Document 1g1zbzKmrKXRvKONnMbLXByEa

1 Wm. Papageorge - Glenn Brown Trial Testimony 10/28/91 P.M. 1 (Ms. Olliges replaced Ms. Carter.) 2 THE COURT: Ladies and gentlemen, thank you 3 for waiting. Sorry for the delay. Mr. Kotoske, you may 4 continue. 5 MR. KOTOSKE: Plaintiffs call as their next 6 witness William Papageorge. 7 (Mr. Papageorge was sworn by the clerk. 8 THE COURTJo : Proceed. 9 10 WILLIAM PAPAGEORGE, 11 of lawful age, having been first duly sworn, testified 12 as follows: 13 DIRECT EXAMINATION 14 QUESTIONS BY MR. KOTOSKE: 15 Q. Mr. Papageorge, do you still work at 16 Monsanto? 17 A. I do not. 18 Q. When did you quit or retire or terminate? 19 A. My last working day was Decembejo r 31st, 1986 20 Q. And how is it that you are the corporate 21 representative in this trial? 22 A. I don't know that I know, sir. You'll have 23 to ask the attorneys. I can only guess. 24 Q. (Inaudible.) Are you being paid for your 25 time? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49426 2 1 A. I do not get paid for testimony as a fact 2 witness. 3 Q. Aside from all that, is Monsanto paying you p4 for being in this trial? 5 A. Monsanto is not. I have an agreement with 6 the law firm that works with Monsanto. 7 Q. To be paid? 8 A. To be -- Yeah. The agreement does provide 9 for paying me for helping out on PCB cases. 10 Q. Would you mind telling us what your hourly 11 rate is? 12 A. It's $150 an hour. 13 Q. And has that been true since you left the 14 company in '86? 15 p A. I'm trying to remember. No. The first year 16 I did not have any arrangement, and following that, as 17 best I recall, it was $125 an hour. 18 Q. And it's gone up? 19 A. It's gone up this past year. 20 Q. About how much time have you spent consulting 21 with Monsanto (inaudible) on PCB cases? 22 MR. CARNEY: Your Honor, could we approach 23 the bench? 24 (A bench conferjo ence was held.) 25 THE COURT: You may proceed, sir. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49427 3 1 Q. How much money has Monsanto paid you in this 2 case? How much money -- Can you hear me? 3 A. Yes, I can. Yes. 4 UNKNOWN JUROR: You need to speak up a 5 little. 6 Q. How much money has Monsanto paid you in this 7 case? 8 A. I don't have an accurate count in mind. As 9 best I can re]o call, it's about 20 hours so far. 10 Q. Not including the trial? 11 A. That is correct. 12 Q. And you've been here for the last two weeks 13 and will be throughout the trial? 14 A. I expect to be, yes, sir. 15 Q. Do you have a pension from Monsanto? 16 A. I do. 17 Q. Medical benefits and dental benefits? 18 A. Just a medical -- Medicare supplement. p Q.19 And you have an interest in seeing Monsanto 20 win this case; do you not? 21 A. Certainly. 22 Q. All right. Now, let's talk about your 23 educational background. Would you tell us where you went 24 to college? That's what I'm interested in. Did you 25 attend college? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49428 4 1 A. I did. I received my Bachelor of Science 2 degree in chemical engineering from Washington University 3 in l]p 943. I received from that same university a Master of 4 Science degree in chemical engineering in 1947. And I 5 also earned about 12 credits toward a Doctorate of Science 6 degree at Oklahoma A & M, now known as Oklahoma State 7 University. 8 Q. Now, you're not a medical doctor? 9 A. That is correct. 10 Q. You don't offer any opinions here in this 11 trial about medical toxicology? p12 A. I don't propose to, no. 13 Q. You don't propose to be an expert in 14 toxicology? 15 A. That is correct. 16 Q. I'd like to start with your work history and 17 the job you had just before you joined Monsanto in 1951. 18 Tell me about that job. 19 A. Just before 1951, I was with the Phillips 20 Petroleum Company in Bartlesville, Oklahoma, working on 21 two different types of assignments. The first two years 22 of a four-year period I was working on research to find 23 better ways to drill for oil wells and also better ways to 24 get oil out of wells that were pretty well spent. In 25 other words, to extract the last bit of oil still in the Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49429 5 1 ground. The last two years I was in the design 2 department, designing equipment for making gasolines or 3 gasoline fractions that are blended later to make the 4 product. p5 Q. Did part of your duties with that company 6 include the designing of equipment? 7 A. Yes. The last two years. 8 Q. Then in 1951 -- I'm going to interrupt 9 myself. I've never taken your deposition in this case; 10 have I? 11 A. That is correct. 12 Q. In fact, you've never seen me before this 13 trial? 14 A. That is correct. We've never met. 15 Q. Then in 1951 you joinjo ed Monsanto? 16 A. I did. 17 Q. Tell us whatyour first job was at Monsanto. 18 A. My first job was designing equipment to be 19 used in the manufacture of a chemical product at a plant 20 located here in St. Louis on Second Street. 21 Q. And what were they making at that -- What was 22 the chemical that was being manufactured? 23 A. Of theunit I was designing or -- 24 25 p Q. Yes. A. It was a chemical called phthalic, that's Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49430 6 1 p-h-t-h-a-l-i-c, anhydride, which is a chemical that is 2 used in making plastics or plastic softeners or used in 3 paint. 4 Q. And in 1953 you got a promotion; isn't that 5 correct? 6 A. In 1953 I would suggest it was more of a 7 lateral move from design engineering over to production 8 supervising. I was assigned a part of Monsanto's planjo t 9 that made a chemical. 10 Q. And you had a supervisory capacity at that 11 time? 12 A. Yes . 13 Q. The (inaudible) at that time was making 14 chemicals? 15 A. That is correct. 16 Q. Not PCBs? 17 A. That is correct. 18 Q. At some point in time you became assigned to 19 the Queeny Plant. Can you -- Could you spell that for the 20 reporter? 21 p A. Q-u-e-e-n-y. 22 Q. Where is that plant located? 23 A. 1700 South Second Street, St. Louis. 24 Q. And were there PCBs in that plant? 25 A. Yes . Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49431 7 1 Q. And I want to know (inaudible) in the plants. 2 Were you making them, or what were you doing? 3 A. They were certainly in the electrical 4 equipment, the transformers and capacitors used in the 5 plantjo to distribute electricity. They were also present 6 in fluids used in some of the machinery. For example, in 7 compressors as an hydraulic fluid. They were present in 8 some systems used for heating chemicals, as heat transfer 9 fluids. They were also present as an ingredient. One of 10 the departments at the plant was given the assignment of 11 taking PCBs and other ingredients and blending them to 12 produce an industrial hydraulic fluid which w]p as shipped 13 from that plant. 14 Q. This hydraulic fluid was used in machinery 15 throughout the United States; was it not? 16 A. Yes, sir. 17 Q. And one piece of machinery comes to mind is a 18 forklift. Would that be the type of hydraulic fluid that 19 you're talking about? 20 A. No. The -- 21 Q. What I need is some examples, if you will, of 22 the type of equipment that the PCB mixjo ture was used in. 23 A. This hydraulic-- This particularmixture? 24 Q. Yes. 25 A. I'll try tothink. It was used in some Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49432 8 1 conveying systems. It was used in compressors that I 2 mentioned earlier. That's all that comes to mind at the 3 moment. Oh, used in some -- 4 Q. That's fine. 5 A. That's all that I can really think of. 6 Q. Just so we know. Withjo respect to that 7 (inaudible), when you sold it did it have a warning on it 8 that would warn people of the dangerous consequences of 9 exposure to PCBs? 10 A. It has cautionary words. 11 Q. What wording? 12 A. I don't propose to recall every word, but to 13 the effect that fumes should not be breathed for long 14 periods of time or repeatedly, that the material should 15 not be allowed on the skin for too lon]p g a period of time, 16 that if clothes are dirty with the material they should be 17 laundered before re-use. That kind of statement. 18 Q. Do those warning labels still exist? 19 A. I suppose they do. I haven't seen them in 20 many years, though. 21 Q. Would the best source of those warning 22 labels, if there were warning labels, be in the hands of 23 Monsanto? p24 A. I would -- Yes. I would suggest that would 25 be a good starting point. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49433 9 1 Q. It would be the best place to find them; 2 isn't it? 3 A. I would think so, yes. 4 Q. Now, (inaudible) that hydraulic fluid prior 5 to 1953? 6 A. I didn't hear the first part. 7 Q. How long did you sell that hydraulic fluid 8 with PCB? 9 A. Prior to 1953? 10 Q. Yes . p11 A. I As best I recall, that's about the time 12 that that fluid was invented and introduced into the 13 marketplace. 14 Q. About 1953? 15 A. In the middle '50's, yes, sir. 16 Q. All right. Now, still at the Queeny plant, 17 did there happen from time to time when one of the 18 capacitors would break or a transformer break that had 19 PCBs in them? 20 A. I personally do not remember any incident 21 where a transformer or a capacitor, to use your word, 22 broke. 23 Q. Maybe that's -- Did you ever have leakage of 24 a PCB oil (inaudible)? 25 A. I am not aware of any incident like that. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49434 10 1 Q. Did any employee ever complain of any health 2 problems at the Queeny plant from exposure to PCB? 3 A. PCBs ? 4 Q. Yes. 5 A. Not to my knowledge, never. 6 l5 Q. Of course, that plant didn't manufacture 7 PCBs; did it? 8 A. That is correct. 9 Q. In 1953, you said there was a warning. What 10 were you aware of, you yourself, in 1953 of the dangerous 11 consequences, health consequences, from exposure to PCB? 12 MR. CARNEY: Your Honor, could we approach 13 the bench? 14 THE COURT: All right. 15 16 17 18 19 20 21 22 23 24 25 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49435 11 1 THE COURT: Restate it or you can have it 2 read back. 3 MR. KOTOSKE: I'll repeat it. 4 THE COURT: Repeat it, please. 5 Q. (By Mr. Kotoske) In 1953 what did you know 6 about the dangerous consequences from exposure to PCB in 7 the work place, outside of the work place, anyplace? 8 A. In 1953, nothing. I was never aware of any 9 such product. I hadn't been inv]p olved with it yet. 10 Q. And do you know if anybody in Monsanto -- Did 11 you discuss anything with anybody in Monsanto what the 12 dangerous consequences were? 13 A. At what time, sir? 14 Q. In 1953. 15 A. 1953, no. 16 Q. And as you sit here, you didn't know 17 anything? 18 A. That's correct. 19 Q. As the supervisor of that plant did you ever 20 consult with D]p r. Kelly, Emmet -- Do you know Emmet Kelly? 21 A. I do, yes. 22 Q. And you know (inaudible)? 23 A. Yes. 24 Q. Did you ever ask him, "Dr. Kelly, are there 25 any consequences from exposure to PCBs?" Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49436 12 1 A. No, sir. My job didn't involve that kind of 2 question. 3 Q. All right. You didn't talk to him? 4 A. That's right. 5 Q. Did you ]p talk to Elmer Wheeler, who is also an 6 assistant of Dr. Kelly, in 1953? 7 A. No. 8 Q. And nobody told you anything? 9 A. That is correct. 10 Q. How do you (inaudible) when you call 11 (inaudible)? Do you call Dr. Kelly in the medical 12 department? 13 A. He was the medical director of the medical 14 department. 15 Q. How about Mr. Wheeler? 16 A. Mr. Wheeljo er, he was at one time the assistant 17 director and later had the title manager-industrial 18 health. 19 Q. You want to refer to those fellows as the 20 medical section? Did Monsanto have a medical department? 21 A. Certainly. 22 Q. Did they have them all the way to 1953? 23 A. 1973, you say? 24 Q. 1953. 25 A. '53? '53, yes, sir. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49437 13 1 Q. I'm goi]p ng to call that the medical 2 department. 3 A. That's all right with me. 4 Q. Now, how long did -- Let's come forward. I 5 want to come forward in time to 1957. You had a job 6 change in 1957. Tell us what it was and the nature of 7 your duties in 1957. 8 A. In 1957 I was assigned as a superintendent in 9 the maintenance department of the Queeny plant. 10 Q. And what did you supervise at that ]o plant? 11 A. I supervised the activities of about 400 12 mechanics, along with 30 or so foremen and a dozen or so 13 supervisors in their activities to either do construction 14 work in the plant or to maintain the equipment in the 15 plant. 16 Q. And did part of their jobs include repairing 17 malfunctioning equipment that contained PCBs? 18 A. Part of the job did include that, yes. 19 Q. That's the par]o t of the job I want to talk 20 about. How many people at the plant did you have that 21 were working with PCBs, that is, flushing or refilling 22 equipment that contained PCBs? Just roughly. It's a long 23 time ago. 24 A. I'll try to think of the numbers. There were 25 about 30 electricians that could at one time or another be Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49438 14 1 involved with the electrical equipment that contained 2 PCBs. There were about as ma]p ny maintenance men we had at 3 the plant called machinists who were involved with the 4 maintenance of pumps. Some of these pumps were involved 5 with pumping PCB type materials. And on occasion these 6 machinists would be involved working with those pumps. 7 There were about 60 pipefitters. These are individuals 8 who worked the pipelines and tubing. At sometime or other 9 these individuals would be working on pipelines or piping 10 systejp ms that contained PCBs. That, I believe, covers most 11 of the maintenance people that could at one time or other 12 be exposed to systems that had PCBs in them. 13 Q. Now, these were PCBs that were manufactured 14 by Monsanto? 15 A. Yes. 16 Q. At this point in time, now we're at 1957, 17 just about the time the Bloomington Westinghouse Electric 18 plant starts construction, for your information. p19 A. I understand. 20 Q. What did you warn -- Pardon me. What did you 21 know about the dangerous consequences from exposure to 22 PCBs in 1957? 23 A. '57. I knew that repeated exposure to the 24 skin would cause a reddening of the skin. And in order to 25 help me describe it, I associate it with the reddening Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49439 15 1 that I had seen on chapped hands. In some cases the 2 cracked skin with maybe a little oozing of ]o blood for the 3 severer cases. I also knew that if an employee breathed 4 too much of the fumes, one of the early warning symptoms, 5 and this is what I called it in my own thinking, would be 6 a chest irritation, pretty much like a severe cold. Those 7 two things served as my guideline for watching out for 8 situations where PCBs were not used properly. 