Document gajwEgz98Q2wg3OjVK3pjwkne

FILE NAME: Chrysler (CHRY) DATE: 1992 Apr 15 DOC#: CHRY089 DOCUMENT DESCRIPTION: Legal - Affidavit of William Watt with Attached Memo RE Asbestos Supplies to Chrysler Corp. w itc a MAMHAi. r c . m v t t o o n muhl u r n o r n a n i ih o u m ic h iu AFFIDAVIT OF WILLIAM WATT STATE OF MICHIGAN ) )$s COUNTY OF WAYNE ) William watt, being first duly sworn on oath, deposes and states: . 1. I am a Manager of the Industrial Hygiene and A *Toxicology Department at Chrysler Corporation and I am authorized ; to make this Affidavit on its behalf. ; 2. As used in the Affidavit, the term "toxic" refers to a chemical's capacity to cause injury to humans. The term "hazard" refers to the possibility or probability that injury to employees may result from- the handling or use of asbestos under certain conditions. . 3. I am informed and believe that during the time period from October 1, 1978 to February 5, 1986, Chrysler Corpo ration ("Chrysler"!, purchased from the defendants A.T. Calias and Alma Products a product called "Calidria", as indicated by the attached Exhibit 1, letter of Fred Roskopp, dated February 5, 1986. Calidria contained asbestos and was used as a thixotropic agent for automotive sealants at the Chrysler Chemical Plant. | 4 . 1 have been assigned to the Industrial Hygiene and \ Toxicology Department during i: j present. ii ' 5. The Industrial It the ceriod of August, 1977 to the ' Hygiene and Toxicology Department was responsible for anticipating, recognizing, evaluating and D C 5276 recommending procedures to control environmental factors or stresses that could cause injury to or impair the health of Chrysler employees who worked in the company's production facili ties. Prior to and since October 1, 1978, Chrysler employed numerous industrial hygienists, toxicologists, medical personnel, and other employees with similar functions, whose responsibili ties included the evaluation and prevention of potential health .hazards associated with the use of chemicals including asbestos, j in the workplace, including the Chrysler Chemical Plant. I 6. At least since October 1, 1978, one category of 'environmental factors of primary concern to Chrysler was chemi< jcals, including asbestos, used in the production process, because I ? the company recognized that hazards to its employees could arise ! as a result of over | 3 : oroduction process. S " exposure -- to toxic | 7. As part of its evaluation substances used in the of the potential health : hazards associated with the use of asbestos in its facilities : during the October 1, 197*8 to February 5, 1986 time period, a < Chrysler employees assigned to the Industrial Hygiene and Coxi- < l cology Department routinely reviewed literature concerning f. * asbestos' toxic properties and potential hazards, and the methods and practices necessary to safeguard employees from such poten tial hazard^. 8. Based upon their evaluation of the workplace environment at Chrysler's production facilities, including the Chrysler Chemical Plant, and their review of pertinent litera ture, attendance at various seminars and programs, and their own im D C 5277 WI&C * M A R iA t, f C , H i m LOOK OUML. 0 U U .O IN C . O f TMOlV. MICHIGAN 4 * 2 2 ( S IS ) 0 2 0 4 4 ) training and education, prior to October 1, 1978, Chrysler's | industrial hygienists and toxicologist's knew of asbestos' toxic I , jproperties and the potential hazards associated with the use .of !asbestos. Chrysler knew that asbestos was a toxic substance | that posed a potential hazard i n "the event that its employees inhaied particulate matter (i.e., dusts), that contained asbes- ijtos. Chrysler had this knowledge prior to and during the October 1, 1978 to February 5, 1986 time period and utilized its knowl edge in an effort to eliminate the hazards posed by worker exposure to asbestos through the use of certain engineering controls, including designing its production machinery to control the airborne concentration of asbestos and properly maintaining ' its production machinery. Chrysler also attempted to eliminate the hazards posed by worker exposure to asbestos by requiring certain general control methods, including the following: a. implementing procedures intended to minimize employee exposure to asbestos; b. utilizing general and local exhaust and ventila tion systems intended to remove from the wor:< environment potentially hazardous levels of toxic materials, including asbestos; c. providing respiratory and other protection for its employees; ' d. implementing housekeeping rules intended to minimize employee exposure to asbestos; e. utilizing medical screening, surveillance pro grams, and pulmonary function_testing of employees working in or near areas utilizing asbestos, and a medical screening program intended to prevent employees with existing medical problems from being assigned to work areas using; i D C 5278 f. training and educating supervisors and workers { concerning the potential hazards associated with exposure to asbestos; and g. routinely conducting industrial hygiene surveys. i I . ; 9. Chrysler is in compliance with the Federal Hazard Communication Act which was designed to inform employees of the ; potential hazards of exposure to potentially hazardous materials ,isuch as asbestos and the precautions necessary to prevent such hazards. 10. Prior to and during the period October 1, 1973 to W . H MANS.AC. r c . U t i l (4-OOH U H L U IL O IN S . U t .l l l O l l. M IC H .O A N ,, .< 2 . ( 3 I 3 , February 3, 1336 Chrysler conducted air monitoring studies at the Chrysler Chemical Plant. The purpose of such studies was to measure the levels, if any, of asbestos present in the ambient i air in various work areas. ' 11. As evidenced by the foregoing, prior to and during the period October 1, 1978 to February 5, 1986, Chrysler knew that asbestos was a toxic chemical that posed potential hazards to its employees and took affirmative steps to protect its employees from such hazards, including review of available literature, implementation of engineering systems to control m e potential for expo-sure to asbestos, instituting medical screening j and surveillance programs, developing and disseminating safety | literature to management and employees, and performing routine : air monitoring to protect employees from overexposure to asbes- .1 tos. ; 12. This Affidavit is based upon my personal knowledge I and my review cf Chrysler Corporation's records. If I am sworn jas a witness, I can testify competently to the faces contained r herein. , William Watt Manager of the Industrial Hygiene 1 and Toxicology Department, ! Chrysler Corporation jSworn to and subscribed to before me 1 this day of l(L&ujL , 1992: Notary Public ' /yjc'tsrxA-- _ County, Michigan My Commais sion Expires: y- V - f y r C . n r . . . 1 0 0 k u . il k u u u im i. o n n o n . h i u . i u l k <k. . . , j . j , m j o t 4 i vit * I D D C 5280 CofCfKC'*OL'C*O*UNSU A Ik CHRYSLEF CORPORATIOr February 5# 1986 Joseph V. Brennan# Esquire SULLIVAN# WARD & BONE 220 w. Congress - 5th Floor Detroit# MI 48226 Re: ASBESTOS SUPPLIERS TO CHRYSLER CORPORATION Dear Joe: The following list of data designates the part number# supplier's# and time period in which.Chrysler Chemical purchased Asbestos: PRODUCT IDENTIFICATION CHRYSLER SUPPLIER CHRYSLER'S BASE TIME PERIOD F445 Asbestos 7D Asbestos Corp. Ltd 10-1-67 to 8-1-78 F448 Asbestos 5K04 International Fibers Manville Bldg. Materials J.M Asbestos Sales 6-1-59 to 1-1-80 1-1-80 to 4-1-84 4-1-84 to Present F1423 RG244 ' Union Carbide Metals Div A.T. Callas Alma Products 10-1-70 to 10-1-78 10-1-78 to 1-1-86 1-1-86 to Present E1488 RG144 Union Carbide Metals Div A.T. Callas Alma Products 10-1-70 to 10-1-78 10-1-78 to 1-1-86 1-1-86 to Present I have also been advised that there is an additional firm which Chrysler did purchase Asbestos from# that firm's name is Boehle Chemical Inc. If we can be of any further assistance# please don *t ask. Very truly yours# FJR/26/las PO 80* :-;9. OETROir. Michigan 2S8 D C 5281