Document mrVKXRmYEJebX2mBd9oa8nVB

5 PLAINTIFF'S;|||` iW-t EXHIBIT 4 .... NOV - s IN RE: ASBESTOS NO. LITIGATION 94-CI--10078 . --v r;> 'v._-1 v S IN THE DISTRICT COURTS OF S S BEXAR COUNTY/ TEXAS VERIFICATION OF DEFENDANTS' OBJECTIONS, ANSWERS AND RESPONSES TO MASTER INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO: Plaintiffs in Bexar County, . Texas, by and through their attorneys of record, Baron & Budd, A Professional Corporation, The Centrum, 3102 Oak Lawn Avenue, Suite 1100, Dallas, Texas 75219. COME NOW, - Gar lock Inc and The Anchor Packing Company, Defendants herein and by and through their counsel of record, file the attached Verifications of their Objections, Answers and Responses to Master Set of Interrogatories and Request For Production of Documents. Respectfully submitted, BROWN McCARROLL & OAKS HARTLINE, A REGISTERED LIMITED LIABILITY PARTNERSHIP ATTORNEY IN CHARGE T. JOHN WARD STATE BAR NO. 20848000 WALTER CLAY COOKE STATE" BAR NO. 04759800 MELISSA K. FERRELL STATE BAR NO. 06937020 1300 Wortham Tower 2727 Allen Parkway Houston, Texas 77019-2100 Phone: (713) 529-3110 Fax: (713) 525-6295 ATTORNEYS FOR DEFENDANTS GARLOCK INC AND THE ANCHOR PACKING COMPANY Certificate of Service I hereby certify that a true and correct copy of the above and foregoing instrument was sent by certified mail, return receipt requested, to counsel for Plaintiffs and by regular mail to all other counsel of record on the day of November, 1994. .'//// //Li i r ? {'( Mr. Russell W. Budd BARON & BUDD 3102 Oak Lawn Avenue Suite 1100 Dallas, Texas 75219-4257 ATTORNEYS FOR PLAINTIFFS K:\PS\QARLOCK\53019.I 991.70736 1 STATE OF NEW YORK COUNTY OF NEW YORK I hereby certify that I am authorized to respond to these interrogatories and requests for production on behalf of Gariock Inc in my capacity as Assistant Secretary and that to the extent that I am personally familiar with the information set forth in the answers, I certify that the answers are correct, and to the extent that I am not personally familiar with the information provided in the said answers, I certify that the information is correct to the best of my information and belief based on my investigation of these matters. DONALD E. O Sworn to and subscribed before me this A 9 day of Cl . 1994 NOTARY PUBLIC State of New York My commission expires .. VERONICA McCARTAN Nota/y Public. Slate of New Vorit ___ rr31:7794225 UuMhod m New York County ^Ofnmtsaon Expires Aug. 31. iggg Bexar County, Texas STATE OF NEW YORK COUNTY OF NEW YORK I hereby certify that I am authorized to respond to these interrogatories and requests for production of documents on behalf of The Anchor Packing Company in my capacity as Assistant Secretary and that to the extent that I am personally familiar with the information set forth in the answers, I certify that the answers are correct, and to the extent that I am not personally familiar with the information provided in the said answers, I certify that the information is correct to the best of my information and belief based on my investigation of these matters. $ OSworn to and subscribed before me this g? day of C/?TO4 O NOTARY PUBLIC State of New York My commission expires Trnvia County, Tokens (1st Amended) t RECEIVED OCT 311934 NO. 94-CI-10078 BARON & BUDD IN RE: ASBESTOS LITIGATION IN THE DISTRICT COURTS OF BEXAR COUNTY/ TEXAS GARLOCK INC'S ANSWERS TO MASTER INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO: Plaintiffs in Bexar County,,, Texas, by and through their attorneys of record, Baron & Budd, A Professional Corporation, The Centrum, 3102 Oak Lawn Avenue, Suite 1100, Dallas, Texas 75219. Pursuant to the Texas Rules of Civil Procedure, Defendant Garlock Inc ("Garlock") answers Interrogatories propounded by Baron & Budd as per the attached. Respectfully submitted, BROWN McCARROLL & BY: STATE BAR NO. 07300100 ,,ATTORNEY IN CHARGE T. JOHN WARD STATE BAR NO. 20848000 WALTER CLAY COOKE STATE BAR NO. 04759800 MELISSA K. FERRELL STATE BAR NO. 06937020 1300 Wortham Tower 2727 Allen Parkway Houston, Texas 77019-2100 Phone: (713) 529-3110 Fax: (713) 525-6295 ATTORNEYS FOR DEFENDANT GARLOCK INC CERTIFICATE OF SERVICE This is to certify that a true and correct copy of foregoing has been served on counsel of record this ________, 1994. above and day of GENERAL OBJECTIONS Garlock makes the following general objections to plaintiffs' interrogatories and incorporates each of these objections by reference to every answer provided hereafter. 1. The interrogatories request information going back many years and Garlock has found it difficult, if not impossible, to reconstruct or retrieve much of the information requested. The answers given are based .on the present facts known or believed by Garlock at the time of its answer. 2. The interrogatories are overly broad, burdensome, and in places, vague and ambiguous. In addition, the interrogatories are not sufficiently limited in time and use terms which do not refer to products manufactured by Garlock.. 3. Garlock does not now manufacture or sell, and has never manufactured or sold, asbestos-containing insulation products as that term is commonly used and understood in this litigation. Therefore, Garlock objects to any interrogatoryreferring to or assuming that such products are or have been manufactured by Garlock. Garlock presumes that questions referring to insulation products are thus not applicable to Garlock. 4. Garlock" does not now manufacture or sell, and' has never manufactured or sold, asbestos-containing building products as that term is commonly used and understood in this litigation. Therefore, Garlock objects to any interrogatory referring to or assuming that such products are or have been manufactured by Garlock. Garlock presumes that questions referring to building products are thus not applicable to Garlock. 5. The interrogatories themselves are overly broad in that they tend to group together all of the defendants. There has never been any competent scientific or medical evidence or reason to believe that Garlock products, upon reasonable use, release asbestos fibers in sufficient quantities, if any, to pose a health hazard, potential or otherwise, to persons using said products. Garlock denies that the use of, or exposure to, its asbestos-containing products poses any health hazard. Furthermore, the plaintiff's alleged problems are not related to Garlock products. 3 INTERROGATORIES INTERROGATORY NO. 1 : State the name, address, job title, length of time employed by Defendant, and a year-by-year list of all other positions, titles, or jobs held when working for Defendant of each person who has supplied any information used in answering these interrogatories. ANSWSB: Garlock objects to this interrogatory on the grounds that it is unduly burdensome, unnecessary and harassing. Subject to and without waiving the foregoing objections, Garlock states that the information used to answer these interrogatories was gathered from answers to interrogatories previously filed in this and other jurisdictions over the last several years and involved obtaining and confirming information " from many present -and former employees. The names of the individuals who provided information include: Clayton M. Jewett, formerly Manager of Marketing - Gasket Products, Garlock Inc, Reno, Nevada, Roy L. Whittaker, Director, Engineering, Industrial Packing, Garlock Inc, 1666 Division Street, Palmyra, New York 14522 and Richard W. Watson, former Paralegal and Patent Agent, c/o 1666 Division Street, Palmyra, New York 14522. INTRRQgAT9RY-NP. 2: . State whether or not you are a corporation. If so, state your correct corporate name, the state of your incorporation, the address of your principal place of business, the name and address 4 of the person or entity authorized to accept service of process on your behalf, and whether or not you have ever held a Certificate of Authority to do business in the State of Texas. Defendant's legal name is Garlock Inc (no punctuation). Garlock.Inc is an Ohio corporation with offices located at 4 30 Park Avenue, New York, New York 10022 and a principal manufacturing facility and sales office at 1666 Division Street, Palmyra, New York 14522. CT Corporation System is the entity authorized to accept service of process on behalf of Garlock. Garlock does hold a Certificate of Authority to do business in the State of Texas. INTERROGATORY NO. 3: Has Defendant or any of its predecessor or ' subsidiary companies at any time engaged in the mining and subsequent sale of material containing asbestos fibers? If so, identify the location of the mine(s) , the years of its operation, the type of asbestos mined and whether you sold any asbestos to any Defendants in the Dallas County asbestos litigation. ANSWER: No. INTERROGATORY NO. 4: Identify by name each product containing asbestos fibers that Defendant or any of its predecessor or subsidiary companies at any time manufactured or sold. 5 ANSWER: Garlock objects to this interrogatory for the reasons set forth in General Objections Nos. 1 and 2, which are incorporated as if they were fully set out herein, and.for the further reason that the only Garlock products at issue in this case are those to which plaintiffs allege to have been exposed. To require Garlock to identify the hundreds of different products it has produced over the years constitutes a request for masses of irrelevant information, is unduly burdensome and beyond the scope of permissible discovery. Notwithstanding and without waiving the foregoing objections, since at least as early as 1907, Garlock has produced and sold encapsulated asbestos-containing gaskets and packing products which do not emit asbestos fibers into the air when in operation. Garlock has not been a manufacturer or seller of asbestos thermal insulation, such as pipe covering, block or cement. The great majority of products which Garlock has manufactured are gaskets and ' compressed asbestos sheet, packing and other gasket materials. Garlock compressed asbestos sheet is a mixture of asbestos fiber, curing agents, reinforcing fillers and elastomers (natural rubber or synthetic polymers having the elastic qualities of rubber). Other gasket material was made from woven asbestos impregnated and encased in a rubberized coating. Other gaskets have had asbestos encased by layers of metal or encapsulated within a P.T.F.E. (polytetrafluoroethylene) resin envelope. Manufacture and sale of such other gasket products has been 6 discontinued, mostly during the decade of the 1980's. Garlock once manufactured and sold, but has now discontinued, asbestos packing encapsulated in either elastomeric compound or metal foils and/or impregnated with .lubricants. Garlock believes its last such packing sale was in approximately 1982. ICT.ERE-QSATQRY * . Identify by name each product containing asbestos fibers that Defendant or any of its predecessor or subsidiary companies at any time marketed or sold. ANSWER: See Answer.to Interrogatory No. 4. - INTERRQffATQRY _NQ,_6: If the a-nswer to one or more of the last three interrogatories is in the affirmative or lists any products, state as to each named product the following: A. As to each product, state whether such product was mined, manufactured, marketed, and/or sold. B. The names of the companies mining, manufacturing, marketing, and/or selling each product mined, manufactured, marketed, and/or sold. C. The trade or brand name of each of those products mined, manufactured, marketed and/or sold. D. The date each of the named products was placed on the market. 7 E. A description of the physical (chemical) composition of each of the named products, including the type of asbestos contained in the product and the percentage of asbestos put in each product. . F. The date each of the products was removed from the market and no longer sold or distributed and the reason or reasons therefor. G. The date asbestos was removed from such products, if ever, and the reasons therefor. H. A description of the physical appearance of each of the named products. I. A detailed description of the intended uses of the named products. J. Identify the last year that you sold each asbestos- cofttaining product. ANSWER; Garlock objects to this interrogatory for the reasons set forth in General Objections -Nos. 1 and 2, which are incorporated as if they were fully set out herein, and for the further reason that the only Gar lock products at issue in this case are those to which plaintiffs allege to have been exposed. To require Garlock to identify the hundreds of different products it has produced over the years constitutes a request for masses of irrelevant information, is unduly burdensome and beyond the scope of permissible discovery. Garlock further objects to this interrogatory to the extent it calls for production of proprietary information. Garlock will 8 produce this information if a proper protective order is entered by this Court. Notwithstanding and without waiving the foregoing objections, Garlock states that it has and does make a wide variety of products., many of which have contained asbestos and many of which have contained no asbestos. Among the specific products which Garlock has and does manufacture are asbestos gasket and asbestos sheet (from which the purchaser cuts gaskets). Garlock asbestos sheet is a mixture of asbestos fibers, curing agents, reinforcing fillers and elastomers (natural rubber or synthetic polymers having the elastic qualities of rubber). Asbestos fibers are machine blended with the rest of the mixture until they are thoroughly coated. The entire compound is then heated and rolled into sheets and is continually compressed to form a tough, impermeable, homogeneous material that looks like linoleum. Other gasket materials were made from woven, long fiber, asbestos yarn impregnated and encased in a rubberized coating. Other gaskets have had asbestos encased by layers of metal or encapsulated with a P.T.F.E. (polytetrafluoroethylene) resin envelope. Garlock asbestos packing materials consisted of woven asbestos encapsulated in either elastomeric compounds or metal foils and/or impregnated with lubricants. Garlock gasket materials are primarily used for static sealing of steam line flanges, cylinder heads of engines, compressors and refrigeration equipment, fluid conduits, etc. Garlock packing materials are primarily used for dynamic sealing of machinery. 