Document K65QVdbVEjYOmEV6pMX9jybX2

deposition routing record IT!DISCOVERY HUE COPY CERTIFIED copy / SUPERIOR COURT OF THE. STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES / JEAN C. BRADLEY, Plaintiff, vs, JOHNS-MANVILLE CORPORATION, e t a 1., Defendants. ) ) ) ) ) ) ) ) ) ) ) NO. C 362 335 RECEIVED OCT 17 TO greene, cramur DROILLET at. A) DEPOSITION OF DAVID H. GARABRANT, M.D., a witness herein, taken by defendants, at 10:20 a.m., on Tuesday, October 7, 1986, at 1420 San Pablo, Suite B-308, Los Angeles, California, before Lucia Moskal, CSR, a Notary Public. LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS REPORTED BY: Lucia Moskal, CSR 1222 Registered Professional Reporter OFFICE NO.: A-6739 210 NORTH CENTRAL AVENUE SUITE 101 GLENDALE. CALIFORNIA 91203 818 247-0920 LUCIA MOSKAL CERTIFIED SHORThanO REPORTERS APPEARANCES OF COUNSEL: For Plaintiff: GLICKMAN & GLICKMAN BY: DAVID R. GLICKMAN, ESQ. For Wellington Defendants: . BOGAN & JONES BY: MARY K. JONES, ATTORNEY AT LAW For Defendant and Cross-Complainant Hill Brothers Chemical: WASSERMAN, COMDEN & CASSELMAN BY: DAVID B. CASSELMAN, ESQ. and KEVIN H. PARK, ESQ. LUCIA MOSKA1 CERTIFIED SHORTHAND REPORTERS October 8, 1986 David R. Glickman, Esq. Glickman & Glickman 9465 Wilshire Boulevard Suite 525 Beverly Hills, CA 90212 ' Re: Deposition of David H. Garabrant, Bradley v. Johns-Manville, et al. M.D. : RECEIVED OCT 17 1986 GREENE, O'REILLY t broiuet*t.a.i L Dear Mr. Glickman: . Per your request, the following are the questions arid answers that you wished to be listed separately: Page 94, line 12, through page 95, line 2: . "Q. BY MS. JONES: Doctor, are you able to say to a high degree of medical certainty that . Mr. Bradley's cancer of the colon was caused by his exposure to asbestos? A. Based on the studies, that I have cited, including both human evidence and animal evidence, it is my opinion that asbestos increased Mr. Bradley's risk, and that if he had not had exposure to asbestos, he would not have contracted colon cancer at the age he did. Q. And it's your opinion that, to a medical certainty, that the latency period, that is, the time between the first exposure in 1968 and development of 210 NORTH CENTRAL AVENUE SUITE 101 GLENDALE. CALIFORNIA91203 * SIS 247-0920 Page 2 October 8# 1986 "symptoms in 1977, is sufficient for the development of Mr. Bradley's colon cancer? A. As we have discussed, I think there is no information in the literature upon which to base that sort of opinion. My opinion is based on analogy to lung cancer in relation to asbestos, which says that is adequate latency, and the relationship between other carcinogens and human cancer which says that 10 years is adequate latency." There will be no charge for furnishing you with this information. Certified Shorthand Reporters LM:pS LUCIA MOSKAL CERTFCD SHORTHAND REPORTERS 2 INDEX 3 4 WITNESS: DAVID H. GARABRANT, M.D. 5 EXAMINATION BY; 6 Ms. Jones: 7 8 9 ._ . 10 , 11 ' 12 13 EXHIBITS 14 DEFENDANTS' 15 A Curriculum Vitae (9 pages) 16 . 17 18 19 . 20 21 22 , 23 24 25 26 27 28 3 PAGE 4 PAGE 8 LUCIA MOSKAL Scherotritfhieadnd REPORTERS 4 1 2 - DAVID H. GARABRANT, M.D., 3 a witness herein, having been first duly sworn, testified 4 as follows: 5 6 EXAMINATION 7 BY MS. JONES: - 8 Q. Doctor, my name is Mary Jones, and I'll be 9 asking you most of the questions here today. 10 Can we start the deposition by having you state 11 your full name for the record, please. 12 A: Sure. My name is David Hay Garabrant, 13 ' Q. How do you spell the middle name? 14 A. H-a-y. - 15 Q. The last name is G-a-r-a-b-r-a-n-d-t? 16 A. No ,"D." , 17 Q. Thank you: 18 Doctor, the oath that you took today is the same 19 oath you would take in a court of law. It has the same 20 force and effect. If you intentionally lied under oath, 21 you would be subject to a penalty of perjury. Do you 22 understand that? 23 Is that a "Yes"? 24 A. Yes. 25 Q. During a deposition, it's necessary for you 26 to' make verbal or oral responses. A nod or shake of the 27 head, or shrug of the shoulders, as we do in normal 28 conversation, is not recorded properly by the reporter, so LUCIA MOSKAL CERTIFIED Shorthanp REPORTERS 5 ' 1 if you lapse into that habit, I will just say to you, "Is 2 that a 'Yes' or is that a 'No,'" and then you can give the 3 verbal response and then the reporter can record that. 4 Do you understand? ` 5 A. Yes. 6 Q. Doctor, haveyou ever had yourdeposition 7 taken before? 8 A. No. 9 Q. ThenI'm goingto go through some rather 10 extensive admonitions or guidelines for the deposition to 11 be sure that you understand what we expect of you today. 12 During a deposition, it's typical to ask questions 13 that go far back in time or to ask you for information in 14 your memory, even though you may 'not have reviewed something 15 immediately or have it in front of you. And although you 16 may not have a precise or complete response', we're entitled 17 to whatever information you do have. I do not, however, 18 want you to guess. So, for instance, if you've reviewed 19 a publication and it was within the last year, then I would 20 be entitled to that information, despite the fact you could 21 not tell me that you reviewed it in May of 1986. Do you 22 understand that? 23 A. Yes. 24 Q. Doctor, if I ask you any questions today 25 that do not make any medical sense to you, then just tell 26 me that and I'll try to rephrase it or have you explain to 27 me why it doesn't make medical sense and then rephrase it 2 for you. Don't try to answer a question that doesn't make LUCIA MOSKAL cStHBOTRwTHeAoND PE POUTERS ' 6 1 any sense. If I ask you a question that you do not understand, 2 just tell me that and I will rephrase it. If I ask you 3 a question and I'm misspeaking myself and you know it, 4 just indicate that. If I ask you a question and you do not 5 hear me, tell me that. 6 If you answer a question. I'll assume that you've 7 8 understood the question and you're answering to the best of your ability. Do you understand that? 9 10 A. Yes. MR. GLICKMAN: Off the record. 11 {A discussion was held off the record.) 12 Q. BY MS. JONES: Let's go ahead and start with 13 14 your C.V., Doctor. ' 15 Do you have any questions about what we expect of 16 you today during the deposition? 17 A. No. . Q. Have you had any medication or alcohol within 18 19 the last 24 hours? 20 A. No. 21 Q. Do you have anyreason tobelieve that you 22 cannot give us your best testimony today? 23 A. No. 24 Q. Doctor, wewill take a break after about an 25 hour. If you need a break more frequently than that to 26 keep your mind fresh, then tell me that. I don't want you 27 to become overtired. We want your best testimony. If it 28 means we have to take a break every half an hour, then that's LUCIA MOSKAL CsRmEecefstfohlfstiEThDatsmsd 7 fine. Do you understand? A. Yes. Q. Doctor, I have in front of me a copy of your curriculum vitae dated August 1986. Is this your most current curriculum vitae? A. I'm not sure. It might have been updated since then. If it has been updated -- Q. Doctor, would you take just a moment and look at it and see if there's anything you'd like to add to that because we will be attaching a copy of that to the transcript. So take your time. A. The only thing that would have change^ that some of the papers listed on pages 8 and 9 would be changed ~ excuse me -- on 7 and 8 would be changed from "submitted" to "in press." Other than that, it won't have changed. ' In fact, I think the secretary will bring in an updated version if you'd rather work from that. ' . Q, If she's going to copy that, I can go ahead and use this until we get the current one in, and then we'll attach the current one, and as soon as we get it, 1*11 identify it and have it attached. Doctor, in looking at the first page of your curriculum vitae, I see that you have received your medical school training at Tufts University; is that correct? A. Yes. Q. And yourinternship atGeorgetown? . A. Yes. Q. And residencies atHarvard and University LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS ` 8 Hospital,in Boston? A. Yes. Q. Doctor, with regard to your residency at Harvard, that was in occupational medicine? A. Yes. Q. Whatexactly.isoccupational medicine? A. It is a field within the broad field of preventative medicine, and it focuses on the -- MS. JONES: Off the record, please. (A discussion was held off the record.) MS'. JONES: Back on the record. Before we go any further, I'd like to attach a copy of the doctor's curriculum vitae dated August 1986, for David Hay Garabrant, M.D., M.P.H.j M.S., and it consists of nine pages. MR. GLICKMAN: That will be Exhibit -- MS. JONES: Defendants' first in order. MR. GLICKMAN: -- A. (Said document was marked Defendants' A for identification by the Notary Public.) Q. BY MS. JONES: Doctor, with regard to Harvard School of Public Health where you took your residency in occupational medicine, what exactly did you study in that residency program? A. I studied epidemiology, biostatistics, industrial hygiene, toxicology -- Q. Let me ask you to slow down just a moment. Epidemiology, toxicology, biostatistics, and what else? LUCIA MOSKAI. CERTFEO SHORTWAhO REPORTERS A. ' Industrial hygiene, basic problems in occupational health, which was -- I don't know if you care for this amount of detail--essentially a review of industrial processes and the health hazards associated with exposures in those industries. Q. All right. Anything else, Doctor? A. Those would have been the major areas. ThpifpJb Jk X \nw wL, wTV pthLi pVw others that were minor. Q. Doctor, epidemiology is the study of populations of individuals; is that correct? A. I would define it as the study of patterns of disease in populations. Q. Doctor? And toxicology, how would you define that, A. As the study of the effects of foreign -- it's the study of the effects of chemicals and, say, pharmaceutical agents on biologic systems. Q. The biologic systems, would that be human systems or animal systems? . A. Toxicology would cover both human and , animal and some in vitro systems like bacteria or fungi. Q. And biostatistics, Doctor, what exactly is that? A. It's a branch of mathematics that is concerned with the use of statistical techniques to analyze data relating to populations and health status. Q. Industrial hygiene is what, Doctor? A. That is the field concerned with evaluating LUCIA MOSKAL eSRheEoPmOrmRtEThEaDRnSd * 10 1 and measuring exposures to chemicals and physical agents, 2 primarily in industry. 3 Q. And problems in occupational health, you 4 said, was a review of the industrial processes? 5 A. And the health hazards*associated with those 6 processes. 7 Q. Doctor, during this residency program, did 8 any of your studies involve individuals exposed to asbestos 9 materials of any type? 10 A. One of my studies did. 11 Q. What study was that? 12 A. It was a study of pulmonary function and 13 . chest X-ray changes in a group of titanium metal production 14 workers. 15 Q. Were these titanium metal production workers 16 also exposed to an asbestos material in their work 17- environment? 18 A. Yes. Some of them were, yes. 19 Q. One other admonition, Doctor, it's important 20 to let me finish the question completely because I may 21 add something to the end of the sentence that would 22 change your response, and if that happens, it's normal 23 to speak over one another in everyday conversation, but 24 the reporter can't record that very well. 25 a. I understand. 26 q. So I may just stop if you start tospeak 27 and then finish my question and you may want to change your 28 answer because of that. That I do because it's easier for LUCIA MOSKAL CERTIFIED Shorthand REPORTERS 11 1 the reporter to record that way. So if you can, even 2 though I sometimes pause mid-sentence, let me finish 3 completely and then give your response. Okay? 4 A. Yes. . 5 Q. Thank-you. 6 What group did you use in this study, Doctor? 7 A. It was a cohort of primarily men who 8 made titanium metal at a plant in Ashtabula, Ohio. 9 Q. Did you collect the data for the study or 10 have it collected at your direction? 11 A. I collected it with other investigators. 12 yes. 13 0. How many individuals were in this study? 14 A. Approximately 209. j 15 Q. What was the purpose of the study? 16 A. To determine if there were substances in 17 the 1work environment that led to pulmonary disease or 18 pulmonary symptoms. 19 Q. Did you reach any conclusions with regard 20 to substances in the work environment leading to pulmonary 21 disease or processes? 22 A. Yes, we did. . 23 ' Q. What conclusions did you reach, Doctor? 24 A. I'm speaking from memory because that study 25 ' was done a long time ago. 26 Q. All right. 27 A. To the best of my recollection, we found 28 that there was an excessive amount of pleural thickening LUCIA MOSKAL CERTIFIED SMORTHANO REPORTERS . 12 in the group, which seemed to be due partly to previous 1 2 asbestos exposure, and partly due to exposure to either 3 titanium tetrachloride or titanium dioxide or intermediate reaction products in the formation of titanium metal. 4 5 Q. Thank you, Doctor. 6 Doctor,- in that study, were you able to -- strike 7 that. 8 You'also undertook education at the Public Health 9 School in 1979 and 1980? is that correct? 10 A, Are you speaking about the Harvard School of Public Health? 11 Q. Yes. 12 13 A. I was there from 1978 to 1980. . 14 Q. All right.' And, Doctor, you've indicated 15 on your curriculum vitae -- this is the section I'm 16 referring to, Doctor -- Public Health School, and you've 17 sectioned off 1979 and 1980 at the Harvard School of Public 18 Health. 19 What exactly was that two years devoted to in - 20 terms of your training? ' 21 A. My residency in occupational medicine. 22 Q. With regard to your residency in' occupational 23 medicine, did it cover the topics you've already indicated 24 to us? 25 A. Yes. 26 Q. Did it cover any additional topics that you 27 haven't listed yet, that you can think of at this time? 28 A. As I said before, there were some minor areas, LUCIA VIOSKAL fCSthCEO*B0BTITFTheaDRmSC 13 1 which I can try to recall. I took a course in tropical 2 diseases, for example, and there were a few others. A 3 course in infectious disease epidemiology; a course - 4 well, actually that course was properly titled, "Decision 5 making in Issues of Public Health Importance," and it focused 6 on decision-making in the area of infectious disease epidemiology and control, 8 I think that covers everything. There are probably 9 a few other small courses that I didn't mention. 10 Q. That's fine. Doctor. Thank you. 11 I s 12 r\ hJ.L > Jp, JwLn JnL j-n. (in. Vjmi/* m* 13 California. 14 * A, Yes. 15 Q. You have 'Board certification in Internal 16 Medicine in *81; is that correct? 17 A. Yes. . 18 Q. And Preventive Medicine in 1982; is that 19 correct? 20 A. Yes. 21 Q- And a subspecialty certification in 22 occupationa nedicine in 1982; is that correct? , 23 A. Yes. 24 Q. Are you Board-eligible in any other 25 subspecialt 26 A. No. 27 Q. Doctor, on page 2 of your curriculum vitae, 28 you have a LUCIA MOSKAL CSRHEERPOOTRIRFTITHEEADRNSD 14 1 "Graduate Level Courses." Do you see that? 2 A. Yes. 3 Q. The fourth item down deals with "Family and 4 Preventive Medicine, Year 1 Medical School Curriculum, 5 lectures on occupational cancer, heavy metals toxicity," 6 et cetera. Do you see that language? 7 A. Yes. 8 Q. Doctor, what exactly did you study with 9 regard to heavy metals toxicity during that one year? A. During which year are we -- . 10 11 MR. GLICKMAN: I think those are what he teaches, 12 not what he studied. Maybe there's a confusion in your 13 question. 14 MS. JONES: Thank you, Counselor. 15 MR. GLICKMAN: Is that right. Doctor? 16 THE WITNESS: Yes. Those are courses I teach. 17 Q. BY MS. JONES: So you teach the first year 18 of medical school in that topic; is that correct? 19 A. I give lectures on those topics to the 20 first-year medical students. 21 Q, Where did you receive your training with 22 regard to heavy metals toxicity? 23 A. At the Harvard School of Public Health, 24 Q. And that was in your occupational health 25 courses and studies? 26 A. That was in -- specifically in the course 27 in toxicology and a course in basic problems in 28 occupational health. LUCIA MOSKAL CSRhepoRoTrrTtIthEeaDrnsd 15 1 Q. Have you done studies with regard to heavy 2 metals toxicity other than the one that you've already 3 indicated on titanium? 4 A. I would not classify titanium as a heavy 5 metal. 6 Q. Thank you, Doctor. ' . Have you done studies in heavy metal .toxicity? 8 A. I am in the middle of a study of lead 9 toxicity from lead naphthenate, n-a-p-h-t-h-e-n-a-t-e. 10 Q. Have you been involved in any other heavy 11 metal toxicity studies other than the one you just 12 mentioned? . 13 A. I did a mortality study of geothermal 14 workers who had low-level exposure to inorganic arsenic. 15 Q. Doctor, on that same section of your curriculum 16 vitae, again, your teaching responsibilities, items 6 and 17 7, invited lecturer. School of Public Administration, and 18 the 7th one, the Institute of Safety and Systems 19 Management -- do any of these courses that you teach, the 20 four that I've mentioned -- excuse me the three that 21 I've mentioned, involve the study of asbestos-exposed 22 individuals? ' 23 A. The fourth item on that list, the year one 24 medical school curriculum, involves teaching the medical 25 students about the health effects of asbestos, under the 26 topic of occupational cancer. 27 Q. Doctor, other than the study that involved 2 the titanium exposure and the asbestos exposure that we  * 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 . 16 17 18 19 20 21 22 23 24 25 26 27 28 LUCIA MOSKAL CEFmREO SHORTHAND REPORTERS 16 discussed earlier, have you participated in any other studies that involved individuals exposed to asbestos material? A. Yes, as a peripheral issue in the mortality study of aircraft mnufacturing workers that we've completed, some of the exposures in which we were interested -- or . we were interested in asbestos exposure in that study. Q. Which page are you now referring to. Doctor, on your C.V.? A. Page 8, item 2 at the top. Q. Is that paper still in preparation, Doctor? A. Yes, it is. Q. What population of workers did you study? A. A cohort of aircraft manufacturing workers in San Di'ego. Q. From a particular plant? A. From Rohr Industries. last? Q. Over what period of time did your study - A. The study was conducted between 1980 -- forgive me if I don't remember if it started in '83 or *84. ' Q. That's all right. A. It was either late '83 or early '84, up to the present time. We conducted the study over that period of time. It was a retrospective study which was interested in exposures reaching back really to the start of the company in the 1940s. Q. During that study, did you identify the , LUCIA VIOSKAL CERTIFIED SHORTHAND reporters 17 . 1 1 particular materials that contained asbestos used at Rohr 2 Industries? 3 A, We ascertained which jobs involved the use 4 of asbestps or exposure to asbestos. 5 Q, In identifying the particular jobs, did you 6 incidentally identify the products that contained 7 asbestos? ' 8 A, Do you mean by brand name? ' 9 Q. By type of product. In other words, brake 10 material, insulation material. _ 11 A. We identified them by type of use, 12 Q. Doctor, have you participated in any other 13 studies that involved asbestos-exposed individuals? 14 A. No. 15 Q. What was the population, that is, the total 16 population that you studied in the second study in 17 San Diego? 18 A. It was approximately 12,600 people. 19 Q. Did you study these people by interview or 20 by record? 21 , A. The subjects of the study were studied by 22 record. However, some of the current employees were .