Document YG2pOQJnoJm57N2o6ZDjLqmvy
FILE NAME: &'ZZ&' DATE: DOC#: &' DOCUMENT DESCRIPTION:>ZZZ/ZZ
Subject: Goodrich From: Michael Shepard <mshepard(0shepardlawfirm.com> Date: Wed, 23 Apr 2008 17:49:14 -0400 To: "Barry Castleman (barry.castleman("dgmail.com)" <barry.castleman(aigmail.com>
Barry,
Here is some Goodrich discovery from Rhode Island. Attached as Exhibit F to the discovery answers is a list of publications to which Goodrich subscribed. Attached as Exhibit A is a list of medical employees of Goodrich over the years. I hope this helps your research project.
Best regards,
Mike
1 of 1
4/24/2008 8:37 AM.
1 WILLIAM G. HOBACK, ESQ., Bar No:088655 JOSEPH J. MINIOZA, ESQ., Bar No.-197379
2 VANESSA JARVIS, ESQ., Bar No. 201585 _
ECEIVED CHASTINE A. FISH, ESQ., Bar No. 206663
3 ERICKSEN, ARBUTHNOT, KILDUFF, DAY & LINDSTROM, INC. 530 Water Street, Suite 720
4 Oakland, CA 94607 (510) 832-7770
5 Attorneys for Defendant,
6 GOODRICH CORPORATION
' 5 2002
7
1(AZAN,
Ai! ,EDISES,ABRANS.
FEftNANDEZ, YONS& FARRISE
8
9
10
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
11
UNLIMITED JURISDICTION
12 IN RE:
13
) No.: 828684
) DEFENDANT GOODRICH 14 COMPLEX ASBESTOS LITIGATION ) CORPORATION'S RESPONSES TO
15
) GENERAL ORDER NO. 129
) INTERROGATORIES
16
17
COMES NOW, the defendant, GOODRICH CORPORATION, and pursuant to San
18 Francisco Superior Court General Order No. 129, answers the interrogatories propounded to
19
20 it as-follows.
21
Defendant and its attorneys have not completed their discovery or preparation for
22 trial, nor have they completed their analysis or review of the investigation and other trial
23 preparation matters and subjects obtained conducted to date. These answers, therefore, state 24
the present information and analysis of the defendant and its attorneys as acquired and 25
26 reviewed to date, without prejudice and to. defendant's right to present additional facts,
27 contentions or theories at the trial based on information evidence or analysis hereinafter
28 obtained or evaluated. The following answers state the information, facts, evidence, and
-1Responses to General Order 129 Interrogatories - 2002
1 contentions presently known to and evaluated by defendants and its attorneys. The following
2 answers at this time are preliminary only in light of the severe time constraints placed upon 3
defendant by plaintiffs in responding to these detailed interrogatories which seek information 4 5 from many sources over one hundred years. These answers to interrogatories are an ongoing
6 project and most likely will change as more information is discovered and reviewed. Over
7 the years this defendant has acquired a number of smaller companies whose product lines
8 may have discontinued many years ago. The information regarding those prior products,
9 from years past, is limited if not totally non-existent. Defendant and its attorneys are
10
11 attempting to go back in time through various avenues to obtain as much information as is
12 possible. Ai that information comes to light, these answers will then be supplemented and
13 modified accordingly. Therefore, these answers should not, and cannot, be construed as final
14 or complete answers to any of the questions posed.
15 RESPONSE TO INTERROGATORY NO. 1:
16
17'
Jerry A. Smith, consultant to the Goodrich Corporation, do Canal Place Ltd. 520
18 South Main Street, Suite 2511, Akron, Ohio 443311-1010.
19 RESPONSE TO INTERROGATORY NO. 2:
20 Objection. Defendant objects on the grounds that this interrogatory is overly broad,
21 unduly burdensome and irrelevant to any issue in this case not reasonably calculated to lead
22
23 to discovery of admissible evidence. Notwithstanding this objection, Defendant answers as
24 follows: Mr. Smith began his employment with the Goodrich Corporation on January 15,
25 1959. He held clerical position in the mail and telecommunication department s until 1964.
26 From 1964 to 1974, Mr. Smith held supervisory and management position in the
27 28 telecommunications department. In 1974, he was appointed director, MIS
- 2 Responses to General Order 129 Interrogatories - 2002
1 Telecommunications. In 1981, Mr. Smith was appointed director of Administration and
2 Information Services Support and in 1982 was appointed director of Administrative Services.
3 Mr. Smith retired from the Goodrich Corporation on February 1, 1990. He has been a
4 5 consultant fOr Goodrich since February 1, 1990.
6 RESPONSE TO INTERROGATORY NO. 3:
7 Yes.
8
A) Goodrich Corporation;
9 B) New York;
10
11
C) May 2, 1912;
12 D) Four Coliseum Centre, 2730 West Tyvola Road, Charlotte, North Carolina 28217;
13
E) Yes. August 1, 1934 to date;
14 F) Not applicable.
15 G) There are several Goodrich plants located in California. Goodrich Corporation's
16
17 principal place of business is Four Coliseum Centre, 2730 West Tyvola Road, Charlotte,
18
North Carolina 28217
19 RESPONSE TO INTERROGATORY NO. 4:
20 Yes.
21 22 RESPONSE TO INTERROGATORY NO. 5:
23
Goodrich started in 1879 when it formed the partnership of Goodrich, Tew & Co. In
24 1874, the partnership changed to the name B.F. Goodrich & Co. On May 10, 1880,13.F.
25 Goodrich transformed the partnership into an Ohio-chartered corporation until such time that
26 it was reincorporated as a New York business on May 2,1912. The company name had
27 28 remained the same until June 1, 2001, when it changed its name to Goodrich Corporation.
-3 Responses to General Order 129 Interrogatories - 2002
1 RESPONSE TO INTERROGATORY NO. 6:
2
Not applicable.
3 RESPONSE TO INTERROGATORY NO. 7:
4
5 Not applicable.
6 RESPONSE TO INTERROGATORY NO. 8:
7
Not applicable.
8 RESPONSE TO INTERROGATORY NO. 9:'
9 Mr. Smith, previously identified in interrogatories 1 and 2, has access to relevant
10
11 business records at the company.
12 RESPONSE TO INTERROGATORY NO. 10:
13
Defendant is unable to fully and completely respond to this interrogatory at this time
14 as no available dates have been forth encompassing the requested period for information and
15 16 defendant's investigation and discovery have not yet been completed. However, based on
17 information available to date, defendant responds as folloWs:
18
A. Goodrich Corporation has no current employee with this knowledge., however,
19 Mr. Smith, previously identified has researched and is familiar with this subject.
20 B. With respect to certain aircraft brake products designed, manufactured and sold by
21 the company, Roland E. Cecil, Supervisor Configuration Control with the Goodrich
22
23 Aerospace Landing Systems, in Troy, Ohio. Mr. Cecil has worked for the Goodrich
24 Corporation since 1958.
25
C. Not applicable. Discovery is continuing.
26 RESPONSE TO INTERROGATORY NO. 11:
27
28 Goodrich object to this interrogatory on the ground that it is overly broad, unduly
burdensome, irrelevant 16 any issue in this case and not reasonably calculated to lead to
- 4 Responses to General Order 129 Interrogatories - 2002
I discovery of-admissible evidence. To require Goodrich to identify the medical directors,
2 industrial hygienists and physicians it has employed over the years constitutes a request for
3 masses of irrelevant information, is unduly burdensome and beyond the'scope of permissible
4 discovery. Withoulwaiving said objection, defendant responds as follows: Defendant is
5 unable to fully and completely respond to this interrogatory at this time as discovery and
investigation are continuing. However, based upon available discovery which has been done
7 to date, defendant responds as follows: for the period 1930 to 1985, the following
8 physicians, medical directors and/or industrial hygienist were employed by the Goodrich
9 Corporation set forth in Exhibit A attached.
10 RESPONSE TO INTERROGATORY NO. 12:
11
Yes: Please see listing of those employees who have given testimony while
12 employed by Goodrich which is attached hereto as Exhibit B. . 13
RESPONSE TO INTERROGATORY NO. 13: 14
15
Goodrich objects to this interrogatory as being overly broad, unduly and unreasonably
16 burdensome.and oppressive and not calculated to lead to the discovery of admissible
17 evidence in that this interrogatory requests information readily accessible to plaintiff from
18 sources other than this defendant. Moreover, Goodrich Corporation never engaged in the
19 20 marketing of any raw asbestos. Without waiving said objectionS, Goodrich has, at times,
21 belonged to the Industrial Hygiene Foundation and/or Industrial Health Foundation, the
22 National Safety Council, the American industrial Hygienists and Resilient Floor Covering
23 Institute) or any other name in which it has existed).
24 RESPONSE TO INTERROGATORY NO. 14:
25
26
American Industrial Hygiene Association
27
A. 1975 to the present; personal membership; never a corporate membership.
28
B. AIHA Journal.
5 -
Responses to General Order 129 Interrogatories 2002
1
C. To our knowledge, none.
2
National Safety Council.
