Document KR63pnmDkVJ9y91YnO97ZDY9w
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that, when used in an ordinary and foreseeable manner, would have presented a significant
potential for exposure. See also response to Interrogatory 43.
Notwithstanding the evidence that the axle products did not need a warning relating
to asbestos, in response to customer inquiry and/or a growing awareness of the hazards of
friable asbestos, as of approximately January 1985, axle assemblies manufactured by Off-
Highway Products and Trailer Axle Products that were dressed with brakes made with
asbestos may have been accompanied by tags that measured 5" by 7", printed with black text
on a yellow background, and bearing, in pertinent part, the following text:
"CAUTION
ASBESTOS BRAKE LININGS CONTAIN ASBESTOS FIBERS.
BREATHING ASBESTOS DUST MAY BE HAZARDOUS TO YOUR HEALTH AND MAY CAUSE SERIOUS RESPIRATORY OR OTHER BODILY HARM.
AVOID CREATING DUST-
DO NOT REMOVE BRAKE DRUM WITHOUT PROPER PROTECTIVE EQUIPMENT.
DO NOT WORK ON BRAKE LININGS WITHOUT PROPER PROTECTIVE EQUIPMENT.
DO NOT REPLACE BRAKE LININGS WITHOUT PROPER PROTECTIVE EQUIPMENT.
DO NOT ATTEMPT TO SAND, GRIND, CHISEL, FILE, HAMMER OR ALTER BRAKE LININGS IN ANY MANNER WITHOUT PROPER PROTECTIVE EQUIPMENT.
FOLLOW O.S.H.A. STANDARDS FOR PROPER PROTECTIVE DEVICES TO BE USED WHEN WORKING WITH ASBESTOS MATERIALS."
EYLROYSTER
VOEUKER &ALLEN
In addition, with respect to Off-Highway Products, Defendant made available instruction manuals and other information for each off-highway axle. These materials may
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have contained the following or similar language: