Document ba5rwGpzkDZvrwZeV4xgvpem3

M2TALS DIVISION " j i Mams) c.;;on .jc.auM Mr. W. C. Thurber Metals Division 38th Floor - 270 Park Avenue New York* N. Y. 10017 Messrs. R. L. Folkman R. F. X. Fusaro F. H. Larrison J. L. Myers J. J. Welsh 4^25 ROY A L A ,- z.. 3 ] 5'J'. [ 5* - oate May 12, 1975 Answer inq .fitter data suoitfc; Roderman et al.v.Union Carbide Corporation et al. Attached are answers to questions 5 and 8, providing background information in the form of supplemental interrogatories. Question 8 is specific for "trade" and "product" periodicals. Unfortunately I can only speak for this location and not for the Corporation. To list all journals pertinent to asbestos would be almost all published. Question 5 is ambiguous, and I answered it the best I could without knowing exactly what the question really was. In the answer to Question 5 1 also included the answer to one of Fusaro's throwaways at the end of his letter, i.e. the mill went on stream in October 1963 and up to then we didn't have "products". Jim Bright first examined asbestos claims in 1957, and we acquired our claims by the end of 1959. We began process development Work in'1959. Product development came later, probably late 1959. The attached history should be of interest to the lawyers. 1 can't understand how we are involved in this- The incubation period, or whatever they call the time between exposure and cancerous disease, for meso thelioma is 20 to 40 years- Anyone conking out now couldn't relate to us because we didn't ship product until late 1963 or early 1964, and our lawyers should have a cakewalk with the time element. If you need my credentials for questions 1, 2, and 3 let me know or just bring my biography in American Men of Science up to date. RJK:MM Attach. R. J. Klotzbach RECEIVED may 13 1975 UCC 004145 To: From: Date: W. C. Thurber R. J. Klotzbach May 12, 1973. Roderman et al. v Union Carbide Corporation et al Question 5 The question specifically asks whether we have or have ever had a "research and product control department". The answer is "no", specifically for the single department mentioned, and it is unlikely that any industrial organ ization has such a singularly-named department. We have a Technology Department, existing in its present form since 1970, combining departments, most of which have been in continuous existence since '955 at various locations. The oldest group, the metallurgical group, has been in continuous existence since 1917- None of the combined departments handled asbestos "products" prior to October 1963 when the king City Mill went on stream, or handled ores prior to 1959- The Technology Department performs research, development, and engineering functions with the following functional groups: 1. Mineral Science .2 Process Development 3 Product Development 4. Process Engineering 5. Project Engineering 6. Analytical Laboratory 7 Metal Properties Laboratory 8. Quality Assurance 9. Administration The present director of the department is Robert J. Klotzbach. The department provides business relevant mineral research, process and engineering devel opment, product development, preliminary engineering and estimates, design and process engineering, project and construction engineering, plant technical assistance, technical sales assistance, new product uses, morphological and metal lographic analyses and analytical services, and quality assurance for new and existing mineral deposits and manufactured chemical and metallurgical commodities won from these ores and related chemical and special metallurgical products. It supplies processes, facilities, products, technical services, capital forecasting and technical problem-solving to the Operating, Marketing, Exploration, and Mining departments. Quality assurance is the regulatory process through which we measure actual product quality performance, by comparing it with standards and acting on the difference. At this time it consists of a manager, acting alone, who coordi nates activities of seven people reporting at the plant and sales level. Quality assurance has been a continuous function since 1965. Quality assuranceapplies to alI of our manufacturing and milling facilities. UCC 004146 To: From: Date: W. C, Thurber R. J. Klotzbach Hay 12, 1975 Roderman et al. v. Union Carbide Corporation et al. Question 5 (continued) A function of the engineering group is to provide a safe working environment, and design and construct process and plant facilities that equal or exceed Corporation and OSHA safety standards and exceed mining industry standards and comply with national, state, and local environmental quality standards. A separate safety divisional department works outside the technical depart ment and relates primarily to in-house safety. UCC 004147 To: From: Date: W. C. Thurber R. J. Klotzbach Hay 12, 1975 Roderman et al. v Union Carbide Corporation et al Question 8 We have in the library at Niagara subscriptions to two product research and trade association periodicals which we have received since 1967: ASBESTOS BULLETIN Bimonthly Science, Technology and Applications of Asbestos- based Materials Printed in-England ASBESTOS Monthly Willow Grove, Pa. However, asbestos is an industrial mineral, and used in drilling muds, con struction, water purification, etc., and constant reference is made to it in mining journals, chemical abstracts, engineering index, construction journals, oil and gas journals, sanitary journals, etc., ad infinitum. We subscribe to a host of these journals, abstracts, and indices, and have done so continuously since the Corporation was formed in 1917 at all of our locations. In addition the Medical and Toxicology library located in New York City contains discipline-related journals from 1930 through 1975. We have been aware of the hazardous potentials of asbestos consistent with the state of medical and toxicological knowledge at any particular time and are also aware of the degree of uncertainty, even at the present time, in defining what constitutes a biological hazard. UCC 004148