Document B5vvrL6Z0jX0DekkJB9z9LV44

Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992 Page 1 to Page 160 ACE-FEDERAL REPORTERS, INC. 202-347-3700 CONDENSED TRANSCRIPT & CONCORDANCE PREPARED BY: ACE-FEDERAL REPORTERS, INC. 1120 G STREET, NW SUITE 500 WASHINGTON, DC 20005 Phone: 202-347-3700 FAX: 202-737-3638 WATER PCB-SD0000068037 BSA Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992 AMAAtU Page 1 [1] - SUBJECT TO PROTECTIVE ORDER [2] IN THE SUPERIOR COURT OF THE STATE OF DELAWARE [3] IN AND FOR NEW CASTLE COUNTY [4] ------------------------------ * [5] MONSANTO COMPANY, : [6] Plaintiff, : [7] -vs- : CA No. 8SC-JA-11S-1-CV [8] AETNA CASUALTY & SURETY : C-l-90492 [9] COMPANY, et al,, : [10] Defendants, : [U] -------------------------------x [12] DEPOSITION OF GEORGE J. LEVINSKAS [13] Tuesday, December 22, 1992 [14] Wilmington, Delaware [15] Deposition of GEORGE J. LEVINSKAS, called for [16] examination pursuant to agreement by counsel, at the [17] law offices of Elzufon, Austin & Drexler, 21st Floor, [18] 1201 Market Street, at 10:00 a.m., before CRAIG L. [19] KNOWLES, Court Reporter, when were present on behalf of [20] the respective parties: [21] - continued - [22] Page 2 [1] APPEARANCES: [2] PETER J. WALSH, JR., ESQ. [3] Potter, Anderson & Corroon [4] 350 Delaware Trust Building [5] Wilmington, Delaware 18999 [6] On behalf of the Plaintiff. [7] DAVID S. FLORIG, ESQ. [8] Manta and Welge [9] One Commerce Square, 37th Floor [10] 2005 Market Street [11] Philadelphia, Pennsylvania 19103 [12] On behalf of the Defendant Liberty Mutual [13] Insurance Company. [14] MARILYN M. SANDBECK, ESQ. [15] Wiley, Rein & Fielding [16] 1776 K Street, N.W. [17] Washington, D.C. 20006 [18] On behalf of the Defendant Travelers Indemnity [19] Co. [20] [21] [22] Page 3 [1] CONTENTS [2] WITNESS EXAMINATION [3] George J. Levinskas . [4] [5] by Mr. Florig 5 [6] [7] EXHIBITS [8] LEVINSKAS DEPOSITION NUMBER None. [9] [10] [11] AFTERNOON SESSION 77 [12] [13] [14] [15] [16] [17] [18] [19] [20] [21] [22] Page 4 [1] PROCEEDINGS: [2] Whereupon, [3] GEORGE J. LEVINSKAS, [4] a witness, was called for examination by counsel for [5] Defendants and, having been first duly sworn by the [6] Notarv Public, was examined and testified upon his oath [7] as follows: [8] EXAMINATION BY COUNSEL FOR DEFENDANTS [9] BY MR. FLORIG: [10] Q. Good morning. Dr. Lchnskas. My name is David [11] Florig. I represent Liberty Mutual Insurance Company [12] in a lawsuit that has beat brought against certain [13] insurance companies by Monsanto Company. I will be [14] asking you a series of questions today. If at any time [15] you don't understand my question or want me to rephrase [16] it, I will be happy to accommodate you, just let me [17] know that, okay? [18] A. I will. [19] Q. The second thing is I need all of your [20] responses to be verbal so that the court reporter can [21] take down your answer. Do you understand that? [22] A. Yes, I do. ______________________________________ Page 5 [1] Q. Will you state your full name for the record, [2] please? [3] A. ITs George J. Levinskas. [4] Q. What is your current address? [5] A. 526 Fairways Circle, Creve Coeur, Missouri, [6] 63141. [7] Q. Dr. Levinskas, are you taking any medications [8] today that would mtcrfcrc with your ability to answer [9] my questions? [10] A. No. [11] Q. Can you tell me whether you have ever been [12] deposed before? [13] A. Yes, I have. [14] Q. How many times? [15] A. Oh, perhaps a dozen. [16] Q. Did any of those relate to your employment [17] with Monsanto? [18] A. All but one were related to employment at [19] Monsanto. [20] Q. Do you recall the names of the cases that you [21] testified at? [22] _____ A. Not in particular. ' Page 6 [1] Let me modify. I have been deposed; I have [2] not testified in court, there is that distinction. [3] Q. What were the subjects involved in those [4] depositions? [5] A. Polychlorinated biphenyls, acrylonitrile, [6] styrene, and one I believe on benzoyl chlorides. [7] Q. Were you deposed in connection with the [8] toxicity of those materials? [9] A. Yes. [10] Q. Tell me, did you meet with Mr. Walsh prior to [11] this deposition? [12] A. Yes, I did. [13] Q. When was that? [14] A. Yesterday afternoon and briefly this morning. [15] Q. For how long did you meet? [16] A. About two or three hours yesterday, an hour [17] this morning. [18] Q. Did you review any documents? [19] A. He showed me one letter. [20] Q. Is Monsatito paybig your travel expenses for [21] this deposition? [22] _____A. I have been informed that my travel expenses Page 7 [1] will be reimbursed. [2] Q. Are you being compensated for your time? [3] A. That has not been discussed. [4] Q. Have you made that request? [5] A. I have not inquired. [6] Q. Do you intend to inquire? [7] A. I shall. [8] Q. Can you describe for me your educational [9] background, beginning with post high school? [10] A. I have a bachelor's degree in chemistry from [11] Wesleyan University in Middletown, Connecticut. I have ' [12] a doctorate in pharmacology from the University of ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 1 to Page 7 WATER PCB-SD0000068038 BSA_______________________________ Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992______ ______________XMAX(2) [13] Rochester. [14] Q is tk'<: a BS in chemistry7 [15] A. It's an AB degree. [16] Q. I wici did wit that degree? [17] A. 1949. ' [18] Q Your major was chemistry? [19] A. Yes. ' [20] Q. Was there a minor? [21] A. Mathematics. [22] Q. Do uou recall u-hat the curricuhun was for your Page 8 [1] chemistry major? [2] A. Basically the program led to certification by [3] the American Chemical Society; Inorganic chemistry, [4] organic chemistry, analytical chemistry including [5] advanced analytical, physical chemistry. [6] Q. That included a certain amount of laboratory [7] work? [8] A. Yes. [9] Q. Did any of the coursesyou took inconnection [10] with your undergraduate degree deal with disposal of [11] industrial wastes? [12] A. No. - [13] Q. Do yourecall ever domg anyreading cm that [14] subject? [15] A. Not at that time. [16] Q. Your Ph.D. hr pharmacology was in 1953? [17] A. Correct. [18] Q. Did tlrat involve a minor, as well? [19] A. Biochemistry. [20] Q. What was the curriculum for tire pharmacology [21] degree? [22] _____ A. There were three major areas. One was Page 9 [1] pharmacology, itself; one was physiology; and the other [2] was biochemistry. [3] And then there were variations, advanced [4] courses and some variations around those subjects. [5] Those are the three areas. [6] Q. There were a number of courses within each of [7] those disciplines, is that what you arc saying? [8] A. There were one to three courses in each of [9] those disciplines, and the rest of the time it was on [10] research. [11] Q. Can you tell me what pharmacology is? [12] A. Basically it's a study of the science of [13] drugs, their biological effects, and which would [14] include their therapeutic uses and their adverse [15] effects, which would include their toxicity. [16] Q. Can you tell me what physiology is? [17] A. Physiology is a more general description or [18] understanding of how the body works in the gross sense, [19] muscles, attachments to muscles, respiratory control as [20] distinct from the biological - biochemical [21] understanding of how those processes work. [22] _____Q. Is it fair to say it's a more mechanical study Page 10 [1] of the body? [2] A. It includes mechanics, but I think it would be [3] too narrow to say it's more mechanical, or implies only [4] mechanical. [5] Q. It doesn't deal with the functions of the [6] various organs? [7] A. It does in a general descriptive sense, but [8] not at the molecular level. [9] Q. Can you describe for me what biochemistry is? [10] A. Biochemistry would be the study of chemical [11] reactions or chemical processes that occur in [12] biological or living systems. [13] Q. How long was the Ph.D. program? [14] A. There was no specified time interval. The - [15] there was no specified time interval I recall. [16] Q. Did you go into that program directly out of [17] college? [18] A. Yes, I did. [19] Q. Was your intent to become a toxicologist? [20] A. I went to become a pharmacologist because 1 [21] was impressed with the department head, at that time [22] Dr. Hodge, whom I had met. And I decided that 1 would ; Page 11 | [1] study toxicology, whatever it entailed, in order to I [2] study under Dt. Hodge. ! [3] Q. Your interest in that field was fostered by i [4] this particular professor? [5] A. Yes, it was. [6] Q. Do vou recall the names of any of the texts P] tint you used in the Ph.D. program, or any of the [8] authors? [9] A. There was A Manual of Pharmacology by Sollman. [10] Q. Hotv do you spell that? [11] A. A Manual of Pharmacology by Sollman, [12] S-o-l-l-m-a-n. [13] There was another textbook on pharmacology, [14] the specific title I don't recall, but the authors were [15] Goodman and Gillman. [16] There was a book, I think the title was [17] Physiological Basis of Medical Practice, by Best and [18] Taylor. [19] I used a volume. Hawk's Physiological [20] Chemistry, 1 think was the title. And the editor was a [21] fellow named Oser, O-s-e-r, in biochemistry. [22] I seem to think there was another biochemistry Page 12 [1] text, but I can't recall a specific title, in addition [2] to which we were given specific references to published [3] articles in the literature that we consulted and used. [4] Q. During the Ph.D. program do you recall ever [5] studying or readmg about the disposal of industrial [6] wastes? [7] A. I don't recall if that was ever much of a [8] consideration. I don't recall any. [9] Q. Did you receive arty academic honors or awards [10] during your undergraduate studies? [11] A. I received a so-called Dunlap Prize for [12] excellence in German. [13] Q. Excellence in? [14] A. German. I was elected to the National Honor [15] Society. That's it. [16] Q. Those were in high school, correct? [17] A. High school, yes. [18] Q. How about in college? [19] A. I was elected a Phi Beta Kappa; I was elected [20] to the Society of the Sigma Xi, which is the honorary [21] scientific society. And I received the Graham Prize [22] for Excellence in Natural Science. Page 13 [1] Q. Did you serve any honors or awards during your [2] Ph.D. studies? [3] A. I was a pre doctoral fellow for the National [4] Research Council for most of my pre doctorate studies. [5] Q. What did that award entail? [6] A. Basically paid tuition and a stipend. [7] Q. Did you have any papers published while you [8] were working on your Ph.D.? [9] A. Not while I was working, but subsequently my [10] dissertation was published. [11] Q. What was your dissertation on? [12] A. Solubility Studies of Synthetic [13] Hydroxylapetite. [14] Q. What was tite last word? [15] A. A-p-e-t-i-t-e, all one word, hydroxylapetite. [16] Q. Not being scientifically trained, could you [17] explain that to me in the best layman's terms that you [18] can? [19] A. It's really a study of the chemistry of the [20] bone mineral. [21] Q. Okay.* 1 2 3 [22]_______ A. Such as you and I carry around. Page 14 [1] Q. Why is there an interest in solubility [2] studies? [3] A. Well, there were two basic reasons at that Page 7 to Page 14 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068039 BSA Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992__________________ A-\1AX(J) [4] time. One is that people felt as a mineral, bone [3] should have a so-called solubility coefficient, and [6] attempts to determine that over the years had been [7] fruitless. I showed that one of the major reasons for [8] the failure to show a solubility product is because the [9] surface of bone is quite active and interacts with [10] chemicals and the metals in the surrounding fluid that [11] bathes the bone. [12] Q. Prior to going to college you served in the [13] militant, correct? [14] A. That's right. [15] Q. Okay. [16] A. I left at the end of my first semester in my [17] freshman year, and I came back. I had started college [18] just before I entered the service. [19] Q- You received an honorable discharge? [20] A. Yes. [21] Q. Did you do any work tluit zoos related to [22] chanistry while in the Army? Page 15 [1] A. No. [2] Q. Did you do any work while you were in the [3] Ph.D. program? [4] A. It was, for practical purposes, a full-time [5] program, if I was not in class I was working on my [6] dissertation. [7] Q. Did you teach while you were in the Ph.D. [8] program? [9] A. Yes, I did. [10] Q. Yfhal did you teach? [11] A. Basic course in pharmacology. After I had [12] taken it, I assisted in the teaching of it. [13] Q. Was that to other graduate students or to [14] undergraduate students? [15] A. This was to medical students and graduate [16] students. [17] Q. Do you recall wlml text you used in teaching [18] pharmacology? [19] A. The two basic ones I referred to, Sollman. [20] Q. All right. [21] A. And Goodman and Gillman. [22] _____Q. Wlmt was your first job after receiving your Page 16 [1] Ph.D.7 [2] A. I took a teaching position at the Graduate [3] School of Public Health at the University of [4] Pittsburgh. [5] Q. What did you teach at the University of [6] Pittsburgh? [7] A. Basically a course in applied toxicology. [8] Q. What is applied toxicology? [9] A. That's the title that was given the course. [10] The way I taught it was how it would be used, [11] toxicology information could be developed and used by [12] students who would go out to call themselves health [13] professionals. [14] Q. Can you help me without with what specific [15] lands of things you taught in applied toxicology? [16] A. I am not sure, when you say "help you out," I [17] am not sure just exactly what you -- [18] Q. All right. Can you give me some more detail [19] as to what lands of things were taught in the applied [20] toxicology course? [21] A. I would have to dredge back quite a ways, but [22] I had, either myself or other individuals, a few 1 2 3 4 5 6 7 8 9 10 Page 17 [1] lecturers, we were - taught the general issues of [2] metabolism compounds, how they are reacted or how they [3] are treated by the body. We would talk about, at that [4] time at least, cancer, industrial inhalation hazards, [5] eye and skin irritants, the gamut of things that people [6] would encounter in industry or in using chemicals. [7] Q. Was the course geared toward people who were [8] going to be gomg out and working in industry as either [9] toxicologists or hygienists? [10] A. Predominantly it was industrial hygienists. [11] some toxicologists, included some physicians, nurses [12] who would be working in the areas of public health. [13] Q. The main thrust of the course teas how various [14] materials toould impact the human body? : [15] MR. WALSH; Objection, leading. [16] A. No, I don't - I think I indicated we tried to [17] discuss various chemicals, exposure, the effects that [18] could be attributed to them to people who would be [19] working in the areas of public health. [20] BY MR. FLORIG: [21] Q. Was the moot concern the effects that those [22] various chemicals would have on human benigs as opposed Page 18 [1] to aquatic life or animals? [2] A. At that time most if not all the emphasis was [3] on mammalian effects, yes. Mammalian effects only, I [4] should say. [5] Q. So a little broader than humans? [6] A. Well, our data are basically developed on [7] animals, we talk about mammalian systems. [8] Q. While you were teaching at the School of [9] Public Health, were you also conducting any research? [10] A. Yes. [11] Q. What kind of research were you conducting? [12] A. We had a fairly extensive program with the [13] armed forces on a high energy fuel that the military [14] was interested in. I had a small grant from the [15] National Institutes of Health to work on mechanisms of [16] toxicity. [17] Others in the department that I assisted had [18] contracts with the Atomic Energy Commission, with other [19] agencies. And I also was involved in the research [20] programs of several students. [21] Q. You mentioned that you were doing some [22] research for the armed forces? Page 19 [1] A. Yes. [2] Q. What specifically did that research entail? [3] A. The high energy fuels were derivatives of a [4] class of compounds, compounds called brown hydrides, [5] which were probably, still are perhaps among the most [6] toxic chemicals that it was proposed to manufacture on [7] a large scale. [8] So we were attempting to determine what the [9] effects are, to alert the physicians attending the [10] people working on these materials to give them some [11] idea what they might anticipate in the event of [12] accidental exposures. [13] Q. The toxicity of those fuels was already [14] understood at that time? [15] A. No, that was the, some things were known about [16] them, but our efforts were known to expand and extend [17] the amount of knowledge regarding those subjects. [18] Q. lit addition to conducting toxicology research, [19] were you also conducting pharmacology research on those [20] fuels? [21] A. We did not make a distinction between the [22] pharmacology and toxicology at that time. I'd say both Page 20 [1] were being considered. [2] Q. At that time you were also dobtg some research [3] for the National Institutes of Health, is that correct? [4] A. I had a grant that allowed me to pursue my own [5] research interests. [61 Q. What were your research interests at that [7] time? [8] A. We were trying to develop an understanding of [9] mechanisms of toxicity that could be applied broadly to [10] many chemicals, not specific ones. [11] Q. Do you recall any of the chemicals that you [12] worked on? [13] A. The one that we spent most of the time on was [14] chloroform. [15] Q. What did you learn about the toxicity of [16] chloroform during that period? [17] A. Regrettably, not much. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 14 to Page 20 WATER PCB-SD0000068040 BSA Depo of: GEORGE J. LEVTNSKAS Monsanto v Aetna December 22, 1992 AMAA(4) [18] Q. You taught at Graduate School of Public Health [19] until 195S? " [20] A. ThaFs correct. [21] Q. Can you define for me what is meant by the [221 uvni "toxic"?_________________________________________________ Page 21 [1] A. I can give you a definition that I use, I am [2] not sure that it's a universal definition or that [3] everybody would define it the same way. M Q. Okay, can l hear your definition? [5] A. Well, toxic is something that would be [6] adverse. [7] Q. Adverse to what? [8] A. Just in general, adverse. The same way, as [9] opposed to, say, beneficial. [10] Q. Would something Itave to be adverse to humans [U] to be considered toxic? [12] A. No, to me toxic is merely a descriptive word [13] which has the opposite connotation of beneficial. [14] Q. Wouldn't you agree that it would have to be [15] adverse to something? [16] A. Yes. [17] Q. Something living? [18] A. It would have to be demonstrable that it was [19] adverse. [20] Q. It would have to be adverse to something that [21] was living? [221 _____ A. It could include that.____________________________ Page 22 [1] Q. Could it indude being adverse to something [2] that was non-living? [3] A. If I hit this table top with a sledgehammer W and broke the glass, I could call that a toxic [5] reaction. [6] Q. Under your definition of toxic would you [7] consider that to be a toxic reaction? [8] A. As I say, to me toxic is a descriptive word [9] which is the opposite of beneficial. And it has to be [10] connected to something. [11] Q. Right. But as you used the word "toxic" you [12] wouldn't describe breaking the glass on this table as a [13] toxic effect, would you? [14] A. Not necessarily, no. [15] Q. Not at all, would you? [16] A. I might facetiously. [17] Q. Would the study of toxicology include [18] considerations of breaking glass? [19] A. It could. [20] Q. Is that something you have ever worked on in [21] your career? [221 _____ A. I have had glass equipment that I was working Page 23 [1] with shatter. [2] Q. Did you consider that to be a toxic effect to [3] the glass? M A. If I got cut by a piece of glass, I would [5] consider that a toxic effect. [6] Q. Could you describe for me what "toxicology" [7] is? [8] A. I would say toxicology is the study, and let [9] me go back, this is a difficulty with the term [10] "toxicology." Toxicology is a study of the effects of [11] chemicals on living systems or organisms. [12] Q. Does that include any living systems or [13] organisms, or is it limited to animal life? [14] A. In my definition it would include all forms of [15] living material. [16] Q. Are there other accepted definitions of [17] "toxic" other than the one you gave me? [18] A. I am sure that if one looked in dictionaries [19] and textbooks one would find variations and many other [20] descriptions probably. [21] Q. Are you familiar with what any of those other [22] variations or descriptions are?_________________________________ Page 24 [1] A. I don't recall that I have ever looked for the [2] definition of toxic, per se, in a textbook, i don't [3] recall dictionary definitions. [4] Q. Have you ever seen through your rcaiiwg or [5] attendance at professional meetings a defbiition of [6] "toxic" different than the one that you gave me*7 81 2 3 4 5 6 [7] A. I probably have, but I don't recall. [8] Q. The only definition of "toxic" that you recall [9] today is something that woidd be adverse? [10] A. I indicated that that was my definition of [11] "toxic" and that others may or may not agree with it. [12] Q. But you don't recall any other definitions [13] that you have heard or luwc heard used within the [14] profession? [15] MR. WALSH; Asked and answered. [16] A. Like I say, I may have. I don't recall [17] specific instances. [18] BY MR. FLORIG: [19] Q. Have you ever heard or read a different [20] definition of "toxicology" than zuhat you gave me? [21] A. Oh, I think originally the definition of [22] "toxicology" came up as sort of a side issue of__________ Page 25 [1] pharmacology. If you overdose with a beneficial [2] therapeutic drug, you will get toxic effects. And I [3] think that the connotation of toxicology, at least [4] originally, was the study of those adverse over effects [5] of drugs. [6] Q. All right. [7] A. But the definition that I offered is that it [8] is perhaps a mislabel to call it "toxic," if that [9] term - but it's a study of the biological effects of a [10] chemical on a living organism. They may be beneficial, [11] they may be deleterious. But the practice has moved [12] away from the initial concept or definition of the [13] term. [14] Q. After leaving the Graduate School of Public [15] Health, what was your next job? [16] A. I went to work for the American Cyanamid [17] Company. [18] Q. Where were they located? [19] A. At that time the laboratory that I went to was [20] in Stanford, Connecticut. [21] Q. Did the laboratory stay there during your [22] career at American Cyanamid?_______________________________ Page 26 [1] A. About three years later it was moved to [2] Princeton, New Jersey. [3] Q. Around 1961? [4] A. Summer of '61, as I recall. [5] Q. What was your first position at American [6] Cyanamid? [7] A. I think the specific title was research [8] pharmacologist. [9] Q. What were your duties as a research [10] pharmacologist? [11] A. It was to inform myself about the operation [12] adequately to be able to take control and direction of [13] the laboratory. [14] Q. Would it be fair to describe that as an [15] indoctrination period? [16] A. Yes. [17] Q. All right. And how long did that [18] indoctrination period last? [19] A. About six months. [20] Q. Can you describe for me in detail what you did [21] during that indoctrination period? [22]_______ A. Familiarized myself with the people, the_______ Page 27 [1] operations and studies under way. Reviewed their data [2] collections, report writing procedures, began drafting [3] reports and formats for reports. [4] Q. Do you recall what kind of projects were being [5] worked on during that indoctrination period at American [6] Cyanamid? [7] A. Most of them probably were agricultural [8] chemicals. There were, since it's a broad based Page 20 to Page 27 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068041 BSA Pepo of: GEORGE J. LEVTNSKAS Monsanto v Aetna December 22, 1992 XMAX(5) [9] chemical company, there were a variety of other [10] products as well. [11] Q. Do vou read! what any of the chemicals were [12] that tecrc being worked on during that period? [13] A. Well, as I have indicated they were pesticide [14] products, probably some polymers and some dyes. [15] Specific names, I don't think I could give you more [16] than one or two. [17] Q. Do you recall the names of any of the [IS] pcsticiilcs? [19] A. One at that time wasCyprex. [20] Q. Is that a trade name? [21] A. That is a trade name. [22] _____ Q. Do you recall what the components of Cyprex Page 28 [1] were? [2] A. It was dodecylgunaidin acetate. [3] Q. Were there others? [4] A. There were some wet strength resins for paper. [5] I could only give you a generic term like Accostrength [6] 2386 was one of them. I would have to stop and think [7] and recollect to go back to specific names. [8] Q. Was the lab working on toxicity tests on [9] Cyprex at that time? [10] A. They had just completed a long-term study [11] about that time. One of my early duties was to write [12] the report on that study, yes. [13] Q. Do you recall what the conclusion was of that [14] study? [15] A. Basically, the nature of the chemicals, it's [16] rather severe eye irritant, that would have been known. [17] The study was known to show the - show whether or not [18] it was a carcinogen, it was free of cardnogenistic [19] effects, and it was submitted to the EPA to support the [20] registration of the product. [21] Q. When something is found to be an eye irritant [22] _ docs that mean that tlw substance is considered to be Page 29 [1] toxic? [2] A. I would make a distinction between toxicity [3] and irritant effects. [4] Q. What distinction would you make? [5] A. Toxic is a connotation of, unfortunately to [6] many people it's something serious or it's almost like [7] fatal. I do not regard minor skin lacerations, even [8] fairly severe skin lacerations or bums as being in [9] that sense toxic as people equate with - as I perceive [10] the lay population to interpret the term "toxic." [11] Q. // toxic is something that would be adverse [12] and the material caused a skin irritation, wouldn't [13] that mean the material is toxic under your definition? [14] A. Yes. I would make a distinction, as I say, [15] between toxicity and irritation. [16] Q. In toxicity reports if something is known to [17] be an eye irritant, tlwl is listed in the report, [18] correct? [19] A. Yes, we describe exactly what we find. [20] Q. That would be a toxic effect of the Cyprex? [21] MR. WALSH: Are you referring to his work at [22] American Cyanamid? Page 30 [1] MR. FLORIG: Yes. [2] MR. WALSH: Or in general? I am sorry? [3] MR. FLORIG: Let"s deal with American Cyanamid [4] right now. [5] A. When I arrived at Cyanamid, Cyprex was labeled [6] as an eye irritant. That label had been approved by [7] the Environmental Protection Agency. The studies that [8] I referred to that were finishing up when I came there [9] were long-term studies aimed at determining whether it [10] was an animal carcinogen, and those are the studies I [11] worked on. [12] BY MR. FLORIG: [13] Q. AH right. So at the lime you arrived at [14] American Cyanamid, Cyprex was known to have some toxic [15] properties? [16] A. Yes. [17] Q. You were ;cork:"g to determine if there tecrc [18] additional toxic properties? [19] A. They had done the work, basically completed [20] the work to determine if there were additional toxicity j [21] properties. [22]Q. And you were reviewing - Page 31 [1] A. I was reviewing that and preparing reports on [2] it. [3] Q. The conclusion ivas that it was not [4] carcinogenic, correct? [5] A. That is correct. [6] Q. You mentioned that during the indoctrination [7] period at American Cyanamid you were working with some [8] polymers? [9] A. Yes. [10] Q. Do you recall what thosepolymers were? [11] A. They were basically wet strength resins for [12] paper. [13] Q. What arc wet strength resins for paper? [14] A. They are coatings that interact with paper to [15] give it some tensile strength when the paper gets wet. [16] Q. Do you recall the names of any of those [17] rcsbis? [18] A. As I say the one that comes readily to mind [19] was Accostrength 2386. [20] Q. What conclusions were reached about 2386? [21] A. As I recall, the one thing I do recall, they [22] did produce some liver injury. They were not Page 32 [1] carcinogenic. And that the feeding levels to the [2] animals were really very high, is about all I recall at [3] this time. [4] Q. Was this, again, a project that you didn't [5] actively work on but reviewed what had been done before [6] you got there? [7] A. Correct. [8] Q. So 2386 wasfound to have toxic properties to [9] it? [10] A. Yes. [11] Q. Do you recall any other polymers that you [12] worked on during that period? [13] A. There were other names under the Accostrength, [14] which is a trade name. There were trade names such as [15] Superflox. I don't recall specifics. [16] Q. You mentionedthat during this indoctrination [17] period you worked on data collections, correct? [18] A. The comment I made about data collection was [19] looking at the procedures, how they were collecting the [20] data from the studies that were ongoing. [21] Q. During the indoctrination period did you do [22] any literature searches or direct any literature Page 33 [1] searches? [2] A. I have made an attempt to keep abreast of the [3] literature regularly, and I can't recall specific [4] searches or specific topics that I would have done at [5] that time. [6] Q. At that time when you first went to work for [7] American Cyanamid were literature searches part of the [8] standard procedure in evalmtbig the toxicity of a [9] material? [10] A. I am not aware of what would be considered [11] standard procedure, I can only address what I would do. [12] Q. You mentioned that you reviewed some data [13] collections and report writing procedures and became [14] familiar with the operations that were going on at the [15] American Cyanamid lab, correct? [16] A. Yes. [17] Q. Did those procedures involve literature [18] searches involving chemicals that American Cyanamid was [19] working on in that lab? [20] A. I did not make searches of the literature for [21] the chemicals that were being worked on. I am not [22] aware of whether others did or did not. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 27 to Page 33 WATER PCB-SD0000068042 BSA JD^j5_of|_GEOR(IEJ1_LEVINSKASJv(onsanto_v_Aetna_Dei^embe^22^1992^ XMAX(6) Page 34 [1] Q You don't recall rcviewvig those in 12] reparaiu.m for writdig reports? [3] A. No. " [4] Q. Do most reports on toxicity of materials being [5] evaluated include a section of references or literature [6] searches? [7] A. Again, I don't think I can speak to most [8] reports. I don't know what would be the most practice. [9] Q. Do you recall if there were such sections on [10] the retorts on Cyprex and 2386? [11] A. It was our practice to limit the report to a [12] description of what the study was. There might be a [13] brief statement, a sentence, as to why the study was [14] undertaken. [15] But basically it was a description of what was [16] done, how it was done, what the findings were and the [17] conclusions which were drawn from the findings. That [18] was the extent of the report. [19] Q. All right. Again, I am talking about this [20] 1958 period, prior to beginning tests on a particular [21] chemical, do you know if American Cyanamid did a [22] literature search about that particular material? Page 35 [1] A. I do not know that. [2] Q. Would you expect that they would have? [3] MR. WALSH: Objection, calls for speculation. [4] You can respond. [5] A. I guess my answer would be they might or might [6] not have, it would depend. [7] BY MR. FLORIG: [8] Q. What tvould it depend on? [9] A. The person who was initiating the study, [10] whatever his feeling was. [11] Q. As a matter of good toxicological practice in [12] 1958, wouldn't it be reasonable to do a literature [13] search prior to beginning any new research cm the [14] material? [15] A. In the case of Cyanamid specifically these [16] were generally proprietary products that the company [17] made and probably relatively few if any other people [18] were making, so that the probability of anything being [19] in the literature would be practically zero. [20] And I don't know about others, but I - that [21] was the situation largely at Monsanto - or at Cyanamid [22] at that time. Page 36 [1] Q. Wouldn't you have wanted to know any dangers [2] or hazards associated with the components of those [3] products before handling them and doing research on [4] them ? [5] A. Most of these are single entities, they are [6] not components. [7] Q. If there were components that were not [8] proprietary, wouldn't you xoant to knoto what safety or [9] hazard information was out there about those components [10] before working on them in the lab? [11] A. I would want to know what the components were. [12] I might then want or might not want to look at [13] individual components. [14] But, yes, I would want to know what the safety [15] precautions others had recommended to avoid needless [16] exposure of myself or my co-workers. [17] Q. That would include any prior toxicity [18] information that teas available, correct? [19] A. Yes. [20] Q. That was really a matter in 1958of good [21] safety and housekeeping practice, correct?* 1 2 3 4 5 6 [22]_______MR. WALSH: Object to the form. Leading. Page 37 [1] Lack of foundation. [2] MR. FLORIG: You can have a standing leading [3] objection, if you like. [4] MR. WALSH: Thank you. [5] A. In 1958 there were relatively few journals [6] describing industrial chemicals and their toxicity. [7] And there were a few fairly good textbooks that one [8] could feel quite confident from checking the textbook [9] that one was up to date. And the literature searches [10] in the concept of computers were not existent. j [11] BY MR. FLORIG: 1 [12] Q. So at least it would be good practice to go to [13] the journals or textbooks or the literature tlmt was [14] available in 1358 to determine safety and housekeeping i [15] and toxicity deformation? [16] A. Let me back up. I guess we have a semantic [17] question. [18] Q. Okay. [19] A. When you say "literature," to me that connotes [20] the research journals and the publications. And I do [21] not think that those at that time contained information [22] on most of these materials that we are talking about. Page 38 [1] Q. All right. [2] A. There were some textbooks or reference books [3] that one kept almost as bibles by the bedside. Yes, [4] those would have been checked. [5] Q. All right. [6] A. But I do not refer to those, at least in my [7] concept of semantics, as the literature. [8] Q. Tlumk you, that is helpful. So you would [9] consult the journals and the textbooks and the [10] literature, if any was amilabk, about the safety and [11] hazards and toxicity of the materials being worked [12] with? [13] A. If the textbooks would carry concise summaries [14] of what was available, if it was deemed pertinent, one [15] could then go to a specific source dted from that [16] textbook and look at it. [17] Q. All right. [18] A. But to systematically search all the journals, [19] no, I did not do that; and I don't think very many [20] people did. [21] Q. Do you recall what the names of any of the [22] journals or textbooks were that were used back in 1958? Page 39 [1] A. I really have difficulty recalling them, [2] because some of these journals have changed names, and [3] I am not sure which -- [4] There was American Industrial Hygiene [5] Association put out a quarterly which became later the [6] American Industrial Hygiene Journal. 1 think about [7] this time The Journal of Occupational Medicine was [8] beginning, about '56, '7, '8, '9, somewheres through [9] there. [10] There was a, at one time it was labeled [11] Journal of Industrial Hygiene and Occupational [12] Medicine, I think was the title. And that has [13] undergone a series of name changes, but it's maintained [14] its continuity. I don't know its current title. [15] Q. Okay. [16] A. There was an industrial hygiene foundation at [17] Pittsburgh that would send out abstracts of articles [18] and references, sort of a periodic check on the [19] literature. [20] Beyond that I don't really recall there were [21] specific sources. [22] ______ Q. Do you recall a book by Irving Sax? Page 40 [1] A. That came much later in time, I think. I am [2] not sure when the first edition came out, but I have [3] some knowledge of it. [4] Q. If I said that was published in 1951, would [5] that refresh your recollection? [6] A. It would surprise me. I was not aware that it [7] went that far back. [8] Q. Is that one of the journals or textbooks tint [9] you referred to as containing concise information? [10] A. Sax contains information. In those areas that [11] I feel I know something about, I would say that it is [12] unfortunately not critically evaluated. It contains [13] good and bad information. Page 34 to Page 40 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068043 BSADepo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992XMAA(/) [14] Q. Was that one of the texts that w<is available [15] to voh :l;ir:>:e your cvccr at A.nicncar, Cyanamid? [16] A. I really do not refer to Sax very often. [17] Q. Isa; that mailable a! American Cyanamid. do [18] you recall? [19] A. I suspect it was, but I don't recall [20] specifically. [21] MR. FLORIG: We have been going for an hour. [22] Do you want to take a five-minute break? Page 41 [1] MR. WALSH: Sure, that sounds good. [2] (Recess.) [3] MR. FLORIG: Back on the record after a short [4] break. [5] BYMR. FLORIG: [6] Q. Dr. Levinsins, I would like to go back just a [7] moment and ask you, is Mr. Walsh representing you at [8] this deposition today? [9] A. He is representing me as a former Monsanto [10] employee, yes. [11] Q. Are you paying his attorney's fees? [12] A. No. ' " [13] Q. Do you know who is? [14] A. No. [15] Q. Have you been able to recall the names of any [16] of the other journals or textbooks other than the ones [17] you mentioned that were used as reference materials [18] during your indoctrination period at American Cyanamid? [19] A. I would first like to say my indoctrination [20] period was an indoctrination into the Cyanamid [21] operation. [22] Q. Yes. Page 42 [1] A. It was not an indoctrination of me into the [2] field of toxicology. [3] Q. Right. [4] A. I really cannot recall. There are many [5] textbooks, not many, there were some textbooks I use [6] and some journals I look at, and I have developed this [7] habit over the years. [8] But I am unable to say when I became aware of [9] or started using this particular text or monograph. [10] Q. Is it fair to say some you had used as a [11] graduate student and continue torefer to? [12] A. Yes. [13] Q. Some that you used at the Graduate School of [14] Public Health that you contmuc to refer to? [15] A. Yes. ` [16] Q. Werethose the ones youmentioned to me [17] already, or some cf the ones you mentioned? [18] A. The ones I mentioned would include those, yes. [19] Q. I am going to take you back briefly to your [20] graduate studies and ask if one of the skills taught [21] during your gradmte studies was how to do this kind of [22] historical research on chemicals and their potential Page 43 [1] toxic effects? [2] A. I was never, quote, taught, end of quote, how [3] to do research, historical research on a chemical and [4] its effects. I am not aware of anyone who was taught [5] that at that time. [6] Q. Is that something that you team through 17] experience as a graduate student? [8] A. There are review articles that come out, there [9] are updates on information. Unless one has a specific [10] interest or a particular need, at least I would not go [11] back and look at the early literature. I would rely on [12] the collector of the information in the review article. [13] Q. For instance, when you were domg your bone [14] solubility testing as a graduate student, did you [15] attempt to review what 'nod gone on before? [16] A. Yes. [17] Q. Wienyou were teaching at theGraduate School [18] of Public Health, did you teachstudentshow to do [19] surveys of literature or texts? [20] A. No. [21] Q Is that something that would be cxpcctal to [22] leant on their own if theu had to7 Page 44 [1] A. I did not teach it, and it never occurred to [2] me that it had to be taught. [3] Q. Is that because you would correct the students [4] to team how to do that? [5] A. All of our students were graduate students. [6] They had at least a bachelor's degree, in some cases [7] doctorates. If they did not know how to study or do [8] research, that was their problem, it was not my [9] concern. [10] Q. If one of your students came to you, for [11] example, and said, "I am interested m studying the [12] toxic effects of mercury, but I don't know where to [13] start," could you direct that student to some [14] information or source books? [15] A. I could probably have located an article, a [16] review article that he could look at. But if he wanted [17] to do research, he would have to have a better [18] formulation of a question rather than "I want something [19] to do. Tell me what I should do." [20] Q. What was your next position at American [21] Cyanamid, or what was your position after this [22] indoctrination period?'_______________ __________________________ Page 45 [1] A. I was named chief industrial toxicologist and [2] I became the director of their environmental health [3] laboratory. [4] Q. That was simultaneous? [5] A. Yes. [6] Q. fust so I get the titles correct, chief [7] industrial toxicologist and director of environmental [8] health laboratory? [9] A. Right. [10] Q. That would have been around the aid of 1958? [11] A. Either end of '58 or early '59, yes. [12] Q. How long did you hold those titles? [13] A. Until 1971. [14] Q. You kept those titles until you left American [15] Cyanamid? [16] A. Yes. [17] Q. Did you have distinct duties with respect to [18] each of those titles, or was it one job with two [19] titles? [20] A. It was one job, and the title depended on the [21] context in which people wanted to refer to it, I guess. [22] _____Q. Can you describe for me what your job entailed Page 46 [1] when you first assumed those positions? [2] A. Basically it consisted of planning, conducting [3] and evaluating the results of toxicity studies on [4] Cyanamid products, preparing those reports or reports [5] of those studies in a manner suitable for distribution [6] outside the company and within the company. There were [7] occasions when I prepared summaries of data for [8] specific reasons, and there were times when I made [9] contact with regulatory agencies regarding those [10] products. [11] Q. Was your work lunited to a final American [12] Cyanamid product, or was it, did it also involve the [13] components cf those products? [14] A. It was limited to things of interest to [15] Cyanamid, most of those were specific materials. The [16] only components, place components would fit would be [17] there might be a formulation of a material in a solvent [18] or some other mixture for ease of application or [19] handling or something. [20] And so that would be the only place that we [21] would get into components in general that I can recall. [22] Most of it was single entity. 1 2 3 4 Page 47 [1] Q. Did any cf your work involve evaluation or [2] tcst'mg of waste streams from American Cyanamid? [3] A. I don't recall that it did. If it were done, [4] it would be no more than very cursory, short-term ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 40 to Page 47 WATER PCB-SD0000068044 BSA___________________________ Depo of: GEORGE J. LEVINSKAS [5] tests. [6] Q V.;:i .iv'i renumber cal! being mvolvcd with [7] ar.y o' those'' [8] A. I say there may be a few that we did, I can't [9] recall specifically. But we certainly did not do any [10] extensive testing of any waste products. [11] Q. Dui you do any evaluation or testing of [12] byproducts or co-products? [13] A. The same answer I would make as I did for [14] wastes. We may have done a few cursory or short-term [15] tests, but we did no extensive testing of such [16] materials. [17] Q. Why do you say cursory or short-term testing? [18] A. Well, we might have done something like [19] measure the ability to irritate the eye or the skin, or [20] we might have done a single dose oral toxicity by [21] mouth, which we would do on many materials, research [22] materials as well as products, early stages. So we may Page 48 [1] have handled the waste, but nothing that made any [2] impression on me. We did not do anything like the [3] kinds of studies we do on a product that was going to [4] be marketed. [5] Q. Was that truethrough your entire career at [6] American Cyanamid? [7] A. Yes. [8] Q. Do you recall being vwolved withtoxicity [9] studies on bulk chemicals being made by American [10] Cyanamid? [11] A. I would give the same answer as I did for the [12] others. We may have done some short-term single dose [13] tests with bulk chemicals. We did not do any extended [14] testing of them. [15] Q. Your involvement was almost exclusively with [16] consumer products from American Cyanamid? [17] A. It included, it could have included all the [18] products or any of the products that Cyanamid made. [19] The predominant emphasis was on agricultural products. [20] Cyanamid initially did not have, in the conventional [21] sense that we think of consumer products that were [22] broad based products. Page 49 [1] Later on they did some, and we did a little [2] bit of testing on consumer products. [3] Q. Thank you. [4] Do you recall any of the agricultural products [5] you were mvolvcd with testing? [6] A. There were a series of chemicals called [7] organophosphates, several derivatives of those or [8] several members of that category. There were a variety [9] of experimental compounds being developed of various [10] classes, I just can't recall specifically, chemical [11] nature. [12] Many of these came in as new materials with CL [13] numbers on them, Cyanamid Laboratories numbers on them. [14] And I did have records, the company had records of the [15] chemical structures, but I did not attempt to recall [16] them. [17] Q. You mentioned organophosphates. Are those [18] fertilizers? [19] A. No, these are pesticides. [20] Q. Pesticides. Do you recall the results of any [21] of your toxicity studies on those pesticides?1 2 3 4 5 6 7 8 9 10 11 [22]_______ A. There were a variety of different responses, Page 50 [1] depending on which material was under study. [2] Q. Do you recall any of the specific materials [3] that were under study? [4] A. Two to illustrate the range. One is Malathion [5] and the other as Parathion. [6] Q. Was the first you mentioned Malathion? [7] A. Yes. [8] Q. Do you recall what the results were of your [9] toxicity tests on that material? [10] A. We did a variety of tests. Some had been [11] done, we did additional ones. Other than give you a Monsanto v Aetna December 22, 1992XMAX(8) [12] recital of all of the effects, I can't tell you which [13] was which. [14] But it's a class of compounds known as [15] cholinesterase inhibitors. IPs been used very widely, j [16] approved on probably a hundred or more crops. Its j [17] toxicity is quite low, it's among the lowest of that j [18] class of compounds. IPs relatively innocuous in ' [19] people, quite potent in insects. ; [20] Q. It was foimd to have some toxic properties, I [21] correct? j [22]_______ A. The purpose of toxicity testing is to give | Page 51 ! [1] sufficiently high doses that one can observe what the [2] adverse effects would be, toxic effects, yes. [3] Q. Can you tell me wlmt you discovered by [4] Parathion? [5] A. By contrast to Malathion it is highly toxic to [6] people, animals and insects. Its general properties [7] are the same except that ips a much more potent, [8] considerably more potent in general than the Malathion. [9] Q. What was the environmental health laboratory [10] at American Cyanamid? [11] A. There had been two preexisting laboratories, [12] one on industrial toxicology and one for industrial [13] hygiene. Those two were merged into the environmental [14] health laboratory, which at the time that I took [15] direction of it. [16] Q. The merger had taken place prior to your [17] becoming the director? [18] A. It occurred about thesametime. [19] Q. All right. [20] A. I can't be more precise than that. [21] Q- Can you describe for me while you were in that [22] position how toxicity tests were done? Page 52 [1] MR. FLORIG: Why don't we strike that and back [2] up a step. [3] BY MR. FLORIG: [4] Q. How wotdd you determme when you became the [5] director of the environmental health lab which [6] materials you were going to test? [7] A. Much of the requests, if you will, for testing [8] came from my immediate superior in the medical [9] department to which I - the laboratory was a part of [10] or the medical director, himself. They in turn would [11] be contacted either by the operating companies, [12] operating units which had the products or they would [13] have contacted the operating units to get their [14] concurrence to do the studies. [15] Q. All right. [16] A. So I did not make very many decisions about [17] what had to be tested. [18] Q. o directive came to you from somewhere from [19] one of your superiors? [20] A. Yes. [21] Q. What would be the next step in dobtg a [22] toxicity test after determining which material you toere Page 53 [1] going to test? [2] A. Well, we woulddetermine what raised the [3] question so we would know what type of testing to do. [4] Then it would be to design a test, plan a test [5] procedure, schedule it and have it conducted, assemble [6] the data, write the report and return it to the [7] appropriate people. [8] Q. All right. Were there protocols in place for [9] conducting those tests? [10] A. My general recollection is that as I got a [11] request, I would develop sort of a general protocol for [12] that test. [13] Q. All right. [14] A. The next time I got a request I would review [15] the previous one I had done of that nature, decide it [16] was either adequate to use again or I would modify it [17] in light of the particular chemical or changes or [18] whatever, and then use that. . Page 47 to Page 53 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068045 BSA_______ ___________________ Pepo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992_________ XMAX^J [19] Q. If the oucstuy? were raised about a material [20] rva?!>c' s.*>icoic hiiii reported that it had caused a skin [21] irritation, irould you also do i>ihalatv?u studies oti [22] that material, oral dose studies cm that material, or Page 54 [1] would you be limited to dermal? [2] A. I don't think there was a specific answer. It [3] would depend on what information we already had, the [4] confidence we put into it, and also the nature of the [5] use from which the complaint had arisen. [6] Q. Do you recall doing aim testing or supervising [7] ami testing while director of the environmental health [8] lab dealing with the effects of materials on other than [9] mammalian life? [10] A. We did not have the capabilities in the [11] laboratory, in my laboratory, environmental laboratory, [12] to deal with other than mammalian systems. We did not [13] do such testing. [14] Q. Did you send any of that testing to outside [15] labs? ' [16] A. There were other parts of the company that [17] would study effects of chemicals on plants, because [18] they were seeking chemicals that were either beneficial [19] or harmful to plant life. [20] Shortly before I left Cyanamid, probably in [21] the late '60s, there was a fish testing laboratory that [22] opened up in the Boston area, and we began doing a Page 55 [1] little bit of our pesticide work for materials intended [2] to be used around or on water. We began doing a few [3] fish toxicity tests. But that was a relatively short [4] time before I left Cyanamid. [5] Q. All right. Was the purpose of that testing to [6] determine what effects the pesticide would have on fish [7] if it got ado the body of water in which the fish was [8] living? [9] A. Yes. [10] Q. Do you recall any such tests being done on [11] aejuatic life within a body of water? [12] A. No, I do not recall such tests. . [13] Q. While you were at Cyanamid and were doing [14] toxicity testing of various materials, was one of the [15] considerations the pathway of ingestion? [16] A. Well, ingestion is a specific pathway. [17] Q. All right. [18] A. That would be by mouth. [19] Q. Did you consider alternative ways in which the [20] material could alter the body? [21] A. Yes, some thought was given to that. [22] _____ Q. That is part of the study of toxicology, Page 56 [1] correct? [2] A. In the sense that there were and still are [3] relatively few criteria or standards, regulatory [4] agencies have subsequently more recently set standards [5] for tests or descriptions of tests, much of the testing [6] at that time was done on the judgment of the [7] individual. [8] And so it's hard to say that, you know, this [9] was a standard or this was not a standard, because I [10] don't think there were very many studies done in what [11] we would call the cookbook fashion, routinely. [12] Q. Even as far back as when you were a graduate [13] student, it was known that the human body could absorb [14] materials in basically three ways, absorption, [15] inhalation and ingestion, is that fair to say? [16] A. Yes. [17] Q. Are there other ways, or arc those the three? [18] A. Well, we inject things, we get them beneath [19] the skin. [20] Q. All right. [21] A. There are other external surfaces besides the [22] skin. There are a few materials that may penetrate Page 57 [1] through the eye, other body surfaces, orifices. [2] Q. All right. [3] A. But it's a question of how you want to [4] subdivide them. [5] Q. Is ;! fair to sou that those arc the three [6] primary means by which matcruds get mtc the human ; [7] body?' " ' j [8] | [9] | [10] j [11] [12] I [13] j [14] A. They would be the three most frequently encountered. Q. Occasionally there would be these other means, cither some kind of injection beneath the skni, absorption through the eye or through some other body cavity? ` A. Yes. [15] Q. You mentioned that as director of the [16] environmental health lab you had contact with [17] regulatory agencies of the government, correct? [18] A. Yes. [19] Q. What did those contacts entail? [20] A. They dealt with registration of the pesticide [21] products or in seeking regulatory approval from the [22] Food and Drug Administration for indirect contact Page 58 [1] chemicals with foods. [2] Q. Was pesticide registration a requirement in [3] 19353, or did that come later? [4] A. It was a requirement and it was at that time [5] handled by the U.S. Department of Agriculture. [6] Q. What kinds of information did the Department [7] of Agriculture require along with your registration [8] application? [9] A. It would depend on the nature of the chemical [10] and the intended use of the chemical. [11] Q. Depending on what it was going to be applied [12] to? [13] A. What it was going to be applied to, how widely [14] it was to be applied, a variety of considerations would [15] go into that. [16] Q. Did the USDA require that you break down what [17] the components of the material being registered were? [18] A. One had to present an identity of the material [19] and, if it was a mixture, one would have to identify [20] the components and the percentages. [21] Q. Was it required that toxicity information be [22] supplied with the registration?_____ __________________________ Page 59 [1] A. Yes. [2] Q. Did American Cyanamid have to do toxicity PI tests to establish what the toxicity cf the materials [4] was? [5] A. Yes. [6] Q.That was part of your job1 [7] A. Yes. [8] Q. What toxicity information was supplied to the [9] U.S.D.A. in conjunction with a pesticide registration? [10] MR. WALSH; Objection, that is a very broad [11] question. Are you asking him about a particular [12] chemical, or in general? [13] MR. FLORIG: I amasking ingeneral. [14] MR. WALSH; All right. [15] A. I think I tried to indicate it would depend on [16] the nature of the chemical, its intended use, its scope [17] of use. I mean how widely was it going to be used. [18] BYMR. FLORIG: [19] Q. Yes. [20] A. Was it going tobe used - who would use it. [21] So there could be quite a number of questions that [22] would have to be considered. Page 60 [1] Q. In connection with thetoxicity mfonnation [2] that was supplied, was that given in parts per million [3] or parts per billion, is that the kind of information [4] tlmt you would give to the U.S.D.A.? [5] A. Part per million and part per billion are [6] concentration terms. They might or might not appear on [7] a toxicity report. It would depend whether those terms [8] were used in the report. [9] Q. Would you provide infonnation on the effects ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 53 to Page 60 WATER PCB-SD0000068046 , ii iwAno 4vioi't>aiuu v /-k.tra'Vd Uecemoer l&I AjVIAA(IU) [10] cm humans of exposure io a certain concentration? [11] A. We would not have information on the exposure [12] effects in huinans. [13] Q. All right. [14] A. In most cases. So we would provide basically [15] animal data describing results which were encountered [16] at levels considerably in excess of any that we [17] anticipated the users or the consumers to encounter. [18] Q. Dul you provide diformation on the effects on [19] animals of exposures to different concentrations? [20] A. Yes. [21] Q. Would thatmformation contain inlmlation [22] mformation?