Document bepe3qmg0m6rkwqNj9nX00Oy

JOHN PETERSON and SHIRLEY MAE PETERSON, Plaintiffs, vs. UNION CARBIDE CORPORATION, Defendants. { *2* 7>c SUPERIOR COURT OF NEW JERSEY LAW DIVISION: MIDDLESEX COUNTY DOCKET NO. L-060148-87 DEPOSITION DIGEST OF SAMUEL S. EPSTEIN, M.D. December 1, 1989 JLr-\ f. /, : /o2/ /'~Xr Digested By: Nancy K. Docher Legal Assistanc Lines Subject Matter 1-4 Name And Address Diqest of Testimony Samuel S. Epstein Apartment 25M 860860 N. Lake Shore Drive Chicago, Illinois 60611 DIRECT EXAMINATION BY ROBERT HOLLINGSHEAD (Union Carbide) 6-25 1-19 20-25 1-3 14-25 1-25 1-9 10-25 1-11 Attorney instructions. Education/ Employment History Witness' Publications (Mr. Hollingshead requested a copy of witness' current CV/resume.) Witness stated that he is currently professor of occupational and environmental medicine at the School of Public Health University of Illinois Medical Center in Chicago. Witness further explain ed that all of the degrees which he holds at present were the re sult of his education at London University. He received the equi valent of the U.S. version of the M.D. in 1950. He is not a licensed physician of any state in the U.S. In his present position at the University of Illinois, he does not diagnose, treat or see patients. He does not maintain any U.S. board certifications. Witness stated that he has authored approximately 300 publi cations over the course of time. Several of his publications dis cussed the chemicals involved in this particular case (polyvinyl chloride, vinyl chloride monomer, polystyrene, isopropilidene resin, asbestos, and various chemicals that are emanated by welding fumes). He further stated that asbestos, vinyl chloride, and PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 089673 Page Lines Subject Matt r Digest of Testimony polyvinyl chloride were discussed by him in a book called The Parti culars of Cancer published in 1978-79. (Mr. Hollingshead re quested the list of publications that witness has authored.) 8 12-25 Litigation Involv- Extensive discussion was held re to ing PVC/VC witness' involvement with PVC/VC 13 1-9 litigation in the past 10 years. Witness described the four cases: Elias v. Parke Davis and Sprayon in 1979, Grasso v. BF Goodrich in 1981, Mikyska v. Ford and Union Carbide in 1981 and Maliko, et al v. Union Carbide in 1979. Elias involved an infant that subse quently developed a malignant tumor post-surgery after his inci sion scar was sprayed with Spray- on. The case was settled after witness' deposition. Grasso in volved an individual who was ex posed to VC emissions from a plant that was located one and three quarter miles from his resi dence. Grasso subsequently devel oped angiosarcoma of the liver. Witness was deposed and testified at the trial. Mikyska involved workers at a Ford plant that was exposed to VC, consequently devel oping a toxic hepatitis. The case was settled after witness' deposi tion. Mr. Hollingshead was fami liar with the Maliko litigation. (Mr. Hollingshead requested copies of all documentation that witness had pertaining to the Elias, Gras so and Mikyska litigations.) 13 10-25 Involvement With Witness stated that his only 14 1-2 Polystyrene Liti- involvement with polystyrene gation litigation was the Maliko case. He further explained that other chemicals were involved in the PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" -2 UCC 089674 \{ Page Lines Subject Matter Digest of Testimony case also, but the main focus was PVC. 14 3-11 Involvement With Witness explained that he had Asbestos Liti very little involvement with gation asbestos litigation. (Mr. Hol- lingshead requested copies of any reports witness may have done on asbestos.) 14 12-25 Involvement With Witness discussed his involvement 15 1-4 Isopropilidene, with isopropilidene bisphenol Bisphenol Resins resins litigation, including the Litigation Maliko case. (Mr. Hollingshead requested a copy of all written documentation that witness had re his isopropilidene, bisphenol resins litigations.) 15 6-10 Involvement With Witness stated that prior to Welding Fumes Lit Peterson, he has never written gation an expert report re emissions from welding fumes. 15 11-25 Responsibilities Witness stated that his current 16 1-12 The University of responsibilities as a professor of Illinois occupational medicine at the Uni versity of Illinois Medical Center included research, teaching and public service. He further ex plained that he teaches an inten sive winter course involving a series of current issues that have a strong scientific involvement in environmental or occupational matters. 16 13-25 Research Assisted Witness stated that he would only 17 1-25 By Graduate utilize graduate students as 18 1-3 Students research assistants when it in volved his work at the University of Illinois. He never utilizes the aid of graduate students in his practice as a consultant. 