Document XJr0BOBN2oDVd8vRZD0N0Qkw

December 7* 1961 Mr. Robert P. Restrepo Director of Manufacturing Price Battery Corporation Hamburg Pennsylvania Dear Mr. Restrepo: I am sending,,herewith* three copies of a memorandum which I have prepared for your information and that of your associates (as you may desire)* following my visit with yourself and others of Price Battery Corporation on November 22. More time has passed than I would have wished since my visit, but other duties had to be attended to* and I've done the best I could in ful filling my promise to advise you* as fully as possible* of my views of your situation. You may come to the conclusion that I am somewhat harsh and unsympathetic in my appraisal of conditions in your plant* and of your needs in matters of industrial hygiene. This would not be a fair appraisal of my attitude. I was pleased by my visit with you and your associates, from the aspect of the openness of mind of your group* and I could wish that I need not be critical. The facts* however, are as they are, and I have attempted to represent them frankly. You do not want my sympathy* I am sure. Rather* you want and need advice* and thj.s I have given. Your plant is* in a number of respects* dangerous* and for this* you and your employees will suffer. Modern social^hygienic and legal attitudes are such that you will be penalized severely - increasingly severely as time goes on - for these shortcomings. They must* therefore* be re cognized and corrected. This will be troublesome and costly* and I cannot deceive you in this matter without being guilty of gross pro fessional dishonesty. It can* however* be done. It would be much easier to build the necessary improvements into a new* well-designed and well-engineered plant* but it can* with somewhat more difficulty and attention to details* be done in the present plant. As the first step* I advise the sampling and analysis of the blood (and advantageously but not imperatively the urine also) of a group* of employees whom you will select as the most representative (from the aspect of the duration of employment in specific jobs or areas) of the various occupations in the plant. The usual procedure in a situation of this sort is that of carrying out an elaborate survey of the lead content of the air in all parts of your plant. I do not advise this*for the reason that it would take a considerable period of time and repetitive sampling (in order to obtain representative Mr. Robert P. Restrepo 2 December 7, 1961 results), and the cost would be considerable (unless the State authorities were to do it for you). Moreover* it would not tell us nearly as much as would the sampling of the men* themselves, who bearjin their own bodies* the record of their experience. The latter information can be obtained quickly and will tell us what we need to know - namely, where there is danger, and how much danger. As I told you on the telephone, I believe now that we should do these analyses for you. The results must be interpreted for your benefit, and I do not want to be handicapped in this by doubt as to their reliability. You will need access to analytical facilities nearer to your plant than Cincinnati, but that can be arranged later. We can help you out in this matter (as we have done elsewhere) by malting sure that you obtain reliable results. We shall send to Dr. Judd the necessary containers, according to your instructions, when you wish this done. We shall provide suitable instructions for obtaining satisfactory samples. The next step in dealing with your problem seems to me to be that of our giving Dr. Judd all the help we can in dealing with your problem. If he will pay us, an early visit, we can go over the problems, step-wise, and advise him what can and should be done. This, in my view* is a crucial matter. I have tried to point out what is wrong with your plant, in some detail. I have not made specific recommendations for curing its faults. A number of things need to be done. Some of these develop automatically out of my criticisms, but how badly are they needed, and where does one start? For example, I believe that you will find it necessary to use wet methods of cleaning floors and of preventing dust, unless you rebuild all the floors in the plant and make them readily subject to vacuum cleaning. This will Yequire drains, ditches and settling basins (or perhaps one central settling basin). Where should you use such methods (certainly in the smelter, but where else?), and where should you resort to vacuum cleaning? Ibis, of course, is an engineer's problem, and not mine. Consequently, I am not making arbitrary recommen dations, but waiting a felt to see what can best be done. (I do not expect to Visit your plant again and agpd?1 in order to guide or follow your progress, and this is why I thought it necessary to write an elaborate memorandum. It is also why I think it necessary to work with Dr. Judd.) By corres ponding with Dr. Judd (and with you also, if you wish), I can aid him and you to some extent, and aid in the achievement of your purpose. You have a difficult Job to do. It will not be easy to surround all of your operations with satisfactory safeguards, but it can be done, and if you are to continue in business, it must be done. I have no wish or intention to be nastily critical, but I know what is going on in this country in matters of industrial health, under the pressure of social changes, union demands, and governmental regulations, together with the progress of professional education. I know that such a plant as yours would not be permitted to operate in some parts of this country. Indeed, it is only because of the benighted state of industrial hygiene in Pennsylvania (confidentially)Ohio is little better), that such a plant can continue to operate. But Penns'ylvania is catching up, and sooner or later you will K& 0018680 Mr. Robert P. Restrepo -3- December 7, 1961 be in deep trouble. Ypu have time to act so as to escape this "catching up", and you should do so. '*--~ What I advise, therefore, is the step-wise procedure whereby you deal with first things first, and gradually get your entire house in order. One of your first requirements is good medical guidance and supervision, and therefore, I am pleased and encouraged in the belief that Dr. Judd can provide this. I will help him all I can, I enclose herewith a statement of my expenses and a bill to cover the cost (to the Laboratory) of the time spent by myself and my secretary thus far, in dealing with your problem. Perhaps I should advise you that I do not expect to make any charge for the time I (and others) spend with Dr. Judd. The Laboratory absorb5the cost of such professional courtesies as a part of our educational function. We shall, however, charge for the analytical services suggested, at the rate of ^12.50 per analysis. I wish to express my appreciation of your courtesy and hospitality at the time of my visit. Cordially yours. Robert A. Kehoe, M. D. RAK:ss Enclosure - 3 copies of memorandum and Statement of expenses P.S. I enclose a brief memorandum on the lethal dose of lead for cattle. This however, is not the criterion which should be applied to the concentration of lead which is permitted in a stream. R. A. K. ME 0018681 / Qa th Conditions Observed f&rtng a Visit to the Float of Price Buttery. Corporation at H&sbarg, Pennsylvania TMa plant was visited on Ksvessber 22, at which tine the operations were observed,, and various otters of interest to the visitor imd of concern to the mnagessent were discussed at gs length, In additional* plant physician, A. Judd, 14.3., was intoa-viewed, and certain miters concerning his activities were inquired into and discussed, briefly, with his. The purpose of this messoraadua is, first, to camsait on certain physical conditions associated with the operation of this plant, in their relation to industrial hygiene, with special referenm to the exposure of the employees to lead; second, to review, briefly, certain utters of procedure and policy in the handling of the operative personnel; and third, to mke certain recoa*endations for th iasprovesaent of industrial hygiene, with respect to th control of the exposure of th employees to lead. 1. General Conditions in the Plant, there are several features of the plant which create gross difficulties in matters of indudtrial hygiene, <) On factor la the limitation, ns well n th unsatisfactory arrangement, of space. It is wise, so far ns possible, to isolate operations which give rise to dust and fuae fro those which are not associated with a significant degree of contamination of the air. This applies also to the movement of materials and partially fabricated articles (those which spread lead-bearing dust around), whereby the wheels of vehicles of any typd^and the shoe and clothing of employees redispersc lead dusts on floors into the HE 0015682 N19715.01 -2- air. Le&d-bearingiaaterials and parts are stored ia may arms of the plant, sad the floors are littered with dost. If ore apace were available it would he possible to rearrange storage and transport areas so as to confine the exposure to dust to those persons who must handle and transport partially finished parts of the batteries. (b> The plant is overcrowded with equipment and materials in all stages of production froa the smelter on through, the space being too little and, therefore, crowded and poorly arranged fro the aspects of convenient handling and conveyance, and the achievement of cleanly house keeping, in consequence persons are being