Document 91wwZgv90QDvYrmdbQ7evDvBe

Pa c i f i c Em p l o y e d ! I I a n c e Co m p a n y THE VICTOR MONTGOMERY GENERAL AGENCY, INC. UNDERWRITING MANAGERS 505 MONTGOMERY STREET S A N F R A N C IS C O 11 Y U K O N 6 - 2 1 8 8 February 1, 1955 Dr, Robert A. Kehoe Kettering Laboratory College of Medicine - Eden Avenue University of Cincinnati Cincinnati 19 Ohio R e : ^ H H B v . Mohawk Petroleum . T ^L l*fb2X Dear Dr. Kehoe: Thank you very much for your very thorough and complete letter of January 25th, under the above captioned. You have outlined just exactly the type of information that we wanted and from your letter, our attorney will be able to prepare questions to ask of you when your deposition is scheduled. We certainly appreciate your cooperation and will ask our attorneys to give you as much notice as possible in making the arrangements to take your deposition. Yours very truly WPD/cm W. P. Davenport Branch Claims Supt. KE 0012340 January 25, 1955 M r. W. P . D avenport Branch C laim s Superintendent P acific E m ployers Insurance Company 505 M ontgom ery Street San F ran cisco 11, C alifornia Re: D ear M r, Davenport: fcv, M ohaw k P e tr o le u m 72-11482X A rep ly to your fu rth er le tte r to m y a sso c ia te , D r. K. V. K itzm iller, has been delayed lon ger than I lik e by m y preoccupation with a h ost of duties which aw aited m e on m y return to m y o ffice. H ow ever, I a ssu m e, from the fact that we have not heard from you further, that the delay has not, thus far, been a m atter of serio u s concern to you. S atisfactory com pliance with your req u est is not en tirely p o ssib le at th is tim e, for the reason that th ere is little published inform ation which b ears d ir e ctly on the point at is s u e . That is to say, that the ev id en ce, in term s of usual effects that have a r ise n actu ally or a lleg ed ly from contact with or exp osu re to lead ed g a so lin e, is e sse n tia lly n egative and is a lso e sse n tia lly p riv a te, being p r a c tic a lly e x c lu siv e ly in our hands. It is w holly n egative so far as effects on the nervous com ponents of the v isu a l apparatus a re co n cern ed . I sh a ll have to rev ie w the lite r a tu r e c a r e fu lly to s e e w hether or not any physician at any tim e has reported a ca se of blindness or visu al im p a ir m en t w hich he b e lie v e d to be d u e, p o s s ib ly or p ro b a b ly , to th e e ffe c ts of the absorption of tetra eth y l lea d . But so far a s our reco rd s a re con cerned, I can say flatly that no ca se of that type has been brought to our a tten tio n du rin g th e p e r io d o f u s e o f le a d e d g a s o lin e . {It b egan e x p e r im e n ta lly in 1923, and expanded p r o g r e s s iv e ly into in c r ea sin g ly w ider u sa g e from 1926 on to the p resen t, when a lm o st a ll of the g a so lin e in the U. S. A . contains tetraeth yl le a d .) I can cite the num bers and typ es of c a se s of injury and illn e s s (rea l and alleged )t that have b een rep orted to u s (we have m aintained a reg istry of all such c a se s and have investigated m any of them ) during that period, and can indicate the nature of our procedure for obtaining, th is type of inform ation, in support of m y opinion that no such d ise a se a s is d escrib ed in th is ca se can be attributed, reasonably, to the e f f e c t s o f le a d e d g a s o lin e , in th a t c o n n e c tio n , we h a v e m a in ta in e d an a ctiv e com m unication with the people in the p etroleu m ind ustry, w hereby c a se s of su sp ected illn e ss or injury have been brought to our attention for investigation at no expense (for our se r v ic e s) to them . This procedure has given us m o st of our record ed c a se s , sin ce the la rg e bulk of th ese had potential or actual m ed ico -leg a l sign ifican ce, in term s of industrial com pensation for em ployees{handlers of gasolin e) w ithin the industry, or Mr. W. P- Davenport - (2) - January 25, 1955 of suits for dam ages, brought or threatened or p o ssib ly only suggested, by the u se r s of gasolin e who, in their opinion, suffered from harm ful effects. N ow th e s u r v e y of a l l Of th e a b o v e m a t e r ia l in o u r f i l e s is a f a ir ly e la b o r a te proced ure, and I cannot hope to provide it in any d etail u n less the situation . req u ires it. I sh a ll now p roceed , how ever, to gath er up the lo o se ends of it, a s it has accum ulated since I la st had need of getting it together. I shall be able only to sum m arize it sk etch ily. My reason for being able, at this tim e, to te ll you that it is negative evidence is that a ll of it goe3 over m y - d esk at som e tim e, and th erefo re I would undertake to rem