Document geKv9EY3D6xp977ME3xZg06a

290 1 Sayers 2 that are more harmful than the larger particles. 3 anything like that? 4 A. There were clearly references to that in 5 some of the literature, yes. 6 Q. Did some of the literature that you 7 review involve animal studies? 8 . A. Almost certainly, yes. 9 Q. Was there anything about the animal 10 studies that you picked up on that caused you to II disregard those studies? 12 A. It's too long ago to remember the 13 details. 14 Q. Were you under the impression when you 15 started at Union Carbide that this product was 16 pelletized for purposes of keeping dust to a 17 minimum? 18 A. Two purposes: to minimize the freight 19 rate and also to minimize dust. 20 Q. Who told you that? 21 A. 1 think 1 just absorbed it as general 22 knowledge. 23 Q. Did Dr. Hall ever tell you that? 24 A. My involvement with Dr. Hall was two 25 years down the track. 292 1 Sayers 2 A. Yes. 3 Q. You understood that it was sanded also? 4 A. Yes. 5 Q. You understood that on occasion it was 6 punched; correct? 7 A. Yes. 8 Q. Did you know that those processes 9 created dust? 10 A. Yes. II Q. Do you have any information that leads 12 you one way or another to believe that the 13 pelletized asbestos was any less dusty during those 14 processes than open fiber? 15 A. No, because liberation had taken place 16 at the commencement of the process. 17 Q. Thank you. 18 Can you tell me the first time that 19 Union Carbide ever put any type of warning language 20 on any of the containers of Union Carbide asbestos? 21 A. During my day they hadn't. 22 Q. Do you know -- again, after the fact, do 23 you know when that was first done? 24 A. No, I don't. 25 Q. Can you imagine, based on your 291 1 Sayers 2 Q. Let me ask you this: Is it possible 3 that Union Carbide's internal position or the 4 understanding that you came to that one of the 5 reasons for pelletizing this product was to 6 minimize the dust, do you believe that it's 7 possible that that was an afterthought? 8 MR. WILL: Objection, speculation. 9 A. I have no idea. 10 Q. No idea. Okay. 11 Would you agree with me that whether 12 it's pelletized or in open form would have little 13 difference once the particular process had been 14 completed, either in the papermaking or board or 15 ceiling tile making process when it came to 16 sanding, cutting, punching and otherwise 17 manipulating the final product? 18 A. Well, in paper per se the chances of 19 release of material was very low in paper. 20 Q. All right. Let's exclude paper, then. 21 Let's just talk about ceiling tile and ceiling 22 board; okay? Did you understand that the ceiling 23 board and ceiling tile was cut afterwards? 24 A. I'm familiar with that process. 25 Q. You understand the process. 293 1 Sayers 2 education, training and experience, of any reason. 3 possible reason, for Union Carbide to have put any 4 warning on any of the containers of Calidria 5 asbestos prior to the time that you left Union 6 Carbide? 7 A. Reason why? 8 Q. No, can you think of any reason why 9 Union Carbide should have put a warning on any 10 container of Calidria asbestos before you left in II 1969? 12 A. That's a subjective question. 13 Q. Yes, it is, and 1 want your subjective 14 answer, please. 15 A. That was really up to the managers 16 involved. 17 Q. 1 understand that. 18 If you were being exposed to Calidria 19 asbestos in 1969 on a daily basis in a ceiling tile 20 plant, would you have appreciated knowing 21 information that was consistent with your 1967 22 report? 23 MR. WILL: Object to the form of the 24 question. 25 Q. If you were the one being exposed. SPHER10N DEPOSITION SERVICES 74 (Pages 290 to 293)