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4
C&EN July 28, 1980
Letters
Getting the act together SIR: Your editorial on "Getting the act together" (C&EN, June 23, page 9) was sorely needed. It is only one plea of many which heretofore have gone unheeded. The recently published regulations, such as the one the Occupational Safety & Health Administration has promulgated on "Access to Employee Exposure and Medical Records" and the one the Environmental Protection Agency has finalized in the "Resources Conservation Recovery Act" are good examples of regulations which are going to add great costs to industry and subsequently to the public. However, it is argued by the agency that the information should be available with little or no additional cost to the manufacturer! Only if we have a President and Congress dedicated to the premise of your editorial will reason prevail. There is no choice on the part of industry but to bow to all their demands, which we are doing for better or for waste. Unfortunately, most of the media use scientific information without learned judgment to misinform the public with spectacular and scary information that may or may not be pertinent to any particular situation. This has been done time and time again, which only incites adverse political action. I am afraid it will be a long time before we really see an "Age of Reason." L. T. Eby Associate Director, United States Gypsum Co., Des Plaines, III.
Patentable life forms SIR: You have an unduly pessimistic antitrust attorney as a source suggesting the control of gene-splicing technology by a few corporate giants (C&EN, June 23, page 10). There is no evidence that one or more of these "giants" have acquired basic patents on the techniques of gene splicing, and there would be little profit in refusing to license basic processes as they are developed. Moreover, processes for the production of microorganisms have always been considered patentable subject matter; the Supreme Court's decision in the Chakrabarty case was directed solely to the patentability of living microorganisms per se, i.e. the manufactured products having new and unobvious properties. Smaller companies may well have the talent as well as the facilities needed to produce valuable new microorganisms. In the furor generated by the Supreme Court ruling, the patent system has been attacked as though it were responsible for creating the problems and dangers of genetic research, and as though no research would be carried out without patent protection. In fact, the patent system is of unquestionable value in obtaining prompt and full public disclosures of all work being done in recombinant DNA industry, including new and improved safety measures. If all genetic research were done under a cloak of secrecy, i.e. by adopting the use of trade secrets as the only alternative to patents, how then would Congress or the executive deal with the
need for regulation and control? We should recognize the importance of the patent system as a tool for solving a difficult problem, rather than being part of the problem itself. Chicago John H. Shurtleff
Be slow with bromocryptine SIR: Before anyone goes rushing off to try the aphrodisiac delights of bromocryptine (C&EN, June 23, page 86), I think it should be noted that this substance has been used as an experimental medication in the treatment of Parkinson's disease/syndrome; as such it has been found to have some rather unpleasant side effects, one of such being a potent hallucinogen. My mother was given it in late 1978 and the hallucinogenic effects lasted for over six months. That is definitely not my idea of "reasonable." Allan R. Brause Senior Food Chemist, Kroger, Cincinnati
EPA's action on NTA SIR: The Environmental Protection Agency's action on nitrilotriacetic acid (C&EN, June 2, page 6) is, in my opinion, immoral and irresponsible and should be reversed immediately. Further, I think Congress should investigate the "agency priorities" on which the decision was based to see if they are in conflict with the mandate given to EPA under the Toxic Substances Control Act. As an industrial chemist, I deplore the bad press the chemical industry has been getting of late when I know that our industry contributes more than any other to the comfort and wellbeing of the general population. However, we can expect nothing but condemnation if some of us continue to ignore the welfare of the public for the sake of profit. Norwalk, Conn. A. J. Gustavsen