18 4-25 19 1-8 witness stated that of a five day workweek approximately four days involved university work and one PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 089675 > Page Lines Subj ct Matt r 19 9-18 19 19-25 Involvement With 20 1-25 Laryngeal Cancer 21 1-7 Litigation 21 8-14 21 15-25 Involvement In 22 1-25 Peterson Case 23 1-9 23 18-25 Exhibit Epstein 1 24 1-18 Digest of Testimony day involved his consulting work which is primarily in the area of litigation. Witness stated that his consulting work is exclusively on behalf of injured individuals in various capacities, not on behalf of any manufacturing or chemical compa nies. Witness stated that prior to Peterson's case, he was involved in two other instances in which there was a laryngeal cancer. (Mr. Hollingshead requested a copy of any documentation witness had pertaining to the involved cases.) Witness stated that due to the fact he did not have any medical qualifications in this country, he was unable to sit for any board certification examination. Witness stated that in April 1988, Levinson wrote him re the Paterson case. Subsequent to the letter, they had a brief dis cussion where witness agreed to get involved. It was not until January 1989, that witness re ceived materials from Levinson. He stated that since the Maliko litigation ten years ago, he has not had any professional contact with Levinson or any member of his firm. Epstein 1 is the Notice To Take Deposition and Produce Docu ments. Witness produced all writ ten documents he received from Levinson incorporated in a note book . sSSSSs* ohoe^?Totive 4 cc 089676 Page Lines Subject Matter Digest of Testimony 25 22-25 Discussion With to Velez 29 1 29 2-25 Tabershaw Report 30 1-10 30 17-25 31 1-25 32 2-17 Exhibit Epstein 2 32 18-25 Updating to Preliminary Report 35 1-15 sag?*!** Witness stated that the only other person he had discussed this liti gation with other than Levinson was Velez. He received two phone calls from Velez in October 1989. During the first one, Velez requested a copy of witness' re port. The second phone call was for the sole purpose of requesting a copy of the Tabershaw docu ments. Velez did mention to wit ness in the second conversation that Velez was going to be de posed. He did not make notes of any of the conversations. Witness stated that of the three Tabershaw reports, only the Tabershaw/Gaffey Report was published and that was in 1974. Witness stated that his notebook contained references to everything that he utilized to render his report, but not the original arti cles. Epstein 2 is a copy of witness' Preliminary Report dated 9/13/89. Extensive discussion was held re four additional documents witness had brought with him to the deposition updating his preliminary report. Witness explained that at the time he authored his Prelimi nary Report, time constraints prevented him from obtaining addi tional material necessary to ade quately update his report. He was advised by Levinson to bring the four additional documents to his deposition, updating his Pre liminary Report. The four docu ments are as follows: Factors Incriminating VC/PVC As The Pri mary Cause Of Peterson's Laryngeal Cancer, State Of The Art On VC/PVC -5- UCC 089677 Page Lines Subject Matter Digest of Testimony Toxicology Prior To 1974, Illus trative Literature On The Toxic And Carcinogenic Effects Of VC/PVC In The Respiratory Tract Of Ex perimental Animals and Illustra tive Literature On The Toxic and Carcinogenic Effects Of VC/PVC In The Respiratory Tract Of Expos d Workers. All of the documents were contained in witness' note book . 35 16-25 Factors Incrimi Witness stated that he wrote his 36 1-25 nating VC/PVC document entitled Factors Incrimi 37 1-12 nating VC/PVC As The Primary Cause Of Peterson's Laryngeal Cancer after reading Davidson's deposi tion re PVC dust exposure. He further explained that all four of his additional documents were authored within two weeks prior to his deposition. 37 13-25 Peterson's Asbestos Witness stated that he learned of to Exposure Peterson's asbestos exposure from 40 1-11 two pieces of info. Those being Peterson's X-ray and additional info he had received from Levinson's office re Peterson's occupational exposure. He further explained that it is his practice, in an attempt to save on file space, to go through all the paperwork that reaches him, ex tract the information, incorporate it into his notes and then discard it. 40 12-25 Exhibit Epstein 3 Epstein 3 is a letter 41 1-13 and 4 dated 4/18/88 from Levinson to witness. Epstein 4 is witness' notebook. 41 14-25 Item No. 5 Of 42 1-25 Notice To Take Deposition Witness stated he has never ren dered an oral report to Levinson nor had any draft copies of his original Preliminary Report in PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" -6- UCC 089678 y gage Lines Subject Matt r Digest of Testimony answer to Item No. 5 of Notice To Take Deposition. 43 1-14 Item No. 6 of Notice To Take Deposition Witness stated that in response to Item No. 6, he will make available copies of prior litigations he had discussed earlier in the deposi tion. 43 15-25 to 52 1-12 Extensive discussion held re the various sections of witness' note- book which was previously marked Epstein 4. 52 14-25 Exhibit Epstein 4 Extensive discussion held re to various sections of Epstein 4 55 1-7 which is witness' notebook. The sections discussed included the background summary, medical his tory and personal section. 55 8-25 Peterson's ATC to Exposures 58 1-13 Witness stated that the section of Epstein 4 entitled occupational history, indicated that prior to Peterson's employment at ATC, he had no exposure to asbestos and PVC. He stated he arrived at this conclusion from information sub mitted to him. He never personal~t ly interviewed Peterson. Witness then explained his elaborate sec- ' tion under occupational health indicating Peterson's exposures at ATC. 58 14-25 59 1-25 60 1-17 Witness stated that some of the documents that he included under the heading of VC/PVC Toxicology were prepared for the Maliko case. 60 18-25 Chronic Meat Witness stated that he does not 61 1-25 Wrappers Asthma associate meat wrappers asthma N 62 1-5 with PVC because "the levels of VC that have been measured from PVC film are extraordinarily small and in some cases not detected at all." (Mr. Hollingshead requested a listing of all cases witness PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" " ^CC 08967Q /y Page Lines Subject Matter Digest of Testimony appeared in with regard to meat wrappers asthma and the attorneys who were involved in those cases.) 62 6-17 Laryngeal Cancer Witness stated that the document entitled Risk Factors For Laryn geal Cancer was prepared by him for the Peterson case. 64 20-25 Use Of Personal Witness stated that when he 65 1-25 Research becomes involved in any piece of 66 1-6 litigation, he relies on his own personal research. He reviews journals on a regular basis and keeps his files up-to-date. If his files on a particular subject are not complete, he may use Tox- line or Medline. His files are maintained by the use of index cards listed by chemicals. He would update the cards by simply listing the name of the author of the study and the date of publica tion. 66 7-25 Page 1 Of Witness Extensive discussion held re to R^port/Peterson's witness' statement on Page 1 of 70 1-19 XTC Exposures his expert report indicating that /Causally Related he had concluded that "Mr. Peter * To His Laryngeal son's occupational exposures at Keratosis And ATC were causally related to the Cancer laryngeal keratosis he developed in 1978 and the laryngeal cancer he subsequently developed in 1984." Witness explained that keratosis is a premalignant condi tion involving epithelial hyper plasia which is generally charac terized by atypical cells in the mucosa. He explained that Peter son's medical records indicated that Peterson was diagnosed with laryngeal keratosis in 1978 and that such a condition is a pro- curance to laryngeal cancer. He explained that Peterson's occupa tional exposure at ATC included PVC, VC, asbestos, polystyrene, isopropilidene resin (Bisphenol privileged and SUBJECT TMAL MATER|AL SUBJECT TO PROTECTIVE ORDER" 8 UCC 089680 Page Lines Subject Matter 70 20-25 Respiratory Tract 71 1-8 71 10-25 Occupational 72 1-14 Exposures All Carcinogens 72 15-25 to 77 1-20 77 21-25 Peterson's PVC to Dust Level 80 1-8 Undetermined Digest of Testimony A), emissions from welding fumes and heat-sealing fumes. It is witness' conclusion that all of these occupational exposures had a contributory role in Peterson's laryngeal keratosis and subsequent laryngeal cancer. Witness defined the respiratory tract to include the nose, naso pharynx, pharynx, larynx, trachea, bronchi, bronchials, alveoli and pleura. Witness stated that all of the occupational exposures that Peterson had at ATC were carcino gens. In some instances, in addi tion to the carcinogenic effect of some of these exposures, there was a chronic toxic or chronic irri tant effect. Witness's extensive explanation of his notebook sheet marked ATC was halted by Mr. Hollingshead due to the fact it was not responsive to the line of questioning re Peter son's specific levels of exposure to PVC or VCM. Witness stated that due to the fact Peterson did not have any specific PVC monitoring, the info could be derived from two sources (description of work conditions and info