Document J3nypq74BBJMkBXvKx41GZDr

SQUARE D COMPANY Dedicated to Growth Committed to Quality INTERNAL MEMO DATE TO FROM SUBJECT January 22, 1991 Jim Dutton - Lexington Rich Niccolls - Cedar Rapids Asbestos Reinforced Molding Compounds C: John Schultz - Lex. Ron Farrington - RD Ted Kendall - EPC Jim: I have bad news and seme suggestions. First, it would be a monumental task to document products with asbestos containing molded parts. All records are on microfiche which would have to be reviewed manually. However, I think I can offer seme suggestions: 1. Infrared analysis techniques are sensitive enough to identify asbestos in parts. Only milligrams of material are necessary for the analysis. Our Raleigh plant, Aaron Underwood, can do the analysis on specific parts if needed. 2. If you have a date code for a product, the microfiche records of old bills of materials would be easier to search. 3. If documentation is needed frem the microfiche records, you should contact Ted Kendall at Cedar Rapids. He has the responsibility for all DEBU records. 4. There is precious little documentation on when we were asbestos free in our molding compounds. I am sending a lab procedure for Cedar Rapids that has seme guidelines for return materials. The Missouri plant reports the elimination program was completed in 1985. Cedar Rapids beat them a few years. Lincoln is still checking as I write. 5. I am sending a copy of a molding compound record from 1976. Asbestos containing ccmpounds were still listed at that time. I highlighted those compounds I suspected had asbestos reinforcement. This may be useful because the corporate rawstock numbers would be used in any search of bills of material. 6. I talked with Harold Stanfield, Corporate Standards, at the Milwaukee Richards Street plant. He has the records dealing with corporate rawstock numbers. There may be traceability. Each plant would request numbers from Harold for materials they used. Given a number, he can trace its history. This also would be a manual process. The group may be moving soon if and when the plant closes there. 7. I attached addresses and phone numbers for various compound suppliers which may be viseful. Our vendors may have past records of formulations, delivery and conversion dates. They would be able to provide details on type and concentration of asbestos in their products. I didn't contact them about this. SC-SDC-4200 SQDDNC 000001 SQUARE COMPANY PAGE 2 8. At the height of the asbestos effort, there were requests from customers for certification of asbestos free products. I believe this was handled through our Marketing group. They may still have records on asbestos free product dates. I wasn't able to find out who would have the information or certifications. I include the comment as a potential lead about cut-off dates for the various products. 9. Any documentation retrieval or review effort must be discussed with Ted Kendall. I am not in a position to help you with that. I hope this information is useful to you. I don't see any way to retrieve product information without a date code in any reasonable time or cost. Good Luck. an compds.m Rich Niccolls SQDDNC 000002 Anthony L. Springfield (816) 360-4291 aspringfield@po!sinel!i .com Twelve Wyandotte Plaza 120 W. 12th Street Kansas City, MO 64105 (816)421-3355 Fax: (816)374-0509 www.polsinelli.com May 22, 2012 Nicholas J. Angelides, Esq. Simmons Browder Gianaris Angelides & Barnerd LLC One Court Street Alton, IL 62002 Re: Roy Duncan and Mary Duncan, His Wife v. A. Shulman Inc., et. al. Case No. 1122-CC09254 Dear Nick: Pursuant to our agreement regarding Discovery Requests in this matter, enclosed you will find a CD-Rom containing Square D's document production in the above-referenced matter. These documents are labeled SQDDNC_000001 - SQDDNC_000473. If you have any questions or concerns, please do not hesitate to give me a call to discuss. ALS/tlh Enclosures Anthony L. Springfield Chicago | Dallas j Danver | Edwardsville | Jefferson City j Kansas City | Los Angeles f New York Overland Park [ Phoenix | St. Joseph j SI. Louis | Springfield | Topeka | Washington, DC | Wilmington In California, Polsinelli Shnghart LLP. 028811/059839-2224089.1