Document rBNyrEDqpQzNKgjnNqxByMrwV
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M J. E. BOUDREAU
July 22, 1966
Messrs. G. F. Kirby J. C. Carter, Jr. H. E. Hesselberg R. A. Kehoe / W. R. Perdue, Jr. G. Roush, Jr. R. K. Scales A. Silverman C. C. Vogel F. P. Warne
The attached material -written in 19^7 may provide some back ground on the Medical department.
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Hie Medical lepcrtaant of Ethyl Corporation eaaae into existence in June of 1924, under conditions which, antedating the origin of the Corporation itself, vers to exert their influence upon the for and functions of medical activities of the Corporation throughout the jeers up to the present time. At that tine, the operations of General Motor Chemical Company in Dayton, Ohio, were just emerging from their early developmental state into the ccsaaerciai blending and die trihution of an antiknock compound. Coincident with the increasing scale of these operations, the toxic properties of the constituents of the antiknock compound gave first evidence of their true significance, when, without apparent warning, a group of workmen fell ill and two of them died with what is now recognisable as tetraethyl lead poisoning. This situation called for some combina tion of medical care for the sick men, and a thoroughgoing investiga tion of the disease from which they were suffering end the environmental and physiological condition which gave rise to it. The present head of the Medical Department, Robert A. Kehoe, a physician and a physiologist in the University of Cincinnati Medical School, was net: at hand and known to Thomas Midgley, manager of General Motors Chemical Company, and was approached for advloe and assistance. Ihe time (Msy, being at the end of the academic year, it was possible, without delay, to undertake the proposed task* The vork of the first summer, carried out in the Dayton plant, resulted in a clinical characterisation of tetraethyl lead poleos&ing, a preliminary and rough interpretation oi the nature and the approximate order of magnitude of the hasards of handling tetraethyl lead and certain halogen carriers, and the develop
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of the sick employees, together with the medical selection and super vision of the personnel of the plant, represented a first responsi bility, which on many days, especially at first, left little time for anything else. However-, as the conditions in the plant responded to the application of good engineering practices based upon the accumulating -leal and physiological information, the uncertainties of the medical -M preach tended to disappear, the anxiety of the employees was replaced by confidence in their security, and the time required for such work .c-crsased in favor of greater experimental efforts. By the end oi
-rr.amber of 1^24 the situation appeared to be well in hand. One odd than view the future of this phase of the industry with reasonole assurance, and could begin to take thought for the actual or :'out*al hasards of its other aspects.
From late la 1^23 on, experimental work on the most signileant problem of public health, - that of the contamination of the vii ci streets, highways, and repair and storage establishments with ...articulate lead compounds in the exhaust gas of motor vehicles -, cad bsen under investigation at the Pittsburgh Experimental i lation ci -te G. : . Bureau of Mines, at the instigation of Midgley . Particii'a -ion in regular (monthly; conferences on this problem inducted the uev medical consultant of General Motors Chemical Company into the -consideration and practical appreciation of these problems, and prompted his to advise an extension of the experimental program of the Bureau of Mines to include the potential hazards of the slight but prolonged exposure to tetraethyl lead through contact with leaded gasoline and exposure to its vapors. This was initiated by means of animal experimentation and carried out in rough parallel with experiments conducted in the laboratories of General Motors Chemical Company by
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staff of General Motors Chemical Company of which he was the head. A little later, Kehoe and Edgar expanded these experimental observations ira te the field of commercial distribution and use of leaded gasoline th under taking a study of the comparative lead exposure of unexposed and exposed garage mechanics, drivera of cars, and filling station attendants.
Ihefforegoing account of the early medical and experimental work ia of more than casual importance in the history of the Medical 1 1 par latent of the Corporation in that they lead up to an event of tajor importance associated with the date, Msy 2o, 1 ^2 5 . '.his date, . cierred to elsewhere ia the annals of Ethyl Corporation, is that of a conference of prominent medical men, public health authorities, ie^iesentatives of industry and labor and other interested persons, called by 5urgecn General Hugh Cuming to consider the problem of public health presented by this industrial enterprise. The proceedings pi this conference are recorded in detail ia U. r. ublic Health bulletin Ho. Ip8,- and its conclusions need not be restated here. It 1:; rat cinent to note, however, that the conservative recommendations cl this conference were arrived at after a lengthy discussion in which highly motional, sometimes lurid, and wholly unsubstantiated state ments were tempered by the observation and facta made available by the experimental vork authorised and sponsored by the predecessors of Ethyl Corporation. Ihe effect of this crucial lest of the practical merits of medical and toxicologic research, upon the executives and medical advisors of the Corporation, was of the greatest moment in establishing the character of future relationships of the Medical Department and its future medical and hygienic policies. As a part of his report of experimental work to the Conference, Kehoe presented the incomplete result of clinical observation on garage mechanics, drivers
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their excretion#. A full report of these rsulta vas prepared
shortly thereafter by Xehoe and Edgar and presented to the Board of Directors of Ethyl Corporation, Since, by that time, the lnvestige tien of the ;ublic Health fervlce vas under way, these results vere not published until a considerably later date (J.A.M.A. j3j: 2j81, 12\-, . -he subsequent confirmation of these results. In part and officially, in the investigation of the Public Health Pervice, and more validly and significantly by the later- extensive investigations sponsored by
thyl Corporation in the Kettering Laboratory of Applied Physiologyin the University of Cincinsti, served to establish the prestige of the Medical Department in tbindustry and among technical and medical people in related fields, thereby implementing its subsequent efforts to promote the broad hygienic program adopted by the Corporation. Prom the general medical and scientific viewpoint, moreover, this Conference and date have still greater significance, in that the data of Kehoe and 1 dfe&r, presented then, gave statement, for the first time, to certain facts as to the lead exposure, absorption and excretion of normal healthy individuals in the American population. These facts, following iheir- confirmation and further elucidation, were destined to have e profound effect upon hygienic concepts and practices in the lead trades and in the coassunity as a whole, with respect to the physiological significance of lead exposure.
