Document jyzB0aXOYeo1gzrBR7zdGvjMR

K8895DIA058 (e) Describe the nature of said study; (f) Describe the nature of any action to eliminate or minimize inhalation of asbestos dust or asbestos fibers undertaken as a result of said study; (g) Identify any and all documents referring to, relating to or reflecting said study or the results thereof; and, (h) Identify any and all persons receiving a copy of any document referring to, relating to or reflecting the results or conclusions of said study. ANSWER TO INTERROGATORY 62. Not applicable. INTERROGATORY NO. 63: Did Defendant, any related company, or any predecessor at any time, give to persons, who would be applying and/or removing any ofthe products listed in response to Interrogatory Nos. 19 and 42, any instructions or guidelines concerning precautions, warnings, procedures, and/or methods to use, in order to safely apply or remove such products? If so, describe such instructions, state to whom they were given, state the dates they were given, and describe the manner in which they were given. ANSWER TO INTERROGATORY 63. Borg-Wamer answers that while the asbestos content within components of its products creates no health risk, a caution label was included for a short period on certain containers of manual clutch products at the request of a customer. The "caution" label is believed to have been initiated in 1986 for a brief period that year on asbestos-bearing manual clutch assemblies. INTERROGATORY NO. 64: Did Defendant, any predecessor or any related company, at any time, place any warning signs or labels on the containers in which any of the products listed in response to Interrogatory Nos. 19 and 42 were packaged? ANSWER TO INTERROGATORY 64, See answer to interrogatory 63. INTERROGATORY NO. 65: If your answer to Interrogatory No. 64 is "Yes," identify each and every product upon which such a warning was placed, and with respect to each such product identified: (a) State the date on which any order directing that a warning be placed on said product first issued; (b) Identify any and all persons participating in the decision to issue that