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Thirdly, as stated by Mr. Peter Miller and the undersigned at the June 30th conference with the Committee Staff, the Associations forming the London Group are made up of shipowners who mutually insure one another, and they therefore can and do insure against liability for fines and penalties imposed on them because of faults of their masters and crews, provided they are reasonable in amount. Thus, the Associations presently insure against liability for the fines and penalties now provided for in the Water Quality Improvement Act of 1970 On the other hand, it is obvious that the Associations could not cover fines or penalties relating to those substances of the extra-hazardous variety, when in no event would they be able to cover civil liabilities with respect to such substances. In short, they could simply insure against fines and penalties relating to those hazardous polluting substances in respect of which they would be affording coverage against civil liability for damages, again provided they were for reasonable amounts. The example given verbally at the June 30th conference was a penalty of not less than $5,000 nor more than $50,000 for the discharge of an unremovable hazards polluting substance, other than one of so extra-hazardous a nature as to be altogether beyond the scope of mutual shipowners' protection and indemnity insurance.

Again, we wish to express our appreciation for the opportunity to set forth the views of the London Group. If there is any further information you would like from us, please do not hesitate to let us know.

Yours very truly,

NICHOLAS J. HEALY,
GORDON W. PAULSEN,
JAMES J. HIGGINS,

Attorneys for the London Group

of Protection and Indemnity Associations.

M & T CHEMICALS INC.

(Subsidiary of American Can Company)

Senator EDMUND S. MUSKIE,

M & T CHEMICALS INC.,
Rahway, N.J., July 30, 1971.

Chairman, Subcommittee on Air and Water Pollution,
Committee on Public Works,
Washington, D.C.

DEAR SENATOR MUSKIE: The proposed amendments to the Federal Water Pollution Control Act, on which your subcommittee is working, recently came to our attention. On page 26 of the working paper released on July 1, 1971, tin is listed among heavy metals designated for severe prohibition. As a company that has been involved in the recovery and recycle of tin from waste sources since 1908, we have accumulated detailed information on the presence of tin in water, soils, plants and animal organisms. We also have a great deal of scientific information on the toxicology and safety of tin as well as on its fate in the environment. Practically all of this data points to tin as an exceedingly safe and innocuous element. It clearly does not belong with the other heavy metals and we are wondering how it got onto the list of prohibited metals.

Indeed, tin chemicals are well known food additives which have been duly registered with the Food and Drug Administration at which time their safety had to be demonstrated.

In order to assist your subcommittee in making some judgments in this area, we have reviewed and reported on the pertinent scientific and technical information relating to tin in the environment. A copy of this report by M. K. Moran entitled, The Environmental and Public Health Aspects of Tin is attached. We request that this report be included in the proceedings of your subcommittee. After reviewing the environmental implication of the report, we trust that your subcommittee will see fit to delete tin from the prohibited list.

Should your subcommittee desire further information we will be most pleased to cooperate with you and to supply you with additional data which you may require.

Sincerely yours,

Attachment.

ALEXANDER Ross, Technical Director.

THE ENVIRONMENTAL AND PUBLIC HEALTH ASPECTS OF TIN

PREPARED BY MARGUERITE K. MORAN, MANAGER, TECHNICAL
INFORMATION, MARCH 1, 1971

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A. Levels of Naturally-Occurring Tin in the
Environment...

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B. Possible Conversion of Tin in the Environ-
ment to Organotin Compounds....

C. Regulatory Controls or Recommended Controls
on Tin in the Environment..

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III.

A.

Tin Levels in the Animal Organism.

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Studies on the Toxicology and Biochemistry
of Inorganic Tin Compounds....

Government Approval for the Use of
Inorganic Tin Compounds as Food
Additives and in Food Packaging and
Processing...

C. Reports on the Therapeutic Applications
of Inorganic Tin Compounds..

Effects of Tin in the Animal Organism.

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C.

Recent Studies on the Beneficial Effects of
Tin in the Animal Organism.

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A. Levels of Naturally-Occurring Tin in the Environment

Tin is present, and has been present for centuries in soils (mainly as cassiterite), and in waters, with no indication that its presence is harmful to life. It also occurs in sizable amounts in the air of industrialized American cities, again with no adverse reports.

Data on the levels of naturally-occurring tin in the environment are not so extensive as for some of the other metals. In telephone conversations with Dr. John V. Lagerwerff (2.8.71), Soil Scientist at the USDA Soil and Water Conservation Research Division in Beltsville, Maryland and in a subsequent conversation with Mrs. Helen Nace, a scientist at the United States Geological Survey, they indicated that there is no interest in tin due to its non-toxic and innocuous nature. Consequently, large scale studies have not been carried out, as with mercury. The best current reviews on the geochemistry of tin have been written by Hamaguchi et al (35, 36) and by Wallihan (99). The levels of tin in plants and marine organisms are also reported by Hamaguchi.

Although analytical data are not extensive for the tin content in soils, the orders of magnitude are indicated. Millman (49) found tin concentrations in soils in southwest England as high as 250 ppm.; Laycock (45) found 1.3 to 3 ppm. in tea soils of Nyasaland; Prince (62) found concentrations of 1 to 11 ppm. in various New Jersey soils; Sarosiek and Klys (74) found 0.0481% tin in the agricultural soils and 0.0051% in natural soils in Poland; Fontana and Alfieri (33) found 10 - 25 ppm. in soils in the Piacenza district in Italy; Chao-Luen Fang et al (17) found an average of 6 ppm. in 360 soil samples in Northeast China and Mongolia; Allison and Gaddum (1) found no tin in 54 cultivated soils from Florida and 52 samples of soil from other states (Sn was probably present but at levels below the spectrographic sensitivity for the wavelength region employed); Mitchell (51) found up to 200 ppm. in soils from Northeast Scotland; Pinta and Ollat (61) found an average of 6 ppm. Sn in five tropical soils.

Millman (49) concluded that concentration of tin in plant tissues is not related to the concentration in the soil and that tin is not concentrated by plants due to its occurrence in soils as the stable mineral cassiterite. Vanselow (97) grew orange seedlings in Florida soils to which tin had been added as stannous chloride at a concentration of 150 ppm. tin. No tin was detected spectrographically in the plant (sensitivity of 1 ppm.).

ppm.

In common igneous rocks the average tin content is 2-3

There is little reliable information on the concentration of tin in sea water. Neutron activation determinations of tin in the Pacific Ocean range from 0.30 to 1.22 μg/1. with the average 0.81 (35). Noddack (54) reported a value of 3.8 μg/1. for the tin content of sea water.

Averages of tin in different types of oceanic sediments were determined by Hamaguchi (35) as follows:

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Spectrographic analyses carried out by Kleinkopf (42) for trace elements in 439 Maine lake and stream waters showed less than 0.01 ppb. Sn in 336 samples with an estimated average value of 0.03 ppb. for the Maine lakes. In studies with municipal waters, Durum and Haffty (25) found 1.1 and 2.2 ppb. Sn in two samples of municipal waters from 42 United States cities and Taylor (92) found 0.8- 30 ppb. Sn in 32 samples from 175 finished municipal waters. (Note: this last reference was picked up in Hamaguchi's review (Handbook of Geo. 1969) but is obviously a wrong citation. Wrote to author to clarify.)

Sizable amounts of tin occur in the air of American cities, especially those heavily industrialized. Amounts from 0.003 to 0.3 mg/m3 were found in 60.6% of 754 samples taken from 22 cities (90). of 312 samples from six major industrial centers, 17% had 0.03 0.3 μg/m3 with considerably less in suburban areas. The tin content of unpolluted air is not known.

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