Document M43694a0JY5Nkvavzj6QaVnby

EDWARD H. GREEN* MICHAEL R. MCGQWN* MITCHELL A. TOUPS* DAVID L. TOLIN** R. LYN STEVENS JOHN R. OQLEZAL NICHOLAS 8. BALDO ZONA JONES MICHAEL R. WALZEL B ADAM TERRELL MICHAEL K. ROSE ELLEN G. LAMAR WELLER & GREEN, L.L.P ATTORNEYS AT LAW FIFTH FLOOR PETROLEUM TOWER SSO FANNIN STREET BEAUMONT, TEXA8 77701 May 21, 1993 MAILING ADDRESS: P.O. BOX 3SO BEAUMONT, TEXAS 77704-0350 TELEPHONE: (409) 838-0101 TELECOPIER: (409) 838-6780 GEORGE A. WELLER (1911-1986) "UCKNSCS IN TKXAB LOUISIANA -oaro certified MMONAk injury trial law and civil trial law TCXAS BOARD or LCOAL RRECIAUZATION Ms. Amalia Rodriguez-Mendoza District Clerk Travis County Courthouse 1000 Guadalupe Street Austin, Texas 78701 Re: No. 92-10123; John A. Loper, et al v. Fibreboard Corporation, et al; In the 53rd Judicial District Court of Travis County, Texas Dear Ms. Rodriguez-Mendoza: Enclosed for filing please find Response of Pittsburgh Corning to Plaintiffs' Interrogatories in regard to the above-referenced cause. Please acknowledge receipt of this document by placing your file mark on the enclosed copy of this letter and return same to the undersigned in the envelope provided. By copy of this letter, I am forwarding a copy of said Response to Plaintiff's counsel of record by Federal Express. Thank you for your assistance in this matter. RLS/mjb Enclosures cc: Mr. RRussell W. Budd Federal Express 05/20/93 NO. 92--10123 JOHN A. LOPER, SR. and PATSY LOPER; WILLIAM GEORGE WALLACE and SHELBY WALLACE; THOMAS COLTON BULLOCH, JR. and MARILYN BULLOCH? ROBERT EARL BUMPERS and FAYE BUMPERS? WILLIE F. MARTIN and IDA FAYE MARTIN? JAMES CLOIS HODGINS and DOROTHY HODGINS; and WOODROW WILSON SMITH and MELBA SMITH, IN THE DISTRICT COURT OF Plaintiffs, vs. TRAVIS COUNTY, TEXAS FIBREBOARD CORPORATION, et al., Defendants. 53RD JUDICIAL DISTRICT RESPONSE OF PITTSBURGH CORNING CORPORATION TO PLAINTIFFS/ INTERROGATORIES TO DEPENDANT GENERAL OBJECTION This Defendant manufactured an asbestos thermal insulation product, UNIBESTOS, from July 1, 1962 to on or about February 1, 1972. Unless otherwise stated in response to specific interrogatories, the responses herein shall be limited to such product and time period. This Defendant objects to providing responses for any other period of time on the grounds that such additional information sought is irrelevant, immaterial, not WGM/WGM/43434.1 calculated to lead to the discovery of admissible evidence and, furthermore, could be burdensome, expensive and harassing to comply with. At various times, this Defendant also relabeled and sold certain types of mastic products as accessory products. Although all the formulations of these relabeled mastic accessory products are not now known, a few did include small amounts of asbestos fibers used as a binder, which fibers were encapsulated in a bituminous and/or resinous binder. These accessory products were not manufactured by this Defendant, were not used on high temperature insulation products such as UNIBESTOS and were not insulating materials. Those few mastic products which contained asbestos fibers as a binder have not been considered to be a source of asbestos fiber emissions. Consequently, such material was specifically exempted from certain regulations in the federal Environmental Protection Agency's National Emissions Standard for Asbestos, see 40 C.F.R. S 61.22 et sea.. (now 40 C.F.R. $ 61.148) and were exempt from the asbestos controls of the Consumer Products Safety Commission 16 C.F.R. S 1304.3(c). Similarly, the asbestos regulations of the Occupational Safety and Health Act, which require caution labels on asbestos products, did not apply WGM/WGM/43434.1 -2- to any material where asbestos fibers were modified by a binding agent, coating or binder. See 29 C.F.R. S 1910.1001(g)(2)(i) (now 29 C.F.R. S 1910.1001(j)(4)(i)). The term asbestos is generically applied to several different minerals, may be found in various fiber types and may be found in a wide variety of product forms, including ceiling tiles, floor tiles, gaskets, gloves, mastics, protective aprons, protective matting, etc. This Defendant objects generally to these interrogatories as vague, overly broad, irrelevant, immaterial and not reasonably calculated to lead to the discovery of admissible evidence so far as they relate or refer to unidentified asbestos-containing products or materials and will limit its responses as stated above. This Defendant states that there never existed a predecessor corporation with respect to this Defendant. While this Defendant purchased on June 30, 1962 selected assets from Union Asbestos & Rubber Co., it did not purchase that company; that company continued to operate as a separate company for years and to sell other products including asbestos-containing products, it was not a predecessor corporation of this Defendant and on information and belief it or its successor continues to operate as an WGM/WGM/43434.1 -3- independent company to this date. Further, Defendant states that its responses to any interrogatory or request herein relate only to this Defendant and are not to be construed to imply the existence of a predecessor corporation. INTERROGATORIES 1. For each document listed below, please answer whether such document is a true and correct duplicate of a genuine and authentic document: RESPONSES This Defendant objects to Interrogatory No. 1 on the ground that the discovery request, although characterized as an "interrogatory", is in reality a request for admission pursuant to Rule 169. As such, this request is outside the scope of discovery as permitted by Rule 169 in that it is compound and exceeds the specific mandate of Rule 169 which allows a request to include "the genuineness of any documents described in the request". This Defendant may affirm or deny that the copy is genuine or identical to the document it possesses, but this Defendant should not be required to authenticate or vouch for the accuracy or the contents of the document. Without waiving this WGM/WGM/43434.1 -4- objection, this Defendant will endeavor to respond as to whether or not the identified documents on Exhibit A are "genuine". EXHIBIT NO a) U-3 RESPONSE! Admit that the document is a genuine copy as it appears in the files of this Defendant. b) U-6 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. c) U-10 RESPONSE: This Defendant lacks sufficient information upon which to determine the genuineness of the identified document as this Defendant has made reasonable inquiry and has ascertained that it is not in this Defendant's files; however, if further response is deemed necessary, deny. WOMAVOM/43434.1 -5- d) U-15 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. e) U-18 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. f) U-20 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. g) U-23 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. h) U-28 RESPONSE: Deny in the form presented; however admit that the document attached as Exhibit U-28a is a genuine copy as it appears in the files of this Defendant. WGM/WGM/43434.1 -6- i) U--32 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. j) U-33 RESPONSES Admit that the document is a genuine copy as it appears in the files of this Defendant. k) U--34 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. l) U-37 RESPONSES Admit that the document is a genuine copy as it appears in the files of this Defendant. m) U-38 response: Admit that the document is a genuine copy as it appears in the files of this Defendant. WGM/WGM/43434.1 -7- n) U-40 RESPONSE; Admit that the document is a genuine copy as it appears in the files of this Defendant. O) U--44 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. p) U-49 RESPONSES Admit that the document is a genuine copy as it appears in the files of this Defendant. q) U-62 S&SSSBS&i Admit that the document is a genuine copy as it appears in the files of this Defendant. r) U-65 RESPONSES Admit that the document is a genuine copy as it appears in the files of this Defendant. WGM/WGM/43434.1 8 S) U-68 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. t) U-69 response: Admit that the document is a genuine copy as it appears in the files of this Defendant. U) U-70 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. v) U-71 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. W) U-78 RESPONSE! Admit that the document is a genuine copy as it appears in the files of this Defendant. WOM/WGM/43434.1 -9- x) U-80 response: Admit that the document is a genuine copy as it appears in the files of this Defendant. y) U-81 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. z) U-83 RESPONSE: This Defendant lacks sufficient information upon which to determine the genuineness of the identified document as this Defendant has made reasonable inquiry and has ascertained that it is not in this Defendant's files; however, if further response is deemed necessary, deny. aa) U-84 RESPONSE: Deny in the form presented; however admit that the document attached as Exhibit U-84a is a genuine copy as it appears in the files of this Defendant. WGM/WGM/43434.1 -10- bb) U-86 RESPONSE: This Defendant lacks sufficient information upon which to determine the genuineness of the identified document as this Defendant has made reasonable inquiry and has ascertained that it is not in this Defendant's files; however, if further response is deemed necessary, deny. cc) U-88 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. dd) U-89 RESPONSE: Admit that the document is a genuine copy as it appears in the files of this Defendant. ee) U-90 RESPONSE: This Defendant lacks sufficient information upon which to determine the genuineness of the identified document as this Defendant has made reasonable inquiry and has ascertained that it is not in this Defendant's WGM/WGM/43434.1 -11- files; however, if further response is deemed necessary, deny. ff) U-94 RESPONSE: This Defendant lacks sufficient information upon which to determine the genuineness of the identified document as this Defendant has made reasonable inquiry and has ascertained that it is not in this Defendant's files; however, if further response is deemed necessary, deny. gg) U-97 response: This Defendant lacks sufficient information upon which to determine the genuineness of the identified document as this Defendant has made reasonable inquiry and has ascertained that it is not in this Defendant's files; however, if further response is deemed necessary, deny. WGM/WGM/43434.1 -12- hh) U-98 RESPONSE: This Defendant lacks sufficient information upon whict to determine the genuineness of the identified document as this Defendant has made reasonable inquiry and has ascertained that it is not in this Defendant's files; however, if further response is deemed necessary, deny. ii) U-99 BSSMSS: Admit that the document is a genuine copy as it appears in the files of this Defendant. jj) u-ioo RESPONSE: This Defendant objects to this request on the basis of attorney-client privilege and/or attorney work product. If further response is deemed necessary, deny. kk) U-174 ggg.PgWgg: Objection. This document is a letter from an attorney at the time representing this Defendant providing WGM/WGM/43434.1 -13- legal advice and/or opinion and suggesting previous attorney-client communications and is thus protected by the attorney-client privilege and/or attorney work product. 