January of 1926, following upon the report of the investigation of the Public Health Service, saw the resumption of the consaercial operations of Ethyl Corporation and the organization of the Medical ^ Department. At that time the medical and hygienic program of the industry as a whole came actually to be centered in one group, namely, the Medical Department and the medical research organization of Ethyl Corporation. Ihis functional coordination of these activities at one
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.lace, essentially under one head and general program, has such significance in relation to the past history as veil as the probable future or Ethyl Corporation that it deserves aphasia. Only by the lorce of unusual circumstances, among vhich the initial deadly threat to the survival of the industry looms large, could have brought the .hiee industrial group# engaged separately in, (1> the manufacture ci' the antiknock compound-(Du Pont), (2) the sale and distribution of the compound (Ethyl Corporation;, and (3) the manufacturers and dis tributers of leaded gasoline ( a number of the oil companies,, under one professional influence. fihis came about largely by reason of a verbal agreement, on the part of Ethyl Corporation, with the United f tates Public Health Service, to implement a series of recommenatione made by the Surgeon General of the United States Public Health Service, for tne control of the hasards of the business. rihe fulfillment of ti/. agreement made it necessary for Ethyl Corporation to establish medical policies and procedures vhich under ordinary conditions would have been regarded as intrusions into the affairs of the manufacturers of the product as veil as the customers of the Corporation. Before long, hcvever, there va a general acceptance of the fact that the medi cal advisors of Ethyl Corporation alone, among those who might other wise exercise influence in these matters# had access to the information that vas required to provide intelligent hygienic guidance. In short, co ^3-he facilities for medical and hygienic research made available by oEthyl Corporation then and expanded since from time to time as o required, have always constituted the cornerstone on vhich the wisdom ^ and adequacy of medical policy and procedure for the control of the basaids of this industry have been based. One aspect of the coordination referred to was accomplished through the multiple role
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while acting as chief medical consultant UMedical Director; to Ethyl Corporation# and medical consultant# in relation to the manufacture oi tetraethyl lead# to Du ront. The other factor in the application of one hygienic policy in the industry arose from the urgent need oi controlling the manifest hazards of the operations involved in the raising of the antiknock compound vith gasoline. The most careful consideration of tH3 serious hygienic problem, on the part of execu tives and medical advisors of Ethyl Corporation# resulted in the development of a program whereby the Corporation undertook to provide the medical and hygienic supervision of mixing plants and mixing personnel# and to set up, in detail# the regulations under which this work was to be done, ihia program involved the unique feature of loioral acceptance (by contract;, on the part of the refiners and distributors of gasoline# of medical regulations and instructions issued by Ethyl Corporation.
The foregoing items of policy and procedure may appear to be given undue importance in this recital. Moreover# they may be suspected of attributing undue prominence to medical work and per sonnel. On the other hand the purpose of this history is to recount and explain the past as a guide to the future. The emphasis# therefore# la upon ideas and principles arrived at largely through an interpretation of the acts and developments which grey out of the problems of the time and the compulsions of circumstances.
In the matter of developments# it may be remarked that the natural outgrowth of the principle of research as the basis of medical vu X and hygienic practice In industry was the relationship between Ethyl Corporation and the Kettering L&boratoi'y of Applied Physiology in the Medical College of the University of Cincinnati. The acceptance and
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the creation of this Laboratory and in its development as a responsible public source of medical and hygienic information. At the time o: uhe creation of the Laboratory, and since, other industrial organisations joined Ethyl Corporation in providing, these facilities for the University of Cincinnati and in supporting the investigative program, hcvever, Ethyl Corporation was the prise over in founding the Laboratory, as veil as its principal source of financial and moral support In its developmental period. The staff of this Laboratory began its vork in the rhyslology Department of the Medical College cl the University of Cincinnati, late in 1^25* Dr-. Kehoe found it impossible to continue to absent himself from hia duties in the University, and, at the same time, it had come to be apparent that m e investigative program,engaged in on behalf of Ethyl Corporation, lit ted Into the public pattern of university activities. Accordingly equipment and such personnel as vere willing to do so, were trans ferred from the Dry ton laboratories of Ethyl Corporation U n the General Motors Research Laboratory; to Cincinnati. The group so installed remained nominally in the employ of Ethyl Corporation for a time as a matter of convenience, and additions vere made to the stall on that basis. Eventually, hovever, the policies of the Univer sity required that the research activities of this group be absorbed into the academic structure of the University of Cincinnati, and all the individuals were given formal appointments in the Department of rhyslology of the Medical College, i separate laboratory building soon came to be a necessity for carrying on the increasing volume of work on the problems of Ethyl Corporation and those of certain other industrial organisations. Several of such organizations joined Ethyl Corporation in making a gift of funds to the University of Cincinnati,
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by mean of which a new laboratory vas built. 'Jhis laboratory received
iia name, in honor of Mr. c. f . Kettering, on its completion and
dedication in December of 1^2tf- Its activities have continued to
expand until, in 1^41, a small addition to the building vae mac=,
through a further contribution by i.tfayl Corporation, and in
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this addition vas extended so as to double the size of the original
building. The latter vas made possible by the contributions of about
a score of large industrial organisations, which, with Ethyl Corpora
tion, had supported the investigative program of the laboratory,
through its encouragement and tinancial support of this enter-prise,
Ethyl Corporation has acquired access to experimental facilities for
the systematic investigation of its own medical and hygienic problems,
and at the same time has been actively instrumental in the development
of & much needed center- lor Industrial medical investigation and
-he peculiar responsibilities and activities of the Medical Department of Ethyl Corporation also resulted in the creation and development of an allied organization devoted to the maintenance of the safety of all field operations in the 'ales Department of the Corporation. The origin, growth and development c-f this organization and of its functions represents a chapter, in itself, of great inters c.^. and importance in the history of the activities of Ethyl Corporation. * Its somewhat unique character, guided, as it is in all matters of hygienic policy, by the Medical Department, and yet administered and directed by sales executives, constitutes an example of the capacity oi a rather large number of individuals to cooperate in single-minded devotion to an high purpose. The safety organization,managed with great zeal and meticulous attention to detail tor many years by C. b . Lewis and now under the capable direction of g.. 0. Jones, had its
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origin fend Its most important initial function in the work oi designing and Maintaining field equipment for mixing "Lthj 1" antiknock compound with gasoline. The pioneer in this work, when the ^ e o a n tjpe oi commercial operations oegan in U 2 j, was E. M. Valterji. Heatf the end cl the first year of these operations he introduced the idtii and designed the first equipment by v h i c p u o p a could be eliminated in the actual movement of the compound, and an "eductor", active tea by a stream of gasoline, was employed to draw the product from it? container into the gasoline with which it was to be mixed, the adoption of tnis principle, whereby contact of the concentrated material with the moving parts of mechanical equipment could be avoided , and the product could be handled at reduced rather than elevated ;lei sures, has contributed incalculably to the simplicity and safety of the mixing operations, and has represented & fundamental contribution to the control of the hazards of this occupation. Walters, as ...osis Lent rales Manager of the Corporation, in which capacity he had many other responsibilities, continued to direct all the work related to mixing installations, maintaining a continued contact with the Medical Department for advice and approval of specific plans and specif Ications for such equipment, until his untimely death in Lecesaber of 1 Luring his regime and largely through his initiation and design, '-he bulk type of mixing equipment (tankcar-to-weightank;, now in use most widely, was developed and introduced. This constituted a second fundamental step in securing the safety of these operations by the application of sound engineering. In later years the further design of mixing equipment, the engineering features of the operations, and the technical supervision of mixing plants passed through various stages of development, with authority residing in various hands, and with significant contributions made by various persons, all of whom