9 Q. What else did you know in 1957? 10 A. I knew that if the conditjo ions continued, in 11 other words, no correction was made for the red skin and 12 the chest, sore chest problems, if it continued, that you 13 could expect to see a condition referred to earlier as 14 chloracne, a skin condition. 15 Q. You were told that that was just a skin 16 condition? 17 A. That was a change in the skin brought about 18 by too much PCBs in the body. And I also was told that if 19 you continued to exposjo e a worker to these conditions, you 20 could end up affecting the liver of the person. 21 Q. Damage the liver; is that right? 22 A. That is correct. 23 Q. You knew all that in 1957? 24 A. Yes, sir. 25 Q. What else did you know in 1957? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49440 1 2 3 4 5 6 7 9 10 11 12 p 13 14 15 16 17 18 19 20 21 22 23 24 25 16 A. Continuing along those lines, I also knew that if the conditions were corrected and the employee was removed from wha]o tever was causing his skin condition and chest raling, that the symptoms would disappear, and they'd be back to normal. Q. That's what you thought? That was your - A. That was my understanding, yes, sir. Q. Back in 1957? A. Correct. Q. In 1957 did you ever see a warning published by Monsanto that warned of liver damage? A. Q. an article. I recall reading some document. Okay. I thought you were going to refer to Go ahead. A. No. There is some document in Monsanto that I recall reading, and I -- Gosh, this has been almost 30 years ago. Q. I understand. A. I just don't recall what the specific document was. I do recall seeing it. And it seems to me I got it from the plant physician. That would be the place to get it]p . Q. The question was -- the question was can you recall -- and if you can't, say so -- a warning, a warning of liver damage to people who come in contact with PCBs? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49441 17 1 If you could answer that yes or no, I would appreciate it. 2 A. In writing or -- 3 Q. Yes. 4 A. I've seen it in writing. 5 Q. Warning to that effect? 6 A. Yes, sir. 7 ]o Q. Now, who would be the best person to have 8 that warning? The company? 9 A. Well, certainly a representative of the 10 company. In this case, the more I think about it, the 11 more it was the plant physician. 12 Q. In his files or records we would be able 13 to -- would that be the best place to look for this 14 document? 15 A. Well, that's where I would start, but I don't 16 know where they are, if theyjo exist at all. 17 Q. You don't think at this point in time there 18 would still be some drums, 55-gallon drums or a tanker car 19 with that warning on it, do you? 20 A. Well, that kind of warning never appeared on 21 any container or tanker car. 22 Q. It didn't? 23 A. No. 24 Q. Where did they appear? 25 A. In the written document that I would -- I Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49442 18 1 would^) call it a brochure that described the PCBs and their 2 uses and their characteristics and proper methods of 3 handling. 4 Q. I better ask the question more artfully 5 because I'm having a problem. I'm talking about warnings 6 to employees, workers who handled PCBs. Did you ever see 7 a warning back in 1957 with respect to liver damage that 8 the user of PCBs would receive? 9 A. When you say did I see, no, but I do know 10 that at safety meetings held with the workers -11 Q. Please, Mr. Papageorge, you have a lawyer who 12 can cross-examine you. I just want answers to my 13 questions so we have an orderly presentation. I know 14 there's a lot of things you want to say, but there's a lot 15 I have to cover. 16 THE COURT: Let's move on. 17 MR. CARNEY: He was answering. He was asking 18 him about warnings. He was givinjo g them to him. He cut 19 him off in the middle of a sentence. 20 THE COURT: (Inaudible) 21 Q. (By Mr. Kotoske) Did you ever see warnings 22 to employees in 1957, and I'm talking about the users of 23 these products, for example, (inaudible) manufacturing, 24 and you've heard these people from Westinghouse testify. 25 I'm talking about those folks. Did you ever see a warning Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49443 19 1 back in 1957 that used thp e word "chloracne"? 2 A. In order for me to answer the way I think you 3 want me, help me with your definition of "warning." Are 4 you talking about a label? 5 Q. Yes . 6 A. No, I did not see such a label with that word 7 on it, "chloracne." 8 Q. Did you see such a label with "liver damage"? 9 A. I did not. 10 Q. But you knew at that point in time that 11 repeated exposjo ure as you've described would cause both 12 liver damage and chloracne? 13 A. Yes . 14 Q. In '57? 15 A. Yes . 16 Q. Now, I want to go forward in time to 1961. 17 You got a new job in 1961, did you not? 18 A. Yes, I believe I know which job -- 19 Q. (inaudible) a little bit. 20 A. That would help. 21 Q. You became superintendent of technical 22 services ]o department in 1961. 23 A. Yes. I recall. 24 Q. What were your -- Just tell us what your job 25 was. We know you were a superintendent, but we don't know Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49444 20 1 of what and what your duties were. 2 A. That particular job, I was back in the plant 3 engineering department, and I had assigned to me anywhere 4 from six to a dozen engineers, depending on how much work 5 we had to do. We were expected t]p o study some of the 6 production processes in the plant and try to improve them. 7 They could either make the product better or lower cost or 8 safer, whatever it took in an engineering way to improve 9 the production units that we were assigned to. 10 Q. Now, in this job did you have any dealings 11 with PCBs? 12 A. No. 13 Q. That job continued till 1964. And you were 14 assigned to another plant? p15 A. I'm sorry. There is another assignment in 16 there. 17 Q. I missed one? 18 A. Yes. This '61 -- The position I just 19 described, I believe, now that I think about it, occurred 20 sometime between '59 and '60-'61. In about 1961 I was 21 assigned still at the Queeny plant as a general 22 superintendent of shipping, utilities, warehousing. It 23 was a sort of a miscellaneous type of services that my 24 departmjo ent would provide the production people to help 25 them produce their products. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49445 21 1 Q. When did you get assigned to the plant in 2 Sauget, Illinois? 3 A. In 1964. 4 Q. The date is 1964. What was the name of the 5 plant? 6 A. It's the William Krummrich plant, 7 K-r-u-m-m-r-i-c-h. 8 Q. And that plant is located where? 9 A. Sauget, Illinois. 10 l5 Q. That's not too far from here? 11 A. It's across the river. 12 Q. What did that plant make? 13 A. Oh, they made over a hundred different 14 chemical products. 15 Q. Let me cut right to the point. Did that 16 plant manufacture PCBs? 17 A. Yes. 18 Q. Now, aside from that plant that manufactured 19 PCBs across the river, what other plants did Monsanto have 20 that ma]p nufactured PCBs in the United States? 21 A. We had one additional plant, Anniston, 22 Alabama. 23 Q. I want to return to the Sauget, Illinois, 24 plant. Am I saying that correctly? 25 A. Yes. It's okay by me, yes. That's all Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49446 22 1 right. 2 Q. I don't think I am, but I'll take your word 3 for it. This plant made PCBs. What kinds of PCBs did it 4 make? 5 A. I ca]o n describe that, I guess, by using 6 Monsanto's trade names and numbers. 7 Q. Sure. 8 A. Would that help? They made Aroclor 1221, 9 Aroclor 1232, Aroclor 1242, Aroclor 1254, Aroclor 1260, 10 Aroclor 1016, and another one that was later referred to 11 as Capacitor 21. 12 Q. All those are PCBs? 13 A. They are mixtures of PCBs, yes. 14 Q. I want (inaudible) footnote in this 15 conversajo tion. Were all PCBs that you made at that time 16 manufactured roughly the same way? 17 A. Roughly, yes. 18 Q. They were similar products, is what I'm 19 trying to establish. I know they have different 20 chlorinations, but roughly they are all made the same way? 21 A. The same way. The temperatures and pressures 22 and process would change, but the procedure was the same. 23 Q. Is it fair to say they are sip milar products? 24 I don't want to (inaudible). They were PCB products? 25 A. Yes. That's all right. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49447 23 1 Q. And do you (inaudible) similar? 2 A. Well, it depends on what you're talking about 3 in trying to make them similar. 4 Q. Well, the general manufacturing process, you 5 didn't have a specific plant for 1216 and a specific plant 6 for 1242, did you? 7 A. No, si]p r. 8 Q. They were all made in the same plant? 9 A. Yes, sir. 10 Q. At about the same time? 11 A. They would be scheduled throughout the year. 12 So many pounds would be produced and put in storage, and 13 then another type would be manufactured and so on. 14 Q. Now, in 1964 the Krummrich plant was making 15 PCBs. How many workers do you have in that plant that 16 were making PCBs? p17 A. Oh, since I wasn't involved with that unit, I 18 really don't know 19 Q. Roughly. Can you give us some (inaudible)? 20 A. It would be a big, big guess on my part. 21 Q. Give us an estimate. Is it more than 10? 22 A. Yes. I would suggest it's about 40 people in 23 the operating unit and supported by about a dozen 24 maintenance people. 25 Q. And the workers that were making PCBs, did Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49448 24 1 they make all the different types of PCBs that you 2 mentioned or did you have special workers that made a 3 special type? 4 A. No. They all participated in making the 5 different PCBs. 6 Q. All right. In 1964 what did you know the 7 dangerous consequences from exposure to PCBs to be? 8 A. In 1964 I had the same knowledge that I 9 learned back in 1957. 10 Q. Hadn'tjo learned anything different? 11 A. That is correct. 12 Q. Now, in 1964 did you ever see a warning label 13 on a Monsanto drum of PCBs that warned workers like these 14 capacitor plaintiffs in this case that exposure to PCBs 15 could cause liver damage? 16 A. I did not. 17 Q. Did you ever see in 1964 a warning label to 18 the plaintiffs in this case, for example, that were 19 exposed to PCBs in the capacijo tor manufacturing process 20 that exposure to that chemical could cause chloracne? 21 A. I did not. 22 Q. How long did you remain there at that job as 23 superintendent of the plant that made PCBs? 24 A. Oh, I was never superintendent of the -- 25 Q. I must be mistaken. What was your job? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49449 25 1 A. I was one of six, general superintendent of 2 manufacturing. p3 Q. Did the general manufacturing that you 4 supervised include the manufacturing of PCBs that you just 5 described? 6 A. It did not. 7 Q. Did that job belong to somebody else? 8 A. Yes. 9 Q. Who? 10 A. Paul Heisler. 11 Q. How do you spell his name? 12 A. H-e-i-s-l-e-r. 13 Q. Now, in 1965 -- And I'm coming forward in 14 time. In 19 65 did you have a]p job change? 15 A. I did. 16 Q. In 1965 what was your job? 17 A. I was assigned as plant manager of the 18 Anniston, Alabama, Monsanto plant. 19 Q. That plant made PCBs also? 20 A. It did. 21 Q. It was the only plant at that time in the 22 United States that made PCBs? 23 A. That is correct. 24 Q. Now, you run the second plant. Let's talk 25 about th]p at. How many -- First we need to know what your Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49450 26 1 title was. 2 A. Plant manager. 3 Q. For the whole plant this time, right? 4 A. That is correct. 5 Q. Promotion? 6 A. Yes . 7 Q. How many employees did that plant have? 8 A. At what point in time? 9 Q. Well, just when you come aboard. 10 A. About 150. 11 Qp . Were they all making PCBs? 12 A. No. 13 Q. Now, let's just talk about that group of 14 employees that were making PCBs. How many of them did 15 that? 16 A. About 35. And that's about that number. 17 It's not exact. 18 Q. That's fair enough. Just to give us an idea. 19 What type of PCBs did they make at that plant? 20 A. They made the same types that I described 21 earlier for the]p Sauget, Illinois, plant. 22 Q. And the Sauget plant made the same as they 23 made in Anniston, Alabama? 24 A. That's right. 25 Q. Why did you have two plants that did that? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49451 27 1 A. Primarily to make certain that we had a 2 second source of supply in the event some accident. Let's 3 say a fire occurred. That we could continue supplying our 4 customers. 5 Q. Did the sam]o e employees make all of the PCBs 6 that you described? 7 A. Yes, at the time. 8 Q. Were they all made (inaudible)? I don't mean 9 the same process, but a similar manufacturing process? 10 A. Yes. 11 Q. And were they all basically similar products, 12 PCB products? 13 A. They fit in that family, yes. 14 Q. All right. Now, this plant had protective 15 clothing that the peopjo le wore who were working with PCBs, 16 did it not? 17 A. Yes. 18 Q. Now, let's just spend a minute on the idea of 19 protective clothing that Monsanto workers used in 20 manufacturing PCBs. Did they use a rubber apron? 21 A. Not an apron, no, sir. 22 Q. What was it? 23 A. On occasion they had access to a rubber sort 24 of an over-pants and a rubber -- like a short raincoat p25 that they had. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49452 28 1 Q. Rubber gear? 2 A. Rubber gear. They hadaccess to that, yes. 3 Q. How about gloves? 4 A. They had access to gloves, yes. 5 Q. Now, this is kind of a (inaudible). These 6 are not cloth working gloves, are they? 7 A. Well, they had access to those also 8 Q. Describe -- All right. (Inaudible) 9 Describe the various types of gloves t]p hat they had access 10 to. 11 A. They had the -- what I'm going to call the 12 cloth, canvas type glove. They had a glove which had a 13 plastic coating on it. They also had leather gloves. And 14 they also had a specialized rubber type of glove. 15 Q. Being (inaudible) to below the elbow? 16 A. There were two kind. There was a short cuff 17 and the higher cuff. p18 Q. Footwear. I want to talk about footwear. 