Document MMD0rEQwGzvJjDEwRdoKgY4Vy

1 1 1 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS 2 3 STATE OF MISSOURI 4 5 6 CECIL SCOTT, et al., 7 8 Plaintiffs, 9 10 vs Cause No. 902 02008 11 12 MONSANTO COMPANY 13 14 Defendant. 15 16 17 DEPOSITION OF R. EMMET KELLY, M.D., produced, 18 sworn and examined on behalf of Defendant, October 24 and 19 25, 1990, between the hours of eight o'clock in the 20 forenoon and six o'clock in the afternoon of that day, at 21 the offices of Communitronics Corporation, 1907 South 22 Kingshighway, St. Louis, Missouri, before FAITH A. 23 OLLIGES, a Registered Professional Reporter and a Notary 24 Public within and for the State of Missouri. 25 WATER PCB-SD0000032952 2 1 2 3 APPEARANCES 4 5 The Plaintiffs were represented by Mr. Joseph 6 Murray of the Murray Law Firm, 650 Poydras Street, Suite 7 1450, New Orleans, Louisiana 70130. 9 The Defendant was represented by Mr. Thomas M. 10 Carney and Ms. Carol A Rutter of the law offices of Husch, 11 Eppenberger, Donohue, Cornfeld & Jenkins, 100 North 12 Broadway, St. Louis, Missouri 63102. 13 14 Also present was Ms. Marie Schneider, 15 videographer. 16 17 18 19 20 21 22 23 24 25 WATER PCB-SD0000032953 3 1 IT IS HEREBY STIPULATED AND AGREED by and 2 between Counsel for the Plaintiffs and Counsel for the 3 Defendant, that this deposition may be taken in shorthand 4 by FAITH A. OLLIGES, a Registered Professional Reporter 5 and Notary Public, and afterwards transcribed into 6 typewriting. 7 8 oOo 9 10 R. EMMET KELLY, M.D., 11 of lawful age, being produced, sworn and examined on the 12 part of the Defendant, deposes and says: 13 DIRECT EXAMINATION 14 QUESTIONS BY MR. CARNEY: 15 Q. Would you state your name, please, for the 16 record? 17 A. R. Emmet Kelly. 18 Q. And where do you live? 19 A. 665 South Skinker, St. Louis, Missouri, 20 63105 . 21 Q. And how long have you lived in St. Louis? 22 A. All my life with the exception of three and a 23 half years in the service. 24 Q. And are you a medical doctor? 25 A. Yes, I am. WATER PCB-SD0000032954 4 1 Q. Tell the jury whether you've ever been 2 employed by Monsanto. 3 A. I originally was employed as a plant 4 physician in January starting in January of 1936. I 5 stayed there in that capacity with some added duties until 6 I went in the service in March of 1942. I returned in 7 February or March of 1946 with the position as Medical 8 Director of a newly formed Central Medical Department. 9 Q. And this was employment at Monsanto? 10 A. All at Monsanto, yes. 11 Q. So you were employed byMonsanto foralmost 12 40 years? 13 A. Yes. I was part time until the service and 14 then full time on my return from the service. 15 Q. Would you tell the jury, Dr. Kelly, your 16 educational and professional background 17 A. Yes. 18 Q. starting with college? 19 A. Yes. I received a Bachelor ofScience degree 20 from St. Louis University, received an M.D. degree in 21 1932. I spent three years as intern, assistant resident 22 and resident of medicine at St. Louis City Hospital. I 23 have taken quite a few one and two week courses in either 24 internal medicine or in occupational medicine since that 25 time. WATER PCB-SD0000032955 5 1 Q. And where did you do your internship and 2 residency? 3 A. St. Louis City Hospital in St. Louis. 4 Q. And that was for howlong? 5 A. Three years. 6 Q. And for what period of time have you been 7 licensed by the State of Missouri as a medical doctor 8 authorized to practice medicine? 9 A. Since 1933. 10 Q. And are you licensed in any other state other 11 than Missouri? 12 A. I'm licensed in Illinois. I was licensed in 13 Arizona, but I dropped that. 14 Q. Doctor, could you explain what it means to be 15 board certified? 16 A. Board certifiedmeans that you are approved 17 as a specialist by a group of individuals set up in that 18 particular specialty and approved by the American Medical 19 Association. It means that you have to have certain 20 qualifications to be able to take that examination, a 21 certain amount of training. You then have to submit to 22 two examinations, a written and an oral examination, and 23 after that is done you are accepted as a specialist by 24 your peers. 25 Q. Are you board certified in any medical WATER PCB-SD0000032956 6 1 specialty? 2 A. I'm board certified in internal medicine. I 3 was originally in 1955, and I was recertified, I believe, 4 in 1964. I was certified in the specialty of preventive 5 medicine with a subspecialty of occupational disease in 6 either 1955 or 1956. 7 Q. What is internal medicine? 8 A. Internal medicine is that branch of the 9 general field of medicine that relates to the non surgical 10 treatment and the diagnosis of diseases in the post young 11 child age, the post pediatric age. 12 Q. So you diagnose adult illnesses primarily in 13 that specialty? 14 A. Adolescents and adults. 15 Q. What is occupational medicine? 16 A. It's that branch of medicine that deals with 17 the examination and treatment and prevention of disease in 18 the working community in relationship to its working 19 environment and to its outside environment. 20 Q. Doctor, could you briefly summarize for us 21 what hospitals you're on the staff of and any teaching 22 positions you have held or hold? 23 A. Well, I'm an emeritus assistant professor of 24 political medicine at St. Louis University as well as an 25 assistant professor of community medicine at St. Louis WATER PCB-SD0000032957 7 1 University. I'm on the staff of St. John's Mercy Medical 2 Center, the University Hospital of St. Louis University, 3 and St. Mary's Health Center, all in St. Louis. 4 Q. And have you been a professor in any school 5 of medicine? 6 A. Assistant professor at St. Louis University 7 School of Medicine. Q. Have you given lectures at any other 9 universities? 10 A. I've given lectures on occupational medicine 11 at Baylor, Harvard, Washington University, University of 12 Cincinnati. 13 Q. Have you published any articles on medical 14 subjects? 15 A. Well, yes. I published four that I recall. 16 Q. Okay. What publications did you publish 17 articles in? 18 A. Well, the "New England Journal of Medicine," 19 the "American Public Health Journal, " the "National Cancer 20 Institute Journal," and the "Missouri Medical Association 21 Journal". 22 Q. Could you please summarize some of the 23 professional organizations that you belong to or have 24 belonged to? 25 A. Well, I'm a fellow of the American Medical WATER PCB-SD0000032958 8 1 Association. I'm a member of the American Society for 2 Clinical Therapeutics and Pharmacology. I'm a member of 3 the American Heart Association, Industrial Medical 4 Association, the American Academy of Occupational 5 Medicine, and the usual A.M.A., American Medical 6 Association, St. Louis Medical Society, and the Missouri 7 Medical Association. 8 Q. Have you held any offices in any of those 9 organizations ? 10 A. Well, I was the assistant chairman of the 11 board of the American Society for Pharmacology and 12 Therapeutics, and it was called the American Therapeutics 13 Society at that time. 14 Q. How old a man are you, Dr. Kelly? 15 A. I'm 80. 16 Q. Are you still active in the practice of 17 medicine? 18 A. Yes. In the field of occupational medicine I 19 am. I'm not doing general internal medicine with the 20 exception of seeing the occasional consult that has a 21 bearing on an occupational condition. I'm an associate 22 physician of the Barnes Sutter Health Service in St. 23 Louis, which is the oldest and largest occupational clinic 24 in St. Louis. It's associated with Barnes Hospital, which 25 is the teaching hospital of Washington University and WATER PCB-SD0000032959 9 1 probably one of the top five rated hospitals in the United 2 States. 3 Q. Have you been a consultant for any other 4 company other than Monsanto? 5 A. I was a consultant for the Consolidated 6 Aluminum Company for about ten years. I was sort of the 7 medical director there, although I was listed as a 8 consultant, and I retired from that in January of this 9 year. 10 Q. Okay. Let's get back to your employment at 11 Monsanto. I believe you indicated you were a part time 12 employee when you started in 1936? 13 A. Yes. May I make a suggestion? I did not 14 mention that I had been a member of and chairman of the 15 Medical Advisory Committee of the Manufacturing Chemical 16 Association. I was a consultant for the Poison Control 17 Center in Washington, and I had been a chairman of the 18 medical committee of the National Agricultural Chemical 19 Association. 20 Q. Okay. Thank you, Doctor. What were your 21 duties, your job duties, when you first started work at 22 Monsanto back in 1936? 23 A. Well, I was a company physician at this one 24 plant. It was mainly the treatment and diagnosis the 25 diagnosis and treatment of occupational injuries and any WATER PCB-SD0000032960 10 1 occupational conditions that were there, and I carried out 2 a preventive medical program that consisted of examining 3 the working environment of the plant as well as physical 4 examination program for the workers. 5 Q. And that was at what plant? 6 A. Plant A or the St. Louis plant. 7 Q. Was that also called the Queeny plant? 8 A. Later on. When I started, it was A. Public 9 relations people later changed it. 10 Q. When did you officially become Monsanto's 11 Medical Director? 12 A. Officially in probably March of 1946, 13 although from around '38 till '42 when I went in service 14 I was sort of Medical Director without a portfolio. 15 Q. What branch of the military were you in when 16 you served in the military during World War II? 17 A. Well, most of the time I was I was with a 18 medical department, Medical Corps they called it the 19 Medical Corps at that time all the time. But I was 20 stationed at two chemical warfare arsenals: the first at 21 Pine Bluff, Arkansas, and the second at Edgewood Chemical 22 Center, which was the research branch of the Chemical 23 Warfare Service, as well as they had a production plant 24 there where they manufactured war gases and other chemical 25 warfare agents. WATER PCB-SD0000032961 11 1 Q. And that was in the Army? 2 A. Yes. 3 Q. The Medical Corps? 4 A. Yes. 5 Q. In whatcapacity did you return to Monsanto 6 after the war in 1946? 7 A. As Medical Director of the Director of the 8 Central Medical Department. 9 Q. And what were the duties that you had as 10 Monsanto's Medical Director? 11 A. Well, I was supposed to set up My duties 12 included setting up a medical organization in each of the 13 plants. At that particular time, we might have had 15, 20 14 plants. So it was to see that each plant had a medical 15 organization. Of course, it varied with size. Secondly 16 was to obtain toxicological information on all our raw 17 materials and our products in order to prevent any injury 18 to the workers or the customers who used Monsanto 19 products. And, number three, I was to set up an 20 industrial hygiene survey of the various plants. 21 Industrial hygiene means that you check by analytical 22 means the presence of any contaminants in the air. 23 Q. Was one of your duties to supervise all of 24 the plant doctors at all the Monsanto plants? 25 A. Yes. The plant doctors, they varied a great WATER PCB-SD0000032962 12 1 deal in the amount of their time they spent. As it turned 2 out, in some of our larger plants we had two or three 3 full time doctors. In some of the small plants where we 4 only had 40 or 50 people, the doctor was just an 5 individual whom we sent people to for examinations and 6 treatments. But, yes, it was to survey, to supervise the 7 documents, supervise our medical departments. 8 Q. Would you please define for the jury the term 9 "toxicology"? 10 A. Toxicology is that science that determines 11 the harmful or unwanted effects of a product. 12 Q. What size company was Monsanto when you first 13 went to work there in 1936? 14 A. Probably five to 6,000 people with about 15 seven plants and sales of $80 million a year. 16 Q. During youryears atMonsanto, did you 17 implement any policies or practices to help promote 18 product safety? 19 A. Oh, yes. 20 Q. Could you 21 A. Well, I would say that the two main ones were 22 that we obtained information on any possible harmful 23 effects of our products to people who came in contact with 24 them, either worked with them or used them. Number two, I 25 was responsible for disseminating this individual I WATER PCB-SD0000032963 13 1 mean this information to the individuals, the management 2 of the people who used these products. 3 Q. When you say you obtained all the information 4 on the products, how did you go about doing that? 5 A. Well, it all depends on the product. In 6 other words, if we made Product A and it was used had 7 been made previously by Product B by other companies, 8 in other words, we were a "me too" company, we started to 9 manufacture something that had already been existing, I 10 would call the medical directors of these other companies 11 and say, "We're going to start making this stuff. Have 12 you had any problems with it? What do you know about it?" 13 And I would get information from that. That was a very 14 It was a very free give and take among industrial 15 physicians as far as product safety is concerned because 16 what hurts one hurts all. So that was easy if the product 17 had been in use. 18 Number two, if there were We went through the 19 medical literature to find out whether any toxicity 20 information existed on it. Now, that varied in the early 21 days, 1938, 1945. There wasn't an awful lot of 22 toxicological information around. But still we went 23 through that. There were government publications on some 24 of the products. There was some information in the 25 medical literature. And third, as a last resort, if there WATER PCB-SD0000032964 14 1 wasn't anything known, we had animal experimentation done 2 at outside laboratories. 3 Q. When you went about trying to obtain all the 4 information you could about Monsanto products, would that 5 entail looking at all the scientific and medical journal 6 articles that were available? 7 A. Oh, yes. All those things are indexed, and 8 you check it out in the index to see if there's anything 9 available. 10 Q. Did you as Medical 11 A. And the third thing I mean, a fourth thing 12 which was sort of important on new products was the 13 information you received from the individuals who were the 14 research people who were working in the laboratories with 15 these things, whether they had any rashes, ill effects or 16 any harmful effects or noticed any symptoms while they 17 were working at the laboratory bench with these products. 18 That was quite imped any symptoms while they 17 were working at the laboratory bench with these products. 18 That was quite important because here we've got a new 19 product, nobody knows anything about it, and the first 20 people who are exposed to it are the laboratory workers. 21 Q. Did you have any practice with regard to 22 visiting the various plants of Monsanto while you were 23 Medical Director? 24 A. Yes. 25 Q. What was that? WATER PCB-SD0000032965 15 1 A. Well, I went at least once a year. If there 2 were anything important, either of a personnel matter or 3 any other problems, that could be oftener than a year. 4 Sometimes it was twice a year. Could be oftener. At the 5 time of our Texas City explosion where the ship blew up 6 outside our Texas City plant, I was down there probably a 7 half dozen times. Some of the smaller plants If we had 8 a plant that was making cocoa butter or something like 9 that, with 40 people, it might be every two years. But I 10 tried to do it every year. 11 Q. To each plant? 12 A. That's correct. 13 Q. Did you have any policy 14 A. With the one exception in the early days I 15 did not go to the We had three plants in England, and I 16 didn't go there until later on. 17 Q. Did you have any policies while you were 18 Medical Director from the early '40's until you retired in 19 1974 about periodic physical examinations of the plant 20 workers ? 21 A. Yes. Well, some of the plants already had 22 it. The plant at which I started in St. Louis, the Queeny 23 plant or Plant A, did have a medical program of examining 24 people, and that continued. I instituted it in the other 25 plants, especially some of the plants that came into the WATER PCB-SD0000032966 16 1 Monsanto organization through buy out or almalgamation or 2 something of the sort. 3 Q. Would you have annual physical exams at most 4 of the plants? 5 A. Well, it all depends on the ages. If the 6 person got up to 40, it might be every two to three years. 7 If they got up to 50, it would be every 18 months to two 8 years. If the man were over 50, it would be annually. 9 Some of the departments where we thought a hazard might 10 exist, regardless of the age it would be once a year, 11 sometimes oftener even. 12 Q. What did you do with regard to industrial 13 hygiene? Did you do any kind of a survey of the plants in 14 that regard? 15 A. When I first came with Monsanto, I went 16 through all the plants. It was important to know how a 17 man is working and what products he's working with and 18 what his particular exposure is. If he's in a plant 19 similar to an oil refinery, for example, where everything 20 is inside a pipe and it's out in the open, there isn't an 21 awful lot of exposure because no matter how toxic a 22 product is, if the man isn't exposed, he hasn't got any 23 problem. So I went through the plants and watched the men 24 at work. I would go through with either the safety man, 25 and in each department the manufacturing superintendent of WATER PCB-SD0000032967 17 1 that department, and he'd tell me what the raw materials 2 were and showed me the various steps in the procedure of 3 the plant so I could familiarize myself when somebody came 4 in and said, "I was working with paracloranaline, and it 5 did this and this. Is this liable to be serious?" I'd be 6 able to know exactly how he worked. Well, then 7 afterwards, I recognized the fact that I'm not a chemical 8 engineer and there needed to be more of an engineering 9 aspect to these inspections, and there needed to be more 10 of an analytical method. In other words, if there's some 11 dust in the plant, we had to find out what kind of dust it 12 was and how much the man was exposed to. So at that 13 particular time we engaged a man who had been an 14 industrial hygienist in one of the New England states, a 15 Mr. Elmer Wheeler. That was about 1947 I think, around 16 then. And he was an industrial hygienist. He did this 17 work. He went around to the plants on frequent 18 inspections or regular inspections. So that industrial 19 hygiene aspect grew. I think when I left we had four 20 people. When I left in '74, we had four industrial 21 hygienists. 22 Q. And Dr. Wheeler was the first one? 23 A. It's a Mr. Wheeler. He had a Master's or 24 something like that. 25 Q. Okay. And did you also add toxicologists to WATER PCB-SD0000032968 18 1 your Medical Department staff when you were 2 A. Yes. When I came in, in the early days there 3 were very few people that were called toxicologists. They 4 were usually pharmacologists or something like that. Now 5 they have people that are specialized in the toxicological 6 discipline, but they are basically pharmacologists. 7 Pharmacologist is a person who understands how chemicals 8 work on the body. That's really And that's what a 9 toxicologist is mainly, too. So, yes, after the 10 toxicological interest became quite prominent we engaged a 11 toxicologist, and that was later. I guess that was in the 12 '50's. And when I left, I believe we had four, three or 13 four toxicologists, and we had started planning to do 14 our to build our own toxicological laboratory. I left 15 in '74, and I think the building, the laboratory, was 16 finished in '75 or '76, and God knows they have probably 17 ten toxicologists now. 18 Q. Was there any policy at Monsanto while you 19 were Medical Director as to what would happen if somebody 20 inquired about a product or any health problems with a 21 product? 22 A. Yes. At first, in the days before the war 23 when I was part time, it was mostly on an informal basis. 24 After the Here I was in this one plant, the Queeny 25 plant building here. Here's the general office right next WATER PCB-SD0000032969 19 1 to it. Well, there wasn't too much contact at first 2 between myself and the people in the general office, but 3 as they got to know that there was a doctor over at the 4 Queeny plant and they would get in a question related to 5 health aspects, they were very happy to either buck this 6 letter down to me or call me up and say, "What about 7 this?" Well, when I came back after the service and the 8 Medical Department was set up, one of the directives from 9 the executive committee, the group that ran the company, 10 was that any toxicological question or any question 11 relating to health matters would be handled by the Medical 12 Department. In other words, if a salesman out of Detroit 13 office got a call from Fort Ord that we were using this 14 particular oil in our hydraulic system, what's the 15 toxicological problems that might be associated with it, 16 that would be bucked to St. Louis. So all telephone calls 17 that came into 18 Q. I thought to St. Louis. 19 A. To the St. Louis office, to me, or to the 20 Medical Department. And that situation obtained through 21 all the time I was with Monsanto and may very well still 22 do still occur. All letters that went out to customers 23 and to doctors, private doctors, who would write up, write 24 in, and all telephone calls were handled by the Medical 25 Department. WATER PCB-SD0000032970 20 1 Q. What about information such as safe handling 2 information that went out from Monsanto? Was there any 3 policy on approval with regard to that information? 4 A. Any publication that dealt with the 5 toxicological problem aspects or properties of a 6 Monsanto product or any safe handling procedures with the 7 exception of safe handling procedures for fire or 8 explosion, which were carried out by the Safety 9 Department. But anything as far as the safe handling of 10 the material from the medical aspect was approved by the 11 Medical Department. It was either written by It was 12 most of the time written by the Medical Department. It 13 could be changed in the sense of a lay out or something in 14 a publication or on a label, but there could be no change 15 in the 16 Q. Wording? 17 A. Wording of the material. 18 Q. Could you define the term "toxicity"? 19 A. Well, toxicity is the potential of a compound 20 to do harm to people, to animals or people. It's a 21 property that exists in everything depending upon how it's 22 used. In other words, salt, which is used Every 23 compound has a certain amount of toxicity, but it's the 24 amount of use, it's how it's used and the exposure that a 25 person has that really is the important thing. For WATER PCB-SD0000032971 21 1 example, butter is certainly not considered a toxic 2 property, but if you take an awful lot of butter you're 3 going to have a tendency towards heart disease. Salt is 4 not a toxic not considered toxic, but in people with 5 high blood pressure it's quite toxic. So, true, there are 6 industrial compounds Any industrial compound has toxic 7 properties, but it varies. Some are extremely toxic, that 8 a small amount, a tenth of a teaspoonful to a man can 9 cause very serious problems. Others might take a half a 10 pint. Alcohol, for example, there's no question alcohol 11 is a toxic compound by anybody's deposition definition, 12 but you take two beers a day, that's not toxic to you. So 13 the toxicity There's an inherent quality of the 14 possibility of doing harm, but it always has to be in 15 relationship to how much you're getting of it. 16 Q. So most compounds are toxic; it just depends 17 on how much you get? 18 A. Sure. Oxygen. If you get too much oxygen in 19 a baby, it's extremely toxic. Well, oxygen we're 20 breathing 14 times a minute. 21 Q. When did you first begin studying all the 22 significant medical and scientific articles relating to 23 Monsanto products? 24 A. 1936 when I started with them. I had never 25 heard of Monsanto before then. WATER PCB-SD0000032972 22 1 Q. Okay. And for how long did you continue that 2 practice? 3 A. Till today. 4 Q. So you were doing it at the time of your 5 retirement in 1974? 6 A. Yes. 7 Q. And you've continued to read the literature 8 since then? 9 A. That's correct. 10 Q. Can you give me some examples of some of the 11 publications you reviewedwith regard toMonsanto products 12 prior to World War II? 13 A. There wereonly a couple that werestrictly 14 occupationally oriented, strictly dealt with occupational 15 matters. There was one called "A Journal of Industrial 16 Hygiene and Toxicology," which was published in the United 17 States, and that went defunct after awhile. I don't think 18 it survived through the war. But that was basically 19 devoted to industrial hygiene, as the name implied, and 20 articles on animal toxicity and on human toxicity, if 21 there were any cases of illness or harm from industrial 22 chemicals. There was also a journal called "Journal of 23 the Industrial Medical Association," which also dealt 24 mostly with case reports of individual illnesses, either 25 alleged or actually due to occupational conditions. Then WATER PCB-SD0000032973 23 1 there were publications of the government. There was a 2 Department of Mine Safety that dealt with products. The 3 Public Health Service would come out with irregular 4 bulletins on materials. Then there were isolated case 5 reports in the various medical journals, like the "New 6 England Journal of Medicine," the "Journal of the American 7 Medical Association". 8 Q. Why did you review the scientific articles 9 regarding Monsanto products? 10 A. To find out all I could about any possible 11 harmful properties so that I could advise our workers and 12 our customers as far as safe handling procedures is 13 concerned. 14 Q. And I believe you indicated you made these 15 plant inspections sometime annually or at least every 16 other year of all the plants in the United States for 17 Monsanto while you were Medical Director. What was the 18 purpose for these periodic plant visits? 19 A. Well, I think it was two purposes. One to 20 see the medical organization was running all right, that 21 the doctor was doing a good job. Secondly, to familiarize 22 myself with the plant manufacturing process to see if 23 there were any changes or any uncontrolled hazards there. 24 And Let's see. That's two. There was another one, 25 another particular WATER PCB-SD0000032974 24 1 Q. I guess Well, let me ask you this. Was 2 part of it to check to see if the safe handling procedures 3 were being followed? 4 A. Oh, yes. That was part of the inspection as 5 far as the industrial hygiene aspect of it was controlled. 6 Most of the time the safe handling procedures in a plant 7 were directed and supervised by the safety department. 8 These were plant employees. They were not They were 9 Monsanto employees, but they were under the line direction 10 of the plant,, and they have their own safety department, 11 they have their own foreman and manufacturing 12 superintendent of the individual departments. They had 13 their own safety meetings where they brought up all of 14 these things. It wasn't really my function to see that a 15 man wore a respirator when he was told. That was I 16 would tell the plant what safety precautions should be 17 carried out, what safe handling procedures should be 18 carried out. It was up to the plant to do it. If I saw 19 something at the time that was a flagrant violation, 20 obviously I would tell the plant manager. 21 Q. Did you talk to the plant physicians and 22 nurses about any to inquire about any unusual health 23 problems? 24 A. Oh, yes. I talked to the plant physician and 25 nurse all the time. I would see the nurse Whether the WATER PCB-SD0000032975 25 1 plant physician was a full time plant employee or a 2 part time plant employee or just a plant consultant, I 3 would see them everytime I went there. I would talk to 4 the nurse, spent quite a bit of time at the dispensary. I 5 would check with her as to whether there were any grouping 6 of any illnesses, any particular amount of complaints from 7 any particular department, and I would do random 8 examination of some of the employee records, pull them out 9 to see what sort of an examination the doctor was doing. 10 Q. How long would these plant visits usually 11 take? 12 A. From a half a day in a small plant to three 13 days in a large plant. 14 Q. Did you visit any plants in the United States 15 that manufactured PCBs? 16 A. Yes, I did. 17 Q. Which plants were those? 18 A. Anniston, Alabama, and the Krummrich plant, 19 which let's call the East St. Louis plant. It's located 20 at Sauget, S a u g e t, Illinois, which is right across 21 the river from Monsanto, and it's been From St. Louis, 22 rather. And it's been termed First it was Plant B. 23 Then it was Krummrich plant. Then it was Monsanto 24 Illinois plant. Then it was Sauget plant. They all 25 referred to the same plant. Let's call it East St. Louis. WATER PCB-SD0000032976 1 It's right over there. 26 2 Q. So there were two plants that manufactured 3 PCBs, one in Anniston, Alabama, and then one in East St. 4 Louis ? 5 A. That's correct. 6 Q. Okay. And we'll just talk about East St. 7 Louis rather than the other names so we can keep it 8 straight. 9 A. Fine. 10 Q. Were there any products manufactured other 11 than PCBs in the Anniston, Alabama Plant? 12 A. Yes, it varied. They never manufactured more 13 than three or four. They manufactured parathion, which is 14 an insecticide. They manufactured some abrasives and they 15 manufactured some phosphorous compounds at Anniston. They 16 only had about three or four or five. They manufactured a 17 plasticizer down there. Not too many. 18 Q. What about East St. Louis? Were there other 19 products? 20 A. They manufactured everything from phenol, 21 which is carbolic acid, to chlorine. They manufactured 22 about 75 different products. Anniston was small. It 23 might have had It varied from 75 to 200 people. East 24 St. Louis varied from 600 to 1400. 25 Q. During what period of time did you visit the WATER PCB-SD0000032977 27 1 Anniston plant in Anniston, Alabama? 2 A. I went there first before the war, probably 3 in '37, and then, of course, all the time from '46 to '74. 4 East St. Louis, I'm not exactly sure when I first went to 5 East St. Louis. I certainly went to them every year after 6 1946. I may have gone there before the war, but I'm not 7 too sure about it. 8 Q. And you visited those two plants through your 9 retirement in 1974? 10 A. Yes. 11 Q. For what period of time did Monsanto 12 manufacture PCBs? 13 A. They started in Anniston sometime before I 14 came with the company. As I said, I came with the company 15 I think January 15th, 1936. But they bought a company 16 that was called Swann, Swann, Chemical Company, which 17 had manufactured PCBs from 1933 on. They continued 18 manufacturing these PCBs until 1977, or they were 19 manufacturing them when I left. I don't know when they 20 started the manufacturing in East St. Louis. I don't 21 remember. But they continued manufacturing that certainly 22 through 1974. They started manufacturing it at one of the 23 plants in England, but I'm not sure of the dates of that. 24 It was certainly after World War II. 25 Q. But in the United Well, the PCB WATER PCB-SD0000032978 28 1 manufacture started by Monsanto in 1936 or about then? 2 A. Yes. It started Monsanto became involved 3 in it. It was not started by Monsanto. 4 Q. No. I 5 A. It was started bySwann. We took over Swann, 6 so we were making it. 7 Q. So Monsanto bought Swann, which had been 8 manufacturing PCBs for about three years? 9 A. That's correct. 10 Q. What was Monsanto's policy withregard to 11 physical examination of employees at the Anniston, Alabama 12 plant and the East St. Louis plant while you were Medical 13 Director? 14 A. We had a full time doctor at Anniston, which 15 is a little bit strange because of the size of the plant, 16 but at that particular plant he did non occupational 17 conditions also. In other words, he was sort of like what 18 would be called today an HMO. He took care of 19 non occupational conditions as well as occupational 20 conditions. 21 Q. Let me ask it Did you have the same policy 22 of periodic physical exams at the Anniston, Alabama and 23 the East St. Louis plants that you had at the other 24 plants? 25 A. Yes. There were regular examinations. WATER PCB-SD0000032979 29 1 Q. What was the purpose of these regular or 2 periodic physical exams of the Monsanto workers, including 3 the PCB workers? 4 A. Well, it was to all workers. I mean, PCB 5 people were not treated any differently than people 6 manufacturing phosphorous or people manufacturing 7 chlorine. It was to see to detect any beginning or 8 early illnesses, whether of a private nature, beginning 9 high blood pressure, early diabetes, or to see if there 10 were any condition that could be attributable to the 11 chemicals with which they were working. 12 Q. Did you monitor or check the health of 13 Monsanto employees involved in the manufacture of PCBs 14 over the years? 15 A. You mean did I physically examine the people? 16 Q. Well, either that, or did you monitor the 17 exams ? 18 A. Well, I didn't examine the people except for 19 one occasion, which I guess you'll come to later. That 20 was in 1972 or '73 where I examined the PCB workers. But, 21 yes, I talked to the doctors, I examined the records. I 22 saw the records at Anniston because, as I said, it was a 23 small department with PCB. And I saw the records 24 individually in East St. Louis. Their workers rotated 25 around, but I talked to the dispensary people and I talked WATER PCB-SD0000032980 30 to the plant physician and monitored through them. Q. Did any of the plant physicians or workers report any health problems they were having with PCBs? A. Not while Monsanto had it. They had Dr. Martin, who was at the Anniston plant, was the doctor who took care of the Swann Chemical employees. Q. Okay. I'll get to that situation in a minute. A. To answer your question, no. Q. While Monsanto manufactured PCBs from, say, 1937 until your retirement, you heard of no problems, health problems, with PCB workers? A. That is correct. Q. You mentioned that you did examine some PCB workers at one particular time where you got involved. A. Yes. Either '72 or '73 there was quite a bit of interest in the environmental aspects of PCB. Q. Well, let me ask you I'm going to get to that in a minute. A. Oh, okay. The answer is yes. Q. Okay. Yeah. Let me cover that a little bit 10 later in the sequence because that was 1972, I believe A. Okay. Q. Who did the plant physicians at Monsanto report to? WATER PCB-SD0000032981 31 1 A. Well, they reported from the medical aspect 2 to me. They reported as far as They were plant 3 employees, they were paid from the plant payroll, so in 4 that sense they reported to the plant manager. But 5 medically they were under my supervision and direction. 6 Q. Did you give the plant physicians any 7 instructions concerning what they were to report to you? 8 A. Yes. Any occupational condition with the 9 exception if a fellow got a burn he wasn't supposed to 10 call me up and say this man burned his forearm with a hot 11 chemical or something like that. But anything that was of 12 any importance, they were supposed to report it to me. 13 Q. And what do you mean by anything of 14 importance? 15 A. Well, if several people in the department 16 developed pulmonary problems from chlorine, for example. 17 We had a Chlorine Department where we made chlorine. If 18 we were getting a group of dispensary visits from the 19 Chlorine Department, he was supposed to let me know about 20 it, and we'd get our industrial hygienist down there and 21 see what's going on. 22 Q. Who was the plant doctor at the Anniston, 23 Alabama plant that manufactured PCBs? 24 A. A Dr. Martin. 25 MR. MURRAY: At what time? WATER PCB-SD0000032982 32 1 Q. When you started. 2 A. When I started? 3 Q. Yeah. 4 A. Dr. Martin. 5 Q. And did you personally hire or approve the 6 hiring of the plant physicians while you were Medical 7 Director? 8 A. Well, if they were there Dr. Martin was 9 there obviously. 10 Q. For new ones. 11 A. New ones, yes. I interviewed them, and the 12 final decision was made by the plant manager. But he 13 couldn't hire anybody without my approval. He might say, 14 "I don't think this man will get along with the employees" 15 because of personality or anything else, and he might say, 16 "No, I don't think I can use him. We'll get somebody 17 else." But the plant manager could not go out and get his 18 own physician. 19 Q. What type of credentials or gualifications 20 did you look for in plant doctors? 21 A. A good doctor, an intelligent doctor, an 22 honest doctor. 23 Q. Did the During your 38 years at Monsanto, 24 or roughly 40 years actually at Monsanto, did the plant 25 physicians at the Anniston, Alabama plant or the East St. WATER PCB-SD0000032983 33 1 Louis plant ever report any PCB related health problems in 2 the Monsanto PCB workers? 3 A. No, they did not. 4 Q. How did it come to be Monsanto's policy that 5 all inquiries concerning possible adverse health effects 6 be directed to the Monsanto Medical Department? 7 A. I told the executive committee, "This is what 8 we ought to do." After all, the Medical Department is the 9 authority on the medical aspects of any Monsanto products, 10 and we were the people who knew what to do to prevent any 11 problems. 12 Q. And did management agree with your 13 recommendation? 14 A. Yes. They sent out a directive to all the 15 plants and all the sales offices. 16 Q. And that policy was consistent throughout 17 your time at Monsanto? 18 A. Yes, it was. 19 Q. What was the purpose of the policy that you 20 mentioned about having all of the complaints of unusual or 21 serious complaints of health problems come to the Medical 22 Department? 23 A. We knew more about it than anybody else. 24 Q. Was there Was that also a policy with 25 regard to customer complaints as well as employee WATER PCB-SD0000032984 34 1 complaints? 2 A. Oh, yes. I thought when you said "all 3 complaints," that referred to customers, yes, certainly. 4 In the plants, the person would obviously first go to the 5 plant doctor. And then he wouldn't call me if he had a 6 problem. He'd go to the plant doctor. And if the plant 7 doctor had any problem, he'd call me. But we had 8 instructed the plant doctor as to what the toxicological 9 properties of the raw materials were and the finished 10 products. But all customers, they didn't have that 11 intermediary, so they came right to us. 12 Q. You mentioned also the policy of the company 13 that all safe handling information be approved by the 14 Medical Department. What was the purpose of that policy? 15 A. The purpose was to prevent any injury to our 16 customers due to the use of Monsanto products. And the 17 Medical Department was the fountain head, as it were, of 18 the knowledge of this knowledge as to what the 19 toxicological properties, if any, were and how to and 20 the safe handling procedures be used. I have to repeat, I 21 did not function for fire or explosion. That's something 22 else. 23 Q. How did Monsanto typically publish toxicity 24 and safe handling information in relation to its products? 25 A. Well, it all depends. Typically it would be WATER PCB-SD0000032985 35 1 in a section in the bulletins that are put out. First of 2 all, there's a technical bulletin. Suppose Product X is 3 found. Here we've got a compound, we've got a bunch of 4 suggested uses for it, and it's not on the market yet, so 5 they send this bulletin out to a bunch of potential 6 customers. In that they list the product, the properties, 7 they list what the company thinks it's good for, and they 8 also list what the safe handling procedures are to be used 9 to handle it. Then once the thing got into production and 10 use, there would be application bulletins and sales 11 bulletins, which would also include a section on safe 12 handling procedures for use with the product. In 13 addition, there were some letters that were more involved 14 that we would send out to bulletins that we would send 15 out for the Medical Department that were somewhat more 16 detailed. If people were asking about specific problems, 17 like "We heat this up to 100 degrees, what's the problem? 18 We heat it up to 500 degrees, what's the problem?" Then, 19 of course, there's the labels. The information of the 20 safe handling precautions to be taken were put on all 21 labels. 22 Q. Once the safe handling information was put on 23 a label or a bulletin of some kind, did Monsanto have a 24 policy concerning which customers received the materials? 25 A. Everybody did. WATER PCB-SD0000032986 36 Q. Why did Monsanto want to ensure that all its customers got this safe handling information about its products? A. They didn't want anybody hurt, whether it was a big company or a little company. Q. Why didn't Monsanto give this safe handling information directly to the employees of the customers? MR. MURRAY: I just object to the form of the question, and you've asked him several times why did Monsanto do this and why did Monsanto do that, and I'm not sure he's qualified to speak on behalf of Monsanto. You can ask him about what his the reasons why he wanted it done if, in fact, he did want it done, but I don't believe you can ask him questions regarding what Monsanto wanted what Monsanto why Monsanto did something. You can answer. Q. Do you remember the question? A. No. Q. Okay. Let me try to repeat it. Why did Why didn't Monsanto A. Why did or didn't? Q. Why didn't Monsanto give this safe handling information directly to employees of customers? If you know. A. Well, yes. I consider myself part of WATER PCB-SD0000032987 37 1 Monsanto. First of all, we have no right to go directly 2 to an employee of a different company. Number two, and 3 this is more important, we don't know how it was used. We 4 don't know the exposure that the employee may have in a 5 customer's plant. So we give this information to their 6 management, who then has what we know, and they know how 7 the employee is exposed, and we know I mean, they know 8 what our advice is as to prevent any harmful effects. 9 Q. And if a customer or user of a Monsanto 10 product wrote a letter to Monsanto with a question about 11 the toxicity or safe handling of a Monsanto product, what 12 would happen to that letter? Where would it go? 13 A. Come to the Medical Department, and we would 14 answer it either by telephone or by letter. 15 Q. During the time that you were Medical 16 Director at Monsanto, what was the company policy 17 concerning communication of safe handling information to 18 Monsanto employees who were engaged in the manufacture of 19 various products? 20 A. We would send the information, and that was 21 in various forms. I mean, it might be a memorandum, it 22 might be a Monsanto Safety Data Sheet, which listed the 23 physical properties and the toxicological properties and 24 the safe handling procedures. We would send that to the 25 plant manager, the manufacturing superintendent, the WATER PCB-SD0000032988 38 1 dispensary and the safety man, the safety director. They 2 had regular safety meetings in all departments, and this 3 information then was transmitted by either the foreman or 4 the safety director to the individual employees. 5 Q. Doctor, did you keep track of any statistics 6 in relation to any particular diseases occurring in 7 Monsanto employees? 8 A. Yes. 9 Q. Any kind of an index of that? 10 A. Yes, I did. There was one illness or one 11 condition that existed in three of Monsanto's plants that 12 had nothing to do with PCBs. I mean, this was a bladder 13 condition. And they didn't These people did not work 14 with PCBs; they worked with an entirely different 15 chemical. And that was a specific illness that we kept 16 very close track on. In addition to that, we had 17 quarterly reports of any workmen's compensation cases that 18 would include any illness that was occupational in nature 19 that we spent any money for, that we had a doctor's bill 20 or a hospital bill or a lost time of employees. That was 21 a quarterly report that I saw and reviewed quarterly from 22 all our plants. Third, sometime after the war the 23 question of whether or not cancer could be caused by 24 chemicals became interesting to an awful lot of people, 25 and myself included. So I set up a program in which our WATER PCB-SD0000032989 39 1 own health insurance, to which 95 percent of Monsanto 2 employees belonged to at first, and then when it became 3 non contributory, in other words, they gave it to the 4 employees, everybody had it. So I had our general office 5 get send me a list of any malignancies that occurred in 6 any Monsanto employee in any plant, whether salaried or a 7 wage earner, and I kept that list from sometime I guess in 8 late '40's or '50's to the time I retired. 9 Q. Was this cancer index limited to any 10 particular plant at Monsanto? 11 A. No. Any plant or office. Anybody, whether 12 he's a salaried person or worked in the Medical 13 Department, was listed. 14 Q. Did you commence this cancer index because 15 you were concerned with any particular chemical exposure? 16 A. No. I was interested just in any possible 17 connection of any chemical in a worker, exposure to a 18 worker, with any malignancy. 19 Q. And I don't know if you mentioned this in 20 your answer, but did you review that periodically, that 21 A. Oh, sure. There was no reason to do it 22 unless I reviewed it. 23 Q. How often would you review it? 24 A. Oh, I can't say every Probably quarterly 25 is a pretty good answer. At least quarterly I think. WATER PCB-SD0000032990 40 1 Q. Four times a year? 2 A. Something like that. 3 Q. Did you find any groupings of cancer that 4 were related to PCBs during that period? 5 A. No, I did not. 6 MR. CARNEY: Why don't we take a break? The 7 tape is about to expire. 8 (Brief recess.) 9 Q. Doctor, I believe you indicated that your 10 department expanded over the years by adding industrial 11 hygienists and toxicologists. How did you supervise your 12 Medical Department? 13 A. We also expanded by adding more doctors, too. 14 Q. Okay. 15 A. But still we were a small department. We 16 were in one section of the complex, the office 17 headquarters complex. We all had offices around a central 18 secretarial pool. And we went to lunch together. We were 19 very close. Well, I was Medical Director. There was a 20 Dr. Morris Johnson, who was Assistant Medical Director, 21 and under him was Mr. Wheeler, who handled industrial 22 hygiene. He had his industrial hygienists there. We had 23 a Dr. Levinskas. We had a toxicological department. 24 First Mr. Wheeler was in charge of the toxicologist 25 department, but then he became administratively in charge. WATER PCB-SD0000032991 41 1 Mr. Wheeler handled a good part of the toxicology until 2 we until our toxicologist came onboard. 3 Q. Did you have periodic department meetings? 4 A. We met every week. We also had a system in 5 which we had any carbons that were sent out I mean, any 6 letters that were sent out, carbons were checked off to 7 the relevant individual so that I was familiar with every 8 correspondence of Mr. Wheeler or Dr. Levinskas carried out 9 as far as toxicology was concerned. 10 Q. Did you in your role as Medical Director have 11 access to the top management at Monsanto? 12 A. Very frequently. As I say, we were almost a 13 first name company, and I was able to talk to Mr. Queeny, 14 who was the president, calling him Edgar. And so I was 15 very frequent. 16 Q. Was the management at Monsanto responsive to 17 your requests and recommendations? 18 A. Completely. I never had a medical request 19 for any policy that was directed towards safety or medical 20 conditions turned down by management. Now, there would 21 be For example, in toxicology, if somebody came up with 22 a product and said, "I'd like to have this examined," I 23 would go up and check out Suppose it were an 24 agricultural chemical. And I'd go up and say, "This is 25 going to cost $200,000," I'd go back to the person and WATER PCB-SD0000032992 42 1 say, "Look, we can have this done, but it's going to cost 2 you $200,000." He'd say, "Well, I don't believe this 3 product has that much potential. I don't think we'll do 4 it." Well, that's not a question of turning it down. But 5 any medical condition, any medical procedure or medical 6 statement that I wanted to carry out, medical policy I 7 wanted carried out, was never turned down. 8 Q. Dr. Kelly, what were PCBs used for in the 9 193 0's ? 10 A. The main use was a dielectric. That means a 11 compound that does not conduct electricity. They were 12 used in electrical applications, primarily in transformers 13 and then in capacitors. I do not know exactly when the 14 use of capacitors started, but they had been used in 15 transformers certainly when I came with Monsanto. 16 Q. Who were some of the Monsanto customers for 17 PCBs that were used in transformers and capacitors? 18 A. Well, the big ones were General Electric, 19 Westinghouse, Allis Chalmers. There were smaller, Maloney 20 Electric. Monsanto was the only manufacturer of PCBs in 21 the United States. 22 Q. What were some of the trademark names for 23 PCBs used by Westinghouse or General Electric? 24 A. Westinghouse used the trademark Inerteen, 25 Inerteene (sic). General Electric used Pyranol, WATER PCB-SD0000032993 43 1 P y r a n o 1. 2 Q. Those were the names for PCBs for 3 Westinghouse and General Electric? 4 A. That is correct. 5 Q. Over the years, Dr. Kelly, were other uses 6 developed for PCBs? 7 A. Oh, yes. They were used as a plasticizer. 8 They were used in lubricants. They were used in waxes. 9 They were used Those are relatively small uses. They 10 were used in paints. Again, a small use. Large uses were 11 in carbonless carbon paper and hydraulic fluids. That's a 12 fluid that you use to carry pressure from one vessel to 13 the other I mean, one pump to the other, like in 14 die casting or airplane hydraulic fluids they were used, 15 although PCBs were not used in airplanes. I was just 16 using that as an example of an hydraulic fluid. And they 17 were used in heat transf agents. In other words, if 18 you've got a source of heat there and you want the heat 19 over there, but you don't want the furnace inside the 20 building, you put a pipe system filled with PCBs where 21 it's being heated and it transmits the heat over here 22 where you want the heat. 23 Q. What were the names of the PCBs that were 24 used as hydraulic fluids? 25 A. Pyranol. Monsanto had a name Aroclor. I WATER PCB-SD0000032994 44 1 mean Hydraulic fluids? 2 Q. Yes. 3 A. Sorry. Not Pyranol. Pydraul. Pydraul's 4 P y d r a u 1. Monsanto had a generic name for compounds, 5 PCBs, that were Aroclors. All Aroclors were not PCBs, but 6 all PCBs fell under the classification of Aroclor. It's 7 A r o c 1 o r. 8 Q. What was the name, PCB name, that was used in 9 the heat transfer systems that you mentioned? 10 A. Therminol, Therminol. Now, there 11 were other names that crept in. Some were called OS, then 12 some are called MCS. Then they put a number afterwards. 13 But the main name was Therminol for heat transfer agents 14 and Pydraul for hydraulic fluids. 15 Q. Were there benefits to using PCBs in 16 transformers and capacitors? 17 A. Oh, a tremendous benefit. They were fire 18 resistant. Previously They combined good dielectric 19 qualities, that's good electrical properties, with fire 20 resistance. Some things had Some fluids, like 21 hydrocarbons, which was a refinery comes from an oil 22 refinery, a cut of oil before you take the gasoline off or 23 after you take the gasoline off, this has good dielectric 24 products properties, but it catches on fire readily. 25 And that's the most important thing, because if you've got WATER PCB-SD0000032995 45 1 a transformer in a hospital, in a school, in the White 2 House, you put a flammable substance in there and you 3 catch on fire, you transform a small fire into a 4 conflagration. If you have it in a subway 5 Q. A what? 6 A. To a big A big fire. 7 Q. Okay. 8 A. A big fire. If you have a subway, it's awful 9 to have a big fire in a subway. In trains. Suppose Busch 10 Stadium, they've got these transformers up near the 11 lights, if there's a fire there from a lightning strike or 12 God knows what fire, you get a bunch of flaming oil 13 dropping down on the people in the grandstands, that's 14 bad. So the inflammability was very important. Now, they 15 did have products that had silicates and other products 16 that were not inflammable, but they weren't good 17 dielectrics. So that accounts for the fact that the PCBs 18 were sold one year almost a hundred million pounds of 19 them. 20 Q. So was there a material substitute that could 21 perform the job in transformers and also be fire retardant 22 like PCBs during the time you were Medical Director? 23 A. Not as good 24 MR. MURRAY: I'm going to object to the 25 question as beyond this witness' expertise. He's a WATER PCB-SD0000032996 46 1 doctor. 2 Q. Okay. If you know, Doctor. 3 A. Well, I don't know except that I know that 4 one year they sold a hundred million pounds of the stuff 5 to transformer people, and there seemed to be no 6 competition for particular uses. 7 Q. Okay. Did you review the pre World War II 8 literature relating to a substance called chlorinated 9 naphthalene? 10 A. Yes. In fact, chlorinated naphthalene was 11 the substance that they mentioned in medical school. It 12 had been around since, oh, the turn of the century, 13 1890's. 14 Q. Was there a lot of medical literature 15 available about PCBs before the late 1930's? 16 A. No. I don't know of any. There was very 17 little. 18 Q. Was there any literature 19 A. There might have been one or two isolated 20 articles where they might have run an acute toxicity on 21 the stuff, but there was no important literature in the 22 toxicological libraries. 23 Q. Are PCBs similar to chlorinated naphthalenes? 24 A. Oh, no. They're I mean, they're both 25 chlorinated, they both start from benzene, but they are a WATER PCB-SD0000032997 47 1 lot different. Just like diamonds are made of carbon, 2 coal is made of carbon, but there's a big difference 3 between diamonds and coal. 4 Q. Did Was there some early literature that 5 discussed both PCBs and chlorinated naphthalenes? 6 A. It depends what you mean by early. 7 Q. In the ' 30's, say. 8 A. Well, in 1938, there was quite a bit of 9 literature, '38 and '39, by a Dr. Drinker at Harvard. 10 Q. How is it that you recall studying some of 11 this literature in the late 1930's about PCBs? 12 A. Well, I recall it because it was quite a big 13 deal at the time. Swann Chemical Company You want me 14 to go into all of this stuff to answer it? Swann Chemical 15 Company, which was bought by Monsanto in 1935, sometime 16 before I came there, in 1933 Swann Chemical Company had an 17 incident in which around 20 people had chloracne. 18 Chloracne is a condition somewhat similar to teenage acne, 19 only it's different in several areas. One, it doesn't 20 occur in the same places. It may or may not, but quite 21 often it doesn't. It is accompanied by pigmentation, 22 which does not occur in teenage acne. And it's caused by 23 a variety of chlorinated compounds: wood preservatives, 24 penachlorophenol, herbicides, 245 T, and chlorinated 25 naphthalene, and in PCBs, which and its contaminants. WATER PCB-SD0000032998 48 1 The Swann people had this epidemic. They had been making 2 this material for 3 Q. By "this material"? 4 A. PCBs. They had been making PCBs for I guess 5 three or four years. They changed the supply. They made 6 it from benzene. You make PCBs by taking benzene, joining 7 two molecules of benzene together and chlorinating them. 8 They changed the supplier of benzene and they found out 9 later they got a bum supply of benzene. So when they 10 chlorinated it, they got a PCB This is Swann now. They 11 got a PCB 12 Q. Now, Swann was the company that Monsanto 13 bought later on? 14 A. That's right. And this occurred two years or 15 so before Monsanto bought it, at least two years. So they 16 came out with a PCB that was a different color than the 17 standard PCB, different dielectric quantities, but they 18 still sold it. Why I don't know. But during the course 19 of this manufacture, they developed the workers at 20 Swann developed chloracne. It was treated and then went 21 away. But it was pretty prominent for awhile. Well, 22 obviously I was interested because when I came with the 23 company the people were happy to unload their files on 24 anything they had related to Medical Department. They 25 bumped it down to me. So I was interested. WATER PCB-SD0000032999 49 1 Well, then in '37, some of one of Monsanto's 2 customers, Halowax, H a 1 o w a x, which was making wire 3 coatings You're too young to remember the old wire that 4 you would pull it, pull on it and it would give you a 5 brownish stain on your hands instead of the nice clean 6 rubber or vinyl extension cords we have today. But, 7 anyway, Halowax manufactured this coating from chlorinated 8 naphthalene. 9 Q. Let me get to that in a minute. 10 A. I thought you were asking me how I got going 11 on this. 12 Q. Well, but it was the Swann Chemical outbreak 13 of chloracne and then Monsanto bought Swann that peaked 14 your interest in 15 A. That's correct. 16 Q. the PCB literature? 17 A. That's correct. 18 Q. You mentioned the chloracne can be caused by 19 various compounds, including PCBs. Is chloracne the only 20 known health problem which can be caused by industrial 21 exposure to PCBs? 22 A. You could get acuteatoxic hepatitis if you 23 were exposed to inhalation of the fumes at elevated 24 temperature for a prolonged period of time, yes. There 25 have been reports. One case of three people that WATER PCB-SD0000033000 50 1 developed jaundice from They had a . . 2 Q. Okay. So there's What's hepatitis? Could 3 you put that in layman's language so I can understand it? 4 A. It's an inflammatory disease of the liver. 5 Chemical hepatitis is inflammatory is a disease of the 6 liver due to chemicals. And there are other hepatitis, 7 obviously from eating fish or infected needles. 8 Q. Is this hepatitis, is that a permanent 9 condition if you're exposed to PCBs at elevated 10 temperature ? 11 A. It has not been with the PCBs. I mean, but 12 you can get a chemical hepatitis. You get chemical 13 hepatitis from chlorinated naphthalene that proceeds to a 14 very serious liver condition, even death. 15 Q. What about the situation with PCB exposure 16 that might cause hepatitis or a liver problem? Is that 17 permanent? 18 A. No. No reports of any permanent injury from 19 industrial exposure to PCBs. In the two instances that I 20 know about, they cleared up without any problem. 21 Q. And so the chloracne that could be caused by 22 various products, including PCBs, is that a permanent 23 condition? 24 A. I think it depends on the extent. You could 25 get scarring from it, and you can get inclusions like WATER PCB-SD0000033001 51 1 blind blackheads that may have to be opened. If they 2 don't open, you can consider it permanent. 3 Q. By permanent, what do youmean? 4 A. It lasts a long time. 5 Q. But if you remove the PCBs from the person, 6 what happens to the chloracne? 7 A. Well, as I say, if it's mild, it goes away. 8 If you've got cysts, they can persist until they are 9 opened. If they are opened, you get scars from it. But 10 you don't get any more. In other words, if you got 11 chloracne from PCBs, you take out the PCBs, you aren't 12 going to get any more. If you take away the PCBs, you 13 aren't going to get any more chloracne. 14 Q. So you won't get any more pimples or acne? 15 A. That's correct. 