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' 'ibe responsibility of the latter ior final decision vith xeieience to the compatibility of proposed engineering procedures vith the ultimate saiety of personnel concerned vith the transport of the product and vith mixing operations, has never been a matter of question ex controversy . 1 rom the organisational viewpoint, certain changes occux red from time to time, engineering and technical field super vis lor* of mixing plants being first a function of the Sales iep&xsment in collaboration vith the Medical Department, then being transferred, as to its xesponsible direction, to the Medical Iepar-iment, and latex .turning to the fries Depax-uaent, where it operates at present as ax: integrated part of a sex vice organisation to the cuatomex-s of the Corporation. ihe present stage of th organization became mandatoxy, partly because of the variety of the operations and the necessity oi -heir integration with other field activities, but largely because of the emergence of an hazax-d which lot- a time x-eqaired heroic efforts on the pax-t of the entire field staff of the Cox-poxation fox* its control, ihia hazard - that associated with the cleaning of gasoline storage tanks - now recognised as the most serious of the occupational h&saxds of th industry, because of the virtual universality of its geographic occurrence, and because of the difficulty of keeping it uiider observation, was not anticipated originally by the Medical Department or by the technical personnel of the Corporation. It vas recognised for the first time and somewhat incompletely in 19Z$* and regulations were Issued by the Medical Department for its control. rhese regulations required modification, shortly after their initial issuance, in ordex* to cover th various features of the hazax*d as they came to light, but even after they x'eached their present satis factory state tl^J2 vith only slight changes in detail, since) they were ineffectual because they were not always applied at a point
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vhere a tank used for the storage of leaded gasoline was being cleaned.
Ihe problem has been a difficult one# since it Is many sided. Involving
in scaae measure, all transporting equipment for gasoline and all
containers used in storing and handling leaded gasoline, in all piaits
ci the world. After a series of cases of poisoning, numbering mere
than one hundred among employees of American manufacturers and dis
tributors of gasoline, of whom more than a score died, it became
apparent that steps had to be taken to bring this hazard under control,
cespite the reluctance, on the part of representatives of Ithyl
,,orporation, to extend their activities further into the operations
o.f customer companies. Li ly*>5, following a series of meetings of
executives of the Seles Department and representatives oi the Medical
department with various groups of the field staff, a program of
observation and investigation was worked out, whereby, until further
notice, the large proportion of the gasoline storage tanks in the
ini ted states and Canada, that were to be entered for cleaning, were
to be observed by representatives of the Corporation during their
cleaning. Samples of their water bottoms ana of scale and sludge veie
to be obtained for examination, and detailed information concerning
the previous use of the tanks was to be assembled for study. *rne
plan of an integrated experimental study was worked out in advance
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through the collaboration of the Tales and Medical Departments, with the understanding that the information was to be gathered in the field and furnished to the Medical Department. All of the samples were to be analysed and all of the results were to be correlated and interpreted in the Kettering Laboratory of Applied Physiology, under
the direction of the Assistant Medical Director of the Corporation,
Dr, k . f . Machle, who was also the Associate Director of the Laboratory
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After many months of faithful and intelligent vcrk on the part of the field staff, and after further months of careful statistical study of the results, a report was issued in 1^4j , which pointed clearly to the necessity of maintaining the intensive organized collaboration ;i field personnel of Ithy1 Corporation in the tank-cleaning operations of customer companies. The history of this collaboration, and the developments that have followed further investigation of various aspects of this problem would take us far afield into a voluminous account of organizational and technical details, he basic facts, .recounted as briefly as possible, will serve to demonstrate the functional and historical association of field and service stall v.Vth the activities of the Medical Department, thereby illustrating, m e point that industrial safety and hygiene in the- hazardous chemical trades is largely, of necessity* and by its very nature, a medical matter which requires medical research and medical direction for its implementation.
While the various activities of the Corporation were developing and expanding, the Medical Department grew in also and in the scope of its activities. The first year of business after the investigation of the Public Health rvice, ll^2C;, can be said to be the actual beginning of planned commercial operations, and the first stage in the organization of a Medical Department. luring that year, and subsequently, additions were made to the traveling medical staff with headquarters in Cincinnati, as the systematic examination and re-examination of an increasing number of mixing personnel in the Vij refineries of customer companies required. Men of high calibre and of sound medical training were needed for this work, and despite the personal and professional difficulties associated with this unusual
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longed periods of time. This vas made possible because the executives
of the corporation were willing to follow the policy required 10
certain unattractive qualities of muck of the medical work. Members
of the staff of the Medical Eapartment were given opportunities ant'
were encouraged to engage in other investigative and professional
activities that were not incompatible with their responsibilities to
i thyl Corporation. By such means they were spared the rigors of
continuous traveling and were enabled to avoid a degree of isolation
from other professional colleagues and activities# which would have
made such a position unacceptable at any price to a well trained and
generally competent physician. Through the operation of this policy
the physicians of the Medical Eepartment, as a rule# have conducted
their work as virtually full-time (in the sense of continuous respon
sibility; members of the staff and with the benefits and privileges
associated therewith, while engaged in restricted private medical
practice or in organised investigative work, feveral of them have
had formal membership in th medical faculty of the University ci"
Cincinnati# by virtue of their appointment to th ft&ft of the
Kettering Laboratory.
The first physician to be added to the medical staff vas
Li . Karl v. hitzailler (1926;. The next# within a few months, was
in E r . Vi. 1 . M&ohle (1926), to be followed/ succession by Dr. R. L.
Gxudgington and Er. Lester W. Ganders (1927;# Dr. L. J. Schradin
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and Er. Francis F . Heyroth (19^2). Dr. Crudgington relinquished his
duties in 193^# la order to devote himself to the practice of obstetrics
and to take up more extensive duties on the obstetrical staff of the
Cincinnati General Hospital (the teaching hospital of the College of
Medicine of the University of Cincinnati). Dr. Machle# who became
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was on military leave l'ioa October of 1^42 until October li}45, during which he directed the U. 2. Array Medical research Laboratory at I o n Knox, lienlucky. He returned as head of the Sew fork office of the Medical Department, taking this part of a nev function of the Medical Department which will be referred to later. rihe other members oi the medical stall as named above have continued their professional servlets on behalf of the Corporation. Dr. Kitzmiller has been Assistant Medical Director since 1h46.