9 Finished compressed asbestos sheet is either cut into gaskets by Garlock or sold for use by others in cutting gaskets. Garlock's flexible and durable gasketing material is handled, installed and removed in all intended applications without releasing meaningful quantities, if any, of asbestos fibers into the air. Garlock's compressed asbestos sheets and gaskets are treated with an anti-stick releasing agent which reduces any tendency of the gaskets to adhere to pipe flanges during removal and replacement. This anti-stick agent facilitates the removal of old gaskets without generating dust. Other Garlock products come in specific sizes for application and do not generally require modification before or during application or use. Garlock states that from 95% to 98% of its asbestos-containing products have been made only with chrysotile asbestos fibers and that the remaining 2% to 5% of such products were made with crocidolite asbestos fiber. Depending upon the type of product involved, the percentage of asbestos contained in these products has ranged from about 10% to about 85%. This Defendant has never mined, supplied, distributed, marketed and/or sold raw asbestos fibers to others. IKTERR9gAT9RY..yQt 7: Do any documents, including but not limited to written memoranda, specifications, recommendations, blueprints, or other written materials of any kind or character, relating to the design, 10 preparation, or introduction into the market of the products listed in Interrogatory No. 6 still exist? if so, state: A. A description of each such document. B. The name, address, and job title of each person who currently has possession of each document, and where the documents are currently located. ANSWER: Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, oppressive and not reasonably calculated to lead to the discovery of admissible evidence and for the further reason that the only products at issue in this case are those to which plaintiff alleges to have been exposed. Notwithstanding and without waiving the foregoing objections, Garlock states that the design and/or development of new products and the improvement of existing Garlock products has been the responsibility of the technical staff involved in each particular project. All relevant, discoverable documents are available for inspection and copying at Garlock's offices: 1666 Division Street, Palmyra, New York 14522. INTERROGATORY NO. 8: Before distributing, selling, or placing the products listed in your response to Interrogatory Nos. 3-6 into the streams of commerce, were any tests conducted to determine potential health hazards involved in the use of, or exposure to, the materials such 11 as asbestos, contained in those products? affirmative, state: If the answer is A. The names of the products tested and the date of each test. _ . B. The name, address, and job title of each person conducting the tests or involved with conducting the tests. C. The results of the tests. MSWEB: Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and for the further reason that it presupposes that the asbestos-containing products of Garlock emit dust at levels harmful to the human body. Notwithstanding and without waiving the foregoing objections, Garlock "states that it is unaware of any investigations, tests, examinations or experiments concerning the asbestos- containing products of Garlock and any effect thereof on the human body. '' IMTERROgATfiBY FOt ?: Do any documents, including but not limited to written memoranda, specifications, recommendations, blueprints, or other written materials of any kind or character, relating to the testing of the products referred to in Interrogatory No. 6 now exist? If so, state: A. A description of each such document. 12 B. The name, address, and job title of each person who currently has possession of each document, and where it is presently located. ANSWER; _ Garlock objects to the extent this Interrogatory seeks information which is neither relevant nor likely to lead to the discovery of relevant evidence. The only products relevant are the ones the Plaintiffs are claiming exposure to. Garlock also objects to the interrogatory as overly broad and vague. Subject to and without waiving any of the foregoing objections, see Answers to Interrogatories Nos. 8 and 56. IEEERRQQATQRY NQ, 12: Did Defendant or any of its predecessor or subsidiary companies make any design changes or modifications as a result of those tests described in responses to Interrogatory No. 8? If the answer is affirmative, state; A. The trade names of the products changed. B. The nature of the changes made and the date of such changes or modifications. C. The name, address, and job title or each person responsible for having caused a change to be made, or having made a change or modification. MSWEE: Not Applicable. See Answer to Interrogatory No. 8. 13 INTERROGATORY NO, 11: After releasing the products listed in Interrogatory No. 6 to the public, were any tests conducted on them to determine potential health hazards resulting from the use of or exposure .to the materials, such as asbestos, contained in those products? If the answer is affirmative, state: A. The names of the products tested and the dates of such tests. B. The name, address, and job title of each person who conducted those tests. C. The results of those tests. D. Whether, as a result of the tests, any products were removed from the market. E. The names of all products removed from the market as a result of these tests. ANSWER: * Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and for the further reason that it presupposes that the asbestos-containing products of Gar lock emit dust at levels harmful to the human body. Notwithstanding and without waiving the foregoing objections, Garlock states that it is unaware of any investigations, tests, examinations or experiments concerning the asbestos- containing products of Garlock and any effect thereof on the human body. > 14 INTERROGATORY NO. 12: Do any documents, including written memoranda, specifications, recommendations, blueprints, or other written materials of any kind or character, relating to the potential health hazards of the products listed in Interrogatory No. 6 now exist? If so, state: A. The name of each product. B. A description of each document and how it relates to each product. C. The name, address, and job title of each person who currently has possession of each document, and where it is presently located. ANSWER: - Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and for the further reason that it'presupposes that the asbestos-containing products of Gar lock emit dust at levels harmful to the human body. Notwithstanding and without waiving the foregoing objections, Garlock states that it is unaware of any investigations, tests, examinations or experiments concerning the asbestos- containing products of Garlock and any effect thereof on the human body. INTERROGATORY NO. 13: Did Defendant or any of its subsidiary companies make any design changes as a result of the tests discussed in your response to Interrogatories No. 8 or 11? If the answer is affirmative, state: 15 A. The names of the products changed or modified. B. The name, address, and job title of each person responsible for having made a change or modification. C. The nature of the hazard or defect which resulted*in such change or modification. Mg WEB: _ Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and for the further reason that it presupposes that the asbestos-containing products of Garlock emit dust at levels harmful to the human body. Notwithstanding and without waiving the foregoing objections, Garlock states that it is unaware of any investigations, tests, examinations or experiments concerning the asbestos- containing products of Garlock and any effect thereof on the human body. lEQlEftBP.gAlPRY.. NP-t.. 14: Has Defendant or any of its' predecessor or subsidiary companies at any time published or distributed any printed material, including brochures, pamphlets, catalogs, packaging or other written material or any kind or character containing any warnings concerning the possibility of injury resulting from the use of the asbestos-containing products listed in Interrogatory No. 6? If so, state: A. The names of each relevant product. B. The exact wording of each warning statement on each printed material. 16 C. A description of the printed material other than the warning statement. D. The method used to distribute the warning to persons likely to use the product. E. The date each warning was first issued, distributed, or placed on packaging. F. The name, address, and job title of each person responsible for having drafted or issued the warning. G. The current location of any such printed material and the custodian thereof. H. The form in which such literature or printed material can be accessed, i,e., the manner in which such literature is indexed or stored. 5: . Garlock^ objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and assumes the truth of matters in dispute in this litigation, specifically that there are dangers associated with - the use of Garlock products. Notwithstanding and without waiving the foregoing objections, Garlock states that there has never been any competent scientific or medical evidence or reason to believe that its asbestos-containing products, upon reasonable use, release asbestos fibers in sufficient quantities, if any, to pose a health hazard, potential or otherwise, to persons using 6uch products. Garlock denies that use of, or exposure to, its asbestos-containing products poses any health hazard, or any significant possibility of inhalation of asbestos fibers. The 17 asbestos fibers in Garlock products are encapsulated or otherwise retained, and, therefore, fall within the exception provided in the OSHA regulations requiring warnings on asbestos products and materials.. Nevertheless, Garlock places the warning set forth in section 1910.1001, paragraph 2(ii) of the OSHA regulations on its asbestos-containing products. The name of the person who formulated this warning is not known. The warning reads: "CAUTION: Contains Asbestos fibers. Avoid creating dust. Breathing Asbestos dust may cause serious bodily harm." This warning has been present on all Garlock asbestos-containing products and/or the product packaging since late 1977. A similar warning notice has been contained in product literature published since 1977 that describes one or more asbestos-containing products. See attached Exhibit "A". All relevant discoverable printed material is available for inspection and copying at Plaintiffs expense at Garlock's offices: 1666 Division street. Palmyra, New York 14522. ` INTERROGATORY NO. 15: Before 1970, had you received notice that any individual or individuals, other than those Plaintiffs who have filed personal injury actions in Dallas County, Texas, is or are claiming or has or have claimed an injury as a result of using asbestos products manufactured and/or sold by your company or any of its predecessors or subsidiaries before 1970? If so, state: A. The name and address of each claimant. 18 B. The date of notice of each claim. C. A description of the claim. D. The type of injuries allegedly sustained. E. The name and address of each attorney who represents each individual making a claim. F. The style and court number of each claim. G. The disposition of each claim that has been settled or taken to judgment. . ANSWER: Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and that the information sought is irrelevant in this case and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the foregoing objections. Garlock states that it had "no such personal injury claims alleging asbestos- related disease or injury based on product handling or use before 1970. INTERROGATORY NO. 16: Were your asbestos products distributed, marketed, packaged, labeled and/or sold by companies other than your own? If the answer is affirmative, list the names and addresses of each of those companies, and the products in question. ANSWER: Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, does not call for relevant evidence and is not calculated to lead to the discovery of 19 admissible evidence and the further reason that the only garlock products at issue in this case are those to which plaintiff alleges to have been exposed. Notwithstanding and without waiving the foregoing objections, Garlock states that most of its product sales were on a direct basis until the mid-1960's. At that time, the decision was made to utilize distributors for sales to maintenance and repair customers and after a conversion period of several years, the majority of Garlock product sales were made through distributors. Garlock has continued to sell directly to original equipment manufacturers who use Garlock products in making their products. A listing of Garlock distributors in Texas is attached as Exhibit "B". Garlock'does not have records of its direct sales prior to the utilization of distributors nor of sales by its distributors to specific customers. INTERROGATORY NO. 17: Did you or any of your predecessors, successors, or subsidiaries have any distributors or sales representatives of asbestos products in the States of Alabama, Florida, Mississippi, Oregon, Washington, Georgia, Tennessee, Texas, and Virginia? If so, state: A. The name and address of each such distributor or sales representatives. 20 B. The years in which such company or person distributed, marketed, or sold your products. C. What products were distributed, marketed, or sold and in . what years. ANSWER: Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, does not call for relevant evidence and is not calculated to lead to the discovery of admissible evidence and the further reason that the only Garlock products at issue in this case are those to which plaintiff alleges to have been exposed. Garlock further objects to this request, with respect to its reference to the States of Alabama, Florida, Mississippi, Oregon, Washington, Georgia, Tennessee and Virginia, on the grounds that it is overly "broad, unduly burdensome, irrelevant to any issue in this case and not reasonably calculated to lead to the discovery of admissible evidence. With respect to its reference to Texas, Garlock also objects on the grounds that it is overly broad, unduly burdensome, irrelevant to any issue in this case and not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding and without waiving the foregoing objections, Garlock states that it did have sales representatives responsible for different portions of Texas (see Exhibit "BM, and answer to Interrogatory No. 16) . Upon receipt of specific information from the plaintiffs as to the time periods and specific locations at issue. 21 Garlock will attempt to review available records in order to provide a more specific response. Discovery is continuing. INTERROGATORY_NO,- 18: _ . List each employee (including only physicians and/or hygienists) who has acted in a medical advisory capacity to your company at any time during the past 40 years, including, but not limited to, physicians and industrial hygienists, and the current address, telephone number and job title of each of those individuals and who has, had or may have had any knowledge regarding the hazards of asbestos. AESWEB: Garlock has not employed, retained or otherwise engaged physicians, industrial hygienists or others to conduct medical research. Garlock has had six part-time plant physicians since 1920. They are as follows: Name Dates of Service Dr. C. C. Nesbitt (deceased) ' * 8/30/20 - 8/ 1/56 Dr. J. D. Bramer (deceased) Dr. K. K. Kapur 1269 Pittsford Palmyra Road Macedon, New York 14502 Dr. William G. Fallon 602 7th Street Liverpool, New York 13088 8/ 1/56 - 7/24/72 10/23/72 - 8/14/79 10/31/79 - 3/ 1/88 Dr. B. Maureen Merritt P. 0. Box 477 Celoron, New York 14720 9/15/88 - 8/28/90 22 Dr. Tillman F. Farley Garlock Inc 1666 Division Street Palmyra, New York 14522 10/9/90 to Present All of these physicians served, on a part-time basis and were at Garlock primarily for incoming, employee physicals, treatment of minor injuries, etc. Any existing records, reports or memoranda written by any of these physicians and pertaining to Garlock are in the hospital records which are all maintained by patient name at Garlock. INTERROGATORY NO. 19: Does Defendant have in its possession any books, pamphlets, memoranda, or written materials of any kind or character that would indicate that asbestos fibers, when inhaled, can be hazardous to the health of human beings? If so, state: A. The name of each such publication. B. The date of publication and the names of the author and publisher (if any). '. C. The date received by Defendant, if known. D. The name, job title, and address of each person who currently has possession of each publication and its present location. . ANSWER: Garlock objects to this request on the grounds that it is overly broad, unduly burdensome and seeks information which is irrelevant in this case and not reasonably calculated to lead to discovery of admissible evidence, subject to and without 23 waiving the foregoing objections, Garlock states that it may have obtained documents responsive to this request throughout the course of asbestos litigation but these documents are irrelevant since they do not relate to this Defendant's knowledge. iyTERPOf?