Document byo72p8MwyLkVbXwwbamv949Z

April 5, 1060 Mr. to. ft. Perdue, Jr. Mr. J. ft. MacGregor Mr. J. a. Sabina Gentlesenj I forward herewith to each of you a reproduced copy of a letter received free Dr. Price of the U.S. Public Health Service lit response to certain questions and suggestions of nine stated in order to clarify certain details of procedure in connection with the marketing of gasoline containing tetramethyl lead. My tentative suggestions were put in the fora of questions as to what sight be regarded us desirable, and I think I should consent on the paragraphs numbered 1, 2, and 3, in the reply, for these are to be regarded, 2 believe, as the evidence that any reasonable suggestions made at this tine would be regarded as being up to the industries to follow so long as they were not a source of embarrassment or concern to the Service. 1. With respect to the maximum limit of the concentration of TKL, it might, perhaps, have been desirable to ask that this limit be regarded as the equivalent of 4 rather than 3 ml. of TEL, so as to have this behind us if it becomes desirable to go to this level of M L . I do not believe this would be wise at this tine, and I do not think this should even be considered by the industry until experience in the use of TML shall have proved that the substitution of TML for TEL up to 2.06 ml. per American gallon of gasoline is wholly lacking in risk. I believe firmly in a stepwise procedure, and Z am pleased by the corres ponding attitude of the Public Health Service. This is sufficient reason for holding the line at the level of 2.06 ml. of TML. I do not anticipate that there will be any difficulty, but the industries concerned here, because of their stature in American commercial life, should make their moves on evidence and not on faith and hope. 2. The willingness on the part of the Service to accept "lead alkyl" on the signs arises from ray suggestion, which 1 believed to bo true at the time, that this was what technical representatives of the industries desired. 2 saw no objection to it and so indicated in ay letter, pointing out, however, that since the present signs correspond to written and published specifications of the O.8.P.B.S., it was felt that they should not be changed In any respect, without, in effect, consulting the Service, or at least Informing the. The acquiescence to our suggestion indicates to me that the words recently agreed upon by the industries "antiknock compounds" will meet with no objection. I believe the latter to be superior to the former, since it will be ore widely understood by the public (if the public pays any attention to either). At least, on of the persons involved Mr. Win. R. Perdue, Jr Mr. J. R. MacGregor Mr. J. R. Sabina_____ 2 April S. I960 in this natter in the Service agrees informally that this is true, and 2 anticipate no difficulty here. Before writing further to fir. Price, however, and either asking for advice or merely stating the case for his Information, Z wish to be advised in writing as to the final form of the sign that is desired by the industries. There is a question as to the precise position and manner of the use of ''antiknock compounds," in relation to the other wording of the sign. 2 would like to have this straight before Z take any further action, if, as I believe, some further action is to be taken. 3. Paragraph 3 is entirely satisfactory, I believe, and is entirely logical in view of paragraph 1. Zt needs no further comment fra^ss sse. Z shall await further instructions before making any other move. Sincerely yours, RAK:ss Enclosure Robert A. Kehoe, K. L*. tfgr 0003068 * VC' vv'oV^ * ,>'.4^1 \ * o *+ vAVv& > % -4 O' ield Investigation of Potential Hazard of Commercial Distribution of Gasoline Containing Tetramethyl Lead Following the preparation of a memorandum on the general method jf approach to this field investigation (Memorandum of April 1, 1960 by R.A.K.), two meetings of representatives of The Kettering Laboratory were held in San Francisco with representatives of the industries concerned,for the purpose of discussing and developing the details of the investigation (R.A.K. on April 8th, after his examination of the proposed sites at the Richmond Refinery and in San Francisco, and J.C. on April 13,, 1960). The two meetings had to do with (a) the personnel to be investigated by means of physical examinations and analyses for lead in urine and bloody and (b) the sites and methods of the environmental investigation (air analyses) and the designation of technical personnel for the various tasks. These meetings have resolved the essential questions of procedure, have determined the general scope of the investigation, subject, to the further examination of sites and the selection of suitable personnel at Bakersfield and El Segundo Refineries and in Los Angeles (this is being done along the lines developed in the Richmond and San Francisco area and agreed upon in principle at the meetings referred to above) by representatives of Standard Oil Company of California. It is now possible to define the approximate scope of the entire investigation, to visualize the participation of the various groups and persons in the investigation, and to provide a fairly realistic estimate of the expense involved therein. No attempt is made, however, to estimate the precise value of the services that are to be rendered by personnel of the participating companies. It is believed that each company can make a more realistic estimate 2 e of the services contributed by its representatives than could be e only the actual cost of the parts of the investigative program which to be performed in The Kettering Laboratory, and which, after the planning tage, are made up of analytical services, checking on the course and adequacy of the program, arrangement and examination of data, and the preparation of interim reports (if required) and a final report. Scope of Investigation A considered effort was made in a survey of the sites of potential hazard in the San Francisco Bay area, to discover those which might have the greatest expectation of hazard, and to select the men, employed at these sites, who would be subject to the greatest likelihood of exposure to such hazards. By this means one could hope to