subjected to exposure to lead duets, because of the work and activities of others, when their own work, of Itself, Involves little necessary exposure. (e> An additional problem, which militates against good house keeping, is the condition of the floors generally, ia most of the areas of the plant. These are rough, uneven and irregular as to surface, so that they defy adequate cleaning. In consequence of this factor, augmented by the shortage of space, there is a general state of uncleanliness. The m housekeeping is very poor, and is likely to remain poor, in view of the difficulty, under the prevailing circumstances, of achieving good house keeping. (Cleanliness in the lead trades is something very different fro the degree of orderliness which is satisfactory in any industries. It is achieved only When lead-bearing dust on floors, moving objects, and surfaces that my be disturbed by moving people and objects and air currents, has been reduced to the point at which only very minute quantities are available for dispersion into the air of spaces in which people work. By "minute quantities'* one means a few milUgram,rather than visible, palpable quantities. This is why the housekeeping is said to be very poor, for almost anywhere in He 0018683 3 the operating areas of this plant, lead dust exists in sufficient Quantities to be seen readily, and in some it can be shoveled up. One cannot guess at the concentrations in the air in various parts of the plant, but the Impression developed at the time of the visit mas that in some areas - the smelter being the worst - the atmospheric contamination must be excessive. In others, at least intermittently, it must often b cbu^erously high.) (d) A third problem, somewhat related to those mentioned previously, is the difficulty of providing suitable drainage (floor drains, ditches, etc.,) in and from the operating^areas by which water, used to hose out dust and debris from floors end other accessible surfaces, can be collected into a settling basin and freed (sufficiently) of lead before entering drains which lead directly (or perhaps indirectly) to a local stream (or streams). It docs not appear that there is space enough to enable suitable local drains to be used and controlled (as to their output of lead). (> the problem of stack effluents may or may not be significant. It appeared^at one time during the day^ that there was a considerable quantity of effluent! at other times it appeared to be nearly negligible. If there is an intermittent escape of lead compounds in significant quantity from this source, os further effort will need to be directed toward this end. Our primary concern, however, is for the safety of the workmen in the plant, and although the cultivation of good relations in the neighborhood is important, the workmen are sheeted to greater risk than the neighbors, and they are entitled to the first consideration. K& 0018684 4 2, Eg-ccific Areas and Conations. (a) The yard around the smelter in which broken batteries are stored ami handled, and transported, along with other le4-containing materials ^to the furnaces, is potentially dangerous* It appeared, at the tine of this visit, that there was sufficient moisture in the materials and all over this area to prevent the dispersion of dual into the air* There is no assurance, however, that this is always the case, sad if it is not, this situation is dangerous. In a similar situation, involving dry material, we found that every ma who had worked for as long as three weeks, had absorbed dangerous Quantities of load* Lewd-containing materials in this A area of the ^Pric^premises were distributed over the entire area of these activities in very generous quantities. Only a limited amount of superficial drying of some parts of the general area would be sufficient to create a gross has&rd. b) Conditions within the smelter on the day of this visit were almost as bad as any that can bo Imagined in lead trades in which dust and fuBfe are to be dealt with* The' tmn in the sir van distributed largely (but not exclusively) within the upper part of the sumIter building, where no one ms working (one an went into this area to open up a partially plugged duct and remained there only 'for a short' time). ' It can safely bo assumed, however, that the point at Which the visitor stood to view the operations , was surrounded by air too heavily contaminated with dust and fuse to bo safe for regular occupancy. ' There was no part of the smelter* on this day, in which it.was safe for men to work regularly, Some of the men wore dust respirators* One had his respirator around his neck. Others had no respirators H 0018685 -5- with the at tala ttsw#. d&ptie .the existence. o* unusually bad. conditions, It-la evident that the' uac oS respirators is a attar <ii jaugment or choice on the p*xt of th* woricsesu . it -is Just as evident that, under the conditioas that existsa in the steelier on this day, every a&n should have been using Jilt* `respirator continuously. "the sea,.- clearly, had no fear oi the situation is which they- wsr serving* Tills means, simply and certainly, that: they had no real understanding at the significance of th exposure 'to lead to which they war being subjected,. This observer will be surprised if there is a single dan in this group who has not \ absorbed potential.!? dangerous quantities cf lead, 2i there is such a man in the group, then- the conditions observed (on llcvcaber 22ad\-srero unnsunl, or else such a tom has bach writing in the smelter irregularly or for only a short tiisc. To cap th cilaax, as to conditions in the shelter, dry sweeping. was being done in an effort to gather up -the shovels full of finely divided dry, lead oxide, Seference will bs ;sad to this procedure later. (c) The urea in which yaatifcg is dene appears to be reasonably / free of hazard. Sven here, however, stu-iut paste falls to the floor, and soise of it regains. there long enough to dry md them to be available for dispersion into the air. An 020a of this type should bo spot less and entirely free of dry deposits. <d) At the other end of the pasting smohlnoa, j m! in the same raia, the plates, new filled with oxide, and partially dried (still laoist enough to prevent dusting), are being handled and piled up on wooden boards or frames. These beards, vth.ilc* being transported to and brews the point at which they were being loaded, and while being handled, had considerable quantities KF 0018686 of dried oxide (once paste) upon them, so that the moist state of the newly mde plates did not serve to prevent the contamination of the air at work sites with dust. Moreover* the debris on the boards fell to the floor, at times, where it was ground up by the feet of men, and by the lowwheeled vehicles on which finished and unfinished products were being moved about. Such boards or frames* used for the handling of plates in tiers, are widely distributed through the plant, often being seen in rooms in which little or no other means existed for spreading lead compounds upon floors. 130 effort appears to be made systematically to keep them clean, and thus they are a source of widespread contamination. Emphasis is put on this, possibly beyond its significance as a lone factor, for the reason that the movement of people, equipment and materials through this plant is an important series of sources of contamination of the air. the floors over which vehicles move, the vehicles themselves, and everything they carry, should always be free of dust-producing materials. These items can be vacuum-cleaned frequently and kept clean. After they have moved unclean materials, they should bo cleaned thoroughly, so as not to perpetuate the ! distribution of debris, however, so long ae dusty objects and dust-producing materials are being moved about, the floors over which the movement takes place will be contaminated. Such floors (in areas of traffic) should be kept smooth, free of pits, ridges, gratings and the like, and should be thoroughly vacuum*swept with sufficient frequency to maintain their cleanliness. The only alternative - which is an unsatisfactory one, for several reasons - is that of keeping the floors wet, so as to prevent the raising of dust. Vacuum cleaning is preferable, but is, we believe, impossible, unless floors are smooth, regular and as free as possible of objects that get in the way of vacuum sweeping, having corners and crevices in which dust gathers. kF 0018687 (e) In tfee aasenbiy are*, groups of plates bound together . ', t ' ' in units, were being handled an uaventilated stands cr-tables, &a which : ' Ctust accumulated. All such' table# or stands on which dry (or drying) -. < : ; satarial#: L'w*y collect during aoraal operations should be down-ventilated grilles. Every sovment of these materials raises dust unless the latter ' is renewed at Its point of. origin. ' Every such noveaent also' results in: thc dre^pplng oi dry (or drying) material on the floor to he trod upon . end carted about. ) ( (1) In areas in which plates were being handled (pasting and assembling) mm and wu&en were seen eating and drinking during a rest period. At this tim, the adjacent wash-rocas were being used to soae extent, but the employees did not always wash up before eating and drinking, and they did not resort to catling rcoass, but ate and drank esseatially on the Job., It is possible, perhaps, to avoid the ingestion of appreciable quantities of load under these conditions, but it is hardly likely that this will fee done, and it is certain that it was not