Document GK5qb1ENg7v19Nd3GJgdrKqan

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY JOAN MAERTIN, Executrix of ) the Estate of Lothar ) Maertin, JOAN MAERTIN/ ) individually and in her ) own right, et al., Plaintiffs, ) ) vs. ) ARMSTRONG WORLD INDUSTRIES, ) ) INC., ) vs. ) MONSANTO COMPANY AND AMERICAN) MINERAL SPIRITS COMPANY, ) Defendants. ) Cause No. L-95-CV 02849 (JBS) DEPOSITION OF JOHN H. CRADDOCK Taken on Behalf of the Defendants November 13, 1997 Condensed Transcript and Word Index Taylor & Associates Reporting, Inc. MM Kl KIIMMMIKS 7494 ETHEL AVE. ST. LOUIS, MISSOURI 63117 PHONE: (314) 644-2191 1-800-280-DEPO DepoNet.^ STLCOPCB4025564 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock . Cause No.: L-9S-CV02848(JBS)___________ _____________________________ November 13, 1997 1 INDEX OF QUESTIONERS 2 QUESTIONS BY: Page Page 1 i 2 APPEARANCES For the Plaintiff; Page 3 ] ' 3 Kr. O'Connor 4 Ms. O'Connor Mr. 5 Kr. O'Connor Kr. DiMuro 6 4 3 LAE OFFICES OF GARY D. GINSBERG 96 BY: Brian P. O'Connor 11S 4 11 Atrium U, Suite 101 116 3000 Atrium Way 123 5 Mt Laurel, New Jersey 08054 128 (709) 727-1991 6 7 INDEX OF DEFENDANT'S DEPOSITION EXHIBITS fl *0. DESCRIPTION MARKED 9 1 A Perspective 32 2 Letter dated 11/13/81 41 10 3 Letter dated 3/17/92 45 4 Letter dated 3/25/92 47 11 5 News release 47 6 Epidemiology of PCBs 47 12 7 Letter dated 4/1S/92 54 6 Letter dated 9/15/92 57 13 9 Monsanto Backgrounder 58 10 Report/J.Craddock 64 14 11 Nova Transcript 65 12 Letter dated 4/4/86 71 IS 13 Letter dated 4/8/86 78 14 Memo dated 6/10/86 90 16 IS Letter dated 9/16/87 93 16 Letter dated 7/25/66 127 17 Exhibits attached IB 19 7 For the Defendant Monsanto Company: 8 LATHAM & WATKINS BY: Christopher M. DiMuro 9 One Newark Center Newark, New Jersey 07101-3174 10 (973) 639-7298 11 SMITH HELMS MULLISS L MOORE. L.LP. BY: Gerard H. Davidson, Jr. 12 300 North Greene Street, Suite 1400 P. O. Box 21927 13 Greensboro, North Carolina 27420 (910)378-5267 14 15 For the Defendant Armstrong World Industries, Inc.: 16 DUANE. MORRIS & HECKSCHER. LLP 17 BY: Craig F. Turet One Liberty Place 18 Philadelphia, Pennsylvania 19103*7396 (215)979-1000 19 20 20 For the Defendant (Present Telephonically) 21 21 WILSON, ELSER. MOSKOWITZ. EDELMAN &. DICKER BY: Carolyn O'Connor 22 22 Two Gateway Center Newark, New Jersey 07102*5311 23 23 24 24 25 25 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY 2 JOAN MAERTIN, Executrix of ) 3 the Estate of Loth&r ) Maertin, JOAN MAERTIN, ) 4 Individually and in her ) Cause No. L-95-CV own right, et al., ) 02B49 (JBS) S Plaintiffs, ) vs. ) 6) ARMSTRONG MORUJ INDUSTRIES, ) 7 INC vs. * ) 8 MONSANTO COMPANY AND AMERICAN) MINERAL SPIRITS COMPANY, ) 9 Defendants. ) 10 11 DEPOSITION OF JOHN H . CRADDOCK, 12 produced, sworn and examined on the 13th day of 13 November, 1997, between the hours of eight 14 o'clock in the IS Taylor 16 4 Associates, Inc., 7494 Ethel, St. Louis, 17 Missouri, before Nancy A. Kuncaitis, a IB Registered Professional Reporter and Notary 19 Public within and for the state of Missouri in 20 the cause now pending in the United States 21 District Court for the District of New Jersey, 22 wherein Joan Maertin et al. are the Plaintiffs, 23 and Armstrong Norld Industries, Inc. , and 24 Monsanto Company and American Mineral Spirits 25 Company are the Defendants. Page 2 i 2 3 4 5 6 7 Page 4 IT IS HEREBY STIPULATED AND AGREED by and between Counsel for the Plaintiff and Counsel for the Defendant that this deposition may be taken by Nancy A. Kuncaitis, Notary Public and Registered Professional Reporter, thereafter transcribed into typewriting, with the signature of the witness being expressly reserved. 8 9 JOHN H. CRADDOCK, 10 of lawful age, being produced, sworn and 1! examined on behalf of Defendant, testified as 12 follows: 13 14 EXAMINATION 15 QUESTIONS BY MR. TURET: 16 Q.Good morning. Dr. Craddock. Would you just 17 state your full name for the record, please? 18 A. John Harvey Craddock. 19 Q. Have you been deposed before today? 20 A. Yes. 21 Q. On more than one occasion? - 22 A. Yes. -n 23 Q. You're probably familiar with this. I'm going 24 to ask you a series of questions this morning. 25 You'll be expected to answer as completely as Page 1 - Page^ STLCOPCB4025565 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock Caase No.: L-95-CV02848(JBS)November 13, 1997 Page 5 Page 7 1 you can. I'm not asking you to speculate or 1 polychlorinated biphenyls or other hydrocarbons? 2 guess. If you don't understand my question or 2 A. Well, I guess in general they would relate to 3 you don't hear it, let me know. I'll be happy to 3 anything. I had a course in chemical toxicology 4 repeat it or rephrase it, but if you do answer a 4 at the Jefferson Medical School in Philadelphia 5 question I'll assume you heard it and understood 5 which was about a week course, just in 6 it; is that acceptable? 6 toxicological principles as applied to testing 7 A.That's fine. 7 of chemicals in general. I've had courses that 8 Q.If you need to take a break at any time let me 8 related to specific aspects of chemicals. 9 know. We'll be happy to accommodate you as long 9 coatings, formulations or disposal of chemicals, 10 as there is not a question outstanding. Also, 10 that sort of thing. 11 sir, do you understand that your testimony today 11 Q. You mentioned coatings and formulations. What 12 is being taken down by the court reporter and 12 courses have you taken that relate to those 13 will be a written transcript when we're done? 14 A. Yes, I do. 13 subjects? 14 a. It was just a simple course at an American 15 Q.And you understand if for any reason you're not 15 Chemical Society meeting where they have 16 available at the time of trial in this case that 16 continuing education courses and just something 17 transcript could be admitted in your absence 17 that looked interesting and intriguing. It 18 just as if you were testifying? 18 really had nothing to do with any work that 1 19 A. Yes. 19 had going on at the time or anticipated. 20 Q.Dr. Craddock, could you just give us a thumbnail 20 Q. Was anyone from Monsanto on the faculty of that 21 sketch of your educational background? 21 particular seminar? 22 A. I got an undergraduate degree in chemistry from 22 A. No. 23 Memphis State University in 1958. I went to 23 Q. Mr. Darby or any of those folks were not 24 graduate school at Vanderbilt University in 24 involved? 25 Nashville, Tennessee, and graduated with a Ph.D. 25 A. No. Page 6 Page 8 1 in chemistry in 1961. 1 Q. When did you begin your employment with 2 Q.Do you have a master's degree as well? 2 Monsanto? 3 A. No. 3 A. May of 1965. 4 Q. Was there a particular area of specialization 4 Q. Did you work anywhere before coming to Monsanto? 5 within chemistry? 5 A. Yes, I worked for the MW Kellogg Company in 6 A. Inorganic chemistry. 6 major offices in New York City, and the 7 Q. Inorganic chemistry? 7 laboratory was in New Jersey. Primarily I was 8 A.Inotganic chemistry. 8 assigned to the laboratory. 9 Q. Inorganic, one word? 9 Q. What types of lab work did you do for MW 10 A. Inorganic, one word. 10 Kellogg? 11 Q.How does inorganic chemistry differ from organic 11 A. MW Kellogg was a construction engineering 12 chemistry? 12 company primarily into the design of petroleum 13 A. Organic chemistry is generally the chemistry of 13 refineries and petrochemical processes, and I 14 the carbon atom, and inorganic chemistry is the 14 was involved in a new area of the chemistry at 15 chemistry of all the other elements essentially. 15 the time that was the homogeneous catalyses 16 Q. Did you do a doctoral dissertation? 16 systems for producing petrochemicals from 17 A. Yes. 17 hydrocarbon extractions derived from oil 18 Q. What was the subject? 18 refining. 19 A. The racemization of optically active arsenic 19 Q. Did you say you were with MW Kellogg from 1961 20 five complexes. 20 to 1965? - 21 Q. Sorry I asked. Have you done any further course 21 A. Right. 22 work since receiving your Ph.D. back in 1961? 22 Q. How did you come to be employed by Monsanto? 23 A. I've taken some odd courses and continuing 23 A. Monsanto ran an ad in some of the basic journals 24 education courses off and on. 24 or magazines, trade magazines, Chemical Engineer 25 Q. Are there any that would relate directly to 25 News was one. They were forming a new group to ------------;---------U* Page 5 - Page 8 STLCOPCB4025566 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock . Cause No.: L-95-CV02848(JBS)November 13, 1997 Page 9 Page 11 1 investigate homogeneous catalyses. And at the 1 became a group leader then I was responsible for 2 time I was looking to change jobs from New York 2 the work of a group of other chemists. 3 City, and anywhere but New York City. And it 3 Q. How long did you remain a senior group leader? 4 was a good opportunity, it was a new field and I 4 A, Until I left the research department in roughly 5 was one of the few people that was working in 5 1973. 6 that field at the time, maybe 100 or so in this 6 Q. Where did you go next? 7 country. 7 A. I became a manager of commercial development and 8 Q. What was the position that you first assumed 8 I went to what was then the hydrocarbon and 9 with Monsanto? 9 polymers division. 10 A. Probably research chemist or research 10 Q. Were PCBs included within the hydrocarbons and 11 specialist, something like that. 11 polymers division? 12 Q.How long did you remain a research chemist or 12 A. No. 13 specialist? 13 Q.As manager of commercial development, did that 14 A. Probably a year. 14 include research on new applications for 15 Q. During that time did you do any work with 15 existing products? 16 polychlorinated biphenyls? 16 A. Actually, it was -- we had developed a whole 17 A. Not that I recall. 17 family of catalysts to manufacture some 18 Q. Which division were you in as a research 18 petrochemical products in the laboratory. And 19 chemist? 19 as part of the function, the research people 20 A. The corporate research department. 20 keep hollering why don't you put this stuff into 21 Q. What position did you assume in 1962? 21 practice, and ultimately 1 was transferred to 22 A. Senior research chemist or research specialist 22 the commercial development manager to transfer 23 whatever the title was at the time. 23 this technology from the research function to 24 Q. Was that within the same division? 24 the manufacturing function which was the 25 A. Same division. 25 hydrocarbons and polymers division. So I Page 10 Page 12 1 Q.Was the subject matter of your research the 1 essentially moved to the H and P division and 2 same? 2 took the technology that we developed with me to 3 A. Yes, it was, homogeneous catalyses. 3 move it into the manufacturing division. 4 Q.How long did you remain a senior research 4 Q. How long did you remain as manager of commercial 5 chemist? 5 development? 6 A. Probably another year or two, something like 6 A. From '73 to about - well, again, there is 7 that. 7 another title change in there which essentially 8 Q. What position did you assume then? 8 is a salary grade thing, but 1 was in commercial 9 A. Research group leader. 9 development in H and P until roughly '77. 10 Q.Was that also within the same group? 10 Q.What position did you assume in 1977? 11 A. Same group. 11 A. Wait a minute, let's see, take it back. There 12 Q.How long did you remain a research group leader? 12 was an interim job in there sometime roughly -- 13 A. Probably a couple of years. 13 1 moved from H and P to Monsanto Industrial 14 Q.So until 1966 or so? 14 Chemicals Company into the food and fine 15 A.No, we're up to probably about 1970 now, aren't 15 chemicals business group. That's roughly this 16 we, a year or two years here and there would be 16 '75-'76 time frame, somewhere in there. 17 probably up about five or six years now, about 17 Q. Also as a commercial development - 18 '70 or '71. 18 A. Commercial development manager, and essentially 19 Q. Again, the subject matter of your research was 19 we moved the technology that we had taken to the 20 the same? 20 H and P division which we were now manufacturing, 21 A. Same thing. 21 and we were trying to sell the product, once we 22 Q.What position did you assume in 1970 or '71? 22 could make the product we-were trying to sell 23 A. I became a senior group leader or something like 23 the product through new uses and applications. 24 that. These are essentially salary grade 24 And the most promising applications were back in 25 changes, same work, same job except that as I 25 food preservatives. And so 1 again moved with Page 9 - Page 1 STLCOPCB4025567 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock Cause No.: L-95-CV02848(JBS)November 13, 1997 Page 13 Page 15 1 the product back into the operating unit which l responsibilities did you have that led you to 2 would be selling the products which we were now 2 communications with the FDA and Department of 3 making in H and P. 3 Agriculture? 4 Q.That brings us up to 1977? 4 A. In the food and fine chemicals area my primary 5 A. About 1976, 1977. 5 responsibility was with food preservative 6 Q.What position did you assume then? 6 chemicals. We were adding to our portfolio. We 7 A.Probably in '76, '77 I was still in food and 7 had been reselling absorbic acid and potassium 8 fine, and about 'll, '78, at that point in time 8 sorbates which are food preservatives which were 9 I moved into the -- this was a new group formed 9 regulated by the USDA, which were allowed to be 10 in the Industrial Chemicals Company which was 10 used, and we were buying the process from the 11 the environmental operations group, and I moved 11 Japanese to manufacture those food additives in 12 into the environmental operations group about 12 this country. So my function was to find new 13 that time 'll, '78 somewhere like that. 13 ways to use these chemicals to be able to sell 14 Q.And this environmental operations group was 14 the output of a full fledged plant that would be 15 within which division? 15 manufacturing these chemicals. 16 A. Still it was in the Monsanto Industrial 16 Q. In your efforts to find new uses, did that 17 Chemicals Company. It was a staff operations 17 require additional submissions to these 18 group there. 18 agencies? 19 Q.What was the function of the environmental 19 A. It required testing, yes, submitting data to the 20 operations group? 20 agencies, whatnot. 21 A. At this point in time the Toxic Substances 21 Q. Where these submissions written submissions or 22 Control Act had been passed, the first rules 22 were you called upon to go down to Washington to 23 were promulgated in about the summer of 1978 and 23 meet with the agencies? 24 the company was gearing up to be able to 24 A. Both. 25 implement those regulations within the operating 25 Q. How frequently did you actually meet with the Page 14 Page 16 l companies. So I moved into the environmental 1 people down there? - 2 operations group as manager of activities that 2 A. When you deal with regulatory agencies, we would 3 were related to TSCA, Toxic Substances Control 3 call them quarterly, or if we had new data we 4 Act. And it was my job to implement the 4 went in as new data was available. If they 5 regulations in the operating manufacturing 5 requested information we would go in and present 6 facilities for the Industrial Chemicals 6 the information as requested. 7 Company. We had about 35 plants in the U.S. at 7 Q. On average was it quarterly or more frequently? 8 that time, 33 to 35. 8 A. Probably on the order of every other month or 9 Q.That was a new area for you, wasn't it? 9 so. 10 A. Well, it was a new area for everybody because 10 Q. Other than the FDA and U.S. Department of 11 TSCA had not been into effect. But when I was 11 Agriculture, were there other agencies that you 12 in the food and fine chemicals company my area 12 regularly dealt with in your capacity at the 13 was dealing with regulatoiy agencies because we 13 food and fine chemicals? 14 were dealing with food additives. And so I 14 A. No, that was it. 15 dealt with the Food and Drug Administration and 15 Q. Jumping back to your environmental operations 16 with the U.S. Department of Agriculture which 16 group, what did you do when you first started to 17 had responsibility for regulating food chemicals 17 get ready for that position? 18 and pharmaceutical intermediates. When TSCA was 18 A. First thing to do is get a copy of the 19 formed they were looking for anybody that had 19 regulations and try to read them and understand 20 any experience to deal with governmental 20 what was required of the plants under the new -- 21 regulatory agencies so it was a logical 21 regulations that were corning in. There were 22 progression from one regulatory agency to a new 22 requirements for reporting,-record keeping, 23 regulatory agency. 23 submission of information, everything from 24 Q.Let me go back for a second to your time in food 24 production volumes to disposal methods. 25 and fine chemicals. What types of 25 whatever. Page 13 - Page 16 STLCOPCB4025568 Joan Maertin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock _______ November 13, 1997 Page 17 Page 19 1 Q. Did you go within Monsanto to educate others 1 it banned the use of PCBs except for all 2 within the company as to what their obligations 2 authorized uses. So it did not ban PCBs, it 3 were? 3 just set up a restricted list for which PCBs 4 A. Yes. 4 were allowed to be continued to be used and they 5 Q.Were there others who also were given the 5 are allowed to be used today. 6 responsibility for mastering the aspects of 6 Q.What were these authorized uses? 7 TSCA? Do you know what you I mean when I refer 7 A. Primarily electrical uses. There were several 8 to TSCA? 8 others. 9 A. Yes. In other operating units, there were 9 Q. When you say electrical, does that include 10 people that were responsible for TSCA and there 10 transformers? 11 were people at the plants that were responsible 11 A. Primarily transformers, power distribution 12 for TSCA. My function was to coordinate these 12 systems, transformers, capacitors, oil field 13 activities overall for the chemical company, the 13 cable, switches, closers, anything that has to 14 Industrial Chemicals Company. 14 do with power transmission. 15 Q. At that time was the - were PCBs still being 15 Q. Did you in your capacity as -- actually what was 16 manufactured at the time you were-- 16 the official title when you were moved into the 17 A. No. PCBs had not been manufactured since 17 environmental operations group? 18 roughly '76,1 think. 18 A.God, I don't remember. Title changed some. 19 Q. To the extent that there were regulations or 19 Probably just manager of environmental control 20 provisions that related specifically to PCBs, 20 TSCA, something of that nature. 21 did that come under your domain? 21 Q.Just to round out the employment history, how 22 A. Yes. 22 long did you remain at manager of environmental 23 Q. What did you do specifically to learn the area 23 control or whatever the precise title was? 24 as it related to PCBs? 24 A. Until June of 1980. 25 A. Primarily it was a matter of reading the 25 Q. What position did you assume then? Page 18 Page 20 1 regulations and outlining and documenting the 1 A.Then I became -- I've forgotten the exact title, 2 requirements that had to be met. A big area of 2 but essentially 1 became the product 3 TSCA had to do with the PCB regulations at the 3 environmental safety manager with responsibility 4 time, which required an inventoiy of PCBs in use 4 for PCBs. 5 at the manufacturing facilities, how they were 5 Q. How long did you remain in that position? 6 used, whether they came under the use 6 A. Until I retired February 1st, 1993. 7 authorizations, which were primarily electrical 7 Q.Have you remained retired since February of '93? 8 equipment at the time, and a couple of dozen 8 A.Semiretired. I do consulting a little bit. I'm 9 other small items, setting up disposal 9 semiretired. 10 facilities, record keeping systems which were 10 Q.What types of consulting have you done since 11 consistent with TSCA regulations, reviewing 11 '93? 12 disposal contractors to assure they met the 12 A.I've done all sorts of things. I've done lots 13 requirements of TSCA. And we prepared a list of 13 of things related to super fund sites 14 specific contractors who were authorized under 14 contaminated with PCBs, apportion of costs, cut 15 TSCA to dispose of PCBs or store PCBs, whatever 15 shares cost for disposal depending on usage. 16 was required at the time. In the early days 16 I've been an expert witness for a federal 17 that was a disposal hiatus because TSCA required 17 magistrate in New York City, a Court's expert in 18 disposal of PCBs and there were no facilities in 18 a case involving PCB dioxin contamination of an 19 the country available to dispose of PCBs, so 19 industrial site where there was an industrial 20 PCBs essentially had to be stored. 21 Q. Based on your study of the TSCA legislation, as 20 fire. I've consulted with clients which were - 21 charged with improper disposal of PCBs by EPA in 22 of 1977 or '78 when you assumed the position, 22 their behalf to refute and dispel these 23 did TSCA ban the use of PCBs? 23 allegations, a variety of things. 24 A. TSCA banned the use of PCBs in the regulations 24 Q. I guess 1 jumped out of sequence. Let me go 25 of issue May 31, 1979. Essentially what it did. 25 back to the product environmental safety manager STLCOPCB4025569 Joan Maertin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock _____________ _________________ November 13,1997 Page 21 Page 23 1 position with responsibilities for PCBs. What i to decide who was responsible for the costs - 2 specific duties and responsibilities did you 2 associated with the cost of cleaning up this 3 have during your three year stint or so in that 3 plant site after this fire. 4 position? 4 Q. Where was the fire in New York City that was at 5 A. Where are we now, back in the Industrial 5 issue? 6 Chemicals Company prior to 1980? 6 A. The fire was not in New York City. The trial 7 Q.No, this would be June of 1980 until February of 7 was in the federal court in New York City for 8 1993,1 believe you testified you were product 8 that district, whatever it was. 9 environmental safety manager? 9 Q. Where was the fire itself? 10 A. So that's 13 years; I thought you said three 10 A. West Virginia, a plant in West Virginia. 11 years. That's what confused me. My primary 11 Q. Have you ever done any consulting work in a case 12 responsibility was I was the corporate focal 12 that involved alleged personal injury due to 13 point for PCB questions and PCB issues within 13 alleged exposure to PCBs? 14 the company. My job was to see that all of our 14 A.I guess I've been involved in cases that 15 plants uniformly complied with the PCB 15 involved exposure to PCBs. I don't know if 16 regulations which came in under TSCA. My office 16 there was ever any litigation involved with 17 also answered any questions or inquiries that 17 respect to that, but there has been alleged 18 came in relating to PCBs from former customers. 18 exposure, yes. 19 regulatory agencies, our own plants, news media. 19 Q. And have you ever been retained to provide 20 the general public, anybody with questions 20 information about alleged health hazards in the 21 related to PCBs, they were channeled to this 21 abstract that might be associated with exposure 22 office. 22 to PCBs? 23 Q. Did you handle that entire function for yourself 23 MR. DiMURO: Object to the form. 24 for the 13 years? 24 A. Yeah, I guess 1 don't quite understand what you 25 A. I had various staff members assist me. 25 want. Page 22 Page 24 1 Sometimes I had another chemist, or secretaries. 2 whatever. In addition, at my disposal 1 Q. Well, was the subject matter of your 2 consultancy, if that's a word, the compliance or 3 Monsanto's entire resources, the medical 4 department, the engineering department, 3 non compliance with regulations? 4 A. In some cases, yes. 5 analytical department, whatever resources we had 5 Q. Was it ever on toxicological or medical aspects? 6 there that if their services were required they 6 MR. DiMURO: Object to the form 7 were available. 7 again. 8 Q. When you referred to the different subjects that 8 A. I've been asked about health effects of PCBs, 9 you've addressed as consultant, have the 9 but generally when a case or something revolves 10 consulting projects been more for Monsanto or 11 for others? 12 A. For others. 10 around PCBs my recommendation to the client is 11 get a medical expert or toxicologist or someone 12 like that and if necessary they can get those 13 Q. Have you done any consulting work for Monsanto? 13 people. 14 A. No, not that I recall. 14 Q. Have you ever been retained to provide 15 Q. How did your position come about as expert 16 witness for the magistrate in New York City? 15 information about Monsanto's actions or 16 Monsanto's knowledge with regard to PCBs? 17 A. Reputation as being knowledgeable, unbiased and 17 A. Retained by other clients to ask me about 18 so forth. I don't know how the judge got my 18 Monsanto? 19 name. I think he asked the plaintiffs and the 19 Q. Yes. 20 defendants to submit lists of people that were 21 known to them to be knowledgeable in the general 20 A. No. 21 Q. Dr. Craddock, in the course of your career have 22 area of PCBs and who they felt would address the 22 you been involved in trade associations or 23 issue in an objective manner. 24 Q. Was that a personal injury claim? 23 organizations? 24 A. Yes. 25 A.No, this involved an insurance company's trying 25 Q. Which ones have you been involved in? Page 21 - Page 24^- STLCOPCB4025570 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock . Cause No.: L-95-CV02848(JBS)November 13,1997 Page 25 Page 27 1 A. Talking about my total career or my PCB career l Q. What was National Electrical Manufacturers 2 or what point in time? 2 Association? 3 Q. Let's start after you left the research 3 A. It was a trade association of manufacturers of 4 department in, say 1973? 