Document QJmzmmENYEbGm7DMBn8BqKXpk

ADDRESS COM MUNICATIO NS TO FEDERAL TRADE COM M IS S IO N OFFICE OF THE CHIEF COUNSEL AT THE NATIONAL ARCHI v ' f f f c & 9 (} o s r H Mn SJL. M r-V - IN REPLYJN' FEDERAL TRADE COMMISSION WASHINGTON u June 9, 1936 Surgeon General n t'1 Public Health Service, W a s h i n g t o n , D. G. `P TM T P f/T- *' ,'i5- In re: Cushing Refining & Gasoline Co. Docket 2825 Sir: Reference is made to Public He a l t h Bulletin No. 163 pertaining to the use of tetraethyl gasoline in its relation to pub- / lie health and the report of a committee / of seven recognized authorities, appointed by the Surgeon General of the United States Public He a l t h Service, as to the health hazards involved in the retail distribution and general use of tetraethyl lqad gasoline motor fuel, prepared by: ' W. H. Howell A. J. C h e s l e y D a v i d L. Edsall Reid Hunt W. S. Leathers Julius Stieglitz C. E. A. Winslow. This Committee reported, as shown by page 110 of the bulletin cited above, that in their opinion there are at present no good grounds for prohibiting the use of ethyl gasoline,, w h i c h is the p r i n c i p a l issue in the above entitled proceeding. Page 2 June 9, 1936 It is accordingly asked that you be kind enough to let me have the present address of each member of this committee, insofar as the same may be known at this time, together with a statement as to w h e t h e r or not any of them are in the Government service / Very truly yours Chief Counsel fair. T # v-r ;V J [KtPftOOUC^ A T THE :it '. < ' . ,.f m ........./., .. 1 " " > : v ^ V . O v ; 'a ; 0S75~e^20^General; . ; ty-':;::,v' ;\ t- W+ff&''' ;4j' ; ' "- fX :'? ;:- ; ; X X X ,X ;, ; $Vy/X;^;h s.-:- riiA':-. /' ll'V^VO ' It*.V';.;'/'.:> ;'.A.^,'Mr. -W.T;; e]JLey,,;;;j. :.' '''Stvifr/er: ^->^- t - , f. %{:$;.>i;..: 4fi.U . ;,. /. J u n e .lft 1956... ,: ,`;.;-'V'ir-iv '' . / ^ ' ^-i-s-' . .;> V ' .;'> >!. .' ".' Vv X - ., ,> 'i-^ .'V v ,i: ,,'/ .>/- ;..\ &*'<J'{..'V^-'Vk ,!-V>K- ''>*' vi-`;.;:; .(,}.,ay ' >'H e a ip lr i^ a o ^ of June 9, ,rfrring to , Publio HeilfH; BiiUeUn'HoV`i1651oontainlng the .^report o f t h e com- cal't'b'eo ^ r and re^Taati4 gXtW ;ttddre8S 9 f eam 1aembe^^cf. the1'coataittee and a stAtemeat a s t o '^ e t i i ^ ars-inltha'Govsrnnent service, I r a a v ^'>'3 : 1 ^ . ; t^e coaunittee and . thelr prsent addressss>V;?^^''i?3^'-fi ^ | ^ i:'B 'oa'jth'e' lit are at prsent i.consultats of.i tba'P ublic 4 ^ of , tbe coa- a itte e aenbera :namad heTdf4ppointrantsi.Tfith :,the ;Servlce, as" consultants a t the tine o f th eir study o f the ,'tetraathyl. lead '.problem and th eir rep ort-to the Surgeon General. '/ v- r v : `is:->'-''-'''- <.:]': Very;'truly; ycurs, ' . y>> \.<:v';tf1<Vr * '*. -I'!, *^''*.*. } , \ ^ : Acting; Surgeon General .- i;f Esaou ; ... ; ' ' ' ' - ,-:>.K':\ I- -'V`; '' ; . .. ,'*f | . ',!' ' . '.'- ( '. i . ' ' ,. , ' , I ;*,*'''11' 'i'-v'v!-''* 1 ^v'.,vi.,* ^ V-'/'f>.v`iV1'-'iv'y ,l' .- .. 4:^ _ w *`v.:*. i t i f ' ...* ' > . *. ..* :V . 1 1 r. ' / . .. T$yp*:'':'vl':'v :`v : ' v :*. .." * * ` - V- v ..V ' v ' * . i /' ; .' . ; M y .. WM\ S eprooso-- -* '* `H-1''*fa- firsmoisr ARCHIVES -,a ~t Y*)';,, \ September 21, 1936 My dear Mr. Spivakr\V-3 c y o :* v`:t ? . ' 'V'-.V'T`1 -oi;'1 *'.v? ~s:.a ; ... .. ' I am somewhat surprised that you are "bewildered" by what you refer to as "a strange coincidence." After look ing into the methanol matter, I. could- find no,.better-and ,no more-accurate>statements--than those',.which, were... contained tin 'the preliminary report"on methanol to .which you refer.. , -'i- <j..f:fl i i. -1 ,**:, ,;<* , 'In other.words',rl subscribe.fully to the, conclusions ^.-reached by the.-,investigators .who:prepared, rthis. report. As I, ' Vf told you 'when'.you 'were in my,.'office,', if.your own investigations -`lead you to conclude (that the statements mad e 'in .this report are v: erroneous, I';earnestly.;request that you;bring such facts.to my ? attention, -r' .xud t >.