Ihe original program oi the Medical Department was concerned with the medical supervision of (1; members of the field staff of Zthyl Corporation whose occupations involved actual or potential exposure to lead hazards, (2J members of the technical staff of Ithyl Corporation in 'search and testing laboratories, and (3, employees of customer companies in the United States and Canada engaged in mixing operations or In ether occupations which gave rise to hazardous expo sure to tetraethyl lead, the physicians vex-e also required to inves tigate reported cases of illness among garage mechanics, refinery personnel engaged in handling leaded gasoline, filling station attendants and all other pex'sons, including the drivers of automobiles, when any of such cases were thought or alleged to be due to exposure to leaded gasoline or to the exhaust gases of automobiles using le&aed gasoline as a fuel. Medical representatives were also to consult with and advise refinery superintendents and other executives and technical personnel of customer companies on problems arising from their use of the antiknock compound, and to maintain such regular contact with regional and local representatives of customer companies as to be acquainted with their problems. This vas facilitated greatly by the eventual development by Ethyl Corporation of a trained staff of
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oi customer companies, whether in the promotion ot sales or in the
technical control of hazards, vre of great help to the physicians.
.he technical supervision of mixing plants and the medical supervio.cn
0 1 the personnel were coordinated efiactively by an arrangement vhe.--.-iy
the doctor visited the plants in the company oi i;..- appropriate membex
ol the field organization.
Viith the advent of a program of health and sickness benei its,
-..rovided by thyl Corporation for all of its employees, in lySS, the
work of the Medical Department was expanded to include medical exami
nations for all new and prospective employees.
far as possible,
these examinations were carried out by traveling members oi the medical
tall, however-, the geographic distribution of division oil ices, and
the tact that the headquarters of the Medical, I epar tment was in
Cincinnati and not New fork or Detroit, made lor inconvenience and
delay in the performance of these examinations, for this reason, a
,-:;rcu: oi local medical consultants was engaged to carry out pre-employ
ment examinations of applicants for positions in thy1 Corporation
when and as requested, and to report these to the Medical Department.
these consultants were located in New York, in relation to the New
fork office and th Yonkers Laboratory, in Detroit, and in other cities
in which there were division offices. Members of the Medical itail
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have maintained close professional contact with these consultants,
familiarizing them with the relevant medical policies of the dorpora
tion, and integrating their vox-k with that of the Medical Department.
u, he foregoing development led to the advisability oi fur theiextension of the medical services of the Corporation to its employees,
and paved the way for the present program of medical service and, so
to speak, medical maintenance flans were laid during the war, and
consummated s soon as possible after its close, lor providing net oni^"'lire-employment examinationo for all employees, but also annual examinations, vith somewhat limited opportunities lor certain types ci medical advice in the interim, 'ihis required the development c: a medical .;ff.tce in Hev York, and an extension oi the medical f&cilitier ci ne Ltroit Laboratory. Br. Machie took over the reoponsibili ty . .. ,j3 development in Kev ork, and soon associated vith himseix an
. uad laborstori' staff of tv persons and an assistant physician, . uii Layer * At the same time, this group took over the respansi.,,1. -.v ior all personnel of Ethyl Corporation in the Nev England and iiacal^hia areas, and loi1mixing personnel of customer companies in na t .
ihe Ietroit Laboratory, under the medical supervision oi 1a-. 1J-nders as the visiting physician, had first acquired the services
& nurse for first aid and minor medical service to its stall in lj- Vith the adoption of the more comprehensive program oi medical work, it became advisable to engage the services of a physician tc visit the Laboratory daily and to set up and maintain a schedule oi
J. ,ex Iodic examinations. Dr. carl/Sjprunk of Detroit assumed these duties, in vhich capacity he now acts as assistant to r. Sanders.
At the and of th war it v&a possible to augment the stall ol tx-aveling physicians so as to lighten the load of medical work vhich had increased steadily during the var and of necessity had been assumed by the existing ataif. B r . Earl Boty was appointed in this
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x iole in iy*5, first as assistant to Dr. Schr&din, then as a stall member assigned to an area in vhich he assumed full responsibility for the medical supervision of personnel of both Ethyl Corporation
and oil companies.
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implemented, a new phase of medical work came Into being, in that Ethyl Corporation took over the operation of its manufacturing plant in B*ton i-ouge in fopt ember of ly45. It became necessary to organise a tlant medical service, without delay. fortunately this was not as difficult as might have been expected since the Medical Director of Ethyl Corporation, acting as a special medical consultant to E. 1. Du ront de Nemours and Company, had had intimate and continual familiaiitj with the Baton Rouge plant and its personnel throughout the entire period of the existence of the plant. After a period during vnich the physicians of the Du Pont medical staff remained at the plant tc carry on the medical services as they had before, Dr. itoy c. A. Dock was appointed to head the Medical Staff at Baton :ouge. Dr. Villlam V. Corbett, formerly of the Du Pont organization, elected to remain, and other physicians were found to assist Dr. Bock in the work at Baton Iouge. Ihe present medical service at Baton ..ouge, which will require some expansion when a new medical building has been completed, consists of icur physicians, Dr. H . C. Harris having joined Dr. Dock and Dr. Corbett in November of lj>4$, and Dr. George D. Dicks having come in October of lyM*7. Oh full staff cf the plant dispensary. In conformance with the requirements oi lilt vailed services, (formally approved by the American College of Surgeons) is made up of nurses, technicians in the clinical and X-} ay laboratories, and secretarial assis tents.
Ihe beginning of commercial operations in Mexico in IjO # required the appointment of a physician residing in and licensed in that country to supervise the mixing personnel of the gasoline distributing companies. fihia was accomplished when Dr. W. J. Lynn agreed to undertake this work. Dr. Lynn died in November of 1>37# and was succeeded by Dr. Salvador Bermudez, who la associated with
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the School of ublic Health in Mexico City. Ir. Bermudez maintains u close consulting relationship vith Mr. L. M. thillips, vho represents T.thyl Corporation commercially in Mexico# and sends reports frequently to the Medical Iirector.
the activities of the Medical leper tmen trover the ears, arid L ta present 1unctionshave been indicated in the preceding account. In order to summarise them and to demonstrate the functional pattern oi the Department as a whole, a chart has been prepared and is attached'-vc additional features of the aedic&i activities mentioned in the chart, as duties of the Medical Director appear to require elaboration c-.s history and as present policy.
