Images (20)
Document
| id |
id
75730723
|
|---|---|
| contentType |
contentType
document
|
| source |
source
import
|
Source image fields (6)
Extracted text
OCR Page 1 of 20MEVORANDUM or DEFENSE
Based on Points Raised in Mr.BerrY's
Proposed Agreement on Facts.
1. Claims in Paragraph 1 - admitted.
2. (a) Contained Radium only until May 1919.
(b) Contained Radium and Mesothorium in varying quantities from May 1919
Can prove by - C. B. Lee or H.H.Barker
3. It is admitted that the radio-active constituants contained in our luminous
preparations were known since the year 1900, but it is denied that there was common
knowledge relative to the destructive effects which might be incurred in the
ordinary handling or commercial production of this substance. The first real
indicat-
tion of any such hagard was reported by the Radium Institute of London in their
annual report of 1919, and even this report does not strongly predict that there is
a hazard existing, although they make certain recommendations for the protection of
their employees who are engaged in the handling of relatively large quantities of
radium.
In 1920 Mottram reports on three fatel cases occuring at the Radium Institute,
and while he states that the proof is not conclusive that their deaths should be
attributed to radiom, still he foels that they could not deny the fact that it might
have been contributory. All of this work applies to the use of radium in high
concentration, as well as large dosage or amounts, and is comparable in no way to
either the concentration or the quantity of radium involved in luminous paints. In
fact there is no mention of such paints in the work reported at this time, even
though radiom paints were in common use, especially in England. Again let 125 keep
in mind that none of this work was directed to such quantities of radium as are
involved in the handling of radium luminous material, but with quantities ranging
from 100 to 1000 times such amounts. That the therapeutic value of radium was
based upon the destructive effect of this material to bodily tissues is somewhat
far fetched, on the contrary it would seem that as a result of the use of radium
for therapeutic purposes the fact that it was injurious under certain conditions
became apparent.
Drs. Moore, Schlundt,Lind, Flinn and if necessary Mr. Barker
4.
Probably no specific information was ever given to the complainants regarding
the material furnished them for use, but is was common knovledge that the material
contained radium, and was ealled radium, or radium paint by our employees. This
is confirmed by the further fact that our name at that time was Radium Luminous
Materials Corporation.
(1) Advertising,sales & publicity material posted at times on plant
bulletin board.
(2) Most of Plant devoted to production of Radium
Relations
belongs_to
belongs_to