em b er and to record sep arately for easy a c c e ss, only such item s as have been significan t, in the se n se g requiring in vestigation , or a s being of such a type as to req u ire som e alteration of cu r opinions. e have changed our m in ds, in r e sp o n se to e v id e n c e, on c er ta in a s p e c ts of the situa-tion, but not at, a ll on the h azard s of the handling or ord in ary u se of lead ed g a so lin e, or on the hazard of ordinary contact with it. T hirty y ea rs is a long tim e over w hich to gather negative evid en ce, considering the hundreds of thousands of refinery and filling station handlers of leaded gasoline, and therefore I feel quite s e c u r e in the p o sitio n I .take. The oth er sid e of the problem is that which d e r iv es from the ex p erim en ta l work which we have done in relation to the toxic hazards of tetraethyl lead and gasolin e containing it. U nfortunately, the publications on this cam e out, for the m o st part, m any y ea rs ago. R eprints of th ese are not availab le for distribution at this tim e. I have at lea st one copy of everything any of us has w ritten or ,published on the subject, but som e of them I am not prepared to lo se sight of .even in the form of a loan. B ecau se of th eir volum inous ch a ra cter, m any of the rep orts of in v estig a tio n s w ere n ev er published. They w ere m im eograp h ed o r rep rod u ced o th er w ise fo r d istrib u tio n to health authorities and to oth er resp o n sib le people in a ll p arts of the w orld, and th ese too are put of supply. The fact is that th ere have been p ra ctica lly no leg a l prob lem s in a sso c ia tio n with the distribirtion of lead ed g a so lin e for the p ast ten - nearly fifteen - y e a rs. T herefore, there has been no real n e e d to h a v e th e s e r e p o r ts and,'p u b lish e d a r t ic le s r e p r in te d , and m o s t of th em a r e no lo n g er a v a ila b le fo r d istrib u tio n or lo a n . In fa c t, X cannot supply you with any of the m o st pertin en t rep orts and pu b lication s, although I sh a ll bring so m e of them with m e and show them to you. In co n seq u en ce of th is situ a tio n , I sh a ll have to te s tify to the p ro g ra m of exp erim en tal w ork on a n im a ls w hich we ca rried out to rev ea l the follow ing things (1) The to x icity , m ode o f ab sorp tion , and m od e of a ctio n in the a n im a l body, Mr. W. P. Davenport - (3) - January 25, 1955 of tetra eth y l le a d . It is a to x ic m a te r ia l, w ith certa in v e r y c o n siste n t and highly ch a ra cteristic e ffects. : (2) The con trastin g to x icity of lead ed g a so lin e / in which tetraeth yl lead is so high ly diluted - never m ore than 1 part in 945 parts of ga so lin e by volum .' in aviation g a so lin e , and n ev er m o re than 1 part in 1260 p arts in autom obile gasolin e - a s e sse n tia lly to lo se its toxic p ro p erties. The high dilution of the lea d compound in g a so lin e so in ter fe r es with its ab sorp tion through the skin or into any tis s u e of the body of an a n im a l, as to elim in ate, for a ll p ractical p u rp oses, its injurious effects. Hence what happens, when leaded g a so lin e com es in contact with the skin or with a m em brane such a s the eye, is p r e c ise ly what happens when the g a so lin e alon e is involved in such contact. I sh all be ab le to d escrib e the exp erim en ts w hich provided the proof o f this in sim p le language which w ill be understood by laym en, and can show them how it was that the d ecision was a rriv ed at that the d istrib u tio n and u se of such g a so lin e in v o lv ed no danger to h a n d lers and u sers. A third m atter for testim on y is that of the field in vestigation which we ca rried out to d eterm in e in p ra ctice, w hether the behavior of m an w as the sa m e, in effect, as that of experim en tal anim als in th ese m a tters. F or sev era l years and then at longer in terv a ls, we carried out careful clin ica l and lab oratory in v estig a tio n on som e hundreds of the m o st exp osed p erson n el in the industry - garage m ech a n ics, refin ery and fillin g station em p lo y ees, etc. - in an effort to d isco v er any evid en ces of illn e ss or of absorption of lead am ong them in con seq u en ce of th eir work. T h ese w ere w idely d istrib u ted and carefu lly executed su rv ey s, involving elaborate ph ysical and laboratory exam inations. They confirm ed com pletely the conclusions arrived at by anim al experim entation. . T h is c o m p le te s, in p r in c ip le , the accou n t of the g e n e ra l su b ject m a tter of m y testim ony, based on experim ental work and clin ical work carried out by m y s e lf and m y a