4 electrical equipment including, they had a 5 A. In the hydrocarbon company there were trade 5 division which included manufacturers of 6 associations that had to do with manufacture and 6 transformers, capacitors, power transmission 7 sale of hydrocarbon chemicals. I'm hard pressed 7 equipment, but they had all sorts of other 8 to think what they were at the time. Attended 8 divisions, too. 9 meetings, I think National Petroleum Refineries 9 Q. How long were you a member of the Chemical 10 Association in Texas which had to do with 10 Manufacturers Association? 11 procuring and refining crude oil which the 11 A. Until 1 retired. 12 hydrocarbon polymers plants did. In food and 12 Q. Was the PCB panel in existence throughout 13 fine chemicals division I was a member of the 13 your - 14 Institute of Food Technologists, attended all 14 A.It was formed roughly in '80, '81 late '80, 15 the conferences for the Institute of Food 15 early '81 and it was in existence throughout 16 Technology. And there were probably a half 16 that time and still is in existence today to my 17 dozen different trade associations involved with 17 knowledge. 18 that that I attended meetings. Sometimes I 18 Q. Were you a member of the PCB panel? 19 joined these groups, that's how you get to go to 19 A. I was a member of the panel for three or four 20 the meetings, you pay your dues and get to go, 20 years and I was chainnan of the panel for about 21 but I don't recall the names of those. 21 10 or 12 years. 22 Q. Did you hold any offices within those 22 Q. How large a panel was it? What was its 23 organizations? 23 membership? 24 A. No. 24 A. It varied. Usually it had an average membership 25 Q. How about once you became involved in the PCBs? 25 of probably eight to ten. In times of high Page 26 Page 28 1 A. After 1980 when I became involved in PCBs 1 1 stress, new regulations or whatever the type of 2 became very active with the Chemical 2 activities it was doing, it could jump as high 3 Manufacturers Association PCB panel. They 3 as 15 or 20. That's the CMA time. 4 actually set, the Chemical Manufacturers 4 Q. What other companies or organizations were 5 Association actually set up a panel of its 5 active through their representatives in the PCB 6 members to try to set up uniform processes or 6 panel. 7 standards within the chemical industry as to how 7 A. Are you talking about the CMA PCB panel? 8 to handle the response to tsca PCB regulations. 8 Q.Yes. 9 Ultimately the CMA group became involved with 9 A. Dow Chemical was involved, Dupont, Union 10 other trade association groups which sort of 10 Carbide, most of the major chemical 11 banded together to address the same issues, 11 manufacturers, mainly because they all had 12 which included the National Electrical 12 electrical equipment. You can't run a chemical 13 Manufacturers Association, the USWA group, 13 plant without electrical equipment. PCB regs 14 Utility Solid Waste Activities group, all sorts 14 primarily regulated electrical equipment. 15 of groups like this which were involved in PCB 15 disposal of the electrical equipment from the 16 activities. 16 manufacturer. 17 Q.What is the EEI? 17 Q.Did any of the organizations that you've 18 A. Edison Electric Institute. 18 mentioned get involved in lobbying activities? 19 Q. Were you at all involved in the Edison Electric 19 A. No, we were not registered lobbyists. We were 20 Institute? 20 involved in activities. We provided data to the - 21 A. USWA was a part of EEI. USWA was a subgroup of 21 regulatory agencies, CMA intervened in a lawsuit 22 EEI. 22 filed by the -- it was a lawsuit filed against 23 Q.What was EEI? 23 EPA over the original issuance of the PCB 24 A. It was a trade association of electric 24 regulations to remand the regulation as it was 25 utilities. 25 filed by, 1 think the Jackie Warren group. I -------- ------ ------------ " " -------------- Page 25 - Page 2^?" STLCOPCB4025571 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock Cause No.: L-95-CV02848(JBS)November 13,1997 Page 29 Page 31 1 can't remember the name now. l Chemical Manufacturers Association that you were 2 Q. What was the substance of the allegations? 2 actively involved in during your involvement 3 A.That the PCB regulations didn't go far enough or 3 with PCBs? When I say involvement with PCBs, 4 that there was no basis in scientific fact for 4 you understand I'm talking about - 5 establishing whether it be 50 parts per million 5 A. There was a coalition that was formed between 6 cutoff was one issue. And allowance of 6 CMA, ultimately formed between CMA, NEMA., uswa 7 electrical equipment that was totally enclosed, 7 and the Environmental Defense Fund which worked 8 that was another issue. There were several 8 with EPA to propose guidelines for the new 9 issues. CMA entered that lawsuit as an 9 regulations. And this was as part of the 10 intervenor along with the Edison Electric 10 settlement of whatever this intervention in this 11 Institute USWA group along with NEMA. 11 lawsuit was. So I worked with this group for -- 12 Q. On whose behalf? 12 at the same time that 1 worked with the CMA 13 A. On behalf of their industries. 13 groups. The groups met separately, they met 14 Q.On which side of the dispute? 14 together, they met with EPA. 15 A.They were on -- I guess I don't know whether 15 Q.The lawsuits you referred to before by the 16 this was like a friend of the court or what. 16 Environmental Defense Fund against the EPA? 17 They weren't really taking sides at the time. 17 A. Right. 18 Q. What was the position they were bringing to the 18 Q. Were settled? 19 Court with regard to the regulations contained 19 A. Judge Edwards ultimately resolved it and said 20 within TSCA? 20 that it required EPA to go back and revisit the 21 A.The industries' position was that in some cases 21 rules and to either propose justification or 22 the --1 guess it was generally supporting EPA 22 propose new regulations. And at that point in 23 at this time. 23 time, every time they proposed new rules there 24 Q.And was that specifically on the regulations 24 was a comment period. And the industry working 25 that related to PCBs? 25 groups essentially would propose comments on Page 30 1 A. Strictly on the regulations that related to 2 PCBs. 3 Q.Now, did, to your knowledge, the Chemical 4 Manufacturers Association have lobbyists that l 2 3 4 Page 32 what EPA had proposed for the new regulations as well as the environmental groups. Ultimately it got to where the environmental and the industry groups together were working and trying to find 5 were in Washington lobbying with respect to 6 these proposed regulations? 7 A. Well, the Chemical Manufacturers Association had 8 registered lobbyists in Washington. I don't 9 think -- I don't know if they specifically 10 lobbied with respect to these regulations. 11 Q. Who proposed the intervention into the lawsuit? 12 A.I don't know. 13 Q.Did you personally advocate one way or the other 14 as to whether the CMA should get involved? 5 a workable system to implement the regulations. 6 Q. What was your role in that whole set of 7 activities? 8 A. 1 was chairman of the CMA group and I was 9 chairman for the working group for a point in 10 time. 11 Q.The working group you're referring to was the 12 one with representatives in NEMA and USWA and 13 the Environmental Defense Fund as well as CMA? 14 A. Right. 15 A.I don't think I had any input as to whether CMA 16 should get involved into the lawsuit or not. I 17 was just a member -- this was a technical 18 panel. Our function was to provide technical 19 data to CMA, to the companies, and to EPA. EPA 20 would from time to time ask for all sorts of 21 data and our job was to try to find a way to do 22 surveys or whatever, to provide this data on the 23 use of equipment and disposal of equipment, PCBs 24 in general. 25 Q. Were there any other committees other than the 15 Q. You said you also chaired that working group and 16 you also chaired -- 17 A. The CM A panel separately. 18 Q.That was the panel you referred to earlier? 19 A. Yes, CMA PCB panel. 20 MR. TURET: Let me have this marked 21 Craddock 1. 22 (A Perspective -- 23 marked as Exhibit No. 1 24 for identification.) 25 MR. TURET: Can we take a quick - Page 29 - Page 32 STLCOPCB4025572 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock . Cause No.: L-95-CV02848(JBS)November 13, 1997 Page 33 Page 35 1 break? 1 A. Yeah, it varied. As I say, this was originally 2 (Brief recess.) 2 written for a speech in Dayton, Ohio. At one 3 MR. TURET: Back on the record. 3 time I think there was somebody called a 4 Carolyn, are you still there? 4 Building Owners and Management Association in 5 MS. O'CONNOR: Yes, I am. 5 Seattle, Washington that I gave a presentation 6 Q.For the record, the document that's been marked 6 to. It varied. 7 Craddock 1 is a document that is entitled 7 Q. Did you give presentations in-house for any of 8 Polychlorinated Biphenyls, A Perspective. It's 8 the present or former customers of Monsanto? 9 by John H. Craddock, Monsanto Bates numbered MAE 9 A.In-house, you mean in Monsanto's house? 10 010245 through 257. Dr. Craddock, have you seen 10 Q.No, I mean like, say, a GE for example, did you 11 the document that's been presented to you as 11 ever go to a General Electric and give a 12 Craddock 1? 12 presentation to employees of GE? 13 A. Yes. 13 a.No, I don't recall giving any presentations or 14 Q. Is that a document you authored? 14 being requested to give presentations for 15 A. Yes, it is. 15 employee groups. I had lots of dealings with 16 Q. What is it exactly? 16 General Electric and my counterparts at General 17 A.It's essentially what the title says, it's a 17 Electric, but never employee groups. General 18 perspective on PCBs at the time it was written 18 Electric, by the way, was a member of the CMA 19 in 1981. 19 PCB panel. They had a chemicals division. 20 Q.There is a date on the bottom, January 22, '81. 20 Q. Was Westinghouse on it as well? 21 Is that when it was published? 21 A. No, but Westinghouse was in the NEMA group. GE 22 A. Right. 22 was also in the NEM^ group because they had a 23 q.To whom was it disseminated? 23 power transmission division, and different hats, 24 A.It's primarily a document I used as the basis 24 different companies. 25 for speeches or oral presentations to various 25 Q. Did anybody else provide substantive information Page 34 Page 36 1 groups who would ask for presentations on PCBs. 1 to you that was incorporated into this Craddock 2 Q. Was that a part of your job responsibilities at 2 1? 3 that time? 3 A. Well, probably. If I needed information about 4 A. Yes. 4 health effects or interpretations 1 went to 5 Q.That was when you were manager of environmental 5 Monsanto's medical department, into literature. 6 control? 6 Q. Who at the medical department of Monsanto did 7 A.No, this was after 1980. It was when 1 had the 7 you seek out information from when you needed 8 separate responsible for PCB issues. 8 it? 9 Q.Okay. When you were product environmental 9 A. Epidemiology would have been Dr. Bill Gaffey. 10 safety manager? 10 Medical effects would have been the head of the 11 A. Correct. 11 medical department at the time was George 12 Q.How frequently were you called upon to give 12 Roush. Toxicology, interpretation would have 13 presentations to others on PCB issues? 13 been Dr. George Levinskas who was head of the 14 A.It varied. In the early '80s maybe every six to 14 toxicology department. Industrial hygiene, 1 15 eight weeks, something like that. 15 don't know who was the director of the 16 Q. What types of organizations did you appear 16 industrial hygienists at the time but we had 17 before? 17 one. Whatever information 1 needed, the 18 A. I think this was originally written for the 18 resources were there, and that's where I could 19 Chamber of Commerce of the city of Dayton, Ohio, 19 get the information. 20 who was having a meeting about PCB electrical 20 Q. On Page 3 of Craddock 1, when you were - 21 equipment in their town, but it ranged for 21 discussing properties and uses of PCBs there is 22 everything from chambers of commerce, PTAs, 22 a reference to very low vapor pressure of PCBs. 23 trade associations, groups who had an interest 23 What does that mean? 24 in TSCA and PCBs. 24 A. It means it does not evaporate or volatilize 25 Q. Was that organizations across the country? 25 into the air readily. Page 33 - Page 36 STLCOPCB4025573 Joan Macrtin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock _____ November 13, 1997 Page 37 Page 39 1 Q.Down below under distribution it states that 1 know who did the testing, but it's public 2 from 1930 to 1977 about 1.4 billion pounds of 2 testing data, yes. 3 PCBs were produced. Where did that information 3 Q. But the information itself was given to you from 4 come from if you recall? 4 the medical department or you got it from 5 A. Primarily came from Monsanto documents that were 5 somewhere else? 6 provided to the U.S. Government, 6 A. Well, by recollection it probably came from the 7 Q.Do you know one way or the other whether that 7 medical department or was reviewed by the 8 was the total of all PCBs produced throughout 8 medical department. It's out of a published 9 the world? 9 document. It could be a NIOSH document or 10 A.No, that's just U.S., I believe. 10 something that's a standard thing, but it came 11 Q. So is that just Monsanto? 11 through the medical department. I can say that. 12 A. Well, it's basically Monsanto. Monsanto was the 12 Q.When you say reviewed by, did this particular 13 major producer of PCBs in the United States. 13 document that's been marked as Craddock 1 have 14 EPA reports there were either one or two others, 14 to be reviewed by anybody before you could use 15 but Monsanto is a major player. 15 it as a basis for presentations outside? 16 Q.And at least as of 1981, half of that amount was 16 A. You say did it have to be reviewed by anybody. 17 still in use in electrical transformers and 17 There was no requirement that it had to be 18 capacitors? 18 reviewed by anybody, but in good common sense 19 A. That was an EPA estimate, yes, sir. 19 and judgment it was reviewed by the experts in 20 Q.That statement came from the EPA? 20 the field because they were the ones to make 21 A. Yes. 21 sure it was correct. My function was to provide 22 Q.Do you have any knowledge as to how much of the 22 as much information as was known about PCBs and 23 1.4 billion pounds are still in use today? 23 make sure that it was correct, and it was the 24 A. Very little. Just an educated guess, probably 24 up-to-date information of the time. 25 -- I haven't tracked this in years, but most of 25 Q. So you had Dr. Gaffey take a look at it? Page 38 Page 40 1 the electrical utilities have been retiring 1 A. I'm sure Dr. Gaffey looked at this. I'm sure 2 equipment, whatnot, so probably 10 percent or 2 Dr. Roush looked at it. 3 less still in use. That's just a guess. 3 Q.And Dr. Levinskas? 4 Q.Okay. Page 4, as of 1981 it stated that many 4 A. Dr. Levinskas. Any section in here that relates 5 European countries still allow and in some cases 5 to a particular medical function or a health 6 require use of PCB equipment for certain 6 function, those experts would have been asked to 7 applications. Do you know whether that's still 7 look at it to make sure that the statements were 8 true today? 8 correct, make sure there were no typographical 9 A. The European countries have been phasing out 9 errors. It's very easy to go back, when you're 10 PCBs and the manufacturers of the European 10 doing something not exactly in your field to 11 countries have been phasing out. When I left 11 take it out of context or something. So they 12 Monsanto in '93,1 think maybe the French were 12 would have been the principals. 13 the only ones that were still manufacturing 13 Q.The parenthetical at the end of that sentence 14 PCBs. Whether they're still manufacturing them 14 says. Similar to NaCL dash salt, is that table 15 today or not, I don't know. PCBs are still used 15 salt? 16 in Europe. The European regulations parallel 16 A.That's table salt, and that has an oral 17 the U.S. EPA regulations, so I'm sure there is 17 ingestion level in that range. It's in the 18 still a lot of electrical equipment they're 18 standard text. 19 still in. That is the big use. 19 Q.Page 12, the sentence, in total the human 20 Q.On Page 10, there is a statement, in the 20 epidemiology experience indicates an absence of - 21 classical short term exposure acute toxicity 21 morbidity (ill health) associated with 22 sense, PCBs are classified as slightly toxic by 22 significant exposure to PCBs> More importantly, 23 oral ingestion. Is that a statement that came 23 none of these studies found PCBs to cause cancer 24 from the medical department at Monsanto? 24 in humans. Is that something that came from Dr. 25 A. Yes. And that comes from testing data. I don't 25 Roush, Dr. Gaffey or Dr. Levinskas? ^ -----------------------------------------Aii Page 37 - Page 40 STLCOPCB4025574 Joan Maertin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock . _______ November 13, 1997 Page 41 Page 43 1 A. Well, I had read these studies at one time l Q. Is this the kind of letter that we talked about 2 myself. And my interpretation, and I wrote 2 before as one of your responsibilities to 3 this, and they agreed with what I had written. 3 comment on proposed rule making by agencies? 4 that these studies showed that there was an 4 A. Yes. 5 absence of ill health. 5 Q. On the third page of the letter, the paragraph 6 Q.And the last page, the conclusion that in some 6 that begins with "in addition"? 7 cases these compounds have been labeled by 7 A. Okay. 8 regulatory agencies, legislative bodies, the 8 Q. There are -- there is a statement that through 9 populace and the media as human cancer causing 9 reviews of the scientific and technical 10 agents and deadly toxins. However, the 10 literature relating to health effects of test 11 scientific evidence does not support these 11 animals exposed to PCBs by several independent 12 claims. Was that your view as of January of 12 bodies show that PCBs are not deadly toxins as 13 *81? 13 occasionally misrepresented in the news media. 14 A.That was my view in January of '81 and remains 14 Is that something that you wrote or is that 15 my view today. 15 something that was written as part of the letter 16 Q.I take it Dr. Roush, Dr. Levinskas and Dr. 16 for you? 17 Gaffey also signed off on these and can be 17 A. Well, I wrote this letter, this letter wasn't 18 included? 18 written for me. That was my opinion and still 19 A. I don't know if they signed off on it. They 19 is my opinion. 20 agreed with my conclusion. 20 Q. When you wrote this letter did you run it by any 21 (Letter dated 11/13/81 21 of the other departments before sending it out? 22 marked as Exhibit No. 2 22 MR. DiMURO: Object to the form. You 23 for identification.) 23 can answer. 24 Q.For the record, Craddock 2 is a letter signed by 24 A. I don't specifically recall, but as I stated 25 John Craddock dated 11/13/81, addressed to 25 previously, when I sent out a document, 1 Page 42 Page 44 1 Document Control Officer, EPA. Dr. Craddock, 2 have you seen this letter before today? 3 A. Yes. 4 Q. Is this a letter that you wrote to the EPA back 1 generally made sure that appropriate people who 2 could have any input would read it and comment 3 on it and so I'm sure that 1 did, but I don't 4 recall that particularly. 5 on November 13 of '81? 6 A. Yes, it is. 7 Q.What were the circumstances that prompted you to 5 Q. And was it your view then and now that any 6 impact of PCBs on the environment is so slight 7 as to be totally insignificant? 8 write this? 9 A. EPA filed a notice of proposed rule making and 10 this rule, as I recall, is called the closed and 11 control rule or incidental manufacture of PCBs, 8 A. Yes. 9 Q. Was it also the view of the other departments to 10 whom you showed this letter? 11 MR. DiMURO: Object to form. He 12 one of those two. 13 Q.What was the substance of that proposed 14 regulation? 12 didn't say he showed it to any other 13 departments. With that objection, you can 14 answer the question. 15 A. EPA was trying to - they had written an all 16 encompassing rule about PCBs and they failed to 17 recognize that PCBs could be manufactured 18 incidentally just in the course of chemical 19 reactions that were taking place. It's just a 20 statistical occurrence; small, but measurable 21 trace amounts of PCBs could be formed. So they 22 had to find a way out of the box. They had 23 banned certain processes and things. They had 24 taken the approach that any molecule of PCBs 25 were bad, but it wasn't a practical approach. 15 A. Nobody disagreed with my conclusion to suggest 16 that 1 change it, so 1 assume that they agreed 17 with it. They didn't disagree with it. That's 18 about all I can say. 19 Q. Did the EPA change their proposed rules that 20 were at issue in this letter? 21 A.They essentially wrote a new rule, yes. 22 Q. Did the new rule allow for-incidental -- 23 A. Yes. ' 24 Q. - creation of PCBs? 25 A. Yes. ,, Page 41 - Page STLCOPCB4025575 Joan Macrtin v Annstrong World Ind. Multi-PageTM Witness: John H. Craddock Cause No.: L-95-CV02848(JBS)______________________ November 13,1997 Page 45 Page 47 1 MR. DiMURO: Let him finish his i salt as well, yes. 2 question for the sake of the court reporter. 2 Q. And you're listed as a blind carbon copy. Was 3 THE WITNESS: Yes. 3 it customary for you to receive letters from 4 MR. DiMURO: I know you can 4 Monsanto Europe? 5 anticipate what he's going to say. 5 A. Any correspondence related to PCBs 1 was 6 MR. TURET: I also speak very slowly. 6 customarily copied on. 7 (Letter dated 3/17/82 7 Q. Was there any other location abroad other than 8 marked as Exhibit No. 3 8 Monsanto Europe that generated letters on behalf 9 for identification.) 9 of Monsanto relating to PCBs? 10 Q. For the record, Craddock 3 is a letter from DR 10 A. Well, the Brussels office of Monsanto Europe 11 Bishop to Mr. Robert Schofield, 11 generally handled questions related to Monsanto 12 S-C-H-O-F-I-E-L-D, dated March 17, 1982, MAE 12 Chemicals outside the U.S. So they would have 13 005905. Dr. Craddock, have you seen the letter 13 gone through, generally any inquiries would have 14 that's just been marked as Craddock 3 before? 14 gone through that office. 15 A. Yes, I have. 15 (Documents 16 Q. Who is DR Bishop? 16 marked as Exhibits Nos. 4, 5, 6 17 A. Dan Bishop was the director of the public 17 for identification.) 18 relations department at Monsanto at the time 18 (Discussion off the record) 19 period. 19 Q. For the record, we've now marked a document as 20 Q. Did you know Mr. Bishop as director of public 20 Craddock 4 which is a March 25, 1982 letter from 21 relations back in Monsanto in St. Louis as well? 21 Mr. Craddock that's Bates numbered M\E 054387. 22 A. Yes. 22 through 388. Craddock 5 is a news release. 23 Q. During this time he was in Monsanto Europe? 23 Bates number MAE 005907 to 908. And Craddock 6 24 A.No, I think he was in Europe at some point in 24 is a document that's entitled the Epidemiology 25 time but he was also in St. Louis. He may have 25 of PCBs, authored by William Gaffey, Page 46 Page 48 1 been in Europe at this time, but I knew him in 1 G-A-F-F-E-Y, and Bates numbered MAE 011777 2 St. Louis and in Europe when he came back. 2 through 807. 3 Q.Mr. Bishop makes the statement in the paragraph 3 Mr. Craddock, let's address each of 4 numbered one that there has never been a single 4 these in turn. Have you seen the document that 5 documented case of human cancer or any other 5 has been marked Craddock 4 before today? 6 chronic long-term illness attributed to Monsanto 6 A. Yes, I have. 7 manufactured PCB compounds anywhere in the 7 Q. Is that a letter that you wrote to Ms. Dolly 8 world. Would you have agreed with that 8 Katz of the Detroit Free Press back on March 25 9 statement back in March of 1982? 9 of '82? 10 A. Yes. 10 A.That's correct. 11 q.Do you still agree with that statement as of 11 Q. What is the Detroit Free Press? 12 today? 12 A.That's the major newspaper in Detroit, Michigan, 13 A. Yes, I do. 13 or it was major. I don't know whether it is 14 Q.In Paragraph 4 Mr. Bishop makes the statement 14 now. 15 that the acute oral toxicity of PCBs is roughly 15 Q. In the -- do you recall why it was that you were 16 the equivalent of common table salt and thus it 16 writing to Ms. Katz? 17 is considered to be only mildly toxic. Is that 17 A. Yes. She called me to discuss PCBs in general 18 the same statement we saw a few moments ago? 18 and a symposium that was taking place or had 19 MR. DiMURO: I'll object to the form 19 taken place. I've forgot which now, in 20 of the question. 20 Michigan. - 21 Q. Would you agree that the reference to table salt 21 Q. There is a reference in the second paragraph to 22 as an analogy to PCBs was in the paper we 22 the end to a,different conclusion from Dr. 23 reviewed? 23 Humprey. Who is Dr. Humprey? What were his 24 A. He's essentially taking the same published data 24 different conclusions? 25 about LD 50 or PCBs and comparing it to table 25 A.Dr. Humprey was, I think he's an epidemiologist, Page 45 - Page STLCOPCB4025576 Joan Maertin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock ______ November 13, 1997 Page 49 Page 51 1 in the state of Michigan. I don't know whether 1 from Mr. Gaffey's epidemiological study on PCBs? 2 he worked for, whether he was with the 2 MR. DiMURO: Do you want him to read 3 university or worked for the Department of 3 it? 4 Natural Resources, but he was from the state of 4 MR. TURET: No, he said he read it. 5 Michigan and he had done a lot of fish studies 5 MR. DiMURO: Do you need to read it? 6 or studies on people who had consumed fish. 6 A. If you want detailed discussions of conclusions, 7 Q.Do you remember what the conclusions were? 7 I would have to read it again. It's been 15, 16 8 A.He's written several papers and, no, I would 8 years, but - 9 have to look at the paper now, it's been so 9 Q. Let me put it this way: Is it your 10 long, that's 15 years. 