-yt ; .. - : .;V. Cv - - ;e - V ' .'j. . ir.-iv',-v - -Sincerely .yours,.*. m,.. (Sgd) Parrasr'P p Surgeon General- Mr. John L. Spivak, 31 East 27th Street, New York, N. Y. TP:MTL \ \ 6 51 East 27th Street, New York,Sept.17,1956 The Surgeon General, U.S.Public Health Service, Washington,D.C. My dear General Parran: Thanks ever som u c h for your letter of September l4th and the lengthy statement you were kind enough to write for me on methanol. I am a little bewildered by your assurances that you "have looked into this matter at some length....and I have written it with a view to making the facte clear to readers of your newspaper,..,'' I am afraid my readers may find it difficult to understand for the state-, ment your wrote for me is,word for word,taken from the preliminary report on methanol prepared by Dr. R.R.Sayres and W.P.Yant and submitted for approval to the Du Pont Amonia Co.,the Carbide & C arbon Chemical Corpora-, tion and the Commercial Solvents Corporation in 1950Thia is the very statement that the Du Pont firm edited so carefhlly,requesting that certain portions be deleted and suggesting that certain phrases be substituted for some of those in the original draft submitted to them.The suggested phrases .1 * /si by the Du Ponts were incorporated verbatim and are included in the statement I vi you sent me. ...I ',,8 I feel confident,after my talk with you in Washington, that you can straighten me and my readers out on this rather "strange co-, incidence" as The New Yorker would call it. !: ..< A& REPROOuce ATTH^TfSr ARCHIVES :% IV. Dr',f>*.K ']"<f s.-.,, UNITED STATES PUBLIC HEALTH SERVICE W a s h in g t o n , d , c . September 14, 1936 Mr* John !.. Spivak, 31 East 27th Street, New York, H. Y, Dear Mr.* Spicks. G-.aerol, IT, S- Public H 'oli.h fxv'/J','1'. ^sh.l'rbi3:;isj;4n';,iurthor reference to our conversation of last week at which time I promised to send to you today a statement con- cerntas-,;a}ethanol^.-.Utj Bllv.. o f S c ie n t if ic deoefirch) I; have. sinc^, .you were here and have assembled available information. It is likely "that my statementbitten, it with a view to making the facts clear to the readersof your"newspaper, most 9^fb9^d<i3c^r^?%hftSi^u9hikg^wle4g^i.c.oinc5;gi^.^bi6 matter as you do* ' ...... . York City. You" made some reference to the fact that the final report of the Bureau of Minos had not yet bcep?published, I, have taken this matter up with the Bureau of lines and find that/'tho^rannuqc'ript will be publish ed by the end of the present- calendaryear J { 'J\) , ,/.<`y"j y / \y' S . j- You called my attention tp,tbp guct^hai -Lire^studies made by Doctor Sayers at the Bureau/bfjviMlpe,3jw,pe?;fInan!3Qdat*?y:,^he manufacturers of methanol. This i3 a regular procedure in the Department of Commerce and I am sure that insofar as relates to the studies carried out by Doctor Sayers and other members of my 3taff, tha source of the funds for the re search did not influence the findings. This was a definite understanding at tha time the study was undertaken. 3in.ee talking with you 1 have refreshed my memory also concern ing the publications of certain investigators who have reached conclusions different from, those of Doctor Sayers. With the knowledge now available, I believe, there would be very little, if any, difference of opinion at the present time between any reputable investigators and members of the Public Health Service who have been intimately concerned with this problem, I appreciated very much the opportunity of discussing this matter with you, If in the course of your inquiries you find convincing evidence of methanol poisoning, under conditions as that material is being used in industry, X hope you will,bring them promptly to my^al&ention, and I can assuro you of a careful and thorough investigation. i'.i t OFFICE OF INDUSTRIAL HYGIENE AND SANITATION UNITED STATES PUBLIC HEALTH SERVICE W ASHING TO N , D , C. September 12, 1936. The Surgeon General, U. S. Public Health Service, Washington, D. C. Sir: (Through Division of Scientific Research) I have the honor to transmit herewith a statement con cerning the toxic effects of methanol which you asked to be prepared for Mr. John L. Spivak, 31 East 27th Street, New York City. r-usal {.Vfh`t-"",! ,------* .taevsnusam V METHANOL "v ?;v-a ;- Ci< -.hr b*.viv: j. .'KZZv 'AJ, .5, v /rplJlethanol. is, neither a'.he.w -nor,.an.uncommon, chemical -compound.; Itv.h6a.--.been'>marketed .nnder.:.ffi&ny-;.diffrentjchQmicai';snd,;tra^.(names, some of-;which-are methyl; alcohol,', wood alcohol^wood spirit,, methyl hydrate,-- wood naphtha^Columbia.-Spirits .and;{,Colonial 8pirita*yv-Mil lions :of. -gallon^ have,been -used; by ..millionSj oi,-people, during'-the past thirty? years,^principally for.solvent..purposes,, Or -the.;manu facture- .of..-formaldehyde,'and.rfpr,;.denat^ingxQthyl,calco,hol.,, -In -1930 methanol became available-.in ilargej quantities ;.and-;at,a markedly lower cps.t than ..heretofore; rThis,<.was.-vno.tdue -,,to the-.;,expansion ,or.develop ment in ..the .wood --.distillation industry, .but tg the development of :a synthetic process .for, making the....product.c^ilhe^ new process -was. originally conceived;and ^.developed, in -France -.and.-.Germany-,. primarily from the/.viewpoint-of- ...increasing -uses of coal,,and.-gas and with the , particular viewpoint-of the developments of,future,liquid motor fuels The. process readily found adoption in the United States for the utilization.of heretofore waste.gases in-the.manufacture of in dustrial.chemicals, resulting in.the'production of ,methanol &t.Uj,, markedly reduced cost. 0?S> or t-.'C- -. ; ^\ ....... \ r-\t TOXICITY OF' METHANOL ................ ' >"111 -u,..! . v . v ' ;, . v o*; it Tho observationsand discussions of,the,poisonous, effect oil-,, methanol which {have beon'.recordod.,-in"-.the,literature are .in-many ` casesviconflictingiend. confusing?) uS.ooe have explained, .the.differences O, * ` * J".!fjKtir. in results on .the basis of individual susceptibility. Vvhile, this explanation,is no .-.doubt valid in part,.it isalso just as possible that many of .the. differences,arise .through-the, difficulty; in ob taining accurate-.quantitative details, particularly-if it involves the possible;use^of,methanol for beverage.,purposes.) In surveying past experience,,hocever, .there are.,certain.consistent observations. * It, has, been-shorn, beyond .doubt ..that^jnethanol>is-,a poison,.and will.produce serious ^poisoning,when,sufficient amounts are:taken into .the,,body.. ...Also,..there is..no, practical difference between the toxicity.of.crude and refined:methanol or between methanol-made: by the wood distillation,,process and that made by the recent synthetic process*. Further, it cannot,be ..made nonpoisonous, by, any known ft ta w n 'lr il v 4*.rw *5twrMvr*^ a a + Via+- m mi-n< PA /a/i /* + A a. thetproduct .is,takenInto the,.stomach is pretty well .known.- Small amounts (-:haye. been taken -without.apparent harm,..but on the average one ,or two ounces .,(the contents of one -to two ordinary whiskey glasses) will cause serious poisoning with the possibility of blind ness.,and;tdeath*,,and twice that amount ;.will frequently.-cause deatii,,... .. ....The. effects ..ofinhaling air; containing v^ious amounts :q f methanol vapor are not so well known. Wide experience over many I '?!efJ# '*** 8X*0TPffW01 ja v-eI* j years has' shown that there are conditions of .exposure- t o .ethanol / vapor'in the-'air; which cause ho .apparont harm and also that there are conditions which rill produce serious poisoning* Records of cases of'severe poisoning-by-inhaling-methanol-.yapor* however, show the large majority'of serious, cases to. have -occurred in the use of | 'methanol, principally<as absolvent,-for paints, and..varnishes in relaJ \ lively small- confined end unventilated places.';.The use of. shellac 'dissolved' in -methanol-for..coating-the interior;of ,beer vats.has been an'"Important'.-source- of trouble of this- kind. The potential "-health'hazards'''from'.air- containtng methanol vapor thus depend,on the- degree- O f !exposure. Lees is known -of :the-.dangers to;.health.from.absorption of -methanol `through'the' skin*.'.'A*.review-.of .the,.literature, gives,no conclusive information-.that, serious poisoning.has been .acquired in this 'manner.' A fewvcases .are described -as possibly, being due "'to* skin absorption.;:In tihese cases the .exposure, was. either so slight .that-it"is'rather hard;tp.believe that the .trouble was due V !t<f''absorption'of.-methanol through the skin, or the situation was I so complicated.by the possibility-of high .concentrations of vapor in -the air breathed* 'When.one .considers the large amounts, of ; j methanol-that'.have .been used, and the frequency with which it has j undoubtedly come in-contact with the skin, in many instances having ) 'been-used, for* treatment of-wounds and for ^rubbing*' purposes, it is T,, ^ i i i s g g i v ^ ig1SiSf e a y , ><.' *- " 0NA1- archives. ,:r.r^TiT? aW SKffi';.r,J'S ot osipcooX .i. ; 1 i i ,i /.-Ia' H'O " ' f jrunonajT^ ' AOT.fi1 0/>tS. ^ '* ^ ** ~~ produced by the rapid evaporation. A number of persona stated that they had used methanol on wounds and as u liniment for rubbing purposes. . None of these men expressed fear of exposure to the vapors or by- skin contact, for the reason that they had never experienced ill health from it, nor did they know of serious effects having occurred to workers in the industry from this manner of exposure. There is, on the other hand, universal knowledge that methanol is poisonous and cannot be taken into the stomach. The results of the physical exam ination of these men revealed no acute or chronic illnesses and no defective vision or eye pathology attributable to methanol. There was also no indication of deleterious action revealed by blood and * i` . *, urine analysis. .In & considerable number of cases of comparatively severe exposure, methanol,wa3 found in both the blood and urine when the specimens were taken after several hours' work. This con firms actual exposure and acquiring methanol, but, on the other hand, substantiates experience that certain amounts of methanol can be ac quired, without apparent harm. Specimens taken the following morning from several of these parsons showed methanol to be practically absent in most cases, and markedly reduced in the others. In all cases the .amounts in the blood and urine were far below those which r had been found in the laboratory part of the study to be harmful to \ dogs. It was concluded that the evidence that raethcnol poisoning has been caused by absorption through the skin is rare and inconclusive. Also that practically continuous exposure to low concentrations and - :?,TT -- fr'y-i i-Si>:-i P^ 7F ^ ARCHIVES : ' ''ifv.V'.iMlj'f :'':'/vJi'7|::V-:;''- ' '7 j^:; i short '^ateraltte^nt'^exposure to 'high'concentrations^of";,otha^nol :; :c ;. C$.^.:n;^ -but, ori' the other hand, ,continued, exposure ." /' y^'-CyPJr'hv^ - ' -'"';":.-.J:'.'-:. -*/:,' S.'.'-"'-'.*'V- -V ;. I ,- to :Kigif.concentrations'-yiir*cftus serious polBflovsg ;.. .! ..;% ' :,All.ethanol* ;whether made hy wood distillation methods' or . f y S ; y it-is .crude,, refined or highly puri~ . Vi'S^ y e t ' p o i s o n o u s .when;takeii^pte^wi^. It. vili',causo' serious ;i ; > . V ' :>:; ;?;;:|^v;poisoi4^ bliminesa^ or^ssibty.^eathV %en"a8;;ilttl87KB:tiio !v;: 'Jv - e. is taken' into, the stomach. ^ The', grette s^d^nger is 'that . ;.|r..someone might drink'met h a n o ^ wood '' j. alcohol'd methyl; alcohol.'