#174: Hazardous Waste Incineration in Cement Kilns: 'Recycler's' Paradise.

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #174
---March 28, 1990---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com ========================Original Source========================

The federal Resource Conservation and Recovery Act (RCRA) is supposed to regulate the generation and disposal of hazardous chemical wastes "from cradle to grave."

Unfortunately, Congress built a feature into the law that EPA (U.S. Environmental Protection Agency) has turned into a loophole. Today, enormous quantities of hazardous waste are escaping regulation through this loophole. Specifically, Congress exempted "recycled" chemical wastes from control under RCRA, and EPA ruled that chemical wastes burned as fuel in industrial boilers, industrial furnaces, aggregate kilns and cement kilns are being "recycled" and are thus exempt from RCRA regulation.

According to Richard Fortuna, director of the Hazardous Waste Treatment Council (an incinerator industry group in Washington, DC), 50 billion pounds of chemical wastes are being burned in unregulated boilers and kilns each year, compared to only 5 billion pounds (or less) being burned in RCRA-regulated hazardous waste incinerators.[1]

A recent report from Greenpeace describes the burning of chemical wastes in aggregate kilns and cement kilns. Page numbers in our text, below, refer to this report, SHAM RECYCLERS, PART 1: HAZARDOUS WASTE INCINERATION IN CEMENT AND AGGREGATE KILNS.

Cement is the raw material from which concrete is made. In a cement kiln, powdered limestone and clay are burned at high temperatures to form a "clinker" that is later ground into a fine powder, which is cement; when water is added to this powder, it hardens. Certain "aggregates" can be added to cement to make mortar, plaster, concrete or other similar materials. As with cement, aggregates are formed by firing them in a high temperature kiln. Thus aggregate kilns and cement kilns seem ready-made for destroying hazardous wastes. They have to be heated to high temperatures with fuel, so why not substitute hazardous wastes for part of the fuel and burn up the wastes while making aggregate or cement? Save on fuel and destroy wastes--what could be better? This was the question Greenpeace's Science Director, Pat Costner, and her colleague Joe Thornton, set out to answer.

There are at least 24 cement kilns and 17 aggregate kilns in the U.S. burning hazardous wastes today (listed on pgs. 31-33). Together, they burn approximately 3 billion pounds of hazardous wastes, and a recent industry analysis says this amount could double between 1989 and by 1992 (pg. 8).

It is difficult to obtain data on destruction of wastes in kilns precisely because kilns are exempt from RCRA; kilns are not required to meet the permit requirements of regular hazardous waste incinerators, nor are they subject to the operation and emissions standards that control regular hazardous waste incinerators. So long as a company claims to be using hazardous waste as a fuel or as a raw material, they are classified as "recyclers," and there is essentially no review process within EPA to check their claims or their operations. Thus a fraudulent company, bent on unregulated waste disposal, has an easy time exploiting this exemption within RCRA. Marine Shale Processors in Amelia, Louisiana, which was recently closed down by EPA after national TV threw a spotlight on them, is a notorious example of a fraudulent waste hauler disguised as a kiln operator.

Even when the intention is not to defraud, destruction of wastes in kilns is highly questionable. As Costner and Thornton make clear, there are about a dozen good reasons for wanting to prevent wastes from entering kilns. Here are some of them:

Typical wastes burned in kilns include paint, ink, and coatings manufacturers' wastes, spent halogenated and non-halogenated solvents generated by a wide variety of manufacturing processes, still bottoms from solvent recovery operations, petroleum industry wastes, and waste oils including crankcase oil, transmission fluid, hydraulic and compressor fluids and coolants. Typically, 1.35% of these wastes are metals (including cadmium, arsenic, chromium, lead, mercury, zinc, and thallium). If 1.35% seems like a small amount, remember that 1.35% of 3 billion pounds is 40.5 million pounds of metals. Metals make trouble in incinerators--they are not destroyed but instead pass through the furnace into the outside environment, often in forms that make them more dangerous than when they first entered the kiln (e.g., attached to fine [extremely small] particles that can readily penetrate human lungs or can leach into groundwater) [see RHWN #131, #132, #134, #136, and #162].

Kilns burning hazardous wastes emit 66% more particles (soot, smoke, haze) than kilns burning normal fuel. Kilns burning halogenated wastes (containing chlorine, bromine, fluorine or iodine) emit 203% more particles than kilns burning normal fuel (pgs. 12, 26). This increased production of particles provides a pathway for metals to escape the incinerator in a form that is particularly dangerous to humans. The metals become attached to the outside of the fine particles and thus become available for humans to breathe. Costner and Thornton estimate that some 2 million pounds of metals may leave kilns attached to fine particles each year (pg. 23). Measurements at one kiln in California indicated it was releasing 15,000 pounds of metals into the local environment via airborne particles each year; measurements at a Florida kiln revealed airborne releases of 21,000 pounds of metals per year (pg. 23). Tests at an Illinois kiln revealed that burning hazardous wastes increased lead emissions 82%, chromium 167% and zinc 662%, compared to the same kiln burning normal fuel (pg. 23).

The fly ash from kilns is loaded with metals if the kiln burns hazardous wastes. Based on EPA data, Costner and Thornton estimate that 18.6 million pounds of metals enter the U.S. environment in fly ash from kilns each year (pg. 25). These metals are in a particularly leachable form, having a large surface area, and are thus available to enter water and living things (see RHWN #162). The high alkalinity (high pH) of kiln ash makes kiln ash even more leachable than ash from normal hazardous waste incinerators (pg. 25). At least two ash disposal sites for cement kilns are on the Superfund list, and neither kiln is supposed to have burned hazardous waste (pg. 25).

Advocates of hazardous waste incineration in kilns often claim that kilns destroy 100% of the wastes entering the furnace. Unfortunately, available data reveal this is not true by a wide margin. Kilns do operate at high temperatures (2000 to 3000 degrees Fahrenheit), but metals are not destroyed at any temperature. Furthermore, a class of chemicals called "products of incomplete combustion" (PICs, which include dioxins, furans, and a broad range of other organic chemicals) are created in a kiln, not in the furnace itself but in lower-temperature parts of the machine (smoke stack, pollution control devices, or ambient air outside the incinerator) (pgs. 18-21, 27-30).

The production of PICs is enhanced by "upsets," which occur in kilns several times each month, when something goes wrong with the machine. During these periods, puffs of hazardous chemicals are emitted into the local environment (pg. 18).

Another source of problems may be chemical releases resulting from transportation accidents. A typical kiln will burn 1,800 tank-truck loads of hazardous wastes per year. Many such trucks operate dangerously, in violation of applicable laws (pg. 18).

--Peter Montague, Ph.D.

===============

[1] Personal communication March 19, 1990, from Richard Fortuna, executive director of Hazardous Waste Treatment Council, Washington, DC; phone (202) 783-0870.

Get: Pat Costner and Joe Thornton, SHAM RECYCLERS, PART 1: HAZARDOUS WASTE INCINERATION IN CEMENT AND AGGREGATE KILNS (Washington, DC: Greenpeace [1436 U Street, NW, Washington, Dc 20009; phone (202) 462-1177], November, 1989). Greenpeace asks a $5.00 donation to cover printing and handling costs. Well worth the price.

Descriptor terms: rcra; epa; cement kilns; hwtc; hazardous waste; merine shale processors; ash; heavy metals;

#173: Dioxin--Part 2: Gauging the Toxicity of Dioxin.

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #173
---March 21, 1990---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com =================================Original Source========================

[Continuing our series on dioxin. Page numbers in parentheses refer to the ATSDR (the federal Agency for Toxic Substances and Disease Registry) Toxicological Profile for dioxin, cited in our last paragraph, below.]

It has become fashionable to pooh-pooh dioxin. We believe there are two reasons why this is occurring. First, some scientists have been publishing studies indicating that humans exposed to dioxin do not have an increased risk of cancer. As we saw in RHWN #171, some of the most important of these studies have now been exposed as fraudulent. The second reason is that dioxin is so toxic that it is difficult to express its potency in normal terms; therefore the media frequently print scary claims without offering much evidence, leading some people to conclude (incorrectly) that there isn't much substance to any claims about the extreme toxicity of dioxin.