2. For each document listed below, please answer whether such document was kept and/or generated in the regular course of a regularly conducted business activity of any PCC Entity by an employee or representative of any PCC Entity with knowledge of the act, event, condition or opinion recorded. RESPONSE? This Defendant objects to Interrogatory No. 2 on the ground that this interrogatory is outside the scope of discovery as permitted by Rule 168, in that the interrogatory as phrased seeks to have this Defendant substitute itself for the judicial authority in making a determination relevant to the admissibility of a document into evidence. In addition, this interrogatory is compound and improperly phrased in the alternative, without waiving this objection, this Defendant will advise plaintiffs as to whether not WGM/WGM/43434.1 -14- such documents identified on Exhibit A are located in Defendant's files. EXHIBIT NO a) U-3 RESPONSE? See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. b) U-6 RESPONSE? See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. C) U-10 RESPONSE? See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -15- d) U-15 RESPONSE* See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. e) U-18 RESPONSE; See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. f) U-20 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. g) U-23 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -16- h) U-28 RESPONSEt See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. i) U-32 RESPONSE: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. j) U-33 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. 1C) U-34 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -17- 1) U-37 RESPONSE: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. m) U-38 RESPONSE: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. n) U-40 RESPONSE: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. o) U-44 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -18- p) U-49 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. q) U-62 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. r) U-65 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. s) U-68 response: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -19- t) U-69 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. u) U-70 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. V) U-71 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. w) U-78 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -20- X) U-80 RESPONSE; See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. y) U-81 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. Z) U--83 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. aa) U-84 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -21- bb) U--86 RgSPOlfgg: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. cc) U-88 Rgggoyggi See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. dd) U-89 Rgg.PPgS.gs See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. ee) U-90 RggPOKSg: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -22- ff) U-94 RESPONSE: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. gg) U-97 RESPONSE; See this Defendant's response to Interrogatory No. i, regarding this exhibit, which is incorporated herein by reference. hh) U-98 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. ii) U-99 RESPONSE; See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -23- jj) U-100 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. kJc) U-174 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. 3. For each document listed below, please answer whether such document was found in your files in such a condition as to create no suspicion concerning its authenticity. RESPONSES This Defendant objects to Interrogatory No. 3 on the ground that the discovery request, although characterized as an "interrogatory", is in reality a request for admission pursuant to Rule 169. As such, this request is outside the scope of discovery as permitted by Rule 169 in that it is compound and exceeds the specific mandate of Rule 169 which allows a request to include "the genuineness of any documents WGM/WGM/43434.1 -24- described in the request". This Defendant may affirm or deny that the copy is genuine or identical to the document it possesses, but this Defendant should not be required to authenticate or vouch for the accuracy or the contents of the document. Without waiving this objection, this Defendant will endeavor to respond as to whether or not the identified documents on Exhibit A are "genuine". EXHIBIT WO a) u-3 RESPONSES See this Defendant's response to Interrogatory Wo. 1, regarding this exhibit, which is incorporated herein by reference. b) U-6 BSOM: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. WGM/WOM/43434.1 -25- c) U-10 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. d) U-15 RESPONSES See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. e) U-18 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. f) U-20 RESPONSES See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -26- g) U-23 RESPONSES See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. h) U-28 response: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. i) U-32 RESPONSE; See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. j) U-33 BSSSSUfi* See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -27- k) U-34 RESPONSES See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. 