being done by all of v these people. Is) The wash toons, lunch roc (one seen, there say be others), . shower roans and locker roone, while not highly attractive, appeared to bo staple for the purpose to bo served by thera. It is to b doubted, however, that they &re being used satisfactorily by & well informed and well supervised plant population. The sight of euployeca eating and drinking, without a disciplined washing up, beforehand, was fairly convincing evidence that they have little idea of the ways of cleanliness in connection with their work that is, of the precise nature of the cleanliness required and how to achieve it. K 0018688 ~8- 3. Miittcra of Procedure unci Policy in Industrial Hygiene.. It. cun hardly fee said that there is a prograia of industrial hygiene in this plant, in the technical or professional aeuniug oi the term. - leefcie attest ia that direction is feeing aade on the rectxjpeadatioa oi some person or person - obviously inexperienced. - connected 'with the insurer (or insurers? oi the industry. Industrial hygiene, in the lead trades, insofar as it is sought and achieved in its noa-medieai aspects, is comprised oi a series of technical procedures, whereby exposure to lead is measured and brought under adequate control. It consists, first, of the design of operations so as to limit the contamination of the air oi work-rooms, and the arrangement of space, so as to separate potentially hazardous from noa-hasardous operations. It then measures the respiratory b&xurd fey adequate sampling and analyses of the air at the breathing stone of the operators ot various processes, and on this basis appraises the need for measures -of control. It continues further in bringing the necessary degree oi control into the hazardous or potentially "hazardous operations. Such control relates to the design of equipment, the > ventilation of equipment that requires ventilation (primarily fey exhaust ventilation of specific areas or operations which give rise to dust or fume), and the collection of exhausted material where it will not return to the air. (The adequacy oi the measures of control is checked' fey further analysis of the air.) It goes still further, is developing. methods of housekeeping which prevent the accumulation of saterials that can raise aunt, and which gather up ouch materials by means which do not, of themselves, create dust. Industrial hygiene as applied to industrial personnel, is directed first to the instruction of such personnel in the potential dangers of their H 0018689 0 ** work,' so that they will understand why they are required to do certain thing and, not to do certain others, lit Mwt lesson relates to car is not raising hast, (ftrjr awsopiag, of naturae, flies in the face i this,, and defeats every other effort to achieve tmdcrstaadinjj of this aattor.) Such attention as is required in devoted to the prefer use of respirators, air-line jsasfe*, or whatever is best sad necessary, in dualiass with irr$ttlariy recurring conditions in r&ichy Xros tine to ttee, the air - where. one -east work ts badly contaminated and rauet not he breetfced or jaus* be cleaied before 5:eius breathed. Proper nasks aust be selected by the isanagepsmt (or those who isnew bent), nad rust be kept la proper condition for paror.pt use, and their v,r-.e enst he enforces! by adequate intelligent bat insistent, supervision. <!t is not satisfactory to depend, upon the as of respirators regularly or constantly, for the avoidance of exposure to lead dust or fuse. The baric.conditions, under which sen work should be safe, There are, hewever, sjituutiona which -ay recur Irosi tf,*, to tits, through f&uity equipment or operations, or in ccaaecticn with e'ccasio&al operations or processes, which require respiratory protection. These should he subject to fir supervisory inetrr.etien, so us never to be ignored.) Next in importance cooes the training of the nersoim&l la the avoidance of the insertion of load. This calls for tstcelient-facilities- for storing work and street clothing (double lockers), comfortable and cleanly showers which will invito usage, suitable baud (and face) washing facilities, spotlessly clean find duet-froe roowa ia which all eating is dene, and clean and sanitary toilets. Unless those are orderly, clean, and reasonably attractive they will not be used freely by eon and waeu, so that training and discipline will fail. KE 0018630 IQ - All employees should be instructed in attention to the details of cleanliness - bathing and. changing clothes at the end. of the shiftf washing up carefully before eating; eating and drinking only in specially provided and designated places... {j$ea were seen to be smoking., See of timn in all likelihood, chew tobacco, t&ie should probably not be permitted, for