Document XRvMwyYOQzGEqbY8G2aEeOqzg

CONWED CORPORATION V. UNION CARBIDE 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA In Re : Asbestos Products Liability Litigation (No. VI) Civil Action No. MDL 875 UNITED STATES DISTRICT COURT FIFTH DIVISION DISTRICT OF MINNESOTA CONWED CORPORATION, Plaintiff, -against- - UNION CARBIDE CHEMICALS AND PLASTICS COMPANY, INC., (f/k/a UNION CARBIDE CORPORATION), Defendant, Case No. Civ. 5-92-88 - and- UNION CARBIDE CHEMICALS AND PLASTICS COMPANY, INC., (f/k/a UNION CARBIDE CORPORATION), _ Third-Party Plaintiffs; : : : : -against- : OWENS-CORNING FIBERGLAS CORPORATION, : WALKER JAMAR COMPANY, A.W. KUETTEL & : SONS, INC., API, INC. and MacARTHUR : COMPANY, : Third-Party Defendants. : ................................................................................................................ x January 14, 1994 ARTHUR M. LANGER Doyle Reporting, Inc. CERTIFIED STENOTYPE REPORTERS Total Litigation Support WALTER SHAPIRO. CSR CHARLES SHAPIRO. CSR 369 LEXINGTON AVENUE MEW YORK. N.Y. 10017 (212) 867-8220 2 January 14, 1994 10:25 a.m. Deposition of Non-Party Witness ARTHUR M. LANGER, taken by Defendant, pursuant to notice, at the offices of Kelley Drye & Warren, Esqs., 101 Park Avenue, New York, New York, before Robert E. Levy, a Certified Shorthand Reporter and Notary Public within and for the State of New York. 3 Appearances: STICH ANGELL KREIDLER & MUTH, P.A. Attorneys for Plaintiff The Crossings, Suite 120 250 Second Avenue South Minneapolis, Minnesota 55401 By: ROBERT D. BROWNSON, ESQ., of Counsel FOLEY & LARDNER, ESQS. Attorneys for Defendant 777 East Wisconsin Avenue Milwaukee, Wisconsin 53202-53 7 By; TREVOR J. WILL,' ESQ., Of Counsel - and- KELLEY DRYE & WARREN, ESQS. 101 Park Avenue New York, New York 10178 By: ALAN GERSON, ESQ., of Counsel oOo 14 2 ARTHUR M. LA N G E R, (residing at 6 3 Rochambeau Drive, Hartsdale, New York), 4 having been first duly sworn by the Notary 5 Public (Robert E. Levy), was examined and 6 testified as foll< 7 EXAMINATION BY 8 MR. WILL: 9 Q. State your name, please. 10 A. Arthur M. Danger. 11 Q. And Dr. Langer,. my name is Trevor 12 Will . We have met before . I'm going to be taking 13 your deposition today. I understand you have been 14 depo sed before? 15 A. Yes * 16 Q. If I ask you something that doesn't 17 make sense or that you don't hear, let me know and 18 I'll either try to rephrase it or have it read 19 back. If you answer the question I'll have to 20 assume that you heard it, understood it and 21 answered it to the best of your ability, all 22 right ? 23 V 24 A. Yes. Q. And also as you are doing, please use 25 yes or no rather than uh-huh or uh-uh, because DOYLE REPORTING, INC. (212)867-8220 1 Langer 5 2 that is hard for the reporter. 3 A. Agreed. 4 Q. If you need a break for any reason 5 let me know and at an appropriate point, we will 6 stop and go off the record. 7 A. Fine. 8 Q. Did you bring a copy of your CV with 9 you today? 10 A. Yes. 11 (Handing) 12 MR. WILL: I would ask the reporter 13 to mark this as Exhibit 1. 14 (Whereupon, curriculum vitae of 15 Arthur M. Langer marked Langer Exhibit 1 16 for identification, as of this date.) 17 MR. WILL: Let me ask you to mark 18 this as 2. 19 (Whereupon, notice of deposition 20 marked Langer Exhibit 2 for identification, 21 as of this date.) 22 MR. WILL: And this will be three. 23 (Whereupon, document entitled 24 "Mineralogical Analysis of Chrysotile Ore 25 Specimens Obtained in the KCAC Pit DOYLE REPORTING, INC. (212)867-8220 1 Langer 6 2 (Formerly Union Carbide's New Idria 3 Deposit), Summary" marked Langer Exhibit 3 4 for identification, as of this date.) 5 Q. Is Exhibit 1 complete, Doctor? 6 A. Complete in the sense that this is 7 the document that I brought today and represents 8 my updated curriculum vitae, yes. 9 Q. Do you have anything to add to it, 10 any publications or abstracts since that was 11 prepared? 12 A. No. 13 Q. And what was the date of the last 14 revision? 15 A. Sometime late December, mid December, 16 something like that. 17 Q. December of 1993? 18 A. December of 1993, yes. 19 MR. WILL: At the request of Mr. 20 Brownson, I will put on the record that I 21 did serve a copy of the notice of Dr. 22 Langer's deposition on all parties to this 23 case and they have for whatever reason 24 chosen not to appear, but I did serve 25 everyone. nnVT,l? OPDriOTTWa. TMT ( 2 1 2 ^ ft 6 1 - ft 2 2 0 1 Langer 7 2 Q. Doctor, when were you first contacted 3 by anyone at Conwed or working for Conwed about 4 this case? 5 A. I believe it was sometime in 1993. 6 Q. 7 A. 8 Q. 9 before? Who was it that made that contact? Mr. Brownson. And had you worked with Mr. Brownson 10 A. Yes , 11 Q. Was this the first time you had been 12 contacted by Mr. Brownson to do any work for 13 Conwed? 14 A. No. 15 Q. When was the first time you were 16 contacted to do any work for Conwed? 17 A. A year, perhaps 1990 or 1989. 18 Q. In this particular case, the Conwed 19 versus Union Carbide case, what was it that you 20 were asked by Mr. Brownson to do? 21 A. Mr. Brownson asked me to review 22 general materials pertaining to the Union Carbide 23 asbestos deposit in California. He asked me to 24 review documents pertaining to -- reports, rather, 25 pertaining to the biological potential of DOYLE REPORTING, INC. (212)867-8220 1 Langer 8 2 chrysotile asbestos. He asked me to review 3 documents pertaining to industrial hygiene surveys 4 in user facilities, meaning facilities which used 5 the Union Carbide product. He asked me to 6 determine size distribution, characteristics of a 7 chrysotile aerosol generated from the Union 8 Carbide product. He asked me to attend a meeting 9 in California concerning the Environmental 10 Protection Agency's Superfund cleanup operation at 11 the New Idria chrysotile deposit. Essentially 12 that was what was asked of me. 13 Q. Were you asked to review ore samples 14 or samples of material? 15 A. Yes. 16 Q. The general materials regarding the 17 Union Carbide deposit in California, what were 18 those materials? 19 A. In accompanying Mr. Brovnson, we 2 0 visited the operation which was formerly Union 21 Carbide's operation, now called the King City 22 Asbestos Corporation. 23 Q. Maybe I can interrupt you? 24 A. Please. 25 Q. I didn't ask a very clear question. nnvT.i? ocPORTTMr, INC. (212 ) 867- 8220 1 Langer 9 2 You said you first were asked to review some 3 general materials? 4 A. Right. 5 Q. Regarding the Union Carbide deposit? 6 A. Right. 7 Q. Okay. And by that, I assume you 8 meant some written materials? 9 A. Sure, right, yes, within the 10 mineralogical literature there are reports 11 concerning the mineralogy of the deposit and there 3 12 are existing reports on the nature of the 13 serpentine itself and the general geology. 14 mineralogy and structure of that particular 15 geological feature. 16 Q. Did Mr. Brownson provide you with any 17 of those materials or were you asked to look them 18 up and review them yourself? 19 A. No, this basically was my assignment. 20 Q. Do you recall which general pieces of " 21 literature or reports you reviewed? 22 A. Yes, there are several papers by Dr. 23 Mumpton, who now is affiliated with the state 24 university, Dr. Sheldon Thompson, both of whom at 25 that time worked for Union Carbide. There is a nnYT.P uponpTTWG. INC. (212)867-8220 1. Langer 10 2 guidebook to the area by a Professor Fowkes at one 3 of the local colleges in Coalinga. There are 4 several other reports but X can't at the present 5 time recall the senior authors, but there are some 6 general reports. 7 Q. Okay. You said Mr. Brownson asked 8 you to review reports on the biological reports of 9 chrysotile asbestos? 10 A. Yes. 11 Q. And again was that something you were 12 asked to research? 13 A. Yes. 14 Q. Were any of those furnished to you by 15 Mr. Brownson? 16 A. None. 17 Q. And how much time did you spend 18 researching the literature on biological affects 19 of chrysotile asbestos? 20 A. Total hours? 21 Q. Yes. For this project. 22 A. Maybe 30 hours. 23 Q. Are there any - 24 A. Plus or minus. 25 Q. Which studies or papers or articles DOYLE REPORTING, INC. (212)867*8220 1 Langer ll 2 did you find that you felt to be important on this 3 question of biological effect? 4 A. There is a series of experimental 5 studies by Wagner and colleagues. A series of 6 studies by Davis and colleagues from Edinburgh. 7 Studies in the United States by Brody, Kagan. A 8 study of ours in which the senior author is Yager. 9 Studies from Germany, and this is Muhle, a study 10 by Pott, a study by Maltoni. I'm sure there are 11 others but I've just -- I'm .just blocking on them. 12 Q. All right. 13 A. But there are a number of studies 14 which pertain to in vitro tests using cells, 15 challenged by mineral dust, a number of studies 16 involving animals involving inhalation studies, 17 and of course studies involving epidemiological 18 studies of cohorts of workers exposed to the 19 mineral. 20 Q. Of the studies that you reviewed, how 21 many of them involved specifically the so-called 22 calidria asbestos or Coalinga asbestos? 23 A. Maltoni used the Coalinga asbestos. 24 Muhle used Coalinga asbestos. We used the 25 Coalinga asbestos. DOYLE REPORTING, INC. {212)867-8220 1 Langer 12 2 Q. "We" meaning the Yager paper? 3 A. Yager et al.( right. 4 I didn't mention Frank Platek's 5 paper. He is from NIOSH. They used Coalinga 6 material. Pott used Coalinga material. 7 Q. Other than those five studies, are 8 you aware of any other studies reporting on the 9 health effects of Coalinga asbestos in the 10 1iterature? 11 'A. There may be others but I'm just not 12 recalling. I cannot recall of others. 13 Q. You said you were also asked to 14 review industrial hygiene reports at facilities 15 where they were using Union Carbide asbestos, is 16 that correct? 17 A. Yes. 18 Q. Approximately howmany of those 19 reports did you review? 20 A. There are hundreds of these reports 21 and I have not as yet reviewed all of them. It is 22 just so voluminous but I'm in that process now. I 23 brought some of these with me. 24 Q. What is the reason for reviewing 25 those reports? How do they fit into your role in DOYLE REPORTING, INC. (212)867-8220 1 Langer 13 2 this case? 3 A. They fit into this case in the 4 following way. I am one of those individuals, and 5 I believe that many others in the field believe 6 that mining and milling of chrysotile is 7 associated with one set of risks whereas those 8 risks change in the user industries, so mining and 9 milling of chrysotile may be a relatively low-risk 10 operation but user industries that manipulate for 11 different purposes may not have the same control 12 technology or the same control strategies and 13 'u A .flair ovnnoQ^ t-n hiohpr rnnrpnCrat ions of 14 15 16 17 18 19 Q. In your view is the difference in 20 risk between the mining and milling occupation on 21 the one hand and the user industries on the other 22 due to a change in the nature of the fibers itself 23 that results from the milling process or is it the 24 result of differing concentrations or is it some 25 combination? nnYLE REPORTING, INC. (212)867-8220 1 Langer 14 2 A. Probably a combination. 3 Q. What do you believe happens to the 4 fiber during the mining or milling process that 5 changes the risk? 6 A. During mining and milling? 7 Q . Yes. 15 During the crushing operation it tne 16 ores are still wet, the concentrations of fiber 17 are not that great either. It is only when the 18 materials are dried and processed through milling 19 do they become more dusty, and when one raises 20 dust, then the risk associated with exposure 21 increases. 22 Q. Is.it basically then the quantity of 23 dust that dictates the level of risk? 24 A. That is one of the factors. That's 25 right. DOYLE REPORTING, INC. (212)867-8220 1 2 3 4 5 6 7 8 9 10 11 12 13 14 ir i< i' i* is 2C 21 27 23 24 25 Langer 15 Q. Is that in your view the most important factor? A. It is one of the important factors. Talking about chrysotile? Q. Yes. Chrysotile. A. That is one of the factors, important factors, cumulative dose, sure. Q. Is there anything that happens to the fiber itself during the milling process other than whether it is wet or dry, talking about actual . phanrrao tip - a -4 V-v -v ^ t- a a 1 ^ *- V-> - *- .. 1" - 1 - -- - - -- DOYLE REPORTING, INC. {212)867-8220 1 Langer 16 2 q. You mentioned dust control. Is the 3 dust control used by the user industry an 4 important factor in the risk to the workers in the 5 user industry? 6 A. I'm sorry. Could you -- 7 Q. Sure. Is the dust control or lack 8 thereof employed by the user industry an important 9 factor in determining what the risk is to a worker 10 in the user industry from the chrysotile fiber? 11 A. Yes. 12 Q. Who was it that, to your knowledge, 13 actually conducted those air hygiene studies that 14 you referred to? 15 A. There are some names which are 16 indicated in these documents that I have brought, 17 and I'm assuming that these are industrial 18 hygienists. 19 Q. Do you know for whom they worked? 20 A. I believe they worked for Union 21 Carbide. 22 Q- To your knowledge, then all of these 23 studies were done by Union Carbide? 24 A. Apparently so. 25 Q. All right. Do you have any criticism DOYLE REPORTING, INC. {212)867-8220 1 Langer 17 2 of the technique employed by those industrial 3 hygienists in doing their air hygiene surveys? 4 A. No. 5 Q. Do you have any critique of the 6 conclusions which they drew, if any? 7 A. Given the date of the report, given 8 the standards at the time, and given the data, do 9 I have any criticism? 10 Q. Yes, of what conclusions they drew? 11 *A. Well, one doesn't want to be a Monday 12 morning quarterback. You have to take it at face 13 value. No. 14 Q. Sitting here today in 1994, the 15 standards for permissible exposures to asbestos 16 have changed, is that correct? 17 A. Yes. 18 Q. From what they were when these air 19 hygiene studies were being conducted? 20 A. Yes. 21 Q. Now youmentioned also that you were 22 asked to investigate the size distribution 23 characteristics - - 24 A. Yes. 25 Q. -- of the calidria asbestos fiber? DOYLE REPORTING, INC. (212)867-8220 1 Langer 18 2 A. Yes. 3 Q. What did that involve? 4 A. We had made, in the university, a 5 chamber from which we could generate an aerosol 6 through air movement across a specimen, and we 7 milled one of the commercial grade Union Carbide 8 pellet classes for approximately three seconds 9 just to break them, and this material was then 10 subjected to an air flow and we collected the 11 fibers generated during this release and we 12 analyzed those fibers, although we are still 13 crunching numbers. 14 Q. What was the purpose of doing that? 15 A. Well, one of the frequently heard 16 criticisms involved in generating a size 17 distribution on any specimen is that we use a 18 dispersion in an aqueous medium, in water, and 19 this may introduce artifacts in that the way to 20 determine the size distribution of a dust cloud to 2 1 which workers might be exposed would be to 22 generate an aerosol and see what is actually in 23 the air. 24 Q. Why are you interested in the size 25 distribution characteristics of the asbestos from DOYLE REPORTING, INC. (212)867-8220 1 Langer 19 2 Union Carbide? 3 A. It is frequently heard that the Union 4 Carbide deposit is a short fiber and therefore 5 does not possess biological potential. 6 Q. When you say it is frequently heard 7 that the Union Carbide deposit is a short fiber, 8 what is meant, to you, by short in that context? 9 A. Well, there are two meanings of the 10 word "short." One meaning is a commercial meaning 11 and the other is a biological meaning. For sure, 12 the deposit in California is a short commercial 13 fiber, for sure. In fact it is just about one of 14 the shortest dispersed preparations made 15 commercially anywhere. 16 QBefore we leave that, what length 17 would you expect to find in something considered a 18 short commercial product? 19 A. Well, I'm thinking of the Quebec 20 standards, the screening technique in which there 21 the technique for - - let me change this. The 22 protocol for determining the size of a fiber is 23 based on this particular technique originated in 24 Canada because fibers of different lengths impart 25 certain qualities to products. Weaving or DOYLE REPORTING, INC. (212)867-8220 1 Langer 20 2 spinning grades are AAA, AA, A or something like 3 that or a 3. Fine materials, commercially short 4 fiber used in a product like a floor tile or a 5 ceiling tile in the Canadian classification is a 6 7. 7 Now, the Coalinga-type fibers are all 8 7's. Now the Quebec screening, to answer your 9 question specifically, the Quebec screening 10 technique consists of three screens and a 11 catchment device in which 16 ounces of a fiber 12 preparation is dumped on top and the screen is 13 subjected to certain motion and the materials 14 filter through, and the screening, the Quebec 15 screening classification then requires the 16 material be weighed and to the nearest ounces of 17 the 16 ounces, you have four figures which reflect 18 screen A, screen B, screen C and then the 19 catchment pan, so a typical cement fiber might be 20 2, 6, 6, 2 or something like that but it has to 21 add up to 16. The fibers out in California in the 22 Coalinga deposit would be 0, 0, 0, 16. Now that 23 is a commercial classification. 24 Q. In terms of their "length," what 25 would you expect to -- DOYLE REPORTING, INC. (212)867-8220 A. I know this is hard to believe but that first screen catches materials that are greater than about .5 inches. It is .5 or 6, something like that. Now a half inch, that is 25.4 millimeters, so that is 12 millimeters. That means fibers less than 12,000 microns in length fall through it. The next one, actually the bottom screen would be fibers less than about a thousand microns in length passes through it. Q. Which is one millimeter? A. Which is one millimeter, that's right, so it is a little bit more than a millimeter, something like that. So the commercial application when we talk about long fiber, short fiber, biologically, it is less than five microns or greater than five microns. So we are dealing with a different entity. Q. So then what is considered a short fiber commercially is something that is less than approximately one millimeter in length? A. That's right. Q. And what is considered a short fiber biologically is something less than five microns DOYLE REPORTING, INC. (212)867-8220 1 Langer 22 2 in length? 3 A. That's right. 4 Q. Now, when you said it was often 5 stated that - - 6 (Pause) 7 Q. Dr. Langer, when you mentioned 8 earlier that it was often said that the chrysotile 9 from the Coalinga area was a short fiber and 10 therefore biologically inactive, was the "short" 11 in that comment being used in the commercial sense 12 or the biological sense or do you know? 13 A. It is frequently heard from 14 biologists or those in certain medical fields, and 15 these individuals assumed that when a commercial 16 application was a short fiber, they immediately 17 thought of biologically short. Which is not 18 uncommon. But it is quite different, of course. 19 Q. Now, am I correct that the size 20 distribution analysis that you are doing is with 21 respect to the five-micron standard for 22 biologically short? 23 A. Yes. Well, we do it all, but we are 24 interested in what percentage of the total aerosol 25 is greater than five microns. DOYLE REPORTING, INC. (212)867-8220 1 Langer 23 2 Q. Are you using ocher cucoff points 3 besides five microns for calculating percentages, 4 in other words - 5 A. We are looking at other size 6 increments, less than one, one to two, two to 7 three or five to 10 or greater than 10. 8 Q. You say that those numbers have been, 9 or some of the data has been obtained but the 10 calculations haven't been done? 11 A. Yes. 12 Q. Do you have a sense of what the data 13 show, at least preliminarily? 14 A. We can generate an aerosol with I 15 think it will be greater than 10 fibers per c.c. 16 of air greater than five microns in length per 17 cubic centimeter of air. 18 Q. And in that dust sample, how many 19 fibers would there be less than five microns? 20 A. Maybe a hundred times. 21 Q. So that you would expect to find 22 something on the order of 1,000 fibers below five 23 microns and per 10 fibers above five microns? 24 A. Yes. 25 Q. Do you know which grade of Union DOYLE REPORTING, INC. (212)867-8220 1 Langer 24 2 Carbide calidria asbestos was used for this? 3 A. I think we used RG-100. 4 Q. And was that actually Union Carbide 5 product or King City Asbestos Corp.? 6 A. No, these are historical samples that 7 we have in our laboratory marked Union Carbide. 8 Q. When were they obtained, do you know? 9 A. In the '70s. When I was at Mount 10 Sinai. 11 Q. So they were obtained by Mount Sinai 12 Hospital in New York? 13 A. NO . By me as an individual. 14 Q. When you were - 15 A. When I was at Mount Sinai, yes. 16 Q. When you say you are generating an 17 aerosol, does that mean anything more than just 18 dust in the air? 19 A. That is it. 20 Q. When you milled this fiber pellet, 21 what type of equipment did you use? 22 A. We,used a mill made in Germany. It 23 is a blade mill. And it consists of -- it looks 24 1 ike an inverted malted milk machine with a 25 chamb er and the blade spins and it shatters DOYLE REPORTING, INC. (212)867-8220 1 Langer 25 2 materials. 3 Q. You say you used about three seconds? 4 A. It could have been less. What we 5 were trying to do is just -- let me backtrack for 6 a second. These pellets tend to be friable, and 7 if a pellet were to break, or a pellet were to be S subjected to a saw in some process, what would 9 happen to this material. And we wanted to -- it 10 is impossible to reproduce everything. We just 11 wanted to break down some pellet so it no longer 12 had a physical state in which it was a pellet but 13 rather it had broken as if somebody stepped on it. 14 Q. If the pellet were broken through 15 some mechanism other than a blade, do you believe 16 that would affect the fiber distribution 17 characteristics? 18 A. It is possible. 19 Q. Would the length of time to which the 20 pellet was subject to milling or processing affect 21 the fiber distribution characteristics? 22 A. Yes, it probably would shorten it, 23 but this is just a guess. It would change it. 24 How it would change it, I can't predict. 25 Q. Is the technique that you used in DOYLE REPORTING, INC. (212)867-8220 1 Danger 26 2 aerosolizing this pellet supposed to in way way 3 replicate how the pellets were subjected- in 4 Conwed? 5 A. No. 6 Q. Are you aware of where the Union 7 Carbide pellets were placed in the Conwed 8 production process? 9 A. NO. 10 Q. If the pelletswere dumped into a 11 watery solution, and then basically pulverized or 12 mixed together with other ingredient, would that 13 have an impact on fiber size distribution 14 characteristics? 15 A. Probably. 16 Q. Do you know what that impact would 17 be? 18 A. No. 19 Q. You mentioned that you were also 20 asked to -- when do you expect to have the results 21 completed of your fiber size distribution? 22 A. We are working on it now. It is just 23 a matter of looking at the final data sets. A 24 couple of weeks. Then we are busy with so many 25 other things. DOYLE REPORTING INC. (212)867-8220 1 Langer 27 2 Q. How many times did you run this 3 particular experiment with the blade mill? 4 A. You mean how many times was an 5 aerosol generated? 6 Q. Yes . 7 A. Several times. 8 Q. Several meaning three to five? 9 A. No, I would say two or three. 10 Q. Does your data suggest variation 11 between the two or three samples or are the 12 results consistent? 13 A. Well, that is something that we are 14 looking at now. Just how consistent this is. 15 Q. You said that Mr. Brownson also asked 16 you to attend a meeting in California? 17 A. Right. 18 Q. About theSuperfund cleanup at the 19 New Idria area? 20 A. Right. 21 Q. And whatwas your-- do you know what 22 the purpose of asking you to go to that meeting 23 was ? 24 A. Just to hear what was going on. How 25 the federal government perceived the problem. DOYLE REPORTING, INC. (212)867-8220 1 Lange r 28 2 Q. How does the government perceive the 3 problem, to your knowledge? 4 A. Apparently they perceive a hazard. 5 Q. What is the nature of that hazard? 6 Is it asbestos in the air, asbestos in the water? 7 A. Both. 0 Q. What is the source of the asbestos 9 that the government is worried about? 10 A. Well, principally, the asbestos 11 deposit itself, the runoff from that deposit and 12 the fibers which are in the soils and alluvium in 13 the area and water in the California aqueduct 14 system. 15 Q. Are the Johns-Manville and Atlas mine 16 sites in the New Idria area? 17 A. Yes. 18 Q. Thought to be responsible for this 19 problem? 20 A. Yes. 21 Q. How about the Union Carbide site? 22 A. No . 23 Q. What air concentrations are the 24 federal government reporting? 25 A. i don't think they arereporting any. DOYLE REPORTING, INC. (212)867-8220 1 Langer 29 2 The data I have seen, are 0001 or below. Something 3 like that. 0.0001. 4 Q. That is considered not atypical for 5 ambient air throughout the country? 6 A. I would say so, yes. 7 Q. Do you believe based on what you know e that there is any health risk from the asbestos 9 concentrations in the air or the water that the 10 federal government is talking about in this area? 11 A. Do I believe there is a risk? 12 Q. Yes. 13 A. No. If there is a risk it is very 14 1 ow. 15 Q. You are talking something less than 16 winning the lottery or being hit by lightning? 17 A. Something like that. 18 Q. What is the federal government 19 proposing to do about this risk? 20 A. What have they done? They have done 21 the following. They have dismantled the 22 Johns-Manville mill. They have moved the tailings 23 deposits. They have rerouted waterways. They 24 have reconstructed roads. They have buried the 25 mill on the site. They have proceeded with DOYLE REPORTING, INC. (212)867-8220 1 Langer 30 2 similar actions at Atlas. They have proceeded to 3 change the configuration of the Pasajero catchment 4 basin which during times of flooding spills over 5 into the California aqueduct system. And there is 6 some talk of modifying several hundred acres of 7 area out there at an additional cost of $75 3 million. 9 Q. In your view, is that money well 10 spent ? 11 A. No. _ 12 Q. Were you asked to give your 13 observations on what was going on there? 14 A. No. 15 Q. You were just there as an observer? 16 A. I was there as an observer. --- 17 Q. Okay. Other than attending that one 18 meeting, have you been asked to do anything else 19 with respect to the Superfund cleanup efforts 20 there? 21 A. Well, they would like me to come back 22 next year and give a talk, as a matter of fact. 23 Q. That would be on the government's 24 tab? 25 A. I guess. DOYLE REPORTING, INC. (212)867-8220 1 Langer 31 2 Q. Not on Mr. Brownson's tab? 3 A. I guess. 4 Q. How, if at all, do you think that c what occurred at that meeting and what you 6 observed relates to what you have been asked to do 7 in this case, the opinions you have been asked to S give in this case? 9 A. California is a very interesting 10 place, and the fact that the government focused on 11 this particular site, this particular material is 12 a naturally occurring material. This represents 13 the only Superfund site in the United States which 14 is a natural outcropping of materials. And on the 15 basis of the data provided to the government in 16 their perception, they are investing $100 million 17 on ameliorating this. 18 Q. Basically changing nature? 19 A. If you will. 20 Q. As you put it, this is not a 21 situation where people have collected toxic 22 chemicals from other places and dumped there in 23 the ground? 24 A. No, no, no, not at all. 25 Q. This is just a mineral that was in DOYLE REPORTING, INC. (212)867-8220 1 Langer 32 2 the ground to begin with? 3 A. Yes. 4 Q. You also mentioned that you were 5 asked to collect and review samples of ore from 6 the KCAC asbestos mine, the former Union Carbide 7 mine? S A. Yes, that's right. 9 Q. In fact on July 27 of 1993, you did 10 tour the mine site and collect materials? 11 *A. That's right. - 12 Q. Have you now had a chance to analyze 13 those? 14 A. Yes. 15 Q. What were you asked to look for in 16 the course of that analysis? 17 A. What is present in the deposit, are 10 there mineral fibers present other than 19 chrysotile. And if so, what are they and what are 20 their concentrations and could this have an impact 21 on biological potential. 22 Q. Were you specifically looking for 23 amphibole fibers? 24 A. Yes. 25 Q. And why were you looking for DOYLE REPORTING, INC. {212)867-8220 1 Langer 33 2 amphiboles? 3 A. It is -- there is a currently held 4 belief that several of the diseases associated 5 with chrysotile exposure may be explained wholly 6 or in part by the presence of associated minerals 7 within chrysotile, specifically certain 8 amphiboles. 9 Q. Is it known that amphiboles can cause 10 asbestosis, lung cancer and mesothelioma without 11 chrysotile? - 12 A. Amphibole asbestos materials can 13 produce those diseases without the presence of 14 chrysotile, yes. 15 Q. Have you now completed your work in 16 analyzing the samples from the mine site? 17 A. I've completed the laboratory work. 18 I'm still looking at certain kinds of data to more 19 and better understand the nature of nonchrysotile 20 fibers which are present in some of the samples. 21 Q. In terms of the biological 22 definition, the short fibers being below five 23 microns - - 24 A. Right? 25 Q. -- who was it that came up with that DOYLE REPORTING, INC. (212)867-8220 1 Langer 34 2 criteria for the short, if you will? 3 A. Actually it goes back to the 1950's, 4 i960's when the British changed over standards 5 from total particles to fibers and the five-micron 6 size length was incorporated in the new counting 7 strategy for analytical purposes, with the support a of some very limited biological data. 9 Q. So that when the British standards 10 changed from counting particles to counting 11 fibers, they told the industrial hygienists to 12 count only fibers longer than five microns? 13 A. Well, this is developed. No one told 14 anyone anything. It was basically a group of 15 people, the fact that they were working for Turner 1 6 Newall, and it was found that when one counted 17 total particles, you didn't care how long the 18 fibers were, but once the fibers went below a 19 certain length it was more difficult to get 20 reproducible results. 21 And the wisdom at that time was that 22 asbestosis was produced by the disintegration of 23 long asbestos bodies releasing silicic acid and 24 involving a cellular process much like silicosis. 25 So you had a convergence of the need to DOYLE REPORTING, INC. (212)867-8220 1 Langer 35 2 distinguish particles from fibers using a light 3 microscope. You had the constraints of developing 4 a system that was reproducible when you reexamined 5 the same specimen. You needed a counting protocol 6 which could be used by different laboratories and 7 still come up with the same answer. And there was 8 this prevailing biological hypotheses concerning 9 the disease of interest at that time, which was 10 principally asbestosis. 11 Q. And the hypotheses at that point was 12 that fibers below five microns would not produce 13 asbestosis? 14 A. The prevailing view at that time. 15 The prevailing view. 16 Q. When you mentioned that that .was . - 17 based on some limited biological work - 18 A. Yes. 19 Q. -- whose work was that? 20 A. Beattie & Knox's work that was 21 presented in 1959, published in 1960 in the 22 proceedings of the conference -- it is generally 23 called the inhaled particles and vapors meeting 24 but it was a meeting held -- a pneumoconiosis 25 meeting held under the auspices of the British DOYLE REPORTING, INC. (212)867-8220 1 Langer 36 2 Occupational Hygiene Society. 3 Q. Have you then as a mineralogist 4 accepted that five micron definition essentially 5 ever since you have been working in the field? 6 A. No, actually I've had a long 7 interesting journey through this. 8 Q. Maybe I should rephrase the question 9 Would it be correct to say that ever since you 10 have been working in the field, you have been 11 aware of the fact that in biological terms 12 something below five microns is considered short? 13 A. Generally held, yes. 14 Q. Okay. This is not a definition that 15 you came up with? 16 A. No. 17 Q. This is something shared throughout 18 the scientific community? 19 A. Parts of the scientific community, 20 yes. And I would say -- yes. 21 Q. Shifting gears, I want to ask you 22 about the other cases that you've worked on for 23 Conwed Corporation. Can you tell me what those 24 involved? 25 A. They involved property damage DOYLE REPORTING, INC. (212)867-8220 1 Langer 37 2 litigations. 3 Q. Where were they? 4 A. Let's see, I think they involved the 5 Annerundel County, Maryland school cases, 6 Baltimore County cases. These were ceiling tile 7 cases in buildings. 8 Q. So is this the third case that you've 9 worked on for Conwed? 10 A. It could be. There could have been 11 one more. - 12 Q. Were all of the other ones so-called 13 property damage cases? 14 A. Yes. 15 Q. Building owners that were suing for 16 the cost of removing Conwed ceiling tiles? 17 A. Yes. 18 Q. And in those cases, were you asked to 19 assess the biological risk to occupants of the 20 school buildings from asbestos released by the 21 tiles? 22 A. No. 23 Q. What were you asked to do? 24 A. Examine the tiles, determine if 25 asbestos existed in the tiles, fiber type and DOYLE REPORTING, INC. (212)067-8220 1 Langer 38 2 concentration. Basically a certain assay. 3 Q. Were you asked to give any opinions 4 at all about a health risk posed by those products 5 in those buildings? 6 A. I don't think so, as I sit here. 7 Q- Have you ever been involved with 8 Conwed in a case where someone was suing Conwed 9 alleging personal injury as a result of working 10 with or around Conwed ceiling tiles? 11 A. I don't think so. 12 Q. Have you ever heard of such a case? 13 A. I don't think -- no. If I had some 14 knowledge, I can't recall. 15 Q- You've also worked with Mr. Brownson 16 for other clients of his other than Conwed? 17 A. Yes . 18 Q. Which other - - 19 A. Asbestospray. 20 Q. That is Mr. Levine's company? 2 1 A. It was. 22 Q. In Brooklyn? 23 A. Yes . 24 Q- First of all, how many cases have you 25 worked on for Asbestospray? DOYLE REPORTING, INC. (212)867-8220 A. The City of Wichita Convention Center. When X say worked on these cases. I've analyzed air samples, I've provided data. That does not mean I was deposed nor testified but just general assistance in cases. City of Wichita Convention Center. Kansas City International Airport. Transworld Airline International Terminal at Kennedy Airport, New York. Boys High School in New York, Brooklyn, New York. The State of West Virginia for the University of West Virginia Coliseum. University of South Carolina. Q. And in those cases your role has been to analyze materials to see if there is asbestos in them? A. Principally, although I did testify down in Morgantown, West Virginia. Q. In any of the other cases, other than the West Virginia case, have you given testimony either by way of deposition or in court? A. I think in several of those cases I gave deposition .testimony but never at trial. Q. Did you testify at trial in West Virginia? A. Yes. DOYLE REPORTING, INC. (212)867-8220 1 Langer 40 2 Q. How about in Wichita? 3 A. No . 4 Q. In the West Virginia case, did your 5 testimony in any way touch upon health effects or 6 risks of the products in question? 7 A. In a way, yes. S Q. In what way? 9 A. Level of dust, comparison of the 10 workplace with the coliseum, levels of the fiber 11 in the air in the coliseum. - 12 Q. Did you offer opinions on what health 13 risks, if any, those fiber levels present? 14 A. I don't know if I was allowed to. 15 THE WITNESS: Did I -- I'm turning 16 to Mr. Brownson. _ 17 Did I offer any opinions as to the 18 health risks? 19 MR. BROWNSON: I don't remember. 20 THE WITNESS: I don't remember 21 either. 22 MR. BROWNSON: I'm sure I did but I 23 don't remember if you did. 24 A. It was just a relative gauging of 25 exposures to a fiber in the workplace as compared DOYLE REPORTING, INC. (212)867-8220 1 Langer 4l 2 to what they were in the coliseum. 3 Q. For an occupant or somebody attending 4 a basketball game? 5 A. Exactly. 6 Q. What type of asbestos fiber did 7 Asbestospray use in their product? 8 A. In West Virginia, it wasamosite. 9 Q. Did they also use chrysotile in any 10 of their products? 11 A. There is a formulation with 12 chrysotile, and that was -- I think chrysotile was 13 in the Kansas City International Airport. 14 Q. Is theirproduct a plaster -- sprayed 15 on plaster material? 16 A. It is a cementing agent and it is 17 tamped. 18 Q. Is it applied for fireproofing? 19 A. Yes. 2 0 Q. All right. Other than for Mr. 21 Brownson, have you done other work -- let me 22 rephrase that question because we will be here all 23 year. 24 Am I correct that you've worked for 25 other clients as well as Mr. Brownson's clients in DOYLE REPORTING, INC. (212)867-8220 1 Langer 42 2 analyzing building materials for asbestos content? 3 A. Yes. 4 Q. Do you know a fellow named Ray 5 Balz e r ? 6 A. Roy Balzer, yes. 7 Q. Have you ever worked with Mr. Balzer? S A. Worked with him directly? 9 0- Yes. 10 A. No. 11 Q. What is his field or area of - 12 A. He studied at Berkeley with Clark 13 Cooper. I believe he has a PhD in epidemiology or 14 public health. 15 Q. Do you recognize himas having 16 expertise in the field of asbestos risks from 17 building materials? 18 A. Asbestos risks? 19 Q. Let me try again. 20 Do you recognize him as having 21 expertise in health risks to building occupants or 22 workers from the presence of asbestos - containing 23 materials in the building? 24 A. That sounds like a legal question. A 25 real legal question. DOYLE REPORTING, INC. (212)867-8220 l- Langer 43 2 Q. From a scientific - 3 A. From a scientific point of view , he 4 knows what air samples are all about and he knows 5 how to obtain the data and gene rate the numbers, 6 and he, like every intelligent other person. can 7 compare this with exposures in other instances and 8 draw some conclusions. So do I recognize his 9 capability in doing that, yes of course. 10 Q. Have you ever spoken with Dr. Balzer 11 about Conwed asbestos products? 12 A. No. 13 Q. Do you know whether he, Balzer, has 14 ever done any work for Conwed? 15 A. No. 16 Q. In this case, are you planning to 17 give any testimony about health risks from 18 calidria asbestos to workers in the Conwed plant 19 in Minnesota? 20 A. If someone asks me what I think, I'll 21 tell them my opinion. 22 Q. In your opinion, are Conwed ceiling 23 panels containing calidria asbestos and only 24 calidria asbestos, a health risk to building 25 occupants in - - DOYLE REPORTING, INC. (212)867-8220 1 Langer 44 2 A. No . 3 q. I was going to say in buildings where 4 those tiles are installed? 5 A. No. 6 Q. Why is that? 7 A. Because all of the data which I have 8 seen concerning the use of Conwed tiles in 9 structures show that the levels inside those 10 buildings are indistinguishable from ambient 11 levels. Therefore the risk is extraordinarily 12 1 ow. 13 Q. So low to be trivial? 14 A. I would say so low as to be phantom. 15 We have to worry about other things in society and 16 the risks are trivial, that's right. 17 Q. How about to a person who is, say, a 18 janitor or a maintenance man, cleaner in that 19 building? 20 A. Tell me how frequently they move the 21 tiles, what fiber levels they are exposed to, 11 ~ 22 calculate a cumulative dose and a time weighted 23 average and we can then tell you what the risk is. - 24 Q. All right. So that to know whether 25 somebody was at risk from working with a ` DOYLE REPORTING, INC. (212)867-8220 1 Langer 45 2 calidria-containing Conwed ceiling panel, what you 3 would really want to know is what dose of asbestos 4 are they getting out of the panel? 5 A. Yes. 6 Q. Would that same answer be true with 7 respect to what risk a person had who was working 8 in the Conwed plant itself? 9 A. Yes. 10 Q. In order to evaluate the risk you 11 need to know what the dose was? 12 A. Yes. 13 Q. In a factory, the dose that a worker 14 gets of dust is determined by, among other things, 15 whatever air hygiene or dust-handling equipment is 16 in place in the factory, is that correct? 17 A. Sure. 18 Q. To your knowledge, did Union Carbide 19 have any direct say or control over what dust 20 equipment or air-handling equipment was used in 21 the Conwed plant? 22 A. I don't know. 23 Q. Doctor, in your opinion, are pleural 24 plaques a disease? 25 A. Is it a pathological lesion? It is DOYLE REPORTING, INC. (212)867-8220 1 Langer 46 2 something that is not normally there? Yes. 3 Q. How about clinically, are they 4 considered a disease from a clinical point of 5 view? 6 A. It could. Pleural plaques can cause 7 clinical disease. 8 Q. How about in the ordinary course? 9 A. No. 10 Q. How about localized pleural 11 thickening, is that from a clinical perspective 12 considered a disease? 13 MR. BROWNSON: I object. I object 14 to the form of the question. Considered by 15 whom, by him or by others? 16 MR. WILL: By him. 17 MR. BROWNSON: Okay. 18 Q. So the point of my question is, I am 19 trying to distinguish a situation where you have 20 substantial diffuse pleural thickening over half 21 or something like that or three-quarters of the 22 pleura. I'm just talking about localized areas. 23 MR. BROWNSON: All these questions 24 deal as to his views, if any, as opposed 25 to - - DOYLE REPORTING, INC. (212)867-8220 1 Langer 47 2 MR. WILL: Yes. His views. 3 A. From what I gather in the literature, 4 a localized thickening or plaque does not cause 5 clinical symptoms. 6 Q. In terms of the testimony you have 7 given in other cases, you have -- well, I'll just 8 ask it this way. Am I correct that it is your 9 opinion that chrysotile does not cause peritoneal 10 mesothelioma? 11 A. Yes. 12 Q. Is it your opinion also that 13 chrysotile is unlikely to cause pleural 14 mesothelioma? 15 A. It is less potent, but yes, of 16 course. 17 Q. How many pure chrysotile-exposure 18 pleural mesotheliomas are you aware of that have 19 been reported in the literature? 20 A. The numbers are low, yes. 21 Q. Probably under 15, 20? 22 A. One question at a time. 23 Q. Under 20? 24 A. Under 20? Pure chrysotile verified 25 by tissue burden studies, is that correct? DOYLE REPORTING, INC. (212)867-8220 1 Langer 48 2 Q. Yes. 3 A. It could be that number. 4 Q. For a while it was thoughtthat the 5 Rochdale and Ferodo plant had some pure chrysotile 6 mesotheliomas ? 7 A. Yes. 8 Q. But later investigation showed that 9 they were contaminated with crocidolite? 10 A. They were related to crocidolite, 11 yes . 12 Q. In terms of ability to causepleural 13 mesothelioma, would you say -- of the asbestos 14 minerals, would you say that crocidolite is the 15 most potent? 16 A. Yes, generally so. 17 Q. Amosite, second? 18 A. Probably tremolite asbestos in the 19 true asbestos form is probably second, up with 20 crocidolite. Amosite next. 2 1 Q. Where do you put chrysotile? 22 A. Below that. 23 Q. Am I correct that you believe that in 24 order for chrysotile to cause pleural 25 mesothelioma, there has to be a very high dose? DOYLE REPORTING, INC. (212)867-8220 1 Langer 49 2 A. Yes. 3 Q. High enough that you would expect to 4 find asbestosis in that person? 5 A. I'm shaking my head. Probably yes. 6 Q. At least on pathological examination? 7 A. Yes. 3 Q. Perhaps not by x-ray but certainly on 9 pathological review? 10 A. Yes. Yes. 11 Q. How about lung cancer, do you believe 12 there is a difference in the ability of different 13 asbestos fibers to cause lung cancer? 14 A. Yes. 12 15 Q. Which do you feel is the most potent? 16 And let's say the absence of confounding factors 17 at this point, so assume a nonsmoker, if you will. 18 A. All right. A nonsmoker. I am one of 19 those people who believes that the amphibole 20 asbestos varieties produce more lung cancers than - 2 1 chrysotile. 22 Q. Now if you add smoking into the mix, 23 there is supposed to be a synergistic effect, is 24 that correct? 25 A. Yes. DOYLE REPORTING, INC. (212)867-8220 1 Langer 50 2 Q. And is the synergistic effect in your 3 opinion any different with amphibole than it is 4 with chrysotile? 5 A. It probably is different but I don't 6 know. 7 Q. You would expect a greater synergism 8 with the amphibole? 9 A. Well, actually if you follow along 10 the newer concepts of how cigarette smoking 11 interacts with asbestos fiber, it is probably 12 chrysotile which is more carcinogenic. 13 Q. Is that because of thesurface area? 14 A. In part, yes. 15 Q. Any other reason? 16 A. Chrysotile absorbs certainorganic 17 biological compounds more easily, and it is 18 thought that the carcinogens from cigarette smoke 19 attach to the organic material carried on the 20 surface of the fiber. So the more lipid the 21 surface of the fiber, the more carcinogenic 22 compound is carried to the target cell. 23 Q. You said this would be the modern 24 thinking? 25 A. Yes. DOYLE REPORTING, INC. (212)867-8220 1 Langer 51 2 Q. You are not aware of any experiments 3 that have been done to try to prove this one way 4 or the other? 5 A. No . 6 Q. In terms of relative risk of lung 7 cancer, can you give me some sense of where in a 8 nonsmoker chrysotile stands versus the amphiboles? 9 A. Other than animal data? 10 Q. Talking about human data. 11 A. Who has a population of nonsmokers? 12 No one. So no, those data are unavailable. 13 14 in 1 15 was 16 17 OCF . 18 V* x luxuai xu was Day xc rxiuici a l uilcLL 19 point. You were called to testify that the 20 chrysotile in the Eagle Pitcher cements could not 21 have been a cause of Mr. Pennock's mesothelioma? 22 A. I don't know if I testified to that, 23 but we were looking at different fiber types and 24 concentrations and other factors, but yes. 25 Q. Have there been other cases -- have DOYLE REPORTING, INC. (212)867-8220 1 Langer 52 2 there been any cases where you have testified in a 3 personal injury context that you did not believe 4 that chrysotile played a role in the plaintiff's 5 development of mesothelioma? 6 A. I wonder if I ever testified too. 7 The last personal injury case that I was involved 8 in here in New York involved the finding of a 9 mixture of fibers in the pulmonary tissues of an 10 electrician who succumed with pleural 11 mesothelioma. And at that time, the fibers in the 12 tissues consisted principally of crocidolite with 13 an extraordinarily small portion of chrysotile. 14 Crocidolite would have to be called the causative 15 agent. I don't think I have ever dismissed i fi chrysotile in a role, but rather given the 17 relative potencies one has to come to some general 18 conclusion. 19 Q. What type of fiber burdens would you 20 expect to see in the lung of a person whose 21 mesothelioma you believe was caused by chrysotile? 22 What kind of fiber burdens - 23 A. At least hundreds of millions of 24 fibers per gram of dry lung tissue. 25 Q. The normal white developed male lung DOYLE REPORTING, INC. (212)867-8220 Langer 53 2 has approximately how many dried grams in it? 3 A. The ratio is generally one to 10, 4 meaning that for every 10 grams of wet tissue, 5 this can be reduced by heating and dehydration to 6 one gram, so in an adult lung, a male, with a 7 1,000-gram right lung, this could be reduced to 8 100 grams of dry lung. 9 Q. How about the left lung, how many -- 10 A. It is smaller. We are talking in 11 generalities. Could be 1500 grams, 1200 grams. 12 In women it could be 850 grams or 650 grams, 13 something like that. 14 Q. But an average white male -- lung 15 size does - - 16 A. It depends on physiology, race and 17 other factors. 13 18 Q. So we are talking about white males, 19 say approximately a thousand grams of wet tissue 20 on the right lung and 900 on the left? 21 A. 900, 850, something like that. 22 Q. When was the first time you ever 23 looked at calidria asbestos samples? 24 A. 1960's. 25 Q. What was the reason for doing that? DOYLE REPORTING, INC. (212)067-8220 1 Langer 54 2 A. I was interested in characterizing 3 asbestos used in the United States and in various 4 products. 5 Q. From what perspective, characterizing 6 it as to what? 7 A. Just looking at it in terms of 8 mineralogical composition, fiber length, fiber 9 character. 10 Q. Is that when you acquired some 11 calidria from Union Carbide? 12 A. Yes. I think I got those fibers in 13 the early '70s. 1970, 1971, '72. Something like 14 that. 15 Q. So that would have been your first 16 examination of calidria at that pint? 17 A. I'll tell you when I became 18 interested in calidria. This is just an aside. I 19 was at a meeting, mineralogical meeting, 20 mineralogy of asbestos in Oxford in 1968, and Fred 21 Mumpton presented data on the New Idria deposit 22 and I obtained some speciments at that time. 23 Q. Shortly after that meeting and then 24 you began looking at them? 25 A. I was interested. It was a new kind DOYLE REPORTING, INC. (212)867-8220 1 Langer 55 2 of product, new kind of material. 3 Q. Did the first calidria you obtained 4 come from Union Carbide or were those samples in 5 '70/'71 after you had already done some looking at 6 it? 7 A. No, they came from Union Carbide, I'm 8 sure . 9 Q. What did you do, just call up Union 10 Carbide and say, "I'm interested in investigating 11 your product, could you send-me some samples"? 12 A. Essentially yes, but I think I wrote 13 to someone. I don't know whoever or whomever. 14 Q. What conclusions, if any, did you 15 draw from your first review of the calidria 16 asbestos ? 17 A. When I first looked at the stuff? 18 Q. Yes, in the early '70s; late '60s, 19 early '70s? 20 A. Well, you would have to go back and 21 look at some of my early papers. 22 Q. Well, for example, did you ever call 23 up Union Carbide and say something to them like, 24 "I've looked at your asbestos and I think the 25 fiber is a real health hazard to people using it"? DOYLE REPORTING, INC. (212)867-8220 1 Langer 56 2 A. I'm sitting here thinking. I may 3 have. I don't know. Would I have called someone 4 to say that? I must have discussed it at 5 meetings. 6 Q. Well - 7 A. Is it a health hazard? What do we 8 talk about at meetings. In my 1974 paper on size 9 distribution of asbestos minerals, which was 10 published in the Environmental Health 11 Perspectives, I talked about size distribution of 12 fibers and whether or not length was important, 13 and I said if length is important, then 14 anthophyllite should produce the most 15 mesotheliomas, followed by amosite, followed by 16 crocidolite, that is if length is the major 17 determinant of mesothelioma production. But it 18 didn't work like that. It worked in the opposite 19 20 21 22 23 24 Q. What your comment said was unis mignt 25 warrant investigation? DOYLE REPORTING, INC. (212)867-8220 1 Langer 57 2 A. Yes. 3 Q. My question was more narrow. Do you 4 remember in the late '60s or early '70s ever 5 having a conversation specifically with the people 6 at Union Carbide in which you said to them, in 7 words or to that effect, "I have done some 8 research on your asbestos and I think you've got a 9 real hazard here that you ought to be concerned 10 about"? 11 *A. No. 12 Q. Other than what you put in your 13 scientific papers that may have been published or 14 said at scientific meetings, did you have any 15 communication with anyone suggesting that the 16 Union Carbide calidria asbestos that you were 17 analyzing was a potential health hazard in the 18 factories or plants where it was being used? 19 A. I can't recall. I don't think so. 20 Q. All right. At least as we sit here 14 21 today, you don't recall ever doing such a thing? 22 A. I don't recall, no. 23 Q. And if you had ever done that, that 24 would be something, at least at that time, unusual 25 for your general practice, wasn' t it? DOYLE REPORTING, INC. (212)867-8220 1 Langer 58 2 A. Well, it was unusual for me. I'm not 3 so sure it was unusual for Irving Selikoff, but - 4 it was unusual for me to do that, yes. 5 Q. Did you ever go to Mr. Selikoff or 6 any other colleague at Mount Sinai between '68 and 7 ' 7 4 and say to them words to the effect that "I've 8 been looking at the calidria asbestos, short 9 fiber, and perhaps you should get the word out to 10 warn people about this"? 11 A. Maybe a little background without 12 going into the details of this. We were 13 interested in the fibers which were in the 14 mainstream of commerce with the greatest number of 15 applications. And the stuff from Coalinga was 16 going into things like floor tiles and ceiling 17 tiles and I don't think it concerned us very much. 18 So we were interested in construction products 19 coming out of the Manville deposits or the other 20 deposits from Canada, so our focus was there. 2 1 Q. Would it be correct to say, Doctor, 22 that you are not aware of anyone from Mount Sinai 23 during this period 1968 to 1974 going to Union 24 Carbide and saying something to the effect of, "We 25 have been looking at your calidria asbestos and we DOYLE REPORTING, INC. (212)867-8220 1 Langer 59 2 think it is a potential hazard in the plants where 3 it is being used"? 4 A. I don't have any knowledge of that, 5 no. 6 Q. That is what I asked you.You are 7 not aware of any such conversation? 8 A. No. 9 Q. Okay. All right. Let's look at what 10 I have earlier marked as Exhibit 2, just to be 11 compulsive and go in order. This is a copy of the 12 notice of your deposition? 13 A. Right. 14 Q. And you received a copy of that? 15 A. Yes . 16 Q. Okay. We will come: back to that a 17 little later. Let's talk about Exhibit 3, which 18 is your report in this case, is that correct? 19 A. Right. 20 Q. That is the report on your analysis 21 of the materials that you obtained from the KCAC 22 mine? 23 A. Right. 24 Q. This past July? 25 A. Yes . DOYLE REPORTING, INC. (212)867-8220 1 Langer 60 2 Q. And do you have any plans at this 3 point to -- let me back up. 4 You said you had completed the 5 laboratory work, is that correct? 6 A. Yes. 7 Q. But you said you might do some 8 additional work on what you described as the 9 nonchrysotile fibers? 10 A. Yes. This is just che analysis of 11 diffraction patterns. - 12 Q. That you've already done the 13 diffraction patterns? 14 A. I've already done the electron 15 microscopy. I have photographed the diffraction 16 patterns but I have not obtained the plates nor 17 the prints as yet. 18 Q. Will those plates of the diffraction 19 patterns help you to perhaps identify precisely 2 0 what minerals are in the sample? 21 A. Yes. 22 Q. Other than identifying those as to 23 date,unidentified minerals, is there any other 24 work that you plan on doing with respect to the 25 analysis of the samples taken from the mine? DOYLE REPORTING, INC. (212)867-8220 1 Langer 61 2 A. Probably not, no. 3 Q. Am I correct that in your -- backing 4 up, you had 12 different samples, is that right? 5 A. Right. 6 Q. And you also had some of the RG-100 7 pellets that had been given to you by Union 8 Carbide back in the early '70s? 9 ' A. I have RG-100, 144, 244. 10 Q. For purposes of this report, the only 11 pellets that you looked at though were the RG-100, 12 is that right? ' 13 A. That's right. 14 Q. Was there a reason you picked the 15 RG-100 and not one of the other pellets? 16 A. No. 17 Q. Are you aware of what grade of Union 18 Carbide pellet was used at Conwed? 19 A. I think it is 144. It may be 244. I 20 have some attributions to some dust counts. 21 Q. What is your understanding of the 22 difference between the Union Carbide grades 100, 23 144 and 244? 24 A. My understanding, there is a 25 different degree of processing and beneficiation. DOYLE REPORTING, INC. (212)867-8220 1 Langer 62 2 Q. What do you mean by beneficiation? 3 A. It is a general term of grading of 4 ore to concentrate of that which is being 5 extracted and that which is being discarded. 6 Q. So - - 7 A. It is a general term. 8 Q. So 244 would be "purer asbestos" than 9 100? 10 A. Well, make no mistake about it, these 11 are awfully pure. So that the degree of purity 12 would require another analytical study, if you 13 really want to characterize in terms of analytical 14 purity, but for our purposes, I believe it is 15 okay. 16 Q. Just generally that is your 17 understanding, that the RG-144 and 244 have 18 additional refining steps beyond the RG-100 to try 19 to remove so-called impurities? 20 A. That is my understanding. 21 Q. In terms of what you find in the ore 22 then, am I correct you would be -- you would want 23 to look at the RG-100 to be sure that what you 24 were looking for hadn't been removed in the 25 additional refining? DOYLE REPORTING, INC. (212)867-8220 1 Langer 63 2 A. I don't understand that question. 3 Q. if your point in doing the analysis 4 of these materials is to try to see what else is 5 in the product other than chrysotile asbestos, you 6 would want to look at the RG-100 because that 7 presumably has the most nonchrysotile objects or 8 materials in it? 9 A. I don't think it makes any 10 difference. It is like top grades of nytal 100, 11 200 and 300. There are some, minor differences 12 that they are interchangeable. Frequently they 13 are. So I am unimpressed with differences that I 14 see by optical microscopy so it didn't matter to 15 me. There was no selection on the basis that, 16 gee, this might have the most mineral A in it as 17 associated mineral. No, that didn't drive this 18 assay. 19 Q. I was just suggesting in terms of 20 being conservative, if you take the one that goes 21 through the least refining steps, you are 22 guarding, however slightly, on the side of making 23 sure that anything that is there you will find, 24 would that be correct? 25 A. No, that didn't enter into the assay. DOYLE REPORTING, INC. (212)867-3220 1 Langer 64 2 If I wanted to do an assay like that, I would have 3 ground up the host rock and looked at the host 4 rock rather than the ores. If that guided me - - 5 looking at this material, why would you want to 6 look at the host rock which is discarded in the 7 boulders and all of that sort of stuff. It is 8 kind of interesting if you are doing the genesis 9 of the ore deposit, but other than that, it is not 10 helpful. 11 Q. Was there any reason then that you 12 chose the RG-100 as opposed to the 144 or the 244? 13 A. I think I had most of that in the 14 laboratory. That was just available. And it 15 could also be RG-100, I think is mentioned in 16 several of these papers that I described to you 1 *7 aa i n DOYLE REPORTING, INC. (212)367-8220 1 Langer 65 2 Q. Are you aware that: people have been 3 analyzing this material for something like 100 4 years ? 5 A. Well, this is true. And I also would 6 offer the following piece of information, that 7 when the original prospectors went over that 8 deposit, they thought it was talc and not 9 asbestos. 10 Q. Did you find anything -- backing up, 11 you did find chrysotile asbestos in the samples? 12 A. Sure. 13 Q. Putting aside the chrysotile asbestos 14 for a moment, did you find anything in the samples 15 16 it 17 18 19 20 intergrowth structure of some kind which might 21 conceivably cause disease, but there is no 22 evidence of that either. So to answer your 23 question, the answer is not at this time, no. 24 There are some suggestions but I don't know. 25 Q. Let me see, I think I asked you this DOYLE REPORTING, INC. (212)867-8220 1 Langer 66 2 question in terms of pleural plaque but let me 3 refine the question a little bit. Setting aside 16 4 the chrysotile asbestos for a moment, did you find 5 anything in any of the samples that is associated 6 with asbestosis, lung cancer or mesothelioma in 7 humans ? 8 A. Anything else? 9 Q. Right. 10 A. In humans? 11 Q. Right. 12 A. Well, I don't want to get Union 13 Carbide nervous, but there is some chromite 14 magnetite, but I don't think that would be a 15 problem. 16 Did you find something? You are 17 asking me did I find something. I would have to 18 think of all of the minerals there and how many of 19 those are associated with disease. Is it 20 chrysotile, yes, okay, the amphibole asbestiform _ 21 materials are not there. Nemalite, experimentally 22 in animals, laboratory animals. Does that mean 23 that coalingite is also active? I don't think so. * 24 So chromite has produced diseases in certain 25 instances but this is an associated minor mineral. DOYLE REPORTING, INC. (212)867*8220 1 Langer 67 2 And I'm not even sure people inhale the thing. So 3 I would say, well, there is some -- probably not. 4 No. 5 Q. Let me ask you the question this way 6 then. Would it be your opinion that whatever 7 health effects are associated with calidria are 8 due to the chrysotile component as opposed to 9 anything else? 10 A. Yes. Probably yes. 11 . MR. WILL: Off the record. 12 (Discussion off the record) 13 Q. Doctor, in the course of preparing 14 this report. do you have any other data 15 compilation or notes of your analysis? 16 A. Sure. 17 Q. Did you bring that with you today? 18 A. No. 19 Q. What else do you have? 20 A. Well, I have all my laboratory notes 21 and the x-ray diffraction tracings and things like 22 that, and the reason I provided a summary report 23 is that I have not had time to give you all of the 24 details but that essentially is what the data will 25 support, that there is chrysotile there, there are DOYLE REPORTING, INC. {212)867-8220 1 2 3 4 5 6 7 3 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Langer 68 che other serpentine minerals present and there are these other minerals associated with serpentines. Period. That's it. Q. As far as you are concerned, is your analysis of the samples and the RG-100 consistent with the other analyses that have been published in the literature? A. Yes, generally so. Q. Prior to doing this particular piece of research for Mr. Brownson-, had you ever before done an analysis of ore from -- let me be careful -- material either processed or unprocessed from the KCAC mine? A. KCAC specifically. Q. Or -- from the pit, put it that way? A. Yes . Q. You mentioned you had looked at some of the Uni on Carbide samples that had been given to you in '68 or somewhere in that '68/'71 time f rame ? A. Right. Q. Did you later have occasion to get additional samples from either the mill or from the mine? DOYLE REPORTING, INC. (212)867-8220 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 Langer 69 A. I got some other samples,, yes, and my colleague Dr . Nolan got some samples. and he was involved in this litigation, I think. Q. Did you do anything to review the samples that Dr. Nolan got ? A. No . Q. Maybe I can do this a little less clumsily. I understand -- X know of two occasions when you have reviewed either processed or the raw ore. One would be in the '68 to '71 time frame? A. Something like that. Q. When you got samples from Union Carbide? A. Right, right. Q. The second would be this time for Mr. Brownson? A. Right. 1 Q. Okay, and you said there were some other times - - A. There had to be. Pe ople send me samples all the time, so I would say yes, there had to be other instances, sure. Q. Do you remember what the other instances were next with? DOYLE REPORTING, INC. (212)867-8220 1 Langer 70 2 A. No. I've looked at literally 3 hundreds of samples that people send me. They 4 send me samples from all over the country, what is 5 in this and so on and so forth, but -- so I'm sure 6 I've had an opportunity over the past 28 years to 7 look at other samples of this, sure. 8 Q. And the findings that you reached in 9 this case were, as far as you know, consistent 10 with all of your previous findings? 11 A. I think so, yes'. 12 Q. On page 1 of your report, which shows 13 it was faxed to me, it has been faxed so many 14 times it keeps growing as people put cover sheets 15 on, but in any event, the title page about 16 three-quarters of the way down the page, you say 17 that some fibers displayed anomalous blue-gray 18 birefrigence. 19 Q. First of all, what is blue-gray 20 birefrigence? 21 A. When minerals are examined by means 22 of polarized light, microscopy, the minerals, 23 those which are crystalline, display colors which 24 are the product of light entering the crystal and 25 being affected by the mineral's crystal structure. DOYLE REPORTING, INC. (212)867-8220 1 Langer 71 2 And different minerals display different colors as 3 a function of their chemistry and structure. This 4 particular color is not usually found with 5 chrysotile. 6 Q. That is why you said it was 7 anomalous? 8 A. Meaning that instead of a straw 9 yellow color, like this pad, it was darker and 10 bluish, generally a color not found for this 11 particular material. 12 Q. ' Did you associate the blue-gray 13 birefrigence with any particular mineral or 14 substance? 15 A. Generally in thicker specimens, it is 16 a sign of straSx that the mineral was subjected to 17 some force, external to it, and the crystal 18 structure deformed in some way. 19 Q. Would this be then an indicator of 20 the geologic history of that area? 21 A. It is possible. Since I found 22 associated features in a feldspar, I would assume 23 that this is related to some of the tectonic 24 forces . 25 Q. Am I correct that this blue-gray DOYLE REPORTING, INC. {212)867-8220 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Langer 72 birefrigence was in the chrysotile fibers themselves ? A. In some. Q. In some of them, not all of them? A. Some of them. It was just an observation. Q. Over on the second page you mention that you analyzed the RG-100. A. Right,, Q. And then you talk about the aliquots? A. Yes. Q. What exactly is an aliquot? A. That is a subsample. You have the material and you select portions of it to analyze, not the whole thing. Q. How many subsamples of the RG-100 did you analyze? A. Looked at by polarized light -- Q. Yes. A. Maybe up to 10. Q. How about of the ore samples from the pit? A. Two or three each. Q. So since there were 12 samples, you DOYLE REPORTING, INC. (212)867-8220 1 Langer 73 2 probably had 36 aliquots that you would look at? 3 Something like that? 4 A. Give or take. 5 Q- Somewhere between 24 and 36? 6 A. Probably more, but -- 7 Q. Okay. And you indicated that under 8 polarized light microscopy, you did not observe 9 any amphibole material? 10 A. That's correct, but there was one 11 fragment that could have been an amphibole. 12 Q. Let me ask you about that, that was 13 a - - 14 A. Nonasbestiform. 15 Q. Meaning it was not fiberous? 16 A. Correct. A fragment. "" " 17 Q. And you describe it as a single 18 crystal? 19 A. Yes . 2 0 Q. Were you able to identify what that 21 mineral was? 22 A. No. 23 Q. Was that one of the x-ray diffraction 24 plates that you are waiting -- 25 A. No, no. DOYLE REPORTING, INC. (212)867-8220 1 Langer 74 2 Q. Did you attach any particular 3 significance to the appearance of that fragment? 4 A. No. 5 Q. How were you able to identify this 6 fragment as a possible amphibole under light 7 microscopy? 8 A. This is the technique. A powder is 9 immersed in some general mounting medium because a 10 powder by itself will just refracture light from 11 its boundary. You want to compare the properties 12 of light coming through this crystal with the 13 properties of light which surrounds it. So we use 14 immersion oils with known indices of refraction, 15 known densities. 16 Light behaves in a certain way. 17 Light enters the medium and is slowed in some 18 fashion. Velocity of light in air, about 1.00. 19 The velocity of light in water is 1.33. So it is 20 slowed down approximately 33 percent. When light 21 enters minerals, depending on the crystal 22 structure and the chemistry, light slows and 23 breaks into component parts according to these 24 properties of the mineral. 25 I have a collection of mineral oils, DOYLE REPORTING, INC. (212)867-8220 1 Langer 75 2 a standard set of oils which change in increments 3 of 0.002 units, let's call them units. These 4 immersion oils range from approximately 1.400 to 5 approximately 1.800. The minerals which have high 6 density which have iron in the structure, like for 7 example olivine and pyroxene have high indices of 8 refraction. 9 When I scan a specimen, I use an 10 immersion oil which will allow me to visualize, 11 for example, chrysotile. My normal scanning oil 12 has an index of refraction of 1.515. Now 13 chrysotile has, for example, one of the indices 14 parallel -- vibrating to the long fiber direction. 15 Approximately 1.556. Now the difference between 16 1.556 and the immersion oil 1.515 allows me to 17 visualize chrysotile very well because there is a 18 difference in index of refraction, and it means 19 that I can, that the mineral has what is known in 20 the optical crystalography field as high relief. 21 There is a marked difference in the 22 transmission of light in these two materials and 23 so there is a contrast. There are edge effects. 24 Now if you scan a field of a powder at 1.515 and 25 you see a mineral which looks like a mountain, it DOYLE REPORTING, INC. (212)867-8220 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 Langer 76 looks like a grain which stands out very high, it is either very much lower in index than the mounting oil or very much higher. Now given the assemblage of minerals, I assume that I was not looking at cristobalite or opal but rather I was looking at a crystal which was a ferromagnesium mineral which made up the serpentine host. Now when it is rounded with high birefrigence, slightly altered serpent ini zed, it is probably olivine of some form. If it has very high relief but yet has a certain pattern of cleavage which are more rectagonal, rectangular, I made up a word, rectangular, this is more characteristic of pyroxenes. Now I can't analyze the materials I'm looking at when immersed in an index oil 1.515. I have to take another aliquot powder and use a different liquid and hope to find a similar grain to measure the characteristics. Sometimes you see it, sometimes you don't. What looked like a fragment of amphibole based on certain extinction characteristics, when the crystal became darkened when viewed between crossed Nichols, that is the DOYLE REPORTING, INC. (212)067-8220 1 Langer 77 2 name of a prism, and has certain characteristics 3 of amphibole, one has to measure the indices of 4 refraction. If you find other pieces like it and 5 it is more frequent or more abundant or occurs 6 with greater concentration, you can do this. But 7 when that is the only fragment you found, you 8 cannot. So it remains unknown. The other 9 minerals were more, behaved better. They were 10 there in higher concentration and it allowed me to 11 perform more analytical work. 12 Q. Let me see if I can ask a shorter 13 question here. ' 14 A. Please. 