.r,,

/'

\"

(

'.

UNITED STATES Of N\E!UCA

2

BEFORE THe

J

•

ENVIRONI1ENTAL PROTECTION AGENCY

5

- - - - - - - - - x

6

-

7

8
9

In the Matter of the Hearing of::
2,4,S-T and SILVEX

Docket Nos.

The Dow Chemical Company,

et a1

x

10

1I

415, et a1

vol~e

(This

~ages

contains

6875 throu9h

170~~)

I

12

14

Room 2~09
Environmental Protection Agency
Headquarters

15

Washin9ton,

16

Thursday, November 13,

IJ

D. C.
198~

I
I

I.

17,

-

I

I

401 t1 Street, 50uthlolest

18

I

The hearin<)

""dS

convenei'

pur~uant

to "ctjournmen-l,

19

at 9:00 a.m., before Administrative Law Judge Edward B.

20

Finch, when were present the

21

ON BEHALF OF THE ENVIRON:"ENTAL P~OTEC"'ION AGENCY:

follo~inq:

22

DOROTHY PATTON, ESQ,

Of~ice

2J

KARL BAYER, ESQ,

Office of Ceneral Counsel

24

MICHAEL NINER, ESQ.

Office of General Counsel

25

AN~RE\·1

Office of \.eneral Counsel

G.

GORDON.

1:50.

"1l:~1

0

rof""l<:<:

of General Counsel

(

(
JUDGE fINCH:

TS/Sl -1

'-'

17039

\"Ie will resume the hearing.

2

Hr. McConnell.

3

HR.

,

Our next witness is Hr. V. K. Rowe, Mr. Rowe

HcCONNELL:

Good afternoon,

Your Honor.

~ffairs

5

is the former director of Toxicological

6

and Environmental Research at Dow.

7

in 1979. but he is still active as a consultant.

S

9

of Toxicology,

He has,

II

EPA,

a~d

is a past president of the Society.

for OSHA and with the National Cancer Institute.

Hr. Rowe.
~'lhereupon

,
V.

K.

ROliE

15

was called as a witness and, having first been duly

16

was examined and testified as

17

IS
19

JVDGE FINCH:

Are there any additions or

corrections to your s aterrent?
TilE \V1TNESS:

Yes, I "have one reinor one, in

the educational section there, my

21

a\'Jarced in 1938, instead of

23

swor~,

follows:

20

22

Dow

in addition, served on advisory committees for

12

14

fr~~

Hr. Rowe ...las a charter merrber of the Society

10

13

He retired

and Health

JUDGE FINCH:

~laster's

Degree was

1)7.

Well, we want to make that change

then ....·here docs it aflpear?

2,

TH E I-IITNESS:

It's in my CV.

25

JUDGE FINCH:

Oh, in
l-lEAI

R

t~e

r.ROC;C;

cv.

\

(
5

1

Q

17054

And wOllld he be one of the people that may have

2

informed you that the careful medical surveillance was

3

being conducted?

4

5
6

7
8

9
10

11

A

I suspect that that

lS

the case. but I cannot

be certain.
Q

Do you remember what he told you, or what you

were told by people in the meetings?
A

Si~ply

that these people were being followed on

a periodic basis.
Q

You were not informed as to the tests that were

actually being conducted on these workers, \-Jere you?

12

A

I can't testify to that on a personal basis, no.

13

Q

Let's turn to the"next section of your \... itness

I~

statement.

15

sequent to the 19611 Chloracne Outbreak".

16

A

17

o

On page 5, which is entitled "Resei\rch Sub-

(Perusing documents.)

Yes.

This section of your testimony discusses

(I/~a I

18

experiments conducted by a Dr. ~ Kligman, which were

19

initiated and funded by Dow Chemical Company, is that

20

correct?

21

A

That's right.

22

Q

In these experiments varying doses of 2,3,7,8-

23

TeOD were dermally ap!"licd to the' forehead and back of

24

human subjects incarcerated at a prison at Holmesburg,

25

Pennsylvania, is that correct?
""CAl

0

r.onc;c:

(
6

1

",-,

=

A

17055

The test procedures were as you describe,

2

whether incarcerated is a proper word, I don't know, I

3

presume it is.

,

Q

They were prisoners, is that correct?

5

A

That's my understanding.

6

Q

You state, at the beginning of the bottom of

7

page 5 that you contacted Dr. Albert Kligman and then at

8

the top of page 6 you state,

9

the chlor?cnegenic potential, TCOO in

10

existing program",

~s

"Dr. Kligman agreed to test
h~ans.

under his

that correct?

I1

A

Yes.

12

Q

Would it be fair to say that you were the Dow

lJ

representative \... ho initiated'"' contact with Dr. Kligman,

I~

and requested that he conduct experiments in which human

15

subjects would be der1"lally exposed to TeOD?

16

A

Yes.

17

Q

Now, Dr.

Kligman conducted two separate sets

18

of

ests in ....· hich he apl"liec TeDJ to the skin of these

19

human SUbjects, is that correct?

20

A

You are talking about two different tests?

21

Q

Two different sets of experiments.

22

A

Well, there was one experiment to start with and

23

then there was a SUbsequent expcri~ent that he conducted,

2,

yes.

25

Q

Did you not de:iign the protocol for the first

,

(

-17

'-'

17056

1

set of tests conducted by Or. Kligman in which the re-

2

searchers applied a range of doses of TeOD to the backs

3

and the foreheads of 60 human sUbjects?

6

Yes.

Q

Has there a di! fecent protocol for the second

series of tests which Dr. Kligman conducted?

1

A

8
9

A

Hell, not to my knowlecge, that VIas his protocol

I did not know that this second experiment \las to be done

I

he way it •.·.. as done.

10

Q

On page 8 -- let's turn to page 8.

11

A

(Perusing documents.)

12

Q

In the second full paragraph on that page, near

Yes.

13

the bottom of that page, at the bot;.tom of that paragraph,

l~

you st.ate, "Accordingly, I indicated to Or. Kligman that

15

Dow would fund a continuation of his studies" and then you

16

go on to say,

17

receive a letter from Dr. KligY.1an reporting ne,... results".

IS
19
20

"In January of 196B, I \<as sur?=ised to

Coule you explain to us

wh~t

you mean by

"surprised"?
P.

Yes.

As much of the first protocol had yielded

2\

absolutely negative results, we did agree, at his request,

22

to fund a continuation, but I

23

the same progression that I had outlined in the first

24

instance.

25

writing . .;nd the next

assumed it would. be following

Unfortunately., that \>/as never confinned in
I

heard fror.! it

\oMS

that the results

18

\

(
I

17057

that he reported to me.
Now, each of these

2

s~eps

takes a considecable

If you will look at the protocol, because

3

period of time.

4

I was very concernerl that we approach this very cautiously.

5

And raise the dosage in increments so as not to exceed a·

6

level which would produce a threshold response.

7

The reason for that was that in our studies on

8

animals we had determined that concentrations of chloracne-

9

gens which produced an effect in humans, essentially always

10

produced an effect in the animals.
And if the animal work was not positive, we

1I

12

never had a

~aterial

that cause injury in humans.

Noy.', so what we wanted to do and II/hat \'Ie felt

13

1.;

""e should do was to attempt to determine the relationship

15

between the sensitivity of the

16

humans.

17

-- i t measured quantitatively, we determined that a certain

18

dosage level \'Ias the J71inilT'um required to procuce an effect

19

cn the rabbit's ears.

20

rabbit'~

ear to that in
(f1J1(l;,II'(.~~
After we had identified the material ~ad ~ e

But our evidence from practicnl
hu~an

I

e~?crience

Vias much more resistant, but \-Ie

21

indicated that the

22

didn't know ho\v much more resistant.

23

concerned ahout ,... hc}t the r:'largins of safety would be.

24
25

So, therefore,

had

J\nd ",Ie were very

the purpose of this study was to

increMentally increase the dosage,
NFAI

R

~o

GRO~~

th~t

we would be able

(
-19

1

to find out what that figure was.
Q

2

3

17058

You indicated to Dr.

Kligman that Dow would

continue its funding of the studies, is that correct?

4

A

That's right.

5

Q

And yet you assumed -- you said that you assumed

6

that he would continue to follow the protocol that you had

7

given him, is that correct?

8

A

Yes.

9

Q

Between the time you received the results of

10

Dr. Kligman's first series of tests,

in May and June of

II

1966;

12

he stated he had conducted a second set of tests, did you

13

have no contact with Dr. Kligman concerning this second

l-i

series of tests?

and the time that you received his letter in which

had none.

15

A

I

16

Q

You mean you had said that Dow would continue to

17

fund this study, and yet you did not bother to even con-

IS

tact Dr.

t·1R.