s s o c ia te s in th is L a b oratory under m y p e r so n a l d ir e c tio n . B ecau se of the p oten tialities of lead absorption for causing w idespread harm , this situation has been investigated m ore carefu lly and m ore con sisten tly o v er a lo n g er p erio d .o f tim e than any oth er p ro b lem of public h ealth w hich rela tes to a p oten tial toxic hazard that has develop ed in the la s t h alf a century, and th erefore it would be hard to convince any ju ry of reason ab le p erson s that th ere is any virtu e in the cla im m ade in th is c a se . i I tru st that the contents of this long letter w ill give you what you require at ; p resen t, but if further questions or needs a r ise , I tru st you w ill le t m e know. V ery truly yours, ft' 0 0 1 2 3 4 3 Pa c i f i c Em p l o y e r s THE VICTOR MONTGOMERY UNDERWRITING pSiURANCE Co mpa n y GENERAL AGENCY, INC. MANAGERS 505 M O N T G O M ER Y S TREET S A N F R A N C IS C O 11 Y U K 0 N December 27, 1954- 6-2 1 8 8 Dr. K. V, Kitzmiller University of Cincinnati The Kettering Laboratory College of Medicine - Eden Avenue Cincinnati 19, Ohio Re: Iv. Mohawk Petroleum '2-1U82X Dear Doctor: Thank you very much for your letter of December 21st advising us that Dr. Kehoe is out of the city until January 1st. We have no way of telling just when this matter vili be reached but ve think ve probably can wait until after the first of the year for any depositions. In the meantime, however, it would be extremely helpful to us if a review of the literature and docu mentary information from the files of the laboratory could be briefly summarized so that we can pass it along to our attorneys for their guidance in preparing to take a deposition. In other words, without a little background information as to what the literature and the documentary evidence reveals, our attorneys will be a little uncertain as to what questions should be asked in connection with any depositions that they may elect to arrange. Perhaps you would be good enough to forward this to us at your early convenience. Yours very truly, W P D :vs HE o * y*. \ ; U jU o 4<1 W. P. DAVENPORT Branch Claims Supt. December 21 195&J. Mr. W. P. Davenport Branch Claims Supt. Pacific Employers Insurance Company 5>0f> Montgomery Street Ban Francisco 11, California Re: vs5** MJOoUhUaUWwiki Petroleum 72-.12ij.82X Dear Mr* Davenport: Dr* Robert Kehoe is out of tho city and will not return before January 1 1950* If it is necessary to proceed in this case before he returns, I will attempt to review the literature in this field, collect documentary information from the files of the laboratory, and be prepared to give a deposition accordingly Please advise me if this proposal will be satisfactory in the event that it will be necessary to make arrangements without further delay* Very truly yours, KVK: vr K* V. Kitsmiller, M.D. December 21 19531 Mr, W, P, Davenport Branch Claims Svxpt. Pacific Employers Insurance Company 5>05> Montgomex'y street San Francisco 11 California Re vs, Mohawk Petroleum 72~llL82X Dear Mr, Davenport: Dr. Robert Kehoe is out of the city and will not return before January 1 195>5* If it is necessary to proceed in this case before he returns, I will attempt to review the literature in this field, collect documentary information from the files of the laboratory, and be prepared to give a deposition accordingly. Please advise me if this proposal x?ill be satisfactory in the event that it will be necessary to make arrangements without further delay. Very truly yours, KVX:vr K. V. ftitsmiller, M.D. Pa c i f i c Em p l o y e r s I a n c e Co m p a n y THE VICTOR MONTGOMERY GENERAL AGENCY, INC. UNDERWRITING MANAGERS 505 MON TGOMERY STREET SA N FRANCISCO 11 Y U K O N December 9? 195*+ 6-2188 Dr. Robert A. Kehoe University of Cincinnati Cincinnati, Ohio Re : vs. Mohawk Petroleum 11*+82X Dear Dr. Kehoe: You were very kind in replying to our communication on February 3, 195^ under the above caption, and the information contained in your letter was very helpful. Our investigation indicates that this case is without merit but a nominal settlement cannot be effected so we probably are not too far away from actual trial of the case. Our attorneys advise us that in properly defending the case, it will be helpful either to have the actual testimony of someone from your organization or perhaps it would suffice if we could arrange to take the ' deposition of someone who has reviewed all the literature on the subject and is qualified to express an expert opinion as to the effect of leaded gasoline on the eye. Assuming that the latter plan would be preferrable as far as you are con cerned, we are taking the liberty of requesting that you forward us some of