Document kD09BJNgoGwDqJ0R4RE9ojjEy

90 1 Sayers 2 A. I'm manager of the advanced concepts 3 group. 4 Q. What does the advanced concept group do? 5 A. In layman's terms it's really a blue 6 skies group, charged with finding new products for 7 our existing markets and developing processes to 8 make those products. 9 Q. Is it somewhat of an R&D department? 10 A. It's very much R&D throughout. II Q. You said you're the manager. Do you 12 have -- can you tell me what facilities are under 13 your control? What do you have? 14 A. Yes. 1 have 14 staff, and we have a 15 very large laboratory on the Blackburn site. 16 Q. Do you hold any patents? 17 A. Yes, 1 do, on the order of 20. 18 Q. Is that in the U.K. or where is that? 19 A. They're usually global patents. 20 Q. Do any of those have anything to do with 21 asbestos? 22 A. Nothing whatsoever. 23 Q. Have you or Scapa won any awards since 24 you've been there? 25 A. Yes. We developed a product called 92 1 Sayers 2 you were at Scapa, what division or area were you 3 working in? 4 A. I was initially marketing paper machine 5 clothing product. 1 then moved on to their 6 filtration division, became technical manager 7 there. I then moved off to France to open up a 8 making up unit for filters. 9 Q. Since you joined Scapa have you had any 10 exposure to asbestos? II A. Yes. After the French experience I came 12 back and spent two years selling paper machine or 13 asbestos/cement machine clothing. 14 Q. When you say "clothing," what is that? 15 A. These are large fabrics that run around 16 a board machine upon which cement/asbestos mix is 17 deposited and dried. 18 Q. What kind of product is made on these 19 machines? 20 A. Roofing materials, wall materials. 21 Q. Was the clothing that Scapa made itself. 22 did that have any asbestos in it? 23 A. No. It was made of nylon. 24 Q. Where did you get the asbestos exposure. 25 then? 91 1 Sayers 2 Spectra Membrane for which we got the Queen'S award 3 for Industry for Technology in 1997. 4 Q. For those of us who don't know in the 5 U.S.. can you explain a little bit about what the 6 Queen'S award for Technology is? 7 A. Well, it's ah award bestowed upon a very 8 limited number of companies per year, either for 9 export achievement, technological development or 10 environmental work. II Q. Had you worked on the project that won 12 the award? 13 A. Yes. 14 Q. Now', when you joined Scapa in 1969. did 15 they have any involvement with asbestos? 16 A. Yes. they did. They were still weaving 17 quantities ofasbestos as the weft in dry fabrics. 18 Q. Were you personally involved with 19 that -- let me back up a second. Is that an 20 asbestos-containing yarn? 21 A. Asbestos-containing yam. that's right. 22 Q. Did you personally have any involvement 23 with that product line? 24 A. No. 1 just observed the fact. 25 Q. Then for the first ten years or so when 93 1 Sayers .. 2 A. Simply by visiting asbestos/cement .mills 3 in the world. 4 Q. Where were those mills? 5 A. Some in the U.K., an awful lot on the 6 north African coast. Middle East, Indonesia, 7 Malaysia and Australia. 8 Q. What were the conditions like that you 9 observed in those mills? 10 A. In some of the mills, horrible. II Q. Horrible in what respect? 12 A. The air float material was enormous. 13 Q. What types of asbestos fibers w ere being 14 used in the products made on those machines? 15 A. Either crocidolite or chrysolite, but 16 not Coalinga. 17 Q. Just before Union Carbide shifted the 18 marketing of asbestos to Degussa, were you involved 19 in any marketing or last marketing efforts? 20 A. Yes. The major marketing effort was the 21 preparation of a mail shot that was going to be 22 sent to selected clients around Europe. 23 Q. And what was the mail shot? What was 24 that? 25 A. Essentially it w as a brochure which was SPHERION DEPOSITION SERVICES (212)490-3430 24 (Pages 90 lo 93)