Document em06wBzQqeBxdgyrOwYN5eMoG

FILE NAME Owens Illinois OWILL DATE 1979 July 11 DOC OWILL020 DOCUMENT DESCRIPTION Legal - Deposition of William Justice a _ Mari Cen Dav_i_ d W ye + con Cowles David Griffith Conard Metcalf cae WilliamWilliam A. Trine Trine Charles E. Williams Michael A. Patrick Law Offices WILLIAMS TRINE GREENSTEIN & GRIFFITH Professional Corporation 1435 Arapahoe Boulder CO 80302-6390 TEL 303 442-0173 FAX 303 443-7677 Joel H. Greenstein 1933-1984 11/3/89 Barry Castleman Sc.D. 1722 Linden Ave Baltimore MD 21217 Dear Barry - Enclosed are copies of pages from the 1979 deposition of William Justice a long time employee of Owens Illinois and Owens Corning Two matters discussed One the 1958 OI Berlin plant dust study I I sent you and said I couldn't remember where got it The document is referred to in the Justice deposition as having been produced by Aetna FORM FORM . 12 2020 N.J. 13 BAYONE 14 CO 15 PENGAD 16 17 18 19 20 21 22 23 24 25 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY CIVIL ACTION NO 78-2509 DOMINIC FORTE and JOSEPHINE Ye? FORTE his wife Ye ee Plaintiffs | . VS ee MANVILLE et als a - Defendants Si 7 ... UNITED STATES DISTRICT COURT - ae FOR THE DISTRICT OF NEW JERSEY CIVIL ACTION NO 78-2207 HARRY S. COPELAND et al Plaintiffs MANVILLE PRODUCTS CORPORATION et als Defendants DEPOSITION OF WILLIAM JUSTICE witness of lawful age taken on behalf of the Defendants in the entitled cause wherein MORTON J. AUSTIN and others are the Plaintiffs and MANVILLE and others are the Defendants pending in the United States District Court for the District of New Jersey before GERARD J. RICHARDS a Notary Public of the State of New Jersey on Wednesday July 11 1979 at the Corning Fiberglas plant Berlin New Jersey s o4 s 7 z J = . 07002 07002 07002 07002 07002 N.J. N.J. N.J. BAYONNE BAYONNE BAYONNE BAYONNE BAYONNE BAYONNE BAYONNE CO CO PENGAD PENGAD PENGAD PENGAD PENGAD PENGAD 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Justice - direct 6 proceeding and should be treated as though you were actually testifying in a courtroom Do you understand all of that A Yes Q |. How long have been employed by Owens- Corning _ A . I have to go back and start when I was employed by Illinois Q Let me rephrase the question and go back to the beginning Let's start with Illinois when were you employed by them A I can give it to you within one day it was either 4/1/1951 or 4/2/1951 I'm not sure of the 4/1 or 4/2 0 Either April Fool's Day or the day after A Yes or the day after Q Where did you work before you came to work for Illinois A Where did I work before then Q If you did oo Te A Various and sundry places After I got out of the service I worked for Goodyear for a while in Akron Ohio and then I went back to Ohio State got my degree from Ohio State and after I got out of Ohio State I interviewed with many companies one of which was Illinois and I went to work for Illinois Illinois Lae Do eek tenmt cath of wales eee ath Oe Oe he eet . pered ee 2066 1,oman FORM 0702 N.J. BAYONE .. CO abe PENGAD e tate 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 . Justice - direct T Q What was your degree from Ohio State A Bachelor of Science in Industrial Management And when you went to work for Owens- . Illinois at what facility of that company were you . assigned A I went to work at - the Sayreville plant the Kaylo operation in Sayreville New Jersey Q And you worked at the Sayreville plant * from approximately April of '51 up to the time that cs Sayrevillewas closeddown - A Yes approximately two years if I remember 7 right And the plant manager at that time there was Mr. Pfeiffer A Pie Pfeiffer Q And at that point in time he was brought to Berlin and so were you A Yes I came here with Pie Pfeiffer to Berlin Q ever since And have you worked here continuously A Yes Q And when you were working at Sayreville back in theperiod of '51 to '53 what was your job A Let's see I started out in the maintenance department and I was a maintenance supervisor for a while approximately a year Then I was warehouse and coop PMT. we arpa. a2 om newest prerwer ys i Re ne wast ee Dian ak 8 tierce tsa oh 6c Bh ot dentin . ret 2046 2046 ume 2046 2046 FORM FORM FORM FORM * . 0702 N.J. BAYONE CO PENGAD - 10 11 12 13 . 14 15 16 17 18 19 20 21 222 222 222 Sn ee eri PO ee ree, 2 ae Justice - direct 00 shipping manager and right prior to leaving Sayreville I became the service manager there here I was a service manager And when I came Q What did service manager mean what does that mean - A That means incoming orders shipments out of the plant keeping track of them making sure they are shipped on the day they are supposed to go out the mix of goods is right servic- - ing customers => ae - - Q All right And after you came to Berlin _ when did your job title next change A I don't know whether I can give you exact dates I can give you approximate dates Q Give us your best approximation A A year and a half and then I became a production ~ supervisor Q of -'55 So it would be somewhere in the vicinity A That would be somewhere around '54 it was '54 I became a production supervisor Q And how long