Document DGZXY21ooxVJOZ8m172Gb5XbM
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January 4, 1946 -'CH r *r"
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Mr. T. R. A. Bevan, The Associated Ethyl Company Limited, Artillery House# Artillery Row,
London# S. W. 1.
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Bear Ray<
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Quite some weeks ago In letters dated August 21 and September 21# #-., -
I received from Fossett analytical data from Abadan as forwarded
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by Mr. Harrison. Fossett*s original letter of August 21 va*
accompanied by a letter from Mr. Harrison dated July 26 In which
there were a number of comments and. Questions# which I have attemptedm*': ;
to deal with In a memorandum which you can deal with In accordance,
with your best--judgment... -
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I regret that It has taken me so long to get around to this matter
However# there have been so many things to do that I have had to K'^'^ **"
take them In accordance with their apparent urgency. I hope you
will be able to convey this to Mr. Harrison In such a way as to
Indicate that I have not been unmindful either of their interests
or of their very splendid cooperation. It is rather that I have
not solved the problem of being in two places at once or of doing^
two things simultaneously* Perhaps the scope of the memorandum#
attaohed herewith# will both explain xry.. delay# and make amends for
it.
With kindest personal regards.
.In
sincerely yours #
Robert A * liiehbe # M. D .
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MEMORANDUM ON REPORT AND QUERIES FROM ABADAN
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Lead Exposure Associated with Various Occupations
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The data obtained by the (analysis of the urine of workmen.. ?$& m*xli
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have been examined, and various aspects of the problems Involved, as'gT^l
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raised in Mr. Harrison's letter to Mr. Fossett dated 26 July 1945, *-.V: '"7
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have been considered */ The data are set up in tabular fonn herewith
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for illustration and comment,.but^the several occupational groups
are referred to separately for greater clarity, r
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Distribution of Analytical Results Obtained Upon Samples of
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Urine of Various Groups of Workmen at Abadaun in 1944 and T$45 ^a,.
Urinary Lead
Concentration
Mg'/l
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Frequency of Occurrence of Anal^rtical Results within 'i.M
Limits Indies ed
1944
SEB
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1945 .
7-7- : vV-
Entire Nov*
DF
TPA
SEB
DF TPA ' '
and
Dec.
0 - 0.019
.02
.04
.06
.08 - -
.10
.12
7 ;-7'
14 -
.16 ' ^
.18
.20
.22
.24
1 11 19 23
4 13 21
7 3
1 1
1
4 1 2
5
9^ 2
1
9
6
6
" 1 '
6 2
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2 2 8
3
5
12 4, 3
1
2-2
<\
1. 10
6 2 s'. 12 10 ..... 2
1 . .2 ..
4 6 4 8 7 2
2*
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1 7 6 4 3 ,v 7 3
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Total
105
Mean
777^, , 0.092
P.E.
so. 003
S.D.
*o.046
C.V. .()...
49.74
24 -V JQ ;:A-
' 44 ^
0.111 0.067; 0.120
to.005 0.004 0.005
*0.035 *0.034 *6.049
31.89 50.25 7, 41.06
45
0.099 0.004
*0.041
41.07
34 - 31 ' 0.092 0.092 0.004 0.004
*0.036 *0.036 38.87 39.21
Mixing Plant Personnel ^ ; ^The group of men engaged in mixing Ethyl fluid with gasoline
deserve special attention in view of the1 data and the question raiBed as to the accepted limit of safety*
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1. The data on these men (Class S.E.B.) demonstrate
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clearly that some degree of occupational lead absorption Is occurring among them. The comparison of the available data for 1944 vith those
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for 1945 shows that no significant reduction In the lead exposure y has occurred during 1945, even when one employs the results obtained
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only for the months of November and December of 1944 (by which time ,, v- -^K- ^
most of the low results duet to the Introduction of new men with no 5. V
prior occupational lead exposure during earlier months of the year ,v 1
were eliminated,
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2. Examination of the results on individual men for the ^
year 1945, show that eight members of the group have provided more
than one sample with a lead concentration in excess of 0.10 mg. per
liter (Case 95, 129, 150, 141,-142/145, 152 and 166), and that these
men appear to be more or less consistently high in their rate of lead
excretion. One (#166) had two dangerously high results, while another
(#152) had the highest of all (0.52 mg. per liter), followed subse
quently by a lower but significant result (0.15 mg. per liter) . ;j?
There may have been some factor of contamination to raise the general
level of these results, but one may not safely assume that this was
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the case.-
5. The question of the tolerable or safe limit of lead uig -vv,.:
exposure, as expressed in terns of urinary.lead excretion, appears ,,
not to have been fully understood, and in a subsequent part of .this
memorandum I shall attempt to clarify this matter and to give advice Jf
on the application of suitable criteria for the disposition of
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individual cases. However, this is not the point involved in the
operation of plants in which Ethyl fluid is mixed with gasoline. Persons who work vith Ethyl fluid in its concentrated form
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must be protected against lead exposure. Unless they are protected
completely. It Is not possible to be sure that, they are protected at
all, for the rate of lead absorption as the result of contact of the
skin vith Ethyl fluid or because of inhalation of vapor,, given off
from the concentrated fluid, is so rapid, as to be excessively danger
ous., Errors of technique or judgment, therefore, may have prompt and
serious results. Accordingly, a .regimen of precautions,, In - the form v`
of suitable equipment and detailed .instruetions, has-been provided, ,
which has as its purpose : the avoidance of all exposure and all ab
sorption of lead. Moreover, evidence of lead exposure and absorption
on the part of the workmen, is regarded as evidence that the mixing
equipment is inadequate, or that the instructions are not followed
properly, or that both of these factors are involved. When such
evidence is available every effort must be made to find the faults in
performance and correct them. It is not a question, therefore, of
how long a man can work in this occupation, or when he has been
exposed for a period sufficiently prolonged to be dangerous. It is
rather a question of whether he has been trained sufficiently (or
well enough supervisedJ in the performance of his duties so as to
avoid lead exposure.
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Recognizing the fallibility of man', some provision has been
made for offsetting the effects of some slight defects in the precau
tions. Therefore,,the periodicity of mixing operations has been^:
regulated. This regulation has. certain other purposes* however, which
are more important than the spacing ofsexposure. It also has a ten
dency to determine the character of the mixing equipment. Our
reasoning in this regard takes the following line; - if.it is necessary
to mix more frequently than six times per. month, then the mixing .
equipment is not of the type best adapted to the purpose* In general
0010302
our experience fully justlflea this conclusion. Therefore, (to
answer another question in Mr. Harrison * s le tter), the duration of
an individual mixing operation is not a primary consideration, and
ve are not in position to take it into account. We must insist upon
the importance of the avoidance of lead exposure. If that is done
the length of this time is unimportant Moreover, it is not our
general practice to make use of multiple groups of men, so as to
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limit individual exposure. Instead ye insist.upon changing to a
type of equipment that requires no limitation of the frequency of
mixing.
It is recognized that these principles are not now applicable
In every respect at Abadan. A large volume of fluid in drums must
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be handled, and the long time and the frequent repetition of. this
work introduce some degree of hardship and discomfort into the work
of the men, as well as some tendency for relaxation of precautions.
This elsewhere, at least in the U.S.Awould be counteracted by the
adoption of a new type of mixing equipment which would enable the
Ethyl fluid to be handled in bulk under conditions which, during
mixing, would entail no opportunity for lead, exposure. The one most
Important principle, however, does apply at Abadan, and indeed, is
all the more imperative, - namely the principle of complete avoidance
of lead absorption. So long as we cannot apply the orthodox solution
of this problem, in the form of new equipment, it isrnecessary that
every other means for the avoidance of exposure be emphasised. For *
this reason, the use of multiple crews of mixing personnel was
approved .
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For the above reasons, the relaxation of the standard of
safety as expressed in urinary lead concentration, in this occupation
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is hot good policy1 or practice . Vhat I said of this originally In -r
Abadan in relation to mixing, vas^that lead concentrations In excess
of o.lo mg. per liter of urine vere almost certainly indicative of,
occupational lead absorption even though there;vere only a few < f
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results to go bn , and as such vere to be regarded as dangerous, not
in themselves, but rather beoause they demonstrated failure, of the
precautionary regimen. This* is true-; nov, as it vas then'. \ The >:
criterion of "safe "versus hazardousi lead absorption (to be discussed
later), is applicable in industries in vhich there is a slight or
moderate, conventionally controlled hazard .7.. It-.is not applicable to
this occupation* in toy opinion. Kather, the evidence of lead absorp
tion on the part of these vorkmen, is proof that the entire operation
needs better and closer supervision or. better equipment and operating
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methods. It is a sign of need for improving the performance, not for
changing the program of medical handling of the men. . , .
Drum and Can Filling Personnel
It is obvious that vork done by these men involves some de
gree of almost unavoidable lead exposure, vhich, hovever, can be
accepted vlth a degree of equanimity because of certain factors
vhich operate vithout fail to dilute the exposure and to make it less
than immediately hazardous.((l) The dilution of the lead compound vith gasoline reduces the danger of fatal skin absorption of T.E.L.
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to the vanishing point, and decreases the volatilization of T.E.L. in
an indirect manner. (2) The presence of gasoline liquid and vapor,
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introduces other obvious risks (fire and explosion) the control of
vhich tends to reduce greatly the lead exposure.) One is not likely
to be poisoned by T.E.L., therefore, in these occupations, as the
result of an accident or a technical error that gives rise to a
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brief exposure. Poisoning, if It can occur under existing conditions.
results fran relatively prolonged exposure, vhlch therefore provides'
time in vhich to appraise the situation and to take appropriate action It is in such a situation that the level of tW lead excretion of
groups or individuals' demonstrates that the sources of lead exposure
require better control if conditions are to be`safe for indefinite
periods of employment, or alternately,'that an individual' needs to be removed from exposure for his ovh safetyi ?*'' 4 ` l?u*` **
In dealing vith problems of this type ve have found by
experience that if 1 the'stable mean concentration of lead in the urine
of exposed vorloaen does not exceed 0.10 mg. per liter, cases of lead
poisoning vill not occur. This same fact applies to the individual
if there are a sufficient number of analytical results to provide a
stable mean value for the expression of his actual physiological
status vith respect to lead absorption. (This Implies,of course,
that the lead exposure is fairly veil controlled and not subject to
vide variations from time to time. Othervise stable mean values could
not be obtained.) This standard allovs for certain variations above
and belov the mean, and does not require that a man vhose urinary
lead concentration in a given instance,.is above the mean value, is
to be removed from his employment. ,.^On. the 'other hand, the standard ,
itself is factual, and as such is not.subject to modification to meet
a given set of practical conditions
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Looking at the tabulated data from this vievpplnt, and
assuming that there is no factor of contamination to elevate the.. .
individual results and thereby the mean values, the follovlng conclu
sions are justified;, ,
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lead exposure associated with drum and can filling
vas kept within safe limits during 19^5 > tout was Just at the threshold
of danger, Le. there Is no large factor of safety. ^ :
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2. If, however, conditions remain as they are, it Is" J
possible that the factor of time and lead accumulation in the tissues ",
of persons who remain in their respective occupations, will cause the
mean values to increase to levels that will then toe unsafe.
(Vfe have previously discussed the special factors in is -.t
connection with the mixing of Ethyl Fluid with gasoline, which negate
the conclusion that this occupation is safe, or, at least, that it
would toe so considered under the usual conditions of unsupervised
work, that normally characterise this work in various parts of the
world. However, it can now toe said that if the supervision of this
work Is or should toe sufficiently precise and continuous so as to
prevent all highly dangerous exposure to T.E.L., this same conclusion
is applicable here, as it is in T.E.L. manufacturing plants, where
supervision Is continuous> and where the training and discipline of
operating personnel is kept at a high level of quality.)
Criteria for the Medical Handling of Exposed Personnel
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Over the years of observation and-study of conditions and
personnel in manufacturing operations, criteria have developed which
enable the physician to determine howrto deal with the several situa
tions which arise In connection with the safety of individuals i The
special conditions of the war-time manufacture of tetraethyl lead
have given to these criteria a precision that was formerly lacking.
It is to toe remarked that there is no large factor of safety in their
application, in view of the fact that shortage of men in the manu facturing plants was responsible for the exercise of the most conser-
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vative judgment in the removal of men from their employment. At the
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same time/ it may be said that not even the necessities of war vere
believed
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justify the acceptance of .undue risk. On. the part of
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individual workmen. Therefore , these criteria are advanced with
some confidence in their validity.
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1. When analytical data are available ;in the'presence of
symptomatology of any type , V*W
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a. the symptomatology should be interpreted without referencef
to analytical data and a conclusion arrived at di^to^lts ^in
significance/'"taking into account .the hematological and
other laboratory findings; \ v
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b. a cause and effect relationship between lead' absorption
and non-specific symptomatology, on the part of men who
have been working up to the time of sampling, may be ..
'excluded'.when;
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(1) the results on a sample of blood and a spot sample
of urine are well within safe limits; i.e. - less
than 0.06 mg. per 100 grams of whole blood less than 0.1S rag. per liter of urine; or when (2) repeated results on spot samples of urine are within safe limits as defined above, or when
(?) the result on a large sample of urine is within safe
limits as defined above...
a cause and effect relationship between lead absorption and non-specific symptomatology.may be assumed to exist,
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(1) other causes'of symptomatology have been excluded
beyond reasonable doubt and the analytical results
are above safe limits; or when - "
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(2) the background of. the symptomatology is quite un
certain, and the analytical results are within the
dangerous range, i.e. -
0.00 to 0.15 mg. per 100 grams of whole blood
. 0.18 to ,0.40 mg. peh liter, of urine. , r,_
a cause and effect relationship, between lead absorption w and strongly suggestive or specific symptomatology may ' UX
be assumed to exist, when
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(1) . the analytical results are within the dangerous
range; or when . (2j it. is known that the analytical results were yell
above safe levels during a period of lead exposure that has now been discontinued, for some weeks.
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2. When no symptoms of any kind exist, persons should/be removed -
from lead exposure or transferred to vork involving greatly
reduced exposure, when
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a. the analytical results are consistently vithin dangerous
limits, i.e. -
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(1) results on a blood sample and a spot urine sample " ~'
? are in agreement at high levels of more than 0.*o8->\; xv
mg. per loo grams of whole blood and more than\ 0.l8y/ -
^ r.* .mg. '-per liter/of . urine! or (2) repeated results on spot urine
./ * v"- samples are
cont-s>l?s- ite^htlyv5
ur* within the high range indicated above; or -
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(3i the result on a large sample of urine is vithin ithe -
range given above (0.18 mg. per liter or more) .
exception may be made in this rule when it can be"
established that a high result is of short duration
and is followed by a rapid drop in the results, as,
in the case of brief severe exposure.)
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3. Men with no symptomatology may be returned to the work from* '/>
which they were transferred or removed because of excessive/,
lead absorption, when
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a. the analytical results have fallen to levels -that are
consistently safe, i.e. -
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U) the blood results are down to 0.05 mg. per 100 grams
or lower, and the urinary results are not higher than o.lo mg. per liter; or
(2) the results on urine samples of large volume (one
liter or more) are not in excess of 0.10 mg. per
liter, and a representative sample of feces for a twenty-four hour period contains under 6.40 mg. of lead. (In general, the length of the period of re duced or discontinued lead exposure should be more extended in the case of persons whose employment under conditions of potentially hazardous exposure c has been prolonged, i.e. the longer the period of ^ exposure> the longer shall be the period of freedom from exposure.
Masks for the Protection of Mixing Plant Personnel against T.E.L.Vapor
Previous discussion of the hazards of mixing have dealt with
the need for additional precautions. ^Vith respect to canister masks,
additional comments are justified..* /
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to the length of use of canisters (luo hours) has been set up in
relation to the somewhat diluted vapor of tetraethyl lead only. It
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has no application to gasoline vapor, on vhich ve have no valid data fYff
JIn mixing operations, as ve are generally familiar vith them, the t ^
problem of concentrated gasoline vapor is not encountered to an Y: " important degree^ and therefore ve have not attempted to deal.vith%4^
it, in the belief that technical and medical personnel in the petro-
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leum industry have had more experience vith it than have ourselves*!
It Is know* however, that moderately concentrated gasoline vapor;,_
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will flood a canister mask and render it ineffectual after relatively
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brief periods of use. There is no means of dealing with this probl_lY_
except experimentally. If and when exposure to gasoline vapors ocpursl
to a significant extent in association vith mixing operations, standard
will need to be established and put into effect to meet the actual1 ,v
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conditions. If possible, it is veil to deal vith the gasoline hazard Y!
as an entirely separate problem, and to limit exposure to gasoline?
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in mixing operations to such an extent that the masks used against
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tetraethyl lead vapor will be directed solely against that hazard.
If this cannot be done,> period of use of the canister will have to
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be set to meet the requirements of the most concentrated vapor, that
of gasoline, in the mixture of vapors to vhich men are exposed.
Cumene
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The toxic effects of exposure to cumene have not been fully
investigated, so thatsIt Is not possible to set up a standard of
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safety for prolonged regular exposure. Vork is under way at the .
National Institute of Health in Bethesda, Maryland, U.S.A., but has
not been completed. Information on acute effects is available and a''
copy of a reprinted publication is enclosed herewith. It seems pro-
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bable that the concentration of 50 p.p.m. Is reasonably safe and it
is not surprising that exposure to concentretioro of several hundred
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parts per million caused difficulty. The observations made at Abadan!
are of great interest, and the handling of the problem as indicated^
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is cause for congratulation.
Signed:
. V__'r ' WiMMk`if'
Robert A. Kehoe, MVD.-^u,
Chief Medical Consultanf
Associated Ethyl CompaiiygLW
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