. In advance of the conference, the Secretary General was called
4.-1 to submit, a report concerning—

I1

.-1
(a) The nature, scope, and progress of work at present being done In the
if field of h n r n n u environment;
,;i
( f t ) The main probU-ms facing developed and developing oountrios it* this
»|
area, which mi^ht with particular advantage be considered at such n con•j|
ferewcc, Including the possibilities for inerwxsetl intornational cooperation,
,ls
especially as they relate to economic andjsQcial development, in particular
-j
of the developing countries;
' •J|
(c) rosslble methods of preparing for the Conference and the time ueces•'-| fiary for such preparations;
(rf) A possible time ntul piuce for the Conference;
(n) The range of financial Implications for the United Nations of the
holding of the Conference.""
M
"It's still 'no* on AAAS ttfortu to luunfih Vietnam ecological murvny;"'Scientific
&gt;*ffireh (Oct. H. lOHSl. p. 10.
'•'" Gcnornl A«»"'mlily Hi-Kulutlnno, Z.'tn! ri'vrulnr sdsHlon. Resolution niloptfxl 2.W.S (XXltl),
''"•r. ?,, 1IK1S. n.'i.lnl plenary mi'^tlni*. In coinmcnt nn tliU nrtlon, Sciuttor Milsklo, Apr. 3,
:• i-!nrc.-l Hint "Thi&gt; nntloiiK »f tin- worlil must. ilvv^Iop coolrmlrul t'onscli-ni'i'a, nn nw«r»-npsa
:i:tf WP KTf nil n part of ,1 tiltiKlt ooosyntcm iltsvclopcil OVi-r con« of tlmi&gt;. Our nltcmllon
f lliat tfiroHystcm [iiitti n lu-nvy rcsponslltltlty on »n:i» to nuinn^fr f h c n n u l l t y of tin* environ*
in-lit to nsstiro his own unrvlvivl nml tlio survival of tlioso otlii-r spocliiH cKHoattul to lEfc on
.irth." II- oSiTi-iJ n ri'xolutloh (S. Iloa, 170) t h u t the United K t n t c B Blionlil artlvi-ly Hut&gt;l&lt;ort
ni! pftrtlM|iiit« In Kiich n ronfeti'licc-aiKl assist in HH formation. (ConBrcKKlonnl Itrcord.
'.pr. 3. lOHa, pp. S:«30-S3531.)'

Tlio other TJ.N. action was an Assembly resolution that, •onion'.; other
things, called upon the Secretary General to "prepar^B^icise. Report * * * based on accessible material and' prepared v^^^Bu £i.-?istarid'
anco of qualified consultant experts" concerning "vari
"pects of
position _ „ ____ ____ . . ..
warfare, including herbicides, hud been de=-;ci-i)K;d to -the U.X.
Assembly, December 5, l%f&gt;, by.San'iuel M.. Xubrit.'U.S. A nibaHHador to
the United Nations. He said"the U.S. dclugsition would support, the
U.N. endorsement "of the Geneva protocol of 102"). As uncler.-.rood by
the United States, the Geneva protocol of 1025, he said, "prohibits
the use in war of asphyxiating and poisonous gas and other similar
gases and liquids with equally -deadly eil'ects." However, "* * * the
protocol does not apply to herbicides,' which involve the same chemicals and have the same eil'ects as those used domostica'lly in the United
States, the Soviet Union and many other countries to control weeds
.and other unwanted vegetation." uo
The AAAS Board of Directors invited to its October meeting, for
the discussion of the herbicide issue a number of persons involved in
this issue in or for the Department of 'Defense.111 At this meeting, a
public symposium &gt;vas planned for the annual meeting of the a.^ociation, to air views on the MRI report, the Tschirlev report in Saigon,
and other aspects. Dr. Pfeiil'er, who had apparently not been. ~ati&gt;f;t-d
with either the MKI report or the. subsequent Tseh'irley nvestigatinn.
a few days after the board meeting, oll'cred to the Committee on Coun'
cil Affairs a resolution that- the. council ask the committee ou.i'nvh-oii,mental alteration to appoint a subcommittee to conduct the. field study
called for in the board resolution adopted the previous J une.
Renewed AAAS Appeal for Field Ecological In-i-e tf
When the AAAS membership convened at Dallas, at the close of
' IOCS, the status of the controversy over military use of herbicide.-? in
Vietnam was as follows :
Tho Department of Defense had released considerable technical information assertedly relevant to its conclusion that no "seriouslv adverse consequences" resulted from military herbicide usage; and had
given assurance that the assessment program was continuing.
The AAAS board of directors had urged specific reductions in the
program, and had not revised this recommendation upon receipt of
DOD information.
.
i" Gfiifnil 'ASKomlilv HcsoluUons. 2.1r&lt;) rcpilar session, Resolution Adopted
24. r i-t-.\(XXlin. t&gt;cc. ^0&gt;, lOC.S, 1750th plenary inc-etinjr.
no Representative Robert Kn&amp;tenwi'li'r, Sept. It, IP.V.*, liail pruposeil n rc-xolutlnn (U.Cnn.
Res. -lail) that wmilil renlllrm the "lon^stiHiilhii: pulley of the Vnitisl stnt«.s Uiat In th»
event of wnr the United Ktiitex Hhull under no rlrrunistwnecu resort to the u-"- of h'.nlc'glcal
-weapons or the nse of poisonous or (noxious) t'lt-^'-'s unities they are I'r^t usisl by" our
pnemleK," Both the Department* of Ktute nml ivfense opp«»i'd pnnRnw nf this renoluttoti.
However, 8tnte'» opposition was based on tlie propusltUm t h a t It was r m l u n d n n t h'H^iu-'e
the U n i t e d StiHon WUH already romtitlttol to n-fnilu from t hi e use of fonv of any kind
In a niniiner contrary to the charter of the fnlti-d Rations. I)i parti«fiit of ivfi'ti".- oppi&gt;&gt;l*
tlon WIIB Also bused on (he f u r t h e r conslderiilion tlmt other coimtrli-s were nctlvely smrmilii); programs In thin Held, nnd the propo-od ri-solnilon would posslhly "lutnxliji-e uncertainty Into the neeessitry tiliinnlnt; of tin* Dejiurtrneiit of iN-fen^e In freparliij; to meet
ponslhle luiHtlle uetloti of all kinds."
"'Them' WiTe: Mi'SHrs. Rodnry NldiolR nnd A. K. Hnywnrd ttf the Office of the Piroetor
of Defenne ReseureU and Kngluecrlni; • find Dr». Mlnarlk and Tuelilrley.

