Document Ramn0k30MqnBeYbpY0EdD00aB

FILE NAME Paccar PAC DATE 2001 Jan 12 DOC PAC009 DOCUMENT DESCRIPTION Legal - Answers to Plaintiffs Interrogatories Henderson v ACandS Inc. Ex F EXHIBIT F STATE OF SOUTH CAROLINA _ ) } COUNTY OF GREENVILLE ) JAMES W. HENDERSON JR and wife BETTY LEE HENDERSON Plaintiffs VS. ACandS INC et al Defendants IN THE COURT OF COMMON PLEAS ) C.A. No. 23-2792 ) ) ) } ) ) ) ) ) _) ANSWERS TO PLAINTIFFS FIRST SET OF INTERROGATORIES Served upon you are the following written responses to Plaintiffs First Set of Interrogatories to Peterbilt Motors Company GENERAL OBJECTIONS 1 Defendant Peterbilt objects to responding to any Interrogatory that seeks information which constitutes confidential attorney communications or which falls within the scope of the attorney product doctrine 2 Defendant Peterbilt objects to responding to any request that solicits from it information more appropriately requested from another person or entity RESERVATION OF RIGHTS 1 Defendant Peterbilt reserves the right to alter or amend its responses for accuracy if other information becomes available to it at a subsequent time 2 In responding Defendant Peterbilt does not waive any objections which may be appropriate either to a use by the Plaintiffs of any response for any purpose or b the materiality of any of the responses as to any issue in the case 3 Defendant Peterbilt reserves all rights to objections which may otherwise be available to it and further states that no response should be deemed as an admission of relevancy materiality or admissibility into evidence of any particular response GENERAL RESPONSE The interrogatories propounded define the word product to include all asbestos or containing products mined milled manufactured or distributed by you which were intended for thermal insulation use or were cloth or spray products containing asbestos This defendant has never been involved in the manufacture or distribution of any product as defined for purposes of these interrogatories This defendant's business consists primarily of the manufacture in part and assemblage in part of heavy duty trucks For some trucks and for some periods of time clutch and brake component parts manufactured by others which on information and belief did contain asbestos were utilized in the production of some of these vehicles Neither of these component part items are intended for thermal insulation use Despite the fact that these interrogatories do not address such items as products this defendant has answered the same providing information regarding the component parts utilized in the assemblage of vehicles based on the information available to this defendant SECTION A 1 Identify the registered name of the answering defendant as well as all prior names or predecessor entities by which the defendant has existed a For each give the current address and the state of incorporation and whether or not it is an active corporation ANSWER _ Peterbilt Motors Company 1700 Woodbrook Street Denton Texas 76205-7864 Peterbilt is an unincorporated division of PACCAR Inc. 777 106th Ave. N.E. Bellevue Washington 98004 PACCAR is an active Delaware corporation 2 Set forth the full and correct name the principal place of business and the state and date of incorporation of the answering defendant ANSWER The correct name of this defendant is Peterbilt Motors Company an unincorporated division of PACCAR Inc. See response to Interrogatory No. 1 above 3. defendant Identify all divisions subsidiaries or affiliated companies to the answering ANSWER None 4 For each entity or division listed in response to # 3 state whether or not it ever has or presently engages in any phase of mining manufacturing sale supply distribution or design of asbestos or containing products ANSWER Not applicable 5 With respect to each division subsidiary or company listed in # 4 identify the nature and extent of its function during the period of time it was in existence ANSWER Not applicable 6 Has this answering defendant been sued under its correct name If not please state the correct legal name of the defendant and provide the information requested in Interrogatory # 1 above concerning the defendant as correctly named ANSWER See response to No. 2 above 7 Please state whether or not you have ever held a certificate of authority to do business in this state and the address for your registered agent for service of this state ANSWER No. None PRODUCT IDENTIFICATION 8 ANSWER Have you ever mined asbestos No. 9 If the answer to the previous Interrogatory is yes please state the dates in which you were involved in mining asbestos and the locations of your mines ANSWER Not applicable 10 Have you ever sold raw asbestos fiber to any of the defendants in what years and in what quantities did you make such sales If so ANSWER No. 11 As to any product containing asbestos in any form or quantity has this defendant ever a designed such a product b manufactured such a product c processed such a product 3 d sold such a product e distributed such a product f relabeled such a product manufactured or designed by another g held a patent for such a product ANSWER _ This defendant objects to this interrogatory on the basis that the unlimited time frame is overly broad Without waiving said objection this defendant would respond a No. b No. c No. d Only as part of a truck e Only as part of a truck f No. g No. 12 If the answer to the previous Interrogatory or any sub part thereof was in the affirmative please state the following information about each product a the manufacturer of the product b the designer of the product c the supplier of the raw asbestos fiber used in the product d the