&TQRY m, .2 9: Has Defendant or any of its subsidiary or predecessor companies at any time been a member of any trade organization or association that published or disseminated any documents or information relating to the hazards of asbestos comprised of other manufacturers, miners, marketers, and/or sellers of asbestos products? If so, state: A* The name and address of each such association or organization. B. The dates during which Defendant or any of its subsidiaries or predecessors were members. C. The names and dates of any publications, minutes, or reports published, written, or disseminated by any of the named associations or organizations. D. Whether any of those publications are still in your possession, and if so: 1. A description of the publications, including the date. 2. The current location of such publications. 3. The custodian of such publications. 24 4. The method or manner in which such publications are maintained. ANSWER: Garlock objects to this interrogatory on the grounds that it is overly broad. Notwithstanding and without waiving the foregoing objection, Garlock states that it has been a member of five organizations which may have dealt with asbestos- containing products: 1. The Fluid Sealing Association (formerly Mechanical Packing Association) (member from 1933 to present). 2. Asbestos Textile Institute, Inc. (member from approximately 1966 to 1979 - Garlock acknowledges that a review of ATI minutes discloses an earlier membership period during the 1940's, but Garlock has no independent record or information as to such period.) 3. Asbestos Information Association of North America (member from approximately 1974 to 1980). 4. American Society for Testing and Materials (member from 1945 to present). 5. National Safety Council (member from 1922 to present). Subject to and without waiving the foregoing objections, Garlock states that it may have obtained documents responsive to this request throughout the course of asbestos litigation but these documents are irrelevant since they do not relate to this Defendant's knowledge. . INTERROGATORY NO. 21: Identify by name and location each plant or manufacturing facility in which the products listed in your answers to 25 Interrogatory Nos. 3-6 were manufactured, assembled, or prepared for sale or marketing, specifying which plants produced each item, the dates each plant is or was in operation, and the time span during which each named item was pi^duced or manufactured.. MSWEE: Garlock objects to this interrogatory on the grounds that the information sought is irrelevant in this case and is not reasonably calculated to lead to discovery of admissible evidence. The plaintiff has never been a Garlock employee and does not allege ever visiting any Garlock facility. The only relevant issues in this action pertain to finished asbestoscontaining products after they have- left the Garlock facilities. Notwithstanding and without waiving the foregoing objections, Garlock states that it has a principal manufacturing facility and sales office located at 1666 Division Street, Palmyra, New York 14522. INTERROGATORY NO. 22; "- Have printed sales materials been prepared by Defendant or any of its subsidiary or predecessor companies or their agents for purposes of marketing or advertising products containing asbestos? If so, state: Answer: Garlock objects to this interrogatory as being overly broad, unduly burdensome, not properly limited as to time and not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding and without waiving the foregoing 26 objections, Garlock states that over the years it has prepared hundreds of writings, instruction sheets, brochures and the like regarding its products. The majority of said writings have long since been discarded. All existing writings (several file cabinets full) are available for inspection and copying at plaintiff's expense at Garlock Inc, 1666 Division Street, Palmyra, New York 14522. .23.: Have any written or printed materials or instructions of any kind or character been prepared by Defendant or any of its subsidiary or predecessor companies or their agents indicating how asbestos products should be used and maintained? If so, state: A. The name; address, and job title of each person who prepared such materials or instructions or assisted in their preparation. B. The name, address and job title of each person who currently has possession of such materials or instructions and their present location. C. The dates of distribution or use and the manner in which such materials or instructions were distributed to purchasers of Defendant's products or those of its subsidiaries or predecessors. D. The year each such written material or instruction was .. prepared and disclosed to potential consumers. 27 ANSWER: Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, not properly limited as to time and for the further reason that the only Garlock products at issue in this case are those to which plaintiff alleges to have been exposed. Notwithstanding and without waiving the foregoing objections, Garlock states that it has continually provided its customers with instructions as to the proper handling, installation and use of its products. Such instructions have been in various forms, including instruction sheets, advertising literature and user seminars. IHTERBggATPRY NP, 24: Does Defendant have insurance policies that might cover the claims made by Plaintiffs in these cases? If so, list the name of each insurance carrier, the amount of initial coverage, amount of coverage remaining at the present time, and the effective dates of each policy. (If properly answered, this Interrogatory need not be supplemented as to the remaining amount of coverage). ANSWER: . Product liability insurance coverage. for Garlock has been available under various policies, including the following primary policies: 28 carrier Travelers Insurance Company Employers Mutual of Wausau Aetna Life and Casualty Company lar 1951 - 1961 1961 - 1976 1975 - 1986 The full amount of coverage available under such policies is subject to differing views between the insured and the insurers. INTERROGATORY NO. 25: As to the disease asbestosis, state: A. The date on which Defendant or its subsidiary or predecessor first learned that such disease was caused by inhalation of asbestos fibers by humans. B. How Defendant became aware of the existence of the disease. ` C. Who within the company first discovered, recognized or understood the adverse consequences or effects of the disease and/or of asbestos, exposure. D. What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. E. Whether any such information is still maintained by Defendant or its subsidiary or predecessor in any written form. F. Who is the custodian of such information. 29 G. The date on which you first received knowledge or information that asbestosis was caused by inhalation of asbestos fibers. ANSWER: _ Garlock objects to this interrogatory on the grounds that it calls for an expert medical opinion which Garlock is not qualified to give. Notwithstanding and without waiving the foregoing objection, some Garlock personnel have been aware for a number of years that excessive exposure to asbestos dust may be hazardous to one's health. Garlock is unable to pinpoint when or how such personnel first became aware of the possible health hazard. However, there has never been any competent scientific or medical evidence or reason to believe that Garlock products, through normal use, have caused or contributed to any hazardous condition, potential or otherwise, since they are bonded and/or encapsulated. INTERROGATORY NO. 26: "` As to the disease lung cancer, state: A. The date on which Defendant or its subsidiary or predecessor first learned that such disease was caused by inhalation of asbestos fibers by humans. B. How Defendant or its subsidiary or predecessor became aware of the disease and its relationship to asbestos exposure. . 30 C. Who within the company or its subsidiary or predecessor first discovered or recognized the adverse consequences or effects of asbestos exposure. D. . What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. E. Whether any such information is still maintained by Defendants or its subsidiaries or predecessors in a written form. F. Who is the custodian of such information. G. The date on which you first received knowledge or information that lung cancer was caused by inhalation of asbestos dust and fibers. ANSWER: Garlock'objects to this interrogatory on the grounds that it calls for an expert medical opinion which Garlock is not qualified to give. Notwithstanding and without waiving the foregoing objection, some Garlock personnel have been aware for a number of years that excessive exposure to asbestos dust may be hazardous to one's health. Garlock is unable to pinpoint when or how such personnel first became aware of the possible health hazard. However, there has never been any competent scientific or medical evidence or reason to believe that Garlock products, through normal use, have caused or contributed to any hazardous condition, potential or otherwise, since they are bonded and/or encapsulated. 31 INTERROGATORY NO, 27: As to pleural disease, pleural thickening or pleural plaques, state: A. The date on which Defendant or its subsidiary or predecessor learned such disease was caused by inhalation of asbestos fibers by humans. B. How Defendant or its subsidiary or predecessor became aware of the disease and that it was caused by exposure to asbestos. C. Who within the company or its subsidiary or predecessor first discovered or recognized the adverse consequences or effects of asbestos exposure. D. What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. E. Whether any such information is still maintained by Defendant or its subsidiary or predecessor in a written form. '- F. Who is the custodian of such information. MSHEB: Garlock objects to this interrogatory on the grounds that it calls for an expert medical opinion which Garlock is not qualified to give. Notwithstanding and without waiving the foregoing objection, some Garlock personnel have been aware for a number of years that excessive exposure to asbestos dust may be hazardous to one's health. Garlock is unable to pinpoint when or how such personnel first became aware of the 32 possible health hazard. However, there has never been any competent scientific or medical evidence or reason to believe that Garlock products, through normal use, have caused or contributed to any hazardous condition, potential or otherwise, since they are bonded and/or encapsulated. iCTEFftQgATQRY KQ...._28.s ` As to the disease mesothelioma, state: . A. The date on which Defendant or its subsidiary or predecessor first learned such disease was caused by inhalation of asbestos fibers by humans. B. The date on which Defendant first suspected that mesothelioma was caused by inhalation of asbestos dust and fibers by humans. C. HOW Defendant or its subsidiary or predecessor became aware of the disease and that it was caused by exposure to asbestos. . D. Who within the company or its subsidiary or predecessor first discovered or recognized the adverse consequences or effects of asbestos exposure. E. What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. F. Whether any such information is still maintained by Defendant or its subsidiary or predecessor in a written form. G. Who is the custodian of such information. 33 H. Whether Defendant agrees that there is no medical cure for mesothelioma. ANSWER: Garlock objects to this interrogatory on the grounds that it calls for an expert medical opinion- which Garlock is not qualified to give. Notwithstanding and without waiving the foregoing objection, some Garlock personnel have been aware for a number of years that excessive exposure to asbestos dust may be hazardous to one's health. Garlock' is unable to pinpoint when or how such personnel first became aware of the possible health hazard. However, there has never been any competent scientific or medical evidence or reason to believe that Garlock products, through normal use, have caused or contributed to any hazardous condition, potential or otherwise, since they are bonded and/or encapsulated. JHT.gRBQgAIQB3L.WQA. 2?.: As to gastro-intestinal cancer, `laryngeal cancer, pharyngeal cancer or lymphatic cancer, state: A. The type of cancer and the date on which Defendant or its subsidiary or predecessor first learned that such diseases were caused by inhalation of asbestos fibers by humans. B. What cancers has the Defendant or its subsidiary or . predecessor become aware can be caused by exposure to asbestos fibers? 34 C. The date on which Defendant first suspected other cancers were caused by asbestos inhalation. D. Who within the company or its subsidiary or predecessor first discovered the advejrse consequences or effects of asbestos exposure. E. What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. . F. Whether any such information is still maintained by Defendant or its subsidiary or predecessor in a written form. G. Who is the custodian of such information. - ANSWER Garlock objects to this interrogatory on the grounds that it calls for an expert medical opinion which Garlock is not qualified to give. Garlock objects to making a general review of literature having no relevance to Garlock asbestos- containing products on the grounds that to do so would put defendant in the position of doing the plaintiffs' work. Subject to and without waiving the foregoing objections, some Garlock personnel have been aware for a number of years that excessive exposure to asbestos dust may be hazardous to one's health. Garlock is unable to pinpoint when or how such personnel first became aware of the possible health hazard. However, there has never been any competent scientific or medical evidence or reason to believe that Garlock products, through normal use, have caused or contributed to any 35 hazardous condition, potential or otherwise, since they are bonded and/or encapsulated. INTERROGATORY NO- 30: _ . Does Defendant contend that asbestos products can be manufactured or designed so as to eliminate all potential health hazards to persons working with or exposed to them? If the answer is affirmative, explain in detail, and attach any studies or surveys on which this answer is based. ANSWER: Garlock objects to this interrogatory on the grounds that it calls for an expert medical opinion which Garlock is not qualified to give. Garlock objects to making a general review of literature having no relevance to Garlock ' asbestoscontaining products on the grounds that to do so would put defendant in the position of doing the plaintiffs' work. Subject to and without waiving the foregoing objections, Garlock states that there has never been any competent scientific or medical evidence or reason to believe that its asbestos-containing products, upon reasonable use, release asbestos fibers in sufficient quantities, if any, to pose a health hazard, potential or otherwise, to persons using such products. Garlock denies that use of, or exposure to, its asbestos-containing products pose any health hazard or any significant possibility of inhalation of asbestos fiber. This defendant does not know of or have in its possession any 36 books, pamphlets, memoranda or other written materials of any kind or character which present any evidence or which would otherwise indicate that Garlock asbestos-containing products, upon reasonable use, release asbestos fibers in sufficient quantities, if any, to pose a health hazard, potential or otherwise, to persons using such products. Garlock has no knowledge about any products other than gaskets and packing and cannot answer with respect to products manufactured or sold by other companies. INTERROGATORY NO. 31: Describe in detail the types of packages or packaging which Defendant or any of its subsidiary or predecessor companies used for asbestos material or products, listing the dates each type of package was used, a physical description of each type of package, and providing a description of any printed material or trademarks that appeared thereon. ANSWER: - Garlock objects to this interrogatory on the grounds that it is overly broad and burdensome. Notwithstanding and without waiving the foregoing objections, Garlock states that it does not have records which would indicate when it started and/or stopped using any particular type or style of packaging. For probably at least 50 years, the dominant colors of our packaging materials have been yellow, red and black. Sometimes black has predominated, and at other times, yellow 37 has been the dominant color. However, the three colors have usually been used together. The form in which Garlock asbestos-containing products are shipped varies, depending upon_the size and configuration of each item, the number of items called for by the customer's order and the customer's own desires. Among the containers used are burlap bags, cardboard boxes and wooden crates. In addition, asbestos sheet is occasionally shipped flat on wooden pallets. All of its products, both those containing asbestos and those containing no asbestos, have always been sold under the GARLOCK name. In addition, the Calipers and Scale trademark was used with all of its products from about 1900 until approximately 1968. A number of secondary trademarks have also been used over the years. Principal marks "which have been used in connection with asbestos-containing products, as well as non-asbestos-containing products, have been BELMONT, GUARDIAN, CHEVRON, LATTICE BRAID', PALMYRA and PAPERPAK. INTERROGATORY NO. 32: Has Defendant or any of its subsidiary or predecessor companies at any time entered into a "rebranding" agreement with any other company, either as buyer or seller, concerning asbestos materials or asbestos products? If so, state, as to each such agreement: A. The name of the company manufacturing the asbestos products. 