3 A. 1975 to the present; personal membership; never a corporate membership.
4
5
B. Unknown; discovery is continuing;
6
C. None, based upon this defendant's current corporate knowledge.
7
American Industrial Hygienists\
8
A. Unknown.
9
B. Unknown. 10
11
C. Unknown
12
Resilient Floor Covering Institute.
13
A. Unknown.
14 C. Unknown.
15 C. Unknown
16
17 RESPONSE TO INTERROGATORY NO. 15:
18
. No, based upon this defendant's current corporate knowledge.
19 RESPONSE TO INTERROGATORY NO. 16:
20 No, based upon this defendant's current corporate knowledge.
21 22 RESPONSE TO INTERROGATORY NO. 17:
23
No. based upon this defendant's current corporate knowledge.
24 RESPONSE TO INTERROGATORY NO. 18:
25
Goodrich objects to this request on the grounds that it is overly broad and
26 burdensome and that it seeks information not relevant to the subject matter of the information
27 .
28 not relevant to the subject matter of the litigation and which is not likely to lead to admissible
-6Responses to General Order 129 Interrogatories - 2002
1 evidence, in that not all such libraries and/or collection of books and publications would have
2 any relevance to the case at bar
3 Notwithstanding the foregoing and without waiving any applicable objections,
4 5 Goodrich has maintained several libraries since the Company, was formed in 1870, each with
6 many collections of books and publications. Certain Company libraries, which may have
7 been in existence since 1920, have been closed. Certain company libraries may have been
8 closed or sold along with other various business entities.
9 RESPONSE TO INTERROGATORY NO. 19:
10
11
No, based upon this defendant's current corporate knowledge.
12 RESPONSE TO INTERROGATORY NO. 20:
13
No, based upon this defendant's current corporate knowledge.
14 RESPONSE TO INTERROGATORY NO. 21:
15 Defendant believes the answer is yes based on current corporate knowledge.
16
17
A. 500 South Main Street, Akron, Ohio; and Marion, Ohio, both of which were
18 shut down quite sometime ago.
19
B. Accordingly, documents responsive to this interrogatory, if any exist, can be
20 made available for inspection at defendant's offices were the documents are kept, at a mutual 21 22 convenient time during regular business hours. Defendant has not done a separate
23 compilation of the information requested and any such information would exist in any
24 remaining existing documents from these locations.
25
C. Accordingly, documents responsive to this interrogatory, if any exist, can be
26 made available for inspection at defendant's offices were the documents are kept, at a mutual
27
28 convenient time during regular business hours. Defendant has not done a separate
Responses to General Order 129 Interrogatories - 2002
1 compilation of the information requested and any such information would exist in any
2 remaining existing documents from these locations. 3
D. Accordingly, documents responsive to this interrogatory, if any exist, can be 4 5 made available for inspection at defendant's offices were the documents are kept, at a mutual
6 convenient time during regular business hours. Defendant has not done a separate
7 compilation of the information requested and any such information would exist in any
8 remaining existing documents from these locations.
9 E. Accordingly, documents responsive to this interrogatory, if any exist, can be
10 11 made available for inspection at defendant's offices were the documents are kept, at a mutual.
12 convenient time during regular business hours. Defendant has not done a separate
13 compilation of the information requested and any such information would exist in any
14 remaining existing documents from these locations.
15 RESPONSE TO INTERROGATORY NO. 22:
16
17
No, based upon this defendant's current corporate knowledge.
18 RESPONSE TO INTERROGATORY NO. 23:
19
Defendant is not aware of any such tests or studies at this time, however, discovery is
20 continuing.
21 RESPONSE TO INTERROGATORY NO. 24:
22
23
Yes.
24
A. Yes.
25
B. See copy of thd Goodrich policy OHP001.3.10, Exhibit D.
26 C. See copy of the Goodrich policy OHP001.3.10, Exhibit D.
27
28 D. - Dr. Ray Bermea. (No longer employed by Goodrich)
-8 Responses to General Order 129 Interrogatories - 2002
1 RESPONSE TO INTERROGATORY NO. 25:
2
Goodrich objects to this interrogatory on the grounds that the information sought is
3 irrelevant in this case and is not reasonably calculated to lead to discovery of admissible
4
5 evidence. The plaintiff has never been a Goodrich employee and does not allege ever
6 visiting any Goodrich facility. Notwithstanding this objection and without waiving any
7 applicable objections, the defendant responds as follows: No, based upon this defendant's
8 current corporate knowledge.
9 RESPONSE TO INTERROGATORY NO. 26:
10
11
See Attached listing of liability insurance carriers that is attached hereto as Exhibit C.
12 RESPONSE TO INTERROGATORY NO. 27:
13
No, based upon this defendant's current corporate knowledge.
14 RESPONSE TO INTERROGATORY NO. 28:
15 No, based upon this defendant's current corporate knowledge.
16
17 RESPONSE TO INTERROGATORY NO. 29:
18
Not applicable.
19 RESPONSE TO INTERROGATORY NO. 30:
20 Yes.
21 A.Yes, based on available records from 1939 to 1985
.22
23
B. No, based upon this defendant's current corporate knowledge.
24
C.See subpart A above.
25
D. See subpart A above.
26 E. See subpart A above.
27
28
F. Unknown.
Responses to General Order 129 Interrogatories - 2002
G.See subpart A above. _
H.No, based upon this defendant's current corporate knowledge.
3 Discovery is continuing.
4 5 RESPONSE TO INTERROGATORY NO. 31:
6
Defendant is unable to fully and completely respond to this information because of
7 the extensive time period to which these interrogatories pertain. Only limited information is
8 still available. Notwithstanding this difficulty and without waiving any applicable objections
9 and the fact that investigation and discovery are still continuing, defendant responds as
10
11 follows: See Exhibit E attached.
12 RESPONSE TO INTERROGATORY NO. 32 (PREMISES DEFENDANTS only)
13
Not applicable.
14 RESPONSE TO INTERROGATORY NO. 33 (CONTRACTOR DEFENDANTS only): 15
Not applicable. 16
17 RESPONSE TO INTERROGATORY NO. 34:
18
Goodrich Corporation has never manufactured or distributed any raw asbestos. With
19 respect to exclusive distributorship, defendant responds as follows: No, based upon this
20 defendant's current corporate knowledge.
21 RESPONSE TO INTERROGATORY NO. 35:
22
23
Froni approximately 1955 to 1976, Goodrich Corporation manufactured an asbestos-
24 containing adhesive known.as "R-907-T" and "permate" and placed the adhesives in drums
25 and pails for Lexsuco, Inc. with "Lexsuco" labels. The products were not rebranded per se. 26
Lexsuco, Inc. purchased the adhesives from Goodrich and Goodrich packaged the adhesives 27
28
-10Responses to Gineral Order 129 interrogatories - 2002
I in drum and pails bearing the name "Lexsuco." Lexsuco became part of Goodrich
2 Corporation in 1976.
3 RESPONSE TO INTERROGATORY NO. 36:
4 5 Not applicable.
