Document LpJkEVXj01ryxdVa9qO8K3mNb

I*4 t LAW--OrF F I C E S^ O F PIL3BU.RY, M ADISON a SUTRO F STANDARD OIL BUILDING ' SAN FRANCISCO February 8, 1935. _ _ _ _ _ v. Standard Oil company ~of California Dr. Robert A. Kehoe, . College of Medicine, University of Cincinnati, Cincinnati, Ohio. Dear Dr. Kehoe: Thank you for your letter of February 5, 1935. It is indeed unfortunate that we did not have the benefit of your testimony at the trial in which the Standard oil Company of California was sued for damages for claimed tetraethyl lead poisoning. As it will be necessary for us to file an affidavit, on or before ten days from today we have taken the liberty of drafting an affidavit which we understand is in accord with your views. ?.re enclose the original and a copy for your files. If it is satisfactory to you, please execute the original and have it verified before-anotary public in your city and also have the notary's certificate exemplified or certified by a clerk of one of your courts of record. The clerk will know of the form of certificate which is necessary to make the affi- " davit admissible in our court proceeding. If you find it necessary ' to make any changes or additions in the affidavit please feel free to do so. This will necessitate redrafting and retyping the affidavit and you will necessarily have to arrange for this to be done. If it KJT .001.1843 . i -# fi -2 is necessary to consult an attorney to assist you in doing this, do not hesitate to do this and advise him to forward his hill to us. We have previously written to you concerning reimbursement for any costs you may be put to and also a charge for your services. You will note that the affidavit refers to and incorporate the article in the March, 1934 issue of The Journal of Industrial Hygiene. We will arrange to attach this article to your affidavit when we receive it back from you. We again remind you of the need of expedition and haste in returning the affidavit to us Yours Encs P. S,. Possibly the matter might be expedited if before making any changes in the affidavit you discuss them over the telephone either with me or with Mr. Eugene D. Bennett of my firm. For your further enlightenment I am enclosing portions of the transcript which I have had copied so you may see just what it was that was said. F. T. S,, HE 001teso In the Superior Court of the State of California, in and for,the City and County of San Francisco 'I '`I Plaintiff, vs. STANDARD OIL COMPANY OF CALIFORNIA, a corporation, Defendant. ) ) s) . ) ) )... Wo. 244538 .... . . ) ) ) -- AFFIDAVIT OF ROBERT A. KSHOTS STATS OF OHIO, ) )ss. County of Hamilton.) ROBERT A. ESROE, being first duly sworn, deposes and says: That I am now and for more than ten years past have been a graduate physician end am now associate professor of physiology of the College of Medicine of the University of Cincinnati; that for more then ten years past I have been engaged in extensive investigations concerning and involving lead hazards associated with the distribu tion and use of gasoline containing tetraethyl lead; that I am the Ribsrt A. Kehoe quoted and referred to in and by public Health Bulletin Ho, 158 of the United States Public Health service, dated August, 1925, and am one of the authors of the article entitled '"Aa Appraisal of the Lead Hazards Associated with the Distribution and Use of Gasoline containing Tetraethyl lead,' published in the March, 1934, issue of The Journal of Industrial Hygiene, Vol. XVI, So 2. A copy of said last mentioned article is attaches hereto end 'harked Exhibit "A." That the facts, conclusions and opinions stated - 1- in end by said last mentioned article were set forth and expressed therein as the result of -my studies and investigations aforementioned and the studies and investigations of the co-authors of said article, to wit, Prsderlclc Themann and Jacob Cholak, end that the statements contained in said last mentioned article are, to my knowledge and belief, true and correct. In so far as the aforementioned public health bulletin or to my knowledge any other public health bulletin is concerned, there is nothing said by ne or attributed to me to the effect that there is danger of lead absorption as the result of exposure to gasoline containing tetraethyl lead and as pointed out, illustrated ana stated in the aforementioned article published in The Journal of Industrial liyginne in March, 1934, there is a complete and definite distinction and difference between the toxicity and danger of lead absorption from concentrated tetraethyl fluid and the gasoline treated with such fluid. This distinction and difference is illustrated and made apparent by the fact that whereas there have been substantiated cases of lead poisoning from the handling of and exposure to the concentrated tetraethyl lead fluid, there is, so far as I know or am advised, no substantiated case of lead intoxication or poisoning up to the present time in the United States as the result of exposure to gasoline treated with tetraethyl lead in the commercial form in which said gasoline is distributed, which is approximately one part of tetraethy* lead fluid to 1,000 or more parts of gasoline. Among the reasons for this being so is that while tetraethyl lead alone or in high concentration In gasoline is rapidly absorbed through the skin, its absorption is retarded greatly by dilution in gasoline. I have been unable to obtain evidence of lead absorption through - 2 <* r> rr th skin of experiments! animale after their prolonged exposure to one part of tetraethyl lead to 1,000 parts of gasoline "by volume. The dilution of tetraethyl lead with gasoline also largely eliminates the danger of lead inhalation. The difference between the volatility of tetraethyl lead and the various gasoline bases with which it is mixed is eo great that approximately one-half the gasoline may be evaporated before lead can be found in the vapor. It is my opinion, therefore, that th vapors arising from leaded gasoline do not contain appreciable amounts of lead, ; I have had presented to me the hypothetical case of a man between the ages of 45 and 50 years employed as a pumpman aboard a vessel carrying gasoline cargo end who states that he was present in vi pumproom of such vessel during the time it was discharging cargo for s period of approximately six hours, during which time he was exposed to the fumes of tetraethyl gasoline and contact with such gasoline on his hands and feet; that the ventilation in said pumproom was poor due to the failure to operate of certain mechanical means of ventilation; that while he suffered some nauseo, headache and other aches and dizziness he nevertheless was able to continue his duties in said pumproom aboard said ship for several hours ufter the aforementioned exposure and for a number of days there after continued to regularly perform his duties aboard said ship without hoeritfilization or medical treatment and that approximately a year or a year and one-half after such exposure he was physically examined and there were found no signs of stippled blood cells, lead line on the gums or anemia, but in the opinion of the examinSg doctor there was a disturbance or destruction of certain nerve senses and control. From such hypothetical case it Is my opinion that such person had not suffered lead intoxication or poisoning and that such stated resulting nervous disorder is not attributable to lead -5- poisoning or lead exposure in the particulars and extent stated and such opinion by me would not be altered -even though such person had previously bees exposed to contact with tetraethyl gasoline or contact with the residue, if my, accumulating in and about the place or places where he was accustomed to work. In other words. if such person had previous contact with tetraethyl gasoline or its said residue and had ingested lead by reason thereof, in my opinion the particular exposure at the time and place above men tioned would not sufficiently or at all aggravate the extent o.C lead accumulation in the body of such person sufficiently to cause or result in the symptoms or disability claimed, or any disability. Subscribed and sworn to before me this day of February, 1SSB~ - 4- s s m ^ i e. mmm. STjEARD OK, direct, termination of DR. GEORGE E. BAKER HR. FORD: Q,. Your name is George 'E. Baker? A. Res. 0. And what is your profession? A Physician and surgeon. Q. And, Doctor, of what school are you a graduate? A. University of Pennsylvania. C. And when about'did you start practicing? A. I started private 'practice in San Francisco in August, 192?. Q. ted have you practiced here since that? A. I have. . Q. Doctor, did you have occasion-- I will fix the date later on-- to meet Hr. ^ A t :0 plaintiff In this case? A. 1 did. C. And have you- seen him from time to time since that? A. I have. _ Q. ilnd have you made frequent examinations? A. I have. 0_. Doctor, without-- first, before I put any hypothesis to you-- did this'examination-- was this a complete physical examination? 