Further down, the memo details Monsanto's planned response to the scientist's publication:

"Monsanto is preparing to challenge certain aspects of this problem but we are not prepared to defend against all of the accusations.

(a) Monsanto is preparing itself to identify trace ppb quantities of chlorinated biphenyls in water samples, in concentrated collected air samples, and in animal tissues. We will know whether we have been falsely identified and accused or not. We will eventually know where any pollution is taking place and the extent of the pollution.

(b) We are not prepared to defend ourselves against the accusations made of enzyme and hormone activity, the isolation of the enzymes or metabolic products, the indirect accusation of cancer, or the splitting of genes, when its accusation is made. Whether we can defend this route or not needs further discussion.

(c) Through the Industrial Bio-Test program we are to establish the long term allowable limits of chlorinated biphenyls for certain birds-fish-animals by feeding experiments, pathological examination, and tissue analysis for chlorinated biphenyls. We may be able to answer reproductive ability in some animals.

....

Where does this leave us?

Under identification and control of exposure- we will be able to identify and analyze residues as well or better than anyone in the world. We will probably find residues other than DDT and PCB's. We will probably wind up sharing the blame in the ppm to ppb concentration level.

We can take steps to minimize pollution from our own chlorinated biphenyl plants, we can work with our larger customers to minimize pollution, we can continue to set up disposal and reclaim operations. We can work for minimum exposure in manufacture and disposal of capacitors, transformers and heat transfer systems, and minimize losses for large hydraulic users.

But, we can't easily control hydraulic fluid losses in small plants. It will be still more difficult to control other end uses such as cutting oils, adhesives, plastics and NCR paper. In these applications exposure to consumers is greater and the disposal problem becomes complex. If chlorinated biphenyl is shown to have some long term enzyme or hormone activity in the ppm range, the applications with consumer exposure would cause difficulty.

Risebrough has taken known Aroclor samples and claims to have evidence of enzyme and hormone change. Here there is no question of identification. Either his position is attacked and discounted or we will eventually have to withdraw product from end uses which have exposure problems. Since Risebrough's paper in "Nature", Dec. 1968 has just been published, it is timely, perhaps imperative, that this paper and its implications be discussed with certain customers. This is a rough one because it could mean loss of business on empty and false claims by Risebrough.

Well prepared discussions with Ind. Bio-Test, Monsanto biochemists, the medical and legal departments must take place now. The position of DDT manufacturers should be determined as a guide. We are being accused of the same things attributed to DDT." [Richard to Wheeler: Aroclor Wildlife Accusations; March 6, 1969]