�0-i

I AAAS liadJJ^unable to find a way to enlist the. resources of the
T'.X. iti the cd^^Bof an on-the-spot study; the study performed by
1i &gt;OD at the inlHIce. of the AAAS had been limited to the open litcra-| uro, and had'not involved the collection of onsite data; the State I)eJ v.u-tinc&gt;nt,'ri release of data in Saigon had not,quieted those who sought
l|f
jf'i'.sUo data.
.
. '
I Accordingly, in the annual meeting of the. AAAS Council, m Dc$v-.VH-r lOr.S.tho board of directors announced that the AAAS "would
|; .-..-* icipate in a study of the use of herbicides in Vietnam." An account
•'*;&gt;: t';! t « council's msponse to this announcement. carried in Science, was
s follows:"
. '
In a. heated meeting in an overheated room on Monday, the hoard's inclusion
;" Vii tnam in its original resolution was challenged by cotuieil members. TLe
stack was oix'iied by .Tunics U. Ross, representing the Xatun; Con.sorvancy, who
.\u that tin- hoard should concern itself with other environmental hazards and
$='..&gt;;;'.d not single out Vietnam. A resolution expressing the agreement of the
|e..-;r;.'-i! w i t h the sense of the board resolution to conduct a study of the use of
}!';•. •.•-!• ifides in Vietnam, but advising changes in the language of the board's orig..-Jir.:;! resolution so as to delete mention of Vietnam, was passed overwhelmingly.
$!:&gt; pussinij such a resolution, the council was taking' a iwsition similar' to that
.;|;^ .;.ted at rhelOCG AAAS meeting in Washington, D.C.
;-?| 'in accordance with this advice from the council, the board revised its resolu:
?.i i\&lt;--n to read as follows :
1 •it is the sense of the board tbat the association, looking not only to tlje effects
r.hc wartime use of herbicides, but also to tho .opportunities for the peacetime
&lt;&gt;::struetion of the agriculture and economy of Effected areas :
'(1) Determines that 1 1 .-•!• ill be1 a purpose of the association to bring into
';•• field study of the potential long- and short-tomn
rig the mo-t effective p '
•
• "' .
•'•.•jfical risks nnrllionefir.- • . ' h " areas affected;
" i 2 i . Sjvcilically directs t i •• AAAS staff to convene, as soon as possible, an-SMl1'
•• pv.u;&gt; involving rf-pre .-creation of interested national and •international
organization.-! to prr-pure specific plans for conduct of such a field study
r.d with t!ic exiK-&lt;;tuHon that the AAAS would participate in such 'a study within
.-.• rvjsoiiabU- limits o f i t s resources." "2 •
.
. • . . ' • .

The article went on to note that "At the Dallas meeting of the AAAS,
.. V,'. Pfcifi'or of the University of Montana introduced, before the

Yhv-re were also papers on tho possible ecological consequences of the
;:-&lt;i of herbicides in Vietnam presented at si meeting sponsored
i'Miitly by the AAAS Committee on Science in tho Promotion of
FFmntin Welfare and the Scientists' Institute for Public Information.
• The technical papers before the joint meeting were presented by
Dr. Tschirlcy, "Dr. P.ovsie K. Day, professor of plant physiology and
:iH.-.ociato director of the experiment station, University of California
f Riverside), Professor Galston, and a panel discussion with questions
from i\-.f: Hoor.
.
'
.
Dr. T.-&lt;-h iriey, in his prepared statement, covered essentially the
:-:i7ne. matt-rial a:-; in his Saigon report. T)r. Day stressed TT.S. domestic'
experience, with herbicides—noting that some 100,000 ^rganic comlounds were synthesized and tested annually as herbicides, 125 were'
bicing marketed, and about 50 we.ro in quite "extensive use. There was
I'T.rycp Ni'l-ion. "ITorhlrl.Ji-a -In Vietnam : AAAS Board Seeks VIM
(Vol. lfi:i,.Jfon. ,1, 1000), p. K.H.
'
.
,

Study," Science

..•,.:.:, A.^

no relation between herbicidal effect and mammalian t^^ity. The
hazards to vegetation included "failure of selectivity/i^^^nges rh
climate, soil, rainfall," and "migration of the herbicfdcJBHprikT.site."
In the United States, he said, tiie use of herbicides was •unduly regulated." _The primary discoverer of a herbicide develops toxicity information, develops use information, and supplies this i n f o r m a t i o n to,
an agency of the Government in support of a request; for registration.
Tho label, in this trade, he said, was "a sort of a holy document/' To
obtain the label involved some'$:&gt; million of laboratory and Jit-Id research and up to $G, -$8, $10 million i n ' f u r t h e r development. (The.
implication of this presentation was that before herbicides found
their way into military service, they had received an abundance of
testing so that their properties were rather precisely known.)
The presentation-.by Professor Galston took tlie opposite position.
He acknowledged that 'plant regulating chemicals 1md been a "really
brilliant' contribution." However, the "use of any chemical additive
carries with it certain dangers." While peacetime society "has safeguards of such use," he warned that "Under military and especially
under wartime conditions these restraints can he an autocatalyti'c
process leading to still further transgressions and that it is in this area
in which a signal lack of restraints currently bedevils us. and alarms
some of us.".He wjis critical of the "bland reassurances" of Defense
scientists as to the nontoxicity of military herbicides, and declared that
in view 'of the "great stability*' of picloram, its use presented a real
hazard of long-term damage to the ecology. "I suspect that great
•damage will have been done," he said. lie voiced again his earlier
apprehensions concerning danger to microorganisms in the foil, latent*
scat ion, and massive erosion from monsoonal rains. Then he warned:
"We are continually investigating new chemicals for military use.***"
Moreover, "The restraints in this area and the rules governing the
introduction of new weapons into warfare constitute a very great
danger for all of us." The initiating action, under combnt conditions,
is taken by a military oflicer. There is a clearance procedure, he conceded, but it was not as'precise and absolute as with the "big bang
weapons." Then he concluded:
I believe that, we have restraints built into our warfare situation n
the bifj bang weapons. We know that, nobody may use any nuclear device in warfare unless the President of the t'nited States authorizes the pressing of that
button. With regard to the chemical agents, the restraints seem much looser and
it seems to me that . practices that are being conducted in the name of thf
American people in Vietnam in the way of killing vegetation at the moment
have not been subjected to the same kind of searching and restrainiuir curiosity
that r personally would like to see. What about the new wcai&gt;ons that are under
development now? Who is going to exert control over the use of those? If. for
example, a decision Is made to kill rice, which feeds [validations, as a weai«&gt;n of
war, why, then, report to the use of chemicals which have to be sprayed by airplane time after time with the (lunger to the pilots » * ». Why not use an
organism to do thisV
•
'

- Tho panel discussion highlighted some of the dillicuitie.-; the
entists were encountering in achieving a coiir-viisus in tho «*-i»«"&lt;mont
of herbicides in Vietnam. A condensed sampling of the- dii-vussion is
us follows:
Dr. Commoner: Expnwod concern over u n a n t i c m n t o ' t biological
hazards. Were there anv? Were they anticipated? What steps, were

�taken to sco t!
were anticipated? What was the relation between
this report p
port) and their military use ?
Dr. Day:
ow a great deal about, herbicides. Piclorant &lt;does
break down
soil. There-i_ - been some 10.000 pupcrs p t 1 •
have
dealing
n * ir\ ___!.:
c.
AI - LL.,
.
.
with the, effects of 2,4-D, which comes from the "stone age of faerbicides." •
•
• ' I'll''
'
'
Dr. Margaret Mead: "We are, talk-ing about a variant of the "scorched
earth policy." Today, there is a "new ethics"—it is a now thfrag to
worry about the weliarc of an enemy. We arc beginning to realize that
we are living on a planet—"a total system." Yet, we. have a'tendency:
to-worry about smii-1 i?sues.
"'
'
• .
Dr. Day: ';I admit that the world is run on incomplete knowledge.'*
The MKI report gave little coverage of much of the practical literature. "The thing was prepared in GO days by people who know not/lung
about herbicides."
Dr. Commoner: "The public revelations about this problem havebeen characterized by * * * quick and poorly conceived responses
to jabs of criticism made by concerned scientists." He referred to
Dr. Tschirley's survey as a "30 day quickie look in the dry season/''
What was needed, he said, was a "long-term continued investigation."'
Dr. Tsehirle.y: Was in agreement, but who would pay for it? Could
it be made a part- of the activity under the international biological
program: Jrie com l:.-ined that the "ecosystem approach" had fit* been
clone; there was •&gt;' much communication between ecologists and
other scientists. T; re was a need to get together with tho people- who
work with pest!••• •-. There was a great deal known about these, in the
United States. W '.ould admit we need.more ecological information,-.,
But vre can mak:/ ;ter use of what we already know. We know, very
lir;.!--about ecosyst. us in any sense.
•
-.
'• •
Dr. Galstori:*]*: ;-:«! a question about the metabolism of cacodylic .
i:c:d. and the availability of information about it.
Dr. Day: There was "so much arsenic lying around in nature that
r',3 very difficult to sort out the little bit that Ave're putting into the
s-.'.-.tem." The effect-of arsenic deriving from cucodylic acid applications, he said, was "trivial." Agricultural applications of arsewicals
amount to as much as 400 to 800 pounds per acre, whereas cacodylic
cieid provided only something like 1 or 2 pounds per acre.
Dr. Hoi ton: Expressed concern over the use of an incomplete body
of scientific knowledge as the basis for action. He stressed the limitations of the scientific support for policymaking. Nevertheless, he roc••v_rni2e.'l, policymakers have to act. Their decisions, though, should not'
v
--i made dependent on limited scientific knowledge—scientists should
::i-/fc bo made- responsible for political decisions taken on the basis of
such insufficient knowledge.
Apparent Reduction in AAA8 G'oncarn Over IIfMidden in JOG-9
One action in response to the, new council resolution was tnloen bv
Walter Orr Rolxirts, who had retired us AAAS president, to Ixeoomc
Hiuirman of the board of directors at the close of IOCS. Ho \vrot«&gt; tho
^vwtary of State, January 10,^1900, on behalf of tho Assonatum ''to
request your assisianco in making certain that, as soon as conditions
permit there will be undertaken a comprehensive study of the eco-