19

20

23
24

Your Honor, I ·think that questi0

f1cCONNELL:

may be a litti'e argumentative.
JUDGE FINCH:

21

22

Kligman to see what he was doing.

I

think it is, too.

He said he

did not.
You can answer the

gue~tion

'did you have any

contact between the time you got the results?'

./

25

THE \-JITNESS:

If I did, I have no knowledge of

NEAL R. GROSS

17059

1

I don't believe

it.

BY r-1R.

2

4

GORDON:

attention to what is

be~ng

done with the money it grants?

Well, it depends on what the situation is, this

A

5

did,

Does Dow normally fund studies and then not pay

Q

3

I

6

was a contract with the university and with a professional

7

dermatologist who had conducted the first series of protoco s,

8

he knew what my philosophy, with respect to testing was.

9

And it takes so

~uch

time, between tests, that if you

10

proceed according to the protocol, that I had designed,

11

t~at

12

about it.

I didn't feel it was necessary, and I didn't ask him

13
14
15

As
ca~e

report
Q

I

as i

said, it was a total surprise when the
t

Qie.:

Well, you say that Dow and yourself were con-

16

cerned with the margins of safety,what was the highest

17

dose level given

18

in the first set of tests?
I believe you can find the answer to that on

19

20
21
22
23

24
25

applied to the·skins of the prisoners

page 8, in Table 1.
A

Yes, that's right, the total dose that was given

was 16 microgram/kg
Q

per 'person,

'What was the total dose given in the second set

second series of. tests that Dr. Kligman had conducted,
in which Dow funded?

\

17060

(
1

A

7500

2

Q

So, Dr. Klignan went froQ 16 micrograms to

3

micrograms.~

7500 micrograms, is that correct?

4

A

That's what he says he did.

5

Q

So, he increased the dosage somewhere in the

6

neighborhood of 5,000 orders of magnitude?

7
8

A

something like that r wouldn't it?
Excuse me, I will make a calculation.

9

JUDGE FINCH:

10
11

NOr it would be closer to 40 "to 50, 45 perhaps,

That's all right, wait until you

get another question r unless you want him to.

12

BY MR. GORDON:

13

Q

Would you work that out for us, please?

14

A

Yes.

You are closer to right, it's abotit 470.

MR. McCONNELL:

15

Your Honor, if we ciight have a

16

clarification on the question, was that phrased in terms

17

of the magnification of the dose, or the" order of magnitud

18

of difference?

19

MR. GORDON:

20

the wrong terminology.

21

Magnification, I'm sorry,

THE vlITNESS:

I used

It's the difference between 16

22

and 7500, and if you divide 7500 by 16. you com~ ~ut close

23

to 470.

-

-----BY rlR. GORDON:

24
25

Q

Well, when you wrote the protocol" for the first
NEAL R. GROSS

\

(

17061

1

series of tests, you increased the dosage for each group

2

at what you would term a conservative amount, is that

3

correct?

4

A

That's r:ight.

5

Q

Would you call the increase that Dr. Kligman

6

conducted in the second of tests a conservative increase?

7

A

No, sir, I wouldn't.

8

Q

Did you -- had Dow ever funded studies by Dr.

9
10

Kligman previous to the ones that are discussed in your
testimony?

11

A

I

can't answer that, I don't remember doing any

12

of it myself, but Dow Chemical Company is a very large

13

corporation and it could have been done by the medical

14

department, or somebody, and I might not have known about

15

it.

....

16

17

Not to my knowledge.
Q

So, to your knowledge, Dow had no prior experien e

wi th overseeing Dr. Kligr.1an' s studies, is that correct?

18

A

I believe that is correct.

19

Q

So, upon what b3sis did you determine that it

20

was not important to oversee the second series of tests

21

vlhich he \Vas going to conduct?

22

A

I guess only that he was a professor of derma-

23

tology at the University of Pennsylvania, and we had

24

reasonable confidence that he

25

consistent with our original protocol.

wo~ld proceed in a manner
._-~--------~----

I
\

• "-' . J

UNITED STATSS OF

1 '

~~ERICA

2

'

• I'

••.•

•

L

~.

J
'

BEFORE THE

3
4

',
I,

(I:

l' ,

ENVIRONHENTAL PROTECTION AGENCY

5

6

-----------------X

7

In the Matter of the Hearing of:
2,4,5-T and SILVEX

9

The Dow Chemical Company, et al

10
1

Docket Nos. 415, et al

8

1

- - - - - - - - - - -

- X

(This volume contains pages 17066 through 17238)

12

...

