Document 3JK639DZd1GmeMR0qy3a6k1kx
fibers equal to or in excess of OSHA exposure limits for asbestos fibers. From
October, 1973 to August, 1986 the warning label read as follows:
CAUTION CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST BREATHING ASBESTOS MAY CAUSE
SERIOUS BODILY HARM
From September, 1986 until the present the warning label reads as
follows:
DANGER CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD
After Honeywell discontinued the manufacture and sale of asbestos-containing friction
products, it continued to label its non-asbestos containing friction materials with cautions
concering dust exposure.
INTERROGATORY NO. 65: If your answer to Interrogatory No. 64 is "Yes," identify each and every product Upon which such a warning was placed, and with respect to each such product identified:
(a) State the date on which any order directing that a warning be placed on said product first issued;
(b) Identify any and all persons participating in the decision to issue that order;
(c) State the first date on which such warning was actually placed on said product;
(d) State the first date on which such product accompanied by such warning was first sold, distributed or installed;
(e) State the exact wording of this first warning;
(f) State the exact location and size of this first warning as it appeared on said product;
(g) Identify any and all persons who participated in any phase of the drafting or design of said first warning, including, but not limited to, those who performed
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