15 Q. All right. On page 2, you say that 16 you found this in one specimen number one, y-ou 17 found this fragment? 10 A. That's right. 19 Q. You were not able to find a similar 20 fragment in any of the other specimens? 21 A. That's correct. 22 Q. Because you were not able to find a 23 similar fragment in other specimens, you were 24 unable to do the necessary test to identify the 25 mineral? DOYLE REPORTING, INC. (212)867-8220 1 Langer 78 2 A. Yes. 3 Q. Now, my question was based upon what 4 you were able to observe through the optical 5 microscope, of this unique fragment that you 6 found, you felt it was some type of amphibole? 7 A. It was a good probability. 8 Q. And what was it that made you feel 9 that was a good probability? In other words, what 10 about the characteristics of that particular 11 fragment? ' 12 A. It was not olivine because it did not 13 have the very high relief. It was not pyroxene 14 because it did not display any of the pyroxene 15 cleavage characteristics and it looked like what I 16 frequently see as fragments of amphibole. A 17 cleavage fragment. 18 Q. Do you have any way of identifying 19 which amphibole it was like? 2 0 A. No. It could have been a fragment of 21 pyroxene viewed on edge. That is a possibility 22 too. But - - 23 Q. Could have been a lot of different 24 things? 25 A. Well -- a lot. Well, it could have DOYLE REPORTING, INC. {212)867*8220 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 Langer 79 been - - Q. Some? A. Some. One of 20 minerals or one of 10 minerals, something like that. Q. How many different minerals are there in the amphibole family? A. You mean discrete amphibole species? Q. Yes . A. I don't know. There could be a hundred. There could be 150'. Q. All right. A. I mean I could list maybe 20 or 25 principal ones, but then there are, you know. oddball things that people find somewhere. One of something, yes . Q. Langerite? A. Yes, Brownsonite. Q. From page 2 to 3, you say, "It is important to note that fibers are observed within the specimens which exceed 100 microns in length." A. Yes . Q. All right. Now, are those fibers in the RG-100 specimens or in the ore specimens? A. Okay, the longer fibers were found in DOYLE REPORTING, INC. (212)867-8220 1 Langer 80 2 the ore specimens. That is true. 3 Q. I'm just trying to figure out to 4 which specimens that sentence refers. Does it 5 refer to ore or RG-100? 6 A. Since it's a separate paragraph and 7 not in the RG-100 paragraph, there are fibers 8 found in matrices of serpentine that are greater 9 than a hundred microns in length. This is true. 10 Q. Well, over on the very first page, 11 you indicate that at 100 times magnification, 12 several of the finer bundles approached 1 13 millimeter in length? 14 A. Where do I say that? 15 Q. About halfway down. 16 A. Tha?t * s right. Yes, -. 17 Q. All right, so that - 18 A. These are the 12 specimens in. the 19 pit. Some of the fibers approached a millimeter. 20 Q. Okay, so does that mean then that the 21 reference over on page 2 to 3 about 100 microns 22 which would only be about one - hundredth of a 23 millimeter - - 24 A. That would be in the ore specimens as 25 well. DOYLE REPORTING, INC. (212)867-8220 1. Langer 81 2 Q. Right. 3 A. Right. 4 Q. If - 5 A. Actually the short fibers were in the 6 muds that were collected. 7 Q. When the fiber bundles in the ore 8 that were approximately one millimeter in length 9 were processed at the mill, would you expect them 10 to break up and shorten? 11 A. Probably, yes. 12 Q. Are those fiber bundlesmade up of 13 smaller fibriles? 14 A. Yes. 15 Q. What is it that holds thefibriles 16 together, what force - 17 A. One of the great mysteries of life, 18 isn't it. Whatever the forces are, the materials 19 are thought to be essentially the magnesium 20 silicate material itself, which is really some 21 substance that we call sepiolite, which is a 22 magnesium silicate hydrate which may or may not be 23 crystalline, or the fiber bundles are packed 24 together in such a way that their surface 25 properties interact with each other, but those DOYLE REPORTING, INC. (212)867-8220 1 Langer 82 2 forces are not very great, so -3 Q. All right. Over on page 3, you are 4 talking now about the x-ray diffraction, and you 5 say that, "The following minerals were detected," 6 and you say chrysotile, and there is a 1 parenthesis, "Predominantly the 2M polytype." 8 A. Yes. 9 Q. What does that mean? 10 A. That connotes the essential crystal 11 structure. When you compare the pattern you 12 obtain with the available extra data in the 13 literature, this pattern conforms to 2M. It is a 14 monoclinic form. It is a stacking reference.. How 15 the minerals hung together. 16 Q. Then down at the bottom of that 17 paragraph, you say that when you looked at the 18 RG-100 specimen you found chrysotile, lizardite, 19 which is another serpentine. 20 A. Yes. 21 Q. And antigorite, which isanother 22 serpentine. 23 A. Yes. 24 Q. And brucite, that is another - 25 A. That is a magnesium hydroxite. ' DOYLE REPORTING, INC. (212)867-8220 1 Langer 83 2 Q. And coalingite? 3 A. Yes, right. 4 Q. What family is the coalingite in? 20 5 A. Coalingite is an alteration product 6 of brucite. 7 Q. What percentage of the material by 8 weight would you say was brucite or coalingite? 9 A. Small. Trace. Barely detectable. 10 Q. In terms of the x-ray diffraction 11 analysis, what were your detectable limits? 12 A. Well, given this matrix, maybe a half 13 of a percent or a little less. Just kicking it at 14 a thousand watts -- if I had a 2,000-watt 15 generator we would detect lower. We would wallop 16 the material. The RG-100 we are running 95 or 17 better chrysotile. 18 Q. But the detection limits were about 19 half of 1 percent? 2 0 A. Yes, I would -- yes. I'm shaking my - 2 1 head. You admonished me not to but I'm shaking my 22 head. Yes, it is about that. 23 Q. You are satisfied that if there were 24 amphibole fiber in this material, you would have 25 found it? DOYLE REPORTING, INC. (212)867-8220 1 Langer 84 2 MR. BROWNSON: I object to the form 3 of the question. In these samples or in 4 the entire mine? 5 MR. WILL: I'll rephrase the 6 question. 7 Q. Doctor, am I correct you are 8 satisfied if there had been amphibole fibers in 9 the samples or in the RG-100, you would have found 10 it? 11 A. I think they are less than the levels 12 of detection if present. 13 Q. And based on the best science, if you 14 will, that you could do, you were not able to find 15 them, is that correct? 16 A. That's correct. 17 Q. Down at the bottom of page 3, you 18 refer to something called serpentine polymorphs? 19 A. Yes. 20 Q. Polymorph means manystructures or 21 many - - 22 A. A polymorph in thephysical or 23 chemical meaning is a term of the same chemistry 24 but a different structure, and therefore it has 25 different properties. Like silical polymorphs. DOYLE REPORTING, INC. (212)867-8220 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 Langer 85 Q. By the way, has Mr. Brownson given you any other papers or test data that suggests that anyone has ever found fiberous amphibole in any material, whether ore or pellets, taken from the Coalinga mine? A. No. Q. Over on page 4, you are talking about analytical electron microscopy. A. Yes. Q. And you said thatit was decided based on resources that only the final ore product would be examined in detail? A. Right. Q. I assume that means that you didn't have enough money to do all of it? A. Well -Q. Or Mr. Brownsondidn't. A. Well, we canextend this project into two years and have post-docs work on it to look at all those specimens by analytical EM. It is a time-consuming, resource - consuming, costly enterprise. And I -- this is not at Mr. Brownson's direction, by the way. Q. Okay. DOYLE REPORTING, INC. (212)867-8220 1 Langer 86 2 A. I felt looking at the specimens by 3 polarized light microscopy that if I found 4 amphiboles in the part of this ore which is 5 discarded, what in the hell would that -- what 6 would that mean. It wouldn't mean very much. 7 Then going one step further, given materials that 8 would be processed through the mill and the ore, 9 let's look at it by extra diffraction and let's 10 see what that shows, and it basically shows that 11 much of the debris is taken out. Then when you do 12 analytical electron microscopy, which is an 13 investment of these resources, look at the -- look 14 at some product that might have entered that 15 workplace. 16 Q. O.K. 17 A. After everything is removed and 18 discarded, what is left. What would an aerosol 19 look like. 20 Q. What actually went to Conwed, in 21 other words? 22 A. Presumably. Right. 23 Q. In the next paragraph down, you 24 mention that the diffraction patterns are 25 consistent wi th standards with clinochrysotile DOYLE REPORTING, INC. (212)867-8220 1 Langer 87 2 A. Yes . 3 Q. What is clinochrysotile? 4 A. That is the monoclinic form. The 2M 5 form. 6 Q. Now on the bottom paragraph on page 7 4, you reference that occasionally you observed an 8 electron-dense mineral fiber with an aspect ratio 9 greater than 15 to 1? 10 A. Right. 11 Q. And you said that morphologically - 12 that means structurally? 13 A. Form. 14 Q. -- formwise, this mineral resembles 15 an amphibole? 16 A. Right. ' 17 Q. What did you mean by that? 18 A. It just resembles one. It looks 19 like. 20 Q. Did you take a picture of that? 21 A. Yes. 22 Q. Do you have that with you? 23 A. I think so. 24 (Handing) 25 A. These are some of the preliminary DOYLE REPORTING, INC. {212)867-8220 1 Langer 88 2 ones. This is the selected area diffraction 3 pattern (indicating). I said an aspect ratio of 4 greater than 15, correct? 5 Q. Yes. 6 A. That aspect ratio of that one is 19 7 to l. 8 MR. WILL: Off the record. 9 (Discussion off the record) 10 (Whereupon, photographs marked 11 Langer Exhibits 4-A, 4-B and 4-C for 12 identification, as of this date.) 13 (Recess taken) 14 BY MR. WILL: 15 Q. Dr. Langer, let me show you what we 16 have marked as Exhibit 4-A. Can you tell me what 17 that is? 18 A. This is a print, a photomicrograph 19 taken on an electron microscope of one of the 20 nonchrysotile fibers found in this specimen. 21 Q. Okay. And that was -- you indicated 22 that has an aspect ratio of about 19 to l? 23 A. Correct. 24 Q. O.K. 25 A. Length to diameter. Yes. DOYLE REPORTING, INC.( 212) 867 - 8220 1 Langer 89 2 q. All right. And that was done in your 3 lab? 4 A. Yes - - no. No. 5 Q. Sorry. Where was it done? 6 A. This was taken on the instrument in 7 the department of pathology up at Mount Sinai. 8 Q. So you took the samples up there to 9 have the photomicrographs? 10 A. I took the grids up there. Right. 11 Q. I show you what- has been marked as 12 Exhibit 4 -B. Can you identify that for me? 13 A. 4-B is a selected area electron 14 diffraction pattern obtained on this fiber. 15 Q. Now, what is that supposed to show? 16 A. The beam of electrons, the beam 17 passes through the crystal, the crystal -- the 10 atoms in the structure interact with this beam of 19 electrons. The electrons are scattered as x-rays 20 are scattered, and the scattered electrons form 21 patterns which conform to the structure of the 22 material. 23 Q. Okay. And then by comparing those 24 patterns to the known patterns of other materials, 25 you can try to identify them? DOYLE REPORTING, INC. (212)867-8220 1 Langer 90 2 A. Yes. You can do comparisons or you 3 can actually measure the spaces between those 4 particular reflections and generate information 5 concerning the actual interatomic space action 6 present in the material. 7 Q. Let me show you what we have marked 6 as 4 -C. What is that? 9 A. 4-C represents an energydispersive 1 0 x-ray spectrum obtained on this particular fiber. 11 It shows the chemistry, the -essential chemistry of 12 the fiber. 13 Q. Is there any way of saying that this 14 long fiber isn't simply a number of chrysotile 15 fibriles still adherent to each other? 16 A. Probably isn't. 17 Q. Why is that? 18 A. The diffractionpattern shows that it 19 is not a chrysotile pattern, although superimposed 20 in here there are some reflections which might 21 eventually be indexed as a chrysotile pattern, but 22 it is more than chrysotile. This seems to be a 23 mixture of structures and the energy dispersive 24 x-ray spectrum. The chemistry shows that the 25 magnesium signal is too low for chrysotile. DOYLE REPORTING, INC. (212)867-8220 1 Lange r 91 2 Q. Okay. Based on che x-ray spectrum or 3 the diffraction picture, have you been able to 4 identify that material? ' 5 A. Not yet. 6 Q. Okay. 7 A. I've spent another day just on this 8 particular s tuff and I have not been afforded the 9 opportunity to examine the plates in detail. 10 Q. All right. There are two hand-drawn 11 black arrows - - 12 A. Right. 13 Q. -- on Exhibit 4-C? 14 A. Correct. 15 Q. What are those for? 16 A. Those mark out what is the presence 17 of two trace elements. Elements present in small 18 concentrations. The arrow at approximately 640 19 KEV -- actually it is 6,400 electron volts is 20 probably iron, and the pattern, the small peek at 21 approximately 590 or 5,900 electron volts may be 22 manganese. So there are traces of other elements. 23 Q. Are those traces of iron and 24 manganese significant in identifying this 25 material? DOYLE REPORTING, INC. (212) 867- 0220 1 Langer 92 2 A. Iron you would expect in this 3 particular material. Manganese, if that is 4 manganese, it could be some heavy metal, that is 5 the majority of the spectrum lies outside of this 6 particular region. 7 Q. You said that the electron 8 diffraction pattern suggests a complex structure? 9 A. Right. 10 Q. Is that because of the superimposed 11 chrysotile pattern? - 12 A. It could be. 13 Q. Anything else about the pattern that 14 you thought was complex? 15 A. Other than the fact I can't 16 immediately identify what it is, yes. 17 Q. Okay. Are you familiar with the 18 x-ray diffraction pattern of, say, crocidolite? 19 A. Yes. 20 Q. How about tremolite? 21 A. Yes. 22 Q. How about amosite? 23 A. Yes. 24 Q. Does this extra diffraction 25 pattern - - DOYLE REPORTING, INC. (212)867-8220 1 Langer 93 2 A. For x-rays, no, I didn't identify 3 those peaks either. By selected area diffraction, 4 no. They are not and the chemistry is certainly 5 not. 6 Q. You mention in your report something 7 that you call a talc bowl. What is a talc bowl? 8 A. That is a structural mixture of talc 9 and an amphibole, generally anthophyl1ite in which 10 there are regions of different mineral in the same 11 ribbon, in the same fiber. . 12 Q. You were suggesting this may just be 13 a structure that has mixed minerals in it? 14 A. That's right. It is possible. 15 Q. You didn't find talc in this 16 particular fiber, did you? 17 A. No. Actually talc would be a good 18 guess because the magnesium signal for talc is 19 about half of that of chrysotile. 20 Q. You mention in your report the 2 1 magnesium silicon ratio? 22 A. Right. 23 Q. And then you give a ratio for 24 chrysotile of 0.75 to 0.85? 25 A. That is about right. DOYLE REPORTING, INC. (212)867 - 8220 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 Langer 94 Q. What ratio is that? A. Magnesium to silicon. Q. But is that number of atoms, weight - A. Those are the number of x-rays generated on the specimen. You can recalculate on the basis of a first order approximation the atomic percent based on that particular x-ray count. Q. And you say the' ratio then of magnesium to silicon, it is that there is approximately three - fourths to 85 percent magnesium x-rays to silicon x-rays? A. That is exactly what it states, yes. It implies little else other than the fact that the elements are present in approximately equal atomic weight percent. Approximately. Q. And when you did the magnesium silicon ratio for this fiber here, you got a considerably lower percentage? A. Yes. That's right.Correct. Q. When you talk about a discredited serpentine mineral, what do you mean by that? A. There is a convention followed that DOYLE REPORTING, INC. (212)867-8220 1 Langer 95 2 every claim of a new mineral has Co be - - the data 3 has to be presented to some body of mineralogists, 4 either the Mineralogical Society of American or 5 the International Mineralogical Commission or 6 whatever, and the data are presented and people 7 determine whether or not these are distinctly new 8 minerals or whether they are variants of what 9 exists previously or what is known. 10 And the problem in the old 11 nomenclature, there must have been 50 different 12 serpentine minerals. No one used 13 electronmicroscopes because it was not a tool 14 routinely used by mineralogists, but bulk 15 techniques were used to characterize specimens. 16 Bulk chemistry, meaning a whole specimen was 17 analyzed chemically or x-rayed a fraction or 18 something else, and frequently minerals with names 19 like Deweylite and picrolite and Stevensonite and 20 so on were found to be mixtures of chrysotile and 2 1 lizardite, chrysotile and antigorite, antigorite 22 and lizardite. So many of these minerals have 23 been subsequently reevaluated with newer 24 techniques, and these are mixtures, these are not 25 separate entities. So they are discredited. Like DOYLE REPORTING, INC. {212)867-8220 1 Langer 96 2 arnosite. 3 Q. What did you mean by a discredited 4 mineral? ' 5 A. The mineralogists are asked not to 6 use the term anymore because it is something else. 7 Q. So this large fiber may be one of 8 these conglomerate structures? 9 A. Exactly. I just don't know that yet. 10 Q. Okay, but it may be? 11 A. It may be. 12 Q. In your opinion, is the fiber in the 13 photograph Exhibit 4-A a different material than 14 the crystal that you observed in specimen number 15 1? 16 A. Probably is. 17 Q. Do you have an opinion on whether 18 there is any significance for the health of people 19 using RG-100 to the presence of that fiber in 20 picture 4-A? 21 A. Don't know. 22 Q. How long did it take you to do all of 23 the analysis of the -- of all of the specimens? 24 Number of hours? 25 A. I don't know, it has been on and off. DOYLE REPORTING, INC. (212)867-8220 1 Langer 97 2 I do the polarized light microscopy and the x-ray 3 diffraction and I am focusing on the TEM. My 4 colleague generated the aerosol and we are having 5 a student measure under this, under the 6 supervision of Dr. Nolan. My input, in total? 7 Q. Yes. 8 Maybe I should ask you the 9 question - - 10 A. Maybe 40 or 50hours. 11 Q. How many man-hours or person-hours 12 all together? 13 A. That - - 14 MR. BROWNSON: All together for this 15 analysis? 16 MR. WILL: Yes, of this, analysis to 17 this point. 18 A. I believe Dr. Nolan is going to bill 19 separately for his hours involved in the 20 generation of the aerosol and so on and so forth. 21 My involvement may be 50 hours total. 22 Q. And what rate do you charge for your 23 consulting work? 24 A. I charge $225 an hour for background 25 work like this. DOYLE REPORTING, INC. (212)867-8220 1 Langer 98 2 Q. Different rate for testifying? 3 A. $275 an hour for a deposition and 4 $325 an hour for trial testimony. 5 Q. This background work, does it include 6 literature reviews, laboratory work, visiting mine 7 sites or field sites? 8 A. Yes. And what comes free is all my 9 thoughts as I'm driving down in and out of work. 10 That is sort of free. There is no egg timer in 11 the car. - 12 Q. Those are like mine. 13 A. That is a freebie. 14 MR. WILL: Why don't we break for 15 lunch. 16 (Lunch recess: 12:51 p.m.) 17 18 19 20 21 22 23 24 25 DOYLE REPORTING, INC. (212)867-8220 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 99 Afternoon Session 1:50 p.m. ARTHUR M. LANGE R, previously sworn, resumed: BY MR. WILL: Q. Before we took a lunch break we were talking about your report briefly on the analysis of the samples. Am I correct that in terms of your analysis of the samples from the mine and the RG-100 samples, that the only thing that you have left to do at this point is whatever work you are going to do to try to analyze that fiber that is shown in Exhibit -- or not analyze - A. Similar fibers. Q. -- that or similar fibers to that in what is 4 - A ? A. Yes. Q. Other than that, yourwork with the samples is finished? A. Pretty much, sure. Q. Well, I ask you because this is my one chance to ask you about that because anything you do after today - A. i'll tell you about it if I do it DOYLE REPORTING, INC. (212)867-8220 1 Langer 100 2 through Mr. Brownson. 3 Q. All right. 4 You mentioned that you have at your 5 lab the raw data, I guess, if you will. 6 A. Right. 7 Q. That was generated from your analysis 8 of the samples. 9 A. Right. 10 Q. Do you have anything else that you 11 didn't bring with you today that you have 12 collected or prepared forpurposes of your 13 testimony in this case? 14 A. Well, yes, the actual reprints of the 15 papers that I read as background. 16 Q. Okay. 17 A. Correct. 18 Q. So you have somewhere a file with 19 those reprints in them? 20 A. Yes. 21 Q. All right. Other than that file and 22 the raw data from the analysis, is there anything 23 else that you have been given or you have 24 collected for this case that you did not bring 25 with you? DOYLE REPORTING, INC. (212)867-8220 1 Langer 101 2 A. Yes. X mean I look up papers which 3 have been published in the proceedings of 4 conferences which have been published in other 5 j ournals. 6 Q. But if you make a copy of those/ you 7 would put them with the others? 8 A. If I make a copy of them, yes. 9 Q. What I'm asking you is do you have 10 any other materials beyond whatever copies of 11 papers you may have and the raw data from the 12 analysis of the samples that relates to this case 13 that you have not brought with you today? 14 A. Well, there are the standard mineral 15 specimens that are part of my collection in the 16 laboratory. Ore specimens from other parts of the 17 world, the UICC collection. 18 Q. I mean things you gathered just for 19 this case, things that you - 20 A. I don't think so. I can't recall, 21 but as I sit here today I can't think of anything. 22 Q. Okay. Now, what you brought with you 23 today is a small manila file that has some 24 information in it, is that correct? 25 A. Yes. DOYLE REPORTING, INC. {212)867-8220 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 Langer 102 Q. And Chen you brought photocopies that are in three different packages with rubber bands around them? A. Yes. Q. All right. We'll take the thickest of the packages, and that is copies of Union Carbide dust counts, is that correct? A. Yes. Q. And are all of these in the thicker packet from the King City plant? A. I believe so, yes. Q. And I'lljust indicate for the record that they are King City dust count dated February 3rd, 1978, UCC plenum test, 10,903 dust count, 5/12 and 7/26/82. There is an asbestos count -- dust count. King City California dated April 19, 1977. There is a King City NIOSH sample dust count, January 25 through 27 of '83. There is a dust count, King City, California, May 2 of '78. A dust count dated December 11, 1974. A dust count dated March 15, 1979. A dust count dated April 19 through 20 and 25 through 26, 1978. Something called residential dust count. King City, DOYLE REPORTING, INC. (212)867-8220 1 Langer 103 2 California, April 21 through 22, 1981. UCC plenum 3 tests, dust count mill tailings, May 12th, 1982. 4 A dust count, March 23 of '77. A 5 dust count of May 2 , 1978. A dust count of - - I 6 guess this is another copy of the residential dust 7 count, April 21 and 22 of 1981. There is another S dust count apparently dated ceiling counts 9 performed on short-term samples obtained at King 10 City on April 19, 20, 25 and 26 of 1978. And the 11 last item in the packet is a- memo dated March 25, 12 1983 with attached asbestos fiber counts for 13 samples from King City mill collected on February 14 14, 1982. Is that right? 15 A. Sounds right. 16 Q. The second package of materials you 17 have has a label on it that says "Conwed," is that 10 right ? 19 A. Yes. 20 Q. And there is a copy of the deposition 21 of Edward Kleber taken in the case of James 22 Manisto on February 13, 1989, is that right? 23 A. Yes. 24 Q. Then attached to it are some Union 25 Carbide documents marked asexhibits at that DOYLE REPORTING, INC. (212)867-8220 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Langer 104 deposition? A. Right. MR. WILL: Off the record. (Discussion off the record) Q. And the third package of material are dust counts for other Union Carbide customers, is that correct? A. Yes. Q. Those are Southern Imperial Coatings, New Orleans, Louisiana, November 20, 1974, RUCO, Inc. of Meriden, Kansas, dust count of March 7, 1977. RCA Rubber Company of Akron, Ohio, dust count file, no date on the cover of that one. And REN Plastics in Lansing, Michigan, dust count of October 28, 1975. And finally Resin Coatings, dust count of July 30, 1973. Is that right? A. That sounds correct. Q. Okay. How wasit that the other - the dust counts for other customers were selected, do you know? A. NO. Q. Were those given toyou by Mr. Brownson? A. Yes. DOYLE REPORTING, INC. (212)867-8220 1 Langer 105 2 Q. Did he tell you that there were 3 several hundred other dust counts? 4 A. Yes . 5 Q. Is he planning to have you review those? 7 A. I believe so, yes. 8 Q. When you get around to it. 9 A. Well, you are looking at a lot of 10 documents. If you take the numbers out of the 11 tables,'you can make a large table, you get a 12 better understanding of what is going on, so I 13 think it is important to do that. 14 Q. You said if you made a large table 15 showing the dust counts from various plants, you 16 could get a better idea of what was going on? 17 A. Sure. 18 Q. Okay. But in order to know what the 19 dust counts were in a particular plant, you would 20 have to do air sampling in that plant while the 21 product was being made? 22 A. That would be best. 23 Q. Because the amount of dust released 24 in any particular plant depends on a host of 25 site-specific factors? DOYT.F REPORTING. TNC- {212)667-8220 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 Langer 1 06 A. Yes * Q. Do you know for purposes of your testimony in thiscase, what purpose, if any, would be served by doing this large collection of data from all of the different plants? A. Yes. Q. What purpose would that be? A. That purpose would be that which allows one.to focus on the relative degree of manipulation of a product and whether or not a certain product liberates dust. Q. So the purpose of looking at these is to reach some conclusion about whether or not use of the pellets produces dust? A. That's right. Q. Now, would that give you a basis for making a comparison as to whether it produces more or less dust than, say, a similar amount of asbestos that came in bags but was not pelletized? A. I'm not sure. Q. Given the same operation, would you expect pelletized asbestos such as Union Carbide provided to be more or less dusty than an equivalent amount by weight of asbestos that was DOYLE REPORTING, INC. (212)867-8220 1 Lange r 107 2 unpe11etized? 3 4 5 6 7 8 9 10 Q. By friable, you mean they release 11 fibers with finger pressure? 12 A. That is normally how it is defined by 13 EPA, but friable is a term used in the Union 14 Carbide documents. 15 Q. Well, do you know how they meant 16 friable when they used it in their documents? 17 A. I would think that friable would mean 18 crumble to the touch of the hand. 19 Q. That is the EPA definition? 20 A. That is the general mineralogical, 21 geological definition too. 22 Q. When you use friable in this context, 23 do you have a different definition? 24 A. No. 25 Q. If the operation involved is simply DOYLE REPORTING, INC. (212)867-8220 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 Langer 108 taking a bag and dumping it into a tank, if you will, with a wet solution in it, would you expect that operation to be more or less dusty if pellets are used as opposed to just loose fibers? A. That is a different question. The purpose of pelletization is to control dust. One has to determine what the -- how these bags were handled and how much manipulation the bags went through to determine whether or not there is dust which exists somewhere in that bag. Since these pellets rub against each other, suffer a disaggregation when impacted physically with something, but generally speaking, one would have to measure that. One has to measure that. Q. Okay. You are aware of measurements that were taken in the Conwed plant at the time when Union Carbide asbestos was being used there in the Conwed plant? A. In the Conwed plant? Q. Yes. A. No. Q. You've not been shown that information? A. There are no Conwed data there. I'm DOYLE REPORTING, INC. (212)867-8220 1 2 3 4 5 6 7 e 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Langer 109 looking at Mr. Brownson pointing to the study. MR. BROWNSON: I'm not going to answer the question but you can go through them and look. MR. WILL: We just went through it. I don't remember if there was attached to Kleber's - THE WITNESS: Hold it a second. Here we have it. Seek and ye shall find. A. Yes. MR. GERSON: Off the record. (Discussion off the record) Q. You see in Kleber's deposition, there is a report of dust counts made at the Conwed plant when Union Carbide asbestos was being used? A. Yes. Q. And am I correct you had not focused on those before right now? A. Well, I just read too much. There was just too much material. Obviously -- Q. Okay. A. Anyway. Q. Are you aware of any dust counts that DOYLE REPORTING, INC. (212 ) 867 - 8220 1 Langer 110 2 were taken at the Conwed plant when non-union 3 Carbide asbestos was being used in the operation? 4 A. No. 5 Q. Do you have any way, then, of 6 comparing whether use of the pelletized product in 7 the Conwed operation was more or less dusty than 8 use of nonpelletized asbestos would have been? 9 A. No. 10 Q. Were you aware thatunion -- that 11 during this period of time when Conwed was 12 purchasing asbestos from Union Carbide, that Union 13 Carbide made both pelletized - - sold both 14 pelletized and nonpelletized asbestos? 15 A. No. 16 Q. Do youknow whosedecision it was to 17 get the pelletized asbestos for the Conwed 18 operation? 19 A. No. 20 Q. You indicatedthat, toyour 21 understanding, pelletization was designed to 22 control dust? 23 A. Yes. 24 Q. All right. Thegeneral theory being 25 that a pelletized product will emit less dust than DOYLE REPORTING, INC. (212)867-8220 1 Langer ill 2 the same product not pelletized? 3 A. Yes. 4 Q. In the case of calidriaasbestos, is 5 there any reason to believe that that general 6 proposition would not hold true? 7 A. No. 8 Q. In terms of the materials that you 9 have been provided by Mr. Brownson, other than Che 10 Kleber deposition and the materials that we have 11 gone through here today, is there anything else 12 that he has given you? 13 A. Not yet, no. I mean there is some 14 promissory note that I'm going to look at all 15 these other data sets. 16 Q. Okay. Did you have everything you 17 felt you needed in order to make your analysis of 18 the samples that you obtained from the mine? 19 A. I don't understand the question. 20 Q. All right. Let me put it this way. 21 Was there anything that you did not have that you 22 wished you had in order to do your analysis of the 23 material? 24 A. Yes. 25 Q. What was that? DOYLE REPORTING, INC. (212)867-8220 1 Langer 112 2 A. Time . 3 Q. All right. How much more time was 4 that? 5 A. That is a nice project. It is one 6 that you could spend a great deal more effort on. 7 It is an interesting problem area and it is one 8 that doesn't require 50 hours of work. It is one 9 that could require 500 hours of work, and a 10 student doing a master's thesis level project 11 collecting data on the mineral nature of an ore 12 deposit and variation in terms of depth within the 13 pit and so on and so forth. 14 Q. So there are other things from a 15 mineralogical point of view you would have been 16 interested in looking into? ~* 17 A. Sure. 18 Q. As far as the particular issue in 19 litigation, which is what else is in the ore? 20 A. That is one of the factors, right. 21 Q. Did you have enough time to do that 22 analysis? 23 A. Well, is there ever enough time? You 24 have to view the problem against what you consider 25 to be an appropriate commitment of resources. DOYLE REPORTING, INC. (212)867-8220 l 1 Langer 113 2 That this particular problem is one of the 3 principal elements is the presence or absence of 4 other biologically active minerals. If we don't 5 find it now in 50 hours of concentrated work or 60 6 with electron microscopy or 70 or a 100 or 7 whatever, it may not be important, meaning it is 8 trivial in relation to the total risk. 9 Q. Okay. 10 A. Now you can just beat this to death 11 and find one part per million amphibole fiber and 12 it may have very little significance biologically. 13 Q. Or you might beat it to death and 14 still not find anything? 15 A. Exactly correct. 16 Q. Did you feel you were able to make a 17 reasonable commitment of resources and time to 18 this project given what your results indicated so 19 far? 20 A. I think given my experience and given 21 what I find in other instances and given the 22 expertise of the involved players, yes, I think it 23 is reasonable, I think it is reasonable, and given 24 the data which are out there in the published and 25 unpublished reports, I think it is also DOYLE REPORTING, INC. (212)867-8220 1 Langer 114 2 reasonable. 3 q. Okay. Other than time, was there 4 anything else that you would have liked to have 5 that you didn't have? I suppose time and money, 6 right? 7 A. What would I have liked to have for 8 an assay? 9 Q. Something that Mr. Brownson could 10 have given you that he didn't give you. 11 MR. BROWNSON: Wait a minute. That 12 is' a vague question. Why don't you define 13 what you mean. 14 Q. I'll rephrase the question. 15 Did you ask for anything in the 16 course of doing this analysis of the materials 17 that was not given to you or made available to 18 you? 19 A. No. I must state for the record this 20 has never happened. And Mr. Brownson has been 2 1 forthright and forthcoming with all materials. 