15

Room 2409
Environmental Protection Agency
Headquarters
401 M Street, Southwest
Washington, D. C.

16

Friday,

13
14

17

-

IB

-

Nove~ber

14, 1980

-

The hearing was convened pursuant to adjournmens,

.
19

at 9:05 a.m., before Administrative Law Jud0e Edward B.

20

Finch, when

21

ON BEHALF OF THE ENVIRONMENTAL PROTECTION AGENCY:

w~re

present the

fo11o~irlg:

22

DOROTHY PATTON, ESQ.

Offic e

of General Counsel

23

KARL O. BAYER, ESQ.

Office

of

24

ANDREW G. GORDON, ESQ.

Office

of General Counsel

25

Ge~eral

Counsel

\,

\.

17087
1"
2

Was Dow not interested at all in seeing those

Q

resul ts?

3

'ole accepted the statements 'that he and his in-

A

)

4

ternistmade.

5

Q

Does Dow normally, when they contract'out to

6

outside experimenters, do they normally not bother' to

7

acquire the results of the test that the experimenter

8

perf orIlled?

9

A

It generally depends, on the

and we, incident-

10

ally contract out very little work -- but it depends on

11

what the purpose of that work is, where it is going and

12

what the ultimate end is to be.

13

work by constilting

14

done, was not done to the extent that it Mas done under

15

the present GLPs, where every data point has to be rnonitor-

16

ed.

Monitoring of laboratory

,

17

laboratories~

in the time when this

W2S

In those days we usually took what we considered

18

to be competent people and expected them to conduct their

19

studies in the normal course of their investigations.'

20

Dr. Kligman was a professor of dermatology, he is an M.D.,

21

he did

22

are his results, we did not question his reporting.

---..

23
24
25

lots and lots of skin work in those days. ~..nd these

Q
·inDr~

And

,··-·In'

the· ·second"series,of tests which is discussed'
7

Kligman's January 23rd letter, he reports that eight

of the 10 subjects developed chloracne,
NEAL R. GROSS

Did not Dow want

17088

1

to see the clinical te5ts that were conducted on these

2

eight subjects who did develop

3

4

A

chlo~acne?

I guess we really didn't think that it was

necessary to see them.

5

Q

Why did you think it was not necessary to see

6

the results of these clinical tests which were conducted

7

on eight human subjects which had developed chloracne?

8
9

A

Well, in retrospect

been nice to have seen them.

I

will say it would have

But in those days we took

10

their words that they had -- we had seen lots of chloracne,

11

it wasn't a new phenomenon to us.

12

Q

-

So for these human beings you are saying in

13

~etrcspect,

14

these clinical tests?

it would have been nice to see the results of

15

A

I think so, from a curiousity point of view.

16

Q

Just for curiousity's sake?

17

You were not

interested in the health of these eight human beings?

18

A

Well, of course we were --

19

Q

Then why did you not ask to see the clinical

20

results of the tests,

21

t-1R.

McCONNELL:

I don't believe Mr. Rowe had

22

finished his answer there, if I am wrong, I will apologize.

23

But it sounded to me like he was going to say something

24

more.

25

THE vlITNESS:

I was only going to say that

NEAL R. GROSS

\,

1

17115

follow-up on the health status of these three individuals?

2

A

I do not.

3

Q

Do yau,know whether Dow or Dr. Kligman has ever'

4

conducted a follow-up survey of the heal.t:h'status, of the

5

human subjects exposed to TCDD in Dr:. . Kligman'

.

6
7

9

Q

Do you know whether Dow has conducted such a

follow-up study?

10

A

Dow has not.

11

Q

Dow has not?

12

A

Right.
HR. GORDON:

13

14

·t~sts?

have no knowledge of that.

I

8

5

Not.tomy knowledge, I do not know that be has,

A

no.

.

Could" I have just one moment, Your

Honor?

15

JUDGE FINCH:

16

MR. GORDON:

Sure.
I

going to provide the witness,

am

17

and Counsel with Exhibit No. 15, entitled; "Resu1ts of the

18

Two-Year Chronic Toxicity and

19

Tetrachlorodibenzo-p-dioxin,

20

a1.
MR. McCONNELL:

21
22

Exhibit' 13?

MR. GORDON:

24

BY

Q

TcnD

Study on 2,3,7,8

in Rats" by Kocib~, et

Did you say Exhibit 15 or

I believe this is Exhibit 13.

