Document 6bjkywpGV91k43n8BbywY80rm

June 6, 1928 Mr. E. w. Webb, Ethyl Gasoline Gorp., 25 Broadway, New York City. - Bear Mr Webb; In accordance with yesterday* s conference with Mr. Beaumont Parks and yourself, I am forwarding a report on the condition of certain mixing plantB of the Standard Oil Company of Indiana, together with ay recommendations. I should appreciate it greatly if you would im press upon Mr. Parks the danger of further procrastination and the necessity for prompt action, I do not wish to be unneces sarily insistent, but previous diplomacy has been of little avail and I cannot but feel that Mr. Parks* agreeableness of yesterday was based upon his wish not to be discourteous to you, rather than upon any friendliness to our ideas or any acceptance of them in spirit or in fact. If I am correct in my judgment the entire matter will b allowed to drag on as it is till it is too late to anything about It this year, in which case It will be necessary to go through the same process again. I believe that you are the only one who can avert this, and the unpleasant ness that will follow, since I am determined to take any measures that are necessary to prevent the Continuance of these equipments under my responsibility through the summer and fall* I am sending you a copy of a letter I wrote Mr. Parks on this subject in September 1927. You are at liberty to use the material in this letter and in my former report to you in any way you choose in order to bring to Mr* Parks an understanding of the _ responsibility he is taklpg If he denies to his employees the. ' safety to which they are in all fairness and decency entitled. Very truly yours, RAK:EJ H E 0001263 Report on Conditions In Heed of Correction and Recommendations for Such Correction at Various Mixing Plants of the Standard Oil Company of Indiana SUPERIOR Due to previous leaks and dripping of Ethyl Fluid, the odor of Ethyl Fluid Is noticeable at all times around this pump* The metal pan in which the drum sits is not large enough to protect the area In which mixing is done. Thus Fluid Is likely to be spilled on the wooden'floor..o f .the platform* The equipment, consisting of hand pump and tank car loading apparatus, necossitates almost daily use during the summer and fall months# This daily exposure to an hazard {inhalation}which cannot be obviated entirely by this type of apparatus constitutes a dangerous situa tion. It should be corrected by discarding the hand pump and using the eductor system and a tank storage* This would do away with the dangers of leakage to a very large extent, and at the same time cut down exposure greatly by increasing the interval between mixes* At the same time the mixing platform (not necessarily tliat portion used for storage) should be covered with sheet metal so that it can be properly cleansed, or it should be made , of concrete at this point* Until this is done gas masks must b used constantly at this point while Ethyl Fluid is being pumped* This is not being done at pre sent* In fact, gas masks have never been used at this point. GREE1J BAY The same condition exists here as at Superior, except that gas . masks are used at times* The same things need correction, and in exactly the same manner* There is evidence at this point of absorption of lead on the part of the employee who does most of the mixing. Barlement shows a higher than normal lead excretion from time to time, together with a faint lead line# BAY CITY - The same conditions exist here also* In addition, the inadequate equipment is in bad condition, showing leaks at several points. These leaks have occurred frequently before, and this has always been an unsatisfactory apparatus* Here also the equipment is closed in in such a way as to trap the vapors during the period In which the apparatus is not In use* Spillage has Occurred fre quently inside the enclosure, and the odor of Ethyl Fluid is very strong* Mr. Smith, the employee who does most of the mixing, shows some anxiety as to the dangers of mixing, and exercises great care In the use of his mask. The fact remains, however, that this is a dangerous equipment. Smith haB shown high lead excretion, but at present does not, due to his present carefullness. Bay C<ity (cont) This entire installation should be torn out {with great care) and completely discarded* Including the end of the platform, on which the pump has been operating* The present apparatus should be replaced with an eductor bulking system, or should be abandoned* RIVER ROUGE The system here is better than those previously described In that it Is a bulking system. The odor of Ethyl Fluid is noticeable around the pump when the Fluid is being pumped into the gasoline line, however, and the platform is not properly covered with metal* Furthermore, the bathing facilities are so poor or inconvenient that they are never used by the workman. Ewers has shown evidence of lead absorption for some time in an inconstant but significant amount of stippling of his blood corpuscles* This equipment can be greatly Improved at small expence by the installation of an eductor and proper line to and from it. The platform should be concrete at the end where the eductor is installed* It can be made reasonably safe by means of sheet metal covering* V;HITI!IG The smell of Ethyl Fluid Is noticeable around the platform ' when mixing is not being done* This Is due largely, If not ' entirely, to the hand pump, which like all such pumps shows small leaks, and cannot be completely cleaned* The plat form has the usual small metal pan under the drum, instead of a covering in the entire mixing area* Mixing is carried out here on an average of twiee a week, at which time 12 to 20 drums of Fluid are used* This suggests that the storage facilities are somewhat inadequate to care for the bulk of materials handled through this plant* It would be much better If the Intervals between mixes were greater* There is evidence of undue exposure in this plant since both Muhlenbruek and Gilette show faint lead lines* The correction of this plant may be made very simply* The hand pump should be completely discarded* The platform should be covered as recommended in previously discussed plants* It would be a great Improvement, however, if a > concrete and steel platform, capable of complete cleansing were used at this point* This plant handles more Ethyl Fluid and