Document M46EZB3yQQx5MQNgL89NZre9L

Depo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 Page 1 to Page 252 ACE-FEDERAL REPORTERS, INC 202-347-3700 CONDENSED TRANSCRIPT & CONCORDANCE PREPARED BY: ACE-FEDERAL REPORTERS, INC. 1120 G STREET, NW SUITE 500 WASHINGTON, DC 20005 Phone: 202-347-3700 FAX: 202-737-3638 HARTOLDMONOOQ9779 BSA Depo of George Rough, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAX(l) Page 1 [1] - SUBJECT TO PROTECTIVE ORDER IN THE SUPERIOR COURT OF THE STATE OF DELAWARE . P] IN AND FOR NEW CASTLE COUNTY . [3] MONSANTO COMPANY, : [4] Plaintiff, : [5] [6] -vs-: CA No. 88C-JA-118-1-CV m [8] AETNA CASUALTY & SURETY : C-l-90-492 P] COMPANY, et al,, : [10] [11] Defendants, : [12] [13] DEPOSITION OF GEORGE ROUSH, JR., M.D. [14] Thursday, February 18, 1993 [15] Wilmington, Delaware [16] Deposition of GEORGE ROUSH, JR., M.D., called [17] for examination pursuant to agreement by counsel, at m the law offices of Duane, Morris & Heckscher, Suite [19] 1500, 1201 Market Street, at 10:00 a.m., before CRAIG [20] L. KNOWLES, Court Reporter, when were present on behalf [21] of the respective parties: R - continued - Page 2 [1] APPEARANCES: [2] JOSEPH M. JONES, ESQ. [3] Schwalb, Donnenfeld, Bray & Silbert [4] 1025 Thomas Jefferson Street, N.W. [5] Suite 300 [6] Washington, D.C. 20007 m On behalf of the Plaintiff. [8] [9] NANCY L. WALSH, ESQ. rioi Wiley, Rein & Fielding [H] 1776 K Street, N.W. [12] Washington, D.C. 20006 [13] On behalf of the Defendant Travelers Indemnity [14] Co. [15] [16] [17] [18] [19] [20] [21] [22] Page 3 [1] CONTENTS [2] WTINESS EXAMINATION [3] George Roush, Jr. W by Ms. Walsh 5 [5] [6] EXHIBITS m ROUSH DEPOSITION NUMBER IDENTIFIED [8] [9] Exhibit 1 46 [10] Exhibit 2 136 [11] Exhibit 3 157 [12] Exhibit 4 167 [13] Exhibit 5 173 [14] Exhibit 6 176 [15] Exhibit 7 176 [16] Exhibit 8 176 [17] Exhibit 9 184 [18] Exhibit 10 191 [19] Exhibit 11 206 [20] [21] [221 Page 4 [1] [2] Exhibit 12 206 [3] Exhibit 13 223 [4] Exhibit 14 231 [5] Exhibit 15 240 [6] AFTERNOON SESSION 126 171 [8] P] [10] [11] [12] [13] [14] [15] [16] [17] [18] [19] [20] [21] [22] Page 5 [1] PROCEEDINGS: [2] Whereupon, [3] GEORGE ROUSH, JR., M.D., [4] was called for examination by counsel for Defendants P] and, having been first duly sworn by the Notary Public, [6] was examined and testified upon his oath as follows: m EXAMINATION BY COUNSEL FOR DEFENDANTS [8] BY MS. WALSH: P] Q. Good morning, Dr. Roush. My name is Nancy [10] Walsh. 1 am a lawyer with the firm of Wiley, Rein & [11] Fielding in Washington. 1 represent The Travelers [12] Indemnity Company in this lawsuit that has brought us [13] here today. [14] Let me tell you some ground rules. I know [15] from looking at your documents you have been deposed [16] before but just a quick refresher may help. If you [17] don't understand the question, let me know and I will [18] rephrase it, try to make it more dear. [19] The court reporter is taking down everything [20] we say, so please try to give verbal answers, not [21] noddmg your head or saying "uh-huh," it's difficult [22] for him to take that dawn. So please try to bear that Page 6 [1] in mind. [2] As we talked about before, we will take breaks [3] about once an hour, but if you would like them more [4] frequently let me know. P] You have just been sworn to tell the truth and [6] your testimony is the same as if you were testifying in m a court of law, despite the somewhat more informal [8] setting. P] One last reminder. The rule in Delaware [10] prohibits you from discussing the substance of your [11] testimony with your attorney until the deposition is [12] concluded. [13] Any questions? [14] A. No, I don't think so. [15] Q. Have you been deposed before? [16] A. Yes. [17] Q. Can you estimate how many times? [18] A. Fifteen to 2D times. [19] Q. Were those lawsuits bwolving Monsanto? [20] A. Some of them. [21] Q. Do you recall whether you were testifymg as [22] an expert witness for Monsanto in most of time Page 7 [1] depositions? [2] A. I never heard a discussion whether I was there [3] as an expert witness. [4] Q. Did you review any documents in preparation P] for this deposition? [6] A. I reviewed a statement or some discussion on m topics, but nothing of technical. [8] Q. But you did review some documents in p] preparation for the deposition? ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 1 to Page 7 HARTOLDMON0009780 BSADepo of George Roush, [R., M.D. Monsanto v Aetna February 18, 1993 Cr-54456.0XMAX(2) [10] A. Books, a couple of books. [11] Q. Books, okay. What books? [12] A. Patty. [13] Q. That is comparable to Sax, isn't it? [14] A. Yes. [15] Q. A toxicology treatise? [16] A. Yes. [17] Q. All right. [18] A. That is what I looked at most, is toxicology. [W] Q. All right. [20] A. Related to health, environment related to [21] health. [22] Q. These were books? Page 8 [1] A. Yes. P] Q. Do you recall besides Patty the names of any [3] of the books that you reviewed? M A. I looked at an OSHA document on a number of p] chemicals in which they have established PEL'S, [6] permissible exposure limits. m Q. Did you review any documents that were [8] Monsanto documents in preparation for the deposition? P] I just xoant to be dear. [10] A. No. [11] Q. Did you discuss the testimony that you are [12] going to give today with anybody else besides your [13] attorney? [14] A. No. [15] Q. Did you meet with your attorney in preparing [16] for tins deposition? [17] A. With this attorney or some other? [18] Q. Yes, vnth Mr. Jones. [19] A. Yesterday. [20] Q. For how long? [21] A. Too long. r22] Q. Can you give me just a general tone estimate? Page 9 [1] A. Three, four hours. P] Q. Is Mr. Jones your attorney for purposes of [3] this litigation? [4] A. I think so. [5] Q. Are you paying for his services? [6] A. I don't think so. m Q. Is Monsanto paying for his services? [8] A. I wouldn't know. [9] Q. All right. [10] A. That shows how much contact we have had. [H] Q. What I would like to do first. Dr. Roush, is [12] go through and get an idea of your educational [13] background. Would you be aide to start with college [14] and tell me your sort of education as it progressed? [15] A. Went to the University of Wisconsin. [16] Q. When did you graduate? [17] A. It's very peculiar, I was in the Army. [18] Q. All right. [19] A. I was in the Army, and so during that time I [20] was going to Wisconsin. I went there three years. [21] Q. All right. [22] A. Went into the Army- Came out. Went to Page 10 [1] medical school. And when I was finishing medical [2] school I wrote bade and said, hey, give me my [3] bachelor's degree horn Wisconsin. So I graduated from [4] Wisconsin in '51. m Q. All right. [6] A. I mean from Washington University in '51, m medical school. [8] Q. So you got your M.D. and'your bachelor's [9] degree in the same year? [10] A. Yes. [11] Q. Technically, okay. [12] A. After that? [13] Q. Let me ask you one tiring. What was your [14] bachelor's degree in, was it in a particular major or [15] field of study? [16] A. Sure. ' P7] Q. What was it? P8] A. Mathematics. [19] Q. So you have a bachelor's in mathematics from [20] the University of Wisconsin and an M.D. from - [21] A. Washington University in St. Louis. [22] O. Both of those were awarded in '51? Page 11 [1] A. Yes. P] Q. After that? P] A. Internship. I went to Marquette University in [4] Milwaukee, '51 and '52. m Q. What was your internship in? [6] A. General medicine. [7] Q. And then what did you do after your [8] internship? P] A. University of Pittsburgh. [10] Q. AH right. [11] A. Master's in public health. [12] Q. All right. [13] A. And occupational medicine. [14] Q. What year did you get the master's in public [15] health? [16] A. One year. [17] Q. So '53? [18] A. '52, '53. [19] Q. All right. P0] A. And then I had a fellowship from National PH Heart Institute for one year. [22] Q. What kind of work did you do during the Page 12 [1] fellowship? P] A. Studied biochemistry of the foiling heart. [3] Q. All right. [4] A. 1954, 1955. p] Q. All right. ' [6] A. NIH, Bethesda, the Cancer Institute in m chemotherapy for cancer. [8] Q. All right. P] A. '55 - '56, Staten Island Marine Hospital, [10] internal medicine. [11] Q. All right. [12] A. '56 - '57, bade at the University of [13] Pittsburgh. [14] Q. Right. [15] A. In medicine. [16] Q. When you were at Staten Island Marine [17] Hospital, what kind of work did you do in internal [18] medicine? [19] A. Internal medicine. P0] Q. Can you give me just sort of a brief idea of PH what that consisted of? [22] A. It's really a residency in medicine. Page 13 [1] Q. Okay. [2] A. '57 I am back in Pittsburgh. [3] Q. res. [4] A. And I got my first full-time job at the P] University of Pittsburgh, and I was assistant professor [6] of occupational medicine. m Q. Give me a brief idea of what the study of [8] occupational medicine consists of. P] A. It's to prepare physicians to meet the [10] requirements of both the plants, as well as what the [11] public expects of a doctor doing his job. [12] Q. When you say plants, what kind of plants does [13] that field encompass? [14] A. It covers all, I would say all of medicine. [15] That is being kind of broad, but it's plants where [16] it's - U.S. Steel. [17] Q. All right. [18] A. Was in Pittsburgh. A large company. They [19] were there to take care of the workers who get injured P0] at work, because that is a traumatic job, and dedde PI] when a man can go back to work, do the best they can to [22] get him prepared to get back to work. Page 14 Page 7 to Page 14 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMONOOQ9781 BSA Pepo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAX/3) [1] Q. So that P] A. But then if you go into Dupont here, they have [3] a large toxicology unit where they study what the [4] effect of the products they make on a biologic [5] specimen, whether it's a rat, a mouse or a man. [6] Q. Let me stop you here, because you said your m first full-time job was when you were assistant [8] professor, correct? [9] A. Yes. [10] Q. Your fast full time job teas when you were [11] assistant professor at the University of Pittsburgh? [12] A. Yes. [13] Q. Let me stop you here. Throughout your [14] education, which l see you did a lot of post-graduate [15] training, were there any honors or awards that you [16] recall that you got? [17] A. No, all I have is a master's in public health. [18] Q. At any time during the course of your [19] education, and let me just confine this to your formal [20] education up to '57, did you get any formal training in [21] waste disposed, chemical waste disposal? [22] A. No. Page 15 [1] Q. Now is that true through your working career, [2] your time at Monsanto as well as previously? [3] A. When we start talking from 1957 we are talking [4] about a changing expectation of the public. I start [5] out, if you ask me about what environment requires of [6] us, is the first thing they were worried about is air m pollution. [8] Muskie was senator from Maine, and he set up [9] the first law on air pollution control. He didn't [10] worry about water, didn't worry about any other kind of [11] contamination because the concern was they were seeing [12] smog. [13] So our learning and our expectations changed [14] with time. [15] Q. Right, I understand what you are saying. I [16] certainly understand the point that you are making, [17] which I think is that environmental consciousness [18] became much more acute later on, is that correct? [19] A. Yes, and rightly or wrongly. [203 Q. Right. All I am asking is just the simple [21] question, did you during your working career get any r22] formal training in chemical waste disposal? Page 16 [1] A. No. [2] Q. During your working career did you ever take [3] any courses or receive any training on environmental [4] pollution cleanup? [5] A. No. [6] Q. Same question in terms of environmental [7] pollution prevention? [8] A. No. [9] Q. Same question with respect to detecting [10] environmental pollution? [11] A. Did I have a course, you are asking me? [12] Q. res. [13] A. Training? [14] Q. I am saying during your formal education or [15] during your xvorking career do you recall that you ever [16] had ami formal training in, and my last question was [17] detecting environmental pollution. ' [18] A. No. [19] Q. Same question in terms of waste disposal [203 methods? When 1 say waste disposal methods l should [21] say chemical waste disposal methods. [22] A. No. Page 17 [1] Q. Same question in terms of construction of [2] disposal pits for chemical waste? [3] A. No. [4] Q. Same question with respect to landfills? [5] A. No. [6] Q. Same question with respect to waste m incineration, chemical waste incineration? [8] ` [9] [10] A. Training in? Q. Right, formal training. A. All training. No. [11] Q. During your formal education or your working [12] career did you ever have any formal training on [13] pollution abatement or reduction? [14] A. No. [15] Q. How about how to address groundwater or soil [16] pollution? [17] A. No. [18] Q. Did you have any formal training with respect [19] to the properties of soil or geology? [20] A. No. [21] Q. I think this is the last one. In your formal [22] education or your working career did you ever receioe Page 18 [1] any formal training with respect to groundwater? m A. No. [3] Q. I will be more specific later in terms of [4] informal exposure to these areas. [5] A. Could I say something? [6] Q. Sure. m A. The questions you asked me. [8] Q. Yes. [9] A. Was not addressed at the schools of public [10] health, either. We couldn't have gotten the courses [H] you were asking of me. It goes back to my statement of [12] where we are in our expectation. [13] Q. Right. [14] A. But, so I would suspect in the last four or [15] five years there has been a change in schools of public [16] health, where they are becoming more and more involved. [17] Q. Right.. So you are saying a lot of the things [18] I mentioned were not available at the time you were [19] going to school. [20] A. It wasn't even a subject of interest. [21] Q. I understand. [22] A. They could have been, but they were too Page 19 [1] involved in other things. [2] Q. Let's start, and what I vxruld like to do just [3] to make it easier I think is go through and get an [4] overview of your job history, and then what we will do [5] is go back and foots on your time at Monsanto. But l [6] land of want to get a background of what you did m through the years. [8] So we started out in 1957 at the University of [9] Pittsburgh. [10] A. Yes. [H] Q. As an assistant professor in medicine, is that [12] correct? [13] A. Yes - [14] Q. What did you teach? [15] A. In occupational medicine? [16! Q. In occupational medicine, yes. Was the name [17] of the course you taught Occupational Medicine? [18] A. Yes. [19] Q. How long did you remain in that position? [20] A. Can I do it my way, rather than yours? [21] Q. Sure, whatever is easier. [22] A. So when you find out how this is complicated. Page 20 [1] While I was at the University of Pittsburgh they were [2] doing studies at Callery Chemical Company and the [3] effect of these chemicals on man. [4] Q. Callery is? [5] A. C-a-H-e-r-y. They got in trouble and asked [6] me to go out there so I became consultant medical m director at about the same time, so I had two jobs [8] going currently. [9] In a year or two I became medical director, [10] rather than just consultant medical director. [H] In 1952. 1952. My time is lost someplace. [12] Q. That is okay. You said you started at the . [13] University of Pittsburgh in 1957? [14] A. Right. ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 14 to Page 20 HARTOLDMONOOQ9782 BSA Depo of George Rouah, IR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAX(4) [15] Q. If this helps you, just from looking at your [16] documents I think you might mean '62, right? You were [17] medical director at Callery starting in '62? [18] A. In 1962 I watt to the University of [19] Louisville. [20] Q. Okay. [21] A. And there I did cardiac catheterizations on [221 people with heart trouble._________ ____________ __ Page 21 [1] In 1963 I went to University of Cincinnati, [2] and there I became associate professor of occupational [3] medicine. M Q.Is the University of Cincinnati associated pj with Kettering Lab? [6] A. Kettering Laboratory is a part of the [7] Department of PreventiveMedicine. [8] Q. All right. [9] A. And it was the facility in which they did [10] toxicology and things related to public health. [11] Q. All right. [12] A. And preventivemedicine. [13] Q. How Umg wereyou at Cincinnati? [14] A. Five years. [15] Q. Okay. [16] A. To <68. [17] Q. All right. [18] A. 1968 I went to Tulane Medical School in New [19] Orleans. [20] Q. All right, what did you do there? [21] A. I was professor of medicine. And my job was [22] environmental health, environmental medicine, Page 22 [1] toxicology. P] Q. Is that different than occupational medicine? [3] A. It's broader. One was related just to [4] occupation, and mine was general toxicology. [5] Q. How did you familiarize yourself with that [6] field, gioen that it sounds like you didn't haoe formal [7] training in it during your education? [8] A. When I was back at Kettering Laboratory I [9] became medical director of die Ethyl Corporation. How [10] this, I will show you how that relates. I was [11] occupational medicine professor, and the Ethyl [12] Corporation made the anti-knock compound that becomes [13] the thing that makes gasoline work well. And the [14] quarrel was about lead in gasoline. Maybe you have [15] heard that. [16] Q. Right, okay. . [17] A. But that was a big issue. [18] Q. All right. [19] A. My responsibility was trying to find out, does [20] lead in gasoline pose a public health matter. [21] Q. So that was your focus at ethyl? [221 A. Yes. _________ ___________ Page 23 [1] Q. All right. [2] A. And I did that until 1972, and then I went to [3] Monsanto. [4] Q. So you started at Monsanto in 1972? [5] A. Yes. [6] Q. Let me stop you there. When you went, from [7] 1962 to 1963, you were at the Unmersity of Louisville [8] Medical School? [9] A. Yes. [10] Q. Working in cardiology? [11] A. Yes. [12] Q. This was after you had been an assistant [13] professor of occupational medicine and the. medical [14] director for Callery Chemical, is that right? [15] A. Yes. [16] Q- Were youdoing occupational medicine related [17] work in your cardiology work at Louisville? [18] A. No. [19] Q. Did it relate at all to toxicology or [20] occupational medicine? [21] A. No, it relates to occupational medicine. [2Z| Q. In what way? Pna__gefi2t 4 [1] A. The people who work have heart trouble, and [2] somebody's got to decide whether that person with heart pj trouble can do the job in which they were entrusted. [4] Q. So would it be far to say that occupational p] medicine consists not only of toxicology and exposure [6] concerns, but also the fitness of a particular worker [7] for a particular job? [8] A. That certainly is part of it. We have, in P] occupational medicine we have trauma, we have chemicals [10] that are toxic and we have got people who have to do [11] those things. [12] And the question whether they can work there, [13] a man has pain in his chest, has a heart attack, breaks [14] his leg, has a leg taken off, the question is can he go [15] to work. [16] You hear the discussion going today about [17] whether women can do the job the man does? [18] Q. Right. [19] A. Well, that was apart of it back then. [20] Q. All right. [21] A. I used to see, a mart, people would walk past [221 my office down to where they worked. And one man I Page 25 [1] remember so well, he had injured his knee, and he went [2j to the hospital and had it operated on. And he then [3j walked down to path. He looked ten times worse than he [4] had been before he had his surgery, pj Get back to the fact I have got a man who has [6j to do tite job and the question of whether he has the [7] physical capabilities of doing it. [8] Q- All right. P] A. That is a major issue. [10] Q. When you say environmental health with respect [11] to the work you did at Tulane, what does that [12] encompass? [13] A. The people who are in the hospitals may say [14j that his inability to work, because they made him do [15] certain things physically or that he was having [16] complaints because of his work, and the man who takes [17] care of him in his private practice says I don?t know [18] anything about those tilings. And so they would refer [19] him to me. [20] Q. So would it be far to characterize it as the [21] effect of any workplace environment on the health of [2Z| the worker? Page 26 [1] A. Sure. [2] Q. All right [3j A. It was about that time that there was concern [4j about pollution that was started just about then. P] Q. Okay. [6j A. It was on the Mississippi River. And the [7] medical students came over to my lab, and their [8] question was, what are we going to do about this pj polluted river? [10] Q. Okay, so that would be - [11] A. That is the kind of question. [12] Q. - environmental effect? [13] A. Yes. [14] Q. Was it, if you remember, this was around mid [15] '60s, is that correct? [16] A. Late'60s. [17] Q. Late '60s. So was it in the late '60s that [18] you began to see concerns m your field with respect to [19] environmental pollution effect on workers? [20] A. Well, yes, phis the environment, since I said [2lj I was doing lead, and that in the environment. [22] ____ Q. Would that be the earliest time that things. Page 27 [1] like exposure to lead or environmental pollution zoos [2] known? [3j A. During that time there was a plant up the [4j river, Mississippi, that was treating lead and getting pj rid of the waste products, and they were throwing it in Page 20 to Page 27 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMONOOQ9783 BSADepo of George Roush, IR-, M.D. Monsanto v Aetna February 18, 1993 Cr-54456.0XMAX(5) [6] the river. A pound, you know, a pound in the [7] Mississippi River, they couldn't find it that next day. [8] But that is true of all, all companies were doing the [9] same thing, throwing waste into the rivers. The [10] question is how much. [11] Get back to Tulane. The students were brought [12] in to me and they said we want to do something about [13] all this pollution from the chemical companies. I said [14] to them, if we can get rid of the human waste that is [15] in the river it would do a lot more to the health than [16] clearing up that one pound of mercury. So it was just [17] really going to get started. [18] So they said, you have been working on lead, [19] can you help us do a study on lead? And so we brought [20] in a car from ethyl and took the exhaust from that and [21] put it into a container, into a box where we had - we [22] put the rats into a box where they breathed that air, Page 28 [1] and then I had another box where they didn't have. [2] The rats in the box where the lead was had [3] better lungs than the ones that didn't have it. And [4] all of medical school was starting to worry about where [5] this fit. [6] But it's so demanding in terms of time. [7] Q. So the awareness was being heightened in the [8] late'60s? [9] A. Yes, that's right. [10] Q. Okay. [11] A. At the same time we were talkingabout, I was [12] involved in space medicine, I helped to design the [13] first space capsule in terms of requirements in space. [14] Now I wasn't with the one that finally became accepted [15] by NASA, but I am sure part of your recommendations of [16] what was required became a part of it. I became a part [17] of submarine medicine. [18] Q. Okay. [19] A. Not broadly, but like everyoneelse,there are [20] a whole lot of pieces that become a part of it. [21] Q. You started at Monsanto in 1972? [22] _____ A. (Witness nods head.)__________________________ Page 29 [1] Q. I ant sorry, is that a yes? [2] A. Yes. [3] Q. What was your first position at Monsanto? [4] A. Associate medical director. [5] Q. For the whole company? [6] A. Yes. [7] Q. How long did you stay in the position of [8] associate medical director? [9] A. I went there with the recognition I would be [10] medical director in a year. [11] Q. So did you become medical director [12] A. Next year. [13] Q. In '73? [14] A. Yes. [15] Q. Before I ask you more detailed questions about [16] both those positions at Monsanto, are you retired from [17] Monsanto? [18] A. Yes. [19] Q. Do you receive a pension from Monsanto? [20] A. No. [21] Q. Are you a Monsanto stockholder? [22] A. No. Page 30 [1] Q. You don't own any Monsanto stock? [2] A. No. [3] Q. So you are retired from Monsanto? [4] A. Yes. [5] Q. What year did you retire? [6] A. 1988. [7] Q. Haoe you done consulting work for Monsanto [8] since 1988? [9] A. I have had a contract that I was to came in [10] once or twice, every month or two I would go in. [11] Q. What kind you have work did you do? [12] A. Helped them to decide what they should be [13] doing next or interpret what they had to work on. [14] Q. Okay, and - [15] A. I was a part of a committee that included two [16] people from New York State Medical School and bom. [17] University of Wisconsin and from Vanderbilt, and I was [18] the fifth one. . [19] Q. What was the committee called? [20] A. Biohazards Committee. [21] Q. Were you on the Biohazards Committee before [22] you left Monsanto?____________________________._________ _ Page 31 [1] A. No, I set up the Biohazards Committee. [2] Q. This was after retiring? [3] A. No, I had to set it up before. [4] Q. And then were you a member of the committee [5] before 1988? [6] A. Before that I was the one who said what they [7] did. [8] Q. AH right. [9] A. I was the director. [10] Q. So you weren't a committee member until after [11] you retired? [12] A. Right. [13] Q. Can you gioe me sort of a broad idea of what [14] the Biohazards Committee did? [15] A. One of them was a professor of biochemistry, [16] another one was a professor of toxicology, another one [17] was a specialist in cancer. I think that's it. [18] Q. What were you the specialist on? [19] A. Well, until 1988 I told them what we are going [20] to work on this next meeting. [21] Q. As medical director? [22] ________________ A. Correct. __________________ Page 32 . [1] Q. All right. [2] A. After that I became a participantin telling [3] what the practical issues are and how what they were [4] doing applied. [5] Q. To occupational - [6] A. Monsanto's needs. [7] Q. When you say Monsanto's needs, are you talking [8] about concerns regarding occupational medicine? [9] A. Yes, and broader than that, environmental [10] issues. [11] Q. How long after 1988 when you were a member of [12] the committee did you remain on the Biohazards - [13] A. I still am. [14] Q. You still are, okay. [15] You said you had a contract, so Monsanto paid [16] you based on an amount set forth in your contract after [17] you retired? [18] A. Yes. [19] Q. You continue tobe compensated under that [20] contract? [21] A. Yes. [22] ____ Q. Are you being compensated by Monsanto for your Page 33 [1] time m this deposition? [2] A. We neverdiscussed it. [3] Q. You don't know one way or the other no. [4] Q. All right. [5] A. Sometimes I get paid and sometimes I do not [6] when I get involved in depositions. [7] Q. All right. Linder your contract for the [8] Biohazards Committee work is that an hourly rate? [9] A. Day. [10] Q. Daily rate? [11] A. By day. [12] Q. How much is the daily rate? [13] A. It's a thousand dollars for two days. [14] Q. Is that the rate that you are compensated in [15] the depositions that you haoe appeared previously? [16] A. Very similar, it's not the same but it's [17] almost. It depends how long the day is. [18] Q. You don't haoe a separate agreement far [19] deposition testimony? ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 27 to Page 33 HARTOLDMONOOQ9784 BSA Depo of George Roush, 1R., M.D. Monsanto v Aetna February 18, 1993 Cr-54456.0 XMAX(6) [20] A. No. [21] Q. Do you burnt whether you are being compensated f221 fry Monsanto for time spent preparing for this______________ Page 34 [1] deposition? 2] A. Sometimes I don't get involved with [3] compensation, so I can't tell you what is going to take [4] place. [5] Q. In terms of this deposition, though. [6] A. Yes. [7] Q. Do you know whether you are going to be [8] compensated for your prep time? [9] A. I do not. [10] Q. All right. [11] A. Or even for the deposition. [12] Q. Okay. When you started as associate medical [13] director at Monsanto, the medical director at that time [14] was Dr. Robert Emmett Kelly, is that right? [15] A. It was R. G. Kelly. He was Emmett to us. [16] Q. Did Dr. Kelly hire you? [17] A. Yes. [18] Q. Was he your direct boss? [19] A. Yes. [20] Q. Can you give me a general idea of what your [21] duties were as associate medical director? [22] _____A. Occupational medicine varied, we have sort of Page 35 [1] implied that. [2] Q. All right. [3] A. The people that worked in headquarters did [4] examinations. Monsanto has a program set up where they [5] get physical examinations on a periodic basis to [6] everyone who wants an examination. m Q- These are the headquarter employees? [8] A. That was mine, but at the plants where they [9] are big enough to have a full-time physician there is a [10] physician at that plant who does the same thing. [M] Q. So you were at charge of that program for St. [12] Louis? [13] A. And for foe rest of foe country, too. [14] Q. All right. [15] A. But I really can't say that. Dr. Kelly and I, [16] we divided up responsibility. [17] Q. Did you oversee the plant physicians for the [18] plants that you were responsible for? [19] A. Yes. [20] Q. Were you responsible for the Texas City plant? [21] A. Yes, but, you see, once a year, and by that [22] year I was out of that responsibility.______ ._________ Page 36 [1] Q. I see[2] A. So that timing gets difficult. [3] Q. During the year that you were associate [4] medical director, did you work closely with Dr. Kelly? [5] A. Yes. [6] Q. Daily contact withhim? [7] A. Yes. [8] Q. Were there any,and again, this is directed [9] toward your time as associate medical director, were [10] there any special assignments or special projects that [11] you had particular responsibility for? [12] A. Not in that first year. [13] Q. So it was very broad? [14] A. Right. It was trying to learn what is out [15] there. [16] Q. Would it be fair to say it was almost training [17] for the[18] A. Yes. [19] Q. - medical director position? [20] A. Yes. [21] Q. Who else did you work with when you were [22] associate medical director?________________ . Page 37 [1] A. Well, that is people whom Dr. Kelly had in his [2] office. [3] Q. Do you recall any names? [4] A. Oh, yes. It was Elmer Wheeler. [5] Q. All right. Anyone rise? [6] A. Elmer Wheeler had some notoriety. He had been [7] director, or president of foe International Hygiene [8] Association. [9] Q. So he was anindustrial hygienist? [10] A. Yes. [11] Q. All right. [12] A. At least he functioned at it. [13] Q. All right. [14] A. It was broader than that. [15] Q. Did you uxnk closely with Mr. Wheeler? [16] A. Yes. [17] Q. All right. [18] A. He went with me to same of foe plants that I [19] wanted to see, he went with me to Texas City, for [20] instance. [21] Q. Anyone else you worked closely with during m yTM- Page 38 [1] A. We had Jack Garrett. [2] Q. All right. [3] A. Who was an industrial hygienist who worked [4] with Elmer and Dr. Levinskas, who was foe toxicology |5] person. [6] Q. All right. [7] A. For Monsanto at that time. He started [8] toxicology. [9] Q. What kind of Brings did you work on with, is [10] it Mr. Garrett or Dr. Garrett? [11] A. Mr. Garrett. [12] Q. Mr. Garrett. What kind of things did you work [13] on? [14] A. He worked for Elmer, not with me. [15] Q. Okay. [16] A. So he would talk with me about what he was [17] doing, but we didn't get involved in any study [18] together. [19] Q. How about Dr. Leomskas, did you do any work [20] with him? [21] A. No. [22] ____ Q. During your time as assistant medical Page 39 [1] thredor, did you do any work with state or federal P] regulatory agencies? [3] A. No. [4j Q. Who was responsible for that in the Medical [5] Department? [6] A. If there was some contact with Washington it [7] was Dr. Kelly. [8j Q. During the time you were assistant medical P] director and I realize this is just that one year, did [10] you do any work on chemical waste disposal? [11] A. POE'S. [12] Q. What did your work ToithFOB'S involve? [13] A. Mr. Wheeler, I am talking about what other [14] people did. [15] Q. Okay. [16] A. He wasinvolved in following FCB's as a health [17] issue, as a public health issue, government relation. [18] It was about that time they found that FCB's were [19] present in water. [20] Q. Just to make sure l understand, were you doing [2.1] any toork personally with Mr. Wheeler on this? [22] A. No, I was understanding what the issue was. Page 40 [1] What's the big deal, you know. pj Q. Because a year later he would be reporting to [3] you? [4] A. Yes. [5] Q. All right. [6] A. But not only that, since I hadn't been [7] thinking about FCB's before, why had it become an [8] issue. P] Q. All right. [10] A. What is theissue. Page 33 to Page 40 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMONOOQ9785 BSA Pepo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAX(7) [11] Q. Was that the only involvement with waste [12] disposal, chemical waste disposal issues you recall? [13] A. Yes. [14] Q. All right. [15] A. But that was a big one. See, we were involved [16] on FOB'S in Scandinavia. It was about that time that [17] there was a big poisoning episode that took place in [18] Japan, and how did we get into this, you know? [19] Q. Right, okay. In the assistant medical [20] director position was there any work during that year [21] you did on pollution issues? [22] ____A. I don't think so. Page 41 [1] Q. I know you said you didn't work with the [2] regulatory agencies during that year, but did you do [3] any work with respect to complying with regulatory or [4] permit limits? [5] A. No. The place we were working was in [6] compliance of the exposure of the workers for Monsanto. [7] Q. Okay. [8] A. That we guaranteed to the workers as well as [9] to Monsanto that no one's going to be exposed to the [10] chemicals Monsanto is making. [11] Q. When you say the place we are working, are you [12] saying Monsanto headquarters or whatever plant you were [13] involved with? [14] A. In the plants where the material was being [15] made, that the workers that were making them were not [16] being exposed at a level that was inconsistent with the [17] government requirement. [18] Q. That was a goal of the Medical Department? [19] A. Yes. [20] Q. All right. [21] A. Responsibility. . [22] _____ Q. That would be a responsibility to keep____________ Page 42 [1] exposure within OSHA limits? [2] A. Yes. [3] Q. Would that also be NIOSH limits? [4] A. At that time the relationship between NIOSH, [5] they reported to different heads, one reported to EPA [6] and the other one reported to NIH, or to the National [7] Institutes of Health. So they were almost at [8] loggerheads in terms of what were the levels that were [9] expected. [10] Q. All right? [11] A. We had to work with both, obviously. [12] Q. Were there any other regulatory agencies that [13] had limits that the Medical Department had [14] responsibility to stay within? [15] A. That is a very broad question. We have got 15 [16] plants. [17] Q. Right. [18] A. And there were state health officers that [19] could be interested in what - [20] Q. So it would be the state equivalent of OSHA or [21] NIOSH? [22] A. Right. Page 43 [1] Q. All right. [2] A. But they didn't really get very much involved, [3] they didn't have the kind of staffs that NIH has. [4] Q. You said 15 plants. Monsanto is more than 15 [5] plants, right? [6] A. Large plants. m Q- So you are talking about the 15 largest? [8] A. Yes. [9] Q. Was Texas Cityincluded in that? [10] A. Yes. [11] Q. Do you recall during your time as associate [12] medical director you had to do any projects involving [13] pollution abatement or reduction? [14] A. No. [15] Q. No involvement with anything relating to that? [16] A. No. [17] Q. Let me make sure you understood me. When I [18] said pollution abatement or reduction, I meant [19] abatement or reduction of environmental pollution? [20] A.Yes. [21] Q. You understood that? 1221 A. Yes. Page 44 [1] Q. Finally, did you do any work during your year [2] as associate medical director with respect to [3] environmental pollution cleanup? [4] A.No. [5] Q. All right. [6] A. You see, if you ask that question to someone [7] from government they would have said no, too. Back at [8] that time there was little or no effort being made to [9] dean these up. [10] Q. Right,there were not ongoing cleanups. [11] A.That's right. [12] Q. Okay, I understand. [13] A. So our awareness and concern about the [14] environment has increased. [15] Q. Yes, I understand that. I am basically just [16] trying to be thorough. [17] A. So what you talk about then, you can't talk [18] about, you have got to somehow keep it in context. [19] Q.Sure. [20] A. FOB'S was an ongoing when I came, it was a [21] very big issue. [22] ____ Q. But are you saying that at that time - Page 45 [1] A. National issue. [2] Q. But are you saying, I mean when you answered [3] no to my question in terms of I didn't do any work with [4] respect to environmental pollution cleanup, are you [5] saying there wasn't any ongoing PCB cleanup that l was [6] working on? [7] A. No. [8] Q. There wasn't? [9] A. No. [10] Q. I flunk we understand each other. I am more [11] trying to get an idea of what the scope of your [12] responsibilities were. [13| A. Yes, but you see when you talk about what [14] scope is, if no one else was doing it in the world, [15] then what are we talking about when you say what nobody [16] else is doing. [17] Q. Right. [18] A. But if you get to FCB's that would be a good [19] example of what is done. [20] Q. All right. [21] A. Because that happens just about this time. [22] When Emmett retired, it was that time I went to the Page 46 [1] first national meeting and it was on PCB's. [2] MS. WALSH: I want to show you a document. [3] Would you mark this Roush Exhibit 1. [4] (Deposition Exhibit 1 was marked for [5] identification.) [6] BY MS. WALSH: [7] Q. Dr. Roush, this is marked Roush Exhibit 1. [8] The rules require we use your name in marking the [9] exhibit. I would appreciate if throughout the [10] deposition you would be sure to handle the copy with [11] the sticker, that way we know you are looking at the [12] official copy that is gobtg to be attached to the [13] transcript. [14] Could you take just as long as you need to [15] read through this? [16] (Witness examines document.) [17] BY MS. WALSH: [18] Q. You have had a chance to look at Exhibit 1? [19] A. Yes. [20] Q. This is a September 26, 1973 memo. Is that [21] your signature at the end of page 2? [22] A. Yes. Page 47 [1] Q. So you preparedthis? ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 40 to Page 47 HARTOLDMONOOQ9786 BSADepo of George Roush, IR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0XMAX(8) [2] A. Yes. [3] Q. Is this Monsanto letterhead? [4] A. Yes. P] Q. This is, September 26, 1973, would you still [6] have been associate director? [7] A. Yes. [8] Q. Since Dr. Kelly is listed on the c.c. list? I P] am sorry, is that a yes? [10J A. Yes. [H] Q. Who is John Fox? [12] A. He winked at the Texas City plant. [13] Q. Do you recall what he did? [14] A. He was sort of the environmentalist at Texas [15] City. [16] Q. Do you recall why you would have been giving [17] him the results of a urinary phenol study? [18] A. Why I would? [19] Q. Yes. m A. Because, he did this because I asked him to. [21] Q. So he actually did the work? [22] A. Yes. Page 48 [1] Q. Do you recall whether there was a concern [2] about benzene exposure in 1973? [3] MR. JONES: Objection, vague. [4] BY MS. WALSH: [5] Q. You can answer. [6] A. I can't recall. [7] Q. All right. [8] A. But I can tell you what it was. . [9] Q. What teas it? m A. Urinary phenols. We all put out phenols in [11] our urine and the levels are related to exposure to [12] benzene. [13] Q. Do you - [14] A. Not necessarily. [15] Q. All right. [16] A. But it is related to it. And the question is [17] trying to find out the little bit that is not. [18] Q. All right. . [19] A. Or if the exposures are very high like this [20] zeal whose name is listed that is where the [21] occupational exposure was higher. [22] Q. So you did a study - Page 49 [1] A. This is occupational medicine, this is not [2] environmental medicine. [3] Q. How did those differ in your view? [4] A. This is a man's excretion of phenol in his [5] urine as related to their exposure to benzene. But [6] it's occupational medicine because we have to be able [7] to separate that that we are measuring deciding whether [8] it's from other things that you do that produce phenols [9] or whether it's due to the benzene. [HU Q. Do you recall why you wanted to determine [11] workplace exposure to benzene? [12] A. Because we want to know a man's exposure to [13] benzene. [14] Q. Why did you want to know that exposure? [15] A. Because we wanted to know all chemical [16] exposure. People working in a plant, as we said [17] earlier, are exposed to chemicals and we want to know. [18] keep up to date on what the effect of those chemicals [19] are on them. This is one way of doing it. m Q. My question is, was there a specific concern [21] about the properties of benzene at that time that r22] motivated this study? . Page 50 [1] MR. JONES: Objection, vague. [2] BY MS. WALSH: [3] Q. You can answer. [4] A. We were interested in whether a man had an [5] excess exposure to benzene, and this is one way to do [6] it. [7] Q. Right. [8] A. So we had a test that said - down here where . [9] it said we did blood counts? [101 Q. Right. [HI A. Really what we wanted to measure ate blood [12] counts, but the blood counts can't be measured in 1 out [13] of 50. Your blood count is different than mine. If I [14] use blood counts, I have got to explain that [15] difference. [16] Q. Okay. [17] A. That is harder than to do it this way. [181 MR. JONES: Just off the record. [19] (Off-the-record discussion.) [20] MS. WALSH: Let's go back on. PI] BY MS. WALSH: 122] Q. I understand what you are saying about the Page 51 [1] methodologies that are discussed here. My question [2] is m MS. WALSH: Let me rephrase that. [4] BY MS. WALSH: p] Q. Was benzene known to be a carcinogen in 1973? [6] MR. JONES: Objection, vague. [7] A. Yes. [8] BY MS. WALSH: P] Q. Was that why you started to study exposures of [10] workers to benzene? [11] A. They had been studying benzene in the blood [12] for a long time before that. [13] Q. Monsanto had? [14] A. Sure. [15] Q. As part of a routine monitoring at plants? [16] A. No, related to their exposure to benzene. [17] Q. Do you recall when studies with respect to [18] benzene began? [19] A. No. P0] Q. Would it have been before your time at [21] Monsanto? [22] A. Yes. Page 52 [1] Q. Based on your knowledge of occupational P] medicine prior to your time at Monsanto, do you have a P] general recollection of when concern about benzene as a [4] carcinogen arose? [5] MR. JONES: Same objection, he can only [6] testify as to what he was concerned about. m BY MS. WALSH: [8] Q. Right, that is what I am asking. Based on P] your experience do you remember the earliest that there [10] was a concern about benzene as a carcinogen? [11] A. In the '50s. [12] Q. In the '50s? [13] A. Maybe earlier. [14] Q. Do you know that from work you did, or from [15] literature? [16] A. I taught it. [17] Q. As a result of this urinary phenol study were [18] there any changes in worker handling procedures with [19] respect to benzene? po] A. No. [21] Q. Why was that? [22] A. It didn't improve our ability to decide how Page 53 [1] much exposure to benzene there was. P] Q. All right. [3] A. The statement where it says a study of the [4] hemograms revealed there was no dear benzene effect. m Q. All right. [6] A. So we were successful, and if we did it more [7] it was to ensure we stayed successful. [8] Q. Was your conclusion from the urinary phenol P] study that urinary phenol studies couldn't tell you the [10] exposure to benzene, or was your conclusion that there [11] wasn't an unacceptable exposure to benzene? [12] MR. JONES: Objection, leading. [13] MS. WALSH: You can have your objection to [14] leading. [15] MR. JONES: Correct. Page 47 to Page 53 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMONOOQ9787 BSA Depo of George Roush, IR., M.D. Monsanto v Aetna February 18, 1993 Cr-54456.0___________________ XMAX(9) [16] MS. WALSH: Defendants disagree with it for [17] the record. [18] A. It says there are five explanations. [19] BY MS. WALSH: [20] Q- Right- [21] A. And our condusions was that workers do absorb [22] benzene, you can't work with it without exposure. This Page 54 [1] group was not above the TLV. [2] Q. That is "threshold limit value?" [3] A.Yes. [4] Q. Bui 1 guess what I am saying is, I understand [5] what the points of the memo were. What I don't [6] understand from the memo and what I am asking you if m you recall is, was the conclusion that the urinary [8] phenol study is a good test, is an accurate test, our [9] workers are below TLV leads, or was the conclusion [10] that the urinary phenol study is not a good test to [11] measure benzene exposure? [12] A. It's like everything in medicine, it depends. [13] Q. Okay. [14] A. You look at a population. And if die benzene [15] is in the normal range and if 1 have got somebody who [16] then has a urinary phenol that is up, that urinary [17] phenol is not related to this or else he had an [18] exposure that they didn't investigate, in other words [19] he tried to hide it. [20] So the follow-up of this is it's good for [21] looking at individual cases rather than having a survey [22] that we set this up to do._____________________________ Page 55 - [1] Q. Okay. [2] A. So we are still talking medicine, though. [3] Q. I think I may be sounding more complex than [4] what 1 am trying to be. Let me just tell you the [5] background of my question and why I am asking. I don't [6] have the transcript in front of me, but I am tdling [7] you the best of my recollection. [8] In Mr. Fax's deposition my understanding was [9] that Ids thought on this urinary phenol study was that [10] there were too many other factors that influenced the [11] urinary phenol level for it to have a lot of usefulness [12] to measure benzene exposure, but he didn't recall [13] whether the test was changed or whether the phenol [14] study continued, albeit with flaws, and what I am [15] asking is do you recall based on the conclusions about [16] the urinary phenol study whether you continued to use [17] it at Monsanto? [18] A. The fact that it didn't go up and that it can [19] only be used to pick up high exposures or I will have [20] higher exposures that aren't related to it, that we did [21] not continue it. [22] ____ Q. Do you recall whether you instituted other Page 56 [1] tests to measure benzene exposure? [2] A. OSHA. [3] Q. All right. [4] A. Has a requirement that if theblood, if the [5] exposure to benzene is high then you have got to do [6] blood counts more frequently. [7] Q. Okay. [8] A. And the reason that is taking place is because [9] blood counts are done all the time, that is a routine. [10] We don't have to learn to do that. We don't have to [11] follow through like you would with the phenol. [12] Q. Okay. [13] A. In other words, phenol is not asubstitute for [14] doing blood counts. [15] Q. So there were government guidelines interms [16] of how you had to - [17] A. Not then, but there was, discussion was taking [18] place on this. [19] Q. Were there eventuallygovernmentguidelines in [20] .terms of how you had to address benzene exposures? [21] A. There is now. [22] ____Q. There is now, okay.__________________________ ' i Page 57 [1] A. Yes. [2] Q. Was there in 1980? [3] A. Yes, you know, not - not one thatwe had to [4] follow. [5] Q. Do you recall in the early, mid 70s whether [6] there were arty recommended examination procedures for [7] workers who may have been exposed to benzene? [8] MR. JONES: Objection, vague. Recommended by [9] whom, government? [10] MS. WALSH: Recommendedby government or [11] recommended by Monsanto. [12] A. Well, if it was recommended by Monsanto we [13] would be doing it. [14] BY MS. WALSH: [15] Q. AH right. [16] A. The quarrel is when did we know clear . [17] enough - there is still a quarrel. [18] Q. In terms of what? [19] A. Yes. [20] Q. What was Monsantc/s examination procedure for [21] workers that may have been exposed to benzene? [22] ______A. I told you we did on a regular basis once a Page 58 [1] year or more, we would do a physical examination on [2] everyone that worked for Monsanto. [3] Q. Okay. [4] A. Included in that would be those people exposed [5] to benzene. [6] Q. All right. [7] A. And then doing that we would then get the [8] blood counts that would enable us to determine whether [9] they were having excess exposure. [10] Q. So that would be part of their annual [11] physical? [12] A. That's right. [13] Q. Okay. [14] A. And the other thing is that we knew there was [15] exposure to benzene so they were monitoring the [16] exposure to benzene. So we had two cross-checks. [17] Q. You are anticipating my next question, that is [18] when you started as medical director was there a [19] medical monitoring program for benzene? [20] A. That was a blood count. [21] Q. That was a blood count? f22] A. Yes. Page 59 [1] Q. Was that something Monsanto initiated itself, [2] or was that government mandated? [3] A. I can't, I don't remember. [4] Q. Do you recall - [5] A. But you see when you take these things out of [6] context, there was one big episode of benzene poisoning [7] in Dayton, Ohio, where rubber people who were working [8] with benzene and had exposure and their blood counts [9] were affected by it. [10] OSHA is still using that study from the early [11] '50s to decide what there should be an exposure. In my [12] teaching - oh, they were worried the one part per [13] million, TLV is one part per million. In my teaching I [14] said you don't see an effect below 25 ppm. That 25 ppm [15] effect you get is not going to be the one we worry [16] about here. [17] Q. All right. [18] A. Over in, we always talk about this, when you [19] take everything out of context, over in Turkey there [20] is, they are having a business, it's called cottage [21] industries. [22] ______ And the people who worked in these small Page 60 [1] plants, they were putting rubber soles on shoes. They [2] had to paint the shoes with benzene to make the rubber [3] attach. Their exposure was over a hundred ppm. They | [4] got leukemia. j [5] Q. Okay. [6] A. So that is for removed from what we were ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 53 to Page 60 HARTOLDMONOOQ9788 BSADepo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0XMAX(10) [7] talking about because we were trying to tell whether we [8] could tell if there was any abnormal. [9] Q. I understand that. Let me just say, because I [10] was drawing a distinction before, tell me if you are [11] undear on the timeframe l am asking about. In general [12] what I am going to ask you about from here on out [13] throughout the deposition covers your whole time as [14] associate medical director or medical director at [15] Monsanto, in other words it caoers your years at [16] Monsanto. [17] A. Yes. [18] Q. One last question about benzene. Do you [19] recall whether you were or anyone in your department [20] did any carcinogenicity studies on benzene? [21] A. You can't do carcinogenicity studies on [22] benzene.______________________________ _____________ Page 61 [1] Q. Wry not? [2] A. Because exposures aren'thigh enough. [3] Q. All right. [4] A. We didn't havethe kind of exposures they had [5] at Goodrich in Dayton. [6] The quarrel Way that is about benzene and [7] man's exposure is do we have to go down to one part per [8] million and.lower, and they say well we can't get down [9] there, then they find out they can, then the quarrel [10] goes away once we have established they can do it, [11] whether it was necessary or not. [12] Q. Okay. [13] A. It's a health issue that we, like so many [14] things, whether it's AIDS or whatever. [15] Q. So are you saying it was the determination of [16] the Medical Department that exposure was low so there [17] wasn't a need for carcinogenicity studies? [18] A. Well - oh, yes. [19] Q. But the Medial Department had the technology m and the ability to do carcinogenicity studies, is that [21] right? [22] ____ A. A carcinogenicity study is related to the dose Page 62 [1] of what you are exposing them. [2] Q. All right. [3] A. It's not a different study, it's related [4] Monsanto we were working at one part per million. To [5] get into the cancer level at which it happens it's over [6] a hundred ppm. [7] Now the issue today is how do you know that if [8] you did a large enough population that you wouldn't [9] find cancer at one part per million? I don't know how [10] to do that study because they would have to have such a [11] large population. [12] Q. But did you study the Monsanto workers that [13] were exposed to benzene? [14] A. It's the same study. [15] Q. So inherent in the monitoring and - inherent [16] in the monitoring you did for benzene would be a [17] carcinogenicity result? [18] A. We would be able to, carcinogenicity on this [19] is leukemia. [20] Q. Right. [21] A. It's acute myelogenous leukemia. [22] Q. All right._________ .___________ ;_______________ Page 63 [1] A. You don't see it, but if we say, well, let's [2] make real sure that we don't see it, then you use the [3] one part per million standard. [4] Q. All right. [5] A. It's a matter of how far, how safe. If it [6] cost a million dollais to do it, we wouldn't be doing [7] it. [8] Q. All right. [9] A. It has a relationship that, dose, we talk [10] about our dose was one ppm, in order to get leukemia [11] it's a hundred ppm or higher, and if they do get it [12] they don't get it in the form in which they say it. [13] Our problem is we can't tell the leukemia that any [14] person gets from die leukemia that a man that works [15] with benzene gets, when this could be the kind he would [16] have gotten if he hadn't worked with benzene. [17] But if we got a man who has leukemia, we sure [18] go bade to that plant and make sure that their [19] exposures are low. [20] Q. Okay. [21] A. You know, Butt's common sense. 1221 MS. WALSH: That is all for Exhibit 1. Page 64 [1] Would you like a break? We have gone about an [2] hour, why don't we take a five-minute break. [3] THE WITNESS: Very good. [4] (Recess.) [5] MS. WALSH: We are back on the record. [6] BY MS. WALSH: [7] Q. During your time at Monsanto, so this would be [8] from 1972, on, were there any responsibilities you had [9] that were outside your job titles, what I am thinking [10] of is examples, as examples would be committees or [11] special assignments or special areas of expertise? [12] A. I don't know whether the question can be [13] answered with a yes or a no. What is the question? [14] Q. I am asking if there were things you did [15] outside your job title in the course cf your work at [16] Monsanto. In other words did you have any special [17] assignments or committee assignments that weren't part [18] of being medical director that, in other words I am [19] trying to be thorough in terms of what kind of work did [20] you do and was there work you did that was outside your [21] job title? [22] A. No. Page 65 [1] Q. No, okay. Wren you started as medical [2] director did you receive any additional formal [3] training? [4] A. No. [5] Q. Outside your work at Monsanto were you a [6] member cf any professional organizations? [7] A. I was a part of the Occupational Medicine [8] Association. [9] Q. Did you do any work with them? [10] A. Yes. [11] Q. What did you do with them? [12] A. Help explain to them about chemicals. In [13] other words I participated in increasing their [14] knowledge of these chemicals. [15] Q. Was the Occupational Medicine Association, did [16] they have some kind of role in disseminating chemical [17] information? [18] A. They have an annual meeting. [19] Q. All right. [20] A. And I was the director of a subcommittee on [21] toxicology. [22] Q. Okay. Page 66 [1] A. As well as how to monitor it. I was a part of [2] the American Conference of Government and Industrial [3] Hygienists that writes the TLV's. [4] Q. Okay. Any[5] A. I was a member of the Medical Directors Forum, [6] where we communicate back and forth how they do that as [7] opposed to how we do it, in other words increasing the [8] knowledge of the whole group. [9] And I was a member of the Rammazini Society. [10] Q. What is that? [11] A. It's a committee, or a group of 30 physicians [12] who practice occupational medicine. And you can't be a [13] member of that august organization as long as there are [14] 30 people in it, so it's a selective group. [15] Q. Is it similar to the other organizations you [16] have named in that their role is to disseminate [17] information? [18] A. No. [19] Q. What did they do? [20] A. Rammazini? Page 60 to Page 66 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMONOOQ9789 BSA Depo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAXfll) [21] Q. Yes. [22] ____ A. They talk about their relativesuccesses and Page 67 [1] failures. [2] Q. All right. [3] A. In other words it improvesthe general [4] standard of the whole group by meeting together, p] Q. Information sharing withinthe group? [6] A. Yes. [7] Q. Do you know what theIndustrial Medicine [8] Association is? [9] A. That is part of the occupation [10] Q. Okay. Were you part of the industrial hygiene [11] foundation? [12] A. No. [13] Q. 1 am not sure if this is before or after your [14] time at Monsanto. Some of the documents I have looked [15] at say that you did some work for the Lead Institute, [16] is that right? Is that part of your work at Ethyl? [17] A. Yes. [18] Q. What isthe Lead Institute, is that a separate [19] thing? [20] A. Yes. [21] Q. So it's not partof Ethyl? [22] A. What?___________________ _______________ Page 68 [1] Q. The Lead Institute is not part of Ethyl? [2] A. No, no. [3] Q. What is the Lead Institute? [4] A. The Lead Institute is the, an organization in [5] which those people interested in lead. [6] Q. When were you a member? [7] A. Prom the time I went to Ethyl Corporation [8] until I left. [9] Q. Until you left Ethyl? [10] A. Yes. [11] Q. Did you do any projects for the Lead [12] Institute? [13] A. It's hard for me to answer the question. I [14] can't answer that question. [15] Q. You don't remember? [16] A. Yes, but my assignment, I can't say whether [17] I - since I was doing it within the lead industry and [18] I did a study, would I be doing it for the lead [19] industry, was I doing it for myself or for Ethyl. All [20] three of them have interests in that. [21] Q. Would the majority of your work on lead be the [221 project you worked on at Ethyl?________________________ Page 69 [1] A. Yes. [2] Q. So that was the main, that was the main thrust [3] of all your work on lead? [4] A. Lead in gasoline was a national issue. [5] Q. Right? [6] A. I became one of their spokesmen. We had [7] national meetings at which I attended and I would [8] always give - the subject of how much lead you got in [9] your body and was it coming from lead in gasoline or [10] was it from some other source. [11] Q.Okay. [12] A. Just now they are now talking about kids [13] saying they shouldn't have any lead. [14] Q. In your studies of lead in gasoline were you [15] determining acceptable amounts of lead that could be in [16] gasoline? [17] A. That would be a consequence. [18] Q. All right. , [19] A. But our responsibility was to tell them what [20] would happen if they took it out in terms of man's [21] exposure. [22] _____ Q. So your tooth was, if you reduce the lead in Page 70 [1] gasoline, here are the health effects? [2] A. No, mine was whether they would have any [3] effect on the lead you have got in your body. [4] Q. Whether reducing lead in gasoline reduced p] overall - [6] A. Yes. [7] Q. - lead levels inhumans? [8] I am sorry, is that a yes? P] A. Yes. [10] Q. What wasyour conclusion? [11] A. You see, it's not - if I say yes or no, it [12] doesn't Teally answer foe question of what was being [13] done. I can't answer that question by a yes or no. [14] Q. let me rephrase it, I may not have been clear. [15] Did you conclude that lowering the amount of lead in [16] gasoline would lower the amount of lead within peoples [17] bodies? [18] A. Yes. [19] Q. Okay. [20] A. But, see, thatdoesn't answer, because if it's [21] all within the normal limits, like everything else, we [22] all don't have the same thine of most things, but if I Page 71 [1] studied them would I be able to detect a difference in [2] this group. And the answer is probably yes. [3] Q. At some point during those years they phased [4] out leaded gasoline, correct? p] A. Who phased them out. [6] Q. The manufacturers, didn't they? [7] A. No. [8] Q. When was leadedgasoline phased out? P] A. About the time I came here. [10] Q. About the time you started at Monsanto? [11] A. Yes. [12] Q. In '71? [13] A.Yes. [14] Q- So that was after your study - [15] A. But you see there is a great quarrel .going [16] before, can they get it done. [17] Q. When you say can we get it done, can we get [18] the lends of lead in gasoline down? [19] A. No, whether we can - it has - now we are [20] talking about die chemistry, can you have a gasoline [21] that works in our cars today without lead. m______ SLgg!____________________________ Page 72 [1] A. That was the question. [2] Q. All right. [3] A. Then the next question, if they say yes, what [4] would happen if you did that? ' [5] Q. Did any of your work on the lead in gasoline [6] project irwoboe locking at the health effects of other [7] exposures to lead? [8] A. All these questions are not simple yes or no [9] answers. [10] Q. Okay. Well, that is not really, I mean, what [11] / am asking about is the scope of what you looked at in [12] terms of lead exposure, in other words, I am saying [13] is- [14] A. That is a different question, when you talk [15] about the scope. [16] Q. Okay. In terms of learning about the health [17] effects or the amount of lead that would be - [18] A. Big difference. [19] Q.Okay. [20] A. Between health effects and amount of lead. [21] Q. Were you looking at the health effects of lead [22] exposure, or vxre you looking at the effect on the^ Page 73 [1] limits within the body? [2] A. It comes back almost to the same question we [3] had on phenol. [4] Q. Okay. p] A. The difference between those who have some [6] level and some other level, we did a study of, went [7] along the highways with cars running bade and forth and [8] their exhaust, and'we analyzed the amount of lead in [9] those people who lived adjacent to the roadway and all [10] the way bade as far as we could go and then we did [11] enough of it so we were convinced of the magnitude of ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 66 to Page 73 HARTOLDMON0009790 BSA Depo of George Roush, IR-, M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0XMAX(12) [12] the difference. That is not, health is nothing, just [13] talking about how much there is. [itj ou yi/u- wctc avtciif mwung im i/c w/nmn* [15] A. In that study. [16] Q. In that study. [17] A. Yes. [18] Q. Did you do other work with respect to exposure [19] or the amount of lead in the body in other projects [20] that you worked on? [21] A. If you go around the world, we did. We got [22] lead from the Aborigines in Australia, the Incas, South Page 74 [1] America, the amount of lead in Italy, because they get [2] so much lead horn their wine. [3] And then we would do studies. We have people [4] inside of a little chamber and we have diem breathing [5] increasing amounts, how much would it have to increase [6] before we could tell whether it was increased or not. m Q- You studied, you real about these various [8] studies? [9] A. We studied diem. [10] Q. You actually took part in - [11] A. We got blood samples. [12] Q. Was that part of your work at Ethyl? [13] A. Yes. [14] Q. Okay. [15] A. See, that is all part of the environmental [16] business and what are you trying to prove when you do [17] it. [18] Q. The thing that I am not understanding is was [19] your work, was one of the amsetjuences of your work [20] some kind cf determination of this as an acceptable [21] amount of lead to have in the body? [22] A. Well, it depends who, I don't make that Page 75 [1] decision, Monsanto doesn't - I mean Ethyl didn't make [2] that decision. [3] Q. Okay. [4] A. Dupont didn't make that decision. [5] Q. Would there be someone who would make that M decision or some entity? [7] A. The government. [8] Q. So you were going by government limits? [9] A. Ho, no, they were going to establish. If we [10] can get to die place where we can say they can get the [11] lead down then EFA can say we are going to lower it [12] down to that. Or they can say that is not Lowe enough, [13] and so they went down until they got lead out of [14] gasoline. [15] Q. All right. [16] A. And my testimony, practical. I said you can't [17] take lead out of gasoline in national forums. I said [18] if you do, you are going to have to put something in [19] its place. Ho, they said. [20] Have you gone, have you gotten gas at a [21] filling station? r221 Q. Yes.___________________ ;________ Page 76 [1] A. Yourself? [2] Q. Yes. [3] A. Have you ever looked at the little tag that is [4] on that pump? [5] Q. Yes. [6] A. What does it say? [7] Q. The little octane number? [8] A. Ho, no. [9] Q. Unleaded. [10] A. What? [11] Q. What, the fact that it's unleaded gasoline? [12] A. Yes, but that is, it says that if you take [13] lead out of gasoline it now makes this gasoline a [14] carcinogen. [15] Q. Okay. [16] A. Talk about big issue as a public issue. [17] Hobody even talks about it. Talk about cancer and [18] things, but when they want to do something else they i [19] will accept the cancer issue. | [20] Q. All right. [21] A. But it says don't breathe this gasoline [22] because it produces cancer in animals. Page 77 [1] Q- Okay. [2] A. You can see how complicated this is, we can [3] talk about lead the rest of the day. [4] Q. So to some extent you were looking at the [5] health effects of lead in that you were looking at how [6] people were affected by breathing a certain amount? [7] A. We didn't have any problemwith effects. [8] Q.Okay. [9] A. There were no effects. [10] Q. What I don't understand is what was the goal [11] of all this research? [12] A. We were, my goal was to be able to tell the [13] world whether that lead in gasoline was going to [14] produce a measurable effect on people. [15] Q. Okay. [16] A. How the decision, once we get there and say [17] there is a difference, somebody says what are we going [18] to do with this now that we know it? [19] Q. You said was lead in gasoline going to produce [20] a measurable effect on people, right? [21] A. Yes. [22] ____Q. Did you find that lead ingasoline didproduce_________ Page 78 [1] a measurable effect on people? [2] A. Would you call cancer ameasurable effect? [3] Q. Yes. [4] A. It's put on the stamp on that pump, and you [5] don't pay any attention to it. [6] Q. You are not talking about lead then, you are [7] talking about what was substitute for lead, is that [8] right? [9] A. Right, but that is an issue. In other terms [10] if I say I am going - how low is the lead in gasoline, [11] the levels in people are lower than they were back [12] then, but the question is why are they lower? That is [13] where I come back in again, this is an environmental [14] problem, what is the source of the lead? [15] Q. Right. So your study of the effect on humans was more on the reduction cf lead than the existence cf [17] lead, is that correct? [18] A. Or else of those people who are living where [19] they have exposure to lead are they being adversely [20] affected. [21] Q. I understand. [22] ____ A. Everything I talk about is dose related_________ . Page 79 [1] Q. When you say dose related, you mean above TLV? [2] A. Ho, we haven't said there is, there is no TLV [3] when we talk about the lead levels now. [4] Q. All right. [5] A. But there are in occupation, but it's higher [6] than that level. And the changing issue of what, on [7] the lowering lead, there was a fellow in Cincinnati who [8] did lead in the teeth, the deciduous teeth of newborns, [9] and they said that the levels were higher in some than [10] in others. And those who had some, that affected the [11] IQ of the kids. [12] Q. Did any cf your work as medical director at [13] Monsanto invoke lead, in other words did you continue [14] to use any of your expertise about lead in any projects [15] when you became medical director? [16] A. Practically, no. [17] Q. No? [18] A. Ho. [19] Q. At the Texas City plant there teas an ethylene [20] process, correct? [21] A. Ethylene? f22] Q, Ethylene.___________________________________ Page 80 [1] A. Yes. [2] Q. I believe a by-product of that was something Page 73 to Page 80 202-347-3700 ACE-FEDERAL REPORTERS, IHC HARTOLDMONOOQ9791 BSA Depo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Qr-54456.0______________ XMAX(13) [3] called lead pot tars. Do you know what those are? [4] A. No. [5] Q. You don't? [6] A. No. [7] Q. Ethylene. And so there toas an Ethylene [8] Department at Texas City? [9] A. I think so. [10] Q. Do you know what lead pot oil is? [11] A. No. [12] Q. No, okay. [13] A. No, there is a, we are getting off into [14] chemistry. [15] Q. Right. I am more asking - [16] A. So I am - [17] Q. I just want to know whether your expertise in [18] lead caused you to haoe any exposure in lead pot oils [19] in terms of just knowing about it or in working with [20] them. [21] A. The question about chemicals that are found, I [22] think that the anti-knock compounds that have replaced Page 81 [1] lead are something that are made from ethylene so they [2] are involved to a degree. [3] But I am saying I think, when I say *1 think," [4] because that is chemistry. [5] Q. AH right. Do you recall in 1964 that you [6] wrote an article for the Annual Review of Pharmacology m with Dr. Kehoe on Inorganic Toxicology? [8] A. Yes. [9] Q. Do you recall what the article was about? [10] A. A review of metals. [11] Q. AM right. [12] A. And the toxicology of metals. [13] Q. Would it be fair to say that you were [14] summarizmg findings of recent studies? [15] A. What had been written. That is what a review [16] article is, is summarizing what has been written. [17] Q. Did you, if you recall, do any research [18] personally or were you purely doing this review from [19] literature? [20] A. From library review. [21] Q. Who is Dr. Kehoe? [22] ____ A. He was the director of the Kettering Page 82 [1] Laboratory and he was a man almost single-handedly that [2] permitted lead in gasoline to be marketed. [3] Q. AM right. [4] A. They couldn't make it, and this was in Dayton, [5] they couldn't get control of the tetraethyl lead, so [6] that people weren't getting sick from it. And so he [7] set up a facility at the Kettering Laboratory so he [8] could advise the industry and the world, because we [9] wouldn't have had cars if it hadn't have been for [10] Kehoe, because they said that we can't have tetraethyl [11] lead. [12] He just died at 99 in the last month. [13] Q. Are you saying that he found a substitute for [14] tetraethyl lead? [15] A. No, no, no. [16] Q. No? [17] A. He found how to use tetraethyl lead in cars so [18] they could go on having that lead anti-knock. [19] Q. Oh, okay. Do you recall your article you [20] wrote with Dr. Kehoe contained some information about [21] the toxicology of lead? [22] ____ A. 1 am sure there is. Page 83 [1] Q. Okay. [2] A. But Dr. Kehoe would have done it. [3] Q. Dr. Kehoe would have done it, it wouldn't haoe [4] been you? [5] A. No, I wrote it, but he very carefully penciled [6] out what he didn't like about it. m Q. Let me just ask you, do you recall, based on [8] what you remember about writing the article and the [9] research you did for the article, was it known in 1964 [10] when you wrote the article that it was important to [11] avoid breathing lead? [12] MR. JONES: Objection, vague, competence. [13] A. Ask the questionagain. [14] BY MS. WALSH: [15] Q. Was it known in 1964 that it was important to [16] avoid breathing lead or lead compounds? [17] A. All the things we have said about lead here in [18] this room has been related to lead in air. [19] Q. So lead in air, l know we have been talking [20] about it, but we haven't talked about the idea of [21] whether it's something that was known that it should [221 have been avoided or not.'. Page 84 [1] A. Well, the avoidance was not my subject. [2] Q. Right. [3] A. The question is, is what do you do and will [4] that lower the lead in air and will that lead in air [5] affect those who are breathing it? [6] Q. What is the answer to that? [7] A. It all depends. [8] Q. On the dose? [9] A. Depends on dose. [10] Q. Was it known in 1964 that it was important to [11] avoid breathing air that had any amount of lead in it? [12] MR. JONES: Same objection. [13] A. The man who works in a plant exposed to lead, [14] his blood lead, lead in his blood, we call it his blood [15] lead, goes up. The man who, or the family who lives [16] along the highway, the quarrel is does he have more? [17] And my answer is intuitively, without having done the [18] studies, is yes. [19] I believe in conservation of energy and, so it [20] does. And the question is, is it important how much it [21] does, because that is really what this is all about. [22] Those who wanted to get rid of it said it was Page 85 [1] worthwhile. [2] BYMS. WALSH: [3] Q- Is lead something that stays in the blood? In [4] other words, is it possible for onds blood level to [5] decrease if you take away the exposure of lead? [6] A. If I may quote Dr.Kehoe? [7] Q. Sure. [8] A. He says it takes as long to get rid of it as P] it took to get it. If you have bin exposed for two, [10] three, five years, they take you out of the exposure [11] and it comes out in five years. [12] It's much like radioactive material, if you [13] ate exposed to uranium and it gets put in bone the lead [14] apparently goes to the same place in bone as your [15] radioactive material. [16] Q. So in the case of chronic exposure it ivould [17] take some land of time period for the blood levels to [18] decrease? [19] A. Yes. Now I still go back to are we talking [20] about a lot or a little bit you want to talk about, [21] because I said if you are exposed to more you are going [22] to get it.: Page 86 [1] Q. When you say you are going to get it, what P] does that mean? [3] A. I can measure it if you are exposed long [4] enough. [5] Q. AM right. [6] A. And if I have the right tool to measure it. [7] Q. Did you ever do any research or leant anything [8] about exposure to lead by ingesting it? [9] A. If we don't have lead in air you will still [10] have lead in your body. [11] Q. How wdl that get there? [12] A. From your food. [13] Q. AM right. [14] A. Or foam the cans in which it was stored or [15] what we do in making things that's got same lead in it. [16] Q. In the mid '60s timeframe do you know whether ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 80 to Page 86 HARTOLDMONOOQ9792 BSA Depo of George Roush, BL, M.D. Monsanto v Aetna February 18, 1993 Cr-54456.0 XMAX(14) [17] there were efforts being male to determine what the [18] acceptable amount of lead in air or lead in food or [19] containers was? m A. That is what we were working on long before [21] that. m\ Q. When you say we were working on - Page 87 [i] A. What is a safe level of exposure to lead. [2] Q. Was that something that the government [3] mandated at that time? W A. There was a discussion. P] Q. But there were not firm government rules? [6] A. Not until they took lead out of gasoline. m Q. Would it be acceptable to home lead in [8] drinking xoater? PI MR. JONES: Objection, vague. [10] A. What do you mean by objectionable? [11] BY MS. WALSH: [12] Q. Acceptable. I said would it be acceptable to [13] have lead in drinking water? [14] A. We have had lead in our drinking water [15] practically always. [16] Q. So some level is acceptable? [17] A. The question is in whose eyes, if it's so low [18] we can hardly measure it. And the last time they were [19] saying if you, we don't want you to have an exposure to [20] lead anymore. [21] They will say open the faucet and let it run [22] for a little bit, then take vour sample, because there Page 88 . [1] is lead in the pipes. [2] Q. Okay. [3] A. And you say is that bad? We have been doing m it for almost as long as we have had pipes. p] Q. During your time as a medical director at p] Monsanto you were responsible for the whole Monsanto [7] Company? [8] A. Ask that again, was I what? [9] Q. Your position was company-wide, correct, you [10] were medical director for the whole company? [11] A. Yes. [12] Q. You have talked a little bit about how you and [13] Dr. Kelly when you were associate directors split up [14] the plants. But as medical director did you have [15] specific plants that you were responsible for? [16] A. When I was medical director I was responsible [17] for all the plants. [18] Q. In terms of specific work on individual [19] plants, though, did you have special responsibility for [20] arty particular plants? [21] A. I had other physicians working for me. [22] Q. And the people who reported to you would have Page 89 [1] that specific responsibility? [2] 1 am sorry, is that a yes? [3] A. Yes. W Q. W7io did you report to as medical director? p] A. I reported to a number of people. [6] Q. W7io were they? [7] A. One was Mr. Throdahl. [8] Q. What was his position? P] A. Vice president. [10] Q. Vice president of the whole Monsanto Company? [11] A. No. Well, vice president of research. [12] Q. All right. [13] A. And vice president in charge of the health [14] issue. [15] Q. Was Mr. Throdahl a doctor? [16] A. No. [17] Q. Obviously not. Was he your direct boss? [18] A. Yes. [19] Q. Did you report to anyone else besides Mr. [20] Throdahl? [21] A. After he retired. [22] Q. Who was that after he retired? Page 90 . m A. Mr. Senger. m Q. Did you continue to work with Mr. Garrett when p] you became medical director? [4] A. Yes. pi Q. Did you continue to work with Mr. Wheeler? [6] A. Mr. Wheeler retired very shortly after I came m aboard. [8] Q. Did someone replace Mr. Wheeler? p] A. That is the reason he retired partially. [10] because Garrett took his place. pi] Q. And did you continue to work with Mr. [12] Levinskas? [13] A. Yes. [14] Q. Anyone else you worked closely zoith during [15] your time as medical director? m A. Dr. Gaffey. [17] Q. Who is that? [18] A. Pardon? [19] Q. What did Dr. Gaffey do? m A. He is an epidemiologist. pi] Q. When you were medical director at Monsanto was [221 the department organized the same way during all, let's Page 91 [1] see, you were in that position for 15 years. m A. Yes. P] Q. Was the department organized the same way all [4] 15 years? p] A. We built a toxicology laboratory shortly after [6] I became medical director. [7] Q. So that was a new component of the Medical [8] Department? PI A. Yes. [10] Q. Where was the toxicology lab? [11] A. It was separated from the rest of the company. [12] and it was within two or three blocks of the medical [13] school. [14] Q. All right. [15] A. Washington University Medical School. P6] Q. Why did you build it? [17] A. So we could understand more about the [18] toxicology of chemicals. [19] Q. How did Monsanto study toxicology prior to [20] building the toxicology lab? PI] A. That is before me. [22] Q. All right, well - Page 92 [1] A. I started working towards that laboratory [2] about the time I became medical director. [3] Q. How about in the interim while you were still [4] at Monsanto but before the lab was built, how did they PI study toxicology? [6] A. Before I came. [7] Q. The toxicology lab took some time to budd, is [8] that correct? P] A. Yes. [10] Q. So there were years there when you were [H] operating as either assistant or medical director? [12] A. Yes. [13] Q. Before the lab was built? [14] A. Yes. [15] Q. So how did Monsanto study toxicology before [16] that, was it simply a smaller part of the Medical [17] Department, or were you faming out your toxicology [18] studies, or how was that working? [19] A. When we, before we had the laboratory built we [20] used contract laboratories, like everyone else. [21] Q. And when you say like everyone else, like [22] other chemical companies? Page 93 [1] A. All chemical companies that had need for that [2] kind of information. P] Q. Was Monsanto the first to have its own [4] toxicology lab? PI A. No. [6] Q. So part of the Medical Department that was new [7] when you came in was the toxicology lab? Page 86 to Page 93 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMONOOQ9793 BSA Depo of George Roush, JR-, M.D. Monsanto v Aetna February 18, 1993 Cr-54456-0 XMAX(15) [8] A. Was after I was there. P] Q. Right. Was industrial hygiene a part of the [10] Medial Department? [11] A. That was Garrett. [12] Q. That was Mr. Garnett's, he headed up the [13] industrial hygiene section? [14] A. And Ms team. [15] Q. All right. [16] A. He had industrial hygienists working for him. [17] Q. Would it be correct to all it the bidustrial [18] hygiene section? [19] A. Yes. m Q. So the toxicology lab was the toxicology [21] section? [221 A. Yes.________________________ ;_________ Page 94 [1] Q. Whitt other sections were there in the Medical [2] Department? [3] A. This Gaffey that I [4] Q. All right. [5] A. And heis an epidemiologist. [6] Q. Any other sections of the Medical Department? [7] A. We had another unit, we were talking about die [8] examinations that we did every year? P] Q. Yes. [10] A. They sent those back to us and we had a group [11] whose responsibility was to organize those medical [12] reports. [13] Q. When you say organize did Medical Department [14] personnel interpret the results of the annual [15] physicals? [16] A. No. [17] Q. Who did that? [18] A. The ones who did the examinations. [19] Q. So the plant physicians? [20] A. Yes. [21] Q. How did you in the Medical Department interact [22] with the plant physicians? In other words what was the________ Page 95 [1] working relationship? [2] A. Very good. [3] Q. Did St. Louis Medical Department dictate what [4] the plant physicians did? [5] A. Infrequently, butyes. [6] Q- So loould it be fair to say St. Louis would [7] determine what the policy was and pass it on to the [8] plants? [9] A. Yes. [10] Q. Did all the major plants, let's say the 15 [11] biggest, have a plant physician? [12] A. There were five or six that had a full-time [13] physidan. [14] Q. All right. [15] A. There were probably five, seven that had [16] somebody come in. [17] Q. Okay. [18] A. And the rest of them, we sent them out for the [19] examinations. [20] Q. Did the Texas City plant have a physician? [21] A. Yes. Yes. [22] _____Q. Do you recall who it was?_________________ Page 96 [1] A. No. [2] Q. How big was the Medical Department? [3] A. Depends on when you ask the question. [4] Q. How about in the '70s? [5] A. A hundred. [6] Q. Was there some land of reorganization that [7] made the size change? [8] A. Yes. [9] Q. How did that work? [10] A. Toxicology was taken, or the laboratory was [11] taken out of my responsibility. [12] Q. So you built it and they took it away? [13] A. That's not unusual. [14] Q. When did the toxicology lab maoe out of your [15] area of responsibility, pist generally, if you [16] remember? [17] A. About five to seven years before I retired. [18] Q. We have talked about, you haoe known Mr. [19] Garrett, and for a short time Mr. Wheeler, Dr. [20] Lemnskas, Dr. Gaffey. pi] Was it a small number of people inducting [22] these people that reported directhj to you as medical Page 97 [1] director? [2] A. That reported directly to me? [3] Q. Yes. [4] A. Yes. [5] Q. Anyone else that you have left out that [6] reported diredly to you as medical director? [7] A. The physician responsible for die occupational [8] medicine. P] Q. Who would that be? [10] A. Dr. Coleman. C-o+e-m-a-n. [11] Q. So there was the toxicology section for some [12] time, the industrial hygiene section, an epidemiology [13] section, an occupational medicme section and the [14] section that dealt with organizing the annual physical [15] exams, is that right? [16] A. There was no one responsible for organizing, [17] there was a group of them. [18] Q. Would that be all the sections of the Medical [19] Department as you remember it? [20] A. I think so. [21] Q. Did the Medical Department during your time as [22] the medical director do any work with regulatory Page 98 [1] agencies? [2] A. I am not sure what you mean by do woric with [3] them. [4] Q. Did Medical Department personnel ever haoe to p] interact toith regulatory agency personnel? [6] A. Most often it was by our intent, not theirs. [7] Q. What do you mean by that? [8] A. Well, we wanted to go and talk to them about P] something. [10] Q. Which agencies would the Medical Department [11] haoe an interest in talking to? [12] A. Those that could give us advice on how they [13] were going to handle a certain subject. [14] Q. All right. [15] A. We would want to be consistent with what they [16] were or understand where they were going. [17] Q. Would the Medical Department then be [18] concentrating on the agencies that set exposure limits? [19] MS. WALSH; Let me rephrase. [20] BY MS. WALSH: [21] Q. Would the Medical Department be concerned [22] primarily with regulations that were put forth by Page 99 [1] agencies that set exposure limits? [2] A. That's one Mnd. [3] Q. Can you think of any other kind? [4] A. How their - has anything to do with health. p] How to measure the materials to which they are exposed. [6] Q. All right. [7] A. When they measured it did they know the [8] effect? If there was a question about one of our P] plants, we would go to talk to them, what we were going [10] to do. Anything having to do with health. [11] Q. All right. [12] A. They were supposed to be the health leaders. [13] Q. Do you recall during your time as medical [14] director whether you or anyone in your department [15] worked with or sought information from ERA? [16] A. I don't recall. [17] Q. You don't recall either way? [18] A. That doesn't mean there couldn't have been [19] because there is lots of people looking. [20] Q. Would the Medical Department or could the [21] Medial Department haoe had occasion to need ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 93 to Page 99 HARTOLDMONOOQ9794 BSA Depo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAX(16) [221 information from state environmental regulatory Page 100 [1] agencies? [2] MR. JONES: Objection, speculation. [3] BYMS. WALSH: [4] Q. If you know. [5] A.Information on what? [6] Q. Anything relating to health. [7] A. That's a very broad subject. [8] Q. I am just asking if you recall any instances [9] where in seeking information relating to health the [10] Medical Department had to interact or get information [11] from environmental regulatory agencies. [12] A.And state. [13] Q. And state. [14] A. Our effluents that go into the river, someone [15] has to talk to somebody about it. There's a standard. [16] The government, die state sets how much you can put [17] out. So we had to get permit. [18] But we didn't do that, that is not [19] occupational medicine's problem. [20] Q. So in terms of, would there have been anything [21] with respect to effluent permits that the Medical [221 Department would have been involved with? ________ Page 101 [1] A. No. [2] Q. No, okay. Would it have been environmental [3] affairs or environmental control that would be the [4] parts of the company that would have interaction with [5] EPAand[6] A. That wasn't my assignment. [7] Q. You don't know1 [8] A. No. [9] Q. Did you personally ever have to work with or [10] get information from EPA or any state environmental [11] regulatory agencies? [12] A. We have to talk about what kind of questions [13] or what kind of things we talked about. Did I talk to [14] them? [15] Q.Yes. [16] A. Did I talk tothem totell them what'sgoing [17] on? [18] Q. Yes. [19] A. Is that the kind of question, that is not [20] Q. I am just asking about any contact that you [21] had in the Medical Department had with environmental [22] regulatory agencies, was that part of what you did in Page 102 [1] the Medical Department. [2] A. Are youtalkingabout OSHAor NIOSH, or are [3] you talking about EPA? [4] Q. I am talking about EPA, because it seems to me [5] that OSHA or NIOSH would deal with health from the [6] standpoint of exposure limits, correct? [7] A. OSHA would talk to us about that. [8] Q. All right. [9] A.Air pollution. [10] Q. See, I think this is sounding more complex [11] than it is. I am just asking if there was anything [12] that was within the Medical Departments duties that [13] made it so that they had to work with or seek [14] information from EPA or the state equivalent of EPA. [15] A.I don't know. [16] Q. You don't recall? [17] A. That doesn't mean that someone from our [18] department wasn't asked by someone to do it. [19] Q. Okay. Do you recall whether you personally [20] ever had to interact with EPA or state environmental . [21] regulators? [22] _____A. Yes. We talked about some chemicals. Page 103 [1] Q. Do you recall the specifics of those contacts? [2] You said you talked about some chemicals. [3] A. It was more seeking information, more than [4] anything else. [5] Q. Do you recall what land of information you [6] were trying to get? [7] A. Whether they were concerned about chemicals. [8] Q. The regulators were? [9] A. Yes. [10] Q. But you were seeking information from them? [11] A. Whether they were talking about the same [12] chemicals. [13] Q. So were you saying are you concerned about [14] this chemical that Monsanto makes? [15] A. Yes. But they already knew about it. [16] Q. Can you recall [17] A. It's sort of, it's a give and take as you go [18] down in improving knowledge. [W] Q. Do you recall any specific chemicals, are you [20] thinking of any specific chemicals in your answers1 [21] A. No. C22] Q. No? _______________________________________ Page 104 [1] A. Yes, I suppose a recent one is dioxin. [2] Q. All right. [3] A. Because that is a big issue, is what should we [4] do about it? p] Q. So let me make sure I understand this. The [6] idea would be that you would know there is some concern [7] with the regulators about dioxin, so you would go to [8] them and ask what the concerns were so you could [9] address them, is that right? [10] A. No, it would be very - it would be, a lot of [11] the questions is, you build up to see where they are. [12] If they aren't very far along there is no sense [13] spending a great deal of time talking to them. [14] Q. All right. [15] A. On dioxin the perfect example is, you don't [16] remember, but we had limes Beach, and EPA became [17] involved. Times Beach wasn't Monsanto. [18] And I went and talked about limes Beach and I [19] talked about dioxin because it was important to us, not [20] limes Beach that they were concerned about. [21] So the answer yes, it wasn't us, we were 122] talking about Times Beach. But it was a government Page 105 [1] issue. [2] So I went and talked to them, said what are [3] you going to do about it? They said, well, we are [4] going to clean it up. [5] Went bade to see them two or three years [6] later. They said if we knew then what we know now, we [7] wouldn't have done anything. See, it's not yes or no [8] or how or maybe, it has all kinds of things, things [9] that makes an answer. [10] But, you see, if you go back and talk about [11] dioxin, what they were trying to do, a lot depends on [12] what the state of their knowledge is. Whatever you do, [13] whether it's lead in gasoline or whatever, or benzene. [14] Q. How was finding out what the government was [15] going to do about cleaning up dioxin relevant to what [16] you were doing in the Medial Department? [17] A. We were concerned if we had a dioxin problem [18] as well. [19] Q. When you say dioxin problem, what do you mean [20] by that? [21] A. We had dioxin in our plants. [22] _____Q. You were manufacturing it?; Page 106 [1] A. No, that is aby-product. P] Q. Yes, sorry. It was a result of your [3] manufacturing process? [4] A. Yes. [5] Q. Wouldthe Medical Department have any [6] involvement besides a concern about worker exposure? [7] A. Well, we have concern about the health of our [8] employees. m Q. So the Medical Department's concern would be [10] the health effects, is that right, would that be fear [11] to say? [12] A. Yes. Page 99 to Page 106 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMONOOQ9795 BSA Depo of George Roush, 1R-, M.P. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAX(17) [13] Q. But would the Medical Department have any [14] involvement if there was a dioxin cleanup that Monsanto [15] had to undertake? [16] A. Of course, [17] Q. What would the involvement he? [18] A. The workers that would dean it up that they [19] don't get exposed to the dioxin, like they don't get [20] exposed to the lead or to the things we have been [21] talking about. [22] ____ Q. So basically the Medical Department was___________ Page 107 [1] involved in any area where workers would be working P] with chemicals? [3] A. Right on. [4] Q. All right [5] A. And die other one is, mere presence is not a [6] basis for studying it. [7] Q. What do you mean by that? [8] A. We are back to lead. If I have got that much [9] I don't have to worry about it, or if I have got [10] benzene that much and this is how much it takes to [11] cause them to get sick, 1 want to prove that that level [12] is low and I don't have to worry about it. [13] (Indicating.) [14] Q. Let me just make sure I understand, because I [15] think I do understand the scope of the Medical [16] Departments involvement better at this point. If you [17] had an environmental cleanup that Monsanto had to [18] undertake, the Medical Department would be involved [19] because workers' health would be at issue, is that [20] right? [21] A. Yes. That doesn't mean we have to do [22] something.__________________________________________ Page 108 [1] Q. Right. [2] A. We have to convince ourselves there is no [3] problem. [4] Q. You need to ascertain that there would not be [5] a problem? [6] A. That's right. m Q- Would that be the sum total of the Medical [8] Departments involvement in an environmental cleanup? [9] A. We had dioxin deanups. [10] Q. All right. [11] A. So we had workers involved in that. [12] Q. But what I am saying is, is the concern about [13] worker health and establishing that there are not [14] health dangers the sum total of the Medical [15] Departments role in an environmental cleanup? [16] A. If we know something that the government [17] doesn't know we tell them. [18] Q. So you would also need to communicate with the [19] government? [20] A. Now most of it's related to health. But the [21] EPA is interested in health, they are the ones that are [22] writing the standards for lead in gasoline or whatever. Page 109 [1] They are the ones who are interested in, were [2] interested in FCB's. [3] Q. Would the Medical Department need to be [4] involved, lets talk about the dioxin example. Were [5] there dioxin cleanups that you had to be involved with? [6] A. Yes. [7] Q. With respect to those dioxin cleanups did the [8] Medical Department have input in deciding how to carry m out the cleanup? [10] A. No. [11] Q. Would that be decided by the individual plant? [12] A. Plant manager. You are out of my area. [13] Q. All right. [14] A. The responsibility there. But someplace in [15] there the plant manager is much involved. [16] Q. So in terms of using, if you were deciding [17] between using incineration rather than soil removal, PA that wouldn't be the Medical Department's domain? [19] A. We couldn't care less. [20] Q. AH right. [21] A. Because how it's - we were talking about the 122] dose, we can, if we can get that from this down to ______ Page 110 [1] this, that is our goal. [2] (Indicating.) pj Q. just for therecord,what you are saying is [4] that reducing the dose of chemicals that a worker is pj exposed to would be the domain of the Medical [6] Department? [7] A. That's tight,1 have been saying that [8] practically all morning. P] Q-Right. [10] A. It's the same subject. Our goal is to protect [11] die worker, and we protect the worker by some kind of [12] respiratory device. [13] Q. Okay. [14] A. Or dothing or gloves to protect the workers. [15] Q. Would the Medical Department ever need to be [16] involved in determining how contamination occurred [17] prior to a cleanup? [18] A. Conceivably, but practically not. [19] Q. When you say conceivably - [20] A. It could. We could be involved saying we [21] found something here and would, we have to do something [22] about it. _____________________ Page 111 [1] Q. Sharing information? [2] A. Yes. [3] Q. With the plant as it madethatdetermination? [4] A. Yes. pj Q, When you were medical director did you ever [6] work on any projects that involved chemical toaste [7] disposal? [8] A. That doesn't mean the department wasn't. PI Q. You personally? [10] A. Right. Our Garrett group. [11] Q. Yes. [12] A. That knew about that unit, and we saw no [13] health problem there. But in deaning it up Garrett [14] might help to straighten it out. [15] Q. All right. [16] A. Get it in the right place. Garrett would [17] help, say, this is what we have got to dean up, not [18] that. [19] Q. When you say Garrett's group, you said he was [20] the industrial hygiene section? [21] A. Yes. 122] Q. Right? Page 112 [1] A. Yes. [2j Q. Would it be fair to say that in terms of [3j pollution issues that Mr. Garrett was the one with the [4j expertise in the Medical Department? pj A. See, we are talking about questions that I [6] really haven't been involved with. All 1 am saying is [7] that he knew enough about it and how to monitor and [8j things that would help the plant. pj Q. All right. [10] A. So we were involved in how much contamination [11] and where was it, so that Garrett and his group would [12] be involved. [13] Q. Tell me again specifically how they would be [14] involved. [15] A. They would know what to do, 1 mean how much [16] there was. [17] Q- How much contaminant there was, yes? [18] I am sorry, is that a yes? [19] A. Yes. [201 Q. But if- [21] A. We are out of my direct responsibility, and I [221 am saving they would participate where it would be Page 113 [1] helpful to Monsanto. [2] Q. But still within the same role as you have [3j described for the Medical Department, right? ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 106 to Page 113 HARTOLDMONOOQ9796 BSA Depo of George Roush. JR., M.D. Monsanto v Aetna February 18, 1993 Ci-54456.0 XMAX(18) [4] A. Practically, yea. p] Q. When you say Garretts team, are you talking [6] about a team of industrial hygienists? [7] A. Yes. [8] Q. What doindustrial hygienists study? [9] A. The industrial hygienist is the man who goes [10] out and monitors and says that the benzene is below one [11] part per million, we don't have to worry about it. [12] Q. M right. [13] A. Or else he says theyhave got to do something. [14] And his goal is make them put on respiratory gadgets or [15] something to protect them until we get that benzene [16] under control. [17] Q. So toorker exposure lends are the concern of [18] an industrial hygienist? [19] A. It's just as much the responsibility, concern [20] of the occupational physician bemuse, he is worried [21] about what that does to them. One is trying to find [22] how much, and the other is saying does it do something Page 114 [1] to him. [2] Q. What 1 am trying to find out is, I understand P] Mr. Garrett headed the industrial hygiene section, but [4] did he hone additional expertise or job pi responsibilities outside the area of industrial pj hygiene? [7] A. Practically. I don't think so, but you are pj asking could he ever, I don't know. [9] Q. How about when he reported to you? [10] A. It wasn't a major issue. It could have been [11] at some time, but I don't recall. [12] Q. When you say it wasn't a major issue I am not [13] sure [14] A. It doesn't happen every day. [15] Q. All right. [16] A. It could have happened sometime in the 15 [17] years I was there. [18] Q. So based on your recollection the vast [19] majority cf what Mr. Garrett did was industrial [20] hygienist work? [21] A. Yes, but I don't want to say that I have [22] answered all the questions about Garrett's job. Page 115 [1] Q. Right. But Garrett reported directly to you, [2] right? [3] A. Yes. [4] Q. So you had an idea of what Ids job scope was, pj right? [6] A. Yes, but he also can talk to anybody he wants [7] to in the company who would call him and he would pi answer the question what needs to be done. [9] Q. Oh, 1[10] A. Withoutcommunicating to me because that was [llj part of his job. [12] Q. Right, 1 understand that. [13] A. Yes. [14] Q. Would it be fair to say that Mr. Garrett had [15j more involvement in pollution matters than you did? [16] A. When I came to Monsanto, the big issue was [17] PCB's. And as I said, that was Elmer Wheeler's [18] responsibility. But when he retired, Garrett took over [19] and did his job for him, the same kind of breadth. [20] But practically we handled all the problems we [21] were talking about within the Medical Department. So [22] it could happen they could be outside. _____________ Page 116 [1] We were involved in dioxin at Nitro, the [2] Medical Department was involved in that even though it [3] was purely an environmental problem, an environmental [4] contamination problem. So we were interested and we [5] followed it and we knew where it was. [6] Q. lam just trying to understand the difference [7] between substantive areas cf expertise and [8] responsibility. [9] You occupied a very high position, I mean you [10] were the head of a large department, correct? [11] A. Yes. [12] Q. So the people whoreported directly to you had [13] different substantiae areas of responsibility, right? [14] A. Yes. [15] Q. So if there was a pollution issue that touched [16] on the Medical Department, would Mr. Garrett be the [17] primary source cf expertise? [18] A. But he might talk to Levinskas. As a [19] toxicologist he has got as much involvement or more [20] involvement as Garrett. PI] Q As compared to you,would you have more [221 expertise or Mr. Garrett have more expertise Page 117 [1] substantively in terms cf pollution issues that pj affected the Medical Department? [3] A. I could answer your question if you had left [4] out the Medical Department. P] Q. Okay. [6] A. Medical Department, if you leave out the [7] Medical Department it would be Garrett representing [8] outside or talking to them because he knew it. P] Q. AU right. [10] A. Die question is where is the expertise. If [11] they had been monitoring, if Garrett had been [12] monitoring and they - the rest of the company becomes [13] interested, involved, they came over here and learn how [14] he is doing that. [15] Q. Right. I am confused, though. [16] MS. WALSH: Can you read back my question. [17] (The reporter read as directed.) [18] BY MS. WALSH: [19] Q. Let me ask the question again. /4s between you [20] and Mr. Garrett, who had more substantive expertise on [21] pollution issues? [22] ____ A. On health issues related to it or cleanup of: Page 118 [1] it or recognizing where it is and where the other [2] locations in which it can occur, which one of those [3] questions? Those are three different questions. [4] Q. All cf those questions. p] A. I have told you, they are getting pretty [6] complicated for me to say how it was done. Knowing how [7] to measure it and knowing the likelihood of that [8] contamination taking place, that would be Garrett. P] Q. He would know more than you in that? [10] A. He would be involved in it more. [11] Q. All right. [12] A. But he may not know which one should be, [13] because I was sort of getting the overall in terms of [14] what the issues are. [15] Q. All right. [16] A. Now in terms of do we have to clean it up, [17] what does it mean? Garrett had been doing it without [18] saying we have got to clean up, but if Levinskas had [19] gotten involved, the question is does it have to be [20] cleaned up, could be involved. [21] Q. But as between you and Garrett, was my [22] question. Page 119 [1] A. He would be much more involved in the plant [2] than me. [3] Q. He would have more knowledge about pollution [4] issues effecting the plants than you? p] A. Yes. [6] Q. He was a section that reported to you, [7] correct? [8] A. Yes. [9] Q. All right. [10] A. A good example of how things get complicated [11] is Wheeler was responsible for PCB's, worldwide. [12] Q. Okay. [13] A. You can see, special, you can get special [14] assignments. But our goal is to try to keep these [15] things from being a hazard wherever they are. [16] Q. I understand. Let me ask you just a few more [17] questions and then we can go to lunch. Page 113 to Page 119 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMONOOQ9797 BSA Depo of George Roush, IR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAX(19) [18] During your time as medical director do you [19] recall whether you worked on anything that involved [20] pollution abatement or pollution reduction at the [21] plants? [22] ___ A. Offhand, I would say no._____________ Page 120 [1] Q.M right. [2] A. Not involved. PI Q Okay. [4] A. Practically not involved. But I could be [5] asked all kinds of questions about die hazards related [6] to that. Do we have to worry about that pollution? [7] Q. So, again, the same Medical Department role [8] comes up again. You would be asked about information [9] that affected worker health? [10] A. That's right. [11] Q. Is that right? [12] A. Yes. [13] Q. During your time as medical director did you [14] ever have any input on the corporate level to what [15] environmental policy would be? [16] A. We participated in writing statements about [17] the toxicological aspects of a chemical. [18] Q. M right. [19] A. On new chemicals, on old chemicals or when new [20] questions arise on new chemicals. No one else could do [21] it, they couldn't write anything on toxicology, it was [22] our job._________________ Page 121 [1] Q. What are those materials safety data sheets [2] (Discussion off therecord.) [3] THE WITNESS: She asked what kind of sheets we [4] were talking about, what kind of method did we have for [5] deciding how it should be handled and one way would be [6] a safety data sheet. [7] Q. So the information about chemicals you would [8] provide could take other forms besides a material [9] safety data sheet? [10] A. That's right. It depends on the state of our [11] knowledge and understanding that chemical. [12] Q. Any other input into making corpomte [13] environmental policy that you can recall? [14] A. Crazy things. Springfield, Massachusetts, the [15] union there said that they were developing cancer. [16] Q. Okay. [17] A. Of course they are developing cancer. Twenty [18] percent of all people die of cancer. And this was an [19] environmental problem. I took the plant manager and we [20] went down to see the people at NIOSH and I told him [21] that couldn't possibly be. And he said do a study [22] anyway.____________ '; Page 122 [1] So we hired an epidemiologist. And half of [2] those people with cancer didn't even work, hadn't [3] worked for Monsanto. That's the unions making the [4] list. [5] Q. Okay. [6] A. And that's die continual interplay between [7] what the plant says, what EPA says, what the health [8] aspect says. And you can't do any of it without having [9] all those things under control. If you do, you are [10] going to miss it [11] Q. So would it be correct to say that a majority [12] of the role of the Medical Department in making [13] corporate environmental policy decisions was providing [14] that crucial information about health effects of [15] various chemicals? [16] A. Well, we stumbled just like everybody else in [17] getting there, because if the methodology isn't there, [18] you have got to develop the methodology first in terms [19] of whether you move to the next step. So we may ask [20] the chemical company to supply the chemistry for what [21] we were trying to do. [22] ____ Q. But in terms of what the Medical Department Page 123 [1] was providing for corporate environmental policy, it [2] would either be the information on various chemicals or [3] obtaining the information on various chemicals, would [4] that be fair? [5] A. Say it again. [6] Q. What I am saying is, 1 want to make sure I [7] understand the role of the hdedkxd Department in making [8] corporate environmental policy. And what I understand [9] you to be saying is were you either provided that [10] absolutely crucial information about the health effects [11] of chemicals or, if we didn't have the information to [12] provide, we had to go get it? . [13] A. Yes, and it stfil could be we are talking [14] about rat studies, that doesn't do it, and how do We [15] know whether man does or not. [16] Q. All of that is part of getting information [17] about chemicals, isn't that right? [18] A. Yes. [19] Q. What I want to make sure is that there is not m some other input that the medical department had into [21] environmental policy that I am missing. [221_______A. The problem with Peg's was so big at Monsanto, Page 124 [1] and that is a chemical problem, it's a plant problem, [2] have to worry about the workers. Then they found out [3] that it caused cancer in the rats, then what problem [4] was it then? Then we had to do epidemiology studies to [5] decide whether that chemical that caused the rat to [6] have it doesn't do it in man. [7] But, you know, it's all little bits of [8] information that we sort of leam a little bit and we [9] can't find enough to get an answer and we have to wait. [10] We go out and what we do, we use different approaches, [11] we put them in respirators or something to protect [12] them. [13] Q. So, again, the Medical Department was [14] providing information or Obtaining information or [15] interpreting information, would that be fair to say? [16] A. Yes. You see, that is so complicated in terms [17] of who was involved, as I can be understating or [18] overstating. I am giving you a practical way to look [19] at it. [20] But it's a big subject, especially if we are [21] not agreeing on what the results should be. If NIOSH [22] can't agree with me that the fact that there weren't Page 125 [1] very many people who got cancer, that is a fact. Even [2] told me, he says go ahead with the study anyway. So [3] that becomes information that the workers know, too. [4] Got to communicate that to them. [5] MS. WALSH: Why don't we break for lunch here. [6] (Whereupon, the deposition was recessed at [7] 1235 p.m., to resume at 135 p.m.) [1QI [11] [12] [13] [14] [15] [16] [17] [18] [19] m [21] [23___________________________________________________ . Page 126 [1] AFIERNOON SESSION [2] (135 p.m.) [3] MS. WALSH: Let's go back on the record. We [4] are back after lunch. [5] BY MS. WALSH: [6] Q. Dr. Roush, let me just ask you a few more [7] general questions in terms of the scope of the medical [8] director position in the Medical Department. As the ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 119 to Page 126 HARTOLDMONOOQ9798 BSA Depo of George Roush. IR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAXqO) [9] medical director would it be fair to say that the [10] Medical Department was concerned with the tcacidty of [11] chemicals used at the Monsanto plants? [12] A. Certainly that [13] Q. All right. [14] A. But it also is in products that they sold. [15] Q. That is what I was going to ask. Does that [161 extend to feed stocks, intermediates and products? [17] A. Yes, if that isn't big enough somebody else [18] would have to tell me how to get bigger. But it's [19] broad. [20] Q. So aU chemicals whether they are a finished [21] product or not? [22] ____ A. Yes, but that doesn't mean they sold every Page 127 [1] one. [2] Q. Right. [3] A. It depends on, we are bade to the same place. [4] Q. Right. [5] A. Monsanto makes acrylicfiber. [6] Q. Yes. [7] A. Acrylic fiber goes inrugs. It goes into [8] sweaters. And they found that it causes cancer in [9] rats. The reason, I am not sure of the reason, it [10] doesn't it doesn't to people. And what does it do? [11] It apparently doesn't get into man. And, if it does, [12] it's not in sufficient quantity to produce an effect. [13] But what I am trying to say is, die fact that [14] it does something, that doesn't in itself apply to [15] utility or whatever, broader than that maybe. [16] Q. Was it part of the Medical Department's role [17] to wake sure the Monsanto workers were not exposed to [18] amounts of chemicals that would be dangerous to their [19] health? [20] A. Or somehow we limit their exposure. Let's [21] take back your benzene. You are doing something and [22] using benzene as one of the precursors, make it bigger. Page 128 [1] So the people in this room would have exposure unless [2] we do something about it. That could be putting up big [3] ventilation so that the fumes are carried away, it [4] could be putting respirators on them so that they [5] aren't getting exposed. So all that becomes a part of [6] method of handling. [7] Q. AU right. [8] A. Ideally, of course, would be to use another [9] substance. But most often we don't know enough how to [10] do that. [11] Q. In your view why was it important to have [12] toxicity information on the chemicals used at the [13] Monsanto plants? [14] A. Ask the question again. [15] Q. In your view why was it important to have [16] toxicity information on the chemicals used at the [17] Monsanto plants? [18] A. So that we could not have people being exposed [19] to something that would be toxic to than. [20] Q. So many of the chemicals used at the plants [21] would be considered toxic? [22] ____ A. You have to go back and define toxic, we Page 129 [1] haven't done that yet. [2] Q. Right. [3] A. Toxic can include getting on the skin and [4] burning it, that is a form of toxicity. [5] Q. I guess I would try to use a broad definition [6] of toxic, and without getting very technical I think [7] just for your understanding, what I mean when I say [8] toxic is generally a substance would be toxic if [9] exposure to a small amount over a long period of time [10] could have adverse health effects, chronic, or if [11] exposure to a larger amount over a more concentrated [12] period of time could also cause adverse health effects. [13] So l am trying to encompass acute and chronic toxicity [14] in kind of a general definition. That is what I mean [15] when I say it. [16] A. Moat chemicals that produce adverse effects [17] are acutely so. Most of them are acutely so. That can [18] either be that they breathe it in and get pneumonia, or [19] that they get it on their skin or that they ingest it. [20] That is acute. [21] Now chronic is almost not toxic. But over a |22] long period of time there is sufficient of it and it Page 130 [1] accumulates so that it's sufficient to produce an p] effect. pj Q. And there were chemicals of both the types you [4] described in use at various Monsanto plants, right? [5] A. Yes, I think so. But you see we haven't tried [6i to say how serious that effect we are trying to look at [7] up until now. [8i Q. Right, I understand that and l don't thmk we pj need to get into a discussion of dosage. [10] A. No, I am just trying to make it broad so that [11] one understands it. It's a very complicated matter to [12] make it work. [13] Q. I understand, yes. [14] Was it your belief that Monsanto kept up toith [15] the state of the art in terms of toxicity on chemicals, [16] or of chemicals, I should say? [17] A. In terms of toxicity? [18] Q. Yes. [19] A. Levinskas was really - he is now developing a [20] laboratory right today in India, he is building a pii toxicology laboratory for them, or putting one in [22] place. But so he is directing our toxicology, so he is Page 131 [1] giving us the state of the art. pj Our Biohazards Committee is trying to pj second-guess so that we have that state of the art [4j stated beyond the state of the art. In other words pj they are expressly to try to - to either, to establish [6j the fact that that was die definition or that it can be [7] broadened. [8j Q. The Biohazards Committee you said is made up pj of people who don't work for Monsanto? [10] A. That's right. [11] Q. Is that right? [12] A. They are consultants. [13] Q. Is thid kind of information sharing with [14] people outside the company something that is common m [15] your experience in the chemical industry? [16] A. Well, they are being compensated for what they [17] ate doing. [18] Q. Right. [19] A. I can't answer that for other companies. P0] Q. So you don't have any knowledge about it? [21] A. No, because that is a little bit of this. [22] (Indicating.) Page 132 [1] Q. Did you ever visit the Texas City plant? pj A. Oh, yes. pj Q. How many times? [4] A. Several times. P] Q. All right. [6] A.I can't say how many. 171 Q. Let's see if we can get a little more general [8] number than several. Was it more than ten? [9j A. About tenmaybe. [10] Q. About ten? [11] A.Yes. [12] Q. We will say about ten. [13] When did you visit, do you recall aver what [14j time period? [15] A. Early, early in my time of being at Monsanto. [16] Q. Okay, so[17] A. I put my time where I thought the problems [18] were. Acetonitrile is a perfect example. What you do [19] after you have been making this, our world business is [20] making acrylic fiber, and then you suddenly find out [2lj that you have got a chemical you have been using that [22] is a carcinogen.______________ Page 126 to Page 132 202-347-3700 ACE-FEDERAL REPORTERS, INC. HARTOLDMONOOQ9799 BSA__________________ Depo of George Roush, IK., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0XMAX(21) Page 133 [1] Q. Would you consider that, wttt, let me rephrase [2] it. [3] You said you would go to where you considered [4] there would be problems, is that right? p] A. Yes. [6] Q. Did you consider acrylonitrile a problem? m A. I didn't know it wasn't going to cause - our [8] people working with it in Decatur weren't getting m cancer. [10] Q. Did you consider acrylonitrile a problem at [11] Texas City, though? [12] A. Not the same way, because the exposure there [13] was to the product, as opposed to being a component of [14] acrylonitrile. [15] (The reporter read as directed.) [16] THE WITNESS: But that was where Gaffey came [17] in. [18] BY MS. WALSH: [19] Q. That was Ids issue? [20] A. Responsibility, yes. [21] Q. Do you recall the purpose of your visits to [22] the Texas City plant? , Page 134 [1] - A. I didn't have a problem that I was looking at. [2] mine was more overview. [3] Q. So vxntld you routinely visit just to keep up [4] on what vxis going on? [5] A. No, another physician was assigned to do that. [6] Q. So why were you gobtg, spedficaUy? m A. Making sure I - my goal was to try to [8] understand. [9] Q. Try to understand the chemicals that were [10] being used there? [11] A. Yes. [12] Q. What kind of things did you do when you went [13] to the Texas City plant? [14] A. Walked through the plant and talk about [15] various parts of it. What is tins and why is that and [16] can you get that down. [171 Q. You were locking at the plant with an eye [18] toward things that would affect worker health? [19] A. Yes. [20] Q. You said you were touring the plants. Were [21] you actually doing a formal inspection of the[221 A. No. Page 135 [1] Q. Of the Texas City plant, no? [2] A. A walk-through. [3] Q. A walk-through. [4] A. Just to see it, let them talk to. [5] Q. Did you have a working knowledge cf the [6] chemicals used at the Texas City plant? m A. Not really. I knew what the, the chemicals [8] that were there, but I didn't know how it got there or [9] what it was. You can't be a mathematician and do that [10] well. [11] Q. I guess my question isn't that complex. I am [12] more asking did you haoe a familiarity with what [13] chemicals were involved in the processes at Texas City? [14] A. Sort of. [15] Q. Sort of? [16] A. But not well. [17] Q. So you [18] A. That is true of most plants. [19] Q. So it would be, an overview knowledge would be [20] a good way to characterize it? [21] A. Yes, but that may not have been as much as it [22] should. You know, every time you do it you make it a Page 136 [1] little bit better. [2] Q. Okay. [3] A. You hope. [4] Q. Were you familiar with the products cf the [S] Texas City plant? [6] A. I don't recall them. m Q. Did you participate at all in the process of [8] selling the Texas City plant to Sterling Chemicals? P] A. No. [10] Q. You didn't have any role in that? [11] I am sorry, is that a no? [12] MR. JONES: What is the answer? [13] THE WITNESS: No. [14] (Deposition Exhibit 2 was marked for [15] identification.) [16] BY MS. WALSH: [171 Q. Dr. Roush, in front cf you is Exhibit 2. If [18] you would just read the first page, I will guide you [19] through the rest of it. Actually, you may just want to m skim the remainder of it. PI] (Witness examines document.) [22] BY MS. WALSH; Page 137 [1] Q. Dr. Roush, I gave you too many pages. The [2] article that is yours and Dr. Kehods actually P] shouldn't be attached. [4] A. That was the best part of it p] Q. 1 am sure it was and I apologize. I didn't [6] realize you were looking at it until I realized yours m looked thicker than mine. [8] MS. WALSH: For the record let me read the P] Bates numbers in just so we are dear. It's MCO [10] 9327590 through 605. [11] BY MS. WALSH: [12] Q. You can certainly have a copy of that article [13] if you like. [14] With respect to the corrected Exhibit 2 haoe [15] you had a chance to look through it? [16] A. Through this? [17] Q. Yes. [18] A. Yes. [19] Q. I will direct you to specific areas. I don't [20] haoe a lot of detailed questions. PI] This is a handwritten cover memo from R. L. [22] Biggerstaff to Clayton Callis and George Roush. Page 138 [1] Was Mr. Biggerstaff a Monsanto employee? P] A. I don't know. [3] Q. You don't remember him? [4] A. No. p] Q. Do you recall these materials that he has [6] attached? m A. No. [8] Q. Do you recall receiving them? P] A. No. I knew about this levee. [10] Q. All right. [11] A. I have walked the levee. [12] Q. At North 80? [13] A. Yes. [14] Q. Do you haoe any recollection of why you would [15] haoe been copied on this information about the North 80 [16] site? [17] A. No. [18] Q. You said you haoe walked the Levy, so you haoe [19] obviously visited the North 80 site? P0] A. Yes. [21] Q. Did you visit it as many times as you visited [22] the plant? Page 139 [1] A. No. P] Q. How many times did you visit the North 80 [3] site? [4] A. A couple times. p] Q. Probably twice? [6] A. I can't - you know, I can't be specific, but m there is a motel up that way, that I walked up to that [8] motel. P] Q. All right. [10] A. There is a golf course right next to it, there [11] was. [12] Q. Do you recall why you went to the North 80? [13] A. It was a problem of concern when they led me ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 133 to Page 139 HARTOLDMON0009800 BSA Depo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAXJ22) [14] up that way. [15] Q. The people atthe plant? [16] A. Yes. Maybe this man walked me up, you know. [17] Q. Okay. [18] A. But to go back, when was this? [19] Q. This isn'tdated. [20] A, This was early in my tune. [21] Q. All right. [22] _____ A. And you could smell some chemical. But you Page 140 [1] can smell chemicals in the plant anyway. [2] Q. Right. [3] A. A lot has to do with solubility in water. [4] Q. Do you recall whether you had to do any work [5] involving the North 80 at all? [6] A. Dr. Spraul took over that plant when he came [7] with me, so last, long before, see, when did we get out [8] of this business, when did we sell Texas City? [9] Q. Texas City was sold in '86, I believe. [10] A. And I believe that was about the time Dr. [11] Spraul died. [12] Q. And did Dr. Spraul report to you? [13] A. Yes. [14] Q. Okay, so he was - [15] A. Well, sort of. He was working with Dr. [16] Coleman. [17] Q. That would have been your - [18] A. He was our contact with the plant. Dr. Spraul. [19] Q. Was he the plant physician? . [20] A. No, he was with Monsanto. [21] Q. So he was from headquarters? [22] A. Yes.________ . . . " Page 141 [1] Q. Let me make sure 1 understand this then. So [2] he was in the occupational medicine section? [3] A. Yes. [4] Q. Of the MedicalDepartment? [5] A. And we talked about this, but I couldn't get [6] very excited because 1 couldn't tell what was going on [7] and the fact, what they are saying was correct. But [8] the problem what to do about it, that is very pj complicated. . [10] Q. Do you recall what Dr. Spraul, what toork Dr. [11] Spraul did toith respect to the North 80 site? [12] A. I am not sure he did anything. [13] Q. But he had responsibility for the plant? [14] A. Well, he is a physician and he would have been [15] interested in what materials were out there. [16] Q. In order to provide guidance on how to [17] minimize worker exposure? [18] A. Or whether they should or whether it was [19] necessary. [20] Q. Is that your only recollection of the Medical [21] Department personnel being - [22] ____ A. As related to this? ___________ ;__________ Page 142 [1] Q. Yes. [2] A. Yes. [3] Q. So in terms, let me make sure I understand, in [4] terms of the North 80, Dr. Sprouts work on it is the [5] extent of the Medical Department's - [6] A. Each time he was there he may have talked to [7] them or he may have walked it just like I did. [8] Q. But you didn't do any toork personally? [9] A. No. [10] Q. That is it for tins exhibit. [11] A. But my doing something was really having Dr. [12] Spraul go there. [13] Q. fust a clarification. Do you consider [14] yourself to have substantive expertise in the areas of [15] water pollution or chemical waste disposal? [16] A. No, not - 1 have no expertise. [17] Q. All right. [18] A. But you see you are asking such a complicated [19] question, it has to do with contamination of the [20] product, it has something to do with difference in [21] concentration from one time to the next. At least [22] that's the kind of things - what 1 am saying to you is Page 143 [1] what bothers me when I go to a plant, when 1 hear about [2] something. [3] Q. Right. Did you have any role m waste [4] disposal during your time at Monsanto? p] A. Not personally that I recall. [6] Q. Were you an expert on state of the art matters [7] in waste disposal? [8] A. No. P] Q. All right. [10] A. That is chemistry. [11] Q. That would be outside the Medical Department? [12] A. No, it's out of my expertise. [13] Q. Did you rely on someone who was an expert in [14] state of the art with respect to waste disposal? [15] A. Waste disposal was a responsibility of the [16] plant. [17] Q. In terms of waste disposal were you mvolved [18] in the decisions of haw and where a particular plant [19] would dispose of its waste materials? P0] A. No. pi] Q. All right. [22]______ A. Not unless they might ask a question. Page 144 [1] Q. And in that case you would respond to their [2] question? [3] A. As best 1 could. [4] Q. Did the plants have to report to the Medical pj Department on haw they disposed of their waste? [6] A. No. [7] Q. Do you recall that during your time as medical [8] director Monsanto sometimes took a calculated risk in P] allowing pollution at its plant locations? [10] MR. JONES: Objection, vague. [11] A. That is a very broad question. [12] BY MS. WALSH: [13] Q. Do you ever recall that you had any [14] involvement or knowledge of a plant decision to allow [15] pollution after weighing the pros and cons? [16] A. Allowing; pollution of what? [17] Q. Allowing any kind of chemical discharge into [18] the environment. [19] A. Into the air, into the water or into the [20] ground? pi] Q. Any of the three. [22]______ A. You see, they can be all, any one of them, and Page 145 [1] 1 can't go further because it depends on the chemical pj that's there. Or the chemicals that are there. [3j Q. I am just asking ays or no question about [4] whether you readl whether there was a decision made to P] go ahead and allow some kind of chemical release into [6] the environment that you recall. [7] A. No. [8j Q. Did the MedicalDepartment have any pj involvement or any input on whether pollution abatement - [10] was considered in the manufacturing emits? [llj A. When you say pollution abatement I am back to [12] whether we are talking about air, about water or just [13j being put in the dump. Every one of them has got that [14] and it depends on the chemical. And they could well [15] talk to Levinskas about whether that was toxic or not. [16] MR- JONES: Also object to the use of the term [17] "pollution," which I don't know if counsel is using [18] that term to be synonymous with discharge of a waste or [19j discharge of a chemical versus pollution, if you are P0] distinguishing between pollution and that. [2lj MS. WALSH: Let me rephrase. [22] BY MS. WALSH: ___________________________ Page 146 [1] Q. When manufacturing departments were deciding pj whether to modify a chemical process, and part of that [3j calculus would be how much by-product or waste is [4j created, would the Medical Department have any input on Page 139 to Page 146 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMON0009801 BSA_____________ Depo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0XMAX(23) [5] what kind of mcdifkatians that manufacturing unit [6] could or could not make? m A. Practically it did have something to do with [8] it. P] Q. What specjfkaBy? [10] A. They could ask us how do I evaluate the [11] toxicity of lids material. [12] Q. Any other things you can think of? [13] A. It wouldn't be quantity, but primarily it [14] would be is to add the dimension of whether this is [15] toxic or not. [16] Q. So it would be providing toxidty information [17] to help make that decision? [18] A. Yes. [19] Q. After the toxicology lab was built did [20] Monsanto conduct all its own toxicology testing? [21] A. No, there was a continual change in what they r22] wanted that laboratory to do. Page 147 [1] Q. How did it change? [2] A. Well, before lunch we were talking that we [3] used outside facilities, and we continued to have a [4] relationship with the outside laboratories. It had [5] something to do with the expertise of die toxicology [6] lab, our laboratory, as opposed to one outside in terms m of even the size of how many studies can you do in a [8] facility, because as time went along they have enlarged P] it. [10] Q. So some toxicology studies stdl went to [11] outside labs? [12] A. Yes. [13] Q. During your time as medical director did you [14] exchange information with other chemical companies, [15] toxicity information? [161 A. Levinskas would do that. [17] Q. You didn't have any direct interaction? [18] A. No, he is a better toxicologist than I am. [19] Q. AH right. [201 A. Experimental toxicologist. [21] Q. Was it common to share information with other [22] chemical companies? Page 148 [1] A. There are some studies that are done by a [2] group of companies, and so there would certainly be a [3] part of that group. W Q. All right. [5] A. So it depends on how we got to that. [6] Q. What is the Manufacturing Chemists m Association? [8] A. That is a, all the companies that want to be a P] part of that organization. [10] Q. Okay. [H] A. That they think they can handle the problems [12] of their business better by using a common resource. [13] Q. That became the Chemical Manufacturers [14] Association, is that correct? [15] I am sorry, was that a yes? [16] A. Yes. [17] Q. Did you do any work with CMA or MCA, as it [18] later became? [W] A. I am sure that I did. But 1 was not on [20] regular assignment to them, I was called in on [21] exceptional things. [22] Q. Do you remember any specific projects? Page 149 [1] A. No. [2] Q. Did CMA or MCA haoe a program for issuing [3] material safety data sheets for various chemicals? [4] A. I don't know. [5] Q. Okay. [6] A. Each company had their own way of getting that m information out to the customers. [8] Q. This case, this lawsuit is very large, as you PI may know, it covers dbout 80 different sites across the [10] country. The part of the suit that is going to be [11] tried first is the Texas City plant and then four sites [12] in Texas. The first one is North 80, iohidi toe haoe P3] already discussed. [14] The second one is now called the Brio site. [15] It's been known by a number of names over the years, [16] Hard-Lowe Chemical Company, Lowe Chemical Company, [17] Phoenix Chemical, Friendswood Remining. It's located [18] on Dixie Farm [19] A. I have been there. [20] Q. You haoe been there. When did you visit the [21] Brio site? 122] A. When I gave my deposition on the Brio site. Page 150 [1] Q. Did you testify in the Slaughter litigation? m A. Yes. [3] Q. What was the purpose of your visit to the Brio [4] site? [5] A. They called me, asked me to testify. [6] Q. Monsanto did? m A. Yes. [8] Q. What did you testify about? P] A. The question related to the people who lived [10] on the other side of that ditch. [H] Q. The homeowners in the subdioision? [12] A. Yes. [13] Q. Now did you visit the Brio site once? [14] A. Yes. [15] Q. Only once? [16] A. Yes. [17] Q. What did you do on your visit? [18] A. Just looked at it. [19] Q. Did you do any testing or [20] A. That wasn't my purpose. [21] Q. All right. [22] A. We were interested in those people on the Page 151 [1] other side, living in that area. m Q. Were you maikjng a judgment as to whether the [3] exposure leads were acceptable? [4] A. Yes. [5] Q. What was your condusion? [6] A. That I didn't think there was enough there for m it to be a hazard to the people who lived there. [8] Q. Do you recall - P] A. And that examinations were not required. [10] Q. Physicals of the people? [11] A. Yes. [12] Q. How did you make that determination, did you [13] take instruments with you, or did you just look around? [14] A. Just looked around. [15] Q. How can you make that determination without [16] measuring the actual chemical levels? [17] A. A lot easier than most of the things we do. [18] Q. Really? [19] A. Sure, there wasn't anything there. [20] Q. No open pits? [21] A. Oh, yes, no open pit. The question was that [22] little ditch that went around there. Page 152 [1] Q. So you examined the ditch? [2] A. I didn't do a physical examination, I didn't [3] do it with a stethoscope. [4] Q. But you looked around the ditch? [5] A. Yes, I went down in the ditch, and it was dry. [6] Q. During your time as medical director did you m haoe any work involving the Brio site? [8] A. No. P] Q. So the Slaughter visit was your only exposure [10] to the Brio site? [11] A. Yes. [12] Q. Did you do any research on past practices at [13] the site before you made your visit? [14] A. No. [15] Q. Do you recall what chemicals were of concern [16] there? [17] A. No. [18] Q. Do you have any expertise in geology? ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 146 to Page 152 HARTOLDMON0009802 BSADepo of George Roush, JR., M.P. Monsanto v Aetna February 18, 1993 Cr.54456.0XMAX(24) [19] A. No. [20] Q. Did you investigate the sod types at Brio? [21] A. No. [22] Q. Did you examine the groundwater at Brio? Page 153 [1] A. No. m Q. The next of the four sites thatis in the first [3] trial group is now called Motco, again it's had a [4] number of names, Petroprocessors, the Texas City Wye. [5] Are you famdiar with that site? [6] A. I have heard the names. m Q. Have you ever visited? [8] A. No. P] Q. Did you ever do any work during your time at [10] Monsanto that related to Motco? [11] A. No. [12] Q. The last site is called the South 20 site. [13] south of the plant adjacent to Swan Lake. Are you [14] famdiar with that site? [15] A. I think we talked about it one time. [16] Q. Have you ever visited it? [17] A. No. [18] Q. Do you recall what the discussion that you [19] just mentioned - [20] A. No. [21] Q. You don't recall any specifics? f22] A. No. Page 154 . [1] Q. Do you recall any other work you had to do [2] involving the South 20 site during your time at [3] Monsanto? [4] A. No. [5] Q. Let me bade up a minute, 1 forgot to ode you [6] this. Did you inspect the sod at the North 80 site? [7] A. No. [8] Q. Did you inspect the groundwater at the North [9] 80 site? [10] A. I can't answer the one about did I ever, when [11] I was walking along. [12] Q. Right. [13] A. Could I have walked down closer to the water [14] to see how high it was, you know, all kinds of sort of [15] look around kind of things. [16] Q. I guess my question is did you investigate the [17] sod type or sod condition at the North 80 site? [18] A. No. [19] Q. Let's see, Dr. Roush, do you remember some [20] time ago you were contacted by an investigator from [21] Clarence Kelly Investigation Services? [?2L A. No. Page 155 . [1] Q. You don't recall. Do you recall at any time [2] in the last few years being contacted by an [3] investigator regarding this case? [4] A. Regarding what? [5] Q. Regarding this lawsuit. [6] A. No. m Q. It would have been probably a telephone call, [8] does that help you remember at all? [9] A. No. [10] Q. Okay. [11] A. Things like that, I have nothing to relate it [12] to, you know, if they don't follow up and that. [13] Q. So you don't have any recollection about [14] giving any investigator information about Monsanto? [15] A. That you can rest assured that I didn't give [MJ anybody any information about Monsanto. [17] Q. If an investigator had asked you for [18] information, would you have provided information? [19] A. No. [20] Q. Did you ever participate in negotiating [21] insurance contracts that Monsanto was going to purchase [22]_ or had purchased? Page 156 [1] A. No. [2] Q. Was that the responsibdity of the Insurance [3] Department? [4] A. Pardon? m Q. Was that the responsibdity of the Insurance [6] Department? m A. I don't know. [8] Q. Ad right. P] A. Could well be the company, could well be the [10] product. [11] Q. Did you ever as medical director have to work [12] with Insurance Department personnel? [13] A. No. [14] Q. Did you have any role at ad in obtaining [15] insurance coverage for Monsanto? [16] A. No. [17] Q. Did you ever have to meet with or do any work [18] with insurance company personnel? [19] A. No. [20] Q. Do you recad whether you ever had to have any [21] phone calls or correspondence with insurance company [22] personnel? Page 157 [1] A. No. [2] Q. Did you have an understanding of who was [3] responsible for negotiating with insurance companies to [4] get cooemge? P] A. No. [6] MS. WALSH: Would you marie this, please. m Exhibit 3. [8] (Deposition Exhibit 3 was marked for P] identification.) [10] BY MS. WALSH: [11] Q. If you could read through Exhibit 3, please. [12] Dr. Roush. I don't have a lot of questions about it, [13] but I would like you to read the cover memo and then [14] skim through the attached materials. [15] A. Say that again now. [16] Q. If you could read through the cover memo, [17] which is the first two pages. [18] A. This is the document? [19] Q. Exactly. P0] A. All tight. PH Q. Then just skim through the attached materials, [22] which are the last few pages. Page 158 [1] (Witness examines document.) [2] THE WITNESS: This is mighty complicated stuff [3] just to read and have a couple of sentences. [4] MB. WALSH: Right. [5] BY MS. WALSH: [6] Q. Have you had a chance to look through Exhibit [7] 3? [8] A. Yes, I have looked through it. P] Q. This is a memo dated February 1, 1988, and its [10] subject is Minutes of DEOILiaison Committee Meeting. [11] Do you remember what the DEO Liaison Committee [12] was? [13] A. No, I sure do not. [14] Q. It indicates under committee members present, [15] G. Roush, ]r. That is you, right? [16] A. Yes. [17] Q. Do you have any recollection of this [18] particular meeting that this memo describes? [19] A. No. [20] Q. On the first page of the memo, item 2 says [21] "Insurance," then, "(R. E. Toth)." Then it says, "Key [22] points of this presentation (visual aids attached) Page 159 [1] were:", and then it goes through a number of bullet [2] points. [3] Do you remember this presentation at all? [4] A. No. [5] Q. Does this refresh your memory as to whether [6] you may have done any work with respect to insurance? [7] A. Oh, I am not sure I was there. [8] Q. All right. P] A. It says members present. I am not sure there Page 152 to Page 159 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMON0009803 BSA Depo of George Roush, [R-, M-D. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAX(25) [10] was, I didn't even know there was a committee of that [11] sort. [12] Q. Okay. [13] A. If you were to go through my file you wouldn't [14] find anything like diet. [15] Q. So this is a presentation that you probably [16] heard but you didn't haoe any involvement or [17] responsibility xoith? [18] A. Yes, I am not sure how we became a part of an [19] insurance litigation effort. [20] Q. Let me ask you this. On the second page item [21] three says "Carcinogen Policy" and it's got Dr. [22] Levinskas's name and yours following. Page 160 [1] A. It's not in here, is it? [2] Q. No, it doesn't appear to be attached, tins is [3] all we got in the production. [4] The first paragraph says, "The Document was [5] intended to be consistent with, and a checklist of [6] actions to tike, with respect to compliance with WWG #5 [7] when new internal or external health/environmental [8] knowledge is obtained." [9] Do you remember the carcinogen policy? [10] A. No, I do not. [11] Q. Do you haoe any general recollection of [12] whether it was a new policy or not? [13] A. They are writing a definition and this man was [14] never put in charge of anything. [15] Q. The author, Mr. Elmer? [16] A. Yes. [17] Q. Okay. . [18] A. So just exactly, we need more information to [19] make it useful. [20] Q. Do you remember worldwide guideline number 5, [21] which I believe is the WWG #5? [22] ____ A. No, I do not.: Page 161 [1] Q. That is it for this exhibit, you can put it [2] aside? [3] A.What? [4] Q. That is it for this exhibit. [5] A. Okay. We probably couldn't have finished one [6] by the time I retired, anyway. [7] Q. A new carcinogen policy? [8] A. You would have to get everybody's approval, [9] you know. [10] Q. It would take too long. [11] Are you familiar with vinyl chloride monomer? [12] A. Yes. [13] Q. That chemical was manufactured at the Texas [14] City plant, right? [15] A. Yes. [16] Q. Was it still being manufactured id the time 117] you became medical director? [18] A. No. [19] Q. So the unit had already shut down? [20] A. Yes. [21] Q. Vinyl chloride is nowknown to be a [22] carcinogen, is that right?___________________________________ Page 162 [1] A. Yes. [2] Q. Do you know what kindsof cancer it can cause? [3] A. I was very much involved in this with the [4] vinyl chloride industry. [5] Q. Okay. [6] A. They had their own MCA. So they had a group [7] together to handle their common problems of vinyl [8] chloride. - [9] Q. This was the Chemical Manufacturers [10] Association? [11] A. Yes. Well, it was the equivalent of that, it [12] was the vinyl chloride industry people. It was 19, [13] just before I left Cincinnati. [14] Q. So that would haoe been just as you started? [15] A.1973, 1975. [16] Q. All right. [17] A. Now they knew that there were problems of [18] workers going down inside of reactors, and they then [19] found that several of the people who went into reactors [20] and had an operation, they found they had pij angiosarcomas. [221 Q. What is an-_____________________________ Page 163 [1] A. That is a cancer of die blood vessels but [2] involves primarily the liver. So, yes, these people p] who were working with vinyl chloride developed [4j angiosarcoma. pj Q. This was in the mid '70s? [6] A. Yes. [7] Q. Was that the first time that you were aware of [8j studies that suggested that vinyl chloride could cause P] cancer in humans? [10] A. I knew about it before it became a public [llj issue. [12] Q. Were there any studies [13] A. It happened at Louisville and the doctor [14] operating on several people found this cancer. And [15] they looked at it tinder a microscope and did all kinds, [16] found it was an angiosarcoma, which was quite unusual. [17] Q. These were workers who would go in and dean [18] out a reactor? [19] A. Go down inside of reactors, yes. Big, big [20] exposure. pi] Q. Do you recall whether there toere any studies [22] before the mid '70s that suggested that vim/l chloride Page 164 [1] could cause cancer in animals? [2] A. There was discussion of it, in animals, but I pj don't think they ever showed it in man like they did [4] with the angiosarcoma. PI Q- So the angiosarcoma, to your knowledge, was pi the first indication it could cause cancer? [7] A. Could causecancer. PI Q- In humans? P] A. Yes. [10] Q. Did you ever on behalf of Monsanto institute [llj any kind of monitoring program for workers who might [12] haoe been exposed to vinyl chloride? [13] A. We were still making "P B C" up in [14] Springfield, and we worked out a procedure for them to [15] be looked at. [16] Q. All right. [17] A. And we also cut down their exposure like mad, [18] they didn't go into reactors, and that was the basic [19] thing that was good. But the other one, just poj confirmatory type. pij Q. Do you recall whether the studies with the [22] angiosarcomas showed that the cancer would appear much Page 165 [1] later than the exposure, or was it a cancer that would [2] show up whim a relatively short time of the exposure? pj A. Relatively short time. [4] Q. Did you ever go bade and evaluate whether P] there may haoe been affected workers at the Texas City pj plant? [7] A. No, they were out, we didn't think there was a pj place for doing that. P] Q. Why not? [10] A. Because there had been sufficient time that we [11] didn't think it could be possible. [12] Q. The relatively short time? [13] A. Yes. [14] Q. For cancer to show up would haoe passed? [15] A. Yes. [16] Q. When you say relatioely short time, can you [17] give me a general idea of what that timeframe is? [18] A. No, I don't recalL [19] Q. Did Monsanto ever do a carcinogenicity study [20] for VCM, besides what you haoe described id PI] Springfield? [22] A. No. Page 166 ACE-FEDERALRBPORTERS, INC 202-347-3700 Page 159 to Page 166 HARTOLDMON0009804 BSA Depo of George Roush, IR., M.D. Monsanto v Aetna February 18, 1993 Cr-54456.Q XMAX(26) [1] Q. Was the carcinogenicity study inherent with [2] what you did with the workers at Springfield? [3] A. We did what the industry was saying to be [4] done, where these people were actually - Monsanto did [5] not have people going in the reactors Hke die place [6] where they had the angiosarcomas, our exposures were [7] relatively low. [8] Q. So you didn't have people cleaning out the [9] reactors? ` [10] A. No. [11] Q. Do you recall whether you ever did any - [12] A. Well, we did it, but we did it by washing it [13] out, as opposed to getting a man down there with a [14] knife blade and scraping it off. [15] Q. Okay. [16] A. Grossdifference in terms of level of [17] exposure. [18] Q. Do you remember whether Monsanto did any [19] long-term or short-term health effects studies on vinyl [20] chloride? [21] A. No. They were examined yearly, that is the |22] way our system works.____________ Page 167 [1] Q. So in the routine monitoring the answer is no? [2] A. And, not routine monitoring, it was examining [3] them. [4] Q. The actual annual physical exams? [5] A. Right, and the fact that we didn't go into [6] reactors. [7] MS. WALSH: Let me just show you one document. [8] (Deposition Exhibit 4 was marked for [9] identification.) [10] BY MS. WALSH: [11] Q. This is Exhibit 4, Dr. Roush, an April 17, [12] 1974 memo with an attachment questionnaire. Could you [13] read through it. [14] (Witness examines document.) [15] THE WITNESS: That is the general vinyl [16] chloride examination program. [17] BYMS. WALSH: [18] Q. All right. [19] A. And it became a part of the OSHA regulation [20] now. [21] Q. At the time it was not part of OSHA? [22] ____A. I don't recall. _________________________ _ Page 168 [1] Q. Is that your signature - lam sorry, have you [2] read through it? [3] A. No. [4] Q. Take your time. [5] (Pause.) [6] THE WITNESS: AD these questions that are [7] asked are related to liver effect. [8] BY MS. WALSH: [9] Q. You are referring to questions on the [10] questionnaire? [11] A. The questionnaire, right. [12] It doesn't say where this thing went, does it? [13] Q. No, it doesn't. [14] Have you read through Exhibit 4? [15] A. Yes. [16] Q. That was my next question, do you recall who [17] you distribute! this to? [18] A. No. [19] Q. Is that your signature at the bottom of page [20] 1, the very farnt copying? [21] A. Not the one - I can surmise it's mine, but I [221 sure can't see it._____________________________ Page 169 [1] Q. The copying is not good, I apologize. This is m on Monsanto letterhead, is that right? [3] A. Yes. [4] Q- Do you remember preparing this? [5] A. No, I do not. [6] Q. You don't have a specific recollection? [7] A. No, but it was, it's a reasonable one. [8] Q. From reading through the memo, the subject of [9] which is Medical SurveSlahce of Workers Exposed to [10] Vinyl Chloride, is this procedure that is laid out [11] something that teas instituted as a result of VCM [12] producing cancer in the workers you described? [13] A. I am sure it is. [14] Q. Okay. [15] A. They had a peculiar disease in those workers [16] who went down in reactors while I was -- before I came. [17] Q. On the first item, item 1, it says, "A [18] physical examination should be done on all workers at [19] least once a year." [20] Did- eg___ a.[21] A. All those exposed to vinyl chloride, "If a worker has been exposed to vine chloride Page 170 [1] for ten years or longer, examinations should be done P] every six months. The examination should include P] evaluation of the lioer and spleen for possible [4] enlargement." p] Those steps, instructions for physical [6] examination part of the annual exantination as a [7] routine, or were they added just for the vinyl [8] chloride? [9] A. They were part of the routine. [10] Q. So item 1 was always part of the routine? [11] A. Well, I suppose the logical thing, we could [12] have done more, or were doing was to twist the arms of [13] those involved more without forcing them. [14j Q. In other words, encourage participation? [15] A. Yes. [161 Q. The liver function testing that is outlined in [17] item 2, was that routinely done as part of the annual [18] physical exams? [19] A. Yes. P0I Q- The questiontudre that you added, that was pij specie to vinyl chloride workers, is that right? [22] A. Yes, and it almost reads like OSHA just wrote Page 171 [1] it. PI Q. I don't know whether that is good or bad. pj A. It's too dose to being the same to be by [4] aeddent. P] Q- So you may have used some OSHA [6] A. I would think I copied it from somebody. [7] Q. Okay. [8] A. And take full credit for it. [9] Q- The last item, number 3, just says copies of [10] the test scores as well as the completed questionnaires [11] should go to St. Louis Medical Department. An [12] evaluation of the testing will be returned to the [13] plant. [14] Did St. Louis actually do the analysis on [15] those physicals? [16] A. Well, all we would do was find out if it was [17] abnormal and call them and say did you do so and so. [18] It was really a means of making sure that the work was [19] done. P0] Q. Do you recall [21] A. Where did we get the protected order 1989 on [22] that.1 Page 172 [1] Q. That is part of this litigation. [2j A. Oh, it's nota part - [3] Q. Not a part of the document, no. There are [4] protective orders in the case that protect some of the [5] trade secret materialin the documents. [6] A. Sure. [7] Q. Let me ask you one more thbig, and that is [8] were there any additional steps that you remember that pj you took in the Medical Department in response to the [10] knowledge about VCM causmg these angiosarcomas? [11] A. I went up to Springfield and walked through [12] the plant. [13] Q. All right. [14] A. And found out that they didn't go into the Page 166 to Page 172 202-347-3700 ACE-FEDERAL REPORTERS, me HARTOLDMON0009805 BSA Depo of George Roush. [R., M.D. Monsanto v Aetna February 18, 1993 Cr-54456.0 XMAX(27) [15] reactors, so their exposures were relatively minor. [16] Q. Do you recall whether any of the Springfield [17] workers hod abnormal tests following this procedure? [18] A. No. [19] Q. None did? [20] A. No. [21] Q. ! am sorry, I am not dear. m. A. No, they were not. They did not have i page 173 [1] abnormal. [2] MS. WALSH: That is it for Exhibit 4. Why [3] don't we take a five-minute break, we have gone about [4] an hour. P] (Recess.) [6] MS. WALSH: Mark this. m (Deposition Exhibit 5 was marked for [8] identification.) P] BY MS. WALSH: [W] Q. This is Exhibit 5, Dr. Roush, ft's a November [11] 12, 1975 memo. If you could please read thxough that. [12] (Witness examines document.) [13] THE WITNESS: There's my boss. [14] BY MS. WALSH: [15] Q. Mr. Throdahl? [16] A. Yes, Mr. Throdahl. [12] (Pause.) [18] BY MS. WALSH: [W] Q. Have you read through Exhibit 5? [201 A. Yes. [21] Q. All right. IM. A. My boss had me all nervous.______________ _ Page 174 [1] Q. So this was written by Mr. Reese and Mr. [2] Throdahl? [3] A. Yes. M Q. Mr. Throdahl was your boss? [5] A. Yes. [6] Q. What uas your relationship to Mr. Reese? m A. Good with both of them. [8] Q. I am sorry? P] A. My relationship was good with Reese and [101 Throdahl, both. [11] Q. Did you report to Rase? [12] A. No. [13] Q. What was Ids position? [14] A. I know he was at a very high level in the [15] company. [16] Q. But you reported to Throdahl? [17] A. Yes. [18] Q. You oboiously received a copy of tins? [19] . [20] A. I am sure I did. Q. You don't have a specific recollection? [21] A. No. [22L Q. Do you have any idea why you would have been______ Page 17S [1] copied on a memo that discusses chlorinated [2] by-products? [3] A. So that when they get around to defining what [4] products were of concern that they were going to [5] incinerate, that if it came to my mind, no, or yes, I [6] could respond in an appropriate manner if in feet we m had some chemical that I recognized that we said we [8] wanted to get rid of. P] Q. But did you - [101 A. The real issue is if someone got chlorine on [11] them, and the question is, is that bad or good, or how [12] are we going to get rid of it. [13] Q. Did you have any involvement in determining [14] which chemicals, which chlorinated by-products were [15] incinerated? [16] A. No. [17] Q. No, okay. [18] A. I would have the responsibility of saying what [19] would happen if they did or didn't. [20] Q. Do you recall specifically any chlorinated [21] by-products that you said were not proper for [221 numeration, not proper candidates for inaneratian, I Page 176 m should say? P] A. No. P] Q. Do you recall having any response to tins [4] memo? p] A. No, I wouldn't be, it wouldn't be appropriate [6] for me to respond yet. P] Q.Okay. [8] A. If I were real smart and had some good points P] on what hydrochlorine compounds that should be [10] controlled, if I had said we have got to do so and so, [11] if it came to mind, then I would get it back. [12] Q. Did you ever work with Dr. fair, Dr. J. R. [13] Fair, who is mentioned on the second page? [14] A. No. [15] MS. WALSH: That is it for this. This is [16] Exhibit 6. [17] (Deposition Exhibit 6was marked for [18] identification.) [19] MS. WALSH: I would also like to mark 7 and 8 m at the same time. pi] (Deposition Exhibits 7 and 8 were marked m. for identification.)________________ Page 177 [1] MS. WALSH: Dr. Roush, could you please read P] through Exhibit 6. Take as much time as you need. [3] THE WITNESS: AD right. [4] MS. WALSH: Just for your information my pj questions are going to be directed to the first two [6] pages of Exhibit 6. [7] (Witness examines document.) [8] BY MS. WALSH: P] Q. You have read through Exhibit 6? [10] A. Yes. I always try to understand it as I go. [11] Q. Take as much time as you need. [12] This is dated July 22, 1977. Do you remember [13] being appointed to the Corporate Environmental Policy [14] Staff? [15] A. No. P6] Q. You don't, okay. Do you recall the name of [17] the Corporate Environmental Policy Staff? [18] A. Pardon? [19] Q. Do you recall that there was a committee m called the Corporate Environmental Policy Staff? PI] A. Yes. [22]______ Q. Let me direct you to Exhibits 7 and 8, the two Page 178 [1] charts. Does that refresh your memory? P] If you could look over those and see if by pj looking at them they might refresh your memory as to [4] who ioos on the committee and if it refreshes your pj memory on your role. [6] (Witness examines documents.) [7] A. Yes. Lots of changes have been made from this [8] to this. pj Q. I believe Exhibit 7 has a date at the bottom [10] that says April 1, 1980. And Exhibit 8 has a date at [llj the very bottom right that says 1984. So that was [12] 1984? [13] A. What was the first one? [14j Q. The first chart, Exhibit 7, is dated 1980. [15] The memo is '77. The first chart, Exhibit 7, is 1980. [16] A. Mine says - oh, yes. [17] Q. At the very bottom. [18] A. Right, right. [19] Q. The second chart, Exhibit 8, says 1984, and [20] that is little tiny numbers down at the bottom. pi] A. Yes. And the first one was '77. [22] Q. The memo, which is Exhibit 6, is dated 1977. Page 179 [1] Does looking at the charts hdp you remember pj anything about tins committee? pj A. Well, this was just something you put into [4i your - this man here was the company executive pj officer. ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 172 to Page 179 HARTOLDMON0009806 BSADgpo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr-54456.0XMAX(2B) [5] Q. Mr. Hanley? [7] A. Yes. [8] Q. Who wrote EMM 6? pj A. Oh, my, yes. [10] Q. He was the chief - [11] A. Chief bottle washer. [12] Q. All right. [13] A. AH these other people reported to him. [14] Q. Okay. [15] A. So my reporting to him was only there so that [16] he has got that area covered. [17] Q. Do you remember whether in 1977 you took on [18] additional responsibilities? [19] A. Mo, my additional responsibilities would have [20] been assigned to me by Throdahl. pi] Q. Okay. . [22]______ A. Just as simple as that, do you see? And when Page 180 [1] Throdahl, the assignment would be that some of these [2] things are moving and we would provide the backup so [3] that he didn't get into any trouble doing it. [4] Q. Do you remember whether Mr. Throdahl at this [5] time changed or added any responsibilities of you or [6] the Medical Department? [7] A. No, it wouldn't. [8] Q. It wouldn't? P] A. No. [10] Q. So this was morea formal reporting function? [11] A. No, no. It's a way of stating what way we [12] think and what we want to get done. [13] Q. Okay. [14] A. And I was sort of the batter that is behind, [15] ready to bat if they want me to bat, that is all. [16] Q- Would it be fair to say, then, that this was [17] defining Monsanto's resource network? [18] A. No, this defines direction. [19] Q. Exhibit 6 is redefbting direction? P0] A. That's right. We were only there to, in mine, [21] would be to report to Throdahl and Throdahl would say, [22] George, we have got to do so and so far so and so. Page 181 [1] Q. On Exhibit 6 at the very bottom of the first P] page, that is the memo. [3] A. Yes. [4] Q. There is a pamgmph that talks about what the [5] Corporate Enoinmmental Policy Staff is going to do, [6] and l will read it. It says starting on the second m sentence, "Tins group, headed by Mr. Throdahl, will [8] become a central resource for developing corporate [9] policies and translating regulations, laws and various [10] pressures from public groups into corpomteaoide [11] action, hence it will provide corporate initiative in [12] managing Monsanto's impact on the total emrbonment." [13] Were there any responsibilities that you took [14] on after this that were part of the Corporate [15] Environmental Policy Staffs purpose? [16] A. No, what would happen, if they wanted me, Mr. [17] Throdahl would call and say, can you come over? [18] Q. Okay. [19] A. We would sit down and we would talk about it. [20] I would say I don't know. [21] Q. So let me first make sure l understand this, [22] then. You don't have any specific recollection of any; Pag 182 [1] particular projects. [2] A. Right. p] Q. You did for this Corporate Environmental [4] Policy Staff? [5] A. Yes, but you see my position has not changed. [6] Q. Right. [7] A. Since I was putthere. [8] Q. Right, the secondpage of Exhibit 6. [9] A. Right [10] Q. It says George Roush will continue as director . [11] DMEH. [12] A. And will continue to report to Throdahl doing [13] the same thing as I did before, unless Mr. Throdahl had [14] some question that he wanted to have answered right [15] away. [16] Q. When did the Medical Department become [17] Department of Medicate and Environmental Health? [18] A. Very soon after I became medical director. P9] Q. All right. [20] A. Throdahl wanted it that way because my [21] responsibility was environmental. P2]_______Q. In terms of the workplace environment? Page 183 [1] A. That's right. p] Q. Was that supposed to better define what you pj were domg, or did that change the responsibilities of [4i the Medical Department? pj A. It would be that I am available to help on pi anything that they, was related to this Environmental [7] Policy Staff. [8] Q. How about when the Medical Department became pi DMEH, was that a change in responsibility? [10] A. No, that was just defining it. [llj Q. Exhibit 6 on the second pagetoward the bottom [12j refers to the Dayton laboratory. [13] A. Yes. [14] Q. Was that part of your responsibility in the [15] Medical Department? [16] A. We had a doctor from the area who came in and [17] did physicals for us. [18] Q. At Dayton? [195 A. At the Dayton lab, he willgo into the lab and [20] doit. Pli Q. Did the Dayton lab do any toxicology work? [221 A. No._______________________ Page 184 [1] Q. No? pi A. They were not in our business. We supplied pj what they needed in the area. [4i MS. WALSH: That is it for this exhibit and pj for the two charts, as well, pj (Deposition Exhibit 9 was marked for [7] identification.) [8] MS. WALSH: Dr.Roush, could you readthrough pj Exhibit 9, please. [10] (Witness examines document.) [11] BYMS. WALSH: [12] Q. Have you reed through Exhibit 9? [13] A. Yes. [14] Q. This is a list of names and phone numbers that [15] is headed Emergency Notification, Phime Numbers for [16] Reporting Accidents. The date, which is on the bottom [17] of the second page is 9-15-77. Also on the second page [18] under the heading medical is your name, do you see [19] that? P0] A. Yes. pij Q. Do you recall what land of emergencies you [22] would have been notified of?______ ______________________ Page 185 [1] A. The best one I have got is the Sturgeon spill, pj Q. They notified you of the Sturgeon spill? [3] A. Sure did. [4] Q. What land of emergencies would it be necessary pj to notify you, the head of the Medical Department, or [6] the hard of DMEH at this point? [7] A. In this case it was a major spill. [8j Q. Would you get notified in the case of any pj major spill? [10] A. Depends on who above them wanted to call. [11] Q. All right. [12] A. That dedsion was made by somebody up here. [13] Q. Now the Sturgeon spill was a spill of a [14] railroad car that had some dioxm in it, right? [15] A. One teaspoonful. [16] Q. Then there was, and it was in Sturgeon, [17] Missouri? [18] A. Yes. [19j Q. And you are saying it would depend, whether | Page 179 to Page 185 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMON0009807 BSA Dcpo of George Rough, JR., M.D. Monsanto v Aetna February 18,1993 Cr.54456.0 XMAX(29) [20] got notified would depend on whether someone higher [21] up decided you should be notified? [22] ____ A. Sure. Somebody from safety most Kkely would Page 186 [1] call and tell us. [2] Q. Soon the first page under the Monsanto [3] category where it says Safety and Property Protection, [4] would it have been one of those people who decided [5] whether to notify you? [6] A. Yes. [7] Q- Do you know who notified you about the [8] Sturgeon spill? P] A. No. [10] Q. Okay. [11] A. I don't recall that anymore. [12] Q. What did you do when you found out about the [13] Sturgeon spUl when you were notified1 [14] A. One of my group went out there and looked ait [15] it right there, decided what they should do. [Id Q- So it wasn't necessarily any environmental [17] emergency or any large spUl that you would get [18] notified of, right, it would be whatever safety deemed [] you should be notfied of? [20] A. That's right. [21] Q. Were you, in the case of Sturgeon, expected to [22] take any specific action once you were notified? Page 187 [1] A. If I thought it was appropriate. It could [2] just be bringing it to our attention. [3] Q. Is the Sturgeon spin the only emergency that [4] you recall being notified of during your time in the [5] Medical Department? [6] A. Well, that was by far the biggest [7] Q. But are there any others that you remember? [8] A. That's the only accident that I can recall, at P] least offhand. [10] Q. AH right. [11] A. If we did find same more it would be much [12] smaller. [13] Q. Which you may have been notified of? [14] A. Yes. [15] Q. You don't recall? [16] A. No. [17] Q. Did you haoe any responsibility to notify [18] people in the Insurance Department if you were told [19] about an emergency under these notification procedures? [20] A. Somebody at higher level, or even at my level [21] would think to call me and say what took place at [22] Sturgeon.____________________ Page 188 [1] Q. But in terms of what you had to do next If you [2] were notified, did you haoe responsibility to call pj someone in the Insurance Department? [4i A. No, I would call somebody above the Insurance pj Department, let it come down. [6] Q. So there was no formal requirement that you [7] call the Insurance Department? [8] A. No. pj Q. Under these emergency procedures? [10] A. No, as long as it got done. [11] Q. Do you recall whether you had any [12] responsibility to notify the Insurance Department with [13j respect to your opinion on whether a certain emergency [14j was covered by insurance or not? [15] A. No. [16] Q. You didn't make any determinations? [17] A. No. And I would have to go there in order to [18] doit. [19] Q. Okay. [20] A. And I wouldn't go there unless it was a [2lj medical type, somebody else would be doing that [22]______ Q. Soil uras someone elsds responsibility to Page 189 [1] decide whether or not to make a coverage claim? [2] A. Yes, unless it came to me. Andthen I would pi go back and put it into what I thought was the normal [4] chain. pi Q. Okay, so - [6] A. If it wasn't medical I would get it out of the [7] medical responsibility. If it was medical plus safety [8] then I would call safety, someone from safety. [9] Q. If it was an emergency that was medical in [10] nature, did you haoe any responsMity for determining [11] whether Monsanto should make a claim on their policies? [12] A. No. [133 Q No. Do you haoe an idea of where that [14] responsibility would haoe rested? [15] A. No, I would just go back and I would go to the [16] safety route. [17] Q. So you would convey it to [18] A. Mine is of doing, rather than informing. [19] Q. You are saying you weren't part of the formal [20] chain of informing the Insurance Department on the [21] issues toe have ban talking about? [22] ____ A. No, I would tell one in the Insurance Page 190 [1] Department. pj Q. Do you recall any emergencies that you did pj inform the Insurance Department about? [4i A. No, that one came to us from safety, pj Q. Did you ever haoe any responsibility to notify [6] the actual insurance companies of an incident? [7] A. No, that wouldn't be my responsibility. [8] Q. Again, would that be the same answer, in other P] words it would either rest with safety or you would [10] notify someone else? [11] A. If it was big enough I would probably call my [12] boss. [13] Q.Okay. [14] A. You know? [15] Q. This is it for thisexhibit. [16] Wait, let me ask you one more question. On [17] the first page it says "Travelers," then, "(auto and [18] general lirddhty and Workers' Compensation)." [19] Did you ever have to contact Travelers? P0] A. No. Pli Q. Did anybody from Traders ever contact you? 1221 A. Not that Irecall.______________________________ Page 191 [1] Q. Did you ever, just to clarify, I know we haoe [2j discussed this in more general terms, the people listed pj under Insurance on page 1. [4] A. Yes. pj Q. Did you ever have to work with any of those [6j people? Their names would be Chapman, Caldwell, Grimm, [7] Stryker and Rasmussen. pj A. I am quite sure with some time came up with pj something with Chapman and maybe with Stryker. [101 Q. Do you haoe any recollection of what kind of [11] things you would have [12] A. No, I would have to work to find it, if I [13] found something. [14] Q. So there is nothing you specifically recall? [15] A. Nothing of consequence. [16] Q. That is it. [17] A. The time you get in trouble is if you want to [18] call somebody and you can't get them. And if I [19] couldn't get them, then I would go to their boss. PH MS. WALSH: This is Exhibit 10. [21] (Deposition Exhibit 10 was marked for P2] identification.) Page 192 [1] BY MS. WALSH: [2j Q. Dr. Roush, feel free to scan through it if you [3] like, this is Exhibit 10. I will tell you ahead of [4] time, my question on it is why toere you copied on this p] waste management study, which is dated January 3rd, [6] 1979. [7] So take as much time as you need to scan pj through it. Other than that I will direct you to [9j specific sections that I may have questions on. [10] (Witness examines document.) ACE-FEDERAL REPORTERS, INC 202-347-3700 page 185 to Page 192 HARTOLDMON0009808 BSADepo of George Roush, IR.. M.D. Monsanto v Aetna February 18, 1993 Cr-54456.0XMAXQO) [11] THE WITNESS: AD right. m BY MS. WALSH: [13] Q. You have looked through Exhibit 10? [14] A. Yes. There's lots of words in here. [15] Q. Do you have any recollection of why you would [16] be copied on a waste management study1 [17] A. No. It's just for information. [18] Q. Purely for information? [W] A. Yes. [20] Q. You haoe read through the document. Was there [21] anything that you saw that you did any work on m personally? Page 193 [1] A. No. And I wouldn't do it, it wouldn't be my [2] responsibility to do it. [3] Q. Okay. M A. My responsibility would be to read through [5] what they have done and see whether I agree with what [6] they have done. m Q. And then, inform them if you disagreed? [8] A. That's right. [9] Q. Let me direct you to - [10] A. But this is still lessee's, early in their [11] getting this in form [12] Q. Okay. [13] A. As I read it. [14] Q. Let me turn your attention to the tided page, [15] under, it has introduction at the top, under summary. [16] I zoill read part of the introduction. "Corporatewide [17] study of Monsanto's waste management condition was made [18] in December, 1978. Its purpose was to establish the [19] integrity and any potential problems related to present [20] and pak disposal of wastes from our manufacturing and [21] laboratory operations." [22] Under summary it says, "78 manufacturing Page 194 [1] sites, 20 animal product centers and three research [2] laboratories were included in the study. Each location [3] supplied information for the following:". M The first is active owned and operated [5] disposal systems. Would the Medical Department have [6] any involvement with that? m A. No. [8] Q. No? [9] A. No. m Q. The next one [11] A. It wouldn't have involvement with any of these [12] things until we got someplace where we had a chance to [13] look through for conclusions. [14] Q. What about the item that says potentially [15] toxic contents of systems, would medical be invoked in [16] that? [17] A. If they were to ask us to. [18] Q. They would provide information if requested? [19] A. They would help us to do it, we would have to [20] have more information than that. [21] Q. How about existing monitoring programs, would [22] medical be invoked in that? Page 195 [1] A. They really don't define monitoring programs [2] enough. [3] Q. So if it's health monitoring of workers? [4] A. That wouldn't be this. [5] Q. It wouldn't be, because this is waste [6] management? m A. Yes. [8] Q. Monitoring programs being developed, would [9] that be the same thing? , [10] A. Yes. [11] Q. It's probably not worker monitoring? [12] A. That's right. [13] Q. All right. [14] A. When they got done with it they may ask us [15] where they stand on toxic [16] Q. Okay. [17] A. But not without same background information. . [18] Q. So this study that was done at the plants and [19] manufacturing sites would not haoe had medkats [20] involvement up front? [21] A. Unless they asked specifically for some [22] question on same specific as expected. Page 196 [1] Q. On the next page that is headed Decisions and P] Actions, paragraph 2 begins, "Quantifying a complete [3] Monsanto waste disposal history is impassible due to [4] absence of records." P] Did you or anybody in the Medical Department [6] have to do any work in compiling a waste disposal IT] history for any fount? [8] A. No. P] Q. The last page, which is a chart, aver on the [10] left it says Anniston. [H] A. Yes. [12] Q. Did you ever do any work with respect to the [13] Anniston plant? [14] A. Yes. [15] Q. Do you remember what that work was? [16] A. POE'S. [17] Q. Okay. [18] A. Which would indude parathion in some form. [19] Q. Was that assessing the exposure risks? [20] A. I can't tell you because it's too early. [21] Q. When you say too early, you mean too early [22] to- Page 197 [1] A. For me to evaluate what information has been [2] given to us. [3] Q. I see. I am just asking your general [4] recollection of - p] A. Of this? [6] Q. No, of projects you may have worked on at m Anniston. [8] A. The one we were involved with most often was PI PCB's. [10] Q. Do you remember the specifics? [11] A. And parathion. [12] Q. What were you doing with respect to those [13] chemicals? [14] A. Parathion, it's a fact that that is toxic, or [15] can be toxic. [16] Q. So you were doing toxicology testing? [17] A. No, this is human testing. [18] Q. Is taxicobgy testing different than human [19] testing? [20] A. Toxicology can - a parathion effect would be [21] a toxic effect. [22] Q. I am not quite clear on that. Generally what Page 198 [1] work did you do that invoked PCB's and parathion and [2] Anniston? [3] A. I just had a long time before this become [4] alert and aware of PCB's. p] Q. When you were assistant director and after [6| that? m A. Well, when we had the concern from the fact [8] that it was in the environment and stayed in the P] environment. [10] Q. At Anniston, l understand that you identified [11] the PCB's and parathion as an issue, but at Anniston [12] were you doing some specific projects that related to [13] those two chemicals? [14] A. Yes, I was asked about PCB's from someone, I [15] don't remember what it was about, that was involved. [16] Q. You were providing information to the plant? [17] A. No, it was outside the plant. [18] Q. What do you mean when you say outside the [19] plant? [20] A. I am back in the same place, I can't recall. [21] All I am saying is I was involved in an evaluation of [22] parathion. Page 199 [1] Q. When you say "I was outside," does that mean Page 192 to Page 199 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMON0009809 BSA Depo of George Roush. IR-, M.D. Monsanto v Aetna February IB, 1993 Cr.54456.0 XMAXQ1) [2] that you weren't at Monsanto? I don't understand what [3] that means. [4] A. 1 was involved in parathicn in some operation [5] outside of Monsantoon Pen's. [6] Q. Okay. [7] A. On parathion. 1 keep saying it. [8] Q. So would [9] A. If we were to find it, it would be to find it [10] in the documents someplace where -- it was not a big [11] involvement. [12] Q. Was it, did you even do any work specific to [13] Amiston on PCB's or paratkion? [14] A. No. [15] MS. WALSH:That answersmy question. That is [16] it for this exhibit,Dr. Roush.You can put that [17] aside. [18] (Pause.) [19] BY MS. WALSH: [20] Q. Dr. Roush, do you know what poiynudear [21] aromatics are? [22] ____A. Usually cancer agents.________________________ Page 200 [1] Q. Alright. [2] A. It means nudeus, it's got more than one [3] nucleus. [4] Q. Is that a generic group? [5] A. We say PNA's. [6] Q. PNA's are a generic group of chemicals? [7] A. If they have mote than one nudeus, that is [8] one of the ways you get, a certain percentage of them [9] will be carcinogenic. [10] Q. So there are a lot of different compounds that [11] are PNA's? PNA isn't like oxygen? [12] A. No, no. [13] Q. It's more like aromatics, it's more like [14] organics, ifs not a specific term, is it? [15] A. No, but it talks about those chemicals that [16] have more than one nudeus. [17] Q. Al right. [18] A. And of those things that have more than one [19] nudeus, a number of them will be carcinogenic. [20] Q. Do you haoe a recollection of the early years [21] point that you were aware of that fact? [22] ____ A. Of what, what PNA's are?___________________ Page 201 [1] Q. That PNA's can be carcinogenic. [2] A. One way of finding are they carcinogens is to [3] look far the PNA's. [4] Q- Is that something that was known rdatiody [5] early on in your career? [6] A. In what? [7] Q. Was that something that you knew early on? [8] A. It was in literature, it's a literature thing. [9] It's a very common thing. [10] Q. Okay. Do you[11] A. It's animal studies is where they have first [12] talked about PNA's. [13] Q. Did you do any studies in the hdedical [14] Department on PNA's? [15] A. No, we did studies that showed they were [16] carcinogenic, then they might have been called PNA's. [17] Q. So the Monsanto Medical Department did some [18] studies [19] A. No. We did experimentalstudies. [20] Q. What did those experimental studies focus on? [21] A. We were doing lifetime feeding studies and it [22] was found to be carcinogenic.________________________ Page 202 [1] Q. Were you doing the lifetime feeding studies on [2] a number of different chemicals? [3] A. Well, we talked about them. We did one on [4] PCB's, we did one on acrylonitrile. I don't remember [5] whether we did any others or not. [6] But they are so big and so complicated, that's [7] about where I am. [8] Q. So there was a specific lifetime feeding study [9] that looked at poiynudear aromatics? [101 A. No. [11] Q. There was not? [12] A. Were found to be polynuclear aromatic after we [13] did them. [14] Q. Oh, okay. [15] A. And those that are carcinogenic may well be [16] PNA's as welL [17] Q. So your studies were not focusmg on [18] polynuclear aromatics? [19] A. No, no. [20] Q. They were focusing on - [21] A. It was finding, rather than direction. [22] ____ Q. I want to make sure I understand this. You________ Page 203 m don't haoe a recollection of when there was an [2] awareness in the industry that polynuclear aromatics [3] were carcinogenic? ` [4] A. No. [5] Q. Do you recall after the finding from the [6] lifetime feeding studies, rohether you did any |7] additional studies on polynuclear aromatics, [8] specifically? [9] A. On the ones that we have talked about earlier? [10] Q. Well, teU me which ones we talked about [11] earlier, because I am not - [12] A. I just said there are two of them, PCB's and [13] acrylonitrile. [14] Q. Those are both polynuclear aromatics? [15] A. No, I didn't say that. [16] Q. What did you say? [17] A. I think that if we had a hundred of them, 50 [18] or more of them may well be PNA's. But there are [19] different ways of getting to be cancer besides going [20] through the PNA route. There are somewhere they would [21] became carcinogens without going through a stage where [22] there are additional nuclei. Page 204 [1] Q. / don't mean - [2] A. PNA is still an experimental statement, way of [3] looking at carcinogenesis. If I had a good expert, if [4] we had one of the men from the - Pitot here, he would [5] say, yes, some of these are PNA's, not all of them are. [6] Q. I am not trying to torture you, I am having a m little built of a disconnect on this, though. How do [8] your lifetime feeding studies on PCB's and AN relate to [9] polynuclear aromatics? [10] A. We have a lifetime feeding study. And we cut [11] them apart and put them under a microscope. All of [12] those cells in that microscope, all those cells of [13] nuclei. Some of them will have two nudei. [14] I am not sure whether these two I talked about [15] have them, but if they do have, then they are called [161 PNA's. [17] Q. Okay. [18] A. Poiynudear aromatics. [19] Q. When you say we cut them apart, you are [20] talking about the animal test subject? [21] A. Yes. [2?]____ _ Q. So the cells of some of the animal test Page 205 [1] subjects that fed on AN or PCB's had polynuclear - [2] A. Scire. Some of them will hove cancers that was [3] not from that because they get their cancers normally, [4] too. [5] Q. But does that study whereyou fed an animal [6] PCB's or AN and then the animal's ceOsshow [7] polynuclear compounds - [8] A. Not compounds, nudei. [9] Q. Okay, they show, but does that tell you [10] anything about the carcinogenicity of polynuclear [11] aromatics? [12] A. Rather, die PNA's may help us to find which [13] ones are carcinogenic. You are going back instead of [14] forward. [15] Q. You are looking at which poiynudear - ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 199 to Page 205 HARTOLDMON0009810 BSAPepo of George Roush, 1R., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0XMAX(32) [16] A. Each cell has got a nucleus. [17] Q. Right. [18] A. When they have mare than one, it's more likely [19] that that will became a carcinogen, or carcinogenic [20] response, I should say. PH Q. So you are looking at the cells that have [22] A. What is the hangup on FNA's? I am not sure Page 206 [1] what, where we are going. P] Q. All I wont to know is if you did studies on [3] the carcinogenic effects of PNA's. What I don't W understand - p] A. You don't do carcinogenic studies of PNA's, [6] you do studies on chemicals. Some of them will end up m with more than one itudeus in that cell. P] Q. Okay. P] A. That is all I can say. Some of those FNA's m will go on and became cancerous. [11] Q. Did the Medical Department provide information [12] about these feeding studies to the plants if they [13] requested it? [14] A. Would we give them to the plants? [15] Q. Yes. [16] A. What we would probably do is talk about [17] something as complicated as that, we would talk to the [18] management of that plant, it's a bigger subject titan [19] just that plant [20] MS. WALSH: I want to made the next two [21] exhibits together. T22] (Deposition Exhibits 11 and 12 were Page 207 [1] marked for identification.) [2] (Witness examines documents.) [3] THE WITNESS: Did you notice he says again [4] recommending? P] (Pause.) [6] THE WITNESS: Did you see "George demands?" m That shows that I was in there fighting from time to [8] time. P] Is there another one? [10] MS. WALSH: 11 And 12. [11] (Witness examines document.) [12] THE WITNESS: Crosson's on my side. [13] BY MS. WALSH: [14] Q. You have raid through 11 and 12? [15] A. Yes. [16] Q. Let's look at Exhibit 11, first. This is a [17] March 2nd, 1981 memo. [18] A. Yes. [19] Q. From C. A. Sweets to D. R. Bishop and G. C. [20] Rankey. [21] Who is C. A. Sweets? [22] A. He is in personnel. Page 208 [1] Q. You sad his first mane is Clarence, is that [2] right? [3] A. Yes. [4] Q. Who are Mr. Bishop and Mr. Rankey, do you p] know? [6] A. Bishop is a public relations fellow who does m writings. [8] Q. All right. [9] A. He is a writing type. [10] Q. Do you know who Mr. Rankey is? [11] A. No. [12] Q. Mr. Sweets' memo begins "I am not sure what [13] the approach should be as to the employee [14] communications George Roush is (again) recommending." [15] He continues further. [16] Do you recall what employees communication [17] approach you were recommending? [18] A. I would suspect that I was telling them if [19] they have a concern or not. P0] Q. Telling who? [21] A. That the worker has a reason for a concern or [22L not. Page 209 [1] Q. You were telling the people in public P] relations? PI A. No, employees, not the public relations. [4] Q. So the approach you advocated was what? P] A. Telling them, telling the workers. [6] Q. Telling them specifically everything that m Monsanto knows about a chemical? [8] A. No. P] Q. Okay. [10] A. Things that are of concern to them. [11] Q. Things of concern to the worker? , [12] A. Yes. [13] Q. Was it the Medical Department's responsibility [14] to inform workers about things of concern to them? [15] A. We would say to the plant, the plant would be [16] the one that tells them what they should be telling [17] them. [18] Q. You would ted the plant management and they [19] would disseminate the information? P0] A. Yes. He may have a fight with personnel. PH Q. Do you recad whether the approach you were [22] advocating represented a change? Page 210 [1] A. I would think it was not. P] Q. Do you have any P] A. What we are really saying is something that [4] personnel would want to keep on doing something or p] something new has been found, we have got something [6] that causes a rash or causes skin - and we want to get P] that information to them before they get their rash. [8] that is the most likely problem. PI Q. What's personnel's role in communicating with [10] the workers? [11] A. The personnel manager at that plant reports to [12] Sweets. [13] Q. How does personnel play into the communication [14] of information of concern to the workers? [15] A. They are the ones who do it. [16] Q. They do it? [17] A. They communicate to the workers. [18] Q. Ad right. [19] A. If they don't, they lose their position. P0] Q. So if medical had information about a PI] previously uhknown rash that a chemical could cause, [22] medical would ted the plant, is that right? Page 211 [1] A. Yes. P] Q. Then the plant management would ted personnel P] at the plant? [4] A. No, they are part of management. PI Q. So you would be communicating to the plant [6] management which includes personnel, is that right? m A. Yes. [8] Q. Then personnel would communicate it to P] mdividual workers? [10] A. Either put it up on the bulletin board or have [H] a meeting with all the people from that one unit or [12] something. [13] Q. Ad right. [14] A. In same way they would communicate it to them. [15] Q. Do you recad talking to Mr. Sweets about this [16] at ad? [17] A. No. [18] Q. The second paragraph of Exhibit 11 says, [19] "Personally, 1 feel there is a balance point somewhere [20] between teding employees all we know about ad [21] substances and keeping them attuned to specific [22] concerns of which we (Monsanto management) decide they Page 212 [1] should be aware. 1 have no argument against a fully P] explanation of PCB"s and employee exposure to them [3] within Monsanto. As a matter of fact 1 am such ah [4] employee. On the other hand, Roy 'Red' Hall waslis p] exposed to hundreds of substances as an employee and [6] union safety committeeman at Crummrich. Giving him all Page 205 to Page 212 202-347-3700 ACE-FEDERAL REPORTERS, INC. HARTOLDMONOOQ9811 BSA Depo of George Roush, TR., MJD. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAX(33) [7] we know about all of them is going to be [8] self-defeating." [9] Was the[10] A. I have no qualms with telling people tilings [11] that they don't need to know. [12] MR. JONES: Doctor, you should just make sure [13] you allow Ms. Walsh to finish asking the question, and [14] then answer. [15] BY MS. WALSH: [16] Q- Mr. Sweets ends, "George prefers (demands) a [17] broad effort. 1 support a more specific (narrow) [18] approach. I would like you experts to conciliate, so [19] we can sort out a pmper (or at least an approved) [20] corporate effort." [21] To your knowledge, was there a corporate [22] policy on what to communicate to workers at this time? Page 213 [1] A. No. [2] Q. Would Mr. Sweets have been the one in charge [3] of formulating it? [4] A. Yes. [5] Q. Do you remember in what context you advocated [6] your broad approach, as Mr. Sweets calls it? [7] A. No. [8] Q- No. Did you advocate telling employees, as P] Mr. Sweets' memo puts it, "all toe know dbout all [10] substances"? [11] A. No. [12] Q. I am not sure I am clear on this. You [13] advocated telling employees those things that were of [14] concern to them? [15] A. Yes. [16] Q. Would that indude any physical effects of a [17] chemical they worked with? [IS] A. Sure. [W] Q- To your knowledge, was that information always [20] communicated? [21] A. We are saying it should be. [22] ____ Q. But did you have any knowledge about whether Page 214 [1] the plants actually communicated the information? [2] A. No one communicated to me that it was not [3] followed through. [4] Q. So you demit know one way or the other? [5] A. I would suspect they were being told. [6] Q. So your impression was most of the things that m you passed along from the Medical Department were [8] passed on to workers? [9] A. I would say it's a problem of what is a [10] hundred percent? [11] Q. Right. [121 A. You know, or whatever. They are at the plant [13] and we are not. [14] Q. Looking at Exhibit 12, and this is a memo from [15] W. D. Crosson bade to Mr. Sweets. Do you know who Mr. [16] Crosson was? [17] A. He was in public relations as I recall. [18] Q. Were you aware of the survey results that Mr. [19] Crosson passes on in tins memo? [20] A. I don't recall now. [21] Q. On the second page the paragraph begms, "On a [22] more positive note, however, both the corporate issues__________ Page 215 [1] study and the environmental network study showed [2] employees have a great deal of faith in the company's [3] communications efforts. This favorable opinion was [4] also reflected in the finding in the recent Sirota and [5] Alper Associates, Inc., study, that communications [6] within Monsanto concerning safety are rated highly. [7] (Concerning the Sirota study, it should be noted that [8] restricting information flow, 'the need to know" [9] approach, was identified as a communications problem [10] area.) Making a direct comparison of 'health' vs. [11] 'safety is subject to some error due to differing [12] perceptions of terms, yet the responses in the research [13] I have reviewed are so similar that I feel I can safely [14] draw conclusions." [15] Was it your belief that if you passed [16] information on to the Public Relations Department that [17] they would make some determination as to whether it was [18] a health or safety issue? [19] A. I don't know what they would do. PO] Q. You don't have any knowledge? [21] A. I don't know whether I did back then or not. 122] I might have called them on the phone and asked them Page 216 [1] what they thought they were saying. [2] Q. It refers to the need to know approach was pj identified as a communications problem area. [4] Would you characterize your, the employee pj communications approach that you advocated a need to [6] know approach? [7] A. Say that again. [8] Q. The approach you advocated in terms of what P] should be communicated to employees, would it be fair m to call that a need to know approach? [11] A. Yes. [12] Q. Do you know whether the environmental [13] communications group which Mr. Crosson refers to in the [14] last paragraph of Exhibit 12, did they adopt your [15] suggestion in terms of how communications should be [16] passed on to workers or what communications should be [17] passed on? [18] A. I don't recall. [19] Q. Do you recall having any conversations with P0] anyone regarding the subject matter of Exhibits 11 and PI] 12, these two memos? [22] ____ A. No, I don't, I would have to speculate.________ Page 217 [1] Q. Do you have any recollection of whether you pj did any work in terms of making recommendations on what pj should be communicated to employees? [4j A. Well, I say I think there should be, it says pj there, a candid, frank disclosure. [6j Q. Right, but do you have any specific [7] recollection of communicating that to certam people or [8j advocating that approach in meetings or that land of m thing? . [10] A. No, I think what I did here is where I would [llj go and as far as I would go because I would then go to [12] the plant and see whether they were or not. It's [13] supposed to be part of a team. [14j Q. What was your recollection of how PR fit into [15] this whole communications chain, because - [16] A. They sort of feel that their responsibility is [17] employees as well. [18] Q. If you had information dbout some effect of a [19j chemical you wanted to pass on, would you tell PR and [20] the plant management? [2lj A. A lot depends on the timing. If I would say, [22] can you write this, put this in a better form and send Page 218 [1] it down, you know. [2] Q. Okay. [3j A. I know I havegot employee relations on my [4j side when they say an effort in line with the corporate pj employees relations objective is the way to go. [6j Q. Exhibit 12 refers to Monte Throdahl's [7] Environmental Policy Staff. That is in the second [8j paragraph on page 1. P] A. AH right. [10] Q. Do you recall any discussions of [llj communications with workers in connection with the [12] Environmental Policy Staff? [13] A. We didn't care how it got to the employees as [14j long as it got there. We usually tried to work through [15] a group that is regularly in communications and let [16] this be another one, rather than saying we will tell [17] them the bad news kind. [18] Q. So this appears to be memos largely between [19j public relations employees, would that be accurate? [20] A. It's a means of getting communication to ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 212 to Page 218 HARTOLDMONOOQ9812 BSADepo of George Roush, [R., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0XMAX(34) [21] employees. [22] _____ Q, No, I mean just these two memos. Exhibits 11________ Page 219 [1] and 12, this is something that is internally passing[2] A. Yes. [3] Q. - within PR peoples hands, right? [4] A. It's stQl dealing with the same subject we [5] have been talking about [6] Q. Right. But it seems the way these memos [7] characterize it, it appears you id some time made some [8] type of disclosure recommendation, would that be [9] accurate? [10] A. Yes. [11] Q. My question is, just to be clear, did you make [12] that recommendation because you wanted to clarify the [13] policy or change the policy, or set a policy? [14] A. I don't recall. [15] Q. You don't remember? [16] A. No. [17] Q. That is it. [18] A. But I think the statement stands by itself, [19] hying to make it work and after we wrote it, then [20] Crosson agreed with it. [21] MS. WALSH: That is it for these exhibits. [22] _____Do you want to take a break? We have been Page 220 [1] going about an hour. [2] MR. JONES: Yes, I think so. [3] (Recess.) [4] MS. WALSH: We can go back on. [5] BY MS. WALSH: [6] Q. I know you mentioned at some point that the [7] toxicology lab that you built became the domain of [8] another department, is that right? [9] A. No. The, Jim Sanger's name is in this. And [IQ] Jim Senger was an associate or working for one of the [11] people in the top of Monsanto. And his boss changed [12] assignments so he didn't need Jim any longer. So pm [13] started to report to me. [14] Along about two or three yean later, four [15] yean later, I got a call from one of the chief [16] officers. He said, "You remember Jim Senger?" [17] I said, "I sure do." [18] He said, "He has been reporting to you for the [19] last four or five yean?" [20] I said, "Yes." [21] He says, "Do you know what?" [221 1 said, "What?"_______________ ____________ Page 221 [1] He said, "You are going to start reporting to [2] him." [3] Q. He replaced Mr. Throdahl? [4] A. Yes, and I started reporting to him. [5] Q. Okay. [6] A. That's what happened to Throdahl and what [7] happened to Senger. So Senger moved up, became vice [8] president as well. I don't know whether it's in there [9] or not. [10] Q. How did that affect the toxicology lab? [11] A. The toxicology laboratory was, while he was [12] working with me he was given assignment to be [13] responsible for the toxicology laboratory. [14] Q. All right. [15] A. What things they were studying and how they [16] studied them. [17] Q. And then when did the toxicology lab cease to [18] be your responsibility? [19] A. When Senger became my boss. [20] Q. Did the responsibility go to another [21] department or did it remain with Mr. Senger? [22] ____ A. Sometime along in there it moved over and Page 222 [1] became a responsibility of our Ag' Division. [2] Q. MAC? [3] A. Agriculture. [4] Q. Monsanto Agricultural Chemicals, or Company? p] A. Yes. M Q. Do you recall what year that switch happened? [7] A. No. [8] Q. When the toxicology lab became the Ag P] Company's responsibility did the whole toxicology [10] program go with it? [11] A. No, we had divided up the toxicologists, we [12] had about ten of them. [13] Q. Okay. [14] A. We had divided the toxicologists up into those [15] who worked for ag' and those who did not. So when Tom [16] Fuhreman, who was head of the toxicologists, moved over [17] to ag' he took with him the toxicologists who were ag' [18] toxicologists. [19] Q. Did you have a toxicologist working for you P01 named S. V. Baker? PI] A. No. [22]_______Q, Are you familiar toith that name id all? Page 223 [1] A. No. Maybe I should, but it's not one lam [2] familiar with at all. P] Q. Did you commonly haoe toxicologists who were [4] veterinarians? p] A. They were largely or all of them were down at [6] the fox' lab. [7] Q. The veterinariantoxicologists? [8] A. Yes. P] Q. That would not have been your responsibility [10] MS. WALSH: This is the next exhibit. [11] (Deposition Exhibit 13 was marked for [12] identification.) [13] BY MS. WALSH: [14] Q. Dr. Roush, you haoe Exhibit 13 in front of [15] you. Could you please skim through Exhibit 13. [16] A. Okay. [17] (Witness examines document.) [18] THE WITNESS: Okay. [19] BY MS. WALSH: P0] Q. You have read through Exhibit 13? pi] A. Well, no, I have looked through it and tried 1221 to study it as I went.; Page 224 [1] Q. All right. [2] A. But it's hard to even identify them by their [3] way of identifying sites. [4] Q. This is an August 29, 1983 memo that says as pj the subject line, Outline of September 1, 1983 Texas [6] City Plant Groundwater Assessment, and G. Roush is [7] under the list of recipients. That is you, is that [8] right? [9] A. Yes. [10] Q. So you received a copy of this? [11] A. Yes. [12] Q. Do you have a specificrecollection of [13] receiving a copy of this? [14] A. No. [15] Q. Do you remember working withMr. Hancock at [16] all? [17] A. No, I think Spraul was the one who was working [18] with the plant. [19] Q. So Spraul who is in your department reported [20] to you? [21] A. Right. And the one, his surveillance was [22] Texas Qty._ Page 225 [1] Q. All right. [2] A. He would come back and we would talk about [3] their groundwater. [4] Q. Do you recall any work that you or your [5] department did with respect to this Texas City plant [6] groundwater assessment? [7] A. It doesn't even suggest in here that we did [8] it. [9] Q. Is it[IQ] A. The problem of handling water was not ours. [11] Q. Okay. Page 218 to Page 225 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMONOOQ9813 BSA Dcpo of George Roush, 1R., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAX(35) [12] A. Ouis was people. [13] Q. So if there nos an issue with handling [14] groundwater that affected worker health, you would be [15] inoohxd? [16] A. Yes. We would also be involved if they told [17] us something about the chemistry. [18] Q. You would give feedback on the toxicobgy of a [19] certain chemical? [20] A. We would decide what should be done next if we [21] got a definition of what the chemicals were. [22] Q. All right. ________________________________ Page 226 [1] A. What was going on. [2] Q. When you say you would decide what would be [3] done next, are you talking about haw the workers would [4] have to deal with that chemical? [5] A. No, we are talking about whether anything had [6] to be done in the way of protection. [7] Q. Protection from the chemicals for the workers? [8] A. Right, or, that definition, what do you do [9] after that? It could be that we were talking about the [10] city as well, because it really was just on the other [11] side of that embaikment, embankment. [12] Q. So your concern in the Medical Department [13] would also have included people who were not workers [14] that were in the city that would have been affected by [15] the chemicals? [16] A. No, we would think about them. [17] Q. Okay. [18] A. We wouldn't say until we saw that there was a [19] problem. It could well be we say, well, you have got [20] to do this, because again, what they did was their [21] responsibility, not ours. [22] ____ Q. So you don't have any specific recollection of Page 227 [1] advice you gave the Texas City plant on this [2] groundwater assessment? [3] A. We wouldn't have given advice at this stage. [4] Q. Too early? [5] A. Yes. [6] Q. 1 am going to direct you to the fifth page of [7] the document which is headed Current Waste Disposal [8] Systems. [9] A. Yes, all light. [10] Q. Did you have any involvement with any of these [11] waste disposal systems that are mentioned? [12] A. See, whether it got primary treatment or [13] secondary treatment depends what it is. And we don't [14] have a definition of what it is. Once you have got [15] that, then you can talk about it. [16] Hus could well be that by knowing where this [17] thing came from they may have been able to do this [18] without our input. [19] Q. Would you in the Medical Department have input [20] if the plant recpiested it? [21] A. If they requested it we would go down and* 1 11 [22] discuss it with them, which could include either that's Page 228 [1] your problem, that would be one response. Another one [2] is, if you do this, then we can tell what should be [3] done. [4] Or, thirdly, we could say, we will go bade and [5] talk to our toxicologists and decide what we think [6] should be done. [7] Q. Okay. Would there - [8] A. There is a lot of probability, but it's based [9] on a further step than we have here. [10] Q. Which is further information, right? [11] A. No, this isn't even much information, we talk [12] about primary versus secondary. I have got to know [13] what die primary was, first. [14] Q. Did you personally do any work that involved [15] injection wells or incineration or boilers or [16] .landfills? [17] A. That wouldn't be our responsibility, that [18] would be going into their plant and doing their work [19] for diem, because if they did they wouldn't like [20] anything that we did, since it was their plant. [21] Q. So this land of dedskm [22] ____ A. You see, it's really theirs. ; Page 229 [1] Q. So those kind of decisions really rested with [2] the plant, itself? [3] A. If it's in the plant. [4] Q- And the Medial Department was there to lend p] resources? [6] A. But also to be involved if we thought we [7] should be. [8] Q. Okay. [9] A. But more information would be required. And [10] they weren't far enough along. [11] Q. Let me take you back two more pages, the page [12] headed North Ditch. [13] A. Yes. [14] Q. Were you fomdiar with the North Ditch at the [15] Texas City plant? [16] A. Pardon. [17] Q. Were you fomdiar with the North Ditch at the [18] Texas City plant? [19] A. Not by name of the ditch.North Ditch. m Q. Do you recall during your visits at the plant [21] an earthen ditch that went through the site from east [22] to west that bounded Monsanto's property? Page 230 [1] A. I think so. [2] Q. Did you ever have to do, did you or any of [3] your department people do any work that involved the [4] North Ditch? [5] A. No. There is an estuary right there, and what [6] was put into that estuary and under what drcurostances [7] I didn't know. When I went down there, we walked [8] through the plant with die manager and he would point [9] like this. Right adjacent to us was a big refinery, [10] and Amoco refinery. [11] Q. Okay. [12] A. They were into the same area, so there was [13] lots of contamination into that plant. Now how much? [14] We weren't involved in that. [15] Q. If you go bade, well actually I don't need to [16] direct you back. [17] Did you or any of your people in your [18] department have to do any migration studies? [19] A. No. [20] Q. The second-to-last pageofthis document, [21] which is headed Technical Approach. [22] A. Yes.____________ Page 231 [1] Q. Sets out Phase I, Trench drain network in [2] settling pond. [3] Oay Cap Over West Side. [4] Phase II. Substitute conduit culvert for [5] borrow ditch. [6] Backfill borrow ditch. m Concrete slurry wall along south property [8] line. PI Phase III. Soil - bentonite slurry walls [10] along north and west property lores. [11] Assuming this applies to the North 80 site, [12] would the Medical Department or you have had any [13] involvement with working on these phases? [14] A. Not at this stage. [15] MS. WALSH: That is it for this document. [16] Please mark this document as Exhibit 14. [17] (Deposition Exhibit 14 was marked for [18] identification.) [19] BY MS. WALSH: [20] Q. Dr. Roush, Exhibit 14 is dated January 9, [21] 1984, and its headed Status of Environmental [22] Practices. I believe its a presentation that was * 1 2 Page 232 [1] given by Monte Thrvdahl, as the name indicates up in [2] the upper left comer. ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 225 to Page 232 HARTOLDMONOOQ9814 BSA Pepo of George Roush, JR,, M-D. Monsanto v Aetna February 18, 1993 Cr.54456.0 XMAX(36) [3] l would like you to read pages 1 through 5, [4] and 1 will direct my pages only to those. Feel free to p] skim the rest of the document f you like. I am not [6] going to ask any questions about it. [7] (Witness examines document.) [8] THE WITNESS: Do you see what it says on page PI 2. in 1977? Have to advertise a Htfle bit. Has a [10] long record of responsible decisions. [11] (Pause.) [12] THE WITNESS: Just the first five pages? [13] BY MS. WALSH: [14] Q. fust the first fine pages. [15] A. Makes good reading. [1(5] Q. So you have read through at least the first [17] five pages of Exhibit 14? [18] A. Yes. [19] Q. I want to direct you to the paragraphs that [20] are on page 4. [21] A. Page 4. All right. [22] ____ Q. Looking down, after the list of six items it Page 233 [1] says, "Let me give an example of an important job where [2] establishing good communications has proved to be [3] critical to success, yet has not proved easy to do." [4] The next paragraph reads, "l am thinking of [5] toxicology. In the early 1970s it became dear that Monsanto1's program of animal testing was not meeting m our needs for consistency or uniformly high quality. [8] Dr. George Roush also was convinced that such testing [9] would become increasingly important to our efforts to [10] determine the human health effects to Monsanto's [U] chemicals and that new regulations would demand an [12] increasing volume of such testing." [13] I toill read you the rest of it, if it wdl [14] make it clear. "The need for better monitoring and [15] control became pamfuOy obvious soon, as the [16] Industrial BioTest scandal unfolded. We obviously did [17] not know in early 1977 that an 1BT was going to happen, [18] and we weren't prepared for it then. Bid l can say [19] that our present system of placement and audits will [20] prevent any recurrence." [21] Let me stop here. Did you revamp the program [22] of animal testing when you started as the medical Page 234 [1] director? [2] A. When I came to Monsanto all of our toxicology [3] was being done at Industrial BioTest, that is what it [4] says. [5] Q. What is the Industrial BioTest scandal? [6] A. It was shortly thereafter that EFA came in and [7] found that they thought Industrial BioTest was not [8] doing an adequate job. [9] Q. All right. [10] A. For HPA. [11] Q. Okay. [12] A. And Monsanto was doing all of their testing at [13] Industrial BioTest. [14] Q. Did that in essence render their toxicology [15] studies for you ineffective in EPA's eyes? [1(5] A. No. [17] Q. No? [18] A. No. It required us to reevaluate them [19] ourselves, and so a rewritten statement was given to [20] the EFA. They were done by Levinskas. [21] Q. All right.1 2 3 4 5 6 7 8 9 [22]______ A. And he had a couple of other outstanding Page 235 [1] people who helped him to review them. [2] Q. Was that the only effect on Monsanto? [3] A. There were lots of studies that we didn't even [4] try to get reevaluated. But it was a terrible burden [5] on the operating companies that were dependent on this [6] testing. [7] Q. Was that part of the emphasis for building the [8] new toxicology lab? [9] A. Yes. [10] Q. Ways it the only reason for budding it? [11] A. No, they wererrt adequate. But when we [12] dropped IBT we, Levinskas got us involved with [13] Biodynamics, that does the same thing. [14] Q. Okay. [15] A. And their studies have been quite adequate. [16] Q. When he refers to in the early 70s, it became [17] clear that Monsanto's program of animal testing was not [18] meeting our needs for consistency or uniformly high [19] quality, to your knowledge, was that referring to just [20] the fact that you were using IBT? [21] A. Yes. I am not saying a hundred percent. [22] Practically that was correct. Page 236 [1] Q. The last full paragraph on page 4 says, "The [2] results from toxicology testing are useful to help [3] identify possible human health rides from Monsanto [4] chemicals. It's DMEWs jab to interpret all the [5] relevant data. But it is the opending unitd job to [6] manage the plants and businesses. And we can't make [7] good decisions on testing priorities without the [8] operating units? input. [9] "We struggled for a few years to establish [10] workable interfaces and communications, between DMEH [11] and operating units, especially the old MIC. With the [12] new corporate organization, and persistent effort, good [13] communications links, through the DEO now exist. Now [14] all the operating units haoe in place plans to fill [15] those important gaps in the data base that remain [16] open." [17] How did DMEH ultimately communicate with the [18] operating units? [19] A. Sent them reports of the results of the [20] studies. [21] Q. Were testing priorities established by the [221 Medical Department? Page 237 [1] A. We would do that as the requests came from the [2] operating companies. [3] Q- So in conjunction with the operating units the [4] testing priorities were set? [5] A. Sure. And if we couldn't do them all we would [6] go back and negotiate which ones we would do next. [7] Q. Do you recall any issues that you had to work [8] out with the operating company to get workable [9] interfaces and communications? [10] A. No, it just took time. [11] Q. It was more establishing what needed to be [12] there? [13] A. Sure, having them understand what has to be [14] done. [15] Q. Okay. [16] A. And why we have got to do it differently and [17] that sort of thing. [18] Q. Were the interests of DMEH in terms of testing [19] priorities different from the interests of the [20] operating plants? [21] A. By and large, it has something to do with 1221 acceptability. When they found out what we did was1 11 Page 238 [1] almost invariably right, they didn't quarrel. When [2] they found it was easier than doing it themselves, we [3] monitored what was being done and assured them it was [4] being well done, then they were very happy to have us [5] doit. [6] Q. When you say to have us do it, was the idea [7] that the plants had the option to [8] A. Not the plants. [9] Q. Who are you talking about then? [10] A. Talking about the operating companies. [11] Q. The operating companies, okay. [12] A. Yes. [13] Q. Was the idea that the operating companies [14] could do testing outside of DMEH? [15] A. Could operating companies? [16] Q. Yes. Page 232 to Page 238 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMONOOQ9815 BSA Pepo of George Roush, IR-, M.D. Monsanto v Aetna February 18, 1993 Cr-54456.0 XMAXQ7) [17] A. No. [18] Q. Oka/. [19] A. We had to do it We were recognized as being m the ones, we knew what the laboratories could provide [21] to us, and we learned if they didn't meet schedules and [22] all that kind of business. Page 239 [1] So we did it and made them meet die schedules [2] of the operating companies. [3] Q. Did DMEH have a method for deciding to test, [4] and when I say test, I mean toxicobgy testing, on [5] chemicals even if the plant involved didn't request M testing? [7] A. Not plants, operating companies. [8] Q. The operating companies? [9] A. Yes. [10] Q. Let me make sure l understand this then. If [11] you had MIC down at Texas City [12] A. MIC wasn't in Texas City, one of MICs plants [13] was in Texas City. [W] Q. Okay. [15] A. The headquarters was in St. Louis. [16] Q. Would it he MICs headquarters that would [17] request toxicology testing on a particular chemical? [18] A. No, they would tell us what they had to do. [19] and we would tell them what tests they need. po] Q. They would be communicating the regulatory [21] demands and that kind of thing? [22] A. We knew the demands. It was their recognition Page 240 [1] what they needed and they communicating to us and we m tell them that they are out of line on what terms, [3] needs to be done. We were the experts. [4] Q. Was it the operating company that tons P] communicating with the plant on this? [6] A. Yes. m Q. Or did the DMEH also work with the plants? [8] A. Hie plants weren't much interested in these P] studies. These studies were being done to meet [Id requirements of EPA and whoever else.' [11] Q. So it was much more of a headquarters concern? [12] A. Yes. [13] Q. Okay. [14] A. But we had no problem if Texas City called us [15] and asked about it, a study. We would tell them if we [161 knew it, we weren't trying to withhold it. [17] Q. Okay. [18] A. But they were too busy doing what they had to [19] do. [20] MS. WALSH: That is it for this exhibit. [21] Let's mark this as the next exhibit f22] (Deposition Exhibit 15 was marked for Page 241 [1] identification.) [2] BY MS. WALSH: [3] Q. This is Exhibit 15, Dr. Roush. If you could [4] read through it. [5] My question is basically what loas your [6] involvement in the issues that are described here, if m that helps you read it with an eye toward that. [8] (Witness examines document.) [9] THE WITNESS: CMA. [10] That's quite a statement. [11] BY MS. WALSH: [12] Q. You have read through Exhibit 15? [13] A. Yes. [14] Q. This is a June 30th, 1986 memo. The subject [15] is Monsanto Position Statement and Overview. One of [16] the recipients is listed as G. Roush. That is you, [17] right? [18] A. Yes. [19] Q. So you received a copy of this? [20] A. It says I did. [21] Q. Do you have any reason to think you didn't [22] receive it? Page 242 [1] A. What? m Q. Do you have any reason to think you did not p] receive a copy? [4] A. I have no reason, you know, I would assume I p] got it. [6] Q. Do you recall - m MR. JONES: Off the record. [8] (Off-the-record discussion.) m BY MS. WALSH: m Q. Do you remember what the ECC Groundwater in] Steering Committee is? [12] A. That was not a medical group. [13] Q. You weren't involved? [14] A. No. [15] Q. Do you remember having any involvement in [16] formulating this Monsanto Company groundwater position [17] statement? [18] A. No, I did not. [19] Q. You did not? m A. No. pi] Q. Do you recall whether you had any input on the |22L information that went mto this groundwater overview Page 243 [1] that is dated June, 1986, which is the third page of p] the document? [3] A. No, I did not. [4] Q. Did you have any input in makmg the p] determination of the impact on Monsanto of public and [6] governmental concern about groundwater quality? [7] A. No, I did not. [8] Q. Did you ever do any work that had to do with m legislation or regulation that related to groundwater? m A. No, I did not. [ii] Q. On what is numbered page 4 of the memo there [12] is a headmg that says Advocacy Groups. The first is [13] the National Groundwater Policy Forum. Did you ever do [14] any work for them? [15] A. No. [16] Q. Did you ever do any work that involved the [17] National Groundtoater Policy Forum? [18] A. No. It says who it was, it was Fernandez and [19] Pierle. [20] Q. Did you ever do any work with the second group [21] listed, the National Environmental Development [22]_ Association? Page 244 [1] A. No. [2] Q. We have discussed the next advocacy group. P] xohich is Chemical Manufacturers Association. You [4] belong to CMA, right? p] A. I didn't. . [6] Q. Monsanto was a member? [7] A. Yes. [8] Q. You personally did some work with them, is m that correct? [10] A. No, some of our department did, toxicologists [11] did. [12] Q. Did you or anybody in your department do any [13] work with CMA that had to do with groundwater? [14] A. No, it wasn't our department. [15] Q.Okay. [16] A. It was someone else, but they were involved. [17] Q. So even your toxicologists wouldn't have done [18] any work with groundwater? [19] A. Unless they were asked to. m Q. Did you ever do any work with the National [21] Water Alliance? [22] A. No. Page 245 [1] Q. How about the National Agricultural Chemists [2] Association? ; P] I am still on page 5. At the last bullet, [4] paragraph. p] A. Yes. [6] Q. Did you ever do any work with the National [7] Agricultural Chemists? ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 238 to Page 24S HARTOLDMONOOQ9816 BSADepo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr-54456.0XMAX(38) [8] A. We weren't members, our Ag' Company was [9] involved. [10] Q. So the Medical Department didn't hmx any [11] involvement? [12] A. No. [13] Q. How about the Synthetic Organic Chemicals [14] Manufacturers Association? [15] A. No. [16] Q. How aboutthe National Wildlife Federation? [17] A. No. [18] Q. The Chemical Specialties Manufacturers [19] Association? [201 A. No. [21] Q. So, and when I ask, I mean did you or anyone [22] in your department?_________________________ ;________ Page 246 [1] A. That's right That doesn't mean we didn't, we [2] could have been involved by virtue of Ag' Company [3] asking us to be, for instance. [4] Q. I see. There is, the last page of the memo it [5] talks about future plans. It says, "First we will [6] continue to protect groundwater by adhering to our [7] environmental guidelines for current operations and by [8] responding to instances of serious past contamination [9] through the ongoing groundwater assessment program." [10] Did you or anybody in your department work on [11] the ongoing groundwater assessment program? [12] A. No. [13] Q. "Secondly we will continueto try tosteer [14] this policy development along the lines of reason and [15] effectiveness." And it tabes about workmg on ' [16] legislation that zoill affect groundwater policy. [17] Did you or anybody in your department do any [18] work with respect to that type of legislation? [19] A. No. [20] Q. Finally at the very bottomofthe page it [21] says, "The Corporate Environmental Policy Staff will [22] continue to coordinate these efforts, but wdl solicit____________ ; Page 247 [1] the involvement of the various expertise resident [2] throughout Monsanto as noted above." [3] I know you said you don't have a recollection [4] of bemg involved on the Corporate Environmental Policy [5] Stiff. Does this refresh your recollection about why [6] you may have received this memo? , [7] A. No. [8] Q. Do you know why you would have been copied on m this memo? [10] A. Because they weren't sure I shouldn't be. [11] Q. Okay. [12] A. This all could have changed since '88, of [13] course. [14] Q. In terms of the Medical Department's [15] involvement? [16] A. Work participation or other organizations may [17] have gotten involved with it, you know, to improve it. [18] Q. Okay. [19] A. Obviously, their commitment to getting control [20] over groundwater was there, and how they did it, I [21] can't imagine them going four years without finding [22] something they could have done better._______________ Page 248 [1] Q. Right. [2] A. But I don't know. [3] Q. Is your thought that, in saying that are you [4] saying that perhaps the Medical Department - [5] A. Not the Medical Department. [6] Q. Just the company in general? [7] A. Monsanto would. [8] MS. WALSH; That is all I have. If you don't [9] mind, why don't we take a five-minute break and I will [10] go back through my notes and make sure I didn't leave [11] anything out and get you out of here sooner. [12] (Recess.) [13] BY MS. WALSH: [14] Q. I just have one more short series cf questions [15] for you, Dr. Roush. Before we Med about the [16] education and training you received I want to make sure [17] that l understand. [18] And my question is, during your time at [19] Monsanto did you develop any substantive expertise in [20] environmental poUution cleanup? |21] A. Did 17 [22] Q. Yes._________ ____________________________ Page 249 [1] A. No. P] Q. Same time period. Did youdevelop any P] substantive expertise in waste incineration? [4] A. No. p] Q. Same question with respect to landfills? [6] A. No. [7] Q. Same question with respect to sob and [8j groundwater? P] A. No. [10] Q. Same question with respect to pit [11] construction? [12] A. No. [13] Q. Did you develop anysubstantive expertise with [14] respect to the specifics of waste disposal methods? [15] A. No. [16] Q. Did you develop anysubstantive expertise with [17j respect to how to deal with gmundwater pollution? [18] A. No. [19j Q. Did you develop any substantive expertise with P0] resped to how to deal with soil pollution? [21] A. No. [22] ____Q. Or soil contamination?_______________________ Page 250 [1] A. No. [2j Q. Did you develop any substantive expertise in P] terms of the prevention of chemical releases? [4] A. No. pi Q. Did you develop any substantiae expertise with [6] resped to the detection of chemical releases? P] A. No. [8] Q- Did you develop any substantive expertise with pj resped to methods of pollution abatement or reduction? [10] A. No. [11] MS. WALSH: Those are all the questions I [12] have. Thank you for your time. Mr. Jones may have [13] some questions for you. [14] MR. JONES: I have no questions. [15] (Whereupon, the deposition was concluded at [16] 5;50 p.m.). [17] [18] [19] P01 [21] [2?]___________________________________________ Page 251 [1] ACKNOWLEDGMENT OF DEPONENT [2j I, George Roush, Jr., M.D., hereby acknowledge that [3j I have read and examined the foregoing pages of my [4] deposition and that pj (Check appropriate box.) [6j () the same is a true, correct and complete [7] transcription of the answers given by me to [8j the questions therein recorded. pj () except for the changes noted in the attached [10] Errata Sheet, the same is a true, correct and [llj complete transcription of the answers given [12] by me to the questions therein recorded. [13] Date [14] Signature of Witness [15] Subscribed to and sworn before me. [16] this day of, 19 [17] [18] Notary public in and for the [19j My commission expires: [201 [21] Page 245 to Page 251 202-347-3700 ACE-FEDERAL REPORTERS, INC HARTOLDMONOOQ9817 BSA Depo of George Rough, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 [??]_________ ;_____________________________ Page 252 [1] Certificate of Reporter) [2] United States of America ) ss. 131 District of Columbia ) [4] I, CRAIG L. KNOWLES, the officer before whom P] the foregoing deposition was taken, do hereby certify [6] that the witness whose testimony appears in the [7] foregoing deposition was duly sworn by me; that the [8] testimony of said witness was taken by me to the best [9] of my ability and thereafter reduced to print under my [10] direction; that I am neither counsel for, related to, [11] nor employed by any of the parties to the action in [12] which this deposition was taken and, further, that I am [13] neither a relative nor an employee of any attorney or [14] counsel employed by the parties thereto nor financially [15] or otherwise interested in the outcome of this action. [16] Witness my hand this 19th day of February, 1993. [17] [18] Notary Public in and for [19] the District of Columbia. P0| My Commission Expires October 31, 1994: pi] [22]____________________________________ XMAX(39) ACE-FEDERAL REPORTERS, INC 202-347-3700 Page 251 to Page 252 HARTOLDMONOOQ9818 HARTOLDMONOOQ9819 BSA Look-See Concordance Report 2,383 UNIQUE WORDS 386 NOISE WORDS 35,774 TOTAL WORDS SINGLE FILE CONCORDANCE CASE SENSITIVE WORD RANGES* BOTTOM OF PAGE - 1- I [16] 3:9; 46:3, 4, 7, 18; 50:12; 63:22; 158:9; 168:20; 169:17; 170:10; 178:10; 191:3; 218:8; 224:5; 232:3 10 [5] 3:18; 191:20, 21; 192:3, 13 1025 [1] 2:4 10:00 [1] 1:19 II [8] 3:19; 206:22; 207:10, 14, 16; 211:18; 216:20; 21822 12 [10] 42; 173:11; 20622; 207:10, 14; 214:14; 216:14, 21; 218:6; 219:1 1201 [1] 1:19 126 [1] 4:6 12:35 [1] 125:7 13 [5] 4:3; 223:11, 14, 15, 20 136 [1] 3:10 14 [5] 4:4; 231:16, 17, 20; 232:17 15 [12] 4:5; 42:15; 43:4, 7; 91:1, 4; 95:10; 114:16; 24022; 241:3, 12 1500 [1] 1:19 157 [1] 3:11 167 [1] 3:12 17 [1] 167:11 173 [1] 3:13 176 [3] 3:14, 15, 16 1776 [1] 2:11 18 [1] 1:14 184 [1] 3:17 19 [2] 162:12; 251:16 191 [1] 3:18 1952 [2] 20:11 1954 [1] 12:4 1955 [1] 12:4 1957 [3] 15:3; 19:8; 20:13 1962 [2] 20:18; 23:7 1963 [2] 21:1; 23:7 1964 [4] 81:5; 83:9, 15; 84:10 1968 [1] 21:18 1970s [1] 233:5 1972 [4] 232, 4; 2821; 64:8 1973 [5] 4620; 47:5; 482; 51:5; 162:15 1974 [1] 167:12 1975 [2] 162:15; 173:11 1977 [5] 177:12; 178:22; 179:17; 232:9; 233:17 1978 [1] 193:18 1979 [1] 192:6 1980 [4] 572; 178:10, 14, 15 1981 [1] 207:17 1983 [2] 224:4, 5 1984 [4] 178:11, 12, 19; Depo of George Ranah, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 Look-See(41) 23121 1986 [2] 241:14; 243:1 1988 [6] 30:6, 8; 315, 19; 32:11; 158:9 1989 [1] 17121 1993 [2] 1:14; 252:16 1994 [1] 25220 19th [1] 252:16 1:35 [2] 125:7; 1262 -2- 2 [9] 3:10; 4621; 136:14, 17; 137:14; 15820; 170:17; 1962; 2325 20 [4] 6:18; 153:12; 1542; 194:1 20006 [1] 2:12 20007 [1] 2:6 206 [2] 3:19; 42 22 [1] 177:12 223 [1] 4:3 231 [1] 4:4 240 [1] 4:5 25 [2] 59:14 26 [2] 4620; 47:5 29 [1] 224:4 2nd [1] 207:17 -3- 3 [6] 3:11; 157:7, 8, 11; 158:7; 171:9 30 [2] 66:11, 14 300 [1] 25 30th [1] 241:14 31 [1] 25220 3rd [1] 192:5 -4- 4 [9] 3:12; 167:8, 11; 168:14; 1732; 23220, 21; 236:1; 243:11 46 [1] 3:9 -5 - 5 [10] 3:4, 13; 160:6, 20, 21; 173:7, 10, 19; 232:3; 245:3 50 [2] 50:13; 203:17 50s [3] 52:11, 12; 59:11 51 [4] 10:4, 6, 22; 11:4 52 [2] 11:4, 18 53 [2] 11:17, 18 55 [1] 12:9 56 [2] 12:9, 12 57 [3] 12:12; 132; 1420 5:50 [1] 250:16 -6 - 6 [12] 3:14; 176:16, 17; 1772, 6, 9; 17822; 179:8; 180:19; 181:1; 182:8; 183:11 605 [1] 137:10 60s [6] 26:15, 16, 17; 28:8; 86:16 62 [2] 20:16, 17 68 [1] 21:16 -7- 7 [7] 3:15; 176:19, 21; 177:22; 178:9, 14, 15 70s [5] 57:5; 96:4; 163:5, 22; 235:16 72 [1] 71:12 73 [1] 29:13 77 [2] 178:15, 21 78 [1] 19322 -8- 8 [6] 3:16; 176:19, 21; 17722; 178:10, 19 80 [14] 138:12, 15, 19; 1392, 12; 140:5; 141:11; 142:4; 1492, 12; 154:6, 9, 17; 231:11 86 [1] 1403 88 [1] 247:12 88C-JA-118-1-CV [1] 1:6 -9- 9 [5] 3:17; 184:6, 9, 12; 23120 9-15-77 [1] 184:17 9327590 [1] 137:10 99 [1] 82:12 - A- a.m. [1] 1:19 abatement [8] 17:13; 43:13, 18, 19; 11920; 145:9, 11; 250:9 ability [3] 5222; 6120; 252:9 able [6] 9:13; 49:6; 62:18; 71:1; 77:12; 227:17 abnormal [4] 60:8; 171:17; 172:17; 173:1 aboard [1] 90:7 Aborigines [1] 7322 absence [1] 196:4 absolutely [1] 123:10 absorb [1] 5321 accept [1] 76:19 acceptability [1] 23722 Acceptable [1] 87:12 acceptable [7] 69:15; 7420; 86:18; 87:7, 12, 16; 151:3 accepted [1] 28:14 accident [2] 171:4; 187:8 Accidents [1] 184:16 accumulates [1] 130:1 accurate [3] 54:8; 218:19; 219:9 acknowledge [1] 2512 ACKNOWLEDGMENT [1] 251:1 Acrylic [1] 127:7 acrylic [2] 127:5; 13220 Acrylonitrile [1] 132:18 acrylonitrile [5] 133:6, 10, 14; 202:4; 203:13 action [4] 181:11; 18622; 252:11, 15 Actions [1] 1962 actions [1] 160:6 active [1] 194:4 actual [3] 151:16; 167:4; 190:6 acute [4] 15:18; 6221; 129:13, 20 , acutely [2] 129:17 add [1] 146:14 added [3] 170:7, 20; 180-3 additional [7] 652; 114:4; 172:8; 179:18, 19; 203:7, 22 address [3] 17:15; 5620; 104:9 addressed [1] 18:9 adequate [3] 234:8; 235:11, 15 adhering [1] 246:6 adjacent [3] 73:9; 153:13; 230:9 adopt [1] 216:14 adverse [3] 129:10, 12, 16 adversely [1] 78:19 advertise [1] 2323 advice [3] 98:12; 227:1, 3 advise [1] 82:8 Advocacy [1] 243:12 advocacy [1] 2442 advocate [1] 213:8 advocated [5] 209:4; 2135, 13; 2165, 8 advocating [2] 20922; 217:8 AETNA [1] 1:8 affairs [1] 101:3 affect [4] 845; 134:18; 221:10; 246:16 affected [9] 593; 77:6; 7820; 79:10; 1172; 120:9; 165:5; 225:14; 226:14 affecting [1] 119:4 AFTERNOON [2] 4:6; 126:1 Ag [4] 222:1, 8; 245:8; 2462 ag [3] 222:15, 17 agencies [11] 392; 412; 42:12; 98:1, 10, 18; 99:1; 100:1, 11; 101:11, 22 agency [1] 98:5 agents [1] 19922 agree [2] 12422; 193:5 agreed [1] 21920 agreeing [1] 12421 agreement [2] 1:17; 33:18 Agricultural [3] 222:4; 245:1, 7 Agriculture [1] 222:3 AIDS [1] 61:14 aids [1] 15822 Air [1] 102:9 air [12] 15:6, 9; 2722; 83:18, 19; 84:4, 11; 86:9, 18; 144:19; 145:12 al [1] 1:9 albeit [1] 55:14 alert [1] 198:4 Alliance [1] 24421 allow [3] 144:14; 145:5; 212:13 Allowing [2] 144:16, 17 allowing [1] 144:9 Alper [1] 215:5 America [2] 74:1; 2522 American [1] 662 Amoco [1] 230:10 amount [15] 32:16; 70:15, 16; 72:17, 20; 73:8, 14, 19; 74:1, 21; 77:6; 84:11; 86:18; 129:9, 11 amounts [3] 69:15; 74:5; 127:18 analysis [1] 171:14 analyzed [1] 73:8 angiosarcoma [4] 163:4, 16; 164:4, 5 angiosarcomas [4] 16221; 16422; 166:6; 172:10 animal [9] 194:1; 201:11; 20420, 22; 205:5, 6; 233:6, 22; 235:17 animals [3] 7622; 164:1, 2 Anniston [7] 196:10, 13; 197:7; 1982, 10, 11; 199:13 Annual [1] 81:6 annual [7] 58:10; 65:18; 94:14; 97:14; 167:4; 170:6, 17 answer [21] 48:5; 50:3; 68:13, 14; 70:12, 13, 20; 712; 84:6, 17; 10421; 1053; 115:8; 117:3; 1243; 131:19; 136:12; 154:10; 167:1; 190:8; 212:14 answered [4] 452; 64:13; 11422; 182:14 answers [6] 520; 723; 10320; 199:15; 251:7, 11 anti-knock [3] 22:12; 8022:82:18 anticipating [1] 58:17 anybody [8] 8:12; 115:6; 155:16; 19021; 196:5; 244:12; 246:10, 17 anymore [2] 87:20; 186:11 anyway [4] 12122; 1252; 140:1; 161:6 apart [2] 204:11, 19 apologize [2] 137:5; 169:1 apparently [2] 85:14; 127:11 appear [2] 1602; 164:22 APPEARANCES [1] 2:1 appeared [1] 33:15 appears [3] 218:18; 219:7; 252:6 applied [1] 32:4 applies [1] 231:11 apply [1] 127:14 appointed [1] 177:13 appreciate [1] 46:9 Approach [1] 23021 approach [13] 208:13, 17; 209:4, 21; 212:18; 213:6; 215:9; 2162, 5, 6, 8, 10; 217:8 approaches [1] 124:10 appropriate [4] 175:6; 176:5; 187:1; 251:5 approval [1] 161:8 approved [1] 212:19 April [2] 167:11; 178:10 area [11] 96:15; 107:1; 109:12; 114:5; 151:1; 179:16; 183:16; 184:3; 215:10; 216:3; 230:12 areas [6] 18:4; 64:11; 116:7, 13; 137:19; 142:14 aren't [4] 5520; 61:2; 104:12; 128:5 argument [1] 212:1 arise [1] 12020 arms [1] 170:12 Army [3] 9:17, 19, 22 aromatic [1] 202:12 aromatics [10] 199:21; 200:13; 2023, 18; 2032, 7, 14; 2043, 18; 205:11 arose [1] 52:4 art [6] 130:15; 131:1, 3, 4; 143:6, 14 article [9] 81:6, 9, 16; 82:19; 83:8, 9, 10; 137:2, 12 ascertain [1] 108:4 aside [2] 161:2; 199:17 asking [21] 15:20; 16:11; 18:11; 52:8; 54:6; 55:5, 15; 60:11; 64:14; 72:11; 80:15; 100:8; 10120; 102:11; 114:8; 135:12; From 1 to asking HARTOLDMON0009820 BSA 142:18; 145:3; 197:3; 212:13; 246:3 aspect [1] 122:8 aspects [1] 120:17 assessing [1] 196:19 Assessment [1] 224:6 assessment [4] 225:6; 227* 246:9, 11 assigned [2] 134:5; 179*) assignment [5] 68:16; 101:6; 148*); 180:1; 221:12 assignments [6] 36:10; 64:11, 17; 119:14; 220:12 assistant [10] 13:5; 14:7, 11; 19:11; 23:12; 3822; 39:8; 40:19; 92:11; 198-5 Associate [1] 29:4 associate [13] 212; 29:8; 34:12, 21; 36:3, 9, 22; 43:11; 442; 47:6; 60:14; 88:13; 220:10 associated [1] 21:4 Associates [1] 215:5 Association [12] 37:8; 65:8, 15; 67:8; 148:7, 14 162:10; 24322; 244:3; 2452, 14, 19 assume [1] 242:4 Assuming [1] 231:11 assured [2] 155:15; 238:3 attach [1] 60:3 attached [8] 46:12; 137:3; 138:6; 157:14, 21; 15822; 1602; 251:9 attachment [1] 167:12 attack [1] 24:13 attended [1] 69:7 attention [3] 78:5; 1872; 193:14 attorney [6] 6:11; 8:13, 15, 17; 92; 252:13 attuned [1] 21121 audits [1] 233:19 August [1] 224:4 august [1] 66:13 Australia [1] 7322 author [1] 160:15 auto [1] 190:17 available [2] 18:18; 183:5 avoid [3] 83:11, 16; 84:11 avoidance [1] 84:1 avoided [1] 8322 awarded [1] 1022 awards [1] 14:15 aware [5] 163:7; 198:4; 20021; 212:1; 214:18 awareness [3] 28:7; 44:13; 2032 -B - bachelor [4] 10:3, 8, 14, 19 Backfill [1] 231:6 background [4] 9:13; 19:6; 55:5; 195:17 backup [1] 1802 balance [1] 211:19 base [1] 236:15 Based [2] 52:1, 8 based [5] 32:16; 55:15; 83:7; 114:18; 228:8 basic [1] 164:18 basically [3] 44:15; 10622; 241:5 basis [3] 35:5; 5722; 107:6 bat [2] 180:15 Depo of George Roush, IR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 _____________Look-See(42) Bates [1] 1372 batter [1] 180:14 Beach [5] 104:16, 17, 18, 20, 22 bear [1] 522 Becker [1] 22220 becomes [4] 22:12; 117:12; 125:3; 1285 becoming [1] 18:16 begins [3] 1962; 208:12; 21421 behalf [4] 120; 2:7, 13; 164:10 behind [1] 180:14 belief [2] 130:14; 215:15 beUeve [7] 802; 84:19; 1402, 10; 16021; 178:9; 23122 belong [1] 244:4 bentonite [1] 2312 benzene [50] 482, 12; 495, 9, 11, 13, 21; 505; 515, 10, 11, 16, 18; 525, 10, 19; 53:1, 4, 10, 11, 22; 54:11, 14; 55:12; 56:1, 5, 20; 57:7, 21; 585,15, 16, 19; 59:6, 8; 602, 18, 20, 22; 61:6; 62:13, 16; 63:15, 16; 105:13; 107:10; 113:10, 15; 12721, 22 besides [7] 82, 12; 89:19; 106:6; 121:8; 16520; 203:19 Bethesda [1] 12:6 bigger [3] 126:18; 12722; 206:18 Biggerstaff [2] 13722; 138:1 biggest [2] 95:11; 187:6 biochemistry [2] 122; 31:15 Biodynamics [1] 235:13 Biohazards [8] 3020, 21; 31:1, 14; 32:12; 33:8; 1312, 8 biologic [1] 14:4 BioTest [5] 233:16; 234:3, 5, 7, 13 Bishop [3] 207:19; 208:4, 6 bit [8] 48:17; 8520; 8722; 88:12; 124:8; 13121; 136:1; 232:9 bits [1] 124:7 blade [1] 166:14 blocks [1] 91:12 blood [22] 50:9, 11, 12, 13, 14; 51:11; 56:4, 6, 9, 14; 58:8, 20, 21; 59* 74:11; 84:14; 85:3, 4, 17; 163:1 board [1] 211:10 bodies [1] 70:17 body [6] 69:9; 705; 73:1, 19; 7421; 86:10 boilers [1] 228:15 bone [2] 85:13, 14 Books [2] 7:10, 11 books [4] 7:10, 11, 22; 8:3 borrow [2] 231:5, 6 boss [9] 34:18; 89:17; 173:13, 22; 174:4; 190:12; 191:19; 220:11; 221:19 bothers [1] 143:1 bottle [1] 179:11 bounded [1] 22922 box [5] 2721, 22; 28:1, 2; 251:5 Bray [1] 25 breadth [1] 115:19 break [6] 64:1, 2; 125:5; 1735; 21922; 248:9 breaks [2] 62; 24:13 breathe [2] 7621; 129:18 breathed [1] 2722 breathing [6] 74:4; 77:6; 83:11, 16; 845, 11 brief [2] 1220; 13:7 bringing [1] 1872 Brio [9] 149:14, 21, 22; 150:3, 13; 152:7, 10, 20, 22 broad [11] 13:15; 31:13; 36:13; 42:15; 100:7; 126:19; 1295; 130:10; 144:11; 212:17; 213:6 broadened [1] 131:7 broader [4] 22:3; 32:9; 37:14; 127:15 broadly [1] 28:19 build [3] 91:16; 92:7; 104:11 building [4] 9120; 13020; 235:7, 10 built [8] 915; 92:4, 13, 19; 96:12; 146:19; 204:7; 220:7 bullet [2] 159:1; 245:3 bulletin [1] 211:10 burden [1] 235:4 burning [1] 129:4 business [7] 5920; 74:16; 132:19; 140:8; 148:12; 1842; 23822 businesses [1] 236:6 busy [1] 240:18 by-product [3] 802; 106:1; 146:3 by-products [3] 1752, 14, 21 -C- C-l-90-492 [1] 1:8 C-a-l-l-e-r-y [1] 205 C-o-l-e-m-a-n [1] 97:10 c.c. [1] 47:8 CA [1] 1:6 calculated [1] 144:8 calculus [1] 146:3 Caldwell [1] 191:6 call [18] 782; 84:14; 93:17; 115:7; 155:7; 171:17; 181:17; 185:10; 186:1; 18721; 1882, 4, 7; 189:8; 190:11; 191:18; 216:10; 220:15 Callery [4] 202, 4, 17; 23:14 Callis [1] 13722 calls [2] 15621; 213:6 Cancer [1] 12:6 cancer [29] 12:7; 31:17; 625, 9; 76:17, 19, 22; 782; 121:15, 17, 18; 1222; 124-3; 125:1; 127:8; 133:9; 1622; 163:1, 9, 14 1641, 6, 7, 22; 165:1, 14 169:12; 19922; 203:19 cancerous [1] 206:10 cancers [2] 2052, 3 candid [1] 217:5 candidates [1] 17522 cans [1] 86:14 Cap [1] 231:3 capabilities [1] 25:7 capsule [1] 28:13 car [2] 2720; 185:14 Carcinogen [1] 15921 carcinogen [9] 515; 52:4, 10; 76:14 13222; 1605; 161:7, 22; 205:19 carcinogenesis [1] 2043 carcinogenic [11] 2005, 19; 201:1, 16, 22; 202:15; 203:3; 205:13, 19; 206:3, 5 carcinogenicity [10] 6020, 21; 61:17, 20, 22; 62:17, 18; 165:19; 166:1; 205:10 carcinogens [2] 2012; 20321 cardiac [1] 2021 cardiology [2] 23:10, 17 care [4] 13:19; 25:17; 109:19; 218:13 career [7] 15:1, 21; 162, 15; 17:12, 22; 201:5 carefully [1] 83:5 carried [1] 128:3 carry [1] 109:8 cars [4] 7121; 73:7; 825, 17 case [8] 85:16; 144:1; 149:8; 155:3; 172:4; 185:7, 8; 18621 cases [1] 5421 CASTLE [1] 12 CASUALTY [1] 1:8 category [1] 186:3 catheterizations [1] 2021 caused [3] 80:18; 1243, 5 cease [1] 221:17 cell [2] 205:16; 206:7 cells [5] 20412, 22; 205:6, 21 centers [1] 194:1 central [1] 181:8 Certificate [1] 252:1 certify [1] 252:5 chain [3] 189:4 20; 217:15 chamber [1] 744 chance [4] 46:18; 137:15; 158:6; 194:12 change [8] 18:15; 96:7; 14621; 147:1; 183:3, 9; 20922; 219:13 changed [6] 15:13; 55:13; 180:5; 182:5; 220:11; 247:12 changes [3] 52:18; 178:7; 251:9 changing [2] 15:4 79:6 Chapman [2] 191:6, 9 characterize [4] 2520; 13520; 216:4; 219:7 charge [4] 35:11; 89:13; 160:14 2132 chart [4] 178:14, 15, 19; 1962 charts [3] 178:1; 179:1; 184:5 Check [1] 251:5 checklist [1] 160:5 Chemical [9] 20:2; 23:14 148:13; 149:16, 17; 162:9; 244:3; 245:18 chemical [43] 1421; 1522; 1621; 172, 7; 27:13; 39:10; 40:12; 49:15; 65:16; 9222; 93:1; 103:14 111:6; 120:17; 121:11; 12220; 1241, 5; 131:15; 13221; 13922; 142:15; 14417; 145:1, 5, 14, 19; 1462; 147:14, 22; 151:16; 161:13; 175:7; 209:7; 21021; 213:17; 217:19; 225:19; 226:4 239:17; 2503, 6 Chemicals [3] 136:8; 222:4 245:13 chemicals [58] 83; 20:3; 249; 41:10; 49:17, 18; 65:12, 14 8021; 91:18; 10222; 1032, 7, 12, 19, 20; 1072; 110:4 120:19, 20; 121:7; 122:15; 1232, 3, 11, 17; 126:11, 20; 127:18; 128:12, 16, 20; 129:16; 130:3, 15, 16; 134.