logical effects of th&amp; use of herbicides in Vietnam." Dr. Roberts expressed the Board's gratification that the State Deps^Bfclat/hac}
"adopted the recommendations of your consultant, J|^Mchirley
regarding the need for ecological research to be ctirrisWPat," and
said: "We also understand that there_is, from your Department.
a recommendation for the adoption, prior to the cessation of combat, of a policy of defoliation in strips as opposed to big area defoliation." Finally, he ofl'ered the support and assistance- of AAAS in
preparing for the recommended postwar assessment:
I am sure [ho concluded1] that our board and'our council will enthusiastically
support those stops to control the use of defoliants in Vietnam, and to assess the
long-term ecological consequences of. the defoliant usage of the past. Thy AAAS
will be very Imppy to help in any way that we can. As scientists and citiz'.-rw, v.-n
sincerely hope that the steps approved by your Department and our Embassy in
- Vietnam will be put promptly Into effect. We will be very pleased to help to plan
or to organize an appropriate ecological study that can be conducted in the field .
after, very hopefully, tho hostilities cease.10

By the end of June 1909, it appeared that the AAAS had virtually
exhausted its initiatives. The association had'obtained assurances from
the Department of Defense that herbicide usage would be continually
assessed. A general policy had also been established that there should
be no long-range and seriously adverse consequences of such usage.
.Both tho Departments of State'and Defense had promised support for
a postwar ecological investigation of long-range consequences of the
military use of Herbicides in Vietnam. The United Nations had agreed
'to sponsor a full-scale international meeting of world scientists on
•environmental quality. The issue of chemical and biological warfare
had been referred by the General Assembly to the iSth National Dis-:
armament Conference in Geneva for consideration as a part of irs per-"
manent. agenda. Technical cautions had been expressed by the AAAS
board concerning the treatment of large areas or blocks of territory;
.the issues of bibdegradability, toxidty, heavy application, and repeated application had been made publicly visible.
On tho other hand, the operational role of the AAAS in making
-ready for long-sought postwar assessment had not yet been defined.
Although pledging its support and assistance, the board and council
had taken no steps to mobilize AAAS resources for this purpose. A
substantial membership roster had been recruited for the new AAAS
Committee on Environmental Alteration, but the staff of AAAS
Jiavo made, clear that it was not expected to spearhead the Ouort. 1 '- 4
« 5 l n oommntit on tlic olrcumstancoa loaillnp up to the pnn&gt;.irat!f&gt;n of Wnltf-r Roberts
letter, DMO! Wfilfte notM that "Uls&lt;'.\i*»lon« Hobi'ctH had with I"''1!'1"-' in ODDK.'iT: in tl:«
Itiiinciliutcly followlne [the I(i):&gt;rtl nif'tliitf of Doci'mher 1V01*! IM! him to

Thcoiiorp"C. &gt; "ltyoriy", Ailiiiliilstriit'or.'Oooiu'riitivi? Stnh&gt; U'^caroh Scrvii*, I'.S. IVoi_i.iftmi'nt
of Acrli'iiltiiri-:. Dr. John K. &lt;. 1 untl.&gt;n, I'rof.-ssor of Kc««lnK.v. &gt;Ii(rhl ; rau Suite

fiinrmncoiuKy. t;onii'il umvi'ruiiy i-inii'co or -Mcuiruic; IT. ^nuiii .•;. ...i....&lt;..., ..•,.
of Chi'iiili-nl Ki)«ln(MTlii(f, City ColU-fie of the City. Uolvcrulty of &gt;ew iotk ; Or.

'{

�"here was available no indication that its future program would
hide the. d^ign^B^fcologieal survey of herbicide efleets in Viets'l, or eveii'the d^^^Htnent of criteria that such a survey would need
jarisfy. It reniaimiKo be seen whether its membership could pre.•ehoth stability of leadership and forward momentum.
n comment on the status of the'AAAS action on postwar exaralnai of the ebnsequeiu'es of herbicides use in Vietnam, Dael Wolfle has
Gained that at the board meeting in April 1009, there- had been no
ly to the letter from Dr. Roberts to the Secretary of State, but the .
ird chose, to wain a little longer. The State Department still had Jiot
lied by the rime of the June meeting, so the board felt it necessary to
irn to its December IOCS statement. Accordingly, the AAAS bourd,
lint time, began organizing a meeting of representatives of national
t international .-•.- ; entific organizations to begin planning the iwomnded field scudy. De. Wollie noted that both the State, Department
1 the Cilice of Defense Research, and Engineering were on record as
irnving the idea ol' a substantial field study. lie expressed the la ope
t the proposed AAAS sponsored meeting would get this study
ler way.115
.
'
Pfcijfer's Volunteer llcrliicide Asscsxm-eiit Expedition
l;e originator of the motion that had involved the AAAS ira the
bteide. controversy. Prof. _E. W. Pfeiffer, of the University of"
ntana.had persistently called, throughout subsequent developments,
an objective, authoritative, on-the-spot examination and analysis
;he ecological impacts of repeated application of herbicides milif purposes. lie had been frequently quoted with reference to the
vious attempts at assessment. The 'MRI study was a "snow job'5-; •
S:ugon assessment too general. In October 19GS, he still sougM a
:! study:
.
'here there's a will there's probably a way [lie was quoted as saying], !&lt;-anbi'licve t h a t there is that much fighting going on in the areas affectc.'-d by
)if:iflf.«. Sonic things could be learned and some knowledge is better tlutu no
ivledge, which is our situation now. Simply from conversations with South
n.'uaese biologists and French plantation owners on the scene, valuable Juforion could be obtained * * *. Already, some European scientists have liteeu,
North Vietnam, into the battle zones and have pictures of defoliation
:t^'-s

'he AAAS resolution in December lOfiS, calling for a "field sfauly
'lie potential long- and short-term ecological risks and benefits of
bio'idf- use r ' was attributed "to the dogged persistence of; A A A S
;ib»'T.s such as PfeilTer and of some, members of the boanU'" 7
Pfeiti'or had also been active, during 1908, in attempting io arouse
:ivst. in having a survey organized under the sponsorship of the
k-ty for Social Responsibility in Science (SSRS). In this effort
v;is supported by Franklin Miller, Jr., of Kenyon College, GamJbier,
:o, and vice president of the, society. Miller was reported as saying:
hen the war ends it will be of the utmost importance to restore (ho
d t i c t i v i f y of the land areas in the combat zones. It is an urgent task
r.-'ttf-r from Hr. r&gt;:ifl Wr.lfl* to U. A. Carpenter, July 10, SflflO. Op. fit,
"It's f t l ' t *n&lt;"&gt;' f-n A ^ A S «-lTortR (o Inuiu-Ji Vli'tn.ijrt f^olo^'l^jtl f»urvf.v." &lt;&gt;J&gt;. clt., p. 10.
»ry&lt;-c Nrlhori, "HiTblrlrti-H in Vietnam : A A A S l««ninl Sfi.'k.H Klclil Htndy," i&gt;v. clt.. g&gt;. f&gt;8.

