Document NEML39KebYmRan9Kevn8Y2Ox8

1 Wm. Papageorge - Glenn Brown Trial Testimony 10/29/91 1 THE COURT: Counsel, you may continue. 2 MR. KOTOSKE: I recall William Papageorge. 3 CONTINUED DIRECT EXAMINATION OF WILLIAM PAPAGEORGE 4 QUESTIONS BY MR. KOTOSKE: 5 Q. Mr. Papageorge, is it a fair statement that 6 the Anniston plant in Alabama was the plant that supplied 7 the PCBs to Monsanto, (inaudible) PCBJo s to the Westinghouse 8 plant in Bloomington, Indiana? 9 A. It is one of the two plants, yes. 10 Q. I want to focus your attention on the 11 conditions of the Westinghouse plant in Bloomington, and 12 in order to differentiate between Monsanto plant which is 13 making the PCBs and Westinghouse plant, I'm going to refer 14 to it as the Bloomington plant so we keep an orderly p15 differentiation in our discussions. Did it come to your 16 attention in the 1960's that the working conditions of the 17 workers in the Bloomington plant -- I'm going to have to 18 strike that. 19 Did it come to your attention in the '60's the 20 conditions under which workers were working with the PCBs 21 in the Bloomington plant? 22 A. No. I was never told the conditions in the 23 plant. 24 Q. Let me show you a memorandum dated September 25 21, 1967, and I']p 11 see if that refreshes your Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49516 2 1 recollection. 2 MR. CARNEY: Could we approach the bench, 3 Your Honor? 4 THE COURT: All right. 5 (A bench conference was held.) 6 MR. KOTOSKE: Judge, can I have that copy 7 back? 8 THE COURT: Oh, sure. Ladies and gentlemen, 9 now that I've got you down here, we're going to have to 10 take a very short fiv]p e-minute break. I apologize for the 11 disruption, but we have to discuss something, so a 12 five-minute break. Stretch your legs a little bit. Don't 13 discuss the case among yourselves or with others. 14 Felicia, bring them back at quarter to 10:00. 15 (Brief recess.) 16 THE COURT: Proceed. 17 Q. Have you had chance to look at the 18 memorandum? 19 A. Yes. Yes. p20 Q. And you were copied on that memorandum; were 21 you not? 22 A. I was. 23 Q. Does that memorandum refresh your 24 recollections as to the working conditions at the 25 Bloomington plant? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49517 3 1 A. Your question, sir, is -- When you asked me, 2 as I understood it, was I told about plant conditions, my 3 mind immediately went to the arrangement of the equipment, 4 the absence or presence of ventijo lation. 5 REPORTER: Presence of what? 6 A. Absence or presence of ventilation in the 7 working area, these kinds of things. The memo reminded me 8 of the presence of liquid and oil on the workers and their 9 shoes and the fact that they didn't change their clothing. 10 I would associate that more with the workers' practices 11 rather than condition of the plant. 12 Q. Thank you for your explanation. Now, let' s]p 13 cut right to it. What did you know about these workers at 14 the Bloomington plant handling PCBs in a sloppy fashion? 15 A. The author of that memorandum did use that 16 word, and he was relaying in that memorandum information 17 he received from someone at the Bloomington plant. 18 Q. Who was the author of the memorandum? 19 A. Paul Benignus. 20 Q. Who is Paul Benignus? 21 REPORTER: (]p Inaudible.) 22 MR. PAPAGEORGE: B-e-n-i-g-n-u-s. 23 A. Mr. Benignus at that time was the manager of 24 marketing of the dielectric fluids that contained PCBs. 25 Q. He was a Monsanto employee; was he not? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49518 1 A. Yes. 4 2 Q. He was a seller of PCBs. He was in the sales 3 department; wasn't he? 4 A. Well, yes. 5 Q. And he was reporting to you in this]p 6 memorandum on which you received a copy back in '67 that 7 the conditions out at that plant in Bloomington were 8 unacceptable? 9 A. Were sloppy is the word he used. 10 Q. Would Mr. Benignus be in a position toknow 11 that type of information? 12 A. If he personally saw it, yes. 13 Q. Did Mr. Benignus in his memorandumrefer to 14 spilling of PCBs, workers getting their clothes soaked, 15 ]p their shoes full of PCBs? 16 A. He did. 17 Q. Those were conditionsthat Monsanto would not 18 tolerate in its plants; would it? 19 A. That is correct. 20 Q. Those conditions could bevery harmful to the 21 Bloomington plant workers; would they not? 22 A. Not on a one-time condition or exposure, but 23 repeated, eventually, yes. 24 Q. The conditions were so bad that if they p25 continued those workers could have died from that Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49519 1 exposure? 5 2 A. That would be the extreme case, yes, sir. 3 Q. But certainly those workers at the 4 Bloomington plant, considering the conditions that you 5 knew, were quite likely to have chloracne from that 6 exposure? 7 A. No. I had no information to tell me that 8 they would have chloracne. 9 Q. Did you have any informjp ation that those 10 workers were likely to incur liver damage from that 11 exposure? 12 A. I had no information of that kind. 13 Q. You knew that their exposure consisted of 14 clothes drenched in PCBs, shoes soaked in PCBs; did you 15 not? 16 A. I did. 17 Q. You knew that as early as the 1960's? 18 A. By that memorandum, yes, sir. 19 Q. You also knew at that time that repeated^) 20 exposure to PCBs in conditions described in that 21 Bloomington plant could result, could result, in those 22 workers contracting chloracne? 23 A. Could under the right conditions, yes. 24 Q. You also knew at that time that those 25 workers, if that exposure and those conditions at that Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49520 6 1 plant continued, they could incur liver damage? 2 A. If they continued long enough, yes. 3 p Q. How long is long enough? 4 A. I do not know. 5 Q. Did Monsanto, knowing the conditions in which 6 the PCBs were used at the Bloomington plant, ever conduct 7 a seminar or a session with the workers themselves -- I'm 8 talking about the men and women who worked in that 9 plant -- to explain to them the dangerous conditions from 10 exposure to PCBs? 11 A. Did Monsanto do that? 12 13 p Q. Yes. A. No, sir. We cannot speak to our customers' 14 workers. 15 Q. I'm going to change the subject. Did you 16 ever visit the Bloomington plant? 17 A. Yes, sir. 18 Q. How many times? 19 A. Once. 20 Q. When? 21 A. July 1970. 22 Q. What were the conditions of the plant when 23 you visited there? 24 A. Well, I saw a fairly clean plant. 25 Q. Anybody tell you that the plant had been Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49521 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18]p 19 20 21 22 23 24 25 7 spruced up just for your visit? A. No, sir. Q. Did you ask? A. No. It wouldn't occur to me to ask. Q. I wonder if this question occurred to you. Did you ask anybody at the Bloomington plant, "Listen, how did these workers work on a day-to-day basis with this stuff, the PCBs that we manufacture and sell themjo ? How do they work on a day-to-day basis?" A. We had such a discussion. Q. Who did you have thediscussion with? A. Oh, a room full I would say of about a dozen people, including the top managers, the plant manager himself, and his engineering people, his manufacturing people. Q. And you were told that these workers handle this stuff in perfect order, in perfect condition, according to all rules and regulations issued by Monsanto? A. I don't recall the word "perfect" being used, but I was assured that all the precautions that were well-known to the Westinghouse managers were being emphasized and the foremen were observing the activities and that the proper kinds of equipment were available, that they were following good practices. Q. Let me ask you something. By now you know Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49522 8 the chemical can be dangerous if it's misused. We've agreed on that? A. Oh, I knew it even then, sir. Q. Did the thought ever occur to you to make a surprise, unannounced visit? A. The thought did occur, sir, but that just isn't done. I can't walk into a plant -- That would be a form of trespassing the way I see it. Q. That's your explanation? ]p A. Yes. Q. Now, I want to talk a little bit about Renate Kimbrough Renate Kimbrough conducted some toxicity studies on animals in the early '70's; did she not? A. Yes, she did. Q. And she came to the conclusion, did she not, that the PCBs you were producing were toxic to (inaudible) animals; did she not? A. One of the PCB mixtures that Monsanto was producing used in hp er tests showed an effect on the test animals, yes Q. It was an adverse health effect; was it not? A. Yes. That's her interpretation. Q. You knew that in the early '70's; did you not? A. Yes . Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49523 9 1 Q. And you were not pleased -- Monsanto was not 2 pleased with the results and the conclusions she reached p3 about the toxicity of her animal studies on your PCBs? 4 A. I think a more accurate word would be we were 5 surprised rather than not pleased. 6 Q. Were you concerned? 7 A. Certainly. 8 Q. Now, the last of thosestudies ispublished 9 by Renate Kimbrough in 1974. I ask you to accept that 10 date as true. Studies, (four of them, three of them), 11 were in '72 and '74 when she found your PCB to be very p12 toxic. Did you change the warning label the workers would 13 see, if they ever saw it, to include the data and warning 14 about the toxicity that she found in her laboratory 15 animals? 16 A. No, sir. You don'tchange wording based on 17 one isolated study that has not been confirmed. 18 Q. And you didn't consider her at that time to 19 be world renowned in the area of PCB toxicology? 20 A. She was world renowned, certainly, but that 21 doesn't mean th]o at the one test could go unchallenged. 22 This is done in the scientific community all the time. 23 Q. Now, the results she reached were directly 24 opposed to the results reached by IBT; were they not? 25 A. I don't know what you mean by the word Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49524 1 "opposed". They -- 10 2 Q. Scientifically they reached different 3 conclusions? 4 A. Correct. 5 Q. On the one hand you had]o the IBT studies 6 showing no toxicity, and on the other hand you had the 7 Renate Kimbrough studies showing toxicity? 8 MR. CARNEY: I'm going to object. I think 9 it's mischaracterizing the studies. 10 THE COURT: I'm going to let the witness 11 explain if he doesn't agree. You may answer, sir. 12 A. Sir, both studies showed toxicity of that 13 particular PCB, the Aroclor 1260. It was the 14 interprjo etation of what the pathologists were seeing 15 through their microscopes that was in dispute. 16 Q. Nevertheless, both studies finding toxicity 17 in test animals, you did not change your warning label 18 after you had your studies and the Kimbrough studies; is 19 that true? 20 A. That is true. The warnings already there 21 would have prevented workers from reaching a condition 22 described by either of these sets of pathologist^) s. 23 Q. Now, for the balance of this examination, I 24 want you to have before you, which you probably 25 (inaudible), Exhibit 11. Let me show you how Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49525 11 1 (inaudible). Refer to those pages from Exhibit 11. The 2 first thing I'd like to talk about, and if you could stay 3 with me, I want to look at the material safety data tests 4 or sheets for Monsanto for the manufacturing of its own 5 Aroclors, and they start ]o on page one, and I'm sure you are 6 familiar with these data sheets. Start on page one, and 7 they go through page, I believe, 23 or so, page 20. I 8 want to -- Let's look at page one. This material safety 9 data sheet is dated May of '71. I asked this question of 10 Dr. Kelly, and he (inaudible). Where are the material 11 safety data sheets for the '50's and the '60's? 12 A. There were no such documents by the 13 Department of Labjo or, the new OSHA organization. 14 Q. Aside from the federal requirements now 15 requiring safety data sheets, did Monsanto nevertheless 16 have material safety data sheets for the manufacture of 17 PCBs prior to the 1970's? 18 A. There were data sheets that addressed the 19 safe handling of material, but they were not in a format 20 such as we're looking at now. 21 Q. I don't care about the format. Where are 22 t]o hose documents? Does Monsanto still have those 23 documents? 24 A. That I can't answer, but I do know that 25 safety data was included in Monsanto's manufacturing Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49526 1 2 3 4 5 1) 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12 procedure manuals and in their operating instructions which the operators used. Q. Let me just interrupt you, please. I'm talking about the material safety data sheets. Did Monsanto have material safety data sheets prior to 1970? A. You're referring to a piece of paper with that title on it? Q. Yes. A. No, sir. Q. Something like that? A. No such documents existed in industry at that time. Q. Look at -- You're familiar with these kinds of documents; are you not? A. Certainly. Q. I want you to turn to section four of this document. Just!) use the first part, it's easier to read, where it says fire and explosion hazard data. A. I see it. Q. It says the flash point of PCB is 180 degrees centigrade; does it not? A. That's what it says, yes. Q. I'm going to read some of these to the jury, and you tell me if I read it correct. It says, "Special precaution, special fire fighting procedures," and it says Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49527 13 1 "Respiratory protection when fighting fires or exposure to 2 vapor or gases is possible." Does it not? 3 A. It does. 4 Q. That means you've got to wear a mask of some 5 kind? 6 A. During a fire. 7 Q. I understand. Some type ofrespiratory 8 equipment. Is that what it says? 9 A. Yes. Against the smoke and whatever else 10 develops during the fire. 11 Q. And]o then it talks aboutexploding hazards; 12 does it not? Do you read that? 13 A. I do. 14 Q. And it saysthis: "Highlytoxic gases, 15 chlorides and chlorine, can be involved in fires of this 16 product." Does it not? 17 A. It does. 18 Q. When a person -- If you look at section five, 19 health hazard data, do you see that? 20 A. I see it. 21 Q. And it talks about theeffects ]o of over 22 exposure to PCBs; does it not? 23 A. It does. 24 Q. And it says this is what happens when you're 25 overexposed. Skin irritation in a form of chloracne. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49528 14 1 Systemic intoxication leads to nausea, vomiting, loss of 2 weight, edema, and abdominal pain. Does it not? 3 A. It does. 4 Q. Let's just stop. On any warning, on any 5 warning label that you've ever seen at Mon]o santo that was 6 on these drums or on these tankers or however you 7 delivered your PCBs, did you ever include this language, 8 "Exposure can result in skin irritation in the form of 9 chloracne. Systemic intoxication leads to nausea, 10 vomiting, loss of weight, edema and abdominal pain"? 11 A. No. 12 Q. Spills or leaks -- This is Section 7. 13 A. I see it. 14 Q. When there's a spill of PCBs, you'rjo e supposed 15 to (inaudible) clay, sawdust or other absorbing material, 16 place it in a drum, bury it in an approved chemical 17 landfill in accordance with local and state regulations. 18 Did I read that correctly? 19 A. Yes, I did. 20 Q. I just wantto ask you something. In all the 21 time you worked at Monsanto, in the '50's, in the '60's, 22 in the '70's -- And there's an exception. You changed 23 your warning in thejo '70's about environmental (inaudible); 24 did you not? 25 A. We did change that warning. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49529 15 1 Q. Did you ever have in the '50's, '60's and 2 '70's a warning to workers on the labels of these drums or 3 tanker cars or whatever that when a spill occurred it 4 would have this language included on it? Did the label 5 have that language? 6 A. The language you just read out of Section 7? 7 Q. Yes. 8 A. No. 9 Q. Section 8, special precautions, ventilation. 10 You're supposed to have ventilation for the vapors; is 11 that right? I'm down in Section 8. 12 A. Are you -- Under which part of that? 13 Q. Local exhaust. 14 A. Local, yes. 15 Q. It says, "Protective clothing, rubber gloves, 16 chemical (buffers)." Does it not? 17 A. Yes . 18 ]o Q. Now, down at the bottom Monsanto writes on 19 this material safety data sheet, quote "While the 20 information and recommendations set forth herein are 21 believed to be accurate as of the date hereof, Monsanto 22 Company makes no warranty with respect thereto and 23 disclaims all liability from reliance thereon." Did I 24 read that correctly? 25 A. You did. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49530 1 1) 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 16 Q. Will you please turn to page 22? A. May I -- Earlier you mentioned a May date. Would you repeat that for me? I can't find that. Q. It's May '71. A. That's the date that OSHA designed this form. Q. All right. Is that when you first started using it? A. No. Q. When did you first start using it? A. We started using it in late '71. This one is dated, as you can see at the ]o bottom of page two, January 26th, '72. Q. Thank you. Would you turn to page 22? I'm not going to spend a lot of time on these medical studies, but I had asked you before whether or not you had read these medical studies, these toxicity studies from the Harvard School of Public Health carried out by (inaudible). They start on page 22. A. Page 22. I have it. Q. When I asked you before ]o whether -- These were the studies I was referring to. Were we talking about the same studies? A. Yes. Q. Turn to page 46. Can you tell me what this document is? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49531 17 1 A. The document starting on page 46 appears to 2 be part of a manufacturing process manual. 3 Q. For PCBs? 4 A. For PCBs at Monsanto. 5 Q. That's a Monsanto document; is it p not? 6 A. Yes . 7 Q. I'm interested to know whether or not you 8 ever read it 9 A. Certainly. 10 Q. Turn to page 51, and I'm going to read 11 something. 12 A. I have it. 13 Q. Did you read this document at or about the 14 time it was published or shortly thereafter, or when did 15 you read it? 16 A. I read this document when I was assigned to 17 the p Anniston plant in 1964 or so. 18 Q. This document is dated in 1955, but, 19 nevertheless , you read it when you got to the Anniston 20 plant? 21 A. Yes, sir. 22 Q. This document states on page 51, talking 23 about your PCBs, "There is need, therefore, to give 24 warning for the toxicity of these compounds has been 25 repeatedly demonstrated both from a standpoint of the Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49532 18 p1 absorption from the inspired air as well as from their 2 effects in producing serious and disfiguring dermatitis 3 when allowed to remain in contact with the skin." I want 4 to ask you something. On any warning on any label that 5 Monsanto ever had on any of these drums or tankers or on 6 anything, did that warning include the language that I 7 just read? 8 A. You mean word for word? 9 Q. Yes. 10 A. No. p11 Q. Would you please turn to page 57, please? I 12 don't know if you've seen this letter. Do you need a 13 minute to look at it? 14 A. It's been a while since I've seen it. 15 MR. CARNEY: What page are we on now? 16 MR. KOTOSKE: 57. 17 Q. I'm interested, Mr. Papageorge, in the last 18 paragraph of this document. 19 THE COURT: On page 57? 20 MR. KOTOSKE: Yes, sir. 21 l5 22 A. I have read the last paragraph. Q. This document is authored by Dr. Emmet Kelly? 23 A. It is. 24 Q. Did you ever discuss the contents of this 25 document with him? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49533 19 1 A. I did back in early 1970, yes, sir. 2 Q. This document says -- And we already know 3 that MCC stands for Monsanto Chemical Company. This 4 document is referring to the toxicity of your P]p CBs; is it 5 not? 6 A. It does. 7 Q. And it says, "Monsanto's position can be 8 summarized in this fashion. We know Aroclors are toxic, 9 but the actual limit has not been precisely defined. It 10 does not make too much difference it seems to me because 11 our main worry is what will happen if an individual 12 develops any type of liver disease and gives a history of 13 Aroclor exposure. I'm sure the juries would no]p t pay a 14 great deal of attention to MAC." Did I read that 15 correctly? 16 A. You did. 17 Q. At any time in the '50's, in the '60's, in 18 the '70's, did the warnings on the labels of the drums and 19 the tankers, or however you sold this stuff, ever contain 20 the language that I just cited - 21 A. No, sir. 22 Q. --in this document? 23 A. No, sir. 24 Q. The fact of]p the matter is in the 1950's you 25 didn't even know how toxic PCBs were; did you? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49534 20 1 A. Well, I hesitate, Mr. Kotoske, because I need 2 some help from you. Will you describe for me what you 3 mean when you use the word "toxic"? 4 Q. I'm going to rely on Dr. Emmet Kelly, the 5 medical director for Monsanto, who indicates he doesn't 6 know how toxic this stuff is. 7 MR. CARNEY: I'm going t]p o object. That 8 mischaracterizes what he said in (inaudible). 9 THE COURT: The letter will speak for itself. 10 Let's proceed. 11 A. What's your question, sir? 12 Q. I'll move on. I want you to turn to page 64. 13 MR. CARNEY: Your Honor, I don't think he 14 gave the witness a chance to - 15 THE COURT: There was a question. You want 16 to withdraw it? 17 MR]o . CARNEY: I would object to his giving 18 speeches (inaudible). 19 THE COURT: Just drop it. Let's proceed. 20 Q. Turn to page 64. Is this a Monsanto 21 document? 22 A. This is a collection of portions of a 23 Monsanto document. 24 Q. When was it published? 25 A. Well, the date of the document is July 1964. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49535 21 1 Q. It's a Monsanto in-house document? 2 A. Yes. 3 Q. Turn to page 66. Before I ask you this 4 question, was chlorine gas used in the manufacture of 5 PCBs ? 6 A. Yes. 7 Q. Read to the jury what it says about chlorine 8 gas on page 66. 9 A. The entire section? 10 Q. No. Just right across from number one, the 11 chlorine gas. 12 A. "Chlorine gas is a very toxic, corrosive gas. 13 Leaks or highjo pressure can occur to liberate it." 14 Q. Thank you. Would you please turn to page 70? 15 A. I have it. 16 Q. Biphenyls were used in the manufacture of 17 PCBs? 18 A. Biphenyls, yes. 19 Q. Read what it says there about biphenyl. 20 A. "Biphenyl is a flammable material which will 21 burn. Burning should not be done in the presence of 22 biphenyl or biphenyl vapors. The melting poinjo t is 68.7 23 degrees C, flash point 106 degrees C, the fire point is 24 124 degrees C, and the auto ignition temperature is 258 25 degrees C. Inhalation of biphenyl fumes is not Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49536 22 1 recommended since it can cause a drugged effect on the 2 person." What does that mean, "drugged effect"? That's 3 what I'm interested in (inaudible). 4 A. Similar to a light alcohol drug, 5 lightheadedness, unsure movements, so on. Q. Would that include dizziness? 7 A. To some people, yes. Q. Now, I want you to turn to page 75, if you 9 will, and it has a list - 10 A. I have it. 11 Q. And that's your drum weights when you shipped 12 these PCBs out, is that right, 55 or five-gallon drums? 13 A. Yes. 14 Q. Now, I'm going to -- Mr. Papageorge, I'm 15 going to ask you a series of questions. ]p They're going to 16 sound kind of inane, but a foundation. Everybody knows 17 the answer. I want to make the record. In the '50's, 18 '60's, '70's, was Monsanto in the business of selling 19 PCBs? 20 A. Yes. 21 Q. It's not difficult. I've got to ask it. Did 22 you place your PCB products in the stream of commerce? 23 A. Yes. 24 Q. Did you sell theminterstate? 25 A. Yes. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49537 23 1 Q. All right. And I might have asked you. You 2 were engaged in the business of selling PCBs? 3 A. Yes. 4 Q. All right. And when the PCB products that 5 you manufactured left your plant, they left your plant 6 without any substantial change in the specification of 7 PCBs that you (inaudible)? You weren't telling your 8 customer, "Here's one," and then sell them another? 9 A. Oh,]p certainly not. 10 Q. The product, the PCBproducts, were expected 11 to reach and did reach a consumer, Westinghouse, without 12 any change in their conditions as far as you know? 13 A. Not necessarily. 14 Q. How did they change? I'm talking about the 15 time you ship them from your plant until they arrive at 16 the plant at Westinghouse. That's all we're talking 17 about. 18 A. I understand. The Wesjo tinghouse Corporation 19 gave Monsanto a specification of the product they expected 20 when it arrived at their plant. Monsanto shipped -21 Q. Anddid it arrive according to those 22 specifications? 23 A. Yes. But Monsanto shipped a product with a 24 tighter specification to make certain that if there was a 25 change enroute it would still arrive and meet the Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49538 24 p1 specification called for by Westinghouse. So there were 2 slight changes. 3 Q. They were not substantial changes in the 4 chemical structure? 5 A. Oh, no. No. 6 Q. Those specifications were designed to insure 7 the product arrived without a substantial change in 8 specifications? 9 A. That is correct. 10 Q. I think I'm almost done in this series of 11 questions. You had told us -- Excuse me. Page 78, moving p12 right through. 13 A. Page 70? 14 Q. 78. 15 MR. CARNEY: Did you say78? 16 MR. KOTOSKE: Yes. 78. 17 A. I have it. 18 Q. These are the corporate minutes of Monsanto 19 with respect to the Corporate Development Committee, dated 20 April 22, 1968. I don't know what the Corporate 21 Development Committee is. What is it I guess is the 22 question? 23 A. Th]o is committee consists of the highest 24 officials in Monsanto Company, and it's chaired by the 25 chairman of the Monsanto board and the chief executive Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49539 25 1 officer. The other members include the executive vice 2 presidents who were responsible for the different areas of 3 activity going on at Monsanto, such as marketing, 4 manufacturing, and so on. And they met on a scheduled 5 basis to discuss the important matters facing the corporation each month. 7 Q. Fine. And then there's some notes on page 79 of what they concluded, and one of those notes has to do 9 with PCBs. Do you see the last paragraph there? 10 A. I see it. 11 Q. And it says - 12 MR. CARNEY: Your Honor, I'd like to object 13 just on relevancy grounds. This paragraph has to do with 14 transformers and Therminol. It's a heat transfer. 15 Doesn'Jo t have anything to do with capacitors and PCB. 16 THE COURT: Is it a PCB? 17 MR. KOTOSKE: Yes. 18 MR. CARNEY: Yes, it is. 19 THE COURT: I'm going to allow it with the 20 objection. Let's keep it moving. 21 Q. The Corporate Development Committee decided 22 on April '68, quote, "In the case of Aroclor, the key 23 issue becomes how to significantly increase the sales 24 quotas whip le maintaining the domestic supply position and 25 profitability. It is believed transformers and heating Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49540 26 1 systems provide the major opportunities." Have I read 2 that correctly? 3 A. You have. 4 Q. Now, if you'll turn to page 80, this is a 5 Monsanto letter. 6 A. Yes. 7 Q. It was sent to all your customers that used 8 PCBs ? 9 A. No. This was sent to th]p e - 10 THE COURT: Did you say 80? 11 MR. KOTOSKE: Page 80. 12 THE COURT: 80. You said eight. Proceed. 13 Q. Page 80. Are you with me? 14 A. I'm with you. 15 Q. All right. What is this document? 16 A. This is a Monsanto letter mailed on March the 17 3rd of 1969 to Monsanto customers who purchased PCBs for 18 use in electrical equipment. p19 Q. And it is authored by Elmer P. Wheeler? 20 A. It is. 21 Q. Who worked with Dr. Kelly? 22 A. Yes. 23 Q. The substance ofthisletter is reporting on 24 what Swedish scientists had found with respect to PCBs and 25 their persistence in the environment; is it not? I was Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49541 27 1 unfair. You may take a minute and look at it. 2 A. It does refer to the Swedish work. It also 3 ref) fers to other work known as of March '69. 4 Q. Now, Mr. Wheeler says in this letter, "The 5 Swedish and American scientists also imply that 6 polychlorinated biphenyls are highly toxic chemicals. 7 This simply (inaudible). This is simply not true." He 8 goes on. "PCBs are not toxic unless they are mishandled 9 or misused." Mr. Papageorge, that's a bald 10 misrepresentation what you knew to be the toxicity of 11 PCBs? 12 ]p A. Sir, that's why I asked earlier for your 13 definition of the word "toxic". The word "toxic" is used 14 by so many people in so many different ways that it's 15 become difficult to communicate using that word unless 16 someone describes it in detail. 17 Q. Turn to the next page of this letter. We're 18 on page 82 at the bottom. 19 A. I see it. 20 Q. Mr. Wheeler goes on, "It is, therefore, not 21 only p]p uzzling, but extremely difficult to conceive how 22 commercially-produced PCB can show up in wildlife as DDT 23 and other pesticides appear to be. This raises the 24 question whether the substance identified in the Swedish 25 work and now in California is actually PCB." Mr. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49542 28 1 Wheeler's position at the time he wrote this letter was 2 whatever these people found, it wasn't PCB? 3 p4 A. No. Mr. Wheeler was just raising the question is it in truth PCBs, which reflected the thinking 5 of scientists working on this PCB/DDT problem. 6 Q. Is that your answer? 7 A. Yes. 8 Q. Shortly after, in fact, a month later, a memo 9 was issued by Monsanto, and it appears on page 83. 10 A. I see it. 11 Q. And it's dated April 14th, 1969; is it not? 12 A. It is. 13 Q. And it's -- 14 ]p MR. CARNEY: Your Honor, I'm going to object 15 to this memo on relevancy grounds. This is a memo with 16 regard to disposal of Aroclors. 17 THE COURT: We're not to get into disposal, 18 but is there another area in here that's relevant to the 19 issues ? 20 MR. KOTOSKE: Paragraph two is very relevant. 21 THE COURT: I'll allow that, but -- 22 MR. CARNEY: Paragraph two has to do with p23 Pydrauls, Your Honor, the hydraulic fluid. 24 THE COURT: Are Pydrauls PCBs? 25 MR. KOTOSKE: They are. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49543 29 1 THE COURT: I'll allow (inaudible). 2 Q. The letter states quote, "At present we are 3 putting reclaim Aroclor into new Pydraul hydraulic fluid. 4 We can't really satisfy pollution people with this 5 explanation. This will just bring the focal point to 6 hydraulic flujo ids that much sooner." Who were the 7 pollution people that were referred to in this memo? 8 A. Well, Dr. Richard is referring to people - 9 MR. CARNEY: Let me object here. I think 10 this might call for the witness to speculate inside Mr. 11 Richard head. 12 THE COURT: Well, let him answer as best he 13 can. Overruled. You may answer, sir. 14 (Ms. Olliges was replaced by Ms. Carter.) 15 16 17 18 19 20 21 22 23 24 25 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49544 30 1 A. Dr. Richard was referring to those 2 individuals who looked upon PCB as a serious environmental 3 problem, and that included people, private citizens, 4 government people, as well as industrial people. 5 Q. That's who he was referring to as the 6 pollution people? 7 A. That was my understanding, yes, sir. 8 Q. Who wrote this memo? p9 A. Dr. Richard. 10 Q. Who was he? 11 A. He was the director ofresearch or manager of 12 research for products that included PCBs in their makeup. 13 Q. Was he a Monsanto employee? 14 A. Yes. 15 Q. If you will please go ahead now and turn to 16 April 28th, '69. There are more corporate minutes. And 17 they are on pages 85 and 86. 18 A. I have found it, yes. 19 Q.]p As of April 28, 1966, you were still seeking 20 to expand the production of PCBs, that is, Monsanto? 21 MR. CARNEY: Your Honor, I'm going to object 22 here. This (inaudible) on relevance grounds. What we are 23 talking about here is a solid Aroclor in a solid form, not 24 in a fluid form. None of this material was sent to 25 (inaudible). Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49545 31 1 MR. KOTOSKE: (inaudible) PCBs, Your Honor. 2 It exprejo sses the attitude of the (inaudible) . 3 THE COURT: I'm going to allow it on that 4 basis. Overruled. Let's keep it limited. 5 Q. (By Mr. Kotoske) Now, despite what you know 6 and have learned about the persistence of PCB, the Swedish 7 scientists, the problems began to develop in the late 8 '60s, on April 28, 1969, you were seeking to expand PCB 9 production by expansion of the Anniston plant, were you 10 not? 11 p A. No, sir. 12 Q. What does that mean? And I'll read it. 13 THE COURT: What page are you on again? 14 MR. KOTOSKE: Oh, 86. 15 Q. (By Mr. Kotoske) Are you on page 86? 16 A. Yes, sir. 17 Q. "The president advised that he would 18 recommend to the board of directors for approval - 19 Organic Division Appropriation Request," and then its has 20 its number abbreviajo ted "for $1,100,000 for solid Aroclor 21 expansion-Anniston." What does that mean? 22 A. That refers to a project to expand the 23 facilities for making another line of products that had 24 the trademark Aroclor, but they were not PCBs. These are 25 different chemicals. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49546 32 1 Q. The chemicals called Aroclors didn't have 2 PCBs in them? 3 A. Yes, sir. 4 Q. Turn to the corporate min]p utes on November 17, 5 1969, that appear on page 87. 6 A. I have it. 7 Q. Mr. Wheeler now discussed the environmental 8 aspects of PCBs, does he not? 9 A. That's reportedhere, yes, sir. 10 Q. And you now know for sure that "5 and 6 11 chlorinated biphenyls (Aroclor 1254 and 1260) have been 12 found at limited locations in water, in birds and some 13 forms of aquatic life. Recent indications are th]p at such 14 biphenyls may affect reproduction of fowl life and may be 15 toxic to shrimp." And he says, "These products are not 16 toxic from the acute standpoint to man or fish." Do you 17 see that? 18 A. I do. 19 Q. Do you know that to be true? 20 A. That's my understanding, yes, sir. 21 Q. Despite what you told us? 22 A. I'm sorry? 23 Q. Despite what you have told us yesterjo day and 24 today? 25 A. I don't know that I mentioned anything about Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49547 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 p 20 21 22 23 24 25 33 acute toxicity. Q. The memo goes on on page 89 where the company reached some conclusions. Do you see that at the bottom of page 89? A. I believe I do, yes. Q. And the company concludes, "In light of the recent and developing evidence of a possible threat to ,pcertain species of birds aquatic life, we should plan to discontinue the manufacture of Aroclors 1254 and 1260. The division is instructed to develop a program to discontinue these products" and report back. That was in 1969, was it not? A. Yes, sir. Q. But, nevertheless, youcontinued to manufacture those things, did you not? A. No. Q. 1254? A. Yes. Q. A. Q. 1242? Yes. Why didn't you just stop the whole problem right there? Why didn't Monsanto just stop it? A. That would havebeen anirresponsible act on Monsanto's part because these materials, we kept getting assurance from our customers, were very critical in the Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49548 1 2 3 4 5 6 7 9 10 11 Vp 2 13 14 15 16 17 18 19 20 21 22 23 24 25 34 manufacture of electrical equipment, and we believe that sincerely. Q. You believe that the elecjo trical equipment was more important than the environment? A. No, I didn't say that. Q. I know you didn't say that, but isn't that the conclusion you've drawn? Monsanto took the position in 1969 you could have stopped the production of PCBs altogether. You took the position that the electrical industry, Westinghouse, General Electric, McGraw-Edison and the rest of them, your customers who reaped profits for your coffers were more important than the environment and human health? A. That is not true. Q. You continued to make PCBs even after 1969? A. That is correct. Q. Would you please turn to page 90. I wonder if you've seen this letter before. I've discussed it with Dr. Kelly. And we referred to it the other day, I believe. A. Have I seen this particular l]p etter? Q. Yes. A. It was addressed to me, yes, sir. Q. This letter is dated March 30, 1970. And he's discussing a PCB product, and you knew it by the name Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49549 35 1 'Krumar,' did you not? 2 A. 'Krumar' was a -- Yes, that was the term used 3 to describe this particular mixture. 4 Q. It contained PCBs, did it not? 5 A. Yes . 6 Q. And you p painted -- people used it to paint 7 the inside of silos, did they not? 8 A. Yes . 9 Q. And it leached the PCB into the food that was 10 to be fed animals, in this particular case cows? 11 A. Yes . 12 Q. And the dairy milk became polluted with PCBs, 13 did it not? 14 A. Some of it. 15 Q. And the people drank the milk? 16 A. Some of it, yes. 17 Q. Andp people became polluted with PCBs, did 18 they not? 19 A. That I don't know. I don't have any evidence 20 to show me that. 21 Q. And Dr. Kelly was warning you in early 1970 22 that "We've got to tell the people or we are going to have 23 serious legal problems and publicity concerns," didn't he? 24 A. That's what he says. 25 Q. What did you do in response to that study Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49550 36 1 because n]p ow you're in charge of the environmental program 2 we discussed yesterday; isn't that right? 3 A. I don't know that I would use the word "in 4 charge." 5 Q. Well, (inaudible) but - 6 A. There were others who were heading it up. I 7 was helping them. 8 Q. What did you do? 9 A. In response to this letter? 10 Q. Yes. 11 A. I got in touch with Dr. Kelly and infojo rmed 12 him that he hadn't caught up with this yet. We had 13 already embarked on a program to phase out of that 14 particular application that he was talking about here. 15 Q. How long did that take (inaudible)? 16 A. Well, we finally -- we started this 17 particular activity in about December of '69, and we 18 totally stopped all sales to the paint applications in 19 August 30, 1970. 20 Q. Let's go to April 20,]p 1970, and we'll look at 21 some more corporate minutes on page 92. 22 A. I have it. 23 Q. The corporate minutes indicate, "Publicity 24 about PCBs has been limited to a few articles in 25 scientific publications and newspapers until Congressman Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49551 37 1 Ryan's press conference" -- Oh, my. Let me repeat that 2 again. "Publicity about PCBs has been limited to a few 3 articles in scientific publications and newspjo apers until 4 Congressman Ryan's press conference, implicating Monsanto 5 and the products." What were the products that the 6 corporate officers were talking about? 7 A. The PCB products. 8 Q. And what did you -- Do you know what -- They 9 use the word "implicate" Monsanto. At this particular 10 point in time nobody in Congress knew to what extent you 11 had distributed and manufactured PCBs, had they? 12 A.]p As of 1970, yes, many -- Did you say 13 Congress? I'm sorry. 14 Q. Congress did not know the scope of your 15 production. You hadn't given them sales figures, had you? 16 A. That is true. 17 Q. At this point in time they didn't even know 18 who all your customers were, did they? 19 A. That is true. 20 Q. And whereas Congress was trying to deal with 21 the scope of the PCB problem, they cap me to you and asked 22 you for a customer list, didn't they? 23 A. Congress never asked me for a customer list. 24 Q. You're quite correct. EPA. Tell me what 25 federal agency asked you for a customer list? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49552 38 1 A. Representatives from the EPA did, yes, sir. 2 Q. And (inaudible) 3 MR. CARNEY: Your Honor, may we approach the 4 bench, please? 5 (A benchjo conference was held.) 6 THE COURT: Why don't we go for about another 7 15 minutes, Mr. Kotoske? You may proceed. 8 Q. (By Mr. Kotoske) I want you to turn to page 9 94. By this time, Mr. Papageorge, Monsanto knew that 10 Congress was coming after Monsanto as a manufacturer of 11 PCBs ? 12 MR. CARNEY: Your Honor, I object to that as 13 a foul mischaracterization of the record of what Congress 14 (inaujo dible). I think he's mischaracterizing the record. 15 MR. KOTOSKE: I'll rephrase. 16 THE COURT: All right. Rephrase. 17 Q. (By Mr. Kotoske) Who was Congressman Ryan? 18 A. Congressman Ryan was the Congressman from 19 Manhattan, New York, who in 1969 -- Let me think -- '70 20 and '71 became interested in PCBs and attempted to enact 21 legislation regarding PCBs. 22 Q. He was a federal Congrejo ssman? 23 A. Yes, sir. 24 Q. And he was trying to enact legislation to 25 totally ban the production, manufacturing of PCBs; isn't Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49553 39 1 that right? 2 A. He tried to do that at his second attempt. 3 Q. In fact, he submitted legislation to Congress 4 to make it a criminal act to even manufacture this stuff? 5 A. As I remember, that is correct. 6 Q. On page 94, h]p ave you seen this letter before? 7 A. I don't believe I've seen the letter, no, 8 srr. 9 Q. It's from NEMA, National Electrical 10 Manufacturers Association? 11 A. It is. 12 Q. And you were selected to be the chairman of 13 that committee we discussed yesterday to coordinate a 14 response to Congress' effort to control PCBs both in the 15 water, in the ground. Do you remember that? 16 A]p . First of all, I was not chairman of the NEMA 17 committee. 18 Q. I understand. It's ANSI? 19 A. It's the ANSI committee. And the committee 20 met to draw up a standard on the proper way to handle PCBs 21 which had no relationship to what Congress was or was not 22 thinking about PCBs. 23 Q. You wanted to have a coordinated position, 24 did you not? 25 A. Well, certainly for a common effort, for a Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49554 40 1 common good. 2 Q. And that included Monsanto, Westinghouse, 3 General Electric, McGraw-Edison, Saginaw Weston and all 4 the (inaudible) and transformer manufacturers, not all of 5 them, but most of them? 6 A. And the EPA, the Department of Defense, 7 Department of Interior, the TVA Authority and many other 8 groups, yes. 9 MR. KOTOSKE: Your Honor, this is a 10 convenient^) place, and I will pick up with Mr. Papageorge' s 11 speech. If you'd like me to go into it now, I can. 12 THE COURT: Yes. Let's get into it. 13 Q. (By Mr. Kotoske) You gave a speech, if 14 you'll turn to page 100. Is that a speech you gave? 15 A. I didn't think of it as a speech. I 16 personally looked upon it as a status report on what I 17 knew of what Monsanto knew about PCBs and was sharing it 18 with this c]p ommittee that we just talked about, the ANSI 19 committee. 20 Q. For the record, that committee has a number, 21 it's ANSI, A-N-S-I, right? 22 A. Correct. 23 Q. And it was number 107, I believe, wasn't it? 24 A. It was C-107. 25 Q. I stand corrected. You're absolutely right, Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49555 41 1 C-107. So when we talk about ANSI 107, that is the 2 committee that you chaired; is that truejo ? 3 A. True. 4 Q. And that contained a membership of 5 Westinghouse, General Electric and so forth? 6 A. The group we described earlier, yes. 7 Q. These were the electrical equipment 8 manufacturing people in part? 9 A. In part, yes. 10 Q. All right. And this speech was given to the 11 ANSI committee; is that right? 12 A. Yes. 13 Q. All right.]o Before you gave these remarks, 14 did you think about what you were writing down here? Did 15 you intend to be careful and accurate? 16 A. As much as I could be, yes. 17 Q. Did you go back to the company records and 18 try to reconstruct as best you could what you knew about 19 PCBs at the time? 20 A. Yes. 21 Q. All right. You said on the first page, the 22 second paragraph, "We at Monsanto first heap rd of PCBs as a 23 potential environmental contaminant in early 1967 when we 24 received copies of a talk given in Sweden by Professors 25 Widmark and Jensen of the University Stockholm." Is that Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49556 42 1 statement correct? 2 A. It's correct in terms of copies of the talk. 3 It is incorrect in that we first heard of it in late ' 66 4 initially. 5 Q. You first were aware in 1966? p6 A. November or so of '66. And then this copy of 7 a talk confirmed that initial report. 8 Q. Now, I'm going to go down to the last 9 paragraph on this page, and you say, "During this period 10 Monsanto mounted an extensive program aimed at acquiring 11 more knowledge about PCBs and their effects on the 12 environment. We provided our analytical methods, and we 13 started animal toxicity studies," and so forth. Those 14 animal toxicity studies wer]o e the IBT studies? 15 A. Yes. 16 Q. Page 2, "Our animal toxicity work was similar 17 to the type we would have undertaken if we had wished to 18 have FDA approval for food use." Is that what you told 19 the people? 20 A. Yes. 21 Q. These were the IBT studies? 22 A. Yes. 23 Q. Still on the same page. "To summarize what I p24 have said about Monsanto's sponsored animal toxicity work, 25 a highly chlorinated, polychlorinated biphenyls at 100," Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49557 43 1 you go on to describe that they are toxic to some animals; 2 is that right? 3 A. Well, I prefer that you read what I have. 4 "Does have some effect on animals." 5 Q. Were you relying on the IBT studies? 6 A. Yes, sir. 7 Q. Now, if the studies weren't published until 8 November 12, 1974, and this speech was g]p iven in September 9 of '74, how did you know about those IBT studies? 10 A. This particular talk was dated '71. 11 Q. Pardon me? 12 A. By September '71 I had information regarding 13 the results of the studies. It took from September to 14 November of that year for the typing to be completed and 15 the printing process to be completed and the copies to be 16 distributed. 17 Q. Let me understand what yo]o u're saying. You 18 knew prior to the time the actual studies were finally 19 concluded what the results of the studies were? 20 A. What the principal, overall results, yes, 21 sir. I was getting reports every six to eight months on 22 the progress of the study. 23 Q. Now, you told us about three people that went 24 down to IBT and actually looked at the raw data. One of 25 them was Mr. Wheeler. The other was, I believe, a Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49558 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 p 19 20 21 22 23 24 25 44 Dr. Hunt, and the third guy was Levinskas, all Monsanto employees, right? A. They were Monsanto employees. I didn't know that I said they looked at raw data. They visited the laboratory and discussed in a professional way whatever toxicologists do. Q. You told us yesterday that they reported on the raw data to you, and you testified yesterday that they told you that those studjo ies would be conducted according to protocol? MR. CARNEY: I don't think he's exactly summarizing, as I heard it, what the testimony was. I think he's mischaracterizing. THE COURT: I'll let the witness disagree if he wants to disagree. It's overruled. You may answer, sir. A. I was kept informed that they were following the protocol. I know nothing about raw data. That's two different areas, as I see it. Q. (By Mr. Kotoske) What kind of information were you receiving on a periodic basis from IBT? A. I was receiving nothing from IBT. Q. Well, you just told us you were receiving reports. A. From Mr. Wheeler. He would give me a two- or Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49559 45 1 three-page summary about a paragraph or two on each of the 2 studies as to the findings to date.jp 3 Q. And did Mr. Wheeler ever tell you what he 4 based his conclusions on? Did he say, "Bill, I went down 5 and looked at the raw data. It looks good to me. Here's 6 my summary of what I found"? 7 A. That's roughly what he did, yes, sir. 8 Q. Did Mr. Levinskas do the same thing? Did he 9 go down there, come back and say, "Hey, Bill, I've been 10 down to IBT. I looked at the raw data. This is according 11 ]o to protocol." Is that roughly what happened? 12 A. Mr. Levinskas, if he did that, would have 13 told Mr. Wheeler. Mr. Wheeler would have communicated to 14 me. 15 Q. How about Bill -- Is Mr. Hunt's first name 16 William? 17 A. William Hunt, yes, sir. 18 Q. Did he tell you, "Papageorge, I went down to 19 IBT. I looked at the raw data. It's according to 20 protocol"? Did he come back and tell you]o that? 21 A. Not to me directly, no. 22 Q. He would have told that to 23 A. Mr. Wheeler, his boss. 24 Q. Then told you? 25 A. Mr. Wheeler was my contact Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49560 46 1 Q. That's how it worked? 2 A. Yes. 3 MR. KOTOSKE: This is a convenient place, 4 Your Honor. 5 THE COURT: All right. We'll stop for ten 6 minutjo es. We'll take a ten-minute break. Do not discuss 7 the case among yourselves or with others. Let's keep it 8 to ten minutes, please. 9 (A recess was taken.) 10 Q. (By Mr. Kotoske) We are on page 103 of 11 Exhibit 11, to your remarks to the ANSI committee. 12 A. I have it. 13 Q. And you told the committee, last paragraph on 14 that page, "There is a growing concern that we should be 15 con]o sidering to a greater degree chronic effects of all 16 these materials rather than relying on old acute studies 17 that used to serve as a screening for many, many 18 chemicals." Have I readthat correctly? 19 A. You did. 20 Q. When you referto all these materials, were 21 you referring to PCBs? 22 A. Yes. 23 Q. And in this vein you were conducting the IBT 24 studies to get more current toxicity informjo ation, were you 25 not? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49561 47 1 A. Yes. 2 Q. Going on, page 6, that would be 105. You 3 told the committee, "We have questions raised, 'Is it in 4 my shower curtains at home? Is it in my draperies, in my 5 carpet?' The answer to those is 'Not very likely,' and I 6 use those words because we really don't know." At this 7 point in time you had no -- Monsanto had no knowledge of 8 how far and how wi]p de the PCB problem was? 9 A. I wouldn't say we had no knowledge. We had 10 considerable knowledge. We lacked some detailed knowledge 11 on those sales that were made by distributors. That's the 12 only area where we didn't know what the final use would 13 be. 14 Q. Let me ask you the question point blank. You 15 did not know how toxic, you did not know the outer limits 16 of the toxicity of PCBs at this time? p17 A. I need help with that word "toxic" because 18 the extreme can be death, as we all know, but the word 19 "toxic" is used in my understanding to describe any 20 unwanted effect by a material on a living creature. 21 Q. Thank you. You did not know how far and how 22 wide PCB pollution was? You did not know to what extent 23 it had contaminated the milk supply in 1971? 24 A. No one knew. That's true. p25 Q. You did not know how far the water systems Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49562 48 1 had been contaminated? 2 A. That is true. 3 Q. You did not know how far and wide the fish 4 stocks in this country were contaminated? 5 A. That is true. 6 Q. You did not know and you still do not know to 7 what extent the human population is contaminated? 8 A. That is true. No one knows. p9 Q. Would you agree with me that to produce a 10 chemical like this without knowing these outer parameters 11 is reckless and done with conscious disregard for the 12 rights of the human citizens in this country? 13 A. No, I don't agree with you at all on that. 14 Q. Thank you. Page 111, secondparagraph, 15 "Because of this incident, Congressman Ryan withdrew the 16 first bill that was submitted and now has placed before p17 the same committee a bill which would totally ban PCB and 18 does not provide for any use whatsoever." By 1971 you 19 knew there was a Congressional effort to ban this stuff? 20 A. There was one Congressman's effort, yes. 21 Q. And you objected to what he was doing? 22 A. Certainly. 23 Q. It would have a tremendous impact on the 24 profitability of Monsanto and the sales from PCBs? 25 A. No. At thattime the profitability was Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49563 49 1 inconsequential to Monsanto. 2 Q. How much was it? 3 A. I don't recall a number, sir, but it was not 4 a star, if I use that word, product for Monsanto. 5 Q. Why didn't Monsanto just quit (inaudible)? 6 A. Because there was no fire-resistent 7 alternative available to use in this electrical equipment, 8 and it would be irresponsible to put products out there 9 that would resujp It in explosions and fires. I don't 10 believe I would like to stay in a Holiday Inn with a 11 transformer outside my door that might explode and burn on 12 me. That's the kind of situation that existed. 13 Q. There are thousands of transformers out there 14 today with PCBs in them? 15 A. Yes, there are. 16 Q. There are thousands of capacitors out there 17 today with PCBs in them? 18 A. Yes, there are.jp 19 Q. PCBs which you manufactured? 20 A. Right. 21 Q. Page 111, "We feel we have good technical 22 data to justify our staying in the business for limited 23 applications, but we cannot overlook the emotions that 24 have set in. And believe me, there are many and they are 25 deep." Continuing, "This is a real problem. In my Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49564 50 1 opinion it is a difficult problem." Is that what you told p2 the committee? 3 A. Well, you've skipped several sentences. 4 Q. I understand that I did. Is there anything 5 else that you would like to read? 6 A. Let me read and see what -- because that last 7 statement may refer to what you didn't read. 8 Q. Go right ahead. 9 A. Now, I've forgotten yourquestion. 10 Q. Did you make those statements to the 11 committee? 12 A.]o Yes, I did. 13 Q. And then you tell the committee on page 113, 14 "A thought we must all keep in mind, too, is that we've 15 got to live with the PCBs we introduced into the 16 environment for the past 40 years. They have not 17 disappeared overnight. They will not disappear overnight. 18 We do not have any tests that tell us how long it will 19 take." Did you make that statement? 20 A. I did. lip21 Q. Page 4, you told the committee, "I will 22 attempt to summarize. I think we can conclude that PCBs 23 are in the environment. There is no question about it. 24 Many of these PCBs are man-made and were introduced into 25 the environment because of our lack of understanding of Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49565 51 1 what these materials can do to the environment. In this 2 country Monsanto as the sole producer has attempted to 3 improve the situation by limiting the applicajo tions of 4 these materials to which these materials are used." Why 5 didn't you just stop right there? Why didn't you stop 6 making PCBs if you didn't have the understanding? If 7 Monsanto didn't have the understanding, why didn't you 8 just stop? 9 A. Not having understanding, sir, of how a 10 chemical is going to behave in the environment doesn't 11 mean that that chemical cannot be used for its benefits as 12 long as it' s]p not allowed to get into the environment. And 13 this was the intent that Monsanto had in mind. Let's 14 benefit from the safety features, keep it out of the 15 environment so you don't introduce these unknown questions 16 as to what's happening in the environment. 17 Q. Page 115, "In my personal opinion the emotion 18 that is now prevailing regarding PCBs is something that we 19 must contend with. Whether we believe in it or not, there p20 are many people that sincerely believe PCBs should be 21 totally banned." Did you make that statement? 22 A. I did. 23 Q. And Congress did, in fact, ban them by 24 (inaudible)? 25 A. Yes, many years later. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49566 52 1 Q. Fine. (inaudible) October 17, 1976. When 2 this speech was made was September 14, 1971? 3 A. Sir, as I understand it, in '76 Congress gave 4 the EPA authojo rity to consider regulating PCBs. 5 Q. Would you please turn to 116? 6 A. I have it. 7 Q. This is a letter? 8 A. It is. 9 Q. Dr. Levinskas, Monsanto Company? 10 A. He is the addressee,recipient. 11 Q. And he is being told on June 14, 1973 - 12 MR. CARNEY: Your Honor, may I object before 13 we get into this? Why don't you take a look at the 14 let]p ter, if you would.. I think you might object to the 15 obvious. 16 THE COURT: Yeah, it depends on how you're 17 going to use it. 18 MR. KOTOSKE: Exactly. 19 THE COURT: Be careful of the contents. Do 20 you want to come over or not? 21 MR. CARNEY: All I'm saying is the obvious we 22 all see. 23 THE COURT: Stay away from that. 24 MR. CARNEY: And, in addijo tion, the letter 25 isn't concerned with PCBs, at least the first two Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49567 53 1 paragraphs. 2 THE COURT: I'm going to let Mr. Kotoske 3 proceed, pursuant to my earlier ruling and trust that he 4 will steer the questioning the right way. 5 MR. KOTOSKE: I understand. 6 Q. (By Mr. Kotoske) Renate Kimbrough on October 7 14, 1971, was advising Monsanto of other toxic problems 8 associated^) with PCBs. 9 MR. CARNEY: Objection, Your Honor. That's 10 not true, and it's, I think, in violation of the order. 11 THE COURT: Come on over. 12 (A bench conference was held.) 13 (Ms. Pape replaced Ms. Carter.) 14 15 16 17 18 19 20 21 22 23 24 25 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49568 54 1 (A discussion was had at the Bench.) 2 Q. Doctor, page 116 of the letter from p3 Kim--Renate Kimbrough of October 14, 1971. Attached to this 4 letter are two studies showing toxical effects from exposure 5 to PCBs? 6 A. There are --I see what I think are reports from 7 three different studies. 8 Q. Correct. 9 MR. KOTOSKE: Three reports is correct, Your Honor. 10 Q. Three reports. The toxic effects on animals 11 from exposure to PCBs--you can answer that yes or no be]o cause 12 we have a ruling. 13 THE COURT: Just answer yes or no. 14 A. This first article is strange to me. I have 15 to read it over. This is the first I've seen it. I -- 16 Q. How about the other two articles? 17 A. The other two, the answer is yes. 18 Q. Now, at this time in 1971, did Monsanto have a 19 screening program for its workers involving cell tissue-take 20 a biopsy of]p the skin to see if there was any problems? 21 A. No, sir. 22 Q. Turn to page 123. I want you to look at pages 23 123, 129. Tell us what it is, when it's dated. Then I'm 24 gonna ask you some questions about it. 25 A. The pages you refer to are parts of a Monsanto Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49569 55 1 document entitled, A Standard Manufacturing Process for 2 Aroclors (Take-over distilled). 3 4p Q. Dated? A. And it's dated January, 1972. 5 Q. I want you to turn to the section on toxicity, 6 page 125. We're talking in this section of toxicity of PCBs, 7 are we not? 8 A. I am looking for it. 9 Q. Page 125, Section 3, Toxicity. 10 A. I find that section, but there is no reference 11 to PCBs there. 12 Q. Back to page 123. I'll just (inaudible). 13 Monsanto Indusjo trial Chemical Company, Functional Products 14 Group. Standard Manufacturing Process for Aroclors. See 15 that? 16 A. That's what I just read earlier, yes. 17 Q. Turn to toxicity on page 125. 18 A. I have it . 19 Q. It says, "The following toxic rating codes 20 will be used in describing the toxicity of these chemicals." 21 A. I see -- 22 THE COURT: The materials. 23 ]o MR. KOTOSKE: The materials, right. 24 A. I see that. 25 Q. A zero means none. One means slight. Three Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49570 56 1 means high. And a U means unknown; is that correct? 2 A. I see that, yes. 3 Q. And then it talks about biphenyl, does it not? 4 A. It does. 5 Q. Skip down to paragraph 6 where it says 6 toxic--toxic hazard rating. p7 MR. CARNEY: Your Honor, I'm gonna object on 8 relevancy grounds (inaudible). 9 THE COURT: (Inaudible) 10 (A discussion was had at the Bench.) 11 THE COURT: You may proceed. 12 Q. 'Barphenyl'--biphenyl is a component of PCB? 13 A. I wouldn't call it a component, sir. It's a 14 material you start with to make PCBs. p15 Q. Now, toxic hazard rating for biphenyl--an 16 acute local--it's got a U next to it? 17 A. That is correct. 18 Q. Is unknown? 19 A. That is right. 20 Q. Acute systemic ingestion and inhalation are 21 all marked three? 22 A. Yes. 23 Q. As high? 24 A. Yes. 25 Q. 'Cronic'--and I think that means Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49571 1 2 3 4 5 6 7 9 10 p 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 57 chronic--should be chronic? A. I agrejo e. Q. Chronic local toxicity rating is unknown? A. Correct. Q. Let's go to page 126. It states, "Biphenyl vapors are irritating to the upper respiratory tract. Workers should not be exposed to vapor levels throughout their shift in excess of the threshold limit values of one milligram per cubic meter of air"--or about two--pardon me--.2 parts per million. "The compound, or organic solutions of the compound can absorb through the intact skin; therefore, repeated skin contact should be avoided." True? Is that what it says? A. That's what it says for biphenyl, not PCBs now. Q. Turn to page 130. A. I have it. Q. This document is dated January 25, 1972. And I'm interested in paragraph 3. What we're looking at is a report to the Januajo ry meeting of the board of directors of the status of PCB implementation program. Is that the board of directors of the company? A. Yes, sir. Q. Now, on paragraph 2, it says, and I want you to read along with me. "All original equipment capacitor and Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49572 58 1 transformer" -- 2 MR. CARNEY: Your Honor, I--Your Honor --never mind. 3 THE COURT: Start over. p4 MR. KOTOSKE: All right. 5 Q. "All original equipment capacitor and 6 transformer customers for our PCB dielectric fluids were 7 notified on December 21, 1971, that further sales after 8 January 15th, 1972, would be dependent on receipt of 9 financially meaningful and acceptable hold harmless 10 agreements. To date, six companies have complied, which 11 represents 63 percent of the domestic dielectric sales: 12 General E]p lectric, Westinghouse, McGraw-Edison, ITE 13 Imperial"--and so forth. Every one of those customers of 14 yours, including Westinghouse, had to sign a hold harmless 15 agreement, did they not? 16 A. They did. 17 Q. That agreement provided in substance that if 18 anybody sued Monsanto for exposure to PCB, Westinghouse, as a 19 signer of that agreement, would indemnify and hold harmless-- 20 MR. CARNEY: Your Honop r-- 21 Q. --Monsanto? 22 MR. CARNEY: Your Honor, may we approach the Bench? 23 THE COURT: Sure. 24 (A discussion was had at the Bench.) 25 Q. Mr. Papageorge, I want you to turn to page 135 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49573 59 1 and 136, and I'm going to ask you to read for the jury what 2 that document is--just read everything on those two pages to 3 the jury. 4 TH]o E COURT: Not--without (inaudible) the areas we 5 talked about. 6 THE WITNESS: I understand. 7 A. This is on Monsanto letterhead and it's 8 entitled, Special Undertaking by Purchasers of 9 Polychlorinated Biphenyls. "Monsanto Company (Monsanto) 10 manufactures certain polychlorinated biphenyl products (PCBs) 11 which," blank blank, "buyer, desires to purchase. While 12 buyer desires to purchase PCBs because of certajo in desirable 13 flame resistant and insulator properties, buyer acknowledges 14 that it is aware and has been advised by Monsanto that PCBs 15 tend to persist in the environment, that care is required in 16 their handling, possession, use and disposition, that 17 tolerance limits have been and are being established for PCBs 18 in various food products. Monsanto has, therefore, adopted 19 certain restrictive policies with respect to its further 20 ]o production, sale and delivery of PCBs, including the receipt 21 of undertakings from its customers as set forth below. And 22 buyer is willing to agree to such undertakings with respect 23 to sales and/or deliveries of PCBs by Monsanto to buyer. 24 Accordingly, buyer herein covenants and agrees that with 25 respect to any and all PCBs sold or delivered by or on behalf Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49574 1 p2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 60 of Monsanto to buyer on or after the date hereof and in consideration of any such sale or delivery, buyer shall defend, indemnify and hold harmless Monsanto, its present, past and future directors, officers, employees and agents, from and against any and all liabilities, claims, damages, penalties, actions, suits, losses, costs and expenses arising out of or in connection with the receipt, purchase, possession, handling, use, sale or disposition of such PCBs by, through or unp der buyer, whether alone or in combination with other substances including, without implied limitation, any contamination of or adverse effect on humans, marine and wildlife, food, animal feed or the environment by reason of such PCBs. All existing contracts for the sale of PCBs by Monsanto to buyer are herein amended to contain the provisions set forth above. Nothing herein shall create or imply any duty or obligation of Monsap nto to sell or deliver any PCBs to buyer. No conditions, understandings or agreements purporting to modify or vary the terms hereof shall be binding unless hereafter made in writing, specifically referring to this agreement and signed by the party to be bound, and no modification or variance of the above undertaking shall be affected by the acknowledgment or acceptance of any sales document, purchase order, shipping i]p nstruction or other forms containing terms or conditions at variance herewith." And there are --there's a line with a Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49575 61 1 buyer designation and a Monsanto Company line, dates and 2 titles. 3 Q. Turn to page 143. 4 MR. KOTOSKE: You know, Your Honor, I'm going to a 5 whole different section. 6 THE COURT: How much longer are you going to be? 7 I'm not rushing you. Your total directjo --the rest of your 8 direct? 9 MR. KOTOSKE: I'm gonna (inaudible). 10 THE COURT: All right. It's up to you. If it's 20 11 more minutes or so, then we can keep going. If it's gonna be 12 longer than that, we'll stop now. 13 MR. KOTOSKE: It's gonna be longer than that. 14 THE COURT: Would you like to take a lunch break 15 now and start back at 1 o'clock? We'll take a one-hour lunch 16 break.]o Ask everyone to return at 1 p.m. Again, do not 17 discuss this case among yourselves or with others. See you 18 back here at 1 o'clock. 19 (A recess was taken, after which the 20 following proceedings were had.) 21 THE COURT: Proceed, please. 22 Q. I direct your attention to page 143 of Exhibit 23 11. 24 A. I have it. 25 Q. That's a memo o]o n which you were copied? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49576 62 1 A. Yes. 2 Q. Dated March 22, 1972? 3 A. Yes. 4 Q. Subject is PCBs in Japan? 5 A. Yes. 6 Q. Written on a letterhead, Mitsubishi Monsanto 7 Chemical Company? 8 A. Yes. 9 Q. Is that located in Japan? 10 A. Yes. p11 Q. Memo says, "No electrical machinery and 12 equipment which contain PCB must be manufactured as of 13 September 1, 1972; is that right? 14 A. That's what it says, yes. 15 Q. Japan was going to outlaw--ban PCBs, 16 September, '72. 17 A. Is that a question? 18 Q. Yes. 19 A. They were, yes. 20 Q. And as the author of the memo rightly points p21 out on page 145, quote, "The grand funeral of PCB is close at 22 hand." Is that right? 23 A. That's true. 24 Q. Monsanto, however, continued to manufacture 25 PCBs? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49577 1 2 3 4 5 6 P7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 63 A. Yes, sir, because of the difference in electrical systems in the two countries. Q. I want you to turn your attention to page 148. This is a document you authored; is it not? A. Yes, it is. Q. Who is it directed to? A. Dr. Martha Sager, Chairman of Effluent Standards and Water Quality Information-- THE REPORTER: What? A. Effluent Standards and Water Quality Information Advisory Committee to the Environmental Protection Agency. Q. And it's dated? A. The date is July 13, 1973. Q. Did you sign the document? A. Yes, I did. p MR. CARNEY: Your Honor, I'm gonna object on relevance grounds. We made the objection in chambers. THE COURT: I'll sustain unless there's some particular part of it that relates to what we're talking about. MR. KOTOSKE: Look at background in your first sentence on the background. See that? A. I do. MR. KOTOSKE: No, I'm talking to the judge. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49578 64 p1 THE COURT: Still don't see it. You want to go 2 over or-- 3 MR. KOTOSKE: Yeah, let's (inaudible). 4 (A discussion was had at the Bench.) 5 Q. I'm gonna read some sections from this--what 6 would you call this? A report or a letter or a standard 7 report or what of the EPA? 8 A. Well, it's a letter to Dr. Sager in an attempt 9 to quickly summarize Monsanto's position regajo rding water 10 standards. 11 Q. I understand. I'm gonna read a couple things 12 here from this letter that you wrote, and I'm going to ask 13 you whether that's correct. On page 148. "Monsanto has been 14 a major manufacturer of chemical products since 1901." Is 15 that true? 16 A. That's true. 17 Q. You go on, "The chemical structure of PCB has 18 been known for nearly 100 years. It was not untiljo the late 19 1920s that a use for PCB was found--as a dielectric fluid in 20 transformers and capacitors." Is that true? 21 A. That's true. 22 Q. "Monsanto began the commercial production of 23 PCBs in 1929." Is that true? 24 A. Not technically. The company purchased by 25 Monsanto started in 1929. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49579 65 1 Q. Well, is the statement that you gave the EPA 2 true or not? (]p Inaudible)? 3 A. Well, I don't either, sir. To me, Swann 4 Chemical and Monsanto are the same thing. 5 Q. Thank you. "Today"--page 150--"PCB 6 manufactured by Monsanto Company is sold to the electrical 7 industry where it is used in closed systems as a dielectric 8 fluid in transformers and capacitors." Is that true? 9 A. I have lost the page, sir. 10 Q. Top sentence, page 150. 11 ]p A. 150? That's true. 12 Q. Same page starting with recognizing. 13 "Recognizing the need for proper controls in the handling and 14 use of PCBs, representatives of the transformer and capacitor 15 industries, utilities and government agencies under the 16 initial auspices of the National Electrical Manufacturers 17 Association formed American National Standards Institute 18 Committee C-107." Is that true? 19 p A. That is true. 20 Q. That's the committee you were talking about? 21 A. Correct. 22 Q. That's the committee you chair? 23 A. Yes. 24 Q. Page 151. Quote: "On the basis of available 25 evidence, it would appear that PCBs pose less of an acute Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49580 66 1 toxic health hazard than many substances not proposed for 2 your list and at the levels found in the total environment^ 3 are not a threat to public health." That was your position 4 on July 13th, 1973, with the EPA? 5 A. That is true. That is true today. 6 Q. You go on, "It is our considered opinion 7 that 8 A. What page? 9 Q. 152. 10 A. I have it. 11 Q. "It is our considered opinion that in the 12 absence of critical basic scientific data, any attempt to 13 ]o establish a PCB standard for water effluents at point sources 14 would be premature at this time." 15 MR. CARNEY: Your Honor, I didn't know that was 16 gonna be read. I thought that was -- 17 THE COURT: I agree. That's--that's beyond what we 18 talked about. I'm--I'll entertain a motion and it will be 19 stricken. 20 MR. KOTOSKE: You don't have to. I'll withdraw the 21 question. 22 THE COURT : ]p Withdrawn. 23 BY MR. KOTOSKE: 24 Q. Now, I want you to turn to page 154. 154 and 25 the pages thereafter that summarize this meeting that was Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49581 1 held. Please go to 172. 67 2 A. 172. 3 Q. I want to talk to you about this meeting. 4 Yeah, 172. Now, I can't expect you to read that whole 5 memorandum. Have you ever seen it before? 6 A. Certainly. 7 p Q. All right. Are you familiar with it? 8 A. Yes, sir. 9 Q. All right. 10 MR. CARNEY: Your Honor, I would object here. This 11 is on the subject matter we just talked about. 12 THE COURT: I make the same ruling, and stick to 13 the issues. 14 MR. KOTOSKE: I am. Thank you. There's a reason 15 for this memorandum. It hasn't--it doesn't have to do with 16 the (inaudible^) ) and so forth. 17 BY MR. KOTOSKE: 18 Q. Where did this meeting occur on February 28, 19 1974? 20 A. Where? 21 Q. Where. 22 A. In St. Louis. Monsanto's office. 23 Q. It was held in your offices? 24 A. Yes . 25 Q. Now, the purpose of this meeting is stated on Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49582 1 the next page, 155. 68 2 A. That is correct. 3p Q. "The purpose of the meeting"--reading from the 4 document--"was to share information, experiences and 5 impressions"-- 6 MR. CARNEY: Your Honor, I'm gonna object. 7 Q. --"to help each of the participating 8 companies" -- 9 MR. CARNEY: Your Honor, I'm gonna object here. I 10 think this is something that's covered by your ruling you 11 just made. 12 THE COURT: I'm gonna o]o verrule the objection. I do 13 admit it uses some of the language therein. I'm gonna let 14 him do it with cross examination--you have the right to bring 15 out the fact that it's--there is some irrelevancy in the 16 general purpose, but he can ask the question. Go ahead. 17 Q. Let me start over. First of all, you are the 18 chairman (inaudible)? 19 A. Yes, sir. 20 Q. And the purpose of the meeting is statjo ed. 21 "The purpose of the meeting was to share information, 22 experiences and impressions to help each of the participating 23 companies in taking appropriate actions which are mutually 24 supportive and effective in persuading the administration of 25 EPA to modify the proposed PCB Effluent Standard." That was Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49583 69 1 the idea of it all, right? 2 A. Yes . 3 Q. Now, I want--I want to know the particp ipants 4 Turn to the next page. Because they're listed here, are they 5 not? 6 A. They are. 7 Q. General Electric well-attended by three 8 persons; is that true? 9 A. Well, this is the anticipated list of 10 attendees. I-- 11 Q. You don't deny that Westinghouse had 12 representatives there? 13 A. Yes, but I don't know if they are these 14 specific individp uals listed. 15 Q. I don't care about that. I want to know if 16 there were representatives there from General Electric. 17 A. There were. 18 Q. From Westinghouse? 19 A. Yes . 20 Q. Monsanto? 21 A. Yes . 22 Q. You had scheduled to be there yourself. 23 Benignus 9 24 25 'E P1 2 A. Yes . Q. And Mr. Paul Wright? 6 A. Yes. Q. Manager, Toxicology? 3 A. Yes . 4 Q. You had--you had an agenda prepared for this 5 meeting, did you not? 6 A. Yes, sir. 7 Q. And one of the sections in that agenda was 8 toxicity --acute and chronic. We're talking about human 9 beings here, are we not? 10 A. No, everything. All known toxicity. Fish, 11 birds--whatever p was known. 12 Q. Including humans? 13 A. Yes . 14 Q. Now, as one reads through this memorandum, 15 each participant--General Electric had certain tasks to 16 perform, Westinghouse had certain tasks that they were gonna 17 perform, and you were gonna have a coordinated effort with 18 respect to the electrical industry's presentation to the EPA 19 in connection with its efforts to regulate PCBs; is that 20 p true? 21 A. That is true, yes, sir. 22 Q. Now, I want you to bear with me for a minute. 23 I want to look at the section that Paul Wright was 24 (inaudible). Do you see, for example, on page 164--I want to 25 read the --at the bottom. You on page 164? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49584 1 A. I am. 70 2 Q. "Mr. Wright (Monsanto) went through the 3 rationale used by EPA in arriving at a PCB discharge 4 p maximum"--and then it's stated. "He also showed how the 5 standard could be changed" -- 6 MR. CARNEY: Your Honor, I think we're talking 7 about -- 8 Q. --"and yet be" -- 9 MR. CARNEY: Objection, Mr. Kotoske. Here we're 10 talking about clearly the area of effluents. And I think 11 your ruling-- 12 MR. KOTOSKE: That's not what-- 13 14]o 15 MR. CARNEY: That is what this case is about. THE COURT: I know that. I'm gonna let --I'm gonna overrule the objection. I stand by my earlier ruling about 16 that other issue. 17 MR. KOTOSKE: You know what I'm doing, Judge. I'm 18 not interested in how much PCBs in (inaudible). 19 THE COURT: You're allowed to continue as long as 20 you remember what my rulings are and how (inaudible). 21 Q. Back on page 146--and I'm gonna read it again 22 p because I was interrupted--"Mr. Wright of Monsanto went 23 through the rationale used by EPA in arriving at a PCB 24 discharge maximum. . . He also showed how the standard could 25 be changed and yet be consistent with published data on Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49585 71 1 PCBs." Were you present when he gave those remarks? 2 A. Yes. 3 Q. Now, I want to do one other thing. You 4 decided amongst yourselves at this meeting that youp were 5 gonna make a presentation to the EPA. I'm on page 172. 6 A. I have it. 7 Q. You were definitely gonna show up--somebody 8 from Monsanto was gonna appear; is that right? 9 A. Yes. 10 Q. Were you gonna do yours by way of affidavit or 11 what? I will tell you that your vice-president, Fitzgerald, 12 showed up to testify in this (inaudible). Were you gonna put 13 in some technicap 1 data? 14 A. I am confused by your statement -- 15 Mr. Fitzgerald showing up at a water effluent standards 16 meeting. 17 Q. No, I'm talking about the data. How were you 18 gonna carry out the role that you were given? 19 A. For the effluent standards? 20 Q. Yes. 21 A. Personally be present and read from a prepared 22 outline. 23 Q. And then GE was given certainp tasks on page 24 172? 25 A. Yes. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49586 72 1 Q. And they were gonna explain why PCBs are 2 used--the consequence of a ban and so forth? 3 A. Yes. 4 Q. What was Westinghouse's role? 5 A. Supportive of GE. 6 Q. Now, were GE, Westinghouse and Monsanto the 7 three major players in this effort to persuade EPA to change 8 standards of--to regulatejo PCBs? 9 A. I don't know how to describe--they were, of 10 course, the bigger companies represented, but there were 11 others there that were just as interested and just as active. 12 Q. All right. Now, turn to page 174. That's a 13 letter from Monsanto to the EPA enclosing your affidavit? 14 A. It is. 15 Q. And there appears your affidavit to the EPA 16 under oath; isn't that true? 17 A. True. 18 Q. Let's move through a little 19 inaudible). If you'll turn to page 189. 20 A. I have it. 21 Q. That's your signature? 22 A. Yes, it is. 23 Q. You signed this affidavit? 24 A. Yes . 25 Q. Under oath? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49587 1 A. Yes. 73 2 Q. Penalty of perjury if it's--if there were 3 an]p ything false? 4 A. That's my understanding. 5 Q. Sent it to EPA? 6 A. Yes. 7 Q. Concerns PCBs? 8 A. Yes. 9 Q. Attempts by EPA toregulate PCBs? 10 A. In waterways, yes. 11 Q. You state on page 175, "I am a member and have 12 served as chairman of a committee of the National Electrical 13 Manufacturers Association which has reviewed th]p e 14 environmental effects of PCBs and has recommended procedures 15 to users of PCBs which should minimize the possibility of 16 entry of PCBs into the environment." Did you make that 17 statement? 18 A. Yes, sir. 19 Q. Next page. You state, "The proposed effluent 20 standards for PCBs are unwarranted and practically and 21 economically unattainable." Did you make that statement? 22 23 p A. I did. Q. Did you believe when you signed this document 24 that PCBs should not be regulated? 25 A. Yes, I did. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49588 74 1 Q. You stated, "The definition of PCBs in section 2 129.09a, Subpart I, should be changed to read"--and then you 3 suggest a definition of PCBs? 4 A. Yes. 5 Q. Don't you? 6 A. Yes, I did. 7 Q. And then you go on, "The pp roposed PCB effluent 8 standard is based on inadequate toxicity information, on 9 nontypical fish species and on an unusually high and 10 artificial bioaccumulation factor." Did you make that 11 statement? 12 A. Yes, I did. 13 Q. Where did you get that information from? 14 A. Got that from our own Monsanto scientists. 15 Q. Who? 16 A. Well, it depended on the type of informatiop n. 17 The toxicity information came out of Mr. Wheeler's office. 18 Q. Thank you. That's all I need to know. The 19 upshot of this affidavit was your objection--Monsanto's 20 objections to the regulation of PCBs in water? 21 A. It's the objection to an unreasonable level in 22 water. 23 Q. What did you think was a reasonable amount of 24 PCBs in water? (Inaudible.) Was there -- strike that 25 questip on. Was it Monsanto's position at the time you sent Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49589 75 that affidavit to the EPA that there was a reasonable amount of PCBs that people should tolerate in their drinking water? A. We're not talking drinking water, sir. Q. What kind of water are we talking about? A. Water in the natural streams in the environment. Q. People, of course, don't drink that? p A. Well, I mean I can't say that. Some people do. Q. How much did you think was reasonable for us to have in our waterways ? A. In our waterways? We were convinced that ten parts per billion in the waterways was something that the environment could cope with and tolerate and would cause no harm. Q. You figured in your collective wisdom over here at corporate headquartjo ers that this country could stand to have ten parts per billion in the water? A. As the maximum. Q. Okay. A. Yes, sir. (Ms . Pape was replaced by Ms. Olliges.) Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49590 76 1 Q. Would you turn to page 184? It says there 2 the cumulative sales of PCBs in the United States since 3 1930 has been estimated to be about 500,000 tons. Is that 4 p5 6 true? A. Q. As best as I could determine, yes. And that the total world production was 7 probably one million tons? A. That was the number used by all the 9 authorities at that time, yes, sir. 10 Q. Monsanto produced half of all the PCBs on 11 this planet? 12 A. I haven't made a comparison of the two. We 13 did make quite a few of them. I don't know if it was a 14 half or not. 15 Q. Another statement you make, page (181), 16 "Although many reports have been published on the subject 17 of polychlorinated biphenyls and living organisms, the 18 majority of these describe the presence of PCB in the 19 environment. Presence should not be assumed to imply 20 adverse effect." What did you mean by that? 21 A. I meant that the mere fact that the 22 analytical chemist with his sophisticated instrument was 23 p able to detect the chemical in an environmental sample did 24 not necessarily mean that that PCB had caused any harm or 25 was going to cause any harm. It depended on too many Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49591 1 2 3 4 5 p6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 77 other conditions regarding what kind of place it was in and what creatures were near it and so on. Q. Please go forward in the exhibit to page 191. This is a letter addressed to you from Westinghouse dated February 3, A. Q. 1975; is it not? It is. Did you receive it? A. Yes. Q. And in this letter, Westinghouse is asking Monsanto about the toxic effects of this chemical, PCBs, and they attach to it a list of questions. Did you read those questions? A. Certainly. Q. I'd like to read a few of them. First, the cover letter says, "Attached you'll find the list of questions^ that have been asked by our employees regarding the use of Inerteen. Mr. Garry Wilburn, our Engineering Manager, felt if these questions could be answered you would be the man to answer them." Is that what it says? A. It does. Q. Let's look at thequestions that the Westinghouse employees are asking in 1975. MR. CARNEY: Let me object. He mischaracterizes. This is a plant in South Boston, Virginia. He's implying it's Bloomington. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49592 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 'O P1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 78 THE COURT: That's correct. MR. KOTOSKE: It's a Westinghouse - THE COURT: Do you accept that correction? MR. KOTOSKE: Of course I do. THE COURT: Let's proceed. Q. We all know that. These Westinghouse employees are asking questions. What do they make at that Westinghouse pl]p ant in Virginia? A. Transformers. Electrical transformers. Q. Here's one of the questions. "Question - Does Inerteen have permanent effects on the human body? If so, what type of permanent damage and how long a period of time does it take for this to develop? If not, explain why, if possible." You think that was an important question to ask? A. Certainly. Q. Here's another p question (inaudible). "Since Inerteen effects birds and other animals, if there is no real effect on human beings, how do you explain it to the employees in such a way that they will understand why you can kill a bird and not a human?" Did you think that question was important? A. Yes. Q. "If an employee spills Inerteen on his clothing and later takes the clothing home to be washed 6 with other clothes, will this have any effect on he or his family and should he carry his clothes home to be washed?" Did you think that was an important question? A. Certainly. Q. Let me read one more. "Employeescarry Inerteen home on soles of their shoes and complain quite a bit about the effect Inerteen has on wearing out their shoes. Is this a serious problem? Will Inerteen in the soles andjo leather of shoes, over a long period of time, have an effect on the feet and skin since the shoe is the only protective equipment we wear on our feet and the Inerteen penetrates through the leather?" Do you think that was an important question? A. Certainly. Q. These are the kind of questions you should be addressing in your labels, your warning labels to workers who use this PCB; isn't it? p A. No, sir. Q. These are the kind of questions that employees at Westinghouse need information on to be adequately warned about the dangers of Inerteen; isn't that true? A. The employees at Westinghouse, at least through their management, had been informed of what to do to avoid ever reaching these conditions. They should Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49593 p2 9 10 Vp 1 12 13 14 15 16 17 18 19 20 2p 1 22 23 24 25 79 never have experienced these if they followed what was already on the label. Q. But if we believe you, Mr. Papageorge, why do you think these employees were asking questions? MR. CARNEY: Well, I'm going to object. It calls for this witness to speculate about somebody in South Boston, Virginia. THE COURT: I'll sustain that. Proceed. Q. Well, Mr. Papageorge, on page 193, you acknowledge that you have received a letter from Westinghouse and that you're going to have the medical department answer the questions; right? A. I do. Q. Is that your signature on that document, 193? A. It is. Q. (Inaudible) you wrote anothermemo before these answers were sent down to Westinghouse; didn't you? It appears on 194. A. I see that, yes. Q. Let me read that memo. Does it bear your signature? A. No. That was signed by my secretary. Q. Did you dictate it? A. Yes. Over the telephone. Q. And you dictated it -- Who did you dictate it Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49594 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 p 16 17 18 19 20 21 22 23 24 25 80 to? A. Mr. H. R. Ford, a Monsanto employee in Atlanta, Georgia. Q. And why did you dictate this memo to him? A. He was the district manager, the person of hi]p ghest position in that area who was near this plant, and I was asking him to personally deliver the message since I couldn't personally deliver it. Q. There's a copy of this memo that's sent to E. P. Wheeler. We know who that is. A. Yes . Q. Who's D. Wood? A. David Wood at that time was the marketing manager for PCBs. Q. Now, the memo says, "Attached is the original letter addressed to Mr. Dan A. Albert of Westinghouse, South Boston, Virginia. The contents of this letter have been reviewed with David Wood, and it was agreed that the letter be delivered by you personally to South Boston, giving you an opportunity to discuss with the Westinghouse representatives the proper approach that must be taken in presenting this information to avoid undue concerns and misunderstandings. Will you ple]p ase deliver this letter as soon as practical." You wanted this fellow to go over and hand-deliver this? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49595 81 1 A. Yes, sir. 2 Q. You didn't want to raise undue concern? 3 A. That is correct. 4 Q. What were you concerned about? 5 A. Well, I've been experienced enough with 6 working people who upon hearing some information regarding 7 health misunderstand, and they ]o get so concerned and 8 worried, and I don't believe it's responsible to cause 9 people to worry needlessly. 10 Q. Did you think - 11 A. It's just not responsible to cause them to 12 worry without making sure they understand what was said. 13 That's why I was concerned that the message was conveyed 14 in a very responsible kind of way, not to whitewash it, at 15 the same time not to leave the wrong impression. 16 Q]p . Do you think it's irresponsible to tell the 17 people the truth? 18 A. Absolutely not. 19 Q. Even if they find it concerning and have 20 problems with the truth, you've got to tell them? 21 A. That is true. 22 Q. Even if it upsets them, you've got to tell 23 them the truth? 24 A. True. But don't mislead them to worry 25 needlessly. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49596 82 1 Q. You were wor]p ried that the employees at that 2 plant when they found out what I'm about to read, the 3 answers to those questions, they would be upset; weren't 4 you? 5 A. No, I wasn't, because I assumed that they 6 already heard most of these. 7 Q. Then you don't have any concern? 8 A. That is true. That's good -- 9 Q. But you just told Mr. Wood you were 10 concerned? 11 A. You can take any]o sentence in here and create 12 unnecessary misunderstandings. So one must be very 13 careful how it's described. 14 Q. The first question, "Does Inerteen have 15 permanent effects on the human body? If so, what type of 16 permanent damage and how long a period of time does it 17 take for this to develop? If not, explain why," et 18 cetera. And here's your answer. "The polychlorinated 19 biphenyls in Inerteen have permanent effects on ]o the human 20 body." 21 A. Can have. 22 THE COURT: Can have. 23 Q. "Polychlorinated biphenyls in Inerteen can 24 have permanent effects on the human body." 25 A. Correct. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49597 83 1 Q. "The length of time or period of exposure 2 necessary to develop symptoms depends on the degree or 3 amount of exposure." 4 A. True. 5 Q. The problems are --]p I'm skipping down. No. 6 I'm going to read them all. "In general, a single 7 exposure for a few minutes to atmospheric concentrations 8 that cause irritation to the eyes and/or respiratory tract 9 would not be expected to cause either skin eruptions or 10 demonstrable liver injury. The problem arises from 11 repeated and prolonged exposure to atmospheric 12 concentrations in excess of the accepted Threshold Limit 13 Levels or repeated and prop longed skin intact." 14 MR. CARNEY: Skin contact. 15 Q. Reading on, "The potential toxic effects in 16 humans from excessive exposure to polychlorinated 17 biphenyls include injury to the liver and chloracne. In 18 animals, the liver effect is demonstrated by increased 19 liver weights and injury to cellular tissue. Although 20 chloracne is difficult to evaluate in animals, in humans, 21 this takes the form of comedones (larp ge blackheads with 22 typical acute pustules) and may be an external symptom of 23 overexposure preceding serious liver injury." 24 You go on to say to question number three, 25 "Since Inerteen effects birds and other animals, if there Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49598 84 1 is no really effect to human beings, how do you explain it 2 to employees in such a way that they will understand why 3 it can kill a bird and not a human?" And you answered, 4 p "There is a potential real effect to humans - including 5 death - as discussed in the answer to Question 1." 6 To the question about carrying Inerteen home on 7 their shoes and so forth, you people wrote, Monsanto 8 wrote, "There should not be polychlorinated biphenyl on 9 the floor for workmen to contaminate their shoes to carry 10 home. The plasticizer or solvent action will destroy or 11 shorten the life of the shoes. More importantly, wea]o ring 12 of contaminated shoes could lead to absorption of the 13 liquid through the soles of the feet as through any other 14 unbroken skin surface." 15 I'm going to ask you something, Mr. Papageorge. 16 You were still making polychlorinated biphenyls and 17 selling them when you wrote that, when Monsanto answered 18 those employees' questions? 19 A. Yes. 20 Q. Did you ever change your warning label on 21 drumjo s or tankers or trucks, however you people sold this 22 stuff, to include the information that I just read to you 23 in the form I just read it to you? 24 A. No, sir. 40 years of experience showed us 25 that what we had on the label was working beautifully. It Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49599 85 1 worked so well that we were quite -- 2 Q. You've answered the question. 3 MR. CARNEY: Let him finish. 4 THE COURT: ]p Let him finish the sentence. 5 Then move on. Finish the sentence. 6 A. I've forgotten what I started to say. But, 7 nevertheless, the message that existed on those labels for 8 decades worked so well that for 40-plus years we did not 9 have any reports from anywhere that employees working with 10 PCB liquids were being harmed in a permanent way, even to 11 the ultimate of death, which you've indicated here. There 12 just was no evidjo ence to say, "Your labels are not 13 adequate. You better change them." It was working. Why 14 bother with something that was working? 15 Q. Was medicine changing during that 40 years? 16 Did science change? 17 MR. CARNEY: With regard to PCBs? 18 MR. KOTOSKE: Absolutely. 19 A. There was no new evidence that would say the 20 label as worded was not doing the job and was not proper. 21 Q.]p Turn to page 203. 22 A. Okay. 23 Q. Were you still using IBT as late as 1975? 24 A. Yes, sir. 25 Q. Carrying out laboratory studies? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMON0049600 86 1 A. Yes, sir. 2 Q. Was Mr. Calandra still president of that 3 company in April of 1975 as far as you know? 4 A. Yes, sir. 5 Q. And you were CC'd on this letter dated April 6 17th, 1975, appearing g as page 203 of Exhibit 11. Did you 7 receive a copy of this letter? 8 A. I did. 9 Q. Did you read it? 10 A. Yes, sir. 11 Q. It says, "Ifully appreciate that the meeting 12 on PCBs today was not completely satisfactory and that 13 many nagging questions remain." What was Mr. Calandra 14 talking about? 15 MR. CARNEY: Your Honor, I think he may have 16 to -- You want to approachjo the bench? 17 THE COURT: Just a moment. 18 (A bench conference was held.) 19 THE COURT: You may rephrase your question or 20 restate it. 21 Q. (Inaudible.) Let me start over again. Are 22 you on page 203? 23 A. Yes, I am. 24 Q. All right. Who is George Roush at Monsanto 25 Company? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49601 1 2]p 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 87 A. He is the Monsanto medical director who replaced Dr. Emmet Kelly. Q. You are the William Papageorge on the distribution? A. I am. Q. And you received your copy? A. I did. Q. On or about the day indicated? I don't mean the next day, but in a reasonable amount of time? A. Yes, sir. Q. You didn't have any problem getting your mail out at Monsanto? A. Nop . Normally no. Q. George Levinskas is this fellow we've been talking about in this trial; isn't it? A. His name has come up. Q. And Mr. Wheeler, his name has come up? A. Yes, sir. Q. They also received copies ofthisletter according to the distribution (inaudible)? A. Yes. Q. Now, I want you to turn to page 209, to a letter dated July l]o 8th, 1975. MR. KOTOSKE: Your Honor, could I offer these in evidence independently? The whole exhibit is in -- Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49602 CO CO 1 THE COURT: We've been calling it Exhibit 11 2 I think. 3 MR. CARNEY: We went through this page by 4 page 5 THE COURT: That's right. You did. 6 MR. CARNEY: So I think it will be on the 7 record. 8 THE COURT: p The record (inaudible). 9 MR. KOTOSKE: Thanks. That will save me a 10 whole lot of time. 11 MR. CARNEY: I don't think it's all been 12 received is what I'm saying, so there's no 13 misunderstanding. 14 THE COURT: Why don't we tie it up later on? 15 We can go through it and then (inaudible). 16 Q. You're on page 209, sir? 17 A. I am. 18 Q. This letter is written bp y George Levinskas. 19 Is that his signature? 20 A. This is a poor reproduction, sir. I really 21 can't tell. 22 Q. He was employed as the Manager, Environmental 23 Assessment and Toxicology, on or about July 18th, 1975? 24 A. He was. 25 Q. At Monsanto? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49603 89 1 A. Yes . 2 Q. All right. Now, I want you to look at this 3 letter dated August 4, 1975 from Mr. Cap landra to Monsanto, 4 specifically to George Levinskas, Manager of Environmental 5 Assessment and Toxicology. 6 A. Can you give me a page number, sir? 7 Q. (Inaudible) 212. 8 A. I have it. 9 Q. Did you ever see a copy of that letter? 10 A. I have seen a copy of this letter as it 11 related to a case. 12 Q. A case involving Monsanto? 13 A. Yes, sir. 14 ]p Q. All right. In which you testified? 15 A. I either testified or was deposed. I don't 16 recall which. 17 Q. The letter is familiar to you? 18 A. Yes. 19 Q. Now, I want you to turn to page 213. I'm 20 going to start a different subject matter here. If the 21 jury can bear with me, I've got about a half an hour. 22 THE COURT: Fine. 23 MR. KOTOSKE: Maybe 20 minutes. 24 THE COURT: Then we'll take a break. 25 Q. Along about October 17th, 1975, the EPA had Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49604 90 1 now been seeking information from Monsanto; is that 2 correct? 3 A. Yes. This is one of -- an example of that 4 kind of request. 5 Q. They sent a list of questions to you to 6 answer; did they not? 7 A. They did. 8 Q. And those questionsarecontained on]opages 15 9 through -- 215 through 219; is that right? 10 A. That is correct. 11 Q. One of the questions that the EPA asked you 12 is No. 10, and here's what EPA asked you to provide them 13 with. A description - 14 THE COURT: Is that on page 218? 15 MR. KOTOSKE: Yes. 16 MR. CARNEY: Your Honor, can I record an 17 objection as to the relevancy of that? If you want to a 18 p take a look and read it (inaudible). 19 THE COURT: Well, as long as you stay away 20 from the effluents question (inaudible). I'll let you ask 21 the question as long as you stick to that area. Proceed. 22 Overruled. 23 Q. Question No. 10, "A description of any 24 adverse health or environmental effects which you know or 25 believe to have resulted from the introduction of PCB Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49605 91 1 compounds or mixtures i]p nto the environment. Indicate any 2 specific occasions, including, dates, times, locations, 3 amounts, parties involved," and so forth. And you were 4 asked to answer that question? 5 A. I was. 6 Q. Now, turn to page 220. 7 A. I have it. 8 Q. This is Monsantomemo written by this David 9 Wood? 10 A. Yes, it is. 11 Q. And he, as I understand, is in marketing? 12 p A. Yes, sir. 13 Q. And it's his comments on these questions that 14 we're going to read; is that right? 15 A. They appear to be. Yes, they are. Uh-huh. 16 Q. And he says with respect to Question No. 10 17 on page 221, he states -- 18 MR. CARNEY: Are you talking about Question 19 No. 10? 20 MR. KOTOSKE: That's right. 21 MR. CARNEY: I see it on page 220. Right?!) 22 THE COURT: The answer is. 23 MR. CARNEY: You said 221. 24 MR. KOTOSKE: I'm looking at page 221 for the 25 answer to Question No. 10. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49606 92 1 MR. CARNEY: Okay. Yeah. 2 THE COURT: Okay. Go ahead. 3 Q. And the answer by Mr. Wood to this particular 4 question about adverse health effects is -- We shouldn't 5 be saying none. He writes "none" p to the question. 6 "Yusho" with a question mark. "Chloracne years ago - 7 Dangerous question." Is that what Mr. Wood wrote? 8 A. He wrote that, but you described it as an 9 answer. These are Mr. Wood's reactions to the question. 10 Q. He thought that that question was a very 11 dangerous question? 12 A. He apparently did; otherwise, he wouldn't 13 have written it that way. 14 Q. Did you receive th]p is back from Mr. Wood? 15 A. Yes, I did. 16 Q. When you received his response, which was 17 apparently a choice between none, Yusho, chloracne years 18 ago, or dangerous question, how did you choose to answer 19 that question to the EPA? 20 A. First, I don't interpret this as a choice. 21 The way I read it, Mr. Wood is saying are there any? In 22 other words, none? Is Yusho an environmental kind of 23 exposure? p And the chloracne that we experienced years 24 ago, does it fit the question which says due to 25 environmental? And he says "Dangerous question?" And Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49607 93 1 only he knows what led him to use the word "dangerous". 2 Q. Let me ask you something. Why in the world 3 does Monsanto have a guy from marketing even answer these 4 type of questions? 5 A. Well, sir, he's not answering. He's trying 6 to be helpfuljo to me. He volunteered the sheet and sent it 7 to me. 8 Q. I don't mean to be flip, but why in the world 9 didn't you use the medical department to answer that kind 10 of question? 11 A. Well, I did. 12 Q. Let's see what they say. Their answer is on 13 page 241, Question No. 10. Of course, you're trying to be 14 helpful to the EPA, give them all the information that you 15 have available; isn't that right, M]p r. Papageorge? 16 A. That was the intent, yes, sir. 17 Q. And here's what you tell them in answer to 18 Question No. 10. Quote, "Monsanto Company is not aware of 19 any health or environmental effects resulting from the 20 introduction of PCB compounds or mixtures into the 21 environment which has not been reported in the scientific 22 and popular press and already known to the representatives 23 of the EPA. " That was your answejo r? 24 A. That is right, yes, sir. 25 Q. Did you authorize that answer? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49608 94 1 A. Yes, sir. That's a truthful answer. 2 Q. Mr. Papageorge, would you turn to page 246 in 3 the exhibit? 4 A. (Inaudible.) 5 Q. I had mentioned to you earlier in your 6 testimony, in my examination of you, about Vice-President 7 Fitzgerald making a comment to the EPA at the hearings 8 early in '76? 9 A. You did mention it, yes. 10 Q. This is what I was talking about. 11 A. All right. 12 Q. This particular speech on 246 and 247. Were 13 you present when he gave his remarks? 14 A. I was. 15 Q. Is this a true and accurate copy of the 16 speech he said he used, his testimony put into the record? 17 A. It is. 18 Q. And he told EPA p at that time, quote, "Let me 19 emphasize that we have no desire to remain in the PCB 20 manufacturing business any longer than is necessary. " Did 21 you believe that statement to be true in May of - 22 A. Yes. 23 Q. Where were these alternative dielectric 24 fluids? In what state of development? 25 A. There were -- As best Monsanto could Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49609 1 p2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 95 determine, there were some liquids under test at that time, but as yet none had been proven satisfactory. Q. Now, Mr. Papageorge, Congress banned PCBs by name in the statute on October 16, '76, but the phasing regulations prepared by EPA give different deadlines so that you could stop making PCBs in '77; right? When did you stop making PCBs? MR. CARNEY: I'm going to object. He's misled the jury to thinking Congress banned the PCBs, he's done it p several times, in '76. It was done in '79, and I think he's just deliberately trying to confuse the jury with that kind of question. MR. KOTOSKE: We don't have to -- THE COURT: Sustain. MR. KOTOSKE: We'll bring the statute in and I'll let everybody - MR. CARNEY: I'd like to do that because I think it's important for the jury to know. THE COURT: Fp ine. We'll do that. I'll sustain as to form of question. You may rephrase. Q. Why did you raise the price of PCB in 1976? A. The cost of producing the PCBs for the small market that existed was increasing. We still had all that equipment and all the costs that go into making chemicals that were constant, but the volume had dropped so that the 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49610 96 1 cost per pound to manufacture had gone up, and Mo]o nsanto 2 had to raise the price to meet that increased cost. 3 Q. Why did you ask all your customers who had 4 PCB manuals to destroy them in September of '77? 5 A. I'm not aware of that. 6 Q. Turn to page 249. Is this a Monsanto letter? 7 A. It is. 8 Q. Dated September 22, 1977? 9 A. It is. 10 Q. Signed by J. A. A-l-l-e-y,Industrial 11 Specialist in Dielectjo rics? 12 A. Yes, sir. 13 Q. Does it say, "I suggest that you destroy all 14 copies in your files and offices so we don't inadvertently 15 supply obsolete information to the industry"? And he's 16 talking about Monsanto bulletins for inspection and 17 maintenance of transformer askarel? 18 A. He is referring to that, but I don't recall 19 which year of publication that is. I don't know if it's 20 an obsolete one ]o or the latest one. 21 Q. Finally, I'm going to show you one document 22 in Exhibit No. 12. We're through with Plaintiff's 11. 23 This exhibit has to do with Mr. Paul Wright who worked at 24 IBT, and you heard his testimony, the testimony of Mr. 25 Phil Smith. Mr. Paul Wright was given a cash award; was 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49611 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 'c 97 he not? A. I think you're referring to the incentive award from Monsanto. Q. p I think that's what you call it. A. I was made aware of that lately, yes, sir. Q. Turn to page -- the last page in that exhibit, page 522. A. I have it. Q. Do you recognize that sort of document? A. I recognize the form, yes. Q. Is that the form used for cash incentive awards ? A. Yes, sir. Q. Do you recognize Levinskas as you gep t down there next to the date July 16th, 1976? A. I do. Q. Did you sign the document? A. He did. Q. How about you? Did you sign it? A. No, sir. I had nothing to do with this. Q. This is a cash award to Paul Wright. I'd like to read to the jury what Monsanto gave him this award for. I'll read from the document. "His excellent analysis and synthp esis and widely-scattered observations played a prominent role in forestalling EPA's promulgation 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49612 98 1 of unrealistic regulations to limit discharges of 2 polychlorinated biphenyls, EPA's proposed regulations that 3 precluded the use of these materials by Monsanto's 4 customers." So Monsanto gave him a cash award? 5 A. I still haven't found the line, sir. 6 Q. I can help you. In the middle of the page. 7 MR. CARNEY: I'll agree that he read the 8 words correctly, at least part of the words. 9 Q. Do you see where it starts "Particularly 10 noteworthy"? 11 A. Yes. I found it. 12 Q. Let me read it again so (inaudible). 13 MR. CARNEY: Your Honor, I stipulated that he 14 read the words correctly the first time. 15 THE COURT: It's been read. 16 MR. KOTOSKE: ]p I have no further questions. 17 THE COURT: All right. 18 MR. KOTOSKE: I do. 19 Q. How much money did Monsanto pay Paul Wright 20 for his efforts in PCBs? 21 A. Sir, I don't know anything about this other 22 than I saw this document fairly recently. 23 Q. You don't know how much money? 24 A. No, I don't. 25 'd MR. KOTOSKE: No further questions. 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49613 99 THE COURT: Let's take a ten-minute break, folks. Again, do not discuss the case among yourselves or with others. (Brief recess.) THE COURT: Mr. Carney, you may proceed. (Ms. Olliges was replaced by Ms. Carter.) 'e 0 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49614 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 'f 100 THE COURT: Mr. Carney, you may proceed. Q.]p (By Mr. Carney) You didn't think I was ever going to get the chance to ask you questions, Mr. Papageorge. Now it's my turn. You know who I am? A. Certainly. Q. I was going tocall you in my case, but Mr. Kotoske has called you in plaintiff's case. So I'm going to go through the questions that I would have asked you in my case, and I can just save time rather than just recalling you, if that's okay? A. Yes. Q. And ratherthan trying to berepetitious, I went over last night and tried eliminating any questions Mr. Kotoske covered. I'm not sure if he asked you where your residence was? A. Well, I live in West County in St. Louis at 321 Pebble Valley Drive. 63141 is the zip code. Q. How long have you lived in the St. Louis area? A. I'm a native that left!) three times for about four years each. So the rest of the time I've been in the St. Louis area. Q. And how old a man are you, sir? A. Sixty-nine. Q. 6 Are you married? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49615 1 A. Yes. 101 2 Q. Children? 3 A. Yes. 4 Q. Could you briefly give me your background, 5 where you grew up and what school you went to? 6 A. Certajo inly. I grew up in St. Louis, what I 7 call the Near South Side, the area around Lafayette Park, 8 the Old City Hospital, Barr branch. I went to Seigel 9 School on Allen Avenue, actually, it was nine years. The 10 first year of high was held there because of overcrowding 11 at the McKinley High School, which was the next block over 12 on Russell Boulevard. That's my -- those are my early 13 years. 14 Q. Graduated from McKinley High? 15 A. Yes, sir. 16 Q. I think it was covered you went to Washington 17 University here in St. Louis? 18 A. Yes . 19 Q. Did you supplement -- Did you work your way 20 through to get through school? 21 A. Oh, I had to, yes, sir. 22 Q. Then you -- Were you in the military? 23 A. Yes, I was. 24 Q. What branch? 25 A. In the Army. 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49616 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21) 1 22 23 24 25 'h 102 Q. And what ranks did you hold? What did you start out as, and what did you end up as? A. Started as a private and was discharged as a captain. Q. And you were -- What years were you in the Army? A. Let me think back. It was 1943 through '4 - most of '46. Q. Were you in the war, World War II? A. The Pacific theater, yes, sir. ]o Q. And just briefly what were your duties. Don't go into detail. A. Well, my duties changed with the way the war was progressing. I started out in anti-aircraft and then got into infantry, and then during the occupation of Japan I was in the Corps of Engineers. Q. And you're a chemical engineer. That's your degree? A. Yes. Q. Just very briefly could you tell the jury what a chemical engineer does, what it is? A. I will try. Chemical engineering involves the use of, knowledge of mathematics, knowledge of chemistry, knowledge of physical properties of things like flowing of fluids or movement of gases and the like. 6 And Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49617 103 1 you put all this knowledge together to design the 2 necessary equipment, the pots and pans, if you will, of 3 making certain chemicals safely, of a]p good quality and as 4 economically as you can. 5 Q. Are you a registered professional engineer in 6 the state of Missouri? 7 A. I am. 8 Q. How long have you had that registration? 9 A. Oh, since about 1963, if I remember 10 correctly. 11 Q. And I believe you indicated when you retired 12 from Monsanto, I believe that was '86? 13 A. Yes. 14 Q. When did yo]p u start with Monsanto? I'm not 15 sure that date was mentioned. 16 A. November 1951. 17 Q. And I think -- and I just want to briefly - 18 You covered a lot of your jobs when Mr. Kotoske was asking 19 questions. So I don't want to repeat that, but your very 20 first job was at the Queeny plant? 21 A. Yes. 22 Q. And what was your -- Were you in charge? 23 Were you a supervisor of anybody in that very fi]p rst job 24 from 1951 to 1953? 25 A. No. I worked as a loneengineer designing 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49618 104 1 equipment. 2 Q. Were you working in the plant or were you in 3 an air conditioned office? 4 A. I was in an office, air conditioned office, 5 as you put it, yes. 6 Q. And the Queeny plant didn't manufacture PCBs, 7 did it? 8 A. That is correct. 9 Q. Did you havejo anything to do with PCBs that 10 first two years, 1951 to 1953? 11 A. Absolutely nothing. 12 Q. And you didn't knowanything about PCBs 13 during that two-year period? 14 A. That is correct. 15 Q. But you learned aboutthese later? 16 A. Correct. 17 Q. Now, you had a couple jobs, and then I think 18 in 1956, '57 you were supervisor of maintenance at the 19 Queeny plant? 20 ]o A. I was. 21 Q. And you had a small group that you were 22 responsible for? 23 A. Yes. 24 Q. And then from '57 to '59 you had a work force 25 'j of about 400 people? 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49619 105 1 A. Yes. 2 Q. And you were superintendent of the 3 maintenance department? 4 A. Correct. 5 Q. Now, I believe Mr. Kotoske asked you when you 6 were supervising g these 400 maintenance people if you saw 7 any written warnings to employees in the maintenance area, 8 any written warnings? Do you recall your answer to that? 9 A. I believe I do. 10 Q. Did you recall any written warnings? 11 A. I recall written sheets which described what 12 chemicals they might be exposed to and what kind of harm 13 might be expected under certain conditions of mishandling 14 or misuse. 15 ]o Q. Did you rely on those written documents when 16 you were in charge of the maintenance people to get across 17 how to safely handle PCBs in the work place? 18 A. I relied on them, of course, but I sort of 19 looked upon them as something to back up what the 20 employees heard at the safety meeting. I believe the 21 spoken word carries a better message than the written word 22 that's over on some desk somewhere. 23 Q. ]o And did you have regular safety meetings at 24 the Queeny plant during that time? 25 'k A. 6 Certainly, every month a meeting. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49620 106 1 Q. And what -- Do you recall what was said in 2 these safety meetings with regard to the PCBs? 3 A. We covered the usual, the need to be careful. 4 Don't breathe too much. Don't get it on your skin. When 5 you get a chance, change your clothes. Don't panic. 6 There i]p s no need to rush over right away, but when time 7 permits, go over there, change your clothes. Take a 8 shower if necessary or at least wash off the area that's 9 got the oil on it. We also emphasized to help control 10 PCBs to look for those two what I call early warning 11 symptoms. If any of you get red skin on your hands 12 because you didn't wear the right kind of gloves, go to 13 the dispensary, report to it to the medical doctor. If 14 ]o you have a bad chest cold, don't assume it's just a chest 15 cold. Find out from the doctor. It may be related to you 16 breathing too many fumes. So once we controlled those 17 two, then we were comfortable that nothing more serious 18 would happen by working with PCBs. 19 Q. Did you see while you worked at the Queeny 20 plant, were there any employees that got chloracne because 21 of PCBs? 22 A. At the Queeny plant, no, sir,]o no. 23 Q. Did anybody get any type of liver effects or 24 liver damage that you saw at the Queeny plant because of 25 '1 PCB exposure? 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49621 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 'm 107 MR. KOTOSKE: Judge, excuse me for not standing. He is not a medical man. He can't diagnose whether somebody's got chloracne. I'm sorry I didn't object earlier. That I would like to object to have (inaudible) medical documents. THE CO]p URT: Well, I don't know if he can (inaudible). When you say "saw," what do you mean by "saw"? Q. (By Mr. Carney) Well, did anybody to your knowledge get chloracne at the Queeny plant from PCBs? MR. KOTOSKE: See, that's the objection. He can't diagnose, and he doesn't know, and he doesn't have -- He's already told me he doesn't have that expertise. THE COURT: I agree there, bu]p t I'm trying to figure out from what source you're talking about. Q. (By Mr. Carney) Let me ask. Have you seen chloracne? A. I have seen chloracne, yes, sir. Q. And where did you see it? A. When I was assigned to the Sauget, Illinois, plant one of the departments that was my responsibility making wood-treating chemicals had an accidental release years before I arrived. The e]p mployees at that time were exposed to this wood-treating chemical. 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49622 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 'n 108 Q. Was this PCB? A. No, no. Q. Another? A. Another chemicalaltogether, but, nonetheless, because of that exposure they developed chloracne. When I arrived there were 12 of those individuals still under the medical program. And every so often they would be given a pass to leave the plant ]o and go to the doctor to get treatment. And I was very much involved because they would come by the office, and I would sign the pass, and they would go to the doctor for treatment. Q. And you saw their chloracne? A. Yes, I did. Q. And what did it look like? Can you describe -A. To me it looked like, I'm going to use terms that are probably not medical, blackheads ]o on their cheek bones, their hairline behind the ears, and some of them even had it in their throat and the forehead, the hairline of the forehead. And there were others that had not only blackheads, but they had raised portions on their skin, what I call whiteheads. That's what I saw, and that - the medical doctor at the plant told me that was an outward symptom of chloracne. 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49623 109 1 Q. Did you ever p see any of the maintenance 2 people that worked for you at the Queeny plant that worked 3 with PCBs come down with chloracne? 4 A. I did not see anything like that. 5 Q. Did you ever hear of anybody at the Queeny 6 plant getting chloracne from PCBs? 7 A. I never heardthat. 8 Q. Did you ever hear of anybody getting liver 9 effects at the Queeny plant from PCBs? 10 A. I did not. 11 l5 Q. Or liver damage? 12 A. I did not. 13 Q. Did you ever see among your maintenance 14 people that worked with PCBs at the Queeny plant -- I 15 believe all 400 didn't work with PCBs, but I think it was 16 60 or 70 or whatever it was you said? 17 A. That's close. 18 Q. Did you ever see them get the red skin, which 19 is the first symptom that they might have some exposure to 20 PCBs? 21 p A. I never saw that. 22 Q. Did you ever see -- Did you ever have any of 23 your maintenance people get the stuff on their throat like 24 a chest cold that they thought might be related to 25 'o breathing PCB fumes? 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49624 110 1 A. I did not. 2 Q. You next went to this plant called three 3 things, the East St. Louis plant, it's called the 4 Krummrich plant, and it's called the Sauget plant. What 51? do you like to call it? 6 A. Well, I think I'm using the word Sauget, 7 Illinois, plant. 8 Q. We'll use Sauget. In other words, it's right 9 next to East St. Louis? 10 A. Correct. 11 Q. And they made PCBs at that plant? 12 A. Yes, they did. 13 Q. Now, you were involved as a superintendent at 14 that plant of about one-sixth of the manufacturing area of 15 that plantjo ? 16 A. Roughly that, yes. 17 Q. Now, did your section of the plant that you 18 supervised in the Sauget or East St. Louis plant, did that 19 involve a PCB section where they made PCBs? 20 A. No. 21 Q. Well, while you worked there, I think you 22 worked there from 1964 through 1965? 23 A. Yes. 24 Q. About two years, was it? 25 A. Roughly, yes. 'P 1? 1 6 Q. Did any of the employees that worked with 2 PCBs at the Sauget plant get chloracne to your knowledge? 3 A. To my knowledge -- No, not to my knowledge. 4 Q. Did any of the PCB workers in the Sauget 5 plant near East St. Louis have liver damage at any time? 6 A. Not that I know of. 7 Q. Let me ask this because Mr. Kotoskeasked you 8 several times why Monsanto didn't put chloracne or liver 1? 9 disease on the labels that you could get those two 10 problems by exposure to PCB. Did you. Bill Papageorge, 11 know of any cases of chloracne in an American capacitor 12 plant? Have you ever heard of it? 13 A. I never heard of it or saw it, no. 14 Q. Did you know of any cases of liverdisease in 15 an American capacitor plant, whether it was General 16 Electric, whether it was Westinghouse, whether it was 17 Bloomingtonjo , did you ever hear of any liver damage in any 18 American capacitor plant because of PCB? 19 A. I did not. 20 Q. And that's true up to today? 21 A. To this day, yes. 22 Q. And have you heard it today? Have you 23 heard -- Well, I'll leave that for the doctors who are 24 going to testify as (inaudible). I won't have you get 25 into that. Could you briefly describe your duties? I 'q 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49625 Ill 1 p think you told the jury that for five years from 1965 2 until toward the end of '69 you were plant manager in 3 Anniston, Alabama? 4 A. I was, yes. 5 Q. You just describedthat's where they made 6 PCBs ? 7 A. Yes. 8 Q. In fact, that's the plant thatMonsanto 9 bought that was owned by Swann Chemical, and Monsanto 10 bought the plant in 1935? 11 A. Yes. 12 Q. S]p tarted making PCBs from that time until 13 1977? 14 A. That is correct. 15 Q. Could you just describe your duties when you 16 were plant manager of the Anniston, Alabama, plant? 17 A. I suppose the best, simple statement I could 18 make is I guess I was responsible for everything that 19 happened there from the hiring of the worker, the training 20 of the worker, the getting the necessary equipment and 21 using th]p at equipment to make chemicals at the proper 22 costs, that the cost didn't get out of hand, and to do all 23 of this safely. Don't hurt anybody. Package it properly 24 so it can withstand the trip to the customer. Be a good 25 'r neighbor in terms of don't send out obnoxious fumes into 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49626 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 's 112 the neighborhood. Watch the water discharge so it doesn't pollute the local sewage treatment plant. Participate in the local communities lik]o e the United Way and the local music club and the Boy Scouts and Girl Scouts and the YMCA. These are just examples of the kind of participation, not only with donation of money, but with allowing the workers at the plant to take time off from work to go help these organizations. It even went down to instructing the truck drivers on how to behave on the highways and roads of the cities so they did not create problems and a ba]p d reputation for Monsanto. Q. Was this good-neighbor policy that you described, was this the policy that Monsanto followed at all of its plants? A. Oh, yes, yes. Q. It's true at the St. Louis plants as well? A. Yes. Q. What other products were manufactured at the Anniston plant other than we already know about PCBs? There were other products, weren't there, that were manufactured there? Could you just give a few examples? A. I'll try. Of course, we made muriatic acid. We made an insecticide that's used in cotton fields called parathion and its cousin chemical we called 'niran.' We made potassium phosphorous -- I'm sorry -- phosphorous 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49627 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 't 113 pentasulfide which was a chemical used to make other materials. We made the biphenyl that we sold as biphenyl to other ch]p emical companies. We made other products that started with biphenyl, like hydrogenated biphenyl. I don't want to get too complicated, but there's a whole family of chemicals that come from biphenyl. And, of course, we made the chlorinated terphenyls which were also called Aroclors. Q. And they are not PCBs? A. They are not PCBs. Q. Let me ask you this because you just hit upon somethijo ng I'm going to ask you later on, but I'll ask it right now. Mr. Kotoske I think during his examination today was asking you about the toxic properties of I think it was biphenyls, wasn't it? A. Yes . Q. Do you recall that? A. Yes . Q. And that's a raw material for PCB? A. That 's what we called it, yes. Q. Now, can you have, say, two raw materials are toxic, for example, very toxic, and they make something that either is less toxic or maybe not very toxic at all? Is that something that happens? A. 6 Well, that happens fairly often. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49628 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 'u 114 Q. Can you give me any examples, give the jury an example? A. I'll try. I don't know how many of the jury recognize an acid like muriatic acid or battery acid. Muriatic acid is one that'Jp s used to clean brickwork after bricklayers are finished putting the wall up. Q. It's toxic? A. Oh, yes, definitely. And if you couple that with lye that many of us are familiar with, that's pretty corrosive, that's pretty toxic. You combine muriatic acid and lye in the right mixture so you don't have too much of one or the other, you end up with salt water. Sodium from the lye combined with the chlorinejo from the acid makes sodium chloride, which is salt water. That final product, as we all know, is innocuous. It doesn't hurt anything, but the two starting materials must be carefully handled. Q. Let's get back to the Anniston plant for a minute. Did you have written information that was available to the workers at Anniston that made PCBs about how to handle PCBs? A. Yes, we did. Q. C]p an you describe what that information was? A. Well, it's a -- it's a sheet of paper in which the information is typed, of course, and is available for the worker to read. 6 In addition to that, Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49629 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 'v 115 they had copies of the pamphlet put out by the American Industrial Hygiene Association describing how much PCBs is permissible in the air that the worker breathes throughout the eight-hour shift. That kind of documjo ent was available. That pretty well covers it. Q. And did you rely on this written material as the only source of information to the employee about how to handle PCBs at the Anniston, Alabama, plant? A. No. I personally didn't rely on that written material as the only source. I relied on that written material as sort of backup information. The better way to communicate to the worker is to tell them facejo -to-face what to look out for, and what the material can do to you, and what's the best way to protect yourself, what kinds of equipment are available, where do you get this equipment and where do you keep it so it's handy, under what conditions do you use it. That is the most effective way, and this is reviewed at the safety meetings. Q. How often are these safety meetings held or how often were they held in the ' 6]p Os while you were at Anniston? A. Safety meetings are held once a month, but the subject changes each time so that the exposure to chemicals might be covered every third meeting or so. Q. 6 What about a new employee, if he came and Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49630 1 2 3 4]p 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 'w 116 didn't have a safety meeting, say, for two months, how was he to know how to handle PCBs safely? A. Before a now employee is sent to work in the plant, he has one or more meetings, and it depends how many are hired at a time, but generally it's a few at a time. And they meet with the safety supervisor of the plant. They meet with the medical doctor. They meet with their future foreman and supervisor to discuss many things, amongst which is the safety and health aspects. Q. And what was told to the Anniston, Alabama, workers that worked with PCBs? ]o A. Don't get it on your skin and leave it on there too long. There is really no need to panic, you know, drop everything and run to the wash room. But first chance you get, wash it off. Same thing goes with your clothes. If they are badly drenched, certainly, go get another pair of trousers or what have you. If not, you can wait till the end of the shift, and there won't be any harm. If there are some fumes that you must w]p ork in, use your judgment as to whether you can turn off the source of the fumes quickly or whether you should go get your respirator which has been assigned to you, by the way. It's not -- Everybody doesn't use it. Get your respirator, put it on and go out there and do what it takes to stop the fumes. 6 So the whole program is really Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49631 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 'x 117 based on training that employee and relying on his judgment, rather tha]o n have the boss breathing down his back all the time because, keep in mind, there is 21 shifts to the week, and the boss is only there about 5. Q. By "the boss," you mean the foreman? A. The foreman is the immediate boss. So the other 17 -- My arithmetic's wrong -- the other 16 shifts we have to rely on each worker taking care of himself. Q. And you described the protective equipment that was ava]p ilable to the workers at Anniston, and I won't cover that again. But let me ask you this, did the PCB workers wear these rubber coats and the respirators and the rubber gloves going up their arms at all times? A. Oh, no. Only when in their judgment the conditions called for it. Q. What was their normal uniform? What did the PCB workers wear on a daily basis? A. A normal uniform was a two-piece, ]o gray khaki shirt and trousers. They had safety shoes issued to them and a hard hat. That would be during milder weather. During colder weather they would also have a jacket and maybe even a wool knit cap to wear underneath the hard hat, and they wore gloves, generally a plastic-lined canvas glove, unless they were involved in a situation that a lot of PCBs would get on those gloves. 6 Then they Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49632 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21) 1 22 23 24 25 'Y 118 would pu^) t on the neoprene gloves. Q. Let me ask you this while I'm thinking about it, did you ever -- did you walk through the plant, particularly in the area where the PCBs were made or did you stay in your air conditioend office? I don't even know if it was air conditioned, but (inaudible). A. I made a point to walk through the plant at least once a day whenever I was in town. If I was traveling, of course, I cl) ouldn't do it. Q. And you were in town most of the time at the plant? A. Yes. Q. And did you ever get PCBs on you as you were working or as you were walking through the plant or going through the PCB area? A. Many times, yes. Q. Can you describe it? A. Of course, it varied. Q. You weren't drenched from head to toe, I take it? A. Oh, no, no. I never found myself in that situation, but let me describe, when I first arrived, the conditions were a little different than when I left in terms of the degree of cleanliness that was expected. When I first arrived, I found that the handrails were 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49633 1 2 3 4 5 6 7 9 10 p 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 119 gummy. The steps -- and up the steps were -- they had PCBs on them, and my shoes would stick on them. In fact, at the bottom of eachjo stairwell they had a little sand box to pick up some sand so they wouldn't slip as they go up the steps. There were some fumes coming out of the pots, the reactors because the workers were not covering that opening. So as I'd walk through, yes, I would get spots of oil on my shoulders or down my pants leg. Then I'd pick up material on my shoes. I remember many times going to the car in the parking lot and finding a piece of stick or a twig and cleaning out the material from the front of my heels. I remember that. So there were at that time opportunities to pick up the PCBs. Q. Did you get it on your hands when you touched the rails that were gummy? A. Yes, I did get it on my hands. I would get it on the door knobs. Of course, unless I ate something, that wasn't often, I had to wash my hands before I picked up any food o]o r even sometimes a piece of paper and pencil because the work would get dirty from the PCB. Q. If you got it on your hands would you immediately run to the wash room? A. No, not immediately, but when I got back to the office, I'd wash up. Q. 6 Did Monsanto ever manufacture -- I'm Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49634 120 1 switching subjects completely. I thought I had a question 2 to follow up. I can't remember what it ]o was. So I'm going 3 to switch the subject for a minute. Did Monsanto ever 4 manufacture or sell trichlorethylene? 5 A. No. 6 Q. Or trichloroethane? 7 A. No. 8 Q. And then you were given the job, and I think 9 you've discussed that at some length in the last day or 10 so, of manager-environmental control. In that job, and 11 you had that from 1970 to '76, was your only job with 12 regard ]o to PCBs? 13 A. Initially, yes. But as the program 14 developed, I was given other products to be responsible 15 for. So my work load did change. 16 Q. Say from the period 1973 to '76 how much of 17 your time was spent on PCBs as opposed to other issues 18 unrelated to PCBs? 19 A. I would estimate about half of my time was on 20 PCBs, in that period of time. 21 Q. And before that it would be more? 22 ]o A. It was 100 percent before. 23 Q. Generally, and I'm not sure you were given 24 the opportunity to do this, can you just describe what 25 your job duties were? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49635 1 A. When? 121 2 Q. In 1970 when this position was created that 3 you assumed. 4 A. I was expected to know as much as I could 5 about PCB and the environmental issue and to communicate 6 that information to]p anybody that had any interest in it 7 within Monsanto, within the university community, within 8 the government agencies, foreign producers, environmental 9 groups, anybody that had a question about PCBs. I tried 10 to serve at least as a starting mark. And if I felt I can 11 answer the question properly, I would do so. If not, I 12 would make it a point to get the real expert to answer the 13 question. 14 Q. You described the safe h]p andling procedures 15 that you told the workers about at the Queeny plant and at 16 the Anniston, Alabama, plant. How did you learn about 17 those safe handling procedures? 18 A. Primarily my principal source was the plant 19 doctor and his files at both of those plants. 20 Q. I remember now the question I couldn't think 21 of a minute ago. You described the conditions of the 22 Anniston plant at the time you started, 1965, and ]o they 23 weren't as good as you thought they should be. Would that 24 be fair to say? 25 A. They weren't good enough for me. That's Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49636 1 true. 122 2 Q. And did the -- Did you institute some changes 3 to improve conditions? 