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`oCTOB3 12-14, 1950 CONTENTS MAX 2 41974 ,, CENTER LlBRARV^j judication TEE NEED FOR TEAMWORK IN INDUSTRIAL HEALTH1* i KISF7SR DAVIS, M. D. TEAMWORK IN INDUSTRIAL HYGIENE" CLYDE M. BERRY Ph. D. THE ENGINEER IN INDUSTRIAL HEALTH" JOSEPH E, FLANAGAN HEALTH AND MANPOWER IN PEACE OR WAR" BRIGADIER GENERAL JAMES STEVENS SIMMONS U. S. ARMY (RETIRED) DEAN, HARVARD SCHOOL OF PUBLIC HEALTH ..THE PLACEMENT OF THE PHYSICALLY HANDICAPPED IN INDUSTRY" T. M. FRANK, M. D. 10 QUESTIONS AND ANSWERS HARDY A. KEMP, M. D. 10 QUESTIONS AND ANSWERS C. U. DERNEHL, M.D. ATMOSPHERIC CONTAMINATION AND INDUSTRIAL WASTES SYMPOSIUM" JOSEPH B, FLANAGAN l*A PHOGRAM FOR INTER-INDUSTRY COOPERATION" A* J ZRELL : INDUSTRIAL WASTES AND STREAM POLLUTION SYMPOSIUM - "GENERAL TRENDS [EEGARDING INDUSTRIAL WASTES AND STATE LEGISLATION IN THE NATION" 13 18 21 25 28 33 39 - jjidOSTRaT?EXbPbECoTsS bFRuOiMwTaHsEtess-tate REGULATOHRY? wHJromnDn raw 18,1 HAYDEN W. HEAD ivSAT IN]3UStKJ S^C'^L^ROM THE state regulatory bureau IN THE 'J^OIIJNQ OF INDUSTRIAL WASTES" H. B. EAttBION ^OLLINIDSUSUTR0Y?EXINPDECUTSSTRFIRAOLMWTAHSETESST"ATE REGULAIOBY BBUtrRaTEfAAUn IrNn TirHTMB G- H. HERZII, JR,, C.J. l9jO REGISTRATION LIST * 46 51 55 59 "TEAMWORK 15 I5BJSTRIAL HIOIEM* Clyde M, Berry, Ph. D. Industrial Hygiene Engineer Medical Department Esso Standard Oil Company Sew York City October 12 If *9 consider the objective of industrial hygiene in the positive sense, having optijujn health among the gainfully employed ae its goal, then it becomes quickly apparent that oe single individual is able, by training or experience, to anticipate and proride an idealized working environment. It require* the combined efforts of many in jactly the way that the ball carrier in a football game is dependent on the inte grated efforts of ten other player* if.the game is to have a successful outcome based oQ their objectives* Although I have listed that number, the industrial hygiene team ^ more than eleven players* Ae in football, there is no plaee on the team for the prioa donna, the spotlight stealert each oust be imbued with the concept of service which precludes selfish aggrandisement* Management* The most important man on the team is management too frequently this is ignored* If any hazards exist in an industrial process, management la morally and financially responsible for the correction of that hazard. In a com petitive economy, an enlightened and foresighted management realizes that a high maintenance level is ae important for the human machine ae it is for a mechanlaal machine. All of us are familiar with the types of dividends accruing to manage ment as a result of their participation on the team other than the elimination of occupational disease - more and better production, better employee relations, and others. Management is in a position to provide a spot in the organization of the company that will go far in making an industrial health program successful. Wherever it is placed it should be in a position to cut across organizational lines in carry* ing out its work. Management will be disappointed in any program that Is set up to provide a scape-goat or whipping boy that can be blamed if things go wrong. They will be disappointed if they wish to prove that they and their Industry are not culpable without getting all the facts and letting then speak for themselves. They will be disappointed if they are simply trying to be in style and they feel that they are constrained to keep up with the industrial Joneses* 2. Employees. Any program aimed at the proteotion and improvement of the health of the employee* can only succeed if it has the full and complete cooperation of the employees*. They should be apprized of the need for any action taken in their be half so that they can cooperate intelligently* In order to seeure hie confidence and cooperation* every evidence should be provided the employee that the indue* trial health program is operating without biae* This means the development of rapport between the personnel carrying out a program and the people for whom it Is planned* The physician will not have the eonfidenee of the individual employee if that employee feele that any confidence! will be violated or that he may be sub sequently penalised or restricted* The work of the industrial hygienist will be viewed with suspicion if he Investigates only complaints and then finds them nega tive without exception, or if he is brusque or curt with the worker* Behind the machine it a man and he must be treated ae one* 4 Medical Department* The Medical Department, the physicians, the narses, the ^cbnicians, the first-aiders, all are on the team* How would a problem he lo cated if it were not for the physical manifestations found by the Medical Depart ment? How would or could it be developed without their records and perhaps spe cial examinations? After controls have been initiated, a clinical fcllow-up is Bacessary for the final assaying of their effectiveness. The Medical Department will be of infinite help if their advice and guidance are sought wherever such might be helpful. It, Chemist. The services of the chemist are indispensable in the appraisal of the working environment. He must be capable, alert and honest. Far reaching de cisions that affect the lives of his fellow employees and the economy of the coin pany for which he works will be made on the basis of his results. His is not the place for a cook-book chemist. The chemist responsible for Industrial hygiene analyses must be alert to unusual factors or conditions which may affect his re sults. He must check his work all the way, from the calibration of his equipment to the analyses of test samples duplicating the actual sample as closely as pos sible. Much of his work will be micro chemical and he must be careful and accu rate. His professional honesty must be unimpeachable. The Safety Department. The Safety Department is certainly on the team. Safety men know the plant operations and the personnel associated with them. They pro ride continuous coverage and thus augment the eyes and ears of the industrial hygienist. The safety man is alert to the possibility of hazardous exposure and can thus help in Identifying health hazards before they have produced disability. The Safety Department is responsible for the repair, sterilization, and icsuanco of protective equipment. The department distributes such items as goggles, face shields, shoes and other personal protective devices. The latter function places the Safety Department in an ideal poeitlon to administer permit systems wherever those are desirable or necessary for protection of workers. 6. Governmental Health Agencies. Have you ever stopped to think what the local health department does in keeping the employee healthy. They insure the safety of the water and milk supply, both of which are consumed on the premises of the plant. They insure that food consumed in a nearby restaurant or the box lunch purchased just outside the gate has been prepared and kept hygienically. The im munizations provided for the family of the worker protect their health and make him a better, more efficient worker than he would be if members of hie family were ill. There are many others. Perhaps the local health department is not prepared to give advice and consults?* tion in the field of Industrial health. Should this be true, this service is available from nearly every State Health Department. For the small plant they r can provide free services that would otherwise be Inaccessible to the employee. Vith the larger plant they will be able to offer proven solutions to comparable problems, problems that they have seen solved successfully by other plants. Any complaints of workers will come to them and much embarrassment will be saved by all concerned if they are apprized of a known health problem, told of the protec tive program contemplated, and asked for their comments and suggestions. After all, two heads are better than one. 7, Technical Service Department. The department that maintains technical surveil lance of the whole process, by whatever name it is called, is eminently qualified 5 to discuss any problem involving health# They know, or can find out, why a cer tain is carried out in a particular manner, or with the use of specific equipasat. Any proposed solution to a problem should invariably be hr-ught to their attention* They may be able to think of a better or a cheaper way of solv- jng the problem. They have, or can get, the information needed to strike a mate rial balance from vhich one can determine lossee, their amounts their loca tions# gnfllneering Department, The planning and design group are able to design health protection into a process, better and more cheaply than can be applied at a is ter date* If they have been educated to their responsibility in the protection of the health of the worker they will recognise the need for such protection at an early date or will discusB a proposed installation with someone able to antici pate such a need. A pre-blueprint discussion may be more valuable than many, many subsequent conferences* The Engineering Department, properly oriented, will thus bring to the industrial hygienist for review those plane that are pertinent to industrial health* industrial Hygienists in Other Companies. Almost every problem encountered has been met and solved, at least analogously, by some other industry# The free in terchange of industrial hygiene information between members of this profession is always desirable. Professional ethics forbid the transmission of irrelevant in dustrial know-how in such contacts* The exchange of industrial hygiene informa tion, in addition to being directly helpful in the solution of a problem, may stimulate the study of a problem not yet acute or perhaps not even suspected. Such industrial hygiene personnel may be found in governmental ageneies, in edu cational Institutions, in companies from vhich materials are bought, and in com panies to which materials are sold, in insurance companies and, most helpful of all, in competing companies. These people may not be on your payroll but they are on your team. Other Professional Personnel. The technical sales group within your own company can be very helpful in determining a known or suspected hazard in perspective, They know where company products are going, in what quantities, and for what use. It is thus possible to add the experience of the consumer to that of the producer in the study of a problem. The makers of personal protective equipment can be helpful in the exchange of information# So can the manufacturers of processing equipment or the manufacturers of special control equipment, such as ventilation systems, dust and fume control systems, or other similar devices* The toxicolo gist, the physicist, the bacteriologist, all these and more are capable of help ing the team. Let us not forget the secretary who finds those few minutes in the busy day of her boss so that you can see him and present your case personal ly and without delay. The Induatrihl Brglenlst* This is not the place nor do we have time to outline the duties of the industrial hygienist. Irom the environmental standpoint, his is the counterpart of the preventive medical approach. It is anticipated that his versatility may bring him in contact with all of the team members described above. His contribution will be as a coordinator such that the contributions of the other participating professions will be used most effectively* Ho concern need be felt over the possibility that there is an overlapping of ac tivities. The purpose of a roof is to keep the rain out of the house and it is 6 expected that the shingles will overlap. It is logical aad necessary to insure tbo beBt coverage. In no aenee should there he competition between the varioua jjemhera of the team - to prevent harm from coming to the employee by providing jjja with a safe and healthful place in which to work. BIOGRAPHY Clyde M.Berry Born - June 18, 1913. Education. - Elementary School, Posey, Illinois. Grad. 1925. " High School, Carlyle, Illinois. Grad, 1929 McXendree College, Lebanon, Illinois; Grad. 1933 - B. S. University of Illinois, Urbena, Illinois, Grad, 1936 - M. S. University of Iowa, Iowa City, Iowa. M-S 19^0 Ph.D. ljfcl Professional Experience 19^1-^3 - On loan to the Division of Industrial Hygiene, H. C. State Health Department by the Public Health Service, Raleigh, N. C. 1943-h6 - Washington, D.C. making industrial hygiene surveys of munitions plants and special industries. 19^6-^8 - Chief Engineering Section, Industrial Hygiene Division, Public Health Service, Washington, D.C. 1943. - Industrial fygienist, Esso Standard Oil Company, Hew York City, oCa "THE EHGIHEES IH ISDtJSTBXAL HEALTH" Joseph E. Planegas Senior Sanitary Engineer Chief Cooperative Health Service Branch Division of Industrial Hygiene Dhited States Public Health Service Washington, D. C. October 12 . any discussion of the need for teamwork in industrial health, I believe that ve gtl0Uld sake clear at the outset that industrial health means teamwork, I think there danger of selling short its importance if ve speak of the "need", as though teamvork Is an abstraction and not necessarily an Inherent quality of the operation. It i# true, of course, that teamwork will- enhance the performance of ang activity. It can act as a catalyst---speeding the action--or it can bring about more fruitful as veil as harmonious results. Thus, with perhaps few exceptions, all operations have , lB common the desirability of teamwork. In the case of industrial health programs, However, the situation is entirely different, for ours is not an activity in which teamwork is merely to be desired. In all industrial health programs--whether they gfe conducted by the Federal, State, or local governments or by private industry^teamwork is the very keystone. To illustrate this premise, I should like to tell you about our work in the Division of Industrial Hygiene of the TJ. S. Public Health Service. 10 begin with, our organisational structure ie built on a foundation of teamwork. The various professional categoriea in the Division do not function as separate, totally disjointed, administrative entities. In other words, we do not have separate pro fessional groupings--like a medical section, dermotoiogical section, engineering sec tion, laboratory section, and so on. Bather, there ie a functional grouping of per sonnel. Thus, medical personnel, including physicians, dermatologists, and dentists, are considered part of the Clinical Investigations Branch of. the Division. Ihey are concerned with the personal health of the worker, as contrasted with the engineers, physidBts, chemists, and toxicologists who are part of the Environmental Investiga tions Branch. Auxiliary personnel, such as analysts, statisticians, and information apecialists, serving the Division as a whole or doing States relations work, are grouped in the Cooperative Health Services Branch* This functional alignment of per sonnel, we have found, permits the most effective teamwork approach to industrial hygiene problems. Sot only does the teamwork motif make for better administration, but in the field study it also becomes a vital, living factor which is apparent to all. Field studies are planned and executed with the closest amount of cooperation between the clinical and environmental teams. Bien equally exacting cooperative work is required when the findings are correlated and analysed in a complete repoTt* Without such correlation, reports of investigations would present limited facets of a problem and could not pretend to be as conclusive as possible. It la the correlation--made possible through the teamwork operation--that gives real meaning to the survey. Ibis teamworlf bp^h unilateral and bilateral. Here it hew it woks, for example, In the medicpl team, in the conduct of regular routine* The industrial hygiene phy sician's role in a study is to make a physical examination of the worker exposed to potential health hasard* and to take an occupational history to determine if there 8 $gt9 'been any prior exposures to hazardous substances* At the sane time, the Indus-- hygiene dentist determines if there are any oral manifestations of occupational disease. If there are evidences of unusual dermatitis, dermatologists from the Divi sion may he called upon for specialized assistance. All phases of the physical exsuination are closely wrapped together, since what one examination will not reveal gjgy he brought to light by another. As a case in point, the medical examination may feveal no unusual symptoms; but, since the oral structure often is a sensitive indi cator of trouble before it appears elsewhere in the body, the oral examination may pie the first clue that a worker is being exposed to harmful substances on his Job* cite this as an example of the fine lengths to which cooperation must extend within the working of each individual group, finally, the clinical findings must be- Corre cted with the findings of the engineers and chemists, who have taken and analyzed samples of potentially dangerous gasea, fumes, dusts, or other substances in the worklag environment to determine their concentrations and toxicity* ijd indicate a little further the teamwork nature of industrial health operations, I should like to point out how complicated--and often barren--the work of the indus trial hygiene physician and the industrial hygiene engineer can be if there is not close cooperation. For example, in differential diagnosis of occupational disease, the physician must know the patient's exposure to any hazardous conditions before he can make a definite diagnosis. Often, several diseases may present identical or similar symptoms, and for this reason information on potentially hazardous occupa tional exposure is absolutely essential* Thus, the engineer, with detailed knowledge 9f the industrial operations and the concentrations of contaminants in the working atmosphere, plus a general knowledge of the toxicity of these substances, may help to provide the answer to a medical problem* Conversely, the physician, by making his specialized knowledge available to the environmental investigators, may help in the solution of an engineering or toxicological problem. In fact, the working relation* ship is so close that, after many years of experience, engineers may learn quite a bit about Industrial medicine, while the physicians become conversant with environsental conditions* The operations that I have described revolve about the traditional medieal and engl* nearing teams. However, if a study warrants the Inclusion of other specialized personnel, the Division of Industrial hygiene does not hesitate to bring them into the investigation. In our Donora smog study, for example, in addition to industrial hygiene physicians, dentists, nurses, engineers, chemists, toxieologists, statisti cians, and information specialists, we also drew upon Public Health Service veterina rians, sanitary engineers, and housing inspectors, as well as calling upon the U* S. Yeather Bureau for meteorologists. The close cooperation of the various groups was excellent, and 1 think that this study will go down as a complex inter-professional teamwork classic. Also notable in the Donora study was the degree of cooperation with the Pennsylvania State Health Department, the United Steelworkers of America, CIO, which has a local union in Donora, the Donora Borough Council, the industrial plants concerned, and ther groups. This type of inter-and extra-agency cooperation, however, was not pe culiar to the Bmog investigation, for it is employed in moat of the Division*s tulles. For example, in the study of health hazards associated with the mining and silling of uranium, which we are presently conducting in the Colorado plateau, the Public Health Service personnel are working with the State Departments of Health of Utah, Colorado, Hew Mexico, and Arizona, the Haval Badiological Defense Laboratory San Francisco, the National Bureau of Standards in Washington, and the Los Alamoe Installation of the Atoaio Energy Commission* 9 j0 all of these activities, of course, the industrial hygienist is the pivotal figure, ggd. other technical personnel are brought into the study as they are needed* Since ja this discussion 1 have been asked to talk chiefly about the engineer's role in industrial hygiene, I think it might be well at this point to attempt to clarify just bat is meant by an industrial hygiene engineer. p the engineers attending this conference know, there is no standard four-year coursf in industrial hygiene engineering* Thus, the industrial hygiene engineer is not the product of a traditional professional course* Ee has usually taken his professional degree in sanitary, mechanical, or chemical engineering, or in a related field, and may have supplemented his education with graduate industrial hygiene courses which sre offered by several universities. Or he may have received the additional training yliile working on an industrial hygiene job* Industrial hygiene engineers, in the full sense of the word, are found in governmental industrial hygiene agencies and in some of the larger industries* The latter instances are comparatively few, however, because most industries do not yet feel it necessary to employ a specialized industrial hygiene engineer, ae such, but rely on the plant engineers to keep the working environmental free of hazardous exposures, in addition to their regular duties* Whenever these plant engineers need specialized assistance to control such conditions as excessive concentrations of fumes, dusts, gases, mists, and vapors; exposures to very high humidity; exposures to harmful enounts of radiation; exposures to noiee; inadequate illumination; and unnecessary fatigue, the services of industrial hygiene engineers in official State agencies are available. The Public Health Service, in turn, is available to assist the State* whenever called upon. The extent to which State engineering personnel can assist industry is determined many times by the professional engineer registration act of that particular State* In all cases, however, the engineer can study the conditions in the plant--taking samples or making other tests with his instruments--and then recommend any needed control measures, such as exhaust ventilation, isolation of dangerous processes, sub stitution of less hazardous materials, and use of protective devices* Since State regulations may prohibit official State agencies from engaging in the practice of engineering in competition with private consulting firms, the State industrial hygiene engineer may not be permitted to design the needed control devices for the industrial plant. The plant must then call upon the services of consulting engineers, who usually have heating and ventilating backgrounds, to carry out the recommendations of the industrial hygiene engineer* Tery often, the consulting engineers are highly qualified to do the usual design job vhlch occurs in the heating and ventilating field, but mny times they are sadly lacking in technical knowhow for the control of atmospheric contaminants* Ihey frequently make the mistake of just throwing in control equipment without appli cation of the principles related to the industrial hygiene problem* Hence, there is a needless waste of money by industry--and, even more serious, a false sense of secur ity develops through the belief that proper controls have been installed* When the awakening comes--when employees begin to complain or to get sick--the industry calls in the State industrial hygiene engineer, who must then point out tho fallacy of the design. Industry is thus confronted with the necessity of revamping the old instal lations or removing them entirely and putting in new costly control devices. It all , adds up to duplicate expenditures in terms of money and manpower, and it does not make for good public relations for the engineering profession ae a whole* 10 fb lesson to be drawn from such experiences, I believe, is clear. There must be closer cooperation--teamwork--between the official industrial hygiene engineer, the plant engineer, the heating and ventilating engineer, and the construction and coa~ 'suiting engineer, and the architectural engineer. Nor can the channeling of inforcation be one-sided, for the plant and other engineers can help the industrial hygiene engineer by calling certain peculiarities of the operation to his attention. There cust be a two-way flow of information, predicated upon close observation of the worfc' ing environment. Since, somewhere along the line, all engineering activities impinge on the industrial hygiene field, it behooves engineering personnel to familiarize themselves with the principles of the control of the working environment. The State industrial hygiene agency, I am sure, will be more than glad to give the necessary indoctrination. In industry, which uses a financial yardstick as one measure of success, an industrial hygiene conditioning of plant engineers would greatly enhance their value to the firm. In official governmental work, where public service is the criterion, the engineer who is engaged in other than industrial hygiene work also has a moral obligation to acquaint himself with this important activity. In many States, for example,sanitary engineers greatly outnumber industrial hygiene engineers, and the success of indus: trial hygiene programs in those areas may be largely dependent on the interest mani fested by sanitation personnel. Finally, all professional personnel--regardless of > their position--must remember that their professional status cloak3 them with a rej sponsibility not usually found in the 9 to 5 worker. They must continue to grow--to idevelop their talents and abilities to the utmost--to make their greatest possible I contribution. If they are true to their responsibility, their interests should ;broaden beyond their individual specialities. In the case of engineers, if they are conscientious followers of their profession, their interests cannot help but embrace Industrial hygiene, and I would venture to say that any engineer can undergo Indus* trial hygiene conditioning to good advantage. So much for broad inter-professional cooperation. Now I should like to touch upon the engineer who wishes to make industrial hygiene his specialty. What are the qualifications that he must have? First of all, education-wise, as I have mentioned before, there are graduate courses available to him in a number of universities. This education must be supplemented by extensive in-plant experience. Second, he must realize that in industrial hygiene activities the human factor is equally important t as technical competence and get along with people is an he must obvious discipline himself accordingly. asset in any walk of life, but, The as 1 ability to have emphar* I sized previously, because of the teamwork required in industrial hygiene, it is a ! prime necessity for the industrial hygienist. He must also have an open and inquisi tive mind and a searching intelligence. Since he will be called upon often to improve testing methods to design apparatus, or to devise new control procedures, he must have imagination and ingenuity. Furthermore, he must have a deeply ingrained desire to learn. In this connection, many of the State health departments are to be congrat ulated for making educational opportunities available to qualified engineering peiv i sonne1 and for encouraging attendance at professional meetings. In the constant proa- ess of learning, the industrial hygienist must also build up his professional library subscribe to professional Journals and follow the progress made in his own and related fields. Finally, he must have the capacity for cooperation, for the extent to which be, as a representative of his organization, invitee or repels cooperation will de termine his success in his field. In short, he must sell himself. 