38 B. The trade name affixed to those products. C. The periods of time covered by each such agreement. D. The volume, in dollar amount, of each transaction. E. The initial purchaser of the products. ANSWER: . Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, not properly limited as to time and for the further reason that the only products at issue in this case are those to which plaintiff alleges to have been exposed. Notwithstanding and without waiving the foregoing objections. Garlock states that it has, from time to time, sold some of its products for resale under other labels. Some of these products contained asbestos, others contained no asbestos. Garlock has no record, knowledge or recollection of any written distribution or sales agreement concerning such products. There is no reason to believe that such products are germane to this litigation. INTERROGATORY NO. 33: List the name and address of each company from which Defendant or its subsidiary or predecessor purchased materials or asbestos products which Defendant sold or distributed in any form, stating the form of the materials, the dates of such purchases, and the ultimate disposal of such materials. 39 ANSWER: Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, not properly limited to a relevant time period and for the further reason that the only products at issue in this case are those to which plaintiff alleges to have been exposed. Notwithstanding and without waiving the foregoing objections, Garlock states that it has, from time to time, purchased products from others for resale under the Garlock label. Some of these products contained asbestos, others contained no asbestos. Garlock has no record, knowledge or recollection of any written distribution or sales agreement concerning such products. There is no reason to believe that such products are germane to this litigation. INTERROGATORY'NO. 34: Does Defendant or any of its subsidiaries or predecessors currently have possession of any writings or contracts on those rebranding agreements set forth in answer to Interrogatory No. 32? If the answer is affirmative, state: A. The name, address, and job title of each person having custody of each of those documents and their current location. B. A brief discussion of each such document, including the dates and the parties signatory. 40 This Defendant has no record, knowledge or recollection of any such writings or contracts. Discovery is continuing. INTERROGATORY NO. 35: . Prior to 1968, did any person file a claim against a Worker's Compensation carrier covering Defendant or any of its subsidiaries or predecessors alleging that he/she contracted a disease form inhaling asbestos fibers? If so, provide: A. A list of the claims, including each claimant's name, address and the date each claim was filed, and including the caption and jurisdiction of the claim. B. The disease alleged in each such claim. C. A brief .summary of the disposition of each such claim. D. The name, address and title of the person having custody ANSWER: of the records pertaining to each such claim. Garlock objects to this interrogatory insofar as it pertains to Workers' Compensation claims on the grounds that it is overly broad, unduly burdensome and that the information sought is irrelevant in this case and is not reasonably calculated to lead to discovery of admissible evidence. The plaintiff has never been a Garlock employee and does not allege ever visiting any Garlock facility.* The only relevant issues in this action pertain to finished asbestos-containing . products after they have left Garlock facilities. 41 INTERROGATORY NO. 36: Did Defendant or any of its subsidiaries or predecessors maintain written minutes of corporate meetings, either board of directors, departmental, or otherwj.se, which reflect discussion pertaining to any subject matter related to asbestos, asbestos health hazards or asbestos products? If so, for each such set of minutes, state: A. The dates of each such meeting. B. The general subject matter discussed at each meeting. C. Who was in attendance at each meeting. D. Where and by whom the written minutes are presently maintained. E. By whom the minutes were taken and put into final format. F. Whether ' the minutes were abstracted and reports disseminated to other individuals, and if so' the names and job titles of those individuals. ANSWER: This Defendant has no record, knowledge or recollection of any such writings. INTERROGATORY NO. 37: Do you or any of your subsidiaries, including foreign business entities, currently manufacture any products containing asbestos? If so, state: A. As to each product, whether such product is mined, manufactured, and/or marketed or sold. 42 B. The names and addresses of the companies mining manufacturing, marketing, and/or selling each of those products. C. The trade or brand name of each of those products mined, manufactured, marketed, and/or sold. D. The date each of the named products was placed on the market. E. A description of the physical (chemical) composition of each of the named products, including the type of asbestos contained in the product. F. A description of the physical appearance of each product and its packaging. G. A detailed description of the intended uses of each of the named products. H. Whether there are any warning labels on said products or containers regarding potential asbestos-related health hazards. Garlock objects to this interrogatory on the grounds that it is overly broad and unduly burdensome and for the further reason that the only products at issue in this case are those to which plaintiff alleges to have been exposed during the time periods at issue. Notwithstanding and without waiving the foregoing objections, Garlock still produces some products containing asbestos. 43 ! INTERROGATORY NO. 38: State whether you or any of your predecessors and/or subsidiaries maintain, from 1940 through the present or for any portion thereof, copies of invoices, shipping documents, bills of lading, purchase orders, or other documents of a similar nature relating to the mining, manufacture, marketing, sale or distribution of asbestos products. If so, state: A. The location of such documents. B. The name and address of the custodian of the documents. C. The format in which the documents are kept, i.e. . hard copy, microfilm, microfiche, etc. D. In what form the documents can be accessed, i,e. . by state, by product, etc., and if by product, whether kept according to asbestos or non-asbestos. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant to any issue in this case, not reasonably calculated to lead to discovery of admissible evidence and for the further reason that the only products at issue in this case are those to which the plaintiffs allege to have been exposed. Subject to and without waiving the foregoing objections. Garlock states that it does not maintain separate compilations of sales records for its asbestos-containing products or for sales in specific states or sub-divisions thereof. Such older records as still exist are retained in Palmyra in 40** x 40** x 40" cardboard boxes, each containing several cartons of records. 44 These records will be made available to plaintiff for inspection and copying at plaintiff's expensed'and" upon appropriate prior arrangements. It is believed that the oldest such paper records generally date from approximately 1978. . Upon receipt of specific information from the Plaintiffs as to the products to which they allege to have been exposed, the dates of the alleged exposure and the locations at issue, this Defendant will attempt to identify whether or not it sold such asbestos-containing products to the locations specified, at the time periods in question. INTERROGATORY NO. 39: Will you call company representatives as witnesses at the trial of any of these cases? If so, list: A. The name, address, and job title of each company representative who may be called. B. A summary of the testimony.expected to be given by each such witness. C. List any and all previous times that the named witnesses . have either given deposition or trial testimony in an asbestos-related case, including the jurisdiction, style of the case, case number, date of testimony, and the name of the attorney taking the deposition for the Plaintiffs in that case. 45 ANSWER: Defendant objects to this interrogatory as beyond the scope of discovery. Defendant has not yet determined exactly which witnesses it will call. Defendant will provide this information to Plaintiffs pursuant to the Texas Rules of Civil Procedure or court order. Subject to and without waiving the foregoing objections: Any present or former employee of Garlock. Garlock specifically identifies Mr. Clayton Jewett and Mr. Roy Whittaker as former and current employees who may testify on behalf of Garlock. Mr. Jewett and/or Mr. Whittaker will provide testimony on the process involved in the manufacture of various asbestos containing and non asbestos containing Garlock gaskets and packing material. Mrf Jewett and/or Mr. Whittaker may also describe the various products manufactured by Garlock and the proper application and use of said products. Garlock reserves the right to call any current or past Garlock employees in response to the evidence presented in plaintiff's case-in-chief. Garlock has not yet completed its determination of witnesses and reserves the right to supplement and amend this list up to and including the time of trial. INTERROGATORY NO. 40: Have Defendant or its subsidiaries or predecessors ever acquired through purchase, reorganization, or merger another 46 corporation, company, or business which manufactured, sold, processed, distributed, or contracted or supplied products containing asbestos? If so, for each such entity, state: A. Full and correct name; . B. Principal place of business; . C. State of incorporation; D. Date of acquisition by Defendant; E. Whether or not the business entity was ever authorized to transact business in the State of Texas; ANSWER: In past years, Garlock acquired four subsidiary companies which made and/or sold at least some asbestos-containing products. Those companies were the Belmont Packing & Rubber Company, Crandall Packing Company, Dealers' steam Packing Company and U.S. Gasket Company. The only asbestos-containing products of which Garlock is aware that were made and/or sold by these companies were sealing products substantially equivalent to similar such products made and sold by Garlock. The Belmont Packing & Rubber Company was located in Philadelphia, Pennsylvania; Crandall Packing Company and Dealers' Steam Packing Company were located in Palmyra, New York and U.S. Gasket Company was located in Camden, New Jersey. Ultimately, each of the four subsidiaries was merged or otherwise absorbed into Garlock, including all assets and . liabilities. As far as Garlock is aware, all business records of these former subsidiaries were destroyed many years ago in accordance with Garlock's long-standing record retention and 47 destruction program. It is probable that old corporate minute books still exist, but Garlock would not expect them to contain any information pertinent to this litigation. In June, 1987, Garlock Inc acquired The Anchor Packing Company of Philadelphia, Pennsylvania which has sold asbestos-containing gaskets, gasket materials and packing. Garlock has no information regarding the state in which these entities were incorporated. Garlock has no information regarding whether these entities were ever authorized to do business in Texas. INTERROGATORY NO. 41: Was each of your asbestos products generally expected to reach, or packaged to reach, the consumer or user, without substantial change in the condition in which it was sold? If not, with respect to any such product, explain in what way the Defendant claims its products were altered or substantially changed after sale or distribution and before reaching the user. ANSWER; This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, and for the further reason that the only products at issue in this case are those to which the plaintiffs allege to have been exposed. Subject to and without waiving the foregoing objections, Garlock states that it does sell gasket sheets and other packing materials that may be cut to proper size by the user or pre-cut by Garlock or by others. 48 INTERROGATORY NO, 42: For each asbestos-containing product identified in response to Interrogatory No. 6, identify all foreseeable users such as insulators, helpers, pipefitters, welders, machinists, plasterers, drywall finishers, carpenters, boilermakers, shipwrights and riggers, etc. of any of Defendant's asbestos-containing products. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant to any issue in this case, not reasonably calculated to lead to discovery of admissible evidence and for the further reason that the only products at issue in this case are those to which the plaintiffs allege to have been exposed. Subject to and without waiving the foregoing objections, this Defendant states that gasket materials were primarily used for static sealing of steam line flanges, cylinder heads of engines, compressors, refrigeration equipment, etc. Packing materials were primarily used for dynamic sealing of machinery. We assumed certain workers would remove and install our products. INT.ERR9GftT.QRY NQt 43: Based upon the material contents of your asbestos-containing products, the method of manufacturing, and the method of application, can such products be generally applied without liberating asbestos fibers into the air? 49 A. If there is a different answer concerning different products manufactured, sold, distributed, or used by your company, then specify the different products by precise manufacturer's name and popular name. - B. If there is a difference in your answer depending on the year or years in which a particular product was used, then specify in detail what year or years you are referring to and the specific products you are referring to and year involved. ANSWEB: This Defendant objects to this interrogatory on the grounds that it is overly broad and unduly burdensome and for the further reason that the only products at issue in this case are those to which the plaintiffs allege to have been exposed. Subject to and without waiving the foregoing objections, Garlock states that there has never been any competent scientific or medical evidence or reason to believe that Garlock asbestos-containing products, upon reasonable use, release asbestos fibers in sufficient quantity, if any, to pose a health hazard, potential or otherwise, to persons using such products. Garlock denies that use of, or exposure to, its asbestos-containing products poses any health hazard, or any significant possibility of inhalation of asbestos fibers, since they are bonded and/or encapsulated. 