avoid the dilution of any significant affects of such exposure in a larger volume of insignificant findings. As it turned out, only a few of the potentially available sites or personnel could be regarded as suitable for investigation, as judged by the criteria which we adopted. The sites of investigation and the numbers of persons regarded as worthy of observation are listed below: Sites, Specific Operations and Personnel Sites Types of work performed Numbers of workmen whose exposure may be significant Richmond Refinery: (1) Lead Blending Plant Regular conduct of blending operations 5 (2) Tank Truck Loading Rack Loading petroleum products including Supreme gasoline and supervising loading done by approximately 60 drivers of trucks 12 Loaders only, Drivers have too little exposure 3 Types of work performed Numbers of Workmen whose exposure may be significant Richmond Refinery: (3) Barge Loading and Sampling at Long Wharf Inspectors who take and test samples of gasoline, including Supreme 4 Loaders' exposure negligible (4) Barrel Filling Site Workmen who fill drums with gasoline, including Supreme 5 (2 regular, 3 relief) (5) Chemical Laboratory Men who carry out routine distillations on gasoline including Supreme 4 (or 5) Representatives of a group of 12 men Standard Oil Company Service Stations: 10 scattered in San Francisco Regular attendants including Manager and Asst. Manager 40 final number of suitable men The Union Square Garage The few men engaged to the greatest extent in fueling cars 3 minimum 10 maximum on all shifts Other groups of men employed at certain other sites were considered for inclusion, such as men employed in the knock-testing laboratory at Richmond, those engaged in loading tank cars with petroleum products, the drivers of tank trucks (as differentiated from Standard's regular loaders of tank trucks), the loaders of barges (as differentiated from the inspectors). The decision in each instance was made on the consideration of the severity and the duration per day of the potential exposure to TML or to Supreme gasoline containing TML. Since other types of exposure to lead compounds or to gasoline, in the absence of potential exposure to TML, must be regarded as irrelevant for the purposes.of this investigation, the decision could be arrived at readily in most instances. It should be recognized that the exposure of service station personnel to TML will, almost certainly, be negligible, while that of persons working within any parking garage will be obscured,to some extent, by the greater exposure to -4 - ulate, inorganic lead. The inclusion of these two groups of workmen the investigation, together with observations on their environmental onditions is desirable, however, in order to assess the impact of the use of TML upon the general atmospheric situation (with respect to lead absorption) which existed prior to its use. This is an essential point in the investigation, from the aspect of the public health. Despite the fact that the findings of the investigation, especially in relation to service stations, can be expected, with reasonable certainty, to be negative, it is imperative, nevertheless, that there be findings, whether negative or positive, in demonstration of the facts. A more important and immediate issue in the practical affairs of the industries concerned here, is that of the extent of the hazard, if any, to any of the handlers of gasoline containing TML within the refineries. We have searched carefully for the more hazardous occupations in a refinery (Richmond), on the presumption, strengthened by information from those responsible for the operation of the refineries, that the operations of this refinery are characteristic (or, at their best, are not less potentially hazardous in the respect involved here) of those in the other refineries of this Company. We have also considered, as carefully as possible, the manner of choosing other sites (service station and garage) and other personnel. We are satisfied to have the further selection of sites and personnel in the other refineries (especially Bakersfield and El Segundo) and in the Los Angeles area (service stations and a garage, presumably the Pershing Square garage) made by representatives of the Company, on the same type of information and criteria applied in the San Francisco area. It seems likely that additional persons, substantially equivalent in total number (but not necessarily of all types) to those listed above, will be selected in the Bakersfield and El Segundo refineries and in the Los Angeles area. This will bring the total number of persons to be investigated up to approximately -5- rsons. (In order to have 40 suitable service station attendants in :h of the two major areas at the end of the period of investigation, it may be 'necessary to have half again that number at the start. This would bring the total number of persons involved in the initial survey up to about one hundred. This number, in view of the general importance of this survey, would not be excessive.) It is essential that this investigation shall not lapse into insignificance because of an unduly limited consideration of the potential hazard, or because of the smallness of the numbers of persons who remain to be examined on the second round. Certain limitations are now apparent, in that, under the conditions established by the operations of this one Company, the potential hazards of this commercial development will not reach the peak that could result from the use of TML in all of the gasolines or even all of the premium gasolines in these urban areas. These limitations must not be permitted to assume any greater importance through our failure to recognize and to appraise any of the significant features of the present commercial operations. The experience of the California Company, throughout its area of operations, will have to be scrutinized carefully, therefore, from time to time during this survey. Medical Examinations In view of the fact that all but a very few of the persons to be examined are employees of Standard Oil Company of California, it is recognized that the medical policy involved in this investigation is the primary responsibility of Dr. L. E. Curtis. Dr. Curtis has expressed the view that the medical