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-2- mesothorium was added to the basic zine sulphide mechanically, and the amount varied from one (1) part in 140,000 to one (1) part in 33,000. Inasmuch as it was not a loaded brush which was "poänted", but the dry brush, it is obvious that at the worst the amount of radioactive zinc sulphide that could be ingested per day sould be very small. However, as small as this amount nust have been we have found a fow cases where the system has absorbed some of the radioactive constituents and it has been depos- ited thruout the bony skeleton. The deposit of this material has persisted after & period of several years, and it is now the theory that the continued action of the alpha particles from the radioactive nateriala so deposited has been the cause of any of the conditions reported among these employees. In 1925, two cases that were diagnosed as suffering from the result of their employment by us brought suit for damages, and were settled. In June, 1928, there was a group of five cases, which had been given wide pub- licity, thru their efforts in endeavoring to obtain redress, by the press, these were also settled. These cases you probably are agee or less familiar with thru such publicity, and the information which I gave you. We are now confronted with building a defense in four (4) more cases that have been instituted against us. In this connection they charge us with contributory negligence, in that we did not provide proper precautions for these employees during the periods of their employment from 1916 to 1924. They claim that it was common knowledge at that time that even small amounts of radioactive materials taken into the system was deleterious, and that it was well known, and that we should have been aware of it. On the contrary we maintain that there was no reason why we should have been suspicious that even though very minute amounts had been ingested that there was any possibility of hazard arising from the practice. This conclusion was based primarily upon the fact that during this time radium chloride was administered internally for certain conditions under medical supervision, and that there had never been reported in the literature any untoward effects resulting from this prac- tice. We further maintain that even though we had been aware that small amounts of luminous zinc sulphide were being ingested daily we should not have viewed this with any particular alarm, due to the fact that the radium or mesothorium, as the case night have been, was percipitated upon the surface of the zinc sulphide in an insoluble form - that is the sulphate, and knowing that radium sulphate is one of the nost insoluble inorganic compounds known we should have felt a certain amount of confidence that the material would of necessity pass thru the alimintary. tract without any appreciable amount being absorbed. It is in this connection that we are soliciting your aid, for as I pointed out our counsel is anxious to establish before the court that up to and including 1925, the medical profession did not consider the internal use of radium befraught with any hazards either immodiate or latent. The fact that you administered radium chloride internally as late as 1925, and even later, and that you did not consider it hazardous in any way will be of great value to us in establishing this point. It might be well for you to bring your cards indicating the amounts of material administered to some of your patients, as well as the indicated progress.

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    "ocrText": "-2-\nmesothorium was added to the basic zine sulphide mechanically, and the amount\nvaried from one (1) part in 140,000 to one (1) part in 33,000.\nInasmuch as it was not a loaded brush which was \"poänted\", but the\ndry brush, it is obvious that at the worst the amount of radioactive zinc\nsulphide that could be ingested per day sould be very small. However, as\nsmall as this amount nust have been we have found a fow cases where the\nsystem has absorbed some of the radioactive constituents and it has been depos-\nited thruout the bony skeleton. The deposit of this material has persisted\nafter & period of several years, and it is now the theory that the continued\naction of the alpha particles from the radioactive nateriala so deposited has\nbeen the cause of any of the conditions reported among these employees.\nIn 1925, two cases that were diagnosed as suffering from the result\nof their employment by us brought suit for damages, and were settled. In\nJune, 1928, there was a group of five cases, which had been given wide pub-\nlicity, thru their efforts in endeavoring to obtain redress, by the press,\nthese were also settled. These cases you probably are agee or less familiar\nwith thru such publicity, and the information which I gave you.\nWe are now confronted with building a defense in four (4) more cases\nthat have been instituted against us. In this connection they charge us with\ncontributory negligence, in that we did not provide proper precautions for\nthese employees during the periods of their employment from 1916 to 1924.\nThey claim that it was common knowledge at that time that even small amounts\nof radioactive materials taken into the system was deleterious, and that it was\nwell known, and that we should have been aware of it. On the contrary we\nmaintain that there was no reason why we should have been suspicious that\neven though very minute amounts had been ingested that there was any possibility\nof hazard arising from the practice. This conclusion was based primarily\nupon the fact that during this time radium chloride was administered internally\nfor certain conditions under medical supervision, and that there had never\nbeen reported in the literature any untoward effects resulting from this prac-\ntice.\nWe further maintain that even though we had been aware that small\namounts of luminous zinc sulphide were being ingested daily we should not\nhave viewed this with any particular alarm, due to the fact that the radium or\nmesothorium, as the case night have been, was percipitated upon the surface\nof the zinc sulphide in an insoluble form - that is the sulphate, and knowing\nthat radium sulphate is one of the nost insoluble inorganic compounds known\nwe should have felt a certain amount of confidence that the material would\nof necessity pass thru the alimintary. tract without any appreciable amount\nbeing absorbed.\nIt is in this connection that we are soliciting your aid, for as I\npointed out our counsel is anxious to establish before the court that up to\nand including 1925, the medical profession did not consider the internal use\nof radium befraught with any hazards either immodiate or latent.\nThe fact that you administered radium chloride internally as late as\n1925, and even later, and that you did not consider it hazardous in any way\nwill be of great value to us in establishing this point.\nIt might be well for you to bring your cards indicating the amounts\nof material administered to some of your patients, as well as the indicated\nprogress."
}