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.

FROM: Cate Jenkins, PhD, Chemist, Regulatory
Development Branch.

TO: John West and Kevin Guarino, 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.

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.

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.

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.

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.

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.

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.

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.