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Monsanto's Dioxin Fraud The following leaked memo to the US Environmental Protection Agency,

summarised by The Ecologist shows how Monsanto lied to the US authorities about its dioxin production, and deliberately falsified data to

prevent compensation claims or the tightening of regulations.

DATE: November 15, 1990. SUBJECT: Criminal Investigation of Monsanto Corporation

- Cover-up of Dioxin Contamination in Products - Falsification of Dioxin Health Studies.

Fraudulent Dioxin Health Studies The following are a few key instances where obvious fraud was utilised in the conduct of Monsanto's epidemiological studies:

Dr. Raymond Suskind at the University of Cincinnati was hired by Monsanto to study the workers at Monsanto's Nitro, West Virginia, plant. Dr. Suskind stated in published studies in question that chloracne, a skin condition, was the prime indicator of high human dioxin exposures, and no other health effects would be observed in the absence of this condition.

FROM: Cate Jenkins, PhD, Chemist, Regulatory

Development Branch.

TO: John West and Kevin Guanno, Special Agent

Office of Criminal Investigations, EPA.

As per our meeting yesterday, I am summarising information available to me supporting allegations of a long pattern of fraud by Monsanto Corporation. The fraud concerns 2,3,7,7tetrachlorodibenzodi (dioxin) contamination of Monsanto's dioxin-exposed workers.

Significance of Monsanto's Dioxin Fraud Monsanto has in fact submitted false information to EPA which directly resulted in weakened regulations. The Monsanto human health studies have been submitted to EPA by Monsanto as part of public comments on proposed dioxin rules, and Agency-wide dioxin health studies are continually relied upon by all offices of EPA to conclude that dioxins have not caused cancer or other health effects (other than chloracne) in humans. Thus, dioxin has been given a lesser carcinogenic potential ranking, which continues to be the basis of less stringent regulations and lesser degrees of environmental controls. The Monsanto studies in question also have been a key basis for denying compensation to Vietnam Veterans exposed to Agent Orange and their children suffering birth defects from such parental exposures.

Unpublished studies by Suskind, however, indicate the fallacy of this statement. No workers except those having chloracne were ever examined by Suskind or included in his study. In other words, if no workers without chloracne were ever examined for other health effects, there is no basis for asserting that chloracne was "the hallmark of dioxin intoxication". These conclusions have been repeatedly utilised by EPA, the Veterans Administration, etc., to deny any causation by dioxin of health effects of exposed citizens, if these persons did not exhibit chloracne.


Fraud • Stealth • Hype

Dr. Suskind also covered up the documented neurological damage from dioxin exposures. At Workers Compensation hearings, Suskind denied that the workers experienced any neurological health effects. In the Kemner,

et al. v. Monsanto proceedings, however, it was revealed that Suskind had in his possession at the time examinations of the workers by Monsanto's physician, Dr. Nestman, documenting neurological health effects.

Dioxin Contamination of Monsanto Products Monsanto covered up the dioxin contamination of a wide range of its products. Monsanto either failed to report contamination, substituted false information purporting to show no contamination, or submitted samples to the government for analysis which had been specially prepared so that dioxin contamination did not exist.

Another Monsanto study involved independent medical examinations of surviving employees by Monsanto physicians. Several hundred former Monsanto employees were too ill to travel to participate in the study. Monsanto refused to use the attending physicians' reports of the illness as part of their study, saying that it would introduce inconsistencies. Thus, any critically ill dioxin-exposed workers with cancers such as non-Hodgkin's lymphoma (associated with dioxin exposures) were conveniently excluded from the Monsanto study.

The earliest-known effort by Monsanto to cover up dioxin contamination of its products involved the herbicide used in Vietnam, Agent Orange. Available internal Monsanto correspondence in the 1960s shows a knowledge of this contamination and the fact that the dioxin contaminant was responsible for kidney and liver damage, as well as the skin condition chloracne.

Early internal Monsanto documents reveal that samples of Agent Orange and other chlorinated herbicides and chlorophenols submitted to the US Department of Agriculture in the 1970s were 'doctored'. In other words, highly contaminated samples were not submitted to the government... These analyses were subsequently adopted by EPA in a 1980 publication and were used without any data from other sources as the basis for 1984 regulations under RCRA.

There are numerous other flaws in the Monsanto health studies. Each of these misrepresentations and falsifications always served to negate any conclusions of adverse health effects from dioxins. A careful audit of these studies by EPA's epidemiological scientists should be obtained as part of your investigation.

The false conclusions contained in the Monsanto'studies have been refuted by the findings of a recent study by the National Institute of Occupational Safety and Health (NIOSH). This NIOSH study, recently circulated by Dr. Marilyn Fingerhut for review, found a statistically significant increase in cancers at all sites in the Monsanto workers, when dioxin-exposed workers at Monsanto and other industrial locations were examined as an aggregate group.


The Ecologist, Vol. 29, No 6, October 1999 NO-ONE EVER DIE D FROM DIOXI N

revealed figures similar to those found around the Coalite plant.