gather the necessary information as a basis for sensible and prompt
;tion." Accordingly, his group was "* * * * seeking ways utfMLrlcli;
l revive interest,, in such an investigation." 1 " 1 Even before tl'^^^Bv.S
.
n
in December 19GS, Dr. Pfeiil'er had annotmced his
'
of conducting a reconnaissance survey in Vietnam under the auspices
of the SSIvS. According to a statement in the newsletter of the society.
"the trip should produce valuable information and may serve, as a pilot
project for a much larger investigation into this field long overdue
for scientifically trained observation." The plan' for the survey was
described as follows:
. ' '
.•'...
I. PUIU'OSKS

.

(a) To stimulate awareness nmons scientists of the need for :ui intensive and long-term study of the effects of military usi's of chemical agents in Vietnam.
(ti) To demonstrate the possibility of obtaining meaningful information even
with limited funds and personnel.
(c) To obtain from Vietnamese .scientists information related to the military
uses of chemicals in Vietnam.
(il) To obtain samples of foil, water, plant, and animal tissues from treated
areas for analyses to determine levels of contamination by different chemicals.
(c) To determine effects of defoliants and herbicides on anininl populations.
(/) To make a eijiematogrnphic record of areas in Vietnam that hiive been
treated by defoliants and herbicides..
• .
• •'
n. JLEIHODS
(a) Interviews with Vietnamese scientists and officials of such organizations
as the- National Committee for the Conservation of Xatnre in Vietnam,
(It) Examine hospital records vitli ix-ference to patients .suffering from exposure to war fjfises.
(&lt;;) Collect samples of soil, water, plant, and animal tissues frouj areas exposed
to chemicals... Analyze, these samples, at .'laboratories in the United States to
"
.......
'' '
.
; 'determine concentrations of chemicals.
- (&lt;?) Estimate' population of different mammalian species in chemically treated
areas and in ecological similar areas not treated b;* chemicals. Use standard
small mammal or bird population sampling technicuies.
(c) Make 3(i millimeter motion picture records of the areas in Vietnam that
have been treated with chemicals.1"

It was not evident that this ambitious plan of investigation was
feasible in ''a 15-day incursion into a region of actual combat, by
two zoologists, one specializing in the evolution of vertebrate social
systems and the, other interested mainly in the renal physiology of
mammals. lOven w i t h the assistance of the Department of Defense,
which enabled the two scientists to fly defoliation missions, hispoet
defoliated areas from gunboat and helicopter, and converse with
biologists in Saigon, their findings were necessarily largely based
on qualitative information and hearsay. Much of it was economic
information about damage being claimed by managers of rubber plantations.
Professor Pfeill'er, accompanied by Prof. G. II. Orians, o f _ t h e
department of zoolology, University of Washington, Seattle, visited
the Republic, of Vietnam, from March 17 to April 1, l!X'&gt;i&gt;. pursuant to
this plan. They flew defoliation missions, and observed the effects
lit "Ciiomtonl Hiirvcv !u V i e t n a m plumiuil by milvrrslty nnil i n d u s t r y scientists," Scientific
cwiiroli, A U K . r&gt;. lOHs., i&gt;. in.
"" .S.SKS Ni'W.sk'Uer, No. 1!)4, NovomhiT-lVci-mbcr IOCS, p. 1.

�.'in n

by river patrol boat in the Mekong Delta.

jj£ report, April G, they noted:

Crop
n programs had been reduced to about one-third ©f 10G7
level;
Defolint'
protective cover was being maintained at about its 10G7-CS level:
Agent white (pidoram and 2,-1-D) was being used much more, extensively
in the central highland than previously, because of its low volatility*;
Bird life in the ''Saigon Kiver Delta" had apparently been greatly rotduced ;
2\o adverse etTeet from toxioity against mammals was noted frouu agent
blue (caeodylie acid) ;
:f
Accidental, defoliation ''bad been very costly, and is a factor in the greatly
| reduced rubber production in Vietnam:"
.),
"We determined from conversations with U.S. AID experts that tlhe de;-3
foliation program is a potential threat to the forest industry of Soutlh Viet^
naia" such that multiple applications "may kill approximately 00 {percent
»i
of commercially valuable timber in defoliated'forests."
•JJ
'•* * * A great deal of accidental defoliation of fruit trees and vegetable
,-t,
gardens has occurred as the result of drifting of defoliant and from jeifctison»j
ing entire loads of defoliant because of aircraft engine failure;"
•i
The peculiarity of a guerrilla war, without battle lines.or secure territory
a
and fixed military targets, inherently results in an effort to increase ffiatali-|
ties, deny resources, and deprive cover to the adversary, which is destructive
1
of lives and ecological communities.""

\| In the press interview in Isew York upon his return, Professor
'pfeiffcr expanded somewhat on this report. He observed that lit was
;j'cornplctely unrealistic" to expect military commanders to abstain
Jirom defoliation actions. "There is no question about it," he' sa:id.
j-'fhey save American lives." On a 65-rmle journey by armed! iboat
Ji rom Saigon to the sea, he said, "We scarcely saw a living" plant." Mow|,:ver, he added that had the vegetation not been destroyed, he arad his
-'companion would probably not have returned alive,"-121.' • .-'
-.;

:. v;. Ffeiffer and G. H. Orlans. "The Ecological Ejects of the Vietnam \T,"ar: A
-;aciry lie-port." (Society for Social ItcsponsIbiUty lu Science, mimeo, Apr. 3. 3.000),
' -ii;*r Sullivan. "Zoologist, Back From Vietnam, Notes Defoliants' Value and; 'Toll."
/--.rk Times (Apr. 4, 1909), p. 5.
•
.
,
.. .'
. ..'.
:-

V. CONCLUSIONS AXD OB^.RVATIOXS
Initial, development of herbicides had been quickly r^^Bzcd in the
United States, after World War II, as having enoil^HJfavorable
consequences for agriculture. Although their developnWit had been
hastened as a part of the scientific effort supporting the war efforts,
and a number of new chemicals of unprecedented potency as herbicides resulted from this wartime program, herbicide.s had long l^en
used commercially in the United Si ates. The rapid adoption of the new
• chemicals into agricultural practice as weed killers was facilitated by
the. highly technological diameter of .U.S. 'agriculture generally.
Chemically defoliants were closelj*"compatible with farm practice nrul
yielded important economic gains through increased farm productivity.
Reassessment of the complex secondary and long range consequences
of wide-spread usage of commercial herbicides was intensified after
19G2, when the Carson book, "Silent Spring," dramatized the possibly
adverse effects of pesticide usage. As more information was accumulated about desirable and undesirable effects of the new chemicals,
tho initial-emotional response stimulated by the book was tempered
by a more objective realization that herbicides were both potentially
dangerous to the environment and important for human survival. It
became evident thijt active programs of scientific research were essential to discover as much as.possible about the "ecosystem'*' and the
effects of pesticides upon it. Only by this effort would it be possible
to maximize the benefits, and reduce the. injurious consequences of
the new potent agricultural chemicals. It also became evident that the
•science of 'ecology-was in-its infancy, that-an -interdisciplinary ap- .
.groach'was needed, and that the. various disciplines contributing to an'
. understanding of environmental factors were encountering difficultyin exchanging knowledge across disciplinary boundaries.
The initial decision to use herbicides in Vietnam was made by the
.-President of the United States at the request of the Republic of Vietnam. Development of the program took place concurrently with an
'enlargement of U.S. participation in the conflict. The program was
•dictated by military'advantage. Its primary purpose was to maintain
• road and canal trallic with a minimum expenditure of lives and manpower. Its undoubted effectiveness for this purpose lias motivated its
• continuation. The program was initiated despite early warnings that
adverse public opinion could be expected in response to such a new
military application of chemical technology. A positive effort has been
maintained by the military services, in cooperation with Republic of
Vietnam and United States civil authorities in Saigon and in the
.field, to counteract the adverse public reaction by the careful screen-ing of targets, restraint in the use of herbicide chemicals, arrangements to reimburse victims of inadvertent damage, and final approval
•of each proposed application at tho highest available level?. Tho. research emphasis in the initial stages of the program was on the development of herbicides that would 1m effective against the. kinds of
flora actually encountered in Vietnam. Kmphasis was «1so plaml on
tho nchie.vement of tin- speediest possible response—the swift defoliation of tho jungle after the application of a herbicide. However, alien-