1) U-37 RESPONSES See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. m) U-38 Bgg.PQNgg: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. n) u-40 RESPONSE? See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -28- o) U-44 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. p) U-49 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. q) U-62 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. r) U-65 RESPONSE: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -29- s) U-68 RESPONSE: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. t) U-69 RESPONSE: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. u) U-70 RESPONSE; See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. v) U-71 responses See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 --30 -- W) U-78 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. x) U-80 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. y) u--81 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. z) U-83 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -31- aa) U-84 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. bb) U-86 RESPONSE: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. cc) U--88 RESPONSE? See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. dd) U-89 RESPONSE: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. WGM/WGM/43434.1 -32- ee) U-90 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. ff) U-94 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. gg) U-97 RESPONSES See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. hh) U-98 RESPONSE: See this Defendant's response to Interrogatory No. I, regarding this exhibit, which is incorporated herein by reference. WOM/WGM/43434.1 -33- ii) U--99 RESPONSE: See this Defendant's response to Interrogatory No. 1, regarding this exhibit, which is incorporated herein by reference. jj) U-100 RESPONSE: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. kk) U-174 RESPONSE: See this Defendant's response to Interrogatory No. l, regarding this exhibit, which is incorporated herein by reference. 4. Has PCC stipulated or agreed to the authenticity of any of the documents referenced in Interrogatory No. 1 with any person prior to the date of these Interrogatories? RESPONSE: This Defendant objects to Interrogatory No. 4 on the grounds that it in effect asks whether there has been WGM/WGM/43434.1 -34- a previous response to a request for admission and i. so doing seeks to circumvent the specific mandate of Rule 169(2), which forbids a response for a request for admission in one proceed to be used for any purpose in any other proceeding. As such, the interrogatory is improper and outside the scope of discovery as permitted by Rule 169. WGM/WGM/43434.1 -35- Respectfully submitted, WELLER & GREEN, P. 0. BOX 350 BEAUMONT, TEXAS (409) 838-0101 L.L.P. 77704-0350 ATTORNEYS FOR DEFENDANT, PITTSBURGH CORNING CORPORATION CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing instrument has been forwarded to all known counsel of record by regular mail on this the 21st day of May, 1993. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA } SS: COUNTY OF ALLEGHENY BEFORE ME, the undersigned authority in and for said Commonwealth and County, personally appeared Richard C. McPherson, who being duly sworn deposes and says that he is Vice President of Human Resources with Pittsburgh Corning Corporation, that he is authorized to make this affidavit on its behalf and that the facts contained in the foregoing Interrogatories are based on previous responses to similar Interrogatories compiled by Robert E. Buckley who was a former Vice President and Assistant to the President of Pittsburgh Corning Corporation and who has sworn that said responses were true and correct to the best of this knowledge or information and belief. R. C. McPherson SWORN TO AND SUBSCRIBED BEFORE ME this of Mji W 1993 mu,: a. MmM.v Notary Public , ,, NotanalSeal Julia A. Stephens. Notary Pubfc PtsnSoro. A-r/envCcurty MyCf:Tt:*;".cn r.-jires rv.jrch 16.1296 MefflDer, PernsyivanaAssooacco ofNobles' EXHIBIT A EXHIBIT HO. a) U-3 b) U-6 c) U-10 d) U-15 e) U-18 f) U--20 g) U-23 h) U-28 i) U-32 j) U-33 *) U-3 4 1) U-37 m) U-3 8 DESCRIPTION Asbestos Survey, Pittsburgh Corning Corporation, Tyler, Texas, Project No. 71-45, dated 12/7/71. Letter of Clyde C. Ruddick to Karl Baumler dated 5-16-62 with attachments. Letter dated 6-21-67 from Dr. Hurst to Dr. Grant. Letter dated 4-8-69 from Wendell Blair, U, S. Department of Labor, to Bierer with attachments. Letter dated 1-27-70 from Clinton V. Oster to Mr. C. E. Van Horne. Letter dated 3-13-70 from Dr. Grant to Van Horne. Letter by Wilson to Fuhs dated 9-10-70. (Exhibit 2 to Deposition of Roy Fuhs). Letter dated 11-16-71 from Dr. William Johnson and Bobby Craft to Dr. James K. Peavy with attached air sample results. Notification of Proposed Penalty dated 12-16-71 from U.S. Department of Labor. Citation (5 pages) from U.S. Department of Labor dated 12-16-71. Notification of Failure to Correct Violation and of Proposed Additional Penalty dated 1-17-72 from U. S. Department of Labor. Letter dated 12-20-71 from Dr. Grant to Mr. Van Horne with Attachment #1, Grant's Memorandum to the Record and Attachment #2, Asbestos Standard. Letter dated 12-21-71 from Craft and Dr. Johnson to Dr. James E. Peavy. n) U-40 o) U-44 P) U--49 q) U--62 r) U-65 s) U-68 t) U--69 u) U-70 v) U-71 w) U-78 x) U--80 y) U-81 Z) U--83 aa) U-84 bb) U-86 cc) U-88 Letter dated 1-4-72 from Dr. Grant to Personal Environment systems. Letter dated 1-31-72 from Dr. Grant to Mr. Carl Olm and Mr. Van Horne. Letter dated 5-25-62 from Mr. Clyde C. Ruddick to Mr. Karl Baumler with enclosures. Pittsburgh Corning Corporation Appropriation Request, 2-17-65 (7 pages). Letter dated 08-15-66 from Lee B. Grant, M.D., to Mr. Arthur Haskins. Letter dated 8-23-67 from Lee B. Grant, M.D., to J. M. Barnhart with blind carbon copy to Mr. Russell Brittingham, including