Document 5LN968ygM0G218XreByjE57B5

n w u ioof ^.(DO C<4 0jlD 1 f"T!5IiNTIFFS IN THE SUPERIOR COURT OF THE STATE OF DELAWARE || || EXHIBIT HAV-27 IN AND FOR NEW CASTLE COUNTY % SCOTT B. DERR and BRENDA L. DERR, his wife. ) ) ) Plaintiffs, ) ) v. ) C.A. No. 96C-07-226 ) (Asbestos) HERCULES, INCORPORATED, ) et al.. - ) ) Defendants. ) ANSWERS AND OBJECTIONS OF HERCULES, INCORPORATED TO PLAINTIFFS' INTERROGATORIES PER STANDING ORDER NO. 1. EXHIBIT C" Introduction And General Objections This action arises out of Scott Derr's alleged exposure to asbestos allegedly released from a plant in Marshallton, Delaware ("Haveg Plant") at some time between approximately 1957 and 1975. There is no allegation that Mr. Derr was exposed to any Hercules, Incorporated ("Hercules") product or to anything released from a Hercules plant or property. Hercules had no relationship of any kind with the Haveg Plant or any asbestos at that plant prior to 1964. In 1964 Hercules purchased all of the assets of Haveg Industries, Inc. ("Haveg Inc"). Those assets included a 2 wholly owned subsidiary known as Haveg Corporation ("Haveg Corp") and the Haveg Plant in Marshallton, Delaware. In 1965 Haveg Corp was merged into Haveg Inc. In 1980, a number of Haveg Inc's assets, including the Haveg Plant were sold to Ametek, Inc. ("Ametek") and Haveg Inc changed its name to Champlain Cable Corporation ("Champlain"). As the parent of Haveg Inc for a brief period of approximately 16 years, Hercules obtained some limited information and some documents which are relevant to this action and Hercules will respond to these interrogatories on that basis. However, Hercules objects to these interrogatories to the extent that they seek information generally regarding Hercules plants, operations and personnel on the grounds that such information is not relevant to this action and such inquiries are overly broad, unduly burdensome and are not reasonably calculated to lead to the discovery of admissible evidence. Hercules also objects to these interrogatories to the extent that they seek information relating to any time period prior to 1957 or after 1975 on the same grounds. Unless otherwise stated, all of Hercules' responses will be limited to the relevant time frame of 1957 through 1975 and will also be limited to the information and documents relevant to the Haveg Plant. INTERROGATORIES INTERROGATORY NO. 1: Describe in detail, with specificity and particularity each product mined, produced, manufactured or sold by the answering defendant or its pre decessors in title or subsidiaries which contained asbestos 3 for each year from 1926 until 1980; and for each such prod uct describe: a. Its chemical ingredients;' b. State the manner in which it was intended to be used, i.e.. in the construction and/or insulation of buildings and/or equipment, etc.; state: c. For each ingredient contained therein (i) The name or chemical composition of each substance, what harmful effects, if any are known, that it produces in man or mammals and whether it produces its harmful effects through ingestion, inhalation, absorption or a combination of these; (ii) When you determined and/or learned that the substance produced harmful effects and how such effects were produced; (iii) Identify each individual who par ticipated in such determination and/or obtained such knowl edge. (iv) Identify each document that refers, reflects or relates to any information pertaining to the properties of each of the ingredients and/or how the harmful effects are produced as well as your determination of those toxic effects and the manner by which they are produced; (v) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. (vi) Which products or ingredients were mined, which were manufactured and which-were distributed by answering defendants. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules further states that in 1964 Hercules purchased all of the assets of Haveg Inc. Those assets included its wholly owned subsidiary Haveg Corp and the Haveg Plant. In 1965 Haveg 4 Corp was merged into Haveg Inc. Between 1957 and 1965 Haveg Corp manufactured 'and sold a line of asbestos containing products at the Haveg Plant. That business was continued by Haveg Inc from 1965 to 1980. The product line manufactured and sold by Haveg Corp, and later by Haveg Inc, can be generally described as corrosion-resistant chemical process equipment. For further information, relating to those products see Champlain's response to these interrogatories. INTERROGATORY NO. 2; If any product identified in answer to Interrogatory No. 1 and (sic) was produced, manu factured and/or sold under a trade name, identify that trade name(s) and state the time period that each such product was sold under such trade name. ANSWER: Hercules incorporates herein its general objections and its response to interrogatory one. INTERROGATORY NO. 3: For each product identified in answer to Interrogatory No. 1, state: (a) The address of each plant where it was manufactured, processed or packaged; (b) Whether you were the sole producer, manufacturer and/or distributor of the product and, if not: (i) The name and address of each other person, firm or other entity engaged in the production, manufacture and/or distribution of the product; (ii) Whether any other manufacturer produced the product by virtue of a franchise.or license from you; - (iii) The persons or firms who produced the product for distribution in the United States; (iv) The person or firms who produced the product for distribution in the State of Delaware. ANSWER: Hercules incorporates herein its response to interrogatory one. 5 INTERROGATORY NO. 4: For each product identified in answer to Interrogatory 1 state: (a) How the product was sold and/or distrib uted for use in the United States and/or the State of Delaware. (b) Identify all persons, firms or other entities to whom these products were sold or through whom they were distributed during the period 1936 to 1980; (c) For each such person, firm or other entity identified in answer to subpart (b) above, state the following: distributed; (i) the specific product sold and/or (ii) the quantity of the product sold and/or distributed; . (iii) the dates which these products were sold, shipped and delivered to each entity; (d) Identify each individual who has any knowledge of these sales and/or distribution and state with specificity and particularity the substance of each indi vidual's knowledge; (e) Identify and produce all documents which refer, reflect or relate to all sales and/or distribution of each such product to each entity identified above. ANSWER: Hercules incorporates herein its response to interrogatory one. INTERROGATORY NO. 5: For each product identified in answer to Interrogatory 1 state whether you engaged in any advertising program to promote the sale of that product and, if so state: ' (a) The name or description of each adver tising media that you have used to promote the product during the period 1936 to 1980; (b) The name of each national magazine or periodical in which you have advertised the product during the period 1940 through 1976; (c) The date of each issue of such magazine or periodical in which such advertisement appeared; 6 (d) The name and address of each newspaper in which you have advertised the product during the period 1936 through 1980.;' (e) The date of each publication of each newspaper in which the advertisement appeared; (f) Identify each document which refers, reflects or pertains to each such advertisement which was published in each such magazine, periodical and/or news paper ; (g) State whether the advertising of the product was handled by an agency and, if so, state the name and address of each advertising agency that handled any por tion of the advertising of the product during the period 1940 through 1976. ANSWER; Hercules incorporates herein its general objections. Without waiving those objections, Hercules further responds that it did not engage in any such program. INTERROGATORY NO. 6: For each product identified in answer to Interrogatory 1 which was distributed to a com pany that used said products in Delaware or was a distrib utor of said products for an area including Delaware, state: (a) The name and address of the company; (b) Whether the asbestos contained was tremolite, crocidolte, chrysoltile, amosite and/or anthophyllite asbestos and state the amount in terms of the percentage of the total asbestos contained in the product; (c) The total amount of asbestos contained in the product; - (d) The exact formulation of the product including the other non-asbestos ingredients thereof; (e) The name and address of each individual who participated in the formulation of such product; (f) The identity of each document which refers, reflects or relates to any information provided in the answer to this interrogatory; (g) The names and addresses of each indi vidual most knowledgeable about the answers given above in 6 (b) , (c) , and (d) ; 7 (h) Identify the living individual most knowledgeable about distribution of the above products in Delaware and in an area of which Delaware was a part. ANSWER: Hercules incorporates herein its responses to interrogatory one. INTERROGATORY NO. 7: With regard to each form of asbestos fibers identified in the answer to Interrogatory 6, state: (a) Where it was purchased, if it was not purchased, where it was obtained; (b) From whom it was purchased; (c) The manner in which it was received, stored and used in the production of the product. ANSWER: Hercules incorporates herein its response to interrogatory one. INTERROGATORY NO. 8: If you manufacture any insu lation products which are commonly used by insulators and which contain asbestos; (a) Describe how the products 'listed below in (b) are cut, shaped, mixed and applied on the jobs giving particular reference as to whether or not the materials have to be sawed or cut on the job, blown into confined areas, or mixed with water into cement or paste; (b) State if there is any known to you that the products listed below can be used and applied without the worker inhaling any of the asbestos dust or fibers: Finishes; (i) Asbestos cement; Asbestos - (ii) Asbestos pipe covering; (iii) Asbestos bricks or block; (iv) Asbestos sheeting; (v) Asbestos insulation used to cover extremes of heat as well as cold; (vi) Asbestos insulation in loose form which may be blown into homes or building; 8 (vii) Asbestos in spray form; * (viii) Asbestos mineral in fiber form or particulate form. (ix) Asbestos Millboard, rope, gaskets, paper gloves or blanket. (c) Did your company buy any products listed in (b) above from other manufacturers and relabel it or have it labeled for your company? whom. (i) If yes, which products and from (d) Did your company produce any products on the list in'(b) above from other companies? whom. (i) If yes, which products and for . (e) Whether prior to distributing the prod uct you altered it in any manner from the form in which you received it from the sources, and if so what type of altera tions or modifications were made by you; (f) Whether prior to distributing the prod uct you re-packaged or in any way altered the packaging or labelling of the product after receiving it from the source, and if so what alterations were made by you. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules further states that as it understands the question, the Haveg Plant did not manufacture insulation products that were commonly used by insulators. * INTERROGATORY NO. 9: For each product listed in answer to Interrogatory No. 1, describe each end use for which each such product was intended to be used by the general industry and for each such use: ' used; (a) Describe the form of the product when so (b) Describe the process and/or method by which the product would be applied for each such use; 9 (c) Describe the equipment to be used to apply the product for each such use; (d) Identify each document that refers, reflects or relates to any information and state the full substance of the information supplied; . (e) As to any information received orally in answer to any interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory one. INTERROGATORY NO. 10: State whether any of the equipment identified in answer to Interrogatory No. 9(c) was manufactured by you or any parent or subsidiary company or related company. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections Hercules responds that as it understands the question the answer is no. INTERROGATORY NO. 11: If any piece of equipment identified in answer to Interrogatory No. 9(c) was invented, developed or first made by you or any person associated with you or any related company or association, state: (a) When it was invented, developed or made; (b) The identity of each individual who par ticipated therein and describe in detail the extent of his participation; (c) The idehtity of each document which reflects, refers or relates to any information set forth in answer to this interrogatory; (d) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules 10 responds that as it understands the question, its answer is not applicable. ' - INTERROGATORY NO. 12; . State whether you or any person associated with you or any related company or asso ciation invented, developed or made any change and/or improvement in any piece of equipment identified in answer to Interrogatory No. 9(c), and if so: made; (a) Describe the change and/or improvement (b) State when it was made; (c) Identify each individual who partici pated therein and describe in detail the extent of his par ticipation; (d) Identify each document which reflects, refers or relates to any information set forth in answer to this interrogatory; (e) As to any information received orally in answer to this interrogatory, identify each person who has supplied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory ten. INTERROGATORY NO. 13: For each process and/or method identified in answer to Interrogatory No. 9(b), state whether it was developed by you or a parent or subsidiary or related company. ANSWER: Hercules incorporates herein its response to interrogatory ten. INTERROGATORY NO. 14: For each process and/or method identified in answer to Interrogatory No. 9(b) devel oped or first made by you or any person associated with you or any related company or association, state: (a) When it was developed; (b) The identity of each individual who par ticipated therein and describe in detail the extent of his participation; 11 (c) The identity of each document which reflects, refers' or relates to any information set forth in answer to this Interrogatory; (d) ' As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory eleven. INTERROGATORY NO. 15: State whether you or any person associated with you or any related company or asso ciation developed or made any change and/or improvement in any process and/or method identified in answer to Interroga tory No. 9(b), and if so: made ; (a) Describe the change and/or improvement (b) State when it was made; (c) Identify each individual who partici pated therein and describe in detail the extent of his par ticipation; (d) Identify each document which reflects, refers or relates to any information set forth in answer to this interrogatory; (e) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the . information supplied; (f) Identify the living person who has the most knowledge of matters discussed herein. ANSWER: Hercules,^incorporates herein its response to interrogatory eleven. INTERROGATORY NO. 16: For each product identified in the answer to Interrogatory No. 1, describe what, if any, tests were made to determine the safety of said product and: (a) State when each such test was made; (b) Describe the results of each such test; 12 (c) Identify each individual who partici pated therein and describe in detail the extent of his par ticipation; ' (d) Identify each document which reflects, refers or relates to any information set forth in answer to this interrogatory; (e) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory one. INTERROGATORY NO. 17: For each process or method identified in answer to Interrogatory No. 9(b), describe what, if any, tests were made to determine the safety of said process or method and: (a) State when each such test was made; (b) Describe the results of each such test; (c) Identify each individual who partici pated therein and describe in detail the extent of his par ticipation; (d) Identify each document which reflects, refers or relates to any information set forth in answer to this interrogatory; (e) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. - ANSWER: Hercules incorporates herein its response to interrogatory sixteen. INTERROGATORY NO. 18: For each piece of equipment identified in answer to Interrogatory No. 9(c), describe what, if any tests were made to determine the safety of said equipment and: (a) State when each such test was made; (b) Describe the results of each such test; 13 (c) Identify each individual who partici pated therein and describe in detail the extent of his par ticipation; ' (d) Identify each document which reflects, refers or relates to any information set forth in answer to this interrogatory; (e) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory eleven. INTERROGATORY NO. 19: For each label, brochure, or other written material describing or relating to each product identified in answer to Interrogatory No. 1, pro duced by you or any person associated with you or any related company or association: . (a) Describe its contents; . distributed; (b) State when, how, and to whom it Was (c) State the manner in which it was placed on or in the product container, or whether it was separate from the product or container; (d) State whether any written, printed or graphic matter was present to warn of any harmful ingredient it might contain. If so, state: (i) Whether a signal word, i.e. "danger", "warning" or "caution" was present; (ii) Whether the signal word was printed in boldface, capita-! letters or different colored inks. Which? - (iii) The wording of the statements describing any hazard; (iv) The wording of all directions and/or instructions pertaining to any method of use to avoid any hazard. (e) Identify each individual who partici pated in the writing of the label, brochure or other written 14 materials; (f) ' Identify each document which reflects, refers or relates to the information contained'on'the labels, brochures, or other written materials and/or the decision to include such information; (g) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory one. INTERROGATORY NO. 20: For each product identified in answer to Interrogatory 1 state whether warnings of any harmful or potentially harmful effects of the product were . printed on the cartons or packing cases in which individual containers were packed and, if so: (a) State the printed warning's contents; (b) State when the warning was used; (c) Describe the manner in which it was placed on or in the product container; (d) Identify each individual who partici pated in writing of the label or brochure; (e) Identify each document which reflects, refers or relates to the information contained on the cartons or packing cases and the decision to include that information; - (f) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ' ANSWER: Hercules incorporates herein its response to interrogatory nineteen. INTERROGATORY NO. 21: For each label, brochure, or written material describing or relating to each process or method identified in answer to Interrogatory No. 9(b) produced by you or any person associated with' you or any related company or association; and for each such label, brochure or written material: . 