6 RESPONSE TO INTERROGATORY NO. 37:
7
To the best of defendant's knowledge and believe, no.
8 RESPONSE TO INTERROGATORY NO. 38: 9
Goodrich objects to this interrogatory for the reason that the only products at issue in 10
11. 'this case are those to which plaintiff alleges to have been exposed. To require Goodrich to
12 identify any logo, design, marking or printing for every product it has sold and/or distributed
13 over the years constitutes a request for masses of irrelevant information, is unduly
14 burdensome and beyond the scope of permissible discovery.
15 Notwithstanding this objection, defendant responds as follows: Goodrich's name,
16
17 trade name and/or logo may have appeared on certain asbestos-containing sheet rubber and
18 hose products.
19 RESPONSE TO INTERROGATORY NO, 39:
20 Defendant is unable to fully and completelyrespond to this interrogatory as discovery
21 22 is continuing. However, based upon discovery to date, responding party answers in
23 approximately the 1940's defendant acquired an asbestos containing asphalt floor tile product
24 from Hood Rubber in Watertown, Massachusetts. Additional information is no longer
25 available.
26 RESPONSE TO INTERROGATORY NO. 40:
27
28
No, based upon this defendant's current corporate knowledge.
- II Responses to General Order 129 Interrogatories - 2002
1 RESPONSE TO INTERROGATORY NO. 41:
2
Goodrich Corporation has never manufactured, sold, or distributed raw asbestos
3 material. With respect to asbestos-containing products listing in Exhibit E, various
4
5 documents currently exist but generally consist of catalog listing, advertising, price list, etc.
6 The printing dates vary. See Exhibit E for information concerning location and the
7 custodian of records.
8
In addition, any answer to this interrogatory would require a compilation of
9 10 documents which do not exist. It would not be substantially less expensive for responding
11 party to make this compilation that it would be for the party propounding the interrogatories
12 to do so. Accordingly, the documents responsive to this interrogatory that have been located
13 can be made available at the corporate office of the Goodrich Corporation.
14 RESPONSE TO INTERROGATORY NO. 42:
15 No, based upon this defendant's current corporate knowledge.
16
17 RESPONSE TO INTERROGATORY NO. 43:
18
No. Subparts (A) through (D) are not applicable.
19 RESPONSE TO INTERROGATORY NO. 44:
20 Goodrich has in its Industrial Hygiene Library some publications which suggest a
21 22 relationship between asbestos exposure and asbestos dated in the 1930s. An awareness of a
23 possible relationship between asbestos exposure and the occurrence of mesothelioma and
24 some lung cancers existed in the Industrial Hygiene Department since 1976, but defendants
25 do not know when the awareness may have exited prior to 1976. 26 27 28
.
- 12 -
Response:s to General Order 129 Interrogatories - 2002
1 RESPONSE TO INTERROGATORY NO. 45:
2
Goodrich had in its library publications about the relationship of disease to exposure
3 to asbestos.
4
5 RESPONSE TO INTERROGATORY NO. 46:
6.
See the list of publications from defendant's Industrial Hygiene Library, attached
7 hereto as Exhibit F.
8 RESPONSE TO INTERROGATORY NO. 47:
9 Defendants have been unable to locate any documents regarding when Goodrich
10
11 Corporation first warned its employees that exposure to asbestos could be hazardous to
12 human health, however, it is believed that subsequent to the regulationS issued following the
1.3 institution of OSHA, Goodrich Corporation complied.
14 RESPONSE TO INTERROGATORY NO. 48:
15 Goodrich objects to this interrogatory on the grounds that the information sought is
16 irrelevant in this case and is not reasonably calculated to lead to discovery of admissible
17 evidence_ The plaintiff has never been a Goodrich employee and does not allege ever visiting
18 any Goodrich facility. Notwithstanding this objection, defendant responds as follows: No, .
19 based on this defendant's current corporate knowledge.
20 RESPONSE TO INTERROGATORY NO. 49:
21
22
No, based upon this defendant's current corporate knowledge.
23 RESPONSE TO INTERROGATORY NO. 50:
24
No, based upon this defendant's current corporate knowledge.
25 RESPONSE TO INTERROGATORY NO. 51:
26 .Not applicable.
27.
28
- 13 Responses to General Order 129 Interrogatories - 2002
1 RESPONSE TO INTERROGATORY NO. 52:
2
Not applicable. .
3 RESPONSE TO INTERROGATORY NO. 53:
4
No, based upon this defendant's current corporate knowledge.
5
6 DATED; February 21, 2002
7
ERICKSEN, ARBUTHNOT, KILDUFF, DAY & LINDSTROM, INC.
8
9
10
CHASTINE A. FISH
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 14 Responses to General Order 129 Interrogatories - 2002
VERIFICATION
2 STATE OF OHIO 3 COUNTY OF SUMMIT 4 I hereby certify that I am authorized to respond to Plaintiff's
Interrogatories, on- behalf of Goodrich Corporation, in my 5 capacity as Consultant - Special Projects, and that to the
extent that I am personally familiar with the information set 6 forth in these answers, I certify that the answers are correct,
and to the extent that I am not personally. feral]: with the
7 information provided in the said answers, I ce;,tir that the information is correct to the best of my infrin i and b lief
8 based on my investigation of -se matters
9
10
11 Sworn to.efore me this
da o
, 204
12 IitYPela-,_
13 OTARY
IC
/ MITI1
14
15
MARY J. MILLER, NOTARY PUBLIC
RESIDENCE-WAYWOOUNlY
16
. STATEWIDEJURISDICTION, OHIO
MYCOMMM1ON EXPIRE:SEES.% 2005
17
18
19
20
21
22
23
24
25
26
27
28
1
DECLARATION OF SERVICE BY MAIL
2
3
I the undersigned, hereby declare: .
4
1. I am over the age of 18 years, employed in-the county of Alameda, and not
5 a party to the within action. My business address is 530 Water Street, #720, Oakland,
6 California, 94607.
2. I am readily familiar with our business' practice for collection and
78 processing of documents for mailing with the U.S. Postal Service, and that the below-named
9 document will be deposited with' the U.S. Postal Service with fully prepaid postage thereon
10 on the date set forth below at Oakland, California.
1
3. On the date set forth below I served the within DEFENDANT
12 GOODRICH CORPORATION'S RESPONSES TO GENERAL ORDER NO. 129
13 INTERROGATORIES by placing a true copy thereof in an envelope, sealing, and placing
14 it for collection and mailing following ordinary business practices addressed.as follows:
15
PLEASE SEE ATTACHED LIST
16 17 I declare under penalty of perjury that the foregoing is true and correct. 18 Executed on February 22, 2002 at Oakland, California
wza 19
20
CAROL WEIC10ER
21
22
23
24
25
26
27
28
- 16 Responses to General Order 129 Interrogatories - 2002
Firm Name Berry & Berry Brayton & Purcell Clapper & Patti Hobin & Shingler Kazan, McClain, Edises, et at. Law Office of Bruce Ahnfeldt Law Offices of Christopher E. Grell Paul & Hanley Visse & Yanez Wartnick, Chaber, et al,
Plaintiff Attorney Serrice List
Street Address P.O. Box 16070 222 Rush landing Road 2330 Marinship Way, Ste. 140 1011 A Street 171 - 12th Street, 3rd Floor P.O. Box 6078 360 - 22nd Street, Suite 320 4905 Central Avenue, Ste. 200 1375 Sutter Street, Ste. 120 101 California Street, 22nd Floor
City Oakland Novato Sausalito Antioch Oakland Napa Oakland Richmond San Francisco San Francisco
State Zipcode
CA 94610
CA
94945
CA
94965
CA
94509
CA
94607
CA
94581
CA
94105
CA
94804
CA
94109
CA
94111
Akron Plant - Medical Center -- Full time employees as far as we know.,, unless noted
Dr. Rex H. Wilson
Medical Director SD 6/1/46 - 5/1/74, retired, deceased
Dr. Arnold V. Gold
Medical Director, SD 9/1/66 - 1-1/1/77, retired, deceased
Dr. Richard A. Guyton
Staff VP, Health & Env. Services, SD 1/2/74 - 7/31/88, retired
Dr. Maurice N. Johnson
Director of Toxicology, SD 4/6/72 - 5/31/85, retired (UGTC list), deceased April 1999
Dr. Harold W. Dietz
'Director of Health & Env. Services 10/18/76 - 1991. Retired
Dr.Charles T. Disney
Asst. Dir. of Env. Health, 7/15/74 - 2/17/75, retired, deceased.
