Document Rj5DkYnRrxpY5eVzrY8KvzZ8n
(b) Tests, studies, surveys and/or research of any
type concerning the hazards and/or potential
exposure associated with any specific type and/or
brand of asbestos-containing material/product,
including but not limited to, materials/products
that were manufactured,
sold,
distributed,
installed, applied and/or otherwise used by
defendant and/or any predecessor/related entity,
other than those already identified in response to
Standing Order No. 1 Interrogatories;
(c) Tests, studies, surveys and/or research of any type concerning the relationship between exposure to asbestos and any disease, including pleural disease, asbestosis, lung cancer, mesothelioma and/or cancer of any kind;
(d) Dust counts, industrial hygiene surveys, tests
relating to TLVs, and/or like studies, tests and
or surveys concerning the propensity of any
material/product to release asbestos fibers
(including but not limited to, materials/products
that were manufactured,
sold,
distributed,
installed, applied and/or otherwise used by
defendant and/or any predecessor/related entity)
and/or the quantity of fibers released;
(e) Dust counts, industrial hygiene surveys, tests relating to TLVs, and/or like studies, tests and or surveys concerning the presence of asbestos fibers at any facility, location and/or area (including but not limited to, those owned, operated and/or controlled by defendant and/or any predecessor/related entity) and/or the quantity of fibers present;
(f) Tests, studies, surveys and/or research of any type designed to reduce or eliminate inhalation of asbestos and/or asbestos fibers by persons working with and/or around asbestos and/or asbestoscontaining materials/products; and/or
(g) Research of any type concerning asbestos.
ANSWER:
a) No b) No c) NO d) Gleason Facilities were tested for asbestos some
time in the mid 1980s. Please see documents provided. e) See above ,f) See above 9) Three employees are tested every year relative to
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