22 Q. So that basically you had everything 23 you felt you needed to make a reasonable analysis 24 of the material? 25 A. Yes. Frequently of course it is DOYLE REPORTING, INC. (212)867-8220 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 Langer 115 reversed, it is I who provided the materials as I should. Q. Okay. In terms of your CV, which we have marked as Exhibit 1, let me ask you a couple of questions about that. Actually before we leave that, I want to ask you about other documents. You brought with you a manila file and in it was a copy of your report? A. Right. Q. Copy of the deposition notice? A. Right, Q. Okay. There is also a copy of a document from the State of California, Air Resources Board, Stationary Source Division dated February 1990 entitled "Proposed Control Measure For Asbestos - Containing Serpentine Rock in Surfacing Applications, Staff Report"? A. Right. Q. What is the gist of this report? A. As a result of the EPA involvement out in California and as a result of several reports that there were chrysotile outcroppings and asbestos entering the air at certain places, DOYLE REPORTING, INC. (212)867-8220 1 Langer 116 2 in fact there is a major recreation area in which 3 off-road vehicles raise dust clouds that contain 4 fiber, California became interested in whether or 5 not serpentine rock could be used on roads as road 6 surfacing material. 7 Q. As in gravel or - - 8 A. Yes. 9 Q. - - or as blacktop? 10 A. No, uncovered. Just crushed stone 11 which is a serpentine rock. 12 Q. 13 measure. This says this is a proposed control 14 A. Yes. I think that has recently 15 been -- it has been legislated into law. 16 Q. And why were you involved with that? 17 A. Actually this is the result, these 18 documents that I have in my possession are the 19 result of my contacts at that EPA meeting, so 20 there were individuals there representing the 21 California Air Resources Board and the State 22 Health Service and the State Environmental Control 23 Group. In fact the meeting was held at the 24 Monterey Bay Pollution Control Unified District, 25 or whatever it is called, and they are interested DOYLE REPORTING, INC. (212)867-8220 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 Langer 117 in the use of asbestos - containing rocks. Q. If you had been asked your opinion on this proposed control measure, do you think it is appropriate or not? A. I think it is overstated, yes. Q. Did anybody ask you your opinion on it? A. No. Q. All right. By overstated, you mean that that degree of control is not necessary? A. Well, I think that -- yes, that degree of control is unnecessary, that they are dealing with levels of fiber that are about a million or 10 million times less than you find in workplaces, at least workplaces in the past that produced disease, that their concerns are disproportionate to the risk involved. Q. All right. And - MR. WILL: Let me mark this as Exhibit 5. (Whereupon, report marked Langer Exhibit 5 for identification, as of this date.) Q. I show you what we have marked as DOYLE REPORTING, INC. ( 212 ) 867 - B220 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 Langer 118 Exhibit 5, and that also came from your folder? A. Right. Q. Where did you get that? A. That was given to me by Mr. Browns on. Q. And you indicated you would like to get a copy of that report from NIOSH? A. Yes ~f MR. WILL: Let's mark this proposed California measure as Exhibit 6, just to be complete. {Whereupon, California staff report marked Langer Exhibit 6 for identification, as of this date.) Q. We have marked the California staff report as Exhibit 6, is that right? A. Right. DOYLE REPORTING, INC. (212)867-8220 t 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2S Langer 119 Q. You also have with you, there is a piece of yellow paper, notes in your file, I guess. What is that all about? A. That is just an outline of what I thought would be areas that I might be ashed to comment on or testify to. Q. Okay. MR. WILL: Let's mark that as 7. (Whereupon, notes marked Langer Exhibit 7 for identification, as of this date. } Q. We have now marked your sheet of notes as Exh ibit 7. A. Okay. Q. Is that right? A. Yes . Q. Was this a list of topics you thought you would be asked about at the deposition or that you might testify about at t rial in this ca se? A. Actually this i s my list which I proffered to Mr. Brownson as to what I thou ght I could assist on. Q. Okay. A. I don't know whether I'll be asked to DOYLE REPORTING, INC. (212)867-8220 i 1 Langer 121 2 A. Yes. And che size character of 3 aerosols. 4 Q. All right. 5 A. Then a calculation as to what is seen 6 by light microscopy and what is actually present 7 as visualized by transmission electron microscopy. 8 Q. Does that last item refer to the fact 9 that if you can see a certain number of fibers 10 optically under a light microscope, that if you 11 use it, an electron microscope, there will be a 12 certain magnitude higher of fibers? 13 A. Yes. 14 Q. What is the size character of the 15 aerosol, is that what we discussed earlier? 16 A. Yes. 17 Q. About the distribution of fibers in 18 different sizes? 19 A. Right. 20 Q. The last thing says "Ratio light to 21 TEM"? 22 A. Yes. 2 3 Q. "Numbers not crunched"? 24 A. "Numbers not crunched." That is my 25 own little note to me. The "numbers not crunched" DOYLE REPORTING, INC. (212)867-8220 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 Langer 122 is correct. Q. And then the last line says something about "Very large, could be like textiles"? A. Yes, it is "Very large, could be like textiles." Meaning that one of the standing working hypotheses regarding the extreme risk associated with asbestos textile work is based on the supposition that there exists a larger population of fibers greater than five microns in length -which are beyond the resolution of the light microscope. And that this material is of such character as to suggest that this is also possible. Q. When you say beyond five microns in length, do you mean less than or greater than? A. I'm sorry, greater than. Q. Greater than five microns? A. Yes. Q. But still you are unable to see it under light microscope? A. Because it is too thin. Correct. Q. Looking at a sample with the electron microscope would hopefully reveal those types of fibers ? DOYLE REPORTING, INC. (212)867-8220 1 Langer 122 2 is correct. ---3 ------ ^ -- 1 1 no ea vo enmot-Vii nr i c { S c 1C 13 i: 12 14 15 Q. When you say beyond five microns in 16 length, do you mean less than or greater than? 17 A. I'm sorry. greater than. 18 Q. Greater than five microns 0 19 A. Yes . 20 Q. But still you are unable to see it 21 under light microscope? 22 A. Because it is too thin. Correct. 23 Q. Looking at a sample with the electron 24 microscope would hopefully reveal those types of 25 fibers ? DOYLE REPOPTTWG, INC. (212) 867 - 822 0 1 Langer 124 2 Q. All right. How about for lung 3 cancer? 4 A. Yes. 5 Q. How about for mesothelioma? 6 A. Still yes. 7 Q. Okay. 8 A. All other factors equal. 9 Q. Right. Implicit in those questions 10 was the assumption that the worker was there and 11 that there was sufficient fiber release from the 12 production process to generate disease if the 13 fibers are biologically capable of generating 14 disease ? 15 A. That's correct. I'm assuming an 16 exposure like in Paterson, New Jersey, if the same 17 materials are used and they are dispersed in the 18 same way. 19 Q. In your opinion, those fibers are 20 biologically capable of causing disease under the 21 right circumstances? 22 A. Possessing the characteristics, yes. 23 Q. Are you aware of the amosite use at 24 the Conwed plant in Cloquet, Minnesota? 25 A. it is my understanding amosite was HAVT P T5 BrtAO'TTMd TMr* f 51 9 ^ QC7. B520 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 Langer 125 used for some time period, yes. Q. Have you been given years or quantities? A. My understanding it was for the first several years. Quantities? No. Q. Have you been asked to provide any opinions in this case on the relative contribution of amosite versus Union Carbide calidria in causing any disease that may have developed out at the Conwed plant? A. No. Q. Do you feel qualified to give those types of opinions if asked? A. I feel qualified to speak about anything. Whether the court qualifies me. is something else again. Q. Let me try the question differently. Are you going to be asked to give such opinions in this case? A. I don't know. I really don't. Q. If you were asked such questions, what information would you want to know on which to base your opinion? A. First, the individual involved, and DOYLE REPORTING, INC. (212)867-8220 1 Langer 12 6 2 I'm assuming that these diseases appear in 3 individuals - - 4 Q. Yes. 5 A. What is the individual's work 6 history. 7 Q. O.K. 8 A. If an individual worked during the 9 time period that the other fiber was used, how 10 long, what.were the fiber levels, what was this 11 particular person's job description, what was this 12 person's cumulative dose when this particular 13 fiber was stopped or removed from the process and 14 calidria was introduced. The same questions are 15 asked for this particular individual's 16 occupational history. ' 17 Q. If we do not have dust count data for 18 the period when the amosite was being used, would 19 you still be able to make an assessment of the 20 relative contributions between the two fibers? 21 A. That would be far more difficult. If 22 the individual succumed with a peritoneal 23 mesothelioma, then without knowing what the levels 24 were of amosite, I would say that sounds like 25 amosite. Amosite produces a proportionately DOYLE REPORTING, INC. (212)867-8220 1 Langer 127 2 greater mortality experience, it is higher, 3 following amosite exposure. 4 Q. Without regard to a specific plant or 5 individual, do you believe that amosite is more 6 fibrogenic? 7 A. Do I believe that amosite is more 8 fibrogenic ? 9 Q. Yes . 10 A. No . 11 Q In terms -- go ahead. 12 A. I misspoke. Than chrysotile? 13 Q. Yes . 14 A. No . 15 Q. In terms of ability to cause 16 asbes tos is, if we assume the same dose between 17 amosite and chrysotile. 18 A. On a fiber-by-fiber basis? 19 Q. Yes. 20 A. On a fiber-by-fiber basis, probably 21 amosite. 22 Q- Would be more potent than chrysotile? 23 24 21 nnvT.xr oconoTTwr: . INC r?l2)867-8220 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 Langer 128 Q. By fibrogenic, do you mean ability to cause fibrosis in the lungs? A. Yes. Q. Which is another way to say caused by asbestosis? A. If it is caused by an asbestos fiber, it is called asbestosis, right. Q. In a given amount of amosite, would you expect to find more, less or the same number of fibers as in an equivalent weight of calidria? A. Far less. Q. Because the fibers are larger? A. Yes. Q. And heavier? A. More dense, yes. Q. More dense? A. So that even if the size distribution was identical given an equivalent weight, you would find less amosite, correct. Q. If you were counting fibers? . nnvT.p d rcnDTTMn TNT . 1217)067-8220 1 Langer 30 2 dissimilar is the fact that amosite has a density 3 that is about 20 percent greater, 30 percent 4 greater than chrysotile, so that means that there 5 will be 20 or 30 percent less fiber. So we can go 6 the other way and give chrysotile a 20 percent 7 more fiber or 30 percent more fiber, so instead of 8 a hundred, it is the equivalent of 120 or 130 9 chrysotiles. 10 Q. So if I - 11 A. On a weight basis. 12 Q. Then on a weight basis, you might 13 have a hundred chrysotile -- 130 chrysotile fibers 14 and about a hundred amosite fibers? 15 A. One. 16 Q. One amosite fiber? 17 A. Yes. 18 Q. That is assuming the same length? 19 A. Yes. 20 Q. Are you familiar with the South 21 African asbestos amosite grade G? 22 A. Oh boy, classifications from South 23 Africa were different from the classification of 24 Quebec, of course. I'm completely blocking on it. 25 Q. You realize G, GK, DX? nnvr.p ^PORTING. INC. (212)867- 8220 Langer 13 1 2 A. It is a completely -- it is a similar 3 :ion but it is not same. Again it is a 4 commercial application. We are talking about a 5 commercial designation. We are not talking about 6 the Quebec method. It is a different kind of 7 classification. This classification scheme was a given to me by the former president, Bob Cryor of 9 North American Asbestos in Chicago. 10 Q. Do you know where Cryor is today? 11 A. He died of a mesothelioma. 12 Q. Do you know when that was? 13 A. 15 years ago, 20 years ago. In fact 14 the last time I saw him he was at Mount Sinai 15 Q. For treatment? 16 A. I think he came for a consultation 17 with Irv. 18 Q. After he became ill? 19 A. Uh-huh. 20 Q. That was a yes? 21 A. I'm sorry, I apologize. 22 Q. Doctor, at the present time you are 23 the director of the Environmental Sciences 24 Laboratory of the Institute of Applied Sciences at 25 the Brooklyn College of the City University of New DOYLE REPORTING, INC. (212)867-8220 1 Langer 132 2 York? 3 A. 4 Q. 5 A. e guess. 7 Q. Yes. How long have you been the director? Since I arrived there in 1988, I And prior to that, you were at Mount 8 Sinai? 9 A. Yes. 10 Q. Why did you leave Mount Sinai? 11 A. Well, it is a long tortured kind of 12 explanation. Basically I left the Environmental 13 Sciences Laboratory. My appointment was not 14 renewed under Landrigan. I went to the Center for 15 Polypeptide and Membrane Research, which was 16 incorporated into the department of physiology and 17 biophysics when that director retired. That is 18 Dr. Irving Schwartz. And that was the time to 19 leave. 20 Q. You indicated your appointment was 21 not renewed? 22 A. Yes. 23 Q. Who was that? 24 A. Landrigan. He was Irving Selikoff's 25 replacement. DOYLE REPORTING, INC. (212)867-8220 1 Langer 133 2 Q. What was the reason, the stated 3 reason that 4 appointment 5 A. The stated reason was that on the 6 retirement 7 other direc 8 any asbesto 9 Q. Did you suspect there was another 10 reason? 11 A. 12 Q. 13 A. Oh, sure, of course. What was that? What does it matter. Doesn't matter 14 today. 15 Q. I don't know unless I know what the 16 reason was. 17 A. Why don't you ask Phil Landrigan. ll 18 Q. From your perspective what was the 19 real reason 20 A. Irv Selikoff didn't want me around. 21 I became to< 22 which were i 23 beliefs. I hard to believe but it is 24 true . 25 Q. HOYLE RPOOPTING. INC. (212)867-8220 1 Langer 134 2 important areas where you came to disagree with 3 Irv Selikoff? 4 A. There are many areas. 5 Q. Can you pick out one or two or three 6 or four? 7 A. In the early 1980's, I was involved 8 in a study which was funded by a Crown Corporation 9 in Canada which involved the asbestos industry. 10 In fact, the Crown Corporation was represented - 11 it represented the reorganized industry after the 12 bankruptcy of Johns-Manville. This industry was 13 jointly owned by the Ottowa government, the Quebec 14 government and the holders of the asbestos 15 interests at Thetford and Asbestos, Capital A, 16 that is the name of a town. 17 The study involved the modification 18 of fiber for safe use. It doesn't matter what the 19 details are. I first spoke about these materials 20 at an OSHA hearing in 1984 in which I essentially 21 violated the litany of Sinai, which infuriated 22 Irving Selikoff, and Irving Selikoff felt that he 23 was losing control or lost control of what I was 24 saying and where I was going. 25 Q. Which part of the litany did you DOYLE REPORTING, INC. (212)867-8220 1 Langer 135 2 violate? 3 A. That modified asbestos could be used 4 in certain products with reasonable safety of low 5 risk and that the surface properties of a mineral 6 fiber dictated its biological potential, and that 7 I did not believe that many of the frequently 8 stated concepts were true. I mean people kept 9 repeating them, so many neophytes in the field 10 thought that this was so, and there was some data 11 to support it but there weren't any data, and I 12 said so. And I was the only one who went my own 13 way. Anyway - - 14 Q. Okay. Well, I am -- I'm interested 15 in these areas where you disagreed with Dr. 16 Selikoff. 17 A. I disagreed with him in a lot of 18 areas. 19 Q. As opposed to the personality clash 20 but the scientific disagreement. Was it your 21 perception at that time that the Sinai litany was 22 that there was -no safe level? 23 A. i didn't believe that. 24 Q. And they did? 25 A. Yes. DOYLE REPORTING, INC. {212)867-8220 1 Langer 136 2 Q. And one of the areas where you 3 disagreed with extrapolating projections of 4 disease from relatively high exposures to rather 5 low exposures? 6 A. Well, there is nothing to disagree 7 about. I think you can do that. The nature of a 8 model certainly warrants discussion. The problem 9 was that I didn't believe that the EPA could base 10 a policy which would affect society so 11 dramatically based -- it should be based on such 12 weak data'. I was opposed to that . I came out 13 against the EPA ban on asbestos. I critiqued the 14 environmental -- no, excuse me. It is the Natural 15 Resources Defense Council's proposed ban on 16 asbestos and friction products. I thought it was 17 so unscholarly and offensive and I said so. There 18 were a lot of reasons why we parted company and 19 parted ways. 20 Q. How is the Environmental Sciences 21 Laboratory of which you are the director funded? 22 A. We do contract work with various 23 groups . 24 Q. Is there any state funding? 25 A. We just got a major state grant. The DOYLE REPORTING, INC. (212)867-8220 1. Langer 137 2 state just gave us $725,000 as part of a major 3 grant to the City University, and that will be for 4 new equipment. 5 Q. Okay. I guess - 6 A. My laboratory. This is just my 7 laboratory. 8 Q. Is that -- this is the Environmental 9 Sciences Laboratory? 10 A. At Brooklyn, yes . 11 o. What I am not clear abo ut is , as I 12 understand, you have this laboratory which is - - 13 affiliated with the Brooklyn College of the City 14 University of New York? 15 A. That's right. 16 Q. But you are funded basically from 17 your contract work? 18 A. That's correct. 19 Q. Unless you qualify formore or less 20 one-time state grants? 21 A. We are hoping it is not one time, but 22 we qualify to seek support from any units, whether 23 these are foundations or various government, state 24 or federal or through various talc companies, 25 pharmaceutical companies, gasket manufacturers, nA VT.t1 Ti B r. An m t tkrr / n ^ \ Q C 7 , ft 77D 1 Langer 141 2 feet. We have a microscopy room that is 15 by 15, 3 so that is 225. We have a preparation room. They 4 are all about 15 by 20, that is 300. And we just 5 got a room to set up microscopy preparations, 6 another 300, so that is 600 feet. So it is about 7 3,000 square feet. 8 Q. And this is in one of the buildings 9 at the City College? 10 A. Yes. 11 Q. Brooklyn College? 12 A. Ingersoll Hall. 13 Q. Were you the founder of the lab? 14 A. Yes. 15 Q. For purposes of theanalysis you did 16 in this case * - 17 A. Right? 18 Q. -- was all of the equipment that you 19 used at your lab or did you need to go somewhere 20 else? 21 A. No. Not all equipment was at my lab. 22 Yes, I had to go somewhere else. 23 Q. And what equipment did you not have 24 at your laboratory? 25 A. The x-ray diffraction unit was not at DOYLE REPORTING. INC. (212)867-8220 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 Langer 142 my laboratory. I have one in my laboratory but it is not set up to do this kind of work. I used the one available in the laboratory up at Vanderbilt Talc Company in Norwalk, Connecticut, and I have a user relationship with the department of pathology in the Mount Sinai School of Medicine to use their analytical electron microscope. Q. And you pay them a user fee? A. It is a modest fee but we have a very good working relationship and it worked out well. I help them interpret data they can't interpret and they let me use that instrument any time I want to. Q. Okay. How long have you known Bob Nolan? A. Bob Nolan, he was an undergraduate when I first met him at Mount Sinai. He came in as a summer student. I bet that is maybe 15 years ago. Q. What is his degree in? A. He has a PhD in chemistry here in the City University. Q. Is he any relation to Charles Nolan? A. Chuck Nolan? DOYLE REPORTING, INC. (212)867-8220 1 Langer 143 2 Q. Yes. 3 A. Captain of police, Paterson, New 4 Jersey. They are only related by blood. That is 5 his father. 6 Q. All right. Was Bob i n any way 7 involved in the Paterson, New Jers ey studies? 8 A. No. 9 Q. Do I understand corre ctly that Chuck 10 Nolan helped even to the point of - - helped that 11 study to the point of storing spec imens of 12 materials. 13 A. Yes. 14 Q. Other than being chief of police, did 15 he have any scientific training? 16 A. I don't know. 17 Q. Did you work with the father? 18 A. I knew Chuck Nolan and -- well, work 19 with him, other than see him at Sinai, once in a 20 while. 21 Q. Do you know where the materials are 22 today from the Paterson study, the tissue? 23 A. The tissue I would give my right arm 24 for. No. 25 Q. Nobody knows where it is? DOYLE REPORTING, INC. {212)867-8220 1 Langer 144 2 A. Several years ago I made an inquiry 3 of Jack Churg, and by law pathology departments 4 store materials, even blocks, for only five years. 5 That is some legal requirement. And bulk tissues 6 no pathology department has room to store, so 7 whatever they had were disposed of. 8 Q. I see from your CV that you have a 9 bachelor's degree in geology, master's in 10 petrology and PhD in mineralogy. 11 A. Correct. 12 Q. What is the difference between the 13 three ? 14 A. Geology is the general field, the 15 general science. Petrology is the science of 16 rocks and rock systems. And mineralogy is the 17 study of the individual components of rocks, ore 18 deposits and things like that. 19 Q. What are -- if somebody else starts 20 out as a geologist, what are some of theother 21 directions they go other than into petrology and 22 mineralogy? 23 A. Let's be serious about this. They 24 could go into petroleum exploration as a 25 structural geologist or paleontologist or DOYLE REPORTING. INC. (212)867*0220 1- Langer 145 2 micropaleontologist or sedimentologist or a 3 stratigrapher. They could also go into mining, 4 mining engineering. Also could go into a 5 general -- academics, X suppose. 6 Q. As you described it, it seems to me 7 you were talking more about larger structures and 8 relationships than in the direction you went. 9 which is fo cusing first on rocks and then the 10 individual components ? 11 A. That's right. 12 Q. Is that a gross summary? 13 A. Well, it is just different 14 disciplines . Different disciplines look at 15 different parts of the problem. 16 (Recess taken) 17 BY MR. WILL : 18 Q. Dr. Langer, have you looked at any 19 tissue of any workers at the Conwed plant at 20 Cloquet ? 21 A. No. 22 Q. Have you been made aware of any fibe 23 studies or ;fiber burden studies on any Conwed 24 worker? 25 A. No. DOYLE REPORTING, INC. (212)867-8220 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 Langer 146 Q. Do you know whether that has ever been done? A. No. Q. Have you seen any medical records or any x-rays or any medical materials on any of the workers at Conwed? A. No. Q. Do you have any sense of what diseases were claimed to have been suffered by the work force as a result of their exposure to asbestos ? A. I'm thinking. Q. Let me see if I canrephrase the question. Have you been given any sort of breakdown about claimant diseases that are related to asbestos that were incurred by the Conwed -- or allegedly incurred by the Conwed work force? A. Years ago the Cloquetplant closed, am I correct, in that assumption, years ago -- Q. NO . A. The Conwed facility closed? Q. No. A. It is still open? DOYLF REPORTTwr: INC. ( pi? ) 867- 8220 1 Langer 147 2 Q. It was sold but it didn't close. 3 A. I see. It was sold but then 4 something happened whereby everybody was out of 5 work, is that correct? 6 Q. When it was sold they were out of 7 work. 8 A. When it was sold they were out of 9 work. Okay. I thought there was -- my 10 recollection is that years ago there was some - 11 I'm not' sure this is Minnesota or Wisconsin. 12 There is a class action suit and there are two 13 papers published in the American Journal of 14 Industrial Medicine on a group of people, and I 15 can't think of the -- I'm blocking on this. Maybe 16 it is late in the day. Right now I can't recall, 17 although in dim recollection I think there are a 18 couple of papers published but -- 19 Q. Okay. Let me make the question more 20 specific. Has Mr. Brownson given you any such 21 information for use in this case? 22 A. He might have mentioned it to me but 23 I can't recall. 24 Q. Do you have then as we sit here today 25 any awareness of what the claimed types or DOYLE REPORTING. INC. (2121867-8220 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 1G 17 18 19 20 21 22 23 24 25 Langer 148 instances of asbestos - related disease at the Conwed plant were? A. No. That was not in my workout line. Q. If we are looking at getting disease from amosite exposure, what number of fiber years of exposure would you feel is necessary to cause and start with asbestosis? A. Fiber years? Q. Well, we -- whatdegree of exposure, let's put it that way, toamosite would you feel is necessary? - A. You just want a guess. You just want me to off the top of my head do one of these -- Q. Well, I can short-circuit this. Are you going to ask or be asked to give any opinions in this case on whether the exposure to amosite at this plant was insufficient or sufficient to cause disease ? A. I don't know. MR. WILL: Can you help us out? MR. BROWNSON: This is not an issue in the case because under Minnesota compensation case, if the disease was caused in any degree - - DOYLE REPORTING, INC. (212)867-8220 1 Langer 149 2 MR. WILL: I would care about the 3 amosite. 4 MR. BROWNSON:, Well, we don't. He 5 is not going to make those calculations. 6 When I said -- it is not an issue for us. 7 It may be a defense for you. 8 MR. WILL: Right, okay. 9 On the representation of Mr. 10 Brownson that you are not going to offer 11 any such calculations, then I think we can 12 move on. 13 MR. BROWNSON: Yes, we can move on. 14 Q. Without trying to figure out what 15 the -- or did you do the calculations while we 16 were talking, you did them? - .. 17 A. Well, I mean if you were to assume an 18 insulation worker is exposed to between 10 and 20 19 fibers per c.c., that is the difference between 20 low-end construction and high-end marine, for 25 21 years, that would be a Selikoff kind of 22 calculation. That is 250 to 500 fiber years. 23 About 7 percent of the mortality is asbestosis, so 24 if 7 percent results at let's take 250, it is the 25 low end. If 7 percent is at 250 fiber years DOYLE REPORTING, INC. (212)867-8220 1. Langer 150 2 cumulative, 2500 fiber years would produce 70 3 percent and 25 fiber years would produce 0.7 4 percent. 5 Q. That is asbestosis mortality? 6 A. That's correct. 7 Q. That doesn't tell you how many people 8 simply contract the disease? 9 A. At 250 to 500 fiber years for 25 10 years , they all have some asbestosis, or clinical 11 or subclinical, but it is present. 12 Q. In terms of just calculating people 13 who may develop clinical but not fatal asbestosis 14 from an amosite exposure, less than 250 fiber 15 years would be required? 16 A. I would think so, yes. 17 Q You mentioned Dr. Pooley. You worked 18 with him and published papers? 19 A. Yes . 20 Q. You recognize him as an expert in the 21 area of asbestos-related disease? 22 A. Yes . 23 Q. Do you know Richard Lee? 24 A. Yes . 25 Q. How do you know Mr. Lee? DOYLE REPORTING. INC. (212)867-8220 1. Langer 151 2 A. Dr. Lee. I first met Dr. Lee when he 3 represented U.S. Steel when I was involved in the 4 contamination of Lake Superior. The Reserve 5 Mining case. United States of America versus 6 Reserve Mining, et al. 7 Q. In what areas do you recognize Dr. 8 Lee as having expertise? 9 A. In electron microscopy. The 10 acquisition and analysis of data by electron beam 11 methods. 12 Q. Do you know Dr. William Weiss in 13 Philadelphia? 14 A. I know of him. I've never had an 15 opportunity to sit down and chat with him, no. 16 Q. Do you recognize him as having some 17 expertise in the area of - - 18 A. He is a pulmonologist, yes. 19 Q. Okay. And how about in the 20 epidemiology of asbestos diseases? 21 A. How about it? 22 Q. Are you familiar with his work 23 that area? 24 A. Less familiar with that. 25 Q. Okay. Have you ever had any DOYLE REPORTING. INC. (212)867*8220 \ 1 Danger 152 2 relationship with McCrone Laboratories? Done any 3 work with them, for them? 4 A, I know of them. I believe we may 5 have passed samples back and forth 20 years ago or 6 something like that. 7 Q. Okay. Are you in a position to 8 comment on their expertise? 9 A. They are very good. 10 Q. Or the accuracy -- have you ever 11 checked any of their results? 12 A. Yes, as a matter of fact. 13 Q. In what context? 14 A. The analysis of Conwed ceiling tiles. 15 Q. Was that in one of the Baltimore 16 cases ? 17 A. I think it was Annerundel. 18 Q. I'm sorry, the Maryland cases? 19 A. Right. 20 Q. Did you reach the same results that 21 they did? 22 A. Basically. 23 Q. What was the result? 24 A. That there was fiber present. We 25 disagreed a little on the amount of fiber. DOYLE REPORTING, INC. (212)867-8220 1 Langer 153 2 Q. You were low, they were high? 3 A. I don't recall the details. There 4 was some discrepancy but I didn't think it was 5 major. Since we use different protocols for the 6 preparation of the material. 7 Q. You mentioned in your CV a Professor 8 Kerr. 9 A. Professor Kerr was the Newberry 10 professor of mineralogy of Columbia University. 11 Q. Did you do your graduate work under 12 his direction? . 13 A. Most of it. 14 Paul F. Kerr, a gentleman and a 15 scholar. So few of us left. 16 Q. You came to Mount Sinai in what year? 17 A. 1965. 18 Q. And remained there then until '88, is 19 that correct? 20 A. Correct. 21 Q. Okay. You held various capacities 22 during that time? 23 A. Yes. 24 Q. Your training was in geology, 25 petrology and mineralogy? DOYLE REPORTING, INC. (212)867-8220 t 1 Langer 154 2 A. Correct. 3 Q. what formal training did you have in 4 biology? 5 A. Formal training, you mean coursework? 6 Q. Yes. 7 A. At what, undergraduate level -- 8 Q. Skip the undergraduate for a minute. 9 A. Graduate level? 10 Q. Yes. 11 A. Formal in which I enrolled for a 12 course. None. 13 Q. Okay. How about any formal 14 coursework at the graduate level in terms of, I 15 don't know how you want to break it down, but more 16 the biological impact of mineral fibers on humans? 17 A. I don't think anyone offered acourse 18 in that, quite frankly. 19 Q. All right. 20 A. It is just on the basis of work and 21 reading. 22 Q. All right. Since you went to work 23 for Mount Sinai and since then? Let me rephrase 24 the question. 25 Am X correct that your reading -- the DOYLE REPORTING. INC. (212)367-8220 1 Langer 155 2 reading and the work which you referred to that 3 provided you with knowledge concerning the 4 biological effect of minerals on humans has been 5 acquired since approximately 1965? 6 A. That's right, basically with study 7 and research and reading. 8 Q. You have testified numerous times as 9 an expert witness in cases involving asbestos, is 10 that correct? 11 A. No. ` 12 Q. How many times have you testified? 13 A. By deposition or trial -- 14 Q. Start at trial. 15 A. Trial. Not many. Over -- I've been 16 in this field for 28 years. I may have testified 17 at trial 20 times, 18 times. Nothing 18 extraordinary. 19 Q. How about by deposition? 20 A. By deposition, maybe twice that. 21 Maybe twice that. 22 Q. And the times that you have testified 23 at trial, have you sometimes been limited in the 24 opinions that you could express to those relating 25 to mineralogy as opposed to medicine or - DOYLE REPORTING, INC. (212)867-8220 1 Langer 156 2 A. Limited to mineralogy? No. 3 Q. Have you ever been prevented by a 4 court from giving testimony about what the court 5 regarded as medical issues? 6 A. Yes. 7 Q. All right. And that would be to 8 assess risk or cause and effect? What types of 9 things have you not been allowed to testify to? 10 A. It was more generic, whether I could 11 testify to or make the statement in open court 12 that the biological potential of chrysotile that 13 had been milled either increased or decreased 14 depending on the milling method. I was prevented 15 from commenting on two papers where I was senior 16 author on both. You can laugh but that is the 17 nature of it. 18 Q. It was sufficient for peerreview 19 journals but it wasn't sufficient for the judge? 20 A. Correct. That is absolutely correct. 21 Q. How did you happen to get interested 22 in the area of asbestos research? 23 A. That is a long, involved story. 24 Selikoff, in 1965, was interested in forming a 25 unit at Mount Sinai which would focus on asbestos, DOYLE REPORTING, INC. (212)867-8220 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 Langer 157 and included among the disciplines he wished to bring to bear on the problem was mineralogy. I was the last of Paul Kerr's PhD students in residence. At that time I had an appointment to go to the astrogeology .branch in Flagstaff, Arizona with the United States Geological Survey, but Selikoff in outlining the nature of the position convinced me that maybe a year's leave of absence would not be out of -- would be -- would not be damaging, and I could explore this new area, new interesting area, which I did. Q. And that started a life's work? A. That started, yes, my life's work. Q. You worked part time for the Air Force? A. Yes. When I was a graduate student. Q. What did you do for the Air Force? A. I was involved in a study concerning the mineral character and the role mineralogy played in imparting mechanical properties to dry lake beds which permitted their use as landing fields. It is fascinating. Q. Were you involved in setting up these DOYLE REPORTING, INC. (212) 867- 8220 I 1 Langer 158 2 airfields on the dry lake beds? 3 A. No, but I was involved in the assay 4 of certain playas or dry lake beds and indicating 5 which would be suitable for emergency landing 6 fields. 7 Q. You've also consulted, at least in a 8 couple of cases, with the oil industry? 9 A. Yes, that's correct. 10 Q. That was earlier, though, in your 11 career? 12 A.. Much earlier. I was still a graduate 13 student at Columbia. Professor Kerr had some 14 problems, one was with the Creole Oil Company. 15 Also he consulted with Texas Gulf Sulfur. 16 Q. Trying to find oil? _ 17 A. No. Texas Gulf Sulfur had a 18 phosphorite deposit in North Carolina, and they 19 wanted to set up some catchment ponds for the 20 water because it was very close to the surface and 21 they were pumping from this surface working, and 22 they found that their earthen dams failed, and the 23 reason for that was the nature of the clay 24 minerals associated with the phosphorite deposit. 25 It picked up water, it swelled, it had no DOYLE REPORTING, INC. (212)867-8220 1 Langer 159 2 mechanical strength. 3 Q. You mentioned you had done some work 4 in Minnesota in connection with the Reserve Mining 5 case . 6 A. Yes. 7 Q. Was that looking at the dumping of 8 asbestiform minerals into Lake Superior? 9 A . NO . 10 Q. What was it? 11 A. It was the dumping of amphibole 12 gangue materials. There were no asbestiform 13 minerals, no asbestos minerals present. And years 14 later when we had more data we found that the 15 materials that were being dumped into Lake 16 Superior had no bearing, had no relationship 17 basically with asbestos minerals. 18 Q. But at the time people thought 19 asbestos was being dumped into Lake Superior? 20 A. Exactly. 21 Q. And there was a much-to-do about 22 that ? 23 A. Much to do about nothing, someone 24 once said Or much ado about nothing. 25 Q- Who were you working for in that DOYLE REPORTING, INC. (212)867-8220 1 Langer 160 2 case? 3 A. The United States Department of 4 Justice. 5 Q. Who was suing to prevent Reserve 6 Mining dumping? 7 A. It was the U.S. -- yes, it is the 8 United States of America, et al., the State of 17 9 Wisconsin, the State of Minnesota, the State of 10 Michigan. 11 Q. That were trying to shut down the 12 plant? 13 A. Silver Bay. Shut it down. 14 Q. At least keep it from dumping, which 15 would have shut it down? 16 A. I' 11': tell you a story off the record 17 when we finish with this - 18 MR. BROWNSON: Let's get the 19 questions answered. 20 Q. You are listed as a fellow of the 21 Collegium Ramazzini. What is the Collegium 22 Ramazzini? 23 A. It is a brainchild, was a brainchild 24 of Irving Selikoff. Ramazzini is considered the 25 father of occupational medicine, and on the 300th DOYLE REPORTING, INC. (212)867-8220 1. Langer 161 2 anniversary of Ramazzini's birth, Irving Selikoff 3 banded together with a group of other interested 4 parties, international parties, to form a group 5 which would meet periodically to bring to the 6 forefront emerging occupational problems, in the 7 sense that there is always some lag time between 8 the appearance of reports in the literature and 9 the application and implementation of control 10 strategies,- so Irv thought it was a good idea, and 11 it was a good idea, yes. 12 Q. And who provides the financial 13 sponsorship for that? 14 A. Well, everyone is supposed to pay 15 their dues and then they hold meetings and they 16 charge people to attend the meetings and things 17 like that. 18 Q. You are elected a fellow? 19 A. Yes . 20 Q. What does that mean? 2 1 A. What does that mean? 22 Q. Yes. 23 A. With $1.25, I can ride your subways. 24 It means there were only 100 fellows in the whole 25 world and I am one. You got it. DOYLE REPORTING, INC. (212)667-8220 1 Langer 162 2 Q. All right. Has the Collegium looked 3 issues other than asbestos 4 A. Yes , sure. 5 Q. Has any funding for the work of the 6 Collegium been provided by the Plaintiffs' 7 Asbestos Personal Injury Bar? 8 A. It is my understanding that this has 9 occurred in the past. 10 Q. You wrote, I believe it was your 11 master's thesis, on Manhattan serpentine? 12 A. No. It is actually on the Manhattan 13 formation in New York City. The rocks that 14 constitute - - 15 Q. Is there serpentinein those rocks? 16 A. Yes. 17 Q. Any asbestiform? 18 A. Yes. Right out there (indicating) 19 there is a low-lying hill in Staten Island, the 20 witness is pointing south, and on the other side 21 of that harbor (indicating), the continuation of 22 the Palisades, it goes under the surface of New 23 Jersey here and it crops out on Staten Island and 24 there is a hill called Todt Hill, and it is the 25 highest peak along the East Coast, the shore, 400 DOYLE REPORTING, INC. (212)867-8220 1 Langer 163 2 feet above sea level. And a gentleman by the name 3 of Mr. Johns had an asphalt asbestos tile plant 4 there where he personally mixed by hand various 5 asphalt products with chrysotile asbestos from e that deposit and made asphalt shingles. Mr. 7 Johns, who expired, in 1899, this is true, of 8 miner's pthysis. He died of pneumonoconiosis. 9 Q. Doctor, you have been on the 10 editorial board of a number of different 11 publications? 12 A. Journals. 13 Q. Journals? 14 A. Yes. 15 Q. And some of those journals have also 16 published some of the papers you have -- some of 17 those journals have published some of the papers 18 of which you have been the author or co-author? 19 A. Yes. 20 Q. For a person submitting a paper who 21 also is on the editorial board of the journal, are 22 there any different requirements or procedures 23 involved in getting the paperpublished? 24 A. Well,yes, ofcourse. It is 25 subjected to the most rigorous of evaluations. DOYLE REPORTING, INC. (212)867-8220 1 Langer 164 2 Even more so. 3 Q. There is no different procedure in 4 terms of the number of people that review it? 5 A. Well, it depends who is doing it. If 6 I'm doing it, it is one standard. If Phil 7 Landrigan is doing it, it is some other standard. 8 That is the way it is. 9 Q. All kidding aside - 10 A. All kidding aside, basically all of 11 the papers I've ever written I've given to 12 colleagues, and I say go over it and tell me what 13 you think and/or I will make recommendations. 14 Let's say a paper is submitted to the British 15 Journal of Industrial Medicine, I say this should 16 be reviewed by Chris Wagner or John Davis or John 17 Addison and you make recommendations. They are 18 people, experts in the field, and they will read 19 this and they will tell you what they think is 20 good and what they think is lousy, and you respond 21 to it, and it makes the paper better and it is a 22 positive form of evaluation. 23 Q. You mentioned something earlier about 24 how long asbestos remains in the lung. Is that 25 something that is sometimes referred to as DOYLE REPORTING, INC. (212)867-8220 1 Langer 165 2 biopersistence? 3 A. Yes . That is a wonderful term. 4 Q. When you use that term in your 5 writing, what doe s that refer to? 6 A. The fact that fibers are retained and 7 remain as opposed to being degraded or eliminated 8 in some fashion. 9 Q. All right. Does chrysotile have a 10 different biopersistence than the amphiboles? 11 A. It tends to be less. 12 Q. Does the biopersistence of chrysotile 13 depend upon fiber size? 14 A. Yes. 15 Q. All right. Are.shorter chrysotile 16 fibers more likely to be removed? 17 A. Yes. 18 Q. In terms of those fibers, chrysotile 19 fibers removed from the lungs, what is your 20 opinion about whether those fibers contribute to, 21 let's start with asbestosis? 22 A. Probably not. 23 Q. How about lung cancer? 24 A. I think the two processes are pretty 25 much related. Less, also. DOYLE REPORTING, INC. (212)867-8220 1 Langer 16 6 2 Q. How about mesothelioma? 3, a. The problem is when you remove it 4 from the lung, where does it go? If it is coughed 5 up or spit out, it has no effect on mesothelioma. 6 Q. If it lodges in the pleura - 7 A. That is not the story. 8 Q. Are some of the fibers removed 9 through the lymph system? 10 A. Yes. 11 Q. Those fibers would not play a role in 12 pleural mesothelioma, would they? 13 A. The surface of the pleura, whether it 14 is the visceral pleura or the parietal pleura, is 15 an area of lymphatic drainage to fibers swept 16 along could come to rest on the pleura, so if you 17 remove particles from the lung through the 18 lymphatic drainage, it could come to rest at the 19 pleura. 20 Q. If it doesn't come to rest, if it 21 continues to drain, then presumably it plays no 22 role? 23 A. It would play no role. It would be 24 sequestered in some node. 25 Q. in terms of the amosite, is there any DOYLE REPORTING, INC. (212)867-8220 1 Langer 167 2 clearance of amosite from the lung? 3 A. Yes. Some of it goes. About 80 4 percent of it goes. Something like that. 5 Q. How is it removed? 6 A. The same processes, it is a 7 mucocilliary escalator. That is the beating of 8 cilia, and of course the macrophages and the other 9 cells which move particles. 10 Q. So would you also then get amosite 11 fibers draining through the lymph system along the 12 pleura? - 13 A. Yes, sure. 14 Q. In terms of the translocation of 15 fibers, what do you mean by that? 16 A. Translocation is a fiber that changes 17 from one place to the next. This is part of this 18 system that we are talking about. You can have a 19 particle removed from the lung but it winds up in 20 some other organ. Let's say you have a very long 21 amosite fiber, you cough it up, you swallow it, it 22 winds up in the gut. It is thought this is one of 23 the mechanisms, one of the pathways by which 24 fibers wind up in the gut and is associated with 25 increased gastrointestinal cancer. DOYLE REPORTING, INC. (212)867-8220 1 Langer 168 2 Q. Does the translocation of fibers 3 refer only to movement. within the organ and withi 4 the body? 5 A. Yes . 6 Q. In terms of the translocation within 7 the lungs. is there a difference between the 8 ability of chrysotile and, say, amosite to move 9 it? 10 A. Depends on the size distribution. 11 Which is the longer fiber. The longer the fiber, 12 they tend' to remain, shorter fibers tend to be 13 swept. Given general populations of fibers, I 14 would say amosite tends to remain. Chrysotile 15 tends to be removed. 16 Q- So the amosite fibers would tend to 17 remain where they lodge? 18 A. All other factors being equal. 19 Q. 20 they - - They are more likely to remain where 21 A. I would agree with that, yes. 22 Q. You have published studies on an 23 analysis of calidria asbestos, correct? 24 A. Yes. . 25 Q. You have been the author on how many DOYLE REPORTING, INC. {212)867-8220 1 Langer 169 2 published studies on calidria? 3 A. Specifically calidria? 4 Q. Right. There is the Yager paper you 5 mentioned earlier? 6 A. I'm just recalling that offhand. The 7 others are just attributions to the nature of the 8 material. 9 Q. So that is the only published - 10 A. Offhand that is the only one I can 11 think of. 12 Q.' Now, are you aware of any cohort 13 studies done with a calidria-exposed population? 14 A. Cohort study? Bona fide cohort? 15 Q. Yes. 16 A. No. 17 Q. If we could do that,wouldn't that be 18 a good study to see what impact calidria may have 19 in causing disease? 20 A. It might be. It might not. 21 Q. Why might it not be? 22 A. It would be very similar to the 23 studies for other forms of chrysotile. If you 24 went to Charleston, South Carolina and thought 25 that represented all of the chrysotile industries DOYLE REPORTING, INC. (212)867-8220 1 -Langer 170 2 in the world, you would be misled. If you were to 3 study miners and millers in Canada or Ferodo 4 friction product manufacturing, you would get a 5 different picture. So it might be in some way a 6 good extrapolation to Conwed if similar products 7 were made or similar machinery was involved and 8 amounts of fiber and the matrices were the same. 9 Q. At least there would be a piece of 10 data you would be interested in if it were 11 available? 12 A. Sure. 13 Q. Would you expectto find -- based on 14 what you know about calidria, would you expect to 15 find examples of asbestos * related disease in 16 people who mined and milled the 17 calidria-containing ore? 18 A. No. 19 Q. Why not? 20 A. The fiber levels areextraordinarily 21 low. I was out at the pit. I felt extremely 22 comfortable. The material is -- the material 23 forms a mud. It is wet right below the surface. 24 Vehicles moving on the surface did not raise much 25 dust at all. The mill, the ore was dumped a half DOYLE REPORTING, INC. (212)867-8220 1 Langer 171 2 mile from the mill or quarter mile from the mill. 3 It is brought to the mill in a slurry, a wet 4 slurry. The process is a wet process. No, I 5 would be surprised if there was any disease. 6 Q. Again that is based on the low fiber 1 levels? 8 A. I'm sure the fiber levels are very 9 1 ow. 10 Q. You have some dust counts in your 11 possession that were taken at the mill and the 12 mine, correct? At least at the mill? 13 A. Yes, I have seen some data. In fact 14 some of Lee's data, by TEM, extraordinarily low. 15 No, I would not anticipate diseases there. In 16 that small group of people? No. 17 Q. Do you know how the measured fiber 18 levels at the mill compared to the measured fiber 19 levels at the Conwed plant? 20 A. The mill represents a different 21 environment entirely and control measures were 22 taken. I'm not sure they are even comparable. 23 Q. But measurements were taken at both 24 sites ? 25 A. Correct. DOYLE REPORTING, INC. ( 2 12 ) 867 - 8220 1 Langer 172 2 Q. My question is, do you know which 3 showed higher levels based on the measurements 4 that were taken? 5 A. I think -- X can't compare them 6 directly, and the reason I can't compare them 7 directly, because there are values given for times 8 that are less than time-weighted averages. They 9 would have to be recomputed or you have to know 10 whether this represents an episodic burst or a 11 segment of an eight-hour time-weighted day. In my 12 head I think that one of the levels found at the 13 mill was 0.95 fibers. And at Conwed, there are in 14 some places excursions of greater than 10 fibers, 15 but the time-weighted averages seem to be lower 16 than the .95, so it.is something like that. . 17 Q. Basically you would want to review 18 the data and perhaps - 19 A. It has to be tabulated. When you 20 read these different reports and everybody is 21 doing different kinds of things, it becomes 22 difficult to make an immediate mental comparison. 23 You have to sit down, look at the data and say 24 this could happen, that could happen and so on. 25 Q. Do you know whether in fact there has DOYLE REPORTING, INC. (212)867-6220 1 Langer 173 2 been any asbestos - related disease with the people 3 who worked at the mine or at the mill? 4 A. I have no idea. 5 Q. In the Yager paper, you and your 6 collaborators attempted to measure I guess the 7 macrophage mortality rate? 8 A. That's right. A macrophage mortality 9 study. You feed cells dust and determine if these 10 cells respond differently than another cell 11 populations not exposed to the same material. 12 Q. Now you've got the cells, they were 13 alveolar macrophages. 14 A. Yes. 15 Q. And you got them from seven doners I 16 guess through Georgetown? . 17 A. Right. 18 Q. And in the article it indicates that 19 there were three nonsmokers, one smoker and one 20 donar, if I may, one marijuana smoker? 21 A. Weren't there nine individuals 22 involved? Or five volunteers? It is 10 years 23 ago . 24 Q. I didn't know --do you recall what 25 the smoking history of the ones - - ' DOYLE REPORTING, INC. (212)867-6220 1 Langer 174 2 A. No, no. That's right, there were 3 some cigarette smokers and some guy who was a 4 marijuana freak. Right. 5 Q. Now, the dust that you used was from 6 one of three sources, is that correct? 7 A. I think so. 8 Q. UICC, chrysotile? 9 A. Yes, we used UICC, that's right. Or 10 the calidria, yes, correct. 11 Q. And you also used quartz dust as a 12 positive control. 13 Was there any reason that you didn't 14 use a negative control, some sort of dust felt to 15 be largely inert? 16 A. I left that to my colleagues' who'-were' 17 formally trained in biology. 18 Q. That is something to take up with 19 them, in other words? 20 A. That's right. Those dopes. 21 Q. Now another thing that this study did 22 was to ball-mill the calidria asbestos? 23 A. It was blade-milled. 24 Q. To blade-mill it? 25 A. That's right. DOYLE REPORTING, INC. (212)867-8220 1 Langer 175 2 Q. And at two different time intervals? 3 A. That1s right. 4 Q. And the study reported that the 5 longer the calidria was milled, the greater the 6 macrophage mortality? 7 A. That's right. 8 Q. But the UICC, I believe it was 9 Rhodesian chrysotile was not milled, was it? 10 A. I don't think so, no. 11 O'. Was there any reason why it wasn't 12 milled? 13 A. We wanted to retain its fiber length, 14 as I remember in our discussions. 15 Q. Do you have an opinion on whether had 16 you milled the Rhodesian chrysotile, it Would have 17 produced a similar increase in macrophage 18 mortality? 19 A. It probably would have. 20 Q. How about for example amphibole 21 fiber, would you expect to see the same results if 22 you did the same experiment? 23 A. I don't know. 24 Q. Why is that? 25 A. It behaves differently when it is DOYLE REPORTING, INC. (212)867-8220 1 Langer 176 2 milled. It is a more -- it is a tougher mineral 3 and you tend' to introduce surface artifacts more 4 quickly than with chrysotile, which disaggregates 5 first, then the surface functionalities are 6 af fected. 7 Q. I realize this is sort of a crude 8 description, but are you saying that if you - 9 A. i'll give you a crude answer. 10 Q. If you mill chrysotile it tends to 11 come apart fairly easily? 12 A, Yes. 13 Q. Whereas if you mill the amphibole 14 fibers, say amosite, it is so tough to break it 15 apart that you may alter the surface of the fiber? 16 A. It is more difficult to manipulate. 17 Q. And in manipulatingthat harder 18 mineral, you may induce alterations in the surface 19 chemistry? 20 A. Yes. What you are basically doing is 21 imparting mechanical energy into the system. Now 22 the system responds. The system may respond by 23 breaking apart and breaking along the weakest 24 bonding elements, or you have to attack the bonds 25 themselves that make up the mineral. So you DOYbE REPORTING, INC. (212)867-8220 1 Langer 177 2 either disaggregate it or you start to break down 3 the mineral itself. 4 Chrysotile tends to disaggregate 5 because those fiber bundles are not held together 6 with strong forces, whereas an amphibole fibrile, 7 if it doesn't have some submicronic, some 8 submicroscopic structure along which the material 9 breaks like a twin plane or some other defect, it 10 will start to modify the surface. 11 Q. Do you think it would have made any 12 difference to the results if you had ball-milled 13 the chrysotile as opposed to blade-milling? 14 A. I think it would have. 15 Q. What - 16 A. It would have reduced the activity. 17 Q. Why? 18 A. Well, we have a study that we 19 published in which material was ball-milled, 20 impact milling, and that starts to break bonds and 21 it changes the characteristics of the surface and 22 the structure of the material so that certain 23 properties fail. The flow of electrons and so on. 24 Q. And ball-milling would have made the 25 calidria, in your opinion, less toxic, if you ' DOYLE REPORTING, INC. (212)867-8220 1 Langer 178 2 will, to the macrophages? 3 A. Yes. 4 Q. Which study is that that you prepared 5 with respect to the ball-milled - 6 A. The 1977 study. 7 Q. That is publishedunder the name of 8 what ? 9 A. Langer, et al. It is in my CV. It 10 is on progressive milling of chrysotile asbestos 11 alteration of -- let me just get this citation for 12 you. 13 The citation is the following. It is 14 on page 13, number 36, in my CV. Variation of 15 properties of chrysotile asbestos subjected to 16 prolonged milling. 1978. 17 Q. In terms of the biological effect of 18 chrysotile, do you think it makes -- if we are 19 talking just about the chrysotile, does it make 20 any difference whether it is Canadian or Rhodesian 21 chrysotile or calidria chrysotile or is it the 22 size and shape of the fiber that makes the 23 difference? 24 A. Complex question. All the fiber 25 types are different. They are different from a DOYLE REPORTING, INC. ( 2 12) 867 - 8220 1 Langer 179 2 number of standpoints. All of the fibers then 3 manipulated respond to the manipulation 4 differently so you get a range of properties which 5 affect biological potential. 6 Q. By and large, do you think results 7 obtained with fibers of one chrysotile type of a 6 given size are applicable to fibers of another 9 chrysotile type of comparable size? 10 A. Probably within a certain range. 11 Q. And I realize this is a general 12 questionbut is that range so large that the 13 studies are of no value or is the range small 14 enough that you say yes, the studies are probably 15 applicable but they might change a little bit? 16 A. All studies are of value. They 17 answer certain questions. Some studies answer 18 more questions than others. I thought I 19 successfully avoided answering your question. 20 I'll give you an example. 21 Q. Sure. 22 A. The UICC, that is all caps, by the 23 way, UICC-B, the Canadian standard is a mixture 24 from eight different mines in Canada. The 25 asbestos mine, the question was do chrysotiles DOYLE REPORTING, INC. (212) 867-8220 Langer 80 behave the same. No, they don't behave the same. For example, the standard asbestos type, the UICC-B, which is the Canadian specimen, results from a mixture of fibers from a number of mines. Chris Wagner has experimented with each of the individual splits that make up the specimen and he produced a range of mesothelioma mortality in laboratory animals which -- well, the values of which ranged from 32 percent to 64 percent-. So it was -- it varied by a whole factor. Q. So there is some difference from one form of chrysotile to another? A. Certainly. Q. All right. In terms of biological - okay. Within those limits there are applicabilities from one study to another? A. Sure. Q. In your opinion, what isresponsible for the differences in the behavior of different types of chrysotile? A. The properties are many. And the properties may be those properties of the fiber itself, which includes chemistry, trace metals, DOYLE REPORTING, INC. (212)867-8220 1 Langer 181 2 relative harshness, associated minerals, 3 superimposed properties brought about by 4 industrial manipulation which include heating, 5 surface treatment, mechanical milling and others, 6 and finally the superimposed properties of the 7 product itself and the products use. 8 For example, thermal insulation on a 9 pipe which contains chrysotile after many years 10 contains a modified chrysotile which is more 11 dusty, so you have the intrinsic properties of the 12 material,, you have the superimposed properties of 13 the industrial workplace and you have the final 14 properties of the environment of use. 15 Q. If we are talking about fiber as it 16 comes from the mill, say, then what you would be 17 talking about are the differences between the 18 shape, chemistry of the fiber itself, plus 19 anything that was done to it in the milling and 20 mining? 21 A. That is a way of looking at it. 22 That's right. I mean it is the nature of the 23 fiber itself plus everything that is superimposed 24 on it. 25 Q. In terms of -- other than the DOYLE REPORTING, INC. (212) 8 6 7- 8220 1 Langer 182 2 macrophage mortality study you mentioned, are you 3 aware of any studies that attempt to measure 4 whether calidria chrysotile is more or less 5 biologically active in the production of 6 asbestos - related disease than other types of 7 chrysotile? 8 A. I've seen no cohort studies so I 9 can't j udge that. 10 Q. Okay. Are you aware of anybody else 11 who has done papers attempting to compare the 12 performance of calidria versus other types of 13 chrysotile, I mean an experiment in animals - 14 A. Yes, there are a few of those. 15 Q. What studies are those? 16 A. Hartwig, Muhle, Pott, Maltoni, and 17 others. 18 Q. You mentioned Platek? 19 A. Frank Platek and colleagues at NIOSH. 20 Q. What did Muhle show in his study? 21 A. He showed it was not very active. 22 Q. Calidria was not active? 23 A. Yes . 24 Q. Less active than other types of 25 chrysotile? DOYLE REPORTING, INC. (212)867-8220 1 Langer 183 2 A. Yes. 3 Q. What did Pott show? 4 A. He wasn't too sure, although it 5 showed some activity but he didn't think it was 6 terribly dangerous. 7 Q. How about Maltoni? 8 A. Maltoni produced tumors. 9 Q. With calidria? 10 A. Yes. 11 Q. And none with - 12 A. But less than the other chrysotiles. 13 Q. And how about Platek and NIOSH? 14 A. No lung scarring in laboratory 15 animals, although Arnie Brody has reviewed these 16 and he thinks there is some scarring. 17 Q. But in any event, less than with 18 calidria? 19 A. Yes, that is myunderstanding. 20 Q. Now - - 21 A. I'm testifying to this -- this is my 22 recall . 23 Q. Right. 24 A. If I had allthe papers in front of 25 me, we could go over them in detail. DOYLE REPORTING, INC. ( 2 12 ) 8 6 7 - 8 2 2 0 Langer 184 Q . Right. A. Just trying to pull this out. Q. Right. This is your off-of -the-top-of-your-head recollection? A. That's right. Q, Would it be a fair summary of your off-the - top-of-your - head recollection of these papers that what they showed was to the extent that calidria is biologically active, if you will, it is somewhat less active than other types of chrysotiles? A. That is the general conclusion. Yes. Q. Do you agree or disagree with that c onclusion? A. Do I agree or disagree? I sit here and think about it. How were the materials prepared, were they comparing mass, were they comparing fiber number per unit. It is more difficult to evaluate. I can only tell you what they reported. We would have to go over the details of the study, so offhand I would say at first blush, yes, they -- it seems to be less active, but the details of it, I don't know. Q. Okay. Are you planning as part of DOYLE REPORTING, INC. (212)867-8220 1 Langer 185 2 your work in this case to do any kind of analysis 3 or critique of those studies? 4 A. Well, if I'm called to trial I would 5 more than likely pull them out of my file and 6 review them, sure. 7 Q. Are you aware of any studies, putting 8 aside the Yager paper for a minute, any studies 9 that show that calidria is more biologically 10 active than other types of chrysotile? 11 A. I can't think of any offhand. 12 Q.. You did some lung burden analysis of 13 lung fiber -- burden analysis, excuse me -- of 14 people who lived in New York City? 15 A. Yes. 16 Q. To attempt to measure the 17 biopersistence of asbestos, is that right? 18 A. Well, no, that was not the objective 19 of the study. 20 Q. Okay. Was that one of the 21 by-products of it? 22 A. That was a by-product of it, yes. 23 Q. And in that group of about 126 people 24 that were in your series - 25 A. Yes, 126, 128, something like that, DOYLE REPORTING, INC. (212)867-8220 Langer 18 6 right. Q. And in that group were both people who had occupational asbestos exposure and those who did not? A. Yes. Q. You found among the people without occupational asbestos exposure that there was chrysotile in the lung, is that right? A. That's correct. Q. I think you gave the count. A.- Above statistical background, I think half of them. 64 out of 128. Something like that. Q. For the people in New York with nonoccupational exposure to asbestos, what is the background level of fiber burden? A. It is pretty low. MR. BROWNSON: The people in his study? MR. WILL: Yes. A. It is not so much the quantities, although the quantities -- I think the highest level I found in a nonoccupationally exposed individual was in a man who was an 80, 81-year-old DOYLE REPORTING, INC. (212)867-8220 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 Langer 187 male who died of heart failure for which he had no -- he had five million fibers greater than five microns in length per gram of dry lung tissue. Per gram of tissue, put it that way. And that this was the highest of the nonoccupationally exposed. So for us it was a statistical outwire. Didn't have good follow-up on this person's occupational history, but we accept that as a background case. That was the highest, but most were much lower. 50 to a hundred thousand or 200,000, but it was very much lower. Q. Among those people that had nonoccupational exposure, did you find evidence of asbestos- associated disease? A. No. Q. Am I also correct that among those without occupational exposure. the type of fiber you found was chrysotile? A. Yes . Q. You also attempted to count the fibriles shorter than five microns? A. That's right. Everything. Q. Everything. Both longer and shorter? A. Yes . DOYLE REPORTING, INC. (212)867-8220 1 Langer 188 2 Q. And in those people without 3 occupational exposure, you did find significant 4 numbers of chrysotile fibriles below five microns 5 in length? 6 A. That is true, yes. 7 Q. Those counts are reported in your 8 paper? 9 A. That's right. 10 Q. Now, in the occupationally exposed 11 people, you did find some evidence of 12 asbestos-related disease, is that right? 13 A. Yes. 14 Q. And you also found long chrysotile 15 fibers in the occupationally exposed? 16 A. Yes. Yes. . 17 Q. Far more than in the 18 nonoccupationally exposed? 19 A. Yes. That was one of the 20 distinguishing characteristics. 21 Q. Is the length of the fiber in the 22 1 ung ? 23 A. Yes. 24 Q. You also found amphibole fiber in the 25 occupationally exposed? DOYLE REPORTING, INC. (212)867-8220 1 Langer 189 2 A. That is true. 3 Q. Did you do anycomparison of the 4 chrysotile fibrile burdens below five microns 5 between the occupationally exposed and the 6 nonoccupationally exposed? 7 A. I'm not sure. 8 Q. In terms of what caused the 9 asbestos - related disease in the occupationally 10 exposed, was it the long fibers, was it the 11 greater number of fibers, was it the greater 12 number of short fibers, what was it? 13 A. Well, this is by deduction from other 14 cohorts, that there are two factors that are 15 operative. Well, there are several factors 16 operative. Number one, the presence of 17 amphiboles. The dimension of the fiber itself. 18 The third factor which may be operative, the 19 mixture of fibers may represent some interesting 20 increase in risk. 21 Q. By mixture of fibers, you mean 22 having - - 23 A. Both chrysotile and an amphibole. 24 Q. In most cases both amosite and 25 crocidolite? DOYLE REPORTING, INC. (212)867-8220 1 Langer 190 2 A. Either/or. 3 Q. Has your research or reading 4 indicated anything that suggests that chrysotile 5 becomes more biologically potent when it is in the 6 lung with amosite? 7 A. No, I think it is the opposite. 8 Q. It becomes less potent? 9 A. With or without amosite. Chrysotile 10 with time may be detoxified, depending where it is 11 in the lung. 12 Q. And that is through this clearance 13 mechanism? 14 A. No. 15 Q. What is that that detoxifies it over 16 time? 17 A. Chemical degradation. It loses 18 magnesium from the surface. 19 Q. Whereas the amosite does not degrade? 20 A. Not as much, no. 21 MR. WILL: Let's take a quick break 22 and decide what we are going do do. 23 (Recess taken) 24 BY MR. WILL: 25 Q. Referring for a moment to the Yager, DOYLE REPORTING, INC. (212)867-8220 1 Langer 191 2 et al. article, what conclusions, if any, from the 3 results of that study did you draw? 4 A. Chrysotile is cytotoxic to human 5 cells, human macrophages, that the use of a mass 6 unit in a dose response study may be misleading 7 because the manipulation of the dust which alters 8 fiber number and surface area changes the outcome. 9 And we found that an asbestos sample in which the 10 absolute number of fibers greater than five 11 microns in length remained the same as the shorter 12 bundles were opened to a greater surface area, the 13 material became more cytotoxic. We felt that was 14 an interesting contribution. 15 Q. The relationship of surface area - 16 A. Yes. 17 Q. - - to toxicity? 18 A. And the most important part of that 19 study was never published but Kagan began to tell 20 you about that. 21 Q. Which part was that? 22 A. We had a cigarette - smoking 23 population, and the macrophages were killed more 24 effectively- 25 Q. With the cigarette smoking? DOYLE REPORTING, INC. (212)867-8220 1 Langer 192 2 A. Yes. And it follows everybody's 3 hypotheses that cigarette smoke exacerbates 4 asbestosis as well. 5 Q. Why wasn't it published? 6 A. Henry Yager just didn't get around to 7 it. That was the medical side of it. And we 8 said, "Publish it, Henry, this is interesting," 9 "Well, I would like to." 10 Q. In terms of the relationship between 11 killing alveomacrophages and producing asbestosis, 12 in your opinion is that what does it? 13 A. No. 14 Q. Okay. 15 A. No. I would prefer for a macrophage 16 to live and continue to generate chemical 17 substances under the generic heading cytokines, 18 specifically a subgroup called growth factors, and 19 that these stimulate the fibroblast population to 20 produce collagen. 21 Q. Could - - 22 A. So I would prefer a macrophage to 23 live and generate all of the chemical stuff than 24 to die. 25 Q. Would that suggest then that because DOYLE REPORTING, INC. (212)867-8220 1 Danger 193 2 the milled calidria had a higher macrophage 3 mortality rate that it would be less likely to 4 produce asbestosis in a human? 5 A. I would think yes, but others would 6 disagree. 7 Q. Disagree? 8 A. Of course. 9 Q. In terms of your findings about 10 surface area, do I understand correctly that what 11 you said is that as you get smaller fibers, you 12 have more surface area per given mass? 13 A. Yes. Thinner fibers, specifically. 14 Q. Because asthecalidriachrysotile 15 splits up, breaks up, it splits longitudinally? 16 A. Yes. It splits both ways but " 17 primarily longitudinally. 18 Q. It gets thinner and thinner? 19 A. Thinner and thinner. 20 Q. Rather than shorter and shorter? 21 A. Correct . it gets thinner and thinner 22 first, then shorter and shorter. 23 Q. Okay. Do you think that calidria 24 chrysotile is capable of producing pleural 25 mesothelioma in humans? DOYLE REPORTING, INC. (212)667-8220 1 Langer 194 2 A. If you get a high enough dose of it. 3 Q. How high a dose would you have to 4 have ? 5 A. Pretty good dose of that stuff. 6 Q. Higher than you think would have been 7 obtained at the Conwed plant from what you know 8 about the air samples? 9 A. Well, I don't know what the air 10 samples are telling me just yet, but I think in 11 order to produce pleural mesothelioma with 12 chrysotile, you would have to be exposed to 10 to 13 a hundred times more fiber than an amphibole. And 14 I'm quoting to you from some of my own data. And 15 I think that this follows some of the data that 16 exists in the literature, specifically some of 17 Andrew Churg's data, that is Jack's son, in which 18 these mesotheliomas occur and there is a lot of 19 fibers still in the tissue. 20 Q. Andrew Churg says that if you get 2 1 levels of exposure comparable to the World War II 22 shipyards, without that you will not get a 23 chrysotile mesothelioma, he said that, is that 24 right? 25 A. Yes, but that begs the question what DOYLE REPORTING, INC. (212)867-8220 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 Langer 195 were the levels. Q. O.K. A. Then we will talk about it. Q. Yes. All right. In terms of the ability to cause asbestosis in humans, what degree of exposure to calidria chrysotile do you think a person would have to have? A. I don't know. But it has to be like the others, high. Q. Higher than for mesothelioma? A. Yes. Q. How about for lung cancer, what degree of exposure? A. I believe it is the same. You need high levels. Q. The same asasbestosis? A. Yes. MR. WILL: I think this is a good time to stop. We are at 4:15. MR. BROWNSON: Okay. MR. WILL: What we have decided to do is to adjourn the deposition at this point to be reconvened, hopefully within DOYLE REPORTING, INC. (212)867-8220 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 Langer 196 the next week, or two in conjunction with another trip out here when we have got other depositions in this case. I told Mr. Brownson that I was not going to use the fact that we were unable to finish Dr. Langer today as a reason to refuse to produce my witnesses, so we will work on the scheduling of those people. In terms of the exhibits that we had today, what I would like to do is to give Exhibits 1, 2 and 3 to the court reporter and have those attached to the transcript. So, Doctor, if I may I'll take your CV back. ~ THE WITNESS: Fine. ' MR. WILL: I would like Dr. Langer to get, through Mr. Brownson, a copy of Exhibits 4-A, B and C, 5, 6 and 7 for us. Is that all right? MR. BROWNSON: Yes. MR. WILL: And he can retain the originals of those, but if you would please get those. The other thing that I would ask is DOYLE REPORTING, INC. (212)867-8220 1 2 3 4 5 6 7 e 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Langer 197 that Dr. Langer try to complete whatever further analysis that he wants to do of that one fiber before we reconvene the deposition so when we wrap up the deposition, we can wrap up all of his work on the analysis. MR. BROWNSON: Okay. THE WITNESS: Okay. That sounds all right to me. MR. WILL: Is that all right? MR. BROWNSON: I've got your card. (Time noted: 4:28 p.m.) Subscribed and sworn to before me thisday of, 1994. DOYLE REPORTING, INC. (212)867-8220 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 196 ilRlUILAli STATE OF NEW YORK COUNTY OF NEW YORK ) ) SS . : ) I, ROBERT E. LEVY, a Certified Shorthand Reporter and Notary Public within and for the State of New York, do hereby certify: That I reported the proceedings in the within entitled matter, and that the within transcript is a true record of such proceedings. I further certify that I am not related, by blood or marriage, to any of the parties in this matter and that I am in no way interested in the outcome of this matter. 1 199 2 January 14, 1994 3 4 Witness 5 Arthur M. Langer LN R Page 4 6 7 H1&1I 8 Lanoer For Ident. 91 Curriculum vitae of Arthur M. Langer 10 2 Notice of deposition 11 3 Document entitled "Mineralogical 12 Analysis of Chrysotile Ore Specimens Obtained in the KCAC 13 Pit (Formerly Union Carbide's New Idria Deposit), Summary" 14 4 - A, 4 -B 15 and 4 -C Photographs 5 5 6 88 16 5 Report 117 17 6 California staff report 118 18 7 Notes 119 19 oOo 21 22 23 24 25 DOYLE REPORTING, INC. (212)867-8220 CTTRRICPLUM VITAB Arthur M. Danger, Ph.D CURRENT POSITION: ADDRESS: Director, Environmental Sciences Laboratory of the Institute of Applied Sciences, Brooklyn College of the City University of New York, Brooklyn, NY 11210. Professor of Geology, Department of Geology, Brooklyn College. Associate Director of the Center for Applied Studies of the Environment, Applied Science Coordinating Institute, City University of New York. Office: Environmental Sciences laboratory Ingersoll Hall - Room 5144-6 Brooklyn College of the City University of New York Brooklyn, NY 11210 (718) 951-4793; 951-4242 (718) 951-4438 FAX Home: 6 Rochambeau Drive Hartsdale, NY 10530 (914) 428-3667 DATE 07 BIRTH: February 18, 1936 PLACE 07 BIRTH: New York, NY ACADEMIC DEGREES B.A., Geology, Hunter College-CUNY, New York, NY, 1956. M.A., Petrology (Geology), Columbia University, New York, NY, 1962. Ph.D., Mineralogy (Geology), Columbia University, New York, NY, 1965. PREVIOUS POSITIONS: Associate Professor, Center for Polypeptide and Membrane Research, Mount Sinai School of Medicine, New York, NY 1986-1988. Associate Professor, Mineralogy, Department of Community Medicine, Mount Sinai School of Medicine, New York, NY, 1968-1986, 1987-1988. Ph.D., Graduate Faculty, Program: Earth and Environmental Sciences, City University, New York, NY, 1982-present. Science Administrator, Environmental Sciences Laboratory, Mount Sinai School of Medicine, New York, NY, 1983-1984. Research Associate, Department of Mineral Sciences, American Museum of Natural History, New York, NY, 1979-present. IywufSjgy***1 I Robert E Uvy C S R ft/ 1 / Ooyie Reporting, inc /fif IllUj&te LARGER, ARTHUR X. PAGE 2 PREVIOUS POSITIONS (cont) Associate Director, Environmental Sciences Laboratory, Mount Sinai School of Medicine, New York, NY, 1969-1986. Head, Physical Sciences Section, Environmental Sciences Laboratory, Mount Sinai School of Medicine, New York, NY, 1969-1986. Adjunct Associate Professor, Mineralogy, Graduate Division, City University of New York, NY, 1968-1969. Assistant Professor, Mineralogy, Department of Community Medicine, Mount Sinai School of Medicine, New York, NY, 1967-1968. # Research Associate, Environmental Medicine, Department of Medicine, Mount Sinai Hospital, New York, NY, 1965-1967. Lecturer, Geology, City College of City University of New York, NY, 1964-1965. Research Assistant, Mineralogy, Department of Geology, Columbia University, New York, NY, 1961-1964. Teaching Assistant, Economic Geology, Department of Geology, Columbia University, New York, NY, 1959-1960. Teaching Assistant, Department of Geology, Columbia College, New York, NY, 1958-1959. Field Assistant, Geology, Beartooth Mountains, MT, Columbia University, 6/57-8/57. Field Assistant, Geology, Beartooth Mountains, MT, Columbia University, 6/58-8/58. Exploration Geologist, Rosario Exploration Chibougamau Mining and Smelting, 6/56-8/56. Consulting Mineralogist, Columbia University, New York, NY: -TAMS Dam site, East Pakistan, WHO, 1960 (with Professor Fairbridge). -Consulting Mineralogist, American Metals Climax, 1961 (with Professor Kerr). -Consulting Mineralogist, Creole Oil Company, 1962 (with Professor Kerr). -Tidewater Oil Company, 1962 (with Professor Kerr). -Texas Gulf Sulphur Company, 1965 (with Professor Kerr). FELLOWSHIPS: Research Mineralogist, Department of Geology, Columbia University, New York, NY. Sponsored by the U.S. Air Force Cambridge Research Laboratories under the direction of Prof. P.F. Kerr, 3/61-9/63. MEMBERSHIPS AMD OTHER PROFESSIONAL ACTIVITIES: Fellow, Geological Society of America. Fellow, Kineralogical Society of America. Fellow, New York Academy of Sciences. Fellow, Collegium Ramazzini. Geochemical Society. LARGER, ARTHUR M. PAGE 3 MEMBERSHIPS AMD OTHER PROFESSIONAL ACTIVITIES (COnt): American Association for the Advancement of Science. Electron Microprobe Society of America. Sigma Xi, Kappa Chapter (Honorary Scientific). International Association of Bioinorganic Scientists. HONORS AMD AWARDS: Honors, Department of Geology, Hunter College, New York, NY, 6/56. Sigma Xi, Kappa Chapter, Columbia University, New York, NY, 9/64. Dust Research, Polachek Foundation Award, 9/65-6/67. Career Scientist Award, National Institute of Environmental Health Sciences, 6/69-5/74. Phi Beta Kappa, Nu Chapter, Hunter College, New York, NY, 6/77. Hunter College Hall of Fame HC-CUNY, 6/78. Biography in: American Men of Science; Who's Who in the East; Who's Who in America (September, 1992). Elected Fellow, Collegium Ramazzini, 1983. EXPERT CONSULTANT: Atlantic Legal Foundation. Amici Curiae in support of respondents to the Supreme Court of the United States. October Term, 1992. Daubert et.al. Petitioners v. Merrell Dow Pharmarceuticals,Inc., Respondent. Environmental Protection Agency, Superfund Present. Cases, 3/85- National Institute for Occupational Safety and Health, 6/75- Present. , _._ National Institute for Environmental Health Sciences, 4/75Present. Environmental Protection Agency, 6/75-Present. National Heart, Lung and Blood Institute, 6/75-Present. National Institutes of Health, Section of Grants, 6/74Present. World Health Organization, Geneva, Biomedical Expert, 6/75Present. GRADUATE THESES: - Gepjpqy g & Manhattan Formation. Submitted in partial fulfillment for the degree of Master of Arts, in the faculty of Pure Science, Columbia University, NY, p. 132, 1962. Hinaralagy Physical Properties & ttPlave Desert Plava Crusts. Submitted in partial fulfillment for the degree of Doctor of Philosophy, in the faculty of Pure Science, Columbia University, NY, p. 155, 1965. LANGER, ARTHUR M PAGE 4 EDITORIAL BOARD SERVICE: Assistant Editor, Environmental Research, 1978-1985. Advisory Editor, Environmental Research, 1985-1987. Assistant Editor, American Journal of Industrial Medicine, 1980-1985. Associate Editor, American Journal of Industrial Medicine, 1985-1986. Editorial Review Board, Journal of Environmental Pathology and Toxicology, 1978-1982. Editorial Advisory Board, Advances in Modem Environmental Toxicology, 1981-1982. Editorial Review Board, Journal of Environmental Pathology Toxicology and Oncology, 1983-Present. REVIEW MANUSCRIPTS (Journals other than those cited above): Journal of Histochemistry and Cytochemistry. Pharmacology Reviews. American Chemical Society Reviews. Advances in Chemistry Annals New York Academy Sciences. Science (AAAS). SEM-IITRI Symposia. Lung. American Review of Respiratory Diseases. American Mineralogist. Clay Minerals Society (Clays and Clay Minerals). Canadian J. Fisher Aquatic Sciences. Journal National Cancer Institute. American Journal Pathology. Annual Meeting SEMA. Chest. Laboratory Investigations. . Journal of the American Medical Association. New England Journal of Medicine. Toxicology In Vitro. Journal of the American Industrial Hygiene Association Annals of Occupational Hygiene Pathology Annual Environmental Health Perspectives Health Effects Institute American College of Chest Physicians - REVIEW AND AUTHOR FEDERAL, INDUSTRY DOCUMENTS (1978-PRESENT): NIOSH Fibrous Glass Criteria Document, 1978. Reviewer. Federal. NIOSH Talc Criteria Document, 1979. Reviewer, contributor. Federal. OSHA Fiber Manuscript (Definitions, Nomenclature, Properties), 1980. Reviewer. Federal. LANGER, ARTHUR M PAGE 5 REVIEW AND AUTHOR FEDERAL, INDUSTRY DOCUMENTS (1978-PRESENT) (cont)s ALOSH Mineralogy Manuscripts (Occupational Lung Disease), 1979-1980. Reviewer, contributor. Federal. Report on Tobacco and Asbestos Interaction, Commercial Union Insurance, 1982. Contributor. Industry. Environmental Protection Agency, Office of Pesticides and Toxic Substances-Asbestos in Buildings Guidance Documents; Guidance Documents; Operations and Maintenance Programs. "Orange", "Purple", "Blue" Books. Reviewer, contributor. Federal. Surgeon General's Report: Cancer and Chronic Lung Disease in the Workplace: The Health Consequences of Smoking, 1985. Reviewer, contributor. Reviewer, contributor. Federal. INTERNATIONAL COMMITTEES AND CONSULTATIONS (1979-PRESENT): US-Japan Cooperative Science Program Working Group on Air Pollution and Health. NIEHS-Institute of Health, Japan, February, 1969. International Agency for Research on Cancer, WHO Development of V. 14 Chemical Carcinogenesis Monograph Series, Evaluation of Carcinogenic Risk of Chemicals to Man: Asbestos. Member of working group, Lyon, France, 1976. International Association of Geochemistry and Cosmochemistry, Working Group on the Geochemistry of Health and Disease, 1976-1979. Consultant, South African Ministry of Mines, Asbestos Symposium, Johannesburg, South Africa, 1977. Consultant, Institute of Public Health, Norway, Microscopy Facility, Oslo, Norway, 1977. Seminars on vitreous fibers as asbestos substitutes. Consultant, International Metalworkers Federation, Problems Focusing on Asbestos Contamination of Nickel Ores, Geneva, Switzerland, 1980. Research Consultant, Societe Nationale de l'Amiante, Quebec, Canada, Work on Modified Fiber, 1984. WHO-International Program on Chemical Safety (IPCS), Environ mental Health Criteria Document on Asbestos and Other Natural Mineral Fibers, Section Chairman, Hannover, Federal Republic of Germany, 1985. Organizing Committee, Third International Conference, In - Vitro Effects of Mineral Dusts, Schluchsee, Federal Republic of Germany, 1984. Societe Nationale de l'Amiante. Consultant. Modified Fiber and the Environmental Protection Agency Asbestos Ban, Montreal, Canada, 1986. LANGER, ARTHUR M. PAGE 6 INTERNATIONAL COMMITTEES AND CONSULTATIONS <1979-PRESENT) (cont)S International Agency for Research on Cancer, WHO Development of V.42, Chemical Carcinogenesis Monograph Series, Evaluation of Carcinogenic Risk to Chemicals in Man: Silica and Some Silicates, Member of Working Group, Lyon, France, 1986. Consultant, Asbestos Institute, Canada, Organization of Symposium on Biological Effects of Asbestos Substitutes, 1987. Vllth International Pneumoconiosis Conference. International Organizing Committee; Organizer of Session: Hazard Recognition of Mineral Dust. Pittsburgh, PA, August, 1988. Chaired Two Sessions at Meeting: Mineral Recognition by Membranes and Mineral Toxicity; Mineral Fiber and Diseases of the Pleura. International Federation of Building and Wood Workers, Conference on Interior Works, Geneva, Switzerland. Presented paper: Hazards in the Painting Trades. Panel on Hazards in the Interior Workplace, May 9-12, 1989. NATIONAL COMMITTEES/ CONSULTATIONS: Food and Drug Administration, Asbestos, Talc, Asbestos Bodies,and Consumer Talcums, Seminar, Washington, DC, June, 1968. National Air Pollution Control Administration, Asbestos in Ambient Air. Arlington, VA, June, 1969. National Institute for Occupational Safety and Health, USPHS, Asbestos Research in the United States, Cincinnati, OH, January, 1970. Food and Drug Administration, Asbestos in Consumer Talcums, Seminar, Washington, PC, August,, .1971, Environmental Protection Agency, National Air Pollution Control Techniques Advisory Committee, Asbestos Emissions Document, Atlanta, GA, 1971. NIOSH Task Force on Occupational Respiratory Diseases, 1975. Environmental Protection Agency, HERL, Ad Hoc Committee for the Fibrous Amphibole Study Protocol, Triangle Park, NC, 1976. NIEHS-NIOSH-EPA-ERDA. Interagency Retreat and Colloquium. Man-made Vitreous fibers, Asbestos Substitutes and the Energy Crisis. Potential Risks to Health. Pinehurst, NC. 7-9 January, 1976. _ NIOSH Criteria Document Recommended Standard For Occupational Exposure to Fibrous Glass, Reviewer. November, 1976. Environmental Protection Agency, HERL, Biological Effects on Fibrous Inorganic Particles, 1977. DHHS, Interagency Committee to Coordinate Environmental and Related Problems, Biological Effects of Fibrous Particulates: Serpentine-Containing Host Rocks, Amphibole-Containing Host Rocks, 1980. LANGER, ARTHUR M. PAGE 7 NATIONAL COMMITTEES, CONSULTATIONS (ooBt): Mount St. Helen*s Volcanic Ash: Mineral Nature and Biological Activity, Interagency Task Force, Bethesda, MD, 1980. NHLBI, Evaluation of Existing Inorganic Microparticulate Laboratories: Vermont Lung Group, Tulane Occupational Lung Hazards Group, 1978. National Institute of Environmental Health Sciences, Workshop, Pathobiology of Mesothelioma, RTP, NC, January, 1983. Occupational Safety and Health Administration, Expert to write and review Asbestos Standard-Talc Standard, US Department of Labor, 1983. National Academy of Sciences, Division of Life Sciences Com mittee to Evaluate Risk to Low-Level Exposure to Asbestiform Fibers in the Environment, 1982-1984. Environmental Protection Agency. Prepared for meeting Substitute Fibers. Pre-market Testing of Fibers. USEPA, Washington, DC. 26 June 1984. Environmental Protection Agency, Committee Member, Review and Rewrite EPA "Guidance Document for Controlling Friable Asbestos-Containing Minerals in Buildings," 1985. American Society Testing Materials, Committee, D22-Indoor Air Pollution Asbestos: D22.05-Methodology and Measurement of Fibers in Air. Electron Microscopy, 1985. American Society Testing Materials, Organizing Committee, Silica and Silica-Induced Diseases, International Conference, 1985. NIOSH, Mine Health Research Advisory Committee Meeting, Tucson, AZ: The Impact of Mineral-Asbestos Definitions on the Mining Industry, 1986. Environmental Protection Agency. Develop guidance document for Identifying asbestos hazards and implementing abatement programs in public buildings, Washington, DC, April, 1986. NIOSH Review Panel for Project "Evaluation of Mesothelioma Production by Asbestos Substitutes." Cincinnati, OH, June, 1986. Environmental Protection Agency, Guidance Document for Assessing and Managing Exposure to Asbestos in Building, Arlington, VA, September, 1986. Environmental Protection Agency, Operations and Maintenance Programs for Asbestos-Containing Materials in Buildings: A Guide for Building Owners and Managers, Washington, DC, _ January, 1987. NIEHS-NIOSH - National Toxicology Program. To formulate study protocol comparing biological activities of asbestiform and non-asbestiform amphibole minerals. NIEHS - Res. Triangle Park, NC, October 11, 1989. Health Effects Institute. Asbestos Literature Review Panel. April, 1990 - August, 1991. Health Effects Institute. Reviewer of Research proposals - RPI-1-91. LANGER, ARTHUR M. PAGE 8 TESTIMONY - FEDERAL AGENCIES Expert Testimony, Toxic Substances Control Act, 1973. Provided evidence to Sen. Tunney's committee hearing, Washington, D.C. Expert Witness, Contamination of Lake Superior. On behalf of the Department of Justice of the United States, 1974. Minneapolis, MN. Expert Testimony, Occupational Safety and Health Administration, US Department of Labor, Asbestos Standard, 1984. Washington, D.C. Expert Testimony, Consumer Products Safety Commission. Asbestos in Play Sand. Washington, DC, December 7, 1988. Expert Testimony Occupational Safety and Health Administration, U.S. Department of Labor. Asbestos Standard Revisions. April, 1990. Washington, D.C. REGIONAL CONSULTATIONS: Health Research Council of New York City, Subcommittee on Asbestos Hazards - Air Pollution Working Corp. Seminar on Asbestos in Construction Products, Rockefeller University, June 9, 1969. New York City Board of Education: Asbestos in Schools, 1981 1983. New York City Department of Sanitation? Fire Department: Insulation Products, 1979-1983. New York State Consumer Affairs and Protection: Construction and Insulation Products, 1980-1983. City University of New York-Brooklyn College: Asbestos Problems, 1981-1982. ACADEMIC COMMITTEES: Academic Council, Department Representative, MSSM, 1977-1979. Medical Center Safety Committee, MSSM, 1979-1988. Chemical Hazards Committee, MSSM, 1979-1988. Alternate Medical Safety Officer (in absence of Dr. S. Kochwa), MSSM, 1980-1983. Space Committee (Department and Institution), MSSM, 1982-1985. New York Academy of Sciences, Conference Organizing Committee, 1976-1980. Visiting Professor Program. Mt. Sinai School of Medicine. _ 1971-1973. Educational Policy Committee. Mt. Sinai School of Medicine. 1972-1974. _ Ad Hoc Reviewer, National Institutes of Health, Minneapolis Medical Center, 1977. Ad Hoc Reviewer, National Institutes of Health, Harvard Medical Center, 1978. LANGER, ARTHUR M. PAGE 9 ACADEMIC COMMITTEES (cont): Workshop Organizer and Chairman, Significance of Aspect Ratio in Asbestos Diseases, New York Academy of Sciences, 1977. Workshop Organizer, Third International Workshop on Vitro Testing of Mineral Dusts, 1984. Executive Committee, Ph.D. Program, Earth and Environmental Sciences, City University of New York, 1985. Curriculum and Examination Committee, Ph.D. Program, Earth and Environmental Sciences, City University of New York, 1987-1990. Faculty Membership Committee - Chairman - Ph.D. Program, Earth and Environmental Sciences, City University of New York, 1989-present. CONSULTANT: Cyprus Minerals-Nature of US Talc Deposits, 1979. General Accident Insurance Company: Asbestos Compensation, 1981. Gulf Minerals: Modified Chrysotile Fiber, 1982. Oil, Chemical and Atomic Workers International Union, Safe Handling of Asbestos, Training Film, 1976. Lung Center and NHLB-SCOR, in the Departments of Physiology, Medicine, Pathology, and Engineering in the University of Vermont, Burlington, VT, 1984. Societe Nationale de 1'Andante: Phosphorylated Fiber? Asbestos Substitutes, 1984. w.R. Grace & Company: Asbestos and Indoor Air Pollution, 1984. Asbestos Institute of Canada, Asbestos and Asbestos Substitutes, 1985-1986. Litigations. Represented numerous plaintiffs,- defendants7~ insurance carriers, US Department of Justice, Brooklyn and New York counties1 District Attorneys. R.T. Vanderbilt Company, Nature of Tremolite in the Gouverneur Talc Deposit, 1987. Safe Building Alliance, Problems of Asbestos in Buildings, 1987. Review applications for funding requests: FCAC, Quebec, Canada, 1985. Battelle Columbus Laboratories: Analysis of Microparticles by Analytical Electron Microscopy, 1987-1989. INDUSTRY PROJECT REPORTS: Chrvsotile and chrvsophosphate. A comparative study of their physicochemical properties and membrane activities. A report to SNA-Chrysophosphate, Canada. Danger AM, Nolan RP, p 87, June 1, 1987. LARGER, ARTHUR M. PAGE 10 INDUSTRY PROJECT REPORTS (cont): Wollastonite in the pulmonary tissues on animals. A report to Northrop Services Industries, National Toxicology Program. Langer AH, Nolan RP, p. 101, June 15, 1989 Preparation, examination and characterization of mineral standards bv analytical electron microscopy. A report to Battelle Columbus Laboratories, Langer AM, Nolan RP, Pooley FD, Gieseke JA, Fisher G, 61 p., December 12, 1989. Comparison and evaluation of the analytical capabilities of three U.S. laboratories for submicroscopic particulate analysis. A report to Battelle Columbus Laboratories, Langer AM, Nolan RP, Gieseke JA, Fisher G. February, 1991. The Identification and Quantitation of Small Asbestos Fibres in Injectable Medicines. Technical Expert Report Prepared for Hoffman-LaRoche, Basel. 16 p. Addison J, Burdett GJ, Langer AM, Muhle H. 1993 GOVERNMENT PROJECT REPORTS: Asbestifpryi___Fibers___=___Non-Occupational Health Risks. Academy of Sciences. National Research Council. Academy Press, 334 p., 1984. National National Report____to____the___ILS,_____Consumer____Product Safety commission: Mineralogical Analysis of Two "Play Sands" For Their Asbestos Contents. Langer AM, Nolan RP. 26 November, 1986. 9p., 4 Tables, 18 plates. Report to the U.S. Consumer Product Safety Commission: Mineral Analysis, of a Carbonate Plav Sand. Langer AM, Nolan RP. July, 1987. 19 p., 3 Tables, 8 plates. Asbestos in Public and Commercial Buildings; A Literature Review and Synthesis of Current Knowledge. Health Effects Institute, Cambridge, MA and U.S. Environmental Protection Agency. 300 p., 1991. INTERNATIONAL DOCUMENTS: Evaluation of Carcinogenic Risk of Asbestos. Volume 14. Asbestos. Series. IARC Monographs on the Evaluation of Carcinogenic Risk of Chemicals to Man. Inti Agency for Res. on Cancer - WHO, Lyon. 106 p. 1977. Co-author, Panel Member. ~ International Programme on Chemical Safety (IPCS). WHO. Environmental Health Criteria 53: Asbestos and Other Natural Mineral Fibres. 194 p., 1986. Co-author, Panel Member. Silica and Some Silicates. Volume 42. Series IARC Monographs on the Evaluation of Carcinogenic Risk of Chemicals to Man. Inti Agency for Res. on Cancer - WHO, Lyon. 289 p., 1987. Co author, Panel member. LANGER, ARTHUR K. PAGE 11 PUBLICATIONS IN PEER-REVIEWED JOURNALS 1. Kerr PF, Thomas AM, Langer AMs The nature and synthesis of ferrimoiybdite. Am Mineral 48:14-32, 1963. 2. Kerr PF, Langer AM: Mineralogical features of Mojave playa crusts. In: Mineralogy and Hydrology of PS Plavas. Neal J (ed), US Air Force Cambridge Research Laboratories Environmental Research Paper No. 96, pp. 31-72, 1965. 3. Langer AM, Kerr PF: Experimental variables influencing DTA curves of kaolinite. Dupont Thermogram 3:1-4, 1966. 4. Langer AM: Older paleozoic metamorphism and pegmatization in Bronx, New York. Ann NY Acad Sci 136:1-32, 1966. 5. Langer AM, Kerr PF: Mojave Desert playa crusts: physical properties and mineral content. J Sed Patrol 36:377-396, 1966. 6. Langer AM, Kerr PF: Evaluation of kaolinite and quartz differential thermal curves with a new high-temperature cell. Am Mineral 52:509-523, 1967. 7. Berkley C, Langer AM, Baden V: Instrumental analysis of inspired pulmonary particulates. Trans NY Acad Sci 30:331 350, 1967. 8. Neal JT, Langer AM, Kerr PF: Giant desiccation polygons of Great Basin playas. Bull Geol Soc Am 79:59-90, 1968. 9. Langer AM, Bowes DR: Polyphase deformation in the Manhattan formation of Manhattarr-Island, New York City. Memoir 115 Geol Soc Am 358-373, 1969. 10. Langer AM, Selikoff IJ, Sastre A: Chrysotile asbestos in the lungs of persons in New York City. Arch Environ Health 22:348-361, 1971. 11. Langer AM, Mackler AD, Rubin IB, Hammond EC, Selikoff IJ: Inorganic particles in cigars and cigar smoke. Science 174(4009):585-587, 1971. 12. Selikoff IJ, Nicholson WJ, Langer AM: Asbestos air pollution in urban areas. Arch Environ Health 25:1-13, 1972. 13. Liebling R, Langer AM: optical properties of fibrous brucite from asbestos, Quebec. Am Mineral 57:857-864, 1972. 14. Langer AM, Rubin IB, Selikoff, IJ: Chemical characterization of asbestos body cores by electron microprobe analysis. J Histochem Cytochem 20 (9):723-734, 1972. LANCER, ARTHUR M PACE 12 PUBLICATIONS IN PEER-REVIEWED JOURNALS (coat): 15. Langer AM, Rubin IB, Selikoff IJ, Pooley, FD: Chemical characterization of uncoated asbestos fibers from lungs of asbestos workers by electron microprobe analysis. J Histochem Cytochem 20(9):735-740, 1972. 16. Bowes DR, Langer AM: Petrochemistry of the Manhattan formation, New York City. Krystalinikum 10:39-51, 1974. 17. Langer AM, Ashley R, Baden V, Berkley C, Hammond EC, Mackler AD, Maggiore CJ, Nicholson WJ, Rohl AN, Rubin IB, Sastre A, Selikoff IJ: Identification of asbestos in human tissues. J Occup Med 15:287-295, 1973. 18. Ehrenreich T, Mackler AD, Langer AM, Selikoff IJ: Les fibers d'amiante dans les poumons humains: leur signification medicolegale dans les maladies de 1'environment. Arch des Maladies Professionelles 34(4-5):189-204, 1973. 19. Bowes DR, Langer AM: Hornblende schists in the Manhattan formation in the Bronx, New York:Discussion. Bull Geol Soc Am 84:1483-1490, 1973. 20. Ehrenreich T, Mackler AD, Langer AM, Selikoff IJ: Identification and characterization of pulmonary dust burden in pneumoconiosis. Ann Clin Lab Sci 3(2):118-131, 1973. 21. Kleinfeld M, Messite J, Langer AM: A study of workers exposed to asbestiform minerals in commercial talc manufacture. Environ Res 6(2):132-143, 1973. 22. Nicholson WJ, Langer AM, Selikoff IJ: Discussion: asbestos fibers in the air of towns. Atmosph Environ 7:666-668, 1973. 23. Langer AM: Inorganic particles in human tissues and their association with neoplastic disease. Environ Health Perspect 9:229-233, 1974. 24. Langer AM: Approaches and constraints to identification and quantitation of asbestos fibers. Environ Health Perspect 9:133-136, 1974. 25. Langer AM: Research perspectives concerning asbestos minerals and their effects on biological systems. Environ Health Perspect 9:335-338, 1974. 26. Langer AM: The subject of continuous vigilance. Health Perspect 9:53-56, 1974. Environ 27. Rohl AN, Langer AM: Identification of asbestos in talc. Environ Health Perspect 9:95-109, 1974. LANGER, ARTHUR N PAGE 13 PUBLICATIONS IN PEER-REVIEWED JOURNALS (cont): 28. Langer AM, Mackler AD, Pooley FD: Electron microscopical investigation of asbestos fibers. Environ Health Perspect 9:63-80, 1974. 29. Miller A, Langer AM, Teirstein, AS, Selikoff IJ: "Non specific" interstitial fibrosis: association with fibers detected by electron microscopy. N Engl J Med 292:91-93, 1975. 30. Rohl AN, Langer AM, Selikoff IJ, Nicholson WJ: Exposure to asbestos in use of consumer spackling, patching, and taping compounds. Science 189(4204):551-553, 1975. 31. Rohl AN, Langer AM, Klimentidis R, Wolff MS: Asbestos exposure during brake lining maintenance and repair. Environ Res 12:110-128, 1976, 32. Rohl AN, Langer AM, Selikoff IJ, Tordini A, Klimentidis R, Bowes DR, Skinner D: Mineral and chemical characterization of selected consumer talcum products. J Toxicol Environ Sci 2:255-284, 1976. 33. Bowes DR, Langer AM, Rohl AN: Nature and range of mineral dusts in the environment. Phil Trans Roy Soc London 286:593 610, 1977. 34. Rohl AN, Langer AM, Klimentidis R, Wolff MS, Selikoff IJ: Asbestos content of dust encountered during brake maintenance and repair. Proc Roy Soc Med 70:32-39, 1977. 35. Rohl AN, Langer AM, Selikoff IJ: Environmental asbestos pollution related to use of quarried serpentine rock. Science 196:1319-1322, 1977. 36. Langer AM, Wolff MS, Rohl AN, Selikoff IJ: Variation of properties of chrysotile asbestos, subjected to prolonged milling. J Toxicol Environ Sci 4:173-188, 1978. 37. Fischbein A, Langer AM, Suzuki Y, Selikoff IJ: Carcinoma of the lung in a drywall taping worker: report of a case. Toxicol Letters 2:231-236, 1978. 38. Langer AM: Crystal faces and cleavage planes in quartz as templates in biological processes. Quart Rev Biophys 11:543 575, 1978. 39. Rohl AN, Langer AM, Selikoff IJ: Airborne asbestos in the vicinity of a freeway: discussion. Atmosph Environ 12:2030 2031, 1978. LANGER, ARTHUR X. PAGE 14 PUBLICATIONS IN PEER-REVIEWED JOURNALS (co&t): 40. Langer AM, Rohl AN, Selikoff IJ: Asbestos on Maryland1s roads. The Lancet i:1263-1264, 1978. 41. Fischbein A, Rohl AN, Langer AM, Selikoff IJ: Drywall construction and asbestos exposure. Am Industr Hyg Assoc 40:402-407, 1979. 42. Langer AM, Rohl AN, Selikoff IJ, Harlow G, Prinz M: Asbestos as a co-factor among nickel processing workers. Science 209:420-422, 1980. 43. Nolan RP, Langer AM, Harington JS, Oster G, Selikoff IJ: Quartz hemolysis as related to its surface functionalities. Environ Res 26:503-520, 1981. 44. Rohl AN, Langer AM, Moncure G, Fischbein AS, Selikoff IJ: Endemic pleural disease associated with mixed fibrous dust exposure in Turkey. Science 216(4545):518-520, 1982. 45. Langer AM,. McCaughey WET: Mesothelioma in a brake repair worker. The Lancet ii:1101-1103, 1982. 91-95, 1992. 46. Ehrenreich T, Espinoza T, Langer AM, Rohl AN, Daum SM: Algorithm for forensic pathological diagnosis of asbestosrelated diseases. Am J Foren Med Pathol 3(4):315-321, 1982. 47. Langer AM, Rohl AN, Fischbein AS, Selikoff IJ: Cancer in nickel processing workers in New Caledonia: discussion. Science 215:425-426, 1982. s/48. Yeager H, Russo D, Yanez M, Gerardi D, Nolan RP, Kagan E, Langer AM: Preliminary observations on acute cytotoxicity of short fiber chrysotile asbestos for human alveolar macrophages. Environ Res 30:224-232, 1983. 49. Brody J, Miller A, Langer AM: Pneumoconiosis associated with exposure to glass and abrasive fragments. Am J Industr Med 6:339-346, 1984. 50. Constantopoulos S, Goudevenos J, Saratzis N, Charalampopoulos C, Laparidou S, Langer AM, Selikoff IJ, Moutsopoulos H: Endemic asbestos-like pleural calcifications in the absence of occupational asbestos exposure. Arch Hellenic Med 1(10):165171, 1984. 51. Sawyer R, Rohl AN, Langer AM: Fiber contamination in buildings resulting from removal of asbestos-containing materials. Environ Res 36(i):46-55, 1985. LANGER, ARTHUR It. PAGE 15 PUBLICATIONS IN PEER-REVIEWED JOURNALS (cont): 52. Constantopoulos SH, Goudevenos JA, Saratzis N, Langer AH, Selikoff IJ, Moutsopoulos HM: Metsovo lung: pleural calcification and restrictive lung function in northwestern Greece. Environmental exposure to mineral fiber as etiology. Environ Res 38:319-331, 1985. 53. Langer AM, Nolan RP: Asbestos in potable water supplies and attributable risk of gastrointestinal cancer. Northeast Environ Sci 5(1/2):41-53, 1986. 54. Langer AM, Nolan RP, Constantopoulos SH, Moutsopoulos HM: Association of Metsovo lung and pleural mesothelioma with exposure to tremolite-containing whitewash. The Lancet i:965967, 1987. 55. Nolan RP, Langer AM, Weisman I, Herson R: Surface character and membrolytic properties of the titania polymorphs. Br J Ind Med 44 (10):687-698, 1987. 56. Nolan RP, Langer AM, Eskenazi RA, Herson GB, Foster KW: Membranolytic activities of quartz standards. Toxicol In Vitro 1(4):239-245, 1987. 57. Langer AM, Nolan RP: Fiber type and mesothelioma risk. Symposium of Health Aspects of Exposure to Asbestos in Buildings. Energy and Environmental Policy Center, Kennedy School of Government. Harvard University. December, 1989, 91-141. 58. Freed JA, Miller A, Gordon R, Fischbein A, Kleinerman J, Langer AM: Desquamative interstitial pneumonia associated with chrysotile asbestos fibers. Br J Ind Med, 332-337, 1991. 59. Nolan RP, Langer AM, Herson GB: Characterization of palygorskite specimens from different geological locales for health hazard evaluation. Br J Ind Med, 4JS.: 463-475, 1991. v/' 60. Langer AM, Nolan RP: Comparison of lung tissue mineral fiber retention of exposed workers and the general population. Env. Health Perspect. in press. >/61. Nolan RP, Langer AM, Addison J: Lung content analysis of cases occupationally exposed to chrysotile asbestos. Env. Health Perspect. in .Prftfff. 62. Langer AM, Nolan RP: Chrysotile: Its Occurence and Properties as variables controlling Biological Effects. Ann. Occup. Hyg., in press. LANGER, ARTHUR M. PAGE 16 PUBLICATIONS IN SYMPOSIA PROCEEDINGS: 1. Berkley C, Langer AM, Sastre A, Arneson A: Electron microprobe analysis of asbestos bodies. In: Int11 JConferenz uber die Biologischen Wirkunoen des Asbestos, Dresden, 22-24 April, 1968. Holstein, Anspach M (eds), Deutsches Zentralinstitut fur Arbeitsmedizin, Berlin, DDR, pp. 12-22. 2. Schwartz J, Langer AM: Technique of removal and analysis of single fibrous particles from human lung tissue. In: Int11 Konferenz uber die Biologischen Wirkunoen des__Asfrgstp?, Dresden, 22-24 April, 1968. Holstein, Anspach M (eds), Deutsches Zentralinstitut fur Arbeitsmedizin, Berlin, DDR, pp.8-12. 3. Bowes DR, Langer AM: Polyphase deformation in the schist of the Bronx, New York City. In: Geology. Queens College, CUNY, Alexandroff E (ed) l(3):17-32, 1969. 4. Langer AM: Electron microprobe analysis (study of asbestos fibers and bodies from lung tissue) . In: Laboratory Diagnosis of Diseases Caused bv Toxic Agents. Sunderman FW, Sunderman Jr FW (eds), W.H. Green: St. Louis, MO, Chapt. 14, pp. 126 136, 1970. 5. Langer AM, Rubin IB, Selikoff IJ: Electron microprobe analysis of asbestos bodies. In: Pneumoconiosis. Proc Int'l Conf, Johannesburg. Shapiro HA (ed) , Oxford University Press; Capetown, pp. 57-69, 1970. 6. Langer AM, Baden V, Hammond EC, Selikoff IJ: Inorganic fibers, including chrysotile in the lungs at autopsy: preliminary report. In*: Inhaled Particles III. Proc Conf Brit Occup Hyg Soc, London. Walton WH (ed), Unwin Bros? Surrey, England, 2:683-694, 1971. 7. Langer AM, Selikoff IJ: Chrysotile asbestos of lungs in residents of New York City. In: 2nd Int1! Clean Air Congress. Washington, DC. Englund HM, Beery, WT (eds), Academic Press; New York, pp. 161-165, 1971. 8. Langer AM, Pooley FD: Identification of single asbestos fibers in human tissues. In: Proc Int1! Agency for Research on Cancer. Biol. Effects of Asbestos, Lyon, 1972, Bogovski P, Gilson JC, Timbrell V, Wagner JC (eds), pp. 119-125, 1973. 9. Langer AM: Aspects of mineralogy of talc. In: proc Syroo on Talc. Washington, DC, May 9, 1973. Goodwin A (ed), USBM IC 8639, US Department of Interior, pp. 82-88, 1974. LANGER, ARTHUR X. PAGE 17 PUBLICATIONS IN SYMPOSIA PROCEEDINGS (coat): 10. Pooley FD, Rohl AN, Langer AM, Bowes DE, Skinner DL: Mineralogy and chemistry of British talc and consumer talcum products. In: 4th lnt'1 Svmp Inhaled Particles and Vapors. Walton WH (ed), Pr. 8.6, pp. 1-18, 1975. 11. Langer AM, Rohl AN, Wolff MS, Klimentidis R, Shirey SB: Review of current techniques for the analysis of fibers in talc. In: Electron Microscopv_of Microfibers. Asher IM, McGrath PP (eds), US Government Printing Office, pp. 28-33, 1977. 12. Langer AM, Wolff MS: Asbestos carcinogenesis. In: Inorganic and Nutritional Aspects of Cancer. Adv Exper Med Biol Series, Schrauzer GN (ed), Plenum Press; New York, pp. 29-55, 1977. 13. Nicholson WJ, Langer AM, Selikoff IJ: Epidemiological evidence on asbestos, Part I: Human health effects; Part II: Extrapolation to other inorganic fibers. In: Proc of Workshop on Asbestos. NBS SP 506. Gravatt CC, LaFleur PD, Heinrich KFJ (eds), with discussion. US Government Printing Office, Washington, DC, pp. 71-93, 1978. 14. Rohl AN, Langer AM: Fibrous mineral content of consumer talccontaining products. In: Dusts and Diseases. Lemen R, Dement JM (eds), Pathotoxicol Publishers, Inc; Forest Park, IL, pp. 393-403, 1979. 15. Langer AM, Rohl AN, Wolff MS, Selikoff IJ: Asbestos, fibrous minerals, and acicular cleavage fragments: nomenclature and biological properties. In: Dusts and Diseases. Lemen R, ' Dement JM (eds), Pathotoxicol Publishers," Inc?" Forest Park,' IL, pp. 1-22, 1979. 16. Langer AM, Maggiore CJ, Nicholson WJ, Rohl AN, Rubin IB, Selikoff IJ: The contamination of Lake Superior with fibrous amphiboles. In: Proc NY Acad Sci Asbestos Conf. New York, NY, June 1978, Ann NY Acad Sci 330:549-572, 1979. 17. Langer AM: Significance of aspect ratio in regulation of asbestos fiber exposure. Ann NY Acad Sci 330:601-604, 1979. 18. Langer AM, Selikoff IJ, Rosenberg C: Defining new asbestos high risk groups. In: Int'l Conf Critical Current Issues, in Environmental Health_Hazards. Tel Aviv, Israel, March 4-7, p. 11, 1979. 19. Langer AM, Sebastien P: Physical-chemical properties of fibers: discussion. In: Biological Effects of Asbestos. IARC, Vol. 1, Wagner JC (ed) , WHO, Lyon, France, pp* 143-145, 1980. LANGER, ARTHUR M. PAGE 18 PUBLICATIONS IN 8YXPOSIA PROCEEDINGS (cont): 20. Suzuki Y, Rohl AN, Langer AM, Selikoff IJ: Mesothelioma following intraperitoneal administration of zeolite. Fed Proc 39(3):640, 1980. 21. Langer AM: Natural non-fibrous asbestos substitutes: talc. In: Proc Nat'l Workshop on Substitutes for Asbestos. Guinond RJ, Rowe J (eds), US Environmental Protection Agency, Office of Pesticides and Toxic Substances, Washington, DC, pp. 563 569, 1980. 22. Rohl AN, Ehrenreich T, Langer AM: Characterization and identification of asbestos materials in human tissues. In: Adv Pathol (Anat and Clin). Vol. 2, Anatomic Pathology, Cytopathology, Forensic Pathology and Toxicology, Levy E (ed) , Pergamon Press, New York, pp. 523-525, 1982. 23. Langer AM, Weisman I, Adams A: Characterization of crystalline particles in human tissues by analytical electron microscopy. J Rheumatol 8(6):1018-1019, 1982. 24. Nolan RP, Langer AM: Quartz and hemolysis: physico-chemical factors controlling membrane activity. In: 4th Ann RMCOEH Conf Health Issues Related to Mining and Minerals. Wagner w, Merchant J, Rom W (eds), Chapt. 4, Ann Arbor Press, Michigan, pp. 63-81, 1983. 25. Langer AM: Surface characteristics and biological properties of minerals. In: World Svmp on Asbestos. May 25-27, 1982, Canadian Asbestos Information Center, Montreal, Quebec, pp. 393-400, 1983. 26. Langer AM, Nolan RP: Minerals, rocks and ore bodies: sources of agents of human disease. In: Proc 2nd Int1! Conor on Applied Mineralogy in the Minerals Industry. Park we. Hausen DM, Hagni RP (eds), pp. 1159-1179, 1985. 27. Harlow GE, Kimball MR, Dowty E, Langer AM: Observations on amosite-grunerite dusts. In: Proc 2nd_Int11 Conar on Applied Mineralogy in the Minerals Industry. Park WC, Hausen DM, Hagni RP pp. 1147-1157, 1985. 28. Nolan RP, Langer AM, Foster KW: Particle size and chemically induced variability in the membrolytic activity of quartz: preliminary observations. In: In Vitro Effects of Mineral Dusts. 3rd Int1! Workshop. Beck EG, Bignon J (eds), SpringerVerlag, Berlin, pp. 39-50, 1985. LANGER, ARTHUR M. RAGS 19 PUBLICATIONS IN SYMPOSIA PROCEEDINGS (oont): 29. Langer AM, Nolan RP: Physico-chemical properties of minerals relevant to biological activities. State of the Art. In: XU Vitro Effects of Mineral Dusts. 3rd Int'l Workshop. Beck EG, Bignon J (eds), Springer-Verlag, Berlin, pp. 9-24, 1985. 30. Langer AM, Nolan RP: Physico-chemical properties of quartz and biological activity. In: Silica. Silicosis, and Cancer. Controversy in Occupational Medicine. Ca Res Monogr 2, Goldsmith DF, Winn DM, Shy CM (eds), Praeger, NY, pp. 125-136, 1986. 31. Langer AM, Nolan RP: The properties of chrysotile asbestos as determinants of biological activity. Variations in cohort experience and disease spectra as related to mineral properties. In: general___Motors Workshop.___Biol___Effects Chrysotile Asbestos. Cardiff, 7-9 May, 1986, Wagner JC (ed), Accomplishments in Oncology. Lippincott Press, 1(2):30-51, 1986. 32. Langer AM: * Fibers in friction products. Discussion and summary of Symposium. In: Proc Fibres in Friction Materials Symposium. The Asbestos Institute, Montreal, Canada, pp. 67 74, October, 1987. 33. Nolan RP, Langer AM: Quantitative aspects of fiber morphology, in: Proc Fibres in .Friction Materials Symposium. The Asbestos Institute, Montreal, Canada, pp. 75-97, October, 1987. 34. Langer AM, Nolan RP: Fiber type and burden found in parenchymal tissues of workers occupationally exposed to asbestos in the United States. In: Mineral Fibers in the Non- Occupational Environment. Spec. Publ. 90. IARC-WHO, Lyon, France, pp. 310-315, 1989. 35. Langer AM, Nolan RP, Bowes DR, Shirey: Inorganic particles found in cigarette tobacco, cigarette ash, and cigarette smoke. In: Biological Interaction of Inhaled Mineral Fibers and Cigarette Smoke. Wehner AP, Felton DL, Eds., Battelle Press, Columbus, OH, pp. 421-439, 1989. 36. Nolan RP, Langer AM, Herson GB: Physico-chemical properties and membranolytic activities of the titanium dioxide polymorphs compared to quartz. In: Biological Interaction of Inhaled Mineral Fibers and cigarette Smoke. Wehner AP, Felton DL, Eds., Battelle Press, Columbus, OH, pp* 391-419, 1989. UNGER, ARTHUR M. PAGE 20 PUBLICATIONS IN SYMPOSIA PROCEEDINGS (CO&t): 37. Langer AM, Nolan RP: Mineral fibers in lung 'tissues of persons exposed to asbestos in the United States. In: vnth Int11 Pneumoconiosis Conf, August 23-26, 1988. 38. Nolan RP, Unger AM: Physicochemical characteristics of quartz dust which controls its biological activity. In: Vllth Int11 Pneumoconiosis Conf. August 23-26, 1988. 39. Langer AM, Nolan RP: Distinguishing asbestiform tremolite from non-asbestiform tremolite. In: Vllth Int'l Pneumoconiosis Conf. August 23-26, 1988. 40. Nolan RP, Langer AM, Herson GB: Membranolytic activity of palygorskite and sepiolite. In: IVth Int1! Workshop: Effects of Mineral Dusts on Cells. Mossman BT, Begin RO, Eds., Springer-Verlag, Oxford, Quebec, Canada, September, pp. 37-48, 1989. 41. Langer AM, Nolan RP, Pooley FD,: Phyllosilicates:associated fibrous minerals. In: Health Related Effects of Phyllosilicates. J. Bignon, Ed., 59-74, Springer-Verlag, N.Y., 1990. - 42. Langer AM, Nolan RP, Addison J: Physico-chemical properties of asbestos as determinants of biological potential. In: Mineral Fibers and Health. Liddell FDS, Miller K, Eds., CRC Press, Ann Arbor, Michigan, pp. 207-224, 1991. 43. Langer AM, Nolan RP, Addison J: Distinguishing between amphibole asbestos fibers and elongate cleavage fragments of their non-asbestos analogues. In: NATO Advanced Research Workshop on Mechanisms in Fibre Carcinogenesis. RC. Brown, J. Hoskins, N. Johnson, Eds., Albuquerque, New Mexico, October 22-25, 1990. p. 253-267. 1991. 44. Nolan RP, Langer AM, Oechsle GW, Addison J, Colflesh DE: Association of tremolite habit with biological potential. In: NATO Advanced Research Workshop on Mechanisms in Fibre Carcinogenesis. RC. Brown, J. Hoskins, N. Johnson, Eds., Albuquerque, New Mexico, October 22-25, 1990. p.231-251. 1991. 45. Langer AM, Nolan RP: Zeolite catalysts. Is there a health risk? The erionite experience and its application to other zeolites, jg: Chemicals and the Environment. Symposium on Chemical Specialties USA, Philadelphia. Spring Innovations, Ltd. 91-95, 1992. 46. Langer AM, Nolan RP: Factors controlling the biological potential of inorganic dusts. Surface chemistry and character, in: Toxic and Carcinogenic Effects of Solid Particles in the Respiratory Tract. 4th Inti. Inhalation Symp., Hannover, Germany. 1-5 March, 1993. in press. ILSI Press. LANGER, ARTHUR M. PUBLICATIONS IN SYMPOSIA PROCEEDINGS (cont)S PAGE 21 47. Langer, AM, Nolan RP, Herson, G: Phosphorylated Canadian chrysotile. In: NATO Advanced Research Workshop. Cellular and Molecular Effects of Mineral and Synthetic Dusts and Fibres. In Pres?- 48. Nolan RP, Langer AM: Limitations of the Stanton Hypothesis. Chapt. 9. Health Effects of Mineral Dusts, Reviews in Mineralogy, 23, Guthrie GD., Jr. and Mossman BT, Eds, Mineral. Soc. America, Wash., D.C., 309-326. 49. Ross M, Nolan RP, Langer AM, Cooper WC: Health effects of mineral dusts other than asbestos. Chap. 12. Health Effects of Mineral Dusts, Reviews in Mineralogy, 23, Guthrie GD., Jr. and Mossman BT, Eds, Wash., D.C., 361-407. CONTRIBUTIONS TO BOOKS, MONOGRAPHS, REPORTS: 1. Langer AM, Mackler AD: Mineral particles and human disease. In: Encyclopedia of Geochemistry and Environmental Sciences. Fairbridge RW (ed), Van Nostrand; Reinhold, NY, Vol. IVA, pp. 730-739, 1972. 2. Langer AM, Pooley FD: Mineralogy of asbestos minerals and methods of their characterization in human tissues. In: AsbestosVolume 14 in the .Chemical Carcinogenesis Series. Int'l Agency for Research on Cancer, p. 107, 1977. 3. Langer AM, Holaday D, Nicholson WJ, Rohl AN: Chapter 2. Asbestos Minerals: Nature, Occurrence and Properties, pp. 34 50. Chapter 4. Identification and Quantitation of Asbestos Fibers, pp. 71-100. Chapter 5. Environmental Distribution, pp. 102-134. In: Asbestos and Disease. Selikoff IJ, Lee WHK (eds), Academic Press; NY, 1978. 4. Rohl AN, Langer AM, Wylie AG: Mineral characterization of asbestos-containing spray finishes. In: Asbestos-Containing Materials^ in School Buildings. US Environmental Protection Agency, Document EPA 450-2-78-014, US Government Printing Office; Washington, DC, pp. 59-64, 1979. 5. Langer AM: Mineralogy of dust diseases. In: Maxcv-Rosenau Public Health and^reventive Medicine. Last J (ed) , AppletonCentury-Crofts Publishers; NY, 11th Edition, pp. 637-641, 1981. 6. Zoltai T, Langer AM: Chapter 2. Asbestiform fibers: historical background, terminology, and physicochemical properties. In: Asbestiform Fibers - Non-Occupational Health Risks. NAS-NRC, Nat'1 Acad Sci, pp. 25-47, 1984. LANGER, ARTHUR M PAGE 22 CONTRIBUTIONS TO BOOKS, MONOGRAPHS, REPORTS (coat)S 7. Lynch J, Langer AM: Chapter 4. Measurement of exposure to asbestiform fibers. In: Asbestiform Fibers * Non-Occupational Health Risks. NAS-NRC, Nat'l Acad Sci, pp. 82-96, 1984. 8. Langer AM, et al.: Asbestos and other natural mineral fibers. In: Int1! Program on Chemical Safety. Environ Health Criteria 53, Chapters II, III, IV, V, WHO, Geneva, 1986. 9. Langer AM: Mineralogy. Chapter II. Presidential Report on Occupational Chest Diseases, Vol. 1, Characterization and Measurement of the Environment. Merchant J, Dement J (eds), ALOSH--NIOSH--CDC; Washington, DC, pp. 3-40, 1987. 10. Langer AM: Asbestos. In: Collier's Encyclopedia. 3:4-5, 1987. 11. Langer AM: Asbestos. In: Merit Students Encyclopedia. Macmillan Ed Pub, NY, pp. 270-271, 1990. 12. Langer AM: Asbestos chapter: American Medical Association Primer on Chemical and Radiation Exposures. Davis, A., Ed. (in review) . 13. Ross M, Nolan R, Langer AM, Cooper WC. In: Mineral Short Course. Biological Effects of Minerals. Chapter 6. Health Effects of Mineral Dusts other than Asbestos. Guthrie, G and Mossman, B, Eds. Min. Soc. America, Wash., D.C. in press. 14. Nolan RP, Langer AM. In: Mineral Short Course. Biological Effects of Minerals. Chapter 14. Limitations of the Stanton Hypothesis. Guthrie, G and Mossman, B, Eds. Min. Soc. America, Wash., D.C. in press. OTHER PUBLICATION FORMS: 1. Miller A, Teirstein AS, Langer AM, Selikoff IJ: Submicroscopical asbestos fibers and disease. Letter to the Editor. Reply to discussion. N Engl J Med 292:1195-1196, 1975. 2. Wolff MS, Langer AM, Shirey SB: Gas chromatographs: health effects. Letter to the Editor. Science 191:13, 1976. 3. Rom WN, Langer AM: Carcinogenicity of fibrous glass. Letter to the Editor. West J Med 126:413, 1977. 4. Rohl AN, Langer AM, Selikoff IJ: Asbestos pollution. Letter to the Editor. Reply. Science 197:716-718, 1977. LANGER, ARTHUR N PAGE 23 OTHER PUBLICATION PORKS (COllt) * 5. Rohl AN, Langer AM, Selikoff IJ: Chrysotile asbestos, effects of human exposure. Letter to the Editor. Reply. Science 198:1202, 1977. 6. Langer AM: Relationship between chemical and physical properties of mineral fiber and health effects. NBS SP506, Workshop on Asbestos: Definitions and Measurement Methods. Gravatt CC, LaFleur PD, Heinrich KFJ (eds), pp. 104-195:198, 1978. 7. Langer AM: Mineralogical factors in asbestos health effects. NSB SP506, Workshop on Asbestos: Definitions and Measurement Methods. Gravatt CC, LaFleur PD, Heinrich KFJ (eds), pp. 91 9 2;19 8, 1978. 8. Fischbein AS, Rohl AN, Langer AM, Selikoff IJ: Pleura-undperitoneal mesothelioma. Letter to the Editor. Med Klin 74(19):742, 1979. 9. Langer AM: Electron microscopy and x-ray applications to environmental and occupational health analysis. Book Review. J Toxicol Environ Health, 1979. 10. Langer AM: Mineralogy and physical properties of fibers. Talcs contaminated with other minerals. Discussions. In: Dusts and Disease. Lemen R, Dement J (eds), Pathotoxicol Pub Inc, Park Forest, IL, 120:122-123, 341-344, 1979. 11. Langer AM: Round-table discussion on talc as an asbestos substitute. Chairman's remarks, in: Proc Nat'l Workshop on Substitutes for Asbestos, Arlington, VA, Guimond RJ, Rowe JN, Levin A, Pillsbury H (eds), USEPA Office Toxic Substances, Washington DC, pp. 612-619, July 14-16, 1980. 12. Fischbein AS, Langer AM, Rohl AN, Selikoff IJ: Asbestos disease in drywall construction workers. Letter to the Editor. Am Industr Hyg Assoc 40(9):829-830, 1980. 13. Fischbein AS, Rohl AN, Langer AM, Selikoff IJ: Past asbestos exposure among cable splicers. Letter to the Editor. Am J Pub Health 71:1277-1278, 1981. 14. Langer AM: Host rocks and gangue materials in relation to pneumoconiosis and cancer. Editorial. Am J Industr Med 2:89 90, 1981. 15. Langer AM, Sebastien P: Physical-chemical properties of fibers. Rappateur Report. In: Biological Effects of Mineral Fibers, Int'l Agency for Research on Cancer, Wagner JC (ed), IARC-WHO, Lyon, France, 1:143-145, 1981. LARGER/ ARTHUR M. PASS 24 OTHER PUBLICATION FORMS (cont) 16. Langer AM, Selikoff IJ: Scientific data on chrysotile. Letter to the Editor. Chen Engineer News 2:59, 1984. 17. Langer AM: Mineral dust and pulmonary lesions: etiological link or epiphenomenon? Editorial. Am J Industr Med 6:169-171, 1984. 18. Fischbein AS, Langer AM, Rohl AN: Asbestos-associated diseases: lessons from the past for the future. Letter. JAMA 254:1309-1310, 1985. 19. Langer AM, Nolan RP: Asbestos in play sand. Letter, N Engl J Med 316:882, 1987. 20. Constantopoulos SH, Langer AM, Saratzis N, Nolan RP: Regional findings in Metsovo lung. Correspondence, The Lancet ii:452453, 1987. 21. Langer AM, Nolan RP, Constantopoulos S: Endemic pleural calcification and mesothelioma. JAMA 260(3):339-340, 1988. 22. Langer AM: Chairman1s Summary and Discussion. In: Biological Interaction of Inhaled Mineral Fibers and Cigarette Smoke. Wehner AP, Felton DL, Eds., Battelle Press, Columbus, OH, pp. 590-593, 1989. 23. Langer AM, Nolan RP, Ross M: 249:1485, 1990. Asbestos policy. Science, 24. Langer AM, Nolan RP: Pleural mesothelioma resulting from exposure to amosite asbestos in a building. _ _Letter. Respiratory Medicine 84:509-510, 1990. 25. Langer AM, Nolan RP, Addison J: Letter to the Editor concerning Editorial " On talc, tremolite and tergiversation," Reger R, Morgan WKC. British Journal Industrial Medicine 48:359-360, 1991. 26. Wilson R, Langer AM, Nolan RP, Gee JB, Ross M: Policy forum: Asbestos in New York City public school buildings. Society for Policy Analysis, in review. PUBLISHED ABSTRACTS: 1. Berkley c, Langer AM, Berkley LE, Anderson CA: Chemical changes in inspired asbestos fibers. Microscopy Symp, McCrone Laboratory, Chicago, IL, August, 1966. LANGE*, ARTHUR M. PAGE 25 PUBLISHED ABSTRACTS (CODt): 2. Berkley C, Langer AM, Selikoff IJ: Microbeam analysis and identification of the degradation products of inspired pulmonary particulates. Trans NY Acad Sci, May, 1967. 3. Langer AM, Kerr PF: The nature of soft and harsh chrysotile. In: Conference on the Physics and Chemistry of Asbestos Minerals, Oxford, Pr. 2-2, July, 1967. 4. Berkley C, Langer AM, Ameson A: Electron microprobe and electron diffraction analysis of asbestos bodies. In: 2nd Inti. Conf. Biol. Effects Asbestos, p. 7, Dresden, 22-25 April, 1968. 5. Berkley C, Langer AM, Rubin IB: Electron Microprobe analysis of particles in tissues. In: Proc 5th Nat'l Conf Elect Probe Soc Am, New York, Pr. 29A, July, 1970. 6. Selikoff IJ, Nicholson WJ, Langer AM: Asbestos air pollution in urban areas. In: Proc AMA Air Pollution Med Res Conf, New Orleans, October, 1970. 7. Ehrenreich T, Langer AM, Selikoff IJ: Asbestos fibers in human lungs: forensic significance in environmental disease. In: 6th Int'l Mtg Forensic Sci, Edinburgh, Int'l Assn Forensic Sci, p. 86, September, 1972. 8. Teirstein AS, Miller A, Langer AM, Selikoff IJ: Sublight microscopic mineral particles in the etiology of pulmonary fibrosis, in: Proc Am Thorac Soc, New York, pp. 33-34, May 21-21, 1973. 9. Everett GA, Langer AM: Environmental contamination of Lake Superior asbestos from amphiboles in taconite wastes. In: Proc Ann Mtg Geol Soc Am, Miami, p. 728, November 18-20, 1974. 10. Rohl AN, Anderson K, Langer AM: Asbestos exposure during brake lining maintenance and repair. In: Proc Am Ind Hyg Assn, Miami, May 12-16, 1974. 11. Langer AM, Pooley FD, Bowes DR: Environment, disease and minerals. Read before the Geological Society, London, November 20, J Geol Soc, with discussion, 1974. 12. Langer AM, Wolff MS, Rubin IB: Environmental assay: particles in human tissues. In: Proc Int'l Conf Environ Sensing and assessment, Environmental Protection Agency, Pr. 29-34, September 14-19, 1975. LANGER, ARTHUR K. PAGE 26 PUBLISHED ABSTRACTS (eo&t): 13. Bowes DR, Langer AM, Rohl AN: Nature and range of mineral dusts in the environment. Roy Soc London (Geological), p. 18, April 7, 1976. 14. Langer AM, Suzuki V, Rohl AN: Identification of Microparticles. In: 3rd Inti. Symp. on Detection and Prevention of Cancer. ACS. New York, p. 91, April 26-May 1, 1976. 15. Fischbein A, Langer AM, Suzuki Y, Selikoff IJ: Carcinoma of the lung in a drywall taping worker: report of a case. In: Prog Abstr 3rd Int'l Symp Detect Prevent Cancer, No. 280, September 7, 1976. 16. Rom WN, Frank A, Suzuki Y, Langer AM, Selikoff IJ: Rapidly progressive interstitial pulmonary fibrosis from short term mixed dust exposure. 42nd An Sci Assem Am Coll Chest Phys, Atlanta, GA, October 21-28, 1976. 17. Fischbein A, Langer AM: Shale oil: A future energy alternative. A review of the mineralogic and carcinogenic properties of shale oil. Tenth Ann Conf Trace Substances in Environ Health, Columbia, MO, June 8-10, 1976. 18. Langer AM: Identification of microparticles in tissues. Workshop 13, 3rd Int'l Sump on Detection and Prevention of Cancer, September 1976. 19. Langer AM, Wolff MS: Asbestos carcinogenesis. I&: Inorganic and Nutritional Aspects of Cancer, La Jolla, CA, January 2-5, 1977. 20. Selikoff IJ, Nicholson WJ, Langer AM: Epidemiological evidence on asbestos. Workshop on Asbestos, Definition and Measurement Methods, NBS Workshop, Gaithersburg, MD, July, 1977. 21. Langer AM: Contamination by submicroscopic particles in the biosphere. Int'l Symp Anal Electron Microscopy in Biol and Environ Routine and Research Work, Nat'l Inst Pub Health, Oslo, May 10, 1977. 22. Langer AM: Asbestos minerals and their carcinogenic effect. Int11 Symp Anal Electron in Biol and Environ Routine and Research Work, Nat'l Inst Pub Health, Oslo, May 10, 1977. 23. Langer AM, Oster G: Crystal faces and cleavage planes in quartz as templates in biological processes. Biophys Soc Am Phys Soc Mtg, Washington, DC, March, 1978. LANGER, ARTHUR K. PAGE 27 PUBLISHED ABSTRACTS <CO&t): 24. Lilis R, Langer AH: Chronic interstitial pulmonary disease with severe respiratory disfunction due to unsuspected occupational beryllium exposure. In: XIXth Int'l Congr Occup Health, Dubrovnik, Yugoslavia, pp. 89-90, September 25-30, 1978. 25. Rohl AH, Danger AH: Asbestos and asbestiform minerals in non asbestos mines in the United States, in; XIXth Int'l Congr occup Health, Dubrovnik, Yugoslavia, pp. 121-122, September 25-30, 1978. 26. Russo DA, Kagan E, Langer AH, Yeager H: Human alveolar macrophages: cytotoxicity of naturally-occurring short fiber. Federation Proceedings, Section Physiology, Federation American Societies of Experimental Biology, 1980. 27. Langer AM: Physical-chemical characteristics of chrysotile and their relationship to biological activity. In: 29th Ann Clay Minerals Conf, Baylor, Waco, TX, p. 58, October 5-9, 1980. 28. Bowes DR, Langer AM: Mineralogy and geochemistry of particulates -in cigarette smoke. In: Ann Htg Geol Soc, London, Environmental Mineralogy, January 11, 1980. 29. Langer AM: Particulate inhalants. In: Occupational Toxicology, College of Medicine and Dentistry, NJ, September 26, 1980. 30. Langer AM: Minerals as toxic agents: parameters and mechanisms. In: Proc 50th Geol Alumni Assn, Brooklyn College, CUNY, May 7-9, 1981. 31. Langer AM, Weisman, I, Adams A, Pooley FD: Characterization of crystalline particles in tissue by analytical electron microscopy. In: Symp on Crystalline Deposits in Tissues, Toronto, August 13-14, 1981. 32. Russo DA, Kagan E, Langer AM, Nolan R, Yeager H: Cytotoxicity of naturally-occurring short fiber asbestos. In: 20th Int'l Congr Occup Health, Cairo, September 25-October 1, 1981. 33. Ehrenreich T, Langer AM, Selikoff IJ: Algorithm of pathologic diagnosis of asbestos-related diseases for forensic purposes. Significance of quantitative and morphological correlates. Id: 20th Int'l Congr Occup Health, Cairo, September 25-October 1, 1981. LANGER, ARTHUR K PAGE 28 PUBLISHED ABSTRACTS (OODt): 34. Rohl AN, Langer AM, Suzuki V, Lilis R, Moncure G, Selikoff IJ: Endemic pleural disease associated with mixed fibrous dust exposure in Turkey. In: 20th Int'l Congr Occup Health, Cairo, September 25-October 1, 1981. 35. Nolan RP, Langer AM: Surface functionalities of quartz and hemolytic activity. Id: Proc 2nd Int'l Workshop of the In Vitro Effects of Mineral Dusts, Arkadelphia, AR, April 5-6, 1982. 36. Langer AM, Nolan RP: Membrolytic properties of quartz. In: Proc 2nd Ann Geol Alumni Assn, Brooklyn College, CUNY, p. 4, April 28-30, 1983 (abstracts). 37. Nolan RP, Langer AM, Foster KW: Recognition of quartz by erythrocyte membranes. In: 6th Int'l Penumoconiosis Conf, Bochum, FDR, September 20-23, 1983 (Abstract 198). 38. Nolan RP, Langer AM, Foster KW: Physico-chemical factors effecting membrolytic properties of quartz. Id: 6th Int'l Pneumoconiosis Conf, Bochum, FDR, September 20-23, 1983 (Abstract 199). 39. Langer AM, Nolan RP: Surface properties of quartz and membrane activity. Id: Int'l Symp Silica, Silicosis and Cancer, Chapel Hill, NC, April 3-5, 1984. 40. Langer AM: Asbestos, fibrous minerals, acicular cleavage fragments and the mineral industries. Id: Int'l Congr Applied Mineralogy, Los Angeles, February, 1984. 41. Langer AM: Minerals and disease: the association between exposure to minerals and rock dust and the occurrence of human disease. Id: Int'l Congr Applied Mineralogy, Los Angeles, February, 1984. 42. Langer AM: Mineral fiber in water? Id Medical Geology Conference on Health Threatening Toxins in Water, Brooklyn College, NY, May, 1984. 43. Constantopoulos SH, Langer AM, Saratzis N, Goudevenos JA, Selikoff IJ: Metsovo lung: pleural calcifications and malignant pleural mesothelioma in northwestern Greece. Tremolite asbestos used for whitewashing as etiology. Id: 3rd Int'l Conf Environmental Lung Disease, Am Coll Chest Phys, Montreal, Canada, October 15-18, 1986. Chest 91(2):300, 1987. LANGER, ARTHUR M. PAGE 29 PUBLISHED ABSTRACTS (co&t): 44. Langer AM, Nolan RP: Fiber type and parenchymal burden found in workers occupationally exposed to asbestos fiber in the United States. Implications for risk assessment in the general population. Mineral Fiber in the Non-Occupational Environment, Lyon, France, October 8-10, 1987. 45. Langer AM, Nolan RP: Mineralogical and biological comparison of asbestiform and non-asbestiform tremolite. AIKE Annual Meeting, Phoenix, AZ, January 25-28, 1988. 46. Langer AM, Nolan RP, Bowes DR, Shirey S: Inorganic particles in cigarettes and cigarette smoke. Id: Biological Interaction of Inhaled Mineral Fibers and Cigarette Smoke. International Symposium/Workshop, Seattle, WA, April 10-14, 1988. 47. Nolan RP, Langer AM, Herson GB: Physico-chemical properties of the titanium dioxide polymorphs and biological activity. Id: Biological Interaction of Inhaled Mineral Fibers and cigarette Smoke. International Symposium/Workshop, Seattle, WA, April 10-14, 1988. 48. Nolan RP, Langer AM, Herson GB: Membranolytic activity of palygorskite and sepiolite. In: IVth International Conference on the Effects of Mineral Dusts on Cells, p. 15, Oxford, Quebec, Canada, 1988. 49. Langer AM, Nolan RP, Herson GB: Membranolytic activity and physicochemical characterization of phosphorylated Canadian chrysotile. In: IVth International Conference on the Effects of Mineral Dusts on Cells, p. 14, Oxford, Quebec, Canada, 1988. - 50. Nolan RP, Langer AM, Herson GB: Physicochemical character istics of quartz dust which controls its biological activity. Id: Vllth International Pneumoconiosis Conference, DKHS (NIOSH) Publication No. 90-108, Part I, 754, 1990. 51. Langer AM, Nolan RP: Fiber type and risk of mesothelioma to building occupants. Id: Health Aspects of Exposure to Asbestos in Buildings. Energy and Environmental Policy Center, John F. Kennedy School of Government, Harvard University, Cambridge, MA, December 14-16, 1988. 52. Langer AM, Pooley FD, Nolan RP: Phyllosilicates: Associated fibrous minerals. In: First International conference on Health Related Effects of Phyllosilicates. NATO Advanced Research Workshop, Paris, France, March 16-18, 1989. LANGER, ARTHUR M PAGE 30 PUBLISHED ABSTRACTS (COBt): 53. Nolan RP, Langer AM, Herson GB: Characterization of palygorskite specimens from different geological locales for health hazard evaluation. Ins First International Conference on Health Related Effects of Phyllosilicates. NATO Advanced Research Workshop, Paris, France, March 16-18, 1989. 54. Langer AM, Nolan RP: The importance of mineral subpopulations in biological assays. In: NATO Advanced Research Workshops on Mechanisms in Fibre Carcinogenesis. Albuquerque, New Mexico, October 22-25, 1990. 49-50. 55. Nolan RP, Langer AM, Oechsle GW, Addison J, Colflesh DE: Association of tremolite habit with biological potential. In: NATO Advanced Research Workshops on Mechanisms in Fibre Carcinogenesis. Albuquerque, New Mexico, October 22-25, 1990. 57. 56. Langer AM: Fiber types, fiber sizes, and asbestos diseases. Andrews Communications Seminars. 2nd Asbestos Litigation. The Eye of the Storm. 25-26 February, 1991. Bal Harbour, Florida. 57. Nolan RP, Langer AM, Oechsle GW, Johnson NF: Physicochemical characterization of selected zeolite minerals for health hazard evaluation. Fourth Inti. Conf. Env. Lung Disease. Montreal, Canada, September 25-28, 1991. 58. Nolan RP and Langer AM: Characterization of fibers for Health Hazard evaluation. Critical Research Needs. Workshop on Chemical and Biological Interactions of Glass. Bethesda, MD, 5-6 Mar, 1992. 59. Langer AM and Nolan RP (1992). Comparison of lung tissue mineral fibre retention of exposed workers and the general population. In: Biopersistence of respirable synthetic fibres and minerals. 7-9 Sept, 1992. Lyon. p. 26. 60. Nolan RP, Langer AM, and Addison J (1992). Health hazard evaluation of the lung tremolite fiber content among Canadian chrysotile workers. Xn: Biopersistence of respirable synthetic fibres and minerals. 7-9 Sept, 1992. Lyon. p. 52. 61. Langer AM, Nolan RP (1993). Factors controlling the biological potential of inorganic dusts: surface character and chemistry. 4th International Inhalation symposium, Hannover. Toxic and Carcinogenic Effects of Solid Particles in the Respiratory Tract, 1-5 March, 1993, Hannover. Abst. A-10, p. 48. 62. Langer AM, Nolan RP (1993) Physico-chemical characteristics of quartz dust which controls its biological activity. Clay Minerals Society Meeting. San Diego, 25-30 Sept, 1993. LANGER, ARTHUR M. PAGE 31 KAHUSCRIPTS IK PREPARATION: Langer AM, Kimball MR, Harlow GE: A comparison of fibrillar structure in amosite and crocidolite. Langer AM, Kimball MR, Harlow GE, Dowty E: Electron microscopystudies of amosite and grunerite dust particles. Langer AM: Distribution of amosite and chrysotile fibers in the lung of an exposed worker: role of fiber size and type. Nolan HP, Langer AM: Mineral surfaces and the anion transport system of the human red blood cell. Mechanism of hemolytic action. Langer AM, al: Amosite fiber size-distribution at a fabrication plant: mesothelioma and fiber dimension. Langer AM, &1* Asbestos bodies in two periods of time: review, secular trends, New York City, 1915-1970. Langer AM, al: Asbestos bodies and age, sex, occupation of urban dwellers: asbestos bodies as indices of disease risk PARTICIPATION IN POSTGRADUATE EDUCATION COURSE8 (1976-PRESENT): 6/70 - Page and Black Postgraduate, Mount Sinai School of Medicine: Asbestosis. 4/71 - NY Academy of Sciences, Seminars for Trade Union Represent atives: Occupational Health Hazards. 4/71 - American College of Chest Physicians, Mount Sinai School of Medicine, NY: Interstitial Pneumonias--Acute and Chronic. 5/75 - United States-USSR Environmental Protection Agreement: Workshop on Basic Practical Approaches to Environ mental Carcinogenesis, Mount Sinai. 6/76 - Page and Black Postgraduate, Mount Sinai School of Medicine: Environmental Lung Disease. 2/77 - Office of Continuing Education, Baylor Medical College, Houston, TX: Pulmonary Diseases and Carcinoma of the Lungs, Baylor Medical School, Houston, TX. 11/77 - New York Lung Club, Cornell University Medical College: Silicosis revisited. New York City Tunnel and Caisson Workers: 1928-1977. LANGER, ARTHUR X. PAGE 32 PARTICIPATION IX POSTGRADUATE EDUCATION COURSES (1976-PRESENT) (cont)s 1/78 - Page and Black Postgraduate, Mount Sinai School of Medicine, New York, NY: Asbestos Carcinogenesis. 3/78 - Page and Black Postgraduate, Mount Sinai School of Medicine, New York, NY: Occupational and Environmental Pulmonary Diseases. 6/78 - Page and Black Postgraduate, Mount Sinai School of Medicine, NY: Health Effects of Asbestos Exposure. Course Director. 11/78 - Page and Black Postgraduate, Mount Sinai School of Medicine, NY: Asbestos Associate Diseases: With Particular Reference to United States Shipyards. 1/79 - Page and Black Postgraduate, Mount Sinai School of Medicine, NY: Scientific Basis for Evaluation of Occupational and Environmental Asbestos Disease. 10/79 - Office of Continuing Education, Baylor Medical College, Houston, TX: Asbestos-Associated Diseases, Houston, TX. 1/80 - Page and Black Postgraduate, Mount Sinai School of Medicine, New York, NY: Asbestos in Shipyards. 3/80 - Page and Black Postgraduate, Mount Sinai School of Medicine, New York, NY: .- Management and Control of Asbestos in Public Buildings. 6/80 - Page and Black Postgraduate, Mount Sinai School of Medicine, New York, NY: Health Effects of Asbestos in Public Buildings. 9/80 - College of Medicine and Dentistry of New Jersey: Rutgers Medical School, Recent Advances in Occupational Toxicology, Graduate Center, NY. 11/81 - Page and Black Postgraduate, Mount Sinai School of Medicine, New York, NY: Recent Advances in occupational Medicine. 12/82 - Page and Black Postgraduate, Mount Sinai School of Medicine, New York, NY: Scientific Basis for Evaluation of AsbestosAssociated Diseases. LARGER, ARTHUR X. PAGE 33 PARTICIPATION IN POSTGRADUATE EDUCATION COURSES (1976-PRESENT) (COUt): 3/85 - Page and Black Postgraduate, Mount Sinai School of Medicine, New York, NY: Asbestos in Schools and Public Buildings, Hasbrook Heights, NJ. 9/91 - Environmental Lung Disease. American College of chest Physicians. Mineralogy Techniques. Montreal, Canada. INVITED SEMINARS AND LECTURES: Union College, Schenectady, NY, Department of Geology and Civil Engineering. "Asbestos and Lung Disease." April, 1967. Barnard College, NY, Department of Geology. "Asbestos Fiber in the Ambient Air and Disease Potential." December, 1968. The Rockefeller University, Air Pollution Working Group, Health Research Council. "Analysis of Air Samples for Inorganic Constituents." June 9, 1969. New York University Medical center. New York Lung Club. "Sublight Microscopic Mineral Particles in Talc Pneumoconiosis. Physiology and Mineralogical Studies." November, 1970. Leheigh College, Department of Material Sciences and Metallurgy. "Electron Probe Characterization of Particles in Tissues." April, 1971. Oberlin College, OH, Department of Geology. "Asbestos Dust in the Workplace and Human Disease." May, 1971. State University of New York at Buffalo, Department of Biophysical Sciences. "The Asbestos Problem. An Interdisciplinary Approach." April, 1972. Queens College of the City University of New York, Department of Earth and Environmental Sciences. "Asbestos and Disease. How Wide is the Spectrum?" November, 1972. Columbia University, NY, Department of Geology and Biological Sciences. "Contamination of the Environment with Mineral Particles." December, 1972. College of South Hampton, Long Island University, Division of Chemical Sciences and Oceanography. " The Contamination of Lake Superior with Fibrous Silicates." January, 1973. National Institutes of Health. Review of Asbestos Problem. "Mechanism of Fiber Action." National Institutes of Health, Bethesda, MD, February, 1973. LANGER, ARTHUR M. PAGE 34 INVITED SEMINARS AND LECTURES (cont): City College of the City University of New York, Department of Earth and Planetary Sciences. "Mineral Particles and Human Disease." May, 1973. Queens College of the City University of New York, Department of Health Sciences. "occupational Hazards as Harbingers of Environmental Hazards." September, 1973. Rutgers University, Colonial Conference Tri-State Environmentalists. "Recognition of Environmental Hazards: Use of Academic Facilities for Monitoring and Control of Hazards." November, 1973. Johns Hopkins University, School of Public Health. Minerals and Disease." Seminar. April, 1974. "Asbestos Rutgers University, Department of Environmental Sciences. "Mineral Particles in the Air." June, 1974. Temple University, Department of Geology. "Amphibole Contamination of Lake Superior Water from Taconite Processing." September, 1974. American Museum of Natural History, Department of Mineral Sciences. "Minerals and Disease." September, 1978. Rutgers University, Department of Chemistry. "Minerals and Their Biological Activity." October, 1978. University of North Carolina, Department of Medicine. "Analytical Methods of Tissue Analysis, Asbestos Bodies Asbestos Fibers"; 2) "Inorganic Particles in Cigarettes Cigarette Smoke." November, 1978. 