Document NGJREqYXrqY0LQ3JObEYpwKrR

AFFIDAVIT I, George Earl Parker, residing at 3006 Jonte Street, Pascagoula, Mississippi , do swear and aftirni; i. I was employed by Johns-Manvi1 Is Corporation City in I960 as an attorney and continued employment legal and business capacities in New York City Col or ado unt i .1 i 937. in Mew York in various and Denver, 2. Attached to this affidavit is a copy of a letter from S. A, Williams, Vice President, Johns-Manvilie Corporation to Mr, ft. R, Fisher, Manager, Manvilie Factory, dated August 29, 1933 and three pages of questions and answers referred to in the letter f a r a t o t a 1 o f f ou r p a g e s. 3. I first encountered this letter and enclosures in 1968 at Johns-Manvi11e Corporation headquarters at 22 East 40th Street, Mew York, Mew York, among various papers, medical journal articles, newspaper articles and correspondence from the files of the Industrial Relations Department of Johns-Manvilie Corporation made available to me for review by Hugh Jackson and Boyd Moulder of the I ndust.r i a 1 Re 1 at i. ons Depart. ment of John s-Manv 11 1 e Corporation, 4. Subsequently, about June 1993, I encountered this document in files of Johns-Manvi11e Corporation in the custody of Manvilie Personal Injury Trust in Denver, Colorado. Sworn to.this STATE OF COLORADO ) ) COUNTY OF BOULDER ) eg eg. Subscribed and sworn to before me this 1993, by George Earl Parker, W i t n e s s my h a n d a n d o f f i c i a 1 s e a ,1 . dav of Gimnl Headquarters, August 29, 1933. Personal & Confidential Mr. A. R. Fisher, Manager, Manville Factory QUESTIONS ASKED cr. a. J. LANZA AMP HIS AWSWSS.VPBAIW Attached is ccpy nade by Mr. Kottcarp's office of questions asked Dr. A. J. Lanza by our local physician at Waukegan and his answers; the recarcnendations by our plant physician. I would like to have you turn this ever to saneone who could review this correspondence and then 30 over it yourself and write ne your opinion of it. . cc - Mr. J. P. Rottcaap Waukegan Factory S. A. WILLIAMS, Vice President PLAINTIFF'S EXHIBIT cI QUESTIONS ASKED CR. A. J. LANZA AND HIS ANSWERS VERBA1CM Qnsticn No.l. Amcng iltvm employees in the Textile depar&ant, all exposed to asbestos dust, era only wears a respirator, several an being questioned - clam they cannot wear then continuously especially in hot weather. Should all employees be forced to wear these respirators whether subjected to such or little asbestos dust? Is any such difficulty experienced at the Manville N.J. J-M plant or other places of wtui you have jQ-evlajga? Answer: Respirators are not satisfactory. It is possible to construct a respirator which will filter out fine dust, but it would offer so much re sistance to respiratien that it could not be worn continuously on an eight hour shift. There are cn the sarkst ssall face mask respirators which axe equipped with positive pressure and these are both satisfactory, efficient, nd comfortable but they cannot be worn except by a person who stands in cne s place as they have to be hooked up with a rubber tube to an air line. I V. doubt if they would be practical in a textile plant. Questions No.2. * . . Do you agree with ay recamendaticn that csplcyees definitely be made aware of the fact that asbestos dust is hazardous to thsir health? My idea is that a poster be placed at cne or sore conspicuous places in the de- parenent, signed by the physician, stating that the dust is injuriaa, ad vising the .... ... use of respirators while at work and claansing of hands before eating lunch and after worx. Your cn this please and particularly is thsre any addi tional advice that should bs given? Answer: This is partially arawered by No.l. I doubt if the hazard is sufficient to justify warning pcstsrs as night be used where lead, benzol or carton ronoxida arelrarned. This is especially true in view of the extraordinary legal situation. If anything is said at all, it world be better to sake a general statement that the Qaspany istaking stspa to ggrtrol the amount of dust in the air for general health purposes. Any acticn contasjolated at Waukegan would probably be influenced by the experience at other lants of the Ozpany. c Oiescicn No. 3. 2- Co you regard the finding of asbestosis bodies in tbs sputum as pathogenesis of asbestcsis? I haw* cne etployaa with x-ray and physical findings pointing toward asbestosis but not sufficiently definite that Z can be positive as to whether or not she has asbestcsis. However, every one of four or five speci mens of sputisa examined show typical asbestcsis bodies. On the other hand, is it possible for a.person to have asbestcsis and not be able, with careful and thorough seartn to find asbestosis bodies in the spuosn? Answer: The presence of asbestos bodies in the sputaaa only irplies that the individual has been exposed to asbestos dust. I aa not certain of the exact pathological significance. My ispressicn is that the presence of a^hesrns bodies in the sputum indicate seme definite lung pathology. I be lieve it is quite possible for an individual to have asbestceis without asbestos bodies in the sputua. Question No.4. Are you of the opinion that the added information derived from stereoscopic films of the* chest justified the procedure of taking a stereo on every case that is to be x-rayed? This is the conclusion I drew froa Car. Pancost'a talk in Chicago. - -- - co you ccraider it advisable and practical that an x-ray film ' be taken of every plcy*e in the Waukegan J.M plant who is exposed to .. asbestos or silica chat? To date I have x-rayed cnly these cases suspected, ,'frcra history or physical findings, of having asbestosis of other lung pathology. Answer: Stereoscopic files are better than singla films. They are also more expensive. In our work at the Pi<*er Clinic, we used single films sizply cn account of the expense involved. Yoi can diagnese silicosis or any other form of pneumoconiosis from a single flat film. the cither hand, you can probably get a more caplets and accurate idee of the exact condition of any given case from a stereo. If it is the intention to determine whet may be the extent of pneurcemicsis asmg oployees, obviously the cnly thing to do is to x-ray all of them and than correlate your findings with the length of exposure and acure of the jds in order that you may get a fairly acogata idee of what the hazard is. . PLAINTIFF'S 1 EXHIBIT I t* ;v ". C Question No.5. ( -3- . X have mad* a diagnosis of asbestcsis en an cqslcyse who has bean working in th* card room of tha textile department six years. This place is extmaly dusty. He is not disabled. In my juipaant the bt disposi tion of such a case is to remove him firta the dust and give him a jcb in sene other part of the plant. Fttn your marks in Qiicago X believe this was your advise as to the disposition of such cases. Answer: ' _//' " - - - It is difficult to answer this question. X think it would depend upon the man's age. the nature of his work, his length of service, and cthar considerations which might have sods bearing. If he is veil along in years and shows no disability, it may be just as well to leave hin alone, one of the difficulties and vstions in trying to deal with tha problems of pneumoconiosis is that economic as wall as production factors must be balanced against the medical factors. Question No.6. We have what seems to be an unfortunate situation existing in the fact that the asbestos textile department including loans, twisters, pools, etc. occupies one side or about half tha width of a long building, Ctha other side of which is oocupiad by tha packing, brake lining and other departments in vhirtj there is very little diat. The card roan, or rest dusty part of tha textils department is isolated by partition. Further isolation of the textile department involves considerable expense. Should or would you be guided by the dust counts and other dbssrvaticns in these adjoining departments? Answer: - X think the amwer to the situation outlined in this question is the control of disc in those processes that cause it. V*an evarything possible has basn dens to eoonrpllsh this rswlt, it may than ba nacassary to isolate or ccnfins the dusty pxocassss so as to avoid nssdlass exposure of other ssploysas not in these processes. This is a situation that in many different types of industrial hazard. It calls for nothing mors than the application of lumen sense to the prctolsn.