Document O1pN2Mv2rDjbkM64518JXRVkj

January 19, 1935 Mr* John dehaefer Ethyl Gasoline Corporation F* O* Box i88 ft'ilcfngton* Delaware Dour Mr* aohitefcr? 1 have copies of your various letters concerning toh information which is to be sent out to aiding plants of the tank storage type where Fluid is shipped and handled in drums It la. not feasible at this time to re-draft the reflations in relation to the hand ling of tank oar and tank storage.'equipment* This will be Amw within a reasonable period hut^I do not wish to do it until X have all of the nesressary Information, at 'hand-.as ;to '..hat Is likely to be - done in She ours of the next several weeks or months# fh whole question of the number-of drums involved in this business is at stake, and-X feel reasonably certain that .something- will be done shortly which will arterially reduce the number, if for no other reason than that the trassportation of the drums Is at present sufficiently dangerous to warrant careful examination*-: t shall refer to this later In-.this letter* .< , . tilth regard to the insfcruotlons to he stmt out, X think that every customer of th Corporatloiv hb Is now reoelving drums of Fluid for emptying in storage tank, should be provided with a sufficient number of copies of the now regulations concerning the handling of drums so that it will bo certain they they have available information on which to handle such drums properly* Moreover*' placards having to do with the handling of drums should be posted at these mixing plants along with tii other placards whlch invclve the handling of the bulk equipment* I should be made perfectly clear to th raonagemente and to the men that then now placards provide infottaation relative to the handling of drums only, and that they are not intended to govern th precise handling of the bulk mixing quloment. It should.he fully pointed out also that this is,for th present, a temporary measure in view of an lranediate necessity which has arisen for the re-editing of the HE 0000853 ii* John Schaefer regulations which arc concerned with hulk equipment* I am not afraid that the new regulations or the new placards will result is error In handling the Fluid at the hulk mixing plants for the manner of handling the Fluid and ashing out the drums after they are emptied 1ms been so arranged at these plants that no difficulties should arise* What I am afraid of is that i n -the absence of instructions the drums of Fluid will be improperly stored and improperly liandlodas indeed they have been in acane degree In the past '' . . . /: Hturning to the subject of transportation of drums I have only recently discovered that it is the general practice in coast-wlse trade, and for ought I know. In European trade to store the drums of Ethyl Fluid below the deck In e substantially enclosed com parfesent where they are stood on end and lashed in place as securely as possible* 1 have been under ths. . previous impression that it was the general practice to have the drums of Fluid shipped on deck* at least In a place where the :sides were open or fr`#ly ven* fcilatsd* find who re.,the opportunity existed for hosing . out any spilled Fluid* It. wee a shock to me 'tofind out tlvat this la not the case* I mist come to the conclusion that our prosent method of transporting drums on. ship board is-unsatisfactory definitely ;. un-aafe* and that it is simply a means of Inviting trouble and diiiaStor*It is not proper to say that the dangers are imaginary rather than actual* since I have already established the fact that in at least one instance, considerable quantities of Fluid have been spilled in a compartment under the deck of a cargo vessel hot the property of on of the Oil Shipping Companies' '.'ho Fluid in this Instance was cleaned up as satisfactorily as possible by a repre sentatlve of the Corporation* but not without Involving an exposure to lead on his part which Is by no means pleasant to contemplate* Mr Walter and X have dts- cussed this matter* and wo are of the opinion that ^ Something will have to ba done to. make certain that E this condition does not exist In the future* Either the tankers and other cargo vessels will have tp make provision for carrying Fluid on deck# or they will nob be permitted to carry it at all* One other word with regard to regulations and placards at the bulk mixing plants in which drums are handled* I am writing Ur* Walter today# suggesting that a field representative of the Corporation make it a point to disciuss with the management at wahh of these points# the matters in the drum mixing regulations and KE 0000854 Mr* John Schaefer 5 placards which specifically effect the handling of Fluid at these points* I think this is necessary to avoid any mis-understandings and to make it perfectly clear that the application of the drum mixing regulations and placards to the hulk mixing apparatus is for the present at least a temporary measure. Moreoverf this procedure will result in a clear understanding among the field staff and among the refinery personnel as to just what is expected of them* Very truly yours, UK :IS Robert A. Kehoe, M*D* H 0000855