Document EvzROr40E7mNR4zOX0XQjKMYR

ANSWER: cerning such standards or regulations, and the name, address, job title of the current custodian of all such reports or other written communication, (or alternatively attach copies of each hereto); (h) Attach hereto copies of each such standard or regulation; (i) Whether defendant disseminated such standards or.regulations to any other person or entity; and if so, set forth the name and address of said entity, the date of dissemination, and the substance of what was disseminated. Defendant objects to this Interrogatory insofar as it is directed to "awareness of any standards or regulations set" by any "trade or safety associ ation concerning quality of air relating to asbestos exposure at any time from 1940 to 1975." Preliminarily, "trade or safety associations" do not, insofar as this defendant is aware, purport to promulgate "regulations". The term "trade or safety association" is ambiguous in the context of the.Interrogatory because it is non-specific, and leaves the answering party in doubt as to what plaintiff has in mind in employing that termin ology. By the same tokeh, the time frame en compassed by the Interrogatory (1940 to 1975) is overly broad. Decedent's first alleged exposure to asbestos occurred in 1959, some 19 years later. The Interrogatory is also objectionable as irrelevant absent some indication that plaintiff's various employers belonged to some "safety or trade association" which, in turn, "set" some standard for asbestos exposure. Finally, defen dant objects to the Interrogatory's use of the term "standards" because the determination of a "standard" is a matter for expert testimony. Subject to the foregoing objections, defendant understands that in 1946 the American Conference of Governmental Industrial Hygienists (ACGIH) recommended a Threshold Limit Value (TVL) for asbestos dust of 5 mppef. That TVL existed through 1970. In 1968 and 1969, ACGIH proposed a change in the TVL to 12 Fibres/ml-um in length. 9002 0614 PRODUCED BY FORD