In this series, we hope to lay the groundwork for an understanding of dioxin, to help people put dioxin into perspective. Some of what follows may seem a bit more technical than you are accustomed to reading in this newsletter; but stick with it, and you'll see why we have taken this approach.

The scientific and medical evidence presented by ATSDR forces us to conclude that dioxin deserves our greatest respect. It seems to be one of the two or three most toxic chemicals ever discovered, and it is produced as a byproduct of several different industrial processes. For years, industry has been dumping dioxin into the environment in large quantities without paying attention to the consequences. This does not mean there have been no consequences; it just means no one has made any systematic effort to tally them up.

Dioxin is a family of chemicals (75 in all) that does not occur naturally, nor is it intentionally manufactured by any industry (pg. 1). The most toxic dioxin is called 2,3,7,8-TCDD. Dioxins are produced as byproducts of the manufacture of some herbicides (for example, 2,4,5-T), wood preservatives made from trichlorophenols, and some germicides (for example, hexachlorophene). Dioxins are also produced by the manufacture of pulp and paper, by the combustion of wood in the presence of chlorine, by fires involving chlorinated benzenes and biphenyls (e.g., PCBs), by the exhaust of automobiles burning leaded fuel, and by municipal solid waste incinerators.

ATSDR says, "2,3,7,8-TCDD is highly toxic to all laboratory animals tested...." (pg. 11). Even the most conservative of toxicologists says, "TCDD has been called the most toxic synthetic chemical known to man. If its acute toxicity to the guinea pig, and even the rat and mouse, is the criterion, the statement is probably correct.... TCDD is unquestionably a chemical of supreme toxicity to experimental animals. Moreover, severe chronic effects from low dosages have also been demonstrated in experimental animals. Therefore, the concern about its effects on human health and the environment is understandable."[1]

In cases of high exposure of humans through industrial accidents, 2,3,7,8-TCDD causes a severe acne (called chloracne) which is not just a skin ailment; chloracne is a systemic disease that is more disfiguring than teenage acne and its effects last for years (in some cases, decades) after exposure (pgs. 3, 39).

There is "suggestive evidence" that 2,3,7,8-TCDD causes liver damage in humans (pgs. 3, 52-53). It definitely causes severe liver damage in animals.

In animals, 2,3,7,8-TCDD is toxic to the immune system; such effects have not been proven in humans (pgs. 3, 40, 54-56). In animals, 2,3,7,8-TCDD causes reproductive disorders, including spontaneous abortions. Monkeys are particuarly sensitive to reproductive effects from exposure to 2,3,7,8-TCDD. Such effects have not been proven in humans (pgs. 3, 17, 58-59). In animals, dioxin causes genetic damage (pgs. 60-61).

Both the U.S. Environmental Protection Agency (EPA) and the International Agency for Research on Cancer (IARC) have concluded that dioxin is a "probable human carcinogen" (pgs. 7, 61-68, 94). As we saw in RHWN #171, scientists within EPA have asked that this question be reviewed again because some of the key studies of dioxin and cancer were fraudulent, and EPA has relied on these fraudulent studies to set current standards.

How can we judge the toxicity of dioxin (or of any chemical, for that matter)? One way is to look at the standards that have been set by regulatory agencies.

In the case of dioxin, EPA has calculated a "safe" dose, taking into consideration dioxin's ability to cause cancer. The "safe" dose is expressed in extremely small units: femtograms. There are 28 grams in an ounce, and one femtogram is 0.000,000,000,000,001 grams, or one quadrillionth of a gram, or 10**-15 (or, 10 raised to the power of negative 15) grams.

EPA believes that ingesting (eating) 6.4 femtograms (6.4 x 10**-15 grams) of 2,3,7,8-TCDD per kilogram of body weight per day would cause cancer in one in a million people so exposed (pg. 95). Since an average adult weighs 62 kilograms or 137 pounds (average men weigh 70 kilograms [154 pounds] and average women weigh 55 kg [120 pounds]), the EPA is saying that 397 femtograms of 2,3,7,8-TCDD consumed in food each day would kill one-in-a-million humans so exposed. Over a year's time, 397 femtograms per day add up to 145,000 femtograms; over a 70-year lifetime, this would add up to 10.1 million femtograms, so 10.1 million femtograms (or 0.01 micrograms) is the maximum amount you could safely get into your body during your entire lifetime, EPA believes.

