Document mp0aYqEgByxr9Gmd8q7yKzwJd

198 1 Sayers 2 when they were dumping the contents of the bags? 3 A. When asked, we did recommend that masks 4 be worn for that small period of time. 5 Q. But if nobody asked you, then you 6 wouldn't recommend it? 7 A. For the pelletized version, no. 8 Q. So in other words ifyou were standing 9 at a paper mill in England in 1965 and '66 and 10 watching an employee dump a bag of pellets into a II hydropulper, you wouldn't volunteer on your own: 12 Hey, he should be wearing a mask? 13 A. No, not in those days. 14 Q. Just so I'm clear, do you ever remember 15 anyone asking you on those occasions in those days 16 whether they ought to wear masks when they were 17 dumping the pellets into the hydropulpers? 18 A. The shop floor worker, you mean? 19 Q. Yes. 20 A. Not to the best of my recollection, but 21 it is a long time ago. 22 Q. Right. How about any ofthe management 23 people at those paper mills, did they ever ask you 24 whether the workers should wear masks when dumping 25 pellets? 200 1 Sayers 2 dust yourself? 3 A. No, 1 did not. 4 Q. So you thought that was a particularly 5 dusty operation? 6 A. That's right. 7 Q. That's why you would not have, ifasked. 8 stated that respirators or masks would be required? 9 A. Yes. 10 Q. Now, on those occasions when you visited II paper mills in England in 1965, '66, did you ever 12 see the pallets of bags of Union Carbide asbestos 13 being unloaded off oftrains, train cars? 14 A. No, because they were never in train 15 cars. 16 Q. How did they arrive at those paper 17 mills? 18 A. They arrived with bags on pallets with 19 the cardboard cover on top. 20 Q. Would they come what, by truck or how 21 would they get to the mill? 22 A. Usually by truck, because at that period 23 of time we were mainly conducting trials. 24 Therefore we were looking at a ton or so of 25 material. 199 1 Sayers 2 A. This topic was discussed with a number 3 of managers; and when asked, the recommendation was 4 made. 5 Q. Just so I'm clear, would you recommend 6 that they wear masks when they were dumping pellets 7 or just when they were dumping non-pelletized? 8 A. There was no question of dumping 9 non-pelletized. It didn't exist in those early 10 days. So it was purely pelletized. II Q. So I'm clear, what was your 12 recommendation with respect to wearing of masks 13 when dumping pellets? 14 A. When asked -- don't forget we had the 15 Demehl report that we were issued -- it was 16 reinforced that a respirator was an ideal 17 protection device to wear. 18 Q. If asked, would you say that it was 19 required that respirators be worn? 20 A. No. The reason for that was looking at 21 the amount of fibrous material in the air, it was 22 very, very low. because they were pellets going. 23 Q. Yes. So when you would stand there. 24 observing people dumping Union Carbide asbestos 25 pellets into hydropulpers. you didn't see a lot of 201 1 Sayers 2 Q. Okay. So just so we're clear, when you 3 say you were conducting trials, they were just 4 doing little trial runs of using the asbestos? 5 A. That's right. 6 Q. This was not full-scale production? 7 A. Later on there were some consistent 8 customers, but predominantly it was still in the 9 trial vogue. 10 Q. Did there come a time ever that you can II recall where a directive was issued by Union 12 Carbide that all of its papermaking customers in 13 England should require all of their employees 14 working in paper mills where Union Carbide asbestos 15 was being used to wear respirators? 16 A. 1 think there was a directive issued. 17 but I'm a bit vague about that. 18 Q. 1 just want to be clear here. Was the 19 directive directed to everybody in the mill or just 20 people dumping bags? 21 A. There was a papermaking association to 22 which the various mills belonged. At one point 1 23 think there was a discussion document issued by 24 that said organization. 25 Q. By that organization? SPHERION DEPOSITION SERVICES (212)490-3430 51 (Pages 198(0 201)