mixes more Ethyl Gasoline than most mixing plants In various parts of the country. Yet its facilities are far from being among the best to be found* It could, with advantage, be made an ideal mixing plant# By all means. Storage facilities should be ample to minimize the frequency of mixing. Further observation may indicate the necessity of increasing the tank storage facilities in the Interest of safety. ZILWAKEE This# a new, and as yet unused equipment, Is open to the same objection as the others in one respect* The mixing site on the platform, is not adequately protected against spillage of Ethyl Fluid* This area should be of concrete, but may he rendered fairly satisfactory by a covering of sheet metal* The platform is too small, and should be enlarged to care for the maximal drum storage needs# The bath house is situated some distance away from the platform and is thus inconvenient* This arrange** ment contributes greatly to the laxity of the men in carrying out the regulations# This is the most serious aspect of the unfavorable location of the bathing facilities, and it can be prevented by proper discipline* MUSKEGON This equipment tinder present conditions is satisfactory, in a general way# It has the same objectionable small pan under the drum, instead of a covered area sufficient to take care of any spillage or drippage# The worst feature of operation of this equipment consists of the long delivery line which carries a 1 to 10 dilution of Fluid in Gasoline to the tank cars# It is inevitable that there should be leaks from time to time in such a long pipe line, as a result of temperature changes, and the wear and tear of time* The fact that there are no such leaks at present does not detract from the potential hazard# I feel that it is proper to allow this equipment to continue for the present without radical modification, for the sake of obtaining much more immediately needed changes elsewhere# How*# ever, it is not the most satisfactory method for handling the mixing, and I cannot but feel that eventually it will be found advisable to resort to the more satisfactory method* EODESH The same objections that have been applied to the Bay City, Green Bay and Superior plants apply directly to this plant# In as much as the degree of responsibility, if any, of the Standard Oil Company of Indiana, for thi3 apparatus, is not clear to me, I mention it thus briefly, in order to request such co-operation and information as will make it possible to discuss the matter with properly responsible persons* . f Discussion t* The criticisms and recommendations found In the foregoing para graphs are based on continual observation of the operation of the mixing plants and workmen in the United States and Canada over a period of two years. During this time this laboratory has made extensive studies of industrial and experimental lead poisoning and lead absorption. It is possible to speak with considerable assurance as to the magnitude of the lead.hazards associated with thi3 work. Observation of the plants dis cussed herein shows that there are avoidable exposures to significant quantities of tetraethyl lead, most of the exposure consisting of the possibility of inhalation of tetraethyl lead vapor. The occurrence of abnormally high lead excretion and stippling of the red blood corpuscles on the part of workmen in a few instances only verifies what observation and judgment indicate to be true* These data do not tell the whole story however, he have found that lead compounds, when absorbed into brain tissue are held there in a comparatively firm combination of some sort, and are not excreted. Thus lead excretion does not show any evidence of what exists In this tissue. The importance of this consists in the fact that we cannot rely entirely on analyses of excreta of workmen as evidence of their safety or danger, for tetraethyl lead, especially when inhaled, has a de'cided tendency to go In relatively high concentration to brain tissue. Thus exposure to ore than minute traces of tetraethyl lead vapor in the air one breathes constitutes a serious danger. -Where such danger exists measures must be taken either to reduce the concentration of vapor, or to lengthen the intervals between exposure. It nay b 'i necessary to do both of these things. In the case of these plants I I feel that it is imperative to do away with a type of apparatus which allows^ t significant amounts of vapor to be thrown off in the atmosphere breathed by workmen. At the same time an equipment which makes possible the avoid ance of dally or almost daily exposure reduces the danger very effectively. There is no justification, economic or otherwise, for the contlnuance of the dangers associated with the type of mixing equipment seen at several of the above plants. lot to speak of the obvious humanitarian aspects of allowing the occurrence of preventable poisoning, it is pro bable that a single case of actual lead poisoning in one of those planta [could be more expensive than the entire cost of alterations of equipment needed to prevent its occurrence. The experiences of the past two years in manufacturing tetraethyl lead amply demonstrate our ability to prevent the occurrence of the horrible type of poisoning seen as a result of the absorption of tetraethyl lead in sufficient quantity* If such cases de velop in connection with the much less hazardous job of mixing Ethyl "Gasoline, I am afraid that ex post facto contrition will not serve any good purpose* There will be those who, rightly, will inquire into the matter and determine why it was that precautions of knovm value were not taken. Cuite naturally, I feel this keenly, for X am the first person of whom such inquiry would be made. Consequently I am taking considerable trouble to point out the dangers, to prove their existence and to indicate the remedies* Considering the time that has lapsed since these things were first pointed out by me, and recognising that these hazards have continued suffi ciently long to be a source of immediate danger, I cannot.avoid insisting upon the necessity for prompt action* I shall be glad to render every K 0001267 N5809.01 put Mr. Sibonthaler, the technical representative of my office, at the disposal of the Standard Oil Company for such use as can be made of him in arriving at estimates of the cost of alterations, and in effecting the proper changes*