enclosures. Letter dated 2-5-68 from Roy E. Fuhs to Robert E. Buckley. Letter dated 5-29-68 from Roy E. Fuhs to Robert E. Buckley. Letter dated 7-9-68 from Lee B. Grant, M.D., to Mr. Byrl M. Stout. Letter dated 6-23-69 from Mr. John L. Hyde to Mr. A. R. Gebrin. Letter dated 9-16-69 from Lee B. Grant, M.D., to Mr. Byrl Stout, Mr. E. W. Holman. Pittsburgh Corning Corporation Inter-Office correspondence dated 1-20-71 from Mr. G. S. Gregory to Mr. E. W. Holman. Memorandum dated 10-19-64; Subject: Asbestos Exposure at Pittsburgh Corning Corporation with attached newspaper article. Pittsburgh Corning corporation Inter-Office correspondence dated 4-25-63 from Mr. K. Baumler to Mr. J. W. McMillan, with attachments. Letter dated 4-3-68 from Lee B. Grant, M.O. to Mr. J. W. McMillan.. Pittsburgh Corning corporation Inter-Office handwritten correspondence dated 5-1-70 from Mr. Jim Nesser to Mr. Roy Fuhs. dd) U-89 ee) U-90 ff) U-94 gg) U-97 hh) U-98 ii) U-99 jj) U-100 kk) U-174 Pittsburgh Corning Corporation Inter-Office correspondence dated 5-12-70 from Mr. John H. Price, Jr. Letter dated 3-2-70 from R. E. Faucett to Commander, Naval Engineering Center. An organization chart of Pittsburgh Corning Corporation. Letter dated January 12, 1966, from Mr. Philip Zullo to Mr. R. K. Francis. Pittsburgh Corning Corporation reported dated January 5, 1966. Letter dated April 22, 1966 to Mr. Russell Brittingham from Lee B. Grant enclosing Memorandum for record April 21, 1966 by Lee B. Grant. Notes made by w. Farkos dated January 4, 1972, with copy of letter from Lee B. Grant to J. W. McMillan, dated April 3, 1968, attached. Letter dated June 24, 1968 from Richard C. Packard to George E. Duncan, Esquire. EXHIBIT U-28a Satleoal Xaatltota for Occnpaflonal Safety an* Health 550 Main Street, IUm 7053 Claclaaatl, Ohio 45202 Boveaber 14, 1571 JflMi X* ?itV7^ XD Comloelaaor of Seelth Tnaa Suu PoperlMt of Malt! U00 nt 49th Stmt Aeatla, Tom 7X754 Doer 1ft* Pearyi A rtcait R.I.O.t.L eorrey I--ooetratol on irtfMly eerloee ood critical MopAtioMl health eitaatloe it fha Plttebergh Corel** Corporative Jwoelte Aebootoo Thexael Mpo Iaeolatlao Plant la Tyler, Texae* I.I.Q.S.H* tedaetrial kyrleae wmyi la 1947 md 1970 yielded greenly eoeeeetee filer ooaeoottatlooa owytil to comet aa* ptopoood aafccetee eteaiarda, ood tbeee rooolto wore forwarded to the noogamy for appro the Tom State laalth OtpirtMt ood the looal mml irrtfp of the Oil Chemical md Atomic Vrtiri Xataractloeal Umtea, I.1.0fH. ooodoctad a eooprohoaalro fadaotrfel hygleae ood medical wmy darlag the meefc of October 24 to 29, 1971* potato* oot major ladaetrlal hyglcee doftrtomoteo which ioalodo* a greenly laoAoqoato reetlUtie* eyetoo oad poor hooaeheopfnt la Impact 1971, roaplrators ooro mode olctory la all aroaa till appllaatlea for mUm from the oar-goat aloof U Mm, oar aarway pereenael eheeromd Mqr wployoeo vith rtrepe. Alao, there moo ao filvCiMhr the flttlat of reoplratera* Again yereaoat air aaaplea yielded Dr. James E. Peary - 11/16/71 2 pulmonary fibrosis. However, Dr. Lea Grant, Medical Consultant to the Pittsburgh Corning Corporation, has delayed release of these film* to H.I.O.S.H. and its expert panel of radiologists pending his personal review of the films. Even without benefit of the X-rays, 7 of 18 workers with greater than ten years employment at the Tyler Plant meet et leant three of fonr criteria for aabestosla. These criteria Include: (1) forced vital capacity below SOX of predicted, (2) dyepoea (3) finger dubbing, and (A) rales. Positive X-ray result* could In crease further the number of cases of asbestosls. Reduced pulmonary function was also observed la a few workers with lsss then five years employment. Therefore, medical follow-up of current and past employees is Indicated Zmnedlate corrective aetlon Is necessary to redoes asbestos exposure levels to conform to existing standards. Sincerely yours. William M* Johnson, H.D. Acting Deputy Director, Division of Field Studies and Clinical Investigations Bobby F, Craft, Ph.D. Acting Director, Division of Techalcel Services Enel. (Air Sampling Results; October, 1971) ce: Kerens K. Key, M.D. Mr. Charles Van Bone Mr. J. >. Stokes Hr. George Pettigrew, Region VI, H.I.O.S.H. Mr. John K. Sarto, Region VI, O.S.H.A. Jbeeph R. Wagoner, S.D. Hyg. WKJOHKSOH: jo ANALYSIS OF PERSONAL SAMPLES PITTSBURGH-CORNING ASBESTOS PLANT, TYLER, TEXAS ASBESTOS PIPE-INSULATORS OPERATION SAMPLE Mixing Forming Feeder Feeder Feeder Feeder Scrap Feeder Feeder Feeder Feeder Feeder Feeder Feeder Builder Builder Builder Builder Builder Builder Builder Relief Builder Builder Builder Builder . Builder Relief Builder Builder Builder Builder Builder Builder Relief Builder Builder Builder Builder Builder Builder . 45 139 117* 99* 106 60* 12* 57 82 132 29 18 91 103 88 119 83 85 105 89 121 54 25 71 90 92 120* 110 107* 111 16* 20 14 17 53 CONC, (FIBERS >5u/cc) 54.04 105.83 101.71 169.7 9.58 188.91 92.77 26.4 9.14 22.5 37.6 40.93 26.11 14.61 7.45 9.42 25.79 42.77 22.33 6.67 25.53 12.28 57.72 35.24 17. 37.54 90.9 70.36 103.97 30.43 134.41 53.23 44.31 59.58 42.99 Page 2 - Pittsburgh-Coming Asbestos Plant Curing Finishing Relief Builder Builder Builder Builder Builder Builder Builder Builder Builder Builder Builder Builder Relief Builder Builder Labor Oven Tender Oven Tender Oven Tender Oven Tender Oven Tender Supervisor Wrapper Wrapper Finishing Laborer Utility-Finishing Utility-Finishing Wrapper Utility-Finishing Finishing Laborer Saw Operator Saw Operator Saw Helper Saw Operator Saw Operator SRL Saw Cutting Saw SRL Cutting Saw Saw Feeder Pine Machine Oper. Saw Labor Saw Labor 27 74 15 24* 131 136 122 101 124 65 95 58 56 102 52 47 140 112 93 84 68 130 98 1 3 66 8 4 22 30 126 78 76 94 118 51 55 35 006* 007 116 72.12 9.74 64.35 111.15 13.8 9.9 14.8 26.9 8.44 56.45 36.41 14.75 24.27 31.2 11.26 23.5 5.08 6.89 19.87 16.40 20.38 11.43 37.45 30.43 48.53 12.03 94.81 55.11 22.83 27.36 19.38 14.18 31.23 21.9 1.73 91.76 40.28 2.30 208.42 97.26 6.59 Page 3 - Pittsburgh-Corning Asbestos Plant SRL Saw SRL Saw Saw Labor SRL Labor Inspection Box Marker Weigher Fork Lift Operator Packer Packer Shipping Supervisor Packer Fork Lift Operator Labeler Inspector Weigher Inspector Packer Packer Weigher Miscellaneous Maintenance Utility Utility Maintenance Utility Maintenance Maintenance . Maintenance Maintenance Sweeper Maintenance Maintenance Janitor Shipping Guard Guard Guard Supervisor Supervisor Supervisor Supervisor 134 141 109 26 86 59 2 21 42 43 10 62 63 69 5 23 9 44 125 75 135 133 108 39 11 13 50 64 97 123 127 129 40 73 113 72 128 080 19 79 25.97 1.96 11.62 91.52 20.71 34.49 11.71 9.5 1.84 2.18 13.08 20.42 20.72 92.26 29.45 73.62 3.83 .71 6.8 32.08 2.09 8.36 18.12 30.38 42.28 26.81 28.43 . 37.54 3.61 2.10 0.94 2.29 1.36 1.94 4.58 0.64 1.57 14.92 29.91 6.28 Page 4 - Pittsburgh-Coming Asbestos Plant Supervisor Supervisor Supervisor Office Workers 77 104 115 154 152 158 155 ^Approximate (too many to count) Samples taken on October 26, 27, 28, 29, 1971 24.25 25.2 2.28 0.04 0.04 0.03 0.66 mm it sS Si a & V O CO M) * \ EXHIBIT U-84a INTEROFFICE CORRESPONDENCE To J* V, McMillan From k. Baumler Subject: Plant Safety and Protection Date April 25, 1963 Dear Mac: Attached is a copy of a nemo dated April 23, 1963, from Mr, J, E. Morrison, covering his recent inspection trip to Tyler* We have discussed the survey and I agree vith all the recommendations made* Nov, it vill only be a matter of timing for execution of these rec ossendations * sv #1 Mr* Morrison vill contact the Industrial Hygiene Foundation and vill " arrange for the necessary dust survey* You vill be advised in advance vhen these people come to Tyler* f #2 X-Bays -- All nev employees should be given the complete x-rays as i outlined* When old employees are re-x-rayed, the front and side X-ray of the lumbar region of the back should be made in addition to the chest x-ray* Thus, ve vill build up a complete history of all our employees* #3 Can and should be done as soon as possible* #4 fisployees vill need a soft sell on respirators, to be folloved up vith rigid enforeeme&t in troublesome areas, vhen Hygiene Foundation submits their findings* #5 Can and should be done as soon as possible* #6 Same as #5* #7 Suggest at this tiam you request your supplier of fire extinguishers to give a demonstration to your employees at the plant site, vith necessary instruction* #8 To organise an effective fire brigade vill take some planning, but the groundwork should be laid now to have it in operation vithin reasonable time* #9 Pick a central and convenient area for an oil storage house and build one* #10 This ties in vith #8* An Executive Safety Committee vith the Works Manager as permanent chairman should have as members, the General Foreman, and the Works Accountant as Secretary* As the need arises, additional salaried supervisors can be included -2- Ve suggest that you arrange to send your Fire Marshall, I assume that vould be your General Foreman, to the Ansul Fire School for training* Schedule of school dates is enclosed* Pick the date most desirable and make reservation* I believe ve also should take advantage of the Industrial Hygiene Foundation's service to survey the medical doctors in your area and make reconoendation to us on the best qualified doctor for our particular need* As you knov, ve in Pittsburgh Corning are safety conscious at all times and attempt to give the best possible protection to our employees and manufacturing facilities* We are sure you vill incorporate the above improvements in your overall schedule at an early date* EB:km Enc* cc: J. E* Morrison PITTS B U P.G H PLATE CLASS COMPANY 6CNIM. 0"'CCOMC OATTWAT CINTtA. *TT#4j*<3h 22 A* April 23, 1963 Mr. Karl Saunler 7ice Resident of Xarufaeturing Pittsburgh-Coming Corporation One Gateway Center Pittsburgh 22, Pennsylvania . * Bear Hr* Srjilert * this is to oonfira iy visit to your ?7ler, Texas operation oa April .8 k 9, 1963* This visit was *ade in the interest of olant safety and with the objective of working toward the high standards which are in vogue in PittsburghCorning plants. Mr* J* W. McMillan, tha Plant Manager, escorted me through the nlar.t and snowed no all tho courtesy possible* Re did a fine job of explaining plant operation and historical background. All plant people were courteous and helpful* Mr. McMurray, a plant surervisor, was most helpful and courteous* - ' A thorough audit of the plant safety effort was made and reccrxendaiions are attached which cover the important items which take priority. These i*eas can Cut costs on a long-range basis and are the* basic or first steps that should be taken toward your high standards* ' Attached Is an Ansul ?lre School schedule and a reproduction from Industrial Hy- . giene Journal cn Asbestcsis* The hygienic standards mentions 'periodic* clyrical examinations* The Foundation feels this allows latitude far judgment in the In dividual plant situation^ defending tmon exposure, dust concentration and other .factors* A recoeneodation can be included in the dust survey report to ccv^r *tis# A dust.sjrv*y can te aude in the coning early summer. We will te advised of tr:e date in due tins* 4' The Foundation also offers a service which say be of interest* They have means for surveying the medical doctors in the plant vicinity; to determine who could be recommended as a cm?any physician based on background In our particular nsM* They will assist Ms in setting up a program tailored to fit the need of the plant* This is reooranended for serious consideration* . It was a pleasure to be of help in this natter* . JIMtm cct I W* Cellins Very twly yours# - . *.. J* E Morrison, Asst* Manager Safety and Plant Protection UCOHKUDATI 0N3 1* A dost rvyvqy by Industrial ifygiene foundation abould be made at an early'date* , 2* A front and aid* X-ray of the 1'jab ay region of tht bade should be cade a* a part of the ?re-*ployntct physical exam ination along vith the chart X-ray. ... . # ' 3# Several additional fire extinguisher* should be placed in the shipping area and 1a the north end of the sanufaeturing building* lu- fiaplpyees should wear respirators Id dusty atnoephere. 