-9; 135:6, 7, 13; 140:1; 1452; 149:3; 152:15; 175:14 197:13; 198:13; 200:6, 15; 2022; 206:6; 22521; 226:7, 15; 233:11; 236:4; 239:5 chemistry [6] 7120; 80:14 81:4 12220; 143:10; 225:17 Chemists [3] 148:6; 245:1, 7 chemotherapy [1] 12:7 chest [1] 24:13 Chief [1] 179:11 chief [2] 179:10; 220:15 Chloride [1] 169:10 chloride [15] 161:11, 21; 162:4 8, 12; 163:3, 8, 22; 164:12; 16620; 167:16; 16921, 22; 170:8, 21 chlorinated [3] 175:1, 14, 20 chlorine [1] 175:10 chronic [4] 85:16; 129:10, 13, 21 Cincinnati [5] 21:1, 4 13; 79:7; 162:13 circumstances [1] 230:6 City [33] 3520; 37:19; 43:9; 47:12, 15; 79:19; 80:8; 9520; 132:1; 133:11, 22; 13413; 135:1, 6, 13; 136:5, 8; 140:8, 9; 149:11; 153:4; 161:14 165:5; 2246, 22; 225:5; 227:1; 229:15, 18; 239:11, 12, 13; 240:14 city [2] 226:10, 14 claim [2] 189:1, 11 Clarence [2] 15421; 208:1 clarification [1] 142:13 clarify [2] 191:1; 219:12 day [1] 231:3 Clayton [1] 13722 clean [7] 44:9; 105:4 106:18; 111:17; 118:16, 18; 163:17 cleaned [1] 11820 cleaning [3] 105:15; 111:13; 166:8 cleanup [12] 16:4 443; 45:4 5; 106:14; 107:17; 108:8, 15; 1092; 110:17; 11722; 24820 cleanups [4] 44:10; 108:9; 109:5, 7 clear [13] 5:18; 8:9; 53:4 57:16; 70:14; 137:9; 17221; 19722; 213:12; 219:11; 233:5, 14; 235:17 clearing [1] 27:16 aspect to clearing HARTOLDMONOOQ9821 BSA closer [1] 154:13 clothing [1] 110:14 CMA [5] 148:17; 149* 241:9; 244:4, 13 Co [1] 2:14 Coleman [2] 97:10; 140:16 college [1] 9:13 Columbia [2] 252:3, 19 coming [1] 69:9 Commission [1] 252:20 commission [1] 251:19 commitment [1] 247:19 Committee [10] 30:20, 21; 31:1, 14; 33:8; 131* 8; 158:10, 11; 242:11 committee [12] 30:15, 19; 31:4, 10; 32:12; 64:17; 66:11; 158:14; 159:10; 177:19; 178:4; 179:2 committeeman [1] 212:6 committees [1] 64:10 common [6] 63*; 131:14; 147:21; 148:12; 162:7; 201:9 commonly [1] 223:3 communicate [8] 66:6; 108:18; 125:4; 210:17; 211:8, 14; 212*; 236:17 communicated [5] 213:20; 214:1, 2; 216:9; 217:3 communicating [7] 115:10; 210:9; 211:5; 217:7; 239*); 240:1, 5 communication [3] 208:16; 210:13; 218* communications [16] 208:14; 215:3, 5, 9; 216:3, 5, 13, 15, 16; 217:15; 218:11, 15; 233* 236:10, 13; 237:9 companies [20] 27:8, 13; 92*; 93:1; 131:19; 147:14, 22; 148* 8; 157:3; 190:6; 235:5; 237* 238:10, 11, 13, 15; oqo.o 7 o COMPANY [2] 1:3, 9 Company [11] 5:12; 20:2; 88:7; 89:10; 149:16; 222:4, 9; 242:16; 245:8; 246:2 company [19] 13:18; 29:5; 88:10; 91:11; 101:4; 115:7; 117:12; 122:20; 131:14; 149:6; 156:9, 18, 21; 174:15; 179:4; 215* 237:8; 240:4; 248:6 company-wide [1] 88:9 comparable [1] 7:13 compared [1] 116* comparison [1] 215:10 compensated [6] 32:19, 22; 33:14, 21; 34:8; 131:16 Compensation [1] 190:18 compensation [1] 34:3 competence [1] 83:12 compiling [1] 196:6 complaints [1] 25:16 complete [3] 196* 251:6, 11 completed [1] 171:10 complex [3] 55:3; 102:10; 135:11 compliance [2] 41:6; 160:6 Depo of George Roush, ]R., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 Look-See<43) complicated [11] 19*; 77* 118:6; 119:10; 124:16; 130:11; 141* 142:18; 158* 202:6; 206:17 complying [1] 41:3 component [2] 91:7; 133:13 compound [1] 22:12 compounds [6] 80*; 83:16; 176* 200:10; 205:7, 8 Conceivably [1] 110:18 conceivably [1] 110:19 concentrated [1] 129:11 concentrating [1] 98:18 concentration [1] 142* concern [28] 15:11; 26:3; 44:13; 48:1; 49*; 52:3, 10; 104:6; 106:6, 7, 9; 108:12; 113:17, 19; 139:13; 152:15; 175:4; 198:7; 208:19, 21; 209:10, 11, 14; 210:14; 213:14; 226:12; 240:11; 243:6 concerned [7] 52:6; 98*; 103:7, 13; 104*; 105:17; 126:10 Concerning [1] 215:7 concerning [1] 215:6 concerns [5] 24:6; 26:18; 32:8; 104:8; 211* conciliate [1] 212:18 conclude [1] 70:15 concluded [2] 6:12; 250:15 conclusion [6] 53:8, 10; 54:7, 9; 70:10; 151:5 conclusions [4] 53*; 55:15; 194:13; 215:14 Concrete [1] 231:7 condition [2] 154:17; 193:17 conduct [1] 146* conduit [1] 231:4 Conference [1] 66:2 confine [1] 14:19 confirmatory [1] 164* confused [1] 117:15 conjunction [1] 237:3 connection [1] 218:11 cons [1] 144:15 consciousness [1] 15:17 consequence [2] 69:17; 191:15 consequences [1] 74:19 conservation [1] 84:19 consider [4] 133:1, 6, 10; 142:13 considered [3] 128*; 133:3; 145:10 consisted [1] 12* consistency [2] 233:7; 235:18 consistent [2] 98:15; 160:5 consists [2] 13:8; 24:5 construction [2] 17:1; 249:11 consultant [2] 20:6, 10 consultants [1] 131:12 consulting [1] 30:7 contact [7] 9:10; 36:6; 39:6; 101* 140:18; 190:19, 21 contacted [2] 154* 155:2 contacts [1] 103:1 contained [1] 82* container [1] 27* containers [1] 86:19 contaminant [1] 112:17 contamination [9] 15:11; 110:16; 112* 116:4; 118:8; 142:19; 230:13; 246:8; 249* contents [1] 194:15 context [4] 44:18; 59:6, 19; 2135 continual [2] 122:6; .146* continue [11] 32:19; 55*; 79:13; 90* 5, 11; 182:10, 12; 246:6, 13, 22 continued [4] 1*; 55:14, 16; 147:3 continues [1] 208:15 contract [6] 305; 32:15, 16, 20; 33:7; 92* contracts [1] 155* control [7] 155; 825; 1015; 113:16; 1225; 233:15; 247:19 controlled [1] 176:10 conversations [1] 216:19 convey [1] 189:17 convince [1] 1085 convinced [2] 73:11; 233:8 coordinate [1] 246* copied [6] 138:15; 171:6; 175:1; 192:4, 16; 247:8 copies [1] 1715 copy [8] 46:10, 12; 137:12; 174:18; 224:10, 13; 241:19; 242:3 copying [2] 168* 169:1 comer [1] 2325 Corporate [8] 177:13, 17, * 1815, 14; 1825; 246*; 247:4 corporate [12] 120:14; 121:12; 122:13; 123:1, 8; 181:8, 11; 212* 21; 214*; 218:4; 236:12 Corporate-wide [1] 193:16 corporate-wide [1] 181:10 Corporation [3] 225, 12; 68:7 corrected [1] 137:14 correspondence [1] 156* cost [1] 63:6 cottage [1] 59* COUNSEL [1] 5:7 counsel [5] 1:17; 5:4; 145:17; 252:10, 14 count [3] 50:13; 58*, 21 country [2] 35:13; 149:10 counts [9] 50:9, 12, 14; 56:6, 9, 14; 58:8; 59:8 COUNTY [1] 15 couple [4] 7:10; 139:4; 158:3; 234* course [9] 14:18; 16:11; 19:17; 64:15; 106:16; 121:17; 128:8; 139* 247:13 courses [2] 16:3; 18:10 COURT [1] 1:1 Court [1] 1* court [2] 5:19; 6:7 cover [3] 137*; 157:13, 16 coverage [3] 156:15; 157:4; 189:1 covered [2] 179:16; 188:14 covers [4] 13:14; 60:13, 15; 1495 CRAIG [2] 1:19; 252:4 Crazy [1] 121:14 created [1] 146:4 credit [1] 171:8 critical [1] 233:3 cross-checks [1] 58:16 Crosson [6] 207:12; 214:15, 16, 19; 216:13; 219* crucial [2] 122:14; 123:10 Crummrich [1] 212:6 culvert [1] 231:4 Current [1] 227:7 current [1] 246:7 currently [1] 20:8 customers [1] 149:7 cut [3] 164:17; 204:10, 19 - D- D.C. [2] 2:6, 12 Daily [2] 33* 36:6 daily [1] 33:12 dangerous [1] 127:18 dangers [1] 108:14 data [6] 121:1, 6, 9; 149:3; 236:5, 15 Date [1] 251:13 date [4] 49:18; 1785, 10; 184:16 dated [8] 139:19; 1585; 177:12; 178:14, 22; 192:5; 231* 243:1 Day [1] 335 day [7] 27:7; 33:11, 17; 77:3; 114:14; 251:16; 252:16 days [1] 33:13 Dayton [7] 59:7; 615; 82:4; 183:12,18, 19, 21 deal [7] 40:1; 102:5; 104:13; 215* *6:4; 249:17, 20 dealing [1] 219:4 dealt [1] 97:14 Decatur [1] 133:8 December [1] 193:18 decide [11] 13* 24*; 30:12; 52*; 59:11; 124:5; 189:1; 211*; 225* *6:2; 228:5 decided [4] 109:11; 185*; 186:4, 15 deciding [6] 49:7; 109:8, 16; 121:5; 146:1; *9:3 deciduous [1] 79:8 decision [10] 75:1, 2, 4, 6; 77:16; 144:14; 145:4; 146:17; 185:12; 228* Decisions [1] 196:1 decisions [5] 1*:13; 143:18; *9:1; *2* 236:7 decrease [2] 85:5, 18 deemed [1] 186:18 Defendant [1] 2:13 DEFENDANTS [1] 5:7 Defendants [3] 1:11; 5:4; 53:16 define [3] 1**; 183* 195:1 defines [1] 180:18 defining [3] 175:3; 180:17; 183:10 definition [7] 129:5, 14; 131:6; 160:13; 225*; 226:8; 227:14 degree [4] 10:3, 9, 14; 815 DELAWARE [1] 1:1 Delaware [2] 1:15; 6:9 demand [1] 233:11 demanding [1] 28:6 demands [4] 207:6; 212:16; *951, * DEO [3] 158:10, 11; 236:* Department [106] 21:7; 39:5; 41:18; 42:13; 61:16, 19; 80:8; 91:8; 92:17; 93:6, 10; 945, 6, 13, 21; 95:3; 965; 97:19, 21; 98:4, 10, 17, 21; 99*. 21; 100:10, *; 10151; 102:1, 12; 105:16; 1065, 9, 13, *; 107:16, 18; 108:8, 15; 109:3, 8, 18; 110:6, 15; 112:4; 113:3; 115*; 1165, 16; 1175, 4, 6, 7; 120:7; 122:*, *; 1*:7; 124:13; 126:8, 10; *7:16; 141:4, 21; 1425; 143:11; 1445; 145:8; 146:4; 156:3, 6, 12; 171:11; 172:9; 180:6; 182:16, 17; 183:4, 8, 15; 1855; 1875, 18; 188:3, 5, 7, 12; 18950; 190:1, 3; 1945; 1965; 201:14, 17; 206:11; 209:13; 214:7; 215:16; 226:12; 257:19; 229:4; *1:12; *652; 245:10; 247:14; 248:4, 5 department [20] 60:19; 9052; 91:3; 99:14; 102:18; 111:8; 116* 1** *0:8; *151; *4:19; 2*5; *0:3, 18; 244:10, 12, 14; 24552; 246:10, 17 departments [1] 146:1 depend [2] 185:19, 20 dependent [1] 235:5 Depends [3] 84:9; 96:3; 185:10 depends [12] 33:17; 54:12; 7452; 84:7; 105:11; 121* 127:3; 145:1, 14; 148:5; 21751; 227:13 DEPONENT [1] *1:1 deposed [2] 5:15; 6:15 DEPOSITION [2] 1:13; 3:7 Deposition [14] 1:16; 46:4; 136:14; 157:8; 167:8; 173:7; 176:17, 21; 184:6; 19151; 20652; 2*:11; *1:17; 240* deposition [20] 6:11; 7:5, 9; 8:8, 16; 33:1, 19; 34:1, 5, 11; 46* 55:8; 60:13; 1*:6; 149*; *0:15; *1:4; *25, 7, 12 depositions [3] 7:1; 33:6, 15 described [5] 113:3; 130:4; 16550; 169:12; 241:6 describes [1] 158:18 design [1] 28:12 despite [1] 6:7 detailed [2] 29:15; 137:* detect [1] 71:1 detecting [2] 16:9, 17 From closer to detecting HARTOLDMONOOQ9822 BSA detection [1] 250:6 determination [7] 61:15; 7420; 1112; 151:12, 15; 215:17; 2432 determinations [1] 188:16 determine [5] 49:10; 58:8; 86:17; 95:7; 233:10 determining [4] 69:15; 110:16; 175:13; 189:10 develop [9] 122:18; 248:19; 2492, 13, 16, 19; 2502, 5, 8 developed [2] 163:3; 195:8 developing [4] 121:15, 17; 130:19; 181:8 Development [1] 24321 development [1] 246:14 device [1] 110:12 dictate [1] 95:3 die [1] 121:18 died [2] 82:12; 140:11 differ [1] 49:3 difference [9] 50:15; 71:1; 72:18; 73:5, 12; 77:17; 116:6; 14220; 166:16 differently [1] 237:16 differing [1] 215:11 difficult [2] 521; 362 dimension [1] 146:14 dioxin [17] 104:1, 7, 15, 19; 105:11, 15, 17, 19, 21; 106:14, 19; 108:9; 109:4, 5, 7; 116:1; 185:14 direct [13] 34:18; 89:17; 11221; 137:19; 147:17; 17722; 192:8; 193:9; 215:10; 227:6; 230:16; 232:4, 19 directed [4] 36:8; 117:17; 133:15; 177:5 directing [1] 13022 direction [4] 180:18. 19; 20221:252:10 director [64] 20:7, 9, 10, 17; 22:9; 23:14; 29:4, 8, 10, 11; 31:9, 21; 34:13, 21; 36:4, 9, 19, 22; 37:7; 39:1, 9; 4020; 43:12; 442; 47:6; 58:18; 60:14; 64:18; 65:2, 20; 79:12, 15; 8122; 88:5, 10, 14, 16; 89:4; 90:3, 15, 21; 91:6; 922, 11; 97:1, 6, 22; 99:14; 111:5; 119:18; 120:13; 126:8, 9; 144:8; 147:13; 152:6; 156:11; 161:17; 182:10, 18; 198:5; 234:1 Directors [1] 66:5 directors [1] 88:13 disagree [1] 53:16 disagreed [1] 193:7 discharge [3] 144:17; 145:18, 19 disclosure [2] 217:5; 219:8 disconnect [1] 204:7 discuss [2] 8:11; 22722 discussed [5] 332; 51:1; 149:13; 1912; 2442 discusses [1] 175:1 discussing [1] 6:10 Discussion [1] 1212 discussion [10] 72, 6; 24:16; 50:19; 56:17; 87:4; 130:9; 153:18; 1642; 242:8 Depo of George Ronah, IR,, M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0_____________ Look-See(44) discussions [1] 218:10 disease [1] 169:15 Disposal [1] 227:7 disposal [23] 1421; 1522; 16:19, 20, 21; 172; 39:10; 40:12; 111:7; 142:15; 143:4, 7, 14, 15, 17; 19320; 1945; 196:3, 6; 227:11; 249:14 dispose [1] 143:19 disposed [1] 1445 disseminate [2] 66:16; 209:19 disseminating [1] 65:16 distinction [1] 60:10 distinguishing [1] 14520 distributed [1] 168:17 District [2] 252:3, 19 Ditch [5] 229:12, 14, 17, 19* 230:4 ditch [9] 150:10; 15122; 152:1, 4, 5; 229:19, 21; 231:5, 6 divided [3] 35:16; 222:11, 14 Division [1] 222:1 Dixie [1] 149:18 DMHH [10] 18221; 1835; 185:6; 236:4, 10, 17; 237:18; 238:14; 239:3; 240:7 Doctor [1] 212:12 . doctor [4] 13:11; 89:15; 163:13: 183:16 Document [1] 160:4 document [24] 8:4; 462, 16; 13621; 157:18; 158:1; 167:7, 14; 172:3; 173:12; 177:7; 184:10; 192:10, 20; 207:11; 223:17; 227:7; 23020; 231:15, 16; 2325, 7; 241:8; 2432 documents [11] 5:15; 7:4, 8; 8:7, 8; 20:16; 67:14; 172:5; 178:6; 199:10; 2072 doesn't [21] 70:12, 20; 75:1; 99:18; 102:17; 10721; 108:17; 111:8; 114:14; 123:14; 124:6; 12622; 127:10, 11, 14; 1602; 168:12, 13; 225:7; 246:1 dollars [2] 33:13; 63:6 domain [3] 109:18; 1105; 220:7 Donnenfeld [l] 25 dosage [1] 130:9 dose [9] 6122; 63:9, 10; 7822; 79:1; 84:8, 9; 10922; 110:4 Dr [55] 5:9; 9:11; 34:14, 16; 35:15; 36:4; 37:1; 38:4, 10, 19; 39:7; 46:7; 47:8; 81:7, 21; 8220; 832, 3; 85:6; 88:13; 90:16, 19; 96:19, 20; 97:10; 126:6; 136:17; 137:1, 2; 140:6, 10, 12, 15, 18; 141:10; 142:4, 11; 154:19; 157:12; 15921; 167:11; 173:10; 176:12; 177:1; 184:8; 1922; 199:16, 20; 223:14; 23120; 233:8; 241:3; 248:15 drain [1] 231:1 draw [1] 215:14 drawing [1] 60:10 drinking [3] 87:8, 13, 14 dropped [1] 235:12 dry [1] 1525 Duane [1] 1:18 due [3] 495; 196:3; 215:11 duly [2] 55; 252:7 dump [1] 145:13 Dupont [2] 142; 75:4 duties [2] 3421; 102:12 -E- earliest [2] 2622; 525 Early [1] 132:15 early [15] 575; 59:10; 132:15; 13920; 193:10; 19620, 21; 20020; 201:5, 7; 227:4; 233:5, 17; 235:16 earthen [1] 22921 easier [4] 19:3, 21; 151:17; 2382 east [1] 22921 easy [1] 233:3 ECC [1] 242:10 education [9] 9:14; 14:14, 19, 20; 16:14; 17:11, 22; 22:7; 248:16 educational [1] 9:12 effect [25] 14:4; 20:3; 2521; 26:12, 19; 49:18; 53:4; 59:14, 15; 70:3; 7222; 77:14, 20; 78:1, 2, 15; 99:8; 127:12; 1302, 6; 168:7; 19720, 21; 217:18; 2352 effectiveness [1] 246:15 effects [18] 70:1; 72:6, 17, 20, 21; 77:5, 7, 9; 106:10; 122:14; 123:10; 129:10, 12, 16; 166:19; 2065; 213:16; 233:10 effluent [1] 10021 effluents [1] 100:14 effort [6] 44:8; 159:19; 212:17, 20; 218:4; 236:12 efforts [4] 86:17; 2155; 2335:24622 Elmer [6] 37:4, 6; 38:4, 14; 115:17; 160:15 embankment [1] 226:11 embarkment [1] 226:11 emergencies [3] 18421; 185:4; 1902 Emergency [1]-184:15 emergency [6] 186:17; 187:3, 19; 188:9, 13; 189:9 Emmett [3] 34:14, 15; 4522 emphasis [1] 235:7 employed [2] 252:11, 14 employee [8] 138:1; 208:13; 2122, 4, 5; 216:4; 218:3; 252:13 employees [15] 35:7; 106:8; 208:16; 209:3; 21120; 213:8, 13; 2152; 2165; 217:3, 17; 218:5, 13, 19, 21 enable [1] 58:8 encompass [3] 13:13; 25:12; 129:13 encourage [1] 170:14 end [2] 4621; 206:6 ends [1] 212:16 energy [1] 84:19 enlarged [1] 147:8 enlargement [1] 170:4 ensure [1] 53:7 entity [1] 75:6 entrusted [1] 245 environment [12] 720; 155; 2521; 2620, 21; 44:14; 144:18; 145:6; 181:12; 18222; 198:8, 9 Environmental [14] 177:13, 17, 20; 1815, 15; 1825, 17; 183:6; 218:7, 12; 23121; 24321; 24621; 247:4 environmental [44] 15:17; 165, 6, 10, 17; 2122; 25:10; 26:12, 19; 27:1; 325; 43:19; 445; 45:4; 492; 74:15; 78:13; 9922; 100:11; 1012, 3, 10, 21; 10220; 107:17; 108:8, 15; 116:3; 120:15; 121:13, 19; 122:13; 123:1, 8, 21; 160:7; 18221; 186:16; 215:1; 216:12; 246:7; 24820 environmentalist [1] 47:14 EPA [18] 425; 75:11; 99:15; 101:5, 10; 102:3, 4, 14, 20; 104:16; 10821; 122:7; 234:6, 10, 15, 20; 240:10 epidemiologist [3] 9020; 945; 122:1......... epidemiology [2] 97:12; 124:4 episode [2] 40:17; 59:6 equivalent [3] 4220; 102.14; 162:11 Errata [1] 251:10 error [1] 215:11 ESQ [2] 22, 9 essence [1] 234:14 establish [4] 755; 1315; 193:18; 2365 established [3] 85; 61:10;23621 establishing [3] 108:13; 2332; 237:11 estimate [2] 6:17; 822 estuary [2] 2305, 6 et [1] 15 Ethyl [11] 22:9, 11; 67:16, 21; 68:1, 7, 9, 19, 22; 74:12; 75:1 ethyl [2] 2221; 2720 Ethylene [4] 7921, 22; 80:7 ethylene [2] 79:19; 81:1 evaluate [3] 146:10; 165:4; 197:1 evaluation [3] 170:3; 171:12; 19821 eventually [1] 56:19 everybody [2] 122:16; 161:8 Exactly [1] 157:19 exactly [1] 160:18 EXAMINATION [2] 32; 5:7 examination [12] 1:17; 5:4; 35:6; 57:6, 20; 58:1; 1522; 167:16; 169:18; 1702, 6 examinations [7] 35:4, 5; 94:8, 18; 95:19; 151:9; 170:1 examine [1] 15222 examined [4] 5:6; 152:1; 16621; 251:3 examines [14] 46:16; 13621; 158:1; 167:14; 173:12; 177:7; 178:6; 184:10; 192:10; 2072, 11; 223:17; 232:7; 241:8 examining [1] 1672 example [6] 45:19; 104:15; 109:4; 119:10; 132:18; 233:1 examples [2] 64:10 exams [3] 97:15; 167:4; 170:18 except [1] 2515 exceptional [1] 14821 excess [2] 505; 58:9 exchange [1] 147:14 excited [1] 141:6 excretion [1] 49:4 executive [1] 179:4 exhaust [2] 2720; 73:8 Exhibit [73] 3:9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19; 42, 3, 4, 5; 46:3, 4, 7, 18; 6322; 136:14, 17; 137:14; 157:7, 8, 11; 158:6; 167:8, 11; 168:14; 1732, 7, 10, 19; 176:16, 17; 1772, 6, 9; 178:9, 10, 14, 15, 19, 22; 179:8; 180:19; 181:1; 182:8; 183:11; 184:6, 9, 12; 19120, 21; 192:3, 13; 207:16; 211:18; 214:14; 216:14; 218:6; 223:11, 14, 15, 20; 231:16, 17, 20; 232:17; 24022; 241:3, 12 exhibit [10] 46:9; 142:10; 161:1, 4; 184:4; 190:15; 199:16; 223:10; 24020, 21 Exhibits [5] 17621; 17722; 20622; 21620; 21822 exhibits [2] 20621; 21921 exist [1] 236:13 existence [1] 78:16 existing [1] 19421 expectation [2] 15:4; 18:12 expectations [1] 15:13 expected [3] 42:9; 186:21; 19522 expects [1] 13:11 experience [2] 52:9; 131:15 Experimental [1] 147:20 experimental [3] 201:19, 20; 2042 expert [5] 622; 7:3; 143:6, 13; 204:3 expertise [25] 64:11; 79:14; 80:17; 112:4; 114:4; 116:7, 17, 22; 117:10, 20; 142:14, 16; 143:12; 147:5; 152:18; 247:1; 248:19; 249:3, 13, 16, 19; 2502, 5, 8 experts [2] 212:18; 240:3 Expires [1] 25220 expires [1] 251:19 explain [2] 50:14; 65:12 explanation [1] 2122 explanations [1] 53:18 Exposed [1] 169:9 exposed [23] 41:9, 16; 49:17; 57:7, 21; 58:4; 62:13; 84:13; 85:9, 13, 21; 86:3; 99:5; 106:19, 20; 110:5; 127:17; 128:5, 18; 164:12; 169:21, 22; 212:5 detection to exposed HARTOLDMONOOQ9823 BSA poisoning [2] 40:17; 59:6 policies [2] 181:9; 189:11 Policy [14] 15921; 177:13, 17, 20; 181-3, 15; 182:4; 183:7; 218:7, 12; 243:13, 17; 24621; 247:4 policy [16] 95:7; 120:15; 121:13; 122:13; 123:1, 8, 21; 160:9, 12; 161:7; 212:22; 219:13; 246:14, 16 polluted [1] 26:9 pollution [41] 15:7, 9; 16:4, 7, 10, 17; 17:13, 16; 26:4, 19; 27:1, 13; 4021; 43:13, 18, 19; 44:3; 45:4; 102:9; 112:3; 115:15; 116:15; 117:1, 21; 119:3, 20; 120:6; 142:15; 144:9, 15, 16; 145:9, 11, 17, 19, 20; 24820; 249:17, 20; 2502 Polynuclear [1] 204:18 polynudear [12] 19920; 202:9, 12, 18; 2032, 7, 14; 204:9; 205:1, 7, 10, 15 pond [1] 2312 population [3] 54:14; 62:8, 11 pose [1] 2220 Position [1] 241:15 position [14] 19:19; 29:3, 7; 36:19; 4020; 883; 89:8; 91:1; 1162; 126:8; 174:13; 182:5; 210:19; 242:16 positions [1] 29:16 positive [1] 21422 post-graduate [1] 14:14 pot [3] 80:3, 10, 18 potential [1] 193:19 potentially [1] 194:14 pound [3] 27:6, 16 ppm [6] 59:14; 60:3; 62:6; 63:10, 11 PR [3] 217:14, 19; 219:3 practical [3] 322; 75:16; 124:18 Practically [6] 79:16; 113:4; 114:7; 120:4; 146:7; 23522 practically [4] 87:15; 110:8, 18; 11520 practice [2] 25:17; 66:12 Practices [1] 23122 practices [1] 152:12 precursors [1] 12722 prefers [1] 212:16 prep [1] 34:8 preparation [3] 7:4, 9; 8:8 prepare [1] 13:9 prepared [3] 1322; 47:1; 233:18 preparing [3] 8:15; 3322; 169:4 presence [1] 107:5 present [6] 120; 39:19; 158:14; 159:9; 193:19; 233:19 presentation [4] 15822; 159:3, 15; 23122 president [6] 37:7; 89:9, 10, 11, 13; 221:8 pressures [1] 181:10 pretty [1] 118:5 prevent [1] 23320 prevention [2] 16:7; 250:3 Depo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 Look-See{49) Preventive [1] 21:7 preventive [1] 21:12 previously [3] 152; 33:15; 21021 primarily [3] 9822; 146:13; 1632 primary [4] 116:17; 227:12; 228:12, 13 print [1] 25Z-9 prior [3] 522; 91:19; 110:17 priorities [4] 236:7, 21; 237:4, 19 private [1] 25:17 probability [1] 228:8 problem [29] 63:13; 77:7; 78:14; 100:19; 105:17, 19; 108:3, 5; 111:13; 116:3, 4; 121:19; 12322; 124:1, 3; 133:6, 10; 134:1; 139:13; 141:8; 210:8; 214:9; 215:9; 2162; 225:10; 226:19; 228:1; 240:14 problems [7] 11520; 132:17; 133:4; 148:11; 162:7, 17; 193:19 procedure [4] 5720; 164:14; 169:10; 172:17 procedures [4] 52:18; 57:6; 187:19; 188:9 process [4] 7920; 106:3; 136:7; 1462 processes [1] 135:13 produce [7] 49:8; 77:14, 19, 22; 127:12; 129:16; 130:1 produces [1] 7622 producing [1] 169:12 product [5] 12621; 133:13; 14220; 156:10; 194:1 production [1] 160:3 products [6] 14:4; 27:5; 126:14, 16; 136:4; 175:4 professional [1] 65:6 professor [10] 13:5; 14:8, 11; 19:11; 212, 21; 22:11; 23:13; 31:15, 16 program [12] 35:4, 11; 58:19; 1492; 164:11; 167:16; 222:10; 233:6, 21; 235:17; 246:9, 11 programs [3] 19421; 195:1, 8 progressed [1] 9:14 prohibits [1] 6:10 project [2] 6822; 72:6 projects [10] 36:10; 43:12; 68:11; 73:19; 79:14; 111:6; 14822; 182:1; 197:6; 198:12 proper [3] 17521, 22; 212:19 properties [2] 17:19; 4921 Property [1] 186:3 property [3] 22922; 231:7, 10 pros [1] 144:15 protect [7] 110:10, 11, 14; 113:15; 124:11; 172:4; 246:6 protected [1] 17121 Protection [2] 186:3; 226:7 protection [1] 226:6 PROTECTIVE [1] 1:1 protective [1] 172:4 prove -[2] 74:16; 107:11 proved [2] 2332, 3 provide [8] 121:8; 123:12; 141:16; 1802; 181:11; 194:18; 206:11; 23820 provided [2] 123:9; 155:18 providing [5] 122:13; 123:1; 124:14; 146:16; 198:16 Public [3] 5-3; 215:16; 252:18 public [20] 11:11, 14; 13:11; 14:17; 15:4; 18:9, 15; 21:10; 2220; 39:17; 76:16; 163:10; 181:10; 208:6; 209:1, 3; 214:17; 218:19; 2433; 251:18 pump [2] 76:4; 78:4 purchase [1] 15521 purchased [1] 15522 Purely [1] 192:18 purely [2] 81:18; 1163 purpose [5] 13321; 150:3, 20; 181:15; 193:18 purposes [1] 92 pursuant [1] 1:17 puts [1] 213:9 putting [4] 60:1; 1282, 4; 13021 -Q- quality [3] 233:7; 235:19; 243:6 qualms [1] 212:10 Quantifying [1] 1962 quantity [2] 127:12; 146:13 quarrel [8] 22:14; 57:16, 17; 61:6, 9; 71:15; 84:16; 238:1 question [74] 5:17; 1521; 16:6, 9, 16, 19; 17:1, 4, 6; 24:12, 14; 25:6; 26:8, 11; 27:10; 42:15; 44:6; 45:3; 48:16; 492Q; 51:1; 55:5; 58:17; 60:18; 64:12,13; 68:13, 14; 70:12, 13; 72:1, 3, 14; 732; 78:12; 8021; 83:13; 84:3, 20; 87:17; 96:3; 99:8; 101:19; 115:8; 117:3, 10, 16, 19; 118:19, 22; 128:14; 135:11; 142:19; 14322; 1442, 11; 145:3; 150:9; 15121; 154:16; 168:16; 175:11; 182:14; 190:16; 192:4; 19522; 199:15; 212:13; 219:11; 241:5; 248:18; 249:5, 7, 10 questionnaire [4] 167:12; 168:10, 11; 170:20 questionnaires [1] 171:10 questions [28] 6:13; 18:7; 29:15; 72:8; 101:12; 104:11; 112:5; 11422; li8:3, 4; 119:17; 120:5, 20; 126:7; 13720; 157:12; 168:6, 9; 177:5; 192:9; 232:6; 248:14; 250:11, 13, 14; 251:8, 12 quick [1] 5:16 quote [1] 85:6 - R- radioactive [2] 85.-12, 15 railroad [1] 185:14 Rammazini [2] 66:9, 20 range [1] 54:15 Rankey [3] 20720; 208:4, 10 rash [3] 210:6, 7, 21 Rasmussen [1] 191:7 rat [3] 145; 123:14; 1245 rate [4] 33:8, 10, 12, 14 rated [1] 215:6 rats [4] 2722; 282; 1245; 127.-9 reactor [1] 163:18 reactors [9] 162:18, 19; 163:19; 164:18; 1665, 9; 167:6; 169:16; 172:15 read [34] 46:15; 74:7; 117:16, 17; 133:15; 136:18; 137:8; 157:11, 13, 16; 1585; 167:13; 1682, 14; 173:11, 19; 177:1, 9; 181:6; 184:8, 12; 19220; 193:4, 13, 16; 207:14; 22320; 2325, 16; 233:13; 241:4, 7, 12; 251:3 reading [2] 169:8; 232:15 reads [2] 17022; 233:4 real [3] 632; 175:10; 176:8 realize [2] 395; 137:6 realized [1] 137:6 reason [10] 56:8; 90:9; 1275; 20821; 235:10; 24121; 2422, 4; 246:14 reasonable [1] 169:7 recall [98] 621; 82; 14:16; 16:15; 37:3; 40:12; 43:11; 47:13, 16; 48:1, 6; 49:10; 51:17; 54:7; 55:12, 15, 22; 575; 59:4; 60:19; 815, 9, 17; 82:19; 83:7; 9522; 99:13, 16, 17; 100:8; 102:16, 19; 103:1, 5, 16, 19; 114:11; 119:19; 121:13; 132:13; 13321; 136:6; 1385, 8; 139:12; 140:4; 141:10; 143:5; 144:7, 13; 145:4, 6; 151:8; 152:15; 153:18, 21; 154:1; 155:1; 15620; 16321; 16421; 165:18; 166:11; 16722; 168:16; 17120; 172:16; 17520; 176:3; 177:16, 19; 18421; 186:11; 187:4, 8, 15; 188:11; 1902, 22; 191:14; 19820; 2035; 208:16; 20921; 211:15; 214:17, 20; 216:18, 19; 218:10; 219:14; 222:6; 225:4; 22920; 237:7; 242:6, 21 receive [6] 16:3; 1722; 29:19; 652; 24122; 242:3 received [5] 174:18; 224:10; 241:19; 247:6; 248:16 receiving [2] 138:8; 224:13 recent [3] 81:14; 104:1; 215:4 Recess [4] 64:4; 173:5; 220:3; 248:12 recessed [1] 125:6 recipients [2] 224:7; 241:16 recognition [2] 29:9; 23922 recognized [2] 175:7; 238:19 recognizing [1] 118:1 recollection [23] 52:3; 55:7; 11428; 138:14; 141:20; 155:13; 158:17; 160:11; 169:6; 17420; 18122; 191:10; 192:15; 197:4; 20020; 203:1; 217:1, 7, 14; 224:12; 22622; 247:3, 5 recommendation [2] 219:8, 12 recommendations [2] 28:15; 2172 Recommended [2] 57:8, 10 recommended [3] 57:6, 11, 12 recommending [3] 207:4; 208:14, 17 record [9] 50:18; 53:17; 645; 110:3; 1212; 126:3; 137:8; 232:10; 242:7 recorded [2] 251:8, 12 records [1] 196:4 recurrence [1] 23320 Red [1] 212:4 redefining [1] 180:19 reduce [1] 6922 reduced [2] 70:4; 252:9 reducing [2] 70:4; 110:4 reduction [7] 17:13; 43:13, 18, 19; 78:16; 11920; 2503 Reese [4] 174:1, 6, 9, 11 reevaluate [1] 234:18 reevaluated [1] 235:4 refer [1] 25:18 referring [2] 1683; 235:19 refers [5] 183:12; 2162, 13; 218:6; 235:16 refinery [2] 2303, 10 reflected [1] 215:4 refresh [4] 159:5; 178:1, 3; 2475 refresher [1] 5:16 refreshes [1] 178:4 Regarding [2] 155:4, 5 regarding [3] 32:8; 155:3; 21620 regular [2] 5722; 148:20 regularly [1] 218:15 regulation [2] 167:19; 2433 regulations [3] 9822; 1813; 233:11 regulators [3] 10221; 103:8; 104:7 regulatory [11] 39:2; 412, 3; 42:12; 97:22; 98:5; 9922; 100:11; 101:11, 22; 23920 Rein [2] 2:10; 5:10 relate [3] 23:19; 155:11; 204:8 Related [1] 720 related [27] 720; 21:10; 22:3; 23:16; 48:11, 16; 49:5; 51:16; 54:17; 5520; 6122; 62:3; 7822; 79:1; 83:18; 10820; 117:22; 120:5; 14122; 1503; 153:10; 168:7; 183:6; 193:19; 198:12; 243:9; 252:10 relates [2] 22:10; 23:21 relating [3] 43:15; 100:6, 9 relation [1] 39:17 Relations [1] 215:16 relations [7] 208:6; From poisoning to relations HARTOLDMONOOQ9824 BSA 2092, 3; 214:17; 218:3, 5, 19 relationship [6] 42:4; 63:9; 95:1; 147:4; 174:6, 9 relative [2] 66:22; 252:13 Relatively [1] 165:3 relatively [6] 1652, 12, 16; 166:7; 172:15; 201:4 release [1] 145:5 releases [2] 250:3, 6 relevant [2] 105:15; 236:5 rely [1] 143:13 remain [4] 19:19; 32:12; 22121; 236:15 remainder [1] 13620 remember [35] 25:1; 26:14; 529; 59:3; 68:15; 83:8; 96:16; 97:19; 104:16; 138:3; 14822; 154:19; 155:8; 158:11; 159:3; 160:9, 20; 166:18; 169:4; 172:8; 177:12; 179:1, 17; 180:4; 187:7; 196:15; 197:10; 198:15; 202:4; 2133; 219:15; 220:16; 224:15; 242:10, 15 reminder [1] 6:9 Remining [1] 149:17 removal [1] 109:17 removed [1] 60:6 render [1] 234:14 reorganization [1] 96:6 rephrase [6] 5:18; 51:3; 70:14; 98:19; 133:1; 14521 replace [1] 90:8 replaced [2] 8022; 221:3 report [8] 89:4, 19; 140:12; 144:4; 174:11; 18021; 18212 220:13 reported [15] 425, 6; 8822 89:5; 96:22; 972, 6; 114:9; 115:1; 116:12; 119:6; 174:16; 179:13; 224:19 Reporter [2] 120; 252:1 reporter [3] 5:19; 117:17; 133:15 Reporting [1] 184:16 reporting [6] 402; 179:15; 180:10; 220:18; 221:1, 4 reports [3] 94:12; 210:11; 236:19 represent [1] 5:11 represented [1] 20922 representing [1] 117:7 request [2] 239:5, 17 requested [4] 194:18; 206:13; 22720, 21 requests [1] 237:1 require [1] 46:8 required [4] 28:16; 151:9; 229:9; 234:18 requirement [3] 41:17; 56:4; 188:6 requirements [3] 13:10; 28:13; 240:10 requires [1] 15:5 research [8] 77:11; 81:17; 83:9; 86:7; 89:11; 152:12; 194:1; 215:12 residency [1] 1222 resident [1] 247:1 resource [3] 148:12; 180:17; 181:8 resources [1] 229:5 Depo of George Roush, JR M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 Look-See(50) respect [3311&9; 17:4, 6, 18; 18:1; 25:10; 26:18; 412; 442; 45:4; 51:17; 52:19; 73:18; 10021; 1092; 137:14; 141:11; 143:14; 159:6; 160:6; 188:13; 196:12; 197:12; 2252; 246:18; 2492, 7, 10, 14, 17, 20; 250:6, 9 respective [1] 121 respirators [2] 124:11; 128:4 respiratory [2] 110:12; 113:14 respond [3] 144:1; 175:6; 176:6 responding [1] 246:8 response [4] 1722; 1762; 20520; 228:1 responses [1] 215:12 responsibilities [8] 45:12; 64:8; 1142; 179:18, 19; 1802; 181:13; 1832 Responsibility [2] 4121; 13320 responsibility [47] 22:19; 35:16, 22; 36:11; 4122; 42:14; 69:19; 88:19; 89:1; 94:11; 96:11, 15; 109:14; 11221; 113:19; 115:18; 116:8, 13; 141:13; 143:15; 1562, 5; 159:17; 175:18; 18221; 183:9, 14; 187:17; 1882, 12, 22; 189:7, 10, 14; 1902, 7; 1932, 4; 209:13; 217:16; 221:18, 20; 222:1, 9; 2232; 22621; 228:17 responsible [12] 35:18, 20; 39:4; 88:6, 15, 16; 97:7, 16; 119:11; 157:3; 221:13; 232:10 rest [10] 35:13; 77:3; 91:11; 95:18; 117:12; 136:19; 155:15; 190:9; 2322; 233:13 rested [2] 189:14; 229:1 restricting [1] 215:8 result [4] 52:17; 62:17; 1062; 169:11 results [6] 47:17; 94:14; 12421; 214:18; 2362, 19 resume [1] 125:7 retire [1] 302 retired [12] 29:16; 30:3; 31:11; 32:17; 4522; 8921, 22; 90:6, 9; 96:17; 115:18; 161:6 retiring [1] 312 returned [1] 171:12 revamp [1] 23321 revealed [1] 53:4 Review [1] 81:6 review [8] 7:4, 8; 8:7; 81:10, 15, 18, 2ft 235:1 reviewed [3] 7:6; 8:3; 215:13 rewritten [1] 234:19 rid [6] 27:5, 14; 8422; 85:8; 175:8, 12 Right [58] 12:14; 15:15, 2ft 17:9; 18:13, 17; 20:14; 22:16; 24:18; 31:12; 36:14; 40:19; 42:17, 22; 44:10; 45:17; 50:7, 1ft 52:8; 5320; 6220; 69:5; 78:9, 15; 80:15; 842; 93:9; 107:3; 108:1; 1102; 111:10, 22; 115:1, 12; 117:15; 1272, 4; 1292; 130:8; 131:18; 1402; 143:3; 154:12; 158:4; 1672; 178:18; 1822, 6, 8, 9; 205:17; 214:11; 217:6; 219:6; 22421; 226:8; 2302; 248:1 right [199] 7:17, 19; 92, 18, 21; 10:5; 11:10, 12, 19; 12:3, 5, 8, 11; 13:17; 20:16; 21:8, 11, 17, 20; 22:18; 23:1, 14; 2420; 25:8; 262; 282; 31:8; 32:1; 33:4, 7; 34:10, 14; 352, 14; 372, 11, 13, 17; 382, 6; 40:5, 9, 14; 4120; 42:1ft 43:1, 5; 44:5, 11; 4520; 48:7, 15, 18; 532, 5; 56:3; 57:15; 58:6, 12; 59:17; 61:3, 21; 622, 22; 63:4, 8; 65:19; 672, 16; 69:18; 722; 75:15; 7620; 7720; 78:8; 79:4; 812, 11; 82:3; 862, 6, 13; 89:12; 91:14, 22; 93:15; 94:4; 95:14; 97:15; 98:14; 99:6, 11; 102:8; 1042, 9, 14; 106:10; 107:4, 20; 108:6, 10; 109:13, 20; 110:7; 111:15, 16; 1122; 113:3, 12; 114:15; 1152, 5; 116:13; 1172; 118:11, 15; 119:9; 120:1, 10, 11, 18; 121:10; 123:17; 126:13; 128:7; 130:4, 20; 131:10, 11; 132:5; 133:4; 138:10; 1392, 10, 21; 142:17; 1432, 21; 147:19; 148:4; 15021; 156:8; 15720; 158:15; 159:8; 161:14, 22; 162:16; 164:16; 167:18; 168:11; 1692; 17021; 172:13; 17321; 177:3; 178:11, 18; 179:12; 18020; 182:14, 19; 183:1; 185:11, 14; 186:15, 18, 20; 187:10; 192:11; 193:8; 195:12, 13; 200:1, 17; 2082, 8; 210:18, 22; 211:6, 13; 218:9; 219:3; 220:8; 221:14; 224:1, 8; 225:1, 22; 227:9; 228:10; 230:5; 23221; 234:9, 21; 238:1; 241:17; 244:4; 246:1 rightly [1] 15:19 risk [1] 144:8 risks [2] 196:19; 236:3 River [2] 26:6; 27:7 river [5] 26:9; 27:4, 6, 15; 100:14 rivers [1] 27:9 roadway [1] 73:9 Robert [1] 34:14 role [13] 65:16; 66:16; 108:15; 1132; 120:7; 122:12; 123:7; 127:16; 136:10; 1433; 156:14; 178:5; 210:9 room [2] 83:18; 128:1 ROUSH [4] 1:13, 16; 3:7- 5.3 Roush [30] 3:3; 5:9; 9:11; 46:3, 7; 126:6; 136:17; 137:1, 22; 154:19; 157:12; 158:15; 167:11; 173:10; 177:1; 182:1ft 184:8; 1922; 199:16, 20; 208:14; 223:14; 224:6; 23120; 233:8; 2413, 16; 248:15; 2512 route [2] 189:16; 20320 routine [7] 51:15; 563; 167:1, 2; 170:7, 9, 10 routinely [2] 1343; 170:17 Roy [1] 212:4 rubber [3] 59:7; 60:1, 2 rugs [1] 127:7 rule [1] 63 rules [3] 5:14; 46:8; 87:5 run [1] 8721 running [1] 73:7 -S- safe [2] 63:5; 87:1 safely [1] 215:13 Safety [1] 186:3 safety [16] 121:1, 6, 9; 149:3; 18522; 186:18; 189:7, 8, 16; 190:4, 9; 212:6; 215:6, 11, 18 sample [1] 8722 samples [1] 74:11 Sax [1] 7:13 saying [42] 521; 15:15; 16:14; 18:17; 41:12; 4422; 452, 5; 5022; 54:4; 61:15; 69:13; 72:12; 81:3; 82:13; 87:19; 103:13; 108:12; 110:3, 7, 20; 112:6, 22; 11322; 118:18; 123:6, 9; 141:7; 14222; 166:3; 175:18; 185:19; 189:19; 19821; 199:7; 210:3; 21321; 216:1; 218:16; 23521; 248:3, 4 scan [2] 1922, 7 scandal [2] 233:16; 234:5 Scandinavia [1] 40:16 schedules [2] 23821; 239:1 School [4] 21:18; 23:8; 30:16; 91:15 school [6] 10:1, 2, 7; 18:19; 28:4; 91:13 schools [2] 18:9, 15 Schwalb [1] 2:3 scope [7] 45:11, 14; 72:11, 15; 107:15; 115:4; 126:7 scores [1] 171:10 scraping [1] 166:14 second [13] 149:14; 15920; 176:13; 178:19; 181:6; 182:8; 183:11; 184:17; 211:18; 21421; 218:7; 24320 second-guess [1] 131:3 second-to-last [1] 23020 secondary [2] 227:13; 228:12 Secondly [1] 246:13 secret [1] 172:5 section [12] 93:13, 18, 21; 97:11, 12, 13, 14; 11120; 114:3; 119:6; 1412 sections [4] 94:1, 6; 97:18; 1922 seek [1] 102:13 seeking [3] 100:9; 103:3, 10 selective [1] 66:14 self-defeating [1] 212:8 seU [1] 140:8 selling [1] 136:8 senator [1] 15:8 send [1] 21722 Senger [8] 90:1; 2203, 10, 16; 221:7, 19, 21 sense [2] 6321; 104:12 sentence [1] 181:7 sentences [1] 158:3 separate [3] 33:18; 49:7; 67:18 separated [1] 91:11 September [3] 4620; 47:5; 224:5 series [1] 248:14 serious [2] 130:6; 246:8 Services [1] 15421 services [2] 9:5, 7 SESSION [2] 4:6; 126:1 Sets [1] 231:1 sets [1] 100:16 setting [1] 6:8 settling [1] 2312 seven [2] 95:15; 96:17 share [1] 14721 Sharing [1] 111:1 sharing [2] 67:5; 131:13 Sheet [1] 251:10 sheet [2] 121:6, 9 sheets [3] 121:1, 3; 149:3 shoes [2] 60:1, 2 short-term [1] 166:19 show [7] 22:10; 462; 1652, 14; 167:7; 205:6, 9 shows [2] 9:10; 207:7 shut [1] 161:19 sick [2] 82:6; 107:11 Signature [1] 251:14 signature [3] 4621; 168:1, 19 Silbert [1] 2:3 simple [3] 1520; 72:8; 17922 single-handedly [1] 82:1 Sirota [2] 215:4, 7 sit [1] 181:19 site [22] 138:16, 19; 139:3; 141:11; 149:14, 21, 22; 150:4, 13; 152:7, 10, 13; 153:5, 12, 14; 1542, 6, 9, 17; 22921; 231:11 sites [6] 149:9, 11; 1532; 194:1; 195:19; 2243 six [3] 95:12; 1702; 23222 size [2] 96:7; 147:7 skim [5] 1362ft 157:14, 21; 223:15; 2323 skin [3] 129:3, 19; 210:6 Slaughter [2] 150:1; 152:9 slurry [2] 231:7, 9 smaller [2] 92:16; 187:12 smart [1] 176:8 smell [2] 13922; 140:1 smog [1] 15:12 Society [1] 66:9 Soil [1] 231:9 soil [10] 17:15, 19; 109:17; 15220; 154:6, 17; 249:7, 20, 22 sold [3] 126:14, 22; 140:9 solely [1] 73:14 soles [1] 60:1 solicit [1] 24622 solubility [1] 140:3 Somebody [2] 18522; 18720 relationship to Somebody HARTOLDMONOOQ9825 BSA exposing [1] 62:1 exposure [65] 8:6; 18:4; 245; 27:1; 41:6; 42:1; 482, 11, 21; 49:5, 11, 12, 14, 16; 5ft5; 51:16; 53:1, 10, 11, 22; 54-11, 18; 55:12; 56:1, 5; 58:9, 15,16; 59:8,11; 60:3; 61:7, 16; 69m; 72:12, 22; 73:18; 78:19; 80:18; 85:5, 10, 16; 86:8; 87:1, 19; 98:18; 99:1; 102:6; 106:6; 113:17; 12720; 128:1; 129:9, 11; 133:12; 141:17; 151:3; 152.-9; 163:20; 16417; 165:1, 2; 166:17; 196:19; 2123. exposures [11] 48:19; 51:9; 55:19, 20; 5620; 613, 4 63:19; 72:7; 166:6; 172:15 expressly [1] 131:5 extend [1] 126:16 extent [2] 77:4; 142:5 external [1] 160:7 eye [2] 13417; 241:7 eyes [2] 87:17; 23415 -F- facilities [1] 147:3 facility [3] 21:9; 82:7; 147:8 fact [15] 25:5; 55:18; 76:11; 124-22; 125:1; 127:13; 131:6; 141:7; 167:5; 175:6; 197:14; 198:7; 20021; 212:3; 23520 factors [1] 55:10 failing [1] 122 failures [1] 67:1 faint [1] 16820 Fair [1] 176:13 fair [14] 244; 2520; 36:16; 81:13; 95:6; 106:10; 1122; 115:14 123:4 12415; 126:9; 176:12; 180:16; 216:9 faith [1] 2152 familiar [8] 136:4; 153:5, 14 161:11; 22222; 2232; 229:14, 17 familiarity [1] 135:12 familiarize [1] 22:5 family [1] 84:15 Farm [1] 149:18 fanning [1] 92:17 faucet [1] 8721 favorable [1] 215:3 February [3] 1:14; 1582; 252:16 fed [2] 205:1, 5 federal [1] 39:1 Federation [1] 245:16 feed [1] 126:16 feedback [1] 225:18 feeding [7] 20121; 202:1, 8; 203:6; 204:8, 10; 206:12 Feel [1] 232:4 feel [4] 1922; 211:19; 215:13; 217:16 fellow [2] 79:7; 208:6 fellowship [2] 1120; 12:1 Fernandez [1] 243:18 fiber [3] 127:5, 7; 13220 field [4] 10:15; 13:13; 22:6; 26:18 Pepo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr34456.0____________ Look-See(45) Fielding [2] 2:10; 5:11 Fifteen [1] 6:18 fifth [2] 30:18; 227:6 fight [1] 20920 fighting [1] 207:7 file [1] 159:13 fill [1] 236:14 filling [1] 7521 financially [1] 252:14 find [18] 1922; 22:19; 27:7; 48:17; 61:9; 62:9; 7722; 11321; 1142; 124:9; 13220; 159:14 171:16; 187:11; 191:12; 199.-9; 205:12 finding [6] 105:14 2012; 20221; 203:5; 215:4; 24721 findings [1] 81:14 finish [1] 212:13 finished [2] 12620; 161:5 finishing [1] 10:1 firm [2] 5:10; 87:5 First [1] 246:5 first [40] 5:5; 9:11; 13:4; 147, 10; 15:6, 9; 28:13; 29:3; 36:12; 46:1; 93:3; 122:18; 136:18; 149:11, 12; 1532; 157:17; 15820; 160:4 163:7; 1646; 169:17; 177:5; 178:13, 14 15, 21; 181:1; 1862; 190:17; 1944 201:11; 207:16; 208:1; 228:13; 232:12, 14, 16; 243:12 fit [2] 28:5; 217:14 fitness [1] 24:6 Five [1] 21:14 five [11] 18:15; 53:18; 85:10, 11; 95:12, 15; 96:17; 220:19; 232:12, 14 17 five-minute [3] 642; 173:3; 248:9 flaws [1] 55:14 flow [1] 215:8 focus [3] 19:5; 2221; 20120 focusing [2] 202:17, 20 follow [3] 56:11; 57:4 155:12 follow-up [1] 5420 followed [2] 116:5; 2143 following [4] 39:16; 159:22; 172:17; 194:3 follows [1] 5:6 food [2] 86:12, 18 forcing [1] 170:13 foregoing [3] 251:3; 252:5, 7 forgot [1] 154:5 form [5] 63:12; 129:4; 193:11; 196:18; 21722 formal [17] 14:19, 20; 1522; 16:14, 16; 17:9, 11, 12, 18, 21; 18:1; 22:6; 652; 13421; 180:10; 188:6; 189:19 forms [1] 121:8 formulating [2] 213:3; 242:16 forth [4] 32:16; 66:6; 73:7; 98:22 Forum [3] 66:5; 243:13, 17 forums [1] 75:17 forward [1] 205:14 found [20] 39:18; 8021; 82:13, 17; 11021; 1242; 127:8; 162:19, 20; 163:14, 16; 172:14; 186:12; 191:13; 20122; 202:12; 210:5; 234:7; 23722; 2382 foundation [1] 67:11 four [7] 9:1; 18:14; 149:11; 1532; 220:14 19; 24721 Fox [2] 47:11; 55:8 frank [1] 217:5 free [2] 1922; 232:4 frequently [2] 6:4 56:6 Friendswood [1] 149:17 front [4] 55:6; 136:17; 19520; 223:14 Fuhreman [1] 222:16 full [3] 14:10; 171:8; 236:1 full-time [4] 13:4 147; 352; 95:12 fully [1] 212:1 fumes [1] 128:3 function [2] 170:16; 180:10 functioned [1] 37:12 future [1] 246:5 -G- gadgets [1] 113:14 Gaffey [5] 90:16, 19; 943; 9620; 133:16 gaps [1] 236:15 Garrett [32] 38:1, 10,11, 12; 902, 10; 93:11, 12; 96:19; 111:10, 13, 16, 19; 112:3, 11; 113:5; 114:3, 19, 22; 115:1, 14, 18; 116:16, 20, 22; 117:7, 11, 20; 118:8, 17, 21 gas [1] 7520 gasoline [29] 22:13, 14, 20; 69:4, 9, 14 16; 70:1, 4, 16; 71:4, 8, 18, 20; 72:5; 75:14, 17; 76:11, 13, 21; 77:13, 19, 22; 78:10; 822; 87:6; 105:13; 10822 gave [3] 137:1; 14922; 227:1 generic [2] 200:4, 6 geology [2] 17:19; 152:18 GEORGE [3] 1:13, 16; 5:3 George [9] 3:3; 13722; 18022; 182:10; 207:6; 208:14; 212:16; 233:8; 2512 gets [4] 362; 63:14, 15; 85:13 Give [1] 13:7 give [15] 520; 8:12, 22; 102; 1220; 31:13; 3420; 69:8; 98:12; 103:17; 155:15; 165:17; 206:14; 225:18; 233:1 given [8] 22:6; 1972; 221:12; 227:3; 232:1; 234:19; 251:7, 11 Giving [1] 212:6 giving [4] 47:16; 12418; 131:1; 155:14 doves [1] 110:14 goal [8] 41:18; 77:10, 12; 110:1, 10; 113:14; 119:14 134:7 goes [8] 18:11; 61:10; 8415; 85:14 113:9; 127:7; 159:1 golf [1] 139:10 Goodrich [1] 61:5 gotten [5] 18:10; 63:16; 7520; 118:19; 247:17 Government [1] 662 government [17] 39:17; 41:17; 447; 56:15, 19; 572, 10t 592; 75:7, 8; 872, 5; 100:16; 10422; 105:14 108:16, 19 governmental [1] 243:6 graduate [1] 9:16 graduated [1] 10:3 great [3] 71:15; 10413; 2152 Grimm [1] 191:6 Gross [1] 166:16 ground [2] 5:14 14420 Groundwater [4] 224:6; 242:10; 243:13, 17 groundwater [21] 17:15; 18:1; 15222; 154:8; 225:3, 6, 14 2272; 242:16, 22; 243:6, 9; 244:13, 18; 246:6, 9, 11, 16; 24720; 249:8, 17 group [25] 54:1; 66:8, 11, 14 67:4, 5; 712; 9410; 97:17; 111:10, 19; 112:11; 1482, 3; 153:3; 162:6; 181:7; 186:14 200:4 6; 216:13; 218:15; 242:12; 24320; 2442 Groups [1] 243:12 groups [1] 181:10 guaranteed [1] 41:8 guess [4] 544; 129:5; 135:11; 15416 guidance [1] 141:16 guide [1] 136:18 guideline [1] 16020 guidelines [3] 56:15, 19; 246:7 -H- hadn't [4] 40:6; 63:16; 819; 1222 half [1] 122:1 Hall [1] 212:4 Hancock [1] 22415 hand [2] 212:4 252:16 handle [4] 46:10; 98:13; 148:11; 162:7 handled [2] 11520; 121:5 handling [4] 52:18; 128:6; 225:10, 13 hands [1] 219:3 handwritten [1] 13721 hangup [1] 20522 Hanley [1] 179:6 happens [2] 4521; 62:5 happy [1] 238:4 hard [2] 68:13; 2242 Hard-Lowe [1] 149:16 harder [1] 50:17 hardly [1] 87:18 haven't [5] 792; 8320; 112:6; 129:1; 130:5 hazard [2] 119:15; 151:7 hazards [1] 120:5 head [6] 521; 2822; 116:10; 185:5, 6; 222:16 headed [9] 93:12; 1143; 181:7; 184:15; 196:1; 227:7; 229:12; 23021; 23121 heading [2] 18418; 243:12 headquarter [1] 35:7 headquarters [6] 35:3; 41:12; 14021; 239:15, 16; 240:11 heads [1] 42:5 Health [2] 42:7; 182:17 health [56] 720, 21; 11:11, 15; 1417; 18:10, 16; 21:10, 22; 2220; 25:10, 21; 27:15; 39:16, 17; 42:18; 61:13; 70:1; 72:6, 16, 20, 21; 73:12; 77:5; 89:13; 99:4, 10, 12; 100:6, 9; 1025; 106:7, 10; 107:19; 108:13, 14 20, 21; 111:13; 11722; 120:9; 122:7, 14 123:10; 127:19; 129:10, 12; 134:18; 160:7; 166:19; 195:3; 215:10, 18; 225:14 233:10; 236:3 hear [2] 24:16; 143:1 heard [4] 72; 22:15; 153:6; 159:16 Heart [1] 1121 heart [5] 122; 2022; 241, 2, 13 Heckscher [1] 1:18 heightened [1] 28:7 Help [1] 65:12 help [12] 5:16; 27:19; 111:14, 17; 112:8; 146:17; 155:8; 179:1; 183:5; 194:19; 205:12; 2362 Helped [1] 30:12 helped [2] 28:12; 235:1 helpful [1] 113:1 helps [2] 20:15; 241:7 hemograms [1] 53:4 hence [1] 181:11 hereby [2] 2512; 252:5 hey [1] 102 hide [1] 54:19 high [9] 48:19; 55:19; 56:5; 612; 116:9; 15414 174:14 233:7; 235:18 higher [7] 4821; 55:20; 63:11; 79:5, 9; 18520; 18720 highly [1] 215:6 highway [1] 8416 highways [1] 73:7 hire [1] 3416 hired [1] 122:1 history [3] 19:4 196:3, 7 homeowners [1] 150:11 honors [1] 1415 hope [1] 136:3 Hospital [2] 12:9, 17 hospital [1] 252 hospitals [1] 25:13 hour [4] 6:3; 642; 173:4 220:1 hourly [1] 33:8 hours [1] 9:1 human [5] 27:14 197:17, 18; 233:10; 236:3 humans [4] 70:7; 78:15; 163:9; 164:8 hundred [7] 60:3; 62:6; 63:11; 96:5; 203:17; 214:10; 23521 hundreds [1] 212:5 hydrochlorine [1] 176:9 Hygiene [1] 37:7 hygiene [8] 67:10; 93:9, 13, 18; 97:12; 11120; 114:3, 6 hygienist [5] 37:9; 38:3; 113:9, 18; 11420 Hygienists [1] 66:3 hygienists [3] 93:16; From exposing to hygienists HARTOLDMONOOQ9826 BSA 113:6, 8 -I- IBT [3] 233:17; 235:12, 20 idea [14] 9:12; 1220; 13:7; 31:13; 3420; 45:11; 8320; 104:6; 115:4; 165:17; 17422; 189:13; 238:6, 13 Ideally [1] 128:8 identification [13] 465; 136:15; 1575; 1675; 173:8; 176:18, 22; 184:7; 19122; 207:1; 223:12; 231:18; 241:1 IDENTIFIED [1] 3:7 identified [3] 198:10; 215:9; 216:3 identify [2] 2242; 236:3 identifying [1] 224:3 H [1] 231:4 Ed [1] 2315 imagine [1] 24721 impact [2] 181:12; 243-5 implied [1] 35:1 important [10] 83:10, 15; 84:10, 20; 104:19; 128:11, 15; 233:1, 9; 236:15 impossible [1] 196:3 impression [1] 214-6 improve [2] 5222; 247:17 improves [1] 67:3 improving [1] 103:18 inability [1] 25:14 Inc [1] 215:5 Incas [1] 7322 incident [1] 190:6 incinerate [1] 175-5 incinerated [1] 175:15 incineration [7] 17:7; 109:17; 17522; 228:15; 249:3 include [5] 129:3; 1702; 196:18; 213:16; 22722 Included [1] 58:4 included [4] 30:15; 435; 1942; 226:13 includes [1] 211:6 inconsistent [1] 41:16 increase [1] 74:5 increased [2] 44:14; 74:6 increasing [4] 65:13; 66:7; 74:5; 233:12 increasingly [1] 233:9 Indemnity [2] 2:13; 5:12 India [1] 13020 indicates [2] 158:14 232:1 Indicating [3] 107:13; 110:2; 13122 indication [1] 1646 individual [4] 5421; 88:18; 109:11; 211:9 Industrial [7] 662; 67:7; 233:16; 2343, 5, 7, 13 industrial [16] 37:9; 38:3; 67:10; 93:9, 13, 16, 17; 97:12; 11120; 113:6, 8, 9, 18; 114:3, 5, 19 industries [1] 5921 industry [8] 68:17, 19; 82:8; 131:15; 162:4, 12; 166:3; 2032 ineffective [1] 234:15 influenced [1] 55:10 inform [3] 190:3; 193:7; 209:14 informal [2] 6:7; 18:4 Depo of George Roush, JR,, M.D- Monsanto v Aetna February 18, 1993 Cr54456.0_____________Look-Se?e(46) Information [2] 675; 1005 information [64] 65:17; 66:17; 8220; 932; 99:15, 22; 1005, 10; 101:10; 102:14 103:3, 5, 10; 111:1; 120:8; 121:7; 122:14; 1232, 3, 10, 11, 16; 124:8, 14, 15; 125:3; 128:12, 16; 131:1% 138:15; 146:16; 147:14, 15, 21; 149:7; 155:14, 16, 18; 160:18; 177:4; 192:17, 18; 1945, 18, 20; 195:17; 197:1; 198:16; 206:11; 209:19; 210:7, 14, 20; 213:19; 2141; 215:8, 16; 217:18; 228:10, 11; 2295; 24222 informing [2] 189:18, 20 Infrequently [1] 95:5 ingest [1] 129:19 ingesting [1] 86:8 inherent [3] 62:15; 166:1 initiated [1] 59:1 initiative [1] 181:11 injection [1] 228:15 injured [2] 13:19; 25:1 Inorganic [1] 81:7 input [11] 109:8; 120:14 121:12; 12320; 145:9; 146:4 227:18, 19; 236:8; 24221; 243:4 inside [3] 744; 162:18; 163:19 inspect [2] 154:6, 8 inspection [1] 13421 instance [2] 3720; 246:3 instances [2] 100:8; 246:8 Institute [8] 1121; 12:6; 67:15, 18; 68:1, 3, 4, 12 institute [1] 164:10 instituted [2] 5522; 169:11 Institutes [1] 42:7 instructions [1] 170:5 instruments [1] 151:13 Insurance [13] 1562, 5, 12; 15821; 187:18; 188:3, 4, 7, 12; 18920, 22; 190:3; 191:3 insurance [9] 15521; 156:15, 18, 21; 157:3; 159:6, 19; 188:14; 190:6 integrity [1] 193:19 intended [1] 1605 intent [1] 98:6 interact [4] 9421; 98:5; 100:10; 10220 interaction [2] 101:4; 147:17 interest [2] 1820; 98:11 interested [12] 42:19; 50:4; 685; 10821; 109:1, 2; 116:4; 117:13; 141:15; 15022; 240:8; 252:15 interests [3] 6820; 237:18, 19 interfaces [2] 236:10; 237:9 interim [1] 92:3 intermediates [1] 126:16 Internal [1] 12:19 internal [3] 12:10, 17; 160:7 internally [1] 219:1 International [1] 37:7 Internship [1] 11:3 internship [2] 11:5, 8 interplay [1] 122:6 interpret [3] 30:13; 9414 236:4 interpreting [1] 124:15 introduction [2] 193:15, 16 intuitively [1] 8417 invariably [1] 238:1 investigate [3] 54:18; 15220; 15416 Investigation [1] 15421 investigator [4] 15420; 1555, 14, 17 involve [3] 39:12; 72:6; 79:13 involved [63] 18:16; 19:1; 28:12; 33:6; 342; 38:17; 39:16; 40:15; 41:13; 432; 812; 10022; 10417; 107:1, 18; 108:11; 109:4, 5, 15; 110:16, 20; 111:6; 112:6, 10, 12, 14 116:1, 2; 117:13; 118:10, 19, 20; 119:1, 19; 1202, 4; 12417; 135:13; 143:17; 162:3; 170:13; 194:15, 22; 197:8; 198:1, 15, 21; 199:4; 225:15, 16; 228:14; 229:6; 2305, 14; 235:12; 2395; 242:13; 243:16; 24416; 2455; 2462; 247:4, 17 involvement [25] 40:11; 43:15; 106:6, 14, 17; 107:16; 108:8; 115:15; 116:19, 20; 14414 1455; 159:16; 175:13; 194:6, 11; 19520; 199:11; 227:10; 231:13; 241:6; 242:15; 245:11; 247:1, 15 involves [1] 1632 involving [5] 6:19; 43:12; 1405; 152:7; 1542 IQ [1] 79:11 Island [2] 12:9, 16 issue [31] 22:17; 25:9; 39:17, 22; 40:8, 10; 4421; 45:1; 61:13; 62:7; 69:4; 76:16, 19; 78:9; 79:6; 89:14; 1043; 105:1; 107:19; 11410, 12; 115:16; 116:15; 133:19; 163:11; 175:10; 198:11; 215:18; 225:13 issues [14] 325, 10; 40:12, 21; 112:3; 117:1, 21, 22; 118:14; 119:4; 18921; 21422; 237:7; 241:6 issuing [1] 1492 Italy [1] 741 item [8] 15820; 159:20; 169:17; 170:10, 17; 171:9; 194:14 items [1] 23222 -J- Jack [1] 38:1 January [2] 192:5; 23120 Japan [1] 40:18 Jefferson [1] 2:4 Jessee [1] 193:10 Jim [5] 220:9, 10, 12, 16 job [24] 13:4, 11, 20; 147, 10; 19:4; 2121; 243, 7, 17; 25:6; 645, 15, 21; 114:4, 22; 115:4, 11, 19; 12022; 233:1; 234:8; 236:4, 5 jobs [1] 20:7 John [1] 47:11 JONES [20] 22; 48:3; 50:1, 18; 51:6; 525; 53:12, 15; 57:8; 83:12; 8412; 875; 1002; 136:12; 14410; 145:16; 212:12; 2202; 242:7; 250:14 Jones [3] 8:18; 92; 250:12 JOSEPH [1] 22 JR [3] 1:13, 16; 5:3 Jr [3] 3:3; 158:15; 2512 judgment [1] 1512 July [1] 177:12 June [2] 241:14 243:1 -K- keep [7] 4122; 4418; 49:18; 119:14; 1343; 199:7; 210:4 keeping [1] 21121 Kehoe [8] 81:7, 21; 82:10, 2Q; 832, 3; 85:6; 1372 Kelly [10] 34:14, 15,16; 35:15; 36:4 37:1; 39:7; 47:8; 88:13; 15421 kept [1] 130:14 Kettering [5] 21:5, 6; 22:8; 8122; 82:7 Key [1] 15821 kids [2] 69:12; 79:11 kinds [5] 105:8; 120:5; 15414; 1622; 163:15 knee [1] 25:1 knife [1] 166:14 Knowing [1] 118:6 knowing [3] 80:19; 118:7; 227:16 knowledge [19] 52:1; 65:14 66:8; 103:18; 105:12; 119:3; 121:11; 13120; 135:5, 19; 14414 160:8; 164:5; 172:10; 21221; 213:19, 22; 21520; 235:19 KNOWLES [2] 120; 252:4 -L- Lab [1] 21:5 lab [21] 26:7; 91:10, 20; 92:4, 7, 13; 93:4, 7, 20; 96:14 146:19; 147:6; 183:19, 21; 220:7; 221:10, 17; 222:8; 223:6; 235:8 laboratories [4] 9220; 147:4; 1942; 23820 Laboratory [4] 21:6; 22:8; 82:1, 7 laboratory [12] 91:5; 92:1, 19; 96:10; 13020, 21; 14622; 147:6; 183:12; 19321; 221:11, 13 labs [1] 147:11 laid [1] 169:10 Lake [1] 153:13 landfills [3] 17:4; 228:16; 249:5 Urge [1] 43:6 large [8] 13:18; 143; 62:8, 11; 116:10; 149:8; 186:17; 23721 largely [2] 218:18; 223:5 larger [1] 129:11 largest [1] 43:7 last [18] 6:9; 16:16; 1721; 18:14; 60:18; 82:12; 87:18; 140:7; 153:12; 1552; 15722; 1712; 1962; 216:14; 220:19; 236:1; 245:3; 246:4 Ute [2] 26:16, 17 late [2] 26:17; 28:8 law [3] 1:18; 6:7; 15:9 laws [1] 181:9 lawsuit [3] 5:12; 149:8; 1552 lawsuits [1] 6:19 lawyer [1] 5:10 Uad [7] 67:15, 18; 68:1, 3, 4, 11; 69:4 lead [104] 22:14, 20; 2621; 27:1, 4, 18, 19; 282; 682, 17, 18, 21; 69:3, 8, 9, 13, 14, 15, 22; 702, 4, 7, 15, 16; 71:18, 21; 72:5, 7, 12, 17, 20, 21; 73:8, 19, 22; 741, 2, 21; 75:11, 13, 17; 76:13; 77:3, 5, 13, 19, 22; 78:6, 7, 10, 14, 16, 17, 19; 79:3, 7, 8, 13, 14 80:3, 10, 18; 81:1; 822, 5, 11, 14, 17, 18, 21; 83:11, 16, 17, 18, 19; 844, 11, 13, 14, 15; 85:3, 5, 13; 86:8, 9, 10, 15, 18; 87:1, 6, 7, 13, 14, 20; 88:1; 105:13; 10620; 107:8; 10822 leaded [2] 71:4 8 leaders [1] 99:12 leading [2] 53:12, 14 learn [5] 36:14; 56:10; 86:7; 117:13; 124:8 learned [1] 23821 learning [2] 15:13; 72:16 leave [2] 117:6; 248:10 leg [2] 2414 legislation [3] 243:9; 246:16, 18 lend [1] 229:4 letterhead [2] 47:3; 169:2 leukemia [7] 60:4; 62:19, 21; 63:10, 13, 14, 17 levee [2] 138:9, 11 level [15] 41:16; 55:11; 62:5; 73:6; 79:6; 85:4; 87:1, 16; 107:11; 120:14; 166:16; 174:14; 18720 levels [12] 42:8; 48:11; 549; 70:7; 71:18; 78:11; 79:3, 9; 85:17; 113:17; 151:3, 16 Levinskas [12] 38:4, 19; 90:12; 9620; 116:18; 118:18; 130:19; 145:15; 147:16; 159:22; 23420; 235:12 Levy [1] 138:18 liability [1] 190:18 Liaison [2] 158:10, 11 library [1] 8120 lifetime [6] 20121; 202:1, 8; 203:6; 204:8, 10 likelihood [1] 118:7 limit [2] 542; 127:20 limits [11] 8:6; 41:4; 42:1, 3, 13; 70:21; 73:1; 75:8; 98:18; 99:1; 102:6 line [4] 218:4; 224:5; 231:8; 2402 lines [2] 231:10; 246:14 links [1] 236:13 list [5] 47:8; 122:4; 184:14; 2247; 23222 listed [5] 47:8; 4820; IBT to listed HARTOLDMONOOQ9827 BSA____________________ 1910; 241:16; 24321 literature [4] 52:15; 81:19; 201:8 litigation [4] 9:3; 150:1; 159:19; 172:1 lived [3] 73:9; 150:9; 151:7 liver [4] 163* 168:7; 170:3, 16 lives [1] 84:15 living [2] 78:18; 151:1 located [1] 149:17 location [1] 1942 locations [2] 118* 144:9 loggerheads [1] 42:8 logical [1] 170:11 long-term [1] 166:19 lose [1] 210:19 lost [1] 20:11 lot [15] 14:14; 18:17; 27:15; 2820; 55:11; 8520; 104:10; 105:11; 13720; 140:3; 151:17; 157:12; 200:10; 21721; 228:8 Lots [1] .178:7 lots [4] 99:19; 192:14; 230:13; 235:3 Louis [7] 1021; 35:12; 95:3, 6; 171:11, 14; 239:15 Louisville [4] 20:19; 23:7, 17; 163:13 low [6] 61:16; 63:19; 78:10; 87:17; 107:12; 166:7 Lowe [2] 75:12; 149:16 lower [6] 61:8; 70:16; 75:11; 78:11, 12; 84:4 lowering [2] 70:15; 79:7 lunch [4] 119:17; 125:5; 126:4; 1472 lungs [1] 28:3 -M- M.D. [6] 1:13, 16; 5:3; 10:8, 20; 2512 MAC [1] 2222 mad [1] 164:17 magnitude [1] 73:11 main [2] 692 Maine [1] 15:8 major [7] 10:14; 25:9; 95:10; 114:10, 12; 185:7, 9 majority [3] 6821; 114:19; 122:11 man [28] 13:21; 14:5; 20:3; 24:13, 17, 21, 22; 25:5, 16; 49:4, 12; 50:4; 61:7; 63:14, 17; 6920; 82:1; 84:13, 15; 113:9; 123:15; 124:6; 127:11; 139:16; 160:13; 164:3; 166:13; 179:4 manage [1] 236:6 management [11] 192:5, 16; 193:17; 195:6; 206:18; 209:18; 2112, 4, 6, 22; 217:20 manager [5] 109:12, 15; 121:19; 210:11; 230:8 managing [1] 181:12 mandated [2] 592; 87:3 manner [1] 175:6 manufactured [2] 161:13, 16 Manufacturers [5] 148:13; 162:9; 244:3; 245:14, 18 Pepo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 ____________ Look-See(47) manufacturers [1] 71:6 Manufacturing [1] 148:6 manufacturing [8] 10522; 1063; 145:10; 146:1, 5; 19320, 22; 195:19 March [1] 207:17 Marine [2] 12.-9, 16 Mark [1] 173:6 mark [6] 46:3; 157:6; 176:19; 20620; 231:16; 24021 marked [14] 46:4, 7; 136:14; 157:8; 167:8; 173:7; 176:17, 21; 184:6; 19121; 207:1; 223:11; 231:17; 24022 Market [1] 1:19 marketed [1] 822 marking [1] 46:8 Marquette [1] 11:3 Massachusetts [1] 121:14 Master [1] 11:11 master [2] 11:14; 14:17 material [7] 41:14; 85:12, 15; 121:8; 146:11; 149:3; 1723 materials [7] 99:5; 121:1; 1383; 141:15; 143:19; 157:14, 21 mathematician [1] 135:9 Mathematics [1] 10:18 mathematics [1] 10:19 matter [5] 2220; 63:5; 130:11; 21*3; 21620 matters [2] 115:15; 143:6 MCA [3] 148:17; 149* 16*6 MCO [1] 137:9 mean [30] 10:6; 20:16; 45* 7*10; 75:1; 79:1; 862; 87:10; 982, 7; 99:18; 10*17; 105:19; 107:7, 21; 111:8; 112:15; 1163; 118:17; 1262* 129:7, 14; 19621; 198:18; 199:1; 204:1; 21822; 239:4; 24521; 246:1 means [4] 171:18; 199:3; 200* 21820 meant [1] 43:18 measurable [4] 77:14, 20; 78:1, 2 measure [9] 50:11; 54:11; 55:1* 56:1; 86:3, 6; 87:18; 99:5; 118:7 measured [2] 50:1* 99:7 measuring [2] 49:7; 151:16 Medical [97] 21:18; 23:8; 30:16; 39:4; 41:18; 42:13; 61:16, 19; 66:5; 91:7, 15; 9*16; 93:6, 10; 94:1, 6, 13, 21; 95:3; 96* 97:18, 21; 98:4, 10, 17, 21; 9920, 21; 100:10, 21; 10121; 10*1, 1* 105:16; 1063, 9, 13, 22; 107:15, 18; 108:7, 14; 109:3, 8, 18; 110:5, 15; 11*4; 113:3; 11521; 1162, 16; 117* 4, 6, 7; 120:7; 122:12, 22; 123:7; 124:13; 126:8, 10; 127:16; 141:4, 20; 1423; 143:11; 144:4; 145:8; 146:4; 1693; 171:11; 17*9; 180:6; 182:16; 183:4, 8, 15; 1853; 187:5; 194:5; 1963; 201:13, 17; 206:11; 209:13; 214:7; 226:1* 227:19; 229:4; 231:1* 23622; 245:10; 247:14; 248:4, 5 medical [78] 10:1, 7; 20:6, 9, 10, 17; 2*9; 23:13; 26:7; 28:4; 29:4, 8, 10, 11; 3121; 34:12, 13, 21; 36:4, 9, 19, 2* 382* 39:8; 40:19; 43:12; 442; 58:18, 19; 60:14; 64:18; 65:1; 79:12, 15; 883, 10, 14, 16; 89:4; 903, 15, 21; 91:6, 1* 9*2, 11; 94:11; 962* 97:6, 22; 99:13; 1113; 119:18; 120:13; 12320; 126:7, 9; 144:7; 147:13; 15*6; 156:11; 161:17; 18*18; 184:18; 18821; 189:6, 7, 9; 194:15, 2* 195:19; 21020, 22; 2332* 24*12 Medicine [6] 19:17; 21:7; 65:7, 15; 67:7; 182:17 medicine [40] 11:6, 13; 1*10, 15, 18, 19, 2* 13:6, 8, 14; 19:11, 15, 16; 21:3, 12, 21, 2* 222, 11; 23:13, 16, 20, 21; 24:5, 9; 28:12, 17; 3*8; 3422; 49:1, 2, 6; 522; 54:1* 55* 66:1* 97:8, 13; 100:19; 1412 meet [6] 8:15; 13:9; 156:17; 23821; 239:1; 240:9 Meeting [1] 158:10 meeting [8] 3120; 46:1; 65:18; 67:4; 158:18; 211:11; 233:6; 235:18 meetings [2] 69:7; 217:8 member [9] 31:4, 10; 3*11; 65:6; 66:5, 9, 13; 68:6; 244:6 members [3] 158:14; 159:9; 245:8 memo [28] 4620; 54:5, 6; 13721; 157:13, 16; 158:9, 18, 20; 167:12; 169:8; 173:11; 175:1; 176:4; 178:15, 22; 1812; 207:17; 208:1* 213.-9; 214:14, 19; 224:4; 241:14; 243:11; 246:4; 247:6, 9 memory [4] 159:5; 178:1, 3, 5 memos [4] 21621; 218:18, 22; 219:6 men [1] 204:4 mentioned [5] 18:18; 153:19; 176:13; 220:6; 227:11 mercury [1] 27:16 mere [1] 107:5 metals [2] 81:10, 12 method [3] 121:4; 128:6; 239:3 methodologies [1] 51:1 methodology [2] 122:17, 18 methods [5] 1620, 21; 249:14; 2503 MIC [5] 236:11; 239:11, 12, 16 microscope [3] 163:15; 204:11, 12 mid [5] 26:14; 57:5; 86:16; 163* 22 mighty [1] 1582 migration [1] 230:18 million [8] 59:13; 61:8; 6*4, 9; 63* 6; 113:11 Milwaukee [1] 11:4 mind [4] 6:1; 175* 176:11; 2483 Mine [2] 178:16; 189:18 mine [8] 22:4; 35:8; 50:13; 702; 1342; 137:7; 16821; 18020 minimize [1] 141:17 minor [1] 172:15 minute [1] 1545 Minutes [1] 158:10 miss [1] 12*10 missing [1] 12321 Mississippi [3] 26:6; 27:4 7 Missouri [1] 185:17 modifications [1] 146:5 modify [1] 1462 monitor [2] 66:1; 11*7 monitored [1] 238:3 Monitoring [1] 195:8 monitoring [15] 51:15; 58:15, 19; 6*15, 16; 117:11, 12; 164:11; 167:1, 2; 19421; 195:1, 3, 11; 233:14 monitors [1] 113:10 monomer [1] 161:11 MONSANTO [1] 1:3 Monsanto [124] 6:19, 22; 8:8; 9* 152; 195; 23:3, 4; 2821; 29:3, 16, 17, 19, 21; 30:1, 3, 7, 22; 3*6, 7, 15, 2* 332* 34:13; 35:4; 38:7; 41:6, 9, 10, 1* 43:4; 47:3; 51:13, 21; 5*2; 55:17; 57:11, 1* 20; 58* 59:1; 60:15, 16; 6*4, 1* 64:7, 16; 655; 67:14; 71:10; 75:1; 79:13; 88:6; 89:10; 9021; 91:19; 9*4, 15; 93:3; 103:14; 104:17; 106:14; 107:17; 113:1; 115:16; 12*3; 1232* 126:11; 127:5, 17; 128:13, 17; 130:4, 14; 131:9; 132:15; 138:1; 14020; 143:4; 144:8; 14620; 150:6; 153:10; 154:3; 155:14, 16, 21; 156:15; 164:10; 165:19; 166:4, 18; 169* 180:17; 181:12; 1862; 189:11; 193:17; 196:3; 1992, 5; 201:17; 209:7; 2112* 212:3; 215:6; 220:11; 222:4; 22922; 233:6, 10; 2342, 1* 2352, 17; 236:3; 241:15; 24*16; 243:5; 244:6; 247* 248:7, 19 Monte [2] 218:6; 23*1 month [2] 30:10; 82:12 months [1] 1702 morning [2] 5:9; 110:8 Morris [1] 1:18 Motco [2] 153:3, 10 motel [2] 139:7, 8 motivated [1] 4922 mouse [1] 145 move [2] 96:14; 12*19 moved [3] 221:7, 2* 222:16 moving [1] 1802 MS [85] 5:8; 46* 6, 17; 48:4; 50* 20, 21; 515, 4, 8; 5*7; 53:13, 16, 19; 57:10, 14; 632* 645, 6; 83:14; 852; 87:11; 98:19, 20; 100:3; 117:16, 18; 1255; 126:3, 5; 133:18; 136:16, 22; 137:8, 11; 144:12; 14521, 2* 157:6, 10; 158:4, 5; 167:7, 10, 17; 168:8; 173* 6, 9, 14, 18; 176:15, 19; 177:1, 4, 8; 184:4, 8, 11; 19120; 19*1, 1* 199:15, 19; 20620; 207:10, 13; 21*15; 21921; 220:4, 5; 223:10, 13, 19; 231:15, 19; 23*13; 24020; 241* 11; 24*9; 248:8, 13; 250:11 Ms [2] 3:4; 21*13 Muskie [1] 15:8 myelogenous [1] 6221 myself [1] 68:19 -N- N.W. [2] 2:4, 11 name [12] 5:9; 19:16; 46:8; 4820; 1592* 177:16; 184:18; 208:1; 2205; 22222; 229:19; 232:1 named [2] 66:16; 22220 names [7] 82; 37:3; 149:15; 153:4, 6; 184:14; 191:6 NANCY [1] 2:9 Nancy [1] 5:9 narrow [1] 21*17 NASA [1] 28:15 National [10] 1120; 4*6; 45:1; 243:13, 17, 21; 24420; 245:1, 6, 16 national [4] 46:1; 69:4, 7; 75:17 nature [1] 189:10 needs [6] 32:6, 7; 115:8; 233:7; 235:18; 240:3 negotiate [1] 237:6 negotiating [2] 15520; 157:3 nervous [1] 17322 network [3] 180:17; 215:1; 231:1 newborns [1] 79:8 news [1] 218:17 NIH [3] 12:6; 4*6; 43:3 NIOSH [7] 4*3, 4, 21; 1022, 5; 121:20; 12421 Nitro [1] 116:1 Nobody [1] 76:17 nobody [1] 45:15 nodding [1] 521 nods [1] 2822 normal [3] 54:15; 7021; 189:3 normally [1] 205:3 North [18] 138:1* 15, 19; 139* 1* 140:5; 141:11; 14*4; 149:1* 154:6, 8, 17; 229:12, 14, 17, 19; 230:4; 231:11 north [1] 231:10 Notary [3] 5:5; 251:18; 252:18 note [1] 21422 noted [3] 215:7; 2472; 251:9 notes [1] 248:10 From literature to notes HARTOLDMONOOQ9828 BSA notice [1] 207:3 Notification [1] 184:15 notification [1] 187:19 notified [13] 184:22; 1853, 8, 20, 21; 186:7, 13, 18, 19, 22; 187:4, 13; 188:2 notify [6] 185:5; 186* 187:17; 188:12; 190:5, 10 notoriety [1] 37:6 November [1] 173:10 nuclei [4] 203:22; 204:13; 205:8 nucleus [7] 200:2, 3, 7, 16, 19; 205:16; 206:7 NUMBER [1] 3:7 number [12] 8:4; 76:7; 89:5; 96.21; 132:8; 149:15; 153:4; 259:1; 16030; 171:9; 200:19; 20212 numbered [1] 243:11 Numbers [1] 184:15 numbers [3] 137:9; 178:20; 184:14 -O- oath [1] 5:6 object [1] 145:16 Objection [9] 48:3; 50:1; 51:6; 53:12; 57:8; 83:12; 87:9; 10012; 144:10 objection [3] 52:5; 53:13; 84:12 objectionable [1] 87:10 objective [1] 218:5 obtained [1] 160:8 obtaining [3] 123:3; 124:14; 156:14 obvious [1] 233:15 Obviously [2] 89:17; 247:19 obviously [4] 42:11; 138:19; 174:18; 233:16 occasion [1] 99:21 occupation [3] 22:4; 67:9; 79:5 Occupational [4] 19:17; 34:22; 65:7, 15 occupational [26] 11:13; 13:6, 8; 19:15, 16; 21* 22:2, 11; 23:13, 16, 20, 21; 24:4, 9; 32:5, 8; 48:21; 49:1, 6; 52:1; 66:12; 97:7, 13; 100:19; 11330; 1413 occupied [1] 116:9 occur [1] 1183 occurred [1] 110:16 octane [1] 76:7 October [1] 25230 Off-the-record [2] 50:19; 242:8 Offhand [1] 11932 offhand [1] 187:9 office [2] 2432; 373 officer [2] 179:5; 252:4 officers [2] 42:18; 220:16 offices [1] 1:18 official [1] 46:12 Oh [9] 37:4; 82:19; 115:9; 1323; 15131; 159:7; 1723; 179:9; 202:14 oh [3] 59:12; 61:18; 178:16 Ohio [1] 59:7 oil [1] 80:10 oils [1] 80:18 Okay [102] 13:1; 2030; Depo of George Roush, JR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456. 0_____________Look-See(48) 21:15; 26:5, 10; 28:10, 18; 30:14; 34:12; 38:15; 39:15; 41:7; 44:12; 50:16; 54:13; 55:1; 56:7, 12; 583, 13; 603; 61:12; 6330; 6532; 66:4; 67:10; 69:11; 70:19; 7132; 72:10, 16, 19; 73:4; 74:14; 753; 76:15; 77:1, 8, 15; 83:1; 883; 95:17; 102:19; 110:13; 1173; 119:12; 120:3; 121:16; 1223; 132:16; 1363; 139:17; 140:14; 148:10; 1493; 155:10; 159:12; 160:17; 1613; 1623; 166:15; 169:14; 171:7; 176:7; 179:14, 21; 180:13; 181:18; 186:10!; 188:19; 1893; 190:13; 1933, 12; 195:16; 196:17; 199:6; 201:10; 204-17; 2053; 206:8; 2093; 2183; 2213; 222:13; 223:16, 18; 225:11; 226:17; 228:7; 229:8; 230:11; 23411; 235:14; 237:15; 238:18; 239:14; 240:13, 17; 24415; 247:11, 18 okay [15] 7:11; 10:11; 20:12; 22:16; 32:14 40:19; 5632; 65:1; 80:12; 82:19; 1013; 175:17; 177:16; 202:14 238:11 old [2] 120:19; 236:11 ones [10] 28:3; 9418; 10831; 109:1; 2033, 10; 205:13; 210:15; 237:6; 23830 ongoing [5] 4410, 20; 453; 2463, 11 open [4] 8731; 15130, 21,-236:16 operated [2] 253; 194:4 operating [20] 92:11; 163:14 235:5; 2363, 8, 11, 14 18; 2373, 3, 8, 20; 238:10, 11, 13, 15; 2393, 7, 8; 240:4 operation [2] 16230; 199:4 operations [2] 19331; 246:7 opinion [2] 188:13; 215:3 opposed [4] 66:7; 133:13; 147:6; 166:13 option [1] 238:7 ORDBR [1] 1:1 order [4] 63:10; 141:16; 17131; 188:17 orders [1] 172:4 Organic [1] 245:13 organics [1] 200:14 organization [4] 66:13; 68:4; 148.-9; 236:12 organizations [3] 65:6; 66:15; 247:16 organize [2] 94:11, 13 organized [2] 9032; 91:3 organizing [2] 97:14, 16 Orleans [1] 21:19 OSHA [12] 8:4; 42:1, 20; 563; 59:10; 1023, 5, 7; 167:19, 21; 17032; 171:5 Ours [1] 225:12 ours [2] 225:10; 22631 ourselves [2] 1083; 23419 outcome [1] 252:15 Outline [1] 224:5 outlined [1] 170:16 Outside [1] 653 outside [17] 649,15, 20; 1143; 11532; 117:8; 131:14; 143:11; 1473, 4, 6, 11; 198:17, 18; 199:1, 5; 238:14 outstanding [1] 23422 overall [2] 703; 118:13 oversee [1] 35:17 overstating [1] 12418 Overview [1] 241:15 overview [4] 19:4 1343; 135:19; 24232 owned [1] 194:4 oxygen [1] 200:11 -P- p.m. [4] 125:7; 1263; 250:16 Page [1] 23231 page [30] 4631; 136:18; 15830; 15930; 168:19; 176:13; 1813; 182:8; 183:11; 18417; 1863; 190:17; 1913; 193:14 196:1, 9; 21421; 218:8; 227:6; 229:11; 23030; 232:8, 20; 236:1; 243:1, 11; 245:3; 246:4 20 pages [11] 137:1; 157:17, 22; 177:6; 229:11; 2323, 4, 12, 14, 17; 2513 paid [2] 32:15; 333 pain [1] 24:13 painfully [1] 233:15 paint [1] 603 paragraph [10] 160:4 181:4 1963:211:18; 21431; 216:14 218:8; 233:4 236:1; 245:4 paragraphs [1] 232:19 Parathion [1] 197:14 parathion [9] 196:18; 197:11, 20; 198:1, 11, 22; 199:4 7, 13 Pardon [4] 90:18; 156:4; 177:18; 229:16 part [58] 21:6; 248, 19; 28:15, 16, 20; 30:15; 51:15; 58:10; 59:12, 13; 61:7; 62:4 9; 633; 6417; 65:7; 66:1; 673, 10, 16, 21; 68:1; 7410, 12, 15; 92:16; 93:6, 9; 10132; 113:11; 115:11; 123:16; 127:16; 1283; 137:4; 1463; 1483, 9; 149:10; 159:18; 167:19, 21; 170:6, 9, 10, 17; 172:1, 2, 3; 181:14; 183:14; 189:19; 193:16; 211:4 217:13; 235:7 partially [1] 903 participant [1] 323 participate [3] 11232; 136:7; 15530 participated [2] 65:13; 120:16 participation [2] 170:14; 247:16 parties [3] 131; 252:11, 14 parts [2] 101:4 13415 pass [2] 95:7; 217:19 passed [6] 165:14 2147, 8; 215:15; 216:16, 17 passes [1] 214:19 passing [1] 219:1 path [1] 253 Patty [2] 7:12; 83 Pause [5] 1683; 173:17; 199:18; 2073; 232:11 pay [1] 783 paying [2] 93, 7 PCB [28] 39:11, 12, 16, 18; 40:7, 16; 4420; 453, 18; 46:1; 1093; 115:17; 119:11; 12332; 196:16; 197:9; 198:1, 4, 11, 14; 199:5, 13; 202:4 203:12; 204:8; 205:1, 6; 2123 peculiar [2] 9:17; 169:15 PEL [1] 83 penciled [1] 833 pension [1] 29:19 People [1] 49:16 people [68] 2032; 24:1, 10, 21; 25:13; 30:16; 35:3; 37:1; 39:14 58:4; 59:7, 22; 66:14; 683; 70:16; 73.-9; 743; 77:6, 14, 20; 78:1, 11, 18; 82:6; 8832; 893; 9631, 22; 99:19; 116:12; 121:18, 20; 1223; 125:1; 127:10; 128:1, 18; 131:9, 14 133:8; 139:15; 1503, 22; 151:7, 10; 162:12, 19; 1633, 14 166:4 5, 8; 179:13; 186:4; 187:18; 1913, 6; 209:1; 211:11; 212:10; 217:7; 219:3; 220:11; 225:12; 226:13; 230:3, 17; 235:1 percent [3] 121:18; 214:10; 23531 percentage [1] 200:8 perceptions [1] 215:12 perfect [2] 10415; 132:18 period [6] 85:17; 1293, 12, 22; 132:14; 2493 periodic [1] 353 permissible [1] 8:6 permit [2] 41:4; 100:17 permits [1] 10031 permitted [1] 823 persistent [1] 236:12 person [3] 243; 383; 63:14 Personally [1] 211:19 personally [10] 3931; 81:18; 1013; 102:19; 111:9; 142:8; 143:5; 19232; 228:14 244:8 personnel [16] 9414 98:4, 5; 14131; 156:12, 18, 22; 20732; 20930; 210:4, 9, 11, 13; 2113, 6,8 Petroprocessors [1] 153:4 Pharmacology [1] 81:6 Phase [3] 231:1, 4 9 phased [3] 71:3, 5, 8 phases [1] 231:13 phenol [16] 47:17; 49:4; 52:17; 53:8, 9; 548, 10, 16, 17; 553, 11, 13, 16; 56:11, 13; 73:3 phenols [3] 48:10; 49:8 Phoenix [1] 149:17 Phone [1] 184:15 phone [3] 15631; 184:14; 21532 physical [11] 25:7; 35:5; 58:1, 11; 97:14; 1523; 167:4 169:18; 170:5, 18; 213:16 physically [1] 25:15 Physicals [1] 151:10 physicals [3] 9415; 171:15; 183:17 physician [10] 353, 10; 95:11, 13, 20; 97:7; 11330; 1345; 140:19; 141:14 physicians [7] 133; 35:17; 66:11; 8831; 9419, 22; 95:4 pick [1] 55:19 pieces [1] 2830 Pierle [1] 243:19 pipes [2] 88:1, 4 pit [2] 15131; 249:10 Pitot [1] 204:4 pits [2] 173; 15130 Pittsburgh [9] 113; 12:13; 133, 5, 18; 1411; 193; 20:1, 13 place [19] 344; 40:17; 41* 11; 56:8, 18; 75:10, 19; 85:14 90:10; 111:16; 118:8; 127:3; 13032; 165:8; 166* 187-31; 19830; 236:14 placement [1] 233:19 Plaintiff [2] 1:4; 2:7 plans [2] 236:14 246:5 Plant [2] 109:12; 224:6 plant [83] 27:3; 35:10, 17, 20; 41:12; 47:12; 49:16; 63:18; 79:19; 8413; 9419, 22; 95:4, 11, 20; 109:11, 15; 111:3; 112.-8; 119:1; 121:19; 122:7; 1241; 132:1; 13332; 13413, 14, 17; 135:1, 6; 136:5, 8; 13832; 139:15; 140:1, 6, 18, 19; 141:13; 143:1, 16, 18; 144:9, 14 149:11; 153:13; 161:14; 165:6; 171:13; 172:12; 196:7, 13; 198:16, 17, 19; 206:18, 19; 209:15, 18; 210:11, 22; 2113, 3, 5; 214:12; 217:12, 20; 22418; 225:5; 227:1, 20? 228:18, 20; 229:2, 3, 15, 18, 20; 230:8, 13; 239:5; 240:5 plants [45] 13:10, 12, 15; 35:8, 18; 37:18; 41:14; 42:16; 43:4, 5, 6; 51:15; 60:1; 88:14, 15, 17, 19, 20; 95:8, l(k 99:9; 10531; 119:4, 21; 126:11; 128:13, 17, 20; 130:4; 13430; 135:18; 144:4 195:18; 206:12, 14; 214:1; 236:6; 23730; 238:7, 8; 239:7, 12; 240:7, 8 play [1] 210:13 Please [1] 231:16 please [8] 530, 22; 157:6, 11; 173:11; 177:1; 184:9; 223:15 plus [2] 2630; 189:7 PNA [21] 200:5, 6, 11, 22; 201:1, 3, 12, 14, 16; 202:16; 203:18, 20; 2043, 5, 16; 205:12, 22; 206:3, 5, 9 pneumonia [1] 129:18 point [8] 15:16; 71:3; 107:16; 185:6; 20031; 211:19; 220:6; 230:8 points [4] 545; 15832; 1593; 176:8 notice to points HARTOLDMONOOQ9829 BSA somebody [11] 242; 54:15; 77:17; 95:16; 100:15; 126:17; 171:6; 185:12; 188:4, 21; 191:18 somehow [2] 44:18; 12720 someone [15] 44:6; 752; 90:8; 100:14; 102:17, 18; 143:13; 175:10; 18520; 188:3, 22; 189:8; 190:10; 198:14; 244:16 someplace [4] 20:11; 109:14; 194:12; 199:10 somewhat [1] 6:7 somewhere [2] 20320; 211:19 sooner [1] 248:11 sorry [11] 29:1; 472; 70:8; 892; 1062; 112:18; 136:11; 148:15; 168:1; 17221; 174:8 Sort [2] 135:14, 15 sort [15] 9:14; 1220; 31:13; 3422; 47:14; 103:17; 118:13; 124:8; 140:15; 154:14; 159:11; 180:14; 212:19; 217:16; 237:17 sought [1] 99:15 sounding [2] 55:3; 102:10 sounds [1] 22:6 source [3] 69:10; 78:14 116:17 South [3] 7322; 153:12; 1542 south [2] 153:13; 231:7 space [3] 28:12, 13 special [8] 36:10; 64:11, 16; 88:19; 119:13 specialist [2] 31:17, 18 Specialties [1] 245:18 specific [26] 18:3; 4920; 88:15, 18; 89:1; 103:19, 20; 137:19; 139:6; 14822; 169:6; 17021; 17420; 181:22; 18622; 192.-9; 19522; 198:12; 199:12; 200:14; 202:8; 21121; 212:17; 217:6; 224:12; 22622 specifically [8] 112:13; 134:6; 146:9; 17520; 191:14; 19521; 2(0:8; 209:6 specifics [4] 103:1; 15321; 197:10; 249:14 specimen [1] 14:5 speculate [1] 21622 . speculation [1] 1002 spending [1] 104:13 spent [1] 3322 spiU [10] 185:1, 2, 7, 9, 13; 186:8, 13, 17; 187:3 spleen [1] 170:3 split [1] 88:13 spokesmen [1] 69:6 Spraul [10] 140:6, 11, 12, 18; 141:10, 11; 142:4, 12; 224-17, 19 Springfield [6] 121:14; 164:14; 16521; 1662; 172:11, 16 ss [1] 2522 St [7] 1021; 35:11; 95:3, 6; 171:11, 14; 239:15 Staff [11] 177:14, 17, 20; 181:5, 15; 182:4; 183:7; 218:7, 12; 24621; 247:5 staffs [1] 43:3 Depo of George Roush. TR-. M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 Look-See(51) stage [3] 20321; 2272; 231:14 stamp [1] 78:4 stand [1] 195:15 standard [3] 632; 67:4 100:15 standards [1] 10822 standpoint [1] 102:6 stands [1] 219:18 start [5] 9:13; 15:3, 4 192; 221:1 started [17] 19:8; 20:12; 23:4; 26:4 27:17; 2821; 3412; 38:7; 512; 58:18; 65:1; 71:10; 92:1; 162:14; 220:13; 221:4; 23322 starting [3] 20:17; 28:4; 181:6 STATE [1] 1:1 State [1] 30:16 state [18] 39:1; 42:18, 20; 9922; 100:12, 13, 16; 101:10; 102:14, 20; 105:12; 121:10; 130:15; 131:1, 3, 4 143:6, 14 stated [1] 131:4 Statement [1] 241:15 statement [8] 7:6; 18:11; 53:3; 2042; 219:18; 234:19; 241:10; 242:17 statements [1] 120:16 Staten [2] 12.-9, 16 States [1] 2522 stating [1] 180:11 station [1] 7521 Status [1] 23121 stay [2] 29:7; 42:14 stayed [2] 53:7; 198:8 stays [1] 85:3 Steel [1] 13:16 steer [1] 246:13 Steering [1] 242:11 step [2] 122:19; 2282 steps [2] 170-3; 172:8 Sterling [1] 136:8 stethoscope [1] 152:3 sticker [1] 46:11 stock [1] 30:1 stockholder [1] 2921 stocks [1] 126:16 stop [4] 14:6, 13; 23:6; 23321 stored [1] 86:14 straighten [1] 111:14 Street [3] 1:19; 2:4, 11 struggled [1] 236.2 Stryker [2] 191:7, 9 students [2] 26:7; 27:11 Studied [1] 122 studied [4] 71:1; 747, 9; 221:16 studies [46] 202; 51:17; 53.2; 6020, 21; 61.-17, 20; 69:14 743, 8; 81:14 8418; 92:18; 123:14; 1244 147:7, 10; 148:1; 163:8, 12, 21; 16421; 166:19; 201:11, 13, 15, 18, 19, 20, 21; 202:1, 17; 203.-6, 7; 2048; 2062, 5, 6, 12; 230:18; 234:15; 235:3, 15; 23620; 240:9 study [51] 10:15; 13:7; 143; 27:19; 38:17; 47:17; 4822; 4922; 513; 52:17; 53:3, 9; 548, 10; 553, 14, 16; 59:10; 6122; 62:3, 10, 12, 14 68:18; 71:14 73:6, 15, 16; 78:15; 91:19; 923, 15; 113:8; 12121; 1252; 165:19; 166:1; 1923, 16; 193:17; 1942; 195:18; 2023; 20410; 2053; 215:1, 5, 7; 22322; 240:15 studying [3] 51:11; 107:6; 221:15 stuff [1] 1582 stumbled [1] 122:16 Sturgeon [9] 185.-1, 2, 13, 16; 186:8, 13, 21; 187:3, 22 subcommittee [1] 6520 subdivision [1] 150:11 SUBJECT [1] 1:1 subject [16] 1820; 69:8; 841; 98:13; 100:7; 110:10; 12420; 158:10; 169:8; 20420; 206:18; 215:11; 21620; 219:4 2243; 241:14 subjects [1] 205:1 submarine [1] 28:17 Subscribed [1] 251:15 substance [3] 6:10; 1283; 129:8 substances [3] 21121; 212:5; 213:10 substantive [12] 116:7, 13; 11720; 142:14 248:19; 249:3, 13, 16, 19; 2502, 5, 8 substantively [1] 117:1 Substitute [1] 231:4 substitute [3] 56:13; 78:7; 82:13 success [1] 233:3 successes [1] 6622 successful [2] 53:6, 7 sufficient [4] 127:12; 12922; 130:1; 165:10 suggest [1] 225:7 suggested [2] 163:8, 22 suggestion [1] 216:15 suit [1] 149:10 Suite [2] 1:18; 2:5 sum [2] 108:7, 14 summarizing [2] 81:14, 16 summary [2] 193:15, 22 SUPERIOR [1] 1:1 supplied [2] 1842; 1943 supply [1] 12220 support [1] 212:17 suppose [2] 1041; 170:11 supposed [3] 99:12; 1832; 217:13 SURETY [1] 1:8 surgery [1] 25:4 surmise [1] 16821 Surveillance [1] 1693 surveillance [1] 22421 survey [2] 5421; 214:18 suspect [3] 18:14; 208:18; 2143 Swan [1] 153:13 sweaters [1] 127:8 Sweets [10] 207:19, 21; 208:12; 210:12; 211:15; 212:16; 2132, 6, 9; 214:15 switch [1] 222:6 sworn [4] 5:5; 63; 251:15; 252:7 synonymous [1] 145:18 Synthetic [1] 245:13 system [2] 16622; 233:19 Systems [1] 227:8 systems [3] 1943, 15; 227:11 -T- tag [1] 76:3 takes [3] 25:16; 85:8; 107:10 Talk [2] 76:16, 17 talk [33] 38:16; 44:17; 45:13; 59:18; 633; 6622; 72:14 77:3; 7822; 793; 8520; 98:8; 993; 100:15; 101:12, 13, 16; 102:7; 105:10; 109:4; 115:6; 116:18; 13414 135:4 145:15; 181:19; 206:16, 17; 2252; 227:15; 2283, 11 talked [19] 62; 8320; 88:12; 96:18; 101:13; 10222; 1032; 10418, 19; 1052; 1413; 142:6; 153:15; 201:12; 2023; 2033, IQ: 20414 248:15 Talking [1] 238:10 talking [42] 15:3; 28:11; 32:7; 39:13; 43:7; 45:15; 552; 60:7; 69:12; 7120; 73:13; 78:6, 7; 83:19; 85:19; 947; 98:11; 1022, 3, 4 103:11; 10413, 22; 10621; 10921; 1123; 1133; 11521; 117:8; 121:4 123:13; 145:12; 1472; 18921; 20420; 211:15; 2193; 2263, 5, 9; 2383 talks [5] 76:17; 181:4 200:15; 2463, 15 tars [1] 80.-3 taught [2] 19:17; 52:16 teach [1] 19:14 teaching [2] 59:12, 13 team [4] 93:14; 1133, 6; 217:13 teaspoonful [1] 185:15 Technical [1] 23021 technical [2] 7:7; 129:6 Technically [1] 10:11 technology [1] 61:19 teeth [2] 79:8 telephone [1] 155:7 Telling [3] 20820; 209:5, telling [10] 322; 55:6; 208:18; 209:1, 5, 16; 21120; 212:10; 213:8, 13 tells [1] 209:16 ten [7] 25:3; 132:8, 9, 10, 12; 170:1; 222:12 term [3] 145:16, 18; 200:14 terns [47] 16:6, 19; 17:1; 18:3; 28:6, 13; 345; 42:8; 453; 56:15, 20; 57:18; 6419; 6920; 72:12, 16; 783; 80:19; 88:18; 10020; 109:16; 1122; 117:1; 118:13, 16; 122:18, 22; 12416; 126:7; 130:15, 17; 142:3, 4; 143:17; 147:6; 166:16; 18222; 188:1; 1912; 215:12; 216:8, 15; 2172; 237:18; 2402; 247:14; 2503 terrible [1] 235:4 test [10] 50:8; 548, 10; 55:13; 171:10; 20420, 22; 2393,4 testified [1] 5:6 testify [4] 52:6; 150:1, 5, 8 testifying [2] 6.-6, 21 testimony [7] 6:6,11; 8:11; 33:19; 75:16; 252:6, 8 testing [24] 14620; 150:19; 170:16; 171:12; 197:16, 17, 18, 19; 233:6, 8, 12, 22; 23412; 235:6, 17; 2362, 7, 21; 237:4, 18; 238:14; 239:4, 6, 17 tests [3] 56:1; 172:17; 239:19 tetraethyl [4] 823, 10, 14,17 Texas [34] 3520; 37:19; 433; 47:12, 14; 79:19; 80:8; 9520; 132:1; 133:11, 22; 13413; 135:1, 6, 13; 136:5, 8; 140:8, 9; 149:11, 12; 153:4 161:13; 1653; 2243, 22; 2253; 227:1; 229:15, 18; 239:11, 12, 13; 240:14 Thank [1] 250:12 theirs [2] 98:6; 22822 thereafter [2] 234:6; 2523 therein [2] 251:8, 12 thereto [1] 252:14 thicker [1] 137:7 thinking [4] 40:7; 649; 10320; 233:4 third [2] 193:14 243:1 thirdly [1] 228:4 Thomas [1] 2:4 thorough [2] 44:16; 6419 thousand [1] 33:13 Three [1] 9:1 three [10] 920; 6820; 85:10; 91:12; 105:5; 118:3; 14421; 15921; 194:1; 220:14 threshold [1] 542 Throdahl [23] 89:7, 15, 20; 173:15, 16; 1742, 4, 10, 16; 17920; 180:1, 4, 21; 181:7, 17; 182:12, 13, 20; 218:6; 221:3, 6; 232:1 throwing [2] 27:5, 9 thrust [1] 692 Thursday [1] 1.-14 timeframe [3] 60:11; 86:16; 165:17 Times [5] 104:16, 17, 18, 20, 22 times [8] 6:17, 18; 25:3; 132:3, 4; 13821; 1392, 4 timing [2] 362; 21721 tiny [1] 17820 title [2] 6415, 21 titles [1] 64:9 TLV [6] 54:1, 9; 59:13; 66:3; 79:1, 2 Tom [1] 222:15 tool [1] 86:6 topics [1] 7:7 torture [1] 204:6 total [3j 108:7, 14 181:12 Toth [1] 15821 touched [1] 116:15 touring [1] 13420 towards [1] 92:1 tox [1] 223.-6 Toxic [1] 129:3 From somebody to Toxic HARTOLDMON0009830 BSA Depo of George Roush, TR., M.D. Monsanto v Aetna February 18, 1993 Cr.54456.0 __________ Look-See(52) toxic [15] 24:10; 128:19, 21, 22; 129:6, 8, 21; 145:15; 146:15; 194:15; 195:15; 197:14, 15, 21 toxicity [10] 126:10; 128:12, 16; 129:4, 13; 130:15, 17; 146:11, 16; 147:15 toxicological [1] 120:17 toxicologist [4] 116:19; 147:18, 20; 222:19 toxicologists [10] 222:11, 14, 16, 17, 18; 223A 7; 228:5; 244:10, 17 Toxicology [3] 81:7; 96:10; 197:20 toxicology [54] 7:15, 18; 14:3; 21:10; 22:1, 4; 23:19; 24:5; 31:16; 38:4, 8; 6521; 81:12; 82:21; 91:5, 10, 18, 19, 20; 92:5, 7, 15, 17; 93:4, 7, 20; 96:14; 97:11; 120:21; 130123., 22; 146:19, 20; 147a 10; 183-21; 197:16, 18; 220:7; 221:10, 11, 13, 17; 222:8, 9; 225:18; 233:5; 2342, 14; 235:8; 236* 239:4, 17 trade [1] 172:5 Training [2] 16:13; 17:8 training [14] 14:15, 20; 1522; 16:3, 16; 17:9, 10, 12, 18; 18:1; 22:7; 36:16; 65:3; 248:16 transcript [2] 46:13; 55:6 transcription [2] 251:7, 11 translating [1] 181:9 trauma [1] 24:9 traumatic [1] 1320 Travelers [5] 2:13; 5:11; 190:17, 19, 21 treating [1] 27:4 treatise [1] 7:15 treatment [2] 227:12, 13 Trench [1] 231:1 trial [1] 153:3 trouble [6] 20:5, 22; 24:1, 3; 180:3; 191:17 true [5] 15:1; 27:8; 135:18; 251:6, 10 truth [1] 6:5 Tulane [3] 21:18; 25:11; 27:11 ' Turkey [1] 59:19 Twenty [1] 121:17 twice [2] 30:10; 139:5 twist [1] 170:12 type [6] 154:17; 16420; 18821; 208:9; 219:8; 246:18 types [2] 130:3; 15220 -U- U.S. [1] 13:16 uh-huh [1] 521 ultimately [1] 236:17 unacceptable [1] 53:11 unclear [1] 60:11 understand [40] 5:17; 15:15, 16; 1821; 3920; 44:12, 15; 45:10; 5022; 54:4, 6; 60:9; 77:10; 7821; 91:17; 98:16; 104:5; 107:14, 15; 1142; 115:12; 116:6; 119:16; 123:7, 8; 130:8, 13; 134:8, 9; 141:1; 142:3; 177:10; 18121; 198:10; 1992; 202:22; 206:4; 237:13; 239:10; 248:17 understanding [6] 3922; 55:8; 74:18; 121:11; 129:7; 1572 understands [1] 130:11 understating [1] 124:17 understood [2] 43:17, 21 undertake [2] 106:15; 107:18 unfolded [1] 233:16 uniformly [2] 233:7; 235:18 union [2] 121:15; 212:6 unions [1] 122:3 unit [6] 14:3; 94:7; 111:12; 146:5; 161:19; 211:11 United [1] 2522 units [7] 145:10; 236:5, 8, 11, 14, 18; 237:3 University [18] 9:15; 10:6, 20, 21; 11:3, 9; 12:12; 13:5; 14-11; 19:8; 20:1, 13, 18; 21:1, 4; 23:7; 30:17; 91:15 unknown [1] 21021 Unleaded [1] 762 unleaded [1] 76:11 unusual [2] 96:13; 163:16 upper [1] 2322 uranium [1] 85:13 Urinary [1] 48:10 urinary [11] 47:17; 5Z-17; 53:8, 9; 547, 10, 16; 552, 11, 16 urine [2] 48:11; 495 useful [2] 160:19; 2362 usefulness [1] 55:11 utility [1] 127:15 - V- vague [7] 48:3; 50:1; I 51:6; 57:8; 83:12; 87:9; 144:10 value [1] 542 Vanderbilt [1] 30:17 varied [1] 3422 vast [1] 114:18 VCM [3] 16520; 169:11; 172:10 ventilation [1] 128:3 verbal [1] 520 versus [2] 145:19; 228:12 vessels [1] 163:1 veterinarian [1] 223:7 veterinarians [1] 223:4 Vice [2] 89:9, 10 vice [3] 89:11, 13; 221:7 view [3] 49:3; 128:11, 15 vine [1] 16922 Vinyl [2] 16121; 169:10 vinyl [13] 161:11; 162:4, 7, 12; 163:3, 8, 22; 16412; 166:19; 167:15; 16921; 170:7, 21 virtue [1] 2462 visit [11] 132:1, 13; 134:3; 13821; 1392; 14920; 150:3, 13, 17; 152:9, 13 visited [4] 138:19, 21; 153:7, 16 visits [2] 13321; 22920 visual [1] 15822 volume [1] 233:12 vs [2] 1:6; 215:10 -W- Wait [1] 190:16 wait [1] 1249 walk [1] 2421 walk-through [2] 1352, 3 Walked [1] 134:14 walked [9] 25:3; 138:11, 18; 139:7, 16; 142:7; 154:13; 172:11; 230:7 walking [1] 15411 wall [1] 231:7 walls [1] 2315 WALSH [86] 25; 5:8; 462, 6, 17; 48:4; 502, 20, 21; 515, 4, 8; 52:7; 53:13, 16, 19; 57:10, 14 6322; 645, 6; 83:14 852; 87:11; 98:19, 20; 100:3; 117:16, 18; 125:5; 126:3, 5; 133:18; 136:16, 22; 137:8, 11; 144:12; 14521, 22; 157:6, 10; 158:4, 5; 167:7, 10, 17; 168:8; 1732, 6, 9, 14, 18; 176:15, 19; 177:1, 4, 8; 184:4, 8, 11; 19120; 192:1, 12; 199:15, 19; 20620; 207:10, 13; 212:15; 21921; 220:4, 5; 223:10, 13, 19; 231:15, 19; 232:13; 2402ft 2412, 11; 242:9; 248:8, 13; 250:11 Walsh [3] 3:4 5:10; 212:13 wanted [14] 37:19; 49:10, 15; 50:11; 8422; 98:8; 14622; 175:8; 181:16; 182:14, 20; 185:10; 217:19; 219:12 wants [2] 35:6; 115:6 washer [1] 179:11 washing [1] 166:12 Washington [7] 2:6, 12; 5:11; 10:6, 21; 39:6; 91:15 Waste [2] 143:15; 227:7 waste [34] 1421; 1522; 16:19, 20, 21; 172, 6, 7; 27:5, 9, 14 39:1ft 40:11, 12; 111:6; 142:15; 143:3, 7, 14, 17, 19; 1445; 145:18; 146:3; 192:5, 16; 193:17; 195:5; 196:3, 6; 227:11; 249:3, 14 wastes [1] 19320 Water [1] 24421 water [11] 15:10; 39:19; 87:8, 13, 14 140:3; 142:15; 14419; 145:12; 154:13; 225:10 Ways [1] 235:10 ways [2] 200:8; 203:19 weighing [1] 14415 wells [1] 228:15 weren't [16] 31:10; 6417; 82:6; 12422; 133:8; 189:19; 1992; 229:10; 230:14 233:18; 235:11; 240:8, 16; 242:13; 245:8; 247:10 West [1] 231:3 west [2] 22922; 231:10 Wheeler [11] 37:4, 6, 15; 39:13, 21; 90-3, 6, 8; 96:19; 115:17; 119:11 Whereupon [3] 52; 125:6; 250:15 wherever [1] 119:15 whoever [1] 240:10 Wildlife [1] 245:16 Wiley [2] 2:10; 5:10 Wilmington [1] 1:15 wine [1] 742 Wisconsin [6] 9:15, 20; 10:3, 4 20; 30:17 withhold [1] 240:16 WITNESS [18] 32; 643; 121:3; 133:16; 136:13; 1582; 167:15; 168:6; 173:13; 177:3; 192:11; 207:3, 6, 12; 223:18; 232:8, 12; 241:9 Witness [17] 2822; 46:16; 13621; 158:1; 167:14; 173:12; 177:7; 178:6; 184:10; 192:10; 2072, 11; 223:17; 232:7; 241:8; 251:14; 252:16 witness [4] 622; 7:3; 252:6, 8 women [1] 2417 words [16] 54:18; 56:13; 60:15; 6416, 18; 65:13; 66:7; 67:3; 72:12; 79:13; 85:4; 9422; 131:4; 170:14; 1903; 192:14 Work [1] 247:16 work [110] 1122; 12:17; 1320, 21, 22; 22:13; 23:17; 241, 12, 15; 25:11, 14, 16; 30:7, 11, 13; 3120; 33:8; 36:4 21; 37:15; 383, 12, 19; 39:1, 10, 12, 21; 402ft 41:1, 3; 42:11; 44:1; 453; 4721; 52:14 5322; 6415, 19, 20; 653, 9; 67:15, 16; 6821; 693, 22; 723; 73:18; 7412, 19; 79:12; 88:18; 902, 5, 11; 963; 9722; 982; 1013; 102:13; 111:6; 11420; 1222; 130:12; 131:9; 140:4 141:10; 142:4 8; 148:17; 152:7; 1533; 154:1; 156:11, 17; 159:6; 171:18; 176:12; 18321; 1913, 12; 19221; 196:6, 12, 15; 198:1; 199:12; 2172; 218:14; 219:19; 225:4 228:14, 18; 2303; 237:7; 240:7; 243:8, 14, 16, 20; 2448, 13, 18, 2ft 245:6; 246:10, 18 workable [2] 236:1ft 237:8 worked [19] 2422; 35:3; 37:21; 38:3, 14 47:12; 582; 5922; 63:16; 6822; 7320; 90:14 99:15; 119:19; 1223; 16414 197:6; 213:17; 222:15 worker [17] 246; 2522; 52:18; 106:6; 108:13; 110:4, 11; 113:17; 120:9; 134:18; 141:17; 16922; 195:11; 20821; 209:11; 225:14 Workers [2] 1693; 190:18 workers [43] 13:19; 26:19; 41:6, 8, 15; 51:10; 5321'549; 57:7, 21; 62:12; 106:18; 107:1, 19; 108:11; 110:14 1242; 125:3; 127:17; 162:18; 163:17; 16411; 1653; 16i,169:12, 15, 18; 17024 172:17; 195:3; 209:5, 14 210:10, 14, 17; 211:9; 21222; 2148; 216:16; 218:11; 2263, 7, 13 Working [1] 23:10 working [33] 15:1, 21; 162, 15; 17:11, 22; 27:18; 413, 11; 45:6; 49:16; 59:7; 62:4 80:19; 8620, 22; 8821; 92:1, 18; 93:16; 95:1; 107:1; 133:8; 135:5; 140:15; 163:3; 220:10; 221:12; 222:19; 22415, 17; 231:13; 246:15 workplace [3] 2521; 49:11; 18222 works [4] 63:14 7121; 8413; 16622 world [5] 45:14 7321; 77:13; 82:8; 132:19 worldwide [2] 119:11; 16020 worried [3] 15:6; 59:12; 11320 worry [9] 15:10; 28:4; 59:15; 107:9, 12; 113:11; 120:6; 1242 worse [1] 25:3 worthwhile [1] 85:1 wouldn't [25] 9:8; 62:8; 63:6; 82:9; 83:3; 105:7; 109:18; 146:13; 159:13; 176:5; 180:7, 8; 18820; 190:7; 193:1; 194:11; 195:4, 5; 226:18; 227:3; 228:17, 19; 24417 write [2] 12021; 21722 writes [1] 66:3 writing [5] 83:8; 10822; 120:16; 160:13; 208:9 writings [1] 208!7 written [3] 81:15, 16; 174:1 wrongly [1] 15:19 wrote [8] 10* 81:6; 8220; 83:5, 10; 170:22; 179:8; 219:19 WWG [2] 160:6, 21 Wye [1] 153:4 -Y- year [21] 10:9; 11:14, 16, 21; 20:9; 29:10, 12; 30:5; 3521, 22; 36:3, 12; 39:9; 402, 20; 412; 441; 58:1; 94:8; 169:19; 222:6 yearly [1] 16621 years [23] 9:20; 18:15; 19:7; 21:14; 60:15; 71:3; 85:10, 11; 91:1, 4; 92:10; 96:17; 105:5; 114:17; 149:15; 1552; 170:1; 20020; 220:14, 15, 19; 236:9; 24721 Yesterday [1] 8:19 York [1] 30:16 yours [4] 1920; 137:2, 6; 15922 Yourself [1] 76:1 yourself [2] 22:5; 142:14 ________ -Z- zeal [1] 4820 toxic to zeal HARTOLDMONOOQ9831 KUL4& ftp u ` , c,0i CORRECTIONS TO DEPOSITION Monsanto Company vs. Aetna Casualty & Surety Company, et a.1. Page 13 Page 14 Page 15 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32 Page 33 Page 35 Page 38 Page 41 Page 42 Page 44 Page 48 Page 49 - Lines 15 , 16, 18 - Lines 3, 4 - Lines 6, 19 - ' Line 2 - Line 7 - Lines 9, 21 - Lines 2, 4 - Lines 9, 10 - Lines 13 , 14 - Lines 3, 4 - Lines 4, 20, 21, 22 - Lines 1, 4, 5, 15, 17, - Line 13 - Line 10 - Lines 6, 7 - Lines 3, 9 - Line 13 - Lines 5, 8, 9 - Line 5 - Line 9 - Lines 4, 5^ 6, 7 - Line 20 - Lines 11 , 20 - Lines 5, 7, 8 HARTOLDMONOOQ9832 (reofye. KoiAzH , 2- - Page 50 -- Page 53 Page 57 Page 59 Page 62 Page 63 Page 64 Page 66 Page 70 Page 73 Page 75 Page 95 Page 106 Page 107 Page 108 Page 113 Page 115 Page 123 Page 124 Page 125 Page 126 Page 127 Page 128 Page 129 Page 130 Page 131 - Lines 5, 6, 12 Line 22 Lines 12, 13 Lines 11, 13, 19, 20 Lines 3, 8, 18, 19 Lines 9, 10, 11, 12, 13, 14 Line 8 Lines 2, 9, 20 Line 22 Lines 12, 13 Line (12 Line 16 Line 18 Line 8. ' Line 2 Line 21 Line 19 Lines 14, 15 Lines 6, 8 Lines 1, 2, 4 Line 14 ' Lines 8-, 9, 10, 20, 21, 22 Lines 1, 3, 4 Lines 3, 4, 17, 18 ` Line 22 Line 4 ' ` o / / / /^. HARTOLDMONOOQ9833 i^-eoH^e KotAsn f / /vt./y, / `--t*j ' t'/ / / / Page 138 -- Line 18 Page 147 - Line 2 Page 148 - Lines 8, 9 Page 162 - Lines 12, 15 Page 163 - Lines 2, 15 Page 164 - ' Line 13 Page 165 - Lines 7, 10 Page 189 - Line 22 Page 198 - Line 5 Page 200 - Lines 7, 8 Page 201 - Lines 16, 22 Page 202 - Lines 12, 13 Page 210 - Lines 6, 15 Page 226 - Lines 11, 19 Page 228 - Line 1 Page 230 - Line 10 Page 237 - Line 13 Page 239 - Line 9 HARTOLDMONOOQ9834