15 (a) Describe its contents; tributed; (b) ' State when, how, and to whom it was dis (c) State whether any written, printed or graphic matter was present to warn of any harmful ingredient it might contain. If so, state: (i) Whether a signal word, i.e. "danger", "warning" or "caution" was present; (ii) Whether the signal word was printed in boldface, capital letters or different colored inks, and if so, which one; - (iii) The wording of the statements describing any hazard; (iv) The wording of all directions and/or instructions pertaining to any method of use to avoid any hazard. (d) Identify each individual who partici pated in the writing of the label, brochure or other written materials; (e) Identify each document which reflects, refers or relates to the information contained on the labels, brochures, or other written materials and/or the decision to include such information; (f) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory eleven. INTERROGATORY NO. 22: For each label, brochure, or other written material describing or relating to each process or method identified in answer to Interrogatory No. 9(b), produced by you or any person associated with you or any related company or association; and for each such label, brochure or written material: (a) Describe its contents; distributed; (b) State when, how, and to whom it was . 16 (c) State whether any written, printed or graphic matter was present to warn of any harmful ingredient it might contain. If so, state: (i) Whether a signal word, i.e. "danger", "warning" or "caution" was present; (ii) Whether the signal word was printed in boldface, capital letters or different colored inks, and if so, which one; (iii) The wording of the statements describing any hazard; (iv) The wording of all directions and/or instructions pertaining to any method of use to avoid any hazard.- (d) Identify each individual who partici pated in the writing of the label, brochure or other written materials; (e) Identify each document which reflects, refers or relates to the information contained on the labels, brochures, or other written materials and/or the decision to include such information; (f) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory eleven. INTERROGATORY NO. 23: With regard to the produc tion, distribution, and/or sale of each product identified in answer to Interrogatory 1 state whether you have ever been accused of violating any of the provisions of the Federal Labeling of Hazardous Substances Act, and, if so, state: - (a) The date of each indictment; complaint or information that accused you of such violation; instituted; (b) The court in which the proceedings were (c) The plea you entered; (d) The verdict and/or judgment in each such 17 case; case; (e.r The date set for trial ofany pending (f) Identify each document which reflects. refers or relates to information pertaining to such accusa tion; {g) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory ten. INTERROGATORY NO. 24: For each product identified in answer to Interrogatory 1, state whether you contend it is a "hazardous substance" as defined in 15 United States Code, Section 1261(f) and, if so, state with specificity and particularity the facts which you rely on to support that contention. ANSWER: Hercules incorporates herein its response to interrogatory one. INTERROGATORY NO. 25: With regard to each product identified in answer to Interrogatory 1 state whether any quantity of that product has ever been seized (sic) by any governmental agency; and if so: * x (a)- State the date of each such occurrence; (b) State the name or description of the violations of which you were accused; (c) State the court in which the action was filed; 18 (d) Describe the judgment that was rendered; (e) State the date that has been set for trial of any pending case; (f) Identify each document which reflects, refers or relates to information pertaining to such seizure; (g) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER; Hercules incorporates herein its response to interrogatory ten. INTERROGATORY NO. 26: State whether you have ever been the subject of any investigation or accusation by any Government Agency concerning the provisions of the Occupa tional Safety and Health Act of 1970 (P.L. 91-596, 29 U.S.C. 651 e sea.). If so state: (a) The date of such investigation, accusa tion, or other administrative or judicial procedure or action; ' (b) The administrative agency or Court in which any proceedings arising from such investigation or accusation were heard or instituted; (c) The determination and results of any such accusation or action; (d) The identity of each document which refers or relates to information set forth in answer to this interrogatory; ' 19 (e) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ' ANSWER: Hercules incorporates herein its general objections. INTERROGATORY NO. 27: State what action, if any, you have taken since 1935 to reduce or eliminate any risk of occupational disease or personal injury to those engaged in the manufacture of your asbestos products or to those using your asbestos products which arises from the inhalation of dust and fibers. ANSWER: Hercules incorporates herein its general objections. Hercules further objects to the portion of the interrogatory relating to the use of asbestos products on the basis that it is not relevant to any of the issues involved in this case and it is not calculated to lead to the discovery of any further relevant or admissible evidence. - INTERROGATORY NO. 28: Describe in full and com plete detail each of the activities which you have under taken with the intention of warning the public of the effects of any product identified in answer to Interrogatory 1 as to the health of the user or general public and give the inclusive dates of each such activity, and: (a) Identify each individual who partici pated therein and describe the nature of his participation; (b) Identify each document which reflects, refers or relates -to information pertaining to such warning; (c) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory nineteen. 20 INTERROGATORY NO. 29: Have you or any of your " companies conducted any studies concerning the effects of inhalation of asbestos dust or fibers by one using or being exposed to any of the asbestos materials manufactured by you and/or any of your companies? In answer to this question, please state: (a) The date and nature of your studies; (b) The name or names of the persons conducting the studies and their address; (c) The purpose of the studies; (d) The identity of each document which refers or relates to any information set forth in answer to this interrogatory; (e) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. '. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules states that as it understands the question the answer is no. INTERROGATORY NO. 30: Have you or any of your companies conducted any studies designed to minimize or eliminate the inhalation of asbestos dust and fibers by those exposed to the use of any of the products containing asbestos materials manufactured by you or any of your com panies? If so: (a) The date and nature of your studies; (b) The name or names of the persons con ducting such studies and their address; * (c) ` State what action, if any, was taken based upon such studies in an effort to minimize or elimi nate the effects of inhalation of asbestos dust or fibers upon those using or being exposed to the dust and fiber; contained in such products as manufactured by your company; (d) Identify each document which refers or relates to any information set forth in answer to this interrogatory; ' (e) As to any information received orally in 21 answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory twenty-seven. INTERROGATORY NO. 31: What technique, if any, did and/or do you use to make dust samplings in the manufactur ing and packaging production environment or at job sites where your materials are used? (a) Set forth in detail the technique used, when it was commences and when, if ever, it was concluded; ' samplings; (b) State the purpose for administering such (c) State the results of such samplings; (d) State what action, if any, has been taken in response to the findings as to thee dust samples; (e) Identify each document which refers or relates to such sampling; (f) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied; (g) Identify the living person who has the most knowledge of the matters discussed here in. ANSWER: Hercules incorporates herein its response to interrogatory twenty-seven. INTERROGATORY NO. 32: State what, if any, safety measures were taken by you as to your employees, during the processing, manufacturing and packaging of products contain ing asbestos including but not limited to products that have been distributed to the duPont Company. If any such safety measures were taken, state: (a) The reason for the use of such measures, equipment or clothing; (b) Identify each document relating to safety procedures taken by employees or plant personnel in the manufacture, processing and packaging of such products; 22 (c) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information. ANSWER: Hercules incorporates herein its responses to interrogatories nineteen and twenty-seven. INTERROGATORY NO. 33: State: (a) Knowledge as to any respirator or other breathing device which was on the market during the relevant period which would prevent the inhalation of asbestos dust and fibers; - (b) A detailed description of such respira tor or other breathing device, together with all information as to how such device prevents the inhalation of asbestos dust and fibers; (c) What tests, if any, were conducted, by whom and where, with regard to the effectiveness of any such device; (d) Identify each document in any defen dant's possession which refers or relates to the subject matter of this interrogatory; (e) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. . ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules further responds that information responsive to this interrogatory is contained in the documents previously produced to plaintiffs' counsel and the Hercules person who is believed to have the most information regarding respirators at that time is Emil Christofano. INTERROGATORY NO. 34: Have you or anyone on your behalf conducted or had conducted any investigation of the statistical and/or epidemiological relationship between the use of any product identified in answer to Interrogatory No. 23 1 and the contraction by humans or animals of cancer includ ing, but not limited to, mesothelioma. If so: * (a) Identify each person participating in such investigation; ducted; (b) State when the investigation was con- (c) Identify the person or persons who authorized the investigation; (d) Identify each document which refers or relates to any information set forth in answer to this interrogatory; - (e) As to any information supplied orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules further responds that to its knowledge, no such formal investigation was conducted. INTERROGATORY NO. 35: Have you or anyone on your behalf conducted or had conducted any investigation of the statistical and/or epidemiological relationship between the use of any product identified in answer to Interrogatory No. 1 and the contraction by humans of pulmonary asbestosis. If so: (a) Identify each person participating in such investigation; ducted; (b) State when the investigation was con- ' (c) Identify the person or persons who authorized the investigation; (d) Identify each document which refers or relates to any information set forth in answer to this interrogatory; (e) As to any information supplied orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the 24 information supplied. ANSWER: ' Hercules incorporates herein its response to interrogatory thirty-four. _ INTERROGATORY NO. 36: Describe in detail all written and oral reports including those reports originating from users of any of the products identified in answer to Interrogatory No. 1# including doctors, and employees and agents of the defendants concerning any relationship between the use of these products and the development of pulmonary asbestosis in humans or animals: (a) Identify all persons making said reports and to whom said reports were made; (b) State whether any report or series of reports initiated changes and/or reevaluation of the produc tion, sale or use, or recommendations for use, of any of those products; (c) Identify each document which refers or relates to any information set forth in answer to this interrogatory; (d) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules further responds that any such documents including medical and newspaper articles, OSHA regulations, insurance reports and doctors reports relating to the Haveg Plant, were previously produced to plaintiffs' counsel. INTERROGATORY NO. 37: Describe in detail all written and oral reports including those reports originating from users of any of the products identified in answer to Interrogatory No. 1, including doctors, employees and agents of the defendants concerning any relationship between the use of any of those products and the development of cancer including, but not limited to, mesothelioma in humans or animals: 25 (a) Identify all persons making said reports and to whom said reports were made; (b) State whether any report or series of reports initiated changes and/or reevaluation of the produc tion, sale or use, or recommendations for use, of any of those products; (c) Identify each document which refers or relates to any information set forth in answer to this interrogatory; (d) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. ANSWER; Hercules incorporates herein its response to interrogatory thirty-six. INTERROGATORY NO. 38: For each product identified in answer to Interrogatory No. 1, state whether the produc tion and/or sale of the product has been discontinued and, if so: (a) State when it was discontinued; (b) State with specificity and particularity all the reasons for the discontinuance; ' (c) Identify each individual who partici pated in the decision to discontinue production and/or sale; (d) Identify all documents which reflect, refer or relate to each such discontinuance; (e) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and.state the full substance of the information supplied. ' ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules responds that asbestos was no longer used at the Haveg Plant by the time of the sale to Ametek on October 8, 1980. INTERROGATORY NO. 39: For each product identified in answer to Interrogatory No. 1, state whether the produc 26 tion and/or sale of that product has been limited and/or curtailed or reduced and, if so: (a) Describe how it was so limited or cur tailed or reduced; reduced; (b) State when it was limited, curtailed or (c) State with specificity and particularity all of the reasons for the limitation, curtailment or reduc tion; (d) Identify each individual who partici pated in the decision to so limit, curtail or reduce produc tion and/or sale; (e) Identify each document which reflects, refers or relates to the limitation, curtailment or reduc tion and/or the decision to implement the limitation, cur tailment or reduction; (f) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory thirty-eight. INTERROGATORY NO. 40: Do you contend that each of the products identified in Interrogatory No. 1 do not or did not create any risk to one who applies or uses the product: (a) If so, state the factual basis for each such contention; (b) If not, state: (i) ^he degree and kind of risk which is created by such' use; (ii) The conditions under which such risk is created, increased or decreased; (iii) Identify each document which reflects, refers or relates to your answers to this interrogatory; . (iv) As to any information received orally in answer to this interrogatory, identify each person 27 who supplied such information and state the full substance of the information supplied. ANSWER; Hercules incorporates herein its general objections. Hercules further objects on the ground that the information sought by this interrogatory is not relevant to this action since there is no allegation that Mr. Derr used or applied any Haveg product. INTERROGATORY NO. 41; Do you contend that it was not your responsibility to warn workers of the risk of harm arising from the use of your product or of the danger of asbestos to -their health? response; (a) State the factual basis for such (b) Identify each document which reflects, refers or relates to your answers to this interrogatory; (c) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER; Hercules incorporates herein its general objections and further objects on the grounds that the information sought by this interrogatory is not relevant to this action since none of Hercules' products are the subject of this action and it is not claimed that Mr. Derr used any Haveg products. INTERROGATORY NO. 42; Do you contend that it was only the responsibility of the employing company involved, or others, to so warn the workers of the risk of harm aris ing from the use of your product or of the danger of asbestos to their health? (a) State the basis for such contention; sible; (b) Identify which others were so respon- 28 (c) Identify each document which reflects, refers or relates to your answer to this interrogatory; (d) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory forty-one. INTERROGATORY NO. 43: Do you contend that the danger to any plaintiff was not foreseeable at the time the products alleged to have caused his injuries were sold? If so, as to each plaintiff: tion; (a) State the factual basis for such conten- (b) Identify each document relied upon in support of such contention; (c) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules states that it was not reasonably foreseeable to Hercules at the times relevant to this suit that a child who was never in the Haveg Plant would be exposed to a dangerous level of asbestos fibers from the Haveg plant due to alleged neighborhood exposure. ' INTERROGATORY NO. 44: Do you contend that the danger from the use by plaintiffs of products containing asbestos was obvious? If so, as to each plaintiff: tion; (a) State the factual basis for such conten- (b) Identify all documents relied upon in support of such contention; 29 (c) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. . ANSWER: Hercules incorporates herein its general objections and further objects to this interrogatory on the ground that the information sought is not relevant since no party is presently claiming that Mr. Derr used any Hercules product or any product containing asbestos. INTERROGATORY NO. 45: Do you contend that plain tiffs knew,'understood and appreciated the danger arising from their contact with your products which contained asbestos? If so, as to each plaintiff: tion; (a) State the factual basis for such conten (b) Identify each document relied upon in support of such contention; (c) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory forty-four. INTERROGATORY NO. 46: Do you contend that plain tiffs voluntarily and unreasonably exposed themselves to the danger arising from their contact with your products containing asbestos? If so, as to each plaintiff: tion; (a) State the factual basis for such conten- (b) Identify each document relied upon in support of such contention; (c) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response 30 to interrogatory, forty-four. INTERROGATORY NO. 47; Do you contend that plain tiffs used any of your products in other than their usual, customary and expected manner? If so, as to each plaintiff: (a) State the name and chemical composition of the product claimed to have been used in other than its usual, customary and expected manner; (b) State in detail the manner in which plaintiffs used said product in other than its usual, cus tomary and expected manner; (c) Identify each document relied upon in support of such contention; " (d) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory forty-four. INTERROGATORY NO. 48: With regard to each product identified in answer to Interrogatory No. 1, state whether you have ever been named as a defendant in any other civil action, including Workmen's Compensation Actions, filing of Workmen's Compensation consent agreements, or other proceed ings, to recover damages for injuries resulting from pulmonary asbestosis received as a result of using that product and, if so, for each proceeding: plaintiff; (a) State the name and address of each defendant; (b) State the name and address of each co- (c)_ State the date it was filed; was filed; (d) State the name of the Court in which it (e) Describe the judgment rendered; (f) State the date that has been set for trial of any case still pending; ' (g) Describe the terms of any settlement 31 reached before or during trial; (hT State whether any appeal is pending from any judgment that has been rendered; ' (i) State the exact nature of the condition alleged in such action to have resulted from the plaintiffs' use of or contact with said product and identify the product involved; (j) Identify each document which reflects, refers or relates to any information pertaining to that com plaint . ANSWER: Hercules incorporates herein its general objections." Hercules also objects to this interrogatory on the grounds that it is irrelevant, overly broad, unduly oppressive and not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 49: With regard to each product identified in answer to Interrogatory No. 1, state whether you have ever received a notice of injury to any other person as a consequence of a condition of pulmonary asbestosis or cancer resulting from the use of. that product and, if so: - (a) State the date it was received; (b) State the name and address of the injured person; (c) Describe in detail the complaint; (d) Identify each document which reflects, refers or relates to any information pertaining to that com plaint ; (e) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory forty-eight. 32 INTERROGATORY NO. 50: With regard to each product identified in answer to Interrogatory No. 1, state whether you have ever been named as a defendant in any other action to recover damages for injuries resulting from cancer including, but not limited to, mesothelioma received as a result of using that product and, if so: plaintiff; (a) State the name and address of each defendant; (b) State the name and address of each co (c) State the date it was filed; was filed; " (d) State the name of the court in which it (e) Describe the judgment rendered; . (f) State the date that has been set for trial of any case still pending; (g) Describe the terms of any settlement reached before or during trial; (h) State whether any appeal is pending from any judgment that has been rendered. ANSWER: Hercules incorporates herein its response to interrogatory forty-eight. INTERROGATORY NO. 51: With respect to the period from 1950 through 1980, state the names, addresses and com pany title or position of each person who at any time during that period was in charge of the following activities with regard to each of the products identified in answer to Interrogatory No. 1: (a) Production; (b) Marketing; (c) Labeling; ` (d) Advertising; . (e) Product evaluation; (f) Research and development; 33 (g) Distribution. ANSWER;. * Hercules incorporates herein its general objections. ' INTERROGATORY NO. 52: Identify the parties or persons who know of all products containing asbestos sold and/or distributed by you from 1936 to present. Identify all documents which related to such sales and/or distribu tion. ANSWER: Hercules incorporates herein its general objections. INTERROGATORY NO. 53: Have you or has anyone on your behalf attended and/or participated in any conference, seminar, lecture or symposium dealing with the hazards of using any product identified in answer to Interrogatory 1 or of asbestos in general and, if so, state: (a) The date and place of such conference, seminar, lecture or symposium; (b) The person or persons conducting such conference, seminar, lecture or symposium; your behalf; (c) The person or persons who attended on (d) The subject matter of such conference, seminar, lecture or symposium; (e) The speakers and/or moderators at such conference, seminar, lecture or symposium; (f) Whether any reports or memoranda were made concerning the subject matter of such conference, seminar, lecture or symposium; identifying each such report or memorandum. ' ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules states that transcripts of the depositions of Dr. Flanders and Dr. Heckler contain information about the conferences and seminars they attended. 34 INTERROGATORY NO. 54: Are you familiar with the hearing concerning the dangers of asbestos conducted in March, 1967 before' the House of Representatives of the United States Congress Subcommittee on Labor? If so, identify those persons who are or were associated with you that were familiar with that hearing. ANSWER: No. . INTERROGATORY NO. 55: State when if at all, you received knowledge of the following publications or matters discussed therein, who received such knowledge and identify all documents relating to such knowledge: (a) Fleischer, Viles, Gade and Drinker, "A Health Survey of Pipe-Covering Operations in Construction (sic) Naval'Vessels," 28 J. Indus. Hyg. 9-16. (b) Selikoff, et al., "Asbestosis and Neoplasia," 42 Am. J. Med. (1967); (c) Selikoff, Churg and Hammond, "The Occur rence of Asbestosis Among Industrial Insulation Workers,: 132 Ann. New York Acad. SC. 139 (1965); (d) "Documentation of the Threshold Limit Values for Substances in Workroom Air," A.C.G.I.H. (3rd 1971); (e) "Threshold Limit Values for 1961," A.C.G.I.H. (1961). (f) 1906 report by Dr. Montague Murray. (g) 1934 study by Dr. Anthony J. Lanza, Ass. Med. Director, Metropolitan Life Insurance Co. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules *x. states that it has- no present knowledge of receiving publications (a)-(c) and (e). Hercules did receive a copy of (d) around the date of its publication. INTERROGATORY NO. 56: Identify each publication contained in your research library, or otherwise in your custody, including but not by way of limitation, your Research and Development Center, all medical journals, industrial medical journals, industrial hygiene journals. 35 technical literature in the area of asbestos raining, manu facture, application and use, and Governmental publications, dealing with occupational diseases arising from the manufac ture and use of asbestos-containing products. As to all such publications, state the volumes which are in your custody and control, when each such volume was received and the present location of such publications. ' ANSWER; Hercules incorporates herein its general objections. Without waiving those objections, Hercules incorporates herein the information contained in the attached Exhibit A. Hercules is unable to state when the publications identified in Exhibit A were received. INTERROGATORY NO. 57; As to any threshold limit values published by the American Conference of Governmental Industrial Hygienists, state whether you have brought such information to the attention of those using your products. If you have not done so, state the reasons why you have not done so. ANSWER: Hercules incorporates herein its response to interrogatory one. INTERROGATORY NO. 58: Have you been: (a) a mem ber of (b) affiliated in any manner with or (c) received reports or (d) subscribed for reports or publication to the Industrial Hygiene Foundation of Pittsburgh? ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules response is, no, except that it believes that reports or publications of the Industrial Hygiene Foundation may have been received from time to time. INTERROGATORY NO. 59: With regard to Interroga tory 58, what years did you participate under (a), (b), (c), or (d) ? ANSWER: Hercules incorporates herein its response to interrogatory fifty-eight. 36 INTERROGATORY NO. 60: With regard to Interroga tory 58, do you have any documents obtained from the Indus trial Hygiene Foundation? If so: (a) List all such documents; sion? (b) Who currently has them in their posses (c) When was each received? (d) State the name of the individuals who received such documents or information contained in such documents. ANSWER: Hercules does not currently have any such documents and has no further information about them. INTERROGATORY NO. 61: Have you received any reports or documents prepared by Metropolitan Life Insurance Company from 1929 to about 1960, concerning statistical and other studies of asbestos workers for Johns-Manvilie? If so, state: (a) The documents received; (b) Who received them and when; (c) The current location of the documents. ANSWER: No. INTERROGATORY NO. 62: State all chemical, indus trial, medical or trade associations to which you have belonged since 1936. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules states that information responsive to this interrogatory has been previously produced to plaintiffs' counsel. INTERROGATORY NO. 63: With regard to the associa tions enumerated in the answer to Interrogatory 62, state: (a) The names of each individual associated with the answering defendant since that date who have had dealings with each such association; 37 (b) Describe the nature of their dealings with each such association; (c) State their last known address; title. (d) If still employed,- their current job and ANSWER; Hercules incorporates herein its response to interrogatory sixty-two. INTERROGATORY NO. 64: Name each corporate officer and/or member of corporate management who attended any meet ing and/or conference concerning the health and medical aspects of asbestos and/or the use of products containing asbestos, and for each person identified, state the nature of his participating in each such meeting or conference. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules states that to the best of its present knowledge, no corporate officer or member of corporate management attended any such meetings during the relevant time frame. For the purpose of responding to this interrogatory, Hercules considers the terms corporate officers and corporate management as synonymous. INTERROGATORY NO. 65: State the sources of all products containing asbestos which have been incorporated in any product manufactured by you which have been distributed, sold and/or utilized from 1945 to 1970. (a) State the names of all individuals asso ciated with the above stated sources who dealt with or handled your account; (b) Identify any such document which refers, reflects or relates to any information provided in answer to this interrogatory; . * (c) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the information supplied. 38 ANSWERHercules incorporates herein its general objections. Without waiving those objections, Hercules states that it was not a purchaser of raw asbestos or asbestos material to be used in the manufacturing of any of Haveg products. Documents containing information regarding suppliers of raw asbestos to the Haveg Plant has been previously provided to plaintiffs' counsel. INTERROGATORY NO. 66: State the sources of all asbestos which has been incorporated in any product manufac tured by you which has been distributed, sold and/or utilized from 1940 through 1979. (a) State the names of all individuals asso ciated with the above stated source who dealt with or handled your account; (b) Identify any such document which refers, reflects or relates to any information provided in answer to this interrogatory; (c) As to any information received orally in answer to this interrogatory, identify each person who supplied such information and state the full substance of the information supplied. ANSWER: Hercules incorporates herein its response to interrogatory sixty-five. INTERROGATORY NO. 67: State the names of all individuals associated with you who had any dealings with the requisition and/or procurement of asbestos or products containing asbestos as indicated in answer to'interroga tories 65 and 66 and for each such person: (a) Identify the nature of his associa tion (s) and the dates of their occurrence; (b) Identify each document which refers, reflects or relates to any information provided in answer to this interrogatory; (c) As to any information received orally in answer to this interrogatory, identify each person who sup plied such information and state the full substance of the 39 information supplied. ANSWER: ' Hercules incorporates herein its response to interrogatory sixty-five. INTERROGATORY NO. 68: State the names of all individuals who dealt with or handled the account with and/or made any sales to the duPont Company of asbestos and/or products containing asbestos. (a) Describe in detail the nature and dates of each such association with the said accounts; (b) Identify each document which refers, reflects or relates to any information provided in answer to this interrogatory. ANSWER: Hercules incorporates herein its general objections and further objects to this interrogatory on the grounds that it seeks information which is not relevant to this action and it is not reasonably calculated to lead to the discovery of relevant or admissible evidence. INTERROGATORY NO. 69: Identify each individual whom you expect to call as an expert witness at the trial of this litigation, and for each person identified: (a) State the substance of the facts and opinions to which he or she is expected to testify and a summary of the grounds for each opinion; (b) Identify each document referring, relat ing or containing any such facts and/or opinions and identify each individual having custody of each document identified. ANSWER: - Hercules has not yet made a decision regarding the use of expert witnesses at trial. Hercules also incorporates herein its witnesses identified in its non-medical witness list filed on CLAD. INTERROGATORY NO. 70: Identify each individual who you have retained or employed or anticipate retaining or employing in any way in preparation of or anticipation of 40 trial in this litigation who is not expected to be called as a witness at trial, and for each such individual: (a) State the substance of any facts or opinion which he or she has discussed with any agent, em ployee, or representative of the answering defendant, together with a summary of the grounds for each opinion; (b) Identify each document referring to or containing such facts and/or opinions, and identify each person having custody of each document identified. ANSWER: Hercules objects to this interrogatory on the grounds that it seeks information which is not subject to discovery tinder the Superior Court Civil Rules. INTERROGATORY NO. 71: State the names, last known addresses and telephone numbers of each and every person who you intend to call as a witness at the trial of this litiga tion. (a) State the substance of any facts or opinion which he or she has discussed with any agent, em ployee or representative of the answering defendant, together with a summary of the grounds for each opinion; (b) Identify each document referring to or containing such facts and/or opinions, and identify each person having custody of each document identified. ANSWER: Hercules objects to this interrogatory on the grounds that it is premature and seeks information which is protected from discovery by the attomey/client privilege and work product doctrine. Trial witnesses will be disclosed in accordance with the schedule issued by the Court. INTERROGATORY NO. 72: State: (a) Whether your corporation is insured; (b) If so, the limits of coverage; (c) The name of the insurance company; 41 (d) Whether this claim has been accepted or whether a letter of intent to deny coverage has been received. ' ANSWER: Hercules objects' to this interrogatory on the grounds that this information has been previously made available to plaintiffs' counsel. INTERROGATORY NO. 73: In whose possession are your and your predecessors' annual reports from 1940 to the present? Produce such reports. ANSWER: Hercules incorporates herein its response to Interrogatory seventy-two. INTERROGATORY NO. 74: Describe in detail your policy with respect to the destruction of records pertaining to each of the products identified in answer to Interroga tory 1. (a) Identify all documents pertaining to your policy, if any, regarding the destruction of such records; (b) Identify the person or persons having custody of such policy documents; (c) Identify the person or persons in charge of destroying records pertaining to each such product; (d) Identify each document which refers, reflects or relates to any information provided in answer to this interrogatory. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules ' states that its reoords retention or destruction policy during the relevant time has been previously produced to plaintiffs' counsel. INTERROGATORY NO. 75: State the names of all individuals who aided in the preparation of these answers, and for each such person, state: (a) Which interrogatories they helped pre 42 pare or the particular subject area for which they supplied information; (b) Their current, position with the company; (c) Their current or last known home and business address and phone number. ANSWER: Responses to these interrogatories were prepared by the undersigned counsel with the assistance of Hercules legal staff based on available documents as well as records from prior Delaware asbestos litigation. ~ INTERROGATORY NO. 76: State all processes used by plaintiff's employer, where asbestos was an ingredient. ANSWER: None are currently known. INTERROGATORY NO. 77: State all uses of asbestos insulation by plaintiff's employer, known to any defendant. ` (a) Types of asbestos insulation used; (b) Manufacturer and/or brand names; (c) Locations in said plants where said insulation was used; (d) The person most knowledgeable in said corporation about the purchasing of insulation by distribu tors that covered the states of New Jersey, Delaware, Penn sylvania and Maryland. ANSWER: None are currently known. INTERROGATORY NO. 78: If you have insurance including secondary or tertiary coverage, state: (a)~ Policy number and amount; (b) Company underwriting said insurance; (c) The name of your contact in said company concerning asbestos claims. ANSWER: Hercules incorporates herein its response to interrogatory seventy-two. INTERROGATORY NO. 79: State whether you 1 entered into any agreement, either oral or written, other defendant irt this action regarding: (a) Settlement or non-settlement; an (b) Allocation of damages, should th tiffs prevail on liability. If the answer is yes to either of the above, state t stance of each such agreement and such parties who ht entered into this agreement: (a) Identify those persons who partic in the preparation of each such agreement and descrit detail the nature and extent of his participation; ar (b) Identify each document which cont refers or relates to each such agreement. ANSWER: This interrogatory is objected tc basis that it requests information not relevant to th issues in this matter. However, without waiving this objection, the answer is no. INTERROGATORY NO. 80: Do you or your attorr know of any person or persons not listed in the precec answers having knowledge of facts relevant to the allt tions in this lawsuit, including witnesses to the acci injury, illnesses, etc. in question? If yes, please the names, addresses, home telephone numbers, places c employment, relationship to you, the present whereabou all such persons, and which of said persons you intend produce as witnesses in the trial of this action. ANSWER: Hercules incorporates herein its re. to interrogatory seventy-orife. Without waiving those objections, Hercules states that it does not currently of specific potential witnesses outside of plaintiffs s their family members and doctors and former employees c Haveg Plant. 