Document 4v7j26XNwj1wwdY8bEy06bEVQ
(b) Tests, studies, surveys and/or research of any
type concerning the hazards and/or potential
exposure associated with any specific type and/or
brand of asbestos-containing material/product,
including but not limited to, materials/products
that were manufactured,
sold,
distributed,
installed, applied and/or otherwise used by
defendant and/or any predecessor/related entity,
other than those already identified in response to
Standing Order No. 1 Interrogatories;
(c) Tests, studies, surveys and/or research of any type concerning the relationship between exposure to asbestos and any disease, including pleural disease, asbestosis, lung cancer, mesothelioma and/or cancer of any kind;
(d) Dust counts, industrial hygiene surveys, tests
relating to TLVs, and/or like studies, tests and
or surveys concerning the propensity of any
material/product to release asbestos fibers
(including but not limited to, materials/products
that were manufactured,
sold,
distributed,
installed, applied and/or otherwise used by
defendant and/or any predecessor/related entity)
and/or the quantity of fibers released;
(e) Dust counts, industrial hygiene surveys, tests relating to TLVs, and/or like studies, tests and or surveys concerning the presence of asbestos fibers at any facility, location and/or area (including but not limited to, those owned, operated and/or controlled by defendant and/or any predecessor/related entity) and/or the quantity of fibers present;
(f) Tests, studies, surveys and/or research of any type designed to reduce or eliminate inhalation of asbestos and/or asbestos fibers by persons working with and/or around asbestos and/or asbestoscontaining materials/products; and/or
(g) Research of any type concerning asbestos.
ANSWER;
a) No b) No c) No d) Gleason Facilities were tested for asbestos some
time in the mid 1980s. Please see documents provided. e) See above . f) See above g) Three employees are tested every year relative to
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