How can we express this in terms that people can grasp?

Let's compare it to one single aspirin tablet. One aspirin tablet weighs 5 grains (or 325 milligrams, or 325 trillion femtograms), so to express one "safe" lifetime dose of 2,3,7,8-TCDD, you would take a single aspirin tablet and divide it into 32 million (actually 32,172,218) miniscule pieces. Then one of those tiny pieces would represent one "safe" lifetime dose of 2,3,7,8-TCDD.

Another comparison: A single grain of table salt weighs approximately 0.1 milligrams or 100 billion femtograms, so to get an amount of table salt that weighs the same amount as one "safe" lifetime dose of 2,3,7,8-TCDD, you would divide a single grain of table salt into 9,900 microscopic pieces. One of those tiny pieces would represent a "safe" lifetime dose of dioxin.

The U.S. Food and Drug Administration (FDA) has its own way of calculating the same one-in-a-million cancer risk and they believe the EPA has overestimated the hazard by a factor of 10. In other words, FDA believes you could represent a "safe" dose of 2,3,7,8-TCDD by dividing a single grain of table salt into 990 pieces, with one of those pieces representing a safe lifetime dose. The federal Centers for Disease Control (CDC) in Atlanta has done its own calculation, concluding that the cancer hazard from dioxin is about half-way between the EPA's estimate and the FDA's estimate. EPA says 6.4 femtograms per kilogram of body weight per day is the safe dose; CDC says the correct number is 27.6; FDA says it's 57.2 (pg. 95). No matter which agency does the calculation, there's no escaping the fact that dioxin is considered supremely toxic.

One other way to understand the toxicity of dioxin is to compare the dioxin "reference dose" established by EPA to the "reference dose" they have set for other common toxic materials. The "reference dose" is the highest amount they believe you could eat regularly without incurring any disease (not considering cancer).

The reference dose for dioxin is 0.000,000,001 milligrams per kilogram of body weight per day (mg/kg/day) (pg. 94); the reference dose for the toxic metal cadmium[2] is 0.001 mg/kg/day and the "reference dose" for the toxic metal arsenic[3] is the same as for cadmium.[2] Thus we can see that EPA considers dioxin in food 1,000,000 times (one million times) more toxic than cadmium or arsenic[3], not counting the cancer hazard from dioxin. Yes, dioxin is toxic, no doubt about it.

[Part 3 continued issue #175 ]

--Peter Montague, Ph.D.

Also see: Dioxin--Part 1: Gauging the Toxicity of Dioxin. #171

===============

[1] Fred H. Tschirley, "Dioxin," SCIENTIFIC AMERICAN Vol. 254 (February, 1986), pg. 34."

[2] Agency for Toxic Substances and Disease Registry, TOXICOLOGICAL PROFILE FOR CADMIUM (Springfield, VA: National Technical Information Service [NTIS], 5285 Port Royal Rd., Springfield, VA 22161; phone (703) 487-4650), pg. 76.; NTIS number PB89-194476. $21.95.

[3] Agency for Toxic Substances and Disease Registry, TOXICOLOGICAL PROFILE FOR ARSENIC (Springfield, VA: National Technical Information Service [NTIS], 5285 Port Royal Rd., Springfield, VA 22161; phone (703) 487-4650), pg. 92.; NTIS number PB89-185706. $21.95.

Get: Agency for Toxic Substances and Disease Registry, TOXICOLOGICAL PROFILE FOR 2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN (Springfield, VA: National Technical Information Service [NTIS], 5285 Port Royal Rd., Springfield, VA 22161; phone (703) 4874650); NTIS number PB89-214522. $21.95.

Descriptor terms: dioxin; atsdr; herbicides; wood preservatives; trichlorophenols; hexachlorophene; pulp and paper; pcbs; msw; incineration; skin disorders; liver; fda; health effects; sudies; reproductive disorders; miscarriages; genetic disorders; cancers; risk assessment; chloroacne;

#171: Dioxin--Part 1: Dioxins And Cancer: Fraudulent Studies.