Dr. Harold E. May
Dir. of Medical Services (Medical Center) - 6/10/74 1/1/87; retired
Dr. Charles Wintrup
Medical Center Staff Physician, SD 5/22/67 - 2/25/72, terminated, deceased.
Dr. Carolyn McCann
Medical Center Staff Physician,.5/9/77 - 5/31/86 -- term..
Dr. Edson Freeman
Medical Center Staff Physician, 7/10/73 - 12/31/80, term.
Dr. John Spillane
Medical Center Staff Physician, dates of service unknown, deceased.
Dr. D. B. Lowe
'Medical Director 193?-1946, retired 1946, deceased.
Dr. F. R. Stees "
Medical Center Staff Physician, dates of service unknown, approx. 1945 - deceased.
Dr. J. H. Pollock
Medical Center Staff Physician, approx. 1955
Dr. Glenn Hough
Medical Center Staff Physician, dates unknown, status unknown but believed deceased.
Dr. George Donnelly
Medical Center Staff Physician, 4/1/55 - 5/1/62, deceased.
Dr. Ernest H. Planck 11
Medical Center Staff Physician, 4/16/54 - 3/1167, retired, deceased.
EXHiBri
Dr. Harold Reed
Medical Center Staff Physician, 5/3/54 - 3/1/67, retired, deceased.
Dr. I. R. Birnbaum
Medical Center Staff Physician, early 70's,deceased. (fee for service arrangement)
Dr. Zadinsky
Medical Center Staff Physician, early 60's, status unknown but believed to be deceased.
Dr. Ralph W. Jacobs
Medical Center Staff Physician, was around in 1954, status unknown.
Physicians - Akron Plant Dispensary - none were full time, all worked on a fee for services basis. The dispensary was opened July 1980 and closed September 1987.
Robert G. Scacella, MD Private practice, Akron
Samir Abdo, MD
Left Akron area, early 80's.
John A. Pfeiffer, MD
Left Akron area
David L. Yontz, MD
Deceased 10/22/94
Alan Henson, MD.
Orthopedic specialist, current location unknown
Philip Wilcox, MD
Private practice, Akron
Thomas Naumoff, MD
Private practice, Medina
Jerry Tardio, MD
Family Medicine, current location unknown
Radiologists (Akron Medical Center)
Not full time employees, hired on a retainer or fee for service basis.
Thomas Oakley, M.D.in private practice
Richard Hirsch, M.D. on staff of Akron City Hospital
Robert Hamor, M.D. on staff of Akron City Hospital
Carroll Tatum, M.D. 1960's, deceased
Ben F. Suffron, M.D. 1970's, deceased
List of BFG Industrial Hygienists and other environmental personnel
W. E. McCormick
Director of Ind. Hyg. & Tox., SD 1946 -- 1973
George Wilson
Industrial Hygienist, Term. 1968?
Tom Bialke
Industrial Hygienist, Term. 1989
Tom Shepley
Industrial Hygienist, Term. date unknown
Bob Nash
Industrial Hygienist, Term: date unknown
Mark Kennedy
Industrial Hygienist, Term. date unknown
Betty Hodgson
Industrial Hygienist, Term. from UGTC 1985
Bob Modrell
Industrial Hygienist, Retired 1989
Ed Katzenmeyer
Industial Hygienist, Term. from UGTC 1988
John Born
Chemist, Special Assignment in Akron 1971-1974 Retired from Brecksville 1989
John McCool
(title?) Retired UGTC 1982
Charles T. Disney, MD Asst. Dir. Env. Health, 1974-1975 (deceased)
Richard G. Carter
Industrial Hygienist, late 60's
Ronald Callender
Industrial Hygienist, late 60's
NAME OF DEPONENT Jerry A. Smith
Jerry A. Smith
Dohrman Wells
Keith Banke
Jerry A. Smith
Marilyn Petroski
Jerry A. Smith
fer7 A. Smith
Jerry A. Smith
Jerry A. Smith
TESTIMONY OF GOODRICH EMPLOYEES
CASE NAME The Mayor and City Council of Baltimore v. Keene Co . Hartford Fire Insurance Co. v. Westinghouse Electric Corp. City of Baltimore v. BFGoodrich Co. City of Baltimore v. BFGoodrich Co. City of Baltimore v. BFGoodrich Co. City of Baltimore v. BFGoodrich Co. Mike Norman v. A-C Product Liability Trust Mon Mass II
Goldberg Groups 5, 6 & 7
Rickey A. Lanier v. Eastern Refractories Com any, Inc.
COURT Circuit Court Baltimore C. , MD District Court Hennepin County, MN Circuit Court Baltimore City, MD , Circuit Court Baltimore City, MD Circuit Court Baltimore City, MD Circuit Court Baltimore Cit , MD Circuit Court Wayne County, MI Circuit Court Monon_galia County, WI Court of Common Pleas Cuyahoga County, OH Superior Court Middlesex. County, MA
DOCKET NO. 84268068/CL25639
87-14006
84268068 CL25639 84268068 CL25639 84268068 CL25639 84268068 CL25639 94421061NP
.
286145-014
00-0066
0 ..t DATE OF TESTIMONY 4/27/93
5/13/93
9/21/93
9/21/93
6/7193
9/21/93 ,
12/20/95
6/17/97
5/10/99
3/21/01
F=atA
le 1!
am:=IIRI
= >< Udal
,
Revised 7/9/2001
INSURANCE INDEX
10/29/93
POLICY PERIOD
POLICY
INSURER
FROM
TO NUMBER-
TYPE
LAYER EXCESS OF:
a= a a c aa=a a == a a =a ssa a a a a. a a c a a a s at a a a z a a a la a Ma a la a la a a a a.. a 1= a [1: a a= = = r n 1= a a al as = =
BFGoodricli Policies up to $20M
AMERICAN MOTORISTS INSURANCE CO.
1/1/44'
1/1/63 'Unknown
CGL
1,000,000
1,000,000
LLOYDS
1/1/55
11/6/56 'Unknown
UMB
50,000 (PI
50,000
LLOYDS
1/1/55
11/6/58 Unknown
UMB
1,000,000 (GL
1,000,000
LLOYDS
1/1/55
11/6166 "U45508
XS
1,000,000 (GL(
1,000,000
LLOYDS
1/1/55
11/6156 *U45508
XS
- 500;000 (PD)
500,000
50,000
LLOYDS
1/1/55
11/6/56 'U45558
XS
450,000 (PD)
450,000
559,000
LLOYDS
1/1/55
11/6156 'U50514
XS
1,000,009
1,000,000
2,000,000
LLOYDS LLOYDS
11/6/56 1116/56
1/1/60 1/1/60
*UnknoWn 'U62302
UMB XS
100.000 500,000
100,000 500,000
1,000.000 600,000
LLOYDS
11/6156
1/1/60 41.162354
XS
400,000
400.000
1,000,000
LLOYDS
11/6/56
1/1/60 'U62353
XS
1,000,009
1,000,000
'1,000,000
LOYOS
1/1/60
1/1/63 U70656
UMB
100,000
100,000
1,000,000
LLOYDS
1/1/60
1/1/63 *U75658
XS
500,00b
500,000
600,000
LLOYDS
111/60
1/1/63 'U78657
XS
400,0110
400,000
1,000,000
LLOYDS
I/1/60
1/1/63 U78660
XS
1,000,000
1,000,000
1,000,000
EMPLOYERS REINSURANCE CORP.
1/1/60
10/13/61 PLE 128
XS
EMPLOYERS.RE INSURANCE CORP.