50 INTERROGATORY NO. 44: Was it a foreseeable use of your asbestos-containing products that they may have been removed, stripped, or replaced at some time after installation? . ANSWER: - This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant to any issue in this case, not reasonably calculated to lead to discovery of admissible evidence and for the further reason that the only products at issue in this case are those to which the plaintiffs allege to have been exposed. Notwithstanding, Garlock states that it is anticipated that its sealing products, of whatever material, may have to be replaced from time to time. INTERRQffATQKL. WOx,,4 5: Before 1970, did you or your subsidiaries or predecessor(s) ever arrange for any labor inspectors,* insurance company inspectors or anyone from your company to go to job sites where your products were being used or installed to make or take dust level counts? If so, state when this procedure started, the purpose of such procedures, and all results of such procedures. ANSWER: No. 51 INTERROGATORY NO. 46: If Defendant performed or had performed any dust level counts, what action, based on the results, did your company take? ANSWER: Not Applicable. See Answer to Interrogatory No. 45. INTRRQGATQRY-NQ-r.. 17.8 Has your company or its subsidiaries or predecessor(s) ever conducted or caused to be conducted any studies designed to assist in minimizing or eliminating the inhalation of asbestos dust and fibers by those exposed to the use of your company's products? If so, give the following: A. Name of the person or firm conducting such studies; B. The date the studies began and the date they were completed; C. Any' publication or other written dissemination of the results of the studies; D. The nature of any action to eliminate or minimize the inhalation of asbestos dust fibers; ANSWER: ' Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and for the further reason that it presupposes that the asbestos-containing products of Garlock emit dust at levels harmful to the human body. Notwithstanding and without waiving the foregoing objections, Garlock states that it is unaware of any investigations, tests, examinations or experiments concerning the asbestos- 52 containing products of Garlock and any effect thereof on the human body. INTERROGATORY NO. 48: . Does your company have, has it ever had, or have your predecessor(s) or subsidiaries ever had, a Research Department? If so, give the year such Research Department was established, and whether or not such Research Department has operated continuously since being established. State also: A. The amount of time and money expended each year on research concerning asbestos or asbestos-containing products? B. What percentage of gross sales did your company or its predecessor(s) spend on research concerning the health effects of asbestos? c. State in detail the purposes, duties, and responsibilities of such Research Department. ANSWER: '- A Research and Development Department existed during most of the I960'8. The exact dates of its formation and termination are not available. A new Research and Development Department was established early in 1984 and functioned for approximately two years. In both instances, the Department worked on the development of new and/or improved products and processes. The Department never conducted any medical research. 53 INTERROGATORY NO- 49: Does your company have, has it ever had, or have your predecessor(s) or subsidiaries ever had, a Medical Department? A. The year such Medical Department was established*; B. Whether or not such Medical Department has operated continuously since being establishedf C. The name of each director, chief, or head of your Medical Department year by year, beginning with the first year you had a Medical Director or Medical Department, and the last known address and phone number of each; D. State the duties and responsibilities of such Medical Department. * ANSWER: Garlock has ' not employed, retained or otherwise engaged physicians, industrial hygienists or others to conduct medical research. By way of further answer, see Answer to Interrogatory No. 18. INTERROGATORY NO. 50: Did your company or its predecessor(s) or subsidiaries ever place any warning directly on any of its asbestos-containing product or on their packaging. If so, identify the product(s) and year said warning was first applied. MSWEB: See Answer to Interrogatory No. 14. 54 INTERROGATORY NO,. 51: Did your company or its predecessor(s) or subsidiaries ever stamp or place the name of the company, its initials, or any identifying logo on any of its asbestos-containing products? If so, please state the name brand names . of such products, a* description of such stamp or logo and the dates such were placed on the referred products. MS: ' This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and for the further reason that the only products at issue in this case are those to which the plaintiffs allege to have been exposed. Subject to and without waiving the foregoing objections, see Exhibit MC". . INTERROGATORY NO. 52; Has your company, or your predecessor(s) or subsidiaries, ever devised a research plan to develop, or actually developed or had developed, a product which did not contain asbestos and which could be substituted for one or more of your asbestos-containing products? If so, state the date that such research plan was begun and when such asbestos-free product was first placed on the market. ANSWER: This Defendant has always made available non-asbestos containing sealing products as well as asbestos-containing sealing products to its customers. This Defendant has not recommended asbestos containing products for any particular 55 purpose. Customers specified the need for asbestos-containing material for certain applications requiring a heat resistant sealing product. This company has constantly been involved in supplementing and developing products to satisfy customer needs and meet specific application requirements of the customer. The non-asbestos products which most closely conformed to the properties of the asbestos-containing products, were developed after 1970. INTERROGATORY. HSU 53 s Did your company or its predecessor(s) or subsidiaries ever recall any products containing asbestos from the market or stream of commerce? If so, state: A. All details of such recall; B. The name of the product recalled, including the reason for the recall and the names and current addresses of those individuals who determined that it should take place; C. The dates of recall; D. The purpose for the recall. ANSHER: ' No. INTERROGATORY NO. 54: Before 1970, did you ever manufacture or sell products which did not contain asbestos and which could be substituted for your 56 asbestos-containing products? If so, state the date such asbestos- free products were first placed on the market. ANSWER: This Defendant has always made available non-asbestos containing sealing products as well as asbestos-containing sealing products to its customers. This Defendant has not recommended asbestos containing products for any particular purpose. Customers specified the need for asbestos-containing material for certain applications requiring a heat resistant sealing product. This company has constantly been involved in supplementing and developing products to satisfy customer needs and meet specific application requirements of the customer. The non-asbestos products which most closely conformed to the properties of the asbestos-containing products, were developed after 1970. Garlock made both asbestos and non-asbestos containing products available to its customers. The customers made the decision regarding which type of products they would ue. IflXERRQffATQRY _ NO 5.5: Have any products you identified in your response to Interrogatory Nos. 52 and 54 not performed as intended? Please list all such products that have not performed as intended. This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant to any issue in this case, not reasonably calculated to lead to 57 discovery of admissible evidence and for the further reason that the only products at issue in this case are those to which the plaintiffs allege to have been exposed. INTERROGATORY _.0.t .56: ' Did your company or its predecessor(s) or subsidiaries ever make, order, or arrange for any industrial hygiene surveys regarding asbestos or asbestos-containing dust? If so, give the date of such surveys and state who, or what entity, was responsible for completion of such surveys. MSHEB: Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, irrelevant to any issue in this case, not reasonably calculated to lead to discovery of admissible evidence and for the further reason that the only Garlock products at issue in this case are those to which plaintiffs allege to have been exposed. Notwithstanding and without waiving the foregoing objections, Garlock states that during the course of continuous investigation, observation, experience and study of its products and their use, there has never been any competent scientific or medical evidence or reason to believe that Garlock products pose any health hazard, potential or otherwise, to persons using said products. Garlock products pose no health hazard, potential or otherwise, to persons using such products. Garlock has had the following studies conducted for it by industrial hygienists: "The Actual Occupational Exposure to Airborne 58 Asbestos Released by Garlock Spiral Wound, Braided and Encapsulated Gaskets11 by Carl A. Mangold, CIH (December 1982); "The Actual Contribution of Garlock Asbestos Gasket Materials to the Occupational Exposure to Asbestos Workers" by carl A. Mangold, CIH (October 1982); "Asbestos Fibers in the Ambient Air in the Greater San Francisco Area": by Carl A. Mangold, CIH (March 1983); "Ambient Asbestos Fiber Levels in the Metropolitan Areas of Norfolk-Portsmouth-Newport News, Virginia" by Joseph D. Wendlick, CIH (December 1983) ; "The Actual Contribution of Asbestos Fiber Exposure During Gasket Removal from Pipe Flanges Aboard Ship" by Carl A. Mangold, CIH ^November 1983); "The Actual Release of Asbestos Fibers from New, Used and Flanged Garlock Inc Asbestos Gasket Materials" by Carl A. .Mangold, CIH (September 1985); "Occupational Exposures During Processing, Handling, Installation and Removal of Garlock Asbestos-Containing Gaskets" by Martin R. Bennett and Richard L. Hatfield (June 1985); "Garlock Inc Gasket Materials -A Comparison' of the Tyndall Phenomena to the Actual Concentration of Asbestos Fibers in the Breathing Zone of Workers" by Carl A. Mangold, CIH (July 1986); "The Actual Contribution of Airborne Asbestos Fibers to the Occupational Exposure of By-Standers During Selected Processing of Encapsulated Asbestos Gaskets" by Carl A. Mangold, CIH (January 1989) - Eight separate sub-divisions titled as follows: Cutting Gaskets with a Circular Cutter; Gasket Cutting with Hand Shears; Gasket Cutting with Ball Pien (sic) Hammer; Scribing of Gasket Materials; Opening of Old Flanges 59 and Removal of Asbestos Gaskets; Flange Face Scraping with Putty Knife; Hand Wire Brushing of Asbestos Gasket Residual from Flanges; Power Wire Brushing of Flange Faces; "The Actual Contribution of Asbestos Fibers from Removal and Installation of Asbestos Packing from Valves" by Carl A. Mangold, CIH and Robert L. Gay, Ph.D. (May 1991). INTERROGATORY_NQ_i _51: As to either the threshold limit values or maximum allowable concentrations of both asbestos dust and total dust provided by the American Conference of Governmental Industrial Hygienists, state: A. The year in which Defendant or any predecessor(s) or subsidiaries were first advised of such limits or concentrations; B. The name of the employee or official of the company receiving such advice; C. How Defendant received notice of such limits or concentrations. ANSWER: Garlock objects to this interrogatory on the grounds that it is overly broad and vague, in that it makes no reference to the circumstances, conditions and locations relevant to this litigation. Notwithstanding and without waiving the foregoing objections, this Defendant states, upon information and belief, that in the early or mid-1950's Garlock became aware of the prevailing TLV or safe limit for exposure to asbestos fibers. 60 INTERROGATORY NO. 58: Were the threshold limit values or maximum allowable concentrations inquired about in Interrogatory No. 57 for total dust, and not asbestos dust alone? . Yes. INTERROGATORY__NO .-53: State in detail what tests, if any. Defendant ever made with regard to the quantity, quality, or threshold limit values of asbestos dust or particles to which workers were exposed while using, working with or around, or installing your asbestos- containing products. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, not properly limited in time and for the further reason that the only products at issue in this case are those to which the plaintiffs allege to have been exposed. Subject to and without waiving the foregoing objections, see Answer to Interrogatory No. 56. INTERROGATORY NO. 60: Please state the following with respect to each expert witness you that you may call during trial of these case. Please designate with specificity the expert witnesses that you will call, including: 61 (a) The name, address, and job classification of each such expert witness; (b) The subject matter on which the expert is expected to testify; * (c) The substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion; (d) Whether any person identified in subparagraph (a) above has provided a report or other documentation to you, and if so, identify each such document or report; (e) Identify all documents that you have provided to each person identified in response to subparagraph (a) above; (f) Describe in detail the education and work history of, and identify any books, treatises, articles, published and unpublished reports, studies or other scholarly works authored by any individual identified in response to subparagraph (a) above. Alternatively, in lieu of said response, attach a copy of a resume or curriculum vitae and a list of publications to your answers. ANSWER: Defendant objects to this interrogatory as beyond the scope of discovery. Defendant has not yet determined exactly which witnesses it will call. Defendant will provide this information to Plaintiffs pursuant to the Texas Rules of Civil Procedure or court order. Subject to and without waiving the foregoing objections. Garlock discloses the following expert witnesses who may be called to testify at trial: 62 CARL MANGOLD, C.I.H. Hr. Mangold is an industrial hygienist. He may give testimony regarding the level of fiber release, if any, from gasket and packing products in the occupational setting. He may .testify regarding threshold limit values and permissible exposure levels as promulgated by private organizations and government agencies. He may testify as to issues involving reentrainment and fiber drift. He may testify as to work practices regarding various types of occupations using products that contained asbestos. He may testify as to the applicability of the Environmental Protection Agency's guidelines as they relate to various types of products including gaskets and packings. He may testify as to exposure that may result from the use of other types of asbestos products. ROPEBL.SAWYER.. M-Pt Dr. Robert Sawyer may testify, in general, concerning asbestos related diseases and the effects of exposure to asbestos upon persons in occupational settings, including the epidemiology of asbestos related diseases and the criteria for diagnosis of any asbestos related disease. He may also testify regarding the existence or non-existence of any asbestos related disease in the plaintiffs, including, but not limited to pleural changes, asbestosis, lung cancer, mesothelioma, laryngeal cancer, esophageal cancer and stomach cancer. He may also testify on whether any asbestos related disease allegedly suffered by plaintiffs was medically or proximately 63 caused by exposure to asbestos containing gasket and packing products. He may also testify on the existence of a dose response relationship between exposure to asbestos and asbestos related disease. He may also testify on increased risk of caner issues and whether a particular plaintiff has a reasonable fear of cancer due to exposure to asbestos. He may also testify on the health consequences of smoking. With respect to particular plaintiffs, he may testify as to review and interpretation of x-ray films, review and interpretation of pulmonary function testing, the nature and extent of any impairment or disability, whether the condition is progressive and whether other disease or conditions are present in plaintiffs. Dr. Sawyer's testimony will be based on his training, experience, education and review of the medical literature concerning asbestos related disease. STANLEY FIEL/ M.D, Dr. Stanley Fiel may testify, in general, concerning asbestos related diseases and the effects of exposure to asbestos upon persons in occupational settings, including the epidemiology of asbestos related diseases and the criteria for the diagnosis of an asbestos related disease. He may also testify regarding the existence or non-existence of any asbestos related disease in the plaintiffs, including, but not limited to pleural changes, asbestosis, lung cancer. 