__________ Page 61 [1] A. Theremight beshort-term inhalation studies [2] on some registrations. [3] Q. Was that information based on a single dose? [4] A. Much of the inhalation information at that [5] time was based on single dose exposures. [6] Q. Was some also based on exposures over an [7] extended period of time? [8] A. There were some multiple exposures; I do not [9] recall any for extended periods of time. [10] Q. Just so I am clear, what do you mean by an [11] extended period of time? [12] A. It would have been exposures over several days [13] a week for a week or two, but not a 90-day or a [14] lifetime sort of inhalation study. [15] Q. That was not required by the U.S.D.A.? [16] A. Not that I am aware of, they never required [17] it. [18] Q. Were some of the studies submitted to the [19] U.S.D.A. also digestion studies? [20] A. Yes. [21] Q. Was that information also provided in the same [22L way, is it a single digestion, long-term ingestion,_____ ______ ? M i\c 62 [1] some intermediate level? [2] A. Except for very preliminary information most [3] of the ingestion data were of longer duration, anywhere [4] from one month upward. [5] Q. Okay. Was absorption diformation supplied? [6] A. In most cases, or I should say probably [7] virtually no cases the effects of the chemical as [8] manifested in the animal would be attributed to [9] absorption. But absorption as such was not measured. [10] Q. Can you explain that to me, how you can [11] attribute it to absorption without testdig for [12] absorption? [13] A. If I gave an animal cyanide and it turned blue [14] and died of cyanide poisoning, I would assume it died [15] from cyanide poisoning. I would not have measured how [16] much of the administered cyanide had gotten into the [17] animal, but I would be quite convinced he had died of [18] cyanide poisoning, or he did die of cyanide poisoning. [19] Q. Is that because of controls used, you can rule [20] out other causes? [21] A. The purpose of control is to observe the [22] behavior of the test animals, a norm or standard from Page 63 [1] which you observe the changes in behavior if any of the [2] test animals. There simply is an inability in most [3] cases to measure the extent of absorption of many [4] compounds. [5] Q. Was diformation supplied in connection with [6] the registrations as to whether the material was a skin [7] irritant? [8] A. That would be part of the registration [9] package, it would be required for labeling of the [10] material. [11] Q. The same is true for an eye irritant? [12] A. Yes. [13] Q. Does the word "corrosive" have a technical [14] meaning within the study of toxicology? [15] A. I guess I would have to indicate I am not sure [16] what most people consider corrosive. To me corrosive [17] is destruction. IPs a destruction of tissue or : [18] destruction of the underlying material, corrosion of a [19] metal by an add. ! [20] So corrosion is an actual destruction, it's 1 [21] more than an irritation. I [22]____ Q. All right. If / look at a toxicology report_____________ j Page 64 | [1] and it lists a material as corrosive, does that mean i [2] that it will do permanent damage to the living tissue [3] it's exposed to? [4] A. Corrosive can refer to inanimate surfaces or [5] to living tissue. [6] Q. Yes. [7] A. There are substances that I have tested that [8] were marked corrosive to inanimate surfaces that are [9] not corrosive to living tissue. [10] Q. Okay. [11] A. The fact that there is destruction of the [12] tissue may or may not mean that it will recover at the [13] end, it could be either. [14] Q. As applied to living tissue, corrosive is, [15] just so I understand, more extreme than an irritant, [16] correct? [17] A. Yes. [18] Q. From your understanding of your profession, if [19] / see in a toxicology report that something is listed [20] as corrosive, if doesn't say to what, does that [21] generally mean to Irving tissue? [22] ______ MR. WALSH: Objection. The question calls for_____ Page 65 [1] speculation. [2] You can respond. [3] A. If I were labeling - if I tested a material [4] that was destructive to living tissue, I would label it [5] corrosive. And then I would either specify skin or [6] eyes, if I knew, or both. [7] BY MR. FLORIG: [8] Q. Adi right. [9] A. Or I might say "Corrosive," and then follow it [10] with the phrase, "Do not get in skin or eyes or on [11] skin, in eyes," and so forth. Then with a very, the [12] following line, "In case of contact flush immediately [13] with plenty of water." So I would try to make the [14] statement refer to the tissue. [15] If it said corrosive to mild steel or [16] whatever, that's the way I would prefer to see it done. [17] I am not sure it's always done that way. [18] Q. Most industrial toxicity testing is not done [19] on humans, correct? [20] A. That's a very general statement, but I guess I [21] would concur. Most industrial toxicologists are not [22] physidans; they have no justification for working on Page 66 [1] people or with people. [2] Q. How do you go about translatdig the results of [3] animal toxicity testing to humans? [4] I should say, how did you do that when you [5] ivere at Cyanamid? [6] A. Well, there are several ways. One is that you [7] assume - all of these involve assumptions until you [8] gain experience otherwise. For most short-term tests [9] including labeling we assume the animal is predictive [10] of the effect in man. [11] If there are handling aeddents or episodes of [12] some nature that there is human contact, inadvertent or [13] acddental, then one would attempt, should attempt to [14] gather that information and compare it with the animal [15] result. [16] If there is consistency between animal and [17] human, then one has greater confidence that other [18] studies will also be consistent. If they are [19] inconsistent it creates dilemmas. [20] The other aspect of animal testing is that we [21] frequently test in more than one spedes. And there is [72] a general supposition which has worked well over the Page 67 Page 60 to Page 67 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068047 BSA Depo of: GEORGE ]. LEVINSKAS Monsanto v Aetna December 22, 1992 Ag\lAA(l 1) HI years that if there is a consistency in response [2] between the different species, that man ought to be [3] somewhat similar. [4] Q. All right. [5] A. If there is a discrepancy between the two [6] tested species, one assumes as a matter of prudence and [7] common sense that man might be at least as sensitive as [S] the most sensitive species, recognizing man might be [9] less sensitive. [10] But he is at least as sensitive as the most [11] sensitive species, and one would use that as a basis [12] for extrapolation. [13] Those are the general rules that I think most [14] people follow whether they recognize them or not. [15] Q. Okay. [16] A. Then a third point. The levels at which those [17] effects occur and the potential level of exposure of [18] man, fantastically high levels of exposure, one does [19] not expect to see them at very insignificant levels of [20] exposure to man. [21] Q. You anticipated my next question. Knowing [221 what a toxic dose is to an animal, how arc safe levels____________ Page 68 [1] of exposure to humans established, how were they back [2] m your Cyanantid days? [3] A. The only reasonably referable standard was the [4] Food and Drug Administration. The late Dr. Arnold [5] Lehman and his group concluded that there could be a [6] ten-fold variation between species, between the test [7] animal and man, and there could be a ten-fold variation [8] between the most sensitive and the most resistant [9] member of a given species. [10] So ten times ten is a hundred, and they [11] applied a hundred fold safety factor to the so-called [12] no-effect level of a long term animal study. [13] Later they began using a thousand-fold safety [14] factor if they were using a 90-day study for a [15] no-effect level instead of a lifetime study. [16] Q. All right. [17] A. If one looks at the so-called threshold limit [18] value set by the American Conference of Governmental [19] Industrial Hygienists the, quote, safety factors [20] between the no-effect levels and the permissible [21] workplace exposure levels are really - vary all over [22L the map, there is no consistency. Some are relatively Page 69 [1] small, you know, just small devisors, 2, 3, 4, 5 upper [2] effect levels. So there is no overall consistent [3] pattern. [4] Q. No effect level is referred to as NOEL, is [5] that correct? [6] A. Yes, they are essentially synonymous, some [7] minor variation but essentially synonymous. [8] Q. NOEL is no observable [9] A. Us old-timers would say no observed effect, [10] which we meant, and the purists are saying well, since [11] you didn't look at everything you could have looked at, [12] so they are saying, we would say no observed level, [13] saying we did not see anything, they are saying we did [14] not see anything in the things we looked for and we [15] didn't look at everything under the sun, so they have a [16] no observed effect level which is, semantically may be [17] more precise but the meanings are essentially [18] synonymous. [19] Q. You mentioned threshold limit values a moment [20] earlier, those arc knoion as TLVs? [21] A. Yes. [22]_ _____ Q. Do you recall when TLVs came into being?____________ Page 70 [1] A. The predecessor of the TLVs was a list [2] published by Warren Cook about 1943 or '45. [3] Q. Is tluit Warren Cook? [4] A. Warren Cook, C-o-o-k, I think. [5] They had different terms. He published a [6] so-called "permissible workplace exposure" or [7] something, I forget. The term has bounced around quite [8] a bit before they settled on TLVs. His is probably one [9] of the earliest, if not the earliest publication. It [10] was a compilation of numbers that different people in [11] state, federal government's and elsewhere had [12] established. [13] Q. All right. [14] A. So he just sort of compiled and published this [15] list. [16] Q. Mr. Cook used some predecessor term to TLV? [17] A. Yes, I think he said "permissible exposure [18] levels," I am not sure that that was the -- [19] Q. Your recollection is that Mr. Cook's, was it a [20] book? [21] A. No, it was just an article. [22] Q. An article. Do you know where it was Page 71 [1] published? [2] A. I wouldn't want to swear at it, but in general [3] I think there is a journal that is no longer published [4] call Journal of Industrial Hygiene and Toxicology. [5] Q. All right. [6] A. And I think it was in that. And it would have [7] been in the 1940s. [8] Q. Your imdcrstanding was that Mr. Cook conducted [9] some kind of literature or search to determme what [10] studies had been made on various materials and compiled [11] them? [12] A. As I recall I think I said he compiled [13] information from a variety of sources. How he, whether [14] he got it through personal contact or, I doubt that [15] many of these were published prior to his collecting [16] them. [17] Q. Sure. [18] A. I don'tknow how he got them. [19] Q. Was that a reference or a source that you used [20] at the Graduate School of Public Health? [21] A. The reason I - I think the reason, I don't [22] know when I did this, but somewhere along the line as Page 72 [1] part of the teaching I was going to present to students [2] or to people that I was talking to a history, where did [3] TLVs come from and how they got to the present form. [4] And in preparing for that is when I went back and [5] looked at Cook's original article and how it developed. [6] Q. Yes. [7] A. But I don't recall now whether I did this as a [8] teaching at Pittsburgh or did this at a talk I was [9] going to give somewhere subsequent. [10] But that is the reason why I went back and [11] looked at it. [12] Q. Referring to your period at Cyammid, is it [13] fair to say that you would want to be conservative in [14] exposing humans to materials that were known to be [15] toxic in some fashion? [16] A. I guess I have some difficulty with the [17] question. [18] Q. Okay, what difficulty? [19] A. We are not -- we don't normally plan to expose [20] people to chemicals. [21] Q. It was recognized within the chemical industry [22] at that period that people did get exposed to chemicals Page 73 [1] either in the workplace or near the plant, correct? [2] A. Yes, we Tecognized that people will be exposed [3] to chemicals if they use them, but we don't plan to [4] expose them in that sense of the word. [5] Q. All right. [6] A. I guess thatis thedistinction I would like [7] to make. [8] Q. Within the chemical industry at that time, [9] well, let me go back a step. [10] During the period you worked for Cyanamid did [11] you have contact with people from other chemical [12] companies? [13] A. Yes. [14] Q. How wouldthosecontacts occur? ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 67 to Page 73 WATER PCB-SD0000068048 BSA Depo of: GEORGE J. LEVIN5KAS Monsanto v Aetna December 22, 1992 AMAA\1ZJ [15] A. A fair number would be through scientific [15] meetings. I would meet them at scientific meetings or [17] be introduced to them by people who knows them as well [IS] as me. Through trade association activities such as [19] tire Chemical Manufacturers Association, I would meet [20] and deal with some of these people. In a few instances [21] there might be a common interest in a chemical or they [221 would be using one of our materials or we would be Page 74 [1] using one of theirs and we would have contact on a [2] specific chemical. I guess those are the [3] predominant [4] Q. In some instances would Cyanamid fund studies [5] along toith other companies of various materials, is [6] that one of the xvays you are thinking about? [7] A. There could be that. There were one or two [8] instances I think when I was at Cyanamid where Cyanamid [9] participated in a so-called joint venture. [10] Q. You participated in some of those meetings and [11] trade associations and joint studies personally? [12] A. I was not personally involved in the joint [13] studies. [14] Q. All right. [15] A. I did participate in trade association [16] meetings, yes. [17] Q. Was it your understanding as an industrial [18] hygienist or toxicologist that chemical companies were [19] interested in keeping worker exposures to the lowest [20] levels they could if the materials were known to be [21] toxic? [22] _____ A. That's the impression I had, and as far as I Page 75 [1] know that is the procedure they operate under. [2] Q. That is true even until today, correct? [3] A. Yes. [4] Q. And that was true when you were at the [5] Graduate School of Public Health, to the best of your [6] knowledge, correct? [7] A. Yes. [8] Q. You mention that you have done a little bit of [9] historical research, at least in connection with Mr. [10] Cooks list. [11] Is it your understanding that one of the [12] reasons mdustrial toxicology became a discipline was [13] to protect workers from unsafe exposures to chemicals? [14] A. I really don't know why industrial toxicology [15] became a discipline assuch. [16] Q. Okay. [17] A. Under thegeneral framework of occupational [18] health that I referred to as the Department of [19] Occupational Health at the school in Pittsburgh, there [20] was an interest in protecting employee health. This [21] was one of the facets of it. That was one of the [22] elements to consider in health protection. Page 76 [1] Beyond that, I don't know and I don't really [2] have much, haven't given though to why it became, or [3] why it's recognized as a separate discipline and became [4] a separate discipline. [5] MR. FLORIG: It's almost a quarter after. Do [6] you want to take a lunch break? [7] MR. WALSH: Sure, fine. [8] MS. SANDBECK: Fine. [9] MR. FLORIG: We will resume at a quarter after [10] 1. [11] (Whereupon, the deposition was recessed at [12] 1215 p.m., to resume at 1:15 p.m.) [13] [14] [15] [16] [17] [18] [19] [20] [21] [22] Page 77 [1] AJTERNOON SESSION [2] (1:23 p.m.) : [3] MR. FLORIG: Back on the record, i [4] BY MR. FLORIG: | [5] Q. Dr. Levinskas, as you understand, you are ' [6] still under oath, correct? . . I [7] A. I do. [8] Q. Before lunch we were talking a little bit [9] about the history of mdustrial toxicology or [10] industrial hygiene. Do you recall that? [11] A. We talked about the specific special limit [12] value list. [13] Q. All right. Was one of the purposes of [14] industrial toxicology cr mdustrial hygiene to allow [15] companies to imp.cment procedures that would prevent [16] employees from bring exposed to certain levels of toxic [17] materials? [18] A. I can't answer that question, I don't know | [19] what the origin was or its intention. [20] Q. During your career at Cyanamid would Cyanamid [21] take steps to make sure their employees weren't exposed [22] to unacceptable amounts of toxic materials? Page 78 [1] A. There were other people in the Medical [2] Department whose function was to ensure the safety of [3] workers. I do not know much of their operations, but [4] there were other people who had that concern. [5] Q. Those people would rely on the information [6] that your department helped to generate? [7] A. That would be part of the consideration, yes, [8] I would say. . [9] Q. Based on your knoioledge of the chemical [10] industry up until 1971 - [11] MR. FLORIG: Strike that. [12] BY MR. FLORIG: [13] Q. At Cyanamid were precautions taken to prevent [14] human exposure to potentially toxic materials? [15] A. I have indicated there are other people who [16] were concerned with the health of workers. [17] Q. Yes. [18] A. And I could assume that that was so, but I was [19] not directly involved in that phase of the operation. [20] Q. That woidd have been a reasonable step to [21] take, correct? [22] ______ A. As I have indicated, in the Medical Department Page 79 [1] were personnel concerned with health, and as far as [2] that was concerned that would be a reasonable step to [3] take. [4] Q. Based on your experience in the industry up [5] until '71, woidd that have been done throughout the [6] industry? [7] MR. WALSH: Objection, that calls for [8] speculation. [9] A. I do know from contact with people in other [10] companies that they had medical departments and [11] personnel who were concerned with employee safety. On [12] the basis of that I could assume that the rest of the [13] industry was doing the same. [14] Q. Okay. [15] A. Or at least the segments of industry I had [16] contact with. [17] Q. As an industrial hygienist or toxicologist or [18] pharmacologist, based on your experience up until 1971 [19] you wouldn't want the potential for uncontrolled [20] exposure to toxic materials to occur to human beings, [21] woidd you? [22]_______ MR. WALSH: Object to the question as broad Page 80 [1] and vague. [2] A. I guess one would have to define [3] "uncontrolled." I think I have indicated in earlier [4] comments that the intent is not to expose people. It [5] comes about rather through a recognition that in using Page 73 to Page 80 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068049 BSA Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992 AMAAjU) [6] chemicals people will be exposed. But there is no [7] intention of exposing them. [8] And so I guess the most direct answer to your [9] question is, I don't think I would want people exposed, [10] controlled or uncontrolled, if I could avoid it. [11] BY MR. FLORIG: [12] Q. While you were at Cyanamid did you have any [13] responsibility for disposal or treatment of waste [14] products? [15] A. No. [16] Q. In 1971 you went to work for Monsanto, [17] correct? [18] A. Yes. [19] Q. Can youtell me how it isthat youcame to be [20] employed by Monsanto? [21] A. TheCyanamid decided to disband their [22] environmental health laboratory. It was retrenched and Page 81 [1] ultimately closed out. And so I was seeking [2] employment. [3] Through the offices of people in personnel at [4] Cyanamid that I knew, had suggested I contact the [5] personnel people at Monsanto, which I did, which led to [6] my coming here, or coming there. [7] Q. And ultimately to your coming here. A little [8] 'round about, but understood. [9] Your first contact was with personnel within [10] Monsanto, the Personnel Department? [11] A. Yes. [12] Q. Prior to that time did you know anybody who [13] worked for Monsanto? [14] A. Yes. [15] Q. Do you recall who those people were? [16] A. The two that come most readily to mind is the [17] late Dr. Bill Hunt and to a lesser degree, Elmer [18] Wheeler. [19] Q. How did you know Bill Hunt? [20] A. Through meetings, associations in toxicology. [21] Q. How about Elmer Wheeler? [22] _____ A. Again,through meetings and associations. Page 82 [1] Predominantly through the American Industrial Hygiene [2] Association, similar to along the line I met him. [3] Q. Did you hold those two men in high esteem, did [4] you respect them professionally? [5] ' A. Yes. [6] Q. Did you interview prior to being hired by [7] Monsanto with anyone other than personnel people? [8] A. At Monsanto? [9] Q. Yes. [10] A. Oh, my initial contact waswith the Personnel [11] Department. Interviews and discussions were held with [12] members of the Medical Department before I joined the [13] company, before they agreed to accept me. [14] Q. Were those interviews with Mr. Hunt and Mr. [15] Wheeler? [16] A. Predominantlywith Dr. Kelly,with Mr. [17] Wheeler, in the course of which I had some discussions [18] with Dr. Hunt. [19] And I met Jack Garrett for the first time. I [20] had also met Dr. Kelly for the first time. I had not [21] met him prior to being interviewed at Monsanto. [22]_______ Q, Did you mterview xoith Jack Garrett, or just Page 83 [1] meet him prior [2] A. Just discussions along the way. But I would [3] not regard what I had with him as an interview in that [4] sense of the word. [5] Q. Prior to 1971 / take it you were familiar with [6] Monsanto Company? [7] A. Yes, I had heard of the company. [8] Q. Prior to applying with Monsanto how did you [9] view them within the chemical industry? [10] MR. WALSH: Objection, broad, vague. [11] A. I don't think I had made a particular [12] assessment of them as such. I don't recall that I did, [13] and I don't recall that I would have had a basis to [14] even think about it. ; [15] BY MR. FLORIG: [16] Q. Had they beat considered a leader withm the [17] chemical industry? [18] A. My response is limited to my opinion. I had [19] not thought of any of the chemical companies at that [20] time in terms of leaders or followers or rankings. [21] Q. All right. [22] ______ A. I would have to confess that I don't think I Page 84 [1] consciously or even subconsciously thought in terms of [2] ranking companies in any sort of relative scale for [3] goodness or badness. [4] Q. What was your first job at Monsanto? [5] A. I think the initial title was manager of [6] product development. [7] And the reason I joined the company was to [8] formalize and centralize environmental assessments of [9] Monsanto products. And the initial charge was to look [10] at new products and new uses of existing products. [11] Q. How long were you manager of product [12] development? [13] A. That title was probably about a year and a [14] half, something on that order. [15] Q. Until 1972 or 73? [16] A. I would say end of '72, early '73, somewhere [17] in there. [18] Q. What you just described for me, was that the [19] extent of your job duties in that position? [20] A. That was what occupied a substantial part of [21] my time. I may have, undoubtedly did have requests or [22] questions from other people that I responded to, but it Page 85 [1] would have been somewhat incidental. [2] Q. What kind of environmental assessments did you [3] do? [4] A. In light of changing standards, concepts of [5] what was safety, what would constitute safety, and the [6] fact that there were increasing questions being raised [7] about environmental effects of chemicals, the idea was [8] to look at a material at an early stage of development, [9] try to anticipate the kinds of questions that would [10] arise or could arise from users of the material, from [11] the makers of the material, from those who wound up [12] with the final product in their hand, the ultimate fate [13] of the thing, and try to develop information or [14] research, see if there was information available or [15] should additional information be developed to try to [16] anticipate responses to those questions. [17] And then to come back at a second stage, after [18] the information had been developed and after the [19] product group had a chance to assess whether there [20] seemed to be a reasonable market for the product, to [21] give the Medical Department's concurrence that it was a [22] reasonably reassuring that the product could be made. Page 86 [1] used and ultimately disposed of safely. m q. Is it fair to say that your environmental [3] assessment of potential new Monsanto products was a [4] kind of cradle to grave assessment? [5] MR. WALSH: Object to the form. [6] MR. FLORIG: I will explain what I mean by [7] that to you. [8] BY MR. FLORIG: [9] Q. You had stated that you were looking to see if [10] the product could be made, used and disposed of safely? [11] A. That's right. [12] Q. Is it fair to characterize that as a cradle to [13] grave assessment? [14] A. That terminology, cradle to grave, has crept [15] in in more recent years, it has gotten to be bandied [16] about. That would be one characterization, I guess. [17] Q. Okay. [18] A. Would be acceptable, reasonable. [19] Q. All right. Did you assess the manufacturing ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 80 to Page 86 WATER PCB-SD0000068050 bsa Uepo or: Lmunim j. LfcviAJjsAa ivionsanto v rtenu ueiemoer zz, iA>z [20] process fa? that product? [21] A. The manufacturing concept would take that into [22] account. If it were a new process - Page S7 [1] Go back. If it were an existing process, [2] since we are dealing with new products and new uses of [3] products, we would not have considered necessarily an [4] old process. [5] If it was a new process for manufacture, there [6] was a separate procedure that I have heard of in the [7] company and I have very little knowledge about, it's [8] called LPP review, loss of property protection review, [9] that was done by others that would look at the aspects [10] of manufacturing under a new process. [11] Q. If that kind of evaluation was to be done [12] under uour direction, would employee exposures have [13] been considered? [14] A. I think I would have to say first they were [15] not done under my direction. [16] Q. Okay. [17] A. And secondly, I don't reallyknow. While I [18] know they were done and I know they existed, I really [19] am not sufficiently familiar with the content or the [20] nature of those reviews to comment whether or not [21] employee exposures were actually considered. [22] Q, You arc talking about the LPP reviews? Page 88 [1] A. Right. [2] Q. What you sayyou wereevaluatingwhether the [3] product could be used safely, tohat did that evaluation [4] entail? [5] A. From my perspective, again, there is an [6] earlier act, the Federal Household Substances Act, [7] which deals with labeling hazards for household [8] products. And that act's regulations require [9] consideration of the intended use and reasonably [10] foreseeable misuse of the product. [11] Now that is what I would, from what I [12] understand, would be the use of the product - I would [13] look at it from the standpoint of intended use of the [14] product and reasonably foreseeable misuse, which is not [15] really well-defined. I would try to anticipate those [16] kinds of questions. [17] Q. How would you go about determining whether a [18] product could be used safely? [19] A. The proposed, those proposing its use would [20] have some idea what it's to be used for and how it [21] would be used. [22] You know, I would have to ask them, what is it Page 89 [1] that you want to make and how do you anticipate people [2] are going to use it. And then I would want to know [3] whatever else, whatever information might be available [4] that might or might not be useful in evaluating the [5] situation. [6] Q. What kinds of information would you want to [7] know m evaluatmg whether it could be used safely? [8] A. Not to sound facetious, but I would like to [9] know everything that was related to the safe use of the [10] compound. [11] But I don't really know what may or may not be [12] useful until I get the information and I can look at it [13] and consider it and decide whether it's useful. So [14] what 1 would like to know is what can they tell me [15] about the product, and then I will sit there and try to [16] cogitate it. [17] Q. Is one of the things you would want to know [18] what the components of the product are? [19] A. Again, I will go back to comments that I have [20] made several times. I would want to know the [21] composition, is it a single substance or is it a [22] formulated material, a mixture of substances. So, yes. Page 90 [1] I would want to know the major constituents of the [2] material. [3] Q. Would you wa/it to know the major constituents, [4] or cd! the constztucnts? [5] A. t would have to say major constituents. [6] Q A7:v wouldn't yon want zc know all of them*7 81 92 1304 5 6 [7] A. I don't think there is a chemist astute enough , [8] to know every constituent in the sense of analyzing ; [9] down to the last molecule. I [10] Q % ^mt you arc talking about impurities and \ [11] that kind of thing? j [12] A. Yes, it's a question of what you can detect, j [13] and the levels at which you can detect varies greatly j [14] for different kinds of materials. So I don't think it j [15] is feasible to say that I want to know everything down I [16] to a fixed level. That may be achievable for some j [17] substances and not achievable for others. And so the [18] composition in terms of state of the art analytical [19] capability. And that changes with time. [20] Q. Right. You would at least ivant to know every [21] constituent that was intentionally pul there in making [22] that product, correct?___________ Page 91 [1] A. Yes, I indicated major constituents. If it's [2] in there, there must be a reason for it, or it's doing [3] something and it should be mentioned. [4] Q. Would you want to know the toxicity of all of [5] those compxments? [6] A. There well may be substances in there which [7] are, for instance, on the threshold limit value list or [8] somewhere that they have been well studied and [9] regulated. I could (heck that without going into depth [10] of the toxicology. [11] If it were a new material, we would probably [12] want to develop some of our own data, because there [13] would be no data on it. [14] So, yes, I would want to know something about [15] the toxicology of the substances. But what I would [16] want to know and to what extent again would depend on [17] the product, its intended use and a host of other [18] factors. [19] Q. All right. [20] A. I don't think there is a, I made reference to [21] a cookbook. There is no standard procedure that one [22] would in a mindless fashion apply time after time after Page 92 [1] time because of differing circumstances and differences [2] in products. [3] Q. If it was a material whose toxicity was well [4] known, you would simply refer to the literature or [5] previous information about that component, is that [6] correct? [7] A. If it was a reasonably well known material and [8] there was reasonable consensus about the toxicity, then [9] I would rely on that data and not go further. [10] Q. During the early 70s how would you determine [11] if there was reasonable consensus about the material? [12] A. Could be a variety of ways. One would be to [13] talk to other toxicologists at other companies. [14] Q. All right. [15] A. One could look to see whether published data [16] were consistent, whether different people had basically [17] published or drawn the same conclusions from their [18] data. The source of the data sometimes, whether it was [19] well documented or was purely anecdotal. [20] There would be a variety of ways of attempting [21] to assess the data. [22]_______ Q, Is that a somewhat subjective process? Page 93 [1] A. All judgments are subjective. [2] Q. If one of the constituents of the product ivas [3] a material whose toxicity was not well known, what [4] steps would you take at that point? [5] A. There could be a variety of responses. It [6] would depend on the amount of material, of the unknown [7] material, it would depend on the product, its nature of [8] its use. [9] There is no, at least in my judgment there is [10]no fixed response to an unknown material without Page 86 to Page 93 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068051 BSA_______________________________ Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992_______________________ aMaaUo) [11] consideration of a variety of other factors. [12] Q Would you that haiv tests performed on that [13] material? [14] A. I may or may not. [15] Q. If one of the constituents ivas a material of [16] unknown toxicity, you may or may not test that [17] material? [18] A. That's correct. [19] Q. What considerations would go into deciding [20] whether to test tlwt material? [21] A. I think this has been indicated in the context [22] of another earlier. It depends on the nature of what Page 94 [1] it occurs in, the final product that is being marketed, [2] its intended use, how ips going to be used, how much [3] is going to be used, who is going to use it, how big a [4] percent of it of the thing, how much of the composition [5] is it in the material. Is it based on its chemical and [6] physical properties, is it considered to be [7] particularly hazardous in handling or not. [8] So I think there are a variety of [9] considerations that would come up each time, and I [10] don't see that there is a fixed answer. At least I [11] would not respond there is a fixed answer. [12] Q. If you decided that Monsanto should test the [13] material for toxicity, would you kind of walk me [14] through what would be done with that material. Again, [15] we arc talking about the early 1970s. [16] MR. WALSH: Object to the question as broad, [17] vague and in the abstract. [18] But you can respond. [19] A. IPs been said somewhere earlier in discussion [20] that if we take over the concepts of what the product [21] is, how iPs intended and so forth we will determine [22] what kind of questions might arise from its handling. Page 95 [1] BY MR. FLORIG: [2] Q. Yes. [3] A. Then the experiments would be designed to [4] develop information that could answer those questions. [5] So it depends on what type of testing one [6] deemed necessary, what kind of tests would be designed [7] and would be conducted. [8] Q. Still talking about this material of unknown [9] toxicity, during your early years at Monsanto would [10] kind of a literature survey be done? [11] MR. WALSH: Same objection, vague, broad, in [12] the abstract. [13] A. The people who are working on the product [14] generally have an idea of what competing products or [15] the market they are entering, what the nature of the [16] products is in there. They have an idea of the [17] similarity or dissimilarity of their compounds to [18] existing compounds. [19] And they probably have as good an information [20] base, I would rely on information they supplied, at [21] least in the early years at Monsanto I would have [22] relied on the information they supplied me because they Page 96 [1] would be more familiar with the information than I [2] would be. [3] BY MR. FLORIG: [4] Q. How would they come into possession of that [5] information? [6] A. I do not know how they came into possession of [7] it. [8] Q. By this time had some kind of database or [9] computerized access to information about toxicity of [10] various chemicals been developed? [11] MR. WALSH: What do you mean by "this time," [12] can you specify a time? [13] MR. FLORIG: The early '70s. [14] MR. WALSH Thank you. [15] A. By whom7 [16] BY MR. FLORIG: [17] Q. By anyone. [18] A. Oh, there were databases being developed. I [19] can't be very precise, I can't precisely give you who [20] and when, what dates. But as computers became [21] available people began collecting data and databases, [22] yes. Page 97 [1] Q. If Monsanto in the early '70s >wd wanted to [2] look up the toxicity mformation of chemical X, could [3] they do that through some kind of database? [4] A. We have a library information services at [5] Monsanto. My choice would be to ask them to look up [6] the information. [7] Q. All right. [8] A. And whatever they returned to me I would then [9] look at. [10] Q. Would that include references to the [11] scientific literature? [12] A. It would depend on the nature of the request. [13] If I asked them for toxidty, and I could name you the [14] chemicals or classes of chemicals, I would get that [15] toxicity information related, the more specific the [16] question, the more likely you will get the information [17] you desire without a lot of scatter. [18] Whether they developed thisinformation from [19] manual searches or computerized searches I don't really [20] know. But their job was information services, and if I [21] had a question I would ask them to provide me with [22] input. Page 98 [1] Q. They could provide you with references to [2] other studies? [3] A. Yes. [4] Q. That had been done? [5] A. Depending what was available, either abstracts [6] with reference to the article or just a list of [7] references. [8] Q. Do you know if they could also provide you [9] with the article, itselp [10] A. We could obtain the articles, yes, if they [11] were not already available in the numerous journals [12] that the library subscribed to of its own right. [13] Q. Did that service also include foreign studies? [14] A. I would say it probably did. [15] Q. Was that service in place when you became [16] manager cf product development? [17] A. I assume it was, I don't know when it came [18] into service exactly. But I do know that when I had [19] questions and I asked them, they were responsive. [20] Q. Was that service administered through [21] Monsanto's library, did you say? [22]_______ A. I think it was the library information Page 99 [1] services, yes, it was a Monsanto people in a Monsanto [2] facility. [3] Q. Was it at headquarters, do you recall? [4] A. It was at St. Louis, the one I am referring [5] to. [6] Q. Going back to this unknown constituent of a [7] new product or a constituent that had unknown toxicity, [8] you mentioned thal you might develop some tests that [9] you would want done on that material, correct? [10] A. I don't think I indicated I would want to test [11] that material. If it were a component of a product I [12] might want to test the product containing that [13] component. I might in some cases want to go back and [14] test the component by itself. [15] Q. All right. [16] A. But it would depend again on a variety of [17] factors. [18] Q. As manager of product development what kind of [19] questions would you want those tests to address?, [20] A. I think I have indicated, when you look at the [21] anticipated use of the product and with some [22] imagination the reasonably foreseeable misuse, what * Page 100 [1] kind of issues, questions are likely to arise from 1 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 93 to Page 100 WATER PCB-SD0000068052 BSA ______________________________ Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992XMAX(16) [2] those circumstances and those are the questions one [3] would want to address. [4] Q Would one of the questions lx by what mtlrxcm [5] Co:oil the materd! possibly alter the body? [6] A. I think it was fairly general throughout the [7] industry that the acute hazards, what happened if you [8] spilled it on your skin, you got it on your fingers and [9] you licked your fingers, or you spilled it in your eye, [10] those were covered by proper labeling of the product. [11] If we had a component of ceramics and we [12] specifically said do not, you know, not for ingestion, [13] do not eat, or some phrasing of that sort, I don't [14] think I would expect that to be reasonably anticipated. [15] So I probably would not spend much time worrying about [16] repeated oral dosing, just as examples. [17] So it would depend as I say on what the nature [18] of the material is, how intends to use it, in the [19] course of using it what reasonable mistakes can we [20] make. [21] I see my associate, if I said don't drink it, [22] but I was going to use it, put it next to my coffee cup Page 101 [1] I think I would worry about it more than if you had it [2] out in a backyard for some reason in a cup. [3] Q. ]u$t so that I understand, if it were a liquid [4] that was deigned to be sprayed, you would likely look [5] at the three major pathways we talked about earlier, [6] correct? [7] A. I probably would, in most cases probably [8] would. [9] Q. If it were a solid, you probably wouldn't [10] worry so much about absorption through the skin, [11] correct? [12] A. Solids can be absorbed through the skin. [13] Q. Right, but that would not be as likely in your [14] view as a liquid being absorbed, correct? [15] Or, again, does it all depend on the specific [16] material? [17] A. In addition to the specific material I would [18] ask you what's the nature of your solid. [19] Q. Okay. [20] A. Is it a talcum powder or is it a brick? [21] Q. Fair enough. In any event, someone within [22] your unit would sit down and evaluate all these Page 102 [1] potential means by which it could get into the body, [2] correct, and decide which ones needed some study? [3] MR. WALSH; Objection, form. I think it's a [4] misstatement of the testimony. [5] A. I have indicated that I would want to know [6] what's available in terms of the product, its nature, [7] its use, et cetera, et cetera. And on the basis of [8] that my own judgment and experience, I would make [9] recommendations for testing if I deemed some was [10] necessary. [11] BY MR. FLORIG: [12] Q. Okay. [13] A. What others might do, I really cannot say. [14] Q. You also mentioned that you were as part of [15] the environmental assessment considering whether the [16] product could be disposed of safely, correct? [17] A. We considered what was the nature, what was [18] the ultimate disposition of the product. We took that [19] in as part of our assessment. [20] Q. How would yougo about studying that? [21] A. I would have to relyon what people tell me [22] what happens to the product when it's served its Page 103 [1] purpose. [2] Q. All right. [3] A. I feel if it was a component of cement I would [4] not worry about it. If it was a food additive and [5] somebody ate it, I would start worrying about it if I [6] was assured of the safety of it for being eaten. [7] So, again, it's hard to be general without [8] being specific about it, without specifics on a given [9] compound. [10] Q. One of uour examples is causing me some [11] confusion. You mcntwi an apple that is eaten. : [12] A. I didn't mention an apple. [13] Q. Somcthbig that was eaten. That had been, the ! [14] protluct had been used on that food and the food was j [15] eaten. | [16] Is that a use, or a disposal in your mind? | [17] A. If I had a packaging material that was i [18] regulated by FDA and it permitted some finite but small [19] level of contamination of a foodstuff and we were [20] making that chemical for that food contact, packaging [21] application, I would consider the final, the use of it [22] as in that packaging material. Page 104 [1] Q. Okay. [2] A. The ultimate fate of it is that that packaging [3] material, if it's locked in a carport, whatever it is, [4] it's going to be burned or landfilled, whatever, but [5] the amount of material that gets onto the foodstuff [6] that you eat, that is an ultimate fate. Once you have [7] eaten it, I don't expect to see it around anymore. [8] And if it is part of a packaging component, to [9] do its job as a packaging component it's got to stay in [10] the package. [11] So I would figure that is the ultimate fate of [12] it or final disposition of it, it gets locked into the [13] packing material and we are done with it. [14] Q. Did you consider at all how that packaging [15] material was disposed of, whether by landfill or [16] incineration or some other method? [17] A. I don't think anybody considered the specifics [18] on how it was disposed of, but if it's to be a - if it [19] serves a function, a useful function as packaging [20] material it will have to stay with the packaging [21] material to perform its function. [22]_______ Q. Even though some of it may get off into the Page 105 [1] food, itself, is it not serving its function if it [2] leaves the packaging material and gets on the food? [3] A. If it's a component of the packaging material, [4] its function is packaging material. [5] Q. Yes. [6] A. The amount that gets into the food is [7] incidental, or it should be incidental. And so if the [8] regulatory agencies have approved the packaging [9] material, they basically are saying it is not going to [10] get into the foodstuff. If it does get into the [11] foodstuff it's going to be such small amounts that it17s82 3 4 5 6 [12] not going to be a problem. [13] And they are basically saying, we agree with [14] you that it stays in the packaging. If it does not [15] stay in the packaging, we have a direct food additive [16] and we have a tremendous regulatory hurdle. [17] Q. A whole different settle of requirements? [18] A. Yes. [19] Q. And reporting? [20] A. Yes. [21] Q. All right. As manager of product development [221 wm Vou concerned in any way with disposal of Page 106 [1] Monsanto's toastes? [2] A. I don't recall that I had involvement at that [3] time with waste disposals. [4] Q. Did there come a time later when you did? [5] A. I suspect there were times when I was asked [6] questions about waste disposal, but I really cannot [7] recall the details and I would have to say for [8] practical purposes I was not very much involved in [9] waste disposal. [10] Q. What was your next position at Monsanto? [11] A. I became manager of environmental assessment [12] and toxicology. [13] Q. That was around 1973? [14] A. That would be about the time that I dropped [15] the title - end of '72, beginning of '73, probably. Page 100 to Page 106 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068053 BSA Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992 XMAX(17) [16] Q Here long did you hold that position? [17] A. Until about i960, 1982, probably. [18] Q. At which tone you became director of [19] cniiromncnta! assessment in toxicology? [20] A. That's right. It might have been a little [21] earlier, but the next step was director of [22] environmental assessment and toxicology. Page 107 [1] Q. Was there any difference in those two [2] positions? [3] A. For practical purposes, no. The staff that I [4] had working for me had increased; there were more [5] people involved. We had a larger testing program under [6] way. [7] Q. When you became director did someone step into [8] your old position as manager? [9] A. I had hired Dr. Fred Johansson, who basically [10] became manager at that time, yes. [11] Q. You became director sometime at the early [12] 1980s? ' [13] A. I guess it was about 1980. It might have been [14] a little earlier than that, I really don't recall [15] specifically. [16] Q. How long did you keep the position of [17] director? [18] A. Until 1986. [19] Q. What were your responsibilities as manager, [20] environmental assessment and toxicology. [21] A. By then we had developed a review of many of [22] the existing company products, we were involved in Page 108 [1] several new ventures, joint ventures with the [2] chemical - under the auspices of the Chemical [3] Manufacturers Association. We increased our testing [4] programs so we would run a fairly extensive testing [5] program. [6] Developing data on new products, increasing [7] the available data on existing products, largely to [8] reflect the public concepts of what constituted safety, [9] which has become increasingly larger definition, larger [10] scope. ' [11] We had undertaken to build a laboratory, do [12] some in-house testing. There were increasing [13] regulations dealing with chemicals, and we were [14] cooperating to some extent with the regulatory agendes [15] to help develop those regulations. [16] Q. As manager what kind of joint ventures or [17] studies were being conducted under the auspices of the [18] CMA? [19] A. The two that I spent the most time on and [20] probably most involvement were acrylonitrile and [21] styTene. [22] _____Q. Is that styrene monomer? Page 109 [1] A. Styrene, both monomers, acrylonitrile monomer [2] and styrene monomer. [3] Q. What did that joint venture consist op [4] A. Each was a separate one. [5] Q. Why don't we deal with the AN one, prst, [6] acrylonitrile. [7] A. In the early to mid '70s both, not both, [8] three, Dupont, Borg-Wamer and Monsanto were working on [9] an acrylonitrile-containing polymer for a soft drink [10] bottle. [11] There was a considerable database available on [12] acrylonitrile, though it was quite dated. [13] Acrylonitrile had been used and regulated fairly [14] widely, I think there was reasonable agreement on it. [15] Q. Excuse me, there was - [16] A. There was reasonable agreement among people on [17] the health risks. But because of the, this proposed [18] expanded use and as a food packaging material, we would [19] need additional data. [20] We made attempts to locate the background data [21] on some of the published abstracts, and those were not [22] available. There were published abstracts by Svirbely Page 110 [1] and Floyd. [2] So we met with a couple companies and [3] suggested we should pool our resources, expand and [4] develop an up-to-date database to reflect this greater [5] societal expansion of the definition of safety, what it [6] encompasses. And that it would probably be prudent for [7] us to get together and do this jointly, than each of us [8] should spin our wheels attempting to do it separately. [9] So that led to the formation of two [10] subcommittees or two committees under the CMA auspices, [11] one on acrylonitrile, one on styrene. These were [12] basically starting almost from scratch one. We looked [13] at the long-term effects, lifetime effects on rats, [14] six-month study in dogs, reproduction studies in rats, [15] some inhalation work in rats, some acute toxicity [16] studies. [17] About somewhat after we organized this the [18] Food and Drug Administration came out with a proposal [19] that they wanted to see an expanded database on [20] acrylonitrile because of the increased interest in [21] using these as food contact applications. [22] _____ We then met with representatives of the FDA Page 111 [1] and a host of Washington agencies, EPA, NIOSH, NCI, [2] OSHA. And we presented your program that we had agreed [3] on among the industry and under CMA auspices. And it [4] was not totally in agreement, but it was reasonably [5] close to FDA's proposal. [6] So we negotiated some changes in ours and [7] their demands, and we agreed on a proposal to studies [8] we would do and we would make the data publicly [9] available, then we proceeded to implement and develop [10] that data. [11] Q. Ultimately the bottle was not approved, [12] correct? [13] A. Technically the bottle was on sale. [14] Q. Okay. [15] A. I presume it was approved because it was being [16] used. [17] The Monsanto bottle was somewhat different [18] from the other two. When the studies being conducted [19] by Dow for the CMA group showed that acrylonitrile [20] produced tumors in rats, the project basically folded. [21] FDA, I think FDA revoked clearances or whatever [22] marketing permits were, whatever the basis was. That Page 112 [1] led to ultimate lawsuits. [2] Q. Was the Monsanto bottle ever used for [3] anything? [4] A. It was on the market for at least awhile in [5] some test cities. I don't know whether it had general [6] approval or limited marketing approval. I don't know [7] the details of that. [8] Q- You mentioned that early on in this project P] there was a database available on AN? [10] A. Yes. [11] Q. Correct? [12] A. Yes. [13] Q. And that there was reasonable agreement about [14] the toxicity of AN? [15] A. Yes. [16] Q. What was that agreement? [17] A. Acrylonitrile had been on the TOV list, I [18] won't say since the first one, but probably since the [19] first one. I think the TLV was unchanged up until the [20] time of the, that the questions arose regarding [21] carcinogenicity. Cyanamid had pulled together a [22] booklet. 1 2 3 4 5 6 Page 113 [1] Q. Cyanamid or Monsanto? [2] A. Cyanamid, in the '40s or '50s, 50s I guess, [3] that summarized, reviewed the literature on the [4] handling and hazards of acrylonitrile. [5] AsI indicated, there were the published [6] papers of Svirbely and Floyd from the Public Health ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 106 to Page 113 WATER PCB-SD0000068054 BSA Depo of: GEORGE I. LEVINSKAS Monsanto v Aetna December 22, 1992 XMAX(18) [7] Service who had published and said they did a lifetime [8] drinking water study in rats, as I recall as high as 50 [9] pans per million drinking water, for two years and [10] they had seen no cancers. Most everybody was aware of [11] this. [12] Q. Was that stiuiy by Svirbchj and Floyd,'did you [13] say? '' ' ' [14] A. S-v-i-r-b-e-l-y, and Floyd is F-l-o-y-d, I [15] think. [16] Q Do you hmo when their study ivas done? [17] A. Those studies were published in the Abstracts [18] of the Industrial Hygiene Association in the, I would [19] say probably in the early '60s, it might have been very [20] late '50s, '58 to '62, '63 interval, somewhere in [21] there. [22] Q, AM had a TLV or cquivalait value established Page 114 [1] for it back in the '40s or '50s, did you say? . [2] MR. WALSH: Object to the form, lack of [3] foundation. [4] A. I said I think it appeared on the original [5] list, the Warren Cook list. I think it appeared on [6] there, I am not positive of that. And I think the [7] numbers stayed basically unchanged up until this [8] question arose about the carcinogenicity. [9] BY MR. FLORIG: [10] Q. Since AN was on this TLV list, that means it [11] had some toxic properties associated with it? [12] A. Acrylonitrile - [13] Q. At the time it appeared, correct? [14] A. Yes. [15] Q. Do you recallwhat thosewere? [16] A. Acrylonitrile is a rather toxic material. I [17] don't - liquid acrylonitrile is very irritating to [18] skin, eyes. [19] It's flammable. One has to keep air [20] concentrations low because it bums readily, it [21] represents a fire hazard. And that of itself puts [22] restrictions on what you can do with acrylonitrile. Page 115 [1] Q. Did AN have any other toxic properties other [2] than being capable of producing skin irritation or eye [3] irritation that were known back in the '40s or '50s? [4] A. It is a, it will cause death in animals if [5] given by mouth. I mean you can dose an animal, I think [6] the published values in the literature are around 90 [7] milligrams per kilo, which means it's a toxic material. [8] But I don't think its a poison by the [9] statutory definition of a poison. Yes, it can kill [10] you. [11] MR. FLORIG: We have been going about an hour [12] and ten, do you want to take a break? [13] MR. WALSH Sure. [14] (Recess.) [15] MR. FLORIG: Back on the record. [16] BY MR. FLORIG: [17] Q. Dr. Levinskas, as you widerstand, you are [18] still under oath. [19] A. I do. [20] Q. Do you know when the joint study under CMA on [21] acrylonitrile was done, was that in the mid '70s? [22]_______ A. That program started in, I guess, about '74, Page 116 [1] '5, so the study probably was finished around '77, '8, [2] somewhere in there. [3] Q. You mentioned a second study done under the [4] aioc species of the CMA, and that was a styrene study, [5] correct? [6] A. Yes. It was somewhat analogous but not [7] identical with the acrylonitrile study. [8] Q. Can you tell me about the styrene study? [9] MR. WALSH Objection, vague. Can you be more [10] specific? [11] A. There was a program, there was more than one [12] study involved. [13] BY MR. FLORIG: [14] Q. Ccidd you teli me what the progr.vn was, first? [15] A. One was a lifetime rad exposure. It was 600 [16] and 1200 ppm, but I will be darned if I can recall [17] whether that was drinking water or inhalation. I think [18] it was inhalation. [19] MR. WALSH Remember, Dr. Levinskas, you don't [20] have to guess, okay? [21] THE WITNESS: I don't remember the route of [22] exposure. Page 117 [1] BYMR. FLORIG: [2] Q. Okay. [3] A. There was a short-term dog study, about six [4] months. I don't - can't dear the cobwebs. I really [5] hit a mental block on this right now. [6] Q. Let me ask you some specific questions, maybe [7] that will help. [8] IVos the styrene study done about the same time [9] o> the AN study we talked about? [10] A. Yes, about the same time. [11] Q. Again, that was under the CMA? [12] A. It was initiated by Dow Chemical Company, and [13] it was picked up and incorporated into the CMA program. [14] Q. Do you know what other companies besides Dow [15] and Monsanto were involved, if any? [16] A. Oh, there were probably eight or ten companies [17] involved, Dow, Monsanto and Borg-Wamer, Foster Grant. [18] There were others, but I am not sure I could - which [19] were on acrylonitrile or on this or on both. I really [20] can't be sure which were on which group. But there [21] were more companies, there were about six or ten [22] companies in total involved. Page 118 [1] Q- Was this studydesigned to determine if [2] styrene monomer was a carcinogen? [3] A. Yes. [4] Q. Was a styrene monomer also known to have a [5] TLV? [6] A. Yes. [7] Q- Was that known back at the time of the Cook [8] work that you referred to earlier? [9] A. I don't know whether it was on the Cook list, [10] but it had been on the list for quite sometime. [11] Q. Wien you say for quite sometime, do you know [12] if it had been on the list since the 1940s? [13] A. It had been on the list for some time, but I [14] can't recall when it made its first appearance. [15] Q. Do you know what the toxic effects of styrene [16] exposure were known to be? [17] MR. WALSH Objection. It's vague insofar as [18] the timeframe is involved. [19] MR. FLORIG: You are right. Let me rephrase [20] it. [21] BY MR. FLORIG: [22] _____Q. Was there a database available on styrene Page 119 [1] monomer prior to your starting the study, participating [2] in the CMA study? [3] A. Yes, there was information available. [4] Q. Was there also reasonable agreement on the [5] toxic properties of styrene at that time? [6] A. Since it was on a TLV list and that data was [7] available, I would feel that there was reasonable [8] agreement, yes. [9] Q. Prior to the CMA study, what was agreed about [10] the toxicity of styrene? [11] A. Styrene is also a reactive chemical, it's [12] flammable to some degree. It's a gas, or its [13] pressurized, mostly. And the air place, workplace [14] levels had been accepted or established by the TLV [15] Committee. [16] Other than its generally solvent and narcotic [17] action, I don't recall specifics. [18] Q. You mentioned that styrene was known to be [19] reactive. What does "reactive" mean? [20] A. It reacts with other chemicals and with Page 113 to Page 119 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068055 BSA Pepo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992_______________________ XMAX(19) [21] itself, that is how it makes polystyrene. [22] _____ Q. What did i/oii mean when you said it's known to Page 120 [1] be solvent? [2] A. It's a liquid, it will dissolve other [3] substances. [4] Q. Okay. [5] A. When it'spressurized it's a liquid. [6] Q. Was stymie also bimen to be a sldn and eye [7] irritant? [8] A. Yes. [9] Q. Was it biown to cause respiratory difficulty? [10] A. I don't recall that specifically, but it did [11] have a, an acceptable level set for its safety in the [12] workplace, air concentration. [13] Q. You mentioned the TLV Committee, and l may [14] iuwc missed this earlier. What was the TLV Committee? [15] A. The American Conference of Governmental [16] Industrial Hygienists published the TLV list, so the [17] TLV Committee is the group within it that reviews the [18] data, adds to or revises the numbers on that list. [19] Q. Do you htow when that committee came into [20] existence? [21] A. Not specifically, I don't recall the date. [22] ____ Q. Was it back in the 1940s or '50s, I am trying Page 121 [1] to get a feel for [2] A. It was