10 understanding that the bottom line of Dr. 11 Q. Down at the very bottom, the enclosures, there 11 Gaffey's work was that none of the health 12 is a reference to the Gaffey paper. Is that the 12 studies dealing with human exposure to PCBs 13 document that's been marked as Craddock 6, The 13 showed a link between PCBs and cancer? 14 Epidemiology of PCBs? 14 MR. DiMURO: Object to the form, and 15 A. That is correct. 15 you can answer. 16 Q. Is that a document that you've seen? You 16 MR. O'CONNOR: Join the objection. 17 referred to having read the epidemiological 17 A. Dr. Gaffey's study was done at my direction. I 18 studies in the past, is Craddock 6 a document 18 had looked at most of these studies that had 19 that you've read before? 19 been published trying to sort these out in my 20 A. Yes, it is. 20 own mind. And the thing that became patently 21 Q. And Dr. Gaffey was the epidemiologist that you 21 clear is that all of these studies had been 22 referred to that was at one time in the medical 22 published independently with all sorts of 23 department of Monsanto? 23 conclusions, and that no one had reviewed all of 24 A. He was the director of the Monsanto epidemiology 24 the separate studies, and there were probably a 25 department. 25 dozen or two dozen of these things published Page 50 Page 52 1 Q. There is also a reference to Gaffey's press 1 over a decade, to see what the overall 2 release in Craddock 4. Is that the news release 2 conclusion should be. This includes the U.S. 3 that's marked as Craddock 5? 3 EPA, all the government regulatory agencies 4 A.That's correct. 4 which were writing all these rules at the time. 5 Q. And what is the reference to CMA overview? 5 And I asked Dr. Gaffey to assemble all these 6 A. CMA had caused to be published several documents 6 papers and do an overall review of the 7 relating to the health effects of PCBs and 7 epidemiology of PCBs. It was really quite 8 summaries of the literature. And I'm sure that 8 startling when you did that because if you took 9 -- I don't have a copy of the documents in 9 all the papers and put them together, there was 10 front of me, but I'm sure we sent them a copy of 10 no clear causal relationship between PCBs and 11 the CMA document, whatever it was. She was 11 human ills or PCBs and human illness. I haven't 12 asking for as much information as she could get, 13 so I'm sure that was provided to her. 12 gone back and looked at the conclusions, but I'm 13 sure that's what they say now. That was very 14 Q.Do you know if anyone from Monsanto participated 14 surprising at the time. That's why he was 15 in putting together the CMA overview of PCBs? 15 invited to present this paper all over the 16 A. I'm sure Monsanto provided data but the CMA 16 country because people were quite surprised that 17 overview was primarily done by independent 17 nobody had taken the time to sit down and put 18 contractors. In fact, the contractors are 18 all this together, first time it had been done, 19 listed there. Ecology and Environment. 19 1981. Does that answer your question? _ 20 Q. These were the same contractors that - 20 Q. Yes, it does. When you say that you asked Mr. 21 A. That were retained by the CMA panel to review 21 Gaffey to do this study, was Mr. Gaffey -- was 22 contact with PCBs. 22 he under you in the -- I mean, did you have the 23 Q. Just a reminder, let me get the question all the 23 ability to instruct him to do a study or were way out so the transcript will be readable. 24 your recommending that it was a study that What is your understanding of the conclusions 25 should be done? >& Page 49 - Page 52 STLCOPCB4025577 Joan Maertin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock November 13, 1997 Page 53 Page 55 1 MR. DiMURO: Object to the form. l A. Yes. 2 A. As I told you, my function was the corporate 2 Q.And is this a letter that you wrote in April 15, 3 focal point for PCBs in Monsanto operations and 3 '82 to Mr. Barry Sheerman, MP? 4 in order to get the job done I had at my 4 A. Yes. MP is Member of Parliament. 5 disposal all the resources within the 5 Q.The first sentence says that Dan Bishop, 6 corporation. And as director of this function, 6 director of public affairs of Monsanto Europe 7 I could ask the director of the medical 7 had asked that you respond to his letter of 8 department or the director of epidemiology 8 March 27, his being Mr. Sheerman. What had Mr. 9 questions, and ask them for an answer. And I 9 Sheerman written to Dan Bishop or Monsanto 10 had a discussion with Dr. Gaffey and he was 10 about? 11 surprised nobody had done this. And so it 11 A. I would have to see the letter to recall. To me 12 wasn't a question of directing him to do it. I 12 it looks like that he was asking for more 13 said has anybody ever looked at these studies, 13 detailed health effects information on PCBs. 14 what do you think the results would be. He did 14 Q. Why did Dan Bishop ask you to respond? 15 the study, he assembled the papers, reviewed 15 A. My function was to respond to PCB issues in 16 them. Dr. Gaffey was a well known established 16 general. Dan was the director of public 17 credible scientist in the field. He was a well 17 relations, but when it got into more detailed 18 known epidemiologist in the country. When you 18 scientific questions, he would ask me to answer 19 have one of the top people in the country at 19 those questions for him to respond in more 20 your disposal, sure as hell you're going to ask 20 detail. 21 him to look at it. And being as bright as I 21 Q.Flip back down to the very bottom of the letter 22 thought he was, he thought it was a good idea. 22 with the enclosure section? 23 And the paper was received in the scientific 23 A. Yes. 24 community very well. People were astounded it 24 Q. There is a reference to the Ecology and 25 hadn't been done before because it was such a 25 Environment Executive Summary. That's the one Page 54 Page 56 1 simple thing to do. 1 we just saw, and there's a reference to CMA 2 Q.Do you know whether updates were done on the 2 Comments to ANPR. What is that? 3 epidemiological study subsequently? 3 A.That's the advance notice of proposed rule 4 MR. DiMURO: I object to form; by 4 making. That was published on that page in the 5 Monsanto or anybody? 5 Federal Register. I would have to look at it to 6 MR. TURET: By Dr. Gaffey? 6 see which rule it was. Over two dozen EPA rules 7 A.I don't think Dr. Gaffey did any updates, mainly 7 came out in that time period so the final PCB 8 because up until that point of time there were 8 rule was not final. It's a new rule that was 9 very few other epidemiological studies that were 9 supposed to be out four years ago to end all PCB 10 done. There may have been a few done since 10 rules, and if that's it, I don't know. 11 then, but I haven't followed the literature that 11 Q.What was the 80-015 package? 12 close since '92, '93. There is one in the press 12 A. In my function as the major focal point of PCBs 13 in the past week about PCBs and breast cancer. 13 within Monsanto Company, we got so many requests 14 It ain't so. It's been alleged for years PCBs 14 for all kinds of information from people that 15 cause these horrid things. You get another 15 after I would get a request more than once or 16 study, it's not so. So I would say the studies 16 twice that looked like a recurring request, 1 17 support the paper. Dr. Gaffey is deceased, so 17 would put together packages of information. And 18 he can't update it anymore. 18 it was different levels of information. We had 19 (Letter dated 4/15/82 19 packages for high school kids writing science 20 marked as Exhibit No. 7 20 papers. We had packages for elementary kids .. 21 for identification.) 21 writing science papers. We had packages for 22 Q.For the record Craddock 7 is an April 15, 1982 22 various degrees of detail or.answering specific 23 letter from Mr. Craddock to Mr. Barry Sheerman, 23 questions. So to simplify things for me, once 24 MP. Dr. Craddock, have you seen this document 24 that package had been put together, I would 25 before today? 25 write a response letter and tell my secretary. Page 53 - Page Sfc- STLCOPCB4025578 Joan Maertin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock . _______ November 13, 1997 Page 57 Page 59 1 send them this package, so she would send all 1 and I had some input and some knowledge of it in 2 the attendant information in that particular 2 detail. 3 package of handouts. I was in the information 3 Q. And which department within Monsanto put 4 dissemination business, provide as much 4 together Backgrounders? 5 information as possible. 5 A.The Backgrounders were primarily put together by 6 (Letter dated 9/15/82 6 the public relations department. 7 marked as Exhibit No. 8 7 Q. And was that with input from the medical 8 for identification.) 8 department and whatever the applicable 9 Q.For the record, Craddock 8 is a September 15, 9 departments were? 10 1982, letter from Dan Bishop to the editor, 10 MR. DiMURO: Object to form. 11 Electrical Review. Mr. Craddock, have you seen 11 A. Yes, these people are primarily, or their 12 this letter before today? 12 function is to provide information in readable 13 A. I most probably have because I'm a "carbonee." 13 form for generally non-technical audiences, and 14 Q.From the heading at the very top, this is from 14 one way that we used this information was that 15 Dan Bishop while he was with Monsanto Europe? 15 we sent these to all of our plant managers, so 16 A. Yes. 16 if they had a question that they could answer 17 Q.The second paragraph of Mr. Bishop's letter 17 this question on the spot. They wouldn't say 18 again is addressing the issue of a highly toxic 18 you have to go ask John Craddock in St. Louis. 19 or carcinogenic label, and he talks about PCBs 19 There were certain basic facts that were known 20 on an acute basis are about as toxic to humans 20 that are in all of our written documents and all 21 as common table salt and are classified as only 21 of our written testimony, whatever we had. If 22 mildly toxic. And you agreed with that 22 we made this information available, in case you 23 statement before? 23 couldn't get hold of me, that was there, and 24 A. Yes. 24 this could be sent immediately. If you had a 25 Q.The very last paragraph Mr. Bishop states: As a 25 specific question, you could come back. It was Page 58 Page 60 1 former manufacturer of PCBs and an unrivaled 1 just to provide general background information 2 source of scientific expertise on them, we have 2 on the particular subject. This particular 3 a responsibility to combat the grossly 3 subject is PCBs. 4 exaggerated perceptions of risk associated with 4 Q.On the second page, the paragraph begins, it's 5 PCBs wherever encountered. Do you agree with 5 important to note the following. Third 6 that as well? 6 paragraph, the first item of information is 7 A. Yes. 7 Monsanto's decision to withdraw from the PCB 8 (Monsanto Backgrounder 8 business was based on concerns about 9 marked as Exhibit No. 9 9 environmental persistence rather than health 10 for identification.) 10 effects. Do you know what was the source of 11 Q. For the record, the document that's been marked 11 your information for that statement? 12 as Craddock 9 is a document that's entitled 12 A. Yes, there was a study that was done in 19 - 13 Monsanto Backgrounder, Polychlorinated 13 early 1970s that was published as the 14 Biphenyls. Mr. Craddock, have you seen this 14 inter-agency task force on PCBs summary, 1 think 15 document before today? 15 it was published in March of 1972. And this 16 A. Yes, I have. 16 study was a cooperative study between government 17 Q.What is a Monsanto Backgrounder? 17 agencies that existed at the time. I'm not sure 18 A. It's Monsanto's policy that for products or 18 EPA was even there at the time. Monsanto, as a 19 issues that we received a lot of inquiries 19 manufacturer of PCBs, the government agencies 20 about, that we would put together a paper called 20 that were involved, 1 know the USDA was - 21 a background information document. And this was 21 involved, FDA. whatever they had, council on 22 a standard piece of information which included 22 environmental quality or something like that. 23 the facts and representations as we knew it at 23 PCBs had become an issue. They put together a 24 the time. For this particular Backgrounder, 24 task force of regulatory agencies. Monsanto was 25 this was related to polychlorinated biphenyls, 25 a participant, provided all the information that Page 57 - Page 60 STLCOPCB4025579 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock Cause No.: L-95-CV02848(JBS)_________________________ November 13, 1997 Page 61 Page 63 1 we had. We had more information than anybody ] salt, but nobody could understand eating mineral 2 else, any other companies that had an interest 2 oil or motor oil. So if I made a comparison, my 3 in PCBs or anybody. And so this task force met, 3 approach was to use something people knew about 4 published this report. 4 that they used daily. 1 don't know where this 5 Q.Am I understanding you correctly that the report 5 came from. Possibly if you went through a list 6 of that group concluded that Monsanto's decision 6 of toxicities, they would all be in that 7 to withdraw from the PCB business was based on 7 listing. Mineral oil is what my grandfather 8 concerns about environmental persistence rather 8 took for constipation, you know, it might move 9 than health effects? 9 you, but it's not going to kill you. Motor oil, 10 MR. DiMURO: Objection to the form of 10 I don't know. 11 the question. 11 Q. Do you know one way or the other whether there 12 A.The group had nothing to do with Monsanto's 12 is any significance to the reference to mineral 13 decision. The group issued the report that PCBs 13 oil or motor oil rather than table salt? 14 were environmentally persistent, PCBs had not 14 A.No, I think it's in the eyes of the beholders. 15 been shown to be a human health hazard, and so 15 Q. Down at the very bottom there is a reference. 16 forth. But PCBs were a big issue because at 16 for additional information contact Dan Bishop or 17 this time this was about the time they had been 17 Larry J. O'Neill. Who is Larry J. O'Neill? 18 discovered in the environment in shells of bird 18 A. Larry J. O'Neill was a staff member in the 19 eggs and feathers of eagles and things like 19 public relations department of Monsanto at the 20 this. So at this point in time Monsanto decided 20 time. 21 that they would slowly move out of the PCB 21 Q.To your knowledge, did he have a particular 22 business, they would stop sales for open use 22 specialization on PCB issues? 23 which was -- that was based strictly on 23 a. Well, he used to work for EPA on PCBs and he 24 environmental persistence. Does that answer 24 left EPA and joined Monsanto. It wasn't a 25 your question? 25 specialization. That just happened to be one of Page 62 Page 64 1 Q.I think so. On page 5 Paragraph 2, there is a 1 the products that he dealt with at EPA and he 2 statement, based on acute, subchronic and 2 also did that at Monsanto. PCBs was not a 3 chronic studies of PCB effects in test animals. 3 full-time job for any person in Monsanto. PCBs 4 it can be stated that PCBs have a low order of 4 was just another one of the items that had to be 5 acute toxicity similar to that of mineral oil 5 responded to. I was the only person in Monsanto 6 and motor oil. 6 that had a full-time job that had to do with 7 MR. DiMURO: Or motor oil. 7 PCBs as far as I know. 8 Q. Pardon me, mineral oil or motor oil. Did this 8 (Report/J.Craddock 9 information come from you or did it come from 9 marked as Exhibit No. 10 10 someone else? 10 for identification.) 11 A.This probably came from -- it didn't come from 11 Q. For the record, Craddock 10 is a document 12 me that I recall. Most probably came from 12 entitled, PCBs Not Deadly Chemicals by Dr. John 13 published data on the acute toxicity studies and 13 H. Craddock. Dr. Craddock, is this a document 14 compared them with nonacute toxicity studies of 14 you've seen before today? 15 other chemicals. 15 A. Yes, it is. 16 Q.As the point person on PCB issues, do you 16 Q. What is the document that's been marked as 17 remember a time where the reference to table 17 Craddock 10? 18 salt changed to reference to mineral oil or 18 A. It's a short article discussing the toxicity or 19 motor oil? 19 health effects of PCBs. 20 MR. DiMURO: I object to the form. 20 Q.And it's an article you wrote? " 21 You can answer if you can. 21 A. Yes, it is. 22 A. I don't remember when it changed. I used the 22 Q. Do you remember to whom it was to be 23 reference to table salt because I thought it was 23 disseminated? 24 more easily understandable. If you're talking 24 A. I don't remember exactly, but I think this was a 25 about human effects, people understand table 25 letter to the editor of --1 don't know whether ^ Page 61 - Page 64 STLCOPCB4025580 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock . Cause No.: L-95-CV02848(JBS)___________ ____________________________ November 13,1997 Page 65 Page 67 1 it was a newspaper or magazine or a journal in i than anybody else, and Dupont knows more about 2 response to some article that had been published 2 its products than anybody else, absolutely. 3 previously about PCBs. 3 Q. Fair enough. 4 Q. Do you know when it was written? 4 (Brief recess.) 5 A.I don't see a date on it. I don't remember -- 5 MR. TURET: Back on the record. 6 well, it had to be after 1980 because I was 6 Q. Dr. Craddock, when did you first learn that PCBs 7 there, but it could have been written any time. 7 had been discovered at Burlington County 8 After 1980 for sure, and after 1981, that's the 8 College? 9 latest date. 9 A.It was probably --1 don't know whether I saw it 10 (Nova transcript 10 in a newspaper release or whether I had a call 11 marked as Exhibit No. 11 11 from Armstrong first, but it's been mid '80s, 12 for identification.) 12 '85, '86 time frame, something like that. 13 Q.Mr. Craddock, you're being shown a document 13 Q. Do you remember who it was that contacted you 14 that's a Broadcast Information Services, Inc. 14 either from within Monsanto or from Armstrong? 15 transcript of the program Nova of October 2 of 15 A. When I was contacted? 16 1979. I'm not going to ask you to read that 16 Q. Yes. 17 word for word, not to worry. Have you ever seen 17 A. I think that the first contact 1 had that 18 it before? 18 Armstrong had a problem might have been from 19 A. Probably. 19 Dick Mahoney or his office. 20 Q. On Page 9 of it Dan Bishop is quoted as saying 20 Q. Who was Dick Mahoney? 21 that the chemical industry knows more about - 21 A. Dick Mahoney was the CEO of Monsanto at the 22 MR. DiMURO: Hold on a second. 22 time. 23 . MR. TURET: I'm sorry. 23 Q. What was the substance of what he told you? 24 MR. DiMURO: Where you are reading? 24 A. That Armstrong, who was a major customer of 25 MR. TURET: From where it says, Dan 25 ours, had a PCB problem and that they needed Page 66 Page 68 1 Bishop. It quotes him as saying the chemical 1 some help and some information and to give them 2 industry knows more about their products than 2 all the help and information that we could. 3 anyone else does. They have the best equipment. 3 Q. In the ordinary course where a customer or 4 they have the best qualified people. 4 former customer of Monsanto had, as you've 5 Q.Do you agree based on your experience both as an 5 described it, a PCB problem, were you the one 6 employee of Monsanto and with others at the 6 who was particularly contacted to provide 7 Chemical Manufacturers Association? 7 information or assistance? 8 MR. DiMURO: I'm going to object to 8 A. Yes. 9 the form. 9 Q.Was that part of your job responsibility at the 10 MS. O'CONNOR: Object to the form of 10 time? 11 that question. 11 A. Yeah, my job responsibility from 1980 on was to 12 Q.Do you agree with that statement? 12 deal with PCB issues for the company. 13 MR. DiMURO: As to what time period? 13 Q. What did you do after hearing from Dick Mahoney 14 I'm objecting to the form of the question. 14 about Armstrong? 15 A.I guess I'm not sure what you want me to agree 15 A. 1 did what anybody else does who hears from the 16 to. 16 CEO, got my butt in high gear and called 17 Q.Do you agree that the chemical industry knows 17 Armstrong or went to Lancaster shortly 18 more about their products than anyone else does? 18 thereafter. 19 A. I would say that the major players in the 19 Q. Who did you call first? 20 chemical industry. My statement would be that 20 A. 1 was given some names. I can't remember. 1 _ 21 the majors in the chemical industry know more 21 talked to a young woman who was an industrial 22 about their products than anyone else. 22 hygienist at some point in tqne. 23 Q.Does Monsanto know more about its products than 23 MR. O'CONNOR: Are we talking with 24 anybody else? 24 about at Armstrong? 25 A.That's right. Dow knows more about its products 25 MR. TURET: Yes. Page 65 - Page STLCOPCB4025581 Joan Maertin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock November 13,1997 Page 69 Page 71 1 A. There were three or four people there that I l Q. All right. So a couple days after the initial 2 talked to at different times, and I think they 2 contact you had a meeting out in Lancaster? 3 were at the first meeting. They all weren't at 3 A. Yes. 4 the second meeting because that was a pretty 4 Q.That was just you and Bob Kaley from Monsanto? 5 high level meeting. But there was a woman who 5 A. Right. 6 was an industrial hygienist, there was a VP who 6 Q. Who was there from Armstrong other than Carolyn 7 was at both meetings and there was another guy. 7 Kent, the vice president -- 8 I don't know whether he was an analytical 8 A. There was a room full of people. We got there 9 chemist or what his function was. His name was 9 and there was a meeting going and they were -- 10 Kilgour. I talked to him a couple of times. 10 somewhere there has got to be a trip report or 11 But those are the people that I remember. 11 something that's got all that stuff. 12 Q. Would you know the name of the woman if you 12 Q. Actually I'm going to mark it right now. 13 heard it? 13 (Memo dated 4/4/86 14 A. Yeah, probably. 14 marked as Exhibit No. 12 15 Q. Was it Carolyn Kent? 15 for identification.) 16 A. Yeah, Carolyn Kent. 16 Q.Dr. Craddock, have you seen the document that's 17 Q.You think Carolyn Kent was the first person you 17 been marked as Craddock 12 before? 18 spoke to when you called? 18 A. Yes. 19 A. I don't know, either she or this Kilgour. 19 Q. Is that a memo that Dr. Kaley wrote summarizing 20 Q. Who was it that -- 20 his and your visit to Armstrong? 21 A. I think this Carolyn person, I think she also 21 A.That's correct. 22 talked -- she was on the committee with our OSHA 22 Q. On the first page there is a listing of four or 23 guy and I think she might have - I think this 23 five people. TM Bistline, is that Tom Bistline 24 may have come in from two ways. I think she may 24 from the legal department? 25 have talked to him, and he may have said, you 25 A. Yes. Page 70 1 know, call this person. It all happened about 2 the same time. 3 Q. Who's the OSHA guy to whom you're referring? 4 A. Tom Evans. Page 72 1 Q. And BJ Gilhousen, who is that? 2 A. He was our environmental counsel. Tom is --1 3 don't know how you divide it -- well, litigation 4 and environmental, I guess. 5 Q.Now, who was it that told you what the problem 6 was with the PCBs? 7 A. The details of what the problem was? 8 Q.Yeah? 9 A. Whoever I talked to the first time, either 10 Carolyn or Kilgour, and I can't remember who I 11 talked to first. We really found out in depth 12 what the problem was at a meeting a couple days 13 later. I went to Lancaster. The guy worked 14 with me at the time. 15 Q. Who was the guy who worked with you at a time? 16 A. Bob Kaley, he was an analytical chemist by 17 training and he joined the staff. 18 Q. Just to digress for a moment, was Bob Kaley a 19 Ph.D.? 20 A. Yes. 21 Q.How long did Dr. Kaley work with you? 22 A. Oh, God, I don't know. When I left he was my 23 successor, so he was there eight or ten years, 24 something like that. It was '85, '86 and he was 25 there before that. 5 Q. Who is WJ McCarville? 6 A. He was my immediate supervisor. 7 Q. What was his position at the time? 8 A. I forget what his exact title would be, sort of 9 director of regulatory affairs or something like 10 that. He had two or three groups. Mine was one 11 of them. 12 Q.How about JH Senger, S-E-N-G-E-R? 13 A. He was the vice president of environmental 14 affairs. McCarville reported directly to him. 15 Q. On the second page, roughly the middle of the 16 page, the paragraph begins, John and I were 17 introduced into a meeting -- there is a 18 reference three lines down to we gave them the 19 ACSH green book. What is that? 20 A. American Council on Science and Health, which is 21 an independent group that addresses all types of 22 science medical issues. They have done 23 everything from breast feeding babies to 24 toxicity of various chemicals such as aspirin. 25 PCBs is one of them. They had published a Page 69 - Page 72 STLCOPCB4025582 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock . Cause No.: L-95-CV02848(JBS)November 13, 1997 Page 73 Page 75 1 booklet on PCBs summarizing the health effects. 1 testing programs? 2 We gave them a copy of that. That was probably 2 A. No, I guess the one thing is, that we always 3 the most recent document that reviewed the 3 did, is any time people were doing any kind of 4 health effects of PCBs at the time. 4 samples analysis we wanted to make sure that we 5 Q. There is a reference to we, referring to -- this 5 were involved in the sampling and analysis, knew 6 is Dr. Kaley referring to he and you, also 6 how it was being done, what methodology was 7 participated in discussions of options available 7 being used, what laboratory was being used, make 8 at Armstrong. What is your recollection of the 8 sure proper controls, blanks, standards and all 9 options that existed at the time at Armstrong? 