Document baxNJL1gzk6V34dpg9zxQKzDZ

Hicks; et al. v. ACandS, Inc., et al. .... 6/1/01 - Paul L. LeCour Page 98 Page 100 1 Q. Was (here any shift in your duties and 2 responsibilities or personnel at Genuine Parts or Rayloc 3 from before the insurance company notified you about the , 4 hazards of asbestos to after the company notified you 5 about the hazards of asbestos? 6 A. No. 7 Q. Was there any department that assumed 8 responsibility, any greater responsibility with respect 9 to the dangers or hazards associated with asbestos after 10 you were notified by your insurance company, as compared tl to before you were notified? 12 A. No. 12 Q. Did the company employ any consultants, other 14 than through its insurance company, with respect to the 13 dangers or hazards of asbestos after it was first 16 notified by its insurance company? 17 A. No. IS Q. Did Genuine Parts attempt to investigate any 19 of the hazards or dangers of asbestos after it was 20 notified by its insurance company, other than thework 21 it did in connection with its insurance company at the 22 plant?. 23 A. Well, when they were made aware that it was 24 a potential hazard to a person's health, they took 23 corrective action immediately to prevent any exposure 1 received any medical literature about the dangers or 2 hazards of asbestos? ' 3 . A. f do not recall that, no. 4 Q. Does Rayloc have an industrial hygienist or 5 medical doctor on stiff? 6 A. No, they do not. 7 Q. After you were notified about the dangers or 8 hazards of asbestos from your insurance company, was 9 (here any decision or discussion about whether or not 10 . you should hire an industrial hygienist or a medical . 11 doctor at any of the Rayloc facilities? 12. ' A. Not that I can recalL 13 Q. Has Genuine Pans or Rayloc ever employed the 14 services of any outside industrial hygienist or medical 15 doctor with respect to the asbestos in its plants? 16 A. With respect to asbestos in its plants or the 17 exposure to the employee? 18 Q. Either/or. 19 A. You Ivave to rephrase your question, please. 20 Q. Okay. Has Rayloc or has Genuine Pans ever 21 gone out and hired an industrial hygienist or medical 22 doctor as-a consultant in any way related to asbestos? 23 A. No. 24 Q. I've seen in the documents that were produced 25 to me yesterday Material Safety Data Sheets. Page 99 Page 101 1 to excessive dust. 2 Q. . That was at the plant? 3 A. At the plant.. .4 . Q. Can you tell.me who the person was at Genuine 5 Parts who was responsible for investigating whether or 6' not Genuine Parts products were producing dust when .7 mechanics used them in the normal course of their work? 8 A. That were producing dust or were not producing 9 ' dust? 10 Q. Were or were hot. II A. Were not - was anyone appointed? . 12 Q. Let me ask you - let me rephrase the 13. question. 14 Was anyone appointed or did anyone have the 13 specific responsibility ofsaying, we should ensure that 16 mechanics who are using our products are not producing ' 17 dust when they use our product, after you learned about 18 the hazards From your insurance company? 19 A. Our product did not have dust in it, so we had 20 no reason to appoint someone. 21 . Q. So the answer is there was no one appointed to 22 ensure whar you already knew, 1 guess? 23 A. Well, we ensured it by making sure we kept it '24 in the plant. 25 ,Q, Are you aware ofanyone at Genuine Parts who 1 A. (Nods head affirmatively.) 2- . Q. You have to say "yes." . 3' A. Yes. 4 MR. RILEY; You're asking him to agree 5 that you saw them yesterday. 6 MR. DUMLER: You can't shake your head. 7 MR. RILEY; You have to ask a question. S Q. (By Mr. Dumler) A/e you familiar with 9 Material Safety.,Data Sheets?. 10 A. From whom? II Q. Are you familiar with them in general? 12 A. Yes. 13. Q. When is the first time that you have any 14 recollection of receiving a Material Safety Data Sheet 15 from any manufacturer? 16 A. 1 don't recall the exact time. 17 Q. Can you give me a general time frame? 18 A. '80s, late '80s. 19 (Plaintiffs' Exhibits LeCour 10, 11, and 12 20 . .21 22 were marked.) Q. (By Mr. Dumler) I'll give you 10, 11, and 12. First take a look at Exhibit No. 10, and tell 23 me what that is. 24 A. It's an Abcx Material Safety Data Sheet. 25 Q. When did you first begin to receive Material WHEELER REPORTING COMPANY. INC., 40*73.51.457.7 26 (Pages 9S to .101)