�tioii was also given to the technology of application to luininuze inadverfentfspi^jug: of unintended targets and to 'assure that sprays
could be dii^^H|efliciently against their intended objectives, with
least waste. '•Hrghout the program, the question of toxicity &lt;of the
chemicals to man and animals was an important concern. Toxicity is
important because of tho implications for "chemical warfare" ;und the
claims of the, Vietcong that many persons had been noisoroed by
aerially sprayed herbicides. Although toxicity has always been difficult
to characterize, or measure with absolute precision, and particularly
with respect to long range effects of repeated exposures, there hasbeen much experience, in the United States with the measurement of
h-:-rbicidc toxicity for practical purposes of home and farm usts.
Assessment of the use of herbicides in Vietnam has proved more
complex and difficult than the assessment of the use of these same
materials in the United csates. One important complicating factor is
the 1 controversial nature of U.S. participation'in the hostilities. Anor! •:- is the question as to the propriety of chemicals as a part of the
t&lt;-•••:. P. ology employed in conflict—the possible, escalation that anight
result from it, and the general desirability of preserving'thresholds
f.-&gt; si;..-h escalation. A third complicating factor is the informal arad limited nature of the conflict itself: (1) a number of nations are giving
;••_;:•'•= ."t to the Republic of Vietnam, and a number of other natiorns are
..'.'. ", : '-ipport to the guerrillas and the organized forces of the Xorth
;•' : v.=e: (2) specific restraints have been decided upon arad dc.-_:.::\•-' 1 &gt;. effect, in the conduct of the hostilities; (3) a large psart of
t::e ;..•-;"ilities are conducted within the jurisdietional .limits, iif not
control, of the Republic of .Vietnam; (4) a very large part w&gt;'f the
r -•.-;. of herbicides,, along transportation, arteries, has both military.
:.avar.trigo to reduce the likelihood of ambush and the same gcp.neral
convenience that, motivates its use along right-of-way .in the TUnited
Stares.
' •
•
A fourth complicating factor'is the imposition of the restraints of
j :iitary security over thei flow of information about various aspects
o:" tho conflict, including the use and the cffects-of herbicides.
A series of protests arose among scientists in the United Stages as
r::-_herbicide, program in V i e t n a m expanded after 1902. The general
r i t i o n a l e for protests from this source was that since scientists had
&lt;•• n r r i b u f e d to the development of tho new technology of herbicides,
:! -y had a right to exercise some extent of moral or technical sassess!-;--.'-.i of tlu-ir use.
Ic. is indeterminate as to the. extent that this anxiety to assess was
'..•ucnsified by the disapproval of U.S. participation 'in the com diet.
However, the fact that annual spraying of herbicides in the, United
traces, since 1905, has maintained a level of some 120 million. ;acres
:-• ••_"_'p.sts t h a t the greater concvni over the more, intensive. UPC of siknilar
- • •h.u-iilosjigiiiri.st. 5 million acres in'Vietnam is motivated in part by
&lt; ••.-ilk-rations 1-f.yond that for ecological consequences.
*
A long aiTiiy of specific issues has been raised as questions associated
v.-irh military herbicide usage,:_ toxicity to man and animals;, synf-rgistic toxicity of several herbicides in combination, or in coidJmiatfori with oilier^environmental factors, or in interaction with tluc soil,
o:- oilier chemical compounds resulting from decomposition; con-

centration of herbicides along food chains, in surface'water, in
ground reservoirs, in water plants or organisms, in grojlh.'aU'r,
m the soil; effects of herbicides on timber crop, and rubl
or on food supply generally; losses of domesticated and
fish and birds; threatened extinction of rare species; genetic impairments of animals or plants; encroachment of unwanted species on
bared areas; mass destruction of sensitivo_ vegetation (e.g., mangrove)
requiring decades to recover ; and possibility of hiteri/atiou of exposed
jungle soils.
.
'
In an effort to distinguish military from civilian use. of herbicides
attention was drawn to .the asserted greater intensity and more frequent application of defoliants to achieve military objectives, the
moral issue of crop destruction, and the question as to the propriety of
using chemicals to expose enemy personnel to attack by conventional
weapons. The question was also raised as to the military ability to
exorcise due restraint in the type, amount, and 'frequency of herbicide
applications.
The annual meetings of the American Association for the Advancement of Science provided an opportunity for the scientific politicization of the issue. Once the council of the AAAS had adopted a resolution bearing somewhat on the relationship of herbicides to the human
environment, those concerned with the use of herbicides in Vietnam
continued to keep Jho question of this war use alive among the. membership and the leadership of the association. An attempt wn-&gt; made
to separate the thorny political question of military heroic-ides from
tho broader but less inflammatory technical issue of "environmental
alteration." However, when the board of directors of AAAS attempted
to develop a position on the military, herbicide is.sue, it- was able t o agreo substantially on only the one. proposition that the long-range
ecological eil'ects needed, study.1-- However, the board of directors
did not speak with a single voice, but with five. The e fleet of its dilVused
expression of views was doubtful. All parties were agreed as to the
desirability of learning more about the long-range ecological ollVcts of
intensive military use of herbicides. But the AAAS board of directors
had not assumed leadership in defining what form this assessment
should take. By June 19G'«), neither those who favored nor those who
opposed defoliants in Vietnam had given a clear indication as to what
'tho ecological questions were nor how the}' should be answered.
A number of observations can be made on the record of this assessment. process. One. is that a large federation of scientific soeiecies like
tho AAAS can provide a valuable forum in which to discuss issues of
great public moment. Tho annual meetings of tho AAAS bring together from nil over the United States scientific specialists from many
disciplines. An opportunity is provided for those in each individual
discipline to exchange knowledge, and also for the valuable crossfertilization of interdisciplinary discussions. Issues that rife_ out of
this intellectual ferment, and become recognized by a substantial part
of the membership present at these meetings us important concerns,
'"To bo mm-, It was nlno fmmcu-tint oonn-rniMl nhmit HIP »."e of cnccxlyllc nelil. find »r;.-H
thnt l t n lino bo "miHprniltMl" u n t i l moiv wits known ntuxit HH "f.-itc." lint In .Snlj,"&gt;n, two
montliti l n l c r , l&gt;r. M l m i r l k ohurnclcrl/.cil IIH t r i v i nlls u tlio qimotttk's of products of d o u b t f u l
t o x l c l t v tluit wore l e f t on llni Krouiul frnm 1 1"' &gt; o' *" ls difmlcnl. Tlii; game 'Juclyincut
WUH offered In A A A S UlseusHlonH tliv fulluwlHf DvvumLicr by Dr. I&gt;ny.