4 A. I did, yes. 5 Q. Just generally describe what you did. 6 A. I'll try. 7 Q. And the reason for it, if you can. 8 A.p I'll try. I don't know if I'll make myself 9 ' inaudible' As I see it, there are about four reasons to 10 push for good housekeeping. One, of course, is to avoid 11 exposing workers to hazardous materials, and that was 12 being done at the Anniston plant in spite of the sticky 13 handrails and the sand box at the bottom of the 14 footsteps -- of the stairways. Another reason for good 15 housekeeping is to avoid the slippery steps, for example, 16 the kinds of situations that result in falls and broken 17 ankles and the like and lacerations and other kinds of 18 injuries. That's still kind of safety related. There is 19 a third one that became more and more prominent as time 20 went on when I was there. This is the one having to do 21 with the environment. A dirty plant sort of dirties its 22 neighborhood. So good housekeeping helps environmental 23 contamination. And the fourth one, and ]o this, I guess, one 24 could laugh at me for, but I have a strong belief that 25 people like to work in a clean place. It seems to show up Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49637 123 1 in the way they keep their records, their enthusiasm on 2 the job, the way their tools are kept clean and safe. 3 I've even seen it in the way they appear. They just comb 4 their hair better, and they dress cleaner. It sort of 5 feeds on itself. So finally I was gratified that -- I 6 ]o forgot what year it was, 1968 I think it was, Monsanto 7 gave the Anniston plant an outstanding award for 8 housekeeping. And at this point the employees came in and 9 asked could they bring their families by. And I was ready 10 for the answer. I expected it. And the answer was 11 "Certainly." So we had the families, and they brought 12 their children in. The place was clean enough that they, 13 themselves, were proud enough to show it, which pr]p ior to 14 that they just would not have even thought of it. Does 15 that help any? 16 Q. Yes. Back in the late 1930's were the people 17 at Monsanto, including yourself -- Well, strike that. You 18 weren't there in that period? 19 A. Not quite. 20 Q. You were probably in grade school or 21 something? 22 A. Right. 23 Q. But you did look into when you took the job 24 in 1970, you]p studied the history of Monsanto's association 25 with PCBs and any problems that might have been caused by Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49638 124 1 PCBs during the period from 1935 until 1970? 2 A. Yes, I did. 3 Q. And in that review was Monsanto aware that if 4 you breathed the fumes, and this is back in the 1930's, 5 from heated PCBs for an extended period you could develop 6 some situations where your liver would be affected? 7 A]p . Yes. 8 Q. And I mention the word heated PCBs. If you 9 had a vat of PCBs sitting right here in front of the jury, 10 between us, would that be of concern, the fumes, if they 11 were at room temperature? 12 A. No. 13 Q. Why not? 14 A. They do not give off fumes at room 15 temperature the way, say, gasoline would. They are just 16 not that type of liquid. 17 Q. So you've got to he]p at the PCBs to generate 18 fumes that would cause any type of problems whatsoever? 19 A. Certainly. 20 Q. As far as you know, based on your years 21 you've spent at Monsanto dealing with PCB matters, what 22 human health effects or health problems can be caused by 23 exposure to PCBs? 24 A. Well, they can run from stinging of the 25 eyes -- When it gets in the eyes, it does sting. No Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49639 125 1 quesjo tion about it. It can cause reddening of the skin 2 that I believe I described as like similar to chapped 3 hands. It can cause this severe chest pain that I 4 described similar to a chest cold, a coughing and 5 irritation. 6 Q. Let me stop you right here because I want to 7 clarify something. There have been some words used, and 8 I'm not sure that they have been explained. Maybe I'm 9 being over-simplified in this, but are tho]o se what you 10 would call acute symptoms from PCB exposure? 11 A. Yes. That would fit the definition for acute 12 exposures, yes. 13 Q. What does the word "acute" mean? 14 A. That means a very short-term exposure at a 15 level enough to cause the effect that you're seeing for a 16 very short time, like a snapshot from a camera kind of 17 thing. 18 Q. And that's pretty immediate, those effects? 19 ]o I mean they wouldn't show up ten years later or two months 20 later? 21 A. Oh, no. 22 MR. KOTOSKE: We are in a position now where 23 the man doesn't have the qualification to answer that 24 question. 25 MR. CARNEY: I think, Your Honor, he does. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49640 1 2 3 4 5 6 7 9 10 11 Vp 2 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. KOTOSKE: Please. 126 THE COURT: Your objection is qualifications? MR. KOTOSKE: Yes. He ca]p n't speak for (inaudible) periods and (inaudible) diseases. He is not qualified to do that. THE COURT: Well, he's a chemical engineer. MR. KOTOSKE: Well, that doesn't give him medical qualifications to diagnose and articulate the medical effects and the health hazards from exposure to chemicals. I concede he's a chemical engineer, and he might design a very good chemical piece of equipment, but the human body is something that this man doesn't know anything about. THE COURT: I'm going to sustain to form the question, Mr. Carney. Rephrase. MR. CARNEY: Maybe we'll -- You know, I think this witness is qualified to talk about acute versus chronic, something very basic, but we'll have medical doctors who will describe it, and I'm perfectly willing to wait. THE COp URT: That's fine. MR. CARNEY: I just thought I'd clarify it for jury. MR. KOTOSKE: Don't misunderstand me, Judge. He can give symptoms. He can talk about chest pain, Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49641 127 1 redness of the skin. 2 THE COURT: He can describe what he's seen. 3 MR. KOTOSKE: That's right. Don't 4 misunderstand me. 5 THE COURT: It's up to you, Mr. Carney. 6 MR. CARNEY: I'll wait on it. We have other 7 witnesses, and they are going to cover that. 8 Q. (By Mr. Carney) Let me ask you this. I 9 interrupted your answer. Based on all of your knowledge 10 and study of PCBs over the years, I'd like to ask you what 11 are the human health effects, health problems that can be 12 caused by exposure to PCBs? And you started out and you 13 gave me those three. Will you finish your answjo er? 14 MR. KOTOSKE: Well, I have the same 15 objection. Enough is (inaudible) What he sees, I have no 16 objection to. 17 THE COURT: It's based on this information. 18 He is not making a medical diagnosis. It's based on his 19 learning, as to what he's learned, et cetera. So I'm 20 going to overrule the objection. You may answer. 21 A. In addition to those that I described, 22 further exposure beyond t]o he sore chest and the red skin 23 could lead to the chloracne we talked about earlier and, 24 again, still further exposure could lead to damages to the 25 liver, to the point where the liver is affected. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49642 128 1 Q. (By Mr. Carney) Any other health problems 2 that can be caused by exposure to PCBs? 3 A. I can't think of any more. 4 Q. Now, there's been some testimony and some 5 evidence about if you]o drink cups of PCB material or 6 something, it can cause death. Has there ever been any 7 situation you're aware of where somebody has died from 8 exposure to PCBs? 9 A. I have not heard or seen or witnessed any 10 such death. 11 Q. Why did you say -- or I don't know if it was 12 you or somebody from Monsanto. Maybe it was somebody from 13 Westinghouse -- that if you ultimately -- the extreme is 14 the PCBs could causjo e death? 15 A. I say that because my medical advisors at the 16 plants knowing how the liver can be affected and its 17 ability to repair itself told me that if it goes too far, 18 the liver, in essence, gives up. And without a liver, you 19 have death. 20 Q. Is that something unique to PCBs as an 21 industrial chemical that it can cause death? 22 A. That's not unique to PCBs. The liver damage? 23 Q. Y]p es . 24 A. Many chemicals cause that. 25 Q. There are other industrial chemicals that if Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49643 1 you get too much of them can cause death? 129 2 A. Certainly. 3 Q. Are there other chemicals that we know of 4 every day that can cause death if you get too much of 5 them? 6 A. Certainly. 7 Q. Can you give me an example? 8 A. Well, let me try to think o]p f something we 9 all -- 10 MR. KOTOSKE: Well, judge, you know, let's 11 not drift too far, and I think we are. 12 MR. CARNEY: Well, I think he's making the 13 point that if you drink a gallon - 14 MR. KOTOSKE: Let's not argue in front of the 15 jury. There's a time for that. 16 THE COURT: (inaudible) arguing. I'm going 17 to overrule the objection, but remember what we're here 18 ]o about as far as this witness is concerned. 19 MR. CARNEY: I know (inaudible). 20 A. I guess gasoline and the motor oil and the 21 gasoline in our cars are examples of materials that can 22 cause death if misused. The liquid bleach in our homes 23 and the drain cleaner that clears up our stopped-up drains 24 could cause death if misused. (inaudible) just come to 25 mind a common, every-day kinds of things that we use and Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49644 1 yet they are hazardous if misused. 130 2 Q. (By Mr. Carney) Now, you started to mention 3 something else. I'm not sure this has been clearly 4 mentioned in this case yet (inaudible). Are there other 5 industrial chemicals that cause chloracne? 6 A. Yes, sir. 7 Q. You mentioned -- I goes you did mention 8 earlier the wood preservative. Can you give me some other 9 examples of chemicals thatjo are industrial chemicals that 10 cause chloracne? 11 A. Well, I suppose I could rattle off a group of 12 chemicals, but I think I could shorten it by saying that 13 most of the family of chemicals that are referred to by 14 the chemist as chlorinated hydrocarbons, that's carbon and 15 hydrogen with a chlorine, that combination leads to many 16 chemicals that can cause this chloracne symptom. 17 Q. And those chemicals also cause l]o iver damage? 18 A. Yes. 19 MR. KOTOSKE: I'll stipulate that they will. 20 MR. CARNEY: Good. 21 THE COURT: Do you? 22 MR. CARNEY: Good. 23 Q. (By Mr. Carney) Are there other industrial 24 chemicals that can cause skin irritation, redness of the 25 skin that we heard some plaintiffs talk about? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49645 131 p1 A. Certainly. There's many of those, of course. 2 Q. Just give a couple of examples. 3 A. Paint thinners, anything that blends well 4 with the fats and oils that will extract the fat out of 5 the skin will redden the skin. That's paint thinners, the 6 dry cleaner fluid, triethylene, perchloroethylene. These 7 kinds of things will extract oils and will cause 8 reddening. 9 Q. I want to briefly cover this topic, and I 10 want to get into it a li]p ttle more today. You've mentioned 11 what you told Monsanto workers about safe handling or 12 precautions with PCBs. Did Monsanto give any information 13 to its customers about safe handling of PCBs? 14 A. Yes, they did. 15 Q. Can you describe the types of information? 16 We've already had some mention of the labels, but can you 17 describe some of the other information that was given to 18 Monsanto's customers about that subjeep t? 19 A. The other information includes primarily 20 booklets and brochures that describe the product and its 21 properties and its uses. There are sections in those 22 brochures that highlight the safe handling required for 23 that particular material. 24 Q. Was there also correspondence between 25 customers such as Westinghouse back and forth, questions? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49646 132 1 A. Very much of that, where individuals^) from our 2 customers' plants would inquire directly to Monsanto with 3 sometimes a general question and sometimes a very 4 specific. And the medical department would respond to 5 those either by a return telephone call or a letter, 6 sometimes a visit, whatever was appropriate. 7 Q. Now, when you were plant manager at Anniston, 8 did you have any of your PCB workers that came down with 9 chloracne? 10 A. No. 11 I5 12 Q. Any liver damage - A. No. 13 Q. -- because of exposure to PCBs? 14 A. No, sir. 15 Q. Did you have any problems with dermatitis or 16 a reddening or a rash of the skin with a PCB worker while 17 you were plant manager at the Anniston, Alabama, plant? 18 A. I recall one case, the individual who, 19 incidentally, was a 30-year employee and a chief operator. 20 TH]p E REPORTER: And a what? 21 A. And a chief operator just didn't put on his 22 gloves when he was filling a tank car and taking a sample 23 of the material, and he didn't do that for several evening 24 shifts in a row. 25 Q. (By Mr. Carney) He didn't wear gloves for Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49647 1 several evenings? 133 2 A. That's right. He finally noticed his hands 3 getting red, and he reported it to the doctor. And, of 4 ]o course, the doctor told him how to treat it and then told 5 him to wear his gloves, as he should be. So the doctor 6 then in his daily stop by my office told me about it. And 7 I made it a point to wait for that evening shift to meet 8 the employee, and I saw his hands. They were red and had 9 broken hair lines with evidence of past bleeding by that 10 time. He was treating. And he sheepishly admitted that 11 he should have known better. 12 MR. KOTOSKE: Objection. Let's strike the 13 whole thing as hearsay. 14 MR. CARNEY: I think it goes to the knowledge 15 of Monsanto employees. 16 MR. KOTOSKE: (inaudible). 17 THE COURT: I'll allow the answer. 18 Overruled. You may finish your answer. 19 A. He sheepishly admitted to me that he should 20 have known better. He was wearing his gloves. 21 Q. (By Mr.]p Carney) Did he miss any work? 22 A. No. 23 Q. Did that problem ever occur again? 24 A. No. 25 Q. Did you ever in any of the five years you Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49648 134 1 were Anniston plant manager ever see any other injury of 2 any kind related to PCB exposure? 3 A. I didn't. 4 Q. Whether it was skin rash or any kind of 5 injury? 6 A. I did not. 7 Q. ]o Is there a difference that you observed 8 between the skin rash that you saw of a PCB worker and the 9 chloracne that you observed that you described earlier? 10 A. Yeah, to me there was a definite difference. 11 Q. Can you describe to the jury the difference 12 between a skin rash from a PCB worker that you saw and 13 chloracne? 14 MR. KOTOSKE: Judge, same objection. I hope 15 this is not going to be construedjo as any kind of medical 16 diagnosis with any medical overtones. 17 THE COURT: You're not representing that, are 18 you? 19 MR. CARNEY: No. He's seen both, and I just 20 want him to describe what he saw. 21 THE COURT: He can describe what he saw. 22 A. The skin rash definitely was a reddening of 23 the skin. I don't know quite what to compare it with. It 24 was an angry looking kind of red]o skin; whereas, the 25 chloracne, I didn't see any redness. I just saw the Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49649 135 1 imperfect texture of the skin. It was rough, along with 2 the blackheads. 3 Q. (By Mr. Carney) Let's go back. I'd like to 4 give the jury a little bit of background about Monsanto's 5 history. And I'm going to be very, very brief about it. 6 I think there's been some mention, Monsanto was founded in 7 1901? 8 A. Y]p es . 9 Q. What was it -- What was the company's first 10 product, if you recall? 11 A. Saccharin. 12 Q. And what are the types of businesses that 13 Monsanto is in now or in the last, say, five years? 14 A. They are in the fibers business. They 15 manufacture fibers that are used in Wear-Dated clothing or 16 in the Wear-Dated carpeting, the acrylon and nylon fibers. 17 They make the sweetener Nutra-Sweejo t. They are in the diet 18 drinks that we see. They make many of the plastics we 19 find in the automobiles these days, the dashboard, the 20 paneling, the outside trim. And they also make the 21 plastic liner that's in the safety glass for your 22 windshield and also for those windows that are now -- they 23 have a colored sheet in there to keep out sunlight. And 24 they make that same liner for building windows in the sky 25 scrapers that we no]o w see with the glass that you can see Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49650 136 1 out, but you can't see in kind of thing. Of course, they 2 make a lot of chemicals for other industries. They make 3 many of the ingredients that go into detergents like the 4 shampoos and so on, the liquid soap. They make materials 5 that go into plastics to make them soft that I talked 6 about earlier, plasticizer. They make a lot of the 7 chemicals that go into rubber tires so the t]p ires don't 8 crack and dry and stay flexible and sturdy and reliable. 9 I can't think of any more. 10 Q. I think that's enough. I wanted to give a 11 little flavor of the company. Monsanto has some plants 12 located near this courthouse? 13 A. Yes. 14 Q. Can you name the ones in the city of 15 St. Louis? 16 A. There is one on the South Second Street. 17 That's the Queeny plant we talked about.]o Then there is 18 one in south St. Louis, the Carondelet plant. 19 Q. And there is one, of course, across the 20 river, Sauget? 21 A. Sauget, yes, sir. 22 Q. And Monsanto's headquarters are out on 23 Lindbergh and Olive; is that correct? 24 A. That's correct, yes. 25 Q. The Carondelet plant down in south St. Louis Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49651 137 1 makes ingredients for toothpaste and other tooth producjo ts? 2 A. Yes, sir. 3 Q. I almost hesitate to ask this question, but I 4 want you to be very brief. And I'll ask you to give a 5 very brief explanation of what PCBs are made of. And I've 6 heard you give a detailed explanation, and I couldn't 7 follow it. So if you could just be real brief, I think 8 that's all we need. 9 A. I'll try. We start out with - 10 THE REPORTER: One moment. 11 ]o (The reporter changed paper.) 12 A. We start out with two common chemicals that's 13 common to most of us, I believe. There is chlorine gas, 14 just like the chlorine used to sterilize public swimming 15 pools. And we start with benzene, which is an ingredient, 16 for example, in gasoline. The benzene is heated at a high 17 temperature and pressure, and it makes biphenyl, two 18 benzenes combined to make biphenyl. The biphenjo yl at room 19 temperature looks like white candle wax. So it's kept 20 heated so it's molten. We bubble chlorine through it. 21 The chlorine attaches itself to the biphenyl, and we start 22 making chlorinated biphenyl. And depending on which of 23 the chlorinated biphenyls we need, the chlorination is 24 either a short one or a longer one. At the -- I'm sorry. 25 Q. I'm sorry. Go ahead. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49652 138 1 A. At the end,]p that mixture is boiled off, and 2 the vapors are cooled, and you collect the good PCB. The 3 bottom is a brown or black tar that is discarded. 4 Q. What do the PCBs look like after they are 5 manufactured? 6 A. The lower chlorinated, like the 1242 type, 7 look very much like baby oil or the mineral oil you buy in 8 the drugstore. It's about that consistency. And it's 9 water clear. Once in a while it might be describejo d as 10 having a faint yellow color to it, but generally when it's 11 real pure it's like baby oil. The higher chlorinated ones 12 pick up this yellow tint. And finally when you get to the 13 very high chlorinated ones, they become a solid like the 14 Aroclor 1268 when it's ground up looks like table salt. 15 Q. So it's not a liquid at all at that point? 16 A. That is true. 17 Q. What do PCBs smell like? We have had a]o lot 18 of testimony about that. I'd like your (inaudible). 19 You've been in the (inaudible). 20 A. To me, they remind me of disinfectant kind of 21 odor, like many of the household disinfectants, those 22 without the perfumes in them, sort of a medicinal kind of 23 odor, the kind you might associate with, again, in my 24 mind, with an operating room disinfectant kind of aroma. 25 Q. Do they smell at all like rotten eggs? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49653 139 1 A. That's the first I heard of that expression 2 was in this courtroom. I've never heard that description 3 before. 4 Q. And what was Monsanto's trade name for PCBs? 5 A. Aroclor was one of the trade names, followed 6 by a number. 7 Q. And most of the PCBs that were sent to the 8 Bloomington plant were what type of Aroclor? 9 A. Aroclor 1242. 10 Q. A]p nd I may give a little more detail on this 11 later, but was there another PCB that was about the same 12 chlorination as Aroclor 1242? 13 A. Yes, there was. 14 Q. And what was that called? 15 A. Aroclor 1016. 16 Q. And both these two PCBs, what percentage of 17 the amount of PCBs sent to Bloomington were these Aroclor 18 1242 or 1016, which are about the same? 19 A. Oh, gosh, over 99 1/2 percejo nt, very close to 20 100 percent. 21 Q. Of all the PCBs sent to Bloomington were this 22 1242 or its sister compound, 1016? 23 A. That's right. 24 Q. Was there any of the 1260 that we have heard 25 about and tested at IBT that went to Bloomington? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49654 140 1 A. No, not that I know of. 2 Q. And there was a tiny, tiny amount of 1254? 3 A. A little bit, yes. 4 ]p Q. So the overwhelming majority, in fact, 99 5 over 99 percent of PCBs sent to Bloomington was 1242 or 6 the related 1016 which had the same chlorination? 7 A. That's correct. 8 Q. These are both what you would call lower 9 chlorinated PCBs? 10 A. Yes. 11 (Ms. Pape replaced Ms. Carter.) 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49655 141 1 Q. And the PCBsjo that Renate Kimbrough found some 2 problems with in the rats, were they the lower chlorinated 3 1242 or the higher chlorinated? 4 A. They were the higher chlorinated 1260. 5 Q. 1260. And no 1260 even went to Bloomington, 6 did it? 7 A. That is true. 8 Q. And the 1242 means 42 percent chlorination? 9 Or am I--describe the 42--1242--what the 42 means. 10 A. 42--it says tha]o t--let me put it this way: For 11 every 100 pounds of that PCB, 42 pounds of that is chlorine. 12 Q. And in the 1254 would mean--? 13 A. 54 percent by weight is chlorine--54 pounds 14 out of every 100 pounds. 15 Q. And the 1260, the 60 would mean the same 16 thing--60 pounds? 17 A. Correct. 18 Q. Chlorine by weight? 19 A. Correct. 20 Q. Just for curijo osity, why did you have 1016? 21 Why did you not have that the 1242 or have a 42 at the end of 22 it since it was 42 pounds chlorinated by weight? 23 A. We tried that, but it caused so much confusion 24 in the minds of everybody connected with it. They couldn't 25 tell whether we're talking about the older product or the new Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49656 142 1 product. And in order to avoid that confusion, we decided to 2 keep the number 1016 whip ch was used back at the laboratory to 3 identify that material while it was under test. 4 Q. And the 1016 was the product that Monsanto 5 made to replace the 1242? 6 A. Yes. 7 Q. And that came about in trying to find a PCB 8 that wouldn't harm the environment? 9 A. That was the intent, yes, sir. 10 Q. Mr. Kotoske has talked about the profits on 11 PCBs. Can you give me som]p e idea--give the jury some idea as 12 to how profitable an item of PCBs was for Monsanto as 13 compared to the other products that it had? 14 A. I guess the best way I can describe it is just 15 to say that PCBs were not what I want to call a star product. 16 They were a good average product for a chemical company. 17 Q. Indeed, Monsanto was the only producer or 18 manufacturer of PCBs in the United States? 19 p A. That is correct. 20 Q. Did Monsanto have a patent on PCBs? 21 A. No, it did not. 22 Q. And there were other manufacturers of PCBs in 23 the world? 24 A. Yes. 25 Q. Japan? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49657 1 A. Yes. 143 2 Q. And what countries in Europe had companies 3 that manufactured PCBs? 4 A. Germany, France, Spain, Italy, Czechoslovakia 5 ]p and Russia. 6 Q. Did Monsanto sell its PCB products to the 7 United States Government? 8 A. Yes. 9 Q. To which branches? 10 A. The Department of Defense--all the military 11 installations and the like--the General Services 12 Administration, the T.V.A. Authority, the Rural 13 Electrification Administration. That's all I can think of at 14 the moment. 15 Q. What ]o did the Government use the PCBs for that 16 they bought--the United States Government? 17 A. They use it in power distribution 18 equipment--electrical equipment. 19 Q. Transformers and capacitors? 20 A. Transformers and capacitors, yes, sir. 21 Q. Who were the first customers for PCBs that 22 were made at the plant back in 1935 that Monsanto bought? 23 A. The electrical equipment 24 ]o manufacturers--General Electric, Westinghouse . 25 Q. For how many years did Westinghouse purchase Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49658 144 1 Monsanto's PCBs for use as a dielec--for use in transformers 2 and capacitors? 3 A. Over 40 years. From the middle '30s to--to 4 '77 . 5 Q. So the Bloomington plant--the Westinghouse 6 Bloomington plant was opened in about 1958, so for over 20 7 years Westinghouse had been buying ]o PCBs from Monsanto prior 8 to Bloomington plant being opened? 9 A. That is correct. 10 Q. Let me hand you this book and I'm gonna ask 11 you to look at Exhibit D-246. 12 MR. KOTOSKE: No objection if he wants to offer 13 that. 14 MR. CARNEY: Just briefly, I want to describe the 15 D-246 and D-247. Can you describe those exhibits for the 16 jury? 17 A. Yes. These are U.S. ]o patents issued to 18 representatives of the Westinghouse Electric Corporation and 19 they refer to the use of chemicals that are added to 20 transformer PCB-type oils to make them perform better and to 21 make them more stable. 22 MR. CARNEY: Your Honor, I would offer these two 23 Westinghouse patents in evidence at this time. 24 MR. KOTOSKE: What's the other one--246? 25 MR. CARNEY: 247. 246 and 247. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49659 1 2 3 4 5 6 7 9 10 Vp 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 145 MR. KOTOSKE: No objection. THE COURT: So admitted into evidence. Both of ' em. BY MR. CARNEY: Q. Westinghouse had patents on the use of PCBs in electrical equipment, correct? A. As reflected by something like these two. Q. And 247 covers an additive that Westinghouse added to PCBs to make a better PCB for the electrical equipment? A. That is correct. Q. Next I'd like to refer to D-54 and D-55. I'd like you to look at those. MR. KOTOSKE: You mean 254 and 255, don't you? MR. CARNEY: I'm sorry. Defendant's Exhibit 254 and 255. MR. KOTOSKE: I'll have an objection to 254 because that has to do with Westinghouse Inerteen transformers which has nothing to do with this case. And 255 is tranjo sformers. If he's got some for capacitors, I don't care, but I don't want transformers going into this case. MR. CARNEY: Your Honor, this--these are PCBs. Or it's the transformers using PCBs, and it goes to the knowledge of Westinghouse about these. THE COURT: Overruled. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49660 1 BY MR. CARNEY: 146 2 Q. Can you identify Exhibit 254? 3 A. 254 is a brochure or pa]p mphlet entitled 4 Westinghouse Inerteen Transformers, published by the 5 Westinghouse Electric and Manufacturing Company. 6 THE REPORTER: Westinghouse what? 7 A. Electric and Manufacturing Company, Sharon, 8 Pennsylvania. 9 Q. What about 255? 10 A. 255 is another booklet or brochure -- 11 MR. KOTOSKE: Your Honor, I think we're going too 12 far. We better go to side bar. 13 p THE COURT: Okay. 14 (A discussion was had at the Bench.) 15 THE COURT: You may continue. 16 Q. Mr. Papageorge, have you had a chance to look 17 at Exhibit -- and would you identify Exhibit 255? 18 A. 255 is a Westinghouse article or brochure or 19 pamphlet entitled Network Transformers and Accessories for 20 Secondary Network Systems published by the Westinghouse 21 Electric an]p d Manufacturing Company, Sharon, Pennsylvania. 22 MR. CARNEY: Your Honor, I move for the admission 23 of Exhibits 250--Defendant's Exhibits 254 and 255. 24 MR. KOTOSKE: Well, you know, I've already objected 25 and you overruled my objection, so I guess they're in. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49661 147 1 THE COURT: It's noted. 2 MR. KOTOSKE: And the other one the same thing. 3 THE COURT: Same thing. 4 MR. CARNEY: I'm gonna show the jury Exhibit 254, 5 and I don't exactly--this right here --can you read it in the 6 back row? I can't -- let me--I'm gonna go up here and I'll 7 pull it over so you can share. 8 BY MR. CARNEY: 9 Q. Would you take a look and read from this 10 Westinghouse document the first sentence of paragraph 2? 11 THE COURT: What page from the document is that 12 chart? 13 MR. C]p ARNEY: That's on page 3. 14 THE COURT: Thank you. 15 MR. KOTOSKE: Well, now, let him read--read the big 16 chart. I don't have a problem with this. 17 THE COURT: It's in evidence, so he can read 18 whatever he wants. 19 MR. KOTOSKE: You don't have to read it. Read it, 20 Mr. Attorney. I don't care. 21 THE COURT: Well, Mr. Carney, do it--do it the way 22 you want to. 23 MR. KOTOSKE: Whatever is easiest. 24 BY MR. CARNEY: 25 Q. Why don't you read it, Mr. Papageorge, since Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49662 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 21) 4 25 I'm-- 148 A. Will you help me find it again, sir? Q. Let me do that. Why don't I read this one because I--it probably goes quicker if I read it. "In this Golden Jubilee Year, Westinghouse takes pleasure in presenting Inerteen." MR. KOTOSKE: I'll s]o tipulate that's what it says. MR. CARNEY: "Much time and effort have been expended in developing this truly nonflammable liquid which may be used as a substitute for transformer oil. Research work to bring about this outstanding development dates back to the year 1921 when the United States patent"--I won't read the number--"was assigned to Westinghouse Electric and Manufacturing Company. Inerteen was first used commejo rcially in transformers early in 1933. Inerteen has been approved by the National Board of Fire Underwriters, thus making possible its use for many applications where oil-insulated transformers carry restrictions." And that's a document--what' s the date of that document? A. 1936. Q. Okay. MR. CARNEY: Your Honor, this will probably be a -- THE COURT: Take a break? MR. CARNEY: --a break point. THE COURT: Ladies and gentlemen, we'll take a Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49663 149 1 short ten-minute break. Do not discuss the case among 2 yourselves or with others. 3 (A recess was taken, after which the 4 following proceedings were had.) 5 THE COURT: We're gonna go for about 40 more 6 minutes if we can stand it. (Inaudible.) Everybody^) okay 7 with 40 minutes? About 40 minutes and get out of here by 20 8 or a quarter to 5? 9 UNKNOWN JUROR: Okay. 10 THE COURT: You're on. 11 MR. CARNEY: Okay. 12 BY MR. CARNEY: 13 Q. Let's go to Exhibit D-55 which has been-- 14 THE REPORTER: Did you say D? 15 MR. CARNEY: D as in David. Defendant's Exhibit 16 255 which has been admitted into evidence. 17 ]o Q. And this is a Westinghouse 1936 document, 18 correct? 19 A. Yes, sir, it is. 20 Q. And would you go to page 7? 21 A. I have it. 22 Q. And read starting with the Inerteen Network 23 Transformers. Would you start reading there? Read the first 24 three sentences 25 A. "Westinghouse research and installation Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49664 150 1 engineers have produced a new p nonflammable insulating and 2 cooling medium for use in transformers and switches known as 3 Inerteen." 4 Q. Now, that Inerteen was Westinghouse's trade 5 name, right? 6 A. Yes. "In addition to these characteristics, 7 Inerteen has dielectric and thermal characteristics equal to 8 or better than transformer oil. It is nonflammable in the 9 sense that it cannot be made to burn, and nonexplosive since 10 p the gas given off is noncombustible when mixed with air in 11 any proportion." 12 Q. Okay. Now, go down to the sentence starting 13 more or less. 14 A. "More or less irritation to the skin may be 15 expected in handling these liquids, and, for this reason, 16 care is necessary when working around transformers and 17 switches in which they are used." 18 Q. Okay. Are you familiar with the type of 19 cap pacitors that were manufactured at the Westinghouse 20 Bloomington plant between 1958 and 1977? 21 A. To a degree, yes. 22 Q. And was Westinghouse plant--well, was 23 Westinghouse one of the largest PCB customers of Monsanto? 24 A. Yes. 25 Q. Next to General Electric? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49665 1 A. Yes. 151 2 Q. What is a capacitor? Can you just explain it 3 briefly? 4 ]o A. I'll try. Since I'm not an electrical 5 engineer, I'll try to use my layman's understanding. 6 Q. That would help everybody. 7 A. It's a device that is used to store electrical 8 energy and to release it in--when needed in sudden bursts to 9 run motors, for example, or to send power along transmission 10 lines on to its destination, wherever it's headed, so that it 11 gets to that destination at the righjo t level, so it doesn't 12 peter out and there's nothing there at the end of the line. 13 Q. Did Westinghouse buy Monsanto PCBs for use in 14 any products other than capacitors at the Bloomington plant? 15 A. No. 16 Q. Did Westinghouse also buy PCBs for other 17 plants that it owned? 18 A. Yes. 19 Q. Tell me what those--just mention those other 20 plants--Westinghouse plants that b]o ought PCBs for capacitors 21 or transformers. 22 A. Sharon, Pennsylvania, and South Boston, 23 Virginia. 24 Q. Were those transformer or capacitor plants? 25 A. Transformer plants. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49666 152 1 Q. Okay. Did they also use PCBs at Westinghouse 2 in its Muncie, Indiana, plant? 3 A. There was a time, yes, when they did. 4 Q. Did Westinghouse also use PCBs in]p its 5 Cincinnati, Ohio, plant, if you know? 6 A. I don't remember that. 7 Q. And where were the headquarters of 8 Westinghouse? 9 A. Pittsburg, Pennsylvania. 10 Q. How were PCBs shipped to the Bloomington 11 plant? 12 A. In tank cars--railroad tank cars. 13 Q. Were there also some 55-gallon drums shipped? 14 A. Oh, yes. Yes. 15 ]o Q. But the vast majority of the PCBs went by tank 16 cars to the Bloomington plant? 17 A. Yes. 18 Q. Take a look at Exhibit 248 and 250. Can you 19 identify Exhibit 248? 20 A. 248 is a copy of a Westinghouse purchasing 21 department specification for 54201 CF and CH. 22 Q. Are those PCBs? 23 A. (No oral response.) 24 Q. Let me ask you this, Mr. Papageorge: Was thisjo 25 a specification for Inerteen for capacitors? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49667 1 A. Yes. 153 2 Q. And this was a Westinghouse specification 3 telling Monsanto how they wanted their Inerteen manufactured? 4 A. Not--not manufactured, but how they 5 wanted--what properties they expected of the Inerteen when 6 they received it. 7 Q. And did Monsanto follow the Westinghouse 8 specifications in makingjo and sending PCBs to the Bloomington 9 plant? 10 A. Yes. 11 Q. Take a look--and that's a specification made 12 in 1961, correct--Westinghouse specification? 13 A. That is correct. 14 Q. Take a look at the next exhibit--250. 15 A. I have it. 16 Q. Is that a Westinghouse specification for 17 Inerteen for capacitors? 18 A. Yes. 19 Q. p And that's dated 1971? 20 A. Yes. 21 Q. And did Monsanto follow this specification in 22 making and delivering to Westinghouse PCBs for the 23 Bloomington plant? 24 A. Yes. 25 Q. What is the purpose of these specifications Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49668 154 1 that Westinghouse sent to Monsanto for capacitors for 2 Inerteen? 3 A. It's to inform Monsanto of the type of product 4 that^) Westinghouse expected to be delivered to its plants. 5 Q. It would describe the chemical, physical and 6 electrical properties that Westinghouse required PCBs to 7 meet? 8 A. Yes. 9 Q. Did Westinghouse have any procedures for 10 testing the PCBs that it received from Monsanto to make sure 11 it met its specifications? 12 A. They did. 13 Q. Did Westinghouse Bloomington plant ]o test the 14 PCBs when they came in railroad tank cars? 15 A. Yes. 16 Q. And what would happen if the PCB tank car 17 shipment didn't meet the Westinghouse specification? 18 A. If it was slightly out of specification, they 19 would attempt to treat it in their own plant. If it was far 20 off specification, they would send the tank car back to 21 Monsanto. 22 Q. Did that ever happen? 23 ]o A. Occasionally. 24 Q. Were PCBs a good dielectric product for use in 25 capacitors ? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49669 155 1 A. The best. 2 Q. Why were they the best? 3 A. Well, of course, they had near perfect 4 electrical properties. But in addition to that, they had 5 this resistance to burning--to fire that was very important. 6 Q. What does fire-resistant mean? 7 ]o A. It means that the material, even in the 8 presence of air, will not support a flame. The flame will 9 keep snuffing out. It will not keep burning. 10 Q. Why is it important to have a fire-resistant 11 material in a capacitor? 12 A. Well, many capacitors are installed in 13 locations that involved valuable property and, of course, the 14 presence of people. And, of course, the idea there is to 15 prevent any ]o disastrous fires from resulting because of a 16 failed capacitor that erupts into a flame and then spews 17 burning oil in all directions. 18 Q. Were capacitors and transformers used in 19 public places like stadiums and subway stations and high-rise 20 buildings? 21 A. Exactly, yes. 22 Q. What is a--what is a building code? 23 A. Well, a building code is a set of--of the 24 listed requiremejo nts describing the kinds of things that a 25 community will--expects in the construction of a building. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49670 156 1 Q. Did any of the building codes in the 2 United States require the use of PCBs? 3 A. Many of the building codes in the 4 United States did require that, yes. 5 Q. For what reason? 6 A. For safety protection--for fire protection. 7 MR. CARNEY: Before I forg]p et, Your Honor, I--I had 8 the witness identify the exhibits 250 and 248--the Inerteen 9 Westinghouse specifications for capacitors. I would offer 10 those exhibits. 11 THE COURT: Any objections? 12 MR. KOTOSKE: No objection to 250. I want that in. 13 But I got a problem with 248. And it's not a big problem. 14 My exhibit has a 248-A attached to it. Does yours? 15 THE COURT: No. 16 MR. KO]p TOSKE: Should I just discard-17 MR. CARNEY: I'll tell you what the difference is, 18 Judge. 19 THE COURT: No, wait. I'm sorry. It does. 20 MR. KOTOSKE: Well, is he offering 24-21 THE COURT: Yeah. 22 MR. CARNEY: I believe they're the same document 23 except one of 'em came out of--let me make sure on this. 24 MR. KOTOSKE: And the other problem, Judge--I don't 25 think it]p 's major. This one--248--it's got a whole lot of Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49671 157 1 handwriting notes. 2 MR. CARNEY: Oh, I-- 3 MR. KOTOSKE: Do you know what that means? Other 4 than that, I--you know, I don't object to it unless 5 (inaudible). But I want the exhibit in. I just don't want 6 it in this form. 7 MR. CARNEY: Okay. What we have here is the same 8 document. One of 'em has Westinghouse bar codes on it]p . 9 That's 248-A which is, I believe, what you have. The other-- 10 MR. KOTOSKE: Is that the one you wanted to use? 11 MR. CARNEY: And that's fine. 12 THE COURT: Want to use A? 13 MR. CARNEY: (Inaudible). 14 THE COURT: All right. 15 MR. KOTOSKE: Use this 248-A. 16 THE COURT: Defendant's Exhibit 248-A and 17 Defendant's 250 are admitted into evidence. 18 p MR. KOTOSKE: No objection. 19 BY MR. CARNEY: 20 Q. Did Westinghouse--Mr. Papageorge, did 21 Westinghouse have an industrial hygiene or a medical 22 department during the years that they were using PCBs? 23 A. Yes, they did. 24 Q. And how do you know that? 25 MR. KOTOSKE: Oh, I'll stipulate they had a medical Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49672 158 1 department. 2 MR. CARNEY: And industrial^ hygiene department? 3 MR. KOTOSKE: Oh, I don't know about that. 4 Q. Did Westingho use also have: an industrial 5 hygiene department? 6 A. They had an industrial hygienist. I don't 7 know if they were organized into a department. 8 Q. And who was the head of the--or who was the 9 person that you had dealings with or had--or who was the 10 person that Monsanto corresponded with in the industrial) 1 11 hygiene department at Westinghouse primarily? 12 A. Mr. Speicher. 13 Q. You described how Monsanto conveyed 14 information about PCBs and safe handling to customers. Let's 15 focus on Westinghouse because that's the customer that was 16 involved in this case. How did Monsanto give Westinghouse 17 information about how to handle PCBs safely? Could you 18 summarize the different types of information? 19 ]o A. There were, of course, the product bulletins 20 that were made available to many people at Westinghouse -- 21 research people, manufacturing people, health people. There 22 were, of course, discussions--person-to-person kind of 23 discussions. The opportunities for that were many. Examples 24 include the contact from Monsanto sales representative who 25 would drop by with brochures in hand and any new information Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49673 159 1 p that he might be brought up to speed on. There were 2 opportunities for Westinghouse people to come to St. Louis 3 and sit down with the--the right people at Monsanto and have 4 these discussions. Opportunities also for individuals from 5 Westinghouse to go to Monsanto plants and then compare notes. 6 That's all that comes to mind now, but-7 Q. Okay. And we'll get into some of those 8 documents tomorrow if we don't get into i]p t today. And, of 9 course, there were warning labels that were put on all the 10 drums? 11 A. Oh, yes. Yes. 12 Q. How do you know the Monsanto warning label was 13 put on every drum of PCBs? 14 A. Well, the procedure at Monsanto for labeling 15 drums involves many individuals whose job it is to check that 16 label through that system. The label is applied to the drum 17 by the individual in charge p of the drumming facility. That 18 drum is labeled before the contents--before the materials is 19 put into the drum. It's moved, then, into the filling 20 station where the individual who fills it again checks that 21 label to see that it's getting--it's labeled with the 22 material it's going to receive. When the drum is full, it 23 is, of course, stenciled with other information like lot 24 numbers and dates and so on. And that's then sent over!) and 25 put on a pallet--four drums to a pallet. Other individuals Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49674 160 1 with fork lift trucks come by when notified to pick up that 2 day's drumming and take it to a warehouse. The individual 3 picking it up checks the labels again to make certain that 4 all four drums on each pallet has the right label on it. 5 Because he's carrying a ticket that tells him what kind of 6 material he's to pick up and where he is supposed t]p o take it. 7 When it arrives at the warehouse, the area designated for 8 that particular load, there is another individual in charge 9 of that warehouse who makes sure that what goes into that bay 10 or that area is the right material. And he fills out his 11 ticket. So that when all these papers go back, then, to the 12 office, they should all match. And then later when a 13 shipment is made, the shipping people know exactly where to 14 ]o go to get the right material to make the proper shipment. 15 Q. Because of those procedures that you talked 16 about, are you certain that every PCB drum that would have 17 PCBs in it that was sold by Monsanto had a label? 18 A. Yes. 19 Q. And it had a Monsanto warning on it? 20 A. Yes. 21 Q. You've described, Mr. Papageorge, how--in a 22 general way how Monsanto conveyed information a]p bout PCBs to 23 Westinghouse. Can you tell me whether Westinghouse had any 24 knowledge about PCBs other than what was given to them by 25 Monsanto? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49675 161 1 MR. KOTOSKE: This is gonna call for hearsay and 2 I'm gonna object. I just don't want to get caught short. 3 MR. CARNEY: I think this--you know, this goes to 4 our knowledge as to what Westinghouse knew. I think it goes 5 to that issue. 6 THE COURT: You want to come over? 7 MR. KOTOSKE: Yeah, I think so. 8 (A discussion was had at the Bench.) 9 THE COURT: You may proceed. 10 Q. Mr. Papageorge, did you know certain people at 11 Westinghouse that worked for Westinghouse? 12 A. I did, yes. 13 Q. Tell me the people that you knew personally. 14 A. I recall a Mr. Don McClain. 15 Q. Where did he work? 16 A. Bloomington, Indiana. 17 Q. Westinghouse Bloomington plant? 18 A. Yes, sir. 19 Q. Okay. 20 A. Dr. T. K. Sloat. 21 THE REPORTER: Dr. whom? 22 THE WITNESS: T. K. Sloat--S-l-o-a-t. He was with 23 the Sharon, Pennsylvania, transformer plant. I remember a 24 Mr. Wilburn. I believe he was with the South Boston, 25 V]o irginia, plant. There was a Dr. Dakin--D-a-k-i-n--in the Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49676 162 1 research dependent in Pittsburg. 2 Q. Did you know a Mr. Mandelkorn? 3 A. Mandelkorn, also with research, yes, sir. 4 Q. Did you have discussions with these people and 5 meetings with these people and telephone conversations with 6 these people? 7 A. Many times. 8 Q. Based on those discussions and col) nversations 9 that you had--let's take 'em one at a time. Let's talk about 10 D. T. Sloat. 11 MR. KOTOSKE: Your Honor, just one other thing. 12 Can we have a rough time frame when it happened? 13 THE COURT: Sure. 14 Q. What was the time period that you knew 15 Mr. Sloat? 16 A. 1970 through 1976. And I still know him 17 today, I guess, but I worked with him through '76. 18 ]o Q. What was the state of Mr. Sloat's knowledge 19 with regard to PCBs? 20 MR. KOTOSKE: Well, see, that's the problem. 21 Objection. 22 Q. Based on your personal knowledge and 23 experience and discussion. 24 THE COURT: He can relate to the tenor of the 25 discussions. He can get into what was discussed and then the Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49677 163 1 jury can make the necessary conclusions. So go ahead and do 2 ]o that. 3 Q. Go ahead. 4 A. Dr. Sloat, to me, was the key Westinghouse 5 individual who knew an awful lot about PCB and transformers. 6 He was Mr. Transformer--Mr. Westinghouse Transformer --in my 7 way of observing him. He was a pioneer in a way, and 8 certainly knew a lot more about PCBs than I did in the 9 transformer application. 10 Q. Did he indicate through the discussions you 11 had witjo h him any knowledge about toxicity of PCBs? 12 A. Oh, yes. In fact, he taught me a few things. 13 Q. Did he -- 14 MR. KOTOSKE: Okay. Now, the objection. You 15 forced the issue. Now, the objection is learned (inaudible). 16 MR. CARNEY: Well, Your Honor, could we do this at 17 side bar? I don't want to get into speeches. 18 THE COURT: Yeah. That's a legal point. 19 (A]p discussion was had at the Bench.) 20 THE COURT: All right. Ladies and gentlemen, we're 21 gonna--I'm sure you'll be disappointed to hear this, but 22 we're gonna stop for today. And the attorneys and I have 23 some matters in chambers that we have to discuss further, so 24 I'm gonna ask you all to be here at 10:15 tomorrow morning, 25 so (inaudible). Again, do not discuss the case among Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49678 164 1 yourselves or with othern s or review or listen to anything 2 about this trial. Any questions? 3 UNKNOWN JUROR: We're not staying 'til 6, right? 4 THE COURT: Oh, no. 5 UNKNOWN JUROR: Good. 6 THE COURT: See you tomorrow at 10:15. 7 (Ms. Pape was replaced.) Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49679 [Os - 2] Transcript Word Index 0 1242 164 Oc 115:20 1 33:19 138:6 139:9,12,18,22 69:24,25 140:5 141:3,8,9,21 142:5 16th 125 97:15 55 6 9 17 17 1 1254 32:4 52:1 117:7 61:15,16,1862:1369:25 32:11 33:9,17 140:2 141:12 172 78:25 79:10,20 84:5 102:20 126 67:1,2,4 71:5,24 110:25 118:20 145:10 57:5 174 1,100,000 1260 72:12 31:20 10:13 32:11 33:9 139:24 175 1/2 141:4,5,5,15 73:11 139:19 1268 17th 10 138:14 86:6 89:25 90:12,23 91:16,19,25 93:13 129 180 93:18 54:23 12:20 10/29/91 129.09a 181 1:1 74:2 76:15 10:00 13 184 2:14 63:14 76:1 10:15 130 189 163:24 164:6 57:16 72:19 100 135 18th 40:14 42:25 64:18 120:22 58:25 7:17 88:23 139:20 141:11,14 136 19 1016 59:1 44:18 139:15,18,22 140:6 141:20 13th 1901 142:2,4 66:4 64:14 135:7 103 14 191 46:10 52:2,11 53:7 54:3 77:3 105 143 1920s 47:2 61:3,22 64:19 106 145 1921 21:23 62:21 148:12 107 146 1929 40:23,24 41:1,1 65:18 70:21 64:23,25 11 148 193 10:25 11:1 46:11 57:10 63:3 64:13 79:9,14 61:23 86:6 88:1 96:22 14th 1930 119:10 28:11 70:13 76:3 111 15 1930's 48:14 49:21 38:7 90:8 123:16 124:4 113 150 1933 50:13 65:5,10,11 148:15 115 151 1935 51:17 65:24 111:10 124:1 143:22 116 152 1936 52:5 54:2 66:9 148:20 149:17 11th 154 194 50:21 66:24,24 79:18 12 155 1943 43:8 96:22 108:6 68:1 102:7 123 15th 1950's 54:22,23 55:12 58:8 19:24 124 16 1951 21:24 80:15 95:4 117:7 103:16,24 104:10 1953 103:24 104:10 1955 17:18 1956 104:18 1958 144:6 150:20 1960's 1:165:17 1961 153:12 1963 103:9 1964 17:17 20:25 110:22 1965 110:22 111:1 121:22 1966 30:19 42:5 1967 1:25 41:23 1968 24:20 123:6 1969 26:17 28:11 31:8 32:5 33:12 34:8,15 38:19 1970 6:21 12:5 19:1 34:24 35:21 36:19,20 37:12 120:11 121:2 123:24 124:1 162:16 1970's 11:17 1971 47:23 48:18 52:2 53:7 54:3 54:18 58:7 153:19 1972 55:4 57:18 58:8 62:2,13 1973 52:11 63:14 66:4 120:16 1974 9:9 43:8 67:19 1975 77:5,22 85:23 86:3,6 87:23 88:23 89:3,25 1976 52:1 95:21 97:15 162:16 1977 96:8 111:13 150:20 IP 34:11 79:10 87:23 126:11 145:10 2 L 161 3411 4216 57 10 24 60:1 79:1 95:1 126:11 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49680 [2 - absorb] 2 (cont.) 147:10 20 11:733:1936:20 61:10 89:23 144:6 149:7 203 85:21 86:6,22 209 87:22 88:16 21 1:25 58:7 117:3 212 89:7 213 89:19 215 90:9 218 90:14 219 90:9 22 16:1,13,18,19 24:20 62:2 96:8 220 91:6,21 221 91:17,23,24 23 11:7 24 156:20 241 93:13 246 94:2,12 144:11,15,24,25 247 94:12 144:15,25,25 145:8 248 152:18,19,20 156:8,13,14 156:25 157:9,15,16 249 96:6 25 57:18 250 146:23 152:18 153:14 156:8,12 157:17 254 145:14,15,17 146:2,3,23 147:4 255 145:14,16,19 146:9,10,17 146:18,23 149:16 258 21:24 26th 16:12 28 30:1931:8 67:18 28th 30:16 2|d 79:20 87:1 102:20 118:20 148:23__________________ 3 3 55:9 57:19 77:5 147:13 30 34:24 36:19 132:19 30s 144:3 321 100:17 3rd 26:17___________________ 4 4 28:3 50:21 89:3 102:7 148:23 40 50:16 84:24 85:8,15 144:3 149:5,7,7 400 104:25 105:6 109:15 42 141:8,9,9,10,11,21,22 46 16:24 17:1 102:8 4th 116:3___________________ 5 5 32:10 76:4 117:4 149:8 500,000 76:3 50's 11:11 14:21 15:1 19:17 22:17 51 17:10,22 522 97:7 54 141:13,13 145:12 54201 152:21 55 22:12 145:12 149:13 152:13 57 18:11,16,19 104:18,24 59 104:24 5th 110:4 6 6 12:5 22:5 25:5 32:10 47:2 56:5 77:5 164:3 60 109:16 141:15,16 60s 31:8 60's 1:19 11:11 14:21 15:1 19:1722:18 63 58:11 63141 100:17 64 20:12,20 66 21:3,8 42:3,6 67 4:6 68 25:22 68.7 21:22 69 27:3 30:16 36:17 111:2 6th 115:20 7 7 14:12 15:6 63:6 149:20 70 21:1424:1338:19 109:16 70's 8:13,23 14:22,23 15:2 19:1822:18 71 11:9 16:4,10 38:20 43:10 43:12 72 9:11 16:1262:16 74 9:11 43:9 75 22:8 76 52:3 94:8 95:4,10 120:11 120:16 162:17 77 95:6 96:4 144:4 78 24:11,14,15,16 79 25:7 95:10 8 8 15:9,11 80 26:4,10,11,12,13 82 27:18 83 28:9 85 30:17 86 30:1731:14,15 103:12 87 32:5 89 33:2,4 8th 87:23 9 9 110:8 90 34:17 92 36:21 94 38:9 39:6 99 139:19 140:4,5 a a.p 37:12 50:12 122:8 abbrevia|3 31:20 abdominal 14:2,10 ability 128:17 able 76:23 about.|3 136:17 absence 3:4,6 66:12 absolutely 40:25 81:18 85:18 104:11 absorb 57:10 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49681 [absorbing - appear] absorbing addressed 14:15 11:18 34:23 77:4 80:15 absorption addressee 18:1 84:12 52:10 accept addressing 9:9 78:3 78:16 acceptable adequate 58:9 85:13 acceptance adequately 60:23 78:21 accepted administration 83:12 68:24 143:12,13 accessories admission 146:19 146:22 accidental admit 107:23 68:13 accurate admitted 9:4 15:21 41:15 94:15 133:10,19 145:2 149:16 acid 157:17 112:22 114:4,4,4,5,10,13 adopted acknowledge 59:18 79:10 adverse acknowledges 8:21 60:11 76:20 90:24 59:13 92:4 acknowledgment advised 60:22 31:1759:14 acquiring advising 42:10 53:7 acrylon advisors 135:16 128:15 act advisory 33:23 39:4 63:11 action affect 84:10 32:14 actions affidavit 60:6 68:23 71:10 72:13,15,23 74:19 active 75:1 72:11 agencies activities 65:15 121:8 7:22 agency activity 37:25 63:12 25:3 36:17 agenda actual 69:4,7 19:9 43:18 agents acute 60:4 32:16 33:1 46:16 56:16,20 ago 65:25 69:8 83:22 125:10,11 92:6,18,24 121:21 125:13 126:17 agree added 10:11 48:9,13 59:22 66:17 144:19 145:9 98:7 107:15 addi|3 agreed 52:24 8:2 80:18 addition agreement 114:25 127:21 150:6 155:4 58:15,17,19 60:20 additive agreements 145:8 58:10 60:18 agrees 59:24 agre|3 57:2 ahead 30:15 50:8 68:16 92:2 137:25 163:1,3 aimed 42:10 air 18:1 57:9 104:3,4 115:3 118:5,6 150:10 155:8 aircraft 102:14 alabama 1:6 111:3,16 115:8 116:10 121:16 132:17 albert 80:15 alcohol 22:4 alien 101:9 allow 25:19 28:21 29:1 31:3 133:17 allowed 18:3 51:1270:19 allowing 112:7 alternative 49:7 94:23 altogether 34:9 108:4 amended 60:14 american 27:5 65:17 110:11,15,18 115:1 amount 74:23 75:1 83:3 87:9 139:17 140:2 amounts 91:3 analysis 97:24 analytical 42:12 76:22 andling 121:14 and|s 13:11 35:17 78:9 angry 134:24 animal 9:3 42:13,14,16,24 60:12 animals 8:13,17,20 9:15 10:17 35:10 43:1,4 54:10 78:18 83:18,20,25 ankles 122:17 anniston 1:6 17:17,1931:9,21 111:3 111:16 112:19 114:17,19 115:8,21 116:10 117:10 121:16,22 122:12 123:7 132:7,17 134:1 ansi 39:18,19 40:18,21 41:1,11 46:11 answer 10:11 11:24 22:17 28:6 29:12,13 44:15 47:5 54:11 54:13,17 77:19 79:12 82:18 84:5 90:6 91:4,22,25 92:3,9 92:18 93:3,9,12,17,25 94:1 105:8 121:11,12 123:10,10 125:23 127:9,20 133:17,18 answered 77:18 84:3,17 85:2 answering 93:5 answers 79:17 82:3 answer 93:23 answ|s 127:13 ant 78:8 an|s 73:3 146:21 anti 102:14 anticipated 69:9 anybody 6:25 7:6 58:18 103:23 106:23 107:9 109:5,8 111:23 121:6,9 any|s 82:11 apers 37:3 apologize 2:10 apparently 92:12,17 appear 27:23 32:5 65:25 71:8 91:15 123:3 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49682 [appearing - badly] appearinp aroclor 86:6 10:13 19:13 25:22 29:3 appears 30:23 31:20,24 32:11 17:1 28:9 72:15 79:18 138:14 139:5,8,9,12,15,17 applica|? aroclors 51:3 11:5 19:8 28:1632:1 33:9 application 55:2,14 113:8 36:14 163:9 aroma applications 138:24 36:18 49:23 148:17 arrangement applied 3:3 159:16 arrive appreciate 23:15,21,25 86:11 arrived approach 23:20 24:7 107:24 108:6 2:2 38:3 58:22 80:21 118:22,25 approach|? arrives 86:16 160:7 appropriate arriving 68:23 132:6 70:3,23 appropriation article 31:19 54:14 146:18 approval articles 31:1842:18 36:24 37:3 54:16 approved articulate 14:16 148:15 126:8 april artificial 24:20 25:22 28:11 30:16,19 74:10 31:8 36:20 86:3,5 ase aquatic 80:23 32:13 33:8 aside are.|? 11:14 49:18 askarel area 96:17 3:7 9:19 28:18 47:12 70:10 asked 80:6 90:21 100:19,22 101:7 3:1 11:9 16:15,20 23:1 105:7 106:8 110:14 118:4 27:12 37:21,23,25 77:16 118:15 160:7,10 90:11,1291:4 100:8,14 areas 105:5 110:7 123:9 25:2 44:18 59:4 asking argue 77:9,22 78:7 79:4 80:7 129:14 103:18 113:14 arguing aspects 129:16 32:8 116:9 arises assessment 83:10 88:23 89:5 arising assigned 60:6 17:16 107:21 116:22 arithmetic's 148:13 117:7 associate arms 3:10 138:23 117:13 associated!? army 53:8 101:25 102:6 association arney 39:1065:1773:13 115:2 147:13 123:24 assume 106:14 assumed 76:19 82:5 121:3 assurance 33:25 assured 7:20 ate 119:17 ap 39:16 103:3 124:7 138:17 139:10 160:22 163:19 ation 5:9 46:24 atlanta 80:3 atmospheric 83:7,11 attach 77:11 attached 54:3 77:15 80:15 156:14 attaches 137:21 attempt 39:2 50:22 64:8 66:12 154:19 attempted 38:20 51:2 attempts 73:9 attended 69:7 attendees 69:10 attention 1:10,16,19 19:1461:22 63:3 attitude 31:2 attorney 147:20 attorneys 163:22 august 36:19 89:3 auspices 65:16 author 3:15,18 62:20 authored 18:22 26:19 63:4 authorities 76:9 authority 40:7 143:12 authorize 93:25 autho|? 52:4 auto 21:24 automobiles 135:19 available 7:23 49:7 65:24 93:15 114:19,25 115:5,15 158:20 ava|? 117:10 ave 39:6 avenue 101:9 average 142:16 avoid 78:25 80:22 122:10,15 142:1 avoided 57:12 award 96:25 97:3,21,22 98:4 123:7 awards 97:12 aware 42:5 59:14 93:18 96:5 97:5 124:3 128:7 awful 163:5 b baby 138:7,11 back 2:7,144:6 19:1 33:11 41:17 45:9,20 55:12 61:15,18 70:21 92:14 102:7 105:19 114:17 117:3 119:23 123:16 124:4 131:25 135:3 142:2 143:22 147:6 148:11 15420 16011 background 63:22,23 101:4 135:4 backup 115:11 bad 4:24 106:14 badly 116:16 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49683 [balance - buffers] balance bench (cont.) birds boulevard 10:23 58:22,24 64:4 86:16,18 32:12 33:8 69:11 78:18 101:12 bald 146:14 161:8 163:19 83:25 bound 27:9 bench|3 bit 60:21 ban 38:5 2:12 8:11 78:7 135:4 140:3 bout 38:25 48:17,19 51:23 62:15 benefit black 160:22 72:2 51:14 138:3 box banned benefits blackheads 119:3 122:13 51:21 95:3,9 51:11 83:21 108:18,22 135:2 boy bar benignus blank 112:4 146:12 157:8 163:17 3:19,20,23 4:10,13 69:23 47:1459:11,11 branch barphenyl benzene bleach 101:8,24 56:12 137:15,16 129:22 branches barr benzenes bleeding 143:9 101:8 137:18 133:9 break based best blends 2:10,12 46:6 61:14 89:24 9:16 45:4 74:8 117:1 29:12 41:18 76:4 94:25 131:3 99:1 148:23,23 149:1 124:20 127:9,17,18 162:8 111:17 115:14 142:14 block break.|3 162:22 155:1,2 101:11 61:16 basic beth bloomington breathe 66:12 126:18 54:11 1:8,11,14,17,21 2:25 3:14 106:4 basis better 3:17 4:7,21 5:4,21 6:6,16 breathed 7:7,9 25:5 31:4 44:21 65:24 85:13 105:21 115:11 123:4 7:6 77:25 139:8,17,21,25 124:4 117:17 133:11,20 144:20 145:9 140:5 141:5 144:5,6,8 breathes bath 146:12 150:8 150:20 151:14 152:10,16 115:3 112:11 beyond 153:8,23 154:13 161:16,17 breathing battery 66:17 127:22 bloomington|3 106:16 109:25 117:2 114:4 big 110:17 bricklayers bay 147:15 156:13 board 114:6 160:9 bigger 24:25 31:18 57:20,21 brickwork bear 72:10 148:16 114:5 69:22 79:20 89:21 bill body brief beautifully 45:4,9,1548:16,17 110:10 78:11 82:15,20,24 126:11 2:15 99:4 135:5 137:4,5,7 84:25 billion boiled briefly began 75:13,18 138:1 101:4 102:11,20 103:17 31:7 64:22 binding bones 110:25 131:9 144:14 151:3 behalf 60:19 108:19 bring 59:25 bioaccumulation book 2:14 29:5 68:14 95:15 behave 74:10 144:10 123:9 148:11 51:10 112:9 biopsy booklet brochure beings 54:20 146:10 146:3,10,18 69:9 78:19 84:1 biphen|3 booklets brochures belief 137:18 131:20 131:20,22 158:25 122:24 biphenyl boss broken believe 21:19,20,22,22,25 56:3,12 45:23 117:2,4,5,6 122:16 133:9 11:7 33:5 34:1,3,20 39:7 56:15 57:5,14 59:10 84:8 boston brought 40:23 43:25 49:10,24 51:19 113:2,2,4,4,6 137:17,18,21 77:24 79:7 80:17,19 151:22 123:11 159:1 51:20 73:23 79:3 81:8 137:22 161:24 brown 90:25 94:21 103:11,12 biphenyls bother 1:1 138:3 105:5,9,20 109:15 125:2 137:13 156:22 157:9 21:16,1827:6 32:11,14 85:14 42:25 59:9 76:17 82:19,23 bottom bfj 88:18 151:20 161:24 83:17 84:16 98:2 113:15 15:18 16:11 27:1833:3 bubble believed 137:23 69:25 119:3 122:13 138:3 137:20 15:21 25:25 bird bought buffers bench 78:21 84:3 111:9,10 143:16,22 15:16 2:2,5 38:4 53:12 54:1 56:10 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49684 [building - chemicals] building capacitor cars 135:24 155:22,23,25 156:1 57:25 58:5 65:14 110:11,15 15:3 129:21 152:12,12,16 156:3 110:18 151:2,24 155:11,16 154:14 buildings capacitors carter 155:20 25:15 49:16 64:20 65:8 29:14 53:13 99:6 140:11 bulletins 143:19,20 144:2 145:20 case 96:16 158:19 151:14,20 152:25 153:17 2:13 5:2 25:22 35:10 46:7 burn 154:1,25 155:12,18 156:9 61:1770:1389:11,1299:2 21:21 49:11 150:9 captain 100:6,7,9 130:4 132:18 burning 102:4 145:19,21 149:1 158:16 21:21 155:5,9,17 car 163:25 bursts 119:10 132:22 154:16,20 cases 151:8 carbon 110:11,14 bury 130:14 cash 14:16 care 96:25 97:11,21 98:4 business 11:21 59:1569:15 117:8 cath 22:18 23:2 49:22 94:20 145:20 147:20 150:16 37:21 89:3 126:3 150:19 135:14 careful caught businesses 41:15 52:19 82:13 106:3 36:12 161:2 135:12 carefully cause bu|s 114:16 22:1 54:11 75:14 76:25 107:15 carney 81:8,11 83:8,9 124:18 buy 2:2 10:8 18:15 20:7,13,17 125:1,3,15 128:6,21,24 138:7 151:13,16 24:15 25:12,18 28:14,22 129:1,4,22,24 130:5,10,16 buyer 29:9 30:21 38:3,12 44:11 130:17,24 131:7 59:11,12,13,22,23,24 60:1 52:12,21,24 53:9 56:7 58:2 caused 60:1,9,14,1761:1 58:20,22 63:17 66:15 67:10 76:24 123:25 124:22 buying 68:6,9 70:6,9,13 77:23 79:5 127:12 128:2 141:23 144:7 83:14 85:3,17 86:15 88:3,6 caus|3 c 88:11 90:16 91:18,21,23 128:14 calandra 86:2,13 ralifnrnia 92:1 95:8,17 98:7,13 99:5 100:1,2 107:9,17 125:25 126:15,16,22 127:5,6,8 cbs 19:4 cc'd 27:25 128:1 129:12,19 130:2,20 86:5 call 29:10 56:13 64:6 97:4 130:22,23 132:25 133:14 cell 133:21 134:19 135:3 54:19 100:6 101:7 106:10 108:23 144:14,22,25 145:4,15,22 cellular 110:4 125:10 132:5 140:8 146:1,22 147:4,8,21,24 83:19 142:15 161:1 148:8,22,23 149:11,12,15 centigrade called 24:1 32:1 100:7 110:2,3,4 156:7,17,22 157:2,7,11,13 12:21 157:19 158:2 161:3 163:16 certain 112:23,24 113:8,20 117:15 carondelet 23:24 33:8 59:10,19 69:15 139:14 136:18,25 69:16 103:3 105:13 160:3 calling carpet 160:16 161:10 47:5 certainly 88-1 calls carpeting 5:3 9:7,20 12:15 17:9 23:9 796 135:16 39:25 48:22 67:6 77:13 camera carried 78:16,4,14 100:5 105:25 125:16 16:17 116:16 123:11 124:19 candle 13719 carries 105:21 129:2,6 131:1 163:8 certain|3 canvas carry 71:23 71:18 78:2,5 84:9 148:18 certa|3 11794 cap 117:22 carrying 84:6 85:25 160:5 59:12 101:6 cetera 82:18 127:19 cf 152:21 ch 142:2 152:21 chair 65:22 chaired 24:24 41:2 chairman 24:25 39:12,16 63:6 68:18 73:12 chambers 63:18 163:23 chance 2:17 20:14 100:3 106:5 116:15 146:16 change 3:9 6:159:12,16 10:17 14:25 23:6,12,14,25 24:7 72:7 84:20 85:13,16 106:5 106:7 120:15 changed 14:22 70:5,25 74:2 102:13 137:11 changes 24:2,3 115:23 122:2 changing 85:15 chapped 125:2 characteristics 150:6,7 charge 36:1,4 103:22 105:16 159:17 160:8 chart 147:12,16 check 159:15 checks 159:20 160:3 cheek 108:18 chemical 8:1 14:16 15:16 19:3 24:4 48:1051:10,11 55:1362:7 64:14,17 65:4 76:23 77:10 102:17,20,22 107:25 108:4 111:9 112:24 113:1 126:6 126:10,11 128:21 142:16 154:5 chemicals 27:6 31:25 32:1 46:18 55:20 95:24 103:3 105:12 107:23 111:21 113:6 115:24 126:10 128:24,25 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49685 [chemicals - conditions] chemicals (cont.) claims combination comparison 129:3 130:5,9,9,12,13,16 60:5 60:9 130:15 76:12 130:17,24 136:2,7 137:12 clarify combine complain 144:19 125:7 126:22 114:10 78:6 chemist clay combined completed 76:22 130:14 14:15 114:13 137:18 43:14,15 chemistry clean comedones completely 102:24 6:24 114:5 122:25 123:2,12 83:21 86:12 120:1 chest cleaner comfortable complicated 106:14,14 109:24 125:3,4 123:4 129:23 131:6 106:17 113:5 126:25 127:22 cleaning coming complied chief 119:10 38:10 119:5 58:10 24:25 132:19,21 cleanliness comment component children 118:24 94:7 56:12,13 101:2 123:12 clear comments compound chloracne 138:9 91:13 57:10,10 139:22 5:5,8,22 13:25 14:9 83:17 clearly commerce compounds 83:20 92:6,17,23 106:20 70:10 130:3 22:22 17:24 91:1 93:20 107:3,10,18,19 108:6,13,25 clears commercial concede 109:3,6 110:2,8,11 127:23 129:23 64:22 126:10 130:5,10,16 132:9 134:9,13 close commercially conceive 134:25 62:21 109:17 139:19 27:22 27:21 chloride closed commep concentrations 114:14 65:7 148:14 83:7,12 chlorides clothes committee concern 13:15 4:14 5:14 78:25,2 106:5,7 24:19,21,23 25:21 39:13,17 46:14 81:2 82:7 124:10 chlorinated 116:16 39:19,1940:19,2041:2,11 concerned 32:11 42:25 113:7 130:14 clothing 46:11,13 47:3 48:17 50:2 9:6 52:25 81:4,7,13 82:10 137:22,23 138:6,11,13 3:9 15:15 78:25,25 135:15 50:11,13,21 63:11 65:18,20 129:18 140:9 141:2,3,4,22 club 65:22 73:12 concerning chlorination 112:4 common 81:19 137:23 139:12 140:6 141:8 coats 39:25 40:1 129:25 137:12 concerns chlorine 117:12 137:13 35:23 73:7 80:22 13:1521:4,7,11,12 130:15 code communicate conclude 137:13,14,20,21 141:11,13 100:17 155:22,23 27:15 115:12 121:5 50:22 141:18 codes communicated concluded chlorine|3 55:19 156:1,3 157:8 45:13 25:8 43:19 114:13 coffers communities concludes choice 34:11 112:3 33:6 92:17,20 cold community conclusion choose 106:14,15 109:24 125:4 9:22 121:7 155:25 8:15 34:7 92:18 colder companies conclusions chronic 117:21 58:10 68:8,23 72:10 113:3 9:2 10:3 33:3 45:4 163:1 46:15 57:1,1,3 69:8 126:18 collect 143:2 conditioend ch|s 138:2 company 118:5 113:3 collection 15:22 19:3 24:24 33:2,6 condition Cincinnati 20:22 41:17 52:9 55:13 57:22 3:11 4:22 7:17 10:21 152:5 collective 59:9 61:1 62:7 64:24 65:6 conditioned cited 75:16 86:3,25 93:18 136:11 104:3,4 118:6 19:20 color 142:16 146:5,7,21 148:14 conditions cities 138:10 company's 1:11,16,20,22 2:24 3:2 4:7 112:10 colored 135:9 4:17,20,24 5:4,20,23,25 6:5 citizens 135:23 compare 6:9,22 23:12 60:17,24 77:1 30:3 48:12 comb 134:23 159:5 78:25 105:13 115:17 city 123:3 compared 117:15 118:23 121:21 101:8 136:14 142:13 122:3 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49686 [conduct - covered] conduct constant 6:6 95:25 conducted construction 8:12 44:9 155:25 conducting construed!} 46:23 134:15 conference consumer 2:5 37:1,4 38:5 53:12 86:18 23:11 confirmed contact 9:17 42:7 18:3 45:25 57:12 83:14 confuse 158:24 95:11 contain confused 19:1960:1462:12 71:14 contained confusion 3:24 35:4 41:4 90:8 141:23 142:1 containing congress 60:24 37:10,13,14,20,23 38:10,13 contaminant 39:3,14,21 51:23 52:3 95:3 41:23 95:9 contaminate congressional 84:9 48:19 contaminated congressman 47:23 48:1,4,7 84:12 36:25 37:4 38:17,18,18 contamination 48:15 60:11 122:23 congressman's contend 48:20 51:19 congre|s contents 38:22 18:24 52:19 80:17 159:18 connected con|3 141:24 46:15 connection continue 60:7 69:19 1:1 70:19 146:15 conscious continued 48:11 1:3 4:25 6:1,2 33:14 34:15 consequence 62:24 72:2 continuing consider 49:25 9:18 52:4 contracting considerable 5:22 47:10 contracts consideration 60:13 60:1 control considered 39:14 106:9 120:10 66:6,11 controlled considering 106:16 5:4 controls consisted 65:13 5:13 convenient consistency 46:3 138:8 convenient!} consistent 40:10 70:25 conversations consists 162:5 24:23 conveyed 81:13 158:13 160:22 convinced cotton 75:12 112:23 cooled coughing 138:2 125:4 cooling counsel 150:2 1:1 coordinate countries 39:13 63:2 143:2 coordinated country 39:23 69:17 48:4,12 51:2 75:17 cope county 75:14 100:16 copied couple 2:20 61:25 64:11 104:17 114:8 131:2 copies course 41:24 42:2 43:15 87:19 72:10 75:7 78:4 93:13 96:14 115:1 105:18 112:22 113:7 copy 114:24 118:9,18 119:17 2:6 4:6 42:6 80:9 86:7 87:6 122:10 131:1 133:4 136:1 89:9,10 94:15 152:20 136:19 155:3,13,14 158:19 corporate 158:22 159:9,23 24:18,19,20 25:21 30:16 court 32:4 36:21,23 37:6 75:17 1:1 2:4,8,16 10:10 18:19 corporation 20:9,15,19 25:16,19 26:10 23:18 25:5 144:18 26:12 28:17,21,24 29:1,12 corps 31:3,1338:6,1640:12 102:16 44:14 46:5 52:16,19,23 correct 53:2,11 54:13 55:22 56:9 4:19 10:4 12:24 24:9 34:16 56:11 58:3,23 59:4 61:6,10 37:24 39:5 40:22 42:1,2 61:14,21 63:19 64:1 66:17 54:8,9 56:1,17 57:4 64:13 66:22 67:12 68:12 70:13,19 65:21 68:2 78:1 81:3 82:25 78:1,3,5 79:8 82:22 85:4 90:2,10 104:8,14,16 105:4 86:17,19 88:1,5,8,14 89:22 110:10 111:14 136:23,24 89:24 90:14,19 91:22 92:2 140:7 141:17,19 142:19 95:14,19 98:15,17 99:1,5 144:9 145:6,10 149:18 100:1 107:15 126:2,6,14 153:12,13 127:2,5,17 129:16 130:21 corrected 133:17 134:17,21 145:2,25 40:25 146:13,15 147:1,3,11,14,17 correction 147:21 148:23,25 149:5,10 78:3 156:11,15,19,21 157:12,14 correctly 157:16 161:6,9 162:13,24 14:18 15:24 19:15 26:2 163:18,20 164:4,6 46:18 98:8,14 103:10 courthouse corresponded 136:12 158:10 courtroom correspondence 139:2 131:24 cousin corrosive 112:24 21:12 114:10 covenants cost 59:24 95:22 96:1,2 111:22 cover costs 77:15 117:11 127:7 131:9 60:6 95:24 111:22 covered CO|} 68:10 100:14 101:16 107:6 126:21 162:8 103:18 106:3 115:24 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49687 [covering - desk] covering dakin dealings departments 119:6 161:25 158:9 107:22 covers damage death depended 115:5 145:8 5:10 6:1 78:12 82:16 47:18 84:5 85:11 128:6,10 74:16 76:25 cows 106:24 109:11 110:5,17 128:14,19,21 129:1,4,22,24 dependent 35:10 128:22 130:17 132:11 decades 58:8 162:1 crack damages 85:8 depending 136:8 60:5 127:24 decernber 137:22 create dan 36:17 58:7 depends 60:1582:11 112:10 80:15 decided 52:16 83:2 116:3 created dangerous 25:21 71:4 142:1 deposed 121:2 6:9 8:1 92:7,11,18,25 93:1 deep 89:15 creature dangers 49:25 der 47:20 78:21 defend 60:9 creatures dashboard 60:3 dermatitis 77:2 135:19 defendant's 18:2 132:15 criminal data 145:15 146:23 149:15 describe 39:4 9:13 11:3,6,9,11,15,16,18 157:16,17 20:2 35:3 43:1 47:19 72:9 critical 11:25 12:4,5,18 13:19 defense 76:18 108:16 110:25 33:25 66:12 15:19 43:24 44:4,8,18 45:5 40:6 143:10 111:15 114:22 118:17,22 cronic 45:10,19 49:22 66:12 70:25 defined 120:24 122:5 126:19 127:2 56:25 71:13,17 19:9 131:15,17,20 134:11,20,21 cross date definite 141:9 142:14 144:14,15 68:14 9:10 15:21 16:1,5 20:25 134:10 154:5 cp 58:10 60:1 63:14 97:15 definitely described 40:18 114:22 118:9 147:13 103:15 148:19 71:7 114:8 134:22 5:20 10:22 41:6 82:13 92:8 cubic date.|3 definition 105:11 111:5 112:13 117:9 57:9 45:2 27:13 74:1,3 125:11 121:14,21 125:2,4 127:21 cumulative dated degree 134:9 158:13 160:21 76:2 1:24 11:9 16:11 17:18 46:15 83:2 102:18 118:24 describes cups 24:19 28:11 34:24 43:10 150:21 27:16 128:5 54:23 55:3,4 57:18 62:2 degrees describe^ curi|3 63:13 77:4 86:5 87:23 89:3 12:20 21:23,23,24,25 138:9 141:20 96:8 135:15,16 153:19 deliberately describing current dates 95:11 55:20 115:2 155:24 46:24 61:1 91:2 148:11 159:24 deliver description curtains david 60:16 80:7,8,23,25 90:13,23 139:2 47:4 80:13,1891:8 149:15 delivered design customer day 14:7 59:25 80:19 154:4 103:1 126:11 23:8 37:22,23,25 111:24 7:7,7,9,9 32:23 34:19 87:8 deliveries designated 158:15 87:9 110:21 118:8 120:9 59:23 160:7 customers 129:4,25 delivering designation 6:13 26:7,17 33:25 34:11 days 153:22 61:1 37:18 58:6,13 59:21 96:3 135:19 delivery designed 98:4 131:13,18,25 132:2 day's 59:20 60:1 16:5 24:6 143:21 150:23 158:14 160:2 demonstrable designing cut ddt 83:10 103:25 3:13 27:22 28:5 demonstrated desirable Czechoslovakia de 17:25 83:18 59:12 143:4 47:8 deny desire d daily 117:17 133:6 dairy 35:12 deadlines 95:5 deal 19:14 37:20 dealing 124:21 69:11 94:19 department desires 4:3 11:13 40:6,7 79:12 93:9 59:11,12 105:3 132:4 143:10 152:21 desk 157:22 158:1,2,5,7,11 105:22 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49688 [despite - drinks] despite 31:5 32:21,23 destination 151:10,11 destroy 84:10 96:4,13 detail 27:16 102:12 139:10 detailed 47:10 137:6 detect 76:23 detergents 136:3 determine 76:4 95:1 develop 31:7 33:10 78:13 82:17 83:2 124:5 developed 108:5 120:14 developing 33:7 148:9 development 24:19,21 25:21 94:24 148:11 develops 13:10 19:12 device 151:7 diagnose 107:2,12 126:8 diagnosis 127:18 134:16 dible 38:14 dictate 79:23,25 80:4 dictated 79:25 died 4:25 128:7 dielec 144:1 dielectric 3:24 58:6,11 64:19 65:7 94:23 150:7 154:24 dielect|3 96:11 diet 135:17 difference 19:1063:1 134:7,10,11 156:17 different 10:2 25:2 27:14 31:25 different (cont.) discussed document (cont.) 44:18 54:7 61:5 89:20 95:5 32:7 34:18 36:2 39:13 44:5 19:4,22 20:21,23,25 21:1 118:23 158:18 84:5 120:9 162:25 26:15 55:1 57:18 59:2 differentiate discussing 60:23 63:4,15 68:4 73:23 1:12 34:25 79:14 96:21 97:9,17,23 differentiation discussion 98:22 147:10,11 148:19,19 1:15 7:10,11 54:1 56:10 58:24 149:17 156:22 157:8 difficult 64:4 146:14 161:8 162:23 documents 22:21 27:15,21 50:1 83:20 163:19 11:12,22,23 12:11,14 direct discussions 105:15 107:5 159:8 1:3 61:8,22 1:15 158:22,23 159:4 162:4 docum|3 directed 162:8,25 163:10 115:4 63:6 disease doesn'|3 directions 19:12 110:8,14 25:15 155:17 diseases doing directly 126:4 48:21 70:17 85:20 9:23 45:21 132:2 disfiguring domestic director 18:2 25:24 58:11 20:5 30:11 87:1 disinfectant don directors 138:20,24 161:14 31:18 57:20,22 60:4 disinfectants donation direct^ 138:21 112:6 61:7 dispensary door dirties 106:13 49:11 119:17 122:21 disposal dozen dirty 28:16,17 7:12 119:20 122:21 disposition dr disagree 59:16 60:8 11:10 18:22 20:4 26:21 44:14,15 dispute 29:8 30:1,9 34:19 35:21 disappear 10:15 36:11 44:1 52:9 63:6 64:8 50:17 disregard 87:1 161:20,21,25 163:4 disappeared 48:11 drain 50:17 disruption 129:23 disappointed 2:11 drains 163:21 distilled 129:23 disastrous 55:2 drank 155:15 distributed 35:15 discard 37:11 43:16 draperies 156:16 distribution 47:4 discarded 87:4,20 143:17 draw 138:3 distributors 39:20 discharge 47:11 drawn 70:3,24 112:1 district 34:7 discharged 80:5 drenched 102:3 division 5:14 116:16 118:19 discharges 31:1933:10 dress 98:1 dizziness 123:4 disclaims 22:5 drift 15:23 doctor 129:11 discontinue 54:2 106:13,15 108:9,11,24 drink 33:9,11 116:7 121:19 133:3,4,5 75:7 128:5 129:13 discuss doctors drinking 2:11,13 18:24 25:5 46:6 110:23 126:19 75:2,3 61:17 80:20 99:2 116:8 document drinks 149:1 163:23,25 12:17 16:25 17:1,5,13,16 135:18 17:18,22 18:18,22,25 19:2 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49689 [drive - et] drive edema emical 100:17 14:2,10 113:3 drivers edison emmet 112:9 34:10 40:3 58:12 18:22 20:4 87:1 drop effect emotion 20:19 116:14 158:25 8:19,21 22:1,2 43:4 47:20 51:17 dropped 60:11 76:20 78:19,25,7,10 emotions 95:25 83:18 84:1,4 125:15 49:23 drug effective emphasize 22:4 68:24 115:17 94:19 drugged effects emphasized 22:1,2 13:21 18:2 42:11 46:15 7:22 106:9 drugstore 54:4,10 73:14 77:10 78:11 employed 138:8 78:18 82:15,19,24 83:15,25 88:22 drum 90:24 92:4 93:19 106:23 employee 14:1622:11 159:13,16,18 109:9 124:22 125:18 126:9 3:25 30:13 78:24 80:2 159:19,22 160:16 127:11 115:7,25 116:3 117:1 drumming effluent 132:19 133:8 159:17 160:2 63:6,10 68:25 71:15,19 employees drums 73:19 74:7 44:2,3 60:4 77:16,22 78:7 14:6 15:2 18:5 19:1822:12 effluents 78:20,5,20,23 79:4 82:1 152:13 159:10,15,25 160:4 66:13 70:10 90:20 84:2,18 85:9 105:7,20 drum|3 effort 106:20 110:25 123:8 84:21 39:14,25 48:19,20 69:17 133:15 dry 72:7 148:8 enact 131:6 136:8 efforts 38:20,24 due 69:19 98:20 ence 92:24 eggs 85:12 duties 138:25 enclosing 102:11,13 110:25 111:15 eight 72:13 120:25 26:12 43:21 115:4 energy duty either 151:8 60:16 10:22 65:3 83:9 89:15 engaged e 113:23 132:5 137:24 23:2 eachp 1193 elec|3 34:3 engineer 102:17,20 103:5,25 126:6 earlier electric 126:10 151:5 16:1 27:12 41:6 53:3 55:16 70:15 94:5 107:4 127:23 1308 1349 1366 early 5:17 8:13,23 19:1 35:21 41:23 94:8 101:12 106:10 34:10 40:3 41:5 69:7,16,15 engineering 110:16 143:24 144:18 7:14 77:17 102:22 146:5,7,21 148:13 150:25 engineers electrical 102:16 150:1 26:18 34:1,9 39:9 41:7 49:7 enroute 62:11 63:2 65:6,16 69:18 23:25 148:15 ears 108:19 easier 1P17 73:12 78:9 143:18,23 145:6 ent 145:9 151:4,7 154:6 155:4 115:4 electrification entertain 143:13 66:18 eliminating enthusiasm easiest 14723 east 110:3,9,18,5 100:13 elmer 26:19 em 123:1 entire 21:9 entitled economically 145:3 156:23 157:8 162:9 55:1 59:8 146:3,19 73:21 103:4 ed embarked 36:13 entry 73:16 68:20 environment 26:25 34:4,11 42:12 50:16 50:23,25 51:1,10,12,15,16 59:15 60:12 73:16 75:6,14 76:19 91:1 93:21 122:21 142:8 environmental 14:23 30:2 32:7 36:1 41:23 63:11 73:14 76:23 88:22 89:4 90:24 92:22,25 93:19 120:10 121:5,8 122:22 environments 66:2 epa 37:24 38:1 40:6 52:4 64:7 65:1 66:4 68:25 69:18 70:3 70:23 71:5 72:7,13,15 73:5 73:9 75:1 89:25 90:11,12 92:19 93:14,23 94:7,18 95:5 epa's 97:25 98:2 equal 150:7 equipment 3:3 7:23 13:8 26:18 34:1,3 41:7 49:7 57:25 58:5 62:12 78:11 95:24 103:2 104:1 111:20,21 115:15,15 117:9 126:11 143:18,18,23 145:6 145:10 er 8:19 127:13 ers 75:17 eruptions 83:9 erupts 155:16 es 46:6 128:23 135:8 esis 97:24 essence 128:18 establish 66:13 established 59:17 estimate 120:19 estimated 76:3 et 82:17 127:19 156:7 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49690 [etation - fighting] etation exhibit (cont.) exposing fairly 10:14 77:3 86:6 87:25 88:1 94:3 122:11 6:24 98:22 113:25 e|3 96:22,23 97:7 144:11 exposure falls 58:12 107:24 145:15 146:2,17,17 147:4 4:22 5:1,6,11,13,20,25 6:10 122:16 etter 149:13,15 152:18,19 13:1,22 14:8 19:13 54:4,11 false 34:21 153:14 156:14 157:5,16 58:18 83:1,3,7,11,16 92:23 73:3 europe exhibits 106:25 108:5 109:19 familiar 143:2 144:15 146:23,23 156:8,10 110:10 115:23 124:23 11:6 12:1367:7 89:17 evaluate existed 125:10,14 126:9 127:12,22 114:9 150:18 83:20 12:11 49:12 85:7 95:23 127:24 128:2,8 132:13 families evening existing 134:2 123:9,11 132:23 133:7 60:13 exposures family evenings expand 125:12 78:2 113:6 130:13 133:1 30:20 31:8,22 expression far eventually expansion 139:1 23:12 47:8,21,25 48:3 86:3 4:23 31:9,21 expre|s 124:20 128:17 129:11,18 everybody expect 31:2 146:12 154:19 22:16 95:16 116:23 141:24 67:4 extended fashion 151:6 expected 124:5 3:14 19:8 everybody^ 23:10,19 83:9 105:13 extensive fat 149:6 118:24 121:4 123:10 42:10 131:4 evidence 150:15 153:5 154:4 extent fats 33:7 35:19 65:25 85:19 expects 37:10 47:22 48:7 131:4 87:25 128:5 133:9 144:23 155:25 external fda 145:2 147:17 149:16 expended 83:22 42:18 157:17 148:9 extract features evid|3 expenses 131:4,7 51:14 85:12 60:6 extreme february exactly experience 5:2 47:18 128:13 67:18 77:5 44:11 52:18 147:5 155:21 84:24 162:23 extremely fed 160:13 experienced 27:21 35:10 examination 79:1 81:5 92:23 eyes federal 1:3 10:23 68:14 94:6 experiences 83:8 124:25,25 11:14 37:25 38:22 113:13 example 68:4,22 expert f feed 60:12 69:24 90:3 113:22 114:2 121:12 122:15 129:7 137:16 151:9 expertise examples 107:14 112:5,21 114:1 129:21 explain 130:9 131:2 158:23 6:9 10:11 72:1 78:13,19 excellent 82:17 84:1 151:2 97:23 explained exception 125:8 14:22 explanation excess 3:12 8:9 29:5 137:5,6 57:8 83:12 explode excessive 49:11 83:16 exploding excuse 13:11 24:11 107:1 explosion executive 12:18 24:25 25:1 explosions exhaust 49:9 15:13 exposed exhibit 57:7 105:12 107:25 10:25 11:1 46:11 61:22 115:12 face|3 11512 farilitipQ 31'23 facility 15917 facing 255 fact 3:9 19:24 28:8 39:3 51:23 68:15 76:21 111:8 119:2 140:4 163:12 factor 741 o failed 15516 faint 13810 fair 1:5 121:24 feeds 123:5 feel 49:21 feet 78:10,11 84:13 felicia 2:14 fellow 80:24 87:14 felt 77:18 121:10 fers 27:3 fibers 135:14,15,16 fields 112:23 fighting 12:25 13:1 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49691 [figure - getting] figure fitzgerald 107:16 71:11,1594:7 figured five 75:16 2:12 13:1822:12 111:1 figures 133:25 135:13 37:15 fiv|3 files 2:10 96:14 121:19 flame filling 59:13 155:8,8,16 132:22 159:19 flammable fills 21:20 159:20 160:10 flash final 12:20 21:23 47:12 114:14 flavor finally 136:11 36:16 43:18 96:21 123:5 flexible 133:2 138:12 136:8 financially flip 58:9 93:8 find floor 16:3 55:1077:1581:19 84:9 106:15 135:19 142:7 148:2 flowing finding 102:25 10:16 119:10 fluid findings 28:23 29:3 30:24 64:19 45:2 65:8 131:6 fine fluids 25:7 52:1 89:22 126:21 3:24 58:6 94:24 102:25 157:11 flu|3 finish 29:6 85:3,4,5 127:13 133:18 focal finished 29:5 114:6 focus fire 1:10 158:15 12:18,25 13:6,10 21:23 folks 49:6 148:16 155:5,6,10 99:2 156:6 follow fires 120:2 137:7 153:7,21 13:1,1549:9 155:15 followed first 79:1 112:13 139:5 11:2 12:17 16:6,9 39:16 following 41:21,22 42:3,5 45:15 7:24 44:17 55:19 61:20 48:16 52:25 54:14,15 63:22 149:4 68:17 77:14 82:14 92:20 food 98:14 101:10 103:20 35:9 42:18 59:18 60:12 104:10 109:19 116:14 119:19 118:22,25 135:9 139:1 footsteps 143:21 147:10 148:14 122:14 149:23 force fish 104:24 32:16 48:3 69:10 74:9 forced fit 163:15 92:24 125:11 ford fi|D 80:2 103:23 forehead 108:20,21 foreign ft* 121:8 95:19 foreman full 116:8 117:5,6 4:15 7:12 159:22 foremen fully 7:22 86:11 forestalling fumes 97:25 21:25 106:16 109:25 forgot 111:25 116:19,21,25 119:5 123:6 124:4,10,14,18 forgotten functional 50:9 85:6 55:13 forg|3 funeral 156:7 62:21 fork further 160:1 58:7 59:19 98:16,25 127:22 form 127:24 163:23 8:8 13:25 14:8 16:5 30:23 future 30:24 83:21 84:23 95:20 60:4 116:8________________ 97:10,11 126:14 157:6 g format 11:19,21 gallon 22:12 129:13 152:13 formed garry 65:17 forms 32:13 60:24 forth 77:17 gas 21:4,8,11,12,12 137:13 150:10 15:20 41:5 42:13 58:13 59:21 60:15 67:16 72:2 84:7 91:3 131:25 forward 77:3 gases 13:2,14 102:25 gasoline 124:15 129:20,21 137:16 foul 38:13 found 9:11,14 26:24 28:2 30:18 ge 71:23 72:5,6 83:21 general 34:10 40:3 41:5 58:12 68:16 69:7,16,15 83:6 32:12 45:6 64:19 66:2 82:2 110:15 132:3 143:11,24 98:5,11 118:20,25 141:1 foundation 22:16 72:18 founded 135:6 four 150:25 160:22 generally 116:5 117:23 120:23 122:5 138:10 generate 124:17 9:10 12:16 100:21 122:9 159:25 160:4 fourth 122:23 fowl gentlemen 2:8 148:25 163:20 george 86:24 87:14 88:18 89:4 georgia 32:14 frame 162:12 france 80:3 germany 143:4 143:4 ge|3 97:14 front 119:10 124:9 129:14 getting 4:14 33:24 43:21 87:11 109:6,8 111:20 133:3 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49692 [getting - help] getting (cont.) going (cont.) guess (cont.) harvard 159:21 117:13 118:14 119:9 120:2 129:20 142:14 146:25 16:17 ghest 126:14 127:7,20 129:16 162:17 hat 80:6 134:15 135:5 145:21 gummy 113:22 117:20,23 girl 146:11 159:22 119:1,15 have|s 112:4 golden guy 104:9 give 148:5 44:1 93:3________________ hazard 17:23 44:25 89:6 93:14 gonna h 12:18 13:19 56:6,15 66:1 95:5 101:4 112:21 114:1,1 54:24 56:7 61:9,11,13 hadp hazardous 124:14 126:7,25 129:7 130:8 131:2,12 135:4 136:10 137:4,6 139:10 142:11,11 158:16 63:17 64:5,11 66:16 68:6,9 68:12,1369:16,1770:13,13 70:21 71:5,7,8,10,12,18 72:1 144:10 147:4,6 149:5 10:5 hair 123:4 hairline 133:9 122:11 130:1 hazards 13:11 126:9 head given 37:1541:10,24 71:18,23 96:25 108:8 120:8,14,23 131:17 150:10 160:24 161:1,2 163:21,22,24 good 7:24 40:1 45:5 49:21 82:8 103:3 111:24 112:12 108:19,20 half 76:10,14 89:21 120:19 hand 29:11 118:19 158:8 headed 151:10 heading gives 121:23,25 122:10,14,22 10:5,6 62:22 80:25 111:22 36:6 19:12 128:18 giving 20:17 80:20 glass 126:11 130:20,22 138:2 142:16 154:24 164:5 gosh 139:19 144:10 158:25 handle 7:16 39:20 105:17 114:20 115:8 116:2 158:17 headquarters 136:22 152:7 headquart|3 75:17 135:21,25 government handled health glenn 1:1 glove 117:24 30:4 65:15 121:8 143:7,15 143:16 grade 123:20 114:16 handling 3:14 11:1959:1660:8 65:13 121:17 131:11,13,22 8:21 13:19 16:17 34:13 66:1,3 81:7 90:24 92:4 93:19 116:9 124:22,22 126:9 127:11,11 128:1 gloves graduated 15:15 106:12 117:13,23,25 101:14 118:1 132:22,25 133:5,20 grand go 62:21 9:21 11:7 30:15 36:20 38:6 gratified 150:15 158:14 handrails 118:25 122:13 hands 106:11 119:14,16,18,21 158:21 hear 109:5,8 110:17 163:21 heard 42:3 44:12 82:6 96:24 40:11 41:17 42:8 43:1 45:9 123:5 50:8 57:5 64:1,17 66:6 67:1 gray 68:16 74:7 77:3 80:24 117:18 83:24 88:15 92:2 95:24 great 125:3 133:2,8 handwriting 157:1 handy 105:20 109:7 110:12,13,22 110:23 128:9 130:25 137:6 139:1,2,24 hearing 100:8 102:12 106:7,12 19:14 115:16 81:6 108:8,11 112:8 116:16,21 greater 116:24 119:4 135:3 136:3,5 46:15 136:7 137:25 146:12 147:6 grew 149:5,13,20 150:12 159:5 101:5,6 160:11,14 163:1,3 ground goes 39:15 138:14 happen 19:11 106:18 154:16,22 happened 45:11 111:19 162:12 happening 51:16 hearings 94:7 hearsay 133:13 161:1 heat 25:14 27:8,20 33:2 116:15 128:17 grounds 130:7 133:14 145:23 148:4 25:13 28:15 30:22 56:8 160:9 161:3,4 63:18 going group 1:13,172:9 6:15 10:8,10 41:6 55:14 104:21 130:11 happens 13:24 113:24,25 hard 117:20,22 harm heated 124:5,8 137:16,20 heath 41:22 heating 12:23 16:14 17:10 20:4,7 groups 22:14,15,15 25:3,19 28:14 40:8 121:9 30:21 31:3 35:22 42:8 47:2 growing 51:10 52:17 53:2 59:1 61:4 46:14 75:15 76:24,25 105:12 116:19 142:8 harmed 85:10 25:25 heels 119:12 held 61:6,11 62:15 64:12 76:25 gt> harmful 2:5 38:5 53:12 67:1,23 79:5,10 83:6 84:15 89:20 43:8 91:14 95:8 96:21 100:3,6,8 guess 108:17 110:24 113:12 24:21 111:18 122:23 4:20 harmless 58:9,14,19 60:3 86:18 101:10 115:19,20,22 help 20:2 47:17 68:7,22 98:6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49693 [help - incur] help (cont.) 106:9 112:8 123:15 148:2 151:6 helpful 93:14 helpful|3 93:6 helping 36:7 helps 122:22 hereof 15:21 60:1,18 herewith 60:25 hesitate 20:1 137:3 he|s 124:17 hey 45:9 high 56:1,23 74:9 101:10,11,14 137:16 138:13 155:19 higher 138:11 141:3,4 highest 24:23 highlight 131:22 highly 13:14 27:6 42:25 highb 21:13 highways 112:10 hired 116:5 hiring 111:19 history 19:12 123:24 135:5 hit 113:11 hi|3 80:6 hold 58:9,14,19 60:3 102:1 holiday 49:10 home 47:4 78:25,2,6 84:6,10 homes 129:22 honor 2:3 20:13 25:12 28:14,23 honor (cont.) improve 30:21 31:1 38:3,12 40:9 ibt 51:3 122:3 46:4 52:12 53:9 54:9 56:7 9:24 10:5 42:14,21 43:5,9 inadequate 58:2,2,22 61:4 63:17 66:15 43:24 44:21,22 45:10,19 74:8 67:10 68:6,9 70:6 86:15 46:23 85:23 96:24 139:25 inadvertently 87:24 90:16 98:13 125:25 idea 96:14 144:22 145:22 146:11,22 69:1 142:11,11 155:14 inane 148:22 156:7 162:11 identified 22:16 163:16 27:24 inaudible hono|s identify 1:73:21 8:16 10:25 11:1,10 58:20 142:3 146:2,17 152:19 14:15,23 16:1820:8,18 hope 156:8 22:3 23:7 27:7 29:1 30:22 134:14 ids 30:25 31:1,2 36:5,15 38:2 hose 29:6 40:4 49:5 51:24 52:1 55:12 11:22 ies 56:8,9 59:4 61:9 64:3 65:2 hospital 44:9 68:18 69:24 70:18,20 71:12 101:8 ignition 72:19 74:24 78:17 79:16 hour 21:24 86:21 87:20 88:8,15 89:7 61:15 89:21 115:4 ii 90:18,20 94:4 98:12 107:5 house 102:9 107:7 110:24 118:6 122:9 21:1 ilable 126:4,4 127:15 129:16,19 household 117:10 129:24 130:4 133:16 138:21 illinois 138:18,19 149:6 157:5,13 housekeeping 107:21 110:7 163:15,25 122:10,15,22 123:8 immediate inaudible|3 hth 117:6 125:18 67:16 8:1939:6 121:14 immediately inau|3 huh 3:3 119:22,23 38:14 91:15 impact incentive human 48:23 97:2,11 34:13 48:7,12 69:8 78:11 imperfect incident 78:19,21 82:15,19,24 84:1 135:1 48:15 84:3 124:22 126:11 127:11 imperial incidentally humans 58:13 132:19 60:11 69:12 83:16,20 84:4 implementation include hunt 57:21 9:13 14:7 18:6 22:5 25:1 44:1 45:17 implicate 83:17 84:22 158:24 hunt's 37:9 included 45:15 implicating 11:25 15:4 30:3,12 40:2 hurt 37:4 includes 111:23 114:15 implied 131:19 hydraulic 60:10 including 28:23 29:3,6 imply 7:13 58:14 59:20 60:10 hydrocarbons 27:5 60:16 76:19 69:12 84:4 91:2 123:17 130:14 implying inconsequential hydrogen 77:25 49:1 130:15 important incorrect hydrogenated 25:5 34:4,11 78:14,22,3,13 42:3 113:4 95:18 155:5,10 increase hygiene importantly 25:23 115:2 157:21 158:2,5,11 84:11 increased hygienist impression 83:18 96:2 158:6 81:15 increasing impressions 95:23 68:5,22 incur 5:106:1 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49694 [indemnify - japan] indemnify information (cont.) instructing 58:19 60:3 93:14 96:15 114:18,22,24 112:9 independently 115:7,11 121:6 127:17 instructions 87:25 131:12,15,17,19 158:14,17 12:1 indiana 158:18,25 159:23 160:22 instrument 1:8 152:2 161:16 information 76:22 indicate 74:16 insulated 36:23 91:1 163:10 informed 148:17 indicated 44:17 78:24 insulating 85:11 87:8 103:11 inform |} 150:1 indicates 5:9 46:24 insulator 20:5 info|} 59:13 indications 36:11 insure 32:13 ingestion 24:6 individ|3 56:20 intact 69:14 ingredient 57:10 83:13 individual 137:15 intend 19:11 132:18 159:17,20 ingredients 41:15 160:2,8 163:5 136:3 137:1 intent individuals inhalation 51:13 93:16 142:9 30:2 108:7 159:4,15,25 21:25 56:20 interest individuals |s initial 121:6 132:1 42:7 65:16 interested indus|3 initially 17:7 18:17 22:3 38:20 55:13 42:4 120:13 57:19 70:18 72:11 industrial injuries interior 30:4 96:10 115:2 128:21,25 122:18 40:7 130:5,9,23 157:21 158:4,6 injury interpret industrial!} 83:10,17,19,23 134:1,5 92:20 158:2 inly interpretation industrial} 101:6 8:22 158:10 inn interpr|} industries 49:10 10:14 65:15 136:2 innocuous interrupt industry 114:15 12:3 12:11 34:10 65:7 96:15 inquire interrupted industry's 132:2 70:22 127:9 69:18 insecticide interstate ine 112:23 22:24 95:19 inside in|} inerteen 29:10 35:7 152:4 77:17 78:11,18,24,6,7,8,12 inspection intoxication 78:21 82:14,19,23 83:25 96:16 14:1,9 84:6 145:18 146:4 148:6,14 inspired introduce 148:15 149:22 150:3,4,7 18:1 51:15 152:25 153:3,5,17 154:2 installation introduced 156:8 149:25 50:15,24 infantry installations introduction 102:15 143:11 90:25 93:20 inform installed involve 154:3 155:12 110:19 information institute involved 3:164:11 5:7,12 15:20 65:17 122:2 13:1591:3 108:10 110:13 43:12 44:20 63:8,11 68:4 instructed 117:24 155:13 158:16 68:21 74:8,13,17 78:20 33:10 involves 80:22 81:6 84:22 90:1 102:22 159:15 involving 54:19 89:12 ior 123:13 ipants 69:3 ires 136:7 irginia 161:25 irrelevancy 68:15 irresponsible 33:23 49:8 81:16 irritating 57:6 irritation 13:25 14:8 83:8 125:5 130:24 150:14 isolated 9:17 issue 25:23 70:16 121:5 161:5 163:15 issued 7:1728:9 117:19 144:17 issues 28:1967:13 120:17 italy 143:4 ite 58:12 item 142:12 it* 60:24 91:1 106:6 159:8 i'|} 1:25 it's)} 51:12 itp 156:25 157:8 iven 43:8 iver 130:17 j jacket 117:21 january 16:11 55:4 57:18 58:8 janua|} 57:20 japan 62:4,9,15 102:15 142:25 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49695 [jensen - legislation] jensen kind ko|s landra 41:25 5:12 13:5 22:16 44:20 156:16 89:3 job 49:12 75:4 77:1 78:15,19 kotos ke language 85:20 103:20,23 120:8,10 81:14 90:4 92:22 93:9 1:2,4 2:6 18:16,20 20:1 14:7 15:4,5,6 18:6 19:20 120:11,25 123:2,23 159:15 95:12 105:12 106:12 112:5 24:16 25:17 26:11 28:20,25 68:13 jobs 115:4 122:18 125:16 134:2 31:1,5,14,15 38:7,8,15,17 largest 103:18 104:17 134:4,15,24 136:1 138:20 40:9,13 44:20 46:3,10 150:23 jubilee 138:22,23,24 158:22 160:5 52:18 53:2,5,6 54:9 55:23 lar|3 148:5 kinds 58:4 61:4,9,13 63:22,25 83:21 judge 3:77:23 12:13 115:14 64:3 66:20,23 67:14,17 late 2:6 63:25 70:17 107:1 122:16,17 129:25 131:7 70:9,12,17 78:2,4 85:18 16:1031:7 42:3 64:18 126:24 129:10 134:14 155:24 87:24 88:9 89:23 90:15 85:23 123:16 156:18,24 knew 91:20,24 95:13,15 98:16,18 lately judgment 5:5,13,17,19,24 8:3,23 98:25 100:7,14 103:18 97:5 116:20 117:2,14 27:10 34:25 37:10 38:9 105:5 107:1,11 110:7 latest july 40:17,1741:1843:1847:24 113:13 125:22 126:1,3,7,24 96:20 6:21 20:25 63:14 66:4 48:19 161:4,13 162:14 127:3,14 129:10,14 130:19 lation 87:23 88:23 97:15 163:5,8 133:12,16 134:14 142:10 3:4 june knit 144:12,24 145:1,14,17 laugh 52:11 117:22 146:11,24 147:2,15,19,23 122:24 juries knobs 148:7 156:12,20,24 157:3 layman's 19:13 119:17 157:10,15,18,25 158:3 151:5 juror know 161:1,7 162:11,20 163:14 le 149:9 164:3,5 3:13 4:10 6:4 7:25 9:25 krumar 25:24 jury 11:24 17:7 18:12 19:2,8,25 35:1,2 leached 12:23 21:7 59:1,3 89:21 20:6 23:12 24:20 31:5 krummrich 35:9 95:9,11,18 97:22 102:20 32:10,19,25 34:6 35:19 110:4 lead 111:1 114:1,3 124:9 126:23 36:3 37:8,14,17 43:9 44:3 1 84:12 127:23,24 129:15 134:11 135:4 142:11 144:16 147:4 163:1 justify 49:22 44:18 47:6,12,15,15,18,21 47:22,25 48:3,6,6 61:4 66:1569:3,13,1570:13,17 72:9 74:18 76:13 78:6 label 9:12 10:17 14:5 15:4 18:4 79:1 84:20,25 85:20 159:12 159:16,16,21 160:4,17 leads 14:1,9 130:15 leaks 14:1221:13 jUSt|3 12:17 keep k 80:10 86:3 90:24 95:18 96:19 98:21,23 100:4 104:12 107:6,12 110:6,11 110:14 112:19 114:3,15 labeled 159:18,21 labeling 159:14 learn 121:16 learned 31:6 104:15 127:19 163:15 1:14 25:20 31:4 46:7 50:14 116:2,14 118:6 121:4 122:8 labels learning 51:1461:11 115:16 117:3 123:1 135:23 142:2 155:9,9 kelly 11:10 18:22 20:4 26:21 34:19 35:21 36:11 87:1 kept 124:20 126:11,16 128:11 129:3,10,19 134:23 140:1 146:24 152:5 157:3,4,24 158:3,7 159:12 160:13 161:3,10 162:2,16 knowing 15:2 19:18 78:16,16 85:7 85:12 110:8 131:16 159:9 160:3 laboratory 9:14 44:5 85:25 142:2 lab|3 127:19 leather 78:9,12 leave 81:15 108:8 110:23 116:12 lectric 33:24 44:17 123:2 137:19 key 25:22 163:4 khaki 117:18 6:5 48:10 128:16 knowledge 42:11 47:7,9,10,10 102:23 102:23,24 103:1 107:10 110:2,3,3 127:9 133:14 11:13 lacerations 122:17 lack 50:25 58:12 led 93:1 left 23:5,5 118:23 kill 78:21 84:3 kim 54:3 145:24 160:24 161:4 162:18,22 163:11 known 7:21 27:3 64:18 69:10,11 lacked 47:10 ladies 2:8 148:25 163:20 left|3 100:20 leg 119:8 kimbrough 93:22 133:11,20 150:2 lafayette legal 8:12,12 9:9 10:7,18 53:6 54:3 141:1 knows 22:16 48:8 93:1 101:7 landfill 14:17 35:23 163:18 legislation 38:21,24 39:3 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49696 [legs - manufacturing] legs line (cont.) longer maintenance 2:12 151:12 61:6,12,13 94:20 137:24 96:17 104:18 105:3,6,7,16 length lined look 109:1,13,23 83:1 120:9 117:23 2:17 11:3,8 12:13 13:18 major let's|3 liner 18:13 27:1 36:20 52:13 26:1 64:14 72:7 156:25 3:12 135:21,24 54:22 63:22 69:23 77:21 majority letter lines 89:2 90:18 106:10 108:15 76:18 140:4 152:15 18:12 20:9 26:5,16,23 27:4 133:9 151:10 115:13 123:23 138:4,7 makeup 27:17 28:1 29:2 34:18,24 liquid 144:11 145:13 146:16 30:12 36:9 39:6,7 52:7,24 54:2,4 3:8 84:13 124:16 129:22 147:9 152:18 153:11,14 making 64:6,8,12 72:13 77:4,9,15 136:4 138:15 148:9 looked 1:1331:2351:6 81:12 79:10 80:15,17,19,23 86:5 liquids 30:2 40:16 43:24 44:4 45:5 84:16 94:7 95:6,7,24 103:3 86:7 87:19,23 88:18 89:3,9 85:10 95:1 150:15 45:10,19 105:19 108:17 107:23 111:12 127:18 89:10,17 96:6 132:5 list looking 129:12 137:22 148:16 letterhead 22:9 37:22,23,25 66:2 69:9 11:20 55:8 57:19 91:24 153:22 59:7 62:6 77:11,1590:5 134:24 making^ let|3 listed looks 153:8 52:14 69:4,14 155:24 45:5 137:19 138:14 man level listen loss 32:16 50:24 77:19 100:23 74:21 125:15 151:11 7:6 164:1 14:1,10 107:2 125:23 126:11 levels 57:7 66:2 83:13 lit* 131:10 losses 60:6 management 78:24 levinskas little lost manager 44:1 45:8,12 52:9 87:14 2:128:11 72:18 118:23 65:9 3:23 7:13 30:11 69:2 77:18 88:18 89:4 97:14 119:3 135:4 136:11 139:10 lot 80:5,14 88:22 89:4 111:2 liabilities 140:3 16:14 88:10 103:18 117:25 111:16 120:10 132:7,17 60:5 live 119:10 136:2,6 138:17 134:1 liability 50:15 100:16 156:25 159:23 163:5,8 managers 15:23 lived louis 7:13,21 liberate 100:18 67:22 100:16,18,22 101:6 mandelkorn 21:13 liver 101:17 110:3,9,18,5 112:16 162:2,3 life 5:106:1 19:12 83:10,17,18 136:15,18,25 159:2 manhattan 32:13,14 33:8 84:11 83:19,23 106:23,24 109:8 lower 38:19 lift 109:11 110:5,8,14,17 124:6 138:6 140:8 141:2 manual 160:1 127:25,25 128:16,18,18,22 It 17:2 light 132:11 49:9 manuals 22:4 33:6 lightheadedness living 47:20 76:17 It* 34:21 130:17 12:1 96:4 manufacture 22:5 load lunch 7:8 11:1621:4,1633:9,15 lik|3 120:15 160:8 61:14,15 34:1 39:4 62:24 96:1 104:6 112:3 local lye 119:25 120:4 135:15 limit 14:17 15:13,14 56:16 57:3 114:9,11,13 manufactured 19:9 57:8 83:12 98:1 limitation 60:10 limited 31:4 32:12 36:24 37:2 49:22 limiting 51:3 limits 47:15 59:17 lindbergh 136:23 line 31:23 60:25 61:1 98:5 112:2,3,3 m located 62:9 136:12 locations 32:12 91:2 155:13 lone 103:25 mac 1914 machinery 62:11 mail 87-11 long 6:2,3,3 36:15 50:18 51:12 70:19 78:12,9 82:16 90:19 90:21 100:18 103:8 116:13 mailed 26:16 main 1911 longed 83:13 maintaining 25:24 23:5 37:11 49:19 62:12 65:6 112:18,21 138:5 143:3 150:19 153:3,4 manufacturer 38:10 64:14 142:18 manufacturers 39:10 40:4 65:16 73:13 142:22 143:24 manufactures 59:10 manufacturing 7:14 11:4,25 17:2 25:4 38:25 41:8 55:1,14 94:20 110:14 146:5,7,21 148:14 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49697 [manufacturing - monsanto] manufacturing (cont.) mean (cont.) mere mislead 158:21 145:14 155:6 76:21 81:24 march meaningful message misled 26:16 27:3 34:24 62:2 58:9 80:7 81:13 85:7 105:21 95:9 marine means met misrepresentation 60:11 13:4 55:25,25 56:1,1,25 25:4 39:20 154:11 27:10 mark 125:14 141:8,9 155:7 157:3 meter missouri 92:6 121:10 meant 57:9 103:6 marked 76:21 methods misunderstand 56:21 medical 42:12 81:7 126:24 127:4 market 16:14,16 20:5 79:10 87:1 microscopes misunderstanding 95:23 93:9 106:13 107:2,5 108:7 10:15 88:13 marketing 108:18,24 116:7 126:8,9,18 middle misunderstandings 3:24 25:3 80:13 91:11 93:3 127:18 128:15 132:4 98:6 144:3 80:23 82:12 married 134:15,16 157:21,25 milder misuse 100:25 medicinal 117:20 105:14 martha 138:22 military misused 63:6 medicine 101:22 143:10 8:1 27:9 129:22,24 130:1 mask 85:15 milk mitsubishi 13:4 medium 35:12,15 47:23 62:6 match 150:2 milligram mixed 160:12 meet 57:9 150:10 material 23:25 96:2 116:6,7,7 133:7 million mixture 11:3,8,10,16,19 12:4,5 154:7,17 57:10 76:7 35:3 114:11 138:1 14:15 15:19 21:20 30:24 meeting mind mixtures 47:20 56:14 113:19 115:6 57:20 66:25 67:3,18,25 3:3 50:14 51:13 58:2 117:3 8:18 91:1 93:20 115:10,11,13 119:9,10 68:3,20,21 69:5 71:4,16 129:25 138:24 159:6 modification 128:5 131:23 132:23 142:3 86:11 105:20,25 115:24 minds 60:21 155:7,11 159:22 160:6,10 116:1 141:24 modify 160:14 meetings mineral 60:18 68:25 materials 105:23 106:2 115:18,19,22 138:7 molten 33:24 46:16,20 51:1,4,4 116:3 162:5 minimize 137:20 55:22,23 98:3 113:2,21 melting 73:15 moment 114:16 122:11 129:21 21:22 min|3 86:17 137:10 143:14 136:4 159:18 member 32:4 money mathematics 73:11 minute 98:19,23 112:6 102:23 members 2:10,12 18:13 27:1 46:6 monsanto matter 25:1 69:22 99:1 114:18 120:3 1:7,123:254:176:5,11 19:24 67:11 89:20 membership 121:21 149:1 7:178:189:1 11:4,15,22 matters 41:4 minutes 12:5 14:21 15:18,21 17:4,5 25:5 124:21 163:23 memo 24:18 30:16 36:21,23 38:7 18:5 19:3 20:5,20,23 21:1 maximum 3:7 28:8,15,15 29:7 30:8 46:8 61:11 83:7 89:23 22:18 23:19,20,23 24:18,24 70:4,24 75:19 33:2 61:25 62:11,20 79:16 149:6,7,7 24:25 25:3 26:5,16,17 28:9 mcc 79:20 80:4,9,15 91:8 minute 30:13,20 33:22 34:7 37:4,9 19:3 memorandum 46:6 38:9,10 40:2,17 41:22 mcclain 1:24 2:18,20,23 3:15,16,18 mischaracterization 42:10 44:1,3 47:7 48:24 161:14 4:6,13 5:18 67:5,15 69:14 38:13 49:1,4,5 51:2,7,13 52:9 mcgraw men mischaracterizes 53:7 54:18,25 55:13 58:18 34:10 40:3 58:12 6:8 20:8 77:24 58:21 59:7,9,9,14,18,23 mckinley mention mischaracterizing 60:1,3,14 61:1 62:6,24 101:11,14 94:9 124:8 130:2,7 131:16 10:9 38:14 44:13 64:13,22,25 65:4,6 69:20 mean 135:6 151:19 mishandled 70:2,22 71:8 72:6,13 74:14 9:21,25 18:8 20:3 22:2 mentioned 27:8 76:10 77:10 80:2 84:7,17 31:12,21 51:11 75:8 76:20 16:1 32:25 94:5 103:15 mishandling 86:24 87:1,12 88:25 89:3 76:24 87:8 93:8 107:7 130:4,7 131:10 105:13 89:12 90:1 91:8 93:3,18 117:5 125:13,19 141:12,15 94:25 96:6,16 97:3,22 98:4 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49698 [monsanto - observed] monsanto (cont.) muncie nevertheless (cont.) 98:19 103:12,14 110:8 152:2 85:7 111:8,9 112:11,13 119:25 muriatic new 120:3 121:7 123:6,17 124:3 112:22 114:4,5,10 11:1329:3 38:1985:19 124:21 128:12 131:11,12 music 115:25 141:25 150:1 132:2 133:15 135:6,13 112:4 158:25 136:11 142:4,12,17,20 mutually newspapers 143:6,22 144:7 150:23 68:23 36:25 151:13 153:3,7,21 154:1,3 n newspp 154:10,21 158:10,13,16,24 159:3,5,12,14 160:17,19,22 160:25 monsanto's nagging 86:13 name 34:25 45:15 87:16,17 95:4 37:3 ng 113:12 night 11:25 19:7 33:24 42:24 64:9 67:22 74:19,25 98:3 123:24 131:18 135:4 136:22 139:4 144:1 monsap 60:16 month 14:5 25:5 28:8 105:25 115:22 months 136:14 139:4 150:5 names 139:5 national 100:13 nine 100:24 101:9 niran 39:9 65:16,17 native 100:20 natural 75:5 nausea 73:12 148:16 112:24 noncombustible 150:10 nonexplosive 150:9 nonflammable 43:21 116:1 125:19 morning 163:24 mop 14:1,9 nd 139:10 near 148:9 150:1,8 nontypical 74:9 normal 96:1 motion 66:18 motor 129:20 motors 151:9 mounted 42:10 move 77:2 80:6 101:7 110:5 136:12 155:3 nearly 64:18 necessarily 23:13 76:24 necessary 83:2 94:20 103:2 106:8 111:20 150:16 163:1 need 117:16,18 normally 87:13 noted 147:1 notes 25:7,8 157:1 159:5 noteworthy 98:10 noth 20:12 72:18 85:5 146:22 moved 159:19 movement 102:25 movements 17:23 18:12 20:1 47:17 65:13 74:18 78:20 106:3,6 116:13 137:8,23 needed 151:8 needlessly 19:13 87:13 135:25 noticed 133:2 notified 58:7 160:1 november 22:5 moving 24:11 25:20 mphlet 146:3 mployees 107:24 mr.p 133:21 mrp 81:9,25 neighbor 111:25 112:12 neighborhood 112:1 122:22 nema 39:9,16 neoprene 118:1 network 32:4 42:6 43:8,14 103:16 nsanto 96:1 nstruction 60:24 nt 139:19 n't 126:3 nth 20:17 mp 93:15 146:19,20 149:22 nevertheless 10:16 11:15 17:1933:14 36:1 nto 60:1691:1 nts 155:24 number 21:10 31:20 40:20,23 49:3 76:8 83:24 89:6 139:6 142:2 148:13 numbers 159:24 nutra 135:17 nversations 162:8 nylon 135:16__________________ 6 6 69:25 78:25 95:25 96:25 97:25 98:25 99:25 100:25 101:25 102:25 103:25 104:25 105:25 106:25 107:25 108:25 109:25 110:25,25 111:25 112:25 113:25 114:25 115:25 116:25 117:25 118:25 119:25 o oath 72:16,25 object 10:8 20:7,17 25:12 28:14 29:9 30:21 38:12 52:12,14 56:7 63:17 67:10 68:6,9 77:23 79:5 95:8 107:4,4 157:4 161:2 objected 48:21 146:24 objection 25:20 53:9 63:18 68:12 70:9,15 74:19,21 90:17 107:11 126:2 127:15,16,20 129:17 133:12 134:14 144:12 145:1,17 146:25 156:12 157:18 162:21 163:14,15 objections 74:20 156:11 obligation 60:16 obnoxious 111:25 observations 97:24 observed 134:7,9 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49699 [observing - papageorge] observing okay organized 7:22 163:7 75:20 85:22 92:1,2 100:10 158:7 obsolete 146:13 148:21 149:6,9,11 original 96:15,20 150:12,18 152:1 157:7 57:25 58:5 80:15 obvious 159:7 161:19 163:14 ork 52:15,21 old 116:19 occasionally 46:16 100:23 101:8 osha 154:23 older 11:13 16:5 occasions 141:25 osity 91:2 olive 141:20 occupation 136:23 of) 102:15 olliges 61:25 68:12 119:19 129:8 occur 29:14 75:22 99:6 ought 7:4 8:4,6 21:13 67:18 ommittee 151:20 133:23 40:18 ouldn't occurred once 118:9 7:5 15:3 6:19 106:16 115:22 118:8 outer o'clock 138:9 47:15 48:10 61:15,18 ones outlaw October 136:14 138:11,13 62:15 52:1 53:6 54:3 89:25 95:4 onf> outline odor 90:8 71:22 138:21,23 opened outside offer 144:6,8 49:11 135:20 87:24 144:12,22 156:9 opening outstanding offering 119:7 123:7 148:11 156:20 operating outward office 12:1 138:24 108:25 67:22 74:17 104:3,4,4 operator overall 108:10 118:5 119:24 133:6 132:19,21 43:20 160:12 operators overcrowding officer 12:2 101:10 25:1 opinion overexposed officers 50:1 51:1766:6,11 13:25 37:6 60:4 opportunities overexposure offices 26:1 119:13 158:23 159:2,4 83:23 67:23 96:14 opportunity overlook officials 80:20 120:24 49:23 24:24 opposed overnight Off) 9:24 10:1 120:17 50:17,17 19:24 54:20 oral overrule oh 152:23 70:15 127:20 129:17 2:8 7:12 8:3 23:9 24:5 order overruled 31:14 37:1 101:21 103:9 1:127:1753:1060:23 29:13 31:4 44:15 90:22 112:15 114:8 117:14 142:1 133:18 145:25 146:25 118:20 125:21 139:19 orderly overf) 152:14 157:2,25 158:3 1:14 159:24 159:11 163:12 164:4 organic overtones Ohio 31:1957:10 134:16 152:5 organisms overwhelming oil 76:17 140:4 3:8 106:9 119:8 129:20 organization ow 138:7,7,11 148:10,17 150:8 11:13 36:1 155:17 organizations owned oils 112:8 111:9 151:17 131:4,7 144:20 P fil Ifi nar ifir 102:10 pacitors 15019 package 111:23 poyc 11:5,6,7,7,8 16:1,11,13,18 16:19,24 17:1,10,22 18:11 18:15,1920:12,20 21:3,8 21:1422:8 24:11,1325:7 26:4,11,1327:17,1828:9 31:13,15 32:5 33:2,4 34:17 36:21 38:8 39:6 40:14 41:21 42:9,16,23 45:1 46:10,14 47:2 48:14 49:21 50:13,21 51:17 54:2,22 55:6,9,12,17 57:5,16 58:25 61:3,22 62:21 63:3 64:13 65:5,9,10,12,24 66:8,24 68:1 69:4,24,25 70:21 71:5 71:23 72:12,19 73:11,19 76:1,15 77:3 79:9 85:21 86:6,22 87:22 88:3,4,16 89:6,19 90:14 91:6,17,21 91:24 93:13 94:2 96:6 97:6 97:6,7 98:6 147:11,13 14920 11:1 30:17 54:22,25 59:2 66:25 90:8 pain 14:2,10 125:3 126:25 paint ' 35:6 36:18 131:3,5 painted 356 11617 159:25,25 160:4 1151 14619 13520 106:5 116:13 1032 1198 papageorge 1:1,2,3,5 3:22 18:17 22:14 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMON0049700 [papageorge - phasing] papageorge (cont.) pass pcbs (cont.) perce|3 27:9 38:9 45:18 58:25 79:3 108:8,11 77:10 80:14 85:17 86:12 139:19 79:9 84:15 87:3 93:15 94:2 patent 95:3,6,7,9,22 98:20 104:6,9 perchloroethylene 95:3 100:4 110:10 146:16 142:20 148:12 104:12 105:17 106:2,10,18 131:6 147:25 152:24 157:20 patents 106:21 107:10 109:3,6,9,14 perfect 160:21 161:10 144:17,23 145:5 109:15,20 110:11,19,2 7:17,17,19 155:3 papageorge's path 111:6,12 112:19 113:9,10 perfectly 40:10 146:3 114:19,20 115:2,8 116:2,11 126:19 pape pathologists 117:25 118:4,13 119:2,13 perform 53:13 75:22 140:11 164:7 10:14 120:12,17,18,20 121:9 69:16,17 144:20 paper pathologist^ 123:25 124:1,5,8,9,17,23 perfumes 12:5 114:23 119:19 137:11 10:22 127:10,12 128:2,8,14,20,22 138:22 papers paul 131:12,13 132:13 137:5 period 160:11 3:19,20 69:25,23 96:23,25 138:4,17 139:4,7,16,17,21 42:9 78:12,9 82:16 83:1 paragraph 97:21 98:19 140:5,9 142:11,12,15,18,20 104:13 120:16,20 123:18 18:18,21 25:9,13 28:20,22 pay 142:22 143:3,15,21 144:1,7 124:1,5 162:14 41:22 42:9 45:1 46:13 19:1398:19 145:5,9,22,23 151:13,16,20 periodic 48:14 56:5 57:19,24 147:10 pcb 152:1,4,10,15,22 153:8,22 44:21 paragraphs 8:189:11,19 10:13 12:20 154:6,10,14,24 156:2 periods 53:1 22:22 23:4,10 25:15,16 157:22 158:14,17 159:13 126:4 parameters 27:22,25 28:2,5 30:2 31:6,8 160:17,22,24 162:19 163:8 perjury 48:10 34:25 35:9 37:7,21 47:8,22 163:11 73:2 parathion 48:17 56:12 57:21 58:6,18 pcbs|s permanent 112:24 62:12,21 64:17,19 65:5 141:1 78:11,12 82:15,16,19,24 pardon 66:13 68:25 70:3,23 74:7 pcb|s 85:10 43:11 57:9 76:18,24 78:17 85:10 90:25 1:7 permissible park 93:20 94:19 95:21 96:4 pebble 115:3 101:7 106:25 108:1 109:25 100:17 permits parking 110:19,4,10,18 113:19 penalties 106:7 119:10 117:11,17 118:15 119:20 60:6 persist part 121:5 124:21 125:10 128:5 penalty 59:15 12:17 15:12 17:2 33:24 132:8,16 134:2,8,12 138:2 73:2 persistence 41:8,9 63:20 98:8 139:11 141:11 142:7 143:6 pencil 26:25 31:6 participant 144:20 145:9 150:23 119:19 person 69:15 154:16 160:16 163:5 penetrates 13:18 22:2 80:5 158:9,10 participate pcbs 78:12 158:22,22 112:2 1:7,13,20 3:14,24 4:2,14,15 Pennsylvania personal participating 5:14,14,20 6:6,10 7:8 8:16 146:8,21 151:22 152:9 51:17 162:22 68:7,22 9:3 11:17 13:22 14:7,14 161:23 personally participation 17:3,4,23 19:25 21:5,17 pentasulfide 4:12 40:16 71:21 80:7,8,19 112:6 22:12,19 23:2,7 25:9 26:8 113:1 115:9 161:13 partied 26:17,24 27:8,11 28:3,24 people persons 69:3 30:12,20 31:1,24 32:2,8 7:13,14,15 22:7 27:14 28:2 69:8 particular 34:8,15 35:4,12,17 36:24 29:4,7,8 30:3,4,4,6 35:6,15 persuade 10:13 34:21 35:3,10 36:14 37:2,11 38:11,20,21,25 35:17,22 41:8 42:19 43:23 72:7 36:17 37:9 43:10 63:20 39:14,20,22 40:17 41:19,22 51:20 75:2,7,8 81:6,9,17 persuading 92:3 94:12 131:23 160:8 42:11 46:21 47:16 48:24 84:7,21 104:25 105:6,16 68:24 particularly 49:14,17,19 50:15,22,24 109:2,14,23 122:25 123:16 pesticides 98:9 118:4 51:6,18,20 52:4,25 53:8 155:14 158:20,21,21,21 27:23 parties 54:5,11 55:6,11 56:14 159:2,3 160:13 161:10,13 peter 91:3 57:14 59:10,12,14,17,20,23 162:4,5,6 151:12 parts 59:25 60:8,13,13,17 62:4 percent phase 54:25 57:10 75:13,18 62:15,25 64:23 65:14,25 58:11 120:22 139:20 140:5 36:13 party 69:19 70:18 71:1 72:1,8 141:8,13 phasing 60:21 73:7,9,14,15,16,20,24 74:1 percentage 95:4 74:3,20,24 75:2 76:2,10 139:16 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49701 [phil - procedures] phil plants pools presence 96:25 1:94:18 112:14,16 121:19 137:15 3:4,5,6,8 21:21 76:18,19 phosphorous 128:16 132:2 136:11 poor 155:8,14 112:25,25 151:17,20,20,24,25 154:4 88:20 present physical 159:5 popular 29:2 60:3 71:1,21 94:13 102:24 154:5 plants 93:22 presentation pick 110:15 population 69:18 71:5 40:10 119:4,9,13 138:12 plastic 48:7 presenting 160:1,6 117:23 135:21 portions 80:22 148:6 picked plasticizer 20:22 108:22 preservative 119:18 84:10 136:6 pose 130:8 picking plastics 65:25 president 160:3 135:18 136:5 position 31:17 71:11 86:2 94:6 piece played 4:10 19:7 25:24 28:1 34:7,9 presidents 12:5 117:18 119:10,19 97:25 39:23 64:9 66:3 74:25 80:6 25:2 126:11 players 121:2 125:22 press pioneer 72:7 possession 37:1,4 93:22 163:7 please 59:16 60:8 pressure pittsburg 12:3 16:1 18:11,11 21:14 possibility 21:13 137:17 152:9 162:1 30:15 34:17 38:4 46:8 52:5 73:15 pretty place 61:21 67:1 77:3 126:1 possible 114:9,10 115:5 125:18 14:16 22:22 40:10 46:3 pleased 13:2 33:7 78:14 148:16 prevailing 77:1 105:17 122:25 123:12 9:1,2,5 potassium 51:18 placed pleasure 112:25 prevent 48:16 148:5 potential 155:15 places ple|3 41:23 83:15 84:4 prevented 155:19 80:23 pots 10:21 plaintiffs 130:25 Pit* 78:8 103:2 119:5 pound price 95:21 96:2 plaintiffs plus 96:1 primarily 96:22 100:7 85:8 pounds 121:18 131:19 158:11 plan point 141:11,11,13,14,16,22 principal 33:8 12:20 21:23,23 29:5 37:10 power 43:20 121:18 planet 37:1747:7,1466:13 118:7 143:17 151:9 printing 76:11 121:12 123:8 127:25 practical 43:15 plant 129:13 133:7 138:15 80:24 prior 1:6,6,8,11,12,13,14,17,21 148:23 163:18 practically 11:17 12:5 43:18 144:7 1:23 2:25 3:2,11,14,174:7 poin|3 73:20 private 4:21 5:4,21 6:1,6,9,16,22 21:22 practices 30:3 102:3 6:24,25 7:6,13 8:7 17:17,20 points 3:10 7:24 probably 23:5,5,15,16,20 31:9 77:24 62:20 precaution 10:24 76:7 108:18 123:20 80:6 82:2 103:20 104:2,6 policies 12:25 148:4,22 104:19 105:24 106:20,22 59:19 precautions problem 106:24 107:10,22 108:8,24 policy 7:20 15:9 131:12 28:5 30:3 33:21 37:21 47:8 109:2,6,9,14 110:2,3,4,4,7 112:12,13 preceding 49:25 50:1 78:8 83:10 110:11,14,17,18,2,5,12,15 pollute 83:23 87:11 133:23 147:16 110:18 111:2,8,10,16,16 112:2 precisely 156:13,13,24 162:20 112:2,7,19 114:17 115:8 polluted 19:9 problems 116:3,7 118:3,7,11,14 35:12,17 precluded 31:7 35:23 53:7 54:20 121:15,16,18,22 122:12,21 pollution 98:3 81:20 83:5 110:10 112:11 123:7 132:7,17,17 134:1 29:4,7 30:6 47:22 prefer 123:25 124:18,22 127:11 136:17,18,25 139:8 143:22 polychlorinated 43:3 128:1 132:15 141:2 144:5,6,8 150:20,22 151:14 27:6 42:25 59:9,10 76:17 premature procedure 152:2,5,11,16 153:9,23 82:18,23 83:16 84:8,16 66:14 12:1 159:14 154:13,19 161:17,23,25 98:2 prepared procedures 69:4 71:21 95:5 12:25 73:14 121:14,17 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49702 [procedures - rash] procedures (cont.) prolonged pull question 154:9 160:15 83:11 147:7 3:1 7:5 11:9 20:11,1521:4 proceed prominent purchase 24:22 27:24 28:3 47:14 2:16 20:10,19 26:12 38:7 97:25 122:19 59:11,12 60:7,23 143:25 50:9,23 62:17 66:21 68:16 53:3 56:11 61:21 78:5 79:8 promulgation purchased 78:10,15,17,22,3,13 82:14 90:21 99:5 100:1 161:9 97:25 26:17 64:24 83:24 84:5,6 85:2 86:19 proceedings proper purchasers 90:20,21,23 91:4,16,18,25 61:20 149:4 7:23 39:20 65:13 80:21 59:8 92:4,5,6,7,9,10,11,18,19,24 process 85:20 111:21 160:14 purchasing 92:25 93:10,13,18 95:12,20 17:2 43:1555:1,14 properly 152:20 120:1 121:9,11,13,20 produce 111:23 121:11 pure 125:24 126:15 132:3 137:3 48:9 properties 138:11 questioning produced 59:13 102:24 113:14 purporting 53:4 27:22 76:10 150:1 131:21 153:5 154:6 155:4 60:18 questions producer property purpose 1:4 22:1524:11 47:351:15 51:2 142:17 155:13 67:25 68:3,16,20,21 153:25 54:24 77:11,12,18,21 78:7 producers proportion pursuant 78:10,15,19 79:4,12 82:3 121:8 150:11 53:3 84:18 86:13 90:5,8,11 producing proposed push 91:13 93:4 98:16,25 100:3 8:16,19 18:2 95:22 66:1 68:25 73:19 98:2 122:10 100:8,13 103:19 131:25 product protect pustules 164:2 13:16 23:10,19,23 24:7 115:14 83:22 questions |s 34:25 49:4 114:14 131:20 protection put 77:16 135:10 141:25 142:1,4,15 13:1 63:12 156:6,6 49:8 71:12 94:16 103:1 questi|3 142:16 154:3,24 158:19 protective 104:5 110:8 115:1 116:24 74:25 product 15:1578:11 117:9 132:21 141:10 159:9,13,19 quicker 137:1 pro|3 159:25 148:4 production 83:13 pufj quickly 30:20 31:9 34:8 37:15 protocol 118:1 64:9 116:21 38:25 59:20 64:22 76:6 44:10,1845:11,20 putting quit products proud 29:3 114:6 49:5 22:22 23:4,10 30:12 31:23 123:13 pydraul quite 32:15 33:11 37:5,5,7 49:8 proven 29:3 5:5 37:24 76:13 78:6 85:1 55:13 59:10,18 64:14 95:1 pydrauls 123:19 134:23 112:18,20 113:3 120:14 provide 28:23,24_________________ quotas 142:13 143:6 151:14 26:1 48:18 90:12 q 25:24 professional provided q.|3 quote 44:5 103:5 professors 42:12 58:17 provisions 30:19 85:21 100:2 15:19 25:22 29:2 62:21 65:24 93:18 94:18_________ 41:24 profitability 25:25 48:24,25 profitable 60:15 pr|3 123:13 p|3 qt> 81:16 qualification 125:23 qualifications r railroad 152:12 154:14 rails 142:12 profits 34:11 142:10 program 33:10 36:1,13 42:10 54:19 57:21 108:7 116:25 120:13 progress 43:22 progressing 102:14 project 31:22 19:4 27:21 74:7 public 16:1766:3 137:14 155:19 publication 96:19 publications 36:25 37:3 publicity 35:23 36:23 37:2 published 9:8 17:14 20:24 43:7 70:25 76:16 146:4,20 126:2,8 qualified 126:5,17 quality 63:8,10 103:3 quarter 2:14 149:8 queeny 103:20 104:6,19 105:24 106:19,22,24 107:10 109:2 109:5,9,14 121:15 136:17 ques|3 119:15 raise 81:2 95:21 96:2 raised 47:3 108:22 raises 27:23 raising 28:3 ranks 102:1 rash 125:1 132:16 134:4,8,12,22 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49703 [rating - repetitious] rating reason redden related (cont.) 55:19 56:6,15 57:3 60:12 67:14 122:7,14 131:5 122:18 134:2 140:6 rationale 150:15 156:5 reddening relates 70:3,23 reasonable 125:1 131:8 132:16 134:22 63:20 rats 74:23 75:1,10 87:9 redness relationship 141:2 reasons 127:1 130:24 134:25 39:21 rattle 122:9 red|s relaying 130:11 recall 134:24 3:16 raw 1:2 7:19 49:3 89:16 96:18 refer release 43:24 44:4,8,18 45:5,10,19 105:8,10,11 106:1 113:17 1:134:13 11:1 27:2 46:20 107:23 151:8 113:19,21 132:18 135:10 161:14 50:7 54:25 144:19 145:12 relevance rcially recalling reference 30:22 63:18 148:14 100:10 55:10 relevancy rd receipt referred 25:13 28:15 56:8 90:17 41:22 58:8 59:20 60:7 29:7 34:19 130:13 relevant rding receive referring 28:18,20 64:9 77:7 86:7 92:14 159:22 12:5 16:21 19:4 29:8 30:1,5 reliable reach received 46:21 60:20 96:18 97:2 136:8 23:11,11 3:17 4:6 41:24 79:10 87:6 refers reliance reached 87:19 88:12 92:16 153:6 31:22 15:23 9:2,23,24 10:2 33:3 154:10 reflected relied reaching receiving 28:3 145:7 105:18 115:10 10:21 78:25 44:21,22,23 refresh rely reactions recess 2:23 20:4 105:15 115:6,9 117:8 92:9 2:15 46:9 61:19 99:4 149:3 refreshes relying reactors recipient 1:25 43:5 46:16 117:1 119:6 52:10 regard remain read reckless 28:16 85:17 106:2 120:12 18:3 86:13 94:19 12:17,23,24 13:12 14:18 48:11 162:19 remarks 15:6,24 16:15 17:8,10,13 reclaim regarding 41:1346:11 71:1 94:13 17:15,16,19 18:7,21 19:14 29:3 38:21 43:12 51:18 77:1,16 remember 21:7,1926:1 31:1243:3 recognize 81:6 39:5,15 70:20 103:9 119:9 46:18 50:5,6,7 54:15 55:16 97:9,10,14 114:4 rega|3 119:12 120:2 121:20 57:25 59:1,2 64:5,11 66:16 recognizing 64:9 129:17 152:6 161:23 67:4 69:25 70:21 71:21 65:12,13 registered remind 74:2 77:11,14 78:5 79:20 recollection 103:5 138:20 82:2 83:6 84:22,23 86:9 2:1 registration reminded 90:18 91:14 92:21 97:22,23 recollections 103:8 3:7 98:7,12,14,15 114:25 147:5 2:24 regular renate 147:9,15,15,17,19,19,25 recommend 105:23 8:11,12 9:9 10:7 53:6 54:3 148:3,4,12 149:22,23 31:18 regulate 141:1 reading recommendations 69:19 73:9 renowned 68:3 83:15 149:23 15:20 regulated 9:19,20 reads recommended 73:24 repair 69:14 22:1 73:14 regulate |s 128:17 ready reconstruct 72:8 repeat 123:9 41:18 regulating 16:3 37:1 103:19 real record 52:4 repeated 49:25 78:19 84:4 121:12 22:17 38:13,14 40:20 88:7 regulation 4:23 57:12 83:11,13 137:7 138:11 88:8 90:16 94:16 74:20 repeatedly really records regulations 17:25 29:4 47:6 84:1 88:20 41:17 123:1 7:17 14:17 95:5 98:1,2 repeated|3 116:13,25 red relate 5:19 reaped 106:11 109:18 127:22 162:24 repetitious 34:11 133:3,8 related 100:12 89:11 106:15 109:24 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49704 [rephrase - sales] rephrase 38:15,16 86:19 95:20 126:15 replace 142:5 replaced 29:14 53:13 75:22 87:1 99:6 140:11 164:7 report 33:11 40:16 42:7 57:20 64:6,7 106:13 reported 32:9 44:7 93:21 133:3 reporter 3:5,21 63:9 132:20 137:10 137:11 146:6 149:14 161:21 reporting 4:5 26:23 reports 43:21 44:24 54:6,9,10 76:16 85:9 representative 158:24 representatives 38:1 65:14 69:12,16 80:21 93:22 144:18 represented 72:10 representing 134:17 represents 58:11 reproduction 32:14 88:20 reputation 112:11 request 31:19 90:4 require 156:2,4 required 59:15 131:22 154:6 requirements 11:14 requireme|3 155:24 requiring 11:15 research 30:11,12 148:10 149:25 158:21 162:1,3 residence 100:15 resistance 155:5 resistant ried rst 59:13 155:6,10 82:1 103:23 resistent right rubber 49:6 2:4 3:13 5:23 15:11 16:6 15:15 117:12,13 136:7 respect 21:1022:1223:1,4 24:12 rules 15:22 24:19 26:24 59:19,22 26:15 33:22 36:2 38:16 7:17 59:25 69:18 91:16 39:1 40:21,2541:10,11,21 ruling respirator 43:2 44:2 46:5 49:20 50:8 53:3 54:12 67:12 68:10 116:22,24 51:5 53:4 55:23 56:19 58:4 70:11,15 respirators 61:10 62:13,22 67:7,9 rulings 117:12 68:14 69:1 71:8 72:12 70:20 respiratory 79:12 86:24 88:5 89:2,14 run 13:1,7 57:6 83:8 90:9 91:14,20,21 93:15,24 116:14 119:22 124:24 respond 94:11 95:6 98:17 106:6,12 151:9 132:4 110:8 113:13 114:11 rural response 123:22 124:9 125:6 127:3 143:12 35:25 36:9 39:14 92:16 133:2 139:23 147:5 150:5 rush 152:23 157:14 159:3 160:4,10,14 106:6 responsibility 163:20 164:3 rushing 107:22 right.b 61:7 responsible 41:13 russell 25:2 81:8,11,14 104:22 righ|3 101:12 111:18 120:14 151:11 russia rest rightly 143:5 34:11 61:7 100:21 restate 62:20 rights ry 57:20 86:20 48:12 ryan restrictions ring 38:17,1848:15 148:18 84:11 ryan's restrictive rise 37:1,4____________________ 59:19 result 5:21,21 14:8 122:16 resulted 90:25 resulting 93:19 155:15 results 9:2,23,24 43:13,19,20 resu|s 49:9 re|s 27:3 retired 103:11 return 61:16 132:5 review 124:3 164:1 reviewed 73:1380:18 115:18 richard 29:8,11 30:1,9 rics 96:11 155:19 rity 52:4 river 136:20 rmed 36:11 roads 112:10 role 71:18 72:4 97:25 room 7:12 116:14 119:22 124:11 124:14 137:18 138:24 roposed 74:7 rotten 138:25 rough 135:1 162:12 roughly 45:7,11 110:16,25 roush 86:24 row 132:24 147:6 s saccharin 135:11 safe 11:19 121:14,17 123:2 131:11,13,22 158:14 safely 103:3 105:17 111:23 116:2 158:17 safety 11:3,8,11,15,16,25 12:4,5 15:19 51:14 105:20,23 106:2 115:18,19,22 116:1,6 116:9 117:19 122:18 135:21 156:6 sager 63:6 64:8 saginaw 40:3 sale 59:20 60:1,8,13 sales 4:2 25:23 36:18 37:15 47:11 48:24 58:7,11 59:23 60:23 76:2 158:24 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49705 [salt - sincerely] salt screening September (cont.) shoe 114:12,14 138:14 46:17 54:19 62:16 96:4,8 78:10 sample se series shoes 76:23 132:22 125:9 22:15 24:10 3:9 4:15 5:14 78:6,8,9 84:7 sand second serious 84:9,11,12 117:19 119:2,9 119:3,4 122:13 39:2 41:22 48:14 136:16 18:2 30:2 35:23 78:8 83:23 short santo secondary 106:17 2:10 125:14,16 137:24 14:5 146:20 serve 149:1 161:2 satisfactory secretary 46:17 121:10 shorten 86:12 95:1 79:22 served 84:11 130:12 satisfy section 73:12 shortly 29:4 12:16 13:18 14:12 15:6,9 services 17:14 28:8 sauget 15:11 21:9 55:5,6,9,10 61:5 143:11 shoulders 107:21 110:4,6,8,18,2,4 69:23 74:1 110:17,19 session 119:8 136:20,21 sections 6:7 show save 64:5 69:7 131:21 set 1:24 10:25 27:22 35:20 88:9 100:9 seeing 15:20 49:24 59:21 60:15 71:7 96:21 122:25 123:13 saw 10:14 125:15 155:23 125:19 147:4 4:12 6:24 9:13 98:22 105:6 seeking sets showed 106:24 107:7,8 108:13,23 30:19 31:8 90:1 10:22 8:19 10:12 70:4,24 71:12 109:21 110:13 133:8 134:8 seen severe 84:24 134:12,20,21,25 14:5 18:12,14 34:18,21 125:3 shower sawdust 39:6,7 54:15 67:5 89:10 sewage 47:4 106:8 14:15 107:17,19 123:3 127:2 112:2 showing saying 128:9 134:19 sformers 10:6,7 54:4 71:15 43:17 52:21 88:12 92:5,21 seigel 145:19 shrimp 130:12 101:8 shampoos 32:15 says selected 136:4 side 12:18,20,22,24,25 13:8,14 39:12 share 101:7 146:12 163:17 13:24 15:15 19:2,7 21:7,19 sell 68:4,21 147:7 sidering 25:11 27:4 32:15 35:24 7:8 22:24 23:8 60:16 120:4 sharing 46:15 55:19 56:5 57:13,14,24 143:6 40:17 sign 62:11,14 76:1 77:15,19 seller sharon 58:1463:1597:17,19 80:15 86:11 91:16 92:24,25 4:2 146:7,21 151:22 161:23 108:11 141:10 148:7 selling sheepishly signature scattered 22:18 23:2 84:17 133:10,19 72:21 79:14,20 88:19 97:24 seminar sheet signed scheduled 6:7 11:9 15:19 93:6 114:23 60:20 72:23 73:23 79:22 25:4 69:22 send 135:23 96:10 school 111:25 151:9 154:20 sheets signer 16:17 101:5,9,11,20 123:20 sending 11:4,6,11,15,16,18 12:4,5 58:19 science 153:8 105:11 significantly 85:16 sense shift 25:23 scientific 150:9 57:8 115:4 116:18 133:7 silos 9:22 36:25 37:3 66:12 sent shifts 35:7 93:21 26:7,9 30:24 73:5 74:25 117:4,7 132:24 similar scientifically 79:17 80:9 90:5 93:6 116:3 ship 22:4 42:16 125:2,4 10:2 139:7,17,21 140:5 154:1 23:15 simple scientists 159:24 shipment 111:17 26:24 27:5 28:5 31:7 74:14 sentence 154:17 160:13,14 simplified scope 63:23 65:10 82:11 85:4,5 shipped 125:9 37:14,21 147:10 150:12 22:11 23:20,23 152:10,13 simply scouts sentences shipping 27:7,7 112:4,4 50:3 149:24 60:23 160:13 sincerely scrapers September shirt 34:2 51:20 135:25 1:24 43:8,12,13 52:2 62:13 117:19 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49706 [single - star] single slight soon speicher 83:6 24:2 55:25 80:24 158:12 sir slightly sooner spend 3:1 5:2,18 6:13,17 7:2 8:3,6 154:18 29:6 16:14 9:16 10:11,12 12:9 17:21 slip sophisticated spent 18:20 19:1,21,23 20:11 119:4 76:22 120:17 124:21 27:1229:1330:731:11,16 slippery sore spews 32:3,9,20 33:13 34:23 38:1 122:15 127:22 155:16 38:23 39:8 43:6,21 44:16 sloat sorry spill 45:7,17 49:3 51:9 52:3 161:20,22 162:10,15 163:4 32:22 37:13 107:3 112:25 14:14 15:3 54:21 56:13 57:23 63:1 sioat's 137:24,25 145:15 156:19 spilling 65:3,9 67:8 68:19 69:6,21 162:18 sort 4:14 73:18 75:3,21 76:9 78:18 sloppy 97:9 105:18 115:11 122:21 spills 81:1 84:24 85:24 86:1,4,10 3:14 4:9 123:4 138:22 14:12 78:24 87:10,18 88:16,20 89:6,13 small sound spite 91:12 93:5,16,24 94:1 95:22 104:21 22:16 122:12 96:12 97:5,13,20 98:5,21 smell source spoken 100:23 101:15,21 102:10 138:17,25 107:16 115:7,10 116:20 105:21 106:22 107:19 130:6 smith 121:18 sponsored 132:14 136:21 137:2 142:9 96:25 sources 42:24 143:20 148:2 149:19 smoke 66:13 spots 161:18 162:3 13:9 south 119:7 sister snapshot 77:24 79:7 80:17,19 101:7 spruced 139:22 125:16 136:16,18,25 151:22 7:1 sit snuffing 161:24 sses 159:3 155:9 spain 31:2 sitting soaked 143:4 ssman 124:9 4:145:14 speak 38:22 situation soap 6:13 20:9 126:3 St 49:12 51:3 117:24 118:22 136:4 special 67:22 100:16,18,22 101:6 128:7 sodium 12:24,25 15:9 59:8 101:17 110:3,9,18,5 112:16 situations 114:12,14 specialist 136:15,18,25 159:2 122:16 124:6 soft 96:11 stable six 136:5 species 144:21 43:21 58:10 sold 33:8 74:9 stadiums sixth 19:19 59:25 65:6 84:21 specific 155:19 110:14 113:2 160:17 69:14 91:2 132:4 stairways sixty sole specifically 122:14 100:24 51:2 60:20 89:4 stairwell skin soles specification 119:3 13:25 14:8 18:3 54:20 78:6,9 84:13 23:6,19,24 24:1 152:21,25 stand 57:10,12 78:10 83:9,13,14 solid 153:2,11,12,16,21 154:17 40:25 70:15 75:17 149:6 84:14 106:4,11 108:22 30:23,23 31:20 138:13 154:18,20 standard 109:18 116:12 125:1 127:1 solutions specifications 39:20 55:1,14 64:6 66:13 127:22 130:24,25 131:5,5 57:10 23:22 24:6,8 153:8,25 68:25 70:5,24 74:8 132:16 134:4,8,12,22,23,24 solvent 154:11 156:9 standards 135:1 150:14 84:10 speculate 63:8,1064:1065:1771:15 skip somebody 29:10 79:6 71:19 72:8 73:20 56:5 71:7 79:6 128:7,12,12 speech standing skipped somebody's 40:11,13,14,1541:1043:8 107:2 50:3 107:3 52:2 94:12,16 standpoint skipping somethin speeches 17:25 32:16 83:5 113:12 20:18 163:17 stands sky som|3 speed 19:3 135:24 142:11 159:1 star 49:4 142:15 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49707 [start - systems] start sticky sturdy 11:5,6 16:9,18 56:14 58:3 122:12 136:8 61:15 68:17 86:21 89:20 sting subject 102:2 103:14 137:9,12,15 124:25 6:15 62:4 67:11 76:16 137:21 149:23 stinging 89:20 115:23 120:3 started 124:24 subject 16:6,10 36:16 42:13 64:25 stipulate 131:18 85:6 102:3,14 113:4 121:22 130:19 157:25 subjects 127:12 130:2 stipulated 120:1 starting 98:13 submitted 17:1 65:12 114:16 121:10 Stockholm 39:3 48:16 149:22 150:12 41:25 subpart starts stocks 74:2 98:9 48:4 substance state stop 26:23 27:24 58:17 14:17 73:11,19 94:24 103:6 14:4 33:21,22 46:5 51:5,5,8 substances 162:18 61:12 95:6,7 116:25 125:6 60:10 66:1 stated 133:6 163:22 substantial 67:25 70:4 74:1 stopped 23:6 24:3,7 statement 34:8 36:18 129:23 substitute 1:5 42:1 50:7,19 51:21 65:1 store 148:10 71:14 73:17,21 74:11 76:15 151:7 subway 94:21 111:17 strange 155:19 statements 54:14 sudden 50:10 stream 151:8 states 22:22 sued 17:22 29:2 57:5 76:2 91:17 streams 58:18 142:18 143:7,16 148:12 75:5 suggest 156:2,4 street 74:3 96:13 station 136:16 suits 159:20 stretch 60:6 stations 2:12 summarize 155:19 stricken 42:23 50:22 64:9 66:25 statp 66:19 158:18 68:20 strike summarized status 1:18 74:24 123:17 133:12 19:8 40:16 57:21 strong summarizing statute 122:24 44:12 95:4,15 structure summary stay 24:4 64:17 45:1,6 11:2 49:10 52:23 90:19 studied sunlight 118:5 136:8 123:24 135:23 staying studies superintendent 49:22 164:3 8:13 9:3,8,10 10:5,7,9,12 105:2 110:13 steer 10:16,18,18 16:14,16,16,21 supervised 53:4 16:22 42:13,14,14,21 43:5 110:18 stenciled 43:7,9,13,18,19 45:2 46:16 supervising 159:23 46:24 54:4,7 85:25 105:6 steps stud|s supervisor 119:1,1,5 122:15 44:9 103:23 104:18 116:6,8 sterilize study supplement 137:14 sp 9:17 35:25 43:22 127:10 101:19 stuff supplied 111:12 148:7 7:8,17 19:19 20:6 39:4 1:6 stick 48:19 84:22 109:23 supply 67:12 90:21 119:2,10 25:24 47:23 96:15 support 155:8 supportive 68:24 72:5 suppose 111:17 130:11 supposed 14:14 15:10 160:6 sure 2:8 11:5 19:13 32:10 58:23 81:12 100:14 103:15 120:23 125:8 130:3 154:10 156:23 160:9 162:13 163:21 surface 84:14 surprise 8:5 surprised 9:5 sustain 63:19 79:8 95:14,20 126:14 swann 65:3 111:9 Sweden 41:24 Swedish 26:24 27:2,5,24 31:6 sweetener 135:17 swee|s 135:17 swimming 137:14 switch 120:3 switches 150:2,17 switching 120:1 symptom 83:22 108:25 109:19 130:16 symptoms 83:2 106:11 125:10 126:25 synth |s 97:24 system 159:16 systemic 14:1,9 56:20 systems 26:1 47:25 63:2 65:7 146:20 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49708 [t.v.a. - time] t telling th (cont.) think t.v.a. 23:7 153:3 76:23 77:5 78:17,25,18 9:4 10:8 20:13 24:10 29:9 143:12 tells 79:1 80:15 81:7 82:19 83:5 38:14,1940:1541:1444:11 table 160:5 84:4 85:4 88:8 89:14 90:18 44:13 50:22 52:14 53:10 138:14 temperature 91:12,21 92:5,23 94:18 54:6 56:25 68:10 70:6,10 taken 21:24 124:11,15 137:17,19 95:1,10 96:20 97:4 98:7,16 74:23 75:10 78:14,21,3,12 46:9 61:19 80:21 149:3 ten 101:25 102:11 104:20 79:4 81:10,16 86:15 88:2,6 talk 46:5,6,8 75:12,18 99:1 105:15,23 106:14,22 108:8 88:11 95:11,18 97:2,4 8:11 11:2 41:1,24 42:2,7 125:19 149:1 108:18 109:1,11,21 110:25 100:2 101:16 102:7 103:17 43:10 67:3 126:17,25 tend 110:8 111:1 116:12 117:18 104:17 109:15 110:6,21 130:25 162:9 59:15 119:10 120:2,12,22 121:22 111:1 113:13,14 120:8 talked tenor 122:16,23 123:6 125:19 121:20 123:6 125:25 40:18 59:5 66:18 67:11 162:24 127:6 129:18 131:1 132:11 126:16 128:3 129:8,11,12 127:23 136:5,17 142:10 ter 133:4,12 134:7 137:11 130:12 133:14 135:6 136:9 160:15 52:14 138:1 140:4 142:19 143:5 136:10 137:7 143:13 talking term 143:15,24 144:7,17 146:13 146:11 156:25 161:3,4,7 6:8 12:4 16:21 17:22 23:14 35:2 125:14 147:4,23 149:17 150:1,10 thinking 23:16 30:23 36:14 37:6 terms 151:4 152:15 153:19 28:3 39:22 95:9 118:2 55:6 63:20,25 65:20 69:8 42:2 60:18,24 108:17 154:13,23 155:7,15 157:18 thinners 70:6,10 71:17 75:3,4 86:14 111:25 118:24 158:19 159:1,17 160:14 131:3,5 87:15 91:18 94:10 96:16 terphenyls 161:6,15 162:18 163:2 third 107:16 141:25 113:7 thank 44:1 115:24 122:19 talks test 3:12 16:1321:1447:21 this|s 13:11,21 56:3 8:19 9:21 10:17 95:1 142:3 48:14 65:5 67:14 74:18 4:5 152:24 tank 154:13 147:14 tho|s 132:22 152:12,12,15 tested thanks 125:9 154:14,16,20 139:25 88:9 thought tanker testified tha|s 8:4,6 50:14 66:16 92:10 15:3 44:8 89:14,15 117:2 141:10 109:24 120:1 121:23 tankers testify that|s 123:14 126:22 14:6 18:5 19:19 84:21 71:12 110:24 130:9 154:4 thousands tar testimony that'ls 49:13,16 138:3 1:1 44:12 94:6,16 96:24,24 114:5 threat tarted 128:4 138:18 theater 33:7 66:3 111:12 testing 102:10 three tasks 154:10 them|s 9:10 43:23 45:1 54:7,9,10 69:15,16 71:23 tests 7:8 55:25 56:21 69:7 72:7 taught 8:19 11:3 50:18 thereon 83:24 100:20 110:2 127:13 163:12 texture 15:23 149:24 technical 135:1 thereto threshold 49:21 th 15:22 57:8 83:12 technically 1:15 2:20 3:21 4:15,25 6:3 thermal throat 64:24 6:13,25 8:10 9:3,12 11:5 150:7 108:20 109:23 technicals 12:5 13:21 15:7,18 16:1,11 therminol th|s 71:13 16:20 17:5,17 18:1,11,21 25:14 9:21 24:23 26:9 32:13 59:4 ted 21:2 22:5,15 23:9 24:1,12 the|s 73:13 92:14 111:21 132:20 31:20 25:5 26:19 27:12 28:3,14 14:23 ticket telephone 28:23 30:9 31:11 33:8,19 thing 160:5,11 79:24 132:5 162:5 35:6 36:20 42:6,24 44:18 11:2 45:8 65:4 71:3 116:15 tie tell 45:11 47:17,25 48:9,17 125:17 133:13 136:1 88:14 5:7 6:25 12:24 16:24 35:22 50:2 51:20 54:3 55:4,23 141:16 147:2,3 162:11 tighter 37:24 45:3,18,20 50:13,18 56:7,15 57:10 58:4 59:20 things 23:24 54:23 71:11 81:16,20,22 60:1 62:11,21 63:6,17 64:1 3:7 33:15 64:11 102:24 till 88:21 93:17 102:20 115:12 65:2,11,19 66:13,22 67:7 110:3 116:9 129:25 131:7 116:18 141:25 151:19 156:17 68:3 69:25,11,20 70:4,22 155:24 163:12 time 160:23 161:13 72:17 73:23 75:8 76:4,15 3:23 4:22 5:19,24 9:18,22 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49709 [time - typical] time (cont.) tolerate training true (cont.) 12:12 14:21 16:14 17:14 4:18 75:2,14 111:19 117:1 64:15,16,20,21,23 65:2,8 19:1723:1528:1 37:10,17 tomorrow transfer 65:11,18,19 66:5,5 69:8,20 38:9 41:19 43:18 47:7,16 159:8 163:24 164:6 25:14 69:21 72:16,17 76:4 78:22 48:25 54:18 66:14 74:25 tons transformer 81:21,24 82:8 83:4 94:15 76:9 78:13,9 80:13 81:15 76:3,7 40:4 49:11 58:1,6 65:14 94:21 110:20 112:16 122:1 82:16 83:1 87:9 88:10 tools 96:17 144:20 148:10 150:8 138:16 141:7 94:18 95:1 98:14 100:9,21 123:2 151:24,25 161:23 163:6,6,9 true|3 105:24 106:6 107:24 110:5 tooth transformers 41:2 111:12 112:7 115:23 116:5 137:1 25:14,25 49:13 64:20 65:8 truly 116:6 117:3 118:10 119:12 toothpaste 78:9,9 143:19,20 144:1 148:9 120:17,19,20 121:22 137:1 145:18,21,23 146:4,19 trust 122:19 125:16 129:15 top 148:15,18 149:23 150:2,16 53:3 133:10 144:23 148:8 152:3 7:1365:10 151:21 155:18 163:5 truth 162:9,12,14 topic transmission 28:3 81:17,20,23 times 131:9 151:9 truthful 6:18 91:2 95:10 100:20 toske tran|s 94:1 110:8 117:13 118:16 119:9 156:16 145:19 try 162:7 total traveling 41:18 102:22 112:22 114:3 tinghouse 61:7 66:2 76:6 118:9 122:6,8 129:8 137:9 151:4 23:18 totally treat 151:5 tint 36:18 38:25 48:17 51:21 133:4 154:19 trying 138:12 toth treating 37:20 38:24 93:5,13 95:11 tiny 121:6 107:23,25 133:10 100:12 107:15 142:7 140:2,2 touch treatment ts tion 36:11 108:9,12 112:2 137:1 52:24 125:1 touched tremendous tp tions 119:14 48:23 11:22 20:7 113:22 127:22 51:3 town trespassing 136:7 160:6 tipulate 118:8,10 8:8 ttle 148:7 toxic trial 131:10 tires 8:16 9:12 13:14 19:8,25 1:1 55:13 87:15 164:2 turn 136:7 20:3,6 21:12 27:6,8,13,13 trical 12:16 16:1,13,24 17:10 tissue 32:15,1643:1 47:15,17,19 34:3 18:11 20:12,20 21:3,14 54:19 83:19 53:7 54:10 55:19 56:6,6,15 trichlorethylene 22:8 26:4 27:17 30:15 32:4 title 66:1 77:10 83:15 113:14,22 120:4 34:17 38:8 40:14 52:5 12:7 113:22,23,24 114:7,10 trichloroethane 54:22 55:5,17 57:16 58:25 titles toxical 120:6 61:3 63:3 66:24 69:4 72:12 61:2 54:4 tried 72:19 76:1 85:21 87:22 today toxicity 39:2 100:13 121:9 141:23 89:19 91:6 94:2 96:6 97:6 32:24 49:14,17 65:5 66:5 8:12 9:3,14 10:6,7,12,16 triethylene 100:4 116:20 86:12 110:20,22 113:14 16:16 17:24 19:4 27:10 131:6 tva 131:10 159:8 162:17 33:1 42:13,14,16,24 46:24 trim 40:7 163:22 47:16 55:5,6,9,17,20 57:3 135:20 twig toe 69:8,10 74:8,17 163:11 trip 119:10 118:19 toxicologists 111:24 type told 44:6 trousers 4:11 13:7 19:1242:17 1:22 3:2 7:16 24:11 32:21 toxicology 116:17 117:19 74:16 78:12 82:15 93:4 32:23 42:18 43:23 44:7,9 9:19 69:2 88:23 89:5 truck 106:23 124:16,18 138:6 44:23 45:13,22,24 46:13 tract 112:9 139:8 144:20 150:18 154:3 47:3 50:1,21 52:11 82:9 57:6 83:8 trucks typed 94:18 107:13 108:24 111:1 trade 84:21 160:1 114:24 116:10 121:15 128:17 139:4,5 150:4 true types 131:11 133:4,4,6 trademark 9:10 10:19,20 27:7 32:19 131:15 135:12 158:18 tolerance 31:24 34:14 37:16,19 41:3 47:24 typical 59:17 48:2,5,8 53:10 57:12 62:23 83:22 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49710 [typing - water] typing university utilities 43:14 41:25 101:17 121:7 65:15 u unknown uzzling u.s. 144:17 uals 51:15 56:1,18 57:3 149:9 164:3,5 unnecessary 27:21________________ v valley 69:14 82:12 100:17 uh 91:15 unrealistic 98:1 valuable 155:13 ultimate 85:11 ultimately 128:13 unreasonable 74:21 unrelated 120:18 values 57:8 vapor 13:2 57:7 unacceptable 4:8 unannounced 8:5 unsure 22:5 un|s 60:9 vapors 15:10 21:22 57:6 138:2 variance 60:21,25 unattainable until|3 varied 73:21 unbroken 84:14 unchallenged 64:18 unusually 74:9 unwanted 118:18 various 59:18 vary 9:21 47:20 60:18 underneath 117:22 understand 13:723:1839:1843:17 unwarranted 73:20 upper 57:6 vast 152:15 vat 124:9 50:4 52:3 53:5 59:6 64:11 78:20 81:12 84:2 91:11 understanding 30:7 32:20 47:19 50:25 51:6,7,9 73:4 151:5 upset 82:3 upsets 81:22 upshot vein 46:23 ventilation 3:6 15:9,10 venti|3 understandings 60:17 understood 3:2 74:19 u're 43:17 urt 3:4 verrule 68:12 versus undertaken 107:6 126:21 126:17 42:17 undertaking 59:8 60:22 undertakings 59:21,22 underwriters use 3:15 12:17 20:3 26:18 36:3 37:9 42:18 47:6,12 48:18 49:4,7 52:17 59:16 60:8 64:19 65:14 77:17 78:17 93:1,9 98:3 102:23 108:17 vice 25:1 71:11 94:6 violation 53:10 Virginia 77:25 78:8 79:7 80:17 148:16 undue 80:22 81:2 unfair 27:1 110:8 115:17 116:19,23 129:25 143:15,17 144:1,1 144:19 145:5 148:17 150:2 151:5,13 152:1,4 154:24 156:2 157:10,12,15 151:23 visit 6:16 7:1 8:5 132:6 visited 6:23 44:4 uniform 117:16,18 unique 128:20,22 users 73:15 uses 68:13 131:21 volume 95:25 volunteered 93:6 united usual vomiting 76:2 112:3 142:18 148:12 156:2,4 143:7,16 106:3 utes 32:4 14:1,10 vfj 161:25 w wait 116:18 126:20 127:6 133:7 156:19 walk 8:7 118:3,7 119:7 walking 118:14 wall 114:6 want 1:108:11 10:24 11:3,8 12:16 14:20 18:3 20:12,15 22:8,17 38:8 52:20 54:22 55:5 57:24 58:25 63:3 64:1 66:24 67:3 69:3,3,15,22,23 69:24 71:3 81:2 86:16 87:22 89:2,19 90:17 103:17 103:19 113:5 125:6 131:9 131:10 134:20 137:4 142:15 144:14 145:21 147:22 156:12 157:5,5,12 161:2,6 163:17 wanted 39:23 80:24 136:10 153:3,5 157:10 wants 44:15 144:12 147:18 war 102:9,9,13 warehouse 160:2,7,9 warned 78:21 warning 9:12,13 10:17 14:4,5,23,25 15:2 17:24 18:4,6 35:21 78:16 84:20 106:10 159:9 159:12 160:19 warnings 10:20 19:18 105:7,8,10 warranty 15:22 wash 106:8 116:14,15 119:18,22 119:24 washed 78:25,2 Washington 101:16 watch 112:1 water 32:12 39:15 47:25 63:8,10 64:9 66:13 71:15 74:20,22 74:24 75:2,3,4,5,18 112:1 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49711 [water - yl] water (cont.) we've 114:12,14 138:9 8:1 35:22 50:14 87:14 88:1 waterways 131:16 73:1075:11,12,13 whatsoever wax 48:18 124:18 137:19 wheeler ways 26:19 27:4,20 28:3 32:7 27:14 43:25 44:25 45:3,13,13,23 wear 45:25 80:10 87:17 13:4 78:11 106:12 117:12 wheeler's 117:17,22 132:25 133:5 28:1 74:17 135:15,16 white wearing 137:19 78:7 133:20 whiteheads weap 108:23 84:11 whitewash weather 81:14 117:20,21 whip week 25:24 142:2 117:4 wide weight 47:22 48:3 14:2,10 141:13,18,22 widely weights 97:24 22:11 83:19 widmark went 41:25 3:3 43:23 45:4,18 70:2,22 wilburn 88:3 100:13 101:5,8,16 77:17 161:24 110:2 112:8 122:20 139:25 wildlife 141:5 152:15 27:22 60:12 werp william 42:14 1:2,3 45:16,17 87:3 west willing 100:16 59:22 126:19 wesp windows 23:18 135:22,24 westinghouse windshield 1:7,11,137:21 23:11,16 135:22 24:1 34:10 40:2 41:5 58:12 wisdom 58:14,18 69:11,18,16 72:6 75:16 77:4,9,22 78:2,6,8,20,23 wished 79:10,17 80:15,20 110:16 42:17 128:13 131:25 143:24,25 withdraw 144:5,7,18,23 145:5,8,18 20:16 66:20 145:24 146:4,5,6,18,20 withdrawn 147:10 148:5,13 149:17,25 66:22 150:19,22,23 151:13,16,20 withdrew 152:1,4,8,20 153:2,7,12,16 48:15 153:22 154:1,4,6,9,13,17 withstand 156:9 157:8,20,21 158:4,11 111:24 158:15,16,20 159:2,5 witness 160:23,23 161:4,11,11,17 10:1020:1429:1044:14 163:4,6 59:6 79:6 126:17 129:18 westinghouse's 156:8 161:22 72:4 150:4 witnessed weston 128:9 40:3 witnesses working (cont.) 127:7 106:18 118:14 150:16 witp workmen 163:11 84:9 wm world 1:1 9:19,20 76:6 93:2,8 102:9 women 142:23 6:8 worried wonder 81:8 7:5 34:17 worry wood 19:11 81:9,12,24 80:12,13,18 82:9 91:9 92:3 worth 92:7,14,21 107:23,25 130:8 82:1 wood's wright 92:9 69:25,23 70:2,22 96:23,25 wool 97:21 98:19 117:22 writes word 15:18 92:5 3:16 4:9 7:19 9:4,25 18:8,8 writing 20:3 27:13,13,15 36:3 37:9 41:1460:19 47:17,18 49:4 93:1 105:21 written 105:21 110:6 124:8 125:13 62:6 88:18 91:8 92:13 worded 105:7,8,10,11,15,21 114:18 85:20 115:6,9,10 wording wrong 9:16 81:15 117:7 words wrote 47:6 92:22 98:8,8,14 110:8 28:1 30:8 64:12 79:16 84:7 125:7 84:8,17 92:7,8 wore wp 117:23 116:19 work 7:7,9 27:2,3,25 42:16,24 y 101:19 104:24 105:17 109:15 112:8 116:3 119:20 120:15 122:25 133:21 148:11 161:15 52:16 64:3 67:4 92:1 13410 15621 1617 16318 worked 6:8 14:21 26:21 46:1 85:1,8 96:23 103:25 106:19 109:2 109:2,14 110:21,22,25 116:11 161:11 162:17 worker 43:14 96:19 101:10 104:13 123:6 132:19 148:5,12 years 50:16 51:25 64:18 84:24 85:8,15 92:6,17,23 100:21 101:9,13 102:5 104:10 111:19,20 114:25 115:3,12 117:8 132:16 134:8,12 workers 1:17,20 3:8,10,134:14,21 4:25 5:3,10,22,25 6:7,14 107:24 110:24 111:1 12420 12519 12710 133:25 135:13 143:25 144:3,7 157:22 7:7,16 9:12 10:21 15:2 54:19 57:7 78:16 110:4 112:7 114:19 116:11 117:10,12,17 119:6 121:15 138:10,12 yesieraay 36:2 39:13 44:7,8 122:11 131:11 132:8 working 1:16,20 2:24 3:7 28:5 81:6 84:25 85:9,13,14 104:2 3223 \y/<l 13718 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49712 [ymca - zip] ymca 112:5 york 38:19 yo|3 43:17 103:14 you'r|3 14:14 youth 45:20 71:4 123:24 128:5 yt* 128:23 135:8 ything 73:3 yusho 92:6,17,22 zero 55:25 zip 100:17 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN TOWOLDMONOQ49713