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #171
---March 7, 1990---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com ========================Original Source========================

For years, industry scientists have been claiming there's no evidence that dioxins cause cancer in humans. Now there is mounting evidence that such claims rely heavily on studies that are fraudulent. Two companies recently accused of producing fraudulent dioxin-and-health data are Monsanto and BASF.

Monsanto

A scientist with U.S. Environmental Protection Agency (EPA) says Monsanto falsified data in important studies that Monsanto used to support its claim that dioxin does not cause cancer in humans. Dr. Cate Jenkins, a chemist in EPA's Office of Solid Waste and Emergency Response, says EPA itself relied upon Monsanto's fraudulent data in setting health standards for dioxin, and Jenkins has asked the EPA's Science Advisory Board to reopen the matter of EPA's dioxin standards, to take a fresh look at available data.[1]

Two important sources of dioxins in the environment are old chemical dumps and the incineration of municipal solid wastes,[2] which is why EPA is concerned about allowable levels of human exposures to dioxin.

BASF

The British technical journal, NEW SCIENTIST, says, "A new analysis by a West German epidemiologist may have established the first clearcut evidence of a direct link between exposure to dioxins and cancer in humans. Friedemann Rohleder, an independent specialist, has produced a report detailing an unexpectedly high incidence of cancer among workers exposed to dioxins during an industrial accident at a chemicals plant in 1953.[3]

"The plant, operated by the West German company BASF, made trichlorophenol. Rohleder claims the company presented the data in a way that disguised the cancers," says NEW SCIENTIST.

Background

Each of these claims of fraud relates to an industrial accident in which workers were exposed to dioxins; follow-up medical studies funded by the responsible companies have been published in mainstream scientific journals, claiming to show that no excess cancers have occurred in the dioxin-exposed workers. In fact, excess cancers have occurred, but it appears that the data have been manipulated to hide the facts.

The Monsanto Case

In 1949, an explosion occurred at a Monsanto chemical factory in Nitro, West Virginia; as a result, many workers in the plant were exposed to the herbicide 2,4,5-T, which was contaminated with dioxin. (This herbicide was later the principal component of Agent Orange, the chemical defoliant used by the U.S. in Viet Nam.) In subsequent years, two Monsanto scientists, J.A. Zack and R. W. Gaffey, studied the exposed workers, comparing their health against the health of a similar group of workers who were not exposed to dioxin or 2,4,5-T.[4]

According to court documents attached to the EPA memo,"Zack and Gaffey deliberately and knowingly omitted 5 deaths from the exposed group and took four workers who had been exposed and put these workers in the unexposed group, serving, of course, to decrease the death rate in the exposed group and increase the death rate in the unexposed group."

Other studies of this same accident were also fraudulent, according to the same court documents, including a study by R.R. Suskind published in the JOURNAL OF THE AMERICAN MEDICAL ASSOCIATION:[5] "This published study of the workers exposed in the 1949 accident reported only 14 cancers in the exposed group and 6 in the unexposed group (a smaller cohort). However, the medical records produced [by Monsanto] to the Plaintiffs conclusively prove gross miscalculations and omissions... there were 28 cancers in the group that had been exposed to dioxins in 1949 as opposed to only 2 cancers in the unexposed group." Mr. Suskind published two other reports [6,7] on the same accident, using his same data, to reach the conclusion that dioxin does not cause cancer.

The BASF Case

On the night of November 17, 1953, a runaway chemical reaction spewed dioxin-contaminated chemicals over workers and community residents of two small German cities, Mannheim and Ludwigshafen. Subsequently, an epidemiological study was used to deny workers any compensation for ailments they claimed they suffered as a result of exposure. In keeping with German law, the workers retained their own expert to review the data. Their expert, Friedemann Rohleder, received the data from the German government but found, to his surprise, that all the data actually came from the BASF company itself. He analyzed the data and found that some workers suffering from chloracne, which is universally acknowledged to be evidence of high exposure to dioxin, had been placed in the low-exposure or non-exposed group. He found evidence of "diluting" the exposed group with 20 plant supervisory staff who, Rohleder believes, were not exposed. When Rohleder omitted the 20 supervisory staff, his analysis revealed statistically significant increases in two groups of cancers: cancers of the respiratory organs (lungs, trachea, etc.), and cancers of the digestive tract. "This analysis adds further evidence to an association between dioxin exposure and human malignancy," Rohleder told NEW SCIENTIST.

[continued see issue #173 ]

--Peter Montague, Ph.D.

===============

[1] Cate Jenkins, "Memo to Raymond Loehr: Newly Revealed Fraud by Monsanto in an Epidemiological Study Used by Epa to Assess Human health Effects from Dioxins," dated February 23, 1990. Jenkins is a chemist with the Waste Characterization Branch (OS 332), Characterization and Assessment Division, U.S. EPA, 401 M St., SW, Washington, DC 20460. Loehr is Chairperson of the Executive Committee of the Science Advisory Board (A-101), Office of the Administrator, U.S. EPA, 401 M St., SW, Washington, Dc 20460. The Jenkins memo has attached to it 25 pages of a brief filed in Case No. 5-88-0420, in the Appellate Court of Illinois, Fifth District by attorneys suing Monsanto on behalf of plaintiffs who say they were harmed when a Norfolk and Western railroad tank car derailed, spilling 19,000 gallons of a Monsanto chemical called "ocp-crude" into the community of Sturgeon, Missouri the night of January 10, 1979. Chief attorney for the plaintiffs is Rex Carr, 412 Missouri Avenue, East St. Louis, Il 62201; phone (618) 274-0434. Our thanks to Margo Blackwell, People Against the Incinerator (pati), Bloomington, Indiana, and to Epa official William Sanjour, both of whom independently sent us the information about Monsanto. We can mail copies of the Jenkins memo and attachments (28 pages) for $14.00, which covers our actual costs of photocopying, handling and mailing.

[2] Oak Ridge National Laboratory. TOXICOLOGICAL PROFILE FOR 2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN [ATSDR/TP-88/23; PB89-214522] (Springfield, VA: National Technical Information Service, June, 1989), pg. 22, identifies dumps and incinerators as "the important sources of 2,3,7,8-TCDD exposure to the general population." This is the Agency for Toxic Substances and Disease Registry [ATSDR] toxicological profile for dioxin (See RHWN #169.)

[3] Stephanie Wanchinksi, "New Analysis links dioxin to cancer," NEW SCIENTIST October 28, 1989, pg. 24. Thanks to Paul Connett of Work on Waste USA, we have a copy of Friedemann Rohleder's paper, which he presented in late September at a dioxin conference in Toronto, Ontario; Rohleder's paper is entitled "Dioxins and Cancer Mortality-Reanalysis of the BASF Cohort." We can mail you the 14-page Rohleder paper for $7.00, or you can request a copy directly from the author: Friedemann Rohleder, Friedrich Hebel Str. 13, 1712 Werne, West Germany.

[4] Zack, J.A., and W. R. Gaffey, "A Mortality Study Of Workers Employed At The Monsanto Company Plant In Nitro, West Virginia," ENVIRONMENTAL SCIENCE RESEARCH, Vol. 26 (1983), pgs. 575-591.

[5] R.R. Suskind, and V.S. Hertzberg, "Human Health Effects Of 2,4,5-T And Its Toxic Contaminants," JOURNAL OF THE AMERICAN MEDICAL ASSOCIATION, Vol. 251, No. 18 (1984), pgs. 2372-2380.

[6] R.R. Suskind, "Chloracne, 'The Hallmark Of Dioxin Intoxication,'" SCANDINAVIAN JOURNAL OF WORK, ENVIRONMENT AND HEALTH, Vol. 11, No. 3 (1985), pgs. 165-171.

[7] R.R. Suskind, "Long-Term Health Effects Of Exposure To 2,4,5-T And/Or Its Contaminants," CHEMOSPHERE, Vol. 12, No. 4-5 (1983), pg. 769.

Descriptor terms: dioxins; monsanto; basf; cancers; trichlorophenol; occupational safety and health; nitro, wv; va; herbicides; studies; chloracne; skin disorders; lung cancer; respiratory cancer; digestive tract;