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Hicks, et al. v. ACandS, Inc., et al. ... 6/1/01 - Paul L. LeCour Page 102 Page 104 1 Safety Data Sheets from Abex? At the same lime frame, a late '80s? 3 A. Ye*. 4 Q. Nos. 11 and 12, what are those documents? 5 A. Material Safety Data Sheets, Abex lining. & That's it. 7 . Q. These are prepared by Rayloc; is that correct? s A, This Item 11 would have been prepared by 9 Rayloc. 10 Q. Did you have any involvement in preparing that 11 document? 12 A. No, I did not. 13 Q. Do you know where the information that was 14 -placed on that document came from? It looks like 15 a computer-generated document. 16 . A. It would have come from Abex, because it 17 designates Abex lining. 18 Q. So the information is provided by Abex. And 19 then it's just simply put on the sheet by Rayloc; 20 is that correct? 21 A. Yes. 22 Q. All right. Prior to gening the Material 23 Safety Data Sheet, was there ever any other data or . 24 product information that was sent to you by any of the 25 manufactures along the same lines as this, warning of 1 A. Yes. 2 Q. Did Genuine Pans use this document in 3 connection with its Rayloc operation? 4 A. No. ' 5 Q. What's the reason that you or someone else '6 at Genuine Pans would get a'copy of this document? 7 ' A. FiMSI itself is Supported by the manufacturers 8 of friction material. We would get this document here 9 to look at, for cataloging purposes, to make sure as 10 a comparison uf what we are cataloging versus what II they're saying tu catalog. 12 We also wanted to do it on thickness, because 13 they do supply the thickness of the material in the 14 back. And then how is it attached, it tells you whether 15 it's integrally molded or whether it's riveted. I'm 16 . speaking of a disc pad. That's the reason why we would 17 use il. 18 It also gives specifications of the drum 19 diameter, the width. So we would use it for really 20 brake shoe and disc pad identification purposes.' 21 Q. So when the catalog, die FMSI catalog, came 22 out, would you compare that .catalog to the catalog you '23 wore producing? 24 . A. Well, it wouldn't be 100 percent. But,yes, 25 if they, came out with any new information, we always Page 103 Page 105 1 2 3 4 5 6 7 S .9 10 11 ' 12 13 14 15 J6 17 IS 19 20 21 22 23 24 25 any particular dangers or health hazards? A. Not that 1 can recall. (Plaintiffs1. Exhibit LeCour 13 was marked.) Q. (By Mr. Dumler) I've given you Exhibit No. 13, an FMSJ Brake Shoe Identification Catalog. And other than the name, can you tell me what this is? A. Friction Material Standard Institute.. Q. What is the catalog used for? ` A. Well, the catalog is used to specify by application what strip lining or what friction materiat you'll use on that particular application. Q. All right Is this a document that came from your personal file? A. It could have. I have copies like this. Q. How-long have you been getting copies of this particular catalog from FMSi? A. Well, it doesn't come out all the - or regularly. So I Would say it would have been started in the late '70s, early '80s. Q. The date on this is *78. Do you have any recollection of receiving this document prior to 1978 or another catalog from a prior year? A. I've seen some in prior years. Q. All right. So what's the earliest, early '70s, that you - 1 looked at the new information from a dimensional point 2 of View. And that's what we used it for, to make sure* 3 we had the applications covered. 4 Q. Who would be responsible for going through the 5 catalog and comparing it to your particular catalogs? 6 A. What time, frame? 7 Q. Well, let's say the 1970s. ' 8 A. 1 would. . 9 Q. So did you receive each ofthe catalogs that 10 came out from FMSI 11 A. Uh-huh. 12 Q. -in the 1970s? 13 A. Uh-huh. 14 Q. Al the back of this catalog, Bates No. 120535 , 15 there's recommended procedures for reducing asbestos 16 dust during brake servicing. 17 Art you familiar with that document? 18 . A. Yes, 1 am. 19 Q. When did you first leam about those 20 recommended procedures from FMSI? . 21 A. I can't recall the exact time, but these .22 procedures we used internally every day at Rayloc. 23 ' Q. Do you remember takingthose procedures and 24 matching ihcm against the procedures you were using 25 iii'housc? Wheeler reporting company, inc., 404-351-4577 27 (Pages' 102 io 105)