9 this stuff was used. It's very difficult to 10 MR. DiMURO: Object to the form. 10 analyze for PCBs especially in small quantities 11 A. Well, my recollection is they were really 11 and to identify them. And so, you know, the one 12 wondering what to do and how to handle a problem 12 thing you want to do is any time you have a 13 like this. This had become a very high profile 13 testing program is make sure the samples are 14 problem, sort of a media event, and they were 14 taken properly, it's a statistical sampling 15 saying what would you do. And Monsanto's option 15 program and that the methodology is good 16 is to get out in front, answer any questions 16 methodology and that proper standards are used. 17 that you have, make all the information 17 Otherwise you just don't know what you've got. 18 available that you have, try to put it in proper 18 Q. Did you or Dr. Kaley make any specific 19 perspective. You can always be on the defensive 19 recommendations with regard to testing that 20 to have it come back piecemeal information, and 20 should be done? 21 one option is to just get out front, tell 21 A.Not that I recall. 1 don't see anything in 22 everybody what you know about the problem, what 22 this, need just to make sure that that's done. 23 information you have about anything, information 23 Q. There is a reference in the last paragraph to, 24 about the chemicals involved, information about 24 we were also asked to participate in a 25 whatever the situation is. So that's probably 25 walk-through of the college building, but we Page 74 Page 76 1 the major option. That's what I remember 1 responded that we would not be able to commit to 2 talking to them about primarily is what would 2 that without consulting with our environmental 3 you do and how would you do it. 3 attorney. Why was it necessary to consult an 4 Q. What did you or Dr. Kaley offer as comments with 4 environmental attorney? 5 regard to those options? 5 MR. DiMURO: I would just caution the 6 MR. DiMURO: Object to the form. 6 witness not to disclose any conversations he 7 A. Well, it says, you know, we would make as much 7 might have had with the Monsanto environmental 8 information available. We would talk about how 8 attorney, whether inside counsel or outside 9 you put together a question and answer sheet or 9 counsel, but subject to that you can answer the 10 something like a Backgrounder. I did suggest to 10 question. 11 them they ought to get an independent consultant 11 A. I think that we probably didn't go because we 12 to look at this and suggested Ray Harbison who's 12 didn't have the opportunity to discuss with any 13 vety good at risk assessment. He's a 13 of Monsanto's legal representatives and who 14 toxicologist well-known in the field, well 14 knows what the implications would be for this. 15 respected. He's done a lot of work for EPA as 15 It's one thing, you can give general advice or 16 well as private industry. He's a good man. 16 something like that, but to be asked specifics, 17 People like Harbison are good if you have a 17 just, I don't know what our involvement would 18 community response. Harbison is very good at 18 have been or would not have been just as a 19 going in and talking to people, answering 19 matter of policy we didn't get -- we provided 20 questions, allaying fears, getting the facts 20 general infonnation, published information, - 21 straightforward. I don't remember specifics of 21 things that were known. But as far as getting 22 what we talked about. I'm looking at these 22 into the specifics or somebody's particular 23 notes. That's about it. 23 problem, we didn't do that as a matter of policy 24 Q. Do you have any recollection about discussions 24 without first discussing with our in-house 25 that related to the implications of various 25 counsel, and there was no opportunity to do that Page 73 - Page tS STLCOPCB4025583 Joan Maertin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock November 13, 1997 Page 77 Page 79 1 since we were at that meeting there. 1 deleted. 2 Q. When you say it's a matter of policy, is that a 2 MR. TURET: I'm sorry? 3 written policy? 3 MR. DiMURO: Mr. Senger has been 4 A. No. 4 deleted. 5 Q.Is that a policy that's discussed as part of the 5 Q. What are the enclosures to this letter? 6 training for people who are in that area? 6 A. The first three pages are an example of what a Q 7 A. Well, it's part of the training that I had when 7 and A is. We discussed with them that they 8 I was in that area because I was a chemist in a 8 should be prepared to provide as much 9 world full of all kinds of people. And you 9 information as possible and showed them how we 10 know, I did not know what legal ramifications, 10 did it. We put together questions about, you 11 you know, came of certain actions. I mean, the 11 know, somebody would ask a question, what if 12 things I did I had discussed previously with 12 they ask you this and you sit down and think 13 counterparts in the legal department at 13 about an appropriate answer and then we would 14 Monsanto, whatever else, is to make sure I 14 write these down. So we would have thought 15 didn't make commitments that couldn't be 15 about them in advance. The second part is a 16 honored. 16 copy of the Monsanto Backgrounder that we talked 17 Q. And were you responsible for training Dr. Kaley 17 about before which is the document we put 18 when he became your assistant? 18 together, general background information about 19 A. Yes. 19 PCBs, which is generally available to be 20 Q. What did you tell Dr. Kaley specifically in this 20 transmitted to anybody who has a question about 21 regard? 21 PCBs who's contacted Monsanto. 22 A. I don't recall. I probably said, you know - 22 Q. For the record, I note this is all stapled 23 MR. DiMURO: I don't want you to 23 together and I believe it was as produced to 24 guess, Dr. Craddock. If you have a specific 24 us. There is no reference in the letter to 25 recollection of what you said to Dr. Kaley, you 25 anything other than the sample questions and Page 78 Page 80 1 can give it to Mr. Turet. 1 answers. Do you have any knowledge one way or 2 A. I don't recall. It's been a long time ago. I 2 the other, Dr. Craddock, whether the 3 don't recall the specifics. 3 Backgrounder was included? 4 Q.A11 right. 4 A. 1 don't have any specific knowledge that it 5 (Letter dated 4/8/86 5 was. But what does the letter say, let me read 6 marked as Exhibit No. 13 6 the letter. I agree from looking at the carbon 7 for identification.) 7 copies, 1 assume there was, because Larry 8 Q.For the record, Craddock 13 is an April 8, 1986, 8 O'Neill put together the Backgrounder and he is 9 letter from Dr. Kaley to Mr. Robert Kilgour, 9 carboned on the list in case he gets some 10 K-I-L-G-O-U-R, at Armstrong, Bates numbered MAE 10 questions from these people. 11 059152 through 162 and has enclosures. Dr. 11 Q. When you were contacted by a customer or you 12 Craddock, have you seen the document that's been 12 learned that a customer had a PCB problem, did 13 marked as Craddock 13 before today? 13 you customarily have the PR department put 14 A. Yes. 14 together a list of sample questions and answers? 15 Q. And do you understand that's a letter from Dr. 15 MR. DiMURO: I'll object to the 16 Kaley to Bob Kilgour of Armstrong on or about 16 form. 17 April 8 of '86? 17 A. No. Generally the problems that, or questions 18 A.That's correct. 18 that came in didn't require that. The Armstrong 19 Q. And you're listed as a CC down at the bottom? 19 thing was a special case. It was a high 20 A. Right. 20 visibility news media event, and those are the _ 21 Q. Again, with the same lineup as in the last 21 kind of things that you would anticipate you're 22 letter except Larry O'Neill from the public 22 going to get lots of questions from. So knowing 23 relations department has been added? 23 that, you ought to think about them in advance. 24 A. Correct. 24 That's the reason for that. 25 MR. DiMURO: Mr. Senger has been 25 Q.I didn't ask you before. Can you tell me what Page 77 - Page 8^ STLCOPCB4025584 Joan Maertin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock . _______ November 13, 1997 Page 81 Page 83 1 your understanding of what the problem was at l A. It's the same substance that I put into letters. 2 Burlington Community College that prompted this 2 many response letters, yes. 3 communication? 3 Q. Response letters to customers? 4 A. Which communication? 4 A. EPA, to some of the letters you showed me today 5 Q. Prompted the contact with Armstrong? 5 to the member of Parliament, whatnot, Dolly 6 A. Well, the problem was that they had this fire at 6 Katz. 7 the college, as I understand it they had this 7 Q.That was the Detroit Press? 8 fire at the college which they were cleaning up 8 A. Right. 9 and they thought everything had been cleaned up 9 Q.Did Armstrong periodically call - let me 10 and it was fine, and PCBs were discovered. And 10 withdraw the question. Did you receive a call 11 the more they looked, they couldn't find a 11 from anyone at Armstrong after this April 8, 12 source of the PCBs. They looked for electrical, 12 1986, meeting? 13 they looked for chemicals in the storeroom. 13 A. April 8 wasn't a meeting. The meeting was some 14 whatever it was, and so this raised the specter 14 other time. 15 of PCBs. Then the news media in New Jersey, and 15 MR. O'CONNOR: The meeting was April 16 by the way New Jersey at this time was 16 fourth. 17 developing their own sets of PCB regulations 17 MR. DiMURO: Are you asking if he got 18 which were not necessarily going to parallel the 18 a call after the April 2nd meeting at Armstrong? 19 federal regulations, so it was a political issue 19 A. There may have been a couple of calls but I 20 in the state of New Jersey as to how to tailor 20 specifically don't recall. There was a 21 that state's PCB regulations. So it became a 21 follow-up call that I remember later from Unger, 22 media event. And if I recall, there were things 22 just to bring us up-to-date or something on 23 in the paper where different people in the state 23 whatever it was. And I'm not sure I talked to 24 of New Jersey had been asked what they thought 24 him, I think maybe Bob talked to him or 25 about it or that made various statements about 25 something like that, but they called Page 82 Page 84 1 PCBs being found and some of them were 1 periodically for a couple of months or so and 2 inflammatory, and it just sort of raised the 2 that was it. 3 media awareness. 3 Q. Coming out of the April 2nd meeting did you have 4 Q.On the first page of the proposed questions and 4 any specific understanding as to what Monsanto's 5 answers, I guess it says Page 39 at the top, the 5 involvement would be, if anything, at BCC? 6 very first page after that. There is the 6 A. Yeah, my understanding was we would be happy to 7 question down at the bottom of the page, why all 7 provide any information we had on PCBs and 8 the concerns about PCBs? Do they cause cancer? 8 answer any questions they had, provide them with 9 And the answer states, the hazards of PCBs to 9 any information we could. 10 humans are greatly exaggerated, they are not 10 Q. Was that the full extent of your expected 11 cancer causing agents, they are not deadly 11 involvement of Monsanto in the activities at 12 toxins, and there is an analogy to common table 12 BCC? 13 salt. Is this the same information that had 13 MR. DiMURO: Object to the form, his 14 been in your letters to other customers? 14 understanding after the meeting? 15 MR. DiMURO: I'll object to the 15 Q. Yes. 16 form. What letters to what customers? 16 A. My understanding after the meeting is that we 17 Q. Specifically the section of that answer that 17 had committed we would provide them certain 18 begins with the hazards and ends with the 18 information and we would try to do that and if 19 sentence, there has never been a single 19 they had other questions we'd try to respond to 20 documented case where PCBs caused serious 20 their questions. That was after this meeting at .. 21 chronic human health problems, including cancer. 21 April 2nd. 22 cardiovascular or neurological problems. Isn't 22 Q. Was that the full extent of what you expected 23 that the same substance that you put in your 23 Monsanto's'involvement would be at BCC? 24 letters to the epa, for example? 24 MR. DiMURO: i'll object to the form 25 MR. DiMURO: Object to the form. 25 of the question. Page 81 - Page 83' STLCOPCB4025585 Joan Maertin v Armstrong World Ind. Multi-PageTM Cause No.: L-95-CV02848(JBS)__________________________________ Witness: John H. Craddock November 13,1997 Page 85 . Page 87 1 A. When you say -- what is my understanding of l said that he expected that there would be phone 2 Monsanto's full extent? 2 calls, he would answer the questions and 3 Q.Yes. 3 Monsanto would continue to provide certain 4 A. Yes, that's -- yeah, that's what I was asked to 4 information. 5 do and that's what we committed to do and that's 5 MR. TURET: I'm asking a different 6 what we would do. 6 question. 7 Q.Did you understand that Armstrong would be 7 MR. DiMURO: It doesn't sound like 8 following up with Monsanto after that April 2nd 8 it's a different question. 9 '86 meeting? 9 MR. TURET: l don't care if you don't 10 A. Yes. 10 think it's a different question. 11 Q. What was your understanding of why there was to 11 MR. DiMURO: I do care because he's 12 be follow-up and what form of following up it 12 not going to answer the same question over and 13 would be? 13 over and over just because you change one word 14 A. My understanding is they would give us a call, 14 from correspondence to consult. I have an 15 let us know what was happening and if they had 15 objection to that. I'll let him answer the 16 any other questions they wanted to ask, whether 16 question. I object to the form. You asked me 17 it was how to do something or what to do, they J7 what my objection was and now I'm telling you. 18 would ask these questions and we would try to 18 Q. Do you remember my question? 19 answer them, give them the best advice we could. 19 A. Which question? 20 Q. Did you have any understanding as to whether 20 Q.The most recent one? 21 Armstrong was going to keep Monsanto apprised of 21 MR. DiMURO: If the court reporter 22 developments that were going on at BCC? 22 would read it back. 23 A. When you say understanding, I think that's one 23 Q.I'll ask it again. Coming out of the April 2, 24 of the things is they would let us know how 24 1986, meeting with Armstrong, did you have an 25 things were going, but it was no requirement 25 understanding as to whether or not Armstrong was Page 86 Page 88 1 either way. If they wanted more information, we 1 going to consult Monsanto before making any 2 would certainly give them more information, and 2 decisions as to how to proceed at BCC? 3 let us know what developments were. 3 MR. DiMURO: Objection to the form. 4 Q.Did you have any understanding as to whether 4 A. What do you mean by consult? 5 Armstrong was to consult Monsanto before 5 Q. Did you have any understanding as to whether 6 deciding to do anything in particular at BCC? 6 Armstrong was going to seek approval of Monsanto 7 MR. DiMURO: Object to the form. 7 before any decisions were to be made as to 8 ^ MR. TURET: What's your objection? 8 actions to be taken at BCC? 9 MR. DiMURO: The objection is are you 9 MR. DiMURO: I'm going to object to 10 talking about his understanding after this 10 the form of that question also. 11 particular meeting or the next day? They met 11 a.No, Armstrong didn't have any ties to Monsanto's 12 again, you know they met again. You know they 12 actions with what they did. They made their own 13 were here on phone calls. 13 decisions. We had nothing to do with any 14 MR. TURET: I'm asking at different 14 decisions that they made. We could provide what 15 points in time. Is that objectionable? 15 information we could, they could factor that 16 MR. DiMURO: I think it's 16 into their decision making, but they made the 17 objectionable knowing that he's testified there 17 decisions. We had no decision making capability 18 were certain calls made back and forth. If 18 or we weren't responsible for their decisions in 19 you're going to ask him what he came away with. 19 any way. 20 I just want to be clear. I'm not telling him 20 Q. What was the next communication that you can " 21 not to answer the question. If you want his 21 remember with Armstrong? 22 understanding as of April 3rd or April 2nd on 22 A. 1 don't know. There was soTne phone calls and at 23 his way back to Monsanto whether there was going 23 some point in time there was another meeting 24 to be consultations between Armstrong and 24 several months later. I don't know the exact 25 Monsanto, he's testified three times, I think he 25 date, probably the fall, something like that. ,- Page 85 - Page 88 STLCOPCB4025586 Joan Maertin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock . _______ November J 3, 1997 Page 89 Page 91 1 Q. And just want to make sure I understand you. 1 '86 and the subsequent meeting that you 2 Before the phone calls that came in between the 2 referred to? 3 April 2nd, 1986, meeting and the second meeting 3 A.The details, I don't recall the details anymore 4 you've described, were they calls that went into 4 than what's here except I did know we had a 5 Dr. Kaley as opposed to you? 5 phone call from this high level guy that was 6 A.I don't know who they went into because the 6 several months later. 7 phone calls came into one number. They came 7 Q. Dr. Craddock, do you remember anything about 8 into one phone number and whoever was there 8 1CF, Inc., who they were? 9 answered the phone. 9 A. I think they were an EPA contractor, did all 10 Q.Do you have any recollection of speaking with 10 kinds of data stuff for EPA from time to time. 11 anybody at Armstrong about the events at BCC 11 Q. Do you remember specifically in connection with 12 between the April 2nd, 1986, meeting and any 12 this issue of BCC and Armstrong whether you were 13 subsequent meeting? 13 contacted by ICF for information? 14 A.I may have spoken to somebody, but I'm not 14 A. We were contacted by somebody for information. 15 sure. I may have spoken to Kilgour once or 15 but I don't know whether it's ICF or who. 16 something, but I'm not sure. 16 Q.What information were you contacted for? 17 Q. Do you have any recollection of what was 17 A. I think they wanted to know about usage of PCBs 18 discussed with Mr. Kilgour if he did speak to 18 in tiles or something like that. 19 you? 19 Q. Did they want to know anything else specifically 20 A. No. 20 as it relates to Armstrong? 21 Q.Do you remember any information you received 21 A. They may have asked specifically about 22 from Dr. Kaley about his conversations with 22 Armstrong. If they did, we would as a matter of 23 Armstrong, if any, after this April 2nd, 1986, 23 rule have contacted Armstrong. We don't give 24 meeting? 24 out customer infonnation without the customer's 25 A. Yeah, I think Unger who is their highest level 25 approval. It's just a matter of policy that Page 90 Page 92 1 person called, he actually called for me one day 1 we've had, considered confidential business 2 and I wasn't there and Kaley took the call, and 2 infonnation. We have had that policy ever since 3 Kaley told me Unger called and it was an update 3 TSCA has been in. We don't provide infonnation 4 on what was going on, something to that effect. 4 on customers or through agencies or anybody 5 There may be a correspondence file after that. 5 else. They have to go directly to the customer 6 I don't know. 6 to get it. 7 Q.Have you seen a telephone conversation report 7 Q. Do you know if Annstrong ever gave Monsanto 8 that is dated between April 2nd of '86 and any 8 approval to provide infonnation about sales to 9 subsequent meetings that relate to a 9 Annstrong to ICF? Did you understand my 10 conversation with Dr. Kaley? 10 question? 11 A. Is that what you have in your hand? 11 A. Yeah, I do. 1 don't recall Armstrong 12 Q.Yeah. 12 specifically giving approval, but I don't 13 A. Is my name on the distribution list? 13 remember them not giving approval either. I 14 MR. TURET: Let's mark that as 14 don't remember whether we provided the data. 15 Craddock 14. 15 Q. You don't remember whether you provided the 16 (Memo dated 6/10/ 86 16 data? 17 marked as Exhibit No. 14 17 a. (Witness nods.) 18 for identification.) 18 Q.Tell me about the other meeting that you've 19 Q. Mr. Craddock, have you seen the telephone 19 referred to a couple times with Annstrong. 20 conversation report that's been marked as 20 a. The one other meeting with Annstrong was a high _ 21 Craddock 14 before today? 21 level meeting that 1 attended with Bob Potter 22 A. Most probably, yes. 22 who was the -- I don't know what his title was 23 Q. Does it, other than having read it just now. 23 at the time, was he president of the chemical 24 does it refresh your recollection as to any 24 company or whatever. He was essentially the 25 conversation that occurred between April 2nd of 25 top, he and Tom Gossage and Tom Bistline and Page 89 - Page 9^ STLCOPCB4025587 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock Cause No.: L-95-CV02848(JBS)November 13,1997 Page 93 .Page 95 1 that was high level people including Caldwell, 1 l Q. Did you ever hear from Mr. Potter or Mr. 2 remember Rocky Caldwell at Armstrong. 2 Bistline or Mr. Gossage that there was a 3 Q. What is your understanding of what took place at 3 response? 4 that meeting? 4 A.No, not that 1 recall. 5 A. I think essentially Armstrong was asking Potter 5 Q. Do you know if there were any communications 6 to help them pay the cost of whatever their 6 between Armstrong and Monsanto that followed 7 clean up was or something like that. 7 this letter on the issue of the request that 8 Q.Do you have an understanding as to why Armstrong 8 Monsanto contribute to the cost? 9 was asking Monsanto to pay? 9 A. Not that I recall unless there is something in 10 A. They were just trying to get another source of 10 the file. 11 funding as far as I know. 11 Q.Is there any -- withdraw that question. Are you 12 Q.Do you understand Armstrong's position at the 12 aware of any further discussions between 13 time? Did you understand Armstrong's position 13 Armstrong and Monsanto after September 16 of '87 14 at the time as to why it felt Monsanto should 14 relating to the events that were taking place at 15 contribute to the cost of the clean up at BCC? 15 BCC? 16 MR. DiMURO: I'm going to object to 16 MR. DiMURO: Object to the form. You 17 the form. 17 can answer. 18 A. I'm not sure they stated a position as to why 18 A.I don't remember anything else. And again, you 19 that I heard, other than it was very expensive. 19 would have to look through the file. 20 MR. TURET: Let's mark that as 15. 20 Q. Is it fair to say, so 1 don't keep asking 21 (Letter dated 9/16/87 21 questions and getting the same answer, that 22 marked as Exhibit No. 15 22 you're not aware of any further letters or 23 for identification.) 23 communications of any sort with Armstrong after 24 Q.Dr. Craddock, have you seen the document that's 24 September 16 of '87 on the issue of remediation 25 been marked as Craddock 15 before? 25 at BCC or costs? Page 94 Page 96 1 A. Yeah, I'm on the distribution list so I'm sure 1 A.No, I don't recall any. 2 I've seen it. 2 MR. TURET: I have no further 3 Q. Do you remember receiving a copy in or about 3 questions. 4 September of '87? 4 MR. O'CONNOR: Let me take a quick 5 A.I don't specifically remember it, no. 5 break. I don't have a real lot. 6 Q. There is a reference in the last or second to 6 (Brief recess.) 7 last sentence that we look forward to talking 7 8 about this again when you come back in October. 8 EXAMINATION 9 To the best of your knowledge, was there another 9 QUESTIONS BY MR. O'CONNOR: 10 meeting in October? 10 Q.Dr. Craddock, my name is Brian O'Connor. I'm an 11 A. Not that I know of. 11 attorney in New Jersey and I represent the 12 Q. Would you agree with me that in 'his letter Mr. 12 plaintiffs in this case that have brought an 13 Unger suggests to Mr. Potter that Monsanto 13 action against Armstrong World Industries for 14 contribute to the cost of the remechation at 14 exposure to PCBs at their workplace. The 15 BCC? 15 allegation is that there were ceiling tiles in 16 MR. DiMURO: I'll object to the 16 place at the Burlington County College that 17 form. 17 existed for approximately 14 or 15 years that 18 A. Yeah, he's certainly asking Potter for 18 were coated with PCBs. Is that your 19 assistance with the cost. 19 understanding of the basis of this lawsuit? 20 Q.Do you have any understanding as to whether 20 A. As far as 1 know. " 21 Monsanto responded to that request? 21 Q.You understand that Armstrong World Industries 22 A.I haven't seen any response, but I would imagine 22 has brought jn Monsanto Cffemical Company as a 23 that Potter responded. 23 third-party defendant in this case? 24 Q. Did you ever see a document that responded? 24 A. Right. 25 A. No, not that I recall. 25 Q.You had mentioned earlier that you have been A- Page 93 - Page 96 STLCOPCB4025588 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock . Cause No.: L-95-CV02848(JBS)November 13,1997 Page 97 Page 99 1 deposed before. How many times have you been i A. That's correct, yeah. 2 deposed? 2 Q.And have you ever done any work at Monsanto by 3 A.I don't know, maybe half a dozen. 3 way of research or just come across it in your 4 Q.Have you ever been deposed as a so-called fact 4 normal activities with regard to plasticizers 5 witness on behalf of Monsanto Chemical Company, 5 that contain PCBs? 6 in other words, as a representative of Monsanto 6 A. Have I done any work with them? 7 Chemical Company? 7 Q. Right. 8 A.That 30 B something, was that a fact witness. 8 A.No. 9 Gerard -- yes. 9 Q.Are you familiar at all with plasticizers? 10 Q. So on one other occasion you appeared as a 10 A. Yes. 11 representative for Monsanto Chemical Company? 11 Q. What is your familiarity if you can give me a 12 A. Yes. 12 brief -- 13 Q.Have you yourself reviewed any documents prior 13 A. Basically I know the textbook definition of 14 to today other than what Mr. Turet has shown you 14 plasticizers, what they are, what they're used 15 today? 