23

25

Oncogen~city

Oh ,

I

meant to' say 13, yes.

MR. GORDON:

Are you familiar with this document, Mr. Rowe?
NEAL R. GROSS

1

A

I am generally familiar with it, not in detail

2

beccu5e I am not a pathologist and I certainly don't in-

3

tend to get into pathology.

4

Q

Let's look at the abstract on the first page,

5

~n

6

"Ingestion of 0.1 ~/kg/day caused an increased incidenc~

7

of hepatocellular carcinomas and squamous cell carcinomas

8

of the lung, heart, pal2.te,

9

whereas a reduced incidence of the' pituitary, uterus,

10

the seventh line from the top, does it not state that

nasal turbinates, or tongue"

mammary glands,· oancreas and adrenal

gland was noted"?

11

A

Yes.

12

Q

After you became aware of the oncogenic effects

13

of'TCDD reported in the Kociba Study, did .you or Dow con-

14

sider whether the human subjects you had exposed to TeDD

15

had develop~d cancers in the years subsequent. to ~he con-

16

duct of the study?

17

A

We have not followed up on that.

18

Q

Did you consider whether the hlli~an subjects had'

19
20

21
22

developed cancers from the study in 1966?
A

I don't remember entering into any discussions

on that subject.
Q

Well, you had entered into no discussions as

23

to whether these human subjects had developed cancer,

24

had you considered that they might have developed cancer

25

on your own?
NEAL R. GROSS

bU~

-/
.

/

V.'

.

.

48640

July 9, 1965
'.".

Albert M.· Kligman J M. D., Ph. D.
Depa~tment-of

Deroatology
Hosp! tal of the Ulii ve:-~l tr of

36~h

and Spruce Stre;t~
?hiladelphia 4 , Pennsylyan1a

?,~nIi~ylyanla

Dear Dr. Kligman:
sepu~~~~ ~over a 3m~11 a~ount of
2,3,(,8-:etrachlorociibe:1z.o-p-d.l.cx:":1. 'l~1~ 1.:::) !;~le material
\'ih1.:r. 1~ a potent acnegen a~c ::.: bl.6j11· ~oxi=. 1 have
checked b~ck on ou~ figure5 ~nc riu~ th~t t~e single dose
oral LD~ for rabbI~s 1s In :h~ n~lGhbo~h~Od or 100 microgra:~:/k~2c3r2rC, and. we had -:>r;e .:.rJi::l~l .cie 'lihich h:ld received
a 5in ole dose or 16 ~ic~O~~~~~/~:l~gr~~. I~ 1s safe to ~aYJ
howevc~, that doseG of 0.5 ~~ :.0 mg~A~ are a1wa1~ fatal,
although deaths may be del~ycd ~~r 10 to ~O ~ays po~t treatcent. The typical cl:~1cal p::~~:-~ 1~ seYe~e liver and
kidney inJury ..

1 am sending you under

In regar-d to the ~kln r~sp~niJe ~rJ r~bbit~, \O;e ha'le attem?ted
to q~~ntit~te thi~ by appl¥~~g C.~ ~l cf t~~~ ~ulu:l0~ to one
to t~o square inchez of the ~UI~~~C of the lnn~~ f~ce or the
rabbi~ e~r .
..Ie find th~t ~'Jbe:1 ~h.: :0:01 oo::c (~vCS not exceed ~bcut O.2·of a mi~ro£ra~ ~r ~h~ dcr.~se~, no follicular
?~vi.11:)encc

0:- epi:.h~l:<ll br;:H=:"';)l.~:.'~':;'t, de·i~lo?::.