44 INTERROGATORY NO. 81: Do you or your attorneys have any written statements which you have not previously produced in this suit from any persons having knowledge of facts relevant to the subject matter of this lawsuit, including witnesses to the accident, injury, illnesses, etc. in question? If yes, please state the names, addresses, home telephone numbers, places of employment, relationship to you and the present whereabouts of all such persons. ANSWER; No. INTERROGATORY NO. 82: State whether you were a member of the Asbestos Information Association (A.I.A.) or in any manner received information or participated in any of the associations's activities. ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules . states that the answer is no. INTERROGATORY NO. 83: If your answer to any part of Interrogatory 82 is in the affirmative, please state: (a) The date, time and places of any A. I.A. meeting attended; (b) The date of time periods during which you received any publication of the A.I.A.; (c) The name, address and telephone number of each and every person who attended such meeting and to whom any such publications were sent; (d) The nature of the information that was furnished at meetings or in such publications; (e) Name, address and telephone number of the present or last known custodian of any copies of A.I.A. newsletters, correspondence'or publications. ANSWER: Hercules incorporates herein its response to interrogatory eighty-two. ' INTERROGATORY NO. 84: State whether you received . a publication known as the "Asbestos Magazine". ANSWER: Hercules incorporates herein its general objections. Without waiving those objections, Hercules states that the answer is no. INTERROGATORY NO. 8S: If your answe rogatory 84 is in the affirmative, please stat* (a) The date and time periods c you received such publication; (b) The frequency of receipt, e. larly, occasionally, rarely, etc.; (c) The terms, circumstances or or receipt of such publication, e.q.. free, by s distributed at meetings, etc.; (d) Name, address and telephone : the present or last known custodian of any copies magazine. ANSWER: Hercules incorporates herein i. to interrogatory eighty-four. INTERROGATORY NO. 86: Does the answerir. dant have in its possession any medical records, n viously produced in this case relating to any of t; plaintiffs, including, but not limited to, charts, physical examination reports, summaries, tape recox interviews and any and all other records pertaining medical condition of the plaintiffs? If so, plaint request that such records be produced in accordance Rule 34. ANSWER: No. INTERROGATORY NO. 87: With respect to eac tention in your response to the Complaint, state the ing: (a) Identify which defense it relate based; (b)- Each fact upon which your conten (c) The names and present or last kn addresses and present or last known employers of all having knowledge of any of the facts set out in answ subparagraph (b) hereof; (d) The description or designation o document which in any way reflects, relates or refer of the facts set out in answer to subparagraph (b) h FLAG D // FLAG H Ali vTJi: // ANSWER;- Not applicable. Hercules also 46 incorporates herein its responses to plaintiffs' interrogatories directed to defendants' affirmative defenses. INTERROGATORY NO. 88: Other than annual reports produced pursuant to No. 73 above, identify documents which accurately reflect the following information as to the answering defendant for each calendar year since 1940; (a) Total net worth; (b) Profits; (c) Total earnings; (d) Specific earnings attributed to the manufacture and/or distribution of any products containing asbestos. ANSWER; Hercules objects to this interrogatory on the grounds that it seeks information which is not relevant to this action and it is not reasonably calculated to lead to the discovery of relevant or admissible evidence. MORRIS, NICHOLS, ARSHT & TUNNELL April 25, 1997 Donald E. Reid 1201 N. Market Street P.O. Box 1347 Wilmington, DE 19899 (302) 658-9200 Attorneys for Hercules, Incorporated 17 AC'Uofc.* M Olirif-1 *"Li ode* FLf c; V DOCUMENTS 1 TO 51 PAGE = 1 OF G2000 108 DOCUMENT* 1 OF 51 CLASS = RP YEAR = 71 GENERAL YEAR=71 DOCNO* 108 DOCCODE=RP REFCODE* DAlACf REFERENCE EPA BACKGROUND INFO PRPSD STANDS (DEC 1971) TERMS * ASBESTOS / BERYLLIUM / MERCURY / STANDARD NATL EMISSION 02000 1482 DOCUMENT* 2 OF 51 CLASS * RP YEAR = 73 GENERAL YEAR=73 DOCNO* 1482 DOCCODE=RP REFCODE* DATaD REFERENCE NEW YORKER 16PP (1973) BROBEUR P TERMS * ASBESTOS / ASBESTOSIS WORKER // 02000 3508 DOCUMENT* 3 OF 51 CLASS * RP YEAR =70 GENERAL YEAR=70 DOCNO* 3508 DOCCODE=RP REFCODE* DAlACi REFERENCE ARCH ENVIR HEALTH 20, 481-2(1970) MT SINAI SCHOOL MED TERMS' CMC USE / VINYLPYRIDINE-N-OXIDE POLYMER USE / DRUG ANT ] I * CMC / ASBESTOS FIBER HEMOLYTIC / ANTAGONISM // 02000 3523 DOCUMENT* 4 OF 51 **STAIRS/VS UNDER IMS ** DOCUMENTS 1 TO 51 FACE * CLASS = RP YEAR = 68 GENERAL YEAR=68 DOCNQ= 3523 DOCCODE=RP REFCODE REFERENCE ANN OCCUR HYG 11, 1-6(1968) PHS, EDUARDS GH, LYNL TERMS * ASBESTOS DETN / AIR ANAL / ANAL PROC PHS // 02000 3B95 DOCUMENT5* 5 OF 51 CLASS = RP YEAR = 71 GENERAL YEAR=71 DOCNO= 3895 DOCCODE*RP REFCODE* REFERENCE IND HYGREV 13, 3-5<JAN 1971) NY DIV IND HYG, SHE TERMS ASBESTOS SPRAYING / HANDLING // 02000 3896 DOCUMENT55 6 OF 51 CLASS RP YEAR 55 68 . GENERAL YEAR=68 DOCNO= 3896 DOCCODE=RP REFCODE55 REFERENCE HMSO, FACTORY INSPECTORATE ASBESTOS REGS 1968, 4Pf- TERMS # ASBESTOS / REGS FACTORY INSPECTORATE / ENG // 2000 3906 DOCUMENT55 7 OF 51 CLASS 55 RP YEAR = 68 . ** STAIRS/VS UNDER IMS *# DOCUMENTS 1 TO 51 PAGE = 3 OF 17 GENERAL YEAR=68 DOCNO= 3906 DOCCODE=RP REFCODE* DAI ACODE = REFERENCE J OCCUR MED 10, 38-41<JAN 1963) PHS, CRALLEY LJ ET AL TERMS * ASBESTOS / HANDLING / RES REV // " 02000 3907 DOCUMENT* 8 OF 51 CLASS * RP YEAR = 68 GENERAL YEAR=68 DOCNO* 3907 DOCCODE=RP REFCODE* DAI ACODE* REFERENCE J OCCUR MED 10. 25-31(JAN 1968) UNIV CAL, BALZER JL TERMS * ASBESTOS USE / HANDLING / INSULATION // 02000 3908 DOCUMENT*- 9 OF 51 CLASS" * RP YEAR = 68 GENERAL YEAR=68 DOCNO* 3908 DOCCUDE=RP REFCODE* DATACUDE* REFERENCE MED TIMES 96, 1223-9(DEC 1969) NY DEPT LABOR, KLEINFELi* M TERMS * ASBESTOS / ASBESTQSIS / CA MAN // 02000 3909 DOCUMENT* 10 OF 51 CLASS * RP YEAR * 68 GENERAL YEAR=68 DOCNO* 3909 DOCCODE=RP REFCODE* DhTACOOF* REFERENCE J OCCUP MED 10, 21-4(JAN 1963) PHS, LYNCH JR. AYER HE ** STAIRS/VS UNDER IMS ** FI. AG= FLhG* Kl HU -- FLAG* DOCUMENTS 1 TO 51 PAGE = 4 OF 17 TERMS * ASBESTOS / TLV / TEST PROC // 02000 3910 DOCUMENT* 11 OF 51 .. CLASS = RP ' - YEAR = 68 GENERAL YEAR=68 DOCNO* 3910 DOCCODE=RP REFCODE* DATAi.'GDfe* REFERENCE J OCCUR MED 10, 32-7<JAN 1968) UNIV CAL, TABERSHAU IK TERMS * ASBESTOS / HANDLING / CA MAN // 02000 3911 DOCUMENT* 12 OF 51 CLASS * RP YEAR * 66 GENERAL YEAR=66 DOCNO* 3911 DOCCODE=RP REFCODE* DATaCODE* REFERENCE MED SER BULL NO 11, 16PP (1966) TERMS * ASBESTOS / HANDLING / RES IND REV // 02000 3912 DOCUMENT* 13 OF 51 CLASS = RP YEAR =05 GENERAL YEAR=05 - DOCNO* 3912 DOCCODE=RP REFCODE* DATACODE* REFERENCE INTL OCCUP SAFETY HEALTH INF CENTRE CIS BIBLIO NO 6. 39PP TERMS * ASBESTOS / HANDLING / ASBESTOSIS / CA MAN /LIT SURVEY // 02000 3913 DOCUMENT* 14 OF 51 ** STAIRS/VS UNDER IMS ** cc DOCUMENTS 1 TO 51 PAGE = 5 OF 17 CLASS = RP YEAR =69 GENERAL YEAR=69 DOCNO= 3913 DOCCODE=RP REFCODE= DATACt)I>E= REFERENCE OCCUP HEALTH NEUS + VIEUS <PA DEPT HEALTH) 7, 20JINTER 19e>v> TERMS * ASBESTOS / LABELING // 02000 3914 DOCUMENT= 15 OF 51 CLASS = RP YEAR = 68 GENERAL YEAR=6B DOCNO= 3914 DOCCODE=RP REFCODE= DaTaC<.iL>E= REFERENCE DIS CHEST 54, 17-19(JULY 1968)INST OCCUP HEALTH (FINLAND) TERMS * ASBESTOSIS ULTRASONIC EXAMN // 02000 3915 DOCUMENTS 16 OF 51 . CLASS = RP YEAR = 68' GENERAL YEAR=68 DOCNO= 3915 DOCCODE=RP REFCQDE= DAT Af:iil>(-.= REFERENCE NEW YORKER, 27PP(0CT 12, 1968>. BRODEUR P TERMS * ASBESTOS- / HANDLING / LIT SURVEY // 02000 3916 -DOCUMENTS 17 OF 51 CLASS = RP YEAR = 68 ** STAIRS/VS UNDER IMS ** FLAGS FL.aGs M..AG= . (C . DOCUMENTS 1 TO 51 GENERAL YEAR=68 DOCNO= 3916 Rage = 6 OF 17 DOCCODE=RP REFCODE DAI ACODE REFERENCE FCT 6, 565-6(1968) ROYAL CANCER HOSPITAL LONDON. ROE FJL TERMS ASBESTOS / ASBESTOSIS / CA MAN // 02000 3917 DOCUMENT= 18 OF 51 ... . CLASS.'.,.. = RP .............. YEAR = 68 GENERAL YEAR=68 D0CN0=3917 DOCCODE=RP REFCODE DAIAi';ui>h = M.REFERENCE FCT 6, 566-8(1968) ROYAL CANCER HOSPITAL LONDON, POL El TERMS * ASBESTOS / CA MICE // 02000 3918. DOCUMENT 19 OF 51 CLASS . RP . " YEAR . = 70 GENERAL YEAR=70 DOCNO 3918 DOCCODE=RP REFCODE da i Adn.h = REFERENCE FCT 8. 207-10(APR 1970) ANONYMOUS . TERMS * ASBESTOS / ASBESTOSIS / CA MAN // 02000 3919 DOCUMENT 20 OF 51 * CLASS RP YEAR 69 . GENERAL YEAR=69 DOCNO 3919 DOCCODE=RP REFCODE DATACODE REFERENCE FCT 7, 649(NOV 1969) ANONYMOUS ** STAIRS/VS UNDER IMS ** RhI,= H hi, H..hi,= KLAii c DOCUMENTS 1 TO 51 .PAGE = 7 UF 1/ >TERMS * ASBESTOS / HANDLING / REGS STATUTORY INSTRUMENT NO 6V O FNG / 02000 3920 DOCUMENT^ 21 OF 51 CLASS YEAR = RP - 68 , GENERAL YEAR=68 DOCNO= 3920 DOCCODE=RP REFCODF. DATACODh. REFERENCE FCT 6, 657-9(DEC 1968) ANONYMOUS TERMS * ASBESTOS / ASBESTOSIS / CA MAN // 02000 3922 DOCUMENT 22 OF 51 CLASS = RP YEAR = 67 GENERAL YEAR=67 DOCNO= 3922 DOCCODE=RP REFCQDE DAI ALODE REFERENCE ARCH ENVIR HEALTH 15, 177-80(1967) NY DIV IND HYG, KL EINFELD+ TERMS ASBESTOS / CA MAN // 02000 3923 DOCUMENT 23 OF 51. CLASS = RP YEAR = 65 GENERAL YEAR=65 DOCNO 3923 DOCCODE=RP REFCODE DAT ACODE REFERENCE ARCH ENVIR HEALTH 11, 221-9(AUG 1965) INTL UNION AGAl NST CA TERMS ASBESTOS / CA // 02000 3924 DOCUMENT **24 OF 51 * STAIRS/VS UNDER IMS Kl. AG FLAG FLAG= DOCUMENTS 1 TO 51 PAGE = 8 OF 17 CLASS = RP ` YEAR =66 " GENERAL YEAR=66 DOCNO= 3924 DOCCODE=RP REFCODE= DATACOI)E= FLAG= REFERENCE ARCH ENVIR HEALTH 13, 171-B4CAUG 1966) UNIV CINCINNATI! KEANF Ul+ TERMS ASBESTOS USE / GLASS FIBER USE / INSULATION / PIPE / LIT SURVEY // 02000 3925 DOCUMENT= 25 OF 51 CLASS = RP YEAR = 66 GENERAL YEAR=66 DOCNO= 3925 DOCCODE=RP REFCODE= DAT Af;(i.