�u-.;-e; \ e u&gt; Oo uu-.vh jvriou.sty by the public at large. With (he effective—
if some-times imprecise—aid of the public press, the AAAS is able to
identify'anj^^kractfrizo scientific issues in which tho genera:! public
has a legitii^^^B)ncern.
By the &amp;fflWroken, the AAAS board of directors in its nvore frequent' meetings, and the_ AAAS Council in its formal annual assemblies, are able to crystallize these, issues in a form that can'be cocrnminicated to responsible political dccisionmakers. Hoard actions ami (council
resolutions can serve usefully as challenges to existing policy* and as
' demands for policy reviews. Sometimes, the need for specific actions or
' changes can even be made apparent. In the herbicide case, tMs combination of organizational forces gave undoubted emphasis ta&gt; :tho ef-'
forts of the- Department of Defense to keep its own house irl order,
and to anticipate the need for information about its program. Military
reassessment might have gone on in any event, but the persistent ex; •••••ssioiis of concern from the governing'bodies of the AAAS maiy have
• ''-ed to make these, reassessments more frequent and more searching.
Another observation is that any'issuc on which there are bofth dif:~ -.ilt scientific questions and intense political feeling is unlikelV to be
r-/olved in the great forum of discussion that the annual meetrings of
I'.Q AAAS produces. Even the more formal and structured sessions of
thet AAAS Council appear to be an inappropriate mechanism for the
revolving of such political/scientificjis-sues. And, indeed, tlie relaitively
small and select group that comprises the "legal entity" of theJLAAS
:-; not effective as an instrument for technology assessment.
Tlie question might be asked as to wheiher, indeed, the AAAS or
: •'.-•• of its component parts should be expected to function as a decisionr. --"ring body on technological assessment matters with a.substantial
;
i I ' ricul content. Can scientist's, any more than other people, connpart':. • iralize their judgment regarding'issues they feel strongly sabout?
I •"
they ignore tlie political content'and address themselves im pure '
j .' -.-to the technical?
• |
I : . r/e history of the herbicide controversy illustrates once more the
I i.• r.-rent difficulty of demonstrating a negative scientifically. Questions
!; - to acute toxicity and ecological effects of herbicides used in. "Vict• i- -..'-I were answered for immediate practical purposes. However, clcfinijit! •••• answers as to chronic long-term toxicity, genetic impairment, and
.•.'ig-term ecological consequences wore not. available relative to&gt; Viot|r \ :n any more than they wore for tho United States.
It can probably bo concluded with justice that the herbicide iques-.
:-.."—militan' or civilian—is a part of the larger question of ecological
; 1 environmental consequences of and for man. Apart from tho
;,;cal or normative issues of tho Vietnamese war, tho question w&gt;f tho
•::-orim-nws of herbicide use on the environment is a serious and
.'loiiit on«, but one that needs to bo answered. The moans by wShich
•-. provide the answers are not yet at hand. The fact that all parties
• •••Ived in the assessment have agreed-to look long and hard sat tho
• twar Vietnanip.^', ecology is reassuring. However, tho state «sf tho
•t of the, ecological^ disciplines, and the ability of professional
••oplc in those disciplines to exchange knowledge and under.stan«:ling,
• ill be tested to tho limit in.tho performance of such an assessment.

tary expedience—irrelevant to tho purposes of science—and whore the
results would bo likely to bo clouded by emotional dissonance.

�APPENDIX A
DRAFT or PENDING SECTION OF M.AXUAL ox Usn OF HKKUJCIDKS FOR
'

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'
MILITARY PtTM'OSKS
'
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'
MS SCITLIED BY; DKFAKTMENT OF THE AlllIY

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•
Section I.: TECHNICAL ASPECTS
51. General
;
Antiplant agents arc chemical agents which possess a high offensive
potential for destroying or seriously limiting the production of food
and defoliating vegetation. These compounds include herbicides that
kill or inhibit the growth of plants; plant growth regulators that
either regulate o r . inhibit plant growth, sometimes causing plant
death; desiccants that dry up: plant foliage; and soil sterilants that
prevent or inhibit the growth; of %-egetation by action with the soil.
Military applications for antiplant agents are based on denying the
enemy food and concealment. •
52. Antiplant agents in use
a. ORANGE. .
(1) Description. Agent ORANGE is the Standard A agent. IT
is composed of a 50:50 -mixture -of the n-butyl esters • of 2.4- D and
2,4,5-T (app_D_a.ncl Cl, TM_ 3-1-215). ORANGE appears as a dark. brown oily liquid which is insoluble in water but misoible in oils
such as diescl fuel. It weighs about 10.75 pounds per gallon and becomes quite viscous as the temperature drops, solidifying at. 4~&gt;° F.
It is noncorrosivc, of low volatility, and nonexplosive, but deteriorates
rubber. . .
'
i I
• '
- (2) Rate of application. The recommended rate of application
of ORANGE is 3 gallons per acre. This may vary depending on the
. typo of vegetation (app C). In some situations b'etter coverage may
bo obtained by diluting ORANGE with diesel fuel oil, which results
in a less viscous solution that is dispersed in smaller droplets. Dilution
may also be required when using dispersion equipment which dot\s not
permit the flow rate to be conveniently adjusted to 3 gallons per acre.
See discussion of application methods in paragraphs "&gt;" and 58.
•(3) Effect on foliage. ORANGE penetrates the waxy covering of
leaves and is absorbed' info the, plant system. Tt a fleets" the crowing
points of the plant, resulting in its death. Rains occurring within the
First hour after spraying will not reduce the effectiveness of ORANGE
to the extent that they reduce the effectiveness of aqueous solutions. Bmulleaf plants arc highly susceptible to ORANGE. Some
grasses ca.n IKS controlled but require a much higher dose rate than
broadleaf plants. Susceptible, plum's exhibit varying degrees of susceptibility to ORANGE. TVa tli of a given plant may occur within a
week or less, or may require up to several months depending on the .
(07)

�plant's age. stage of growth, susceptibility, and the dose rate. See employment? co^flhtatious in paragraphs 53 through 55.
' (4) Saj^^B'ccautt'onJi and decontamination. ORANGE is relatively nontoSBw man or animals. No injuries have been reported to
personnel exposed to aircraft spray. Personnel subject to splashes
from handling the agent need not be alarmed, but should shower and
change clothes at a convenient, opportunity. ORANGE is noncorrosive
to metals but will remove aircraft paint and .walkway coatings. Contaminated aircraft should be washed with soapy water to remove the
agent. Rubber hoses and other rubber parts of transfer and dissemination equipment will deteriorate and require replacement, since ORANGE softens rubber.
•
J. BLUE (Phi/tar 560G). '
•
'.'• .
(1) Description. Agent BLUE is an aqueous solution containing
about 3 pounds per gallon of the sodium salt of cacodylic acid, the
proper amount of surfactant (a substance which increases the effec! t-veuess of the solution), and a neutralize.!' to prevent corrosion of
I r.ii-' ;! spray apparatus. BLUE is the agent normally used for crop
: ik'o:ruction.
,
.
•(2) Rate of o-pplication. BLUE may be sprayed as received! from
the manufacturer without dilution, if desired. The recommended .application rate for crop destruction is about 1 to 2 gallons per acre (app .C). However, much higher use rates of BLUE are required to kail tall •
grasses, such as elephant grass or sugarcane, because of the large
i:lasses of vegetation. For hand-spray operations, two gallons of l
BLUE diluted with water to'make 50 gallons will give a solution that
can bo dispersed by hand at a rate equivalent to approximately 1-to'
3 gallons o f pure agent p e r acre.
. ' ' • " . ' •
..-•-.•-••
(3) Effect on. foliage. Enough BLUE applied to any kind «f foil- .
age will cause it to dry and shrivel, but the agent-is more effective
;:L'ain.-;f grassy plants than broadleaf varieties. Best results are obxtaincd
when the plant, is thoroughly covered, since the agent, kills by al/sorp- .
\ tion of moisture from the leaves. The plants will die within 2 to- 4 days .
\ or less and can then bo burned if porinitte.fl to dry sufficiently. Blue in
| low do«e rates can also prevent grain formation in rice without any
apparent external effect. The plant develops normally but does not
yield a crop. Spray rates higher than about one-half gallon per aero
usually kill the crop. Although BLUE can produce relatively rapid
defoliation, regrowth may occur again in about 30 days. Repeated
spraying is ncce.ssary to provide a high degree of continuous plant .
^» 11 *• *

