Document 2RNBEMg2mQLxqwN0B3zbOreL7

FILE NAME: General Motors (GM) DATE: 2001 Aug 29 DOC#: GM082 DOCUMENT DESCRIPTION: Legal - Deposition of Dr. William Krebs WILLIAM KREBS, Ph.D., AUGUST 29, 2001 162 1 IN RE: BALTIMORE CITY * IN THE 2 ASBESTOS CASE * CIRCUIT COURT 3 FOR 4 BALTIMORE CITY 5 'k k * * k k k k 6 GABRIEL NOVO, et al., * CASE NO. 24X00000003 7 Plaintiffs, * AUGUST 2001 TRIAL GROUP 8 vs. * HON EDWARD J. ANGELETTI 9 ACandS, INC., et al., * CONSOLIDATED CASE NO. 10 and * 11 A.P. GREEN INDUSTRIES, * 12 INC., a/k/a A.P. GREEN * 13 REFRACTORIES, a/k/a * 14 RHI REFRACTORIES * 15 AMERICA GREEN BOULEVARD * WILLIAM KREBS, Ph.D ., AUGUST 29, 2001 195 A. I would say approximately 1973, 1974. Q. After that point were all of the General Motors brake materials shifted to semi-metallic or were just some of them? Did General Motors immediately start making all semi-metallic brakes and no asbestos brakes? MR. THOMPSON: After, as of what year? 1973? MR. RUCKDESCHEL: Seventy-three, when whatever this year you have given me the approximate date. THE WITNESS: No. General Motors did not immediately switch 100 percent of its manufacturing to semi-metallic linings. There are many considerations that go into the development of a braking system and there was very extensive testing that was required and design considerations before a new brake system could be employed in a motor vehicle. Q. (BY MR. RUCKDESCHEL) For vehicles that were produced prior to 1973 did General Motors continue to produce brake linings for those vehicles after 1973? A. For vehicles that were produced prior to 1973 brake linings were available for replacement parts for those model years. My recollection is that there would be periodically a run of or a production run to EANSON/RENAISSANCE COURT REPORTERS Detroit (313) 567-8100 Mt. Clemens WILLIAM KREBS, Ph.D., AUGUST 29, 2001 196 1 meet need if one should occur. 2 Q. Prior to 1982 if such a reproduction run was 3 made for a General Motors car that was originally 4 designed with asbestos-containing brake materials, 5 would the replacement parts made by G.M. contain 6 asbestos? 7 MR. THOMPSON: Objection, but you 8 can answer. 9 THE WITNESS: Yes. They would very 10 definitely have contained asbestos because one could 11 not move from one friction material to another 12 friction material, because as I was indicating 13 earlier, the brake assemblies are rigorously tested v 14 according to the requirements of the Federal Motor 15 Vehicle Safety Standard, and there was no simple 16 replacement for those systems. 17 Q. (BY MR. RUCKDESCHEL) Did there come a time 18 when non-asbestos-containing brake materials were 19 available for G.M. cars that had originally been 20 designed with asbestos-containing brake systems? 21 A. I am unaware of that having occurred. 22 Q. Are you familiar with what companies, from 23 what companies General Motors may have purchased 24 asbestos-containing brake materials during the 1960s 'w 2"* and 1970s? HANSON/KENAISSANCE COURT REPORTERS Detroit (313) 567-8100 Mt. Clemens