on the monitoring levels in the area Peterson worked). He estimated Peterson's PVC dust levels to be in the "20 milligram per cubic meter range." He further explained that it was impossible to give a precise figure because of the failure of UC/ATC to do any PVC dust moni toring . PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" 9 UCC 089681 Page Lines Subiect Matter Digest of Testimony 80 9-25 PVC Dust- to Respiratory System 84 1-23 84 24-25 Peterson's Expo 85 1-25 sure To VCM 86 1-11 86 12-25 PVC Dust Asso 87 1-25 ciated With 88 1-2 Respiratory Ca 88 3-25 VC Sources 89 1-25 90 1-21 PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" Extensive discussion was held, re witness' understanding of PVC dust being filtered by the respiratory system. He explained that every thing that Peterson would breathe in the air would reach his larynx and particles under ten microns would reach Peterson's lungs. The remainder of the particles would remain in contact with the larynx eventually being coughed up or processed through the digestive system. (Mr. Hollingshead requested this portion of witness' answer be striken as unresponsive to his question.) It was witness' testimony that Peterson was exposed to PVC dust in the range of at least approximately 20 milligrams per cubic meter. Witness stated that he was unable to determine Peterson's VCM exposure on an average workday at ATC prior to 1975, because of the wide range of different sources of Peterson's exposure. Witness discussed the various doc umentation he included in his notebook re the fact PVC dust was associated with respiratory tract cancers. One explanation was due to the fact VC had a rapid blood absorption. Witness explained the various sources of VC that Peterson may have been exposed to. They in cluded: VC absorbed on PVC resin, VC in storage areas (bins, bags, hopper cars, vans), degassing of all VC from pellets, powder and PVC dust, displacement of air in the PVC bags, fix point emission sources (dust from PVC pellets) and thermal degradation from the heat sealer and welding. UCC 089682 Pag Lines Subiect Matter Diqest of Testimony 90 22-25 VC Levels Prior Witness stated that there was no 91 1-25 To 1974 VC sampling data prior to 1974 and 92 1-21 that VC resins prior to 1974 had much higher levels. 92 22-25 CJC Lowered Levels Witness stated that in 1974, UC 93 1-10 Of VC In 1974 introduced a vacuum stripping technology that reduced the levels of residual VC in PVC. 93 11-25 Available Data on Witness discussed the available 94 1-25 VC Levels Subse- data on VC levels subsequent to 95 1-3 quent To 1974 1974. He stated that Wheeler's simulation in modeling stated that there were levels of 0.98 ppm during bagging, where in contrast, Davidson's estimate was in the order of 10 ppms. He explained that the Gollob analytical data of 1975-76 did not take into account all possible exposures of PVC dust at ATC. 95 16-25 Peterson' s VC Witness explained that he could 96 1-25 Levels Of Exposure not give an exact figure of 97 1-22 At ATC Peterson's VC levels of exposure while employed at ATC because the wide range of VC sources each without characteristic types of exposure. 97 23-25 Gollob Analytical Witness stated that it was his 98 1-25 Testing understanding that Gollob per 99 1-3 formed their 1974 test on breath ing zones of the baggers by use of personal monitoring. He further explained that the Gollob personal monitoring results were not di rectly relevant to Peterson be cause Peterson was not a bagger. 99 4-25 Peterson's PVC/VC Witness stated that prior to 1974, CO Exposure Peterson was a maintenance and 10 2 1-19 repair mechanic. Subsequent to 1974, Peterson was Maintenance Supervisor. Extensive discussion was held re the fact it was basi- PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" "u` UCC 089683 Page Lines Subject Matter Digest of Testimony 102 to 106 106 107 108 108 109 20-25 1-4 5-25 1-25 1-3 15-25 1-24 cally impossible tor witness to determine what the exposure levels were for Peterson during Peter son's employment at ATC because of his multiple and separate types of exposure. Peterson's Asbestos Exposure Witness stated that despite the fact ATC did not undertake any asbestos monitoring, there were two sources of evidence of Peter son's asbestos exposure. The first one was the radiological changes in Peterson's lungs and the second was the description of Peterson's work practices (repair ing brake linings). (Mr. Hollingshead requested a copy of Peterson's employment history supplied to witness by Levinson.) Peterson's Asbestos Exposure From Brake Shoes Discussion was held re the fact Peterson never discussed asbestos exposure in his deposition, wit ness stated that he arrived at Peterson's asbestos exposure from Peterson's 4/85 radiological re port and the fact that Peterson changed brake shoes and assisted boiler workers in replacing the insulation of the doors with as bestos rope, 1963-73. It is his opinion that Peterson's asbestos exposure could have caused Peter son's laryngeal keratosis and subsequent laryngeal cancer. All Asbestos Is Carcinogenic Witness stated that despite the fact he had no idea what form of asbestos Peterson was exposed to, all asbestos is carcinogenic. He further stated that he had expe rience with asbestos litigation approximately three times. He stated that Peterson's last signi ficant asbestos exposure was 196768 when Peterson changed brake shoes. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 089684 ES Lines Subject Matter Digest o Testimony 109 25 Latency Period- 110 1-24 Laryngeal Cance Witness stated that it was im possible to estimate the latency period for laryngeal cancer from exposure to a carcinogenic agent. Only smoking can be dis cussed in relation to specifics of latency. 110 25 Vigilani Study to 113 1-24 Witness discussed the Vigilani Study which he referred to in his Appendix 1. The Vigilani Study was an analysis of 19 asbestos workers with respiratory tract cancer and among them there was one case of laryngeal cancer. Witness stated that the general rate of laryngeal cancer in the population at large in males is about 8.5 per one hundred thou sand. He considered it a rare cancer, especially being relative ly uncommon under the age of 60. 113 25 Stell And McGill Witness explained that the Stell to Study and McGill Study referred to in 117 1-20 his Appendix 1 was an analysis of 59 cases of laryngeal cancer of which 17 had a history of asbestos exposure. The 1973 study found a highly significant association between occupational exposure to asbestos and laryngeal cancer. The authors of the. study recognize the limitations of the data, due to the fact that there were more non-smokers in the control group than there actually was in the test group. It was his view that the study supported the proposi tion that laryngeal cancer can also be related to smoking ciga rettes . 117 21-25 Smoking And Laryn Witness described various areas in 118 1-25 geal Cancer his preliminary report and note 119 1-16 book where references were made to alcohol and smoking being recog- PRIVILEGED AND SUBJECT ^IAL MATER'AL SUBJECT TO PROTECTIVE ORDER" 13 UCC 089685 Page Lines Subject Matt r Digest of Testimony 119 to 123 123 124 125 125 126 17-25 1-7 8-25 1-25 1-19 23-25 1-13 Peterson's Apical Pulmonary Fibrosis Shettigara And Morgan Report Peterson's ATC Exposures Future Risks Mesothelioma Linked To Asbestos nized risk factors of laryngeal cancer. Witness discussed the fact that prior to Peterson's ATC employment, Peterson was noted to have minimal apical pulmonary fibro sis. He explained that the Stell and McGill Study indicated that apical pulmonary fibrosis was unrelated to asbestos exposure. He stated that Velez indicated that Peterson had two types of lung problems: chronic obstructive lung disease and restrictive dis ease characteristic of pulmonary asbestosis. It is his under standing that pulmonary asbestosis is caused by asbestos exposure. Witness stated that the Shettigara and Morgan Report of 1975 that he referred to in his Appendix 1, was a study on asbestos exposure in which smoking was considered. He made no reference in his prelimi nary report to the study of smok ing. Witness stated that it was his opinion that Peterson's exposure to asbestos during Peterson's employment at OTD and ATC has placed Peterson at excess risk of future disease and cancer. The cancers involve bronchial/lung cancer, mesothelioma and GI can cer. The diseases involve infec tion (pneumonia) and various car diovascular strains, including cor pulmonale (right heart failure). Witness stated that mesothelioma is a cancer that is linked specifically with asbestos expo sure. There are two kinds of mesothelioma, plueral involving the lining of the lung and per- 14 f Page Lines Subject Matter Digest of Testimony itoneal involving the lining of the abdomen. 127 14-25 Peterson's Likli- Witness explained that if an to hood Of Developing individual has asbestosis, his 131 1-16 Malignant Lung chances of getting malignant lung Disease disease is five times greater than the general population. It is for that reason that Peterson's risk of lung cancer is increased five fold that of the general popula tion. He further explained that with the total U.S. population, the overall figures for cancer incidence, excluding skin cancer, is one out of three in terms of the risk of contracting cancer and one out of four of contracting and diagnosing. Witness referred all further questions re Peterson's cancer risk to the pulmonary/as bestos expert, Velez. 