* 23 interviewed to ascertain exposures that had occurred in 24 the past, in the jobs held by the subjects of the study. 25 Q. So you collected your data for the study from 26 records that had previously been authored by other 27 individuals? 28 A. Ves.  t LUCIA VIOSKAL cSReHEnOPTOR*fTtiTHEDAPNSD 18 1 Q. Would the same be true with regard to your 2 data collection in the first study that you mentioned? 3 A. Which one are you referring to? 4 Q. The titanium metal production. 5 A. Yes. 6 Can I add something to that? 7 Q. Ce rtainly. 8 A. In that study, we abstracted the work records 9 and we also interviewed the workers in the titanium study. 10 So it was a combination of the two. 11 Q. Thank you, Doctor. . 12 Doctor, on page 3 of your curriculum vitae, if I 13 can find it again, under "Clinical Teaching," you indicate 14 that you've taught at Barlow Hospital; is that correct? 15 A. Yes. 16 Q. That was from 1983 to 1986; is that correct? 17 A. Yes. 18 Q. And you have also held a teaching position 19 with CAL-OSHA; is that correct? 20 A . I wouldn't put it in the terms that I've held . 21 a teaching position with CAL-OSHA. ' 22 Q.- I see. 23 A. I supervise a field placement of our residents 24 with CAL-OSHA. 25 Q. In other words, medical residents from this 26 University Hospital you place with CAL-OSHA? 27 A. Yes. I supervise their work and meet 28 regularly with them and a supervisor from CAL-OSHA. LUCIA MOSKAL CEOTVIED SRHEPOORRTTHEARNSD . 19 , 1 Q. Have you ever worked for CAL-OSHA? 2 A. No, I have not. , 3 Q. Have you ever worked for National-OSHA? 4 A. No, I have not. 5 Q. Have you ever authored or participated in 6 authoring any studies for CAL-OSHA or National-OSHA? A. Yes, I have. 8 Q, What studies werethose, Doctor? 9 A. We conducted a study -- or I should say, we . 10 with others conducted a study under contract with CAL-OSHA, 11 and that was a study of pulmonary function -- or of 12 respiratory effects of cotton-dust exposure in the- cotton 13 garnetting industry. 14 Q. Any other studies that you have conducted 15 for or in cooperation with CAL-OSHA? 16 A. I'm currently assisting them on an informal 17 basis in a study of styrene exposure. 18 Q. Would you term or characterize your assistance 19 as an advisor of some type? 20 r A. Yes. 21 Q. Doctor, the same questions with regard to 22 National-OSHA. Have you participated in or cooperated 23 with the studies conducted by National-OSHA? 24 A. No. 25 Q. Doctor, on page 5 of your curriculum vitae, 26 . you listed a category, "Research Activities." I'd like to 27 ask you some questions about that, if I may. 28 Your major areas of research interest are LUCIA MOSKAL CERTIFIED SMORTHANO REPORTERS occupational cancer, epidemiology, and epidemiology of 20 occupational pulmonary disease; is that correct? 2 3 A. Yes. 4 Q. Doctor, do either of these two general 5 topics, that is, your major areas of interest, involve 5 the study of asbestos-exposed individuals? 7 A. Insofar as asbestos exposure relates to 8 those general- areas, yes, it would. 9 Q. Have you ever attempted in your research in 10 these two major areas to isolate the effect of asbestos 11 upon individuals that you've studied, that is, isolate it 12 from other industrial effects? 13 A. In the titanium study that we described 14 earlier, we did attempt to do that, and in the mortality 15 study of aircraft manufacturing workers, we also attempted 16 to determine the effect of asbestos. 17 Q. Did you publish either of those studies. 18 Doctor? 19 A. The titanium study is in press. And the 20 aircraft manufacturing study is in preparation. 21 Q. Is it common to publish interim results of 22 studies in the medical field? In other words, while 23 you're in progress, did you publish any of your data or 24 opinions before you had actually finished the studies? 25 A. The only situation in which that has occurred 26 is when I've submitted a technical report on a study, 27 and then later tried to publish the results in a medical 28 journal. LUCIA MOSKAL CSHEORRTFTHCADND REPORTERS 21 1 Q. With regard to the technical reports, would 2 that be something you would publish if you had received 3 a grant from an organization of some kind and you were 4 keeping them informed of your progress? 5 A. Yes. 6 Q. Would the.re be any other instance in which 7 you would publish such a study in an interim basis? 8 A. Not to my recollection. 9 Q. Doctor, under the major areas of studies, the first one being occupational cancer epidemiology, the third 10 11 category is gastrointestinal cancer and occupational factors. 12 Do you see the language that I'm referring to? 13 A. Yes. 14 Q. Doctor, with regard to gastrointestinal 15 cancers, is it common to group cancers of all parts of the 16 gastrointestinal system into one, or are they separated out 17 according to the portion of the system that's affected? 18 A. I'm not sure I understand the question. 19 Q. Would you, for instance, attempt to study 20 stomach cancers as distinguished from colon cancers, or 21 would they be combined in the same data? 22 A. I guess it would depend on what purpose you 23 had for doing the study. - 24 Q. With regard to your areas of interest in 25 this regard, have you undertaken any studies of gastro 26 intestinal cancer? 27 A. Yes. 28 , Q. Can you estimate for us the number of studies LUCIA MOSKAL CERTFEO SHORTHANO EORTERS ' _ 22 that you have undertaken or participated in? 1 2 A. Three related to gastrointestinal tract 3 cancer. 4 Q. Is gastrointestinal tract cancer distinguished 5 from colon cancer? 6 A. Colon cancer is a subcategory of gastro 7 intestinal tract cancer. 8 Q. Would those three studies include any work 9 that you have done with regard to colon cancer? 10 A. Yes. Q. Doctor, let me ask you, then, about these 11 12 three studies. Can you tell me what the first study was, 13 that is, what group you studied, for instance? 14 A. We studied the relationship between job 15 activity and colon cancer risk in Los Angeles County. 16 Q. What population did you study? Just workers 17 in Los Angeles? 18 A. We studied approximately 2,950 cases of colon 19 cancer diagnosed among men in Los Angeles County between 20 1972 and '81, I believe, and used as a comparison 21 population many thousands of people who had other types 22 of cancer. 23 Q. The comparison was the control group, or is 24 that an incorrect explanation? 25 A. That's a reasonable way to say it. 26 Q. And these thousands of other people, then, 27 had other types of cancer, also living in Los Angeles 28 County? LUCIA MOSKAL CERTIFCD SHORTHAND REPORTERS 23 1 A. Yes. 2 Q. Did you obtain your data by interview with 3 individual physicians, or by review of records? 4 A. The data were obtained through the Los Angeles 5 County Cancer Surveillance Program which ascertains 6 virtually all incident cases of cancer in Los Angeles 7 County, and those data are obtained by abstracting 8 pathology records at all of the hospitals in Los Angeles 9 County. 10 Q. Doctor, to your knowledge, was any of this 11 data abstracted from death certificates? 12 A. Yes. The Cancer Surveillance Program also 13 ascertains death certificates in Los Angeles County to see 14 whether they have missed any incident cases of cancer, 15 so they surveil mortality.due to cancer as well. 16 Actually -- excuse me -- but for our study, we 17 only used incident cases. I should back up. For our study 18 we did not use death certificate based causes. Those were 19 just incident cases. . 20 q. Can you explain to me in a little more detail 21 what an incident case is? ` 22 A. An incident case is the case at the time it 23 is diagnosed. 24 Q. Do you know whether the L.A. County Cancer 25 Surveillance Program used pathology reports, for instance, 26 or interviews with doctors? In other words, do you know 27 how they obtained their information? 28 a. They obtained their information from pathology  LUCIA MOSKAL SRHEPOOflTRHTEARNSO ' 24 1 reports. 2 Q- Do you know which hospitals in Los Angeles 3 ' County participate or contribute to the L.A. County Cancer 4 Surveillance Program? 5 A. It's my understanding that every hospital in 6 Los Angeles County participates in it. 7 Q. Do you know what years are reflected, that is. 8 years of diagnosis, are reflected in the documents that 9 you used from the L.A. County Cancer Surveillance Program? 10 A. The Cancer Surveillance Program began in 11 roughly 19 71 or '72, and had incomplete ascertainment for 12 either `70 and *71 or '71 and .'72, and has had virtually 13 14 15 16 complete ascertainment of incident cases since then. So it 's roughly from '71 or '72. Q. And that is the data base that you used, '71 or '72 through *81; is that correct? . , # - 17 A. I believe we terminated in '81. I would . 18 have to check to be certain. 19 Q* All right. Doctor, with regard to this 20 first study that we're talking about, did you determine 21 from the L.A. County Cancer Surveillance Program the 22 occupation of the individuals whose cancer was reported? 23 A. Yes. 24 Q. Did you obtain employment information or 25 occupational background from any source other than that? 26 A. Other than what? 27 . Q. Other than the L.A. County Cancer Surveillance 28 Program data. LUCIA MOSKAL certfieo shorthand REPORTERS ' 25 1 A. For that study? 2 Q. Yes. . 3 A. No. 4 Q. So the individual's employment and 5 individual 1 s diagnosis -- that information came from the 6 L.A. County Cancer Surveillance Program data; is that 7 C U JL <l v V- V # ' / 8 A * Yes. ' 9 o. What other data did you abstract or use 10 from the L ft A ft County Cancer Surveillance Program? 11 A For that project? 12 Q. Vnl pftw QHIM* ,ft 13 A, I'm not clear what your question is. 14 . ' Q. For instance, did you attempt to categorize 15 according to age, sex, height, weight, that sort of thing? 16 A We obtained information on sex, race, age, 17 pathologic diagnosis. 18 We inferred socioeconomic stratum. 19 . As you've stated, we had information on occupation 20 and industry. 21 Q. With regard to -- excuse me, Doctor. Was 22 there anything else you wanted to add? 23 A. No. 24 Q. With regard to occupation and industry, did 25 the material that you reviewed indicate the individual's 26 entire employment history, or the job at the time of 27 diagnosis? 28 A. It indicated the job stated as the usual job LUCIA MOSKAL CEHTFIED SKflTHANO BEPOflTJRS - .. 26 1 and that was stated at the time of. diagnosis. 2 Q. Did you publish the results of this particular 3 study? 1 4 A. Yes. .' 5 Q. Is that listed on your C.V., Doctor? 6 A. Yes, 7 'Q. Can you point that out to me, please? 8 A. On page 7, No. 3, under "FullLength papers." 9 MS. JONES: Off the record, please, 10 (A discussion was held off the record.) 11 1 MS. JONES: Back on the record, please. 12 Q, I notice that you, Drs. Peters, Bernstein 13 and Mack participated in the study; is that correct? 14 A. Yes. 15 Q. So you co-authored this particular article? 16 A. Yes. 17 Q. Did you reach any conclusions as to the 18 result of the study that you published? 19 A. Yes. 20 Q. What conclusions did you reach? 21 A. We found that physicalactivity on the job 22 was associated with lower colon cancer risk, not sedentary - 23 or I should say, not lack of physical activity on the job, 24 Q. Did you direct this particular study to 25 focus on physical activity on the job? 26 A. Yes, we did. 27 Q. Did you direct this particular study to focus 28 on any other activity or -- strike that. LUCIA moskal CERTFEO SRHEPOORRTTHEARNSD ' . 27 Did you direct this activity to focus on any other parameter, in other words, such as dietary habit or type 2 3 of industry? . A. Could you restate that question for me, please? 4 5 Q. Sure. In other words, the study was directed 6 at finding the effects of activity, an individual's physical 7 activity on the job, and that relationship to development 8 of colon cancer; is that correct? 9 A. It was directed at finding the relationship 10 between physical activity on the job and colon cancer. IV Q. Did you attempt in that study, whether or not 12 the results were published, to determine the relationship . 13 between colon cancer and any other factor, such as an 14 individual's diet or an individual's industry, particular 15 type of industry? 16 A. We did not study diet. We did not study 17 industry other than as a means of grouping people according 18 to physical activity. 19 Q. Did you reach any other conclusions as the 20 result of that study, or maybe "conclusion" is the wrong 21 word. Did you have any other findings as a result of that 22 study? 23 A. The major finding was the one I've already 24 mentioned. 25 Q. Sure. 26 A. And the subsidiary finding to that was that 27 the association between job activity and -- or I should 28 say, job inactivity and colon cancer was not explained by LUCIA MOSKAL CERTIFIED SHOPTHANO REPORTERS 28 1 socioeconomic status or by ethnicity, or by age differences 2 between the cases and the comparison population. 3 Q. Anything else that you can add to that, 4 Doctor? 5 A * No. 6 Q. What is the second study you undertook with 7 regard to G .1 . cancers? 8 A* * We did a similar study to the first one of 9 the relationship between exposure to various types of dust 10 and stomach cancer risk. 1 , 11 Q. Was that study directed solely at stomach 12 cancer? 13 A. Yes, it was. 14 . Q. Did you again obtain your data from the 15 L.A. County Cancer Surveillance Program? . 16 A. Yes, we did. 17 Q. For what period of time? Was this again the 18 '71 to '81 range? 19 A May I look at the study to refresh my 20 memory? 21 ' Q. Certainly. " - 22 A. 1972 to '82. 23 ' Q. The data that you used in the study was 24 taken from that range of years; is that correct? 25 A. The cases were men who were diagnosed between 26 1972 and 1982 as having stomach cancer. 27 Q. That was, again, for males only? 28 A. Yes. 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 ' 18 19 20 21 22 23 24 25 26 27 28 LUCIA MOSKAL CERTFlEO SHORTHAND ; REPORTERS Q. 29 What factors did you consider in this study? In other words, were you looking at particular types of industry, focusing on particular types of dust? A. We were looking at types of dust. Q. What types of dust did you focus on with this study? - A. We categorized dust into broad groups such as metal dusts, organic dusts, mineral dusts. Q. Did you have any subcategorizations within those three areas? In other words, did you take metal and divide it up between iron and aluminum, or did you just take metal dust in general? A. We took metal dust in general. Q. Would the same be true of the general group, organic dust? A. Yes, except that we made a distinction between smoke and'exhaust and other types of organic dusts, Q. Did you also take mineral dust in general, or did you have any subcategories of that? A. Mineral dust in general. Q. In looking at your paper, Doctor, can you tell us what job categories the individuals had whose data you used in this study? A. It's difficult to give you an answer to that. There were 1,342 cases. Do you want all the jobs held by all the cases? Q. Let me put it this way to make this shorter. Is there any particular group of job category that you LUCIA MOSKAL CSHeQHRTTMHADNO REPORTERS ^ 1 attempted to study? 2 A. No. We attempted to study all types of jobs, 3 within Los Angeles County and use the jobs to group people 4 according to the type of dust exposure. 5 Q. Doctor, is asbestos itself a mineral? 6 A. Yes. 7 Q. Was asbestos one of the minerals that -- 8 strike that. 9 In doing this study, was asbestos as a mineral under 10 the category, the general category of minerals? 11 ' A. Jobs in which there was exposure to asbestos 12- would have been grouped into the category of jobs in which 13 there was exposure to mineral dust. 14 Q. Can you tell me what other mineral dust aside 15 from asbestos would have been grouped in that third category 16 A. It would haveincluded variousdusts such as 17 silita, plaster, various types of stone, cement. 18 Q. Those would be the major minerals that you - 19 A. Yes. . ' 20 ' Q. -- obtained :data on? All right. 21 Did you attempt in any" way to differentiate between 22 any of these types of minerals in the data that you ' 23 collected? 24 A. Not -- no. 25 Q. Doctor, did you reach anyconclusions or 26 did you have any findings as a result of this particular 27 study? 28 A. Yes. LUCCA MOSKAL cspr^ec? SHORTHAND REPORTERS . 31 1 . Q. What conclusions or findings, did you reach? 2 A. We found that men who worked in dusty - jobs 3 had a risk for developing stomach cancer at least 1.2 . 4 times that of unexposed'men. Do you want me to continue? 5 6 Q. Yes. Any other findings you had. Doctor? 7 A. The association of exposure with stomach 8 cancer was stronger at higher levels of dust exposure. 9 The risk was not uniform throughout the stomach. The highest risk was found for the antrum and pylorus. At that 10 11 site, exposure to mineral dust carried the greatest risk 12 for cancer, which was 2.4 times the risk for unexposed 13 men. - 14 Q. Any other findings or conclusions? 15 A. The highest risks from dust were observed in 16 blacks. 17 Q. Any other'conclusions or findings. Doctor? 18 A. Those are the major ones. There are some 19 minor ones, but those are the major ones. 20 Q. Doctor, are you aware -- strike that. I'll 21 try to keep this in some sort of order'. 22 What was the third study that you did with regard 23 to cancer? 24 A. The study that we previously mentioned 25 regarding mortality in the aircraft manufacturing industry. 26 That study included a case-control study of esophagus 27 cancer. 28 Q- Let me back up. Doctor. With regard to the LUCIA VIOSKAL CERTIFIED SHOflTWANO reporters 32 1 second study , was that one also published? 2 A. That one has been submitted for publication. 3 Q. Is it listed on your curriculum vitae? 4 A. Yes. On page 7. 5 Q. Page 7? 6 ' A. Under "Papers Submitted," it's No. 1. 7 Q- Thank you. 8 "Adenocarcinoma of the stomach and exposure to 9 occupational particulates"? 10 A. Yes. 11 Q. Doctor, would it be possible for us to obtain 12 from you a copy of that paper since it is not yet published? 13 A. I don't know what the protocol is for that. 14 Q. The protocol is just to ask for it and we 15 attach it to the deposition transcript. 16 MR. GLICKMAN: No, that's not necessarily true. 17 The doctor may not want an unpublished article that may 18 still be revised in your hands or anybody else's hands. 19 It's his private affairs and it's going to stay that way 20 until the judge rules otherwise. 21 THE WITNESS: That is work in progress, and there 22 are other people involved with it, and I would not feel 23 right about giving that to you without their permission. 24 MR. GLICKMAN: You get a court order'and we'll 25 talk about it, and I'll be there to resist it. 26 Q. BY MS. JONES: Let me put it this way. This 27 particular article is the one that you were referring to 28 in responding to certain questions during the deposition; LUCIA moskal cewnreD SHORTHAND , reporters 33 1 is that correct? 2 MR. GLICKMAN: Only because you were asking the 3 questions. 4 Q. BY MS. JONES: In other words, the paper 5 that you were referring to is the unpublished article 6 that you've identified at page 7, No. 1, of your curriculum 7 vitae? 8' A. Yes. _ _ 9 MS. JONES: Counsel, are you still going to 10 instruct your expert not to produce that item? 11 MR, GLICKMAN: Sure. It's not even all his work 12 product. He just told you there's other people involved 13 and he'd have to get their consent. It's work in progress. 14 I don't think it has anything to do with the issues in this 15 case. You're just on a fishing expedition, and engaging 16 in a sea of trivia as opposed to concentrating on the 17 issues in this case, and without a court order, he's not 18 going to turn it over to you, and that's the way it's going 19 to be. Go on to the next question. 