64 mesothelioma, laryngeal cancer, esophageal cancer and stomach cancer. He may also testify on whether any asbestos related disease allegedly suffered by plaintiffs was medically or proximately caused by exposure to asbestos containing gasket and packing products. He may also testify on the existence of a dose response relationship between exposure to asbestos and asbestos related disease, He may also testify on increased risk of cancer issues and whether a particular plaintiff has a reasonable fear of cancer due to exposure to asbestos. He may also testify on the health consequences of smoking. With respect to particular plaintiffs, he may testify as to review and . interpretation of x-ray films, review and interpretation of pulmonary function testing, the nature and extent of any impairment or disability, whether the condition is progressive and whether other disease or conditions are present in plaintiffs. "* . Dr. Fiel's testimony will be based on his training, experience, education and review of the medical literature concerning asbestos related disease. J, LEROY BALZER, Ph.P., CIH Mr. Balzer is a Certified Industrial Hygienist. He may give testimony regarding the level of fiber release, if any, from gasket and packing products in the occupational setting. He may testify regarding threshold limit values and permissible exposure levels as promulgated by private organizations and 65 government agencies. He may testify as to issues involving reentrainment and fiber drift. He may testify as to work practices regarding various types of occupations using products that contained asbestos. He may testify as* to the applicability of the OSHA and Environmental Protection Agency's guidelines as they relate to various types of products including gaskets and packings. He may testify as to exposure that may result from the use of other types of asbestos products. pQNWA.M.t BINGO, .cm Donna M. Ringo is a Certified Industrial Hygienist. She may give testimony regarding the level of fiber release, if any, from gasket and packing products in the occupational setting. She may testify regarding threshold limit values and permissible exposure levels as promulgated by private organizations and government agencies. She may testify as to issues involving reentrainment and fiver drift. she may testify as to work practices ' regarding various types of occupations using products that contained asbestos. She may testify as to the applicability of the OSHA and Environmental Protection Agency's guidelines as they relate to various types of products including gaskets and packings. She may testify as to exposure that may result from the use of other types of asbestos products. (F) Available curriculum vitae are attached hereto as Exhibit nD" (Mangold, Fiel, Sawyer, Balzer and Ringo). 66 INTERROGATORY-NO. 61: Please state the name, present address and present telephone number, along with the experience and qualifications, if applicable, of each and every person, known to Defendant or to Defendant's agents, having knowledge of facts relevant to these cases involving, but not limited to: (a) identification of asbestos-containing products to which each and every individual Plaintiff, separate and distinct from all other Plaintiffs within the group, allegedly was exposed or facts disputing the identification of asbestos-containing products in this case. (b) Each and every individual Plaintiff's, separate and distinct from all other Plaintiffs within the group, alleged damages, injuries and/or facts disputing each and every Plaintiff's alleged damages and/or injuries; (c) the negligence of any person or entity other than Defendant which Defendant contends was a cause of each and every individual Plaintiff's, separate and distinct from all other Plaintiffs within the group, alleged . injuries and/or damages; (d) each of Defendant's defenses enumerated in Defendant's last filed Answer in each of these case. MSWE: This Defendant has no record or knowledge of any such persons at this time, other than the Plaintiffs' themselves. Discovery is continuing and Defendant will supplement in 67 accordance with the Texas Rules of Civil Procedure and court order. INTERROGATORY62: - Please identify documents which will be used at time of trial, (Exhibit List, Deposition List), which are relevant to each of Defendant's enumerated defenses in Defendant's last filed Answer. AHSWEBs Defendant Garlock objects to this request as beyond the scope of discovery. Garlock has not yet determined which exhibits it will use. Garlock will provide this information pursuant to the Texas Rules of Civil Procedure or Court Order. Finally Garlock reserves the right to introduce exhibits not designated herein for the purpose of impeachment or rebuttal or which are later determined to be beneficial. INTERROGATORY NO, 63: When if ever, did Defendant or' any of its predecessors-in- interest first receive a copy of the article entitle "A Health Survey of Pipe Covering Operations in Constructing Navel Vessels", published in January, 1946 in the Journal of Industrial Hygiene & Toxicology, and authored by W. Fleischer and P. Drinker, et al ("the Fleischer-Drinker Report")? (a) Identify the name and position of the employee or officer who received same; 68 (b) Please produce all documents generated by Defendant which discuss or in any way reference the "Fleischer-Drinker" study prior to 1968; (c) Please produce all documents upon which your responses above are based; (d) Please identify the name(s) and address(es) of any person(s) who can verify your above response; (e) Did Defendant ever rely on the Fleischer-Drinker Report in whole or in part as a basis that Defendant's asbestos products could be used in the workplace without risk of asbestos-related health impacts to the consumer and/or bystander; (f) If so, please produce every document which evidences in any way. that Defendant relied on the Fleischer-Drinker Report in whole or in part for the proposition stated in Interrogatory No. 63(a) above; (g) If your answer to 63(e) is yes, when was the first date Defendant relied on the oh the Fleischer-Driker report in whole or in part for the proposition stated in 63(e) ANSWER: above? Garlock has no record, knowledge or recollection of receiving a copy of the Fleischer-Drinker Report during the normal course of business at any time prior to the commencement of the asbestos litigation. Garlock did receive a copy of the Fleischer-Drinker report for the first time from its attorneys 69 through the discovery process at the beginning of the asbestos litigation. INTERROGATORY NO. 64: . When if ever, did Defendant or any of its predecessors-in- interest first receive a copy of the article entitle "A Study of Asbestos in the Asbestos Textile Industry", published in 1938 in Publice health Bill, No. 241, U.S. Publice Health Service and authored by W. C. Dreessen ("the Dreessen Report")? (a) Identify the name and position of the employee or officer who received same; (b) Please produce all documents generated by Defendant which discuss or in any way reference the "Dreessen" study prior to 1968; (c) Please produce all documents upon which your responses above are based; (d) Please identify the name(s) and address(es) of any person(s) who can verify your above response; (e) Did Defendant ever rely on the Dreessen Report in whole or in part as a basis that Defendant's asbestos products could be used in the workplace without risk of asbestos- related health impacts to the consumer and/or bystander; (f) If so, please produce every document which evidences in any way that Defendant relied on the Dreessen Report in whole or in part for the proposition stated in Interrogatory No. 64(a) above; 70 (g) If your answer to 64(e) is yes, when was the first date Defendant relied on the on the Dreessen report in whole or in part for the proposition stated in 64(e) above? ANSWER: . Garlock has no record, knowledge or recollection of receiving a copy of the Dreesen report during the normal course of business at any time prior to the commencement of the asbestos litigation. Garlock did receive a copy of the Dreesen report for the first time from its attorneys through the discovery process at the beginning of the asbestos litigation. REQUEST FOR PRODUCTION REQUEST..EPR-EBPPHgTXQK NP. 1: ' Please produce a true and correct copy of each photograph of each asbestos-containing product identified in answer to Interrogatory No. 4. RESPONSES. '- Garlock objects to this Request on the grounds that it is overly broad, unduly burdensome, not reasonably calculated to lead to the discovery of admissible evidence and for the further reason that the only Garlock products at issue in this case are those to which plaintiffs allege to have been exposed. Notwithstanding and without waiving the foregoing objections, Garlock states that over the years it has prepared hundreds of writings, instruction sheets, brochures and the like regarding its products. The majority of said writings 71 have long since been discarded. All existing photographs (several file cabinets full) are available for inspection and copying at plaintiff's expense at Garlock Inc, 1666 Division Street, Palmyra, New York 14522. REQUEST FOR PRODUCTION NO. 2: Please produce any diagrams or schematics indicating, stating or detailing the existence of' any of your subsidiaries, predecessors, or divisions as defined on Page 1 of these Interrogatories and Request for Production. . Defendant has not been able to locate any documents responsive to this request. To the extent such documents exist, they are available for inspection and copying at Plaintiff's expense at Garlock Inc, 1666 Division Street, Palmyra, New York 14522. REQUEST FOR PRODUCTION NO. 3: Please produce copies of all reports of Defendants' experts and any and all documents relied upon by such experts. RESPONSE; Garlock objects to this Request on the grounds that it is overly broad and unduly burdensome. The reports of Dr. Charles Mangold listed on the Exhibit List of Garlock Inc filed in this numbered cause of action are available for inspection and copying at Plaintiff's expense at Brown, McCarroll & Oaks Hartline, 2727 Allen Parkway, Suite 1300, Houston, Texas 77019. K:\PS\OAWLOCK\49525.1 991.70736 72 CAUTION; Contain* AaOaaioaflbare. Avoid erecting dwt Breathing A*b**to*du*tin*ycs**a various bodfty haem. ! GARLOCK DISTRIBUTORS IN TEXAS Bayou Gasket & Hose. Inc. 1550 E. Cardinal Drive Beaumont, TX 77705 Bearings, Inc. Cottingham Div. Branch 040 9421 Neils Thompson Drive Austin, TX 78759 320 South Wilcox Rockdale, TX 76567 Cottingham Div. Branch 2613 Bearing Lane Temple, TX 76501 042 Bryan Hose & Gasket Co. Hwy. 21 W. & Quality Bryan, TX 77803 Lane C.F. Adams Industries Div. of Empire Mfg. Co., 1665 Hickory Hamilton City,. TX 76117 Inc. Champion Hi-Tech Mfg., 4387 Canyon Drive Amarillo, TX 79110 Inc. Corpus Christi Gskt. & Fastener 341 Westchester. Dr. ' Corpus Christi, TX 78469 Corpus Christi Rubber & Spec. 2728 S. Port Ave. Corpus Christi, TX 78465 Crown Products, Inc. 1206 FM 1845 Longview, TX 75602 Marine & Petroleum Mfg. 1404 N. Ave. J Freeport, TX 77541 Inc. 9426 Old Katy Rd. Houston, TX 77055 Crown Products, Inc. of Dallas 2616 Irving Blvd. Dallas, TX 75207 basket Service, Inc. ` 2120 Kermit Hwy. P.0. Box 2373 * Odessa, TX 79760 George S. Thomson Co., Inc. 3738 Durazno P.O. Box 17 El Paso, TX 79999 Houston Gasket & Packing Co., Inc. 1809 Franklin St. P.O. Box 551 Houston, TX 77001 Intex Rubber 4 Specialty 907 Old Temple Rd. P.O. Box 67 Hewitt, TX 76643 Leak Repair 2105 North Highway 35 Alvin, TX 77511 Longhorn Gasket & Sply Co. 2425 W. Longhorn Dr. Lancaster, TX 75134 Lufkin Rubber & Gasket Co., Inc. 501 Ellen Trout Drive Lufkin, TX 75901-0483 Triplex, Inc. 203 S. Logan P.O. Box 1270 Texas City, Tx 77590 Victoria Bearing 1708 N. Wheeler Victoria, TX 77901 Farm Road 1006 Orange, TX 77630 North Texas Packing & Seal Co. 13606 Floyd Circle Dallas, TX 75243 Current Garlock Distributor's in Texas Panhandle Packing & Gasket, Lubbock Gasket & Supply 402 19th St. P.O. Box 2154 Lubbock, TX 79408 Inc. 1 1416 N. Grant St. Odessa, TX 79761 Seal-Pac Professional 2425 Broad Street Houston, TX 77087 Svcs., Inc. Swing Machinery & Equipment Co. 106 W. Rhapsody San Antonio, TX 78216-3104 Triangle Packing & Specialty 2315 Lilac P.O. Box 1755 Nederland, TX 77627 Triplex, Inc. 1142 Kress Street Houston, TX 77020 4401 Highway 347'South Nederland, TX 77027 11/07/90 Osedi fTj^eJy /<? 7o J <?&?  .- OCK r janocR uari ck udnuc > .j : P 900 900 900 tioc'k Garlock Garlock Garloc ti >0 900 900 900 i\ lock Garlock Garlock Garlocf A. * 4 W* r 1 - 1 >0 900 900 900 l/s re / S /nce > ;Sock- Garlock Garlock Garlock > bo 900 900 900 lock Garlock Garlock Garlock : po i 900 ^_9I0f 0 900 REVISED: June 1.993 QUALIFICATIONS OF CARL A. MANGOLD, CIH Date of Blrthi February 16, 1931 Ref: Resume1 Residence: 3033 170th Place S.E. Bellevue, Washington, 93008 . (206) 747-9620 Educational Background: - Bachelor of Science In Chemistry University of Washington, Seattle, Washington In 1957. Master of Public Administration, City University of Seattle, Seattle, Washington in 1961. Industrial Toxicology, Post Graduate study School of Medicine, Columbia University, - New York, New York, in 1966. - . National Board Certification, Certificate NO. 633, May 1969, granted by the Aaerlcan Board of Industrial Hygiene. / Industrial Hygiene Engineering Course, NO. 601, U.S. Public Health Service, Cincinnati, Ohio, 1963. Radiological Health Course, U.S. Public Health Service, Las Vegas, Nevada in 1966. Occupational Radiation Protection, U.S. Public Health Service,. Las Vegas, Nevada In 1971. Western Ventilation Conference Training Course, Univarsity of Washington, Seattle, Washington, in 1979. Electromagnetic Spectrum Course (non ionizing radiation of all types). Environmental Protection Agency, Richland, Washington, in 1968. EXHIBIT . Radiological Control Procedures.Course, U.S. Department of the Navy, Puget Sound Naval Shipyard, Bremerton, Washington, 1968. Basic Health Physics (Ionizing radiation) course, O.S. Department of the Navy, Puget Sound Naval Shipyard, Bremerton, Washington, in 1965. . Instruction Training Course, O.S. Department of the Navy, Pjuget Sound Naval Shipyard, Bremerton, Washington, 1967. Chemical Carcinogenesis Course, Sponsored by the National Institute for Occupational Safety and Health at the University of Washington, Seattle, Washington In 1961. Laser Safety Course, Sponsored by the National Institute for Occupational Safety and Health at the University of Washington, Seattla, Washington, In 1981. Compliance Officer Course (100*4), Occupational Safaty and Haalth Administration, U.S. Dapt. of Labor, Chicago, Illinois, 1972. Araa Industrial Hyglanlst Coursa, ~ Occupational Safety and Health Administration, U.S. Dept, of Labor. Washington D.C., 1973. Foundry Industry Education Studies, School of I7iglneerlng, University of Alabama, In 1976.' Noise Engineering Control Course, Occupational Safety and Health Administration, U.S. Dept, of Labor, Washington D.C. In 1977. Industrial Noise Abataaant Technology, University of Texas, San Antonio, Texas, April 1977. Executive Seminar on Sclenea, Technology and Public Policy, U.S. civil Service Commission. In 1977. industrial Ventilation and Air Cleaning Conference, University of Washington, September 1979. 