Document 3Npjk43gp92Xr66Ja5r6zrEGO

FILE NAME: &'ZZ&' DATE: K DOC#: &' DOCUMENT DESCRIPTION:>ZZZtDZ 1 1 IN THE COURT OF COMMON PLEAS 2 CUYAHOGA COUNTY, OHIO 3 JANE CUNNINGHAM, Executrix for the Estate of 4 David G. Cunningham, 5 Plaintiff, JUDGE TALTY 6 -VS- CASE NO. 150433 7 AKRON GASKET & PACKING ENTERPRISES, INC., et al., 8 Defendants. 9 10 - - - - 11 Deposition of WILLIAM MCCORMICK, taken as if 12 upon cross-examination before Gala J. Marzec, a 13 Notary Public within and for the State of Ohio, 14 at the offices of Bevan & Economus, Northfield 15 Road, Northfield, Ohio, at 10:00 a.m. on FORM C SR - LASER REPORTE RSPAPER &MFG CO. 800-626-6313 16 Friday, October 25, 1991, pursuant to notice 17 and/or stipulations of counsel, on behalf of 18 the Plaintiff in this cause. 19 - - - - 20 MEHLER & HAGESTROM 21 Court Reporters 1750 Midland Building 22 Cleveland, Ohio 44115 216.621.4984 23 FAX 621.0050 800.822.0650 24 25 29 1 employees? 2 A. There was a potential problem. 3 Q. Are you aware of any specific industrial 4 hygiene memos at B.F. Goodrich Company relating 5 to not potential problems but actual problems 6 based upon measurements taken by the industrial 7 hygiene department, asbestos exposure? 8 A. I think we perhaps took some measurements. I 9 think we perhaps took some measurements at this 10 operation. 11 Q 12 Did those measurements indicate to you that there was a hazard to employees? 13 A. I don't recall specifically, because that's 14 been years ago. But we did do air sampling. 15 We also examined personnel. FORM CSR - LASERREPORTE RSPAPER & MFGCO 800-626-6313 16 Q Did you do air sampling on a regular basis in 17 every department? 18 A. It depends by what you mean by regular. 19 Q. Every day? 20 A. No. 21 Q. Every week? 22 A. No. 23 Q. Every month? 24 A. No. 25 Q. Every six months? 30 1 A. It would vary. 2 Q. So you really don't know how often you did it 3 or how frequently? 4 A. No, I don't. 5 Q There was no program set up at Goodrich which 6 established a periodic air sampling regimen in 7 every department that you know of? 8 A. No. 9 Q. Are you familiar with whether or not -- strike 10 that. 11 Let's talk about air sampling a little bit 12 more. Did you personally ever conduct any air 13 sampling in any of the tire curing areas? 14 A. I probably did. 15 Q. Do you have any records of that that you can FORM CSR - LASERREPORTERS PA PER & MFG CO. 800-626-6313 16 show me? 17 A. No. 18 Q. Do you recall the results of those air 19 samplings? 20 A. No. 21 Q. Do you recall how often you did it? 22 A. No. 23 Q. At Goodrich was the curing area also known or 24 were the curing areas -- 25 There were more than one tire curing 43 1 A. A compounder? 2 Q. Yes. 3 A. A compounder was basically a chemical engineer 4 who devised formulations, checked raw 5 materials, did a number of things. 6 Q. Would a compounder have been exposed to 7 asbestos containing materials at the Goodrich? 8 A. Probably not. 9 Q. Was raw asbestos used in the calendar room? 10 A. No. 11 Q. Did you or anyone, in your department ever, 12 monitor for asbestos in the ambient air at the 13 B.F. Goodrich in the 1940's-and' 50's? 14 A. I do not.know. - That's, a:Lons:_tiln.e- ago. 15 Q. Do you recall specifically when you yourself FORM CSR - LASERREPORTERSPAPER & MFG CO 800-626-6313 16 first became involved in air monitoring at the 17 Goodrich? 18 A. Oh, I became involved from 1946 on. 19 Q. In air monitoring? 20 A. To some degree. 21 Q. Did you keep records? 22 A. Yes. 23 Q. You don't know where they are? 24 A. They're with the B.F. Goodrich Company. They 25 were there when I retired. I don't know where 44 1 they are now. 2 Q Are you aware as we sit here that asbestos 3 exposure can cause disease in human beings? 4 A. Yes. 5 Q. When did you first become aware of that fact? 6 A. Oh, I can't recite dates. But certainly back 7 in the late 30's probably. 8 Q Are you familiar with the department 153 in 9 Building 5-F at the Goodrich? 10 A. No. I'm not familiar with it. 11 Q. Do you know whether or not asbestos was ever 12 used as a binder in rubber formulation in that 13 department? 14 A. I don't know. 15 Q. You don't know? FORM CSR - LASERREPORTERSPAPERSMFGCO 800-626-6313 16 A. No. 17 Q. Do you know whether employees at the Goodrich 18 ever used wire brushes and drills to cut 19 asbestos blocks used at Goodrich, one of the 20 hazards in the ink mill with asbestos exposure 21 at Goodrich? 22 A. No. 23 Q Do you know whether or not Goodrich was ever 24 cited by the U.S. government for violation of 25 standards regarding airborne asbestos? 53 1 Q That's a very general term. Are you familiar 2 with a principle which indicates that asbestos 3 fibers once released into the ambient air have 4 a tendency to settle, and once settled, again 5 released based upon sweeping or blowing or some 6 other such of mechanical action? 7 A. Perhaps no more than any other particles of 8 dust that settle. 9 Q Do: you know whether or. not at Goodrich that was 10 ever a' concern? 11 A. Never a concern for us. 12 Q. Ne'ver a' cOncern. Okay. Why was that? 13 A. Why; races it? 14 Q . Yes";,-: L'WhY"'wasp:' t- it a: ,concerm? 15 A. 1.1e -,wotrkdrui;tv_be' any''-'mcir-el'con"c,erned, about that FORMCSR LASERREPORTERS PA PER & MFG CO 800-626-6313 16 -- 17 Q. Why not? 18 A. -- which contain asbestos fibers. 19 Q. Except you had no control over the sweeping of 20 city streets containing asbestos fibers? 21 A. That's correct. 22 Q. But you did have control over Goodrich? 23 A. Yes and no, but not to that degree. 24 Q. When you did air sampling studies at the 25 Goodrich, if you found what you believed to be 54 1 asbestos in the ambient air, would you make a 2 report of it? 3 A. Oh, yes. 4 Q. Would you let the employees in the area where 5 the sample was done know of the contents of 6 your report? 7 A. No. 8 Q. Why not? 9 A. The company policy, and I think this was at 10 that time, perhaps still is, very general. The 11 reports went to management with 12 recommendations, if there were any 13 recommendations. 14 Q. Up until the late 50's at Goodrich no one had 15 done any work on anything that could be related FORM C SR - LASERREPORTERS PAPER & MFG. CO. 800-626-6313 16 to asbestos, is that a fair statement? 17 A. You'll have to define your terms. You said no 18 one did any work on asbestos. I can't verify 19 that. I don't know. 20 Q. Did you establish an industrial hygiene 21 laboratory at the Goodrich? 22 A. Yes. 23 Q. In the mid to late 50's? 24 A. I established a laboratory soon after I came 25 there in 1946.