-he occupational hazards Involved in the conduct of this business enterprise, and the Justified concern manifested by health authorities and by the public in relation to the effects ci d^sfeure to lead compounds, have necessitated the maintenance of close and mutually frank relationships between the Medical :eparusent of thy 1 corporation and responsible public health officiais. fuch a liaison has been ms.Inf.alned with the LF. I. Public Health Service, and when hthyi Corporation has extended its activities Into other countries, cue public health authorities have been consulted beforehand and put In possession of all the available information relating to occupational or public health. By such a policy, and by virtue of the systematic publication of the results of investigations carried out in a responsi ble institution of learning, the good faith of the Corporation has been shown and its medical representatives have been accorded a respectful hearing. Indeed, on aeveral occasions, their professional assistance has been sought in dealing vith problems of public and governmental
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policy and procedure in relation to this Industry. The conduct of the admittedly hazardous business or Ethyl
Corporation has been fraught vith more than an ordinary need for the means of defense against litigation based upon false or mistaken claims of injury to the health and well-being of persons engaged In specific occupations or merely represented in the general population. This need had been one of the factors which has justified the expense of the program of hygienic research sponsored by the Corporation. In addition, - t has been a duty of the Medical Department to maintain intimate and detailed acquaintance with all of the activities of the Corporation which might, conceivably, result in medico-legal complication. It is true unfortunately, that very few of the business operations of the Corporation fall outside this category. Consequently the Medical Department has been required to enter Into the discussion of all manner of policies and procedures which, ordinarily, would be regarded as strictly related to commercial matters. It has had a degree of authority deliberately delegated to It by executives of the Corporation, the exercise of which, under other circumstances, might have had an arbitrary and dogmatic character. The point which has been recognized and implemented, is that if the Medical Department must accept pro fessional responsibility for the guidance of the Corporation in matters of public policy related to health, - as it must under legal attack it must have minute and detailed knowledge of what is done by represen tatives of the Corporation and, in many instances, by customers of the Corporation. It must also have an authority commensurate vith its responsibility. This has translated itself into an organizational relationship which is not common in American industry, in that the Medical Director has derived his authority directly from the President
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MBHOftABDOBt OBJHE OBJECTIVES ABD0PERATI0B3 OF THE! fUSPlCAL BSPARTMEafE OP BW0OUCOEFOKifflOB - 1953
C/bjeafives
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The primary objectives of the Medical Department of
Ethyl Corporation are t
L . Continuous appraisal of the occupational and
nubile h&Z&V&& to health associated with the operations of the
Corporation, aa thee derive frost the manufacture and distribu
tion of all of ita product a (clinical, epidemiologic and physio
logic 2 search) *
2* Protection of persons who m y be subjected to
hazards from Ethyl*s products or operations;
a. The employees of the Corporation;
b * The employees of carriers of the products;
e. The employees of customer companies whose
handling of these products (principally FiTffL
fluids) exposes thorn to significant danger;
d. The public
3* Maintaining employees of the Corporation in a
state of health, so far as may ho possible vithia the limits of
the medical policies and capacities of the Corporation, and giving
advice and assistance toward appropriate medical care when pre
ventive measures fail.
Secondary but essential objectives are those of? 0
1. Coordinating the activities of the Medical Department
with those of other departments, notably manufacturing, sales and
0004768
research, to tire end that hygienic considerations are maintained in a prominent position in the conduct of tire day* work;
2. Cultivation of familiarity with current policies and plans for the further development of the Corporation,, at various points of contact, including that with major executives,for the purpose of providing such guidance on hygienic matters as might be indicated*
'fiSBSFTAnSBdB ;urs>:
Medical Director lovember 24, 1352
0004769
APPENDIX
Operation The operation which are concerned with the foregoing
objective are the followings Direction and Admin!stratIon The Medical Director limits his activities mainly to
the general administration of the activities of the Medical .Department, but paya, particular attention to those operations that seem to him most crucials
1. Control of the hazards of the manufacture of tetrae clivi lead;
2. various current and long term investigations on the medical and hygienic problems of the Corporation, initiated by the Medleal Director and then followed in his capacity of Director of The Kettering Laboratory.
The Associate Medical Director is responsible for the day-to-day conduct of the medical and hygienic operations of the Corporation, with particular reference to the clinical and safety programs. He also coordinates the clinical work of the manufac turing plants with that carried out in theCorporation, generally, and does a considerable portion of the clinical work himself.
Medical Caro of Ethyl Personnel The regular clinical and first-aid operations involving
personnel of the Corporation, exclusive of the two manufacturing plants (Baton Bouge and Houston) which are operated and budgeted separately, are carried out by regular medical consultants in Hew York, Detroit, Los Angeles, and Cincinnati, and by Medical Super-
visors whose headquarters are in Cincinnati and whose principal
2.
activities relate to the medical oar of employees of customer companies# In this work are Involved nine physicians and two nurses (one each in Few York and Detroit}
Medical Car of Customer Personnel
The regular clinical supervision of blending plant
personnel (and that required occasionally for other customer
personnel) involves approximately four thousand persons in some
four hundred locations# scattered over the United States, Canada,
Mexico, Cuba and certain south American Countries (Venezuela and
Chili at present)* These employees of customers are examined
periodically and maintained under instruction and supervision by
a substantially uniform and personalised, procedure, which, thus
far alac 1926 when this work was organized and inaugurated, has
Ducceeded in preventing the occurrence of lead poisoning among
this group despite the potentially great severity of their occu
pational hazards* The Associate Medical Director, the three
Medical Supervisors, on part-tisi plant physician, slx regularly
retained Medical Consultant, and throe local medical consultants
(in Venezuela and Chili), i.e* fourteen physicians in all, are
concerned with tka conduct of these medical operations*
Clerical and Financial Operations
.
The maintenance of the sedlcal records of Corporation and
customer personnel is the responsibility of one confidential secretary in Cincinnati*
The maintenance of the records and correspondence cf the
Medical Supervisors and regular Medical Consultants, as those
relate to' the plants and the nansg^ent of plants of customers is
carried out by on secretarial assistant, who is also the secretary
of the Associate Director the financial ssatters involved in the operations of
the Medical Department and in the activities of the Kettering Laboratory as these relate to Ethyl Corporation, are handled by a financial secretary, vho also is the accountant for the Kettering Laboratory.