2 Advanced Executive Management Seminar Series, U.S. Civil Service Commission Curricula, University of California, Berkley, California, completed in 1980. Toxic and Hazardous Waste Dump Site Course, Environmental Protection Agency', Raritan Arsenal, Hew Jersey in April 1983. Hazardous and Toxic Material Management Course, Harvard School of Public Health, Boston, Massachusetts in 1984. Respiratory Protection Course, H.W. Center for Occupational Safety and Health, University of Washington in January 1986. Advanced Seminar on Asbestos Disease, Ogden, Ogden A Murphy Law Offices, Seattle, Washington in April 1985. Asbestos Worker Certification Course, No. 000? to qualify as an asbestos worker under Washington State Rules in July 1966 - developer and instructor. Hazardous Materials Management Symposia, American Institute of Plant Engineers, Seattle, Washington in March 1985. ~ Current Issues in Asbestos Control, sponsored by the N.W. Center for Occupational Safety and Health, University of Washington in March 1986. * O.S. Army Command and General Staff Collage (5 year resident/nan-resident course) Ft. Leavenworth, Kansas, graduate 1978, 0.3. Army War College, Carlisle Barracks, Pennsylvania, graduate of the 1986 class. Certified Asbestos Supervisor - ( a requirement of the State asbestos standards for asbestos removal) Certificate # 007477, effective until August 4, 1993. (State Certification Examination -July 1989). (Previously Competent Person Certification) Recertified to August 4, 1993) 3 KIOSK Course # 582 -Sampling and Evaluating Asbestos Duat --- April 1987. Thla la a mandatory requirement currently specified In the Federal 0S8A and State of Washington aebaatoe standards for those who count asbestos by phase contrast microscopy according to the standards. University of California, Berkeley, "Building Inspection and Management Planning for Asbestos", April 1986* (EPA qualification for inspection and aanageaent planning for schools under the Asbestos Hazard Emergency Response Act, (AHERA 1987), Re-certlflcatlon through Environmental Health Sciences, Inc. Refresher certifications 930601-08 and 930602-04 to June 1.- 1994. University of Washington, "Health Effects of Synthetic Fibers" (A review of the toxicology of fibers other than asbestos) May 1986. American Industrial Hygiene Association, Professional Development Course # 41, "Asbestos Sampling Analysis end Regulatory Update" May IS, 1966. "Disease Potential of Different Asbeatoe Fiber Varieties", Collegium R*m*zelni, Ottawa, Ontario, Canada, March 20-22, 1969. (Sponsored by X.J. Sellkoff, Mt. Sinai Hospital aa an International Symposium of scientists recognized for asbestos knowledge and research) "Risk Assessment and Rlak Communication", Short Course sponsored by the Pacific Northwest Section, American Industrial Hygiene Association, Octobsr 10, 1990, Portland, Orsgon. "Quality Assurance end Quality Control - for Field and Laboratory data" Short Course sponsored by the American Industrial Hygiene Association, May 16, 1991, Salt Lake City, Utah. "Engineering Noise Control" Short Course sponsored by the American Industrial Hygiene Association, May 19, 1991, Salt Lake city Utah. 4 "Luna Toxicology & Disease" . Short Oourae sponsored by the Auer loan Industrial Hygiene Association, May 31, 1992, Boston, Massachusetts. "Lead Paint Inspections k AbatementM Short Course sponsored by the American Industrial Hygiene Association, May 31, 1992, Boston, Massachusetts. "Aerosols in Occupational Environments", Short Course>sponsored by the American Industrial Hygiene Association, May 16, 1993, New Orleans, Louisiana. "Occupational Epidemiology for the Industrial Hygienist", short Course Sponsored by the American Industrial Hygiene Association, May 16, 1993, New Orleans, Louisiana. 5 POSITIONS HELD Analytical Chemist, Aluminum Company of America, Wenatchee, Washington, 1957 - 1962 Industrial Hygienist, O.S.- Department of the Navy. Puget Sound naval Shipyard, Bremerton, Washington, 1952 - 1967 . Head, Industrial Hygiene_Branch, Medical Department, Puget Sound Naval Shipyard, Bremerton, Washington, from 1967 to 1972 Washington Arse Industrial Hygienist, Occupational Safety and Health Administration, O.S. Dept, of Labor, Bellevue, Washington, 1972 - 1976 Regional Industrial Hygienist, Raglon X (4 western state#). Occupational Safety and Health Administration, O.S. Department of Labor, Seattle, Washington from 1976 to 1965 Senior Health Scientist, Environmental Services Division, American Building Malntenanca Co., Tacoma, Washington, July 1985 through March 1986 as a consultant. Industrial Hygiene Consultant and Analytical Chemist, July 1985 to Present. President, Environmental Control Sciences, Xne., Bellevue, Washington. Initial devsloper and instructor In ths Stats of Washington cartlflsd "Certified Asbestos Worker Certification Course, # 0007 from 1988 through 1986. Instructor for "Sampling and Analysis of Asbestos Materials" In ths Stats of Washington certified Competent Persons Course for Asbestos, presented by Heavey Engineering, Inc. (February 1967 to May 1968) Instructor for the University of California, Berkeley, CA, "Building Inspection and management Planning for Asbestos" Course (providing SPA approved training to etodente who will become building Inspectors and management planners for schools under the Asbestos Hazard Emergency Response Act, 1967) - May 1988, Portland, Orsgon. 6 APPOINTMENTS Member of the tJ.S. Navy Industrial Hygiene Association Non-Ionizing Radiation Committee. A special report was prepared on Microwave Radiation Safety and RF Power Density Instrumentation in 1905. The O.Sr Navy had unique RP radiation exposures fro* a large variety of coaaunlcatlons and nlsalle director systems. Some of the radiation patterns were high energy collimated pencil beams capable of physical damage even on intermittent exposure up to a distance of 1,000 feet. This committee dratted a proposed Instruction for implementation at U.S. Naval Shipyards. 1956 - 1968. U.S. Navy Industrial Hygiene Association Committee for Laboratory Procedures. (The committee reviewed needs for standardization, reporting proceduree and information exchange for Navy industrial hygienists) 1966 - 1967* Htad, Nuclear Accident Team # AA at Puget Sound Naval Shipyard, exclusive of submarine operations. This team conducted surveys In case of national emergency, or e locel Incident that might cause contamination of government or nearby civilian property. 1968 - 1972. Environmental Consultant on the Deep Submergence Rescue Vehicle Development for submarine rescue for the U.S. Department of the Navy, from 1968 to 1972. . Aerosol Hazards Evaluation Coaalttee Member for ASBESTOS, American Industrial Hyglsns Association, In 1972. Advisor to the Workers Compensation Board of British Columbia, Canada on Industrial Nolee Programs, October 1979. Advisor to the Weyerhaeuser' Company on a volcanic ash hsalth plan during logging operations following the Mt. St. Helens volcanic eruption. May to September 1980. Advisor to the Hanford Environmental Health Laboratory, Richland, Washington, 1980 - 1982. - Advisor and lecturer to the 8eattle Fire Department for technical advice on toxic and hazardous materials from 1980 to 1986. Expert witness for Asbestos Litigation, Occupational Safety and Health Administration, U.S. Department of Labor, Seattle, Washington, 1980 - 1968. Team Member, Hazardous Waste Pollution Contingency Plan, Region X an interagency work group between four Federal agencies - IPA, OSHA, FDA, CPSC in four western etetee, 1980 to 1988. 7 Member, Toxic and Hazardous Waste Site Inspection lean. Region X, Occupational Safety and Health Administration, U.S. Department of Labor, Seattle, Washington, 1983 - 1985. Member, Bronchial Provocation Challenge Chaaber Teak Force, Virginia Mason Clinic, Seattle, Washington, fro* July 1985 to January 1967. Peer Reviewer by Invitation of the Proposed State of Washington Asbestos standard, WAC 296-62-077 adopted as a Permanent Rule In March 1987. \ 8 AWARDS AHD COMMENDATIONS 2. October 1963 - Quality Salary Increase for Industrial Hygiene Program excellence. 2. July 1964 - Letter of Appreciation from the Commanding Officer, U.S. Naval Air Station, Whldby Island for aeaeureaent of unusual electromagnetic hazards. 3. July 1967 - Department of the Navy Certificate of Merit froa the Commander, Naval Ships Systems Coaaand, Washington, D.C. . 4. August 1967 - U.S. Department of the Navy Award of Merit for Group Achievement for the Industrial Hygiene Division, Puget Sound Naval Shipyard, Bremerton,-Washington. 6. May 2966 - Letter of Appreciation froa the Naval Investigative Services, Seattle. Washington for unusual analyses of drugs. 6. January 1969 - Lattar of Apprsclatlon froa ths coaaanding Offlesr, Naval Supply Center, Puget Sound, for special reporting of occupational health hazards. 7. May 1969 - Admitted as a Olpolmate of ths American Board of Industrial Hygiene for Comprehensive Practice. Nationally Board Certified --- Certificate # 633. 8. June 1969 - Commendation from the Deputy Commissioner, Bureau of Raployees Compensation, U.S. Dapt. of Labor for excellence in the review of several hundred hearing loes * clalme froa the Puget Sound Naval Shipyard. 9. September 1970 - Certificate of Commendation for the development of an M Air-fed double-bibbed plastic hood for protsctlon against toxic materials". This dsvlcs la used by five major Naval Shipyard and some private shipyards. U.S. Navy Patent Applied Por. 10. November 1970 - Certificate of Commendation froa ths Acting Commander, Bureau of Medicine and Suraary, U.S. Department of the Navy for efforts In presenting ths U.S. Navy Asbestos Control Program mt a Symposium in New York, sponsored by Z.K. Sellkoff for nationally known scientists dealing with asbestos. 11. December 1970 - Commendation from ths Commander, Puget Sound Naval Shipyard for efforts toward solving ths asbestos r*l*tad health hazards and the presentations to industrial scientists. . 9 . ! i : ; ' i ! i i' 12. March 1971 - Latter of Appreciation froa the. Command#r, Puget Sound Naval Shipyard for the presentation of tha exemplary Shipyard Asbestos Control Program to visiting scientists. IS. Hay 1972 - Certificate of Commendation from Puget . Sound Naval Shipyard. Bremertonr Washington for superior achievement In tha development of the Asbestos Control Program, which was an axample for other shipyard activities, both Federal and Private. 14. April 1976 - Commendation from B.J. White, Aaaoclata Assistant Secretary, Occupational Safety and Health Admlnlatratlon for Regional Programs, for assistance to the Lockheed Shipbuilding Co. In identifying and developing programs to control occupational exposures to epoxy resin ship coatings. 15. August 1977 - Quality Salary Increase froa OSHA, U.S. Oapt. of Labor for; a. performance es Area Operations Manager, Bellevue, Washington conducting compliance and State evaluation programs b. performance as tha Senior Industrial Hygienist in the Regional Office of Technical Support, Region X, OSHA, conducting operations in 4 western states. c. Leadership and drive to inspire and motivate others in his field of industrial hygiene. 16. October 1978 - Commendation froa the Directorate, Technical Support, OSUA. U.S. Dept, of Labor, Washington D.C. for unusual performance and the development of a unique engineering control design for the noise control of large wire rope atranders. Tha innovation impacted 13 national companies and thair 27 plants in tha United States. 17. November 1979 - Commendation from the Workers Compensation Board of British Columbia, Canada, for advice, technical expertise and assistance toward development of an industrial noise control program. 18. December 1979 - Commendation froa the Graduate School of Public Affairs, University of Washington for outstanding lectures on occupational safety and health issues. 19. March 1980 - Meritorious Achievement Award from the Occupational Safety and Health Administration awarded for unusual skill, innovation, and leadership in developing evaluation protocols and a plan of strategy for negotiations with tha Bunker Hill Co, Kellogg, Idaho, a large copper smelter. 10 20. September 1981 - Commendation from Thorne Auchter, Assistant Secretary of Labor. Occupational safety and Health Administration for professionalism In the Involved, complex, legal, technical and other sensitive issues In the settleaent Kith the Bunker Hill Co., Kellogg, Idaho. 21. October 1982 - Commendation from the United States Attorney, U.S. Department of Justice, Western District of Washington, for assistance and testimony in current asbestos litigation. 22. October 1982 - Commendation from Congressman Ron Wyden, 0.8. House of Representatives. Congress of the United States, Washington D.C., for excellent Information and research about potential asbestos exposures to constituents. 23. November 1982 - Commendation from-Judge Alfred T. Goodwin, United States Court of Appeals, Ninth Circuit, for the excellent presentation of current research on the potential health effects of microwave emissions from Video Display Terminals. 24. 1982 - Group award from tha National Office, OSHA. U.8. Dept, of Labor, Washington D.C. for the professional advice and chemical analyses following the Nt. St. Selene Volcanic Eruption In Washington Stats In May 1980. 26. July 1983 - The Distinguished Service Award, from OSHA, U.S. Deptr. of Labor, for dedicated personal leadership in the Implementation of occupational safety and health programs within the federal Government. 26. January 1984 - Commendation from Thorne Auchter, Assistant Secretary of Labor, Occupational Safety and Health Administration, Washington D.C., -for the articulate presentation of OSHA regulatory activities to the Seattle Poet Intelligencer Newspaper. 27. January 1986 - Commendation from the Office of the King County Executive. King County, Washington, for providing outstanding expertise and professional advice to develop a comprehensive asbestos abatement control program for county buildings end schools. 28. March 1988 - Certificate of Appreciation from the American Znstltute of Plant Engineers, Chapter 130, for Outstanding service (Lectures and Symposia). . 11 PUBLICATIONS 1. C.A. Mangold, Application of Spectrophotometrie Determination of Low Fluoride with Zirconium Eriochroae Cyanine it to Rapid Routine Operations, Aluminum co. of Anar lea, Wenatchaa, WA, June 1962 (A study of tha gaaaoua diffusion methods and raflnanents for routine operations) 2. C.A. Mangold, O.J. Bassaar. R.R. Beckett, Tha Respirator As A Field s aspling Device for Lead Dust, August 1964. (Presented to the Pacific NIC Section of the American Industrial Hygiene Association Conference In August 1964.) Tha paper described a technique for sampling highly noblie work groups with varying Individual exposures to lead duet at Pugst Sound Naval shipyard. 3. C.A. Mangold, R.R. Backatt, Davran Epoxy Coatings -- . Evaluation of the Occupational Exposure to Painters at Puget sound Naval shipyard, January 1967. (This paper identified the amine hardeners causing dermatitis and . hypers!lsrganlc sensitivity which lead to the developaant of ventilated suits as a - control measure.) 4. C.A. Mangold, Barrier Crass Protection Against Low Level Radioactive Contamination and Toxic Matarlals, Puget Sound Naval Shipyard, in February 1967. 6. D.J. Beeaaer, C.A. Mangold, Noise Reduction of a High Pressure Eductor of an Industrial Vacuus, Journal of Aaerlcan Society of Safety Engineers, September 1969. ( also presented to the Pacific 1T.N. Section of the American Industrial Hygiene Association Conference In August 1966.) (This paper describes a resonance muffler to reduce the exhaust noise of a pneumatically operated vacuum used aboard ship. An unusual abatement of 29 decibels of reduction resulted.) 6. R.R. Backatt, C.A. Mangold, The Quantitative Deterslnatlon of Butoxyacetlc Acid Metabolite In Urine by Gae chromatography, Puget Sound Naval Shipyard, December 1969, (This technique was used to tha evaluate the exposure of painters who used about 90,000 gallons of 12 butyl celloaolve each year at Puget Sound Naval Shipyard In the applioatlona ot Epoxy paints. 7. C.A. Mangold* The Occupational Noise Exposure During Construction of the U33 SAMUEL GOMPERS, (AD-37) * Pugef. Sound Naval Shipyard 16 106?. (This Monograph related the occupational noise exposures to work groups constructing a large'Naval veaael from keel laying to launching over a 26 month period. The data was collected to help evaluate 470 hearing loaa claims between 1064 and 1967* which eventually cost the U.8. government 91*600*000 In payments. - 8. C.A. Mangold* Teaporary Ventilation - A Supervisor's Guide* Puget Sound Naval Shipyard ( An Illustrated manual tor the use of teaporary ventilation aboard ships under repair or overhaul). Publlahad Oeceaber 1967 9. C.A. Mangold* R.R. Beckett* D.J. Bessaer* ASBESTOS EXPOSURE AND PULMONARY X-RAY CHANGES TO PXPECOVERERS AND INSULATORS AT PUGET SOUND NAVAL SHIPYARD * Official U.8. Navy publication* August 1968. (This paper presented to the Pacific N.W. Section of the American Industrial Hyglsns Association _ Conference) (The study showed a 2 1/2 year comparison that Insulation workers had a 21k diagnosed pulmonary abnormalities as a group compared to 3.6 X for boiler makers* and less than IN for clerical workers. 20. C.A. Mangold* R.R. Beckett, Environmental Conditions During Hatch Entry Penetration Testa for the Deep Submergence Rescue Vehicle (DSRV), Puget sound Naval Shipyard* June 1970. (This paper outlined the potential axpoaure to toxic gases and particles that could be encountered during reecus of sunken submarines with the DSRV.) 11. C.A. Mangold* R.A. Xalffar* G. Mattson* A Plastic Disposable Double-Bibbed Air-red Hood for Protection Against Low Level Radioactive and Toxic Materials* U.8. Navy Publication* September 1970* U.8. Navy Patent Applied For. 12. C.A. Mangold* R.R. Beckett* D.J. Bessaer, A8BS3T08 EXPOSURE AND CONTROL AT PUGET SOUND NAVAL SHIPYARD* an Official U.8. Navy Publication, 13 * March 1970. 13. C.A. Mangold, O.J. Beesaer. Cadmium Oxids, Nitrogen Dioxide, and fluoride Exposure from Silver Brazing Ships Piping Systems, American Industrial Hygiene Journal, February 1971. (This protracted study beginning In 1965 was presented to the Pacific N.W. Section of the American Industrial Hygiene Association Conference in 1969. 14. C.A. Mangold, Exposure of Welders to Fluorides at Puget Sound Naval Shipyard. Presented to the Pacific N.W. Sactlon of the Amerlomn Industrial Hygiene Aeeocietlon Conference. October 1971 at Idaho Falls, Idaho. ( Fluorldss In the urine of welders from the use of fluxes can'be rapidly measured with a specific ion electrode as an index of exposure.) 15. C.A. Mangold. R.A. Xleffer, Development of Chapter 7B-3. U.S. Navy Nuclaar Power Manual, Puget Sound ' Neval Shipyard, 1971* (This chapter made PSNS one of the first nuclear shipyards to standardize an integrated Ufa support and protective system for respiratory protection eysteae and heat stress control for personnel employed In nuclear reactor work an submarines.) 16. C.A. Mangold, The Impact of the OSHA Standard for Asbestos on Industry and Asbestos Control Methods. (Presented to the Pacific N.W. Section of the American Industrial Hygiene Association Conference, In Seattle, Washington In October 1972. 17. Duncan Holiday, C.A. Mangold, Asbestos Control Measures For Ths Shipbuilding Industry, A Manual of Practices, Mt. Sinai School of Medicine Publication, November 1973. 16. C.A. Mangold, Asbestos Hazard Control-------A Symposium For Employers. (Sponsored by OSHA In January 1973) (Received TV coverage In Seattle, Washington and Portland, Oregon.) 19. J.W. Roberta, H. Waters, C.A. Mangold, A.T. Rossano, Benefits of Road Dust Control In Seattle's Industrial Valley, Journal of Air Pollution Control, Vol 25. No. 9, September 1973. (This paper discusses free silica exposures) 14 20. C.A* Mangold, The Occupational Health Hazards'of Polychlorinated Biphenyls. (Presented to the 28th Annual Governor*a Safety Conference, Seattle, Washington in November 1977.) Paper le in printed fora. 21. C.A. Mangold, An Engineering Control Approach to High Intensity Wire Rope Strander Noise, Official OSHA Publication, July 197B. (A unique control aethod for large etrander* that Impacted 13 companies and thsir 27 plants In the 0.8.). ' 22. C.A. Mangold, Developing Industrial Hygiene Programs and Personnel for Emerging State Programs, Occupational Safety and health Administration, 0.8. ~D0L, August 30, 1974, Revised October 26, 1978. 23. C.A. Mangold, A Modal Asbestos Control Program for the U.S. Public Health Sarvlce Hospital, Veterans Administration, Seattle, Washington, October 1979. 24. C.A. Mangold, W.E. Ruch, PhD, - Chemical Hazards in the Wood Products Industry, October 1979. - (A reference manual for International Wood - Workers Onion , AFL-CXQ) - 25. C.A. Mangold, General Guidelines for Occupational Health Control to Volcanic Aeh During Forest Operations m the State of Idaho, July I960. (A program to minimize elllca dust exposure (from Mt. St, Helens eruption ash.) 26. C.A. Mangold. A Typical Lead Control Program for Employers, OSHA Publication, Saptsmbsr 1980. 27. C.A. Mangold, A Model Asbestos Control Program for the Ship-Breaking Industry, OSHA Publication, August 1980. 28. C.A. Mangold, Potential occupational Health Hazards at the Wind River Forest Nursery, Carson, Washington and the Albuquerque Seed Extractory, Albuquerque, Nett Mexico, December, 1981, ( A review of toxic and hazardous chemicals and the allergenic effects of seed duet.) 29. C.A. Mangold, An Asbestos Control Program - A Typical Employer's Format. OSHA Publication, March 1982. 15 30. C.A. Mangold, Personal Protective Equipment Manual for Entry Into Toxic and Hazardous Masts Sites, February 1964 (A comprehensive volume that coablnes Federal regulations, recognized safe procedures, and elements of contamination control*} 31. C.A. Mangold, The Effects of Contaminated Clothing on the Sampling of Low Level Asbestos Fiber Concentrations in the breathing Zone of Workers. (Presented to the Pacific N.N. Section of the American Industrial Hygiene Association Confersncs on October 11, 1984} (This papers shows that asbestos . contaminated clothing can obscure results of low level sampling for asbestos fibers in air) October 1984. - 32. C.A. Mangold, Mike Reid, Asbestos Worker Certification Course, No. 0007, for the State of Washington requirement for certified asbestos workers. (A Stats of Washington Approved 32 Hour Course ) July 1986 33. C.A. Mangold, A Summary Review of Exposure to Low Concentrations of Asbestos Fibers in Air, Hay 1986. (Expresses the Impact of low level concentrations of asbestos In perspective to - known and potential risks) 34. C.A. Mangold, provided technical assistance and advice to an Ad Hoe Task Fores that prepared the text: Managing the Risks of Exposure to Asbestos In Federal Reserve Bank Buildings, September, 1986 (National Task Fores) i i e AFFILIATIONS Diplomat* of the American Board of Induatrial Hygiene. Certificate # 633, awarded Hay 12, 1909 to present. Meaber, American Industrial Hygiene Association, 2903 to present. Member, Aaerlean Conference of Governmental Industrial Hygienists - Fab 1, 1963 to present (Affiliate Membership} . Meaber, Pacific Northwest Section of the American Industrial Hygiene Association, 1903 to present. (President In 1971) Meaber, Aaerlean Chealcal Society (Member # 13730208} 27 SERVICE: MILITARY STATUS U.S. ARMY RESERVE . RANK: COLONEL (Retired July 1987) HXGHE8T ASSIGNMENTS: Deputy Chief of Staff of Personnel for the 124th U.S. Aray Reaerve Command, Ft Lawton* Washington. Deputy Chief of Staff* 124th U.S* Army Reserve Command SECURITY CLEARANCEi Special Top Secret EDUCATIONAL U.S. Army Command and General Staff College, Ft. Leavenworth, Kansas, 1978 graduate * U.S. Army War College, Carlisle Barracks, Pennsylvania, 1986 graduate KOREAN SERVICE: 1954 - 1956 HIGHEST AWARDS: Legion of Merit (highest non-combat decoration award by the U.S, Army) Merltoroua Service Medal Army commendation Medal ROBERT N. SAWYER. M.D.. FACPM CURRICULUM VITAE OFFICE AND MAILING ADDRESS: U.S. MAIL: P.O. Box 1407 Guilford. Connecticut 06437-0507 COURIER: 149 Prospect Avenue Gulford, Connecticut 06437 - 203-453-3050 CORPORATE ADDRESS: * Entek Environmental and ` Technical Services. Inc. Rensselaer Technology Park 125 Oefreest Drive Troy. NY 12180 518-283-9200 EDUCATION AND TRAINING: UNDERGRADUATE: Massacnuserts Institute of Technology Camoridge. Massachusetts MEDICAL Case Western Reserve University School of Medicine Cleveland. Ohio INTERNSHIP: Oakland Naval Hospital, Oakland. California. Routing Internship RESIDENCY: Preventive Medicine. Department of Epidemiology and Public Health. Yale University School of Medicine New Haven. Connecticut POST DOCTORAL RESEARCH: Yale University School of Medicine. Department of Epidemiol ogy and Public Health. New Haven. Connecticut BS 1956 MO 1963 1964 1967 - 1970 MPH 1970 1968 1970 BOARD CERTIFICATION: American Board of Preventive Medicine Certificate No. 254. December. 1972 FELLOWSHIP: American College of Preventive Medicine Certificate No. 2023. April. 1973 LICENSURE AND CERTIFICATION: Diplomats of National Board of Medical Examiners. Certificate No. 79307 Medical Licenses: Connecticut California Colorado 12054 G-13270 16661 1972 1973 1964 ' 1965 1967 1970 UWVCT M o WVtWTlVf AMO OCCUPATIONAL MCOCMC -GcE.-.T ' ir/i HR. M.O SOCIETY MEMBERSHIPS: FACULTY APPOINTMENTS: COMMITTEE APPOINTMENTS PRESENT PROFESSIONAL ACTIVITIES: PAST MAJOR PROFESSIONAL ACTIVITIES: New York Academy of Science . American Association for tne Advancement of Science Amencan College of Occupational Medicine Occupational Medical Association of Connecticut Air Pollution Control Association Lecturer in Medicine. Department of Medicine. Associated Facuiry. School of Medicine. University of Pennsylvania, lecture faculty: Mt. Sinai School of Medicine New York. N.Y. Lecture faculty. The University of Kansas. Division of Continu ing Education Lecture faculty Department of Epidemiology and Public Health. School of Medicine. Yale University, New Haven. CT 1981 - 1978 - 1986 1985 - 1972 - 1981 U.S. Environmental Protection Agency. Water Engineering Laboratory (WERL). Cincinnati, Ohio. Peer Review Commit tee. 1987 National Institute of Building Sciences. Asbestos Preject Committee * 1989 National Institute of Building Sciences. EPA Radon Standards Project Committee. 1989 Consultant, Industrial and Preventive Medicine. ~ 1979 - Vice President. Entek Environmental and Technical Services. Inc.. Troy, NY. Consultants in toxic materials: architectural and engineering services for survey, assessment and control. 1986 - Consultant. Radiation Management Consultants. Phfladelphia. PA Consultation to nuclear power industry on medical aspects of radiation, care of exposed or contaminated patients. 1979 - Vice President, Environmental Technology, Inc.. West Hartford. CT. Consultants in toxic material survey, assessment and control. Yale University Health Services. Yale University. New Haven, Connecticut " Head. Preventive and Occupational Medicine. Surveillance of special risk groups in areas of radiation, carcinogens, biohazards. Head. Department of Urgent Visit Service. Clinic and in-patient services in primary patient care. Staff included physician, physician associate, and nursing personnel. . 1979 - 1986 1972 - 1981 OttKT W SAWVt* M 0 . mvtvnvi AMO OCCVMTOm*, mCOCMC S.-V.YSR. M.D CUrr.i'CL'LLM VITAE PAST MAJOR PROFESSIONAL ACTIVITIES: (Continueo) Navai Submarine Medical Center. New London. Connecticut Staff Medical Officer. Military Operations. Clinic, hospital, and general medicine duties. Consultation in radiation, chemical toxicology, and infectious disease. Medical Center Command Officer. Senior Medical Officer. Hyperbanc Medicine Officer, and Command Radiation Medical Officer. 1969 - ; S72 . Research: Headed section studying relationship of nudear submarine environment and potential health effects. Directed research in hazardous material control and personnel protection. Post Doctoral Research: Yale University School of Medicine. School of Epidemiology and Public Health 1967 1969 Principal Investigator in prospective study of Epstein-Barr virus and other respiratory system viral pathogens. Work published in Journal of Infectious Diseases. Delegate to North Atlantic Treaty Organization (NATO): Committee on Nuclear. Chemical, and Biologic Effects. 1966 - 1967 Squadron Medical Officer: U.S. Navy Submarine Squadron Two. New London. Connecticut 1966 - 1967 Clinical out-patient care. Medical system and preventive medicine program development ' Research: Special Projects Medical Officer. Systems development and personnel protection. Medical Officer: tJSS Sam Houston. Polaris Submarine. The Holy Loch. Scotland. General medicine, preventive medicine, and radiation control. Research in epidemiology of infectious diseases in submarine crews. 1964 1966 Miltary medicine: Submarine Medical Center. New London, Connecticut Medical, surgical, and radiation control training for independent assignment 1964 * *WYfH MO *WV*NTM[ MO OCCUMTONAL MCOC*C SA.VYER. m.d '.ot'.r.i ;llm rUBUCATlONS: Sawyer. R. ViraJ serdogy antiboay survival versus storage temperatures available aooard nuclear suomannes. Naval Submanne Medical fiesearcn Laboratory Report No. 474. 11 Marcn 1966. Sawyer. R. Viral disease diagnosis aboard nuclear submarines. Naval Submarine Medical Researcn Laboratory Report No. 473. 10 Marcn 1966. ` Sawyer. R. and Somerville. R. Outbreak of mycoplasma pneumoniae infection in a nuclear suomanne. JAMA 195(11):958-59. 14 Marcn 1966. ' Sawyer. R.N.. Evans, A.S., Niederman. J.C. and McCollum. R.W. Prospective studies of a group of Yale University freshman. I. Occurrence of infectious mononucleosis. J of Inf Dis 123:3, Marcn 1971. Evans. A.S.. Niederman, J.C. and Sawyer, R.N. Prospective studies of a group of Yale University fresnman. ii. Occurrence of acute respiratory infections and rubella. J Inf Dis 123:3. March 1971. Sawyer. R. Yale Art and Architecture Building Asbestos Contamination: Past. Present and Future. Proceeamgs international Conference Environmental Sensing and Assessment. September 1975. Storhe. M.C., Sawyer. R.N.. Sphar. fl.L and Evans. A.S. Seroepidemiofogicai studies of poiaris submarine crews II. Military Medicine. January 1976. Sawyer, R. Asbestos Exposure in a Yale Building: Analysis and Resolution. Ertvir. Res 13:1 146-168. 1977. Nicholson, W.J., Rohl, A.N., