Document JJ867ORQ87957ed7avMEJ0bva

U. S. DEPARTMENT OF LABOR CH I LD REN ' S BUREAU W A SH IN G TO N October 20, 1922 Air*- i.AlIL Dr. Bobert A. fehoe Kettering Laboratory of applied Physiology Aden Avenue Cincinnati., Ohio Dear Dr. Kehoe Thank you very much indeed for your' oi October 15 with reference to the preliminary craft of our standard for minimum age for employment in industries involv ing exposure to lead. We are very glad to 1-mow that you are in accord with the spirit and statements contained in the draft, even though you feel that in some plants significant exposure may' occur in offices and other places where isola tion is not adequate ana control measures are lacking. There is, of course, at present no Feaeral minimum age standard for occupations involving lead exposure, so that vie hope the effect of this voluntary standard will be to improve the placement of young workers to some extent and to supplement existing State laws ana regulations. Some reviewers of the draft, have suggested an addi tion to item 4 for the purpose of clarification, so that it would read as follows: n4. Work in connection with tetraethyl lead. (a) Tlie manufacture of tetraethyl lead (b) The mixing of antiknock compound (c) The blending of gasoline and antiknock com-oound.,1 N 6286 I would like to know whether you think that this list makes the coverage clear and specific. , flay I again thank you for giving us your detailed comments and suggestions Vj 0002370 Sincerely yours, ^ . ia) t^tcu*c ^ ' u T / October 15 19^2. Dr. William M . Schmidt, Medical Consultant, Industrial Division, b . S . Department of Labor, Children *s Bureau, Washington, D. G. Dear D r . Schmidt I have your letter of October 10, together with the attached preliminary draft of certain policies with respect to the employment of minors in the lead trades. I find myself in complete agreement with the principles and statements in /the preliminary draft. There is no question, I think, concerning the greater susceptibility of minors to the toxic effects of lead absorption. For this reason alone, 'minors should be protected against any other than slight lead exposures. Nevertheless, there are a number of jobs available in most of the lead-using industries, that involve little or no exposure to leacl compounds. There is no good reason why such jobs could not be handled satisfactorily and without undue risk by persons under eighteen. There is only one difficulty that I anticipate in this connection. There are still a considerable number of industrial plants some large, but for the most part small, in which there is no adequate medical or hygienic su pervision. of workmen and working conditions. In some of these plants, and I fear in many of them, there Is no adequate know ledge of the severity of the hazards, and there is no such iso lation of different parts of the plant as will provide safety against lead exposure in offices, shipping rooms, and In other places where exposure need not exist. It seems reasonably cer tain to me that if the bars are let down, youngsters will be employed In some of the presumably safe areas in plants of this type. If I were sure that there was a sufficient amount of general control to provide against lead concentrations in excess of the present standard of 15 milligrams of lead per 10 cubic meters of air, I should have very little anxiety about the re sults^! am somewhat disturbed, however, by the fact that large numbers of plants have no knowledge of the magnitude of their lead exposure, have never had a plant survey, aiiid do not even know that such a standard as indicated above lias been promul gated . My ghees, which Is based on experience, is that the largest proportion of lead workers in the United States are working under conditions in which there Is neither adequate 0002371 Dr. William II. Schmidt * (2) - October 15, 1942. ! medical supervision nor engineering control beyond that provided by the use of mosks and by improvised and untested ventilating equipment. Accordingly# I am disposed to feel that any apparent relaxation of standards might have disadvantageous results at this time. I believe that considerable car should be exercised in the manner and in the locality in which this policy is applied. I repeat# however, that despite all of the reservations Indicated above, I am in complete agreement with the spirit and the state* ments of fact contained in the draft. Cordially yours, KAK ef Robert'rA . ehoe M. "i5 '^iLs U. S. DEPARTMENT OF LABOR CH I LD REN 'S BUREAU W A SH IN G TO N October 10, 1942 Dr. Robert Keyhoe The Kettering Laboratory of Applied Physiology M e n and Bethesda Cincinnati, Ohio . Ky dear Doctor Keyhoe: ' The Division has the responsibility of issuing standards for minimum age for employment in various occupations. Under the Fair Labor Standards Act, which establishes a general 16-year minimum age for factory employment, the Chief of the Children* s Bureau may issue hazardous-occupations orders which have the effect of raising the minimum age for employment to 18 years. Six such orders have been issued. At the present time, we are contemplating the issuance of certain minimum age standards, hot as mandatory orders under the Act, but as standards recommended for voluntary compliance. These standards would be distributed to the industries concerned, to Employment Service offices and the like as a guide for their employment policies in an effort to encourage well-planned place ment for boys and girls 16 and 17 years old. The standard on occupations with lead exposure has been informally discussed and well received by several persons connected with the industry* Because of your long experience and extensive studies in this field, we should appreciate it very much if you would re view the draft which is enclosed and let us have your comments and suggestions. We hope to proceed with publication in the near future, and we will be glad to have your comments as Soon as possible. Sincerely yours, Ehc. William M. Schmidt, M. D. Medical Consultant Industrial Division N 6286.02 Tillliam U. bchnidt, October 7, 1942 i Preliminary bruit. 'or lieeueadon P a r i s e s Only WARTIME Il'PLOiMU-T OF 1 6 - 3D i?-YEA;i-Q L2 HUSOES 1:4 OOCUPATIOnO flT h IfCPOfUfE 70 LEAD LED 170 COMPOUNDS ' *- Lead is extensively used in industry under normal circumstances, ;' ' End as an important war r*tal it is being- evgn sore widely used at i present. In 1941.previous consumption records for lead were broken. - In spits of notable progress in control of the besard of exposure ! ju> lead and its compounds, lead res&ins one of the leading causes !1 /: ' of occupational disease other than industrial dermatoses. v ther ia an increasing employment of young person3 today >.,nc, to bn extent greater than ever before, boys and girls are being called dpon to bill jobs ordinarily held by adults. Many of these jobs are suitable and reasonably safe for young workers, but cone arc not, among the latter are occupations with exposure* to lend trust or ini;:?. .'specially under conditions of relative labor, shortage employers Fill want to exercise the best judgment in placement of young workers, reserving the more hazardous occupations for the mature workers v;no are, ds a group, better adapted for such employment physically and better prepared to protect themselves because of their experience and more careful habit of work* On the basis of visits to a number of factories using er pro1> jducing lead in various forms and consultation -vith. persons familiar With the industries, the Children's bureau is presenting in this Leaflet a list of occupations for which a minimum age for employment of 13 years is recommended. Some plants using lead conduct operations N 6286.03 of so varied a nature that employment of persons between 16 and IS years of age in some occupations in many of these Hants is not only feasible but nay be advantageous both to relieve_the ianedi&te labor situation and for purposes of training. Careful placement of young workers will help to meet the demand for labor without ' . rt" subjecting this group of potential soldiers and workers to unnecessary hazard of occupational disease, Tne maximua pernissiblo' limit of 1,5 ailligraao of lead per 10 cubic meters of air, which has been widely accepted, represents good engineering practice and a reasonably a&fc working condition for Adults except for those who are unusually susceptible. However, :young norkars 16 d 17 years of age as a group are considered to be more susceptible tliaa older workera. fork in which no vtramr worker.?- under IS "cars of am should be emoiovod The following list is illustrative end necessarily incomplete. 1, T-ork in connection with the production of white lead or other salts or oxides of load. There is. a considerable evolution of duet in sons of the workrooms of plants producing lead salts or oxides. Certain occupations in theoselves in these establishments are not accompanied by the evolution of lead dust or fume, such as the milling of white lead after it is incorporated in oil, but they say be accompanied by exposure to load dust arising' in other departments* There is, therefore, a potential hazard in all production jobs, end a Einimuia age o r i S should be observed except for work in offices which are fully segregated and free from the possibility of contamination with appreciable concentrations of lead dust* 2, *?ork in workrooms in which lead salto or oxides are used in such r state that they rive rise to appreciable concern ! trations of lead dust in air. (a) Compounding and batch-mixing in tho Esanutacturo of rubber, paint, lead-eontiiining insecticides, linoleum, and other.products into which, loud, compounds enter| ' (b) The manufacture of storage batteriesj (o) Spray painting end vitreous enamelling whan loiitWcontsiaiag asterisla are ueedj (d) Other occupations in which lead dust m ,y aria from the saterials of work such &e storage battery repair snd salvage, junk yard, work, sanding lead-covered surfaces, and the like* 3 Work in occupation3 in which metallic land ia regularly used in the molten state. . (a) Lead burning (b) Cable covering; ( c ) Type casting (u) foundry work with, load-bearing ratals (0) Cutting of lead-coated aeteis (f) Soldering, when carried car continuously as a regular part of tea process of production. 4* Work in connection with tee manufacture of tetraethyl load. Work in lead Industrios suitable for l6~ and 17-year-old workers. The following list Is illustrative end necessarily incomplete. 1. Cm. filling and labelling in paint factories. 2# Marking and testing of storage battery oaaea. and shinning departsont work. 3* Offioe and laboratory work in lead industries. The handling of lead salts or oxides which are completely incorporated ia a solution or suspension or are ia impervious containers does not involve appreciable h&s&rd, provided tee workrooms are segre gated fro those ia which lead compounds are used in the dry state, and aro essentially free from lead in the atmosphere. 3bsergence of legal standards i here lsgel standards tawsr State sad Federal law a- applicable i, sic eaploysmt of young workers la occupations involving exposure to load and its compounds those should bo fully observed* la spcifi situations in viiioh, the illustrations ere not 1 ' .. directly applicable, it is suggested that further information regarding the suitability of the work for young people under 13 years of ago should be secured from Stats departments of labor or from the Children1 Surecu, * S. Department of Labor, Washington, 1. C*