Document EqvKd8DEvEV0Y0NvL5Y4NZbXL
-47Defendant's investigation with respect to axles sold by Heavy Axle Products continues.
The investigation to date has revealed that any brakes made with asbestos that Defendant
installed onto heavy axles came with a warning from the brake manufacturer, which warning
stated that the brake contained asbestos
With respect to Trailer Axle Products, by at least the mid-1980s, the following language
was included in Defendant's installation and field maintenance manual for trailer axles, brakes
and components, which manual was distributed to customers of such products:
"DANGER! ASBESTOS BRAKE LININGS CONTAIN ASBESTOS FIBERS
BREATHING ASBESTOS DUST MAY BE HAZARDOUS TO YOUR HEALTH AND MAY CAUSE SERIOUS RESPIRATORY OR OTHER BODILY HARM
AVOID CREATING DUST
DO NOT REMOVE BRAKE DRUM WITHOUT PROPERPROTECTIVE EQUIPMENT
DO NOT WORK ON BRAKE LININGS WITHOUT PROPER PROTECTIVE EQUIPMENT
DO NOT REPLACE BRAKE LININGS WITHOUT PROPER PROTECTIVE EQUIPMENT
DO NOT ATTEMPT TO SAND, GRIND, CHISEL, FILE, HAMMER OR ALTER BRAKE LININGS IN ANY MANNER WITHOUT PROPER PROTECTIVE EQUIPMENT
FOLLOW O.S.H.A. STANDARDS FOR PROPER PROTECTIVE DEVICES TO BE USED WHEN WORKING WITH ASBESTOS MATERIALS."
Defendant's investigation with respect to axles sold by Light Axle Products continues.
[eylRoyster "VOELKERTM
&ALLEN
I Suite 100 A Twain Ptaxa II lw "'audit!* Street
Iox467 tfw * IL 62025-0467
Fix (618) 656-7940 <618)656-4646
Material Safety Data Sheets and other information relating to certain axle products were also available from Defendant upon request See response to Interrogatory 93.
Additional information regarding warnings, to the extent known to Defendant, may be ascertained from the Axle Product Divisions warning files, which files will be made available for inspection and copying at a mutually convenient time and location, except for those