19 What kind of footwear did they use in making PCBs? 20 A. They were issued a work shoe, steel-toe 21 leather with an oil resistent sole. And when that was 22 damaged because of the exposure to oils and PCBs and what 23 have you, they would be replaced. In addition to that, 24 they had what we called at the plant a bootie, which is a 25 rubber -- looks like a winter over-shoe, which was made of Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49453 29 1 a rubberjo that was a little bit more resistent to PCBs than 2 the ordinary rubbers would be. 3 Q. Before we go on, I (inaudible) put a thought 4 in here. Did the workers at your plant experience this 5 situation where their shoes would deteriorate fairly 6 rapidly if they did not use protective footwear? 7 A. If they didn't use a protective footwear, 8 yes. Their shoes were not designed to withstand the PCBs. 9 So they would havejo to throw them away and get new ones. 10 Q. I want to move up the body. We have the 11 rubber gear, the booties and the gloves. What did they 12 wear on their face? 13 A. When appropriate, they would have available 14 to them what we call a respirator. It's a mask that 15 filters out chemicals. 16 Q. PCBs? 17 A. PCBs being one of them, yes, sir. 18 Q. And the fumes from PCBs? 19 ]p A. Yes. 20 Q. Did they have headgear? 21 A. Yes, we did. They had the cloth cap like a 22 baseball cap, and later this was replaced with the hard 23 hat. 24 Q. Okay. How long did you work at the Anniston 25 plant? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49454 1 2 3 4 5]p 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 30 A. About five years. Q. That would bring us up to1970? A. Correct. Q. Now, between 1965 and 1970 what were you aware of as to the dangerous consequences from exposure to PCBs? If it hasn't changed, say so. And if it has, if you've learned more, tell us. A. It hadn't really changed any. I just made certain that I reviewed everything and reassured myself that my understanding was correct, and it turned out it was. Q. We'll get to that in a minute. Up to 1965 when you go to Anniston -- Are you with me in the]p time? A. I didn't hear that last word. Q. Anniston, Alabama. A. Yes. Q. The other plant. A. Yes. Q. Up to that point in time did you ever see a warning label on any drum, any tanker car, onanything directed at the users like the plaintiffs in this case that exposure to PCBs can cause liver damage? A. No, I did not. Q. p Did you ever see a warning label that warned people that were using PCBs that they could get chloracne? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN {2\ TOWOLDMONOQ49455 31 1 MR. CARNEY: Your Honor, I take it we are 2 still talking about labels on drums and tanker cars? 3 THE COURT: Yes. 4 MR. CARNEY: Okay. 5 A. I did not. 6 Q. (By Mr. Kotoske) Now, in 1969 you ended your 7 tenure at the Anniston plant in Alabama. What hap ppened -8 Was it '69? 9 A. Through the end of '69, yes, sir. 10 Q. What was your next job? 11 A. I was appointed as manager-environmental 12 control, reporting back to St. Louis in the home offices 13 of Monsanto. 14 Q. Did you return to St. Louis or stay in 15 Alabama? 16 A. I returned to St. Louis. 17 Q. At the world headquarters? 18 A. Yes, sir. 19 p Q And the medical department was in the 20 headquarters (inaudible)? 21 A. Yes . 22 THE COURT: What was your title again? I'm 23 sorry. 24 THE WITNESS: Manager-environmental control. 25 THE COURT: Thank you. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49456 32 1 Q. (By Mr. Kotoske) That job actually started 2 in January of '70, didn't it? 3 A. Yes, sir. p4 Q. Now, what qualifications did you have with 5 the position that you were appointed to? 6 A. I don't quite know how to answer that, other 7 than I did have experience with the manufacture of PCBs 8 and the handling of PCBs and the disposal wastes from 9 PCBs, and I suppose my technical change has formed part of 10 my qualifications. 11 Q. Now, I want to return to the title of the 12 job. Tell me the title again. 13 A. Mp anager-environmental control. 14 Q. Was that a new job? 15 A. Yes, sir. 16 Q. Just created? 17 A. Yes, sir. 18 Q. About 1970? 19 A. Yes, sir. 20 Q. What caused Monsanto to create that job? 21 A. There were reports that PCBs were being found 22 in the environment. And as a result of those reports and 23 Monsanto's studies that confirmed that these reports wep re 24 valid, true, management saw a need to appoint somebody to 25 look into this situation. And that somebody turned out to Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2( TOWOLDMONOQ49457 33 1 be me. 2 Q. The job (inaudible)? 3 A. Yes, sir. 4 Q. Now, did those reports that you were 5 receiving about the environment also include animals, 6 birds, fish, rivers, streams? 7 A. The early reports, I don't recall them 8 including animals.]o They did include the others that you 9 mentioned. 10 Q. And what did those reports, later confirmed 11 by Monsanto, illustrate? 12 A. They illustrated thatPCBs that contained 13 5 chlorines per PCB group or more were being found by the 14 analytical chemists in samples taken from rivers, streams, 15 fish, birds. That's it. We were able to confirm that 16 what they were seeing was in truth a PCB. 17 Q. Manufajo ctured by Monsanto? 18 A. Not necessarily. There wereseveral 19 worldwide producers. 20 Q. And where were the scientists finding these 21 PCBs? Globally? 22 A. Yes. 23 Q. Throughout the planet? 24 A. Well, there were some areas of the planet 25 that were not analyzed, but it certainly started up in Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49458 34 1 Sweden and down through Europe and in North America. p Q.2 And you were finding, were you not, about 3 this time, not you, but the scientists, that animals, 4 birds, fish were dying from the toxicity of PCBs? 5 A. I don't remember any report that associated 6 the death of animals with exposure to PCBs. 7 Q. What PCB levels were you finding in the fish, 8 birds and animals in the early '70s? 9 A. I would have to review the literature. I 10 don't remember the numberjo s. 11 Q. In about the 1970's did you also find that 12 the peoplehad background levels now of the PCBs? 13 A. In 1970? 14 Q. Yes. 15 A. No. I don't recall any studythat 16 demonstrated a background level. 17 Q. You know now, do you not, that every one of 18 us has a background level of PCBs? 19 A. Oh, I don't know about every one ofus. Many 20 of us, but I don't know aboutjo every one of us. 21 Q. In order to carry out your job in connection 22 with the environmental concerns -- (Inaudible) interrupt 23 myself. Were you concerned at the same time about toxic 24 effects in humans from PCBs? 25 A. Well, certainly that question was raised, and Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49459 35 1 Monsanto tried to address it, yes. 2 Q. It was part of the environmental concern as 3 well, was it not? You're finding thesjo e levels in the fish 4 and streams, and people are eating the fish and so forth, 5 you were worried also about the human background levels of 6 PCBs ? 7 A. Exactly, yes. Q. The two were inextricably intertwined? 9 A. Which two, sir? 10 Q. The environmental concerns, if you pull them 11 apart, and the human concern? 12 A. Well, I associate the environmental route to 13 the human ex]o posure is very important. 14 Q. Fine. Had you heard of the Yusho accident in 15 1970? 16 A. That's when I first heard of it, yes. 17 Q. What did you hear about it? 18 A. I heard that an incident had occurred in a 19 prefecture of Japan called Yusho in which an oil that was 20 intended for human consumption, human use, had been 21 contaminated with PCBs, and many cases of illnesses were 22 reported. 23 Q. Now, did those illnesses include heart 24 damage? 25 A. I don't remember heart damage. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49460 36 1 Q. Lung damage? 2 A. No. Again, I don't remember lung damage. I 3 remember pigmentation, watery eyes, nausea, lack of 4 appetite, weakness, inability to sleep. Those are the 5 illnesses I recall being described. 6 Q. Dizziness. Do you recall thatone? p7 A. I don't recall that, but -- 8 Q. Joint pain and muscle pain? 9 A. I don't recall that either, but that's 30 10 years ago. 11 Q. Now, you knew that in the reports of the 12 Yusho incident. My question to you is did Monsanto ever 13 have a warning on its tankers or its drums to say 14 (inaudible) the people that were working with the PCBs, 15 for example, the plaintiffs in this, that exposure to PCBs 16 could cap use liver damage, chloracne, dizziness, vomiting 17 and the other symptoms that you just described? Did you 18 ever see a warning label in 1970 describing those 19 conditions as we have just discussed them? 20 A. I have not. 21 MR. KOTOSKE: Judge, can we go to the side 22 bar for just a minute? 23 THE COURT: Sure. 24 (A bench discussion was held.) p25 Q. (By Mr. Kotoske) I need to change the Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49461 37 1 subject a little bit, but I want to stay in the same time 2 frame. We are in 1970. In this connection I would like 3 you to tell us what efforts did you undertake in this new 4 position -- I'm just going to call it environment 5 toxicology. Whatever you want to call it. 6 A. Environment is a better word, yes. 7 Q. Let's just call it that. What efforts 8 efforts did you undertake to be]o come acquainted with the 9 adverse health effects attendant to exposure to PCBs? 10 A. For which creatures? 11 Q. Anybody. 12 A. Any person or bird or -13 Q. (Inaudible) 14 A. Human? 15 Q. From the top of the chain to the bottom of 16 the chain. I just want to know what you did to try to 17 educate yourself on this score since Monsanto selected you 18 as the man to run thisjo program, right? 19 A. That is correct. Myinitial efforts were 20 concentrated on, I'm going to call it atutorial, where 21 Mr. Wheeler taught me the basic ideas concerning medical 22 and toxicology terms. He showed me the medical library. 23 He had copies of appropriate articles accumulated in a 24 book as thick as the St. Louis telephone directory. That 25 was my homework assignment. And I spent I don't know how Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49462 38 p1 many hours with him one-on-one where he coached me. In 2 addition to that, when the opportunity presented itself, 3 he would take me along when he visited individuals in that 4 field. For example -- 5 Q. What field? 6 A. In the field of PCBs and health effects. For 7 example, he was able to take me along to visit individuals 8 that were involved with the Food and Drug Administration 9 where they discussed the ongoijo ng studies that Monsanto had 10 on PCBs and test animals. He was able to take me to visit 11 with government laboratories that were involved in testing 12 of fish and shrimp and the like. That in a general way 13 describes the overall program of my attempts to become 14 familiar with that part of the environmental problem. 15 Q. Now, you knew -- Strike that. Did you ever 16 learn from anyone that Monsanto itself as early as the p17 early '30s and late '30s, 1930's, four years before you 18 took this job, had conducted toxicity studies on animals 19 exposed to PCBs? 20 A. Certainly. 21 (Ms. Pape replaced Ms. Carter.) 22 23 24 25 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49463 39 1 Q. Did you read 'em? 2 A. Yes. 3 Q. And you were aware of the information that was 4 in the Drinker Study--I think you called 'em something else, 5 but studiesjo ? 6 A. I understand. I was made aware in '70, yes. 7 MR. KOTOSKE: I'm gonna (inaudible). 8 THE COURT: Want to take a break? 9 MR. KOTOSKE: Yeah. 10 THE COURT: All right. We'll take a ten-minute 11 break. Let's try to keep it to ten minutes if we can. Do 12 not discuss the case among yourselves or with others. 13 (A recess was taken, after which the 14 ]o following proceedings were had. ) 15 THE COURT: Proceed, please. 16 BY MR. KOTOSKE: 17 Q. In the 1970s when you assumed the new 18 job--this environmental job--to whom did you report? 19 A. It varied through the--are you talking about 20 the whole ten years--'70s--or 1970? 21 Q. '70s. 22 A. '70s? 23 Q. '70--I'm gonna go back-- 24 THE REPORJo TER: Are you saying seven Ts? 25 THE WITNESS: '70s. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49464 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 lp 8 19 20 21 22 23 24 25 40 THE REPORTER: Seven Ds? THE COURT: '70. Q. I'm gonna go back and fill in the year, but this job for you stopped in about 1976, did it not? A. I did, yes, sir. Q. So we have a time frame. 1970 to 1976. A. All right. Q. But during that period of time, goip ng across the board from the '70s to 1976, to whom did you report? A. Initially I reported to Mr. Howard Bergen--B-e-r-g-e-n. Q. Now, you have to tell us the titles of these gents in the company. A. I'll try to remember them all. He was the business director of the Functional Products Business Group. Q. Was he on the executive committee? A. No, sir. Q. All right. A. Following that, I was reporting to Mr. Wendell Corey--C-o-r-e-y. And I believe he was director of administration for Monsanto Industrial Chemicals Company, an operating unit of Monsanto. Q. Was he at the executive level of the company? A. No, sir. Q. All right. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49465 41 p1 A. As best I recall, I was then reporting to 2 Robert Potter--P-o-t-t-e-r. I believe at that time he was 3 director of Specialty Chemicals. I'm not positive of that, 4 but that describes it fairly well. And that's it, as best I 5 recall. 6 Q. Did the president of the company know what you 7 you were doing? 8 A. Certainly. 9 Q. Did the vice-president 'stratosphere' of the 10 company know what you were doing? r11 A. Wel^) 1 they knew what I was doing, but not 12 every detail, of course. 13 Q. I understand. I understand that. They 14 understood the thrust of what you were doing? 15 A. That is correct. 16 Q. At the very highest level of Monsanto? 17 A. Yes, sir. 18 Q. It's true, is it not, that in 19--that in 1970 19 there was discussions in the company to quit making PCBs 20 altogether? 21 1) A. Yes. 22 Q. Why? 23 A. The discussions regarding termination of 24 production and sales were centered around the environmental 25 presence. And it was decided among many of the thinkers in Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49466 42 1 Monsanto associated with this group of products that if 2 alternative materials could serve the same purpose, perhaps 3 the wisest thing to do is not produce these materials since p4 they are being found in the environment and that's not the 5 intended place for 'em. 6 Q. They were never there before you produced 'em; 7 is that right? 8 A. I can only guess to that. I have no other 9 reason to--to believe differently. 10 Q. PCBs are persistent, are they not? 11 THE REPORTER: They're what? 12 MR. KOTOSKE: Persistent. 13 A. Some of the members of the PCB fa]o mily are 14 persistent. 15 Q. That means they stay in the environment and 16 they stay in your body? 17 A. Well, I--I feel more comfortable with the 18 statement with the understanding that they stay in the 19 environment, because that's been demonstrated. I, not being 20 a medical person, I don't know how to describe the reference 21 to staying in the body. I'll have to go to a medical person 22 and ask that. 23 Q. What's the half-life of the PCB that Monsanto 24 manufactured? 25 A. I have never heard a scientifically-developed Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49467 43 1 answer to your question. It's rather difficult to arrive at 2 because the conditions throughout the world are not the 3 constant, but there have been speculation of something like a 4 generation, or some people say decades. Lacking a scientific 5 number, the rest is all g]p uesswork. 6 Q. And you've never been told by anybody at 7 Monsanto what the precise half-life of PCBs are? 8 A. That is correct. 9 Q. As far as you know, Monsanto doesn't even 10 know? 11 A. That is correct. 12 Q. Well, you didn't stop production in 1970, did 13 you? 14 A. No, sir. 15 Q. You kept on producing PCBs; is that right? P16 A . For specific purposes, yes. 17 Q. Did you change your warning labels on the 18 drums and on the tanks? 19 A. Yes, we did. 20 Q. What did you say now? 21 A. We had a reference to the fact that these 22 materials---PCBs--were being found in the environment, that 23 they could be causing some harm to--these are not the exact 24 words 25 Q. I understand. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49468 44 1 A. They could be causing some damage out there in 2 the environment. That every care should be taken in its 3 proper handling, shipment, use, disposal, and don't let it 4 get into the environment, or words to that effect. 5 Q. I understand. That was about 1971 or '72 you 6 did that? 7 A. No, this was in May of 1970 when that was 8 added to the containers. 9 Q. Now, at the time yo]o u changed the labels with 10 respect to the warning as to the environment, did you change 11 the warning with respect to the human health consequences 12 from exposure to PCBs? 13 A. No, there were no reference to health 14 consequences -- 15 Q. Thank you. 16 A. --on the label. 17 Q. The other day Dr. Kelly testified in this case p18 concerning his letter of March 30th, 1970, when he said the 19 company had a duty to warn our people that there was gonna be 20 (inaudible) and legal overtones. Do you remember my reading 21 that? 22 A. Yes, I do. 23 Q. And then I said, what did you do about it, 24 Dr. Kelly. And he said he called you and you told him, 25 Dr. Kelly, you're behind the times --or words to that effect. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49469 45 1 What had you done? 2 A. Up to the time that Dr. Kelljo y prepared that 3 note -- 4 Q. It was a letter. 5 A. That was a Monsanto memorandum as 6 distinguished from a letter sent to outside. Up to that 7 point, consideration had already been given and action 8 started on removing the use of PCBs in the paints that 9 Dr. Kelly was referring to. This was part of the overall 10 program that was later broadened for removal of PCBs from all 11 uses that are, by Monsjo anto' s definition, considered to be 12 open uses. 13 Q. Let's (inaudible) into that section of the 14 testimony. What are some of the open uses that Monsanto made 15 PCBs for? 16 A. I'll try to think of some of them. 17 Q. Just give us a half a dozen or so. 18 A. I'll try. It was used as an ingredient in 19 sealants and caulking, such as the type that's used in the 20 glass windows in the ]o skyscrapers. It's used as an ingredient 21 in special varnishes and paints. It's used as an ingredient 22 in the carbonless copy paper where the pencil breaks the 23 bubble and releases the ink and makes the copy. It was used 24 as a--we call that plasticide. This is a material added to 25 plastics to make them flexible. I'm sure there are other Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49470 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 p 18 19 20 21 22 23 24 25 46 uses; they just don't come to mind at the moment. Q. Those werp e examples of open uses--quote, open uses ? A. That's what we called them. They were the uses that when--when applied to a surface or to an article, it was beyond the control of the user as well as supplier. Q. (Inaudible). What about closed systems? What did Monsanto understand by the phrase closed system? A. We used that expression to describe those systems where the liquid--the PCBp s --along with other ingredients, were in containers that were sealed, or in piping systems that when properly maintained would not permit PCBs to leak out and get out of control. This included, under our initial thinking, the uses in the electrical equipment, the hydraulic fluid systems and the heat transfer systems. That was our initial understanding or definition. Q. 63 percent of all PCBs that Monsanto produced in a year were used by the electrical industry; is that true? A. That sounds like a good percentage, yes, sir. Q. How much of the PCBs in a year that Monsanto produced were used in the open applications? A. I'm gonna estimate on this and I'm gonna say about 15 percent. Q. And of that 15 percent of PCBs, once it was first put into its applications (inaudible) out of control? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49471 47 1 A. Most--in those applications, yes. 2 Q. But you kept on making the PCBs for closed 3 systems, and it was not until 1972--two years later--that you 4 stopped selling PCBs altogether for open applications? 5 A. That's not correct. 6 Q. Which statement is not correct? 7 A. The 1972 date as you referred to the open 8 systems. 9 Q. Yes. 10 ]o A. Unless we have a different definition of open 11 systems. The open systems that I described earlier were 12 terminated--the majority of them--in August of 1970. The 13 carbonless copy paper, because it's technologically very 14 difficult to find a replacement, took a little longer. And 15 as best I recall, we completed that by the end of the first 16 quarter of 1971--about March or April of '71. 17 Q. Yes. What aboutjo the other applications of 18 open--other open applications? When did you stop those? 19 A. I think that describes all of what I--what we 20 call open. Now, we had, as I mentioned, the hydraulic 21 systems and the heat transfer systems -- 22 Q. When did you stop -- 23 A. --that were, in our minds, closed systems. 24 But we found out they were difficult-to-control closed 25 systems, so we made another decisionjo to get out of those Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49472 48 1 closed systems that were difficult to control. 2 Q. When did you make that decision? 3 A. Oh, that was made starting in 19--late 1970 we 4 started reformulating the hydraulic fluids and got into a 5 program of changing out heat transfer systems with alternate 6 fluids. 7 Q. Did you start talking to the United States 8 government along about 1971 about the prop blem with the PCBs? 9 A. When you say you, it's me personally or 10 Monsanto? 11 Q. Monsanto. 12 A. Monsanto? Oh, Monsanto talked to the 13 government representatives--that was before I was assigned 14 this job--in the late '60s. 15 Q. When did you start talking to the federal 16 agencies ? 17 A. Right after I was assigned the manager of 18 Environmental Control job. Thip s would have been January, 19 February, 1970. 20 Q. Now, the IBT studies--do you know what I'm 21 talking about--the IBT Arochlor studies? 22 A. I believe I do, yes, sir. 23 Q. A man testified this morning about it 24 A. Yes, sir. 25 Q. Mr. Smith? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49473 49 1 A. Yes, sir. 2 Q. Did you use those studies in your presentation 3 to the Fed]o eral Government about the toxicity of PCBs? 4 A. I used--when I was alone--traveling alone and 5 discussing PCBs with the representatives of the Government, I 6 used summaries prepared for me by Mr. Wheeler of Monsanto's 7 medical department. When Mr. Wheeler could join me, he, of 8 course, spoke for the medical department. I did not--I 9 didn't play that role. 10 Q. Did he have the studies with him? p11 A. At what point in time? 12 Q. At any point in time. I want to be sure. The 13 studies that I'm talking about during this part of your cross 14 examination are the studies that were identified this morning 15 by Mr. Smith. And you heard his testimony? 16 A. I did. 17 Q. And they are comprised of three studies that 18 make up Exhibit No. 12. Maybe I should get Exhibit 12 for 19 you. Maybe I should do th]o at. Here they are. If you need to 20 look at 'em at all, Mr. Papageorge, I want you to take your 21 time, because I'm very interested in what you did with those 22 studies after you received 'em. 23 A. I'm familiar with the studies that are 24 described by this exhibit, yes, sir. 25 MR. KOTOSKE: For the record, that's Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49474 50 1 12--Plaintiff's 12. Did you rely on those studies when you 2 were talking top , for example, any federal agents about 3 controlling PCBs or the toxicity of PCBs? 4 A. Certainly. I hesitate because there were 5 increment studies or reports--one- or two-page summaries that 6 I was using during the period '70, '71, when this final 7 report was issued. I was not the one to share that with the 8 proper people in the Government. Mr. Wheeler did that. 9 Q. Now, let's (inaudible). Were you ever present^ 10 when Mr. Wheeler shared the results of those studies in 11 Exhibit 12 with the Federal Government? 12 A. I was in some instances, yes. 13 Q. How many instances? I don't want (inaudible). 14 It's not the point. I want to know how frequently Monsanto 15 relied on these studies. When I say those studies, for the 16 record, I mean Exhibit 12 during this part of the 17 examination. 18 A. I don't knojo w that I could describe it in terms 19 of frequency, but this is the only long-term 'feeding' study 20 data Monsanto had for many years. Therefore, it had to rely 21 on these reports and their conclusions. 22 Q. All right. How many different federal 23 agencies did you meet with when those studies were presented 24 as to the toxicity of PCBs? We know one was EPA; is that 25 right? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49475 1 2 3 4 5 6 7 9 10 Vp 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 51 A. Yes, sir.]p Q. The next one was theFDA? A. That is correct. Q. And the FDA was trying to regulate PCBs in milk, fish and some other animals? A. I don't know about animals. Other food items. Q. They were trying to regulate the amount of PCBs that we were eating; is that true? A. That's true. Q. And they were trying to regulate in the milk that we were drinking? A. That's true. Q. Who else did youmeet with? A. I recall the Department of Agriculture representatives. Q. Why did you meet with them? What were they trying to regulate in PCBs? A. Well, the Department of Agriculture is involved with the quality of poultry and meat that the public consumes. Q. All r]p ight. And they were trying to regulate the amount of PCBs in cattle--food that we were eating? A. I don't know that they had reached a point of regulating, but they were interested in the information to determine whether they should regulate. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49476 52 1 Q. And this regulation was (inaudible) designed 2 to prevent the amount of PCBs that humans got in their 3 system; isn't that true? p4 A. When regulation was finally promulgated, if it 5 were, that was the intent, yes. 6 Q. Thank you. Did you actually use those 7 studies--may I have that stricken. When you were present 8 when Dr. Wheeler presented these studies, what did you hear 9 him say about the validity of the studies? 10 A. I don't know that the word validity ever was 11 used in the conversation. The report was represented as 12 sometjo hing Monsanto received from the laboratory, and it 13 concluded--it included the data and the conclusions. And we 14 offered it to them for their experts to review. 15 Q. Each of these federal agencies have copies of 16 those reports -- 17 A. Yes, sir. 18 Q. --in Exhibit 12? 19 A. Each of those that wediscussed. 20 Q. I understand. 21 A. Plus others that I personally w]p as not present 22 when these documents were given to them. 23 Q. Let's move ahead in time to the year 1972. By 24 this time in 1972, the Federal Government had formed a full 25 Federal Injury Agency Task Force on PCBs; isn't that true? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49477 53 1 A. In 1972--let me --as I understood it, this 2 group had been formed in 1971. 3 Q. Now, I want the jury to know--can you describe p4 the function of this PCB task force? 5 A. I'll try. This group consisted of 6 representatives from many U.S. federal departments, agencies, 7 administrations that --for example, the Food and Drug 8 Administration person was there, the person from the 9 President's office of Science and Technology, the Council of 10 Environmental Quality, the Department of Agriculture, the 11 Department of Defense, the Department of Interiors, the 12 Department t of Commerce. That's not the complete --I' m giving 13 you an example of the types of the representatives that were 14 there. And they were all addressing PCBs and the 15 environment, trying to determine how each of their 16 departments and agencies might be involved or should be 17 involved and in what way. 18 Q. And they asked Monsanto to provide them--the 19 agency--with some toxic--toxicolog --information on the p20 toxicity of PCBs--how dangerous was it? 21 A. Yes, they did. 22 Q. And what did you give them in response? 23 A. By that time --let me see. In 1971, right 24 after the reports we just discussed were available to 25 Monsanto, most of the representatives of that group, or at Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49478 54 1 least their agencies, had received copies of these reports. 2 Q. Exhibit 12? 3 A. Exhibit 12. 4p Q. In addition to that, Elmer Wheeler was invited 5 to attend one of their meetings. And I was along with him 6 and others, and Mr. Wheeler was given an opportunity to 7 discuss with this group what Monsanto knew about PCBs and the 8 health effects and animal testing. 9 Q. Now, with respect to health effects, you told 10 'em about chloracne? 11 A. Yes. 12 Q. Did you tell 'em about liver damp age? 13 A. Yes. 14 Q. Did you tell 'em about the results of the 15 Yusho study as you knew 'em? 16 A. Well, we discussed Yusho, but there were 17 people in that room that knew more about Yusho than we did. 18 Q. Now, with respect to the toxicological 19 information or toxicity of Aroclors, you gave the reports 20 from Exhibit 12? 21 A. Yes, plus others. 22 Q. Di]p d you give 'em the Drinker Studies that 23 Monsanto contracted for in the 1930s? 24 A. Yes, sir. 25 Q. But you still hadn't changed the warning label Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49479 p6 55 on tanker cars and the drums as to the human element or effects with respect to humans? A. That's true. Q. Now, I want to move ahead in time to 1974. By this time, there was a full-blown battle going on. On one side there was Monsanto and the electrical industry, and on the other side, there was a government seeking to regulate PCBs. Is that a fair statement? And if it's not--if it's an exaggeration or out of proportion at all, I want you to correct me. A. I--I personally didn't see it the way you described it. In 19 -- Q. Let me get the board and I'll (inaudible). pMR. KOTOSKE: Your Honor, can I pick a good place to stop when we finish the government positions? THE COURT: You mean for another break or for the day? MR. KOTOSKE: For the day. THE COURT: But let me ask you, do you expect to be done on direct today? MR. KOTOSKE: No, not at this point. THE COURT: I would like to go to (inaudible). BY MR. KOTOSKE: Q. I wouljp d like to ask you some questions, Mr. Papageorge. What is NEMA? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2 TOWOLDMONOQ49480 56 1 A. NEMA is the term used to describe the National 2 Electrical Manufacturers Association. 3 Q. Now, Monsanto is not a member? 4 A. That is correct. 5 MR. CARNEY : Mr. Kotoske, I don't think some of the 6 jurors are gonna be able to see it. 7 Q. Is Westinghouse a member? 8 A. ]p Yes. 9 Q. Is GE? 10 A. Yes. 11 Q. These two alone represent the biggest users of 12 PCBs and electrical capacitors, transformers, in the 13 United States, do they not? 14 A. That is correct. 15 Q. You, however, became chairman of the ANSI 107 16 committee (inaudible) at one time? 17 A. Yes, I was. 18 Q. Now, that committee had as its function what?]o 19 And you were the chairman of this committee? 20 A. Yes. 21 Q. What was its function? 22 A. The committee was to put together a standard 23 on the proper use and handling of PCBs in electrical 24 transformers and capacitors. 25 Q. Did you ever accomplish that task? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49481 57 1 A. Yes, we did. 2 Q. When? 3 A. The standard was finallyjo published in January 4 of 1974. 5 Q. We had the EPA at this time in the '70s--about 6 '74--who was seeking to ban PCBs altogether; isn't that true? 7 A. There were individuals in EPA that were 8 striving for such a ban but, officially, EPA, to my 9 knowledge , did not have that posture or that position. They 10 wanted to control it. 11 (Ms. Pape was replaced by Ms. Olliges.) 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49482 58 1 Q. The FDA was seeking to set limits; was it 2 not? 3 A. Yes . 4 Q. On PCBs in our food? 5 A. Yes. 6 Q. There was a federal agency who was seeking to 7 control PCBs in the water? 8 A. That's EPA, yes. 9 Q. You are quite (inaudible). I was wrong. 10 They control the water. There were officials that were 11 trying to control EPA -- PCBs in the workplace? 12 A. Yes. OSHA. 13 Q. Thank you. But NEMA and the committee that 14 you chaired wanted to keep using PCBs - 15 MR. CARNEY: Object. 16 Q. --in closed application? 17 MR. CARNEY: It's a compound question. NEMA 18 is one group and - 19 THE COURT: Sustained. Rephrase it, please. 20 Q. The committee that yo]o u chaired was seeking to 21 continue to use PCBs; were they not? 22 A. Yes, sir. 23 Q. On the other hand, certain agencies of the 24 government wanted to ban them altogether? 25 A. That's not correct. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49483 59 1 Q. What is your position on that score? 2 A. The federal agencies were trying to control 3 the presence of PCBs in the environment or in food or in 4 the workplace. Q. And did you object to those controls? 6 A. No. All we wanted was reasonable achievable 7 controls. 8 Q. You never sat in a meeting conducted by Paul 9 Wright of Monsanto where he designed a scheme to prevent 10 the control or prevent the regulation of PCBs both in the 11 environment, in the water and in the effluent? You sat in 12 that meeting; did you not? 13 A. I may well have, but I don't remjo ember the 14 thrust of the meeting being anything like that. 15 Q. The purpose of the whole meeting attended by 16 Westinghouse, GE, and other members of NEMA held in your 17 offices at Monsanto was deliberately designed to prevent 18 the regulation of PCBs as the federal agencies were 19 attempting to do? 20 A. I'd have to refresh my memory on the exact -- 21 Q. Do you deny it, sir? p22 A. Since I don't remember, I'm forced to deny 23 it. I just don't recall the thrust of the discussion 24 being the way you described it. 25 Q. In any event, even through 1974, even through Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49484 60 1 all this brouhaha, you kept on making PCBs? 2 A. For the electrical use, yes. 3 Q. In 1974, did you change your warning as to 4 users like the Plaintiffs in this case making capacitors 5 with PCBs to warn them of chloracnejo ? 6 A. We did not. 7 Q. Liver damage? 8 A. We did not. 9 Q. Of any of the health consequences that you 10 now knew appeared in the Yusho literature? 11 A. We did not. 12 Q. By 1975, there was amajor conference on PCBs 13 held in Chicago on November (inaudible). Do you recall 14 the event? 15 A. Yes, I attended. p16 Q. Did you participate in that conference - 17 A. I was a member of a panel that ended upthe 18 day's activities. 19 Q. At that conference, did you have those 20 reports with you that are part of Exhibit 12? 21 A. I personally did not have them. 22 Q. Mr. Calandra from IBT was with you; was he 23 not? 24 A. Yes, he was there. 25 Q. Who else from IBT was with you? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49485 61 1 A. Dr. K]p eplinger and Dr. Gordon. There may have 2 been others, but I don't recall. 3 Q. Was Paul Wright with you? 4 A. No. 5 Q. And this conference sponsored by the United 6 States Government, specifically the EPA, were trying to 7 the best they could to regulate PCBs in the environment, 8 its use and its application even in the electrical 9 industry; isn't that true? 10 A. That is true. 11 ]o Q. And I suppose that the information that you 12 wanted to give to the United States Government at this 13 conference would be true and accurate information? 14 A. Certainly. 15 Q. At that conference, Mr. Calandra gave the 16 people running the conference on behalf of the government 17 Exhibit 12, did he not, the reports therein? 18 A. I know that Dr. Calandra spoke on the 19 subject. I have no way of knowing whetjo her he gave full 20 copies of these reports to all the representatives of EPA 21 there or not. EPA had already received copies of this 22 prior to the meeting. 23 Q. Exhibit 12? 24 A. Yes, sir. 25 Q. In any event, he used Exhibit 12 to advance Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49486 62 1 the position that PCBs did not appear to be toxic in the 2 animal studies that IBT had conducted? 3 A. I don't know that I would say th]p ey are not 4 toxic. He mentioned that at certain levels under the 5 conditions of the test conditions were noted which show 6 some harm is possible of these materials on the test 7 animals. 8 Q. Now, during this conference, I would like to 9 add -- You're at the conference with Mr. Calandro, 10 Keplinger and another official from IBT. Did you ever ask 11 those people from IBT how they prepared these studies, p12 whether these studies were true, whether they were valid? 13 Did you ever inquire how these studies were carried out? 14 A. I had discussions regarding these studies for 15 many months before that particular meeting, so that 16 subject did not come up at that meeting, no. 17 Q. What discussions did you have months before 18 (inaudible) regarding these studies? 19 A. I had discussions with the IBT people who ,p20 would come to St. Louis to Monsanto, and I had at least 21 on three occasions visited their laboratory. 22 Q. Did you ever look at the raw data? 23 A. Oh, no. I'm not qualified to look at that 24 data and understand it, no. 25 Q. Let me ask you something. Did you ever ask Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49487 63 1 anybody from Monsanto, "Hey, let's go down and check the 2 raw data at IBT since they are doing toxic tests for us p3 and we haven't had any done since 1938"? 4 A. Did I ask that? 5 Q. Yeah. 6 A. No. That's a responsibility of the medical 7 department. 8 Q. I don't care whose responsibility you think 9 it is. You're in charge of the environment program, and 10 I'm just trying to find out, didn't you think that it 11 would be prudent and reasonable to look at the raw data 12 (inaudible)? p13 A. Certainly, and that was being done. 14 Q. By whom? 15 A. Monsantotoxicologists. 16 Q. Who? 17 A. Well, Dr. Hunt initially, and then when he 18 died he was replaced with a Dr. Levinskas and Elmer 19 Wheeler throughout all of this period was on top of it. I 20 had to rely on those three people. 21 Q. Now, this is very important. Those three 22 people, Monsanto (inaudible) actually went to IBT and 23 looked at the rap w data? 24 A. Since I wasn't there, all I know is they went 25 there and looked at many things. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49488 64 1 Q. Well, now, you just told me that these three 2 Monsanto people looked at this raw data, 3 A. No. I said they're responsible for following 4 the tests to assure that they were properly done, of high 5 guality, and the kind of tests that we expected from the 6 laboratory. p7 Q. All right. Based on the information that you 8 had from these gentlemen, these Monsanto employees, did 9 they come back and tell you, "Bill, we looked at your raw 10 data, the bench books. These tests are according to 11 protocol"? 12 A. They told me the last part of your statement, 13 these tests are on schedule and they're according to 14 protocol. 15 Q. And did they tell -- Did they tell you how 16 they knew the testjo s were according to protocol? 17 A. No. 18 Q. You never asked? 19 A. I didn't know enough about the business to 20 use the right words to form the guestion. 21 Q. And you relied on what these other Monsanto 22 people told you to believe that the tests were not 23 falsified? 24 A. Certainly. 25 Q. Where is Dr. Hunt today? I understand he's Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49489 1 2]p 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 65 deceased? A. Q. He died. What about Elmer Wheeler? A. He died also. Q. Who's left? A. Dr. Levinskas. Q. He's alive? A. Yes, sir. Q. He's available to testify in this trial? A. Oh, I don't know that. I haven't seen Dr. Levinskas for five years or more. Q. Let's just focus on Dr. Levinskas. Did he telljo you that he went to IBT and looked at the raw data? A. No, sir. Q. Did he tell you that the tests being carried out at IBT were being carried out according to protocol? A. Yes, he did. Q. Did he tell you how he knew that fact? A. No, he did not. Q. I want to turn the examination to Paul Wright. Paul Wright worked at IBT; is that true? A. That's w]o hat I found out, yes. Q. Before he went to IBT, Paul Wright worked at Monsanto? A. That's what I understand. Yes, sir. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49490 66 1 Q. What did he do there? 2 A. Where? 3 Q. That's very(inaudible). When Paul Wright 4 worked at Monsanto before he went to IBT, what did he do 5 there? 6 A. All I know is that he worked for Monsanto's 7 agricultural chejo micals company in some position in their 8 laboratories as a technician. That's all I know. 9 Q. You did not know him at Monsanto? 10 A. No, I didn't. 11 Q. Even when you became a director of 12 environment and he was the head of toxicology, you didn't 13 know him? 14 A. He was never the head of toxicology when I 15 was there. 16 Q. (Inaudible) he was the manager of toxicology? 17 ]p A. No. He was just a toxicologist in Monsanto's 18 medical department reporting to Dr. Levinskas. 19 Q. You never met him? 20 A. Oh, sure, I met him, but I had no business 21 discussions with him. They were limited to Elmer Wheeler 22 and George Levinskas. 23 Q. Now, did you hear the testimony this morning 24 about Paul Wright's connection with the studies that are 25 in Exhibit 12? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49491 67 p A. I heard it, yes. Q. If that -- If those facts are true, would you find them to be outrageous? A. If they are -- Under the condition if they are true, I would find it very disturbing. Q. In fact -- A. That just doesn't fit the man I saw briefly. I don't know how else to answer that Q. Would you find that conduct simply reckless? A. I don't knp ow about reckless. It would certainly be unprofessional Q. It would be damn near criminal? A. That -- Not being a lawyer, I don't know what you mean by criminal. Q. It's outrageous under any conditions; is it not? A. It's just unacceptable. Q. Even to Monsanto? A. True. Q. Now, you knew that -- When Paul Wright came back to wop rk in the toxicological department of the Monsanto Company, your employer, did you ever talk to him about those reports and the (inaudible)? A. No. Q. Did you ever think since you were giving Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2 TOWOLDMONOQ49492 68 1 these reports out to federal agency after federal agency, 2 did you ever say to Paul, "Is there anything wrong with 3 those reports?" 4 A. I don't know what would lead a person to 5 su]o spect they are wrong, sir. It comes from a reputable 6 laboratory. 7 Q. Let me suggest a reason. Those reports were 8 given to about six or seven federal agencies as an index 9 to the toxicity of PCBs. They were given to other 10 agencies. They were given to the federal strike force on 11 PCBs. I would think if you want a suggestion that it 12 might be reasonable to ask Paul Wright, "Hey, Paul is that 13 good stuff or is that (inaujo dible)?" 14 MR. CARNEY: Your Honor, I'm going to object. 15 He's suggested no reason why Monsanto would be suspicious 16 at all about that. 17 THE COURT: What's your objection? 18 MR. CARNEY: I object. It's argumentative. 19 THE COURT: I don't think it's a question. 20 But I'm going to ask you to rephrase it as a question. 21 Sustained. 