11 cgU8e of the scope of this discussion, I have stressed cooperation within the engi neries profession, hut I should like to make clear that teamwork possibilities are er ending* They transcend any one profession--even extending beyond the walls of a. working environment, for in its broader concept industrial health concerns itself the health of the "total man" 24 hours a day* not only the 8 hours that he \>ends on the job. Cooperation thus also takes the form of working actively with ^Ite and local health departments on public health programs, with community health 5 j welfare agencies, and with labor and management groups in the betterment of the immunity as well as working environment and in the achievement of total health, And Chen general or total health is concerned, there is Just no question of cooperation, *Qfi as has been repeated many times, health is everybody's business! BIOGRAPHICAL SKETCH Joseph E. Flanagan, Jr* Born - Worcester, Massachusetts Education - Public Schools, and Worcester Polytechinc Institute Received 3.S. Degree in Chemical Engineering - 1935. Experience -- 1935-1940, Massachusetts Department of Public Health 1940 to Present -- U. S. Public Health Service Assignments with Public Health Service 1940- 1941 - Stream pollution and industrial waste investigations Cincinnati, Ohio. 1941- 1943 - Industrial Hygiene Engineer engaged in investigations of arsenals producing munitions of war throughout the United States. 1943-1946 - Assigned to Ohio Department of Health as Industrial Hygiene Engineer.' 1946-1948 - Industrial Hygiene District Consultant, District 3. Chicago, Illinois. 1948-1950 - Chief, Cooperative Health Service Branch, Division of Industrial Hygiene, Washington, &C. 0O0 12 INDUSTRIAL HEALTH CONFERENCE BANQUET P. P. Butler, Presiding "HEALTH AND MANFOWEB IN PEACE OB WAS* Brigadier General James Stevens Simmons U.S. Army (Betired) Dean, Harvard School of Public Health Boston, Massachusetts October 12 H is a special pleasure for me to be back in Texas tonight to attend the Oiird Gulf Coast Regional Conference on Industrial Health. 1 say "back in Texas" because X feel very ouch at home here. I was reared in another great state, North Carolina, but some of the happiest years of oy life have been spent in the Lone Star State. A# i recalled here a year ago at your Second Conference which I had the privilege of attending, oy Army career in Preventive Medicine and Public Health started is Texas. I began prospecting for health as a First Lieutenant at Fort Bliss In 1917. That ,a8 my first Army station, and my second was at Tort Sao Houston as Commanding Of ficer of the Southern Department Laboratories. Aod so, though oy boyhood memories go back to North Carolina, I shall always hold in deep regard this spacious, friendly, enthusiastic, pioneering State of Texas where 1 got my start in a profession that, for me, hae never ceased to be exciting and worthwhile, I have alwaye admired the adventurous spirit and the courage of Texans. I remember hearing of a party of Texans who went bear hunting in the mountains. One of the group got separated from the rest. After searching all day and all night, .hie . friends found what was left of him, lying under the 300-pound carcass of a very dead bear. It was a dreadful sight. It was plain that he had come upon the bear unexpectedly* 1 quick shot had wounded and infuriated the beast and then the gun jammed. The man wee forced to fight with a knife. He finally killed the bear, but not before the inimal had torn off one of the poor man's arms, clawed the scalp from hie head,ohlith irsted his features, broken his back and both lege and inflicted terrible gashes *11 wer his body. Finally, the brute had fallen on top of the man, crushing the rib cage and obviously causing internal injuries. Is horrified huatere managed to lift aside the bear's heavy body and sorrowfully picked up the pieces, of their friend, mangled as he was almost beyond recognition* ii they were stumbling along the trail, they were astounded to hear a faint moan. Sould it be he was still alive? They stopped. One hunter leaned down to the unfor tunate victim and asked unbelievingly! *3111, old man. Can you talkt hlntly they heard that Texan gaept ^--* I am all right. It Just harta a little whan T 13 $o*t that's the kind of Texas spirit that the world respects lfce Texas, Public Health is young. It is a vigorous, pioneering profession. In receat years it has branched off as a specialty of the much older medical profession. Traditionally, the mission of Curative Medicine is to heal the sick. Everyone recog- 0izes the necessity and importance of medical cars; but the Public Health Profession goes beyond this and has the preventive ala of keening well people well. It preaches jgd practices the ancient truth that "an ounce of prevention is worth a pound of - cure." It works to conserve American health and American manpower--manpower for agricttltural production and for business, manpower for our schools, professions and for every civilian occupation, and manpower for our military forces. In short. Public gealth conserves health and manpower for America in peace and in war. This is the gubject of my discussion tonight. It i0 to know that this great objective of health conservation ia recognized gere in Texas and that industrial, civic and professional leader# are taking long eteps toward its attainment through such means as this splendid Conference. I am glad to have this opportunity to Join in your discussion, along with some of my eoll00^60 from The Harvard School of Public Health* Dr. Bobert 'Conner, Assistant professor of Industrial Medicine in our School and Medical Director of the Hew Eng land Division, Loss Prevsntion Department of the Liberty Mutual Insurance Company, la an expert in industrial health organization. Be appeared on today's program ar.d vlll take further part tomorrow and Saturday, from our Department of Physiology cooes Dr. Stanley Sarnoff, who is co-inventor of the Electro-Phrenic Respirator which it a godsend in certain dangerous cases of bulbar infantile paralysis. Ur, Sarnoff will address your luncheon session tomorrow and demonstrate the respirator on a human subject. This le sot his first visit to Texas, During the polio epidem ic a few months ago, he and Dr. Whittenberger from our School responded to an emer gency call and flew to Dallas to confer with Texas Ihysioians and to help in the treatment of a number of desperate bulbar polio oases. Tomorrow noon Dr. Sarnoff vlll tell a unique and thrilling story of developments in research on various aspects of respiration. His story is based on research at The Harvard School of Fublio Health vhere the iron lung was invented by Professor Philip Drinker and where great strides* ha7e been made in developing methods foe purifying the air in Industrial plants and comnunitisa. Last year at your Industrial Health Conference Z spoke as the Dean of a civilian Echoo of Public Health and discussed the importance to both management "<* labor of provid ing good industrial health for civilians in peace time. Now a war is on I am hare tonight as an old soldier. Drawing on oy background of 30 years * service, including experience as Chief of Army Preventive-Medicine daring World Var II, and my prew- st participation la national planning, I should like to talk about the urgent heed for better health in order to conserve both military and civilian manpower. As need for manpower never lessens, Ve may admire the technological advances that tave produced modern industrial machinery and the marvelous military weapons of today* fet ws still need manpower to run the machines* And one- fighting factor which has tot changed since the day of the caveman is the need for manpower to operate the intrnments of war. The Second World War was no exception to the general truth that the 14 protection of the health of troops is an essential part of any well-planned military operation* (jbis has been strikingly demonstrated in Korea* From the start of this hloody war, It wee evident that more than super-armaments would he needed to stop the aggressors, jt took raw manpower. Furthermore, it took strong and healthy manpower. fj0 a public health specialist, no Korean war broadcast was more astounding than the erroneous announcement that North Korean troops had been attacked by yellow fever. Yellow fever has never existed in Asia, and if this report had been correct it would bave meant a recent introduction of the disease. But our troops would have been 9afe because they had been lnnoculated against yellow fever. This is an example of tbe ounce of prevention which pays off in terms of G.I. health. Superior health protection for American military manpower can Jielp turn the tide of this war which la being fought to establish a free world. pablic Health--which is the application of modern prevention medicine to large groups 0f people with the objective of keeping well people well--paid off during World War 11, In the Spanish American War, 13 American soldiers died of disease to every one Killed in battle. In the First World War the ratio was 1 to 1. As midcentury spproached, public health knowledge and techniques had Improved to such an extent and vere so effectively applied that, in the European Theater of World War II, only one soldier died of disease to 65 killed in battle. I clear picture of the progress made is afforded by the rates of disease deaths in these three wars. In the Spanish American War the rate was 25 per 1000 per annum. In World War I it was 16, and in World War II it was only 0.6. Experts in all fields of Public Health--both military and civiliaft--were utilised in operating the giant military health program of World War II. Without it, our troops could not have been shipped overseas--much lest fight there. It vqp a vital factor In winning that war--and it is Just as Important now. In peace or war, this matter of American health and manpower is not Just something nice we'd like to have. It's a necessity--and we*ve got to have ltl We must have health, Just as we must have tanka, airplanes, ships, guns and bomba. Indeed, of all these weapons against the enemies that now threaten our democratic way of life, the nost essential weapon--and the single weapon without which we are lost--in manpnwar. Health and manpower must be maintained to keep our nation strong both on the home and the fighting'fronts. Strong Communist forces are at work in this country and throughout the world, taking advantage of sick and impoverished people, exploiting their discontent and hopeless ness to undermine their political belief. Health ie one of the safeguards against this propaganda. Health is not charity, it la not missionary work, it is not merely good business--it is sheer self-preservation lor us and for the way of life which we regard aa decent. Rurough health we can expand industrial production, strengthen our military forces and maintain the high morale of all our people. Through it ws can prove, to ourselves uul to the world, the wholesomeness and rightness of democracy. Through health we can defeat the evil threat of communism. 15 reover, we of this country are in a position to forward the cause of democracy out446 our own borders by promoting industrial and community health in other countries w01bef we hare influence, especially in the underdeveloped regions of the world. It Is gratifying to know that our American industrial leaders are aware of this oppor tunity and responsibility. xt December, medical and health directors and members of management of 20 or more iLrieen industries with extensive operations in tropical areas - Latin America, the Near East and the Par East - are going to meet for three days at The o'yyard School of Public Health in Boston. There they will be able to exchange in formation and, hopefully, work out solutions for some of the fundamental health jfoblema which confront every industry employing natives in an underdeveloped region, together, with members of our faculty of The Harvard School of Public Health, they rill consider matters of Communicable Diseases and their Control, Nutrition, Organitation of Health and Medical Service and other subjects vital to them and to the people who work for them. w School is proud to sponsor this Conference, We are confident that much good will COB* of it. ja recent months, as President of the Association of Schools of Public Health, I have leen concerned over the mounting need for high level planning on a vast scale to train the health specialists needed for our armed forces and for our civilian popu lation in the current emergency. As spokesman for the country>a ten post-graduate Schools of Public Health, I have urged the President of the United States and the Congress to take action at once to provide this training and develop a program which will conserve the nation's health and manpower* As & member of the Armed Porces Medical Advisory Committee to the Secretary of De fease, I have been attending sessions in Washington which should further this neces sary planning. It is hoped that these plans will provide accurate estimates of the number of public health specialists required for the future; will enable us to re cruit adequate medical personnel to take the necessary post-graduate training; and will provide adequate financing for the institutions responsible for providing this training. Such sound planning should enable us to avoid the World War II situation in which the supply of specialists was inadequate. This led to competition for the available aedical and health personnel. ill this planning for better health is of great importance to industry. Industry, like our military forces, is a vital factor in maintaining our national strength and security. Industry must not only supply the needs of our peace time economy but must build the weapons and provide the sinews of war. If it is to meet this challenging opportunity for service it too oust participate in this planning for the conservation of American health and manpower. Modern industrial health means more than providing medical care. food industrial medical care is essential, so long as we have sick people and acci4 dents. But the fact must be faced that the highest profit to industry and to the country can come through the prevention of disease and the conservation of health for both management and labor. 16 n Ifgft hospital "bed* will not protect the worker against infection or accidents; and 0f9 insurance will not keep him well. The real payoff is prevention and this re quire* the technics of Public Health in any language. ^ industry, then, Public Health should mean much more than just first aid. It should Besn the elimination of industrial hazards; the protection of workers against indus trial poisons and diseases; accident prevention and safety engineering; sanitation; outritioa; and the education of both management and labor in all aspects of Public gealth. In brief, industry, like the Army, Havy and Air Porces, can increase its effective 's toy a fuller utilization of the accumulated scientific knowledge now available f0r the conservation of health and by using the services of the required trained experts in the professions of medicine and public health. la this talk I have not mentioned the specific health problems of industry or the techniques now available for providing adequate health and medical services. These patters are toeing fully covered by the distinguished experts who are taking part in the rest of the program of the Conference. These speakers are concerned with all aspects of Industrial health--not only with peace time programs tout with the special plans required to guard against the possibility of atomic or biological attack, sabo tage or other disaster situations. Ky main purpose is to urge your serious consideration of the broad problem of provid ing the beet health possible for Americans--end of doing this as a matter of national defense. In closing, I wish to thank the Houston Chamber of Commerce for inviting me to attend this meetidg. Also I wish to congratulate the Chamber and the other organizations sponsoring the Conference for the enlightened attitude and the energizing spirit that motivate this important gathering. You are acting in a positive, patriotic way that sets a pattern of action for the rest of the country. Tinally, I wish to state sy belief that through your work for better Public Health and Preventive Medicine as a method of increasing American industrial manpower, you are in the forefront of our fight against Communism* you are helping to forge the moat powerful single weapon In the arsenal of democracy*-- the health and strength of the American people. olo usier. Industrial Health Conference Panel W. H. Hamrick, M. D., Moderator "THE PLACEMENT 0? THE PHYSICALLY HANDICAPPED IN INDUSTRY" T. M. Prank, M. D. Medical Director Pan American Refining Corporation Texas City, Texas October 13 What is the employer's reaction to the practice of hiring handicapped persons? prom a doctor's seat on the side lines, it is my impression that most employers favor the idea but unfavorable experiences in individual cases have occurred and these tend to wield a considerable Influence on employers' actions and decisions. 2, What is the attitude of doctors toward hiring handicapped persons? If the handicapped person can be hired on an individual basis, treated as individ uals--that is, without allowing one to become a precedent for the next case, doc tors highly approve the practice. The work assignment must be within the handi capped person's abilities. Transfer to other work must not be made without medi cal approval. Any person who is handicapped has the physical condition to over come, plus the blow to his morale and often this is the greater damage. Anything which helps to restore his self-respect, his regard for himself as a functioning individual, his ego as a unit of our society, is of great help in overcoming his handicap and recovery from this and future illness, 3. What are the advantages in the practice of employing handicapped persons? A handicapped persou who is determined to work and do a good Job, can be a real prize. Certain of them are grateful for the chance to earn a living and if the Job is properly selected to suit the individual, they may do better than a person without a handicap. In some cases the handicap tends to immobilize them nd they stay on the job better, waste lese time in going to the drinking fountain, toilet, and/or visiting. Often they have fewer natural distractions, k. What should be the criteria for refusal to employ handicapped individuals? When there is no work available which they could do without danger of: 1. Injuring themselves 2. Injuring other personnel 3. Injuring equipment 5. What is the biggest difficulty encountered in employment of the handicapped? As a personal opinion, I believe this is the present tendency to standardization. Our constitution; our laws in general; our labor laws in particular; our union 18 contracts are 'baaed on the assumption that we are all equal. Ve point to the De claration of Independence for support. Eowerer. it says ve are born equal and actually that is merely a point of departure* (I personally believe ve are born with equal rights but not equal.) Ve do not stay equal after ve are born. And ^ is a rare lav, or tariff, or rule, that fits every one with equal acceptability. As a doctor I have learned that ve humane are very much individualists. A l/4 gr. dose of morphine will put most people to sleep in spite of pain, but I know some people who become nauseated, irritable, and hyperactive with the same dose. Just as it is true of medicines, so is it true of diseases. The invasion of the body by a given type of germs will bring about one result in one case, and a very dif ferent result in another. Treatment must be highly individualized. And so it is with handicaps. If we insist on treating the handicapped all alike, w0 will fall. If we treat all persons with the same handicap exactly alike, ve will fail. Each must be accepted on an individual basis or the employment of the handicapped will get a bad local reputation. Precedent must be scrapped. Hot only as to hiring, but it must be acknowledged by all, that the work, care, treat ment of one such person sets no precedent for any other. What are the limits of employability of the handicapped? Whether they can perform the work available. Whether they can work in safety. Whether they will endeanger others. Whether they endanger property. Whether they acquire seniority rights that could enable them to demand to other work for which they are not fitted. 7, Can every industry use handicapped employees? 1. Almost any industry can use a few handicapped employees, depending on what the handicap is and what the work is. 2. Eardly any industry has unlimited capacity to use handicapped employees. 3. The nature of the industry determines how many handicapped persons can be used, also the types of handicaps that matter; e. g., a blind truck driver is not to be considered. Tet a blind person may make a good worker in the dark room tending machinery that makes photographic film. Even bed-ridden persons have been known to turn in a more than creditable performance of certain types of profitable work. 8. What are the obstacles in the way of employment handicapped? Most employers don't know the problems of the handicapped. Educative efforts must he on an individual basis because each employer has different problems. Some efforts in the past have failed to produde all they might, because they were not projected to the employer's view. Some employers are influenced unfavorably by experience to the point where they would like to hire only perfect physical specimens. 19 can one evaluate the degree of the physically handicapped? jbere are many answers. Perhaps the answer nearest the truth Is that only the oQ0 who Is handicapped can evaluate the degree. To take an extreme case, go to a aide how of a hig circus and see the man without arms write on the typewriter (with his toqs, of course). It is easy to dismiss this as a stunt, impractical ln business. But we can't dismiss the fact that, although based on impairment of organ, the degree of handicap is influenced to a major degree by the person's reaction to it. If he succumbs to it, the result is serious. If he uses his ingenuity and determination, he can minimise it to an amazing degree. jvo persons with ankylosis of the hip joint present themselves as prospective em ployees. They have had injuries in some game at school, years before, and each one is unable to move the thigh in relation to the pelvic bone. They state their intention to turn in a good day's work and let the handicap interfere with their work or safety not at all. They are hired. Within three months, one of them reports that in stooping over to pick up some thing he has injured the already injured hip. He indicates that he is holding the company responsible for it and will sue if it is denied. Investigation shows he is presently engaged in a suit against another company on the same allegation. Hie other person remains at work, a valuable employee, with never a complaint about his hip, for several yeara. These two casee illustrate the fact that most handicaps can be a prison cell, or a hurdle, depending on the person involved. 10. Vfhat is meant by the term "physically handicapped"? Different persons use these words with different meaning* Certain handicaps may be obvious, such as the loss of finger, arm, leg, eye. Others are less obvious--heart disease, kidney or liver impairment, tuberculosis, hernia, cancer of various organs, arteriosclerosis, hypertension, syphilis, brain changes, blindness--the list is almost indefinite. Almost every one has something wrong. Most people do not allow it to impair their usefulness, or we wouldn't get much done. And until it interferes, it is hardly fair to call it a handicap, at least from one viewpoint. The opposite of handicap--that is, physical fitness--means nothing until you state the object of the fitness; that is, physically fit for what purpose? A, person physically fit for playing big league baseball at 20 years of age is usually unfit at 35 years of age, but on the other hand, may be quite fit for something else. Similarly, a certain physical handicap may be disastrous to one person and of lit*! tie or no consequence to some one else. One definition of the term "physically handicapped" is that it is the inability to do something one needs or wants to do because of some abnormal condition of the body or its parts. oOo 20 Hard/ A* Hemp, MD. Baylor University,College of Medicine Houston,Texas October 13 j9 a blind person of any possible use to industry? la some industries the blind have been found very valuable in jobs which involve the handling and assembling of small parte* Their production record, as a rule, gas very good and their attendance record exemplary. They need not be segregated, a matter of fact, it has been found that the output of the whole section was increased because those who could see would try to keep up. It is rather generally believed that the person handicapped by an orthopedic injury la a bad risk* Is this true? As far as available statistics show, the opposite seems to be true. For examplef g, N. Anderson states in his monograph, "The Disabled Man and His Vocational Ad justment", published in 1932 in Hew York by the Institute for the Crippled and Disabled, that only 8 out of 4400 men had a second injury over a period of 13 years they were studied. The Office of Vocational-Rehabilitation states that nearly 60 percent of a large number of employees replying to questionnaires found second injuries less fre quent; about 40 percent found them to be the same in frequency. Only 2 percent reported them to be higher* There are many reports of a similar nature* You three men of the panel are M.D*s, Two of you are full-time industrial phy sicians and Dr. Hemp heads a department in a medical college (Baylor) which con cerns itself with industrial medicine* As such you are familiar with placement practices, but where would some of us find at least some of your experience re duced to writing? There are several useful publications. One is "Operations Manual for Placement of the Physically Handicapped. * Its second edition came from the IT. S, Government Printing Office, Washington, D. C. in 1943. It was compiled for the U. 5. Civil Service Commission. Another is "Physical Demands and Capacitlee Analysis" publlst*ed by the Permanente Foundation Hospitals (Oakland and Richmond, California; in May, 1944. These could be supplemented by tha article "Physical Capacity for Work* by Harvey and Luongo, which appeared in "Occupational Medicine" in 1946, Vol. I, pages 1-4?, Additional references are given in this article* All of this and more may be had from the U. S Office of Vocational Bshabilitatlon, a division of the Federal Security Agency. Obviously, second injuries may be far mora incapacitating and expensive to all con cerned than the first injuries. Since the cost of this second injury is legally imposable on the employer at the time, he is not eager to assume the risk. What about the job seeker signing a waiver? That is legal in a few states but is`generally held to be unfair to the employee since he cannot possibly know to what extent he may be incapacitated by a second injury and in signing a waiver may actually be "signing hie life away" in every sense of the word. 21 / what, if anything, is being done constructively to meet the problem of paying for second injuries if a once-injured man is lucky enough to be hired or if the em ployer is generous enough or socially minded enough to take on such a risk? .jo meet such situations "second injury funds" hare been set up in several states in recent years. Methods of financing differ in almost every case, but tha author ity comes from the Federal Longshoremen's Act. The Division of Labor Standards, pept. of Labor, can furnish all details. Essentially, practically all of the state acts, or WCC rules, provide<that the employer pays only for the last injury as such, whatever it is. Provision is made, however, for the injured employee to be compensated for this combined injury as such, the difference being paid from the fund. ^ As to hiring the blind, what about those who have monocular vision or a defect al most as great? Their greatest problem is the perception of spatial relationships which is correct able only by time and experience. Directly after the loss of one of a good pair of eyes this becomes a most serious handicap. As for the person "almost blind in one eye", it is now believed that binocular stereoscopic acuity is lost when one eye is reduced to 20/400 vision. Formerly 20/200 was regarded as the limit and it may still be regarded as such unless the condition is one of long standing which presumably has allowed the individual time to compensate. Harvey and Luongo found that the productivity of monocular employees compared fa vorably with those who have the use of both eyes. The accident rate of the mo nocular, however, was much higher. These two observers, however, believe this is chargeable more directly to fatigue. 7, How far does the physical examination go toward determining the actual working ca pacities of the handicapped? The examination of the human being to find the work for which he is fitted involves knowledge of a method not yet possessed by medical science: namely, a method of estimating reserve compensation. Again, there are a host of factors, personal and environmental, not necessarily related to physical conditions, which have a great bearing upon physiologic capacity. Fatigue itself will vary with the individual's attitude and this in turn is often influenced by incentive, the discovery of which is not possible with the X-ray, stereoscope, or blood pressure apparatus, or, in fact, any of the tools of our trade. Thus quantitative estimates of working ca pacity are well high impossible whether the job applicant is cot healthy or even is subject to defect or disease. The procedures of physical examination* cannot be used for more than a temporary guide at best. Periodical physiologic and peychologic examinations of the worker and a periodic'appraisal of his Job Is equally, or even more, important than the pre-placement examination. However, this may be and regardless of what system of Job analysis and evaluation of working capacity are used, the most important factor in the problem is the industrial physician ; himself. If is his diagnostic acumen and his knowledge of working conditions in his plant which can possibly be the only valuable determining factors. As to people with impaired hearing, what about those who wear hearing aids? 2ren with the assumption that tha hearing aid has aided ia the correction of per sonal problems where such might exist, the hearing aid itself is by no means a full guarantee of satisfactory performance of work, even though it has been well fitted to meet the individual^ ordinary needs. For example, some users of hear ing aids, whose difficulty lies in the middle ear, may get*along very well under noisy conditions, while others whose hearing defects arise from disease or impair ment of the auditory nerve may be extremely sensitive to noise while wearing their hearing aids. For this reason, they will discard them altogether while working and thus become less productive for many obvious reasons. Almost needless to say, the person who is not sensitive to sound, that is, the individual who is usually called "deaf" may be highly valuable on noisy jobs, since they will cot suffer the serious effects of noise induced exhaustion common among those of good hearing. From a medical standpoint, much depends upon the nature of -their illness, since with a severe disease of the middle ear freq[uently report that they can hear "everything" in a noisy environment, thus are subject to constant irritation which may become intolerable. As for those who are totally deaf, their handicap may be considered severe as far as employment is concerned only when their work calls for a memory of sound patterns developed before losing their hearing. As is generally recognized, there does appear to be some compensation for this lost power and we find among totally deaf persons some highly skilled tradesmen, particularly print ers, engravers, machinists and watchmakers, along with professional people and creative artists of the highest rank. 9, Other than technical publications and medical references are there any non-technieal or non-professional pamphlets or other sources of information dealing with the placement of employees who are known to have a certain amount of a heart disease? The American Heart Association hae issued such a pamphlet. It is, of course, only a very simple and practical guide at best and should not be used to take the place of the services of an industrial physician. The same must be said, again, for the use of professional publications themselves. Ho family can take care of their illnesses with a "doctor book", although a number of people will try. 10. Too many unemployed, physically handicapped persons increase relief rolls and even become a contributing factor in the cause of crime. Too many handicapped and too many accidents among them increase compensation rates because too many WCC's are too prone to make too generous awards to the handicapped persona. Too many per sonnel managers and too many physicians just say, "Find a watchman's job." This is a broad statement of the situation. What is to be done about it? Such a broadly stated problem can only be answered in broad terms such as saying that the socio-economic problems of the handicapped will be solved when 1. (When) each employer will actually take the trouble to segregate a few-- or more than a few--carefully appraised jobs for physically handicapped persons who have been e xaained carefully. 2. (When) each handicapped person is given an opportunity to develop new skills and thuB become more productive both to his employer and himself. 3. (When) compensation boards are a little less inclined to penalize the employer and/or the insurance carrier for disabilities arising from previous conditions; or better still when Second Injury Funds are properly worked into the picture. 23 ^ (When) the etate realize that such of the relief money now going to the unem ployed, physically handicapped person could, admittedly, with only considerahle study be channeled into insurance funds thus helping to equalize or balance the cost of all insured, Direct relief is no cure for unemployment. BIOGRAPHICAL SKETCH - Hardy A. Kemp. M. D. Director of Graduate Studies, College of Medicine, Graduate School Affiliated Hospi tal9 > Professor of Preventive Medicine.and Chairman, Department of Public Health gad Preventive Medicine, Baylor University College of Medicine. S, in Medicine, St. Louis University, 1923, M. D. 1926. Teaching fellow in bacteriology, St. Louis University, 1923-26; interne William Beaumont General Hospital, HI Paso, Texas 1926-27; private practice of medicine and pathologist, Missouri State Hospital, 1927-28; associate professor bacteriology and ttygiene, Baylor University, 1928-34; professor bacteriology and preventive medicine, 193^-39; dean College of Medicine and professor preventive medicine. University of Vermont, 1939-41; dean College of Medicine, Ohio State University, and director university Hospital, 1941-44; on mil. leave, 1942-45; dean College of Medicine and professor Preventive medicine, Wayne University, 1945-48; professor of preventive nediclne, director of graduate studies, Baylor University College of Medicine, Graduate School Affiliated Hospitals and Chairman, Department of Public Health and preventive medicine since 1948. Served as 1st It.,Med. Res,, 1926; capt. Mo. Hat. Guard, 1927-32; maj., Med. Res., 1936; active duty with A.U.S.,1942-45; It.col., Med. Corps, 1942; overseas,1942-44, as asst. med. dir.,Trinidad Engineer District, asst, theater surgeon U.S.Forces in Central Africa, asst,, surgeon S.O.S. in China-Burmst-India, became deputy theater surgeon; colonel, Medical Corps Reserve, 1946. Secretary, Army Med. School,Apr., 1944-Oct.,1945, exec, officer in tropical medicine, Oct. 1944-Oct.,1945. Awarded 1st prize for meritorious research Tex. Path. Soc., 1933; 1st prize for scl exhibit Southern Med. Assn.,1934. Fellow A.A.A.S., A.M.A., Royal Soc. Tropical Medicine, Texas State and Harris County med.socs*,Soc. Exptl. Biology and Medicine, As. Assn. Writer of a Syllabus of Public Health Law, 1936, 3? 38. Industrial Physicians and Surgeons; Am. Public Health Association. 0O0 24 C. U. Dernehl,M.D. Medical Director Carbide and Carbon Chemicals Corporation Texas City,Texas October 13 Can all Industries share equally in the employment of disabled individuals? 1* I do not believe that it is possible for all industries to employ disabled individusls. It is my personal opinion that a great deal of the talk about the employ ment of the disabled has come from those areas where piece work or assembly line vork comprises a large portion of industry, I believe that it is possible for such industries to employ disabled individuals to good advantage. I do not see how an industry largely engaged in heavy manufacturing operations can be as lib eral in such a program. It is the general policy of heavy industries to save any light jobs which may be available for'their own ageing and injured personnel.This is only proper and I believe it would be unfair to ask such industries to accept ether handicapped individuals for employment* Should we distinguish between traumatic and disease disability? I believe that there should be a distinction made between these two categories, A traumatic disability usually presents the full degree of disability which can be expected at the time the individual presents himself for employment. In all prob ability any change will be toward improvement of the physical state. The Bame cannot be said of disease disabilities such as hypertension, heart disease, infec tious processes, arthritis, and etc. In these instances experience has shown that one can generally expect an Increase in disability as time wars on. 3, What about the problem of employment or re-employment of psychiatric problem in dividuals? Thi3 is a serious problem that faces all people engaged in industrial medicine. Ex perience has shown that people with psychiatric problems, if they are of any sever ity whatsoever, are usually exceedingly poor employment risks and sooner or later create new Plant problems of one typo or another. I believe that it is exceeding ly poor policy to employ any of these individuals unless it becomes absolutely necessary due to severe man power shortage. Similarly our experience with the re employment of psychiatric cases has been very discouraging. Almost invariably they become a difficult personnel problem within a year or lees of their return to em ployment. I recognize the fact that these individuals should have some means of providing for themselves and their families and yet we cannot permit complete dis ruption of Plant moral due to the presence of a few of these psychiatric cases. There are very few industries so situated that they can segregate such individuals to jobs where they have little or not contact with other employees. Until more satisfactory methods of psychiatric treatment are developed, I would hesitate to employ any individual with such a disability. What effect will the pension programs now being pushed by labor have upon the em ployment of a handicapped individual! It is rapidly becoming clear that industry fears the ultimate costs of the employ ment of handicapped individuals in the face of pension programs. The industries 25 fer, and perhaps Justly so, that they will become burdened with a large number 0f pension payments to individuals who have worked only a few years in the indus try concerned. Obviously there are certain traumatic disabilities that will not 1)e a problem in this regard. The same cannot be said of disability due to a diseHse process. Unless some different method can be devised to care for employees vho become totally disabled before retirement age, I feel that industry will be reluctant to employ those individuals who may become financial liabilities follow ing a short period of employment. t Should industries be held responsible for aggravation claims by handicapped employ ees? 1 feel that as circumstances now exist it is not fair to expect industry to employ handicapped individuals and then face the prospect of having claims made against them for aggravation of a pre-existing disability. We have at present a second injury fund which protects the employer against certain unjust claims with regard to permanent disability. The employer has no such protection against claims of aggravation of pre-existing disabilities. If we are to ask industry to employ handicapped people, then I think we must also make provision to care for these individuals if any claims of aggravation are made. If industry is to accept handicapped individuals who is going to determine ability to do the Job? In the instance of a large plant having a medical service with a physician in : charge, this problem is relatively simple in that the medical department can pro vide this service. In the case of the smaller plants having no medical service or a medical service staffed only by a nurse, this problem must be relegated to an outside physician. If that physician is sufficiently acquainted with the manufacturing processes of the industry concerned, he can in all probability make an Intelligent decision. If on the contrary he knows nothing other than what he has learned by hearsay and has not taken the pains to become acquainted with the worth ing conditions in the plant under consideration he is at best making a guess which may be greatly in error. Lay personnel of the plant can hardly be expected to make such a decision since they cannot be familiar with the medical questions in volved. They might be able to handle, without difficulty, the decision whether a one legged man would be able to hold down the Job under consideration but the finer details involving things like muscular weakness end disease processes would be strictly out of their scope. If an industry is to employ handicapped individ uals, it should have available a physician familiar with the Job under considera tion to pass intelligently upon the applicants ' ability to do the Job. 7. Who should bear the cost of determining continued fitness to work in the disabled employee? Bare again the industry having a full time physician has no problem in that this service can be readily performed by the Medical Department. Those industries re lying upon outside medical help on a case to case basis might well object to being asked to pay for such determinations. However, if the industry wishes to protsot itself, it would become necessary for arrangement of periodic health examinations probably at industry's expense. Only in this way can management be assured that such examinations would be carried cut on schedule.- The added coat of such exam>Tnations might well be another deterrent in the employment of handicapped individ uals. 26 g( Who should determine the degree of disability of the injured employee? It is common practice in many industries employing physicians to send to outside consultants all cases of serious injury requiring prolonged treatment or involving disability. In such instance the attending physician should determine the degree of disability with the plant physician rendering an opinion as to the Justness of the evaluation. In case there is marked disagreement, the opinion of a third phy sician should be obtained. If the plant physician treats the injured employee through the whole of his course and some disability becomes evident, then I feel it would be wise for that physician to obtain impartial consultation in determina tion of the final disability. This would be especially true if there were any question as to the degree of disability* 9, What part would rehabilitation progress play in the future employability of disabled personnel? Following war time experiences, it became very clear that badly handicapped indi viduals could be returned to a gainful occupation through active rehabilitation programs. Such activities are badly needed in the industrial field since actual accident experience has shown that each year there are almost as many workman in jured as the casualty experienced by the Army in active service. I am sure that with a properly active rehabilitation program in effect, that many more men could be returned to some form of gainful occupation if they are given the opportunity to learn and develop new skills within their physical limitations* This would give industry the advantage of employing a handicapped man already skilled in a new Job rather than trying to fit a totally untrained man into some providential gap*which happens to appear in the man power field. 10, What legislative steps are necessary to increase the employment of disabled persons' Occasional individuals have stated it would be well to have a law requiring that each industry employ a said number of disabled individuals. This type of regimen tation is to be deplored and it should be pointed out that it is totally unrealis tic in that it disregards the fact that certain industries can use only very Hab ited numbers of disabled people. The legislation which is now needed, and I might add urgently, is that which will give the employer some measure of protection against claims of aggravation of pre-existing handicaps. I feel very strongly that we cannot expect industry to offer employment to these individuals without that measure of protection* BRIE? BIOGRAPHICAL SKETCH - C. U. Dernehl. M. D. Born in Milwaukee, Wisconsin* Graduated from the University of Wisconsin and diversity of Wisconsin School of Medicine; Internship and Post Graduate training at the Medical College of Virginia in Richmond, Virginia; Joined the staff of the Medical Branch of the University of Texas,Galveston, Texas, in 19^0; Taught Industrial Medicine at the last named school from 19^2 until April, 19^7, at which time accepted a position as Medical Director of the Texas Plant of Carbide and Carbon Chemicals Division, Union Carbide and Carbon Corporation; Have teaching appointments in Industrial Medicine at the Medi cal Branch of the University of Tsxae in Galveeton, and the Baylor School of Medi cine in Houston. oOo 27 Zke Ait We Mreatke Xotes on an exhibit and demonstration of air hygiene research developments at THE HARVARD SCHOOL OF PUBLIC HEALTH Boston -- Massachusetts Presented at THE THIRD GULF COAST REGIONAL CONFERENCE ON INDUSTRIAL HEALTH Houston, Texas ,October 13 1950 DUST INHALATION TO RECORD MAN'S BREATHING Problems of "Loaded Air" Hon- to prevent the injurious and sometimes fatal effects of dust-laden air on industrial workers who breathe it has been studied intensitely by the Department of Industrial Hygiene at The Harvard School of Public Health since its founding in 1921 as the first post graduate health school in this country. This research has developed and made available to other scientist! and to industry and government a great amount of knowledge con cerning the effects of dust inhalation on the human system, as well as equipment for measuring, analyzing and eliminating particle from air. Typical developments: Equipment for finding out how much dust a normal workman retains in his system when he breathes a known amount. (It was found that the nose is a poor dust filter and that "mouth breathers' are not necessarily unhealthier or more likely to get silicosis than persons who breathe through their noses.) Relationships between dust inhalation and clinical symptoms t>: metal fume fever. (This study tevealed how resistance can beat quiied and thus explained a phenomenon familiar to industry--tha men ate not apt to get metal fume fever on two successive days. l>" lose their tesislance alter a few days away from exposure.I Proof that the smaller the dust particles, the greater the claim1to living tissue by silicosis, lead poisoning or other diseases. I Ext1" iuation of the livers of rabbits, IS months after the animals had l>e/r' injected with equal concentrations of quartz dust, in varying si-f1 showed that the least-damaged livers were from rabbits infected the coarsest dust > THE PNEUMOTACHOGRAPH--Until a portable and at curate appa- ratUs of this type was devised at The Harvard School ol Public Health. mans breathing cycle could not easily be followed precisely The instruTMlnt records instantaneously the actual rate of inhaling and exhaling '> persons at rest or at work; it is used in determining air How requirejucnts for gas masks and oxygen supply equipment, and in other proli- nis of great industrial and military importance. The pneimiotadiol',aPh is also a valuable aid in diagnosing industrial lung diseases anil ^ber pathological respiratorv conditions. The instunnent was developed " ^r- Leslie Silverman, Associate Piolessoi oi Industrial Hygiene. AIR AND GAS CLEANING Problems of Ventilation One o the first pieces of equipment made in The Harvard School of Public Health more than a quarter-century ago was a 1200cubic foot dust cabinet in which to produce laboratory conditions found in industrv--in factories, mines and quarries. It has served as a small granite cutting shed, a mine (for studying rock drilling), a paint shop (for studying paint spraying) and a welding shop (for | . .i studying the causes and control of metal fume fever.') This versatilt servant of research has been copied by former students and col leagues of its designers. TO PURIFY THE AIR WE BREATH Proceeding from its studies of the effects of dust inhalation on man. the school has developed ventilating, and air and gas cleaning methods and equipment for industrial workers' protection. Typi^ developments: Specifications, generally adopted during World U'ar 11 and written into most state codes, for exhaust ventilation in uieldn's operations. Operating and ventilating requirements for industrial tanks <*'" vats, including tanks used for impregnating and coating wire. Specifications for the safe use of "metallizing," a metal spraV' ^ n major problems of certain industries lodav is to satislv "gid requirements for air and gas cleaning. process in. which metal fumes may poison the person doing the sf,,<t i uj, l*IC ,ctll|c't ol the Atomic Energy Commission, the Si hoo! has set i,, `'ficiJiori to study present equipment and methods. A majoi por- Specifications for exhausts needed to prevent air contami'"11' in various industrial operations. Contours of air flow into hood- t|,, ' l*,<; P'oject is devoted to basic research on gas cleaning and in- ventilation. 1,1 die .i, aboie photo, a wet cel! air washer is undergoing test lor eHi- different design were developed and are now used routinely ^ M ,1^ ^ P-nticle icmoval. .Simulating actual lactoiy conditions, a number ' `lnt* lll,nes ate ted into the equipment and theii selective climb gineers designing hoods for special jobs. j ' "'casured by various tests. jin!i] c Ji- jvmejiouioije iq \riu cimiiiiil .11103 p.nini]ui-l m )lHp si mm Jjoiiis 3ip J3.\o SRciiiEApr sij mmprm .up ui agqw ?u!sI.IjJU1,J S"`uiSQ"l aie uJJ.pq.qJ.i.pi.q..n .ui suaas ioiejhIss.i |Didu e .si s.iq--j_ ,l3|Sofl i o . , cr 'ifi:1ididss<oH s.ua.ippiQ 1E loiu.uclssj pazis-uiooj e -- iunuido|3A3|) c jjoo sssjnnid 3ui7Eoeiu 3jn .uopq iqnu 3iji ie uuoqs; SUIAOUI ill 33U31U3AU03 JOJ SJ33l|.H llO pJHIllOUI S.UIlipEllI Xp i|i! n nomnpojd ui p33E[d U3qi seas ij 'g^61 u< lu.-imid sis\|E.ind ue uo A||njss333ns pssn 3q 01 .ioie.ikIs.u is.iy .up sr.\i japoiu . j.uiESp uinnjEA pioqssnoq e uiojj Jiiiquuii Jip to ,\poq up p)*l 5jnssa.id a.unsod puE suieSsu sieu.isiie iiuip r O] 3 A | E A UUE-IJ'pOJ t Sill' *s lUEpliaiiE uy 'SpqouioinE ue Japun iHiiqju.u joj s.isn auitnpAui ,e q3ns ..usdssjj.. sSejeS e uiojj spEiu paq e jiue qum jeuiu irpif s)j3J e J P3151SU03 *3.\oqE `njSu sqi ]E ii.'soqs ,.Sun| no.it.. is.iy aq j_ ........ UWP0,U * '"PH ' ` 3U SM> >'oqV-3Nai M0Hi JOlEJldssy 3Ill3.1l|do.U33[3 3l[) U011U3AUI Jl3ip p31EJlSU0lU3p 1SJIJ aSo|OIS\1|J JO HlSUIUudaQ 3ip JO S3I1j5E3[[03 pUE JJOUJES | ASJUElg '.IQ JE3A ISE'J qooips p.lU\JEJ-[ Jip 1E su3iSaj3 jEuisnpuj jo lusuiUEdaQ 3ip jo isqm.iQ diqqg 1<JSS3! -old Aq p3iu3.\ui su.u .,'Suii| uoji,. jo Jonutclsj-y jaquuQ 3qj_ qi[E3H 3!iqnj JO jooips pjE.uuH sqjL 1E p3Cfo|3A3p pUE P3AI3.3UOD 3J3.U qlOQ SScJaI lU3J3JJip JO S3UIIJ3EU1 0.M1 p33np>Ojd SEl| ipjE3S3J SJ3.Mod AJ01BJlds3J jEJtUEU SIl| P3133JJE ipilOjaSuEp SEIJ AJtlfui JO 3SE3SJP U31JAI `UEUl JOJ 3ipE3Jq OJ^ ssMd3,, PUB ttSunl UOJI,, 3HI M0IXVHIJS3H 3VI3I3IXHV qi!H 3'iq^d } IootPS iiofOiSAiJd )0 luaunJBtlafl aqi ;o qijjaqujiuBH i3qis3 Pu* JMJquauni^\ 1 su*f JCT ip!A\ sqiEa.iq isjy .iiaqi aqEi saiqEq ujoq.\iau dpi] aeui puE AJaS ms uiE.iq Sui.inp uiqiEa.iq uieiuibiu oi pasn aq aeui ij iionn30.ii3ap put EIXAqdsE `SuiUASOjp JO SU.1113IA aiEll3SnSai OI SlU3p03E JO 3U33S iqi oi pat.UE3 aq oi qSnoua iqq puE lOEduioa `]]euis si ..'aaa,, aqx uoiEJidsai aqi jo suoya aqi puE suoya s/iuaiiEd aqi uaa.vuaq Diyuoa aqi aA[osa.i snq: puE SuiqiEajq u.no spuaiiEd aqj ssajddns usa S55|mliiii sii asnE3aq asuaaya aaoui si ..adH., aqi ,,`Surq uoji,, aq: \q pasod -mi tuquqj jEjnSaj aqi qii.u paztuojqauAS aq iouue3 SuiqiEajq JEjnSaui nuaiiEd aip ipiqAi ut (oqod JEqjnq XqEiaadsa) sassa uj uavo sii jo saSsi -UEApe SEq ,,ad3,, aqi .,`un[ uo.ii,, aqi 33E[daj lou ][ia\ 11 qSnoqqy SuiqiEajq [elujou sa[qiuasai Xpsop qaiqai `Suiqisajq Wished `]3e.huo3 uiSEjqdEtp aqi saipiu aa.iau oiua.iqd aqi `paiE[nunis ^.L 'mSEjqdEip aqi 01 uicjq aqi uiojj spsa] qaiq.u. `aAjau aiuajqd aqi iui S]EAjaiui ie luas si luajjna panuap pa[[0.iiii03 XqnjajEa e `pau aqi kuieSe passajd apoaiaap ue qSnojqx sumaiA oqod jEq[tiq jo saAi] aqi 5'K oi Susdpq si lEqi aaiaap aqi SuiiEiisuotuap Aiopq u.vsoqs si `joiej aiuajqdouaapj aqi jo tjoiuaAUi-oa `jjoujes -f XajuEis `jQ aoxvHidsaa DiNaaHdoaiaaia f -A.-- Afternoon Industrial Health Conference Panel Frederick G. Sawyer, Ph, D,, Moderator "ATM03P1EHIC COHTAMIHATIOIT AHD INDUSTRIAL WASTES SYMPOSIUM" Joseph E. Flanagan Senior Sanitary Engineer Chief of the Cooperative Health Services Branch Division of Industrial fygiene United States Public Health Service Washington, D. C. October 13 j have been asked to describe for you the government's attitude and plans in the field of air pollution. j am sure that many of you are already aware of Just how much the Public Health Servlec is interested in this problem of air pollution. Many of you, I am sure, attendaA the first U. S. Technical Conference on Air Pollution held in Washington last May. jgre than 800 people from industry, government, labor, and even private citizens at tended this meeting. The Conference was divided into 7 panels considering different aspects of the problem such as agriculture, analytical methods and properties, equipjiat, health, instrumentation, legislation, and meteorology. There were 90-odd tech nical papers prepared for the meeting. The entire proceedings of the Conference are gov being prepared for publication by the McGraw-Hill Publishing Company, and it is yy understanding that the book will be available about the first of the year# Quit took should furnish the most complete and up-to-date piece of literature that pa have os the broad field of air pollution. ft# interest of the Public Health Service, however, is aimed mainly toward the future, ilthough we, along with others, have realized in a general way for many years that air contamination was a problem, it was the episode of Donora that made it so graph ically plain for the first time that air pollution must now be regarded as a more argent public health problem. In addition to the possibility that there may be future acute episodes like Donora, there is the more important probability that air pollu tion in lesser quantities may have chronic effects on citizens in a number of comou.aities in this country. The obvious conclusion is that we need to begin long-range Mdical research as quickly as possible in addition to other fields of activity I will aaatlon in a moment. there ia a considerable amount of research now going on to answer the most important questions in the field of air pollution. A great amount of this research ie best ione by industry and private enterprise, but there is also more in which the govern^ sent should lead. President Truman, in his opening address to the air pollution con ference in Washington last May said in part, and X quote "Since the problem of con trolling atmospheric contaminants la primarily local in character, X believe that each locality should study its own situation and draft lave adapted to local conditions. Before this can be done, however, standards for evaluation and control of air pollut es need to be established. The Federal Government should take the leadership in king this part of the over-all Job, and I hope that Congress will see fit to appro bate the necessary funds for research*. 28 T Acting on this premies, the Public Health Service has napped out a long-range regearch project, which will revolve about four points basic to the air pollution con trol program. First, we must identify in a more detailed fashion the various pol lutants, their properties, and sources. Second, there 1b need to develop more ef fective methods of sampling and analysis. Third, as I have mentioned above, we must determine chronic effects of exposure to air pollution so that threshold values of contaminants may be developed. Finally, we must do research on control measures to arrive at methods that are more practical and economical than those currently avail able. Some of the specific research problems with which we must concern ourselves include field studies to determine the types of contaminants, concentrations, diurnal varitetions, and dissemination of contaminants. Such studies would include meteorological oeasurementa and would be sufficiently comprehensive so as to give basic information of abroad application. Also proposed are studies of available vital statistics to evaluate the possible as sociation of atmospheric pollution with various common diseases. Through laboratory studies with human subjects, we hope to determine variations in individual response to odors and irritants as well as possible effects of tempera ture, humidity, and age. Our proposed laboratory studies will also attempt to as certain, through animal experimentation, the effect of low concentrations of contami nants for continuous exposure, the effect of mixtures of gases,the effect of mixtures of gases and particulate matter, and the effect of contaminated vegetation on animals. Another phase of our proposed research program entails the modification of existing methods, or the development of new methods, including continuous recorders, to more precisely determine atmospheric contaminants* Such studies are fundamental to the whole atmospheric pollution problem, for from them will evolve a better standard!sec tion of methods, which, in turn, is essential in establishing standards. I don't believe that I have to say that these problems are not academic or theoretic al. They are only part of the host of unanswered questions to which the Donora smog investigation called new attention. Ve now know that this information ie absolutely essential before we can proceed to the next step---the establishment of much-needed air pollution standards. At present we know the criteria and factors to be consider^ ed, but they cannot be evaluated adequately until the data that we are seeking are available. The final point in our proposed research program calls for the improvement and devel opment of control procedures, the natural concomitant to the establishment of stand ards. Although here, too, we know the fundamental principles on which to base con trols, much work is needed to apply these principles in an efficient and economical way. These projected activities fora the crux of a comprehensive research program which ve hope will shed light on many of today's puzzling questions on air pollution. This program will awing into action Just ae soon as the expected appropriations material ize. In the meantime, within our budgetary limitations, we have been giving consult ant service to various States confronted with air pollution problems. For instance, we are assisting a city in Maryland with a study of morbidity in relartion to air po llution being made by the Maryland State Health Department on a special 29 ,raat from the State legislature. Ab an aid to researchers, we also did a length? review and abstract of all the literature on the biological aspects of air pollution, ggd, this annotated bibliography has been published by the United Steel workers of America. CIO, as a public service. Our major study at present involves air pollution oTer the international boundary between Windsor, Ontario, and Detroit, Michigan* The problem centers mainly around contamination from vessels plying the waterway and has been referred by the Govern ments of the United States and Canada to the International Joint Commission. Both governments are to provide the necessary services, and the groundwork has now been laid for active participation by the Division of Industrial Hygiene, Public Health Service, which will conduct the work of the American delegation. A&d now let us turn to a look at the matter of legislation. It offers in many ways more obstacles than research. As technical people attacking a technical problem, we ]ojov that no matter how complex the problem and how far distant its apparent solution, vs must first list and evaluate the queetlons to be answered and then sat about an swering them in methodical and orderly fashion. As is often the case, however, scientific progress must often take place in an at mosphere of public demand for that progress and usually the public is not willing to wait as long as the scientists would like for the scientists to produce their answer. At the same time the scientists realize that public demand is often neces sary to their work, so I do not mean to isrply for a moment that public demand ia always to be listed aa a barrier to progress. This has in general been the situation regarding air pollution. Some public demands have been good, some have been unwise. Adding to the confusion has been the fact that many cities have been concerned about smoke pollution through the years, and aany more, still working on pure smoke control, have confused that with the overall problem of atmospheric contamination. One type of legislation requested has been the establishing of air pollution control hoards in each county of a State, authorized to employ their own experts and to op erate individually with no tie-in or correlation of activities with the State Health Department. Such a measure wee proposed, for example, in Hew Jersey, an industry felt compelled to fight its many restrictive provisions. The Federal government in good conscience could not support such legislation, if it was requested to do so. The Massachusetts legislature saw the introduction of another typo of stringent reg ulation. A bill was offered that would require all commercial plants in the State, especially thoae concerned with commercial fertilisers, to eliminate odors detestable by the "average. Individual11 beyond a radius of 300 feet. When one considers the heavy odors that come from, for instance, a candy factory, the enforcement of such a law offers quite.-a problem* Eentucky, on the other hand, is considering the sonlng approach to the problem. A bill has been introduced in the Kentucky legislature to prohibit the establishment, development, or operation of carbide, sulphur, and lime plants within ten miles of a city of the first claasi Thtre are other states which are proceeding toward what ** feel to be a better solution. South. Carolina# for instance, has- authorized the creation of a committee to make a full and complete study of the needs and swans for regulating and controlling smoke, soot, smog, and other similar publie nuisances in the State and to report back to the legislature with recommendations within a speci fied period of time. 30 spring the governor of Maryland signed into law a 'bill providing a sum not to I*5* d $100,000 but appropriated annually for the Statie health department for the * control of air pollution in the State I might add that the actual appro-- ,ttf tion this y*ar amounted to only $10,000. t states have had bills introduced than I have mentioned here, and probably even **rreater number will see bills introduced in future sessions. I am sure you will g 9 with me that every effort should be made to guide the deliberations of State ^islatures considering air pollution bills. this respect it must be borne in mind that often the type of legislation brought fore the legislature of a State may be greatly influenced by the attitude of the 1 2th department of that State. In some states the health department, for reasons a. its own, has not identified itself with air pollution work. In some cases the director of the State industrial hygiene unit is not yet convinced that air pollution a public health problem. In other cases the same officials, while convinced of tbs importance of air pollution as a health problem, have been so understaffed in tbeir efforts toward solving the traditional problems of industrial hygiene that they not felt justified in giving attention to seemingly fringe problem. Consequent-' local communities in these states, unable to look to the State health department for technical leadership and assistance, are left to their own devices in an exceed-logl7 complex field. feedless to say, the Public Health Service is well aware of these problems of staffing tsd budgets, and the many pressures on a State health department. But we believe firmly that the State health department is the logical agency, from many points of riev, to deal with this problem, and we hope that all State health departments will find it possible eventually to get into the field to the extent necessary in daeh State. The extent necessary may be inversely proportional to the efforts and accom plishments of industry. fails the states have been busy with legislation, there has also been considerable activity in the Congress in Washington. Up to now there have been proposed 7 bills. 7our of them would authorize the Public Health Service to proceed immediately with research. Three of them reflect a different--and to our mind a rather limited--view of the over-all problem. One of the three would authorize the Civil Aeronautics Board to study the need for teog control in the vicinities of airports in order to promote safety in air naviga tion. The bill would also give the Civil Aeronautics Board the power to determine the most practicable means by which the discharge of smoke contributing to the forma tion of smog could be controlled*I I believe that the objections to this bill are obvious. First of all, from the stand point of health, the moat dangerous smogs are not necessarily those which hamper visi bility. Second, in soma towns where the smog problem exists, there is no airport* furthermore, we do not believe that Federal control of the smog problem is the solurtlon. Air pollution ia not necessarily even a State problem* It le primarily a local matter, since each locality has its own peculiar topography, industry, and metheological conditions* We believe that the Federal Government should have authority to step into a local situation only when more than one political area ia involvedr--as, for example, the Staten Island problem, involving the States of Hew York and Hew ;hsey. 31 fl0COQd of the three hi lie would authorize the Bureau of Mines to engage in recb and experimentation in the field of air pollution. The language of the hill safl9uch that it would put the Bureau of Mines in the business of industrial hygiene e7ery State in the union and thereby result in a complete duplication of the work i0 ^eing done by the State health departments and the Public Health Service. third bill would authorize the Secretary of the Interior to "conduct researches, Judies* investigations, experiments, and demonstrations, including laboratory and 5 Teiopment work, and to publish and disseminate information, for the prevention of tmo8Pkeric pollution from harmful solid, liquid, or gaseous substances from any aourCe or causes, including all kinds of industrial operations." At the same time, * would authorize and direct the Surgeon General of the Public Health Service to >tarry out a program of investigation and research into the health hazards of atmoefceric pollution designed to determine the long range and chronic, as well as the jcutei effects of atmospheric pollution on health." ^ it stands, the bill would also create the same needless duplication of work between two agencies, since the Public Health Service is already carrying out the atmos pheric pollution functions that would be aBBigned to the Bureau of Mines. la the midst of this problem we are conscious of the situation in which industry finds itself. Many industries are doing their own research and seeking by whatever means they can to cut down on industrial air contamination as a matter of public relations gnd also of economics. At the same time those industries often feel that they should aot talk about what they are doing. There are indeed many management leaders, as well as leaders of other fields, who have refused to accept the importance of air pol lution. But it is industry which will have to live with the problem and eventually help in the solution of it. It seems to us, therefore, that the legislative problem is as important as the re search problem. Wherever there is a public demand for legislation we should work to steer such demand into the proper channels rather than to kill it or rather than to denounce it. So you see it is a field in which there is plenty of work for every body and it is certainly a problem that affects everyone of us, as well aB every citizen. oOo BIOGRAPHICAL SKETCH - Joseph E. Flanagan. Jr. Born - Worcester, Massachusetts. Educated - Public Schools, and Worcester Polytechnic Institute Seceived B.S. Degree in Chemical Engineering - 1935* Experience - 1935-1940, Massachusetts Department of Public Health 19^0 to Present -- D. S. Public Health Service. Assignments with Public Health Service 1940- 1941 -- Stream pollution and industrial waste investigations - Cincinnati,Ohio 1941- 1943 -- Industrial Hygiene Engineer engaged in investigations of arsenals pro ducing munitions of war throughout the United States. 1943-1946 -- Assigned to Ohio Department of Health as Industrial Hygiene Engines. 1946-19^8 -- Industrial Efcrgiene District Consultant,District 3, Chicago, Illinois^ 1948-1950 -- Chief, Cooperative Health Services Branch,Division<f Industrial Hygiene, Washington, D.C. 32 I--' "A PROGRAM FOR INTER-INBOSTRT COOPERATION* A. J. Krell Field Instructor Texas Engineering Extension Service of A & M College College Station,Texas October 13 industries of America have long known that they have a waste problem. More recog(*ion that the problem existed did not, and has not created a solution. There has en rea8 publicity generated on the subject of water and air pollution, and more tke same is undoubtedly in an active state of preparation. In the last decade, a cellar phase of American life has developed. It consists of the act of rushing into pint with a press release, as if the well-springs of publicity had a magic elixir L; the curtailment of a current ill. There is no question about the valid uses of jjiicity end both the lay and technical press have been used in promoting and indeed, jrea creating pressure if necessary, for the development of waste control programs. 3avaver* whether in the employ of government, business, or the publication field, let u# avoid creation bitterness or the sharpening of antagonisms where they already ea- 1st. Cop world is more in need of large doses of cooperative effort, and this is one of tbe fields where industry can demonstrate its ability to work as solid citizen, eaofe 1b his own community. No industry, or individual can live as an isolated entity in lociety* The geographical frontiers of the IT. S. are limited now, until further ad vances in technology and basic science may make areas available not now considered possible investment developments. Essentially we have to stand where we are, develop, ue, and conserve what we have. What promotes the life and progress in each community soat help industry. Tney are inseparable and cannot live apart. Our theme is cooper ation. The means and the methods of making working better now with what we already hare. Can inter-industry cooperation on a regional basis provide clean water and clean air where we live and where we work) We must seek all methods of reaching thie objective without dislocating the productive efforts of industry, or the creation of a possible marginal status. This is what I would like to discuss. There are some interesting parallels between the early industrial development of the U. S. and our present Southwestern industrial concentration. I hesitate to use the vord "empire". During the middle 19th century when the effective industrial developMnt of this country began, it was able to accelerate its production efficiency and rate beyond the Old World's by taking advantage of the technically applicable discov eries of the 17th. and 18th centuries, the then threshold of the new world of science. So here in the Texas Gulf Coast, we find ourselves on still another threshold. For tune Magazine in a recent issue hat called it the "Chemical Century". Our expanding industry brings to the fore new and revolutionary concepts in both technology and in industrial administrative practice. The increasing integration of industry both in the Gulf Coast and other sections of the nation make it difficulty to tell what ia * chemical industry per se, a packing house, ceral' milling, wood pulp, or petroleum Wining industry. All of these and many more industries have become so extensively organized that they are producing what were previously considered primarily the prod-- sets of a chemical industry. Thay have created new chemical products that were not Wn as little ae ten years ago. Tou can all think of plenty of them. In our re- 33 the biggest development cornea under the heading of the petro-chemical industry been growing at a rate that keeps the statisticians slightly out of breath keep records of the progress made. gignifieanee and importance of the part that integration of chemical production e in the control of waste can only be hinted at here. It is a complicated problem ^ t deals with financing, marketing, anti-trust actions, fully as much as technology, ^ can not be explored here. However, the dynamic role of production change and **-giopment as one of the leading aspects of American ohemical technology may be noted observing a product that resulted from industrial integration. A far reaching in- ^fatin i ^e enormous increase in the production of oyrthetic detergents processed /ro petroleum derived hydrocarbons. In 19^1, thirty million pounds of detergent r9 produced and in 1949 - 1950 we are crowding the billion mark. One producer e- d to such an extent that by-product hydrochoric acid resulting from halogenation ^petroleum derived hydrocarbons had replaced all outside purchares, with still an excess in sight. Now attemps are being-made to revise all plBnt processes of the oinpany utilize purchased sulphuric acid, hydrochloric acid here is a waste un- it can be successfully integratsd into the companies own manufacturing operations, ioli or even donated to another producer. jev products bring new wastes and new problems; problems that all existed before. How ler, they have not previously developed at the rate and volume that we are now ex periencing in the unprecedented expansion accelerated by integration of primary pro ducers. The constantly changing panoram. of process developments are being highlight ed by new competitive problems from compounds resulting from the Fischer-Tropech pro cess in petro-chemicals. Coal hydrogenation under high pressure may have a signif icant impact on our economy and restore some of the advantage to coal as a chemical raw material that had been lost to the petroleum hydrocarbons. A bright new comer still in the experimental stage ie the recovery of chemicals from the distillation of shale oil. Its economic position improves as the price of crude petroleum edges higher and the mining and distillation of shale becomes more efficient. These examples indicate the incredible speed with which the 20th century Amerir n Chemical industry changes. It is a prime characteristic of our technology. All modern technological developments are based on extensive and intensive research to obtain maximum yields. As a result of these two characteristics, a waste control program can be a piece meal affair delegated as a nuisance to some 'poor Joe', with whom everybody else in the company will sympathize with in a superior manner. It must be completely married to the research and development phases of every new peoduct con ception and part and parcel of the production process* The first attack on wastes, new or old, belongs at the process development level. And many industries are devel oping the kind of personnel that are ramroddlng the job. I mean a new type of ac tivity, a waste control coordinator, or conservation director. Call him what you' fill, but Ms prime responsibility is to see that management's program of waste con trol by pressing consideration of the problem in research, development, operation, ud where necessary to obtain necessary treatment facilities, Kany management people, executive and technical have told me repeatedly that the po sition of Industry in waste treatment and control is similar to the attitude that existed toward industrial hygiene and safety thirty or more years ago. Social ace*?tance of an industrial activity or benefit, like other phases of education are cu rative. Rational programs for the control of industrial pollutants will not have to be struggled for. We do not wish to gain the public indignation, and indeed hatred 3* t industry reaped from- its early opposition to acceptable programs of hygiene and J^ety. paste resource necessary to the solution of any problem lathe trained people to j It* The Texas Engineering Extension Service of A & M Coliege is working cooppeerran ^* esiy aw.'iiAtUil lIn<d)^a*Atry Atao proviJd*e timn4taemnbs4ive short *cjmourasaeas Atmo ..aacMic^o--m-1p4limsUh AtVhIims Aa a--s,gj o^f TWJmaMsAteA PSAtu"dJ My ConferencMeAMs have VbeAMenA VheldJ Iina AthUeA tinAjdImuAsA tr4ial AcAoAnAcAAeAntraations of ?be state to obtain information concerning the local problem and what the need of the e0ple in industry is to accomplish pollution control work. As a result of this pri? ry activity, a base course, "The Effects of Industrial Waste on Aquatic Life" was rep?e(l ami presented in one locality already* Plans are now being made to complete circuit of Gulf coast cities by January 1951* la addition to this, other courses the treatment of air and water borne wastes are in preparation. Our is a practical rogrnra of working with industry to get something accomplished today. Since the passage of the Water Pollution Control Act* Public Law 845, industry in cooeerted action and as individuals has been making aggressive attacks on many difficult phases connected with the control of water and air pollution, "Stream Pollution Con sol Activities of Industrial Associations", an article by V. H. Wisely, editor of Sewage Work Journal appeared in the January 1949 issue. To the associations Hated, l sent a letter of inquiry requesting information on their industrial vaste activity* goet of the associations have developed programs designed to be of some general bene fit on an industry-wide basis without regard to specific regional aspects of tha prob lem. The most extensive work has been accomplished by the groups of industries whose problems are the largest. Comparison of the accomplishments achieved by the various industrial groups would be beyond the scope of this discussion and certainly such a report would scarcely be accurate based on incomplete information and time limitations. mother development in ths field of inter-industry cooperation was the formation by 19 major industrial groups in May 1950 of the "national Technical Thsk Committee on Industrial Wastes", From all indications the work of this committee is still very such in the formative state and its future activities will be watched by ell of ua. jour major "task groups" havs bsen established) Task Group I, Food Industries, II Mineral Products, III - Chemical Processing, 17 - General. Industries. Purpose of the various groups has been stated by FSA Administrator Oscar Ewing as, "........task comnitteea will draw up a program to solve water pollution problems caused by industrial nates for which no methods of treatment have been developed and to improve existing *aate treatment methods where needed". However, another development that brings together diverse- Industrie*, but of the same locality, has resulted frov ths work being done by eome of the interstate compact comBlssione, and those designated, aa under the Water Pollution Control Act as water pol lution control Agencies os an interstate basis-. These are divided into two groups) The compact agencies through the consent of Congress and by agreement of the cooperat ing state governments; and those organised by private industry and designated under, P.L. 845 by the Publie Health Service.. The letter group of designated agencies ia limited to the work of the marine fisheries industry and is composed of the Atlantic States, Gulf States and Pacific State* Marine Fisheries Commissions. Presently active in this group in pollution control activity is the Atlantie State* Marine Fisheries. Vith a grant-inr-aid from ths USPH3, it is conducting administrative operations on a (tudy to determine the extent end effect of industrial and waste* of. domestic- origin 4n the economy of ths marine fisheries industry of the Atlantia Coastal States. The technical direction of this survey, is under, the supervision, of the U.S. Fish and Wild- 35 . T I Survey and. is acting in its official capacity as the primary research agency for * Commission, neither the Gulf or Pacific Marine Tisheries Comniesions reports any 1 tjvity as a pollution control agency in its own right, either technically or admin istratively. of the inter-state compact commissions report some activity with industry on polJJtioa control. Agy are either surveying the problem or have an industrial advisory committee wortol'og with them. The Interstate Commission on the Potomac Blver Basin delegates to advisory Industrial Committee all problems connected with industrial waste with (be request that they make recommendations to the Commission as to what action should taken. The Commission reserves the right to its own discretion for final action on any recommendation. 0)e Ohio River Valley Water Sanitation Commission composed of eight signatory states l^g a special unit within its own staff to coordinate data and to otherwise develop ggd. accelerate industrial waste control measures. It has received a grant from the QSpgS under Public Law 845. One of the objectives is to bring up to date the primary record of data of the Ohio River Survey. All work will on the coordination level vlth no direct research or laboratory work planned by the Commission itself. {he Interstate Sanitation Commission is presently planning a survey of industrial pol lution and will not be in a position to provide information for a year or two. Its grlmary emphasis has been on the control of domestic sewage pollution from contribu* tory cities into tidal waters of Hew York, Hew Jersey and Connecticutt. It reports 3o specifically organized program of industrial cooperation,but has always worked in the spirit of mutual aid to carry out its objectives of improving the condition of tidal vaters on the shores of the signatory states. This brief account of one phase of the pollution control activities of the interstate sgencies furnishes us with the basis of considering a program that may be more suita bly organized to meet the requirements of the industries of the Texas Gulf Coast. The problem of organizing industry to work on its own pollution control problems is limpler in Texas than elsewhere because of the state*8 geographical continuity. Cur ujor pollution problems originate in well defined industrial concemtrationa, all vithin the state. We are therefore not concerned with the problems of multiple po litical subdivisions with the exception of the county level. They can be readily handled and do not require any further discussion here. There is possible here a re gional type of industrial organization to handle its waste problem because of the fairly sharp lines of demarcation of each industrial area in the state. While the vaate control problems of different industries requires specialized knowledge within the specific industry and individual responsibility, the community receiving water ud atmosphere ia the common responsibility of all resident industries. Eere in Texas w have an opportunity to demonstrate what the local level of industrial cooperation can accomplish by doing the job where it needs doing the most. %s advantages of regional industry organizations to cope with waste control and polrhition problems may be divided into two aspects* The in-plant problems would deal 'ith effluent quality control information, as may be accomplished by process modifi cation, and to technical developments of the treatment of waste itself. There are taay phases of cooperative effort between allied industries la the tame area that are Possible. While it is doubtful that companies will share information concerning their 36 modification* to reduce pollution loads, thorn aro many in-between areas for f'gjjaiigo of Information whom competitive intoreato do not claah^ Thera In always ^poaoibllity of eooprimiao under ouch circumatancen to achieve progress for ali : jonc*^* 4y0 points of cooperative endeavor regional activity suggest themselves for in-plant jtudi*1 (l) the polluting effects of raw materials common to a given group of Indus-- ,f0S may be studied by themf so that better ohoioe in production control may bn ao-> o0pllshed in the transformation of such materials; (2) exchange and standardization ^ analytical methods. One of the fields of investigation is in toxicity testing, f division of labor in a group of local laboratories would certainly provide us with ggj* accurate methods more quickly than is otherwise possible. Oils is the type of ^oject that requires doing in the industrial laboratory because it should be corra^at>d with design and operation of treatment plants. out-plant development of cooperative effort in the area would deal with the Joint gopervision of the common receiving water. There would be collaboration on sampling program and the information obtained by each company would be combined for the bene fit of all. There are many companies now carrying out extensive sampling programs Ib their own receiving waters with considerable duplication by their neighbors. The value of this information could be increased enormously to all in the same area if It vers traded and coordinated in a spirit of mutual trust and confidence* Costs of ,gcb programs would be materially reduced. And in all instances, a more comprenhea,ire and accurate survey would result from such collaborative effort. In the same manner on an in-plant and out-plant basis problems in air pollution could b thrown into the cooperative hopper. The lines of attack on both air and water borne pollution follow the same general application* these few examples are Just suggestions of what may be possible in an organized ac tivity of this type* It by no means explores the possible combinations that may re mit from group action of able and intelligent men with backgrounds of solid indus trial achievement behind them. First, it is necessary to overcome some of the feare and artificial restraints of some company policies* There are many examples in other fields, however, in the field of waste control such actions are still in their infancy* It is in the solid American tradition to be adverturous and experimental enough to form the kind of organisation necessary to the thing that needs doing* Let's got away from that fatally digressive 'rat-hole* of* "..if we only had a law that would...ate." < need trained people, mere information about our Job* and coordination of existing facilities more than anything elae* e fate of industry la this field likee distinctly in its own able bands. Shifting responsibility tor gpvernsient agencies will not get the Job done. Our problem has uny technical selUtlona whose probable solution seestf more reasonably to lay within tfce province of industry* Tbgether with the technical phases, we bare the financial ud internal company organisation aspects. All this requires tine to work out* So taount of wish fullfllasnt will ever substitute anything in its place. If we don't Win aggressive programs to accomplish something, we have the alternate- possibility* distinctly real, of more rigid enforeamsnt developed by public through channels ** *slf-geaerating government publicity* Than there in that sisallug type of public taiigaatioa stimulated by obvious nuisance or reel danger to public health through and air pollution* forced on sons communities by industry* Our people no longer tak upon dirty atmosphere or water with glances of gratitude that the plants la their j wnuoity are operating. He expects either a Job or an income from the government, e^coatinuance of dirty atmosphere or water as a result of an industrial activity (hose same companies have already seemingly accomplished miracles of production, flI.e considered modern vizards, only convinces the average citizen that the hig oration is conniving at some way of avoiding and evading the job they can readily cooperative action in each community to work toward a solution of 4* ,,r0blem, will bring us to the point of maximum use of natural resources without Cbe<c and dislocation of industry* Failure to act will be costly to all concerned* 0O0 38 Industrial Wastes and Stream Pollution Symposium David 7. Smallhorst,Presiding "GENERAL TRENDS REGARDING INDUSTRIAL WASTES AND STATE LEGISLATION IN THE NATION* R. 7. Poston Senior Sanitary Engineer Officer in Charge, Western Gulf & Colorado River Basin Office United States Public Health Service Dallas,Texas October 13 4 public concern over the protection of the quality of our natural waters has been in casing steadily in recent years* The passage of Public Lav 8h5 was but another indication of the rising demand that our water resources should be restored to and is a clean condition suitable for public water supply and many other important uses. I clearly expressed desire that constructive steps be taken in removing from our watercourses those substances inimical to the general welfare is making itself in creasingly apparent today* Municipalities are being called on to treat their domes tic sewage* Industry is being asked to utilize or treat its wastes, and other prlT8te and public agencies are being approached to do their part in improving the qual ity of our water resources* One can hardly pick up a professional magazine or trade Journal without finding a reference to water pollution. The newspapers, the popular magazines, the radio and recently television, have taken a part in advancing the cause of clean streams. The iaerican Federation of Women's Clubs, to name just one group, has set as one of their goals the restoration and preservation of pure water resources. I am glad to say that industry has recognized this trend and is taking steps to abate Industrial waste pollution* For many years, certain individual plants, and certain types of industry have been aotively studying their waste disposal problems* To proride a broader base for these efforts, industry has established a National Technical Task Committee on Industrial Wastes* The first meeting of thie group wae held May 9-10 of this year* It Is proposed that they define their problems on an industry vide basis and working with government on a mutual cooperative basis solve the waste problems confronting Industry as a whole* The functions of the National Technical Task Committee are: 1. To inventory, appraise, coordinate and promote research in developing methods of using, treating and controlling industrial wastes* 2. To facilitate the devising and adoption of uniform methods of measuring and evaluating trade wastes in water quality control* 3* To stimulate more effective working relatione on technical phases of trade waste problems among industry and federal, state, and local agencies* 39 4. To employ the facilities of the Environmental Health Center of the Riblic Health Service in those areas of research and development wherein they would he the most valuable to the over-all program* 5* To aid in establishing those areas where major needs exist for financial as sistance in obtaining basic information on industrial waste problems in water pollution control. 6. To stimulate further the adoption of practical methods--known or yet to be developed--for reclaiming, reducing and treating wastes impairing natural stream conditions* 7* To achieve wide dissemination of information on technical developments and ac complishments of industry; maintain suitable relations with technical socie ties, professional organizations, trade associations, and such other groups as issue publications reaching persons concerned with water pollution problems. 8. To aid in promoting training activities to increase the operating efficiency of waste recovery and treatment systems employed by industry* 9. To perform such other technical tasks relating to industrial wastes as neces sary to stimulating improvement in the quality of the nation's water resources. As presently contemplated, a large portion of the technical work of the Committee will be performed by work groups composed of the best technical talent from those in dustries sending representatives to the Committee. It is anticipated that by bring ing together industriea which have what might be termed a community of interest-in so far as wastes are concerned--duplication of effort and needless expense can be minimized. Likewise, those groups best equipped and staffed to conduct studies along certain lines could advantageously be assigned those tasks* The exchange of data and information of a fundamental nature--information which can be applied by the partici pating industries to their individual problems--will be encouraged. It is not proposed that these activities will in any way conflict with or replace activities that already have been sponsored, organized and financed by various indus tries. As a typical and fundamental problem, for which there is pressing need, there is the question of "yardsticksI11 of pollution for all water uses* This is a technical problem which in one way or another affects all industires discharging wastes into natural watercourses. It is an example of but one of the many technical tasks which require vido consultation and general agreement. The answer appears to lie in close working relations--in teamwork* I understand that industry committees have been established in the automotive, beet ragar, canning, chemical manufactaring, coal, dairy, distilling, electric, electro plating, fermentation, gas manufacturing, iron and steel, meat, petrleum,pulp and paper, tanning, textile, non-ferrous metal and rubber fields. Ho doubt there are others. I have here a copy of a Beport by the Waste Disposal Task Committee of the Dairy In dustry Committee. Quoting from the introduction of the Report; "The dairy industry has two important stakes in prevention of waste. The first is the direct savings 40 . foliar8 that too often go down the drain unleea a complete system of waste pre* ation is adopted. Die second is compliance with increasingly strict regulations, ^-ticularly in regard to stream pollution. There again, a complete system of waste fetention is a dollar saver." The Report goes on to cover the seven points where reduction can he made. These points ares (l) leakage (2) overflow (3) spill* 9 (k) freezing on (5) willful waste (6) residual waste (?) carry over. Causes of ggte are enumerated and remedies are prescribed. I am asked this morning to give * 0eral trends regarding industrial wastes. I think the most notable trend is not building of treatment plants but rather the establishment of waste prevention raCticee within the plant itself--good housekeeping, if you please. In many cases Lod housekeeping measures are merely preventive maintenance which should be followed to keep the plant at peak operating efficiency. The cost of such simple measures is and the results may show a saving. One of the reportedly unsolved industrial ,,gBte problems in this section of the country is that connected with the citrus can1Dg industry. I have, however, seen crushed fruit from the unloading bins flushed t9 the sewer with water. If the industry wished, such wastes could be removed dry tgas alleviating the load thrust upon our streams. ^t me enumerate a few developments in industrial waste treatment. An outstanding example of pollution control in the chemical industry is found at the Midland plant 0f the Dow Chemical Company where some 200,000,000 gallons of waste water must be disposed of daily. Brines are stored in huge ponds and released during periods of ligb flow. Clear waters are discharged direct to the river with careful control of graporator losses. Special wastes, unfit for storage or biological treatment may be recirculated, treated with activated carbon, steam-distilled, and extracted or oxi dized with chlorine; inorganic acid wastes are controlled to fit the alkalinity of tie river. Phenolic wastes are treated by acidification, settling, equalization and tiological oxidation after dilution. General organic wastes of 50 MOD are treated ty screening and the activated sludge process. Truly this is a fabulous pollution ontrol undertaking. fhe treatment and disposal of waste soluble oils have been extensively studied at Kichigan State College. They found that emulsions can be successfully broken with calcium chloride and the resulting water layer can be clarified, by flotation and tattling. BOD reductions from 98.3 to 98.8 per cent can be obtained. The treatment:f waste soluble oil is desirable even though the quantity is small. he canning industry is learning that their water consumption can be cut as much as 5Q# by re-use of clear waters.* Screening of all wastes and the elimination of open trains reduce the "garbage" which adds to the pollution load. Lagoons for disposal of cannery wastes are being increasingly used* Sodium nitrate is applied to keep the lagoons from becoming septic. he pulp and paper industry through their national council for stream improvement are vigorously attacking one of pollution abatement's most difficult problems. Screening !i employed to remove fiber chips, etc., and is of substantial value to stream im provement. White water wastes from paper machines are being recycled with a sub`tantial saving at an increasing number of mills. Sulphite waste liquors are being `tailed for methods of utilization and disposal. Utilization of the liquor as a n&d binder, as a briquet binder, aB an adhesive and as a material for alcohol pro tection has been studied. More recently, investigations have been mads for biologkal utilization of carbonhydrates in reducing the oxygen demand. Todder yeast can grown using both fermentable and nonfernentable sugars for food. At Longview, 41 sbingtoa( a mill scale study has heea inaugurated on a process that uses magnesium gther than the usual calcium base of cooking liquor. A recovery system for magneriuo has been provided in which the waste liquor is concentrated then burned for re*laiming the fuel value along with the base for making new cooking liquor. Results bus *ar are a CffUSe for favorable comment. This week I learned that chemists at the diversity of Texas have found that sulphite wastes can be made to produce paracymene. fbis by-product can be converted to para alpha dimethyl styrene. It can replace styreae that combines with butadiene to make synthetic rubber. The paper pulp industry 19 expected to be willing to install necessary recovery equipment for the cymene by product if it would be utilized in large amounts. A report from the rayon industry indicates that acid wastes from viscose rayon and cellophane manufacturing plants are neutralized with lime, settled, treated chemical ly for the recovery of valuable constituents and discharged to the streams without Usance. The sludge resulting from neutralization is very bulky as it comes from clarifiers and its disposal is a costly item where large areas are not available fiear the plant site. One plant ships the sludge 6 miles by railroad and another is considering barging it to sea. In most cases the sludge is dewatered on vacuum fil ters to reduce the volume. Other wastes from these plants have a relatively high cjtygen demand, because of organic and other materials, and are treated biochemically. Vestea resulting from the manufacture of acetate rayon lend themselves to biological treatment and can be handled on trickling filters. The activated sludge process is too sensitive for these wastes because of fluctuating chemical composition, X eight go on the cite studies and developments in the utilization and treatment of tannery wastes; sugar manufacturing wastes; packing house wastes; distillery wastes, etc., but the technical periodicals and trade Journals are replete with this type of information. 1 think you will agree from your personal knowledge and the foregoing examples that there is a definite move by industry to eliminate their industrial vastea or to render them inoffensive prior to discharge to our watercourses. Before I leave this subject, may I point out another trend. I am referring to the employment by industry of technically trained chemists, biologist, and engineers for pollution abatement work. These people understand the importance of pollution abate ment. They understand the difficulties Inherent in treating a trade waste. They bring management closer to the regulatory bodies. And, finally, they spearhead the pollution abatement program for industry, I have been asked to give the general trends regarding State pollution legislation. This is rather a large order as we are presently in a state of flux regarding State legislation. More than half tha> States have adopted new or strengthened existing State water pollution control legislation within the last decade* State water pollution control legislation developed traditionally out of the authori ty of health departments to preserve publio health. In conjunction with thle there vas piecemeal lodging of concurrent water pollution control authority in several other departments of State governments such as those dealing with agriculture, fish and vlldlife, and mines and minerals which also had an interest in water pollution control The modern approach to the problem is reflected in recent State statutes whose object le to preserve and improve water quality for all legitimate uses and do this through agency that represents all affeeted interests in the State. Accompanying this tas been a shifting emphasis from the mere abatement of existing pollution to the pol icy of preventing pollution in its lncipiency. 42 rg the past, the administrative approach, which has set up a single administrative acy, has been largely negative in character* That is when a particular action 40 been found to cause pollution the administrative agency has taken steps to abate 0^ch pollution* With the development of comprehensive programs, classification of vstera, and standards of water purity for water use, administrative programs for water gllution control can move toward a more positive phase* Hot only can the present use of a particular portion of a stream he classified and maintained, hut future water uees may he decided upon, after consultation with community and other interests, and 0 program instituted to bring the quality of the water up to meet the requirements of tbeee new uses* If you will examine the legal responsibility for stream pollution control today you ylll find that twenty-five States vest the State Department of Health with the major part of their program, Typical of these States are Texas and Oklahoma in the South 's t, Colorado in the Mountain States, Arizona in the Vest, Iowa in tha Midwest and Ifessachusetts in the East* In various of those States other agencies are charged vith specialized authority over water pollution* Some other States have divided water pollution control authority among two or more State departments and in some eases have placed their major water pollution control getlvities in State agencies other than the State Health Departments, However,some residual authority is retained by the Health Departments and ean be exercised where health is concerned. It is interesting to note that California recognizes pollution aad contamination* Contamination in (hlifornia means "injurious to health" and the responsibility for its abatement rests with the Health Department* Pollution on the other hand consists of trade waste and domestic sewage and its control is handled by 9 regional boards* Twelve States have set up single State agencies for water pollution control in which the Health Department plays an important role* Some of these agencies are developed within the Health Department itself but having an advisory board of elected State officials and interested water users* In some, the State Health Officer or the State Sanitary Engineer is chairman or executive secretary of the agency* In most of this group the active work of the agency is carried on by State Health Department person nel. Typical of States having this type of organization are Minnesota, Illinois, Oregon, Tennessee, Alabama, Kentucky, and Hew York. Die method of developing the Hew Tork pollution control legislation is of interest as it was somewhat unique. A proposed law was drafted and placed on record by intro ducing it before the 1948 Legislature. In order to give full opportunity for cooper ative study of the biil's provisions, it was not moved for passage at that time* The next twelve months were devoted to fringing the matter to the attention of municipal and industrial officials and other Interested partiee* After their comments were reviewed and weighed by a special sub-committee, the bill wae redrafted to include those suggestions which were found to have merit* The law has as its pupose the safe guarding of Hew York1s waters by preventing new pollution *nA Abating existing pol lution* Toward this end it requires the Board, after proper study and hearings, to establish water quality standards and classify the waters of the State in accordance with considerations of best usage in the interest of the public and with regard to recognised engineering and scientific factors. The lav specifically recognizes that no single standard of purity is applicable to all waters; that waters will vary in quality depending upon the nature of the streams, the character of the area and the nee to which the waters are or will be subjected*- Tha lav also recognises that all oS cannot "be converted into trout waters or sparkling drinking water, but rather *{f watera of the State mat be preserved for their most reasonable use in the inter- of the public* York pollution lav not only gives the pollution eontrol agency pover to abate ^uution but actually spells out many of the agency's specific duties and much of e procedure that must be followed in administering the lav. California legislation, a series of 11 bills, was introduced in brief form by the ter Pollution Committee at the start of the session and developed to final fern fter lengthy hearings and meetings with representatives of all interests concerned f these problems. The new lavs therefore were developed out of a sincere coopera* e effort and the measures are designed to continue that cooperative action in the ,tiaate solution of this complex problem. In New York the pollution bill was intro duced in full,, laid aside for a year for study by all concerned and then revised. In jalifornia the bill was introduced in brief form and developed by the cooperative (fforts of all interested parties. fbe California lav empowers State and local health officers to issue preemtory orders for abatement of conditions of contamination. Contamination is defined to mean "... gu impairment of the quality of the waters of the State by sewage or industrial waste to a degree which creates an actual hazard to the public health...* The term nollution and nuisance are defined in the Act to mean the adverse and unreasonable effects Jfdiaposal of sewage or industrial waste which are not actual hazards to health*.. Pollution and nuisance are subject to control by Regional Water Pollution Control* Boards which are created for the 9 major drainage regions of the State. The regional boards are composed of five appointees representing the major interest involved. A State Water Pollution Control Board is created, consisting of the State Engineer, the Directors of the Department of Public Health, Agriculture, and Natural Resources,and 9 appointees representative of the regions of the State and of the various interests la these problems, lhe State Board has the duty to undertake Stated-wide planning for pollution control, acting in an advisory capacity to the regional boards. It will direct research programs in the technical phases of pollution control, and will admin ister the State Water Pollution Control fund. The State Board may act as an appeal board in any specific instance of pollution where it is found that a regional board has not taken proper action. The Water Pollution Control Act (Public law 845, 80th Congress) statest "The Surgeon General shall.. .encourage the enactment of uniform State lavs relating to water pol lution...." Accordingly the Public Health Service is recommending certain general considerations in the development of such State legislation. The Public Health Serv** lee clearly recognizes in making such recommendations that each State has different problems and different approaches to these probleme and that each State should work out the details of its particular water pollution control program. The general conraiderations recommended are in parti 1. A single State pollution control agency 2. No exceptions from agency jurisdiction. 3* Agency to represent all wateu users. 4, Agency to develop comprehensive water pollution control program which would include setting standards for water purity. 5. Enforcement of agency rules, regulations, and decisions. tor those States who do not wish to prepare a new law from scratch, the Public Health 44 / 81ffiine0trohdasucdtieovneloinpedStaateSulgeggeisstleadtuVraetse.r Pollution Control Act which will he suitable A draft of this Suggested Act was submitted States, industry, and numerous individuals for comment. After consideration of ( comments received, the draft was revised and submitted to the Council of State ^ernments for consideration at its October meeting. As a result, the Council has Versed the Suggested Act and recommends it to States for favorable consideration, /hereas in the past it has been the practice for one State to study the laws of other tat08 ln detail an& combine those items considered good into a new law, a bill is s available which represents the collective thinking of a large group of experts in and engineering. also might be well to point out the consideration being given by States to the atter of financing waste treatment facilities. Cne of the stumbling blocks in se eing pollution abatement is the inability of political subdivisions to finance aeeded sewage treatment works. Many States have eliminated this difficulty by enact ing legislation which permits adequate financing by revenue bonds. Such financing uga received an increasingly broad reception in recent years. Some States also pro-- ride financial assistance to political subdivisions. California has a $1,000,000 revolving fund for loans to municipalities for constructing sewage treatment works, jew York has a legislative committee studying ways and means of State financing and gev Mexico has a provision whereby the State will purchase municipal bonds that cana0t be marketed elsewhere. H I see the water pollution control picture today the trend line is sharply upward. Industry is making great forward strides, better laws are appearing, public senti ent is behind the movement--we are on our way. 0O0 f. 45 Industrial Vastes and Pollution Panel "WHAT INDUSTRY EXPECTS PROM THE STATE REGULATOR! BUREAU IN THE CONTROLLING OP INDUSTRIAL WASTES" Hayden W. Head Attorney for Celanese Corporation of America and Southern Alkali Corporation Auatin,Texas discussing the subject "What Industry Expects from the State Regulatory Bureau in Controlling of Industrial Wastes," I feel compelled to preface all remarks by saying that the views expressed are not necessarily those of my clients, but on the contrary, represent the individual views of the speaker as formed by some experience more observation* I should explain that I am engaged in the general practice of iav and the fact that your program lists me as attorney for the two companies named cones as a result of a request from the program chairman that I be identified as representing the named clients in order that my remarks would have more authority than would be the case if I had no clients. However, I insist again that nothing I say, 001688 it should happen to be beneficial to their interests, should be imputed to them. Row that I have out of the way this protective disavowal of anything detrimental, which is done in accordance with all good editorial standards today, I feel free to proceed with my remarks on the subject assigned. is a background to enable us to consider logically any matter concerning waste dispo sal, it is necessary that I briefly refer to the present laws of the State of Texas which concern pollution. We have two anti-pollution statutes. One is a criminal statute. Article 698b of the Texas Penal Code, and the-other la a civil statute which allows the state regulatory authorities to prevent pollution by injunction, this be-: , ing Article Wth of the Texas Civil Statutes. Under these laws, the Texas State Health Department is the state enforcement agency except where fish and marine life are affected, in which event enforcement is vested in the Texas Game, Fish and Oyster Commission. Other state agencies are in minor degree concerned with various aspects of pollution, but for all practical purposes, the Health Department and the Game,Fish and Oyster Commission are the two regulatory agencies dealing with pollution matters, and in speaking of the state regulatory agencies with which wa are hera concerned, I refer to those. The tvo statues mentioned are very brief and the essence of each is simply that there stall be no pollution of any public waters by any person, firm, corporation, associa tion, town, elty or other political subdivision of the state. As an example of the type of injunction that can be rendered under Article I refer to the language used by the court in the injunction issued in the case of Marvin Petroleum Company T* State. 218 S.W. (2d) 855. where the defendants were enjoined from "throwing, cast ing, discharging, or depositing, directly or indirectly, salt water or other pollut ing substances ... in the San Marcos or Guadalupe Rivers." You will note that no roferenco is made to any permissible quantity or degree of salt water allowed to be discharged into the rivers mentioned, but on the contrary,, the decree- literally pre dated the discharge of any salt water into these streams, regardless of quantity. It Bight be said that our statutes constitute a simple commandment that there shall be no pollution. U6 Oold not be possible for any regulatory agencies to enforce any pollution statutes greater efficiency, understanding and result than have the Texas State Board of ^ 1th and the Texas Game, Fish and Oyster Commission in their administration of our ^**gnt statutes. Under the leadership of Dr, Cox and his associates in the Board of ^Ith and of Mr. Dodgen and his associates in the Same, Fish and Oyster Commission, 8a has come to rank high in the Nation in pollution control. These agencies hare l8tently gone more than half way in meeting municipal and industrial needs,where e opportunity was afforded them to do so, and hare evidenced the broadest possible ^Lyehension of problems of waste disposal confronting both municipalities and Indusis** They have not been extremists. Rather, they have encouraged civic and industr,al development while at the same time demanding that our public waters, in so far tr possible, be maintained in Class A condition* this connection, I should also like to commend the Office of the Attorney General f Texas in its participation toward enforcement of our anti-pollution statues when jelled upon by the regulatory agencies to do so. I have developed a particularly hub regard for Mr. Valdrep, the Assistant Attorney General who for the past few ftars has been charged primarily with the representation of the regulatory agencies these matters, end it is my feeling that he has been and is a valuable member of tbs regulatory team which has achieved such splendid results in Texas pollution con trol* In some specific instances, of course, as a result of factors beyond their control, the regulatory agencies have not been able to accomplish all that they would have iesirsd in obtaining stream purity. An outstanding and ever present handicap con fronting them is the financial inability of various municipalities to make adequate provision for the treatment of municipal sewerage. Naturally, the state regulatory agencies, as a practical matter, cannot compel a municipality to construct necessary treatment works when the municipality has no money with which to do it. existence of such problems has brought into being a necessity that the regulatory agencies not look upon our statutes literally in order that they make allowances for situations affecting certain streams which do not presently carry water of the type and purity on which the regulatory agencies strive to insist. The Trinity River in the Fort Vorth-Dallas vicinity is no doubt the worst pollution condition existing $.n the state today, but as a result of constant encouragement by our regulatory agencj.es, there presently are plans for additional sewerage facilities at all towns discharging sewerage into this river which, when carried out, will have a tremendous effect toward Improving, and possibly, eliminating this condition. By a process of applying a prac tical program of encouragement, rather than an impractical attempt at force, the reg ulatory agencies will achieve an end that could never be achieved by literal applica tion of the statutes. True wisdon has been shown in the administration of our anti pollution laws* In the same manner, our state regulatory agencies have exercised the same wisdom in applying Texas anti-pollution laws to Industrial development. By taking into conoidaration the benefits derived from permissive use of certain water courses for indus trial waste disposal* the regulatory agencies have again looked to the practical, aa distinguished from the literal, administration<f our present pollution laws. At theaaa time the regulatory agencies have continued, to encourage more efficient treat-- of the waetes discharged into such streams. The result has been of great benefit to our budding industrial development, which in turn has been of such great benefit to the people of Texas generally* 47 I do 'believe that any Industry can sincerely maintain that it has been treated fairly by our state regulatory officials who administer our present anti-pollution lfjWa. Bather, I submit on the contrary that any industry which desires to partake j3 any cooperative effort toward efficient disposal of its industrial wastes will find ready and willing assistance when it approaches the Health Department or the Game, and Oyster Commission. For some reason, how ever, it has been, and is still ^e, that for the most part industry is reluctant to attempt cooperative solution of Its waste disposal problems with the regulatory agencies and the result of this fail le is often misundertanding, which leads to further intensification of existing problems. I think it possible that one reason for industry's reluctance to approach tbe regulatory agencies is the fact that no authority is given these agencies under 0ur present law to approve any plan for waste disposal that does not call for complete purific&tion of - such waste, regardless of dilution in the stream into which it is discharged, with the resultant feeling on the part of industry that a change in attitude 0q the part of regulatory officials might render useless efforts to dispose of waste lo a manner previously acceptable. In spite of this, however, I strongly urge that industrial officials take up with the regulatory agenoies their plans for industrial waste disposal prior to placing such plans into operation, for I know of no instance vbere prosecution has resulted from pollution caused by discharges made as the result of disposal plans previously submitted in good faith to the regulatory agencies and accepted by them as satisfactory, even though in actual operation the installed sys tem proved unsatisfactory. In each such instance, remedial revision of the disposal system is required but prosecution is avoided. To industry generally,there are two notable omissions in our Texas laws today. The first is the failure to provide permissive legal authority to the regulatory agencies to allow streams to be used for municipal and industrial waste disposal where the pub lic benefit outweighs detriment, even though pollution occurs. As mentioned previous ly, in actual practice this is being done today but is the result of sanction and pol icy, rather than law. The second omission in our Texas law is its failure to require the submission of plans for waste disposal systems to our regulatory agencies with corresponding authority given to the agencies to approve such plans and permit disposal in the manner thereby provided. In actual practice, this, too, is done today as a matter of policy but it has been my observation that industry inclines toward legal, rather than administrar* tive, approval of such practices. In this connection, I believe that the Model Water Pollution Control Law discussed by Mr. Poston, which has been submitted by the United States Public Health Service to the regulatory agencies of the various states deserves some discussion from the stand* point of industry. This law was prepared and has been proposed as a result of the fact that three years ago Congress passed the Federal Water Pollution Control Act, among other things, directed the Surgeon General of the United States to encourage the enactment of uniform state laws relating to water pollution. The Model Water Pollution Control Law, which is lengthy and detailed, provides for the two situations mentioned previously as lacking in our Texas laws which are of primary concern to Industry. It requires the state regulatory agencies to group the designated waters of the state into classifications in accordance with considerations of best usage in the interest of the public. Such standards may, from time to time, be altered or modified by the regulatory agencies but the purpose of such a provision is explained in a commentary prepared by the Public Health Service which accompanies the proposed law, in the following languages 48 ification of waters and the setting of standards are to he accomplished Cl**8,tar public hearings are held. This will allow the representation of ooV before any classification of standards is promulgated. The lndusal1 **^<1 municipalities in any particular locality will be able to determine tf*eS H$y of effluent they must discharge into the streams in accordance tb*^guch standards. This will create a definiteness of criteria for water witj tioQ which has often been lacking in the state statutes." osed Model Law also requires that plans and specifications be submitted to ^rte regulatory agency for its approval or disapproval of proposed waste dispot&s st sewerage treatment works. If such approval is given, a permit is issued to il 83 ]4Cant to discharge waste in accordance with the conditions of the permit, th* a\l a9 this is done, there is no wilful violation of the statute, and although So and specifications may in practice after installation prove unworkable to tb" p extent that their use must be halted until modifications are made which will "tt* with required standards, still the industry concerned is not in the position eO0LriBg undertaken wilful pollution after having secured state approval of itq. facility. la not oy purpose to plug for the adoption of the Model Water Pollution Control ia Texas but I mention it here as being an authoritative proposal of considerable i^rrent interest which finds acceptance on the part of industry generally as to the features discussed. I do think that it gives legal approval of the policies nqV teing followed to some degree by our own regulatory agencies with signal success. However, objections have been raised to the adoption of the Model law in Texas, Our state regulatory officials feel, and justifiably so, that the results achieved by them in their administration of our present laws have been outstandingly successful. Another argument in opposition is based upon the mandatory burden of additional work ^fiat it would impose upon the already limited facilities of the state agencies. Still another argument which has been expressed against it is that the use of a stream pursuant to a lower classification than Class A might prevent future industrial de velopment upon and use of that same stream by new industries. However, in answer to these arguments, it has been said that legal policy is preferable to administrsv tive policy, that such a program is necessarily long-range, that complete classifi cation of all streams would necessarily oecnr only over a period of years and that anticipation of future needs for the waters of any particular stream would be a car dinal factor in determining the class of use into which that stream should fall. Finally, the thought necessarily occurs that Texas is only now arriving at a point in its industrial development which requires a more comprehensive pollution statute than those presently in existence in our state. I think it can be said that Texas industry generally expects these things in state regulatory control of industrial wastes: First, industry expects to receive the same relative treatment accorded other enti ties who find the use of our public waters necessary to their survival. Second, industry expects to be given, in so far as is possible, the definiteness of criteria recommended by the Public Health Service in its commentary accompanying the proposed Model Water Pollution Control Act. Whether this definiteness of criteria be gained by the adoption of standards of classification and by the issuance of peiv mits after the submission of plans for waste disposal systems, or whether it be 1*9 ed by some other means, is immaterial to me personally but 1 believe that indus^generally expects a definiteness of criteria that is presently unobtainable in trf absence of permissive legislation. (ji <rii industry exPect8 the same attitude of enforcement toward ary pollution control ^ t &as tjeen displayed so admirably by the personnel who presently constitute our ^te regulatory bureaus concerned with pollution matters. If industry could be as*t$dd that Dr. Cox, Mr. Eerzik, Mr. Ehlers, Mr. Smallhorst and their associates in sflr Health Department, and Mr. Dodgen, Mr. Faubion and their associates in the Game, and Oyster Commission would be with us forever to administer our present pollu(1)0 I doubt that industry would ever feel that it might be necessary to pro* ,e by laws the same policites that have been established by them over the years. * ftainly, no law could accomplish more than these departments have accomplished '^er our presently existing laws. keystone of any successful program in waste disposal is cooperation between in' try and the state regulatory agencies. To my certain knowledge, industries facing appeared to be almost hopeless and insoluble problems of waste disposal have round solution to such problems in the assistance given by our regulatory agencies, j feel that this same attitude of helpfulness would be met by any industry which |Pproached these departments with a genuine attitude of cooperation and that lndus,rjr would be amazed to find in the state regulatory agencies such broad understand ing of the problems which confront it in wacte disposal, for our agencies encompass , concentration of knowledge and information which exists nowhere else in the state, help thus given and the understanding gained is invaluable. la conclusion, I should like to say that my subject today is by its very nature some4at intangible but I have endeavored to treat it with the gravity which it deserves. It would have been relatively easy to answer the question "What Industry Expects of the State Regulatory Sureau in the Controlling of Industrial Vastes" by answering rather briefly "Industry expects to be let alone," but since this is only a false ope, as distinguished from an unjustified expectation, I hare not so answered. Thank you. 50 "WHAT INDUSTRY EXPECTS PROM TEE STATE REGULATORY BUREAU HI THE CONTROLLING OP INDUSTRIAL WASTES" H. E. FauMon Assistant Executive Secretary Game,Pish and Cyster Commission Austin, Texas it apPrec*ate ^he reference made to the Game, Pish and Oyster Commission in the paper u9t read hy Mr. Head. Coming, as it does, from a representative of industry, we Jeel deeply grateful. M early as i860, the Legislature of Texas, in keeping with the spirit of that section gf the Constitution, which designates all rivers and streams natural resources, enaeted a law which made it a penal offense for any citizen to pollute or obstruct any ater course, lake, pond, marsh or common sewer to a degree that the water would he rendered "unwholesome or offensive" to the inhabitants. The penalty for a violation 0f this Act is a fine in any sum not exceeding $500.00* lodustrial development in Texas in recent years brought with it pollution hazards *hich caused the Legislature to enact a more drastic anti-pollution statute in 1925. ijbis law made it a penal offense to pollute any water course or public body of water by the introduction of crude petroleum, oil or other like substances; or to introduce directly or indirectly any sewage or unclean water, or unclean or polluting matter or thing into a stream or public body of water used for farm livestock, drinking or do mestic purposes. A violation of this Act was punishable by a fine in any sum not less than $100.00 and not more than $1,000.00* Six years later, the Legislature, keeping in mind that provision of the Constitution which declares the "preservation and conservation of all natural resources to be public rights and duties", enacted a third anti-pollution law to protect the public rights to the use of public property. By this time, industrial development had made strides unparalleled by any state in the Union and pollution hazards had increased by at least tonfold. New oil fields had been discovered in North, East, West and South Texas. Ninety thousand oil wells (we now have about 125,000 wells) were in pro duction and fifty per cent were producing salt water. More than six hundred cities, towns and communities were burdening the public waterways with 200,000,000 gallons of untreated or partially treated waste. Industry was contributing liquid waste in vast quantities possibly equaling that contributed by municipalities. Ibis law was Article 698-a and was cumulative of the law enacted in 1925* It made it a penal offense to pollute a water course or other public body of water by the intro duction of cruda petroleum, oil, acid, sulphur, salt water, oil refinery waste or oil refinery waste or oil well waste, and fixed the penalty for a violation of the Act at Mt less than $200.00 nor more than $1,000.00. It also provided that the introduction of salt water into a stream in excess of 2,000 p.p.m. would constitute a violation of the Act. These-statutes were being equitably enforced by the Game, Pish and Oyster Commission. But the tragedy of the story is that because of a conflict in the penalty clauses of the two statutes, both laws were eli to be inoperative by the Court of Criminal Appeals on January 27, 19*0, when a ease went up on appeal from a county where a conviction had been on a complaint 51 el*rSin violation of Article 698-a the opinion was handed down by the Court of Criminal Appeals on January 27th, t^Le the Game, Fish and Oyster Commission was powerless to aid other State agencies in the prevention of pollution. iy in January of 1943, after the 48th legislature had convened, with the sanction the Governor, a meeting of representatives of the Health Department, Bailroad ^^gaion, Attorney General, Board of Water Engineers and the Game, Fish and Oyster fission was called to draft a hill to he presented to the legislature for enactCo to control pollution in Texas. The hill was amended several times after the first draft, at the suggestion of representatives of some of the larger cities and f e industrialists. The hill in its final draft was passed and signed hy the GovefOor on May 8, 1943. .Mg law makes it unlawful for any person, firm, corporation, association, town, city t other political subdivision of the State, or any agent, officer, employee or rep resentative of any person, firm, corporation, association, town, city or other polit ical subdivision of the State to pollute any public body of surface water. i<be Act defines "pollute" as the throwing, discharging or otherwise permitting to r reach or to he introduced into any public body of surface water, any substance, mate rial or thing in such quantity that the water into which it is introduced will be rendered unfit for one or more of the beneficial uses for which it was fit or suitable prior to the introduction or that is rendered harmful to public health, game birds or game animals, fish or other edible aquatic animals, or that endangers any wharf, hin ders operation of any boat, or renders any bathing beach unclean or insanitary. The term "public body of surface water" as defined by the law, includes all surface creeks, rivers, streams, bayous, lagoons, lakes and bodies of surface waters fed by a stream or that are subject to overflow from or into a stream which are the property of the State or a subdivision thereof; also all portions of the Gulf of Mexico within the gulfward boundary of the State and all inland waters in which the tide ebbs and flows. Texas today has an oil field on the watershed of all the major waterways of the State, and Industrial plants are located on the lower reaches of most of these streams. A high salinity in the streams would be as hazardous to the operation of these plants and the production of war materials as a strike in the coal mines would be to the production of steel by the steel mills. Ve must not permit the introduction of any substance or thing into our streams that will retard development or interfere with the growth of our great Commonwealth. The enforcement of that section of the pollution law which has to do with the protec tion of game and'fish is the responsibility of the Game, Fish and Cyster Commission. Vhen a health problem is involved, the enforcement becomes the responsibility of the State Health Department. In extreme cases, injunctive relief may be had under Article **444 of the Civil Code if the criminal statute does not afford immediate permanent relief. These two departments act jointly with the Attorney General when a suit is filed seeking injunctive relief. It is our candid opinion that the above statute delegates ample authority to the State agencies charged with its enforcement to safe guard all of the interests of the citissns of the State. Cur pollution problems in Texas are so varied that a uniform law for all the States would not be adequata In 52 . and. it would be difficult to enforce because of certain features of the pro* p I**' a ]_0ng period of tine, the StatB Health Department and the Game, Fish and Oyster '^^ission. have been closely associated in the enforcement of the pollution laws, <'hLiin& *rom time to time technical information and advice between the regularly e*Cl0y9d specialists of the Health Department and men trained in the technique of ^^pollution work and law enforcement in the Game, Fish and Oyster Department with- any additional cost to the State* By our combined efforts, we have kept the pu^l lic waters of the State fit for the many uses for which they are intended* public generally, including municipalities and industries, has been apathetic vrd the aPPeal sportsmen's organisations, nature lovers and other unselfish or*Lii*ationB leadinS the campaign in Texas for clean water and the conservation of our tufal resources. Opposing these efforts, some have said: "What are a few fish "trth compared with our industries?" Fishing and hunting is big business in Texas, too* More than 320,000 resident citizens of the State buy hunting licenses each year 1*315,000 citizens purchase fishing licenses* Ibis does not take into account, tbose vho hunt on the land on which they reside or fish in the county of their reel** 4encs without licenses* These same hunters and fishermen spend annually in Texas $200,000,000.00 for fishing tackle, guns, ammunition, food, gas, hunting leases, jlothing* etc. The commercial fishing interests on the Texas Coast have investments in fishing gear jod equipment running well into the millions of dollars and the annual catch of edi ble fish and shrimp is worth well over $25,000,000.00, The landing of fish, shrimp, crabs, and oysters on the Texas Coast last year including menhaden totaled 85,233,237 pounds. These compilations do not take into account the recreational and aesthetic ralue of clean water to the thousands of our citizens who neither hunt nor fish. If Buniclpalities and industrialists of Texas could come to a realization of the value of clean water not alone because of those who hunt and fish and enjoy the outdoors tat as pollution affects their own public relations, we think the problem could be tolTsd more easily and more economically. Cities, towns and communities oust provide pure water for their citizens. Industries require clean water for the operations of their plants. Rice growers, stock raisers and other interests must have clean water or retire from business* This being true, ve feel that it is the duty as well as a privilege for industry to join with our law enforcement agencies in a campaing to abate pollution and keep the public waters clean. Certain.plants in the Houston area have already spent approximately a million dollars this year on waste purification systems. Large appropriations, we understand, to make additional improvements in 1951 have been authorized* In the past, the Game Department has enjoyed the confidence and had the cooperation of a very large per cent of the industrialists of the State and to this relationship vs attribute much of our sttceess in the enforcement of the pollution laws* But until those who violate the law with impunity amend their attitude toward the enforcement f the pollution laws, our efforts to keep the public waters of this State clean will not be fully appreciated* field brine, domestic sewage and industrial waste are all problems separate and opart from each other. Vith the proper approach, expenditure of the necessary funds ud the aid of competent sanitary engineers, chemists, efficient game wardens and 53 etber experts in the field of research, these problems can and will be solved. If you have a pollution problem, it is your responsibility. Don't wait until the Gams Department or Health Department representatives start an investigation to do some thing about it. Game, FiBh and Oyster Commission is concerned primarily with that section of the which concerns the protection of fish and other edible aquatic animals in the gtreams, lakes, ponds, bays and the Gulf of Mexico, co-extensive with State jurisdic tion (3 marine leagues or 10^ miles). However, it is no-t difficult for the average dayman to understand that water polluted to such a degree that it will not sustain fi9h life is definitely unfit for human consumption and for all other purposes in cluding industry tfe trust that the fair and impartial manner in which the pollution laws have been ad ministered by the Game Department and the Health Department merits the approval of you who represent industry. Ve invite your cooperation in our efforts as servants of all the people to render the most efficient and the most helpful service possible. 0O0 54 "WHAT INDUSTRY EXPECTS PROM THE STATE REGULATORY BUREAU IN THE CONTROLLING OP INDUSTRIAL WASTES" G. R. Herzik, Jr., C.E. Bureau of Sanitary Engineering Texas State Department of Health Austin, Texas certainly takes a brave soul to follow speakers of the caliber of Mr. Head and L yaubion. Mr. Faubion was silver-tongued enough to be elected to the State Legis lature at one time; and Mr. Head is a pillar in a profession that has as a primary ^requisite, the ability to sway a jury to his way of thinking. And here am I -- r p00r but honest engineer, who frequently can add 2 and 2 and get 4, but can't telj, Tou why. But I think I can gather together enough words and arrange them in proper Sequence, to express to Mr. Head my appreciation for his kind words regarding our ministration of existing anti-stream pollution laws. ;or many years we have realized that in the enforcement of a law -- any law -- its popularity will determine, to a great extent, the degree of success with which it eafl be enforced. It follows, then, that the mere passage of a law by the State Legis lature, or the National Congress, does not necessarily solve the problem forever gfter. You may recall our experience with National prohibition, and even with our ovn Sunday Blue Laws. Frequently, failure of a law to receive popular support is due to lack of knowledge regarding its need or desirability, and the problem of the en forcing agency then becomes, to a large extent, public education. This has been true^ la a large measure, with regard to anti-pollution activity in Texas. The demand for anti-pollution activity now is certainly greater than it was when I started with the Health Department 13 years ago. No doubt the demand 13 years ago was much greatsr than it was in 1915. when the first State Sanitary Engineer became associated with the Texas State Department of Health. Although some of this demand can be attributed to deterioration of stream conditions, I am of the opinion that by far, the greatest Impetus haa been produced by the present wide-spread public knowledge of those things involved in keeping our streams clean. Problaly not all'of you realize that the State Health Department and the Game, Fish and Cyster Commission have been engaged in water pollution control activities since 1915, and with these 35 years of experience behind them, they feel that their pollu tion control programs have been developed along sound and practical lines. In this connection, however, we are sometimes mildly astonished to note that there are occa sionally individuals, organizations, and even industries in Texas, who are not aware that these agenelea are responsible for the enforcement of the State's anti-pollution statutes. For many years it has been our policy to encourage municipalities and iaiuatries in providing proper treatment facilities by means of an intensive educational program. In carrying out this program, we have worked very closely with a number of advisory committees composed of persons actually engaged or interested in sewage treatment, water conservation, the development of Texas industrially, or similar groups. These committee* have been helpful in establishing standards and setting pol icies and procedures over the past years. In this regard also, we have adhered to the policy that prior to any legal action being initiated, a formal hearing is held,* vherein the evidence involved is presented, and a period of time Is granted to allow the offenders to demonstrate their intentions regarding corrective procedure. 55 outlie*8 extreme interest in stream pollution abatement, was probably responsible passage of Public Law 845 by the 80th Congress, which recognizes the stream ^nutio& problem on a nation-wide basis, Following the enactment of this law, many tee initiated action to secure new state legislation in an effort to satisfy va^- t8 g groups. Consequently, there have been a number of articles published in newsr*ers and national magazines concerning this "new" trend. We have observed these 4#?ivitie i& other states rather closely, and we have yet to be convinced that our sent statutes, together with our long established policies and procedures, should ^radically revised; although they might be improved in certain respect. We justify line of reasoning by the fact that in our State there is at this time no extent ^ e gross pollution creating a hazardous condition along any appreciable distance { any of our major streams. We frankly admit that there are a few "hot spots" in he State, bqt these areas are, in almost every case, being improved upon, and should wibtin the next few years be practically eliminated. rhe State Department of Health, therefore, feels that, considering the overall picture water pollution control activities over the past years have clearly resulted in maintenance of good quality water in our streams. The fact that other Btatee not previously participated in such an effective program is now evident by the activity being' carried on by many of them, attempting to "clean up" their stream tfhich have practically degenerated to open sewers. We maintain that our future pol lution control program should not require extensive surveys, personnel, conferences, legislation, etc., but instead should continue along the lines we have followed in tbs past. In other words, our activities should not be considered "clean up campaign" bat rather intense maintenance and educational activities, Ve will, of course, continue to give the educational phases of our program much time, on the theory that an enlightened populace will, except for a few recalcitrants,police themselves and thereby reduce the need for extensive police agencies. But for the few recalcitrants, there will always be necessary, a police agency, not so much to bring them into line for anti-pollution's sake, since they, as individuals are gener ally minor contributors to pollution --* but principally for morale purposes of those vho take their civic responsibilities seriously, and do what is necessary because of a sincere desire to live by the Qolden Buie. It is only human nature, and I know from personal experience, that a deep sense of frustration is realized when you attempt to be a law abiding citizen, and then observr on all sidee of you, individuals of a different outlook, who apparently, or let us sa; temporarily, appear to be immune to the requirements of the law. As a matter of fact, there have been several instances where industry itself has suggested to us that le gal procedures be undertaken, in order that each unit of-an industrial group could be assured that they all would be required to undertake the same corrective action; as compared, for instance, to a case where most of the pollutors would make necessary corrections on a. voluntary basis, which, in itself, would be adequate for the correc tion of the condition under complaint, only to have one or more minor individuals in the group then ride the gravy train without any corrective effort at all, Vblle our educational program has been accepted rather enthusiastically by those con cerned with municipal sewage treatment, it has been our experience that industry, in general, has not clasped us to its bosom with the same fervor* The reasons for thin I shall not attempt to explain or understand, but it appears some of the reasons are implied in Mr. Head's paper. But I feel that these industrial health conferences, of which this is the third one, are certainly a good sign that progress in this direc tion is being made. 56 fortunately, in the enforcement of enti-atream pollution laws, we are faced with tbree conflicting philosophies. On the one hand, we have those who want complete treatment in all cases, principally the fishermen and the farmers. On the other hand, we have those who argue for the least degree of treatment possible, into which cate gory fa11 principally the municipalities and many industries. Their primary interest is to save as much money as possible. Finally, we have ourselves, who represent a law enforcing agency who has given to it a law to enforce, established by someone else. It is difficult to justify to a fisherman or a farmer, any leniency in behalf of a municipality or an industry, and certainly it is tedious, and frequently unpleasant, to argue with a municipality or an industry about the need for complete treatment in all cases. Consequently, the literal interpretation of a law, which appears to be as clear-cut as ours, is frequently fraught with misunderstanding, This, of course, brings us to the principle of classifying streams, and using dilu* tions as a means of waste disposals, which principle, we understand, is favored to a large extent by industry. This principle of sewage treatment lends itself to sci entific analysis, but the political, social, and economical concepts involved do not. If an industry wants a river full of pure water, they will certainly be opposed to a brother or sister industry upstream using dilution as a means of sewage disposal. Vs are likewise concerned with the alarming depletion of our ground water supplies throughout the state, which is placing more and more demand upon our surface water supplies. It certainly is good sense to maintain good water quality in our streams, so that they will be available for more Important purposest than waste disposal. The classification of streams to allow a certain amount of pollution results in the quality of the water in that stream being fixed, and such classification will tend to retard further development on that stream where higher water quality than that set by the classification might be required* While it is true that classification of stream can be altered, from what we have learned of this procedure, re-classification is an extremely long, complicated procedure. Established industries along a stream considered for reclassification would probably be required to install more efficient treatment works, and would logically oppose any move for upward re-classification* The State of Texas is still primarily an agricultural state, and consequently, the demands for our surface waters and the thinking of our population, in general, indi cate that our surface waters should be maintained in such condition as to be readily usable, first for municipal and domestic water supplies, and second for agricultural uses. An individual owning property along a stream which was classified to cany a relatively heavy load of industrial and domestic wastes would hardly appreciate the depreciation of property value, as well as the possible elimination of this source of water supply for agricultural uses, Vhile the courts will award to Farmer Jones a sufficient sum of money to enable him to move to a new location, I wonder how many of you can evaluate, in dollare and cents, the sentimental value of the old bomeetead. Apparently the due process of law does just this things; but I know of at least one case where we continue to get let ters ten years later, because the "due process of law" built a sewage plant adjoining the old family farm. While I am well aware that our lawyers talk about balancing equities, it has been my experience this type of jargon seldom satisfies the farmer or fisherman. I personally, do not find it easy to evaluate in my own mind the prin ciple of public benefit versus the harm done, with relation to any source of pollution. 57 . for a definiteness of criteria has 1000 advanced, and ve might point out i88irability of this approach to anti-pollution activity was foreeeen by us occasions, the latest of which was ten years ago* ** t agitation then* as there always is, to change the existing anti-pollution **4 w0 lent our efforts to an attempt to have passed, a bill more clearly n:S pollution in terms of scientific limits* A number of legislative committee g vere held, and if I recall correctly, the mmoost impassioned plea against the 0tiiaf 0f the bill was made by an individual purporting to represent industry, on ifl that the bill did not provide enough latitude and allow independent Judgetb* the part of those concerned with the enforcement of the law* oa hefl through the years we have been eenght between the rock and the hard place. 9 tijnes the wind blows hot, and sometimes it blows cold; and in an attempt to be 9*?eious iq our enforcement efforts, we must continue to keep a thermometer out to ^rfflins which way the wind ia blowing. oentl? the suggestion is made that water pollution control activities be vested ^*08* state agency. I might point out that the present arrangement is, in effect, ** equivalent of one agency. Nr* Faubion, of the Same, Fish, and Oyster Commission, probably agree that his organization, through the local game wardens, has for **- years enforced only that portion of the law concerning aquatic life. Under the jdeting laws, all other pollution matters are specified to be under the Jurisdiction , tbe Health. Department* Legal action initiated by game wardens is under the proflsiofl of 698b of the Penal Code, and ia referred to a local court. The State Depart- of Health And the Gems, Fish, and Oyster Commission cooperate when injunction proceedings are initiated under the Civil Statues. In addition to this, the State jSalth Department has for many years been engaged in establishing water quality standards for municipal, swimming pool, ice manufacturing, food processing, interstate sorrier water supplies, etc. Having established an organization and field personnel palified by education, training, and experience to efficiently perform these duties, It would appear to be poor economy to establish still another agency whose achieve*. Mntt could not be expected to be superior to those now being realized. Frankly, I think we are very fortunate that with all the unguided efforts that has been expended la trying to improve our anti-pollution laws, we still have one as workable as it is* It certainly ie far from ambiguous, and it has been declared constitutional in our worts. Vi are genuinely grateful to receive from Industry, expressions of their thinking in litters concerning industrial waste control. As we brought out in our meeting here lait year, aa well as in our meeting in March of this year at L AM. College, the itate agencies are willing and anxious to work with industry towards a better underitaading of our problems and the ultimate development of a fair, effective, compre hensive pollution control program* Actually, Mr. Head's comments have been the first {oaai official remarks we have received from Industry along these lines, end we find this moat helpful. On this basis, ve would like to suggest that the Industries re presented here as members of the Houston Chamber of Commerce, or as members of the taaa Manufacturers' Association, consider the advisability of appointing an advisory tooaittee to meet with us from time to time In order to foster proper understating *84 possibly bring forth a real program. I personally assure you of our cooperation U such a development, and I sincerely trust some plan may bs developed along these lines. 0O0 58 \ 1950 THIRD GULF COAST R3GI0HAL C0HFSBXHC1 0I INDUSTRIAL HEALTH MAT STOASTS Aiiadsos*oaR. C 3. Ht ^apetoe. 1T* ** uci***' L**lle ^Ifano, 3 ^lliason. I* irterbury, 0. B, Jreryt, William 3. ixelrai* B. A* Baird, M. D ' V. C* BaJdce, 0. M* jalbarrie, A. Barker, David 2. Barron, Miss Ruby /Bartula, R.H., Mrs. Abbey Barlow, Katherine R* _ ^Bertholf, Marjorie Bashor, Harvey /Baa.H*H. .Mrs, Martha Battle, Gilbert Beasley, R. S. x-Becl?, B.H., Basel Beikert, Miss Mary Betts, W.' Doyle Blakealee, Doris Blackwell, Belle -- Blaschke, Lester 2* Blieden, A* Boynton,M. D., Ben L* Srackln, Joyce Brandon, M. D,, 3* Brewer, Sr. ,V.L. Brooke, Maxey Brooks, P. R. M. Brown, L. H. Brown, 7. C. Bruder, R.H., Happy ___ /hirghdorf, Flora M* Camp, E, q, Caldwell, B. T. Carlson, 0. D. Magnolia Petroleum Company Libarty Mutual Insurance Company Jefferson Chemical Company, Inc* The Dow Chemical Company Houston Lighting,A Power Co* The Dow Chemical Company American Air FI Iter Co. T. J. Bettes Company - Houston Fire A Casualty Co* Freeport Sulphur Company Beaumont* Texas Little Rock, Ark* Port Nechea, Texas Freeport, Texas Houston,Texas Freeport,Texas Houston, Texas Houston, Texas Houston, Texas Freeport,Texas Humble Oil & Refining Co. Houston, Texas Houston Laboratories Houston, Texas Lubrlzol Corporation PasAdena, Texas Texas Stats Health Department Austin, Texas Humble Oil & Refining Co* Houston, Texan Continental Can Co.,Inc* Houston, Texas Jefferson Chemical Co. Port Heches,Texas University of Texas Galveston,Texas Pan American Refining Corporation Texas City,Texas American Brake Shoe Co. Houston,Texas Champion Paper A Fibre Co. Pasadena, Texas Lone Star Steel Company Lone Star, Texas Time Inc. Chicago, Illinois John Sealy College of Nursing Galveston,Texas Houston Fire A Casualty Ins. Co. Houston, Texas St,Joseph1s Dept.of Hurting Houston, Texas Houston Public Schools Houston, Texas Corpus Christi-Sheces Co.Health Unit Corpus Chriatf.Texi ^Sanitation* Houston, Texas. Veterans Administration Hospital Houston, Texa# ft. Joseph e Dept, of Forsing Houston,Texas Medical Arte Building Houston, Texas Brasorla Co.Health Uhit Angleton, Ttxm* Phillips Petroleum Company Sweeny, Texas Uhitei- Gas Corporation Houston, Texas Saaters States Petroleum Co.Inc. Houston, Tens* Tin Processing Corporation Texas Clty^fexas Saks Fifth Arenua Chicago, Illinois Lamar High School Houston,Tex^n Humble Oil A Refining Co, Dow Chemical Company Dow Chemical Company Baytown.Texas Freeport. Texas Freeport. Texas 59 ^. Lind. v act. * E\ ,, 8elc. Mr* Amalie /CWS Donald D* WT%, Frank CWQC Franklin W. e^b'M Roger SjSin.B-**- Mias Audrey iocWaa.JE*' ^c8, Cogburn. Dr. C.C. ciuer,-*rs Cooley- Don M. Cope, Ricter4 J* Lland. Bart CoLitt.B.JI.. Zuoa -* Co*a4. D.J. Crute, W. * Cunnicgdam, C. a. Goodyear Synthetic Rubber Corp. Gulf Oil Corporation National Biscuit Company Bethlehem Supply Co. Bumble Oil A Refining Co. Diamond Alkali Company University of Colorado The Lubrizol Corporation Belly A.F.B. Port City Stockyarda Co. E. I. Du Pont De Nemours A Co. Shilstone Testing Laboratory Cabot Carbon Company Goodyear Synthetic Rubber Corp. Houston Anti-Tuberculosis League Continental Can Co. Texas State Health Department Champion Paper & Fibre Co. Continental Can Company.Inc. Houston,Texas Port Arthur,Texas Houston, Texas Tulsa, Okla. Houston, Texas Pasadena,Texas Denver, Colorado Pasadena, Texaf San Antonio,Texas Houston, Texas La Porte,Texas Houston,Texas Fampa, Texas Houston,Texas Houston, Texas Los Angeles,Calif. Houston,Texas Pasadena, Texas Houston, Texas gaes Cheney,Pearl - Eastern States Petroleum Co.,Inc. Houston, Texas Dele, Jr* > B. H. Southwest Steel Products Co. Dalberg.B.N., Mrs. Clara L. " Sinclair Rubber Inc. Houston,Texas Houston, Texas jkfliels. Nurse, Mrs. Mary Tom- Houston Lighting A Power Co. Houston, Texas Daunenbaum, J. B. Consulting Engineer Houston, Texas /Davidson, Miss Helen Magnolia Petroleum Co. Beaumont, Texas ' Qaris, Horace American Associated Ins. Companies Houston, Texas Datis, M. D., Kieffer Phillips Petroleum Co. Bartlesville ^ Okla. Davis, Dr. William Harris County Health Unit Houston, Texas Day, Russell Texas Employers Insurance Co. Houston, Texas /Delehanty ,RN,, Mrs. Mary Equitable Life Assurance Society New^York.N. Y, Delauae, R. H. Dow Chemical Company Freeport, Texas Denaan, C. W. Tex Tan of Yoakum Yoakum,Texas Dernehl,M,D., C. U. Carbide & Carbon Chemicals Corp. Texas City,Texas Diserens, Alton H. Texas State Department of Health Fort Worth,Texas Dooley, Allan E. The Texas Company New York, N.Y. /Dorsey,R.N.,Mrs, Audrey L, Dow Chemical Company Freeport, Texas /Dotson, Miss Pat Humble Oil A Refining Co. Houston, Texas /Doff, Mrs. Florence H Gulf Oil Corporation Port Arthur.Texaa /Eundore.R.N. .Gladys L. American Association of Ind.Nurses New York,N.Y. / Dunne, Larry Corpus Christl-Nueces Co.Health Unit Corpus Christi.Texa BiPree.R. B. Sinclair Refining Co. Houston,Texas Dirham, Mrs, C. A. Peden Iron A Steel Co. Houston,Texas / Durham, R.N., Thelma Continental Can Co. Memphis, Tenn. Ruling,R.N., Effie S. fctman, P. W. He, Grover B. Bders, C.E., V.M. Dmis Dnden /*n'ln,Mrs. Antoinette da*. T. E. Aluminum Company of America Eastern States Petroleum Co.Inc. Humble Oil A Refining Co. State Department of Health Gulf Oil Corporation Mosher Steel Company E. I. Du Pont De Nemours A Co. Fort Lavaca,Texas Houston, Texas Baytown,Texas Austin, Texas Houston, Texas Houston,Texas La Porte,Texas " L- " Harris County Health Unit Rohm & Haas Company * ?;.h. Allied Safety Equipment,Inc. ' Armour and Company Dr. LulB W* jSS- i's. 613 S.V.Life Building United Gas Corporation Celanese Corporation of America to4rey Magnolia Petroleum Co. Magnolia Petroleum Co. Je * H. ** j. Sheffield Steel Corporation E. I. Du Pont De Nemours & Co. Union Carbide A Carbon Corporation Carbisulphoil Company U ' Wyatt Metal A Boiler Works M C.i * Hospital. Ass'n.of the S.P.Lines J^ier!Hi8 Jacqueline (Jackie)Health Edu.Dept., Y.W.C.A. American Associated Ins.Companies *|J,<Villiaffl Humble Oil A Refining Co. Sjrv *ed. s. Diamond Alkali Company Shell Oil Company Travelers Insurance Co. Gulf Oil Corporation Houston,Texas Pasadena, Texas Houston, Texas Houston, Texas Dallas,Texas Houston, Texas Bishop,Texas Beaumont,Texas Beaumont, Texas Houston, Texas La Porte,Texas Texas City,Texas Dallas, Texas Houston. Texas Houston, Texas Houston, Texas Houston, Texas Baytown,Texas Pasadena, Texas Houston, Texas Dallas,Texas Port Arthur,Texas m. ; fct>ad. "* "* ^rlck, M. D., W, H. Anne. R.N. tenon, Jr., Irven E. Arty, R.V., Bath ^krrlson, C, G. irrill, Clyde R. had, Hayden W. 3elnlgr, G. D. Seiner, Arthur J. Henrich.Y, C. Ser&don, H. T* /Hewlett, Mrs. Ella Bodgfcinson,R.E. Sophias, M.C. Bolt.M.D., Milton 0. bltaan, S.J. Natural Gas Odorizing Co.,Inc. Humble Oil A Refining Co. Harris County Medical Society E. I. Du Pont De Nemours A Co. 1010 Vest 4th Street 480? Caroline Chambers Co. VC A ID #1 City Water Department Attorney at Law Dow Chemical Co. J. Weingarten.Inc. Rohm A Haas Co. Texas Employers Ins.Association United Gas Corporation Ethyl Corporation Pan American Refining Corporation Esso Standard Oil Company Southern Alkali Corporation Houston, Texas Houston, Texas Houston,Texas La Porte,Texas Freeport,Texas Houston, Texas Houston, Texas Houston,Texas Austin, Texas Freeport,Texas Houston, Texas Pasadena, Texas Dallas,Texas Houston, Texas Baton Rouge,La. Texas City,Texas Baton Rouge,La. Corpus Christi.Texac /fuaer.R.N. .Miss Mary B. /Johnson, Mildred ___ Johnson, Tom Jones, Mrs. M. G. Alamo Iron Works A*0.Smith Corporation American Associated Ins,Companies The Texas Company San Antonio,Texas Houston,Texas Houston, Texas Houston, Texas kble, Varren /Corney, Marie F. ^ch.J. s. /II, Do ro thea **P,M.D,, Hardy A. &nedy,Villis G, Eastern States Petroleum Co.Inc. Houston, Texas Shell Chemical Corporation Deer Park, Texas Pan American Refining Corp, Texas City,Texas Sheffield Steel Corp. Houston,Texas Baylor Uhiversity College of Medicine,Houston, Texas Diamond Alkali Company Pasadena, Texas 61 t*l/.Pi-.* ct - uenton S5'.e,j.fc. vtfi*. $>J- 0arrl** a If. .Elizabeth vgSW'"*"4*- Margaret t*0?' 'John W. 5.d.. b*1** Lenard " .Lfl-U. ** Z^ise Marguerite WJ:, Eayooa^ C. vimTM B- I/BCh, J. 5* CBliUO l^gjjglluflin IfcfrhflB.M.D. i J feGreth,Warren J /IcLeafi, S f .Beatrice feClintoch.J. H. Neat. Sam Ifeharg, David Martin, Valter G. feeee, V. G. fellah, Arthur W. fercier, G.T. /While,R.N.,Miss Clara WUer, Jarvis E. Kills. K. E. /Mlstead Brown, Trances Mobley, Harvey R. Moore, M. D., John T. Moore, R. B. Aoore.R.N,, Ruth Jane / Morgan, J.R. Moree.R.N. .Frieda N. Moeanan, G. C. Wilkin, R.7. laichks, il I. M, Dr. Carl A. Jack */4, *. Chairman,City Health Board Magnolia Petroleum Co. Houston Lighting 4 Power Co. Texas Graduate Nurses Ass*n.Diat.#9 Champion Paper 4 Fibre Co. Texas Engineering Ext.Service Houston, Texas Beaumont,Texas Houston, Texas Houston, Texas Pasadena,Texas College Sta.,Texas Socony Vacuum Oil Co.,Inc. Houston Health Department Texas State Health Department The American Brass Co. E. I.Du Pont De Nemours 4 Co. Drs. Hollins and Lilee Clinic United Gas Corporation Jefferson Chemieel Co. Natural Gas Odorizing Co.Inc. Gulf Oil Corporation Edgar Tobin Aerial Surveys Hartfield Accident 4 Indemnity Co. Royal Insurance Companies The Ohio Rubber Co. Engineering Extension Service A 4 M Paul aboro,N.J. Houston, Texas La Marque,Texas Detroit, Mich. Orange, Texas Houston, Texas Houston, Texas Port Neches,Texas Houston, Texas Houston, Texas San Antonio,Texas Houston,Texas Houston, Texas Villoughby,Ohio College Sta.Texas Carbide 4 Carbon Chemicals Corp. American Medical Association Schering Corporation Drs. Rollins and Liles Clinic Esso Standard Oil Co.of N.J. Dow Chemical Co. Texas City,Texas Chi cago,Illinois Bloomfield,N.J. Houston, Texas Baton Rouge,La. Freeport,Texas Pan American Refining Corp. Texas City,Texas E..I. Du Pont De Nemours 4 Co. Vilmington, Delawai Tsxas Stats Health Department l^rler, Texas United Gas Corporation Houston, Texas Texas Engineering Experiment Station College Sta.Texas Ethyl Corporation Baton Rouge, La. Todd Shipyards Corp. Houston, Texas Standard Oil Co. of N.J. Baton Rouge,La. Fan American Qefining Corp. Texas City,Texas Houston Anti-Tuberculoeie League Houston, Texas City Health Department Houston, Texas 821 Medical Arte Bldg. Houston, Texas Vest Disinfecting' Co. Houston, Texas Texas State Department of Health . Austin,Texas Tin Processing Corp. Texas City,Texas 15 Bartlett Avenue Highland Park 3,Mir Carbisulphoil Company Dallas,Texas Z.I.Du Font De Hemoura & Co. la Forte,Texas American Associated Ins. Companies Houston Lighting A Power Co. University of Texas-Medical Branch University of Texas-Medical Branch Carbide and Carbon Chemicals Corp. Houston, Texas Houston, Texas Galveston.Tsxas GalvestonTTexas Texas- City,Texas 62 , 3. 3. ^ p^f^cbBTi J>*T: M. B- M. B.. R* B* fee*' !^d Mi*9 Mabel- Otto N*?tr . Harry pil* ' 3,, tfm. M, P*!' `narae. Miss A. 7. P*rlc* ' frothy B. P^!` Cheater ?. [gSa. S^elya May S*I7. f,r -' 2 V B. V. SHW** *<? t* S' well. A. M. well* 3. B* Mitoa, A. a. rtflce, Hare*. Mrs. Hazel -<nr. A* B Aibitt, Agnes fegan, J* 1** fcadsll. Fred A. ^fcttuasen.Mra. Florence leeeS'M.D., Chas# D. /Mala. Miss Emeline J. jiehey, Alvan lieheker, Charles toaper, R. B. /ibinson.R.H., Elizabeth toblnson, F.R. loderlck, D.H. tollIns, M.D. , V. J. tomtl, A. Ross toss, Edith H, toekidashel, R. V. "tp, Christine- "toladlno, R.H., Iris toaders, C. A. Ssundsre, John V, ^7sr, Dr. Frederick ^^aitzer, Jr. .George Wuar, Phy., Sidney ^t.Jr., M.D., J. T. ^tt, Red 7. Dr. S.S. Shell Oil Company M. H. Dannenbaum Co. Box 448 Houston, Texas Houston, Texas Baytown, Texas Liberty Mutual Insurance Co. Boston, Mass. Emsco Derrick A Equipment Co. Houston, Texas Texas State Health Department Austin, Texas Texas State Department of Health Houston, Texas Painter & Painter Houston, Texas Hie Houston Clinic Houston, Texas Houston Lighting & Power Co. Houston, Texas Sheffield Steel Corporation Houston, Texas Texas State Department of Health Houston, Texas University of Houston Houston, Texas Shell Oil' Company Houston, Texas A. 0. Smith Corporation Houbton,Texas Humble Oil & Refining Co. Baytown, Texas San Antonio Air Material Area,Kelly AFB.San Ant.,Texas Texas State Health Department Austin, Texas Stauffer Chemical Co. of Texas Freeport,Texas Mosher Steel Company Houston, Tbxas Houston Laboratories ' Houston, Texas Houston Lighting A Power Co. Houston, Texas Qnsco Derrick A Equipment Co. Houston, Texas Sheffield Steel Corporation Houston, Texas Anheuser Busch, Inc. Celanese Corporation of America Carbide & Carbon Chemicals Corp. Gulf Oil Corporation Lummis, Reece, Burrows A Arnold Houston Anti-Tuberculosis League Industrial Scientific,Inc. The Texas Company Humble Oil & Refining Co. wens Illinois Glass Co. Bnseo Derrick & Equipment Co. Jefferson Chemical Co. Drs. Rollins A Liles Humble Oil & Refining Co* A. 0. Smith Corporation Diamond Alkali Company Hughes Tool Company St. Louis, Mo. Bishop,Texas Texas City,Texas Houston, Texas Houston, Texas Houston, Texas Houbton, Texas Port Arthur,Texas Houston, Texas Fairmont, W.7. Houston, Texas Port Neehes, Texas Houston, Texas Houston, Texas Houston, Texas Pasadena, Texas Houston, Texas San Antonio Garment Workers Texas A < M College Humble Oil <4 Refining Co. Stanford Research Institute Shell Chemical Corporation 411 Medical Arte Bldg. Scott Industrial Clinic Water A Fuel Service,T A H.O.R.R. Humble Oil A Refining Co. San Antonio,Texas College Sta.Texas Baytown. Texas Stanford, California Houston, Texas Houston, Texas Hew Orleans, La* Houston, Texas Baytown.Texas 63 ion. 0. , Jr. v. h. * C. K. iTM4** ^ ^1<ee0avr,,JJSr., 7Edgar G. rloclc- S. v. SSt*Af"l--^er,:M'VS* * Paul R* 5{i03oa. B. w. SJttoo* Lloyd 3. E. ^,,r, Eicfc!,rl * Humble Oil & Refining Co. Chem. A Engr. Hem Dow Chemical Company Stockham Valves A Fittings Dow Chemical Company State Health Department Bexar Co. Tuberculosis Association Humble Oil A Refining Co. 4715 Fannin St. A. 0. Smith Corporation Vright Manufacturing Co. Stockham Valves & Fittings Southwest Research Institute City Health Department Sutter Industrial Surgical Clinic Baytown, Texaa Houston, Texas Freeport, Texas Birmingham, Ala. Freeport, Texas Austin,Texas San Antonio.Texae Houston, Texas Houston,Texae Houston, Texaa Houston, Texas Birmingham, Ala. San Antonio,Texas San Antonio,Texas St, Louis,Mo. . r George ^oie.' c* s* n*vell. Hex L. leyf E. F. John A. xjJsrerae. R.H., Miss Sally M. Humble Oil A Refining Co. Safety Casualty Co. Blue Cross United. Qas Pipe Line Co. Texas Employers' Insurance E. I. Du Pont De Hemours A Co. Baytown, Texas Dallas,Texas Houston, Texaa Houston, Texas Houston, Texas La Porte', Texas tjirejr. s* Scott Tenable, Fred S. ferret, Pearl M. Tiles, P.S. Tineent, D.M. E. I. Du Pont de Hemours A Co. Texas State Health Department Gulf Oil Corporation Humble Oil A Refining Co. Phillips Chemical Co. Victoria, Texas Fort Vorth,Texas Port Arthur,Texas Baytown, Texas Pasadena, Texas Tigers, Otto sgner, R.N., Sara P. ' Ygllentine, Ervin W. Tallis, Dr, W. M. -tard,B.H., Beryl wring, R. P. Karrington, Sam L. Keaver, Jane M. Veatherford, Joe A. Veiler, L. J. Kaaterman, Henry E. /Kballey, Anne M. ttitty, T. P. Wer, C. H. Vi Id, Mrs. Beul'ah Temple /Wllett, Miss Kathryn Wiliams, Ed Wiliams, Jo. __ Wiliams, John K. 'ftlson, Mrs. Billie ''llaon, J. w. Wlaon, P. v. *di David M. 'Jsodley, James V. ght, E. H. Champion Paper & Fibre Co. Standard Oil Co. (H.J.) The Texas Company 918 Union national Bank Bldg. National Lead Company Houston Lighting A Power Co. Hidalgo County Health Unit Liberty Mutual Ins. Company Vest Disinfecting Co. Humble Oil A Refining Co. Gulf Oil Corporation Sheffield Steel Corporation Vest Disinfecting Co. Royal Insurance Company Community Council Gulf Oil Corporation Champion Paper Fibre Co. Champion Paper 4 Fibre Co. The Industrial Health Council Houston Lighting A Power Co. Texae State Health Department Humble Oil A Refining Co. Liberty Mutual Insurance Co. Liberty Mutual Insurance Co. lhe Dow Chemical Co. Pasadena, Texas Hew York, N.Y. Port Arthur, Texas Houston, Texas St. Louis, Mo. Houston, Texas Edinburg, Texas Dallas,Texas Houston, Texas Baytown, Texas Houston, Texas Houston, Texas Houston, Texaa Houston, Texaa Houston, Texaa Houston, Texaa Pasadena,Texaa Pasadena, Texas Birmingham, Ala. Houston, Texas Houston, Texaa Houston, Texaa Houston, Texaa Houston,. Texaa Freeport, Texaa 6k `s/b. Crown Central Petroleum Corporation Texas A 4 M College Texae State Department of Health Liberty Mutual Insurance Companies Houston, Texas College Sta Texas Austin, Texas Dallas, Texas Liberty Mutual Insurance Company Chesapeake & Potomac Telephone Co* Real Estate Houston, Texas Washington, D.C. Houston, Texas 11-3-50 65