. ' On behalf ,of th. state '.'territorial healthoffiGoro, the '.Public Health' Service has b.een instrmentaljin' bi^ii^ing 'about agrtie-- '.menta with the' chemical industry beneficial; to th.e'.heiilth',of those working in the'industry and also to.'those. using its' products. ,'The . ,V*** r . . / | 'A> 7 ) `\ . . ' ' i *v*; Vivivi,: agreements coverr such poisonous, macerialpVas^t^ '''",,0 1 , liquid chlorinated \.y V.Si *' I-: i ,4V * '//`i7.**- lead, 'th- vs-%?/! .-> * : . V . : r \ i ' / V.-VV V .*vv.' ' ? r * *.c V &.*>-* V * - *' ~'\ S ' : :;( \ \ ^ vi iii-:- S:''-Svi;S'S.r`^;S' ;s 'S vrv'/v ;* v 7 ^ C ;,v- >i'.- ;:S i v ... . ; . . '4 'vr-S'- *' .. *.<wr. w'.S aw *iii s fsasw * m J i OUAl ARCHIVES ....... tebo^w > .. "'r '` ..J,, ,, VV/ltfa pVO VfJ'T Vi - 4 i I* ,,, ..;w. ; W - * ' ' r...,,. ' '' 8 ... apparent that no appreciable hazard exists from this manner of exposure to ethanol when it Is used in automobile radiators as antifreeze. . , . ....... A survey of the conditions of exposure prevailing in four plants engaged in the manufacture of methanol and physical exam inations of the limited number of men. who were exposed from a period of .a, few months lo ten to fifteen years has, been completed. This survey consisted in making general observations of duties and exposure of the workmen, quantitative chemical determinations of....'.he amount of,methanol to which the. workmen were exposed and a physical examination, of the workmen. ,The .physical examination, in cluded an occupational history, a health history .and a complete physical., examination..with, special .attention, to vision, pupil re flex and eye pathology as revealed b y .ophthalmoscopic examination. Urine specimens were examined,for. albumen, .sugar, specific gravity, reaction to..litmus and methanol content; and blood specimens ..for methanol, hemoglobin content, number of red and white cells and differential,cell counts. . These persons were engaged in all the.operations of manufacturing methanol;,wherein, there was exposure to air .containing the vapor and exposure by contact with 'he skin. . In nearly all cases both types of .exposure were present.. The manner of ,,exposure to vapor ranged from working over drums .being filled, with methanol, inserting bungs in filled drums the exterior of which was usually wet with drippings, m m . .. .. w . ,\\t working over an open drain pan continuously*wet wita .methanol, taking samples of methanol from drums and otlil-house lock-boxes, making hydrometer.tests and general-exposure resulting from leaks and spillage in;,^he working places. . *-... >. . <' Contact with the skin was a common finding, occurring many times daily.with.some persons# In one.operation a roan net the palm and fingers of one hand two hundred to three hundred timesdaily,' and.in addition to this, was continuously working over arums being filled, with antifreeze methanol. In a similar, operation another, person wore,gloves, the palms, and fingers of which were wet almost constantly. ^Other operations required almost constant'contact of' the. fingers with methanol. ,,;It is a rather -common practice among still-house operations ,at wood distillation plants-to wot their hands j/ith.methanol and smell the-product-as'a..guide1in .still opera tion*. Likewise,., i t ,i s a common practice.atthese .plants to use methanol, for-washing... wood tar from the-hands ..and tools and for cleaning parts,of. machinery* >........... i.-. ?r '- . The above .are usual-and .observed exposures, under unusual con ditions, it. was learned by interview .of workmen, that some frequently got their trouser, legs wet and others,1.on a number .of cases, have . been practically .drenched with methanol'.' They stated- that the uBusunl procedure in these cases is to merely allow the methanol to evaporate., as -they suffer.,no discomfort other than,the .cooling effect