Document 63E5mOm33wb1j4zyyrv5x2rE

Hicks, et al. v. ACandS, Inc., et al. 6/1/01- Paul L. LeCour Page 86 Page 38' 1 2 3 4 5 6 7 8 9 10 II 12 13 14 15 16 17 18 19 20 21 22 23 24 25 semi-metallic on all oT its brake produets? A. Because actually all brake system] were not designed to run with semi-metallic. Q. You said in the beginning of this deposition ' or near the beginning of this deposition that Mr. Huff . was the person that had your job before you: is that correct? A. Uh-huh. Q. Have you ever read Mr. Huffs deposition that he gave on February 26th of 1988? A. No. Q. 1 want to ask.you about something that's stated in that deposition, whether you agree with it. On page 44 and 45 of the deposition, Mr. Huff indicates that Rayloc had procedures in its plants in the 1940s for taking precautions with respect to asbestos. Are you familiar with those precautions? . A. I can only speak from the point of view that when I came into the plant in '76, it was already in place, monitoring and industrial hygiene testing going on. I can't go back to the '40s. Q. As the corporate designee of Genuine Parts, are you familiar.with any precautions for containing or containerizing asbestos that go back-to the 1940s?' A. I'm not familiar with that. 1 you on page 47: What precautions were taken back in Ihe 2 '40s or, you.know, the'50s, when you firsl began the 3 Atlanta plant, with reference to grinding asbestos brake 4 linings?' 5 The answer Mr. Huff gave was: "Well, it 6 was accumulated on the early grinders. They were 7 hand-operaied grinders. We have automated over a period 8 . of time. The early grinders were hand-operated grinders 9 and had bags on them, very much like a vacuum cleaner. 10 And the material waj collected in those bags and then ' II transformed to a larger container." 12 Are you familiar with that process? 13 A. I'm familiar with that process. .14 Q. Do you have any knowledge of how far back that 15 process goes? 16 A. With Rayloc? ,17 .' Q. Correct. 18 A. No, 1 do not 19 Q. What is your understanding for that process. 20 the reason for that process? 21 A. The reason for it is you don't want dust all . 22 over the place. So these machines he's speaking of were 23 hand grinders. Arid they did have a vacuum unit attached 24 to'them, Just like a vacuum cleaner. And then you would 25 take (hat and transfer it over to a larger container. Page 87 Page 89 1 Q. Okay. Are you familiar one way or another 2 whether or not in the 1950s, as testified by Mr. HulT, 3 the company had concern about the dust that was 4 emanating from its grinding operations? 5 MR. RILEY: 1 object to the form of the 6 question. Do you have a specific quote that 7 you want to refer him to? 3 Q. (By Mr. Dumler) Here's the question: 9 Page 47: "So even back in the 19JOs, your 10 company was concerned with the dust that was II- . emanating from thebrake linings?'12 Answer "Oh, yes." 13 Do'you have any knowledge of that one way ' 14 or the other? 15 A. 1 can't speak for the '80s. 16 Q. You have no knowledge one way or the other 17 . whether in the 1950s the company was concerned about the 18 dust that was coming from the brake lining grinding 19 operations? 20 A. I do know that Genuine Parts' Company has 21 always been concerned about good housekeeping. 22 And it was. dust. What type of dust. 1 don't 23 know. But 1 do know they are very sticklers on 24 cleanliness. 25 . Q. On page 40 let me read the full quote to 1 2 3 4 5 6 7 "" 8 9 10 II 12 13 14 15 16 17 -18 19 20 21 22 23 24 25 But it was to prevent getting dust all over the place. Q. Are you familiar with the vacuuming procedures that the company put in place in the 1960s? ,. A., Yes. Q. Tell me about those. What procedures were put in place? A. ' These were central vac units that had big dust collectors. They were driven by like 25-horsepower motors. And they had vacuum suction areas wherever there was processing or asbestos. Q. Who was the person responsible for deciding that these vacuum procedures were going to be put in place? A. General manager. Q. Who was that at the time? . A. What.lime? Q. Well, when the procedures were first initiated, who was die person that did it? A. Oh, ( can't --I don't know that. Q. But ifs fair to say that the vacuum procedures were put in place because of a recognition that you did not want asbestos dust (hat wasn't taken out by a vacuum process? A. That wasn't taken out by a vacuum process'.' Q. Correct. WHEELER REPORTING COMPANY, fNC., 404.351-4577 23 (Pages S6 io S9)-