Document 586KoaY2LxndYe5K1a7o9Q70

FILE NAME Cape Asbestos CAPE DATE 1975 June DOC CAPE150 DOCUMENT DESCRIPTION Deposition of Richard Gaze Legal - Tibbs Case Exhibit 48 3249426 ELECTRONICALY ELECTRONICALY ELCTRONIAY 7 IN THE UNITED STATES DISTRICT COURT 2 FOR THE EASTERN DISTRICT OF TEXAS 3 TYLER DIVISION 4 FILED - bs 5 ve 2023 Oct HERMAN YANDLE et al fe 6 86 Plaintiffs AO 18 ? g 10 10 11 VS. PPG INDUSTRIES INC et al Defendants 12:13 FO Of Civil Action No.TY 80 PM Od - oo 08 RICHLAND 08 A@ - 12 12 COMON RNC 1313 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS . PLEAS 7474 TYLER DIVISION PLEAS 15 15 16 16 1717 .18 .18 19 19 a x LESTER KAY And all Intervening : Plaintiffs : VS. : PPG INDUSTRIES INC et al : - PLEAS Civil Action No. 74-1320234001759aa 203401759 2023401759 2020 a x 2121 egetens - Deposition of RICHARD GAZE produced sworn and 22 examined the 4th and 5th days of June 1975 at the offices of Messrs Davies Arnold & Cooper 4/7 Salisbury Court London re EC4Y 8AD England pursuant to a Notice Walter H. Clark of Harry Counsell & Co. 61 Carey Street London WC2A 2JG England acted as Reporter 1 A 2 ; 3 4 Q 5 A 6 7 8 9 10 ;Q 11 o .& F | A 13 14 ~*~ | f 15 : | 2S 16 A Yes but I today was would repeat that the extent or the what I did not concentrations know as I know of asbestos dust ELCTRONICALY whic could be regarded as hazardous ELCTRONICALY But you did know that ---- ELCTRONICALY I knew for example that the kinds of condition that my FILED colleagues at that time who had worked before the 1933 2023 regulations described to me as being the conditions in the Oct industry I knew I could see that these conditions could 18 cause asbestosis 12:13 So then you knew that the conditions as they existed then PM if not corrected could cause asbestosis RICHLAND The conditions as they existed before 1933 yes of which RICHLAND I had no experience but which had been described to me very COM ON clearly COMON What were those conditions PLEAS The descriptions that were given to me in a general sense PLEAS 17 | 18 were conditions in which the asbestos dust around some machines was so thick that you could not see your hand 19 stretched out in front of your face This was the kind of description that was given to me of the conditions existing 2 Q And unfortunately you knew that these working conditions would ~ continue to exist throughout the world for a perioodf time CASE 203CP401759 203CP401759 203CP401759 : 2023CP401759 ~ that they wouldn't be changed overnight #L _ #L 26 A No but this was 10 years later that it was described to me and of course there were time conditions too involved here where there were very long working hours I know now 27 with hindsight that there were people exposed during the war f 28 who were being subjected to as much danger as people who were 29 in the firing line 30 110 ELECTRONICAL Y Q People exposed to asbestos ELECTRONICALY ELCTRONIAY A That's right | ( 3 | Q But the point I am making and I want to make it clear 4 16 the extent of your knowledge as to the effects of asbestos 5 was such that beginning with the 1950's and through the 1960's FILED - 6 and into the 1970's you realised that it was a dangerous 2023 7 material to work around Oct 18 A Yes but I want to make my position quite clear on this 12:13 9 Mr Baldwin I realised that precautions needed to be taken PM 10 - in the handling of this material What I realise now I was 11 & 12 RICHLAND in error about was the extent of the precautions which needed to be taken - 13 | Q What precautions do you feel should have been taken that 14 were not when you look back COMON 15 A With hindsight I believe that our siting of dust exhaust | ^' machinery PLEAS 16 was not sufficient to reduce the concentration of - 77 | 18 asbestos dust in the atmosphere to a sufficiently low level Q But what I am asking you is that you don't intend to imply 203CP41759 19 20 that you have just recently come upon the knowledge that asbestos can cause the condition of asbestosis 21 | A No. I knew that asbestos improperly handled could cause 22 asbestosis or breathing asbestos dust at too high quantities 23 24 | 25 26 for too long a time could cause asbestosis I have known this since the first day I was employed Q All right You have defined asbestosis yesterday haven't you You don't intend to change that definition 27 A No. \ 28 | MR BALDWIN I have nothing else 29 MR BERNAYS Are you through 30 | MR O'CONNOR Yes 777 a | 1 ^' 2 3 4 5 | 6 7 8 9 10 | 31 12 | 13 aa 74 15 16 | 17 ; 18 wet, MS 19 , 20 ~ | ~ ~ 24 25 ~ CROSS EXAMINATION by MM BERNAYS ELCTRONICALY ELECTRONICALLY Q Dr. Gaze I believe you mentioned the British regulations on ELCTRONICALY ELECTRONICAL Y asbestosis as having been promulgated in 1933 ELECTRONICAL Y A Yes ELCTRONICALY Q Could it possibly have been 1931 that they were promulgated FILED FILED 2023 A It could be yes Q You are not certain about that 2023 Oct A I am not certain 1931. Thank you 18 MR BERNAYS That's all we have 12:13 12:13 A But of course in the light of later knowledge they were PM revised in 1969 RICHLAND RICHLAND MR BALDWIN Dr. Gaze thank you for letting us impose upon your RICHLAND RICHLAND time You were very operative COMMON COMMON A Not at all Thank you for being so considerate COM ON COMMON COM ON PLEAS , The foregoing deposition PLEAS Witness having been taken down in shorthand ; CASE and afterwards transcribed was CASE read over by the witness and 2023CP401759 subscribed to on the day 2023CP401759 of 1975 2023CP401759 2023CP4001759 2023CP4001759 een nenene 2023CP4001759 I Walter H. Clark of Harry Counsell & Co. 2023CP401759 61 Carey Street London WC2A 2JG England a Member of the Institute of Shorthand Writers hereby certify that the foregoing deposition of RICHARD GAZE is a true and correct record of all questions asked and answers made of the said witness , sare W.H. Clark 28 29 112 30