the literature and perhaps some summarizing information that has resulted from your studies. You might also indicate from whom we should obtain a deposition to get an expert opinion on the points involved. We then would advise our attorneys as to what your Expert would testify to, and he would make the necessary arrangements so that a deposition could be taken in your city at your convenience, or at the convenience of the person you designate as properly qualified. It is of course unfortunate that cases of this sort that seem to be completely without merit have to be defended * but as they do, we are sure that you will agree that it is in behalf of the industry whom you are representing that a united front against claims without merit is the only logical answer. 0012347 Re vs. Mohawk Petroleum 2 Accordingly therefore, would you advise us whom we should arrange to take the deposition of, his preference as to time and place, and in brief, what he will be able to testify to. Following receipt of that information, we will make the necessary arrangements with our attorneys. If you do have any other ideas or suggestions, or question^ do not hesitate to advise us. Yours very truly D/cm W. P. Davenport Branch Claims Sunt / 505 M O N T G O M E R Y S TREET . S A N F R A N C I S C O 11 Y U K O N 6-2188 March 11, 1954- Robert A. Kehoe, M. D. University of Cincinnati The Kettering Laboratory College of Medicine-- Eden Avenue Cincinnati 19, Ohio Re: 72-114.82 m P M L v s Mohawk Petroleum Corporation Dear Dr. Kehoe: Thank you very much for your prompt reply to my request which we received in this office on February 8, 195A. Your evaluation of this particular case has been extremely helpful and you can rest assured that you m i l be kept informed as to the progress of this case. Should it be necessary for you or any of your associates to be involved in giving testimony, you will certainly be notified in ample time so as to clan accordingly and to also gather together any documentary information that may be needed. Thank you for your excellent assistance in this natter. Verv t.nilv mure JHDtnsh / JOHN H. DEVLIN ; Claims Department February 3, 1954 M r. John D elvin C laim D epartm ent .. P acific E m ployers Insurance Company 505 M ontgom ery Street .> San F ra n cisco 11, C alifornia i Re: D ear M r. D evlin ' ' 72-11482 v. Mohawk P etroleu m C orporation I have exam ined the rep ort of D r. -Hicks attached to your le tte r of January 25, concerning the leg a l action indicated above, and in m y opinion, such evid en ce a s he p ro v id es should be su fficie n t, in its e lf, to d isp o se of the c a se , u n less one w ere to find that evid en ce to con trovert it i s to be introduced. I say this because there^is the slig h test reason to b elieve that leaded gasolin e would have an y/effect in a c a se of th is so r t than would ordinary g a so lin e, w hile any gasoline could be expected to have no m ore than a lo c a l irrita tin g effe ct. If w e w are d ealin g h e r e w ith p e r s is te n t sig n s of irrita tio n of the conjunctiva of the ey es and ey elid s, or if th ere w ere a conjunctival or corn eal u lc e r, one m ight cla im , with som e but not v ery m uch reason , that the original irritation had initiated or contributed sig n ifica n tly to the. p r e se n t condition. The a ctu a l co m p la in ts, h o w ev er, a re absurd in this connection. If it is n e c e s s a r y to do so , one of us could te stify that the r ec o r d s of com plaints of illn e ss and injury which have com e to us over the y ea rs from a ll so u r c e s, in connection with the distribtition and u se of leaded g a so lin e, fa il to show any ca se of p e r siste n t injury of the type com plained of. Many p erson s have had gasolin e in th eir e y e s, and have su ffered pain (burning and stinging) for variab le p eriod s of tim e th er e a fte r, but in only one or two instan ces have there been m ore than fleetin g d iscom fort. The exceptions have occurred wheythe individual has rubbed the eye vigorou sly b ecause of the pain, traum atising the cornea and causing dam age which resulted in an u lc e r . C orneal u lc e r s from any cau se are often slow in healing and so m etim es they lea v e a sca r which red u ces v isio n . Such a c a se , reg a rd less of the alleged nature of the injury involved, i s difficult to deal with in litigation . The p resen t c a se , in w hich the com plaint h as no apparent relation sh ip to extern al injury, would see m to depend, fo r its background on som e system ic or neural type of intoxication. T his, considering the nature of the exp osu re, seem s w holly unreasonable, and certain ly it h as no precedent in previous ex p erien ce. M r. John D elvin - (2) - F eb ru a ry 3, 1954 You m ay w ell believe that we have no w ish to spend m uch tim e participating in the litig a tio n in 3uch a seem in g ly absurd c a se a s th is, and if th ere is reason to b e lie v e that it can be handled sa tisfa c to r ily without our h elp , we would hope to be sp ared . H ow ever, w e sh a ll be prepared to give such a ssista n c e a 3 we can, to the extent that it app ears to be needed. It has been one of our job s, in this connection, to exam ine into a ll com plaints that have com e to our attention from a ll so u rces in relation to the p o ssib le harm ful effects of the handling of leaded g a so lin e, sin ce 1926. D uring and before this period, we have a lso investigated tetraethyl lead ex ten siv ely , and we have been responsible for the clin ical and toxicologic study of m en exposed to tills m a teria l in a ll parts of the in d u stry. If, th er e fo re , the a lleg ed dam age in this c a se is attributed to the e ffe cts of the m inute quantity of tetraethyl lead involved, we could give testim on y on this sco re in a com p re hensive m anner. I should lik e to be kept inform ed as to the p ro g ress of this c a se , and if I or one of 'my a s s o c ia t e s io to b e in v o lv ed in g iv in g te stim o n y , I sh a ll want am p le notification in advan ce, so a s to be able to plan accord in gly and a lso to g a th e r to g e th e r the d o c u m e n ta r y in fo r m a tio n . We h a v e am e x te n s iv e f ile of the c a se s of com plaints p reviou sly referred to, but there has been no o c ca sio n fo r som e tim e to study them and to su m m a rize the data contained th e r e in . It h as b een a nu m ber of y e a r s sin c e w e h ave en cou n tered any com plaint, cf an injury from the ordinary handling of leaded g asolin e, that has concerned its e lf w ith anything m ore sig n ifica n t than a contact d erm a titis, Very truly yours, RAK e R o b ert A . K eh oe, M. D. H* 0d r> Ul^OOi \\ V A.V' 505 MONTGOMERY STREET . S A N F R A N G ISC O 11 . Y U K 0 N 6 - 2 1 8 January 25, 1954 Dr, KeHoe Kettering Laboratory College of Medicine Eden Avenue Cincinnati 19, Ohio Re: 72-11482 - Mohawk Petroleum Corp. Dear Dr. KeHoe: We are defending a claim on behalf of our insured, The Mohawk Petroleum Corporation, wherein it is alleged by the claimant, a Mrs.d that she has suffered an impairment to her vision as a result of hg"Ethyl Gasoline splashed into her face on July 7, 1953 In the preparation of this defense, we have had Dr. Avery Hicks of San Francisco examine this patient relative to her alleged injury and dis abilities resulting therefrom* Mr, W. A* Sievert, District Manager of the Ethyl Gasoline Corporation, has suggested that we turn to you for assistance in defend ing our lawsuit. He thought you would probably have some reports and statistics as a result of your research tending to show that Ethyl Gasoline getting into the eyes w i n not have a permanent deleterious effect. We are attaching a copy of Dr. Hicks* report of examination of Mrs. to give you the details of this particular occurrence. May we look for ward to hearing from you promptly as to what evidence you can assist us in procuring regarding such a situation in general# Very) JD:vs Enc, KE oU j. 4 O D JOHN DEVLIN, CLAIMS DEPARTMENT Avery M orley Ricks,M. D. MEUICO-DKNTAL BUILD INO FOUR NINETY POST STREET SAN FRANCISCO January 15, 195k Pacific Employers Insurance Company 505 Montgomery Street San Francisco, California Attn: Mr, Devlin re: Mrs, To Whom It May Concern: I have completed my examination of the eyes of this patient. She gave a history that approximately seven months ago ethyl gasoline was blown into her face and eyes. She stated that she attempted to wash out the gasoline immediately with water but became hysterical and was taken to the emergency hospital where the eyes and face were washed and grease was applied to her eyes and face. She called her physician, Dr, Robert Burwick, and when she continued to complain of difficulties with her eyes, she was referred to Dr, Selby Mohr, who has treated her since with drops, pills, and salves. She first stated that she had never worn glasses, but after some question ing, she admitted she had obtained a pair of glasses for reading approxi mately one month before the alleged injury from a ''Jewish'1 optician on Post Street between Kearny and Grant. She could not remember his name and stated that she had not used the glasses. She complained of severe photophobia and stated that she develops pains in her eyes and head when ever she is exposed to bright light or whenever she becomes upset or excited. She stated that she had been very nervous since the alleged in juryj