PCBs AND ASSOCIATED AROMATICS 855
At this point in time (1971), the Government had no
direct regulatory authority to control the manufacture,
distribution or use of PCBs. However, the Government
did possess ‘persuasive’ influence and, beginning in 1970,
Monsanto had begun to reduce the sales of PCBs and
‘voluntarily’ discontinued sales for use in paints, plasticiz-
ers, sealants, adhesives, hydraulic systems and other ‘open
systems’.
The principal recommendation of the Interdepartmental
Task Force was the discontinuance of all uses of PCBs except
in ‘closed systems’ such as transformers and capacitors. This
decision derived from an analysis of the benefits of PCBs,
the economics of fluid replacement and the availability of
substitute fluids. Non-electrical uses in open systems were
viewed as either not essential, potentially or actually con-
tributory to the environmental load, or had suitable replace-
ment fluid alternatives.True regulatory control by the Government in 1971 was
limited to persuasive influence. The gap between persuasion
and regulation was closed by the enactment of the Toxic
Substances Control Act.
In summary, the factors which led to the successful regu-
lation of PCBs were as follows.- Only one manufacturer was involved and end-
users were easily identified. - A model for the rates and routes of dissipation of
PCBs into the environment was developed and the
benefits of PCBs were weighed against the risks. - Scientific information underwent several peer
reviews and was widely disseminated. - The rule-making process was an open one which
education both the regulators and the regulated
communities.
FIGURE 9 Time-line for the development of PCB regulations.C016_003_r03.indd 855C016_003_r03.indd 855 11/18/2005 1:12:24 PM11/18/2005 1:12:24 PM