20 Q. BY MS. JONES: Doctor, what I'm going to do 21 is request the court to obtain that document from you. Can 22 , you tell me who the other contributors to this particular 23 paper are, or are they listed here? ' 24 A. They are listed there. 25 Q. Again, that would be Wright, Bernstein, 26 Peters, Garabrant and Mack; is that correct? 27 A. Yes. 28 Q. And are all of these individuals doctors?  # LUCIA VIOSKAL CSRhEEoPftOrTRFtThEEaDRnSd 34 1 A. They all have doctoral degrees. 2 Q. Either medical or Ph.Di's of some type? 3 A. Yes. 4 Q. Are they all located at this institution, 5 use? 6 A. No. 7 G. Can you tell me where Dr. Wright is located? 8 A. In Washington, D.C. 9 0. And Dr. Bernstein? 10 A- Here at USC. ' .11 Q. And Dr. Peters? 12 A * Here at USC. 13 Q. And Dr. Garabrant is here. Dr. Mack? 14 A. Here at USC. 15 Q. I'm sorry. Did you say Wright was at 16 Washington, D.C.? 17 A. Yes. Well, he lives in McLean, Virginia. 18 Q. Thank you. Doctor. 19 MR. GLICKMAN: I'll give you fair notice under 20 Article 1, Section 1 of the California Constitution, 21 invasion of privacy, and the consumer -- 22 MS. JONES: Counsel -- ' 23 MR. GLICKMAN: I'm putting this on the record. You 24 said you're going to make a motion, and I think you're 25 trying to intimidate my witness. 26 MS. JONES: We have a two o'clock appearance -- 27 MR. GLICKMAN: And I just want to say you're going 28 to have to give all those doctors written notice of any . LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS V 35 1 motion you're going to apply for. 2 MS. JONES: Counsel, we've a two o'clock appearance 3 and you can give the doctor any advice you want, but X think 4 we ought to try to finish this as quickly as we can. 5 MR. GLICKMAN: I think you're trying to intimidate 6 him. . 7 Q. BY MS. JONES: Doctor, with regard to the 8 third study you did with regard to G.I. cancers, let me ask 9 you some questions with regard to that now. 10 That was the study you referred to earlier at Rohr 11 Aircraft Industries in San Diego; is that correct? r 12 A. At Rohr Industries. 13 Q, Rohr Industries. Thank you. 14 That study was directed at mortality, and as a 15 subtitle, so to speak, the study of cancer of the esophagus? 16 A. It was a mortality study of aircraft 17 manufacturing employees, 'With a nested-case control study 18 within it, and that was a case control study of esophagus 19 cancer. 20 Q. Doctor, with regard to this particular study,, 21 you said that you obtained your data, if I recall correctly, 22 from interviews and also from records; is that correct? 23 A. We obtained the work records of cases and 24' controls in the study, and we ascertained the exposures 25 that occurred in those jobs by interviewing current workers 26 who had been present in those areas of the plant at the 27 time the subjects of the study held the jobs. 28 Q. So these would have been co-workers of the LUCIA MOSKAL CfATOED Shorthand ftgPOATEftS 36 1 individuals? 2 A. Of the subjects, yes. 3 Q. Did you obtain your data from any other source 4 for this particular study? E A. Yes. We -- let me back up. Are you asking 6 about the overall mortality study, or the case control study of esophagus cancer specifically? 8 Q. Thank you, Doctor. The case control study 9 of esophagus cancer. 10 'A. We ascertained the vital status of each of 11 the cases and controls, and the cause of death for those 12 who were dead by standard tracing techniques, which involved 13 use of Department of Motor Vehicle records, Social Security 14 Administration records'. State of California death tapes, 15 and credit records from TRW. 16 Q. Has this particular study been published? 17 A. No. 18 Q. Has it been submitted? 19 A.' No. 20 Q, which physicians or Ph.D.'s participated 21 in this' study along with you? 22 A. Leslie Bernstein, and Brian Langholz. 23 Q. Are you referring to a particular item on 24 your curriculum vitae? 25 A. Yes, I am. T 26 Q. Which item is that. Doctor? 27 A. Page 8, under "Papers in Preparation," No. 2. 28 Q. Thank you, Doctor. LUCIA MOSKAL cRSeEHRPOOtR*RTTHeEA>RNSD 1 37 Q. Have you reached a final finding or conclusion 2 with regard to this particular study? 3 A. The study has to be reviewed and accepted 4 by an advisory committee before I can say the results are 5 final. 6 Q. Do you personally have any opinion with 7 regard to the findings and conclusions based upon your 8 review of the data collected in the study? 9 A. Could you say thatagain, please? 10 Q. Yes. Based upon your review of the data in 11 the study, do you have any personal opinions with regard 12 to the findings and conclusions? 13 A. Yes. 14 Q. What are those? 15 A. The goal of the study was to ascertain 16 whether there were factors at Rohr Industries that were 17 associated with esophagus cancer. 18 We found that there were some associations that, 19 although they were statistically significant, appeared not 20 to be causal because they did not show a relationship 21 between increasing risk and duration of work in the areas 22 where there was exposure or between risk and time since # 23 first employment in the areas or in those exposures. 24 There was one finding that was quite strong which 25 showed an association between esophagus cancer and work 26 in a particular building. Actually, it was an area that 27 included two buildings. Q. What particular work, if you recall, was being LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS 38 done in those two areas? A. A variety of things were being done. That area included a large amount of office space where accounting and other administrative tasks were done. It included an engineering design area which was primarily used for tooling design. It included a tooling shop where tools were built, and it included a maintenance area. Q. Within those four subcategories of activity in those two buildings, were you able to find any strong link between the development of cancer of the esophagus and any one of those occupational areas? ` A. The strongest link appeared to be between work in the office areas and esophagus cancer. Both office areas. Q. Thank you, Doctor. Are there any other studies that you've done or participated in with regard to G.I. cancer? A. I guess to be complete, I would have to say that a portion of the mortality study of shoe and leather workers in Massachusetts that I did also looked at cancer mortality due to gastrointestinal cancers. Q. Any particular gastrointestinal cancer? A. It would have looked at all different types. Q. Which document or portion of your C.V. are you referring to. Doctor? A. On page 7, under "Full Length Papers," No. 5. Q. . What findings did you reach in that particular LUCIA MOSKAL cennpeo SHQATHArsC REPORTERS 39 .. study? A. I would have to look. Q. If you have it, you can refresh your memory, Doctor. A. The major findings were that there was a statistically significant excess of bladder cancer among female shoe workers, and a case referent analysis of 'leather workers demonstrated an association of lung cancer with work in leather tanning jobs. ' Q. You said a case -- A. Referent. Q. Were there any other findings with regard to that particular study. Doctor? A. Those were the major findings. Q. Thank you. Doctor, with regard to any of these four studies, can you, from the data that you've collected and the findings you've made as a result of that data, draw any conclusions with regard to the likelihood of an individual developing cancer of the colon? _ MR. GLICKMAN: In any individual, regardless of workplace, regardless of any exposure levels? Q. BY MS. JONES; I'm talking, Doctor, about the populations that you studied in those four studies. Did the data that you collected allow you to draw any conclusions or to reach an opinion with regard to the likelihood of an individual developing colon cancer? A. I don't know how to interpret that question. LUCIA MOSKAL CETTFCD Shorthand *porters 40 Q. What I'm trying to find out. Doctor, is 1 2 whether or not there was any data that was specific enough 3 for you to make a finding or to have an opinion -- and 4 I'm again speaking only about the individuals that you 5 studied in those four studies -- of the likelihood that 6 they would develop a particular type of cancer, that is, 7 colon cancer; 8 A. The study I described of colon cancer 9 identified a risk factor for colon cancer which would 10 influence an individual's risk of developing colon cancer* 11 Q. You're referring to the first study that we 12 discussed; where you obtained the data from the L.A. County 13 Cancer Surveillance Program? 14 A. i'm referring to the study of job activity 15 and colon cancer risk. I believe that was the first 16 study. 17 Q. The physical activity on the job, the 18 relationship of that? 19 A. Yes. 20 Q. All right. With regard to that particular 21 study, is it correct that the data you collected was 22 directed only at the physical activity on the job rather 23 than other factors such as exposure to dusts or to minerals 24 or dietary habits or something else? 25 A. It was directed at the effect of physical 26 activity and other factors such as age, sex, ethnicity, 27 social class. 28 Q. Were any of the other factors -- just to be LUCIA moskal CSEHROTR1TRHEADND REPORTERS 41 2 factors include industrial exposures, such as to dust or 3 chemicals. something like that? 4 A. To chemicals or mixtures of chemicals, no. 5 , Q. To dusts of any kind? 6 A. No. 7 Q. Doctor, have you -- strike that. Let me back 8 up just a minute. 9 Is it correct that your principal emphasis in your 10 work now is with regard to epidemiology? 11 A. Yes. 12 Q. Are there-any other areas of work or study 13 that you are interested in and actively participate in 14 at this time? _ 15 At m There are areas of study, -meaning formal or 16 informal reading and developing skills. My research is 17 focused on occupational cancer epidemiology. 18 > Q. Do you, for instance, see patients privately? 19 A. Yes, I do. . 20 Q. Do you work for any particular governmental 21 agency of any kind? ` 22 A. Not under any formal arrangement. 23 Q. Do you act as an expert advisor to attorneys 24 for legal matters? 25 A. I have done a small amount of that. 26 Q. Can you tell me what amount of your work . 27 activity is directed to advising attorneys in your capacity 28 as an expert?  1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 ' 17 18 19 20 21 22 23 24 25 26 27 28 LUCIA MOSKAL CCRT1TCD SHORTHAND REPORTERS MR. GLICKMAN: You mean like a percentage? MS. JONES: Yes. 42 THE WITNESS: Over what period of time? Q. BY MS. JONES: Well, if the last year is convenient, or the last five years, whatever is most convenient for you, Doctor. A. Over the last five years, I would say it's probably been well under one percent. Q. Have you noticed an increase or a decrease in that figure during the last year? . A. Yes, an increase. Q. During the last year, can you tell us approximately what percentage of your time is spent in that capacity? A. I'd guess on the order of maybe two percent of my time. Q. Thank you, Doctor. With regard to this particular activity, do you know whether the attorneys that you're advising are what are called plaintiff counsel or defense counsel? A. I have advised both. Q. Can you tell us what amount or percentage of your time is spent directly with patients? ` ' A. During the past year? Q. The last year, the last five years, whatever period is easiest for you. A. Well, it's fluctuated. During the past year, I1d say it's less than ten percent. I'd say ten percent is LUCIA MOSKAL CERTIFIED $RhEqPOrRtkTEaRnSo * a reasonable number. . 43 Q. Are these patients individuals who are . 2 3 under treatment for some type of cancer? 4 A. A few have been. 5 Q. Is there any 'other part of the body that you 6 emphasize in terms of the patients that you treat, such as 7 pulmonary problems, heart problems, that sort of thing? 8 A. Most of the patient contact I have is in 9 screening programs, and usually they receive a complete 10 physical examination. 11 Q. What screening programs are you referring to. 12 Doctor? ' 13 A. I run a medical screening program for the 14 USC employees who handle carcinogens in their work, and 15 I run a screening program for foundry workers who are 16 exposed to inorganic lead. 17 Q. .You said "inorganic lead"? 18 A. Yes. 19 Q. Which foundry, Doctor? 20 A. Camsco. 21 Q. What carcinogens are handled by the USC 22 employees that you examine? 23 A. Asbestos, benzene -- can I look? 24 Q. Sure. 25 A. Radionuclides, arsenic, aromaticamines, 26 a-m-i-n-e-s - 27 MR. GLICKMAN: How long a list are you going to 28 read? LUCIA MOSKAL CRTF*D SAgHPOOflATHTEAfNtSO 44 1 THE WITNESS: Not very long. Methylcholanthrene, methyl N-nitrosoguanidine, 2 3 gallium arsenide, aziridine, a-z-i-r-i-d-i-n-e, nickel 4 carbonyl, acrylonitrile, chloromethylmethylether, 5 dimethyl sulfate, arsine, a-r-s-i-n-e, chromates. 6 Q. BY MS. JONES: Thank you, Doctor. 7 The data received in this screening program, is it 8 published within the university? A. No. 9 10 Q. Is it reported to any particular department 11 of the university? 12 A. Not formally. I will be giving an annual 13 summary to the industrial hygienists for the university. 14 I have not done that yet. 15 Q. How long have you been involved in this 16 screening program? 17 A. I assumed responsibility for that program 18 in, I guess, March. 19 Q. March of 1986? 20 A. Yes, although I participated in setting it 21 up, oh, three years ago.' 22 Q. The individual patients that you see, are 23 they from any other source or for any other reason? 24 A. I have seen a small number of patients who 25 were referred by lawyers. 26 . Q. With what types of problems did these 27 patients present? 28 A. A variety. Different types of cancer, LUCIA MOSKAL CERTIFCD SHORTHAND REPORTERS 45 2 I should include under that heading I've also 3 received some referrals from insurance companies that 4 insure companies for Workers' Compensation. 5 Q. Do you have any other work activities other 6 than the ones that you've mentioned so far? 7 A. Those are my major activities, and the 8 teaching which we -- 9 Q. We talked about. ' 10 A. -- discussed briefly. 11 Q. All right. Thank you. 12 Doctor, as an epidemiologist, you read various 13 journals? is that correct? 14 A. I read various journals, yes. 15 Q. Are there any particular journals that you 16 subscribe to? 17 A. I personally subscribe to? 18 Q. Yes. 19 A. I subscribe to the "Journal of Occupational 20 Medicine," and I think I get the "American Journal of 21 Preventive Medicine." , 22 Q. Are there any other journals that you 23 routinely read? 24 A. Yes. 25 Q. What would they be? - 26 A. The "British Journal of Industrial Medicine 27 "Cancer Research," "Journal of the National Cancer 28 Institute, II II Scandinavian Journal of Work Environment and LUCIA MOSKAL CENTRED . RShEOPOARTHTEARM^J 46 , 1 Health," "EnvironmentalPerspectives," "American Review of 2" Respiratory Disease,""Science,""New England Journal 3 of Medicine," "Lancet," "American Journal of Industrial 4 Medicine." 5 MR. GLICKMAN: Can we stop there, or do you want 6 him to keep going on? 7 MS. JONES: We can. If he can see around the 8 reporter, he can keep going. 9 MR. GLICKMAN: Or his memory. 10 Q. BY MS. JONES: Those are principally the 11 journals that you would read on a routine basis? 12 A. Those are the journals that come across my 13 desk and I review what is in them and read what is of 14 interest to me, 15 Q. Doctor, with regard to what is of interest 16 to you, what would that be? In other words, do you spend 17 particular time looking for articles that deal with cancer? 18 A. I am particularly interested in studies of cancer 19 in relation to environmental agents, and within that, 20 particularly related to occupation. 21 I am particularly interested in digestive tract 22 cancer. I am particularly interested in tumors of the 23 central nervous system. 24 I am particularly interested in epidemiologic 25 methods. I am particularly interested in cancer screening 26 and biological monitoring. 27 I'm interested in neurotoxicology, and in 28 hepatotoxicity. LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS 47 1 Q. Thank you, Doctor. 2 Doctor, with regard to the matter that brings us 3 here today, I'd like to ask you a few specific questions. 4 You're familiar with the case of Carl Bradley? 5 A. I have read some physicians' notes about 6 Mr. Bradley. . 7 Q. Can you tell me what documents were provided 8 to you to review in evaluating the case of Carl Bradley? 9 MR. GLICKMAN: How are you holding up? Do you 10 want to take a break for five minutes? 11 THE WITNESS: No, I'm fine. 12 MR. CASSELMAN: Well, you may be -- 13 MR. GLICKMAN: Why don't we take a five-minute 14 break. We've been going an 'hour and a half. 15 MS, JONES: You're saying the three of you are 16 tired. Okay. We'll go off the record for five minutes. 17 (A discussion was held off the record.) ' 18 (A brief recess was taken.) 19 MS. JONES: Back on the record. 20 Q. Doctor, we're back from what was to have 21 been a short break. I want to. remind you that you're still 22 under oath. Do you understand that? ` 23 A. Yes. 24 Q. Doctor, when we left, I was asking you about 25 the documents that you reviewed with regard to the Carl 26 Bradley case. . 27 MR. GLICKMAN: All the documents you want to know? 28 MS. JONES: Yes. '  # ' 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 23 LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS Q. 48 Can you tell me what documents you've reviewed in this matter? . A. Okay. Do you want correspondence from Mr. Glickman that is only procedural and dates and times and things? Q. Just tell me that it was correspondence from him, and that's all I need to know. A. Okay. Correspondence, October 3rd, October 2nd -- Q. Doctor, was the October 2nd -- I notice it's a thicker piece of paper. Is there anything of substance in there with regard -- MR. GLICKMAN: It's his subpoena for trial. Q. BY MS. JONES: -- with regard to medical condition or factors that you would consider in evaluating the case? A# No. , Q. Okay. Go on, please. ' A. Another letter of September 9, 1986. Q. Anything in there with regard to the factors that you considered in evaluating this case? ' . A. No. A letter of April 25, that did not contain any information on factors relating to the case. ' Q. Okay. A. I have a letter -- Q- Before you start. Doctor, the remainder of the documents before you contain information that you considered in evaluating the case? LUCIA MOSKAL CERTIFIED SMORTHAA REPORTERS A. . Yes. 49 Q. Would you identify those, or if you hand them to me, I'll identify them for the record. The first is letterhead stationery, University of Southern California, dated July 4, 1986, to David Glickman from Kaye Kilburn, indicating no evidence of pleural thickening or plaques, despite Dr. Schoen's interpretation. I'll go back and ask you specific questions about each of them as we go through. The next one is August 10, 1981, letterhead stationery of Herman Schoen, to Robert B-u~c-h, regarding Carl Bradley, and it is seven pages, and signature by Herman Schoen. - The next is letterhead stationery, Ira Monosson, M_0_n,,0_s_s_0_nf m.D., November 29, 1982, to David Glickman regarding Carl Bradley, deceased, and it is eight , pages, signed by Ira Monosson. , The next is March 17, '83, on letterhead stationery of Ira Monosson, two pages, to David Glickman regarding Carl Bradley, signed by Dr. Monosson. And the next one is letterhead stationery of Samuel J. Sills, August 24, '81, to Miller & Folse, F-o-l-s-e, regarding Carl Bradley in the Workers Comp case. It is a document of 16 pages, signed by Samuel Sills. Were there any other documents you received in the evaluation of the Carl Bradley case? MR. GLICKMAN: That's what he received. Do you mean that's what he reviewed?  # * 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LUCIA MOSKAL C^HCEOPflOTflTPWHTeEADRMSD 50 Q- BY MS. JONES: Anything else you received -- let me be specific. Anything else you received from plaintiff' s counsel? A. There are duplicates of these documents, but there are no other documents. . Q. Did you obtain any other documents from any other source in evaluating this case such as medical records? A. I did not obtain any documents about Mr. Bradley himself other than these. . Q. Did you review any articles or studies to assist you in your evaluation of the Carl Bradley case? A. Yes, I did. Q. What exactly did you review? A. Can I put these away? Q. Leave them out, Doctor. you some questions about them. I'll need to ask A. All right. Q- All right. Doctor. Which articles? ' A. This is a single article. Q. Thank you. * I reviewed, sections of that. Q. Entitled "Toxicology and Carcinogenesis Studies of Chrysotile Asbestos '(CAS No, 12001-29-5)(Feed Studies)" and this is in F344/N Rats, and this is by U.S. Department of Health and Human Services, Public Health Service, National Institute of Health, Technical Report Series No. 295 from the National Toxicology Program, dated on the binder November 1985. LUCIA MOSKAL CERTIFIED SMOflTKANO REPORTERS 51 Did you review anything else, Doctor? Thank you. A. Yes. Q. That's all right. Entitled "IARC Monographs" on the evaluation of the carcinogenic risk of' chemicals to humans, on the front dated October 1982 from the World Health Organization International Agency for Research on Cancer. This is actually supplement for "Chemicals in industry Associated with Human Behavior," Volumes 1 to 29. Thank you, Doctor. . The next one is by Richard Doll, D-o-1-1, and Julian Peto, P-e-t-o, entitled, "Asbestos, Effects on Health of Exposure to Asbestos." I'm looking for a date on this. The copyright is 1985. Doctor, before we go any further, with regard to this particular document that I've just described, the third one, can you tell me if there were any portions of that document that you reviewed, or did you review the entire document? A. There were portions of it that I reviewed. Q. Are you able to remember or did you mark the portions that you reviewed in that document? A. I am able to remember. Q. Can you tell us which portions of that document you reviewed? . A. If you would like it by the table of contents Q. That's fine. LUCIA MOSKAL CERTIFIED RShEoPOrRtThEaRnSd 52 -1 . A. -- I reviewed Section 1, which is the 1 2 "Origin and Purpose of the report." , 3 Section 2, "Medical Effects of Asbestos." 4 Section 3, "Types of Cancer Produced." And parts of Section 4 titled "Difficulties in 5 6 Assessing Quantitative Effects of Asbestos." Parts of Section 5 titled "Dose Response 8 Relationships." 9 And parts of Section 7 titled "Summary." Q. Thank you, Doctor. 10 . With regard to the second article that I described, 11 the "IARC Monographs," did you review that entire document 12 or only portions of it? 13 14 A. Portions. Q. What portions did you review? 15 A. There's a section onasbestos, which is on 16 17 pages 52 and 53. . 18 Q. Thank you. Doctor. And on the first document that I identified, did 19 you review the entire document or portions of it? 2b MR. _GLICKMAN: The study on rats you're talking 21 22 about? ' .,, the witness: Portions. 23 24 Q. BY MS. JONES: Can you tell me what portions you reviewed? 25 26 A. Yes. I reviewed the abstract. I reviewed 27 the summary of peer review comments. I reviewed the 2l 8 introduction. I reviewed parts of section 3 titled "Results. LUCIA MOSKAL CERTFCD SHORTHAND reporters 53 And I reviewed Section 4, "Discussion and Conclusions." Q. Thank you. Doctor. And I see you also have before you some documents that are Xeroxed pages; is that correct? A. Yes. . Q. Did you also review these in formulating your opinion? A. I reviewedsome of them, yes. Q. Can you pick out for me the ones that you . reviewed with regard to your evaluation of the Carl Bradley case? A. Yes. These are the documents I reviewed. Q. All right, Doctor. Let me just identify each of these for the record. The first one is from the "Lancet," November 20, 1982, "Asbestos Exposure and Lymphomas of the Gastro intestinal Tract and Oral Cavity," pages 1117, 1118, 1119 and 1120; is that correct? A. This is not part of that article. Q. Thank you. Page 1117 is not part of the article. That's peculiar. MR. GLICKMAN: It's just the back of page 1118. That's why the doctor put an'"X" through it. . Q. BY MS. JONES: I assume page 1120 would not be included in that article as well; is that correct? A. I believe some of the references -- Q. Are at the bottom of the page. Okay.  LUCIA VIOSKAL CERTIFIED shorthand Reporters 54 1 A. -- are at the bottom of the page. 2 Q. Otherwise, the text would not be included 3 in the article; is that correct? 4 A. Yes. . 5 Q. The next article is -- what publication is 6 this, Doctor? 7 A. "Mayo Clinic Proceedings." 8 Q. I see. "Mayo Clinic Proceedings," 9 52: 809-812, 1977, entitled "Brief Note, Penetration of 10 the Small Intestinal Mucosa by Asbestos Fibers," by 11 Storeygard and Brown, M.D., S-t~o-r-e-y-g~a-r-d. 12 The next document is entitled "Occupational Related 13 Risks for Colorectal Cancer" by Spiegelman, S-p-i-e-g-e-l-m 14 and Wegman, W'-e-g-m-a-n, B.A. and M.D, 15 Doctor, 4s this published in any available 16 publication? 17 ' A. Yes, ' 18 Q. What publication is that? 19 A. "Journal of the Nati'onal Cancer Institute." 20 Q. Do you know when it was published? 21 A. In 1985. 22 Q. I see your reference here. Thank you, Doctor 23 . A. I don't have the exact citation. 24 Q. That's all right. 25 The next document is from the "British Journal of 26 Industrial Medicine" 1982, Volume 39, pages 368 to 374, 27 entitled "Dust Exposure and Mortality in an American 28 Factory Using Chrysotile, Amosite and Crocidolite in Mainly LUCIA MOSKAL SCHgAOTOTMED*NO 6PORTERS ' 55 1 Textile Manufacture." 2 The next is a "Journal of the American Medical 3 Association," JAMA, April 6, 1964, entitled "Asbestos 4 Exposure and Neoplasia," pages 22 through 26. 5 The next is entitled "Mortality Experience of 6 Insulation Workers in the United States and Canada," 1943 7 1976, by Irving J. Selikoff, published in the Annals 8 New York Academy of Science, pages 91.-- I'll just flip 9 to the'last page here -- 91 through 116. _ Next is published in the "British Journal of 10 Industrial Medicine," 1984, Volume 41, pages 151 to 157, 11 * "Dust Exposure and Mortality in an American Chrysotile 12 Asbestos Friction Products Plant," pages 151 to 157. 13 Next is "British Journal of Industrial Medicine," 14 15 1983, Volume 40, pages 361 to 367, entitled "Dust Exposure and Mortality in an American Chrysotile Textile Plant," 16 17 pages 361 through 367. 18 And the last article is "British Journal of 19 Industrial Medicine," 1980, Volume 37, pages 11 to. 24, 20 entitled "Dust Exposure and Mortality in Chrysotile Mining 21 1910-75." 22 Let me see if I can put these back in the order 23 you gave them to me, Doctor. Can you tell me with regard to the fourth item that 24 25 I have identified, did you review the entire article as 26 I've cited it? 27 A. Which is the fourth article? 28 Q. They're in order again. Doctor. LUCIA MOSKAL CERTIFIED shorthand REPORTERS 56 1 A. Yes, I did. 2 Q. With regard to the Xerox pages that I have 3 identified and the various articles that they represent, 4 did you review the entire articles of each of them or just portions of that article? 5 6 A. Shall- I go through each one? Q. Just flip through. If there are any that you 8 did not review in their entirety, stop and tell me. 9 A. Completely? 10 Q. Right. 11 A. This one I skimmed. Q. That's No. 5. 12 13 A. No. 6, I skimmed, but I am familiar with it 14 from the past, so I knew what I was looking for. 15 Q. Okay. 16 A. This one. No. 7, I read completely. 17 No. 8, I read. 18 No. 9, I had read in the past, and I refreshed my 19 memory on that. 20 No. 10, I skimmed, looking for specific elements. 21 No., 11, I skimmed, looking for specif 1c elements. 22 And No. 12, I read completely. ' 23 MS. JONES: For the record, I'll just attach these 24 by identification only. 25 Q. Doctor, if I have any difficulty locating 26 those articles, would it be possible for me to obtain a 27 copy of them from your office? - 28 A. Be happy to. LUCIA MOSKAL CERTIFIED SHOftTHANO REPOftTEftS ., 57 1 MR. GLICKMAN: If you make'the appropriate 2 arrangements to come in and microfilm them. 3 MS. JONES: No. I mean these copies, photocopies. 4 MR. GLICKMAN: Well, send a photocopy service down. 5 MS. JONES: What I'm talking about is maybe two or 6 three pages. I don't think we would need a photocopy 7 service.for that. If I needed to copy all of them, I'd 8 make arrangements for someone to come in and do that. But 9 I'm sure most of these we have available in our library. 10 {Transcript continues on page 58.) 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28  w LUCIA MOSKAL cewnpco SHORTHANO REPORTERS - 58 1 Q BY MS. JONES: Doctor, with regard to each 2 of these articles, did you after receiving the request 3 to review the Carl Bradley file research the available 4 material that you felt was relevant? To identify material 5 that you felt was relevant. Excuse me. 6 A I'm not sure I understand that question. 7 Q After receiving the request to review and 8 give your opinion on the Carl Bradley case, did you at 9 that time review the medical literature to determine 10 what articles would be relevant in this particular instance 11 A Yes. 12 Q In other words, you went out and did some 13 research. in other words, and looked through the available 14 journals? 15 A Yes. 16 Q With regard to the articles that we've 17 identified, had you on any previous occasion read any of 18 those articles? 19 A Some of them, yes. 20 Q Can you tell me which of them were new to you 21 upon your evaluation of the Carl Bradley case. 22 A Do you want to include these, as well? 23 ' Q Yes. Start with this as No. 1. 24 A That I had looked at previously. 25 Q Okay. That's No. 1. 26 A That I had looked at many times previously. 27 Q That1s No. 2. 28 A This was new to me. LUCIA MOSKAL cearneo SMO*TmanO RPQTTO 59 1 Q No. 3 was new. Okay. 2 And back on the copy of the articles starting 3 with No. 4 on top. 4 A This I had seen. 5 This I had seen. 6 This I had seen. 7 Q 4, 5 and 6. 8 A This was new. 9 Q No. 7 was new to you? 10 A This I had seen* 11 Q Excuse me. Let me just turn that sideways. 12 Go ahead. 13 A This I had seen. 14 This was new. 15 Q Okay. No. 10. 16 A This was new. 17 Q 11. ' 18 A And this was new. 19 Q Okay. 12. 20 The articles then that were new to you just briefly. 21 "British Journal of Industrial Medicine," 1980, Volume 37, 22 Pages 11 to 24 . 23 "British Journal of Industrial Medicine 19 83 , Volume 24 Pages 361 to 367. 25 "British Journal of Industrial Medicine," 1984, 26 Volume 41, 151 to 157. 27 And the "British Journal of Industrial Medicine," 1982 28 368 to 374. LUCIA MOSKAL CERTIFIED SRHEPOORRTTHEARNSD 60 1 Thank you, Doctor. 2 Doctor, was there anything else, any documents or 3 tapes or video tapes or audio tapes or anything else that 4 you reviewed in evaluating the Carl Bradley case? 5 A I can't -- no, I don't think there is. 6 Q Did you receive any infprmation by interviewing 7 individuals or discussing, obtaining orally, in other words, 8 information from anyone? 9 A . I had a discussion with Mr. Glickman. My 10 recollection is that I did not receive any information 11 that was different than what I had read in the documents 12 we've already gone through. 13 Q Again, Doctor, just'to be sure I'm clear, 14 did you at any time review the medical records on Carl 15 Bradley, that is, medical records generated by any hospitals 16 he was treated at or any physicians who treated him? 17 A I reviewed the medical records that we have 18 already looked at. 19 Q These are the correspondence on letterhead 20 stationery that I identified earlier; is that correct? 21 A Yes. 22 Q So these documents before us now and which 23 we've identified for the record are everything that you've 24 reviewed in terms of documents for this case? 25 ,, A To the best of my recollection. 26 Q Okay. Good. / 27 Doctor, after reviewing all of these records, were 28 you asked to formulate or to express an opinion regarding -- LUCIA MOSKAL CSRTtted shorthand REPORTERS 61 1 ' strike that. Let me lay a little foundation. 2 Are you aware from reviewing the records that 3 Mr. Carl Bradley had a carcinoma of the colon? 4 A Yes, I am. 5 Q Are you aware of the location in the colon 6 of that carcinoma? 7 A I believe it was in the cecum, although the 8 record of Dr. Schoen at one point indicates it's in the 9 descending colon, but most of the other notes say cecum, 10 so I believe that's where it was. 11 Q Did you assume then that it was located in 12. the cecum for the purposes of your evaluation of the case? 13 A Ye s 14 Q You're also aware that he developed metastatic 15 carcinoma in other organs of the body? 16 A Yes. 17 Q Doctor, were you asked at any time to formulate 18 an opinion regarding the cause of Mr. Bradley's carcinoma? ' 19 A I think so, yes. 20 Q Do you have ahopinion in that regard? 21 A Yes. 22 Q What is that opinion? 23 A That his exposure to asbestos had a causative 24 role in his carcinoma of the colon. 25 Q What do you mean by "causative role," Doctor? 26 A That it was a cause. 27 Q Was it theonly cause, in your opinion? 28 A- I'm not sure what terminology you use in the LUCIA moskal CERTIFIED SRHEPOORRTTHEARNSD 62 .' 1 area of causation. 2 Q Let's use yours, and you can define it for me. 3 A Certainly age is a cause, as it is for all 4 cancers, that there is a riskthat changes with age for 5 most cancers; such as cancer of the colon, the risk 6 increases with age, so that certainly played a 'role. Q Anything else. Doctor? So far you've 8 identified asbestos and age as possible causes, or causes - 9 A As causes. 10 Qw>w uacSe wruLflUi>ieScaS eo /Oa J-Pw JmLcv v Q XT w xliil wailmlCai Wt.JtIXaJL"Jv<"**1"hi 11 Mr. Bradley developed. Are there any other causes, in 12 your opinion? 13 " A There are no other causes that raised his 14 risk above that of males of his sex -- that raised his 15 risk above that of people of his sex, race and 16 socioeconomic status. _ 17 What I'm implying there is that those factors also 18 play a role in colon cancer risk. . 19 Q Just to be sure I'm clear, are there any ' 20 other causes of Mr. Bradley's cancer other than the age 21 and the asbestos? 22 A There are none that I am aware of, based on 23 the records I've reviewed. ' 24 Q Doctor, in reviewing this case, did you 25 request copies of Mr. Bradley's employment records? 26 A No, I did not. 27 Q Were you told anything about his industrial 28 exposures at his place of employment? LUCIA MOSKAL CERTIFIED shorthand REPORTERS 63 1 A I read about them in the notes we have already 2 discussed. . 3 Q Are there any chemicals or toxins that are 4 mentioned in any of those records in addition to asbestos? 5 A There are a number of chemicals that are 6 mentioned. Specifically I remember in Dr. Schoen's note 7 and Dr. Monosson's notes. 8 Q In your opinion, would any of those toxins 9 contribute to colon cancer or cause colon cancer? 10 A . I know of no evidence that would link any 11 of those other materials to colon cancer. 12 Q You said it was in Dr. Schoen's report and -- 13 A Dr. Monosson's. . 14 Q Thank you. * 15 Doctor, what is your understanding of Mr. Bradley's 16 exposure to- asbestos? 17 A In terms of what? ' 18 Q in other words, you have identified age and 19 asbestos as causes of cancer in Mr. Bradley. Am I correct? 20 A Uh-huh. 21 Q is that a "Yes"? 22 A Yes. Excuse me. 23 Q That's all right. 24 With regard to asbestos in particular, what do you 25 know of his exposure to that material? 26 A Okay. Based on the notes -- the medical reports 27 I have read, Mr. Bradley was exposed to asbestos while 28 working for Standard Brands Paint Company between LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS 64 1 approximately 1968 and 1972, and there's some difference 2 in those dates, depending on which note I read. 3 Q Do you know the level of exposure that he 4 had between the years '68 and '12? 5 A . I only know that from the numbers that are 6 cited in Dr. Monosson's note in which he cites measurements 7 of exposure made some years after Mr. Bradley was exposed. 8 Q Do you recall what figures Dr.Monosson cited? 9 A May I look? 10 Q Certainly. 11 A . To generalize, essentially, they were under 12 two fibers per cc. 13 ' Q Two fibers identified as asbestos or two fibers 14 of any material? 15 A My reading of this is that those were, 16 asbestos -- these were airborne fiber counts. I do not 17 know if.those were -- I'm sorry. Here it is stated. 18 Airborne concentrations of asbestos. I believe that this 19 note implies that all these measurements were of asbestos 20 fibers. 21 Q Doctor, did you assume, in evaluating the case 22 that the fiber concentration between 1968 and 1972 is the i 23 same as that reported by Dr. Monosson? 24 A No. 25 Q Do you know when the fiber count was taken 26 that Dr. Monosson reports? 27 A Dr. Monosson cites measurements made in May 1976, 28 March 1977, February 1978. LUCIA MOSKAL CERTFED- SRHEPOORRTTHEARNSD ' Q Do you have any work experience yourself, that is, in your work as an epidemiologist, with Standard Brands? A No. Q Do you have any work experience with a company similar to that, that is, one that manufactures paint products? A No. . Q Doctor, do you have any knowledge as to whether or not Mr. Bradley used any type of breathing protection during his employment at Standard Brands? A 1 read that he used at some times a paper mask. Q mask? Do you krfow at what times he used the paper A I do not think that that was clear. I had the impression that it was intermittent during the times he handled asbestos. I don't recall the exact dates, if they were specified. I believe they were not specified, though. Q Do you know anything about the particular asbestos material that Mr. Bradley was exposed to at that work location? A I do not, other than that it was a pelletized form of asbestos, which from what I read was supplied by Union Carbide. I do not know what mineralogic form of asbestos it was. Q You said "pellet," "pelletized"? A Yes. And that was what he handled and LUCIA MOSKAL CENTRED shohthano HEPOBTEBS I. 1 generated an aerosol exposure. . 66 2 Q Do you know anything about the actual procedure 3 Mr. Bradley used when handling the pellets from Union 4 Carbide? 5 A I read that he dumped bags of those pellets 6 into a mixture, and then added a large quantity of water 7 and other ingredients and mixed the paint. - 8 Q Do you know anything else in particular about 9 Mr. Bradley's work with the pellets at Standard Brands? 10 A I read that he mixed two batches of paint 11 each day, and that he put 16 bags of pellets into the mixer 12 for each batch. 13 Q Is it your understanding that he introduced 14 the pellets into a container, and then added water onto 15 the pellets? 16 A That was my impression. 17 Q Doctor, do you have any knowledge as to any 18 other products that Mr. Bradley used that contained asbestos 19 other than the pellets that you've referred to? 20 A I do not. 21 Q Do you have any knowledge of any other products 22 that contained asbestos that were used at that plant while 23 Mr. Bradley was employed there? 24 A I do not. 25 Q ' Doctor, is it your opinion that an individual 26 who inhales air that contains less than two fibers per cc 27 of airborne asbestos is at an increased risk of developing 28 medical problems from that exposure? LUCIA MOSKAL CERTfflEO SHORTHAND REPORTERS -- 67 1 MR. GLICKMAN: You're assuming that's what 2 Mr. Bradley inhaled, or are you just asking the general 3 population, because those studies were done under later 4 time conditions when Bradley was not intensively mixing 5 the pellets. I just want to get what your question is. 6 MS. JONES: We have the dates down.' 7 Q What I'm asking for is do you have an opinion 8 as to whether or not an individual exposed to less than 9 two fibers per cc of airborne asbestos will develop medical 10 problems from that exposure? 11 A It's my opinion that exposures at that level 12 are associated with an increased risk of lung cancer, and 13 of mesothelioma. 14 Q Any other illnesses. Doctor? 15 A It would depend on the duration of the 16 exposure. I should have said that even for those two, 17 how high the risk would be for those two diseases. 18 Q Is it correct, then, the longer the duration 19 of exposure, the greater the increased risk of lung cancer 20 and mesothelioma? 21 A I believe so. 22 Q Doctor, can you tell me, is this based on 23 your own studies or studies you have read in journals? 24 A That is based on studies I have read in 25 journals. 26 Q Can you tell me which studies in particular? 27 If you can recall any of them, Doctor. 28 A Can I go to my files? LUCIA MOSKAL CSmOSHTTHw5 c SEPOfiTESS 68 1 G Sure. 2 A Let me set some things aside. These are the 3 documents -- 4 Q Stick those papers over here# if you will# 5 because 1*11 be asking you some questions about them. 6 A Well, I'll start over here. 7 Okay. It would be 4 in this textbook. 8 Q "Occupational Lung Disorders," by W. Raymond 9 Parkes,. P-a-r-k-e-s# Second Edition# at page what#' Doctor, 10 or just generally throughout the text? 11 A There are scattered sections onasbestos and 12 its health consequences. . 13 Q Doctor, can you think of any particular 14 authors that come to mind with regard to responding to 15 that question, that is, what articles or material you've * 16 reviewed on which you base your opinion? Last opinion. 17 Excuse me. 18 A I can think of a teaching material put 19 together by the American College of Radiology that presents 20 a very nice concise review of that. 21 This is an article by Herbert Sideman# published 22 in "Prevention and Detection of Cancer," Part 1, Volume 1, 23 H. E. Neibers, Editor. 24 Q Is that S-i-d-e-m-a-n? 25 A Yes. Marcelle Decker, Incorporated, New York, 26 1977. 27 Q Are there any authors in particular. Doctor, 28 that you rely upon in formulating your opinion that there's LUCIA MOSKAL CsChRoToTRtEmOaw REPORTERS 69 1 increased risk of developing lung cancer, mesothelioma, 2 from exposure to asbestos at that level? 3 A I will have to look. 4 Q Okay. 5 MR. GLICKMAN: I think the record should show that 6 the doctor has pulled out a file drawer full of materials, 7 loose-leaf in nature. It must be six to eight inches 8 thick. Do you want him to look through all that stuff. 9 Counsel? . 10 MS. JONES: I just want an idea of what he's relying v 11 on. I'm sure he's reviewed tons of material. I don't 12 want to know everything he's ever read, certainly. 13 MR. GLICKMAN: Like Dr. Selikoff's book or something 14 like that? 15 Q BY MS. JONES: Doctor, you mentioned earlier 16 an article or publication that was a compilation of various 17 article's. Would the various authors that you are looking 18 for in the material before you be included in that 19 particular publication, teaching material?' 20 A I would have to look at it. 21 Q Okay. Can you tell me, again, the name of 22 that teaching material and where I might locate a copy 23 of it. 24 A Yes, if I can find it. It's in another file. 25 It's in a teaching file. ' 26 Q Is that a dry hole. Doctor? 27 A No, no. I'm going to have to pull the articles 28 that it refers to. It says, "MacDonald, et al.. Nearly  i LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS 70 1 Linear Dose Response Relationship Between Lung Cancer and 2 Cumulative Asbestos Exposure." 3 Neither study demonstrated a threshold dose below 4 which there is no risk. 5 Q ' Can you just give me the citation for each 6 ' of those articles? 7 A I don't have that. Dement, et al., demonstrated 8 approximately a twofold excess risk of lung cancer among 9 chrysotile textile workers after cumulative exposures of 10 27 fiber years. 11 Q ' what is a fiber year,-Doctor? . 12 A It is a year at one fiber per cc. 13 Q . And they're indicating there's an increased 14 risk after 27 fiber'years? 15 A Correct. And that'Study -- there's two 16 JLi. mm pVw nrmf.pnm *r'P "&tr under the name of Dement, and I will have to 17 find those citations. . 18 Q Is that D^-e-m-e^n-t? 19 A Yes, it is. 20 Do you want those citations? 21 Q Yes, Doctor. Thank you. 22 A Dement, J. M., and Harris, R. L.,"Estimates 23 of Pulmonary and Gastrointestinal Deposition for Occupational 24 Fiber Exposures," National Institute for Occupational Safety 25 and Health, NIOSH Publication No. 79-135 -- 26 Q Just a moment. Doctor. Publication No. 79-135? 27 A 1979. 28 The next one is Dement, J. M., Harris, R. L., ' , LUCIA MOSKAL Cht*hed SHQATHANO 71 Symons, M. J., that's S-y-m-o-n-s, et al"Estimates of Dose Response for Respiratory Cancer Among Chrysotile Asbestos Textile Workerspresented at the BOHS Fifth International Symposium on Inhaled Particles, Cardiff, Jm Wales, September 8 to 12, 1980. Q Is that published in a journal. Doctor? A I do not know. And the material that I'm looking at is titled "Teaching Module on Asbestos-Related Disease," developed by the American College of Radiology, supported by National Cancer Institute, and National Institute of Occupational Safety and Health, June 1981. I know that can be obtained through the American College of Radiology. 'Q Thank you, Doctor. Otherwise, I think that's sufficient, otherwise, we'd have to let you' review each of those articles and find the particular ones that you have in mind. Can you tell me whether or not, to your memory -- I won't ask you to review the articles again or hunt for them -- : A May I put these things away? Q Certainly. Can you tell me, again from your memory, whether or not the type of asbestos fiber is important in the development of carcinoma of the lung or -- excuse me -- of the pleura. A I believe it is. Q What is your understanding in that regard? LUCIA MOSKAL CERTIFIED Shorthand REPORTERS 72 1 A May I look? . 2 Q Yes. 3. You're referring now to "Asbestos," by Doll and 4 Peto that we referred to earlier? 5 A Yes. 6 Q It was Publication 3 on thelist. 7 A Okay. The overall view given by Doll and 8 Peto, which is that crocidolite, amosite and anthophyllite 9 all produce cancer of the lung and mesotheliomas of the 10 pleura and peritoneum. They also indicate that similar 11 respirable masses of chrysotile and amosite have been found 12 to be less carcinogenic than crocidolite, while Walton 13 concluded that animal studies point to chrysotile being 14 at least as damaging and possibly more so than crocidolite 15 or amosite at equal respirable mass exposure concentrations 16 and much more damaging for equal amounts retained in the 17 lungs. 18 Q Doctor, can you tell me what page you're 19 reading from. 20 A Page 15. 21 Q Let me interrupt you, if I may. 22 Do you have any knowledge of articles from your 23 reading of the literature that deal with the development 24 of cancer of the colon with regard to the risk associated 25 with different types of asbestos fibers? 26 A Yes. 27 Q Whatarticles would they be? 28 A I have three articles that deal specifically LUCIA MOSKAL CERTIFIED Shorthand REPORTERS 73 1 with chrysotile. 2 Q Can you just tell me which journals they're 3 in, Doctor. 4 A They're all in the"British Journal of Industrial 5 Medicine." . 6 One of them is by A. D. MacDonald, 1984. Another 7 one is by A. D. MacDonald, 1983, and the third is by 8 J. C. MacDonald, 1980. 9 Q Thank you. 10 Doctor, do you know what type of asbestos fiber 11 was contained in the material that was used by Mr. Bradley? 12 A I do not. 13 Q Doctor, do you have any opinion as to whether 14 or not an individual first exposed to asbestos, of whatever 15 type, in 1968, would be likely to develop a carcinoma of 16 the colon, exhibiting symptoms, in other words, in 1977? 17 A I do not have direct information on that topic. 18 However, the studies of lung cancer risk indicate that 19 cases do occur within 10 years after the first exposure 20 for that tumor. 21 Q For what tumor.Doctor? 22 A Lung cancer. 23 Q Are you familiar with any studies whatsoever 24 that have studied the question of latency in colon cancer? 25 A These studies that I have looked at do have 26 some information on that topic. 27 Q Is there, from your reading of the medical 28 literature, an agreement among the medical community as to LUCIA MOSKAL cSeHnOmRTffHeAoND REPORTERS 74 ' 1 the latency period required between first exposure and 2 development of colon cancer? . 3 A I'm not aware of agreement on that topic. 4 Q Do you have any recollection from your reading 5 of the literature of the range of years that different 6 investigators have reported with regard to the latency period, that is, between first exposure to asbestos and 3 development of colon cancer? , 9 A I would say that.the latency issue has not 10 been adequately defined for that tumor site. 11 Q Doctor, in your experience, and based upon 12 your education and your reading of the literature, can 13 you give us an idea of the various types of materials that 14 could cause -- excuse me -- that are linked to colon cancer? 15 In other words, environmental factors, diet, industrial 16 exposures. Can you give us an idea of what those particular 17 elements are. '. 18 A There have been a large number of studies 19 of diet in colon cancer with conflicting results in some 20 areas. 21 To summarize that literature briefly, there appears 22 to be good evidence that dietary fat increases the risk 23 of colon cancer, and that dietary fiber exerts a protective 24 effect. 25 However, the literature on dietary fiber is somewhat 26 less firm than that on fat. 27 There have been other studies that have -- single 28 studies or in some cases a few studies that have shown LUCIA MOSKAL CERTIFIED SRHEPOORRTTHEARNSO 75 * 1 that cruciferous, c-r-u-c-i-f-e-r-o-u-s, vegetables exert 2 a protective effect, that beer increases the risk of rectal 3 cancer, that red meat is associated with colorectal cancer, 4 that I think dietary vitamin intake is associated with 5 a lower risk of colon cancer, that stool bulk is associated 6 with a lower risk of colon cancer. A string of those. To be succinct about it, I think the only ones that 8 look firm are dietary fat associated with an increased g and -fiber with decreased risk. 10 As I mentioned before in our discussion, we have , 11 studied the role of physical activity which shows a clear 12 protective effect, and our study has now been confirmed, - 13 to my knowledge, by four or five other studies around 14 the world. So there's a clear indication that physical 15 activity protects or is associated with lower colon cancer 16 risk. In terms -- 17 Q Doctor, I'm sorry. Go ahead. 18 A In terms of industrial exposures, there have 19 been a few studies that have indicated occupational factors 20 other than asbestos are associated with colon cancer. 21 ' There are a series of studies that have come from 22 the automobile manufacturing industry in which model and 23 patternmakers, who work primarily with hard woods have 24 increased colon cancer risk, and there have been a handful 25 of studies concerning a cluster of colon cancer in a 26 synthetic textile mill in Quebec. But that's not an 27 asbestos mill. That's a mill that makes some sort of 28 synthetic plastic fiber. ` LUCIA MOSKAL CSRHEEPOHORIVRT-HTLEADRNSD 76 1 And to my knowledge, that essentially summarizes 2 the literature.. 3 Q Are you aware of any studies that indicate 4 that any types of heavy metals, for instance, are linked 5 to colon cancer? ' 6 Let me just give you a range of things. Heavy 7 metals, chemicals such as benzene or petroleum 8 distillates -- ' ' 9 A Excuse me. Those are not heavy me'tals. 10 , Q I know. Heavy metal, No. 1, or things like 11 petroleum distillates, or things like chromates. Are there 12 any types of other chemicals or materials that someone 13 would come into contact with in an industrial setting that 14 are linked to colon cancer, to your knowledge? 15 A To my knowledge, there are none that are clearly 16 linked. I can give you a review of the IRAC Monographs 17 within about a minute, if you'd like. 18 Q Sure. 19 A There's a suggested association with cadmium 20 Ora.mHUL /w"ti dsl/U"I tlvIilX*1 1U1 wiui rL'UAlimLipfiUAilnilTl*tU 9c: 21 There are unsubstantiated hints of associations 22 with, tetrachloroethylene and trichloroethylene. 23 There are suggested associations with work in rubber 24 manufacturing. 25 1Q Doctor, what document are you referring to? 26 Thank you. Published in "Cancer Research," Volume 44, 27 starting at Page 2244 through 2250, May 1984. The title is, 28 "Target Organs for Carcinogenicity for Chemicals and LUCIA MOSKAL CERTIFIED SHORTHAND reporters 77 . 1 Industrial Exposures in Humans." A review of the results 2 in the IARC Monographs on the evaluation of the carcinogenic 3 risk to humans. 4 Thank you, Doctor. 5 Doctor, what particular factors that you're aware 6 of in Mr. Bradley's case led you to conclude that his colon cancer was caused by the two factors you mentioned before, 8 age and asbestos? 9 A In terms of age, it's well known, and I could 10 give .you a number of references that would indicate that 11 the risk of colon cancer rises throughout adult life, in 12 males, both in black males and white males, so age clearly 13 influences the risk. I can give you those citations, if 14 you like. 15 Q That's not necessary. Thank you. Doctor. 16 A In terms of asbestos, I think the most -- 17 the two studies that are most convincing in that area are 18 the study by MacDonald, reprinted -- printed in the"British 19 Journal of Industrial Medicine"in 1980, which shows a dose 20 response relationship between asbestos exposure and colon 21 cancer risk, and I'm looking specifically at Table 7D, 22 Table 8, and Table 10, and MacDonald in Table 10 indicates 23 that subjects who have had heavy exposures in excess of 24 a thousand -- their index of exposure is MPCF*years, which 25 is -- I have to go back and look at that -- 26 Q Okay. 27 A -- to be sure I'm stating it properly. 28 I think it's million particles per cubic foot times LUCIA MOSKAL C6RTFIEO SHORTHAND REPORTERS 78 1 years is what they're referring to. The risk is roughly 2 5.3 times that of the lowest exposure group for colon and 3 rectal cancer. 4 Q 1 Excuse me. The subjects with heavy exposures, 5 which is defined as 1,000 MPCF -- 6 A Dot year. 7 Q Do they indicate in the article the length 8 or duration of the exposure that they observed when they 9 calculate this data? . ' 10 A Not in that table, although they do indicate 11 that the exposure was accumulated up to nine years before 12 the death of the case. 13 Q They don't give the total exposure for the 14 population study? 15 Excuse me. The range of exposure for the population 16 studied. 17 A In the table to which I'm referring, they 18 have broken the population down into four exposure groups. 19 Q I see. 20 A And those groups are less than 30 MPCF-year, 21 30 to less than 300, 300 to less than a thousand, and then 22 greater than or equal to a thousand. 23 And what we see is a stepwise increase in risk as 24 exposure increases going from 1 to 5.3. 25 Q Does Mr. Bradley's exposure, in your opinion, 26 fit within any of those four categories of amount of 27 exposure? 28 A I would be speculating if I tried to tell you LUCIA MOSKAL certified SHORTHAND REPORTERS 79 1 what his exposure was. 2 Q Okay. I'll give you a hypothetical. 3 After reviewing his deposition transcript, it's 4 my understanding that Mr. Bradley was exposed to asbestos 5 pellets on the average of dumping 32 50-pound bags into 6 a vat already filled with water, wearing a double paper 7 mask at the time, between the years 1968 and 1972, his 8 first exposure being in 1968. 9 From that information, are you able to reach an 10 opinion as to whether or not his exposure -- excuse me. 11 Let me also add that the vat of water which he was dumping 12 the material into was covered with a covering of some kind. . 13 I don't know if it.was metal or plastic. Had five openings 14 in it. One was for -- two were for rods, the shaft of 15 blades that mixed the material. Two were for ventilation 16 hoses. And one was the opening in which he introduced 17 the material into the water. 18 Does that information assist you in any way in 19 determining whether or not his exposure would come within 20 the four groups that you've referred to in Table 10? 21 MR. GLICKMAN: Just a moment. Before you answer 22 that, I do have an objection to place on the record briefly. 23 MS. JONES: Sure. 24 MR. GLICKMAN: I think you've misstated the record, 25 Counsel, in that Mr. Bradley testified he did not always 26 wear a mask. He seldom wore one. Also, that he would 27 not dump the asbestos into a tank of water. He would dump 28 the asbestos in, then add water, stir it with a paddle LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS . 80 1 without the tank being covered, then add some more asbestos, 2 then add some more water, stirring the mix, that the last 3 batches of these bags would be the hardest to wet, as he 4 described it, and he'd have to stir them vigorously with 5 the paddle, and that the asbestos fibers would be floating 6 around the room like snow, coating his nostrils, hair, 7 clothes, et cetera. . 8 Q BY MS. JONES: Doctor, with the.information 9 that I gave you, if you'll disregard what plaintiff's 10 counsel indicated to you, are you able from that information 11 alone to formulate an opinion as to whether or not 12 Mr. Bradley's exposure comes within any of the four groups 13 that are set forth in Table 10? 14 A No, because -- 15 Q What additional information do you need? 16 A I would like to know the size of the room, 17 what sort of ventilation there was in the room, how many 18 air changes per hour, whether there were other sources 19 of asbestos, the duration of time that the mixing tank 20 was fully generating an aerosol exposure of asbestos. 21 Ideally, I would like to have measurements -- , 22 Q Air sampling measurements? 23 A Measurements of asbestos in the air. 24 Q From the period of '68 to '72, in other words? 25 A Given my professional training, I think it 26 would be speculative for me to try to guess what his exposures 27 were based on that description. 28 Q I understand. Doctor. LUCIA MOSKAL certpcd SHQRTHAN0 REPORTERS : 81 1 I'm sorry. 2 A I did not get a chance to finish my answer 3 to your question some time ago about what evidence or what 4 materials I based my opinion on -- 5 Q You referred to the two MacDonald studies -- 6 I mean the MacDonald study,"British Journal," 1980, which 7 you've just described for us and the three tables. 8 Is there an additional study that you want to indicate, 9 Doctor? ' 10 A Yes. 11 Q Or additional response to that question? 12 A There are other materials -- 13 ,Q Thank you -- 14 A -- that I think are important. 15 Q Okay. 16 A The,Selikoff article published in the New York 17 Academy of Sciences in 1979 also indicates an increased 18 risk of cancer of the colon and rectum with risk increasing 19 with' duration of exposure. 20 When I say that, I'm referring specifically to 21 Table 16, Page 108.. ,' 22 Q Thank you, Doctor. 23 Is there any other article that you would like to 24 reference in response to that question? 25 A Yes. This document -- 26 MS. JONES: Off the record. 27 (A discussion was held off the record.) 28 THE WITNESS: This document -- are we on the record? LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS 82 1 2 3 4 5 6 7 8 9 10 11 12 . 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Q BY MS. JONES: Yes. We're on the record. Thank you. Doctor. A -- which indicates -- . Q That's the rat study we referenced before? A Yes. -- which indicates that rats fed chrysotile asbestos over their entire lifetimes developed adenomatous polyps in the large intestine, and this was viewed by the National Toxicology Program as evidence of carcinogenicity. This study, I should say, contradicts previous studies that I have seen cited that indicate that animal studies show no relationship between asbestos exposure and colon cancer. The last study that I think is worth mentioning to put the issue in perspective -- Q All right. A -- is the Doll and Peto monograph, Table 3/1, which summarizes 16 mortality studies of asbestos workers in which gastrointestinal cancers were studied, and although this table in summary and the accompanying graphs that are derived from it show a relatively weak relationship between colon cancer and asbestos exposure -- or I should say, gastrointestinal tract cancer and asbestos exposure. I think that reviewing the two largest studies in this table, namely, the MacDonald study and the Selikoff studies which I-have reviewed, accounts for a sizable proportion of these total studies, and they have findings that are contrary to this overall LUCIA MOSKAL CCRTFlEO RSEHPOORRTTHEARNSD 83 . 1 opinion. ' 2 The area where I find an inconsistency between the 3 opinion of Drs. Doll and Peto, and the studies on which 4 this monograph is based, is in that misdiagnosis of 5 mesotheliomas could lead to falsely elevated estimates 6 of the number of colon cancer deaths, and the reason I find discrepancy there is the MacDonald study from 1980, 8 wherever I've put it -- 9 Q Right. 10 A -- clearly shows a dose response relationship 11 for colon cancer. This study is based on exposure to 12 chrysotile asbestos, as Drs. Doll and Peto clearly point 13 out, and I agree with them, as far as we know, chrysotile 14 asbestos does not cause peritoneal mesotheliomas, which 15 then makes it extremely unlikely that there would be a 16 misallocation of mesothelioma deaths into the category 17 of colon cancer. 18 So although this point is interesting, I think there's 19 an inconsistency between this conclusion and one of the 20 large studies upon which it's based. 21 Q Doctor, do you have an opinion as to whether 22 or not there is a level at which any individual can be exposed 23 to asbestos without increasing their risk of getting a 24 colon cancer? 25 A From my reading of these studies, there is no 26 direct evidence upon which to base a distinction of that 27 type. ' 28 The evidence regarding lung cancer, in my opinion. LUCIA MOSKAL REPORTERS * _ 84 indicates that there is no such cutoff for lung cancer risk. ' Q Do you believe that the studies that are directed at lung cancer are accurate when evaluating a case of colon cancer? A ' X don't know how to interpret that question. Q Would you rely upon studies -- in other words, in evaluating the Carl Bradley case, a colon cancer case, if you were trying to determine the appropriate latency period or the likely latency period, the dose response relationship, et cetera, would you feel comfortable in relying upon data developed with regard to development of lung cancer from exposure to asbestos? .MR, GLICKMAN: Axe you putting aside everything else he knows? MS. JONES: Yes. THE WITNESS: I thought I understood the question until the last point. Now I'm not sure I do. Q BY MS. JONES: What I'm trying to find out, Doctor, is would you rely upon studies only dealing with lung cancer when you're trying to evaluate a case that is a colon cancer case? A I would rely on a broader knowledge of the mechanisms of carcinogenesis, which indicate to my reading that there is no substance which is known to be carcinogenic for which there is a threshold below which there is no risk. Q That's true of any carcinogen, in your experience? LUCIA MOSKAL CeBTWD Shohthano reporters 85 . A That basic model is assumed by many scientists to be the best representation of the truth for a variety of other carcinogens. And I know of no reason in the case of colon cancer to assume that that model is wrong, Q The model being that there is not, in the vernacular, a safe level; is that correct? A That there is not a level below which there is no,increased risk. Q Doctor, when we've talked about these articles in passing and we've talked about latency period, do you have any opinion as to whether or not an individual exposed in 1968 would, by 1977, develop symptoms which led to the discovery of colon cancer? In other words, it's my understanding that in this case, Mr. Bradley's first exposure was 1968. He started having vomiting and other symptomatic problems in 1977, and he was diagnosed either late '77 or early *78. Is that period of time sufficient, in your opinion, in terms of a latency period for the development of colon cancer from exposure* to asbestos? `, A As we discussed earlier, I think that the latency period for colon cancer in relation to asbestos has not been well worked out. , Q So you would have no opinion in that regard? A Again, I would base my opinion on a broader knowledge of environmental causes of cancer, which indicate that for a number of other agents, latency periods of LUCIA MOSKAL CCBTlRgO SHORTMANO RCPORTERS 86 1 10 years are adequate for cancer to develop in response 2 to exposure, and I would also base it on information that 3 indicates that is also true for lung cancer in relation 4 to asbestos exposure. 5 Q Do you have any opinion as to how long 6 Mr. Bradley would have had the tumor developing before 7 he exhibited symptoms? 8 A That is an extremely difficult question which 9 would -- I would ask you to define what you mean by "the 10 tumor developing." 11 Q In other words, the initiation of the cancerous 12 process in the cecum. Would you expect a tumor to develop 13 within two or three months to the size that it would cause 14 the symptoms that I've described to you, vomiting and so 15 forth, pain in the stomach, or would you expect that type 16 of- symptom to occur after several years of development 17 -of the tumor? 18 A I can't give you an overall answer to that. 19 It would depend on the exact location of the polyp. If 20 the polyp were located so that it interfered with the 21 function of the ileocecal valve, it could be quite small 22 and be symptomatic. 23 Q Do you have a range of years in mind that 24 you would expect between the initiation of the tumor 25 development and the development of the symptoms? 26 A What do you mean by "initiation"? 27 Q By the cells in the cecum starting to multiply 28 inappropriately and develop a tumor. As a layman, that's LUCIA MOSKAL CEffnFES RSEHPOORRTTHEARNSD 87 1 the best I can explain what I'm trying to get at. 2 A That's not what I would call initiation. 3 . Q All right. What is initiation. Doctor? 4 A Initiation in my mind refers to the 5 intracellular process by which DNA is irrevocably changed 6 so that unrestrained growth may be expressed at a future 7 date, and a tumor that -- or I should say a cell that has 8 been changed may then lie dormant for a very long or a 9 very brief period of time before it begins to proliferate. 10 Q Do you have any idea as to how long a tumor 11 in the cecum would develop before the symptoms were 12 exhibited, in other words, the vomiting and stomach pains? 13 A I'm sorry. Say that again, please. 14 0 Yes. Once' the tumor starts to develop, is 15 there any range of time between the beginning of the, 16 development of a tumor and Mr. Bradley's noticing problems 17 with his stomach, vomiting, and so' forth? 18 A And again, what do you mean by "beginning 19 of development"? _ 20 Q Let me back up. Doctor, if I understand you 21 correctly, initiation is when the DNA is altered so that 22 at some future date a tumor will develop, is that correct, 23 may develop? 24 A That's a reasonable approximation. 25 Q I'm now trying to determine when that point 26 in time comes and the tumor starts to develop, a mass starts 27 to. develop in the colon, for instance, in the cecum. Is 28 there a range of time, that is, six months to a year, you LUCIA MOSKAL CCBTFED SHORTHANO REPORTERS 88 1 would expect someone to notice a problem, four to five 2 years you would expect someone to notice a problem, go 3 to a doctor, present the symptoms he has, and then get 4 the appropriate workup? 5 In other words, an individual could have a ' 6 developing tumor and not know it for a while. Am I _ 7 correct in that? 8 A You're correct in that, but to answer your g previous question, I think that that range is highly 10 variable. 11 Q All right. 12 A There are some tumors that are very fast 13 growing, and there are some that are very slow-growing. 14 There are also some patients who are. quite stoical who 15 do not seek help for a long time after they have had a 16 tumor which would be quite symptomatic in rcost people. 17 Q Do you know what type of tumor that Mr. Bradley 18 had? 19 A I believe it was a scirrhous carcinoma. ' 20 Q Is that type of a tumor a fast-growing or 21 slow-growing tumor, if you know? 22 A I don't know offhand. I can look. 23 Q That's all right, Doctor. Thank you. 24 MR. GLICKMAN: It's 1:30. We've, got to be in court 25 by 2:00. What do you propose here. Counsel? 26 MS. JONES: Well, let's go off the record, please. 27 (A discussion was held off the record.) 28 (A brief recess was taken.) LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS 89 (Mr. Casselman no longer present.) 2 MS. JONES: Back on the record, please. 3 Q Doctor, let me just be sure I understand you 4 correctly in the opinion you've expressed and the thoughts 5 you've expressed today. 6 Is it correct that it is your opinion that there 7 is no threshold level below which the risk is not increased 8 for the relationship of exposure to asbestos to development 9 of colon.cancer? ` 10 A . There is no evidence to indicate that is true, 11 and I share the view with many other scientists that -- 12 or I should say I share the assumption with other scientists 13 that there is no threshold below which there is no increased 14 risk. 15 Q Are there any particular studies that deal 16 with colon cancer which support that opinion, that is, 17 studies of duration and amount of exposure to the development 18 of colon cancer? 19 A Exposure to what? 20 Q Asbestos. Excuse me. 21 Let me try again. Doctor. Is there any study that ` 22 deals specifically with the exposure of individuals to 23 asbestos and the development of colon cancer, focusing 24 on the threshold limit, if any? Threshold being a safe 25 limit, in other words. 26 A Are you asking -- I'm not sure what you're 27 asking. I'm having trouble with that. 28 Q' Let me put it this way. upon what do you LUCIA MOSKAL CERTOEO SRHEPOORRTTHEARNSD 90 1 base your opinion, along with other doctors or scientists 2 in the field, that there is no safe limit of exposure to 3 asbestos and the development of colon cancer? 4 A It is based upon the studies that I've cited rJ 5 for you that show a dose response relationship between 6 asbestos exposure and colon cancer risk, and it's based 7' upon an animal model which shows evidence of carcinogenicity 8 of asbestos for colon polyps, and it is based on a wide 9 variety of studies of other tumor sites in relation to 10 other environmental agents which do not show any threshold 11 below which there is no risk. 12 And let me add, and is based on other studies of 13 asbestos exposure in relation to lung cancer, which 14 similarly failed to show a threshold below which there 15 is no increased risk. 16 Q Anything else, Doctor? 17 A I believe that's all. 18 Q Are you familiar with anystudies ofworkers 19 specifically in the paint industry, such as Standard Brands., 20 manufacturing paints, with regard to their mortality rate 21 and the development of cancer? ., 22 A I could pull those out for you. I have some. 23 Q Can you identify them for me, please. 24 Off the record. , 25 (A discussion was held off the record.) 26 MS. JONES: Back on the record, please. 27 Q Doctor, while you're thumbingthrough that, 28 do you recall in what journal or by what agency those LUCIA MOSKAL eenrmeo shorthand REPORTERS ' 91 , 1 studies were done with regard to the paint industry? 2 A Well, I'm trying to find them. I can't cite 3 them until I find them. 4 MS. JONES: Let's go off the record, then, and give 5 the doctor an opportunity to search them out. 6 (A discussion was held off the record.) 7 MS. JONES: Back on the record. 8 Q I'm interested. Doctor, with regard to the 9 development of cancer, yes. 10 MR. GLICKMAN: The doctor asked you off the record, 11 "Do you want cancer mortality?" Now you're saying just 12 development of cancer? 13 MS. JONES: The question originally, Counsel, was 14 with regard to mortality and with the development of cancer. 15 MR. GLICKMAN: Now which do .you want? Both? . 16 MS. JONES: Yes. 17 Q " I am particularly interested in studies with 18 regard to cancer in individuals in that industry, if that 19 clarifies it. 20 Doctor, while you're thumbing through that, let 21 me ask one question that may cut this short. Do you have 22 any recollection of those articles with regard to their 23 findings of the development of cancer in individuals employed 24 in that industry? 25 A I know I have recently seen a mortality study 26 of painters, and I can't put my hands on it right now, and . 27 I do not know what the findings were, but it's in this room. 28 Q Somewhere. LUCIA MOSKAL CERTIFIED SHORTHANO REPORTERS ' 92 1 A I just -- I just can't put my hands on it 2 right now. 3 Q Did you use that particular article in any 4 way in evaluating the Carl Bradley case? 5 A The article that I mentioned I'm aware of 6 and can't find? 7 Q Right. 8 A No. 9 Q Doctor, inevaluating the Carl Bradley case, 10 did you assume that Mr. Bradley had a high fat diet? 11 A I made no assumption about his diet whatsoever. 12 Q Did you make any inquiry with regard to his 13 dietaryhabit s ? 14 A I read the medical records that I was given 15 specifically to find out what his dietary history was, 16 and found no information on that topic. 17 Q Is that, in youropinion, animportant factor 18 in evaluating the Bradley case? 19 A The dietary studies that indicate that fat, 20 dietary fat is a risk factor for colon cancer indicate 21 that the risks are of the order of magnitude of one-and-a22 half to two-and-a-half-fold for dietary fat. 23 Those risks are somewhat weaker than the risks I 24 see for people exposed to asbestos, the risks of colon cancer 25 among people who have been exposed to asbestos. 26 Q Are you saying by your statement -- I don't want 27 to put words in your mouth, but I want to understand your 28 position. Are you saying that because, in your opinion. LUCIA MOSKAL CERTIFIED SRHEPOORRTTHEARNSD ` 93 1 asbestos -- and again based upon the studies you've stated - 2 there's a stronger relationship between exposure to asbestos 3 and development of colon cancer, that the dietary habits of _% _ 4 Mr. Bradley can be ignored? 5 A No. 6 Q Is it correct, then, that both asbestos and a 7 high fat diet# if he' had one, would, in your opinion, 8 contribute to the development of colon cancer? 9 A Yes. If he had a high fat diet, that would 10 increase his risk of colon cancer. 11 Can I continue? 12 Q Certainly. 13 A Given that I have no information on his life 14 style, I chose not to speculate on that issue of what sort 15 of diet he had. If we were going to do that, I would also 16 point out that there is a growing body of evidence that 17 indicates physical activity protects against colon cancer, 18 and that the description of Mr. Bradley's work would lead 19 me to think that he was, in fact, quite physically active 20 on the job, so that he ought to have a lower risk as a 21 result of that factor.. 22 Q That factor taken alone, you mean? 23 A That factor would act to reduce his risk. 24 Q The other two factors increasing his risk 25 could.be a high fat diet and exposure to asbestos; is that 26 correct? 27 A Yes. 28 Q And the factor decreasing his risk, in your LUCIA MOSKAL CEFmFIED SHORTHAND REPORTERS J 94 1 opinion, would be the physical activity? 2 A Yes. 3 Q Are there anyother factors about which you 4 may not have any particular information in this case that 5 you would want to consider for complete evaluation of 6 Mr. Bradley's case? 7 A His dietary fiber intake might also play a 8 role. 9 Q Anything else/ Doctor? 10 A Those are the only knownfactors that play 11 a role in colon cancer. 12 Q Doctor, are you able to say to a high degree 13 of' medical certainty that Mr. Bradley's cancer of the colon 14 was caused'by his exposure to asbestos? . 15 A- Based on the studies that I have cited, including 16 both human evidence and animal evidence, it is my opinion 17 that asbestos increased Mr. Bradley's risk, and that if he 18 had not had exposure to asbestos, he would not have contracted 19 colon cancer at the age he did. 20 Q And it's your opinion that, to a medical 21 certainty, that the latency period, that is, the time between 22 the first exposure in 1968 and development of symptoms in 23 1977, is sufficient for the development of Mr. Bradley's 24 colon cancer? 25 A As we have discussed, I think there is no 26 information in the literature upon which to base that sort 27 of opinion. My opinion is based on analogy to lung cancer 28 in relation to asbestos, which says that is adequate latency. LUCIA MOSKAL CERTIFIED SHORTHAND . REPORTERS 95 . 1 and the relationship between other carcinogens and human 2 cancer which says that 10 years is adequate latency. 3 MR. GLICKMAN: Please mark your notes at this point. 4 Thank you. 5 Q BY MS. JONES: Do you have any knowledge of 6 Mr. Bradley's family history with regard to diseases, diabetes, cancer, anything else? 8 A I recall reading in, I think it was 9 Dr. Monosson's note, a statement that there was no familial 10 incidence of cancer in Mr. Bradley's family. 11 Q Do you have any opinion as to whether or not 12 Mr. Bradley's socioeconomic stratum or status would in 13 any way contribute to development of colon cancer, that 14 is, increase or decrease the risk? 15 A Yes. ' 16 Q What opinion is that? 17 A It's clear in L. A. County that colon cancer 18 risk increases with increasing socioeconomic status. It's 19 a disease primarily of the industrialized world and tends 20 to be more prevalent among the affluent segment of that 21 world. Colon cancer incidence is lower in people who have 22 lower incomes and blue collar jobs than it is in people 23 who have white collar jobs. 24 Based on my knowledge of what his job was, and 25 assuming that he had a socioeconomic status that was 26 determined primarily by his work, he would be at relatively 27 lower risk -- in other words, he would be in a socioeconomic 28 stratum that would have slightly lower risk. LUCIA MOSKAL cerniFED SSPHOOTflTtHEARttSO 96 1 Q That's based upon your study for L- A. County? 2 A That's based upon a review of the Cancer . 3 Surveillance Program -- Cancer Surveillance Project data 4 for Los Angeles County. 5 Q That was the data base you used in one of 6 your studies; is that correct? 7 A Yes. 8 Q Doctor, with regard to colon cancer in the 9 United States, do you know what the incidence is throughout 10 the United States on a yearly basis? 11 A I can look that up. 12 Q Thank you. Would you, please. ,, 13 A Where would you like it? 14 Q I' sorry? 15 A' What part of the country? The whole country? 16 Q Throughout the United States. 17 A What year? 18 Q The most recentinformation you have. 19 A Now, I'll have to ask you exactly what type 20 of data you would like to have. 21 Q Doctor, I'm interested in, first of all -- 22 let me just explain to you the questions I'll be asking, 23 and that may help you to pick from the chart the information 24 that's most applicable. 25 I'm interested in knowing what the incidence of colon 26 cancer is in the United States, and of those persons who 27 were diagnosed with colon cancer, whether or not there 28 are known and unknown causes, and which cause or unknown LUCIA MOSKAL CERTIREO SHORTHAND REPORTERS 97 1 cause is greatest. 2 A Can we start with the first question? 3 Q Sure. 4 A What type of incidence would you like? 5 Q ` What types do you have in your chart. Doctor? 6 A I have age specific. I have age adjusted. 7 And I have cumulative. 8 Q Let's start with cumulative, I guess. With 9 regard to cumulative data -- 10 A Cumulative incidence, age, '85? ' 11 Q Yes. 12 A That will take a little time to find that. 13 Q If that's difficult to find, then can we start 14 with an individual in Mr. Bradley's age group, that is. 15 35 to 45, something like that. 16 A You mean by age specific? 17 Q Yes. 18 A For black males? 19 Q Yes. 20 A Nationwide? 21 Q Yes. Is that easier? 22 A Well, I think I know where that is. 23 ' What age group did you want? 24 Q 35 to 45 or 35 to 40. 25 A I can give you 35 to 39. 26 Q All right. 27 A In 1973 to 1977, age specific incidence per 28 hundred thousand population for black males, for all the LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS 98 1 SEER reporting areas except Puerto Rico, was 3. -- no. 2 I'm sorry. *73 to '77 was 5.1. 3 Q 5.1 represents what, Doctor? ' 4 A The number of incident cases per hundred 5 thousand black males, age 35 to 39, in the cities that 6 were part of the SEER reporting network. 7 Q Is Los Angeles one of the cities in the SEER . 8 reporting network? . 9 A No, it is not. ' 10 Q All right. Then that's not going to help 11 me too much. 12 Do you have any data with regard to Los Angeles 13 specifically, or this geographic area? 14 A No, I can't give you age specific off the 15 top of my head. I could get that, but I don't have that 16 within my reach in this office right now. 17 I can give you age adjusted incident rate per 18 hundred thousand black males in Los Angeles County. 19 Q Fine. We'll go with that, Doctor. 20 A And this is based on 1972 through 1981. 21 Q All right. 22 A And the number would be 21.9 cases per hundred 23 thousand- black males per year. 24 Q Doctor, the chart or the article that you're 25 looking at, does that or does any of the other information 26 you have indicate to you whether or not any of the cases 27 of colon cancer in Los Angeles County, from which that 28 data was taken, are of unknown causes? LUCIA MOSKAL CfiTlFD SRHEPOOflTRWTEARNSO * ' 99 1 A I don't understand the question. 2 Q What I'm trying to find out is, with regard 3 to colon cancer, is it typical for an individual diagnosed 4 with colon cancer to have a known cause of that colon cancer? 5 A What do you mean, is it typical? 6 Q Are most people who are diagnosed with colon 7 cancer in those cases, is it true or not true that there 8 is a known cause for the colon cancer? .9 A The only correct answer to that question is 10 to indicate that there are known causes of colon cancer 11 that we have discussed. 12 Q Right. . 13 A Such as dietary fat, lack of dietary fiber, 14 lack of physical activity, et cetera. And that one could 15 make an estimate of the risk the individual had as a result 16 of the presence or absence of those factors. 17 Q In the reported literature, is it true that 18 most colon cancers are of unknown cause? 19 A I don't know any other way to answer it than 20 the way I just did. To say again, there are factors that 21 clearly increase risk, and there are factors that decrease 22 risk. 23 Q Thank you, doctor. 24 Doctor, would an individual's consumption of alcohol 25 or the rate of consumption have any effect on the development 26 of colon cancer? 27 MR. GLICKMAW: Regardless of the quantities or years 28 consumed? Is that what you mean? LUCIA MOSKAL CSHEROTRITRHEAOND %REPORTERS 100 1 MS- JONES: I'm just asking for a general question 2 right now, and I'll be more specific later. 3 Q Is there any relationship at all, is what 4 I'm asking, with regard to alcohol consumption and 5 development of colon cancer? . 6 A There is no conclusive evidence to indicate 7 that alcohol consumption is a risk factor for colon cancer. 8 Q Are you aware of any studies that suggest 9 such a link? . 10 A Yes. Do you.want me to get them? 11 Q No, not yet. 12 Do you have any knowledge as to Mr. Bradley's 13 usual alcohol consumption, that is, daily intake? 14 A I read in Dr. Monosson's -- I'm not sure whose 15 note it was -- that he consumed about a half a pint of 16 liquor per day on a regular basis, and that he stopped 17 around the time he was diagnosed. 18 Q With regard to the medical literature that 19 suggests such a link, did you take that into consideration 20 in your evaluation of the Carl Bradley case? 21 A I took it into consideration, but my view 22 of the studies, the overall -- the summary of studies of 23 dietary factors is that alcohol does not play a causative 24 role in colon cancer. 25 Q Doctor, in your consideration or your 26 opinion -- I'm sorry -- your evaluation of the Carl Bradley 27 case, would Mr. Bradley's lack of pulmonary indices of 28 asbestos exposure influence your decision as to whether or LUCIA MOSKAL smorthano REPORTERS 101 1 not he developed colon cancer from his exposure to 2 asbestos? - 3 A It's well known that interstitial changes 4 in the lungs are more frequent the more heavily exposed 5 people -- the more heavily exposed a group of people is. 6 However, even among heavily exposed workers, there 7 are still workers who show no evidence of pulmonary change B on their chest x-rays. So it is entirely possible that 9 an individual could have had heavy exposure to asbestos 10 and still not show changes indicative of either pleural 11 thickening or interstitital fibrosis on his chest x-ray, 12 Q Doctor, you' said "entirely possible." Is 13 it probable that that would happen in an individual heavily 14 exposed? . 15 A Within 10 years of exposure, yes, I think 16 it is probable. 17 Q It's probable that an individual with heavy _ 18 exposure would not exhibit fibrosis; is that correct? 19 A Within 10 years of exposure, yes, the majority 20 of people heavily exposed would not show fibrosis within 21 10 years. 22 Q Would the same be true with regard to pleural 23 plaqueing, in your opinion? 24 A I believe that would also be true, the majority 25 would not show evidence of pleural change within 10 years of 26 first exposure. 27 Q Doctor, if I can summarize, just to be sure I 28 understand your position, is it correct to state that, in  # LUCIA MOSKAL CERTIFIED SHORTHANO REPORTERS 102 1 your opinion, an individual with the type of job that 2 Mr. Bradley had, that is, someone who would be physically 3 active as opposed to sitting in a desk, would have a 4 decreased risk of developing a colon cancer? 5 A Compared to whom? 6 Q Good question. With regard -- let me strike 7 the last question and start again. 8 Is it correct there are certain risk factors that 9 should or can be considered when evaluating a person for 10 colon cancer? 11 A Would you restate that question? 12 Q Sure. Are there certain factors in an 13 individual 's life style, employment, et cetera, that may 14 be considered in evaluating the likelihood of an individual 15 developing colon cancer? 16 A Yes. " 17 Q Is exposure to asbestos one of those factors? 18 A Yes. . 19 ' Q Is increased dietary fat one of those factors? 20. A Yes. 21 Q Is physical activity one of those factors? 22 A Yes. 23 Q Is socioeconomic class one of those factors? 24 A Yes. 25 Q Are there any other factors? 26 A Age, sex, race, place of birth. 27 Q Anything else, Doctor? 28 A Place of residence. ' LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS 103 1 Q From your understanding of the literature, 2 .was Mr. Bradley's age an increased or decreased risk or 3 no effect at all with regard to his development of colon 4 cancer? 5 A In comparison to who? 6 Q The general population in Los Angeles. 7 A That question doesn't have any meaning to me. 8 Q What information do you need to respond to 9 that question? Obviously, I'm leaving out some factors 10 that you need to consider. 11 A We usually discuss risk in relation to other 12 people of the same sex, race, and age group. 13 q All right. So, in other words, an individual 14 who is black male of that age, does that assist you in 15 responding to the question? 16 A Yes. And the reason that we discuss that 17 is those are the factors that one cannot change. So it's 18 not a meaningful question to ask whether someone's -- 19 well, I don't remember exactly the form of your question, 20 but without comparing people to people who share those 21 same unalterable risks, the question has no meaning. 22 Q So, then, properly stated, I should have asked 23 you an individual of similar age, the same sex and the 24 same race, is it then correct that that individual exposed 25 to asbestos would have an increased risk of developing 26 colon cancer? 27 A I believe so. Let me state it in my own 28 words'. LUCIA MOSKAL CERTFIED SHORTHAND REPORTERS .. 104 1 Q All right.Thank you. Doctor. 2 A It is correct to think that an individual 3 who was exposed to asbestos would have a higher risk of 4 colon cancer than individuals of the. same sex, race and 5. age who were not exposed to asbestos. 6 Q Thank you. 7 Did Mr. Bradley's place of birth have any effect 8 upon your risk assessment of his developing colon dancer? 9 A ' I don't recall his place of birth offhand. 10 May I look? 11 Q Certainly. 12 (Mr. Casselman enters deposition room.) 13 THE WITNESS: He was born in Missouri. As far as 14 I know, that would not greatly change his risk in comparison 15 to other black males of his age group in the United States. 16 The instance in which place of birth changes risk 17 is when one is born in, for example, a low-risk country, 18 one tends to maintain that low-risk for some decades. So, 19 for example, people born in Central America have lower 20 risk of colon cancer than people born in this country who 21 are of the same ethnic origin. That appears not to be 22 important in this case. 23 Q BY MS. JONES: Was his place of residence ' 24 of importance in assessing the risk to Mr. Bradley of 25 developing colon cancer? In other words, the fact that 26 he resided in the Los Angeles area. 27 A My recollection is that colon cancer rates ' 28 for Los Angeles County are not markedly different than . LUCIA MOSKAL CERTOEO SHORTHAND REPORTERS 105 .1 those of the rest of the United States, and if that is 2 true, as I believe it is, then his place of residence did 3 not alter his risk in comparison to the rest of the United 4 States black male population. 5 If we need to document that Los Angeles County 6 incidence rates for colon cancer are similar to those of 7 the rest of the United States, we could do that. I am 8 working on recollection. I'm sure there are small 9 differences, but I think they are very small. ' 10 Q Would the mere fact that Mr. Bradley was a 11 man rather than a woman affect his risk of developing colon 12 cancer? . , 13 A As you and I discussed about 10 minutes ago, 14 yes, but the only valid comparison is to compare him to 15 other men in terms of risk. We don't usually compare 16 people who have unalterable risk factors, because those 17 comparisons have no meaning, 18 Q The same question, Doctor, with regard to 19 his race. Does the fact that he was black rather than 20 some other race alter his risk of developing colon cancer? 21 A . And my question would be, then, in relation 22 to whom? 23 Q To males of a similar age. 24 A In fact, my recollection is that based on 25 the SEER data that I looked at before, the rates for black 26 males are virtually identical to the rates for white males 27 in his age group. ^ 28 Q Doctor, have you ever done any consultation LUCIA MOSKAL cemnED SHORTHAND reporters 106 1 work with other doctors or investigators at this university 2 with regard to asbestos materials and exposure to asbestos? 3 A I'm not sure exactly what you're asking. 4 Q Have you ever done any studies with other 5 individuals at this university with regard to development 6 of diseases in individuals who have been exposed to 7 asbestos? 8 A We discussed at the start of this deposition 9 all the studies I have done that have any relationship 10 to asbestos. 11 Q And there's nothing else that you need to 12 add to that at this time; is that correct? 13 A None that -1 can recall. 14 Q Doctor, do you feel that you have sufficient 15 information from the material that you were supplied and 16 that we reviewed on Mr. Bradley in particular to express 17 an opinion with medical certainty that his colon cancer 18 resulted from exposure to asbestos? 19 A Based on the records that I was given regarding 20 Mr. Bradley specifically, and the medical literature that 21 I reviewed, it's my opinion that had Mr. Bradley not been 22 exposed to asbestos, he would not have developed colon cancer 23 at the age he did. 24 Q Is there any additional information that you 25 would prefer to have in assessing this case? In other 26 words, to make you feel more sure about your opinion, a 27 stronger foundation, in other words. Is there any 28 additional data you would want to have? LUCIA MOSKAL CERTIFIED Shorthand REPORTERS 107 1 A I would like very much to have specific 2 measurements of exposures that accurately represented 3 Mr. Bradley's asbestos exposure. 4 Q What would his levels of exposure tell you 5 with regard to his risk of developing colon cancer? 6 A They would allow me to make a more precise estimate of his risk by using the medical literature that 8 we have already discussed. 9 Q Doctor, from the information that you have, 10 you said that he did have an increased risk; is that 11 correct? ` . 12 A I believe so. 13 Q . What exactly was that risk, if you can tell 14 us? Can you quantify it for us? 15 A Without knowing his exact exposure history, 16 I can give you a range. 17 Q All right. And you are referring now to what 18 article. Doctor? 19 A I'm referring to the MacDonald article in 20 the"British Journal of Industrial Medicine"in 1980. 21 Q Thank you, Doctor. 22 A That article leads me to believe that the 23 upper limit of his risk would not exceed fivefold above 24 that of the nonexposed population. 25 I said that awkwardly. Would not exceed five times 26 that of the nonexposed population. 27 Q All right. 28 A It would be speculative for me to say how LUCIA MOSKAL CERTFED SHORTHAND REPORTERS 108 1 small the lower limit of the increased risk might be 2 without knowing his exposure. His risk is somewhere between 3 1 and 5. 4 And if I were to assume that he had exposure 5 equivalent to the heavily exposed workers in this MacDonald 6 study I previously cited, his risk would be fivefold. 7 Q Okay. Thank you. Doctor. I have no further 8 questions. 9 Counsel, do you have something? 10 MR. CASSELMAN: In light of the hour, and under 11 the circumstances, I don't. I may reserve that right if 12. counsel will allow it later, but we have to be in court, 13 and I don't think I have much choice. 14 MR. GLICKMANi I don't think there's any choice. 15 It's now 2:25. This was estimated to be a two-hour depo, 16 100CUvsIU TX Klida.tVtfti#i tIviUr"\ tvtjUi c Q +L" XT /U'AUficoa * 17 MS. JONES: Excuse me. You estimated two hours. 18 MR. GLICKMAN: I told Joe Bogan that yesterday. 19 I told you that this morning. . 20 MS. JONES: Right. A little bit late. Counselor. 21 I appreciate your estimate, but having never met Dr. Garabrant 22 before, there are a lot of questions I asked him that I would 23 not necessarily have to go into if I ever depose him again. 24 Thank goodness; right? 25 Counsel, you do have a few minutes. Is there anything 26 you want to ask? 27 MR. CASSELMAN: I do, but there's no point in getting 28 started for three minutes, literally. LUCIA MOSKAL CERTFIEO SHORTMANO REPORTERS 109 1 MS. JONES: Anything else. Counselor, Mr. Glickman? 2 MR. GLICKMAN: No. I want to put something on the 3 record about the doctor's signature, and I assume you're 4 going to have this transcript expedited since we may start 5 trial tomorrow? 6 MS. JONES: Yes. Those assumptions are all correct. 7 I'd like to propose the following stipulation, that the 8 reporter be relieved of her duties as follows: That she 9 will prepare the original transcript and forward it -- 10 do you want to waive signature on this, or do you want 11 him to review it? 12 MR. GLICKMAN: Well, I think the doctor would be 13 entitled to review and correct and sign under penalty of 14 perjury his transcript. 15 MS. JONES: I'll leave it up to you. 16 THE WITNESS: I'd like to read it. 17 MS. JONES: All right. Fine. Once the reporter 18 has prepared it, she will forward it, I guess by messenger 19 to the doctor, who can review it, make any corrections 20 that are necessary, and sign it under penalty of perjury. 21 Off the record. 22 (A discussion was held off the record.) 23 MS. JONES: Can you give me an estimate of how much 24 time you need to review it? 25 MR. GLICKMAN: Keep in mind he's never had his 26 deposition taken before. 27 THE WITNESS: How thick will that be is more the 28 issue. LUCIA MOSKAL eewrweo EPCRTEft$ 110 1 MR. GLICKMAN: About as thick as that. 2 THE WITNESS:. The typing is bigger, I know. 3 MS. JONES: It reads easily. Doctor. 4 MR. GLICKMAN: It does read easily. . 5 THE WITNESS: You probably know more than I about 6 that. I would think a couple of hours to read through 7 it if I have to do it carefully. Is that -- 8 MS. JONES: Sure. 9 THE WITNESS: -- a reasonable number? 10 MR. GLICKMAN: I think you need a couple days, 11 because you won't be able to do it continuously. What 12 do you think, Dave? 13 THE WITNESS: You meant over what period of time 14 could I complete it? 15 MS. JONES: Sure. 16 THE WITNESS: Not how many hours would it take me 17 to do it? 18 MR. GLICKMAN: I think he needs a couple days* time, 19 at least. 20 THE WITNESS: I'm going out of town on Friday. 21 MS. JONES: All right. Then we have to have it 22 done before Friday. 23 THE WITNESS: Okay. I'll have it for you Friday 24 if I have it tomorrow. 25 MS. JONES: Off the record, please. 26 {A discussion was held off the record.) 27 MS. JONES: The doctor has indicated that he'll 28 do his best to have this document reviewed, completely reviewed LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS 111 ' 1 and signed under penalty of perjury by Wednesday afternoon. 2 THE WITNESS: Thursday afternoon. ' 3 MS. JONES: I'm sorry. Thursday afternoon. Pardon 4 me. Today is Tuesday. The transcript will be delivered 5 to you sometime tomorrow afternoon -- 6 MR. GLICKMAN: What do you want him to do with the 7 original? 8 MS. JONES: which is Wednesday, and then hopefully 9 you'll be able to complete your review, make any corrections 10 that are necessary, and sign under penalty of perjury by 11 Thursday .afternoon, and you can contact the reporter's 12 office -- do you want to keep the original, or do you want 13 to have it returned to the reporter? 14 MR. GLICKMAN: The reporter. 15 MS. JONES: Then the reporter will retrieve it and 16 keep custody of the original, so if you'll just call her, 17 and her number and so forth will be on the transcript, 18 and you won't have any difficulty finding that. 19 Let's see. What did I forget? His fee is $250 20 an hour. 21 MR. GLICKMAN: What do you think would be fair, 22 considering it's now 2:30? You cut into his schedule. 23 MS. JONES: There is something else to add -- 24 MR. GLICKMAN: What do you think would be fair, 25 Doctor? 26 THE WITNESS: I think 1,250. 27 MS. JONES: There's something else to add -- let 28 me stop and think -- to the stipulation. LUCIA MOSKAL CERTIFCD SRhEPOORRThTEaRnSO ' ' 112 ' 1 The reporter, after receiving the original transcript, 2 will then notify all parties of any changes made by the 3 doctor. 4 Off the record. 5, (A discussion was held off the record.) . 6 MS. JONES: And that will also be completed within 7 24 hours of receipt by the reporter of the original 8 transcript. ,* 9 - MR. GLICKMAN: How about the final stipulation? 10 If for some reason the trial starts -- 11 MS. JONES: Well, it will definitely start. We 12 know that. 13 MR. GLICKMAN: -- and it's not signed and corrected, 14 that either party can use a certified copy in lieu of the 15 original as if it had been signed and corrected? 16 MS. JONES: Sure. . 17 MR. GLICKMAN: Is that okay, Dave? 18 MR. CASSELMAN: Yes. 19 MS. JONES: One final one. If the original for 20 any reason is lost, a certified copy can be used as though 21 it were the original. 22 MR. CASSELMAN: So stipulated. 23 MR. GLICKMAN: Sure. 24 {A discussion was held off the record.) 25 MS. JONES: Doctor, you can put this on the record. 26 If for any reason I cannot locate those articles that you 27 have used, I'll let you know, and if it's a substantial 28 amount, we'll have a copy service come over and copy them. LUCIA MOSKAL CERTIFIED SHORTHAND REPORTERS 113 So if you'll just keep them all in the same group, then the copy service will know what to copy. THE WITNESS: I will do that. MS. JONES: Thank you very much. (The deposition concluded at 2:30 P.M.) I declare under penalty of perjury under the laws of the State of California that the foregoing 113 (one-hundred, thirteen) pages are true and correct. Executed this ___ day_ of 1986, at , California. DAVID H. GARABRANT, M.D. LUCIA MOSKAL cenrrco SHORTHAND REPORTERS 114 2 STATE OF CALIFORNIA ) SS 3 4 I, Lucia Moskal, CSR 1222 , 5 a notary public in and for the State of California, do 6 hereby certify: 7 That prior to being examined, David H._________ 8 Garabrant, M.D., the witness named in the foregoing 9 deposition, was by me duly sworn to testify the truth, 10 the whole truth, and nothing but the truth; 11 That said deposition was taken down by me in 12 shorthand at the time and place herein named and was 13 thereafter transcribed into typewriting under my 14 direction, said transcript being a true and correct copy 15 of my shorthand notes. i 16 JL UIJL VhkcSJL Im,JL JLJjt IrJllcnLt JJtCtVJL14 a*JLtUSSSk V# JLIl 17 outcome of this action. 18 19 WITNESS my hand and seal -this day 20 of October, 1986 21 22 23 24 25 26 27 28 A. Personal Information: Name in Full Business Address Business Phone Home Address Home Phone Date of Birth Place of Birth Citizenship Marital Status Spouse's First Name Children , Social Security Number B. Education: High School College Medical School Internship Residencies Fellowship Public Health School Honors and Awards CURRICULUM VITAE August 1986 David Hay Garabrant, M.D., M.P.H., M.S. Department of Preventive Medicine University of Southern California School of Medicine 2025 Zonal Avenue PMB B-306 Los Angeles, CA 90033 (213) 224-7355 1880 Carlisle Drive San Marino, CA 91108 (818) 308-2071 June 22, 1950 Newark, NJ U.S.A. Married Janet Matthew, Alice 157-42-4991 Westfield High School, 1968 Tufts College, B.S., Chemical Engineering 1972, Medford, MA ` .' .Tufts University School of Medicine, M.D., 1976, Boston, MA Georgetown University Hospital, July 1976 - June 1977, Medical Intern Harvard School of Public Health, September 1978 - June 1980, Occupational Medicine University Hospital, Boston University Medical Center, July 1980 - June 1981, Internal Medicine Georgetown University Hospital, September 1977 June 1978, Internal Medicine, Ambulatory Care Harvard School of Public Health, M.P.H., 1979 Harvard School of Public Health, M.S., Physiology (Occupational Medicine), 1980 Awarded Training Grant for Study and Research in Occupational Medicine from the National Institute for Occupational Safety and Health, 1978, renewed 1979 Awarded a seat on the Tufts Medical School Admissions Committee, 1975 Graduated Magna Cum Laude, Tufts College, . 1972 Tau Beta Pi Engineering Honor Society, 1971 ' kJu'-firS-M.. -tfTK /U. /? Curriculum Vitae David H. Garabrant, M.D., M.S. Page 2 Licensure Board Certification District of Columbia, 1978, (Certificate 10775) Maryland, 1977, (Certificate - B-20626) Massachusetts, 1978, (Certificate - 42987) California, 1982, (Certificate -- G--47344) Internal Medicine, 1981 Preventive Medicine, 1982 Subspecialty certification in Occupational Medicine, 1982 C. Professional Background: Academic Appointments Assistant Professor, University of Southern California School of Medicine, 1981present Teaching Assistant in Medicine, Boston University School of Medicine, 1980-81 Specific Teaching Responsibilities Graduate Level Courses Introduction to Clinical Medicine, Year IX. University of Southern California School of Medicine. 1981-1983 Preventive Medicine 563. Occupational Medicine Administration (taught during Spring semester to residents in Occupational Medicine, USC School of Medicine, 1984-1986) Preventive Medicine 561. Basic Problems in Occupational Health (taught during fall semester to residents in Occupational Medicine, USC School of Medicine, 1984-86) . Family and Preventive Medicine, Year 1 Medical School Curriculum, lectures on occupational cancer, heavy metals toxicity, biologic monitoring (taught every year, USC School of Medicine, 1981-1986) Year 3 Medical School Curriculum, Review of Basic Sciences. Review of Occupational Health (taught at USC School of Medicine, 1984-1985) Invited lecturer, USC School of Public Administration, graduate course on Health in the Workplace. Lecture topic: Legal and Ethical Issues regarding Occupational Safety and Health, 1985-86 Invited lecturer, USC Institute of Safety and Systems Management. Course on Industrial Safety. Lecture topic: Health Hazards in the Petroleum . Industry, 1985 Curriculum Vitae David H. Garabrant, M.D., M.P.H., M.S. Page 3 Graduate Student Committees MS Thesis Chairman - Melody Kawamoto; Respiratory effects of cotton dust exposure in the cotton garnetting industry (USC, 1985) MS Thesis Committee Member- Jonathan Bernstein - in progress John Barone - in progress Clinical Teaching Director, Occupational Medicine clinical rotations for residents in Occupational Medicine, USC School of Medicine. (Taught and supervised clinical activities of residents at Huntington Memorial Hospital Center for Occupational Health and at Barlow Hospital, 1983-86) Director, clinical rotation with Cal/OSHA for Occupational Medicine residents, USC School of Medicine. Supervised field rotation in which residents worked with Medical Unit of Cal/OSHA in enforcement activities of occupational safety and health statutes, 1984-1986 . ' Post-graduate Courses Program Chairman. 29th Annual Western Occupational Health Conference. Western Occupational Medical Association. Irvine, CA, 1985 Program Committee Member. American Occupational Medical Association Annual Meeting. Los Angeles, CA,. 1984 ' Seminar Faculty Member. Epidemiology for the Occupational Medicine Physician. American Occupational Medical Association. Los Angeles, CA, 1984 Seminar-Faculty Member. Toxicology. Quality Care in the Workers' Compensation system. Post graduate course sponsored by the State of California, Division . of Industrial Accidents Workers' Compensation Appeals Board and USC School of Medicine. Los Angeles, CA, 1985 Seminar Faculty Member. American Occupational Medical Association Basic Curriculum in Occupational Medicine. Denver, CO, 1984 Occupational Epidemiology Forum, held 3 times a year jointly by Occupational Medicine Departments at USC, UCLA, and Irvine. 1981-1986 Service University Service Member, USC Comprehensive Cancer center 1984-present Representative Alternate, Medical Faculty Assembly 1985-present Representative Alternate, Ye'ar 1 Curriculum Committee, School of Medicine, 1986. Reviewer, Scientific Proposals to USC faculty innovation Award, 1986- Curriculum Vitae David H. Garabrant, M.D., M.P.H., M.S. Page 4 Departmental Committee (Preventive Medicine) Director, Medical Practice Plan Committee, 1983--1985 Secretary, Family and Preventive Medicine Associates (medical practice plan for Departments of Family and Preventive Medicine), 1985-present Search Committee, 2 biostatistics faculty, (tenure track), 1984-1985 Service to Outside Institutions Teaching of UCLA and UC, Irvine graduate students. Teach topics in cancer epidemiology, heavy metals toxicity, neurobehavioral effects of solvents, occupational lung disease, introduction to occupational medicine, 1981-1986 Chairman, Committee on Occupational and Environmental Health, American Lung Association of Los Angeles County, 1984-1985 Reviewer, Occasional Scientific Manuscripts Journal of the National Cancer Institute Cancer Research Specific Administrative Responsibilities - Member, Education and Clinical Care Committee, University Hospital, 1980-81 Coordinator of Medical Practice Plan for Departments of Pediatrics, Family Medicine and Preventive Medicine, 1982-1986 Year I Curriculum Committee, 1986- . Military Service None . Other Employment or Activity Staff Physician, Occupational Medical Clinic, Norfolk County Hospital, Braintree, MA 1979-80 Staff Physician, Boston Edison, Co., Boston, MA, 1979-80 D. Society Memberships: American Occupational Medical Association 1982-present - elected to fellowship, 1986 . American College of Physicians, 1980-present American College of Preventive Medicine, 1985-present - elected to fellowship, 1986 American Academy of Occupational Medicine, 1985-present Western Occupational Medical Association, 1982-present Offices in Professional Societies Western Occupational Medical Association - Board of Directors, 1984-present American Occupational Medical Association - member, Occupational Surveillance Committee, ' 1986-present Curriculum Vitae David H. Garabrant, M.D., M.P.H., M.S. Page 5 Consultantships State of California, Division of Industrial Relations, Occupational Safety and Health Administration (CAL/OSHA), Medical Unit, 1984-present Community Service (volunteer) American Lung Associaton of Los Angeles County. Service on Community Eduation Committee, Occupational and Environmental Health Committee, 1983-1986 Los Angeles Coalition for Occupational Safety and Health. Service on Health Technical Committee, 1982-1985 Pasadena Dispensary. Presentation to the Board of Directors on occupational health in the community, 1983 Mastectomy Recovery Plus. Educational seminar on breast cancer epidemiology, 1985 . Cancer Information Service of California. Educational seminar on cancer etiology and epidemiology, 1985 . International Association of Scenic and Title Artists Local 866. Presentation on health hazards to artists, 1984 E. Research Activities: Major Areas of Research Interest Occupational Cancer Epidemiology - occupational factors in central nervous systems tumors - methodology for using cancer registry data for defining occupational cancer risks - gastrointestinal cancer and occupational factors. Studies of occupational factors in cancer of the esophogus, stomach and colon Epidemiology of Occupational Pulmonary Disease - bronchoconstrictive effects of formaldehyde, cotton dust, methylmethacrylate Research in Progress Occupational factors in colorectal cancer. , Central nervous system cancer in the aerospace industry. Reactive airway disease among manicurists exposed to methyl methacrylate. Research Grants in Past Five years As principal investigator 1. American Lung Association/078082/Respiratory Disease in Borax Workers/DH Garabrant/$28,810/11-1-82 through 10-31-83. 2. Rohr Industries/Mortality Study of Aircraft Manufacturing Employees/DH Garabrant/$103,781/2-1-84 through 1-30-86. 3. State of California/44404118/Study of Pulmonary Function in Cotton Garnetters/DH Garabrant/$9985/4-4-85 through 10-30-85. 4. NCI/K04 CA01155-Q1 - Research Career Development Award/Occupational Factors in Cancer Etiology/DH Garabrant/$49,840 (annually)/4-1-87 through 3-30-92/ priority score 145, funds pending. Curriculum Vitae David H. Garabrant, M.D., M.P.H., M.S. Page 6 As co-principal investigator/co-investigator 1. Union Oil Company/Mortality Study of Geothermal Workers Exosed to Arsenic/JM . Peters/$7926/4-l-82 through 3-31-83. 2. NIOSH/#210-81-5014/Health Hazard Evaluation of US Borax, Boron, California/ JM Peters/$98098/10-1-81 through 3-31-83. 3. NIOSH/UC Irvine ERC Subcontract/Residency Program in Occupational Medicine/ JM Peters /$90,89G (annually)/7-l-84 through 6-30-89. ' ' 4, NCI/CA36501/Case-Control Study of Colon Carcinoma/RK Peters/8178458 (annually)/7--1--84 through 6-30-89. ' 5. NCI/CA17054/USC Cancer Center Epidemiology and Biostatistics Unit/Brian . Henderson/$l,37Q,281 (annually)/1-1-75 through 3-31-87. 6. ACS/S1G 2/Cancer Cause and Prevention Research/BE Henderson/?1,000,000/ 1-1-81 through 12-31-85. Curriculum Vitae David H. Garabrant, M.D., M.S Page 7 Bibliography Full Length papers in Peer-Reviewed Journals 1. Peters JM, Wright WE, Garabrant DH, Occupational1 epidemiology: detection of cancer in the workplace. West J Med 1962; 137:555-559. 2. Bernstein RS, Sorenson WG, Garabrant DH, Reaux I, Keough B, Hunninghake G, Treitman M. Exposures to respirable airborne penlcillium from a contaminated ventilation system: clinical, environmental, and epidemiological aspects. Am Indus Hygiene Assoc J 1983; 44:161-169. 3. Garabrant DH, Peters JM, Bernstein L, Mack TM. Job activity and colon cancer - risk. Am J Epidemiol 1984; 119:1005-1014. 4. Garabrant DH, Peters JM, Bernstein L, Smith T, Wright WE. Respiratory and eye irritation from boron oxide and boric acid dusts. J Occup Med 1984; 26:584-586. 5. Garabrant DH, Wegman DH. Cancer mortality among shoe and leather workers in Massachusetts. Am J Indust Med 1984; 5:303-314. 6. Garabrant DH, Peters JM, Bernstein L, Smith T, Wright WE. Respiratory effects of borax dust. Brit J Indust Med 1985; 42:831-837. 7. Garabrant DH. Dermatitis to an aziridine hardening agent used in water based printing ink. Contact Dermatitis 1985; 12:209-212. 8. Peters JM, Garabrant DH, Wright WE, Bernstein L, Mack TM. Uses of a cancer registry to assess occupational cancer risks. National Cancer Institute Monograph 1985; 69:157-161. 9. Osorio AM, Bernstsin L, Garabrant DH, Peters JM. Investigation of lung cancer among female cosmetologists. J Occup Med 1986; 28:291-295. 10, Froines JR, Garabrant DH. Quantitative evaluation of manicurists exposure to methyl, ethyl, and isobutyl methacrylate during production of synthetic fingernails. App Indust Hyg 1986; 1:70-74. Papers Submitted ' 1. Wright W, Bernstein L, Peters JM, Garabrant DH, Mack TM. Adenocarcinoma of the stomach and exposure to occupational particulates. 2. Garabrant DH, Fine U, Oliver C, Bernstein L, Peters JM. Abnormalities of pulmonary function and pleural disease among titanium metal production workers. 3. Kawamoto MM, Garabrant DH, Balmes JR, Dlmlck JR, Simonowitz JA, Held J, Bernstein L. Respiratory effects of cotton dust exposure in the cotton garnetting industry. Curriculum Vitae David H. Garabrant, H.D., M.S. Page 8 Papers in Preparation 1. Uba G, Pachorek D, Bernstein J, Garabrant DH, Wright WE, Balmes JR. Acute respiratory effects of formaldehyde exposure in anatomy laboratory. 2. Garabrant DH, Held JH, Langholz B, Bernstein L. Mortality study of aircraft manufacturing workers. 3. Garabrant DH, Bernstein L, Held JH, Peters JM. Case-control study of central nervous system tumors among workers in the aircraft industry. 4. Garabrant DH, Froines JR. Acute pulmonary irritation due to methylmethacrylate vapor. 5. Barone JA, Peters JM, Garabrant DH. Cigarette smoking as a factor in noise induced hearing loss. 6. Peters. JM, Garabrant DH. Carcinogenicity of trichloroethylene: a critical appraisal. Chapter 1. Garabrant DH, Olin R. Carcinogens and cancer risks in the microelectronics industry. In: LaDou J (ed), State of the Art Reviews; Occupational Medicine. Vol 1, No 1, January-March, 1986. Hanley and Belfus, Inc, Philadelphia, pp 119-134. Miscellany ' 1. Mosely C, Garabrant D, Fine L. Health Evaluation Report 79-17-751, RMI Metals Reduction Plant. U.S. Department of Health and Human Services, Center for Disease Control, National Institute for Occupational Safety and Health, Cincinnati, OH, 1979. 2. Garabrant DH, Peters JM, Bernstein E, Smith T, Wright WE. US Borax and Chemical Corporation, Boron, California: Health Hazard Evaluation. . Final Report. National Institute of Occupational Safety and Health, Cincinnati, OH, 1983. 3. Kawamoto MM, Garabrant DH, Balmes JR, Dimick JR, Simonowitz JA, Held J, Bernstein L. Respiratory effects of cotton dust exposure in the cotton gametting industry. I. Epidemiological study. Health Hazard Evaluation. Special Studies Unit, Division of Occupational Safety and Health, Department of Industrial Relations, State of California, Sacramento, GA, 1985. Papers Presented at Scientific Meetings (contributed) 1. "Pulmonary disease in borax workers." Annual meeting of the Western Occupational Medical Association, San Francisco, CA, 1982. 2. "Respiratory symptoms from borax and boric acid aerosols." 4th Annual Rocky Mountain Conference on Occupational and Environmental Health. Park City, UT, 1982. Curriculum Vitae Page 9 David H. Garabrant, M.D., M.P.H., M.S 3. "Occupational cancer". American Occupational Medical. Association Annual meeting. Los Angeles, CA, 1984. - 4. "Epidemiology of occupational cancer". Stanford University - Western Occupational Medical Association Conference, Palo Alto, CA, 1985. 5. "Cancer mortality in the aircraft manufacturing industry." V International Symposium, Epidemiology in Occupational Health. Los Angeles, CA, 1986. Invited Papers and Seminars . 1. "Colon Cancer and Job Activity". Invited Paper at Occupational Epidemiology Forum, sponsored by USC, UCLA, and UC Irvine Schools of Medicine. Irvine, CA, 1983. . 2. "Respiratory Effects of Borax Dust". Invited Paper at Occupational Epidemiology Forum, sponsored by USC, UCLA, and UC Irvine Schools- of Medicine, Irvine, CA, 1984. 3. Panel Chairman. "Health Issues for Women in the Workplace". Annual Scientific Meeting, American Occupational Medical Association, Los Angeles, CA, 1984. 4. "Occupational Cancer". Postgraduate Education Conference at the American Occupational Medical Association Basic Curriculum Course, Salt Lake City, UT, 1984. . 5* "Contact Dermatitis from Aziridine Hardener In Printing Ink". Invited Paper at Occupational Epidemiology.Forum, sponsored by USC, UCLA, and UC Irvine Schools of Medicine, Irvine, CA, 1985. ,, 6. "Epidemiology for the Occupational Physician", Postgraduate Education Conference at the Annual Scientific Meeting, American Occupational Medical Association, Los Angeles, CA, 1984. 7. "Cancer Mortality in the Aircraft Manufacturing Industry". Invited Paper at Occupational Epidemiology Forum, sponsored by USC, UCLA, and UC Irvine Schools of Medicine, Irvine, CA, 1986, 8. . "Toxicology". Workshop on evaluation of workers compensation patients exposed to hazardous chemicals. Postgraduate Education Conference. /Presented by the State of California Division of Industrial Accidents and USC School of Medicine, Los Angeles, CA, 1985. .