Aquatic toxicology SIR: I am intrigued by the article in C&EN, June 30, page 18, on aquatic toxicology, and especially by the statement that "An independent aquatic toxicology testing industry also seems to be emerging . . . . " My own company has been conducting such tests for clients since its formation 10 years ago, and I know others who have engaged in such work commercially for decades. This is because a number of responsible companies in the chemical industry have been using bioassays as effluent monitoring and control tools for a very long time—far longer than such testing has been the requirement it has now become in many NPDES discharge permits. A historic series of bioassays on a particular effluent using an aquatic test organism obtained consistently from the same source has considerable value as a tool for effluent treatment control, but the entire procedure—testing and Continued on page 90
ufacture, cumene oxidation to cumene hydroperoxide and phenol production, morpholine, anisole, benzyl chloride, benzal chloride. Sheldon E. Frey, 404 Kings Highway, Moorestown, N.J. 08057. Phone: (215)923-3970. Organic-Toxicologlcal Chemist: Skilled in G.C., H.P.L.C, I.R. U.V., N.M.R. etc. Experienced in drug-assay, syntheses, identification of trace organics. Having training in G.C.—M.S. Available immediately. Contact (914) 476-3038. Box 405-C-6, ACS, 1155-16th Street N.W., Washington, D.C. 20036 Chemist B.S. 1979: Seeking entry level position. Have experience with GC, IR, UV, AA, FE, Voltammetry. Organic, Inorganic, Quant, Qual Analysis. Will relocate for the right position. No agencies. T. A. Lee, 363 Bellflower Ave. N.W., Canton, OH 44708. Phone: (216)453-2331. Chemist—MBA: Experience with dyes, pigments, resins, solvents, and some adhesives. Have supervisory experience both in lab and processing. Looking for position as Lab Manager, Product Manager, or other responsible position with good possibilities for future advancement. Will relocate. Box 407-C-6, ACS, 1155-16th Street N.W., Washington, D.C. 20036 Laboratory Chemist: M.S., UC Berkeley, 1975. Analytical, environmental, water chemistry, water/wastewater analysis and treatment, especially boiler chemistry. 5 years college teaching experience. Relocate most of western U.S. Brian H. Nordstrom, 1619 Mary C Drive, Napa, CA 94558. Phone: (707) 255-7968. Sales/Marketing Management: Profitable sales, dynamic marketing, business expansion, new product/market development. Resins, polymers, chemicals, additives, plastics, rubbers. Very profit-motivated, results-oriented, creative chem engineer seeks challenge to contribute. Experienced industrial markets, N. America/Europe. Box 410-C-6, ACS, 1155-16th Street N.W., Washington, D.C. 20036 Analytical Organic. Ph.D.: Strong instrumental background particularly in GC/MS but including GC, HPLC, UV, IR, FLUOR, etc. applied to clinical chemistry and therapeutic drug monitoring/toxicology. Experience at supervisory level in 600 bed metropolitan hospital. Seek similar or related stimulating position; available immediately. Box 401-A-6, ACS, 115516th St. N.W., Washington, D.C. 20036 Organic/Polymer Chemist: M.S. 1980, experienced in RIM urethane Elastomer and also worked in Paint and Plastic additives. Mfg. Intend to work in polymer processing lab or R&D. Box 403-A-6, ACS, 1155-16th St. N.W., Washington, D.C. 20036 Formulation—Technical Service: MS 1955. Experience in technical service and formulation development of release agents, emulsions and dispersions used by the agricultural, chemical, food, petroleum and other industries. Some pilot plant operating experience. Seeking a development or technical service position. Box 405-A-6, ACS, 1155-16th St. N.W., Washington, D.C. 20036 Inorganic Chemist: Ph.D. Industrial and academic experience. Background in photographic science, inorganic synthesis, organometallics, catalysis, instrumental methods. Excellent problem solver and effective communicator. Seeks a challenging position in industrial or government research and development. Contact B. Flynn: 40 Johnson Avenue, Binghamton, NY 13905. Phone: (607) 723-7014 Polymer/Organic Chemist: Ph.D. 1976. Cationic polymerization of various olefins and heterocyclic monomers. Ziegler-Natta polymerization of Dienes. Synthesis, characterization, modification & processing of polymers, copolymers & graft-copolymers. Experience in engineering resins, elastomers & thermoplastic elastomers. Desires challenging research position with supervisory duties. Four years of industrial experience. Publications and patents. Box 404-C-5, ACS, 1155-16th Street N.W., Washington, D.C. 20036 Physical Organic Chemist, Ph.D., 1979: Experience in Pesticide Chemistry (synthesis, residue, analysis, and photolysis), interaction studies of halogenated hydrocarbons with bases, natural products (isolation and structure elucidation). Proficient in GC (tô, ec, fid), HPLC, NMR, UV, IR, Raman and Rayleigh scattering, AA, and some biochemical techniques. Dr. Kashinat Nag, Dept. of Chemistry, Fordham University, Bronx, NY 10458 Consultant: Extensive background in oxidations of petroleum fractions. Down stream products are rust-preventives, lubrication and fuel additives, coatings and a variety of automotive packages including car undercoatings. Box 407-C-5, ACS, 1155-16th Street N.W., Washington, D.C. 20036
in the areas of catalyst research, catalyst manufacture, plant liaison, and patent liaison. Call or write James R. Owen, 1918-333-4608, 2413 Summit Rd., Bartlesville, OK 74003 Consultant: Retired organic chemist Ph.D. with over 30 years in research direction and industrial operations. Available for consultation in organics studies and manufacturing processes for compounds of pharmaceutical interest. Box 413-D-7, ACS, 1155-16th Street N.W., Washington, D.C. 20036 Engineering Services: Operations research, development, applications, management. Thirty years experience in petroleum, chemical, and computer industries, North America, South America, Europe. Expert in computer control of industrial processes, energy and environmental applications, instrumentation. Master's publications, patents. Box 414-D-7, ACS, 1155-16th Street, N.W., Washington, D.C. 20036 Retired teacher (1979) available for period January to June, 1981. 32 years experience teaching General and Physical at Wittenberg University. Level of salary not of great importance if department is actively interested in good chemical education. Dr. Paul K. Glasoe, Route 1, Box 140, Sarona, Wl 54870 Consultant: 40 years industrial experience. Expertise in reverse osmosis, ion exchange, and water treatment technologies, and in the synthesis of resins and polymers that can be used in them and for other purposes. James R. Dudley, Ph.D., 12656 Cijon St., San Diego, CA 92129
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C&ENJuly28, 1980
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Letters Continued from page 4 use of results—is wholly empirical. To my thinking, this will not change. Any organism brought into a laboratory environment is subjected to incredible stresses, most of which cannot even be defined, much less estimated. Many fish and invertebrates, for example, will not survive capture, handling, or transport. Thus, species of organisms which do adapt to captivity are the really tough ones, are living on the ragged edge, and in no way represent the average situation in the wild. For example, D. W. Hood and I showed 25 years ago (Texas A&M Research Foundation, Project 112) that simply transferring a stable algae uniculture from a small flask to a large container resulted in a "transfer shock" expressed as near cessation of photosynthesis for 24 hours or more. From this, it follows that any test represents simply the imposition of a more-or-less definable stress on top of a series of standing, but unknown stresses, all being directed at a very tolerant subject. We can gain a measure of the differential and can sometimes gather kinetictype data, but nothing more. Surprisingly, this differential, expressed as LD50, is not necessarily as variable as one might expect when tests are made on a diversity of organisms such as several types of shrimp and a variety of fish. This emerged from some work we did a number of years ago with standard toxins for clients who wished to make submissions to various agencies relative to proposed rule-making. One major flaw in present-day applications of aquatic toxicology to hazardous discharge control is that the wrong targets tend to be selected. Test animals are usually higher organisms, predominantly fish. Obviously, this derives from a desire to avoid fish kills, which are unquestionably a nuisance. Barring a major wipeout, such as the Mississippi episode, however, the killing of a number of fish is, ecologically, a trivial thing. Such losses are replaced quickly, either by recruitment from adjacent populations, or by enhanced survival of the next brood. Far more consequential is an attack on the phytoplankton population, which is the primary producer for aquatic and marine food webs, or on the zooplankton association, the primary consumer. Unfortunately, plankton toxicity assays are conducted only rarely, even though discharge rates and application limits for various materials, set on the basis of toxicity to higher organisms, may lead to devastating effects at the primary producer-consumer level. Please understand that I support heartily the increasing emphasis on toxicology as a monitoring tool. Many of us were advocating years ago that this control parameter should be used instead of the host of tests for heavy metals, phenolics, etc., that were imposed on the industry. But do not expect this tool to be something that it is not, a microcosm of the real world, and be aware that the "carcinogen" phenomenon is loose among us as techniques are developed to detect ever smaller stress increments. Also be aware that mammalian toxicology is still largely empirical and has yet to solve the white-rat-vs.-white-mouse response dilemma. Walter Abbot President, Environomics, Houston