dates of its manufacture or sale by the answering defendant e the percentage of asbestos content of the product f the type of asbestos used in the manufacture of the product ANSWER With respect to clutches a Rollaway now known as Midland Brake Company a Rockwell International Corporation a Valeo Clutches a Rockford Power Train Inc. a Dana Corporation - Spicer Clutch Division b Unknown c Unknown d Unknown when first used Discontinued in late 1980's e Unknown f Unknown With respect to brake assemblies including friction material a Eaton Corporation a Rockwell International Corporation a Timken Axle Company b Unknown c Unknown d Unknown when first used Discontinued in 1987 e Unknown f Unknown 13. In what year did the answering defendant first begin selling or distributing containing products Please be specific for each containing product manufactured sold or distributed by you ANSWER See General Response This defendant does not know when clutch or brake parts that might have contained asbestos were first utilized in the assemblage of vehicles by this defendant 14. In what year did the answering defendant last manufacture an containing product Please be specific containing product sell distribute or for each asbestos- ANSWER See General Response and response to Interrogatory No. 12 above 15 you state For each containing product manufactured and distributed by a the brand name of the product and the inclusive years of its manufacture and distribution b the asbestos content by weight of each product for each year c the type of asbestos fiber used in each product d the application for which such product was advertised or sold e the temperature ranges for the products used f whether the product was a cement a pipe covering a cloth or other type of thermal insulation product ANSWER See General Response This defendant objects to this interrogatory on the grounds that it is overly broad as applied to this defendant Without waiving said objection this defendant would respond that it did not manufacture or distribute individual containing products Transmission clutches and brake linings included as components of a truck assembly may have contained asbestos As to clutches actual years of distribution of containing products manufactured by the following companies are unknown a Rollaway now known as Midland Brake Company a Rockwell International Company a Valeo Clutches a Rockford Power Train Inc. a Dana Corporation - Spicer Clutch Division b Unknown c Unknown d Heavy duty trucks e Unknown f No As to brake assemblies including friction material actual years of distribution of containing products manufactured by the following companies are unknown a Eaton Corporation a Rockwell International Corporation a Timken Axle Company b Unknown c Unknown d Heavy duty trucks e Unknown f No 16 | Describe each product as to its color and physical characteristic and appearances ANSWER Unknown 17 As to each product state how such product was packaged or supplied ANSWER The products listed in response to Interrogatory No. 15 may have been installed as a component part of a heavy duty truck during the assembly process 18 Does the answering defendant claim that any patent would cover any product listed in response to the interrogatories above If so give the number of the patent the date same was issued and the number of each patent application that is pending ANSWER products Neither Peterbilt nor PACCAR has any patents covering any of the listed 19 For each containing product manufactured or designed by you please state the specific batching requirements for that product ANSWER _ Peterbilt did not manufacture or design any containing products 20 State the time period each particular batching requirement was followed and any changes that were made ANSWER _ Not applicable 21 For each containing product that you manufactured please set forth the supplier of the raw asbestos fiber used for that product ANSWER Peterbilt did not manufacture any containing products 22 As to each product mentioned above identify the following a any pertinent trademark that was applicable to the product during any time of its sale b the label on the packaging of that particular product for each year of its manufacture c all sales brochures specification sheets performance data or other promotional material as well as any and all installation materials data or brochures which would have accompanied or been distributed in connection with the installation application or use of each of the products listed above d The advertised use of the product as to this Interrogatory you may provide a copy of the document in lieu of describing the same ANSWER Not applicable 23 For each document listed or described above please indicate the name or the names of the individuals having custody of said documents or copies thereof and where they are located ANSWER _ Not applicable 24. Please describe in detail the method for disbursement and sale of each containing product manufactured designed or distributed by the answering defendant ANSWER Any containing product that may have been distributed by this defendant would have been a component part of a vehicle assembly sold to a dealer representative 25. Have any of the products listed in the answer to Interrogatories Nos 12 13 and 16 above been altered in chemical composition or asbestos type or content since their first being marketed ANSWER _ Not by this defendant 26 If so please state a the trade name of each such product b the date such product was altered c the nature of that alteration d the reason for the alteration e what person has knowledge concerning the alterations ANSWER Not applicable 27 Identify all sales literature including brochures advertisements pamphlets or other material describing each containing product manufactured by you beginning in 1925 and coming forward to date ANSWER See General Response containing products Peterbilt did not manufacture any asbestos- 28. Prior to 1960 did you conduct any tests concerning the health consequences of the use of your containing product ANSWER See General Response No. 29. Prior to 1960 did you conduct any tests concerning the consequences related to the manufacture of your containing product health ANSWER See General Response containing products Peterbilt did not manufacture any asbestos- 30. Do any written memoranda specifications recommendations or other written materials of any kind or character related to the testing of said products exist ANSWER Peterbilt did not manufacture any containing products Furthermore Peterbilt is not aware of any written materials directly related to the testing of said products Vehicle brake system testing was conducted by PACCAR to establish overall system performance 31 If so please state a identify each such written material or document b who presently has possession of each such document and where is it located ANSWER _ Not applicable 32 Have you conducted any tests concerning the health consequences of the use of your product between 1960 and 1975 or the date that the asbestos content was removed from the product whichever is the later ANSWER _ See General Response No. 33 so please state a what tests were done b who was responsible for conducting the tests c what the results of the tests were d identify any documents concerning the tests ANSWER _ Not applicable 34 When did the containing products manufactured by you first contain any warning or caution concerning the health consequences of the use of the product or the breathing of asbestos dust ANSWER See General Response containing products Peterbilt did not manufacture any asbestos- 35 For each such product please state - 030 the wording of each warning or caution 030 the description of each such printed warning or caution 030 the method used to distribute the warning to persons who were likely to use the products 00 the date each such warning was issued 00 the name address and job classification of each person who presently has possession of the described warning or caution f identify the warning or caution by date and content g state whether any industrial psychologist or human factors engineers were consulted prior to utilizing such warnings or cautions h identify any special instructions provided with each product regarding its use or safety procedures to be employed by persons handling such product ANSWER _ Not applicable 36 For any warning ever provided on an containing product manufactured or distributed by you please state a when the warning first appeared b what was the precise wording of the warning when it first appeared c was the warning ever altered amended or changed in any manner and if so how and when d | where was the warning located on the product or packaging ANSWER _ Peterbilt manufactures in part and assembles in part the vehicles that it sells Peterbilt did not place any warnings on its vehicles pertaining to the possibility of containing products Peterbilt is not aware of any warnings that might have been placed on any of the component parts that were used in the assembly of its vehicles 37. When did you first become aware that warnings were placed or products distributed by other defendants ANSWER Unknown Peterbilt is generally unfamiliar with the business activities of most of the other defendants Peterbilt is not aware of any other truck manufacturer or assembler providing any such warnings 38. State the manner in which each of your products was shipped and the type of container it was shipped in to the retailers ANSWER Peterbilt vehicles are shipped via a contract carrier There is no container used during this process ~ 39. | When if ever did you specifically inform the purchaser or user of your products that contained asbestos that the use of that product or exposure to asbestos dust could cause cancer asbestosis or other serious diseases Please identify the document containing this information by date and location ANSWER _ The only reference discovered thus far is in a Peterbilt maintenance manual dated 4/87 copy attached 40. Identify any and all labeling or relabeling agreements in existence since 1925 between you and any other person including defendants ANSWER _ This defendant is not aware of any such agreement 41 Did you sell any of your products containing asbestos fibers or any raw fiber to any of the companies named as defendants in this suit ANSWER _ The only possible sale Peterbilt may have had with any of the other defendants would be the sale of a Peterbilt vehicle to such defendant 42 If so please state a the name address and job classification of each individual who currently has possession of such knowledge either by documents or records b please list the names of products have been sold c please state the dates of kind of materials sold ANSWER _ Not applicable 10 43 State whether your company manufactured containing insulation products for a defendant and placed the defendants labels logos or insignia on said products and list each such defendant ANSWER No. 44. Has this defendant ever acquired another corporation company or business which manufactured sold processed distributed or contracted to apply insulation products containing asbestos ANSWER _ No. 45 If the answer to the above Interrogatory is yes please state the following concerning such other entity a the full and correct name - b the principal place