One additional secretary is confidential secretary to the Medical Director of the Corporation. Her vork includes secretarial responaibilit to the Director of the Kettering laboratory
ovr.Kber S4 195-
Robert A* Eofeoe, 8. D. Medici Director
0004772
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grap&ie stari and ttse Sa !ork' eseoutiva grmsp., and all ite peracofi!
f resMrote arsa teetSDg Xaboscitorl * Oriaiaailjr tal sonatitutad
aoi-o ttaan tvo*tteird* of Ih apio?* 1 tu Corporati. M e o m
tSm& veafc on* oasteora of th elafi: of ite Modica! ttepertmeat ore
eailed upoo fo* matle&X ad vie by eacoeutivaa 'la &w Storie aad by
'
pareo&ael la all area of aoiivliy of lisa Corporation* hls cccurrod
prlaai'lly beoauea of th capate-Iliila of tue sodica! etaff aad beoauee
of ih frequeot and urge* oeed for sedia! advlea ubiate area* aaasg
ti3e posponete! f'im m lo n o questi ae te tt daai ratei!!ty oad th
.uniti* to tue voi'pomtioa of havlag caca sorvice avallateio vitata
re&sosateX llaits. Haay situati over t'm yetera lavo aria la
vuic sediosi old bea be@ yendered vteich M a resulied in oaivaglag
individua! aad la bai llag arsraio asosg tao pareot*! of tu*
.osporsi,io
.
vith th inttugastetlan of vmittmm teea!tte ad siafeaeaa tecae*
lite ror all ejap!y@ of Use Corporation il teeoSEs aeceeeari for ta
dedicai Dopartet to sua th roeposalMlity of -pr*ca|iicgiaeat
u-aamiimti.on& for all anployeae of teOotpavtetlost#sd io deai vitte
noioal protelano arislisg out of tMs eitu&tim. 2teesaturo of
dtaateilltlea thei? cooposeablilty * ttesir iapiicaUo viite roepoct
io durai! aad protesatela oui-aoao# liso sutesequent esployatellifcy of
indlvidoale# aaa elsdLlar seti-ere# M & io tee dealt vita* Becaiwe of
tte vide distribuii of ttee spXoyee of th- Corporation, tte direct-
janfiliag of isdividoel oaseo baca trouteiaaooa and simulive* aad
tteareforo a carie of locai ooaeuitaatc vara agagsd,. to care far "" sue saitara at tb cali of ttee Medica! Diraete r or aeoteore of ite, ttodleol 3taff ftithsKit eoissg lato dotai! tea t profoesioael natta*# tteo vork or euete ccMostiltaate Ma eivaye beati a probi to dea! vita, unti! interna aod frequent eoyreepoadoiMsa o tastiere of
'.. X & 0 0 0 4 7 7 4
' 3*
eosapaeqr aft pTQtm&i&ml pollor* ara fCQuired, end because of the
fact that tneae natters are rarely of first laportaaoe to ok engaged
la primi practice# it la dlfflealfc to achieve tmt quality of aedi* cal service vitioh nonbera of the fla&Unfcl Staff of the Corporation have
dosirod to provide,thaeelv,aaa obtain froa other.
' *1 setting up of the Sew Xor& Medical Office vue the
outgrowth of this general situation* It m m a logical aft# in the
opinion of tu Medicai Director#an highly deeirefcl ove# 11) because
of the growth in nushers.of the Self Xoik group# (2j because of tn
iapor-tano to the corporation of th health msaicaanc of its top
aanagcMnt and Cp ) because of the increeeiag difficulty of handling
oiedical p^oblaa hr reset control
lias tahlienaent of its 8 Xor& lexical Office <mm about
iato.- tnaa che nced which it was dosignod io scoi* lor a naatoer f
icasone > iti urgeat ne& for odioal peraomel in Menti*! servioos
uux-mg th vasr# th uMsfldlafelllty th right pcroa fon ta oh#
aie*/* lt vas noi ercafcod# tlMu**?* wtthout i-ol&tion to use
considercd indicai golioie tot th Carpeetotlan imi wao, in faci# a
;?art <:;! such pollai li ht feeen appii-ss e ver tb yeor* * ih
tatuai tino of ite estabXXabei*t w&a ooaa&tloMd by ti foet u t
th right pcrsca# in Us opinion f th Medicai Birector, hocm&
uvallaci, through a osx&iaafciQ of irouneeaaoee* in timt Doctor
bilicati machie# o Icavo fra th Mediani Deparfasmt durusg th ma*.#
d e d d e a to go iato U nioni dica! praatioe ratfear than to return
io hs post m lealeteat Medicai Director rad Aeaoolftt* Director of
l lettering iaboratory) *
Corporation hod a largo etake la
Bocter ilachle# in tbat hia fiftao yeera or ocre of essperioae viti*
-he Moaieal Departraessi and with the accperliwntal pregia relating to
ne
th igieni- problemi e*
Corpoi-anoa# M A fenili tip la hi
a toovltge poeeed % ao ose elee la th crgusatloa seept ti
lie&ieal Direter* snob fe&owleaise le noi asil^ oam by# m thie
represente m, aoeet and aa laveotaent ufelets th corporati eould
ili affer to lese* in additea* hi clinicsUL umiliti* and iti
a<^uain lance vitti th $* 1os*te peareomel af ti Gerperfttleo M g .
hi th ideal choioe for H m task f se-ttlag us fi Ilei# xo*k fiedical
unii* `Jader tfceae circisastaacoa tm Miotti Bireetor rccossaendod
thie court
ttee approvai of csecutivoa of ti sorporcition,
it va& iiasertdkSi.
