Document NEwdqEmnQMpzkN0ze2GgMLJDg

... _ .............................._...................................................................................................................................... 0 2 1 Deposition of BRUCE . KETCHAM, called for 2 examination pursuant to notice of deposition . on 3 Friday, January 22, 1999, in Washington, D.C . at the 4 law offices of Shea and Gardner, 1800 Massac lusetts 5 Avenue, 1>7. W . , Suite F, at 10:35 a.m, before 7ENDY S. 6 CASWELL, Court Reporter, having been duly sw 3rn by 7 Edwin G. Crowley, a Notary Public within and for the 8 District of Columbia, when were present on b shalf of 9 the respective parties: 10 PERRY J, ROUSSEL, JR., ESQ. 11 Roussel and Roussel 12 1710 Cannes Drive 13 LaPlace, Louisiana 70068 14 (504) 651-6591 15 On behalf of Plaintiffs IS THOMAS J. MIKULA, ESQ. 17 REENA N. GLAZER, ESQ. 18 Shea & Gardner 19 1800 Massachusetts Avenue, N.W. 20 Washington, D. C. 20036 21 (202) 828-2000 22 On behalf of Defendant Rockwell Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 WXKtf6-6646 410-664-25i D 0 3 1 APPEARANCES {CONTINUED): 2 MICHAEL T. CALI, ESQ. 3 Frilot, Partridge, Kohnke & Cleme hts, LC 4 3600 Energy Centre 5 1100 Poydraa Street 6 New Orleans, Louisiana 70163-360 P 7 (504) 599-8005 8 On behalf of Abex Corporation and 3 Motion Control Industries, Inc.j 10 XI JULIANNE P. ECHOLS, ESQ. 12 CHRIS WNUK, ESQ. 13 Laski, Giger & Laborde 14 One Shell Square 15 701 Poydras 16 New Orleans, Louisiana 70139 17 (504) 561-0400 18 On behalf of Ford Motor Company 19 20 21 - - continued - 22 Acf,-Federal Reporters, Inc. Nationwide Coverage 3Q2-347.37U0 ti00-336-6646 41fl-684-25!j3 0 4 1 |APPEARANCES {CONTINUED ) : 2 WILLIAM BROCKMAN, ESQ, 3 ROBERT KNIGHT, ESQ. 4 HOWARD KAPLAN, ESQ. 5 Bernard, Cassisa & Elliott 6 1615 Metairie Road 7 Metairie, Louisiana 70005-5490 8 (504) 834-2612 ;. 9 On behalf of General Motors 10 11 WILLIAM J, PERRY, ESQ, 12 (for David Schnexnaydre) 13 3850 North Causeway Boulevard 14 Lakeway II, Suite 650 IS Metairie, Louisiana 70002 16 [504) 836-6300 17 On behalf of Midland Brake, Prattville 1 8 Manufacturing, Inc,, and United Brake 19 20 21 22 Ace-Federal Reporters, Inc. Ngtfumvide Cover# 202-347--VIW B00-336-6646 4]0-6R4-25i 0 0 5 1 proceedings 2 thereupon, 3 BRUCE E. KETCHAM 4 jas called as a witness and, having first besn duly 5 sworn, was examined and testified as follows 6 MR. ROUSSEL: Usual stipulations? 7 MR. MIKULA: Which are? a MR. ROUSSEL: Ho objections except to the 9 ;orm of the question and responsiveness? 10 MR, MIKULA; You mean all objections -- 1 1 MR. ROUSSEL: Are reserved. 12 MR. MIKULA: That's fine. 13 MR. CALI: Yes. 14 EXAMINATION IS BY MR. ROUSSEL: 16 Q Okay, Mr. Ketcham. My name is Per|ry 17 oussel. I represent the plaintiffs in this case. 18 Could you please give your full na|me and 19 ddress for the record? 20 A Bruce E. Ketcham. My business address is 21 135 West Maple Road, Troy, Michigan 48084. 22 Q Could you please give me your homd Ace-Fkderal Reporters, Inc. Naliuflwide Coverage 202-347-3700 800-336-6646 41(1.684-25! 9 0 6 a address. 2 A Home address is 2854 Steamboat Spr| ngs, 3 Rochester Hills, Michigan 48309, 4 Q Could you please go over your educ tional 5 background for the record, 6 A Starting? 7 Q Starting with high school. 8 A I graduated from Poughkeepsie High School 9 .n Poughkeepsie, New York. I attended -10 Q What was the date of that? 11 A 1967. I attended Union College in 12 Schenectady, New York, graduated in 1972 wit . degree 13 nelectrical engineering and industrial ecofr: omics. 14 QAny further education? 15 A Yea. 16 Q What? 17 A I attended Xavier University in Ci cinnati IB >hio, received my MBA, I believe that was in 1981 . 19 Then I attended the University - irst of 20 11, I attended North Kentucky University an f 21 tarting in 1983, and then transferred to tb 22 'niversity of Detroit and received my PhD in 1 987. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-334-6646 410-684-255) ) 7 1Q 2 state? Are you licensed to practice law i h a ny 3 A Yes 4 Q Which states are those? 5 A Michigan. 6 Q When did you receive your license? 7 A I believe it was 1988. 8 Q Do you practice law? 9 A Mo . Do you perform any legal functions! for 10 Q 11 Rockwell International Corporation? 12 A No , 13 Q Have you used your law degree in a|ny 14 manner? 15 A To the extent-that I use my legal training 16 in my current position, so I used the trainiln g that I 17 received. 18 Q Why don't you tell me about your e| employment 19 listory, starting from high school and when you got 20 jut of college, whenever you first became emu loyed. 21 A Are you talking regarding full-tinje 22 employment ? Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-664-25: (1 8 1 Q Full- or part-time. 2 A Well, then, could you clarify whet her you 3 want high school or whether you want after my 4 graduation from college. 5 Q Well, did you do any full-time wor k between 6 high school and college? 7 A No, 8 Q After college? 9 A I started with the General Electri p Company 10 following my graduation from college in 1972 in 11 Schenectady, New York. 12 Q What did you do there? 13 A I was on their manufacturing manag ement and 14 training program. 15 Q What did you do there at that part icular 16 location? 17 A It was a large location, had vari oM s 18 manufacturing businesses located in the faci lity . 19 Q What was your function there? 20 A I was a methods specialist, 21 Q When you say methods, are you ta Ikling about 2 2 industrial engineering-type work done in ti me and Ace-Federal Reporters, Inc. Nalionwide Coverage 202*347-3700 800-336*6646 410*684-255) 7 118 2 . 0 WSCs jg motion studies; what type of work are you tajLking about ? A Generally that type of thing, although not that type of description as you describe. Q What areas were you evaluating as a methods specialist? Let me clarify it a little bit. D|id you have any work with automobile parts at that particular location? 10 A No . 11 Q That includes no tru cks 12 vehicles, trail .ers, that type of trucks, 13 A That s correct ' 14 Q Wha t was your next j ob? 15 A I went into th e Army Re btive 16 duty. 17 Q When was that? 18 A In the fall of 1972. 19 Q How long were you on active duty? 2 0 A Approximately six months. 21 Q Did you go to Vietnam then? 22 A No. Ac.e-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-3366646 410-684-25$ 1 Q What did you do on active duty? 2 A That was the train! ng, ha S ic train L 3 AIT . 4 Q What type of training were they giv 5 A Basic training, and following that 6 training in transportation, MOS. 7 Q What does that stand for? 8 A I don't know at this point in time. 9 Q What did you do after the reserves ' 10 A I returned to General Electric. 11 Q Had your job changed any? 12 A I went on to the next assignment i:i 13 nanufacturing training program, 14 Q What was that? 15 A That was as a production control 16 specialist 17 Q Again, dealing with any automotive 16 ruck parts, that type of stuff? 1 9 A Wo. 2 0 Q How long were you atGE? 2 1 A Until 1978. 22 Q At any timewhile you were at GE, 1 Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 B0M36-6646 410-6B4-255( 71182.0 VJSCs jg 11 1 work with any automotive parts, truck parts of any 2 type, anything like that? 3 A No. 4 Q When you left OB, where did you go next ? 5 A To Rockwell International. 6 Q That was in 197B? 7 A That's correct. 3 Q Tell me what you did when you firs b got to 9 Rockwell,, 10 A I was sales order manager at their 11 Florence, Kentucky facility. 12 Q What was your function as a sales brder 13 manager? 14 A Supervising the sales order function. 15 Q What did you sell there? 16 A Automotive service parts. 17 Q What type of parts did you sell at this 18 particular location? 19 A The Florence facility was the serv [ice parts 20 facility for Rockwell International. We solid the 21 full gamut of the aftermarket parts in suppo rt of 22 Rockwell's production business. Ace-Federai. Reporters, Inc. Nationwide Coverage 202-M7-37D0 800-336-6646 410-684-25E ] 71182,0 WSCsj g 12 1 Q Tell me what you mean by "aftermar ket 2 ipartB . *' 3 A Parts that would be used to repair or 4 replace product in the field, of service. 5 Q What types of product? 6 A Pardon? 7 Q What types of product? e A Major categories would include axl fee, 9 brakes, drive lines. 10 1 Q Is that the first experience you h ad with 11 automotive parts? 12 A Yes. 13 Q Could you tell me how, as your pos tion 1 4 progressed, and what different locations you have 15 worked at with being with Rockwell, 16 * A In the fall of '78, I moved to pur phasing 17 manager at the Florence facility. 18 MS, ECHOLS: I would like to inter rupt for 19 a second. This is Julianne Echols, for Chri k Wnuk, 20 I have arrived. 2 1 MR. ROUSSEL: Good. 22 MS. ECHOLS: Thanks. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 WX)-33ti-4646 410-684-255(1 Q 13 1 BY MR. ROUSSEL: 2 Q what did you do as purchasing mana jer ? 3 A I was responsible for supervising : he 4 purchasing function that handled the procure In ent of 5 outside product, not internal Rockwell produ ttB . 6 Q When you say outside product, v/e a e 7 talking about supplies to Rockwell? a A That's correct. 9 Q What types of suppliesare we talk Ing 10 about? - 11 A General major categories, might be 12 fasteners, bearings, seals, those types of p toduct s 13 that Rockwell itself did not manufacture. 14 Q What about brake linings, brake sh es, 15 brake pads, is this something that you did i ft this 16 Florence, Kentucky location? 17 ACould you repeat the question, ia Q When you said Florence, you said i t was 19 Florence, Kentucky? 20 A That's correct. 21 Q Was that something you did in the lorence, 22 Kentucky location, purchase brake linings, s oes, Ach-Federal Reporters, Inc. Nation wide? Coverage 2JJ2-347-3700 BOD-336-6646 4U)-6B4-255<] 1 brake pads, that type of stuff, from outside 2 for assembly by Rockwell? 3 A I canrc recall whether they came f: 4 outside vendors or whether1 they came through 5 inner-plant sources, 6 Q How would they have been ordered hr 1 inner-plant sources? What do you mean by in:i 8 sources? 9 A Rockwell has a number of manufactu : 10 plants where we produce the production produ: 11 was sold to the original equipment manufactu.: 12 would -- not the purchasing function, but Flo 13 would order certain of its parts directly ag i 14 inner-plant sources. 15 For instance, if there was a brake 16 lining assembly, that would have been ordere l 17 one of our brake manufacturing assembly plan: 18 Q The Florence, Kentucky operation, / 19 a distribution center, or what was that? 20 A That's correct, it was a distribut. 21 center. 22 Q So there was no manufacturing goinq Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 ROO-336-6646 4W-6R4`2S5( 0 1 Florence or at Florence ? 2 A Not at that time. 3 Q At that time, you weren't concerned 4 any manufacturing operations? 5 A Wo. 6 Q What was your next job at the Flor>i 7 location? 8 A I was t he production control manage 9 Q Now, we are going from distribution 10 production contro 1. Can you tell me exactly 11 what has changed, now that you are production 12 manager. 13 A I am still at the Florence, Kentuc : 14 facility. The production control manager, i;i 15 function, I had responsibilities at various 16 several subdepartments, including procuremen1; 17 urchasing -- purchasing, quality control, in 18 eceiving, traffic, information services, and 19 inventory control. 20 Q Let me ask you about -- at this tin 21 nything being produced in the Florence faci . 22 as it still a distribution center only? Ace~Fedekal Reporters, Inc. Nationwide Cuvent^o 2Q2-347-37W} JWXKJ36-6646 410-684-25S( 16 1 A At what time? 2 Q At the time you became production control 3 nanager. 4 A At the time I became production co it rol 5 lanager, there was no production, there, it ;as a 6 lietribution center. 7 Q What was the date of that? 8 A 1982 approximately. 9 Q What quality control were you concerned 10 ibout? - 1 1 A Incoming inspection of purchased a implete 12 iarts as well as quality control of the pack iging and 13 .itting operations that went on in the facil ty, and 14 he final pick and shipment to our customers 15 Q What was your next job with Rockwe 1? 16 A I was the division materials manag r for 17 he on-highway axle division. 18 Q For what division is that? 19 A On-highway axle. 20 Q What did you do as the division ma uager for 21 he on-highway axle division, and when was t lat ? 22 A I started in 1984. X was responsi le for Ace-Federal Reporters, Inc. Nationwide Coverage 2n2-.W^7l)G 410-684-2551 I 1 coordinating the materials activity with the 2 on-highway axle plants. 3 Q Did any of the on-highway axle pla i 4 brake shoes, brake linings, those types of p: 5 A No, they did not make them. 6 Q What did they produce? 7 A They produced axles, the driving a:c 8 front axles for on-highway vehicles. 9 Q What was your next position with t i 10 company? 11 A I was the manager of product compl.. 12 Q When was that? 13 A 1988. 14 Q What did you do asmanager of prodi 15 compliance? 16 A Responsible for productsafety 17 investigations, recall notices to our customs IS compliance with NHTSA regulations, and commun 19 with NHTSA and NTSB. 20 Q When you say NHTSA, what are you t i 21 about ? 22 A National Highway Traffic Safety Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-37W 800-336-6646 410-684-255( 0 1 Administration. 2 Q What was your next position with R 3 International? ;4;= 1 A ;; . Manager of product analysis, ..- 'i 5 When was that? ;. 6 A In 1993 . r Q What did you do in that function.? 3 ... A Initially, I was responsible for aj 9 counsel in the defense of product liability 10 litigation and claims. 11 Q What else? 12 A Over the years, it was expanded to 13 couple of other areas, including government 2 14 administration, as well as contract adrainist : 15 with our on-board computer business, 16 Q You said "initially.11 How has tha : 17 from 1993 through the years? In addition, w 1 18 you done in that position? 19 A The additional responsibilities wer 20 over time in the contracts area. 21 Q Then when did you change positions, 22 you still in that position? Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 SOO-336-6646 4MI*M-25H 0 1 A I am still in that position, Howe 2 is now Meritor Automotive, Inc, 3 Q Is that the new company you work f 4 A Yes 5 Q Could you spell that for me, 6 A Meritor, M-E-R-I-T-O-R, Automotive 1 Incorporated. 8 Q How did you come from working for 9 International to Meritor Automotive, Iracorpo 1.0' A Rockwell spun off the automotive b^j 11 of Rockwell effective October 1, 1997, and a 12( company was formed of those automotive busing 13 Q Is any automotive still done by Ro 14 itself, any automotive business? 15 A Wo, 16 Q Do you know the reason why they sp^u 17 this particular company? 18 A They were transforming the company 19 narrowing its focus into an electronics busiju 20 Q What do you do at Meritor Automotive 21 Incorporated? 22 A Same positions I did for Rockwell, Ace-Federal Reporters, Inc. Nationwide Coverage 202-347^3700 BOO-336-6646 410-6B4-255C 71182 . Q WSCaj g C 20 posicion. 2 Q You s tarted in 3 A Yes October 1, company 4 came into exd St ence . 5 Q I B Me ritor Auto )F 6 Rockwell, or is it a sepa 7 A It i a a eeparat a Q It is wholly ow 9 A NO , i ndependent 10 Q Do yo u know if 11 corporation of Rockwell? r 12 . A No. 13 Q How is it related to Rockwell? 14 A It is the former businesses of Roc kwell 15 Automotive. 16 Q Does Rockwell have an interest in P-t ? 17 A Wo. 18 Q They don't own the stock? 19 A No . 2 0 Q Do you know who owns the stock? 2 1 A The shareholders. 22 Q Is it a corporation that's traded bn the c Ace-Federal Reporters, Inc. NMiwwid Coverage 2(12-347-3700 B00-336-6646 41Q*fiB4-25M 0 1 York Stock Exchange? 2 A Yes, 3 Q Did you read or review any documen: 4 reparation for this deposition today? 5 A Yes. 6 Q Could you tell me what you reviewe 7 /our deposition. 8 A As X recall, some of the interroga 9 inswers, the document request, some literatu 10 jublications and some correspondence. 11 Q Did you look atany Rockwell docum 12 :ar as their corporate history or anything 1 13 >r were you already familiar with that? 14 A I did not look at any Rockwell doc 15 egarding corporate history, 16 Q Do you know about Rockwell's corpo 17 iistory, how did it develop, I guess, maybe, 18 .935 on? 19 A In generalities, yes. 20 Q Why don't you tell me a little bit 21 hem. 22 A Starting when? Ace-Federal Reporters, Inc. Nationwide Courage 202-347-3700 BWKJ3(>*6646 410-6B4-255< 0 1 Q 1935. 2 A 1935. I believe at that point in 3 vas known aa Timken Detroit Axle Company. 4 Q Let me stop you for a second. I wfe 5 isk you a little bit about this Timken Detroi 6 Company. What did Timken make, do you know, 7 :hey were operating? S A Wait a minute. where -- can you b 9 ipecific? 10 Q When they were operating under -the a l 'imken Detroit Axle, what type of products w 12 taking? 13 A Axle products, brake products. Th 14 iave been other businesses that they held, bti 15 .on't recall what they were at this particulfc 16 n time. 17 Q Did Rockwell purchase Timken? . Exa); IB appened to Timken? 19 A ..Timken Detroit Axle cj>i 20 lecame, I believe it was, Rockwell Spring an 21 Q Now, once this change was made, v/a 22 :ockwell Spring and Axle still producing par Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-.1700 BOO-336-6646 410-AB4-155( 4 ---- 0 1 Q yes, 2 A In approximately 1957, it became Rfc 3 Standard. 4 Q Now, when Rockwell Standard took o 5 ?ompany, it became the name of Rockwell Stan 6 fere they still using the same or selling pa 7 :he name of Timken Detroit Axle? a A I don.'t recall . 9 0 Do you remember at what point in t IQ iver, Rockwell quit using the name Timken De 11 Lxler or do they still use it today? 12 A No, it is still not used today. 13 Q Do you know when they stopped usinjj 14 A No, I do not. 15 Q Does Rockwell have records or any 16 information to identify when the Timken Detr 17 iame was discontinued in its use? 18 A Not that I am aware of . 19 Q Do you know who would know that ty 20 nformation? 21 A No. 22 Q you said you didn't know when it s Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800J36-fiM6 410-684-25M 71182. WSCsjg 25 1 Do you have any rough estimate of when it stppped 2 using it? 3 A By the `60s, I believe that it was no 4 longer using that nomenclature. Where in fch |* '60s, 1 5 don't know. 6 Q When you came to work for Rockwell in 1978, 7 >did you handle any products at the distribut Lon 8 center that still had the Timken Detroit Axl 5 name on 9 it? 10 A Not that I can recall. 11 Q Baaed on, maybe, your review, was imken 12 Detroit Axle a big vendor, whether you know b r not ? 13 MR. MIKULA: Objection, vague. 14 BY MR. ROUSSEL; Q Was there a lot of product sold unjler that 15 16 particular name? 17 A Objection, vague. IB MR. MIKULA: Objection, vague. 19 THE WITNESS: All of the product that the 20 company made was sold under that name. The Volumes 21 that were at any given point in time, I don't know, 22 as we sit here. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 80M36-6Me 0 I 1 BY MR. ROUSSEL; 2 Q Initially, in 1953 when the name w 3 changed to Rockwell Spring and Axle, was Roc. i 4 only making automotive parts at that time? | S A I don't recall as I sit here. 6 Q What was the name change after Roc 7 Standard? 8 A North American Rockwell. 9 Q That was approximately what year? 10 A Approximately 1967. 11 Q . Eventually, in 1973, I think, it ci 12 ockwell International Corporation? 13 A X believe that's the approximate di 14 MR. MIKULA: Excuse me one second. 15 MR. ROUSSEL; We can go off the re: 16 second. 17 (Discussion off the record.) 18 MR. M1KULA: Go ahead. 19 MR. ROUSSEL: Back on the record. 20 BY MR. ROUSSEL; 21 Q How many locations of Rockwell mak5 22 utomotive parts, such as brake shoes, brake Ace-Federal Reporters, Inc. NaUcmwidt? Coverage 202-347-3700 800-336-<t64<7 410-664-25K j. 0 1 or assemble those parts? 2 a At what point in time? 3 Q Let's say from 1970 on. 4 A At some point in time. North Araeri? 5 Ashtabula, Ohio facility, Tilbury, Ontario, ) 6 South Carolina facility, our Battle Creek, ML 7 facility, our Kenton, Ohio facility, and our 8 Florence, Kentucky facility. 9 In addition, brake assemblies were 10 attached to axles at various occasions at our 11 facilities. 12 Q What about Troy, Michigan? 13 A Troy, Michigan is the headquarters 14 eration. 15 Q Did they make anything there? 16 A No. 17 Q Both the facilities that you named, 18 any parti cular facility supply or distribute 19 into the State of Louisiana; do they all, ba3 20 iistr ibut e products or initially supply to a 21 listr ibut or who is going to supply into the 3 22 Louis iana Ace-Federal Reporters, Inc. Naiionwide Coverage 202-347-3700 800036-6646 410-684-2551 0 1 MR. MIKULA: Objection, vague. 2 THE WITNESS: Could you clarify yo 3 question. 4 BY MR. ROUSSEL: 5 Q Of the five facilities, six facili 6 rou named, where do they send their products 7 A To their customers. e Q And their customers could be an in 9 >rganization? 10 - MR. MIKULA: Objection, vague. 11 BY MR. ROUSSEL: 12 Q Someone not associated with RochweV 13 A Yes. . 14 Q Their customers could also be a Rofc] 15 distribution facility? 16 A Yes, other than the one itself. 17 Q Which is the Florence facility? IB A Correct. 19 Q Any of the other facilities you naiju 20 hey a distributor also, a distribution centu: 21 A At what period of time? 22 Q During ** - from 1970 on. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 HWKJ36-6646 410-6B4-255( 0 1 A 1970? 2 Q Yes * 3 A Distribution was made, yes. 4 Q Which one? 5 A T know of Kenton, Ohio. 6 Q Any other one besides Florence? 7 A Wot that I know of, as I sit here, 8 Q Do the six facilities you mention a 9 supply the Kenton, Ohio, and Florence facili: 10 certain manufacturing operations supply cert a 11 distribution centers? 12 A Could you repeat that question, 13 Q Yes, you have two distribution cen : 14 those two exist presently? 15 A No. Well, let me back up. They d> 16 exist as distribution centers presently. 17 Q When did the Kenton plant stop 18 istributing? 1 9 A 1976. 20 Q When did the Florence operations s: 2 1 istribution center? 22 A That still is a distribution center Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410^M-255d 0 1 Q They still have one distribution c? 2 A Today? 3 Q Yes. 4 A The Florence facility, and Plorenc j 5 has a satellite operation in Brampton, OntarL 6 B-r-a-m-p-t-o-n. And at one point in time th 7 West Coast facility in Hayward, California, i a satellite of Florence. 9 Q The six manufacturing facilities t.i 10 mentioned, do they all manufacture the same > 11 MR, MiKULA: Why don't you ask him 12 the names of the facilities, then you can go 13 find that out again, instead of the six ones 14 mentioned. 15 BY MR. ROUSS EL: 16 Q Kent on, Ohio , is 17 A Yes, it 1 a wi th a 18 Q It's ha rd to say, 19 o fa cility man uf act ure t 20 ar io facili ty? 21 A Some product may 22 Q Let me he mo re sp Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 S00-336-6M6 410-684-25K 0 1 brake linings are the same thing; is that col 2 A To me? 3 Q I am asking you, yes. 4 A NO . 5 Q What is the difference? Tell me. 6 A Brake shoe, to me, meansthe shoe 7 the metal component, table and backing plate 8 lining is the lining that is attached to the 9 Q what is the brake pad? 10 A -That's another description for the 11 Q What facilities of the six that yo 12 make heavy-duty brake shoes? 13 MR, MIKULAr At what point in time 14 BY MR, ROUSSEL: 15 Q From 1970 on. 16 A All of them did at some -- could yt> 17 the question again. 18 Q From 1970 on, which of the six fac 19 that you named made heavy-duty brake shoes 20 trucks, trailers, that type of operation? 21 A Heavy-duty brake shoes were manufafc 22 various points in time in Kenton, Tilbury, Bi Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 0'604-25SCj 0 32 1 Creek and York. 2 Q What about heavy-duty brake lining b > 2 A None of them -- I'm sorry, linings were 4 manufactured in our York, South Carolina fac tLlity. 5 . Q Prom what point in time? 6 A Approximately 1985. 7 Q The ones manufactured in York, Sou th 8 Carolina, were those asbestos or nonasbestos linings? 9 A Nonasbestos. 10 Q Of the six facilities that you nam d 11 jearlier, did all of those particular manufac ur ing 12 facilities, from 1970 on, make aebestos-cont ining 13 brake linings and brake shoes? 14 A None of the facilities made 15 asbestos-containing brake linings. 16 Q Which ones assembled asbestos-cont aining 17 brake linings? 18 A The Battle Creek, Kenton, Ashtabul 19 Tilbury -- I don't recollect, and I am uncer am as 2 0 to whether Florence assembled asbestos-conta ning 2 1 linings or not. 22 Q The Kenton Ohio distribution facil f-ty Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 K00-336-6M6 410*684-2551 0 1 closed, in what you said, 1976, as a distrib 2 center. Were they receiving parts from the 3 five facilities to distribute to the -- I gub 4 rest of the country? 5 A Some of the other facilities were i 6 existence at the time that Kenton ceased to 3 7 distribution center. 8 I am unaware of the internal distr L 9 from other plants, so T can't answer the que 3 10 beyond that. 11 Q The Florence distribution center, '/ 12 the distribution center for the entire count: 13 Rockwell? .. 14 A When? 15 Q From 1970, or whenever it opened, ; 16 resent. 17 A It was not open in 1970. 18 Q When did it open? 19 A 1976, 20 Q So in 1976 on, was it the distribu : 21 center for the entire company? 22 A At some points in time, yes, for ti Ace-Federal Reporters, Inc. Nationwide Coverage 2Q2-347-37W 800-336-6646 410-684-255C j. 0 1 States? 2 Q Yes. 3 A Yes. Then the Hayward facility; afc 4 previously mentioned, was a satellite distrib S center for West Coast operations. 6 Q Okay. You said in some points in 7 was the distribution center for the United S 8 At what other points in time was it not? 9 A During the points in time that the 10 facility existed, certain distribution was 11 of that Hayward facility, 12 Q Basically, the Florence facility w 1-3 main facility for Rockwell? 1 4 A Main distribution center, 15 Q Main distribution center, yes. 16 A That is correct. 17 Q If someone in Louisiana was going 18 parts from Rockwell, where would they be ord: 1 9 those parts? 2 0 A What type of customers? 21 Q Automotive parts, brake assemblies 22 contained brake linings. Ace-Federal Reporters, Inc. Nationwide Coverage 202*347-3700 B00-136-6646 410-6&4-255C 0 1 A What type of customers? 2 Q Automotive customer -- when you sa^ 3 type of customer, someone who handled automo: 4 brake parts, automobile parts. 5 A They could be ordered against any 6 facilities. 7 Q You could actually order from the 8 distribution center, you could order from ths 9 manufacturing facility direct? 10 A Depending upon the type of custome r 11 you are, 12 Q If I was in Louisiana, and I was a 13 wholesaler of Heavy Duty brake parts, could I 14 hose from the Florence facility? 15 A Yes . 16 Q Could I order them from any other : 17 A No. 18 Q Why not? 19 A Because, with its formation in 197> 2 0 ype customer would order its parts from the 21 istribution center. The other facilities w-s 22 esponsible for the sale of production parts Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 8Q0-336-frMf> 410-KI4-2551 0 1 Q To other manufacturers? 2 A Correct, to OEMs. fe3 Q When you say OEM, what does that m 4 A Original equipment manufacturer. 5 Q Like General Motors? 6 A Like General Motors, 7 THE WITNESS: May I take a five-mi* 8 break? 9 MR. ROUSSEL: Sure. Off the record 10 (Recess.) 11 BY MR. ROUSSEL: 12 Q Back on the record* 13 So, I just want to clarify, basical 14 onoriginal part vendors would have to purcha 15 he distribution center? is that correct? 16 MR. MIJCULA: Could you repeat the 17 uestion, 18 BY MR. ROUSSEL: 19 Q All nonoriginal parts, such as GM, 20 21 A Manufacturers. 22 Q -- manufacturers would have to pure Ace-Federal Reporters, Inc. Nationwide Coverage 2tJ2-M7-3700 tiW-336-6646 410-A8V2S5C 0 1 their parts from the Florence distribution c= 2 the one that was in California at one time? 3 A Production parts were shipped from 4 production facilities; aftermarket parts wers 5 from our aftermarket facility, primarily in ? 6 or Hayward or the other ones. 7 Q When you say aftermarket parts, ar5 8 talking about repair items, something that w5 9 go in an original-manufactured vehicle? 10 A Repair item could be a part which L 11 part of an original assembly, which is sold : 12 somebody. 13 Q Those would be sold directly from : 14 anufacturer? 15 A Could you clarify your question? 16 Q 1 am trying to find out if organizi 17 ther than facilities that made automobiles . 18 r made trailers, made trucks, could purchase 19 irectly from one of these facilities, any pi 20 id they have to go through Florence? 21 A Would you repeat the question or r? 22 sa ck. Ace-Federal Reporters, Inc. Nationwide Coverage 202-547-3700 WOO-336-6646 410-6W4-255C 1 Q Yes. Did anyone, other than an ori 2 manufacturer, purchase stuff from a product!3 3 facility and not from Florence? 4 A No, not at the time after Florence 5 into existence. 6 Q Let me ask you if you are familiar 7 distribution by Rockwell to - - and I am goin3 8 some companies -- Pruehauf Corporation, Do / 9 if you guys sold any parts, Rockwell sold an ^ 10 to Fruehauf Corporation? 11 When I say parts, we are talking a> 12 brake linings, brake pad, brake shoe assemblL 13 type of stuff. 14 A I don 1t know. 15 Q How about to NAPA? 16 A I don't know. 17 Q How about Rayloc Corporation? is A I don't know. 19 Q How about an organization called RL 20 Truck Parts? 21 A I don't know. 22 Q How about Haygood Corporation? Ac.e-Federal Reporters, Inc. Nationwide Covnrngc 202-347-3700 BOO'336-6646 410-684-2550 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 1 9, .-J 2 / 22 A Sounds familiar, hub I don't know. Q Trailmobile Company? A I don 11 know. Q Fontaine Corporation? A I don't know, Q New Way Company? A The name sounds familiar, but I don Q New Life Corporation? A Same sounds familiar, but I don't : Q . Fleet Parts and Equipment Company? A 1 don 1t know. Q . Heavy Duty Parts & Equipment? A Name sounds familiar, but I don't !: Q Did Rockwell manufacture any sbestos-containing parts? A Would you clarify yourquestion. 0 2_d Ruckweil ii .`si'i u . . 1.1: r ary sbestos-containing brake parte, such as bra): r.ake linings, .brake shoes? _ A Vit! (i jsur.bi CO .li.li.'jjJ L Lr . Vh fr.Yor th.'ir oui _uu_l.Lv, i\.<wi u~ u"... i Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 B00-336-6M6 410-684-255C 0 1 Q The York facility made nonasbestos 2 is that correct? 3 A That is correct. 4 Q What about facilities manufacturin' 5 assemblies or clutch disks? 6 A No . 7 Q Does Rockwell at any facility make e parts? 9 A Yes. 10 Q What facility is that? n A At what period of time? 12 Q 1970 on. 13 A At one point intime, they were 14 .anufactured or assembled in Florence, Kentu: 15 nother point in time in Laurinburg, one of : 16 arolinas, I can't recall which. 17 Q Do you know whether or not the clu : 18 r facing that was being assembled contained 19 sbestos products? 20 A Yes, I do know. 21 Q During what period of time did thoi 22 articular items contain asbestos products? Ace-Federal Reporters, Inc. Nationwide Coverage 202-347*3700 HOO-336-6646 410-684-255C J. 72 182.0 wscs j g C 41 1 A They never contained asbestos prod Uct s . 2 Q Qhf they did not. 3 Hie: Koc'-swi- : " ^ t c rna t ion u - ov' p -1 i ion 4 purchase any products from Allied Signal, 5 1-iiOvtpyl dled, any asb_es-toa - conn-a i-nmg-produc s, -- 6 A . Jo.i t ciow. _ ........ . . .\ 7 Q '--"which is also the successor--to Bendix 8 Corporation? . - 9 A T don't know. 10 Q Did Rockwell sell any products to Allied 11 Signal / ' Incorporated? 12 | A I don't know, 13 Q slow about t.ic Unr.u:Corporation? 14 --A- - "I don't know. 15 Q Did Rockwell purchase any products from IS Abex Corporation? 17 A Yes . .Q During what period of time did'RocIwell purchase products from Ab'ex/ products 'being fcrake oua):-; l:j-.r.cjo. 1 I'lis, ai*bes tos - containing? A I don 1t know the years. C Ace-Federal Reporters, Inc. Nationwide Coverage 202-.W-37DO 800-336-&646 410-684-2550 i 1 Q .Are- they presently still buying th j :< products from Abex Corporation? 3 A Asbestos-containing? i 4 Q Yes , 5 A Wo . ' Q Do you know when they discontinued 7 asbestos*-containing products from Abex Corpo:' 8 A Asbestos^containing? Q Yes. . 10, ll Q Does Rockwell sell any products to 12 orporation? 13 A I don't know. 14 Q Up until 1987, do you know the type 15 products that Rockwell purchased from Abex 16 oration? 17 A Brake linings. ia Q Did Rockwell ever buy any products 1 9 , F. Goodrich Company? 20 Again, when r say products, I am t< 2 1 bout brake linings, brake shoes, brake pads 22 ebestos-containing. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336*6646 410-684-2550 1 A I don r t know, 2 Q Did Rockwell ever sell any product 3 B. F. Goodrich Company? 4 A l don't know. 5 Q Did Rockwell ever buy any parts fr 6 Borg-Warner Corporation, B-O-R-G? 7 A X don't know. 8 Q Do you know if they ever sold any p 9 to that corporation? 10 A I don't know. 1 l Q Did Rockwell ever buy any parts fr^ 12 Control Industries, a division of Carlisle 13 Corporation? 14 A The name sounds familiar, but I am 1 5 uncertain. 16 Q Do you know if Rockwell ever sold ^ 17 to Motion Control Industries? 18 A 1 don 1t know. 19 Q Did Rockwell ever buy any parts Ixp 2 0 Motor Company? 2 1 A I don't believe so. 22 Q Did Rockwell ever sell parts to Pofr Ace-Federal Reporters, Inc. Nationwide Coverage 2D2-347-3700 80a-336-*646 410-CS4-255C 1 Company? 2 A Yes, 3 Q Through today, has Rockwell sold 4 Ford Motor Company? 5 A Yes, excuse me - 6 MR. MIK.ULA: What do you mean by " ]|> 7 again? 0 MR. ROUSSEL: Again, we want to def 9 BY MR. ROUSSEL: 10 Q Asbestos-containing brake linings, 11 pads, brake shoes, 12 MR, MIKULA: Are you talking about 13 continuously throughout this period? 14 MR. ROUSSEL: Well, whatever period 15 time. 16 THE WITNESS] Could you repeat the 17 question? 18 MR. ROUSSEL: Yes. 19 BY MR. ROUSSEL: 2 0 'Q Has Rockwell sold any parts to For 2 1 or'ip.:.:iy < vrm 197;; up li.-uuqh Lodr.y? 11 at c4 22 ger^dTods of ti me-te-11--me-.w.hat^ periods of time Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 600-336-6646 410-664*25Sf 1 ............A----------jteer- that- peid*ed^jQ.--t-*iTiie; "we sold ' 2 sbeetoe~containing brake parts to Ford Motor 3 ompany. I don't know when during that perio 4 ime, and I want to quantify that. jjj Q Do you know approximately when Roc: 6 iscontinued selling asbestos-containing par: 7 ord Motor Company? 8 A The approximate date would be in tli IS 8 0-s - or--ear-l-y - 1-9Gsv to' the bes-t--67T-my knowle'd 10 Q Doea Rockwell still assemble brake 11 ith asbestos-containing materials? 12 A To the best of my knowledge, we do 13 oday. 14 Q Do you know when that was totally 15 iscoutinued? 16 A I believe it was last year. 17 Q Does Rockwell buy -- from 1970 on, ia roducts, any definition we used, from Frueha 19 orporation, F-r-u-e-h-a-u-f? . 20 A Not that I am aware of. . 21 Q Has Rockwell sold any.products to 22 ompany? Ace-Federal Reporters, Inc. Nationwide Coverage 2UZ-347-3700 SCXK336-6646 410-684-2550 0 46 1 A Wot that I am aware of. 2 Q Has Rockwell brought any parts fro F General 3 Motors Corporation? 4 A Wot that I am aware of. 5 Q Has Rockwell sold any parts to Gen eral 6 Motors Corporation? 1 A Yes. ' 8 Q From 1970 through today, could you tell me 9 about those sales of asbestos-containing pr Offl ucts . 10 A They were sold to them over some g ven 11 period of time during that period of time th t you 12 had mentioned, not for all the years. 13 Q And did you discontinue, approxima ely, the 1-3 sale of those asbestos-containing products a about 15 the same time that you discontinued the sale to Ford 16 Motor Company? 17 A To the best of my knowledge. 18 Q Did Rockwell buy any parts from Mi 1 and 19 Heavy-Duty Systems, successor to Gray Rock B ake 20 Company? 21 A Not that I am aware of. 22 Q Did Rockwell sell any parts to Mid and Ace-Federal Reporters, Inc. Natiunwid & Coverage 2UZ-347-3700 800-336-6646 41 <1684-2550 0 47 1 leavy-Duty Systems or to Gray Rock Brake Company? 2 A Not that I am aware of. 3 Q Did Rockwell buy any parts from Ra^loc, 4 incorporated? 5 A Not that I am aware of. 6 Q Did Rockwell sell any parts to Rayloc 7 lorporation? S A Not that I am aware of. 9 Q Did Rockwell buy any parts from Ra Mark 10 'riction Company? . 11 A Not that I am aware of. 12 Q Did you sell any parts to Ray Mark Friction 13 'ompany? - 14 A Not that I am aware of. 15 Q Let me ask you, you had mentioned Earlier 16 hat you are not aware of certain sales. Do s that 17 ean it didn't happen, or just that you don' have 18 ny knowledge of it personally? 19 A As I sit here today, to the best o :: my 20 emory, I have no knowledge. 21 Q That doesn't mean Rockwell may or nay not 22 ave done it; is that correct? Ace-Federal Reporters, Inc, Nationwide Covetage 202-347-3700 800-336-6646 410-684-255C 0 1 A That is correct. 2 Q Does the distribution -- strike th 3 Does Rockwell have, I guess, 4 subdistribution centers that might be under t 5 Florence facility in different states? 6 A Owned by Rockwell? 7 Q Yes , 8 A The Hayward facility inCalifornia 9 existed at one point in time. 10 Q Any other ones that you know of? 11 A The other Worth American one is th 12 irampton, Ontario. 13 Q That is it? 14 A That is it. 15 Q The Florence distribution, did it 4 1 6 nyone who placed an order, or did it have to 17 :ertain type of company, wholesaler, retaile:18 ,ave to be just any individual ordering theso 19 'hat qualified someone to order parts from th 2 0 'lorence facility? 21 A They had tobe an approvedcustome;' 22 Q What criteria was it to get approvn Ace-Federal Reporters, Inc. Nationwide Coverage 2U2-347'3700 WXJ-336-6646 410-664-25Sq 0 1 A I don 11 know. 2 Q Who approved those particular cust<t> 3 A I am uncertain exactly. 4 Q While you were at the Florence fac 5 'ou remember any other sales to other than 6 rholesale-type operations, such as other sup^ 7 ither distributors which might be independent B ifiople call them jobbers, maybe? 9 A Warehouse distributors? 10 Q Right, warehouse distributors. Do 11 emember any sales to individual-type compan:. 12 hen I say individual, those that are doing t. 13 hemselves, or was it always to another 14 arehouse-type distributor, or a jobber, as 15 ; call it , 1 16 A The FIlorence facility sold to WDs a 17 EMs . IB Q And no 19 A Wo ione 20 Q Let me 21 ity rece ive 22 ake lini:ngs Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 H00-336-6&46 410-65H-255I! 0 1 A I am uncertain. 2 Q Did the Florence facility ever rec 3 jroducta that it put its name on, and actual 4 elabeled the product as a Rockwell product? 5 re are talking about brake pads, brake lining 6 irake shoes. 7 A Could you repeat the question. 6 Q Did the Florence facility ever rec*: 3 'roducts that it may have relabeled as its ov 10 t received directly from a supplier and sent 11 istribution facility and sold to distributio 12 acility, WD, the wholesale distributor? 13 A Product that we received from othei 14 ianuf acturers, we put into Rockwell boxes, ai. 15 oxes had Rockwell labels on them? 16 Q Which manufacturers that you can 17 emember -- and we might have covered some th 18 .orning -- that you received those types of ]i 19 ctually relabeled them and put them in Rockw 2 0 oxes, such as Abex. 2 1 MR. CALI: Object to the form. 22 THE WITNESS; To the extent that p Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 U0O336-6646 410-6W4-255C 71182.0 WSCsjg c 51 o 1 was boxed, it was all products placed and labeled in 2 Rockwell boxes and labeled with the Rockwell label. 3 BY MR. ROUSSEL: 4 Q When you were at the Florence facility, do 5 you remember ordering and receiving any Abex brake 6 linings or brake pads or brake shoes that you 7 relabeled as a Rockwell product and put in your 6 boxes? 9 A To the extent that we would have received 10 Abex product, right, and would have packaged it, it 11 would have generally -- would have been in a Rockwell 12 box, in a box that had a Rockwell label. 13 Q Did the Florence facility order those types 14 of individual items such, as Abex brake linings? 15 A I am uncertain. From Abex? 16 Q Yes, Abex. 17 A I am uncertain. IS Q Do you remember if the Florence facility, 19 when you were working there, ordered any products 20 from Motion Control Industries and relabeled those? 21 A 1 am uncertain. 22 Q When I say Motion Control, do you c Ace-Federal Reporters, Inc. Nationwide Covniagn 202-347-370(1 800-336-6646 410-684-2550 71182.0 WSCsj g 52 [understand that can also be Carlisle Corporation; is that correct? A No. Q Then I will ask the next question. Do you [know if the Florence facility ever received any brake linings from Carlisle Corporation that it relabeled and placed in the boxes? A To the extent that they would have received Carlisle linings, they would'have been placed, as all the other product was, in Rockwell boxes and labeled with a Rockwell label. Q Was it the normal practice of that Florence facility to order brake linings from suppliers and Iplace them in Rockwell boxes? MR. MlKULAr Objection, vague. THE WITNESS: 1 don't recall whether we 17 ordered the linings directly from the lining \ manufacturer. However, linings that were received 1 I* there would have been - - as with the other product, would have been placed in Rockwell boxes and labeled with a Rockwell label. BY MR. ROUSSEL: Ac.e-Federal Reporters, Inc. Nationwide Coverage 20Z.347.3700 800*356-6646 4lO-684-25f0 1 71182,0 wscsjg 53 Q My understanding is that Rockwell Idid not manufacture any asbestos brake linings; is tlhat correct ? A That's correct. Q Did Rockwell manufacture any brakei linings at all except at the South Carolina facility? A No, . Q So any product that you would have, received, as far as an asbestos brake lining:, at the Florence facility would have been from an outside vendor; is that correct? A No . Q How is that incorrect ? i A The linings may have come t o 1 f rom one of our production fa 16 Q But the production facili ty I / make that product? I A That's correct. 1 P Q It actually was manufactured bysome other i2 0 third party? 2 A That is correct. 2-2 Q Now, the Florence facility,would ithey Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-330-6M6 410-6B4-2550 I 54 1 relabel -- if they would have come in, were ithey 2 relabel ing asbestos-containing brake linings|? > A Could you define 11 relabel ing , " . Q Putting them in a Rockwell box. ' i A Yes . r Q How long did that continue? 7 A For the period of time for which w;e were i: Rockwel 1, and for the period of time for which we 9 were di stribut ing or boxing asbestos- con ta i niing 10 product 3 . 11 Q And Rockwell continues to sell brake 12 linings, just the linings themselves, today;1 is that 13 correct ? 14 A Could you repeat that. 15 Q Does Rockwell continue to sell brajke 16 linings , just the lining, today? 17 A Meritor does, yes. 18 Q Meritor, excuse me. And then Rocklwell, of 19 course, continued until 1997 to sell brake linings? 2 0 A That is correct. 21 Q What were the particular uses for those 22 brake 1 inings ? Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-2550 0 55 1 A Out of which facility? ' 2 Q Out of the distribution, Florence,: 3 faei1ity. 4 A Those were service and repair partis. 5 Q Did Rockwell do any type, at any off these 6 facilities, any type of remanufacturing of fcjrake 7 parts? a MR. MIKULA: Objection, vague. No;t to the 9 best of my knowledge. 10 BY MR, ROUSSELs 11 Q Were you familiar with Abex Corporation; 12 are you f amiliar with that name? 13 A Iknow the name. 14 0 Do you know if it's the same compaJny as 15 American Brake Blok, B-l-o-k? 16 A I don't know. 17 Q Now, let's see, we are going to stjart 18 getting i nto all of these documents, 1 9 MR. ROUSSEL: Off the record. 20 (Discussion off the record.) 2 1 MR. MIKULA: This is Tom Mikula, fior those 22 f you on by conference call. I will ask my Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-2550 I 0 56 1 secretary to make arrangements to have anotbjer 2 conference call convened in approximately ode hour; 3 is that okay? 4 MS. ECHOLS: Yes, that's fine. 5 MR. KNIGHT: That1a fine. : 6 MR. PERRY: That's fine. 7 MR. KNIGHT: That's fine, hut if yiou would 8 tell your secretary to notify Bill Brockman lin my 9 office, because I am headed out to another 10 deposition. ll MR. MIKULA: Could you give me your number, 12 please. 13 MR. PERRY: (504} 834-2612. I appreciate 14 it very much. , 15 (Whereupon, at 11:55 a.m., the deposition 18 was recessed, to be reconvened at 1:00 p.m. this same 17 18 19 20 21 22 Ace-Federal Reporters, Inc. ; Nailonwide Coverage 2UZ-34?-3700 640-336*6646 410-664*2550 i 0 57 1 AFTERNOON SESSION (l:j07 p.m.} 2 Whereupon, 3 BRUCE KETCHAM 1 4 resumed the stand and, having been previously duly 5 sworn, was examined and testified further as! follows 5 6 MR. ROUSSEL: Everyone there? _ 1 MS. ECHOLS: Yes. ` 6 MR. BROCKMAN: Yes, yes. : 9 MR. PERRY: Yea. 10 BY MR. ROUSSEL: 11 Q Mr. Ketcham, I missed a couple of icompanies 12 I wanted to go bade and cover with you earlifer. 13 Did Rockwell International Corporation ever 14 purchase any parts from United Brake Systems;, 15 Incorporated? ' 16 A Not that I am aware of, : 17 0 Do you know if Rockwell International ever 18 sold any parts to United Brake Systems, Incorporated? 19 A Not that I am aware. 20 Q Did Rockwell International ever purchase 21 any parts from Prattville Manufacturing, 22 Incorporated? Ace-Federal Reporters, Inc. ' Nationwide Coverage Z02-347-3700 BOD-336-6646 4lQ-6B4*255fl 0 58 1 A Not that I am aware of. 2 Q Do you know if Rockwell ever sold iany parts 3 to Prattville Manufacturing, Incorporated? : 4 A Not that I am aware of. 5 Q Do you know if Rockwell ever purchased any 6 parts from Genuine Parts Company? 7 A Not that I am aware of. ' 9 Q Do you know if Rockwell ever sold any parts 9 to Genuine Parts Company? 10 A Not that I am aware. ; 11 Q Do you know if Rockville ever bought any 12 parts from Raymark Industries, Incorporated?' 13 -- A Not that I am aware of. 14 Q Do you know if Rockwell ever sold any parts 15 to Raymark Industries, Incorporated? 16 A Not that I am aware of. 17 Q 1 am just going to mark for the record the 18 notice of deposition of Mr. Bruce Ketcham scheduled 19 for today at 10:00 a.m., as Exhibit Number 1|. 20 (Ketcham Exhibit 1 identified.) 21 BY MR. ROUSSEL: 22 Q Mr. Ketcham, I want you to look at a Ace-Federal Reporters, Inc. Nationwide Coverage 20Z-.W-37D0 800-336-6646 410-6S4-255Q 0 59 1 memorandum I received from an attorn ey for Rjockwell, 2 name of Hugh Glenn. Could you look at this ,j and tell 3 me if you had any input into coming up with la chart 4 that's on page 2 of the memorandum. 5 A Yes . 6 Q What input did you have in coming jup with 7 these particular quantity of brake shoes and! air disc a brake lining kits? 9 A I believe that I provided the basijc data 10 that allowed that particular compilation. 11 MR. ROUSSEL: I want to attach that 12 document as Ketcham Number 2. 13 (Ketcham Exhibit 2 identified.) ! 14 BY MR. ROUSSEL: 15 Q Mr. Ketcham, 1 want to show you another 16 document that was presented to me this mornihg, I 17 think, which reflects more details of what 1s1 been ia shown on this chart. 19 Could you tell me exactly what thife 20 articular document reflects. 21 A This indicates sales by part numbep to 22 customers here, Fleet Parte, Heavy Duty Parts -- Ace-Federal Reporters, Inc. Nationwide Coverage 2O2-347-37O0 BOO`336-6646 410-684-2550 i 0 60 1 :heir address and names, I believe, are more' 2 rompletely reflected in the other document and 3 spreads the sales to them across from `78 thjrough *92 4 tfhen they occurred by year. . 5 Q Again, you had input into development of 6 :his document? 7 A Yes. a Q Let me ask you, what other wholesale 9 iistributors did you research besides Fleet iParts and 1 0 leavy Duty Parts? : 11 A As I recall, there was a question, I 12 jelieve it was in a - - either interrogatory ;or 13 locument request, that elicited several company 14 tames, and we researched against those company 15 tames , 16 Q Of those names, these are the only, two that 17 'ou found sales to? 18 A Those were the two, although I bellieve that 19 ierhaps the corporate names didn't exactly m^tch the 2 0 lames that were requested. These were the stales to 21 hese two entities. 22 Q I want to attach this as Ketcham KTUmber 3. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 iHK>-336-6646 410-6&4-255Q i 0 61 1 Looking at the past numbers here; do you notie whether 2 or not particular kits or parts contained asjbeatos, 3 as far as the brake linings, brake shoes, brjake pads, 4 if any? ; 5 A Yes, that was the purpose of the sjearch, to 6 identify part numbers that contained . 7 asbestos - containing materials. e (Ketcham Exhibit 3 identified.) : 9 BY MR. ROUSSEL: ! 10 Q Do all of those particular part numbers 11 here contain those identified materials? ; 12 A Yes. ' 13 Q Mr. Ketcham, I am going to show you what's 14 been identified by a Bates stamp number as Rp 00004. 15 Mould you tell me what this particular item is, what 16 that material data sheet identifies. 17 A It's a material safety sheet for dji.sk brake T 18 linings. 19 Q Was that an alternative product to; 20 asbestos-containing brake linings? 21 A Could you repeat the question? 1 22 Q Was that an alternative product thfrt was Ace-Federal Reporters, Inc. Nationwide Covyrafto 202-347-3700 tfW-336-6646 470-6S4-255P 0 62 1 being used at that time to asbestos-containiing brake 2 linings? 3 A This is for air disc brakes, the pjads for 4 air disc brakes. : 5 Q At the time, did the pads for air jdiac I 6 brakes contain asbestos? ` 7 A The pads on air disc brakes at one; time a contained an asbestos backing material. However, the 9 lining material itself has always been made pf 10 nonasbestos materials. . ii Q To your knowledge, does the pads o|i air 12 disc brakes ever wear down to the backing materials? 13 A In normal use, it would not, 14 Q What do you mean by normal use, coiald you 15 define them. ; 16 A The pads are supposed to be replaced when I 17 they reach certain wear limits, and as long fcs the 18 pads are replaced at that point in time, the;backing 19 plates should not be exposed* 20 Q What is the backing plate? , 21 A Or backing material, excuse me. 22 Q Could you describe to me the backing Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800*336*6646 470*684-2550 ! j 63 I 1 material. What is that? i 2 A I believe it is a type of mesh matjerial to i 3 which the lining material is attached, it supplies ! 4 the backing or basis or bonding strength to jthat i 5 pad. ' 6 Q Is it actually bonded to the disc ibrake 7 itself or, I mean, the air brake itself, or -is it a another material used to bond the backing material to *j 9 the disc brake -- I mean, to the air brake? ! 10 A The backing material is incorpora tied in the 11 air disc brake pad. 12 Q How thick is that material? i ; 13 A Which material? 14 Q The backing material. ; I . 15 A It's relatively thick. I don't knpw the 16 dimensions. 17 Q When you say thin, quarter inch, 1 j/ 8 inch, 19 1/16? 19 A I don't know the dimensions. ; 20 MR. ROUSSEL: I would like to attach this i 21 document as Number 4. 22 {Ketcham Exhibit 4 identified.) Ace-Federal Reporters, Inc. Nationwide Coverage ' 202'347'37tH) B0QJ36`6W6 41U-6B4-255Q 0 64 1 BY MR. ROUSSEL; ! | 2 Q I am going to show you a document jwhich 3 says "Material Data Sheet for Bonding Strip pn Disc 4 Brakes." Would you describe to me what a bonding 5 strip on a disc brake is. Would you take a [look at 6 that document. 7 A This is the backing strip thatI w^S 8 referring to in my prior testimony. 9 MR. ROUSSEL: Thank you. 10 I would like to mark that as Ketch^m Number 11 5 . 12 (Ketcham Exhibit 5 identified.) 13 BY MR. ROUSSEL: i 14 Q Do you know at what time Rockwell s: 15 discontinued using asbestos-containing backing 16 material? ; 17 A Not precisely. ' 18 Q Approximately? _ 19 A My estimate would be in the late '^0s or i 2 0 early '90s. : I { 21 Q What type of brake assemblies doesjthis 1 22 backing material come on? Did it come on thp lining i i Ace-Federal Reporters, Inc. ; Naltonwide Coverage [ 202-347-3700 800-336-6M6 410-6514-2550 0 65 1 itself? 2A 3 itself. 4Q 5A 6Q It was embedded in the lining matejrial i i Who put that material on the lininjg? The lining manufacturer. : Did Rockwell ever manufacture any packing 7 material? a MR. MIKULA:~ You mean asbestos-containing 9 backing material? 10 MR. ROUSSEL: Yes. 11 THE WITNESS: No. : J ' 12 BY MR. ROUSSEL: : 13 Q I would assume that Rockwell did 1 14 manufacture backing material at the South Carolina i 15 location at some part in time? j 16 A I am not certain. 17 (Ketcham Exhibit 6identified.) 18 BY MR. ROUSSEL: : 19 Q I am going to show you what's beenjmarked i 20 as Ketcham Exhibit 6. Will you tell me what this 2 1 locument is identified by RD 00047, as far the 22 Bates stamp and continuing thereafter? ' i Ace-Fedf.ral Reporters,' Inc. Nationwide Coverage ;i ; 202-347-3700 BOO-336-6646 41O-6S4-2S50; 0 66 1 A It's a material safety data sheet,j appears i 2 to be for Motion Control Industries, a divisjion of l 3 Carlisle Corporation, 4 Q Does that document reflect anyplacje that 5 Rockwell actually purchased this particular jitem from j 6 Motion Control Industries? ; I 7 A No, it does not. ; i fi Q How about the first page of this pjarticular 9 document identified as RD 00046? j 10 A Yes. 11 Q It does indicate that Rockwell daejs buy I 12 this product from Motion Control Industries;! is that 13 14 A The document speaks for itself. I); says, 15 "Enclosed are material safety data sheets fo{r brake 16 linings which are used on trailer axles sent; to your 17 company, amongst other things. 11 . 18 Q Does this particular what particular i 19 product is identified on this material safety data 20 sheet? 21 A The material safety data speaks ofibrake 22 lining, has after that CAS No. 1332214, and fa trade Ace-Federal Reporters, Inc. = Nntiunwidu Covorayt; 2(12-347-3700 8tfl.336.6646 410*684-2350, 0 67 1 name, and synonyms listing Carlisle brake li ning . 2 Q Does that material data sheet identify that ! 3 that particular brake lining contains asbestjos? 4 A There is a statement here that states# 5 "This compound contains asbestos with varying 6 percentage in individual product formulas." : 7 MR. ROUSSEL: I am going to attach; that as B Exhibit Number 6. _; 9 MR. CALI: Off the record. i 10 (Ketcham Exhibit 6 identified.) : 11 {Discussion off the record.) ; 12 EXAMINATION 13 BY MR. CALI; ; 14 Q Mr. Ketcham, again, my name is Mik^ Cali. : 15 I am here for Abex and Motion Control. 16 Referring to Exhibit 6, that we ha\re i 17 previously discussed, was this document produced in : 18 connection with the written discovery response in 19 this case by Rockwell? : 20 A I don1t know. ': 21 Q You don't know where it came from?; 22 A No. i i Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 600436-6646 410.684-2550, 0 ee 1 Q Do you know what product the MSDS Irefers 2 to, in particular, brake linings on. an axle;j are you 3 familiar with that type of product? 4 A Would you reask thequestion, | compound, 5 Q The way it's phrased, a brake lining on an 6 axle seems to be kind of an unusual application. i I 7 just want to know if you are familiar with that, and 8 could you tell me a little bit about it, if j/ou are. 9 A Yes. i 10 Q Could, you, please. i 1.1 A In some instances, when we manufactured our [ 12 axles, be they trailer axles or front axles fc>r drive 13 axles, we assembled the brake components andjbearing 14 configurations on that axle and shifted to a' 15 production customer. 16 Q The brakes in question are designeji to 17 provide friction to the axle itself and not to a 18 rake drum or well? ! i IS A Wo, it's to apply the friction product 20 against a drum or against a disc. However, jrhey are 21 counted to a brake spider, which is attached;to the 22 axle . . Ace-Federal Reporters, Inc. : 202-347-3700 Nationwide Cove/age B00-336-6646 . 4l(Mtt4-2S5(j ! 69 1 Q Is the product that's referred to |i n this 2 MSDS a product that Rockwell sold as opposed! to its 3 own business for use in its trucks, for instance, or 4 do you know? j I 5 A We have a very limited truck fleetj in our 6 sales. The cover letter appears to indicate]that it 7 was sent to people because it was sold to thpm as a customers < 9 Q So what you are saying is it was probably 10 an item that Rockwell sold at one point or another? 11 A That would be my interpretation, y^s . 12 Q The exhibit that you produced prev jLously, 13 Number 3, whic h I think listed several part jiumbers 14 identified as having been sold at one time o jr another 15 to either Flee t Parts or Heavy Duty Parts * d lies this 16 product - - whe n I say this product, I mean t he one i 17 referenced in Exhibit Number 6, the MSDS _ - jioes this 18 product appear in the list that you have giv $n i us in 19 Exhibit 3 , or can you tell? 1 20 A Can I tell from Exhibit Number 3 i ni 21 comparison. to Exhibit Number 6? 22 Q You cannot tell? Ace-Federal Reporters, Inc, I Nationwide Coverage 202-347-3700 800-336-6646 410-684-255ti 0i 70 1 A From those two exhibits, I cannot {tell. 2 Q Do you know, of your own knowledge!, whether 3 or not this Exhibit Number 6 product is one {of the i 4 products that we would identify as possibly joeing - having been sold to Fleet Parts or Heavy Dut^ in 5 6 Exhibit Number 3, i 7 A As I sit here, no, I do not know. : 8 Q Ts that information obtainable? . I 9 A I believe it was obtainable. t i 10 Q It was at one time? I'm sorry. 11 A Yes. I don't understand your question 12 Q You mean it's no longer obtainable!? 13 A No. : 14 Q Okay. I 15 A No, it's not - 16 Q Okay. ; 17 A Ask your question again. ; 18 Q Gan we find out whether or not the]products 1! 19 Listed in Exhibit Number 6 are also referenced in 2 a Exhibit Number 3? | 21 A I am uncertain because the data ehfeet right 22 theredoes not listlining mixes. ; Ace-Federal Reporters, Inc. . Nationwide Coverage 202-3470700 800-336-6646 410-684-2550, 0 71 1 Q So you can't testify as to whether or not 2 this product in Exhibit Number 6 ever got to Fleet I 3 Parts or Heavy Duty, can you? ! 4 a no, : 5 Q The product that we discussed, aolji by 6 Rockwell where the brake linings were sold ih | 7 connection with or attached to the axle, somewhere or 8 ir, i a that, in your belief, i s that a Jrar e 9 .ion i or was it very common, or can you i say j 10 :T 0 r not ax]L e s were generally sold a 11 che 1 11 an d vice versa i 12 I t just s t r ikes me - - I am not an txpe l i 13 typ es of parts, but it strikes me a s k j.nd 14 rare situation. Can you tell me or not whether or t 15 not that's correct? t 16 A What is your definition of "rare"?- 17 Q Okay, uncommon. The other way arojmd would i 18 oe more common, whether the two components w^re sold I 19 separately, ! i 20 A It would be more common for the products to 21 :e sold separately. j i 22 Q Can you tell me whether or not the; Ace-Federal Reporters, Inc. j Nationwide Coverage ' 202-347-3700 H00-336-6646 41C-684-255Q i 0 72 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 IS 19 20 21 22 application where they are sold together wasj destined Eor any particular brand of vehicle? For instance, i ''as it only sold for Ford trucks or a type ojf truck, Like only flatbed trucks? ! Do you understand what I am getting at? ?as it across-the-board, light, medium, heav^-duty trucks, et cetera? j ! A It would probably be more prevalent for the i small vehicle OEMs to purchase their product^ with brakes attached. The larger OEMs that we soj.d to, .he Fords, .ypically, GMs, Volvos, major truck manufactprers, i got their axles and brakes separately. .hat Q Would would have this been I particular product have!been one i sold almost exclusivelyto an 'EM as opposed to for aftermarket use? A Could you repeat the question. Q Yes. Would this axle brake union product ave been one that Rockwell would have sold to an OEM or use in the construction of a vehicle -- . A Yes. ; Q -- as opposed to the exclusion of pold over he counter to a place like Heavy Duty or Fl^et Parcs Ace-Federal Reporters, Inc. : Nationwide leverage ! 202-347-3700 MXK336-6646 410-684*2,550 0 73 1 to be used to repair a vehicle? Or either, |could it 2 be either way? i 3 A To Heavy Duty, Fleet Parts, or replace 4 Heavy Duty or Fleet Parts? 5 Q The latter, the to replace Heavy Djity or 6 Fleet Parts, : A It is possible that the distributoj: of 7 S trailer and brake parts may get a trailer axjLe that already had the brakes on them. 9 That is probably, t in 10 my opinion, less common than more on them, 11 Q You referenced smaller OEMs. Can j'ou give 12 me an example -- do you mean smaller vehiclep or a 13 smaller company? : 14 A A smaller company, manufacturing vehicles. 15 Q Can you give me an example? 1 16 A Hot as I sit here. \ i 17 Q Mack Truck, for instance, would th^t be 18 larger or smaller? ' 19 A That would be a larger. t MR. CALI: That's all I have, thanjc you. 20 21 EXAMINATION CONTINUED ! 22 BY MR. ROUSSEL: ` Ace-Federal Reporters, Inc. : Nfllionwide Coverage 202-347-3700 BOO-336-6646 410-6M-255O; 0 74 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q Mr, Ketcham, I want to show you whjat will 3een marked as Ketcham Exhibit 7. Can you tjell me i tfhat the document represents and whether youj l recognize the individuals at the bottom as Rjockwell employees? A Your question again, please. ! : t l ! I Q Yes. Do you recognize the people |at the jottom of the document as Rockwell employees!? A Some of the names I recognize as bjeing Rockwell employees, : i Q What does this document -- what is| the i lurpose of this particular document, which w|e are [oing to mark as Exhibit Number 7? j A I believe the document speaks for jLtself, 'he title is "New OSHA Asbestos Hazard Regulation." i Q I think the document reflects that! starting n February of 1986, Rockwell will begin to jaend out iaterial safety data sheets on all of its asbestos inings to its customers; is that what this jiocument eflects -- or to its aftermarket customers,j anyway? A ware, As the first sentence states, the new MSDS asbestos regulation "As you i affejrts are our Ace-Federal Reporters, Inc. ; Nationwide Coverage ' 202-347-3700 800-336-6646 410484-2550: I i ! 0 75 1 service business, as we supply asbestos linings for 2 she aftermarket." 1 i 3 Q Let me ask you, do you know if Rockwell was I 4 sending out MSDS sheetB to this particular directive, 5 :o its aftermarket customers. 6 A I do not know, however, this epeak^ of a | 7 lew MSDS regulation, so it is quite possible!that i 8 ihis came about as the effect of a new regulation. 9 BY MR. ROUSSEL: 10 Q I want to show you what's going tojbe 11 larked as Ketcham Exhibit 8. Could you takeja look 12 it this document and tell me what its purpoa^ is. I 13 A Again, the document speakB for itself. The ii 14 :over letter that is attached to the balance!of the i r 15 lacumenta indicating that we are transmitting certain 16 laterial safety data sheets to our customersjin i 17 :ompliance with the OSHA Hazard Communication 18 standards CFR 1910.1200. > 19 Q That particular letter is in compliance i 20 rith the directive of Exhibit Number 7 that |ou 21 ooked at earlier? 22 A I can't speak - - : : Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 BOO-336-6646 410-684-2550: 0 76 1 MR. MIKULA: Do you want to read q:his 2 document again? j 3 THE WITNESS: No, I have seen it. j 4 I can't apeak to the interrelationjehip of 5 the two documents other than that they are bjoth I 6 discussing, at about the sameperiod of time), the 7 transmittal of certain MSDS sheets. a BY MR. ROUSSEL: \; 1 9 Q Exhibit Number 8 has Bates numbers! RD 55 10 through 73. I want to show you what is Exhibit i 11 Number 0, RD 56. Can you tell me what -- whjs is the j 12 manufacturer of this product, and what is it! used 13 for? 14 A The sheet appears to list Allied 15 Corporation Automotive Sector, Bendix Friction ! 16 Materials Division, and the products discussed here t 17 is a brake block formula B-4123. i 18 Q What is that used for? What is thut 19 particular product; do you know? I 20 A 21 slock. It states on its face that it's a j^rake i : 22 Q What is a brake block? Where is used? Ace-Federal Reporters, Inc. i 202-.W-37Q0 Nationwide Coverage 8IXM36-AM6 ` 410-6S4-255o! 0 77 1 A A brake block, it would be my ; i 2 interpretation that we are talking about a birake 3 lining, synonymous, 4 Q Does this particular document identify any 5 asbestos warnings on it? ' 6 A There is a caution statement listed on the 7 document, it says, "Contains asbestos fibersi. Avoid 8 creating duet. Breathing asbestos dust may bause 3 serious bodily harm." 10 Q Do you know, what is the date of that 11 document ? 12 13 page? MR. MIKULA: Speaking about just that ' 14 MR. ROUSSEL: Mo, I think it's a two-page 15 document. 16 THE WITNESS: The one date listed on RD 17 00056 states that it was filed on November 1985, 18 BY MR. ROUSSEL; 19 20 21 22 Q Again, I am going to show you what^s part 3f Exhibit 8, RD 00058 through 59. Could yofc tell me .vhat product is identified here. A This appears to be a material ' i safety data Ace-Federal Reporters, Inc- Nationwide Coverage 202-347-3700 WXKU&-6646 410-604-2550 1 0 78 1 sheet compiled by Motion Control Industries^ i 2 Carlisle. The first sentence states that Cajrlisle 3 brake lining is a resident - bonded product, sjo one 4 would assume that it dealt withbrake liningj 5 material. : 6 Q Does it show that asbestos is a component ! 7 of that particular product? . a A Yes. 9 Q Let me ask you, there's a section jiere that 10 identifies/ that's called "Identify," it's a- number 11 of numbers. Could you tell me what these nujnbers 12 stand for, or numbers and letters? . 13 A I do not recognise them. . i 14 Q Do you know if there are Rockwell Jpart 15 numbers? 16 A They do not appear to be Rockwell >art 17 numbers. 16 Q Why is that? 19 A A Rockwell part number is generally a - 20 particularly a part of nomenclature. These jiumbers 21 here do not appear to be similar. ! ' I 22 Q Do you know on which types of products this Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-6&4-2S50: 0 79 1 particular brake lining is used at Rockwell?: i 2 A No . j 3 Q Can you tell from that data sheet?! This is 4 a twO'page document. 5 A Could you repeat the question. ' 6 Can you read it back.. 7 fThe reporter read the record as requested.) : THE WITNESS: . No, beyond being brake 8 9 . ining. 10 BY MR. ROUSSEL; * 11 Q I am going to show you another Carlisle 12 lafety -- material safety data sheet. Can ypu tell 13 te the difference between the first one and jihe one 14 hat starts at RD 60 through 61, if you knowj. 15 A Which ones did you wish me to compare now? 16 Q This one, with the one you just previously 17 ooked at, two pages before. 18 A And the question again was? ' 19 Q Do you know of any difference, maybe in the 2 0 pplication of the first to the second? ; 2 1 A The first one, starting with RD 00()58, 22 ppears to be a material safety data sheet f<pr Ace-Federal Reporters, Inc. Nationwide Coverage . 202-347-3700 800-336-6646 410-684-2550, i I X asbes tos - containing brake lining; whereas, tjie one i 2 marked and beginning with RD 00060 appears tb be a 3 material safety data sheet for nonasbestos bjrake 4 lining material. : i 5 Q Do you know if the two linings, bejing one asbestos and one not asbestos, has any different 6 7 application; in other words, do they go into! the same a particular assemblies, or do they go into solne ; 9 different type of assemblies? : 10 A They appear to be brake lining material, 11 and brake lining material is used in various 12 different applications. So, you know, thereiis quite 13 possibly not a one-for-one correlation between one is 14 over here and over here, 15 Q Let me ask you, when you say a bra^e lining 16 material, when you received that material fr<j>rn 17 Carlisle, from other manufacturers, does Rockwell i 18 have to do something to that material to make it fit 19 the break assembly, or is it molded in such way 20 that all you have to do is screw it in or boftd it in? 2 1 A in what period of time are you talking 22 about? Ace-Federal Reporters, Inc. Nationwide Coverage , | 202-347-3700 800-336-6646 410-684-2550 0 81 1 Q From 1970 to present. If it's ghajnged, 2 just let me know. . 3 A I would say at one time it was projbably 4 reasonably prevalent that grinding of a brakje lining 5 material was required. At a later time, tha|t 6 grinding was no longer required, or at least: was 7 minimi zed. 8 Q When did grinding stop? Is that a. recent 9 development? 10 A I am not certain of an exact date.' 11 Q 1990s, estimate, 1995, somewhere ih there? 12 A Based upon what I recall, I believh that 13 the elimination of grinding would have occurred, 1.4 probably, in the early '80s. ' 15 MR. MIKULAj May v/e take a short bjreak. 16 (Recess.) 17 BY MR. ROUSSELi ' 18 Q Mr. Ketcham, I want to ask you a ljittle bit 19 bout some of these other documents attached^ some of 20 hese MSDS documents. 21 Attached at RD 62 there's an Abex ! 22 corporation material safety data sheet for a. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-2550: 0 i 82 i 1 nonasbestos product. Can you tell me, can yj^u look 2 at this and tell me what that product is? 3 A There is an identity section on thp page 4 that lists a number o numbers and letters. \ 5 Q Do you know if that's brake lining^ l 6 A Some of the numbers and letters appear to 7 indicate that. . 8 Q The letters and numbers that you referred 9 tor is that Rockwell's numbering system? : 10 A "No. ' 11 Q How do you kno w that that is brake!1ining 12 f rom the numbers and let ters that appeared; $re you 13 f ami liar with th ose part icular numbers and letters? ared, with some of tljie 14 A Again, it appe 15 iden tifications such as, as an example, ABB2^69ff, 16 that the ABB and , follow ed widely, FF, were some - 17 with some number s in the re, is a common type\of ie desi gnation for Abex lin ing mix. 19 Q And th e letter that references, tht attach 20 thos e pages, tho se were addressing MSDS sheets for i 2 1 brak e linings; i s that c orrect, the cover letter? 22 A Cover let ter. Again, though, the over Ace-Federal Reporters, Inc. ' Nationwide Covers ge 202-W-3700 800-336-6646 410-684-2550, 0 83 1 letter speaks for itself that we are providing new 2 material data safety sheets from our asbestojs 3 providers. ' 4 Q Let me ask you about the next MSDS; data 5 sheet; RD 65 through 67. Again, it's an Abek 6 Corporation material data safety sheet for asbestos 1 products, It lists a number of serial numbers again, 8 or part numbers. . 9 Again, could you look at those particular 10 part numbers and tell me what particular product this II is referring to? . ! 12 A Again, there is an identity block on the 13 page that lists a series of numbers and letters, Its 14 format appears to resemble lining mixes. 15 Q I am going to show you another Abe# 16 Corporation material safety data sheet at RD' 71 17 through 73. And, again, for aBbestos-contaitiing 18 material, could you tell me what this particular -- a 19 particular label and identities there represent? 20 A Again, they appear to have the forjnat of an 21 ^bex lining mix. i 22 Q Do you know, what is the difference between Ace-Federal Reporters, Inc. , Nationwide Coverage 202-347-3700 800-336-6646 410-684-2550. 0 84 1 2 3 4 5 6 1 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 :his particular data sheet, that set of numbers, and ;he prior one shown on 65? That should be 7|i there. A Again, I believe that the documents speak for themselves. A reasonable, yet not thorough, :omparison between the two indicates the following iifferences. The identity block on page 1 wp with lifferent items in it. The specific gravity1 in section 3 on page 1 is also different. Q with respect to page 4, some of the health lazards as listed in section 6f language is plightly Lifferent. . li-eets. I am looking at those two different Can you tell the different -applications that hose two different products are used in? 1 A Again, it would appear as though they are ised in brake linings, and the one is for asbestos 1 .nd the other appears to be for nonasbestos linings. Q I think the other one is also for Asbestos, s it not? MR. CALI: Object to the form, Perry. 'here are several different products. _ THE WITNESS: Perhaps we should separate Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-37IX) 800-336-6646 410-684-2550! I 0 85 1 the pages. 2 BY MR . ROUSSEb; Q3 70 and 71 . 4 A Or word -by-word anal 5 them? ' 6 Q I hate to separate it because that set of 7 documents came in as a group like that; it w&s a attached to that letter. 9 A If you are asking for my analysis knd 10 comparison from one document to the other document, I 11 would prefer that, at least for my review purposes, 12 that they be separated. 13 Q We can do that and staple them back. 14 A All right. 15 Q Can you tell from those specific documents 16 what those particular linings might have been used 17 in -- as far as products of Rockwell, those * 18 particular products linings might have been used in? 19 If you can, we can go ahead and unstaple the(n. 20 A These are a pair of lining mixes. sAs I sit 2 1 iere, I do not know which particular products they 22 were used in. Ace-Federal Reporters, Inc. ' Nationwide Coverage 202-347-3700 HK>-336-6646 410-684-255Q 0 86 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 16 19 20 21 22 Q When you say ''lining mixes, 11 how dan we equate a lining mix to a particular Rockwell! product :hat might have been produced? A What Rockwell product are you referring :o? Q Anyone that might have used that pjarticular .ining mix, that lining. A The -- for a particular Rockwell lining ind/or lining that would be attached to a shoe for ihat particular lining, we would have, in our records, the lining mix that was associated y/ith that .ining Q part number. % In other words, the part . numbers tjiat were .dentified earlier on Exhibit Number, I think it is .et r s see i f you pull it , 0 0 1 Hi ling mix; is that ect? A No , These appear to ass embly is a li ning, all : 0 All right. A Tha t 1:ining part numb : as sembli es woul d be assoc Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-37D0 800-336-6646 410-684-2550| 0 87 1 Q Does any particula r part go with a; specific 2 kit number, or are they inte rchangeable part.'e that 3 would go with a kit? 4 A I don't know if I can answer the question. 5 Q In other words, if I asked you for- all of 6 the part numbers in that kit , you could supply those; 7 is that correct? 8 A That is correct. _ 9 Q For a specific point in time, before any 10 ngineering changes were made? 11 A That is correct. 12 Q Once you supply that particular list of 13 arts, you could identify which particular lining mix 14 ent into that particular part number; i3 that 15 orrec t ? 16 A You can go from that particular part number 17 f that lining to a lining mix, yes. 18 Q Mr. Ketcham, I am going to show yoy a list 19 f organizations. 20 MR. CALI: Perry, before you go on, can I 21 ak you a few questions with regard to number 8? 22 MR. ROUSSEL: Sure. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-2550 0 88 1 EXAMINATION 2 BY MR. CALI: . 3 Q Mr. Ketcham, without: doing research, you 4 can't tell us what Rockwell parts, if any, utilized 5 the -- either the Motion Control or the Abex. i 6 materials referenced in the MSDS sheets attached 7 globally under number 8, can you? . 9 A As I sit here today, from my memory? 9 Q Yes . 10 A No. 1 1 Q Do you know whether or not any of those 12 Motion Control or Abex materials were used in any of 13 the part numbers indicated on Exhibit 3, i,e\, those 14 products sold to Heavy Duty and Fleet Parts?.- 15 A As I sit here right now? 16 Q Yes, 17 A With no additional information? 18 Q Yes 19 A No, I don 1t. 20 Q You could find out; you just don't1know at 21 this particular deposition? 22 A That is correct. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-4<i 410-684-235(5 89 1 2 3 4 5 6 7 e 9 10 11 12 13 14 15 16 17 18 19 20 21 22 MR. CALI: That's all, j MR, ROUSSEL: Off the record for a1 second, {Discussion off the record.) ' BY MR, CALI: e Q I'm sorry, let me follow up with one or :wo . You referred to a brake lining mixf I :hink, we were talking about MSDS Abex? A Yes. Q Can you tell me how it comes. A sheet, a lock, powder? . A As I understand, the mix is what i$ ormulated by the lining manufacturers, and then is tended in their factory and made into a lining or iade into a lining block. So that refers to:the ngredients that become the lining. Q Rockwell, then, does what with that ining? Does it bind it to a tacking, or a shoe, or omething along those lines, before it sells'it? A Depending upon what it is, the lining may i e sold loose, the lining may be assembled ta> a brake hoe and the lined brake shoe sold. Ace-Federal Reporters, Inc. Nationwide Coverage ' 202-347-3700 0<Ki36^6te 410-&W-2550 0 90 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 The lining may go into a kit with pther omponent s in them/ such as rivets that are meant to t tach it t and sold in that type of manner. ' Q In the instances where the lining is sold ithout a ttaching it to another part/ does Rockwell o anythi ng to the lining such as shape it, drill it or rivet s, or in some other way machine it to make t applic able to whatever part it is intended to be sed with ? A During what period of time? Q Okay/ well, you know, I am interested in eally all relevant periods of time. * A -The period of time that I am familiar with, 11 right, that was not done with service lipingB, Q Servicelines? 1 A Yes. However, as I had previously- estified to, at an earlier period of time, it was ecessary to grind the linings in order to shape hem. Q when you say it was necessary, you! mean, ockwell would have done the grinding; is that orrect? Ace-Federal Reporters, Inc. 2.Q2.-M7-3700 Nationwide Coverage 8004364646 410-M-235d i 0 91 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A 'ee . For the ones that went out in production, i Q And so Rockwell sold some linings that it * purchased from lining manufacturers without jreally altering the product at all? A Yes. Q Not all, just some v/ould fit that Sescription? A That's correct/ over the extended period of ime that we are talking about, correct. Q Even in the situations where the lining was ot physically realtered, it was repackaged pr labeled in some way, shape or form; it was called a .ockwell product as opposed to an Abex produtt or [otion Control product? . A 1 don't know if I would characterise it hat way. Q Well, you are a lawyer. But when it went ut, it was sold - A The material was placed in a box, the box, or service parte, said ''Rockwell" on the si<pe, and ad a label that said "Rockwell" and a part humber. Ace-Federal Reporters, Inc. Nationwide Coverage 202-547-3700 000-336-6646 410.604-2550. 0 92 1 2 3 4 5 6 7 a 9 10 11 12 - 13 14 15 16 17 18 13 20 21 22 Q When you say "service parts," you juean hose parts that were intended to be used byj a ervice mechanic as opposed to parts that waljld have een sold to an original equipment manufactuter7 A That's correct, MR. CALI: Thank you. EXAMINATION By MR. ROUSSEL; Q When you get a brake lini ng f rora a; upplier, what does it look like? A It is typically a light g ray or light tan material, can be of various sizes, from relatively mall to c ouple inches by, you know , a couple inches he other way, 6, 7 inches the othe r way, to'a very arge size The thickness might vary, depending upon e size of th e brake that is being used. : Q Baei tally, when you get a lining, it ela tively fit s in the break assembly, except for rhat ever machi ning that you are going to do to it^ is ,hat correct ? A When machining is required, but, otherwise, Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 000-336-6646 410-684-2350' 0 94 1 A As I sit here, I do not. However,.I 2 believe that there was a response to one of t:Jie 3 interrogatory requests that discussed that. 4 Q Your answer would be the same in that set 5 of interrogatories as it would be sitting here today, i 6 IE you could look, at that and refresh your memory? 7 A I have no other knowledge. 8 Q In fact, I might show it to you, 1't I can. 9 I will identify for the record as Exhibit Number 10, 10 this is in the case of Cadei versus OCF Corporation. 11 *Vnd out of the state of -- no -- yes, out of the 12 State of California. It shows responses to 13 interrogatories by Donna J. Morton, of the firm of 14 Shea & Gardner. And it was verified by your; 15 signature, Mr. Ketcham's signature, on the 30th day 16 :>f November, 1994. 17 There is a section in here that talks about 18 :he trade associations and also the identification of 19 :he hazards associated with asbestos. Let's see if I 20 :an find it real quick, 21 MR. MIKULA: Let me state for the record 22 :hat I have an objection to using interrogatories Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 H00-336-6646 410-684-2550 95 1 that were answered in some other case, in thjis 2 particular case, 3 MR, ROUSSEL; I understand. I kno,W it's in 4 here some place, : 5 (Ketcham Exhibit 10 identified.) 6 BY MR. ROUSSEL; 7 Q Do you remember working with counsel to a answer these particular interrogatories? 9 A Do I have an independent memory? 10 Q Yes. 11 A Not as I sit here, T recognize thp case, 12 Q Let me show you the verification oh the 13 back. Is that your signature on the back? 14 A Yes, that appears to be my signature. 15 Q Does Ms. Martin still work for this firm? 16 MR. MIXULA: No, she does not. 17 BY MR, ROUSSEL; _ 18 Q I would like to attach this as Exhibit 19 Number 10 to the deposition. 20 Let me ask you, on interrogatory number 15, 21 you state that Rockwell has supplied 22 asbestos-containing brake linings -- has supplied -- Ace-Federal Reporters, Inc. 202-347-3700 Nationwide Covetage 80CK336-6646 410.684-2550; 96 1 from the following facilities. 2 Are these Rockwell facilities that, are 3 identified down here, or are these other independent 4 facilities, starting at the bottom of the pape, right 5 below the yellow? This is Exhibit 10, interrogatory 6 15 . 7 A These are Rockwell, Rockwell sold these. 8 Q Does Rockwell ever get, say, a pallet of 9 brake linings from a supplier in a shrink-wrapped 10 carton that is not labeled with the supplier's name, 11 and actually just put their name on the package or on 12 the shrink-wrap and send it to a distributor? 13 A Repeat the question again. 14 Q Yes. Does Rockwell ever receive an order, 15 say 1 want a pallet, or I want a carton of brake 16 linings, whatever they come in, comes in a bonded 17 pallet or some kind of plastic container, whatever it 18 is, without the manufacturer's name on it, apd 19 Rockwell actually takes the box or the shrink-wrap, I 20 will put another shrink-wrap around it, and put their 21 name on it and ship it to a wholesale distributor? 22 A To the extent that we might receive brake Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-2550, 97 1 assemblies from one of our manufaccuring plants, all 2 right, it is possible that that would be out of any 3 other manufacturer's box, and we would take those 4 assemblies and shrink-wrap them and ship thejn. 5 The lining material typically has an FMSI 6 number, which identifies particularly the 7 manufacturer of that product. 3 To the extent you may be shipping,say, 9 bulk- brake items such as a pallet load of livings, 10 again, those would be shrink-wrapped. They would, as 11 I recall, be out of the box, but, again, those 12 linings would have an edge code on it typically 13 identifying the manufacturer. 14 Q When you say shrink-wrapped, are you saying 15 that we are going to take the individual iteih off the 16 pallet and wrap those separately? 17 A No. No, I am referring to placing-the 18 items, be it brake assemblies or the linings* on a 19 skid, perhaps putting plywood or cardboard between 3 20 them, stacking them up to a pallet size of . 21 4-by-4-by-4, for instance, banding that, and;then 22 shrink-wrapping the palleted load. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-2350 0 98 '1 2 3 4 5 6 7 8 9 10 11 12 13 14 IB 1G 17 18 19 20 21 22 Q Has Rockwell ever received such a pallet, ust like you described, from a supplier andj only 'hanged the name or just labeled it as Rockwell, and .hen sent it on to a distributor, without doing inything else? A I don't know, as I sit here. MR, CALI; Off the record a second. (Discussion off -the record.) ' EXAMINATION : BY MR. CALI: Q Mr. Ketcham, Mike Cali. I think we have identified here that ockwel 1 has purchased ashestos - containing brake roduct g or brake materials from Abex, Motion ontrol , and I believe we also said Bendix or Allied; a that correct? A Whatever was testified to. Q Do you have any personal knowledge-of any ther s upplier of those types of products to. ockwel 1? A One that comes to mind was Ray Asb^Btos anhattan. Other names of other companies I do not Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-37tXJ 800-336-6646 410-684-2550 1 J 0 99 1 recall as I sit here, . 2 Q There were others though, right? . 3 A Yes, I believe so, yes, 4 Q If we searched, we could find out the 5 identities of those suppliers? 6 A Over the relevant time period, conceivably. 7 yes . 8 Q Can you give me an estimation of hpw many 9 others there are. Would you say there are a'handful, 10 two or three others, or 20 others? 11 A I couldn't say, as I sit here today. 12 Q Order of magnitude, you can't give me an 13 idea; less than 10? 14 A I can't say less than 10 or more than 10. 15 It was certainly not hundreds. 16 Q Back again in number 3, I might have asked 17 you this question in a different way, 1 apologize, ia but do you know, as far as the parts that are in 19 Exhibit 3, which I believe the parts supplied by 20 Rockwell Top -- either Fleet or an entity with a 21 similar sounding name -- are any of those products 22 that contain materials from Rockwell from Bejjidix Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 H00-336-6646 410-684-2550, 0 100 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 IS 19 20 21 22 ibex. Motion Control or Allied? A As I sit heretoday, from my memory? Q Yes . A No, I do not. Q When Rockwell purchases a part, such as isbestos-containing materials; from Abex, Motion Control and Bendix, are those parts supplied to a pecification that Rockwell su-bmits to the suppliers? A I do not believe so. Q So Rockwell doesn't specifycontent. But oes Rockwell specify, we need a brake product for a articular application, let's say? A That is how the process would Btartt . Q Are you aware of any intercourse between ockwell and any of the three suppliers we have alked about, Abex, Motion Control or Bendix, egarding whether or not to include asbestos in the rake materials? A To the best of my knowledge, the decisions o decide or decisions not to include asbestos in a articular brake product is the design prerogative of he lining manufacturer. . Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 BOO-336-6646 410684-2550 0 102 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2Q 21 22 jent to -- one is to Molded Materials Divisi dti, which : think is Carlisle, one is Bendix Corporati on. MR. CALI: Object to the form. BY MR. ROUSSEL: Q One is to Abex. MR. CALI: Withdraw that, then. BY MR, ROUSSEL; Q Can you identify these pai~ticular Letters :s being Rockwell documents? I am not too c oncerned bout the grievance itself. A To the extent that the signature b lock hows a statement of Rockwell Standard Divis Lon, orth. American Rockwell, they appear to be. Q What are the complaints on those t :iree etters to those suppliers? A Without comparing word-for-word, t iey ppear to be identical other than who they a e ddresaed to. It references a grievance fro n pparently a local union and asks them to co rrect the ituation described in the grievance. Q 1 think the grievance describes asbestos ust that is coming into the Rockwell facility from Ace-Federal Reporters, Inc. Naiiomvide Coverage 202-347-3700 800^36-6646 410-6B4-255I 1 the Troy manufacturers that are Identified i 2 the letters; is that correct? 3 A The brief answer itself, as regard 4 statement of dispute or any title box above 5 does not specifically identify any particula 6 however, it does discuss asbestos disc in sh 7 MR. CALI; I said you were rid of fr 6 but - - 9 EXAMINATION 10 BY MR. CALI i 11 Q Mr. Ketcham, this particular griev 12 references asbestos dust from the rivet and 13 holes not being removed from the product. I 14 they mean -- do you agree with me what this \r 15 that the complaint is that when the material 16 received from the vendors, such as Motion Coji 17 Abex or Allied, that at that time the produc IB contains asbestos dust in the rivet and bolt 19 is that what they are complaining about? 20 A That is how I would interpret it. 21 Q Now, at this time, 1973, I think y 22 indicated brake linings were still being grih Ace-Federal Reporters, Inc. Nalionwide Coverage 202-347-3700 flffKJ.%-6646 410-6B4-255I 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 IB 16 17 18 19 20 21 22 round, by Rockwell to a certain extent; l s t correct? A It is my belief, yes. Q Without getting into what controls lad in place, because I don't think that's iither, would you agree that the grinding of \aterials would produce a certain amount of A Yes. Q As an attorney, you ate aware that iccupational Safety and Health Administration egulations in effect in 1973 which was incum ,pon employers to control dust for their own employees, asbestos dust? A I am not aware of a particular dat Q Would you - A --or otherwise, Q Would you disagree with me, I thin n emergency standard was issued in 1971 and ffective in 1972? MR. MIKULA; If you have any knowl bout that. THE WITNESS: (The witness nodded. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 B00-336-6646 41U-6S4-255< 1 MR. CALI: 2 other questions. That's fine, I don't ha V 3 MR. ROUSSELt I am going to show y 4 we will mark as Exhibit Number 12. 5 (Ketcham Exhibit 12 identified.) 6 EXAMINATION 7 BY MR. ROUSSEL: 8 Q The subject of the document is Asbfe 9 Linings in Department Number 30, by OSHA Comp 10 Department. The relevant part of the documeh 11 want to discuss is the one dated at the top 12 October 11, 1971. The document says that, p 13 1, 2, 3, 4, "Mr. Heard was advised that the 14 was aware of the potential health hazard tha 15 be caused by asbestos. You would agree that 16 company knew, in 1971, that asbestos causes 17 types of health hazard to individuals. 18 A Can you show me the document. 19 Q Again - - again, not a complete rea 20 a brief reading of the document, there is a 21 here that says, "The company was aware of th 22 potential health hazard.11 Ace-Federal Reporters, Inc. Nationwide Coverage 202.347-3*00 BOO-336-6646 41(>-6B4-255< 0 1 2 3 4 5 6 7 e 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A I did not see anything in the docur lowever, that identified the company that the referring to. (Keteham Exhibit 12 identified.) BY MR. ROUSSELt Q I am going to show you Exhibit Num| lated 1974 . The document seems to indicate lockwell is continuing to receive from its v .ining material containing excessive dust le .inings. Could you take a look at that docu A Again, the question. Q At that time, I think it's 1983 - he date, 1 974, - - A 1974. Q -- Rockwell is continuing to recei endore, whoever they might be, linings that o have excessive asbestos dust, which is a .o Rockwell , A Yes, the ixcessive asbestos letter states that there dust and that measures ne|e >e taken. MR. ROUSSEL: I am going to ask yo Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 00-336-6646 410-6R4-2SS) 0 107 I 2 3 4 5 6 7 0 9 10 11 12 13 14 15 16 17 IB 19 20 21 22 locument that I am going to mark as Exhibit Number .4 . [Kefcchant Exhibit 14 identified. BY MR, ROUSSEL; Q On the third page identified by RD 530, it :alks about brake linings in asbestos and di [f f erent iperations. I would like to ask you about a certain :olumn. Maybe we can go through each partic Ular fperation . It talks about -riv-et and grinding, I guess, .t says "grind." Is that rivet and grinding of brake inings it is referring to? A Can I read the document? Q Sure. A Would you ask the question again. Q The question is, this 140,000 tota per ionth, are we talking about the number of li flings hat are actually drilled and ground each mo ith, I uess, at this particular facility? A I don't know if that's referring t a linings r lined shoes, one or the other. Q What is the difference? it talks hbout Ace-Federal Reporters, Inc. Nationwid o Coverage 202-347-3700 BOO-336-6646 410`6R4-25!>( 7118 2, 0 WSCfij g 108 1 brake linings here. 2 A Yes, I understand. 3 A lined shoe may consist of one or two, at 4 least that I am familiar with, brake linings 5 Sometimes the brake lining may, depending up n the S size of the area that you are encompassing o I the 7 shoe, sometimes a lining would cover the who(L e shoe 8 surface, or sometimes you would need two lin fings on a 9 shoe. 10 Q I notice that it talks about,-dire :tly 11 under it, I guess the assembly of 80,000 per month, 12 then it says A-R-E ground. Do you know what that 13 stands for, "are ground11? 14 A It would appear on its face to say that 15 80,000 per month are ground. 16 Q Directly under it, it identifies t le 17 80,000, if I am not mistaken, nonasbestos li lings, or 18 that product that you had identified? 19 A As I would interpret it, either li lings or 20 shoes. 21 Q The date of that particular docume it is 22 what? Ace-Federal Reporters, Inc. Nationwide Covcr-tgc 202-347-370(1 800-336-6646 4l0-6B4-255< 109 1 2 3 4 5 6 7 e 9 10 11 12 13 14 15 16 17 IS 19 20 21 22 A There are two dates listed on the document, )ne of which is August 1983 and a second dat 2 is lanuary 1986. Q Thank you. I am going fco show you a survey, I hdustrial [ygiene Survey done of the Ashtabula, -- A Ashtabula. Q -- Ohio plant dated October 15, 19 70 . I ust want to bring your attention, when you Look at LD 57-9, when you talk about the knowledge of isbestos, showing that the industry had know .edge of .sbestos as early as September 3, 1970, I ha L^e a ittle yellow marker. A And your question? Q At that particular time, didRockw^ 11, does hat document indicate that Rockwell had know ledge of he hazards associated with asbestos? A Again, the document speaks for its h If It ppears on its face to be a letter and repor repared by George D. Clayton & Associates, And the age that is indicated on here does state, 11 kebeetoB nhalation is a well-known potential and indh strial Ace-Federal Reporters, Inc:, Nationwide Covftra^o 202-347-3700 WXJ-336-6646 410-684-255( 1 health hazard which can lead to characterise, 2 fibrosis and turn to asbestosie." 3 Q Thank you. 4 MR, ROUSSEL: That is Exhibit Mumbn 5 {Ketcham Exhibit 15 identified,} 6 BY MR. ROUSSEL: 1 Q I want you to look at this particu a document. Can you tell me what this documen 9 A Tt appears to be a piece of sales 10 literature published by Rockwell. 11 MR. ROUSSEL: I am going to mark t 12 Exhibit Number 16. 13 (Ketcham Exhibit 16 identified.) 14 BY MR. ROUSSEL: 15 Q Does this particular document go t 16 customers of Rockwell, those that would be b 17 wholesale distributors, those that would be p 18 parts from Rockwell? Who gets this document 19 A This particular product here, the 20 Holdmaster mechanical brake, appears on the 21 description of the second page of the docume h 22 directed to potential customers of front-end Ace-Federal Reporters, Inc. Natlnmvide Coverage 202-347-3700 000-336-6646 410-AM-255) 0 111 1 jraders, medium trucks, off-highway trailers L road 2 rollers, rough terrain cranes, and various & : ationary 3 lachinery. 4 This could either be distributed t a our 5 .nternal mailings, internal distribution, re guested 6 jy customers typically, or it could be provi led to 7 lustomers that we know are in this particula S larket . 9 Q Does Rockwell send this -- let me tart 10 rith the customer mailing 1-iBt . Who would b * on a 11 lustomer mailing list? Would that be only a : the 12 rholesale distribution or OEM level, or do y? u go 13 urther down to the user level? 14 A There are mailing lists that the c mpany 15 uses. Some of them may be directed to OEMs, some of 16 hem may be directed to WDs, some of them ma V be 17 irected to fleets. 18 Q Does Rockwell send out any brochur es 19 imilar to this, that is, directed to the e no use, 20 hat is actually doing the use on the part, he small 21 ody shop that might be doing brakes, or sma 1 Midas 22 hop, or any little independent operation th t might Ace-Federal Reporters, Inc;. Nationwide Coverage 202-347-3700 BOO-336-6646 410-684-25S( 0 1 be doing work on truck parts or automobile b:: 2 even heavy-duty brakes? 3 A I doubt that they would go to auton 4 brakes, because the brakes that we sell are 5 heavier-medium truck market. As you brought 6 would typically go to fleet. Fleets would be 7 user; dealership, OEM dealership would be an 8 user; it would be directed to them. 9 To the extent that an independent <1 ~10 either requested the information or asked to 12 on a mailing list, it's conceivable that they 12 also receive the information. 13 Q Does Rockwell have a policy of notL 14 its wholesale distributors to distribute the 3 15 of documents to other users that might be pu : 16 from the wholesale distributors? 17 A To the extent that we provide eitha 18 literature or other literature to the WDs, wi 19 may make available at their counter, in the : 20 display, for instance, it is possible that t.i 21 or even the counter trade would pick, up a br3 22 that point in time. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 B00-336-6646 4l(HW4-255< 1 (Ketcham Exhibit 17 identified 2 BY MR. ROUSSELi 3 Q I will show you what's marked as E]x 4 17. Could you tell me who is the intended rp 5 of this particular type document from Rockwe 6 A Documents such as this refer to out 7 parts, and this one in particular refers to d 8 components, document of this type might be s i 9 either our WDs and/or to dealers, and may be 10 available in quantities for them to post at 11 counter, for counter trade to see. 12 Q Does Rockwell -- or have they distL 13 in the manufacturing between certain size ve i 14 in the type of brake linings that they use i.i 15 vehicles? And I know that's unclear. 16 In other words, did Rockwell have 17 heavy-duty trucks or medium-duty trucks whert 18 would use asbestos linings in only heavy-duty 19 not in medium-duty or light-duty vehicles, o:r 2 0 they use asbestos in all of the vehicles at > 21 time? And when I say one time, I am talking 2 2 1970 on up until, I gueBs, when we are start Ace-Federal Reporters, Inc, Nationwide Coverage 2Q2-347-37D0 flOO-336-6646 410-684-255C 0 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 ase out the asbestos parts, up through todi. That was a long question, I know. A To the best of my knowledge, if yotli o 1970, all of the brake linings were manuf 'ith asbestos materials. Nonasbestos materi telieve, came into being during this time th alk.ed about, from 1970 through 1992 ox* 1993 radually replaced the use of asbestos mater Q Was Rockwell -- did they pinpoint \|r articular line of products they would start onasbestos in first, like the light-duty 1 i3)1 eavy-dufcy line, we are going to take this on o you know of any designation by Rockwell t<p ne particular line for use of a nonasbestos ver another line? A Not based upon any decision or dir4 hat Rockwell gave in the transition from asp onasbestos, It required the development of onasbestos linings, in some instances, in eplace the asbestos linings, based upon veh pplication, size, weight, so forth; there ai ifferent lining characteristics that need to Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 H00-33&-6646 410-6R4-255C 1 that lining material and certain characteris : 2 And for certain vehicle applications, I know 3 took the lining manufacturers longer to deve L 4 suitable nonasbestos replacements. 5 Q Do you know if any of the coniponeir: 6 in nonasbestos parts were not available in th 7 1970s? B A Could you define "components." 9 q whatever consists, or whatever comp 10 are used in the makeup of the- asbestos lining 1 X A The lining material-itself? 12 Q The lining material itself. 13 A Okay. 14 Q Do you know if there is any new IB development, since the early 1970s, they fou;i 16 new compound to place into these linings to g 17 from the asbestos product? IS A 1 don't know, no. 19 (Ketcham Exhibit 18 identified.) 20 BY HR. ROUSSEL: 21 Q I am going to show you what's marks 22 Exhibit Number 18. Could you tell me what cp Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 tiOfr-336-6646 41U-6S4-25K 1 this particular product was directed to, and 2 as with the similar brochures, what was the 3 the document? 4 A Again, the document is a piece of 5 literature for Stopmaster series brakes. A p 6 brakes described in the brochure are primariH 7 for use in off highway equipment, and it wou 8 directed at the fleet, or OEM, and the constj: 9 fleet, probably, in most instances, that wou '10 purchasing these products. ' 1-1 Q I am going to show you a document 12 think is a Rockwell document. Maybe you can 13 by looking at the names of individuals on tha 14 that discusses the placing of warnings on ovi 15 packs. Can you tell me about Rockwell's poll 16 far as placing warnings on over packs, and hd 17 particular procedure was changed by this doc 18 And what are over packs? 19 A Okay, again, your question. 20 MR. MIKULA: Could you repeat the 21 one at a time. 22 BY MR. ROUSSEL: Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800436-6646 410*fi842S5( 1 2 3 4 5 6 7 S 9 10 11 12 13 14 15 16 17 16 19 20 21 22 Q What is an overpack? A An overpack is a large box, or it i shrink-wrapped pallet, which would contain smaller, could contain smaller boxes, is madk :ontain the smaller boxes or as such. That b rour shipping container, your 4-by-4-by-4 Ion Q This talks about placing warnings o :ertain over packs and not placing warnings o :ertain other over packs. What policy did R<> lave in-place prior to this particular proced ieing implemented? A With respect to shipments from our .acilities, I know that individual boxes wer& dth an asbestos warning on them. I know tha his point in time, individual brake shoes th ontained asbestos linings were available. Q How was that done? A By taking an adhesive label and pli -n the shoe, as far as shoes go. The box la)p mprinted with an asbestos warning. As far as what was done with over irior to this directive, I am not sure. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347*3700 300-336-6646 410-6W-255C 0 11 1 Q It talks about, in this second -- (Ln this 2 locument about mix loads on less than a ful 1 [-packed 3 .oad containing asbestos, the large pack-and-peel 4 earning asbestos might be used. Can you explain to 5 le why that is not happening and why? 6 A Again, I don't know if I would wan' ; to 7 interpret more than what is on the face of t. :e a document. 9 MR. ROUSSEL: That will be Exhibit Number 10 19 11 (itetcham Exhibit 19 identified.) 12 BY MR. ROUSSEL: 13 Q X am going to show you a letter whj.eh was 14 upplied to me by Rockwell, but I don't think it's a 15 .ockwell letter. Can you look at this and t^ll me 16 hether or not you recognize the individualsilisted 17 n here as Rockwell employees. 18 A The individuals listed here? 19 Q Yes. 20 A Wo. 21 Q And here? 22 A No. I don'trecognize them as Rockwell Ace-Federai. Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6M6 410-6S4-255I 119 1 employees. 2 Q Do you recognize them as Johns Man^-ille 3 employees? 4 A Wo. 5 MR. ROUSSEL: I am going to list this as 6 Exhibit Number 20. 7 Ketcham Exhibits 20 and 21 identified. 8 BY MR. ROUSSEL: 9 Q I am going to show you what has be^n marked 10 as Exhibit Number 21. 11 Could you tell me what this document is and 12 who is meant to receive this particular document? 13 A It is a Rockwell brake maintenancejmanual 14 called "Field Maintenance Manual Number 4." lit IE provides instructions for the service and repair of 16 Rockwell brakes that were being manufactured I at the 17 time for the various model numbers that are included 18 in the maintenance manual. 19 Q Who's the intended recipient of thf.s 20 particular document? 21 A The ultimate intended recipient wo^ild be 22 the maintenance technician. Ace-Federal Reporters, Inc. Nationwide Coverage 2D2-347-3700 800-336-6646 410-684-2550 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q Do you know who Rockwell sent thess articular brochures to? A Again, distribution could be made ; he OEMs, to OEMs, to people on our mailing 1 eople that requested maintenance information uch. (Ketcham Exhibit 22 identified.) BY MR. ROUSSEL: Q I am going to show you what's been s Exhibit Number 22. I am going to ask you dentify t his particular document. A This is a Rockwell maintenance maim Iso, Thi s is an "Advanced Field Maintenance or Cam-Ma ster Q brakes, Q series brakes. G What types of vehicles are Q serieu sed on? A Primarily on-highway vehicles. Q Again, the intended recipient of hi ocument is the same as document manual numh-5 dentified in Exhibit Number 21? A That's correct. (Ketcham Exhibit 23 identified.) Ace-Federal Reporters, Inc. Nationwide Coverage 202-347*3700 00336-664fi 410-6&+-255C 0 1 2 3 4 5 6 7 a 9 10 li 12 13 14 15 16 17 ia 19 20 21 22 BY MR. ROUSSEL: Q Let me show you what is being idem xhibit 23. I am looking at the third parag;: ere. What concerns did - - what would conce:: ockwel1 about assembly linings being damaged hipment as referred to in this particular do A Again, your question? Q What was the concern here in the ex hen the linings would be damaged, was there oncern-by Rockwell that the fibers from the inings well, that damaged linings would n reate asbestos fibers that were dangerous, o the health.of individuals? A If you are referring to the damaged, econd line here, -- Q Yes. A -- that, as I read it, is the rstu:: amaged linings to the lining manufacturer, ppears at this point in time that we were pi, hose damaged linings in tubs and shipping th o the lining manufacturers, is how I would .. t. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 4J0-6&4-255( 71182.0 WSCsjg C 122 o 1 II Q It talkB about; in my opinion, tha : these 2 llshould be totally enclosed and labeled becau 3e of the 3 llpossibi 1 i ty of generating asbestos fibers du ing 4 Ishipment. 5 II There's no grinding going on. Wha 6 Hasbestoe fibers could be generated during the 7 llshipraent of brake linings back to the manyfa turer? 8 A It would be my belief that it says in the 9 statement here, in the first sentence, that he 10 linings were loose in-- tubs; therefore, you wo uld have 11 lining rubbing against lining. I guess, som ebody 12 felt potentially - 13 MR. MIKULA: Don't guess. 14 BY MR. ROUSSEL: 15 i| Q When you shipped linings to a whol sale |j 16 .[distributor, were they ever loose on pallets as 17 idescxibed by this document? 18 ii A Not in my belief. 19 II Q Do you know one way or another? Y 6u say 20 ||not in your belief? 21 A I don't believe so, 22 Q I am going to show you a document which is c Ace-Federal Reporters, Inc. Nationwide Covarago 202*347*37UG WXK336-6646 41ft-(iS4-2S5( 2 not a Rockwell document, but it was in the dp 2 produced by Rockwell, describing a layout o:r 3 asbestos warning. Are you familiar with, X g 4 Rockwell's attempts to design a sticker to pi 5 its component parts as identified in this pa;: 6 set of documents? 7 A Your question again, please. 9 Q Are you familiar with what Rockvii:, 9 doing at this particular time with that part., 10 label design? - 11 A No. 12 Q I am going to show you another exh;. 13 Can you tell from this particular exhibit -14 oing to show you what Rockwell might have b<s 15 to design a warning label for asbestos produo 16 A Again, your question, please. 17 G What actions was Rockwell taking at 18 articular time to design a warning label fo:: 19 uess, individual asbestos products, from vha 20 tell? 21 A This particular label? 22 Q Yes. Ace-Federal Reporters, Inc. Nationwide Coverage 202-3^7-3700 800-336-6646 4JO-684-255C 0 1 A I do not know. 2 Q Do you recognize that set of docum 3 tockwell documents? 4 A The first document, RD 0G1S7, cont 5 lame of some individuals I know as Rockwell fe 6 it that particular point in time. The balan 7 locuments appear to be a letter to Rockwell f 8 Caterpillar Tractor Company dated October 3, 9 Lpparently requesting, as I would interpret 1-0 re put., their label on. -- 11 MR. ROUSSEL: I am going to mark-t 12 Jxh.ibifc Number 24. 13 (Ketcham Exhibits 24 and 25 ident 14 BY MR. ROUSSEL: . 15 Q I am going to show you what is mar 16 Ixhibit Number 25. Could you tell me who is 17 ntended recipient of this particular documefc IS A Intended recipient would be employ 19 taintenance technicians, who had dealt with 20 laintenance and servicing of Rockwell brakes 21 :ontained asbestos linings, 22 Q Do you know who Rockwell sent this Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-2551 1 a 3 4 5 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 >articular document to, or did they send it same individuals as you discussed, with the <j> lanuala identified previously as Exhibit Numb ind 22, the maintenance manual, the two maini. manuals, or the brochures listed as Exhibits .6, 17 and IS? A Without going back and referencing :xhibits, what were the questions, or what ruesfcion? Q -Yes. Do you know who, what was the f getting this document to the WDs, or whortits as intended to get to? A Again, this could be sent t o the WI> lets, as part of a mailing; it cou Id be is tributed by our field force; it co uld be a nc luded as a package insert in brake 1ining , as such, possibly other modes of distrib !u t those are the only ones that occu r to me Q But you don't know offhand exactly one with this particular document? A I just described what I thought wan Ace-Federal Reporters, Inc. Nationwide Coveiage 202-347-3700 600-336-6646 470*04-2551 0 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 irobably the process of distribution on this. {Ketcham Exhibit 26 identified.) BY MR. ROUSSEL; Q I am going to show you another docu hat talks about asbestos label warning test.. Could you look at this particular d nd tell me whether or not Rockwell is in the attempting to develop a warning label for roduct s? A This appears- to indicate testing an suits of that testing with respect to ashen rning label that was attached or was intend tached directly to the brake shoes. (Ketcham Exhibit 27 identified.) BY MR. ROUSSEL: Q I am going to show you what has be<2 s Exhibit Number 27# which is, again. Field aintenance Manual 4P for Heavy-Duty Brakes. Is there any difference from the istribution process for this particular mam pposed to Field Manual Number 4 Exhibit Numb MR, MIKULA: Do you need to look a; Ace-Federal Reporters,, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-2550 ) 1 2 3 4 5 6 1 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 ain? BY MR. ROUSSEb: Q Sure, A Possibly. Q Can you tell me what that is? A The field maintenance manual that ^ landed me, number 4P, for Stopmaster brakes, leavy-duty and to 17 and 36-inch brakes, Thi> irakes that are typically used on off-highway iquipment, whereas the prior exhibit, 21r.tho irakes are primarily used on on-highway equip herefore, customers that you are trying to p his information to might be slightly differ^ Q 1 am going to showyou twoletters ne of June 1, 1983, one of May 16, 1983, wh:. oing to mark as Exhibit 28, The letters see eferring to the receipt, again, of Abex Corp rake linings with excessive asbestos dust iiji axes . Can you take a look at that particiii f documents and tell me exactly what they a:: eferring to, Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 80O-336-6W6 410-6M-255C 0 1 (Ketcham Exhibit 28 identified.) 2 THE WITNESS: Again, your question 3 ilease . 4 BY MR. ROUSSEL: 5 Q Do these set of documents refer to G concern for excessive asbestos dust from the 7 upplier? 8 A Yes, that's what it appears to be o 9 ace . io- . {Ketcham Exhibit 29 identified .'4 ii BY MR. ROUSSEL: 12 Q I am going to mark this as Exhibit 13 gain, this particular document concerns Abe:c 14 orporation'e product that's being supplied :> 15 nd it seemed that there's a problem with, thu 16 articular manufacturer's asbestos brake lin..: 17 ar as the creation of duet. 18 Can you take a look at that particu 19 ocument for me, please. 20 A Again, your question, please. 21 Q Whether or not there's a concern wi 22 inings coming from Abex with the asbestos dr Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-3364646 410-64>2S5C 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A Right. The letter is addressed to uid it does discuss asbestos dust. (Ketcham Exhibit 30 identified.) BY MR. ROUSSEL; Q I want to show you a document chat Ixhibit Number 30 that talks about a respira irogram. Could you tell me whether or not t^ lockwell program, and why i^s being estahli;; A Based upon the heading on page RD b tates, "Rockwell, standard Division of Rockj, nternational," and it appears, as a whole, rogram being established by Rockwell. I do he purpose of having the program. Q I am going to show you, I think th ifferent dates, letters from Rockwell to Ca arlisle Molded Materials Division, to Bendi:s orporation, and to Abex Corporation, which o be a second letter dated 1975 complaining he asbestos dust coining from those particul^ anufacturers to Rockwell. Could you take a look at those par ocuments and see if those are actual Rockwell. Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-255^ 1 ocument s, 2 A. They appear to be Rockwell document 3 upon the heading/ again/ in the signature bio 4 listing Rockwell Standard Division of Rockwei. 5 International. 6 (Ketcham Exhibit 31 identified.) 7 BY MR. ROUSELL; B Q I am going to show you a document w 9 attached material safety data sheet. Can you 10 describe to me what the -material data sheet 11 epreeents, which is the RD 02018. 12 A I'm sorry, again, your question? 13 Q What product is represented on tha1: 14 aterial safety data sheet? 15 A Product name listed here is Cam-Man 16 topmaster truck brakes, front and rear. 17 Q They list on there, I think, 45 pe:: 18 sbestos content. Exactly what are they talk 19 bout as containing 45 percent asbestos? 20 A I could not speculate on that beyo:i 21 n the page. 22 q is there anything besides the braka Ace-Federal Reporters, Inc. Nalionwide Coverage 202-347-3700 800-33<v-6646 410-C&I-2551 131 1 and the brake shoe that contains asbestos in those 2 particular products? 3 A Not to my knowledge, no. 4 MR. MIKULA: Objection, assumes thf t the 5 brake shoe contains asbestos. 6 MR. ROUSSEL: The brake shoe and t e brake 7 lining are the same, from what you said earl er, a right? 9 THE WITNESS: No, actually, the brf ke shoe 10 was the metal, all right. The lining is the asbestos li or nonasbestos lining material. 12 BY MR. ROUSSELi 13 Q You wouldn't expect the composition of the 14 metal to have asbestos in it, would you? 15 A No, I would not, 16 MR. ROUSSEL: Thank you. This wil be 17 Exhibit Number 32. 18 THE WITNESS: May we take a five-m nute 19 break? 20 MR. ROUSSEL: Sure. 21 (Keteham Exhibits 32 and 33 iden if ied.) 22 BY MR. ROUSSEL: Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 ti00v)36'6644 410-684-255C 0 1 Q Mr. Ketcham, I am going to show yo 2 going to be marked as Exhibit Number 33. Co 3 tell me what types of vehicle uses these typ 4 brakes. 5 A 1 don't know if you can specifical 6 identify model to a particular type of vehic 7 however, in general, this category of brakes 8 used in small off-highway equipment, industr 9 brucks, and medium-duty trucks. 10 -- Q - Again< v/ho is the intended recipieh 11 that particular document, and how is it dist 12 to them? 13 A - Again, this is a maintenance manua 14 vould be distributed and the intended recipi^ 15 >/ould be similar to as I testified to before 15 as distribution to various OEMs, dealers, WDfe 17 :he intended recipient in the end is the main 18 technician who is performing the work and cap 19 listributed by mailings or by our field 20 representatives or, upon request, of those a Jr- 21 ?eople. 22 This particular series is, as 1 defe Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6636 410-684-25K 1 the types of vehicles that I believe the brak 2 be used and directed to those types of vehicLL 3 applications, or people that have those type 4 vehicle applications. 5 BY MR. ROUSSEL: 6 Q Again, what types of vehicles woultl 7 these particular types of brakes, in general S A The type of vehicle that was used 9 type of break would be primarily on-highway 10 vehicles. The particular markets where this 11 more prevalent than others would be fire egu|L 12 and refuse hauling. 13 MR. ROUSSEL: I am going to mark t 14 Exhibit ETumber 34. 15 Off the record for a second. 16 {Ketcham Exhibits 34 and 35 identif 17 BY MR. ROUSSEL: 18 Q I am going to show you what has be 19 s Exhibit 35. Can you tell me what that pa. 20 exhibit is? 21 A It is a material safety data sheet 22 asbestos-containing brake linings prepared bk Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-2SK 0 a Rockwell International Corporation, to addres 2 products that were manufactured by other com;? 3 It was prepared on the date on the final pag 4 September 25, 1986. 5 Q Do you know whether or not there w 6 prior material safety data sheet prepared by 7 concerning asbestos products supplied to Roc 8 other manufacturers 7 9 A Yes. . 10 Q What is the answer? .. . 11 A May I review the document? 12 Q Sure, 13 A To the best of my knowledge, this i; 14 first asbestos - containing brake lining MSDS p 15 oy Rockwell for distribution, with the possi 16 sxcepticui of Exhibit 32, which apparently wa 17 3ut by Rockwell. But we are in that letter 18 ;heir material safety data sheet, which was 19 Rockwell International or International Harv 2 0 Canada. 21 Q Just for the record, the answer to 22 discovery that I thought was for some other Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-6S4-25H 0 135 1 chat I read, was actually answers to our die covery, 2 talking about the knowledge of Rockwell to t he health 3 hazards associated with asbestos. 4 I know you have answered some of t hese, and 5 I am not going to reask. you the same guestio n . 6 MR. MIKDLA; Mr. Roussel, are you reading 7 from the notice of the corporate deposition? 8 MR. ROUSSEL: Yes, 9 BY MR. ROUSSEL,* 10 Q May I ask you, do you know why Roc kwell, 11 although it 'had knowledge of the hazards ass ociated 12 with asbestos, waited until what seems to be the late 13 f70s or 1980s before providing warnings abou t 14 asbestos hazards to its customers? jte '70s, 15 A I know that in the '70s, in the la 16 perhaps a little bit earlier in the '70s, we included 17 warnings in some of our product literature atad 18 otherwise, That is the first time that I knbw we 19 included those types of warnings, either on bur 20 packaging or on our literature. Beyond that, I do 21 not know. 22 0 Who, you may not know, do you know anyone Ace-Federal Reporters, Inc.. Nationwide Coverage 202-347-3700 B00-336-6646 410-6W-255f 0 1 in the organization/ or who are in the organ 2 who might be able to testify concerning the 3 not to warn customers about asbestos until t 4 '70s or early '80s, as you just described? 5 A Wo, I know of no such individual. 6 Q Are you familiar with any relabel! 7 rebranding agreements with any of your suppl B brake linings or brake pads? 9 A Wo, 10 Q I just wanted to make sure that. 11 see. i don't know if you signed this one or 12 Strike that, 13 Let me ask you, in the interrogator, 14 provided to us dated August 18, 1993, which w 15 answered by Mr. Hugh Glenn and, therefore, a. 16 the heading of Shea & Gardner underneath, do 17 if you worked in preparing this particular IB answers, maybe I can show it to you, worked -<t 19 attorneys to prepare this set of answers. I 20 them all marked up to take a look at them. 2 1 A I would believe so, at least with : 22 to some of the other responses. Ace-Federal Reporters, Inc. Nationwide Cnvuragi? 202-347-3700 B0TV336-6646 4HF6fl4.255< 0 137 1 MR, ROUSSEL; T would like to atta ch that 2 to this deposition, This will be Exhibit Nu Imber 3 6 . 3 (Ketcham Exhibit 36 identified.) 4 BY MR. ROUSSEL; 5 Q Did you work any in the developmen t of any 6 of the warnings that are in any of the broch. urea, or 7 any brochure that might be distributed by Ro ekwell to 6 its customers? 9 A Yes. 3.0 Q - When did. you work in the developme nt of 11 those labels? 12 A My first involvement with that woup. d have 13 been approximately 1988, beginning then. 14 Q What did you do in your work, to de velop 15 asbestos warning labels? 16 A X would work with counsel in revie wing the 17 labels that are there and assuring that the nost 18 up-to-date revisions to the warnings and/or Labels 13 are included there on our product or in our nanuals, 20 Q Did you have a warning specialist Dr 21 warnings expert work with you in that area, Dr work 22 with Rockwell and you in that area? Ace-Federal Reporters, Inc. Nntionwide Covfcrage 202-347-3700 W-336-6646 4l0-6&4-255{ 7118?, . 8 WSCs j 138 1 A Wot a warnings expert, per se, bey| ond 2 counsel. 3 Q Do you know if Rockwell employed a warnings 4 expert to review the work that you and whoev|er it is 5 that you were working with, came up with the design, 6 the language, whatnot? 7 A Beyond the input of counsel, I am not 8 certain. I don't know of any others. 9 Q What was the ultimate or final war ning that 10 you selected to be placed on asbestos produc ts? Was 11 it anything that we went through today? 12 MR. MIKULA: I think we are asking the 13 witness a pretty tough, question, 14 THE WITNESS: I don't recall. 15 BY MR. ROUSSEL: 16 Q Was there a finalized version, or were 17 there several revisions that may have been aced on 18 products over a period of time? 1 9 A There have been revisions made to [labels 2 0 and literature over time. 2 1 Q Do you remember the reasons why th 22 revisions were made? Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 B00-336-6646 4lO-6&4-255< 0 1 A As I sit here today, no. 2 Q Do you know if revisions were made 3 you felt or someone felt that the label or t 4 warning was inadequate for the purpose of tr 5 be conveyed to the ultimate user? 6 A Again, I really don't know. I can 7 the reasons that we made the changes to the 8 during the tenure that 1 had dealing with la 9 beginning in 1998/ and literature also, 10 Q Are you still in the realm of warnti 11 review; is that still part of your job functti 12 A I still review technical literatur 13 Q When you started reviewing warning 14 1988, did you feel that the warnings were in 15 A Not that X can recall. 16 Q Why did you make any changes to th 17 if they were adequate? 19 A To update them and to ensure that f: 19 in the various pieces of literature. 20 Q Did Rockwell give its salesmen and 21 marketing personnel any type of specific tra 22 education concerning the dangers associated Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 JKKW36-6646 410-6S4-255C ) 1 asbestos that they were to convey to their c 2 A Specific training dealing with asb 3 am not aware of any. Obviously, our field p 4 and received the maintenance literature, saw 5 reviewed that, and would be aware of those i 6 are in the literature7 They would have also received and 8 themselves conducted training, perhaps, uein|3 9 our videotapes, which, I believe, also inclu 10 information dealing with potential asbestos 11 Q What was the date of the first vidja 12 that came out that might have discussed asbe^ 13 hazards,- do you know? 14 A No, I don 1t. 15 Q Was there any particular documents 16 Rockwell produced specifically for the salesjri 17 marketing personnel that discussed asbestos 18 and was directed at exactly those individual 19 A I don 11 know. 20 Q Besides this particular tort claim 21 other tort claim are you aware of that had b 22 against Rockwell for exposure to asbestos be Ace-Federal Reporters, Inc, Nationwide Coverage 2(12-M73700 800-336-6646 4IO-684-255C Q 1 dust from brake linings, brake shoes, brake 2 A Open cases today, is that what you 3 referring to? 4 Q Any cases that you know of from 19fr 5 through today. I am sure that you have prob 6 pointed one out earlier* 7 A I don ' t know the exact number. B Q Could you give me an estimate , mor 9 than? -: 10 A If - I was to make an estimate of to 11 c1 aims against Rockwe11 for asbestos exposur 12 brake 1 inings, I would say it would be in th 13 neighbo rhood.of 150 to 200 That does not i h 14 several hundred claims that were filed in th 15 couple of years ; there was a mass file in th 16 of Ohio 17 Q These have no t included any worker 18 claims; is that correct 7 19 A That is correct. 20 Q Of the claims that you just identi 21 they basically the same type allegations as 22 present claim, where people are saying from Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 B00-336-6646 410-6W-255I 1 grinding of asbestos linings, asbestos brake 2 they have been exposed to asbestos dust and 3 lung condition from that exposure? 4 A I don 1t know. 5 Q Are you involved in all of those ctl 6 any of those claims, as far as helping or as 3 7 attorneys to defend those claims? e A Some of those claims, yes. 9 Q Who actually represents Rockwell ojn 10 those claims? -- 11 A Our counsel. 12 Q Who is that? 13 A Our counsel. 14 Q Shea & Gardner or different counae|L 15 country? 16 A Shea & Gardner is our central counb 17 various local counsel are employed around ths 10 country. 19 Q rs Shea & Gardner involved in all 20 cases ? 21 A I don 11 know. 22 q Have you given any prior depositioh Ace-Federal Reporters, Inc. Nationwide Coverage 2Q2-347-3700 800-336-6646 4)0-684-255i 1 concerning any of those cases that yon just 2 identified? 3 A No. 4 Q Do you. know if Rockwell Internatioi 5 Corporation has given any corporate depositis 6 any of those other claims that you identifiep 7 A No. 8 IM' R , M1KULA; Bru S don't know, O r no? 10 1THE WITNESS: No 11 knowledge, no other person 12 deposition. 13 MR. ROUSSEL: No 14 MR - MIIOJLA: He 1 15 MS . ECHOLS: Yes 16 MR. MIKULA: Do 17 telephone have any questions for Mr. Xetcha.ro:) 19 MR. PERRY: X have none. This is fa 19 Perry. 20 21 MR. ROUSSEL: Anyone else there? MR. BROCKMAN: Yes, this is Bill Bjc 22 and I have no questions. Ace-Federal Reporters, Inc. Nattonwidn Coverage 202-347-3700 300-336-6646 410-M-255Cj 0 1 MR. MIKULA: Anyone else? 2 MS, ECHOLS; This is Julie Echols, 3 have a couple. 4 EXAMINATION 5 BY MS. ECHOLS: 6 Q I represent Ford Motor Company in : 7 matter. 8 A couple hours ago you mentioned F :> 9 Company in reference to Rockwell. Does Rockw 10 still sell parts to Ford Motor Company today, 11 'eat of your knowledge? 12 A Any parts? 13 Q Yes. 14 A Yes, we do. 15 Q What parts would those be? 16 A Parts, automotive parts for your pa 17 ars, I believe. 18 Q What type of automotive parts for ; 19 assenger cars? Can you be more specific? 20 A I know that we supply suspension 21 omponentsj we may supply other components fo 22 assenger cars. I can't speak to that off ti Ace-Federal Reporters, Inc. Nationwide Coverage 202-M7-37OO 80Q-33&-6M6 410-6R4-255C 71182 , 0 WSCsj g 145 1 my head. 2 Q Did I understand you earlier in th at you 3 said you no longer supply parts containing a sbestos 4 to Ford Motor Company? 5 A That is correct. 6 Q Do you remember when you stopped s applying 7 asbestos-containing parts to Ford Motor Comp any, 8 Rockwell? 9 A Not specifically. 1 0 Q Do you need a time frame? 11 A Late 1980s or 1990s. 12 Q Do you know how long Rockwell suppjl ied 13 asbestos-containing products to Ford Motor C ampany? 14 A No, I do not. 15 Q About what point in time, do you k low what 16 point in time they started? 17 A I could not hazard a guess. 18 Q During the time that you supplied 19 asbestos-containing products for Ford Motor pompany, 20 what other companies did you provide similar products 21 to? 22 A OEMs? Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-25.** 146 1 Q Yes. 2 A Over the years, we have supplied 3 asbestos - containing brake products to many o the 4 major heavy vehicle manufacturers such, as F 3rd or GM 5 or the other heavy vehicle manufacturers, as we 11 as 6 the specialty manufacturers in the marketpla re. 7 Q Can youname anyotherspecificall / other a than Ford and GM? 3 A How long a list would you like? 10 Q Just give me,- dur i ng the time fram 2 that 11 also sold to Ford, I j us t want to know w 10 else 12 you sold to during that time frame, 13 A Remember, I couldn't identify the : ime 14 fframe with specifics as far as the time fram 5 that we 15 sold to Ford. 16 Q Generally, do you know within the same time 17 frame? 18 A Well, as I previously stated, we s ipplied 19 our brake products to a number of the major and minor 20 on-highway vehicle manufacturers that manufa rtured 21 products similar to Ford. During every year or every 22 decade, we are not necessarily the manufactu rer of Ace-Federal Reporters, Inc. 202-347-3700 Nationwide Coverage BOKJ36-664G 4l0-6&4-255( 0 1 choice as far as brake produces for those co 2 We did have competitors in there. 3 Being more specific than that, I d: 4 thinJc that I can be. 5 Q You can't tell me who else you sup: 6 products to other than GM and Ford? 7 A I just explained the breadth of th2 8 that we supplied to. 9 Q Can you just identify some of the : 10 automotive manufacturers? -..... 11 A Again, I don't know if and when du:tr 12 period of time we may have supplied brake pr: 13 some of the other manufacturers, but,.as I sa 14 was major as well as medium and minor player 3 15 rket. 16 You had Navistar, Volvo, Mack, Pack 17 group con sisting of Peterbilt and Kenworth. 18 Again, I don f t know during what pa: 19 riod of time we may have supplied product ; 20 Q Fair enough. If you don't know, ag 21 just reit rate at what period of time you suu 22 these pro ducts to Ford as well. Ace-Federal Reporters, Inc.. Nationwide Coverage 202-347-3700 0Q(M36*6646 410-6M-255C 0 1 A That Is correct. 2 MS . ECHOLS; That's all I have, th 3 MR . MIKULA: Let's take a short hr 4 MR. ROUSSEL: This is it. 5 You have some questions? 6 MR. MIKULA: Maybe. 7 (Discussion off the record,) 8 MR. MIKULA: No questions, 9 MR. ROUSSEL; That's the end of ths 1 0 deposition. 1 1 - (Whereupon, at 4:35 p.m., the depos 12 was concluded.) 13 14 15 16 17 18 19 20 21 22 Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-255C 14 9 1 I HEREBY CERTIFY that I h ave read this 2 transc ript of my deposition and that this transcr i pt 3 accura tely states the testimony given by me, with the 4 change a or corrections, if any, as noted. 5 6 7X 3 9 10 11 Subscribed and sworn to before me this day of 12 , 19____ 13 14 15 16 X 17 Notary Public 18 19 My commission expires: 20 21 22 Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 iM)0-336-6446 41(Ht84-255C 0 1 CONTENTS 2 3 WITNE;ss 4 Bruce E . Ketcham EXAME 5 by Mr . Roussel by Mr . Cali 5 7 by Mr . Roussel 7 8 by Mr. Cali 9 by Mr, Roussel J 3 10 by Mr . Cali ? 11 by Mr. Roussel 1) 12 by Mr. Cali 10 13 by Mr. Roussel 1) 14 by Ms . Echols 11 15 16 EXHIBITS _ 17 18 DEPOSITION NUMBER IDEN 19 Exhibit 1 Notice of deposition 20 Exhibit 2 8/20/93 letter 3 5 21 Exhibit 3 Parts sales chart 22 continu 2 Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-334*4646 410-6S4-255C 0 1 EXHIBITS (CONTINUED) 2 3 DEPOSIT] ON NUMBER 4 Exhibit 4 Material safety data sheet 5 Exhibit 5 Material safety data sheet 6 Exhibit 6 11/18/85 letter 7 Exhibit 7 2/4/86 memorandum I DEN] E 6 e i 8 Exhibit 8 2/5/86 letter 7 9 Exhibit 9 Rockwell Brakes membership 3 10 Exhibit 10 Response to interrogatories 3 11 Exhibit 11 Grievance form 13 12 Exhibit 12 8/19/71 inspection report 13 13 Exhibit 13 7/15/74 memorandum 13 14 Exhibit 14 Assessment 1D 15 Exhibit 15 9/15/70 survey 1L 16 Exhibit 16 Copy of Rockwell brochure 1L 17 Exhibit 17 Copy of brochure 1L 18 Exhibit 18 Copy of brochure 1L 19 Exhibit 19 11/18/88 memorandum 1i 20 Exhibits 20 and 21 8/15/72 memorandum and 1L 21 copy of manual 22 - - continus Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 4106M-255C 1 EXHIBITS (CONTINUED) 2 3 DEP0S1 TION NUMBER IDENtt 4 Exhibi t 22 Copy of manual l 5 Exhibi t 23 4/17/79 memorandum 1 6 Exhibi ts 24 and 25 Handwritten document 1 7 and technical service 8 aid 9 Exhibi t 26 Engineering report 1 10 Exhibi t 27 Copy of manual 1 11 Exhibi t 28 12 Exhibi t 29 6/1/83 letter 3/2/79 letter l 1 13 Exhibi t 30 14 Exhibi t 31 Respirator program 5/19/75 letter 12 1 15 Exhibi ts 32 and 33 1/18/60 letter and Ifc IS copy of manual 17 Exhibi ts 34 and 35 Copy of manual and 16 18 material safety data 19 20 Exhibi t 36 sheet Answers to interrogatories lb 21 22 Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 000-336-6646 4UI-664-255C 1 150 1 CONTENTS 2 3 WITNESS EXAMINATION 4 Bruce E . Ketcham 5 by Mr. Roussel 6 by Mr . Cali 5 67 7 by Mr . Roussel 8 by Mr. Cali 9 by Mr. Roussel 10 by Mr. Cali 73 88 92 98 11 by Mr. Roussel 12 by Mr. Cali 13 by Mr. Roussel 101 103 105 14 by Ms . Echols 144 15 16 EXHIBITS 17 18 DEPOSITION NUMBER 19 Exhibit 1 Notice of deposition IDENTIFIED 58 20 Exhibit 2 8/20/93 letter 59 21 Exhibit 3 Parts sales chart 61 22 -- continued -- Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-2550 151 1 EXHIBITS (CONTINUED) 2 3 DEPOSITION NUMBER IDENTIFIED 4 Exhibit 4 Material safety data sheet 63 5 Exhibit 5 Material safety data sheet 64 6 Exhibit 6 11/18/85 letter 65 7 Exhibit 7 2/4/86 memorandum 74 S Exhibit 8 2/5/8 6 letter 9 Exhibit 9 Rockwell Brakes membership 75 93 10 Exhibit 10 Response to interrogatories 95 11 Exhibit 11 Grievance form 101 12 Exhibit 12 8/19/71 inspection report 105 13 Exhibit 13 7/15/74 memorandum 10 6 14 Exhibit 14 Assessment 107 15 Exhibit 15 9/15/70 survey 110 16 Exhibit 16 Copy of Rockwell brochure 110 17 Exhibit 17 Copy of brochure 113 18 Exhibit 18 Copy of brochure 115 19 Exhibit 19 11/18/88; memorandum 118 20 Exhibits 2 0 and 21 8/15/72 memorandum and 119 21 copy of manual 22 -- continued -- Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 AifUttU-iwi 152 1 EXHIBITS (CONTINUED) 2 3 DEPOSITION NUMBER IDENTIFIED 4 Exhibit 22 Copy of manual 120 5 Exhibit 23 4/17/79 memorandum 120 6 Exhibits 24 and 25 Handwritten document 124 7 and technical service 8 aid 9 Exhibit 26 Engineering, report 10 Exhibit 27 Copy of manual 11 Exhibit 28 6/1/83 letter 126 126 128 12 Exhibit 29 3/2/79 letter 13 Exhibit 30 Respirator program 14 Exhibit 31 5/19/75 letter 15 Exhibits 32 and 33 1/18/80 letter and 128 129 130 131 16 copy of manual 17 Exhibits 34 and 35 Copy of manual and 18 material safety data 133 19 sheet 20 Exhibit 36 Answers to interrogatories 137 21 22 Ace-Federal Reporters, Inc. Nationwide Coverage 202-347-3700 800-336-6646 410-684-2550 CERTIFICATE OF NOTARY PUBLIC 153 I, Edwin G. Crowley, a notary public in and for the District of Columbia, do hereby certify that the witness whose testimony appears herein appeared before me and was duly sworn by me. My commission expires 31 October 2000 Edwin G. Crowley Notary Public in and for the District of Columbia Certificate of Court Reporter I> ^ r( - 5 C6 Step ^ f Court Reporter, do hereby certify that the testimony contained herein is a true record of the testimony given by said witness, and I further certify that I am neither attorney nor counsel for, related to, or employed by any of the parties to the action in which this statement is taken; and, further, that I am not a relative or an employee of any attorney or counsel employed by the parties hereto, or financially interested in the action. 0 Court Reporter Ace-Federal Reporters, Inc. Natiuiwidf CuvcrAgc 2l)2-r4707(HI KUn-33f-fiMf> 3NI-fiN4-25iH l>epo of: BRUCE E. KETCHAM (Douglas etal vs, Allied-Signal, Inc.) 1-22-99 LooSc-See{l) Look-See Concordance Report UNIQUE WORDS: 1,656 Total OCCURRENCES: 7,443 Noise words: 391 total Words in FILE: 20,505 SINGLE FILE CONCORDANCE CASE SENSITIVE Noise Word list(s): NOISE.NOI INCLUDES ONLY TEXT OF: QUESTIONS ANSWERS COLLOQUY PARENTHETICALS EXHIBITS DATES ON INCLUDES PURE NUMBERS possessive Forms ON - DATES - August, 1983 [1] 109:2 August 18,1993 [1] 136:14 February of 1986 [1] 74:17 January, 1986 [I] 109:3 June 1,1983 [1] 127:15 May [2] 134:11:135:10 May 16,1983 [1] 127:15 November, 1985 [1] 77:17 November, 1994 [1] 94:16 October 1,1997 [2] 19:11:20:3 October 3,1995 [1] 124:8 October 11,1971 [1] 105:12 October 15,1970 [1] 109:8 September 3,1970 [1] 109:12 September 25,1986 [1] 134:4 . -0 00004 [1] 61:14 00046 [1] 66:9 00047 [1] 65:21 00056 [1] 77:17 00058{2] 77:20; 79:21 00060 [1] 80:2 00186 [1] 129:9 00187 [1] 124:4 02018 [1] 130:11 -1- 1[8] 19:11; 20:3: 58:19, 20: 84:6,8; 105:13; 127:15 1/16 [1] 63:18 1/8 [1] 63:17 1017] 94:9; 95:5,19; 96:5; 99:13,14 10:00 [1] 58:19 11 m 101:21; 105:12 11:55 [1] 56:15 12 [3] 105:4,5:106-4 13 [1] 106-6 1332214 [1] 66:22 14[2] 107:2, 3 140,000 [1] 107:16 15 [5] 95:20; 96:6; 109:8; 110:4,5 150 [1] 141:13 16K 110:12,13; 125:6; 127:15 17 [4] 113:1, 4; 125:6; 127:8 18 [4] 115:19,22; 125:6; 136:14 19 [3] 118:10,11; 149:12 1910.1200 [1] 75:18 1935 P] 21:18; 22:1,2 1953 [2] 22:19; 26-2 1957 [1] 24:2 1967[2] 6:11; 26:10 1970 [19] 27:3; 28:22; 29:1; 31:15, 18; 32:12; 33:15,17; 40:12; 44:21; 45:17; 46-8; 81:1; 109:8,12; 113:22; 114:4, 7; 141:4 1970s P] 115:7,15 1971[3] 104:18/105:12,16 1972 [4] 6:12; 8:10; 9:18; 104:19 1973 p] 26-11; 103:21; 104:11 1974 p] 106:7,13,14 1975 [1] 129:18 1976151 29:19; 33:1,19,20; 35:19 1978 p] 10:21; 11:6; 25:6 1980s (2] 135:13; 145:11 1981 [1] 6:18 1982 [1] 16:8 1983 [5] 6:21; 106:12; 109:2; 127:15 1984 [1] 16:22 1985(2] 32:6; 77:17 1986 p] 74:17; 109:3; 134:4 1987 p] 6:22,-42:10,14 1988 7:7; 17:13; 137:13; 139:14 1990s [2] 81:11,-145:11 1992(1] 114:7 1993 (4] 18:6,17; 114:7; 136:14 1994(1] 94:16 1995(2] 81:11,-124:8 1997(4] 19:11,-20:2,3,-54:19 1998(1] 139:9 1:00(1] 55:J6 1:07(1] 5Z-J 2(4] 59:4,12,13; 105:13 20 P] 99:10,-119:6, 7 200 [1] 141:13 21(6] 119:7,10; 120:20; 125:3; 126:21; 127:10 2135(1] 5:2J 22 P] . 120:7,10; 125:4 23(2] 120:22; 121:3 24 P] 124:12,13; 126:22 25 p] 124:13,16,-134:4 26(1] J25-2 27 p] 126:14,17 28 P] 127:16,-128:1 2854(1] 6:2 29 P] 128:10,12 -3- 3(15] 60.-22; 61:8; 69:13,19, 20; 70:6,20; 84:8; 86:15; 88:13; 99:16,19; 105:13; 109:12/124:8 30 P] 105:9; 129:3, 6 30th [1] 94:15 31 [1] 130:6 32 P] 131:17,21,-134:16 33 p] 131:21; 132:2 34 P] 133:14,16 35 p] 133:16,19 36 P] 137:2,3 36-inch [1] 127:8 56:13 50s [1] 93:19 530(1] 107:5 55(1] 76:9 56(1] 76:11 579(1] 109:10 59(1] 77:20 -6- 6(12] 65:17, 20; 67:8,10,16; 69:17, 21; 70:3,19; 71:2; 84:10; 92:14 60 [1] 79:14 60s p] 25:3, 4; 93:19 61 [1] 79:14 62 [1] 81:21 65 m 83:5; 84:2 67(1] 83:5 -1~ 7(4] 74:2,13; 75:20; 92:14 70(1] 85:3 70s [5] 135:13,15,16; 136:4 71 PI 83:16; 84:2; 85:3 73 P] 76:10/83:17 78 P] 12:16; 60:3 -8- -4- 4 [7] 63:21,22; 84:9; 105:13; 119:14; 120:19; 126:21 4-by-4-by-4 p] 97:21/117:6 45 P] 130:17,19 48084(1] 5:21 48309(1] 6:3 435(1] 148:11 4P P] 126:18/127:7 -5- 5 P] 64:11,12 504(1] 8(6] 75:11; 76:9,11; 77:20; 87:21; 88:7 80,000 P] 108:11,15,17 80s [4] 45:9; 64:19; 81:14; 136:4 834-2612 (1] 56:13 -9- 9 P] 93:14,16 90sp] 45:9; 64:20 92(1] 60:3 -A- A-R-E [1] 108:12 ACE-FEDERAL REPORTERS, INC. 202-347-3700 From August, 1983 to A-R-E a.m. |2} 56:15; 58:19 ABB [1] 82:16 ABB2569FF [1] 82:15 Abex P5] 41:16,19; 42:2, 7,11, 15; 50:20; 51:5,10,14, 15,16; 55:11; 67:15; 81:21; 82:18; 83:5,15, 21; 88:5,12; 89:8; 91:14; 98:14; 100:1, 6,16; 102:5; 103:17; 127:17; 128:6,13,22; 129:1,17 able [1] 136:2 accurately [1] 149:3 across-the-board [1] 72:5 actions [1] 123:17 active p] 9:15,19; 10:1 activity [1] 17:1 actual [1] 129:22 added [1] 1819 addition {2} 18:17; 27:9 additional [2] 1819; 88:17 address [6] 5:19,20; 6:1, 2; 60:1; 134:1 addressed p] 102:18; 129:1 addressing [1] 32:20 adequate [1] 139:17 adhesive [1] 117:18 Administration [2] 181; 104:10 administration p] 18:14 Advanced [1] 120:13 advised [1] 105:13 affects [1] 74:22 aftermarket [9] 11:21; 12:1; 37:4,5, 7; 72:15; 74:20; 75:2,5 AFTERNOON [1] 57:1 agree p] 103:14; 104:6; 105:15 agreements [1] 136:7 air [9] 59:7; 62:3, 4,5, 7,11; 63:7, 9,11 AIT [1] 10:3 allegations [1] Ascjiu at: ckUCE E. KKTCHAM (Douglas aal vs. Allied-Signal, Inc.) 1-22-99 141:21 Allied [6] 41:4,10; 76:14; 98:15; 100:1:103:17 allowed [1] 59:10 altering [1} 91:5 alternative P] 61:19,22 America [1] 27:4 American [4} 26:8; 48:11; 55:15; 102:13 amongst [1] 66:17 amount [1] 104:7 analysis p] 28:4; 85:4,9 answer P] 23:9; 33:9; 87:4;94:4; 95:8; 103:3; 134:10,21 answered P] 95:1; 135:4; 136:15 answers [4] 21:9; 135:1; 136:18,19 anybody [1] 23:14 anyplace [1] 66:4 anyway [1] 74-20 apologize [1} 99:17 apparently P] 102:19; 124:9; 134:16 appear [13] 69:18; 78:16,21; 80:10; 82:6; 83:20; 84:15; 8617; 102:13,17; 10814; 124:7; 130:2 appeared p] 82:12,14 appears [17] 66:1; 69:6; 76:14; 77:22; 79:22; 80:2; 83:14; 84:17; 95:14; 109:19; 110:9,20; 121:19; 126:10; 128:8; 129:11, 17 applicable [1] 90:8 application [6J 68:6; 72:1; 79:20; 80:7; 100:12; 114:21 applications [6] 80:12; 84:13; 101:1; 115:2; 133:3,4 apply [1] 6819 appreciate [1] 56:13 approval [1] 48:22 approved p] 48:21; 49:2 approximate pj 26:13;45:8 Approximately [5] 9:20; 26:10; 32:6; 42:10; , 64:18 j approximately [7] ' 1&8; 24:2; 26:9; 45:5; 46:13; 56:2; 137:13 area [4] 18:20; 108:6; 137:21, 22 areas p] 9:5; 18:13; 132:20 Army [1] 9:15 arrangements [1] 56:1 arrived [1] 12:20 Asbestos [4] 74:15; 9821; 105:8; 109:21 asbestos [99] 32:8; 40:19, 22; 41:1; 53:2,9; 61:2; 62:6,8; 67:3,5; 74:18, 22; 75:1; 77:5, 7, 8; 786; 80:6; 83:2, 6; 84:16,18; 93:19, 22; 94:19; 100:17,20; 101:1,3, 4; 10221; 103:6,12,18; 104:13; 105:15,16; 106:17,20; 107:6; 109:11,12,17; 113:18,20; 114:1,5, 8, 17,20,-115:10,17; 117:14,16,20; 118:3,4; 121:12; 122:3, 6; 123:3, 15,19; 124:21; 126:5,8, 11; 127:18; 128:6,16, 22; 129:2,19; 130:18, 19; 131:1, 5,10,14; 134:7,-135:3,12,14; 136-3; 137:15; 13810; 140:1,2,10,12,17, 22; 141:11; 142:1,2; 145:3 Asbestos-containing 3] 42:3,8,-44:10 asbestos-containing p3] 32:12,15,16, 20; 39:16, 19; 41:5,21; 42:7,22; 45:2, 6,11; 46:9,14; 54:2,9; 61:7, 20; 62:1; 64:15; 65:8; 80:1; 83:17; 95:22; 98:13; 100:6; 133:22; 134:14; 145:7, 13,19,-146:3 asbestosis [1] 110:2 Ashtabula [4] 27:5; 32:18; 109:6, 7 asking 5] 31:3; 85:9; 13812 asks[l] 102:19 assemble p] 27:1,-45:10 assembled [7] 32:16,20; 39:21; 40:14, 18; 68:13; 89:21 assemblies [12] 27:9; 34:21; 38:12; 40:5; 64:21; 80:8,9; 86:17,21; 97:1,4,18 assembly [?] 14:2,16,17; 37:11; 80:19; 8618; 92:19; 108:11,-121:5 assignment [1] 10:12 assisting P] 18:8; I486 associated [9] 28:12; 86-11, 21,-93:22; 94:19; 109:17; 135:3,11; 139:22 Associates [1] 109.-20 associations [5] 93:3, 7, 8, 28; 94:18 assume p] 65:13; 784; 103:13 assumes [1] 131:4 assuming [1] 93:11 assuring [1] 137:17 attach p] 59:11; 60:22; 63:20; 67:7; 82:19; 90:3; 93:16; 95:18,-137:1 Attached [1] 81:21 attached [16] 27:10; 31:8; 63:3; 68:21; 71:7,10; 72:10; 75:14; 81:19; 85:8; 86:9; 88:6; 101:22; 126:12,13; 130:9 attaching [1] 90:5 attack [1] 114:13 attempting [1] 126:8 attempts [1] 123:4 attended [5] 6:9,11,17,19,20 attention [1] 109:9 attorney p] 59:1; 104:9 attorneys P] 136:19; 142:7 August p] 109:2; 13614 automobile [4] 9:8; 35:4; 1181,3 automobiles [1] 3Z-17 Automotive [10] 11:16; 19:2, 6,9,20; 20:5,15; 34:21; 35:2; 76-15 automotive [13] 10:17; 11:1; 12:11; 19:10,12,13,14; 26-4, 22; 35:3; 144:16,18; 147:10 available [4] 112:19; 113:10; 115:6; 117:16 Avoid [1] 77:7 aware pi] Lflck-Scg(2) 24:18; 45:20; 46-1, 4,21. 47:2, 5,8,11,14,16; 49:19; 57:16,19; 58:1,4, 7,10,13,16; 74:22; 93:18, 22; 100:14; 104:9, 14,-105:14,21/140:3,5, 21 Axle [16] 22:3,5,11,13,19, 20, 22/23:2,18,19; 24:7, 11,16,-25:8,12,-26:3 axle [14] 1617,19,21; 17:2, 3; 27:10; 682, 6,14,17, 22; 71:7; 72:17; 73:8 axles [12] 12:8; 17:7, 8; 27:10; 6616; 68:12,13; 71:10; 72:12 -B- B-4123 [1] 7617 B4o*[l] J5.-15 B-O-R-G [1] 43:6 B-r-a-m-p-t-o-n [1] 30:6 background [1] 6:5 backing [18] 31:7; 62:8,12,18,20, 21,22; 63:4,8,10,14; 64:7,15,22; 65:6,9,14; 89:18 balance p] 75:14,-124:6 banded [1] 96-16 banding [1] 97:21 Based p] 25:11; 81:12; 129:9 based P] 114:16, 20; 130:2 Base [1] 10:5 basic p] 10:2; 59:9 Basically [2] 34:12/92:18 hascaSy p] 27:19; 36:13; 141:21 baas [1] 63.-4 Bates p] 61:14; 65:22; 769 Battle [3] 27:6; 31:22; 32:18 bearing [1] 68:13 bearings [1] 13:12 becomes [1] 117:5 belief [5] 71:8; 104:3; 122:8,18, 20 believe [28] ACE-FEDERAL REPORTERS, INC. 202-347-3700 From a.m. to believe BSA 6:18; 7:7; 22:2, 20; 25:3; 26:13; 43:21; 45:16; 59:9; 60:1,12,18; 63:2; 70:9; 74:14; 81:12; 84:3; 94:2; 98:15; 99:3,19; 100:9; 114:6; 122:21; 133:1; 136:21; 140:9; 144:17 Bendix [9] 41:7,13; 76:15; 98:15; 99:22; 100:7,16; 102:2; 129:16 Besides [1] 140:20 besides [3] 29:6; 60:9; 130:22 Bill [2] 56-8; 143:21 bind [1] 89:18 bit [63 9:7; 21:20; 22:5; 68:8; 81:18; 135:16 block [10] 76:17,21,22; 77:1; 83:12; 84:6; 89:11,15; 102:11; 130:3 Blok [1] 55:15 bodily [1} 77:9 body [1] 111:21 bolt [2] 103:12,18 bond PI 63:8; 80:20 bonded [2] 63:6; 89:14 Bonding [1] 64:3 bonding p] 63:4; 64:4 Borg-Warncr [1] 43:6 bought [1] 58:11 box [11] 51:12; 54:4; 91:20; 96:19; 97:3,11; 103:4; 117:2,19 boxed [1] 51:1 boxes [13] 50:14,15,20; 51:2, 8; 52:7,10,14,20; 117:4, 5,13; 127:19 boxing [1] 54:9 Brake [9] 30:22,-31:6, 7; 42:17; 46:19; 47:1; 55:15; 57:14,18 brake [162] 13:14,15, 22; 14:1,15, 17; 17:4; 22:13; 26:22; 27:9; 31:1, 9,12,19,21; 32:2,13,15,17; 34:21, 22; 35:4,13; 38:12; 39:19,20; 41:19,20; 42:21; 44:10,11; 45:2, Depo of: BRUCE E. KETCHAM (Douglas dal vs. Allied-Signal, Inc.) 1-22-99 Look-See(3) 10; 49:22; 50:5, 6; 51:5, 6,14; 52:5,13,-53:2,5, 9; 54:2,11,15,19,22; 55:6; 59:7, 8; 61:3,17, 20; 62:1; 63:6, 7,9,11; 64:5,21; 66:15,21; 67:1, 3; 68:2,5,13,18,21; 71:6; 72:17; 73:8; 76:17, 20, 22; 77:1,2; 78:3,4; 79:1,8,-80:1,3,10,11, 15; 81:4; 82:5,11,21; 84:16; 89:7,21,22; 92:9, 17,-95:22,-96:9,15,22; 97:9,18,-98:13,14; 100:11,18,21,-103:22; 104:6; 107:6,11; 108:1, 4,5; 110:20; 113:14; 114:4; 127:15; 219:13; 122:7; 125:16; 126-13; 127:18,-128:16,-130:22; 131:1,5, 6,9; 133:22; 134:14; 136:8; 141:1,12; 142:1,-146:3,19; 147:1, 12 Brakes p] 64:4,-126:18 brakes p2] 12:9; 62:3,4, 6, 7,12; 68:16,-71:11,-72:10,12; 73:9; 111:21; 112:1, 2,4; 116:5, 6; 119:16; 120:14, 15,-124:20,-127:7,8,9, 11,-130:16,-132:4, 7; 133:1, 7 Brampton p] 30:5; 48:12 brand [1] 72:2 breadth [1] 147:7 break [8] 36:8; 80:19; 81:15; 92:19; 113:7; 131:19; 133:9; 148:3 Breathing [1] 77:8 brief PI 103:3; 105:20 brochure p] 112:21; 116:6; 137:7 brochures [5] 111:18,-116-2,-120:2; 125:5,-137:6 BROCKMAN p] 57:8; 143:21 Brockman pj 56:8; 143:21 BRUCE p] 5:3; 57:3 Bruce [4] 5:20; 23:10; 58:18; 143:8 bulk [1] 97:9 business [7] 5:20; 11:22; 18:15; 19:14,19; 69:3; 75:1 businesses [5] 8:18; 19:10,12; 20:14; 22:14 buy [9] 42:18; 43:5,11,19; 45:17; 46:18; 47:3,9; 66:11 buying [4] 42:1, 6; 110:16,17 -c- Cadei [1] 94:10 CALI [19] 5:13; 50:21; 67:9,13; 73:20; 84:20; 87:20; 88:2; 89:1, 4; 92:6; 98:7, 10; 101:7; 102:3,6; 103:7,10,-105:1 Cnlip] 67:14;98:11 California [4] 30:7; 37:2; 48:8; 94:12 call [5] 49:8,15; 55:22; 56-2; 101:15 Cam-Master P] 120:14; 130:15 Canada [1] 134:20 cardboard [1] 97:19 Carlisle [13] 43:12; 52:1, 6,9; 66:3; 67:1; 78:2; 79:11; 80:17; 102:2,-129:15,16 Carolina [5] 27:6;32:4, 8; 53:6; 65:14 CaroBnas [1] 40:16 cars p] 144:17,19,22 carton P] 96:10,15 CAS [1] 66-22 case [6] 5:17; 67:19; 94:10; 95:1, 2,11 cases [4] 141:2, 4; 142:20; 143:1 categories p] 12:8,-13:11 calory [1] 132:7 Caterpillar [1] 124:8 caused [1] 105:15 caution [1] 77:6 ceased [1] 33:6 center p2] 14:19,21; 15:22; 16:6; 25:8; 28:20; 29:21,22; 30:1,-33:2, 7,11,12, 21; 34:5, 7,14,15; 35:8,21; 36:15; 37:1 centers [4] 29:11,13,16; 48:4 central [1] 142:16 CERTIFY [1] 149:1 cetera [1] 72:7 CFR[1] 75:18 change p] . 18:21; 22:21; 26:6 changed [8] 10:11; 15:11; 18:16; 26-3,11,-81:1; 98-3; 116:17 changes [4] 87:10; 139:7,16; 149:4 characteristic [1] 110:1 characteristics P] 114:22; 115:1 characterize [1] 91:16 chart p] 59:3,18 check [1] 101:13 choice [1] 147:1 Chris [1] 12:19 Cincinnati [1] 6-17 claim p] 140:20,21; 141:22 claims [11] 18:10:141:11,14,18, 20; 142:5, 6, 7, 8,10; 143:6 clarify [8] 82; 9:7; 23:10; 28:2; 36:13; 37:15; 39:17; 101:17 Clayton [1] 109:20 closed [1] 33:1 clutch [4] 40:4, 5,7,17 Coast p] 30:7,-34:5 code[l] 97:12 College [1] 6:11 college [5] 7:20,-8-4,6,8,10 column [1] 107:8 coming [5] JS>:5,6; 102:22; 128:22; 129:19 commission [1] 149:19 common [5] 71:9,18,20; 73:10; 82:17 Communication [1] 75:17 communications [1] 17:18 comp [1] 141:17 companies \7] 38:8; 49:11; 57:11; 98:22; 134:2; 145:20; 147:1 Company pi] 8:9; 22:3, 6,19; 23:3; 39:2,6,11,-42:19,-43:3, 20,-44:1,4,21,-45:3,7; 46-16,20,-47:1,10,13; 58-6,9; 124:8; 144:6, 9, 10; 145:4, 7,13,19 company p4] 17:10; 19:3,12,17,18; 20:3; 23:20; 24:5; 25:20; 33:21; 45:22; 4817; 55:14; 60:13,14; 66:17; 73:13,14,-105:13,16, 21; 106-2; 111:14; 134:22 compare [1] 79:15 comparing [1] 102:16 comparison p] 69:21,-84:5,-85:10 competitors [1] 147:2 compilation [1] 59:10 compiled [1] 78:1 complaining p] 103:19; 129:18 Complaint [1] 105:9 complaint [1] 103:15 complaints [1] 102:14 complete p] 16:11,-105:19 completely [1] 60:2 compliance [5] 17:11,15,18; 75:17,19 component P] 31:7; 78-6; 123:5 components [8] 68-13; 71:18; 90:2; 113:8; 115:5, 8; 144:21 composition [1] 131:13 compound P] 67:5; 68:4; 115:16 compounds [1] 115:9 computer [1] 18:15 conceivable [1] 112:11 conceivably [1] 99:6 concern [6] 106-17; 121:4, 8,10; 128:6, 21 concerned p] 15:3,-16:9,-102:9 concerning [4] 134:7; 136:2; 139:22; 143:1 concerns P] 121:4; 128:13 concluded [1] 148:12 ACE-FEDERAL REPORTERS, INC. 202-347-3700 c. D--J! BSA_________ _ condition [1] 142:3 conducted [1] 140:8 conference p] 55:22; 56:2; 101:15 configurations [1] 68:14 connection [2] 67:18; 71:7 consist [1] 108:3 consisting [1] 147:17 consists [1] 115:9 construction p.] 72:19; 116:8 contain [71 40:22; 61:11; 62:6; 99:22; 117:3, 4,5 contained [8] 34:22; 40:18; 41:1; 61:2, 6; 62:8; 117:16; 124:21 container [2] 96:17;117:6 containing [4] 106:9; 118:3; 130:19; 145:3 Contains [1] 77:7 contains [6] 67:3,5; 103:18; 124:4; 131:1,5 content [2] 100:10; 130:18 continue p] 54:6,15,-106:16 CONTINUED [1] 73:21 continued [4] 23:6,12,15; 54:19 continues [1] 54:11 continuing p] 65:22; 705:8,15 continuously [1] 44:13 contract [2] 18:13,14 contracts [1] 75:20 Control [17] 43:12,17,-51:20,22; 66:2, 6,12; 67:15; 78:1; 88:5,12; 91:15; 98:15; 100:1, 7,16; 103:16 control [12] 10:15; 15:8,10,11,14, 17,19,-16:2,4,9,12; 104:12 controls [1] 104:4 convened [1] 56:2 convey [1] 140:1 . conveyed [1] 139:5 coordinating [1] 17:1 Depo of: BRUCE E. KETCHAM (Douglas dal vs. Allied-Signal, Inc.) 1-22-99 Lflok-Ses(4) corporate [8] 21:12,15,16; 23:22; 60:19; 135:7; 143:5,11 Corporation p8] 7:11; 26:12; 38:8,10,17, 22; 39:4,9; 41:3, 8,13, 16; 42:2, 7,12,16; 43:6, 13; 45:19; 46:3, 6; 47:7; 52:1, 6; 55:11; 57:13; 66:3; 76:15; 81:22; 83:6, 16; 94:10; 102:2; 127:17; 129:17; 134:1; 143:5 corporation [7] 20:6, 7,9,11,22; 23:21; 43:9 Corporation's [1] 725:74 corrections [1] 149:4 correlation [1] 50:75 correspondence [1] 21:10 counsel [11] 18-9; 95:7; 137:16; 138:2,7,-142:11,13,14, 16,17; 143:16 counter [6] 72:22; 112:19,21; 113:11 country [4] 33:4,12,-142:15,18 couple [7] 18:13; 57:11; 92:13; 141:15,-144:3,8 course [1] 54:19 Cover [1] 82:22 cover [6] 57:12; 69:6; 75:14; 82:21, 22; 108:7 covered [1] 50:77 cranes [1] 777:2 create [1] 121:12 creating [1] 77:8 creation [1] 128:17 Creek p] 27:6; 32:1,18 criteria [1] 48:22 ' current [1] 7:16 customer p] 35:2, 3,10,20; 48:21; 68:15; 111:10,11; 115:22 customers p3] 16:14; 17:17; 28:7, 8,14; 34:20; 35:1; 49:2; 59:22; 69:8; 74:19,20; 75:5,16; 110:16,22; 111:6, 7; 127:12; 135:14; 136:3; 137:8; 140:1 -D- damaged [7] 121:5, 9,10,11,14,18, 20 dangerous [1] 121:12 dangers [1] 735:22 Data [1] 64:3 data p7] 59:9; 61:16; 66:1,15,19, 21; 67:2; 70:21; 74:18; 75:16; 77:22; 79:3,12, 22; 80:3; 81:22; 83:2, 4, 6,16; 84:1; 130:9, ID, 14; 133:21; 134:6,18 date [13] 610; 16-7; 26:13; 45:8; 77:10,16; 81:10; 104:14; 106:13; 108:21; 109:2; 134:3; 140:11 dated [7] 705:77; 106:7; 109:8; 124:8; 127:14; 129:18; 136:14 dates \2[ 109:1; 129:15 day pi 56:17; 94:15; 149:11 dealer [1] 112:9 . dealers p] 113:9; 125:14; 132:16 dealership p] 112:7 dealing [4] 10:17; 139:8; 140:2,10 dealt [2] 78:4;124:19 decade [1] 146:22 decide [1] 100:20 decision [2] U4:16;136:2 decisions p] 100:19,20 defend [1] 142:7 ddense [l] 18:9 ddine [4] 44:8; 54:3; 62:15; 115:8 definition [2] 45:18; 71:16 degree [1] 7:13 degrees [1] 6:12 Department [2] 705:5, 70 Depending {2] 35:10,-89:20 depending [2] 92:16,-108:5 deposition [13] 27:4, 7,-56:10,15,-58:18; 88:21; 95:19; 135:7; 137:2; 143:12; 148:10, 11,-149:2 depositions p] 142:22; 143:5 discusses [1] describe [4] 116:14 9:4; 62:22; 64:4; 130:10 discussing [1] described [7] 76-6 55:2; 702:20; 116:6; Discussion [7] 122:17; 125:22; 132:22; 26:17; 55:20; 67:11; 136:4 89:3; 98:8; 101:18; 148:7 describes [1] disk p] 702:27 40:17,-61:17 describing [1] disks [1] 723:2 40:5 description [4] display [1] 9:4; 31:10; 91:8; 110:21 772:20 design [6] dispute [1] 100:21; 123:4,10,15, 703:4 18; 138:5 distinguished [1] designation p] 113:12 82:18; 114:13 distribute [4] designed [1] 27:18,20; 33:3; 112:14 68:16 distributed [6] destined [1] 111:4; 125:15; 132:11, 72:1 14,19; 137:7 details [1] distributing [2] 59:17 29:18;54:9 Detroit [12] Distribution [1] 6:22; 22:3,5,11,19; 29:3 23:2,18; 24:7,10,16; distribution [43] 25:8,12 74:79, 20; 75:9, 22; 76:6; develop [4] 25:7; 28:15, 20; 29:11, 21:17; 115:3; 126:8; 13,16,21,22; 30:7; 137:14 32:22; 33:1, 7,8,11,12, development [6] 20; 34:4, 7,10,14,15; 60:5; 81:9; 114:18; 35:8,21; 36:15; 37:1; 115:15; 137:5,10 38:7; 48:2,15; 50:11; difference [6] 55:2; 111:5,12; 120:3; 37:5; 75:73, 75; 83:22; 125:17,-126:1,20; 107:22; 126:19 132:16;134:15 diffa-ences [1] distributions [1] 84:6 50:77 dimensions [2] distributor [9] 63:16,19 27:21; 28:20; 49:14; direct [1] 50:12; 73:7; 96-12,21; 35:9 98:4,-122:16 directed [10] distributors [7] 110:22; 111:15,16,17, 49:7,9,10; 60:9; 110:17; 19; 112:8; 116:1,8; 112:14,16 133:2,-140:18 Division [6] direction [1] 76:16; 102-1,12; 129:10, 114:16 16; 130:4 directive p] division [8] 75:4, 20; 117:22 76:76, 77,18,20,21; disagree [1] 20:5; 43:12; 66:2 104:17 document [84] Disc [1] 21:9; 59:12,16, 20; 60:2, 64:3 6,13; 63:21; 64:2, 6; disc [12] j 65:21; 66:4,9,14; 67:17; 59:7; 62:3, 4,5, 7, 72; 1 74:3, 8,11,12,14, 76, 63:6,9,11; 64:5; 68:20; , 79; 75:12,13; 76:2; 77:4, 703:6 1 7,11,15; 79:4; 85:20; discontinue [1] 93:4; 105:8,10,12,18, 46:13 20; 106:1, 7,10,-107:1, discontinued [6] 13; 108:21; 109:1,16, 24:17; 42:6; 45:6,15; 18; 110:8,15,18, 21; 46:15; 64:15 113:5,8; 116:3,4,11, discovery P] 12,17; 118:2, 8; 119:11, 67:18; 134:22; 135:1 12,20:120:11,19; discuss PJ 121:6; 122:17, 22; 123:1; 103:6; 105:11; 129:2 124:4,17; 125:1,11,21; discussed [7] 1264, 6; 128:13,19; 67:17; 71:5; 76:16; 94:3; 129:5; 130:8; 132:11; 125:2,-140:12,17 134:11 ACE-FEDERAL REPORTERS, INC. 202-347-3700 JUA Documents [1] 113:6 documents [24] 21:3,11,14; 55:18; 75:15; 76:5; 81:19, 20; 84:3; 85:7,15; 102:9; 112:15; 123:1, 6; 124:2, 3,7; 127:21; 128:5; 129:22; 130:1,2; 140:15 doesn't pj 47:21; 100:10 Donna [1] 94:13 doubt [1] ii2.*3 drill [1] 90:6 drilled [1] 107:18 drive [2] 12:9; 68:12 driving [I] 17:7 drum p] 68:18,20 duly p] 5:4; 57:4 dust [19] 77:8; 102:22; 103:12,18; 104:7,12,13; 106:9,17, 20; 127:18; 128:6,17, 22; 129:2,19; 141:1; 142:2 Duty [12] 35:13; 39:13; 59:22; 60:10; 69:15; 70:5; 71:3; 72:22; 73:3,4,5; 88:14 duty p] 9:16,19; 10:1 -E- eariy [7] 45:9; 64:20; 81:14; 109:12; 115:6,15; 136:4 ECHOLS [8] 12:18,22; 56:4; 57:7; 143:15; 144:2,5; 148:2 Echols p] 12:19; 14452 economics [1] 6:13 edgefl] 97:12 education p] 6:14; 139:22 educational [1] 6:4 effect p] 75:8; 104:11 effective P] 19:11; 104:19 Electric p] 8:9; 10:10 electrical [1] 6:13 electronics [1] 19:19 elicited [1] 60:13 elimination [1] Depo of: BRUCE E. KETCHAM (Douglas etal vs. Allied-Signal, Inc.) 1-22-99 LackSaiSi 81:13 embedded [1] 65:2 emergency [X] 104:18 employed p] 7:20; 138:3; 142:17 employees [8] 74:5, 8,10; 104:13; 118:17; 119:1,3; 124:5 employes p] 104:12; 124:18 employment P] 7:18,22 Enclosed [1] 66:15 enclosed [1] 122:2 encompassing [1] 108:6 end [5] 111:19; 112:6, 7; 132-17; 148:9 engineering P] 6:13; 87:10 engineering-type [1] 5:22 ensure [1] 139:18 entities P] 60:21; 93:10 entity [1] 99:20 equate p] 86:2,15 Equipment p] 39:11,13 equipment [8] 14:11; 36:4; 92:4; 116:7; 127:10,11; 132:8; 133:11 established P] 129:8,12 estimate [5] 25:1; 64:19; 81:11; 141:8,10 estimation [1] 99:8 et[l] 72:7 evaluating [1] 9:5 Eventually [1] 26:11 everybody [1] 23:7 exact PJ 81:10; 141:7 Exactly p] 22:17; 23:5; 130:18 exactly [7] 15:10; 49:3; 59:19; 60:19; 125:20; 127:21; 140:18 EXAMINATION [10] 5:14; 67:12; 73:21; 88:1; 92:7; 98.9; 101:9; 103:9; 105:6; 144:4 examined p] 5:5; 57:5 example p] 73:12,15:82:15 exceptp] 5:8; 53:6; 92:19 exception [1] 134:16 excessive [5] 106:9,17, 20; 127:18; 128:6 Exchange [1] 21:1 exclusion [1] 72:21 exclusively [1] 72:14 Excuse p] 26-14; 101:12 excuse P] 44:5; 54:18; 62:21 Exhibit pi] 58:19,20; 59:13; 61:8; 63:22; 64:12; 65:17,20; 67:8,10,16; 69:17,19, 20,21; 70:3, 6,19,20; 71:2; 74:2,13; 75:11,20; 76:9, ID; 77:20; 86:14; 88:13; 93:14,16; 94:9; 95:5,18; 96:5; 99:19; 101:21; 105:4,5; 106-4, 6; 107:1,3; 110:4,5,12, 13; 113:1,3; 115:19,22; 118:9,11; 119:6,10; 120:7,10,20,22; 121:3; 124:12,16; 125:3; 126:2, 14,17,21,-127:16; 128:1,10,12;129:3, 6; 130:6; 131:17; 132:2; 133:14,19; 134:16; 137:2,3 exhibit [6] 69:12; 121:8; 123:12,13; 127:10; 133:20 Exhibits [5] 119:7; 124:13; 125:5; 131:21; 133:16 exhibits P] 70:1; 125:8 east p] 29:14,16 existed P] 34:10,-48:9 existence P] 20:4; 33:6; 38:5 expanded [1] 18:12 expect [1] 131:13 ecperience [1] J2.-10 expat [4] 71:12; 137:21; 138:1,4 expires [1] 149:19 explain [1] 118:4 explained [1] 147:7 exposed P] 62:19; 142:2 exposurep] 140:22; 141:11; 142:3 extend [1] 101:14 extended [1] 91:9 extent [10] 7:15; 50:22; 51:9; 52:8; 96:22; 97:8; 102:11; 104:1; 112:9,17 -F- F-r-u-e-b-a-u-f [1] 45:19 face [5] 76:20; 108:14; 109:19; 118:7; 128:9 facilities p3] 27:11,17/28:5,19; 29:8, 9; 30:9,12; 31:11,18; 32:10,12,14,-33:3, 5; 35:6,21; 37:4,17,19; 40:4; 53:15; 55:6; 96:1, 2, 4; 117:13 facility [61] 8:18; 11:11,19,20; 12:17; 15:14,21; 1613; 27:5, 6, 7,8,18; 28:15, 17; 30:4,7,19,20; 32:4, 22,-34:3,10,11,12,13; 35:9,14.16; 37:5; 38:3; 39:22; 40:1, 7,10; 48:5, 8,20,-49:4,15,16,21; 50:2, 8,11,12,-51:4,13, 18; 52:5,13; 53:6,10, 15,16, 22;55:1,3; 102:22; 107:19 facing [1] 40:18 fact[l] 94:8 factory [1] 89:14 Fair[l] 147:20 faQp] 9:18; 12:16 familiar pO] 21:13; 38:6; 39:1, 7,10, 14; 43:14; 55:11,12; 68:3, 7; 82:13; 90:13; 93:2, 6, 9; 108:4; 123:3, 8,-136:6 fasteners [1] 13:12 feasible [2] 101:2 February [1] 74:17 fed[lj 139:14 fritp] 122:12; 139:3 mm 82:16 fibers [5] 77:7; 121:10,12; 122:3, 6 fibrosis [1] 110:2 Field [4] 119:14; 120:13; 126:17, 21 field [5] 12:4; 125:15; 127:6; 132:19,-140:3 ffle[l] 141:15 filed p] 77:17; 140:21; 141:14 filled [1] 134:16 final [4] 16:14; 19:22; 134:3; 138:9 finalized [1] 138:16 find [6] 30:13; 37:16; 70:18; 88:20; 94:20; 99:4 fine [6] 5:12,-56:4,5,6, 7; 105:1 fire[l] 133:11 firm P] 94:13; 95:15 first pO] 5:4; 6:19; 7:20; 11:8; 12:10; 66:8; 74:21; 78:2; 79:13, 2D, 21,-93:21; 114:11,12; 122.-9; 124:4; 134:14; 135:18; 137:12; 140:11 fitp] 80:18,-91:7 fits[l] 92:19 fiveP) 17:1; 28:5; 33:3 five-minute p] 36:7; 131:18 flatbed [1] 72:4 Fleet [12] 39:11; 59:22; 60:9; 69:15; 70:5; 71:2; 72:22; 73:3,4, 6; 88:14; 99:20 fleet [4] 69:5; 112:6; 116:8,9 Fleets [1] I 112:6 ; fleets [1] i 111.-17 Florence [50] 11:11,19; 12:17; 13:16, 18,19,21; 14:12,18; 15:1,6,13,21;27:8; 28:17,-29:6,9,20;30:4, 8; 32:20; 33:11; 34:12; 35:14,20,-37:1,5,20; 38:3, 4; 40:14; 48:5,15, 20; 49:4,16,20; 50:2,8; 51:4,13,18; 52:5,12; 53:10,14,22,-55:2 FMSI [1] 97:5 focus [1] 19:19 follow [1] 89:5 followed [1] 82:16 following [4] 8:10; 10:5; 84:5; 96:1 ACE-FEDERAL REPORTERS, INC. 202-347-3700 From Documents to following ESA_____________________________ follows (2] 5:5; 57:5 Fontaine [1] 39:4 force [1] 125:15 Ford p4] 36:19,20; 43:19,22; 44:4,20; 45:2,7; 4615; 72:3; 144:6,8,10; 145:4, 7,13,19; 146:4,8,11, 15,21; 147:6,22 Fords [1] 72:11 Form [6] 5:9; 50:21; 84:20; 91:13; 102:3; 103:11 format [2] 83:14,20 formation [1] 35:19 formed [1] 19:12 former [1] 20:14 formula [1] 76:17 formulas [1] 67:6 formulate [1] 23:20 formulated [1] 89:13 forth [1] 114:21 found P] 60:17; 115:15 frame [6] 145:10; 146:10,12,14, 17 Friction {3] 47:10,12; 76:15 friction P] 68:17,19 front [3] 17:8; 68:12; 130:16 front-end [1] 110:22 Fruehauf [3] 38:8, IQ; 45:18 Full [1] 8:1 full [2] 5:18; 11:21 full-packed [1] 118:2 full-time p] 7:21; 8:5 function [8] 8:19; 11:12,14; 13:4; 14:12; 15:15; 1&7; 139:11 functions [1] 7:10 - G- gamut [1] 11:21 Gardner [5] 94:14; 136:16; 142:14, Depo of: BRUCE E. KETCHAM (Douglas etal vs. Allied-Signal, Inc.) 1-22-99 16,19 gaveP] 114:17; 143:11 GEp] 10:20,22; 11:4 generalities [1] 21:19 generated [1] 122:6 generating [1] 122:3 Genuine pj 58:6,9 George [1] i09;20 gets[l] 110:18 give [10] 5:18,22; 56:11; 73:11, 15; 99:8,12; 139:20; 141:8; 146:10 given [6] 25:21; 46:10; 69:18; 142:22; 143:5; 149:3 giving [1] 10:4 Gtecm p] 59:2; 136:15 globally [1] 88:7 GM[5] 36:19; 37:17; 1464, 8; 147:6 GMs [1] 72:11 Goodrich p] 42:19; 43:3 government [1] 18:13 graders [1] 111:1 gradually [1] 114:8 graduated p] 6:8,12 graduation p] 8:4,10 gravity [1] 84:7 Gray P] 46:19; 47:1 gray [1] 92:11 grievance [6] 101:22; 102:10,18, 20, 21; 103:11 grind p] 90:18; 107:11 grinded [1] 103:22 grinding [10] 81:4, 6, 8,13; 90:21; 104:6; 107:10,11; 122:5; 142:1 ground [5] 104:1; 107:18; 108:12, 13,15 group P] 85:7; 147:17 guess [13] 21:17;33:3;48:3; 107:10,19; 108:11; 113:22; 121:12; 122:11, 13; 123:3,19; 145:17 guys [i] 38:9 -H- handed [1] 127:7 handful [1] 99:9 handle p] 18:12; 25:7 handled p] 13:4; 35:3 happening [1] 118:5 hard [1] 30:18 harm [1] 77:9 Harvester [1] 134:19 hate[l] 85:6 limiting [1] 133:12 Haygood [1] 35:22 Hayward [6] 30:7; 34:3; 9,11; 37:6; 48:8 Hazard p] 74:15; 75:17 hazard [5] 105:14,17,22; 110:1; 145:17 hazards [11] 84:10; 93:19,22; 94:19; 109:17; 135:3,11,14; 140:10,13,17 head [1] 145:1 headed [1] 56:9 heading p] 129:9; 130:3; 136:16 headquarters [1] 27:13 Health [1] 104:10 health [7] 84:9; 105:14,17,22; 110:1; 121:13; 135:2 Heard [1] 105:13 heavier-medium [1] 112:5 Heavy [12] 35:13; 39:13; 59:22; 60:10; 69:15; 70:5; 71:3; 72:22; 73:3, 4,5; 88:14 heavy p] 146-4,5 Heavy-Duty P) 46:19; 47:1; 126:18 Heavy-duty [1] 31:21 heavy-duty [10] 9:11; 31:12,19; 32:2; 72:6; 112:2; 113:17,18; 114:12/127:8 held [1] 22:14 Hello [1] 143:14 helping [1] 142:6 HEREBY [1] 149:1 High [1] 6:8 high [4] 6-7; 7:19; 8:3,6 Highway [1] fZ-22 highway [1] 116-7 Hills [1] 6-3 history [4] 7:19; 21:12,15,17 Holdmnster [1] 110:20 boles P] 103:13,18 Home [1] 6:2 home [1] 5:22 bour[l] 56-2 hours [1] 144:8 Hugh p] 59:2; 13615 hundred [1] 141:14 hundreds [1] 99:15 Hygiene [1] 109:6 -I- i.e.[l] 88:13 idea p] 23:15; 99:13 identical [l] JG2:i7 identification [1] 94:18 idaitifications [1] 82:15 identified [52] 58:20; 59:13; 61:8,11, 14; 63:22; 64:12; 65:17, 21; 66:9,19; 67:10; 69:14; 77:21; 86:14; 93:4,14; 95:5; 96:3; 98:12; 103:1; 105:5; 106:2,4:107:3,5; 108:18; 110:5,13; 113:1; 115:19; 118:11; 119:7; 120:7, 20,22; 121:2; 123:5; 124:13; 125:3; 126-2,14; 128:1,10; 129:3; 130:6; 131:21; 133:16; 137:3; 141:20; 143:2, 6 LafcSee<fi) identifies [4] 61:16; 78:10; 97:6; 108:16 Identify [1] 78:10 identify [13] 24:16; 61:6; 67:2; 70:4; 77:4; 87:13; 94:9; 102:8; 103:5; 120:11; 132:6; 146:13:147:9 identifying [1] 97:13 identities P] 83:19,-99:5 identity p] 82:3; 83:12; 84:6 implemented [1] 117:11 imprinted [1] 117:20 inadequate P] 139:4,14 Inc[l] 19:2 inch p] 63:17 ' inches P] 92:13,14 include [5] 12:8; 100:17,20; 140:9; 141:13 included [6] 119:17; 125:16; 135:16, 19; 137:19; 141:17 includes [1] 9:11 Incoming [1] 16-11 incoming [1] 15:17 Incorporated 112] 19:7,9,21; 41:5,11; 47:4; 57:15,18,22; 58:3, 12,15 incorporated [1] <53:10 incorrect [1] 53:13 incumbent [1] 104:11 independent [8] 20:9; 28:8; 49:7; 93:13; 95:9; 96:3; 111:22; 112:9 indicate [6] 66:11; 69:6; 82:7; 106:7; 109:16; 126:10 indicated P] 88:13; 103:22; 109:21 indicates P] 59:21; 84:5 indicating [1] 75:15 individual {?] 48:18; 49:12; 51:14; 67:6; 97:15; 117:13,15; 123:19/136:5 individual-type [1] 49:11 individuals [?] 74:4; 105:17; 116:13; 118:16,18; 121:13; ACE-FEDERAL REPORTERS, INC. 202-347-3700 From follows to individuals BSA 124:5;125:2;140:18 Industrial [1] 109:5 industrial [4] 6:13; 8:22; 109:22; 132:8 Industries {?] 43:12,17; 51:20; 58:12, 15; 66:2, 6,12; 78:1 industry [1] 109:11 information [11] 15:18; 24:16,20; 70:8; 88:17; 93:20; 112:10,12; 120:5; 127:13; 140:10 ingredients [1] 89:16 inhalation [1] 109:22 Initially [2] 18:8; 26:2 initially [2] 18:16; 27:20 inner-plant [4] 14:5, 7,14 input [4] 59:3, 6; 60:5; 138:7 insert [1] 125:16 inspection [1] l&U instance [6] 14:15; 69:3; 72:2; 73:17; 97:21; 112:20 instances [4] 68:11; 90:4; 114:19; 116:9 instructions [1] 119:15 Intended [1] 124:18 intended [12] 90:8; 92:2; 113:4; 119:19,21; 120:18; 124:17; 125:12; 126-12; 132:10,14,17 intent [1] 116:2 interchangeable [1] 87:2 intercourse [1] 100:14 interest [1] 20:16 interested [1] 90:11 internal [4] 13:5; 33:8; 111:5 International [16] 7:11; 11:5,20; 18:3; 19:9; 26-12; 41:3; 57:13, 17,20,-129:11,-130:5; 134:1,19,-143:4 interpret [5] 103:20; 108:19; 118:7; 121:21,-124:9 interpretation p] 69:11; 77:2 . interrelationship [1] 76:4 interrogatories [5] 94:5,13,22; 95:8; Depo of: BRUCE E. KETCHAM (Doimlas dal vs. Allied-Signal, Inc.) 1-22-99 136-13 interrogatory [5] 21:8; 60:12; 94:3; 95:20; 96:5 interrupt [1] 12:18 inventory [1] 15:19 investigation [1] 23:15 investigations [1] 17:17 involved [2] 142:5,19 involvement [1] 137:12 issued [1] 104:18 item [5] 37:10; 61:15; 66:5; 69:10,-97:15 items [7] 37:8; 40:22; 51:14; 84:7; 97:9,18,-140:5 118:11; 119:7; 120:7,22; 124:13,-126:2,14/128:1, 10; 129:3; 130:6; 131:21; 132:1; 133:16; 137:3; 143:17 Keteham's [1] 94:15 kit [4] 87:2,3, 6; 90:1 kits [3] 59:8; 61:2; 125:16 kitting [1] 16-13 KNIGHT p] 56:5, 7 knowledge [23] 45:9,12; 46:17; 47:18, 20; 55:9; 62:11; 70:2; 93:13; 94:7; 98-18; 100:19; 104:20; 109:10, 11,16; 114:3; 131:3; 134:13; 135:2,11; 143:11; 144:11 69:6; 75:14,19; 82:19, 21,22/83:1,-85:8; 106-19; 109:19; 118:13, 15; 124:7; 129:1,18; 134:17 . letters [14] 78:12/82:4,6,8,12,13; 83:13; 101:22; 102:8,15; 103:2; 127:14,16; 129:15 level p] 111:12,13 liability [1] 18:9 licensed] 7:6 licensed [1] 7:1 Life [1] 39:9 light [3] 72:6; 92:11 light-duty p] 113:19/114:11 -J- January [1] 109:3 job [5] 9:14; 10:11; 15:6; 16:15; 139:11 jobber [1] 49:14 jobbers [1] 49:8 Johns [1] 119:2 joined [1] 93:7 Julianne [1] 12:19 Julie [1] 144:2 June [1] 127:15 -K- Kenton [10] 27:7; 29:5,9,17; 30:16, 18; 31:22; 32:18,22; 33:6 Kentucky (9] 6:20; 11:11; 13:16,19, 22; 14:18; 15:13; 27:8; 40:14 Kenworth [1] 147:17 KETCHAM [2] 5:3; 57:3 Keteham [55] 5:16,20; 57:11; 58:18, 20,22; 59:12,13,15; 60:22; 61:8,13; 63:22; 64:10,12; 65:17,20; 67:10,14; 74:1,2; 75:11; 81:18; 87:18; 88:3; 93:14; 95:5; 98:11; 101:11,20,21; 103:11; 105:5; 106:4; 107:3; 110:5,13; 113:1; 115:19; -iL- label [16] 51:2,12,-52:11,21; 83:19; 91:22; 117:18; 123:10,15,18,21; 124:10; 126:5, 8,12; 139:3 ` labeled [8] 51:1, 2; 52-10,20; 96:10; 98-3; 117:13; 122:2 labels [9] 50:15; 117:19; 137:11, 15,17,18; 138:19; 139:7, 8 language p] 84:10,-138-6 large [4] 8:17/92:15; 117:2; 118:3 larger p] 72:10; 73:18,19 last [2] 45:16; 141:14 Late[l] 145:11 late [5] 45:8; 64:19; 135:12,15; 136:3 latter [1] 73:5 Laurinburg [1] 40:15 law [3] 7:1, 8,13 lawyer [1] 91:18 layout [1] 123:2 lead[l] 110:1 legal m 7:10,15 Let's [41 27:3; 86:15; 94:19; 148:3 let's p] 55:17; 100:12 letter [16] limited [1] 69:5 limits [1] 62:17 line [7] 114:10,11,12,14,15; 121:15/127:20 lined {3] 89:22; 107:21; 108:3 lines p] 12:9; 89:19; 90:15 lining [88] 14:16; 31:8,10; 52:17; 53:9; 54:16; 59:8; 62:9; 63:3; 64:22; 65:2, 4, 5; 66:22; 67:1,3; 68:5; 70:22; 77:3; 78:3,4; 79:1,9,-80:1,4,10,11, 15; 81:4; 82:5,11,18; 83:14,21; 85:20; 86:1,2, 7,8,9,10,11,12,16, 18,20,21/87:13,17; 89:7,13,14,15,16,18, 20,21; 90:1,4,6; 91:4, 11; 92:9,18; 97:5; 100:22; 106:9; 108:5, 7; 114:22,-115:1,3,10,11, 12; 121:18, 21; 122:11; 125:16; 130:22; 131:7, 10,11/134:14 Linings [1] 105:9 linings [101] 13:14, 22/17:4; 26:22; 31:1; 32:2,3, 8,13,15, 17,21; 34:22; 38:12; 39:20,21,22; 41:20; 42:17, 21; 44:10; 49:22; 50:5; 51:6,14; 52:6, 9, 13,17,18; 53:2, 5,14; 54:2,12,16,19, 22; 61:3,18,20; 62:2; 66:16; 65:2; 71:6; 74:19; 75:1; 80:5; 82:21; 84:16,17; 85:16,18,-90:14.18; 91:3; 95:22; 96:9,16; 97:9,12,18/103:22; Look-Se<7) 106:10,16; 107:6,12, 17,20,-108:1,4,8,17, 19; 113:14,18; 114:4, 19, 20; 115:16; 117:16; 121:5,9,11,18,20; 122:7,10,15; 124:21; 127:18; 128:16,22; 133:22; 136:8; 141:1,12; 142:1 list [11] 69:18; 70:22; 76:14; 87:12,18; 111:10,11; 112:11; 119:5; 130:17; 146:9 listed [11] 69:13; 70:19; 77:6,16; 84:10; 93:10; 109:1; 118:16,18,-125:5; 130:15 listing p] 67:1; 130:4 lists [5] 82:4; 83:7,13; 111:14; 120:4 literature [13] 21:9; 110:10; 112:18; 116:5/135:17,20; 138:20; 139:9,12,19; 140:4, 6 litigation [1] 18:10 load [4] 97:9,22; 117:6; 118:3 loaders [1] 110:22 loads [1] 118:2 local PI 102:19/142:17 located [1] 8:18 location [8] 8:16,17; 9:9; 11:18; 13:16,22; 15:7; 65:15 locations p] 12:14,-26:21 loose p] S9:2J; 122:10,16 lot[l] 25:15 Louisiana [4] 27:19,22; 34:17; 35:12 lung p] 110:1; 142:3 -M- M-E-R-I-T-O-R [1] 19:6 machine [1] 90:7 machinery [1] 111:3 machining P] 52:20,22 Mack p] 73:17/147:16 magnitude [1] 99:12 mailing [6] 111:10,11,14; 112:11; ACE-FEDERAL REPORTERS, INC. 202-347-3700 T?mm TnJi BSA______________________________ 120:4; 125:14 mailings (2] 111:5; 132:19 Main [2] 34:14,15 main [1] 34:13 Maintenance [3] 119:14; 120:13; 126:18 maintenance [13] 119:13,18,22; 120:5, 12; 124:19, 20; 125:4; 127:6; 132:13,17; 140:4 Major [1] 12:8 major [5] 13:11; 72:11; 146:4,19; 147:14 makeup [1] 115:10 management [1] B:13 Manager [1] 18:4 manager [13] 11:10,13; 12:17; 13:2; 15:8,12,14; 16-3,5,16, 20; 17:11,14 Manhattan [1] 98:22 manner [2] 7:14; 90:3 Manual [4] 119:14; 120:13; 126:18, 21 manual [8] 119:13,18; 120:12,19; 125:4; 126:20; 127:6; 132:13 manuals (3] 125:3,5; 137:19 manufacture [10] 13:13; 30:10,19; 39:15, 18,22; 53:2,5; 65:6,14 manufactured [10] 31:21; 32:4, 7; 40:14; 53:19; 68:11; 114:4; 119:16; 134:2; 146:20 manufacturer [13] 364; 37:14; 38:2; 52:18; 65:5; 76:12; 92:4; 97:7, 13; 100:22; 121:18; 122:7; 146:22 manufacturer's p] 96:18; 97:3; 128:16 Manufactures [1] 36:21 manufacturers (20] 14:11; 36:1,22; 50:14, 16; 72:11; 80:17; 89:13; 91:4; 103:1; 115:3; 121:21; 129:20; 134:8; 146:4, 5, 6, 20; 147:10, 13 Manufacturing p] 57:21; 58:3 manufacturing [15] . 8:13,18; 10:13; 14:9,17, 22; 15:4; 29:10; 30:9; 32:11; 35:9; 40:4; 73:14; 97:1; 113:13 Depo of: BRUCE E, KETCHAM (Douglas ^aJ vs. Allied-Signal, Inc.) 1-22-99 _____________________ Looic-iScg(S) ManviDe[l] 119:2 Maple [1] 5:21 Mark PI 47:9,12 mark [11] 58:17; 64:10; 74:13; 101:21; 105:4; 107:1; 110:11; 124:11; 127:16; 128:12; 133:13 marked [14] 65:19; 74:2; 75:11; 80:2; 113:3; 115:21; 119:9; 120:9; 124:15; 126:16; 129:5; 132:2; 133:18; 136-20 marker [1] 109:13 market [4] 111:8; 112:5; 147:7,15 marketing p] 139:21,-140:17 marketplace [1] 14&6 markets [1] 133:10 Martin [1] 95:15 mass [1] 141:15 match [1] 60:19 Material [1] 64:3 material [59] 61:16,17; 61:8,9, 21; 63:1, 2, 3, 8,10,12,13, 14; 64:16,22; 65:2, 4, 7, 9,14; 66:1,15,19,21; 67:2; 74:18; 75:16; 77:22; 78:5; 79:12,22; 80:3, 4,10,11,16,18; 81:5,22,-83:2,6,16,18; 91:20; 92:12; 97:5; 106:9; 115:1,11,12; 130:9,10,14; 131:11; 133:21,-134:6,18 Materials p] 76.-16; 102:1; 129:16 materials [18] 16:16; 17:1; 45:11; 61:7, 11; 62:10,12; 88:6,12; 98:14; 99:22; 100:6,18; 103:15; 104:7; 114:5,8 matter [1] 144:7 May p] 127:15; 134:11; 135:10 MBA [1] 6:18 mean [17] 5:10; 12:1; 14:7; 36:3; 44:6; 47:17,21; 62:14; 63:7,9; 65:8; 69:16; 70:12; 73:12,-90:20; 92:1; 103:14 means p] 31:6; 103:14 meant p] 90:2,-119:12 measures [1] 106:20 mechanic [1] 92:3 mechanical [1] 110:20 medium p] 72:6; 111:1; 147:14 medium-duty p] 113:17,19,-132:9 member [1] 93:11 memorandum p] 59:1,4 memory [5] 47:20; 88:8; 94:6; 95:9; 100:2 mention [1] 29.-8 mentioned [6] 30:10,14; 34:4; 46:12; 47:15,-144:8 Meritor [7] 19:2, 6, 9,20; 20:5; 54:17,18 mesh [1] 63:2 metal p] 31:7; 131:10,14 methods P] 8:20,21; 9:5 Michigan [6] 5:21; 6:3; 7:5; 27:6,12, 13 Midas [1] 111:21 Midland p] 46:18,22 Mike p] 67:14,-98:11 MIKIILA[401 5:7,10,12; 23:9; 25:13, 18; 26-14,18; 28:1,10; 30:11; 31:13; 36:16; 44:6,12; 52:15; 55:8,21; 56-11; 65:8; 76:1; 77:12; 81:15; 94:21; 95:16; 101:12; 104:20; 116:20; 122:13; 126:22; 131:4; 135:6; 138:12; 143:8,14, 16; 144:1; 148:3, 6, 8 MBada [1] 55:21 mind [1] 98:21 minimized [1] 81:7 minorp] 146:19; 147:14 minute [1] 22:8 missed [1] 57:11 mistaken [1] 108:17 mix [12] 82:18; 83:21; 86:2, 7,11, 16,22,-87:13,17,-89:7, 12;1I8:2 mixes [4] 70:22; 83:14; 85:20; 86:1 model p] 119:17; 132:6 modes [1] 125:17 Molded p] 102:1; 129:16 molded [1] 80:19 month [4] 107:17,18; 108:11,15 months [1] 9:20 morning P] 50:18; 59:16 Morton [1] 94:13 MOS [1] 10:6 Motion [17] 43:11,17; 51:20,22; 66:2, 6,12; 67:15; 78:1; 88:5,12; 91:15; 98:14; 100:1, 6,16; 103:16 motion [1] 9:1 Motor [14] 43:20,22; 44:4,20; 45:2, 7; 46:16; 144:6, 8,10; 145:4, 7,13,19 Motors [4] 36:5, 6; 46:3, 6 mounted [1] 68:21 moved [1] 12:16 MSDS [13] 68:1; 69:2,17; 74:22; 75:4, 7; 76:7; 81:20; 82:20; 83:4; 88:6; 89:8; 134:14 -N- Name [1] 39:14 namep7] 5:16,18; 22:10; 23:1, 2, 4, 6,8, 22; 24:5, 7,10, 17; 25:8,16, 20; 26:2, 6; 38:7; 39:7; 43:14; 50:3; 55:12,13; 59:2; 67:1,14; 93:10; 96:10,11,18, 21; 98:3; 99:21; 124:5; 130:15; 146:7 named [6] 27:17; 28:6,19; 31:11, 19;32:10 names [10] 30:12; 60:1,14,15,16, 19, 20; 74:9; 98:22; 116:13 NAPAp] 38.-15,-49:15 narrowing [1] 19:19 National [1] 17:22 Navistar [1] 147:16 neighborhood [1] 141:13 NHTSAp] 17:18,19,20 nodded [1] 104:22 nomenclature p] 25:4; 78:20 Nonasbestos P] 32:9; 114:5 nonasbestoe [14] 32:8; 40:1; 62:10; 80:3; 82:1; 84:17; 108:17; 114:11,14,18.19; U5:4,6;131:ll Donorigmal p] 36-14,19 normal p] 52:12; 62:13,14 North [5] 620; 26:8; 27:4; 48:11; 102:13 Notary [1] 149:17 note[l] 61:1 noted [1] 149:4 notice P] 58:18; 108:10; 135:7 notices [1] 17:17 notify [1] 56:8 notifying [1] 112:13 November p] 77:17; 94:16 NTSB [1] 17:19 Number [47] 58:19; 59:12; 60:22; 63:21; 64:10; 67:8; 69:13,17,20, 21; 70:3, 6,19,20; 71:2; 74:13; 75:20; 76:9,11; 86:14; 94:9; 95:19; 105:4,9; 106-6; 107:1; 110:4,12; 115:22; 118:9; 119:6,10, 14; 120:10,20; 124:12, 16; 125:3,5; 126:17,21; 129:6; 131:17; 132:2; 133:14; 137:2 number [25] 14:9; 56:11; 59:21; 61:14; 78:10,19; 82:4; 83:7; 86:12, 20; 87:2,14, 16, 21; 88:7; 91:22; 95:20; 97:6; 99:16; 101:22; 107:17; 120:19; 127:7; 141:7; 146:19 numbering [1] 82:9 numbers p6] 61:1, 6,10; 69:13; 76:9; 78:11,12,15,17, 20; 82:4, 6, 8,12,13,17; 83:7, 8,10,13; 84:1; 86:13; 87:6; 88:13; 119:17 -o- ACE-PEDERAL REPORTERS, INC. 202-347-3700 T7., u. __!T!____ *. /M BSA Object pi 50:21; 84:20; 102:3 Objection [8] 25:13,17,18; 28:1,10; 52:15; 55:8; 131:4 objection [1] 94:22 objections p] 5:8,10 obtainable p] 70:8, 9,12 Obviously [1] 140:3 occasions [1] 27:10 Occupational [1] 104:10 occur [11 125:18 occurred pi <50:4; 81:13 OCF [1] 94:10 October [5] 19:11; 20:3; 105:12; 109:8; 124:8 OEM P] 36:3; 72:15,18; 111:12; 112:7; 116:8; 125:13 OEMs [10] 36:2; 49:17; 72:9,10; 73:11; 111:15; 120:4; 132:16; 145:22 off-highway P] 111:1; 127:9; 132:8 oflhand [1] 125:20 office [1] 56:9 OhflJ 41:2 Ohio [10] 6:18; 27:5, 7; 29:5,9; 30:16,19; 32:22; 109:8; 141:16 Okay [8] 5:16; 34:6; 70:14,16; 71:17; 90:11; 115:13; 116:19 okay [1] 56:3 on-board [1] 18:15 On-highway [1] 16:19 on-highway [9] 16:17,21,-17:2,3,8; 120:17; 127:11; 133:9; 146:20 one-for-one [1] 80:13 ones P] 30:13; 32:7,16; 37:6; 48:10; 79:15; 91:1; 125:18 Ontario [4] 27:5; 30:5,20; 48:12 Open [1] 141:2 open p] 33:17,18 Depo of: BRUCE E. KETCHAM (Douglas dal vs. Allied-Signal, Inc.) 1-22-99 Iifc-See(9) opened [1] 33:15 operating P] 22:7,10 operation [8] pads [17] 13:15; 14:1; 39:19; 41:20; 42:21; 44:11; 50:5; 51:6; 61:3; 62:3, 5, 7,11,16,18,-136-8; percent p] 130:17,19 percentage [1] 67:6 perform [1] J47:J4 please [12] 5:75, 22; 6-4/56:12; 68:10; 74:6; 93:5; 123:7, 16; 128:3,19,20 14:18; 23:7,18; 27:14; 141:1 7:10 plywood [1] 30:5; 31:20; 107:9; page [15] performing [1] 97:19 111:22 operations JT| 59:4; 66:8; 77:13; 82:3; 83:13; 84:6, 8,9; 96-4; 132:18 period [23] point p5] 10:8; 22:2,15,-24:9; 15:4; 16-13; 29:10, 20; 34:5; 49:6; 107:7 opinion p] 73:10; 122:1 . 107:5; 109:21; 110:21; 129:9; 130:21; 134:3 pages P] 79:17; 82:20; 85:1 28:21; 40:11,21; 41:18; 44:13,14; 45:1,3; 46:11; 54:7,8; 76:6; 80:21; 90:10,13,17; 91:9; 99:6; 25:21; 27:2,4; 30:6; 31:13,-32:5,-40:13,15; 48:9; 62:18; 69:10; 87:9; 101:15,16; 112:22; opposed [6] pair[l] 138:18; 147:12,19,21 117:15; 121:19; 124:6; 69:2; 72:15, 21; 91:14; 92:3,-126-21 85:20 pallet [8] periods p] 44:22; 90:12 145:15,16 pointed [11 Order [1] 99:12 order [17] 11:10,12,14,-14:13; 96:8,15,17,-97:9,16, 20; 98:1; 117:3 palleted [1] 97:22 PERRY [4] 56-6,13; 57:9; 143:18 Perry [5] 5:16; 84:20; 87:20; 141:6 points [5] 31:22; 33:22; 34:6, 8,9 policy [3] 34:17,-35:7,8,13,16, 20; 48:16,19; 51:13; pallets [1] 122:16 101:12; 143:19 person [1] 112:13; 116-15; 117:9 position [8] 52:13; 90:18; 96:14; 114:19 ordered [5] 14:6,16; 35:5; 51:19; 52:17 ordering P] paragraph p] 105:12; 121:3 Pardon [1] 12:6 paitp2] 36:14; 37:10,11; 59:21; 143:11 personal [1] 98:18 personally p] 23:11,-47:18 personnel p] 7:16; 12:13; 17:9; 18:2, 18.22; 19:1; 20:1 positions PI 18:21; 19:22 possibility [1] 122:3 34:18; 48:18; 51:5 organization [4] 28:9; 38:19; 136:1 61:1, 6,10; 65:15; 69:13; 77:19; 78:14,16,19,20; 83:8,10,-86:12,13, 20; 139:21/140:17 PeterbDt [1] 147:17 post[l] 113:10 potential [5] organizations p] 87:1, 6,14,16; 88:13; phase [1] 105:14,22; 109:22; 37:16; 87:19 Original [1] 36-4 90:5,8; 91:22; 100:5; 105:10; 111:20; 125:14; 139:11 114:1 PhD [1] 6:22 110:22; 140:10 potentially [1] 122:12 original [4] 14:11; 37:11; 38:1; 92:4 origami-manufactured [1] 37:9 OSHA p] 74:15; 75:17; 105:9 outside [5] part-time [1] 8:1 Parts pO] 12:3,-38:20,-39:11,13; 58:6,9; 59:22; 60:9,10; 69:15; 70:5; 71:3; 72:22; 73:3,4, 6; 88:14; 144:16 phrased [1] 68:5 physically [1] 9i:J2 pick pj 16-14,-112:21 piece p] Poughkeepsie [2] 6-8,9 powder [1] 89:11 practice p] 7:1, 8; 52:12 Prattville P] 13:5, 6/14:1,4,-53:10 overpack P] 117:1, 2 Owned [1] 48.-6 owned [1] 20:8 owns [1] 20:20 parts [99] 9:8; 10:17,18; 11:1,16, 17.19, 21; 12:2,11; 14:13; 16:12; 22:22; 24:6; 26:4,22; 27:1; 33:2; 34:18,19,21; 35:4, 13.20, 22; 36:19; 37:1, 3,4,7,19/38:9,11; 39:16,19; 40:1,8; 43:5, 110:9; 116:4 pieces [1] 139:19 pinpoint [1] 114:9 place [7] 52:14; 72:22; 95:4; 104:5; 115:16; 117:10; 123:4 57:21; 58:3 precisely [1] 64:17 prefer [11 85:11 preparation [1] 21:4 prepare [1] 136:19 -P- 11,16,19, 22; 44:3, 6, 20; 45:2, 6,10; 46:2,5, placed [B] prepared [5] 48:16; 51:1; 52:7,9, 20; 109:20,-133:22,-134:3, 6, p.m. p] 56:16; 57:1; 148:11 pack-and-ped [1] 118:3 package p] 96:11,-125:16 packaged [1] 51:10 packaging p] 16:12; 135:20 Packard [1] 147:16 packs [6] 116:15,16,18,-117:8,9, 21 pad [4] 31:9; 38:12; 63:5,11 18,22,-47:3,6,9,12; 48:18,19; 49:21; 55:4, 7; 57:14,18,21,-58:2,6,8, 12,14; 61:2; 71:13; 73:8; 87:2,13; 88:4; 91:21; 92:1,2,3,-99:18,19; 100:7; 110:18; 112:1; 113:7; 114:1,14; 115:6; 123:5; 144:10,12,15, 16,18; 145:3, 7 party [i] 53:20 passenger p] 144:16,19,22 people [9] 49:8; 69:7; 74:7; 120:4, 5; 132:21; 133:3; 140:3; 141:22 91:20; 138:10,17 placing [7] I 97:17; 116:14,16; 117:7, ' 8,18,-121:19 j plaintiffs [1] 5:17 plant p] 29:17; 109:8 plants [6] 14:10,17; 17:2,3; 33:9; 97:1 plastic [1] 96-17 plate PI 31:7; 62:20 plates [1] 62:19 players [1] 14 preparing [1] 136:17 prerogative [1] 100:21 present [4] 33:16; 81:1; 101:5; 141:22 presented [1] 59:16 presently p] 29:14,16; 42:1 pretty [1] 138:13 prevalent p] 72-8/81:4; 133:11 previously [8] 34:4; 57:4; 67:17/69:12; ACE-FEDERAL REPORTERS, INC, 202-347-3700 BSA_______________________________ 79:16; 90:16; 125:3; 146:18 ; | Primarily [1] 120:17 , 1 primarily [4] j 37:5; 116:6; 127:11; 133:9 \ prior [7] 64:8; 84:2; 117:10, 22; 1 127:10; 134:6; 142:22 problem [1] 128:15 procedure P] 116:17; 117:10 process [5] 100:13; 125:10; 126:1, 7, 20 procurement p] 13:4; 15:16 produce p] 14:10; 17:6; 104:7 produced [7] 15:21; 17:7; 67:17; 69:12; 86:3; 123:2; 140:16 producing [1] 22:22 Product [2] 50:13; 130:15 product [72] 12:4,5, 7; 13:5,6; 14:10; 17:11,14,16; 18:4,9; 25:15,19; 30:10,21; 50:4, 22; 51:7,10; 52:10, 19; 53:8,17; 61:19,22; 66:12,19; 67:6; 68:1,3, 19; 69:1,2,16,18; 70:3; 71:2,5; 72:13,17; 76:12, 19; 77:21; 78:3, 7; 82:1, 2; 83:10; 86:2, 4; 91:5, 14,15; 97:7; 100:11,21; 101:4;103:13,17; 108:18; 110:19; 115:17; 116:1; 128:14; 130:13; 135:17; 137:19; 147:12, 19 Production [1] 37:3 production [17] 10:15; 11:22; 14:10; 15:8,10,11,14; 16:2, 4, 5; 35:22; 37:4; 38:2; 53:15,16; 68:15; 91:1 products [72] 13:5,12; 17:4; 22:11,13; 25:7; 27:18,20; 28:6; 40:19,22; 41:1, 4, 5,10, 15,19; 42:2, 7,11,15, 18, 20; 43:2, 8; 45:18, 21; 46:9,14; 50:3, 9,18; 51:1,19; 54:10; 70:4,18; 71:20; 72:9; 76:16; 78:22; 83:7; 84:14,21; 85:17,18,21; 88:14; 98:14,19; 99:21; 114:10; U6:1Q;123:1S,19; 126:9; 131:2; 134:2, 7; 138:10,18:145:13,19, 20; 146:3,19,21; 147:1, 6,22 program [6] Depo of: BRUCE E. KETCHAM (Douglas ^ai vs. Allied-Signal, Inc.) 1-22-99 8:14; 10:13; 129:7, 8,12, 13 progressed [1] 12:14 provide [4] 68:17; 112:17; 127:12; 145:20 provided p] 59:9; 111:6; 136:14 providers [1] 83:3 provides [1] 119:15 providing p] 83:1; 135:13 PubBc [1] 149:17 publications [1] 21:10 published [1] 110:10 pun [i] 86:15 purchase [12] 13:22; 22:17; 36:14, 22; 37:18; 38:2; 41:4,15,19; 57:14, 20; 72:9 purchased [6] 16:11; 42:15; 58:5; 66:5; 91:4; 98:13 purchases [1] 100:5 purchasing [8] 12:16; 13:2,4; 14:12; 15:17; 112:15; 116:10 purposed] 61:5; 74:12; 75:12; 129:13; 139:4 purposes [1] 85:11 Putting [1] 54:4 putting [1] 97:19 -Q- qualified [1] 48:19 quality p] 15:17;16:9,12 quantify [1] 45:4 quantities [1] 113:10 quantify [1] 59:7 quarter [1] 63:17 question [45] 5:9; 13:17; 23:9; 28:3; 29:12; 31:17; 33:9; 36:17; 37:15,21; 39:17; 44:17; 50:7; 52:4; 60:11; 61:21; 68:4,16; 70:11, 17; 72:16; 74:6; 79:5,18; 87:4; 93:5; 96:13; 99:17; 101:13; 106:11; 107:15, 16; 109:14; 114:2; 116:19,20; 121:7; 123:7, 16; 125:9; 128:2,20; 130:12; 135:5; 138:13 questions [9] 87:21; 101:7; 105:2; 125:8; 143:13,17,22; 148:5,8 quick [1] 94:20 quit 1] 24:10 --R-- rarep] 7Z.-8, 14,16 Rayp] 47:9,12; 98:21 Raylocp] 38:17; 47:3, 6 Raymark p] 58:12,15 RD [18] 61:14; 65:21; 66:9; 76:9, 11; 77:16,20; 79:14,21; 80:2; 81:21; 83:5,16; 107:5; 109:10; 124:4; 129:9; 130:11 reach [1] 62:17 read (9] 21:3; 37:21; 76:1; 79:6, 7; 107:13; 121:17; 135:1; 149:1 ' reading P] 105:19,20; 135:6 real [1] 94:20 realm [1] 139:10 realtered [1] 91:12 rear [1] 130:16 reask p] 68:4; 135:5 reason [1] 19:16 reasonable [1] 84:4 reasonably [1] 81:4 reasons p] 138:21; 139:7 rebranding [1] 136:7 recall [16] 14:3; 17:17; 21:8; 22:15; 24:8; 25:10; 265; 40:16; 52:16; 60:11; 81:12; 97:11; 99:1; 138:14; 139:6,15 receipt [1] 127:17 receive [10] 7:6; 49:21; 50:2, 8; 96:14,22; 106:8,15; U2:12;119:12 received [17] 6:18,22; 7:17; 50:10,13, 18; 51:9; 52:5, 8,18; 53:9; 59:1; 80:16; 98:1; 103:16;140:4,7 receiving p] 15:18; 33:2; 51:5 recent [1] 81:8 Recess PI 36:10; 81:16 recessed [1] 56:16 recipient [8] 113:4; 119:19,21; 120:18; 124:17,18; 132:10,17 recipients [1] 132:14 recognize [11] 74:4, 7,9; 78:13; 93:9, 17; 95:11; 118:16,22; 119:2; 124:2 recollect [1] 32:19 reconvened [1] 56:16 record [23] 5:19; 6:5; 26:15,17,19; 36:9,12; 55:19,20; 58:17; 67:9,11; 79:7; 89:2,3; 94:9,21; 98:7, 8; 101:18; 133:15; 134:21; 148:7 records p] 24:15; 86:11 refer p] 113:6; 127:7; 128:5 reference [1] 144:9 referenced [4] 69:17; 70:19; 73:11; 88:6 references P] 82:19; 102:18; 103:12 referencing [1] 125:7 referred [4] 69:1; 82:8; 89:7; 121:6 Referring [l] 67:16 referring [11] 64:8; 83:11; 86:4; 97:17; 106:3,-107:12,20; 121:14; 127:17,22; 141:3 rtfers p] 68:1; 89:15; 113:7 reflect [1] 66:4 reflected [1] 60:2 rrilects [4] 59:17, 20; 74:16, 20 refresh [1] 94:6 refuse [1] 133:12 regard [1] 87:21 regarding p] 7:21; 21:15; 100:17 regards [1] 103:3 Regulation [1] 74:15 regulation P] Loofc-Se=(IO) 74:22; 75:7, 8 regulations p] 17:18,-104:11 reiterate [1] 147:21 relabel [1] 54:1 relabeled [7] 50:4,9,19,-51:7,20; 52:6; 91:13 relabeling P] 54:2,3; 136:6 related [1] 20:13 relatively p] 63:15; 92:12,19 relevant [4] 90:12; 99:6; 104:5; 105:10 remanufacturing [1] 55:6 Remember [1] 146:13 remember [?] 24:9; 49:5,11; 50:17; 51:5,18; 95:7; 138:21; 145:6 removed [1] 103:13 repackaged [1] 91:12 Repair [1] 37:10 repair [5] 12:3; 37:8; 55:4; 73:1; 119:15 Repeat [1] 96:13 repeat [12] 13:17; 29:12; 31:16; 36:16; 37:21; 44:16; 50:7; 54:14; 61:21; 72:16; 79:5; 116:20 replace [4] 12:4; 73:3,5; 114:20 replaced p] 62:16,18; 114:8 replacements [1] 115:4 report [1] 109:19 reporter [1] 79:7 represent P] 5:17; 83:19; 144:6 representatives [1] 132:20 represented [1] 130:13 represents p] 74:3; 130:11; 142:9 request p] 21:9; 60:13; 132:20 requested [5] 60:20; 79:7; 111:5; 112:10; 120:5 requesting [1] 124:9 requests [1] 94:3 required [4] ACE-FEDERAL REPORTERS, INC. 9n?-'M7_-J'7nn bsaDepo of: BRUCE E. KhU'CHAM (Douglas etal vs. Allied-Signal, Inc.) 1-22-99Look-sc<in 81:5, 6; 92:22; 114:18 research p] 60:9; 88:3 researched [1] 60:14 resemble [1] 83:14 Reserve [1] 9:15 reserved [1] 5:11 reserves [1] 10:9 resident-bonded [1] 78:3 respect [4] 84:9; 117:12; 12611; 136:21 respirator [1] 129:6 response P] 67:18; 94:2 responses p] 94:12; 136:22 responsibilities p] 15:15;18:19 Responsible [1] 17:16 responsible [4] 13:3; 16:22; 18:8; 35:22 responsiveness [1] 5:9 rest El] 33:4 results [1] 126:11 resumed [1] 57:4 retailer [1] 48:17 return [1] 121:17 returned [1] 10:10 returning [1] 134:17 review [71 21:3; 25:11; 85:11; 134:11; 138:4; 139:11, 12 reviewed p] 21:6; 140:5 reviewing p] 137:16; 139:13 revisions [5] 137:18; 138:17,19,22; 139:2 rid[l] 103:7 Right P] 49:10; 129:1 right [13] 51:10; 70:21; 85:14; 86:18,19; 88:15; 90:14; 96:4; 97:2; 99:2; 125:18; 131:8,10 Riverside [1] 38:19 ' rivet [4] 103:12,18; 107:10,11 rivets P] 90:2, 7 Road [1] 5:21 road[l] 111:1 Rochester [1] 6:3 Rock P] 46:19; 47:1 Rockvffiep] 58:11; 123:8 Rockwell p43] 7:11; 11:5,9,20; 12:15; 13:5, 7,13,-14:2,9; 16:15; 18:2; 19:8,10,11, 13,22; 20:6, 8,11,13, 14,16; 21:11,14; 22:17, 20, 22; 23:18; 24:2, 4,5, 10,15; 25:6; 2&3, 6, 8. 12,21; 28:12,14; 33:13; 34:13,18,-38:7, 9; 39:15, 18; 40:7; 41:3,10,15, 18; 42:11,15,18; 43:2, 5,11,16,19,22; 44:3, 20,-45:5,10,17,21; 46:2,5,18, 22; 47:3, 6, 9,21; 48:3, 6; 49:22; 50:4,14,15,19; 51:2, 7, 11,12,-52:10,11,14,20, 21; 53:1,5; 54:4,8,11, 15,18; 55:5; 57:13,17, 20; 58:2, 5, 8,14; 59:1; 64:14; 65:6,13; 66:5,11; 67:19; 69:2,10; 71:6; 72:18; 74:4, 8,10,17; 75:3; 78:14,16,19; 79:1; 80:17; 85:17; 86:2, 4,8; 88:4; 89:17; 90:5, 21; 91:3,14, 21,22; 93:7, 11,18,21; 95:21; 96:2, 7,8,14,19:98:1,3,13, 20; 99:20,22; 100:5, 8, 10,11,15,-101:4,21; 102:9,12,13,22; 104:1, 4; 106:8,15,18; 109:15, 16;110:10,16,18; 111:9,18; 112:13; 113:5, 12,16; 114:9,13,17; 116:12; 117:9; 118:14, 15,17,22,-119:13,16; 120:1,12; 121:5,10; 123:1,2,14,17; 124:3, 5, 7,20,22:126:7; 129:8,10,12,15,20, 22; 130:2,4,-134:1,6,7,15, 17,19; 135:2,10; 137:7, 22; 138:3; 139:20; 140:16,22; 141:11; 142:9; 143:4; 144:9; 145:8,12 Rockwell's [5] 11:22; 21:16; 82:9; 116-15,-123:4 rollers [1] 111:2 rough p] 25:1;1U:2 ROUSELL [1] 130:7 ROUSSEL [105] 5:6,8,11,15; 12:21; 13:1; 23:13; 25:14; 26:1, 15.19,20,-28:4,11; 30:15;31:14;36:9,U, 18; 44:8,9,14,18,19; 51:3; 52:22; 55:10,19; 57:6,10; 58:21; 59:11, 14; 61:9; 63:20; 64:1, 9, 13; 65:10,12,18; 67:7; 73:22; 75:9; 76:8; 77:14, 18; 79:10; 81:17; 85:2; 87:22; 89:2; 92:8; 93:15; 95:3, 6,17; 101:10,19; 102:4, 7; 105:3, 7; 106:5, 22; 107:4; 110:4, 6,11, 14; 113:2; 115:20; 116:22; 118:9,12; 119:5, 8; 120:8; 121:1; 122:14; 124:11,14,-126:3,15; 127:2; 128:4,11; 129:4; 131:6,12,16,20, 22; 133:5,13,17; 135:8,9; 137:1, 4; 138:15; 143:13, 20; 148:4,9 Roussel p] 5:17; 135:6 rubbing [1] 122:11 -S- Safety p] 17:22; 104:10 safety P2] 17:16; 61:17; 66:1,15, 19, 21; 74:18; 75:16; 77:22; 79:12, 22; 80:3; 81:22; 83:2, 6,16; 130:9, 14; 133:21; 134:6,18 sale (3] 35:22; 46:14,15 sales [15] 11:10,12,14; 46:9; 47:16; 49:5,11; 59:21; 60:3,17, 20; 69:6; 110:9; 112:17,-116:4 salesmen p] 139:20; 140:16 satellite p] 30:5,8; 34:4 saying [4] 69:9; 97:14; 141:22; 143:8 scheduled [1] 58:18 Schenectady P] 6:12; 8:11 School [1] 6:8 school [4] 6:7; 7:19; 8:3, 6 screw [1] 80:20 se[l] 138:1 seals [1] 13:12 search [1] 61:5 searched [1] 99:4 second [13] 12:19; 22:4; 26:14,16; ' 79:20; 89:2; 98:7; 109:2; 110:21; 118:1; 121:15; 129:18; 133:15 secretary p] 56:1,8; 101:14 section [5] 78:9; 82:3; 84:8,10; 94:17 Sector [1] 76:15 selected [1] 138:10 sell [16] 11:15,17; 41:10; 42:11; 43:2,22; 46:22; 47:6,12; 48:15; 54:11,15,19; 101:4; 112:4; 144:10 selling p] 24:6; 45:6 sells [1] 89:19 send [6] 28:6; 74:17; 96:12; 111:9,18; 125:1 sending [1] 75:4 sentence P] 74:21; 78:2; 122:9 separate [5] 20:6, 7; 84:22; 85:4, 6 separata! [1] 85:12 separately [4] 71:19,21; 71:12; 97:16 September p] 109:12,-134:4 serial [1] 83:7 series [6] 83:13;116:5; 120:14,15; 132:22 serious [1] 77:9 Service [1] 90:15 service [12] 11:16,19; 12:4; 55:4; 75:1; 90:14; 91:21; 92:1, 3; 113:6; 117:12; 119:15 services [1] 15:18 servicing [1] 124:20 SESSION [1] 57:1 shape p] 90:6,18; 91:13 shareholders [1] 20:21 Shea [5] 94:14; 136:16; 142:14, 16,19 Sheet [1] 64:3 sheet p4] 61:16,17; 66:1,20; 67:2; 70:21; 76:14; 78:1; 79:3, 12, 22; 80:3; 81:22; 83:5, 6,16; 84:1; 89:10; 130:9, 10,14; 133:21; 134:6,18 sheets [9] 66:15; 74:18; 75:4,16; 76:7; 82:20; 83:2; 84:13; 88:6 shifted [1] 68:14 ship p] 96.-21,-97:4 shipment [4] 16-14; 121:6; 122:4, 7 shipments P] 103:6,-117:12 shipped P] 37:3,4,-122:15 shipping p] 97:8; 117:6; 121:20 shoe [18] 14:15; 31:6, 8; 38:12; 86:9;89:18, 22; 108:3, 7, 9; 117:19; 131:1,5, 6,9 shoes p41 13:14,22; 17:4; 26:22; 30:22; 31:12,19,21; 32:13; 39:20,21; 41:20; 42:21; 44:11; 50:6; 51:6; 59:7; 61:3; 107:21; 108:20; 117:15,19; 126:13; 141:1 shop p] 111:21, 22 show p9] 59:15; 61:13; 64:2; 65:19; 74:1; 75:10; 76:10; 77:19; 78:6; 79:11; 83:15; 87:18; 94:8; 95:12; 101:20; 105:3,18; 106:6; 109:5; 113:3; 115:21; 11611; 118:13; 119:9; 120:9; 121:2; 122:22; 123:12, 14; 124:15; 126:4,16; 127:14; 129:5,14; 130:8; 132:1; 133:18; 136:18 showing [1] 109:11 shows p] 94:12; 102:12 shrink-wrap [4] 96:12,19,20; 97:4 shrink-wrapped [4] 96:9; 97:10,14; 117:3 shrink-wrapping [1] 97:22 Signal P] 41:4,11 signature [6] 94:15; 95:13,14; 102:11; 130:3 signed [1] 136:11 signify [1] 23:6 sit [16] 25:22; 26:5; 29:7; 47:19; 70:7; 73:16; 85:20; 88:8, 15; 94:1; 95:11; 98:6; 99:1, U; 100:2; 139:1 sitting [1] 94:5 situation P] 71:9,14; 102:20 ACE-FEDERAL REPORTERS, INC. 202-347-3700 T7. ___L 4 BSA______________________________ situations [1] 91:11 six [8] 9:20; 25:5; 29:8; 30:9, 13; 31:11,18; 32:10 size [6] 92:15,17; 97:20; 108:6; 113:13; 114:21 sizes [1] 92:12 sldd [1] 97:19 Slightiy p] 84:10; 127:13 smaller [8] 73:11,12,13,14,18; 117:4, 5 snuff [1] 9:12 sold [50] 11:20; 14:11; 25:15, 20; 37:11,13; 38:9; 43:8,16; 44:3,20,-45:1,21; 46:5, 10; 49:16; 50:11; 57:18; 58:2, 8,14; 69:2, 7,10, 14; 70:5; 71:5, 6,10,18, 21; 72:1,3, ID, 14,18, 21; 88:14; 89:21,22; 90:3, 4; 91:3,19; 92:4; 96:7; 146:11,12,15 somebody p] 37:12,-122:11 Someone [1] 28:12 someone [5] 34:17; 35:3; 48:19; 49:14;139:3 somewhere pj 71:7; 81:11 sorry [4] 32:3; 70:10; 89:5; 130:12 sounding [1] 99:21 Sounds [1] 39:1 sounds [4] 39:7,10,14; 43:14 sources [4] 14:5, 7, 8,14 South [5] 27:6; 32:4, 7; 53:6; 65:14 speak [4] 75:22; 76:4; 84:3; 144:22 Speaking [1] 77:12 speaks [7] 66:14,21; 74:14; 75:6, 13; 83:1; 109:18 specialist [4] 8:20; 9:6; 10:16; 137:20 specialty [1] 146:6 Specific [1] 140:2 specific [9] 22:9; 30:22; 84:7; 85:15; 87:1,9; 139:21; 144:19; 147:3 specifically [5] 103:5; 132:5; 140:16; 145:9; 146:7 Depo of: BRUCE E, KETCHAM (Douglas dal vs. Allied-Signal, Inc.) 1-22-99 ____________________Look-Seg(12) specification [1] 100:8 specifics [1] 146:14 specify p] 100:10,11 speculate [1] 130:20 speD [1] 19:5 spider [1] 65:22 spreads [1] 60:3 Spring [4] 22:20,22; 23:19; 26:3 Springs [1] 6:2 spun pj 19:10,16 stacking [i] 97:20 stage [1] 23:20 stomp p] 61:14; 65:22 stand pj 10:7; 57:4; 78:12 Standard [7] 24:3, 4,5; 26:7; 102:12; 129:10; 130:4 standard [1] 104:18 Standards [1] 75:18 stands [1] 108:13 staple [1J 85:13 shut [5] 55:17; 100:13; 101:13; 111:9,-114:10 Started [5] 8:9; 16:22; 20:2; 139:13; 145:16 Starting PJ 6:6, 7; 21:22 Starting [6] 6:21; 7:19; 74:16; 79:21; 96:4; 113:22 starts [1] 79:14 State p] 27:19,21; 94:12 state [6] 7:2; 94:11,21; 95:21; 109:21; 141:15 stated [1] 146:18 statement [6J 67:4; 77:6; 102:12; 103:4; 105:20; 122:9 States [2] 34:1, 7 states [10] 7:4; 48:5; 67:4; 74:21; 76:20; 77:17; 78:2; 106-19; 129:10; 149:3 stationary [1] 111:2 Steamboat [1] 6:2 sticker [1] 123:4 stipulations [1] 5:6 Stock [1] 21:1 stock p] 20:18,20 stop [4] 22:4; 29:17, 20; 81:8 Shipmaster p] 116-5; 127:7; 130:16 stopped [4J 24:13,22; 25:1; 145:6 strength [1] 63:4 Strike [1] 136:12 Strike [1] 48:2 strikes pj 71:12,13 Strip [1] 64:3 strip PJ 64:5, 7 studies [1] 9:1 stuff [4] 10:18; 14:1; 38:2,13 subdepartments [1] 15:16 subdistribution [1] 48:4 subject [1] 105:8 submits [1] 100:8 Subscribed [1] 149:11 subsidiary [1] 20:10 substitute [1] 101:3 successor p] 41:7; 46:19 suitable p] 101:5; 115:4 Supervising [1] 11:14 supervising [1] 13:3 supplied [16] 95:21, 22; 99:19; 100:7; 118:14; 128:14; 134:7; 145:12,18; 146:2,18; 147:5, 8,12,19, 21 supplier [7] 49:21; 50:10; 92:10; 96:9; 98:2,19; 128:7 supplier's [1] 96:10 suppliers [7] 49:6; 52:13; 99:5; 100:8, 15; 102:15; 136:7 supplies pj 13:7,9; 63:3 supply [11] 27:18,20,21,-29:9,10; 75:1; 87:6,12; 144:20, 21,-145:3 supplying [1] 145:6 support [1] 11:21 supposed [1] 62:16 surface [1J 108:8 Survey [1] 109:6 survey [1] 109:5 suspension [1] 144:20 sworn pj 5:5; 57:5; 149:11 synonymous [1] 77:3 synonyms [lj 67:1 system [1] 52:9 Systems [4] 46-19; 47:1; 57:14,18 -T- toble [1] 31:7 takes [1] 96:19 talk [1J 109:10 talked PJ 100:16; 114:7 talking [19] 7:21; 8:21; 9:1; 13:7,9; 17:20; 37:8; 38:11; 42:20; 44:12; 50:5; 77:2; 80:21; 89:8; 91:10; 107:17; 113:21; 130:18; 135:2 talks [10] 94:17,-107:6,10,22; 108:10; 117:7; 118:1; 122:1; 126:5; 129:6 tan [1] 92:11 technical [1] 139:12 technician PJ 119:22; 132:18 technicians [1] 124:19 telephone [1] 143:17 tenure [1] 139:8 terrain [1] 111:2 testified [5] 5:5; 5Z-5; 90:17; 98:17; 132:15 testify P] 71:1; 136:2 testimony p] 64:8;149:3 testing p] 126-5,10,11 Thank [5] 64:9; 92:6; 109:4; 110:3; 131:16 thank PI 73:20; 148:2 Thanks [1] 12:22 thanks [1] 101:8 There's [1] 122:5 there's [5] 78:9; 81:21; 101:14; 128:15,21 thereafter [1] 65:22 thick PJ 63:12,15 thickness [lj 92:16 thin [1] 63:17 third PJ 53:20; 107:5; 121:3 thorough [1] 84:4 three p] 99:10; 100:15; 102:14 Tilbury P] 27:5; 31:22; 32:19 times [1] 15:15 Timken [16] 22:3,5, 6,11,17,18,19; 23:1,2,5,17,-24:7,10, 16; 25:8,11 titiep] 74:15; 103:4 Tom [1] 55:21 tortp] 140:20,21 total P] 107:16,-141:10 totally p] 45:14,-122:2 tough [1] 138:13 Tractor [1] 124:8 trade (VJ 23:4; 66:22; 93:3, 6; 94:18; 112:21; 113:11 traded [1] 20:22 trademark [lj 23:5 Traffic [1] 17:22 traffic [1] 15:18 trailer [4J 66:16; 68:12; 73:8 trailers [4] 9:12; 31:20; 37:18; 111:1 TraflmobBe [lj 39:2 training [121 7:15,16; 8:14; 10:2,4,5, 6,13; 139:21; 140:2, 8 transcript PJ 149:2 ACE-FEDERAL REPORTERS, INC. 202-347-3700 From situations to transcript BSA transferred [1] 6:21 transforming [1] 19:18 transition [1] 114:17 transmittal [1] 76:7 transmitting [1] 75:15 transportation [1] 10:6 Troy [4] 5:21; 27:12,13; 103:1 Truck [2] 38:20; 73:17 truck [8] 10:18; 11:1; 69:5; 72:3, 11; 112:1,5; 130:16 trucks [13] 9:11; 31:20; 37:18; 69:3; 72:3, 4,7; 111:1; 113:17; 132:9 tubs [2] 121:20; 122:10 two-page [2] 77:14; 79:4 type [37] 9:1, 3, 4,12; 10:4,18; 11:2,17; 14:1; 22:11; 24:19; 31:20; 34:20; 35:1, 3,10, 20; 38:13; 48:17; 55:5, 6; 63:2; 64:21; 68:3; 72:3; 80:9; 82:17; 90:3; 113:5,8,14; 132:6; 133:8,9; 139:21; 141:21; 144:18 types [22] 12:5, 7; 13:9,12; 17:4; 42:14; 50:18; 51:13; 71:13; 78:22; 98:19; 105:17; 112:14; 120:15; 132:3; 133:1,2,3, 6, 7; 135:19 typically [7] 72:12; 92:11; 97:5,12; 111:6; 112:6; 127:9 -u- uldmate p] 119:21; 138:9; 139:5 unaware [1] 33:8 uncertain [8] 32:19; 43:15; 49:3; 50:1; 51:15,17,21; 70:21 unclear [1] 113:15 uncommon [1] 71:17 underneath [1] 136:16 understand [7] 52:1; 70:11; 72:5,-89:12; 95:3; 108:2; 145:2 understanding [1] 53:1 Union [1] 6:11 union [2] Depo of: BRUCE E. KbTUHAM (Douglas gal vs. Allied-Signal, Inc.) 1-22-99 72:17; 102:19 United [4] 33:22; 34:7; 57:14,18 University [4] 6:17,19,20, 22 unstaple [1] 85:19 unusual [1] 68:6 up-to-date [1] 137:18 update [1] 139:18 user [4] 111:13; 112:7,8; 139:5 users [2] 112:15, 20 uses p] 54:21; 111:15; 132:3 Usual [1] 5:6 utilized [1] 88:4 - V- vague[7] 25:13,17,18,-28:1,10; 52:15,-55:8 vary [1] 92:16 varying [1] 67:5 vehicle [14] 37:9; 72:2, 9,19; 73:1; 115:2; 132:3, 6; 133:2, 4, 8; 146:4,5, 20 vehicles [13] 9:12; 17:8; 73:12,14; 113:13,15,19,20; 120:15,17;133:1,6,10 vehicular [1] 114:20 vendor P] 25:12; 53:11; 103:5 vendors [6] 14:1,4; 36:14; 103:16; 1068,16 verification [1] 95:12 verified [1] 94:14 versa [1] 71:11 version [1] 138:16 versus [1] 94:10 vice [1] 71:11 videotapes [2] 140:9,11 Vietnam [1] 9:21 volumes [1] 25:20 Volvo [1] 147:16 Volvos [1] 72:11 Wailfl] 22:8 waited [1] 135:12 wanted [2] 57:12,-136:10 Warehouse [1] 49:9 warehouse [1] 49:10 warehouse-type [1] 49:14 warn [1] 136:3 warning [14] 117:14, 20; 118:4; 123:3, 15,18,-126-5,8,12; 137:15,20; 138:9; 139:4, 16 warnings [16] 77:5; 116:14,16; 117:7, 8; 135:13,17,19; 137:6, 18,21; 138:1,3; 139:10, 13,14 WD [1] 50:12 WDs [7] 49:16; 111:16; 112:18; 113:9; 125:11,13; 132:16 wear [2] 62:12,17 weight [1] 114:21 well-established [1] 23:7 well-known [1] 109:22 weren't [1] 15:3 West p] 5:21,-30:7,-34:5 what's [10] 59:17; 61:13; 65:19; 75:10; 77:19; 113:3; 115:21; 120:9; 130:20; 132:1 whatnot [1] 138:6 whenever [2] 7:20; 33:15 whereas [2] 80:1,-127:10 Whereupon [4] 5:2; 56:15; 57:2; 148:11 Who's [1] 119:19 whoever [2] 106:16; 138:4 wholesale [8] 50:12; 60:8; 96:21; 110:17; 111:12; 112:14, 16; 122:15 wholesale-type [1] 49:6 wholesaler [2] 35:13; 48:17 wholly [1] 20:8 whomever [1] 125:11 widely [1] 82:id> Wiffiam [1] 143:18 wish [1] 79:15 Withdraw [1] 102:6 WITNESS [18] 23:11; 25:19; 28:2; 36:7; 44:16; 50:22; 52:16; 65:11; 76:3; 77:16; 79:8; 84:22; 104:22; 128:2; 131:9,18; 138:14; 143:10 witness p] 5:4; 104:22; 138:13 Wnuk [1] 12:19 word-by-word [1] 85:4 word-for-word [1] 102:16 words [5] 80:7; 86:13; 87:5; 101:3; 113:16 work [18] 8:5,22; 9:1, 8; 11:1; 19:3; 25:6; 49:12; 95:15; 112:1; 132:18; 137:5,10, 14,16, 21; 138:4 worked p] 12:15,-136:17,18 workers [1] 141:17 working [4] 19:8; 51:19; 95:7; 138:5 wouldn't [1] 131:13 wrap [1] 97:16 written [1] 67:18 -X- Xavier [1] 6:17 -Y- year[4] 26:9; 45:16; 60:4; 146:21 years [6] 18:12,17; 41:22; 46:12; 141:15; 146:2 yellow [2] 96:5,-109:13 York [10] 6:9,12; 8:11; 21:1; 27:5; 32:1, 4, 7; 39:22; 40:1 Look-Sce(15) ACE-FEDERAL REPORTERS. INC. 202-347-3700 From trnnvfprrprl fn Vnrk Jan-21-39 03:4fipm Frora-ROUSSEl & ROUSSEL 304-531-8532 T-367 P.03/11 F-307 CIVIL DISTRICT COURT FOR THE PARISH OF ORLEANS STATE OF LOUISIANA NUMBER: 93-9533 DIVISION "K" SECTION "14" GEORGE DOUGLAS AND BONNIE MORALES DOUGLAS VERSUS ALLIED-SIGNAL, INC., ET AL FILED:___________________________ _________________________________ DEPUTY CLERK NOTICE OF DEPOSITION TO ALL COUNSEL OF RECORD: please take NOTICE than the undersigned counsel for plaintiff will take the deposition of Bruce E. Ketcham in accordance with Louisiana Code Civil Procedure Article 1442, to testify on concerning the matters listed with particularity hereinbelow. This deposition shall be taken for all purposes permitted under the Louisiana Code of Civil Procedure on the 22nd day of January, 1999, at 11:00 A.M. (EST) and continuing thereafter day to day until complete, at the offices of Shea Gardner, 1800 Massachusetts Avenue, N.W., Washington, D.C. 20036, before a duly qualified court reporter or other person authorized by law to administer oaths, at which time and place you are hereby notified to appear and take part as you deem fit and proper. Respectfully Submitted, ROUSSEL AND ROUSSEL GEROLYN P. ROUSSEL #1134 PERRY J. ROUSSEL #20351 BRETT D. MAURIN #19696 1710 CANNES DRIVE LAPLACE, LOUISIANA 70068 TELEPHONE: (504) 651-6591 . ATTORNEYS FOR PLAINTIFFS CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served upon counsel for all parties by FAX on this 21st day of January, 1999. /'fay^ BRETT D. MAURIN HUGH M. GLENN, JR. Biknventj, Foster, Ryajst 8z O'Baj^on- AlTOHNBYS AND C032TSKLOHS AT Law Axebion Base Bmurao 200 Cabonsbxet Street Nhw Orleans. Louisiana 70130-7984 tBOA) 3B1-2I40 TELECOPIES (S04> 028-7839 August 20, 1993 FAX - 1-651-6392 Ms. Gerolyn P. Roussel Roussel & Roussel 1714 Cannes Drive Laplace, LA 70QS3 re: Dear Ms. George and Bonnie Douglas v. Allied-Signal, Inc., et al CDC No. 93-9533 HKH Our File: 18,327 Roussel: .V Pursuant to our telephone conference on August 19, 1993, enclosed please find a compilation of sales from Rockwell to Fleet Parts and Equipment in New Orleans and Heavy Duty Parts and Equipment in Harahan, Louisiana for the years 1978-1992 in response to your Notice of Deposition to Rockwell set for August 24, 1993. As we advised, we do not know if these are the same entities referred to in your notice and interrogatories as Fleet Heavy Duty Parts in Harahan, Louisiana and Heavy Duty Truck Parts in Harahan, Louisiana. " You advised you would review these along with our answers to interrogatories and advise us what documents you would want to review. If you need further information please call either the undersigned or Richard Nagareda at (202)828-2000. Cordially HNGJr:dmj end. tH > aJ-* W- h M* 3O J3 M* W W0 P* IT UJ nn o> * (9 ca 3 if cn tr IA 07 1 2 S* in 3* 1978 1979 1980 1981 1982 1583 1984 19B5 1986 j 1587 | 1988 } 196 M cr\ * cn x*. (ji N> o 10 4 TO 03 *sj m Co Complied from data from Product Support Systems O EM Sales System DEPOSITION EXHIBIT ts os On On ON ON ON On BO ON 09 00 On tc-o* On NO qo On in oo On TT 00 on m oo ON fS 00 ON 00 On CO On On r- On Tf CO On <N CS NO l/"l NO Tj* vn r-* --. CN 00 fN in o cs y-h \o 33I2S222S32uQ) sB Z Hes WJ ta CL 0M) cCsS *-- <rmc-Ns> oo s ^sssssss tn sc x c a! x c* a: 3 Q fsj fsj UON OOn nO hO* h H(N| rN-tK fopo'O'ONONONO'ONO a u < X MATERIAL SAFETY DATA SHEET FDR DISC BRAKE LIVINGS NOTE? This Material Safety Data Sheet contains information on the eoi-ecallicf nonaebeatoa friction material. The linings in Rockwell brakes are manufactured by companies other than Rockwell* Coplea of material safety data ahaeta prepared by these companies are available from Rockwall upon request* This material safaty data sheet 1b not part of any contract or sale* No warranties of any kind, expressed or implied, are made as to the brake linings deacrlbed herein. MANUFACTURER: ADDRESS: . SECTION I - NAME. AND ADDRESS Rockwall International Corporation Automotive Qperatlona '135 West Maple Road " ... it ... . :*/R FOR ADDITIONAL INFORMATION OH HEALTH HAZARDS CONTACT: Randall P, Petraeh TEL. i 313-435-1019 PRODUCT NAME: Brake LlnlngB on Rockwell Diac Brakes* SECTION II - HAZARDOUS COMPONENTS AND EXPOSURE LIMITS Component 1/ OSHA PEL ~ ACCIH TLV u Inorganic Components Carbonaceous Friction Enhancers Cured Phenolic Binder Steal aod Iron Particulate 15 ng/m 3 15 mg/m 3 5.0 og/o 3 5.0 ng/m (raaplrable dust^or 15 wg/n (total dust) 3 10 rog/m 3 15 Bg/n 1 1 DEPOSITION I I EXHIBIT hM a* I V 3 5.0 mg/a 3. 5*0 ng/a (respirable dust) or 10 mg/ (total idust) 1/ All UmitB are 8-hour time-weighted averages* RD 00034 1 BECIIOH III - PHYSICAL AKD CHEMICAL CHARACTERISTICS BOILING POINT: N/A SPECIFIC GRAVITY: 3.0-3.5 VAPOR PRESSUREi N/A PERCENT VOLATILEi N/A VAPOR DENSITY: M/A EVAPORATION RATE: 0 SOLUBILITY IN HATER: NO MELTING POINT: N/A APPEARANCE AND ODOR: DARK GREY SOLID, SLIGHT PHENOLIC ODOR SECTION IV - FIRE. EXPLOSION, AND PHYSICAL HAZARD DATA FIRE AND EXPLOSION HAZARDS l Nona flash POINT: N/A____________________ EXTINGUISHING MEDIA: special Tire fighting procedures: CO2 water, foam, dry chemical* Wear self-contained breathing apparatus* REACTIVITY DAIA: Stable material* INCOMPATIBILITY (Materials to Avoid): Avoid strong oxidizers due to organic content. HAZARDOUS DECOMPOSITION PRODUCTS: Incomplete combustion may release toxic materials* HAZARDOUS POLYWIRIZATI0Nr Will not occur* CONDITIONS TO AVOID: Avoid creating and breaching dust* SECTION V - HEALTH HAZARD DATA PRIMARY ROUTES OF ENTRY: Inhalation HEALTH HAZARIfi: ACUTE: May cause aye, skin, or upper rsepiratory system irritation* Metal dusts nay be irritants of the eyes and upper respiratory system* Soma persons may b sensitive to phenolic resins and develop dermatitis* Phenolic reeina may causa akin eruptions similar to ped-esft-dry*-- RD 00035 pneumoconiosis* There la little evidence of chronic industrial poisoning from iron or steel dusts. SIGNS AND STtHPTCHS OF OVEREXPOSURE: Symptoms of pneumoconiosis Include shortness of breath, dry cough, fatigue on exerciaa, chest pains, chest cightnaes, and vague feelings of sickness* Such ByBteras are not usually manifest until 15 to ZO years after first exposure. Other signs may be dlaeovered by trained personnel using X-rays, pulmonary function tests, and ether diagnostic tools during physical examination* SECTION VI - SPECIAL PRECAUTIONS ENGINEERING CONTROLS AND WORK PRACTICES i All feasible engineering controls (for example, enclosure end ventilation) and work practical __ must be Instituted to reduce worker exposures to dusts to or below the OSHA permissible exposure limits. :-:>iSPlRATuSS: . if IIilUe. arc rAceededj NIOSH t; must be used* * * -!ij repplrato*-! OTHER MEASURES.* Avoid scraping or scratching brake linings or other-wise . cresting dust during assembly* Use available dust suppression or control measures, such as local exhaust ventilation, at all tinea* Compressed air should not be used for cleaning up dust from linings unless it 1b used sa part of a ventilation system to capture the duet created* During brake maintenance, brake parts should be cleaned with e HEPA vacuum and then wiped with a damp rag to remove duet residue* Protective gloves, long-sleeved shirts, end other protective measures Are recommended for persona with sensitivity to pheaolic resins. Use of eye protection Is good practice sc all times and is necessary whan dust may be propelled by drilling or machining* SECTION VII - EMERGENCY FIRST AID PROCEDURES In case of eye irritation, gently rinse with vmter and get medical assistance* DATED: Septasber 25, 19B6 RD 00036 ## HATSRIA1 SAFBTX DATA SHEET FOR BONDING STRIP OH DISC BRAKES The brake linings used on Rockwall disc brake unite are semimetallic, nonaabeatoa linings* Theee linings are attached to the brake shoe through the use of a backing atrip (approximately 0*080 inches in width), wire mesh, and adhesive. The backing atrip is employed to Insure bond line integrity* The backing atrip contains asbestos* With proper use, the hacking strip will not be exposed and cannot result in release of asbestos fiber** Proper use of the brake require* that the brake lining bo replaced at appropriate intervals. To insure that the need to replace the linings is readily apparent, Rockwell provides a slide pin wear indicator on ita brake units, and a simple check of this wear Indicator will show whether lining replacement is necaaeary. If the brake 1b misused by failure to replace the linings when Indicated, however, a possibility exists that tha backing strip may become expend* In the event of such misuse, workers performing brake repair should follow the precautions recommended in this sheet* The bonding strips in Rockwell brakes are manufactured by companies other than Rockwell. Coplas of material safety data sheets prepared by these companies are available from Rockwell upon request* .. - - , . iuty dace *.',*. . c. an/ cc.crac. . . Gale. No warranties of any kind, expressed or implied, are made as to the brake component* described herein* MANUFACTURER: ADDRESS; SECTION I - KAH5 AND ADDRESS Rockwell International Corporation Automotive Operations 2132 Vest Maple Road Troy, Michigan 48086 FOR ADDITIONAL INFORMATION ON HEALTH HAZARDS CONTACT! Randall P. Petresh Tel.: 313-435-1019 PRODUCT NAME: Bonding Strip Containing Asbestos on Rockwell Disc Brake*. RD 00037 -2- SKcnoi ii coMPcmr Chrysotile Aibwto* Inorgaaie Components Cozed Phenolic Binder HAZAKDfi COODlWrrS MD EXPOSURE LIMITS QSHA ~ U AOCIH TLV - 0.2 fibers/cc-^ ,3 IS a*/ 2 flbere/ee .3 10**/* 5.0 */* 5*0 **/* 17 All 11*1Es ere 8-hour ti*e weighted avers*TM. If Scientific authorities disagree ee Co whether there la any absolutely eefe level of espoove to asbestos* SECTIOM III - RnSICAL AHS CHEMICAL CHARACTERISTICS JOILUB IDQTi M/A MELXIK BOOT: M/A VAPOR PRESSURE* K/A VAPOR EBS8ITT: H/A brfCITIC aAVI'ii: 3.0-3 .5 KACXJft . jL-Ziii.. rj\ EVAPORATION IA3S: 0 (kytl Acetate " 1) APPEARANCE: Solid, light tan in color- Slight phenolic odor. SOUJITLITT II HATER; Mo. SECnOM IV - mi. explosioh. aid physical hazard data FIU AMD EXPLOSION HAZAMC: see- PLASH POUT: H/A EZTIlRUISaiMC MSDIA: ktar or Class A, B, or C Extinguisher. SPECIAL nu PIGBTDB P10C1DQRES: Hear self-contained breathing apparatus. REACTIVITY BATAI Stable aacerlal. ' UC0MPAI3ILITT (Mscerlals CO Avoid): Avoid stroog oxidirers. RD 00038 HAZARDOUS ZBCQKFD8ITI0V IftOOOCZS: BAZADOOB WUJMSATIOEj COHDITICWS TO AYOIDJ Incomplete combustion may create toxic fueea._______ Will not occur. Avoid erecting end breeching duet.* 1 2 SICTIOB V - HEALTH HAZAtD DATA BAZA1MOS CMFOWMIS; See Section HI ebon. FUHAJCX IODTXS Of KRKt: Inhalation, Ingestion. HEALTH HA2A1BS: ACPTEi Hey causa r, akin, and/or upper respiratory syacaa irritation. Some parsons may be sensitive to phenolic reaine end develop dermatitis* Phenolic reeiue may ceaee skin eruptions similar to polaoa Ivy. uacu.wJ (1) CAHCU: The Rational Toxicology Program, International Agency for Xeaeareh on Center, end QSHA have found that asbeotoe can cense cancer in liiiini. Scudiea of workers expoeed to asbestoe in the peat have found inereeaed daaeba from lung cancer and maaocbelioma. Some atodias have alao observed increeaes la other forma of cancer, each ee cancer of tbe digestive tract, bet ocher etodlea have ooc observed increase a la theme typea of cancar. Smoking baa bean fotaad to increase greatly the risk of lung cancer In aabeatoa morkars. (2) 1ZJHC DZSEASXi Exposure to aabeatoa can land to aabeatoela. In sevare eaaee thin disease can be fatal. Bxpoaure may alao lead to nondleebliag condltloui lateen ae pleural thickening, plaques, and calcification, SICKS ASH SUffTOB W OTEXXXFOSSUz Symptoea of aebeetoaia, poeueoeooloals, and lung cancar include ahortneaa of breath, dry cough, fatigge on exercise, cheat pains, cheat tightness, clubbing of fingers, and vague feeling* of aleknasa. Soch symptoea do not usually nenifast tfcaaeeliea until IS to 20 years after first exposure. Other signs eay be RD 00039 stCTxoa vi - oflHA uwaacffs sed wcm mcautioib THE V0LUHZ9C RECASIXOffS iPFLI 0*LT 17 THE TRUCK UHIT IS tUSGSED ST FAILD1K TO KKFIAGS TEE USHRS HfflM ISDICmO ST TBS SL1DC ra au mZCAXOt, TEUS EXTOSIHO THE BOtDXK snip. nCDCEUlVC (XMU'UiU AHD WHOC nicncu: A2t feesibis engine*rlog controls (for exespis, eaelasace sod ventilation) and nork practical vast be instituted to reduce sorter expoeurns to ssbeetoe dost and otbor doets to or beloir tho 08BA peniselble exposwe Haiti. . EJSPDUTOtS: Under condition* sbera ubuto* dost lovala exceed tbo persdssible level, the OSHA asbestos standard require* due ~ " respirator* approved by HIQffi and KSBA be nsad. OSEA also requires chat all respirators be prosvrly ~ Tt>>ixUe* and Chat quantitative o:. jgjalitstlve ilr f rtta U dooa every six soarhe on all sorters using negative pressure respirators. OTHER PROTECTIVE IffASCUS: If tba OSHA Halt for itbutM Is exceeded, OSHA requires that tba aaplojsr provide and require the uaa of appropriate protaetiTa clothing, rooas with separata locksra for noth clothes, and appropriate Imcfaroaas. OSHA raqoiraa that serkers wpoaad to asbastoe be trained 17 aa to its potaatial basarda and tba --of radKinc ehoea hazards. It also raqoiraa eoaitorlng every six swnths of corker asbestos expostars if le aey reasonably be expected to be at or abovo 0.1 f/ce. OSHA prohibits using empreased air for cleaning op dost frao ssbseeoe coless it is need aa part of a ventilation ayataa to capture the dost created- OSHA requires, if feasible, tba oae of veeauoe sltb HEPA filters or tbs use of see cloths to clean op dost. OSHA prohibits the use of dry sleeping for cleanup if sacttiulag or net cleaning ia fsaaibla. OSHA rsquires that used cleaning cloths be put in sealed, iupsrasshla bags or containers Bbile still sat. (Sea Section Till balo* for disposal nacbods.) 7or further details of the OSHA adbeatos standard, see 29 C.r.I. I 1910. RD 00040 Protective (loves, long-sleeved shirts, sod other protective clothing eve recommended for persons with skin sensitive to phenolic resins. Use of eye protection is good practice et ell tine* sad ie necessary **en dost uj be propelled by drilling or schiningt PRECAUTIONS TO U T1XK1 XX HAHDLXNGt Use eveileble dnet eappreseion or control lessorss, each as local eshaost veatiletion, et ell times. Daring brake neintesence, eleen brake perta with a vacaom with a HKFA filter end then wipe with deep raga to taow sweateecontaining resides- Dispose of oasd raga while eclll wee in sealed, lnpeBeeabla bags or other doaed, lapsreeable containers. (See Section VII for disposal Methods.) SECTION VII - SPILL 0*. LEAK PHOCEDUUS 2ECKTT:----------------------------- -----------------------" " STEPS TO EX 1ADM IK CASS DOST OX. HASTE CORAIXIK AflBSTOS C* OTHEE HAZARDOUS NAlStlALS IS IELXA5ZD OE SPILUD; Avoid creating airborne dost. Use e vaconm with s EEPA filter or remove by asiog water. Do not ass brooms or compressed air on dry vterlal. Hear personal protective equii--nt as prescribed above. HASTE DISPOSAL M3B0D: Haste containing ashes Coe or other beardooe aeerlals hoold be collected and disposed of Id sealed, Impermeable bags or other dosed, lapenmable conteiners with proper lnbele in accordance with applicable federal, state, and local requirements. Hote 08HA standard at 29 C.F.R. S 1910.1001, 51 Fed. Reg. 22713 for asbestos end EPA requirmenta et 40 C.fl. II 61.140-.156 for aria--toe and at 40 C.T.X. If 260-267 for haaardooa eeeeea. SECTION VIII - BgXfllHCT AND FIMT AID PKCCPOttS In case of aye Irritation, patly rinse with water and git nadira1 help. Date Prepared^ September 25, 1966 RD 00041 Higtmfy Bra** Trtiltr Aik DMtien 13267 State Houle 68 South Kenton, Ohio 43326 (419} 674-4051 Rockwell International U/18/85 Dear Safety Director/Purchasing Director, Enclosed are Material Safety Data Sheets for brake linings which are used on trailer axles sent to your company. We are sending this information as part of our effort to comply with GSHA Hazard Communication Standard, (29CFR 1910.1200). Thank you for your attention, to the attached information. Sincerely c.c. H. Biggard J. Ferguson SP .JfeJJ.lt1 RD 00046 I';, lLl /U\ I ] ur L'U'UH Oi'uij*ctiii<'t,j| Safely ,nn! mini* u.iiu'n MATERIAL SAFETY DATA SHEET Required under USOL Safety and Health Regulations for Ship Repairing, Shipbuilding, and Shipbreaking (29 CFR 1915, 1916, 1917) SECTION I MANUf ACTURERTi NAME EMERGENCY TELEPHONE NO. Motion Control Industries, Div. Carlisle aouRLSS (ft umber. Sirret. O'). Siele, and IIP Code) P. 0. Box P. Gillis Avenue. Ridawav. PA CHfMlCAl. NAME AND SV NON VMS Brake Lining CAS. NO. 1332214 CHEMICAL. ^ AMILY Fibrous Mineral Silicate onlv hazardous substance Corporation 814-773-3185 15853 TRADE NAME ANO 5VNONVMS Carl isle Brake Lining FORMULA . Varies with product SECTION II - HAZARDOUS INGREDIENTS PAINTS. PRESERVATIVES, & SOLVENTS X TLV ALLOYS AND METALLIC COATINGS % PIGMENTS BASE METAL N/A TLV lUnitl) CATALYST VEHICLE SOLVENTS ADDITIVES _ N/A ALLOYS METALLIC COATINGS FILLER METAL PLUS COATING OR CORE FLUX OTHERS N/A N/A u . N/tt N/A, . OTHERS N/A HAZARDOUS MIXTURES OF OTHER LIOUIOS, SOLIDS. OR GASES Compound contains asbestos, with varying percentage in individual product formulas. TLV X (Units) 15 -60 2f/cc B hr. TWA BOILING POINT (F.) VAPOR PRESSURE (mm H9.I VAPOR DENSITY (AIR-1J SOLUBILITY INNATE* appearanceanoooor SECTION III -- PHYSICAL DATA ^ jqy^ uy* SPECIFIC GRAVITY {M3O-I) PERCENT, VOLATILE BY VOLUME {%) EVAPORATION RATE ( -1) Grey . Light Tan - Slight Sour Odor SECTION IV FIRE AND EXPLOSION HAZARD DATA FLASH POINT tMNTioB U\aB) . ... , . Not applicable FLAMMABLE LIMITS extinguishing mcoia N/A SPECIAL FI HE FIGHTING PROCEDURES m_____________________________________ 1.87-2.12 Lai Ual UNUSUAL FIRE AND Cvl.nVON HA/AROS 1 There arc no known unusual fire and/or explosion hazards.] PAGE 11) tCnniinurri un reverse side) Fn-m Dr-HA.?0 RD 00047 THHLShOLD LIMIT VALUE LMtCTSO^ OvtfliAl'uSUHE RL'CriONV HLALIUKAZARI* DATA Asbestos threshold limit 2 f/cc 8 hr. TWA Breathing asbestos fibres may cause serious bodily harm. Effects of exposure may not be irrcnediately evident. LMl HGLNCY AND FlHSl AID V R Oct DU H E S Skin Contact - wash with soap and water. Eye Contact - rinse out eyes, use protective glasses. STABILITY UNSTABLE SECTION VI REACTIVITY DATA CONDITIONS to avoio STABLE INCOMH.VTAH1LITY IMotcrtsIt fO 0>Oldj HAZARDOUS DECDMPOSI riON PRODUCTS haZAROOUS POLYMERIZATION MAY OCCUR WILL NOT OCCUR CONDITIONS TO AVOIO X SECTION VII - SPILL OR LEAK PROCEDURES STEPS TO BE TAKEN- IN CASE MATERIAL IS RELEASED OR SPILLED " Avoid creading dust; do not breathe dust. Avoid sweeping or-otherwise generating irborne particulate. Use approved vacuum method. If sweeping is necessary, wet down spillage.; WASTE DISPOSAL METHOD Dust should be disposed of in sealed container. Dispose of in approved landfill. Mark bags. Follow Federal, State, and Local Regulations. SECTION VIII - SPECIAL PROTECTION INFORMATION RESPIRATORY PROTECTION (Specify type) Use Dira:ors as recommended by,the USHA standard . for exposure to achacFne Hue* 29_CF L_19 IL_ 001 paragraph Tell. VENTILATION LOCAL CXWAUST ' AoDroved system to insure meeting T.L.V. as reauired bv 0SHA Standard. mechanical (Generali OTHER 29 CFR 1910. 1001 ch PROTECTIVE GLOVES EYE PROTECTION _ , Yes Yes (Safety Glasses) . qtheq protective EQUIPMENT KeTer CO Uihrt aSDeSLOS Sldnudru I3IU. lUUl iUi auuitiunai information.----------------------------------------------------------------------------------------------------------------------------- --.------------ - SECTION IX - SPECIAL PRECAUTIONS PBECAUTI NS TO BE TAKEN IN HANDLING ANO ST O BING , Avoid , -c-i-e-ating or.breat,hing- du_s.t,. fol Vow label on package. Exposure levels to dust containing asbestos nbers snoui. be monitored in accordance with QSHA regulations 29 CFR 1910. 1001 other precautions" SuEsCTTtlat med 1 cal evidence indicates tnat smok.lnu.will increyg the risk trom asbestos exposure. Those working with products containing asbestos should not smoke. ------------------- THIS DATA ShLiiT IS NOT PART OK ANY LuNTRACOR 5ALE. WHiLt Iht iNI-UkMAi fDff" page (2) AND RECOMMENDATIONS SET FORTH HEREIN ARE BELIEVED TO BE ACCURATEffm OSHA-2C a*. Mi, 72 cro .. CARLISLE COkPORAViQN MAKES NO WARRENTY WITH RESPECT THERETO AND disci ALw l:al ITY FROM RELIANCE THEREON. RD 00048 . '.i u 11 <i.u iiuii;n ,n*n / MATERIAL SAFETY DATA SHEET Requited ur-.i^r USDL Safety and Health Rigi.lalions for Ship Repairing, C'-Mpliuilding, and Sh.pb'C-a* inq 129 CFR 1915, 1916, 19171 MANUFACTURER'S NAME SECTION 1 EMERGENCY TELEPHONE NO. Motion Control Industries, Div. Carlisle Corporation ADDRESS Mrrrt. C. l/<. .S.Vfc. ' /I," CuJr! SI 4-773-3185 -P._D,. Box Px.-G.iJljs Avenue^ _Ridowav. PA 1F.AA7 C-if MiCAl j-ial'C and SvndnVMS Eraxe Lining TKrDf NV^E isle ANQSVNONVMS Enourannd, . * i-llfH'CA. fAMiLV j FORMULA Various } Varies with oroduct SECTION II HAZARDOUS INGREDIENTS TAINTS, PRESERVATIVES. B. SOLVENTS pigments n/A % TLV (Units) ALLOYS AND METALLIC COATINGS BASE METAL N/A CATALYST N/A ALLOYS N/A VEHICLE N/A METALLIC COATINGS N/A SOLVENTS ADDITIVES N/A N/A FILLER METAL PLUS COATING DR CORE FLUX OTHERS W , n/n N/A OTHERS N/A HAZARDOUS MIXTURES OF OTHER LIOUIDS, SOLIDS, OR GASES Material is considered not hazardous. % TLV (Unit*) TLV % (Unit*) BOILING POINT (aF.) VAPOR PRESSURE (mm Hfl.J VAPOR DENSITY (AIR-1J SOLUBILITY IN WATER APPEARANCE AND ODOR SECTION III - PHYSICAL DATA N/A N/A N/A N/A SPECIFIC GRAVITY tH30l) PERCENT, VOLATILE BY VOLUME {+\ EVAPORATION RATE I. - - -U Grey , Slight Sour Odor 1.8-2.1 SECTION IV FIRE AND EXPLOSION HAZARD DATA FCASH POINT tMinob w\e) 1JA EXTINGUISHING MEDIA N/A SPECIAL Ft ftE FIGHTING PROCEDURES N/A FLAMMABLE LIMITS Lt) Uf unusual fire and explosion hazards There are no known unusual fire and/or eAplosion hazards. PAGE (7J * Ml '1 71 (Continued on reverse side) - uj-.'v . l'ii i r' r Form OSH A 20 RD 00049 SECT IUW V HEALTH HAZARD DATA THRESHOLD LIMIT VALUE 3, Nuisance dust (J5jug/m )_05HA TLV crtccts OF OVE Rexposure ~ " Not'established ` EMERCCNCV ANO FIRST AID PROCEDURES Skin contact - wash with mild soap and water Eye contact - rinse out eyes, wear protective goggles STABILITY UNSTABLE SECTION V) - REACTIVITY DATA CONDITIONS TO AVOID STABLE INCOMSATAB'LITV (Mjirrisis lo ortudj X HAZARDOUS DECOMPOSITION PRODUCTS HAZARDOUS MAY OCCUR WILL NOT OCCUR CONDITIONS TO AVOID X 3=^ ----------------- --- - . SECTION VII- SPILL OR LEAK PROCEDURES STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED Avoid creating dust. Avoid Weeping or otherwise^generatinq*airborne particulatev-.vUse approved vacuum. v.jtn^ method; ' If sweep ing`-ts necessary=yr-wet down spillage1. WASTE DISPOSAL METHOD Dispose of in approved landfills.- Follow Federal, State, and local Regulations SECTION VU1 - SPECIAL PROTECTION INFORMATION W6SfT-YuR-W]^i0a^(?fci,e,flprfespirator for nuisance dust if TLV is exceeded, VENTILATION L.OOCAL EXHAUST '' ' Per ANSI 19.2 - "1971 recommended MECHANICAL (General] SPECIAL None OTHER PROTECTIVE GLOVES Work Gloves usually adequate OTHER PROTECTIVE EQUIPMENT Nnnp EYE PROTECTION Dust .goggles _megtln.qJLatesi_ANSL 2.-87 ..l icjec SECTION IX SPECIAL PRECAUTIONS PRECAUTIONS TO BE T A KEN ~i N HANOUNO AND STORING -------------- Avoid creating or breathing dust. OTHER PRECAUTIONS Protective creams may also be used, especially those with sensitive skin._____________ THIS DATA IS NOT PART OF ANY CONTRACT OF SALE. WHILE THE INFORMATION page 12) AN0 RECOMMENOATIONb LET FORTH HEREIN ARE BEUEYED TO BE FormOSHA-20 ACCURATE> CARLISLE CORPORATION MAKES NO WARRANTY WITH RESPECT "* ,y THERETO AND DISCI AIMS ALL LIABILITY FROM RELIANCE THEREON. RD 00050 NEW 03HA ASBESTOS HAZARD REGULATION FEBRUARY 4,19B6 AS YOU ARE AWARE THE MEW MSDS(ASBESTOS) REGULATION AFFECTS OUR SERVICE BUSINESS AS WE SUFPLY ASBESTOS LININGS FOR THE AFTER MARKET. . ' OUR RESPONSIBILITIES UNDER THIS NEW'REGULATION ARE TO SUPPLY OUR CUSTOMERS WITH SAFETY DATA SHEETS FOR ALL LININGS SHIPPED TO OUR CUSTOMERS WHICH CONTAIN ASBESTOS AND TO UPDATE OUR CUSTOMERS AS REQUIRED IF THERE ARE CHANGES TQ THE SAFETY DATA SHEETS.THE ACTUAL SAFETY DATA SHEETS ARE SUPPLIED TO US BY DUR VENDORS. . ' AS OF TODAY WE HAVE COMPLIED WITH THIS NEW REGULATION BY FORWARDING THE REQUIRED SAFETY DATA SHEETS TO OUR AFTER MARKET CUSTOMERS.HOWEVER,IT IS IMPERATIVE 'THAT ANY REVISIONS MADE TO DATA INFORMATION IS IMMEDIATELY COMMUNICATED TO OUR SAFETY DEPARTMENT IN ORDER THAT WE MAY INFORM OUR CUSTOMERS. YOUR CO-1 DISTRIBUTION: K.MYERS B.SMITH D.ZEMMICKY M.LeBLANC D.ANDERSON CC: . J. THOMPSON 8. WILLIS mT'Mc CONNELL* i February 5, 1986 Rockwell International Hebron Road - Route 79 Newark, Ohio 43055 Rockwell International of Canada Ltd f. 0. lex 230 HIGHWAY No. 2 7ILBUIT. ONTAUO, CANADA (5171 452-I7AQ NOT 210 Subject: OSHA Hazard Communication Standard CFR 1910.1200 Dear Material Manager: , To comply with the above-mentioned OSHA regulation, Rockwell International Tilbury Plant, is sending to all of our customers new Material Safety Data Sheets (from our asbestos vendors). These Material Safety Data Sheets have been updated and include the products you currently purchase, as well as products you may purchase from Rockwell in the future. Sincerely, Ken Myers Eng. & Rel. Manager /dz cc: G. Willis J. Thompson J. Simard 3 DEPOSITION stes' EXHIBIT & . --s______ I RD 00055 PRODUCT FACT SHEET Compiled: November 1985 by Allied Corporation, Automotive Sector Bendix Friction Materials Division, p.o. Box 238, Troy, NY 12181 Products - Bendix Friction Materials covered by this Product Fact Sheet can be identified as follows: Brake Block Formula B-4-12J Safety and Health Information Fire and Explosion - Product is classified as non-cdmsustible, requires NO SPECIAL FIRE FIGHTING PROCEDURES, AND DOES NOT PRESENT ANY UNUSUAL FIRE, EXPLOSION OR REACTIVITY HAZARD. SMALL FIRES MAY BE EXTINGUISHED WITH CARBON DIOXIDE OR DRY CHEMICAL. LARGE FIRE5 MAY BE EXTINGUISHED WITH FOAH AND WATER. Health - No Threshold Limit Value (TLV) has been established for the ASBESTOS FIBERS COATED WITH PHENOLIC RESI.N. HOWEVER, A TLV HAS BEEN ESTABLISHED FOR FREE ASBESTOS FIBERS OF 2.0 FIBERs/cC OF AIR. OSHA HAS PROPOSED A REDUCTION IN THIS TLV TO 0-2 FIBERs/cC. INHALATION OF EXCESSIVE CONCENTRATION OF ASBESTOS FIBERS HAS BEEN ASSOCIATED WITH CERTAIN SERIOUS HEALTH PROBLEMS SUCH AS ASBESTOSIS OR MESOTHELIOMA. Symptoms of overexposure are latent for extended periods of time. Recommended Waste Disposal - Dispose of in accordance with applicable federal, state and local laws and regulations in proper receptacles, appropriately labelled. Recommended Precaution - If airborne assestos fiber concentration exceeds DsHA LIMITS, APPROVED RESPlRATORS SHOULD BE WORN AND PROPER ENGINEERING CONTROLS IMPLEMENTED. |F PRODUCT IS GROUND OR MACHINED, LOCAL VENTILA TION TO CONTROL EXPOSURE IS RECOMMENDED. The WORK ENVIRONMENT should be monitored to determine whether employee exposure exceeds OSHA threshold limit value'in accordance with OSHA regulation 29 CFR Part 1910-1001. Packages containing the Product should be labeled in accordance with OSHA regulation 29 CFR Part 1910.1001(g)(2) as follows: CAUTION Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust May Cause Serious Bodily Harm $ Standard industrial hygiene, practices including good housekeeping and vacuuming or wet cleaning work surfaces to prevent asbestos fibers from BECOMING AIRBORNE, SHOULD BE INSTITUTED OR IMPLEMENTED. THE FOREGOING DATA IS SUBMITTED SOLELY FOR YOUR INFORMATION, CONSIDERATION, AND INVESTIGATION. BENDIX MAKES NO WARRANTIES, EITHER EXPRESS OR IMPLIED, AND ASSUMES NO RESPONSIBILITY FOR ACCURACY OF THE FOREGOING DATA. . . : ; i `4i, * (OVER) RD 00056 RECOMMENDED PROCEDURES FOR REDUCING ASBESTOS DUST DURING BRAKE SERVICING Because studies have indicated that exposure to ex cessive amounts of asbestos dust may be a potential health hazard, OSHA has set maximum limits of levels of airborne asbestos dust to which workers may be exposed. Since most automotive friction materials nor mally contain a sizable amount of asbestos, it is Im portant th3t people who handle brake finings and dutch facings understand the nature of the problem and know the precautions to be taken. 1. Areas where brake work is done should be set aside if possible, and entrances Should be posted with an asbestos exposure sign as follows: Asbestos Dust Hazard Avoid Breathing Dust Wear Assigned Protective Equipment Do Not Remain in Ares Unless Your Work Requires tt Breathing Asbestos Oust May Be Hazardous . To Your Health 2. The amount of asbestos in the dust from brake fin ing wear Is normally at an extremely low level be cause of chemical breakdown during use, and If ma chining of friction material does not take place, sim ple procedures will minimize exposure. During brake servicing, the mechanic should wear a respi rator approved by NiOSH for asbestos dust tt should be worn during ail procedures starting with the removal of wheels and including reassembly. 3. When removing worn friction materials, remove the accumuiaieo dust In the assemblies with an industri al vacuum cleaner equipped with a high efficiency fitter system. If such equipment is not available, dust can be removed with a damp doth. Do not use com pressed air or dry brushing for deaning unless the assembly Is enclosed and property exhausted. 4. Whenever possible, purchase friction materials pre ground and ready for installation. If machining is necessary, the precautions which must be taken arc of extreme importance. This is the operation In brake service when exposure to asbestos dust may be at Hs highest. This increases the difficulty in com plying with the OSHA standards, in addition to the approved respirator, there must be local exhaust ventilation such that worker exposures are main tained below the OSHA asbestos standards. If there is any question as to the effidency of asbestos dust removal by the machine, the manufacturer should be contacted. 5. industrial vacuum deaner bags containing asbestos dust and doths used for wiping brake assemblies should be seated in plastic bags and labeled with the following warning label printed in letters of suffi cient size and contrast to be readily visible and togi- ' bie. Caution Contains Asbestos Fibers Avoid Cresting Dust Breathing Asbestos Dust May Cause Serious Bodily Harm All asbestos waste should be disposed of in accor dance with OSHA and EPA asbestos regulations. During removal of vacuum bags, an approved respi rator, as described In (2) above should be worn. 6. Good housekeeping to essentia! In a workplace where asbestos containing materials are handled. Industrial vacuum deaners equipped with multiple stage high effidency filters should be used for re moving accumulations Of asbestos dust and waste. Never use compressed air or dry sweeping ter deaning. Water or other dust suppressants should be applied if brooms are used. 7. Good personal hygiene practices are important in minimizing asbestos dust exposure. Do not smoke. Wash before eating. Shower after work. Change to work dothes upon arrival at work and change from work dothes at condusion of work. Work dothing should not be taken home. Laundering of asbestos contaminated dothing shall be done so as to pre vent release of airborne"asbestos fibers in excess of the exposure limits. \ ; 1 b --= ^ ` "" J ' CAUTION: DO NOT BREATHE ASBESTOS DUST ry; ?Z 'tsOO The above procedure is reproduced from the 1983 editi on.jdf, FMSMis>'Brake Lining, Brake Shoe and Clutch Facing Automotive Data 8ook\\!"qp'c7Vu^ RD 00057 material safety data sheet May be used to comply with OSHA's Hazard Corrnunication Standard 29 CrR 1910 1200. Standard must be consulted for specific requirements. MOTION CONTROL INDUSTRIES _ _.EQEE!. Carlisle brake lining is a resin bonded product. When used as intended this product meets the OSHA definition of an article and is exempt from the Hazard Communication Standard. A potential for exposure to dust when -grinding, drilling, milling* etc. exists and therefore all information contained within should be followed. Materials listed an this data sheet are contained in this product. Exact percentages are proprietary and confidential and will not be disclosed other than as required in accordance with the regulations. The data sheet is not part of any contract or sale. While the information and recommendations set forth herein are believed to be accurate, Carlisle Corporation makes no warranty with respect thereto and disclaims all liability from reliance thereon. IDENTITY (Aa 06zd on Lc.kzl and LUt): 8C5, HOB, SMI2, 45W, 43W, D39A, D39, 5M14\ B62, B62-6, 141 , 243, 345, D16, 262E, G316, SMB1A, DB2A4, PCL, 41W, R31, E3A, DB67 ............. -...............-.......................... SECTION I-.............................. -............. -.......... MANUFACTURER'S NAME ADDRESS: Motion Contol Industries P. 0. Box P, Gillis Avenue Ridgway, PA 15853 SIGNATURE OF PREPARER: * 'fertvCt ???-%eLrJs EMERGENCY TELEPHONE NUMBER: 814-773-3185 TELEPHONE NUMBER FOR INFORMATION: 814-773-3185 PATE PREPARES: November 18, 1985 Robert M. Tami SECTION II - HAZARDOUS INGREDIENTS/IDENTITY INFORMATION hazardous components OSHA PEL {BpecLa^ic. Ck&nZccLi l&znzCtsj, Common Name Ul Asbestos (Crysotile) 2 fibersZcc Silica, Silicates . 0.1 mg/m3 Carbon Black, Graphite, Coal, Coke 2.0 ma/m3 Aluminum,Iron.Magnesium,Ox ides,Calcium Carbonate 10.0 mg/m3 Phenolic and Cashew Resins Flourides 5.0 mg/nr 2.5 mg/m3 ACGIH TLV 2 fibers'cc 0.1 mg/m3 2.0 mg/mJ 10 mg/m3-, 5.0 mg/nr 2.5 mg/m3. SECTION III - PHYSICAL/CHEMICAL CHARACTERISTICS BOILING POINT: N/A SPECIFIC GRAVITY [H,,Q - 1}: 1-8-3.0 VAPOR PRESSURE [mm tfg.J: N/A MELTING POINT: L N/A VAPOR DENSITY {AIR r M- N/A EVAPORATION RATE (Botyl Ace^tfe. -I): SOLUBILITY IN WATER: None ,L,, nJ APPEARANCE AND ODOR: Solid - Light Tan to Dark Gray Color - Slight Sour Odor 0 RD 00058 Form 7-A ......................SECTION IV - FIRE AND EXPLOSION HAZARD DATA.................................... FLASH PCJT.VT: N/A FLXUMA3LE LIMITS: N/A EXTINGUISHING MEDIA: Water, Class A, B, and C Extinguisher SPECIAL FIRE FIGHTING PROCEDURES: None U^LLSLUL FIRE 6 EXPLOSION HAZARDS: None Known tL ____ UL ____ 1* . ......................................-SECTION V - REACTIVITY DATA..................................................... STABILITY Usu.txb.La | | CondCtLOiu to Auo.Td: None Stable |T| INC0MPATA3ILITV to Avoid]: None Known HAZARDOUS DECOMPOSITION OF ByPRODUCTS: None Known HAZARDOUS POL/MESIZAi ION-* May Occilx Q Witt Not Qccjja [x] Conditions to Avoid-*. None Known ................................ SECTION VI - HEALTH HAZARD DATA-............. --............. ............. ROUTE(Sl OF EVTRV: Inhaiation? Yes Sfeiit? Yes IngeACon? No HEALTH HAZARDS (Acuta and Chxania): Dusts of asbestos, silica, graphites, carbon, and coal can produce pneumoconiosis and lung damage. People with sensitive skin may have reactions to phenolic and cashew resins. CARCINOGENICITY: Asbestos NTP? Yes IARC MonogAjiphs? Yes OSHA Uguiajtzd? No SIGNS AND S/MRTOMS OF EXPOSURE: None Known MEDICAL CONDITIONS GENERALLY AGGRAVATED EV EXPOSURE: Employees with highly sensitive skin could develop rash. EMERGENC/ AND FIRST AID PROCEDURES: - Should not be necessary during normal handling procedures. .................-SECTION VII - PRECAUTIONS FOR SAFE HANDLING AND USE...................... STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED: Avoid creating dust; do not breathe dust. Avoid sweeping or otherwise generating airborne particulate. If sweeping is necessary, wet down spillage. . WASTE DISPOSAL METHOD: Asbestos - 40 CFR, part 64.29CFR, part 1910.10,01. Dust should be disposed of in a sealed, marked container. Follow Federal, State, & Local regulations. PRECAUTIONS TO BE TAKEN IN HANDLING AND STORING: Avoid creating or breathing dust. Follow caution labels on package. Exposure to asbestos fibers should be monitored in accordance with 29CFR 1910.1001. OTHER PRECAUTIONS: Substantial medical evidence indicates that smoking will increase the risk from asbestos exposure. Those working with products containing asbestos should not smoke. ---......... -........... SECTION VIII - CONTROL MEASURES.......................... ................... -- RESPIRATORS PROTECTION (Special/ Type.): Use respirators recommended for asbestos exposure. Information found in 29CFR 1910.1001 paragraph (d). VENTILATION: Lets*. Exfuuui - 29CFR 1930.1001 to meet OSHA T.L.V. Spzatil - None Known Mzdvanizat [Gen&fcit) - Same * OtJieA - None Known PROTECTIVE GLOVES: As Required EVE PROTECTION: Yes (OSHA approved) OTHER PROTECTIVE CLOTHING OR EQUIPMENT: As required under 1910.1001. WORK/HYG1EUJC PRACTICES: Refer to OSHA standard 1910.1001 for additional information. RD 00059 . Form 7-A MATERIAL SAFETY DATA SHEET May be used to comply with OSHA's Hazard Communication Standard * 29 CFR 1910 1200. Standard must be consulted for specific requirements. MOTION CONTROL INDUSTRIES KlNlLH: Carlisle brake lining is a resin bonded product. When used as intended this product meets the OSHA definition of an article and is exempt from the Hazard Communication Standard. A potential for exposure to dust when grinding, drilling, milling, etc. exists and therefore all information contained within should be followed. . Materials listed on this data sheet are contained in this product. Exact percentages are proprietary and confidential and will not be disclosed other than as required in accordance with the regulations. . The data sheet is not part of any contract or sale. While the information and recommendations set forth herein are believed to be accurate, Carlisle Corporation makes no warranty with respect thereto and disclaims all liability from reliance thereon. * TVEblTlTY {Aa Uaed on LabeZ and L4si) : EW1, NAB9M, NAB9ML, NAB9MK, E145A, DE2, DS3, DE3 .........................................................-SECTION I--- MANUFACTURER'S NAME S At7DRESS: Motion Contol Industries P. 0. Box P, Gill is Avenue Ridgway, PA 15853 SIGNATURE OF PREPARER: EMERGENCE TELEPHONE NUMBER: 814-773-3185 TELEPHONE NUMBER FOR INFORMATION: 814-773-3185 PATE PREPARED: November 18, 1985 Robert M. Tami SECTION II --HAZARDOUS-INGREDIENTS/IDENTITY INFORMATION HAZARDOUS COMPONENTS . OSHA PEL ACGIH TLV (Spec^-Lc. Ckejnicjzt IdztUUXy, Common Name. U) Silica - Silicates Glass Fiber 0.1 tng/m3 15 mg/ur 0.1 mg/m3 10 mg/mJ Carbon Black - Graphite, Coal, Graphites 2.0 mg/m3 2.0'mg/m3 Calcium Carbonate, Mineral Wools, Aluminum, Iron, Magnesium Oxide 3 10 mg/m 3 10 mg/m33 Phenolic and Cashew Resins Florides :mJg/mm.3 SECTION III - PHYSICAL/CHEMICAL CHARACTERISTICS BOILING POINT: N/A SPECIFIC GRAl/m \H Q - 7): 1.8-3.5 VAPOR PRESSURE (mm Hg.}: N/A MELTING POINT: 4 N/A VAPOR DENSITy (AIR - 1): N/A EVAPORATION RATE (Botyl Acetate - 1) SOLUBILTT/ IN WATER: None APPEARANCE AND ODOR: Solid - Light Tan to Dark Grey Color - Slight Sour Odor RD 00060 Form 7-N ............. ---SECTION IV - FIRE AND EXPLOSION HAZARD DATA.................................... FLASH POINT: FLAMMABLE LIMITS: N/A EXTINGUISHING MEDIA: Water, Extinguisher class A, B, and C ' SPECIAL FIRE FIGHTING PROCEDURES: None Known UNUSUAL F_IRE 5 EXPL0SIM HAZARDS: None Known LEL___ UEL __ ...............................---SECTION V - REACTIVITY DATA........ ......................-.................... STABILITY: Uiu.fa.bie Conditions to Avoid: N/A Stable. INCOMPATABILITY (Mat&Uali to Avoid}: None Known KAZARPUUS DECOMPOSITION OF BYPRODUCTS: None Known HAZARDOUS PO LYMERIZATI ON: May Qccivi Q Will Hot Occjjx 0 Conditions -to Avoid: None Known ----------------- --------- SECTION VI - HEALTH HAZARD DATA-................................ -............. RDLTTEIS) OF ENTRY: Inhalation? Yes Skin? Yes Ingestion? No HEALTH HAZARDS [Aouie and Cknonlc): Dusts from glass fibers, silica, graphite, carbon black, and coal can produce pneumoconiosis and other lung damage. Employees with sensitive skin may have a positive reaction to glass fiber & cashew and phenolic resins. CARCINOGENICITY: NTP ? -- IARCMonographs? -- OSHA Regulated? No SIGHS AM? SYMPTOMS OF EXPOSURE: Rash may develop on skin of employees with sensitive MEDICAL CONDITIONS Skin` * GENERALLY AGGRAVATED BY EXPOSURE: None Known. EMERGENCY AND FIRST AID PROCEDURES: Should not be necessary from reasonable handling of product. ............--SECTION VII - PRECAUTIONS FOR SAFE HANDLING AND USE--............... STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED: Avoid creating dust. Avoid sweeping or otherwise generating airborne particulate. Use approved vacuum'methods. WASTE DISPOSAL METHOD: Follow Local, State, and Federal waste disposal regulations. PRECAUTIONS TO BE TAKEN IN HANDLING AND STORING: Avoid creating excessive dust. OTHER PRECAUTIONS: Protective creams and sleeves may be necessary for employees with sensitive skin. ............. -......... --SECTION VIII - CONTROL MEASURES............................... r.................. - RESPIRATORY PROTECTION (Speedy Type): NIOSH approved for pneumoconiosis and fibrosis producing dusts with TLV's not less than 0.05 mg/m3. VENTILATION: Local Exhaust - Per ANSI 29.2-1971 recommended Mechanical [Gcneoal] - -- Special - -- Qtken - -- PROTECTIVE GLOVES: As needed EYE PROTECTION:_ OSHA approved safety glasses OTHER PROTECTIVE CLOTHING OR EQUIPMENT: Protective sleeves and creams for employees - with sensitive skin. WORK/HYGIENIC PRACTICES; Proper work practices and methods should be followed when handling product. Employees should be instructed on the use of the control methods as outlined above. RD 00061 Form 7-N Acx Revised fage 1 ci 3 MATERIAL SAFETY DATA SHEET May be used to comply with OSHA's Hazard Communication Standard 29 CFR 1910, 1200. Standard must be consulted for specific requirements. The product identity on this page meets the OSHA definition of an article and is exempt rrom the Hazard Communication Standard as to all normally careful uses. Some potential mav exist for exposure to dust. The ingredients in these products are resin-bonded and hazards normally associated with contact to pure dusts of the listed ingredients should not be significant. Abex has listed all of the essential 'ingredients present in a series of products of this general description. All products identified on this M5D5 contain powder metal but will not contain all of the other materials shown. The recommended exposure limits are those for the most hazardous substance in a class of substances. Exact formulation is considered proprietary and confidential. Precise product information will not be disclosed, other than to a health professional in accordance with the regulations, without an approved Secrecy Agreement. The information herein is believed to be accurate, however, Abex makes no representation or warranty as to its accuracy. This data is furnished gratuitously and independently of any sale of the product, and only for customer investigation arid independent verification. * Abex shall in no event be responsible for anv damages of whatever nature directly or indirectly resulting from the publication or use of or reliance upon data contained Herein. No express or implied warranty of any kind, including warranties of merchantability or fitness for use, with respect to the product or to the data herein is*made hereunder. IDENTITY (As Used on Label and List) 175-59&60. 720W&R. 916. 91&-{46. 46Q &46Q2), 3042-11 & 18, ABEX (669FF, 670FF, 641FF, 6006EE. 682GG). ABB (259FF, 261FF, 255FF. 2000EE). COM (359FF. 360FF, 366FF. 390EE). _ SECTION I Manufacturers Name: ABEX CORPORATION Friction Products Division Address: (Number, Street, City, State, Zip Code) 2410 Papennill Road, P.O. Box 3250 Winchester, VA. 22601 Emergency Telephone Number (703) 662-3B42 Telephone Number for Information (703) 662-3871 Date Prepared November 12. 1985 Preparer M K Uung SECTION II Hazardous Ingredients/Identity Information Hazardous Components (Specific Chemical Identity: Common Namelsi . OSHA PEL ACCIH TLV Silica, Silicates. Tripoli Carbon Black, Graphite, Coal, Coke Phenolic and Cashew Compounds Wood Flour and Other Fillers Iron and Fiber, Zinc, Aluminum, Brass, Magnesium, and their Oxides 0.1 mg/M3 2.0 mg/M3 5.0 mg/M3 1.0 mg/M3 10.0 mg/M3 0.1 mg/M3 2.0 mg/M3 5.0 mg/M3 1.0 mg/M3 10.0 mg/M3 Boiling Point Vapor Pressure (mm Hg.) Vapor Density (Air Ij Solubility in Water SECTION III - Physical / Chemical Characteristics NA Specific Gravity (HjO - 1} NA Melting Point NA Evaporation Rate iButvi Acetate 1) Appearance and Odor 5^^ Odor. Brownish Grey Color RD 00062 3-4 NA 0 Form #3 SECTION IV Fire and Explosion Hazard Data Flash Point (Method Used) ^ Extinguishing Media Wateri (Class ^ B, or C) Flammable Limits NA Special Fire Fighting Procedures ^ LEL Unusual Fire and Explosion Hazards Page 2 of 3 UEL Stability Unstable SECTION V - Reactivity Data Conditions to Avoid ^ Stable Incompatability (Materials to Avoid) ^ X Hazardous Decomposition or Byproducts Incomplete combustion will create carbon monoxide and dioxide. Hazardous Polymerization . May Occur Will Not Occur Conditions to Avoid ^ .X Route(s) of Entry: SECTION VI - Health Hazard Data inhalation? Skin? Ingestion? Health Hazards (Acute and Chrome) Some persons may be sensitive to cashew resins and develop dermatitis-type problems. Dust of silica, graphite, carbon black, and coal can produce pneumoconiosis and other lung damage. Metal dusts can be irritants of die eyes and upper respiratory system. There is little evidence of chronic industrial poisoning from iron, aluminum, and zinc dust. Carcinogenicity: NTP? -- LAJtC Monographs? -- OSHA Regulated? NO Signs and Symptoms of Exposure Cashew resins skin eruptions similar in appearance to poison ivy. Pneumoconiosis - coughing, wheezing, shortness of breath, impaired pulmonary function. Dusts in eye may cause irritation. Gastrointestinal disturbances possible from ingestion. Medical Conditions Generally Aggravated by Exposure ^ Emergency and First Aid Procedures Should not be necessary from the handling of this product. i RD 00063 Form #3 Page 3 of 3' . SECTION VII - Precautions for Safe Handling and Use Steps to B Takes in Case Material ii Released or Spilled Grinding, drilling, mining, etc. can result in the release of airborne dust. Measures as outlined in Section VIII should be followed if this occurs. Waste Disposal Method Hazardous ingredients: 40 CFR, Part 261,262 and applicable State and Local regulations. i Other Precautions Pre-employment screening for allergies and histories of skin sensitivities may be beneficial In determining persons sensitive to cashew materials. SECTION VIII - Control Measures Respiratory Protection t Specify Type! niqsh approved for pneumoconiosis and dust with TLV not less than 0.05 mg/M^. Ventilation Local Exhaust por ^ust exposures exceeding TLV. Mechanical (General) No[ reCommended for dust exposures. Special NK ' Protective Cloves Recommended. Barrier creams for persons with skin sensrtivie to cashew resins. . Eye Protection Should not be needed for normal handling of- product. Eye protection is good practice where dust is propelled by grinding or drilling activities. . Other Protective Clothing or Equipment Long sleeved shirts or other protective cfothing may be beneficial to prevent skin contact of persons sensitive to cashew resins. Work/Hygienic Practices Employees should be property instructed in the use of control measures as indicated above when there is a need (or it. if dust from this product is produced, unnecessary exposures should be avoided by using a vacuum in place of dry brooming. Use wet method of cleaning lor other surfaces. Proper and adequate personal hygiene should be practiced by exposed workers. NA - Not Available NK - Not Known t u '* 7( L ;!3 RD 00064 Form #3 Revised Page 1 of 3 MATERIAL SAFETY DATA SHEET May be used to comply with OSHA's Hazard Communication Standard 29 CFR 1910, 1200. Standard must be consulted for specific requirements. The product identity on this page meets the 05HA definition of an article and is exempt from the Hazard Communication Standard as to all normally careful uses. Some potential may exist for exposure to dust. The ingredients in these products are resin-bonded and hazards normally associated with contact to pure dusts of the listed ingredients should not be significant. Abex has listed all of the essential ingredients present in a series of products ot this feneral description. Ail products identified on this MSD5 contain asbestos but will not contain all of the other materials shown. he recommended exposure limits are those for the most hazardous substance in a class of substances. Exact formulation is considered proprietary and confidential. Precise product information will not be disdosed, other than to a health professional in accordance with the regulations, without an approved Secrecv Agreement. The information herein is believed to be accurate, however, Abex makes no representation or warranty as to its accuracy. This data is furnished gratuitously and independently of any sale of the product, and only for customer investigation and independent verification. * ' Abex shall in no event be responsible for anv damages of whatever nature directly or indirectly resulting from the publication or use of or reliance upon data contained herein. No express or implied warranty of any kind, including warranties of merchantability or fitness for use, with respect to the product or to the data herein is'made Hereunder. IDENTITY (As Used on Label and List) jo se*s. $46 sms. ! 74-ie. n. site, 129-10. ikme. Z7B-a an-n. jow. <a. 562-stz 610-1244132. B8WS. 83-199 Senes B3HS12.S31.539. &551 Senes). 734-161.822-440. 652-1054106, 81-1.96H46.634711.1000-12.12024.3GZ3-7.302-334271X32-7. A5EXI610GG. 611GG. 6071= 620FD, S32DD. 631GE. 6MFF. 633EF. 630FF. 629FE 6Q5GH, 614EF. B3EE. 6I3GG. 674GG. 660GG. E79GG. 516FF. 6UFE. 6S3FF. 6B9FF. BJ40FF. 686FF. 692FF. 6B4FF1. ASS [220GG. 222GG. 2Q3FE 20*FD 2160D. Z29GE. 206FF. 2S5EF.234FF. 221FE. 209GH. 2Q7EF.223EE. 2C6GG. 240GG. 241GG. 280FF. 217FF. 245FE. 2B6FF. 2S7FF. 2B3FF.2S9F?. 297FF). COM 1315GG. 320GG. X1FE. 302FD.314DD. 3Z7E. 304FF. i26EF.332FF.319FE.307GH.30SEF.32lEE.306GG.3S5GG.340GG.31SFr.36aFE.3S2FE.353FF.3TCFFI386FF,373fr.37BFF.3KFr.ST.2D4FD.ST.279fE.S638FE.ST280FF.ES639FF.5TZ44F SECTION I Manufacturer's Name: ABEX CORPORATION Friction Products Division Address: (.Vu/nber, Street. Qfy. State, Zip Code) 2410 Papermill Road, P.O. Box 3250 . Winchester, VA. 22601 Emergency Telephone Number (703) 662-3842 Telephone Number for Information (703) 662-3871 Date Prepared November 12. 1965 p^parei- m. K. Leung SECTION II - Hazardous Ingredients/Identity Information Hazardous Components (Specific Chemical Identity; Common Nimefs) OSHA PEL Asbestos (Crysotile), Talc Silica, Silicate, Tripoli . Carbon Black, Graphite, Coal. Coke Phenolic and Cashew Compounds Wood Flour and Other Fillers iron, Zinc, Aluminum, and their Oxides Copper Oxide 2 fibers/c.e. 0.1 mg/M3 2.0 mg'M3 5.0 mg/M3 1.0 mg/M3 10.0 mg'M3 1.0 mg/M3 ACCIH TLV 2 fibers/c.c. 0.1 mg/M3 2.0 mg'M3 5.0 mg/M3 1.0 mg/M3 10.0 mg/M3 1.0 mg-M3 Boiling Point Vapor Pressure (mm Hg.l Vapor Density (Air - 11 Solubility in Water SECTION III - Physical / Chemical Characteristics NA Specific Gravity (HsO 1) NA Melting Point Evaporation Rate NA (Butvl Acetate I) Appearance and Odor So[idi Qrcjorless. Light Tan to Dark Grey Color RD 00065 1.8 - 2.8 NA 0 Form #1  SECTION IV - Fire and Explosion Hazard Data Rash Point (Method Used) ^ Extinguishing Media Water_ (Class A_ Bt or Cj Rammable Limits HA Special Fire Fighting Procedures ^ LEL Unusual Fire and Explosion Hazards ^ Page 2 of 3 UEL Stability Unstable SECTION V - Reactivity Data Conditions to Avoid Stable Incompatibility (Materials to Avoid) ^ X Hazardous Decomposition or Byproducts Hazardous Polymerization May Occur Will Not Occur Incomplete combustion will create carbon monoxide and dioxide. Conditions to Avoid ^ .X Route(s) of Entry: SECTION VI - Health Hazard Data Inhalation? Skin? y^ Ingestion? y^ Health Hazards (Acute and Chronic) Some persons may be sensitive to cashew resins and develop dermatitis-type problems. Dust of asbestos, silica, talc, graphite, carbon black, and coal can produce pneumoconiosis and other lung damage. Metal dusts can be irritants of the eyes and upper respiratory system. There is little evidence of chronic industrial poisoning from iron, aluminum, and zinc dusts. Copper may cause,keratinization and discoloring of the skin. Chronic intoxication from copper is rare and only in persons with Wilson's Disease. Zinc and copper can produce metal fume fever, but is generally associated with exposures to freshly generated fume of those alloys (molten state). Carcinogenicity: Asbestos NTP? Yes 1ARC Monographs? Yes OSHA Regulated? No Signs and Symptoms of Exposure Cashew Resins -- skin eruptions similar in appearance to poison ivy. Pneumoconiosis -- coughing, wheezing, shortness of breath, impaired pulmonary function. Copper may produce metallic taste in mouth and nausea. Small amounts of ingested copper induces vomiting. Dusts in eye may cause irritation. Gastrointestinal disturbances possible from ingestion. Medical Conditions Generally Aggravated by Exposure Copper exposure and Wilson's Disease Emergency and First Aid Procedures Should not be necessary from the handling of this product. RD 00066 Form #1 Pagp 3 of 3 SECTION VII - Precautions for Safe Handling and Use Stepi to Be Taken in Case Material U Released or Spilled Grinding, drilling, milling, etc. can result in the release of airborne dust. Measures as outlined 'n Section VIII should be followed if this occurs. Waste Disposal Method Asbestos: Per 40 CFR, Part 61, 29 CFR, Part 1910.1001. Other Hazardous Ingredients: Per 40 CFR, Part 261, 262 and applicable State and Local regulations. Other Precautions Pre-employment screening tor allergies and histories of skin sensitivities may be benefidal in determining persons sensitive to cashew materials. SECTION vni - Control Measures Respiratory Protection l Specify Type) NiQsHapprQvediorpneumoconiosis-fibrosisprodudngdustsanddustswithTLVnotiessthanO.OSmg/M^. Ventilation Local Exhaust por jusj exposures exceeding TLV. Mechanical (General) Not recommended for dust exposures. Special NK 0th|sr garner creams for persons with skin sensitive to cashew resins. Protective Gloves Recommended for persons with skin sensitive to cashew resins. Eye Protection Should not be needed for normal handling of product Eye protection is good practice where dust is propelled by grinding or drilling activities. . . Other Protective Clothing or Equipment Long sleeved shirts or otherprotective clothing may be benefidal to prevent skin contact of persons sensitive to cashew resins. Work/Hygienic Practices Employees should be property instructed in the use of control measures as indicated above when there is a need for IL ff dust from this product is produced, unnecessary exposures should be avoided by using a vacuum in place of dry brooming. Use wet method of cleaning for other surfaces. Proper and adequate personal hygiene should be practiced by exposed workers. NA - Not Available NK - Not Known \ CF U.--* w- RD 00067 Form #1 Revised Page 1 of 3 material safety data sheet May be used to comply with OSHA's Hazard Communication Standard 29 CFR 1910, 120Q. Standard must be consulted for specific requirements. The product identity on this page meets the OSHA definition of an article and is exempt from the Hazard Communication Standard as to all normally careful uses. Some potential may exist for exposure to dust. The ingredients in these products are resin-bonded and hazards normally assodated with contact to pure dusts of the listed ingredients should not be significant. Abex has listed all of the essential'ingredients present in a series of products of this general description. All products identified on this MSD5 contain asbestos-free material but will not contain all of the other materials shown. The recommended exposure limits are those for the most hazardous substance in a class of substances. Exact formulation is considered proprietary and confidential. Precise product information will not be disclosed, other than to a health professional in accordance with the regulations, without an approved Secrecy Agreement. The information herein is believed to be accurate, however, Abex makes no representation or warranty as to its accuracy. This data is furnished gratuitously and independently of any sale of the product, and only for customer investigation arid independent verification. '' Abex shall in no event be responsible for any damages of whatever nature directly or indirectly resulting from the publication or use of or reliance upon data contained herein. No express or implied warranty of any kind, including warranties of merchantability or fitness for use, with respect to the product or to the data herein is made hereunder.__________ IDENTITY (As Used on Label and List) 931-(66. 83. 1624162A), 9B7-6, 3027-173.85488), 303-67, 3041-29, ABEX (647GG. 697EE. 685FF, 6009FF, 6000GG. 6008FF. 6014FF 6011FF) ABB (281GG, 294EE. 2B2FF, 296GG. 2003FF, 2010FF, 2007FF, 2005FF), COM (371GG, 383EE 372FF. 395FF, 385GG, 392FF, 3000FF, 397FF) SECTION I Manufacturer's Name: ABEX CORPORATION Friction Products Division Address: (Number, Street, Otv, State, Zip Code) 2410 Papermill Road, P.O. Box 3250 . Winchester, VA. 22601 Emergency Telephone Number (703) 662-3842 Telephone Number for Information (703) 662-3871 Date Prepared November 12. 1985 Preparer M k_ Leung SECTION II - Hazardous Ingredients/Identity Information Hazardous Components (Spedfie ChemicalIdentity: Common Namds) OSHA PEL Glass Fiber Silica, Silicate, Tripoli. Talc Carbon Black, Graphite, Coal, Coke Phenolic and Cashew Compounds Wood Flour and Other Fillers Iron, Zinc, Aluminum, Brass and their Oxides 10.0 mg/M3 0.1 mg/M3 2.0 mg/M3 5.0 mg/M3 1.0 mg/M3 10.0 mg/M3 ACCIH TLV 10.0 mg/M3 0.1 mg/M3 2.0 mg/M3 5.0 mg/M3 1.0 mg/M3 10.0 mg/M3 Boiling Poml Vapor Pressure 1mm Hg.) Vapor Density lAir - 1) Solubility in Water ^ Appearance and Odor SECTION III - Physical / Chemical Characteristics NA Specific Gravity IHjO - 1) NA Melting Point Evaporation Rate NA IButvl Acetate 1) , Odor, Dark Grey Color i RD 00068 1.5 3.5 NA 0 Form #4 SECTION IV Fire and Explosion Hazard Data Flash Point (Method Used) ^ Extinguishing Media Watefi (aass ^ B_ C) Flammable Limits NA Special Fire Fighting Procedures ^ LEL Page 2 of 3 UEL Unusual Fire and Explosion Hazards NK Stability Unstable Stable SECTION V - Reactivity Data Conditions to Avoid NK Incompatability (Materials-to Avoid) ^ Hazardous Decomposition or Byproducts Incomplete combustjon will create carbon monoxide and dioxide. Hazardous Polymerization May Occur Will Not Occur . Conditions to Avoid X Route(s) of Entry: SECTION VI - Health Hazard Data Inhalation? Skin? Ingestion? Health Hazards (Acute and Chronic) Some persons may be sensitive to cashew resins and develop dermatitis-type problems. Dust of glass fiber, silica, talc, graphite, carbon black, and coal can produce pneumoconiosis and other lung damage. Metal dusts can be irritants of the eyes and upper respiratory system. There is little evidence of chronic industrial poisoning from iron, aluminum, and zinc dusts. Carrinogenidty. NTP? . -- 1ARC Monograph*? -- ' OSHA Regulated? No Sign* and Symptom* of Exposure Cashew Resins -- skin eruptions similar in appearance to poison ivy. Pneumoconiosis -- coughing, wheezing, shortness of breath, impaired pulmonary function. Dusts in eye may cause irritation. Gastrointestinal disturbances possible from ingestion. Glass fiber may create transient mechanical irritation of the skin of some persons. Medical Conditions Generally Aggravated by Exposure Emergency and First Aid Procedure* Should not be necessary from reasonable handling of this product i RD 00069 Form #4 Page 3 of 3 SECTION VII Precautions for Safe Handling and Use t Steps to Be Taken in Case Material is Released or Spilled Grinding, drilling, milling, etc. can result in the release of airborne dust. Measures as outlined in Section VIII should be followed If this occurs. Waste Disposal Method Hazardous ingredients: 40 CFR, Part 261, 262 and applicable State and Local regulations. > Other Precautions i Pre-employment screening for allergies and histories of skin sensitivities may be beneficial in determining persons sensitive to ; cashew materials. SECTION VIII - Control Measures Respiratory Protection ( Specify Type) NIOSHapprovedlorpneumoconiosis-fibrosisproducingdustsartddustswithTLVnottessthan0.05mg/M 3. Ventilation Local Exhaust For dust exposures exceeding TLV. Mechanical (General) Not recommended for dust exposures. Sf*cU1 NK Protective Gloves ' Recommended. ther Barrier creams for persons with skin sensitivie to cashew resins and fiber glass. Eye Protection . . .Should not be needed for normal handling of product. Eye protection is good practice where dust is propelled by grinding or drilling activities. ' Other Protective Clothing or Equipment Long sleeved shirts or other protective clothing may be beneficial to prevent skin contact of persons sensitive to cashew resins and fiber glass. Work/Hygienic Practices Employees should be properly instructed in the use of control measures as indicated above when there is a need for it If dust from tr..s product is produced, unnecessary exposures should be avoided by using a vacuum in place of dry brooming. Use wet method of cleaning for otner surfaces. Proper and adequate personal hygiene should be practiced by exposed workers. NA Not Available NK - Not Known 1 nnnl'l J J-.t. J.. ' 1 i ' "j C? CA...---* ....... RD 00070 Form #4 X)CX Revised Page 1 of 3 MATERIAL SAFETY DATA SHEET May be used to comply with OSHA's Hazard Communication Standard 29 CFR 1910, 1200. Standard must be consulted for specific requirements. The product identity on this page meets the 05HA definition of an article and is exempt from the Hazard Communication Standard as to all normally careful uses. Some potential may exist for exposure to dust. _ The ingredients in these products are resin-bonded and hazards normally associated with contact to pure dusts of the listed ingredients should not be significant. Abex has listed all of the essential ingredients present in a series of products of this general description. All products identified on this M5D5 contain asbestos and lead but will not contain all of the other materials shown. The recommended exposure limits are those for the most hazardous substance in a class of substances. Exact formulation is considered proprietary and confidential. Precise product information will not be disclosed, other than to a health professional in accordance with the regulations, without an approved Secrecy Agreement. The information herein is believed to be accurate, however, Abex makes no representation or warranty as to its accuracy. This data is furnished gratuitously and independently of any sale of the product, and only for customer investigation and independent verification. * * Abex shall in no event be responsible for anv damages of whatever nature directly or Indirectly resulting from the publication or use of or reliance upon data contained herein. No express or implied warrant)' of any' kind, including warranties of merchantability or fitness for use, with respect to the product or to the data herein is*made Hereunder. IDENTITY (As Used an Label and List) 38-27E. 83-2. 261-142, 337-1.435-(4. 647). 606-2.693-386. 504, ABEX (615GF, 656FF, 667FF.661 FF. 662FF.626GG. 65SFE. 655FF). ABB (215GF. 249FF. 250FF. 272FF. 268FF. 269FF. 219GG. 253FE). COM (313DF. 361FF. 362FF. 346FF. 394FE. 343FF. 344FF. 317GGj t SECTION I Manufacturer's Name: ABEX CORPORATION Friction Products Division Address: (Number. Street, City, State. Zip Code) 2410 Papermill Road, P.O. Box 3250 Winchester, VA. 22601 Emergency Telephone Number (703) 662-3842 Telephone Number for Information (703) 662-3871 Date Prepared November 12,1985 Preparer M K Leung SECTION II - Hazardous Ingredients/Identity Information Hazardous Components tSpecific ChemicalIdentity: Common Namels) OSHA PEL Asbestos (Crysotile), Talc ' Silica, Silicates, Tripoli Carbon Black, Graphite. Coal, Coke Phenolic and Cashew Compounds Wood Flour and Other Fillers Iron, Zinc, Aluminum, Brass, and their Oxides Lead and its Compounds 2 fibers/c.c. 0.1 ma/M3 2.0 mg/M3 5.0 mg/M3 1.0 mg/M3 10.0 mg/M3 0.05 mg'M3 ACCIH TLV 2 fibers/c.c. 0.1 mg/M3 2.0 mg/M3 5.0 mq/M3 1.0 mg/M3 10.0 mg/M3 0.15 mg/M3 Boiling Point Vapor Pressure (mm Hg.) Vapor Density (Air - 1) Solubility in Water ^ SECTION III - Physical 1 Chemical Characteristics NA Specific Gravity IH^O -1) NA Melting Point NA Evaporation Rate iButv) Acetate 1) Appe.nnc, 'nd 0dor Solid, Odor, Light Tan to Dark Grey Color RD 0007*1 1.6-2.8 NA 0 Form #2 SECTION IV - Fire and Explosion Hazard Data Flash Point (Method Used) ^ Extinguishing Media" WatQ[. (C[ass A, B, Of C) Flammable Limits NA Special Fire Fighting Procedures ^ LEL Unusual Fire and Explosion Hazards Page 2 of 3 UEL Stability Unstable Stable incompatability (Materials to Avoid) ^ SECTION V - Reactivity Data Conditions to Avoid X Hazardous Decomposition or Byproducts Hazardous Polymerization May Occur Will Not Occur Incomplete combustion will create carbon monoxide and dioxide. Conditions to Avoid ^ X Routeisl of Entry: Health Hazards (Acute and Chronic) SECTION VI - Health Hazard Data Inhalation? Yes Skin? Yes Ingestion? Yes Some persons may be sensitive to cashew resins and develop dermatitis-type problems. Dust of asbestos, silica, talc, graphite, carbon black, and coal can produce pneumoconiosis and other lung damage. Metal dusts can be irritants of the eyes and upper respiratory system. There is little evidence of chronic industrial poisoning from iron, aluminum, and zinc dust. Chronic exposure to lead can affect kidneys, blood, gums, gastrointestinal system, and central nervous system. Carcinogenicity: Asbestos NTF? Yes 1ARC Monographs? Yes 05HA Regulated? No Signs and Symptoms of Exposure Cashew resin - skin eruptions, similar in appearance to poison ivy. Pneumoconiosis - coughing, wheezing, shortness of breath, impaired pulmonary function. Dusts in eye may cause irritation. Gastrointestinal disturbances possible from ingestion. Lead may decrease physical fitness, cause fatique, sleep disturbance, headache, aching bones and muscles, abdominal pain and decreased appetite and progressive to more severe symptoms. Medical Conditions Generally Aggravated by Exposure Emergency and First Aid Procedures Should not be necessary from reasonable handling of this product. rD 00072 Form 42 Page 3 of SECTION VTI Precautions for Safe Handling and Use , Steps to Be Taken in Case Material it Released or Spilled Grinding, drilling, milling, etc. can result in the release of airborne dust. Measures as outlined in Section VIII stiould be followed if this occurs. Waste Disposal Method Asbestos per 40 CFR. Part 61, 29 CFR, Part 1910.1001 Other Hazardous Ingredients per 40 CFR, Part 261, 262 and applicable State and Local regulations. . Other Precautions Specific requirements are covered per OSHA 29 CFR 1910.1025 Pre-employment screening for allergies and histories of skin sensitivities may be beneficial in determining persons sensitive to cashew materials. SECTION VIII - Control Measures Respiratory Protection [ Specify Type) N105H approved for pneumoconiosis-fibrosis producing dusts and dusts with TLV not less than 0.05mg/M3. Ventilation Local Exhaust Recommended for dust sources. Mechanical (General) recommBnded for dust control. SpUl NK 0ther Banner creams for persons with skin sensitive to cashew resins. Protective Gloves Recommended where skin contact with lead and cashew resins. Eye Protection . Should not be needed for normal handling of product. Eye protection is good practice where dust is propelled by grinding or drilling activities. Other Protective Clothing or Equipment Recommended in dusty atmosphere. This may be required under the OSHA lead standard depending upon exposure levels. Work/Hygienic Practices Employees should be property instructed in the use of control measures as indicated above when there is a need for it. If dust from this product is produced, unnecessary exposures should be avoided by using a vacuum in place of dry brooming. Use wet method of cleaning for other surfaces. Proper and adequate personal hygiene should be practiced by exposed workers. NA - Not Available .VK - Not Known RD 00073 ORGANIZATION TEXAS MOTOR TRANSPORTATION ASSOCIATION TRUCK RENTING AND LEASING ASSOCIATION TRUCK TRAILERS MANUFACTURERS VIRGINIA HIGHWAY USERS ASSOCIATION WASHINGTON TRUCKING ASSOC. WEST VIRGINIA MOTOR TRUCK ASSOCIATION WISCONSIN MOTOR CARRIERS ASSOCIATION WYOMING TRUCKING ASSOC. ROCKWELL MEMBERSHIP CONTACT KELLY WILSON BEVERLEY WALKER CHARLES CALVIN MARY WORREL PATTY HILES JIM WALLEN MIKE DEHAAN SHENA FOERTSCH PHONE 512/478-2541 202/347-2372 703/549-3010 804/649-9311 206/482-0250 304/345-2800 408/255-6789 307/234-1579 REGION WESTERN SOUTHEAST SOUTHEAST WESTERN SOUTHWEST MIDWEST WESTERN Pace 3 RD 00442 CORPORATE MEMBERSHIPS American Council for Coordinated Action Washington, D.C. American Council on Education - Business-Higher Education Forum Washington, D.C. American Council on Science Health Hew York City Washington, D.C. American League for Exports Security Assistance Washington, D.C. . American Management Association New York City American/Saudi Business Roundtable , New York City - American Security Council Washington, D.C. Atlantic Institute for International Affairs Paris, France Better Business Bureau of W. Pennsylvania Pittsburgh, PA Business Council Washington, D.C. Business Council of Pennsylvania Harrisburg, PA . Business-Industry Political Action Committee Educational Fund Washington, D.C. . Business Roundtable New York City Chamber of Commerce - Inglewood Area Inglewood, CA Pennsylvania Chamber of Commerce Harrisburg, PA Greater Pittsburgh Chamber of Commerce Pittsburgh, PA Chamber of Commerce of the United States . Washington, D.C. : Citizen's Choice Washington, D.C. Civil Air Patrol Maxwell Air Force Base, Alabama Coalition for Uniform Product Liability Law Washington, D.C. Committee for Effective Capital Recovery Washington, D.C. Conference Board New York City Council.of the Americas New York City . Council of Better Business Bureaus Arlington, VA f Council on Foundations Washington, D.C. El Segundo Employers Association El Segundo, CA . Explorers Club New York City RD 00443 Foreign Policy Association . New York City International Management and Development Institute Washington, D.C. National Association of Manufacturers . Washington, D.C. National Aviation Hall of Fame Dayton, OH National Center for Export-Import Studies . Georgetown University .Washington, D.C. National Council for U.S.-China Trade Washington, D.C. Newcomen Society of the United States Exton, PA Ohio Public Expenditure Council Columbus, OH Pennsylvanians for Effective Government Harrisburg, PA Pittsburgh Convention Visitors Bureau Pittsburgh, PA Society of Experimental Test Pilots Lancaster, PA Stockholders of America, Inc. * Washington, D.C. . Tailhook Association Cornorado, CA Tax Foundation New York City and Washington, D.C. Town Hall of California Los Angeles, CA U.S.-Arab Chamber of Commerce New York City . U.S. Council for International Business New York City U.S.-Korea Society Inc. New York City . U.S. Business and Industrial Council Nashville, TN I Washington, D.C. World Affairs Council of Pittsburgh Pittsburgh, PA ' Prepared 1/2/85 RD 00444 ORGANIZATION ROCKWELL MEMBERSHIP CONTACT ALABAMA TRUCKING ASSOCIATION ALASKA TRUCKING ASSOCIATION ALBERTA TRUCKING ASSOCIATION AMERICAN BUS ASSOCIATION AMERICAN MOYERS CONFERENCE AMERICAN SOCIETY FOR TESTING AND MATERIALS ROBERT LIGGETT T.J. THRASHER JOHN A77RELL LORRAIN PERRY LESLIE FRANK tfiERICW TRUCK HISTORICAL SOCIETY MER1CW TRUCKING ASSOCIATION AMERICAN TRUCKING MARKETING ARIZONA MOTOR TRWSPORT ASSOC. ARKANSAS MOTOR ASSOCIATION ASSERTT ATLANTIC PROVINCES TRUCKING ASSOC. PAT DATKA TOM FUGEE CARL TERRY SMALLY JOIN CORBETT TOM CALLAGHAN . DALE ELLIOT AUTOMOTIVE PARTS MWUF. ASSOCIATION OF CANADA 416/366-9673 CALIFORNIA TRUCKING ASSOC. CANADIAN ASSOC. OF FLEET SUPER. CANADIAN TRUCKING ASSOCIATION CtfttDIW URBAN TRANSIT ASSOC. CATRALA OF NORTH CAROLINA CENTRAL OHIO FLEET JIM ROBBINS MARGE DUhAIS MR. KULZ1CK1 MICHELLE O'BRIGHT DIANE KERR LARRY DONDREA COLORODO MOTOR TRANSPORT ASSOCIATION . SHERRI ROBBINS COhMON CARRIERS CONFERENCE IREG. CONSTRUCTION INDUSTRY MttlUF. FARM ftiD INDUSTRIAL EQUIP. INSTITUTE BETH LINE GEORGE HETRICK MR. EBB1NGHAU5E FLORIDA TRUCKING ASSOCIATION GEORGIA MOTOR TRUCKING ASSOC. HAWAII TRANSPORTATION ASSOC. HEAVY DUTY DISTRIBUTION DIVISION HEAVY DUTY MANUFACTURER'S ASSOC. IDAHO MOTOR TRANSPORTATION ILLINOIS TRUCKING ASSOCIATION TOM WEBB BOB WILDER FIN DE15EN BOB SCHUTTE JOHN TRAPP PARK GARRARD RON ADAMS INDIANA MOTOR TRUCK ASSOCIATION MRS, BROUN INTERSTATE CARRIERS CONFERENCE IOWA MOTOR TRUCK ASSOC. JOAN LATOUSH MARY ANN LEMAR KANSAS MOTOR CARRIERS ASSOCIATION MARY TURKINGTQN KENTUCKY MOTOR TRANSPORT ASSOCIATION Q.B. ARNOLD Pane 1 PHONE 205/834-3983 907/276-1149 403/46B-3195 202/293-5890 703/83B-2800 215/299-5400 205/879-2131 703/B3B-1750 714/889-1167 602/252-7559 501/372-3462 202/737-4610 506/386-4413 MORLEY BURSEY 916/329-3500 604/522-2117 613/236-9426 416/365-9800 919/872-2224 614/87B-0957 303/433-3375 2Q2/838-1950 414/272-0943 312/321-1470 904/222-9900 404/876-4313 808/833-6628 312/836-9500 201/B36-9500 208/342-3521 312/246-7D40 317/244-7B51 202/B3S-1950 515/244-5193 913/267-1641 502/223-Q686 REGION SOUTHWEST WESTERN CANADIAN NORTHEAST SOUTHEAST SOUTHEAST SOUTHEAST WESTERN WESTERN SOUTHWEST CANADIAN CANADIAN WESTERN CANADIAN CANADIAN CANADIAN SOUTHEAST MIDWEST WESTERN SOUTHEAST MIDWEST MIDWEST SOUTHEAST SOUTHEAST WESTERN MIDWEST NORTHEAST WESTERN MIDWEST MIDWEST SOUTHEAST MIDWEST SOUTHWEST SOUTHEAST RD 00440 ORGANIZATION LOUISIANA MOTOR TRANSPORT MAINE MOTOR TRANSPORTATION MAINTENANCE COUNCIL MAINTENANCE COUNCIL OF MTASC MAINTENANCE COUNCIL OF NCTA MANITOBA TRUCKING ASSOCIATION MARYLAND MOTOR TRUCK ASSOCIATION MICHIGAN TRUCKING ASSOCIATION MIWESOTA MOTOR TRANSPORT MISSISSIPPI TRUCKING ASSOC. MISSOURI BUS find TRUCK ASSOC. MONTANA MOTOR CARRIERS ASSOC. MOTOR TRANSPORTATION ASSOC. OF SOUTH CAROLINA NATIONAL COUNCIL OF INDEPENDENT TRUCKERS NATIONAL SAFETY COUNCIL NEBRASKA MOTOR CARRIERS ASSOCIATION NEVADA MOTOR TRANSPORT ASSOCIATION NORTH CAROLINA MOTOR CARRIERS ASSOCIATION NORTH DAKOTA MOTOR CARRIERS ASSOCIATION OHIO TRUCKING ASSOCIATION OIL FIELD HAULERS ASSOCIATION ONTARIO TRUCKING ASSOCIATION OREGON TRUCKING ASSOCIATION PENNSYLVANIA MOTOR TRUCK AS50C. PRIVATE TRUCK COUNCIL OF AMERICA REGIONAL AND DISTRIBUTION CARRIERS CONFERENCE SALES AND MARKETING COUNCIL SASKATCHEWAN TRUCKING ASSOC. SOUTH DAKOTA TRUCKING ASSOCIATION TENNESSEE MOTOR TRANSPORT ASSOCIATION ROCKWELL MEMBERSHIP CONTACT JOW HIGHTOWER CLIFF GREY BILL TRACY RONNIE DAVENPORT TED MAWING BOB WILKES MAGGIE HOPKINS PAT TURNER MR. UBE BETTY LOSTON WILMA JAMES AGNES PALMER HARRIET DERRICK NANCY BOYLE T.C. GILCHREST SANDY BERGMANN PAULINE KIEF ELIZABETH BAILEY KAREN DAVENPORT DAVE BARTOSIK LES FINDERSON JUDY BEhNET ARLENE SIMS BILL YOCUM JENNIFER BUTLER WARREN WIEDHAhN MAGGIE O'CONNOR JACK WALSH DAVE LARSON CATHERINE COUTURIER Pane 2 PHONE 504/928-5682 207/623-4128 703/838-1763 803/276-2031 704/373-1933 204/632-6600 301/644-4600 517/393-0253 612/646-7351 601/354-0616 314/634-3380 406/442-6600 803/799-4306 REGION SOUTHWEST NORTHEAST SOUTHEAST SOUTHEAST SOUTHEAST CANADIAN NORTHEAST MIDWEST MIDWEST SOUTHUEST SOUTHWEST WESTERN SOUTHEAST 217/525-0310 MIDWEST 312/527-4QQ0 402/476-8504 MIDWEST MIDWEST 702/331-6884 WESTERN 919/834-0387 SOUTHEAST 701/223-2700 MIDWEST 614/221-5375 512/476-5326 416/249-7401 503/233-7673 717/761-7122 202/785-4900 MIDWEST SOUTHWEST CANADIAN WESTERN NORTHEAST NORTHEAST 703/838-1990 SOUTHEAST 202/B3B-1926 SOUTHEAST 306/569-9696 605/334-8871 CANADIAN MIDWEST 615/255-0558 SOUTHEAST RD 00441 /; J ( i II /OA -L) Lr Zo 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 26 27 28 29 30 31 32 33 34 35 36 37 3B 39 40 41 42 43 44 45 David Booth Beers', State Bar No. 030799 Dana J. Martin, State Bar No. 159860 Shea & Gardner 1800 Massachusetts Avenue, N.W. Washington, D.C. 20036 (202) 828-2000 Attorneys for Defendant Rockwell International Corporation RECEIVED DEC - 5 |gg4 IN THE SUPERIOR COURT OR THE STATE OR CALIFORNIA IN AND FOR THE COUNTY OF ALAMEDA ` MARIE CADEI, ET AL. 7 Plaintiff, v. OWENS--CORNING FIBERGLAS CORP., ET AL., Defendants. No. 739867-2 DEFENDANT ROCKWELL1S RESPONSES TO PLAINTIFFS* FIRST SET OF STANDARD INTERROGATORIES Propounding Party: Plaintiffs Responding Party: Defendant Rockwell International Corporation Set: Plaintiffs' First Set of standard Interrogatories (Dated December 16, 1988) INTRODUCTION Rockwell hereby submits its responses to plaintiffs' 46 standard interrogatories, which were served upon Rockwell 47 with the complaint in the above-captioned case. In 48 answering these interrogatories, Rockwell has construed ' 49 plaintiffs' inquiries regarding ''asbestos-containing 2 DEPOSITION I EXHIBIT 1 products'1 to refer to asbestos-containing products 2 contained in certain automotive brakes, brake assemblies, 3 brake parts, or other brake equipment manufactured or 4 otherwise supplied by Rockwell to which plaintiffs allege 5 the decedent was exposed. Rockwell has taken this approach 6 because it understands that plaintiffs' claims are based 7 upon the decedent's alleged exposure to asbestos from S working with certain automotive brake products.11 To the 9 extent these interrogatories request information about 10 products other than automotive brake products, therefore, 11 Rockwell objects on the ground that information about such 12 products would not be relevant to any issue in this case or 13 be reasonably calculated to lead to the discovery of 14 admissible evidence. Rockwell hereby incorporates this 15 objection into each of its responses below. 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 1/ Upon a telephone inquiry as to product identification in this case, counsel for Rockwell was informed by the office of plaintiffs' counsel that this is a "heavy-duty automotive brake" case. We have proceeded based upon that representation, which is consistent with decedent's work history as described in 5[ VIII of the first cause of action listed in plaintiffs' First .Amended Complaint. Moreover, certain automotive brake products appear to be the only Rockwell products that plaintiffs allege could have been used in connection with the decedent's employment and could have contained asbestos. If, through discovery, plaintiffs develop some basis for contending that the decedent was exposed to asbestos contained in some other Rockwell product, Rockwell will conduct an investigation to determine whether the answers to these interrogatories should be supplemented. 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 3B 39 40 41 42 43 44 45 INTERROGATORY NO. 1: State the IDENTITY of each person who has supplied information used in answering these interrogatories. ANSWER: The information used in answering these interrogatories was gathered over a number of years in connection with asbestos-related litigation against ' Rockwell in numerous courts, and was supplied by several present and former Rockwell employees, many of whom provided only limited information. Those employees .who chiefly provided the information used were as follows: Name/Dates Ms. Barbara Boroughf 1978-present Mr. Larry Bowman 19 77-pres ent Mr. Gerry Danner 1975-present Mr. James English 1963-present Mr. James Ferguson 1971-pres ent Mr. Andy Hansen 1968-present Mr. Glen Hottman 1968-present Mr. Ralph Johnson 1968-present Mr. Timothy Kephart 1978-present Mr. Bruce Ketcham 1978-present Mr. Rober Mathers 1969-93 Mr. Stephen McBride 1963-present Mr. Sam Narayan 1967-present Mr. Jerry Rush 1977-present Deoartment Safety Engineering Engineering Quality and Reliability Sales Quality Control Engineering Sales Purchasing Product Analysis Consultant Sales Engineering - Safety Rockwell Location Troy, Michigan Troy, Michigan Troy, Michigan Kenton, Ohio Kenton, Ohio Oshkosh, Wise. Kenton, Ohio York, S.C. York, S.e. Troy, Michigan Troy, Michigan Kenton, Ohio Troy, Michigan Troy, Michigan 3 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 26 27 28 29 30 31 32 33 34 35 INTERROGATORY NO. 2: State whether YOU are a corporation. If so, state: a. YOUR full corporate name; b. the state of incorporation; c. the date of incorporation? d. the address of YOUR principal place of business? e. if YOU are wholly-owned or if more than five (5) percent of the ownership interest of YOUR COMPANY is owned by another business entity, state that entity's name and principal place of business. ANSWER: Yes. (a) Rockwell International Corporation. (b) Delaware. (c) 1973'. (d) 2201 Seal Beach Boulevard, Seal Beach, California 90470. * (e) Not applicable. INTERROGATORY NO, 3 : Has THIS DEFENDANT ever been identified, known, or done business under any other name? If so, please state such name or names and the time period during which THIS DEFENDANT was so known or identified. ANSWER: Since at least 1935, Rockwell or its corporate predecessors-in-interest have purchased asbestos-containing brake linings from other manufacturers for re-sale throughout the United States and elsewhere in conjunction with medium and heavy-duty brakes and brake assemblies manufactured by Rockwell, chiefly as original equipment for certain commercial and military vehicles. To a lesser extent, Rockwell has also sold replacement brakes and brake 4 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 assemblies with purchased brake linings, and, in addition, Rockwell has sold small numbers of such purchased brake linings separately as replacement parts. The companies in Rockwell's corporate history selling such brakes, brake assemblies, and brake parts have been: Timken-Detroit Axle, until late 1953 when it was consolidated into Rockwell Spring and Axle Co., which in April 1958 became Rockwell-Standard Corporation, which in turn was merged in September 19 67 into North American Rockwell. In February 1973, this company was merged into Rockwell International Corporation, the brake operations of which have since been conducted by its Automotive Division with headquarters at 2135 West Maple Road, Troy, Michigan 48084. INTERROGATORY NO. 4 s " State whether YOU have ever been registered or qualified to do business in the state of California, If so, state the date YOU became qualified to conduct business in the State of California. ANSWER: Yes; July 27, 1935. * INTERROGATORY NO. 5: Does THIS DEFENDANT currently have, or has THIS DEFENDANT had a department, division, subdivision, branch or group responsible for the design, development, manufacture, testing and use of ASBESTOS-CONTAINING PRODUCT(S). If so, state: a. the name of each present or former corporate department, division, subdivision, branch or group? 5 1 2 3 4 5 6 7 S 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 .2 6 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 -4 2 43 44 45 b. the IDENTITY of the person most knowledgeable about such department, division, subdivision, branch or group. ANSWER: No; see answer to Interrogatory No. 3. INTERROGATORY NO. 6i Has THIS DEFENDANT engaged in the MARKETing of ASBESTOS-CONTAINING PRODUCT(S)comprised in whole or in part of amosite asbestos fiber; if so, please state: a. the trade, brand name and/or generic name of each type of product? ' b. the date(s) THIS DEFENDANT first MARKETed each type of product; c. the date-(s) THIS DEFENDANT ceased MARKETing each type of product? d. a description of the chemical composition of each type of product, including: (i) the type(s) apd/br grade(s) of RAW ASBESTOS FIBER contained in each type of product; (ii) the quantitative percentage of the type(s) of RAW ASBESTOS 'FIBER in each type of product; (iii) any change(s) in the quantitative percentages of the type(s) of RAW ASBESTOS FIBER in each type of product; e. the NATURE of each type of product; f. a description of any wording, markings and/or logo on each type of product? g. the recommended use(s) of each type of product, including temperature limits? h. the name(s) of the manufacturer(s) of each type of product? i. the name(s) and address(es) of the supplier(s) of the amosite asbestos fiber used in each type of product? j. the IDENTITY of the person(s) most knowledgeable concerning the purchase of amosite- asbestos fiber by THIS DEFENDANT. ANSWER: No. - INTERROGATORY NO. 7: Has THIS DEFENDANT engaged in the MARKETing of amosite asbestos fiber? if so, please state: -6- 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 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 a. the name and-location of each amosite asbestos mine which THIS DEFENDANT presently operates, has operated, or in which THIS DEFENDANT has or had an ownership interest, including the dates of such ownership, and the grade of amosite asbestos fiber mined; b. the date(s) THIS DEFENDANT first MARKETed amosite asbestos fiber; c. the date(s) THIS DEFENDANT ceased MARKETing amosite asbestos fiber? d. the grade(s) of such amosite asbestos fiber ' MARKETed by THIS DEFENDANT; e. the recommended use(s) of each grade of such amosite asbestos fiber, including any temperature limits? f. the name(s) and address(es) of the supplier(s) of amosite asbestos fiber to THIS DEFENDANT. ANSWER; No. INTERROGATORY NO. 8: Has THIS DEFENDANT engaged in the MARKETing of ASBESTOS-CONTAINING PRODUCTS ` comprised in whole or in part of chrysotile asbestos fiber; if so, please state: a. the trade, brand name and/or generic name of each type of product; b. the date(s) this DEFENDANT first MARKETed each type of product? c. the date(s) this DEFENDANT ceased MARKETing each type of product; d. a description of the chemical composition of each type of product, including: (i) the type(s) and grade(s) of asbestos fiber contained in each type of product; (ii) the quantitative percentage of the types of asbestos fiber in each type of product; (iii) any change(s) in the quantitative percentages of the type(s) of asbestos fiber in each type of product; e. the NATURE of each type of product; f. a description of any wording, markings and/or logo on each type of product; g. the recommended use(s) of each type of product, including temperature limits; h. the name of the manufacturer of each type of product; i. the name(s) and address (es) of the supplier (s) of the chrysotile asbestos fiber used in each type of product; 7 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 26 27 28 j. the IDENTITY of the person(s) mast knowledgeable concerning the purchase of chrysotile asbestos fiber by THIS DEFENDANT. ANSWER: (a)-(c), (e) , (g) Rockwell has never mined, sold:, or purchased raw asbestos fiber. Rockwell has never itself manufactured any asbestos-containing product. See answer to Interrogatory No. 3. Normally, asbestos-containing brake linings purchased by Rockwell are physically incorporated by Rockwell into its brakes and brake assemblies? but small numbers of such purchased brake linings are re-sold separately by Rockwell as replacement parts. Asbestos-containing brake linings purchased by Rockwell have come in solid, block-like form, and they are either grey or brown in color. In the 198 0s, Rockwell gradually stopped manufacturing and selling brake assemblies with asbestos-containing linings for most automotive uses. *' (d) Rockwell understands that all asbestos-containing linings used in its brakes have been made with chrysotile asbestos. Rockwell does not know the answer to the remainder of this interrogatory. (f) Rockwell's name and/or corporate logo has appeared stamped on the undersides of brake shoes and on a plate attached to brake assemblies. Rockwell's name and/or corporate logo was printed in blue and white or black and white on cardboard boxes of replacement brake linings supplied by Rockwell. The brake linings that Rockwell has 6 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 26 27 28 29 30 31 32 33 34 35 purchased have not borne the names or trademarks of their manufacturers, but in some cases they have borne a letter code identifying the manufacturers, such as 11 ABB" (Abex) , "MM" (Carlisle) and "RM" (Raybestos-Manhattan) . In some instances, the lining manufacturers have stamped Rockwell's name and/or corporate insignia on the linings before shipment to Rockwell. (h) Rockwell purchased brake linings from a number of different manufacturers from time to time, including Abex, Rayraark, Bendix, Carlisle, Wagner, Johns-Manville, Karemont, Nuturn, S.K. Wellman, H-K. Porter, Gatke, Worldbestos, and possibly others, as well as predecessors and successors to these companies. (i) Rockwell does not know the answer to this interrogatory. (j) Not applicable. INTERROGATORY NO. 9; Has THIS DEFENDANT engaged in the MARKETing of chrysotile asbestos fiber; if so, please state: a. the name and location of each chrysotile asbestos mine which THIS DEFENDANT presently operates, has operated, or in which THIS DEFENDANT has or had an ownership interest, including the dates of such ownership, and the grade of chrysotile asbestos fiber mined; b. the date(s) THIS DEFENDANT first MARKETad chrysotile asbestos fiber? c. the date(s) THIS DEFENDANT ceased MARKETing chrysotile asbestos fiber? d. the grade(s) of such chrysotile asbestos fiber MARKETed by THIS DEFENDANT; e. the recommended use(s) of each grade.of such chrysotile asbestos fiber, including temperature limits; f. the name(s) and address(es) of the supplier(s) of chrysotile asbestos fiber to THIS DEFENDANT. 9 1 ANSWER: No. 2. 3 4 5 6 7 8 9 ID 11' 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 INTERROGATORY NO. 10: Has THIS DEFENDANT engaged in the MARKETing of ASBESTOS-CONTAINING PRODUCTS comprised in whole or in part of crocidolite asbestos fiber? if so, please state: ' a. the trade, brand name and/or generic name of each type of product; b. the date(s) THIS DEFENDANT first MARKETed each type of product; c. the date(s) THIS DEFENDANT ceased MARKETing each type of product? ' d. a description of the chemical composition of each type of product-, including: (i) the type(s) and grade(s) of asbestos fiber' contained in each type of product? (ii) the quantitative percentage of the type(s) of fiber in each type of product? (iii) any change(s)tin the quantitative percentages of the type(s) of asbestos fiber in each type of product? e. the NATURE of each type of product; f. a description of any wording, markings and/or logo on each type of product; g. the recommended use(s) of each type of product, including temperature limits; h the name of the' manufacturer of each type of product? i. the name(s) and address(es) of the supplier(s) of the crocidolite asbestos fiber used in each type of product? j. the IDENTITY of the person(s) most knowledgeable concerning the purchase of crocidolite asbestos fiber by THIS DEFENDANT. ' ANSWER: No. 38 39 INTERROGATORY NO. 11; 40 Has THIS DEFENDANT engaged in the MARKETing of 41 crocidolite asbestos fiber; if so, please state: 42 ' 43 a. the name and location of each crocidolite asbestos 44 mine which THIS DEFENDANT presently operates, has operated, 45 in the, and/or in which THIS DEFENDANT has or had an 10 1 2 3 4 5 6 7 S 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 ownership interest, including the dates of such ownership, and the grade of asbestos fiber mined; ' b. the date (s) THIS DEFENDANT first MARKETed crocidolite asbestos fiber; c. the date(s) THIS DEFENDANT ceased MARKETing crocidolite asbestos fiber? d. the grade(s) of such crocidolite asbestos fiber MARKETed by THIS DEFENDANT? e. the recommended use(s) of each grade of such crocidolite asbestos fiber, including temperature limits? f. the name(s) and address(es) of the supplier(s) of crocidolite asbestos fiber to THIS DEFENDANT. ANSWER: No. INTERROGATORY NO. 12: Does or did THIS DEFENDANT own shares of stock or otherwise have an ownership interest in a COMPANY which MARKETed ASBESTOS-CONTAINING PRODUCT(S); if so, please state: ' a. the name of such COMPANY; b. the date of incorporation of such COMPANY; c. the state of incorporation of such COMPANY? d. the date such interest was acquired? e. the date such interest changed or terminated, if applicable? " f. the name and location of each facility of such COMPANY; g. the name of each type of ASBESTOS-CONTAINING PRODUCT(S) manufactured, processed and/or assembled by such COMPANY. ' ANSWER: No. See answer to Interrogatory No. 3. INTERROGATORY NO. 13: . Did THIS DEFENDANT own any shares of stock or otherwise have an ownership interest in a COMPANY that MARKETed RAW ASBESTOS FIBER; if so, please state: - a. the name of such COMPANY; b. the date of incorporation or charter of such COMPANY? 11 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 IB 19 20 21 22 23 24 25 26 27 2B 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 c. the state or country of incorporation' of such COMPANY; * d. the date such interest was acquired? e. the dates such interest changed or terminated, if applicable; f. the name and location of each asbestos mine owned by such COMPANY; g. the grade and type of RAW ASBESTOS FIBER mined at each mine. ANSWERS No. INTERROGATORY NO. 14; Has THIS DEFENDANT warehoused any RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCT(S) in the State of California; if so, please state: FIBER a. b. c. records. the address of each warehouse facility; the year(s) THIS DEFENDANT utilized each facility; the IDENTITY Df the 'custodian of warehousing ANSWER: No. INTERROGATORY NO. 15: " Has THIS DEFENDANT owned or operated facilities anywhere in the United States in which ASBESTOS-CONTAINING PRODUCT(S) have been manufactured, processed and/or assembled? if so, state: a. the dates said facilities have been in operation? b. the name of each type of ASBESTOS-CONTAINING PRODUCT manufactured, processed or assembled at each such facility? c. the address of each such facility, including city and state. ANSWER: Yes. Rockwell has supplied asbestos-containing brake linings from the following facilities: Incorporated Into Brake Assemblies and Brake Parts Ashtabula, Ohio (194B-B7) Asheville, N.C. (1982-Present) 12 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 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Battle Creek, Mich. (1974-84) Detroit, Mich. (1909-74) Kenton, Ohio (1949-Present) Knox, Ind. (1964-82) Marysville, Ohio (1972-B2) Newark, Ohio (1951-Present) New Castle, Pa. (1949-93) Oshkosh, Wis. (1919- Present) Pontiac, Mich. (19B5-89) Tilbury, Ontario (1959-Present) Utica, N.Y. (1946-64) York, S.C. (1981-Present) Walled Lake, Mich. (1981-85) Winchester, Ky. (1966-92) Sold as Replacement Brake Parts Brampton, Ontario (1988-Present) Florence, Ky.. (1976-Present) Hayward, Cal. (1977-86) Mississauga, Ontario (19B2-88) INTERROGATORY NO. 16: Has THIS DEFENDANT purchased or otherwise acquired any rights to the manufacture of ASBESTOS-CONTAINING PRODUCT(S) from another COMPANY? If so, state; a. the date of purchase or acquisition of such rights ? " b. the trade, brand and/or generic name of such ASBESTOS-CONTAINING PRODUCT(S) ; c. the name and location of any COMPANY from which such rights were purchased or acquired? d. the IDENTITY of the custodian of records of such purchase(s) or acquisition(s) . ANSWER; No. . INTERROGATORY NO. 17; ' . Has THIS DEFENDANT applied for and/or received any patent (s) for any ASBESTOS-CONTAINING PRODUCT(S) . If sd, state for each such ASBESTOS CONTAINING PRODUCT: a. the product and/or issued? b. the date(s) for which each patent was of application? applied 13 1 2 3 4 5 6 7 8 9 ID 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 3B 39 40 41 42 43 44 45 46 c. the date(s) of issuance of the patent(s) if granted; ' d. the date(s) of renewal, if any; e. the patent number(s); f. the name of the individual or COMPANY to whom each patent was issued; g. the IDENTITY of the custodian of patent records of THIS DEFENDANT. ANSWER: No. * INTERROGATORY NO. 18: Has THIS DEFENDANT registered any trademark(s) for any ASBESTOS-CONTAINING PRODUCT(S)? if so, state for each such ASBESTOS-CONTAINING PRODUCT; a. the product for which each trademark was registered; b. whether the registration was State or Federal; (i) if a State, name the State; c. date(s) of registration; d. the term(s) thereof; e. the date(s) of renewal; f. the name of the individual or COMPANY to whom each trademark was registered; g. the IDENTITY of the custodian of such trademark records of THIS DEFENDANT. ANSWER: No. INTERROGATORY NO. 19: Did THIS DEFENDANT contract with the General Services Administration and/or other federal-government agency for the sale, anywhere in the United States, of RAW ASBESTOS FIBER; if so, state for each such sale: a. the grade(s) and type(s) of RAW ASBESTOS FIBER; b. the quantity; c. the date(s) of delivery? d. the locations), including the address(es), of delivery; e. the name(s) of the agency with which THIS DEFENDANT contracted; f. the date(s) of execution of such contract(s) ; g. the IDENTITY of the custodian of such contract records of THIS DEFENDANT. 14 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 26 27 28 29 30 31 32 33 34 35 36 37 -38 39 40 41 ANSWER: No. INTERROGATORY NO. 20: Did THIS DEFENDANT contract with the General Services Administration and/or other federal-government agency for the sale, anywhere in the United States, of ASBESTOS CONTAINING PRODUCT(S), please state for each such sale:- a. the type of product; b. the quantity; c. the date(s) of delivery; d. the location(s), including the address(es), of delivery; e. 'the name(s) of the agency with which THIS DEFENDANT contracted; . f. the date(s) of execution of such cantract(s); g. the IDENTITY of the custodian of such contract records of THIS DEFENDANT. ANSWER: No. INTERROGATORY NO. 218 Does THIS DEFENDANT have any records of the MARKETing, advertisement, or delivery of its RAW ASBESTOS FIBER and/or ASBESTOS-CONTAINING PRODUCT(S) in or to NORTHERN CALIFORNIA? If so, state: a. the manner in which the records are kept, (e.g., in boxes, files, on microfilm, microfiche or computer tape or disk); b. the location(s) and address(es) where such records are maintained; * . c. the IDENTITY of the custodian of such records. ANSWER; Rockwell*s records of sales of its automotive brake products have not been maintained on such a geographical basis. INTERROGATORY NO. 22: If this defendant has in its possession any records of the MARKETing, advertisement, or delivery of its RAW 15 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 IB 19 20 21 22 23 24 25 26 27 2B 29 30 31 32 33 34 35 36 37 38 ASBESTOS FIBER and/or. ASBESTOS-CONTAINING PRODUCTS (including microfilm, microfiche, computer tape or disk, or any other system in which data is taken from other -records), state whether THIS DEFENDANT has retained the original DOCUMENTS from which the data entered into these modes of storage was obtained. If THIS DEFENDANT has not retained such original DOCUMENTS, state: a. the date(s) when and location(s) original DOCUMENTS were disposed of; b. the IDENTITY of the custodian of DOCUMENTS at the time of their disposal. where the the original ANSWER: Rockwell maintains originals of some documents reflecting sales of its brakes and brake parts that have also been reproduced in other forms, and such originals are* maintained at the' locations referred to in the answer to Interrogatory No. 15. Each such facility has a records custodian. Many original records, however, have been discarded in the ordinary course of business. INTERROGATORY NO. 23: Does THIS DEFENDANT have in its possession any exemplar (s) of advertisements or brochures describing its RAW ASBESTOS FIBER and/or ASBESTOS-CONTAINING PRODUCTS; if so,* please state: ' a. the location of each exemplar; b. the year(s) in which said exemplar(s) was utilized; c. the IDENTITY of the custodian of such exemplars. ANSWER: Yes. The answer to the remainder of this interrogatory may be ascertained from copies of the relevant advertisements and brochures, which will be made available for inspection at the offices of Rockwell's National Coordinating Counsel, Shea & Gardner, 1800 Massachusetts Avenue, N.W., Washington, D.C. 20036. 16 1 IINTERROGATORY NO. 24; 2 State the following: 3 4 a. the address(es) where the corporate records of 5 THIS DEFENDANT (including minutes from the Board of 6 Directors meetings and corporation annual reports), are 7 currently located? B b. the IDENTITY of the custodian of such records. 9 10 ANSWER; Corporate records are stored at the various 11 Rockwell plants identified above, as well as at Rockwell's 12 corporate offices in Pittsburgh, Pennsylvania and Seal 13 Beach, California, and at Rockwell's automotive division 14 headquarters in Troy, Michigan. Each facility has its own 15 records custodian. 16 17 INTERROGATORY NO. 25; 18 Describe the packaging or containers in which THIS 19 DEFENDANT sold and/or distributed RAW ASBESTOS FIBER, 20 including composition, dimension, shape and color. 21 22 ANSWER: Not applicable. 23 24 INTERROGATORY NO. 26; . 25 Describe any logo, design, marking or printing, 26 including size and color, which appeared on the packaging 27 or containers in which THIS DEFENDANTsold and/or 28 distributed RAW ASBESTOS FIBER. 29 30 ANSWER; Not applicable. 31 ' 32 INTERROGATORY NO. 27= 33 Describe the packaging or containers in which THIS 34 DEFENDANT sold and/or distributed ASBESTOS-CONTAINING 35 PRODDCT(S), including composition, dimension, shape and 36 color. 37 17 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 IB 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 ANSWER: Rockwell's brake products with asbestos-containing linings have generally been shipped as follows: (1) brakes with axles: stacked and banded on wooden pallets? (2) stand-alone brake units: stacked and banded on wooden pallets and, in recent years, encased in plastic? (3) replacement linings and linings on shoes: cardboard boxes. INTERROGATORY NO- 28; Describe any logo, design, marking or printing, including size and color, which appeared on the packaging or containers in which THIS DEFENDANT sold and/or distributed ASBESTOS-CONTAINING PRODUCT(S). ANSWER: See answers to Interrogatory Nos. 8(f) and 29. INTERROGATORY NO. 29: Does THIS DEFENDANT have any exemplars of packaging or containers in which its RAW ASBESTOS FIBER and/or ASBESTOS- CONTAINING PRODUCTS were sold and/or distributed. If so, . state: a. the location of each exemplar? b. the year(s) in which said exemplar(s) was utilized? c. the IDENTITY of the custodian of such exemplars. ANSWER: Yes, insofar as this question relates to packaging or containers currently in use. The answer to the remainder of this interrogatory may be ascertained from the exemplars themselves and related documents, which will be made available for inspection at the offices of Shea & Gardner. INTERROGATORY NO. 30! . - 18 - 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 26 27 28 29 30 31 32 33 34 35 36 37 38 Did THIS DEFENDANT put warnings of asbestos-related health hazards on bags of RAW ASBESTOS FIBER? if so, please state: a. the wording of such warning(s), including size, location, and color; b. whether the warning was put on a tag attached to the bags? c. the date such warning(s) was first used; d. whether any change was made in the wording of such warnings, the date(s) of such change, and the reasons for such change. ANSWER; Not applicable. INTERROGATORY .NO. 31: Did THIS DEFENDANT put warnings of asbestos-related health hazards on the packaging or containers of ASBESTOSCONTAINING PRODUCT(S) ? If so, please state: a. the wording of such 'warnings, including size, location on the packaging or containers, and color? b. the date such warning(s) was first used? c. whether any change was made in the wording of such warning(s), the date(s) of such change, and the reason(s) for such change. ANSWER; Yes. " . Asbestos-containing brake linings: since the late 1970s. Brake equipment into which asbestos-containing brake linings were incorporated: since 19B7. The answer to the remainder of this interrogatory with regard to the form and. content of warnings and instruction materials used on brake products may be ascertained from copies of the labels and related explanatory documents, which will be made available for inspection at the offices of Shea & Gardner. 19 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 26 27 28 29 30 31 32 33 34 35 36 37 INTERROGATORY NO. 32; Has THIS DEFENDANT distributed any brochures or pamphlets that contain warnings of any asbestos-related health hazards? if so, please state: a. the wording of such warning? b. the method used to distribute such brochures or pamphlets ? c. the date(s) such brochures or pamphlets were first issued; d. whether THIS DEFENDANT has exemplars of such brochures or pamphlets; e. the IDENTITY of the custodian of such exemplars. ANSWER: Yes. The answer to the remainder of this .interrogatory with regard to the form and content of warnings and instruction materials used with brake products may be ascertained from copies of the explanatory documents, including package'inserts, field maintenance manuals, and material safety data sheets, which will be made available for inspection at the offices of Shea & Gardner. INTERROGATORY NO. 33; Did THIS DEFENDANT warn its employees and/or CONTRACT UNIT(S), anywhere in the United States, that exposure to asbestos could be hazardous to human health. If so, state: a. whether copies of documents containing such warnings exist? b. the IDENTITY of the custodian of such documents. ANSWER: Yes. These documents are stored at the offices of Shea & Gardner. INTERROGATORY NO. 34: 20 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 26 27 28 29 State the IDENTITY of medical directors and/or industrial hygienists employed by THIS DEFENDANT in the United States. ANSWER: Medical Directors: Rockwell's corporate-wide medical directors include Dr. Richard Morrison from 1962 until 1979, Dr. Robert Pringle from 19B1 until 1984, Dr. Toby Freedman from 1985 until 1988, and Dr. Albert Puskas from 1988 until 1990. Rockwell has had plant physicians for a number of years. The details of such arrangements are contained in Rockwell's medical care files, which will be made available for inspection at the offices of Shea & Gardner. Industrial Hvcrienists: From 1971-1983, John Rozas served as Rockwell's company-wide Manager of Industrial Hygiene. From 1970-1983, John Maciezjezk served as Corporate Director of Environmental Health and Safety. In 1993, Richard Risenweber-became Vice President for Environment, Health, Safety, and Energy Conservation. -i Dick Johnson served as plant Safety Manager in Troy, Michigan from 1974-1976, and William Long served as Regional Safety Manager in Troy, Michigan from 1976 - 1990. Barbara Boroughf has been a Regional Safety Manager since 1985, and Dick Michalack has been a Regional Safety Manager since 1990. INTERROGATORY NO. 35: Has any employee of THIS DEFENDANT testified by deposition on behalf of THIS DEFENDANT in a third-party 21 1 2 3 4 5 6 7 8 g 10 n 12 13 14 15 16 17 IB 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 case, brought in the United States, wherein the plaintiff has alleged an asbestos-related injury? If so, for each such third party case, please state: a. b. c. d. record. the the the the caption and case number; court of filing including state date of the deposition name and address of plaintiff's and county? counsel of ANSWER: No. INTERROGATORY NO, 36; Has THIS DEFENDANT had a CONTRACT UNIT? each CONTRACT UNIT, please state: If so, for ' a. the date "such CONTRACT UNIT commenced operation; b- the date such CONTRACT UNIT(S) ceased operation? c. the name and location in the State of California of each job site at which such CONTRACT UNIT worked. ANSWER; No. INTERROGATORY NO. 37; Has THIS DEFENDANT been a member of the following: a. Asbestos Textile Institute (ATI); b. Industrial Hygiene Foundation and/or Industrial Health Foundation (IHF); c. Mineral Wool Institute; d. Industrial Mineral Insulation Manufacturers Institute? e. Magnesia Silica Insulation Manufacturers Association? f. National Insulation Manufacturers Association (NIMA) ; g. (TIMA); Thermal Insulation Manufacturers Association ` h. Asbestos Information Association (AIA); i. Quebec Asbestos Mining Association (QAMA)? j. National Safety Council? k. Asbestos Cement Producers Association; l. Refractories Institute? m. any other organizations or associations of manufacturers, miners, distributors, importers, labellers, suppliers and/or sellers of ASBESTOS-CONTAINING PRODUCTS; 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 IS 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 (i) please state the name(s) of such organizations or associations. ANSWER; (a)-(l) No. (m) Yes. . SAE (formerly the Society of Automotive Engineers) 400 Commonwealth Drive Warrendale, Pennsylvania 15096 ' (Rockwell employees, rather than Rockwell itself, are members of this organization.) Heavy-Duty Brake Manufacturers Council 2460 Lemoine Avenue, Suite 510 Fort Lee, New Jersey 07024 INTERROGATORY NO. 3 ai For each organization, association or other entity identified in your Response to Interrogatory No. 37, please state: a. The dates during which THIS DEFENDANT was a member. b. The name(s) of any publication(s) received by this defendant from such association or organization. c. The name of such committee or subcommittee of Which THIS DEFENDANT was a member, and the dates of such committee or subcommittee membership. ANSWER: Rockwell employees have been members of SAE for many years, and Rockwell has been a member of the Heavy- Duty Brake Manufacturers Council since 1986. Rockwell itself has never been a member of SAE or any of its committees. The answer to the remainder of this interrogatory may be obtained from documents concerning the Society of Automotive Engineers and Heavy-Duty Brake Manufacturers Council, which will be made available for inspection at the offices of Shea & Gardner, except for those documents that Rockwell claims are protected from disclosure on the basis of the attorney-client privilege or 23 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 26 27 28 29 30 31 32 33 34 35 36 37 38 'work product rule, a list of which will also be made available in conjunction with the inspection of the remaining documents. INTERROGATORY MO. 39i Has THIS DEFENDANT received any DOCUMENTS containing results or conclusions of any studies and/or tests conducted by the Saranac Laboratory at the Trudeau Foundation relating to the human health consequences of exposure to asbestos? If so, please: a.* IDENTIFY all such DOCUMENT(S); b. state the date upon which THIS DEFENDANT first received such DOCUMENT(S); c. the IDENTITY of the custodian of such DOCUMENT(S) . ANSWER: No. ` INTERROGATORY NO. 40i State whether THIS DEFENDANT has ever maintained a library (or libraries) in the United States which contains books, articles, periodicals, journals and/or reference materials that relate to"the subjects of asbestos, industrial hygiene, medicine, safety, occupational disease and/or engineering. If so, state: a. the date each such library was established; b. the location of each such library; c. the IDENTITY of each librarian or other person in charge of such library; ' . ANSWER: Rockwell has maintained, at a number of its facilities and corporate offices, collections of engineering and related materials that might be considered libraries. These collections have generally contained regulatory materials which included information relating to occupational exposure to asbestos, but have not generally contained materials relating to asbestos and health. 24 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 INTERROGATORY NO. 41; Has THIS DEFENDANT exchanged or communicated with any individual or other COMPANY documents containing the results of tests and/or studies of the relationship between the inhalation of asbestos fibers and development of disease(s); if so, please state; a. each individual or COMPANY with whom the information was exchanged or to whom it was communicated; b. the date(s) of any such exchanges or communications; c. the IDENTITY of the custodian of such documents. ANSWER: No. INTERROGATORY NO. 42: Has any employee of THIS DEFENDANT testified before the Occupational Safety and Health Administration, the National Institute of Occupational Safety and Health, or any committee or subcommittee of the United States Congress on the inhalation of asbestos dust and the development of disease; if so, please state: a. the entity before whom such testimony was given? b. the date(s) and location(s) of such testimony; c. the IDENTITY of the individual(s) who so testified? - d. whether any DOCUMENTS were presented to the entity before which testimony was given; e. whether copies of DOCUMENTS presented were retained by THIS DEFENDANT; (i) if so, state the IDENTITY of the custodian of such DOCUMENTS. ANSWER: No. . INTERROGATORY NO. 43 i At any of the physical facilities identified in the response to Interrogatory No. 15, has THIS DEFENDANT conducted, or caused to be conducted, tests and/or studies of ambient asbestos dust created during the manufacture, processing and/or assembling of ASBESTOS-CONTAINING PRODUCT(S); if so, please state: 25 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 26 27 28 29 30 31 32 33 34 a. each manufacturing facility, including location and address, conducted; b. the c. the at which any such test and/or study was date of each such test and/or study? individual(s) or entity conducting each such test and/or study; d. whether THIS DEFENDANT has any documents containing the results and/or conclusions of each such study ? e. the IDENTITY of the custodian of such documents. ANSWER: Yes. (a)-(e) Since the early 1970s, Rockwell has performed regular monitoring of airborne asbestos concentrations at its automotive plants to determine the effectiveness of asbestos dust control measures and to ensure compliance with applicable health regulations. Further information about the dates, locations, methodology, and results of individual asbestos monitoring measurements in Rockwell automotive plants may be found in monitoring records which will be made available for inspection at the offices of Shea & Gardner, except for those documents that Rockwell claims are protected from disclosure on the basis of attorney-client privilege or the work product rule, a list of which will also be made available in connection with the inspection of the remaining documents. INTERROGATORY NO. 44; Has THIS DEFENDANT conducted, or caused to be conducted, any tests and/or studies on ambient asbestos dust levels at any location or job site where its ASBESTOSCONTAINING PRODUCTS were utilized in the United States; if so, please state: 26 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 26 27 28 29 30 31 32 33 34 35 36 37 3B 39 40 41 42 a. the location-, including name and address, at which each such test and/or study was conducted; - b. the individual(s) or entity conducting each such test and/or study; c. the date of each such test and/or study; d. whether THIS DEFENDANT has any documents containing the results and/or conclusions of each such test and/or study; e. the IDENTITY of the custodian of such documents. ANSWER: No, insofar as this question relates to locations other than Rockwell's own manufacturing plants. See answer to Interrogatory No. 43. INTERROGATORY NO. 45S Did THIS DEFENDANT have any laboratory or other facility anywhere in the United States at which it conducted, or caused to be conducted, any tests and/or studies of its ASBESTOS-CONTAINING PRODUCTS to measure the amount of asbestos dust generated by any use for which such products were designed; if so, please state: a. the location, including name and address, at which each such test and/or study was conducted; b. the individual (s) or entity conducting each such test and/or study; c. the date of each such test and/or study; d. whether THIS DEFENDANT has any documents containing the results and/or conclusions of each such test and/or study; e. the IDENTITY of the custodian of such documents. ANSWER; No. INTERROGATORY NO. 46: Has THIS DEFENDANT financially supported any research into the relationship between the inhalation of asbestos fiber and development of disease(s); if so,, please state the date(s) and recipient(s) of such financial support. ANSWER: No. 27 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 26 27 28 29 30 31 32 33 34 35 36 37 38 39 INTERROGATORY NO. 47s Has THIS DEFENDANT made available to its employees engaged in, anywhere in the United States, the MARKETing its RAW ASBESTOS FIBER and/or its ASBESTOS-CONTAININGPRODUCT(S), a medical examination program; if so, please state: of a. whether chest x-rays or pulmonary function tests were part of such program (s) ; b. whether participation in any such program was a mandatory condition of employment or was voluntary; (i) if mandatory as a condition of employment, how frequently each employee was required to undergo such examination; c. whether THIS DEFENDANT has DOCUMENTS of such program? d. the IDENTITY of the custodian of such DOCUMENTS. ANSWER: Yes. Medical examinations have been provided on an annual or biennial basis for all employees who take part in the machining of asbestos-containing linings at Rockwell's automotive plants. These employees are given physical examinations, chest x-rays, and pulmonary function tests. The earliest date medical examinations were provided is 1973. Documents relating to such examinations were maintained at each production facility in the ordinary course of business. INTERROGATORY NO, 48: Has THIS DEFENDANT notified in writing any individuals or COMPANIES to whom it MARKETed RAW ASBESTOS FIBER and/or ASBESTOS-CONTAINING PRODUCT (S) , anywhere in the United States, of the potential-relationship between exposure to asbestos and disease; if so, please state: a. the date(s) THIS DEFENDANT provided this information; b. the means used for transmittal of such information; 28 1 2 3 4 5 6 7 8 9 XO 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 c. whether THIS DEFENDANT has any copies of any DOCUMENTS transmitting such information; ' d. the IDENTITY of the custodian of such documents. ANSWER: Yes.` See answers to Interrogatories No. 31 and INTERROGATORY NO. 49: Has THIS DEFENDANT required any individual(s) who MARKETed its ASBESTOS-CONTAINING PRODUCT(S), anywhere in the United States, to wear respirators or face masks; if so, please state: a. the job title(s), if known, of individual(s) required to wear respirators or face masks ? b. the date*(s) on which THIS DEFENDANT first required the wearing of respirators or face masks; c. the means by which the requirement to wear respirators or face masks was communicated; d. whether THIS DEFENDANT has any copies of DOCUMENTS communicating such requirements; e. the IDENTITY of the custodian of such-DOCUMENTS. ANSWER: No, insofar as this question relates to locations other than Rockwell's own manufacturing plants. See answer to Interrogatory No. 43. INTERROGATORY NO. 50= Does or did THIS DEFENDANT utilize or employ any CONTRACT UNIT. If so, please state: . a. the inclusive periods of time the CONTRACT UNIT(S) was utilized or employed; b. the business address and name of the CONTRACT UNITS(S); c. whether THIS DEFENDANT has any DOCUMENTS showing the location(s) of the job site{s) where the CONTRACT UNIT(S) worked, and if so, state the IDENTITY of thecustodian of such DOCUMENTS. ANSWER: No. 29 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 26 27 28 29 30 31 32 33 34 35 INTERROGATORY MO. 51:. ' Has THIS DEFENDANT received any written communication or other DOCUMENT, other than a claim for workers' compensation, that any person was claiming injury as a result of exposure to its RAW ASBESTOS FIBER and/or ASBESTOS-CONTAINING PRODUCT(S); if so, please IDENTIFY the first such written communication or DOCUMENT. ANSWER: Yes. The first lawsuit filed against Rockwell `in which a plaintiff claimed an asbestos-related injury was the Hinton case, filed in the U.S. District Court for the Southern District of Mississippi on September 13, 1978. Rockwell was served with the complaint on September 14, 1978. * INTERROGATORY NO. 52; ' Has any person filed a claim for asbestos-related injury against any workers' compensation insurance carrier which provided coverage for THIS DEFENDANT; if so, please state: a. the date of such claim; b. the name of claimant; c. the caption; d. the case number; e. the court in which the claim was filed; f. the IDENTITY of the custodian of such documents. ANSWER: Yes. The remaining answers to this interrogatory may be ascertained from Rockwell's files relating to workers' compensation claims, which will be made available for inspection at the offices of Shea & Gardner, except for those documents that Rockwell claims are protected from disclosure on the basis of the attorney-client privilege or the work product rule, a list of which will also be made 30 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 2B 29 30 31 32 33 34 35 36 37 38 39 40 41 available in connection with the inspection of the remaining documents. INTERROGATORY NO. 53i Has any person filed a workers1 compensation claim for asbestos-related injury against THIS DEFENDANT; if so, ' please state; a. the date of such claim? b. the name of claimant; c. the caption; d. the case number? ' e. the court in which the claim* was filed? f. the IDENTITY of the custodian of such documents. ANSWER; See answer to Interrogatory No. 52. INTERROGATORY NO, 54: ' Does THIS DEFENDANT have insurance available to cover judgment(s) entered against it in asbestos-related personal injury lawsuits? if so, please state; a. the name and principal place of business of any insurance carrier who has issued such policy of insurance? b. the number and effective date of each policy; c. the amount(s) of coverage of each policy? d. the applicable dates of coverage? e. policy? any reservation of rights contained in each such f. the amount of coverage presently exhausted under each such policy; ` g. the amount of coverage presently available, under each such policy? h. whether limits contained in each such policy include costs of defense. ANSWER: Yes. The answer to the remainder of this interrogatory may be ascertained from Rockwell1 s insurance policies and related documents, which will be made available for inspection at the offices of Shea & Gardner, except for those documents that Rockwell claims are 31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 IB 19 20 . 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 protected from disclosure on the basis of the attorneyclient privilege or the work product rule, a list of which will also be made available in connection with the inspection of the remaining documents. INTERROGATORY MO, 55; Has THIS DEFENDANT owned or operated any petroleum refining facilities; if so, please state; a. whether any ASBESTOS-CONTAINING PRODUCTS were MARKETed on the premises of such refining facilities ? b. the location, including the name and address of all such refining facilities? c. the dates of operation of such refining facilities; d. the types of ASBESTOS-CONTAINING PRODUCTS MARKETed on such premises; e. the names of the manufacturers of any ASBESTOSCONTAINING PRODUCTS MARKETed on such premises; f. whether THIS DEFENDANT has documents identifying such MARKET ing; g. the IDENTITY of the custodian of such documents. ANSWERS No. INTERROGATORY NO. 56; Has THIS DEFENDANT held any ownership interest in a COMPANY which owned or operated petroleum refining facilities; if so, for the period(s) of time during which THIS DEFENDANT held such interest, please state: . a. whether any ASBESTOS-CONTAINING PRODUCTS were MARKETed on the premises of such refining facilities; b. the location, including the name and address of all such refining facilities; c. the dates of operation of such refining facilities ? d. " the types of ASBESTOS-CONTAINING PRODUCTS MARKETed an such premises; e. the names of the manufacturers of any ASBESTOS- CONTAINING PRODUCTS MARKETed on such premises; 32 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 IB 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 . such f. whether THIS MARKETing? ' g. the IDENTITY DEFENDANT has documents identifying - of the custodian of such documents. ANSWER; No. INTERROGATORY NO. 57; Has THIS DEFENDANT contracted with any COMPANY for the MARKETing of ASBESTOS-CONTAINING PRODUCT(S) on any premises owned or leased by THIS DEFENDANT? if so, please state: a. the location, including name and address of such premises? b. - the name and address of each such COMPANY? c. the types of ASBESTOS-CONTAINING PRODUCTS; d. the name of the manufacturers of such ASBESTOS- CONTAINING PRODUCTS; e. whether THIS DEFENDANT has DOCUMENTS of such MARKETing; . f. the IDENTITY of the custodian of such DOCUMENTS. - ANSWER; No. Dated; December 1994 David Booth Beers Thomas J. Mikula Dana J. Martin Shea & Gardner 1800 Massachusetts Ave., Washington, D.C. '20036 (202) 828-2000 N.W. Attorneys for Defendant Roclcwell International Corporation 33 1 2 3 4 5 6 1 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 COUNTY OF OAKLAND STATE OF MICHIGAN VERIFICATION ) ) SS, ) BRCJCE E. KETCHAM, of full age, being duly sworn according to law, upon his oath deposes and says: 1. I am the Manager, Product .Analysis of defendant Rockwell International Corporation's Automotive Division and am duly authorised to make this affidavit on its behalf. 2. The facts set forth in the foregoing answers to interrogatories are true to the best cf my personal knowledge, information, and belief. e E. Ketcham Subscribed and sworn to before me this _____________, 1994. day of Notary Public My Commission Expires: __ DIANA R.L0FTJN JCTAHYP1JDUC - 0JW CCXJNTt Ml SH EA & GARDNER IBOO MASSACHUSETTS AVENUE, N.W WASHINGTON, D. C. 20036 FRANCI5 M. SHEA II90S-I9B91 WARNER W. GARDNER LAWRENCE J. LATTO RICHARD T. CONWAY ROBERT T. BASSECHES BENJAMIN W. BOLEY RALPH J. MOORE, JR MARTIN J. FLYNN STEPHEN J. POLLAK DAVID BOOTH BEERS ANTHONY A LAPHAM RICHARD M. SHARP JOHN D. ALOOCK WILLIAM 5. MOORE JOHN TOWNSEND RICH JAMES R. BIEKE I. MICHAEL GREENBERCER WILLIAM F. 5HEEHAN FREDERICK C. 5CHAFRICK DAVID B. COOK STEPHEN J. HADLEY FRANKLIN O. KRAMER WENDY 5. WHITE WILLIAM R GALEOTA PATRICK M. HANLON NANCY C. SHEA TIMOTHY K. SHUBA JAMES R. BIRD MICHAEL S. GIANNOTTO JEFFREY C. MARTIN WILLIAM R. HANLON ELIZABETH RUNYAN GEISE COLLETTE C. GOOOMAN JULIE M. EDMOND LAURA S. WERTHEIMER RICHARD M. WYNER THOMAS J. MIKULA EUGENIA LANGAN NANCY B, STONE CHRISTOPHER E. PALMER MARK S. RAFFMAN ELIZABETH M. BROWN t2021 828-2000 TELECOPIER: 12021 S2B-295 December 8, 1994 WILLIAM H. DEMPSEY OF COUNSEL VIA. FEDERAL EXPRESS Francis Fernandez, Esquire Kazan, McClain, Edises & Simon 171 Twelfth Street, Third Floor Oakland, California 94607 ' ERIC C. JEFFREY ELISE J. RABEKOFF JOSEPH F. TENOUSKAS ROBERT B. WASSERMAN BERNICE M, BLAIR ANNE ft. BOWDEN WILLIAM D. WEINREB DAVID A. BONO KENNETH F. SPARKS LISA A. LANDSMAN ANTHONY HONG AMANDA BERLOWE JAFFE JOHN MOU5TAKAS DAVID E. JONES JONATHAN . BOGGS CYNTHIA GURNEE PUGH OANA j. martin J. BRADFORD WIEGMANN LLOYC D. COLLIER DAVID M. BATTAN* VALERIC - ROSS* MICHAEL K_ ISENMAN David b. goodhano BENJAMIN J. VERNIA MARTHA HIRSCHFIELD AM* HORTON DAVID J. KATZ CELESTINE R. McCONVILLE COWARD J. NAUGHTON* KIM E. DETTELBACH* MARTIN F. HANSEN* "not ADMITTED in d.C. Re: Marv Cadei v. Owens-Corning Fiberglas Com. et_al_.. No. 739867-2 (Alameda Superior Court) Dear Mr. Fernandez: Enclosed is an original executed copy of the verification of Bruce Ketcham on behalf of Rockwell International. Enclosure 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 26 27 28 29 30 31 COUNTY OF OAKLAND STATE OF MICHIGAN VERIFICATION )' } SS. ) BRUCE E. KETCHAM, of full age, being duly sworn according to law, upon his oath deposes and says: 1. I am the Manager, Product Analysis of defendant Rockwell International Corporation's Automotive Division and am duly authorized to make this affidavit on its behalf. 2. The facts set forth in the foregoing answers to interrogatories are true to the best of my personal knowledge, information, and belief. _ Hawfe e . Ketcham Subscribed and sworn to before me this $ $ day of _____________, 1994. ' DIANA R. L0FT1N NOTARY PUSUD - OAKLAND COUNTY, Mi MY COMMISSION EXPIRES 01/Q2M \fJ ' GRIEVANCE FORM ^ Grievance No. -J 1 NORTH AMERICAN ROCKWELL - National Agreement-UAW Plant f Name of Grlevant Classification Lo G fiL Name of Protested Employee Classification ? nv Dept, . Dept, Paragraphs) of Agreement Violated N- STEP 2: Statement of Dispute and Remedy Requested 9 0>rins* JO * If none, so state . QR7UKn / / Hock Mo. snift An Hock * So. '* Seniority Date Hourly Rata Seniority 3ate Sftlft Hourly Rate / Data Violation Occurred , /- . /<0- /3-7 -3 At th prasont time we are still recieving lining from vendors that have not removed the asbestos dust from the rivet and bolt holes thUBja-oating a serious health hax&rd to the operators of the riveters and the G.U.Cbenoh;^^is a serious problem and must be stopped immediatly. Signature of Grlevant STEP 2: Management's Disposition Date Signed hltll Signature of lUnlort Official Date /-73V JSubmitted - 11 vendors of brake blocks are being notifiedtfy the Purchasing Dept, to ensure _iat material received from them meets the specifications as set forth in the purchase agreement. At the same time, air sample tests are being made at the GM bench to see if a health hazard does, in fact, exist. Naturally, if a hazard is present, the Company .will take necessary action to correct same. Grievance allowed as qualified. . STEP 3: 1 Signature of Union Official, 2'Dllposleion li unacceptable, state reason for appealing Q 1 ^itur r Date Received Hi-Ti Signature of Union Official STEP 3: Management's Olsoosltlon Date Submitted Management Official Date Received Signature of Management Official Date Submitted Union Official PREPARE IN QUADRUPLICATE! J-Comm. Cnalrman, 2-Unlon, 3-Personnel Supervisor, 4-Supervlsor (Use attachments - Do Not Write on Back of Form) Received ,. REV. 2-1*71 ,? " ` GRIEVANCE FORM NORTH AMERICAN ROCKWELL -- National Agreement-UAW Grievance No. -- Plant ' ' 1 L Name of Grlevant Classification /CO Name of Protested Employee R'L FL___________________________________ ' 14_________________ Dept. i 1f < Clock No. Shift .. tiff =lock ' /' No. Seniority ate Hourly Rata Seniority ate . Classification Dept. Shift Paragraon(s) of Agreement Violated N- 3:STEP Statement of Dispute and Remedy Requested S- ** .0 f? 7 if ft f y 1 if none, so state h. ftf. nn ' c ,i Hourly Rate Pate Violation Occurred f. - in- In, At the praaent time vie are still recieving lining fron vendors that hare not removed the asbestos dust from the rivet and bolt holes thus ^creating a serious health ha tard to the operators of the rivotrs and the G.U.C.benoh.!Ss is a serious problem and must be stopped immedlatly. Signature of Grlevant STEP 2: Management's Disposition 'll vendors of brake Date Signed Aj^lZZ Signature of /-\ Union Official .7 blocks are being notified^ the Purchasing Data 7V hSuomltted ') ? Dept, to ensure *at material received from them meets the specifications as set forth in the purchase agreement. At the same time, air sample tests are being made at the GM bench to see if a health hazard does, in fact, exist. Naturally, if a hazard _ is present, the Company will take necessary action to correct same. Grievance allowed as qualified. Signature of Management* Date Suomltted Signature of Union Official Date Received STEP 2> if Management's STEP 2 Disposition Is unacceptaOle, state reason for appealing Signature of Union Official STEP 3: Management's Disposition Date Submitted Signature of Management Official Date Received Signature of Management Official Oate Submitted Union Official PREPARE IN QUADRUPLICATE! Chairman, 2*Unlon, 3-Personnet Suoervlsor, 4-Supervlsor (Use attacnments. bo Not Write on Back of Form) RD 00450 Received ' . REV. 2-1-71 i-jcasts, L. Vander RoesC ' K. Davidson January 12., 1973 ' 'v- ' . Molded Materials Division P.0. Box 417 Ricgway, Pennsylvania 15553 ' ` Attention Mr. Ed Zacharias Gentlemen: . This letter is Being directed to all of our lining suppliers along with a copy of a grievance from our local labor representation, UAW Local 274. This grievance -is self-explanatory and some of you have been cautioned of this condition previously and advised this situation cannot be tolerated. To those of you who have been supplying lining trouble free we appreciate your diligence, but to those who*are negligent, we must advise that material found in the condition described, is subject to rejection and return at your expense', * ' It is requested that prompt attention be given this matter to insure that only acceptable material reaches our plant. Very truly yours, ROCKWELL-STANDARD DIVISION North^^e^rican Rockwell ' V. E. Pilkington Purchasing Agent VEP/pm Enclosure . * RD 00452 July 12, 1973 Dr. Jon Swanson Swanson Environmental Consultants, 24630 Sv7anson Road Southfield, Michigan 48076 Inc. Dear Jen: Enclosed are the photomicrographs you allowed us to see, I apologize for not returning them sooner. I understand our Mr. Quick has been in contact with you. I certainly hope you will be able to assist us. Again, thank you for sending this material to us. It was most helpful and we here have a better understanding of what asbestos and resinous material look like. - Very truly yours, ROCKWELL-STANDARD DIVISION Rockwell International Corp. Larry Vander Roest Ass't. Manager Personnel & Industrial Relations ma Enel. cc: Messrs. L. Vander Roest K. Davidson * January 12, 1973 ' TheBendix Corporation . _ Friction Materials Division . 420 North Center Building 20700 Greenfield Road Oak Park, Michigan 4B237 . Attention Mr. J. L. Manion ' Gentlemen: -. This letter is being directed to all of our lining suppliers along "with a copy of a grievance from our local labor representation, UAV 'Local 274. This grievance is self-explanatory and -some of you have been cautioned of this condition previously and advised this situation cannot be tolerated. To those of you who have been supplying lining trouble free we appreciate your diligence, -but to those who are negligent, we must advise that material found in the condition described, is subject to rejection and return at your expense. It is requested that prompt attention be given this matter to insure that only acceptable material reaches our plant. Very truly yours, , ROCKWELL-STANDARD DIVISION *. Purchasing Agent VEP/pm Enclosure RD 00453 cc: Messrs. L. Vander Roest K. Davidson January 12, 1973 ' v' * Abex Corporation American Brakeblok Division 1650 VJ. Big Beaver Rd., Suite 205 Troy, Michigan 43084 . . Attention Mr^ C. E. Hubbard Gentlemen: ' This letter is being directed to all of our lining suppliers along with a copy,of a grievance from our local labor representation, UAW Local 274. This grievance is self-explanatory an'd some of you have been cautioned of this condition previously and advised this situation cannot be tolerated. To.those of you v;ho have been supplying lining trouble free we appreciate your diligence, but to those who are negligent, v?e must advise that-material found in the condition described, is subject to rejection and return at your expense. It is requested that prompt attention be given this matter to insure that only acceptable material reaches our plant. Very truly yours, ROCKWELL-STANDARD DIVISION Nort^^^jrican Rockwell . * . V. E. Pilkington Purchasing Agent VEP/pra Enclosure " CARLISLE HEAVY DUTY BRAKE BLOCKS AND SEGMENTS ............ .............. 'i - Molded Materials Division CARLISLE CORPORATION ' : P. D. BOX P, RIDGWAY, PA. 15853 TELEPHONE (814) 773-3187 January 23, 1973 North American Rockwell Corporation Rockwell-Standard Company 3500 North Ridge West Ashtabula, Ohio 44004 Attention: Mr. V. E. Pilkington Purchasing Agent Re: ' Your letter of January 12, 1973 Dear Mr. Pilkington: Subject: `Asbestos dust in rivet and bolt ' holes . . We believe we have taken all possible steps to insure that you encounter no difficulty on above subject. Yours sincerely. MOLDED MATERIALS DIVISION ERZ:pj RD 00455 stvanson environmental consultants5 me. 7 South Dearborn Street Suite 1631 Chicago, Illinois 60603 Telephone (312) 372-5493 June 5, 1973 ' Rockwell Standard Division Rockwell International 3500 North Ridge West Ashtabula, Ohio 44004 . * . Attn: Mr. Larry E. Van Der Roest Assistant Manager, P. 8c I.R. *` Dear Sir: . . ` Attached you will find photomicrographs of previous asbestos samples obtained in a brake manufacturing plant. Plate #1 shows very clearly a good example of " the asbestos fibers under extremely high magnification. Plate #2 shows a grinding operation sample with only a large resinous piece of material visible on the membrane surface. It is my contention that these resinous, materials may be the object of your current problem with OSHA. Plate #3 provides a ' . good view of both the filters and resinous material under extremely high mag- . nification. . ; .` . ` I would recommend to you that our firm obtained some independent samples in your grinding areas to provide you with visible evidence such as enclosed .. which may be useful in possible litigation. I would be most pleased to discuss . this further with your attorneys or staff. ;. ' Please return the enclosed photomicrographs as soon as possible as these ` are part of our permanent files. . . ' : Very truly yours, * . Enclosures RD 00457 Southfield, Michigan - Telephone (313) 352-0960 Internal Letter Rockwelf international Dale July 15, 1974 No. TO Address Messrs: J. Ensman E, Bollard A, Wrlghtnour FROM . W,J, Robison Jr, Address . Phono . Ext, 268 Subjnci . Lining Dust In Blocks as Received - Health Hazard. - Due to possible health hazard caused by excessive asbestos dust left;in linings by vendors the following procedures will be implemented. . 1. Receiving Inspectors will note Receiving Inspection Transfer with code 82 .(cleanliness defect) when excessive lining dust is found. 2. Mr. Ensman will initiate SW0 to clean and advise vendor of charge back. 3. Mr. Ensman will requisition a small "Shop Vac" to be used for dust removal in rework area. - 4, Department Foremen (3QA. and B 31A and Midnights) and Inspectors will advise vendor, part number and quantities found in balance of shipments discovered with excessive lining dust in departments and transfer linings to rework area. 5. Mr. Ensman will implement items 2 & 3 to affect corrections. ft 4- W.VT. Robison Jr. ' dlf cc: Rec, Insps. (7) ^JW.-'Moon E. Gierok V. Pilkingtoa Foremen Sc Insps, 3QA & B 3LA. Sc Midnights (14) RD 00494 : deposition EXHIBIT 12. August 19, 1971 Subject: * Inspection nauestos Lining in Department 30 by OSHA Complaint Officer On August 11. -1971. at approximately 2:45 p.m., Mr.'Heard advised Mr. rrea liriTTTcns, Plant Manager, and presented his credentials that he had been contacted to inspect the plant. The purpose of this inspection was based upon a complaint filed by an employee. The complainant wished to remain anonymous, therefore his name was not disclosed. The Inspector advised Mr. Griffiths and Mr. Davis that the specific complaint related to the grinding operation of asbestos lining in Department 3D. During the initial conversation, the inspector questioned the above individuals concerning the plant operations, to provide him with the necessary information for completing the government forms. * '- He .asked if there was a designated representative of the employees to-conduct the Company representative on the tour. He was advisedthe Company representative would be Mr. Davis, Manager of Industrial Relations and Personnel, and the employee, representative would be Mr. 0. Richey, Chairman'of the Union Safety Committee. : Mr. Heard v/as advised that the company was aware of the potential health hazard that could be caused by asbestos and, in' fact, had employed the services of George D. Clayton t Associate's to conduct an air sampling survey. The purpose of this survey was to evaluate the contamination of the air in those areas where asbestos v/as being ground, drilled, or riveted. The results of the survey, which was conducted in July, were not yet available and as soon as they were received the .Company would be evaluating the findings and recommenda tions to determine what, if any, action v/as necessary. At approximately 3:15 p.m., Mr. Richey, Mr. Davis, and Mr. Heard commenced the tour in Department 30 - grinding operation. During the initial stages, it was brought to the attention of the inspector, by Mr. Richey, that there were other areas where manufacturing operations v/ere being performed on asbestos lining. As a result, the inspection included all areas where considerable lining was operated on including: Department 30 - grinding, riveting, and out side dust collecting unit, Department 31 - grinding, riveting, drilling, and. dust collecting unit, Department 50 - assembler, and the Tennant sweeper. . The inspection overlapped into the second shift, during which time Mr. Heard talked at considerable length with Mr.'R. Pearson, a riveter in Department 30. In addition, a conversation was also held with a group of four employees, who pointed out a specific dust problem when the large brake linings v/ere ground in Department 31. The t RD 00446 -2- Inspector advised this group of employees that, in a situation-such as he was experiencing here, it was conceivable that to see all of the problems and products manufactured by.this organization, he would have to spend.a month in the plant. However, unfortunately, or fortunately, his schedule would not permit this to occur and there fore he was aware of the fact that he may not.be seeing 'the best or the worst conditions. . The union second shift safety representative. Hr. D. Hunt, requested that- the inspector go down to the assembly department and observe the handling of the brake lining. Hr. Hunt alleged considerable dust was emitted in the handling^of the lining. At this point. Hr. Hunt accompanied'the inspection team to the assembly department. Mr. Heard advised that there appeared to be no dust on the floor underneath' the boxes of brake \inings, nor did there appear to be any dust in the air from handling of these linings by the assemblers, -therefore he did not consider this a potential health hazard area. At this point, the group left the assembly department and proceeded back up to the main office area'. Mr. .Davis then advised Hr. Hunt that the 05HA did not provide for two representatives of the employees to^accompany the inspector on his inspection, and in.accordance with this rule, asked Hr. Hunt to return to work, as the employees were . represented by Hr. Richey, Chairman of the Union Safety Committee. Hr. Heard, at this time advised Mr. Richey and Hr. Davis that he was pleased with the cooperation he had seen`exhibited between the com- ' pany and the union, and further that It was apparent t.hat the company recognized the potential health problem, as they had employed the services of an outside consultant, and furthermore it appeared the union was understanding of_the reason for not making changes in the -present system, until such time as the report by the consultants could be analyzed and studied. '. Foilowing-this brief report, at approximately 5:15 p.m. the following critique was given by Hr. Heard to Hr. Griffiths and Mr. Davis. 1. That the anonymous complainant had advised the inspector,1 during the tour, that his name could be divulged. The complainant Is Hr. R. Pearson. The inspector related that Hr. Pearson appears to believe.things are "looking up", as the company has had a survey made. . . 2. The guards on all chain driven belts should not be below 7 ft. ' The company advised the inspector they were aware of this, in - -fact approximately 2 weeks ago they had commenced to survey the plant to determine the most feasible method of accomplishing this task. ' RD 00447 i -3- . \ 3. Small portable fans be removed or' brought Into compliance with the laws. Company advised that portable fans referred to were- personal property of the employees and that they would take necessary action. 4. Pedestal grinders be brought into compliance with law. Company was also aware .of this and the Maintenance Depart ment was commencing to work on 'it.' 5. Respirators should be furnished to employees when they are requested. Company advised this was the practice, *and in fact in the last several weeks had furnished two respirators to employees who had requested same. 6.' Inspector recommended that Tennant sweeper be replaced, as it appeared to be ineffective.. Company advised that they were presently studying various proposals and types of sweeper - equipment. 7. Inspector questioned the length of the run on the dust collector in Department 30. Company .advised this would be looked into. . ' 8. Inspector advised the line in Department 30 was reported to be half full of brass and suggested that the line be cleaned out. Company advised they will looiuinto this. In summation, the inspector reported he was not unduly 'concerned over the asbestos problem at this time, since the Company was investigating the potential health hazards and at this time was -waiting for a report from their consultants. At approximately 5:45 p.m. the inspector departed. Mel Davis MD/jt RD 00448 ASSESSMENT RESPECTING ASBESTOS EXPOSURE ROCKWELL INTERNATIONAL . HIGHWAY BRAKE AND TRAILER AXLE DIVISION TILBURY, ONTARIO The following assessment is documented to meet the requirements of Section 6 (1) of the Regulation respecting asbestos. Chapter 321 of the Revised Statutes of Ontario, 19B0. The completion of this document was achieved with the able assistance of the following personnel: Mr. Peter Belanger, Plant Chairman of Local 1941 of the UAW, representing hourly employees at the Tilbury plant; Mr. Edgar Labonte and Mr. Greg Church, both Health and Safety Coirmittee Mercfaers of Local 1941 of the UAW;. Mr. Joe Simard, Labour Relations Supervisor at Tilbury; Mr. Dan Ianicello, Manager, Industrial Relations at Tilbury; Mr. Mike Berthiaume, Director of Manufacturing at Troy, Michigan, and former Plant Manager at Tilbury. The input from the various parties was greatly appreciated. It is a concensus that this assessment indicates Rockwell has satisfied the requirement and the intent of the Legislation. T"depos!t!on I 1 EXHIBIT ! rf % RD 00528 WORKBOOK FOR DESIGNATED SUBSTANCE ASSESSMENTS SUBSTANCE: ASBESTOS (CHRYSQTILE) DATE: AUGUST 22, 1933 COMPANY NAME: ROCKWELL INTERNATIONAL DEPARTMENT/ OPERATION( S): ' HIGHWAY BRAKE & TRAILER AXLE DIVISION LOCATION! S): TILBURY, ONTARIO ASSESSMENT PREPARED BY: Lqng TITLE: REGIONAL MANAGER, SAFETY ENGINEERING, TROY, MICHIGAN DATE PREPARED: AUGUST 22, 1983 RD 00529 t I APPLICATION -- WORKSHEET 1: IS THE DESIGNATED SUBSTANCE PRESENT? * 1. (a) Do any of the processes or activities or situations listed in the Appendix, or other ' information sources, indicate that the substance is or may be present? . YES 9 NO 1. (b) Do any data sheets or information from your suppliers indicate the presence of the substance? YES $ - NO 2. If substance is present, indicate the department where it is used, nature of the use (i.e. direct or indirect) and the quantity purchased per month or year: Product Name Department How Used? Direct/Indirect Quantity Per Month/Year BRAKE LININGS RIVET l GRIND DIRECT * . 140,000 TOTAL/MO (CHRYSOTILE ASBESTOS) ASSEMBLY ' DIRECT . SO,COO/MO ARE GROUND SHIPPING & INDIRECT . 17,200 ARE MON RECEIVING ASBESTOS LINING5 I QUALITY CONTROL INDIRECT WAREHOUSING INDIRECT . 400 OF THE 80,000 ARE NON A5BEST0S CENTRAL PAYOUT INDIRECT CAROUSEL INDIRECT **. 1CQ,OGO/TOTAL/MO LIFT TRUCK DRIVER INDIRECT **. 40,003 ARE GROUf THESE FIGURES ARE FOR THE MONTH OF AUGUST, 19G3 .n n ii " " 11 " JANUARY, 1986 ** 40% Or TOTAL LININGS ARE NONASBESTOS CONCLUSIONS Read statements and check applicable box: Substance not present anywhere in workplace: regulation does not apply. No Assessment needed. _ Processes.'activities have been identified where substance present. I Proceed to worksheet 2. RD 00530 APPLICATION -- WORKSHEET 2: IS WORKER EXPOSURE LIKELY? 1. In what form does the substance enter the plant? SOLID & SOME DUST IN, THE BOXES. Product title:. _BRAKE_LIWIHGS CARDBOARD BOXES Type of container: STRETCHED WRAPPED 25 LININGS EACH OR Size 0f Container: 5J..LINING5 EACH 2. Is this form altered during use or in the operation? YES 0 NO If YES, indicate altered fnrm- 57% OF LININGS ARE GROUND; THIS GENERATES DUST 3. Is there a possibility of the sub stance being released into the workplace environment during normal use? YES NO If YES, indicate the stage of the operation or areas where this can occur. INSPECTION, MATERIAL HANDLING, RIVETING, GRINDING, BRAKE ASSEMBLY BENCH. STACKING AND BANDING. 4. If YES, to Question 3, specify the job functions and approximate number of employees who might be exposed: (see addendum nl) fob Function Number of Employees RIVETERS S GRINDERS 1C OVER 3 SHIFTS 5. If YES, to Question 3, indicate how workers could be exposed: Inhalation ID Ingestion Skin absorption D Skin contact D 6. If NO, to Question 3, is there a likelihood of escape due to leaks, accidents, etc.? Are workers likely to be exposed? YES D YES D NO NO D CONCLUSIONS Are there any activities/situations where exposure by any route is likely? YES 1x3 If NO, no further action is necessary. Date completed__ , If YES, an assessment is necessary. -- Proceed to Section in NO Note: If protection against exposure has been left up to some engineering control measure which can fall, or deteriorate for any reason, or to a work/hygiene practice, an assessment is necessary. -- Proceed to Section III. RD 00531 rn INDUSTRIAL HYGIENE SURVEY ROCKWELL-STANDARD COMPANY BRAKE PLANT ASHTABULA, OHIO September 15, 1970 L 2 DEPOSITION i EXHIBIT IL L RD 00576 George D. Clayton & Associates, Inc. Subsidiary of Sitkin Smelting and Refining Company, Inc. 25711 Southfield Road, Southfield, Michigan 4B075 * Telephone: 313-352-3120 ( for better environment October 20, 1970 Mr. John Florip Environmental Safety Engineer Rockwell-Standard Company Detroit, Michigan 48231 . . Dear Mr. Tlorip: Presented herewith are three copies of our report covering the industrial hygiene survey conducted at the Ashtabula Brake Plant on September 15, 1970. In summary, we find the airborne concentrations of parti culate, including oil mist, iron oxide and asbestos to be within acceptable levels. It should be noted that this study represents a very limited, screening type survey rather than a careful documentation of workers1 exposures on the basis of repeated samples. It is apparent, however, that on the basis of this limited study there is no ob vious evidence of inhalation hazards to workers in the plant. It has been a pleasure for us to assist you with this project. Should there be any questions concerning the study, do not hesitate to call. G DC : e s RD 00577 INDUSTRIAL HYGIENE SURVEY ROCKWELL-STANDARD COMPANY BRAKE PLANT ASHTABULA, OHIO INTRODUCTION Rockwell-Standard Company retained George D. Clayton & Associates, Inc. to conduct an .industrial hygiene survey at tea Brake Plant near Ashtabula, Ohio. This report sum marises the results of that study conducted on September 15, 1970 by Mr. John E. Mutchler of Clayton & Associates, as sisted by Mr. John Florip, Environmental Safety Engineer, .Rockwell-Standard Company. DESCRIPTION OP OPERATIONS The Rockwell-Standard Plant surveyed produces asbes tos lined cast and fabricated brake shoes for trucks and trailers. The basic operations include the formation of brake shoes by projection welding with subsequent grinding, milling, machining, asbestos liner bonding (both adhesive and riveted), sizing and assembly. The facility is a one story building covering about 236,000 square feet. A visual Inspection of the plant revealed a neat, well- kept operation for this type of manufacturing, with poten tial inhalation exposure to workers from the following 'materials: total inert dust, iron oxide from welding fume, oil mist and asbestos fibers. ' . TOXICITY AND HAZARDS OF MATERIALS SAMPLED INERT DUST - The term "inert dust" includes a wide variety of chemi cal substances both inorganic and organic, which have been so classified because of a long history of not producing lung disease after prolonged exposures. Because all dust, however inert, may under extraordinary circumstances pro duce lung disease, It is desirable to place a limit on ex posures to these materials. The American Conference of Governmental Industrial HygieniGts has specified a Thres hold Limit Value (TLV) of 10 milligrams per cubic meter or 30 million particles per cubic foot of air as representing acceptable limits of good hygienic practice. IRON OXIDE Industrial experience has shown a high incidence of mottling of the lungs, or iron pigmentation in workers exposed to high concentrations of airborne iron oxide. ' However, the usual effect is considered to be benign pneu moconiosis 6ince it does not lead to fibrous proliferation, has a low order of severity, and usually requires six to RD 00578 -2- ten years of exposure before effects are observable by X-ray techniques. The American Conference of Govern mental Industrial HygienistB has established a TLV for iron oxide fume of 5 milligrams per cubic meter of air based primarily on preventing iron deposition in the lungs. OIL KIST Oil mists encountered in industrial operations con sist of hundreds of individual hydrocarbon compounds from the paraffinic, cycloparaffinic, aromatic, and polyaro matic series. Generally, these oils have a low degree of toxicity and, since their vapor pressures are quite low, inhalation .of vapors is not a significant health hazard. However, exposure to airborne mists of these . oils can cause irritation of. mucous membranes and chem ical pneumonitis if there is excessive direct contact of the liquid or aerosol with pulmonary tissue. The American Conference of Governmental Industrial Hygienists haa established a TLV for non-specific air borne oil mist of 5 milligrams per cubic meter of air.' ASBESTOS Asbestos inhalation is a well known potential indus trial health hazard which can lead to a characteristic lung fibrosis, termed "asbeatosis", Until recently the standard method of sampling asbestos in the workroom was based on the number of particles per unit volume (mil lions of particles per cubic foot) determined by- standard impinger sampling and 100X lightfield microscopy. For several years the Threshold Limit Value (ACGIH) was set at 5 mppcf. In 1969 the Threshold Limits Committee changed the TLV to a tentative value of 12 asbestos fibers per ml for fibers greater than 5^ in length, as determined by phase contrast microscopy at 430X. In 1970 the Committee reduced the TLV to a tentative value of 6 fibers per ml on the same basis. The British Occu pational Hygiene Society has adopted a standard for chrysotile of 2 fibers per ml for 50 years of exposure, 4 fibers per ml for 25 years of exposure, or 10 fibers per ml for 10 years of exposure. These standards are, in the opinion of the experts, the best that can be drawn from existing data. These data are not ideal and. of course, the standards are subject to review in the light of new evidence and improved methods of measurement. Good industrial hygiene practice suggests controlling exposures below the maximum allowable level, rather than maintenance at the maximum. In this connection, it is appropriate to design current engineering controls for an expected airborne concentration of 2 fibers per ml in RD 00579 view of the trend downward in the acceptable exposure level and in accordance with good engineering practice. SAMPLING AND ANALYTICAL PROCEDURES Airborne concentrations of suspended particulates and oil mist were sampled simultaneously at the Ashtabula Plant by drawing air through midget impingera containing isopropyl alcohol at rates of.2 to 4 liters per minute. These implnger samples were analyzed for oil and aolida by evaporating the lBopropyl alcohol at 60*C, weighing the residue of oil and solids, extracting the oil with benzene, and evaporating the benzene to determine the net weight of the oil residue. The weight of solid ma terial in each sample was determined by difference. Both the dust (solids) concentration and oil mist con centration were calculated in terms of milligrams per cubic meter, mg/m3. A high volume air sample was taken in the tool crib near the center of the plant. This sample was taken to obtain enough material to determine the composition of suspended dust in the general work area. The filter sample was weighed and the mass concentration determined in milligrams per cubic meter. Atomic absorption spec trophotometry was then used to determine the iron content of the sample which was then used as a basis of estimating the concentration of iron oxide dust existing generally in Che plant, expressed as mg/m^ of In line with the latest sampling development speci fied for asbestos, air samples were collected on pre weighed cellulose ester membrane filters by using Mine Safety Appliance battery-operated samplers. At the con clusion of a sampling period the filter head was removed and carried to the office area where the filters were carefully transferred to sealed containers for transport back to the laboratory of George D. Clayton & Associates. The method of counting asbestos fibers was that used by the U.S. Public Health Service for the enumeration of asbestos dust on membrane filters. The description of this method by G. H. Edwards and J. R, Lynch appeared In Ann. Occup. Hyg., 11, 1-6 (1968). After weighing, sections of the sample are mounted on standard microscope slides using a high viscosity solution of membrane filter material in a 1:1 mixture of diethyl oxalate and dimethyl phthalate to render the fil ter transparent. The asbestos fibers which lie on the surface filter are counted with phase contrast microscopy specified by the tentative Threshold Limit Value) 10X eyepiece and a 40X phase contrast objective. of the (as using RD 00580 Ten fields selected at random on the sample are counted and fibers greater than 5y and lOy. are recorded. Any particle having an aspect ratio of 3 or greater is considered to be a fiber. RESULTS OF STUDY Results of the airborne particulate measurements and airborne oil mist concentrations- are summarized in Table 1. Iron oxide Is expressed as mg/m3 of Fe203 . The results of the asbestos fiber sampling are summarized in Table 2. Examination of these data indicates that the concentrations of non-specific total dust, iron oxide and oil nifit are veil within acceptable limits throughout the plant. At the projection welding machines where the high est iron oxide concentration would be expected, the total dust concentration of only 1.38 mg/m3 clearly indicates that the iron oxide level would be very much below the acceptable level of 5 milligrams per cubic meter. Table 2 Indicates that the total dust exposures are higher than recommended levels at Che Gardner grinding machines and assembly station at the permafuse bonding' oven, hut that in these and all other areas where the brake liningB are being bonded, riveted and sized, the concentrations of asbestos fibers appear to be within acceptable levels. CONCLUSIONS AND RECOMMENDATIONS On the basis of the samples collected during this brief industrial hygiene 6tudy at the Ashtabula Brake Plant of Rockwell-Standard Company, there is no evidence of inhalation hazards to workers in those operations surveyed. However, it is recommended that local venti lation systems at Che Gardner grinders be inspected, cleaned and modified to provide better capture and re duce the total dust concentration in the grinders1 breathing zone. This report prepared by . _ Lees RD 00581 u n !e f O il ! < i.o < 1 .0 RD 005 m E MM *-s. Oi4 60 d o E 1 o OO H pH p4 VV X o c 0 u u a fat i--4 re 4J 0 H H o > a u am u u c m u 0> o Ik E *>. fiC e o u 4u m aw a US N OQ N HE Va S R *H ao C/3 > m <N m o o pH CM o in nc- 1i i ' r- pi <r o pH . CM ta m r> o n m pH o p* |M Os VO pH o ooo w< S co s W CO E-l < C3 h a 4-1 a Cl Uu r* us a i4 c. M-U 5 H E o (Q V to CO 3 o VO H n. H r-. in CM in CM o U (H Q *4 co & to _M < < CO J) " Id ^2Z ou 2HM P* >- C3 . JS u a . < ft H CO UH e> co CO =3 oa W S5 UM ft pi .< O a -h 2X <o H CO - i ra rJ 3 W .O 3 SO LI a j: O o) rt < 00 e d H 0 pH H CL W 6V a 0< C/3 a. 0 4J C/3 4J a u to d o 4*4 U D. tU .M U w 0) Q 0) a So a ss CO VO M cn pH A *0 QO U e a pH o. cu Q u a u e u u d H J3 H H U pH 0 0 H m n SO CM m CM o mm rH pH o CM m n m in m 1-4 o Cl 0 ov OS o VO OS mm c\ Os o AU d d M US V ao a pd CO 14 JJ O to d a i-i u Q. CO i | aa 0) a uu << pH pH aa lu u CJ o dd 0J a ou Un XD u QJ a o i-3 a pH * 60 aC a d i4 H Q rH 44 rH u U H a os >o --> o u 0o au b0 E H uQ d jj CL a 0 dX a CO *4 a a X P > Li u a 4J n a o. a a o ns 1-4 CM cn -O m eu e a c -- u cn rH in m pH rH in m in pH H pH a. o' a Ma t Os ii Ov os iii Os Os Ov c e % - u a a 3 0 U X l-l f*4 V o n cn . . CM . L 1. . . 1970 D ate 9-15 9-15 . i D 3_ ^^ S ao o S ^ cu >eh- <wi c kJ k5 CJ hi Wj M r' 1 v . . . .' .a l ASBESTOS GEORGE D . FI < O DCIATES, IN C . UMMARY F I an S a m p le ! No. a o H - 41 CU <ri U o a V V Cm S a m p lin g S ta rt m o H a u o a S am ple i S am ple H e ig h t V olum e mg lite rs | 1 a. A n X ao a C o n c e n tra tio n | F lb e ra /m Oi 3. \0 O9 1-4 A R iv e te r fe e d in g G a rd n e rg rin d e r 13:09 13:50 ; 2931 [A ssem bly a re a - g e n e ra l. 13:19 14:16 een' o 0 .6 3 114 ; CM CO n fM rt m 5.53 0.03 ; I 0 .0 1 1 lO O o Q E x l t cm cm i -cn c/3 o os ' <a r ZA <o /x ' Hn i.N i ra . iJ rH ' h3 3 g-3 * *J . oX On < I INVOICE . .. GEORGE D. CLAYTON & ASSOCIATES, INC. - ENVIRONMENTAL HEALTH CONSULTANTS - 2S711 SOUTHFIELD RQAO SOUTHFIELO, MICHIGAN A3075 * . TjL.: 313/352-3120 ,#0X SOLD TO ' . ' ` Rockwell-Standard Company Clifford at Eagley Detroit, Michigan 4B231 Attention: Mr. J. H. Florip N". .1249 customer's order no. None TERMS: Net 30 days pate Oct. 30, 1970 fon PBoFcsnoMiu scnviccs in connection with the report dated October 20, 1970, of an industrial hygiene survey conducted at the Ashtabula, Ohio Brake Plant on September 15, 1970. AMOUNT Field work J. Mutchler September 15, 1970 One man-day at $200.00 per day 0 $ * $200.00 Travel and subsistence '` Evaluation and report writing One man-day at $200.00 per day 9 * . *t *0 20.52 200.00 Laboratory analyses 12 Determinations for total weight at $5.00 12 Asbestos fiber counts at $25.00 1 Determination for iron at $7.50 5 Determinations 'for oil mist at $5.00 . , . 60.00 . . 300.00 . .' . 7.50 . . . '25.00 392.50 $813.02 f * i| RD 00585 D--:a .t December 7, 1970 TO .. Add-css .. F. J. Griffiths Ashtabula Subject .. ENVIRONMENTAL STUDY No. FPOM . Address . J. H. Florip Detroit Phnnc . Ext. 581 Enclosed are two copies of the study con ducted September 15. X must apologize for holding them and. the invoice since November 9, but I was hoping to deliver them myself. . In general, we have no problems with asbestos, which was my major concern. We do have ex cessive levels of nuisance dust in the brake shoe grinding areas. A check of the ventilation system and house keeping in these areas should be all that is required. If you have any questions, please contact me at once. JHF/jl Enclosure .s'Z H. Florip HOLDMASTER MECHANICAL BRAKES RD 00888 ROCKWELL AUTOMOTIVE DUPLEX Rockwell International's tradition of excellence in heavy-duty vehicle components is carried on by the Holdmaster Duplex Cam Mechanical Auxiliary (DCM) Brake and Duplex Lever Mechanical (DLM) Brake. Rockwell Duplex brakes have been on the road for more than 20 years, and off the road too. in the construction, logging and mining industries these brakes have performed with such consistent quality that they have remained virtually unchanged in design for many years. Designed and Tested by one of the World's Largest Independent Manufacturers of Truck Components... Rockwell International has been in the business of developing and manufacturing brakes since 1913 when it introduced the first internal expansion brake for commercial vehicles. The Rockwell International research, test and development center, the most modern independent facility of its kind in the world, assures the production of quality heavy- duty vehicle components to meet the industry's most exacting requirements. At this facility, Holdmaster Mechanical Brakes and other heavy vehicle brake, axle and driveline products are developed, tested and evaluated in a continuing program designed to provide the transportation industry both on and off-highway - with reliable components for trucks, tractors, trailers, buses and special-purpose heavy-duty vehicles of all kinds. Both models are designed for use on a broad spectrum of applications: Front End Loaders Graders Medium Trucks Off-Highway Haulers Road Rollers Rough Terrain Cranes Various Stationary Machinery The Holdmaster series offers simplicity and reliability. Consisting of only eight different parts, Rockwell DCM Brakes and DLM Brakes eliminate the need for a large parts inventory. The brakes are easy to install in just minutes, and require no special tools. I RD 00889 HOLDMASTER DLM LEVER MECHANICAL PARKING BRAKE NO ADJUSTING With the DLM brake there is no tricky assembly. Simply remove the two springs and lift out the shoes. The brake reassembles in minutes, and no adjustments need be made. The DLM brake has fewer parts to wear and to stock. Less inventory and less maintenance, plus long service life, combine to give reliable braking at low cost. SIMPLICITY Only eight simple parts make up a DLM brake. Shoes and springs are completely interchangeable. For instance, brake shoes can be "slapped' in". The position of the shoes makes no difference. Makes stocking simple too. Only six different types of parts are required to completely replace the brake. NO LUBRICATION REQUIRED Maintenance has been reduced to the absolute minimum. No skilled help is needed because the DLM is "foolproof" to service and install. No inside adjustment and no lube are necessary. BALANCED DESIGN The balanced design provides for equal torque in both directions. Balanced pressure makes both shoes do the same amount of work, so brake linings have uniform wear patterns for consistent, smooth performance. RD 00890 DLM SPECIFICATIONS . --1 . .... ~H , >_ . Brake drum area Brake lining area Jfg*' ^ =-'=r :=?>' ' '! T' 34 sq. in. ! 47 sq. in. i 20 sq. in. 1 31 sq. In. 84 sq. in. 55 sq. in. Brake lining thickness 3/16'' ` 1/4" 1/4" Brake weight (approximate) 7 1b. 13 oz. 18 1b. 14 oz. 36 lb. 2 oz. Overall diameter (backing plate) 8-3/32" 11-3/64" 14-35/64" Outside diameter (brake drum) 7-41/64" 10-15/32" inside mounting clearance (backing plate) 4-1/2" Maximum flange clearance (brake drum) 5-3/8" Brake center line to mounting surface i Brake mounting to drum mounting j ` 1-1/64" 1-53/64" 6-1/8" 8" r 2-5/32" Lever stroke Max. lever input ' 1-3/16" t 1-3/8" i' 700 lbs. 1200 lbs. 13-55/64" 8-1/2" 8-1/2" 1-9/32" 2-1/2" 1-15/64" 1700 lbs. Max. torque output 0 Including drum When lining is completely worn j 10,000 lb. ins. 25,000 lb. ins. ! 36,000 ib. ins. RD 00891 HOLDMASTER PCM CAM MECHANICAL BRAKE Rockwell's Holdmaster DCM Auxiliary Brakes have been on the job since 1959, offering efficient and reliable parking and emergency braking. As a parking brake, the Holdmaster provides equal torque in either direction. For emergency stops, the balanced design of Holdmaster Brakes divides the input force between both shoes. Stops are more controlled compared to unbalanced designed brakes, providing protection against damage to vehicle chassis and drive components. The balanced design also extends lining life and reduces transmission bearing stress. Along with these advantages, the DCM auxiliary'brakes are easy to install, and with only eight different parts, they reduce inventory requirements substantially. Simple, external linkage adjustment means easier, faster maintenance when required. HEAVY-DUTY APPLICATIONS The DCM brake is designed for heavy-duty applications, but is of a lightweight, rugged construction, giving increased braking capacity per pound. The cam and lever construction minimizes input force losses. Brakes are applied when the lever moves in either direction. DCM brakes feature central mounting, reducing overhang and minimizing bending stress on the supporting member. DCM BRAKE SPECIFICATIONS . Brake Lining Area Brake Lining Thickness Brake Weight (approx.) 10" Drum Steel Stamping Drum Weight Composite (approx.) Brake Centerline To Mounting Surface Brake Lever Length (standard lever) GVW Ratings 69 sq. in. 3/16" 12 lbs. 14 lbs. -- .526 5-3/8" 27,500 lbs. !> 83 sq. in. Ill sq.'in. 138 sq. in. 1/4" 1/4" 1/4" 17 ibs. 19 ibs. 21-1/2 Ibs. ------ 25 Ibs. 30 lbs. 35 Ibs. .515 .515 .515 4-1/2" min. to 7-1/2" max. 28,000 Ibs. 37,000 Ibs. 46,000 Ibs. SP-S156 flQ/at) Rockwell International Automotive Operations 2135 West Maple Road Troy, Ml 48084 (313) 435-8396 Copyright Rockwell International, 1981 RD 00893 Utho U.S.A.