1) and and University of Maine, Farmington, Department of Geology. l)"The Asbestos Problem"; 2) "Evolution of an Environmental Scientist, A Personal View." March, 1979. School of Public Health, Columbia University. Asbestos Diseases." April, 1979. "Epidemiology of New York Medical Examiner's Conference. "Analysis of Tissues for Asbestos Fiber and Asbestos Bodies." June, 1979. Seton Hall University, Department of Chemistry. "Minerals and Disease: Interaction Mechanisms." October 2, 1979. American Institute of Mining Engineers, Tucson. "The Biological Effects of Inorganic Fibers: The Case Against Asbestos*1 (invited speaker). October, 1979. LARGER* ARTHUR M. PAGE 35 INVITED SEMINARS AND LECTURES (OODt): American Chemical Society, Staten Island Section. "Minerals and Diseases: Physical and Chemical Factors." February 19, 1980. Society of Sigma Xi Lecture. "Man in Conflict with His Physical Environment." Invited Speaker for initiation ceremony, City University, New York, May 13, 1980. National Institutes of Health, Bethesda, Department of Health and Human Services CCERP-26. "Serpentine-Containing Host Rocks: Amphibole-Containing Host Rocks." November, 1980. NIEHS-EPA-NIOSH Joint Committee at Bethesda. "Mount St. Helen1s Volcanic Ash: Mineral Nature and Biological Activity." July 23, 1981. The Rockefeller University. "Minerals and Toxic Agents, Parameters and Mechanisms." Invited speaker in series on Comparative Toxicology, February 12, 1981. Kettering Laboratory, University of Cincinnati Medical Center. "Silica and Silicosis: Mechanisms." April 8, 1981. University of California, Irvine, Occupational and Environmental Health Center. "Physicochemical Properties of Inorganic Dusts and Biological Consequences of Exposure." Occupational Medicine Series, December 2, 1981. Barlow Hospital, Los Angeles, University of Southern California Medical School. "Tissue Analysis for Asbestos, Comparative Techniques." Chest Service, Department of Medicine, December 3, 1981. Appalachian Laboratory for Occupational Safety and Health NIOSHCDC, Morgantown, West Virginia. "Surface Properties of Silica and Its Biological Activity." February 24, 1982. National Institute for Occupational Safety and Health. "Silica and Silicosis." Cincinnati, March 24, 1982. Society of Sigma Xi Lecture, Queens College of the City University of New York. "The Case Against Chrysotile Asbestos." December 2, 1982. National Institute of Environmental Health Sciences, Pathobiology of Mesothelioma, Research Triangle Park, NC. "Physicochemical Character of Dust and its Role in Inducing Human Mesothelioma." January, 1983. Geology Seminar, Long Island University, College at South Hampton. "The Biological Effects of Asbestos." March 18, 1983. LARGER, ARTHUR M. RAGE 36 INVITED SEMINARS AND LECTURES (CO&t)I Graduate Seminar, Rutgers University, Department of Geology. "Physical-Chemical Properties of Minerals and Their Biological Activities." April 13, 1983. Symposium on Fibrous Minerals, American Lung Association Annual Meeting, Kansas City, MO. "Mineralogy of Mineral Fibers." May 8, 1983. Faculty Research Collegium, Ph.D. Program Earth and Environmental Studies, CUNY, Graduate Center, NY. "Physicochemical Properties of Minerals Controlling Biological Activity." March 6, 1984. Graduate Seminar, Department of Geology, Princeton University. "Minerals and Disease." Princeton, NJ, March 8, 1984. Graduate Seminar, Department of Biology, New York University, New York, NY. "Asbestos: Biological Considerations." April 16, 1984. Medical Geology Conference on Health Threatening Toxins in Water. "Asbestos Fiber in Water." May 3, 1984. Asbestos Information Association of North America, Annual Meeting, Alexandria, VA. "Asbestos Substitutes. How Safe are They?" September 18, 1985. American Society for Testing Materials, Annual Meeting, Bal Harbour, FL. "Method for Testing Indoor Air for Asbestos. Analytical Electron Microscopy." November 4, 1985. University.-xif .Southern California Medical School. "Membranolytic Properties of Quartz and Phosphorylated Chrysotile Fiber." January 29, 1985. Main Campus. "Asbestos Fiber in Lung Tissue - Analysis by Analytical Electron Microscopy." January 30, 1986. Milton Kannerstein Lecture. "Mineral Dust and Pulmonary Lesions." Annual Meeting of the Klemperer-Otani Society. Mount Sinai, June 5, 1986. Northeast Regional Environmental Public Health Center, University of Massachusetts. Symposium: Asbestos in Play Sand. "Tremolite Analysis, Morphology, and Health Significance." February 11, 1987. The Defense Research and Trial Lawyers Association, Reno, NV. "Analytical Protocol for the Study of Sublight Microscopic Particles in Human Tissues"? "Types and Amounts of Asbestos Fibers in the Pulmonary Tissues of Asbestos-Exposed Workers in the United States." October 30, 1987. LARGER, ARTHUR M. PAGE 3$ INVITED SEMINARS AND LECTURES (CO&t) Graduate Seminar, Rutgers University, Department of Geology. "Physical-Chemical Properties of Minerals and Their Biological Activities." April 13, 1983. Symposium on Fibrous Minerals, American Lung Association Annual Meeting, Kansas City, MO. "Mineralogy of Mineral Fibers." May 8, 1983. Faculty Research Collegium, Ph.D. Program Earth and Environmental Studies, CUNY, Graduate Center, NY. "Physicochemical Properties of Minerals Controlling Biological Activity." March 6, 1984. Graduate Seminar, Department of Geology, Princeton University. "Minerals and Disease." Princeton, NJ, March 8, 1984. Graduate Seminar, Department of Biology, New York University, New York, NY. "Asbestos: Biological Considerations." April 16, 1984. Medical Geology Conference on Health Threatening Toxins in Water. "Asbestos Fiber in Water." May 3, 1984. Asbestos Information Association of North America, Annual Meeting, Alexandria, VA. "Asbestos Substitutes. How Safe are They?" September 18, 1985. American Society for Testing Materials, Annual Meeting, Bal Harbour, FL. "Method for Testing Indoor Air for Asbestos. Analytical Electron Microscopy." November 4, 1985. University-nf ..Southern California Medical School. "Membranolytic Properties of Quartz and Phosphorylated Chrysotile Fiber. " January 29, 1985. Main Campus. "Asbestos Fiber in Lung Tissue - Analysis by Analytical Electron Microscopy." January 30, 1986. Milton Kannerstein Lecture. "Mineral Dust and Pulmonary Lesions." Annual Meeting of the Klemperer-Otani Society. Mount Sinai, June 5, 1986. Northeast Regional Environmental Public Health Center, University of Massachusetts. Symposium: Asbestos in Play Sand. "Tremolite Analysis, Morphology, and Health Significance." February 11, 1987. The Defense Research and Trial Lawyers Association, Reno, NV. "Analytical Protocol for the Study of Sublight Microscopic Particles in Human Tissues"; "Types and Amounts of Asbestos Fibers in the Pulmonary Tissues of Asbestos-Exposed Workers in the United States." October 30, 1987. LANGER, ARTHUR X. PAGE 37 INVITED SEMINARS AND LECTURES (cont): The Manville Settlement Trust Asbestos Disease Seminar, Washington, DC. "Asbestos Fibers: The Physico-Chemical Properties and Health Effects." March 16, 1988. Asbestos Fiber Type and Risk of Disease, Conference: New York - New Jersey Environmental Expo: The Source for Environmental Solutions. Seminar 7E, The Management of Asbestos in the 1990*s. Thursday, October 18, 1990. American Industrial Hygiene Association, Georgia Section, Atlanta Georgia. Conference: The Asbestos Controversy. Has the Public Been Properly Informed? "Understanding the Asbestos Risk." November 30, 1990. Armstrong Defense Group. Memphis, Tennessee. The Asbestos Saga and the Star Wars Trilogy: The Empire Strikes Back! Thursday, April 25, 1991. Department of Medicine - Pulmonary, New York University Medical Center. Pulmonary Grand Rounds. Particle___Characteristics Responsible for Pneumoconiosis and Cancer. Tuesday, September 3, 1991. Nelson Institute of Environmental Medicine, New York University School of Medicine. Surface. Properties of Minerals as Determinants of Biological Activity. Tuxedo, New York. Wednesday, October 23, 1991. Defense Research Institute. Current Issues in Asbestos in Building Seminar. Report From the Health Effects Institute. ____g&findp,__. Florida. Friday, January 24, 1992. Characteristics of Mineral Fibers - Critical Research Needs. Invited to Workshop on Chemical and Biological Interactions of Glass. Bethesda, Maryland, March 5-6, 1992. Mealey's National Bioavailabilitv of Pennsylvania. Lead Lead. Litigation Conference. Presented: April 22-23, 1993. Philadelphia, Physics and Chemistry of Asbestos Minerals. Oxford, July, 1967. Presented: The Nature of Soft _and Harsh Chrvsotile (with Kerr PF.) . Second International Conference on the Biological Effects of Asbestos. Dresden, DDR, April, 1968 (two papers with Berkley C, Sastre A, Arneson A and Schwartz J). LANGER, ARTHUR N. PAGE 38 INVITED INTERNATIONAL MEETINGS AND CONFERENCES (cont): International Conference on Pneumoconiosis. Johannesburg, April 23-May 2, 1969. Presented: Electron Microprobe Analysis of Asbestos Bodies (with Rubin IB and Selikoff IJ). Working Group: Asbestos and the Asbestos Diseases. Cardiff, April 6-9, 1970. Presented: Identification of Asbestos Fiber in Tissue. British Occupational Hygiene Society: Inhaled Particles and Vapors. Imperial College, London, June, 1970. Presented: Inorganic Fibers. Including Chrvsotile. in Lunas at Autopsy (with Baden V, Selikoff IJ, and Hammond EC). Fifth National Conference on Electron Microprobe Analysis. New York, July 21-24, 1970. Invited paper: Electron Microprobe Analysis of Particles in Tissues (with Berkley C and Rubin IB). Second International Clean Air Congress. Washington, DC, May 1971. Paper with Selikoff IJ. International Agency for Research on Cancer. WHO, Lyon, September, 1972. Presented: Identification of Single Asbestos Fibers in Human Tissues with (Pooley FD). 6th International Meeting of Forensic Sciences. Edinburgh, September, 1972. Presented paper Asbestos Fiber in Human Lunas: Forensic significance in Environmental Disease (with Ehrenreich T). Dialogues in Microscopy, 1973, NY. Microscopical Society. Chaired Session: Identification of Asbestos, May, 1973. International Conference on the Biological Effects of Ingested Asbestos. NIEHS sponsored. Pinehurst, NC, November, 1973. International Conference on Environmental Sensing andJkssessment. Las Vegas, NV, September, 1975 (paper with Rubin IB and Wolff M). Chaired 2 Sessions: Fine Particles-7? Fine Particles-2. United States Environmental Protection Agency. Conference on Health Problems of Energy Technologies. NIEHS, January, 1976. Held by Mineralogical Society of London. London, April, 1976. Presented paper Nature and Range of Mineral Dust in the Environment. International Agency for Research on Cancer. The World Health Organization, Lyon. Invited member of working group, December, 1976. Chemical Carcinogenesis Monograph Series. Evaluation of Carcinogenic Risk of Asbestos. Vol. 14. LANGER, ARTHUR M. PAGE 39 INVITED INTERNATIONAL NESTINGS AND CONFERENCES (coat): Royal Society of Medicine. Meeting Focusing on Occupational Diseases. London, April, 1977. Presented paper Asbestos Content of Dust Encountered During Brake Maintenance and Repair (with Rohl AN, Weisman I, and Klimentidis R). Invited Consultant to Institute of Public Health. Oslo, Norway, May, 1977. Presented three papers: Contamination of the Biosphere bv Submicroscopic Particles: Asbestos___Mineral?____and___Their Carcinogenic Effects; Are There Safe Substitutes for Asbestos Materials? Invited Consultant to the Ministry of Mines. Biological Effects of Asbestos. Johannesburg, October, 1977. Monograph, Ministry of Mines. Health Hazards of Asbestos Exposure. New York, June 24-27, 1978. Presented paper on Contamination of Lake Superior with Amohibole Gancme Minerals and organized and chaired workshop on Significance of Aspect Ratio in Regulation of Asbestos Fiber Exposure. International Conference on Critical Current Issues in Environmental___Health___Hazards- Tel Aviv, March 4-7, 1979. Presented paper Defining New Asbestos High Risk Groups. Chairman Workshop: Laboratory Approaches in Environmental Medicine. International Agency for Research on Cancer. WHO, Lyon, October, 1979. International Conference on the Biological Effects of Inorganic Fibers. Invited Rappateur. Physics and Chemistry of Asbestos Minerals. Expert Consultant, International Metal Workers Federation. Geneva, September, 1980. Focus on problem: Asbestos Fiber Contamination of Metal Ore PepggitS- International Conference on Crystalline Deposits in Human Tissues. August 13-14, 1981. Mount Sinai Hospital, Toronto. Presented paper The Role of Analytical Electron Microscopy in Diagnosis _of the Pneumoconiosis (with Weisman I, Adams A, and Pooley F). Annual Symposium Scanning Electron Microscopy. Anaheim, CA, April, 1982. Presented paper Identification Characterization____and Quantitation of Asbestos Fibers in Human Lung Tissue bv Analytical Electron Microscopy. Fourth Annual Rocky Mountain Center for Occupational and Environmental Health Center. Salt Lake City, April, 1982. Invited to present two papers: Fibrous Minerals: Properties and Biological Activity; Relationship Between Surface Properties and Biological Activity in Health Issues Related to Metal and Non-Meta]lie Mining* LARGER, ARTHUR X. PAGE 40 INVITED INTERNATIONAL MEETINGS AND CONPBRENCES (COHt): World Symposium on Asbestos. Montreal, May 24-27, 1982. Presented paper Mineral Fibers; Properties Impaling Biological Activity. 6th International Pneumoconiosis Conference. Bochum, Federal Republic of Germany, September, 1983. Presented two papers: Recognition of Quartz bv the Erythrocyte Membrane; PhVSjcpghemical Factors Effecting Membrolvtic Properties of Quartz (with Nolan RP, Foster KW, and Simenski R). Chaired Session: Etiopathogenesis of Silicosis. Program of Research on Asbestos. University of Sherbrooke, December 5-6, 1983. Presented lecture Physicochemical Properties of Minerals as Related to Biological Activities. 2nd International Congress on Applied Mineralogy. February 22-25, 1984. Presented two papers: Asbestos. Fibrous Minerals. Acicular Cleavage Fragments and the Minerals Industries? Minerals,,_and Disease: The Association Between Exposure to Minerals and Rock Dusts and the Occurrence of Human Disease. Workshop on the Assessment of Mineral Fibers from Human Lungs. Oxford, England, September 17-19, 1984. Keynote speaker Problems of Tissue Analysis with the Analytical Electron Microscope, 3rd International Workshop on the In Vitro Effects of Mineral Dusts. Schluchsee, Hochschwarzwald, FRG, October, 1984. Physicochemical Properties of Minerals Relevant to Biological Activities, state of the Art, (paper with Nolan RP) ? Alteration of surface of quartz and altered biological activity. Workshop on Biological Effects of Chrysotile. General Motors Cancer Research Foundation. Cardiff, Wales, May 7-9, 1986. The Mineralogy of Chrvsotile Asbestos: Physicochemical FfPPerti*3-M Determinants of Disease Potential (with Nolan RP). International Programme on Chemical Safety (IPCS). WHO Environmental Health Criteria 53. Asbestos and other Natural Mineral Fibres. Hannover, Germany. Session chairman, co-author. 194 p., 1986. International Agency for Research on Cancer. The World Health Organization. Invited member of working group. Lyon, France, July, 1986. Chemical Carcinogenesis Monograph Series. Evaluation of Carcinogenic Risk of Fibrous Tale. Wollastonite. Palygprs&iSSx Sepiolite. Erionite and Crystalline Silica. Vols. 34-42. IANGBR, ARTHUR M. PAGE 41 INVITED INTERNATIONAL MEETINGS AND CONFERENCES (CODt): Symposium: Mineral Fibers in the Non-Occupational Environment. IARC-WHO. Lyon, France, September 8-10, 1987. Summary of five presented papers; Round-table discussant on Environmental Risk. Presented paper: Fiber Type and __Parenchvmal Burden Found__in workers Occupationally Exposed to Asbestos Fiber in the United States (with Nolan RP). Symposium: Fibers in Friction Materials. Society Automotive Engineers and the Asbestos Institute. Symposium organizer and Co Chairman. Fibers and Health Issues. Atlantic City, NJ, October, 1987. Presented summary paper; co-authored Physicochemical Properties of Fibers and Biological Potential (with Nolan RP). Symposium: Safe Use of Asbestos Cement. Peruvian Ministry of Health and the Environment. The Asbestos Information Association of South America. Lima, Peru, March, 1988. International Symposium/Workshop: Biological Interaction of Inhaled Mineral Fibers and Cigarette Smoke. Session Chairman. Presented paper: Inorganic Particles Found in Cigarette Tobacco. Cigarette Ash, and Cigarette Smoke; co-authored PhygiCP-ChemiCfll Properties and _ Membranolvtic _Activities of the Titanium Dioxide Polymorphs Compared to Quartz. April 10-14, 1988. Electron Microscopy Society of America; the Microscopical Society of Canada: Presented paper: Electron. Diffraction of Mineral Fibers Vs. Acicular Cleavage Fragments. Milwaukee, Wl, August 7-12, 1988. National Organizing Committee, Workshop chairman: Hazard Recognition of Mineral Dusts. Presented: Mineral Fibers in the Lung Tissues of Persons Exposed to Asbestos in the United States; Distinguishing Between Tremolite Asbestos and Tremolite Cleavage Fragments. Vllth International Pneumoconiosis Conference, Scientific Organization Committee. Pittsburgh, PA, August, 1988. Session Chairman: Asbestos, Pleural Pathology, and Lung Fiber Burden. Vllth International Pneumoconiosis Conference, Pittsburgh, PA, August, 1988. Workshop on Asbestos Research. Health Effects Institute, American Academy of Arts and Sciences, Cambridge, MA, October 31-November 1, 1988. Symposium on the Health Aspects of Exposures to Asbestos in Public Buildings. Presented: Fiber Type and Risk of Mesothelioma__t Building Occupants. John F. Kennedy School of Government, Harvard University, Cambridge, MA, December 14-16, 1988. DANGER, ARTHUR M. PAGE 42 INVITED INTERNATIONAL MEETINGS AND CONFERENCES (cont): First International Conference on Health Related Effects of Phyllosilicates. International Scientific Organizing Committee. Session Chairman: Health Related Effects After Non-Occuoational Exposure. Presented: Fibrous Minerals as Natural Contaminants of Phyllosilicates (with Pooley F) . Paris, France, March 16-18, 1989. International Federation of Building and Woodworkers. Health Hazards in Painting and Allied Trades. Presented: Hazards in the Painting Trade. Panelist. Geneva, Switzerland, May 8-12, 1989. NATO Advanced Research Workshop on Mechanisms in Fibre Carcinogenesis. Presented: The Importance of Mineral Subpopul at ions in Biological Assays. Alburquerque, NM, October 22 25, 1990. Co-authored paper: Association of tremolite habit with biological potential, co-authored with Nolan RP, Oechsle G, Addison J, Colflesh D. American Lung Association - American Thoracic Society. 1991 International Conference. Presented: Mechanisms of Asbestos- Induced Pulmonary Disease: Importance of_Surface Properties of Asbestos and Non-asbestos minerals in cell interaction. Anaheim, California, May 12-15, 1991. American College of Chest Physicians. Fourth International Conference - Environmental Lung Disease. Presented: Diagnostic Methods in Occupational Luna Disease: Mineraloaic Techniques. Co Chair session: Diagnostic Methods in Occupational Lung Disease. Montreal, Canada. September 25-28, 1991. Chemical Industry Institute of Toxicology. Workshop on Approaches to Evaluating the Toxicity and Carcinogenicity of Man-made Fibers. Durham, North Carolina. November 11-13, 1991. "" " Institute for Glass Science and Engineering. Workshop on Chemical and Biological Interactions of Glass. Discussant on Biologically Important Properties. Bethesda, Maryland. March 5-6, 1992. International Geological Congress. Environmental Mineralogy in relation to human health and activities. Session 1-3-49. Co-chair with N. Kohyama, J. Addison, Kyoto, Japan. 24 August-3 September, 1992. Introduction. Importance of environmental mineralogy. Summing up. l September, 1992. Biopersistence of Respirable Synthetic Fibres and Minerals. Presented: Comparison of luna tissue mineral fibre retention of exposed workers and the general population. With RP Nolan, co authored : Health hazard evaluation of the lung tremolite fibre content among Canadian chrvsotile workers, with RP Nolan and J Addison. Round-Table discussant on: Role of Biopersistence--in Pathogenicity. IARC, Lyon. September 7-9, 1992. LANGER, ARTHUR N. PAGE 43 INVITED INTERNATIONAL MEETINGS AND CONFERENCES <cont) Symposium on Chemicals and the Environment. Chemical Specialities, '92. Invited presentation: Zeolite catalysts. Is there a health risk? Philadelphia, 3-4 November, 1992. International Life Sciences Institute. 4th International Inhalation Symposium, Hannover. Invited Faculty Presentation: Factors Controlling the Biological Potential of Inorganic Dusts. Surface Chemistry and Character. With R.P. Nolan. Hannover, 1-5 March, 1993. Hoffman-LaRoche Pharmaceuticals. Analysis of Medicines for Asbestos. Microscopy Protocol. Edinburgh, U.K. Institute of Occupational Medicine. April 25-26, 1993. Cellular and Molecular Effects of Mineral and Synthetic Dusts and Fibres. NATO Advanced Workshop. Invited paper: Phosohorvlated Canadian chrvsotile. With RP Nolan and G Herson. Chaired session: Physico-chemical properties of minerals in relation to their biologic effects. Paris, 11-13 October, 1993. Workshop on the Health Risks Associated with Chrysotile Asbestos. Inti. Commission on Occupational Health - Inti. Program on Chemical Safety (WHO) Presented paper: Chrvsotile: The Mineral and Its Properties. 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at g co at o* g CO PS O CO rH o h a C P 0 CO c at c P cu P 1H MOO) a) * m P tH CO pnok0) 0) ^ P C0 *0 at co *o a H 9 CO 0 P iH to at p *aut t0H 0c **h at > *H o tH a0 H > t0H <CO 0> in p CO tn c <P <0 at o ao CO 0 <5 C0 W CO mC CgO > tH 10 at >i i1 *anJ Os 0) r* 9 \c rH H OP \c r* o O0 rH fS 00 \\ rH o rs rs \\ 0 SO 01 01 O rH 00 \\ rH rH oO \\ Os P^ oo tH 0 11 p H H CO P P O' CO CO H at Qt p >> CO c c at H M > c HH w CO 10 aa rH H *H - 0 o_ a cc H H H 0 tH tH tH tH c ao ao H ip ip tH O C0 O co a O O' u o* TJ C rH CM (0 co OO CO *H MOD' 0) P 0 HUH P 0) 0 tn P *H at iq p a co oc tn 0) *H a rH rH h at co at p -h OO OP co a tn e 5h at tH tH CO P 9P+> o w o *h a tH 0) O c (0 P O0 0) rH V-S CO O P tH ca at gp C0 O tH tH CO *h at > CO Uc at tH *o 9 P 0 CO H P CO P >1 rH rH (0 co at cs (0 CO at *h rH O' u at h a p tH co P a0 TOTAL DIRECT SUPPORT so 9m) ooo Ooo Q o w oy* o s* ooin s,, n rH o r o' on in 0rs4 o om pH Cr>O 0) B CD C 44 to 4J 0 3 u O *H 0 3 CO pH 44 pH pH OO' *0 CD <0 P IQ Lh 0 -H CO C CL Wo z CO U zM <0 *0 <0 c <0 CJ IQ 0 10 c IQ V UB A1 0 Li U 0) e 3 4-> 4-> pH H A> Lh C ft) IQ c H co 0 p CO ft) CO pH 3 z0!) -sI OH >, P O' 10 o Z pH 0 1u * < < CD 0) C <M >co ae ft) 43 PP 3 pH pH WX CO CO O 3 0 CO U CO > v < <Q 0 AU zCO eo* SOURCE OF FUNDS PROJECT PERIOD ROLE IN PROJECT CO \ pH m SO CO \ o r> so 00 \ pH n r* CO CO CO o OS CO CO CO CO CD 9 CO CO N pH N pH \s H pH \ o VN pH pH n O o m n OO \ \ S \ \ \ \ \ "N S CO o SO O 1 CH pH n PM c* r> so SO CM oi 01V pH 0 1 o O pH (N r- r* CO r- CO CO CO CO \ CO \ CO \ CO \ CO \ CD N CO \ CO \ CO CO \ pH pH pH pH pH pH pH pH pH o o O O O O O oo \ 0% o \ ro \ O' o \ pH \ pH \ V \ \ n PM CO o pH o o o pH O | pH 44 to 0) 44 > 60 C H *OH' 0 pH pH a10 10 u H a) uc C *H H Li \ CL U 0 1 44 0 (0 U 0> ft) 44 H 0u 44 Q) pH C CO 3 0B M 0> <0 o 4-1 c 0 IQ >i CO 44 0 pH 44 > CD U pH ft) ft) 44 43 43 0 CO -pH < IQ 4-1 CL 13 -H 0 44 Ll CD O ft) > >i C CP HH 0 pH pH (Q IaQ Ll 0 W fi 0 *PH CX H \ Ll oLi Li ft) a o 1 44 IQ 0 10 ft) cj &X 44 4: c 44 .IQ pH D <0 u ft) Lh ft) P-4 44 IQ C 44 ft) CU ft) E CO C 0) 00 Lh *h h> >2 C ft) A CO Lh 0 44 10 O' pH 44 CO ft) > c H pH IaQ pH 0 c pH Li CL 4-1 0 >, ft) 44 pH pH *pH > 44 H 0 44 CO Lh 0 >i ft) IQ Lh 43 43 *H pH O 4-1 (0 0 *0 CO pH ft) 0 0>*pH 44 -H0 44 CO pH ft) 0 *0 u pH 0 CD A E (0 Lh 0 44 10 O' pH 44 CO 0) > c H rH 10 a -pH 0 c -pH Lh A 4-1 0 CO 5* ft) 44 44 pH 3 > 44 pH pH 44 44 0 CO 10 n3 pH (0 (0 l> CO H o CP 44 0 CO pH ft) 0A pH CO A (0 Lh O 44 10 O' pH 44 CO ft) > e H pH <0 A pH O c pH Lh A T3 C 44 10 C CD ft) 44 *c ao pH 0 A CO <M 0 0 44 CO CD ft) pH A CD CO * 10 pH 10 Lh C0 < < Lh O 44 (0 tr pH 44 CO ft) >c M H 10 A H 0 c pH Lh A Lh O <M CO Lh O ft) pH 44 10 O 44 IQ U <Lt 10 0 13 O CD H pH CO 10 )H pH ft) 10 C B5*2 < u 0 44 1O0 ' H 44 CD ft) > C H pH (0 A pH U c pH Lh A CO ft) 44 4H 3 0 44 pH CO 44 ft) CD H A 44 3 Lh CD ft) A*0 0C Lh (0 A CO ft) 0 U 44 10 CO <M ft) Lh 43 3 CO C/3 IQ 1 H 44 CO a> Lh >O c 44 H 10 pH 10 A pH 0 c pH Lh Lh A0 1 44 0 10 O 0* >i A O O CO 0 Lh O pH CO ft) C *pH O Lh pH 0 44 44 10 10 3 Lh pH 0 a 43 > 15 AM pH 44 CO ft) ... > C H pH 10 A pH o c pH Lh A . C pH ft) CO 44 0s pH C C3 O pH 44 CO pH (0 10 pH 6 pH *H 0 c 10 PROJECT CD DC<DODu <J HEOd HZ0O* EHO- OChWCDu Oo* ion oo ooo(\&N pH re EOZDd CQZDO OCO EOl* roe ucre at <zCO re 4creJ u prHe c0 s A pH -pH 0 AAC0rOe) AvLrei >i crae >cre obo oofFM0* ooo oin 0 4pH h Zp0reH re UpDE00hH)> O>CraS0ei 0 o re o crL5ei 10 c HI <z u ooo o mcs oo oo oo * oo o imn o pH o ON PoS r* , CreO Eh A pH z 0 o Uh c o0 UJ rrreee re Are A co re > pH c A re re cu Li B 30 QO (0 3 C pH a> re A ffi Li re r3e Xre co u CD z Li >0 z5re co DO Uz D O CO CzD H 2 Du z z D Z * % Z DO C9 2 3 o Qo C\ \ H pH ZO W\ a ON 0 Eh 11 U CO w 00 \ o pH aO a* \ o CO CO A \ poH Cre L< \ Eh O' 3 011 U1ft a ON a CO \\ pH pH OO \N CoO NoO pH ON 4J A AAA \ ON ere fH \ CreO roj aEh i Cre CreO u a Cre Cre Cre troe troe creo u Li Li NO a i a i a ON iN ON co CO CO \N pH ON \ r> PS m ON On ON ON o \Ns 1 opH o O r \\ CO NO o o r s H o pH pH pH CN o o O ON N pH \ o \ r \ ON O rH o o &H o Ed z3 a zM EAd zO Eh U Ed 3 z 0* u 0 Aroe* H 4- >c100) H pH rae *ucH auH* * r*e C4O> A3 CreO 0 A *H 0) A Li <D CO <D aa a C0 3 0 re CO Li a *0 CO 0) 0 4) H4cJo 0 re H 0) MH 'DAL S0 CreO 3co Lt 0 Aore* pH A Crc>eO H praMHe 0c H ZLi re A pH p3H 0 pH eC re > c pH uCO Are fH*4 u 0 A re O' pH A CO cr>e H praHe pcrHeH ZEh creo pH AUh 0 0 pH Vcre *rhrHe co Acre oHU a *0 Cre Aasre G 0 re a <N N s H LHi H re Lo 4-> CO re re < re p-h -h re re ^o aco aco re Lt re o poH *H a re co re ci 0c Li O Are re* pH A rcC>eO H praHe prceH pH ZLi Tr3e Are proeH creo CO *H CO A re *h Li CO 3 Aa H fi H 0 C pH re re Eh re re prHe *hC bB Li 0 Are pOH' a troe > c H Hre paH o c pH Li Z (0 0A A0 CreO e A 0 Eh rCeO pH a preH (M A C 0 0>*-frHei-H*Co <0 AH 3 C *H A03 CO 0 A U 0 Are Li pOH ' A CO 0 prHe A0 O' re ' a-* > c H H o cH Arree > 0 u Eh C Z Hi CO c 0 pH CO Q -pH Srie Are More Acre CO o O' Sre AweOr' e0 ure-H a paH > re 3 re < *0 L pH CO 0 Mo o AXre CreO z0 O' B <H 0 0 <LHi rrrreeee rree Eh pH zre *a<hu (H 0 Are pOH' A Eh 0 CreO Are > c pOH' HI A CO prHe re > Hc 1 - paH 0 cH 0 Eh uZ re A u B3 0 *0 Eh 0 A Eh re a CrreeO >t pH a prhe Lt asre re O' oc Arree*pABJ A3 re h <a CO O' c 3 pH re MrEreeh A Eh A 03 C H re *rr0ee 00 arree axre A re *m << o Li 0 A A -OpH' Are re > c M 1 O U i re 0 >i c $0MA pH CO 0c AtroHe -<prreeH Ac *o re re B pH ZA HACA04L*#SMWH1 Cf1fWt 0|1 < Ed O SENT BY F&L YILSAIXEE 1-14-84 e 41A>. ; 414'2C8-.3T91-KELLN. DRYE & .tfR.V 3 IK THE UNITE) 8TATE8 DISTRICT COURT FOR EASTERN DISTRICT OF PENNSYLVANIA ----------------- ------------ IN RE: ASBESTOS PRODUCTS LIABILITY LITIGATION (NO. VI) ..................------------ ----------------X CIVIL ACTION NO. XDL 875 This Document Relate* Tot UNITED STATES DISTRICT COURT FIFTH DIVISION DISTRICT OF MINNESOTA CONNED CORPORATION, Plaintiff, vs. Cass No.: Civ. 5-93-88 UNION CARBIDE CHEMICALS AND PLASTICS COMPANY, INC., (f/fc/a Union Carbide Corporation), Dafandant, and UNION CARBIDE CHEMICALS AND PLASTICS COMPANY, INC. (f/)c/a Union Carbide Corporation), vs. OWENS-CORNING FIBERGLA8 CORPORATION, WALKER JAKAR COMPANY, A.W. KUETTEL 8 SONS, INC., API, INC., and MacARTHUR COMPANY, Third Party Defendants. NOTZCR OP DEPOSITION OP SR. ARTRUl N. LANGKR TO: Mr. Robert D. Brovnson Stieh, Angall, xreidler 8 Muth, P.A. The Crossings, Suite 130 350 Second Avenue South Minneapolis, MN 55401 All Counsel of Record PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. P. 30, the deposition of Dr. Arthur M. Langer vill be taXen at 9:30 a.R. UVW(l for ID#rEV_____ Robert E Livy C S Ooyl* Reporting, Inc *)L*ALKtt l' i4-3i 0 *.<* on January 14, 1994 at tha offices or Ksllsy, Drya t Warren, 101 Park Avenue, 32nd Floor, New York, saw York 10179. Tha deposition aha 11 contlnua froa tiaa to time and from placa to placa aa nacaaaary until coapleted, and may ba uaad tor all purposaa contemplated undar tha Federal Rules of Civil Procedure. PLEASE TAKE FURTHER NOTICE that tha vitnaaa ia required to produoa tha documents daacrlbad aa follows: 1. Any report, analyaia, taat raaulta, notaa or documents relating or refarring to any aaaplaa of calidria or Coalinga asbaatoa Or. Langar haa ravieved, examined or tastad. 2. Any publically unraportad or unpuhliflhad data, taat raaulta, atudiat or reports upon vhich Dr. Langar relies to support any opinion ha has formed for or intends to offer in this action. 3. Dr. Langar*s file for this case. 4. Tha results of Dr. Langar*s analysis of ths samples ha took at tha KCAC asbestos mine in July of 1993, Datadi January 6, 1994 TREVOR J. WILL (WBH 1008725) FOLEY 8 LARDNXR 777 Esat Wisconsin Avenue Milwaukee, SI 53202*5367 (414) 271-2400 (414) 2S9-3791 (fax) Direct inquiries to: (414) 289*3517 (TJW) Attorney for Union Carbide chemicals and Plasties Coopany, Inc. JftN-13-94 THU 16:02 FAX NO. 6123331940 P.33/37 * . 3 Klaeraiegioal luiTtii of cuyaotlu On Specimens Obtained la the seme Hi (formerly Onion Oasbide's How xdrla Deposit) Ore specimens obtained during the July 27, 1993, field trip to Union Carbide1 a Hew Zdrla eabeatos depoelt vara subjected to' analyala by polarised light microscopy and continuous seen x-ray diffraction. Selected epeoiaane vara examined by analytical electron microscopy. The twelve epeclmane collected from the pit were separately (and gently) ground by hand In an agata mortar with pestle. Aliquots of eaoh specimen vara mounted in appropriate immersion oile for purposes of mineral identification end charaetarisation. The indices of refraction of the lmertlon oils ranged from n 1.51* n - 1.700. The findings mere es followsi ehrysotile fiber was found in all specimens, but ranged in concentration; at lOox magnification several of the fiber bundles approached approximately lam in length (commercially a "short1' fiber) * intexgrowths of fiber and massive serpentina were common end occasionally some fibers displayed anomalous blue-gray birefringence; fragments of other minerals derived from the host root (serpentinite) ranged in abundance es well, a foliation of proximity to the central ore body; other mineral particles identified included plaglocalse feldspar (displaying tindulatcry extinction of elbitm twinning); altered ulnaral fragments with optical characteristics of both olivine end pyroxene ware observed; piety form of serpentina (lltardite and antlgorlte) verm observed; ehrysotile bundles with llmonlte stains -y , ; RobartE levy CSRjmJ 1 J Do*. B^iorttnfl.Inc W(flflff JAN-13-94 THU 16:03 FAX HO. 6123331940 P. 04/07 P. a suggested weathering of associated iron-containing mineralsf several carbonate minerals, including magnesite and caloita vara present) fibers with optical properties consistent vith tha brucita vara observed) aoaa fibers of brucita displayed signs of altaration (coalingita?). in ona specimen, number 1, a fragment of an amphibole mineral traa dotad. Tha fragment vas a single crystal, non-polyfilemantous, and na not aabaatifoni. Tha identity of tha fragment remains unknown. Opaqus minerals (magnetite? chromite?) were alao noted. Aa vlth tha other principle minerals, thair concentrations vara obaarvad to ba variabla. it vaa notad that certain minerals ranged widely in concentration throughout the deposit. The opagua mineral, thought to ba principally aagnatita/ although invariably present in all specimens ranges considerably in concentration. fo it la alao for tha brovniah alteration produot of bruaita (oo&lingita) aa vail aa for tha praaanoa of fractured and aarpentinlsed raaidual olivine and pyroxene alnarala. An analysis of pallatised ora, JU3 100. in addition to chryaotllo/ oontalnad concentration* of mafic ainaral fragnantar opagua minerals, and brucita altaration products. In tha many allguata examined lay polarised light microscopy no aaphlbole mineral vaa observed* it is important to note that fibara era obaarvad vithln tha JAH-13-94 THU 18:04 FAX NO. 6123331S40 p. oe/07 4 Analytical ilaafcron Mlcrcaoonv as for analysit of specimens by continuous tom x-ray diffraction only select sample* vara analysed by analytioal electron nioroccopy. It vas decided, hovavar, basad on resources, that only tha final ora product (AC 100) vould ba sxamlnsd In datail, the instrument uaad vaa a J50L 100 CX intarfaoad vith a Traoor Northern 5300 energy diaparsiva x-ray apaotranatry system. A number of grids vara praparad and examined. Chrysotile asbestos Is a tha principal elnaral in all of tha preparations axanlnad. Salactad araa alactron diffraction patterns are consistent with standards for olinochrysotlla. Associated platy minerals are oonslatant vitb liaardite, antigorita and braeit*. Occasionally, an elsctron-dense mineral fiber/ vith aspect ratio > 15H, was observed. Morphologically this sineral resembles an amphlbole but Inspection of the salactad araa alactron diffraction pattern suggests a complex structure not unlike tha talabolea found in eany talc deposits in tha United States. The magnesium silicon ratio is much Isas that for ohryaetile, generally lying in the range of 0.45-0.53. Chrysetils appears to be associated with the fiber, vith Its long axis parallel to th* long axis of the electron-dense mineral, tbs chemistry of ehrysetlle obviously effects the chemical ratio obtained on these fibers (chryeotlle's ratio of magnesium!silicon is approximately 0.75-0.05). It is JAN-13-94 THU 16 = 05 FAX NO. 6123331940 ?.07/07 0 unknown at thia tin* if this mineral represents an lntergrovth a chain silicate and a serpentine mineral or la tvta on* of th discredited xpmtlM alnaraia which baa b**n ahovn to )m i mixture of several of tno associated magnesiua silicate phases. Environmental Scienoea Laboratory