of business c the state of incorporation d the date of its acquisition by you e the products that the other entity manufactured distributed sold or used ANSWER _ Not Applicable 46. Did you ever stamp or imprint the name of your company its initials or any identifying logo on any of your containing products If so please describe the identifying logo or initials and the dates of its inclusion on the product and the product on which it was included ANSWER Not on Peterbilt logos individual components The final vehicles did have various 47 As of the date of your answers to these Interrogatories is your company still manufacturing selling or distributing any containing products If so give the brand names of each such product ANSWER Not to our knowledge 48 For each product identified as being manufactured sold or distributed by you in interrogatories No. 12 13 or 16 state whether or not a you have actual containers or photographs of containers in which said products were sold or distributed b who is the custodian or keeper of said containers or photographs including their address and telephone number ANSWER No containers are utilized in the distribution of vehicle assemblies 49 From what source or sources did you obtain raw asbestos fiber beginning in 1940 and going to date on a yearly basis ANSWER _ This defendant did not obtain raw asbestos fiber 50. State whether or not any warnings cautions caveats or directions accompanied the raw asbestos fiber referred to in the previous Interrogatory and identify the nature and extent of said warnings cautions ANSWER _ Not applicable 51 State what date said warnings cautions caveats or directions first appeared on the mined asbestos fiber ANSWER Not applicable 52 If you have discontinued manufacturing and selling asbestos products please state the reason or reasons therefor ANSWER The power clutch material was changed to a asbestos ceramic material sometime in the 1978-1984 time period due to environmental reasons and the need for higher torque capacity Brake lining material was changed in 1987 for environmental reasons Exact dates are difficult to determine as some of these materials were phased out as they became no longer available from our suppliers NOTICE 53 When was the first time that you received notice that any person was claiming an injury as the result of using containing products and sold by your company ANSWER _ This defendant has no such records The PACCAR Risk Management Department records show the first claim was filed in August 1989 54 For each such injury that you received notice of or a claim for prior to 1970 please list a the name and address of each claimant b the date of the notice of each claim c a description of the claim i.e. workmen's compensation or a third party liability action d __ the type of injury allegedly sustained e the name and address of each attorney who represents individuals making such claims the style and the court number of each claim g the resolution of each claim that has been disposed of h the custodian of the records that relate to the claim In lieu of answering the above questions you may attach copies of any and all claims ANSWER _ Not applicable 55. Do you contend that insulation products containing asbestos can be manufactured or treated so as to eliminate all potential health hazards to workers installing the same If so please explain in detail what your contentions are and the basis for each contention ANSWER Not applicable containing asbestos This defendant did not manufacture insulation products 56. Did you receive any reports or communications from your workmen's compensation insurance carrier or products liability insurance carrier with regards to the hazards incident to the use of containing insulation products If so please state who has possession of the contents of such reports the location of such reports and the substance of the contents of such reports listing for each such report the respective insurance company its address the agents signing such correspondence and the date of such notice or report ANSWER products Not applicable This defendant did not use containing insulation 57 Have any of the defendants named in this litigation ever furnished you with any information as to the state of the medical knowledge regarding the connection between asbestos dust exposure and the contracting of pulmonary diseases including asbestosis and cancer ANSWER _ This defendant has no record of information responsive to this request 58 identify If the answer to the preceding Interrogatory is in the affirmative please a what information you were furnished b who furnished that information c when that information was furnished ANSWER _ Not applicable 59 Have you at any time since 1930 interchanged results of research tests medical studies or experiments regarding the state of the medical knowledge regarding the connection between asbestos exposure and the contracting of pulmonary diseases including lung cancer and asbestosis with any other person including any defendants in this action ANSWER This defendant responds that to the best of its knowledge it has not engaged in any such activity state 60. If the answer to the preceding Interrogatory is in the affirmative please a when this interchange took place b who participated in these interchanges c summarize the content of these interchanges or studies ANSWER _ Not applicable 61 Please state if you or anyone on your behalf ever conducted sponsored or contributed financially to any studies or research to determine if inhalation of asbestos fibers may be harmful ANSWER This defendant responds that to the best of its knowledge it has not engaged in any such