also, that prior to the injury she was able to read and see well for distance and that she found glasses unnecessary, but that since the injury she has not been able to read and glasses do not help her. Examination: right eye vision less than 20/300, left eye vision 20/200. There was continuous closure of the eye lids and squinting which gave one the impression that it was an intentional blepharospasm. It was not consistent and became more marked when on talked to her. She complained of marked sensitivity to light but I was able to shin the bright light of the oph thalmoscope in her eyes at times and she did not object, while at other times she would insist that the light was so bright that she would forcibly close her eyes and prevent any examination of the interior of her eyes by even the small incandescent light of relatively low inte&a^ y The lids, conjunctiva, corneas, anterior chambers, and irises were normal. The pupils reacted normally to direct and consensual stimulation. The lens and media were clear, and the fundi were normal. A study of the peripheral fields showed a marked, irregular constriction of the visual field of the right eye and a marked, spiral constriction of the field of the left eye. (Spiral constrictions of the fields of vision are usually either intentional or occur in hysterias.) Ho extraocular muscle Imbalance could be made out. Refraction showed a moderate degree of myopia in the right eye and a KB 0012663 page 2 re: Mrs Avery M orley Hicks.M. D. MEDICO-DENTAL BUILDING POUR NINETY POST STREET SAN FRANCISCO relatively low degree of myopic astigmatism in the left eye. Opinion: I have been unable to make out any evidence of injury to this patient's eyes. There is no conjunctivitis, keratitis, or other external evidence of disease which could possibly account for a real organic photo phobia, It is obvious in examining the patient that she is making no effor to try and read, The best vision obtainable In the right eye with a minus lens was 20/300 plus while the vision in the left eye could not be improved to better than 20/200 which she could read with or without glasses. The patient's history that she has never worn glasses and found glasses unnec essary is probably true because the right eye has about the right degree of near-sightedness so that one would be able to read with the greatest of ease without lenses with this eye, while the left eye is only very slightly near-sighted and would, under normal circumstances, give an individual almost normal distance vision. Patients with refractive errors such as found in this case very frequently use the essentially emmetropic eye for distance vision and the myopic eye for reading, T The patient has a very fair complexion and it is fairly possible that Bbe is an albino in which there has always been some moderate reduction in vision. But I feel definitely that she can read better than she would admit while in the office, and I am sure that her visual fields are larger than she would admit. The visual field of the right eye showed an eratlc, concentric constriction, and it was rather obvious that she was making no effort to do her best. As far as the left field was concerned, it was a typical spiral field, getting smaller and smaller as one continued in a clockwise maimer from meridian to meridian. This patient is extremely nervous and is undoubtedly going to lay the cause of the nervousness to the injury* This part of the case should be carefully investigated. However, as far as her eyes are concerned, I feel definitely that she has not sustained any damage to her ocular apparatus as a result of the alleged injuries. I have never seen any damage to the eyes as a result of gasoline, either plain or ethyl, being blown into them, and I feel definitely that if ethyl gasoline were detrimental to eyes one would see many examples of it as the wide use of gasoline of the ethyl type has resulted in this substance being splashed into many people's eyes. The patient complained bitterly of the fact that the gasoline which was on her skin produced severe burning, nec essitating frequent applications of oil. I know from personal experience, having worked in an oil refinery with gasoline, that it does not burn the skin to any degree. And I have, while working at the refinery, had gasoline splashed in my face and eyes, and, although it does produce a mild conjunc tivitis, it is certainly not disabling. It is, therefore, my feeling that this patient has not suffered any damage to her eyes as a result of her HE 0012654 *r pag 3 re Mr alleged injury. AMH:jh Avery M orley H icks,M. D, MEDICO-DENTAL BUILDING FOUR NINETY POST STREET SAN FRANCISCO Very truly Avery M o ^ M y Hicks, K.D. k'f 0 0 1 2 o 5 5