Document ga8e77YvJZDGDap2x6xEbj0y3

,( INTERROGATORY HO. 17: Please state if the Defendant's medical officers or industrial hygienists ever nade at any time any recommendations and/or suggestions to the Defendant pertaining to the risks or hazards to persons involved in the manufacturing or use of insulation products containing asbestos? {As contemplated by these Interrogatories/ an industrial hygienist is one who performs engineering or health studies to identify and evaluate potential occupa tional health hazards and suggest methods of dealing vrith same.) If so, please state: j (a) Identify each document pertaining to such recommendations and/or suggestions. (b) The substance of the recommendations and/or suggestions. ANSWER: Defendant objects to this Interrogatory as irrelevant .as'"insulation products" are not involved in this lawsuit, and the term is not defined. _ 1C _ SPNY 003540