Document DGyR2nj2B3gbo63yxBZG2kE4a

AH asbestos waste should be disposed of in accordance with OSHA and EPA asbestos regulations. During removal ofvacuum bags, an approved respirator, as described in (2) above, should be worn. 6) Good housekeeping is essential in a workplace where asbestos-containing materials are handled. Industrial vacuum cleaners equipped with multiple stage, high efficiency filters should be used for removing accumulations of asbestos dust and waste. Never use compressed air or dry sweeping for cleaning. Water or other dust suppressants should be applied ifbrooms are used. 7) Good personal hygiene practices are important in minimizing asbestos dust exposure. Do not smoke. Wash before eating. Shower after work. Change to work clothes upon arrival at work and change from work clothes at conclusion of work. Work clothing should not be taken home. Laundering asbestos contaminated clothing shall be done so as to prevent release of airborne asbestos fibers in excess of the exposure limits. CAUTION: DO NOT BREATH ASBESTOS INTERROGATORY NO, 64: Did Defendant, any predecessor or any related company, at any time, place any warning signs or labels on the containers in which any or the products listed in response to Interrogatory Nos. 19 and 42 were packaged? SECOND AMENDED ANSWER TO INTERROGATORY NO, 64: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. Abex also objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to Abex. Abex further objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the ground that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence. Abex objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. 104