activity 62 the answer to the above question is in the affirmative please state a by whom the research was conducted giving complete names and addresses b the dates that each such research project or test was conducted c the complete results of each test or study d identify all documents that refer reflect or relate to the test or study e supply copies of the reports of the research department pertaining to the use by the corporation of asbestos in their manufacture of insulation products ANSWER Not applicable 63. Please state the names and addresses of your chief medical officers from 1930 until the present time listing the periods of time each such medical officer was employed by defendant in that capacity If you did not have a medical officer please indicate what persons or persons performed that function ANSWER _ This defendant did not employ anyone in this capacity PACCAR has employed a Corporate Medical Director since approximately 1984. The following people have served in this capacity Dr. Francis VonFeldt present Dr. J.M. Hughes 1984 64. Please state the names and addresses of all physicians who were employed retained or otherwise engaged by you at any of your facilities from the years 1930 until the present ANSWER None 65 Please state the names and addresses of all persons employed by you from 1930 until the present time who functioned as industrial hygienists As used in this Interrogatory an industrial hygienist is one who performs engineering or health studies to identify and evaluate potential health hazards and suggests methods of dealing with the same ANSWER None as defined 66 For each industrial hygienist listed above please state a the facility or office to which that individual was assisted b the complete and precise duties and responsibilities ANSWER _ Not applicable 67. Did anyone ever make any recommendations and suggestions to you pertaining to the risks and hazards associated with the manufacturing or use of insulation products containing asbestos ANSWER _ This defendant responds that to the best of its knowledge it has not received any such recommendations and suggestions 68 the answer to the above question is yes please state a where such recommendations or suggestions were made b | who made such recommendations or suggestions c to whom were these recommendations or suggestions made d the substance of the recommendations or suggestions e what actions did you take as the result of those recommendations and suggestions ANSWER _ Not applicable 69 exposure and Do you agree that there is a causal connection between the asbestos dust a asbestosis b lung cancer c mesothelioma d other cancers 15 ANSWER _ This defendant objects to this interrogatory on the grounds that it is overly broad as applied to this defendant and is more properly the subject of competent expert testimony Without waiving its objection this defendant would state that because of the nature of its business and the lack of any significant utilization of asbestos in the course of this business this defendant's general understanding of asbestos exposure and the consequences of such exposure were acquired through general media coverage of these topics and information learned in connection with claims brought against this defendant starting in the 1989 time period Based on such information this defendant denies that mere exposure to asbestos fibers is a cause of the diseases set forth in d above This defendant admits that according to medical and scientific literature inhalation and retention of asbestos fibers of certain types and sizes in certain quantities over an extended period of time after an appropriate latency period may result in the disease asbestosis in certain populations that exhibit such increased rate of asbestosis This defendant admits that there are certain medical and scientific studies that indicate that some populations that have excessive exposure inhalation and retention of certain asbestos fibers of certain sizes and types for a prolonged period of time and after an appropriate latency period can contract the disease mesothelioma Additionally there are medical and scientific articles that indicate that some populations with excessive exposure inhalation and retention of certain asbestos fibers for prolonged periods of time and after an appropriate latency period have an increased incidence of the disease lung cancer however the medical and scientific literature indicates that such incidences of lung cancer are predominately associated with the inhalation of cigarette smoke or other substances or factors This defendant further states that there are conflicting medical opinions regarding the incidence and relationship of other cancers and excessive asbestos inhalation and retention Given the indefiniteness of the term other cancers this defendant cannot answer further 70. If your answer to the previous Interrogatory is yes as to any or all subparts please identify the following as to each disease process listed above a when and how you first learned of such connection b if the knowledge was obtained by the attendance of any conference lecture convention symposium or meeting identify such event and provide the name of the person attending or the documents obtained from that meeting c if knowledge was obtained from a medical or scientific study or any other published works identify the same d if the knowledge was otherwise obtained identify the manner of receipt of the document or communication ANSWER _ See answer to Interrogatory No. 69 above 71 With regard to any knowledge obtained subsequent to that described in the previous Interrogatory please identify a all documents or other communications