Document Raywvo5JKbL9VNgbLqXyz2g3z

282 1 Sayers 2 particle or fiber size is most apt to reach the 3 deepest recesses of the lungs? 4 A. 1 have no idea. 5 Q. Do you know what a micron is? 6 A. Ten to the minus six millimeter, ten 7 minus six. 8 Q. Are you familiar at all with the term 9 "submicron"? 10 A. Yes, 1 am. 11 Q. What does the term ''submicron" mean to 12 you? 13 A. Nano. 14 Q. Can you tell me just generally, if you 15 have an understanding -- ifyou don't, tell me -16 of whether or not a submicron particle would be 17 more apt to reach the alveoli in the lung as 18 opposed to a particle greater than one micron? 19 A. 1 have no idea. We would have to put it 20 to the test. 21 Q. And have you ever -- did you or have you 22 ever read any articles that dealt with that 23 subject? 24 A. Not with that degree of specificity, no. 25 Q. Have you ever done any research into any 284 1 Sayers 2 Q. Let me ask it a different way. Do you 3 have an opinion, as you sit here today, based upon 4 your education, training and experience, whether or 5 not Calidria asbestos -- whether it's possible that 6 Calidria asbestos causes lung cancer and/or 7 asbestosis? 8 A. 1 have absolutely no idea. 9 Q. So in other words, you have no opinion 10 one way or another; is that correct? 11 A. 1 have nothing to base an opinion upon. 12 Q. You indicated earlier in some 13 testimony - and I'm sorry, I have some cursory 14 notes here -- but that the curved shape of -- and 1 15 think you were talking in terms of chrysotile 16 fiber? 17 A. Conventional chrysotile fiber, yes. 18 Q. Does not align with the air flow and 19 gets caught, 1 think you said, in the nasal 20 passages. 1 just want to clarify for my own 21 information that you weren't talking about Calidria 22 asbestos at the time; is that correct? 23 A. At the time, no, because I was lifting 24 that information from the document. 25 Q. Do you know what the mean fiber length 283 1 Sayers 2 type of silica-related disease issues? 3 A. Research, no. 4 Q. Have you gained any type of knowledge 5 whatsoever in the context of silica or silicosis? 6 A. Well, this was the forerunner of the 7 asbestos situation. The Pneumoconiosis Research 8 Unit was in fact created to investigate silicosis, 9 miner's disease, as it was so called. 10 Q. So is the answer to my question is yes, II that you gained some knowledge? 12 A. Yes, some knowledge, yes. 13 Q. Do you know when the medical community 14 first began to write about asbestos-related 15 diseases? 16 A. Not totally, no, 1 don't. 17 Q. Do you have an opinion, as you sit here 18 today, based on your entire work history, and 19 education, training and experience, as to whether 20 or not Calidria asbestos causes asbestosis? 21 A. I couldn't make that judgment. 22 Q. Do you know whether or not -- do you 23 have an opinion as to whether or not Calidria 24 asbestos causes lung cancer? 25 A. No, 1 still don't. 285 1 Sayers 2 was in 1967 of a Calidria raw fiber? 3 A. 1 seem to recall 5 microns was the 4 figure. 5 Q. Do you know what the mean fiber length 6 was of a processed Calidria fiber in 1967? 7 A. No, 1 didn't know that figure. 8 Q. Do you agree that the form of the 9 Calidria fiber changes from the raw fiber to a 10 different form once processed, or don't you know? II A. I'm not sure that 1 knew that. 12 Q. 1 thought you said that the geometry 13 changed, but 1 may be wrong. That may just be an 14 error in my notes. 15 A. 1 didn't mean it if it was said. 16 Q. Would you have appreciated to know, when 17 you wrote your report in 1967, that the medical 18 director of Union Carbide already knew about the 19 disease of mesothelioma? 20 A. That was the purpose of the report, to 21 elicit that sort of information. 22 Q. Do you know whether or not Union 23 Carbide, prior to the time that you wrote your 24 report, had employees that had been diagnosed with 25 asbestosis? SPHERION DEPOSITION SERVICES nnt jQn-tJtn 72 (Pages 282 to 285)