(4.) Safety precautions and decontamination. Normal sanitary
precautions should be followed when handling BLUE. Although it
contains a form of arsenic, BLUE is relatively nontqxic. It should not
bo taken, internally, however. Any material' that get on the Lands,
face, or other parts of iho body should be washed off at the. first opportunity. Clothes that became, wet with a solution of BLUE should
f&gt;e. changed. Aircraft used for spraying this solution .should be, washed
well afterward. When WHITE is added to BLUE, u precipitate forms
that will clog the system. I f the same, spray apparatus is to !s« used
; for spraying agents WHITE and BLUE, llio system must bo flushed
to assure that u.11 residue of the previous ngunt is removed.

_-.c. WHITE (TordonJOJ}.
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(1) Description. The active ingredients of agent
percent picloram and 80 percent isopropylamine salt c ^ ^ ^ - Active
ingredients constitute about 25 percent of the solution.^P^factant is
also present. WHITE is soluble in water, noncorrosive, nonflammable,
nonvolatile, immiscible in oils, and more viscous .than ORANGE at
the same temperature.
(2) Rate of application. WHITE usually should be applied at a
rate of 3 to 5 gallons per acre on broadleaf vegetation. However, the
rate may vary depending on the type of flora. Quantities required to
• control jungle vegetation may varv from 5 to 12 gallons per acre. This
quantity exceeds the spray capability of most, aircraft spray systems
for a single pass. It is usually unfeasible in large-scale military opcra' tions to apply such large volumes. For ground-based spray operations,
however, high volumes are necessary. Hand-spray operations cannot
evenly cover a whole acre with only 3 gallons of solution. Three gallons of WHITE diluted to a 30-gallon solution can be more easily
sprayed over an area of one acre. The manufacturer recommends
'diluting WHITE with sufficient water to make a 10-gallon solution
for each gallon of''agent.
(3) Effect on foliage. WHITE kills foliage in the same manner
as ORANGE, sirjco 80 percent of the active ingredient is 2,4-D.
' PICLORAM is irfore effective than 2,4-D, but acts slower. WHITE is
• effective on many plant species, and equal to or more effective than
ORANGE on the more woody species. The material must be absorbed
through the leaves. The water solution does not penetrate-the waxy
• covering of leaves as well as oily mixtures, and is more easily washed
• off by rain.""
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•-...,
• . -•• =
(4) Safety precaution* anrl decontamination-. WHITE exhibits'
a low hazard from accidental ingest ion. However, it may cause some
irritation if splashed into the eyes. Should eye contact' occur. f!u-=h
with 'plenty of water. Splashes on the skin should be thoroughly
washed with soap and water at the first opportuniiv. Contaminated
clothing should be washed before reuse. When WHITE is used in the
same equipment as BLUE, all of the WHITE should be i-emoved !•&lt;&gt;fore using BLUE. The two agents produce a white precipitate that
will clog spray systems.
' •
d. Soil Stcrilants.
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,
( 1 ) BROMACIL. .
- ' ' • ' .
(a) Drxrr!pf!f&gt;n. BROMACTL is an odorless. nonriMT«~;ve,
vliito crystalline solid, slijifhtlv soluble in water or die.-cl fuel oil. Three
dip'orent forms are produced: HYVAR-X, a wettable powder containing 80-percent active ineredient; HVVAR-N-WS, a fiO-penvnt
active ingredient water-soluble powder; and URON 'B', a liquid containing 4 pounds of active ingredient per gallon (app I)).
(5) Rate of application. HYVAR-X is applied at a rate of
15 to 30 pounds per aero; TIYVAR-X-WS, 2-1- to 4S pounds per acre;
and UROX 'B', 3 to 0 gallons per acre, Sprav concentrations of the
agent as high as 50 to 150 pounds per 100 gallons' of wafer or oil can
bo handled by aircraft-mounted spray systems. Tim 80-percent wet-

�V-/ '

. (a) JJ&amp;fiption. IIRO'X 22 is'a granular substance containing
122 percent monuron trichloroacetftte.
'
'
(i) $nte of application. Tlie manufacturer suggests using 150
I to 200 pounds per acre.
(:?) Effect on foliage. Soil sterilants act by absorption through, the
jroot system and therefore aro most effective under conditions of good •
;lsoil moisture. They are relatively stable once absorbed into the soil.
' : iS(&gt;il sterilants kill vegetation and may prevent regrowth for periods
;-'of a few months to a year, depending on the quantity and soil concli-

coils or
a. In some plants, leaves and growing stems form
develop marked curvature.
I. Growing stems may remain green, but may swell, develop cracks,
and form callous tissue.
G. Watery, translucent buds often appear at the crowns of some
. plants.
d. Spongy, enlarged roots may appear, turn black or gray, and rot.
e. Dead 'areas will form on the leaves wherever the spray droplets
have settled on'the leaf surface. A yellow ring may appear around the
'dead area, and gradually the entire leaf will develop yellow, brown,
.or red autumnal coloration and fall.
SECTION* III. DISSEMIXATION* METHODS

:

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(4) Safety pre can f ions and handling. Soil sterilants are only'slightly corrosive to metals, but dispersion equipment should be thor;
;pug!i!y flushed after use. They are relatively nontoxic to humans, but
;1 re-pi rat or masks should be worn to prevent inhalation of dust during
'"handling.
.
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..1

; SECTION" TI. COXCErrS OF EMl'LOVMEXT

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y&gt;'-\. General
•' .
•;j c. The employment of antiplant agents must be carefully controlled'
|!&lt;y technically qualified personnel to avoid many undesirable nftcr'•?(&lt;•• :i''~ts. FM :-MO discusses the employment concepts, analysis of opera- .
'us, and limitations of antiplant agents-.

a was is ideal for elusive hit-and-run tactics of the guerrilla.'.
L.*-::ioval or reduction of this concealment limits the guerrilla's ca-.
. {r I'-.ility to operate in the defoliated area.
. '
P-;. KiMploymcnt considerations
'
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'
-&lt;S l.-i addition to the. concepts discussed in FM 3-10, tho following
.v/oiiits should be considered when planning the use of antiplant agents.
J ft. Type of Poling4. ORAXGK is a wide-range, general-purpose agent
iVhirh is effective on the many types of foliage found in jungle areas.
I'.VHITK is also considered a general-purposo herbicide, but it is geu'i Tilly slower than O'KAXGK. BLUE is most effective on the narrow
.iip.if .species: the grasses, sugarcane, rice, and other cereal grains.
| f&gt;. When to Ai'pty. Tise best time to apply antiplunt agents is during
~~?l:-'. i:i'~t active growing season. This corresponds roughly tot-he pc-riocl
;;" ' • ::;f. appearaticB of new buds until 3 or -t weeks before onset of
.^
. •;. =eii.^on. Wh'iIt; spraying during the. dry season does produce
-'.:.'ifi», vegetation is not killed as quickly as it is during the. most
:'f:
"h• &lt;.'.\-&lt;:, growing season. An exception would be in certain tropical
j f i w l a n d areas where water is plentiful and c-onfinuous growth exists;
;"1 iiu.s antiplant agents are effective, throughout the. year.