oral or written concerning the causal connection between exposure to asbestos dust or asbestos products and the disease processes identified in question No. 60 above b identify the person communicating the information ANSWER This defendant is not documents or persons Such materials any claim file are privileged aware of the existence of any such specific bearing on this subject as might be contained in 72 When and by what manner were you first aware of the hazards of asbestos or containing products to the users of those products ANSWER _ This defendant objects to this interrogatory on the grounds that it is overly broad and unduly burdensome as applied to this defendant Without waiving such objections this defendant believes its first real awareness of the potential hazards of asbestos or containing products came in the 1980's near the time of the first filing of a claim against this defendant in 1989. Prior to this time this defendant was generally aware of the regulations contained in OSHA dealing with asbestos and hazards attendant upon the use of asbestos 73 Identify any medical examination programs offered or sponsored by or your insurance carrier for employees handling or otherwise exposed to asbestos asbestos products With respect to each such program please state you and a the manner of communicating with employees about such program 30 | whether examination was mandatory or optional 30 what percentage of workers permitted to undergo such examination actually participated d | what percentage of workers were found to have asbestosis or mesothelioma or bronchogonic carcinoma e with respect to d what percentage of such workers were paid disability workmen's compensation benefits or for whose benefit medical expenses were paid to undergo treatment for such conditions ANSWER _ Not applicable 74 Identify all trade organizations associations or other entities including but not limited to All IF NAIMA AIA NICA TIMA QAMA PICA QAPA to which you belonged or in which you have participated since 1925 and the years of your participation ANSWER _ This defendant is generally unfamiliar with any organizations which might be designated by the acronyms used in this interrogatory PACCAR has been a member of the following related trade associations at some point over the past 25 years Washington Trucking Association Washington Highway Users Association California Trucking Association Texas Trucking Association Tennessee Truck Association Ohio Trucking Association American Highway Users Federation Truck Manufacturers Association Truck Rental and Lease Association and American Trucking Association Information on memberships prior to this time period is not available 75. Identify all persons attending on your behalf any meetings held by any trade organization listed in the Interrogatory stated above ANSWER _ The Director of Public Affairs has primary responsibility for representing PACCAR at any meetings held 76. Identify the names or nature of all asbestos notes reports studies or other writings submitted by you or received by you at meeting identified in the Interrogatory stated above ANSWER _ This defendant responds that to the best of its knowledge none 77. Identify all documents you received from or submitted to those trade organizations associations or other entities identified in Interrogatory 65 relating to the relationship between asbestos exposure and disease ANSWER _ This defendant responds that to the best of its knowledge none 78. Did you direct to be performed sponsor finance or receive the results of any studies or tests performed by the Saranac Lake Laboratory or the Trudeau Foundation relating to asbestos exposure and its effect on human life If so identify a all documents summarizing findings or results of those studies or tests which you have in your possession or control b all communications oral or written between answering defendant and Saranac personnel including but not limited to Gerrit W. H. Schepers M.D c all documents relating to Saranac studies received or submitted by you either directly through associated or predecessor companies through other companies or through any trade associations organizations or entities d all recommendations or findings of such studies in relating to 1 adequacy or inadequacy of the threshold limit values 2 the substitution of materials other than asbestos to be used in insulation process 18 e where the documents and communications identified in this Interrogatory are presently maintained ANSWER This defendant responds that to the best of its knowledge no 79. Identify all persons who have testified on your behalf and all documents presented to or utilized in preparation of testimony before the Occupational Safety and Health Administration the National Institute of Occupational Safety and Health any U.S. Congressional committee or committee or governmental hearing or investigative proceeding on the subjects of biological effects on human life from exposure to asbestos and the setting modification feasibility and acceptance of allegedly safe or proper levels of such exposure to asbestos and asbestos products ANSWER _ This defendant responds that to the best of its knowledge no one 80 For all testimony set forth above please identify a the dates and descriptions of the proceedings b the relationship between the person who testified or responded and you c all studies test results or other scientific or medical documents relied upon by said person as a basis for any recommendations made or testimony given d whether at any time prior to or following such testimony you possessed knowledge of documents suggesting that existing or proposed threshold limit values were not safe or proper or that lower threshold limit values were necessary in order to prevent disease as to this response please identify the origin of the knowledge and all documents relating thereto e whether at any time prior to or following such testimony you were aware that the proper method for determination of safe levels f asbestos dust was to test concentrations of fibers in the air rather than the total number of particles If your answer is in the affirmative identify the origin of said knowledge and all documents relating thereto ANSWER _ Not applicable 81 What do you understand threshold limit value to mean ANSWER _ This defendant understands this term to be a term of art utilized by the industrial hygiene community This defendant has no industrial hygienists in its employ and therefore is unable to answer further 82. | What do you understand dose response relationship to mean 19 ANSWER | This defendant understands this term to be a term of art utilized by the industrial hygiene community This defendant has no industrial hygienists in its employ and therefore is unable to answer further 83 What is being measured when you take the measurement of threshold limit value as you define it ANSWER See response to Interrogatory No. 81 above 84 Did you advertise any of your containing products for use on ships or navy vessels ANSWER No. 85 the response to Interrogatory No. 84 was yes please state a the name of the product - b in what years you advertised the product c the intended purpose of the product ANSWER Not applicable 86 please state Did you design any containing products for use on vessels so a the name of the products b the year of their design c the manufacturer d the intended use ANSWER No. 87 Did you sell any containing materials to the a United States government b General Services Agency c United States Navy d any naval shipyard e any shipyard ANSWER Any material sold to the listed entities would have been as a component of a heavy truck 88. Do you ever conduct any dust studies in any of your asbestos product manufacturing facilities If so please state ANSWER a the date of each such study b the person conducting the study c the result or conclusion d who presently has possession of the report or study This defendant did not manufacture any asbestos products Date James Bundy | James B. Pressly Jr. Bar 4555 Wm David Conner Bar 66358 HAYNSWORTH HAYNSWORTH SINKLER BOYD P.A. Post Office Box 2048 Greenville SC 29602 864 240-3200 Attorneys for Defendant Peterbilt Motors Company 21 CERTIFICATE OF SERVICE This is to certify that the foregoing Peterbilt Motors Company's Answers to Plaintiffs First Set of Interrogatories was served by depositing a copy of said document in the United States Mail postage prepaid on this the 12 day of January 2001 addressed as follows Richard J. Lutzel WALLACE & GRAHAM P.A. 525 N. Main Street Salisbury NC 28144 PERSONALLY appeared before me Kirk A. Hoover who being duly sworn deposes and says that he is the Technical Advisor of PACCAR Inc. and as such is authorized to make this statement that he has read Answers of Peterbilt Motors Company to Plaintiffs First Set of Interrogatories and that on information and belief as to the content thereof is informed and believes them to be true PETERBILT MOTORS COMPANY an unincorporated division of PACCAR Inc. --"---- ---- --"---- ------"---- ---- Kirk A. Hoover Technical Advisor of PACCAR Inc. SWORN to before me this 11th day of January January 2001 MD. ELLA DELLA DELLA LINDA LINDA . LINDA LINDA RO8 EXPIRES EXPIRESRO8 EXPIRES LINDA NOTARY 1Fs Notary PublicforState of Washington Washington Washington Linda M. Della Rossa Rossa PUBLIC STATE WASHINGTON STATSTEATE 17 WASHINGTON WASHINGTON WASHINGTON 23 wow 37 we isi awry F. 02/02 02/02 FOUNDATION BRAKES Cam Brakes , ad Servicing Precautions Cam brakes use a rotating shaped cam to spread the brake shoes When the brakes are applied air pressure is sent to the brake chamber The brake 1. Always cage spring brakes before performing any chamber contains a piston and diaphragm which converts the air pressure to linear force The brake adjustment or repair 2. Always exhaust pressure from air lines before disconnecting air lines chamber pushes the slack adjuster The slack adjuster acts as a lever to rotate the cam and spread the brake shoes into the brake drum The slack adjuster contains a worm gear mechanism which allows the brake to be 3. Always replace brake components linings shoes etc. with components meeting the original spec- ifications : 4. Many brake linings contain asbestos fibers Use caution when handling or maintaining refer to adjusted to compensate for lining wear cam brake size is specified as the brake diameter and shoe width For example a 16.5 x 7 brake has a diameter of 16.5 internal diameter of the brake drum and a shoe width of 7 OSHA 29CFR part 1910.1001 5. After any brake maintenance or repair test to ensure brakes are functioning properly before placing vehicle back in service 6. Always block vehicle wheels before performing any maintenance 7. Never attempt to disassemble any component until you have read and understand the recommended procedures Some components contain powerful springs Always use proper tools 8. Never exceed recommended air pressure Always wear safety glasses when working with pressur- ized air Foundation Brake Types Foundation brakes are the components which actually accomplish the braking This includes brake shoes linings actuating mechanisms and brake spider or backing plate There are three types of foundation brakes available on Peterbilt vehicles Cam Wedge and Disc All types use air pressure to apply brakes BRAKES 8-1