Document jyp5dxjgJOK7LoNBJvLXKpJ6R

50 1 Sayers 2 MR. BROWNSON: Objection, hearsay. J MR. LANIER: Objection to form. 4 A. No, that wasn't the case. 5 Q. As you perceived it, what was the 6 perception about asbestos at that time? 7 A. Well, it was a useful material, and it 8 was the health hazard part that was really causing 9 the problem. There was a lot of utility in that 10 material. II Q. So given the utility, what were people 12 trying to do, as you perceived it? 13 A. They were trying to use it in a safer 14 manner. 15 Q. Were they trying to find ways in which 16 it could continue to be used? 17 MR. LANIER: Objection to form. 18 A. Oh, definitely, yes. 19 Q. Now, in your report you talk about lung 20 cancer; is that correct? 21 A. Yes. 22 Q. If you look at page 11, you have a Table 23 I there. 24 A. Yes. 25 Q. That reports on a certain number of 52 1 Sayers 2 A. That's right. 3 Q. Mr. Sayers, what were the years involved 4 in the deaths that were reported at Table 1? 5 A. 1924 to'64. 6 Q. Was Union Carbide selling asbestos in 7 Great Britain at that time? 8 A. 1 don't think any material was sold 9 during '64. 10 Q. At page 5 of your report you indicate II there were 500 cases of cancer of the lung and 12 mesothelioma; correct? 13 A. Yes. 14 Q. Do you know how many of those were lung 15 cancer and how many were mesothelioma? 16 A. No. There wasn't a breakdown, to my 17 recollection. 18 Q. And in the discussions that you had with 19 people and the materials that you read, was there 20 any proposal to ban asbestos in England because of 21 a lung cancer risk? 22 A. No. 23 Q. You also in your report discuss the 24 disease of mesothelioma; is that correct? 25 A. Yes. 51 1 Sayers 2 deaths where asbestosis was present? 3 A. Yes. 4 Q. And a certain number where there was 5 asbestosis and lung cancer? 6 A. Yes. 7 Q. Did you give any information in your 8 report about examples where there was lung cancer 9 without asbestosis? 10 A. No. II Q. Was there anything in your report about 12 how many of the cases of lung cancer involve 13 smokers? 14 A. No. 15 Q. Or involve exposure to other materials 16 that may have caused cancer? 17 A. That data wasn't available. 18 Q. Were any of these individuals in the 19 lung cancer table, would any of them have been 20 exposed to Calidria? 21 A. Certainly not. The time wasn't right. 22 Q. These were people in the U.K. before 23 Union Carbide began selling? 24 MR. POLK: Objection to form. 25 MR. LANIER: Objection to form. 53 1 Sayers 2 Q. I'd like to have you turn to page J1 of 3 your report, paragraph 4.4.1. Do you see that? 4 A. 1 do. 5 Q. That's titled "occurrence of disease"; 6 is that right? 7 A. Yes, that's right. 8 Q. The report states, "Mesothelioma is the 9 most disturbing of the three diseases attributable 10 to asbestos for two reasons. Firstly, in contrast II to bronchial carcinoma it can occur in people with 12 minimal fibrosis, i.e. only after a brief exposure 13 which may be as little as three months. Some 14 authorities even believe that a single brief 15 exposure might be sufficient." 16 Did 1 read that correctly? 17 A. You did. 18 Q. What was the source of the information 19 that you used to put in that paragraph? 20 A. It came from the pneumoconiosis research 21 establishment. 22 Q. Also other things you had read? 23 MR. LANIER: Objection to form. 24 A. Yes, but mainly from the PRU. 25 0- Did you have an opinion on whether or SPHERION DEPOSITION SERVICES (212)490-3430 14 (Pages 50 to 53)