Document 7OQO1kv8XJyZj2Oo5bk1eV56o

FILE NAME: Welding (WELD) DATE: 1995 DOC#: WELD020 DOCUMENT DESCRIPTION: Legal - Affidavit of Dr. John Dement ROBERT JACOBS * THOMAS C. CRUMPLAR + MARLA ROSOFF ESKIN 0 ELIZABETH B A R N E S LEWIS + V IN C E N T J .X . H ED R IC K, II * ALSO A D M IT T E D U. S. PATENT O FFIC E D ISTR IC T O F C O LU M B IA BAR + ALSO AD M ITTED NEW JE R SEY ALS O AD M ITTED P EN N SYLVAN IA BAR J a c o bs & C r u m p la r , P. A. ATTORNEYS AT LAW 2 EAST 7 T H STREET P. O. BO X 1271 WILMINGTON, DELAWARE 19899 (302) 6S6-54-45 April 7, 1997 FAX (302) 656-5675 Barry Castleman, Sc.D. 2412 Pickwick Road Baltimore, MD 21207-6631 Re: Welding Rod Defendants Dear Dr. Castleman: Pursuant to our telephone conversation of this morning, I am enclosing copies of Dr. Nicholson's and Dr. Dement's affidavits and deposition testimony regarding welding rod exposure, as well as Dr. Dement's study dated March 14, 1995 regarding welding rods If you have any questions please feel free to contact me VJH\pra Enclosure Vincent J. X. Hedrick, II AFFIDAVIT OF DR. JOHN DEMENT STATE OF NORTH CAROLINA SS, COUNTY OF DURHAM APPEARED BEFORE ME, a Notary Public for the state and county aforesaid, John Dement, Ph.D., wl^o being duly sworn on the I? "day of OcJr> t 1995, did depose and, based on his personal knowledge, state as follows: 'fHe has a Doctor of Philosophy degree in Industrial Hygiene and Epidemiology. He is certified in the comprehensive practice of industrial hygiene by the American Board of i I Industrial Hygiene. 2. He is currently employed by Duke University, Division of Occupational & Environmental Med .cine, where he is employed as an Associate Professor of Community & Family Medicine and is involved with epidemiologic and industrial hygiene research. 3. During the course of his academic career and professional training he has conducted, studied and evaluated air sampling studies performed at asbestos manufacturing plants and upon various asbestos products. In particular, he has studied the release of asbestos fibers during normal use and handling, and during application, removal and replacement of asbestos- i containing products. 4. The welding process does decompose the asbestos at the point of arc. However, this is not true for the flux coating below the arc area. According to the literature, unless the entire welding rod is consumed during the process, the flux on