5* A 5-pound Aneul dry oh--leal fire ertinguiaber ahould be provided for each fork truck* . a 6* Boris should be installed on fork trucks. 7* Ifcplcyee* should have training in use of dry powder and other extinguishers* ~ * .. . # 8* firs brigades should be activated.' `9.* * Special"oXl~sfcrags "house is needed* ' . a . * 10* Executive Safety Coamittee should be reactivated vith the ' Works Karager as the Peraanent Chairman. RECOMMENDATIONS ! A dust surrey by Industrial Hygiene Foundation should be made A at an early date* g ^ 2. A front and side X-ray of the lumbar region of the back ' should be made as a part of the pre-ennloyaait ohysical exam ination along with the chest X-ray* e>K. 3* Several additional fire extinguishers should be olaced in the shipping area and in the north end of the manufacturing building* r " k Employees should wear respirators in dusty atmosphere. C, * fsu'l ' :/'i 6 A 5-pound Ansul dry chemical fire extinguisher should be provided for each fork truck. Horns should be installed on fork trucks* 7 Biployees should hare training in use of dry powder end other extinguishers _ ; - 8* Fire brigades should be activated f !/ 9* Special oil storage house is needed* 10* Executive Safety Committee should be reactivated with the Works Manager as the Permanent Chairmen* Indu4trial Hygu*4 Journal - m C. RECOMMENDED CONTROL PRO CEDURES: To preveal exposure to high concentrations of amorphous silica di*t, process ventilation aad/of en closure are the bed neui of control. For socno operations a dud respirator approved by the U. S. Bureau of Mine* may bo satisfactory. IV. Spedfie Procedures A. FIRST AID: None. . B. SPECIAL MEDICAL PROCEDURES: (1) Preplacement: Clinical and ehed radiographic examinations abould bo mads on all persons, prior to job assignment. (3) Penodie: Since there it only lim ited information about the harmful effects of aaorpbouo alien a in dustry, oxpooed personnel should hove careful periodic medical aminaboos, including ebed x-ray. Pulmonary function testing may b* useful. .> (3) Treetaunt: No satisfactory treat ment other than removal from a* poeure, and therapy for any com plicating iatoctioa. Y. Literature Reference* 1. Cooraa, W. C, t al: Industrial Hy giene Foundation Trumcuoo Bulietia No. 30,183-194. JL Daorasa, P. uro Hatch, T.: Industrial Dm. McGraw-Hill Co, Inc. Nov York, 1964. A Flats*, D. A.: AifA Arek. of Ini. Hff. end Ooe. ifd, / 412, 1963. 4. Umn, J. S.: Ini, Jfsd, 7: 470,1934 A Paucana, A. arm Courr, A.: AUA Arck. of Ini. Urt- end Oce. ifed, I: 389, 1964. 4 Scnnu, 0. W. H., d al: AMA AreA of /ad. /*; 125, 1967; ibid, IS: 303, 1057; ibid, IS: 2*>, 1967; ibid, IS: 30, 1957; ibid, /#; 499, 1967. . 7. Smart, R. H. air* Anotaaon, W. M.: /nd. ifed. and Svry, Si: 609, 196A A Tsauxa, B. D. ana Baaao, R. R-: AUA Ank. Ini. HtoUk, IS: 56,1967. A U. 8. Pubii* Health Servieo; California Department of Public Health; Nevada State Health Department; Orefoo State Board of Health: Program Report of Study of Pneumoeocioao Hasards in the. Diatomite Proensring Industry. 1966. Asbestos L Hygienic Standards A. RECOMMENDED MAXIMUM AT MOSPHERIC CONCENTRATION (S hours): 6 million particles per eubse foot of air (MPPCF).* (1) Basis for Recommendation: Experi ence in industry,* -* aid ani mal experiments.*r B. SEVERITY OF HAZARDS: (1) Health: Long continued inhalation of oebeetoa dud results in.a form of pneumoconiosis known as ssbes toms. Tbs primary effect of inhalatioo is an interstitial pulmonary fibrosis. Tbs diseam is characterised by asbestos bodies in the lungs and * sputum. Baaed on roentgenological examinations, srbestode can be das-' rified as minimal, moderate, and advanoad. It is a mrioos disease m some instances, but non frequently it remains noodieabjmg for many yoars, oven without. appreciable symptoms, as long as some other serious disease doss not supenrons , to eauss death.* Chief symptoms of advanced asbestos* are variable cough, dyspnea, substeraal chest paint, decreased chest expansion, weakTimi, emaciation, clubbed fin ger tips, and curved fingernails. Any . '. t appreciable decrease in the amount . ' of asbestos dud in the breathing ` atmosphere will eause a deervaes . in the incidence and. severity of asbedosis. Individual suctptibility varies.* There have been reports of . .v an increased incidence of lung .eea . eer In person* with asbedosis* (3) Fit*: None. '. C. SHORT EXPOSURE TOLERANCE: Not applicable: ,, 21 Significant Properties A fibrous magnesum calehtm sflieate vhieh occur* ia venous combinations as white, greyish of greenish minus, either comped or of long silky fibers, fiax-fike and readily separated. About 96% of oonunerical aibe*. tea la chrysotile, which is derived from serpentine, and is a hydrous aagneriua rr ISA ApnJ, J$S8 Iiaott oontoiai&c from 13 to H per ere* hire periodic cliciciJ ex3rs;n.