subsequent to Dr. Cook's initial [3] publication which was mid '40s. It would have been [4] probably in the '50s, the TLV Committee. [5] Q. Was styrene determined to be carcinogenic as a [6] result of the CMA study? [7] A. The conclusion of the report was somewhat [8] unsatisfactory in that it was not a specific [9] conclusion. It indicated an increased incidence or [10] occurrence of leukemia in female rats with some [11] discussion as to the difficulty of reaching a [12] conclusion, and I believe also concluded on the note [13] that the study should be repeated. [14] Q. Was the study ever repeated, do you know? [15] A. Insofar as I know, it was not. [16] Q. Monsanto was a major producer of styrene at [17] the time of the study, is that correct? [18] A. Monsanto was a producer. I would not [19] characterize it as a major producer relative to the [20] other companies. [21] Q. Was Monsanto manufacturing styrene anyplace [22] other than Texas City, that you know of? Page 122 [1] A. I do not know where the manufacturing [2] facilities were. [3] Q. Do you know why the test or study was never [4] redone? [5] A. I cannot give a specific reason that I am [6] aware of. [7] Q. Do you know whether Monsanto conducted its own [8] study, subsequently? [9] A. Not on styrene. [10] Q. Why was the conclusion of the report mewed as [11] unsatisfactory? [12] A. I would say that when one does an experiment [13] to come up with an answer, if one concludes that I [14] can't draw a good conclusion and I must do it over [15] again, I would say that is unsatisfactory. [16] Q. Did you identify any particular problems with [17] the study that caused it to be inconclusive? [18] A. I am not aware from my knowledge of any [19] procedural or technical deficiencies or discrepancies [20] or details that would have concluded I think, the [21] response in animals was a weak one. It depends on how [22] the analysis was done, it was or was not statistically Page 123 [1] significant against different comparisons. It just was [2] not a significantly strong response to reach a definite [3] conclusion. [4] Q. When you were manager of environmental | PI assessment and toxicology at Monsanto did you have i [6] responsibility for all of the toxicity testing gomg on I [7] within Monsanto? i [8] A. Initially testing was being done by a variety [9] of people under a variety of circumstances. Dr. Hunt [10] was probably coordinating a fair part of it. After his [11] death, which was August I believe of '72, and it was [12] after that I got the title change of manager, [13] environmental assessment and toxicology, I was given [14] responsibility for toxicology testing. So [15] progressively we began to get more of a control, [16] direction, initiation of toxicity testing into the [17] Medical Department. [18] Q. All right. [19] A. At one time we probably were doing virtually [20] all the mammalian testing that was going on in the [21] company. [22]_______ Q. Was testmg for toxicity being done at any Page 124 [1] point that you were manager of waste streams from [2] various Monsanto plants? [3] A. We may have done some short-term tests, acute [4] toxicity tests on waste streams, I cannot specifically [5] recall. [6] Q. If they were being done, they would be done [7] withm your general area, though, correct? [8j A. No, I think I have indicated that prior to Dr. [9] Hunt's death I really was not involved in toxicity [10] testing. [11] Q. Right. [12] A. Subsequently we began getting more and more of [13] it centralized in the Medical Department. So it is [14] conceivable that it was being done at early stages by [15] somebody else or someone else in the company, I cannot [16] speak to that. [17] Q. The only testing you recall doing may have [18] teen some short-term testing of waste streams? [19] A. Yes, the stuff that I can recall was [20] relatively short-term testing. [2lj Q. Do you recall what plants the testing zoos [22]being done for? Page 125 [1] A. No, I do not. First, I did not personally [2] receive every sample that came in. [3] Secondly, samples generally came in with a, [4] you know, a code number or sample identity number or [5] something, and I would have no means of routinely [6j ascertaining or tracking back the specific plant site [7] from which it came. And I never made an effort to do [8j so. So I really cannot say. [9] Q. Do you recall ever determining whether a waste [10]stream from a Monsanto plant was toxic? [llj A. Again, without a definition or description of [12] toxic, or what are the criteria for using the term - [13] Q. Well, let's use the definition you gave me [14] earlier. [15] A. Well, if one is attempting to determine [16] whether a waste stream will kill or not kill aquatic [17] organisms such as fish, one can get a number analogous [18] to the LD 50, on rats, to go back to my two exam also [19] earlier of Malathion and Parathion. Parathion is a [20j statutory poison, Malathion is not. [21] Q. Right. [22]_______A. So in the sense that you may kill an animal or Page 126 [1] kill an aquatic organism with the waste it would [2] manifest toxicity. [3] But whether I would consider it a toxic [4] chemical would depend on the concentration before I [5] could do that. [6] Q. Do you recall ever determining whether a m concentration you have a Monsanto plant waste stream [8] was sufficient to kill organisms that may come in [9] contact with it? [lOj A. I think I have indicated that we may have run [llj some short-term tests and gotten results. But I don't ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 119 to Page 126 WATER PCB-SD0000068056 BSA Depo of: GEORGE J. LEVINSKA5 Monsanto v Aetna December 22, 1992 AMAAUUj [12] recall specific compounds, nor do 1 recall specific [13] results well enough to comment on them. [14] Q. Why were cn'.u short-term v.::, conducted? [15] A. On what? [16] Q. On plant waste streams. [17] MR. WALSH: Let me just note an objection. I [18] don't think that was the testimony. Unfortunately, [19] that is how it now sounds. [20] But you can respond if vou understand it. [21] BY MR. FLORIG: ' [22] ____ Q. Is there anything maccuratc in thequestion 1 Page 127 [1] asked you? [2] A. You have asked me earlier whether we worked on [3] tests of plant effluents. I have indicated, I believe, [4] that those that I might have been involved in would [5] have been short-term tests. In other and earlier [6] testimony I had indicated that other people were doing [7] testing at Monsanto, as well. And there could well [8] have been other longer term tests or different tests [9] being done by other people. [10] And so now the question as I understand it to [11] me is why are we only doing short-term tests with the [12] implication that short-term tests are the only tests [13] Monsanto has been doing on these wastes. I would I [14] guess - [15] MR. WALSH: Just to clarify the record, that [16] was the basis of my objection. [17] THE WITNESS: Yes, that I am talking about [18] what I was involved with and what I would have some [19] knowledge of. [20] By focusing on that it's not meant to make any [21] comments or statements about what the rest of Monsanto [22] might or might not have been doing, because I don't Page 128 [1] have spedfic knowledge. [2] BY MR. FLORIG: [3] Q. That is fine. [4] Do you have any personal knowledge of anyone [5] at Monsanto ever doing long-term tests of Monsanto [6] plant effluents? [7] A. I know that there was an environmental [8] sciences group that was concerned with environmental [9] effects of chemicals. The specifics of what they were [10] doing I am not in a position to comment, I don't know. [11] Q. You are familiar with some short-term tests of [12] plant effluents, is that correct? [13] A. I have indicated that among the many tests [14] that would have gone through my group that I could [15] consider responsible for could have included some [16] short-term tests. I do not recall that my group worked [17] on any extended tests. [18] Q. Okay. Those short-term tests, you don't know [19] what plants they came from, do you? [20] A. I am not sure that we did any and, no, I am [21] not sure what plants they came from. [22] Q, You don't know wlutt materials may have been Page 129 [1] tested, correct? [2] A. That's correct, I would not recall. If there [3] were such tests, I don't recall the materials. [4] Q. Do you recall during the period that you were [5] the manager of environmental assessment and technology [6] any tests being performed by Monsanto to determine m whether nwterials were hazardous or dangerous to [8] aquatic life? [9] A. I have indicated that there were other people [10] in Monsanto who were concerned with environmental [11] effects, and they could have done such studies. I do [12] not -- I do not recall any at this time. [13] Q. What is the environmental sciences group? [14] A. It's another group within Monsanto that is [15] concerned with the, I would say environmental effects [16] of chemicals, specifically what they do in the charter [17] I do not know. [18] Q. Was that group in existence when you footed [19] Monsanto? [20] A. There were people working in the areas of [21] environmental measurements and environmental effects. [22] What they were called and how they were structured 1 do Page 130 [1] not know, they were not part of the Medical Department. [2] I don't really know the organization structures, how [3] they evolved or changed with the years. [4] Q. Did they have their own laboratory? [5] A. Yes, they have facilities elsewhere at St. [6] Louis. [7] Q. In a different building from where you were? [8] A. Yes. [9] Q- Were they also conducting toxicity tests? [10] A. I have indicated I am not sure what they were [11] doing except they existed and they were working in that [12] general area. [13] But I don't recall specifics of what their [14] capabilities were or what they were doing. [15] Q. Do you recall ever exchanging any information [16] with them? [17] A. I am sure we talked back and forth on [18] occasion. But as I say, I do not have enough of a [19] detailed recollection to be sure what we talked about [20] or when. [21] Q. Do you recall if they ever asked your [22] department to perfonn am/ tests or studies? Page 131 [1] A. I have indicated that we may have done some [2] short-term tests, some of the requests may have come [3] from that group. At this time I can't recall. [4] Q. Do you recall the names of any of the people [5] working in the environmental sciences group? [6] A. Some come to mind. One was Scott Tucker. [7] Another was, I forget his first name, a fellow named [8] Keller. I think Rich Kimmerle was there at that time. [9] There were several chemists I met early when I came to [10] Monsanto whose names I can't recall and I didn't have [11] much contact with, but these three come to mind quite [12] readily. [13] Q. Do you know if one of them was the manager or [14] director of that group? [15] A. I don't know how, the structure of the company [16] at that time. [17] Q. While you were the manager of environmental [18] assessment and technology, was the actual testing of [19] materials performed on a contract basis? [20] MR. FLORIG: Strike that. [21] BYMR. FLORIG: [22]_______ Q. Did you use outside labs during that time? Page 132 [1] A. Yes. [2] Q. Did you do any testingin-house? [3] A. I don't know about the rest of the company, we [4] had no central testing laboratory. We did proceed to [5] build one which became operational about 1977. [6] Q. Was that built right on headquarters grounds, [7] or somewhere else? [8] A. It was built a few blocks from the Washington [9] University Medical School in St. Louis. [10] Q. That laboratory is Monsanto-owned? [11] A. It's a Monsanto-owned facility, yes. [12] Q. Prior to 1977 analysis and testing xoas [13] performed by outside laboratories? [14] A. As a chemical company Monsanto has always had [15] excellent and extensive analytical capabilities. How [16] much or to what extent they used outside laboratories I [17] do not know. [18] Q. I am talking just about your department. [19] A. With respect to animal toxicity testing. [20] Q. Okay. [21] A. Insofar as I know Monsanto had no in-house [22] capabilities prior to that. Page 133 [1] Q. So the outside laboratory was for animal [2] toxicity tests? Page 126 to Page 133 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068057 BSADepo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992XMAX(21) [3] A. Yes. [4] Q. If youwanted an animal toxicity test [5] verfonned prior to 1977. did you tel! the outside lab [6] what material you wanted tested? [7] A. Yes.' [8] Q. Did you tell them what lands of tests you [9] wanted performed? [10] A. Yes. [11] Q. What exposure patirway you wanted used? [12] A. That was part of the testprocedure, yes. [13] Q. The duration of the test, all those thittgs? [14] A. Yes. [15] Q. Would you issue tlumi some kind of written [16] instructions or protocol? [17] A. It would depend on - it would depend on the [18] laboratory at the time. But there would be agreement [19] on what was to be done and how it was to be performed [20] before the studies began. [21] Q. Proccdurally how would you be told or how [22] would you find out that there was a need to test a Page 134 [1] certain material? [2] A. There could be several different ways. Most [3] would probably originate with the operating unit [4] because they would have a proposed use, or they would [5] have a desire to do something with their material. It [6] might require regulatory approval. So one would take [7] note of the regulatory wishes. [8] There could be any external factor which would [9] raise a question and to whom the question occurred [10] might or might not filter back down somehow and prompt [11] a review of the situation. [12] Q. Would an external factor be perhaps a [13] complaint from someone who had come in contact with a [14] material? [15] A. I suppose that could be a stimulus, yes. [16] Q. Or a complaint that a material had allegedly [17] caused a fish kill? [18] A. I don't recall being approached with the, an [19] allegation that a fish kill had happened and, [20] therefore, we should do something about it, I don't [21] recall having that sort of situation brought to me. [22] _____Q. Would those external complaints or ex Monsanto Page 135 [1] complaints be the kinds of external factors you arc [2] thinking about? [3] MR. WALSH: Objection to the form of the [4] question, vague, confusing. [5] A. I guess the fact that a question is raised [6] about a chemical, there may be adequate information [7] available to understand and, you know, it may be that [8] the statement that something happened is well known and [9] it's almost to be expected under the conditions every [10] misuse or the accident which occurred. [11] So the fact that a question is raised of [12] itself does not necessarily mean that one has to crank [13] up and initiate a, an investigation. You know, one [14] takes that statement and considers it in what is known [15] and it may be a plausible, logical, understandable, [16] almost expected consequence of what happened, in which [17] case one would do nothing. [18] Or it may be that one would decide that one [19] should at least consider doing something further. So I [20] am not sure that there is a fixed answer. [21] BY MR. FLORIG: [22]_______ Q. Wlwt kinds of requests would you get from Page 136 [1] operating units to conduct toxicity testing? [2] A. I don't know that we received requests as such [3] for toxicity testing. [4] I will go back and make the comments I made [5] about the environmental assessment procedure. For [6] manageability purposes, when a new product or new use [7] came up of existing products, we would look at this and [8] make recommendations to the operating unit for the [9] kinds of testing that should be done to reassure : [10] ourselves that their proposed programs would be [11] acceptable, assuming that the data we developed would [12] support their aims. | [13] Later on we began a more general review of our ] [14] other products, existing products, on the basis that, [15] as I have indicated, the criteria, the definition of [16] safety had been expanded by the public at large to see [17] whether we should increase or strengthen, develop [18] further data on existing products. [19] So most of the time, and the [20] acrylonitrile/styrene programs would be an example of [21] this, we went back to the operating units and made a [22] suggestion to them that they should consider doing more Page 137 [1] work, which they in turn would have to fund. And they [2] did. [3] Again, there may have been some circumstances [4] when they came in and said we would like you to do [5] something for a specific reason, but I don't really [6] recall that they did this. They might have come in and [7] talked about the question, said we ought to do some [8] further studies or consider doing further studies. [9] Again, over the years with the number of [10] things that happened, they may have come in and asked [11] us to do a specific test, but I cannot specifically [12] recall it. [13] Q. Some of your testing was done to meet [14] regulatory requirements? [15] A. Yes. [16] Q. Would the request for those toxicity tests [17] come from the regulators, or initiate withm Monsanto? [18] A. No, they would come - [19] Let me add one possible qualification to what [20] I just said. If the pesticide people wanted to go for [21] a specific crop use they would have some idea of what [22] the regulations required to get that, the kinds of data Page 138 [1] that had to be submitted to support that registration. [2] So they might come in and say we need these tests [3] because we want to register compound X for use P. [4] The people who make the products, generally [5] they are quite familiar with what criteria, what [6] regulations if any exist regarding their products. And [7] so when they feel that they want to go for one of those [8] goals then we would begin discussions as to scheduling [9] tests, target dates, so forth to come up with those [10] data. [11] Q. Okay. Going back to the outside laboratories [12] that Monsanto used for animal toxicity testing prior to [13] 1977, do you recall the names of those labs? [14] A. Well, there are lots of laboratories that [15] Monsanto has used off and on. I am not sure I could [16] recall them all, I am not sure I am aware of them all. [17] We used an industrial. Industrial Bio Test [18] Laboratories. We used the Younger Laboratories. I [19] believe they had used in the past Hazelton [20] Laboratories, and there was a Shelanski Laboratories [21] that we were probably - those were probably the ones [22] being actively used about the time I joined the Page 139 [1] company. [2] Q. Did you stop using those laboratories when [3] Monsanto's laboratory was built? [4] A. No. [5] Q. Did you continue to use all four, even after [6] your own laboratory was built? [7] A. Industrial Bio Test Laboratories no longer [8] exists, so we know longer use it. [9] Our laboratory was designed to handle a [10] substantial portion, but not all of the toxicity [11] testing that we anticipated when it was built, so that [12] there was the intention we would always have some [13] outside work. [14] Q. Did you let the outside labs know why you [15] wanted particular materials tested or why you wanted [16] the tests that you requested performed? ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 133 to Page 139 WATER PCB-SD0000068058 BSA_______________________________ Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992_______________________ XMAX(22) [17] A. I don't know what the practice was prior to my [13] coming. In some cases we probably did, in others we [19] probably did not. [20] Q. Okry. [21] A. We would tell them what we knew about the [22] handling hazards so they could protect themselves and Page 140 [1] their personnel. [2] Q. Vial teas n uniform practice? [3] A. Yes. [4] Q. Did you ever tell the laboratories what kind [5] of results you would like to sec? [6] A. No. [7] Q. During the period that you were manager did [8] you have direct contact with regulatory agencies? [9] A. I had. some. [10] Q. Do you recall what those contacts were in [11] reference to? [12] A. Some were in connection with pesticide [13] registrations and some were dealing with the food and [14] drug administration regarding indirect food additives. [15] And there also were some dealing with the proposed [16] plastic soft drink bottle, which is basically food [17] additives. [18] Q. Your contacts with the regulators were limited [19] to pesticides and additives? [20] A. Most of it was that. There may have been a [21] few other contacts later on, but substantially those [22] are the two areas.__________________________ Page 141 [1] Q. Sometime in the late 1970's or early 1980s you [2] became director of environmental assessment and [3] toxicology, is that correct? [4] A. Yes. [5] Q. You stayed in that position until 1986? [6] A. Yes. ` [7] Q. Your duties were basicallythesame as those [8] of manager but with a somewhat larger staff? [9] A. I would say substantially that's correct. [10] Q. Did you pick up any additional duties as [11] director? [12] A. Not that I can recall. It just seemed an [13] intensification and enlargement of what we were doing. [14] Q. During the period you were director do you [15] recall any other joint ventures under the awe species [16] of the CMA? [17] A. Initially I was largely involved with, [18] personally involved with the acrylonitrile and styrene. [19] In later years I was less involved and others [20] participated. I am not sure whose auspices, CMA or [21] some other, but we have been involved in the [22] Chlorobenzene Producers Association, or people who Page 142 [1] worked for me were involved in the Chlorobenzene Users [2] Association. [3] We had a - I guess that's really the only [4] other big one I can recall. [5] Q. Do you remember any studies being conducted by [6] the Chlorobenzene Producers Association? [7] A. That is the reference I just made, [8] Chlorobenzene Producers Association, the testimony I [9] just said. [10] Q. Right. Do you recall any sttulies that they [11] did? [12] A. I was pretty much out of the toxicology [13] testing business at that time and I really don't recall [14] specifics on the studies that they were doing. [15] Q. Cldorobenzenc Producers Association is a trade [16] association? [17] A. It's a trade association, I am not sure under [18] whose auspices. Whether it's the Chemical [19] Manufacturers or some other trade association, I don't [20] recall. [21] Q. You don't recall Monsanto participating in any [22] studies in conjunction with that association? Page 143 [1] A. Right. I have indicated that I know Monsanto [2] participated in that group, it may still be a [3] participant since I left, I don't know. I do not i [4] specifically recall the kinds of testing they were | [5] engaged in, I was not directly involved. But I do know j [6] we did belong to it. ; [7] Q. What was your next job after being director of I [8] environmental assessment and toxicology? | [9] A. I was named thesenior toxicology consultant. | [10] Q. How long did youkeep that title? | [11] A. From the beginning of 1986 until I retired at [12] the end of September, 1991. [13] I did say '86, didn't I? [14] Q. Yes. [15] A. Yes, '86 to '91. [16] Q. What were your duties as senior toxicology [17] considtant? [18] A. At that time with structural reorganizations [19] the group I had headed was broken into two. One group [20] was transferred to the agricultural company on work on [21] pesticides, the other remained corporate to work on [22] industrial chemicals. My duties were, I must say, Page 144 [1] quite enjoyable personally. I had no administrative [2] responsibilities. [3] Q. That is always a nice touch. [4] A. I had no budgets to worry about. I was there [5] to act as a resource in terms of educating, assisting [6] the younger toxicologists. [7] I was attempting to keep these two separate [8] toxicology groups consistent, that they didn't start [9] going off in contradictory manners and so forth, since [10] we were talking judgments, to try to keep a [11] consistency. [12] Q. fust a second. Are you talking about a [13] consistency in procedures? [14] A. In procedures, in the way we look at things. [15] Q. Okay. [16] A. I wouldn't want two parts of Monsanto talking [17] out of its mouth in two different ways. And we would [18] keep posted so we would have a consensus as to how we [19] viewed things, and we expressed things, tried to use [20] language in a similar manner that we would be [21] consistent. [22]_______ And that if we got new information which Page 145 [1] caused us to change our thinking, that we should do [2] that consciously and that we all agreed we would make a [3] change in our thinking. [4] And since we also had inother areas of the [5] company a fair number of new people, it was as I say to [6] render what assistance I could to strengthen, to [7] reinforce, to educate people throughout the department. [8] MR. FLORIG; We have been going for an hour or [9] so, do you want to take another short break? [10] MR. WALSH- Sure. [11] (Recess.) [12] MR. FLORIG: Back on therecord. [13] BY MR. FLORIG: [14] Q. Dr. Levinskas, are youreceiving a pension [15] from Monsanto? [16] A. Yes. [17] Q. Can you explain to me the difference between [18] acute, subacute and chronic toxicity? [19] A. They are very general terms. I would refer to [20] acute as either single doses or would possibly include [21] a few doses over a short period of time. [22] Subacute in my definition would be anything of Page 146 [1] greater intensity than acute up to six months duration. [2] And I would then consider anything over sue [3] months duration as chronic. [4] Now those are again somewhat subjective, [5] others may not quite recognize those same limits. [6] Q. Generally, whether they use the same time [7] periods are not, those are terms that are understood . Page 139 to Page 146 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068059 BSA Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, bftl [8] :c:ir:n the industry, correct? [9] A. Right. " [10] Q. Subacute is a dose of greater intensity than [11] acute? [12] A. Mo, it's, the duration of dosing. [13] Q. Right. [14] A. It's a longer duration of dosing. [15] Q. Subacute refers to the time period, not the [16] dose level? [17] A. Right, the interval. [18] Q. Does a thorough toxicity evaluation of a [19] material include all three kinds of tests? [20] A. I guess it depends on how one wants to define [21] "thorough," what you mean by "thorough." I guess I [22] would say it could but it need not indude all three. Page 147 [1] Gf. Can you tell me in what circumstances it might [2] not include all three kinds of toxicity tests? [3] A. I would go back again to the concepts of use, [4] who was using it, how was he or she using it, what [5] levels are they using it at. [6] I think that, say some chemical with a very [7] minor use, casual, minor use, the definition of [8] thorough evaluation would be different than say a food [9] additive intended for wide scale consumption by large [10] segments of the population. [11] Q. Okay. [12] A. So that in some special cases or some [13] situations very little testing might be adequate, [14] sufficiently thorough to reassure one of the safe use [15] of the product, whereas in other cases that same amount [16] of testing would be quite inadequate. [17] Q. For an industrial worker working within a [18] chemical company withm a particular Operating unit [19] doing that week after week after week, would you want [20] to do all three kinds of toxicity tests for materials [21] that worker may be exposed to? [22] _____ A. I think I would go back to some variation of Page 148 [1] what I just said. There may be times when you would [2] want to; there may be times when it would not appear to [3] be necessary. [4] Q. If it was known that that worker was being [5] exposed to a chemical in some quantity during his or [6] her work, would you then run all three, want all three [7] kinds of tests to be done? [8] A. I think one would have to consider the [9] quantity, the frequency, the availability, [10] non-availability of protective equipment, a variety of [11] things. [12] I would go back. I do not see that there is a [13] single procedure or testing regimen that one says I [14] would always follow and this is what I would always [15] want to do and this is what I would always want to see [16] before I did something. I do not subscribe that that [17] is a necessary practice. [18] Q. What's the purpose of an acute toxicity study? [19] A. A major use of it is to provide labeling, [20] precautionary labeling for a product, raw material. It [21] is also used predictively of the effects, possible [22] potential effects of responses of a person exposed to Page 149 [1] relatively large doses. So that if a worker, lab [2] worker drops a bottle and it breaks, is it likely to be [3] a cause for serious alarm or something relatively [4] harmless. [5] But its single biggest use I would say is for [6] labeling of a product, which in turn conveys safety [7] information to the potential user. [8] Q. What's the purpose of a subacute toxicity [9] study? [10] A. IPs used to see if there are responses that [11] can occur from repeated exposures at considerably lower [12] doses in most cases that would not have manifested [13] themselves from a single exposure. [14] Q. And the purpose of a chronic toxicity study? i [15] A. I would say ips essentially a repetition of [16] what I said for subacute. IPs of longer duration, \ [17] again, of lesser intensity of exposure, lesser degree 1 [18] of exposure to see if there are other effects that have I [19] not been seen earlier. [20] Q. Have you beat employed since you retired from [21] Monsanto? [22] ______ A. I have been asked by two different people Page 150 [1] outside Monsanto to do a little bit of consulting work, [2] which I have elected to do. I am not actively seeking [3] consulting, and except for calls such as this from [4] Monsanto and the two companies I made reference, the [5] little bit of work I have done with, I have not been [6] employed. [7] Q. What's the nature of the consulting work you [8] are doing on those two jobs? [9] A. One is that they have a proposed food [10] additive, and I was asked to assist them in drafting [11] their petition reviewing some information form. [12] The other is a product liability case, and [13] because of work I had done years ago I have been asked [14] to testify to the toxicity of a material. [15] Q. What material is that? [16] A. It happens to be a chemical called [17] tetramethylsucdnotrile, [18] t-e-t-r-a-m-e-t-h-y-l-s-u-c-c-i-n-o-t-r-i-l-e. [19] Q. Are you still doing that consulting, or are [20] those jobs complete? [21] A. They are both in a hiatus now. They may be [22] complete, I may be called back on them later. I do not Page 151 [1] know at this time. [2] Q. You have been a member of a number of [3] professional societies throughout your career, correct? [4] A. Yes. [5] Q. From your resume l will just read several of [6] them and you can tell me what your participation is in [7] those societies. [8] What is the Society of Toxicology? [9] A. That was organized in 1961. Until then [10] toxicology had been a more generalized part as I have [11] indicated of the occupational medicine, occupational [12] health background. [13] There were people who decided that we should [14] have our own society. It was organized in 1961, and I [15] was one of a hundred or so charter members. [16] Q. Was anyone from Monsanto a member of that [17] society? [18] A. The late Dr. Hunt was a member of it. [19] Q- Was he also a charter member? [20] A. I can't swear to it, but he may have been. [21] Q. Have you held any officerships or leadership [22L positions within that society? Page 152 [1] A. I am a member of several committees throughout [2] the years. There was a not too well named Toxicology [3] Committee at one time, and there was a Technical [4] Committee and a Membership Committee that I have served [5] on. And I have been chairman of the latter two, the [6] Membership Committee and the Technical Committee. [7] Q. Does tlwt society issue any publications? [8] A. It sponsors two. One is Toxicology and [9] Applied Pharmacology, and the other is Fundamental and [10] Applied Toxicology. Those are regular periodicals. [11] It does issue abstracts for its annual [12] meetings under, I believe they are in a separate [13] monograph referred to as The Toxicologist. [14] Q. Those abstracts discuss particular chemicals [15] or compounds? [16] A. They are studies which may deal with chemicals [17] or with procedures, in some cases even with regulatory [18] issues. [19] Q. Has any of your work ever been published in [20] any of those publications? [21] A. I believe I have a paper or more in each of ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 146 to Page 152 WATER PCB-SD0000068060 BSA Depo of: GEORGE J. LBVINSKAS Monsanto v Aetna December lL, lyv/ AJVLAA(Z4) [221 those. Page 153 [11 O. Do vott recall 'dial the tones were for these [2] papers? [3] A. I can't recall specifically which journals and [4] which topics, but some of those would probably go back [5] to my days at, probably started when I was at the [6] University of Pittsburgh, over the years. [7] Q. You were a member of the American Industrial [8] Hygiene Association? [9] A. Yes. [10] Q. Do you knou' when you became a member of that [11] organization? [12] A. Probably about 1955. [13] Q. What kind of issues is that association [14] involved with? [15] A. At that time that was basically the technical [16] society, or the professional society for people with an [17] interest in occupational health. It consisted of [18] hygienists, physicians, toxicologists, health [19] physicists, ergonomics. [20] Q. Did you stay a member of that association [21] until youretired fromMonsanto? [22] A. Yes. Page 154 [1] Q. Is the same true for the society of [2] toxicology? [3] A. Yes. [4] Q. Other thanyourself, was anyone from Monsanto [5] a member of the American Industrial Hygiene [6] Association? [7] A. Mr. Wheeler is a past president of the [8] association. I believe Jack Garrett has been a long [9] time member. Several of the more recent additions at [10] Monsanto would be members. [11] Q. Did you hold any positions of leadership [12] withm that organization? [13] A. I was chairman of the Pittsburgh section of [14] the national society, and I have served as a member of [15] its Technical Committee, of its Hygienic Guides [16] Committee. And I think I was on its education, I think [17] that is the one I was on the Education Committee for [18] awhile. [19] Q. Does that association issue any publications? [20] A. Yes, I made reference earlier to the American [21] Industrial Hygiene Association Quarterly, which has [22] been changed to the Journal of Industrial Hygiene. It Page 155 [1] also publishes several monographs dealing with [2] different phases of industrial hygiene and assorted [3] pamphlets and booklets. [4] Q. Did they also publish abstracts? [5] A. They publish abstracts in connection with [6] their annual meeting, the presentations for the annual [7] meetings. [8] Virtually every article published in their [9] journals does have an abstract early on, at the [10] beginning of the published article. [11] Q. When did you become a member of the American [12] Chemical Society? [13] A. Probably 1950 or '51. It was after I finished [14] college, before I left graduate school. [15] Q. Did you remain a member of that society until [16] you retired from Monsanto? [17] A. Yes. [18] Q. Did youhold anyleadership positions withbt [19] that society? [20] A. I was on the board of directors and I was the [21] chairman of the Trenton, New Jersey, section of the [22] society. Page 156 [1] Q. That'snot an organization specifically [2] concerned with toxicology or industrial hygiene, is it? [3] A. No. [4] Q. What prompted your membership in that society? [5] A. I think I indicated at the beginning that, as [6] a major in chemistry, the courses we took were, the [7] course I took was adequate to be certified as a chemist [8] by the American Chemical Society. Having successfully [9] completed that course, having been given a certificate ; [10] saying I was a, quote, knowledgeable chemist, it was j [11] among the earliest of the professional societies that I | [12] decided to join. ! [13] Q. Were you active in the society? j [14] A. With the exception of local affairs such as I j [15] have made reference to the Trenton section, I was not [16] active beyond the local section. [17] Q. Does the American Chemical Society issue any [18] publications? [19] A. Several. [20] Q. Do you remember if any articles or abstracts [21] concerning toxicity have been published in their [22] publications?_______________________________________________ Page 157 [1] A. I cannot recall specific articles that are [2] published in that. They tend to be more heavily [3] weighted towards chemistry. There could be toxicology [4] data, but I do not recall. [5] Q. Have you ever been published in their [6] publications? [7] A. No. [8] Q. You were a member of the Manufacturing [9] Chemists Association? [10] A. I served on several of its committees and task [11] forces. [12] Q. Those task force, were conducting or [13] supervising toxicity testing of bulk chemicals? [14] A. We made reference earlier to the acrylonitrile [15] and styrene task forces. [16] Q. Yes. [17] A. Those are two specific ones that were under [18] CMA auspices. [19] Q. The Manufacturing Chemists Association, is [20] that the same thing as the Chemical Manufacturers [21] Association? [22] ______ A. Yes, the - MCA, Manufacturing Chemists_____ Page 158 [1] Association was the earlier title. [2] Q. Thank you. [3] A. Currently some timeback they changed their [4] name to the current title, Chemical Manufacturers [5] Association. ' [6] Q. That straightens that out and reduces a few [7] questions. [8] (Pause.) [9] MR. FLORIG: Why don't we break for the day [10] and pick up at 9:30 tomorrow morning. [11] (Whereupon, the depositionwas recessed for [12] the day at 4:05 p.m., to resume at 9:30 a.m. the [13] following day, Wednesday, December 23, 1992.) [14] [15] [16] [17] [18] [19] [20] [21] [22]___________________________________________________________ Page 159 [1] ACKNOWLEDGMENT OF DEPONENT [2] I, GEORGE J. LEVINSKAS, hereby acknowledge that I [3] have read and examined the foregoing pages of my [4] deposition and that: [5] (Check appropriate box.) [6] () the same is a true, correct and complete [7] transcription of the answers given by me to [8] the questions therein recorded. [9] ( ) except for the changes noted in the attached [10] Errata Sheet, the same is a true, correct and [11] complete transcription of the answers given [12] by me to the questions therein recorded. Page 152 to Page 159 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068061 BSADepo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992 [13] [14] Date Signature of Witness [15] Subscribed to and sworn before me. [16] this day of , 19 [17] ' [18] Notary public in and for the [19] My commission expires: [20] [21] [22] Page 160 [1] Certificate of Reporter ) [2] United States of America ) ss. [3] District of Columbia ) [4] I, CRAIG L. KNOWLES, the officer before whom [5] the foregoing deposition was taken, do hereby certify [6] that the witness whose testimony appears in the [7] foregoing deposition was duly sworn by me; that the [8] testimony of said witness was taken by me to the best [9] of my ability' and thereafter reduced to print under my [10] direction; that I am neither counsel for, related to, [11] nor employed by any of the parties to the action in [12] which this deposition was taken and, further, that I am [13] neither a relative nor an employee of any attorney or [14] counsel employed by the parties thereto nor financially [15] or otherwise interested in the outcome of this action. [16] Witness my hand this 25th day of December, 1992. rit] [18] Notary' Public in and for [19] the District of Columbia. [20] My Commission Expires October 31, 1994: [21] [22] ; ; ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 159 to Page 160 WATER PCB-SD0000068062 BSA Look-See Concordance Report 2,277 UNIQUE WORDS 386 NOISE WORDS 24,444 TOTAL WORDS SINGLE FILE CONCORDANCE CASE SENSITIVE WORD RANGES 6 BOTTOM OF PAGE -1- 1 [1] 76:10 10:00 [1] 1:18 1200 [1] 116:16 1201 [1] 1:18 12:15 [1] 76:12 1358 [1] 37:14 1776 [1] 2:16 18999 [1] 2:5 19 [1] 159:16 19103 [1] 2:11 19358 [1] 58:3 1940s [3] 71:7; 118:12; 120:22 1943 [1] 70:2 1949 [1] 7:17 1950 [1] 155:13 1951 [1] 40:4 1953 [1] 8:16 1955 [1] 153:12 1958 [7] 20:19; 34:20; 35:12; 36:20; 37:5; 38:22; 45:10 1961 [3] 26:3; 151:9, 14 1970 [1] 141:1 1970s [1] 94:15 1971 [5] 45:13; 78:10; 79:18; 80:16; 83:5 1972 [1] 84:15 1973 [1] 106:13 1977 [4] 132:5, 12; 133:5; 138:13 1980 [2] 106:17; 107:13 1980s [2] 107:12; 141:1 1982 [1] 106:17 1986 [3] 107:18; 141:5; 143:11 1991 [1] 143:12 1992 [3] 1:13; 158:13; 160:16 1994 [1] 160:20 1:15 [1] 76:12 1:23 [1] 77:2 -2- 2 [1] 69:1 20006 [1] 2:17 2005 [1] 2:10 21st [1] 1:17 22 [1] 1:13 23 [1] 158:13 2386 [5] 28:6; 31:19, 20; 32:8; 34:10 25th [1] 160:16 -3- 3 [1] 69:1 31 [1] 160:20 350 [1] 2:4 37th [1] 2:9 -4- 4 [1] 69:1 Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992__________________ LooK-3ee(z/; 40s [4] 113:2; 114:1; 115:3; 121:3 45 [1] 70:2 4:05 [1] 158:12 -5- 5 [3] 3:5; 69:1; 116:1 50 [2] 113:8; 125:18 50s [7] 113:2, 20; 114:1; 115:3; 120:22; 121:4 51 [1] 155:13 526 [1] 5:5 56 [1] 39:8 58 [2] 45:11; 113:20 59 [1] 45:11 -6- 600 [1] 116:15 60s [2] 54:21; 113:19 61 [1] 26:4 62 [1] 113:20 63 [1] 113:20 63141 [1] 5:6 -7- 7 [1] 39:8 70s [5] 92:10; 96:13; 97:1; 109:7; 115:21 71 [1] 79:5 72 [3] 84:16; 106:15; 123:11 73 [3] 84:15, 16; 106:15 74 [1] 115:22 77 [2] 3:11; 116:1 -8- 8 [2] 39:8; 116:1 86 [2] 143:13, 15 88C-JA-118-1-CV [1] 1:7 -9- 9 [1] 39:8 90 [1] 115:6 90-day [2] 61:13; 68:14 91 [1] 143:15 9:30 [2] 158:10, 12 -A- A-p-e-t-i-t-e [1] 13:15 a.m. [2] 1:18; 158:12 AB [1] 7:15 ability [3] 5:8; 47:19; 160:9 able [2] 26:12; 41:15 abreast [1] 33:2 absorb [1] 56:13 absorbed [2] 101:12, 14 absorption [9] 56:14; 57:12; 62:5, 9, 11, 12; 63:3; 101:10 abstract [3] 94:17; 95:12; 155:9 Abstracts [1] 113:17 abstracts [9] 39:17; 98:5; 109:21, 22; 152:11, 14; 155:4, 5; 156:20 academic [1] 12:9 accept [1] 82:13 acceptable [3] 86:18; 120:11; 136:11 accepted [2] 23:16; 119:14 access [1] 96:9 accident [1] 135:10 accidental [2] 19:12; 66:13 accidents [1] 66:11 accommodate [1] 4:16 Accostrength [3] 28:5; : 31:19; 32:13 account [1] 86:22 ; acetate [1] 28:2 : achievable [2] 90:16, 17 I add [1] 63:19 j acknowledge [1] 159:2 ACKNOWLEDGMENT [1] 159:1 Acrylonitrile [4] 109:13; 112:17; 114:12, 16 acrylonitrile [17] 6:5; 108:20; 109:1, 6, 12; 110:11, 20; 111:19; 113:4; 114:17, 22; 115:21; 116:7; 117:19; 136:20; 141:18; 157:14 acrylonitrile-containing [1] 109:9 Act [1] 88:6 act [3] 88:6, 8; 144:5 action [3] 119:17; 160:11, 15 active [3] 14:9; 156:13, 16 actively [3] 32:5; 138:22; 150:2 activities [1] 73:18 actual [2] 63:20; 131:18 acute [8] 100:7; 110:15; 124:3; 145:18, 20; 146:1, 11; 148:18 add [1] 137:19 addition [3] 12:1; 19:18; 101:17 additional [6] 30:18, 20; 50:11; 85:15; 109:19; 141:10 additions [1] 154:9 additive [4] 103:4; 105:15; 147:9; 150:10 additives [3] 140:14, 17, 19 address [4] 5:4; 33:11; 99:19; 100:3 adds [1] 120:18 adequate [4] 53:16; 135:6; 147:13; 156:7 adequately [1] 26:12 administered [2] 62:16; 98:20 Administration [3] 57:22; 68:4; 110:18 administration [1] 140:14 administrative [1] 144:1 advanced [2] 8:5; 9:3 Adverse [1] 21:7 adverse [12] 9:14; 21:6, 8, 10, 15, 19, 20; 22:1; 24:9; 25:4; 29:11; 51:2 AETNA [1] 1:8 affahs [1] 156:14 AFTERNOON [2] 3:11; 77:1 afternoon [1] 6:14 agencies [8] 18:19; 46:9; 56:4; 57:17; 105:8; 108:14; 111:1; 140:8 Agency [1] 30:7 agree [3] 21:14; 24:11; 105:13 agreed [5] 82:13; 111:2, 7; 119:9; 145:2 agreement [9] 1:16; 109:14, 16; 111:4; 112:13, 16; 119:4, 8; 133:18 agricultural [4] 27:7; 48:19; 49:4; 143:20 Agriculture [2] 58:5, 7 aimed [1] 30:9 aims [1] 136:12 air [3] 114:19; 119:13; 120:12 al [1] 1:9 alarm [1] 149:3 alert [1] 19:9 allegation [1] 134:19 allegedly [1] 134:16 allow [1] 77:14 allowed [1] 20:4 alternative [1] 55:19 America [1] 160:2 American [36] 8:3; 25:16, 22; 26:5; 27:5; 29:22; 30:3, 14; 31:7; 33:7, 15, 18; 34:21; 39:4, 6; 40:15, 17; 41:18; 44:20; 45:14; 46:11; 47:2; 48:6, 9, 16; 51:10; 59:2; 68:18; 82:1; 120:15; 153:7; 154:5, 20; 155:11; 156:8, 17 amount [6] 8:6; 19:17; 93:6; 104:5; 105:6; 147:15 amounts [2] 77:22; 105:11 analogous [2] 116:6; 125:17 analysis [2] 122:22; 132:12 analytical [4] 8:4, 5; 90:18; 132:15 analyzing [1] 90:8 Anderson [1] 2:3 anecdotal [1] 92:19 animal [20] 23:13; 30:10; 60:15; 62:8, 13, 17; 66:3, 9, 14, 16, 20; 67:22; 68:7, 12; 115:5; 125:22; 132:19; 133:1, 4; 138:12 animals [9] 18:1, 7; 32:2; 51:6; 60:19; 62:22; 63:2; 115:4; 122:21 annual [3] 152:11; 155:6 answer [13] 4:21; 5:8; 35:5; 47:13; 48:11; 54:2; 77:18; 80:8; 94:10, 11; 95:4; 122:13; 135:20 answered [1] 24:15 answers [2] 159:7, 11 anticipate [5] 19:11; 85:9, 16; 88:15; 89:1 anticipated [5] 60:17; 67:21; 99:21; 100:14; 139:11 anybody [2] 81:12; 104:17 anymore [1] 104:7 anyplace [1] 121:21 anywhere [1] 62:3 appear [2] 60:6; 148:2 appearance [1] 118:14 APPEARANCES [1] 2:1 appeared [3] 114:4, 5, 13 appears [1] 160:6 apple [2] 103:11, 12 application [3] 46:18; 58:8; 103:21 applications [1] 110:21 Applied [2] 152:9, 10 applied [10] 16:7, 8, 15, 19; 20:9; 58:11, 13, 14; 64:14; 68:11 apply [1] 91:22 applying [1] 83:8 approached [1] 134:18 appropriate [2] 53:7; 159:5 approval [4] 57:21; 112:6; 134:6 approved [5] 30:6; 50:16; 105:8; 111:11, 15 aquatic [5] 18:1; 55:11; 125:16; 126:1; 129:8 area [3] 54:22; 124:7; 130:12 areas [8] 8:22; 9:5; 17:12, 19; 40:10; 129:20; 140:22; 145:4 arise [4] 85:10; 94:22; 100:1 arisen [1] 54:5 armed [2] 18:13, 22 Army [1] 14:22 Arnold [1] 68:4 arose [2] 112:20; 114:8 arrived [2] 30:5, 13 art [1] 90:18 article [10] 43:12; 44:15, 16; 70:21, 22; 72:5; 98:6, 9; 155:8, 10 articles [6] 12:3; 39:17; 43:8; 98:10; 156:20; 157:1 ascertaining [1] 125:6 asking [3] 4:14; 59:11, 13 aspect [1] 66:20 aspects [1] 87:9 assemble [1] 53:5 assess [3] 85:19; 86:19; 92:21 assessment [17] 83:12; 86:3, 4, 13; 102:15, 19; 106:11, 19, 22; 107:20; 123:5, 13; 129:5; 131:18; 136:5; 141:2; 143:8 assessments [2] 84:8; 85:2 assist [1] 150:10 assistance [1] 145:6 assisted [2] 15:12; 18:17 assisting [1] 144:5 associate [1] 100:21 associated [2] 36:2; 114:11 Association [18] 39:5; 73:19; 82:2; 108:3; 113:18; 141:22; 142:2, 6, 8, 15; 153:8; 154:6, 21; 157:9, 19, 21; 158:1, 5 association [10] 73:18; 74:15; 142:16, 17, 19, 22; 153:13, 20; 154:8, 19 associations [3] 74:11; 81:20, 22 assorted [1] 155:2 assume [6] 62:14; 66:7, 9; 78:18; 79:12; 98:17 assumed [1] 46:1 assumes [1] 67:6 assuming [1] 136:11 assumptions [1] 66:7 assured [1] 103:6 astute [1] 90:7 ate [1] 103:5 Atomic [1] 18:18 attached [1] 159:9 attachments [1] 9:19 attempt [5] 33:2; 43:15; 49:15; 66:13 attempting [5] 19:8; 92:20; 110:8; 125:15; 144:7 attempts [2] 14:6; 109:20 attendance [1] 24:5 attending [1] 19:9 attorney [2] 41:11; 160:13 From 1 to attorney WATER PCB-SD0000068063 _______- j. Li.u.wi^Lj iTiuu3<iiUu v1 ,-i^uta L/ecemoer zz, iyyz LooK-5ee(28) attribute [1] 62:11 attributed [2] 17:18; 62:8 August [1] 123:11 auspices [7] 108:2, 17; 110:10; 111:3; 141:20; 142:18; 157:18 Austin [1] 1:17 authors [2] 11:8, 14 availability [1] 148:9 available [21] 36:18; 37:14; 38:10, 14; 40:14, 17; 85:14; 89:3; 96:21; 98:5, 11; 102:6; 108:7; 109:11, 22; 111:9; 112:9; 118:22; 119:3, 7; 135:7 avoid [2] 36:15; 80:10 award [1] 13:5 awards [2] 12:9; 13:1 aware [10] 33:10, 22; 40:6; 42:8; 43:4; 61:16; 113:10; 122:6, 18; 138:16 awe [2] 116:4; 141:15 awhile [2] 112:4; 154:18 -B- bachelor [2] 7:10; 44:6 background [3] 7:9; 109:20; 151:12 backyard [1] 101:2 badness [1] 84:3 bandied [1] 86:15 base [1] 95:20 Based [2] 78:9; 79:4 based [7] 27:8; 48:22; 61:3, 5, 6; 79:18; 94:5 Basic [1] 15:11 basic [2] 14:3; 15:19 Basically [6] 8:2; 9:12; 13:6; 16:7; 28:15; 46:2 basically [16] 18:6; 30:19; 31:11; 34:15; 56:14; 60:14; 92:16; 105:9, 13; 107:9; 110:12; 111:20; 114:7; 140:16; 141:7; 153:15 Basis [1] 11:17 basis [8] 67:11; 79:12; 83:13; 102:7; 111:22; 127:16; 131:19; 136:14 bathes [1] 14:11 becoming [1] 51:17 bedside [1] 38:3 behalf [4] 1:19; 2:6, 12, 18 behavior [2] 62:22; 63:1 beings [2] 17:22; 79:20 believe [8] 6:6; 121:12; 123:11; 127:3; 138:19; 152:12, 21; 154:8 belong [1] 143:6 beneath [2] 56:18; 57:11 beneficial [6] 21:9, 13; 22:9; 25:1, 10; 54:18 benzoyl [1] 6:6 besides [2] 56:21; 117:14 Beta [1] 12:19 bibles [1] 38:3 biggest [1] 149:5 Bill [2] 81:17, 19 billion [2] 60:3, 5 Bio [2] 138:17; 139:7 biochemical [1] 9:20 Biochemistry [2] 8:19; 10:10 biochemistry [4] 9:2; 10:9; 11:21, 22 biological [4] 9:13, 20; 10:12; 25:9 biphenyls [1] 6:5 bit [7] 49:2; 55:1; 70:8; 75:8; 77:8; 150:1, 5 block [1] 117:5 blocks [1] 132:8 blue [1] 62:13 board [1] 155:20 : body [13] 9:18; 10:1; i 17:3, 14; 55:7, 11, 20; ! 56:13; 57:1, 7, 12; 100:5; j 102:1 ! bone [5] 13:20; 14:4, 9, I 11; 43:13 book [3] 11:16; 39:22; 70:20 booklet [1] 112:22 booklets [1] 155:3 books [2] 38:2; 44:14 Borg-Warner [2] 109:8; 117:17 Boston [1] 54:22 bottle [7] 109:10; 111:11, 13, 17; 112:2; 140:16; 149:2 bounced [1] 70:7 box [1] 159:5 break [7] 40:22; 41:4; 58:16; 76:6; 115:12; 145:9; 158:9 breaking [2] 22:12, 18 breaks [1] 149:2 brick [1] 101:20 brief [1] 34:13 briefly [2] 6:14; 42:19 broad [7] 27:8; 48:22; 59:10; 79:22; 83:10; 94:16; 95:11 broader [1] 18:5 broadly [1] 20:9 broke [1] 22:4 broken [1] 143:19 brown [1] 19:4 BS [1] 7:14 budgets [1] 144:4 build [2] 108:11; 132:5 Building [1] 2:4 building [1] 130:7 built [5] 132:6, 8; 139:3, 6, 11 bulk [3] 48:9, 13; 157:13 burned [1] 104:4 bums [2] 29:8; 114:20 business [1] 142:13 byproducts [1] 47:12 -C- C-l-90-492 [1] 1:8 C-o-o-k [1] 70:4 CA [1] 1:7 call [6] 16:12; 22:4; 25:8; 47:6; 56:11; 71:4 calls [4] 35:3; 64:22; 79:7; 150:3 cancer [1] 17:4 cancers [1] 113:10 capabilities [4] 54:10; 130:14; 132:15, 22 capability [1] 90:19 capable [1] 115:2 carcinogen [3] 28:18; 30:10; 118:2 carcinogenic [3] 31:4; 32:1; 121:5 carcinogenicity [2] 112:21; 114:8 carcinogenistic [1] 28:18 career [6] 22:21; 25:22; 40:15; 48:5; 77:20; 151:3 carport [1] 104:3 carry [2] 13:22; 38:13 case [4] 35:15; 65:12; 135:17; 150:12 cases [13] 5:20; 44:6; 60:14; 62:6, 7; 63:3; 99:13; 101:7; 139:18; i 147:12, 15; 149:12; ; 152:17 I CASTLE [1] 1:3 j casual [1] 147:7 J CASUALTY [1] 1:8 J category [1] 49:8 j caused [5] 29:12; 53:20; 122:17; 134:17; 145:1 cavity [1] 57:13 cement [1] 103:3 central [1] 132:4 centralize [1] 84:8 centralized [1] 124:13 ceramics [1] 100:11 Certificate [1] 160:1 certificate [1] 156:9 certification [1] 8:2 certified [1] 156:7 certify [1] 160:5 cetera [2] 102:7 chairman [3] 152:5; 154:13; 155:21 chance [1] 85:19 change [3] 123:12; 145:1, 3 changed [4] 39:2; 130:3; 154:22; 158:3 changes [6] 39:13; 53:17; 63:1; 90:19; 111:6; 159:9 changing [1] 85:4 characterization [1] 86:16 characterize [2] 86:12; 121:19 charge [1] 84:9 charter [3] 129:16; 151:15, 19 Check [1] 159:5 check [2] 39:18; 91:9 checked [1] 38:4 checking [1] 37:8 Chemical [10] 8:3; 73:19; 108:2; 117:12; 142:18; 155:12; 156:8, 17; 157:20; 158:4 chemical [36] 10:10, 11; 25:10; 27:9; 34:21; 43:3; 49:10, 15; 53:17; 58:9, 10; 59:12, 16; 62:7; 72:21; 73:8, 11, 21; 74:2, 18; 78:9; 83:9, 17, 19; 94:5; 97:2; 103:20; 108:2; 119:11; 126:4; 132:14; 135:6; 147:6, 18; 148:5; 150:16 chemicals [38] 14:10; 17:6, 17, 22; 19:6; 20:10, 11; 23:11; 27:8, 11; 28:15; 33:18, 21; 37:6; 42:22; 48:9, 13; 49:6; 54:17, 18; 58:1; 72:20, 22; 73:3; 75:13; 80:6; 85:7; 96:10; 97:14; 108:13; 119:20; 128:9; 129:16; 143:22; 152:14, 16; 157:13 chemist [3] 90:7; 156:7, 10 Chemistry [1] 11:20 chemistry [12] 7:10, 14, 18; 8:1, 3, 4, 5; 13:19; 14:22; 156:6; 157:3 Chemists [3] 157:9, 19, 22 chemists [1] 131:9 chief [2] 45:1, 6 chlorides [1] 6:6 Chlorobenzene [5] 141:22; 142:1, 6, 8, 15 chloroform [2] 20:14, 16 choice [1] 97:5 cholinesterase [1] 50:15 chronic [3] 145:18; 146:3; 149:14 Circle [1] 5:5 I circumstances [5] 92:1; 100:2; 123:9; 137:3; 147:1 cited [1] 38:15 cities [1] 112:5 City [1] 121:22 CL [1] 49:12 clarify [1] 127:15 class [4] 15:5; 19:4; 50:14, 18 classes [2] 49:10; 97:14 clear [2] 61:10; 117:4 clearances [1] 111:21 closed [1] 81:1 CMA [14] 108:18; 110:10; 111:3, 19; 115:20; 116:4; 117:11, 13; 119:2, 9; 121:6; 141:16, 20; 157:18 Co [1] 2:19 co-products [1] 47:12 co-workers [1] 36:16 coatings [1] 31:14 cobwebs [1] 117:4 code [1] 125:4 coefficient [1] 14:5 Coeur [1] 5:5 coffee [1] 100:22 cogitate [1] 89:16 collecting [3] 32:19; 71:15; 96:21 collection [1] 32:18 collections [3] 27:2; 32:17; 33:13 collector [1] 43:12 college [5] 10:17; 12:18; 14:12, 17; 155:14 Columbia [2] 160:3, 19 coining [4] 81:6, 7; 139:18 comment [4] 32:18; 87:20; 126:13; 128:10 comments [4] 80:4; 89:19; 127:21; 136:4 Commerce [1] 2:9 Commission [2] 18:18; 160:20 commission [1] 159:19 Committee [13] 119:15; 120:13, 14, 17; 121:4; 152:3, 4, 6; 154:15, 16, 17 committee [1] 120:19 committees [3] 110:10; 152:1; 157:10 common [2] 67:7; 73:21 companies [17] 4:13; 52:11; 73:12; 74:5, 18; 77:15; 79:10; 83:19; 84:2; 92:13; 110:2; 117:14, 16, 21, 22; 121:20; 150:4 COMPANY [2] 1:5, 9 Company [6] 2:13; 4:11, 13; 25:17; 83:6; 117:12 company [20] 27:9; 35:16; 46:6; 49:14; 54:16; 82:13; 83:7; 84:7; 87:7; 107:22; 123:21; 124:15; 131:15; 132:3, 14; 139:1; 143:20; 145:5; 147:18 compare [1] 66:14 comparisons [1] 123:1 compensated [1] 7:2 competing [1] 95:14 compilation [1] 70:10 compiled [3] 70:14; : 71:10, 12 complaint [3] 54:5; j 134:13, 16 ! complaints [2] 134:22: j 135:1 I complete [4] 150:20, 22; 159:6, 11 completed [3] 28:10; 30:19; 156:9 component [9] 92:5; 99:11, 13, 14; 100:11; 103:3; 104:8, 9; 105:3 components [15] 27:22; 36:2, 6, 7, 9, 11, 13; 46:13, 16, 21; 58:17, 20; 89:18; 91:5 composition [3] 89:21; 90:18; 94:4 compound [3] 89:10; 103:9; 138:3 compounds [11] 17:2; 19:4; 49:9; 50:14, 18; 63:4; 95:17, 18; 126:12; 152:15 computerized [2] 96:9; 97:19 computers [2] 37:10; 96:20 conceivable [1] 124:14 concentration [5] 60:6, 10; 120:12; 126:4, 7 concentrations [2] 60:19; 114:20 concept [4] 25:12; 37:10; 38:7; 86:21 concepts [4] 85:4; 94:20; 108:8; 147:3 concern [3] 17:21; 44:9; 78:4 concerned [9] 78:16; 79:1, 2, 11; 105:22; 128:8; 129:10, 15; 156:2 concerning [1] 156:21 concise [2] 38:13; 40:9 concluded [3] 68:5; 121:12; 122:20 concludes [1] 122:13 conclusion [8] 28:13; 31:3; 121:7, 9, 12; 122:10, 14; 123:3 conclusions [3] 31:20; 34:17; 92:17 concur [1] 65:21 concurrence [2] 52:14; 85:21 conditions [1] 135:9 conduct [1] 136:1 conducted [8] 53:5; 71:8; 95:7; 108:17; 111:18; 122:7; 126:14; 142:5 conducting [8] 18:9, 11; 19:18, 19; 46:2; 53:9; 130:9; 157:12 Conference [2] 68:18; 120:15 confess [1] 83:22 confidence [2] 54:4; 66:17 confident [1] 37:8 confusing [1] 135:4 confusion [1] 103:11 conjunction [2] 59:9; 142:22 connected [1] 22:10 Connecticut [2] 7:11; 25:20 connection [7] 6:7; 8:9; attribute to connection WATER PCB-SD0000068064 BSA 60:1; 63:5; 75:9; 140:12; 155:5 connotation [3] 21:13; 25:3; 29:5 connotes [1] 37:19 consciously [2] 84:1; 145:2 consensus [3] 92:8, 11; 144:18 consequence [1] 135:16 conservative [1] 72:13 consider [16] 22:7; 23:2, 5; 55:19; 63:16; 75:22; 89:13; 103:21; 104:14; 126:3; 128:15; 135:19; 136:22; 137:8; 146:2; 148:8 considerable [1] 109:11 considerably [3] 51:8; 60:16; 149:11 consideration [4] 12:8; 78:7; 88:9; 93:11 considerations [5] 22:18; 55:15; 58:14; 93:19; 94:9 considered [12] 20:1; 21:11; 28:22; 33:10; 59:22; 83:16; 87:3, 13, 21; 94:6; 102:17; 104:17 considering [1] 102:15 considers [1] 135:14 consist [1] 109:3 consisted [2] 46:2; 153:17 consistency [5] 66:16; 67:1; 68:22; 144:11, 13 consistent [5] 66:18; 69:2; 92:16; 144:8, 21 constituent [4] 90:8, 21; 99:6, 7 constituents [7] 90:1, 3, 4, 5; 91:1; 93:2, 15 constitute [1] 85:5 constituted [1] 108:8 consult [1] 38:9 consultant [2] 143:9, 17 consulted [1] 12:3 consulting [4] 150:1, 3, 7, 19 consumer [3] 48:16, 21; 49:2 consumers [1] 60:17 consumption [1] 147:9 contact [19] 46:9; 57:16, 22; 65:12; 66:12; 71:14; 73:11; 74:1; 79:9, 16; 81:4, 9; 82:10; 103:20; 110:21; 126:9; 131:11; 134:13; 140:8 contacted [2] 52:11, 13 contacts [5] 57:19; 73:14; 140:10, 18, 21 contain [1] 60:21 contained [1] 37:21 containing [2] 40:9; 99:12 contains [2] 40:10, 12 contamination [1] 103:19 content [1] 87:19 context [2] 45:21; 93:21 continue [3] 42:11, 14; 139:5 continued [1] 1:21 continuity [1] 39:14 contract [1] 131:19 contracts [1] 18:18 contradictory [1] 144:9 contrast [1] 51:5 control [4] 9:19; 26:12; 62:21; 123:15 controlled [1] 80:10 Qepo of: GEORGE ). LEVINSKAS Monsanto v Aetna December 22, 1992 controls [1] 62:19 conventional [1] 48:20 conveys [1] 149:6 convinced [1] 62:17 Cook [12] 70:2, 3, 4, 16, 19; 71:8; 72:5; 75:10; 114:5; 118:7, 9; 121:2 cookbook [2] 56:11; 91:21 cooperating [1] 108:14 coordinating [1] 123:10 corporate [1] 143:21 Corroon [1] 2:3 corrosion [2] 63:18, 20 Corrosive [2] 64:4; 65:9 corrosive [10] 63:13, 16; 64:1, 8, 9, 14, 20; 65:5, 15 Council [1] 13:4 COUNSEL [1] 4:8 counsel [4] 1:16; 4:4; 160:10, 14 COUNTY [1] 1:3 couple [1] 110:2 course [10] 15:11; 16:7, 9, 20; 17:7, 13; 82:17; 100:19; 156:7, 9 courses [5] 8:9; 9:4, 6, 8; 156:6 COURT [1] 1:2 Court [1] 1:19 court [2] 4:20; 6:2 covered [1] 100:10 cradle [3] 86:4, 12, 14 CRAIG [2] 1:18; 160:4 crank [1] 135:12 creates [1] 66:19 crept [1] 86:14 Creve [1] 5:5 criteria [4] 56:3; 125:12; 136:15; 138:5 critically [1] 40:12 crop [1] 137:21 crops [1] 50:16 cup [2] 100:22; 101:2 current [3] 5:4; 39:14; 158:4 Currently [1] 158:3 curriculum [2] 7:22; 8:20 cursory [3] 47:4, 14, 17 cut [1] 23:4 Cyanamid [52] 25:16, 22; 26:6; 27:6; 29:22; 30:3, 5, 14; 31:7; 33:7, 15, 18; 34:21; 35:15, 21; 40:15, 17; 41:18, 20; 44:21; 45:15; 46:4, 12, 15; 47:2; 48:6, 10, 16, 18, 20; 49:13; 51:10; 54:20; 55:4, 13; 59:2; 66:5; 68:2; 72:12; 73:10; 74:4, 8; 77:20; 78:13; 80:12, 21; 81:4; 112:21; 113:1, 2 cyanide [6] 62:13, 14, 15, 16, 18 Cyprex [7] 27:19, 22; 28:9; 29:20; 30:5, 14; 34:10 -D- D.C. [1] 2:17 damage [1] 64:2 dangerous [1] 129:7 dangers [1] 36:1 darned [1] 116:16 data [31] 18:6; 27:1; 32:17, 18, 20; 33:12; 46:7; 53:6; 60:15; 62:3; 91:12, 13; 92:9, 15, 18, 21; 96:21; 108:6, 7; 109:19, 20; 111:8, 10; . 119:6; 120:18; 136:11, 18; 137:22; 138:10; 157:4 database [7] 96:8; 97:3; | 109:11; 110:4, 19; 112:9; I 118:22 I databases [2] 96:18, 21 | Date [1] 159:14 I date [2] 37:9; 120:21 dated [1] 109:12 dates [2] 96:20; 138:9 DAVID [1] 2:7 David [1] 4:10 day [5] 158:9, 12, 13; 159:16; 160:16 days [3] 61:12; 68:2; 153:5 deal [7] 8:10; 10:5; 30:3; 54:12; 73:20; 109:5; 152:16 dealing [6] 54:8; 87:2; 108:13; 140:13, 15; 155:1 deals [1] 88:7 dealt [1] 57:20 death [3] 115:4; 123:11; 124:9 December [3] 1:13; 158:13; 160:16 decide [4] 53:15; 89:13; 102:2; 135:18 decided [5] 10:22; 80:21; 94:12; 151:13; 156:12 deciding [1] 93:19 decisions [1] 52:16 deemed [3] 38:14; 95:6; 102:9 Defendant [2] 2:12, 18 DEFENDANTS [1] 4:8 Defendants [2] 1:10; 4:5 deficiencies [1] 122:19 define [4] 20:21; 21:3; 80:2; 146:20 definite [1] 123:2 definition [22] 21:1, 2, 4; 22:6; 23:14; 24:2, 5, 8, 10, 20, 21; 25:7, 12; 29:13; 108:9; 110:5; 115:9; 125:11, 13; 136:15; 145:22; 147:7 definitions [3] 23:16; 24:3, 12 degree [9] 7:10, 15, 16; 8:10, 21; 44:6; 81:17; 119:12; 149:17 DELAWARE [1] 1:2 Delaware [3] 1:14; 2:4, 5 deleterious [1] 25:11 demands [1] 111:7 demonstrable [1] 21:18 Department [12] 58:5, 6; 75:18; 78:2, 22; 81:10; 82:11, 12; 85:21; 123:17; 124:13; 130:1 department [7] 10:21; 18:17; 52:9; 78:6; 130:22; 132:18; 145:7 departments [1] 79:10 depend [16] 35:6, 8; 54:3; 58:9; 59:15; 60:7; 91:16; 93:6, 7; 97:12; 99:16; 100:17; 101:15; 126:4; 133:17 depended [1] 45:20 Depending [2] 58:11; 98:5 depending [1] 50:1 depends [4] 93:22; 95:5; 122:21; 146:20 DEPONENT [1] 159:1 I deposed [3] 5:12; 6:1, 7 DEPOSITION [2] 1:12; | 3:8 Deposition [1] 1:15 deposition [9] 6:11, 21; 41:8; 76:11; 158:11; 159:4; 160:5, 7, 12 depositions [1] 6:4 depth [1] 91:9 derivatives [2] 19:3; 49:7 dermal [1] 54:1 describe [9] 7:8; 10:9; 22:12; 23:6; 26:14, 20; 29:19; 45:22; 51:21 described [1] 84:18 describing [2] 37:6; 60:15 description [4] 9:17; 34:12, 15; 125:11 descriptions [3] 23:20, 22; 56:5 descriptive [3] 10:7; 21:12; 22:8 design [1] 53:4 designed [5] 95:3, 6; 101:4; 118:1; 139:9 desire [2] 97:17; 134:5 destruction [5] 63:17, 18, 20; 64:11 destructive [1] 65:4 detail [2] 16:18; 26:20 detailed [1] 130:19 details [3] 106:7; 112:7; 122:20 detect [2] 90:12, 13 determine [14] 14:6; 19:8; 30:17, 20; 37:14; 52:4; 53:2; 55:6; 71:9; 92:10; 94:21; 118:1; 125:15; 129:6 determined [1] 121:5 determining [5] 30:9; 52:22; 88:17; 125:9; 126:6 develop [10] 20:8; 53:11; 85:13; 91:12; 95:4; 99:8; 108:15; 110:4; 111:9; 136:17 developed [12] 16:11; 18:6; 42:6; 49:9; 72:5; 85:15, 18; 96:10, 18; 97:18; 107:21; 136:11 Developing [1] 108:6 development [6] 84:6, 12; 85:8; 98:16; 99:18; 105:21 devisors [1] 69:1 dictionaries [1] 23:18 dictionary [1] 24:3 die [1] 62:18 died [3] 62:14, 17 difference [2] 107:1; 145:17 differences [1] 92:1 differing [1] 92:1 difficulty [6] 23:9; 39:1; 72:16, 18; 120:9; 121:11 dilemmas [1] 66:19 direct [5] 32:22; 44:13; 80:8; 105:15; 140:8 direction [6] 26:12; 51:15; 87:12, 15; 123:16; 160:10 directive [1] 52:18 director [17] 45:2, 7; 51:17; 52:5, 10; 54:7; 57:15; 106:18, 21; 107:7, 11, 17; 131:14; 141:2, 11, 14; 143:7 directors [1] 155:20 disband [1] 80:21 discharge [1] 14:19 discipline [4] 75:12, 15; 76:3, 4 disciplines [2] 9:7, 9 discovered [1] 51:3 ; discrepancies [1] 122:19 ] discrepancy [1] 67:5 discuss [2] 17:17; 152:14 discussed [1] 7:3 discussion [2] 94:19; 121:11 discussions [4] 82:11, 17; 83:2; 138:8 disposal [7] 8:10; 12:5; 80:13; 103:16; 105:22; 106:6, 9 disposals [1] 106:3 disposed [5] 86:1, 10; 102:16; 104:15, 18 disposition [2] 102:18; 104:12 dissertation [3] 13:10, 11; 15:6 dissimilarity [1] 95:17 dissolve [1] 120:2 distinct [2] 9:20; 45:17 distinction [6] 6:2; 19:21; 29:2, 4, 14; 73:6 distribution [1] 46:5 District [2] 160:3, 19 doctoral [1] 13:3 doctorate [2] 7:12; 13:4 doctorates [1] 44:7 documented [1] 92:19 documents [1] 6:18 dodecylgunaidin [1] 28:2 doesn't [2] 10:5; 64:20 dog [1] 117:3 dogs [1] 110:14 dose [9] 47:20; 48:12; 53:22; 61:3, 5; 67:22; 115:5; 146:10, 16 doses [5] 51:1; 145:20, 21; 149:1, 12 dosing [3] 100:16; 146:12, 14 doubt [1] 71:14 Dow [4] 111:19; 117:12, 14, 17 dozen [1] 5:15 Dr [19] 4:10; 5:7; 10:22; 11:2; 41:6; 68:4; 77:5; 81:17; 82:16, 18, 20; 107:9; 115:17; 116:19; 121:2; 123:9; 124:8; 145:14; 151:18 drafting [2] 27:2; 150:10 draw [1] 122:14 drawn [2] 34:17; 92:17 dredge [1] 16:21 Drexler [1] 1:17 drink [3] 100:21; 109:9; 140:16 drinking [3] 113:8, 9; 116:17 dropped [1] 106:14 drops [1] 149:2 Drug [3] 57:22; 68:4; 110:18 drug [2] 25:2; 140:14 drugs [2] 9:13; 25:5 duly [2] 4:5; 160:7 Dunlap [1] 12:11 Dupont [1] 109:8 duration [7] 62:3; 133:13; 146:1, 3, 12, 14; 149:16 duties [8] 26:9; 28:11; 45:17; 84:19; 141:7, 10; From connotation to duties WATER PCB-SD0000068065 BSADepo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992Look-See(30) 143:16, 22 dyes [1] 27:14 -E- earliest [3] 70:9; 156:11 early [20] 28:11; 43:11; 45:11; 47:22; 84:16; 85:8; 92:10; 94:15; 95:9, 21; 96:13; 97:1; 107:11; 109:7; 112:8; 113:19; 124:14; 131:9; 141:1; 155:9 ease [1] 46:18 eat [2] 100:13; 104:6 eaten [5] 103:6, 11, 13, 15; 104:7 edition [1] 40:2 editor [1] 11:20 educate [1] 145:7 educating [1] 144:5 Education [1] 154:17 education [1] 154:16 educational [1] 7:8 effect [9] 22:13; 23:2, 5; 29:20; 66:10; 69:2, 4, 9, 16 effects [38] 9:13, 15; 17:17, 21; 18:3; 19:9; 23:10; 25:2, 4, 9; 28:19; 29:3; 43:1, 4; 44:12; 50:12; 51:2; 54:8, 17; 55:6; 60:9, 12, 18; 62:7; 67:17; 85:7; 110:13; 118:15; 128:9; 129:11, 15, 21; 148:21, 22; 149:18 effluents [3] 127:3; 128:6, 12 effort [1] 125:7 efforts [1] 19:16 eight [1] 117:16 elected [4] 12:14, 19; 150:2 elements [1] 75:22 Elmer [2] 81:17, 21 elsewhere [2] 70:11; 130:5 Elzufon [1] 1:17 emphasis [2] 18:2; 48:19 employed [5] 80:20; 149:20; 150:6; 160:11, 14 employee [6] 41:10; 75:20; 79:11; 87:12, 21; 160:13 employees [2] 77:16, 21 employment [3] 5:16, 18; 81:2 encompasses [1] 110:6 encounter [2] 17:6; 60:17 encountered [2] 57:9; 60:15 end [8] 14:16; 43:2; 45:10, 11; 64:13; 84:16; 106:15; 143:12 Energy [1] 18:18 energy [2] 18:13; 19:3 engaged [1] 143:5 enjoyable [1] 144:1 enlargement [1] 141:13 ensure [1] 78:2 entail [4] 13:5; 19:2; 57:19; 88:4 entailed [2] 11:1; 45:22 enter [2] 55:20; 100:5 entered [1] 14:18 entering [1] 95:15 entities [1] 36:5 entity [1] 46:22 Environmental [1] 30:7 environmental [33] 45:2, 7; 51:9, 13; 52:5; 54:7, 11; 57:16; 80:22; 84:8; 85:2, 7; 86:2; 102:15; 106:11, 19 , 22; 107:20; 123:4, 13; 128:7, 8; 129:5, 10, 13, 15, 21; 131:5, 17; 136:5; 141:2; 143:8 EPA [2] 28:19; 111:1 i episodes [1] 66:11 ! equate [1] 29:9 j equipment [2] 22:22; 148:10 equivalent [1] 113:22 ergonomics [1] 153:19 Errata [1] 159:10 ESQ [3] 2:2, 7, 14 essentially [4] 69:6, 7, 17; 149:15 | establish [1] 59:3 i established [4] 68:1; 70:12; 113:22; 119:14 esteem [1] 82:3 et [3] 1:9; 102:7 evaluate [1] 101:22 evaluated [2] 34:5; 40:12 evaluating [5] 33:8; 46:3; 88:2; 89:4, 7 evaluation [6] 47:1, 11; 87:11; 88:3; 146:18; 147:8 event [2] 19:11; 101:21 everybody [2] 21:3; 113:10 evolved [1] 130:3 ex [1] 134:22 exactly [3] 16:17; 29:19; 98:18 exam [1] 125:18 EXAMINATION [2] 3:2; 4:8 examination [2] 1:16; 4:4 examined [2] 4:6; 159:3 example [2] 44:11; 136:20 examples [2] 100:16; 103:10 Excellence [2] 12:13, 22 excellence [1] 12:12 excellent [1] 132:15 Except [1] 62:2 except [4] 51:7; 130:11; 150:3; 159:9 exception [1] 156:14 excess [1] 60:16 exchanging [1] 130:15 exclusively [1] 48:15 Excuse [1] 109:15 exist [1] 138:6 existed [2] 87:18; 130:11 existence [2] 120:20; 129:18 existent [1] 37:10 existing [8] 84:10; 87:1; 95:18; 107:22; 108:7; 136:7, 14, 18 exists [1] 139:8 expand [2] 19:16; 110:3 expanded [3] 109:18; 110:19; 136:16 expansion [1] 110:5 expect [5] 35:2; 44:3; 67:19; 100:14; 104:7 expected [3] 43:21; 135:9, 16 expenses [2] 6:20, 22 experience [5] 43:7; 66:8; 79:4, 18; 102:8 experiment [1] 122:12 experimental [1] 49:9 experiments [1] 95:3 Expires [1] 160:20 expires [1] 159:19 explain [4] 13:17; 62:10; 86:6; 145:17 expose [3] 72:19; 73:4; 80:4 exposed [10] 64:3; 72:22; 73:2; 77:16, 21; 80:6, 9; 147:21; 148:5, 22 | exposing [2] 72:14; 80:7 exposure [20] 17:17; 36:16; 60:10, 11; 67:17, 18, 20; 68:1, 21; 70:6, 17; 78:14; 79:20; 116:15, 22; 118:16; 133:11; 149:13, 17, 18 exposures [11] 19:12; 60:19; 61:5, 6, 8, 12; 74:19; 75:13; 87:12, 21; 149:11 expressed [1] 144:19 extend [1] 19:16 extended [5] 48:13; 61:7, 9, 11; 128:17 extensive [5] 18:12; 47:10, 15; 108:4; 132:15 extent [6] 34:18; 63:3; 84:19; 91:16; 108:14; 132:16 external [5] 56:21; 134:8, 12, 22; 135:1 extrapolation [1] 67:12 extreme [1] 64:15 eye [12] 17:5; 28:16, 21; 29:17; 30:6; 47:19; 57:1, 12; 63:11; 100:9; 115:2; 120:6 eyes [4] 65:6, 10, 11; 114:18 -F- F-ho-y-d [1] 113:14 facetious [1] 89:8 facetiously [1] 22:16 facets [1] 75:21 facilities [2] 122:2; 130:5 facility [2] 99:2; 132:11 fact [4] 64:11; 85:6; 135:5, 11 factor [4] 68:11, 14; 134:8, 12 factors [5] 68:19; 91:18; 93:11; 99:17; 135:1 failure [1] 14:8 Fair [1] 101:21 fair [11] 9:22; 26:14; 42:10; 56:15; 57:5; 72:13; 73:15; 86:2, 12; 123:10; 145:5 fairly [6] 18:12; 29:8; 37:7; 100:6; 108:4; 109:13 Fairways [1] 5:5 familiar [7] 23:21; 33:14; 83:5; 87:19; 96:1; 128:11; 138:5 Familiarized [1] 26:22 fantastically [1] 67:18 fashion [3] 56:11; 72:15; 91:22 fatal [1] 29:7 fate [4] 85:12; 104:2, 6, 11 FDA [5] 103:18; 110:22; 111:5, 21 feasible [1] 90:15 Federal [1] 88:6 federal [1] 70:11 feeding [1] 32:1 feel [6] 37:8; 40:11; 103:3; 119:7; 121:1; 138:7 feeling [1] 35:10 fees [1] 41:11 fellow [3] 11:21; 13:3; , 131:7 ' felt [1] 14:4 female [1] 121:10 t fertilizers [1] 49:18 field [2] 11:3; 42:2 j Fielding [1] 2:15 j figure [1] 104:11 filter [1] 134:10 final [5] 46:11; 85:12; 94:1; 103:21; 104:12 financially [1] 160:14 .find [3] 23:19; 29:19; 133:22 findings [2] 34:16, 17 Fine [1] 76:8 fine [2] 76:7; 128:3 fingers [2] 100:8, 9 finished [2] 116:1; 155:13 finishing [1] 30:8 finite [1] 103:18 fire [1] 114:21 First [1] 125:1 first [20] 4:5; 14:16; 15:22; 26:5; 33:6; 40:2; 41:19; 46:1; 50:6; 81:9; 82:19, 20; 84:4; 87:14; 109:5; 112:18, 19; 116:14; 118:14; 131:7 fish [7] 54:21; 55:3, 6, 7; 125:17; 134:17, 19 fit [1] 46:16 five-minute [1] 40:22 fixed [5] 90:16; 93:10; 94:10, 11; 135:20 flammable [2] 114:19; 119:12 Floor [2] 1:17; 2:9 FLORIG [50] 2:7; 4:9; 17:20; 24:18; 30:1, 3, 12; 35:7; 37:2, 11; 40:21; 41:3, 5; 52:1, 3; 59:13, 18; 65:7; 76:5, 9; 77:3, 4; 78:11, 12; 80:11; 83:15; 86:6, 8; 95:1; 96:3, 13, 16; 102:11; 114:9; 115:11, 15, 16; 116:13; 117:1; 118:19, 21; 126:21; 128:2; 131:20, 21; 135:21; 145:8, 12, 13; 158:9 Florig [2] 3:5; 4:11 Floyd [4] 110:1; 113:6, 12, 14 fluid [1] 14:10 flush [1] 65:12 focusing [1] 127:20 fold [1] 68:11 folded [1] 111:20 follow [3] 65:9; 67:14; 148:14 followers [1] 83:20 following [2] 65:12; 158:13 follows [1] 4:7 Food [3] 57:22; 68:4; 110:18 food [15] 103:4, 14, 20; 105:1, 2, 6, 15; 109:18; 110:21; 140:13, 14, 16; 147:8; 150:9 foods [1] 58:1 foodstuff [4] 103:19; 104:5; 105:10, 11 force [1] 157:12 forces [4] 18:13, 22; 157:11, 15 foregoing [3] 159:3; 160:5, 7 foreign [1] 98:13 foreseeable [3] 88:10. 14; 99:22 forget [2] 70:7; 131:7 form [7] 36:22; 72:3; j 86:5; 102:3; 114:2; 135:3; j 150:11 I formalize [1] 84:8 j formation [1] 110:9 formats [1] 27:3 former [1] 41:9 forms [1] 23:14 formulated [1] 89:22 formulation [2] 44:18; 46:17 forth [5] 65:11; 94:21; 130:17; 138:9; 144:9 Foster [1] 117:17 fostered [1] 11:3 found [3] 28:21; 32:8; 50:20 foundation [3] 37:1; 39:16; 114:3 four [1] 139:5 framework [1] 75:17 Fred [1] 107:9 free [1] 28:18 frequency [1] 148:9 frequently [2] 57:8; 66:21 freshman [1] 14:17 fruitless [1] 14:7 fuel [1] 18:13 fuels [3] 19:3, 13, 20 full [1] 5:1 full-time [1] 15:4 function [6] 78:2; 104:19, 21; 105:1, 4 functions [1] 10:5 fund [2] 74:4; 137:1 Fundamental [1] 152:9 -G- gain [1] 66:8 gamut [1] 17:5 Garrett [3] 82:19, 22; 154:8 gas [1] 119:12 gather [1] 66:14 gave [5] 23:17; 24:6, 20; 62:13; 125:13 geared [1] 17:7 generalized [1] 151:10 generate [1] 78:6 generic [1] 28:5 GEORGE [4] 1:12, 15; 4:3; 159:2 George [2] 3:3; 5:3 German [2] 12:12, 14 gets [5] 31:15; 104:5, 12; 105:2, 6 Gillman [2] 11:15; 15:21 give [14] 16:18; 19:10; 21:1; 27:15; 28:5; 31:15; 48:11; 50:11, 22; 60:4; 72:9; 85:21; 96:19; 122:5 given [12] 12:2; 16:9; 55:21; 60:2; 68:9; 76:2; 103:8; 115:5; 123:13; 156:9; 159:7, 11 glass [6] 22:4, 12, 18, 22; 23:3, 4 goals [1] 138:8 Goodman [2] 11:15; 15:21 goodness [1] 84:3 gotten [3] 62:16; 86:15; 126:11 government [2] 57:17; 70:11 dyes to government WATER PCB-SD0000068066 BSA Governmental [2] 68:18; 120:15 Graduate [7] 16:2; 20:18; 25:14; 42:13; 43:17; 71:20; 75:5 graduate [10] 15:13, 15; 42:11, 20, 21; 43:7, 14; 44:5; 56:12; 155:14 Graham [1] 12:21 Grant [1] 117:17 grant [2] 18:14; 20:4 grave [3] 86:4, 13, 14 greater [4] 66:17; 110:4; 146:1, 10 greatly [1] 90:13 gross [1] 9:18 grounds [1] 132:6 group [17] 68:5; 85:19; 111:19; 117:20; 120:17; 128:8, 14, 16; 129:13, 14, 18; 131:3, 5, 14; 143:2, 19 groups [1] 144:8 guess [20] 35:5; 37:16; 45:21; 63:15; 65:20; 72:16; 73:6; 74:2; 80:2, 8; 86:16; 107:13; 113:2; 115:22; 116:20; 127:14; 135:5; 142:3; 146:20, 21 Guides [1] 154:15 -H- habit [1] 42:7 half [1] 84:14 hand [2] 85:12; 160:16 handle [1] 139:9 handled [2] 48:1; 58:5 handling [7] 36:3; 46:19; 66:11; 94:7, 22; 113:4; 139:22 happens [2] 102:22; 150:16 happy [1] 4:16 hard [2] 56:8; 103:7 harmful [1] 54:19 harmless [1] 149:4 haven't [1] 76:2 Hawk [1] 11:19 hazard [2] 36:9; 114:21 hazardous [2] 94:7; 129:7 hazards [7] 17:4; 36:2; 38:11; 88:7; 100:7; 113:4; 139:22 Hazelton [1] 138:19 head [1] 10:21 headed [1] 143:19 headquarters [2] 99:3; 132:6 Health [12] 16:3; 18:9, 15; 20:3, 18; 25:15; 42:14; 43:18; 71:20; 75:5, 19; 113:6 health [20] 16:12; 17:12, 19; 45:2, 8; 51:9, 14; 52:5; 54:7; 57:16; 75:18, 20, 22; 78:16; 79:1; 80:22; 109:17; 151:12; 153:17, 18 hear [1] 21:4 heard [5] 24:13, 19; 83:7; 87:6 heavily [1] 157:2 held [2] 82:11; 151:21 help [4] 16:14, 16; 108:15; 117:7 helped [1] 78:6 helpful [1] 38:8 hereby [2] 159:2; 160:5 hiatus [1] 150:21 Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992 High [1] 12:17 high [9] 7:9; 12:16; 18:13; 19:3; 32:2; 51:1; 67:18; 82:3; 113:8 highly [1] 51:5 hired [2] 82:6; 107:9 historical [3] 42:22; 43:3; 75:9 history [2] 72:2; 77:9 hit [2] 22:3; 117:5 Hodge [2] 10:22; 11:2 hold [5] 45:12; 82:3; 106:16; 154:11; 155:18 Honor [1] 12:14 honorable [1] 14:19 honorary [1] 12:20 honors [2] 12:9; 13:1 host [2] 91:17; 111:1 hour [4] 6:16; 40:21; 115:11; 145:8 hours [1] 6:16 Household [1] 88:6 household [1] 88:7 housekeeping [2] 36:21; 37:14 * human [8] 17:14, 22; 56:13; 57:6; 66:12, 17; 78:14; 79:20 humans [8] 18:5; 21:10; 60:10, 12; 65:19; 66:3; 68:1; 72:14 hundred [4] 50:16; 68:10, 11; 151:15 Hunt [7] 81:17, 19; 82:14, 18; 123:9; 124:9; 151:18 hurdle [1] 105:16 hydrides [1] 19:4 Hydroxylapetite [1] 13:13 hydroxylapetite [1] 13:15 Hygiene [10] 39:4, 6, 11; 71:4; 82:1; 113:18; 153:8; 154:5, 21, 22 hygiene [6] 39:16; 51:13; 77:10, 14; 155:2; 156:2 Hygienic [1] 154:15 hygienist [2] 74:18; 79:17 Hygienists [2] 68:19; 120:16 hygienists [3] 17:9, 10; 153:18 -I- I'd [1] 19:22 idea [6] 19:11; 85:7; 88:20; 95:14, 16; 137:21 identical [1] 116:7 identify [2] 58:19; 122:16 identity [2] 58:18; 125:4 illustrate [1] 50:4 imagination [1] 99:22 immediate [1] 52:8 immediately [1] 65:12 impact [1] 17:14 implement [2] 77:15; 111:9 implication [1] 127:12 implies [1] 10:3 impressed [1] 10:21 impression [2] 48:2; 74:22 impurities [1] 90:10 in-house [3] 108:12; 132:2, 21 inability [1] 63:2 inaccurate [1] 126:22 inadequate [1] 147:16 inadvertent [1] 66:12 inanimate [2] 64:4, 8 ! incidence [1] 121:9 ; incidental [3] 85:1; 105:7 incineration [1] 104:16 include [16] 9:14, 15; 21:22; 22:1, 17; 23:12, 14; 34:5; 36:17; 42:18; 97:10; 98:13; 145:20; 146:19 , 22; 147:2 included [5] 8:6; 17:11; 48:17; 128:15 includes [1] 10:2 inconclusive [1] 122:17 inconsistent [1] 66:19 incorporated [1] 117:13 increase [1] 136:17 increased [4] 107:4; 108:3; 110:20; 121:9 increasing [3] 85:6; 108:6, 12 increasingly [1] 108:9 Indemnity [1] 2:18 indicate [2] 59:15; 63:15 indicated [25] 17:16; 24:10; 27:13; 78:15, 22; 80:3; 91:1; 93:21; 99:10, 20; 102:5; 113:5; 121:9; 124:8; 126:10; 127:3, 6; 128:13; 129:9; 130:10; 131:1; 136:15; 143:1; 151:11; 156:5 indirect [2] 57:22; 140:14 individual [2] 36:13; 56:7 individuals [1] 16:22 indoctrination [12] 26:15, 18, 21; 27:5; 31:6; 32:16, 21; 41:18, 19, 20; 42:1; 44:22 Industrial [14] 39:4, 6, 11; 68:19; 71:4; 82:1; 113:18; 120:16; 138:17; 139:7; 153:7; 154:5, 21, 22 industrial [25] 8:11; 12:5; 17:4, 10; 37:6; 39:16; 45:1, 7; 51:12; 65:18, 21; 74:17; 75:12, 14; 77:9, 10, 14; 79:17; 138:17; 143:22; 147:17; 155:2; 156:2 industry [14] 17:6, 8; 72:21; 73:8; 78:10; 79:4, 6, 13, 15; 83:9, 17; 100:7; 111:3; 146:8 inform [1] 26:11 information [60] 16:11; 36:9, 18; 37:15, 21; 40:9, 10, 13; 43:9, 12; 44:14; 54:3; 58:6, 21; 59:8; 60:1, 3, 9, 11, 18, 21, 22; 61:3, 4, 21; 62:2, 5; 63:5; 66:14; 71:13; 78:5; 85:13, 14, 15, 18; 89:3, 6, 12; 92:5; 95:4, 19, 20, 22; 96:1, 5, 9; 97:2, 4, 6, 15, 16, 18, 20; 98:22; 119:3; 130:15; 135:6; 144:22; 149:7; 150:11 informed [1] 6:22 ingestion [8] 55:15, 16; 56:15; 61:19, 22; 62:3; 100:12 inhalation [10] 17:4; 53:21; 56:15; 60:21; 61:1, 4, 14; 110:15; 116:17, 18 inhibitors [1] 50:15 initial [5] 25:12; 82:10; 84:5, 9; 121:2 ! Initially [2] 123:8; 141:17 ! initially [1] 48:20 initiate [2] 135:13; 137:17 initiated [1] 117:12 initiating [1] 35:9 initiation [1] 123:16 inject [1] 56:18 injection [1] 57:11 injury [1] 31:22 innocuous [1] 50:18 Inorganic [1] 8:3 input [1] 97:22 inquire [1] 7:6 inquired [1] 7:5 insects [2] 50:19; 51:6 insignificant [1] 67:19 Insofar [2] 121:15; 132:21 insofar [1] 118:17 instance [2] 43:13; 91:7 instances [4] 24:17; 73:20; 74:4, 8 Institutes [2] 18:15; 20:3 instructions [1] 133:16 Insurance [2] 2:13; 4:11 insurance [1] 4:13 intend [1] 7:6 intended [9] 55:1; 58:10; 59:16; 88:9, 13; 91:17; 94:2, 21; 147:9 intends [1] 100:18 intensification [1] 141:13 intensity [3] 146:1, 10; 149:17 intent [2] 10:19; 80:4 intention [3] 77:19; 80:7; 139:12 intentionally [1] 90:21 interact [1] 31:14 interacts [1] 14:9 interest [8] 11:3; 14:1; 43:10; 46:14; 73:21; 75:20; 110:20; 153:17 interested [4] 18:14; 44:11; 74:19; 160:15 interests [2] 20:5, 6 interfere [1] 5:8 intermediate [1] 62:1 interpret [1] 29:10 interval [4] 10:14, 15; 113:20; 146:17 interview [3] 82:6, 22; 83:3 interviewed [1] 82:21 Interviews [1] 82:11 interviews [1] 82:14 introduced [1] 73:17 investigation [1] 135:13 involve [5] 8:18; 33:17; 46:12; 47:1; 66:7 involved [25] 6:3; 18:19; 47:6; 48:8; 49:5; 74:12; 78:19; 106:8; 107:5, 22; 116:12; 117:15, 17, 22; 118:18; 124:9; 127:4, 18; 141:17, 18, 19, 21; 142:1; 143:5; 153:14 involvement [3] 48:15; 106:2; 108:20 involving [1] 33:18 irritant [9] 28:16, 21; 29:3, 17; 30:6; 63:7, 11; 64:15; 120:7 irritants [1] 17:5 irritate [1] 47:19 irritating [1] 114:17 irritation [6] 29:12, 15; 53:21; 63:21; 115:2, 3 Look-See(31) Irving [1] 39:22 issue [6] 24:22; 133:15; 152:7, 11; 154:19; 156:17 issues [4] 17:1; 100:1; 152:18; 153:13 ______ __________ Jack [3] 82:19, 22; 154:8 Jersey [2] 26:2; 155:21 job [11] 15:22; 25:15; 45:18, 20, 22; 59:6; 84:4, 19; 97:20; 104:9; 143:7 jobs [2] 150:8, 20 Johansson [1] 107:9 join [1] 156:12 joined [4] 82:12; 84:7; 129:18; 138:22 joint [8] 74:9, 11, 12; 108:1, 16; 109:3; 115:20; 141:15 jointly [1] 110:7 Journal [5] 39:6, 7, 11; 71:4; 154:22 journal [1] 71:3 journals [13] 37:5, 13, 20; 38:9, 18, 22; 39:2; 40:8; 41:16; 42:6; 98:11; 153:3; 155:9 JR [1] 2:2 judgment [3] 56:6; 93:9; 102:8 judgments [2] 93:1; 144:10 justification [1] 65:22 -K- Kappa [1] 12:19 keep [7] 33:2; 107:16; 114:19; 143:10; 144:7, 10, 18 keeping [1] 74:19 Keller [1] 131:8 Kelly [2] 82:16, 20 kept [2] 38:3; 45:14 kill [8] 115:9; 125:16, 22; 126:1, 8; 134:17, 19 kilo [1] 115:7 Kimmerle [1] 131:8 kinds [18] 16:15, 19; 48:3; 58:6; 85:9; 88:16; 89:6; 90:14; 133:8; 135:1, 22; 136:9; 137:22; 143:4; 146:19; 147:2, 20; 148:7 Knowing [1] 67:21 knowledge [9] 19:17; 40:3; 75:6; 78:9; 87:7; 122:18; 127:19; 128:1, 4 knowledgeable [1] 156:10 KNOWLES [2] 1:19; 160:4 -L- lab [9] 28:8; 33:15, 19; 36:10; 52:5; 54:8; 57:16; 133:5; 149:1 label [2] 30:6; 65:4 labeled [2] 30:5; 39:10 labeling [8] 63:9; 65:3; 66:9; 88:7; 100:10; 148:19, 20; 149:6 Laboratories [6] 49:13; 138:18, 20; 139:7 laboratories [7] 51:11; 132:13, 16; 138:11, 14; 139:2; 140:4 laboratory [23] 8:6; 25:19, 21; 26:13; 45:3, 8; 51:9, 14; 52:9; 54:11, 21; From Governmental to laboratory WATER PCB-SD0000068067 BSA 80:22; 108:11; 130:4; 132:4, 10; 133:1, 18; 139:3, 6, 9 labs [4] 54:15; 131:22; 138:13; 139:14 lacerations [2] 29:7, 8 Lack [1] 37:1 lack [1] 114:2 landfill [1] 104:15 landfilled [1] 104:4 language [1] 144:20 large [4] 19:7; 136:16; 147:9; 149:1 largely [3] 35:21; 108:7; 141:17 larger [4] 107:5; 108:9; 141:8 last [3] 13:14; 26:18; 90:9 late [6] 54:21; 68:4; 81:17; 113:20; 141:1; 151:18 latter [1] 152:5 law [1] 1:17 lawsuit [1] 4:12 lawsuits [1] 112:1 lay [1] 29:10 layman [1] 13:17 LD [1] 125:18 leader [1] 83:16 leaders [1] 83:20 leadership [3] 151:21; 154:11; 155:18 Leading [1] 36:22 leading [2] 17:15; 37:2 learn [4] 20:15; 43:6, 22; 44:4 leaves [1] 105:2 leaving [1] 25:14 lecturers [1] 17:1 Lehman [1] 68:5 lesser [3] 81:17; 149:17 letter [1] 6:19 leukemia [1] 121:10 level [12] 10:8; 62:1; 67:17; 68:12, 15; 69:4, 12, 16; 90:16; 103:19; 120:11; 146:16 levels [15] 32:1; 60:16; 67:16, 18, 19, 22; 68:20, 21; 69:2; 70:18; 74:20; 77:16; 90:13; 119:14; 147:5 LEVINSKAS [5] 1:12, 15; 3:8; 4:3; 159:2 Levinskas [9] 3:3; 4:10; 5:3, 7; 41:6; 77:5; 115:17; 116:19; 145:14 liability [1] 150:12 Liberty [2] 2:12; 4:11 library [4] 97:4; 98:12, 21, 22 licked [1] 100:9 life [6] 18:1; 23:13; 54:9, 19; 55:11; 129:8 lifetime [5] 61:14; 68:15; 110:13; 113:7; 116:15 light [2] 53:17; 85:4 limit [5] 34:11; 68:17; 69:19; 77:11; 91:7 limited [7] 23:13; 46:11, 14; 54:1; 83:18; 112:6; 140:18 limits [1] 146:5 line [3] 65:12; 71:22; 82:2 liquid [5] 101:3, 14; 114:17; 120:2, 5 list [17] 70:1, 15; 75:10; 77:12; 91:7; 98:6; 112:17; 114:5, 10; 118:9, 10, 12, Depo of: GEORGE [. LEVINSKAS Monsanto v Aetna December 22, 1992 13; 119:6; 120:16, 18 listed [2] 29:17; 64:19 lists [1] 64:1 literature [25] 12:3; 32:22; 33:3, 7, 17, 20; 34:5, 22; 35:12, 19; 37:9, 13, 19; 38:7, 10; 39:19; 43:11, 19; 71:9; 92:4; 95:10; 97:11; 113:3; 115:6 liver [1] 31:22 living [14] 10:12; 21:17, 21; 23:11, 12, 15; 25:10; 55:8; 64:2, 5, 9, 14, 21; 65:4 local [2] 156:14, 16 locate [1] 109:20 located [2] 25:18; 44:15 locked [2] 104:3, 12 logical [1] 135:15 long-term [5] 28:10; 30:9; 61:22; 110:13; 128:5 looks [1] 68:17 loss [1] 87:8 lot [1] 97:17 lots [1] 138:14 Louis [3] 99:4; 130:6; 132:9 low [2] 50:17; 114:20 lower [1] 149:11 lowest [2] 50:17; 74:19 LPP [2] 87:8, 22 lunch [2] 76:6; 77:8 - re main [2] 17:13, 21 maintained [1] 39:13 major [13] 7:18; 8:1, 22; 14:7; 90:1, 3, 5; 91:1; 101:5; 121:16, 19; 148:19; 156:6 makers [1] 85:11 Malathion [6] 50:4, 6; 51:5, 8; 125:19, 20 Mammalian [1] 18:3 mammalian [5] 18:3, 7; 54:9, 12; 123:20 man [7] 66:10; 67:2, 7, 8, 18, 20; 68:7 manageability [1] 136:6 manager [18] 84:5, 11; 98:16; 99:18; 105:21; 106:11; 107:8, 10, 19; 108:16; 123:4, 12; 124:1; 129:5; 131:13, 17; 140:7; 141:8 manifest [1] 126:2 manifested [2] 62:8; 149:12 manner [2] 46:5; 144:20 manners [1] 144:9 Manta [1] 2:8 Manual [2] 11:9, 11 manual [1] 97:19 manufacture [2] 19:6; 87:5 Manufacturers [5] 73:19; 108:3; 142:19; 157:20; 158:4 Manufacturing [3] 157:8, 19, 22 manufacturing [5] 86:19, 21; 87:10; 121:21; 122:1 map [1] 68:22 MARILYN [1] 2:14 marked [1] 64:8 Market [2] 1:18; 2:10 market [3] 85:20; 95:15; 112:4 marketed [2] 48:4; 94:1 marketing [2] 111:22; 112:6 material [72] 23:15; 29:12, 13; 33:9; 34:22; 35:14; 46:17; 50:1, 9; 52:22; 53:19, 22; 55:20; 58:17, 18; 63:6, 10, 18; 64:1; 65:3; 85:8, 10, 11; 89:22; 90:2; 91:11; 92:3, 7, 11; 93:3, 6, 7, 10, 13, 15, 17, 20; 94:5, 13, 14; 95:8; 99:9, 11; 100:5, 18; 101:16, 17; 103:17, 22; 104:3, 5, 13, 15, 20, 21; 105:2, 3, 4, 9; 109:18; 114:16; 115:7; 133:6; 134:1, 5, 14, 16; 146:19; 148:20; 150:14, 15 materials [37] 6:8; 17:14; 19:10; 34:4; 37:22; 38:11; 41:17; 46:15; 47:16, 21, 22; 49:12; 50:2; 52:6; 54:8; 55:1, 14; 56:14, 22; 57:6; 59:3; 71:10; 72:14; 73:22; 74:5, 20; 77:17, 22; 78:14; 79:20; 90:14; 128:22; 129:3, 7; 131:19; 139:15; 147:20 Mathematics [1] 7:21 matter [3] 35:11; 36:20; 67:6 MCA [1] 157:22 mean [14] 28:22; 29:13; 59:17; 61:10; 64:1, 12, 21; 86:6; 96:11; 115:5; 119:19, 22; 135:12; 146:21 meaning [1] 63:14 meanings [1] 69:17 means [6] 57:6, 10; 102:1; 114:10; 115:7; 125:5 meant [3] 20:21; 69:10; 127:20 measure [2] 47:19; 63:3 measured [2] 62:9, 15 measurements [1] 129:21 mechanical [3] 9:22; 10:3, 4 mechanics [1] 10:2 mechanisms [2] 18:15; 20:9 Medical [9] 11:17; 78:1, 22; 82:12; 85:21; 123:17; 124:13; 130:1; 132:9 medical [4] 15:15; 52:8, 10; 79:10 medications [1] 5:7 Medicine [2] 39:7, 12 medicine [1] 151:11 meet [6] 6:10, 15; 73:16, 19; 83:1; 137:13 meeting [1] 155:6 meetings [9] 24:5; 73:16; 74:10, 16; 81:20, 22; 152:12; 155:7 member [15] 68:9; 151:2, 16, 18, 19; 152:1; 153:7, 10, 20; 154:5, 9, 14; 155:11, 15; 157:8 members [4] 49:8; 82:12; 151:15; 154:10 Membership [2] 152:4, 6 membership [1] 156:4 men [1] 82:3 mental [1] 117:5 mention [3] 75:8; 103:11, 12 mentioned [19] 18:21; 31:6; 32:16; 33:12; 41:17; 42:16, 17, 18; 49:17; 50:6; 57:15; 69:19; 91:3; 99:8; 102:14; 112:8; 116:3; 119:18; 120:13 mercury [1] 44:12 merged [1] 51:13 merger [1] 51:16 metabolism [1] 17:2 metal [1] 63:19 metals [1] 14:10 method [1] 104:16 mid [3] 109:7; 115:21; 121:3 Middletown [1] 7:11 mild [1] 65:15 military [2] 14:13; 18:13 milligrams [1] 115:7 million [3] 60:2, 5; 113:9 mind [5] 31:18; 81:16; 103:16; 131:6, 11 mindless [1] 91:22 mineral [2] 13:20;. 14:4 minor [6] 7:20; 8:18; 29:7; 69:7; 147:7 mislabel [1] 25:8 missed [1] 120:14 Missouri [1] 5:5 misstatement [1] 102:4 mistakes [1] 100:19 misuse [4] 88:10, 14; 99:22; 135:10 mixture [3] 46:18; 58:19; 89:22 modify [2] 6:1; 53:16 molecular [1] 10:8 molecule [1] 90:9 moment [2] 41:7; 69:19 monograph [2] 42:9; 152:13 monographs [1] 155:1 monomer [6] 108:22; 109:1, 2; 118:2, 4; 119:1 monomers [1] 109:1 MONSANTO [1] 1:5 Monsanto [73] 4:13; 5:17, 19; 6:20; 35:21; 41:9; 80:16, 20; 81:5, 10, 13; 82:7, 8, 21; 83:6, 8; 84:4, 9; 86:3; 94:12; 95:9, 21; 97:1, 5; 98:21; 99:1; 106:1, 10; 109:8; 111:17; 112:2; 113:1; 117:15, 17; 121:16, 18, 21; 122:7; 123:5, 7; 124:2; 125:10; 126:7; 127:7, 13, 21; 128:5; 129:6, 10, 14, 19; 131:10; 132:14, 21; 134:22; 137:17; 138:12, 15; 139:3; 142:21; 143:1; 144:16; 145:15; 149:21; 150:1, 4; 151:16; 153:21; 154:4, 10; 155:16 Monsanto-owned [2] 132:10, 11 month [1] 62:4 months [4] 26:19; 117:4; 146:1, 3 morning [4] 4:10; 6:14, 17; 158:10 mostly [1] 119:13 mouth [4] 47:21; 55:18; 115:5; 144:17 moved [2] 25:11; 26:1 MS [1] 76:8 multiple [1] 61:8 muscles [2] 9:19 Mutual [2] 2:12; 4:11 myself [4] 16:22; 26:11, 22; 36:16 LQ0ij.-3eevJZj -N- N.W. [1] 2:16 name [9] 4:10; 5:1; 27:20, 21; 32:14; 39:13; 97:13; 131:7; 158:4 named [5] 11:21; 45:1; 131:7; 143:9; 152:2 names [14] 5:20; 11:6; 27:15, 17; 28:7; 31:16; 32:13, 14; 38:21; 39:2; 41:15; 131:4, 10; 138:13 narcotic [1] 119:16 narrow [1] 10:3 National [4] 12:14; 13:3; 18:15; 20:3 national [1] 154:14 Natural [1] 12:22 nature [17] 28:15; 49:11; 53:15; 54:4; 58:9; 59:16; 66:12; 87:20; 93:7, 22; 95:15; 97:12; 100:17; 101:18; 102:6, 17; 150:7 NCI [1] 111:1 needless [1] 36:15 negotiated [1] 111:6 nice [1] 144:3 NIOSH [1] 111:1 no-effect [3] 68:12, 15, 20 NOEL [2] 69:4, 8 non-availability [1] 148:10 non-living [1] 22:2 norm [1] 62:22 normally [1] 72:19 Notary [3] 4:6; 159:18; 160:18 note [3] 121:12; 126:17; 134:7 noted [1] 159:9 NUMBER [1] 3:8 number [9] 9:6; 59:21; 73:15; 125:4, 17; 137:9; 145:5; 151:2 numbers [5] 49:13; 70:10; 114:7; 120:18 numerous [1] 98:11 nurses [1] 17:11 -O- O-s-e-r [1] 11:21 oath [3] 4:6; 77:6; 115:18 Object [5] 36:22; 79:22; 86:5; 94:16; 114:2 Objection [10] 17:15; 35:3; 59:10; 64:22; 79:7; 83:10; 102:3; 116:9; 118:17; 135:3 objection [4] 37:3; 95:11; 126:17; 127:16 observable [1] 69:8 observe [3] 51:1; 62:21; 63:1 observed [3] 69:9, 12, 16 obtain [1] 98:10 occasion [1] 130:18 Occasionally [1] 57:10 occasions [1] 46:7 Occupational [3] 39:7, 11; 75:19 occupational [4] 75:17; 151:11; 153:17 occupied [1] 84:20 occur [5] 10:11; 67:17; 73:14; 79:20; 149:11 occurred [4] 44:1; 51:18; 134:9; 135:10 occurrence [1] 121:10 occurs [1] 94:1 labs to occurs WATER PCB-SD0000068068 BSA October [1] 160:20 offered [1] 25:7 officer [1] 160:4 officerships [1] 151:21 offices [2] 1:17; 81:3 Oh [5] 5:15; 24:21; 82:10; 96:18; 117:16 Okay [25] 13:21; 14:15; 21:4; 37:18; 39:15; 62:5; 64:10; 67:15; 72:18; 75:16; 79:14; 86:17; 87:16; 101:19; 102:12; 104:1; 111:14; 117:2; 120:4; 128:18; 132:20; 138:11; 139:20; 144:15; 147:11 okay [2] 4:17; 116:20 old [2] 87:4;' 107:8 old-timers [1] 69:9 ones [10] 15:19; 20:10; 41:16; 42:16, 17, 18; 50:11; 102:2; 138:21; 157:17 ongoing [1] 32:20 opened [1] 54:22 operate [1] 75:1 operating [8] 52:11, 12, 13; 134:3; 136:1, 8, 21; 147:18 operation [3] 26:11; 41:21; 78:19 operational [1] 132:5 operations [3] 27:1; 33:14; 78:3 opinion [1] 83:18 opposed [2] 17:22; 21:9 opposite [2] 21:13; 22:9 oral [3] 47:20; 53:22; 100:16 ORDER [1] 1:1 order [2] 11:1; 84:14 organic [1] 8:4 organism [2] 25:10; 126:1 organisms [4] 23:11, 13; 125:17; 126:8 organization [4] 130:2; 153:11; 154:12; 156:1 organized [3] 110:17; 151:9, 14 organophosphates [2] 49:7, 17 organs [1] 10:6 orifices [1] 57:1 origin [1] 77:19 original [2] 72:5; 114:4 originally [2] 24:21; 25:4 originate [1] 134:3 Oser [1] 11:21 OSHA [1] 111:2 ought [2] 67:2; 137:7 ours [1] 111:6 ourselves [1] 136:10 outcome [1] 160:15 outside [11] 46:6; 54:14; 131:22; 132:13, 16; 133:1, 5; 138:11; 139:13, 14; 150:1 overall [1] 69:2 overdose [1] 25:1 -P- p.m. [4] 76:12; 77:2; 158:12 package [2] 63:9; 104:10 packaging [16] 103:17, 20, 22; 104:2, 8, 9, 14, 19, 20; 105:2, 3, 4, 8, 14, 15; 109:18 packing [1] 104:13 Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December Lm, iyy/ ________________ Loun-jeetjj) , pages [1] 159:3 paid [1] 13:6 pamphlets [1] 155:3 paper [6] 28:4; 31:12, 13, 14, 15; 152:21 papers [3] 13:7; 113:6; 153:2 Parathion [4] 50:5; 51:4; 125:19 Part [1] 60:5 part [16] 33:7; 52:9; 55:22; 59:6; 60:5; 63:8; 72:1; 78:7; 84:20; 102:14, 19; 104:8; 123:10; 130:1; 133:12; 151:10 participant [1] 143:3 participate [1] 74:15 participated [4] 74:9, 10; 141:20; 143:2 participating [2] 119:1; 142:21 participation [1] 151:6 parties [3] 1:20; 160:11, 14 parts [5] 54:16; 60:2, 3; 113:9; 144:16 pathway [4] 55:15, 16; 100:4; 133:11 pathways [1] 101:5 pattern [1] 69:3 Pause [1] 158:8 paying [2] 6:20; 41:11 penetrate [1] 56:22 Pennsylvania [1] 2:11 pension [1] 145:14 people [61] 14:4; 17:5, 7, 18; 19:10; 26:22; 29:6, 9; 35:17; 38:20; 45:21; 50:19; 51:6; 53:7; 63:16; 66:1; 67:14; 70:10; 72:2, 20, 22; 73:2, 11, 17, 20; 78:1, 4, 5, 15; 79:9; 80:4, 6, 9; 81:3, 5, 15; 82:7; 84:22; 89:1; 92:16; 95:13; 96:21; 99:1; 102:21; 107:5; 109:16; 123:9; 127:6, 9; 129:9, 20; 131:4; 137:20; 138:4; 141:22; 145:5, 7; 149:22; 151:13; 153:16 perceive [1] 29:9 percent [1] 94:4 percentages [1] 58:20 perform [2] 104:21; 130:22 performed [8] 93:12; 129:6; 131:19; 132:13; 133:5, 9, 19; 139:16 period [24] 20:16; 26:15, 18, 21; 27:5, 12; 31:7; 32:12, 17, 21; 34:20; 41:18, 20; 44:22; 61:7, 11; 72:12, 22; 73:10; 129:4; 140:7; 141:14; 145:21; 146:15 periodic [1] 39:18 periodicals [1] 152:10 periods [2] 61:9; 146:7 permanent [1] 64:2 permissible [3] 68:20; 70:6, 17 permits [1] 111:22 permitted [1] 103:18 person [2] 35:9; 148:22 personal [2] 71:14; 128:4 personally [5] 74:11, 12; 125:1; 141:18; 144:1 Personnel [2] 81:10; 82:10 personnel [7] 79:1, 11; 81:3, 5, 9; 82:7; 140:1 perspective [1] 88:5 pertinent [1] 38:14 , pesticide [8] 27:13; 55:1, I 6; 57:20; 58:2; 59:9; i 137:20; 140:12 Pesticides [1] 49:20 pesticides [5] 27:18; 49:19, 21; 140:19; 143:21 PETER [1] 2:2 petition [1] 150:11 Ph.D. [9] 8:16; 10:13; 11:7; 12:4; 13:2, 8; 15:3, 7; 16:1 pharmacologist [4] 10:20; 26:8, 10; 79:18 Pharmacology [3] 11:9, 11; 152:9 pharmacology [11] 7:12; 8:16, 20; 9:1, 11; 11:13; 15:11, 18; 19:19, 22; 25:1 phase [1] 78:19 phases [1] 155:2 Phi [1] 12:19 Philadelphia [1] 2:11 phrase [1] 65:10 phrasing [1] 100:13 physical [2] 8:5; 94:6 physicians [4] 17:11; 19:9; 65:22; 153:18 physicists [1] 153:19 Physiological [2] 11:17, 19 Physiology [1] 9:17 physiology [2] 9:1, 16 pick [2] 141:10; 158:10 picked [1] 117:13 piece [1] 23:4 Pittsburgh [7] 16:4, 6; 39:17; 72:8; 75:19; 153:6; 154:13 place [6] 46:16, 20; 51:16; 53:8; 98:15; 119:13 Plaintiff [2] 1:6; 2:6 plan [3] 53:4; 72:19; 73:3 planning [1] 46:2 plant [9] 54:19; 73:1; 125:6, 10; 126:7, 16; 127:3; 128:6, 12 plants [5] 54:17; 124:2, 21; 128:19, 21 plastic [1] 140:16 plausible [1] 135:15 please [1] 5:2 plenty [1] 65:13 point [3] 67:16; 93:4; 124:1 poison [3] 115:8, 9; 125:20 poisoning [4] 62:14, 15, 18 Polychlorinated [1] 6:5 polymer [1] 109:9 polymers [4] 27:14; 31:8, 10; 32:11 polystyrene [1] 119:21 pool [1] 110:3 population [2] 29:10; 147:10 portion [1] 139:10 position [12] 16:2; 26:5; 44:20, 21; 51:22; 84:19; 106:10, 16; 107:8, 16; 128:10; 141:5 positions [5] 46:1; 107:2; 151:22; 154:11; 155:18 I positive [1] 114:6 possession [2] 96:4, 6 post [1] 7:9 posted [1] 144:18 ; potent [3] 50:19; 51:7, 8 potential [7] 42:22; ! 