131 21-25 Risk Of Lung Cancer Witness stated, "a little more 132 1-10 than a quarter of all cancer deaths are due to smoking--more than a quarter of all cancer deaths are due to lung cancer.'' 133 13-25 Residue VC In 134 1-25 Manufacturing 135 1-3 Methods Witness explained the amount of residue VC contained in the various manufacturing methods that were used in the resin that was shipped to ATC. According to Wheeler, the amount for suspension was 360 ppms. The amount for bulk was 5-15 ppms. The amount for solution was 1 ppm. Witness noted inconsistencies in Wheeler's statements where he indicated sus pension levels of 860 ppms in Wheeler v. Maliko "but he changes his mind when it comes to the interrogatories where it says they go up to 2,000 ppms." PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" T JCC 089687 Page Lines Subject Matter Digest of Testimony 135 to 141 141 142 142 143 143 to 146 146 147 148 10-25 1-11 12-25 1-12 13-25 1-9 10-25 1-12 13-23 15-21 12-21 Rate Of RVCM's After Manufacture Extensive discussion held re the fact witness was unable to give an approximate rate for RVCM involv ing the three manufacturing pro cesses of PVC. Witness did not agree with Wheeler's conclusion with regard to the RVCM content so, therefore, "I have to approach all of his statements on VC resi due levels with caution." He did say that the RVCM level would decrease rather rapidly in the beginning after manufacture event ually tapering off. PVC Pollution By Body Fluids Witness described the process by which the unreacted monomer can be eluded out of PVC by body fluids after the PVC was ingested or inhaled by the body. PVC Resin-Laryngeal Cancer Witness stated that he was not aware of any indication in any animal studies where there is a connection between the exposure to PVC resin/dust and laryngeal cancer. Witness discussed various criticisms of the Keplinger and Viola Studies. ViolaData Witness stated that the Viola Study of 1970 was the first animal data linking VC with cancer. The study occurred four decades after VC was manufactured. Maltoni Findings Witness stated that the Maltoni 1969 findings reported in 1965, were the first linking VC with cancer in humans. Lilis And Miller Witness stated that in his Appen dix regarding PVC and VCM, he expressed the views of Lilis and Miller when stating that the PVC dust "was likely to concentrate in PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" 16 UCC 089688 Page Lines Subject Matt r Digest of Testimony and damage the small airways, besides also acting as the carrier for carcinogenic VC monomer.'' 149 1-25 Infante Studies 150 1-6 Of 1981 Witness stated the reference in his Appendix re PVC/VC to the Infante Studies of 1981 noted laryngeal cancer. He explained that although Infante did not specifically include the larynx in his very wide range of cites, Infante did discuss respiratory tract cancers which could include the larynx. 150 7-25 Tabershaw And 151 1-25 Gaffey Studies 152 1-25 Witness stated that in the initial Tabershaw and Gaffey Study in 1974, of the twelve workers with respiratory tract cancers, there was one extrinsic laryngeal can cer. In the subsequent study, of the 37 respiratory tract cancers, there were two laryngeal cancers. 153 1-15 Witness stated that the incidence of laryngeal cancer for all males is 8.5 per hundred thousand. 154 3-17 Tabershaw And Gaffey Exposure Levels Witness stated that due to the fact the 19 different industries that Tabershaw and Gaffey utilized in their studies failed to monitor the work environment prior to 1974, the individual workers' exposure were ranked on the basis of work practice and exposure duration. 154 18-25 Studies Connecting Witness discussed his various 155 1-25 VC And Cancer tables indicating studies that 156 1-14 show a connection between VC and cancer (lung and respiratory tract). He further stated that the three studies by Tabershaw/- Cooper/Gaffey indicated a connec tion between laryngeal cancer and VC/PVC. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" 17 UCC 089689 Pag Lines Subject Matter Digest of Testimony 156 15-25 157 1-15 (Witness was instructed by Mr. Hollingshead to review the pap r by Richard Doll that was published in the Scandinavian Journal Of Work And Environmental Health in 1988 for his next deposition. It is a review of epidemiologic studies relating to the health effects of VC exposure.) 157 19-25 Updating Chemical - Witness stated that when making 158 1-16 Index Cards note of recent literature on dif- ferent chemicals on his index cards, he tends to be selective in obtaining more info on certain chemicals more so than others. He stated he had a "reasonable" cata log with regard to VC/PVC. PRIVILEGED AND SUBJECT TO PROTECTIVE ORDER" 18 UCC 089690