10/3/61
1/1/63 PIE-128
XS
1,000,000 2 ,000,000
1,000,000 2,000,000
2,000,000 2,000,000
GENERAL REINSURANCE CORP,
8/8/62
1/1/63 'Unknown
XS
2,000.0b13
2,000,000
4,000,000
EMPLOYERS REINSURANCE CORP.
8/8/62
1/1/63 PLE224
XS
4,000,000
4,000,000
6,000,000
AMERICAN MOTORISTS INSURANCE CO.
1/1/63
1/1164 3YM 113 800
CGL/UM
11,000,000
11,000,000
AMERICAN MOTORISTS INSURANCE CO.
1/1/64
1/1/69 3YM 113 800
CGL/UM
20,000,000
20,000,000
AMERICAN MOTORISTS INSURANCE CO.
1/1/69
11/12n5 9YM 113 800,
COL/UM
20,000.000
20,000,000
AMERICAN BANKERS INS.CO. OF FLA.
11/12/75
1/1/77 XL 345 1150
UMB
500,000
5,000,000
SIR
LONDON
11112/75
111177 614 NC 1050
UMW
3,000,000
5,000,000
SIR
STONEWALL INSURANCE CO.
11/12/75
1/1/77 35000443
LIMB
1,500,000
5,000,000
SIR
INSURANCE CO. STATE OF PA.
11/12/75
1/1(77 4176.6735
XS
1,000,000
14,000,000
5,000,000
LONDON
11/12/75
1/1/77 614 NC 1051
XS
1,890,060
14,000,000
5,000.000
NORTIIBROOK INSURANCE CO.
11/12/75
1/1/77 63 001 415
XS
4,500,000
14,000,000
5,000,000
STONEWALL INSURANCE CO.
11/12/75
1/1/79 35000444
XS
3,000,000
14,000,000
5,000,000
AMERICAN REINSURANCE CO.
11112/75
111177 M1029862
XS
3,610,000
14,000,000
5,000,000
1.S.L.I.C.
1/1177
1/1/78 GP 2217
UMB
250,000
5,000,000
' SIR
SEGUROS LA REPUBLICA SA
1/1177
1/1/78 XL01-0031
UMB
1,000,000
5,000,000
SIR
>s< LONDON
rn DRAKE INS. CO. OF NEW YORK INSURANCE CO. STATE OF PA. LONDON
1/1/77 111177 111/77 1/1/77.
1/1/79 10/1/77
1(1/79 1/1179
614 NC 1050 XL 01521 4176.6735 614 NC 2917
1/M8 )(S XS )(S
3,750,000 450.000
2,100.000 2.800,000
5,000,000 14.000,000 14,000,000 14,000,000
SIR 5,000,006 5,000,000 5,000,000
NORTFIBROOK INSURANCE CO.
1/1/77
1/1/79 63 001 415
XS
5,040,000
14,000,000
5,000,000
amccacm
LONDON I.S.L.I.C.
10/1177 1/1/78
1/1/78' "Unknown 1/1/79 GP 2662
XS UMB
450.000 250,000
14,000,000 5,000,000
5.000,000 SIR
AVRECO/SEGURUS LA REPUBLICA
1/1/78
6/1/78 XL 01.0121
UMB
1,000,000
5,000,000
SIR
LONDON
1/1/78
1/1/79 614 NC 1051
XS
3.250,000
14,000,000
5,000,000
HIGHLANDS INSURANCE CO.
1/1/78
1/1179 SRNO 40321
XS
3,610,000
14.000,000
5,000,000
AMERICAN CENTENNIAL
6/1/78
I/1/79 X000-00.17
UMB
1,000.000
5,000.000
sin
AMERICAN CENTENNIAL
1/1/79
711/79 XC000046
UMB
1,250.000
5,000,000
SIR
1/1/79
.711/79 GP 50003
LAO
250,000
6,000,000
SIR
LONDON
111/79
7/1/79 614 NC 6524
UMB
3,500,000
5,000,000
SIR
LONDON
1/1/79
711/80 614 NC 6525
)(S
10.900,000
15,000,000
5,000,000
TRAN SIT CASUALTY CO.
:1/1/79
7/1/79 SCU 955-032
XS
2,000,000
15,000,000
5,000,000
INSURANCE INDEX 10/29/93
INSURER
=
=
GRANITE STATE INSURANCE CO, LONDON
LS.L.I.C. TRANSIT CASUALTY CO. GRANITE STATE INSURANCE CO. 1.5.1,1.C. LONDON TRANSIT CASUALTY CO, GRANITE STATE INSURANCE CO, 1.5.1.1.C. LONDON LONDON LONDON
LONDON LONDON
EPU1311C INSURANCE CO, LONDON SELF-INSURED WEAVERS ASS1CURA ZION! SELF-INSURED WEAVERS NY INS EXCHANGE SELF-INSURED WEAVERS IIE IIE WEAVERS ASS1CURAZIONI HE WEAVERS TUREGUM WEAVERS WEAVERS GENERAL! IIE TUREGUM
WEAVERS WEAVERS TUREGUM WEAVERS ZURICH RE ANGLO AMERICAN LLOYDS ZURICH RE VARIOUS ZURICH RE & ANGLO AMERICAN ALLIANZ
POLICY PERIOD
POLICY
FROM
=
TO
= =
NUMBER
TYPE
LIMIT
LAYER
= = a= ..,===== a ====a== = =
1/1/79
711179 6679-1020
XS
2,100,000
75,000,000
7/1/79
7/1/81 . 614 NC 6524
UMB
4,750,000
5,000,000
7/1/79
7(1180 GP 50351
UMB
250,000
5,000,000
7/1/79
7/1/80 SCU 955.237
XS
2,000,000
15,000.000
7/1179 7/1180
7/1/80 - 6679.1323 7/1/81 GP 51318
XS UMB
2,100,000. 250,000
15,000,000 5,000,000
711/80
7/1101 614 NTA 158
XS
10,900,000
15,000,000
7/1/80
7/1/81 SCU 955 237
XS
7/1/80
7/1/81 6680-2329
XS
2,000,000 2,100,000
15,000,000 15,000,000
7/1/81
7/1183 GP52768
UMB
500,000
5,000,000
711/81
7/1/83 6)4 NTA 570
UMB
4,500,000
5.000,000
7/1/81
7/1/84 614 NTA 571
XS
15.000,000
15,000,000
711183
8/1/86 614 NTB 380
UMB
4,500,000
5,000,000
7/1/83
7/1/85 GP 562 86
UMB
500,000
5,000,000
7/1/93
7/1/85 614 141-11 381
XS
15,000,000
15,000,000
7/1/85
8/1/86 . 614 NTB 380
LIMB
4,100,000
5,000,000
7/1/05
8/1/86 COLI-18248
UMB
900,000
5,000,000
7/1/85
8/1/86 614 NTT) 381
XS
9,525,000
15,000,000
81118 6
8/1/87 N/A
LIMB
875,000
5,000,000
8/1/86
8/1/87 61414T0 418
UMB
4,125,000
5,000,000
8/1/86
811187 614 NTT) 419
XS
125,000
5,000,000
811/86
8/1/87 N/A
XS
8/1186
8/1/87 614 NTI) 419
XS
8/1/06
8/1/87 S6585/86
XS
875,000 2,000,000
250,000
5,000,000 5,000,000 10,000,000
8/1/86
8/1/87 N/A
XS
3,750,000
10,000,000
8/1/86
8/1/87 614 NTD 420
XS
4,000,000
10,000,000
8/28/86
8(1/87 001-06980
XS
8/28/86
8(1/87 001-06979
XS
2,000,000 2.000,000
5,000,000 10.000,000
8/1/87 8/1/87
811/88 8/1/88
977/7GA2012 977/70A2014
UMB XS
5,000,000 250,000
5.000,000 5,000,000
8/1/87 8/1/87
8/1/88 001.104115
XS
8/1/88 977/7GA2013
XS
375,000 4,375,000
5,000,000 5,000,000
8/1/87
8/1(88 977/70A2015
XS .
1%250,000
-10,000,000.
811/87
811188 977/7GA2013
XS
8,750,003
10,000,000.
email
8/1/89 977/8GA2002
UMB
5,000,000
5,000,000
8/1188
8/1/89 977/8042004
XS
250,000
15,000,000
8/1/88
8/1/89 1301-120540
XS
375,000
15,000,000
8/1/88
8/1/89 977/8042005
XS
1,250,000
15,000,000
8/1/88 8/1/89
8/1/89 977(86A2003 8/1/90 - 977/96A200.3
XS UMB
13,125,000 5,000,000
15,000,000 6,000,000
8/1/89
8/1/90 *90A2004
XS
1,875,000
15,000,000
811/89
8/1/90 977/96A2004
XS
13,125,000
15,000,000
811190 8/1/90 8/1/90
8/1/91 8/1/91 8/1/91
977/06A2006
LIMB LIMB XS
3,865,000. 1,135,000
850,000
5,000,000 5,000,000 17,000,000
8/1/90
8/1/91 977/010A2007
XS
6,630,000
17,000,000
8/1/90
8/1191
XS
9,520,000
17,000,000
. 8/1/91
8/1/92 977/91M1073
UMB
22,000,000
22,000,000
8/1192
8/1/93
UMB
4,400,000
22,000,0D0
EXCESS OF: a = = it=
5,000,000 SIR SIR
5,000,000 5,000,000
"SIR 5,000,000 5,000,000 5,000,000
SIR SIR 5,000,000 SIR SIR 5,000,000 SIR SIR 5,000,000 SIR SIR 5,000,000 5,000,000 5,000,000 10,000,000 10,000,000 10,000,000 5,000,000 10,000,000 S1R 6,000,000 5,000,000 5,000,000 10,000,000 10,000,000 SIR 5,000.000 5,000,000 5,000,000 5,000,000 SIR 5,000,000 5,000,000 SIR SIFT 5,000,000 5,000.000 5,000,000 SIR SIR
INDEX
INSURER is s 4 .= b a St zuniCH RE
POLICY PERIOD
POLICY
FROM
TO NUMBER
TYPE
LIMIT
LAYER EXCESS OF:
= = = = Mau. a a a a= a Se C a slca C at Si aaa a ma= a a a a a a al a a n SI =a a a ter C m A Ca 4 a a MCC.
8/1192
8/1/93 92M0777
LIMB
17,600,000 22,000,000
SIR
3
BFGoadrich
OM Guidelines Document Control Nurnb41:-. Authorized by/date.
0KP-001.3.10 Effective 9/1/95
Page 1 of 6
7BFGoiidrichZt-.!.:147i4-47.17:t454..- it
''AtCiptirgut -..1%;f1:7553$-17.1
OCCUPATIONAL HEALTH EXAMINATION PROGRAM
0 C 'CUt:CTIONAL EXI"btiRg7.0.:ASB ESTOS
Overview
In the United States, the Occupational Safety and Health Administration (OSHA) requires that employees who are exposed to asbestos, tremolite, anthophyllite, actinolite or a combination of these must participate in annual medical surveillance examinations (29 CFR 1910.1001 and CFR 1926.1101) if they experience any of the following exposure situations:
exposed at or above the permissable exposure limits (PEL's) of 0.1 fiber
per cubic centimeter as art 8-hour time-weighted-average (TWA) or the
excursion limit (EL) of I fiber per cubic centimeter averaged over 30
minutes, for a combined 30 days or more per year;
are involved in Class I, II or 111 asbestos work for a combined N days or
more a year. (Note -.days involving 1 hour or less in total of Class II
and/or Class In work performed using the work practices specified in the
OSHA standard, are not to be counted.)
This applies without regard to the employee's use of personal protective equipment. While it is unlikely that any BFGoodrich employee will be exposed to asbestos in excess of the PEL or EL, many employees are involved in Class I, II or III tasks including changing asbestos gaskets or transite removal or maintenance job's involving incidental disturbance of installed asbestos products.
Purpose
This program is intended to:
Insure the effectiveness of work practices And use of personal protective equipment to minimize employee exposure to asbestos arid prevent asbestos-related health effects,
Insure that employees may safely userespiratory protective equipment as required by their job (see Section 1.2.3 - Medical Clearance for Respirator Use),
Identify employees with other medical problems or health risks so that
., they may be referred for appropriate evaluation. HIBIT
BFCrood ricb OHP Cuktelioe Document Control Number:
011P-0013.10 Effective 9/1195 Page 2 or g
Participation - Content
Facility health and safety personnel must determine which employees will be included in the asbestos medical program. This determination may require performance of industrial hygiene sampling to dqcument representative air levels; however, for work around installed buildings materials, the requirements are based on the nature of the work regardless of exposure level. AU employees whose work involves potential exposure to asbestos must be medically cleared for respirator use. The asbestos and respirator examinations must be conducted prior to placement in a job with potential exposure to asbestos. Employees are not to be issued respirators, at tested or -trained for respirator use until they have been medically cleared.
Asbestos medical surveillance and respirator clearance require the following:
Review of respirator use requirements;
Review of pertinent medical and work history with special emphasis on
the pulmonary, cardiovascular and gastrointestinal systems;
Pulmonary function test to include FEVI, FEV,iFVC. %of predicted
FEV, and % of predicted FVC;
Physical examination with special emphasis:on pulmonary and gastrointestinal systera,
Chest x-ray.
Chest x-rays must be performed at the time of initial placement and then at five and ten years after placement For employees why have more then ten years since their first exposure, chest x-rays must be performed on the following age-adjusted basis:
Age 15 - 35 Age 36 45 Age over 46
every 5 years every 2 years annually
All chest x-rays must be interpreted by a certified B-reader, or a board certified or eligible radiologist or other physician with known expertise in the pneumoconioses (dust-related diseases of the lung). The results must be recorded on the ILO B-reader form (Form CSD./1410SH M 2.3).
BFGoodrich OH:P Guideline Document Control Number:
OHP-001-3.10 Effective 911195 Page 3 of 6
Procedure
Evaluation a
Health Effects
Each location - must identify a local physician to conduct the examinations. Medical surveillance for asbestos exposure under the OSHA standards requires the use of the mandatory medical questionnaire (Appendix ID) attached at the end of this guideline.
The physician should be provided with- the following:
A copy of this guideline;
The OSHA Asbestos Standards, including appendices D, E and I of
29CFRI926.1101;
Representative exposure levels:
A description of job duties and use of protective equipment;
Results of past examinations.
The examining physician will evaluate overall employee health and fitness, concentrating on any problems which may be relaxed to the workplace exposure to asbestos and the employee's ability to perform his or her job safely. The
physician will also determine whether the employee is capable of wearing a respirator, as necessary (see Section 1.2.3 - Medical Clearance for Respirator Use).
Acute effects related to asbestos inhalation are minimal and similar to that of nuisance dusts. Three chronic medical conditions have been associated with exposure to high levels of asbestos fibers. These rarely become evident until 10 years from first exposure. They are:
Pleural
Pleural changes are the most common finding in asbestos-exposed workers. These may occur on any pleural surface. These are usually evident on plain x-rays, although oblique films or CT scanning may better document the presence or absence of true pleural changes. Pleural asbestosis is usually asymptomatic and uncomplicated. Pleural asbestosis only rarely causes pleural effusion, and this finding should prompt an evaluation for possible pleural mesothelioma. In general, the presence of pleural findings supports a history of significant past
asbestos exposure.
BFfiroodrich OKP Guideline Document Control Number:
OKP-0013.10 Effective e11195
Page a or 6
Evaluation of Wealth Effects . (coned)
Interstitial
Interstitial pulmonary fibrosis or pulmonary asbestosis, is a much more serious development. Chest x-ray findings include irregular opacities which are predominately in the lower lobes. The physical examination may reveal coarse rales in the lung bases. Pulmonary function usually shows restrictive impairment (decreased vital capacity) and impaired diffusion. Obstructive changes may also occur, although this is usually confined to smokers.
IVIesothelloma
Mesothelioma is a malignant tumor of the pleural or peritoneal cavity which has been particularly associated with exposure to amphibole asbestos (crocidolite, amosite). This may be confused with poorly differentiated adenocarcinoma, particularly when arising in the abdominal cavity. Proper diagnosis may require review of the tissue specimens by an experienced pathologist.
Lung Cancer
An excess incidence of lung cancer has also been reported in epiderniologic studies of asbestos workers. This excess has primarily been associated with the combination of asbestos exposure and cigarette smoking. The extent to which asbestos exposure alone is a significant risk factor for developing lung cancer remains uncertain.
Other Cancer
Several other types of cancer have been considered as possibly being related to asbestos exposure. These include gastrointestinal cancers and kidney cancer. Findings from limited studies in these areas have been inconsistent.
Interpretation of Results
The interpretation of the significance of any given finding in an individual with exposure to asbestos requires careful consideration of the following:
The significance of the finding,
Tyre intensity of the exposure,
Other possible causes of the finding ,
Latency between exposure and effect
BFGoodrieh Guicielite
Document Control Number:
OHP-001-3.10 Effective 9/1/95 Page S of 6
Interpretation of Results (cont14)
Separation! Retirement Management
Written Opinion
Proper diagnosis requires a thoughtful history, careful examination and appropriate testing. The determination of whether an individual has developed asbestosrelated health effects requires.a clear understanding. of the pathophysiology of asbestos-related disease.
All persons who are diagnosed as having possible asbestos-related disease should be evaluated by an experienced occupational or pulmonary physician. Part of this evaluation should include a review of the work and exposure history_ to determine the factors which contributed to disease development. Individuals who properly follow current recommended work practices should not develop any asbestosrelated findings.
Any employee who was exposed to asbestos at or above the PEL and/or EL is to be provided a complete physical examination 31) days before or after the last day worked. This examination is to be provided regardless of time since last exposure. If the employee has been examined according to this guideline within the prior 12 months, no medical examination is required.
Persons who are diagnosed as having developed asbestos-related health effects must be advised of the finding and its significance. Simple pleural plaques, require no specific treatment and should result in no symptoms or disability. In contrast, pulmonary asbestosis may result in significant respiratory impairment. Both mesothelioma and lung cancer can be fatal. Fitrther evaluation and treatment must be managed on a case by case basis. Appropriate BFGoodrich occupational health resources should be consulted in all cases of possible asbestos-related diSease.
Experts in the field differ on the issue of whether individuals with asbestos-related
fuldings duet past exposures should be allowed to continue to work in. potential
exposure areas using protective equipment. If proper procedures are followed,
additional exposure and health risk should be
Ultimately, the
determination MUST be made on a case by case basis,. considering the health of the
effected individual, the risk of exposure and the nature of the work.
The examining physician must supply the facility with a written opinion on the folloWing for each employee:
Whether any medical condition is present whiCh presents an increased risk
of material health impairment due to exposure to asbestos;
Whether there are limitations on employee exposure or use of respirators
and other protective equipment;
ISFGoo.trich offp Goidetine Document Control Number:
OR?-0013.10 Effective 9/1195
Page 6 of 6
Written Opinion
(coned)
Confidentiality
A statement indicating that the employee has been informed of the results
of the cumi'nation and of any medical conditions which may result from
exposure to asbestosv
A statement that the employee has been infOrmed by the physician of the
increased risk of lung cancer attributable to the combined effect of
smoking and asbestos exposure.
A copy of the physician's written opinion shall be provided to the affected employee within 15 days of receipt by the employer.
The employee should sign a statement indicating that they have been informed of all the results of the examination.
The results of the examination that are not directly related to the employee's health
and safety in the work environment are confidential. These findings must not be
communicated or released to any individual without the employee's written
consent
ASBESTOS CONTAINING PRODUCTS MANUFACTURED BY THE BF GOODRICH COMPANY (Rev. 11-2-00)
PRODUCT NAME & WHERE mmermerumo
'
DATE PRODUCT' DATE PRODUCT
FIRST PLACED - CEASED TO RE
ON httwarr
PRODUCED
Furnace Door Lion
(Akron, OH & . Marion, OH)
Approx. 1955
Approx. 1979 -
Pyratock . Rocket ' 1952 Insulation (Akron, OH)
1974.1975
Sheet Rubber (Masao, OM
Early 1900's
Aspitak Floor Tile (Waterlwoa, MA)
Approx. 1945
icor nal Vinyl Asbestos Floor Tile (Worertowo, PAA)
Approx. 1950
Gaskets
1959
(Salem,IN) ..
Brake Tubes
1963
(Akron & Troy, OH)
Approx. 1960
Early 19601
1963
Lally 1970's 1970
DESCR1P. OF
ctrewica.
COMPOSITION
EPDM Rubber w/Asbestos & Wire
DESCRIP. OF PHYSICAL . APPEARANCE OF PRODUCT
Wire Coveted Hose
Mixture of waterglass, clay, high carbon tubber and ehrysotilo asbestos (less than 9%)
Neoprene Efrain, Rubber Asbestos
Brown or gray pests Robber Sheers/Rolls
Aspbott, Asbestos & Color, Chrysolite (SS, Unknown)
Vinyl, Clay, Asbestos, Color. Plasticizer, Chrysorile (% Unknowo)
Unknown
9'x51' & 12'5(12' Floor Tiles
rx9 & 12'x12 Floor:files
Gasket Strip
Rubber Tube w/Aobestoa Cover
Rubber Tube
DESCRIPTION OF WAS PRODUCT
INTENDED USE
' ON US GOVT.
QUAL/FTE.D PROD,
LIST
Water cooled doors on . Unknown
steel mills
SUPPLIER OF RAW ASBESTOS
0
MISCELLANEOUS INFORMATION
Unknown
Industrial Nose bUS41e32 sold to ERR Iltarentid - 1986
Line and institute
Yes
rook& etweeessings
Johns-Manville 'Thetford Mines
.
Purchased by Navy ander M1L-C-Z2608. Made by Adhesives Div.
Gasket Materials & Sheet Packing
Floor Covering
Unknown
. Unknown
Floor Covering
Carskett for Dishwasher Doors
Alreraft & Of. Highway Vehicle Brakes
Unknown
Unknown .
Yes
Unauown
Rttb MO TiattrOtd Num JohnsManville Ruberael TIrstistel Mines, JohnsManville
Unknonvo
See Note /12
Product genetally sold east of Mississippi River
Precinct generally sold east of IvIlssissippi River
.
RECORDS AVATLABLE CUSTODIAN
Few catalog references/Custodian See note I.
See Note 1
I t
Few ostalog references/Cnstodlan -See note 1.
Advettlect& Ischeleal tnanwals, CustodianSee note 1.
Advertising, teehnical manuals. CustodianSeeNew I.
Unknown
Unknown
Alteraft Brake Issas Mid 1940's
1985
(Tray. orri
Unkbovm
BrnIce Assembly
Aircraft Brake
Yes
Assembly
'
See Note 02
Unknown
PRODUCT NAME & WHERE
MANUFACTURED-
DATE PRODUCT FIRST PLACED ON MARKET
011-1111gbovy Brake Parts (Troy and Akron; OH)
Rodger Insulation (Akron, OH)
Late 1950's
1960
DATE PRODUCT CEASED TO BE " . PRODUCED
.
1985
DESCR1P. OF CHEMICAL COMPOSITION
Unknown
1985
Unknown
149W54
AutomobiltILIgtit
1930
1985
Unknown
Truck Brakes '
(Mfg. Lot. N/A)
DWA 14 (Akron, 011)
PL111-A (Akron, CM)
Pl...717-13 (Akron, OW
PL129-3 (Akron, OH)
PL-706 (Akron, OH) R-907-T (Akron, Oil)
1968
1969 .
1969 .