67:17; 79:19; 86:3; 102:1; 148:22; 149:7 potentially [1] 78:14 Potter [1] 2:3 powder [1] 101:20 ppm [1] 116:16 practical [3] 15:4; 106:8; 107:3 practically [1] 35:19 Practice [1] 11:17 practice [9] 25:11; 34:8, 11; 35:11; 36:21; 37:12; 139:17; 140:2; 148:17 pre [2] 13:3, 4 precautionary [1] 148:20 precautions [2] 36:15; 78:13 precise [3] 51:20; 69:17; 96:19 precisely [1] 96:19 predecessor [2] 70:1, 16 predictive [1] 66:9 predictively [1] 148:21 predominant [2] 48:19; 74:3 Predominantly [3] 17:10; 82:1, 16 preexisting [1] 51:11 prefer [1] 65:16 preliminary [1] 62:2 preparation [1] 34:2 prepared [1] 46:7 preparing [3] 31:1; 46:4; 72:4 present [4] 1:19; 58:18; 72:1, 3 presentations [1] 155:6 presented [1] 111:2 president [1] 154:7 pressurized [2] 119:13; 120:5 presume [1] 111:15 pretty [1] 142:12 prevent [2] 77:15; 78:13 previous [2] 53:15; 92:5 primary [1] 57:6 Princeton [1] 26:2 print [1] 160:9 Prior [6] 14:12; 81:12; 83:5, 8; 119:9; 132:12 prior [15] 6:10; 34:20; 35:13; 36:17; 51:16; 71:15; 82:6, 21; 83:1; 119:1; 124:8; 132:22; 133:5; 138:12; 139:17 Prize [2] 12:11, 21 probability [1] 35:18 problem [2] 44:8; 105:12 problems [1] 122:16 procedural [1] 122:19 Procedurally [1] 133:21 procedure [9] 33:8, 11; 53:5; 75:1; 87:6; 91:21; 133:12; 136:5; 148:13 procedures [8] 27:2; 32:19; 33:13, 17; 77:15; 144:13, 14; 152:17 proceed [1] 132:4 proceeded [1] 111:9 process [7] 86:20, 22; 87:1, 4, 5, 10; 92:22 processes [2] 9:21; 10:11 produce [1] 31:22 produced [1] 111:20 producer [3] 121:16, 18, 19 Producers [4] 141:22; 142:6, 8, 15 producing [1] 115:2 product [44] 14:8; 28:20; 46:12; 48:3; 84:6, 11; 85:12, 19, 20, 22; 86:10, 20; 88:3, 10, 12, 14, 18; 89:15, 18; 90:22; 91:17; 93:2, 7; 94:1, 20; 95:13; 98:16; 99:7, 11, 12, 18, 21; 100:10; 102:6, 16, 18, 22; 103:14; 105:21; 136:6; 147:15; 148:20; 149:6; 150:12 products [39] 27:10, 14; 35:16; 36:3; 46:4, 10, 13; 47:10, 22; 48:16, 18, 19, 21, 22; 49:2, 4; 52:12; 57:21; 80:14; 84:9, 10; 86:3; 87:2, 3; 88:8; 92:2; 95:14, 16; 107:22; 108:6, 7; 136:7, 14, 18; 138:4, 6 profession [2] 24:14; 64:18 professional [4] 24:5; 151:3; 153:16; 156:11 professionally [1] 82:4 professionals [1] 16:13 professor [1] 11:4 program [16] 8:2; 10:13, 16; 11:7; 12:4; 15:3, 5, 8; 18:12; 107:5; 108:5; 111:2; 115:22; 116:11, 14; 117:13 programs [4] 18:20; 108:4; 136:10, 20 progressively [1] 123:15 project [3] 32:4; 111:20; 112:8 projects [1] 27:4 prompt [1] 134:10 prompted [1] 156:4 proper [1] 100:10 properties [10] 30:15, 18, 21; 32:8; 50:20; 51:6; 94:6; 114:11; 115:1; 119:5 property [1] 87:8 proposal [3] 110:18; 111:5, 7 proposed [7] 19:6; 88:19; 109:17; 134:4; 136:10; 140:15; 150:9 proposing [1] 88:19 proprietary [2] 35:16; 36:8 protect [2] 75:13; 139:22 protecting [1] 75:20 Protection [1] 30:7 protection [2] 75:22; 87:8 PROTECTIVE [1] 1:1 protective [1] 148:10 protocol [2] 53:11; 133:16 protocols [1] 53:8 provide [7] 60:9, 14, 18; 97:21; 98:1, 8; 148:19 provided [1] 61:21 prudence [1] 67:6 prudent [1] 110:6 Public [11] 4:6; 16:3; 18:9; 20:18; 25:14; 42:14; 43:18; 71:20; 75:5; 113:6; 160:18 public [5] 17:12, 19; 108:8; 136:16: 159:18 publication [2] 70:9; 121:3 publications [7] 37:20; 152:7, 20; 154:19; 156:18, 22; 157:6 publicly [1] 111:8 From October to publicly WATER PCB-SD0000068069 BSA ' Depp of: GEORGE [. LEVINSKAS Monsanto v Aetna December 22, 1992 Look-See(34) publish [2] 155:4, 5 published [25] 12:2; 13:7, 10; 40:4; 70:2, 5, 14; 71:1, 3, 15; 92:15, 17; 109:21, 22; 113:5, 7, 17; 115:6; 120:16; 152:19; 155:8, 10; 156:21; 157:2, 5 publishes [1] 155:1 pulled [1] 112:21 purely [1] 92:19 purists [1] 69:10 purpose [7] 50:22; 55:5; 62:21; 103:1; 148:18; 149:8, 14 purposes [5] 15:4; 77:13; 106:8; 107:3; 136:6 pursuant [1] 1:16 pursue [1] 20:4 puts [1] 114:21 - Q -__________ qualification [1] 137:19 quantity [2] 148:5, 9 quarter [2] 76:5, 9 Quarterly [1] 154:21 quarterly [1] 39:5 question [26] 4:15; 37:17; 44:18; 53:3, 19; 57:3; 59:11; 64:22; 67:21; 72:17; 77:18; 79:22; 80:9; 90:12; 94:16; 97:16, 21; 114:8; 126:22; 127:10; 134:9; 135:4, 5, 11; 137:7 questions [21] 4:14; 5:9; 59:21; 84:22; 85:6, 9, 16; 88:16; 94:22; 95:4; 98:19; 99:19; 100:1, 2, 4; 106:6; 112:20; 117:6; 158:7; 159:8, 12 quote [4] 43:2; 68:19; 156:10 -R- rad [1] 116:15 raise [1] 134:9 raised [5] 53:2, 19; 85:6; 135:5, 11 range [1] 50:4 ranking [1] 84:2 rankings [1] 83:20 rats [7] 110:13, 14, 15; 111:20; 113:8; 121:10; 125:18 raw [1] 148:20 reach [1] 123:2 reacted [1] 17:2 reaction [2] 22:5, 7 reactions [1] 10:11 reactive [3] 119:11, 19 reacts [1] 119:20 read [3] 24:19; 151:5; 159:3 readily [4] 31:18; 81:16; 114:20; 131:12 reading [3] 8:13; 12:5; 24:4 reason [8] 71:21; 72:10; 84:7; 91:2; 101:2; 122:5; 137:5 reasonable [13] 35:12; 78:20; 79:2; 85:20; 86:18; 92:8, 11; 100:19; 109:14, 16; 112:13; 119:4, 7 reasonably [8] 68:3; 85:22; 88:9, 14; 92:7; 99:22; 100:14; 111:4 reasons [4] 14:3, 7; 46:8; 75:12 reassure [2] 136:9; , 147:14 i reassuring [1] 85:22 recall [111] 5:20; 7:22; 8:13; 10:15; 11:6, 14; 12:1, 4, 7, 8; 15:17; 1 20:11; 24:1, 3, 7, 8, 12, I 16; 26:4; 27:4, 11, 17, ! 22; 28:13; 31:10, 16, 21; ! 32:2, 11, 15; 33:3; 34:1, ' 9; 38:21; 39:20, 22; ! 40:18, 19; 41:15; 42:4; | 46:21; 47:3, 9; 48:8; 49:4, 10, 15, 20; 50:2, 8; 54:6; 55:10, 12; 61:9; 69:22; 71:12; 72:7; 77:10; 81:15; 83:12, 13; 99:3; 106:2, 7; 107:14; 113:8; 114:15; 116:16; 118:14; 119:17; 120:10, 21; 124:5, 17, 19, 21; 125:9; 126:6, 12; 128:16; 129:2, 3, 4, 12; 130:13, 15, 21; 131:3, 4, 10; 134:18, 21; 137:6, 12; 138:13, 16; 140:10; 141:12, 15; 142:4, 10, 13, 20, 21; 143:4; 153:1, 3; 157:1, 4 recalling [1] 39:1 receive [2] 12:9; 125:2 received [4] 12:11, 21; 14:19; 136:2 receiving [2] 15:22; 145:14 recent [2] 86:15; 154:9 recently [1] 56:4 Recess [3] 41:2; 115:14; 145:11 recessed [2] 76:11; 158:11 recital [1] 50:12 recognition [1] 80:5 recognize [2] 67:14; 146:5 recognized [3] 72:21; 73:2; 76:3 recognizing [1] 67:8 recollect [1] 28:7 recollection [4] 40:5; 53:10; 70:19; 130:19 recommendations [2] 102:9; 136:8 recommended [1] 36:15 record [6] 5:1; 41:3; 77:3; 115:15; 127:15; 145:12 recorded [2] 159:8, 12 records [2] 49:14 recover [1] 64:12 redone [1] 122:4 reduced [1] 160:9 reduces [1] 158:6 refer [9] 38:6; 40:16; 42:11, 14; 45:21; 64:4; 65:14; 92:4; 145:19 referable [1] 68:3 reference [11] 38:2; 41:17; 71:19; 91:20; 98:6; 140:11; 142:7; 150:4; 154:20; 156:15; 157:14 references [6] 12:2; 34:5; 39:18; 97:10; 98:1, 7 referred [7] 15:19; 30:8; 40:9; 69:4; 75:18; 118:8; 152:13 Referring [1] 72:12 referring [2] 29:21; 99:4 refers [1] 146:15 reflect [2] 108:8; 110:4 refresh [1] 40:5 regard [2] 29:7; 83:3 regarding [5] 19:17; 46:9; 112:20; 138:6; 140:14 regimen [1] 148:13 ' register [1] 138:3 j registered [1] 58:17 ! registration [8] 28:20; 57:20; 58:2, 7. 22; 59:9; 63:8; 138:1 registrations [3] 61:2; 63:6; 140:13 Regrettably [1] 20:17 Tegular [1] 152:10 regularly [1] 33:3 regulated [3] 91:9; 103:18; 109:13 regulations [5] 88:8; 108:13, 15; 137:22; 138:6 regulators [2] 137:17; 140:18 regulatory [12] 46:9; 56:3; 57:17, 21; 105:8, 16; 108:14; 134:6, 7; 137:14; 140:8; 152:17 reimbursed [1] 7:1 Rein [1] 2:15 reinforce [1] 145:7 relate [1] 5:16 related [5] 5:18; 14:21; 89:9; 97:15; 160:10 relative [3] 84:2; 121:19; 160:13 relatively [9] 35:17; 37:5; 50:18; 55:3; 56:3; 68:22; 124:20; 149:1, 3 relied [1] 95:22 rely [5] 43:11; 78:5; 92:9; 95:20; 102:21 remain [1] 155:15 remained [1] 143:21 Remember [1] 116:19 remember [4] 47:6; 116:21; 142:5; 156:20 render [1] 145:6 reorganizations [1] 143:18 repeated [4] 100:16; 121:13, 14; 149:11 repetition [1] 149:15 rephrase [2] 4:15; 118:19 report [13] 27:2; 28:12; 29:17; 33:13; 34:11, 18; 53:6; 60:7, 8; 63:22; 64:19; 121:7; 122:10 reported [1] 53:20 Reporter [2] 1:19; 160:1 reporter [1] 4:20 reporting [1] 105:19 reports [10] 27:3; 29:16; 31:1; 34:2, 4, 8, 10; 46:4 represent [1] 4:11 representatives [1] 110:22 representing [2] 41:7, 9 represents [1] 114:21 reproduction [1] 110:14 request [5] 7:4; 53:11, 14; 97:12; 137:16 requested [1] 139:16 requests [5] 52:7; 84:21; 131:2; 135:22; 136:2 require [4] 58:7, 16; 88:8; 134:6 required [5] 58:21; 61:15, 16; 63:9; 137:22 requirement [2] 58:2, 4 requirements [2] 105:17; 137:14 Research [1] 13:4 research [24] 9:10; 18:9, 11, 19, 22; 19:2, 18, 19; ' 20:2, 5, 6; 26:7, 9; 35:13; 36:3; 37:20; 42:22; 43:3; 44:8, 17; 47:21; 75:9; | 85:14 I resins [4] 28:4; 31:11, I 13, 17 I resistant [1] 68:8 i resource [1] 144:5 resources [1] 110:3 respect [3] 45:17; 82:4; 132:19 respective [1] 1:20 respiratory [2] 9:19; 120:9 respond [5] 35:4; 65:2; 94:11, 18; 126:20 responded [1] 84:22 response [5] 67:1; 83:18; 93:10; 122:21; 123:2 responses [6] 4:20; 49:22; 85:16; 93:5; 148:22; 149:10 responsibilities [2] 107:19; 144:2 responsibility [3] 80:13; 123:6, 14 responsible [1] 128:15 responsive [1] 98:19 rest [4] 9:9; 79:12; 127:21; 132:3 restrictions [1] 114:22 result [2] 66:15; 121:6 results [8] 46:3; 49:20; 50:8; 60:15; 66:2; 126:11, 13; 140:5 resume [4] 76:9, 12; 151:5; 158:12 retired [4] 143:11; 149:20; 153:21; 155:16 retrenched [1] 80:22 return [1] 53:6 returned [1] 97:8 review [11] 6:18; 43:8, 12, 15; 44:16; 53:14; 87:8; 107:21; 134:11; 136:13 Reviewed [1] 27:1 reviewed [3] 32:5; 33:12; 113:3 reviewing [4] 30:22; 31:1; 34:1; 150:11 reviews [3] 87:20, 22; 120:17 revises [1] 120:18 revoked [1] 111:21 Rich [1] 131:8 Right [13] 22:11; 42:3; 45:9; 88:1; 90:20; 101:13; 124:11; 125:21; 142:10; 143:1; 146:9, 13, 17 right [45] 14:14; 15:20; 16:18; 25:6; 26:17; 30:4, 13; 34:19; 38:1, 5, 17; 51:19; 52:15; 53:8, 13; 55:5, 17; 56:20; 57:2; 59:14; 60:13; 63:22; 65:8; 67:4; 68:16; 70:13; 71:5; 73:5; 74:14; 77:13; 83:21; 86:11, 19; 91:19; 92:14; 97:7; 98:12; 99:15; 103:2; 105:21; 106:20; 117:5; 118:19; 123:18; 132:6 risks [1] 109:17 Rochester [1] 7:13 round [1] 81:8 route [1] 116:21 routinely [2] 56:11; 125:5 rule [1] 62:19 rules [1] 67:13 run [3] 10S:4; 126:10; 148:6 j ~S- | S-o-l-!-m-a-n [1] 11:12 | S-v-i-r-b-e-l-y [1] 113:14 safe [3] 67:22; 89:9; 147:14 safely [6] 86:1, 10; 88:3, 18; 89:7; 102:16 safety [18] 36:8, 14, 21; 37:14; 38:10; 68:11, 13, 19; 78:2; 79:11; 85:5; 103:6; 108:8; 110:5; 120:11; 136:16; 149:6 sale [1] 111:13 sample [2] 125:2, 4 samples [1] 125:3 SANDBECK [2] 2:14; 76:8 Sax [3] 39:22; 40:10, 16 saying [8] 9:7; 69:10, 12, 13; 105:9, 13; 156:10 scale [3] 19:7; 84:2; 147:9 scatter [1] 97:17 schedule [1] 53:5 scheduling [1] 138:8 School [9] 16:3; 18:8; 20:18; 25:14; 42:13; 43:17; 71:20; 75:5; 132:9 school [5] 7:9; 12:16, 17; 75:19; 155:14 Science [1] 12:22 science [1] 9:12 sciences [3] 128:8; 129:13; 131:5 scientific [4] 12:21; 73:15, 16; 97:11 scientifically [1] 13:16 scope [2] 59:16; 108:10 Scott [1] 131:6 scratch [1] 110:12 se [1] 24:2 search [4] 34:22; 35:13; 38:18; 71:9 searches [10] 32:22; 33:1, 4, 7, 18, 20; 34:6; 37:9; 97:19 second [4] 4:19; 85:17; 116:3; 144:12 Secondly [1] 125:3 secondly [1] 87:17 section [5] 34:5; 154:13; 155:21; 156:15, 16 sections [1] 34:9 seeking [4] 54:18; 57:21; 81:1; 150:2 segments [2] 79:15; 147:10 semantic [1] 37:16 semantically [1] 69:16 semantics [1] 38:7 semester [1] 14:16 send [2] 39:17; 54:14 senior [2] 143:9, 16 sense [10] 9:18; 10:7; 29:9; 48:21; 56:2; 67:7; 73:4; 83:4; 90:8; 125:22 sensitive [6] 67:7, 8, 9, 10, 11; 68:8 sentence [1] 34:13 separate [6] 76:3, 4; 87:6; 109:4; 144:7; 152:12 separately [1] 110:8 September [1] 143:12 series [3] 4:14; 39:13; 49:6 serious [2] 29:6; 149:3 publish to serious WATER PCB-SD0000068070 BSA Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992 ______________ LooK-5ee(3j) serve [1] 13:1 served [5] 14:12; 102:22; 152:4; 154:14; 157:10 serves [1] 104:19 Service [1] 113:7 service [5] 14:18; 98:13, 15, 18, 20 services [3] 97:4, 20; 99:1 serving [1] 105:1 SESSION [2] 3:11; 77:1 settle [1] 105:17 settled [1] 70:8 severe [2] 28:16; 29:8 shatter [1] 23:1 Sheet [1] 159:10 Shelanski [1] 138:20 short-term [19] 47:4, 14, 17; 48:12; 61:1; 66:8; 117:3; 124:3, 18, 20; 126:11, 14; 127:5, 11, 12; 128:11, 16, 18; 131:2 show [3] 14:8; 28:17 Sigma [1] 12:20 Signature [1] 159:14 significant [1] 123:1 significantly [1] 123:2 similarity [1] 95:17 simultaneous [1] 45:4 single [12] 36:5; 46:22; 47:20; 48:12; 61:3, 5, 22; 89:21; 145:20; 148:13; 149:5, 13 sit [2] 89:15; 101:22 site [1] 125:6 situation [4] 35:21; 89:5; 134:11, 21 situations [1] 147:13 six [5] 26:19; 117:3, 21; 146:1, 2 six-month [1] 110:14 skills [1] 42:20 skin [19] 17:5; 29:7, 8, 12; 47:19; 53:20; 56:19, 22; 57:11; 63:6; 65:5, 10, 11; 100:8; 101:10, 12; 114:18; 115:2; 120:6 sledgehammer [1] 22:3 so-called [6] 12:11; 14:5; 68:11, 17; 70:6; 74:9 societal [1] 110:5 societies [3] 151:3, 7; 156:11 Society [7] 8:3; 12:15, 20; 151:8; 155:12; 156:8, 17 society [14] 12:21; 151:14, 17, 22; 152:7; 153:16; 154:1, 14; 155:15, 19, 22; 156:4, 13 soft [2] 109:9; 140:16 solid [2] 101:9, 18 Solids [1] 101:12 Soliman [3] 11:9, 11; 15:19 Solubility [1] 13:12 solubility [4] 14:1, 5, 8; 43:14 solvent [3] 46:17; 119:16; 120:1 somebody [2] 103:5; 124:15 somehow [1] 134:10 someone [5] 53:20; 101:21; 107:7; 124:15; 134:13 somewhat [9] 67:3; 85:1; 92:22; 110:17; 111:17; 116:6; 121:7; 141:8; 146:4 somewhere [9] 52:18; 71:22; 72:9; 84:16; 91:8; 94:19; 113:20; 116:2; 132:7 ' somewheres [1] 39:8 sorry [1] 30:2 sort [8] 24:22; 39:18; 53:11; 61:14; 70:14; 84:2; 100:13; 134:21 sound [1] 89:8 sounds [2] 41:1; 126:19 source [4] 38:15; 44:14; 71:19; 92:18 sources [2] 39:21; 71:13 speak [2] 34:7; 124:16 special [2] 77:11; 147:12 species [9] 66:21; 67:2, 6, 8, 11; 68:6, 9; 116:4; 141:15 Specific [1] 27:15 specific [37] 11:14; 12:1, 2; 16:14; 20:10; 24:17; 26:7; 28:7; 33:3, 4; 38:15; 39:21; 43:9; 46:8, 15; 50:2; 54:2; 55:16; 74:2; 77:11; 97:15; 101:15, 17; 103:8; 116:10; 117:6; 121:8; 122:5; 125:6; 126:12; 128:1; 137:5, 11, 21; 157:1, 17 specifically [15] 19:2; 35:15; 40:20; 47:9; 49:10; 100:12; 107:15; 120:10, 21; 124:4; 129:16; 137:11; 143:4; 153:3; 156:1 specifics [7] 32:15; 103:8; 104:17; 119:17; 128:9; 130:13; 142:14 specified [2] 10:14, 15 specify [2] 65:5; 96:12 speculation [3] 35:3; 65:1; 79:8 spell [1] 11:10 spend [1] 100:15 spent [2] 20:13; 108:19 spilled [2] 100:8, 9 spin [1] 110:8 sponsors [1] 152:8 sprayed [1] 101:4 Square [1] 2:9 ss [1] 160:2 St [3] 99:4; 130:5; 132:9 staff [2] 107:3; 141:8 stage [2] 85:8, 17 stages [2] 47:22; 124:14 standard [7] 33:8, 11; 56:9; 62:22; 68:3; 91:21 standards [3] 56:3, 4; 85:4 standing [1] 37:2 standpoint [1] 88:13 Stanford [1] 25:20 start [3] 44:13; 103:5; 144:8 started [4] 14:17; 42:9; 115:22; 153:5 starting [2] 110:12; 119:1 STATE [1] 1:2 state [3] 5:1; 70:11; 90:18 stated [1] 86:9 statement [5] 34:13; 65:14, 20; 135:8, 14 statements [1] 127:21 States [1] 160:2 statistically [1] 122:22 statutory [2] 115:9; 125:20 stay [5] 25:21; 104:9, 20; 105:15; 153:20 stayed [2] 114:7; 141:5 stays [1] 105:14 ; steel [1] 65:15 step [7] 52:2, 21; 73:9; i 78:20; 79:2; 106:21; 107:7 , steps [2] 77:21; 93:4 stimulus [1] 134:15 stipend [1] 13:6 stop [2] 28:6; 139:2 straightens [1] 158:6 stream [3] 125:10, 16; 126:7 streams [5] 47:2; 124:1, 4, 18; 126:16 Street [3] 1:18; 2:10, 16 strength [4] 28:4; 31:11, 13, 15 strengthen [2] 136:17; 145:6 Strike [2] 78:11; 131:20 strike [1] 52:1 strong [1] 123:2 structural [1] 143:18 structure [1] 131:15 structured [1] 129:22 structures [2] 49:15; 130:2 student [5] 42:11; 43:7, 14; 44:13; 56:13 students [12] 15:13, 14, 15, 16; 16:12; 18:20; 43:18; 44:3, 5, 10; 72:1 studied [1] 91:8 Studies [1] 13:12 studies [46] 12:10; 13:2, 4; 14:2; 27:1; 30:7, 9, 10; 32:20; 42:20, 21; 46:3, 5; 48:3, 9; 49:21; 52:14; 53:21, 22; 56:10; 61:1, 18, 19; 66:18; 71:10; 74:4, 11, 13; 98:2, 13; 108:17; 110:14, 16; 111:7, 18; 113:17; 129:11; 130:22; 133:20; 137:8; 142:5, 10, 14, 22; 152:16 study [57] 9:12, 22; 10:10; 11:1, 2; 13:19; 22:17; 23:8, 10; 25:4, 9; 28:10, 12, 14, 17; 34:12, 13; 35:9; 44:7; 50:1, 3; 54:17; 55:22; 61:14; 63:14; 68:12, 14, 15; 102:2; 110:14; 113:8, 12, 16; 115:20; 116:1, 3, 4, 7, 8, 12; 117:3, 8, 9; 118:1; 119:1, 2, 9; 121:6, 13, 14, 17; 122:3, 8, 17; 148:18; 149:9, 14 studying [3] 12:5; 44:11; 102:20 stuff [1] 124:19 StyTene [2] 109:1; 119:11 styTene [23] 6:6; 108:21, 22; 109:2; 110:11; 116:4, 8; 117:8; 118:2, 4, 15, 22; 119:5, 10, 18; 120:6; 121:5, 16, 21; 122:9; 136:20; 141:18; 157:15 Subacute [3] 145:22; 146:10, 15 subacute [3] 145:18; 149:8, 16 subcommittees [1] 110:10 subconsciously [1] 84:1 subdivide [1] 57:4 SUBJECT [1] 1:1 subject [1] 8:14 subjective [3] 92:22; 93:1; 146:4 subjects [3] 6:3; 9:4; 19:17 submitted [3] 28:19; 61:18; 138:1 subscribe [1] 148:16 Subscribed [1] 159:15 subscribed [1] 98:12 subsequent [2] 72:9; 121:2 Subsequently [1] 124:12 subsequently [3] 13:9; 56:4; 122:8 substance [2] 28:22; 89:21 Substances [1] 88:6 substances [6] 64:7; 89:22; 90:17; 91:6, 15; 120:3 substantial [2] 84:20; 139:10 substantially [2] 140:21; 141:9 successfully [1] 156:8 sufficient [1] 126:8 sufficiently [3] 51:1; 87:19; 147:14 suggested [2] 81:4; 110:3 suggestion [1] 136:22 suitable [1] 46:5 summaries [2] 38:13; 46:7 summarized [1] 113:3 Summer [1] 26:4 sun [1] 69:15 Superflox [1] 32:15 SUPERIOR [1] 1:2 superior [1] 52:8 superiors [1] 52:19 supervising [2] 54:6; 157:13 supplied [7] 58:22; 59:8; 60:2; 62:5; 63:5; 95:20, 22 support [3] 28:19; 136:12; 138:1 suppose [1] 134:15 supposition [1] 66:22 SURETY [1] 1:8 surface [1] 14:9 surfaces [4] 56:21; 57:1; 64:4, 8 surprise [1] 40:6 surrounding [1] 14:10 survey [1] 95:10 surveys [1] 43:19 suspect [2] 40:19; 106:5 Svirbely [3] 109:22; 113:6, 12 swear [2] 71:2; 151:20 sworn [3] 4:5; 159:15; 160:7 synonymous [3] 69:6, 7, 18 Synthetic [1] 13:12 systematically [1] 38:18 systems [5] 10:12; 18:7; 23:11, 12; 54:12 -T- t-e-t-r-a-m-e-t-h-y-l-s-u [1] 150:18 table [2] 22:3, 12 takes [1] 135:14 talcum [1] 101:20 talk [4] 17:3; 18:7; 72:8; 92:13 talked [6] 77:11; 101:5; 117:9; 130:17, 19; 137:7 talking [13] 34:19; 37:22; 72:2; 77:8; 87:22; 90:10; 94:15; 95:8; 127:17; 132:18; 144:10, 12, 16 target [1] 138:9 task [3] 157:10, 12, 15 taught [9] 16:10, 15, 19; 17:1; 20:18; 42:20; 43:2, 4; 44:2 Taylor [1] 11:18 teach [5] 15:7, 10; 16:5; 43:18; 44:1 teaching [7] 15:12, 17; 16:2; 18:8; 43:17; 72:1, 8 Technical [3] 152:3, 6; 154:15 technical [3] 63:13; 122:19; 153:15 Technically [1] 111:13 technology [2] 129:5; 131:18 ten [5] 68:10; 115:12; 117:16, 21 ten-fold [2] 68:6, 7 tend [1] 157:2 tensile [1] 31:15 term [10] 23:9; 25:9, 13; 28:5; 29:10; 68:12; 70:7, 16; 125:12; 127:8 terminology [1] 86:14 terms [11] 13:17; 60:6, 7; 70:5; 83:20; 84:1; 90:18; 102:6; 144:5; 145:19; 146:7 Test [2] 138:17; 139:7 test [23] 52:6, 22; 53:1, 4, 12; 62:22; 63:2; 66:21; 68:6; 93:16, 20; 94:12; 99:10, 12, 14; 112:5; 122:3; 133:4, 12, 13, 22; 137:11 tested [7] 52:17; 64:7; 65:3; 67:6; 129:1; 133:6; 139:15 testified [3] 4:6; 5:21; 6:2 testify [1] 150:14 testimony [6] 102:4; 126:18; 127:6; 142:8; 160:6, 8 testing [59] 43:14; 47:2, 10, 11, 15, 17; 48:14; 49:2, 5; 50:22; 52:7; 53:3; 54:6, 7, 13, 14, 21; 55:5, 14; 56:5; 62:11; 65:18; 66:3, 20; 95:5; 102:9; 107:5; 108:3, 4, 12; 123:6, 8, 14, 16, 20, 22; 124:10, 17, 18, 20, 21; 127:7; 131:18; 132:2, 4, 12, 19; 136:1, 3, 9; 137:13; 138:12; 139:11; 142:13; 143:4; 147:13, 16; 148:13; 157:13 tests [52] 28:8; 34:20; 47:5, 15; 48:13; 50:9, 10; 51:22; 53:9; 55:3, 10, 12; 56:5; 59:3; 66:8; 93:12; 95:6; 99:8, 19; 124:3, 4; 126:11, 14; 127:3, 5, 8, 11, 12; 128:5, 11, 13, 16, 17, 18; 129:3, 6; 130:9, 22; 131:2; 133:2, 8; 137:16; 138:2, 9; 139:16; 146:19; 147:2, 20; 148:7 tetramethylsuccinotriie [1] 150:17 Texas [1] 121:22 text [3] 12:1; 15:17; 42:9 textbook [4] 11:13; 24:2; 37:8; 38:16 textbooks [11] 23:19; From serve to textbooks WATER PCB-SD0000068071 BSA Depo of: GEORGE J. LEVINSKAS Monsanto v Aetna December 22, 1992 Look-See(36) 37:7, 13; 38:2, 9, 13, 22; 40:S; 41:16; 42:5 texts [3] 11:6; 40:14; 43:19 Thank [5] 37:4; 38:8; 49:3; 96:14; 158:2 theirs [1] 74:1 therapeutic [2] 9:14; 25:2 thereafter [1] 160:9 therein [2] 159:8, 12 thereto [1] 160:14 thinking [4] 74:6; 135:2; 145:1, 3 third [1] 67:16 thorough [5] 146:18, 21; 147:8, 14 thousand-fc!d [1] 68:13 three [18] 6:16; 8:22; 9:5, 8; 26:1; 56:14, 17; 57:5, 8; 101:5; 109:8; 131:11; 146:19, 22; 147:2, 20; 148:6 threshold [3] 68:17; 69:19; 91:7 thrust [1] 17:13 timeframe [1] 118:18 times [7] 5:14; 46:8; 68:10; 89:20; 106:5; 148:1, 2 tissue [9] 63:17; 64:2, 5, 9, 12, 14, 21; 65:4, 14 title [16] 11:14, 16, 20; 12:1; 16:9; 26:7; 39:12, 14; 45:20; 84:5, 13; 106:15; 123:12; 143:10; 158:1, 4 titles [5] 45:6, 12, 14, 18, 19 TLV [12] 70:16; 112:19; 113:22; 114:10; 118:5; 119:6, 14; 120:13, 14, 16, 17; 121:4 TLVs [5] 69:20, 22; 70:1, 8; 72:3 tomorrow [1] 158:10 topics [3] 33:4; 153:1, 4 total [1] 117:22 totally [1] 111:4 touch [1] 144:3 TOV [1] 112:17 towards [1] 157:3 Toxic [1] 29:5 toxic [50] 19:6; 20:22; 21:5, 11, 12; 22:4, 6, 7, 8, 11, 13; 23:2, 5, 17; 24:2, 6, 8, 11; 25:2, 8; 29:1, 9, 10, 11, 13, 20; 30:14, 18; 32:8; 43:1; 44:12; 50:20; 51:2, 5; 67:22; 72:15; 74:21; 77:16, 22; 78:14; 79:20; 114:11, 16; 115:1, 7; 118:15; 119:5; 125:10, 12; 126:3 toxicity [76] 6:8; 9:15; 18:16; 19:13; 20:9, 15; 28:8; 29:2, 15, 16; 30:20; 33:8; 34:4; 36:17; 37:6, 15; 38:11; 46:3; 47:20; 48:8; 49:21; 50:9, 17, 22; 51:22; 52:22; 55:3, 14; 58:21; 59:2, 3, 8; 60:1, 7; 65:18; 66:3; 91:4; 92:3, 8; 93:3, 16; 94:13; 95:9; 96:9; 97:2, 13, 15; 99:7; 110:15; 112:14; 119:10; 123:6, 16, 22; 124:4, 9; 126:2; 130:9; 132:19; 133:2, 4; 136:1, 3; 137:16; 138:12; 139:10; 145:18; 146:18; 147:2, 20; 148:18; 149:8, 14; 150:14; 156:21; ! 157:13 toxicological [1] 35:11 I Toxicologist [1] 152:13 ! toxicologist [5] 10:19; j 45:1, 7; 74:18; 79:17 ! toxicologists [6] 17:9, | 11; 65:21; 92:13; 144:6; ! 153:18 | Toxicology [6] 23:10; | 71:4; 151:8; 152:2, 8, 10 toxicology [45] 11:1; ! 16:7, 8, 11, 15, 20; j 19:18, 22; 22:17; 23:6, 8, 10; 24:20, 22; 25:3; 42:2; 51:12; 55:22; 63:14, 22; 64:19; 75:12, 14; 77:9, 14; 81:20; 91:10, 15; 106:12, 19, 22; 107:20; 123:5, 13, 14; 141:3; 142:12; 143:8, 9, 16; 144:8; 151:10; 154:2; 156:2; 157:3 tracking [1] 125:6 trade [10] 27:20, 21; 32:14; 73:18; 74:11, 15; 142:15, 17, 19 trained [1] 13:16 transcription [2] 159:7, 11 transferred [1] 143:20 translating [1] 66:2 travel [2] 6:20, 22 Travelers [1] 2:18 treated [1] 17:3 treatment [1] 80:13 tremendous [1] 105:16 Trenton [2] 155:21; 156:15 true [7] 48:5; 63:11; 75:2, 4; 154:1; 159:6, 10 Trust [1] 2:4 Tucker [1] 131:6 Tuesday [1] 1:13 tuition [1] 13:6 tumors [1] 111:20 type [2] 53:3; 95:5 -U- U.S. [1] 58:5 U.S.D.A. [4] 59:9; 60:4; 61:15, 19 ultimate [6] 85:12; 102:18; 104:2, 6, 11; 112:1 Ultimately [1] 111:11 ultimately [3] 81:1, 7; 86:1 unable [1] 42:8 unacceptable [1] 77:22 unchanged [2] 112:19; 114:7 uncontrolled [3] 79:19; 80:3, 10 undergone [1] 39:13 undergraduate [3] 8:10; 12:10; 15:14 underlying [1] 63:18 understand [10] 4:15, 21; 64:15; 77:5; 88:12; 101:3; 115:17; 126:20; 127:10; 135:7 understandable [1] 135:15 understanding [7] 9:18, 21; 20:8; 64:18; 71:8; 74:17; 75:11 understood [3] 19:14; 1 81:8; 146:7 ; undertaken [2] 34:14; 108:11 undoubtedly [1] 84:21 Unfortunately [1] 126:18 I unfortunately [2] 29:5; ! 40:12 | uniform [1] 140:2 l unit [4] 101:22; 134:3; } 136:8; 147:18 United [1] 160:2 units [4] 52:12, 13; 136:1, 21 universal [1] 21:2 University [6] 7:11, 12; 16:3, 5; 132:9; 153:6 unknown [6] 93:6, 10, 16; 95:8; 99:6, 7 unsafe [1] 75:13 unsatisfactory [3] 121:8; 122:11, 15 up-to-date [1] 110:4 updates [1] 43:9 upper [1] 69:1 upward [1] 62:4 USDA [1] 58:16 useful [4] 89:4, 12, 13; 104:19 user [1] 149:7 Users [1] 142:1 users [2] 60:17; 85:10 uses [3] 9:14; 84:10; 87:2 -V- vague [7] 80:1; 83:10; 94:17; 95:11; 116:9; 118:17; 135:4 value [4] 68:18; 77:12; 91:7; 113:22 values [2] 69:19; 115:6 variation [4] 68:6, 7; 69:7; 147:22 variations [4] 9:3, 4; 23:19, 22 varies [1] 90:13 variety [15] 27:9; 49:8, 22; 50:10; 58:14; 71:13; 92:12, 20; 93:5, 11; 94:8; 99:16; 123:8, 9; 148:10 vary [1] 68:21 venture [2] 74:9; 109:3 ventures [4] 108:1, 16; 141:15 verbal [1] 4:20 view [2] 83:9; 101:14 viewed [2] 122:10; 144:19 Virtually [1] 155:8 virtually [2] 62:7; 123:19 volume [1] 11:19 vs [1] 1:7 -W- walk [1] 94:13 WALSH [31] 2:2; 17:15; 24:15; 29:21; 30:2; 35:3; 36:22; 37:4; 41:1; 59:10, 14; 64:22; 76:7; 79:7, 22; 83:10; 86:5; 94:16; 95:11; 96:11, 14; 102:3; 114:2; 115:13; 116:9, 19; 118:17; 126:17; 127:15; 135:3; 145:10 Walsh [2] 6:10; 41:7 wanted [12] 36:1; 44:16; 45:21; 97:1; 110:19; 133:4, 6, 9, 11; 137:20; 139:15 wants [1] 146:20 Warren [4] 70:2, 3, 4; 114:5 Washington [3] 2:17; 111:1; 132:8 ! waste [15] 47:2, 10; 48:1; 80:13; 106:3, 6, 9; 124:1, 4, 18; 125:9, 16; 126:1, 7, 16 wastes [5] 8:11; 12:6; 47:14; 106:1; 127:13 water [7] 55:2, 7, 11; 65:13; 113:8, 9; 116:17 ways [10] 16:21; 55:19; 56:14, 17; 66:6; 74:6; 92:12, 20; 134:2; 144:17 weak [1] 122:21 Wednesday [1] 158:13 week [5] 61:13; 147:19 weighted [1] 157:3 Welge [1] 2:8 well-defined [1] 88:15 weren't [1] 77:21 Wesleyan [1] 7:11 wet [4] 28:4; 31:11, 13, 15 Wheeler [5] 81:18, 21; 82:15, 17; 154:7 wheels [1] 110:8 whereas [1] 147:15 Whereupon [3] 4:2; 76:11; 158:11 wide [1] 147:9 widely [4] 50:15; 58:13; 59:17; 109:14 Wiley [1] 2:15 Wilmington [2] 1:14; 2:5 wishes [1] 134:7 WITNESS [3] 3:2; 116:21; 127:17 Witness [2] 159:14; 160:16 witness [3] 4:4; 160:6, 8 won't [1] 112:18 word [9] 13:14, 15; 20:22; 21:12; 22:8, 11; 63:13; 73:4; 83:4 work [27] 8:7; 9:21; 14:21; 15:2; 18:15; 25:16; 29:21; 30:19, 20; 32:5; 33:6; 46:11; 47:1; 55:1; 80:16; 110:15; 118:8; 137:1; 139:13; 143:20, 21; 148:6; 150:1, 5, 7, 13; 152:19 worked [15] 20:12; 22:20; 27:5, 12; 30:11; 32:12, 17; 33:21; 38:11; 66:22; 73:10; 81:13; 127:2; 128:16; 142:1 worker [6] 74:19; 147:17, 21; 148:4; 149:1, 2 workers [3] 75:13; 78:3, 16 working [21] 13:8, 9; 15:5; 17:8, 12, 19; 19:10; 22:22; 28:8; 30:17; 31:7; 33:19; 36:10; 65:22; 95:13; 107:4; 109:8; 129:20; 130:11; 131:5; 147:17 workplace [5] 68:21; 70:6; 73:1; 119:13; 120:12 works [1] 9:18 worry [4] 101:1, 10; 103:4; 144:4 worrying [2] 100:15; 103:5 Wouldn't [2] 21:14; 36:1 wouldn't [9] 22:12; 29:12; 35:12; 36:8; 71:2; 79:19; 90:6; 101:9; 144:16 wound [1] 85:11 write [2] 28:11; 53:6 I writing [3] 27:2; 33:13; ! 34:2 ' written [1] 133:15 I -x- J Xi [1] 12:20 -Y- year [2] 14:17; 84:13 years [14] 14:6; 26:1; 42:7; 67:1; 86:15; 95:9, 21; 113:9; 130:3; 137:9; 141:19; 150:13; 152:2; 153:6 Yesterday [1] 6:14 yesterday [1] 6:16 Younger [1] 138:18 younger [1] 144:6 yourself [1] 154:4 -Z- zero [1] 35:19 texts to zero WATER PCB-SD0000068072 LEVih/ZtfftS i Mo/fcAWTt? 1/5. 1W>okWci= cos. Par 1 of 2 _____________________________ .ORRECTIONS TO DEPOSITION-Get _e J. Levinskas Dec 22-23. 199? Page Line Correction: n /3.I5"! SPEU-Tfi/Qr i IH---'---7--- S' : Missfotrcr - s flouuT) 1? H 1 speu-ifi/fr % Pkdbuc~r As oaj eiwe g 19 (6 ! * 1 WTTWEo' CoA/t/Bys PufiPSSE AO ! 5feULffVGr Afi ! a ! SpEuL/n'ix d& \ t1? ` 2f> IP ?A is ')wTAA?l>" Cofi/i/Ey$ Pu$po$t |' i Sfi ELLAS' ! SPb i~u/a/g- oE)PESEA&eH SO 'S" | 3PAL j iJT9- 7 CIAAIPV PMAS/Mb-________________________________ ^|7 I PvtfCsTVA T/oA/ CL/\(k\FiES> fcEJpotet (j / Sf>LL>tVS /I A/P <EA$\F'/ 17TMA/T 61 9rofe C V? Eesfb/v^ ?? 19 SPeLL/WO- *16 2 SPeuLfVCr C2 A U)oPy> CoPd^cTni/ 103 CoNi/ey ! A/TsiUpj> Pes&>*"$ m J SPeLL.1 /V(r- m (9 (JoPP CoA$^Ct?oAS los r SPSLUf/Cr i\i 3 SPe/-l;a/g- 19 SPeuu)/}&. l((c> /S' S?l~LlN(r las- Ip SlMSH lootis 9,!o,t) C 0MFi / IV rzASDEV ft FSPoAGf Xol -2_ %o6 \io,o\\ ftissfotrif. Fth'IL c^idf rifts iqcAl Anesthtjp vss WATER PCB-SD0000068073 LtVWMZIfr t _____________________ Page I Line Correctioi.. ys * //vs v/y tvv^ts oc^. Page 2 of 2 ORRECTIONS TO DEPOSITION ~ rge J. Levinskas Dec 22-23. 92 aoTrto/fe! 'S)slT, N/ssfo/rz:, i7/y2- Hfc ArvBS'fatrrt^ dm \r*lo' h\$s(>otTE, (\\-ohtNvtf 5 ot-r^VE- / M rV) weH/T, i1 oll^ I ^ U?0#> Cpfik&cTtcA/ m. WtAv QotokCTse>AJ ds?>\ Ifi i s>pi//yr^ WATER PCB-SD0000068074