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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 th^Ls 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 raen> 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 require 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? This, of course, is an engineer's problem, and not mine. Consequently, I am not making arbitrary recommen dations, but waiting a bit to see what can best be done. (I do not expect to Visit your plant again and agfiin 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 Dp. 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 (confidentiallyjOhio is little bettep), that such a plant can continue to operate. But Penris'ylvania is catching up, and sooner or later you will Mr. Robert P. Restrepo -3 December 7, 1961 be in deep trouble. You have time to act so as to escape this "catching up", and you should do so. v" 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 absorb3the 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. U S 0018681 i s S ; ;! and policy in the imuSltng of the operativ personnel; and third, to m k e t 1 t s* i i w ** <00 CD oq vHi o o Ul -a air. Lead-bearing eat e-rials and parts are stored in m ay areas of the plant, and the floors are littered with dust. If ore space were available it would be 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. (bjs The plant is overc r o w d e d with equipment and materials in all stages of production fro 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, in 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 from the degree of orderliness which is satisfactory in m ay industries. It is achieved only when lead-bearing dust on floors, moving objects, and surfaces that may 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 milligrams^rather than visible, palpable quantities. This is why the housekeeping is said to be very poor, for almost anywhere in H e 0018683 the operating areas of this plant, lead dust exists la 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 was that in some areas - the smelter being the worst - the atmospheric contamination oust be excessive. In others, at least intermittently, it must often be dangerously 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 frost floors ami 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 does 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 nay or may not be significant. It appears^ at one time during the day^ that there was a considerable quantity of effluent! at other tines it appeared to be nearly negligible# If there is an Intermittent escape of lead compounds in significant quantity from this source, some 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 subjected to greater risk than the neighbors, and they are entitled to the first consideration. K& 0018684 drying of soae parte of ibe generai are wouid bo sufficient to create a Cb) Conditions within ih sssoiter on the day of this visit S8S8I00 3 KF 0018686 s O M Eftr n Q d o ET. & r. 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PK -<Hf** atr>tt riftttr P rt 0 H w V' ft Jc ".; rrftft *f1t *0* & .t- .f1trf ft- N ca I Ci i of dried oxide (once paste) upon them* so that the m i s t state of the newly made 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 U s e s , where it was ground up by the feet of men, and by the low wheeled vehicles on which finished and unfinished products were being moved about. Such boards or frases, used for the handling of plates in tiers, are widely distributed through the plant, often being seen in roosts in Which little or no other m a n s existed for spreading lead compounds upon floors, lib effort appears to be mad 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 material.s, they should bo cleaned thoroughly, ! so as not to perpetuate the distribution of debris. However, so long as 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. HE 0018687 {) la t y p :a*esibly *x m , group* ftf plates bound together . ' ' ' t ' " in unit on being handled an unvaotilated stand or tables, an which ' /: ' , cast aeewmtetod. All such tables o r stand on which dry (or drying} *. i : ' ; Baterlalf: y collect during normal operations should be Gowtt-yeatilated grill*, > Every movement of these materials raises dust unless the latter ' is rmBOVed at its point of. origin. Every such aovement also' results in: -V: `f.->; ` '. - th* dropping oi dry (or drying) notorial on the floor to ho trod upon '''and'carried about. ) . ( Cl) In areas in which plates were being handled (pasting and aeso&fcltag) m m and wo&en w ore seen eating and drinking during a rest period. At this tine, the adjacent wash-rooms were being used to soae extent, but the employees did not always wash up before eating and drinking, and they did not resort to eating roans, but ate and drank essentially'on the Job. It is possible, perhaps, to avoid the ingestion of appreciable quantities of lead under these conditions, but it is hardly likely that t M # will fee done, and it is certain that it was not being done by all of v these people. (g) Th e wash toons, lunch roo (one seen, there stay bo others), * shower rooms and locker roose, While not highly attractive, appeared to bo ample for the purpose to bo served by thess. It is to b doubted, however, that they are being used satisfactorily by a well inforaed and well cupervised plant population. The sight of employees 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 h ow to achieve it. K 001S688 ~8 - 3. Matters of Procdar *ui4 Flicy in Industrial Hygiene. It can hardly to* said that here is a prograis of industrial hygiene in this plant, in the technical or professional neaniug oi the tora. - feeble a t t e s t ia that direction is toeing aaSe on the reccoxsendatlon of sose person or person. - obviously inexperienced - connected with the insurer (or insurers) of the industry. Industrial hygiene, in the load trades, insofar as it is sought and achieved in its non-medical aspects, is comprised of 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 of work-rooms, and the arrangement ox space, go as to separate potentially hazardous from nca-haaardous operations. If then measures the respiratory hazard by adequate sampling and analyses of the air at the breathing zone of the operators of various processes, and on this basis appraises the need for measures -of control, it continues further in bringing the necessary degree of control into the hazardous or potentially hazardous operations. Such control relates to the design of equipment, the ventilation of equipment that requires ventilation (primarily by 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 of the measures of control is checked by further analysis of the air.) It goes still further, in developing methods of housekeeping which prevent the accumulation of materials that con raise oust, and which gather up such materials by means which do not, of theaselves, create dust. - Industrial hygiene as applied to industrial personnel, is directed first to the instruction of such personnel in the potential dangers of their HB 0018689 -- 0 * work,' so that they will uhdcrstasKi why they arc.ircquir&i to da certain . thing and not to do- certain others. . The f l w t lesson relates to c a w is aot raising hast, (Btf sweeping, of siottm, flics# in the face o this-, and defeat every other effort tc achieve tanderstaswliaij of this attor. ) Such attention a is required is devois** tc the proper, use of respirator#, air-line .sassi**, or whatever is best cad necessary, in do&llass with irrrsiaariy recurring condition#, -in Tfeieh," from time to time, the ir -tiers, one -aust work is badly contaminated sad rsuat not he breathed or .must be cle*ed before 5:eius breathed. Proper :*asks sust be selected by the managas*mt (or those who iiiicw bent), and mist be kept in proper condition for pror.pt use. and their v.c.o must be enforced by adequate intelligent but insistent, supervision, a t is not satisfactory to depend, upon the use of respirators regularly or constantly, for thc\ avoidance of exposure to lead dust or use. fao basic.conditio#- under which sen work should be safe. There are, however, eituatioaa which -ay re-cur irosa ii*.e to time, through f&aiiy vtfulfmmt or operation, or in ccnaection with occasiswaal operations or processe#, which require respiratory protection^ These should be subject to fir supervisory inctrr.etion, so a# never to bo ignored.) Next In importance come the training of the personnel in the avoidance of the insertion of lead. This calla for excellent' -facilities- for storing work and street clothing (double lockers), comfortable and cleanly showers which will invito usage, suitable hauti (and face) washing facilities, spotlessly clean find duet-free roex> ia which all eating is dons.-, unci clean and sanitary toilets. Unless those are orderly, clean, and reuou*bly attractive they will not be used freely by aen and wo?aeu, no that training and uisciyiino will fail. kE 0018630 IQ - All employees should foe instructed in attention to the details of cleanliness - bathing m & changing ciothes at the end. of the shift? washing up carefully before .eating'? eating and drinking only in specially provided and desig'hated pieces,. {$ea rer seen to be smoking. Bos of then in ail likelihood, chew iafoacea* ffei# should prabably not be permitted, for it is only fcy the exercise of unusual care that this can be don# without taking load into the ssouth. In any case# if it 1 perseitted* th-en (and m e n ) should 1m? shown Uow to avoid the ingestion of lead. They must coim to an understanding of the fact that the swallowing of lead, in connection with their work, must 1ms prevented, and that this can be done only through their own euro.) !*o food or drink should foe kept anywhere in the plant except la designated storage areas and facilities, Such facilities stunt foe so designed, located and maintained as to be free of dust at ail times. There should foe a satisfactory-regime of medical supervision of ail operating personnel. This is cosjprieeil of suitable medical examinations, suitable clinical laboratory procedures for investigating the ii&aftii of employees,' and satisfactory, analytical facilities for checking the lead content of blood or urine {or footh) at suitable intervals as determined by setiicai and oeonoadc policies of the plant, {such facilities need not foe in the plant, but should be accessible by ^rearrangement and not too remote for prosapt service),and opportunity for inspection of the plant and for instructing the employees in matters of hygiene. The details of the medical regimen cannot be and need not foe - described here. They can foe considered in detail by Dr. Judd, mio will foe preys red to decide what should be done and what can bo hone in the available time, after consideration of the situation with the management. (ft is anticipated that ho tail visit this laboratory and consider KiT 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 permit 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 .t 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 .\s-8-a j K Robert A. Kehoe, 7K Director. H 0018692 muQitfgaiM On the Toxicity of head in Food or Water for Crtt.lo The oral dose of lead required to kill cattle /arica with a number of factors, such as the compound of lead ingested, the state.of health and nutrition of the animals at the tiix# the lead is ingested, the period of time, over which the Horn is ingested, the age of the animals (the young being roore susceptible), and the medium ia which it is taken (whether in food or water and ia what concentration). Che dose of soluble lead, of the order of 50 to 100 grams, administered orally at oae tiee, to an adult, healthy cow, is likely to be lethal. If the food or water taken regularly by cattle contains lead ia relatively high concentrations, illness ** perhaps fatal Illness * results after periods of tioee which vary inversely with the sine of the dose taken per day. low concentrations, on the other hand, appear to be incapable of inducing chronic poisoning. It is said,authoritatively, that such a quantity as 8 i&illigrass of lead <Pb) per kilogram of body weight per cay, can be taken daily by adult cattle over a period of months, without liars. Young calves sicken and die after a few days when they ingest 0.2 to 0,4 gram of lead (Pb) per kilogram of body weight. The lethal dose for adult cattle, under these conditions, is somewhat larger. December 7, 1961 STATEMENT Expenses oi Robert liehoe, M.D* la visiting the plant of Price Battery Corporation, Hamburg, Pa. on November 22, 1961 Airplane fare Hotel (paid by .Price Battery Corporation) Meals Tasi and airport limousine 78,,65 6.35 7.00 ' $32.00 Reimbursement of The Kettering Laboratory for time spent in services of consultation unci advice rendered by Robert A. Kehoe, M.. 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 1961 HE 0018694