22 Q. Since you had given these reports t]o o all 23 these federal agencies (inaudible) -- I'll ask it this 24 way. Did the thought ever occur to you, "Maybe I should 25 check with Paul Wright about the data underlying his Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49493 69 1 conclusions in this report to be sure it's true"? Did 2 that thought ever occur to you? 3 A. A thought like that would never occur to me 4 because I'm talking to his superiors who know more than 5 Paul does about toxicity studies and p protocols and 6 interpretation of raw data. Why should I go to a person 7 who is less experienced than they are to get some feel for 8 the value and the validity of this work? 9 Q. Because, Mr. Papageorge, it was Paul Wright 10 who wrote the report and concluded the raw data. 11 MR. CARNEY: I'm going to object. That 12 misstates what the report says. 13 THE COURT: It's not a question. I'll 14 sustaijo n. Proceed. 15 Q. Now, again, in 1974 Monsanto was thinking 16 about quitting production of PCBs. Is that true? 17 A. That thought was always under consideration, 18 yes . 19 Q. Why didn't you quit? 20 A. Because it was our sincere belief that the 21 use in electrical equipment under the right conditions of 22 handling would provide a safety benefit to society that 23 could not be provided by any other p known material, and 24 without -- by arbitrarily stopping the production of PCBs 25 we would have put the power industry in this country in a Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49494 70 1 position where all kinds of difficulties would have 2 occurred, blackouts, brown-outs, factory shutdowns, 3 subways wouldn't work and on and on. It was a very 4 difficult decision to make. 5 Q. Yeah. In October 17th, 1976, Congress passed 6 the Toxic Substance Control A]p ct; didn't they? 7 A. Yes, sir. 8 Q. The one chemical, the very one chemical and 9 the only chemical that is banned by name in that statute 10 is what? 11 A. PCBs. 12 Q. (Inaudible.) Have weexperiencedgreat 13 brown-outs? Have factories shut down? Have elevators 14 stopped? Has the whole world come to an end? 15 A. No, sir, becausealternatives were found to 16 prevent those drajo stic conditions with some sacrifice in 17 efficiency and safety. 18 Q. And those alternatives have been known for at 19 least 15 years? 20 A. That I don't know. 21 Q. You don't know? 22 A. No. 23 Q. As a chemist? 24 A. As a chemist. 25 Q. As a man who deals with Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49495 71 1 A. But not as a capacitor or transformer 2 designer. 3 ]o Q. It would have also meant if they were banned 4 altogether a great loss of income to Monsanto? 5 A. I would not describe it as great. 6 Q. You wouldn't? 7 A. No, sir. Not atthat time. 8 MR. KOTOSKE: Now, I'm trying to cut it down. 9 Your Honor, because I know we're running over. 10 Q. I want to -- I'm going to talk specifically 11 now -- As a chemist, you might know the answejo r. First 12 I'll offer a general proposition to see if we can have 13 some agreement. By the way, did Monsanto keep making PCBs 14 after 1976? 15 A. Yes, they did. 16 Q. Did they makethem in '77? 17 A. Yes, sir. 18 Q. '78? 19 A. No. 20 Q. Do they still make PCBs today? 21 A. No. 22 Q. Are you sure? 23 A. Positive. 24 ]o Q. Has Monsanto ever gone to the EPA and asked 25 for exemptions from the regulations to keep producing Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49496 72 1 PCBs ? 2 A. That doesn't fit with the official position I 3 know from Monsanto. 4 Q. I want to ask you about a byproduct 5 (inaudible). I want to see what information you have. 6 When you heat PCBs in the presence of oxygen at a certain 7 temperature, it produces furans. True or not true? 8p A. The potential is there, yes, sir. 9 Q. Now, Monsanto has known for at least 50 10 years, at least all the time you've been there, furans are 11 a very toxic substance? 12 A. I don't know that at all. I didn't find that 13 out personally until 19 -- I want to say 1970, '71. What 14 the medical people knew about it before that, I don't 15 know. 16 Q. Furans are about, according to Dr. Kelly, 17 p 2,000 more times toxic than PCBs. Do you know anything 18 about that? 19 A. I've heard that description, yes. 20 Q. And you have heard toxicity levels much 21 higher than that, haven't you, In the range of five to 22 10,000 times as toxic as PCBs? 23 A. Yes. I've heard some very high 24 concentrations, yes. 25 Q. Now, I want you to think back during the Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49497 73 1 '50's, during the '60's,]p during the '70's. Did Monsanto 2 ever put on its labels, on its drums, on its tankers, on 3 anything, to warn people like the Plaintiffs in this case 4 who actually used this stuff in the manufacture of 5 electrical capacitors, that heated PCBs could cause the 6 formation of extremely toxic furans? 7 A. No. That information was not known and not 8 discussed in that time period you discussed, '50's, '60's. 9 Q. Was it kn]o own in the '70's? 10 A. In the '70's, yes, there was discussion 11 amongst the scientists at the leading edge of this type of 12 study that this was a good probability, yes. 13 Q. Did you ever change? Did you ever change the 14 warning on the labels of these drums and these tankers to 15 alert people like the Plaintiffs in this case who use that 16 stuff to manufacture capacitors that heated PCBs could 17 cause the formation of e]o xtremely toxic furans? 18 A. On the label, no. 19 MR. KOTOSKE: (Inaudible) take a break, Your 20 Honor. 21 THE COURT: Well, let me ask the jury. Let 22 me have counsel come over. 23 (A bench conference was held.) 24 THE COURT: We'll go ten more minutes, and 25 then we'll stop. Does that meet with you all's approval? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49498 74 1 MR. KOTOSKE: They can'Jo t take me for ten more 2 minutes 3 THE COURT: Let's take ten more minutes. The 4 more we do now, the less we have to do later. You may 5 proceed, sir. 6 MR. CARNEY: I'm willing to stop, just so I'm 7 on the side of the jury. It's your decision to 8 (inaudible). 9 THE COURT: Go ahead. 10 Q. Mr. Papageorge, did Monsanto hire lobbyists 11 back in Washington, D.C.? 12 ]o MR. CARNEY: In connection with PCBs, I 13 assume? 14 Q. Yes. In connection with PCBs. 15 A. PCBs, not to my knowledge. 16 MR. KOTOSKE: Now I am at a convenient - 17 THE COURT: You win. You want to step down? 18 We'll take a break. Ladies and gentlemen, we will break 19 for the day. We will continue with the witness tomorrow 20 at 9:30. Again, do not discuss this case among yourselves 21 or with others. We'll see all of you back here at 9:30 22 and proceed at that time. Thank you. 23 (Court was recessed for day.) Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49499 [& - additional] Transcript Word Index & & 4:6 1 1 51:10 10 23:21 10,000 72:22 10/28/91 1:1 1016 22:10 107 56:15 12 4:5 49:18,18 50:1,1,11,16 52:18 54:2,3,20 60:20 61:17,23,25 66:25 1216 23:5 1221 22:8 1232 22:9 1242 22:9 23:6 125 2:17 1254 22:9 1260 22:9 13 16:12 15 46:23,24 70:19 150 2:1226:10 1700 6:23 17th 70:5 18 46:17 19 41:1848:3 55:1272:13 1930s 54:23 1930's 38:17 1938 63:3 1947 4:4 30 1951 13:12,25 16:16 36:9 4:17,195:8,15 30s 1953 38:17,17 6:4,6 9:5,9,14 10:9,10 11:5 30th 11:8,14,15 12:6,22,24 44:18 1957 31st 13:5,6,7,8 14:16,22 15:9,23 1:19 15:25 16:8,10 18:7,22 19:1 35 24:9 26:16______________ 1961 19:16,17,22 20:20 4 1964 20:13 21:3,4 23:14 24:6,8 24:12,17 1965 40 23:22 400 13:11 25:13,14,16 30:4,12 1969 31:6 1970 30:2,4 32:18 34:13 35:15 36:18 37:2 39:20 40:6 41:1843:1244:7,1847:12 48:3,19 72:13 1970s 39:17 1970's 34:11 1971 44:5 47:16 48:8 53:2,23 1972 47:3,7 52:23,24 53:1 1973 12:23 1974 33:13 50 72:9 50's 9:15 73:1,8 53 12:25,25 55 17:18 57 14:23 19:14 59 20:20 5th 30:4 59:4 6 55:4 57:4 59:25 60:3 69:15 1975 55:5 60:12 60 1976 14:7 20:20 40:4,6,9 70:5 71:14 60s 1986 48:14 1:19 60's It* 4:3 40:1751:10 73:1,8 61 2 20:18,20 63 2,000 46:17 72:17 69 20 31:8,9 3:9 21 22:11 2t* 65:1 70 32:2 39:6,23 40:2 50:6 70s 34:8 39:20,21,22,25 40:9 57:5 70's 73:1,9,10 71 47:16 50:6 72:13 72 44:5 74 57:6 77 71:16 78 71:18___________ 8 8 40:17 86 2:14 9:30 74:20,21 943 4:3 a able 17:12 33:15 38:7,10 56:6 aboard 26:9 about|3 34:20 47:17 access 27:23 28:2,4,7,9 accident 27:2 35:14 accomplish accumulated 37:23 accurate 3:8 61:13 achievable 59:6 acquainted 37:8 action 45:7 activities 13:11,1360:18 add 62:9 added 44:8 45:24 addition 28:23 38:2 54:4 additional 21:21 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMON0049500 [address - believe] address anager appropriate 35:1 32:13 29:13 37:23 addressing analytical approval 53:14 33:14 73:25 administration analyzed april 38:8 40:21 53:8 33:25 47:16 administrations anhydride apron 53:7 6:1 27:20,21 advance animal arbitrarily 61:25 54:8 62:2 69:24 adverse animals areas 37:9 33:5 34:3,6,8 38:10,18 51:5 33:24 age 51:6 62:7 argumentative 1:11 54:12 animals.|s 68:18 agencies 33:8 arochlor 48:16 50:23 52:15 53:6,16 anniston 48:21 54:1 58:23 59:2,18 68:8,10 21:21 25:18 26:23 29:24 aroclor 68:23 30:13,1531:7 22:8,9,9,9,9,10 agency ansi aroclors 52:25 53:19 58:6 68:1,1 56:15 54:19 agents answer arrangement 50:2 17:1 19:2 32:6 43:1 67:8 2:16 ago answering arrive 13:23 16:17 36:10 18:17 43:1 agreement answers artfully 2:5,8 71:13 18:12 18:4 agricultural answer article 66:7 71:11 16:14 46:5 agriculture anto's articles 51:14,18 53:10 45:11 37:23 ahead anybody aside 16:14 52:23 55:4 74:9 11:10,11 37:11 43:6 63:1 2:3 21:18 alabama anyplace asked 21:22 25:18 26:23 30:15 11:7 53:18 64:18 71:24 31:7,15 apart asking alert 35:11 18:17 73:15 appear assigned alive 17:24 62:1 6:8,18 13:8 20:3,9,14,21 65:7 appeared 21:1 25:1748:13,17 allowed 17:20 60:10 assignment 8:15 appetite 7:10 20:15 37:25 all's 36:4 assignments 73:25 application 4:21 alternate 58:1661:8 assistant 48:5 applications 12:6,16 alternative 46:21,25 47:1,4,17,18 associate 42:2 applied 14:25 35:12 alternatives 46:5 associated 70:15,18 appoint 34:5 42:1 altogether 32:24 association 41:20 47:4 57:6 58:24 71:4 appointed 56:2 america 31:11 32:5 assume 34:1 appreciate 74:13 amount 17:1 assumed 51:7,22 52:2 approach 39:17 2:22 10:12 assure 64:4 a|s 25:14 70:6 attempting 59:19 attempts 38:13 attend 3:25 54:5 attendant 37:9 attended 59:15 60:15 attorneys 1:23 august 47:12 available 29:13 53:24 65:9 aware 9:25 10:10 11:8 30:4 39:3,6 b bachelor 4:1 back 11:2 16:5,8 18:7 19:1 20:2 24:9 31:12 39:23 40:3 64:9 67:21 72:25 74:11,21 background 3:23 34:12,16,18 35:5 ban 57:6,8 58:24 banned 70:9 71:3 bar 36:22 bartlesville 4:20 baseball 29:22 based 64:7 basic 37:21 basically 27:11 battle 55:5 behalf 61:16 belief 69:20 believe 14:10 19:18 20:19 40:20 41:2 42:9 48:22 64:22 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49501 [belong - coached] belong 25:7 bench 2:23,24 10:13 36:24 64:10 73:23 benefit 69:22 benefits 3:17,17 bergen 40:11 best 2:17 3:9 8:21 9:1,11 17:7 17:1341:1,4 47:1561:7 beth 37:8 better 4:23,23 18:4 20:7 37:6 beyond 46:6 big 23:20,20 biggest 56:11 bill 64:9 bird 37:12 birds 33:6,15 34:4,8 bit 4:25 19:19 29:1 37:1 blackouts 70:2 blem 48:8 blended 5:3 blending 7:11 blood 15:2 bloomington 14:17 blown 55:5 board 40:9 55:13 body 15:18 29:10 42:16,21 book 37:24 books 64:10 bootie 28:24 booties capacitors chairman 29:11 7:4 9:18 56:12,24 60:4 73:5 56:15,19 bottom 73:16 change 37:15 capacity 13:6 15:17 22:22 25:14 break 6:10 32:9 36:25 43:17 44:10 9:18,18 39:8,11 55:16 car 60:3 73:13,13 73:19 74:18,18 17:18,21 30:20 changed breaks carbonless 30:6,8 44:9 54:25 45:22 45:22 47:13 changing breathed care 48:5 8:13 15:3 44:2 63:8 chapped briefly carney 15:1 67:7 2:22 10:12 18:1731:1,4 characteristics bring 56:5 58:15,17 68:14,18 18:2 30:2 69:11 74:6,12 charge broadened carried 63:9 45:10 62:13 65:15,16 check brochure carry 63:1 68:25 18:1 34:21 chemical broke cars 4:2,4 5:19,22,25 6:1,9 9:22 31:2 55:1 21:14 24:20 70:8,8,9 brought carter chemicals 15:17 1:1 38:21 6:14 7:8 29:15 40:21 41:3 brouhaha case chemist 60:1 3:2,7,20 5:9 17:10 24:14,18 70:23,24 71:11 brown 30:21 39:12 44:17 60:4 chemists 1:1 70:2,13 73:3,15 74:20 33:14 bubble cases chest 45:23 2:9,21 15:1,3 35:21 15:6,12,12 16:4 business cath che|s 40:15,15 64:19 66:20 22:5 36:16 66:7 byproduct cattle Chicago 72:4 51:22 60:13 c calandra 60:22 61:15,18 calandro 62:9 caulking chloracne 45:19 15:14 19:1,7,12 24:20 cause 30:25 36:16 54:10 14:24 19:11 24:15,20 30:22 chloracne |s 73:5,17 60:5 caused chlorinations 1:5 3:9 12:10,11 13:1 18:1 28:11 29:14 37:4,5,7,20 45:24 47:20 called 32:20 causing 16:3 43:23 44:1 cautionary 5:25 14:3 15:5 28:24 35:19 39 4 44 24 46 4 8:10 centered can'p 41:24 74:1 canvas certain 27:1 30:9 58:23 62:4 72:6 2812 cap 29:21,22 capaci|3 certainly 3:21 7:3 12:21 17:9 33:25 34:25 38:20 41:8 50:4 61:14 63:13 64:24 67:11 24:19 chain capacitor 9:21 22:11 24:14 71:1 37:15,16 chaired 58:14,20 22:20 chlorines 33:13 clerk 1:7 closed 46:7,8 47:2,23,24 48:1 58:16 cloth 28:6,12 29:21 clothes 8:16 clothing 27:15,19 coached 38:1 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49502 [coating - day] coating conducted 28:13 38:18 59:8 62:2 cold conference 15:6 60:12,16,1961:5,13,15,16 college 62:8,9 73:23 3:24,25 confer^ comfortable 2:24 42:17 confirm coming 33:15 25:13 confirmed commerce 32:23 33:10 53:12 congress committee 70:5 40:16 56:16,18,19,22 58:13 connection 58:20 34:21 37:2 66:24 74:12,14 company consequences 2:14 4:20 5:5 17:8,10 40:13 8:8 10:11,11 11:6,12,25 40:21,23 41:6,10,19 44:19 14:21 24:7 30:4 44:11,14 66:7 67:22 60:9 complain consideration 10:1 45:7 69:17 complete considered 53:12 45:11 completed consisted 47:15 53:5 compound constant 58:17 43:3 compressors construction 7:7 8:1 13:13 14:18 comprised consult 49:17 11:20 concentrated consulting 37:20 2:20 concentrations consumes 72:24 51:20 concern consumption 35:2,11 35:20 concerned contact 34:23 16:25 concerning contained 37:21 44:18 13:17,22 14:1,10 33:12 concerns container 34:22 35:10 17:21 concluded containers 52:13 69:10 44:8 46:11 conclusions contaminated 50:21 52:13 69:1 35:21 condition continue 15:13,14,16 16:3 67:4 1:4 27:3 58:21 74:19 conditions continued 15:19 16:2 36:19 43:2 62:5 15:10,12,1920:13 62:5 67:15 69:21 70:16 continuing condit|3 16:1 15:10 contracted conduct 54:23 67:9 control court|s 31:12,24 32:13 46:6,13,25 1:8 47:24 48:1,18 57:10 58:7 cover 58:10,11 59:2,10 70:6 18:15 controlling covers 50:3 14:10 controls cracked 59:4,7 15:2 convenient create 74:16 32:20 conversa|3 created 22:15 32:16 conversation creatures 52:11 37:10 conveying credits 8:1 4:5 copies criminal 37:23 52:15 54:1 61:20,21 67:12,14 copy cross 45:22,23 47:13 18:1249:13 corey ct 40:20 70:6 corporate ctured 1:20 33:17 correct cuff 3:11 4:9,155:11,146:5,15 28:16,17 6:17 10:8 11:18 12:9 15:22 customers 16:9 24:11 25:23 26:4 30:3 27:4 30:1037:1941:1543:8,11 cut 47:5,6 51:3 55:10 56:4,14 18:1821:1571:8 58:25 d corrected d.c. 16:2 correction 15:11 correctly 74:11 damage 15:21 16:11,25 18:7 19:8 19:12 24:15 30:22 35:24,25 21:24 36:1,2,16 44:1 60:7 cost 20:7 council 53:9 counsel 73:22 damaged 28:22 damn 67:12 dam|3 54:12 count 3:8 country 69:25 course dangerous 88 1010 116 12 1421 24:7 30:4 53:20 data 50:20 52:13 62:22,24 63:2 10:641:1249:8 court 1:2 2:25 10:14 11:1,4 18:16 18:20 31:3,22,25 36:23 63:11,23 64:2,10 68 25 69 6 10 date 21 4 47 7 65:13 39:8,10,15 40:2 55:16,19 day 55:22 58:19 68:17,19 69:13 73:21,24 74:3,9,17,23 1:19 44:17 55:17,18 74:19 74:23 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49503 [day's - elmer] day's 60:18 dealings 20:10 deals 70:25 death 34:6 decades 43:4 deceased 65:1 decembe|3 1:19 decided 41:25 decision 48:2 70:4 74:7 decision^ 47:25 defense 53:11 definition 19:3 45:11 46:1647:10 degree 4:2,4,6 delay 1:3 deliberately 59:17 demonstrated 34:16 42:19 dental 3:17 deny 59:21,22 department 5:2 12:12,14,20 13:2,9 19:22 20:3 31:19 49:7,8 51:14,18 53:10,11,11 63:7 66:18 67:21 department} 53:12 departments 7:10 53:6,16 departm|} 20:24 depending 20:4 depends 23:2 deposition 5:9 describe 14:25 22:5 28:8,9 42:20 46:9 50:18 53:3 56:1 71:5 described discussed (cont.) 18:1 19:11 20:1925:5 54:16 73:8,8 26:20 27:6 36:5,17 47:11 discussing 49:24 55:12 59:24 49:5 describes discussion 38:1341:447:19 36:24 59:23 73:10 describing discussions 36:18 41:19,23 62:14,17,19 66:2 description disposal 72:19 32:8 44:3 design distinguished 5:1 6:7 45:6 designed distribute 29:8 52:1 59:9,17 7:5 designer disturbing 71:2 67:5 designing di|} 5:2,6,18,23 54:22 detail dizziness 41:12 36:6,16 deteriorate doctor 29:5 4:8 determine doctorate 51:25 53:15 4:5 developed document 42:25 16:12,15,20 17:14,25 dible documents 68:13 52:22 died doing 63:18 65:1,4 7:2 41:7,10,11,1463:2 different dozen 4:21 21:1322:1924:1,5,10 13:12 20:4 23:23 45:17 47:10 50:22 dr differently 11:24 12:6,11 44:17,24,25 42:9 45:2,9 52:8 61:1,1,1863:1 difficult 63:18 64:25 65:6,10,12 43:1 47:14,24 48:1 70:4 66:18 72:16 difficulties dra|} 70:1 70:16 direct drill 1:13 55:20 4:23 directed drinker 30:21 39:4 54:22 director drinking 12:13,1740:15,2041:3 51:10 66:11 drug directory 38:8 53:7 37:24 drum dirty 24:13 30:20 8:16 drums disappear 17:18,1831:2 36:1343:18 16:4 55:1 73:2,14 discuss ds 11:11 39:12 54:7 74:20 40:1 discussed d|D 36:19 38:9 52:19 53:24 11:20 duly 1:11 duties 5:5 13:7 20:1 duty 44:19 dying 34:4 e earlier 8:2 15:13 26:21 47:11 early 15:4 33:7 34:8 38:16,17 earned 4:5 eating 35:4 51:8,22 ed 5:15 edge 73:11 educate 37:17 educational 3:23 effect 8:13 17:5 44:4,25 effects 34:24 37:9 38:6 54:8,9 55:2 efficiency 70:17 effluent 59:11 efforts 37:3,7,8,19 either 13:13 20:7 36:9 elbow 28:15 electric 14:17 electrical 7:3 14:1 46:14,17 55:5 56:2 56:12,23 60:2 61:8 69:21 73:5 electricians 13:25 electricity 7:5 element 55:1 elevators 70:13 elmer 12:5 54:4 63:18 65:3 66:21 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49504 [em - form] em exactly f 39:1,4 42:5,6 49:20,22 35:7 face 54:10,12,14,15,22 exaggeration 29:12 ember 55:9 fact 59:13 examination 2:1 5:12 43:21 65:18 67:6 emmet 1:13 49:14 50:17 65:20 factories 11:20,20 examine 70:13 employee 18:12 factory 10:1 15:3 16:2 example 70:2 employees 7:6 18:23 24:18 36:15 38:4 facts 18:6,22 26:7,14 27:5 64:8 38:7 50:2 53:7,13 67:2 employer examples fair 67:22 7:21 46:2 22:23 26:18 55:8 ence executive fairly 2:24 40:16,23 29:5 41:4 ended exemptions falsified 31:6 60:17 71:25 64:23 engineering exhibit familiar 4:2,4 6:7 20:3,8 49:18,18,24 50:11,16 52:18 38:14 49:23 engineers 54:2,3,20 60:20 61:17,23 family 20:4 61:25 66:25 27:13 ent exist far 20:24 8:18 17:16 3:9 21:10 43:9 environment expect fa|s 32:22 33:5 37:4,6 42:4,15 3:14 15:1355:19 42:13 42:19 43:22 44:2,4,10 expected fda 53:15 59:3,11 61:7 63:9 20:5 64:5 51:2,4 58:1 66:12 experience february environmental 29:4 32:7 48:19 31:11,24 32:13 34:22 35:2 experienced federal 35:10,12 38:14 39:18 41:24 69:7 70:12 48:15 50:2,11,22 52:15,24 48:18 53:10 expert 52:25 53:6 58:6 59:2,18 epa 4:13 68:1,1,8,10,23 50:24 57:5,7,8 58:8,11 61:6 experts fed|s 61:20,21 71:24 52:14 49:3 eplinger exposed feeding 61:1 14:1224:1938:19 50:19 equipment expose feel 5:2,6,18 7:4,22 13:14,17,22 15:19 19:11 42:17 69:7 14:1 46:15 69:21 exposure fellows er 8:9 10:2,11 11:6,25 14:21 12:19 12:16 14:23 24:7,14,20 28:22 field eral 30:4,22 34:6 36:15 37:9 38:4,5,6 49:3 44:12 files establish expression 17:12 22:19 46:9 fill estimate ex|s 40:3 23:21 46:22 35:13 filters e|3 extract 29:15 73:17 4:25 final europe extremely 50:6 34:1 73:6 finally event ey 52:4 27:2 59:25 60:14 61:25 62:3 finally^ exact eyes 57:3 26:17 43:23 59:20 36:3 find 4:22 9:1 34:11 47:14 63:10 67:3,5,9 72:12 finding 33:20 34:2,7 35:3 fine 8:4 35:14 finish 55:15 fire 27:3 firm 2:6 first 1:11 2:154:21 5:17,189:6 25:25 35:16 46:25 47:15 71:11 fish 33:6,15 34:4,7 35:3,4 38:12 51:5 fit 27:13 67:7 72:2 five 30:1 65:11 72:21 flexible 45:25 fluid 7:7,12,14,18 9:4,7,12 46:15 fluids 7:6,9 48:4,6 flushing 13:21 focus 65:12 folks 18:25 following 2:16 39:14 40:19 64:3 follows 1:12 food 38:8 51:6,22 53:7 58:4 59:3 footnote 22:14 footwear 28:18,18,19 29:6,7 force 52:25 53:4 68:10 forced 59:22 foremen 13:12 forklift 7:18 form 64:20 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49505 [formation - identified] formation given h helping 73:6,17 7:10 45:7 52:22 54:6 68:8,9 hadn'tp 2:9 formed 68:10,22 24:10 hesitate 32:9 52:24 53:2 giving half 50:4 forth 53:12 67:25 42:23 43:7 45:17 hey 35:4 givinb hand 63:1 68:12 forward 18:18 58:23 high 13:4,5 19:1625:13 glass handled 64:4 72:23 found 45:20 18:6 higher 32:21 33:13 42:4 43:22 glenn handling 28:17 72:21 47:24 65:22 70:15 1:1 18:3 32:8 44:3 56:23 69:22 highest four globally hands 41:16 4:22 38:17 33:21 8:22 15:1 hing fractions glove happen 52:12 5:3 28:12,12,14 9:17 hire frame gloves hard 74:10 37:2 40:6 28:3,4,6,9,13 29:11 29:22 history frequency go harm 4:16 50:19 16:14 19:1629:3 30:13 43:23 62:6 home frequently 36:21 39:23 40:3 42:21 hat 31:12 50:14 55:22 63:1 69:6 73:24 74:9 28:9 29:23 65:22 homework full going ha|s 37:25 52:24 55:5 61:19 5:8 16:12 28:11 37:4,20 31:7 honor fumes 55:5 68:14,20 69:11 71:10 have|s 2:22 10:12 31:1 55:14 8:13 15:4 29:18 goi|3 29:9 68:14 71:9 73:20 function 13:1 40:8 head hour 53:4 56:18,21 gonna 66:12,14 2:12,17 functional 39:7,23 40:3 44:19 46:22 headgear hourly 40:15 46:22 56:6 29:20 2:10 furans good headquarters hours 72:7,10,16 73:6,17________ 8:25 46:19 55:14 68:13 31:17,20 3:9 38:1 g 73:12 health howard gallon gordon 10:1,11 12:18 37:9 38:6 40:10 17:18 61:1 44:11,13 54:8,9 60:9 human gasoline 5:3 gosh 16:16 hear 3:2 9:6 30:14 35:17 52:8 35:5,11,13,20,20 37:14 44:11 55:1 gasolines government 66:23 humans 5:2 38:11 48:8,13 49:3,5 50:8 heard 34:24 52:2 55:2 ge 56:9 59:16 gear 50:11 52:24 55:7,15 58:24 61:6,12,16 great 18:24 35:14,16,18 42:25 49:15 67:1 72:19,20,23 heart hundred 21:13 hunt 28:1,2 29:11 70:12 71:4,5 35:23,25 63:17 64:25 general 20:21 23:4 25:1,3 38:12 ground 5:1 heat hydraulic 7:8 46:15 47:21 48:5 72:6 7:7,12,14,18,23 9:4,7 46:15 71:12 generation 43:4 group 26:13 33:13 40:15 42:1 53:2,5,25 54:7 58:18 heated 73:5,16 heating 47:20 48:4 ibt gentlemen 1:2 64:8 74:18 gt> 43:5 7:8 heisler 48:20,21 60:22,25 62:2,10 62:11,19 63:2,22 65:13,16 gents 40:13 george guess 1:23 22:5 23:20 42:8 guideline 25:10 held 2:24 18:10 36:24 59:16 65:21,23 66:4 idea 26:18 27:18 66:22 15:7 60:13 73:23 ideas give help 37:21 23:19,21 26:18 45:17 53:22 14:25 19:3,20 20:24 22:8 identified 54:22 61:12 49:14 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49506 [ight - laundered] ight information (cont.) 51:21 73:7 Illinois ingredient 21:2,9,23 26:21 7:9 45:18,20,21 illnesses ingredients 35:21,23 36:5 7:11 46:11 illustrate initial 33:11 37:19 46:14,16 illustrated initially 33:12 40:10 63:17 important injury 35:13 63:21 52:25 improve ink 20:6,8 45:23 inability inquire 36:4 62:13 inaudible instances 1:24 2:21 6:13 7:1 8:7 9:4 50:12,13 9:24 11:22 12:10,11 18:20 intended 18:23 19:19 22:14,24 23:1 35:20 42:5 23:19 27:8 28:5,8,15 29:3 intent 31:20 33:2 34:22 36:14 52:5 37:13 39:7 44:20 45:13 interest 46:7,25 50:9,13 52:1 55:13 3:19 55:22 56:16 58:9 60:13 interested 62:18 63:12,22 66:3,16 3:24 49:21 51:24 67:23 68:23 70:12 72:5 interiors 73:19 74:8 53:11 inau|3 interpretation 68:13 69:6 incident interrupt 9:20,25 35:18 36:12 5:8 34:22 include intertwined 5:6 13:16,18 25:4 33:5,8 35:8 35:23 introduced included 9:12 46:13 52:13 invented including 9:12 3:10 33:8 invited income 54:4 71:4 involve increment 12:1 50:5 involved index 14:1,3,4,6 23:17 38:8,11 68:8 51:1953:16,17 individuals inv|3 14:7,9 38:3,7 57:7 11:9 industrial ions 7:12 12:17 40:21 15:10 industry irritation 46:17 55:5 61:9 69:25 15:6 inextricably issued 35:8 28:20 50:7 information items 14:18 39:3 51:24 53:19 51:6 54:1961:11,1364:772:5 it|D kno|s 16:22 50:18 j january 32:2 48:18 57:3 japan 35:19 job 4:17,185:17,18 12:1 13:5 13:18,19 19:17,18,24 20:2 20:10,13 24:22,25 25:7,14 25:16 31:10 32:1,12,14,20 33:2 34:21 38:18 39:18,18 40:4 48:14,18 jobs 13:16 join 49:7 joined 4:17 joint 36:8 join|s 5:15 judge 36:21 juror 3:4 jurors 56:6 jury 53:3 73:21 74:7 know 1:22,22 7:1 8:6 11:5,10,16 11:20,22 14:21 15:9,25 17:16 18:9,13 19:18,25,25 22:19 23:18 24:6 25:25 32:6 34:17,19,20 37:16,25 41:6,10 42:20 43:9,10 48:20 50:14,24 51:6,23 52:10 53:3 61:18 62:3 63:24 64:19 65:10 66:6,8,9 66:13 67:8,13 68:4 69:4 70:20,21 71:9,11 72:3,12 72:15,17 knowing 61:19 knowledge 10:5 24:8 57:9 74:15 known 4:6 69:23 70:18 72:9 73:7 kn|3 67:10 73:9 kotos ke 1:3,5,14 11:3,5 18:21 31:6 32:1 36:21,25 39:7,9,16 42:12 49:25 55:14,18,21,23 56:5 71:8 73:19 74:1,16 krummrich 21:6 23:14 kfj 61:1 k1 keep 39:11 58:14 71:13,25 kell|3 45:2 kelly label 19:4,6,8 24:12,17 30:20,24 36:18 44:16 54:25 73:18 labels 8:18,22,22 31:2 43:17 44:9 11:20,20,24 12:6,11 44:17 73:2,14 44:24,25 45:9 72:16 keplinger laboratories 38:11 66:8 62:10 kept 43:15 47:2 60:1 laboratory 52:12 62:21 64:6 68:6 lack kind 8:17 12:1 17:20 28:5,16,19 36:3 lacking 64:5 kinds 22:3 70:1 43:4 ladies 1:2 74:18 knew 14:23 15:3,10,23 16:1 late 38:17 48:3,14 19:1036:11 38:1541:11 54:7,15,17 60:10 64:16 lateral 6:7 65:18 67:20 72:14 laundered 8:17 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49507 [law - monsanto] law 2:6 lawful 1:11 lawyer 18:11 67:13 le 27:15 lead 68:4 leading 73:11 leak 46:13 leakage 9:23 learn 38:16 learned 24:9,10 30:7 leather 28:13,21 left 2:13 65:5 legal 44:20 letter 44:18 45:4,6 level 34:16,18 40:23 41:16 levels 34:7,12 35:3,5 62:4 72:20 levinskas 63:18 65:6,11,12 66:18,22 library 37:22 life 42:23 43:7 limited 66:21 limits 58:1 lines 16:1 liquid 46:10 literature 34:9 60:10 little 3:5 15:2 19:19 29:1 37:1 47:14 liver 15:20,21 16:11,25 18:7 19:8,12 24:15 30:22 36:16 54:12 60:7 lobbyists manager (cont.) members 74:10 48:17 66:16 42:13 59:16 located manufacture memorandum 5:20 6:22 21:8 5:19 10:6 21:16 32:7 73:4 45:5 long 73:16 memory 8:13 9:7 13:4,22 24:22 manufactured 59:20 29:24 50:19 5:22 14:1321:1822:16 men longer 23:13 42:24 14:2 47:14 manufacturers mentioned lon|3 56:2 8:2 24:2 33:9 47:20 62:4 8:15 manufacturing met look 18:23 23:4 24:19 25:2,3,4 5:14 66:19,20 17:13 32:25 49:20 62:22,23 27:9,20 methods 63:11 manufa|3 18:2 looked 33:17 micals 63:23,25 64:2,9 65:13 march 66:7 looks 44:18 47:16 middle 28:25 marketplace 9:15 18:19 loss 9:13 milar 71:4 mask 22:23 lot 29:14 milk 18:14,14 master 51:5,10 louis 4:3 mily 5:20 6:23 31:12,14,16 material 42:13 37:24 62:20 8:14,16 45:24 69:23 mind lower materials 2:10 3:8 7:17 8:2 46:1 20:7 14:5 42:2,3 43:22 62:6 minds lung math 47:23 36:1,2____________________ 14:2 21:20 minute m machinery 7:6,14,17 machinists 14:3,6 maintain 13:14 maintained 46:12 maintenance 13:9 14:2,4,11 23:24 major 60:12 majority 47:12 making 5:2,21 6:2,13 7:2 23:14,16 23:25 24:4 26:11,14 28:19 41:19 47:2 60:1,4 71:13 malfunctioning 13:17 man 37:18 48:23 67:7 70:25 management 32:24 manager 12:1725:1726:231:11,24 mean 27:18 30:12 36:22 39:10 27:8 50:16 55:16 67:14 minutes means 39:11 73:24 74:2,3 42:15 miscellaneous meant 20:23 71:3 missed meat 20:17 51:19 misstates mechanics 69:12 13:12 mistaken medical 24:25 3:17,184:8,11 12:11,13,13 mix|3 12:20,20 13:1 31:19 37:21 7:22 37:22 42:20,21 49:7,8 63:6 mixture 66:18 72:14 7:23 medicare mixtures 3:18 22:13 meet moment 50:23 51:13,16 73:25 8:3 46:1 meeting money 59:8,12,14,15 61:22 62:15 3:1,2,6 62:16 monsanto meetings 1:16 2:3,5,6,21 3:1,6,15,19 18:10 54:5 4:175:15,178:23 11:10,11 member 12:20 14:14 16:11,15 21:19 56:3,7 60:17 24:1325:1827:1931:13 32:20 33:11,17 35:1 36:12 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49508 [monsanto - pcbs] monsanto (cont.) noted 37:17 38:9,16 40:21,22 62:5 41:16 42:1,23 43:7,9 45:5 november 45:14 46:8,17,20 48:10,11 60:13 48:12,12 50:14,20 52:12 nufactured 53:18,25 54:7,23 55:5 56:3 21:20 59:9,17 62:20 63:1,15,22 number 64:2,8,21 65:24 66:4,9 26:16 43:5 67:18,22 68:15 69:15 71:4 numbers 71:13,24 72:3,9 73:1 74:10 13:24 22:6 monsanto's numberp 6:8 22:6 32:23 49:6 66:6,17 34:10 monsp ny 45:11 14:2 months o 62:15,17 morning object 58:15 59:4 68:14,18 69:11 48:23 49:14 66:23 objection move 6:7 18:16 29:10 52:23 55:4 mp 32:13 68:17 occasion 14:5 27:23 occasions muscle 62:21 36:8 occur n 68:24 69:2,3 name occurred 21:4 25:11 70:9 20:19 27:3 35:18 70:2 names October 22:6 70:5 national offer 56:1 4:1071:12 nature offered 13:6 52:14 nausea office 36:3 53:9 near offices 67:12 31:1259:17 necessarily official 33:18 62:10 72:2 need officially 3:4 7:21 25:25 32:24 36:25 57:8 49:19 officials nema 58:10 55:25 56:1 58:13,17 59:16 oh new 8:3 21:13 23:17 24:24 19:17 29:9 32:14 37:3 34:19 48:3,12 62:23 65:10 39:17 66:20 ng 13:1 38:9 40:8 oil 4:23,24,25 9:24 28:21 normal 35:19 16:5 oils north 28:22 34:1 okay note 16:12 21:25 29:24 31:4 45:3 Oklahoma 4:6,6,20 olliges 1:1 57:11 olved 11:9 once 46:24 ones 29:9 ongoip 38:9 oozing 15:2 open 45:12,14 46:2,2,21 47:4,7 47:10,11,18,18,20 operating 23:23 40:22 opinions 4:10 opportunity 38:2 54:6 order 14:24 19:2 34:21 orderly 18:13 ordinary 29:2 osha 58:12 outrageous 67:3,15 outs 70:2,13 outside 11:7 45:6 overall 38:13 45:9 overtones 44:20 ow 67:10 oxygen 72:6 _________________P p.m. 1:1 page 50:5 paid 1:24 2:1,7 3:1,6 pain 36:8,8 paint 6:3 paints 45:8,21 panel 60:17 pants 27:24 papageorge 1:1,6,7,10,15 18:11 49:20 55:25 69:9 74:10 pape 38:21 57:11 paper 45:22 47:13 pardon 14:20 part 5:5 6:8 9:6 13:16,18 23:20 32:9 35:2 38:14 45:9 49:13 50:16 60:20 64:12 parp 13:19 participate 60:16 participated 24:4 particular 7:23 20:2 62:15 passed 70:5 paul 25:10 59:8 61:3 65:20,21 65:23 66:3,24 67:20 68:2 68:12,12,25 69:5,9 paying 2:3,9 pcb 2:9,21 7:22 9:8,24 10:2,11 11:6 14:5 22:24 27:12 33:13,16 34:7 42:13,23 53:4 pcbs 6:16,24 7:11 8:9 9:19 10:3 10:7 11:25 13:17,21,22 14:2,10,12,13,22 15:8,18 16:25 18:1,6,8 20:11 21:16 21:19,20 22:3,3,12,13,15 23:15,16,25 24:1,5,7,13,14 24:19,23 25:4,19,22 26:11 26:14,19 27:5,15,20 28:19 28:22 29:1,8,16,17,18 30:6 30:22,25 32:7,8,9,21 33:12 33:21 34:4,6,12,18,24 35:6 35:21 36:14,15 37:9 38:6 38:10,1941:1942:1043:7 43:15,22 44:12 45:8,10,15 46:13,17,20,24 47:2,4 48:8 49:3,5 50:3,3,24 51:4,8,17 51:22 52:2,25 53:14,20 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49509 [pcbs - provide] pcbs (cont.) pigmentation positive 54:7 55:8 56:12,23 57:6 36:3 41:3 71:23 58:4,7,11,14,21 59:3,10,18 pipefitters possible 60:1,5,12 61:7 62:1 68:9,11 14:7 62:6 69:16,24 70:11 71:13,20 pipelines posture 72:1,6,17,22 73:5,16 74:12 14:8,9 57:9 74:14,15 piping posure pcb|s 14:9 46:12 35:13 46:10 place potential pencil 9:1 11:7,7 16:22 17:1342:5 72:8 45:22 55:14 potter pension plaintiffs 41:2 3:15 1:5 24:14,18 30:21 36:15 poultry people 60:4 73:3,15 51:19 8:8 13:20 14:11 16:25 plaintiff's pounds 18:24 20:24 23:22,24 30:25 50:1 23:12 34:12 35:4 36:14 43:4 planet power 44:19 50:8 54:17 61:16 33:23,24 69:25 62:11,19 63:20,22 64:2,22 plant ppened 72:14 73:3,15 5:19 6:19,22,24 7:10,13 31:7 peop|s 9:16 10:2,6 11:19 13:9,10 precise 27:15 13:14,15,20 14:3,18 16:21 43:7 percent 17:11 20:2,6,14,21 21:1,5,6 prefecture 46:17,23,24 21:8,12,16,18,21,24 22:3 35:19 percentage 23:5,5,8,14,15 24:23 25:17 prepared 46:19 25:18,19,21,24 26:2,3,7,19 45:2 49:6 62:11 period 26:21,22 27:14 28:24 29:4 presence 4:22 8:15 40:8 50:6 63:19 29:25 30:17 31:7 41:25 59:3 72:6 73:8 plan|3 present periods 6:8 7:5,7,9 52:7,21 8:14 plants presentation permit 7:1 21:19 26:25 18:13 49:2 46:12 plants presented persistent 7:5 38:2 50:23 52:8 42:10,12,14 plastic present^ person 6:2 28:13 50:9 15:20 17:7 37:12 42:20,21 plasticide president 53:8,8 68:4 69:6 45:24 41:6,9 personally plastics president's 9:20 48:9 52:21 55:11 6:2 45:25 53:9 60:21 72:13 play pressures petroleum 49:9 22:21 4:20 please pretty Phillips 11:4 18:11 39:1558:19 4:24 15:6 4:19 plus prevent phrase 52:21 54:21 52:2 59:9,10,17 70:16 46:8 point primarily phthalic 6:18 8:25 14:16 17:17 27:1 5:25 19:1021:1526:8 30:19 prior physician 45:7 49:11,1250:1451:23 9:4,9 61:22 16:21 17:11 55:21 probability pick position 73:12 55:14 20:18 32:5 37:4 57:9 59:1 problem piece 62:1 66:7 70:1 72:2 18:5 38:14 7:17 positions problems 55:15 10:2 15:12 procedure 22:22 proceed 1:8 2:25 39:15 69:14 74:5 74:22 proceedings 39:14 process 22:22 23:4 24:19 27:9,9 processes 20:6 produce 7:12 20:25 42:3 produced 23:12 42:6 46:17,21 producers 33:19 produces 72:7 producing 43:15 71:25 product 5:4,19 11:9 20:7 production 6:7 20:6,9,24 41:24 43:12 69:16,24 products 18:23 20:25 21:14 22:18,23 22:24 27:11,12 40:15 42:1 program 37:18 38:13 45:10 48:5 63:9 promotion 6:4 26:5 promulgated 52:4 proper 18:2 44:3 50:8 56:23 properly 15:8 46:12 64:4 proportion 55:9 propose 4:12,138:12 proposition 71:12 protective 27:14,19 29:6,7 pro|3 48:8 protocol 64:11,14,1665:16 protocols 69:5 provide 2:8 20:24 53:18 69:22 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49510 [provided - return] provided 69:23 prudent 63:11 public 51:19 published 16:10 57:3 pull 35:10 pumping 14:5 pumps 14:4,4,6 purpose 42:2 59:15 purposes 43:16 put 23:12 29:3 46:25 56:22 69:25 73:2 q qt> 26'11 qualifications 32:4,10 qualified 62:23 quality 5119 53 10 64 5 quarter 4716 queeny 6:19 9:16 10:2 13:9 20:21 question 12:2 16:23,23 18:4 34:25 36:12 43:1 58:17 64:20 68:19,20 69:13 questions 1:14 18:13 55:24 quit 1:1841:1969:19 quite 32:6 58:9 quitting 69:16 quote 46:2 r raincoat 27:24 raised 34:25 raling 16:4 range referred 72:21 15:13 22:10 47:7 rapidly referring 29:6 45:9 rate refilling 2:11 13:21 ra|s reformulating 63:23 48:4 raw refresh 62:22 63:2,11 64:2,9 65:13 59:20 69:6,10 regarding reached 41:23 62:14,18 51:23 regulate read 51:4,7,10,17,21,25 55:7 11:2 39:1 61:7 reading regulating 16:12,16 44:20 51:24 really regulation 8:5 23:18 30:8 52:1,4 59:10,18 reason regulations 42:9 68:7,15 71:25 reasonable releases 59:6 63:11 68:12 45:23 reassured relied 30:9 50:15 64:21 recall rely 2:178:129:11 16:12,16,19 50:1,20 63:20 16:20,24 19:23 33:7 34:15 remain 36:5,6,7,9 41:1,5 47:15 24:22 51:1459:23 60:1361:2 remember receive 2:15 9:20 34:5,10 35:25 18:8 36:2,3 40:14 44:20 59:22 received removal 4:1,3 49:22 52:12 54:1 45:10 61:21 removed receiving 16:3 33:5 removing recess 45:8 39:13 rem|3 recessed 59:13 74:23 repairing reckless 13:16 67:9,10 repeat record 11:3,4 49:25 50:16 repeated records 14:23 19:11 17:12 repeatedly red 8:14 15:11 rephrase reddening 58:19 68:20 14:24,25 replaced refer 1:1 28:23 29:22 38:21 12:19 16:12 57:11 63:18 reference replacement 42:20 43:21 44:13 47:14 report 34:5 39:18 40:9 50:7 52:11 69:1,10,12 reported 35:22 40:10 reporter 6:20 40:1 42:11 report 39:24 reporting 31:1240:1941:1 66:18 reports 32:21,22,23 33:4,7,10 36:11 50:5,21 52:16 53:24 54:1,19 60:20 61:17,20 67:23 68:1,3,7,22 represent 56:11 representative 1:21 17:9 representatives 48:13 49:5 51:15 53:6,13 53:25 61:20 represented 52:11 reputable 68:5 research 4:22 resistent 28:21 29:1 respect 8:6 18:7 44:10,11 54:9,18 55:2 respirator 29:14 response 53:22 responsibility 63:6,8 responsible 64:3 rest 43:5 restate 11:1 result 32:22 results 50:10 54:14 re|s 3:9 retire 1:18 return 21:2331:1432:11 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49511 [returned - specifically] returned sat 31:16 59:8,11 review sauget 34:9 52:14 21:2,9,23 26:21,22 reviewed saw 30:9 32:24 67:7 right saying 3:22 9:16 10:14 12:3,4 13:3 21:24 39:24 15:21 21:15 22:1,25 24:6 says 26:3,24 27:14 28:8 37:18 69:12 39:10 40:7,17,25 42:7 schedule 43:15 48:17 50:22,25 53:23 64:13 64:7,20 69:21 scheduled river 23:11 21:11,19 scheme rivers 59:9 33:6,14 science rk 4:1,4,5 53:9 67:21 scientific robert 43:4 41:2 scientifically role 42:25 49:9 scientists room 33:20 34:3 73:11 54:17 score roughly 37:17 59:1 13:22 22:16,17,20 23:19 sealants route 45:19 35:12 sealed rp 46:11 51:21 second rubber 5:20 6:23 25:24 27:2 27:20,23,24 28:1,2,14,25 section 29:11 12:20 45:13 rubbers seeing 29:2 3:19 16:20 33:16 rubber^ seeking 29:1 55:7 57:6 58:1,6,20 run seen 25:24 37:18 5:128:19 15:1 17:465:10 running selected 61:1671:9 37:17 s car rifirp 7016 safer 20:8 safety 18:10 69:22 70:17 sell 9:7 selling 47:4 sent 45:6 sentence 18:19 41:24 samples 33:14 sam|3 27:5 serve 42:2 served 15:7 services 19:22 20:23 set sit 58:1 11:16 seven si|3 39:24 40:1 68:8 22:23 23:7 severe situation 15:6 29:5 32:25 severer situations 15:3 15:8 share six 50:7 20:4 25:1 68:8 shared skin 50:10 8:15 14:24,24 15:2,11,14 shipment 15:15,17 16:3 44:3 skyscrapers shipped 45:20 7:12 sleep shipping 36:4 20:22 smith shoe 48:25 49:15 28:20,25 society shoes 69:22 29:5,8 softeners short 6:2 27:24 28:16 sold show 8:7 62:5 sole showed 28:21 37:22 somebody shrimp 25:7 32:24,25 38:12 somet|3 shut 52:12 70:13 sore shutdowns 15:12 70:2 sorry side 1:3 20:1531:23 36:21 55:5,7 74:7 sort similar 20:23 27:23 22:18 23:1,3 27:9,11 sounds simply 46:19 67:9 source sincere 8:21 27:2 69:20 south sir 6:23 1:22 2:25 3:14 7:16 9:15 speak 11:13 12:1,25 15:24 16:7 3:4 17:6 23:9 27:21 29:17 31:9 special 31:18 32:3,15,17,19 33:3 24:2,3 45:21 35:9 40:5,17,24 41:17 specialized 43:14 46:19 48:22,24 49:1 28:14 49:24 52:17 54:24 58:22 specialty 59:21 61:24 65:8,14,25 41:3 68:5 70:7,15 71:7,17 72:8 specific 74:5 16:19 23:5,5 43:16 sir.|3 specifically 51:1 61:6 71:10 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49512 [spect - testing] spect stratosphere supplement tanks 68:5 41:9 3:18 43:18 speculation streams supplier task 43:3 33:6,14 35:4 46:6 52:25 53:4 56:25 spell street supply taught 6:1925:11 5:20 6:23 27:2 37:21 spend stricken supplying technical 27:18 52:7 27:3 19:21 32:9 spent strike supported technician 2:20 4:24 37:25 38:15 68:10 23:23 66:8 spoke striving suppose technologically 49:8 61:18 57:8 8:19 32:9 61:11 47:13 sponsored studies sure technology 61:5 32:23 38:9,18 48:20,21 22:7 36:23 45:25 49:12 53:9 St 49:2,10,13,14,17,22,23 66:20 69:1 71:22 telephone 5:20 6:23 31:12,14,16 50:1,5,10,15,15,23 52:7,8,9 surface 37:24 37:24 62:20 54:22 62:2,11,12,13,14,18 46:5 tell standard 66:24 69:5 suspicious 3:23 4:18 5:17 13:6 19:24 56:22 57:3 studiesp 68:15 30:7 32:12 37:3 40:12 start 39:5 sustained 54:12,14 64:9,15,15 65:15 4:16 17:1548:7,15 study 58:19 68:21 65:18 started 20:5 34:15 39:4 50:19 sustain telling 32:1 33:25 45:8 48:4 54:15 73:12 69:14 2:10 starting stuff SUp tellp 8:25 48:3 68:13 73:4,16 68:5 65:13 starts subject Sweden temperature 14:18 37:1 61:1962:16 34:1 72:7 state substance sworn temperatures 4:6 70:6 72:11 1:7,11 22:21 statement subways symptoms ten 8:17 42:18 47:6 55:8 64:12 70:3 15:4 16:4 36:17 39:10,11,20 73:24 74:1,3 states suggest system tenure 7:15 21:20 25:22 48:7 6:6 8:24 23:22 68:7 46:8 52:3 31:7 56:1361:6,12 suggested systems ter statute 68:15 7:8 8:1 14:12 46:7,10,12,15 39:24 70:9 suggestion 46:16 47:3,8,11,11,21,21 term stay 68:11 47:23,25 48:1,5 50:19 56:1 31:14 37:1 42:15,16,18 summaries systep terminate staying 49:6 50:5 14:10 1:18 42:21 superintendent steel 13:8 19:21,25 20:22 24:23 28:20 24:24 25:1 step superiors 74:17 69:4 Stic supervise 70:16 13:10 stop supervised 43:12 47:18,22 55:15 73:25 13:11 25:4 74:6 supervising stopped 6:8 40:4 47:4 70:14 supervisor stopping 11:19 69:24 supervisors storage 13:13 23:12 supervisory 6:10 t taken 5:9 33:14 39:13 44:2 talk 3:22 12:3,5 13:19 25:24 26:13 28:18 67:22 71:10 talked 4812 talking 7:19 18:5,22,25 19:4 23:2 31:2 39:19 48:7,15,21 49:13 50:2 69:4 tankpr 17:18,21 30:20 31:2 55:1 tankers 36:13 73:2,14 terminated 47:12 termination 41:23 terms 37:22 50:18 test 38:10 62:5,6 testified 1:11 44:17 48:23 testify 18:24 65:9 testimony 1:1 2:1 45:14 49:15 66:23 testing 38:11 54:8 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49513 [tests - value] tests throw toxicologists u 63:2 64:4,5,10,13,22 65:15 29:9 63:15 u.s. test|s thrust toxicology 53:6 64:16 41:14 59:14,23 4:11,14 37:5,22 66:12,14 uesswork tever th|3 66:16 43:5 16:3 19:1 25:25 49:19 62:3 trade unacceptable th till 22:6 67:17 2:4,15 3:19 4:12,22 5:5,25 20:13 transfer underlying 6:21 8:24 9:11,21 10:6 12:5 time 7:8 46:15 47:21 48:5 68:25 13:10 14:19 15:2 16:12 1:25 2:206:11,13,188:14 transformer understand 17:7 19:22 20:1521:10 8:159:11,17,17 11:13 9:18,21 71:1 14:19 16:1839:641:13,13 23:17 25:3 27:25 28:18 12:16 13:5,23,25 14:11,16 transformers 43:25 44:5 46:8 52:20 29:19 30:24 31:19 32:4 14:17 17:17 19:10,16 22:15 7:4 56:12,24 62:24 64:25 65:25 34:2 35:23 36:7,25 38:1,17 23:10 25:14,21 26:3,8 27:7 traveling understanding 39:14 41:1,21 42:4 43:16 30:13,19 34:3,23 37:1 40:6 49:4 16:7 30:10 42:18 46:16 44:18 45:20 46:17 47:10 40:8 41:2 44:9 45:2 49:11 trial understood 49:11 52:4 53:4,20 54:4 49:12,21 52:23,24 53:23 1:1,21 2:43:10,134:11 41:1453:1 55:5,14 56:8,18 58:11 55:4,5 56:16 57:5 71:7 5:13 65:9 undertake 59:22 60:16 61:11 62:12,20 72:10 73:8 74:22 tried 37:3,8 63:3,13 64:7 66:17 67:1 times 35:1 unit 69:5,23 71:3,24 72:8,17 44:25 72:17,22 true 5:23 23:17,23 40:22 73:1 74:12 tion 2:13 32:24 41:18 46:17 united thank 22:15 51:8,9,12 52:3,25 55:3 57:6 7:15 21:20 25:22 48:7 1:2 31:25 44:15 52:6 58:13 title 61:9,10,13 62:12 65:21 56:1361:5,12 74:22 12:1726:1 31:22 32:11,12 67:2,5,19 69:1,16 72:7,7 units thes|s titles truth 20:9 35:3 40:12 33:16 university the|s today try 4:2,3,7 26:21 30:13 55:20 64:25 71:20 7:25 13:24 20:6 37:16 unknown they|3 toe 39:11 40:14 45:16,18 53:5 3:4 17:16 28:20 trying unprofessional thick told 2:15 22:19 23:3 51:4,7,10 67:11 37:24 12:8 15:15,18 43:6 44:24 51:17,21 53:15 58:11 59:2 ure thing 54:9 64:1,12,22 61:6 63:10 71:8 19:11 42:3 tomorrow ts use things 74:19 39:24 8:17 9:21 27:20 28:19 29:6 15:7 18:14 63:25 top tp 29:7 35:20 36:16 44:3 45:8 think 37:15 63:19 20:5 28:9 68:22 49:2 52:6 56:23 58:21 60:2 7:25 8:5 9:3 13:24 17:10,17 tor tubing 61:8 64:20 69:21 73:15 19:2 20:19 22:2 39:4 45:16 24:19 14:8 user 47:19 56:5 63:8,10 67:25 toth ture 18:8 46:6 68:11,19 72:25 50:2 7:22 users thinkers toxic turn 18:22 30:21 56:11 60:4 41:25 34:23 53:19 62:1,4 63:2 65:20 uses thinking 70:6 72:11,17,22 73:6,17 turned 18:2 45:11,12,1446:1,2,3,5 15:5 46:14 69:15 toxicity 30:10 32:25 46:14 this|3 34:4 38:18 49:3 50:3,24 tutorial utilities 37:18 53:20 54:19 68:9 69:5 37:20 20:22____________________ thi|3 72:20 type 48:18 toxicolog 7:18,22 14:5 20:23 23:13 v thought 53:19 24:3 26:19 28:12,14 45:19 valid 16:6,12 29:3 68:24 69:2,3 toxicological 73:11 32:24 62:12 69:17 54:18 67:21 types validity three toxicologist 4:21 24:1 26:20 28:9 53:13 52:9,10 69:8 49:17 62:21 63:20,21 64:1 66:17 value 69:8 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49514 [varied - yusho] varied wear words year 39:19 29:12 4:25 8:10 15:11 43:24 44:4 2:15,19 4:22 23:11 40:3 various weeks 44:25 64:20 46:17,20 52:23 28:9 3:12 wore years varnishes wells 27:15 4:21 5:1,7 8:20 16:17 30:1 45:21 4:23,24 work 36:10 38:17 39:20 47:3 vice welp 1:154:16 11:7,7 13:1420:4 50:20 65:11 70:19 72:10 41:9 visit 41:11 wendell 28:20 29:24 69:8 70:3 worked yP 44:9 58:20 38:7,10 40:19 14:8 65:21,23 66:4,6 yusho visited went worker 35:14,19 36:12 54:15,16,17 38:3 62:21 3:23 63:22,24 65:13,23 15:19 60:10 vomiting 66:4 workers 36:16____________________ werp 18:6,10 23:15,25 24:2,13 w 46:2 27:19 29:4 waiting westinghouse working 1:3 14:17 18:24 56:7 59:16 1:19 4:20,22 13:21 14:6,9 want wep 27:15 28:6 36:14 7:1 12:19 13:5,19 18:12,14 32:23 workplace 19:3,16 21:23 22:14,24 28:1829:1032:11 37:1,5 we've 5:14 58:11 59:4 works 37:16 39:8 49:12,20 50:13 whap 2:6 50:14 53:3 55:4,9 65:20 16:3 world 68:11 71:10 72:4,5,13,25 wheeler 31:1743:2 70:14 74:17 wanted 12:5,15 37:21 49:6,7 50:8 worldwide 50:10 52:8 54:4,6 63:19 33:19 57:10 58:14,24 59:6 61:12 65:3 66:21 worried warehousing 20:22 wheelp 12:16 35:5 wop warn 8:8 14:20 44:19 60:5 73:3 whetp 61:19 67:21 wouldp warned william 18:1 16:11 24:13 30:24 1:6,1021:6 woulp warning willing 55:24 8:7,18,21,22 10:9 15:4 16:10,24,24 17:5,8,19,20 74:6 win wright 59:9 61:3 65:21,21,23 66:3 18:7,25 19:3 24:12,17 3:20 74:17 67:20 68:12,25 69:9 30:20,24 36:13,18 43:17 windows wright's 44:10,11 54:25 60:3 73:14 45:20 66:24 warnings 18:5,18,21 winter 28:25 writing 17:2,4 Washington wisest written 4:2 74:11 42:3 17:25 wastes withstand wrong 32:8 29:8 58:9 68:2,5 watching withp wrote 15:7 8:6 69:10 water witness wp 58:7,10 59:11 1:6 2:2 31:24 39:25 74:19 7:12 52:21 65:22 watery wm X 36:3 1:1 xtremely ways word 73:17 4:23,23 weakness 36:4 8:12 9:21 19:1,6 22:2 30:14 37:6 52:10 y wording yeah 8:11 2:8 39:9 63:5 70:5 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (2) TOWOLDMONOQ49515