-u:<)rm water of crynaliiiotioo. fop rra izd ryrnr.ora of IH Iadudhol Hygioae-Pnctid ' .Jflsfc.Three should incluae exanu- A. RECOGNITION: Th* epiaaiac *** aauoa of the sputum for letoaataua veoriag of eebdtoo, in eocabtaotion with bodies, oad chad i-nyi ef good other tcxbld for fire proof aad boot . quality. noierint doth, remitt in dud exposure. (3) Treatment: No satisfactory treat- - . < It may bo ueed by iteolf or orerihinod moot other then removal iron ex "; with other materials for rohre podriig* : pantre end therapy for any ease- ' pefcets, boiler loggac nod pip* oororw . v plidthif infection. mg, prottdivo alothtat shielding aovenoie, sad as automotive broke lining! T. literature Rofereoed - In the building induetry it i* uood in _ L American Confere&oe of Governmental tba manufacture of oehdtd aaral Industrial Hygienictt; AMA AreA. of product* boot ineukuag, and ire- i 'fed. ffeofcA, 19: Ml, 1&57. proofing mstonnk : i 3. Camn* Papb: AJfA AreA. of 1*4. B. EVALUATION Of EXPOSURES; An- Uorttk, 11: 304, 196*. baato* duct any bo mopfod vuh the 3. Doll, Sli BhL J. 1*4. ifW, IS: , " okotrodo&o prodprtotor 'or by the - * - * IMS. ' . impingd Mthed unog aloohol or eleohat ad water, m tbo mUondac moHTtrm,*> * . oad dud oouatt mode by tbo standard 4 Dusus, W. C, d el: Pubbe Health Bulked No. 341, Supc of Doc^ W**h- - ington, D. O, 193S. . light field technique.4 Tbo recommended .. S. Dtorut, P. ax Hatca, T.: Iadudhol . flusnun atmocpheric oosco&troaon of w Dud. MeGrev-Hill Book Cn, lae^ t ~u f MPPC7 i> booed upon tbo replngM ' '' ' Near York, 1964. - * - sampling prooedoro, . - 1 PainwaiA, LavaecOB T.: Iadudhol * a RECOMMENDED CONTROL PRO . CSDUR&8: Prevention of eehretiare . Tosoology. Tbo WUllooe 4 Wilkins Co, Boluaore, Md, 1967. doptodt entirely upon preventing * ** paeure to ocooectmiooe of dud iufi . 7 Sato, E. ... d a.l:..Tboru. L. p. 188, ready high to produoo tbe character** 1 Ltxcm, TL M.: AMA ArdL of 1*4. tie reocuoa. Qjoiooure or load exhoad Hooitk, 11: 186, 1966. TtntiioUoo ore tbo principal mom of 1 McPsasrioo, & / 1*4. ifyy. 4 ;j.dud eontioL U. S. Bureau of Mind op- ' Too, It: 229, 1936. ,..proved dud respirator* any bo wore m ~ ' 10. Paoa, R. T. axp BtooimzLO, J. J.: ' protection for mm oporetiaan Pub. HeafU Rp4e. <8; 1718, 1987. IY. Speafie Procedural 1L Pattt, Taunt A^ Iaduothol Hygiefw - A. TOST AID; Noon *........................ . 1 * and Toodoology, VoL 1. Iateneteaoe >rr B. SPECIAL MEDICAL PROCEDURES; Publiflbore, lac, Nov York, 1948. a>:`C' U) Preplodooot: Ornidl end ro<fio 12. bon, E. W, AMA ArtA. of 1*4. ^ . graphic ebdt examinations prior to Hodtk, IS: 196, 1966. job saignmong. 18. Vonvatn, A. J, d al: AMA ArcA. 1*4. (3) Pdiodio; Exsoeod poreonnet should Hyf. red Ocotf. ifod. J; 1, 1961. i Boeoud of OM hiw.tefi--l 4 4 mreeAMi to Iftt alt asctAadi of repreore cwfcotic*. -- fbo alertwre bow bore node re tA bow of rerrmt wad, rehabtUr, opphcebiAty ef (o lAo onto! ddortml type ef dpomro. Any ipoa^c ewbtoiio* red/or eentrel probUm ~' wl dvolw pre/arereof ddyreL fba ore bo* bo dow by pro/nsireot todwthol by * fare yadonoC . .1. *. . prC*.- Jldpfi l(vf pretiettm dewed ore reaaerciaHy evo7cble. TAeir we, Aovtver, sArek th* bo eoojhod to reurpewy or mUmkUU dpoeura end not reded upon oe ynmory turn - ,, of Aooard eeutrof. ... . , , . _* o'- A euhWw owte * oeeif for fday (At enmtfy of leeadi: nR kw# aoderete, A^A, end ' - * "eoOro boeerdew. - , ^ . it t."d ^i"%re ;*' i: ' <'. "! ..' v r* 1I A T \ *m may- PITTSBURGH CORNING CORPORATION J, tf# WKlllaa . BmIc Flant Safrty and Prateetl April SS, IdM Ont XMt AtUeM ia a eepy af a Mat dated April tt, 1M, fna J. I. Merrieoa, twrarlng Ilia rwi lupMttaa trip t Tyler. Ve have dieeeeeed tte ivny and I <rM vlth all tbe mtnadtia 4e. ^ It vlll calf W a Miter rf tlaiaf far axeaetiw af thM HrriiM vlll ttMi the Ted**trial nyiliM Fawdatlea tad vlll arra&fe far the aeaeatary dvi ivnr, Taa vlll be advieed la adraoee vfeea theae peeplt aaaa ta Tyler. ft JUftaye -- All aav ta^ltim akaalt W five* the template Maya aa evtlined. toea eld eapleyeea art ra rayed, the fraat aad a 14a Wty af tfaa lobar regie* af the Wall abeald W made la iddiUaa ta tfaa aheat inrty. TWat w vlll balld f a aaaplata hletery ad all aw eapleyeea. # Caa a*d itaald W 4aaa aa aaaa aa peaalbla. #t toyli/m vill aaa4 a aaft aall aa reeperatwa, ta be falletod ep vith rifld eafareeaaat la traablaaaaa areaat vbaa Hygiene FeucriaUe* atoiilta thalr fladlap* *x ft Gaa and Weald ba 4aoa aa aaaa aa paealbla. . M Saw aa . #T Saggeat at tfela tlaa ye* fKfiit yaw sappllw af fire estlecalaHare ta give a daaoaatratlaa ta yaw aeplayeea at tW pleat aite vitk aetttaary laatreetlaa. #8 Ta trgraise aa affaative fire trifade vlll taka aoaa planniaf, tat the giai--Nart abeeld ba UU aav ta bate It ta aparatiaa vitbia Flak a aaatral aad aa last f ail ataraca beere aai belli eve* It# Tbla tlaa la vitk # Aa Rxeeetlva Safety CaadtUt vlth the Varka !bai|r aa paraaaaat abairoe toevld bare aa atabera, the Georal Farenaa, aai the Veto* Aaaaestaat aa Seeratary. Aa the aaad ariaea, additive*! aalarlai aapanrlaara aaa ba iaelaiai . t /' ; V -2- We suggest that you arrange to send your Fire Marshall, I assume that would be your General Foreman, to the Ansul Fire School for training* Schedule of school dates is enclosed* Pick the date most desirable and make reservation* I believe ve also should take advantage of the Industrial Hygiene Foundation's service to survey the medical doctors in your area and make recoosaendation to us on the best qualified doctor for our particular need. As you know, ve in Pittsburgh Corning are safety conscious at all times and attempt to give the best possible protection to our employees and manufacturing facilities* We are sure you vill incorporate the above improvements in your overall schedule at an early date* KB: km Enc* cc*. J, E Morrison