15 for. I know Monsanto is a major manufacturer of 16 A. No. 16 plasticizers and I've looked at technical 17 Q. Were you shown any other documents by counsel? 17 bulletins that describe what some of the 18 A.No. 18 products are and what some of the formulations 19 Q. When were you first contacted about this 19 are. 20 particular case, this deposition? 20 Q. You've also testified that you had some dealings 21 A. I guess I was first contacted about this maybe 21 with Armstrong after Armstrong contacted 22 the end of the summer, just saying that I would 22 Monsanto about a fire that occurred at 23 probably be asked to be deposed or subpoenaed to 23 Burlington Community College in the mid '80s; is 24 be deposed or something like that, and I had a 24 that correct? 25 letter a week or ten days ago saying when the 25 A.That's correct. Page 98 Page 100 1 deposition would be or trying to set up times. 1 Q. Do you recall any specific conversations that 2 Q.Now, you've authored some documents or had some 2 you had with any of the Armstrong people about 3 input in documents, Monsanto documents, that 3 their use of Aroclor 1255 -- 1254 on ceiling 4 have been marked this morning. And you've also 4 tiles? 5 given us your opinion, your beliefs with regard 5 A. What's the question again? 6 to PCBs and their causal relationship with 6 Q. Do you recall any specific conversations you had 7 cancer; is that correct? 7 with any Armstrong employees about Armstrong's 8 A. Correct. 8 use of Aroclor 1254 on ceiling tiles? 9 Q. You yourself are not an expert in the causal 9 A. Just the discussions as they came up in the 10 relationship between PCBs and cancer; correct? 10 meeting we had on the Armstrong site, whatever 11 A.That's correct. 11 it was, about early April of that year we talked 12 Q. Your opinion and your beliefs are derived from 12 about PCB sources being traced to the tiles and 13 other documents, other studies performed by 13 general discussion about why PCBs would be used 14 toxicologists or pathologists; correct? 14 in the tiles, what they were used for. 15 A.That's correct. 15 Q.That's what I'm looking to get at, the general 16 Q. So you don't hold yourself out as an expert on 16 discussions as to why PCBs would be used on 17 the health effects of PCBs; correct? 17 ceiling tiles. Did you have any specific 18 A.No. 18 discussions that you recall? 19 Q. If I was understanding your testimony this 19 A.No. 20 morning correctly, you became involved with 20 Q. For instance-- " 21 quote, unquote, PCBs in or around 1980 at 21 A. Just, you know, there are other plasticizers 22 Monsanto? 22 that are better plasticizers for the type 23 A. That's correct. 23 plastic -- genera] discussion -- 1 guess I don't 24 Q.And much cf your work was geared toward the TSCA 24 remember any specific questions as to why you 25 regulations? 25 would use them. They may have asked, they may t - Page 97 - Page 100 STLCOPCB4025589 Joan Maertin v Armstrong World Ind. Cayse No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock _______ November 13, 1997 Page 101 Page 103 1 not. I don't know. 1 on the ceiling tiles? 2 Q.Let me ask you, you said there were other 2 MR. TURET: Objection. 3 plasticizers that were available that were 3 MR. O'CONNOR: What objection? 4 better plasticizers as far as you know? 4 MR. TURET: What literature? 5 A. Well, a plasticizer is designed for a specific 5 MR. O'CONNOR: rm asking if he was 6 plastic, so when you say a better plasticizer, 6 supplied with any literature; it's a simple 7 you mean better than what and for what use. 7 question. 8 Q. Were there better plasticizers than the PCBs for 8 MR. TURET: I made an objection for 9 the ceiling tiles as far as you knew? 9 the record. Go ahead and ask your question. 10 A. I guess in general I thought there probably were 10 A. I don't recall getting any literature from 11 because PCBs hadn't been used in any type of 11 Armstrong about this. 12 ceiling tile that I knew of before. And 12 Q. Verbally you were provided with no reason as to 13 Armstrong didn't know of any uses in ceiling 13 why they used Aroclor 1254; correct? 14 tiles while they were grappling around trying to 14 A. Somewhere in the recess of my mind there was a 15 find out what tiles they were in. 15 discussion as to -- and 1 don't remember even 16 Q.Did you ask any of the Armstrong people why they 16 who this was with -- as to why you would 17 used Aroclor 1254 on ceiling tiles as a 17 probably use it and the answer that reoccurs is 18 plasticizer? 18 probably for flame retardancy as a building 19 A. I don't recall asking that, no. 19 material. 20 Q. Did you have any discussions with them about the 20 Q. Did you see anything or have any discussion with 21 plastisol coating formulations they put on the 21 anyone at Armstrong that Aroclor 1254 was 22 ceiling tiles? 22 utilized for aesthetic purposes? 23 A. No. 23 A. No. 24 Q.Did you ask them if there were any other 24 Q.Have you seen any literature generated by 25 suspected carcinogenic agents within that 25 Monsanto suggesting that Aroclor 1254 be used as Page 102 Page 104 1 plastisol coating formulation? 1 a plasticizer for ceiling title? 2 A. No. 2 A. For ceiling tiles per se? 3 Q.Had you heard of dibenzyl furans when you went 3 Q. Right. 4 out to Armstrong and met with them and discussed 4 A. I don't recall that. But I haven't gone through 5 the problem as you've described it? 5 all the technical bulletins. 6 MR. DiMURO: Objection to the form, 6 Q. When you became involved with the PCBs at 7 general knowledge concerning dibenzyl furans? 7 Monsanto in 1980, did you have an opportunity to 8 A. When you say dibenzyl furans you mean strictly 8 go back and look at the history of Monsanto's 9 dibenzyl furans as a chemist would define it? 9 decision to stop making and distributing Aroclor 10 Q.Yes. 10 1254 and Aroclor 1260 and PCBs generally for 11 A. I've heard of dibenzyl furans, yes. 11 open uses? 12 Q.Have you heard of dibenzyl furans found in 12 A. Yes. 13 Aroclor 1254? 13 Q. What was your understanding as to why Monsanto 14 A. To my knowledge, there have been no dibenzyl 14 decided to do that? 15 furans found in Aroclor 1254. 15 A. Monsanto's original decision was that they would 16 Q. You've never seen any documentation indicating 16 stop manufacturing PCBs totally and there was a 17 that? 17 hew and cry among the government's regulatory 18 A. No. 18 people and among the electrical people that you 19 Q. Were you familiar at all with phosphate 19 can't do this because you'll shut down electric 20 plasticizers while you were at Monsanto? 20 power distribution in the country. So then they .. 21 A. I just know that Monsanto made phosphate 21 said, well, what can you do. Monsanto's 22 plasticizers and we sold formulations containing 22 attitude was if PCBs were aojmvironmental 23 organic phosphates. 23 problem we won't manufacture PCBs. So I think 24 Q. Were you provided any literature by Armstrong as 24 the final resolution of the problem, I don't 25 to why they used Aroclor 1254 as a plasticizer 25 know how and why it was, that Monsanto would STLCOPCB4025590 Joan Maertin v Armstrong World Ind. Cause No.: L-9S-CV02848(JBS) Multi-PageTM Witness: John H. Craddock . _______ November 43, 1997 Page 105 Page 107 1 stop selling PCBs for what were defined then as l Q. Let me see if 1 can rephrase it. Do you know 2 open uses and they would only manufacture them 2 whether or not Monsanto had serious concerns 3 for closed and controlled uses which primarily 3 about the uses of Aroclor 1254 and Aroclor 1260 4 were electrical power transmission equipment. 4 in open uses versus closed uses? 5 So that was the decision. 5 MR. DAVIDSON: What time period? 6 Q. Was it your understanding that Monsanto had 6 MR. O'CONNOR: In the early '70s. 7 decided to cease the manufacture and 7 MR.TURET: Objection. 8 distribution of PCBs for open uses in 1970? 8 A. Monsanto had concern about use of PCBs for open 9 A. About that time period, yes. 9 uses because of the environmental persistence. 10 Q.And the decision to stop the manufacturing and 10 Q. When you say environmental persistence, what do 11 distribution of PCBs for any use including 11 you mean by that? 12 closed uses was in or around 1977? 12 A. PCBs remain in the environment for a long time. 13 A.'76, '77 right. 13 They biodegrade, but very slowly. 14 Q. Were you aware that Monsanto contacted its 14 Q.Don't they get caught up in the food chain? 15 customers who had purchased Aroclor 1254 and 15 A. They may get caught up in the food chain, they 16 Aroclor 1260 and other PCBs for open uses back 16 may not. 17 in the early '70s? 17 Q.Can't they be eventually passed on to humans? 18 A. Yes. 18 A. They may be. 19 Q.Did you have an opportunity to review literature 19 Q.And with regards to open uses, didn't Monsanto 20 with reference to boilerplate letters that went 20 have a concern that the ultimate user couldn't 21 out to various customers? 21 control the material from entering the 22 A. Yes. 22 environment? 23 Q.Did Monsanto have any type of procedure in place 23 A. I don't know specifically what the concern was 24 to question their customers on what their 24 as to who controlled, I don't recall that. 25 intended use for, say, Aroclor 1254 or Aroclor 25 Q. Well, earlier you gave us your beliefs and your Page 106 Page 108 1 1260 was? 1 opinions on the relationship between PCBs and 2 A. Not that I know of. 2 cancer based on epidemiological studies that you 3 Q.So in other words, when the product was sold to 3 had reviewed and other studies. And some of the 4 a customer, there was really no monitoring of 4 materials references Dr. Kimbrough's studies at 5 what that customer was going to do with that 5 the National Cancer Institute? 6 particular product? 6 A. Right. 7 A.Prior to 1970 is that correct, '71, that time 7 Q. Did you review studies from IBT? 8 frame. 8 A. No. 9 Q. When you say prior to 1970, '71, there was a 9 Q. Do you know who IBT is? 10 change in policy with regards to PCBs after '70, 10 A. Yes. 11 '71? 11 Q. You never in your employment at Monsanto went 12 A. At that time period Monsanto stopped 12 back and took a look at those tests? 13 manufacturing PCBs for open uses and agreed to 13 A. Well, when you say review them, 1 have seen the 14 manufacture PCBs only for closed contained uses 14 documents, the IBT reports. I've read the 15 for electrical equipment, primarily transformers 15 conclusions. I've read the studies, but as far 16 and capacitors. 16 as review, in my context, a scientific reviewer 17 Q. Do you know if Monsanto had significant concerns 17 is somebody who is looking at the details of the 18 with the use of the Aroclor 1254, Aroclor 1260 18 study, the format and all that kind of stuff. 19 in an open use versus closed use? 19 In that context I did not review the studies. 1 20 MR.TURET: Objection. 20 read those studies and looked at some of the - 21 MR. DAVIDSON: At what time? 21 conclusions. 22 MR. O'CONNOR: In or around the early 22 Q. Would you agree with me that PCBs -- Monsanto 23 1970s? 23 did not contemplate that PCBs would be ingested 24 A. Would you repeat that? There is something wrong 24 by humans? 25 with your phrasing, something bothers me. 25 MR. DiMURO: Objection to the form. Page 105 - Page ltfR" STLCOPCB4025591 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock Cause No.: L-9S-CV02848(JBS)_______________________________________________ November 13, 1997 Page 109 Page 111 1 You can answer. l I've seen numbers published as to what they 2 A. Monsanto did not intend for PCBs to be ingested 2 found in carpet or whatnot, but as far as 3 by humans. I don't know, when you said 3 relating it to exposure. I've seen nothing like 4 contemplate, that's why you do LD 50 studies 4 that. 5 because somebody may ingest something, but their 5 Q. You've seen nothing with regards to the alleged 6 intended use was not for ingestion. 6 duration of the exposure; correct? 7 Q. Their intended use was not for inhalation 7 A. Duration, no. 8 either; correct? 8 Q. Do you know whether or not any of the levels 9 A.That's correct. 9 found at the school exceeded NIOSH minimum 10 Q.And Monsanto did not intend that human beings 10 standards? 11 would have skin contact with PCBs either; 11 A.They may have exceeded NIOSH. I don't think 12 correct? 12 they exceeded OSHA. NIOSH standards were 13 MR. DiMURO: Object to the form. You 13 published in the early '70s. They were very 14 can answer, Dr. Craddock. 14 stringent standards based on theoretical 15 A.I don't know whether they intended for you to 15 calculations that not a lot of people agreed 16 have skin contact. I'm not sure whether they -- 16 with. As a matter of fact, a lot of regulations 17 you could have inadvertent skin contact. You 17 were written that didn't include NIOSH 18 can have inadvertent inhalation. These are 18 standards, included OSHA standards but not NIOSH 19 different from deliberate manufacture of a 19 standards. 20 product that is to be applied to the skin or to 20 Q. After TSCA was passed and put into place around 21 be ingested. 21 1979, did Monsanto endeavor to contact its 22 Q.Have you ever seen any literature generated by 22 customers that it had sold PCBs to about tsca 23 Monsanto for the handling of the Aroclors with 23 itself? 24 reference to the Aroclor being toxic? 24 A. Not that 1 recall. 25 A. Talking about the pure Aroclor as an industrial 25 Q. Why was it that Monsanto decided to cease the Page 110 Page 112 1 chemical? 1 manufacture and distribution of PCBs for closed 2 Q. Yes. 2 uses prior to the passage of TSCA? 3 A. Yes, I've seen the warning labels and the 3 A. I don't think I know an answer to that 4 information published, yes. 4 question. 5 Q.Have you seen anything where it describes 5 Q.The epidemiological studies that you made 6 Aroclor as being noxious? 6 reference to and specifically the study of Dr. 7 A.Noxious, I haven't seen that term used, noxious. 7 Gaffey, is that correct, Gaffey? 8 no. 8 A.That's correct, Gaffey. 9 Q.In this particular case with regards to the 9 Q. You had asked him to review the epidemiological 10 Burlington County College incident, when you 10 studies that had existed with regard to PCBs and 11 went out to Armstrong, you came back, you had a 11 cancer as of September 15, 1981; correct? 12 couple of phone calls and then there was another 12 A. It might have been earlier than that, but in 13 contact; correct? 13 that time frame. 14 A. Correct. 14 Q. You would agree with me that there are certain 15 Q. After that, after the late '80s did you have any 15 health hazards associated with exposure to PCBs; 16 more contact at all with Armstrong about that 16 correct? 17 incident? 17 MR. DiMURO: I'll object to the 18 A. Not that I recall, no. 18 form. You can answer. 19 Q.So it's fair to say that you have no idea as to 19 A. There are certain health hazards that are 20 what the levels of PCBs -- what levels of 20 alleged from PCB exposure. I'm not sure 1 agree - 21 exposure are being alleged; correct? 21 that they're hazards. In my mind hazard is in 22 MR. DiMURO: Object to the form. 22 the eye of the beholder, 1 think. 23 MR. TURET: Object to the form. 23 Q. You've heard the term, chloracne? 24 MR. DiMURO: You can answer. 24 A. Yes. 25 A. I don't know what the alleged exposure was. 25 Q. You have heard of dermatitis being caused by Page 109 - Page 112 STLCOPCB4025592 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock - Cause No.: L-95-CV02848(JBS)November 13,1997 Page 113 Page 115 1 exposure to PCBs? 1 A. I don't know that Monsanto contacted the 2 A. Yes. 2 manufacturer of the silos. 1 don't know if 3 Q. You've heard about abnormalities of the liver; 3 Monsanto knew that paints were used in silos. I 4 correct? 4 don't know even know Monsanto knew the Aroclors 5 A.I've heard of those things, but I'm not sure 5 were used in paints. 6 which of those are directly attributable to 6 MR. O'CONNOR: I don't have anything 7 PCBS. 7 further. 8 Q. Have you ever seen any literature authored by 8 MS. O'CONNOR: My turn? 9 Monsanto itself that describes long time 9 MR. DiMURO: Yes. 10 exposure can cause yellow atrophy of the liver? 10 11 A. I don't remember that, no. 11 EXAMINATION 12 Q. Well, Dr. Gaffey notes that exposure to PCBs can 12 QUESTIONS BY MS. O'CONNOR: 13 cause alterations in the liver. Didn't he find 13 Q.Mr. Craddock, my name is Carolyn O'Connor. I 14 that as part of his studies? 14 have a few short questions for you. Do you have 15 a.I would have to reread the studies. It's been a 15 any familiarity with a company known as American 16 long time, but I know it causes changes in 16 Mineral Spirits Company? 17 certain liver functions. I don't know exactly 17 A. No. 18 what those are. 18 Q. During your employment with Monsanto did you 19 Q.The epidemiological studies that somebody 19 ever have any contact with the distributors of 20 performed in the '90s, have you kept abreast of 20 PCBs for Monsanto? 21 them with regard to PCBs and cancer? 21 A. Did I ever have contact with distributors of 22 A. No, not in detail. 22 PCBs for Monsanto. 23 Q. It's not anything you followed? 23 Q. Right? 24 A. Not anymore. 24 a.Not that I recall. 25 Q.Let me ask you, you made reference to a new 25 Q. Okay. Are you aware of any companies that Page 114 Page 116 1 report that came out with reference to breast 1 supplied Aroclor 1254 manufactured by Monsanto 2 cancer and PCBs. Did you actually read that 2 to others? 3 published report? 3 A. I know there were distributors prior to the '70, 4 A. No. 4 '71 cutoff, but 1 don't know who they were. 5 Q. Just saw something about it in the paper? 5 Q. Okay. Did you have any -- did you make any 6 A. I think it's on NBC news as well as the paper. 6 efforts in your various positions at Monsanto to 7 Q. Are you aware if Monsanto ever made any efforts 7 convey any of the public awareness information 8 to contact actual ultimate users of products 8 that you've testified to this morning to any of 9 that contained Aroclors after the passage of 9 those distributors? 10 TSCA? 10 A. Only if they requested it. 11 A.Not to my recollection, no. 11 MS. O'CONNOR: I have no other 12 Q.How about before TSCA? 12 questions. Thank you. 13 A. Before TSCA Monsanto made efforts to contact our 13 MR. DiMURO: I have a couple of 14 customers. Now, I don't know what you mean by 14 questions. 15 ultimate users. Customers made products, 15 MR.TURET: Go ahead. I'll go after 16 whatever, is that your ultimate user -- I don't 16 you. 17 know what you mean by ultimate user. 17 MR. DiMURO: I believe it goes around 18 Q. Were you familiar at all with the use by silo 18 to him again. 19 manufacturers of Aroclor 1254 in the paints they 19 MR. DAVIDSON: We don't have any 20 placed on silos, grain silos? 20 questions right now. 21 A. Yes, I'm familiar with that use. 21 MR. TURET: I have a couple questions 22 Q. Do you know if Monsanto went out and contacted 22 right now and I may have others after you go. 23 the manufacturer of those silos? 23 24 MR. DiMURO: I'll object to the 24 EXAMINATION 25 form. 25 QUESTIONS BY MR. TURET: ^ Page 113 - Page 116 STLCOPCB4025593 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock Cause No.: L-95-CV02848(JBS)November 13, 1997 Page 117 Page 119 1 Q.Dr. Craddock, you were a research chemist; l depends on the intended use and the conditions. 2 correct? 2 1254, from what I have read, was not a 3 A. You say I was? 3 particularly good plasticizer for just plastic 4 Q.Yes? 4 coatings so I don't know why that particular 5 A. Yes, I was. 5 plasticizer was used on ceiling tile. There 6 Q. And as a research chemist, you never worked on 6 were probably, I would think there would 7 plasticizers, did you? 7 probably be other plasticizers that were better. 8 A. No. 8 if it's for a plastic coating, plus other 9 Q.That is true as a senior research chemist and a 9 plasticizers were generally used for plastics in 10 group leader et cetera, you never worked on 10 that kind of stuff. 11 plasticizers; correct? 11 Q. Do you have any knowledge as you sit here today 12 A.That's correct. 12 based on work that you've done of another 13 Q.Did you ever do any work with applications for 13 plasticizer in the lineup of Monsanto products 14 plasticizers as a researcher at Monsanto? 14 between '68 and '70 that would be better than 15 A. No. 15 Aroclor 1254 for use on the ceiling tiles? 16 Q. Did you ever do any analytical work on 16 MR. DiMURO: I object to the form. 17 properties of plasticizers? 17 He doesn't know what the plasticizer formula 18 A. No. 18 was. You haven't established that. It hasn't 19 Q.You made a comment before that there are other 19 been established what the ceiling tiles were 20 plasticizers that are better for use on ceiling 20 made of. You might want to ask him if -- 21 tiles, and then you made some other comments 21 MR. TURET: I don't need 22 that I wasn't sure about. Is it your belief 22 suggestions. Put your objection on the record. 23 that there are other plasticizers that are 23 MR. DiMURO: It's not suggestions. 24 better than Aroclor 1254 for use in the 24 You're asking an unfair question of this witness 25 particular plastisol formulation on the 25 who, to my mind you haven't established whether Page 118 Page 120 1 particular ceiling tiles that Armstrong used? 1 he knows what the plastisol coating was. You 2 MR. O'CONNOR: Objection to form. 2 haven't established what the elements of the 3 Are you asking him about the particular 3 ceiling tile were. You haven't told him what 4 plastisol formulation that was put on the tiles 4 PCB resin based ceiling tile. 5 in this instance? 5 MR. TURET: This is a reaction to the 6 Q. Let me rephrase. Do you have a view as to 6 statement he made. 7 whether there are better plasticizers 7 MR. DiMURO: The way I recall that 8 manufactured by Monsanto as of '68 through '70, 8 testimony is that he wouldn't have recommended 9 better than Aroclor 1254 for use on the ceiling 9 use on this substance. He didn't say ceiling 10 tiles? 10 tile. I think you're asking him an unfair 11 MR. DiMURO: I'm going to object to 11 question asking him generic ceiling tiles 12 the form. 12 without asking the witness whether he knows what 13 MR. TURET: He made that comment. 13 they were made of or what the plastisol coating 14 I'm going to ask what is his basis. 14 was, which would be a specific. 15 MR. DiMURO: I know he made a 15 MR. TURET: There hasn't been any 16 comment. I object to the way you characterized 16 discussion of the substance that came up in 17 it. I think he said -- I'll let you ask another 17 connection with ceiling tiles. 18 question. 18 Q.A11 I'm saying. Dr. Craddock, if you don't know, 19 Q.Did I misunderstand you? Let me ask you 19 you don't know. But if you're going to say 20 directly. I may have misunderstood what you 20 there was another better plasticizer for use on - 21 said. Did you say before that there were other 21 an application, then I want to know what the 22 plasticizers that are better than Aroclor 1254 22 basis of your knowledge is. -Tell me again. 23 for use on ceiling tiles? 23 MR. DiMURO: Ask the question. 24 A.I really don't know what I said. We've had so 24 Q.Do you have an opinion as you're sitting here 25 many questions about this thing. Plasticizer 25 today that there was another plasticizer in the Page 117 - Page 120 STLCOPCB4025594 Joan Maertin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-PageTM Witness: John H. Craddock . November 13, 1997 Page 121 Page 123 1 lineup of Monsanto products from 1968 to 1970 l what they want to use it for. They just ask 2 that would have been better suited to use on 2 you, give me all the things you think will do 3 ceiling tiles than Aroclor 1254? 3 that and we will select one. Proprietary 4 MR. DiMURO: Objection to form. 4 products are very funny business. A lot of 5 A. I don't have any knowledge or any information 5 times customers are actually so devious, they 6 about what kind of plasticizers were used in any 6 will go to a distributor and buy a sample of 7 ceiling tiles. I didn't even know plasticizers 7 product so that you don't know what they're 8 were used on ceiling tiles until I went to 8 using. But when it goes through a small 9 Armstrong that day and they had a problem. So I 9 quantity for a distributor you never know what 10 don't know anything about it. 10 the hell it's being used for. I can go buy a 11 Q.That's fine. Dr. Craddock, the other thing I'm 11 five-gallon drum or 25-gallon pail or 55-gallon 12 not sure if I understood you correctly or not on 12 drum and it's completely out of the system. The 13 this one. Did I understand you to say that 13 distributor doesn't care what he's selling it 14 before 1970 or 1971 there was no way Monsanto 14 for. He's just moving it out the door and 15 could know what its customers' uses for 15 marking it up, so you don't know. 16 plasticizer products were? 16 MR. TURET: I have no further 17 A. There is no way Monsanto what could know what 17 questions. 18 all of its customers used its products for; 18 MR. O'CONNOR: I have a couple 19 right. 19 follow-ups. 20 Q.Do you know what a call report is? 20 21 A. Yea. 21 EXAMINATION 22 Q. What is a call report? 22 QUESTIONS BY MR. O'CONNOR: 23 A. A call report is generally, in Monsanto terms, 23 Q. 1 just have a brief couple of questions with 24 it's where a salesman goes out and makes a call 24 regard to what's been marked Craddock 1, PCB 25 on a purchasing agent or researcher and writes a 25 Perspective which is a document you drafted in Page 122 Page 124 1 report, sends it back to the general office. 1 January of '81; correct? 2 Q.Have you seen call reports in your time at 2 A. Yeah, I think so. 3 Monsanto? 3 Q. Let me show it to you. 4 A. I've seen call reports in my time at Monsanto. 4 A. Okay. 5 Q. Based on what you've seen, do call reports 5 Q.I would like you to tum to Page 4, Doctor. And 6 sometimes refer to the uses that the customer is 6 I want you to take a look now at risk benefit. 