In Rijnmond, Holland, in 1989, the milk from 16 farms was so contaminated by dioxins from a municipal waste incinerator that the fat was skimmed off and sent to a nearby hazardous waste incinerator for disposal. In France, a number of municipal waste incinerators were closed only last year because of heavy dioxin contamination of farm produce in adjacent areas.

Th e Publi c Wake s Up In the early 1990s, the chlorine industry, considering regulations on dioxin too restricting and costly, applied pressure on the US EPA to 'reassess' dioxin's toxicity. The EPA consequently began what turned out to be the most extensive study ever undertaken on a chemical by-product using all available scientific literature. They employed 100 outside scientists as well as their own in-house staff on a programme that took three years. The report concluded that: • the largest source of dioxin was municipal and clinical

waste incinerators: • dioxin was more toxic than had been originally believed,

and was capable of damaging health in ways not widely anticipated, e.g. immune system suppression, endocrine system/hormone disruption: • these non-cancer effects occurred at levels 100 times

below the level that caused cancer.16

The report's findings shocked many people, not least the chlorine industry itself, which had been hoping for a whitewash. A number of conferences were organised about this time by concerned independent scientists and community activists to inform the public of the truth about dioxin. Dr. Barry Commoner told delegates at one such conference:

"Dioxin is now known to interfere with the most delicately balanced biological process in our bodies; they are man-made chemicals that, present in only minuscule amounts, can alter the natural bio-chemical process that determines how people develop, grow, and behave."17

Dr. Linda Birnbaum (Director of Environmental Toxicology Division, EPA), responding to the industry's desperate claims

that "dioxins are natural" and "humans are not as sensitive to dioxin as animals", said: "People have done analyses of Egyptian mummies from more than 2,000 years ago and frozen Eskimos from northern Canada, and the levels are below detection limit. Dioxin is a product of modern industrialisation"18

"When you say that it [incineration] is acceptable, it is acceptable to the more articulate sections of the population. From what you have said, the incinerator ends up in the less articulate section of the population. I do think we ought to make that point quite clear"

Bu t th e Lov e Affai r Continue s All this extensive scientific data didn't stop self-confessed advocate of incineration, Professor Dame Barbara Clayton, immediate past President of the National Society of Clean Air

Incineration is today acknowledged by the British government to be responsible for between 60 and 85 per cent of the UK's current dioxin contamination.

and Environmental Protection (NSCAEP) shamefully misleading a House of Lords inquiry into waste incineration in March this year with the statement: "I f you look at the massive exposure of people to dioxins as a result of two major accidents, there is no evidence that the population was harmed apart from developing severe chloracne, which is a nasty skin complaint, but that was with massive exposure."19

In an attempt to convince the inquiry that incineration was harmless, Dame Clayton claimed that she "would live next to a modern incinerator," safe in the knowledge she will never have to. This was made quite evident when Lord Judd, questioning Mr. Richard Mills (also of NSCAEP) on his evidence, said: "When you say that it [incineration] is acceptable, it is acceptable to the more articulate sections of the population. From what you have said, the incinerator ends up in the less articulate section of the population. I do think we ought to make that point quite clear" 2 0

Incineration is today acknowledged by the British govern-

Dioxin contamination of European animal feed in 1998 In 1998, a significant increase in dioxin levels was detected through routine milk monitoring in Germany1. Elevated dioxin levels were also found in milk in other EU member states, and contaminated feed was imported into the UK. The contamination source was traced to Brazilian citrus pulp used in European animal feed manufacture.

(MPL) for dioxins in citrus pulp used to feed farm animals. These measures, which came into force in August 1998, prevent all citrus pulp containing dioxins above a specified level from entering the EU; but they do not affect the citrus pulp already in Europe.

that contaminated citrus pulp has been fully withdrawn from UK animal feeds. Citrus pulp is a major market for both importers and the exporters - Brazil produces about 60% of the citrus pulp used seasonally in the EU.

Whilst the alarming levels found in citrus pulp used in Germany resulted in direct government action and publication of their data, no such data were released by MAFF in the UK. And whilst other European countries acted immediately to prevent further contamination of the food chain, the UK waited until the EU Commission issued a directive (98/60/EC) before issuing draft regulations introducing a Maximum Permitted Level

This problem is being dealt with on a national, not an EU level. In the UK, there are reports of stockpiles of 192,000 tonnes of this contaminated feed, which has been widely mixed with uncontaminated feed. MAFF2 report that they have written to local authority enforcement officers to alert them to the proposed Regulations (as they have the responsibility to enforce animal feed controls). However, there is little evidence that the problem has reached the ears of dairy and beef farmers, and no evidence

The use of contaminated lime in the pulp extraction process appears to be the most likely cause; a recent Greenpeace investigation lays the source of the contamination at the door of the Belgian based Chlorine producer Solvay. - Miriam Jacobs 1. Malisch, R. (1998) Increase of PCDD/F

contamination of milk and butter in Germany by use of contaminated citrus pulp as component in feedstuff. Organohalogen Compounds. 38 65-69 2. Ministry of Agriculture Fisheries and Food

(1998) Food Safety Information Bulletin No. 100 September 1998

The Ecologist, Vol. 29, No 6, October 1999