Document jmVvLkgrzye9X88BzzZXreBZN

1 (d) Review governmental publications of Great Britain to determine whether the Chief Inspector of Factories or any 2 other British Government agency had issued any regulations or published any findings relative to potential health hazards 3 incident to the use of products containing asbestos. 4 RESPONSE TO INTERROGATORY NO. 55: 5 No, to the best of Wagner's knowledge. 6 INTERROGATORY NO. 56: 7 Has the defendant sponsored, since 1930, any meetings, seminars, conferences, or conventions where the subject of occu 8 pational health and/or exposure to asbestos was discussed? 9 RESPONSE TO INTERROGATORY NO. 56: 10 In its training meetings prior to 1976, instructions 11 on using Wagner products m a manner to avoid exposure to dust 12 were discussed as an incident to stressing the desirability of a 13 clean working environment. In the schools held m 1976 through * 14 the present, minimization of dust creation was discussed in 15 regard to minimizing the workers' potential exposure to free 16 asbestos fiber. 17 INTERROGATORY NO. 57: 18 If the answer to Interrogatory No. 56 is in the affir mative, please state: 19 (a) The date and place of such meeting, seminar, 20 conference or convention; 21 (b) The name and address of the speakers. 22 RESPONSE TO INTERROGATORY NO. 57: 23 Wagner objects to this Interrogatory on the grounds 24 that it is overly broad, unduly burdensome and not calculated to 25 lead to the discovery of admissible evidence. 26 INTERROGATORY NO. 58: 27 Has the defendant ever warned any labor union or its representative of the potential health hazards associated with 28 the use of products containing asbestos? 25