(E= FI.Ai;* REFERENCE ARCH ENVIR HEALTH 13, 619-21(NOV 1966) PA DEPT HEALlH, L1E0FN TERMS * ASBESTOS / ASBESTOSIS / CA MAN // 02000 3926 DOCUMENT 26 OF 51 CLASS = RP YEAR = 68 ` GENERAL YEAR=68 DOCNO= 3926 DOCCODE=RP REFCODF* DaTAPOUK H.AG- REFERENCE AM IND HYG ASSN J, 195-201(1968) INST OCCUP HEALT, NfiRO TERMS * ASBESTOS'/ ASBESTOSIS / FIN // 02000 3927 DOCUMENT= 27 OF 51 CLASS = RP YEAR =70 * STAIRS/VS UNDER IMS * c cv DOCUMENTS 1 TO 51 -PAGE = 9 OF 17 GENERAL YEAR=70 DOCNO 3927 DOCCODE=RP REFCODE F>AlAr:m>F= hi Mi.z REFERENCE AM IND HYG ASSN J, 598-604(SEPT-OCT 1970) HEW, LYNCH JK. *Fk TERMS # ASBESTOS / EXP, INDEX // 02000 3928 DOCUMENT 28 OF 51 CLASS . = RP . YEAR =69 ' GENERAL YEAR=69 D0CN0= 3928 DOCCODE=RP REFCODE DA I'AC(JDF= hi AG^ REFERENCE AM IND HYG ASSN J, 236-44(1969) NIH/NCI, STATON MF+ TERMS * ASBESTOS / CA RAT // 02000 3929 DOCUMENT 29 OF 51 CLASS = RP' YEAR = 66 GENERAL YEAR=66 DOCNO 3929 DOCCODE=RP REFCODE DATAOODE FLAG REFERENCE CHEM WEEK, P 32(SEPT 10, 1966) ANONYMOUS . TERMS * ASBESTOS / POLLUTION AIR / CA MAN- // 02000 3930 DOCUMENT 30 OF 51 CLASS = RP YEAR = 66 GENERAL YEAR=66 DOCNO 3930 DOCCODE=RP REFCODE DATACODF FLAG REFERENCE CHEM UEEK, 1 P(OCT 8, 1966) LETTER TO ED:JOHNS-MANVILLE, HACKNEY ***# STAIRS/VS UNDER IMS DOCUMENTS 1 TO FACE 10 OF 17 TERMS # ASBESTOS / POLLUTION AIR / CA MAN / CRITICISM // 02000 5763 DOCUMENT 31 OF 51 " CLASS = RP ' YEAR = 62 GENERAL YEAR=62 DOCNO 5763 DOCCODE=RP REFCODE=SM DATACODF REFERENCE CLIN F'HARM THERAP 3, 774-813(1962) HUEPER UC TERMS ' CHEM / ORGCOMPD / METAL / POLYMER/ CA / LIT SURVEY // FOOD ADD / FOOD COLORANT / CA /LIT SURVEY // CA LUNG / ENG / CONN / OHIO / LIT SURVEY // CA / WORKER / JOB / LIT SURVEY // * ASBESTOS / CHROMATE / CA / LIT SURVEY // 02000 6590 DOCUMENT 32 OF 51 CLASS = RP ' YEAR = 74 * GENERAL YEAR=74 DOCNO 6590 DOCCODE=RP REFCODE Ai REFERENCE BRIT J CANCER 29, 252-69(1974) LLANDOUGH HOSPITAI . uifTNtrK .:+ TERMS * ASBESTOS / ASBESTOSIS / CA / INHAL DUST A.C-RaT // 02000 6591 DOCUMENT 33 OF 51 CLASS = RP YEAR = 74 *# STAIRS/VS UNDER IMS ** FI *G Fi.Aft DOCUMENTS 1 TO 51 PAGE = 11 OF 17 GENERAL YEAR=74 DOCNO 6591 DOCCODE=RP REFCODE= DATaCODE= FLAG REFERENCE BRIT J IND MED,31, 1 05-1 2 (1 974 ) FIN CA REGISTRY, MEURnAN LU+ TERMS * ASBESTOS ANTHOPHYLLITE / MORTALITY WORKER MINE / CA LUNG ShiiK i.NG / FIN // . * ASBESTOS ANTHOPHYLLITE / ILLNESS WORKER MINE / CA LUNG SMf.l; i ni, / FIN // ASBESTOS ANTHOPHYLLITE / ASBESTOSIS / CA LUNG SMOKING / FIN // 02000 6592 DOCUMENT 34 OF 51 CLASS = RP YEAR = 75 GENERAL YEAR=75 D0CN0= 6592 DOCCODE=RP REFCODE DaTAOiij.h* H au= REFERENCE OCCUP SAFETY+HEALTH REPORTER 4, 865*1975) TERMS # ASBESTOS / REGS OSAHRC // 02000 6593 DOCUMENT 35 OF 51 * CLASS = RP YEAR = 75 GENERAL YEAR=75 ' DOCNO 6593 DOCCODE=RP REFCODE DA1AC0DE FLaG= REFERENCE FED REG 40, 47652-65(10-09-75) TERMS * ASBESTOS / REGS OSHA PRPSD // 02000 7042 DOCUMENT 36 OF 51 ** STAIRS/VS UNDER IMS ** DOCUMENTS 1 TO 51 ' PAGE = 12 OF 17 CLASS = RP YEAR =75 GENERAL' YEAR=75 DOCNO= 7042 DOCCODE=RP REFCODE- DATACODE* REFERENCE AIHAJ 36, 03-90 <FEB 1975) AIHA-ACGIH COMM TERMS ASBESTOS DETN / AIR ANAL / ANAL PROC AIHA-ACGIH // 02000 9040 DOCUMENT = 37 OF 51 ' ; ' ' '" ' CLASS = RP YEAR =76 ' GENERAL YEAR-76 DOCNO= 9040 DOCCODE-RP REFCODE= DATACODE= REFERENCE EXPERIENTIA 32, 602-4(1976)CASE WESTERN RESERVE, EPSTEIN SS+ TERMS ASBESTOS CHRYSOTILE / A OR:MONKEY / . PANCREAS DNA INCREASE 9-D POST DOSE // 02000 9364 DOCUMENT* 30 OF 51 ' CLASS = RP . YEAR = 75 GENERAL YEAR=75 DOCNO= 9364 DOCCODE=RP REFCODE= DATACODF* REFERENCE J PHARM SCI 64, 1435-49(SEPT 1975)FDA, HALEY TJ TERMS # ASBESTOS' / TOX / CA / LIT SURVEY // * ASBESTOSIS / TOX / CA / EPIDEMIOLOGY / LIT SURVEY // 02000 9461 DOCUMENT* **39 OF 51 STAIRS/VS UNDER IMS * FLAG* FLAG* FI A ' c; c DOCUMENTS 1 TO 51 PAGE = . 13 OF 17 CLASS = RP " YEAR - 72 , " GENERAL YEAR=72 DOCNO= 9461 DOCCODE=RP REFCC!DE= DATACOI)E= REFERENCE BRIT J EXP PATH 53, 190-201(1972.) CAMBRIDGE UNIV, DAVIS J I..hG= TERMS MINERAL / PLEURAL INJECTION:MICE<DUST) / FIBROSIS VS FIBER SITE // * ASBESTOS CHRYSOTILE / PLEURAL INJECTION: MICE( DUST)CONTRiu. / FIBROSIS // 0200010014 DOCUMENT= 40 OF 51 CLASS RP YEAR = 73 GENERAL YEAR=73 DOCNO=10G14 DOCCODE=RP REFCODE* DATaCUUK* I. AW= REFERENCE LANCET, 807-09(APR 14, 1973) IMP CANCER RES, MAROUDAS Nu tf Al. TERMS * ASBESTOS / MESOTHELIOMA RAT(FIBER LENGTH) / CA // 0200010253 DOCUMENTS 41 OF 51 CLASS s RP YEAR =71 GENERAL YEAR=71 - D0CN0=10253 DOCCODE=RP REFCODE= DAT ACOf>E= 'I ,AG= REFERENCE NATL ACAD SCI, 40PP (1971) . TERMS * ASBESTOS / EPIDEMIOLOGY / LIT SURVEY // .. 200010289 DOCUMENTS ** 42 OF 51 STAIRS/VS UNDER IMS #* DOCUMENTS 1 TO 51 PAGE = 14 OF 17 CLASS = RP - . YEAR =72 GENERAL YEAR=72 D0CNQ=10289 D0CCODE=RP REFCODE=SM DaIaCOOFs *REFERENCE NIOSH 1972 PH, CRITERIA FOR RECOMMENDED STD . . TERMS ASBESTOS MANUF / INHAL WORKER / REGS NIOSH / LIT SURVEY // 0200010773 DOCUMENT= 43 of 51 CLASS = RP YEAR = 60 GENERAL YEAR=60 D0CN0=10773 DOCCODE=RP REFCODE= DATaCOiF REFERENCE CANCER PROG 1960, 81-97(1960) BIDSTRUP PL TERMS * CHROMATE / NICKEL / ASBESTOS / CA WORKER / LIT SURVEY // 0200011064 DOCUMENT 44 OF 51 CLASS = RP YEAR = 71 GENERAL YEAR=71 D0CN0=11O64 DOCCODE=RP REFCQDE DATAt;ODF = REFERENCE ANN NY ACAD SCI 172, 757-72( 1 971 )MT SINAI SCHOOL MED . SCHrJ [ (,?.EF TERMS * ASBESTOS FIBER / DIVEMA / CMC / ANTAGONISM / HEMOLYSIS ] r< vi ih 0200011641 - DOCUMENTS 45 OF 51 CLASS = RP YEAR = 74 . ** STAIRS/VS UNDER IMS ** DOCUMENTS 1 TO 51 PAGE = 15 OF 17 GENERAL YEAR=74 D0CN0=11641 DOCCODE=RP REFCODE DATALOOE FaG= REFERENCE BRIT J IND MED 31, 105-12 (1974) TERMS ASBESTOS ANTHOPHYLLITE / HEALTH / MORTALITY / WORKER MINE / FJN // 0200013679 DOCUMENT 46 OF 51 CLASS = RP YEAR =73 ' GENERAL YEAR=73 D0CN0=13679 DOCCODE=RP REFEODE DATACUDE H au- REFERENCE FED REG 38, 27876-81(SEPT 28, 1973) TERMS * ASBESTOS / FOOD FILTRATION / DRUG FILTRATION / REUS h I>A kkkmj // 0200014294 DOCUMENT 47 OF 51 CLASS = RP YEAR = 78 GENERAL YEAR=78 D0CN0=14294 DOCCODE=RP REFCODE I>Al a/:ijDF = hi au- REFERENCE NIH 105P (MAY 1978) PH . TERMS * ASBESTOS / MONOGRAPH NIH / LIT SURVEY // 0200015330 DOCUMENT 48 OF 51 CLASS = RP YEAR = 79 GENERAL YEAR=79 D0CNO=1533O DOCCODE=RP REFCODE DATAOiiDF FI AG- **REFERENCE NIOSH 75P (APR 79)PH STAIRS/VS UNDER IMS ** . c DOCUMENTS 1 TO . 51 PACE = 16 OF 1? TERMS * ASBESTOS / FIBERGLASS / FIBER DEPOSITION PULMONARY,GT // MINERAL(GLASS)WOOL / FIBER DEPOSITION PULMONARY,GI // 0200015514 DOCUMENT= 49 OF 51 ' CLASS = RP YEAR =76 ` GENERAL YEAR=76 D0CN0=15514 DOCCODE=RP REFCOI)E= DATAt.;UDF= REFERENCE' NIOSH 96P (DEC 1976) PH REVISE CRITERIA DOC TERMS * ASBESTOS / REGS NIOSH REVISE / LIT SURVEY // 0200015714 DOCUMENT* 50 OF 51 CLASS = RP YEAR = 79 GENERAL YEAR=7? D0CN0=15714 DOCCODE=RP REFCODE* UATACODE= REFERENCE SCIENCE 204, 195-8 (APR 1979) EPA, COOK P + OLSON G TERMS * ASBESTOS / PERSORPTION INTESTINAL // 0200017379 DOCUMENT* 51 OF 51 CLASS = RP YEAR = 80 GENERAL YEAR=80 D0CN0=17379 DOCCQDE=RP REFCODE= DATACODE* REFERENCE NIOSH 106P (FEB 1980) PH TERMS * TALC / ASBESTOS / WORKER EXP / MORTALITY / EPIDEMIOLOGY // ** STAIRS/VS UNDER IHS ** FI .AG= FLAG* FLAG* DOCUMENTS' 1 TO 51 PACE = 17 OF R0601 * END OF DOCUMENTS'IN LIST - ENTER RETURN OR ANOTHER COMMAND # STAIRS/VS UNDER IMS * 61*5.61 L25 1 1 Asbesy** Leme T. Ricnkfu and Dement, John K., eris. lusts and disease. Park Forest South, 111. , Pathotox Pubs., 1979. 559p. illus., tables, diagrs. References. . k V~ -- f. Little vA.D.) Inc.. Asbestos. [ i*.*.1 ,.(,ir. n.) !'<*. Impact of proposedOOHA standard for nnbcst- os; ! st rrnort to the U.S. Dept, of Labor. Apr ?*, : 972. r.d. Issued as PB-283 478 _^21^3ia____ Asbestos. _____ 1455 IfonkhouRe, Allan. ; j Electrical insulating materials. 1926.. (Page 188.) .Vert.F,. , Asbestos. .. U.S. U.B. Standards bureau . - Stan- Building materials and structures .dards Report 122 Bureau Physical properties of some sampler of asbestos-cement siding. 1951. Asbestos. U53 (Jnitdd States. Standards Bureau, ppeclal Publication 506. Proceedings of workshop in asbestos: defir Ltior s and measurement methods; ... held at NBS jaitl ersburg, Md., July 18-20, 1977; ed. by C.C jrav; tt and others. ` Wash., Govt., 1978. U96p. illus., tables, charts, diagrs. . 850 Eer c; Asbestos with plastics and rubber N--., Chemical Pub. Co., 1055 *** Berger, Hans. vnrt.F. Air asbestos. Toxicit'*. u.s. National Institute of Occupational Safety Pollution a id Health/'Pub. no. 60-115. Occupational exposure to talc containing asbe >tos. 1980. . DKLV (NIOSH) 6.200 BER C Asbestos fundamentals Berger, Bans 1963. 6.200 Ber Asbestos fundamentals.. Origin, Pro pertles, mining, processing, uti lization. N.Y., Chemical Pub. Co, 1973. Berger, Hans. .. c c: 61U.83 P28 pc j.*****;st* Peters, George A. and Peters, .Barbara J. Sourcebook on asbestos diseases: nedlcal, legalL and engineering aspects.-. N.T., Garlaiv 1980L var. pgd. Bibliography. Beferences. Vrt.F. 3/>sVletnj *.a^arH; Pa-S,ro~' + Tnl. 1250. Asbestos M.s. (Occupational Safety and Health Administra tion. OSKA 3070. ' Div copy Asbestos Textile Institute Chrysotile asbestos test sanual. 3rd ed. Pillov Grove, PA, 1974 Tar ions paginos 5 20.00 Held by C J Caspbell Quebec Acbegtes ^ioiag Association ASPIiSTOS Vert.F. As bestos T-xtlle Institute. Textile s Handbook of asbestos textiles. ed, . 1957. 3rd. 1 1. * *