16 Q. But you might have a scar, like a teenage 17 acne, that would be permanent? 18 A. Yes. Or you may have a cyst. In other 19 words, like a blocked up sweat gland. There it is. 20 Unless you open it, it's not going to disappear. 21 Q. You mentioned that there were a few reported 22 cases of this hepatitis from exposure to PCBs if they were 23 overexposed at high temperatures. What do you mean by 24 overexposed? 25 A. Well, if you stay around them Here you've WATER PCB-SD0000033002 52 1 got these fumes that are coming out, they are irritating, 2 and if you're inhaling them and you stay around them for 3 all day, that's overexposed. These people I only know 4 of two instances. One was reported in the medical 5 literature, in some obscure journal like the journal of 6 some Midwestern state occupational I mean, state 7 medical journal. I talked to a Dr. Spolyer, who was the 8 Chief of Public Health of some Midwestern state. I'm not 9 certain about it. And I saw the reprint, but I couldn't 10 find it anyplace. He had three cases. They had a 11 jury rigged heat transfer system that leaked. There was 12 no indication of how much it leaked, but it was hot. It 13 was a heat transfer system. These people worked in there 14 for I'm not sure of the details about a week. And 15 these three people got jaundice. And obviously they 16 pulled them out when they started getting jaundiced, 17 stopped the situation, plugged up all the leaks, and 18 watched the people. I don't know if they were 19 hospitalized. I don't think so. But they all got well 20 because I talked to Spolyer, who isn't living anymore, at 21 that time, and that was about in the early '50's or the 22 late '40's, a long time ago. And then there was another 23 one, I had call from a Crown Chemical Company in New York 24 from this doctor who was treating some people who were 25 nauseated from being exposed to PCBs, again in a heat WATER PCB-SD0000033003 53 1 transfer system where there were leaks, and I told him, 2 well, watch out for jaundice, that this can occur, and he 3 had one or two people, and he called me in a week or so 4 later and said, "Yeah, you're right. They do have 5 jaundice. What do we do?" I said, "Well, just watch 6 them. They'll get well." And I checked with him in a 7 month, and they got over it with no problem. 8 Q. Those are the only two cases you can recall 9 where there was any kind of a hepatitis or jaundice 10 problem relating to PCBs that were reported to you? 11 A. Yes. To the best of my knowledge, yes. 12 Q. What were the Monsanto safe handling 13 procedures for PCBs? 14 A. There were two. Avoid repeated or prolonged 15 skin contact. If it gets on your skin, wash it off. If 16 your clothes are contaminated, soaked, change. Avoid 17 breathing the material in confined spaces or at elevated 18 temperatures. PCBs have very low pressure. That means 19 you don't get fumes from them. If we had set a pan of 20 PCBs in the middle of this room, you might be able to 21 smell it maybe, but you wouldn't get anything close to any 22 harmful condition. You could sit there for a week, a 23 month, with the stuff open. You wouldn't get any problem. 24 Q. If these Monsanto safe handling procedures 25 are followed, is there any risk of getting chloracne or WATER PCB-SD0000033004 54 1 hepatitis ? 2 MR. MURRAY: Object to the form of the 3 question in that I assume you're asking his opinion, but 4 you did not phrase it in that manner. 5 Q. Well, let me ask you this, Doctor. If the 6 Monsanto safe handling procedures are followed, do you 7 have an opinion based on a reasonable degree of medical 8 certainty as to whether there'd be any physical problems 9 like chloracne or hepatitis? 10 A. Well, yes, I do. 11 Q. What is that opinion? 12 A. That they wouldn't occur because I have I 13 said with the exception of those two cases where obviously 14 the procedure was not followed, where the material was 15 breathed at elevated temperature, with the exception of 16 those two cases, we had no problems. We did not have I 17 have never received a letter or a complaint from any 18 Monsanto customer that their workers had either hepatitis 19 or chloracne. In the medical literature in the United 20 States, there's been one instance of chloracne resulting 21 again from a heat transfer agent in New England. That's 22 the only one. There have been no reports to the best of 23 my knowledge of chloracne occurring in the electrical use 24 in the United States due solely to PCBs. 25 Q. Did Monsanto PCB workers ever have problems WATER PCB-SD0000033005 55 1 with chloracne or liver problems caused by PCBs? 2 A. They did not have any of those problems, 3 those two problems. 4 Q. And you mentioned the chloracne problem at 5 Swann, but that was before Monsanto bought the company? 6 A. Yes. 7 Q. Have you ever seen chloracne? 8 A. Lots of it. 9 Q. Under what circumstances? 10 A. Under people exposed to penachlorophenol, 11 under people exposed to 245 T. I saw the workers, quite a 12 few of the workers, the Swann workers, three or four years 13 after their chloracne. They really didn't have any 14 residue that I can talk about. It appeared to be quite 15 well. I have seen I saw one case of industrial 16 chloracne. This was I know it was the '40's. It was a 17 transformer I mean, not a transformer. It was a 18 thermometer company up in New York, I believe. Anyway, it 19 was in the East. These people were making oven 20 thermometers. An oven thermometer at that time was sort 21 of like a bellows, that's a little sack made out of 22 leather or something of the sort, which they dipped the 23 PCB they filled these with PCBs, and they would dip 24 these things, these little sacks, into liquid PCBs at room 25 temperature. Well, some of the women, two or three of the WATER PCB-SD0000033006 56 1 women, had chloracne from it. Well, that was new to me, 2 and I In fact, I hadn't seen chloracne at that 3 particular time, so I went up there and talked to them. 4 And I said, "Why don't you get some sort of a gimic that 5 they don't have to put their hands in, a fork or a forceps 6 or something?" Well, they had no other symptoms outside 7 of the chloracne. And they did, and then on follow up 8 they didn't have any problems. I mean, the chloracne went 9 away. Nobody else got it. Does that answer the question? 10 Q. Yes. 11 A. It went so long, I forgot what the question 12 was . 13 Q. I think so, Doctor. Let me hand you some 14 documents that we've marked previously, and I think you 15 have the documents next to you, exhibits we've marked K 1 16 through K 5. I've got a set with me, and, Mr. Murray, I 17 believe you have a set there you can look at. Just for 18 the record, we did agree before this deposition that we 19 would each exchange the documents we were going to use 20 today, and we did that yesterday. So I think, Mr. Murray, 21 you've at least had a chance to see these documents 22 yesterday. Is that correct? 23 MR. MURRAY: For the record, that's 24 absolutely correct, and I appreciate the hospitality. 25 MR. CARNEY: Okay. WATER PCB-SD0000033007 57 1 Q. We've marked the exhibits with the letter K 2 first and then a number to stand for Kelly. So we have in 3 front of you now Exhibits K 1 through K 5. Can you 4 identify briefly those exhibits? 5 A. Yes. You want me to take these individually? 6 Q. Yeah. If you'd just identify them by the 7 author and date. 8 A. K 1 is a reprint that was of a publication by 9 Dr. Henry Smith on the toxicity of certain benzene 10 derivatives and related compounds. It was a 1930 document 11 in the "Journal of Industrial Hygiene". Did I give you 12 the title? 13 Q. Yeah. Why don't you go on to K 2? 14 A. You just want me to identify them? 15 Q. Yeah. If you just very briefly identify 16 them. We'll get into a little more detail later. 17 A. Number two is an article by Dr. Jack Jones in 18 the "Archives of Dermatology and Syphilology," 19 Syphilology, published probably in 1935, 20 called entitled "Acneform," acneform, and I'll 21 have to spell this next one because this is a word I don't 22 know much about either, "Dermatergosis," 23 dermatergosis. Freely translated, that means 24 an acne type of skin trouble. The third is K 3 by Dr. 25 Cecil Drinker, entitled "Symposium on Certain Chlorinated WATER PCB-SD0000033008 58 1 Hydrocarbons". That was published in the "Journal of 2 Industrial Toxicology". The symposium was in '37, in 3 1937, so presumably this was published around that. The 4 next one 5 Q. It's K 4? 6 A. K 4 is another article by Drinker's group 7 called "Morphological Changes in the Livers of Rats 8 Resulting from Exposure to Certain Chlorinated 9 Hydrocarbons," also published in the "Journal of 10 Industrial Hygiene and Toxicology," February 1938. K 5 is 11 also by Drinker, "Further Observations on the Possible 12 Systemic Toxicity of Certain of the Chlorinated 13 Hydrocarbons with Suggestions for Permissible 14 Concentrations in the Area (sic) of Workrooms". 15 Q. In the air, I think, in workrooms? 16 A. In the air, I''m sorry. In the air 17 Reprinted from the "Journal of Industrial Hygiene and 18 Toxicology," 1939. 19 Q. Doctor, did you personally review these 20 articles that we've marked as Exhibits K 1 through K 5 21 sometime between January of 1936 and the time you left 22 Monsanto for the Army in 1942? 23 A. Yes, I did. 24 Q. And I take it you've also reviewed these 25 articles more recently? WATER PCB-SD0000033009 59 1 A. Quite recently and quite often. 2 Q. Doctor, were these articles, K 1 through K 5, 3 readily available for anyone who conducted a reasonable 4 search for them from 1942 forward? 5 A. Oh, yes. They are all indexed. They are all 6 reputable journals, and they were put in the index. Every 7 medical school had them. Most of the medical societies, 8 the larger medical societies, would. St. Louis Medical 9 Society had it. 10 Q. Let's take a look at K 1. That's the Smith 11 article. What did you in your capacity as Monsanto 12 Medical Director learn from your review of this 1931 13 article by Professor Smith? 14 A. Well, this article was just a grab bag. I 15 mean, an acute toxicity of a grab bag of chemicals, one of 16 which was diphenyl, which is a basic thing basic 17 building block for PCBs, and the chlorinated diphenyl. 18 Q. Okay. Just if we could refer to When 19 we're talking about PCBs, if you could use the word 20 "PCB" 21 A. PCBs, okay. 22 Q. I'll know what you're talking about, and I 23 think the jury will also. 24 A. Well 25 Q. So did they test PCBs? Were they reported in WATER PCB-SD0000033010 60 1 this article? 2 A. They tested four PCBs, and they stated that 3 two were slightly toxic and two proved nontoxic in doses 4 of four grams per kilogram. Now, there are 30 grams in an 5 ounce, and so you have to sort of do a little 6 transposition of grams per kilogram in an animal to a 7 human, but 70 pound kilogram man is 150 pounds. So this 8 person took four grams per kilogram. That's 9 Q. You mean the animal? 10 A. The animal took four grams perkilogram. 11 That's four times 70, 280 grams. Four grams in a 12 teaspoonful. That's 70 teaspoonfuls or two ounces of the 13 stuff. 14 Q. So these animals were fed roughly 70 15 teaspoons full of 16 A. Yeah. 17 Q. PCBs? 18 A. And they were called nontoxicand proved 19 nontoxic in one case by his definitions of toxicity, I 20 guess, and the other slightly toxic. So what I gathered 21 from it was here we've got an industrial compound of some 22 toxicity, but nothing unusual for an industrial chemical. 23 Q. Okay. Take a look at K 2. Did this article 24 describe the Swann chloracne outbreak that you've 25 mentioned before in your testimony? WATER PCB-SD0000033011 61 A. Yes, it did. Q. Do you have any personal knowledge about the chloracne outbreak at the Swann Chemical plant, which was the plant that Monsanto bought a few years later? A. Well, I wasn't there when it happened, but I talked to the people who were there, and I talked to the employees who were there. I may have talked to Jones or not. I don t recall that. But I have certainly that much knowledge. I saw articles I mean, memoranda concerning it. Q. Did you talk to the plant physician that was the plant physician at Swann A. Oh, yes. Q. at the time of the outbreak? A. Dr. Martin was the plant physician both at Swann and both at Monsanto until he retired Q. Was it part of your job for Monsanto to familiarize yourself with the details of this chloracne outbreak that occurred prior to Monsanto buying the plant? A. Wait a minute. I didn't familiarize myself Maybe I am misunderstanding you. I did not familiarize myself with the details before Monsanto bought the plant. Q. No. I mean after you joined Monsanto. A. After I joined Monsanto, certainly I was WATER PCB-SD0000033012 62 1 interested both from the standpoint that here we were, we 2 have this plant that had this trouble in the past, and I 3 was obviously very much interested, and I was also 4 scientifically interested in it. So I did familiarize 5 myself quite markedly. 6 Q. Were the plant physicians at the Anniston, 7 Alabama plant, which was the Swann plant, and we've 8 referred to it as the Anniston, Alabama plant after 9 Monsanto purchased it, were those plant physicians at that 10 plant knowledgeable about chloracne? 11 A. Oh, certainly. Martin back in 1936 knew more 12 about it than I did because he had been there when these 13 23 people or so had chloracne. Over in East St. Louis, I 14 had talked to the doctors about the fact that a long time 15 ago PCB manufacturing at Swann had been associated with 16 chloracne. They had also seen chloracne in insecticides 17 and wood treating chemicals. They had quite a few 18 chlorinated compounds in East St. Louis. So they were 19 knowledgeable about it. 20 Q. Did the plant physicians at the Anniston, 21 Alabama plant or the East St. Louis plant ever report to 22 you any chloracne in the PCB workers? 23 A. They did not. 24 Q. When did you review Exhibit K 2, the article 25 by Dr. Jones? WATER PCB-SD0000033013 63 1 A. Sometime in 1937 or '36. Probably '37. 2 Q. Do you recall approximately how many workers 3 had chloracne at the Swann plant, which was the Anniston, 4 Alabama plant, back in the early '30's? 5 A. I thought there were about roughly 20 or 23, 6 and of which three, six, nine, ten, 16 were sent to Jones 7 or Jones reported on 16. 8 Q. And I believe you said that when you got to 9 Monsanto in '37 these workers didn't have any active 10 chloracne at that time? 11 A. That's correct. Correct.. When I got to 12 Monsanto in ''36, I got to Anniston I went down to 13 Anniston in ''37, and they didn't have it. 14 Q. And I believe you started to mention to me 15 the cause of this chloracne outbreak at the Swann plant. 16 Could you just briefly mention what you concluded that 17 chloracne outbreak was caused by? 18 A. Well, I think I can conclude by quoting from 19 Jones, who got the history from the plant and the 20 employees at that time. He said, "The appearance" 21 MR. MURRAY: What page, Doctor? 22 THE WITNESS: Beg your pardon? 23 MR. MURRAY: What page are you on? 24 THE WITNESS: 1029, second paragraph. 25 MR. MURRAY: Thank you. WATER PCB-SD0000033014 64 A. "The appearance of the eruption" the eruption is the chloracne "coincidentally with the production of a poor grade of chlorinated di phenyl" that's PCB "seemed to indicate a relationship. On due chemical investigation, styrene,"styrene, "was assumed to be the offending substance causing the low grade of the finished product." Q. What is A. So I concluded they got some bum benzene, made some bum PCBs, and they got So there must have been a contaminant in the PCB from the bum benzene that gave the people the chloracne because they didn't have it before or after during the manufacturing of the PCBs. Q. What do you mean by bum benzene? A. Off spec. Well, it wasn't up to standard. It was a different color, poor dielectrics. It caused PCB Q. Bum, you mean bum, like bad? A. Yeah. Bad. Q. I just wanted to make sure I was on the same wavelength A. You know, I mean, the good kind is a good dielectric that has a regular color and doesn't give you chloracne. Q. When the Anniston, Alabama plant quit using WATER PCB-SD0000033015 65 1 this bum or bad benzene in their PCBs, did they have any 2 problem with chloracne? 3 A. No. 4 Q. Was there ever any chloracne outbreak at the 5 Anniston, Alabama plant since that time in the early 6 '30's? 7 A. Not only there hasn't been an outbreak, there 8 hasn't been any cases. 9 Q. Did Jones, Dr. Jones, in his article which is 10 K 2, Exhibit K 2, did he recommend any safe handling 11 precautions ? 12 A. Yes, he did. 13 Q. Could youtellme whatthose were? 14 A. I'm looking it up. Well, he 15 Q. What page? Are you on page 1030? 16 A. 1030. 17 Q. Okay. 18 A. He said that they tried to prevent the 19 condition by being especially careful that all men engaged 20 in the manufacture of PCBs should have a thorough bath 21 after working hours and they should wear freshly laundered 22 clothing. Then he started talking about treatment. He 23 also then said Well, he didn't recommend it, but that 24 was studied. So the employment of enclosed distilling 25 apparatus and ventilation fans, there's a gradual WATER PCB-SD0000033016 66 1 improvement in the eruption. So the first time I was 2 there, I didn't see any open distilling apparatus, so 3 obviously if you were distilling stuff you're getting it 4 hot, and if it's open you're getting fumes, so they must 5 have been getting fumes there. 6 Q. Dr. Kelly, did you attend in June of 1937 a 7 symposium presented by Dr. Drinker? 8 A. Yes, I did. 9 Q. And are youfamiliar withthese three 10 articles by Dr. Drinker? I think you've already said 11 you're familiar with them. Exhibits K 3, K 4 and K 5. 12 A. Yes, I am. 13 Q. What types of testsdid Dr. Drinker perform? 14 A. He did three types of tests. He fed animals. 15 He had animals inhale the material. And then he fed 16 animals and subsequently fed them a known liver poison, 17 carbon tetrachloride. 18 Q. Can you take a look at these three exhibits, 19 and maybe you can tell me which one of these what order 20 you want to take discussing these three exhibits that 21 would be simplest to understand. 22 A. Well, I really don't think we ought to 23 need to talk about number two, which is K 4. That just 24 discusses the microscopic pathology of what happened to 25 the animals. WATER PCB-SD0000033017 67 1 Q. Okay. 2 A. I mean, I don't really I'll be happy to 3 discuss it, but it just talks about one detail of it. 4 Q. Okay. 5 A. But Drinker talks about what happens, so 6 that's included. I think we have to start withnumber 7 K 3, number one, and what do you want me to say? What are 8 you asking me? 9 Q. Well, take a look You know, you've got K 3 10 and K 5 in front of you? 11 A. Yes. 12 Q. Okay. And why don't you talk about them? I 13 think they are related. Why don't you talk about them 14 together? 15 A. Okay. Drinker startsoff with a statement of 16 the problem. He relates three employees of 17 Q. Was this K Let me ask you this. Was K 3, 18 the Drinker article, was it primarily focused on PCBs or 19 chlorinated naphthalenes? 20 A. It's primarily focused on chlorinated 21 naphthalenes because they were the majority of the 22 products tested. The only They tested halowaxes. 23 Halowaxes are primarily chlorinated naphthalene. In some 24 cases, there is ten percent of a compound which Halowax 25 called PCB and which Drinker, following Halowax' WATER PCB-SD0000033018 68 1 definition, called PCBs, but which subsequently were 2 proven not to be PCBs but to be chlorinated diphenyl 3 benzene, which is an entirely horse of an entirely 4 different color. I mean, they're somewhat related, but 5 they're, again, a lot different. So that's the There 6 are also a lot of different chlorinated naphthalenes, 7 depending upon the amount of chlorination. So he tested 8 about ten different compounds, one of which had ten 9 percent what he called chlorinated a PCB which 10 subsequently proved not to be PCB, and another one Halowax 11 with ten that he tested the . 12 Q. Let's stick with PCBs because that's what I 13 think we're most interested in in this case. 14 A. Well 15 Q. Did he 16 A. Okay. 17 Q. Did he test in K 3 PCBs? 18 A. No, he didn't. He tested what he called 19 PCBs, but he 20 Q. Why don't you explain that? 21 A. That's We have to go back to No. 5. 22 Q. Okay. Well, then 23 A. Here he says Drinker is testing what he 24 says is PCBs. He said it's got 65 percent chlorine in it. 25 Q. And by "here," you mean K 5? WATER PCB-SD0000033019 69 1 A. In K 3 . 2 Q. Okay. K 3. 3 A. He comes out with a statement saying this is 4 real toxic. Mr. Murray, that's page 288, where he says 5 "Chlorinated diphenyl. Chlorine" that would be a PCB. 6 "Chlorine content 65.0 percent." Then he says Then we 7 turn to page 297. 8 Q. Of Exhibit K 3? 9 A. Huh? 10 Q. Of 11 A. Exhibit KC K 3. In which he said that he 12 found that chlorinated PCB was quite toxic. Then when 13 he says that, I talked to him. I didn't raise my voice at 14 the symposium. I was up there. But I talked to him, and 15 I said, "Look, this is news to us. We don't believe that 16 our PCBs are that toxic, what you're getting here." And I 17 said, "Where did you get the PCBs? We didn't send you 18 any." And he said, "I got it from Halowax." I said, 19 "Well, are you sure they sent you the right stuff? In 20 fact, I'm not even sure we sell Halowax PCB. We sell 21 chlorinated diphenylbenzene." I said, "Why don't I send 22 you some PCB and you test it?" So we sent him some PCB 23 with as close to a chlorine content as he talked about. 24 He had 65 percent chlorine. We sent him chlorinated at 68 25 percent, which was the closest we had. And usually the WATER PCB-SD0000033020 70 1 higher the chlorine, the more toxic it ought to be. So he 2 tests this. 3 Q. And that's Exhibit K 5? 4 A. In K 5 he tests what is honest to goodness 5 PCB which we got right from our production run at 6 Anniston. Then I'll quote now from page 153. This is the 7 third paragraph, Mr. Murray, at the bottom of the left 8 column. The six 9 MR. MURRAY: Wait a minute. I'm sorry. K 5? 10 MR. CARNEY: We're on K 5 . 11 MR. MURRAY: I don 't have 153. 12 THE WITNESS: 153? 13 Q. 158 I think. It's the second to last page of 14 that exhibit. 15 A. 158, sorry. 16 Q. Yeah. 17 A. The sixth compound, which had been previously 18 listed as chlorinated diphenyl, a PCB I'll add that. 19 He didn't add that. It contains 65 percent of chlorine 20 and proved very destructive to the liver. Later 21 experiments with Compound 13, which contains 68 percent of 22 chlorine, which is also labeled chlorinated diphenyl, was 23 a surprise to us since the second compound was almost 24 nontoxic. On inquiry, it was found that Substance 6, 25 which he had tested proved so toxic, one, was in reality a WATER PCB-SD0000033021 71 1 mixture of chlorinated diphenyl and chlorinated 2 diphenylbenzene, and that No. 13, the number two compound, 3 was actually chlorinated diphenyl. 4 Q. If you would just explain to the jury what that 5 means, because there are a lot of big terms. 6 A. Sure. It means they tested apples in one 7 case and oranges in the other. They tested apples, 8 which in the first case, which proved toxic because it 9 was chlorinated diphenylbenzene, which is an entirely 10 different compound than chlorinated diphenyl, which is 11 PCB. In the second case, they tested the oranges, which 12 is pure PCB, and he came out with practically nontoxic. 13 So everything he has reported in his first article to 14 channel as far as testing chlorinated diphenyl is wrong 15 because he didn't test chlorinated diphenyl or PCBs, as he 16 explained in the second article. 17 Q. I got confused with your apples and oranges 18 analogy. 19 A. Well, he tested two different products. 20 Q. Okay. And just talk about Rather than use 21 the Use PCBs or wasn't PCBs so I can understand it 22 because I'm confused a little. 23 A. In his first article he tested what he called 24 PCBs that were not PCBs. They were chlorinated 25 diphenylbenzene. He found quite toxic. The second WATER PCB-SD0000033022 72 article Q. And the second article is K 5? A. K 5. He tested honest to goodness PCBs, and he said it's practically nontoxic. So then he says, in essence, "I was wrong calling this toxic stuff PCBs when it wasn't." Q. So he was wrong when he called what he thought were PCBs in K 3 fairly toxic? A. He was right in the fact that it was toxic, quite toxic, but it wasn't PCBs. Q. Okay. I understand. And he finally tested honest to goodness PCBs in Exhibit K 5 and found them almost nontoxic? A. That's correct. Q. Did Dr. Drinker or the others attending the June 1937 symposium at Harvard University suggest any safety precautions for working with chlorinated hydrocarbons such as PCBs? A. Yes, they did. Q. What were those? A. If the material gets on you, wash it off. Don't breathe the material at elevated temperatures Q. Could you describe or tell me some of the occupational physicians who attended this Dr. Drinker's symposium at Harvard University back in 1937? WATER PCB-SD0000033023 73 A. Sure. If you'll look starting on page 300, first there is Drinker. Q. Page 300 of K what? A. K 3. Q. Okay. A. First there was Drinker. Drinker is a well known toxicologist. He was a fellow that either along with his brother invented the Drinker respirator, iron lung, rather, so he was in the business a long time. Then there was Dr. von Oettingen, who was a Ph.D. and an M.D., really a top notch toxicologist, probably one of the fathers of toxicology in the United States, who was the director of the Haskell Laboratory in Wilmington, Delaware, who was a consultant for Westinghouse Electric. Q. Was there anybody from General Electric there ? A. Yeah. I'm getting there. Q. I don't know that you need go through all the names agarn. A. Oh, I thought you asked. Okay. Vosburgh, who was a medical director of General Electric. Q. Okay. And there were other doctors, prominent doctors from around the country? A. Most of them doctors, directors of labor and directors of public health of the various states, mostly WATER PCB-SD0000033024 74 1 New England, Massachusetts, Connecticut, and New York. 2 Those people. 3 Q. Doctor, were the PCB workers at the Anniston 4 plant in Alabama and the East St. Louis plant examined on 5 a periodic basis for chloracne or any other potential 6 work related health effect? 7 A. They were examined the same examination that 8 all the wage roll employees got. We did not do any 9 special examination on these people. We obviously The 10 examining physician looked at them for chloracne because 11 he was interested in it because that had occurred with PCB 12 workers at Anniston during the Swann time, so 13 Q. Did chloracne ever occur in any of the PCB 14 workers at Anniston and East St. Louis during the time 15 that you were employed at Monsanto? 16 A. No, it did not. Obviously I looked at them. 17 Chloracne, you know, you look at them. When you're 18 examining a fellow you look, and they were particularly 19 interested to see whether or not there was any, and there 20 wasn't. 21 Q. Did any of the workers at the Anniston, 22 Alabama plant or the East St. Louis plant ever demonstrate 23 any ill health effect related to their work with PCBs? 24 A. No, they did not. 25 Q. I'm about to go into a little bit different WATER PCB-SD0000033025 75 1 subject matter, and the tape is about to run out, so we'll 2 take a break. 3 (Brief recess.) 4 Q. Dr. Kelly, in addition to the regular 5 periodic examinations of the Monsanto workers, did you 6 perform any other examinations yourself personally? 7 A. Anytime while I was at Monsanto? 8 Q. Yeah. Did you ever have a special situation 9 where you examined the workers? 10 A. Well, remember, I was a plant physician at 11 the Queeny plant for four years part time, so I examined 12 the workers then. 13 Q. Okay. Other than that. 14 A. Yes. I mean, there would be occasional times 15 when I would examine a person for a particular reason. 16 But as far as PCB is concerned, on one occasion I examined 17 all the workers at the East St. Louis plant who were 18 currently employed in the PCB Department. I examined 19 those myself. 20 Q. Why did you personally perform those exams of 21 PCB workers? Was this In what period of time again? 22 A. Probably 1972 or '73. 23 Q. Okay. 24 A. Sometime the two years before I retired. 25 Q. Okay. Why did you do that? WATER PCB-SD0000033026 76 1 A. Well, there was a lot of interest in PCBs at 2 that time because they were found in the environment and 3 they were affecting birds, and there was a question came 4 up again about, well, are these liable to be affecting 5 people, these PCBs? So to allay any possible workers' 6 apprehensions and also to solidify my own thought that I 7 had always believed that these were not really 8 particularly toxic, I thought I'm going to do this myself 9 and read everything we can on it. So that's what I did. 10 We took these people, gave them a quite thorough 11 examination. We did 12 Q. Why don't you just describe what kind of an 13 exam you performed. 14 A. Well, obviously any exam like you do when you 15 go into a doctor for a thorough examination. You do a 16 history on them, on the person. These were all men who 17 had worked there for five years, ten, 12, 15 years in PCB 18 Department. 19 Q. How many workers were there approximately 20 that you examined? 21 A. Around 20, give or take three or four. 22 Probably 20 to 25 I think. And you do a history, then you 23 do a physical. You strip them down. You do a physical. 24 You check them all over from their eyes to their toes, and 25 I especially looked for any enlargement of the liver. I WATER PCB-SD0000033027 77 1 looked for chloracne. Then we did a battery of tests on 2 them. We did EKG's, we did chest x rays, we did liver 3 function tests. We did blood counts. We did the whole 4 battery of clinical tests. I think at that time the limit 5 was 12 SMA. Twelve They call it SMA 12. Now I think 6 it's either SMA 23 or something like that. But we did 7 every clinical test that you usually get if you go into a 8 hospital. Then we also did blood analysis for PCBs. 9 Q. Okay. What level of PCBs did the employees 10 have in their blood? 11 A. Well, using the methods we used then, which 12 were not as sophisticated as they were in the '80's or as 13 they are now in the late '80's or '90's, about half of 14 them had nothing. Some had a tenth of a part per million. 15 Some had two tenths of a part and one person had 16 five tenths of a part per million. Now, that I have to 17 say again that the methods were not sophisticated, as good 18 as they are now. Now they are talking about finding parts 19 per billion, not million, in the blood. So I'm not so 20 sure how good our analyses were, not anybody's analyses in 21 those days, in '72, how good they were in the blood. 22 Q. Were there any abnormal findings that you 23 found as a result of your exams and the laboratory work 24 that was done on these PCB workers in 1972? 25 A. Well, there was some abnormality. You take WATER PCB-SD0000033028 78 1 23 people, middle aged people, middle aged, forties and 2 fifties, you have some with high cholesterol. One fellow 3 had gout. He had a high uric acid. Nothing In fact, 4 the person with the high cholesterol had no PCBs in his 5 blood. So there was no relation. I could draw no 6 relationship. These people looked like a healthy 7 cross section of any of our plant employees. If we had 8 taken 25 people from any department, I think I'd have 9 gotten the same results. 10 Q. Did you provide the results of your 11 examinations and your lab work to anyone? 12 A. Oh, we told the workers obviously. I told 13 the plant manager, and I sent it into the government 14 because they were interested. I sent it into I don't 15 know which department, but it was some doctor I mailed 16 information to. 17 Q. Take a look at Exhibit K 6. Can you identify 18 that document? 19 A. Yes. That's the letter I wrote to this 20 doctor in whoever the Council of Environmental Quality 21 was, whatever they whoever they reported to. That was 22 I think before the days of the EPA. And EPA probably 23 Whether he was I don't know who he was with. But, 24 anyway, he was with the government, the United States 25 Government. The copy to Dr. Osland. Dr. Osland was a WATER PCB-SD0000033029 79 1 plant physician at East St. Louis. 2 Q. And just for the record, this is your letter 3 to the doctor with the U.S. Government dated May 10, 1972? 4 A. That's correct. 5 Q. And did this report Did you report in this 6 letter the results of your examinations and your 7 laboratory tests on the East St. Louis PCB workers? 8 A. Yes. And I think I'll have to correct my 9 previous statement when I said a high cholesterol 10 didn't had no PCB. It was the liver enzymes that were 11 elevated on one person, and they didn't have they had 12 no PCB in the blood. But I didn't correlate I didn't 13 check on their alcoholic history particularly. 14 Q. And I note I don't want to be critical of 15 you, Doctor, but you said 23 workers, and the letter says 16 27. Does that refresh Was it 27? 17 A. There were 27, but 18 years ago coming within 18 four is not bad. 19 Q. What did you tell Dr. Davis, the U.S. 20 Government doctor, about the PCB workers' health? 21 A. Well, I think it's summarized in the last 22 paragraph. "In summary, I can say that these workers were 23 as healthy as any cross section of our plant workers of 24 the same age." 25 Q. Did Monsanto cooperate fully with the WATER PCB-SD0000033030 80 1 government in relation to their inquiries about the East 2 St. Louis PCB workers? 3 A. Oh, certainly. In fact, I think sometime 4 some of the government people came down. They were going 5 to see whether it was worthwhile to do a full blown 6 investigation, and they said, "I don't think so," "they" 7 meaning the government said. So they never came. But 8 they had sent two or three people down to go through the 9 plant. 10 Q. I think you mentioned earlier in your 11 testimony that you reviewed workmen's compensation 12 records. Are you aware of any workmen's compensation 13 claim that was filed by a Monsanto worker relating to a 14 PCB related health claim? 15 A. I'm aware of none. 16 Q. And I think you've also testified that you 17 reviewed during the time you were Medical Director of 18 Monsanto all of the customer or user complaints that were 19 health related concerning Monsanto products. Did you 20 receive any customer or user complaints about chloracne or 21 any other claimed health effect in relation to PCBs? 22 A. No, I didn't, but let me correct your When 23 you say I reviewed them, your preamble to that question 24 was "Did you review the customer letters?" I didn't At 25 the end of the year, I didn't look up all the letters. WATER PCB-SD0000033031 81 1 When they came in, they came in to me, and I saw them. 2 Q. Okay. I'm sorry. 3 A. And they were So I didn't collect them, 4 you know, look, see what have I got this year. As they 5 came along, I looked at them. But, no, there were none. 6 Wait. With the one exception that this Crown Chemical was 7 one, and obviously What was the last part of your 8 question? I want to be sure. 9 Q. Well, I'm Do you remember approximately 10 over the years how many customer complaints or user 11 complaints there were with regard to health problems? 12 A. I could count on the fingers on one hand. I 13 remember two, this Crown Chemical and this thermometer 14 outfit. 15 Q. You've mentioned I think you've already 16 covered those. 17 A. Yes. 18 Q. So you think it was 19 A. Less than five. 20 Q. Okay. Have you ever had any complaint from 21 anyone in the transformer or capacitor industry regarding 22 a PCB related health problem? 23 A. I have not that I can remember, and I do not 24 believe I had. 25 Q. Have you ever had a complaint or a report WATER PCB-SD0000033032 82 1 from Westinghouse or General Electric concerning a PCB 2 health related problem? 3 A. No, sir. Not that I can remember, and I 4 don't believe I did. 5 Q. Have you ever received any complaint 6 regarding a fatality or a serious long term health illness 7 related to PCBs? 8 A. No, sir, I have not. 9 Q. Dr. Kelly, at the time of your retirement 10 from Monsanto in 1974, did you have an opinion to a 11 reasonable degree of medical certainty concerning the 12 toxicity of PCBs in relation to human health? 13 A. Yes, I did. 14 Q. And what was that opinion? 15 A. Well, that PCBs do have a certain amount of 16 toxicity, which is not unusual for an industrial chemical, 17 but that its use both in our plants and our customers' 18 usage has not been connected with any illnesses as far as 19 any information that I could gather from the published 20 literature or from the customers themselves. 21 Q. Do you have an opinion on whether it can be 22 used safely in the workplace if the Monsanto safe handling 23 instructions are followed? 24 A. Oh, no question. I'm sure it has for the 25 past 40 years. WATER PCB-SD0000033033 83 1 Q. What is that opinion based on? 2 A. It's based on several things. One, the 3 moderate toxicity of the product from an industrial point 4 of view. Two, the experience that I have with the 5 Monsanto workers. Three, the experience that I've had in 6 talking to like the people who were using the material. 7 Four, the absence of any clinical case reports in any 8 significant amount. Four, the fact that government 9 epidemiologists have carried out studies and stated that 10 there has been no clinical disease associated with the use 11 of it. 12 Q. Did that opinion of yours vary at all during 13 the time you were at Monsanto? 14 A. No, sir, it did not. 15 Q. Have you continued to review the available 16 medical and scientific literature on the subject of PCBs 17 from your retirement to the present? 18 A. In the English language, yes, sir. I may not 19 get all of them, but the prominent journals I see. 20 Q. And are your opinions with regard to the 21 safety of PCBs in the workplace if the Monsanto safe 22 handling procedures are followed, is that your opinion 23 today? 24 A. Yes. I think it's been strengthened by the 25 years. WATER PCB-SD0000033034 84 1 Q. Is there any recent medical or scientific 2 literature that supports your conclusion? 3 A. Oh, quite a bit. 4 Q. Can you give me that? 5 A. I'll give you one. 6 Q. Okay. 7 A. Do you mind me reading from Exhibit K 7? 8 Q. Okay. That's the next exhibit I was going to 9 show you anyway. Why don't you identify K 7 for the 10 record? 11 A. This is a report by Dr. Renate, Renata 12 (sic.), Kimbrough, Kimbrugh (sic.), published in 13 1987, the "Annual Review of Pharmacology and Toxicology". 14 Q. That's the publication? 15 A. That's the publication. The "Human Health 16 Effects of Polychlorinated Biphenyls," that's PCBs, "and 17 Polybrominated Biphenyls," PBB. That's a different 18 compound completely. One has got chlorine in; the other 19 has got bromine in. One is used for an insecticide, I 20 believe, and some agricultural products. That's the PBB. 21 And PCBs are the things we've been talking about all day. 22 Q. And just for the record, who is Dr. Renate 23 Kimbrough? 24 A. She has been working with PCBs for 20 years 25 at least, I think. She is with the Center for WATER PCB-SD0000033035 85 1 Environmental Control for the Public Health Service. 2 Q. That's the U.S. Government? 3 A. Oh, that's the U.S. Department of Health and 4 Human Services, Atlanta, Georgia. She is the They've 5 moved her around from different departments, but she is 6 the number one government expert on PCBs. She is the 7 individual who did two year toxicological work on some 8 PCBs. In fact, she found, according to her work with her 9 pathologists that there were liver tumors developed in 10 animals. So she certainly takes an independent point of 11 view as far as toxicity of PCB is concerned. In animals, 12 she's We don't agree with her, but she's an independent 13 person and a government person of high repute, and she's 14 good. 15 Q. Okay. What does she say in her article about 16 the human health problems associated with PCBs? 17 A. Well, I Go to page 106, Mr. Murray. 18 Q. Okay. And let me If you're going to read 19 from page 106, I'd like to take a blow up of that so I 20 can the jury can read along with you on that. Can you 21 get this in? 22 A. She says in her second to last 23 Q. Hold on till we make sure the camera is 24 focused. Okay. 25 A. This quote's from this article. It's the WATER PCB-SD0000033036 86 1 second to last paragraph on page 106. She states in 2 humans "When humans were exposed only to PCBs or 3 PBBs" that's polybrominated "the only acute effects 4 have generally been minor. So far, no significant chronic 5 health effects have been causally associated with exposure 6 to PCBs or PBBs." 7 Q. What does "chronic" mean? 8 A. Long term. 9 Q. Okay. So she's saying that there's no 10 significant long term health effects associated with PCBs? 11 MR. MURRAY: Object to the question as 12 leading and as rephrasing the article itself, which has 13 already spoken for itself. 14 Q. Okay. Maybe Rather than me rephrase it, 15 Doctor, can you indicate in more lay language what Dr. 16 Kimbrough is saying? 17 MR. MURRAY: Object to paraphrasing what Dr. 18 Kimbrough is testifying to. You can go ahead, Doctor. 19 Q. Go ahead, Doctor. 20 A. I can't hear the objection. Does it make a 21 difference? 22 Q. You don't need to hear the objection I don't 23 think unless Mr. Murray wants to repeat it. That will be 24 taken up later by the court. 25 A. What was your question, Mr. Carney? WATER PCB-SD0000033037 87 1 Q. Could you just in more lay language tell me 2 what Dr. Kimbrough is saying? 3 A. Sure. What she is saying is when people were 4 exposed to PCBs, there have been a few minor acute 5 effects. 6 Q. By "acute effects," what do you mean? 7 A. Got sick. 8 Q. What does "acute"mean? 9 A. Short term, or it happens Like you get a 10 cold, that's an acute illness. 11 Q. Okay. 12 A. That's the hepatitis I was talking about 13 earlier. So far no chronic significant chronic health 14 effects have been associated. In other words, nobody got 15 sick while working with PCBs. 16 Q. Okay. Take a look at Exhibit K 8. Can you 17 identify Exhibit K 8? 18 A. Yes. This is an article by Dr. Kimbrough. 19 She was at that time the same Dr. Kimbrough I talked 20 about with the EPA the Director of the Health and Risk 21 Capabilities. 22 Q. And what's the date of that article? 23 A. That's August 1988. That means she's the 24 person that's supposed to go over health risk, what sort 25 of a risk do we have to the people or to the workers. She WATER PCB-SD0000033038 88 1 was with the APA EPA. Now, what she says 2 Q. By "EPA," that's the Environmental 3 A. Environmental Protection Agency of the United 4 States Government. 5 Q. Okay. 6 A. She says on page three of this report, "Thus, 7 despite positive laboratory data animal data, and 8 except for chloracne" It's the last paragraph, sir. 9 I'll repeat. 10 Q. Why don't you start over again? 11 A. "Thus, despite positivelaboratory animal 12 data and except for chloracne, exposure to PCBs has led to 13 no convincing, clinically demonstrable, chronic health 14 effects in humans." 15 Q. That's Dr. Kimbrough'slast sentence and 16 conclusion of her article in August of '88? 17 A. That's correct. And I want to emphasize that 18 here's a woman that found laboratory damage in rats with 19 giving them one PCB. So she did that work, she's 20 knowledgeable about it, been knowledgeable for 20 years, 21 but she's an honest government worker, a very competent 22 worker, and says, "We haven't had any problems." 23 Q. Has Dr. Kimbrough had any affiliation with 24 Monsanto? 25 A. None at all. WATER PCB-SD0000033039 89 1 Q. Has she had any affiliation or employment by 2 private industry? 3 A. Not that I know of. 4 Q. Take a look at Exhibit K 8A. I'll ask you if 5 you can identify that exhibit. 6 A. This is a Health Hazard Evaluation Report by 7 the National Institute for Occupational Safety and Health, 8 also called N.I.O.S.H, N I O S H, which is an arm of the 9 U.S. Government that's situated I think in North Carolina 10 that deals with health effects of various chemicals on I 11 guess both workers and the human population at large. 12 Q. This is I don't know if you gave a date. 13 A. Dated June 1990. It's an analysis of the 14 workers of the Westinghouse Electric Company in 15 Bloomington, Indiana. 16 Q. And could you just briefly describe what type 17 of study N.I.O.S.H. performed on these Bloomington, 18 Indiana Westinghouse PCB workers? 19 A. Yes. They went through an analysis, an 20 examination of these workers, their medical records. They 21 had a questionnaire. They did something like 20 blood 22 tests. They did urine tests. I'm trying to look to see 23 if they did physical examinations also. They took all the 24 symptoms. They assessed liver functions, kidney 25 functions. They did a pretty thorough examination on WATER PCB-SD0000033040 90 1 these people. 2 Q. What did N.I.O.S.H. conclude in June of 1990 3 about the Bloomington PCB workers' health? 4 A. They said on the summary on the first page, 5 "No clinical abnormalities attributable to exposure to 6 PCBs were observed." Clinical abnormalities means you 7 examine a person, he has no sickness. I mean, a clinical 8 abnormality, if you're normal, you're well. If you have 9 an abnormal clinical If you have an abnormality in your 10 clinical makeup, you're sick. 11 Q. Okay. 12 A. They said, when the prevalence of symptoms 13 and overt overt means obvious clinical disease were 14 investigated by exposure group, there was no difference 15 between the exposures, no difference between the groups. 16 In other words, people who had higher exposures weren't 17 any different than people with lower exposures. And there 18 was just a positive association with one GGTP, that's a 19 liver enzyme, and a negative association with urinary 20 creatinine. That really doesn't mean anything. The GGTP 21 just meant that people in the higher exposure group might 22 have more positive findings with this liver enzyme, which 23 is a very sensitive liver enzyme. If you had two drinks 24 the night before, it would show up in changes in your 25 GGTP. So, in essence, what these people said was we WATER PCB-SD0000033041 91 1 examined these workers and could find no connection 2 between their work and their illness. 3 Q. They found no evidence of any sickness 4 attributable to exposure to PCBs? 5 A. That's correct. 6 MR. MURRAY: Object to the question. 7 Q. I'd like to hand you now, Doctor, Exhibits 8 K 9 or Actually I'll let you hand yourself those. They 9 are right beside you. Look at K 9 and K 10. 10 A. Yes, sir. 11 Q. Can you identify those two exhibits? 12 A. Yes. They are two exhibits called "The 13 Aroclors, Physical Properties and Suggested Applications". 14 They both carry the number P 115. 15 Q. I don't know that youneed 16 A. One seems to be 1946. There's a statement on 17 it it's 1946. I don't know the basis of the other one, 18 but it's a little later. 19 Q. Okay. Are these Monsanto bulletins on PCBs 20 called Aroclors? 21 A. Yes. They are official Monsanto bulletins 22 that were published by Monsanto and disseminated to 23 customers. 24 Q. Take a look atExhibit K 11. 25 A. Yes, sir. WATER PCB-SD0000033042 92 1 Q. Can you identify that exhibit? 2 A. Yes. That's a memorandum. It looks like 3 it's a memorandum to file by an L. A. Watt. Linn Watt was 4 an individual He was a chemist in Organic Division, 5 which manufactured Aroclors. 6 Q. He was a Monsanto employee? 7 A. He was a Monsanto employee. It's dated 8 October 11th, 1937, a year and a half after I came with 9 the company, and he This memorandum deals with a 10 conversation I had with him, and it appears we were 11 writing information concerning the toxicity and safe 12 handling procedures to be used with Aroclors or PCBs so 13 that it could be used in the Aroclor booklets and quoted 14 in correspondence as it might be necessary. 15 Q. Did you as early as 1937 approve the safe 16 handling wording for technical bulletins and other 17 materials published by Monsanto? 18 A. Well, as I said, it was not formalized. If 19 they came to me I did, obviously, what came to me, so I 20 can't say that in '37 I did it in all the ones, but 21 Q. After you became Medical Director, you were 22 the one to approve that language? 23 A. That's right. But certainly from '37 on the 24 Aroclor bulletin booklets were approved by me because Watt 25 and I were pretty close on this. WATER PCB-SD0000033043 93 1 Q. Is the language that appears on K 11 language 2 that you approved in 1937 with regard to safe handling for 3 PCBs ? 4 A. Yes, I probably wrote it. 5 Q. Could you read that approved language that 6 you approved back in 1937? 7 A. Yes. "Experimental work in animals shows 8 that prolonged exposure to Aroclor vapors evolved at high 9 temperature or by repeated oral ingestion will lead to 10 systemic toxic effects. Repeated bodily contact with the 11 liquid Aroclors may lead to an acne form skin eruption. 12 Suitable draft ventilation to control the vapors evolved 13 at elevated temperatures as well as protection by suitable 14 garments from extensive bodily contact with the liquid 15 Aroclors, should provide prevent any untoward effect." 16 Now, let me mention, Mr. Carney, that this takes care of 17 Aroclors. Some Aroclors are not PCBs. The chlorinated 18 diphenylbenzene is an Aroclor. That's the one that was 19 proven toxic by Drinker. But it is not a PCB. But this 20 would go into all Aroclor bulletins, which would include 21 chlorinated diphenylbenzene. 22 Q. And it would include PCBs? 23 A. It would include PCBs, but also it would 24 include things that were not PCBs. 25 Q. I understand. Could you review the toxicity WATER PCB-SD0000033044 94 1 section in Exhibits K 9 and K 10, the ones you were just 2 looking at? 3 A. Whoops! Go back. 4 Q. Are they on the table there? 5 A. Oh, here we are. 6 Q. And if you could just tell the jury the 7 source of the safe handling information that appears in 8 the toxicity section in those two exhibits. 9 A. Well, the source was R. E. Kelly. I mean, I 10 wrote it. 11 Q. The source was you? 12 A. Yes. 13 Q. Okay. And was the safehandling information 14 that was in Exhibits K 9 and K 10 identical to the safe 15 handling information you just read that was in K 11? 16 A. That's correct. 17 Q. Are the technical bulletins that we've marked 18 as K 9 and K 10, are they directed to any particular 19 industry? 20 A. No, I don't think so. I think it's pretty 21 widespread because they talk about the applications that 22 go from adhesive, electrical equipment, hydraulic fluids, 23 lubrication, possible uses which hadn't been developed so 24 far, but paints, plastics, varnishes, et cetera, coatings, 25 rubber substitutes. It's the whole gamut. This bulletin WATER PCB-SD0000033045 95 1 was directed to anybody who thought they could use it or 2 anybody who thought that Aroclor could be fitted into 3 their products. 4 Q. Let's next, Doctor, look at Exhibits K 12 5 through K 15. 6 A. Yes, sir. 7 Q. Are thosevarious product bulletins published 8 and distributed by Monsanto over the years relating to 9 PCBs ? 10 A. Yes, sir, they are. 11 Q. And are these exhibits, K 12 through K 15, 12 directed to any particular industry? 13 A. Yes, sir. The electrical industry. 14 Q. Is there safe handling and toxicity 15 information in relation to PCBs in all of these bulletins, 16 K 12 through K 15? 17 A. I'm sure they are. I'll go through them and 18 find the pages. We start with K 12. There's a page on 19 page 17 that describes the toxicity and describes the safe 20 handling procedures to be used. 21 Q. Okay. Why don't you go to the next one? 22 A. K 13, that's got two pages, pages 75 and 76, 23 which describes some toxicity information and describes 24 what should be done on various operations in the 25 electrical industry, and they talk about what should be WATER PCB-SD0000033046 96 1 done when you're sampling tank cars. They say what if 2 you're exposed to Aroclor vapors at relatively high 3 temperatures, such as opening a heated capacitor 4 impregnating chamber, sort of like a bake oven, I suppose, 5 a respirator should be worn during short intervals. They 6 give the gamut of safety precautions for workers in the 7 electric industry. 8 Q. Okay. And does Exhibits 14 and 15 also 9 include safe handling information? You don't need to go 10 into detail on it, but I just want to know 11 A. Yes. 12 Q. whether they include that. 13 A. Yes, they do. 14 Q. Okay. And did the Monsanto Medical 15 Department approve of the safe handling information about 16 Aroclors which or PCBs in these Exhibits K 12 through 17 K 15? 18 A. Yes. Well, we wrote them. I mean, if there 19 was some engineering additions, we approved that. 20 Q. Did the safe handling andtoxicity 21 information about PCBs in these technical bulletins vary 22 greatly from year to year? 23 A. No. With the one exception, two exceptions. 24 One, when the stuff started PCBs were started to be 25 used as a plasticizer, we had run some patch tests on it WATER PCB-SD0000033047 97 1 to be sure that the addition of PCBs to, say, a plastic 2 seatcover in an automobile wouldn't cause any trouble to 3 somebody sitting on there with shorts, wouldn't cause any 4 irritation or sensitivity to the skin. So we ran some 5 patch tests, which is just a type of test which doesn't 6 isn't intended to deal with the inherent toxicity or lack 7 of toxicity but with the possibility of causing skin 8 irritation. So we added that. Then another large, sort 9 of good size change was when the environmental aspect of 10 PCBs became prominent we put information in the bulletins 11 about how to control the release of it to the environment 12 and the possibility of harm to birds and fish or something 13 of that sort. 14 Q. Okay. We'll get to that a little later. 15 A. But, I mean, that's where it changed. Those 16 are the two changes I think. 17 Q. But with the exception of those two changes, 18 did the language about safe handling and toxicity in these 19 technical bulletins concerning PCBs stay relatively the 20 same? 21 A. Oh, yes. I'm not sure whether the language 22 was just the same, the phraseology, but the basic 23 information was the same. Whatever was in there was 24 approved by us. It wasn't edited by anybody. Before the 25 final thing went to the printer, we saw it, we okayed it. WATER PCB-SD0000033048 98 1 Q. Take a look at Exhibit K 13. Why don't you 2 read the title of K 13? 3 A. K 13 is a memorandum of mine on Monsanto 4 letterhead, dated March the 4th, 1941, "Toxicity and Safe 5 Handling of Askarel". 6 Q. I think you're looking at the wrong K 13. 7 A. I'm up to 16. 8 Q. I'm sorry. I may have misspoke, but if you 9 could look at K 13. 10 A. Oh, sorry. 11 Q. Give me the title ofthat. 12 A. K 13. 13 Q. It's a thick 14 A. Oh, I see it. "The Proper Handling of 15 Aroclors and Their Mixtures in the Electrical Industry". 16 Q. And, again, Aroclors can be PCBs; is that 17 right ? 18 A. Oh, yes. All PCBs are Aroclors. 19 Q. Okay. And 20 A. Dated May the 1st, 1956. 21 Q. Okay. And would you take a look at page 75 22 of that rather thick exhibit, and does the last paragraph 23 of page five give information concerning safe 24 concentration of PCB vapors in the workroom air? 25 A. Yes, it does.It states WATER PCB-SD0000033049 99 Q. And is that I don't know that you need to read it unless you want to. And was that safe handling information about safe air levels written by you or someone else in the Monsanto Medical Department? A. Yes, it was. Q. Where did you get that information concerning suggested safe levels of concentration of vapors? A. Well, I arranged for a long term When I say "long term," it was a period of weeks or a couple of months, I suppose, of inhalation of Aroclor vapors at University of Cincinnati Medical School in 1955. That was published. That was the maximum safe concentration that was recommended by the by Dr. Treon, who did the work. Afterwards we cut the level down to half that. Q. Okay. But in order to get the safe levels of vapors in the air, you had some testing done by Dr. Treon? A. Oh, yes. I mean, to find it out. In order to get these levels up, we had to heat the material to get it up there. Q. Okay. And why did Monsanto use Dr. Treon at the He was at what laboratory? A. Kettering Laboratory, Kettering, at the University of Cincinnati Medical School. Q. Why did Monsanto use that laboratory? A. Well, here's an independent research WATER PCB-SD0000033050 100 1 laboratory at a prominent medical school and a man who 2 knew his business and was completely dissatisfied. He was 3 an independent scientist, and he had high standing. 4 Q. Take a look at K 14 and K 15. I think K 14 5 is right there. 6 A. Yeah. I have them. 7 Q. Could you read the title for K 14, if you 8 can? My copy isn't very good. 9 A. Well, the second page I guess it's the 10 same. "Askarel," A s k a r e 1, "Inspection and 11 Maintenance Guide". 12 Q. What's Askarel? 13 A. Askarel is the general name used by the 14 electrical industry for PCB containing transformer fluids. 15 I'm not sure if it includes all transformer fluids or not. 16 But I know it refers also to PCB containing fluids. 17 Q. So Askarel is aPCB? 18 A. Yes. Well, yes. They Yeah, they Yeah, 19 it's a generic name, that means the usual name, for fire 20 resistant liquid insulation. That means transformer 21 fluids. Askarel is Transformer Askarel is manufactured 22 by Monsanto. 23 Q. And Askarel is a PCB? 24 A. PCBs, yes. 25 Q. Okay. And then read the title for K 15. WATER PCB-SD0000033051 101 1 A. "Transformer Askarel Inspection and 2 Maintenance Guide". 3 Q. And K 14 then and K 15 both are PCB 4 inspection and maintenance guides put out by Monsanto 5 A. That's correct. 6 Q. for Monsanto? 7 A. That's correct. The second one, the K 15, is 8 dated March 1975. 9 Q. Did anyone Did Monsanto in K 14 or K 15 10 acknowledge any contributors to the information about the 11 PCBs in K 14 and K 15? 12 A. Yes. I think I've seen them someplace. Yes. 13 On page one of K 14, "Monsanto gratefully acknowledges the 14 assistance, guidance, and the contributions of certain 15 data by the following: Frank M. Clark. . ." 16 Q. Just read the company names, if you would. 17 A. General Electric. 18 Q. I don't think the names will mean anything 19 other than company names. 20 A. Two people from General Electric, one from 21 Westinghouse, one from Allis Chalmers. That's it in K 14. 22 K 15 23 Q. Did anyone contribute to the information in 24 K 15, any company? 25 A. Someplace in here. I've seen it. Yes. WATER PCB-SD0000033052 102 1 Q. I think it's on page 2 A. Yes. On page one they gratefully acknowledge 3 the assistance, guidance, and contributions by the 4 following. A man from G.E. and a man from Westinghouse. 5 Q. And G.E. meaning? 6 A. General Electric. 7 Q. Okay. Now let's go on to Exhibit K 16. 8 A. Yes, sir. 9 Q. Can you identify that document? 10 A. This is a memorandum or really a letter of 11 mine or a statement of mine 12 Q. Let me stop you. I forgot to ask you one 13 thing about these exhibits, K 9 through K 15, these 14 product bulletins on PCBs that Monsanto put out. Would 15 those bulletins have gone to Westinghouse and General 16 Electric? 17 A. Oh, yes. Certainly. 18 Q. Now let's go to K 16. Can you identify that? 19 A. This is a statement by me in the form of 20 well, almost in the form of a letter, a general one page 21 bulletin, as it were, on the toxicity and safe handling of 22 Askarel, A s k a r e 1, again. 23 Q. Again, a PCB? 24 A. PCBs, dated March the 4th, 1971. 25 Q. And what Can you just summarize briefly WATER PCB-SD0000033053 103 1 the safe handling recommendations of Monsanto for PCBs in 2 that bulletin? 3 A. Yes. I stated there about my impression of 4 the general toxicity saying it's only slightly toxic from 5 the standpoint of accidental ingestion, if you swallow it, 6 or single accidental massive skin exposure, if you get it 7 on you and you wash it off, you're all right. Single 8 exposures of vapors aren't bad, aren't serious. Because 9 it's irritating, nobody is going to stand around there too 10 long. And I said repeated or prolonged skin exposure 11 should be avoided. I said it may be absorbed if it's 12 allowed to remain on unbroken skin, so we recommend it be 13 washed off with soap and water if there's contact. We 14 talk about when it's hot how you treat it. And then I 15 said there's no significant vapor inhalation at room 16 temperature, but if its vapors are allowed to be heated it 17 can be injurious, and I gave threshold levels for it. 18 That's the amount that could be safely used. 19 Q. And who would get a document like K 16? 20 A. Everybody in the electrical industry. 21 Q. Let's go to Exhibits K 17 And by 22 electrical industry, you would include Westinghouse and 23 General Electric? 24 A. They are very big in the electrical industry. 25 Q. Okay. Let's go to Exhibit K 17 through K 20. WATER PCB-SD0000033054 104 1 A. Yes, sir. 2 Q. Are these various product bulletins published 3 and distributed by Monsanto over the years relating to 4 Pydrauls or PCB containing hydraulic fluids? 5 A. Yes, they are. 6 Q. Is there safe handling and toxicity 7 information in relation to PCBs in all three of these 8 in all four of these bulletins? 9 A. I feel sure there is, but I'll have to look 10 it up. Yes, there is, at page 11 and 12. 11 Q. And you're looking at K 17? 12 A. K 17, yes, sir. 13 Q. Is there also toxicity and safe handling 14 information in K 18, 19 and 20? 15 A. There is in 18 on page K 18 on page 18. 16 That's convenient. On K 19, it's on page 12. On K 20 17 I can't make the page out, but it's the second to last 18 page. Page 13, yes. 19 Q. Did your Monsanto Medical Department approve 20 the safe handling and toxicity information in each of 21 these bulletins, K 17 through K 20? 22 A. Yes, we did. 23 Q. And who received the bulletins which 24 contained the information on safe handling of the PCBs 25 called Pydrauls? That's K 17 through 20. WATER PCB-SD0000033055 105 1 A. Anybody who bought the material. Anybody who 2 was interested in using it. 3 Q. So all of the customers that Monsanto sold 4 Pydrauls to would get these bulletins? 5 A. Yes, sir. To the best of my knowledge. 6 Q. Let's take a look at K 21 and K 22. Can you 7 identify those two exhibits? 8 A. I've got K 22, but K 20 who? 9 Q. K 21 and K 22. 10 A. Okay. Oh, yes. Yes, I have it. I'm sorry. 11 K 21. 12 Q. Are those two exhibits product bulletins 13 published and distributed by Monsanto relating to 14 Therminol, a PCB containing heat transfer fluid for closed 15 heat transfer systems? 16 A. Yes. The title page on mine is not very 17 remarkable. I can't make it out. 18 Q. On K 21? 19 A. On K 21. But they talk about it on the third 20 page. They talk about it being used as a heat transfer, 21 for general heat transfer, so they talk about it. 22 Q. Okay. What about K 22? Is that a product 23 bulletin published by Monsanto on Therminol? 24 A. Yes. That's entitled "Therminol Fluid Heat 25 Systems". WATER PCB-SD0000033056 106 1 Q. And, again, Therminol was the PCB? 2 A. Heat transfer. Is a PCB, yes, sir. It 3 contains PCB. 4 Q. Did these two bulletins, K 21 and K 22, 5 contain safe handling and toxicity information relating to 6 PCBs ? 7 A. I'm sure they do, but I'll have to look it 8 up. It's going to take me a little time because there's 9 no index. Yes. I can't make a page out, but there's 10 safety of operation that has safety of handling. It's 11 page 16 on K 21. 12 Q. Okay. 13 A. We go to K 22. That's easier. That's got an 14 index. That's on page 46. 15 Q. Okay. Did the language in these bulletins 16 regarding the safe handling information vary from year to 17 year except for that environmental information that was 18 added? 19 A. No, not as far as the basic information is 20 concerned. I mean, it may vary in the length of it or the 21 phraseology or something like that, but the basic 22 information is the same. 23 Q. And what was that basic information? 24 A. The basic information was, as far as safe 25 handling procedure is concerned, avoid repeated or WATER PCB-SD0000033057 107 1 prolonged skin contact and avoid breathing the fumes in 2 confined spaces or at elevated temperatures. 3 Q. Who received these bulletins containing the 4 information on safe handling of Therminols, Exhibits 23 5 or 21 and 22? 6 A. Every customer, potential customer, anybody 7 interested in heat transfer systems. Certainly customers, 8 anybody who was being approached by one of our salesmen, 9 was given one of these. 10 Q. So customers of Therminol would get Exhibits 11 K 21 and K 22? 12 A. Yes, sir. 13 Q. Let's take a look at Exhibit K 24. Can you 14 identify that document? 15 A. Yes. This is another bulletin of mine dated 16 January the 23rd, 1967. 17 Q. Did you read You said '67? 18 A. '69. 19 Q. Okay. 20 A. "Toxicity and Safe Handling of Therminol 21 FR 1, FR 2, FR 3". 22 Q. And you prepared that exhibit? 23 A. Yes, I did. These different Therminols have 24 varying percentages of PCB in it. There might be some 25 little different PCB in it. May be mixtures. But they WATER PCB-SD0000033058 108 1 are all PCBs. 2 Q. And what was done with a document like K 24 3 about safe handling of Therminols? 4 A. Well, this was sent by the Medical Department 5 to all the various sales offices. Whether or not the 6 individual salesmen used this or a bulletin giving it to 7 the customers, I can't be sure. But it certainly is 8 something we sent out to anybody that inquired about the 9 toxicity and safe handling of these various Therminols. 10 Q. Are these technical bulletins that I've 11 that you've reviewed in the last 10 or 15 minutes, K 9 12 through K 24, all of the bulletins which Monsanto 13 published and distributed on the topic of PCBs? 14 A. I wouldn't know. I think there may have been 15 more, but I don't know. I mean, they are certainly 16 representative of them. 17 Q. Okay. Okay. Why don't we take a break? The 18 tape's about to run out. 19 (Luncheon recess.) 20 Q. Okay, Dr. Kelly, if you now take a look at 21 Exhibits K 23 through K 33A. 22 A. K 20? 23 Q. I'm sorry. I gave you the wrong number. 24 K 25 through K 33A. 25 A. Yes, sir. WATER PCB-SD0000033059 109 1 Q. Can you identify those documents? 2 A. These are Material Safety Data Sheets. That 3 is a sheet put out by the Department U.S. Department of 4 Labor. It was put out primarily at first for use in 5 transportation, but then it was adapted or accepted by 6 asked for by any number of customers. They would send 7 these to a supplier and say, "Fill these out and send them 8 back to us." 9 Q. And did Monsanto Company fill out the 10 information on the Material Data Safety Sheets that are 11 Exhibits K 25 through 33A? 12 A. Yes, we did. 13 Q. And these Material Safety Data Sheets relate 14 to what relate to PCB material? 15 A. These particular group, K 25 to 33, relate to 16 PCBs. We filled them out on probably every chemical we 17 made at all. 18 Q. Okay. And did someone And there is 19 safe product safety information on these Material 20 Safety Data Sheets? 21 A. Yes. That's the purpose of it obviously, 22 safety. Data means information. Safety information. And 23 there's health hazard data and fire and explosion hazard. 24 We filled out the health hazard data. We filled out the 25 section on precautions. WATER PCB-SD0000033060 110 1 Q. By "we," meaning? 2 A. We being the Medical Department. 3 Q. Monsanto Medical Department? 4 A. Monsanto Medical Department. 5 Q. Just so it's clear to the jury, what 6 information did the Monsanto Medical Department fill out 7 on these safety data sheets? 8 A. Section five, health hazard data. Section 9 nine, special precautions. 10 Q. And did you approve the language that appears 11 in those sections? 12 A. Yes, I did. 13 Q. Who did you send these sheets to? 14 A. I think they were really sent in response to 15 inquiries from customers. I don't believe we sent these 16 out willy nilly to everybody at all of our customers. 17 Usually a customer would ask for the safety data sheets. 18 Q. Okay. 19 A. I'm not too clear onthat, whether they were 20 sent out, whether they accompanied the salesman into a 21 customer's plant or not. 22 Q. And were these sheets sent to shippers as 23 well? 24 A. Oh, yes. Primarily itstarted as a safety 25 data sheet in transportation. WATER PCB-SD0000033061 Ill 1 Q. Let's take a look now at Exhibits K 34, 35 2 and 36, and I'll ask you if you can identify those 3 exhibits. 4 A. Yes, I can. K 34 is a label for Aroclor, 5 which is a chlorinated a PCB. They use a little 6 different technical term on it, but it's a PCB. K 35 is 7 the same, a caution label. K 36 is a caution label which 8 has been used on Aroclor, which is a PCB but is also a 9 chlorinated hydrocarbon. 10 Q. Are these early labels that were used for 11 PCBs by Monsanto? 12 A. Yes, they were. 13 Q. Okay. And let me We've got a blowup of 14 two of these labels, K 34 and K 36, and I'll ask you is 15 K 34 is the label that's down here at the lower corner 16 that I'm pointing to? 17 A. Is it what? 18 Q. Is that K 34? 19 A. Yes. That's equivalent to K 34. That's the 20 same thing. 21 Q. That's just a blowup of it. Could you read 22 what the label for PCBs says for this Exhibit K 34? 23 A. Yes. It says, "This package contains Aroclor 24 (a chlorinated diphenyl, technical)." Now, that diphenyl 25 is an old term for biphenyl. But it's still PCB. WATER PCB-SD0000033062 112 1 Q. Okay. 2 A. "Avoid repeated contact withskin and 3 inhalation of the fumes and dusts." 4 Q. Okay. And then is K 36, Exhibit K 36, on the 5 blowup? 6 A. Yes, sir. 7 Q. And that's the upper portion of the blowup? 8 A. Yes. It's the label, but it's also on the 9 right hand side, too. 10 Q. Okay. So the same information is in yellow 11 on the blowup, and it's also in white on this side? 12 A. That is correct. 13 Q. Okay. Would you read that label, K 36? 14 A. "Caution! Containschlorinatedhydrocarbons. 15 Avoid prolonged breathing of vapors or mists. Avoid 16 contact with eyes or prolonged contact with skin. If skin 17 contact occurs, remove by washing with soap and water. 18 Following eye contact, flush with water. If clothing 19 becomes soaked with fluid, launder before wearing again." 20 Q. When did Monsanto first start using labels on 21 PCBs ? 22 A. I can't answer that. They had them when I 23 came. 24 Q. So they were using them in 1936 when you 25 came WATER PCB-SD0000033063 113 1 A. Yes. 2 Q. And I don't know if we read Exhibit K 35. Is 3 that another label? 4 A. Yes. That's a label. It says, "Chlorinated 5 Diphenyl Technical. Caution! Avoid prolonged or repeated 6 contact with skin. Avoid prolonged breathing of vapor and 7 fumes." I'm not so sure what the "Diphenyl Technical" 8 meant, but it was certainly chlorinated It was a PCB, 9 but I don't think there was a very big usage of 10 chlorinated diphenyl technical, whatever that was. 11 Q. Were labels like Exhibits K 34, K 35 and K 36 12 used at Monsanto from 1936 until you retired in 1974 for 13 PCBs ? 14 A. Yes, they were. 15 Q. And let's go on to Let me ask you this. 16 What types of Where were these labels put on PCB 17 products? 18 A. Well, it all depends what the size of the 19 package was. It all depends on what the PCB was. If you 20 had a liquid PCB, it was shipped in a drum, and you put it 21 on the outside of a drum. If it were shipped in a tank 22 car, you'd put it in some sort of a picture frame on the 23 tank car. If it were a solid PCB, which some of them 24 were, I don't know if they were shipped in fiber drums or 25 in sacks, but they were put on the outside of the WATER PCB-SD0000033064 114 1 container. 2 Q. Okay. 3 A. I should say for the jury a drum contains 55 4 gallons. It's a good sized container. 5 Q. Okay. And the labels would be put on the 6 drums ? 7 A. That's correct. 8 Q. Let me just ask you to look at Exhibits K 36A 9 and K 36B and ask you to identify those documents 10 A. These are two 11 Q. if you can. 12 A. I'll start with K 36A. It's a letter from 13 Robert Sido, who was sort of the He was located in St. 14 Louis. He was the administrator for the labeling of 15 Monsanto products. And he sent this to somebody I don't 16 know, a Dr. Seppala, talking about the use of Aroclor. I 17 mean the use of labeling for Aroclors. 18 Q. It's dated June 19, 1963? 19 A. Yes. And also this thing clears up my lack 20 of knowledge about chlorinated diphenyl technical. In 21 other words, he says here in paragraph three that where 22 they didn't want to put an Aroclor on it, they put on 23 chlorinated diphenyl technical. So it's still referring 24 to PCBs. 25 Q. Now, Mr. Sido, and that's Sido, what was WATER PCB-SD0000033065 115 1 his job at Monsanto? 2 A. He was head of the administrative label 3 group. In other words, he was the fellow that was 4 responsible to get the information from the marketing 5 people, the medical people, the legal people, and the 6 advertising people together and draw up the format or the 7 art work for the label and get it approved by everybody 8 and then put on the product, send it out to the plants to 9 put it on the material that was packaged. 10 Q. So he was the label man at Monsanto? 11 A. That's right. 12 Q. And can you identify Exhibit 36B? 13 A. Yes. That's a letter to the two plants from 14 Sido in 1964, to the two plants that manufactured PCBs, 15 WGK plant. That was the East St. Louis plant. And 16 Anniston was the other plant. 17 Q. I don't know if you gave the date. 18 A. April 1964. 19 Q. And did this memo concern the subject of 20 precautionary labels being put on all drums of 21 PCB containing products, such as Aroclors, Pydrauls, 22 Inerteens and Pyranols? 23 A. Yes. That's correct. 24 Q. And was the policy followed of putting PCB 25 labels on all PCB drums that were shipped out? WATER PCB-SD0000033066 1 A. Oh, yes. 116 2 Q. What was the purpose of placing these labels 3 on the PCB containers that were sent out to Monsanto's 4 customers ? 5 A. Well, I think there were two reasons. One, 6 to tell them what was in the drum. You had to tell them 7 what was inside it. That's one very good reason. And how 8 much was in there. And, secondly, what to do to avoid any 9 problem with it. There were safe handling procedures 10 listed on the label so the worker who finally got the 11 drum, the customer's worker, would be warned as to what to 12 do or not do. 13 Q. Let's take a look at Exhibit 37. 14 A. Yes, sir. 15 Q. Through I'm going to take a big group of 16 documents, 37 through 64. 17 A. Yes, sir. 18 Q. Can you identify what this group of documents 19 contain? 20 A. Yes. This is a group of documents that are 21 labels for various PCBs. They have them listed sometime 22 with a G.E. copyright name, sometime with a Westinghouse 23 copyright name. 24 Q. G.E. did you say? 25 A. General Electric. WATER PCB-SD0000033067 117 1 Q. Okay. 2 A. General Electric andWestinghouse. Sometime 3 they have on Pydraul, the hydraulic fluids, which is a 4 PCB. Sometimes they have a capacitor fluid, which is also 5 a PCB. Then they have heat transfer compounds, which is a 6 PCB, the Therminols. And some just plain Aroclors, which 7 don't have any particular other designation but is still a 8 PCB. 9 Q. So Exhibits K 37 through 64, just to 10 short circuit things, are representative samples of 11 caution labels with safe handling instructions that were 12 put on PCB containing products? 13 A. Yes, sir. 14 Q. Did you or someone in your Medical Department 15 write or approve the cautionary and safe handling language 16 on these labels? 17 A. Yes, sir. 18 Q. Let's just take a look at a couple some of 19 these here. K 37, can you identify K 37? 20 A. That's transformer Pyranol, and there's an 21 asterisk saying this is a trademark of General Electric 22 and also states that Monsanto made this compound for 23 General Electric. So according to Well, I know it was 24 according to their specifications, but it doesn't say that 25 on there. But it was made for General Electric. It was WATER PCB-SD0000033068 118 1 their trademark name. We had to give them that 2 designation. And it contains the safe handling procedures 3 or the cautions, things that should be watched for or 4 should be carried out. 5 Q. And, again, Exhibit K 37 has safe handling 6 procedures for Pyranol, which is a PCB? 7 A. That's correct. 8 Q. And what precautions did Monsanto put on this 9 label to tell people for safe handling? 10 A. Avoid prolonged breathing of vapors or mists, 11 avoid contact with eyes or prolonged contact with skin. 12 If skin contact occurs, remove by washing with soap and 13 water. Following eye contact, flush with water. If 14 clothing becomes soaked with fluid, launder before wearing 15 again. 16 Q. Take a look at Exhibits K 38, 39, 40, 41 and 17 42. Are these Monsanto's cautionary labels for Pydraul, a 18 PCB? 19 A. Yes, they are. They're representative. 20 There's several different Pydrauls. These talk about two 21 of them. There's Pydraul 135 and Pydraul 312. These are 22 both PCBs. There are some other Pydrauls that are also 23 PCBs. But they're representative of Monsanto labels for 24 their Pydrauls which contain PCB. 25 Q. And rather than read the safe handling WATER PCB-SD0000033069 119 1 information, is it fair to say that the safe handling 2 information for the Pydrauls is similar to the one you 3 just read? 4 A. Yes, it is. 5 Q. Doctor, next look at the Exhibits 43, 44, 45 6 and 4 6. 7 A. Yes, sir, I have. 8 Q. Are these the Monsanto cautionary labels for 9 the Westinghouse Inerteen PCB fluid? 10 A. Yes, it is. For three different Inerteens. 11 Q. Okay. And, again, do the safe handling 12 instructions on these labels are they the same or very 13 similar to the one you just read? 14 A. Well, they are in one sense, as far as to 15 avoid any injury to the people, but on 100 42, an 16 Inerteen 17 Q. Well, read the Refer to the exhibits. 18 Otherwise we won't 19 A. Exhibit K 43 and Exhibit K 46, there's a 20 statement about how to protect the environment from this 21 product. 22 Q. And I think K 44 has the same information on 23 the environment? 24 A. Oh, yes. Yes. 25 Q. And take a look, for example, at K 45. WATER PCB-SD0000033070 1 A. Yes, sir. 120 2 Q. Is that in color? 3 A. Yes. It's red andwhite. 4 Q. Let me Maybe you can hand it to me and I 5 can just I've got a Xerox. It doesn't come out in 6 color. But this is What's showing now is Exhibit K 45? 7 A. Yes. 8 Q. And that's the label for Inerteen, which was 9 a Westinghouse PCB? 10 A. Yes. It was a product made for 11 Westinghouse,, and the name is a Westinghouse copyright, 12 yes. It's PCB transformer fluid. 13 Q. Okay. And were some of these labels in other 14 colors other than the orange or red that I just showed? 15 A. Yes. They are here all in black and white, 16 but I'm sure I've seen some in yellow and blue. I think I 17 have a couple of blues in here. They were in different 18 colors. 19 Q. Okay. Can you identify Exhibit 47A? 20 A. 47A? Wait a minute. I'm up in the 60's 21 here. 22 Q. Yeah. You put that last group away, and I 23 haven't finished with it yet. That's too far. You've got 24 them in your hand now. 25 A. I've got these pretty messed up. WATER PCB-SD0000033071 121 1 Q. Put those Material Safety Data Sheets down. 2 I'm finished with those. 3 A. That' s 63. 64. Wait a minute. 4 Q. You've got It's underneath the material 5 your lap. 6 A. What are you looking for now? 7 Q. It' s in your lap, Doctor. 8 A. What number are we looking for? 9 Q. We' re looking for 47A. 10 A. Oh, I haven't even started 11 Q. No. No. 12 A. Okay. Here I am. 13 Q. Okay. Can you identify Exhibit 47A? 14 A. Yes. This is a stick on label or an addendum 15 label or an additional label which refers to the 16 environmental contamination that should be avoided with 17 PCBs. Before we After we realized that there was a 18 possibility of environmental contamination, before we 19 could get the new labels, we had these stick ons put on 20 all the labels that we had I mean, all the drums that 21 we had in our warehouse, and we shipped this out to our 22 distributors so they put it on the labels, on PCBs that 23 had already been marked. 24 Q. Take a look Do you have the I think 25 they are on your table there Exhibits 43 and 44? WATER PCB-SD0000033072 122 1 A. I'll give you those back. That's 63. 2 Q. No. 3 A. I've got 43. 4 Q. Oh, you've got that? 5 A. I've got 43, yes. 6 Q. Okay. Take a look 7 A. Am I through with these safety data sheets? 8 Q. Hand them to me because I think you've got 9 some labels mixed in there with them. Yes. I think I'm 10 finished. 11 A. They go over here unless 12 Q. Well, we'll just keep them here for now. 13 We'll get them over there eventually. You've got 43 and 14 44 now in front of you? 15 A. Yes, I do. 16 Q. Okay. In addition to the safe handling 17 procedures about avoiding prolonged breathing of vapors, 18 et cetera, there's some environmental warnings on those 19 two exhibits. Could you describe those? 20 A. Yes. There's a slight bit of difference 21 between 44 and 43 and 44. This paragraph is the same 22 on both of them. No. I better read them separately 23 because their wording is a little different. K 43 is 24 talking about Inerteen 100 42, the Westinghouse product, 25 their trademark product, which we made for them. Contains WATER PCB-SD0000033073 123 1 a statement, "This product contains polychlorinated 2 biphenyls," that's PCBs, "which some studies have shown 3 may be an environmental contaminant. Extreme care should 4 be taken to prevent any entry into the environment through 5 spills, leakage, use, disposal, vaporization or 6 otherwise." That's 43. 7 Q. Now, 44 has some language that's similar, and 8 then it has some additional information about waste 9 disposal. Could you read that? 10 A. Yes. It's a little more specific. It says 11 on Inerteen 100 42, again the Westinghouse product, "This 12 product contains PCBs, which some studies have shown may 13 be persistent, an environmental contaminant and, possibly 14 injurious, to certain forms of bird, aquatic," that means 15 fish, "and animal life." Then they go through "extreme 16 care," et cetera. Then they add on it, "Waste disposal. 17 Used PCB fluids may be returned freight prepaid for proper 18 incineration at three cents a pound." We had an 19 incinerator in our East St. Louis plant where we burned 20 this stuff when it came back. 21 Q. Now, if you'd look at Exhibit 50, please. 22 A. Am I through with 47? 23 Q. Yes. 24 A. Okay. Yes, sir. 25 Q. Can you identifyExhibit 50? WATER PCB-SD0000033074 124 1 A. Yes. That's a Monsanto label for Capacitor 2 Fluid 21, which is a fluid obviously for capacitors made 3 by Monsanto containing PCBs. 4 Q. And are there safe handling instructions on 5 this exhibit, on this label? 6 A. Well, it's referred to another label, another 7 label I presume it is, which is shown on the container. 8 In other words, this must be two of these This is an 9 addendum to a label, because it says They said what's 10 in it, and they talk about waste disposal, but they say 11 "Read and follow all important safeguard instructions 12 shown on this container." So this must go along with 13 another label. 14 Q. Take a look at Exhibit 64. Keep those all on 15 your lap, but if you could find Exhibit 64, which is the 16 last group No, it's not there. It's the last exhibit 17 in this group. 18 A. Oh, yes. I've got it. 19 Q. Okay. Are you able to identify Exhibit 64 as 20 the safe handling information that goes with Exhibit 50? 21 A. Yes. This is safe handling information in 22 seven different languages. It says what's in it, says 23 it's got PCBs. They say to keep it out of the 24 environment. They say it's a harmful product if taken 25 internally or prolonged contact with the skin, avoid WATER PCB-SD0000033075 125 1 spills, avoid breathing vapors, mists or fumes. Wash 2 product from skin. Yes. It's got a full battery of 3 precautions. 4 MR. CARNEY: I guess, Mr. Murray, for your 5 information, what we have is virtually illegible. In 6 fact, I think it's safe to say it is illegible. We did 7 get a legible copy that we've marked Exhibit 64 since you 8 didn't have that yesterday. 9 MR. MURRAY: Are these going to be the 10 originals or these I can keep? 11 MR. CARNEY: No. That's the only one we 12 have. We can get you We'll make you a better copy or 13 get you another one. 14 MR. MURRAY: Did we get a date on when this 15 was ? 16 MR. CARNEY: Yeah. 17 Q. Take a look, first of all, at Exhibit 50. 18 Can you date that document? 19 A. Well, except that it's written on it by 20 somebody, "Printed 1/4/73," and then they talk about 21 ordering 2,000 of them in November of '73, and then it's 22 got a notation that they changed the tare, that's the 23 weight of the empty barrel, from 68 pounds to 65 pounds. 24 So presumably it was originally dated 1973. Printed, 25 rather, in '73. WATER PCB-SD0000033076 126 1 Q. And I believe the safe handling information 2 on Exhibit 64 is in English and six other languages. Is 3 that correct? 4 A. Four other languages. 5 Q. No. I'm talking about 64. 6 A. Oh, yes. Seven languages altogether. 7 Q. Including English? 8 A. Yes. 9 Q. Take a look at Exhibits 51, 52 and 53. 10 A. Yes, sir. 11 Q. Can you identify those three exhibits? 12 A. These are exhibits These exhibits are 13 labels for Monsanto Therminol, a PCB heat transfer medium, 14 of three different types, FR 1, 2 and 3. And, as I said 15 earlier, those are either various concentrations of PCBs 16 or various PCBs chlorinated to different levels or 17 mixtures, but they are all PCBs. 18 Q. And are there safe handling instructions on 19 each of these exhibits? 20 A. Yes, there are. 21 Q. And are these safe Rather than have you 22 read it, are these safe handling instructions similar to 23 the ones you've already read? 24 A. Yes. They were the same as before. 25 Q. Okay. Take a look at Exhibits 54, 55 and WATER PCB-SD0000033077 1 5 5 A. 127 2 A. Yes, sir. 3 Q. Can you identify those exhibits? 4 A. Those are Monsanto labels, all for the same 5 Aroclor 1016, which was a PCB, a dielectric fluid that was 6 manufactured by Monsanto in the mid '70's. 7 Q. And does Exhibit 54 contain the safe handling 8 instructions for handling PCBs? 9 A. Yes, it does. The same as In general, the 10 same as before. 11 Q. Okay. And Exhibits 55 and 56 I'm sorry 12 55 and 55A, do they refer to the safe handling information 13 that's in seven languages that's Exhibit 64? 14 A. Yes. It's the same color as that also. 15 Q. Okay. Take a look at Exhibit Exhibits 56 16 through 62. I'm not sure if I misspoke. I meant to say 17 56, if I said 66. But 56 through 62. 18 A. These are labels of Monsanto PCBs. They're 19 labeled Aroclor, although they have the subtitle of 20 chlorinated polyphenyls. It's a different phraseology but 21 it's still our same old PCBs. They're Aroclors 1232, 42, 22 54 and 68, all of which are PCBs that have different 23 chlorine contents. 24 Q. Dr. Kelly, I'd like you to And these all 25 basically have the same kind of cautionary language that WATER PCB-SD0000033078 128 1 we've read before? 2 A. Yes. Basically. Some have an extra 3 stick on, some don't. 4 Q. About the environmental problem? 5 A. Yes. 6 Q. Take a look atExhibit 57. 7 A. Yes, sir. 8 Q. And I've got a blow up of 57. Is this 9 blow up the same as Exhibit 57 that you're looking at? 10 A. Yes, it is. 11 Q. Okay.And could youjust read the safe 12 handling instructions? 13 A. Yes. It's the same pretty much on all of 14 them. Avoid prolonged breathing of vapors or mists. 15 Avoid contact with eyes or prolonged contact with skin. 16 If skin contact occurs, remove by washing with soap and 17 water. Following eye contact, flush with water. If 18 clothing becomes soaked with fluid, launder before wearing 19 again. 20 Q. Okay. Let's go now to Exhibit 63. 21 A. Yes, sir. 22 Q. Can you identify that exhibit? 23 A. Yes. This is a Monsanto label for PCBs. 24 Q. And do you know what this label was put on, 25 what type of container? WATER PCB-SD0000033079 129 1 A. Drums I'm sure, because they talked someplace 2 about the waste disposal and they say you could return the 3 material. So I think it's drums. Conceivably it might be 4 tank cars, but I think it's drums. 5 Q. But it could be tank cars as well? 6 A. Could be tank cars, yes, sir. 7 Q. And this also has the environmentalwarning 8 as well? 9 A. Yes, it does. 10 Q. So would that place this labelsometime after 11 what date? 12 A. '73. 13 Q. Okay. 14 A. Because the environmental warnings were 15 somewhat before '73, but shipping the material back to 16 Monsanto for incineration occurred I believe around '73. 17 Q. Dr. Kelly, during the time that you were 18 Monsanto's Medical Director, did you have a philosophy or 19 a goal that you followed in writing safe handling 20 instructions? 21 A. Yes, I did. 22 Q. What was that? 23 A. Well, there were two main thrusts. One, tell 24 them what they need to protect themselves. Two, be 25 precise in it and short in it. In other words, don't use WATER PCB-SD0000033080 130 1 a page if you can use a paragraph or a paragraph if you 2 can use a couple of sentences. 3 Q. Why? Why did you believe that? 4 A. Well, it's been my experience, my own as well 5 as talking to workers, that they don't read voluminous 6 warning things. 7 Q. Voluminous They don't read what? 8 A. Warnings that are very big, a large volume, 9 extensive warnings. They don't read it. If it's a 10 booklet, they aren't going to go through the booklet. If 11 it's four pages, they aren't going to sit down and thumb 12 through four pages while they're getting the material out 13 of a drum. But if it says on the drum, "This is what you 14 do. Don't get it on your skin, don't breathe it," they 15 are going to listen to it. They are going to read that 16 and pay attention to it. Sol think if you put all the 17 information to protect an individual on a label and make 18 the label make this instruction as short as you can, 19 that's the best protective label. 20 Q. Okay. Dr. Kelly, at the time you retired 21 from Monsanto in December of 1974, did you have an opinion 22 to a reasonable degree of medical certainty whether if the 23 safe handling instructions that you drafted were followed 24 in relation to PCBs, as we've discussed in these Exhibits 25 34 through 64, the products, the PCB products, could be WATER PCB-SD0000033081 131 1 used without ill effects? 2 A. Yes, I did. 3 Q. What was that opinion? 4 A. That they could be used without ill effects. 5 Q. And what is the basis for that opinion? 6 A. Well, the basis is the absence of any illness 7 reported, any case reports in the medical literature about 8 illnesses resulting from contact with PCB in the 9 industrial setting. Number two, the absence of any 10 reports from the government about such occurrences. 11 Number three, the information I received talking to my 12 fellow medical directors in the various companies that 13 used PCBs. And, of course, number four was our own 14 experience. But the labels didn't influence that very 15 much. We didn't label them until they had left the 16 warehouse, the shipping room of the plant. But the other 17 three reasons were The other three statements were the 18 reasons that I was sure that it was working, because we 19 didn't have any trouble in our customers. 20 Q. And did that opinion of yours ever change 21 during the entire time you were employed by Monsanto? 22 A. No. It didn't change. I think it was 23 strengthened after I retired when I read articles like 24 Kimbrough saying there've been no ill effects in any of 25 the industrial workers. WATER PCB-SD0000033082 132 1 Q. Let's take a look now at Exhibit 65. 2 A. Yes, sir. 3 Q. Can you identify Exhibit 65, K 65? 4 A. Well, this is a series of typewritten pages 5 signed by nobody. There's no author on it. It's dated 6 10/1/44. It's labeled "Monsanto Chemical Company Salesman 7 Manual Salesmen's Manual, Aroclor, Description and 8 Properties." 9 Q. Dr. Kelly, did you ever see this document 10 while you were employed by Monsanto? 11 A. I did not. 12 Q. Was this document ever utilized by Monsanto? 13 MR. MURRAY: I object to the form of the 14 question. How could he possibly know if it was utilized 15 if he's never seen it? 16 Q. Let me ask you this. To your knowledge was 17 this document ever utilized by Monsanto? 18 A. While I was with Monsanto I never heard 19 anybody even mention this document, much less use it. I 20 never talked to anybody who used it. 21 Q. Was this document ever reviewed by you to 22 approve the health information in it? 23 A. No, it was not. 24 Q. And are you certain of that? 25 A. Huh? WATER PCB-SD0000033083 133 1 Q. Are you certain of that? 2 A. Positive. Absolutely. A hundred percent. 3 Q. What makes you certain that you never 4 reviewed this document while at Monsanto? 5 A. Well, because I would remember it. This is a 6 manual that I would have thrown away had I seen it. I 7 think it's full of half truths. It's full of garbled 8 information. And I know it. I know I never saw it. 9 Q. Was this document ever officially published 10 by Monsanto? 11 A. It never was. It bears no 12 MR. MURRAY: I object to the question. 13 There's no foundation laid that he would know whether or 14 not this stuff was published by Monsanto. It was 15 apparently published by somebody, and he's said he's never 16 seen it, so he couldn't possibly know who published it. 17 Q. You can answer the question. Was this 18 document ever published by Monsanto? 19 A. You'll have to define what you mean by 20 "publish". It was typewritten by somebody obviously, but 21 it was not published for dissemination to Monsanto 22 employees or to Monsanto customers. If it went outside of 23 Monsanto, there would be on the back of it there would 24 be a bunch of coding like we've seen on our technical 25 bulletins, on our application bulletins. This does not WATER PCB-SD0000033084 134 1 bear any of those things. Somebody at Monsanto during the 2 war sat down when he wasn't doing anything and typing it 3 because we didn't have salesmen's manuals. We didn't need 4 them during the war because Aroclors, PCBs, were on 5 allocation. All you needed to have was someone at a 6 telephone that would call up and say, "I've got a 7 government allocation here for 40,000 pounds of 1242," and 8 they'd say, "Okay. We'll ship it to you." So this was 9 never used by Monsanto. 10 Q. Dr. Kelly, if this document, Exhibit K 65, 11 had been presented to you for your approval back in the 12 '40's, would you have approved it for use by salesmen at 13 Monsanto? 14 A. I would have pitched it in the wastebasket. 15 Q. And why is that? 16 A. Because, as I said, it is a garbled group 17 of garbled group of facts that do not relate to PCBs by 18 themselves. It does not relate to the actual use of PCBs 19 in the industry. 20 Q. Dr. Kelly, during the time you were employed 21 by Monsanto, did Monsanto ever perform tests in relation 22 to the toxicity of PCBs? 23 A. Oh, lots of them over a large number of 24 years. 25 Q. Did Monsanto perform these tests in house? WATER PCB-SD0000033085 135 1 A. No, they did not. We did not have a 2 laboratory of our own. As I said earlier, we started 3 plans for a laboratory a couple of years before I left, 4 and they do now have their in house laboratory. But until 5 1974 when I left they did not. 6 Q. Who performed these tests? 7 A. It varied. It depends on the type of test. 8 If it were a short term test, just acute testing, we would 9 have it performed at two small laboratories in St. Louis. 10 Q. Were they all independent laboratories? 11 A. Oh, they were all independent. Some were 12 university laboratories, but still independent. Some were 13 commercial laboratories that were independent. 14 Q. Dr. Kelly, why And these were all animal 15 tests ? 16 A. Yes. With the one exception. We did some 17 patch tests on humans. 18 Q. Dr. Kelly, why are these tests performed on 19 animals ? 20 A. Well, one reason is that you do not like to 21 perform tests that may be possibly harmful on people. I 22 mean, that's the only reason. 23 Q. Are the results of animal tests easily usable 24 to predict the potential effects of a particular substance 25 in humans? WATER PCB-SD0000033086 136 1 A. Well, not easily, but, as I said, they are 2 the only thing we have. They're the best thing we have, 3 and in some sense it might show the target organ. In 4 other words, if you've got a product that when you give it 5 to an animal it hurts his kidneys, you would then if a 6 man were exposed to that product, you would say, "Well, 7 I'll look pretty close at the kidneys." But it might very 8 well be that a product that hurts animals' kidneys doesn't 9 hurt human kidneys and doesn't hurt human at all. But, as 10 I say, that's the only thing we've got. But if a product 11 is If Product X is twice as toxic to an animal as 12 Product Y, well, you'd probably figure that Product X 13 would be twice as toxic to a human as Product Y. It may 14 not, but that's the only thing you have to go by. 15 Q. Take a look at Exhibit 66. Can you identify 16 K 6 6? 17 A. Yes. This is an article by at any rate, a 18 memorandum by Dr. Frederick Flinn, F 1 i n n, in May of 19 1954. These were patch tests, patch. 20 Q. You said '54. 21 A. 34 . 22 Q. Mine says '34. 23 A. Sorry. '34. 24 Q. Okay. 25 A. These copies aren't the best in the world. I WATER PCB-SD0000033087 137 1 think I better explain to the jury what a patch test is. 2 Q. Okay. Why don't you do that now? 3 A. A patch test is not a test for toxicity. 4 It's a test to see whether a particular product can cause 5 irritation or skin sensitivity. Irritation of skin is 6 like what happens when you put turpentine on. 7 Sensitization is something like when you put poison ivy 8 on. Two different skin reactions. Patch tests are used 9 greatly in the cosmetic industry. If you're going to put 10 a face powder on or a lipstick, you want to test it by 11 patch test to see if it's going to cause a breaking out. 12 Well, Dr. Flinn in those early days had these cases of 13 had heard about these cases of chloracne at our Anniston 14 plant. 15 Q. This was the Swann plant before it became a 16 Monsanto plant? 17 A. Yes, the Swann plant. So presumably the 18 Swann people This was not done for Monsanto; it was 19 done for Swann sent it up there, and he did patch tests 20 with various PCBs and with some of the ingredients some 21 of the halowaxes and some of the ingredients that he 22 thought were contaminants of the bad PCBs that had given 23 Halowax given Swann their problem. 24 Q. And what did he conclude? 25 A. Well, he concluded in paragraph two on page WATER PCB-SD0000033088 138 1 four, "One cannot but feel that any styrene," 2 styrene, "compound which may be found to be present 3 as an impurity is the cause of your trouble." 4 Q. So did he agree with you then that it was the 5 bad benzene that caused the chloracne outbreak? 6 A. Well, he didn't know me then. I mean, he 7 agreed with 8 Q. I mean, did he Did his opinion that is set 9 forth in this article agree with your opinion? 10 A. Yes. And Jones' opinion, the man who wrote 11 the article. 12 Q. Okay. You saw Was this Exhibit 66, this 13 1934 article by Dr. Flinn, in the Monsanto files when you 14 came to work for Monsanto? 15 A. Yes, it was. 16 Q. And you saw the document at the time when you 17 started work for Monsanto? 18 A. Not when I started work. Sometime in the 19 next 12 months. 20 Q. Okay. Did Dr. Flinn suggest any safe 21 handling precautions for PCBs back in 1934? 22 A. Well, he suggested Yes, he did. He 23 suggested you study the ventilation system where there 24 were fumes and have people able to take a bath with soap 25 and water if they came in contact with the material, and WATER PCB-SD0000033089 139 1 he stated, "I found where I had gotten the material on my 2 hands if I washed them thoroughly no trouble occurred." 3 Q. By "material," what do you mean? 4 A. Well, some of these PCBs. He did a bunch of 5 PCBs 6 Q. When you mention "material" 7 A. Well, the ones he tested. 8 Q. And that included PCBs? 9 A. Well, he tested about ten different Aroclors 10 and four halowaxes, and a few of the ones that he thought 11 were contaminants. 12 Q. So he said if you got the PCBs on your hands, 13 no trouble arose if you washed them off? 14 A. He didn't just mention PCBs. He mentioned 15 all of them. I mean he was talking 16 Q. I know. 17 A. about halowaxes, which is chlorinated 18 diphenyl. Any of these things that he was testing, he 19 said if you got them on, even though they were positive on 20 a patch test, if you washed them off you had no trouble. 21 Remember, a patch test you leave on. You put it on your 22 skin. I forgot to mention that. You put it on the skin 23 undiluted. You put it on neat, put a gauze over it so 24 it's soaked, put a piece of cellophane or pliofilm or 25 something like that over it, leave it on for 24 hours, WATER PCB-SD0000033090 140 1 take it off. Two days later, put it on again for 24 2 hours. 3 Q. What was used in these tests? Were there 4 human beings used in Flinn's 5 A. Yes. Animal skin does not react like humans. 6 Q. I thought I read where it's large rabbits. 7 A. Well, he used rabbits. I'm sorry. This 8 fellow used rabbits. 9 Q. Okay. That's what I 10 A. I mean, that even makes it Because 11 rabbits' skin is different than humans'. 12 Q. But Dr. Flinn in Exhibit K 66 used rabbits 13 for his patch test? 14 A. He used rabbits. I was mistaken there. 15 Because certainly anytime I've done a patch test, I've 16 done humans. We don't do skin patch tests. . . 17 Q. And I believe you misspoke. You talked about 18 halowax being a chlorinated diphenyl. 19 A. No, I didn't. Did I say that? I shouldn't 20 have because halowax is not. It's a chlorinated 21 naphthalene. 22 Q. Okay. 23 A. If I said that here, I'm certainly wrong. 24 Q. Okay. I may have been mistaken myself. 25 A. Well, I want to be sure on that because it WATER PCB-SD0000033091 141 1 certainly is not chlorinated diphenyl. 2 Q. Let's go on. Let's go on to Exhibit 67. Can 3 you identify Exhibit 67? 4 A. Yes. This is a report from Drinker to Dr. 5 Drinker to Monsanto. I don't see the date, but I think 6 this is 7 Q. It's on the first page right in the middle. 8 A. Oh, September '38, I'm sorry. 9 Q. September 15, 1938? 10 A. '38. September 15th. This is the basis for 11 that article by Brinker that he had published that I 12 talked about earlier this morning. He tested four 13 compounds we sent up there. Two of them where he could 14 disregard because they had nothing at all to do with PCBs. 15 That's number one and two, chlorcosane, 16 chlorcosane, and diphenyl phthalate, d i 17 Q. We don't need to cover the non PCB. 18 A. Well, I want it just for her. Two of them 19 were not. 20 Q. Okay. Again, we're trying to focus on PCBs, 21 Doctor. 22 A. Okay. Well, two were not. Two were not. 23 The two PCBs were chlorinated diphenyl 1268 and a mixture 24 of chlorinated diphenyl and chlorinated diphenylbenzene 25 5460. WATER PCB-SD0000033092 142 1 Q. Okay. And is Exhibit 67 a report of Dr. 2 Drinker's to Monsanto? 3 A. Yes, it is. 4 Q. Okay. 5 A. And, as I said, this report on the last two 6 compounds , the PCBs, were published by Drinker. 7 Q. Okay. And we've already identified that 8 article? 9 A. Yes, we have. We've gone over that I think 10 at length 11 Q. Okay. And this report then would include Dr. 12 Drinker's study of the honest to goodness PCBs as you 13 said? 14 A. Yes. 15 Q. And that's the PCBs that you sent to Dr. 16 Drinker? 17 A. That's correct. 18 Q. And did you review this report sometime on or 19 about 1938? 20 A. As soon as I got it. 21 Q. And what did Dr. Drinker in this report to 22 Monsanto conclude in relation to these rat tests that he 23 did on honest to goodness PCBs? 24 A. He said on page seven, "In conclusion" 25 Q. I think Let me just see here. Okay. I've WATER PCB-SD0000033093 143 1 got it now. 2 A. What? Is that the page? 3 Q. Yes. 4 A. "In conclusion, 1268," which is a PCB, the 5 honest to goodness PCB, "if handled with ordinary 6 precautions as to ventilation should be entirely harmless 7 to workmen. While it cannot be given an absolutely clean 8 bill of health" Obviously if you get too much of 9 anything, it will be bad, but he didn't say that. But 10 it's preferable to 4465 and 5460, two compounds which are 11 not PCBs. They were chlorinated bi terphenyls or 12 chlorinated diphenylbenzene. Entirely different 13 compounds. 14 Q. Okay. But his first sentence in the 15 conclusion is that the PCBs, and I'll quote, "if handled 16 with ordinary precautions as to ventilation should be 17 entirely harmless to workmen"? 18 A. That's what he said. 19 Q. Okay. Let's go on to Exhibit 68, 69 and 70. 20 Why don't we The tape is about to run out, so when we 21 come back we'll talk about Exhibit 68, 69 and 70. 22 (Brief recess.) 23 Q. Dr. Kelly, could you look at Exhibits K 68, 24 69 and 70, and, excuse me, identify those for the record? 25 A. Yes. These are reports from the Kettering WATER PCB-SD0000033094 144 1 Laboratory, the University of Cincinnati. The principal 2 investigator is Dr. Treon. It deals with the toxicity of 3 the vapors of Aroclor 1242 and 1254, which are PCBs, an 4 ingredient of various Pydrauls, Pyranol, Inerteen, and the 5 last one is a mist generated by the aspiration of Pyranol. 6 The mist The difference between a mist and a vapor is 7 vapor is something that comes off. Mist is something like 8 when you spray paint, that fluid comes out as a mist. 9 Q. And these are all reports dated in the summer 10 of 1955? 11 A. Yes, sir. June of '55. June and July of 12 ' 55 . 13 Q. Okay. And I believe you had mentioned 14 earlier in your testimony Dr. Treon's testing at the 15 Kettering Laboratory at the University of Cincinnati; 16 hadn't you? 17 A. Yes. He was the principal investigator of 18 this group. He had a group doing it, but he was the man 19 in charge. 20 Q. And who at Monsanto requested that this 21 testing be performed by Mr. Treon at the Kettering 22 Laboratory? 23 A. I did. 24 Q. And was the Kettering Laboratory at the 25 University of Cincinnati Medical School a large WATER PCB-SD0000033095 145 1 toxicological laboratory? 2 A. It was a big one. It was a four story 3 building with about 20 Ph.D.'s in it. 4 Q. What type of testing did Mr. Treon at the 5 Kettering Lab perform that is recounted in Exhibits 68, 69 6 and 70? 7 A. They were all vapor inhalations or mist 8 inhalations. They were His earliest one, he started 9 out with one level and he increased the level and then he 10 increased the time of duration of the experiment from 11 Q. Just generally. I'll get into the details. 12 The animals were breathing PCBs? 13 A. They were in a confined box, and they had a 14 mixed bag of animals. I mean, mixed bag, he had Guinea 15 pigs, rabbits, rats, mice, maybe cats. I don't know if 16 they had any dogs in this. 17 Q. Okay. And they were all subject to a 18 confined space where they would breathe PCBs for a period 19 of time? 20 A. That's right. Eight hours or 16 hours a day 21 for a prolonged period of time. 22 Q. And by prolonged period of time, what do you 23 mean? 24 A. Up to seven months. 25 Q. What were the As a result of these tests WATER PCB-SD0000033096 146 1 that Dr. Treon performed on these various animals, was 2 there an estimate made of the safe human exposure levels 3 to vapors of PCBs? 4 A. Well, he came out with Yes, there was. He 5 came out with two levels. He found the 1254, the PCBs 6 with more chlorine in, was somewhat the more toxic, so he 7 gave that a level At one time he gave it a level of two 8 milligrams per cubic meter of air. A cubic meter is 9 roughly a yard by a yard by a yard. Milligram, there's 60 10 milligrams An aspirin tablet is about 60 milligrams of 11 aspirin. Might be some starch in there. But that's to 12 give you a reference point between milligrams and cubic 13 meters. He came out first with one milligram for 1254 and 14 two milligrams for 1242, but I think eventually he either 15 changed it or he changed it after talking to the American 16 Governmental Society of Governmental Industrial 17 Hygienists, to the standard accepted by OSHA of .5 18 milligrams per cubic meter for 1254 and one milligram per 19 cubic meter for 1242. 20 Q. I don't know if I understood all of the 21 milligrams and meters because I can't fathom that, but did 22 he come up with 23 A. He said those were safe. These levels, which 24 are well known to industrial hygienists, industrial 25 physicians and manufacturing people, were safe for a WATER PCB-SD0000033097 147 1 fellow to work in there eight hours a day the rest of his 2 life. 3 Q. How did he heat the PCBs to get the vapors? 4 Or not how. Did he heat them or 5 A. Oh, yes. He had to heat them because, as I 6 said, you put 1242 and 1254 on the floor here 7 Q. Again, you're talking about 8 A. The PCBs. 9 Q. You're naming numbers. 10 A. I'm sorry. 11 Q. And that's not going to 12 A. If you put If one puts these two PCBs that 13 he tested in an open container at room temperature, you 14 will get a negligible amount of material coming off. 15 Q. Vapor? 16 A. Vapor coming off. Negligible. Small. Very 17 small. 18 Q. How high did he heat these PCBs? Do you have 19 an estimate? 20 A. I'll have to look. 21 Q. Did he do it past theboiling point? If you 22 know, if you remember. 23 A. Let me look, and I can be sure. 24 Q. Okay. 25 A. Yes, he had to use He had to get up with WATER PCB-SD0000033098 148 1 one of them to between 115 degrees and 125 degrees 2 centigrade. That's Boiling point centigrade is 3 Q. Do that I don't know what centigrade is. 4 Can you do it Fahrenheit or give me an estimate of how 5 high the temperature was Fahrenheit? 6 A. You don't look at the evening news then. 7 Q. I never have 8 A. They call it Celsius now. 9 Q. I've never been able to adapt to centigrade. 10 A. Well, water boils at 180 degrees Fahrenheit. 11 Water boils at 100 degrees centigrade. So roughly 12 Q. Just use Fahrenheit, please, because I 13 won't I can't understand it if you use centigrade. 14 A. He went up to about 200 to 250 degrees 15 Fahrenheit. 16 Q. Okay. I think Americans are still I think 17 having trouble getting what centigrade means. Maybe in 18 the next century. 19 A. Well, so do I. That's why I have to look 20 this over. 21 Q. Were your conclusions about the toxicity and 22 safe handling of PCBs changed by the results of the 23 Kettering tests that are Exhibits 68, 69 and 70? 24 A. No, they weren't. We accepted the fact that 25 this material had a certain degree of toxicity. We knew WATER PCB-SD0000033099 149 1 that if you got it up to an elevated temperature you could 2 get problems. But we knew that there were safe levels 3 that people could work with. So that's No, it didn't 4 change my point of view at all. 5 Q. Okay. And if Monsanto's safe handling 6 procedures were followed, would there be any problems 7 based on the Kettering results? 8 A. No, there would not. There hasn't been. 9 Q. Did Dr. Treon of the Kettering Lab that 10 prepared these lengthy reports that are Exhibits 68 11 through 70 publish any of its findings? 12 A. Yes. He published K 69 and K 68. I'm not so 13 sure whether he published K 70 or not. That was the mist. 14 Q. Take a look at K 71. Is that the publication 15 of Dr. Treon's findings that were in K 68 and K 69? 16 A. Yes, it was. He didn't do the mist. He 17 didn't publish the mist. 18 Q. Okay. And that would have been K 70? 19 A. That was K 70. Doing the mist was a rather 20 specialized type of experiment. We were 21 Q. I don't know that we need to go into those 22 details. 23 A. All right. Hedidn't publish that because it 24 wasn't as important. 25 Q. Okay. WATER PCB-SD0000033100 150 1 A. But there was nothing unusual in the results 2 I mean. 3 Q. Okay. But Exhibit K 71 is the publicized 4 version of Exhibits results 2 I mean. 3 Q. Okay. But Exhibit K 71 is the publicized 4 version of Exhibits K 68 and K 69? 5 A. That's correct. 6 Q. Did you read the Article K 71 at the time it 7 was published? 8 A. Oh, yes. 9 Q. And what publication was this K 71 in? 10 A. The "Industrial Hygiene Quarterly". 11 Q. I'm sorry? 12 A. Which is a reputable peer reviewed article 13 publication. Peer review means they send out the articles 14 to the acknowledged scientists in the same field the man 15 is working with, and they look it over to see if it's an 16 adequately scientifically prepared and presented paper, 17 and it's available to all industrial physicians, such as 18 Westinghouse or General Electric, which have very 19 sophisticated medical and industrial hygiene groups. It's 20 available to medical schools. It's available all over. 21 Government people read it all the time. 22 Q. Did the published article of Dr. Treon 23 contain the same recommendations concerning the 24 permissible exposure levels of PCBs that the two reports 25 to Monsanto contained? 151 WATER PCB-SD0000033101 151 1 A. I don't think he picked that. Yes. He 2 suggested that Yes, he did. He suggested that Aroclor 3 1242 they should have the same level, and I think 54 he 4 cut it down. He said a safe level is one tenth what he 5 found to be safe for animals. So it was the same level. 6 This is a publication that the government scientists use, 7 the American Conference of Government Industrial 8 Hygienists, that I picked. And I might as well tell you 9 what they are. 10 Q. Well, let me ask you I'11 get to that. 11 A. Fine. All right. 12 Q. But So, again, but the publication of K 71 13 published safe levels for the use of PCBs in the 14 workplace? 15 A. Published recommended safe levels. 16 Q. Okay. And how long Let's take the PCB 17 that's 1242. How many days were some of the animals 18 exposed to the PCB vapors in that test? 19 A. Well, he said seven hours a day, five days a 20 week for several weeks. That's what he reports in here. 21 But in our report, the report the larger report, he 22 said some of them got up to 83 days, and then I believe he 23 increased the dose in the next report. Let's see what 24 they've got on this one. He went up to 214 days. 25 Q. So what would that mean? WATER PCB-SD0000033102 152 1 A. Seven months, a little over seven months, 2 five days a week. That would be 40 weeks, five days a 3 week, 40 weeks, and seven days Seven hours a day, five 4 days a week for eight months. 5 Q. So some of the animals were exposed to PCB 6 fumes for how many hours a day? 7 A. Seven hours a day, five days a week, for 8 eight months. 9 Q. Okay. 10 A. And the other one, the 1254, he went for a 11 period of seven months, 150 days during that seven months. 12 That's not He kept them all for seven months with 1254, 13 but he only did it five days a week, so it was 153 days, 14 150 days. So back in those days, in '55, that was a quite 15 long experiment. 16 Q. Did Dr. Treon send or submit these safe 17 levels for PCB exposure to any group? 18 A. I don't know if he did,but I knowthey used 19 it. I mean, when I say "they," there is a group that 20 adopts safe levels for use in industry. 21 Q. Who is that group? 22 A. That group is called the American Conference 23 of Government Industrial Hygienists. 24 Q. And are these a group of industrial 25 hygienists? WATER PCB-SD0000033103 153 1 A. They are, who are employed solely by 2 government. 3 Q. Okay. These are not 4 A. They are federal government, state government 5 or city government. They do not allow academicians in it. 6 Treon is not in it. They do not allow industrial people 7 in it. Elmer Wheeler couldn't get in it because it's 8 strictly government. They want to be unbiased. 9 Q. Okay. And this group of government 10 industrial hygienists, what did they do with these Treon 11 levels that were recommended by Dr. Treon for 12 A. They took them and used them as a basis for 13 coming out with a standard for safe level for Aroclor, for 14 these two PCBs, one with 42 percent chlorine, one with 54 15 percent chlorine, and OSHA has adopted many of the 16 government industrial hygienists' recommendations, and 17 Q. You better explain what OSHA is. 18 A. Occupational Safety and Health Association I 19 think. 20 MR. MURRAY: Administration. 21 A. Administration. 22 Q. Okay. Is that a U.S. government group? 23 A. That's a U.S. government report. Previously, 24 one of these other depositions, I said that OSHA had not 25 accepted this, but I received I saw in one of the WATER PCB-SD0000033104 154 1 papers referring to Bloomington that they had accepted the 2 government hygienists' report for PCBs of five tenths for 3 PCBs chlorinated to 54 percent and one milligram per cubic 4 meter for PCBs chlorinated to 42 percent. 5 Q. Is there any significance to you that this 6 government group of industrial hygienists approved these 7 safe levels for PCBs? 8 A. Sure. They didn't have any axe to grind. I 9 mean, they were not influenced by any possible motive, 10 profit motive or anything else that an industry might be 11 alleged to have. They were involved primarily in 12 protection of the workers, not to 13 Q. In production of the workers? 14 A. Protection of the workers. Not to say that 15 the industrial physicians aren't, but there's always a 16 possibility that somebody would say, "Well, you people 17 want to get this get levels pretty high because you 18 don't have to use all this ventilation." Well, these 19 people said this is safe. 20 Q. Okay. Let's take a look now at Exhibits 72 21 through 82. 22 A. Yes, sir. I have them here. 23 Q. Can you identify Exhibits K 72 through K 82? 24 Just in a general way without 25 A. Yes. These are acute testing of various WATER PCB-SD0000033105 155 1 PCBs. They were carried out from 1957 roughly to 1963 by 2 a laboratory in St. Louis, an independent laboratory, the 3 Younger Laboratories, which is primarily It's a smaller 4 laboratory. And they did acute testing. In other words, 5 we would do would test by a battery of acute tests. 6 We'd feed it to rats to see if we could determine the 7 toxicity. We would put the skin irritants We would 8 deposit the material on 9 Q. These are all PCB tests? 10 A. All PCB tests. There were four prongs to 11 this examination. Drop it in their eyes to see what 12 effect it would have on their eyes, the undiluted stuff. 13 Feed it to rats to see what it would take to harm them. 14 Three, put it on the skin and cover it up and leave it for 15 24 hours and see if it was irritating. And, four, 16 sometimes we would do an inhalation of a saturated 17 atmosphere. We may not do all four of them on all, but 18 that So it was an acute test really to see what would 19 happen if you got a good size dose of it at one time. 20 Q. Who requested that these tests be performed? 21 A. The Medical Department, either I or our 22 toxicologist. 23 Q. At Monsanto? 24 A. At Monsanto. 25 Q. Could you tell uswhat particular PCB WATER PCB-SD0000033106 156 1 Aroclors were involved in these Younger Laboratory tests 2 that are Exhibits K 72 through 82? Or I don't know if I 3 need to I think these speak for themselves. Rather 4 than go through and list them, they were various PCB 5 Aroclors. Is that 6 A. They were various PCB Aroclors which were 7 chlorinated. Whenever you chlorinate a PCB, when you 8 chlorinate the diphenyl, that's the biphenyl, that's the 9 PC part I mean that's the PB part. 10 Q. I don't know if we need to get into that. 11 A. Anyway, there's a mixed bag of about ten 12 different ones chlorinated to various degrees of 13 chlorination. 14 Q. Okay. And you've used the word "acute," and 15 I'm not sure I've asked you to define what "acute" means. 16 A. Well, acute is something that happens all of 17 a sudden. 18 Q. Short term? 19 A. Short term, and it doesn't linger. You get 20 an acute sore throat. It hurts, comes on relatively 21 suddenly, and lasts for four or five days. That's acute. 22 Q. And just for an example, take a look at 23 What was the dose? What was the amount of PCBs in the 24 1254 PCB that was used in these tests? 25 A. A hundred percent. WATER PCB-SD0000033107 157 1 Q. And how many grams or 2 A. I mean, how many grams were given? 3 Q. Yes. In the 1254, for example. 4 A. I've got to find 1254 here. I've got 42. 5 Q. K 78, would you look at Exhibit 78? 6 A. I found it. Here we are. 0r 0- 7 Q. Is that or is that something 8 A. K 78 . 9 Q. Okay. 10 A. What we did on this, we fed from eight grams, 11 that's two teaspoonfuls roughly, of liquid material to a 12 rat. Two grams I mean, two teaspoonfuls. It all 13 depends how big the rat is. A kilogram 14 Q. Let me ask you this. 15 A. Two and a half kilograms to the pound. 16 Q. Would eight grams 17 A. It's a big dose. 18 Q. Is that the most you gave, or did 19 A. No. We gave up to almost 16 grams, twice as 20 much. 21 Q. To a rat? 22 A. To a rat. 23 Q. Okay. Now, how many teaspoonsful, for 24 example, because I can understand teaspoons, I don't 25 understand grams would that be to a if you gave the WATER PCB-SD0000033108 158 1 same amount to a 150 pound human? How would that 2 translate? 3 A. That would be about You're giving two 4 teaspoonfuls per kilogram to the rat. A person 150 pounds 5 is roughly 70 kilograms, a little more, a little less. 6 Q. 70? 7 A. So giving him 140 teaspoonfuls of material at 8 one dose. 9 Q. 70 kilograms is about 150 pounds? 10 A. Yes. Roughly. 154 pounds. 11 Q. I don't know kilograms. I know pounds. 12 A. Okay. 13 Q. So can you tell me how much of this PCB 14 material would have to be fed to a 150 pound human? How 15 many teaspoonfuls to equal about the same amount to these 16 rats? 17 A. Well, the smallest dose they gave would be 70 18 times two, 140 teaspoonfuls. The dose they came out with 19 the figure was roughly Three times 70 would be 210, 20 divided by It would be about Wait a minute while 21 I You have three teaspoonfuls per kilogram at what they 22 call the dose that killed half the rats. That would be 23 210 teaspoonfuls in a person. 24 Q. So, in effect, what they were doing was 25 feeding Over 200 teaspoons of PCBs to a human would be WATER PCB-SD0000033109 159 1 the equivalent of what they fed these rats? 2 A. Yes. If the human reacted the same way as a 3 rat. 4 Q. Okay. Let's What is acute toxicity 5 testing? That's what this was; wasn't it? 6 A. Yes. 7 Q. Okay. Describe that in layman's language. 8 A. Well, acute toxicity testing is how much of 9 a how much does it take to hurt you if you take it all 10 at once over one day or one dose. 11 Q. Do you come up then with what's called a 12 LD 50 factor? 13 A. Well, the LD means lethal dose for half the 14 animals. In other words, you start off with a particular 15 amount. Then you keep on increasing it until you get a 16 dose that kills half the animals because some of the 17 animals may survive one ten grams, others may survive 20 18 grams. So you come up with a standard test that gives you 19 a figure for killing half the animals. 20 Q. Is this a standard test that's just used for 21 PCBs ? 22 A. Oh, no. It's used all through toxicology 23 because it compares. You can use it for comparing the 24 toxicity of one compound against the other in animals. In 25 other words, if you've got an LD 50 for ten in a rat and 160 1 an LD 50 for two in a rat, you know that in a rat this one 2 with ten it takes five times as much to kill him. So it's 3 one fifth as toxic. 4 Q. Okay. Is the LD 50 factor, is that something 5 that's calculated for lots of different compounds? 6 A. Oh, sure. Whenever anybody does an LD 50 or 7 a toxicity, acute toxicity test, on a new compound or an 8 old compound, he runs the standard LD 50 test. 9 Q. Okay. Does the fact that a chemical or a 10 compound has an LD number mean that it's harmful to 11 humans? 12 A. Well, again, it depends Sure. If it's got 13 an LD number for humans I mean, for animals, it may or 14 may not. You take salt. Salt's probably got an LD 50 of 15 five. So if you take a If you take a great deal of 16 salt at the same time, you may get serious problems, but 17 if you 18 Q. So if you gave enough quantities of something 19 like everyday salt to an animal, you're going to kill half 20 of them with certain levels? 21 A. That's correct. But that doesn't mean that 22 you put a teaspoonful of salt on your food during a day 23 it's going to be harmful to you unless you've got high 24 blood pressure. 25 Q. Why did the Medical Department at Monsanto WATER PCB-SD0000033110 160 1 want to know what the LD 50 number was for the various 2 PCBs ? 3 A. Well, we were always checking our products 4 along the way. In other words, here we have an old 5 product that we've been working on. We had a lot of 6 information on it from 1937 from Drinker, '55 from Treon, 7 and we checked it off and on to see how it was going. In 8 other words, so we wouldn't get booby trapped and find out 9 that, whoops, all of a sudden we've got something that's 10 more toxic than we think. 11 Q. And did these tests that these toxicity 12 tests where you got LD numbers for PCBs that are contained 13 in Exhibits K 72 through K 82 change your view as to the 14 harmfulness of PCBs? 15 A. No. They were all in the same ballpark as a 16 relatively an industrial chemical of relatively modest 17 toxicity. 18 Q. And by "modest toxicity" 19 A. Moderate toxicity, not very toxic. 20 Q. Toxicity means? 21 A. Harmful. 22 Q. So they were modestly harmful? 23 A. Yes. I mean, all industrial chemicals 24 Motor oil is certainly toxic also, but you don't consider 25 that a poison. WATER PCB-SD0000033111 161 1 Q. Okay. Did the Medical Department review 2 Exhibits K 72 through K 82? 3 A. Oh, sure. 4 Q. And did you yourself review them at the time 5 they came in? 6 A. I may or may not. I mean, it all depends. 7 In '57 I'm sure I did. In '62 when we had a toxicologist, 8 he might have reviewed it, but I'm pretty sure it passed 9 my desk. 10 Q. Okay. Let's go to Exhibits 84 through 91. 11 Can you identify those 12 A. Yes. These are 13 Q. exhibits? 14 A. Beg your pardon? 15 Q. Let's go all the way. Why don't you go all 16 r up to 116. Maybe we can combine this . 17 A. I'11 be happy to. 18 Q. And go through it a little faster. 19 A. To 116? 20 Q. Yes. 21 A. Okay. 22 Q. Are these I think there are 31 reports 23 here. Are these 31 reports to Monsanto by two different 24 laboratories, Scientific Associates and Younger 25 Laboratories, dated between February 1951 through October WATER PCB-SD0000033112 162 1 1967 relating to PCB testing? 2 A. Yes, they are. There were two There's one 3 laboratory in St. Louis called Scientific Associates. 4 Younger worked for them. Younger broke up and started his 5 own laboratory. So some of these tests were done by 6 Scientific Associates and some by Younger Laboratories. 7 They are the same type of laboratory. They were good just 8 for They were used just for acute testing. They didn't 9 have the facilities for sophisticated inhalation studies 10 or two year long term testing. 11 Q. And did these tests include Pydraul and 12 Therminol, two PCB containing products? 13 A. Yes. By various different names. There were 14 some called Pydrauls, some called Therminol, some called 15 MCS for Monsanto Chemical. Some was OS. 16 Q. Okay. 17 A. So they are all the same. They are all acute 18 testing of PCBs used for heat transfer agents and 19 hydraulic fluids. 20 Q. Did you request that these tests be 21 performed? 22 A. Yes, I did. 23 Q. Why? 24 A. Well, some of them were either new compounds 25 or new mixtures of compounds, and some were old that we WATER PCB-SD0000033113 163 1 just retested as a routine business. 2 Q. Why did you do that? 3 A. To see if they had changed any, particularly 4 in the toxicity. You mean in the latter 5 Q. Why did you continue What I'm curious 6 about is why you continued to do all this testing. 7 A. Well, we wanted to be sure that we still were 8 dealing a product that had the same toxicity. In other 9 words, we tested it in 1950. We wanted to be sure that in 10 1965 maybe it's time to test it again to see if there's 11 been any change for the better or the worse in it. So 12 that's what we did. But a number of these were new 13 formulations or new mixtures. 14 Q. Did you review Did you or the Medical 15 Department review the tests that are Exhibits K 84 through 16 K 116? 17 A. Yes, we did. They were reviewed by the 18 Medical Department. 19 Q. And were they received by Monsanto on or 20 about the date they bear? 21 A. Oh, yes. We sent them to Younger. We 22 received them. Scientific Associates. We received them. 23 We paid for them. 24 Q. Was there anything contained in these 31 25 reports that caused you to change your opinion that WATER PCB-SD0000033114 164 1 PCB containing products could be used safely in industry 2 if basic safe handling precautions were followed? 3 A. No, there was not. 4 Q. Now, let's go on and look at Exhibits K 117, 5 118, 120 and 121. Can you identify 6 A. Yes. 7 Q. Or just quickly maybe I can Are these all 8 reports from Industrial Bio Test Laboratories relating to 9 testing of various Aroclor PCBs? 10 A. Yes. There were 11 Q. And 12 A. These aretests to Monsanto Chemical Company 13 by Industrial Bio Test Laboratory. 14 Q. And are they all dated 19 in 1963? 15 A. Yes, they're dated 1963. On the subacute 16 skin dermal toxicity, which means skin, subacute means 17 a little longer than acute. These were 20 days, so they 18 didn't call them acute. They weren't 100 days so you'd 19 call them chronic. So they called them subacute. 20 Q. Did you review 21 A. I'm sorry. 22 Q. Did you review these tests? 23 A. Yes, I did. 24 Q. At the time they were received by Monsanto? 25 A. Yes. WATER PCB-SD0000033115 165 1 Q. And did you request that these tests be 2 performed? 3 A. Yes, sir. 4 Q. Why did you choose Industrial Bio Test to 5 perform these tests? 6 A. Well, they at that time We had used them 7 before on other products, and at that time were the 8 pre eminent industrial toxicological laboratory. They're 9 run by a Dr. Calandra, who is a professor at Northwestern 10 University Medical School. 11 Q. Is that a good medical school? 12 A. Oh, it's a top ranked. It's in Chicago. An 13 excellent medical school. 14 Q. Okay. 15 A. Their clients include the government, 16 U.S.D.A., the Department of Agriculture. They included 17 companies that had their own laboratory. Like DuPont had 18 their own laboratory, but they still used Industrial 19 Bio Test. Dow had their own laboratory, but they still 20 used Industrial Bio Test. And we used them. 21 Q. What was their reputation as a laboratory? 22 A. Excellent. 23 Q. Maybe I'm getting confused as to what 24 questions I've asked, but did you review these reports 25 when they came in? WATER PCB-SD0000033116 166 A. Yes, I did. Q. Was there any information contained in these reports, K 117, 118, 120, 121, that caused you to doubt whether PCBs could be safely used in industry if the safe handling precautions were followed? A. No. There were no surprises in there to me. There was no reason for me to doubt my previous to change my previous opinion. 9 Q. Let's go to Exhibits 122 through 127. 10 A. Yes, sir. 11 Q. Okay. These are two year tests 12 A. Yes. 13 Q. that were performed by Industrial 14 Bio Test? 15 A. They are two year feeding tests performed 16 Industrial Bio Test. Their report is dated 19 November 17 1971. That means the preliminary work was probably 18 started sometime in 1968 because 19 Q. All these reports, Exhibits 122 through 127, 20 are Industrial Bio Test reports? 21 A. Yes. And they deal 22 Q. They are all dated November of 1971? 23 A. Yes. That's when the report was done. They 24 deal with the chronic feeding of level of various 25 levels of three different PCBs to rats for two years and WATER PCB-SD0000033117 167 1 to dogs for two years. 2 Q. Okay. Did you request that these studies be 3 performed? 4 A. Yes, I did. 5 Q. Why did you request that I.B.T. perform these 6 two years tests on rats and dogs, PCB tests on rats and 7 dogs? 8 A. Well, because at that time there was 9 information that the PCBs were getting into the food of 10 the American public from environmental contamination. 11 There was information that it was showing up in shrimp or 12 fish or wild ducks, game fish. So the question came up is 13 there any long term toxicity work on these small low 14 levels in animals, and there wasn't any. So we went ahead 15 and did the same sort of testing that the government We 16 talked to the government before we did it. I went up to 17 the Food and Drug Administration along with Calandra and 18 we talked to them and said, "Look, here's what we're going 19 to do. We're never going to think of this as a food 20 additive, intentional food additive, but it may be an 21 unintentional food additive. So we're going to test it 22 just as though we were planning to put an intentional food 23 additive in, like baking powder into bread or something 24 like that." So we tested it in that manner. When we 25 finished up with what looked like a pretty clean bill of WATER PCB-SD0000033118 168 1 health, we sent I think we sent all these reports to 2 the Food and Drug Administration, EPA, if they were 3 several government organizations, United States Government 4 organizations. 5 Q. What did you conclude from these long term 6 two year feeding tests of PCBs to rats and dogs? 7 A. That there was a safe level of PCBs that 8 could be taken in the food for a period of almost a 9 lifetime of a rat. 10 Q. Let me switch to an incident in Japan 11 involving PCBs. It was called I don't think it's come 12 up yet, but the Yusho incident. Are you familiar with 13 that? 14 A. Yes, I am. 15 Q. Could you describe to the jury in a little 16 more detail what this Yusho incident in Japan was? 17 A. Yes. Yes. People in Japan were using a 18 Japan PCB as a heat transfer agent. The Japanese PCB was 19 manufactured by a somewhat different process than a 20 Monsanto PCB was. It contained some contaminants in a 21 different level than might have been present in the 22 Monsanto PCB. It was heated. They were making They 23 were heating up or making rice oil and so were heating 24 this material. So the stuff inside the pipes that were 25 heating the rice oil was hot, quite hot, 800 degrees WATER PCB-SD0000033119 169 1 Fahrenheit or something like that. So it leaked, got into 2 the rice oil at various amounts. They sold the rice oil, 3 not knowing that there had been leaks in it. It was then 4 shipped to the Japanese consumers, who used this rice oil 5 to heat their to fry soybean cakes or soybean pancakes 6 or whatever they were doing with soybeans. So they put 7 this stuff in their pan and put this rice oil contaminated 8 with Japanese PCB, and whatever else was in there, and 9 cooked it. 10 Q. So Japanese ate PCBs? 11 A. They ate it along with the Yes. They 12 thought it was rice oil, and there was PCBs in the rice 13 oil. Not all PCBs obviously, but there was quite a bit of 14 PCBs and other contaminants. Dibenzofurans, 15 quaterphenyls, other things that occurred during either 16 the cooking or the heat exchange business. So they got 17 sick, a lot of them. About 1,000 of them got quite ill. 18 And it was quite a ruckus over in Japan because you get 19 1,000 people sick. And they had chloracne, they had other 20 problems. They had pigmentation. They had poor teeth in 21 children. And they finally checked it out and they 22 found First they thought it was due to PCBs, and then 23 they found out afterwards that it was not. It was due to 24 contaminations in the PCBs that occurred either in the 25 processing of the rice oil at the factory or that occurred WATER PCB-SD0000033120 170 1 in the cooking of the soybean pancakes in the Japanese 2 homes. 3 Q. Okay. Let me stop you there because you 4 covered quite a bit of territory. 5 A. That's as brief as I can make it. 6 Q. Yeah. Well, I know it's not an incident that 7 you can describe in ten words. You mentioned that this 8 Japanese Yusho incident involved Japanese PCBs? 9 A. That's correct. 10 Q. Did it involve any Monsanto or United States 11 PCBs? 12 A. No, it did not. 13 Q. And was there any difference between the 14 Japanese PCBs involved in the Yusho incident and Monsanto 15 PCBs? 16 A. To the best of my knowledge, Japanese PCB is 17 manufactured somewhat differently than the United States. 18 It uses a sodium hydroxide step in the manufacture. I'm 19 not a chemist, so I can't say exactly what happened. But 20 it is There were more The presence of dibenzofurans 21 in the Japanese occurred in the Japanese PCBs to a 22 greater extent I don't know how much greater than it 23 might have occurred if it occurred at that time in the 24 Monsanto PCBs. There also were quaterphenyls, which were 25 not present in the Monsanto PCBs. So we had a different WATER PCB-SD0000033121 171 1 ball of wax than the Monsanto run of the mill PCBs. 2 Q. Okay. And are you aware of any other 3 incident or any incident in the United States where people 4 ate PCBs like they did in Japan? 5 A. No, I am not. I have not. 6 Q. And was there another incident outside of the 7 United States where people accidentally ate Japanese PCBs? 8 A. Ten years later the same thing in Taiwan. 9 Q. Okay. 10 A. The same business, the same rice oil, which 11 was called Yucheng, something like Y a dash cheng. 12 Q. Okay. Is there anything published in the 13 medical literature about the Yusho incident? 14 A. Oh, lots. I mean, first of all, the first 15 year or so it came out in the Japanese literature. Then 16 sometime in the early '70's there was quite a bit in the 17 United States literature. I think they are still 18 publishing it. 19 Q. Did the literature about this Yusho incident 20 where the Japanese ate accidentally Japanese PCBs, was 21 there anything in that literature about the cause of the 22 illnesses ? 23 A. Well, yes. They said it was the added 24 compounds that occurred in the dibenzofurans and the 25 quaterphenyls that were present in the Japanese PCBs WATER PCB-SD0000033122 172 1 either as a result of the Japanese manufacture or what's 2 happening during the heat transfer process or what's 3 happened in the cooking of the rice pancakes. 4 Q. Are there any quaterphenyls that were in the 5 Japanese PCBs, are they in the Monsanto PCBs? 6 A. To the best of my knowledge, no. 7 Q. Did the National Cancer Institute do any 8 studies on PCBs? 9 A. They did on one, 12 PCB 1254. They did a 10 two year testing on rats. 11 Q. What were the results of that study? 12 A. It was primarily looking for cancers in order 13 to Kimbrough did hers on 1260, so the cancer did theirs 14 on 1254. They didn't come up with any cancer. 15 Q. Dr. Kimbrough did some two year feeding 16 studies, I think you mentioned, where she fed 17 A. 1260. 18 Q. PCBs called 1260 to rats for a long term? 19 A. Two years. The cancer people fed rats for 20 two years also with 1254. 21 Q. What were the results of Dr. Kimbrough's 22 long term studies where she fed rats PCBs for two years? 23 A. Depends who you talk to. I mean, Dr. 24 Kimbrough came up and stated under oath that she found 25 liver cancers in a pretty high percentage of her animals. WATER PCB-SD0000033123 173 1 We had a meeting with Kimbrough, I was at the meeting, and 2 she said, "This is what I found." And I said, "Well, 3 look. We used the same stuff. I believe it's almost the 4 same lot numbers. We used a different strain of rats than 5 you did. Why don't you send us your slides, and we'll 6 give you our slides? " So she let us look at her slides, 7 Monsanto when I say "we". This is just about the time 8 a month before I left. After I left, they sent it up 9 they her slides up to the Eppley Institute of Cancer at 10 the University of Nebraska Medical School as well as 11 Northwestern University Department of Pathology, and those 12 people said, "Well, we don't agree with what Dr. 13 Kimbrough's calling cancers. We don't think they are. 14 There may be one or two, but there aren't a bunch that 15 she's talking about." I never did see any paper on what 16 Kimbrough thought of our slides, so I can't say what she 17 said. 18 Q. But at any rate, your tests on rats didn't 19 show any cancer in the rats? 20 A. No, but No, they did not. But I think to 21 be completely honest, there have been studies that show 22 that probably 1260 in rats causes cancer of the liver, but 23 it's a different a funny kind of a cancer. It doesn't 24 metastasize. It doesn't keep on growing. And the 25 mortality of the rats Doesn't kill the rats I mean. WATER PCB-SD0000033124 174 1 It's there, but they live just as long as the control 2 rats. 3 Q. Okay. Did Dr. Kimbrough use you said a 4 different type of rat than Monsanto? 5 A. A different A different species. I mean, 6 just like if somebody used beagles and somebody used 7 German shepherds or cocker spaniels. I mean, she had a 8 different strain of rats. Laboratories use half a dozen 9 different strains of rats. They are all white rats. They 10 are all about the same size. But she used just female 11 rats. So we used a different strain. We used male and 12 female together. 13 Q. Is this the same Dr. Kimbrough that later 14 determined that there was no evidence that PCBs cause any 15 human long term disease? 16 A. That's what she stated, the same person. 17 Q. Dr. Kelly, have you ever known a Dr. von 18 Oettingen? I think his name came up earlier. 19 A. Oh, yes. A long time ago, when I started in 20 the business. 21 Q. Okay. And who was he? 22 A. He was I believe he was with the 23 government for awhile. He was a well known German 24 toxicologist. He was a Ph.D. and an M.D. Then came to 25 the left the government and went to the first WATER PCB-SD0000033125 175 1 toxicological laboratory outside of a medical school, a 2 Haskell Institute at Wilmington, Delaware. He was used as 3 a consultant by good size companies. He was used by 4 Westinghouse at a consultant. 5 Q. Okay. Would you take a look at Exhibit 6 K 128, and I'll ask you if you can identify that, Doctor? 7 A. Yes. This is a document dated March the 8 28th, 1938, entitled "The Toxicity and Potential Dangers 9 of Inerteen," submitted by Dr. von Oettingen, Director of 10 the Haskell Laboratories, to the Westinghouse Electric 11 Manufacturing Company, East Pittsburgh. 12 Q. Okay. And Inerteen, again, is what? 13 A. Inerteen is the trademark of a PCB electric 14 transformer fluid made specifically according to 15 Westinghouse's direction, made by Monsanto. I don't 16 believe by anybody else unless they use foreign PCBs. 17 Q. What type of testing did Dr. von Oettingen 18 perform with Inerteen back in 1938? 19 A. Remember, back in 1938, that was sort of the 20 beginning of toxicology. They weren't doing This was 21 as sophisticated as anybody was doing there. So he did 22 oral administration, took a hundred rats and put the stuff 23 into them in varying doses. Then he examined them 24 pathologically. Then he had repeated doses. He took 33 25 groups of rats, gave it for five days, and he did WATER PCB-SD0000033126 176 1 Q. The testing he did on rats, did he have them 2 inhale PCBs? 3 A. I'm getting to that. 4 Q. Did he have to feed 5 A. He applied it to the skin of rabbits. Yes, 6 he had them inhale the material. 7 Q. So he had them eat the PCBs, inhale PCBs, and 8 then did skin tests? 9 A. That's correct. 10 Q. What 11 A. He gave them quite a few exposures. He gave 12 some rats 41 different exposures. 13 Q. What do you mean by "exposure"? 14 A. Well, he had them inhale the material 41 15 different times, different days. 16 Q. What potential harmful problems did Dr. von 17 Oettingen report in 1938 in relation to the PCB called 18 Inerteen? 19 A. I'll go right to his conclusions. Well, as 20 far as inhalation is concerned, he came out with pretty 21 much the same as Treon did 20 years later, 18 years later. 22 '38 to '55. He said from animal experiments reported it 23 appears that concentrations below .05 milligram per liter 24 of air he even got higher than Treon would cause no 25 toxic symptoms. WATER PCB-SD0000033127 177 1 Q. So he recommended safe levels of air 2 concentration 3 A. He came out with a safe level, yes. 4 Q. Let me Try to wait until I finish. 5 A. I'm sorry. 6 Q. Because the jury won't understand if we're 7 both talking, and the court reporter has a terrible time. 8 So Dr. von Oettingen recommended safe levels of air 9 concentrations of Inerteen in the workplace 10 A. That is correct. 11 Q. in his report? Did he outline a procedure 12 whereby Westinghouse could test the air to learn whether 13 there are unsafe concentration of vapors? 14 A. Yes. He gave a simple method for the 15 determination of Inerteen, and, you know, at Westinghouse, 16 when I came with the company, they were pretty much in the 17 forefront of industrial medicine. They had a fellow who 18 was their medical director, T. Lyle, Lyle, Hazlett, 19 H a z 1 e t t. This fellow was one of the fathers of 20 industrial medicine. And they had a pretty sophisticated 21 medical department when I came there. 22 Q. When you came to Monsanto? 23 A. When I came to Monsanto. 24 Q. So that would be in the 1930's? 25 A. Late '30's, yes. And they had it all the way WATER PCB-SD0000033128 178 1 down to the time I left. They had a good size industrial 2 hygiene department also. So they knew how to do 3 industrial hygiene, and he gave them the method he used to 4 find out how much was in the air. 5 Q. Did Dr. von Oettingen in his 1938 report, 6 which is Exhibit 128, recommend safe handling precautions 7 for PCBs? 8 A. Oh, yes. He said personal hygiene is quite 9 important. First he said you ought to use ventilation if 10 you've got concentration to get concentrations down to a 11 safe level. Then he said contamination of skin should be 12 avoided by wearing proper protective garments, such as 13 gloves, caps, coveralls. Then he said if you're going to 14 get accidental or higher exposure, use respirators, and he 15 also said you should have periodic examinations. So he 16 gave quite a bunch of safe handling procedures, which were 17 pretty much as we gave. 18 Q. And by "we," you mean Monsanto? 19 A. Monsanto. I'm sorry. Monsanto. 20 Q. And you mentioned Westinghouse had a medical 21 director while you were at Monsanto? 22 A. They had a full fledged medical organization 23 while I was starting one. 24 Q. To your knowledge, did Westinghouse have 25 knowledge on the subject of toxicity and safe handling WATER PCB-SD0000033129 179 1 precautions for Inerteen? 2 A. If they read the article they paid for, yes. 3 This was done for Westinghouse. 4 Q. Did Westinghouse employ industrial 5 hygienists? 6 A. Yes, they did. 7 Q. Do you know any of the industrial hygienists 8 employed by Westinghouse? 9 A. Well, not in the early days. The later days, 10 after we got an industrial hygienist, I made the 11 acquaintance of a person who was an administrator. I 12 don't know how many people he had under him, but a Dr. 13 Speicher, Speicher. 14 Q. He was employed by Westinghouse as an 15 industrial hygienist? 16 A. At the headquarters in Pittsburgh, East 17 Pittsburgh. 18 Q. Was Dr. Speicher a competent industrial 19 hygienist to your knowledge? 20 A. Oh, yes. He was head of the industrial 21 hygiene for some state. I don't know whether the state 22 was Pennsylvania. I don't know which one. 23 Q. Okay. I think we're about to run out of 24 tape, so we'll break for a minute. 25 (Brief recess.) WATER PCB-SD0000033130 180 1 Q. Dr. Kelly, if you would take a look at 2 Exhibit K 129. Can you identify that exhibit? 3 A. Yes. This is a letter from Mr. Elmer P. 4 Wheeler of the Medical Department of Monsanto dated July 5 25th, 1956, to a Mr. Speicher, Speicher, the 6 Administrator of Industrial Hygiene at Westinghouse 7 Electric Company. 8 Q. And did you give the date? 9 A. Yes. July 25th, 1956 10 Q. It's getting late in the day, and I'm 11 starting to forget what was said ten seconds ago. And was 12 this letter sent to Westinghouse by Monsanto on or about 13 July 25, 1956? 14 A. Yes, it was. 15 Q. Take a look at this letter, if you would, and 16 I don't want you to read it into the record, but if you 17 could just go through it and summarize it. 18 A. Well, yes. He asks for toxicity information 19 on several of the Aroclors, the PCBs, and he asks how do 20 you sample for it, how do we sample for it, I suppose, in 21 the air. So Wheeler sent him the reports from the 22 Kettering Laboratory that we discussed here, the Treon 23 reports, and told him where it was published, and he said, 24 "I'm sure you've got it," because he knew that they had as 25 big a library as we did, and then he talked about WATER PCB-SD0000033131 1 Treon's 181 2 Q. So when you say "send reports," it was Mr. 3 Wheeler at Monsanto was sending the reports to 4 Westinghouse? 5 A. Send the reports, but he also told them where 6 it was published. 7 Q. He's sending thesereports to Mr.Speicher at 8 Westinghouse? 9 A. Yes, he was. 10 Q. Go on. 11 A. Then he said thatTreon gavelevels for the 12 safe levels of air, and he said Treon told how to sample 13 at its plant, and Wheeler said, "We did a little sampling 14 of our own, and here's what we used." Then Wheeler said, 15 "You've previously seen our complete report on what 16 happens if you drop Pydraul," which is a PCB containing 17 hydraulic fluid, "onto hot metals," and it appears that 18 Speicher was interested in making magnesium die castings, 19 which is something we didn't know about, so he also 20 Wheeler also the second page said what we recommend as far 21 as the skin is concerned. 22 Q. If PCBs come in contact with skin? 23 A. The PCBs, yes. He recommended repeated or 24 prolonged skin contact be avoided, and he also stated what 25 I have said earlier, that reported cases of skin WATER PCB-SD0000033132 182 1 irritation have been surprisingly few in view of the 2 tonnage quantities that we've manufactured and handled. 3 So that's about the gist of that letter. 4 Q. Okay. Let's go on to Exhibit K 130. Can you 5 identify that? 6 A. Another letter to Mr. Speicher from Wheeler. 7 Q. Okay. And, again, where is Mr. Speicher? 8 A. At the headquarters of Westinghouse in East 9 Pittsburgh. 10 Q. Okay. 11 A. This is three years later, October 23. He is 12 interested at that time in a particular mixture of PCBs. 13 We called it We had 1260 in this one, and I believe 14 here he was concerned about 1254, 1242 and 54. And we 15 advised, again, that the chronic toxicity with PCBs 16 That was the inhalation, because that's the only 17 inhalation we had. We didn't say, "We sent this to you 18 three years ago." But he then stated that they should 19 avoid skincontact and 20 Q. With what? 21 A. With PCBs. 22 Q. Okay. 23 A. And we stated that there was an article in 24 the literature that some people had three people had 25 developed minor chloracne from a heat transfer agent. WATER PCB-SD0000033133 183 1 That was the Meigs article. That was in the literature. 2 That was a leaking heat transfer agency. I think I 3 mentioned that. And he talked about the case where we 4 a mild case of chloracne with workmen dipping their hands 5 in liquid Aroclor. That was really workpersons. That was 6 females that did it. That's the case I referred to at the 7 thermometer company. Then he asked about exhaust 8 ventilation, and we said what we should do. Anytime you 9 heat it over 150 degrees F in open tanks, you ought to 10 be you've got to have exhaust or ventilation. So we 11 went through a long list of talked a great deal about 12 this, and he said he's been in one plant where they were 13 used for transformers and capacitors, where Monsanto PCBs 14 were. 15 Q. Who I'm not understanding. 16 A. Wheeler also went on this third page talking 17 about his experience in going to a capacitor and 18 transformer plant, and he said 19 Q. Whose plant? 20 A. Who? Somebody's plant. He didn't say. One 21 plant. Not Monsanto's obviously, because we don't make 22 capacitors or transformers. But he said, "I've been in 23 one plant where the materials were used for capacitors and 24 transformers." And he said he didn't think that the 25 ventilation was good enough there, and the only problem WATER PCB-SD0000033134 184 1 they had was eye irritation when they got the material up 2 to 120 degrees C, which is roughly 200 degrees Fahrenheit. 3 He said they should ventilate the vapors, and he also 4 suggested to Mr. Speicher he ought to talk to some of his 5 people, the manager of the transformer manufacturer for 6 Westinghouse. 7 Q. By "his people," who do you mean? 8 A. The Westinghouse people, I'm sorry. Wheeler 9 told Speicher, "Why don't you talk to some of your 10 Westinghouse manufacturing people who have been used using 11 this material for 25 years?" He gave him the name of the 12 head of Sharon. And then he said, "You've got a man at 13 Bloomington who's been used been associated" 14 Q. Why don't you read that sentence where Mr. 15 Wheeler in your department is telling Westinghouse to 16 contact a Westinghouse person in Bloomington? 17 A. "Similarly, Mr. R. E. Marbury," 18 M a r b u r y, "of your Bloomington Indiana plant has been 19 associated with the use of Aroclor 1242. Presumably you 20 have already discussed potential exposures with these 21 gentlemen. If so, I would be interested in learning of 22 their practical experience with these products." 23 MR. MURRAY: You need to correct that word. 24 Q. Yes. You said "presumably," and I think it's 25 "perhaps". Why don't you read those sentences again WATER PCB-SD0000033135 185 1 because I think you said "presumably" instead of 2 "perhaps". You misread one word. 3 A. Wait a minute. 4 Q. Just read it out loud again so we make sure 5 we have it correct. Read starting with 6 A. I'll start the whole paragraph. 7 Q. No. Just start with "similarly". 8 A. "Mr. Marbury, R. E. Marbury, of your 9 Bloomington, Indiana plant" "Similarly, Mr. Marbury of 10 your Bloomington, Indiana plant has been associated with 11 use of Aroclor 1242. Perhaps you have already discussed 12 potential exposures with these gentlemen. If so, I would 13 be interested in learning of their practical experience 14 with these products." 15 Q. And, again, this is Was this letter from 16 Monsanto to Westinghouse sent to your knowledge to 17 Westinghouse? 18 A. Oh, yes. It was sent from the Medical 19 Department to Mr. Speicher at the headquarters of 20 Westinghouse. 21 Q. Okay. Let's take a look at Exhibit 131. 22 A. This is a letter also from Monsanto from 23 Wheeler of the Medical Department to Mr. Speicher at 24 Westinghouse, June of '69, which is three months before 25 the previous letter. It looks like he must have been WATER PCB-SD0000033136 186 1 asking for 2 Q. Let me go back. There was one other guestion 3 I wanted to ask you on Exhibit 130. Do you have that 4 still? 5 A. Yeah. Uh huh. 6 Q. Okay. In that letter, did Wheeler give Mr. 7 Speicher at Westinghouse any material other than referring 8 him to Westinghouse's own internal own plant people at 9 Bloomington? 10 A. Well, he referred to work by von Oettingen in 11 1955, if that's what you mean. 12 Q. No. I'm talking about the bottom of page 13 two, the last paragraph, that first sentence in the last 14 paragraph. 15 A. Page two in 16 Q. In the 17 A. K 130? 18 Q. Yes. 19 A. Well, I'll read it and we'll see. "The 20 enclosed publication on the toxicity of Aroclor 1242 and 21 1254 suggests an MAC" 22 Q. Okay.That's I just wanted to get So 23 Wheeler enclosed a publication on the toxicity of Aroclor 24 1242 and 1254 in this Exhibit 130, the letter to 25 Westinghouse? WATER PCB-SD0000033137 187 1 A. Yes. Yeah, that's 2 Q. I forgot to bring that out, and now we can go 3 to 131. 4 A. Yes. I thought someplace said it enclosed 5 Aroclor bulletin. That is another publication on 6 toxicity. That was Treon's publication that he sent him. 7 Q. Okay. Let's go on to 131. Can you 8 identify Is that a letter from Wheeler in your 9 department in Monsanto to Mr. Speicher, Westinghouse, 10 dated June 5, 1969? 11 A. Yes, it is. 12 Q. And is that Was that letter sent by 13 Monsanto to Westinghouse? 14 A. Yes, it was. 15 Q. Okay. 16 A. It seemed that he wanted Speicher wanted 17 some Underwriter Laboratory studies on Westinghouse 18 products. I don't know who did that. I don't know if 19 Westinghouse did it, made the studies, or if Monsanto did 20 it. I don't know. But, at any rate, Underwriter 21 Laboratories are usually fire and explosions. They really 22 are not toxicity testing. So I do not believe that was 23 done by the Medical Department. 24 Q. Did Mr. Wheeler forward to Mr. Speicher at 25 Westinghouse toxicity information relating to Monsanto's WATER PCB-SD0000033138 188 1 Therminol heat transfer fluid? 2 A. Well, again, he sent, yes, a reprint of 3 Treon's publication. This appears that it's the third 4 time he sent it to him. In the third paragraph it says, 5 "I enclose also a reprint of Joe Treon's publication on 6 the toxicity of Aroclor 1242 and 54." And he said we 7 don't have enough similar data on 48, but we believe it's 8 someplace between 42 and 54. 9 Q. Take a look at the second I know in the 10 third paragraph he encloses the Treon publications; 11 correct? 12 A. Correct. 13 Q. In the second paragraph, what does he enclose 14 there ? 15 A. He encloses one of our product bulletins, our 16 technical bulletins, our application bulletins, whatever 17 they called it, relating to the fluid heat systems. 18 That's for Therminol. 19 Q. Okay. That's a PCB? 20 A. That's PCBs. 21 Q. Okay. 22 A. Then he also said he was forwarding it 23 without a letter from me referring to our favorable 24 manufacturing experience for a period of more than 30 25 years. So presumably I sent him one later, but I don't WATER PCB-SD0000033139 189 1 know. 2 Q. Okay. Let's take a look at Exhibit 132. Can 3 you identify that document? 4 A. This is a letter from Mr. Wheeler again to a 5 Mr. Bindschauler, Bindschauler, safety 6 administrator of Westinghouse Electric. 7 Q. So is this a letter from Monsanto then to 8 Westinghouse dated February 12th, 1969? 9 A. That is correct. He's asking He inquired 10 about the properties of Therminol. I don't know the name, 11 but it was a heat transfer Therminol that contained a PCB 12 1254 . 13 Q. Okay. 14 A. He enclosed a Hygienic Guide from the 15 American Industrial Hygiene Association which discussed 16 the toxicity. 17 Q. Of what? 18 A. Therminol. The Therminol compounds. 19 Q. The PCB compounds? 20 A. The PCBs. Then a statement by a medical 21 by me summarizing the toxicity and safe handling data of 22 Monsanto Therminols, and a Monsanto publication discussing 23 the proper engineering for Therminols. And he gave the 24 threshold limit, gave our experience. 25 Q. Okay. Would you read the WATER PCB-SD0000033140 190 1 A. And then he ended up by saying, "Look" 2 I'll quote this. I won't paraphrase it. "I'm sure you 3 know that your company has had many years of experience in 4 handling and using the chlorinated biphenyls as electric 5 transformer fluids. It is possible that your experience 6 is wider than ours in terms of exposure levels in a user's 7 plant as compared to our manufacturing facilities." Well, 8 obviously, it certainly was. 9 Q. And he mentions chlorinated biphenyls? 10 A. That's PCBs. 11 Q. Okay. 12 A. That's Inerteen, whatever else you want to 13 call it. 14 Q. So Wheeler is saying that Westinghouse may 15 have more experience with PCBs than Monsanto with regard 16 to exposure? 17 MR. MURRAY: Object to the form of the 18 question. 19 A. Yes. That's what he's saying, yes, because 20 he said exposure levels at a user's plant. We've got 21 exposure levels in our plant, but we're not a user, so 22 you've got a lot more experience in a user's plant. 23 Q. And was this letter that's K 132, the letter 24 from Monsanto to Westinghouse, sent to Westinghouse on or 25 about February 1969? WATER PCB-SD0000033141 191 1 A. Yes, it was. To the safety administrator. 2 Q. Let's go to 130 Exhibit 133. Can you 3 identify that document? 4 A. This is another letter to Dr. Speicher from 5 Mr. Wheeler of Monsanto. Mr. Speicher is still in the 6 headquarters of the Industrial Hygiene Department of 7 Westinghouse Electric. Dated March the 5th, 1969. 8 Q. Okay. And what's this letter do? 9 A. He wanted two more copies of Treon's 10 publication on the toxicity of the vapors of the two PCBs, 11 Aroclor 1242 and 1254. 12 Q. Okay. 13 A. I think that's the fourth one that we sent 14 him. 15 Q. And was that letter, Exhibit 133, sent by 16 Monsanto to Westinghouse? 17 A. Yes, it was. 18 Q. And, finally, or I won't say finally, but 19 Exhibit 134, can you identify that document? 20 A. This is a letter from Mr. Wheeler, again 21 dated April 28th, 1970, to a Dr. Sloat, S 1 o a t, who is 22 in the Transformer Division of Westinghouse Electric. 23 Q. Okay. And this is a letter then from 24 Monsanto to Westinghouse, the Transformer Division, dated 25 April 28, 1970? WATER PCB-SD0000033142 192 1 A. Yes. He's not in the headquarters. He's at 2 Sharon, Pennsylvania. 3 Q. And what does this Does this letter send 4 any information to Westinghouse? 5 A. Well, he's giving them a status of the animal 6 toxicity studies. It looks like Sloat and two other 7 people from two other people from Westinghouse met with 8 Wheeler someplace, and Wheeler gave them two copies of the 9 ongoing study. Remember, these are the studies that we 10 were running at Calandra that we started in 11 Q. The Industrial Bio Test studies? 12 A. The Industrial Bio Test. We started on 13 Aroclor PCBs in '68, '69. We got the final reports in 14 '71. This was the beginning. The tests had been going 15 probably a year. So we had interim reports, and they gave 16 them to the associates, and Sloat wanted one for himself, 17 so Wheeler sent him one. 18 Q. So Wheeler was sending Westinghouse the 19 interim I.B.T. or Industrial Bio Test studies on the 20 status of animal toxicity studies of PCBs? 21 A. Yes. Presumably that's what it is because 22 that's the only ongoing studies we had at that time. 23 Q. Did Monsanto respond to Westinghouse when it 24 asked for studies or materials about PCBs? 25 A. Oh, certainly. Whenever they asked, we sent WATER PCB-SD0000033143 193 1 it to them. And they asked quite a few times. I mean, I 2 don't know if this is all the letters, but Wheeler and 3 Speicher had quite a busy correspondence. 4 Q. Dr. Kelly, if Westinghouse and Westinghouse 5 workers followed the safe handling instructions provided 6 by Monsanto in the bulletins and labels and the 7 correspondence that we've just gone over together with the 8 safe handling precautions of Dr. von Oettingen, the 9 Westinghouse consultant, in your opinion to a reasonable 10 degree of medical certainty could the various PCB products 11 utilized by Westinghouse at its plants be used without ill 12 effects ? 13 A. No question about it. 14 Q. And what's the basis for that opinion? 15 A. Well, my experience with our own workers, my 16 experience with the information I obtained from other 17 people who used our products, the absence of problems with 18 the case reports, the absence of case reports in the 19 medical literature. There are absence of any government 20 reports. 21 Q. Were the various articles that we've gone 22 over, Dr. Smith and Dr. Drinker's article and Dr. Treon's 23 article, readily available to a company like Westinghouse 24 or anyone else who cared to research the subject? 25 A. Oh, certainly. Westinghouse was not a mom WATER PCB-SD0000033144 194 1 and pop operation, you know. This was a pretty big 2 organization, bigger in the electrical field than we were, 3 and they had a very sophisticated medical department and a 4 good size industrial hygiene group. Certainly it was 5 available to them. 6 Q. Dr. Kelly, did Monsanto send Westinghouse 7 information on the subject of avoiding environmental 8 contamination by PCBs? 9 A. We sent it to all our customers, and I'm sure 10 we sent it to Westinghouse. 11 Q. And who at Monsanto was in charge of sending 12 out the environmental communications to PCB customers? 13 A. William Papageorge. 14 Q. So he would be the best person to askabout 15 that information? 16 A. Yes, he would. 17 Q. During the time that you were Medical 18 Director at Monsanto, I think you've indicated that 19 General Electric had a medical director or medical 20 department? 21 A. Yes. They had one when I came with them, a 22 Dr. Vosburgh. They had one when I left, a Dr. Casey. 23 They had somebody in between, but I don't remember the 24 name or names. 25 Q. And I believe you'veindicated Pyranol was WATER PCB-SD0000033145 195 1 General Electric's trademark for PCB containing dielectric 2 fluid for transformers? 3 A. Yes. Remember, General Electric invented the 4 dielectric PCBs. They invented PCBs . 5 Q. Was General Electric 6 A. It was their patent. They have a patent on 7 the product. 8 Q. Okay. Was General Electric knowledgeable on 9 the subject of toxicity and safe handling of PCBs? 10 A. Oh, yes. 11 Q. Was 12 A. They were probably even a bigger outfit than 13 Westinghouse. 14 Q. Was General Electric provided with the 15 various product bulletins containing safe handling and 16 toxicity information relating to Pyranol and other 17 PCB containing fluids which we've previously discussed? 18 A. Yes, and they also contributed to some of the 19 bulletins as we've seen earlier. 20 Q. Did Monsanto attempt to send PCB safe 21 handling information to General Electric transformer 22 customers ? 23 A. No, we did not. 24 Q. Why was that? 25 A. Well, we gave theinformation toGeneral WATER PCB-SD0000033146 196 1 Electric. They built the transformers. They were General 2 Electric's transformers. They knew how to They were 3 told how to prevent injury to their own workers and to 4 anybody that came in contact with the material. 5 Q. Did you know who General Electric's customers 6 were? 7 A. I haven't the slightest idea. 8 Q. Let me show you Exhibit 136. Can you 9 identify that exhibit? 10 A. Yes, I can. 11 Q. Would you, please? 12 A. It is a file copy from Dr. Hunt of the 13 Medical Department, our toxicologist. 14 Q. Monsanto Medical Department? 15 A. Monsanto Medical Department. Dated October 16 the 30th, 1962, concerning a telephone call that was 17 referred to him from a Mr. Kozoriz, K o z o r i z, of the 18 General Electric Company of Hudson Falls. He got a A 19 man by the name of Benignus received a wire from this 20 gentleman at General Electric. He wanted immediate 21 information on some toxicity data on exposures, so Hunt 22 talked to this G.E. employee and told him what acute 23 toxicity data we had for these two compounds. It appeared 24 he was interested in They must have had an acute 25 exposure someplace. So we sent Monsanto sent them that WATER PCB-SD0000033147 197 information, three publications. 2 Q. What were the three publications? 3 A. I don't know. 4 Q. But there were three publications on PCBs ? 5 A. Yes. 6 Q. Let's take a look at Exhibit 138. Can you 7 identify that document? 8 A. This is a letter from me to 9 Q. Are you on 138? 10 A. 37 . 11 Q. Oh, I'm on 138. 12 A. What do I do with 37? 13 Q. Well, put it aside. 14 A. Okay. This is a letter to a General Elect 15 employee, Mr. well, a General Electric employee, from 16 Elmer Wheeler of our department, Monsanto's Department 17 of Medical Department, to this man at Selkirk, New York 18 in their polymer products. That's their plastics 19 department. 20 Q. So this is a letter from Monsanto then to 21 General Electric dated October 10, 1969? 22 A. That's correct. 23 Q. Was this letter sent to General Electric by 24 Monsanto on that date? 25 A. Yes, it was. WATER PCB-SD0000033148 198 1 Q. And did What was this letter concerning? 2 A. Well, this concerned Aroclor 1268, and 3 that's 4 Q. That's a PCB? 5 A. A PCB, but it's a solid. 6 Q. Okay. 7 A. It's a white off colored solid. So Wheele 8 Look, you're going to have to get it real hot to 9 get any vapor exposure from this stuff." He said we 10 didn't have chronic testing on it, but the acute testing 11 shows that it was quite innocuous, and the rabbit the 12 skin rabbit testing showed it was also inoccuous. 13 Q. What do you mean by inoccuous? 14 A. Not harmful. I'm sorry. Not harmful. As I 15 said, we didn't have vapor inhalation because it was 16 almost impossible to get the stuff to melt it and boil 17 off the vapors. But then he said 18 Q. Does this letter contain any safe handling 19 information that Monsanto gave to General Electric? 20 A. Well, yes. He said because of the physical 21 characteristics of the stuff, of the PCB, it would be 22 extreme have extreme handling or usage conditions to 23 reach this concentration in the atmosphere. He did say, 24 however, if the stuff is going to be heated you ought to 25 have mechanical exhaust ventilation around there. He also WATER PCB-SD0000033149 199 1 said he was going to send a copy of this letter to his 2 friend, Jack Ferry, who was the counterpart of Wheeler at 3 that time in Medical Department in Industrial Hygiene 4 Department at General Electric. He was He must have 5 been at the headquarters. 6 Q. Okay. Why don't we go on to 141? This is a 7 December 17 letter from you I'm sorry. Exhibit 141A. 8 Do you have Exhibit 141A? 9 A. Yes, I do. 10 Q. Why don't you identify that for the record? 11 A. That's a letter from me to a gentleman at 12 American Mutual Liability Insurance Company, December 13 17th, 1952, who asked a few questions about Aroclors. He 14 was particularly interested in gloves. I sent him the 15 information about the physical properties of Aroclor 16 together with information concerning packing materials and 17 told him about the gloves. I said rubber gloves what 18 gloves could be used, and I said I was concerned about a 19 statement of nausea and headaches that the workers had, 20 and I 21 Q. Why don't you read then the last sentence in 22 the second to last paragraph? 23 A. Well, shall I read the whole paragraph? 24 Q. I'd 25 A. Whatever you say. WATER PCB-SD0000033150 200 1 Q. I think that's a long paragraph. 2 A. Okay. Well, I said, "Certainly I do not 3 believe the fumes evolved at 180 degrees should be 4 breathed. This, of course, will depend upon what Aroclor 5 is used. The larger capacitor manufacturers, such as G.E. 6 and Westinghouse, have not experienced any of these 7 circumstances." 8 Q. And, again, G.E. is General Electric? 9 A. General Electric. I'm sorry. 10 Q. Okay. Why don't we go to 142? 11 A. This is a letter of Jack Garrett, who is a 12 manager of our Industrial Hygiene Section in the Medical 13 Department of Monsanto, dated November 14th, 1963. 14 Q. And what company is that letter directed to? 15 A. To Fleming of the OccupationalHealth Branch 16 of the Tennessee Valley Authority. 17 Q. So that letter is directed to the Tennessee 18 Valley Authority? 19 A. That's correct. 20 Q. Was that letter sent out on or about November 21 14, 1963? 22 A. Yes, it was. 23 Q. And 24 A. He asked for animal toxicity from us on the 25 possible hazards of the use of Pydraul 625, which is a PCB WATER PCB-SD0000033151 201 1 compound, a PCB of Monsanto mixed with something else. 2 Q. Okay. And did Monsanto send T.V.A. the 3 animal toxicity information requested on this PCB? 4 A. Yes, we did. He wanted to know what was in 5 it. We said we just can't tell you because it's not our 6 compound. I mean, it's developed jointly by somebody 7 else, and we can't let it out. But here's the data on it 8 that ought to allow you to have safe handling procedures 9 carried out. 10 Q. Let's go on to Exhibit 143. Can you identify 11 that document? 12 A. That's a letter from Elmer Wheeler of 13 Monsanto's Medical Department. 14 Q. And which company is that referring to? 15 A. This goes to a Smith, industrial hygienist of 16 the Tennessee Valley Authority, the T.V.A. 17 Q. That's a letter dated September 1, 1970 from 18 Monsanto to the Tennessee Valley Authority? 19 A. That's correct. 20 Q. Okay. 21 A. And he's giving You want me to give the 22 gist of it? 23 Q. Yes. That might be the best way to do it. 24 A. He states, "here's a list of literature 25 references dealing with the environmental aspect of PCBs WATER PCB-SD0000033152 202 1 and two summaries indicating the status of the chronic 2 toxicity and biodegradation studies." Biodegradation 3 means it breaks down or doesn't break down. 4 Q. So this was a letter sent to T.V.A. 5 containing information about PCBs and its toxicity? 6 A. That's correct. 7 Q. Okay. Let's go on to Exhibit Well, just 8 to make sure, I don't know if I asked this question. With 9 regard to Exhibits 142 and 143, were they sent by Monsanto 10 to T.V.A.? 11 A. Yes, they were. 12 Q. Do you know whetherT.V.A.had a medical 13 department? 14 A. Yes, they did, because I had quite a bit of 15 contact with the T.W. T.V.A. because they made 16 phosphorous. They used phosphorous. We made phosphorous. 17 And they were pretty sophisticated. They were doing 18 laboratory research on phosphorous with rats when we 19 weren't. So they were quite knowledgeable about They 20 had a good medical department and a good industrial 21 hygiene group and a good toxicological group. 22 Q. And I used the initials T.V.A., but, again 23 A. Tennessee Valley Authority. 24 Q. that stands 25 A. Yes. They were right up there. WATER PCB-SD0000033153 203 1 Q. Okay. Do you know whether the Ford Motor 2 Company had a medical department? 3 A. They had a big one. 4 Q. Okay. Did they also have industrial 5 hygienists? 6 A. Oh, yes. They had lots, because they had 7 problems with their soldering, they had problems with 8 their paint. They had a big industrial hygiene and a big 9 medical group. I knew them quite well. 10 Q. Did you know the Did they have a medical 11 director as well? 12 A. Oh, sure. Bud Irwin was the first one that I 13 knew, and Dwayne Block was one. So they had it all the 14 time I was with Monsanto. 15 Q. Let's take a look at Exhibit 145. Can you 16 identify that exhibit? 17 A. That's a letter from me to the Ford Motor 18 Company at Dearborn that's their headquarters dated 19 April 16th, 1978. 20 Q. Read that date again. I think you misspoke. 21 A. April 16th, 1968. I'm sorry. It is getting 22 late. In which he asks for information on Pydraul 312, 23 which is a PCB hydraulic fluid. 24 Q. And what toxicity information did you provide 25 Ford Motor Company in 1968? WATER PCB-SD0000033154 204 1 A. Well, all we had on that was the acute 2 testing, and I gave them the testing and I told them about 3 the fact that we didn't have any illnesses in our 4 employees or did we have any reports of injuries from the 5 field, but I said there's always a possibility if you 6 breathe the stuff at elevated temperatures and if you 7 Q. Why don't youread that paragraph? 8 A. "However, there is noclinically" 9 Q. Again, hold on a minute. Let me identify the 10 paragraph. Read the second to last paragraph in Exhibit 11 141, which is the letter from Monsanto for 12 A. Second to last page. 13 Q. The letter 14 A. Clinically 15 Q. Just a minute. Let me finish my question. 16 If you would read the second to last paragraph of Exhibit 17 141, which 18 MR. MURRAY: 145. 19 Q. I'm sorry. It is getting late in the day. 20 145. And that's the letter from Monsanto to Ford Motor 21 Company dated April 16, 1968. 22 A. "However, there is no question but that a 23 potential of injury could occur should the fumes evolved 24 at elevated temperatures be breathed for long periods of 25 time or repeatedly. Likewise, the action of the material WATER PCB-SD0000033155 205 1 on the skin causes defatting but, even more so, repeated 2 or continuous skin contact must be avoided to prevent 3 absorption of the material with systemic effects. I 4 repeat, however, these conditions have not come to my 5 attention." 6 Q. Let's go next to Exhibit 146. Can you 7 identify that exhibit? 8 A. Yes. This is a letter from Jack Garrett to 9 an industrial hygienist at Ford Motor Company, same 10 office, in Dearborn, Michigan, dated February 14, 1969, 11 Jack Garrett being the manager of industrial hygiene at 12 Monsanto's Medical Department. 13 Q. And did 14 A. He asks for the same 15 Q. Let me just Let me just identify. Did 16 this letter Was this letter actually sent to Ford Motor 17 Company on or about February 14, 1969? 18 A. Yes, it was. 19 Q. And the prior exhibit, was that letter sent 20 to Ford Motor, Exhibit 141? 21 A. Yes, sir. 22 Q. I'm sorry. 145. Was that sent by Monsanto 23 to Ford Motor Company? 24 A. Yes, it was. This man was asking for 25 information on the same Pydraul. WATER PCB-SD0000033156 206 1 Q. What information did Monsanto send to Ford 2 Motor Company in the February 14, 1969 letter? 3 A. Well, we sent them two things. We sent them 4 a copy of our resume of the toxicity of Pydraul 312. 5 Q. Is that a PCB? 6 A. That's a PCB used as an hydraulic fluid. 7 Plus we also sent them a safety data questionnaire put out 8 by the Ford Motor Company, and which is sort of similar to 9 the ones put out by the government. But after the 10 government started putting their own safety data sheets 11 out, most of the companies started their own, so they sent 12 these questionnaires of theirs to all their suppliers. So 13 we got hundreds of these from various companies. So this 14 one came from Ford on Pydraul 312, and they asked all 15 these questions about precautions for normal uses, warning 16 properties, and That's about it. 17 Q. Finally, in the last sentence, Monsanto says 18 in its letter to Ford? 19 A. "If you are interested in any specific 20 Pydrauls, please inform us." 21 Q. Okay. Did Monsanto respond to any requests 22 that Ford made about information about PCBs? 23 A. Oh, yes. Anyone We responded to any 24 company that made any request about any of our products 25 from the medical point of view. Certainly Ford To WATER PCB-SD0000033157 207 1 answer your question specifically, if Ford sent us a 2 request or called us, we told them everything we knew 3 about it. 4 Q. Would the same be true of Tennessee Valley 5 Authority? 6 A. Oh, yes. Yes, sir. 7 Q. Would the same be true of General Electric? 8 A. Yes. I mean, a lot of times we were telling 9 them information that they knew more about it than we did, 10 but we told them. I mean, maybe everybody in the 11 organization didn't know it, but some of the people in our 12 customers knew. But we certainly told them. 13 Q. Okay. I've covered one Let me ask you 14 this, Dr. Kelly. If Ford Motor Company or the Tennessee 15 Valley Authority or General Electric or their employees 16 and customers followed the safe handling instructions 17 provided by Monsanto in the bulletins and labels and 18 correspondence which we've discussed today, could the 19 various PCB products utilized by Ford Motor Company, 20 Tennessee Valley Authority or General Electric customers 21 be used without ill effect? 22 A. Yes, they could. 23 Q. And that's based on the same information? 24 A. Based on the same reasons that I gave before. 25 Q. And the various articles that we've discussed 209 1 about PCBs, were they as available to the Tennessee Valley 2 Authority and General Electric and Ford Motor Company as 3 they were to Westinghouse? 4 A. Yes. As they were to us, too. 5 MR. CARNEY: I'm going to another subject 6 area. Does anybody want to quit? How much do we have on 7 the tape? 8 MS. SCHNEIDER: 20 minutes. 9 MR. CARNEY: Okay. Why don't I get a little 10 start on that? I'm not going to quite finish. 11 Q. When did Monsanto first learn that there was 12 a problem with PCBs persisting in the environment? 13 A. Sometime in the late '60's. 14 Q. And how was this environmental problem 15 discovered? 16 A. It was discovered by one of our European 17 offices. I do not know whether it was the Brussels office 18 or the London office. 19 Q. Did Monsanto make the discovery? 20 A. No, they did not. They read it in the 21 newspaper. 22 Q. Okay. 23 A. It was discovered by a Swedish group of 24 scientists, a Dr. Widmark, W i d m a r k, and a Dr. 25 Jensen, Jensen, I believe. I don't know. That's WATER PCB-SD0000033158 208 1 close enough. 2 Q. It looks like Jensen, but it's pronounced 3 "Yensen" in Swedish? 4 A. My Swedish isn't the best. 5 Q. Okay. 6 A. They were examining for various compounds, 7 and they came up with this one particular compound that 8 they couldn't identify. And they had a very new 9 sophisticated analytical tool. I don't really know. It 10 was sort of like a chromatograph, chromograph 11 (sic.), but with some additions. I'm not an analytical 12 chemist, so I can't tell you. But it was really a tool 13 that we didn't even have. So he found this stuff, and 14 using this 15 Q. By "he found," these Swedish chemists? 16 A. The Swedish chemists found this material and 17 was able to identify it as a PCB. So it hit the Swedish 18 newspapers and eventually that was picked up by the 19 Belgian newspapers and by the London newspapers. And so 20 someone either in our Belgian our Brussels office in 21 Belgian or our London office found out about it and went 22 over got in contact with Widmark and Jensen and then 23 reported it to the headquarters in St. Louis. 24 Q. And what was the report to I take it when 25 they reported to the headquarters you found out as well? WATER PCB-SD0000033159 209 1 A. Yes. They bumped it down to Medical 2 Department because in those early days Papageorge had not 3 been appointed and we were the environmental coordinators 4 as it were. 5 Q. By "we," the Medical Department? 6 A. The Medical Department. I'm sorry. The 7 Medical Department. 8 Q. What was this discovery that the Swedish 9 chemists found in the late '60's about PCBs in the 10 environment ? 11 A. There are small levels of PCBs present in the 12 bottom of some waters, some coastal waters. There are 13 PCBs found in the feathers of some fish eating birds, and 14 there are PCBs found in some fish. Now, I'm not sure if 15 all of this happened at the same time, but that's a 16 general overview of it. So when they came to me with 17 this, I said, "Well, we ought to find out more about it. 18 Let's get a group over." 19 Q. What was your reaction when you first heard 20 about this? 21 A. Well, I don't know about it. I thought you 22 people had no idea this stuff hung around. I thought you 23 people believed it was just degraded, it was 24 biodegradable. It was broken down. 25 Q. So were you surprised by this discovery by WATER PCB-SD0000033160 210 1 these Swedish chemists? 2 A. Quite surprised. So I said, "Let's be sure 3 it's really PCBs." I'm not an analytical chemist. I 4 don't know if he's right or not. So let's get somebody 5 over there to talk to him. So we They arranged 6 Q. Was there some confusion early on as to 7 whether this discovery by the Swedish chemists was really 8 PCBs? 9 A. Yes. They thought it might be DDT. In fact, 10 I think he was looking for DDT. 11 Q. Okay. 12 A. Which is, of course, an insecticide that was 13 used during the war for oh, millions of pounds. They 14 dusted everybody. 15 Q. Was there some period of time where there was 16 a confusion as to whether this Swedish finding was PCBs or 17 something else then? 18 A. There was quite a Well, I think there was 19 a confusion as to whether or not it was DDT or not, or 20 something 21 Q. Ultimately was that confusion straightened 22 out? 23 A. Well, nobody came out with the idea it was 24 not DDT. People believed it's DDT or something else. 25 Nobody knew what the "something else" was until Widmark WATER PCB-SD0000033161 211 1 and Jensen came out and said this something else is PCB 2 and we're pretty sure it's PCB, not DDT or what else. So 3 we sent over Wheeler and a Dr. Keller, Keller, who 4 was the chief of our analytical group. 5 Q. By "we"? 6 A. Monsanto. Monsanto. I'm sorry. 7 Q. Okay. So Monsanto sent over And I guess 8 you were the one who actually sent them? 9 A. Well, I brought it up to the head of the 10 Organic Division that was manufacturing PCBs. I couldn't 11 send over an analytical chemist who didn't belong to me, 12 who wasn't in the Medical Department. So they sent their 13 top scientist, their research man, "they" meaning the 14 Organic Division sent over their top research man in PCB 15 manufacturing. They sent over their top analytical 16 chemist. 17 Q. Okay. And "they" now is Monsanto? 18 A. The Organic Division of Monsanto Company. 19 And the Organic Division of Monsanto Company sent over 20 research, manufacturing, and an analytical chemist. The 21 Medical Department of Monsanto sent over Wheeler, who was 22 our industrial hygienist, who had quite a lot of 23 background in toxicology and industrial hygiene, and he 24 was a member of the Medical Department. So they went 25 over. They talked to they, this group, went over and WATER PCB-SD0000033162 212 1 talked to Widmark and Jensen, and they came back, and this 2 group came back and said, "I think he's right. This man 3 certainly seems to know what he's doing." 4 Q. When they said, "I think he's right," who are 5 "they" referring to? 6 A. Widmark and Jensen. 7 Q. This story is getting confusing to me and the 8 jury I think. Okay. 9 A. Why don't I simplify it and say Monsanto sent 10 over this group of people with individual specialties over 11 to Sweden to talk to this man, and presumably I believe 12 they talked to some government officials. This group from 13 St. Louis went over there and talked to these people, 14 Widmark and his group and the Swedish government, and the 15 Monsanto group came back and said, "We believe the Swedish 16 group is right. This is PCB. We, Monsanto, better get 17 one of these instruments right away and start looking 18 around to double check it." And that's what Monsanto did. 19 Q. And did Monsanto eventually get one of these 20 new tools that the Swedes had to detect these minute 21 particles in the environment? 22 A. Yes, they did. 23 Q. Did the Swedish chemists, Dr. Jensen and his 24 other chemist, did they ask for anything from Monsanto? 25 A. I can't be sure. I think they may have asked WATER PCB-SD0000033163 213 1 for as purified samples of various PCBs as we had. They 2 may have done that. I'm not sure. Some people did later 3 on and some didn't. I don't know if the Swedes did. If 4 they did, we sent it to them. 5 Q. Okay. What do you mean You've mentioned 6 that the PC it was learned by these Swedish chemists 7 that PCBs were persisting in the environment, were 8 non biodegradable. What does that mean in lay language? 9 A. Well, non Biodegradable means that if you 10 put something into the soil or drop it in the bottom of a 11 lake, after a while the bacteria in the soil, the fungi in 12 the soil or the bacteria or whatever it is down in the 13 bottom of the lake, in the goop at the bottom of the 14 lake That's spelled goop. 15 Q. Goop is not a scientific word; is it? 16 A. No, sir. 17 MR. MURRAY: As scientific as I ever get. 18 Q. But I understand what goop is. 19 A. At the bottom of the lake will break this 20 molecule down into its parts. I mean, into water, 21 chlorine, et cetera. And then you don't have that 22 material existing anymore as it was when it was dropped in 23 there. If it is non biodegradable, it stays there. 24 Q. And doesn't disappear? 25 A. Doesn't disappear. WATER PCB-SD0000033164 214 1 Q. And that's what was happening to PCBs? 2 Instead of biodegrading and disappearing over the years, 3 it was just staying there? 4 A. That's correct. 5 Q. And that's what the Swedish scientists or 6 chemists found? 7 A. Well, they found even a little more than 8 that, because they found it was picked up by the animal 9 organisms who lived in the very minute plankton,which is 10 like plankton, which is a very minute let's say 11 like algae scum on top of a lake. And shrimp would eat 12 these plankton, fish would eat these shrimp, eagles would 13 eat the fish, and it showed up in the eagles' feathers. 14 Q. Eagles and other birds that eat fish? 15 A. Peregrine falcons and other fish eating 16 birds. 17 Q. Were these reports from these Swedish 18 chemists, were they in English at first, or were they in 19 another language? 20 A. Swedish. 21 Q. And did it take some time to get or did you 22 try to get the nod or get the translations of these 23 reports? Could you describe that? 24 A. Well, we Yes. We wanted We got the 25 Swedish reports. Of course, I gave it to a Swedish. We WATER PCB-SD0000033165 215 1 had the newspapers reports in Sweden, and we gave them all 2 to either our Brussels office or London office and said, 3 "Here, translate these into something we can read, and 4 translate them into English, and get it over to us." 5 Q. You eventually got those articles translated? 6 A. Yes. It took a little time. 7 Q. Okay. I've just got a few more minutes on 8 this tape. Let me just ask a couple more questions and 9 then we'll adjourn for the day. Was Monsanto able to 10 obtain the original paper that had been written by Dr. 11 Jensen, the Swedish chemist? 12 A. Yes, they were. 13 Q. And eventually,after sending this team of 14 people from Monsanto, was Monsanto able to confirm that 15 PCBs, in fact, were persisting in the environment as the 16 Swedish chemists said they were? 17 A. Yes, we were. 18 Q. Did you After this time, did you get some 19 reports that PCBs were persisting in the environment in 20 the United States as well? 21 A. Yes. There's another man, a Dr. Riseborough, 22 I'm not exactly sure, Riseborough, out at one of 23 the California universities. I don't know if it was 24 Berkeley, UCLA or USC. But I thought it was a California 25 state university. Found Corroborated the work of the WATER PCB-SD0000033166 216 1 Swedes. I think he did it before we did. And he found it 2 in some birds out there on the coast of California. 3 Q. By "he found it," he foundsome PCB? 4 A. He found PCB in the tissue 5 Q. Feathers? 6 A. Feathers and tissues, I believe, of birds of 7 prey out in California. 8 Q. These are fish eating birds? 9 A. That's correct. 10 Q. Did PCBs after thisperiod oftime also show 11 up in minute quantities in the food chain, such as fish 12 and later in milk? 13 A. Yes, it did. 14 MR. CARNEY: I think we're running out of 15 tape, so I think we'll break for the day and start in 16 again tomorrow morning. 17 THE WITNESS: No argument with me about it. 18 MR. CARNEY: Okay. 19 (Deposition was recessed until 9:30 a.m. on October 20 25, 1990. 21 Q. Dr. Kelly, earlier we putasideExhibit 137, 22 and if you could just take a look at that quickly and 23 identify it for me. 24 A. This is a letter from me to a Mr. Murray, 25 Robert Murray, of General Electric Corporation, dated WATER PCB-SD0000033167 217 1 August 26th, 1964. He asked for information on 2 Therminols, and I sent it to him. 3 Q. Okay. Take a look at Exhibits 150, 151 and 4 152. Can you identify those three exhibits? 5 A. Yes. These three letters are from people at 6 Monsanto, two of them are from two are from Mr. Richard 7 of Monsanto, and the other is a letter back to Dr. Richard 8 from somebody in the government in the pesticide 9 department. The letters go to various agencies of the 10 government, one Department of Agriculture, the other the 11 Fish and Wildlife Service of the government, which 12 presumably they asked for samples of our various PCBs that 13 we sent up to them. 14 Q. Was this during the time that the government 15 and Monsanto were interested in the environmental problem 16 with PCBs? 17 A. Yes, it was. 18 Q. And Exhibits 150 or Exhibit 150 dated 19 February 15, 1968 and Exhibit 152, dated June 18, 1968, 20 were sent by Monsanto to the government? 21 A. That's correct. 22 Q. And Exhibit 151 was received byMonsanto from 23 the government? 24 A. Yes, it was. 25 Q. Shouldn't Monsanto have discovered this WATER PCB-SD0000033168 218 1 environmental problem before with PCBs earlier than it 2 did? 3 A. Well, no. It's almost like saying If 4 somebody discovered a cure for cancer at Sloan Koettering 5 should you say somebody else should have discovered it? I 6 mean, first, there were two reasons. One, we didn't have 7 the equipment that would go down that low. And, secondly, 8 we didn't Well, we had Like for the environment, 9 we've looked for agricultural chemicals, we've looked for 10 fluorides around our plants. We've carried out work on 11 environmental work, on environmental contamination, but 12 this is one we didn't suspect to be there. And if we had 13 suspected, we were not in the position at that time to 14 have the equipment to get such low levels. 15 Q. What steps did Monsanto take to control the 16 environmental problem of PCBs not biodegrading or 17 disappearing in the environment? 18 A. Well, we couldn't do much about the 19 biodegradability or nonbiodegradability. That's an 20 inherent factor of the chemical itself. Our steps were to 21 prevent any more from going in the environment. We looked 22 at our own plant obviously and our own outflow from the 23 plants. We told all our customers about it. We 24 cooperated with all the government scientists that were 25 trying to help the problem. We arranged for the material WATER PCB-SD0000033169 219 1 to be sent back to Monsanto, any used material or surplus 2 material or drums sent back to us, and we burned the 3 material so that they wouldn't have to put it in landfills 4 or throw it in the streams as they were doing before. 5 Q. Doctor, can you identify Exhibit 153 for me? 6 A. Yes. This is minutes of a meeting of the 7 Corporate Development Committee. That's one of the top 8 two committees of the company. 9 Q. Of Monsanto? 10 A. Of Monsanto. Sorry. It's made up of the top 11 brass in the company. It wasdatedNovember 17th, 1969. 12 They had the people interested in the PCB problem, the 13 environment. We briefed them on the problem, "we" being 14 the Medical Department, as well as the Marketing 15 Department and Research Department, and we gave them our 16 plan of action. We, this group, gave the top brass our 17 plan of action. 18 Q. Okay. And is that plan of action set out in 19 this exhibit? 20 A. Yes, it is. 21 Q. Okay. Did the Monsanto management approve of 22 the plan of action recommended by the research and medical 23 people at Monsanto? 24 A. Yes. They went along with everything we 25 said. They even went along further. I remember Ed Bock, WATER PCB-SD0000033170 220 1 who was the chairman, the number one person at the 2 company, said, "If we can't lick this problem, we're going 3 to stop manufacturing this. We'll get out of it." 4 Q. What was Could you just briefly 5 summarize Feel free to refresh your recollection with 6 Exhibit 153, but if you would briefly summarize Monsanto's 7 plan of action at this time in November 1969. 8 A. Yes. They said we'll take this group by 9 group, we'll go into a program of every use of the 10 material, and, we'll First of all, we'll put a project 11 manager on. The Medical Department was loaning Mr. 12 Wheeler to this project up to then, but we knew it was 13 just more than a part time person could do. So they 14 picked Bill Papageorge, who had been the manufacturing 15 the plant manager of the plant where they manufactured 16 PCBs at Anniston. So, first of all, they said we'll pick 17 a person, then we'll tell all the customers about the 18 problem, then we'll cut down our own effluence, the stuff 19 that comes out of our plants. Then they'd say we'll 20 educate the customers, we'll introduce the market 21 replacement products, if there are any, continue testing 22 various Aroclors to see if we could come up with a PCB 23 that would biodegrade, continue the toxicological testing. 24 Well, that's about it. Developing a plan to reclaim the 25 fluid and recover, keep it out of the environment. WATER PCB-SD0000033171 221 1 Q. Okay. Did Monsanto eventually stop 2 manufacturing PCBs altogether? 3 A. Well, that was the last stop. First of all, 4 they stopped using it in open operations such as 5 stopped selling it for use in carbonless carbon paper, 6 paints, lubricants, waxes, plasticizers. Then they 7 eventually That was the first step. And they stopped 8 using it in places where there were substitutes. We 9 stopped using it where it wasn't so critical that you had 10 to have a PCB. We stopped using it in hydraulic fluids 11 where there could easily be escape to the outside. We 12 stopped using it in heat transfer units where it could 13 leak and give you problems. 14 Q. At that time did you stop using it in 15 capacitors and transformers? 16 A. Haven't got up to that yet. No. 17 Q. Why not? 18 A. There was no substitute, and the use of it 19 was critical to the electrical industry. We'd have shut 20 down the country. They had to use this in the subways, as 21 I said. They used it in hospitals, schools. And there 22 just was no substitute for the material. Once a 23 substitute was found, we stopped it. We stopped 24 manufacturing even for electrical uses. In fact, the 25 government told us before we stopped in the early '70's, WATER PCB-SD0000033172 222 1 "You've got to keep on manufacturing this stuff." So 2 Q. Why? 3 A. Because it was critical. There was no 4 substitute. It was critical because it was used in 5 trains, subways, hospitals, schools, where a fire would be 6 a catastrophe. So what they did, when someone came out 7 with a substitute, that was not Monsanto. Everybody was 8 working on it, of course. We were working on it, all our 9 competitors were working on it, on a substitute for PCBs 10 in this critical area. And when they came out, when a 11 substitute was found, we stopped. We stopped, oh, 1977, I 12 think, or middle '70's, '75, '77. It was two years before 13 the government stopped it. We had to voluntarily cease 14 manufacturing. 15 Q. So Monsanto in 1977 voluntarily ceased 16 manufacturing PCBs altogether? 17 A. Yes, we did. 18 Q. Dr. Kelly, are youfamiliar with an 19 organization called the EnvironmentalDefense Fund? 20 A. Yes, I am. 21 Q. Can you tell me what that is? 22 A. Well, that's an activist group that's sort of 23 similar to a Nader group. It's a self appointed group 24 whose purpose is to keep the environment clean. I would 25 say it's a group that's pretty critical of industry. They WATER PCB-SD0000033173 223 1 certainly are not on industry's side. 2 Q. Are they in the practice of complimenting 3 industry or a chemical company like Monsanto? 4 MR. MURRAY: Object to the form of the 5 question. No foundation's been laid. 6 A. Not as a rule. I've never I've never 7 thought that about them. 8 Q. Okay. Can you identify for me Exhibit 154? 9 A. Yes. That's a letter from the Environmental 10 Defense Fund, the group we've been talking about, August 11 24, 1970, sent by their executive director to our New York 12 office. 13 Q. To Monsanto? 14 A. To Monsanto's New York office. 15 Q. Okay. Let me I've got a blow up of that 16 particular document, and, if you would, read the second 17 paragraph of that letter. 18 A. Yes. It says, "At EDF" that's the 19 Environmental Defense Fund "we have been most impressed 20 by Monsanto's willingness to be responsible where the 21 environment is concerned. We very closely watched the 22 development of information concerning the environmental 23 aspect (sic.) of Monsanto's 24 Q. Impact, I think. 25 A. Impact. ". . .impact of Monsanto's product, WATER PCB-SD0000033174 224 1 PCB. What impressed us most was Monsanto's attitude and 2 finally its action to lessen the environmental degradation 3 caused by its product. We continue to watch your PCB 4 cleanup program to be sure that your action is as good as 5 your word, but, in the meantime, we are impressed by your 6 sensitivity and responsibility. Indeed, in many informal 7 conversations, we have signalled out your company as being 8 one capable of acting in its own long term interest and 9 that of society rather than its short term economic 10 interest. We have great respect for you. Roderick 11 Cameron, Executive Director." 12 MR. CARNEY: Thank you, Dr. Kelly. I have no 13 further questions. 14 CROSS EXAMINATION 15 QUESTIONS BY MR. MURRAY: 16 Q. Good morning, Dr. Kelly. 17 A. Yes, sir, Mr. Murray. 18 Q. Again, for the record, my name is Joe Murray, 19 and I represent the plaintiffs in this case. Dr. Kelly, 20 when Monsanto took over the manufacture of PCBs, did they 21 obtain from Swann Chemical Company any tests that were run 22 by Swann on these chemicals concerning the toxicity of the 23 chemicals ? 24 A. I was not there when Monsanto took over 25 Swann. I do know that when I came with Monsanto in 1936 WATER PCB-SD0000033175 225 1 shortly afterwards I saw the Flinn report in the files of 2 Monsanto. I don't know when they obtained them. I don't 3 know whether there was other material that Flinn might 4 have given them. I saw the Jones article, which was the 5 article that was published by Dr. Jones of Atlanta who 6 took care of the Swann employees with their chloracne. 7 Q. Presumably, Dr. Kelly, if Swann had done 8 further testing other than the Flinn tests on these 9 chemicals, they would have provided that information to 10 Monsanto; is that correct? 11 A. Well, I can't say. 12 Q. Well, isn't that the normalcourse of things 13 when someone takes over the manufacture of a chemical, to 14 obtain all of the information that they can possibly get 15 on that chemical from whoever has that information? 16 A. Yes. 17 Q. Okay. When Monsanto tookover the 18 manufacture of these chemicals, what tests, if any, were 19 run on the chemicals to determine the toxicity of them at 20 the time that or prior to Monsanto beginning the 21 manufacture of it? 22 A. I know of no tests that Monsanto ran from the 23 toxicological point of view from the time they took over 24 Swann until I came with the company, and I do not know the 25 first time we ran some tests. After all, you must WATER PCB-SD0000033176 226 1 remember, Mr. Murray, that Swann had a two year period of 2 no problems at all. They had the one episode that was 3 proven to be due to contaminated benzene, and then they 4 had two years of freedom from any problem when Monsanto 5 bought the company. 6 Q. The first tests that were run by Monsanto 7 would have been roughly in the 1950's; correct, sir? 8 A. Oh, no. Because we had tests We 9 contributed to Drinker's tests in 1937 and '38. 10 Q. What do you mean you contributed to it? What 11 do you mean? 12 A. Beg your pardon? 13 Q. What do you mean you contributed to it? 14 A. We paid part of the bill. 15 Q. So the Drinker test was run in '37 and '38? 16 A. Yes, sir. 17 Q. And then the next test was in the '50's? 18 A. We may have had short term testing in the 19 '40's at Younger's. I'm not sure. 20 Q. Whatever was done, though, we have here with 21 us today; correct? 22 A. I suppose so, yes, sir. 23 Q. Now, the Drinker study was an acute toxicity 24 study; correct? 25 A. Oh, no. He ran In those days, he ran this WATER PCB-SD0000033177 227 1 for weeks. It wasn't acute. He had inhalation for quite 2 a bit a period of time. It wasn't 3 Q. Periods of weeks, though, as opposed to 4 years ? 5 A. Well, yes. But in those days, in the '30's, 6 that was considered sort of long term testing. 7 Q. Well, let me ask you a couple of preliminary 8 questions then, Doctor. What you're telling us and the 9 jury today is that there were no long term chronic 10 toxicity studies in the early '30's and '40's? 11 A. If by long term you mean two years, that's 12 correct. 13 Q. So the best chronic studies that could be 14 done during that period of time would then be periods of 15 weeks ? 16 A. Oh, no. They could have done it if that 17 would have been the usual thing, but they were not doing 18 chronic studies at that time on industrial chemicals. 19 Q. That's what I'm trying to understand. There 20 were chronic studies out there that could have been done? 21 A. Oh, yes, you can always 22 Q. But that was not the usual? 23 A. If you're feeding an animal for two weeks, 24 you can feed him for two years. 25 Q. Now, let's talk a little bit about the WATER PCB-SD0000033178 228 1 difference between acute and chronic. I know you gave a 2 definition in your direct examination about what acute 3 effects or acute toxicity is. Chronic as opposed to acute 4 is simply a longer term? 5 A. Longer term at a smaller dose. 6 Q. And a low level chronic effect of a chemical 7 could very well be different than a high level acute 8 effect; correct? 9 A. Oh, yes. 10 Q. And, in fact, that's normally the case; 11 correct? 12 A. Yes. I would think so. 13 Q. So basically a chemical when it's exposed to 14 a human being or when a human being is exposed to a 15 chemical can get several different effects from that 16 chemical depending upon his exposure and the length of 17 time that he's exposed? 18 A. Yes, sir. 19 Q. Would it be fair to say, Doctor, that the 20 first low level long term chronic toxicity tests run on 21 PCBs were in the late '60's and early '70's when I.B.T. 22 did their two year studies? 23 A. Well, yes and no. It would be fair to say 24 that in 1954 when Treon did repeated inhalation studies he 25 went 127 days or something like that. That was a pretty WATER PCB-SD0000033179 229 1 long term testing by inhalation. And I don't believe that 2 even today they are doing any longer inhalation tests than 3 a period of four months. They don't do two year testing 4 on inhalation. The standard test for a food additive, 5 that's something you add intentionally to food, in the 6 '70's was and '60's, late '60's, was two year feeding 7 in rats, two year feeding in dogs. But prior to that, 8 there are extremely few two year testing of any products. 9 Q. What was Dr. Treon trying to find out when he 10 did his studies? 11 A. What would happen to you if you breathed a 12 small amount of this material for a prolonged period of 13 time. 14 Q. Wasn't part of his Part of the reason for 15 his study was to determine the toxicity of acute 16 toxicity of this chemical when it's breathed in? 17 A. Well, first of all, whenever you do a 18 prolonged study, you have to find out what the acute dose 19 is, because then you've got to cut that dose down so that 20 you can give it repeatedly, or you won't have the animals 21 living at the end of halfway through the experiment. 22 So he does the acute test first, and then he cuts gives 23 a fraction of that every day to the dogs, to the animals, 24 and sees what happens. 25 Q. Essentially he was trying to determine what's WATER PCB-SD0000033180 230 1 a safe level in the air? 2 A. Yes. 3 Q. What epidemiological studies were undertaken 4 by Monsanto in connection with PCBs? 5 A. None while I was with Monsanto. 6 Q. And that was from 1936 until 1974; correct? 7 A. That's correct. 8 Q. The various skin tests that were done by I 9 believe you said Dr. Flinn for Swann? 10 A. Yes, sir. 11 Q. Those were simply to detect the skin reaction 12 to the chemical. It was not designed to detect systemic 13 reaction; is that right? 14 A. That's correct. In those Back then people 15 did not know how chloracne occurred. In the '30's they 16 thought this is due to the action of a chemical on the 17 skin. Later, of course, people found out or people came 18 to realize that chloracne is a manifestation of absorption 19 of the chemical rather than it just getting on the skin 20 itself and clogging up the sweat glands or whatever they 21 thought back in the '30's. 22 Q. When was it determined that Or, I guess, 23 when was it established that chloracne was the result of a 24 systemic reaction as opposed to a local reaction? 25 A. Well, when you say it was established, when WATER PCB-SD0000033181 231 1 most of the people started believing it? 2 Q. Yes. 3 A. I would sayin the '50's. 4 Q. The tests that were run by Monsanto in the 5 '50's by the Younger Laboratories, those were designed, am 6 I not correct, to determine the LD 50 of the chemical? 7 A. That's right. The LD 50, which is the gross 8 toxicity by mouth. Was also to determine whether what 9 the potential for eye injury was, what the potential for 10 skin injury was, whether the material could be absorbed 11 through the skin. 12 Q. All of that is acute toxicity; correct? 13 A. That's correct, yes, sir. 14 Q. And testing for acute toxicity, what can you 15 determine about the chronic effect of the chemical, if 16 anything? 17 A. You can't. 18 Q. The tests that were run, these acute toxicity 19 tests on these chemicals, showed effects on various types 20 of organs; did they not, Doctor? 21 A. No, they don't. In an acute toxicity test, 22 the animal usually dies before a great number of organs 23 are affected. I mean, there are some symptoms you get. 24 Of course, if you give a large dose of an industrial 25 chemical by mouth, you will get obviously vomiting, WATER PCB-SD0000033182 232 1 diarrhea. It will have effects on the intestines because 2 of the volume of stuff and the local irritation. You may 3 get liver failure. So that's usually what occurs in acute 4 poisoning, unless it has a specific action like cyanide, 5 which acts on the oxidation products processes of a 6 body. 7 Q. All of these tests that were run by Monsanto 8 in the '50's and '60's did not show any effects on any 9 other organs other than the liver and the skin? 10 A. They didn't show on the skin. Liver and the 11 intestinal tract. Did you say skin? 12 Q. Yes, skin. 13 A. No. Well, they showed Obviously the 14 animal died, so you had pulmonary edema when an animal 15 dies. His heart eventually stops. Before it stops, the 16 lungs clog up with fluids. So those are the terminal 17 things when you die from anything outside of an accident. 18 Q. Well, the point is, though, is that other 19 effects on other systems in the body other than the liver 20 were shown? 21 A. There were some effects shown. The liver was 22 enlarged. Whether that We did that through microscopic 23 testing on the acute studies at Younger. We really 24 weren't looking for effects, where the effects were. We 25 were looking to see what was the relationship of the acute WATER PCB-SD0000033183 233 1 toxicity of this particular product versus other 2 industrial chemicals. 3 Q. All right. The I.B.T. studies that were 4 done, they were designed to show what would happen if 5 someone was exposed to this chemical in low levels for a 6 long period of time; correct? 7 A. That's correct. 8 Q. All right. Now, would I be correct in 9 saying, Doctor, that when dealing with animals, as these 10 studies were doing, you're not able to determine the 11 symptoms that one might be suffering while taking this 12 chemical over a long period of time? And by symptoms, I'm 13 talking about pain 14 A. Pain, no. 15 Q. Things like that. 16 A. Well, you could have signs in animals. I 17 mean, the animals If it were bothering their joints, 18 you couldn't say whether the joints hurt or not, but you'd 19 be able to tell if the animals were limping that it would 20 be bothering their joints. The animal couldn't tell you 21 that they are sick to their stomach, but if they didn't 22 eat and didn't gain weight, you would be pretty sure that 23 they probably had some intestinal problems. 24 Q. So you could tellsometimesindirectly what 25 the animal might be suffering from during the course of WATER PCB-SD0000033184 234 1 the study by watching the animal and observing it? 2 A. Yes. There are two things that happen. One 3 is symptoms, which are If you have a headache, that's a 4 symptom. If you say your skin itches, that's a symptom. 5 If you say, "My shoulder hurts," that's a symptom. A sign 6 is something that is objective that you can look at and 7 see. You've got a swollen joint, that's a sign. The pain 8 in that joint is a symptom. Animals, obviously the only 9 way you can tell they are in pain is if you move the joint 10 and the animal would start making a fuss. You would be 11 pretty sure he had pain. But he can't tell you this 12 hurts. 13 Q. So in order to determine the effects that 14 this chemical might be having on the animal during the 15 course of the study, one needs to observe the animals 16 closely? 17 A. Oh, yes. Yes. That's done. I mean, you 18 look at the animals every day. 19 Q. Now, during the time that I.B.T. was running 20 its chronicity tests Is that a correct word? 21 A. Chronic tests. 22 Q. Chronic toxicity tests. You mentioned I 23 think Dr. Kimbrough was also undertaking a two year study 24 on rats. 25 A. Yes, she was. WATER PCB-SD0000033185 235 1 Q. And there were two different conclusions 2 reached on these tests; correct? 3 A. That's correct. 4 Q. Dr. Kimbrough found that PCBs actually caused 5 tumors in rats and the I.B.T. study did not? 6 A. Well, not exactly. Remember, we ran three 7 different PCBs; she ran one. We ran two sexes; she ran 8 one sex. 9 Q. Did any of the I.B.T. studies show that PCBs 10 could cause cancer in rats? 11 A. In 1060, there might have been one or two, 12 but there was not the predominance of cancers that she 13 found in her 1260. 14 Q. And you mentioned, Doctor, did you not, in 15 your direct examination that Monsanto took Dr. Kimbrough's 16 slides and showed them to another doctor to get his 17 opinion on whether or not this was actually cancer they 18 were looking at. 19 A. Two others, two groups. Eppley Institute, a 20 cancer institute of the University of Nebraska Medical 21 School, and the Pathology Department of Northwestern 22 University Medical School. 23 Q. Was there not, Doctor, another group that 24 looked at those slides? 25 A. Beg your pardon? WATER PCB-SD0000033186 236 1 Q. Was there not another group that also looked 2 at those slides? 3 A. Well, we gave the slides Well, her 4 pathologist looked at them, but we had two We had two 5 groups that we sent her slides to, "her" being 6 Kimbrough's. 7 Q. Was there also not, Doctor, a group composed 8 of people from Monsanto and people from I.B.T. who 9 traveled to Dr. Kimbrough's laboratory and looked at those 10 slides? 11 A. I don't know. Not while I was there they 12 didn't. 13 Q. You're not aware of a Dr. Richter and Dr. 14 Calandra 15 A. Well, they were I.B.T. 16 Q. going with Dr. some people from 17 Monsanto and looking at those slides and determining that 18 Dr. Kimbrough's results were correct? 19 A. No, I am not aware of that. 20 Q. Okay. 21 A. We did not haveany pathologists, who are the 22 people who look at slides. 23 Q. Doctor, you mentioned, I believe, ondirect 24 examination that part of your job duties at Monsanto was 25 to obtain toxicological data on various chemicals that WATER PCB-SD0000033187 237 1 Monsanto was using and producing. 2 A. Yes, sir. 3 Q. In order to attempt to prevent injuries 4 resulting from those products? 5 A. Well, to prevent injuries to our workers, to 6 our customers and the ultimate user. 7 Q. Right. Part of the way you do that, Doctor, 8 is to review literature in the scientific community about 9 the product? 10 A. Yes, sir. 11 Q. Whenyou reviewliterature, part of what 12 you're looking for is that the literature is coming from a 13 well established journal that has, I think you mentioned, 14 peer review status? 15 A. Yes, sir. 16 Q. What does that mean? And please tell the 17 jury what it is. 18 A. What peer review is? 19 Q. Yes, sir. 20 A. It means that a scientific article that is 21 proposed to be published in that article in that 22 journal is sent out by the editor of this journal to 23 several people, who are presumably expert in that field. 24 If they are dealing with brain tumors, they send out the 25 article to people who are knowledgeable about brain WATER PCB-SD0000033188 238 1 tumors. And they come back to the editor and give their 2 points of view as whether this article has scientific 3 basis or not. 4 Q. And if it does, if it meets with peer 5 approval, then it will be published in the journal? 6 A. That's correct. If there's space for it. I 7 mean, there's a lot more. 8 Q. I understand that. And if it does not, if it 9 comes back and the peers say, "No, this is just a piece of 10 junk," then the journal will not publish it? 11 A. That's correct. 12 Q. So it has to be afairly ascientifically 13 designed study that is done by somebody with a good 14 reputation and comes up with scientifically established 15 results before it will be published in one of these types 16 of journals? 17 A. Yes. The people may not agree with the 18 results. 19 Q. Right. 20 A. I mean, but they say this study is 21 scientifically designed. But just because they say, "We 22 don't believe these results are correct" doesn't mean it 23 wouldn't be published. 24 Q. And it happens, does it not, Doctor, in a lot 25 of situations where these well established peer review WATER PCB-SD0000033189 239 1 articles reach different conclusions based upon based 2 upon the data that was obtained in the study? 3 A. And the interpretation of the data, yes, sir. 4 Q. And the interpretation of the data. 5 Depending upon how you interpret it, depending upon 6 various factors, one person looking at the same article 7 may reach different conclusions about it than another 8 person? 9 A. Yes. 10 Q. Now, would it not be fair to say, Doctor, 11 that with regard to PCBs there have been articles 12 published in the scientific literature, in peer review 13 journals, that reach different conclusions than what you 14 have talked about today and yesterday? 15 A. Yes. But I believe I stated that in 1260 I 16 have accepted the fact that PCB 1260 is acknowledged by me 17 to cause to be an animal carcinogen. Yes, it is. The 18 others have not been shown 1254 was not shown by the 19 National Cancer Institute, and there's been no information 20 on any of the lower chlorinated compounds as far as 21 causing tumors are concerned. 22 Q. Well, I mean, just I'm talking in general 23 terms as opposed to one specific result. 24 A. Yes, but I want to be sure you didn't 25 misinterpret my direct testimony. WATER PCB-SD0000033190 240 1 Q. I understand. I understand. That's not 2 unusual, is it, Doctor, in the scientific community to 3 have different people reach different conclusions with 4 regards to the same issue? 5 A. Not at all. Just like the earthquake scare 6 today. 7 Q. I'm sure. 8 A. Some people say it's going to occur December 9 3rd. An awful lot of people say this is nonsense. 10 Q. The PCBs that are manufactured by Monsanto, 11 they are manufactured in a closed system; correct, Doctor? 12 A. Yes, sir. 13 Q. Meaning that all the material isenclosed in 14 pipes or vats or something to where the workers don't come 15 in direct contact with it. 16 A. Well, in a perfect world, in a perfect 17 chemical plant, that would occur, but there are always 18 leaks, there are always spills, there are always pumps 19 that we have to replace the packing. So ideally that's 20 what we strive for. You strive to minimize exposure. But 21 in a chemical plant there are exposures. 22 Q. I understand that. And the only point I'm 23 making is that someone who is working with a closed system 24 would be expected to have less exposure to a chemical than 25 someone working in an open system? WATER PCB-SD0000033191 241 1 A. Yes. That's correct. 2 Q. The more direct contact you have with the 3 chemical, the more exposure you're going to have? 4 A. Well, yes, but it all 5 MR. CARNEY: Let me object to the question. 6 I think it contains some undefined terms as to what you 7 mean by "direct". Do you mean PCBs in the room, at room 8 temperature, or do you mean actually having skin contact 9 or 10 Q. Well, Doctor, in whatever way that a chemical 11 can be gotten into the system. If you have that kind of 12 exposure, the more of that kind of exposure you have 13 Now I've lost my train of thought. 14 A. The more exposure you have, the more there is 15 a possibility of you having an effect from this chemical. 16 Q. Correct. 17 A. Yes. But that's what I have said, I believe, 18 pretty much all the way through, that if you don't get the 19 material on your skin, you aren't going to get an 20 exposure, whether it's an open system or a closed system. 21 So we say, "Don't get it on your skin." If you don't 22 breathe the material at elevated temperatures and the 23 material has a negligible vapor pressure, in other words, 24 fumes don't come off, but it's sitting in a pan on the 25 floor, you may have exposure, but that exposure is WATER PCB-SD0000033192 242 1 negligible. If you heat it, you've got exposure. 2 Q. I understand that. And that's the point I'm 3 making. Let's talk about that for just a second, Doctor. 4 Let's talk about the three ways that PCBs can get into the 5 human body, one of which is ingestion. That is eating it; 6 correct? 7 A. Yes, sir. 8 Q. The other is by skin absorption. If you get 9 it on your skin and it stays on there, then it can be 10 absorbed into the body? 11 A. Yes, if it stays on long enough and isn't 12 washed off. 13 Q. And the third way is through inhalation, 14 breathing it in? 15 A. That's correct. 16 Q. And you have testified several times, I 17 think, during the course of your testimony that the PCBs 18 at room temperature don't give off as much vapor as those 19 that are heated; correct? 20 A. That's correct. 21 Q. They do give off some, though; don't they 22 Doctor? 23 A. Some negligible. It's insignificant. 24 Q. And, again, if you're there for you know, 25 smelling that kind of thing for over an eight hour day, WATER PCB-SD0000033193 243 1 then that's not going to be harmful to you? 2 A. That's correct. It's not going to be 3 harmful. 4 Q. If you are there breathing that stuff for an 5 eight hour day at room temperature for the course of 20 or 6 30 years, though, there aren't any tests that show what 7 the effects of that might be; are there? 8 A. Well, there are no tests, but there is the 9 historical evidence that people who have been working with 10 the PCBs for 20 or 30 years have not shown problems. 11 Q. At least as far as the studies that you've 12 seen are concerned? 13 A. Yes, sir. 14 Q. And Monsanto didn't run any epidemiological 15 studies themselves to determine what that long term effect 16 might be? 17 A. No, sir, but the people who did run them have 18 stated there hasn't been any ill effect. 19 Q. Do we have any epidemiological studies in the 20 materials that you've talked about? 21 A. You mean yesterday and today? 22 Q. Yes, sir. 23 A. No, sir. 24 Q. Let me just makesure, Doctor. It would have 25 been possible for Monsanto to run epidemiological studies WATER PCB-SD0000033194 244 1 over the course of the 40 years that they were 2 manufacturing this chemical; wouldn't it? 3 A. Oh, sure. It could have been possible, but 4 it wasn't warranted. There were no problems. 5 Q. You indicated that you monitored the Monsanto 6 workers and what effects they might have from their 7 exposure to this through reviewing compensation cases, 8 your cancer index, and I believe you said just by looking 9 at the examinations when they were done. 10 MR. CARNEY: I'm going to object to that. I 11 think it mischaracterizes his testimony. 12 MR. MURRAY: I'm sure if it does the doctor 13 can correct me. 14 MR. CARNEY: Talking with plant physicians 15 and other areas, but you can answer. 16 A. Well, I monitored the health of the 17 employees, all the employees, but not especially PCB 18 workers. I mean, whether they were working in chlorine, 19 phenol, insecticides. We monitored all the workers. 20 Q. That's one of the things I want to talk 21 about, Doctor. For instance, the cancer index that you 22 had, that was for every worker in Monsanto; correct? 23 A. Salaried and hourly, yes, sir. 24 Q. And how would you be able to determine 25 groupings or anything else by looking at the cancer rate WATER PCB-SD0000033195 245 1 for everybody who worked for Monsanto? 2 A. Because it would say Department A 9, Joe 3 Blow, Department A 9, Queeny plant in St. Louis. A 9 I 4 know is the phthalic anhydride department, 5 phthalic, anhydride. We'd know it. If I 6 look at the You know, there weren't thousands of these 7 people. If I look at this every three months and see six 8 people in Department A 9, that rings a bell. I don't need 9 to be an epidemiologist to think that's pretty many. But 10 there weren't any clustering or grouping of cancers like 11 that. 12 Q. None of those obvious things that you could 13 see with a naked eye reviewing these things every three 14 months? 15 A. That's right. 16 Q. Was that cancer index ever given to an 17 epidemiologist to look at and determine what conclusions 18 he would reach, if any? 19 A. No, it wasn't. But it wasn't necessary. You 20 don't need to be an epidemiologist to know that nothing 21 has occurred. 22 Q. Were any Would Monsanto follow up with 23 employees who used to work with them to look at what 24 happened to them after they left? 25 A. If they retired, they still had insurance. WATER PCB-SD0000033196 246 1 If they quit after two years, no, they did not. 2 Q. What kind of turnover rate would Monsanto 3 have Are you familiar with what turnover rate they 4 would have in their plant level employees? 5 A. No. But there were an awful lot of 6 25 year old 25 year watches given out to them. No, it 7 was Q. I'm sure there were. There were probably also an awful lot of people who come and work for a year 10 or two years and leave. 11 A. That's correct. 12 Q. You mentioned various uses that PCBs were put 13 to over the years. 14 A. Uses ? 15 Q. Uses . 16 A. Yes, sir. 17 Q. Were you ever aware of PCBs being used as a 18 mold release agent? 19 A. A which? 20 Q. A mold release agent. 21 A. I may have heard something about that. 22 Q. Could you tell the jury what a mold release 23 agent is? 24 A. Well, I presume it's in a casting where you 25 have a sand or a plastic type of casting in which you pour WATER PCB-SD0000033197 247 1 metal to form individual objects, whether it's a wheel or 2 an axle or something like that, whether or not PCBs were 3 incorporated in the mold in the release agent. You 4 generally spray a release agent onto the sand so it comes 5 out easier. 6 Q. What kind of temperatures would molten metal 7 be, or would that depend upon the metal? 8 A. Yes. But it's hot. If it's metal that's 9 molten, it's hot. 10 Q. It's going to be wellabove 700 degrees? 11 A. Fahrenheit? 12 Q. Yes. 13 A. It's going to be hot. Icannot tell you. I 14 would have to speculate on how hot it is. 15 Q. Let's talk a little bit about chloracne, 16 Doctor. You discussed that a lot on your direct 17 examination, and I just want to make sure I've got some 18 points clear. Chloracne, first of all, is an acute 19 reaction; correct? 20 A. Well, no, it isn't. I don't know what you 21 mean by an acute reaction. Does it occur just because of 22 one acute dose? It isn't acute from the sense that it 23 occurs you get an exposure to anything to a compound 24 that will cause chloracne, if you would get that exposure 25 today, you don't get the chloracne tomorrow. WATER PCB-SD0000033198 248 1 Q. Okay. 2 A. So it isn't acute from that standpoint. I 3 wouldn't call it acute. 4 Q. All right. Would it be the type of thing 5 that you would get from high level exposures over a 6 relatively short period of time as opposed to low levels 7 over the life of a worker? 8 A. It depends on the compound. There have been 9 compounds, not PCBs, that a two week exposure will give 10 chloracne. 11 Q. Usually after the exposure is over, the 12 chloracne goes away? 13 A. Yes. It may end up with scarring. It may 14 end up with cysts. But no new acne occurs. 15 Q. It may also end up with nothing? 16 A. If you had a mild case. 17 Q. Chloracne is usually on what areas of the 18 body? 19 A. Well, again, it depends on how severe it is. 20 It usually starts on the cheekbones. Then it can spread 21 to the face. It can occur on the back of the neck. It 22 can occur a good part of the body. The face is usually 23 the predominant part of the body that's affected. 24 Q. In a word, Doctor, it's blackheads and 25 pimples and whiteheads? WATER PCB-SD0000033199 249 1 A. That's correct. 2 Q. Some obviously can become worse and look like 3 boils, and others might not? 4 A. Yes. If they get infected like boils. And 5 there are usually black pigmentation. Whether that 6 pigmentation is due to blackheads or changes in skin, it's 7 hard to say. 8 Q. Now, you mentioned that you did not feel that 9 PCB could cause any problems in a human being unless there 10 was chloracne present? 11 A. I didn't say that in this deposition. 12 Q. You may not have. 13 A. Beg your pardon? 14 Q. You may not have, and I might be getting it 15 confused. But is that true? 16 A. I would say that chloracne is accepted as the 17 hallmark of PCB harmful effect. I think that's accepted. 18 With the exception of acute episodes. If you get an acute 19 episode of like the people that I mentioned in the heat 20 exchange operations where they developed jaundice, that 21 jaundice occurred without chloracne. 22 Q. Would it be fair to say, Doctor, that the 23 only rule you can follow in toxicology is that there are 24 no definite rules? There are only trends? 25 A. Would you repeat that question? I didn't WATER PCB-SD0000033200 250 1 hear all of it. Sometimes you may have to speak a little 2 louder. 3 (Reporter read back as follows: Would it be 4 fair to say, Doctor, that the only rule you can follow in 5 toxicology is that there are no definite rules? There are 6 only trends?) 7 A. Oh, no, I don't think so at all. No, that's 8 not true. I mean, what I have said talking about 9 chloracne And this refers an awful lot to toxicology. 10 If you get an acute episode, you may get problems before 11 chloracne has time to develop. If you inhale PCBs at 12 elevated temperatures for a period of one, two, three 13 days, you get enough of a dose of this, you will get 14 swelling of the liver and jaundice. You'll get problems 15 from it. You will not get chloracne because chloracne 16 takes longer to develop. So that's very definitely 17 established. Also then, if you get chloracne due to an 18 exposure over a prolonged I can't tell you how long 19 prolonged is but over an extended period of time, that 20 chloracne response is due to absorption of PCBs. You may 21 get no other problems at all from it at all. But I think 22 the rule in toxicology related to PCBs is no chloracne, no 23 PCB poisoning, with the exception of acute problems. 24 Q. Do you have any scientific article that you 25 can cite me to that comes up with that rule? WATER PCB-SD0000033201 251 1 A. Yes, I can get them for you. Yes, I can get 2 them. 3 Q. You can't tell me what they are now, but you 4 will get them for me and provide them to Mr. Carney? 5 A. Uh huh. Yes. I mean, they will be people's 6 opinions, just like my opinions. I mean, I don't believe 7 there's any series of articles that say these people had 8 problems and didn't have chloracne. I mean, there may be. 9 But I can give you the opinions of experts in the field 10 who are not connected with Monsanto or industries. 11 Q. That say if you don't have chloracne you're 12 not exposed to PCBs? 13 MR. CARNEY: That's not quite what 14 A. I didn't say that. I said you do not have 15 problems resulting from PCB exposure. 16 Q. If you don't have chloracne, you do not have 17 problems resulting from PCBs? 18 A. That's correct. With the exception of acute 19 problems like 20 Q. I'm sorry. 21 A. With the exception of acute problems like the 22 liver jaundice, like the jaundice from liver. 23 Q. In order to have any long term problems with 24 PCBs, you have to have chloracne? 25 A. That's correct. WATER PCB-SD0000033202 252 1 Q. You mentioned, Doctor, that I believe you 2 did mention this in your direct examination that people 3 react differently when they have the same exposure to 4 various chemicals or they could react differently? 5 A. Yes, sir. 6 Q. I and Mr. Carney could be sitting together 7 doing the same work with the same chemical. I could come 8 down with a symptom from that exposure and Mr. Carney 9 might not; correct? 10 A. That's conceivable. 11 Q. And, in fact, even in that first instance of 12 chloracne at the Swann Chemical Company, everybody working 13 there did not come down with chloracne; correct? 14 A. That's correct. Of course, they may have 15 different exposures, too. 16 Q. That's the next point. They Those who do 17 come down with a symptom might have different levels or 18 different degrees of that symptom? 19 A. That's correct. Differentdegrees of 20 exposure. You said different degrees of that symptom? 21 Q. Well, what I'm talking about right now, 22 though, is same exposure. 23 A. Oh, same exposure. 24 Q. Same exposure. We both come down with the 25 same symptom, but mine is severe and his is not. WATER PCB-SD0000033203 253 1 A. It's possible. 2 Q. I have to ask you this, Doctor. It's not 3 only possible, it's probable; isn't it? Human beings just 4 don't react the same to the same thing? 5 A. Well, yes, that's correct. But, I mean, it 6 doesn't mean that this happens invariably. I mean, 7 obviously, if people are exposed to any illness, somebody 8 eats a contaminated shellfish, some people may get sick 9 and some may not. There is a difference obviously in 10 susceptibility. 11 Q. And there's also a difference even though in 12 the ones that do get sick, some get very sick and some 13 don't ? 14 A. Yes. That could occur. 15 Q. So in general terms, generally speaking, 16 people don't react the same to the same to the same 17 exposure? 18 A. I don't think I can be as broad as that. 19 People in Generally, people can have varying degrees of 20 response to the same exposure, yes, sir. If that's what 21 you're saying, I'll agree with that. 22 Q. Yes. There are situations, aren't there, 23 Doctor, when even when you try and follow all of the safe 24 handling instructions on a chemical that some people are 25 just so sensitive to it that they are going to get a WATER PCB-SD0000033204 254 symptom from it anyway? A. Would you repeat that? I lost you a little in the middle of it. Q. There are occasions, Doctor, and obviously I'm talking that this is an exception to the general rule, but there are occasions when people are just so sensitive to a chemical, to a product, that they might get a symptom from it even when they follow all of the safe handling instructions, the normal safe handling instructions. A. You're talking MR. CARNEY: I'm going to object. I think the question is overbroad. MR. MURRAY: It's designed to be a broad question. MR. CARNEY: Well, my objection is that it's a little too broad. Q. Can you answer it, Doctor? A. You're talking about a symptom now. Q. Yes, sir. A. A symptom doesn't mean you've got any harm. In other words, if you sneeze, that's a symptom. That doesn't mean you've got trouble with your nose. If somebody is smoking in a room, somebody is going to cough That doesn't mean he's harmed. So there's a difference. You may cough; nobody else coughs. So you may get a WATER PCB-SD0000033205 255 1 symptom from the same amount of secondary tobacco smoke 2 that Mr. Carney does not get. 3 Q. Exactly. I'm more sensitive to it than he 4 is? 5 A. That's correct. But you were talking about 6 symptoms. That doesn't mean there's anything wrong with 7 you 8 Q. I understand. 9 A. just because you cough when somebody is 10 smoking. 11 Q. I understand that. Some people can get 12 symptoms easier than others? 13 A. That's right. A symptom doesn't hurt you. 14 Q. Except when it happens to you. 15 A. Well, if you sneeze, when the sneeze is gone, 16 you're all right. 17 Q. I understand that. But while I'm sneezing, I 18 might be uncomfortable. 19 A. Yes. That's correct. 20 MR. MURRAY: We've got three minutes left. 21 You want to take a break right now so we can change the 22 tape? 23 (Brief recess.) 24 Q. Doctor, I asked you earlier to pull out 25 certain exhibits that you have now in front of you; WATER PCB-SD0000033206 1 correct? 256 2 A. I'm sorry. I couldn't hear you. 3 Q. I asked you earlier to pull out certain 4 exhibits which you now have in front of you? 5 A. Yes, I have four of them. 6 Q. All right. First look at Exhibit K 146, if 7 you would, Doctor. That is a letter from Monsanto to a 8 Mr. Greschaw, an industrial hygienist at Ford Motor 9 Company; is that correct? 10 A. Yes, sir. I have it. 11 Q. And with that letter he attaches a 12 questionnaire which Mr. Greschaw had sent to him regarding 13 PCBs; correct? 14 A. Yes, sir. 15 Q. And he attempted to answer the questions 16 posed on that questionnaire? 17 A. Yes, sir. 18 Q. Who would have filled that out? Would that 19 have been Mr. Garrett? 20 A. Somebody in the Medical Department. I mean, 21 it might very well have been Mr. Garrett. But it might 22 have been Dr. Johnson, who was my associate. Might have 23 been Elmer Wheeler. But probably was Garrett. 24 Q. Would you normally have reviewed things like 25 that that go out to other companies? WATER PCB-SD0000033207 257 1 A. Beg your pardon? 2 Q. Would you normally have reviewed things like 3 that that the Medical Department fills out and sends to 4 other companies? 5 A. The first time I probably would have. 6 Q. All right. 7 A. I mean, these This is just one 8 questionnaire. We probably got this questionnaire from a 9 half a dozen companies similar to this, even on the same 10 product. 11 Q. So the first time somebody would have sent 12 you a similar questionnaire you would have looked at it to 13 make sure it's filled out correctly? 14 A. That's correct. 15 Q. And then from then on it would have been 16 filled out similarly no matter what? 17 A. Yes, sir. 18 Q. If you would look on the first page of that 19 questionnaire, Doctor. 20 A. Yes, sir. 21 Q. Number one asks for the toxicity of the 22 chemical through ingestion, through inhalation and through 23 absorption ; correct? 24 A. Yes, sir. 25 Q. Now, under absorption it says "None"? WATER PCB-SD0000033208 258 1 A. Yes, sir. 2 Q. Do you consider that to be an error? 3 A. If Pydraul is a PCB, that is a mistake, yes, 4 sir. 5 Q. There is, in fact, a toxicity associated with 6 that chemical through skin absorption? 7 A. Yes, sir. 8 Q. Look at Exhibit 142, again from Mr. Garrett 9 to a Mr. Fleming, who was with the T.V.A.; correct? 10 A. Yes, sir. 11 Q. Apparently Mr. Fleming had asked for a 12 breakdown of the composition of PCBs or at least of 13 Pydraul 625? 14 A. Yes, sir. 15 Q. And Mr. Garrett told him he couldn't because 16 it was developed jointly with a second company. 17 A. Yes, sir. 18 Q. What company was that? 19 A. I think it was an airline airplane company 20 like Douglas or something like that. 21 Q. Was there a 22 A. I think there was a patent situation there. 23 Q. A patent or trademark? 24 A. Yes, sir. I mean, I don't know about the 25 trademark, but the patent was there. So I don't believe WATER PCB-SD0000033209 1 Monsanto had sole control of the patent. 259 2 Q. Pydraul was a combination of PCBs along with 3 something else? 4 A. That's correct. 5 Q. Okay. If you look at Exhibit K 141A, that 6 was from a Mr. Palmer at American Mutual Liability 7 Insurance Company; correct? 8 A. Yes, sir. 9 Q. Do you know what company he was talking about 10 where the workers were having nausea and headaches? 11 A. No, sir, I do not. I do not remember. I 12 don't even know if he told me the company. 13 Q. When you get a letter from a company like 14 that and then answer it like this one, would you normally 15 keep the letter that was sent to you originally? 16 A. Yes, I would, unless I sent it back to 17 maintenance, but it certainly should have been kept, yes. 18 Q. Somebody should have it at Monsanto? 19 A. Yes, sir. 20 Q. You don't have any recollection, do you, 21 Doctor, with regard to any specifics that may have been 22 talked about by Mr. Palmer when he was talking about the 23 workers having nausea and headaches? 24 A. No, sir, I do not remember. That was 38 25 years ago. WATER PCB-SD0000033210 260 1 Q. Apparentlythey wereworking with this stuff 2 at temperatures of approximately 180 degrees Fahrenheit? 3 A. Yes, sir. 4 Q. Which would have been theheated type 5 situation which you had referred to at various times in 6 your testimony? 7 A. Yes, sir. 8 Q. Why would heating this chemical cause it to 9 have any more toxicity than if it's at room temperature? 10 A. It doesn't have any more toxicity. You get 11 more exposure. 12 Q. I see. So, again, you were talking about if 13 you breathe it at elevated temperatures, then there are 14 more fumes in the air, and you get more exposure that way, 15 so you're more likely to have a symptom resulting from it? 16 A. You're more likely Yes, if you exceed the 17 concentration. All depends how much gets out in the air, 18 how hot you heat it and whether you protect yourself 19 against it. 20 Q. You talked several times in your direct 21 examination about Dr. Kimbrough and her conclusions 22 regarding PCBs; correct? 23 A. Yes, sir. 24 Q. You stated that she was of the opinion that 25 PCBs don't cause any chronic health effects; is that WATER PCB-SD0000033211 1 correct? 261 2 A. No, she didn't say that. She was of the 3 opinion that there have been no reported cases of adverse 4 health effects in workers using PCB. 5 Q. That's what I wanted. 6 A. She didn't say it was impossible to occur. 7 Q. That's what I wanted to clarify. She's not 8 saying that PCBs can't cause any problems. They are 9 saying that there have been no studies showing that 10 workers exposed to this stuff have come down with any 11 chronic health effects? 12 A. No, she didn't No, that's wrong, too. She 13 said that there have been no cases of industrial injury 14 from workers using PCBs with the exception of chloracne, 15 an occasional acute effect in the last 38 years or 40 16 years that it's been used. She didn't say there were 17 studies. I don't know how she phrased it, but that was 18 the thrust of it. 19 Q. That's what I'm having a hard time 20 understanding. Let's go to Exhibit K 8, which is her 21 article in the "Health & Environment Digest". I believe 22 you may have even quoted from this last paragraph in her 23 article. 24 MR. CARNEY: What number? CO 25 MR. MURRAY: WATER PCB-SD0000033212 262 1 MR. CARNEY: Eight, okay. 2 A. Yes, sir. 3 Q. She says, "Thus, despite positive laboratory 4 animal data and except for chloracne, exposure to PCBs has 5 led to know convincing, clinically demonstrable, chronic 6 health effects in humans." 7 A. That's correct. 8 Q. All right. Now, there are two words in there 9 I'd like to talk to you about first. She said, first of 10 all, "convincing". 11 A. Yes, sir. 12 Q. Now, I would assume by that word being in 13 there that there are some articles out there which, in 14 fact, have talked about some chronic health effects in 15 humans, although in her mind it's not convincing evidence? 16 A. I don't know what she what her 17 interpretation of that word is, but to me it means that 18 she says that "No matter what has been said, I am 19 convinced that there has been no demonstrable chronic 20 health effects in workers with working with PCBs." I 21 don't know. I cannot interpret her wording, whether 22 But here is a person who has worked with PCBs for the past 23 50 20 years and has been certainly studying the problem 24 with PCBs, comes out with a statement. I think you'd have 25 to ask her exactly what she means by it. But the English WATER PCB-SD0000033213 263 1 to me means except for chloracne there have been no 2 convincing, clinically demonstrable, chronic health 3 effects. I take the English for what it says. 4 Q. I just want to make sure we're understanding 5 it in the same vein, and 6 A. Well, that's what I believe. 7 Q. When she says convincing and clinically 8 demonstrable, she has, in effect, said, "There are things 9 out there, but to me they are not convincing"? 10 A. Yes. But she says I don't know what she 11 is saying. There may be suppositions out there. There 12 may be people saying, "Well, maybe this could occur." But 13 she says pretty positively it's led to no convincing, 14 clinically demonstrable, chronic health effects in humans. 15 And other people have said the same thing. 16 Q. There are articles, there are published 17 literature, regarding PCBs which associate it with certain 18 symptoms. Is that not a fair statement? 19 MR. CARNEY: Are you talking about humans? 20 Q. In humans, yes, sir. 21 A. In humans? There are articles, but one has 22 to analyze each article directly, and if you show me the 23 article, I'll be happy to give you my interpretation of 24 it. 25 Q. I understand, Doctor, and all I'm saying WATER PCB-SD0000033214 264 1 all I'm trying to get from this and from you is that to 2 her those articles aren't convincing, the same way they 3 are not convincing to you? 4 A. That's right. 5 Q. Someone else in the medical community might 6 find them convincing? 7 MR. CARNEY: I'm going to object to that. 8 A. They might or might not. 9 MR. CARNEY: It might call for him to 10 speculate as to some unnamed medical person. 11 MR. MURRAY: I understand. 12 Q. Let's look at the N.I.O.S.H. study, which you 13 produced earlier, Exhibit No. K 8A. 14 A. Yes, sir. 15 Q. This was an epidemiological study; correct? 16 A. Beg your pardon? 17 Q. This was a epidemiological study; is that 18 correct? 19 A. Well, I suppose it could be termed that, yes, 20 sir, although there were no controls on it. 21 Q. Well, there, in fact, were; were there not? 22 A. What? 23 Q. They used controls They used two groups of 24 people. One was exposed at levels One had levels of 25 PCB in their blood of over 200 parts per billion? WATER PCB-SD0000033215 1 A. Yes. 265 2 Q. And the other group had levels of under 200 3 parts per billion? 4 A. Yes. But 5 Q. So what youare comparing in this study was 6 highly exposed people to a relatively lower exposed group 7 of people? 8 A. No, not exactly, becausethe presence of PCBs 9 in the blood can also be due to other reasons. It's 10 accepted now that the elevation of PCBs in the blood is 11 relative to the presence of triglycerides. In other 12 words, if an individual has fats in his blood, higher 13 levels of fats in his blood, triglyceride is one of them, 14 PCB is fat soluable. So you can have higher levels of PCB 15 in your blood that is not caused by higher exposure. Do I 16 make myself clear to you, Mr. Murray? 17 Q. I understand what you're saying, Doctor. I'm 18 not familiar with any of the articles that say that. Can 19 you cite me anything? 20 A. Oh, I think that's pretty well established. 21 Q. I know that there is an association between 22 PCB levels and triglycerides. 23 A. Yes. But the reason that has been shown that 24 it's due to the soluability of PCBs in the triglycerides 25 in the blood, that's why it's higher. That's why the WATER PCB-SD0000033216 1 level is higher. 266 2 Q. Can you get me that article also,Doctor? 3 A. Sure. 4 Q. In any event, what this study was doing was 5 comparing people who had levels of over 200 parts per 6 million in their blood with people who had levels of under 7 200 parts per million? 8 A. That's correct. 9 Q. Now, what is theaveragebackground level of 10 PCB in the average person's blood in the United States? 11 A. 20 parts per billion give or take a few 12 points. 13 Q. So if in this group of people that they were 14 comparing you had someone who had 195 parts per billion in 15 their blood, they would be in the lower group, but they 16 would still be way over normal with regard to the levels 17 of PCB in their blood; correct? 18 A. That 's correct. 19 Q. What is an odds ratio, Doctor? 20 A. Pardon? 21 Q. What is an odds ratio? 22 A. Odds ratio? 23 Q. Yes, sir. 24 A. I'm not familiar with the term. 25 Q. Look at table two in that study WATER PCB-SD0000033217 1 A. What page is that on? 267 2 Q. 1546. 3 A. Yes, sir. 4 Q. All right. This table talksabout odds 5 ratios and 95 percent confidence intervals for signs and 6 symptoms of disease by exposure group and study year; 7 correct? 8 A. Yes, sir. 9 Q. They actuallylooked atthese people at two 10 different times. They looked at them in 1977 and again in 11 1985; correct? 12 A. Yes, sir. 13 Q. 1977 was the date that Monsantostopped 14 manufacturing PCBs; correct? 15 A. Yes, sir. 16 Q. The same group ofpeople, two different 17 times ? 18 A. Well, I'm not sure they had I mean, the 19 same group, but there were difference in numbers. 20 Q. Same group. They might have not been able to 21 find some of the ones in 1985 that they had in 1977? 22 A. They may not have examined all the people in 23 '85 that they examined in '77. 24 Q. But whoever was part of this study in '85 was 25 also a part in '77? WATER PCB-SD0000033218 1 A. Yes. Yes. 268 2 Q. Now, it talks about odds ratios and 95 3 percent confidence intervals; does it not? 4 A. Yes. 5 Q. Do you knowwhat those terms mean? 6 A. I don't know what theodds ratio means. 7 Confidence levels means that this does not occur by chance 8 in 95 percent of the people. 9 Q. And 95 percent confident in talking about 10 these odds ratios? 11 A. That's correct. Well, I don't know what odds 12 ratio is. 13 Q. If I told that you that odds ratio meant that 14 it was talking about the percentage of likelihood of these 15 symptoms appearing in this group of people at these levels 16 as opposed to the normal population. Or in this case 17 opposed to the lower 18 A. I think you'd have to ask an epidemiologist 19 about that. 20 Q. All right. They actually asked each 21 individual in this study whether or not they had these 22 symptoms both in 1977 and in 1985; correct? 23 A. Yes, sir. 24 Q. And this exhibit even has a questionnaire 25 that was used? WATER PCB-SD0000033219 1 A. Yes, sir. 269 2 Q. One of the conclusions of this study, was it 3 not, Doctor, was that PCB levels in blood actually 4 decreased after the exposure has been removed or after the 5 people have been removed from exposure to the chemical? 6 A. Well, I'll have to go through it. Yes. They 7 had decreased, yes, sir. 8 Q. Between 1985 when they looked at the blood 9 levels again and 1977 when they first looked at the blood 10 levels, the blood levels had decreased? 11 A. Yes, sir. 12 Q. And would that be something you'd expect, 13 that after you're removed from the exposure that the blood 14 levels would decrease over the years? 15 A. Well, they ought to start decreasing as soon 16 as you were removed. 17 Q. Do you know what percentage the blood levels 18 decreased by over the eight years between the two times 19 when the levels were taken? 20 A. Well, yes. They say on page 21 that it went 21 down 90 percent in the high exposure group and 85 percent 22 in the low group. 23 Q. I'm sorry. On what page? 24 A. Beg your pardon? 25 Q. On what page was that? WATER PCB-SD0000033220 270 1 A. 1521. That's about the third page. 2 Q. So over that eight years 3 A. It's rightthere,right before. 4 Q. I see it. 5 A. It says 6 Q. After those eight years, the blood levels had 7 gone down tremendously? 8 A. Yes. 9 Q. But they were still there. I mean, you could 10 still see blood levels in these people? 11 A. Yes. But I'm not sure what their absolute 12 value was, whether they were down to what would be called 13 a background level. But, you know, you're picking pieces 14 out of this, because right after we're talking about blood 15 levels there's that statement, "No clinical abnormalities 16 attributable to exposure to PCBs were observed." I mean, 17 it's really unfair to me for you to pick out little items 18 of this unless we look at it in the entirety. 19 Q. Well, obviously this is an exhibit, so the 20 jury will be able to look at it entirely, but I'm asking 21 you certain questions about it the same way Mr. Carney 22 asked you certain questions about it. 23 A. Okay. 24 Q. Now, let's talk about that. It says, "No 25 clinical abnormalities were observed." What does that WATER PCB-SD0000033221 1 mean? 271 2 A. That means they couldn't find anything wrong 3 with them from the clinical point of view. 4 Q. Even thought the people might have been 5 saying they had certain symptoms. For instance, I come in 6 and say, "I have headaches." There is no clinical 7 abnormality that can be observed when I say I have 8 headaches; is there? 9 A. That's right. But, again, when I stated 10 right out in the beginning this did not have any control 11 group. They are talking Say, pick poor appetite. The 12 low group, or in '77, they had .3, whatever they mean by 13 the odds ratio, and .3 in '85. I don't know if they 14 examined 200 office workers, a good control group, what 15 their symptoms of poor appetite would be. So certainly 16 these people responded to that questionnaire, but the 17 people if they gave that same questionnaire to people 18 who had never even heard of PCB or been exposed to PCB, 19 what they would say I don't know. 20 Q. Exactly. That's part of the problem with 21 this is because actually what you're looking at is big 22 apples and little apples; huh? You know, you're comparing 23 people who are highly who have very high levels of PCBs 24 in their blood with people who might have moderately high 25 levels of PCB in their blood? WATER PCB-SD0000033222 272 1 A. And you are not comparing the symptoms of 2 these people with individuals who have what would be 3 Q. Normal? 4 A. normal levels. 5 Q. Exactly. 6 A. There is no true control group in this. 7 Q. Okay. In the laboratory tests that were run, 8 they did find that certain liver tests and certain kidney 9 tests were abnormal in the highly exposed or the high 10 level group; correct? 11 A. No. They found a There was no 12 difference 13 MR. CARNEY: Let me object. Are you talking 14 about the N.I.O.S.H.? 15 THE WITNESS: We're back on this. 16 MR. CARNEY: Okay. 17 A. The last sentence it said, "When the 18 prevalence of symptoms and overt clinical disease," overt 19 meaning it's something you can find, "were investigated by 20 exposure group, no difference between the groups could be 21 ascertained except for a positive association with GGTP." 22 That is a very sensitive liver enzyme. There has been no 23 evidence in here to show whether these people had had two 24 beers the night before, which would change GGTP. And a 25 negative association with urinary creatinine means WATER PCB-SD0000033223 273 1 nothing. Creatinine is a negative. If it were a high 2 creatinine, you'd worry. But low doesn't bother you. 3 That has no clinical significance. So I would say that 4 the laboratory work in this looks pretty clean. So 5 there's a little high GGTP. But that's an extremely 6 sensitive liver function test. They did a half a dozen 7 liver function tests, and the others were all negative. 8 Q. Well, you talk about 9 A. So I would discount the GGTP. 10 Q. You talked about, Doctor And let's be fair 11 about this. You talked about maybe the guy might have had 12 two beers the night before. 13 A. I can't hear you, sir. 14 Q. Let's be fair about this. You talked about 15 the guy might have had two beers the night before. 16 Obviously in this kind of a study they control for that 17 kind of thing; don't they? 18 A. Oh, no, they don't. No, they don't. They 19 haven't said anything about it. 20 Q. I understand that. But over the size of the 21 study and the number of people that are studied, that is 22 built into the system; is it not? 23 A. Not necessarily. I don't think so. That's 24 why I'm saying that we didn't have an adequate control 25 group in this. And I'm also saying that this is one of WATER PCB-SD0000033224 274 1 the five liver tests they ran. And the others were all 2 normal. So I don't believe that you pay I don't give a 3 great deal of credence to this GGTP elevation. 4 Q. What you're doing, Doctor, is to accept the 5 study for the negative results but not accept it for the 6 abnormal results? 7 A. No, I'm not. 8 Q. Is that not Wait! Is that not a fair 9 statement? 10 A. No, it is not a fair statement. 11 Q. All right. We'll let the jury decide that. 12 I'd like to talk to you about, if we could, Doctor, the 13 Yusho and Yucheng incidents. 14 A. Yes, sir. 15 Q. You talked about those on direct examination, 16 and you talked about the contaminated rice oil; correct? 17 A. Yes, sir. 18 Q. In the course of your reviewing the 19 literature on those two incidents, were you able to 20 determine the total amount of PCBs or the average total 21 amount of PCBs in the contaminated rice oil? 22 A. Probably was. I don't remember it offhand 23 now. I think it was written up someplace in there. I 24 haven't reviewed it lately. But I think the important 25 amount the important point is the amount of WATER PCB-SD0000033225 1 quaterphenyls and the 275 2 Q. Do you remember 3 A. and the furans. 4 Q. I'm sorry. Do you remember giving the 5 deposition in the case of Brown versus Monsanto where Mr. 6 McCrea and Mr. Carney were here? 7 A. Yes, I did. 8 Q. Let me refer you to page 28 of volume two of 9 that deposition if I could. The question was asked The 10 question was with regard to the levels of PCB in the rice 11 oil. You answered at that time, "To the best of my 12 knowledge, persons consumed 195 to 3,375 milliliters of 13 rice oil, which contained 920 parts per million of PCB." 14 Does that Does that refresh your recollection? 15 A. May I see what I 16 Q. Sure. 17 A. I can't get over there. Yes, sir. I'd 18 really have to look up the articles first. I mean, this 19 transcription is a little confusing. It says, "To the 20 best of my knowledge, persons consumed 95 to 300 comma," 21 then "3375 milliliters of rice oil, which contained 920 22 parts per million of PCB." I don't know what "95 to 300 23 comma 3300 milliliters of rice oil" Those figures are 24 confusing. I mean, I did some corrections on some of 25 these on this. We had troubles with the video. We had WATER PCB-SD0000033226 276 1 troubles with the stenographer. We had troubles with Mr. 2 McCrea, too. But I'm not sure whether I whether these 3 were corrected by me afterwards or not. 4 Q. I understand. I understand. And all I'm 5 asking is if that refreshes your recollection with the 6 amount of PCBs in the rice oil. If it doesn't, say that. 7 A. Well, I don't know because it's confusing to 8 me, Mr. Murray. 9 Q. Does 920 parts per million of PCBs contained 10 in that rice oil sound about right to you? If it doesn't, 11 it doesn't. 12 A. It sounds about right. I'm not positive. I 13 would have to double check it. But I do not know what the 14 sentence before It doesn't make sense to me, the 15 sentence before, "195 to 300 comma," then coming a bunch 16 of numbers on milliliters. 17 Q. I understand, Doctor, and I'm not trying to 18 trick you with this. 19 A. Okay. 20 Q. I'm just asking you if that sounds about 21 right. If it doesn't, that's fine. If it does, then 22 we'll go from there. 23 A. It could very well be true. 24 Q. You testified on direct examination in your 25 opinion the problem with that rice oil was not the PCBs WATER PCB-SD0000033227 277 1 but the furans and quaterphenyls that were contained in 2 the PCBs. 3 A. It was not only my opinion; it was also the 4 Japanese scientists' opinion. That was written up. 5 Q. I understand. I understand. How much Do 6 you remember what the percentage of furans and the 7 quaterphenyls were in the rice oil? 8 A. I don't remember offhand. 9 Q. If I tell you that in your deposition with 10 Mr. McCrea you said that it was between five and 18 parts 11 per million of furans, does that sound about right? 12 A. In the rice oil? 13 Q. Yes, sir. 14 A. It could be, yes, sir. 15 Q. So these people over the course of How 16 long was this, was this incident? Do you remember? 17 A. Months. Some months. 18 Q. Over the course of a few months, these people 19 consumed rice oil which contained between five and 18 20 parts per million of these furans? 21 A. Plus some quaterphenyls, which I don't 22 believe were quantified. 23 Q. Okay. What are quaterphenyls? 24 A. Beg your pardon? 25 Q. What are quaterphenyls? WATER PCB-SD0000033228 278 1 A. It's got four benzene rings on it rather than 2 two in PCBs. 3 Q. That doesn't tell me anything. 4 A. Well, it's a contaminant of PCBs if they are 5 heated in a certain way. 6 Q. And you mentioned that in the normal 7 manufacture of Monsanto's PCBs that they were not 8 contaminated with quaterphenyls; is that right? 9 A. I don't believe I phrased it that way. I 10 think I said I saw no analyses showing whether there was 11 quaterphenyls or not. 12 Q. Okay. That's what I wanted to clarify. 13 There actually was never They were never tested for 14 quaterphenyls to your knowledge? 15 A. To my knowledge, but they might very well 16 have been, because I wouldn't have been privy to all of 17 the analytical tests they did. I do not know I do not 18 remember seeing it. It could very well have been, but I 19 don't remember seeing such analyses. 20 Q. What about furans? 21 A. Yes. There were several analyses of furans. 22 Earlier some Swedish workers examined German French and 23 Italian PCBs and found furans. They did not find any in 24 the Monsanto PCBs. This was a man by the name of Voss, 25 and it was probably the early '70's. Later on, either WATER PCB-SD0000033229 279 1 right before I retired or right afterwards, Monsanto did 2 find some PCBs in their I mean, did find some 3 benzofurans in their PCBs. It was to the best of my 4 knowledge less than that was present in the Kanechlor, the 5 Japanese PCB. 6 Q. So although they were there in lower levels, 7 there were some in the Monsanto PCBs when they were tested 8 by Monsanto? 9 A. That's correct. 10 Q. In your opinion, Doctor, would those levels 11 that were found when they were tested by Monsanto be 12 representative levels of any one particular batch of 13 Monsanto PCBs? 14 A. Well, it was manufactured the same way, and 15 presumably I'd have to speculate. If I were to 16 speculate, I'd probably say, yes, it was representative. 17 Q. So in your opinion, on any 18 MR. CARNEY: Let me just record an objection. 19 I didn't know he was going to speculate. Object to the 20 speculation. 21 Q. In your opinion, Doctor, on any one 22 particular batch of PCBs over the course of the years that 23 they were manufactured, we could expect to find roughly 24 the same levels of furans in Monsanto PCBs? 25 MR. CARNEY: Objection to the form. I think WATER PCB-SD0000033230 1 it would call for speculation. 280 2 A. I don't think I can answer that. I mean, I 3 don't I believe you'd have to ask a manufacturing 4 individual. 5 Q. Do you have any reason to believe that they 6 would not be there? 7 A. I'll have to answer it the same way. I'm 8 not I'm not I have no evidence to show it one way or 9 the other. In other words, I believe you'll have to ask 10 either a research chemist or a manufacturing individual at 11 Monsanto as to what their thoughts were as far as the 12 changing levels of furans in their product was concerned. 13 Q. Okay. Furans are polychlorinated 14 dibenzofurans ? 15 A. By that I mean chlorinated dibenzofurans. 16 Q. They are extremely toxic; are they not? 17 A. They are quite toxic, yes. 18 Q. Can you estimate for me in teaspoons or pints 19 or quarts or any measurement you want to give me how much 20 furans were contained in that rice oil, that batch of rice 21 oil that was that these people in Yusho were consuming? 22 A. No, sir, I couldn't. 23 Q. It would be an awful small amount; would it 24 not? 25 A. It would be small. WATER PCB-SD0000033231 1 Q. Less than a teaspoon? 281 2 A. Less than a teaspoon. 3 Q. That amount of furans caused problems for 4 roughly 1,000 people; correct? 5 A. Beg your pardon? 6 Q. That amount of furans caused healthproblems 7 for roughly 1,000 people; correct? 8 MR. CARNEY: Again, we're talking about the 9 Japanese 10 MR. MURRAY: The Yusho incident. 11 MR. CARNEY: PCB. 12 A. The Yusho incident. That along in 13 conjunction with the quaterphenyls, yes, sir. 14 Q. What were some of the problems found in those 15 people? 16 A. There were problems with pigmentation, skin 17 troubles, chloracne. They had I'm trying to think. 18 There were some digestive disturbances. I'm not There 19 were quite a varied amount of symptoms. 20 Q. Can you tell us any more than that? 21 A. I'm sorry. I didn't hear you. 22 Q. Can you tell us any more than that? 23 A. There was some reproductive problems in the 24 sense that some of the children had the children, the 25 babies that were born, had problems with the eruption of WATER PCB-SD0000033232 282 1 their teeth. 2 Q. There were, in fact, birth defects associated 3 with this incident? There were deformed 4 A. It all depends. Birth defects means a lot. 5 It's different to every to other people. There were 6 not birth defects in the sense There were birth defects 7 in pigmentation of the babies and, as I said, poor 8 dentition, poor eruption of the teeth. Those were the 9 birth defects that were present. 10 Q. There were, in fact, babies born with teeth 11 already in their mouth; correct? 12 A. I believe so. 13 Q. And they were Some of these babies had 14 blackened teeth, they had blackened fingernails, blackened 15 pigmentation on their skin? 16 A. Yes. They had pigmentation, yes, sir. 17 Q. The adults had problems with nausea and had 18 problems with lethargy, they had problems with skin 19 eruption, blackened pigmentation, fingernails, teeth? 20 A. I don't know about the teeth in adults. I 21 know that they had problems with their fingernails, and I 22 do know that they had chloracne. 23 Q. And nausea? 24 A. They could very well have complained of 25 nausea. WATER PCB-SD0000033233 283 1 Q. Headaches? 2 A. There were a variety of symptoms. I 3 Q. Joint pain? I mean, do you remember inthese 4 articles those symptoms being talked about? 5 A. Yes. But I don't know how prominent the 6 symptoms were. Here we're talking 1,000 people. I don't 7 know exactly how many what percentage of people 8 complained of these various things. 9 Q. And, again, go back to the point we're making 10 before. Some of these people had these symptoms; some of 11 them didn't? 12 A. That's correct. 13 Q. Even though they all might have consumed this 14 rice oil? 15 A. Yes, that's correct. 16 Q. When PCBs are heated to certain levels, 17 chlorinated benzofurans could be created; could they not, 18 Doctor? 19 A. It all depends how they are heated. If they 20 are heated in a closed system, there may not, where 21 there's an absence of oxygen. You may not get 22 benzofurans, chlorinated benzofurans. 23 Q. If they are heated in an open system, you 24 can? 25 A. I did not hear you. WATER PCB-SD0000033234 284 1 Q. If they are heated in an open system, you 2 can? 3 A. You can, yes. 4 Q. If a fire happens, you can get dibenzofurans? 5 A. Yes, sir. 6 Q. If the PCBs are poured onto molten metal, you 7 might get dibenzofurans? 8 A. You might or might not because there's a 9 certain window at which the dibenzofurans are formed, and 10 when you exceed that temperature they are broken down 11 completely. 12 Q. And we ought to, just to be fair to the jury, 13 make that clear. At one level temperature, these PCBs 14 might start creating dibenzofurans, and at a higher level 15 then the dibenzofurans are destroyed; correct? 16 A. That's correct. And at a lower level they 17 are formed. 18 Q. Roughly that window is what? Between 200, 19 300 degrees ? And I'm not talking about I'm talking 20 about the window of opportunity, so to speak. 21 A. Yes, sir. 22 Q. It's about a 200 to 300 degree window there; 23 correct? 24 A. That's correct. 25 MR. CARNEY: We're talking Fahrenheit so I WATER PCB-SD0000033235 1 understand? 2 A. Well 285 3 Q. You tell me. I thought it was centigrade. 4 MR. CARNEY: Well, I just want 5 A. That's not the absolute level, but there is a 6 window of about 200 degrees that dibenzofurans can be 7 formed, and if you exceed this upper limit they are 8 destroyed. 9 Q. Is it fair to say, Doctor, that when you have 10 a batch of stuff that is set on fire or that is exposed to 11 heat, part of that batch is going to be exposed to one 12 temperature and part of it is going to be exposed to 13 another? 14 MR. CARNEY: Is the batch PCBs? 15 MR. MURRAY: Yes 16 A. Well, you've got two situations 17 you have the PCBs ignited, caught on fire. Are we talking 18 about that? Are we talking you have a flame under this 19 pot of PCBs and it's heated that way? I mean, there's a 20 difference between burning the PCBs and heating the PCBs. 21 What are we talking about? 22 Q. Well, I don't know, Doctor. And I guess what 23 I'm saying is almost in any situation where something is 24 exposed to heat, whether by fire or whether by hot or 25 whether by just sunlight, part of that material is going WATER PCB-SD0000033236 1 to get hotter than other parts? 286 2 A. Yes. But still you've got two situations. 3 If you're boiling water, a pot full of water, obviously 4 there's going to be The water away from the flame is 5 going to be a little hotter, but then it circulates. When 6 it starts boiling, it all hits the same temperature. 7 Q. Eventually, yes, sir. 8 A. But then if you've got a pile of kindling and 9 it's ignited, there are going to be different temperatures 10 at some time in different parts of that flame. When it 11 gets quite a roaring flame, it all hits pretty much the 12 same temperature. 13 Q. Are you familiar, Doctor, with an incident 14 where a PCB transformer exploded and the residue of that 15 fire was analyzed? Do you know what I'm talking about? 16 A. You want to give me the city? I mean, when 17 you say "exploded" 18 Q. I think it was in New York. I'm not sure. 19 A. Well, there have been fires where the 20 transformer fire started outside the transformer and 21 during the course of this fire the fluid in the 22 transformer came out, leaked and burned, yes. 23 Q. And actually it was the soot on the walls 24 that was analyzed; correct? 25 A. Yes, that's correct. WATER PCB-SD0000033237 287 1 Q. And both dibenzofurans and dioxin were found 2 in that residue; is that correct? 3 A. That's correct. But remember that this 4 particular transformer, dioxins do not come from PCBs. 5 Dioxins came from the trichlorobenzene in the transformer. 6 Q. Trichlorobenzene was one of the ingredients 7 of that transformer fluid that was manufactured by 8 Monsanto? 9 A. Yes. In transformers, but not capacitors. 10 Q. Dioxins are also a very toxic material; are 11 they not, Doctor? 12 A. Yes, they are. 13 Q. In fact, they are one of the most toxic 14 Including furans, they are some of the most toxic 15 materials in the world; are they not? 16 A. Well, they are certainly extremely toxic. I 17 won't be able to say they are among the most toxic in the 18 world, but they are extremely toxic. 19 Q. Are you aware of any chronic toxicity studies 20 that have been performed on chlorinated benzofurans? 21 A. No, sir, I'm not. 22 Q. What about on dioxins? 23 A. No, sir. 24 Q. So if somebody is exposed to those materials 25 at low levels over 20 years, so to speak, or even ten WATER PCB-SD0000033238 288 1 years, we're not sure what that might do to them; are we? 2 A. No, we are not. 3 MR. MURRAY: We can just go off the record 4 for a minute. 5 (An off the record discussion was had.) 6 MR. MURRAY: Dr. Kelly, I appreciate your 7 time this morning, sir. That's all the questions I have. 8 THE WITNESS: Thank you, sir. 9 MR. CARNEY: Dr. Kelly, thank you for coming 10 in. I have no further questions either. 11 THE WITNESS: Thank you. 12 MR. MURRAY: That's it. 13 14 R. Emmet Kelly, M.D. 15 Subscribed and sworn to before me this day 16 of , 1990. 17 My commission expires . 18 19 20 Notary Public 21 22 23 24 25 WATER PCB-SD0000033239 289 1 NOTARIAL CERTIFICATE 2 STATE OF MISSOURI ) 3) 4 CITY OF ST. LOUIS ) 5 I, FAITH A. OLLIGES, a Registered Professional 6 Reporter and a duly commissioned Notary Public within and 7 for the State of Missouri, do hereby certify that there 8 came before me at the offices of Communitronics 9 Corporation, 1907 South Kingshighway, St. Louis, Missouri, 10 R. EMMET KELLY, M.D., 11 who was by me first duly sworn to testify to the truth and 12 nothing but the truth of all knowledge touching and 13 concerning the matters in controversy in this cause; that 14 the witness was thereupon examined under oath and said 15 examination was reduced to writing by me; and that this 16 deposition is a true and correct record of the testimony 17 given by the witness. 18 I further certify that I am neither attorney nor 19 counsel for nor related nor employed by any of the parties 20 to the action in which this deposition is taken; further, 21 that I am not a relative or employee of any attorney or 22 counsel employed by the parties hereto or financially 23 interested in this action. 24 IN WITNESS WHEREOF, I have hereunto set my hand and 25 seal November 8, 1990. WATER PCB-SD0000033240 290 1 My commission expires March 21, 1993. 2 3 commission expires March 21, 1993. 2 3 commission expires March 21, 1993. 2 3 commission expires March 21, 1993. 2 3 4 NOTARY PUBLIC 5 6 I CERTIFY THE FOLLOWING TAXATION TO BE TRUE AND CORRECT: 7 8 Tax for Husch, Eppenberger, Donohue, Cornfeld & Jenkins 9 100 North Broadway 10 St. Louis, Missouri 63102 11 12 Org & 1 cc 13 Attendance $902.10 100.00 14 Jurat ______El.00R 15 TOTAL $1003.10 16 17 Murray Law Firm 18 650 Poydras Street, Suite 1450 19 New Orleans, Louisiana 70130 20 21 Carbon copy $320.10 22 Delivery E2.00R WATER PCB-SD0000033241 [& -1942] Transcript Word Index & 12 (cont.) 138 160 & 2:11 261:21 290:8,12 0 96:16 104:10,16 138:19 172:9 120 164:5 166:3 184:2 197:6,9,11 159:25 14 16th 21:20 96:8 100:4,4,7 101:3 203:19,21 101:9,11,13,21 200:21 17 02008 121 205:10,17 206:2 95:19 103:21,25 104:11,12 1:10 164:5 166:3 05 122 176:23___________________ 166:9,19 140 158:7,18 1400 104:21,25 199:7 17th 199:13219:11 1 1232 26:24 18 1 127:21 141 16:7 34:17 79:17 104:14,15 1:1 56:15 57:3,8 58:20 59:2 1242 199:6 204:11,17 205:20 104:15,15 176:21 217:19 59:10 107:21 126:14 134:7 144:3 146:14,19 141a 277:10,19 159:25 201:17 207:25 147:6 151:3,17 182:14 199:7,8 259:5 180 290:12 184:19 185:11 186:20,24 142 148:10 200:3 260:2 1,000 188:6 191:11 200:10 202:9 258:8 1890's 169:17,19 281:4,7 283:6 125 143 46:13 1/4/73 148:1 201:10 202:9 19 125:20 1254 145 104:14,16 114:18 164:14 10 144:3 146:5,13,18 147:6 203:15 204:18,20 205:22 166:16 30:21 79:3 91:9 94:1,14,18 152:10,12 156:24 157:3,4 1450 1907 108:11 197:21 172:9,14,20 182:14 186:21 2:7 290:18 1:21 289:9 10/1/44 186:24 189:12 191:11 146 1930 132:6 239:18 205:6 256:6 57:10 100 1260 14th 1930's 2:11 35:17 119:15 122:24 172:13,17,18 173:22 200:13 42:9 46:15 47:11 177:24 123:11 148:11 164:18 182:13 235:13 239:15,16 15 1931 290:9 1268 11:1376:1795:5,11,16 59:12 100.00 141:23 143:4 198:2 96:8,17 100:4,25 101:3,7,9 1932 290:13 127 101:11,22,24 102:13 4:21 1003.10 166:9,19 228:25 108:11 141:9 217:19 1933 290:15 128 150 5:9 27:17 47:16 1016 175:6 178:6 60:7 152:11,14 158:1,4,9 1934 127:5 129 158:14 183:9 217:3,18,18 138:13,21 1029 180:2 151 1935 63:24 12th 150:25 217:3,22 47:15 57:19 1030 189:8 152 1936 65:15,16 13 217:4,19 4:4 9:12,22 12:13 21:24 106 70:21 71:2 95:22 98:1,2,3,6 1521 27:15 28:1 58:21 62:11 85:17,19 86:1 98:9,12 104:18 270:1 112:24 113:12 224:25 1060 130 153 230:6 235:11 182:4 186:3,17,24 191:2 70:6,11,12 152:13219:5 1937 11 131 220:6 30:11 58:3 63:1 66:6 72:16 91:24 93:1 94:15 104:10 185:21 187:3,7 154 72:25 92:8,15 93:2,6 160:6 115 132 158:10 223:8 226:9 91:14 148:1 189:2 190:23 1546 1938 116 133 267:2 13:21 47:8 58:10 141:9 161:16,19 163:16 191:2,15 158 142:19 175:8,18,19 176:17 117 134 70:13,15 178:5 164:4 166:3 191:19 15th 1939 118 135 27:15 141:10 58:18 164:5 166:3 118:21 16 1941 11th 136 63:6,7 98:7 102:7,18 98:4 92:8 196:8 103:19 106:11 145:20 1942 12 137 157:19 204:21 4:6 58:22 59:4 76:17 77:5,5 95:4,11,16,18 216:21 WATER PCB-SD0000033242 [1945-44] 1945 1975 23rd 3300 13:21 101:8 107:16 275:23 1946 1977 24 3375 4:7 10:12 11:6 27:6 91:16 27:18222:11,15267:10,13 1:18 107:13 108:2,12 275:21 91:17 267:21 268:22 269:9 139:25 140:1 155:15 33a 1947 1978 223:11 108:21,24 109:11 17:15 203:19 245 34 195 1985 47:24 55:11 111:1,4,14,15,18,19,22 266:14 275:12 276:15 267:11,21 268:22 269:8 25 113:11 130:25 136:21,22 1950 1987 1:19 76:22 78:8 108:24 136:23 163:9 84:13 109:11,15 180:13 184:11 35 1950's 1988 216:20 246:6,6 111:1,6 113:2,11 226:7 87:23 250 36 1951 1990 148:14 63:1,12 111:2,7,14 112:4,4 161:25 1:19 89:13 90:2 216:20 25th 112:13 113:11 1952 288:16 289:25 180:5,9 36a 199:13 1993 26th 114:8,12 1954 290:1,3,3,3 217:1 36b 136:19 228:24 1st 27 114:9 115:12 1955 98:20 79:16,16,17 37 6:3,6 99:11 144:10 186:11 2 28 27:3 49:1 58:2 63:1,9,13 1956 O 191:25 275:8 92:20,23 116:13,16 117:9 6:6 98:20 180:5,9,13 1957 57:13 60:23 62:24 107:21 126:14 65:10,10 280 60:11 117:19,19 118:5 197:10,12 226:15 155:1 1962 196:16 1963 114:18 155:1 164:14,15 2,000 125:21 20 11:13 47:17 63:5 76:21,22 84:24 88:20 89:21 103:25 288 69:4 28th 175:8 191:21 297 38 10:1332:23 47:9 118:16 141:8,10 176:22 226:9,15 259:24 261:15 39 200:13,21 1964 6:4 115:14,18217:1 104:14,16,21,25 105:8 69:7 108:22 145:3 159:17 164:17 176:21 207:8 243:5 3 3 47:9 118:16 3rd 240:9 1965 163:10 243:10 262:23 266:11 287:25 7:1 57:24 66:11 67:7,9,17 68:17 69:1,2,8,11 72:8 73:4 4 4 1967 107:16 162:1 200 107:21 126:14271:12,13 58:5,6 66:11,23 26:23 148:14 158:25 184:2 3,375 40 1968 264:25 265:2 266:5,7 275:12 4:12 12:4 15:9 16:6 32:24 166:18 203:21,25 204:21 217:19,19 1969 271:14 284:18,22 285:6 200,000 41:25 42:2 30 60:4 188:24 243:6,10 300 82:25 118:16 152:2,3 244:1 261:15 40,000 187:10 189:8 190:25 191:7 197:21 205:10,17 206:2 219:11 220:7 1970 209 207:25 21 105:6,9,11,18,19 106:4,11 73:1,3 275:20,22 276:15 284:19,22 30's 47:7 63:4 65:6 177:25 134:7 40's 15:18 39:8 52:22 55:16 134:12226:19227:10 191:21,25 201:17223:11 107:5,11 124:2 269:20 227:5,10 230:15,21 41 1971 102:24 166:17,22 1972 29:20 30:22 75:22 77:24 290:1,3,3,3 210 158:19,23 214 30th 196:16 31 161:22,23 163:24 118:16 176:12,14 42 10:13 118:17 119:15 122:24 123:11 127:21 79:3 151:24 312 153:14 154:4 157:4 188:8 1973 125:24 22 105:6,8,9,22 106:4,13 118:21 203:22 206:4,14 320.10 43 119:5,19 121:25 122:3,5,13 1974 15:19 22:5 27:9,22 82:10 107:5,11 23 290:21 33 122:21,23 123:6 44 113:12 130:21 135:5 230:6 62:13 63:5 77:6 78:1 79:15 109:15 175:24 119:5,22 121:25 122:14,21 107:4 108:21 182:11 122:21 123:7 WATER PCB-SD0000033243 [4465 - accepted] 4465 6 700 9:30 143:10 6 247:10 216:19 45 70:24 78:17 70130 90 119:5,25 120:6 6,000 2:7 290:19 269:21 46 12:14 70's 902 27:3 106:14 119:6,19 60 127:6 171:16 221:25 1:10 47 146:9,10 222:12 228:21 229:6 902.10 123:22 600 278:25 290:12 47a 26:24 71 90's 120:19,20 121:9,13 60's 149:14 150:3,3,6,9 151:12 77:13 48 120:20 207:13 209:9 192:14 91 188:7 228:21 229:6,6 232:8 72 161:10 4th 62 30:16 77:21 154:20,23 920 98:4 102:24______________ 127:16,17 161:7 156:2 160:13 161:2 275:13,21 276:9 5 625 73 95 5 200:25 258:13 29:20 30:16 75:22 125:21 39:1 267:5 268:2,8,9 56:16 57:3 58:10,20 59:2 63 125:25 129:12,15,16 275:20,22 66:11 67:10 68:21,25 70:3 121:3 122:1 128:20 70:4,9,10 72:2,3,12 146:17 63102 74 17:20 18:15 27:3 a.m. a 187:10 50 12:4 16:7,8 123:21,25 2:12 290:10 63105 3:20 75 18:16 26:22,23 222:12 95:22 98:21 216:19 a.m.a. 8:5 124:20 125:17 159:12,25 159:25,4,6,8,14 160:1 64 76 116:16 117:9 121:3 124:14 18:16 95:22 able 5:20 17:6 41:13 53:20 231:6,7 262:23 500 35:18 124:15,19 125:7 126:2,5 127:13 130:25 65 77 222:12 267:23,25 271:12 78 124:19 138:24 148:9 208:17215:9,14 233:10,19 244:24 267:20 270:20 50's 68:24 69:24 70:19 125:23 157:5,5,7,8 274:19 287:17 18:12 39:8 52:21 226:17 132:1,3,3 134:10 8 abnormal 231:3,5 232:8 65.0 8 77:22 90:9 272:9 274:6 51 69:6 23:23 87:16,17 261:20,25 abnormalities 126:9 650 289:25 90:5,6 270:15,25 52 2:6 290:18 80 abnormality 126:9 66 8:15 12:15 77:25 90:8,9 271:7 53 127:17 136:15,16 138:12 800 abrasives 126:9 140:12 168:25 26:14 54 665 80's absence 126:25 127:7,22 136:20 3:19 77:12,13 83:7 131:6,9 193:17,18,19 151:3 153:14 154:3 182:14 67 82 283:21 188:6,8 107:17 141:2,3 142:1 154:21,23 156:2 160:13 absolute 5460 68 161:2 270:11 285:5 141:25 143:10 69:24 70:21 125:23 127:22 83 absolutely 55 143:19,21,23 145:5 148:23 151:22 56:24 133:2 143:7 114:3 126:25 127:11,12 149:10,12,15 150:4 192:13 84 absorbed 144:11,12 152:14 160:6 69 161:10 163:15 103:11 231:10242:10 176:22 107:18 143:19,21,24 145:5 85 absorption 55a 148:23 149:12,15 150:4 267:23,24 269:21 271:13 205:3 230:18 242:8 250:20 127:1,12 185:24 192:13 88 257:23,25 258:6 56 127:11,15,17,17 57 128:6,8,9 161:7 5th 191:7 7 84:7,9 70 7 88:16 8a 89:4 264:13 9 60:7,11,12,14 143:19,21,24 9 145:6 148:23 149:11,13,18 91:8,9 94:1,14,18 102:13 149:19 158:5,6,9,17,19 108:11 245:2,3,3,8 academicians 153:5 academy 8:4 accept 274:4,5 accepted 5:23 109:5 146:17 148:24 WATER PCB-SD0000033244 [accepted - analyzed] accepted (cont.) adapt advise alabama (cont.) 153:25 154:1 239:16 148:9 23:11 74:22 249:16,17 265:10 adapted advised alcohol access 109:5 182:15 21:10,10 41:11 add advisory alcoholic accident 17:25 70:18,19 123:16 9:15 79:13 232:17 229:5 affiliation algae accidental added 88:23 89:1 214:11 103:5,6 178:14 4:5 97:8 106:18 171:23 afternoon allay accidentally addendum 1:20 76:5 171:7,20 121:14 124:9 age alleged accompanied adding 3:11 6:11,11 16:1079:24 22:25 154:11 47:21 110:20 40:10,13 aged allis accounts addition 78:1,1 42:19 101:21 45:17 35:13 38:16 75:4 97:1 agencies allocation acid 122:16 217:9 134:5,7 26:21 78:3 additional agency allow acknowledge 121:15 123:8 88:3 183:2 153:5,6 201:8 101:10 102:2 additions agent allowed acknowledged 96:19 208:11 54:21 168:18 182:25 103:12,16 150:14 239:16 additive 246:18,20,23 247:3,4 amalgamation acknowledges 167:20,20,21,23 229:4 agents 16:1 101:13 adequate 10:25 43:17 44:13 162:18 altogether acne 273:24 ages 126:6 221:2 222:16 47:18,22 51:14,17 57:24 adequately 16:5 aluminum 93:11 248:14 150:16 ago 9:6 acneform adhesive 52:22 62:15 79:17 174:19 american 57:20 94:22 180:11 182:18 259:25 5:18 7:19,25 8:1,3,4,5,11 acquaintance adjourn agree 8:1223:6 146:15 151:7 179:11 215:9 33:12 56:18 85:12 138:4,9 152:22 167:10 189:15 acting administration 173:12 238:17 253:21 199:12 259:6 224:8 153:20,21 167:17 168:2 agreed americans action 175:22 3:1 138:7 148:16 204:25 219:16,17,18,22 administrative agricultural amount 220:7 224:2,4 230:16 232:4 115:2 9:18 41:24 84:20 218:9 5:21 12:1 20:23,24 21:8 289:20,23 administratively agriculture 25:6 68:7 82:15 83:8 active 40:25 165:16217:10 103:18 147:14 156:23 8:16 63:9 administrator ahead 158:1,15 159:15229:12 activist 114:14 179:11 180:6 189:6 86:18,19 167:14 255:1 274:20,21,25,25 222:22 191:1 air 276:6 280:23 281:3,6,19 acts adolescents 11:22 58:15,16,16 98:24 amounts 232:5 6:14 99:3,16 146:8 176:24 177:1 169:2 actual adopted 177:8,12 178:4 180:21 analogy 134:18 153:15 181:12230:1 260:14,17 71:18 acute adopts airline analyses 46:20 49:22 59:15 86:3 152:20 258:19 77:20,20 278:10,19,21 87:4,6,8,10 135:8 154:25 adult airplane analysis 155:4,5,18 156:14,15,16,20 6:12 43:14 258:19 77:8 89:13,19 156:21 159:4,8,7 162:8,17 adults airplanes analytical 164:17,18 196:22,24 6:14 282:17,20 43:15 11:21 17:10208:9,11 210:3 198:10 204:1 226:23 227:1 adverse al 211:4,11,15,20 278:17 228:1,2,3,3,7 229:15,18,22 33:5 261:3 1:6 analyze 231:12,14,18,21 232:3,23 advertising alabama 263:22 232:25 247:18,21,22,22 115:6 25:18 26:3,11 27:1 28:11 analyzed 248:2,3 249:18,18 250:10 advice 28:22 31:23 32:25 62:7,8 286:15,24 250:23 251:18,21 261:15 37:8 62:21 63:4 64:25 65:5 74:4 WATER PCB-SD0000033245 [anhydride - atlanta] anhydride apparatus arizona askarel 245:4 65:25 66:2 5:13 98:5 100:10,12,13,17,21,21 animal apparently arkansas 100:23 101:1 102:22 14:1 22:20 60:6,9,10 88:7 133:15 258:11 260:1 10:21 asked 88:11 123:15 135:14,23 appearance arm 36:9 73:20 109:6 156:15 136:5,11 140:5 159:19 63:20 64:1 89:8 165:24 183:7 192:24,25 176:22 192:5,20 200:24 appeared army 193:1 199:13 200:24 202:8 201:3 214:8 227:23 231:22 55:14 196:23 11:1 58:22 206:14212:25 217:1,12 232:14,14 233:20,25 234:1 appearing aroclor 255:24 256:3 258:11 234:10,14 239:17 262:4 268:15 43:25 44:6 92:13,24 93:8 268:20 270:22 275:9 animals appears 93:18,20 95:2 96:2 99:10 asking 20:20 60:14 66:14,15,16,25 92:10 93:1 94:7 110:10 111:4,8,23 114:16,22 127:5 35:16 49:10 54:3 67:8 85:10,11 93:7 135:19 136:8 176:23 181:17 188:3 127:19 132:7 144:3 151:2 186:1 189:9 205:24 270:20 145:12,14 146:1 151:5,17 appetite 153:13 164:9 183:5 184:19 276:5,20 152:5 159:14,16,17,19,24 271:11,15 185:11 186:20,23 187:5 asks 159:13 167:14 172:25 apples 188:6 191:11 192:13 198:2 180:18,19 203:22 205:14 229:20,23 233:9,16,17,19 71:6,7,17 271:22,22 199:15 200:4 257:21 234:8,15,18 application aroclors aspect anniston 35:10 133:25 188:16 44:5,5 91:13,20 92:5,12 17:9,1920:1024:5 31:1 25:18 26:3,11,15,22 27:1,1 applications 93:11,15,17,17 96:1698:15 97:9 201:25 223:23 27:13 28:11,14,22 29:22 42:12 91:13 94:21 98:16,18 114:17 115:21 aspects 30:5 31:22 32:25 62:6,8,20 applied 117:6 127:21 134:4 139:9 19:5 20:5 30:17 33:9 63:3,12,13 64:25 65:5 70:6 176:5 156:1,5,6 180:19 199:13 aspiration 74:3,12,14,21 115:16 appointed 220:22 144:5 137:13 220:16 209:3 222:23 arose aspirin annual appreciate 139:13 146:10,11 16:3 84:13 56:24 288:6 arranged assessed annually apprehensions 99:8 210:5 218:25 89:24 16:8 23:15 76:6 arsenals assistance answer approached 10:20 101:14 102:3 30:9,20 36:16 37:14 39:20 107:8 art assistant 39:25 47:14 56:9 112:22 approval 115:7 4:21 6:23,25 7:6 8:10 40:20 133:17 207:1 244:15 20:3 32:13 134:11 238:5 article associate 254:17 256:15 259:14 approve 57:17 58:6 59:11,13,14 8:21 256:22 263:17 280:2,7 32:5 92:15,22 96:15 104:19 60:1,23 62:24 65:9 67:18 associated answered 110:10 117:15 132:22 71:13,16,23 72:1,2 85:15 8:24 19:15 62:15 83:10 275:11 219:21 85:25 86:12 87:18,22 88:16 85:16 86:5,10 87:14 184:13 anybody approved 136:17 138:9,11,13 141:11 184:19 185:10 258:5 282:2 32:13 33:23 36:4 39:11 5:16,18 20:10 34:13 92:24 142:8 150:6,12,22 179:2 associates 73:15 95:1,2 97:24 105:1,1 93:2,5,6 96:19 97:24 115:7 182:23 183:1 193:22,23 161:24 162:3,6 163:22 107:6,8 108:8 132:19,20 134:12 154:6 225:4,5 237:20,21,25 238:2 192:16 159:6 175:16,21 196:4 approximately 239:6 250:24 261:21,23 association 207:6 63:2 76:19 81:9 260:2 263:22,23 266:2 5:19 7:20 8:1,3,4,6,7 9:16 anybody's april articles 9:19 22:23 23:7 90:18,19 21:11 77:20 115:18 191:21,25 203:19 7:13,17 14:6 21:22 22:20 153:18 189:15265:21 anymore 203:21 204:21 23:8 46:20 58:20,25 59:2 272:21,25 52:20 213:22 aquatic 61:9 66:10 131:23 150:13 assume anyplace 123:14 193:21 207:25 215:5 239:1 54:3 262:12 52:10 archives 239:11 251:7 262:13 assumed anytime 57:18 263:16,21 264:2 265:18 64:6 75:7 140:15 183:8 area 275:18 283:4 asterisk anyway 58:14 207:6 222:10 ascertained 117:21 49:7 55:18 78:24 84:9 areas 272:21 ate 156:11 254:1 47:19 244:15 248:17 aside 169:10,11 171:4,7,20 apa argument 197:13 216:21 atlanta 88:1 216:17 85:4 225:5 WATER PCB-SD0000033246 [atmosphere - bio] atmosphere awful basically (cont.) believing 155:17 198:23 13:21 16:21 21:2 38:24 228:13 231:1 atoxic 45:8 240:9 246:5,9 250:9 basis bell 49:22 280:23 18:23 74:5 91:17 131:5,6 245:8 attaches awhile 141:10 153:12 193:14 bellows 256:11 22:17 48:21 174:23 238:3 55:21 attempt axe batch belong 195:20 237:3 154:8 279:12,22 280:20 285:10 7:23 211:11 attempted axle 285:11,14 belonged 256:15 247:2____________________ bath 7:24 39:2 attend b 65:20 138:24 bench 66:6 attendance 290:13 babies 281:25 282:7,10,13 baby battery 77:1,4 125:2 155:5 baylor 14:17,17 benefit 44:17 attended 21:19 7:11 benefits 72:24 attending bachelor 4:19 beagles 174:6 44:15 benignus 72:15 attention back 9:10,22 19:7 41:25 62:11 bear 134:1 163:20 196:19 benzene 130:16 205:5 attitude 224:1 63:4 68:21 72:25 93:6 94:3 109:8 122:1 123:20 129:15 133:23 134:11 138:21 bearing 8:21 bears 46:25 48:6,6,7,8,9 57:9 64:9,11,14 65:1 68:3 138:5 226:3 278:1 attorney 289:18,21 143:21 152:14 175:18,19 186:2 212:1,2,15217:7 133:11 beers benzofurans 279:3 283:17,22,22 287:20 attributable 29:10 90:5 91:4 270:16 august 219:1,2 230:14,21 238:1,9 248:21 250:3 259:16 272:15 283:9 21:12 272:24 273:12,15 beg 63:22 161:14 226:12 berkeley 215:24 best 87:23 88:16 217:1 223:10 author background 4:16 211:23 266:9 270:13 235:25 249:13 257:1 264:16 269:24 277:24 53:11 54:22 105:5 130:19 136:2,25 170:16 172:6 57:7 132:5 authority 33:9 200:16,18201:16,18 bacteria 213:11,12 bad 281:5 beginning 29:7,8 175:20 192:14 194:14 201:23 208:4 227:13 275:11,20 279:3 better 202:23 207:5,15,20,2 authorized 45:14 64:18,19 65:1 79:18 103:8 137:22 138:5 143:9 225:20 271:10 behalf 122:22 125:12 137:1 153:17 163:11 212:16 5:8 automobile bag 59:14,15 145:14,14 156:11 1:1836:11 beings beyond 45:25 97:2 bake 140:4 253:3 bi available 14:6,9 46:15 59:3 83:15 150:17,20,20 193:23 194:5 96:4 baking 167:23 belgian 208:19,20,21 believe 143:11 big 36:5 42:18 45:6,6,8,9 47:2 207:25 average 266:9,10 274:20 avoid ball 171:1 ballpark 160:15 6:3 9:11 18:12 23:14 30:22 36:13 40:9 42:2 55:18 56:17 63:8,14 69:15 81:24 82:4 84:20 110:15 126:1 47:12 71:5 103:24 113:9 116:15 130:8 145:2 157:13 157:17 180:25 194:1 203:3 203:8,8 271:21 53:14,16 106:25 107:1 barnes 129:16 130:3 140:17 bigger 112:2,15,15 113:5,6 116:8 118:10,11 119:15 124:25 125:1 128:14,15 182:19 avoided 8:22,24 barrel 125:23 based 144:13 151:22 173:3 194:2 195:12 174:22 175:16 182:13 bill 187:22 188:7 194:25 200:3 38:19,20 143:8 167:25 207:25 212:11,15 216:6 220:14 226:14 103:11 121:16 178:12 54:7 83:1,2 149:7 207:23 229:1 230:9 236:23 238:22 billion 181:24 205:2 avoiding 207:24 239:1,1 basic 239:15 241:17 244:8 251:6 77:19 264:25 265:3 266:11 252:1 258:25 261:21 263:6 266:14 122:17 194:7 aware 59:16,16 97:22 106:19,21 106:23,24 164:2 274:2 277:22 278:9 280:3,5 bindschauler 280:9 282:12 189:5 80:12,15 171:2 236:13,19 246:17 287:19 basically 18:6 22:18 127:25 128:2 believed 76:7 209:23 210:24 bio 164:8,13 165:4,19,20 WATER PCB-SD0000033247 [bio - calculated] bio (cont.) blown break (cont.) bud 166:14,16,20 192:11,12,19 80:5 202:3 213:19 216:15 203:12 biodegradability blowup 255:21 build 218:19 111:13,21 112:5,7,11 breakdown 18:14 biodegradable blue 258:12 building 209:24 213:8,9,23 120:16 breaking 18:15,25 43:20 59:17 145:3 biodegradation blues 137:11 built 202:2,2 120:17 breaks 196:1 273:22 biodegrade bluff 202:3 bulletin 220:23 10:21 breathe 35:2,5,23 92:24 94:25 biodegrading board 72:22 130:14 145:18 204:6 102:21 103:2 105:23 214:2 218:16 5:15,16,25 6:2 8:11 241:22 260:13 107:15 108:6 187:5 biphenyl bock breathed bulletins 111:25 156:8 219:25 54:15 200:4 204:24 229:11 23:4 35:1,10,11,14 91:19 biphenyls bodily 229:16 91:21 92:16 93:20 94:17 84:16,17 123:2 190:4,9 93:10,14 breathing 95:7,15 96:21 97:10,19 bird body 21:20 53:17 107:1 112:15 102:14,15 104:2,8,21,23 123:14 18:8 232:6,19 242:5,10 113:6 118:10 122:17 125:1 105:4,12 106:4,15 107:3 birds 248:18,22,23 128:14 145:12 242:14 108:10,12 133:25,25 76:3 97:12 209:13 214:14 boil 243:4 188:15,16,16 193:6 195:15 214:16 216:2,6,8 198:16 brief 195:19207:17 birth boiling 40:8 75:3 143:22 170:5 bum 282:2,4,6,6,9 147:21 148:2 286:3,6 179:25 255:23 48:9 64:9,10,11,14,1865:1 bit boils briefed bumped 25:4 28:15 30:16,21 47:8 148:10,11 249:3,4 219:13 48:25 209:1 74:25 84:3 122:20 169:13 booby briefly bunch 170:4 171:16 202:14 227:2 160:8 6:20 57:4,15 63:16 89:16 35:3,5 45:12 133:24 139:4 227:25 247:15 booklet 102:25 220:4,6 173:14 178:16276:15 black 130:10,10 bring burn 120:15 249:5 booklets 187:2 31:9 blackened 92:13,24 brinker burned 282:14,14,14,19 born 141:11 31:10 123:19 219:2 286:22 blackheads 281:25 282:10 broad burning 51:1 248:24 249:6 bother 253:18 254:13,16 285:20 bladder 273:2 broadway busch 38:12 bothering 2:12 290:9 45:9 blew 233:17,20 broke business 15:5 bottom 162:4 73:9 100:2 163:1 169:16 blind 70:7 186:12 209:12 213:10 broken 171:10 174:20 51:1 213:13,13,19 209:24 284:10 busy block bought bromine 193:3 59:17 203:13 27:15 28:7 47:15 48:13,15 84:19 butter blocked 49:13 55:5 61:4,22 105:1 brother 15:8 21:1,2 51:19 226:5 73:8 buy blood box brought 16:1 21:5 29:9 77:3,8,10,19,21 145:13 24:13211:9 buying 78:5 79:12 89:21 159:24 brain brown 61:19 264:25 265:9,10,12,13,15 237:24,25 265:25 266:6,10,15,17 branch 269:3,8,9,10,13,17 270:6 6:8,16 10:15,22 200:15 270:10,14 271:24,25 brass bloomington 219:11,16 89:15,17 90:3 154:1 184:13 bread 184:16,18 185:9,10 186:9 167:23 blow break 85:19 128:8,9 223:15 245:3 40:6 75:2 108:17 179:24 275:5 brownish 49:5 brussels 207:17 208:20 215:2 buck 19:5 bucked 19:16 c cakes 169:5 calandra 165:9 167:17 192:10 236:14 calculated 159:5 WATER PCB-SD0000033248 [California - charge] California carbonless catches certain (cont.) 215:23,24 216:2,7 43:11 221:5 44:24 123:14 132:24 133:1,3 call carbons cats 148:25 159:20 255:25 13:10 19:6,13 25:19,25 41:5,6 145:15 256:3 263:17 270:21,22 31:10 34:5,7 52:23 77:5 carcinogen caught 271:5 272:8,8 278:5 283:16 134:6 148:8 158:22 164:18 239:17 285:17 284:9 164:19 190:13 196:16 care causally certainly 248:3 264:9 280:1 28:18 30:6 93:16 123:3,16 86:5 21:1 27:5,21,24 34:3 42:15 called 225:6 cause 61:8,25 62:11 80:3 85:10 8:12 10:7,18 18:3 22:15,22 cared 1:1021:9 50:1663:1597:2 92:23 102:17 107:7 108:7 27:1628:1844:11,1246:8 193:24 97:3 137:4,11 138:3 171:21 108:15 113:8 140:15,23 53:3 57:20 58:7 60:18 careful 174:14 176:24 235:10 141:1 160:24 190:8 192:25 67:25 68:1,9,18 71:23 72:7 65:19 239:17 247:24 249:9 260:8 193:25 194:4 200:2 206:25 89:8 91:12,20 104:25 carney 260:25 261:8 289:13 207:12 212:3 223:1 259:17 152:22 159:11 162:3,14,14 2:10 3:14 40:6 56:25 70:10 caused 262:23 271:15287:16 162:14 164:19 168:11 86:25 93:16 125:4,11,16 38:23 47:22 49:18,20 50:21 certainty 171:11 172:18 176:17 207:5,9 216:14,18 224:12 55:1 63:17 64:16 138:5 54:8 82:11 130:22 193:10 182:13 188:17 207:2 241:5 244:10,14 251:4,13 163:25 166:3 224:3 235:4 certificate 222:19 270:12 252:6,8 254:11,15 255:2 265:15 281:3,6 289:1 calling 261:24 262:1 263:19 264:7 causes certified 41:14 72:5 173:13 264:9 270:21 272:13,16 173:22 205:1 5:15,16,25 6:2,4 calls 275:6 279:18,25 281:8,11 causing certify 19:16,24 284:25 285:4,14 288:9 64:6 97:7 239:21 289:7,18 290:6 camera carol caution cetera 85:23 2:10 111:7,7 112:14 113:5 94:24 122:18 123:16 cameron Carolina 117:11 213:21 224:11 89:9 cautionary chain cancer carried 117:15 118:17 119:8 216:11 7:19 38:23 39:9,14 40:3 10:1 20:8 24:17,18 41:8 127:25 chairman 172:7,13,14,19 173:9,19,22 42:7 83:9 118:4 155:1 cautions 8:10 9:14,17 220:1 173:23 218:4 235:10,17,20 201:9 218:10 118:3 Chalmers 239:19 244:8,21,25 245:16 carry cc 42:19 101:21 cancers 42:6 43:12 91:14 290:12 chamber 172:12,25 173:13 235:12 cars cease 96:4 245:10 96:1 129:4,5,6 222:13 chance capabilities case ceased 56:21 268:7 87:21 22:24 23:4 49:25 55:15 222:15 change capable 60:19 68:13 71:7,8,11 83:7 cecil 20:14 53:16 97:9 131:20,22 224:8 131:7 183:3,4,6 193:18,18 1:6 57:25 149:4 160:13 163:11,25 capacitor 224:19 228:10 248:16 cellophane 166:8 255:21 272:24 81:21 96:3 117:4 124:1 268:16 275:5 139:24 changed 183:17 200:5 cases Celsius 10:9 20:13 48:5,8 97:15 capacitors 22:21 38:17 51:22 52:10 148:8 125:22 146:15,15 148:22 42:13,14,17 44:16 124:2 53:8 54:13,16 65:8 67:24 center 163:3 183:13,22,23 221:15 287:9 137:12,13 181:25244:7 7:2,3 9:17 10:22 84:25 changes capacity 261:3,13 centigrade 23:23 58:7 90:24 97:16,17 4:5 11:5 59:11 casey 148:2,2,3,9,11,13,17 285:3 249:6 caps 194:22 central changing 178:13 casting 4:8 11:8 40:17 280:12 car 43:14 246:24,25 cents channel 113:22,23 castings 123:18 71:14 carbolic 181:18 century characteristics 26:21 catastrophe 46:12 148:18 198:21 carbon 222:6 certain charge 43:11 47:1,2 66:17 221:5 catch 5:19,21 20:23 52:9 57:9,25 40:24,25 144:19 194:11 290:21 45:3 58:8,12 82:15 101:14 WATER PCB-SD0000033249 [check - comma] check chloracne (cont.) Cincinnati closely 11:21 14:8 24:2 25:5 29:12 63:3,10,15,17 64:2,12,24 7:12 99:11,23 144:1,15,25 223:21 234:16 41:23 76:24 79:13 212:18 65:2,4 74:5,10,13,17 77:1 circuit closest 276:13 80:20 88:8,12 137:13 138:5 1:1 117:10 69:25 checked 169:19 182:25 183:4 225:6 circulates clothes 41:6 53:6 160:7 169:21 230:15,18,23 247:15,18,24 286:5 53:16 checking 247:25 248:10,12,17 circumstances clothing 160:3 249:10,16,21 250:9,11,15 55:9 200:7 65:22 112:18 118:14 cheekbones 250:15,17,20,22 251:8,11 cite 128:18 248:20 251:16,24 252:12,13 250:25 265:19 clustering chemical 261:14 262:4 263:1 281:17 city 245:10 9:15,18 10:20,21,22,24 282:22 1:1 4:22 5:3 15:5,6 153:5 coal 17:7 27:16 30:6 31:11 chlorcosane 286:16 289:4 47:2,3 38:15 39:15,17 41:24 47:13 141:15 claim coast 47:14,16 49:12 50:5,12,12 chlorinate 80:13,14 216:2 52:23 60:22 61:3 64:5 81:6 156:7,8 claimed coastal 81:13 82:16 109:16 132:6 chlorinated 80:21 209:12 159:9 160:16 162:15 46:8,10,23,25 47:5,23,24 clarify coating 164:12 218:20 223:3 48:10 49:7 50:13 57:25 261:7 278:12 49:7 224:21 225:13,15 228:6,13 58:8,12 59:17 62:18 64:3 dark coatings 228:15,16 229:16 230:12 67:19,20,23 68:2,6,9 69:5 101:15 49:3 94:24 230:16,19 231:6,15,25 69:12,21,24 70:18,22 71:1 classification cocker 233:5,12 234:14 240:17,21 71:1,3,9,10,14,15,24 72:17 44:6 174:7 240:24 241:3,10,15 244:2 93:17,21 111:5,9,24 112:14 clean cocoa 252:7,12 253:24 254:7 113:4,8,10 114:20,23 49:5 143:7 167:25 222:24 15:8 257:22 258:6 260:8 269:5 126:16 127:20 139:17 273:4 coding chemicals 140:18,20 141:1,23,24,24 cleanup 133:24 18:7 22:22 29:11 38:24 143:11,12 154:3,4 156:7,12 224:4 coincidentally 50:6 59:15 62:17 89:10 190:4,9 239:20 280:15 clear 64:2 160:23 218:9 224:22,23 283:17,22 287:20 110:5,19 247:18 265:16 cold 225:9,18,19 227:18 231:19 chlorinating 284:13 87:10 233:2 236:25 252:4 48:7 cleared collect chemist chlorination 50:20 81:3 92:4 170:19 208:12 210:3 68:7 156:13 clears college 211:11,16,20 212:24 chlorine 114:19 4:18 215:11 280:10 26:21 29:7 31:16,17,17,19 clients color chemists 68:24 69:5,6,23,24 70:1,19 165:15 48:16 64:16,23 68:4 120:2 208:15,16 209:9 210:1,7 70:22 84:18 127:23 146:6 clinic 120:6 127:14 212:23 213:6 214:6,18 153:14,15 213:21 244:18 8:23 colored 215:16 cholesterol clinical 198:7 chest 78:2,4 79:9 8:2 77:4,7 83:7,10 90:5,6,7 colors 77:2 choose 90:9,10,13 270:15,25 271:3 120:14,18 Chicago 165:4 271:6 272:18 273:3 column 165:12 chromatograph clinically 70:8 chief 208:10 88:13 204:8,14 262:5 263:2 combination 52:8 211:4 chronic 263:7,14 259:2 child 86:4,7 87:13,13 88:13 clog combine 6:11 164:19 166:24 182:15 232:16 161:16 children 198:10 202:1 227:9,13,18 clogging combined 169:21 281:24,24 227:20 228:1,3,6,20 231:15 230:20 44:18 chloracne 234:21,22 260:25 261:11 close coming 47:17,18 48:20 49:13,18,19 262:5,14,19 263:2,14 38:16 40:19 53:21 69:23 52:1 79:17 147:14,16 50:21 51:6,11,13 53:25 287:19 92:25 136:7 208:1 153:13237:12276:15 54:9,19,20,23 55:1,4,7,13 chronicity closed 288:9 55:16 56:1,2,7,8 60:24 61:3 234:20 105:14 240:11,23 241:20 comma 61:1862:10,13,16,16,22 283:20 275:20,23 276:15 WATER PCB-SD0000033250 [commence - contamination] commence complained concerning (cont.) consistent 39:14 282:24 283:8 224:22 289:13 33:16 commercial complaint conclude consolidated 135:13 54:17 81:20,25 82:5 63:18 90:2 137:24 142:22 9:5 commission complaints 168:5 consult 288:17 290:1,3,3,3 25:6 33:20,21,25 34:1,3 concluded 8:20 commissioned 80:18,20 81:10,11 63:16 64:9 137:25 consultant 289:6 complete conclusion 9:3,5,8,16 25:2 73:14 175:3 committee 181:15 84:2 88:16 142:24 143:4,15 175:4 193:9 9:15,18 19:9 33:7219:7 completely conclusions consumed committees 41:18 84:18 100:2 173:21 148:21 176:19 235:1 239:1 275:12,20 277:19 283:13 219:8 284:11 239:7,13 240:3 245:17 consumers communication complex 260:21 269:2 169:4 37:17 40:16,17 condition consuming communications complimenting 8:21 29:1031:8 38:11,13 280:21 194:12 223:2 42:5 47:18 50:9,14,23 contact communitronics composed 53:22 65:19 12:23 19:1 53:15 93:10,14 1:21 289:8 236:7 conditions 103:13 107:1 112:2,16,16 community composition 10:1 22:25 28:17,19,20 112:17,18 113:6 118:11,11 6:18,25 237:8 240:2 264:5 258:12 41:20 198:22 205:4 118:12,13 124:25 128:15 companies compound conduct 128:15,16,17 131:8 138:25 13:7,10 131:12 165:17 20:19,23 21:6,11 35:3 42:11 181:22,24 182:19 184:16 175:3 206:11,13 256:25 42:11 60:21 67:24 70:17,21 conducted 196:4 202:15 205:2 208:22 257:4,9 70:23 71:2,10 84:18 117:22 59:3 240:15 241:2,8 company 138:2 159:24,7,8,10 201:1 conference contain 1:12 9:4,6,23 12:12 13:8 201:6 208:7 247:23 248:8 151:7 152:22 106:5 116:19 118:24 127:7 19:9 27:14,14,15,16 34:12 compounds confidence 150:23 198:18 35:7 36:5,5 37:2,16 41:13 21:6,16 26:15 44:4 47:23 267:5 268:3,7 contained 47:13,15,16 48:12,23 52:23 49:19 57:10 62:18 68:8 confident 104:24 150:25 160:12 55:5,18 89:14 92:9 101:16 117:5 141:13 142:6 143:10 268:9 163:24 166:2 168:20 101:19,24 109:9 132:6 143:13 159:5 162:24,25 confined 189:11 275:13,21 276:9 164:12 175:11 177:16 171:24 189:18,19 196:23 53:17 107:2 145:13,18 277:1,19 280:20 180:7 183:7 190:3 193:23 208:6 239:20 248:9 confirm container 196:18 199:12 200:14 conceivable 215:14 114:1,4 124:7,12 128:25 201:14 203:2,18,25 204:21 252:10 conflagration 147:13 205:9,17,23 206:2,8,24 conceivably 45:4 containers 207:14,19,2 211:18,19 129:3 confused 116:3 219:8,11 220:2 223:3 224:7 concentration 71:17,22 165:23 249:15 containing 224:21 225:24 226:5 98:24 99:7,12 177:2,13 confusing 100:14,16 104:4 105:14 252:12 256:9 258:16,18,19 178:10 198:23 260:17 212:7 275:19,24 276:7 107:3 115:21 117:12 124:3 259:7,9,12,13 concentrations confusion 162:12 164:1 181:16 195:1 compared 58:14 126:15 176:23 177:9 210:6,16,19,21 195:15,17 202:5 190:7 178:10 conjunction contains compares concern 281:13 70:19,21 106:3 111:23 159:23 115:19 connected 112:14 114:3 118:2 122:25 comparing concerned 82:18251:10 123:1,12 241:6 159:23 265:5 266:5,14 13:1523:1339:1541:9 Connecticut contaminant 271:22 272:1 75:16 85:11 106:20,25 74:1 64:11 123:3,13 278:4 compensation 176:20 181:21 182:14 connection contaminants 38:17 80:11,12 244:7 198:2 199:18 223:21 39:17 91:1 230:4 11:22 47:25 137:22 139:11 competent 239:21 243:12 280:12 consider 168:20 169:14 88:21 179:18 concerning 36:25 51:2 160:24 258:2 contaminated competition 31:7 33:5 35:24 37:17 61:9 considered 53:16 169:7 226:3 253:8 46:6 80:19 82:1,11 92:11 97:19 21:1,4 227:6 274:16,21 278:8 competitors 98:23 99:6 150:23 196:16 consisted contamination 222:9 198:1 199:16 223:22 10:2 121:16,18 167:10 178:11 WATER PCB-SD0000033251 [contamination - data] contamination (cont.) copies correspondence 194:8 218:11 136:25 191:9 192:8 41:8 92:14 193:3,7 207:18 contaminations copy corroborated 169:24 78:25 100:8 125:7,12 215:25 content 196:12 199:1 206:4 290:21 cosmetic 69:6,23 copyright 137:9 contents 116:22,23 120:11 cost 127:23 cords 41:25 42:1 continue 49:6 cough 22:1 163:5 220:21,23 224:3 corner 254:23,25 255:9 continued 111:15 coughs 15:24 22:7 27:17,21 83:15 cornfeld 254:25 163:6 2:11 290:8 council continuous corporate 78:20 205:2 219:7 counsel contribute corporation 3:2,2 289:19,22 101:23 1:21 216:25 289:9 count contributed corps 81:12 195:18 226:9,10,13 10:18,19 11:3 counterpart contributions correct 199:2 101:14 102:3 15:12 22:9 26:5 28:9 30:13 country contributors 43:4 49:15,17 51:15 56:22 73:23 221:20 101:10 56:24 63:11,11 72:14 79:4 counts contributory 79:8 80:22 88:17 91:5 77:3 39:3 94:16 101:5,7 112:12 114:7 couple control 115:23 118:7 126:3 142:17 22:13 99:9 117:18 120:17 9:16 85:1 93:12 97:11 150:5 159:21 170:9 176:9 130:2 135:3 215:8 227:7 174:1 218:15259:1 271:10 177:10 184:23 185:5 course 271:14 272:6 273:16,24 188:11,12 189:9 197:22 11:1527:3 35:1948:18 controlled 200:19 201:19 202:6 214:4 131:13200:4 210:12 24:5 216:9 217:21 225:10 226:7 214:25 222:8 225:12 controls 226:21,24 227:12 228:8,11 230:17 231:24 233:25 264:20,23 230:6,7,14 231:6,12,13 234:15 242:17 243:5 244:1 controversy 233:6,7,8 234:20 235:2,3 252:14 274:18 277:15,18 289:13 236:18 238:6,11,22 240:11 279:22 286:21 convenient 241:1,16 242:6,15,19,20 courses 104:16 243:2 244:13,22 246:11 4:23 conversation 247:19 249:1 251:18,25 court 92:10 252:9,13,14,19 253:5 255:5 1:1 86:24 177:7 conversations 255:19 256:1,9,13 257:14 cover 224:7 257:23 258:9 259:4,7 30:21 141:17 155:14 convinced 260:22 261:1 262:7 264:15 coveralls 262:19 264:18 266:8,17,18 267:7 178:13 convincing 267:11,14268:11,22 covered 88:13 262:5,10,15 263:2,7 272:10 274:16 279:9 281:4 81:16 170:4 207:13 263:9,13 264:2,3,6 281:7 282:11 283:12,15 created cooked 284:15,16,23,24 286:24,25 283:17 169:9 287:2,3 289:16 290:6 creating cooking corrected 284:14 169:16 170:1 172:3 276:3 creatinine cooperate corrections 90:20 272:25 273:1,2 79:25 275:24 credence cooperated correctly 274:3 218:24 257:13 credentials coordinators correlate 32:19 209:3 79:12 crept 44:11 critical 79:14 221:9,19 222:3,4,10 222:25 cross 78:7 79:23 224:14 crown 52:23 81:6,13 cubic 146:8,8,12,18,19 154:3 cure 218:4 curious 163:5 currently 75:18 customer 33:25 37:9 54:18 80:18,20 80:24 81:10 107:6,6 110:17 customers 11:18 19:22 23:1234:3,10 34:16 35:6,24 36:2,7,23 42:16 49:2 82:17,20 91:23 105:3 107:7,10 108:7 109:6 110:15,16 116:4 131:19 133:22 194:9,12 195:22 196:5 207:12,16,20 218:23 220:17,20 237:6 customer's 37:5 110:21 116:11 cut 44:22 99:14 151:4 220:18 229:19 cuts 229:22 cyanide 232:4 cyst 51:18 cysts 51:8 248:14 d damage 88:18 dangers 175:8 17111 data 37:22 88:7,7,12 101:15 109:2,10,13,20,22,23,24 1107 8 17 25 1217 122 7 188:7 189:21 196:21,23 201:7 206:7,10 236:25 239:2,3,4 262:4 WATER PCB-SD0000033252 [date - diabetes] date decrease department (cont.) description 57:7 87:22 89:12 115:17 269:14 33:22 34:14,17 35:15 37:13 132:7 125:14,18 129:11 141:5 decreased 39:13 40:10,12,15,23,25 designation 163:20 180:8 197:24 269:4,7,10,18 41:3 48:24 75:18 76:18 117:7 118:2 203:20 267:13 decreasing 78:8,15 85:3 96:15 99:4 designed dated 269:15 104:19 108:4 109:3,3 110:2 230:12 231:5 233:4 238:13 79:3 89:13 92:7 98:4,20 defatting 110:3,4,6 117:14 155:21 238:21 254:13 101:8 102:24 107:15 205:1 159:25 161:1 163:15,18 desk 114:18 125:24 132:5 144:9 defects 165:16 173:11 177:21 161:9 161:25 164:14,15 166:16 282:2,4,6,6,9 178:2 180:4 184:15 185:19 despite 166:22 175:7 180:4 187:10 defendant 185:23 187:9,23 191:6 88:7,11 262:3 189:8 191:7,21,24 196:15 1:14,182:9 3:3,12 194:3,20 196:13,14,15 destroyed 197:21 200:13 201:17 defense 197:16,16,17,19 199:3,4 284:15 285:8 203:18 204:21 205:10 222:19 223:10,19 200:13 201:13 202:13,20 destructive 216:25 217:18,19219:11 define 203:2 205:12 209:2,5,6,7 70:20 dates 12:8 20:18 133:19 156:15 211:12,21,24 217:9,10 detail 27:23 definite 219:14,15,15220:11 57:16 67:3 96:10 168:16 davis 249:24 250:5 235:21 245:2,3,4,8 256:20 detailed 79:19 definitely 257:3 35:16 day 250:16 departments details 1:20 21:12 25:12 52:3 definition 12:7 16:9 24:12 38:2 85:5 52:1461:18,22 145:11 84:21 145:20 147:1 151:19 21:11 68:1 228:2 depend 149:22 152:3,6,7 159:10,22 180:10 definitions 200:4 247:7 detect 204:19 215:9 216:15 60:19 depending 29:7 212:20 230:11,12 229:23 234:18 242:25 deformed 20:21 68:7 228:16 239:5,5 determination 243:5 288:15 282:3 depends 177:15 days defunct 13:5 16:5 21:16 34:25 47:6 determine 13:21 15:14 18:2,22 25:13 22:17 50:24 113:18,19 135:7 155:6 225:19 229:15,25 77:21 78:22 137:12 140:1 degradation 157:13 159:12 161:6 231:6,8,15233:10234:13 151:17,19,22,24 152:2,2,3 224:2 172:23 248:8,19 260:17 243:15 244:24 245:17 152:4,7,11,13,13,14,14 degraded 282:4 283:19 274:20 156:21 164:17,18 175:25 209:23 deposes determined 176:15 179:9,9 209:2 degree 3:12 174:14 230:22 226:25 227:5 228:25 4:19,20 54:7 82:11 130:22 deposit determines 250:13 148:25 193:10 284:22 155:8 12:10 ddt degrees deposition determining 210:9,10,19,24,24 211:2 35:17,18 148:1,1,10,11,14 1:173:3 21:11 56:18 236:17 deal 156:12 168:25 183:9 184:2 216:19 249:11 275:5,9 detroit 12:1 47:13 97:6 159:15 184:2 200:3 247:10 252:18 277:9 289:16,20 19:12 166:21,24 183:11 274:3 252:19,20 253:19 260:2 depositions develop dealing 284:19 285:6 153:24 250:11,16 163:8 201:25 233:9 237:24 delaware derivatives developed deals 73:14 175:2 57:10 31:16 43:6 48:19,20 50:1 6:16 89:10 92:9 144:2 delivery dermal 85:9 94:23 182:25 201:6 dealt 290:22 164:16 249:20 258:16 20:4 22:14,23 23:2 demonstrable dermatergosis developing dearborn 88:13 262:5,19 263:2,8,14 57:22 220:24 203:18 205:10 demonstrate dermatology development death 74:22 57:18 219:7 223:22 50:14 dentition describe devoted decern ber 282:8 60:24 72:23 76:12 89:16 22:19 130:21 199:7,12 240:8 department 122:19 159:7 168:15 170:7 di decide 4:8 10:18 11:8 16:25 17:1 214:23 64:3 274:11 18:1 19:8,12,20,25 20:9,11 describes diabetes decision 20:12 23:2 24:7,10 25:7 95:19,19,23,23 29:9 32:12 29:23 31:15,17,19 33:6,8 WATER PCB-SD0000033253 [diagnose - dozen] diagnose diphenyl discussed doctor (cont.) 6:12 59:16,17 68:2 69:5 70:18 47:5 130:24 180:22 184:20 243:24 244:12,21 247:16 diagnosis 70:22 71:1,3,10,14,15 185:11 189:15 195:17 248:24 249:22 250:4 252:1 6:10 9:24,25 111:24,24 113:5,7,10 207:18,25 247:16 253:2,23 254:4,17 255:24 diamonds 114:20,23 139:18 140:18 discusses 256:7 257:19 259:21 47:1,3 141:1,16,23,24 156:8 66:24 263:25 265:17 266:2,19 diarrhea diphenylbenzene discussing 269:3 273:10 274:4,12 232:1 69:21 71:2,9,25 93:18,21 66:20 189:22 276:17 279:10,21 283:18 dibenzofurans 141:24 143:12 discussion 285:9,22 286:13 287:11 169:14 170:20 171:24 dipped 288:5 doctors 280:14,15 284:4,7,9,14,15 55:22 disease 11:24,25 12:3 19:23,23 285:6 287:1 dipping 6:5,17 21:3 50:4,5 83:10 29:21 32:20 40:13 62:14 die 183:4 90:13 174:15 267:6 272:18 73:22,23,24 43:14 181:18232:17 direct diseases doctor's died 3:13 228:2 235:15 236:23 6:10 38:6 38:19 232:14 239:25 240:15 241:2,7 dispensary document dielectric 247:16 252:2 260:20 25:4 29:25 31:18 38:1 57:10 78:18 102:9 103:19 42:10 44:18,23 48:17 64:23 274:15 276:24 disposal 107:14 108:2 125:18 132:9 127:5 195:1,4 directed 123:5,9,16 124:10 129:2 132:12,17,19,21 133:4,9,18 dielectrics 24:7 33:6 41:19 94:18 95:1 disregard 134:10 138:16 175:7 189:3 45:17 64:16 95:12 200:14,17 141:14 191:3,19 197:7 201:11 dies direction dissatisfied 223:16 231:22 232:15 24:9 31:5 175:15 100:2 documents difference directive disseminated 12:7 56:14,15,19,21 109:1 47:2 86:21 90:14,15 122:20 33:14 91:22 114:9 116:16,18,20 144:6 170:13 228:1 253:9 directives disseminating dogs 253:11 254:24 267:19 19:8 12:25 145:16 167:1,6,7 168:6 272:12,20 285:20 directly dissemination 229:7,23 different 36:7,23 37:1 263:22 133:21 doing 26:22 37:2 38:14 47:1,19 director distilling 8:19 13:4 21:14 22:4 23:21 48:16,17 64:16 68:4,5,6,8 4:8 9:7 10:11,14 11:7,7,10 65:24 66:2,3 25:9 134:2 144:18 149:19 71:10,19 74:25 84:17 85:5 14:23 15:18 18:1923:17 distributed 158:24 169:6 175:20,21 90:17 107:23,25 111:6 28:13 32:7 37:16 38:1,4 95:8 104:3 105:13 108:13 202:17 212:3 219:4 227:17 118:20 119:10 120:17 40:19,20 41:10 45:22 59:12 distributors 229:2 233:10 252:7 266:4 122:23 124:22 126:14,16 73:13,21 80:17 87:20 92:21 121:22 274:4 127:20,22 137:8 139:9 129:18 175:9 177:18 disturbances donohue 140:11 143:12 156:12 178:21 194:18,19203:11 281:18 2:11 290:8 159:5 161:23 162:13 223:11 224:11 divided dose 166:25 168:19,21 170:25 directors 158:20 151:23 155:19 156:23 173:4,23 174:4,5,5,8,9,11 13:10 73:24,25 131:12 division 157:17 158:8,17,18,22 176:12,15,15 228:7,15 disappear 92:4 191:22,24 211:10,14 159:10,13,16 228:5 229:18 235:1,7 239:1,7,13 240:3,3 51:20 213:24,25 211:18,19 229:19 231:24 247:22 252:15,17,18,19,20 267:10 disappearing doctor 250:13 267:16 282:5 286:9,10 214:2 218:17 3:24 5:7,14 6:20 9:20 12:4 doses differently discipline 19:3 23:21 25:9 28:14 30:5 60:3 175:23,24 29:5 170:17 252:3,4 18:6 31:22 32:21,21,22 34:5,6,7 double digest discount 34:8 38:5 40:9 46:1,2 52:24 212:18276:13 261:21 273:9 54:5 56:13 58:19 59:2 doubt digestive discovered 63:21 74:3 76:15 78:15,20 166:3,7 281:18 207:15,16,23 217:25 218:4 79:3,15,20 86:15,18,19 douglas dioxin 218:5 91:795:4 119:5 121:7 258:20 287:1 discovery 141:21 175:6 219:5 227:8 dow dioxins 207:19 209:8,25 210:7 228:19 231:20 233:9 165:19 287:4,5,10,22 discuss 235:14,16,23 236:7,23 dozen dip 67:3 237:7 238:24 239:10 240:2 15:7 174:8 257:9 273:6 55:23 240:11 241:10 242:3,22 WATER PCB-SD0000033254 [dr - emphasize] dr drum (cont.) easier effluence 4:15 8:14 17:22 30:4 31:24 130:13,13 106:13 247:5 255:12 220:18 32:4,8 40:20,23 41:8 42:8 drums easily eight 43:5 47:9 52:7 57:9,17,24 113:24 114:6 115:20,25 135:23 136:1 221:11 1:19 145:20 147:1 152:4,8 61:15 62:25 65:9 66:6,7,10 121:20 129:1,3,4 219:2 east 157:10,16 242:25 243:5 66:13 72:15,24 73:10 75:4 ducks 25:19,25 26:3,6,18,23 27:4 262:1 269:18 270:2,6 78:25,25 79:19 82:9 84:11 167:12 27:5,20 28:12,23 29:24 either 84:22 86:15,17 87:2,18,19 due 32:25 55:19 62:13,18,21 4:23 6:6 12:24 15:2 16:24 88:15,23 99:13,16,20 22:25 34:16 50:6 54:24 74:4,14,22 75:17 79:1,7 19:5 20:11 22:24 29:16 108:20 114:16 127:24 64:4 169:22,23 226:3 80:1 115:15 123:19 175:11 30:16 37:14 38:3 54:18 129:17 130:20 132:9 230:16 249:6 250:17,20 179:16 182:8 57:22 73:7 77:6 126:15 134:10,20 135:14,18 265:9,24 easy 146:14 155:21 162:24 136:18 137:12 138:13,20 duly 13:16 169:15,24 172:1 208:20 140:12 141:4 142:1,11,15 289:6,11 eat 215:2 278:25 280:10 142:21 143:23 144:2,14 dupont 176:7 214:11,12,13,14 288:10 146:1 149:9,15 150:22 165:17 233:22 ekg's 152:16 153:11 165:9 duration eating 77:2 172:15,21,23 173:12 174:3 145:10 50:7 209:13 214:15 216:8 electric 174:13,17,17 175:9,17 dust 242:5 42:18,20,23,25 43:3 73:14 176:16 177:8 178:5 179:12 17:11,11 eats 73:15,21 82:1 89:14 96:7 179:18 180:1 191:4,21 dusted 253:8 101:17,20 102:6,16 103:23 193:4,8,22,22,22 194:6,22 210:14 economic 116:25 117:2,21,23,25 194:22 196:12 207:14,24 dusts 224:9 150:18 175:10,13 180:7 207:24 211:3 212:23 112:3 ed 189:6 190:4 191:7,22 215:10,21 216:21 217:7 duties 219:25 194:19 195:3,5,8,14,21 222:18 224:12,16,19 225:5 4:5 9:21,21 11:9,11,23 edema 196:1,18,20 197:14,15,21 225:7 229:9 230:9 234:23 236:24 232:14 197:23 198:19 199:4 200:8 235:4,15 236:9,13,13,16,18 dwayne edf 200:9 207:7,15,20,2 216:25 256:22 260:21 288:6,9 203:13 223:18 electrical draft e edgar 42:12 44:19 54:23 94:22 93:12 drafted el.OOr 290:14 41:14 edgewood 95:13,25 98:15 100:14 103:20,22,24 194:2 221:19 130:23 draw e2.00r 290:22 10:21 edited 221:24 electricity 78:5 115:6 drinker eagles 214:12,13,14 97:24 editor 42:11 electric's 47:9 57:25 58:11 66:7,10 earlier 237:22 238:1 195:1 196:2,5 66:13 67:5,15,18,25 68:23 72:15 73:2,6,6,8 93:19 141:4,5 142:6,16,21 160:6 80:10 87:13 126:15 135:2 141:12 144:14 174:18 181:25 195:19216:21 educate 220:20 educational elevated 49:23 50:9 53:17 54:15 72:22 79:11 93:13 107:2 226:15,23 drinker's 58:6 72:24 226:9 142:2,12 193:22 218:1 255:24 278:22 earliest 145:8 256:3 264:13 4:16 149:1 204:6,24 241:22 effect 250:12 260:13 74:6,23 80:21 93:15 155:12 elevation 158:24 207:21 228:6,8 265:10 274:3 drinks early 231:15241:15243:15,18 elmer 90:23 drop 155:11 181:16213:10 dropped 13:20 15:14,18 18:2 29:8,9 47:4,6 52:21 63:4 65:5 92:15 111:10 137:12 171:16 179:9 209:2 210:6 249:17 261:15 263:8 17:15 153:7 180:3 197:16 effects 201:12 256:23 12:11,23 14:15,16 33:5 emeritus 37:8 84:16 86:3,5,10 87:5,6 6:23 5:13 213:22 221:25 227:10 228:21 87:14 88:14 89:10 93:10 eminent dropping 45:13 278:25 earner 131:1,4,24 135:24 193:12 165:8 205:3 228:3,15 231:19 emmet drug 167:17 168:2 39:7 earthquake 232:1,8,19,21,24,24 234:13 1:173:10,17288:14289:10 243:7 244:6 260:25 261:4 emphasize drum 113:20,21 114:3 116:6,11 240:5 261:11 262:6,14,20 263:3 263:14 88:17 WATER PCB-SD0000033255 [employ - exhibit] employ entirety escape examinations (cont.) 179:4 270:18 221:11 75:6 78:11 79:6 89:23 employed entitled especially 178:15 244:9 4:2,3,11 74:15 75:18 57:20,25 105:24 175:8 15:25 65:19 76:25 244:17 examine 131:21 132:10 134:20 entry essence 29:15,18 30:14 75:15 90:7 153:1 179:8,14 289:19,22 123:4 72:5 90:25 examined employee environment essentially 1:18 3:11 29:20,21 41:22 9:12 25:1,2,8 33:25 37:2,4 6:19,19 10:3 76:2 97:11 229:25 74:4,7 75:9,11,16,18 76:20 37:7 39:6 92:6,7 196:22 119:20,23 123:4 124:24 established 91:1 175:23 267:22,23 197:15,15 289:21 207:12 209:10 212:21 230:23,25 237:13 238:14 271:14 278:22 289:14 employees 213:7 215:15,19218:8,17 238:25 250:17 265:20 examining 24:8,9 28:11 29:13 30:6 218:21 219:13 220:25 estimate 10:2 15:23 74:10,18 208:6 31:3 32:14 36:7,23 37:18 222:24 223:21 261:21 146:2 147:19 148:4 280:18 example 38:4,7,20 39:2,4 61:7 63:20 environmental et 16:1921:1,10 31:1641:21 67:16 74:8 77:9 78:7 30:17 78:20 85:1 88:2,3 1:6 94:24 122:18 123:16 43:16 119:25 156:22 157:3 133:22 204:4 207:15 225:6 97:9 106:17 121:16,18 213:21 157:24 244:17,17 245:23 246:4 122:18 123:3,13 128:4 european examples employment 129:7,14 167:10 194:7,12 207:16 22:10 4:9 9:10 65:24 89:1 201:25 207:14 209:3 evaluation exams empty 217:15218:1,11,11,16 89:6 16:3 28:22 29:2,17 75:20 125:23 222:19 223:9,19,22 224:2 evening 77:23 enclose enzyme 148:6 exceed 188:5,13 90:19,22,23 272:22 event 260:16 284:10 285:7 enclosed enzymes 266:4 excellent 65:24 186:20,23 187:4 79:10 eventually 165:13,22 189:14 240:13 epa 122:13 146:14 208:18 exception encloses 78:22,22 87:20 88:1,2 212:19215:5,13221:1,7 3:22 8:20 15:14 20:7 31:9 188:10,15 168:2 232:15 286:7 54:13,15 81:6 96:23 97:17 ended epidemic everybody 135:16 249:18 250:23 190:1 48:1 35:25 39:4 103:20 110:16 251:18,21 254:5 261:14 engaged epidemiological 115:7 207:10 210:14 222:7 exceptions 17:13 18:1037:1865:19 230:3 243:14,19,25 264:15 245:1 252:12 96:23 engineer 264:17 everyday exchange 17:8 epidemiologist 159:19 56:19 169:16 249:20 engineering 245:9,17,20 268:18 everytime excuse 17:8 96:19 189:23 epidemiologists 25:3 143:24 england 83:9 evidence executive 7:18 15:15 17:1423:6 episode 91:3 174:14 243:9 262:15 19:9 33:7 223:11 224:11 27:23 54:21 74:1 226:2 249:19 250:10 272:23 280:8 exhaust english episodes evolved 183:7,10 198:25 83:18 126:2,7 214:18 215:4 249:18 93:8,12 200:3 204:23 exhibit 262:25 263:3 eppenberger exactly 62:24 65:10 69:8,11 70:3 enlarged 2:11 290:8 17:6 27:4 42:13 170:19 70:14 72:12 78:17 84:7,8 232:22 eppley 215:22 235:6 255:3 262:25 87:16,17 89:4,5 91:24 92:1 enlargement 173:9 235:19 265:8 271:20 272:5 283:7 98:1,22 102:7 103:25 76:25 equal exam 107:13,22 111:22 112:4 ensure 158:15 76:13,14 113:2 115:12 116:13 118:5 36:1 equipment examination 119:19,19 120:6,19 121:13 entail 94:22 218:7,14 3:13 5:20,22 6:17 10:4 25:8 123:21,25 124:5,14,15,16 14:5 equivalent 25:9 28:11 74:7,9 76:11,15 124:19,20 125:7,17 126:2 entire 111:19 159:1 89:20,25 155:11 224:14 127:7,13,15 128:6,9,20,22 131:21 error 228:2 235:15 236:24 132:1,3 134:10 136:15 entirely 258:2 247:17 252:2 260:21 138:12 140:12 141:2,3 38:14 68:3,3 71:9 143:6,12 eruption 274:15 276:24 289:15 142:1 143:19,21 150:3,3 143:17 270:20 64:1,2 66:1 93:11 281:25 examinations 157:5 175:5 178:6 180:2,2 282:8,19 5:22 12:5 15:19 28:25 75:5 182:4 185:21 186:3,24 WATER PCB-SD0000033256 [exhibit - female] exhibit (cont.) expert extent familiar 189:2 191:2,15,19 196:8,9 85:6 237:23 50:24 170:22 41:7 66:9,11 168:12222:18 197:6 199:7,8 201:10 202:7 expertise extra 246:3 265:18 266:24 203:15,16 204:10,16 205:6 45:25 128:2 286:13 205:7,19,20 216:21 217:18 experts extreme familiarize 217:19,22 219:5,19 220:6 251:9 123:3,15 198:22,22 17:3 23:21 61:18,20,22 223:8 256:6 258:8 259:5 expire extremely 62:4 261:20 264:13 268:24 40:7 21:7,19 229:8 273:5 280:16 fans 270:19 expires 287:16,18 65:25 exhibits 288:17 290:1,3,3,3 eye far 56:15 57:1,3,4 58:20 66:11 explain 112:18 118:13 128:17 13:15 20:9 23:12 24:5 31:2 66:18,20 91:7,11,12 94:1,8 5:14 68:20 71:4 137:1 184:1 231:9 245:13 41:9 71:1475:1682:18 94:14 95:4,11 96:8,16 153:17 eyes 85:11 86:4 87:13 94:24 102:13 103:21 105:7,12 explained 76:24 112:16 118:11 106:19,24 119:14 120:23 107:4,10 108:21 109:11 71:16 128:15 155:11,12_________ 176:20 181:20 239:20 111:1,3 113:11 114:8 117:9 exploded f 243:11 280:11 118:16 119:5,17 121:25 286:14,17 face faster 122:19 126:9,11,12,12,19 explosion 126:25 127:3,11,15 130:24 15:5 20:8 34:21 109:23 137:10 248:21,22 facilities 161:18 fat 143:23 145:5 148:23 149:10 150:4,4 154:20,23 156:2 160:13 161:2,10,13 explosions 187:21 exposed 162:9 190:7 fact 17:7 36:13 45:17 46:10 265:14 fatality 82:6 163:15 164:4 166:9,19 202:9 217:3,4,18 255:25 14:20 16:22 17:12 37:7 49:23 50:9 52:25 55:10,11 56:2 62:14 69:20 72:9 78:3 80:3 83:8 85:8 125:6 fathers 73:12 177:19 256:4 exist 16:10 86:2 87:4 96:2 136:6 151:18 152:5 228:13,14,17 233:5 251:12 253:7 261:10 148:24 159:9 204:3 210:9 215:15 221:24 228:10 239:16 252:11 258:5 fathom 146:21 fats existed 13:20 38:11 264:24 265:6,6 271:18 272:9 285:10,11,12,24 262:14 264:21 282:2,10 287:13 265:12,13 favorable existing 13:9 213:22 exists 20:21 expanded 287:24 exposure 16:18,21 20:24 37:4 39:15 39:17 49:21 50:15,19 51:22 58:8 86:5 88:12 90:5,14,21 factor 159:12,4 factors 239:6 factory 218:20 188:23 feathers 209:13214:13216:5,6 february 4:7 58:10 161:25 189:8 40:10,13 expect 91:4 93:8 103:6,10 146:2 150:24 152:17 176:13 169:25 facts 190:25 205:10,17 206:2 217:19 269:12 279:23 178:14 190:6,16,20,21 134:17 fed expected 240:24 experience 196:25 198:9 228:16 240:20,24 241:3,12,12,14 241:20,25,25 242:1 244:7 fahrenheit 148:4,5,10,12,15 169:1 184:2 247:11 260:2 284:25 60:1466:14,15,16 157:10 158:14 159:1 172:16,19,22 federal 83:4,5 130:4 131:14 183:17 184:22 185:13 188:24 189:24 190:3,5,15,22 193:15,16 247:23,24 248:9,11 250:18 251:15 252:3,8,20,22,23,24 253:17,20 260:11,14 262:4 265:15 267:6 269:4,5,13,21 failure 232:3 fair 119:1 228:19,23 239:10 153:4 feed 155:6,13 176:4 227:24 feeding experienced 270:16 272:20 249:22 250:4 263:18 158:25 166:15,24 168:6 200:6 experiment 145:10 149:20 152:15 229:21 exposures 90:15,16,17 103:8 176:11 176:12 184:20 185:12 196:21 240:21 248:5 273:10,14 274:8,10 284:12 285:9 fairly 72:8 238:12 172:15 227:23 229:6,7 feel 104:9 138:1 220:5 249:8 fell experimental 252:15 faith 44:6 93:7 experimentation extended 250:19 1:22 3:4 289:5 falcons fellow 7:25 31:9 73:7 74:18 78:2 14:1 experiments extension 49:6 214:15 falls 115:3 131:12 140:8 147:1 177:17,19 70:21 176:22 extensive 93:14 130:9 196:18 female 174:10,12 WATER PCB-SD0000033257 [females - four] females 183:6 ferry 199:2 fiber 113:24 field 6:9 8:18 150:14 194:2 204:5 237:23 251:9 fifth 159:3 fifties 78:2 figure 136:12 158:19 159:19 figures 275:23 file 92:3 196:12 filed 80:13 files 48:23 138:13 225:1 fill 109:7,9 110:6 filled 43:20 55:23 109:16,24,24 256:18 257:13,16 fills 257:3 final 32:12 97:25 192:13 finally 72:11 116:10 169:21 191:18,18 206:17 224:2 financially 289:22 find 13:19 17:11 23:1040:3 52:10 91:1 95:18 99:17 124:15 157:4 160:8 178:4 209:17 229:9,18 264:6 267:21 271:2 272:8,19 278:23 279:2,2,23 finding 77:18210:16 findings 77:22 90:22 149:11,15 fine 26:9 151:11 276:21 fingernails 282:14,19,21 fingers 81:12 finish 177:4 204:15 207:10 finished flinn (cont.) foreign 18:16 34:9 64:7 120:23 140:12 225:1,3,8 230:9 175:16 121:2 122:10 167:25 flinn's foreman fire 140:4 24:11 38:3 20:7 34:21 44:17,19,24 floor forenoon 45:3,3,6,8,9,11,12,21 147:6 241:25 1:20 100:19 109:23 187:21 fluid forget 222:5 284:4 285:10,17,24 43:12,16 105:14,24 112:19 180:11 286:15,20,21 117:4 118:14 119:9 120:12 forgot fires 124:2,2 127:5 128:18 144:8 56:11 102:12 139:22 187:2 286:19 175:14 181:17 188:1,17 fork firm 195:2 203:23 206:6 220:25 56:5 2:6 290:17 286:21 287:7 form first fluids 36:8 54:2 93:11 102:19,20 9:21 10:20 12:12 14:19 43:11,14,24 44:1,14,20 132:13 190:17 223:4 247:1 16:15 17:22 18:22 19:1 94:22 100:14,15,16,21 279:25 21:21 25:22 27:2,4 34:4 104:4 117:3 123:17 162:19 formalized 35:1 37:1 39:2 40:24 41:13 190:5 195:17221:10 92:18 57:2 66:1 71:8,13,23 73:2,6 232:16 format 90:4 109:4 112:20 125:17 fluorides 115:6 141:7 143:14 146:13 218:10 formed 169:22 171:14,14 174:25 flush 4:8 284:9,17 285:7 178:9 186:13 203:12 112:18 118:13 128:17 forms 207:11 209:19 214:18 focus 37:21 123:14 218:6 220:10,16 221:3,7 141:20 formulations 225:25 226:6 228:20 focused 163:13 229:17,22 247:18 252:11 67:18,20 85:24 fort 256:6 257:5,11,18 262:9,9 follow 19:13 269:9 275:18 289:11 56:7 124:11 245:22 249:23 forth fish 250:4 253:23 254:8 138:9 50:7 97:12 123:15 167:12 followed forties 167:12209:13,14214:12 24:3 53:25 54:6,14 82:23 78:1 214:13,14,15216:8,11 83:22 115:24 129:19 forward 217:11 130:23 149:6 164:2 166:5 59:4 187:24 fitted 193:5 207:16 forwarding 95:2 following 188:22 five 67:25 101:15 102:4 112:18 found 9:1 12:1426:1676:17 118:13 128:17290:6 35:3 48:8 69:12 70:24 77:16 81:19 98:23 110:8 follows 71:25 72:12 76:2 77:23 151:19 152:2,2,3,7,13 250:3 85:8 88:18 91:3 138:2 154:2 156:21 159:2,15 food 139:1 146:5 151:5 157:6 175:25 274:1 277:10,19 159:22 167:9,17,19,20,21 169:22,23 172:24 173:2 flagrant 167:22 168:2,8 216:11 208:13,15,16,21,25 209:9 24:19 229:4,5 209:13,14 214:6,7,8 215:25 flame forceps 216:1,3,3,4 221:23 222:11 285:18 286:4,10,11 56:5 230:17 235:4,13 272:11 flaming ford 278:23 279:11 281:14 45:12 203:1,17,25 204:20 205:9 287:1 flammable 205:16,20,23 206:1,8,14,18 foundation 45:2 206:22,25 207:1,14,19,2 133:13 fledged 256:8 foundation's 178:22 forearm 223:5 fleming 31:10 fountain 200:15 258:9,11 forefront 34:17 flinn 177:17 four 136:18 137:12 138:13,20 7:15 17:19,20 18:12,13 WATER PCB-SD0000033258 [four - goodness] four (cont.) functions general (cont.) glands 26:13,16 40:1 48:5 55:12 89:24,25 195:14,21,25 196:1,5,18,20 230:20 60:2,4,8,10,11,11 75:11 fund 197:14,15,21,23 198:19 gloves 76:21 79:18 83:7,8 104:8 222:19 223:10,19 199:4 200:8,9 207:7,15,20 178:13 199:14,17,17,18 126:4 130:11,12 131:13 fungi 207:2 209:16 216:25 go 138:1 139:10 141:12 145:2 213:11 239:22 253:15 254:5 13:4 15:15,16 16:24 32:17 155:10,15,17 156:21 229:3 funny generally 34:4,6 37:1,12 41:23,24,25 256:5 278:1 173:23 86:4 145:11 247:4 253:15 47:14 57:13 68:21 73:18 fourth furans 253:19 74:25 76:15 77:7 80:8 14:11 191:13 275:3 277:1,6,11,20 278:20 generated 85:17 86:18,19 87:24 93:20 fr 278:21,23 279:24 280:12 144:5 94:3,22 95:17,21 96:9 107:21,21,21 126:14 280:13,20 281:3,6 287:14 generic 102:7,18 103:21,25 106:13 fraction furnace 44:4 100:19 113:15 122:11 123:15 229:23 43:19 gentleman 124:12 128:20 130:10 frame further 196:20 199:11 136:14 141:2,2 143:19 113:22 58:11 219:25 224:13 225:8 gentlemen 149:21 156:4 161:10,15,15 frank 288:10 289:18,20 184:21 185:12 161:18 164:4 166:9 176:19 101:15 fuss georgia 180:17 181:10 182:4 186:2 frederick 234:10 85:4 187:2,7 191:2 199:6 200:10 136:18 free 13:14 220:5 freedom 226:4 freely 57:23 freight 123:17 french 278:22 frequent 17:1741:15 frequently 41:12 freshly 65:21 friend 199:2 front g g.e. 102:4,5 116:22,24 196:22 200:5,8 gain 23322 gallons 1144 game 16712 gamut 94 25 96 6 garbled 1337 134 16 17 garments 93:14 178:12 garrett 200:11 205:8,11 256:19,21 256:23 258:8'l 5 german 174:7,23 278:22 getting 21:15 31:18 52:16 53:25 66:3,4,5 69:16 73:17 130:12 148:17 165:23 167:9 176:3 180:10 203:21 204:19 212:7 230:19 249:14 ggtp 90:18,20,25 272:21,24 273:5,9 274:3 gimic 56:4 gist 182:3 201:22 give 13:14 22:10 31:6 36:6,22 37:5 49:4 57:11 64:23 76:21 84:4,5 96:6 98:11,23 201:10 202:7 205:6 217:9 218:7 220:9 256:25 261:20 269:6 276:22 283:9 288:3 goal 129:19 god 18:1645:12 goes 51:7 124:20 201:15248:12 going 13:11 21:3 30:1831:21 41:25 42:1 45:24 49:10 51:12,13,20 56:19 76:8 80:4 84:8 85:18 103:9 106:8 116:15 125:9 130:10 130:11,15,15 137:9,11 147:11 159:19,23 160:7 167:18,19,21 178:13 183:17 192:14 198:8,24 199:1 207:5,10 218:21 57:3 67:10 122:14 255:25 10:24 256:4 fry 169:5 full gasoline 44:22,23 gather 82:19 4:14 12:3 25:1 28:14 60:15 gathered 80:5 125:2 133:7,7 178:22 286:3 60:20 118:1 122:1 136:4 146:12 148:4 173:6 180:8 186:6 201:21 221:13 229:20 231:24 238:1 242:18,21 248:9 251:9 263:23 266:11 274:2 280:19 286:16 given 7:8,10 107:9 137:22,23 220:2 236:16 240:8 241:3 241:19243:1,2 244:10 247:10,13 253:25 254:11 254:23 264:7 279:19 285:11,12,25 286:4,5,9 good 23:21 32:21 35:7 39:25 41:1 44:18,19,23 45:16,23 fully 79:25 13923 general 143:7 157:2 225:4 245:16 246:6 289:17 fumes 6:9 8:19 18:25 19:2 39:4 gives 49:23 52:1 53:19 66:4,5 107:1 112:3 113:7 125:1 42:18,23,25 43:3 73:15,21 82:1 100:13 101:17,20 159:18 229:22 giving 138:24 152:6 200:3 204:23 241:24 260:14 102 6 15 20 103 4 23 105:21 116:25 117:2,21,23 88:19 108:6 158:3,7 192:5 201:21 275:4 function 24:14 34:21 77:3 273:6,7 117:25 127:9 150:18 154:24 194:19 195:1,3,5,8 gland 51:19 64:22,22 77:17,20,21 85:14 97:9 100:8 114:4 116:7 155:19 162:7 165:11 175:3 178:1 183:25 194:4 202:20 202:20,21 224:4,16 238:13 248:22 271:14 goodness 70:4 72:3,12 142:12,23 143:5 WATER PCB-SD0000033259 [goop - heat] goop group (cont.) handled (cont.) harmless 213:13,15,18 202:21,21 203:9 207:23 143:15 182:2 143:6,17 gotten 209:18 211:4,25 212:2,10 handling harvard 78:9 139:1 241:11 212:12,14,15,16219:16 20:1,6,7,9 23:12 24:2,6,17 7:11 47:9 72:16,25 gout 220:8,9 222:22,23,23,25 34:13,20,24 35:8,12,20,22 haskell 78:3 223:10 235:23 236:1,7 36:2,6,22 37:11,17,24 73:13 175:2,10 government 265:2,6 266:13,15 267:6,16 53:12,24 54:6 65:10 82:22 hazard 13:23 23:1 78:13,24,25 267:19,20 268:15 269:21 83:22 92:12,16 93:2 94:7 16:9 89:6 109:23,23,24 79:3,20 80:1,4,7 83:8 85:2 269:22 271:11,12,14 272:6 94:13,15 95:14,20 96:9,15 110:8 85:6,13 88:4,21 89:9 272:10,20 273:25 96:20 97:18 98:5,14 99:2 hazards 131:10 134:7 150:21 151:6 grouping 102:21 103:1 104:6,13,20 23:23 200:25 151:7 152:23 153:2,4,4,5,8 25:5 245:10 104:24 106:5,10,16,25 hazlett 153:9,16,22,23 154:2,6 groupings 107:4,20 108:3,9 116:9 177:18 165:15 167:15,16 168:3,3 40:3 244:25 117:11,15 118:2,5,9,25 head 174:23,25 193:19 206:9,10 groups 119:1,11 122:16 124:4,20 34:17 115:2 179:20 184:12 212:12,14217:8,10,11,14 90:15 150:19 175:25 124:21 126:1,18,22 127:7,8 211:9 217:20,23 218:24 221:25 235:19 236:5 264:23 127:12 128:12 129:19 headache 222:13 272:20 130:23 138:21 148:22 234:3 governmental growing 149:5 164:2 166:5 178:6,16 headaches 146:16,16 173:24 178:25 189:21 190:4 193:5 199:19259:10,23 271:6,8 grab guess 193:8 195:9,15,21 198:18 283:1 59:14,15 18:11 24:1 29:19 39:7 48:4 198:22 201:8 207:16 headquarters grade 60:20 89:11 100:9 125:4 253:24 254:8,9 40:17 179:16 182:8 185:19 64:3,7 211:7 230:22 285:22 hands 191:6 192:1 199:5 203:18 gradual guidance 49:5 56:5 139:2,12 183:4 208:23,25 65:25 101:14 102:3 happen health grams guide 18:1937:12 155:19229:11 7:3,19 8:22 18:20 19:5,11 60:4,4,6,8,10,11,11 157:1,2 100:11 101:2 189:14 233:4 234:2 23:3 24:22 29:12 30:3,12 157:10,12,16,19,25 159:17 guides happened 33:1,5,21 39:1 49:20 52:8 159:18 101:4 61:5 66:24 170:19 172:3 73:25 74:6,23 79:20 80:14 grandstands guinea 209:15 245:24 80:19,21 81:11,22 82:2,6 45:13 145:14 happening 82:12 84:15 85:1,3,16 86:5 gratefully guy 172:2 214:1 86:10 87:13,20,24 88:13 101:13 102:2 273:11,15 happens 89:6,7,10 90:3 109:23,24 great h 51:6 67:5 87:9 137:6 110:8 132:22 143:8 153:18 11:25 159:15 183:11 half 156:16 181:16 229:24 168:1 200:15 244:16 224:10 231:22 274:3 3:23 15:7 21:9 25:12 77:13 238:24 253:6 255:14 284:4 260:25 261:4,11,21 262:6 greater 170:22,22 greatly 92:8 99:14 133:7 157:15 158:22 159:13,16,19,19 174:8 257:9 273:6 happy 19:5 48:23 67:2 161:17 263:23 262:14,20 263:2,14 281:6 healthy 78:6 79:23 96:22 137:9 greschaw 256:8,12 grew halfway 22921 hallmark 249:17 hard 249:7 261:19 harm 20:20 21:14 22:21 97:12 hear 86:20,22 250:1 256:2 273:13 281:21 283:25 heard 17:19 halowax 155:13 254:20 21:25 30:11 132:18 137:13 grind 154:8 gross 231:7 49:2,7 67:24,25 68:10 69:18,20 137:23 140:18,20 halowaxes 67:22,23 137:21 139:10,17 harmed 254:24 harmful 12:11,22 14:1623:11 37:8 209:19 246:21 271:18 heart 8:3 21:3 232:15 heat group hand 53:22 124:24 135:21 35:17,1843:17,18,18,21,22 5:17 19:9 31:18 58:6 90:14 90:21 109:15 115:3 116:15 56:1381:1291:7,8 112:9 120:4,24 122:8 289:24 159:10,23 160:21,22 176:16 198:14,14 243:1,3 44:9,13 52:11,13,25 54:21 99:18 105:14,15,20,21,24 116:18,20 120:22 124:16 124:17 134:16,17 144:18 handle 35:9 249:17 harmfulness 106:2 107:7 117:5 126:13 147:3,4,5,18 162:18 168:18 144:18 152:17,19,21,22,24 153:9,22 154:6 194:4 handled 19:11,24 40:21 41:1 143:5 160:14 169:5,16 172:2 182:25 183:2,9 188:1,17 189:11 WATER PCB-SD0000033260 [heat - incident] heat (cont.) honest 221:12 242:1 249:19 32:22 70:4 72:3,12 88:21 260:18 285:11,24 142:12,23 143:5 173:21 heated horse 43:21 96:3 103:16 168:22 68:3 198:24 242:19 260:4 278:5 hospital 283:16,19,20,23 284:1 4:22 5:3 7:2 8:24,25 38:20 285:19 45:1 77:8 heating hospitality 168:23,23,25 260:8 285:20 56:24 held hospitalized 6:22 8:8 52:19 help hospitals 12:17218:25 6:21 9:1 221:21 222:5 henry hot 57:9 31:10 52:12 66:4 103:14 hepatitis 168:25,25 181:17 198:8 49:22 50:2,5,6,8,12,13,16 247:8,9,13,14 260:18 51:22 53:9 54:1,9,18 87:12 285:24 herbicides hotter 47:24 286:1,5 hereto hour 289:22 242:25 243:5 hereunto hourly 289:24 244:23 high hours 21:5 29:9 51:23 78:2,3,4 1:19 65:21 139:25 140:2 79:9 85:13 93:8 96:2 100:3 145:20,20 147:1 151:19 147:18 148:5 154:17 152:3,6,7 155:15 159:23 172:25 228:7 248:5 house 269:21 271:23,24 272:9 45:2 134:25 135:4 273:1,5 hudson higher 196:18 70:1 90:16,21 176:24 huh 178:14 265:12,14,15,25 69:9 132:25 186:5 251:5 266:1 284:14 271:22 highly human 265:6 271:23 272:9 22:20 60:7 82:12 84:15 hire 85:4,16 89:11 136:9,9,13 32:5,13 140:4 146:2 158:1,14,25 hiring 159:2 174:15 228:14,14 32:6 242:5 249:9 253:3 historical humans 243:9 86:2,2 88:14 135:17,25 history 140:5,11,16 159:11,13 63:19 76:16,22 79:13 262:6,15 263:14,19,20,21 hit hundred 208:17 45:18 46:4 133:2 156:25 hits 175:22 286:6,11 hundreds hmo 206:13 28:18 hung hold 209:22 6:22 85:23 204:9 hunt homes 196:12,21 170:2 hurt identify (cont.) 36:4 136:9,9 159:9 233:18 121:13 123:25 124:19 255:13 126:11 127:3 128:22 132:3 hurts 136:15 141:3 143:24 13:16,16 136:5,8 156:20 154:23 161:11 164:5 175:6 234:5,12 180:2 182:5 187:8 189:3 husch 191:3,19 196:9 197:7 2:10 290:8 199:10201:10203:16 hydraulic 204:9 205:7,15 208:8,17 19:1443:11,14,16,24 44:1 216:23 217:4 219:5 223:8 44:14 94:22 104:4 117:3 ignited 162:19 181:17203:23 285:17 286:9 206:6 221:10 ii hydrocarbon 10:16 22:12 27:24 46:7 111:9 illegible hydrocarbons 125:5,6 44:21 58:1,9,13 72:18 illinois 112:14 5:12 25:20,24 hydroxide illness 170:18 22:21 38:10,15,18 82:6 hygiene 87:1091:2 131:6 253:7 11:20,21 16:13 17:1922:16 illnesses 22:19 24:5 40:22 57:11 6:12 22:24 25:6 29:8 82:18 58:10,17 150:10,19 178:2,3 131:8 171:22 204:3 178:8 179:21 180:6 189:15 immediate 191:6 194:4 199:3 200:12 196:20 202:21 203:8 205:11 impact 211:23 223:24,25,25 hygienic imped 189:14 14:18 hygienist implement 17:14,16 31:20 179:10,15 12:17 179:19201:15205:9 implied 211:22 256:8 22:19 hygienists importance 17:21 40:11,22 146:17,24 31:12,14 151:8 152:23,25 153:10,16 important 154:2,6 179:5,7 203:5 14:12,18 15:2 16:1620:25 i 37:3 44:25 45:14 46:21 i.b.t. 124:11 149:24 178:9 167:5 192:19 228:21 233:3 234:19 235:5,9 236:8,15 idea 196:7 209:22 210:23 274:24,25 impossible 198:16 261:6 impregnating ideally 96:4 240 19 identical Q4-14 impressed 223:19 224:1,5 impression identified 103:3 1427 improvement identify 57:4,6,14,15 78:17 84:9 87:17 89:5 91:11 92:1 102:9,18 105:7 107:14 66:1 impurity 138:3 incident 109:1 111:2 114:9 115:12 116:18 117:19 120:19 47:17 168:10,12,16 170:6,8 170:14 171:3,3,6,13,19 WATER PCB-SD0000033261 [incident - intentionally] incident (cont.) individually information inoccuous 277:16 281:10,12 282:3 29:24 57:5 11:16 12:22 13:1,3,13,20 198:12,13 286:13 individuals 13:22,24 14:4,13 20:1,2,3 inquire incidents 5:17 13:1 14:13272:2 34:13,24 35:19,22 36:2,7 24:22 274:13,19 industrial 36:23 37:5,17,20 38:3 inquired incineration 8:3 11:20,21 13:14 16:12 78:16 82:19 92:11 94:7,13 18:20 108:8 189:9 123:18 129:16 17:14,16,18,20 21:6,6 94:15 95:15,23 96:9,15,21 inquiries incinerator 22:15,19,21,23 24:5 31:20 97:10,23 98:23 99:3,6 33:5 80:1 110:15 123:19 40:10,21,22 49:20 50:19 101:10,23 104:7,14,20,24 inquiry include 55:15 57:11 58:2,10,17 106:5,16,17,19,22,23,24 70:24 35:11 38:18 93:20,22,23,24 60:21,22 82:16 83:3 131:9 107:4 109:10,19,22,22 insecticide 96:9,12 103:22 142:11 131:25 146:16,24,24 110:6 112:10 115:4 119:1,2 26:1484:19210:12 162:11 165:15 150:10,17,19 151:7 152:23 119:22 123:8 124:20,21 insecticides included 152:24 153:6,10,16 154:6 125:5 126:1 127:12 130:17 62:16 244:19 11:12 38:25 67:6 139:8 154:15 160:16,23 164:8,13 131:11 132:22 133:8 160:6 inside 165:16 165:4,8,18,20 166:13,16,20 166:2 167:9,11 180:18 16:20 43:19 116:7 168:24 includes 177:17,20 178:1,3 179:4,7 187:25 192:4 193:16 194:7 insignificant 100:15 179:10,15,18,20 180:6 194:15 195:16,21,25 242:23 including 189:15 191:6 192:11,12,19 196:21 197:1 198:19 inspection 29:2 49:19 50:22 126:7 194:4 199:3 200:12 201:15 199:15,16 201:3 202:5 24:4 100:10 101:1,4 287:14 202:20 203:4,8 205:9,11 203:22,24 205:25 206:1,22 inspections inclusions 211:22,23 227:18 231:24 207:9,23 217:1 223:22 17:9,18,1823:15 50:25 233:2 256:8 261:13 225:9,14,15 239:19 instance incorporated industries ingestion 54:20 244:21 252:11 271:5 247:3 251:10 93:9 103:5 242:5 257:22 instances increased industry ingredient 50:19 52:4 145:9,10 151:23 81:21 89:2 94:19 95:12,13 144:4 institute increasing 95:25 96:7 98:15 100:14 ingredients 7:20 89:7 172:7 173:9 159:15 103:20,22,24 134:19 137:9 137:20,21 287:6 175:2 235:19,20 239:19 independent 152:20 154:10 164:1 166:4 inhalation instituted 85:10,12 99:25 100:3 221:19 222:25 223:3 49:23 99:10 103:15 112:3 15:24 135:10,11,12,13 155:2 industry's 155:16 162:9 176:20 instructed index 223:1 182:16,17 198:15 227:1 34:8 14:8 38:9 39:9,14 59:6 inerteen 228:24 229:1,2,4 242:13 instruction 106:9,14 244:8,21 245:16 42:24 119:9,16 120:8 257:22 130:18 indexed 122:24 123:11 144:4 175:9 inhalations instructions 14:7 59:5 175:12,13,18 176:18 177:9 145:7,8 31:7 82:23 117:11 119:12 indiana 177:15 179:1 190:12 inhale 124:4,11 126:18,22 127:8 89:15,18 184:18 185:9,10 inerteens 66:15 176:2,6,7,14 250:11 128:12 129:20 130:23 indicate 115:22 119:10 inhaling 193:5 207:16 253:24 254:9 64:4 86:15 infected 52:2 254:9 indicated 50:7 249:4 inherent instruments 9:11 23:14 40:9 194:18,25 inflammability 21:13 97:6 218:20 212:17 244:5 45:14 initials insulation indicating inflammable 202:22 100:20 202:1 45:16 injuries insurance indication inflammatory 9:25 204:4 237:3,5 39:1 199:12 245:25 259:7 52:12 50:4,5 injurious intelligent indirectly influence 103:17 123:14 32:21 233:24 131:14 injury intended individual influenced 11:1734:1550:18 119:15 97:6 12:5,25 22:24 24:12 38:4 154:9 196:3 204:23 231:9,10 intentional 41:7 85:7 92:4 108:6 inform 261:13 167:20,22 130:17 212:10 247:1 206:20 innocuous intentionally 265:12 268:21 280:4,10 informal 198:11 229:5 18:23 224:6 WATER PCB-SD0000033262 [interest - knew] interest iron john's kelly (cont.) 18:1030:1749:1476:1 73:9 7:1 43:5 57:2 66:6 75:4 82:9 224:8,10 irregular johnson 94:9 108:20 127:24 129:17 interested 23:3 40:20 256:22 130:20 132:9 134:10,20 39:16 48:22,25 62:1,3,4 irritants joined 135:14,18 143:23 174:17 68:13 74:11,19 78:14 105:2 155:7 61:24,25 180:1 193:4 194:6 207:14 107:7 181:18 182:12 irritating joining 216:21 222:18 224:12,16 184:21 185:13 196:24 52:1 103:9 155:15 48:6 224:19 225:7 288:6,9,14 199:14206:19217:15 irritation joint 289:10 219:12 289:23 97:4,8 137:5,5 182:1 184:1 234:7,8,9 283:3 kept interesting 232:2 jointly 38:15 39:7 152:12259:17 38:24 irwin 201:6 258:16 kettering interim 203:12 joints 99:22 143:25 144:15,21,24 192:15,19 isolated 233:17,18,20 145:5 148:23 149:7,9 intermediary 23:4 46:19 jones 180:22 34:11 issue 57:17 61:7 62:25 63:6,7,19 kidney intern 240:4 65:9,9 138:10 225:4,5 89:24 272:8 4:21 italian joseph kidneys internal 278:23 2:5 136:5,7,8,9 4:24 6:2,7,8 8:19 186:8 itches journal kill internally 234:4 7:18,19,20,21 14:5 22:15 159:2,19 173:25 124:25 items 22:22,22 23:6,6 52:5,5,7 killed internship 270:17 57:11 58:1,9,17 237:13,22 158:22 5:1 ivy 237:22 238:5,10 killing interpret 137:7 journals 159:19 239:5 262:21 interpretation 239:3,4 262:17 263:23 intervals 96:5 267:5 268:3 interviewed 32:11 intestinal 232:11 233:23 intestines 232:1 introduce 220:20 invariably 253:6 invented 73:8 195:3,4 investigated 90:14 272:19 investigation 64:5 80:6 investigator 144:2,17 involve 170:10 involved 28:2 29:13 30:15 35:13 154:11 156:1 170:8,14 involving 168:11 j 23:5 59:6 83:19 238:16 kills jack 5717 199 2 200 11 205 8 205:11 239:13 july 144:11 180:4,9,13 159:16 kilogram 60:4,6,7,8,10 157:13 158:4 january 4:4,4 9:8 27:15 58:21 10716 japan 168:10,16,17,18 169:18 june 66:6 72:16 89:13 90:2 114:18 144:11,11 185:24 187:10217:19 junk 158:21 kilograms 157:15 158:5,9,11 kimbrough 84:12,23 86:16,18 87:2,18 171:4 japanese 238:10 jurat 87:19 88:23 131:24 172:13 172:15,24 173:1,16 174:3 168:18 169:4,8,10 170:1,8 170 8 14 16 21 21 171 7 15 171 '20 20 25 172 1 5 277 4 279:5 281:9 290:14 jury 4:1,15 12:8 52:11 59:23 71:4 85:20 94:6 110:5 174:13 234:23 235:4 260:21 kimbrough's 88:15 172:21 173:13 jaundice 501 5215 53 2 5 9 249 20 249:21 250:14 251:22,22 jaundiced 114:3 137:1 168:15 177:6 235:15 236:6,9,18 212:8 227:9 237:17 246:22 kind 270:20 274:11 284:12 16:13 17:11 35:23 38:9 k 53:9 64:22 76:12 127:25 52:16 kanechlor 173:23 241:11,12 242:25 jenkins 211 290 8 jensen 207:25 208:2,22 211:1 279:4 kc 69:11 keep 246:2 247:6 273:16,17 kindling 286:8 kingshighway 212:1,6,23 215:11 26:7 38:5 122:12 124:14,23 1:22 289:9 job 9:21 23:21 45:21 61:17 1151 23624 joe 125:10 159:15 173:24 220:25 222:1,24 259:15 keller 211 knew 33:10,23 62:11 100:2 148:25 149:2 178:2 180:24 196:2 203:9,13 207:2,9,12 188:5 224:18 245:2 kelly 210:25 220:12 1:173:10,174:15 8:1442:8 WATER PCB-SD0000033263 [know - levels] know I lap leave 13:12 16:16 17:6 19:3 lab 121:5,7 124:15 139:21,25 155:14 246:10 27:19 31:19 36:24 37:3,4,6 78:11 145:5 149:9 large lectures 37:6,7,7 39:19 42:13 46:2,3 label 25:13 43:10 89:11 97:8 7:8,10 46:3,16 48:18 50:20 52:3 20:14 35:23 111:4,7,7,15 130:8 134:23 140:6 144:25 led 52:18 55:16 57:22 59:22 111:22 112:8,13 113:3,4 231:24 88:12 262:5 263:13 64:22 67:9 73:18 74:17 115:2,7,10 116:10 118:9 larger left 78:15,23 81:4 89:3,12 120:8 121:14,15,15 124:1,5 12:2 59:8 151:21 200:5 17:19,20 18:12,1427:19 91:15,17 96:10 99:1 100:16 124:6,7,9,13 128:23,24 largest 58:21 70:7 131:15 135:3,5 108:14,15 113:2,24 114:16 129:10 130:17,18,19 8:23 173:8,8 174:25 178:1 115:17 117:23 128:24 131:15 lasts 194:22 245:24 255:20 132:14 133:8,8,13,16 138:6 labeled 51:4 156:21 legal 139:16 145:15 146:20 70:22 127:19 132:6 late 115:5 147:22 148:3 149:21 labeling 39:8 46:15 47:11 52:22 legible 152:18,18 156:2,10 158:11 114:14,17 77:13 177:25 180:10 125:7 158:11 159:25 160:1 170:6 labels 203:22 204:19 207:13 length 170:22 177:15 179:7,12,21 35:19,21 111:10,14 112:20 209:9 228:21 229:6 106:20 142:10228:16 179:22 181:19 187:18,18 113:11,16 114:5 115:20,25 lately lengthy 187:20 188:9 189:1,10 116:2,21 117:11,16 118:17 274:24 149:10 190:3 193:2 194:1 196:5 118:23 119:8,12 120:13 launder lessen 197:3 201:4 202:8,12 203:1 121:19,20,22 122:9 126:13 112:19 118:14 128:18 224:2 203:10 207:11,17,25 208:9 127:4,18 131:14 193:6 laundered lethal 209:21 210:4 212:3 213:3 207:17 65:21 159:13 215:23 224:25 225:2,3,22 labor law lethargy 225:24 228:1 230:15 73:24 109:4 2:6,10 290:17 282:18 236:11 242:24 245:4,5,6,20 laboratories lawful letter 247:20 258:24 259:9,12 14:2,14 135:9,10,12,13 3:11 19:6 37:10,12,14 54:17 261:17 262:5,16,21 263:10 155:3 161:24,25 162:6 lay 57:1 78:19 79:2,6,15 265:21 268:5,6,11 269:17 164:8 174:8 175:10 187:21 20:13 86:15 87:1 213:8 102:10,20 114:12 115:13 270:13 271:13,19,22 231:5 layman's 180:3,12,15 182:3,6 185:15 275:22 276:7,13 278:17 laboratory 50:3 159:7 185:22,25 186:6,24 187:8 279:19 282:20,21,22 283:5 14:17,17,20 18:14,15 73:13 Id 187:12 188:23 189:4,7 283:7 285:22 286:15 77:23 79:7 88:7,11,18 159:12,13,25,25,4,6,8,10 190:23,23 191:4,8,15,20,23 knowing 99:21,22,24 100:1 135:2,3 159:13,14 160:1,12231:6,7 192:3 197:8,14,20,23 198:1 169:3 135:4 144:1,15,22,24 145:1 lead 198:18 199:1,7,11 200:11 knowledge 155:2,2,4 156:1 162:3,5,7 93:9,11 200:14,17,20 201:12,17 34:17,17 53:11 54:23 61:2 164:13 165:8,17,18,19,21 leading 202:4 203:17 204:11,13,20 61:9 105:5 114:20 132:16 175:1 180:22 187:17 86:12 205:8,16,16,19 206:2,18 170:16 172:6 178:24,25 202:18 236:9 262:3 272:7 leak 216:24 217:7 223:9,17 179:19 185:16 275:12,20 273:4 221:13 256:7,11 259:13,15 278:14,15 279:4 289:12 lack leakage letterhead knowledgeable 97:6 114:19 123:5 98:4 62:10,19 88:20,20 195:8 laid leaked letters 202:19 237:25 133:13 223:5 52:11,12 169:1 286:22 19:22 35:13 41:6 80:24,25 known lake leaking 193:2 217:5,9 14:1 49:20 66:16 73:7 213:11,13,14,19214:11 183:2 level 146:24 174:17,23 landfills leaks 77:9 99:14 145:9,9 146:7,7 knows 219:3 52:17 53:1 169:3 240:18 151:3,4,5 153:13 166:24 14:19 18:1645:12 language learn 168:7,21 177:3 178:11 koettering 50:3 83:18 86:15 87:1 59:12 177:12 207:11 228:6,7,20 230:1 246:4 218:4 92:22 93:1,1,5 97:18,21 learned 248:5 266:1,9 270:13 kozoriz 106:15 110:10 117:15 213:6 272:10 284:13,14,16 285:5 196:17 123:7 127:25 159:7 213:8 learning levels krummrich 214:19 184:21 185:13 99:3,7,15,18 103:17 126:16 25:18,23 languages leather 146:2,5,23 149:2 150:24 124:22 126:2,4,6 127:13 55:22 151:13,15 152:17,20 WATER PCB-SD0000033264 [levels - magnesium] levels (cont.) list long (cont.) lot (cont.) 153:11 154:7,17 159:20 35:6,7,8 39:5,7 156:4 82:6 86:8,10 99:8,9 103:10 240:9 246:5,9 247:16 250:9 166:25 167:14 177:1,8 183:11 201:24 151:16 152:15 162:10 282:4 181:11,12 190:6,20,21 listed 167:13 168:5 172:18,22 lots 209:11 218:14 233:5 248:6 9:7 37:22 39:13 70:18 174:1,15,19 183:11 200:1 55:8 134:23 159:5 171:14 252:17 264:24,24 265:2,13 116:10,21 204:24 224:8 227:6,9,11 203:6 265:14,22 266:5,6,16 268:7 listen 228:20 229:1 233:6,12 loud 268:15 269:3,9,10,10,14,17 130:15 242:11 243:15 250:18 185:4 269:19 270:6,10,15 271:23 liter 251:23 277:16 louder 271:25 272:4 275:10 279:6 176:23 longer 250:2 279:10,12,24 280:12 literature 164:17 228:4,5 229:2 louis 283:16 287:25 13:19,25 22:7 46:8,14,18 250:16 1:1,22 2:12 3:19,21 4:20,22 levinskas 46:21 47:4,9,11 49:16 52:5 look 5:3,3 6:24,25 7:2,3,6 8:6,23 40:23 41:8 54:19 82:20 83:16 84:2 32:20 42:1 56:17 59:10 8:24 10:6 15:22 19:16,18 liability 131:7 171:13,15,17,19,21 60:23 66:18 67:9 69:15 19:19 25:19,21,25 26:4,7 199:12 259:6 182:24 183:1 193:19 73:1 74:17,18 78:17 80:25 26:18,24 27:4,5,20 28:12 liable 201:24 237:8,11,12 239:12 81:4 87:16 89:4,22 91:9,24 28:23 29:24 33:1 59:8 17:5 76:4 263:17 274:19 95:4 98:1,9,21 100:4 104:9 62:13,18,21 74:4,14,22 libraries little 105:6 106:7 107:13 108:20 75:17 79:1,7 80:2 114:14 46:22 28:15 30:21 36:5 46:17 111:1 114:8 116:13 117:18 115:15 123:19 135:9 155:2 library 55:21,24 57:16 60:5 71:22 118:16 119:5,25 121:24 162:3 208:23 212:13 245:3 180:25 74:25 91:18 97:14 106:8 122:6 123:21 124:14 289:4,9 290:10 licensed 107:25 111:5 122:23 125:17 126:9,25 127:15 louisiana 5:7,10,12,12 123:10 152:1 158:5,5 128:6 132:1 136:7,15 2:7 290:19 lick 161:18 164:17 168:15 143:23 147:20,23 148:6,19 low 220:2 181:13207:9 214:7 215:6 149:14 150:15 154:20 53:1864:6 167:13 218:7,14 life 227:25 247:15 250:1 254:2 156:22 157:5 164:4 167:18 228:6,20 233:5 248:6 3:22 123:15 147:2 248:7 254:16 270:17 271:22 173:3,6 175:5 180:1,15 269:22 271:12 273:2 lifetime 273:5 275:19 286:5 185:21 188:9 189:2 190:1 287:25 168:9 live 197:6 198:8 203:15 216:22 lower lightning 3:18 174:1 217:3 234:6,18 236:22 90:17 111:15239:20 265:6 45:11 lived 245:6,7,17,23 249:2 256:6 266:15 268:17 279:6 lights 3:21 214:9 257:18 258:8 259:5 264:12 284:16 45:11 liver 266:25 270:18,20 275:18 lubricants likelihood 50:4,6,14,16 55:1 66:16 looked 43:8 221:6 268:14 70:20 76:25 77:2 79:10 74:10,16 76:25 77:1 78:6 lubrication likewise 85:9 89:24 90:19,22,23 81:5 167:25 218:9,9,21 94:23 204:25 172:25 173:22 232:3,9,10 235:24 236:1,4,9 257:12 lunch limit 232:19,21 250:14 251:22 267:9,10 269:8,9 40:18 77:4 189:24 285:7 251:22 272:8,22 273:6,7 looking luncheon limited 274:1 14:5 65:14 94:2 98:6 108:19 39:9 livers 104:11 121:6,8,9 128:9 lung limping 58:7 172:12210:10212:17 73:9 233:19 living 232:24,25 235:18 236:17 lungs line 52:20 229:21 237:12 239:6 244:8,25 232:16 24:9 loaning 271:21 lyle linger 220:11 looks 177:18 156:19 linn local 230:24 232:2 92:2 185:25 192:6 208:2 273:4 m 92:3 lipstick 137:10 located 25:19 114:13 london lost 38:20 241:13 254:2 lot 1:17 3:10 4:20 73:11 174:24 288:14 289:10 liquid 55:24 93:11,14 100:20 207:18 208:19,21 215:2 long 13:21 16:21 21:2 38:24 1 46:14 47:1 68:5,6 71:5 76:1 113:20 157:11 183:5 3:21 5:4 22:1 25:10 51:4 52:22 56:11 62:14 73:9 160:5 169:17 173:4 190:22 207:8 211:22 238:7,24 1 CM -1 Q WATER PCB-SD0000033265 [mailed - medicine] mailed manufactured (cont.) material (cont.) means (cont.) 78:15 168:19 170:17 182:2 219:1,2,3 220:10 221:22 53:18 57:23 71:5,6 87:23 main 220:15 240:10,11 279:14 225:3 229:12 231:10 90:6,13 100:19,20 109:22 12:21 42:10 44:13 129:23 279:23 287:7 240:13 241:19,22,23 123:14 148:17 150:13 maintenance manufacturer 285:25 287:10 156:15 159:13 160:20 100:11 101:2,4 259:17 42:20 184:5 materials 164:16,16 166:17 202:3 majority manufacturers 11:17 17:1 23:4 34:9 35:24 213:9 237:20 262:17,25 67:21 200:5 92:17 183:23 192:24 263:1 268:6,7 271:2 272:25 makeup manufacturing 199:16 243:20 287:15,24 282:4 90:10 9:15 16:25 23:22 24:11 matter meant making 27:18,19,20,21,22 28:8 15:2 16:21 75:1 257:16 90:21 113:8 127:16268:13 13:11 15:8 28:6 48:1,4 49:2 29:6,6 37:25 62:15 64:13 262:18 measurement 55:19 168:22,23 181:18 146:25 175:11 184:10 matters 280:19 234:10 240:23 242:3 283:9 188:24 190:7 211:10,15,20 19:11 22:15289:13 mechanical male 220:3,14 221:2,24 222:1,14 maximum 198:25 174:11 222:16 244:2 267:14 280:3 99:12 medical malignancies 280:10 mccrea 3:24 4:7,8 5:7,18,25 7:1,13 39:5 marbury 275:6 276:2 277:10 7:20,25 8:3,5,6,7 9:7,15,18 malignancy 184:17 185:8,8,9 mcs 10:2,11,14,18,18,19 11:3,7 39:18 march 44:12 162:15 11:8,10,12,14 12:7 13:10 maloney 4:6,7 10:12 98:4 101:8 mean 13:19,25 14:5,10,23 15:18 42:19 102:24 175:7 191:7 290:1,3 13:1 14:11 29:4,15 31:13 15:23 18:1,19 19:8,11,20 man 290:3,3 37:7,21 38:12 41:5 43:13 19:24 20:10,11,1221:22 8:14 16:8,17,22,24 17:12 marie 44:1 46:24 47:6 50:11 51:3 22:23 23:5,7,17,20 28:12 17:1321:8 24:1531:10 2:14 51:23 52:6 55:17 56:8 31:1 32:6 33:6,8,9,21 34:14 32:14 38:1 60:7 100:1 marked 59:15 60:9 61:9,24 64:14 34:17 35:15 37:13,15 39:12 102:4,4 115:10 136:6 56:14,15 57:1 58:20 94:17 64:18,22 67:2 68:4,25 40:12,19,2041:10,18,19 138:10 144:18 150:14 121:23 125:7 75:14 86:7 87:6,8 90:7,20 42:5,5,5,6 45:22 46:11,14 184:12 196:19 197:17 markedly 94:9 96:18 97:15 99:17 48:24 52:4,7 54:7,19 59:7,7 205:24 211:13,14212:2,11 62:5 101:18 106:20 108:15 59:8,8,12 73:21 80:17 215:21 278:24 market 114:17 121:20 133:19 82:11 83:16 84:1 89:20 management 35:4 220:20 135:22 138:6,8 139:3,15 92:21 96:14 99:4,11,23 13:1 33:1237:641:11,16 marketing 140:10 145:14,23 150:2,2 100:1 104:19 108:4 110:2,3 41:20 219:21 115:4 219:14 151:25 152:19 154:9 156:9 110:4,6 115:5 117:14 manager martin 157:2,12 159:10,13,21 129:18 130:22 131:7,12 24:20 31:4 32:12,17 37:25 30:5 31:24 32:4,8 61:15 160:23 161:6 163:4 171:14 144:25 150:19,20 155:21 78:13 184:5 200:12 205:11 62:11 172:23 173:25 174:5,7 159:25 161:1 163:14,18 220:11,15 mary's 176:13 178:18 184:7 165:10,11,13 171:13 manifestation 7:3 186:11 193:1 198:13201:6 173:10 175:1 177:18,21 230:18 massachusetts 207:8,10 213:5,8,20 218:6 178:20,22 180:4 185:18,23 manner 74:1 226:10,11,13227:11 187:23 189:20 193:10,19 54:4 167:24 massive 231:23 233:17 234:17 194:3,17,19,19 196:13,14 manual 103:6 237:16 238:7,20,22 239:22 196:15 197:17 199:3 132:7,7 133:6 master's 241:7,7,8 243:21 244:18 200:12201:13202:12,20 manuals 17:23 247:21 250:8 251:5,6,8 203:2,9,10 205:12 206:25 134:3 material 253:5,6,6 254:20,22,24 209:1,5,6,7 211:12,21,24 manufacture 20:10,17 45:20 48:2,3 255:6 256:20 257:7 258:24 219:14,22 220:11 235:20 13:9 27:12 28:1 29:13 53:17 54:14 66:15 72:21,22 267:18 268:5 270:9,16 235:22 256:20 257:3 264:5 37:18 48:19 65:20 170:18 83:6 99:18 105:1 109:2,10 271:1,12 275:18,24 279:2 264:10 172:1 224:20 225:13,18,21 109:13,14,19 115:9 121:1,4 280:2,15 283:3 285:19 medically 278:7 129:3,15 130:12 138:25 286:16 31:5 manufactured 139:1,3,6 147:14 148:25 meaning medicine 10:24 25:15 26:2,10,12,13 155:8 157:11 158:7,14 80:7 102:5 110:1 211:13 4:22,24,24 5:8 6:2,5,7,8,9 26:14,15,16,20,21 27:17 168:24 176:6,14 184:1,11 240:13 272:19 6:15,16,24,25 7:5,7,10,18 30:10 31:23 49:7 92:5 186:7 196:4 204:25 205:3 means 8:5,17,18,19 23:6 177:17 100:21 115:14 127:6 208:16 213:22 218:25 5:14,16,19 11:21,22 42:10 177:20 WATER PCB-SD0000033266 [medium - monsanto] medium methods misinterpret monsanto (cont.) 126:13 77:11,17 239:25 14:22 16:1,15 18:18 19:21 meeting mice misread 20:2,6 21:23,25 22:11 23:9 173:1,1 219:6 145:15 185:2 23:17 24:9 25:21,23 27:11 meetings michigan missouri 28:1,2,3,7 29:2,13 30:4,10 24:13 38:2 41:3 205:10 1:3,22,24 2:12 3:19 5:7,11 30:24 32:23,24 33:2,6,9,17 meets microscopic 7:20 8:6 289:2,7,9 290:10 34:16,23 35:23 36:1,6,10 238:4 66:24 232:22 misspoke 36:10,11,14,15,15,20,22 meigs mid 98:8 127:16 140:17 203:20 37:1,9,10,11,16,18,22 38:7 183:1 127:6 mist 39:1,6,1041:11,16 42:15 melt middle 144:5,6,6,7,8 145:7 149:13 42:16,20 43:25 44:4 47:15 198:16 53:20 78:1,1 141:7 222:12 149:16,17,19 48:12,15 49:13 53:12,24 member 254:3 mistake 54:6,18,25 55:5 58:22 8:1,2 9:14 211:24 midwestern 258:3 59:11 61:4,16,17,19,22,24 memo 52:6,8 mistaken 61:25 62:9 63:9,12 74:15 115:19 mild 140:14,24 75:5,7 79:25 80:13,18,19 memoranda 51:7 183:4 248:16 mists 82:10,22 83:5,13,21 88:24 61:9 military 112:15 118:10 125:1 91:19,21,22 92:6,7,17 95:8 memorandum 10:15,16 128:14 96:14 98:3 99:4,20,24 37:21 92:2,3,9 98:3 102:10 milk misunderstanding 100:22 101:4,6,9,13 102:14 136:18 216:12 61:21 103:1 104:3,19 105:3,13,23 men mill mixed 108:12 109:9 110:3,4,6 16:23 65:19 76:16 171:1 122:9 145:14,14 156:11 111:11 112:20 113:12 mention milligram 201:1 114:15 115:1,10 117:22 9:14 63:14,16 93:16 132:19 146:9,13,18 154:3 176:23 mixture 118:8,23 119:8 124:1,3 139:6,14,22 252:2 milligrams 71:1 141:23 182:12 126:13 127:4,6,18 128:23 mentioned 146:8,10,10,12,14,18,21 mixtures 129:16 130:21 131:21 30:14 33:20 34:12 39:19 milliliters 98:15 107:25 126:17 132:6,10,12,17,18 133:4,10 44:9 46:11 49:18 51:21 275:12,21,23 276:16 162:25 163:13 133:14,18,21,22,23 134:1,9 55:4 60:25 80:10 81:15 million moderate 134:13,21,21,25 137:16,18 139:14 144:13 170:7 12:15 45:18 46:4 77:14,16 83:3 160:19 138:13,14,17 141:5 142:2 172:16 178:20 183:3 213:5 77:19 266:6,7 275:13,22 moderately 142:22 144:20 150:25 234:22 235:14 236:23 276:9 277:11,20 271:24 155:23,24 159:25 161:23 237:13 246:12 249:8,19 millions modest 162:15 163:19 164:12,24 252:1 278:6 210:13 160:16,18 168:20,22 170:10,14,24,25 mentions mind modestly 171:1 172:5 173:7 174:4 190:9 84:7 262:15 160:22 175:15 177:22,23 178:18 mercy mine mold 178:19,19,21 180:4,12 7:1 23:2 98:3 102:11,11 105:16 246:18,20,22 247:3 181:3 183:13 185:16,22 messed 107:15 136:22 252:25 molecule 187:9,13,19 189:7,22,22 120:25 minimize 213:20 190:15,24 191:5,16,24 met 240:20 molecules 192:23 193:6 194:6,11,18 41:4 192:7 minor 48:7 195:20 196:14,15,25 metal 86:4 87:4 182:25 molten 197:20,24 198:19 200:13 247:1,6,7,8 284:6 minute 247:6,9 284:6 201:1,2,18 202:9 203:14 metals 21:20 30:8,19 49:9 61:20 mom 204:11,20 205:22 206:1,17 181:17 70:9 120:20 121:3 158:20 193:25 206:21 207:17,11,19211:6 metastasize 179:24 185:3 204:9,15 money 211:6,7,17,18,19,21 212:9 173:24 212:20 214:9,10216:11 38:19 212:15,16,18,19,24 215:9 meter 288:4 monitor 215:14,14 217:6,7,15,20,22 146:8,8,18,19 154:4 minutes 29:12,16 217:25 218:15219:1,9,10 meters 108:11 207:8 215:7 219:6 monitored 219:21,23 221:1 222:7,15 146:13,21 255:20 30:1 244:5,16,19 223:3,13 224:20,24,25 method mischaracterizes monsanto 225:2,10,17,20,22 226:4,6 17:10 177:14 178:3 244:11 1:124:2,9,10,11 9:4,11,22 230:4,5 231:4 232:7 235:15 11:5,18,24 12:12,16 14:4 236:8,17,24 237:1 240:10 WATER PCB-SD0000033267 [monsanto - observe] monsanto (cont.) n needles northwestern 243:14,25 244:5,22 245:1 n.i.o.s.h 50:7 165:9 173:11 235:21 245:22 246:2 251:10 256:7 89:8 needs nose 259:1,18 267:13 275:5 n.i.o.s.h. 234:15 254:22 278:24 279:1,7,8,11,13,24 89:17 90:2 264:12 272:14 negative notarial 280:11 287:8 nader 90:19 272:25 273:1,7 274:5 289:1 monsanto's 222:23 negligible notary 10:10 11:1028:1033:4 naked 147:14,16 241:23 242:1,23 1:23 3:5 288:20 289:6 38:11 49:1 116:3 118:17 245:13 neither 290:4 129:18 149:5 183:21 name 289:18 notation 187:25 197:16201:13 3:1522:1941:1343:25 new 125:22 205:12 220:6 223:14,20,23 44:4,8,8,13 100:13,19,19 2:77:18 14:12,18 17:14 notch 223:25 224:1 278:7 116:22,23 118:1 120:11 23:5 32:10,11 52:23 54:21 73:11 month 174:18 184:11 189:10 55:18 56:1 74:1,1 121:19 note 53:7,23 173:8 194:24 196:19 224:18 159:7 162:24,25 163:12,13 79:14 months 278:24 197:17 208:8 212:20 noticed 16:7 99:10 138:19 145:24 names 223:11,14 248:14 286:18 14:16 152:1,1,4,8,11,11,12 26:7 42:22 43:2,23 44:11 290:19 november 185:24 229:3 245:7,14 73:19 101:16,18,19 162:13 newly 125:21 166:16,22 200:13 277:17,17,18 194:24 4:8 200:20 219:11 220:7 morning naming news 289:25 141:12216:16224:16 147:9 69:15 148:6 number 288:7 naphthalene newspaper 11:19 12:24 13:1837:2 morphological 46:9,10 47:25 49:8 50:13 207:21 44:12 57:2,17 66:23 67:6,7 58:7 67:23 140:21 newspapers 71:2 85:6 91:14 108:23 morris naphthalenes 208:18,19,19215:1 109:6 121:8 131:9,11,13 40:20 46:23 47:5 67:19,21 68:6 nice 134:23 141:15 159:10,13 mortality national 49:5 160:1 163:12220:1 231:22 173:25 7:19 9:18 89:7 172:7 night 257:21 261:24 273:21 motive 239:19 90:24 272:24 273:12,15 numbers 154:9,10 nature nilly 147:9 160:12 173:4 267:19 motor 29:8 38:18 110:16 276:16 160:24 203:1,17,25 204:20 nausea nine nurse 205:9,16,20,23 206:2,8 199:19 259:10,23 282:17 63:6 110:9 24:25,25 25:4 207:14,19,2 256:8 282:23,25 nod nurses mouth nauseated 214:22 24:22 231:8,25 282:11 52:25 non o move 234:9 moved near 45:10 neat 6:9 28:16,19 39:3 141:17 213:8,9,23 nonbiodegradability oath 172:24 289:14 object 85:5 139:23 murray nebraska 2:6,6 31:25 36:8 45:24 54:2 173:10 235:20 56:16,20,23 63:21,23,25 necessarily 218:19 nonsense 240:9 nontoxic 36:8 45:24 54:2 86:11,17 91:6 132:13 133:12 190:17 223:4 241:5 244:10 254:11 264:7 272:13 279:19 69:4 70:7,9,11 85:17 86:11 273:23 60:3,18,19 70:24 71:12 objection 86:17,23 91:6 125:4,9,14 132:13 133:12 153:20 184:23 190:17 204:18 213:17 216:24,25 223:4 necessary 92:14 245:19 neck 248:21 72:4,13 normal 90:8 206:15 225:12 254:9 266:16 268:16 272:3,4 86:20,22 254:15 279:18,25 objective 234:6 objects 224:15,17,18 226:1 244:12 need 274:2 278:6 247:1 254:13 255:20 261:25 264:11 265:16 276:8 281:10 285:15 288:3,6,12 290:17 66:23 73:18 86:22 91:15 96:9 99:1 129:24 134:3 141:17 149:21 156:3,10 184:23 245:8,20 normally 228:10 256:24 257:2 259:14 north obscure 52:5 observations 58:11 mutual 199:12 259:6 needed 17:8,9 134:5 2:11 89:9 290:9 observe 234:15 WATER PCB-SD0000033268 [observed - ordinary] observed October (cont.) okay onboard 90:6 270:16,25 271:7 196:15 197:21 216:19 7:16 9:10,20 17:25 22:1 41:2 observing odds 26:6 30:7,20,21,23 36:19 once 234:1 266:19,21,22 267:4 268:2,6 40:14 45:7 46:2,7 50:2 15:1 16:10 35:9,22 159:10 obtain 268:10,11,13271:13 56:25 59:18,21 60:23 65:17 221:22 11:16 14:3 215:10 224:21 oettingen 67:1,4,12,15 68:16,22 69:2 ones 225:14 236:25 73:10 174:18 175:9,17 71:20 72:11 73:5,20,22 12:21 32:10,11 42:18 92:20 obtained 176:17 177:8 178:5 186:10 75:13,23,25 77:9 81:2,20 94:1 126:23 139:7,10 12:22 13:3 19:20 193:16 193:8 84:6,8 85:15,18,24 86:9,14 156:12 206:9 253:12 225:2 239:2 offending 87:11,16 88:5 90:11 91:19 267:21 obvious 64:6 94:13 95:21 96:8,14 97:14 ongoing 90:13 245:12 offhand 98:19,21 99:15,20 100:25 192:9,22 obviously 274:22 277:8 102:7 103:25 105:10,22 ons 24:20 32:9 34:4 48:22 50:7 office 106:12,15 107:19 108:17 121:19 52:15 54:13 62:3 66:3 74:9 18:25 19:2,13,19 39:4,11 108:17,20 109:18 110:18 open 74:16 76:14 78:12 81:7 40:16 205:10 207:17,18 111:13 112:1,4,10,13 114:2 16:20 51:2,20 53:23 66:2,4 92:19 109:21 124:2 133:20 208:20,21 215:2,2 223:12 114:5 117:1 119:11 120:13 147:13 183:9 221:4 240:25 143:8 169:13 183:21 190:8 223:14 271:14 120:19 121:12,13 122:6,16 241:20 283:23 284:1 218:22 231:25 232:13 offices 123:24 124:19 126:25 opened 234:8 249:2 253:7,9 254:4 1:21 2:108:8 33:1540:17 127:11,15 128:11,20 51:1,9,9 270:19 273:16 286:3 108:5 207:17 289:8 129:13 130:20 134:8 opening occasion official 136:24 137:2 138:12,20 96:3 29:19 75:16 91:21 140:9,22,24 141:20,22 operation occasional officially 142:1,4,7,11,25 143:14,19 106:10 194:1 8:20 75:14 261:15 10:10,12 133:9 144:13 145:17 147:24 operations occasions officials 148:16 149:5,18,25 150:3,3 95:24 221:4 249:20 254:4,6 212:12 151:16 152:9 153:3,9,22 opinion occupational oftener 154:20 156:14 157:9,23 54:3,7,11 82:10,14,21 83:1 4:24 6:5,15 7:10 8:4,18,21 15:3,4 16:11 158:12 159:4,7,4,9 161:1 83:12,22 130:21 131:3,5,20 8:23 9:25 10:1 22:14,25 oh 161:10,21 162:16 165:14 138:8,9,10 163:25 166:8 28:16,19,19 31:8 38:18 12:19 14:7 24:4,24 30:20 166:11 167:2 170:3 171:2,9 193:9,14 235:17 260:24 52:6 72:24 89:7 153:18 34:2 39:21,24 43:7 44:17 171:12 174:3,21 175:5,12 261:3 276:25 277:3,4 200:15 46:12,24 59:5 61:13 62:11 179:23 182:4,7,10,22 279:10,17,21 occupationally 73:20 78:12 80:3 82:24 185:21 186:6,22 187:7,15 opinions 22:14 84:3 85:3 94:5 97:21 98:10 188:19,21 189:2,13,25 83:20 251:6,6,9 occur 98:14,18 99:17 102:17 190:11 191:8,12,23 195:8 opportunity 19:22 47:20,22 53:2 54:12 105:10 110:24 116:1 197:14 198:6 199:6 200:2 284:20 74:13 204:23 240:8,17 119:24 121:10 122:4 200:10 201:2,20 202:7 opposed 247:21 248:21,22 253:14 124:18 126:6 134:23 203:1,4 206:21 207:13,9,22 227:3 228:3 230:24 239:23 261:6 263:12 268:7 135:11 141:8 147:5 150:8 208:5 210:11 211:7,17 248:6 268:16,17 occurred 159:22,6 161:3 163:21 212:8 213:5 215:7 216:18 oral 39:5 48:1461:1974:11 165:12 171:14 174:19 217:3 219:18,21 221:1 5:22 93:9 175:22 129:16 139:2 169:15,24,25 178:8 179:20 185:18 223:8,15 225:17 236:20 orange 170:21,23,23 171:24 192:25 193:25 195:10 248:1 259:5 262:1 270:23 120:14 230:15 245:21 249:21 197:11 203:6,12 206:23 272:7,16 276:19 277:23 oranges occurrences 207:6 210:13 222:11 226:8 278:12 280:13 71:7,11,17 131:10 226:25 227:16,21 228:9 okayed ord occurring 234:17 244:3 250:7 252:23 97:25 19:13 38:6 54:23 265:20 273:18 old order occurs oil 8:14 49:3 111:25 127:21 11:1766:1999:15,17 112:17 118:12 128:16 16:19 19:14 44:21,22 45:12 159:8 160:4 162:25 246:6 172:12 234:13 237:3 232:3 247:23 248:14 160:24 168:23,25 169:2,2,4 oldest 251:23 o'clock 169:7,12,13,25 171:10 8:23 ordering 1:19,20 274:16,21 275:11,13,21,23 olliges 125:21 October 276:6,10,25 277:7,12,19 1:23 3:4 289:5 ordinary 1:18 92:8 161:25 182:11 280:20,21 283:14 143:5,16 WATER PCB-SD0000033269 [org - pcb] org overexposed paragraph pathologist 290:12 51:23,24 52:3 63:24 70:7 79:22 86:1 88:8 236:4 organ overt 98:22 114:21 122:21 130:1 pathologists 136:3 90:13,13272:18,18 130:1 137:25 185:6 186:13 85:9 236:21 organic overview 186:14 188:4,10,13 199:22 pathology 92:4 211:10,14,18,19 209:16 199:23 200:1 204:7,10,10 66:24 173:11 235:21 organisms oxidation 204:16 223:17 261:22 pay 214:9 232:5 paraphrase 130:16 274:2 organization oxygen 190:2 payroll 11:12,15 16:1 23:20 178:22 21:18,18,19283:21 paraphrasing 31:3 194:2 207:11 222:19 organizations 7:23 8:9 168:3,4 organs 231:20,22 232:9 oriented 22:14 original 215:10 originally 4:3 6:3 125:24 259:15 originals 125:10 Orleans 2:7 290:19 os 44:11 162:15 osha 146:17 153:15,17,24 osland P 86:17 pb package 111:23 113:19 packaged parathion 26:13 pardon 156:9 pbb 84:17,20 115:9 63:22 161:14 226:12 pbbs packing 199:16 240:19 235:25 249:13 257:1 264:16 266:20 269:24 86:3,6 pc page 63:21,23 65:15,15 69:4,7 277:24 281:5 part 156:9 213:6 pcb 70:6,13 73:1,3 85:17,19 86:1 88:6 90:4 95:18,19 98:21,23 100:9 101:13 3:12 4:13 9:11 18:23 24:2,4 25:2 36:25 41:1 61:17 75:11 77:14,15,16 81:7 27:25 29:3,4,20,23 30:12 30:14,17 33:1,2 44:8 48:10 48:11,16,1749:1650:15 1021 2 20 104 10 15 15 16 104:17,18,18 105:16,20 156:9,9 220:13 226:14 229:14,14 236:24 237:7,11 54:25 55:23 59:20 62:15,22 64:4,11,17 67:25 68:9,10 106:9,11,14 130:1 137:25 141:7 142:24 143:2 181:20 183:16 186:12,15 204:12 248:22,23 267:24,25 271:20 285:11,12,25 particles 69:5,12,20,22,22 70:5,18 71:11,1274:3,11,13 75:16 75:18,21 76:17 77:24 79:7 257 18 267 1 269 20 23 25 270:1 275:8 212:21 particular 79:10,12,20 80:2,14 81:22 82:1 85:11 88:19 89:18 5:18 11:13 16:18 17:13 90:3 93:19 98:24 100:14,16 78:25,25 ought 33:8 66:22 70:1 178:9 183:9 184:4 198:24 201:8 209:17 269:15 284:12 ounce 60:5 ounces 60:12 outbreak 49:12 60:24 61:3,14,19 63:15,17 65:4,7 138:5 outfit 81:14 195:12 outflow 218:22 outline 177:11 outside 6:19 14:2 15:6 56:6 113:21 113:25 133:22 171:6 175:1 221:11 232:17 286:20 95:18,22,22 130:11,12 132:4 19:14 23:25 25:6,7 28:16 30:15 38:6 39:10,15 46:6 paid 31:3 163:23 179:2 226:14 56:3 75:15 94:18 95:12 109:15 117:7 135:24 137:4 pain 233:13,14 234:7,9,11 283:3 155:25 159:14 182:12 208:7 223:16 233:1 279:12 paint 279:22 287:4 144 8 203 8 paints 43:10 94:24 221:6 particularly 74:18 76:8 79:13 163:3 199:14 palmer 259:6,22 pan 53:19 169:7 241:24 parties 289:19,22 parts 77:18 213:20 264:25 265:3 pancakes 266:5,7,11,14 275:13,22 169:5 170:1 172:3 papageorge 19413 209 2 220 14 paper 276:9 277:10,20 286:1,10 passed 161:8 patch 43:11 150:16 173:15 96:25 97:5 135:17 136:19 215:10221:5 137:1,3,8,11,19 139:20,21 140:13,15,16 100:17,23 101:3 102:23 104:4 105:14 106:1,2,3 107:24,25 109:14 111:5,6,8 111:25 113:8,16,19,20,23 115:21,24,25 116:3 117:4,5 117:6,8,12 118:6,18,24 119:9 120:9,12 123:17 126:13 127:5 130:25 131:8 141:17 143:4,5 151:16,18 152:5,17 155:9,10,25 156:4 156:6,7,24 158:13 162:1,12 164:1 167:6 168:18,18,20 168:22 169:8 170:16 172:9 175:13 176:17 181:16 188:19 189:11,19 193:10 194:12 195:1,17,20 198:4,5 198:21 200:25 201:1,3 203:23 206:5,6 207:19 208:17211:1,2,14212:16 216:3,4 219:12 220:22 221:10224:1,3 239:16 244:17 249:9,17 250:23 oven 55:19,20 96:4 overbroad 254:12 1 54-1 paracloranaline 17:4 patent 195:6,6 258:22,23,25 259:1 pathologically 175:24 251:15 258:3 261:4 264:25 265:14,14,22 266:10,17 269:3 271:18,18,25 275:10 275:13,22 279:5 281:11 WATER PCB-SD0000033270 [pcb - physical] pcb (cont.) pcbs (cont.) people (cont.) persisting 286:14 217:12,16218:1,16220:16 253:16,19,19,24 254:6 207:12213:7 215:15,19 pcbs 221:2 222:9,16 224:20 255:11 263:12,15 264:24 person 25:1526:3,11 27:12,17,18 228:21 230:4 235:4,7,9 265:6,7 266:5,6,13 267:9 16:6 18:7 20:25 34:4 39:12 28:8 29:13 30:3,10 31:23 239:11 240:10 241:7 242:4 267:16,22 268:8,15 269:5 41:25 51:5 60:8 75:15 38:12,14 40:4 42:8,17,20 242:17 243:10 246:12,17 270:10 271:4,16,17,17,23 76:16 77:15 78:4 79:11 42:23 43:2,6,15,20,23 44:5 247:2 248:9 250:11,20,22 271:24 272:2,23 273:21 85:13,13 87:24 90:7 158:4 44:5,6,15 45:17,22 46:15 251:12,17,24 256:13 277:15,18 280:21 281:4,7 158:23 174:16 179:11 46:23 47:5,11,25 48:4,4,6 258:12 259:2 260:22,25 281:15 282:5 283:6,7,10 184:16 194:14220:1,13,17 49:19,21 50:9,11,19,22 261:8,14 262:4,20,22,24 people's 239:6,8 262:22 264:10 51:5,11,11,12,22 52:25 263:17 265:8,10,24 267:14 251:5 personal 53:10,13,18,20 54:24 55:1 270:16 271:23 274:20,21 percent 61:2 178:8 55:23,24 59:17,19,21,25 276:6,9,25 277:2 278:2,4,7 39:1 67:24 68:9,24 69:6,24 personality 60:2,17 64:10,13 65:1,20 278:23,24 279:2,3,7,13,22 69:25 70:19,21 133:2 32:15 67:18 68:1,2,12,17,19,24 279:24 283:16 284:6,13 153:14,15 154:3,4 156:25 personally 69:16,17 71:15,21,21,24,24 285:14,17,19,20,20 287:4 267:5 268:3,8,9 269:21,21 32:5 58:19 75:6,20 72:3,5,8,10,12,18 74:23 peaked percentage personnel 76:1,5 77:8,9 78:4 80:21 49:13 172:25 268:14 269:17 15:2 82:7,12,15 83:16,21 84:16 pediatric 277:6 283:7 persons 84:21,24 85:6,8,16 86:2,6 6:11 percentages 275:12,20 86:10 87:4,15 88:12 90:6 peer 107:24 person's 91:4,19 92:12 93:3,17,22 150:12,13 237:14,18 238:4 peregrine 266:10 93:23,24 95:9,15 96:16,21 238:25 239:12 214:15 pesticide 96:24 97:1,10,19 98:16,18 peers perfect 217:8 100:24 101:11 102:14,24 5:24 238:9 240:16,16 ph.d. 103:1 104:7,24 106:6 108:1 penachlorophenol perform 73:10 174:24 108:13 109:16 111:11,22 47:24 55:10 45:21 66:13 75:6,20 134:21 ph.d.'s 112:21 113:13 114:24 Pennsylvania 134:25 135:21 145:5 165:5 145:3 115:14 116:21 118:22,23 179:22 192:2 167:5 175:18 pharmacologist 121:17,22 123:2,12 124:3 people performed 18:7 124:23 126:15,16,17 127:8 10:9 12:4,5,14,23 13:2 76:13 89:17 135:6,9,18 pharmacologists 127:18,21,22 128:23 14:14,20 15:9,24 17:20 144:21 146:1 155:20 18:4,6 130:24 131:13 134:4,17,18 18:3,5 19:2 20:20,20 21:4 162:21 165:2 166:13,15 pharmacology 134:22 137:20,22 138:21 26:23 29:5,5,6,15,18,25 167:3 287:20 8:2,11 84:13 139:4,5,8,12,14 141:14,20 31:15 33:10 35:16 38:13,24 period phenol 141:23 142:6,12,15,23 45:13 46:5 47:17 48:1,23 5:6 26:25 27:11 40:4 49:24 26:20 244:19 143:11,15 144:3 145:12,18 49:25 52:3,13,15,18,24 75:21 99:9 145:18,21,22 phenyl 146:3,5 147:3,8,12,18 53:3 55:10,11,1961:6 152:11 168:8 188:24 64:3 148:22 150:24 151:13 62:13 64:12 74:2,9 76:5,10 210:15 216:10 226:1 227:2 philosophy 153:14 154:2,3,4,7 155:1 78:1,1,6,8 80:4,8 83:6 87:3 227:14 229:3,12 233:6,12 129:18 156:23 158:25 159:21 87:25 90:1,16,17,21,25 248:6 250:12,19 phosphorous 160:2,12,14 162:18 164:9 101:20 115:5,5,5,6 118:9 periodic 26:15 29:6 202:16,16,16,18 166:4,25 167:9 168:6,7,11 119:15 135:21 137:18 15:19 23:18 28:22 29:2 phrase 169:10,12,13,14,22,24 138:24 146:25 149:3 41:3 74:5 75:5 178:15 54:4 170:8,11,14,15,21,24,25 150:21 153:6 154:16,19 periodically phrased 171:1,4,7,20,25 172:5,5,8 168:17 169:19 171:3,7 39:20 261:17 278:9 172:18,22 174:14 175:16 172:19 173:12 179:12 periods phraseology 176:2,7,7 178:7 180:19 182:24,24 184:5,7,8,10 204:24 227:3,14 97:22 106:21 127:20 181:22,23 182:12,15,21 186:8 192:7,7 193:17 permanent phthalate 183:13 188:20 189:20 207:11 209:22,23 210:24 50:8,17,18,22 51:2,3,17 141:16 190:10,15 191:10 192:13 212:10,13213:2 215:14 permissible phthalic 192:20,24 194:8 195:4,4,9 217:5 219:12,23 230:14,17 58:13 150:24 245:4 197:4 201:25 202:5 206:22 230:17 231:1 236:8,8,16,22 persist physical 207:25,12 209:9,11,13,14 237:23,25 238:17 240:3,8,9 51:8 10:3 15:19 16:3 28:11,22 210:3,8,16211:10213:1,7 243:9,17 245:7,8 246:9 persistent 29:2 37:23 54:8 76:23,23 214:1 215:15,19216:10 249:19 251:7 252:2 253:7,8 123:13 89:23 91:13 198:20 199:15 WATER PCB-SD0000033271 [physically - precautions] physically 29:15 physician 4:4 8:22 9:23 24:24 25:1 30:1 32:1861:11,12,15 74:10 75:10 79:1 physicians 13:15 24:21 30:2,24 31:6 32:6,25 62:6,9,20 72:24 146:25 150:17 154:15 244:14 pick 220:16 270:17 271:11 picked 151:1,8 208:18214:8 220:14 picking 270:13 picture 113:22 piece 139:24 238:9 pieces 270:13 pigmentation 47:21 169:20 249:5,6 281:16282:7,15,16,19 pigs 145:15 pile 286:8 pimples 51:14 248:25 pine 10:21 pint 21:10 pints 280:18 pipe 16:20 43:20 pipes 168:24 240:14 pitched 134:14 Pittsburgh 175:11 179:16,17 182:9 place 129:10 places 47:20 221:8 placing 116:2 plain 117:6 plaintiffs pliofilm positive 1:8 2:5 3:2 224:19 139:24 88:7,11 90:18,22 133:2 plan plugged 139:19 262:3 272:21 219:16,17,18,22 220:7,24 52:17 276:12 plankton plus positively 214:9,12 206:7 277:21 263:13 planning point possibility 18:13 167:22 83:3 85:10 146:12 147:21 21:1497:7,12 121:18 plans 148:2 149:4 206:25 225:23 154:16 204:5 241:15 135:3 232:18 240:22 242:2 possible plant 252:16 271:3 274:25 283:9 12:22 23:10 33:5 39:16 4:3 9:24 10:3,5,6,6,7,23 pointing 58:11 76:5 94:23 154:9 11:14,24,25 15:6,8,11,19 111:16 190:5 200:25 243:25 244:3 15:22,23,23 16:18 17:3,11 points 253:1,3 18:24,25 19:4 23:15,18,22 238:2 247:18 266:12 possibly 24:6,8,10,16,18,20,21,24 poison 123:13 132:14 133:16 25:1,1,2,2,10,12,13,18,19 9:16 66:16 137:7 160:25 135:21 225:14 25:22,23,24,24,25 26:11 poisoning post 27:1 28:12,12,15,16 30:1,2 232:4 250:23 6:10,11 30:5,24 31:2,3,4,6,22,23 policies pot 32:6,12,17,20,24,25 33:1 12:17 15:17 285:19 286:3 34:5,6,6,8 37:5,25 39:6,10 policy potential 39:11 61:3,4,11,12,15,19 15:13 18:18 20:3 28:10,21 20:19 35:5 42:3 74:5 107:6 61:23 62:2,6,7,7,8,9,10,20 33:4,16,19,24 34:12,14 135:24 175:8 176:16 62:21,21 63:3,4,15,19 35:24 37:16 41:19 42:6 184:20 185:12 204:23 64:25 65:5 74:4,4,22,22 115:24 231:9,9 75:10,11,17 78:7,13 79:1 political pound 79:23 80:9 110:21 115:15 6:24 60:7 123:18 157:15 158:1 115:15,16 123:19 131:16 polybrominated 158:14 137:14,15,16,17 181:13 84:17 86:3 pounds 183:12,18,19,20,21,23 polychlorinated 45:18 46:4 60:7 125:23,23 184:18 185:9,10 186:8 84:16 123:1 280:13 134:7 158:4,9,10,11 210:13 190:7,20,21,22 218:22 polymer pour 220:15,15 240:17,21 197:18 246:25 244:14 245:3 246:4 polyphenyls poured plants 127:20 284:6 11:13,14,20,24 12:2,3,15 pool powder 14:22 15:7,15,21,25,25 40:18 137:10 167:23 16:4,13,16,23 17:1723:16 poor poydras 25:14,17 26:2 27:8,23 64:3,16 169:20 271:11,15 2:6 290:18 28:23,24 33:15 34:4 38:11 282:7,8 practical 38:22 82:17 115:8,13,14 pop 184:22 185:13 193:11 218:10,23 220:19 194:1 practically plastic population 71:12 72:4 97:1 246:25 89:11 268:16 practice plasticizer portfolio 5:8 8:16 14:21 22:2 223:2 26:17 43:7 96:25 10:14 practices plasticizers portion 12:17 221:6 112:7 pre plastics posed 46:7 165:8 94:24 197:18 256:16 preamble please position 80:23 3:15 7:22 12:8 123:21 4:7 218:13 precautionary 148:12 196:11 206:20 positions 115:20 237:16 6:22 precautions 24:16 35:20 65:11 72:17 WATER PCB-SD0000033272 [precautions - proven] precautions (cont.) prevent problems (cont.) products (cont.) 96:6 109:25 110:9 118:8 11:1733:1034:1537:8 54:8,16,25 55:1,2,3 56:8 162:12 164:1 165:7 184:22 125:3 138:21 143:6,16 65:18 93:15 123:4 196:3 81:11 85:16 88:22 149:2,6 185:14 187:18 193:10,17 164:2 166:5 178:6 179:1 205:2 218:21 237:3,5 159:16 169:20 176:16 197:18 206:24 207:19 193:8 206:15 prevention 193:17 203:7,7 221:13 220:21 229:8 232:5 237:4 precise 6:17 226:2 233:23 243:10 244:4 professional 129:25 preventive 249:9 250:10,14,21,23 1:23 3:4 4:16 7:23 289:5 predict 6:4 10:2 251:8,15,17,19,21,23 261:8 professor 135:24 previous 281:3,6,14,16,23,25 282:17 6:23,25 7:4,6 59:13 165:9 predominance 79:9 166:7,8 185:25 282:18,18,21 profit 235:12 previously procedure 154:10 predominant 13:7 44:18 56:14 70:17 17:2 42:5 54:14 106:25 program 248:23 153:23 181:15 195:17 177:11 10:2,4 15:23 38:25 220:9 preferable prey procedures 224:4 143:10 216:7 20:6,7 23:12 24:2,6,17 project preliminary primarily 34:20 35:8,12 37:24 53:13 220:10,12 166:17 227:7 6:12 42:12 67:18,20,23 53:24 54:6 83:22 92:12 prolonged prepaid 109:4 110:24 154:11 155:3 95:20 116:9 118:2,6 122:17 49:24 53:14 93:8 103:10 123:17 172:12 149:6 178:16 201:8 107:1 112:15,16 113:5,6 prepared principal proceeds 118:10,11 122:17 124:25 107:22 149:10 150:16 144:1,17 50:13 128:14,15 145:21,22 presence printed process 181:24 229:12,18 250:18 11:22 170:20 265:8,11 125:20,24 23:22 168:19 172:2 250:19 present printer processes prominent 2:14 83:17 138:2 168:21 97:25 232:5 18:10 48:21 73:23 83:19 170:25 171:25 209:11 prior processing 97:10 100:1 283:5 249:10 279:4 282:9 22:12 61:19 205:19 225:20 169:25 promote presented 229:7 produced 12:17 66:7 134:11 150:16 private 1:173:11 264:13 prongs preservatives 19:23 29:8 89:2 producing 155:10 47:23 privy 237:1 pronounced president 278:16 product 208:2 41:14 probable 12:11,18 13:5,6,7,15,16 proper pressure 253:3 14:19 16:22 18:20,21 20:6 98:14 123:17 178:12 21:5 29:9 43:12 53:18 probably 35:2,6,12 37:10,11 41:22 189:23 159:24 241:23 9:1 10:12 12:14 15:6 18:16 42:3 64:7 83:3 95:7 102:14 properties presumably 27:2 39:24 57:19 63:1 104:2 105:12,22 109:19 20:5 21:7 23:11 34:9,19 58:3 125:24 137:17 184:19 73:11 75:22 76:22 78:22 115:8 119:21 120:10 35:6 37:23,23 44:19,24 184:24 185:1 188:25 93:4 109:16 136:12 159:14 122:24,25 123:1,11,12 91:13 132:8 189:10 199:15 192:21 212:11 217:12 166:17 173:22 192:15 124:24 125:2 136:4,6,8,10 206:16 225:7 237:23 279:15 195:12 233:23 246:8 136:11,12,12,13 137:4 property presume 256:23 257:5,8 274:22 160:5 163:8 188:15 195:7 20:21 21:2 124:7 246:24 278:25 279:16 195:15 223:25 224:3 233:1 proposed pretty problem 237:9 254:7 257:10 280:12 237:21 39:25 48:21 89:25 92:25 16:23 20:5 34:6,7 35:17,18 production protect 94:20 120:25 128:13 136:7 49:20 50:16,20 53:7,10,23 10:23 35:9 64:3 70:5 119:20 129:24 130:17 154:17 161:8 167:25 55:4 65:2 67:16 81:22 82:2 154:13 260:18 172:25 176:20 177:16,20 116:9 128:4 137:23 183:25 products protection 178:17 194:1 202:17211:2 207:12,14217:15218:1,16 11:17,19 12:23 13:2,4,24 88:3 93:13 154:12,14 222:25 228:25 233:22 218:25 219:12,13 220:2,18 14:4,12,17,17 16:1721:23 protective 234:11 241:18 245:9 226:4 262:23 271:20 22:11 23:2,9 26:10,19,22 130:19 178:12 263:13 265:20 273:4 276:25 33:9 34:10,16,24 36:3 proved 286:11 problems 37:19 44:24 45:15,15 50:22 60:3,18 68:10 70:20,25 prevalence 13:12 15:3 18:20 19:15 67:22 71:19 80:19 84:20 71:8 90:12 272:18 21:9 24:23 30:3,11,12 95:3 113:17 114:15 115:21 proven 31:1633:1,11,21 35:16 117:12 130:25,25 160:3 68:2 93:19 226:3 WATER PCB-SD0000033273 [provide - read] provide put (cont.) queeny ran 78:10 93:15 203:24 251:4 45:2 50:3 56:5 59:6 97:10 10:7 15:22 18:24 19:4 19:9 97:4 225:22,25 226:25 provided 101:4 102:14 109:3,4 41:13 75:11 245:3 226:25 235:6,7,7,7 274:1 193:5 195:14 207:17 225:9 113:16,20,22,25 114:5,22 question random public 114:22 115:8,9,20 117:12 19:4,10,1021:1030:9 36:9 25:7 1:24 3:5 7:19 10:8 23:3 118:8 120:22 121:1,19,22 36:17 37:10 38:23 42:4 ranked 52:8 73:25 85:1 167:10 128:24 130:16 137:6,7,9 45:25 54:3 56:9,11 76:3 165:12 288:20 289:6 290:4 139:21,22,23,23,24 140:1 80:23 81:8 82:24 86:11,25 rashes publication 147:6,12 155:7,14 159:22 91:6 132:14 133:12,17 14:15 20:4,14 57:8 84:14,15 167:22 169:6,7 175:22 167:12 186:2 190:18 rat 149:14 150:9,13 151:6,12 197:13 206:7,9 213:10 193:13 202:8 204:15,22 142:22 157:12,13,21,22 186:20,23 187:5,6 188:3,5 216:21 219:3 220:10 207:1 223:5 241:5 249:25 158:4 159:3,25,25,25 168:9 189:22 191:10 246:12 254:12,14 275:9,10 174:4 publications puts questionnaire rate 7:16 13:23 22:11 23:1 147:12 89:21 206:7 256:12,16 136:17 173:18 187:20 188:10 197:1,2,4 putting 257:8,8,12,19 268:24 244:25 246:2,3 publicized 115:24 206:10 271:16,17 rated 150:3,3 pydraul questionnaires 9:1 publish 44:3,14 117:3 118:17,21,21 206:12 ratio 7:16 34:23 133:20 149:11 162:11 181:16200:25 questions 266:19,21,22 268:6,12,13 149:17,23 238:10 203:22 205:25 206:4,14 3:14 36:14 165:24 199:13 271:13 published 258:3,13 259:2 206:15 215:8 224:13,15 ratios 7:13,1522:1657:1958:1,3 pydrauls 227:8 256:15 270:21,22 267:5 268:2,10 58:9 82:19 84:12 91:22 104:4,25 105:4 115:21 288:7,10 rats 92:17 95:7 99:12 104:2 118:20,22,24 119:2 144:4 quickly 58:7 88:18 145:15 155:6,13 105:13,23 108:13 133:9,14 162:14 206:20 164:7 216:22 158:16,22 159:1 166:25 133:15,16,18,21 141:11 pydraul's quit 167:6,6 168:6 172:10,18,19 142:6 149:12,13 150:7,22 44:3 64:25 207:6 246:1 172:22 173:4,18,19,22,25 151:13,15 171:12 180:23 pyranol quite 173:25 174:2,8,9,9,11 181:6 225:5 237:21 238:5 42:25 43:25 44:3 117:20 4:23 14:18,18 18:1021:5 175:22,25 176:1,12 202:18 238:15,23 239:12 263:16 118:6 144:4,5 194:25 25:4 30:16 47:8,12,20 229:7 234:24 235:5,10 publishing 195:16 55:11,14 59:1,1 62:5,17 raw 171:18 pyranols 69:12 71:25 72:10 76:10 11:16 17:1 34:9 pull 115:22 84:3 152:14 168:25 169:13 rays 25:8 49:4,4 255:24 256:3 pulled 52:16 pulmonary 31:16232:14 pump 43:13 pumps 240:18 purchased 62:9 pure 71:12 purified 213:1 purpose 23:18 29:1 33:19 34:14,15 109:21 116:2 222:24 purposes 23:19 put 35:1,20,22 43:20 44:12 q qualifications 5:20 32:19 qualified 36:11 qualities 4419 quality 2T13 78-20 quantified 277:22 quantities 48:17 159:18 182:2 216:11 quarterly 38:17,21,21 39:24,25 169:17,18 170:4 171:16 176:11 178:8,16 193:1,3 198:11 202:14,19 203:9 207:10210:2,18211:22 227:1 251:13 280:17 281:19 286:11 quote 70:6 143:15 190:2 quoted 92:13 261:22 quote's 85:25 quoting 63:18 r 150:10 rabbit quarts 198:11,12 280:19 rabbits quaterphenyls 140:6,7,8,11,12,14 145:15 169:15 170:24 171:25 176:5 172:4 275:1 277:1,7,21,23 raise 277:25 278:8,11,14 281:13 69:13 77:2 reach 198:23 239:1,7,13 240:3 245:18 reached 235:2 react 140:5 252:3,4 253:4,16 reacted 159:2 reaction 209:19 230:11,13,24,24 247:19,21 reactions 137:8 read 22:7 76:9 85:18,20 93:5 94:15 98:2 99:2 100:7,25 101:16 107:17 111:21 112:13 113:2 118:25 119:3 119:13,17 122:22 123:9 124:11 126:22,23 128:1,11 WATER PCB-SD0000033274 [read - representative] read (cont.) recognized regarding remember (cont.) 130:5,7,9,15 131:23 140:6 17:7 23:9 36:14 81:21 82:6 278:18,19 283:3 287:3 150:6,21 179:2 180:16 recollection 106:16 256:12 260:22 remove 184:14,25 185:4,5 186:19 220:5 259:20 275:14 276:5 263:17 51:5 112:17 118:12 128:16 189:25 199:21,23 203:20 recommend regardless removed 204:7,10,16 207:20 215:3 65:10,23 103:12 178:6 16:10 269:4,5,13,16 223:16 250:3 181:20 regards renate readily recommendation 240:4 84:11,22 44:24 59:3 193:23 33:13 registered repeat reading recommendations 1:23 3:4 289:5 34:20 36:19 86:23 88:9 84:7 41:17 103:1 150:23 153:16 regular 205:4 249:25 254:2 real recommended 17:18 28:25 29:1 38:2 repeated 69:4 198:8 99:13 151:15 153:11 177:1 64:23 75:4 53:14 93:9,10 103:10 reality 177:8 181:23 219:22 relate 106:25 112:2 113:5 175:24 70:25 record 109:13,14,15 134:17,18 181:23 205:1 228:24 realize 3:16 56:18,23 79:2 84:10 related repeatedly 230:18 84:22 143:24 180:16 19:4 33:1 40:4 48:24 57:10 204:25 229:20 realized 199:10 224:18 279:18 67:13 68:4 74:6,23 80:14 rephrase 121:17 288:3,5 289:16 80:19 81:22 82:2,7 250:22 86:14 really records 289:19 rephrasing 18:8 20:25 24:14 55:13 25:8 29:21,22,23 80:12 relates 86:12 66:22 67:2 73:11 76:7 89:20 6:9 67:16 replace 90:20 102:10 110:14 recounted relating 240:19 155:18 183:5 187:21 208:9 145:5 19:11 21:22 46:8 53:10 replacement 208:12 210:3,7 232:23 recover 80:13 95:8 104:3 105:13 220:21 270:17 275:18 220:25 106:5 162:1 164:8 187:25 report reason red 188:17 195:16 30:3,25 31:7,12 33:1 38:21 39:21 75:15 116:7 135:20 120:3,14 relation 62:21 79:5,5 81:25 84:11 135:22 166:7 229:14 reduced 34:24 38:6 78:5 80:1,21 88:6 89:6 141:4 142:1,5,11 265:23 280:5 289:15 82:12 95:15 104:7 130:24 142:18,21 151:21,21,21,23 reasonable refer 134:21 142:22 176:17 153:23 154:2 166:16,23 54:7 59:3 82:11 130:22 59:18 119:17 127:12275:8 relations 176:17 177:11 178:5 193:9 reference 10:9 181:15208:24 225:1 reasons 146:12 relationship reported 36:12 116:5 131:17,18 references 6:18 21:15 64:4 78:6 31:1,2,4 51:21 52:4 53:10 207:24 218:6 265:9 201:25 232:25 59:25 63:7 71:13 78:21 recall referred relative 131:7 176:22 181:25 7:1547:10,1253:8 61:8 25:25 34:3 62:8 124:6 265:11 289:21 208:23,25 261:3 63:2 183:6 186:10 196:17 260:5 relatively reporter receive referring 43:9 96:2 97:19 156:20 1:23 3:4 177:7 250:3 289:6 80:20 114:23 154:1 186:7 188:23 160:16,16 248:6 265:6 reports received 201:14212:5 release 22:24 23:5 38:17 49:25 4:19,20 14:13 35:24 54:17 refers 97:11 246:18,20,22 247:3,4 50:18 54:22 83:7 131:7,10 82:5 104:23 107:3 131:11 100:16 121:15250:9 relevant 143:25 144:9 149:10 153:25 163:19,22,22 refinery 41:7 150:24 151:20 161:22,23 164:24 196:19 217:22 16:19 44:21,22 remain 163:25 164:8 165:24 166:3 recertified refresh 103:12 166:19,20 168:1 180:21,23 6:3 79:16 220:5 275:14 remarkable 181:2,3,5,7 192:13,15 recess refreshes 105:17 193:18,18,20 204:4 214:17 40:8 75:3 108:19 143:22 276:5 remember 214:23,25 215:1,19 179:25 255:23 regard 27:21 36:17 49:3 75:10 represent recessed 14:21 16:12,14 20:3 22:11 81:9,13,23 82:3 133:5 224:19 216:19 28:10 33:25 81:11 83:20 139:21 147:22 175:19 representative reclaim 93:2 190:15 202:9 239:11 192:9 194:23 195:3 219:25 108:16 117:10 118:19,23 220:24 259:21 266:16 275:10 226:1 235:6 259:11,24 279:12,16 274:22 275:2,4 277:6,8,16 WATER PCB-SD0000033275 [represented - safety] represented rest right run 2:5,9 147:1 18:25 23:20 25:20 26:1 46:20 70:5 75:1 96:25 reprint result 34:11 37:1 48:14 53:4 108:18 143:20 165:9 171:1 52:9 57:8 188:2,5 77:23 145:25 172:1 230:23 69:19 70:5 72:9 91:9 92:23 179:23 224:21 225:19 reprinted 239:23 98:17 100:5 103:7 112:9 226:6,15 228:20 231:4,18 58:17 resulting 115:11 141:7 145:20 232:7 243:14,17,25 272:7 reproductive 54:20 58:8 131:8 237:4 149:23 151:11 176:19 running 281:23 251:15,17260:15 202:25 210:4 212:2,4,16,17 23:20 192:10216:14 reputable results 230:13 231:7 233:3,8 237:7 234:19 59:6 150:12 78:9,10 79:6 135:23 148:22 238:19 245:15 248:4 runs reputation 149:7 150:1,4 172:11,21 252:21 255:13,16,21 256:6 159:8 165:21 238:14 236:18 238:15,18,22 274:5 257:6 262:8 264:4 267:4 rutter repute 274:6 268:20 270:3,3,14 271:9,10 2:10_____________________ 85:13 resume 274:11 276:10,12,21 s request 206:4 277:11 278:8 279:1,1 sack 41:18 162:20 165:1 167:2,5 retardant 206:24 207:2 45:21 requested retested 144:20 155:20 201:3 163:1 rings 245:8 278:1 riseborough 215:21 55:21 sacks 55:24 113:25 safe requests 41:17 206:21 research 10:22 14:14 99:25 193:24 202:18211:13,14,20 retired risk 9:8 15:18 39:8 61:16 75:24 53:25 87:20,24,25 113:12 130:20 131:23 river 245:25 279:1 25:21 retirement roaring 20:1,6,7,9 23:12 24:2,6,17 34:13,20,24 35:8,11,20,22 36:2,6,22 37:11,17,24 53:12,24 54:6 65:10 82:22 83:21 92:11,15 93:2 94:7 219:15,22 280:10 residency 5:2 resident 4:21,22 22:5 27:9 30:11 82:9 83:17 286:11 return robert 4:14 11:5 129:2 114:13216:25 returned roderick 4:6 123:17 224:10 94:13,14 95:14,19 96:9,15 96:20 97:18 98:4,23 99:2,3 99:7,12,15 102:21 103:1 104:6,13,20,24 106:5,16,24 107:4,20 108:3,9 109:19 residue 55:14 286:14 287:2 resistance 44:20 resistant review role 23:8 39:20,23 46:7 58:19 41:10 59:12 62:24 80:24 83:15 roll 84:13 93:25 142:18 150:13 74:8 161:1,4 163:14,15 164:20 room 116:9 117:11,15 118:2,5,9 118:25 119:1,11 122:16 124:4,20,21 125:6 126:1,18 126:21,22 127:7,12 128:11 129:19 130:23 138:20 44:18 100:20 resort 164:22 165:24 237:8,11,14 237:18 238:25 239:12 53:20 55:24 103:15 131:16 147:13 241:7,7 242:18 146:2,23,25 148:22 149:2,5 151:4,5,13,15 152:16,20 13:25 respect 224:10 respirator reviewed 243:5 254:23 260:9 22:11 38:21 39:22 58:24 rotated 80:11,17,23 108:11 132:21 29:24 133:4 150:12 161:8 163:17 roughly 153:13 154:7,19 164:2 166:4 168:7 177:1,3,8 178:6,11,16,25 181:12 189:21 193:5,8 195:9,15,20 24:15 73:8 96:5 respirators 178:14 respond 256:24 257:2 274:24 reviewing 244:7 245:13 274:18 rice 32:24 60:14 63:5 146:9 148:11 155:1 157:11 158:5 158:10,19 184:2 226:7 279:23 281:4,7 284:18 198:18201:8 207:16230:1 253:23 254:8,9 safeguard 124:11 192:23 206:21 168:23,25 169:2,2,4,7,12 routine safely responded 206:23 271:16 response 110:14 250:20 253:20 169:12,25 171:10 172:3 163:1 274:16,21 275:10,13,21,23 rubber 276:6,10,25 277:7,12,19 49:6 94:25 199:17 280:20,20 283:14 ruckus 82:22 103:18 164:1 166:4 safety 12:18 13:15 16:24 20:8 23:2 24:7,10,13,16 37:22 responsibility richard 169:18 38:1,1,2,4 41:19 72:17 224:6 responsible 12:25 115:4 223:20 responsive 217:6,7 richter 236:13 rigged rule 223:6 249:23 250:4,22,25 254:5 rules 83:21 89:7 96:6 106:10,10 109:2,10,13,19,20,22,22 110:7,17,24 121:1 122:7 153:18 189:5 191:1 206:7 41:16 52:11 249:24 250:5 206:10 WATER PCB-SD0000033276 [salaried - ship] salaried schneider seen sentence (cont.) 39:6,12 244:23 2:14 207:8 55:7,15 56:2 62:16 101:12 186:13 199:21 206:17 sales school 101:25 120:16 132:15 272:17 276:14,15 12:15 33:15 35:10 108:5 7:4,7 45:1 46:11 59:7 99:11 133:6,16,24 181:15 195:19 sentences salesman 99:23 100:1 144:25 165:10 243:12 130:2 184:25 19:12 110:20 132:6 165:11,13 173:10 175:1 self separately salesmen 235:21,22 222:23 122:22 107:8 108:6 134:12 schools Selkirk seppala salesmen's 150:20 221:21 222:5 197:17 114:16 132:7 134:3 science sell September salt 4:19 12:10 69:20,20 141:8,9,10201:17 20:22 21:3 159:14,16,19,22 scientific selling sequence salt's 14:5 21:22 23:8 83:16 84:1 221:5 30:22 159:14 161:24 162:3,6 163:22 send series sample 213:15,17 237:8,20 238:2 35:5,14,14 37:20,24 39:5 132:4 251:7 180:20,20 181:12 239:12 240:2 250:24 69:17,21 109:6,7 110:13 serious samples scientifically 115:8 150:13 152:16 173:5 17:5 21:9 33:21 50:14 82:6 117:10213:1 217:12 62:4 150:16 238:12,14,21 181:2,5 192:3 194:6 195:20 103:8 159:16 sampling scientist 199:1 201:2 206:1 211:11 served 96:1 181:13 100:3 211:13 237:24 10:16 sand scientists sending service 246:25 247:4 150:14 151:6 207:24 214:5 181:3,7 192:18 194:11 3:23 4:6,13,14 8:22 10:13 sat 218:24 277:4 215:13 10:23 19:7 23:3 85:1 134:2 scott sends 217:11 saturated 1:6 257:3 services 155:16 scum sense 85:4 sauget 214:11 20:1331:4 119:14 136:3 set 25:20,24 seal 247:22 276:14 281:24 5:17 11:11,19 19:8 38:25 saw 289:25 282:6 53:19 56:16,17 138:8 24:18 29:22,23 38:21 52:9 search sensitive 219:18 285:10 289:24 55:11,1561:9 81:1 97:25 59:4 90:23 253:25 254:6 255:3 setting 133:8 138:12,16 153:25 seatcover 272:22 273:6 11:12 131:9 225:1,4 278:10 97:2 sensitivity seven saying second 97:4 137:5 224:6 12:15 124:22 126:6 127:13 69:3 86:9,16 87:2,3 103:4 10:21 63:24 70:13,23 71:11 sensitization 142:24 145:24 151:19 117:21 131:24 190:1,14,19 71:16,25 72:2 85:22 86:1 137:7 152:1,1,3,3,7,11,11,12 218:3 233:9 253:21 261:8,9 100:9 101:7 104:17 181:20 sent severe 263:11,12,25 265:17 271:5 188:9,13 199:22 204:10,12 12:5 33:14 41:5,6 63:6 248:19 252:25 273:24,25 285:23 204:16 223:16 242:3 69:19,22,24 78:13,14 80:8 sex says 258:16 108:4,8 110:14,15,20,22 235:8 3:12 68:23,24 69:4,6,13 secondary 114:15 116:3 137:19 sexes 72:4 79:15 85:22 88:1,6,22 255:1 141:13 142:15 163:21 235:7 111:22,23 113:4 114:21 secondly 168:1,1 173:8 180:12,21 sharon 123:10 124:9,22,22 130:13 11:1523:21 116:8 218:7 182:17 185:16,18 187:6,12 184:12 192:2 136:22 188:4 206:17 seconds 188:2,4,25 190:24 191:13 sheet 223:18 257:25 262:3,18 180:11 191:15 192:17,25 194:9,10 37:22 109:3 110:25 263:3,7,10,13 270:5,24 secretarial 196:25,25 197:23 199:14 sheets 275:19 40:18 200:20 202:4,9 205:16,19 109:2,10,13,20 110:7,13,17 scar section 205:22 206:3,3,7,11 207:1 110:22 121:1 122:7 206:10 51:16 35:1,11 40:16 78:7 79:23 211:3,7,8,12,14,15,19,21 shellfish scare 94:1,8 109:25 110:8,8 212:9 213:4 217:2,13,20 253:8 240:5 200:12 219:1,2 223:11 236:5 shepherds scarring sections 237:22 256:12 257:11 174:7 50:25 248:13 110:11 259:15,16 ship scars seeing sentence 15:5 134:8 51:9 8:20 278:18,19 88:15 143:14 184:14 WATER PCB-SD0000033277 [shipped - somebody] shipped signed sitting smaller 113:20,21,24 115:25 132:5 97:3 241:24 252:6 15:7 42:19 155:3 228:5 121:21 169:4 significance situated smallest shippers 154:5 273:3 89:9 158:17 110:22 significant situation smell shipping 21:22 83:8 86:4,10 87:13 19:20 30:7 50:15 52:17 53:21 129:15 131:16 103:15 75:8 258:22 260:5 285:23 smelling short signs situations 242:25 87:9 96:5 117:10 129:25 233:16 267:5 238:25 253:22 285:16 smith 130:18 135:8 156:18,19 silicates 286:2 57:9 59:10,13 193:22 224:9 226:18 248:6 45:15 six 201:15 shorthand similar 1:20 63:6 70:8 126:2 245:7 smoke 3:3 16:1946:23 47:18 119:2,13 sixth 255:1 shortly 123:7 126:22 188:7 206:8 70:17 smoking 225:1 222:23 257:9,12 size 254:23 255:10 shorts similarly 11:15 12:12 28:15 97:9 sneeze 97:3 184:17 185:7,9 257:16 113:18 155:19 174:10 254:21 255:15,15 shoulder simple 175:3 178:1 194:4 273:20 sneezing 234:5 177:14 sized 255:17 show simplest 114:4 soaked 84:9 90:24 136:3 173:19,21 66:21 skin 53:16 112:19 118:14 196:8 216:10 232:8,10 simplify 53:15,15 57:24 93:11 97:4 128:18 139:24 233:4 235:9 243:6 263:22 212:9 97:7 103:6,10,12 107:1 soap 272:23 280:8 simply 112:2,16,16 113:6 118:11 103:13 112:17 118:12 showed 228:4 230:11 118:12 124:25 125:2 128:16 138:24 17:2 120:14 198:12214:13 single 128:15,16 130:14 137:5,5,8 societies 231:19 232:13 235:16 103:6,7 139:22,22 140:5,11,16 59:7,8 showing sir 155:7,14 164:16,16 176:5,8 society 120:6 167:11 261:9 278:10 82:3,8 83:14,18 88:8 91:10 178:11 181:21,22,24,25 8:1,6,11,13 59:9 146:16 shown 91:25 95:6,10,13 102:8 182:19 198:12 205:1,2 224:9 123:2,12 124:7,12 232:20 104:1,12 105:5 106:2 230:8,11,17,19231:10,11 sodium 232:21 239:18,18 243:10 107:12 108:25 112:6 232:9,10,11,12 234:4 241:8 170:18 265:23 116:14,17 117:13,17 119:7 241:19,21 242:8,9 249:6 soil shows 120:1 123:24 126:10 127:2 258:6 281:16 282:15,18 213:10,11,12 93:7 198:11 128:7,21 129:6 132:2 skinker sold shrimp 144:11 154:22 165:3 3:19 45:18 46:4 48:18 105:3 167:11 214:11,12 166:10 205:21 207:6 slides 169:2 shut 213:16 224:17 226:7,16,22 173:5,6,6,9,16 235:16,24 soldering 221:19 228:18 230:10 231:13 236:2,3,5,10,17,22 203:7 sic 237:2,10,15,19 239:3 slight sole 42:25 58:14 84:12,12 240:12 242:7 243:13,17,22 122:20 259:1 208:11 223:23 243:23 244:23 246:16 slightest solely sick 252:5 253:20 254:19 196:7 54:24 153:1 87:7,15 90:10 169:17,19 256:10,14,17 257:17,20,24 slightly solid 233:21 253:8,12,12 258:1,4,7,10,14,17,24 60:3,20 103:4 113:23 198:5,7 sickness 259:8,11,19,24 260:3,7,23 sloan solidify 90:7 91:3 262:2,11 263:20 264:14,20 218:4 76:6 side 266:23 267:3,8,12,15 sloat soluability 112:9,11 223:1 268:23 269:1,7,11 273:13 191:21 192:6,16 265:24 sido 274:14,17275:17277:13 sma soluable 114:13,25 115:14 277:14 280:22 281:13 77:5,5,6 265:14 sign 282:16 284:5,21 286:7 small somebody 234:5,7 287:21,23 288:7,8 12:3 21:8 25:12 26:22 17:3 18:1932:1641:21 signalled sit 29:23 40:15 43:9,10 45:3 97:3 114:15 125:20 133:15 224:7 53:22 130:11 135:9 147:16,17 167:13 133:20 134:1 154:16 174:6 209:11 229:12 280:23,25 174:6 194:23 201:6 210:4 WATER PCB-SD0000033278 [somebody - story] somebody (cont.) speak st (cont.) stated (cont.) 217:8 218:4,5 238:13 253:7 36:11 156:3 250:1 284:20 5:3,3 6:24,25 7:1,2,3,3,6 172:24 174:16 181:24 254:23,23 255:9 256:20 287:25 8:6,22,24 10:6 15:22 19:16 182:18,23 239:15 243:18 257:11 259:18 287:24 speaking 19:18,19 25:19,21,25 26:3 260:24 271:9 somebody's 253:15 26:6,18,24 27:4,5,20 28:12 statement 183:20 spec 28:23 29:24 32:25 59:8 42:6 67:15 69:3 79:9 91:16 someplace 64:15 62:13,18,21 74:4,14,22 102:11,19 119:20 123:1 101:12,25 129:1 187:4 special 75:17 79:1,7 80:2 114:13 189:20 199:19 262:24 188:8 192:8 196:25 274:23 74:9 75:8 110:9 115:15 123:19 135:9 155:2 263:18 270:15 274:9,10 somewhat specialist 162:3 208:23 212:13 245:3 statements 35:15 47:18 68:4 129:15 5:17,23 289:4,9 290:10 131:17 146:6 168:19 170:17 specialized stadium states soon 18:5 149:20 45:10 9:2 17:1422:1723:16 142:20 269:15 specialties staff 25:14 42:21 54:20,24 73:12 soot 212:10 6:21 7:1 18:1 73:25 78:24 86:1 88:4 286:23 specialty stain 98:25 117:22 168:3 170:10 sophisticated 5:186:1,4,13 49:5 170:17 171:3,7,17201:24 77:12,17 150:19 162:9 species stand 215:20 266:10 175:21 177:20 194:3 174:5 57:2 103:9 stationed 202:17 208:9 specific standard 10:20 sore 35:16 38:15 123:10 206:19 48:1764:15 146:17 153:13 statistics 156:20 232:4 239:23 159:18,20,8 229:4 38:5 sorry specifically standing status 44:3 58:16 70:9,15 81:2 175:14 207:1 100:3 192:5,20 202:1 237:14 98:8,10 105:10 108:23 specifications standpoint stay 127:11 136:23 140:7 141:8 117:24 62:1 103:5 248:2 51:25 52:2 97:19 147:10 150:11 164:21 specifics stands stayed 177:5 178:19 184:8 198:14 259:21 202:24 4:5 199:7 200:9 203:21 204:19 speculate starch staying 205:22 209:6 211:6 219:10 247:14 264:10 279:15,16 146:11 214:3 251:20 256:2 269:23 275:4 279:19 start stays 281:21 speculation 13:11 46:25 67:6 88:10 213:23 242:9,11 sort 279:20 280:1 95:18 112:20 114:12 stenographer 9:6 10:14 14:12 16:2 25:9 speicher 159:14 185:6,7 207:10 276:1 28:17 55:20,22 56:4 60:5 179:13,18 180:5 181:7,18 212:17216:15234:10 step 87:24 96:4 97:8,13 113:22 182:6,7 184:4,9 185:19,23 269:15 284:14 170:18221:7 114:13 167:15 175:19 186:7 187:9,16,24 191:4,5 started steps 206:8 208:10 222:22 227:6 193:3 9:12,21 10:8 13:8 15:22 17:2 218:15,20 sound spell 18:13 21:24 27:13,20,22 stick 276:10 277:11 57:21 28:1,2,3,5 32:1,2 42:14 68:12 121:14,19 128:3 sounds spelled 52:16 63:14 65:22 96:24,24 stipulated 276:12,20 213:14 110:24 121:10 135:2 3:1 source spent 138:17,18 145:8 162:4 stomach 43:18 94:7,9,11 4:21 12:1 25:4 38:19 166:18 174:19 192:10,12 233:21 south spills 206:10,11 231:1 286:20 stop 1:21 3:19 289:9 123:5 125:1 240:18 starting 102:12 170:3 220:3 221:1,3 soybean spoken 4:4,18 73:1 178:23 180:11 221:14 169:5,5 170:1 86:13 185:5 stopped soybeans spolyer starts 52:17 221:4,5,7,9,10,12,23 169:6 52:7,20 67:15 248:20 286:6 221:23,25 222:11,11,13 space spray state 267:13 145:18 238:6 144:8 247:4 1:3,24 3:15 5:7,10 52:6,6,8 stops spaces spread 153:4 179:21,21 215:25 232:15,15 53:17 107:2 248:20 289:2,7 story spaniels St stated 145:2 212:7 174:7 1:1,22 2:12 3:19,21 4:20,22 60:2 83:9 103:3 139:1 WATER PCB-SD0000033279 [straight - sworn] straight subacute summarize surgical 26:8 164:15,16,19 6:20 7:22 102:25 180:17 6:9 straightened subject 220:5,6 surplus 210:21 75:1 83:16 115:19 145:17 summarized 219:1 strain 178:25 193:24 194:7 195:9 79:21 surprise 173:4 174:8,11 207:5 summarizing 70:23 strains subjects 189:21 surprised 174:9 7:14 summary 209:25 210:2 strange submit 79:22 90:4 surprises 28:15 5:21 152:16 summer 166:6 streams submitted 144:9 surprisingly 219:4 175:9 sunlight 182:1 street subscribed 285:25 survey 2:6 290:18 288:15 superintendent 11:20 12:6 16:13 strengthened subsequently 16:25 24:12 37:25 survive 83:24 131:23 66:1668:1,10 supervise 159:17,17 strictly subspecialty 11:23 12:6,7 40:11 survived 22:13,14 153:8 6:5 supervised 22:18 strike substance 24:7 susceptibility 45:11 45:2 46:8,11 64:6 70:24 supervision 253:10 strip 135:24 31:5 suspect 76:23 substitute supplier 218:12 strive 45:20 221:18,22,23 222:4,7 48:8 109:7 suspected 240:20,20 222:9,11 suppliers 218:13 studied substitutes 206:12 sutter 65:24 273:21 94:25 221:8 supply 8:22 studies subtitle 48:5,9 swallow 83:9 123:2,12 162:9 167:2 127:19 supports 103:5 172:8,16,22 173:21 187:17 subway 84:2 swann 187:19 192:6,9,11,19,20,22 45:4,8,9 suppose 27:16 28:5,5,7 30:6 47:13 192:24 202:2 227:10,13,18 subways 35:2 41:23 45:9 96:4 99:10 47:14,16 48:1,10,12,20 227:20 228:22,24 229:10 221:20 222:5 180:20 226:22 264:19 49:12,13 55:5,12 60:24 230:3 232:23 233:3,10 sudden supposed 61:3,12,1662:7,15 63:3,15 235:9 243:11,15,19,25 156:17 160:9 11:11 31:9,12,19 87:24 74:12 137:15,17,18,19,23 261:9,17 287:19 suddenly suppositions 224:21,22,25 225:6,7,24 study 156:21 263:11 226:1 230:9 252:12 89:17 138:23 142:12 suffering sure sweat 172:11 192:9 226:23,24 233:11,25 21:18 27:4,7,23 36:11 51:19 230:20 229:15,18 234:1,15,23 suggest 39:21 52:14 64:20 69:19,20 Sweden 235:5 238:13,20 239:2 72:16 138:20 71:6 73:1 77:20 81:8 82:24 212:11 215:1 264:12,15,17 265:5 266:4 suggested 85:23 87:3 95:17 97:1,21 swedes 266:25 267:6,24 268:21 35:4 91:13 99:7 138:22,23 100:15 104:9 106:7 108:7 212:20 213:3 216:1 269:2 273:16,21 274:5 151:2,2 184:4 113:7 120:16 127:16 129:1 Swedish studying suggestion 131:18 140:25 147:23 207:23 208:3,4,15,16,17 21:21 47:10 262:23 9:13 149:13 154:8 156:15 159:6 209:8 210:1,7,16212:14,15 stuff suggestions 159:12 161:3,7,8 163:7,9 212:23 213:6 214:5,17,20 13:11 46:4,21 47:14 53:23 58:13 180:24 185:4 190:2 194:9 214:25,25 215:11,16 60:13 66:3 69:19 72:5 suggests 202:8 203:12 209:14 210:2 278:22 96:24 123:20 133:14 186:21 211:2 212:25 213:2 215:22 swelling 155:12 168:24 169:7 173:3 suitable 224:4 226:19 233:22 250:14 175:22 198:9,16,21,24 93:12,13 234:11 239:24 240:7 switch 204:6 208:13 209:22 suite 243:24 244:3,12 246:8 168:10 220:18 222:1 232:2 243:4 2:6 290:18 247:17 257:13 263:4 266:3 swollen 260:1 261:10 285:10 summaries 267:18 270:11 275:16 234:7 styrene 202:1 276:2 286:18 288:1 sworn 64:5 138:1 1:183:11 288:15289:11 WATER PCB-SD0000033280 [symposium - tests] symposium talked (cont.) technical term (cont.) 57:25 58:2 66:7 69:14 69:14,23 87:19 129:1 35:2 92:16 94:17 96:21 251:23 266:24 72:16,25 132:20 140:17 141:12 97:19 108:10 111:6,24 termed symptom 167:16,18 180:25 183:3,11 113:5,7,10 114:20,23 25:22 264:19 234:4,4,5,8 252:8,17,18,20 196:22 211:25 212:1,12,13 133:24 188:16 terminal 252:25 254:1,7,18,20,21 239:14 243:20 259:22 teenage 232:16 255:1,13 260:15 260:20 262:14 273:10,11 47:18,22 51:16 terms symptoms 273:14 274:15,16 283:4 teeth 71:5 190:6 239:23 241:6 14:16,18 56:6 89:24 90:12 talking 169:20 282:1,8,10,14,19,20 253:15 268:5 176:25 231:23 233:11,12 59:19,22 65:22 77:18 83:6 telephone terphenyls 234:3 255:6,12 263:18 84:21 87:12 114:16 122:24 19:16,24 37:14 134:6 143:11 267:6 268:15,22 271:5,15 126:5 130:5 131:11 139:15 196:16 terrible 272:1,18 281:19 283:2,4,6 146:15 147:7 173:15 177:7 tell 177:7 283:10 183:16 186:12 223:10 4:1,15 17:1 24:16,20 65:13 territory syphilology 233:13 239:22 244:14 66:19 72:23 79:19 87:1 170:4 57:18 250:8 252:21 254:5,10,18 94:6 116:6,6 118:9 129:23 test system 255:5 259:9,22 260:12 151:8 155:25 158:13 201:5 59:25 68:17 69:22 71:15 19:14 41:4 43:20 52:11,13 263:19 268:9,14 270:14 208:12 220:17 222:21 77:7 97:5 135:7,8 137:1,3,3 53:1 138:23 240:11,23,25 271:11 272:13 281:8 283:6 233:19,20,24 234:9,11 137:4,10,11 139:20,21 241:11,20,20 273:22 284:19,19,25 285:17,18,21 237:16 246:22 247:13 140:13,15 151:18 155:5,18 283:20,23 284:1 286:15 250:18 251:3 277:9 278:3 159:18,20,7,8 163:10 164:8 systemic talks 281:20,22 285:3 164:13 165:4,19,20 166:14 58:12 93:10 205:3 230:12 67:3,5 267:4 268:2 telling 166:16,20 167:21 177:12 230:24 tank 184:15 207:8 227:8 192:11,12,19226:15,17 systems 96:1 113:21,23 129:4,5,6 temperature 229:4,22 231:21 273:6 44:9 105:15,25 107:7 tanks 49:24 50:10 54:15 55:25 tested 188:17 232:19 183:9 93:9 103:16 147:13 148:5 60:2 67:22,22 68:7,11,18 t tape 149:1 241:8 242:18 243:5 70:25 71:6,7,11,19,23 72:3 40:7 75:1 143:20 179:24 260:9 284:10,13 285:12 72:11 139:7,9 141:12 201:2,16 258 9 202:4,10,12,15,22 207:7 tape's 215:8 216:15 255:22 286:6,12 temperatures 108:18 51:23 53:18 72:22 93:13 147:13 163:9 167:24 278:13 279:7,11 testified 202 15 tare 125:22 96:3 107:2 204:6,24 241:22 80:16 242:16 276:24 247:6 250:12 260:2,13 testify 94:4 121:25 266:25 267:4 tablet 146:10 target 136:3 tax 290:8 286:9 289:11 ten testifying 9:6 18:17 63:6 67:24 68:8,8 86:18 68:11 76:17 139:9 156:11 testimony 171:8 taxation 290:6 159:17,25,2 170:7 171:8 180:11 287:25 60:25 80:11 144:14 239:25 242:17 244:11 260:6 3:3 4:23 35:20 78:8 86:24 123:4 124:24 168:8 269:19 28920 teaching 6:21 8:25 team 215:13 tendency 21:3 tennessee 200:16,17 201:16,18 289:16 testing 68:23 71:14 99:16 135:8 139:18 144:14,21 145:4 24:21 25:3 26:6 41:13 teaspoon 202:23 207:4,14,20,25 154:25 155:4 159:5,8 162:1 55:14 61:11 66:23 67:12,13 71:20 94:21 95:25 103:14 1051920 21 11820 124:10 125:20 143:21 281:1,2 teaspoonful 21:8 60:12 159:22 teaspoonfuls tenth 21:8 77:14 151:4 tenths 77:15,16 154:2 162:8,10,18 163:6 164:9 167:15 172:10 175:17 176:1 187:22 198:10,10,12 204:2,2 220:21,23 225:8 172:23 184:4,9 210:5 60:12 157:11,12 158:4,7,15 term 226:18 227:6 229:1,3,8 212:11 227:25 242:3,4 244:20 247:15 262:9 158:18,21,23 teaspoons 12:8 20:18 82:6 86:8,10 231:14 232:23 87:9 99:8,9 111:6,25 135:8 tests 270 24 273 8 274 12 60:15 157:24 158:25 280:18 156:18,19 162:10 167:13 168:5 172:18,22 174:15 66:13,14 70:2,4 77:1,3,4 79:7 89:22,22 96:25 97:5 24:24 29:21,25,25 52:7,20 56:3 61:6,6,7 62:14 69:13 teaspoonsful 157:23 224:8,9 226:18 227:6,9,11 228:4,5,20 229:1 243:15 134:21,25 135:6,15,17,18 135:21,23 136:19 137:8,19 WATER PCB-SD0000033281 [tests - toxic] tests (cont.) think (cont.) three (cont.) time (cont.) 140:3,16 142:22 145:25 58:15 59:23 63:18 66:10,22 49:25 52:10,15 55:12,25 288:7 148:23 155:5,9,10,20 156:1 67:6,13 68:13 70:13 76:22 63:6 66:9,14,18,20 67:16 times 156:24 160:11,12 162:5,11 77:4,5 78:8,22 79:8,21 80:3 76:21 80:8 83:5 88:6 104:7 15:7 21:20 36:9 40:1 60:11 162:20 163:15 164:12,22 80:6,10,16 81:15,18 83:24 114:21 119:10 123:18 75:14 158:18,19 159:2 165:1,5 166:11,15 167:6,6 84:25 86:23 89:9 94:20,20 126:11,14 131:11,17,17 176:15 193:1 207:8 242:16 168:6 173:18 176:8 192:14 97:16 98:6 100:4 101:12,18 155:14 158:19,21 166:25 260:5,20 267:10,17 269:18 224:21 225:8,18,22,25 102:1 108:14 110:14 113:9 182:11,18,24 185:24 197:1 tissue 226:6,8,9 228:20 229:2 116:5 119:22 120:16 197:2,4 217:4,5 235:6 216:4 230:8 231:4,18,19 232:7 121:24 122:8,9 125:6 129:3 242:4 245:7,13 250:12 tissues 234:20,21,22 235:2 243:6,8 129:4 130:16 131:22 133:7 255:20 216:6 272:7,8,9 273:7 274:1 137:1 141:5 142:9,25 threshold title 278:17 146:14 148:16,16 151:1,3 103:17 189:24 57:12 98:2,11 100:7,25 tetrachloride 153:19 156:3 160:10 throat 105:16 66:17 161:22 167:19 168:1,11 156:20 tobacco texas 171:17 172:16 173:13,20 throw 255:1 15:5,6 174:18 179:23 183:2,24 219:4 today thank 184:24 185:1 191:13 thrown 22:3 28:18 49:6 56:20 9:20 63:25 224:12 288:8,9 194:18 200:1 203:20 133:6 83:23 207:18 226:21 227:9 288:11 210:10,18 212:2,4,8,25 thrust 229:2 239:14 240:6 243:21 theirs 216:1,14,15 222:12 223:24 261:18 247:25 172:13 206:12 228:12 234:23 237:13 thrusts toes therapeutics 241:6 242:17 244:11 245:9 129:23 76:24 8:2,12,12 249:17 250:7,21 253:18 thumb told therminol 254:11 258:19,22 262:24 130:11 24:15 33:7 53:1 78:12,12 44:10,13 105:14,23,24 265:20 268:18 273:23 till 180:23 181:5,12 184:9 106:1 107:10,20 126:13 274:23,24 278:10 279:25 10:13 22:3 85:23 196:3,22 199:17 204:2 162:12,14 188:1,18 189:10 280:2 281:17 286:18 time 207:2,10,12218:23 221:25 189:11,18,18 thinks 4:13,14,25 5:6 8:13 9:11 258:15 259:12 268:13 therminols 35:7 10:17,19,19 11:13 12:1,3 tomorrow 107:4,23 108:3,9 117:6 third 15:5 17:13 18:23 19:21 216:16 247:25 189:22,23 217:2 13:25 14:11 38:22 57:24 20:12 22:4 24:6,19,25 25:1 tonnage thermometer 70:7 105:19 183:16 188:3,4 25:2,4 26:25 27:3,11 28:14 182:2 55:18,20 81:13 183:7 188:10 242:13 270:1 30:15 31:25 33:17 37:15 tool thermometers thomas 38:20 39:8 45:22 47:13 208:9,12 55:20 2:9 49:24 51:4 52:21,22 55:20 tools thick thorough 56:3 58:21 61:14 62:14 212:20 98:13,22 65:20 76:10,15 89:25 63:10,20 65:5 66:1 73:9 top thing thoroughly 74:12,14 75:11,21 76:2 9:1 41:11 73:11 165:12 14:11,11 20:25 35:9 44:25 139:2 77:4 80:17 82:9 83:13 211:13,14,15214:11 219:7 59:16 97:25 102:13 111:20 thought 87:19 106:8 129:17 130:20 219:10,16 114:19 136:2,2,10,14 171:8 16:9 19:18 34:2 49:10 63:5 131:21 134:20 138:16 topic 227:17 242:25 248:4 253:4 72:8 73:20 76:6,8 95:1,2 145:10,19,21,22 146:7 108:13 263:15 273:17 137:22 139:10 140:6 150:6,21 155:19 159:16 total things 169:12,22 173:16 187:4 161:4 163:10 164:24 165:6 274:20,20 290:15 14:7,15 24:14 44:20 55:24 209:21,22 210:9 215:24 165:7 167:8 170:23 173:7 touching 83:2 84:21 93:24 117:10 223:7 230:16,21 241:13 174:19 177:7 178:1 182:12 289:12 118:3 130:6 134:1 139:18 271:4 285:3 188:4 192:22 194:17 199:3 toxic 169:15 206:3 225:12 thoughts 203:14 204:25 209:15 16:21 21:1,4,4,5,6,7,11,12 232:17 233:15 234:2 280:11 210:15214:21 215:6,18 21:16,19 60:3,20 69:4,12 244:20 245:12,13 256:24 thousands 216:10217:14218:13 69:16 70:1,25 71:8,25 72:5 257:2 263:8 283:8 245:6 220:7,13 221:14 225:20,23 72:8,9,10 76:8 93:10,19 think three 225:25 227:2,14,18 228:17 103:4 136:11,13 146:6 17:15,19 18:1522:1723:19 3:22 4:21 5:5 11:19 12:2 229:13 233:6,12 234:19 159:3 160:10,19,24 176:25 27:15 32:14,16 39:25 42:3 15:15 16:6 18:1225:12 248:6 250:11,19 257:5,11 280:16,17 287:10,13,14,16 50:24 52:19 56:13,14,20 26:13,16 28:8 38:11 48:5 261:19275:11 286:10 287:17,18 WATER PCB-SD0000033282 [toxicity - understanding] toxicity transcribed tremendously twelve 13:1920:18,19,23 21:13 3:5 270:7 77:5 22:20,20 34:23 37:11 46:20 transcription trends twice 57:9 58:12 59:15 60:19,22 275:19 249:24 250:6 15:4 136:11,13 157:19 82:12,16 83:3 85:11 92:11 transf treon type 93:25 94:8 95:14,19,23 43:17 99:13,16,20 144:2,21 145:4 32:19 57:24 89:16 97:5 96:20 97:6,7,18 98:4 transfer 146:1 149:9 150:22 152:16 128:25 135:7 145:4 149:20 102:21 103:4 104:6,13,20 44:9,13 52:11,13 53:1 153:6,10,11 160:6 176:21 162:7 174:4 175:17 246:25 106:5 107:20 108:9 134:22 54:21 105:14,15,20,21 176:24 180:22 181:11,12 248:4 260:4 137:3 144:2 148:21,25 106:2 107:7 117:5 126:13 188:10 228:24 229:9 types 155:7 159:4,8,24,7,7 162:18 168:18 172:2 treon's 66:13,14 113:16 126:14 160:11,17,18,19,20 163:4,8 182:25 183:2 188:1 189:11 144:14 149:15 181:1 187:6 231:19238:15 164:16 167:13 175:8 221:12 188:3,5 191:9 193:22 typewriting 178:25 180:18 182:15 transform trichlorobenzene 3:6 186:20,23 187:6,22,25 45:3 287:5,6 typewritten 188:6 189:16,21 191:10 transformer trick 132:4 133:20 192:6,20 195:9,16 196:21 45:1 46:5 55:17,17 81:21 276:18 typically 196:23 200:24 201:3 202:2 100:14,15,20,21 101:1 tried 34:23,25 202:5 203:24 206:4 224:22 117:20 120:12 175:14 15:1065:18 typing 225:19 226:23 227:10 183:18 184:5 190:5 191:22 triglyceride 134:2____________________ 228:3,20 229:15,16 231:8 191:24 195:21 286:14,20 265:13 u 231:12,14,18,21 233:1 286:20,22 287:4,5,7 triglycerides u.s. 234:22 257:21 258:5 260:9 transformers 265:11,22,24 260:10 287:19 42:12,15,17 44:16 45:10,21 trouble 79:3,19 85:2,3 89:9 109:3 153:22,23 toxicological 11:16 13:22 18:5,10,14 19:10,15 20:5 34:8,19 183:13,22,24 195:2 196:1,2 221:15 287:9 translate 57:24 62:2 97:2 131:19 138:3 139:2,13,20 148:17 254:22 u.s.d.a. 165:16 ucla 37:23 40:23 46:22 85:7 158:2 215:3,4 145:1 165:8 175:1 202:21 translated troubles 275:25 276:1,1 281:17 215:24 uh 220:23 225:23 236:25 toxicologist 18:9,11 40:24 41:2 73:7,11 155:22 161:7 174:24 196:13 57:23 215:5 translations 214:22 transmits 43:21 true 21:5 207:4,7 249:15 250:8 272:6 276:23 289:16 290:6 truth 289:11,12 186:5 251:5 ultimate 237:6 ultimately 210:21 toxicologists 17:25 18:3,13,17 40:11 transmitted 38:3 truths 133:7 unbiased 153:8 toxicology transportation try unbroken 12:9,1022:1641:1,9,21 58:2,10,18 73:12 84:13 159:22 175:20 211:23 109:5 110:25 transposition 60:6 36:19 177:4 214:22 253:23 trying 14:3 89:22 141:20 218:25 103:12 uncomfortable 255:18 249:23 250:5,9,22 track 38:5,16 tract trapped 160:8 traveled 236:9 227:19 229:9,25 264:1 276:17 281:17 tumors 85:9 235:5 237:24 238:1 uncontrolled 23:23 undefined 241:6 232:11 treat 239:21 underneath trademark 42:22,24 117:21 118:1 122:25 175:13 195:1 258:23,25 103:14 treated 29:5 48:20 treating turn 46:12 69:7 turned 12:1 41:20 42:7 121:4 understand 50:3 66:21 71:21 72:11 93:25 148:13 157:24,25 train 52:24 62:17 turning 177:6 213:18227:19238:8 241:13 training treatment 6:10,17 9:24,25 65:22 42:4 turnover 240:1,1,22 242:2 255:8,11 255:17 263:25 264:11 5:21 trains treatments 12:6 246:2,3 turpentine 265:17 273:20 276:4,4,17 277:5,5 285:1 45:9 222:5 tremendous 44:17 137:6 understanding 183:15 261:20 263:4 WATER PCB-SD0000033283 [understands - war] understands use varies visited 18:7 215:24 21:7 27:8 understood use variety visiting 146:20 13:17 20:24 32:16 34:16 47:23 283:2 14:22 undertaken 35:10,1242:10,1443:10,12 various visits 230:3 54:23 56:19 59:19 71:20,21 11:20 14:22 17:2 23:5 23:1825:1031:18 undertaking 82:17 83:10 95:1 99:20,24 37:19,21 49:19 50:22 73:25 voice 234:23 109:4 111:5 114:16,17 89:10 95:7,24 104:2 108:5 69:13 underwriter 123:5 129:25 130:1,2 108:9 116:21 126:15,16 volume 187:17,20 132:19 134:12,18 147:25 131:12 137:20 144:4 146:1 130:8 232:2 275:8 undiluted 148:12,13 151:6,13 152:20 154:25 156:4,6,12 160:1 voluminous 139:23 155:12 154:18 159:23 174:3,8 162:13 164:9 166:24 169:2 130:5,7 unfair 175:16 178:9,14 184:19 193:10,21 195:15 206:13 voluntarily 270:17 185:11 200:25 220:9 221:5 207:19,25 208:6 213:1 222:13,15 unintentional 221:18,20 217:9,12 220:22 230:8 vomiting 167:21 user 231:19 236:25 239:6 231:25 united 37:9 80:18,20 81:10 190:21 246:12 252:4 260:5 283:8 von 9:1 22:16 23:16 25:14 237:6 varnishes 73:10 174:17 175:9,17 27:25 42:21 54:19,24 73:12 user's 94:24 176:16 177:8 178:5 186:10 78:24 88:3 168:3 170:10,17 190:6,20,22 vary 193:8 171:3,7,17 215:20 266:10 uses 83:12 96:21 106:16,20 vosburgh units 35:4 43:5,9,10 46:6 94:23 varying 73:20 194:22 221:12 170:18 206:15 221:24 107:24 175:23 253:19 VOSS universities 246:12,14,15 vats 278:24 7:9 215:23 usual 240:14 vs university 8:5 100:19 227:17,22 vein 1:10 4:20 6:24 7:1,2,2,6,11,11 usually 263:5 w 8:25 72:16,25 99:11,23 18:4 25:10 69:25 77:7 135:12 144:1,15,25 165:10 110:17 187:21 231:22 ventilate 184:3 wage 39:7 74:8 173:10,11 215:25 235:20 232:3 248:11,17,20,22 ventilation wait 235:22 249:5 65:25 93:12 138:23 143:6 61:20 70:9 81:6 120:20 unload utilized 143:16 154:18 178:9 183:8 121:3 158:20 177:4 185:3 48:23 unnamed 132:12,14,17 193:11 207:19 183:10,25 198:25 version 274:8 walls 264:10 V 150:4,4 286:23 unsafe valley versus want 177:13 200:16,18201:16,18 233:1 275:5 36:1,4,13 43:18,19,22 untoward 93:15 202:23 207:4,15,20,25 value vessel 43:12 47:13 57:5,14 66:20 67:7 79:14 81:8 88:17 96:10 unusual 270:12 video 99:2 114:22 137:10 140:25 24:22 33:20 60:22 82:16 vapor 275:25 141:18 153:8 154:17 160:1 150:1 240:2 103:15 113:6 144:6,7 145:7 videographer 180:16 190:12201:21 unwanted 147:15,16 198:9,15 241:23 2:15 207:6 239:24 244:20 12:11 242:18 view 247:17 255:21 263:4 upper vaporization 83:4 85:11 149:4 160:13 280:19 285:4 286:16 112:7 285:7 123:5 182:1 206:25 225:23 238:2 wanted uric vapors 271:3 36:12,14 42:6,7 64:20 78:3 urinary 93:8,12 96:2 98:24 99:7,10 99:16 103:8,16 112:15 vinyl 49:6 163:7,9 186:3,22 187:16,16 191:9 192:16 196:20 201:4 90:19 272:25 118:10 122:17 125:1 violation 214:24 261:5,7 278:12 urine 128:14 144:3 146:3 147:3 24:19 wants 89:22 151:18 177:13 184:3 virtually 86:23 usable 135:23 191:10 198:17 varied 125:5 visit war 10:16,24 11:6 18:22 22:12 usage 11:15,25 13:20 26:12,23,24 25:14 26:25 22:18 27:2,6,24 38:22 46:7 82:18 113:9 198:22 135:7281:19 134:2,4 210:13 WATER PCB-SD0000033284 [warehouse - workroom] warehouse week (cont.) wheeler (cont.) words (cont.) 121:21 131:16 248:9 193:2 197:16 198:7 199:2 87:14 90:16 114:21 115:3 warfare weeks 201:12 211:3,21 220:12 124:8 129:25 136:4 155:4 10:20,23,25 99:9 151:20 152:2,3 227:1 256:23 159:14,25 160:4,8 163:9 warned 227:3,15,23 whereof 170:7 241:23 254:21 262:8 116:11 weight 289:24 265:12 280:9 warning 125:23 233:22 white wore 129:7 130:6 206:15 went 45:1 112:11 120:3,15 174:9 24:15 warnings 4:6 10:13 12:13 13:18,22 198:7 work 122:18 129:14 130:8,9 14:3 15:1 16:15,23 17:17 whiteheads 9:21 12:13 16:24 17:17 warranted 19:22 20:2 22:17 25:3 27:2 248:25 18:8 38:13 74:6,23 77:23 244:4 27:4,5 40:18 48:20 56:3,8 whoops 78:11 85:7,8 88:19 91:2 wash 56:11 63:12 89:19 97:25 94:3 160:9 93:7 99:13 115:7 138:14,17 53:15 72:21 103:7 125:1 133:22 148:14 151:24 wider 138:18 147:1 149:3 166:17 washed 152:10 167:14,16 174:25 190:6 167:13 186:10215:25 103:13 139:2,13,20 242:12 183:11,16208:21 211:24 widespread 218:10,11 245:23 246:9 washing 211:25 212:13 219:24,25 94:21 252:7 273:4 112:17 118:12 128:16 228:25 269:20 widmark worked Washington westinghouse 207:24 208:22 210:25 12:24 17:6 38:14 39:12 7:11 8:25 9:17 42:19,23,24 43:3 73:14 212:1,6,14 52:13 76:17 162:4 245:1 waste 82:1 89:14,18 101:21 102:4 wild 262:22 123:8,16 124:10 129:2 102:15 103:22 116:22 167:12 worker wastebasket 117:2 119:9 120:9,11,11 wildlife 39:17,18 80:13 88:21,22 134:14 122:24 123:11 150:18 217:11 116:10,11 244:22248:7 watch 175:4,10 177:12,15 178:20 william workers 53:2,5 224:3 178:24 179:3,4,8,14 180:6 194:13 10:4 11:18 14:20 15:20 watched 180:12 181:4,8 182:8 184:6 willingness 23:11 29:2,3,4,20,24 30:2 16:23 52:18 118:3 223:21 184:8,10,15,16 185:16,17 223:20 30:12,15 33:2 48:19 54:18 watches 185:20,24 186:7,25 187:9 willy 54:25 55:11,12,12 62:22 246:6 187:13,17,19,25 189:6,8 110:16 63:2,9 74:3,12,14,21 75:5,9 watching 190:14,24,24 191:7,16,22 Wilmington 75:12,17,21 76:5,19 77:24 234:1 191:24 192:4,7,18,23 193:4 73:13 175:2 78:12 79:7,15,20,22,23 water 193:4,9,11,23,25 194:6,10 window 80:2 83:5 87:25 89:11,14 103:13 112:17,18 118:13 195:13 200:6 207:3 284:9,18,20,22 285:6 89:18,20 90:3 91:1 96:6 118:13 128:17,17 138:25 westinghouse's wire 130:5 131:25 154:12,13,14 148:10,11 213:20 286:3,3,4 175:15 186:8 49:2,3 196:19 193:5,15 196:3 199:19 waters we've witness 237:5 240:14 244:6,18,19 209:12,12 14:18 35:3,3 56:14,15 57:1 45:25 63:22,24 70:12 259:10,23 261:4,10,14 watt 58:20 60:21 62:7 84:21 216:17 272:15 288:8,11 262:20 271:14 278:22 92:3,3,24 94:17 111:13 125:7 128:1 289:14,17,24 working wavelength 130:24 133:24 136:10 woman 6:18,18 10:3 14:14,17,17 64:21 142:7,9 160:5,9 182:2 88:18 16:17,17 17:4 29:11 65:21 wax 190:20 193:7,21 195:17,19 women 72:17 84:24 87:15 131:18 171:1 207:18,25 218:9,9,10 55:25 56:1 150:15 160:5 222:8,8,9 waxes 223:10 255:20 wood 240:23,25 243:9 244:18 43:8 221:6 wgk 47:23 62:17 252:12 260:1 262:20 ways 115:15 word workmen 242:4 wheel 57:21 59:19 156:14 184:23 143:7,17 183:4 wear 247:1 185:2 213:15 224:5 234:20 workmen's 65:21 wheeler 248:24 262:12,17 38:1780:11,12 wearing 17:15,22,23 40:21,24 41:1 wording workpersons 112:19 118:14 128:18 41:8 153:7 180:4,21 181:3 20:16,17 92:16 122:23 183:5 178:12 181:13,14,20 182:6 183:16 262:21 workplace week 184:8,15 185:23 186:6,23 words 82:22 83:21 151:14 177:9 4:23 41:4 52:14 53:3,22 187:8,24 189:4 190:14 13:6,8 17:10 19:12 20:22 workroom 151:20 152:2,3,4,7,13 191:5,20 192:8,8,17,18 28:1739:3 43:1751:10,19 98:24 WATER PCB-SD0000033285 [workrooms - yusho] workrooms years (cont.) 58:14,15 172:19,20,22 176:21,21 world 182:11,18 184:11 188:25 10:16 22:12 27:24 46:7 190:3 214:2 222:12 226:4 136:25 240:16 287:15,18 227:4,11,24 243:6,10 244:1 worn 246:1,10,13 259:25 261:15 96:5 261:16 262:23 269:14,18 worry 270:2,6 279:22 287:25 273:2 288:1 worse yellow 163:11 249:2 112:10 120:16 worthwhile yensen 80:5 208:3 write yesterday 19:23,23 117:15 56:20,22 125:8 239:14 writing 243:21 92:11 129:19289:15 york written 52:23 55:18 74:1 197:17 5:22 20:11,12 99:3 125:19 223:11,14286:18 215:10 274:23 277:4 young wrong 6:10 49:3 71:14 72:5,7 98:6 108:23 younger 140:23 255:6 261:12 271:2 155:3 156:1 161:24 162:4,4 wrote 162:6 163:21 231:5 232:23 37:10 78:19 93:4 94:10 younger's 96:18 138:10 226:19 xerox 120:5 X y yucheng 171:11 274:13 yusho 168:12,16 170:8,14 171:13 171:19 274:13 280:21 yard 281:10,12 146:9,9,9 yeah 30:21 32:3 53:4 57:6,13,15 60:16 64:19 70:16 73:17 75:8 100:6,18,18 120:22 125:16 170:6 186:5 187:1 year 9:9 12:15 15:1,3,4,10 16:10 23:16 27:5 40:1 45:18 46:4 80:25 81:4 85:7 92:8 96:22 96:22 106:16,17 162:10 166:11,15 168:6 171:15 172:10,15 192:15 226:1 228:22 229:3,6,7,8 234:23 246:6,6,9 267:6 years 3:23 4:12,21 5:5 9:6 12:16 15:9 16:6,8 28:8 29:14 32:23,24 40:10 43:5 48:5 48:14,1555:1261:4 75:11 75:24 76:17,17 79:17 81:10 82:25 83:25 84:24 88:20 95:8 104:3 134:24 135:3 166:25 167:1,6 171:8 i 11 _> U -- J_ jC`1 _l. L.' CJ V.1 1 1 Clli.7L/J. X|JI------l. V-/ l 1 years, we're not sure what that might do to them; are we? 2 A. Wo, we are not. 3 MR. MURRAY: We can just go off the record 4 for a minute. 5 (An off-the-record discussion was had.) 6 MR. MURRAY: Dr. Kelly, I appreciate your 7 time this morning, sir. That's all the questions I have. 8 THE WITNESS: Thank you, sir 9 MR. CARNEY: Dr. Kelly, thank you for coming 10 in. I have no further questions either 11 THE WITNESS: Thank you 12 MR. MURRAY: That's it 13 14 R. Emmet Kelly, M.D. ' 15 Subscribed and sworn to before me this day 16 DIANE M. fH-fNKJUSf* notary public - gran of gn MY COMMISSION EXPIRE! W. Il91191 17 ST. LOUIS COUNTY .. 18 19 20 Notary Public 21 22 23 24 25 WALLER REPORTING, INC. WATER PCB-SD0000033287 PAGE OF Dr. R. Emmet Kelly "name of witness" " In Re: DEPOSITION CORRECTION SHEET Cecil Scott, et al. v. Monsanto Company Cause No. 902-02008 Upon reading the deposition and before subscribing thereto, the deponent indicated the following changes should be made* Page 6 Line 24 Should read: clinical instead of political. Reason for change: Faulty transcription. Page 12 Line 7 Should read: doctors instead of documents. Reason for change: Faulty transcription. Page 13 Line 7 Should read: Company B instead of Product B. Reason for change: Misstatement by witness. Page 13 Line 18 Should read: left out "not" after "there were." Reason for change: Error in transcription. Page 40 Line 20 Should read: Maurice instead of Morris Reason for change: Spelling error. SIGNATURE OF WITNESS 2 WATER PCB-SD0000033288 PAGE__ 2_ 0F____ JL Dr. R. Emmet Kelly_____ "*NAME OF WITNESSTM " In Re: DEPOSITION CORRECTION SHEET Cecil Scott, et al. v. Monsanto Company Cause No. 902-02008 Upon reading the deposition and before subscribing thereto, the deponent indicated the following changes should be made* Page 42 Line 19 Should read: Moloney instead of Maloney. Reason for change: Spelling error. Page 42 Line 25 Should read: Inerteen instead of Inerteene. Reason for change: Spelling error. Page 43 Line 17 Should read: transfer not transf. Reason for change: Faulty transcription. Page 45 Line 14 Should read: nonflammability instead of inflammability. Reason for change: Witness misspoke. Paq-e--50----Line ? 5--Should--read4- Reason for change: SIGNATURE OF WITNES WATER PCB-SD0000033289 PAGE 3 OF 5 Dr. R. Emmet Kelly NAME OF WITNESS ' In Re: DEPOSITION CORRECTION SHEET Cecil Scott, et al. v. Monsanto Company Cause No. 902-02008 Upon reading the deposition and before subscribing thereto, the deponent indicated the following changes should be made* Page 60 Line 14 Should read: "fed roughly 70 teaspoons" is wrong. That would be for a 70 kg. man. A rat weighing 1 kg. would get 1 teaspoonful. Reason for change: Confusion on part of witness. Page 85 Line 12 Should read: "always" should be inserted before agree. Reason for change: Missed transcription. Page 91 Line 17 Should read: date not basis. Reason for change: Either misspoke or faulty transcription. Page 100 Line 2 Should read: Unbiased instead of dissatisfied. Reason for change: Wrong choice of word. Page 139 Line 18 Should read: change "diphenyl" to "napthalene." Reason for change: Misspoke - corrected on p. 140. SIGNATURE OF WITNESS WATER PCB-SD0000033290 PAGE 4 OF 5 Dr. R. Emmet Kelly NAME OF WITNESS- ' In Re: DEPOSITION CORRECTION SHEET Cecil Scott, et al. v. Monsanto Company Cause No. 902-02008 Upon reading the deposition and before subscribing thereto, the deponent indicated the following changes should be made* Page 141 Line 11 Should read: Drinker not Brinker. Reason for change : Misspelling. Page 141 Line 25 Should read: Reason for change: add: "Chlorinated diphenyl is a PCB, however, chlorinated diphenyl benzene 5460 is not a PCB." Clarification (see p. 143) Page 173 Line 13 Should read: the word "Institute" was left out. it should follow the word Cancer. Reason for change: Faulty transcription. Page 187 Line io Should read: "Treon" not "von Oettingen." Reason for change: Misspoke. Page 1!?0 Line 5 Should read: Bindschadler not Bindschauler. Reason for change: Misspelled. WATER PCB-SD0000033291 PAGE 5 OF 5 Dr. R. Emmet Kelly NAME OF WITNESS ' In Re: DEPOSITION CORRECTION SHEET Cecil Scott, et al. v. Monsanto Company Cause No. 902-02008 Upon reading the deposition and before subscribing thereto, the deponent indicated the following changes should be made; Page 216 Line 25 Should read: "I don't read Swedish" not "I gave it to a Swedish." Reason for change: Garbled. Page 222 Line 18 Should read: effluent instead of effluence. Reason for change: Misspelling. Page 237 Line ii Should read: 1260 not 1060. Reason for change: Either misspoke or faulty transcription. Page 268 Line H Should read: 5-10 parts per billion not 20 parts per billion. Reason for change: Misspoke. Page 288 Line 5 Should read: "little hotter" should be " less hot. " Reason for change: Misinterpretation. WATER PCB-SD0000033292