it is only by the exercise of unusual care that this can be don without taking lead into the ssouth. In any ew| if it is permitted* the -men. (and women) should 'be shown how to avoid tfee ingestion of lead. They must cose to an understanding of the fact that the swallowing of lead, in connection with their worst* oust be prevented* and that this can bo done only through their own euro.) No food or drink should be kept anywhere in the plant except in designated storage areas ana facilities, auch facilities must be so designed, located and maintained as to be free of dust at ail tines. There should fee a satisfactory resfisen of aedieal su;>ervision of ail operating personnel. This is comprised of suitable zaedical examinations, suitable clinical laboratory procedures lor investigating the iiaait-b of employees,' and satisfactory, analytical facilities for cheeking the lead content of blood or urine Cor both) at suitable intervals as determined by setiical ana economic policies of the plant, {such facilities need not be in the plant, bat should fee accessible fey ^rearrangement and not too remote for prompt service),and opportunity for inspection of the plant and for instructing the employees in matters of hygiene. The details of the medical regimen cannot fee* and need not fee - described here, they can be considered in detail by Dr. Judd, who will fee prejred to decide what snould fee done and what can bo done la the available time, after consideration of the situation with the management. (It is anticipated that ho vail visit this Laboratory and consider Kf 0018691 11 our advice). Suffice it to say, as a general principle, that the hygienic regimen of the plant, in all matters that relate to the care and guidance (in matters of health) of the operating employees, should be in his hands, and his recommendations should be followed as closely as may be possible. No one else should have any hand in the instruction and supervision of the employees in hygienic matters, except on his advice. All medical and hygienic findings and the records thereof, should be in his confidential keeping, and should be inaccesible, except for his wish and consent, to all other persons. Such time as may reasonably be required of Dr. Judd, to perst him to take over and bear the full responsibility for the conduct of the regimen agreed upon between him and the management, should be scheduled. The establishment of a satisfactory medical and hygienic regi u will necessitate provisions for a suitable medical facility in the plant. The present quarters are wholly inadequate for this purpose. From The Kettering Laboratory in the Department of Preventive Medicine and Industrial Health, College of Medicine, University of Cincinnati, Cincinnati, Ohio. Date: December 7, 1961 \ j-iejK Robert A. Kehoe, Director. KZ 0018692 On the Toxicity of Lead in Food os* Water for The oral close of lead required to kill cattle varies with a nas:ber of factors# such as the compound of lead ingested, the state, of health and nutrition of the animals at the tim the lead is ingested, the period of time over which the m& is ingested, the age of the animals (the young being roore susceptible), and the medium ia which it is token (whether in food or water and in what concentration). CSfQ dose of soluble lead, of the order of 50 to 100 grams, administered orally at one time, to an adult, healthy cow, is likely to be lethal. If the food or water taken regularly by cattle contains lead in relatively high concentrations, illness ** perhaps fatal Illness * results after periods of tied which vary inversely with the sise of the dose taken per day. how concentrations, on the other hand, appear to be incapable of inducing chronic poisoning. It is said,authoritatively, that such a quantity as 8 i&iXXigrass of lead (Pb) per kilogram of body weight per day, can be taken daily by adult cattle over a period of months, without harm. Young calves sicken arid die after a few days when they ingest 0.2 to 0.4 gram of lead (Pb) per kilogram of body weight. Hi lethal dose for adult cattle, under those conditions, is somewhat larger. December 7, 1961 KE 0018693 N19715.02 STATEMENT Expenses oi Robert Xehoe, M.D* la visiting the plant of Price Battery corporation, Hamburg, ?a on November 22, 1981 Mrplane fare. Hotel (paid by .Price Battery Corporation) Meals Taxi and airport limousine $78.65 6.35 7.00 32.00 Reimbursement of Tile Kettering Laboratory for time spent in services of consultation unci advice rendered by Robert A. Kehoe, M.J8. Cincluding secretarial services) to Price Battery Corporation in connection with the hygienic appraisal of their plant. 2 days at $120............................................................... 240.00 $332.00 December 7, 1061 HE 0018694 N19715.03