total dose 13 about 0.5 of ~
respo~se is m~~ginal; 1 to 2

d:uce:; a re~ponse, ::.nd 4 to

8

~l~r~g~~~
~i~~csr3rns

:~lc~O"'~~a:no

on

th~5
~lm~~~

\\'hen the

area, the
al~ays

pro-

usu;llly produce 'l
been able to quant1tate

r:evere re~pons~. ~e have nc~ 3~ y~t
the d~se required ~o cau~e 5C~ ~or~~llty rro~ ~kln ex?osu:~~
b'.Jt we ar-e ~ure 1 t 19 \"iell ~bove ~he t.u,,:-al do~~ge:3 noted above.
In ·.;1e:w or thIs info:--:1J. -:ivn, 1 t, C·:-·~~i not ~eem probable that
the dozagee :;hown in :h~ acc~~?~~¥1:15 s'.J~gc~:cd pro:ocol for
~h~ hum~n i;or~ \OJould be likely :0 ,,,:;Jr,:tlt.:Jte ~n7 ~erious
s,stcr:lic h:lz~:'d bc:ca~Jsc ~te c~')~~ ~n cJ P~I' !'llogra!n ba~1s
would be far b\?lo\-1 ~h<.lt ~':(!1cl1 prud~ces ~ny ~1gn':'!'lcant effect
eystel:lcal11 in the l"2bbit. I f:)l~ht add o;h.:>.t the rabbIt :"
f3r ~cre c~ns1tlve thun the r~t to th~~ ~¥~~ or compound.
M~ver~hclc3~, the s~rlou:nes= of :hc ~vn~cqu~nce~ that mlght
develo frou testing wIth ,this type or cOfopound requIre that
~e approac
t.e ~~:ter n a
£
vc canne~.
t
.:.

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M. lCl1gt!1an, M.D.

- 2 -

July 9, 1965

1s with th1s thought 1n mind that I have developed the
attached protocol . . The numb~r or persons per e:q'J~_r.i:ue-.nt.
1s your dec ;~_1t?n;. _~__ .~~uld ~_~_~~_~t __ t~~~ .. as _ ~_ s tarte;-~. 'Jhen
ap~11catlon8 are. repeated, I would l:ka to have them·made
on consecutive days J if i t .1~ convenient to do so. Although
the time regt11red to· conduct thc~e experlments w111 'reQuire
several months J I believe. 1 t ~s the ..~_~~e wa y to p·roceed,
.usIng a._rew.p~ople at a t1me with cnreful ~bservatlons on
each. . The observat10ns ~re ~o be made at your di5cret1o~,1
1 ~ut I would urge routine SGOTlc and alk~llne ph08phatase5~

~s

a

.

ru1n1~um.

1 s e:1other !. te:n upon \-IhL.:h comment should be made.
I
1n the ~u3ge~~ec p~otocol that a two week obser..?Cl t,ion periOd Shou4.c be u~~d pri;Jr to star;~ing the ne):t
ser~e~ of ~x?crloen~~.
~i~ ~~ becau~e our ex?~rience with

The:'~

indic~ted

have

both anl~als and ro~n 1r.d~cates tha~ there 15 un induct10n
pericc . . In ~ few ::l:;ta:l~~:;., ·.... e believe an eruption in the
hU~3n has d~velopeJ four ~~ ~ix ~eeks post exp~sure.
Also,
we have. had a r~w 3eri~us fl~re-up5 which'have develcped
within a r.J.:ltt.er of day~, OP:':j":. cxpos~re.
! haole cOMp:-omised
0:'1 a ~,",o-week ob~er'w"a:'iojj r'~:"iOc, b\lt or co-ur:=:e, any treated
1~d1vidu~1 should be ~~:chect fo~ ~~ l~ast t~o mon~h~ post
tes~.

You asked about rna~e~i~l~ i~ fihich th~5 te~t ~~bstan~e is
soluble. 1 have iud~ca~~d i~ ~s qUite solubl~ in chloroform ~nd cc-nze nc ~nd d11.30t 17 ;;", ~l ~.;"o le 1n ~ 1·.; ~r.:, 1 .
I believ~ tha:. a co1:..ltio:1 1~ 5C/:.O ~lc:'hol ..lrH~ ci~l.)rofo~w \"lould
~e quite appropri:J.~e for YO':;':" Y\o:-~c.
l:J r'..:g~1·d :'0 covering
he exp~sed area, I would :;"Jgg';~j~. ~hal; '..:h!~n t.he t!'eated

U
has

dr1e~ th~t

it

keep :he r.lat?rial
contarci:;ate h13 h03.r.c:3 or

r

areaJ

~~vered l:g~tly w~th ~ gauze S1~ply to
f:--om be!n£ b_"uSIT-;d a~'/ay or hav1ng a person
~e

clfj~.hing

inadvertentlj--.

--

I have an3wercd your q~e~tlons, b"J: if you have any
~thorz, plca~e do not hes~tate t~ ~on~~ct ~e.
h0?~

':':lncercly

v.

YOIl!'~,

K. Rowe

Bioch~~lcal

Re~eurch

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Bioc!-'.~~iC2ol Resea.::"cn La~ol"2otory
!~03

B'-lilcing
The Dow C r.err.i cal Com?an Y
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