X* Cn thie baejqp^uad ti presesi and future tatuo of
i-ev Xoxk laisai aotivltiee may he uMJMft ritie&lj. ih-c&a lise
urei? iz<i%oril -vimpaintp aajreful earaUMttiea or U acemplicitseate
:.?f :he Xeni Serie d e d ic a i P t a f f le a ve e l i t t l e `re l'o r doufet ttaat a
ih op&ee o i lesa ttesa tvo ym it usta ohieved i largo w w ^ - e
visat m e xxu sA o & and timi tu rMMt&do? 111 eoa vita tira* r.oss
ilux difxiouxtj arose ai firist la th ra&tter of b naturo and acs?o
v*. survice v&iote nore te be eenteeed uittessut coat lo m & l o y m of
a : Corporati* Thte m t t e r bas beea. dealt trita tim sdoption of
. ::--licy iirnt aedbet o th teisaX Depfcrtaeiit are aot lo aga&o in
c o r s o m i s e d l c a l envloe# f o r seplojroec f o * vhloh. ehargoa ve u M bo
iitaa direotly to ausi* eaployeet * Ofcteer iaor probltone * valete utossati
ito Xae& or uadesetaaliteg or ti generai purpoaea and eoope f ti
rtsdlcal servise an. th pori f r&cssptei or th Corporei le# and vbioh
cari be colvttl sly bj ti miltivailo f proper peiooai and
yrofeseiaaal i!latlcoi3ip&# are nell oa t may io dleappeareae S
KorviQ i good# it imo gaiaed estensive aoeeptaaee and good will
egeag i: eaployee * a M It loos nould he felt oonoldorata^# evea
artor so aliort a tis aa it hae bee la Kleteoee 2f e vianoe of
in jo w o ^ t c r
FOOD H
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fi qufratloo notr poto 1* .aot tMt f ti advantalo or laak or fidvai!tgtt or- ti preoeat Medicai eervicc- to ti corporation and ita spio?* bt vhethor ti Cox^ofratica 'ea afrori ti gooa soioiU servincw provldod* Ofevioualy* col; th mi&agessent of ti Corporation caa anosror tfcia q-weetica. ;levever* In oyder to .pat ti setter on a basta of concede reality# aveli &s to avoA any invidi* iJspXia&Ucsae# ti quetioi* alg&fc veli breat&ted in tir tos*m Are th beoofita of ti np?w vorth th coat? cot cquallp ooneTioiai servi of ocgqparable iyp be provxded at rducod
0091?
In eoaaideriag ti fim i queatlca# to* eope af th s>r*> ssnt seti vitina shcmXd he set agatat tisi? est est ita varai parta# :C89of moh oaaaot be diaparascd viti* mXtss sjcdical poli!** ^coer-ally agresd up&vithia th uorporatlm# -are to ba&eaadoaed. Xt yos recogntsea at th outaet th&i ti ant or ssedieal sorvicea to
'.. 'ov Sork i>oreom@I alone wquM he high if oarrled qui in ti rmaaer
x^sii'tid ty? ti Mediasi i^partiaot, m i f or tisi reseci ertala
activitlea* fcraerly arrled ut by tha pfeoraicUtoa iocs&cd in Cincin
nati//* aiioe&tcd to E* Xm'k* Tdu reduoed th traveli&g spense
fu* e&loai cervie t play** of ouataM* capasi la tha lm
Xitsland area# lishtcsed itm barde** f ti aedioal vovfc or ti
'
Cincinnati group m Xmmre th mmt of tt latie* to thestt! of
Um reductio in tm sraa*il requlrsa to dtt dleal Work* Ai
th am tim* oa&tamt medicai Svio could bygrovldod for eutesser
ecsmtani'h&viiig adijmri* h th'$** in relation to tbsir probiems
of pollo? and o f ssedtc**lgai igaifioaao in sanatic iti* ttei* aaof '^thyl*1flait# ith eoaaid<arbX Snarease Ih ffeetivenea and vith aow eaving in out. *stm% tt&m proviiSe. t m m m or saving th
?
tla Gf tu Uei&X Illreofor* irko up io ibat tla isa hsnlaa all Sso&io*legal natt** for fcJaa Corporation$ 1 anotbsr polut of sog
iMporta ia viw of tu juw rm nis^ dmiuletvativ load f ti
iledieal ftirector in sattere of dlree-fc a wall m ttttirtretNoaaovn
to ti -Corporation
'Tabulated beloo an U m .various nmjor item of tu Ion **s medical aotivities togeiimr iritb V m approdaate coot of each item and tt siaamtioa of tim m t i m coat of tuo pesmtloaa is. 1S48 Sa arriving at, u*e figures to time pent by ti mbers of ti lion York. Medical itali la nodical eesrvie for Btborl Oopponttioii alone* ime bem dotes-
nlned* by analysis of ibe daily acilvitiee of the individual phyelcions
*aa iabulatod) * to be a p p a r i m i ly 53 PhT cent of u r tira. &inao
;:iie clerical and tooimical rfe and all other astivi tie- go along
vith tbe vozk of the pigrale-Ufe Ui proportion of time expended by ilio ptysiciom oa oaois of ti several It ima bean csaabiaed into the proportion of `tin spent by tat group- on U respective itcans.
and tu oatir mat of ti swleal service for tta* year las boon
subdivided according*?* lib book, figure of .^5, p p in round
auribera for 15^8 eows> all of UsspM f of Urnnorie of the lav
fork group niih ilio xee^tlo -of a fon lima of gonoral speme* auch
as Usos of is-aveliag* contrlbuticm to ro-fcirossent plan, and various
types of insurance. The esay bo sttaateii for present jmrpoe at
about $2#0Q'j*;>3# giving a total espeaa of $*8,v>:>j*o-j# \u
;SL,S%$m -- * ^-ySlsSuam^siskSI' i S f i s m B B S B 11 J B M B I S S e M I K M
0004779
bysieiao iSbl'"'""..
faffi^ x a S e a T S i Xniorvieuo
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*fmn ; T O T e r a T : m m r r :Personnel of n Medlco-legal
aix
m i m l Probloso g Codtosam$tatiioeieG&x* oto)
l'saiooi Sopevv&alon of CHtaa0v**
riaspio^eos &Kag >laat)
ail i&dioal Cervie to cuotaaovo
Co-<--*U coot tasSItas; TU
$14,2^3*00 /4?'y'ki
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sasastin&iicassi
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icrlodlo Dis^aosti 'fasatm&lc^ ;rot Aid * 'rocaal CotsaseX# olld*wp iir e. /<m / Horisnua'tjt COB^oaeatiott and SrOTaraae
iUX ueaXo&x rervi to &%*%% All umi <x& Hed&cax rer?to
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san&i&tion of Use oxooimo associated wiUi ertela i t of Uto i-oas^s
>:s a toot**pryiiit Sosia# 1X2 s m *% m io pirovido a n @ m for
corcai; .0oa of Un cost cC tM ofrre&pmin activity If it 2*0 curled
oii AJ a osasciiteat uoiag hi@ mi facilities asad Ba&lag l.s o m loo
'..iUS w stvapaz& o m t q 33
m w s ^ t m ^ ai t -ate
srz..o
aaioato in tas tabi **fsa aSwsssi $5 5 *0 $' so c g c r p b m a to ttae average
o* akout v27*:T>3 loe ioh olialMrX^ eo333r&osi$Xv s^^ais&tiaias lav
boost csanno, out for na tag? lateSEsaiot. in m v m ^ l parts of tia? oon&ti-v*
:te avoa*ao@cosi or 13?
paricelo tiarysoetio ourvcgf
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t?as a l i t t l e leso than $0*X> vistesi Vaile idoli io aa s'gaaisea
mt vmtaissb'iggroup# ts
esseeeeiv l a v l e v o il tim e Quipsimsfc
aa& st|>o^tao oaXXed apea* cssr figaro for oapara&X sasaimitc^s
olsewuojpe have ranged from $40oo te m a m tas #X#tMi*oo# and vhix
tie lattes* sua* on&ttodljr# io gs-oe^lf ^kcoooivo, s - Mea of tie
i-roblis pn&seated lf* epooiaX eita&ti&
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reasons tiret, 'mmm m ailier SNmfeer of ttoe Medical Department
rm 'm tm expetimt m all ptmmm et ils? saelcal m fiygie&ic ' work of tfcyl orpar*ttett tat m u M ptrov&i a baeis for soaad advice m service to u corporati la U mit oT ils- early retiraaent of the Medical Blreotor. Tl eituatioa oziate boccilo tao Medical Director ma relied upe& il attilttiUiy f Dr. Machie la aergeteyi m lie of taking a and gtvl&g ootapaxabl training.to a yooag&r assistant. Eack of ta ofcter saetabera ef tfc Medical Dapartxaeat 1 sully ccaapoteat te do hia jot> vithia lits o m ares of reepcoaifellitgr, tut nono of usas M s ad e combination of expertee in relation lo nsnufaeturiag pissat, field opemiions m genomi hygicaic practice uac poliosr# Uat vere baili u& issDr* Mchie by yeara of oijarin'ti
osponsibllitiee of &he Medical Director* la situation ean b
rur.ccted, but lise m opportunity hve noi beco affos'ded io do so# us ici. recoud, th Medical Directes.le conrincod timi Xt, la advic&bc -ma alooi acceseity w a t ih pb^oieins of Siiayi Corporation who osai viti* ih public and vita ti acutive, tochnical repreaetxMttIvca and o*hr apleyeea of euetester ecaptttfd* b M bave actual and.
*ocogaued piofssional oosj^tonoct toapeett tsat geaemlly expected of -nduatx lai- piiy&icle&a la th paat o r at prsent. Accord agly a m &
always bollerad timi t&o associate afcou&be engagea in proftoasleoal ly `
oork User tracia t&at e'kdcfc^related io ili# affaire of Athyl Corporslica<
Dr. foeklo*e rapatati ad parof ^ m x a m X m u m s m in th fluid of
oecnpatlonal miaXm * m e&uemse visieh u t aiy parti? i'rm io
a s s o c i t i c s triti* Etiiyl Carper tloo and th JSatte rtag baboratoi??, bu t la derlved lasrgely fresa ia trfc afe Fort Knox dusing th var, and aia -a v e o i lg a t i v e and o o au ltiag a o fc iviti# aine t i s i bin e <* a i e valuable to Ettsyl Corporati* qui ta beyon aay paresmt sua repreamtted Us hi c-csapenstion. If Dr* Maole io to he amiloble# tha coedltiene
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30 *3tto3 mow Sox4<t oil op oq ?TT&*<sojDas Ti^xndoc?
t&&. brios us t suggaet eertaia aXtmnmtlv ta t
liquidation of tlse prasost. asHioal rsgSiaeo i 5m? Storfc, subjcct to
eritiasl mtmiaatiofi la t! s* tirt an acoeptblo polios osa oe
agrced upas far tue eca ils ta cane* $>1 tim not SuOiuAe
aos^Idarutio a* till ctne*- posibllitlos
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i. la visu at the oreGD3&g discussion# tfj decision. crf
tae uanactfacat laoy b tut tiw pfesmt progsoet la aatlftfaatar? la
coneepi arxi .;-3?noipX* but tint Its coai sboui ou s;usd a ssuefo
a raa uc la&uible Il m m M se Uaat tais oouM b aaoyssplisbaJ
:>ral;; aus rduction la te uggrc&ato os* lw.ividu&i ou&asrlm al' Usa
.apotclassa xi ms boea rooooBeaed i-&mnlly tat partiis cnbora
cl i tsoatuai ciaiTi Pc? exas'104 as tk&lcal consultants . xf txix
rcKS-a^onoutlon es pprovea lt mil!mai, te aalPa to rovlmr ti
ctatio? ioes cl ail '.-.uon consultants in lla viui u:.e mieux cl u
cor -loess voce arc auXled upa aa rcpU*e "a cive* !:c* laciiio cor
artslOs mpet. 1 aclcod xiopslp :.-.:caxorviee tiuo acmuml acui,1.tl.ec
*-v .lu ascooiatos ursdl to aat a coasultaiit ta ontte? mcolum;;
;aacouer oorspunies a& noioc^l^i^aX ocmsiamiiaoxu
t Xt m&' ic; tiiat sLue 23aaa;*o8aet or iho scrutin la
.-rapared ;.o cet a sua boyond t?.ia& iis coci oX' tiso law lora ;uePlc>ul
actlvitlcs in not to o* itp conl 1# a roiau aussi# or a proportion
it* ovcr-aXl aodloul coete tioceluoive of reooarcis^ or# puri-aps# a
o<:nodule af nifc conta* timrab# ia tlsa Xattor caaaj usafeias allotrua.ee
lor u& cmiiMmloa of total oost Xa pro;poa?iioa to tha use mo
;c trie ecrvlco* tt'il.i t/ouid leavo tix* oisaracter oi tu ^;euioal-~
v-.ervico to tio jupoat of tX:iO vl30# %?e boliovo, are bast rs?e^-Oi.
x-.v truiafx ursci pipetlesc# to atim&lm vat it zz^mM bo
. p. Dr* i-laoble aad M s ascooiate mig&t eoi>arato r^xcmolvce
ontiroip freo laoicsl es^antsatioa of EtJgri worporatisa* aad#
^- 0004786
\ Ip*
after fcieiag over t im pveoent m &oaL facilities &y callable
fin&ael&X armgeenat' ith tfce ceypeeratiao# w oig&t fias ..u t>ocoi-
ble to provide oeie&l service of ti ly^e mlvts ty the 2os*par&ton
on a feo-foi*servie rele Dec&uso of the professional reXati2aehi>
loteen ouroalvoo ao Pr* acrsl, tMs eorvioo coula oc carsica out
uith certain auvantago to tao Corporation and
f e w nandieaus
firm >?oultl obtain if other pir&tclai uere to bo engaged in this
KE" 0004787