Document ZnzxYm3NqGZLYYZ73gjyXX28L

1 INTERROGATORY NO. 70: 2 Please state the manner m which the asbestos- containing products manufactured by defendant were arced since 3 1930. 4 RESPONSE TO INTERROGATORY NO. 70: 5 See Wagner's response to Interrogatory No. 69. 6 INTERROGATORY NO. 71: 7 Is defendant aware of articles authored by W. C. Dres- sen m Public Health Bulletin No. 241 of 1938, establishing 8 threshold limit values for airborne asbestos fibers? If so, when did defendant first learn of the above-mentioned article? 9 RESPONSE TO INTERROGATORY NO. 71: 10 No. 11 INTERROGATORY NO. 72: 12 Please state when defendant obtained any information 13 concerning the likelihood of asbestos being hazardous to one's health. Include m your answer how defendant first obtained 14 this information. 15 RESPONSE TO INTERROGATORY NO. 72: 16 Wagner objects to this Interrogatory on the grounds 17 that it assumes facts not established. Wagner states that it 18 first became aware of the possibility that inhalation of asbes 19 tos fibers may be harmful to the health of brake mechanics in 20 1976. During 1976, Wagner received a letter informing it of 21 this possibility from the United States Government Department of 22 Health, Education and Welfare, from an article in the May 1976 23 issue of Brake & Front End Magazine entitled "Know and under 24 stand the law -- OSHA will soon be around," and from materials 25 received from the National Institute for Automobile Service 26 Excellence, among others. 27 28 30