examinations should be and can be carried out by physicians whom he will select and direct. There is no reason, whatever, to question the propriety or correctness of this view, and the willingness of Dr. Curtis to assume this responsibility solves one of the problems of the 6 of the survey in a manner whieh is most acceptable to The laboration with this Laboratory, in that the arrangement and study of the clinical data, for the purpose of a formal report, can be greatly facilitated by the use of a record form which has been employed in prior investigations of this type on which a great deal of preparatory statistical work (coding etc.) has been done. The problem here is very different, in the formal sense, from that of carrying out examinations to determine the physical fitness of men for initial or continuing employment. .In this connection the minutes of the San Francisco meeting of April 8 refer to the possibility that the second round of medical examinations may not be found to be necessary in some instances in the judgment of Dr. Curtis. Dr. Curtis has given no indication that this is his view, and it is believed that this crept into the minutes in error. In any case, it should be recognized by all concerned that the second round of examinations for the record is an absolute essential. There would be no point whatever in the initial examinations if there is no subsequent examination of comparable thoroughness. This aspect of the investigation of the taxicab garage was passed over lightly because of the brevity of the observations (and for other valid reasons which need not be given here), but in the present investigation of personnel, the physicians are the primary investigators, who, therefore,must exercise every possible care to observe and record, in the second round of examinations, any deviations from the base line observations made in the first round. Both the observations and the record of the observations on both occasions must be expert and precise, for regardless of the interpretation which the physician makes in his complete examination of any man (such interpretations must be made, since they have their own primary importance) or groups of men, the ultimate clinical findings of the -7 their significance, with respect to the groups of persons =d, must be determined on the basis of deviations which can be made arent for consideration and interpretation only by statistical means. It is not to be supposed that frank cases of organic lead intoxication will be found anywhere in the course of this survey. The effects sustained by the workmen, if any, will not be readily discernible. On this account, the minute examination of carefully collected data becomes a necessity. The manner of recording the medical observations is being worked out to the mutual satisfaction of Dr. Curtis and ourselves in time for the initial examinations. Similar examinations will be made after the lapse of nine or more months by the same physicians. At the time of these two series of examinations samples of blood will be obtained and sent to The Kettering Laboratory for analysis. At these times also spot samples of urine will be obtained, but corresponding samples of urine will also be obtained on two other intervening occasions, so as to provide four samples of the urine of each suitable employee included in the survey. These samples will be shipped to The Kettering Laboratory, In view of the current significance of these data the results will be reported to Dr. Curtis as promptly as possible. Meanwhile, it is understood that Dr, Curtis may call upon Dr. Gerlack's laboratory for the analysis of other spot samples of urine as an immediate check on the hygienic status of such persons as he may be concerned about. This is mentioned here only because all such results will be of practical interest and importance, despite the fact that the "screening" analytical procedure by which these data are to be obtained will render them unsuitable for inclusion among those to be-subjected to statistical analysis and comparisons. They should be made available to The Kettering Laboratory for our information and for such consideration as may be pertinent. Any instance of suspected or alleged intoxication, whether based on % 8 indicated for the record or for medico-legal purposes may be pursued with igor and'thoroughness, in full accord, of course, with the wishqs and advice It is recognized that the contribution made to the investigative program by Dr. Curtis and his associates in the Medical Department of the California Company is a large and important part of this undertaking. In it will be included such observations of the clinical laboratory (hematologic,etc.) as will add significantly to the appraisal of the status of the workmen individually and collectively. Environmental Survey The schedule of environmental observations (air analyses) required to provide the background on which the investigation of the responses of the personnel is to be based, has been worked out for the San Francisco Bay area (subject to certain choices) in accordance with a memorandum (attached) provided by Mr. Cholak as the result of the meeting in San Francisco on April 13th. In so far as this schedule can be extended to the other areas yet to be surveyed in detail by the appropriate personnel of Standard Oil Company of California, it would seem to provide a satisfactory basis for assignment of the work (which is to be shared approximately equally by technical representatives of E.I. duPont de Nemours Company and Ethyl Corporation, according to the tentative plan). Mr. Cholak has covered the subject with apparent adequacy in his memorandum, including the approximate cost of the work to be done in The Kettering Laboratory. No further discussion or comment seems to be required except in two respects. It appears that there is some doubt in some minds as to the desirability of making the observations tentatively outlined with -9 - to the Union Square Garage in San Francisco. There is also some ent objection to the idea of carrying out even the minimum of observations cerning the general pollution of the atmosphere in San Francisco, lest there e some public reaction of concern about "smog" there, or perhaps about the contribution