Document DKy1bebjBBM2pDNwwmdM9by4

INTERROGATORY NO. 46: If your answer to Interrogatory No. 45 is <cYes," with respect to each such recommended design change: (a) State the product or products involved; (b) State the test or tests involved; (c) State the nature of the change recommended; (d) Identify the person(s) making the recommendation; (e) State the nature and effective date of any change made; and (f) Identify each and every person who participated in the decision to make or not make the recommended design change. RESPONSE: See Union Carbide's Response to Interrogatory No. 45, including all objections set forth therein. INTERROGATORY NO. 47: Identify any and all persons employed by Defendant, its predecessor or related company at any time from 1940 to date as an industrial hygienist or in a similar position. RESPONSE: See General Objections Nos. 1-8. Union Carbide further objects to this Interrogatory on the ground that it is overly broad. Union Carbide further objects to this Interrogatory to the extent that it calls for information about Union Carbide employees or premises, or policies pertaining to Union Carbide employees or premises that are unrelated to the claims in this litigation on the grounds that such requests are overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to its objections, Union Carbide responds as follows: Union Carbide's Industrial Relations Department was formally organized as early as 1921. The Industrial Relations Department performed several functions similar to those performed by a medical department. Prior to the formal formation of a corporate Medical Department at Union Carbide, Union Carbide and Union Carbide facilities either had their own physicians on site or consulted physicians as necessary. Union Carbide's Medical Department was formally organized in the late 1930s. The duties ofUnion Carbide's Medical Director encompassed coordination of Union Carbide's medical programs, including employee physical examination programs; recommendations with respect to medical policies, standards and procedures; and administration ofmedical services at Union Carbide's corporate headquarters, a corporate epidemiology program, a medical program for employees traveling overseas, and an alcoholism prevention and treatment program. The medical director reports to the corporate Vice President in charge of Union Carbide's Community and Employee Health, Safety and Environmental Protection Department. The Medical Directors at Union Carbide have included the following individuals for the DOCSNYhlO 12018.1 33