Document 82pEMmgDg5J9gkV72vVJjJRGo

FILE NAME: Union Carbide (UC) DATE: 1975 May 12 DOC#: UC100 DOCUMENT DESCRIPTION: Memo RE Roderman et al. v. Union Carbide et al. / s INTERNAL CORRESPONDENCE petals division : j ^Mame) civsion -jcation Mr. W. C. Thurber Metals Division 38th Floor - 270 Park Avenue New York, N. Y. 10017 Messrs. R. L. Folkman R. F. X. Fusaro F. H. Larrison J. L. Myers J. J. Welsh 4625 ROYAL AYE.. ? 0 5J:: 5'. Gate May 12, 1975 Oriqtnatinq Deo:. --Tz'JH.MOL L 'E " A n sw e rin q .m sr AJte SuOioc: Roderman et al.v.Union Carbide Corporation et al. Attached are answers to questions 5 and 8 , providing background information In the form of supplemental interrogatories. Question 8 Is specific for "trade" and "product" periodicals. Unfortunately I can only speak for this location and not for the Corporation. To list all journals pertinent to asbestos would be almost all published. Question 5 is ambiguous, and I answered it the best i could without knowing exactly what the question really was. In the answer to Question 5 I also included the answer to one of Fusaro's throwaways at the end of his letter, i.e. the mill went on stream in October 1963 and up to then we didn t have "products". . Jim Bright first examined asbestos claims in 1957, and we acquired our claims by the end of 1959. We began process development Work in'1959. Product development came later,, probably late 1959. The attached history should be of interest to the lawyers. I can't understand how we are involved in this- The incubation period, or whatever they call the time between exposure and cancerous disease, for meso thelioma Is 20 to LO years- Anyone conking out now couldn't relate to us because we didn't ship product until late 1963 or early 1964, and our lawyers should have a cakewalk with the time element. If you need my credentials for questions 1, 2 , and 3 let me know or .ust bring my biography In American Men of Science up to date. RJK:MM Attach. R. J. Klotzbach RECEIVED may 13 1975 UCC 004145 To: From: Date: W. C. Thurber R. J. Klotzbach May 12, 1975 Roderman et a l . v Union Carbide Corporation et al Question 5 The question specifically asks whether we have or have ever had a research and product control department". The answer is "no", specifically for the single department mentioned, and it is unlikely that any industrial organization has such a singularly-named department. We have a Technology Department, existing in its present form since U70, combining departments, most of which have been in continuous existence sin e 1955 at various locations. The oldest group, the metallurgical group,, has been in continuous existence since 1917- None of the combined departments handled asbestos "products" prior to October 1963 when the King City Mill went on stream, or handled ores prior to 1959- The Technology Department performs research, development, and engineering functions with the following functional groups: 1. Mineral Sc ience 2. Process Develop m ent 3. Product Development k. Process Engineeri ng 5. Project Eng ineerIng 6. Analytical Laboratory 7- Metal Properties Laboratory 8. Quali ty Assurance 9. Administration The present director of the department is Robert J. Klotzbach. The department provides business relevant mineral research, process and engineering devel opment, product development, preliminary engineering and estimates, design and process engineering, project and construction engineering, p ant technical assistance, technical sales assistance, new product uses, morphological an metallographic analyses and analytical services, and quality assurance for new and existing mineral deposits and manufactured chemical and me talurgical commodities won from these ores and related chemical and special metallurgical products. It supplies processes, facilities, products, technica se*'v,j'e ! capital forecasting and technical problem-solving to the Operating, Marketing, Exploration, and Mining departments. Quality assurance is the regulatory process through which we measure actual product quality performance, by comparing it with standards and acting on the difference. At this time it consists of a manager, acting alone, who coordi nates activities of seven people reporting at the plant and sa!*s !ve'; Quality assurance has been a continuous function since 195. Qua 1 > ance applies to all of our manufacturing and milling facilities. UCC 004146 To: From: Date: W. C. Thurber R. J. Klotzbach May 12, 1975 Roderman et a l . v. Union Carbide Corporation et al question 5 (continued) A function of the engineering group is to provide a safe working and design and construct process and plant facilities that equal Corporation and OSHA safety standards and exceed mining industry and comply with national, state, and local environmental quality env ironment, or exceed standards standards. A separate safety divisional department works outside the technical ment and relates primarily to in-house safety. depart UCC 004147 To: From: Date: W. C. Thurber R. J. Klotzbach May 12, 1975 Roderman et al. v Union Carbide Corporation etal Question 8 We have in the library at Niagara subscriptions to two trade association periodicals which we have received since 1967- ASBESTOS BULLETIN Bimonthly Science, Technology and based Materials Printed in-England . Applications , ., of Asbestos ASBESTOS Monthly Willow Grove, Pa. Hoaeeer, asbestos Is an Industrial mineral, ^ \ struction, water purification, etc., and constant construction in mining journals, chemical abstracts, t gj infinitum. We journals, oil and gas journals, sa n it ar y journals, etc., ad .nr.n ^ subscribe to a host of these journals, abstracts, lqiy'at all of done so continuously since the Corporation was formedv ? Ibrv located in our locations. In addition the Medical and Toxicology 1 brary locajad *n New York City contains discipline-related journals from 1930 through i s o Ue have beer eare of the hazardous potentials of^asJ" 1" the state of medical and toxicological know edge * * * " ? > and are also aware of the degree of uncertainty, even at u h in defining what constitutes a biological hazard. ^ nt t ,,,e , UCC 004148