1974
1972 1955
1975
1985
1985
1985 . 1985 1985
Rubber Resin, Inorganic Filkr, anyeatile 20%
Epoxy Resin, atonable < 5% (Caddo)
Epoxy Film. anyeatik < I% (Calk's%)
. Epoxy Frdm, Cluysotile < 2% . (Calithin)
Spry Film, Chrmlile 15%
Rubber. Aspbeil, Inorganic Filler, Cottle 6%
DESCR1P. OF . PHYSICAL APPEARANCE OF PRODUCT
Brake Assembly -
DESCRIPTION OF INTENDED USE
Off-Highway Vehicle Brake Assemblies
WAS PRODUCT ' ON US GOVT. QUALIFIED PROD. LIST
Unknown
SUPPLIER OF RAW ASBESTOS
Sec Note 42
Unknown
Replacement Brake Assembly .
Used as laudation in Phoenix Rockets
Auto & Truck Brakes
Yea
Unknown
Unknown
See Nolen
Thick Adhesive
Drywall Adhesiva
No
Amber Film La Creninfran Film
Bonding Aircraft Parts
. Bonding Material , (Aiteren)
Unknown Unknown
Carey & Johns' Manville
KCAC, Sec Note 84
KCAC
Beige Film
Aluminum C.otored Film Black Adhosin
Bonding Aircraft Pests -
Bonding Aircraft Parts
Unknown Unknown
Ron f Vapor Barrio:
No
Adhesive
KCAC
-
Carey & lameManville
Carey & loisManville
MISCELLANEOUS INFORMATION
RECORDS AVAILABLE CUSTODIAN
BEG told business to Carlisle Braking Sys, Bloomington, IN 1990
Unknown Unknown
Tire Center business snide* Tire Centers,
Inc -1985. Now owned by Michelin
None (IYIlchellnI) 1 i
Adhesive Systems (See Note 5)
Adhesive Systems (Sec Note 5)
Adhesive Systems (See Nate 5)
. Adhesive Systems (See Note 5)
Adhesive Systems (See Note 5)
Adhesive Systems (See Note 5)
2
PRODUCT NAME & WHERE MANUFACTURED
,
DATE PRODUCT FIRST PLACED ON MARKET
Permute
1955
(Akron, OH)
PL-200 (Akron, OH)
PL-400 (Akron, OH)
1964
, 1966
R-1106-T (Akron, OR)
. DA-100 (Akron, OH)
1971
. 1962
A-14044
1979
(Akron, OH)
PL.731
1976
(Akron, OH)
PL-41011-6 (Akron, OH)
DSA 100
(Akron, OH)
1968
'
Unknown
DATE PRODUCT . CEASED TO BE PRODUCED 1985
1910
1980
1980
1965'
1983
1989
'
1992 Unknown
DLSCRIP. OF CHEMICAL COMPOSITION
Rubber. Asphalt, Inorganic Filter, Chryantfte 6%
Rubber, Resin, Inorganic Filler. Chrysotile 21%
Rubber, Resin, inorganic Filler, Chrysottle 19%
Reclaimed Rubber, Resin, Filter & Solvent, Chrysotile 6%
Rubber, Resin. Filer, Solvent, Ctuysotile 20%
Vinyl, Solvent, Filler, auysotile 294 (Calidria)
Aluminum Filled ElselrY TEM Cluysotile < I% (Ceftrbia)
Amino Piller], Oil, Chrysotile < 5%
Resin, Rubber, Filler
Solvent, Myst:dile
20%
DUCAR. 01' PHYSICAL APPEARANCE OF PRODUCT Bieck Adhesive
Black Adhesive
Grey Adhesive
Grey Maack
Ellaek Mae*
White Putty
Amber Pine
Thick Cream Black Mastic
DESCRIPTION OF
INTENDED USE
Roof Vapor Denier Adhesive
WAS PRODUCT
ON US GOVT.
QUALIFIED PROD. LIST ,
No
. SUPPLIER OF RAW ASBESTOS
Carey & JohnsManville
heel Adhesive
No
Carey & Johns-
Manville
Sub Floor Adhesive
No
Carey & JohnsManville
Temporary Branding of Cattle
Searching
Carey & JohnsManville
Drywall Adhesive
No
Vinyl Window Putty No
Carey & JohnsManville
KCAC
Bonding Aircraft Parts No
KCAC
Urethane Sealant
Yes
Drywall Adhesive
No
Itihns4ituwitic
Carey &Johns. Manville
MISCELLANEOUS , INFORMATION
RECORDS
.
AVAILABLE -
CUSTODIAN
Adhesive Systems (See Note 5)
Adhesive Systems
(See Note 5)
Adhesive System (See Note 5)
Adhesive Systems (See Note 5)
Adhesive Systems (See Note 5)
Adhesive Systems
(See Note 5)
Adhesive Systems . ' (See Note 5)
Adhesive Systems (See Note 5)
Adhesive Systems (See Note 5)
3
PRODUCT NAME & WHERE MANUFACTURED
DATE PRODUCT FIRST PLACED ON MARKET
DSA 300 (Alu-on:001)
Unknown
DATE PRODUCT, CEASED TO BE PRODUCED
Unknown
DESCRIP. or CHEMICAL comrosmoN
Rubber Raja, Inorganic Filler, Cbrysetile 25%
.
DESCRIP. OF PHYSICAL APPEARANCE OF . PRODUCT
Black Adhesive
DESCRIPTION OF INTENDED USE
Dry Wail Adhesive
Neter 1.
2. 3. 4. 5.
Custodian is The BPGoodrieb Company, 4 Coliseum Centre, 2730 W. Tyvala Rdad, Charlotte, NC 28217. Manufactured asbestos component parts were purchased from suppliers and used in brake assemblies maaufactured by BPOoodriels. BECroodrich purchased entire *aka assembly and simply installed u auto serviced:MGM.
KCAC address is PO Box K, Cattlemen Road, Ring City, California 93930.
Business sold to Sovereign Engineered Asibersivas; L.L.C. --34146 (sow SIA. Adhesives), 123 Bastges St, Akron, OH 44311.
WAS PRODUCT ON US GOVT. QUALIFIED PROD. LIST
No
. SUPPLIER OF RAW ASBESTOS
Casty & Johns. Manville
MISCELLANEOUS INFORMATION
RECORDS AVAILABLE CUSTODIAN
Adhesive Systems (See Nom 5)
4
Publications subscribed to by Health and Environmental Services with dates where known. 1. American Ind. Hygiene Association Journal
1946 through 1991.
2. Archive& of Environmental Health 1961 through 1982.
3. Archives of Industrial Hygiene & Occupational Medicine 1950 through 1960. Note that name was changed to #2 above in 1961.
4. British Journal of Industrial Medicine 1972 through 1993.
5. Cancer Journal 6. Environment Midwest
7. Environmental Research 1974 through 1980.
8. Environmental Science and Technology
9. Health and Safety 10. Industrial Medicine (1935) and Surgery (1950)
11. Job Safety and Health
12. Journal of Air Pollution Control Association
13. Journal of American Medical Association Kept on current year basis.
14. Journal of ccupational Medicine 1959 (Ongoing).
15. National Safety News
16. Occupational Hazards 17. Ohio State Medical Journal 18. Pollution Engineering 19. Preventive Medicine
E HI IT
20. Today's Health
21, Toxicology. and Applied Pharmaecolo gy 1959 (ongoing).
22. Water and Pollution Control
23. NIOSH Technical Information 1972 (ongoing).
24. NIOSH Criteria For a Recommended Standard 1972 (ongoing).
25. Occupational Safety and Health Reporter 1972 (ongoing).
26. American Industrial Hygiene Association: Hygienic Guidelines
NOTE:
(Rev. 7-22-99)
Per M. B. Butterfield, she shows we started
Subscribing at least as far back as 1958.
27. NIOSH Manual of Analytical Methods 1972 (ongoing).
28. AMA Analytical Abstracts
29. EPA Analytical Quality Control
30. MCA -- Chemical Safety Data Sheets
31. OSHA - Standards
32. OSHA -'Reporter
33. OSHA -.Letter
34. Environmental Health Perspective 1973 (ongoing).
35. Journal of Toxicology and Environmental Health 1976 through 1977 1983 (ongoing).