did you remain production supervisor A about three anda half years About three years I came back in the office late '57 Q As production supervisor what were your ol Pe oe a mc ma ene 10 204 11 FORM - 12 0702 13 N.J. BAYONE 14 CO 15 PENGAD 16 17 18 19 20 21 22 23 24 25 Justice Q direct. duties A supervisor 9 I ran a shift a shift Q At the time that you were production supervisor do you recall what Mr. Grimmie's duties . were what he was doing A Yes he was production superintendent Q two jobs | What was the difference between those a A He was the bossman oe boss He Yes your Q - wort was a A | Q Would you have had foremen working beneath you when you were production A At that time our organization supervisor structure we did not have the luxury of having the foremen reporting to us they do now but we didn't have it then no I had hourly type foremen crew leaders and this type of thing but no salary type Q And in late '57 your job changed to what sir ; A _ I had productio_n| planning and purchasing Then there was I am trying to think '58 wasn't it when Corning took over There was a temporary period where I had three jobs while they were looking for a personnel director I had the personnel director's job I think it was for about seven months na e Perna Tem oe 2046 2046 2046 2046 FORM FORM FORM FORM 0702 N.J. BAYONE CO 15 PENGAD 16 17 18 222 222 . 222 23 24 \ 25 Justice - direct_ 19 or the personnel department on types of respirators to buy types of respirators trials and this sort of thing belongs to But the the processing and purchasing area the actual | procuremer Q Now I am going to show you some documents which have been furnished to us by Aetna Insurance Company _ some of them involve your name and am going some questions to ask you a emitiedl about thems | - Now first of all let me showyou an exhibit that was produced for us by Aetna which has been marked Aetna Exhibit 1 for identification on 6/12/79 It's entitled Dust Survey prepared for Illinois -Kaylo Division Berlin New Jersey by Messrs Sehl and Robinson April 28th and May 2nd 158 which I know were quite close to the dates of the transfer of the plant from Illinois to Coming And under contacts it says the following Mr. F. W. Sehl and the writer that would be Mr. Robinson contacted Mr. Pfeiffer plant manager Mr Justice personnel director Mr. Cassiaral personnel assistant Mr. Grimmie production superintendent Also present were Mr. Gardner safety director for Illinois and Mr. Paul Shoe Aetna safety { engineering representative who services this plant ~.First of all do you have any recollection of Soman egret eee yee = od 7 (4 1 2 ||. of 4 vad ' ;< a . 3 .4 5 6 7 8 a4 - :: 2020 C N.J BAYONE C-O , PENGAD }| 11 12 13 14 15 16 17 ; : C 18 19 20 " 21 " 22 23 | 24 . . | 25 ~~ Justice - CIOSS 43 was '53 I was here a year I went on the floor in '54 and I was on the floor for three years yes '54 to '57 aQ What time 7 : and the facilities were your specific duties during that A I was in charge of a shift of the factory the production and processing and so forth during that period of time Whenever my shift was on I was in charge reporting to a factory superintendent Q ve Did I understand you to say that during | that time you received African asbestos and Canadian asbestos for use in the manufacturing process A Yes Q And from what companies during that time did you receive the African asbestos A North American Q Only A my knowledge at that time | Yes to the best of | Q From what companies did you receive Canadian asbestos A . When I was a shift supervisor on the floor Q Yes If you know A I can't honestly say who the companies that we were receiving asbestos from at that time was I did not really get involved in it until I got in the purchasing area a Sr. Be RL te nee, eee ee ee tee cs Sr er Justice - cross . 44 Q And that would have been in '57 ee, ca A Yes namie I know we were getting short fiber asbestos chrysolite and we were getting long fiber asbestos the African the amosite nom, Q ' Now did I understand you to say that the Canadian asbestos was received on railroad cars A Railroad cars yes Q And in what form of packaging was it 2046 2046 2046 2046 FORM FORM FORM FORM 0708 ~~N.J. 11 12 13 BAYONE 14 to 15 pentli 16 received > ~: oa A >. The earlier ones and that didn't last too long after I came into the purchasing area were in burlap bags and then they went to all multi Kraft paper bags Q Do you know when the change took place A No not exactly no Q Was it during the time that you were the production the production field - 17 A No it was right along before I left the floor 18 and came into the office because the change took place 19 right along in there Because I can remember being ee 20 on the floor and part of my job responsibility was the S pp 21 batch mixing facility and so forth that you could 22 always tell the amosite asbestos because it was in 2 burlap bags and the one grade of Canadian asbestos was in a burlap and a Kraft paper bag 2 2 Q Did those containers let's take the oe . ean ENG OOS TORN TAENT TO > URN Fy FUUNIO INGE E BORD SNA 9 EER. a SUE Stee tet e " ad wh otek ate ena meen Aen a 4- 4- re