56. Genera]
Antiplant agents may be disseminated by various methods depending
on tho sizes of the area to be defoliated and whether.the agent- is in
liquid, slurry, or solid form.
57. Ground-based application
Ground-based, gpray or dispersion methods are suited to small-scale
operations such as defoliation around base camps or installations or
clearing along routes of communication. These methods depend on
•easy access to the area on foot or by spray vehicle.
; 'a. Hand broadcast ing is the simplest way to disperse dry agents. .
• such as soil.sterilants,.but-is a rather time-consuming method.
. b. A 3-galloti- hand-pump sprayer is easy to xise in areas accessible
•by foot but where vehicles cannot, enter. It- is a slow method, however,
and areas out of arm's reach arc still inaccessible.
(1) UTI-1 series aircraft.
(a) .A simple expedient ppray system for a 1*11-1 type aircraft
.might consist of a 55-gallon drum fitted with a rubber hose which delivers the solution to a spray bar temporarily mounted ae.iw? the skids.
Slight, pre-ssumat.ion of the drum will usually help empty the. drum at
a steady rate. A portable* flamethrower pressure, bottle or an A.X-M4
compressor can lx* used for pressurizing, but a gage should be in the.
system to warn of excess pressure, (no more than S to 12 psi should be
used). The six.e and numlxn- of holes in the spray bar may be determined by trial and error; however, %-inch holes spaced G inches apart
will provide, good results.
(ft) Another field expedient system uses the, tank and Ill-foot
boom of the HI DAL. A 2"&gt;-gpm personnel carrier bilge pump delivers
the agent, allowing 30 to 40 meters coverage in width.
(2) CH-Jfl fth'craff. An expedient spray system for a OH—it
aircraft might consist of a oOO-gallon collapsible fuel bladder or a
400-gallon metal, skid-mounted tank. A power-driven fuel transfer
pump (50 to 100 gpm) can be used to deliver tho antiplant agent
to a spray bar attached to the ramp at the rear of tho aircraft.

�j •. The M100 Mity ?&gt;f!te (para 26) may be used $0 disperse liquid or
v- .TntipIfui1*^jBts. Foot, access to the ai'ea i,; i-e&lt;quired, but inaccess\i&gt; areas mt^^^Kovcred to some extent, since the Mity Mite will
ray a distnQjHsf about 50 feet,
d. A ptnccr-Srivcn dccohtfiminating appamtifJi (PDDA) may 1)0
pd when the area is accessible to wheeled vehicles. It is especially
1 mod for spraying soil sterilant in slurry form. The PDDA may
j,l-o be used to spray liquid antiplant agents. WHITE and BLU,E
, e.scnt no corrosion problems, but the apparatus must be well cleaned
rii changing between the two agents. OIJAXGK will soften'the
I &gt;'&gt;er parts, such as hoses and valve diaphragms, requiring their
I placement after a while. Spraying OEAXGE'lsy PDDA also pro4\ :os a hre hazard. .
. •.
•
I c. Comm-crcial orchard-sprayers, if available, may be used for
1 ..aying liquid solutions where ground access to vehicles is possible.
Aerial spray methods
'
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•
j Aerial spray methods are suited for large-scale operations, since a
1 icer area can be covered and ground access is not necessary. Aerial
Y jlieation methods are much more subject to weather conditions, such
&gt; wind direction and spc-od and temperature .gradient, than are
juuuii-b;'!&gt;od methods. Therefore, particular atteniion 'must be paid
\ the possibility of agent drift onto any nearby friendly crops. The
jrht of attack, airspeed, and area coverage depend on'weather and
rain conditions and pilot experience.
a. UC-12-3B Aircraft. UC-123B cargo aircraft fitted with internal
Irs and external ?pniy booms are used tor largo-scale defoliation
?pray booms
for lar^e-scalc
1 crop c
destruction operations. Using the present systems at an al;do of 150 feet as id aii-spced of 130 knots rcsulss in a spray rate of
1.50
i :lions per aera,
&gt;-•. FIDAL (Fi:/:cd-v:iny Insecticide Dispersal A ppamfm. Liquid}'.
:
: FIDAL YA a Xavy developed and tested systom. It has not been
udardized by the AVmy. When available, it can bo used to supplant the spray capability of the C-123 systems.'The FIDAL is
ig on the AIE or All! aircraft without "modification. Each tank
Ms about 275 gallons and has its own ram air turbine to provide
ver for pumping this spray through a spray boom. Cosi, is much less
n that of C-12:&gt; inboard systems, and spray missions do not tie up
aircraft since the tanks can be hung or removed iu'minutes.• •
t-. IleJieoptcr-Mowntfid Spray Systems.
' ••
\(1) HI DAL (Helicopter Insecticide Dtsspental
Appnrafi./s,
"p;id)i The IJTIDAL system is a 1%-gallon spcay system suitable
',. us/s in a UH—1 scries helicopter. Helicoptei's are useful in spray' areas around installations that arc; not acce-siblo to wheeled vc'-.-•: minefields, barbed wire barrieiii, etc. The IIIDAL is sclf• •••'], has an adjustable spray rate, and can. l&gt;e installed'and re, -I ;,-. a matter of minutes. It is a Xavy developed system and has
]/:•";'! standardized by tho Army.
•
. •
•
..'•'.-•
. f-2) AGAVENCO xpm/&lt;'r, Tho AGAVEXCO system has capaj i l tics similar to those of tlie IIIDAL and is presently being pro,red in a limited quantity. It has not lx&gt;cn stantliirdixod.
1

(~*

t

1

ft

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d. Field Expedient Spray Systems. When systems such OM tu, ;
HIDAL are unavailable, field expedient spray systenuj^fct'wiy yrform adequately might be constructed.
^^^B
G. Effect on Nearby^ Crops. If the application of a^|^_nt agents
is on target to begin with, the main clanger to nearby susceptible crops
will be from drift. The main factors affecting agent drift are vandij
direction and speed, dissemination method (para 56 through 58), tern-1'
perature gradient (TAI 3-240), and the agent used. Conditions for
dissemination of antiplant agents are usually most -favorable during
early morning hours (before OSOO) while inversion temperature
gradient prevails and the wind speed is still low (doc:s_not exceed 8
. knots). A volatile antiplant agent may also produce drift effect even
after the spray has settled on target. For example, the slight vaporization of OllAXGE may produce drift damage, especially if nearby
iiponzn
subjc
Thus they can be more safely used near susceptible crops provided
. cautions such as wind direction are heeded, and a dissemination method
that tends to. produce the least amount o£ drift is used. Although
'soil sterilants do not drift, they should not be used closer than 1UO
meters to crops or cropland in a friendly area onto which drainage from
treated areas flows.*'
d. Duration of Effect. Neither OR AXGE, BLUE, nor WHITE can
be consideredi"permano.nt" type antiplant agents. They act by direct
contact with the plant. Defoliation result ing from aerial application of
BLUE may lie. effective only until new growth appears. Defoliation
resulting froin'aerial'application'.'of OR AXGE or WHITE will'
usually bo effective for one growing season, but may be effective for
periods of approximately 0 months to 1 year. Soil sterilants. on the
other hand, ma^y be effective for period.- • • f up to a year or more, because
they are desigi ed to be slowly dissolved by rainfall and remain active
in the soil.

o

.13

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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>Huddle, F. P.</text>
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                <text>A Technology Assessment of the Vietnam Defoliant Matter, A Case History: Report to the Subcommittee on Science, Research, and Development of the Committee on Science and Astronautics, U. S. House of Representatives, Ninety-First Congress, First Session</text>
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