of lead thereto. First, with respect to the observations that may be made in the Union Square Garage, it is agreed that these could be dispensed with, in all probability, without bringing serious criticism upon ourselves. No valid reasons have been given for not making these observations, however, and there can be little doubt that, in the long run, some factual data on the air pollution within this garage and in the atmosphere elsewhere will serve a very useful purpose. The industries concerned here will have no first-hand information otherwise on this situation as it relates to San Francisco. This would be unfortunate, and it could become so unsatisfactory as to require a "crash program" to establish facts which can be obtained as a matter of course and at little expense in this survey. Second, with respect to exciting public apprehension in connection with the making of certain observations concerning the extent of lead in the air of San Francisco, observations are now being made there by others, and the issue, therefore, cannot be avoided. Moreover, public apprehension is always at its greatest in relation to unknown or speculative hazards. The facts always dissipate concern about the unknown, and bring people beyond the point of fruitless anxiety into that of considering appropriate action if any is required. 0003077 io - Estimate of Cost of Work of The Kettering Laboratory: 000 _ y > / { oo IN. o 1. The analysis of biological materials. (1) Analysis of urine Maximum number of samples of urine (4 per person for the 100 persons (approximately) to be included in the investigation) 400 at $12.50* per sample .......................... $5,000.00 (2) Analysis of blood Maximum number of samples of blood (2 per person) for 100 persons to be investigated 200 at $12.50* per sample .......................... 2,500.00 2. The analysis of samples collected from the air. (1) Samples collected according to complete program of proposed environmental survey at unit cost* per analysis as indicated (Mr. Cholak's memo) 11,960.00 (2) Samples collected according to certain limitations of the program (Mr. Cholak's memo) (a) Reduced number of analyses through elimination of samples from Union Sq.Garage ........ 9,960.00 (b) Reduced number of analyses through elimination of samples from general urban atmosphere ................... . ... 7,960.00 (c) Reduced number of analyses through both eliminations indicated in (a) and (b) .............. 5,960.00 3 . Other Roughly Estimated Expenditures of The Kettering Laboratory: (1) For traveling expense of personnel** ........ (2) For the expense of shipping equipment ........ (3) Study of data (including services of statistician) and preparation of report .................... 1,500.00 500.00 1,500.00 4. Total Cost of Work of The Kettering Laboratory: (1) Maximum cost (not including any unforeseen contingencies) .................... 22,960.00 (2) Minimum cost ... .............. 16,960.00 * The unit charge indicated in each instance gives a reasonably adequate repre sentation of the overhead cost associated with the composite type of work in volved, with the exception of shipping costs. It does not include the cost of 11 It Is anticipated that the cost of the work done by The ,,tering Laboratory will be divided among the sponsors according to greement by their principals, that a full accounting will be made to each sponsor, and that the share of each, according to the agreement, will be billed to each sponsor at quarterly intervals in advance, adjustment to be made in the final payment as indicated by the.expenditures. Dat e: April 19, 1960 Robert A. Kehoe, M. Director The Kettering Laboratory KE" 0003079 Attachment Memorandum on a Proposed Environmental Study The following program is proposed for the San Francisco and Los Angeles areas. The environmental program has been designed to supplement the medical investigation as part of the investigation outlined in a meeting of Dr. Kehoe with representatives of the lead suppliers and Standard Oil Company of California in San Francisco on April 8, 1960. The following program was discussed during a meeting with representatives of the same group on April 13, 1960, in San Francisco. The sampling schedules on which the costs have been estimated have been set up at the maximum levels, on the assumption that all of the indicated observations will be carried out over the period of one year. Three alternative proposals are made. Facilities: It is suggested that each of the lead suppliers should undertake to carry out the sampling program in a single area. Accordingly each company will need to assign one man, full time, to the project. Another man should be available on one or two days of each week, to relieve the regular man and to permit the scheduling of night sampling if necessary. The Lead-In-Air Analyzers and the reagents will be furnished by the lead suppliers. The Kettering Laboratory will supply the filter heads, the filter media, and all other equipment which will be needed for parts 4, 5 and 6 of the investigation. Sampling and analyzing procedures will be standardized and agreed upon at the start of the work. A representative of The Kettering laboratory will visit each area at the beginning of the program in order to -2- inspect the sampling sites and to work out any special details which may be necessary. The sites to be investigated, the frequency of sampling, and the costs to be incurred by The Kettering Laboratory in the conduct of this work are outlined below: 1. Antiknock Blending Plants Sites: Richmond and El Segundo refineries Type of Samples: Organic lead only. Frequency: One day each week, at three locations (a) Dome of tank car, (b) at weigh tank, and (c) ground level (outside) below vent line. Number of qbservations ................................. 300 2. Truck Loading Racks Site; Richmond and Bakersfield Types of Samples: Organic lead only. Frequency: Richmond: dne day each week, at breathing zone of loader during 2 to 3 different loadings. One sample at level of ground. Bakersfield: One day every two weeks, same as above. Number of observations.................................. 300 3. Miscellaneous Site: Richmond refinery ' Types of Samples: Organic lead only Frequency: (a) Barrel Filling Area One day each week ................. 3 samples Number of observations .......... 150 (b)Sampling points at Long Wharf - Inspection Laboratory One day each week ................ 1 sample Number of observations.... ........ 50 3- (c) Chemical Laboratory One day each week .... 1 sample Number of observations 50 4. Service Stations; Sites: 10 stations in San Francisco 10 stations in Los Angeles 1 station in Bakersfield Types of Samples: Lead in air + filter (millipore) for organic and inorganic lead Frequency: Each station to be visited once each month, and on each visit 3 samples are to be taken. Number of observations at each s t a t i o n ............ .......... 36 Total number of observations................................. 396 Cost of analysing 396 filters at $ 1 0 . 0 0 ................. $3960.00 5. Underground Garages: Sites: Union Square in San Francisco Pershing Square in Los Angeles Types of Samples: (a) Lead in air + filter (millipore) for organic and inorganic lead. Visits: One day each week, 3 samples per visit, of which one can be organic lead only. Number of observations ...................................... 300 Cost of analysing 200 filters at $ 1 0 . 0 0 ....... .........$2000.00 (b) A.I.S.I. smoke sampler to determine diurnal variations in inorganic lead. Machines to be operated one week out of each month. Cost of analysing samples obtained from two sites....... $2000.00* * Cost calculated on basis of estimated time required to complete the analyses by a simplified(procedure K f 0003082 -4 - 6. Urban Atmosphere Sites; One station in each of San Francisco and Los Angeles. Types of Samples: High Volume; 24 hour periods. Frequency; One sample every two days. Total number of observations,.,...,,............. ............730 Cost of analysing samples from two sites $4000.00* * Cost calculated on basis of estimated time required to complete the analyses by a simplified procedure Dated; April 15, 1960 Signed: J. Cholak 0003083 -2- > if any, of the occupational exposure to lead of the handlers containing tetramethyl lead, within & year, quite as well as this done in several years. Thus the investigation of this problem over riod of approximately one year, and the preparation of a report at the of that time, should settle the matters that are in doubt in a substantially final manner. It is important, therefore, that this investigation be done with adequate scope and precision. Some unusual situations may be encountered in such an investigation as is outlined here. For example, there may be some unexpected disadvantages or advantages in the use of tetramethyl lead in relation to the somewhat complex problem of the precise behavior and fate of the primary organo-metallic compounds in gasoline storage tanks of large volume.) The mandate is that of conducting "studies that would demonstrate (the) acceptability (of gasoline containing the appropriate amounts of tetradmethyl lead) from the public health standpoint." Inasmuch as the exposure to lead from this source, on the part of the public, is certain to be less than that of persons who will engage regularly in certain occupations (indicated hereafter) involving the handling and use of gasoline containing tetramethyl lead, it is encumbent upon us to determine whether any of these regular occupations give rise to hazardous absorption of lead. By so doing, if the investigation yields negative results, we shall have demonstrated the safety of the public, and if, on the other hand, we should demonstrate that the ordinary handling of gasoline containing the appropriate concentrations of tetramethyl lead is ultimately dangerous, in terms of lead absorption, the use of tetramethyl lead for antiknock purposes will have to be abandoned. In any case, an adequate answer to the present question of the feasibility of the continued use.of tetramethyl lead as an antiknock additive to motor gasoline will have been secured. A preliminary investigation has yielded a 3- partial answer to this question - one which is lacking in adequacy only in respect to the influence of the factor of time, concerning which the observations require extension, as indicated above. A further request of the Public Health Service, directed to the industries involved, relates to the preparation of a report "to the Public Health Service, one year after initiating the substitution (of TML for TEL), on the impact of TML on the contamination of the atmosphere in a major population center, as well as clinical and environmental data demonstrating the (degree of) safety -- - in the manufacture, use and handling of TML and of gasoline containing this compound." This report, as indicated above, should be sufficiently comprehensive to serve as a document which can be submitted not only to the U.S. Public Health Service, but also to other agencies and authorities that have legal or professional responsibility for occupational and public health in the United States of America and elsewhere. Outline of Investigation 1. General Scope. The program of investigation contemplated for the fulfillment of the requirements must include a fairly comprehensive examination of the environmental conditions, with respect to the extent of the contamination of the atmosphere with the vapor of tetramethyl lead (1) in the plant or plants in which tetramethyl lead is manufactured commercially; (2) in representative installations in which antiknock fluids containing tetramethyl lead are mixed with gasoline to produce commercial gasoline; (3) in refineries or terminals in which gasoline containing tetramethyl lead is handled in bulk or introduced into mobile equipment or into other containers for distribution; (4) at service or filling stations where gasoline is dispensed into the fuel tanks of automotive -4 vehicles; and (5) in garages in which trucks and automobiles are supplied with fuel and with various services of maintenance. The program must include clinical examination of representative groups of personnel engaged in the usual operations in the various sites and occupations indicated above, initially and at reasonable and appropriate intervals, thereafter. It must also include the collection and analysis of samples of the urine and blood of the persons subjected to the clinical examinations, at the time of the performance of the examinations (and at other intervening times if and when this can be done advantageously for statistical or other purposes.) In order to include within the scope of the investigation such variables as (1) climatic conditions; (2) occupational conditions, facilities, and performance, (3) non-occupational environmental factors, and (4.) represent ative factors relating to personal health and hygiene within the groups of persons to be investigated, the geographic and numerical base of the investi gation should be distributed as widely as is both possible and practicable. Likewise, for statistical purposes, i.e., for the inclusion of purely fortuitou variables and the recognition of genuine correlationships, sufficient numbers of observations must be made over a sufficient period of time to reveal definitive effects or the lack of such effects. 2. The Selection of Experimental Sites and Personnel. Preliminary consideration has been given to the choice of available sites, following the general conference on the subject on March 10th in which the undersigned expressed his wish to visit the proposed sites in person and to consider their relevance at first hand (it will not be necessary for me to visit all of the proposed sites, since Mr. Cholak, who has had extensive 5- 'experience in these matters, is to supervise the environmental survey of the installations of Standard Oil of California as well as the service stations and garage(s) selected for investigation.) (1) Manufacturing plant. So far as is known, commercial manufacturing operations (TML) are now being carried out only at Baton Rouge, Louisiana. The regular environmental and medical regimen of this plant is adequate for the purposes of the hygienic appraisal of the relative disadvantages or advantages of the manufacture of TML as compared with TEL. The results of air analyses, periodic medical examinations, and the analyses of the urine and blood of the employees will be assembled for the purpose of reporting fully on this aspect of the matter. Mr. Cholak and the undersigned will confer with the appropriate personnel in order to make sure that these data shall be obtained and assembled in a suitable manner. If.it should develop within a twelve-month period in 1960 - 61, that there are other commercial manufacturing operations, steps will be taken to obtain for the record, and to report, any and all information that would appear to have a bearing on hygienic matters. (2) Plants in which tetramethyl lead is mixed with gasoline. The only available installations of this type are at refineries (or bulk terminals?) of Standard Oil Company of California. It seems sufficient now (subject to reconsideration on the basis of better and more direct information) to confine this part of the investigation to four plants that appear to present sufficiently variable conditions of climate and Operation. Certain other installations seem to be less important because of the limited numbers of their employees or because there seems to be nothing unusual in their operations. The sites selected are at the Richmond, Bakersfield, El Segundo and El Paso refineries. The men involved in these operations number approximately 14, 15, 14 and 8 respectively, thus providing around 50 persons altogether, a sufficient number for the purpose. (Only 1 man is involved in Salt Lake City, and while the number of Bien so employed in Vancouver is sufficient to justify the inclusion of this group, there seems little point in so doing unless the operations or the conditions surrounding them are found to vary appreciably from those at the refineries listed above. This situation, however, is worthy of careful consideration, since there should be no basic fault in the experimental regimen because of an omission.) It is to be expected, ii$.view of the established regimen for the medical supervision of these employees and the undesirability of interference therewith, that the examinations will be carried out in the usual manner, and that the collection of samples of blood and urine be obtained by the responsible physicians in conjunction with these examinations. Certain modifications of the regular regimen are suggested,however, as follows;~ (a) It is recommended that these examinations be carried out at quarterly intervals, beginning as soon as may be convenient after the operations concerned with TML have been initiated. The clinical data, as well as the analytical results on the samples, will then be available in sufficient volume for satisfactory comparison, on the time base of one year. (Containers for the collection of samples of urine and blood together with instructions for the same, will be supplied to the respective physicians, and these samples will be returned to The Kettering Laboratory for analysis at quarterly intervals.) (b) It is desirable, if feasible, that the examination records (record forms) be the same as those employed in making the examinations, later to be described, at other sites. This arrangement and the provision of a copy of each record for The Kettering Laboratory will facilitate the extraction -7 - of the clinical data for study and comparison. Record blanks for this purpose will be supplied by The Kettering Laboratory to the examiners. The examinations should be made and recorded in as uniform a manner as possible by the several physicians, and some advice along these lines will be sent out from The Kettering Laboratory with the record forms. Despite the somewhat formalized procedures indicated in this relationship for the purposes of a systematic investigation, it is not desired or intended that the physicians should be limited in the performance of their function to the investigative role. Our intention is that of ascertaining the facts, through these expert eyes and ears, concerning the extent of the hazard of lead absorption associated with the handling of concentrated antiknock compounds under the present conditions in the mixing plants. Under certain circumstances this hazard might be highly significant. Errors or accidents in blending,or faults in the equipment leading to the escape of liquid or vaporized TML,might create hazardous conditions, and the seriousness of these, if they should occur, will