0. Doctor, if you assume that H r p r i o r to March 10, i93,-- keep the date in mind-- was in the employ of the defendant in this case as a oump man on one of its tankers carrying gasoline and that on a trio shortly before March 10 the blower in the pump room was completely out.o^ordeg, so that the room was not being ventilated, and that dr. for a period of about six hours, was subjected to the fumes of Ethyl gasoline; ana to-- because of cer tain leaks, also not oiu.y the breathing of the fumes of Ethyl gasoline because of no ventilation, but contacting it, the floor was wet, his feet were constantly wet with gasoline, his working around pumps where at times there were leaks so that it was on his skin; he was back and forth asgd would go up on deck and strop for a few minutes and come back into the pump room; go up for the purpose of drying himself out and getting some fresh air and come back info the pump room where he was again subjected to the fumes; that follow in? this period of being subjected to those fumes and contacting this gasoline he became nauseated, and he had a feeling come on of a deadness in his feet; his skin became-- I sn trying: to think of the term they used-- sensation on his skin; his lungs hurt him; his stomach, he had pains in his stomach; his nose ana throat were irritated and his skin felt irritated; he left the ship on March 10 and has not contacted gasoline since; he has remained away from it; that is, March 10, 1331. Row, with that brief history and v.ita those matters that I have given you tnat he claims-that he felt arid taken in connection with your examination, will you tell the jury what examination 3:011 made and what your conclusions were as to airy condition you found. TIE COURT: Can you recall that question? There is no objection to that, Mr. Bennett? ' Hi. BEi'DiETT: Y-.e would have objected to it except- this: he is calling the doctor out of order; and having consented to the doctor beln" called out of order, we are hardly in a position to lay any objection to any foundation. .X. FORD: I don't want to uit Mr. Bennett to any dis advantage ; 'while it would- be quite a cisadvantace to the doctor, I would rather bring him back. 0011855 ii'L,. DrEHETT: I am not making the objection, because X have agreed that he may be put on out of order. I do not i'-eel-- ah. FORD:-- I don't rant you to out me in a position-- THE COURT; I just ranted to be sure of that, because hr. Foster is replacing- Mr. Sims for the purpose of taking testimony, and 1 didn't want there to.be any difficulty' about the repetition of the question by reason of changing reporters. ' MR. FORD; Before you leave, let me add to that question just one thing. ' Q. Doctor, will you also assume that Jar. following the matter I have just related to you, became s M W l i S y nervous; -that he slept poorly, haying difficulty going to sleep; when he would go to sleep would wake up with a start and what he would call bad dreams, such as accidents and so forth, and that this nervous condition has continued up to and including the present time, and these other conditions have continued from then on up to and including the present time. ' MR. BEliHETI: Of course before this question is answered and in the light of your Honor's question to me, I do not 7-ant it to be conceded in any sense that we agree that the facts are such as recited by Mr. Ford nor that there is sufficient foundation; but I am not making objection at this time to the doctor's testimony, because of the fact he is called out of order. THE COURT: Of course, Mr. Bennett, it is understood that any answer to any hypothetical question is necessarily based upon- the proof of the facts stated in the hypothesis, and if any of them are not nroven, of course the hypothesis is not comlete end the answer would fail to that extent; that is understood always; tut you are not objecting to the particular question being answered now on account of the doctor being called out of order'? ;iR. BEHHRTT: Yes. Mil FORE: Your Honor will have in mind, please, that I have not aimed to give the doctor anything that does not already a 'peer in the evidence. TEE COURT: I know you are trying to do that, Mr. Fora. MR. BEDEETT: I do not concede that th; t is so, but there is no need to argue about it at this time. THE COURT: It is substantially correct, at least; there may be one or two items in it that may have to be cleared up later that we may have a record of it so that the doctor can answer the question. Do you recall it, Doctor? A. It was a hvoothetical question., your Honor, regarding whether I thought it -ossible xaat this exposure in the pum? room was causing these things of rnici: this man complained. tion . THE COURT: That is also based, I think, unon your examina Pit. FOi-iD: X was going to call his attention to that. C. Have you included in your answers an observation of the man? THE COURT: That Is correct. That is correct. r.tn. HE "T _: Hay I ask the doctor i. preliminary question as to when this examination ns made? O f\ -s ! f* * .? . a', 'CDUhTp^yss^Z think that is fair. ' - - I first su'.v ..a July 7, 1925, at my office. He gave a story :i` n&yiniH^^W^HiJpsecl to these fumes of Ethyl gasoline aboard tki tanlirer 'the. "Harper" . . EEH1IETT: Q. 'that is July 1933? July 7, 1933? v m tne first time I san him. 'ii:z r.c also give you the dates as to \;hen he was aboard the .>-ii i. I have few dates here. -. s toad you: it was Over & year previous to that time that he left the Sharper"? -.^ h e s ' \exactlyjilt had been over a year. At the time that f 'sqw isr. Wfjffmii6 time his orincipal complaints were of general, bodily!/##hkHdss, shortness of breath, pains in the'chest and a'rdoMen, headache-, cirstncs:;ting Ling, which he described as sin and needle sensation i n the feet and. hands; he was constipated; ' lie nad 'oor memory and' disturbed sleep. His temperature was normal. His pulse, was slightly eieyatsd. His blood pressure was within normal limits.' 'The past medical history, as far as serious illness was concerned, was negative. Me had had his tonsils removed. His story at-that time was that he was in good general health until the onset of the present illness, which came on while at-work aboard the steamship "Harper" where there ras- a breakdown in the pumping equipment, causing a leakage of a great deal of Ethyl gasoline into the curas room where he was working. Me also said that he was sprayed, with Ethyl gaso line. which ran onto his hands and arms., and soaked his clothing and shoes;, said there was no equipment operating in the nuan room to provide fresh air, and the fumes of gasoline were very strong, making him dizsy and yea::, and making the eyes smart. Several times iie went- to the deck for fresh air, and to let his clothes dry out. Following above incident, he gradually became weid-c, short of erect, with rains in the chest and stomach and tins and needles in the feet and uands. IZ. Edit: i. Doctor-, could you go a little slower? 'Ine reporter may be getting it but he is having a touch time. A. 0 . M. The bowels became constipated this time, and the stool was trnack. The skin was pale. There has since been much roaring in the ears and sleep has been poor, restless, with annoying and disturbing arearns. Anc at no time- -was there loss of consciousness. There was for a considerable time follov.'ing the above incident a burning sensation on urinating, he now tires, very easily. There nr.s been no loss of s shineture control. That means the valves that regulate the bowels and !ladder. Th. BSTlIEIl: a. You say, Doctor, t liare was no loss of ta t? Thera was no loss of s whine ture control. \. You mar.:; by that, it was normal? 1 . Yea-. un .'nysieal examina tion I have the following notes: that he an "-eared underweight; that the skin and mucous membranes were not pallid or indicative o" jaundice; his teeth were in only fair condition. There was no lead line observed on the gums. The puwils of the eye had the normal reactions a... liant end distance. She gait-- that is one mode in which he talked-- vas of sio -py ty >e, but he did not actually stagger. His 'osture and station, as we call his mode of standing, vus of norm; i ty-.s. wo tic. not stagger when his feet were nit close together and rad his ey~s closed. THE COHs -... That is the Babinsky test? A. T n t is known ar the Romberg. The Romberg reaction was not -'resent. !h_ Tod-j.; ... do tab insky taken. .1 , I getting to that, your uonor. hose and throat; tnere was nothin ; remarkable exeat the:!]. In regare to tan ears: he h.ad fair nearing, an., an examination : It h an o tosco .-e inni is. looking in tv- ear at m e cru-;-., va; narrai. He . r o o m m d increased knee jerts_ ~hi>:h I might -?3 sr:c hxs been-- the knee jerks have been increased ;?-.;ry examina si-.-' I heve rn.-.ce since. There was no undue weakness of the extensor muscles. I might say by the extensor muscles v;e have particularly in mini the muscles that-raise the wrist and tne muscles that raise thh foot, he had no loss of sense ef position of the limbs. V it's his eyes closed they are oointed up, down, sideways, and so on. lie could find that out every time. In moving, in quick movements of the hands and feet he had complete control and w a s ' s,tle to nove them rythnieally and in the proper order. In the extreme ties he showed ability to differentiate hot and cold and also sharp r.r.d dull, the Achilles reflexes-- that is the jerking motion that was gotten from tap.::in:: the Achilles tendon back of the heel, was very siov.; and we had to give him what v:e call reinforcement in order to'brir.g that out5 v.y had to-have him cull one. hand against the other. In that way the reflexes were brought out, but they were never of normal quality. He also had a very definite intention tremor of his handsj .in other wardsv.'wben he would hold his hands there was a very coarse sort 'of tremor. The impression at that tine, on first seeing hr. ^iljedal, was'that-'he had some degenerative changes of his brain and cord, arid that,:'due. to the history he gave. me 1 thought they were likely due to Ethyl lead- intoxication. How ever, I felt at that time that primary anemia had. to be excluded and suggested that he have a.'blood count. That blood count was taken on -July 8 , 1333, with the following results: he had hemoglobin 97 per cent, 'which is well above normal, we might say. I normal for an adult man is 35 to 99 per cent; Hr. Biljedal had 97. He had 5,410,000 red cells, 'whereas, ve might say 5,000,000 about represents the maxi mum normal. He had 10,750 white cells, which we might say is within normal limits; and that the relation of the hemoglobin or the coloring matter in the .blood as to the number of cells is represented by the factor .31, which is within normal limits, and not indicative of a pernicious anemia. He was in the office again on July 8 . I made a few more examinations of him. Again the patellar-- that is the knee jerks-- was 'exaggerated. There was no Babinsky response elicited on scratching the bottom of his feet. There were varicose veins of the legs noted, with scarring from operation. He had raucous mem branes and skin that shored neither pallor nor pigmentation. Tne Soleen was not paitadle. T.:e heart vas within normal limits, one tier were a few coarse rales is: the chest. Hales, I might add, are caused by stickiness an:, mucous ana so on in the various tubes and air space: TAT COUi'T: -hat is an abnormal some: A. That is an abnormal sound. In this case I take It indicative of possibly being from bronchitis, due to the fact that ne had no fever and no evidence cf any eneumonic process going on. he saw him again on Atril i3 1351. At that tine air of his previous complaints, exee"t nis constipation were present, Anamination vas as previousiy. exee-t in at there v:as a doubtful i.omberg reaction obtainee. ley 3, 1951. me feels about the same, ana complains greatr: of '-ins e:tneedles it tae feet ana hands, and of poor slee :. Tne examination :t that time was the same. On June 13, 1951, nit com \Uints were :.e be fore. knee jerks continue hyperactive; ankle j a m s are sluggish. There is no loss of pupillary reaction ana no loss of.sphincture con trol. August 3, 1331. Knee jerks were very lively. Ankle triceps biceps, refluxes were mere active than previously. Tne skin tn... mem branes war: found to be norm.l. There was no lead line on tne gums. August Li, 1981. Ail of the original complaints continued unchanged exeeot for slight if any increase in general strength. He dreams. -"is dreams continued to be disturbing, causing a disturbed rest. And -ruabness, the tingling and dewiness of the feet and legs and to a less extent of the h a m s , ne continued to comrlsin of stegrerin, , .n: his gals, I night :.oc , was practically the same as it was the first time I saw him. Tree staggering e hen he veered war rsieuir:ly ' ha. p- zr.e way. v fen ne vent to turn share..:' on a corner or seme- . ~ - -- 1~ . r-hhlihl: . Doctor, Ere you Vieliffluif^f1';what you observe;: V L. Si '.bet I observe;' of the "utient. .. 1 rambling .d; , you mean? ,,,. X said "stirgoring" not "stammering"-- "staggering. ' A. I thought you salt first, "rambling*1-- rambling gait, i Hanoi!n; fait, not speech. 1 . Tier11 X understand. you in trie first rvrt of your testimony to say that he did not stagger? ' A. Ihere was no true stagger as we imov; it, such as a drunken person vouic. exhibit, tut his gait was not that of a normal lively individual. 1. It ran a rambling gait as you described it? A. yes. His complaint of dizziness was unchanged. He v.as at that time-- on August 5, 1334, he coma-lainea of a continuance of this pain in the loner chest, both front arid back, and over the entire abdomen. That, by the way, got worse periodically. He would, have several attacks where the distress in the abdomen would become worse, from two to five times a day, which would last from-- ordinarily last from ten to twenty minutes a time. iR. LBilHETT: Q. Forgive me for interrupting him. You are now recalling things that he told you, Doctor? A. Things that he called my attention to, that is true. He com plained continually of having a bad taste in the mouth, particularly in the morning, and almost always had, a frontal-- that is a forehead-- and a temporal-- side of the head-- headache; and he had this tremor in the hands. At that time his general condition was good; his color was improved, ny the general condition, I might say we would compare the general condition at that time with what he had shown on previous visits to the office. Again on August 9, 1934, general condition was unchanged; the intention tremor-- that is the tremor in the use of the hands-- is more pronounced. There is no tremor of the tongue. The pupils were reacting normally, and his general strength was im proved cut he still complained of tiring easily. September 19, 1934, complaints as previously.. There is no loss of thermal sense in the hands or feet, by thermal sense we mean the sense that differentiates heat and cold. HR. BEdidETT: Pp.rc.on me, Eoctor, for intern-ting asain, but you are going so fast I didn't suite get that. i.oulu you mind repeating the last answer, a . on September 13, 1334. nis com plaints were as before. On examination we found there was no loss of the thermal sense, which is due sense of differentiating heat iron; cold. HE. BEKHEt T: Q. In other words, you mean ty that that in your tests, so fur as you could observe, he could determine? A. Yes, re use"' two test tubes which are exactly similar in ap -ear- cnee, and in one of" them we put ice water, and in one of them we -ut very hot water. -And by covering his eyes we test 'Prtieular_v the hands and feet and .legs, these areas he has c o m i n s r . of, to see whether tner-e is any inability to tell heat from cold. Each time we would touch he says, "dot" or "Uold"; and if he gets -it right we say he is u. ,i.; if he misses then, then we know that, there as some less of that sensation. C. Just one minute, four tests showed that he had normal function; that he could distinguish between them? A. That is true. ' C. And that his thermal sense, therefore, vias normal? A. There wes no loss of sensation of the-- there was no loss of sense of -osition of the fingers or toes. There was seme decrease in his vibratory sense, which re tested at that time. In other words, that his sense of vibration that we get from touching some tony orxrrnence, such as thr bene around the knee or around the ankle, with a vicretins tuning for';-- ordinarily a person is able to 'ick th t to: very m d i l v l - 5- UB 0 0 1 I S S 9 He had a condition there where he was not certain many times whether the tuning ford was vibrating or whether it was still. His knee jerks continued to be hyperactive. The last time he was in the office was January 19 of this year-- January 19, 1935-- when he com plained of having a cough, which had -been worse at night, and had. been troubling him for the past two or three months. His claim was that it was becoming more severe. He had taken some cough mixture without any relief. His nervous.system complaints continued un changed. I tested him again for this thermal sense, which was normal. I tested him for what we call pin-point discrimination, in other words, telling whether they are sharp or dull, which was normal. His knee jerks were exaggerated. His Achilles reflexes were sluggish and re quired this reinforcement in order to elicit them. Pupils reacted normally, and in his chest we found more of these rales which we had heard.once before. In other words, he had a moderate amount of. bronchial irritation, .There is one thing I might add which has not been mentioned here.' In all of the conversation with Mr. Liljedai, and in all of the examinations, that I might say there has been a definite change from normal in the speed with which he answers ques tions, and in the mode in which he understands and so on. It seems that oosslbly-- we might say it takes a longer time for the question to sink in and register than ij; would with the normal individual. I too feel that in spite of the fact that he is a man who was not born and raised in this country and who more or less speaks with a dialect, that there is a tendency of this slurring of his speech. I do not feel that he speaks with the moderate-- with the average control of his voice that we would expect a normal person to have. In view of the history, in view of the fact that we have not been able to demonstrate on him any pernicious anemia, which at times causes those changes in the nervous system which may simulate this condition which we have in him-- I say we have never been able to demonstrate that; his blood has -always been about normal; he has not presented some of the other things which we would expect to be present in pernicious anemia by this length of time-- i can't help but feel, after considering his- history of exposure to this tetraethyl lead gasoline on this one occasion, and the possibility of having been exposed in a lesser degree on previous occasions-- I can't help but feel that his trouble is due to lead intoxication with tetraethyl lead. MH. i*OHC: c. Doctor, in tetraethyl lead poisoning, v.ili you tell the jury whether or not a person who has been subjected to that poisoning has some of the appearances of aneraiaV A. Tetraethyl lead poisoning is not typical of the, usual lead poisoning in that it being a volatile material, it is soluble material which is subject to being taken in very ra-:idly by way of the _ung. It will -penetrate through the skin, and it can-- of course like other lead substances, it can be sv/allowed; but many times nervous symptoms will develop long before the anemia will develop due to the fact that the stuff is so soluble that the nervous system is damaged before the blood is. However, anemia is a very very common symptom with Lead poisoning of any form. Doctor, let me ask there, so that the jury will be able to under stand, in this tetraethyl lead gasoline, if that is the pro '-cr name to call it, you say this lead-- let me change that ana put it this way: in this tetraethyl lead gasoline how is the lead taken into the system where you inhale it or where it contacts your skin? A. 'when you take it by inhalation it dissolves through the little mucous membrane lining of your lungs and immediately goes into your blood. It goes in much the same as ether would do if v;e were to take an anesthetic and the stuff would get into the blood streamcausing anesthesia. It belongs in a group of things which v.e coll fat solvents which are absorbed by Way of the lung. Also it has the ability to )enetrate through the skin and get directly into 6- - - \ '`r 0011360 the. circulation that way. \ihat; is:there about the tetraethyl lead gasoline that permits the lead to be directly taken into the blood stream? I The fact tnat it is not a metallic or a solid substance, but the fact that it is a compound. made from lead and the ethyl radical, which is a relative of alcohol and ether, it gives that volatility, that ^hijity t.o vaporise and top. absorbed just similar to what ether has uqhepwhen you give an anesthetic at the time of an operation. Q. low, in speakihg' of this itetraethyl lead gasoline, is there more than one poison ini that makeup' or compound? JL. hell, the serious one. the[ one wikLch,'vie...consider the most, is the tetraethyl lead fraction! itsjelf., Tetraethyl lead is a definite chemical compound of certain proportions of carbon and hydrogen and lead. HpifeVer, in the .gasoline we'have the same fractions which .occur in ordinary gasoline which1are of a toxic nature, and we also have a third compound known as ethylene dipromide, which is added to the ethyl gaaolJjne. iii order to make the ethyl gasoline a safer thing to use in an automobile. In other words, if we iyere not to use the ethylene dibromide, when that d;hyl gasiolipe were burned, v,e would have a con dition wherein;the lead, in the .form of metallic lead, in the form of oxides of lead, such as red lead and white lead and so on-- they would be thrown out Onto our streets and in our garages, forming dust which would be'definitely dangerous tp the population at largej " but in the use of ethylene dibromide in this gasoline the combustion of- the ethyl gasoline then puts the lead in the form of lead bromide, which is a relatively insoluble and a, relatively unpoisonous form of lead. But Ethylene dibromide itself in the unburned state has toxic quali ties . C. Doctor, with this combination of the gasoline, the tetraethyl lead, what becomes of gasoline that is spilled on the floor; does it evaporate? k. Tetraethyl load boils at a higher temperature than ordinary gaso line. Therefore if we were to shill some on the floor the proportion of evaporation would be much greater in the gasoline element of what was spilled than it would be in the tetraethyl lead element. Therefore the stuff would bit by bit become more concentrated as it laid on . the floor and the fraction of that stuff which was made up of tetra ethyl lead would become greater. C. V.nat effect has the ted so far as nervousness is concerned? now does that manifest itself In.a person who has contacted it if lead affects the nervous system-- A.. Primarily affects the nerves themselves. It is.a direct nervous system poison, causes degenerations and shriveling up and actual destruction of nerve tissue. It is*-- in the ordinary form of lead poisoning particularly affects what we call the extensor muscles; that is, it gives a paralysis of the nerves which have to do with enervating those muscles which raise our arms ana wrists up*. It is shown from experience that tetraethyl lead, when taken in massive doses can cause a thing as severe as acute insanity of the most manic tyoe: that the stuff has been shown, in the earty days of the manufacture of it, when the safeguards were not ordinarily up to standard, that there were a number of cases-- now, I should say offhand there were in the neighborhood of twelve or fifteen .cases of acute insanity which came- on following exposure to this material. In other words, it shows a predilection right along to affect the nervous system. I., Doctor, there is one other matter I want to ask you, and. I an asking so the jury will get this: often we have in mind medicines that are taken that have certain poisonous qualities but taken in doses of a size where they are beneficial rather than detrimental to a person.. V.'ith this lead, this tetraethyl read, I want you to tell the jury whether or not that is cumulative, If that is toe proper word, or whether you could take it in small and targe quantities and keen that time after time without detriment, or does the adding-- this taking it in through your skin, or contacting it through your .Lungs, cumulate that lead poisoning? - 7- K 0011861 A. ^ecn is one of ths classical examples of what we cell a cumulative ooison. If ,lie take in each day the amount that our kidneys and bowels' ere stile to throw off each cay we will never have lead poisoning, however, that amount ,,is., exceedingly small, ana .where we. get more'than the amount we are able to get rid of each day we get a storage of - lean, trncler average conditions, pf lead in the bone .just the same as line is tied up in the bone, combined with phosphates. Should a person through some other minor affair-- we ^ill- say he should get a eold or he should take too many drinks'of whisky or he'Should get on a diet of too. much meatand. eggs aifd ihot;.endugh vegetables, rendering \his sys tem temporarily acid, much .of that lefeS will be liberated from the bones, and when that'Concentration of: lead in the circulating blood reaches a certain: figure, he;v/ill'develop' Symptoms of Head poisoning, which, otherwise; might not be orosent at all, .There is a tendency .. , ; for the lead'to'pile up and the symptoms do not occur until the lead in the circulating blood reaches a figure strong enough to cause the change. _. : 0 . Then, as i understand you, the system will throw off a certain amount of lead poisoning so; we 'can. thro?/ off a certain amount each , day, but beyond that vie can't-- beyond that, if we take more than that, ? our system usually stores it. : q . Doctor, let me ask you then, taking the hypothetical question which x gave you, which is father meager as compared to your examina tion of this man do 1 understand that it is your opinion that he is suffering from tetraethyl lead poisoning'? A. It is my opinion that 4 ? is suffering from the changes that occurred in his nervous s^TenTpartichlarly and in the rest of his body to a less extent, following exposure to tetraethyl lead gasoline. MR. FORD: I think you may cross-examine. One other thing: 0 . I wanted to ask you, Doctor, where a person has been exposed and . his system succumbed to the tetraethyl lead gasoline poisoning, if that is the proosr via;.' to put it, is that a lasting conuitijn, or will treatment cure you of it entirely, or what is the fact? A. Dell, of course anemia can be overcome; the condition of his bowels and the condition of his chest should tend to alleviate itself after time ana rest away from lead, giving him proper diet and so on. But of course these changes in the nervous system, once they are ' established, they never tend to recover. Those nerves are actually 'milled and v/e can't possibly in any way regenerate them. 0 . will you explain to the jury what cart of the nervous system is affacted ? A. In view of my examination and observation of Mr. m it is my iirra belief that he has several places that are directed, iiov:, judging from the examination first of all of these knee jerks that have always been exaggerated, th-.t makes you think that somewhere between the spinal cord and the brain there has been some particular motor pathways that have been -put out of business. In other words, those jerks reflect that the control from his brain to the muscles has been interfered with but that the pathway between the spinal cord and the muscle is still intact. Therefore,the trouble must be somewhere between the spinal cord and the brain, his symotoais of numbness, the tingling, disturbed sensations in the hands ana feet are being taken as in dicative of another portion of the spinal cord being involved, namely, wont are known as posterior columns, which occur in til* back 'art of the spinal cord. .. 0011362