7 -- to the applications that the customer is 7 And this document states: The risk benefit 8 using the Monsanto products for? 8 issue with respect to PCBs is the key to the 9 A. They might. They might be speculation as to 9 whole PCB problem. Much soul searching is being 10 what the salesman thinks they're using it for, 10 done to define these parameters for PCBs. The 11 and they might not have anything about what it's 11 benefit side of the equation is perhaps the 12 being used for. 12 easier of the two to define. We know the 13 Q. Do you have any knowledge as to whether 13 benefits of using nonflammable PCBs in certain 14 salespersons are assigned to particular 14 key and essential industries where technically 15 customers? 15 suitable replacements are not readily 16 A. In some business units salesmen are assigned to 16 available. We can calculate the benefit of 17 a particular customer if the customer is big 17 preventing fires and saving lives. Then it 18 enough, yes, sir. 18 lists several situations where PCBs would be 19 Q. Where it's a big customer and you have a 19 utilized to prevent catastrophes; correct? 20 salesperson assigned, do you know whether it's 20 A. Correct. - 21 frequently the case for a salesman to know what 21 Q.And you go down a little further and it says. 22 the customer uses it for? 22 how do we quantitatively measure risk. Risk of 23 MR. DiMURO: Objection to the form. 23 human health hazard, risk of environmental 24 A. When you say frequently, sometimes customers 24 damage, et cetera, and compare them with the 25 won't tell you their proprietary formulations of 25 benefits; correct? Page 121 - Page 124 STLCOPCB4025595 Joan Maertin v Armstrong World Ind. Multi-PageTM Cause No.: L-95-CV02848(JBS) November 13,1997 Witness: John H. Craddock Page 125 Page 127 l A.That's correct. l A. I've lost the first part of the question. 2 Q.Did you have an expectation or did Monsanto have 2 MR. O'CONNOR: Would you read that 3 an expectation that their customers when 3 back, please? 4 utilizing PCBs would do a similar type of risk 4 (Question read.) 5 utility benefit analysis? 5 A. I don't know. 1 don't know anything about PCBs 6 MR. TURET: Objection. 6 in ceiling tiles. 7 A. In hindsight, I don't think we had any 7 MR. O'CONNOR: 1 have nothing 8 expectation that they would do that. I don't 8 further. 9 know what motivates a customer to put a product 9 MS. O'CONNOR: Nothing further. 10 on the market. Bigger companies do more things 10 Thank you. 11 than smaller companies do. 11 MR. DiMURO: I have a couple of 12 Q.Is this something that Monsanto took into 12 questions. 13 consideration when Monsanto made a decision on 13 I would like to have marked as 14 how they were going to use PCBs? 14 Exhibit 16 a July 25, 1986, letter from Mr. 15 A. Well, I don't know about PCBs. The use of PCBs 15 Craddock to Mr. Mark Wagner of 1CF. It's two 16 was before my tenure. In general with products 16 pages long. I'll represent this document was 17 Monsanto weighed the benefits and risks 17 produced during the course of discovery, that 18 absolutely. That's why you do testing to see 18 the copy I have does have MAE numbers, it's MA.E 19 what types of problems might exist. 19 059149 to 150. And the copy that Mr. Turet has 20 Q. And that analysis, of course, applied to open 20 handed me looks to my eye to be exactly the same 21 uses as well as closed uses; correct? 21 as the copy I have, so I will use the copy Mr. 22 A. Yes. 22 Turet has because it's marked. 23 Q. Where did you get this information to come up 23 (Letter dated 7/25/86 24 with this so-called risk benefit issue, this 24 marked as Exhibit No. 16 25 little section contained on Pages 4 and 5 of the 25 for identification.) Page 126 Page 128 l document authored by you? 1 EXAMINATION 2 A. What do you mean where did I get this 2 QUESTIONS BY MR. DiMURO: 3 information? 3 Q. Dr. Craddock, if you would read through that 4 Q. Where did you come up with the idea that the 4 document. Dr. Craddock, is that your signature 5 risk benefit issue with respect to PCBs is the 5 on what's been marked as Craddock 16? 6 key to the whole PCB problem? 6 A. Yes. 7 A.Because that's what's strictly been talked about 7 Q. There was a suggestion before by Mr. Turet that 8 in the media and papers is why would you make 8 Monsanto might not have had the approval to 9 such a product. And you make such a product 9 release sales summary information to ICF. Inc. 10 because there was a benefit as well as a risk. 10 After taking a look at Craddock 16, does it 11 Why would you make an automobile? My God, 11 refresh your recollection as to whether 12 people are killed like flies every day in 12 Armstrong authorized Monsanto to release 13 automobiles. There is a great benefit in being 13 information, sales information on the Aroclors 14 able to drive across town at 30 miles an hour 14 to ICF? 15 rather than walk at three. You take that risk. 15 MR. TURET: Objection to form. There 16 Q.Did anyone at Monsanto as far as you know look 16 was no such suggestion. 17 at the risks associated with putting Aroclor 17 Q. If there was a suggestion, does this document 18 1254 to open uses such as on ceiling tiles 18 refresh your recollection as to whether 19 versus the risk of human health hazard? 19 Armstrong authorized Monsanto to release sales 20 MR. DAVIDSON: At a given time? 20 information on the Aroclor 1254 to ICF, Inc.? " 21 MR. O'CONNOR: At a given time. 21 A. Yes, this document states that I discussed the 22 MR. DAVIDSON: What time? 22 release of information with Armstrong who were 23 MR. O'CONNOR: Any time. 23 agreeable to providing the data for the EPA 24 MR. TURET: Objection. 24 contact. 25 MR. DiMURO: Object to the form? 25 Q. Do you know who you might have discussed that Page 125 - Page 128 STLCOPCB4025596 Joan Maertin v Armstrong World Ind. Multi-PageTM Witness: John H. Craddock - Cause No.: L-95-CV02848(JBS)November 13,1997 Page 129 1 with at Armstrong? l 2 A. I would imagine Phil Unger because he got a 2 3 carbon copy of this. 3 4 Q. Other than the release of this information to 4 5 ICF* do you remember having any other contact 5 6 with Mr. Wagner concerning the alleged problem 6 7 at Burlington County College? 7 8 A. No. 8 9 q.Do you know if Mr. Kaley had any contact with 9 10 Mr. Wagner? 10 11 A. I don't know. 11 12 Q. At that first meeting with -- at the April 2nd 12 13 meeting with Armstrong, that meeting was only 13 14 attended by you and Mr. Kaley on behalf of 14 15 Monsanto? 15 16 A.That's correct. 16 17 Q. And I'm going to show you what's been previously 17 18 marked as Craddock 12. It is the memo summary 18 19 written by Dr. Kaley on the April 2nd meeting. 19 20 I would like to direct your attention to the 20 21 last page which indicates who attended that 21 22 meeting on behalf of Armstrong and ask you to 22 23 take a look at those names, just tell me when 23 24 you're done. 24 25 A. Okay. 25 Page 131 STATE OF ) COUNTY OF ) I, JOHN H. CRADDOCK, do hereby certify: That I have read the foregoing deposition; That I have made such changes in form and/or substance to the within deposition as might be necessary to render the same true and correct; That having made such changes thereon, I hereby subscribe my name to the deposition. I declare under penalty of peijury that the foregoing is true and correct. Executed this day of ,, 1997, at , . NOTARY PUBLIC My Commission expires: JOHN H. CRADDOCK Page 130 1 Q. Do you remember any of these people calling you 1 2 after the April 2nd meeting to discuss with you 2 3 any part of the situation at Armstrong? 3 4 A. No. I mentioned that 1 thought maybe I had 4 5 talked to Kilgour. He would be the only one and 5 6 Unger had talked to Kaley. 6 7 Q. Do you remember meeting Mr. Collins Bushnell at 7 8 the meeting on April 2nd? 8 9 A. No. 9 10 Q. Do you recall meeting anybody from the research 10 11 and development department at Armstrong? 11 12 A. No. 12 13 Q. Do you remember a gentleman named Mitchell 13 14 Bernstein? He's indicated here on Craddock 12 14 15 as outside environmental counsel. Do you 15 16 remember that? 16 17 A. No, I don't remember him. 17 18 Q. Do you have any reason to believe this list of 18 19 people here who attended the meeting is 19 20 inaccurate in any way? 20 21 A. No, I thought maybe Carolyn Kent was there but 21 22 -- if she were there, Kaley would have 22 23 documented it, I'm sure DiMURO: I luivt uLrlluikg else. 24 MR. TURET: I'm done. 23 24 25 (Witness excused) 25 Page 132 CERTIFICATE OF REPORTER STATE OF MISSOURI ) ) SS COUNTY OF ST. LOUIS ) I, nancy a. KUNCAITIS, a Registered Professional Reporter and Notary Public in and for the State of Missouri, the officer before whom the foregoing deposition was taken, do hereby certify that the witness whose testimony appears in the foregoing deposition was duly swom by me; that the testimony of said witness was taken by me to the best of my ability and thereafter reduced to typewriting under my direction; that I am neither counsel for, related to, nor employed by any of the parties to the action in which this deposition was taken, and further that I am not a relative or employee of any attorney or counsel employed by the parties thereto, nor financially or otherwise interested in the outcome of the - action. State of Missouri My commission expires 11*22-01 ^- Page 129 - Page 132 STLCOPCB4025597 Joan Macrtin v Armstrong World Ind. TM Multi-Page Cause No.: L-95-CV02848(JBS) '68 [2] 118:8 119:14 70 [Sj 10:18 106:10 116:3 118:8 119:14 '70s [3] 105:17 107:6 111:13 '71 [] 10:18,22 106:7,9 106:11 116:4 '73 [l] 12:6 75 1] 12:16 '76 41 12:16 13:7 17:18 105:13 77 [sj 12:9 13:7,8,13 105:13 78 [31 13:8,13 18:22 80 [21 27:14,14 123[i] 1:5 1254(24] 100:3,8 101:17 102:13,15,25 103:13,21 103:25 104:10 105:15,25 106:18 107:3 114:19 116:1 117:24 118:9,22 119:2,15 121:3 126:18 128:20 1255(1] 100:3 1260(5] 104:10 105:16 106:1,18 107:3 127(11 1:16 128[i] 1:5 13(7] 1:15 21:10,24 42:5 78:6,8,13 13lh [ij 2:12 14 (ij 1:15 90:15,17,21 96:17 2(6] 1:9 41:22,24 62:1 65:15 87:23 20(1] 28:3 215(1] 3:18 21927m 3:12 22[ii 33:20 25(3] 47:20 48:8 127:14 25-gallon [i] 123:11 257(1] 33:10 27 [i] 55:8 27420[ii 3:13 2nd[M] 83:18 84:3,21 85:8 86:22 89:3,12,23 90:8,25 129:12,19 130:2 130:8 -3- 80s [4] 34:14 67:11 99:23 110:15 '81 [7j 27:14,15 33:20 41:13,14 42:5 124:1 82(2] 48:9 55:3 85 [21 67:12 70:24 86(61 67:12 70:24 78:17 85:9 90:8 91:1 '87 [3] 94:4 95:13,24 90s [il 113:20 '92 m 54:12 93 [4j 20:7,11 38:12 54:12 0- - 005905 m 45:13 005907(11 47:23 010245 m 33:10 011777 m 48:1 02849(11 2:4 054387[ii 47:21 059149 m 127:19 05 9 1 52(11 78:11 07101-3174(1] 3:9 07102-5311(1] 3:22 08054[i] 3:5 1- - I [9] 1:9 32:21,23 33:7,12 36:2,20 39:13 123:24 1.4pi 37:2,23 10(7] 1:13 27:21 38:2,20 64:9,11,17 100m 9:6 101 [ij 3:4 II [2] 1:14 65:11 11-22-01(1] 132:24 11/13/81(31 1:9 41:21 41:25 115[i] 1:4 116 [i] 1:4 12(7] 1:14 27:21 40:19 71:14,17 129:18 130:14 1400(1] 3:12 l[5j 1:10 36:20 45:8,10 15li2] 1:16 28:3 49:10 45:14 51:7 54:22 55:2 57:9 93:20,22,25 96:17 112:11 150(1] 127:19 16(8] 1:16 51:7 95:13,24 127:14,24 128:5,10 162(1] 78:11 17[i] 45:12 19(1] 60:12 19I03-73961U 3:18 1930 m 37:2 1958 m 5:23 . 1961 (3j 6:1,22 8:19 1962(11 9:21 1965(2] 8:3,20 1966[ii 10:14 3/17/82(1] 45:7 3/17/92m 1:10 3/25/92[ii 1:10 30(2] 97:8 126:14 300(11 3:12 3000(1] 3:4 31 [i] 18:25 32(11 1:9 33(1] 14:8 35(2] 14:7,8 378-5267(1] 3:13 388(1] 47:22 39[i] 82:5 3rd [i] 86:22 1968[i] 121:1 1970(7] 10:15,22 105:8 106:7,9 121:1,14 1970s [2] 60:13 106:23 1971 |i| 121:14 1972m 60:15 1973(2] 11:5 25:4 1976[i] 13:5 1977(6] 12:10 13:4,5 18:22 37:2 105:12 1978[i] 13:23 1979(3] 18:25 65:16 -4- 4(10] 1:3,10 38:4 46:14 47:16,20 48:5 50:2 124:5 125:25 4/15/82(1] 54:19 4/15/92m 1:12 4/4/86(2] 1:14 71:13 4/8/86(2] 1:15 78:5 41 m 1:9 45 [l] 1:10 47(3] 1:10,11,11 111:21 1980[io] 19:24 21:6,7 -5- 26:1 34:7 65:6,8 68:11 98:21 104:7 5(6] 1:11 47:16,22 50:3 62:1 125:25 1981 [6| 33:19 37:16 38:4 52:19 65:8 112:11 SO |3| 29:5 46:25 109:4 1982(5] 45:12 46:9 47:20 54 (ij 1:12 54:22 57:10 55-gallon [1] 123:11 1986(7] 78:8 83:12 87:24 57(i] 1:12 89:3,12,23 127:14 58 m 1:13 1993(2] 20:6 21:8 1997(2] 2:13 131:14 6- - 1 St [i] 20:6 6 m 1:11 47:16,23 49:13 49:18 2- - 6/10/86(2] 1:15 90:16 639-7298m 3:10 64[i] 1:13 65 [l] 1:14 -7- 7 m_ . 1:12 54:20,22 7/2!5/86 [2] 1:16 127:23 709 U 3:5 71 [11 1:14 727 1991 (U 3:5 7494 [( i] 2:16 78 [ij 1:15 actual [i] 114:8 acute [6] 38:21 46:15 57:20 62:2,5c,1"3 adim. . 8:23 added m 78:23 adding [i] 15:6 addition [2] 22:2 43:6 additional [2] 15:17 63:16 additives [2] 14:14 15:11 address [3] 22:22 26:11 48:3 addrcsscd[2] 22:9 41:25 8- - addresses [i] 72:21 817] 1:12 57:7,9 78:8,17 83:11,13 80-015[i] 56:11 807(1] 48:2 -9- (4| 1:13 58:9,12 65:20 9/15/82m 57:6 9/15/92(1] 1:12 9/16/87(2] 1:16 93:21 90 11 ] 1:15 908 |1| 47:23 910[i] 3:13 93 [l] 1:16 96(1] 1:3 973(1] 3:10 979-1000(1] 3:18 -A- abilitym 52:23 132:12 able [4j 13:24 15:13 76:1 126:14 addressing [i] 57:18 Administration m 14:15 admitted [ij 5:17 advance [3] 56:3 79:15 80:23 advice [2] 76:15 85:19 advocate [i] 30:13 acsthcticm 103.-22 affairs [3] 55:6 72:9,14 afternoon [i] 2:15 again (isj 10:19 12:6,25 24:7 51:7 57:18 78:21 86:12,12 87:23 94:8 95:18 100:5 116:18 120:22 against [3] 28:22 31:16 96:13 agem 4:10 agencies [i6] 14:13,21 15:18,20,23 16:2,11 21:19 28:21 41:8 43:3 52:3 60:17,19,24 92:4 agency [2] 14:22,23 agent [ij 121:25 abnormalities |i| 113:! abreast (ij 113:20 abroad (ij 47:7 absence [3] 5:17 40:20 41:5 absolutely (2i 67:2 125:18 absorbiem 15:7 abstract [i] 23:21 acceptable m 5:6 accommodate [i] 5:9 acidm 15:7 agents (31 41:10 82:11 101:25 ago (4j 46:18 56:9 78:2 97:25 agree (12) 46:11,21 58:5 66:5,12,15,17 80:6 94:12 108:22 112:14,20 agreeable [l] 128:23 agreed m 4:1 41:3,20 44:16 46:8 57:22 106:13 111:15 Agriculture [3] 14:16 15:3 16:11 ACSHm 72:19 ahead [21 103:9 116:15 Actl2| 13:22 14:4 ain't[i] 54:14 ' action [3] 96:13 132!::16 132:21 actions [4] 24:15 77 :11 88:8,12 active [3] 6:19 26:2i 28!'5 actively [ij 31:2 activities [io] 14:2 26:14,r6 28:2,18,20132:7 84:11 99:4 airm 36:25 al (2) 2:4,22 allaying [ij 74:20 allegation [i] 96:15 _ allegations [2] 20:23 29:2 alleged[10] 23:12,13,17 23:20 54:14 110:21,25 111:5 112:20 129:6 Index Page j STLCOPCB4025598 Joan Macrtin v Armstrong World Ind. TM Multi-Page allow - ceiling Cause No.: L-95-CV02848(JBS) Witnes s: John H. Cyaddock allOW[2] 38:5 44:22 89:23 91:12,20,22,23 92:7 authorized [$] 18:14 benefits [3] 124:13,25 Bushncll[i] 130:7 allowance [l] 29:6 92:9,11,19,20 93:2,5,8 19:2,6 128:12,19 125:17 )usincss[8] 12:15 57:4 allowed [3] 15:9 19:4,5 95:6,13,23 96:13,21 99:21 99:21 100:2,7,10 101:13 along [2] 29:10,11 101:16 102:4,24 103:11 alterations [i] 113:13 103:21 110:11,16 118:1 always [2] 73:19 75:2 American [si 2:8,24 7:14 72:20 115:15 among [2] 104:17,18 amount [i] 37:16 121:9 128:12,19,22 129:1 129:13,22 130:3,11 Armstrong's [3] 93:12 93:13 100:7 Aroclor[3i] 100:3,8 101:17 102:13,15,25 amounts [i] 42:21 103:13,21,25 104:9,10 analogy [2] 46:22 82:12 105:15,16,25.25 106:18 analysis [4] 75:4,5 125:5 106:18 107:3,3 109:24,25 125:20 110:6 114:19 116:1 analytical [4] 22:5 69:8 117:24 118:9,22 119:15 121:3 126:17 128:20 70:16 117:16 Aroclors[4] 109:23 analyze [l] 75:10 114:9 115:4 128:13 animals [2] 43:11 62:3 arsenic [l] 6:19 ANPR[i] 56:2 article [3] 64:18.20 65:2 automobile [i] 126:11 automobiles [i] 126:13 available [ii] 5:16 16:4 18:19 22:7 59:22 73:7,18 74:8 79:19 101:3 124:16 average [2] 16:7 27:24 aware [3] 95:12,22 105:14 114:7 115:25 awareness [2] 82:3 116:7 away[i] 86:19 -B- B[i] 97:8 babies [i] 72:23 background (4j 5:21 58:21 60:1 79:18 Backgrounder [9| l:13 Bernstein [ij 130:14 best [5] 66:3,4 85:19 94:9 132:12 better 114] 100:22 101:4 101:6,7,8 117:20,24 118:7 118:9,22 119:7,14 120:20 121:2 between [i7j 2:13 4:2 31:5,6 51:13 52:10 60:16 86:24 89:2,12 90:8,25 95:6,12 98:10 108:1 119:14 big [5] 18:2 38:19 61:16 122:17,19 Bigger [i] 125:10 Bill [i| 36:9 billion [2] 37:2,23 biodegrade [ i i 107:13 biphenyls |5| 7:1 9:16 60:8 61:7,22 92:1 122:16 123:4 butt[i] 68:16 buy [2] 123:6,10 buying [ij 15:10 -C- C[i] 3:1 cable [i] 19:13 calculate ii] 124:16 calculations [i] 111:15 Caldwell [2] 93:1,2 calls [9] 83:19 86:13,18 87:2 88:22 89:2,4,7 110:12 cancer [IS] 40:23 41:9 46:5 51:13 54:13 82:8,11 82:21 98:7,10 108:2,5 answer [311 4:25 5:4 43:23 44:14 51:15 52:19 53:9 55:18 59:16 61:24 62:21 73:16 74:9 76:9 aspcctS(3] 7:8 17:6 24:5 58:8,13.17,24 74:10 79:16 33:8 58:14,25 aspirin [i] 72:24 80:3,8 birdm 61:18 assemble [i] 52:5 Backgrounders [2] 59:4 Bishop [13] 45:11,16,17 112:11 113:21 114:2 capability [i] 88:17 capacitors [4] 19:12 79:13 82:9,17 84:8 85:19 assembled [i] 53:15 59:5 45:20 46:3,14 55:5,9,14 27:6 37:18 106:16 86:21 87:2,12,15 95:17 95:21 103:17 109:1,14 110:24 112:3,18 answcrcd[2] 21:17 89:9 answering [2] 56:22 74:19 answers [3] 80:1,14 82:5 anticipate [2j 45:5 80:21 anticipated [i] 7:19 appear [i] 34:16 appeared [i] 97:10 applicable [ii 59:8 application [i] 120:21 assessment [ij 74:13 assigned [4] 8:8 122:14 122:16,20 assist[i] 21:25 assistance [2] 68:7 94:19 assistant [i] 77:18 associated [6] 23:2,21 40:21 58:4 112:15 126:17 Associates [l] 2:16 association [u] 25:10 26:3,5,10,13,24 27:2,3,10 30:4,7 31:1 35:4 66:7 bad [1| 42:25 57:10,15.25 63:16 65:20 ban [2] 18:23 19:2 66:1 banded[i] 26:11 Bishop 'S[i] 57:17 banned [3] 18:24 19:1 42:23 Bistlinc[4| 71:23,23 92:25 95:2 Barry [2] 54:23 55:3 bit [ii 20:8 based [u | 18:2160:8 BJ [i | 72:1 61:7.23 62:2 66:5 108:2 blanks [ij 75:8 111:14 119:12 120:4 122:5 basic [2] 8:23 59:19 blind [ii 47:2 Bob 16] 70:16,18 71:4 78:16 83:24 92:21 basis [7] 29:4 33:24 39:15 bodies [2] 41:8 43:12 57:20 96:19 118:14 120:22 boilerplate [l ] 105:20 capacity |2] 16:12 19:15 Carbide m 28:10 carbon 14] 6:14 47:2 80:6 129:3 carboncdii] 80:9 carboncc[i] 57:13 carcinogenic [2] 57:19 101:25 cardiovascular ii] 82:22 care [3] 87:9,11 123:13 carccr[3] 24:21 25:1,1 Carolina [i] 3:13 applications [6] 11:14 12:23,24 38:7 117:13 associations [4] 24:22 25:6,17 34:23 Bates [5] 33:9 47:21,23 48:1 78:10 book[i] 72:19 booklet [11 73:1 Carolyn [io] 3:21 33:4 69:15,16,17,21 70:10 71:6 122:7 applied [3] 7:6 109:20 125:20 assumcm 5:5 9:21 10:8 10:22 12:10 13:6 19:25 44:16 80:7 BCC[13| 84:5,12,23 85:22 86:6 88:2,8 89:11 91:12 93:15 94:15 95:15 bothers 11| 106:25 bottom [7] 33:20 49:11 51:10 55:21 63:15 78:19 115:13 130:21 carpet [i | 111:2 ease [14] 5:16 20:18 23:11 apportion [i] 20:14 assumed [2] 9:8 18:22 95:25 82:7 24:9 46:5 59:22 80:9,19 apprised [i] 85:21 assure |i] 18:12 became[i4] 10:23 11:l box |2| 3:12 42:22 82:20 96:12,23 97:20 approach [3] 42:24,25 astounded [i] 53:24 11:7 20:1,2 25:25 26:1,2 break 13] 5:8 33:1 96:5 110:9 122:21 63:3 appropriate [2] 44:1 atom[i] 6:14 Atrium [2] 3:4,4 26:9 51:20 77:18 81:21 98:20 104:6 breast [3] 54.13 72:23 114:1 eases [5] 23:14 24:4 29:21 38:5 41:7 79:13 approval [] 88:6 91:25 92:8,12,13 128:8 April [24] 54:22 55:2 78:8 78:17 83:11,13,15,18 84:3 84:21 85:8 86:22,22 87:23 89:3,12,23 90:8,25 100:11 129:12,19 130:2,8 area [11] 6:4 8:14 14:9,10 14:12 15:4 17:23 18:2 22:22 77:6,8 Armstrong [72] 2:6,23 3:15 67:11,14,18,24 68:14 68:17,24 71:6,20 73:8,9 78:10,16 80:18 81:5 83:9 83:11,18 85:7,21 86:5,24 87:24,25 88:6,11,21 89:11 atrophy [i] 113:10 attached [i] 1:17 attendant [i] 57:2 attended [7] 25:8,14,18 92:21 129:14,21 130:19 attention [i] 129:20 attitude [l] 104:22 attorney [3] 76:3,4,8 96:11 132:18 attributable [i] 113:6 attributed [i] 46:6 audiences [i] 59:13 authored [5] 33:14 47:25 98:2 113:8 126:1 authorizations [i] 18:7 become [2] 60:23 73:13 Brian i2] 3:3 96:10 begin [ij 8:1 brief [5] 33:2 67:4 96:6 begins [4] 43:6 60:4 99:12 123:23 72:16 82:18 bright[l] 53:21 behalf [8] 4:11 20:22 29:12,13 47:8 97:5 129:14 bring [I] 83:22 129:22 bringing[i| 29:18 bcholdcrii] 112:22 brings hi 13:4 beholders [i] 63:14 Broadcastm 65:14 beings [i] 109:10 brought 12| 96:12,22 belief [i] 117:22 Brussels [i] 47:10 beliefs [3] 98:5,12 107:25 building [3J 35:4 75:25 below [ij 37:1 103:18 ^ benefit [91 124:6,7,11,16 bulletins [2] 99:17 104:5 125:5,24 126:5,10,13 Burlington [6] 67:7 81:2 96:16 99:23 110:10 129:7 catalyses [3] 8:15 9:1 10:3 catalysts [i] 11:17 catastrophes [i] 124:19 caught [2| 107:14,15 causal [3| 52:1098:6,9 caused [31 50:6 82:20 112:25 causes [i] 113:16 causing [2] 41:9 82:11 _ caution [i] 76:5 CC[i] 78:19 cease [2] 105:7 111:25 ceiling [29] 96:15 100:3 100:8,17 101:9,12,13,17 . Index Page S-- STLCOPCB4025599 Joan Macrtin v Armstrong World Ind. Cai^sc No.: L-95-CV02848(JBS) Multi-Page TO Center - Davidson Witness: John H. Craddock 101:22 103:1 104:1,2 cleaned [i] 81:9 completely [2] 4:25 continued [i] 19:4 7:12,16 117:20 118:1,9,23 119:5 119:15,19 120:3,4,9,11 120:17 121:3,7,8 126:18 127:6 Center [2] 3:9,22 CEO [2] 67:21 68:16 certain [11] 38:6 42:23 59:19 77:11 84:17 86:18 87:3 112:14,19 113:17 124:13 cleaning [2] 23:2 81:8 clcar[3] 51:21 52:10 86:20 client [i] 24:10 clients [2] 20:20 24:17 close [i] 54:12 closed [8] 42:10 105:3 105:12 106:14,19 107:4 112:1 125:21 123:12 complexes [i] 6:20 compliance [2] 24:2,3 complied[i] 21:15 compounds [2] 41:7 46:7 concern [3] 107:8,20,23 concerning [2] 102:7 129:6 certainly [2] 86:2 94:18 CERTIFICATE [i] 132:1 certify [2] 131:3 132:9 cetera [2] 117:10 124:24 chain [2] 107:14,15 closers [1] 19:13 concerns [5] 60:8 61:8 CMA [23] 26:9 28:3,7,21 82:8 106:17 107:2 29:9 30:14,15,19 31:6,6 concluded [i] 61:6 31:12 32:8,13,17,19 35:18 conclusion [3] 41:6,20 50:5,6,11,15,16,21 56:1 44:15 48:22 52:2 coalition [i] 31:5 conclusions [8] 48:24 coated [l] 96:18 49:7 50:25 51:6,23 52:12 chaired [2] 32:15,16 coating [S] 101:21 102:1 108:15,21 chairman [3] 27:20 32:8 119:8 120:1,13 conditions [i] 119:1 32:9 coatings [3] 7:9,11 119:4 conferences [i] 25:15 Chamber [i] 34:19 college [9] 67:8 75:25 confidential [i] 92:1 chambers [i] 34:22 81:2,7,8 96:16 99:23 change [6] 9:2 12:7 44:16 110:10 129:7 44:19 87:13 106:10 Collins [l] 130:7 confused [i] 21:11 connection [2] 91:11 120:17 changcd[3] 19:18 62:18 combat [i] 58:3 62:22 coming [4] 8:4 16:21 consideration [i] 125:13 changes [4] 10:25 113:16 84:3 87:23 131:5,9 comment^] 31:24 43:3 considered [2] 46:17 92:1 channeled [i] 21:21 44:2 117:19 118:13,16 consistent [i] 18:11 characterized [i] 118:16 charged [l] 20:21 chemical [27] 7:3,15 8:24 17:13 26:2,4,7 27:9 28:9,10,12 30:3,7 31:1 42:18 65:21 66:1,7,17,20 66:21 92:23 96:22 97:5,7 comments [4] 31:25 56:2 constipation [i] 63:8 74:4 117:21 . construction [i] 8:11 commerce [2] 34:19,22 consult [5] 76:3 86:5 commercial [7] 11:7,13 87:14 88:1,4 11:22 12:4,8,17,18 consultancy [i] 24:2 commission [2] 131:20 132:24 consultant [2] 22:9 74:11 97:11 110:1 commit [i] 76:1 consultations [i] 86:24 chemicals [27j 7:7,8,9 commitments [i] 77:15 consulted [i] 20:20 12:14,15 13:10,17 14:6 14:12,17,25 15:4,6,13,15 16:13 17:14 21:6 25:7,13 35:19 47:12 62:15 64:12 72:24 73:24 81:13 chemist [131 9:10,12,19 9:22 10:5 22:1 69:9 70:16 77:8 102:9 117:1,6,9 committed [2] 84:17 85:5 committee [1] 69:22 committees[i] 30:25 common [4] 39:18 46:16 57:21 82:12 communication [3] consulting [6] 20:8,10 22:10,13 23:11 76:2 consumed [i] 49:6 contact [18] 50:22 63:16 67:17 71:2 81:5 109:11 109:16,17 110:13,16 111:21 114:8,13 115:19 chemistry [i3] 5:22 6:1 81:3,4 88:20 115:21 128:24 129:5,9 6:5,6,7,8,11,12,13,13,14 communications [3] contacted [is] 67:13,15 6:15 8:14 chemists [l] 11:2 chloracnem 112:23 Christopher [i] 3:8 chronic [3] 46:6 62:3 15:2 95:5,23 68:6 79:21 80:11 91:13 community [4] 53:24 91 14,16,23 97:19,2 i 74:18 81:2 99:23 99 21 105:14 114:22 companies [8] 14:1 28:4 115:1 30:19 35:24 61:2 115:25 contain [i] 99:5 125:10,11 contained [4] 29:19 82:21 company [28] 2:8,8,24 106:14 114:9 125:25 circumstances [i] 42:7 2:25 3:7 8:5,12 12:14 containing [i] 102:22 continuing [2] 6:23 7:16 court [8] 2:1,21 5:12 23:7 contractor [i] 91:9 29:16,19 45:2 87:21 contractors [S] 18:12 Court's [i] 20:17 18:14 50:18,18,20 Craddock [73] 2:11 4:9 contribute [3] 93:15 94:14 95:8 control [8] 13:22 14:3 19:19,23 34:6 42:1,11 107:21 controlled [2] 105:3 107:24 4:16,18 5:20 24:21 32:21 33:7,9,10,12 36:1,20 39:13 41:24,25 42:1 45:10 45:13,14 47:20,21,22,23 48:3,5 49:13,18 50:2,3 54:22,23,24 57:9,11 58:12 58:14 59:18 64:11,13,13 64:17 65:13 67:6 71:16 controls [i] 75:8 71:17 77:24 78:8,12,13 conversation [4j 90:7 90:10,20,25 conversations [4] 76:6 89:22 100:1,6 convey [i ] 116:7 80:2 90:15,19,21 91:7 93:24,25 96:10 109:14 115:13 117:1 120:18 121:11 123:24 127:15 128:3,4,5,10 129:18 130:14 131:3,24 cooperative [i] 60:16 Craig [ij 3:17 coordinate [i] 17:12 creation [i] 44:24 copied [i] 47:6 credible [i] 53:17 copies [i] 80:7 crude [1] 25:11 copy [12] 16:18 47:2 50:9 cry[i] 104:17 50:10 73:2 79:16 94:3 127:18,19,21,21 129:3 customarily [2] 47:6 80:13 corporate [3] 9:20 21:12 53:2 customary [i] 47:3 corporation [i] 53:6 CUStomcr|i6] 67:24 68:3 68:4 80:11,12 91:24 92:5 correct 147] 34:11 39:21 106:4,5 122:6,7,17,17,19 39:23 40:8 48:10 49:15 122:22 125:9 50:4 71:21 78:18,24 98:7 98:8,10,11,14,15,17,23 customer's[i] 91:24 99:1,24,25 103:13 106:7 customers ii7] 21:18 109:8,9,12 110:13,14,21 35:8 82:14,16 83:3 92:4 111:6 112:7,8,11,16 113:4 105:15,21,24 111:22 117:2,11,12 124:1,19,20 114:14,15 121:18 122:15 124:25 125:1,21 129:16 122:24 123:5 125:3 131:8,12 customers' [i] 121:15 correctly [3] 61:5 98:20 CUt[i] 20:14 121:12 cutoff [2] 29:6 116:4 correspondence [3] 47:5 87:14 90:5 COSt[7| 20:15 23:2 93:6 93:15 94:14,19 95:8 -D- D[.| 3:3 costs [3] 20:14 23:1 95:25 daily [i] 63:4 council 12] 60:21 72:20 damage 11] 124:24 counsel [io] 4:2,2 72:2 76:8,9,25 97:17 130:15 132:14,18 Dan [ioj 45:17 55:5,9,14 55:16 57:10,15 63:16 65:20,25 counterparts [2] 35:16 Darby [ij 7:23 77:13 dash[i] 40:14 countries [3] 38:5,9,11 country [8] 9:7 15:12 18:19 34:25 52:16 53:18 53:19 104:20 data [16] 15:19 16:3,4 28:20 30:19,21,22 38:25 39:2 46:24 50:16 62:13 91:10 92:14,16 128:23 County |6| 67:7 96:16 date [4] 33:20 65:5,9 city [9j 8:6 9:3,3 20:17 22:16 23:4,6,7 34:19 claim [l] 22:24 claims [i] 41:12 classical [i] 38:21 classified [2] 38:22 57:21 clean [2] 93:7,15 13:10,17,24 14:7,12 17:2 17:13,14 21:6,14 25:5 56:13 68:12 92:24 96:22 97:5,7,11 115:15,16 company's [1] 22:25 compare [i] 124:24 compared [i] 62:14 comparing [i] 46:25 comparison [i] 63:2 contaminated [i] 20:14 contamination [ij 20:18 contemplate [2] 108:23 109:4 context [3] 40:11 108:16 108:19 continue [i] 87:3 110:10 129:7 131:2 132:4 88:25 Couple [14] 10:13 18:8 dated [22] 1:9,10,10,12 69:10 70:12 71:1 83:19 1:12,14,15.15,16,16 41:21 84:1 92:19 110:12 116:13 41:25 45:7,12 54:19 57:6 ` 116:21 123:18,23 127:11 71:13 78:5 90:8,16 93:21 course [9] 6:21 7:3,5,14 - 127:23 24:21 42:18 68:3 125:20 Davidson [6] 3:11 127:17 106:21 107:5 116:19 courses [S] 6:23,24 7:7 126:20,22 Index Page 3' STLCOPCB4025600 Joan Macrtin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS)______ Multi-Page TM days - EPA Witness: John H. Craddock days [4] 18:16 70:12 71:1 1:8 130:2 72:22 74:15 75:6,20,22 effects [14] 24:8 36:4,10 97:25 design [1] 8:12 Dayton [2] 34:19 35:2 designed [i] 101:5 deadly [4] 41:10 43:12 64:12 82:11 detail [4] 55:20 56:22 59:2 113:22 deal [3] 14:20 16:2 68:12 detailed [3i 51:6 55:13 dealing [3] 14:13,14 55:17 51:12 details [4i 70:7 91:3,3 dealings pi 35:15 99:20 108:17 dealt [3] 14:15 16:12 64:1 Detroit [4] 48:8,11,12 decade [i] 52:1 83:7 discussed [7] 77:5,12 79:7 89:18 102:4 128:21 128:25 discussing [3] 36:21 64:18 76:24 discussion [7] 47:18 53:10 100:13,23 103:15 103:20 120:16 discussions [8] 51:6 73:7 74:24 95:12 100:9 100:16,18 101:20 99:2,6 119:12 124:10 129:24 130:24 door[i] 123:14 Dow 12] 28:9 66:25 down |is] 5:12 15:22 16:1 37:1 49:11 52:17 55:21 63:15 72:18 78:19 79:12,14 82:7 104:19 124:21 dozen [6] 18:8 25:17 51:25,25 56:6 97:3 43:10 50:7 55:13 60:10 61:9 62:3,25 64:19 73:1,4 98:17 efforts [4] 15:16 114:7 114:13 116:6 eggs [ii 61:19 eight [4] 2:13 27:25 34:15 70:23 cithcrp] 31:21 37:14 67:14 69:19 70:9 86:1 92:13 109:8,11 deceased [i] 54:17 developed [2] 11:16 12:2 dispel [l] 20:22 decide [i] 23:1 disposal [13] 7:9 16:24 decided [4] 61:20 104:14 developing]!] 81:17 18:9,12,17,18 20:15,21 105:7 111:25 development [8] 11:7 22:2 28:15 30:23 53:5,20 deciding [l] 86:6 11:13,22 12:5,9,17,18 130:11 dispose [2] 18:15,19 decision [io] 60:7 61:6 dispute [i] 29:14 developments [2] 85:22 61:13 88:16,17 104:9,15 86:3 disseminated [2] 33:23 105:5,10 125:13 decisions [] 88:2,7,13 88:14,17,18 devious [l] 123:5 dibenzyl [7] 102:3,7,8,9 102:11,12,14 64:23 dissemination [i] 57:4 dissertation [i] 6:16 declare [l] 131:11 Dick [4] 67:19,20,21 distributing [i] 104:9 defendant [0] 3:7,15,20 68:13 distribution [8] 19:11 4:3,11 96:23 DICKER [ij 3:21 37:1 90:13 94:1 104:20 DEFENDANT'S m 1:7 defendants [3] 2:9,25 22:20 differ|i| 6:11 different [Mi 22:8 25:17 35:23,24 48:22,24 56:18 69:2 81:23 86:14 87:5,8 105:8,11 112:1 distributor [3j 123:6,9 123:13 distributors h 115:19 Defense [3] 31:7,16 87:10 109:19 115:21 116:3,9 32:13 difficult [i] 75:9 district [5] 2:1,1,21,21 defensive [i] 73:19 digress [i] 70:18 23:8 define [31 102:9 124:10 124:12 DiMuro[67j 1:5 3:8 23:23 24:6 43:22 44:11 divide [l] 72:3 division [14] 9:18,24,25 defined [i] 105:1 45:1,4 46:19 51:2,5,14 11:9,11,25 12:1,3,20 definition [i] 99:13 53:1 54:4 59:10 61:10 13:15 25:13 27:5 35:19 degree [2i 5:22 6:2 62:7,20 65:22,24 66:8,13 35:23 Dr[t7] 4:16 5:20 24:21 electric [9] 26:18,19,24 33:10 36:9,13 39:25 40:1 29:10 35:11,16,17,18 40:2,3,4,24,25,25 41:16 104:19 41:16,16 42:1 45:10,13 45:16 48:22,23,25 49:21 51:10,17 52:5 53:10,16 54:6,7,17,24 64:12,13 67:6 70:21 71:16,19 73:6 74:4 75:18 77:17,20,24 77:25 78:9,11,15 80:2 89:5,22 90:10 91:7 93:24 electrical [20] 18:7 19:7 19:9 26:12 27:1,4 28:12 28:13,14,15 29:7 34:20 37:17 38:1,18 57:11 81:12 104:18 105:4 106:15 elementary [i] 56:20 elements [2j 6:15 120:2 96:10 108:4 109:14 112:6 ELSERpi 3:21 113:12 117:1 120:18 121:11 128:3,4 129:19 employed [3] 8:22 132:15,18 drafted ii] 123:25 employee ]4j 35:15,17 drive | i | 126:14 66:6 132:18 Drugm 14:15 employees i2] 35:12 drumi2j 123:11,12 100:7 DUANE ]ij 3:16 employment [4] 8:1 duC[i] 23:12 19:21 108:11 115:18 ducs[i] 25:20 enclosed [i] 29:7 dulym 132:10 enclosure [i] 55:22 Dupont [2] 28:9 67:1 enclosures [3] 49:11 78:11 79:5 duration [2] 111:6,7 encompassing [ij 42:16 during [6] 9:15 21:3 31:2 45:23 115:18 127:17 encountered [i] 58:5 degrees [i] 56:22 deleted [2J 79:1,4 deliberate [i] 109:19 department [32] 9:20 11:4 14:16 15:2 16:10 22:4,4,5 25:4 36:5,6,11 36:14 38:24 39:4,7,8,11 45:18 49:3,23,25 53:8 59:3,6,8 63:19 71:24 77:13 78:23 80:13 130:11 departments [4] 43:21 44:9,13 59:9 depending [ii 20:15 deposed [6] 4:19 97:1,2 97:4,23,24 73:10 74:6 76:5 77:23 78:25 79:3 80:15 82:15 divisions [i] 27:8 Doctor [ii 124:5 duties [i] 21:2 82:25 83:17 84:13,24 86:7 doctoral [tj 6:16 86:9,16 87:7,11,21 88:3,9 -E- 93:16 94:16 95:16 102:6 108:25 109:13 110:22,24 document [39| 33:6,7,11 33:14,24 39:9,9.13 42:1 E12] 3:1,1 112:17 114:24 115:9 43:25 47:19,24 48:4 49:13 caglcS]i| 61:19 116:13,17 118:11,15 49:16,18 50:11 54:24 early [9] 18:16 27:15 119:16,23 120:7,23 121:4 58:11,12,15,2] 64:11,13 34:14 60:13 100:11 122:23 126:25 127:11 64:16 65:13 71:16 73:3 105:17 106:22 107:6 128:2 130:24 78:12 79:17 93:24 94:24 111:13 dioxin [l] 20:18 123:25 124:7 126:1 127:16 128:4,17,21 casicrpj 124:12 direct [i] 129:20 documentation [i] easily [i] 62:24 directing [i] 53:12 102:16 easypi 40:9 direction [2] 51:17 documented [3] 46:5 eating [i] 63:1 132:14 82:20 130:23 Ecology [2] 50:19 55:24 end [4] 40:13 48:22 56:9 97:22 endeavor [i] 111:21 endsp] 82:18 Engineer11] 8:24 engineering i2] 8:11 22:4 entered [i] 29:9 entering [i] 107:21 entire [2] 21:23 22:3 entitled 14] 33:7 47:24 58:12 64:12 environment [6] 44:6 50:19 55:25 61:18 107:12 107:22 deposition^] 1:72:11 4:3 97:20 98:1 131:4,6,10 132:8,10,16 . depth [i] 70:11 derived [2] 8:1798:12 dermatitis [i] 112:25 describe pi 99:17 described [3] 68:5 89:4 102:5 describes [2] 110:5 113:9 directly [S] 6:25 72:14 documenting pi 18:1 EDELMANnj 3:21 92:5 113:6 118:20 documents (i2) 37:5 Edison [3] 26:18,19 directorpo] 36:15 45:17 47:15 50:6,9 59:20 97:13 29:10 45:20 49:24 53:6,7,8 55:6 55:16 72:9 disagree [i] 44:17 disagreed [i] 44:15 disclose [i] 76:6 discovered [3] 61:18 67:7 81:10 97:17 98:2,3,3,13 108:14 editor [2] 57:10 64:25 doesn't [31 87:7 119:17 educate [i] 17:1 123:13 educated [i] 37:24 Dolly [2] 48:7 83:5 education p] 6:24 7:16 domain [i] 17:21 educational ii] 5:21 done [30] 5:13 6:21 20:10 20:12,12 22:13 23:11 49 " Edwards [i] 31:19 *'* discovery [i] 127:17 50:17 51:17 52:18,25 53 EEI [4] 26:17,21,22,23 environmental [34] 13:11,12,14,19 1^:1 16:15 19:17,19,22 20:3,25 21:9 31:7,16 32:2,3,13 34:5,9 60:9,22 61:8,24 72:2,4,13 76:2,4,7 104:22 107:9,10 124:23 130:15 environmentally [ij" 61:14 EPA [31] 20:21 28:23 29:22 30:19,19 31:8,14 31:16,20 32:1 37:14,19 DESCRIPTION [i] discuss [3] 48:17 76:12 53:11,25 54:2,10,10 60:1 effect [2] 14:11 90:4 37:20 38:17 42:1,4,9,15 Index Page'H- STLCOPCB4025601 Joan Macrtin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-Page TM epidemiological - guy Witness: John H. Craddock 44:19 52:3 56:6 60:18 Exhibit [M] 32:23 41:22 feeding [i] 72:23 formed [6] 13:9 14:19 generally [12] 6:13 24:9 63:23,24 64:1 74:15 82:24 45:8 54:20 57:7 58:9 64:9 felt [2] 22:22 93:14 27:14 31:5,6 42:21 29:22 44:1 47:11,13 59:13 83:4 91:9,10 128:23 epidemiological [*] 65:11 71:14 78:6 90:17 93:22 127:14,24 few[S) 9:5 46:18 54:9,10 former |4] 21:18 35:8 115:14 58:1 68:4 79:19 80:17 104:10 119:9 121:23 49:17 51:1 54:3,9 108:2 112:5,9 113:19 Exhibits [3] 1:7,17 47:16 field [7] 9:4.6 19:12 39:20 forming [ij 8:25 exist [l] 125:19 40:10 53:17 74:14 formula [i] 119:17 generated [3] 47:8 103:24 109:22 epidemiologist [3] existed [4] 60:17 73:9 file [3] 90:5 95:10,19 formulation [3] 102:1 48:25 49:21 53:18 epidemiology [8] 1:11 36:9 40:20 47:24 49:14 49:24 52:7 53:8 96:17 112:10 existence [3] 27:12,15 27:16 existing [i] 11:15 filed [4] 28:22,22,25 42:9 final [3] 56:7,8 104:24 financially]]] 132:19 117:25 118:4 formulations [6] 7:9,11 99:18 101:21 102:22 122:25 equation [l] 124:11 expectation [3] 125:2,3 equipment [17] 18:8 125:8 27:4,7 28:12,13,14,15 29:7 30:23,23 34:21 38:2 38:6,18 66:3 105:4 106:15 expected [4] 84:22 87:1 4:25 84:10 equivalent [i] 46:16 expensive [i] 93:19 fine [io] 5:7 12:14 13:8 14:12,25 15:4 16:13 25:13 81:10 121:11 forth 13| 86:18 22:18 61:16 finish [l] 45:1 forward [i] 94:7 fire [8] 20:20 23:3,4,6,9 81:6,8 99:22 found [7] 40:23 70:11 82:1 102:12,15 111:2,9 errors [i] 40:9 experience [3] 14:20 40:20 66:5 fires [l] 124:17 four [4j 27:19 56:9 69:1 71:22 especially [i] 75:10 essential [i] 124:14 essentially [M] 6:15 10:24 12:1,7,18 18:20,25 expert [6] 20:16,17 22:15 24:11 98:9,16 first [24] 9:8 13:22 16:16 16:18 52:18 55:5 60:6 67:6,11,17 68:19 69:3,17 expertise [i] 58:2 70:9,11 71:22 76:24 79:6 experts [3] 39:19 40:6 82:4,6 97:19,21 127:1 fourth[i] 83:16 frames] 12:16 67:12 106:8 112:13 Free [2] 48:8,11 20:2 31:25 33:17 44:21 46:24 92:24 93:5 expires [2] 131:20 132:24 129:12 French in 38:12 generic [l] 120:11 gentleman [i] 130:13 George [2] 36:11,13 Gerard [2] 3:11 97:9 Gilhouscn[i] 72:1 GINSBERG [ij 3:3 given [6] 17:5 39:3 68:20 98:5 126:20,21 giving [3] 35:13 92:12 92:13 God [3] 19:18 70:22 126:11 goes [3] 116:17 121:24 123:8 gone [4] 47:13,14 52:12 104:4 good [10] 4:16 9:4 39:18 established [S] 53:16 119:18,19,25 120:2 exposed [l] 43:11 fish [2] 49:5,6 frequently [$j 15:25 exposure 117] 23:13,15 five [3] 6:20 10:17 71:23 16:7 34:12 122:21,24 53:22 74:13,16,17,18 75:15 119:3 establishing [i] 29:5 23:18,21 38:21 40:22 five-gallon [i| 123:11 friend|i| 29:16 Gossage [2] 92:25 95:2 Estate [i] 2:3 estimate [i] 37:19 51:12 96:14 110:21,25 111:3,6 112:15,20 113:1 113:10,12 Ct [4] 2:4,22 117:10 124:24 expressly [i] 4:7 Ethel [l] 2:16 Europe [io] 38:16 45:23 45:24 46:1,2 47:4,8,10 55:6 57:15 European [4] 38:5,9,10 38:16 extent [4] 17:19 84:10,22 85:2 extractions [i] 8:17 eyC[2] 112:22 127:20 cycS[i] 63:14 Evans [i] 70:4 evaporate [i] 36:24 -F- flame [i] 103:18 front [3j 50:10 73:16,21 fledged [l] 15:14 full 17] 4:17 15:14 71:8 flics [l] 126:12 77:9 84:10,22 85:2 Flipm 55:21 full-time [2] 64:3,6 focal [3] 21:12 53:3 56:12 function 117] 11:19,23 folks [i] 7:23 11:24 13:19 15:12 17:12 21:23 30:18 39:21 40:5,6 follow-up [2] 83:21 53:2,6 55:15 56:12 59:12 85:12 69:9 follow-ups [i] 123:19 functions [l] 113:17 followed [3] 54:11 95:6 fund [4] 20:13 31:7,16 113:23 32:13 governmental 37:6 52:3 60:16,19 government's [i] 104:17 governmental [i] 14:20 grade [2] 10:24 12:8 graduate [i] 5:24 graduated [i] 5:25 grain [i] 114:20 grandfather [i] 63:7 grappling [i] 101:14 event [3] 73:14 80:20 F [i] 3:17 following [3] 60:5 85:8 fundings 93:11 great [i] 126:13 81:22 events [2] 89:11 95:14 eventually [i] 107:17 everybody [2] 14:10 73:22 evidence[i] 41:11 exact [3] 20:1 72:8 88:24 exactly [5] 33:16 40:10 64:24 113:17 127:20 exaggerated [2] 58:4 82:10 EXAMINATION [t] 4:14 96:8 115:11 116:24 123:21 128:1 facilities [4] 14:6 18:5 18:10,18 fact is] 29:4 50:18 97:4,8 111:16 factor^] 88:15 facts [3] 58:23 59:19 74:20 85:12 follows [l] 4:12 food [18] 12:14,25 13:7 14:12,14,15,17,24 15:4,5 15:8,11 16:13 25:12,14 25:15 107:14,15 foreC[3j 60:14,24 61:3 faculty [i] 7:20 foregoing [4] 131:4,12 failed])] 42:16 132:8,10 fair [3i 67:3 95:20 110:19 forenoon [i] 2:14 fall [i] 88:25 forget [i] 72:8 familiar]5] 4:23 99:9 forgot}i] 48:19 102:19 114:18,21 forgotten [i] 20:1 familiarity [2] 99:11 form [43] 23:23 24:6 funny [i] 123:4 furansm 102:3,7,8,9,11 102:12,15 greatly ii] 82:10 green [i] 72:19 Greene [i] 3:12 Greensboro [ij 3:13 -G- grossly [i] 58:3 G-A-F-F-E-Y [i] 48:1 group [36] 8:25 10:9,10 10:11,12,23 11:1,2,3 Gaffey [20] 36:9 39:25 12:15 13:9,11,12,14,18 40:1,25 41:17 47:25 49:12 13:20 14:2 16:16 19:17 49:21 52:5,21,21 53:10 26:9,13,14 28:25 29:11 53:16 54:6,7,17 112:7,7,8 31:11 32:8,9,11,15 35:21 113:12 35:22 61:6,12,13 72:21 Gaffcy's[4j 50:1 51:1 117:10 51:11,17 groups [13] 25:19 26:10 GARY Lij 3:3 26:15 31:13,13,25 32:2,4 examined [2] 2:12 4:11 example [3] 35:10 79:6 82:24 exceeded [3] 111:9,11 111:12 except [4] 10:25 19:1 115:15 familytw 11:17 far [io] 29:3 64:7 76:21 93:11 96:20 101:4,9 108:15 111:2 126:16 FDA [3] 15:2 16:10 60:21 43:22 44:11 46:19 51:14 53:1 54:4 59:10,13 61:10 Gateway [i] 3:22 62:20 66:9,10,14 73:10 GE[3] 35:10,12,21 74:6 80:16 82:16,25 84:13 gearpj 68:16 84:24 85:12 86:7 87:16 geared [1] 98:24 88:3,10 93:17 94:17 95:16 102:6 108:25 109:13 gearing [i] 13:24 34:1,23 35:15,17 72:10 gUCSS 117] 5:2 7:2 20:24 23:14,24 29:15,22 37:24 38:3 66:15 72:4 75:2 77:24 82:5 97:21 100:23 101:10 78:22 91:4 fears [i] 74:20 110:22,23 112:18 114:25 general [22] 7:2,7 21:20 guidelines [i] 31:8 excused [i] 130:25 Executed [i] 131:13 Executive [i] 55:25 Executrix [i] 2:2 feathers [i] 61:19 February [3] 20:6,7 21:7 federal [4] 20:16 23:7 56:5 81:19 118:2,12 119:16 121:4 122:23 126:25 128:15 131:5 format [i] 108:18 22:21 30:24 35:11,16,16 " guy [6] 69:7,23 70:3,13 35:17 48:17 55:16 60:1 70:15 91:5 76:15,20 79:18 100:13,15 100:23 101:10 102:7 122:1 125:16 -H- Index Page 5 STLCOPCB4025602 Joan Macrtin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-Page TM H - lab Witness: John H. Craddock H [12] 2:11 3:11 4:9 12:1 46:5 51:12 52:11,11 61:15 independent [4] 43:11 interesting [i] 7:17 journals [ii 8:23 12:9,13,20 13:3 33:9 62:25 82:21 109:10 50:17 72:21 74:11 intc.rimpt.,i 12:12 Jrpj 3:11 64:13 131:3,24 124:23 126:19 independently pi intermediates[i] 14:18 judgep] 22:18 31:19 half [3] 25:16 37:16 97:3 handp] 90:11 handed [i] 127:20 handle [3] 21:23 26:8 73:12 handled [i] 47:11 handling [i] 109:23 handouts [i] 57:3 happening [i] 85:15 happy [3] 5:3,9 84:6 Harbisoep] 74:12,17 74:18 hardp] 25:7 Harvey pi 4:18 hatS[i] 35:23 hazard [4] 61:15 112:21 124:23 126:19 hazards [6] 23:20 82:9 82:18 112:15,19,21 head [2] 36:10,13 heading [i] 57:14 health [23] 23:20 24:8 36:4 40:5,21 41:5 43:10 50:7 51:11 55:13 60:9 61:9,15 64:19 72:20 73:1 73:4 82:21 98:17 112:15 112:19 124:23 126:19 hear [2] 5:3 95:1 humans [6] 40:24 57:20 82:10 107:17 108:24 109:3 Humpreypi 48:23,23 48:25 hydrocarbon [S] 8:17 11:8 25:5,7,12 hydrocarbons [3] 7:1 11:10,25 hygiene [l] 36:14 hygienist [2] 68:22 69:6 hygienists [i] 36:16 -I- IBT [3] 108:7,9,14 ICF [9] 91:8,13,15 92:9 127:15 128:9,14,20 129:5 idea [3] 53:22 110:19 126:4 identification [u] 32:24 41:23 45:9 47:17 54:21 57:8 58:10 64:10 65:12 71:15 78:7 90:18 93:23 127:25 identify [i] 75:11 II [2] 3:4,4 ill [2] 40:21 41:5 illness [2] 46:6 52:11 51:22 interpretation [2] 36:12 judgment p] 39:19 INDEX [2] 1:1,7 41:2 Jliuillvyf[,i,j 1i-2>77:.1m4 indicated pi 130:14 interpretations [l] 36:4 jumppj 28:2 indicates [2] 40:20 129:21 indicating [i] 102:16 individually [i] 2:4 industrial [i3] 12:13 intervened [i] 28:21 intervenorp] 29:10 intervention [2] 30:11 31:10 intriguing pj 7:17 jumped [i] 20:24 Jumping [i] 16:15 June [2] 19:24 21:7 justification ii] 31:21 13:10,16 14:6 17:14 20:19 20:19 21:5 36:14,16 68:21 introduced ii] 72:17 69:6 109:25 inventory [ii 18:4 industries [7] 2:6,23 investigate [i] 9:1 -K- K-I-L-G-O-U-R [ij 78:10 3:15 29:13 96:13,21 124:14 invited [i] 52:15 Kalcy[23] 70:16,18,21 involved [27] 7:24 8:14 71:4,19 73:6 74:4 75:18 industries' p] 29:21 22:25 23:12,14,15,16 77:17,20,25 78:9,16 89:5 industry [9] 26:7 31:24 24:22,25 25:17,25 26:1,9 89:22 90:2,3,10 129:9,14 32:3 65:21 66:2,17,20,21 2--6:-1--5-,-1--9--2--8--:-9-,-1--8-,-2--0---3-0--:-1--4 129:19 130:6,22 74:16 30:16 31:2 60:20,21 73:24 75:5 98:20 104:6 Katzp] 48.8,16 83:6 inflammatory [i] 82:2 information ps] 16:5,6 16:23 23:20 24:15 35:25 36:3,7,17,19 37:3 39:3,22 39:24 50:12 55:13 56:14 involvement [] 31:2,3 76:17 84:5,11,23 involvingpj 20:18 issuance |i] 28:23 keeppj 11:20 85:21 95:20 keeping [2] 16:22 18:10 Kellogg 14) 8:5,10,11,19 56:17,18 57:2,3,5 58:21 issuC|i6| 18:25 22:23 58:22 59:12,14,22 60:1,6 23:5 29:6,8 44:20 57:18 Kent [5] 69:15.16,17 71:7 130:21 60:11,25 61:1 62:9 63:16 60:23 61:16 81:19 91:12 keptp] 113:20 65:14 68:1,2,7 73:17,20 95:7,24 124:8 125:24 key [3] 124:8,14 126:6 73:23,23,24 74:8 76:20 126:5 76:20 79:9,18 82:13 84:7 84:9,18 86:1.2 87:4 88:15 issued ii] 61:13 kids [2] 56:19,20 Kilgourpj 69:10,19 heard [io] 5:5 69:13 93:19 102:3,11,12 112:23 112:25 113:3,5 hearing [i] 68:13 hears [i] 68:15 ills [i] 52:11 imagine [2] 94:22 129:2 immediate pi 72:6 immediately [i] 59:24 impact [i] 44:6 89:21 91:13,14,16,24 92:2 issues pii 21:13 26:11 92:3,8 110:4 116:7 121:5 29:9 34:8,13 55:15 58:19 125:23 126:3 128:9,13,13 62:16 63:22 68:12 72:22 128:20,22 129:4 itemp] 60:6 ingest [l] 109:5 items [2] 18:9 64:4 70:10 78:9,16 89:15,18 130:5 killpj 63:9 killed [i] 126:12 Kimbrough's pj 108:4 HECKSCHERpj 3:16 implement [3] 13:25 hell [21 53:20 123:10 14:4 32:5 ingested [3] 108:23 109:2,21 itself [41 23:9 39:3 111:23 kind 16] 43:1 75:3 80:21 113:9 108:18 119:10 121:6 HELMS [i] 3:11 help [3] 68:1,2 93:6 hereby [4] 4:1 131:3,10 132:9 implications [2] 74:25 76:14 important [i] 60:5 importantly [i] 40:22 ingestion [3j 38:23 40:17 109:6 inhalation [2i 109:7,18 initial pi 71:1 -J- J |3| 63:17,17,18 Jackie [I] 28:25 kinds [3] 56:14 77:9 91:10 knew pi 46:1 58:23 63:3 75:5 101:9,12 115:3,4 hew p] 104:17 improper [i] 20:21 injuTy[2] 22:24 23:12 January pj 33:20 41:12 knowing[2] 80:22 86:17 hiatus [l] 18:17 in-house pi 35:7,9 76:24 inorganic [7] 6:10,11,14 6:6,7,8,9 high [loi 27:25 28:2 56:19 inaccurate [i] 130:20 input [3] 30:15 44:2 59:1 68:16 69:5 73:13 80:19 inadvertent [2] 109:17 59:7 98:3 41:14 124:1 Japanese [l] 15:11 JBS [i] 2:4 knowledge [IS] 24:16 27:17 30:3 37:22 59:1 63:21 80:1,4 94:9 102:7 102:14 119:11 120:22 91:5 92:20 93:1 109:18 inquiries [3] 21:17 47:13 Jefferson [ii 7:4 121:5 122:13 highest [i] 89:25 Inc [7] 2:7,16,23 3:15 58:19 Jersey [III 2:1,21 3:5,9 knowledgeable pj highly [i] 57:18 hindsight [i] 125:7 history [2] 19:21 104:8 hold [4] 25:22 59:23 65:22 98:16 hollering [i] 11:20 homogeneous [3i 8:15 9:1 10:3 honored [i] 77:16 horrid pi 54:15 hourp] 126:14 hours pi 2:13 house [i] 35:9 human [12] 40:19 41:9 65:14 91:8 128:9 Inc. [i] 128:20 incidental 110:10,17 incidental [2] 42:11 44:22 incidentally [i] 42:18 inside [ii 76:8 insignificant [i] 44:7 instance [2] 100:20 118:5 Institute [6| 25:14,15 26:18,20 29:11 108:5 include [3] 11:14 19:9 instruct [i] 52:23 111:17 insurance pi 22:25 included [7] 11:10 26:12 27:5 41:18 58:22 80:3 intend [2] 109:2,10 111:18 intended [S] 105:25 includes [1] 52:2 109:6,7,15 119:1 including [4] 27:4 82:21 inter-agency [i] 60:14 93:1 105:11 intcrest[2] 34:23 61:2 incorporated [i] 36:1 interested pi 132:20 3:22 8:7 81:15,16,20,24 96:11 JH [l] 72:12 Joan pi 2:2,3,22 job pu 10:25 12:12 14:4 21:14 30:21 34:2 53:4 64:3.6 68:9,11 jobs pi 9:2 Johnpoj 2:11 4:9,18 33:! 41:25 59:18 64:12 72:16 131:3,24 22:17,21 known [7J 22:21 39:22 53:16,18 59:19 76:21 115:15 knows [81 65:2166:2,17 66:25 67:1 76:14 120:1 120:12 Kuncaitisp] 2:17 4:4 132:5 -L- Joinp] 51:16 joined [3] 25:19 63:24 70:17 journal [i) 65:1 L-95-CV [i] 2:4 L.L.Pp] 3:11 labp] 8:9 Index Page fr1 STLCOPCB4025603 Joan Macrtin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-Page TO label - need Witness: John H. Craddock label [l] 57:19 78:19 manufactured [6] 17:16 meetings [5] 25:9,18,20 97:5,6,11 98:3,22 99:2,15 labeled pi 41:7 listings] 63:7 71:22 17:17 42:17 46:7 116:1 69:7 90:9 99:22 102:20,21 103:25 labels [II 110:3 laboratory [4] 8:7,8 11:18 75:7 LAEpj 3:3 Lancasters] 68:17 70:13 71:2 large [i] 27:22 Larry [S] 63:17,17,18 78:22 80:7 last [7] 41:6 57:25 75:23 78:21 94:6,7 129:21 late[2] 27:14 110:15 latest [i] 65:9 LATHAM [i] 3:8 Laurel pi 3:5 lawful p] 4:10 lawsuit [7] 28:21,22 29:9 lists [2] 22:20 124:18 118:8 literature [12] 36:5 43:10 50:8 54:11 102:24 103:4 103:6,10,24 105:19 manufacturer [] 28:16 58:1 60:19 99:15 114:23 115:2 109:22 113:8 manufacturers [mj litigations! 23:16 72:3 26:3,4,13 27:1,3,5,10 28:11 30:4,7 31:1 38:10 livers] 113:3,10,13,17 66:7 114:19 lives [i] 124:17 manufacturing [ii] LLP [i] 3:16 11:24 12:3,20 14:5 15:15 lobbied [i] 30:10 lobbyings] 28:18 30:5 lobbyists [3] 28:19 30:4 30:8 location [l] 47:7 logical [i] 14:21 long-term [i] 46:6 18:5 38:13,14 104:16 105:10 106:13 March [6] 45:12 46:9 47:20 48:8 55:8 60:15 mark [4] 71:12 90:14 93:20 127:15 marked [3S] 1:8 32:20,23 33:6 39:13 41:22 45:8,14 look [M] 39:25 40:7 49:9 47:16,19 48:5 49:13 50:3 member [9| 25:13 27:9 27:18,19 30:17 35:18 55:4 63:18 83:5 members [2] 21:25 26:6 membership^] 27:23 27:24 memo [3] 1:15 71:13,19 90:16 129:18 Memphis [i] 5:23 mentioned [4j 7:11 28:18 96:25 130:4 met [9] 18:2,12 31:13,13 31:14 61:3 86:11,12 102:4 methodology [3] 75:6 75:15,16 methods [l] 16:24 Michigan [4j 48:12,20 49:1,5 104:7,13,25 105:6,14,23 106:12,17 107:2,8,19 108:11,22 109:2,10,23 111:21,25 113:9 114:7,13 114:22 115:1,3,4,18,20 115:22 116:1,6 117:14 118:8 119:13 121:1,14,17 121:23 122:3,4,8 125:2 125:12,13,17 126:16 128:8,12,19 129:15 Monsanto's [18] 22:3 24:15,16 35:9 36:5 58:18 60:7 61:6,12 73:15 76:13 84:4,23 85:2 88:11 104:8 104:15,21 month [i] 16:8 months [3] 84:1 88:24 91:6 MOORE [ij 3:11 30:11,16 31:11 96:19 53:21 56:5 74:12 94:7 54:20 57:7 58:9,11 64:9 mid [2] 67:11 99:23 morbidity [ij 40:21 lawsuits [i] 31:15 LD [2] 46:25 109:4 leaders] 10:9,12,23 11:1 11:3 117:10 lcarn[2| 17:23 67:6 learned [1] 80:12 least [i] 37:16 led [l] 15:1 left [5] 11:4 25:3 38:11 63:24 70:22 legal [4] 71:24 76:13 77:10,13 legislation [i] 18:21 legislative [i] 41:8 lessp] 38:3 letter^] 1:9,10,10,12 1:12,14,15,16,16 41:21 41:24 42:2,4 43:1,5,15,17 43:17,20 44:10,20 45:7 95:19 104:8 108:12 124:6 126:16 128:10 129:23 looked [12] 7:17 40:1,2 51:18 52:12 53:13 56:16 81:11,12,13 99:16 108:20 lookings! 9:2 14:19 74:22 80:6 100:15 108:17 looks [2] 55:12 127:20 lostp] 127:1 Lothar p] 2:3 . lots [3] 20:12 35:15 80:22 Louis si 2:16 45:21,25 46:2 59:18 132:4 low [2] 36:22 62:4 -M- Mpj 3:8 MAE [8] 33:9 45:12 47:21,23 48:1 78:10 64:16 65:11 71:14.17 78:6 78:13 90:17,20 93:22,25 middle [I] 72:15 98:4 123:24 127:13,22,24 might [U] 23:21 63:8 128:5 129:18 67:18 69:23 76:7 112:12 market [ij 125:10 119:20 122:9,9,11 125:19 128:8.25 131:7 markingpi 123:15 mildly 12| 46:17 57:22 master's [i] 6:2 milespj 126:14 mastering [ii 17:6 million [i] 29:5 material [2] 103:19 107:21 mind [4] 51:20 103:14 112:21 119:25 materials [i i 108:4 Mineni 72:10 matterpoj 10:1,19 17:25 24:1 76:19,23 77:2 91:22 91:25 111:16 mineral [9j 2:8,24 62:5,8 62:18 63:1,7,12 115:16 may [221 4:3 8:3 18:25 minimum p] 111:9 45:25 54:10 69:24,24,25 minute [i] 12:11 83:19 89:14,15 90:5 91:21 misrepresented pi 100:25,25 107:15,16,18 43:13 109:5 111:11 116:22 118:20 Missouri [5] 2:17,19 132:2,7.23 mornings] 4:16,24 98:4 98:20 116:8 MORRIS [i] 3:16 MOSK.OWITZ [i] 3:21 most [9] 12:24 28:10 37:25 51:18 57:13 62:12 73:3 87:20 90:22 motivates [i] 125:9 motors] 62:6,7,8,19 63:2 63:9,13 moves] 12:3 61:21 63:8 moved [8] 12:1,13,19,25 13:9,11 14:1 19:16 moving [1] 123:14 MP [3] 54:24 55:3,4 Ms [9] 1:4 33:5 48:7,16 66:10 115:8,12 116:11 127:9 Mt [i] 3:5 45:10,13 47:20 48:7 54:19 127:18,18 McCarvillc[2] 72:5,14 54:23 55:2,7,11,21 56:25 57:6,10,12,17 64:25 78:5 78:9,15,22 79:5,24 80:5,6 93:21 94:12 95:7 97:25 127:14,23 letters pi] 47:3,8 82:14 82:16,24 83:1,2,3,4 95:22 105:20 Macrtin si 2:2,3,3,22 magazine [i] 65:1 magazines si 8:24,24 magistrates] 20:17 22:16 Mahoneys] 67:19,20 67:21 68:13 mean [13] 17:7 35:9,10 36:23 52:22 77:11 88:4 101:7 102:8 107:11 114:14,17 126:2 means [l] 36:24 measurable [i] 42:20 measure pi 124:22 levels] 40:17 69:5 89:25 major [ii] 8:6 28:10 media [9] 21:19 41:9 91:5 92:21 93:1 37:13,15 48:12,13 56:12 43:13 73:14 80:20 81:15 levels si 56:18 110:20 66:19 67:24 74:1 99:15 81:22 82:3 126:8 110:20 111:8 majors [l] 66:21 medical [IS] 7:4 22:3 Levinskass] 36:13 40:3,4,25 41:16 makes [3] 46:3,14 121:24 24:5,11 36:5,6,10,11 38:24 39:4,7,8,11 40:5 man (ii 74:16 49:22 53:7 59:7 72:22 Liberty pi 3:17 Management [i] 35:4 meet [2] 15:23,25 linep] 51:10 manager [13] 11:7,13,22 meeting [4S] 7:15 34:20 lines [i] 72:18 12:4,18 14:2 19:19,22 69:3,4.5 70:12 71:2,9 lineups] 78:21 119:13 20:3,25 21:9 34:5,10 72:17 77:1 83:12,13,13 121:1 managers [i] 59:15 83:15,18 84:3,14,16,20 linkp] 51:13 manners] 22:23 lists] 18:13 19:3 63:5 manufacture [io] 11:17 80:9,14 90:13 94:1 130:18 15:11 25:6 42:11 104:23 listed si 47:2 50:19 105:2,7 106:14 109:19 112:1 85:9 86:11 87:24 88:23 89:3,3,12,13,24 91:1 92:18,20,21 93:4 94:10 100:10 129:12,13,13,19 129:22 130:2,7,8,10,19 misunderstand [i] 118:19 MULLISSp] 3:11 MW si 8:5,9,11,19 misunderstood [i] 118:20 -N- Mitchell [i| 130:13 N [i] 3:1 molecule [i] 42:24 NaCLp] 40:14 momentp] 70:18 name [9] 4:17 22:19 29:1 moments [i] 46:18 69:9,12 90:13 96:10 monitoring [i] 106:4 115:13 131:10 Monsanto [143] 1:13 2:8 named [i] 130:13 2:24 3:7 7:20 8:2,4,22.23 names [3] 25:21 68:20 9:9 12:13 13:16 17:1 129:23 22:10.13 24:18 33:9 35:8 Nancy SI 2:17 4:4 132:5 36:6 37:5.11,12,12,15 38:12,24 45:18,21,23 46:6 Nashville [1] 5:25 47:4,8,9.10.11 49:23,24 National si 25:9 26:12 50:14,16 53:3 54:5 55:6,9 27:1 108:5 56:13 57:15 58:8,13,17 Natural [i] 49:4 59:3 60:18,24 61:20 63:19 nature [i] 19:20 63:24 64:2,3,5 66:6,23 67:14,21 68:4 71:4 76:7 NBC[i] 114:6 77:14 79:16,21 84:11 85:8 necessarily [i] 81:18 85:21 86:5,23,25 87:3 necessary [3] 24:12 76:3 88:1,6 92:7 93:9,14 94:13 131:7 94:21 95:6,8,13 96:22 need [4] 5:8 51:5 75:22 Index Page 7 STLCOPCB4025604 Joan Macrtin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-Page TM needed - phosphate Witnes s: John H. Craddock 119:21 O [1] 3:12 39:20 27:18,19,20,22 28:6,7 61:16 62:4 63:23 64:2,3,7 needed [4] 36:3,7,17 67:25 neither [i] 132:14 NEMA [5] 29:11 31:6 32:12 35:21,22 neurological [i] 82:22 never[8] 35:17 46:4 82:19 102:16 108:11 117:6,10 123:9 new [421 2:1,21 3:5,9,22 8:6,7,14,25 9:2,3,4 11:14 12:23 13:9 14:9,10,22 15:12,16 16:3,4,20 20:17 22:16 23:4,6,7 28:1 31:8 31:22,23 32:1 44:21,22 56:8 81:15,16,20,24 96:11 113:25 Newark [3] 3:9,9,22 news [9] 1:11 8:25 21:19 43:13 47:22 50:2 80:20 81:15 114:6 newspaper [3i 48:12 65:1 67:10 next [3] 11:6 86:11 88:20 NIOSH [6] 39:9 111:9 111:11,12,17,18 nobody [4] 44:15 52:17 53:11 63:1 o'clock [2] 2:14,14 O'Connor [30] 1:3,4,5 3:3,21 33:5 51:16 66:10 68:23 83:15 96:4,9,10 103:3,5 106:22 107:6 115:6,8,12,13 116:11 118:2 123:18,22 126:21 126:23 127:2,7,9 O'Neill [5] 63:17,17,18 78:22 80:8 object [34J 23:23 24:6 43:22 44:11 46:19 51:14 53:1 54:4 59:10 62:20 66:8,10 73:10 74:6 80:15 82:15,25 84:13,24 86:7 87:16 88:9 93:16 94:16 95:16 109:13 110:22,23 112:17 114:24 118:11,16 119:16 126:25 objecting [i] 66:14 objection [22] 44:13 51:16 61:10 86:8,9 87:15 87:17 88:3 102:6 103:2,3 103:8 106:20 107:7 108:25 118:2 119:22 121:4 122:23 125:6 126:24 128:15 objectionable [2] 86:15 86:17 open [12] 61:22 104:11 105:2,8,16 106:13,19 30:18 32:17,18.19 35:19 50:21 107:4,8,19 125:20 126:18 paper [io] 46:22 49:9,12 operating [4] 13:1,25 14:5 17:9 52:15 53:23 54:17 58:20 81:23 114:5,6 operations [9] 13:11,12 papers [7i 49:8 52:6,9 13:14,17,20 14:2 16:15 53:15 56:20,21 126:8 19:17 53:3 paragraph[in 43:5 46:3 opinion [S] 43:18,19 98:5 46:14 48:21 57:17,25 60:4 98:12 120:24 60:6 62:1 72:16 75:23 64:12,19 65:3 67:6 70:6 72:25 73:1,4 75:10 79:19 79:21 81:10,12,15 82:1,8 82:9,20 84:7 91:17 96:14 96:18 98:6,10,17,21 99:5 100:13,16 101:8,11 104:6 104:10,16,22,23 105:1,8 105:11,16 106:10,13,14 107:8,12 108:1,22,23 109:2,11 110:20 111:22 112:1,10,15 113:1,7,12 opinions [i] 108:1 parallel [2] 38:16 81:18 113:21 114:2 115:20,22 opportunity [si 9:4 76:12,25 104:7 105:19 parameters [l] 124:10 Pardon [i] 62:8 124:8,10,13,18 125:4,14 125:15,15 126:5 127:5 opposed [l] 89:5 parenthetical [ii 40:13 penalty [i] 131:11 optically [i] 6:19 Parliament [2] 55:4 83:5 pending [i] 2:20 option^] 73:15,21 74:1 part [12] 11:19 26:21 31:9 Pennsylvania [i] 3:18 options [3j 73:7,9 74:5 34:2 43:15 68:9 77:5,7 oral [4] 33:25 38:23 40:16 79:15 113:14 127:1 130:3 46:15 participant [i] 60:25 people [37] 9:5 11:19 16:1 17:10,11 22:20 24:13 44:1 49:6 52:16 53:19,24 56:14 59:11 62:25 63:3 order [3] 16:8 53:4 62:4 participate [i] 75:24 66:4 69:1,11 71:8,23 ordinary [i] 68:3 participated [2] 50:14 organic [3] 6:11,13 73:7 102:23 particular [2i] 6:4 7:21 organizations [6] 24:23 25:23 28:4,17 34:16,25 39:12 40:5 57:2 58:24 60:2,2 63:21 76:22 86:6 86:11 97:20 106:6 110:9 original [2] 28:23 104:15 117:25 118:1,3 119:4 originally [2] 34:18 35:1 122:14,17 74:17,19 75:3 77:6,9 80:10 81:23 93:1 100:2 101:16 104:18,18 111:15 126:12 130:1,19 pcr[2j 29:5 104:2 percent [i) 38:2 perceptions [i] 58:4 nods[i] 92:17 non[i) 24:3 objective [l] 22:23 obligations [i] 17:2 OSHA [4] 69:22 70:3 111:12,13 non-lcchnical[ij 59:13 occasion [2] 4:21-97:10 otherwise [2] 75:17 nonacutcpi 62:14 occasionally [i] 43:13 132:20 none [2] 40:23 51:11 occurred [2] 90:25 99:22 Ought [2] 74:11 80:23 particularly [3j 44:4 68:6 119:3 parties [2] 132:15,19 parts [i] 29:5 passage [2] 112:2 114:9 performed [2i 98:13 113:20 perhaps [i] 124:11 period [7i 31:24 45:19 56:7 66:13 105:9 106:12 107:5 nonflammable pi occurrence [i] 42:20 oursp] 67:25 passed [31 13:22 107:17 periodically [2] 83:9 124:13 October [3] 65:15 94:8 outcome [1] 132:20 111:20 84:1 nor[2] 132:15,19 94:10 outlining [i] 18:1 past [2] 49:18 54:13 pcijurynj 131:11 normal [i] 99:4 odd[i] 6:23 output [i] 15:14 patently [i] 51:20 persistence [S] 60:9 North [2] 3:12,13 off[4] 6:24 41:17,19 Outside [4] 39:15 47:12 pathologists [i] 98:14 61:8,24 107:9,10 Nos [ii 47:16 Notary [5j 2:18 4:4 131:18 132:6,23 note [21 60:5 79:22 notes [2] 74:23 113:12 nothing [8] 7:18 61:12 88:13 111:3,5 127:7,9 130:24 notice [2] 42:9 56:3 47:18 offer [l] 74:4 office [6] 21:16,22 47:10 47:14 67:19 122:1 officer pj 42:1 132:7 offices [4j 2:15 3:3 8:6 25:22 official [i] 19:16 Ohio [2] 34:19 35:2 76:8 130:15 outstanding [i] 5:10 overall [3j 17:13 52:1,6 overview [3i 50:5,15,17 Own [S] 2:4 21:19 51:20 81:17 88:12 Owners [ij 35:4 -P- pay [3] 25:20 93:6,9 PCB[44] 18:3 20:18 21:13,13,15 25:1 26:3,8 26:15 27:12,18 28:5,7,13 28:23 29:3 32:19 34:8,13 34:20 35:19 38:6 46:7 55:15 56:7,9 60:7 61:7,21 62:3,16 63:22 67:25 68:5 68:12 80:12 81:17,21 100:12 112:20 120:4 persistent in 61:14 person [7] 62:16 64:3,5 69:17,21 70:1 90:1 personal [2] 22:24 23:12 personally [i] 30:13 perspective [6j 1:9 32:22 33:8,18 73:19 123:25 petrochemical [2] 8:13 Nova [3j 1:14 65:10,15 oil [16] 8:17 19:12 25:11 November^! 