be matters of importance. Physicians are urged, therefore, to be on the alert, without harboring anxiety or communicating it to the personnel under their supervision. Any untoward developments among the workmen, whether in the nature of illnesses or of undue concern for their safety, should be reported to Dr. Curtis and passed on to The Kettering Laboratory in appropriate manner according to his judgment, either as pertinent information, or as incidents or situations which require further investigation. . The analytical survey of the atmosphere in association with the installations and the mixing operations will be carried out by methods selected by Mr. Cholak and by personnel with whom he is able to make satisfactory arrangements (by local personnel so far as possible so that -8- these observations can be made as conveniently and inexpensively as possible). Air analyses will be made at each site in sufficient numbers and 'Kith sufficient frequency to provide data representative of the variables of temperatures, air movement, and operating conditions. (3) At sites in refineries (or bulk terminals) at which the vapors of gasoline and tetramethyl lead are most likely to be discharged into the atmosphere in the course of commercial operations, loading racks, barrel filling operations, or others. Here too, the persons involved will be employees of Standard Oil Company of California, and present information indicates that the loaders of tank cars and trucks at the Richmond and Bakersfield Refineries will number about 30 persons. The corresponding personnel at the El Segundo Refinery appear not to be subjected to exposure of this type because of the nature of the physical facilities, and, therefore, they are not being included in this part of the survey according to present plans. Whether other refinery employees of comparable type are available elsewhere is not certain (to me), but the group indicated above would be adequate if it is representative of the most severe exposure of this type that is likely to be encountered. There are said to be 10 persons in Seattle and Portland combined, whose work involves the filling of drums with gasoline. Whether or not these men should be included in the survey will depend upon the severity and constancy of their occupational exposure to vaporized gasoline. This occupation might turn out to be highly significant as a source of exposure, but t h e . latter may be too slight to merit consideration. The distance between these two sites and the others under consideration will provide an unreasonably great obstacle to their inclusion (considering the small number of persons 0003090 -9 involved) unless they provide occupational conditions of fairly crucial importance. These employees of Standard Oil, in whatever number and at whatever sites may be settled upon, will be under the medical supervision of the Company's medical staff and, will be dealt with, presumably, with respect to the examinations and the sampling and analysis of urine and blood, in the same manner as the personnel of the mixing plants at the refineries, and on the same schedule, with reference to the intervals between examinations and analyses. The numbers of clinical and analytical observations which will result from adherence to this schedule will provide sufficient data for comparison and statistical analysis. A program of air analyses sufficient to portray the environmental conditions - the nature and extent of the exposure of the workmen to vaporized tetramethyl lead - will be developed by Mr. Cholak in collaboration with the available technical personnel of the companies concerned. (4) At service stations for dispensing gasoline to motor vehicles. It is necessary to include in the survey a series of service stations that will be representative in a number of respects and satisfactory in certain others. (a) First, the majority of these employees (attendants) must remain in employment during the entire period of the survey. The selection of sites and persons to be included must be based first on this consideration. (b) Second, the location and facilities of these service stations must be such as to ensure a relatively extensive patronage, and a high demand for high octane gasoline. (c) Third, the number of suitable persons under investigation in each of two conveniently situated and satisfactory cities - San Francisco - lo - obably, and Los Angeles, certainly - from the aspect of climatic conditions , must be of the order of thirty to forty, for purposes of compari son. These stations and persons (in all probability, all of the persons at each station will have to be included in the survey, regardless of their suitability, and, therefore, the total number involved may be appreciably greater than the number of suitable persons) are to be selected after a preliminary review of their suitability in respect to factors (a), (b), and (c) above. They will be examined by members of the medical staff of The Kettering Laboratory, and samples of urine and blood (and, perhaps certain other specimens for laboratory examination) will be obtained during an initial compaign soon after the introduction of TML, and in a second survey carried out nine months (slightly more or less, according to the convenience of all persons concerned) after the completion of the first. (These men are not subjected to any significant hazard, and the nature of their work as filling station attendants is so well defined as to exclude the likelihood of any unusual or unanticipated opportunities for exposure to lead. Accordingly, no useful purpose would be served, it seems, by the repetition of these observations at quarterly intervals.) A program of atmospheric sampling and analysis will be scheduled by Mr. Cholak, and implemented in as convenient and inexpensive a manner as possible. It should include determinations of the extent of the contamination of the air with particulate lead, lead alkyls and total lead at intervals throughout the year. This may be, and in our view should be, combined with a comparable (not elaborate but revealing) survey of the levels of concentration of the same forms of lead in the air of Los Angeles, in particular, and in San Francisco as well, but perhaps in iacent to. but not unduly influenced by, the operations of the areas ' ,cted service stations. (Determinations of the carbon monoxide content s'" of the air should be made in concert with the determinations of lead at the filling stations and at the other sites adjacent to themj Such observations will meet not only the suggestion of the Public Health Service, in relation to a "major metropolitan center, 7 but also will supply current data of a generally useful type in relation to the over-all problem of contamination of the urban atmosphere with lead; in view of the convenience and economy of obtaining these data along with the others, it would be some what less than prudent, in our opinion, to fail to take advantage of this opportunity. The fact that certain other observations of this type will be made by other persons or groups on behalf of the State Health Department of California, or, perhaps for the United States Public Health Service, only makes it the more essential that comparable data should be obtained by ourselves. Our collaboration with official investigators is advisable for several reasons, but, primarily, for the purpose of maintaining for ourselves and for the industries concerned, a direct and satisfactory knowledge of the facts at all times. (5) In a garage. A repetition and extension of the preliminary experimental program carried out and reported recently (Report of The Kettering Laboratory dated November 10, 1959) is highly desirable, in that the occupational absorption of lead by persons who are employed regularly in certain repair and maintenance garages has been shown to be detectable, in contrast to that of filling station attendants and refinery handlers of gasoline containing tetraethyl lead. Any increase in the absorption of lead which might derive from the substitution of TML for TEL, while having been found to be too small 12 - for detection in observations made over the period of six weeks (see Report referred to above) might possibly be sufficient for detection within the period of eight months, or not at all. This possibility seems slight but it must be explored. It is to be hoped, therefore, that a suitable parking and service garage can be found, preferably in Los Angeles. In order to serve its intended purpose, such a garage would have to fulfill the following specifications: (a) It should have good patronage, especially by purchasers of gasoline. A parking garage merely filled to near capacity with parked cars throughout the greater part of the day, with a minimum of short term parking (coming and going), and with only a modest turnover of gasoline, would be entirely unsatisfactory for our purposes. The maximum of fueling and of cars coming and going for that purpose would provide the principal desirable feature, since the concern here is not primarily, or even importantly, with exposure to particulate lead in the exhaust gas, but to unburned gasoline and lead vapors, derived in part from operating cars (as the result of "blowby" etc.), but to a greater extent from the handling (and spillage) of gasoline from fuel pumps to automobile fuel tanks (displacing vapor therefrom). (b) A large proportion of the gasoline dispensed to the patrons should be of the high octane variety containing TML in a concen tration near the upper permissible limit. Otherwise the observations will have little or no relationship to TML and can be counted on in advance to be entirely negative. (c) The ventilation of the garage should be on the low rather than the high side in its speed and thoroughness in effecting changes of air within the garage. I^gr 0003094 .-y / Notations Re Memorandum of April 15 on Field Investigation A. Correction of Error (a) On page 3 of the attachment (Mr. Cholak's memo), see 4. Service Stations. The total number of observations at 21 service stations, instead of 396, is 756. The cost of analysing 756, rather than 396 filters, will be $7,560 rather than $3,960. The correction of this error adds $3,600 to the estimated cost of this item. (b) On page 10 of main memorandum, see 2. The analysis of samples (1) Samples collected $11,960 + 3,600 = $15,560.00 (2) Samples collected - - - - (a) $9,960.00 + 3,600.00 $13,560.00 (b) $7,960.00 + 3,600.00 11,560.00 (c) $5,960.00 + 3,600.00 9,560.00 4. Total Cost - - - - - - - (1) Maximum $22,960.00 + 3,600 (2) Minimum $16,960.00 + 3,600 $26,560.00 $20,560.00 B. Alteration of program (see pages 3 and 10 of main memorandum) It is now agreed, because of the lack of service stations of suitable location and volume of business, that the survey will include 10 stations in San Francisco, 10 in Los Angeles, and 1 in Bakersfield. This reduces the total of such personnel, and results in a proportional reduction in the cost of the analyses of urine and blood. The latter is estimated to be diminished by a sum which will range from $3,000.00 and $3,750.00. K F 0003095; N 6469.03 13 - (d) The personnel of the garage must be of such stability in employment as to justify the reasonable assurance of their continuance in employment during the course of the experimental observation. If there is a high turnover among the employees, the results of the obser vation will be inconclusive and the entire effort will be fruitless. (e) There must be thirty to forty suitable employees in a single garage of the type indicated or in several suitable garages not too distant from the site at which the medical examinations can be carried out. If no garage that meets the foregoing specification is available in Los Angeles, but is available in San Francisco, the observations may be made in the latter city. If no such garage is available in either city or in some other suitable community within the area of distribution of the product, no useful purpose will be served by carrying out this part of the investigation at this time, since, in any case, corresponding work will have to be done later when a satisfactory site shall have been found. An appropriate experimental regimen, comparable in principle and in scope to that described above for application at other sites, will have to be designed to fit the conditions that exist within a garage that is believed to be suitable and at the same time amenable to investigation. Date; April 1, 1960 0003096 The Kettering Laboratory