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 final CCP product, since less of the toxic component is available to consumers in the finished product. In the brief comments noted below, substances identified as mild irritants were not classified as primary irritants, even though some irritation occurred in more than one animal. Many of the compounds caused diarrhea. These observations are probably not relevant to humans—especially when animals were gavaged with a large volume of a slurry of white paper. Also of questionable relevance was the liver damage caused by compound 043. This effect occurred when animals were exposed to 10,000 ppm for 90 days. In a NIOSH docket submission numbered Document 050–EMI, a crystalline white powder was suspected to be relatively toxic. Peer reviewers from the industry noted that at full strength, this substance was corrosive to the skin, severely irritating to the eyes, and acutely toxic by oral ingestion [Graves and Tardiff 1999]. However, comments from the same peer reviewers noted that this component was never used in CCP production or offered for sale commercially. When the component was tested as part of a trial CCP, the paper was negative for acute and dermal toxicity and eye and skin irritation. Also of concern were a few studies in which compounds (033, 034, 036, 038–TR–33 to TR–38) were tested by inhalation or dermal application. Although these compounds did not produce any deaths or pathological findings, exposures resulted in modified behavior. Animals became hyperactive, salivated, became ataxic, and lost their righting reflex. NIOSH concluded that low exposures to these compounds could produce comparable effects in humans. Peer reviewers from the industry noted that these tests involved pure compounds, and that tests of the finished CCP products containing these compounds were negative [Graves and Tardiff 1999]. The chemical or component identification was unknown to NIOSH because of trade secret claims by the industry. Thus connecting the test results from pure compounds to finished products was not possible. None of the mutagenicity studies were positive, but not all substances were tested for mutagenicity. Another NIOSH docket submission from Monsanto is a series of 44 toxicity reports conducted by various testing laboratories on papers and dyes that were tested during the years 1978 to 1986. Each report consists of one to six toxicity tests that include oral and dermal toxicity, skin and eye irritation assessment, mutagenicity testing, and skin sensitization testing in animals.

Santosol 150 dye solution was tested more than any other product. Tests included a 90-day feeding study, developmental toxicity testing, and a series of studies in fish and midges. Unlike the other products tested in the Monsanto series, an LD50 and a maximum tolerated dose were determined for Santosol 150. In general, this dye solution exhibited low toxicity.

None of the products tested in the Monsanto series (including Santosol 150) were mutagenic, but not all products were tested for mutagenicity. None of the products were skin sensitizers in animals or humans, but not all products were tested for skin sensitization. Most compounds were not acutely toxic by the oral or dermal route. This conclusion was based on the fact that they were not lethal at 5 g/kg (oral route) or 2 g/kg 