Document Yr6LBKDp3gqp80exepkwaamqN

FILE NAME: Hampshire (HAMP) DATE: 1993 Aug 24 DOC#: HAMP139 DOCUMENT DESCRIPTION: Legal - Hampshire's Answers to Master Interrogatories (A) program; The manner of communicating with employees about such (B) Whether examination was optional or mandatory and, if the latter, how frequently such examination was required; (C) What percentage of employees permitted to undergo such examination actually participated; (D) What percentage of employees who underwent such medical examination were found to have pneumoconiosis, asbestosis, mesothelioma, lung cancer or other cancers; and (E) With respect to the employees referred to in your Answer to Part (D) of this Interrogatory, what percentage of these employees were paid disability, and/or worker's compensation benefits and for what percentage of employees were medical expenses paid for purposes of treatment of such condition. ANSWER TO INTERROGATORY NO. 3 1 : None. INTERROGATORY NO. 3 2 : State whether you or anyone on your behalf ever conducted, ' engaged in or participated in any tests, studies and/or research j concerning the human health consequences of persons coming in contact with and/or inhaling asbestos fibers or asbestos dust during the manufacture and/or use of asbestos products. identify; If so, j i (A) What tests, studies and/or research were done; j j- (B) When said tests, studies and/or research were done: ; I i I ; (C) The individuals who ordered and supervised the tests, i;studies and/or research; (D) The individuals or groups engaged in or participating in | the tests, studies and/or research; l a w o f f ic e s rHOMAs.libowitz pa professional association F IF T H FLO O R (E) The substance of any recommendations and/or suggestions ;igiven as a result of the tests, studies or research. State when, : by whom and to whom said recommendations were made, including the j addresses of these individuals; OO N CHARLES STREET B ALTIM O R E. M A R Y LA N D 21201-4305 j: (F) All written documents including, but not limited to, |;reports, memoranda, specifications and correspondence which refer, relate or pertain to said tests, studies and/or research; and 20 PLAINTIFFS EXHIBIT MWP-IHO  gnJS- Y / Z j f o (G) The present custodian of the written documents identified ::in your Answer to Part (F) of this Interrogatory. IANSWER TO j ! No. INTERROGATORY WO. 321 INTERROGATORY NO. 3 3 t State whether any of the medical directors, industrial hygienists, physicians, biological scientists or consultants in these fields identified in your Answer to Interrogatory No. 30 ever limade any recommendations and/or suggestions to you pertaining to ;the risks or hazards to persons involved in the manufacture or use j:of asbestos products. If so, identify: (A) The date when said recommendations and/or suggestions :were m a d e ; (B) The individual to who m said recommendations and/or suggestions were made ? ! (C) The individual who made said recommendations and/or suggestions; i! (D) The substance of the recommendations and/or suggestions; ;;and (E) What actions, if any, were taken by you as a result of said recommendations and/or suggestions; and (F) If no action was taken by you as a result of said Irecommendations and/or suggestions, state the reason(s) why and the ;jperson(s) responsible for making that decision. t!;. i1ANSWER TO INTERROGATORY NO. 3 3 1 See Answer to Interrogatory No. 30. LA W O F F IC E S THOMAS & U BO W ITZ P A PROFESSIONAL ASSOCIATION F IF T H FLO O R O O N CHARLES STREET B A LT IM O R E . M A R Y LA N O 21201-4305 i INTERROGATORY NO. 3 4 : ii ij State whether you have ever conducted or directed any ||investigations or studies to determine the amount of airborne dust jj containing asbestos fibers in your facilities where asbestos |i prod u c t s we r e mined, milled, man u f a c t u r e d , produced, fabricated, jjconverted, processed, stored, used, handled, installed or removed. ji If identify: 11 t: || (A) The date of each such dust count or sampling;