2:13 42:5 62:5,6,7,8,8,18,19 63:2,2 63:7,9,13,13 now [23] 2:20 10:15,17 12:20 13:2 21:5 29:1 30:3 44:5 47:19 48:14,19 49:9 once [3] 12:21 25:25 56:15,23 89:15 52:13 70:5 71:12 87:17 one [47j 3:9,17 4:21 6:9 90:23 98:2 114:14 116:20 6:10 8:25 9:5 14:22 29:6 116:22 124:6 30:13 32:12 35:2 36:17 noxious [3] 110:6,7,7 37:7,14 41:1 42:12 43:2 46:4 49:22 51:23 53:19 number [3] 47:23 89:7,8 54:12 55:25 59:14 63:11 numbered [sj 33:9 46:4 63:25 64:4 68:5 72:10,25 47:21 48:1 78:10 73:21 75:2,11 76:15 80:1 numbers [2] 111:1 127:18 85:23 87:13,20 89:7,8 90:1 92:20 97:10 121:13 123:3 130:5 P[9] 3:1,1,3,12 12:1,9,13 12:20 13:3 package [4] 56:11,24 57:1,3 packages [4] 56:17,19 56:20,21 page [201 1:1 36:20 38:4 38:20 40:19 41:6 43:5 56:4 60:4 62:1 65:20 71:22 72:15,16 82:4,5,6,7 124:5 129:21 pages [31 79:6 125:25 127:16 pail [i] 123:11 123:24 124:9 126:6 11:18 PCBsimi 1:11 11:10 17:15,17,20,24 18:4,15 18:15,18,19,20,23,24 19:1 19:2,3 20:4,14,21 21:1,18 21:21 22:22 23:13,15,22 24:8,10,16 25:25 26:1 petrochemicals m 8:16 petroleum [2] 8:12 25:9 Ph.D [2] 5:25 6:22 Ph.D.ni 70:19 ' 29:25 30:2,23 31:3,3 pharmaceutical [i] 33:18 34:1,24 36:21,22 14:18 37:3,8,13 38:10,14,15,22 phasing [2] 38:9,11 39:22 40:22,23 42:11,16 42:17,21,24 43:11,12 44:6 Phil ill 129:2 44:24 46:15,22,25 47:5,9 Philadelphia [2] 3:18" 47:25 48:17 49:14 50:7 7:4 50:15,22 51:1,12,13 52A phone [9] 86:13 87:1 52:10,11 53:3 54:13,14 88:22 89:2,7,8,9 91:5 -o- ones [3] 24:25 38:13 paintS[3] 114:19 115:3,5 55:13 56:12 57:19 58:1,5 110:12 panel [IS] 26:3,5 27:12 60:3,14,19,23 61:3,13,14 phosphate [2] 102:19,21 . . Index Page-Si STLCOPCB4025605 Joan Macrtin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-Page TM phosphates - remained Witness: John H. Craddock phosphates [i] 102:23 practice [i] 11:21 75:15 80:17,22 82:4 84:8,19,20 recurring [i] 56:16 phrasing [i] 106:25 precise [i] 19:23 piece [i] 58:22 prcpared[2] 18:13 79:8 piecemeal [i] 73:20 present [4] 3:20 16:5 place [9] 3:17 42:19 35:8 52:15 48:18,19 93:3 95:14 96:16 presentation [2] 35:5 105:23 111:20 35:12 placed [i] 114:20 Plaintiff [2] 3:2 4:2 plaintiffs [4] 2:5,22 presentations [7] 33:25 34:1,13 35:7,13,14 39:15 presented [l] 33:11 22:19 96:12 preservative [i] 15:5 programs m 75:1 progression [i] 14:22 projects [i] 22:10 promising [i| 12:24 prompted [3] 42:7 81:2 81:5 promulgated [ij 13:23 proper[3] 73:18 75:8,16 properly pi 75:14 properties [2] 36:21 85:16,18 87:2 95:21 96:3 96:9 100:24 115:12,14 116:12,14,20,21,25 118:25 123:17,22,23 127:12 128:2 quick [2] 32:25 96:4 quite [3] 23:24 52:7,16 quote [i] 98:21 quoted [ij 65:20 quotes [i] 66:1 reduced [i] 132:13 refer [2] 17:7 122:6 reference [23] 36:22 46:21 48:21 49:12 50:1,5 55:24 56:1 62:17,18,23 63:12,15 72:18 73:5 75:23 79:24 94:6 105:20 109:24 112:6 113:25 114:1 references [ij 108:4 referred [7] 22:8 31:15 32:18 49:17,22 91:2 92:19 plant [5] 15:14 23:3,10 28:13 59:15 preservatives [2] 12:25 117:17 15:8 propose [4] 31:8,21,22 -R- referring [4] 32:11 70:3 73:5,6 plants [6] 14:7 16:20 17:11 21:15,19 25:12 plastic [4] 100:23 101:6 119:3,8 plasticizer [i3] 101:5,6 101:18 102:25 104:1 118:25 119:3,5,13,17 120:20,25 121:16 plasticizers [23] 99:4,9 99:14,16 100:21,22 101:3 president^] 71:7 72:13 92:23 press [S] 48:8,11 50:1 54:12 83:7 pressed [l] 25:7 pressure [i] 36:22 pretty [i] 69:4 prevent [i] 124:19 preventing [i] 124:17 31:25 R[IJ 3:1 refineries [2] 8:13 25:9 proposed [to] 30:6,11 racemization [i] 6:19 refining [2] 8:18 25:11 31:23 32:1 42:9,13 43:3 44:19 56:3 82:4 raised [2] 81:14 82:2 refresh [3] 90:24 128:11 ramifications [i] 77:10 128:18 proprietary [2j 122:25 123:3 provide [18] 23:19 24:14 30:18,22 35:25 39:21 57:4 59:12 60:1 68:6 79:8 84:7 84:8,17 87:3 88:14 92:3,8 ran[ij 8:23 range [i] 40:17 ranged [ij 34:21 rather [4] 60:9 61:8 63:13 126:15 refute [1] 20:22 regard [io] 24:16 29:19 74:5 75:19 77:21 98:5 99:4 112:10 113:21 123:24 101:4,8 102:20,22 117:7 117:11,14,17,20,23 118:7 118:22 119:7.9 121:6,7 plastics [i] 119:9 plastisol[6] 101:21 102:1 117:25 118:4 120:1 120:13 playcrm 37:15 playcrs[i] 66:19 previously [4] 43:25 65:3 77:12 129:17 primarily [is] 8:7,12 17:25 18:7 19:7,11 28:14 33:24 37:5 50:17 59:5,11 74:2 105:3 106:15 primary [2] 15:4 21:11 principals [i] 40:12 principles [i] 7:6 provided [10] 28:20 37:6 Raynj 74:12 50:13,16 60:25 76:19 reaction [i ] 120:5 92:14,15 102:24 103:12 reactions [ij 42:19 providing [i] 128:23 read [22] 16:19 41:1 44:2 provisions [i] 17:20 49:17,19 51:2,4,5,7 65:16 PTAs[i] 34:22 80:5 87:22 90:23 108:14 public [IS] 2:19 4:4 21:20 39:1 45:17,20 55:6,16 108:15,20 114:2 119:2 127:2,4 128:3 131:4 59:6 63:19 78:22 116:7 readable [2] 50:24 59:12 regards [4] 106:10 107:19 110:9 111:5 Register [i] 56:5 registered [S] 2:18 4:5 28:19 30:8 132:5 regs[i] 28:13 regularly [i] 16:12 regulated [2] 15:9 28:14 regulating [i] 14:17 pluS[i] 119:8 private [i] 74:16 131:18 132:6,23 readily [2j 36:25 124:15 regulation [2] 28:24 point [14] 13:8,21 21:13 problem [20] 67:18,25 published [19] 33:21 reading [2] 17:25 65:24 42:14 25:2 31:22 32:9 45:24 53:3 54:8 56:12 61:20 62:16 68:22 88:23 points [i] 86:15 policy [9] 58:18 76:19 68:5 70:5,7,12 73:12,14 73:22 76:23 80:12 81:1,6 102:5 104:23,24 121:9 124:9 126:6 129:6 problems [4] 80:17 39:8 46:24 50:6 51:19,22 51:25 56:4 60:13,15 61:4 62:13 65:2 72:25 76:20 110:4 111:1,13 114:3 purchased [ij 105:15 ready [i] 16:17 regulations [3i] 13:25 real[i] 96:5 really [7] 7:18 29:17 52:7 70:11 73:11 106:4 118:24 14:5 16:19,21 17:19 18:1 18:3,11,24 21:16 24:3 26:8 28:1,24 29:3,19,24 30:1,6,10 31:9,22 32:1,5 76:23 77:2,3,5 91:25 92:2 82:21,22 125:19 106:10 procedure [i] 105:23 political [i] 81:19 proceed [i] 88:2 polychlorinated [S] 7:1 process [i] 15:10 9:16 33:8 58:13,25 processes [3] 8:13 26:6 polymers [4j 11:9,11,25 42:23 25:12 procuring [ij 25:11 purchasing^] 121:25 reason [4] 5:15 80:24 103:12 130:18 pure [i ] 109:25 receive [2] 47:3 83:10 purposes [i] 103:22 received [3] 53:23 58:19 put [23] 11:20 51:9 52:9 89:21 52:17 56:17,24 58:20 59:3 59:5 60:23 73:18 74:9 receiving [2] 6:22 94:3 79:10,17 80:8,13 82:23 recent [2] 73:3 87:20 38:16,17 81:17,19,21 98:25 111:16 regulatory [i2j 14:13,21 14:22,23 16:2 21:19 28:21 41:8 52:3 60:24 72:9 104:17 relate [4] 6:25 7:2,12 90:9 populace [i] 41:9 portfolio [i] 15:6 produccd[6] 2:12 4:10 37:3,8 79:23 127:17 position [19] 9:8,21 10:8 producer^] 37:13 10:22 12:10 13:6 16:17 producing [i] 8:16 18:22 19:25 20:5 21:1,4 22:15 29:18,21 72:7 93:12 93:13,18 product [is] 12:21,22,23 13:1 20:2,25 21:8 34:9 106:3,6 109:20 123:7 positions [1] 116:6 125:9 126:9,9 possible^] 57:5 79:9 production [i] 16:24 Possibly [i] 63:5 products [2i] 11:15,18 potassium [i] 15:7 13:2 58:18 64:1 66:2,18 Potter [6] 92:21 93:5 94:13,18,23 95:1 pounds [21 37:2,23 power [6] 19:11,14 27:6 35:23 104:20 105:4 PR[i] 80:13 66:22,23,25 67:2 99:18 114:8,15 119:13 121:1,16 121:18 122:8 123:4 125:16 Professional [3] 2:18 4:5 132:6 profile [ij 73:13 83:1 101:21 111:20 118:4 119:22 125:9 putting[2] 50:IS 126:17 -Qqualificd[i] 66:4 recess [4] 33:2 67:4 96:6 related [13] 7:8 14:3 103:14 17:20,24 20:13 21:21 recognize [ij 42:17 29:25 30:1 47:5,11 58:25 74:25 132:15 recollection [ii] 39:6 73:8,11 74:24 77:25 89:10 relates [2] 40:4 91:20 89:17 90:24 114:11 relating [] 21:18 43:10 128:11,18 47:9 50:7 95:14 111:3 quality [i] 60:22 quantitatively [ij recommendation [ij 24:10 relations [6] 45:18,21 55:17 59:6 63:19'78:23 124:22 quantities [l] 75:10 recommendations [i] relationship [4] 52:10 75:19 98:6.10 108:1 quantity [i] 123:9 recommended [i] 120:8 relative [ii 132:17 quarterly [2] 16:3,7 recommending [i] release [io] 1:11 47:22 ,, QUESTIONERS [ij 1:1 52:24 record [18] 4:17 16:22 50:2,2 67:10 128:9,12,19 128:22 129:4 questions [43] 1:24:15 4:24 21:13,17,20 47:11 53:9 55:18,19 56:23 73:16 18:10 33:3,6 41:24 45:10*' remain [8] 9:12 10:4,12 47:18,19 54:22 57:9 58:11 11:3 12:4 19:22 20:5 64:11 67:5 78:8 79:22 107:12 practical [i] 42:25 program[3] 65:15 75:13 74:20 79:10,25 80:10,14 103:9 119:22 remained [i] 20:7 Index Page 9 STLCOPCB4025606 Joan Macrtin v Armstrong World Ind. Cause No.: L-95-CV02848(JBS) Multi-Page TM remains - spoke Witness: John H. Craddock remains [i] 41:14 resolution [i] 104:24 44:19 52:4 56:6,10 send [2] 57:1,1 site [3] 20:19 23:3 100:10 remand [i] 28:24 resolved [i] 31:19 run [2] 28:12 43:20 sending [i] 43:21 sites [i] 20:13 remediation [2] 94:14 resources [5] 22:3,5 95:24 36:18 49:4 53:5 sends [i] 122:1 sitting [i] 120:24 -s- Scngerpj 72:12 78:25 situation [2] 73:25 130:3 remember [i6] 19:18 respect [5] 23:17 30:5,10 29:1 49:7 62:17,22 64:22 124:8 126:5 64:24 65:5 67:13 68:20 respected [l] 74.15 69:11 70:10 74:1,21 83:21 87:18 88:21 89:21 91:7 91:11 92:13,14,15 93:2 respond [S] 55:19 84:19 55:7,14,15 94:3,5 95:18 100:24 responded [3] 64:5 76:1 103:15 113:11 129:5 94:21,23,24 130:1,7,13,16,17 response [] 26:8 56:25 - [1] 3:1 79:3 situations [i] 124:18 S-C-H-O-F-l-E-L-D [1] 45:12 senior Pi 9:22 10:4,23 11:3 117:9 six [3] 2:14 10:17 34:14 sketch [l] 5:21 1-E-N-G-E-R [i] 72:12 sense [2] 38:22 39:18 skin [4] 109:11,16,17,20 safety [4] 20:3,25 21:9 sent [4] 59:24 43:25 50:10 59:15 slight [i] 44:6 34:10 sakep] 45:2 sentence p] 40:13,19 55:5 82:19 94:7 slightly [i] 38:22 slowly [3] 45:6 61:21 reminder [l] 50:23 65:2 74:18 83:2,3 94:22 salaryp] 10:24 12:8 separate [2] 34:8 51:24 107:13 renderp] 131:7 reoccurs [i] 103:17 repeat [2] 5:4 106:24 95:3 responsibilities [S] salc[i] 25:7 separately [2] 31:13 sales [S] 61:22 92:8 128:9 32:17 small [4] 18:9 42:20 75:10 123:8 15:1 21:1,2 34:2 43:2 128:13,19 September p] 57:9 94:4 smaller [i] 125:11 responsibility p] 14:17 salesman [3] 121:24 95:13,24 112:11 SMITH [i] 3:11 rephrase [3] 5:4 107:1 118:6 replacements [i] 124:15 report [i2] 61:4,5,13 15:5 17:6 20:3 21:12 58:3 68:9,11 responsible m 11 :l 17:10,11 23:1 34:8 77:17 88:18 122:10,21 salcsmenp] 122:16 salesperson [i] 122:20 salespersons [i] 122:14 sequence [l] 20:24 scries [i] 4:24 serious [2] 82:20 107:2 services P] 22:6 65:14 so-called [2] 97:4 125:24 Society [1] 7:15 sold [3] 102:22 106:3 111:22 71:10 90:7,20 114:1,3 restricted [i] 19:3 121:20,22,23 122:1 results [l] 53:14 Report/J.Craddock [2j retained [4] 23:19 24:14 1:13 64:8 24:17 50:21 reported [i] 72:14 retardancy [l] 103:18 rcportcr[7j 2:18 4:5 5:12 45:2 87:21 132:1,6 retired pj 20:6,7 27:11 salt [12] 40:14,15,16 46:16 46:21 47:1 57:21 62:18 62:23 63:1,13 82:13 set [6] 98:1 19:3 26:4,5,6 32:6 sample [3] 79:25 80:14 SCtS[i] 81:17 123:6 setting ii] 18:9 samples pi 75:4,13 settled [i] 31:18 sampling [2j 75:5,14 settlement [i] 31:10 Solid [l] 26:14 someone pi 24:11 62:10 sometime [i] 12:12 sometimes [4] 22:1 25:18 122:6,24 somewhere pi 12:16 13:13 39:5 71:10 103:14 reporting [i] 16:22 reports [5] 37:14 108:14 122:2,4,5 represent [2] 96:11 127:16 representations [i] 58:23 representative [2] 97:6 97:11 representatives [3] 28:5 32:12 76:13 Reputation [i] 22:17 request [4] 56:15,16 94:21 95:7 retiring [i] 38:1 review [9] 50:21 52:6 57:11 105:19 108:7,13,16 108:19 112:9 reviewed [i2] 39:7,12 39:14,16,18,19 46:23 51:23 53:15 73:3 97:13 108:3 reviewer^] 108:16 reviewing [i] 18:11 reviews [i] 43:9 revisit [i] 31:20 revolves [i] 24:9 right [2i] 2:4 8:21 31:17 saving [i] 124:17 saw [4] 46:18 56:1 67:9 114:5 says [7] 33:17 40:14 55:5 65:25 74:7 82:5 124:21 Schofield [i] 45:11 school [4] 5:24 7:4 56:19 111:9 science [4] 56:19,21 72:20,22 scientific[7] 29:4 4l:ll 43:9 53:23 55:18 58:2 108:16 scientist [i] 53:17 several pj 19:7 29:8 43:11 49:8 50:6 88:24 91:6 124:18 sorbatesp] 15:8 sorry pi 6:21 65:23 79:2 shares [i] 20:15 sort [7] 7:10 26:10 51:19 Shccrman [4] 54:23 55:3 72:8 73:14 82:2 95:23 55:8,9 sorts [5] 20:12 26:14 27:7 sheet [i] 74:9 30:20 51:22 shells [i] 61:18 SOul[i] 124:9 short [3] 38:21 64:18 sound [l] 87:7 115:14 source [4] 58:2 60:10 shortly [ii 68:17 show [3] 43:12 124:3 129:17 81:12 93:10 sources [i] 100:12 speak p] 45:6 89:18 showed [6] 41:4 44:10 speaking [i] 89:10 requested [4] 16:5,6 35:14 116:10 requests [1] 56:13 require [3] 15:17 38:6 80:18 required [7] 15:19 16:20 18:4,16,17 22:6 31:20 32:14 33:22 66:25 71:1,5 71:12 78:4,20 83:8 96:24 99:7 104:3 105:13 108:6 115:23 116:20,22 121:19 SC[i] 104:2 searching [i] 124:9 Scattlep] 35:5 risk [13] 58:4 74:13 124:6 second [10] 14:24 48:21 124:7,22,22,23 125:4,24 57:17 60:4 65:22 69:4 126:5,10,15,19 72:15 79:15 89:3 94:6 risks [2] 125:17 126:17 secretaries [l] 22:1 44:12 51:13 79:9 83:4 shown [4] 61:15 65:13 97:14,17 shut[i] 104:19 side [2] 29:14 124:11 sides [l] 29:17 signature [2] 4:6 128:4 special [i] 80:19 specialist [3] 9:11,13,22 specialization [3] 6:4 63:22,25 specific [is] 7:8 18:14 21:2 56:22 59:25 75:18 77:24 80:4 84:4 100:1,6 100:17,24 101:5 120:14 requirement [2] 39:17 85:25 Robert [2] 45:11 78:9 Rocky [l] 93:2 secretary [i] 56:25 section [4] 40:4 55:22 signed [3] 41:17,19,24 specifically [is] 17:20 significance[i] 63:12 17:23 29:24 30:9 43:24 requirements [3] 16:22 18:2,13 reread [i] 113:15 research [22] 9:10,10,12 9:18,20,22,22 10:1,4,9,12 10:19 11:4,14,19,23 25:3 99:3 117:1,6,9 130:10 researcher [2] 117:14 121:25 reselling [i] 15:7 reserved [i] 4:7 resin [i] 120:4 rolc[i] 32:6 room [i] 71:8 roughly [8] 11:4 12:9,12 12:15 17:18 27:14 46:15 72:15 round [i] 19:21 Roush [<] 36:12 40:2,25 41:16 rule [121 42:9,10,11,16 43:3 44:21,22 56:3,6,8,8 91:23 rules [7] 13:22 31:21,23 82:17 125:25 SCC [U] 12:11 21:14 52:1 55:11 56:6 65:5 75:21 94:24 103:20 107:1 125:18 seek [2] 36:7 88:6 select [i] 123:3 sell [3] 12:21,22 15:13 selling [3] 13:2 105:1 123:13 seminar [i] 7:21 semiretired [2] 20:8,9 significant [2] 40:22 106:17 silo [l] 114:18 silos [3] 114:20,20,23 115:2,3 similar [3] 40:14 62:5 125:4 simple p] 7:14 54:1 103:6 simplify [i] 56:23 single [2J 46:4 82:19 sit p] 52:17 79:12 119:11 77:20 82:17 83:20 91:11 91:19,21 92:12 94:5 107:23 112:6 ' specifics [4] 74:21 76:16 76:22 78:3 spcctcrp] 81:14 speculate [l] 5:1 speculation [i] 122:9 speech [i] 35:2 speeches [i] 33:25 Spirits [3] 2:8,24 115:16 spoke fi] 69:18 Index Page f0- STLCOPCB4025607 Joan Macrtin v Armstrong World Ind. , .Cftuse No.: L-95-CV02848(JBS) Multi-Page TM spoken - Unger Witness: John H. Craddock spoken [2] 89:14,15 24:1 60:2,3 76:9 62:25 63:13 82:12 tiles [28] 91:18 96:15 transmission [4] 19:14 spot[i] 59:17 SS[i] 132:3 St [6] 2:16 45:21,25 46:2 59:18 132:4 subjects [2] 7:13 22:8 submission [i] 16:23 submissions [3] 15:17 15:21,21 tailor [i] 81:20 taking [6] 29:17 42:19 46:24 48:18 95:14 128:10 talks [i] 57:19 100:4,8,12,14,17 101:9 101:14,15,17,22 103:1 104:2 117:21 118:1,4,10 118:23 119:15,19 120:11 120:17 121:3.7,8 126:18 27:6 35:23 105:4 transmitted [ij 79:20 trial [2] 5:16 23:6 trip Lij 71:10 Staff [4) 13:17 21:25 submit [i] 22:20 task [3] 60:14,24 61:3 127:6 true [4] 38:8 117:9 131:7 63:18 70:17 submitting [t] 15:19 Taylorm 2:15 times [8] 27:25 69:2,10 131:12 standard [3] 39:10 40:18 subpoenaed [i] 97:23 technical [3] 30:17,18 86:25 92:19 97:1 98:1 try [7] 16:19 26:6 30:21 58:22 subscribe [i] 131:10 43:9 99:16 104:5 123:5 73:18 84:18,19 85:18 standards [9] 26:7 75:8 75:16 111:10,12,14,18,18 111:19 subsequent [3] 89:13 90:9 91:1 technically [i] 124:14 title [io] 9:23 12:7 19:16 trying [9] 12:21,22 22:25 Technologists [i] 25:14 19:18,23 20:1 33:17 72:8 92:22 104:1 32:4 42:15 51:19 93:10 98:1 101:14 Stapled [i] 79:22 Start [i] 25:3 started [ii 16:16 startling [i] 52:8 subsequently [i] 54:3 technology [4] 11:23 substance [8] 29:2 42:13 12:2,19 25:16 67:23 82:23 83:1 120:9 telephone [2] 90:7,19 120:16 131:6 Telephonically [ij Substances [2] 13:21 3:20 TM [l] 71:23 TSCA[28] 14:3,11,18 today [22] 4:19 5:11 19:5 27:16 37:23 38:8,15 41:15 42:2 46:12 48:5 54:25 57:12 58.15 64:14 78:13 17:7,8,10,12 18:3,11,13 18:15,17,21,23,24 19:20 21:16 26:8 29:20 34:24 92:3 98:24 111:20,22 State [ii] 2:19 4:17 5:23 14:3 telling [2] 86:20 87:17 83:4 90:21 97:14,15 112:2 114:10,12,13 49:1,4 81:20,23 131:1 substantive [I) 35:25 132:2,7,23 successor[i] 70:23 State's [i] 81:21 such 18] 53:25 72:24 statement [is] 37:20 126:9,9,18 128:16 131:5 38:20,23 43:8 46:3,9,11 131:9 46:14,18 57:23 60:11 62:2 66:12,20 120:6 suggest [2] 44:15 74:10 statements [2] 40:7 suggested [l] 74:12 81:25 suggesting [i] 103:25 States [*] 2:1,20 37:1,13 suggestion [3] 128:7,16 57:25 82:9 124:7 128:21 128:17 statistical [2] 42:20 75:14 suggestions [2] 119:22 119:23 Still [17] 13:7,16 17:15 suggests [l] 94:13 27:16 33:4 37:17,23 38:3 suitable [i] 124:15 38:5,7,13,14,15,18,19 43:18 46:11 stint [l] 21:3 STIPULATED [i] 4:1 Stop [5] 61:22 104:9,16 105:1,10 Stopped [l] 106:12 Suite [2] 3:4,12 suited [l] 121:2 summaries [i] 50:8 summarizing [2] 71:19 73:1 summary [4] 55:25 60:14 128:9 129:18 StOFC[i] 18:15 summcr[2j 13:23 97:22 stored [i ] 18:20 superpj 20:13 ten [3] 27:25 70:23 97:25 Tennessee [ij S:25 tenure (i i 125:16 term [3] 38:21 110:7 112:23 terms [i] 121:23 test [2] 43:10 62:3 testified 16] 4:11 21:8 86:17,25 99:20 116:8 119:11 120:25 Turct[45] 1:3,4 3:17 4:15 together [i8] 26:11 31:14 32:4 50:15 52:9,18 56:17 56:24 58:20 59:4,5 60:23 74:9 79:10,18,23 80:8,14 Tom [S] 70:4 71:23 72:2 92:25,25 toO[i] 27:8 32:20,25 33:3 45:6 51:4 54:6 65:23,25 67:5 68:25 78:1 79:2 86:8,14 87:5,9 90:14 93:20 96:2 97:14 103:2,4,8 106:20 107:7 110:23 116:15,21,25 118:13 119:21 120:5,15 123:16 125:6 126:24 took [7] 12:2 52:8 63:8 127:19.22 128:7,15 90:2 93:3 108:12 125:12 130:24 testifying [ij 5:18 top [4] 53:19 57:14 82:5 turn [3] 48:4 115:8 124:5 testimony [6] 5:11 59:21 92:25 twice [l] 56:16 98:19 120:8 132:9,11 total [3] 25:1 37:8 40:19 two [ill 3:22 10:6,16 testing [9] 7:6 15:19 totally [3j 29:7 44:7 37:14 42:12 51:25 56:6 38:25 39:1,2 75:1,13,19 104:16 69:24 72:10 124:12 125:18 toward [ij 98:24 127:15 tests [l] 108:12 town [2J 34:21 126:14 type [5] 28:1 100:22 Texas [ii 25:10 toxic [8] 13:21 14:3 38:22 101:11 105:23 125:4 tcxt[i] 40:18 46:17 57:18,20,22 109:24 types [6] 8:9 14:25 20:10 textbook [i] 99:13 Thank [21 116:12 127:10 theoretical [i] 111:14 thereafter^] 4:5 68:18 toxicities [l] 63:6 toxicitypj 38:21 46:15 62:5,13,14 64:18 72:24 toxicological [2] 7:6 34:16 72:21 125:19 typewriting [2] 4:6 132:13 typographical [ij 40:8 132:13 24:5 storeroom [ij 81:13 supervisor[i] 72:6 thereon [ij 131:9 toxicologist [2] 24:11 -V~- straight forward [i] 74:2i, Strcojtijl 3:12 stress (iJ 28:1 strictly |V) 30:1 61:23 102:8 120:7 Stringent ]:) 111:14 supplied [2] 103:6 116:1 support [2j 41:11 54:17 supporting [i] 29:22 supposed [i] 56:9 surprised [2] 52:16 53:11 surprising [i] 52:14 thereto [i] 132:19 thinks [i] 122:10 third [2] 43:5 60:5 third-party [i] 96:23 thought [io] 21:10 53:22 53:22 62:23 79:14 81:9 81:24 101:10 130:4,21 74:14 U.S[8J 14:7,16 16:10 37:6 toxicologists [l] 98:14 37:10 38:17 47:12 52:2 toxicology [3j 7:3 36:12 ultimate [$] 107:20 36:14 114:8,15,16,17 toxins [3] 41:10 43:12 82:12 ultimately [3] 11:21 26:9 31:6,19 32:2 trace [1] 42:21 unbiased [l] 22:17 Studies pi]] 40:23 41:1,4 49:5,(g,l 8 $ |: 12,18,21,24 53:13 &;9,]6 62:3,13,14 98:13 l(Ufc?:3,4,7.15,19 surveys [i] 30:22 suspected [1] 101:25 switches [i] 19:13 three [$] 21:3,10 27:19 69:1 72:10,18 79:6 86:25 126:15 traced m 100:12 tracked [i] 37:25 trade [8] 8:24 24:22 25:5 under [9] 16:20 17:21 18:6,14 21:16 37:1 52:22 131:11 132:13 108:2(1 l09:! 112:5,10 113:14, |5,j9 sworn [3] 2:12 4:10 132:11 Study jU) l'8:21 51:1,17 symposium [l] 48:18 52:21.53,24 53:15 54:3 54:16 6(^1^,16,16 108:18 system [2] 32:5 123:12 112:6 systems [3] 8:16 18:10 Stuff [61 11:20 71:11 75:9 19:12 91:10 108:18 119:10 subchronic [l] 62:2 -T- subgroup [i] 26:21 tablcpi] 40:14,16 46:16 subject [7] 6:18 10:1,19 46:21,25 57:21 62:17,23 through [17] 12:23 28:5 25:17 26:10,24 27:3 34:23 undergraduate [ij 5:22 33:10 39:11 43:8 47:13 training 14] 70:17 77:6.7 understand [i7]'5:2,11 47:14,22 48:2 63:5 78:11 77:17 5:15 16:19 23:24 31:4 92:4 95:19 104:4 118:8 123:8 128:3 throughout [3] 27:12,15 37:8 thumbnail [ij 5:20 transcribed [i] 4:6 transcript [6] 1:14 5:13 5:17 50:24 65:10,15 transfer [ij 11:22 62:25 63:1 78:15 81:7 85:7 89:1 92:9 93:12,13 96:21 121:13 understandable [l] 62:24 - tiesp] 88:11 transferred [i] 11:21 ` understood [2] 5:5 tile [5] 101:12 119:5 120:3 transformers [6] 19:10 121:12 120:4,10 19:11,12 27:6 37:17 unfairp] 119:24 120:10 106:15 | Unger [6] 83:21 89:25 Index Page 11 STLCOPCB4025608 Joan Macrtin v Armstrong World Ind. Multi-PageTM Cause No.: L-95-CV02848(JBS) __________ ' 90:3 94:13 129:2 130:6 vice [2] 71:7 72:13 workplace (ii 96:14 uniform (i] 26:6 uniformly(t] 21:1S Union [i] 28:9 view [6] 41:12,14,15 44:5 world [] 2:6,23 3:15 44:9 118:6 37:9 46:8 77:9 96:13,21 Virginia [2] 23:10,10 worry [i] 65:17 unitm 13:1 visibility [i] 80:20 United Pi 2:1,20 37:13 visit [ij 71:20 write [31 42:8 56:25 79:14 writes [l] 121:25 units [2] 17:9 122:16 university [3] 5:23,24 49:3 ' unless [i] 95:9 unquote [1] 98:21 unrivaled [i] 58:1 volatilize [i] 36:24 volumes [1] 16:24 VP [i] 69:6 vs [2] 2:5,7 -w- writings 48:16 52:4 56:19,21 written [18] 5:13 15:21 33:18 34:18 35:2 41:3 42:15 43:15,18 49:8 55:9 59:20,21 65:4,2 77:3 111-12 129:19' up [24] 10:15,17 13:4,24 Wagner[3] 127:15 129:6 wrong [ij 106:24 18:9 19:3 23:2 26:5,6 54:8 129:10 wrote [101 41:2 42:4 81:8,9 85:8,12 93:7,15 98:1 100:9 107:14,15 120:16 123:15 125:23 Wait[i] 12:11 walkp] 126:15 43:14,17,20 44:21 48:7 55:2 64:20 71:19 126:4 up-to-date [2] 39:24 walk-through [i] 75:25 warning [ij 110:3 -Y- 83:22 Warren [i] 28:25 Yca [i] 121:21 update [2] 54:18 90:3 Washington [4] ycar![S] 9:14 10:6,16 21:3 updates [2j 54:2,7 30:5,8 35:5 1 ' >1001:1 V ' ' usage [2] 20:15 91:17 USDA [2j 15:9 60:20 U8Cd|34] 15:10 18:6 19:4 19:5 33:24 38:15 59:14 62:22 63:4,23 75:7,7,9,16 99:14 100:13,14,16 101:11,17 102:25 103:13 Waste pi 26:}4 WATKll^J* [ij 8 ways [2j` js:')3 69:$j weck|3j 7:5 54:13 97;^5 weeks [ij 34:15 " weighed [ij 125:17 years [is] 10:13,16,17 >!jb,'H,24 27:20.21 37:?5 49:10 51:8 54:14 56:970:^3 96:17 yellow rn (3:10 York m' 8:6 9:2.3 20:17 22:16 23:4,$.7 103:25 110:7 115:3,5 118:1 119:5,9 121:6,8,18 122:12 123:10 user[3] 107:20 114:16,17 well-known [ij 74:14 young [l] 68:21 West [21 23:10,10- yoursclfni 21:23 97:13 Wcstinghousc [2j 35:20 98:9,16 35:21 users [2] 114:8,15 whatnot [4] 15:20 38:2 uses [27] 12:23 15:16 19:2 83:5 111:2 19:6,7 36:21 101:13 104:11 105:2,3,8,12,16 106:13,14 107:3,4,4,9,19 112:2 121:15 122:6,22 125:21,21 126:18 wherein [i] 2:22 wherever [i 1 58:5 whole [4] 11:16 32:6 124:9 126:6 usings 122:8,10 123:8 William [1] 47:25 124:13 WILSON [i] 3:21 Usually [i] 27:24 withdrawal 60:7 61:7 USWA [6] 26:13,21,21 83:10 95:11 29:11 31:6 32:12 within [19] 2:19 6:5 9:24 utiliu. 26:25 38:1 utility 26:14 125:5 Utiliaidui 103:22 124.19 utilising |i] 125:4 10:10 11:10 13:15,25 17:1 17:2 21:13 25:22 26:7 29:20 53:5 56:13 59:3 67:14 101:25 131:6 without [51 28:13 76:2 76:24 91:24 120:12 Vanderbilt [l] 5:24 vapor hi 3/>:22 varied [4| 27:24 34:14 35:1$ variety 111 20:23 various, 18] 21:25 33:25 56:22 72:24 74:25 81:25 105:21 116:6 Verbally [i] 103:12 vcrsus[3j 106:19 107:4 126:19 witness [is] 4:7 20:16 22:16 45:3 76:6 92:17 97:5,8 119:24 120:12 130:25 132:9,11 WJfij 72:5 woman [3] 68:21 69:5,12 wondering [I] 73:12 word [6] 6:9,10 24:2 65:17,17 87:13 words [21 97:6 106:3 workable [i] 32:5 worked [io] 8:5 31:7,11 31:12 49:2,3 70:13,15 117:6,10 uniform - yourself ( Witness: John H, Qradddfik Index Page 12 STLCOPCB4025609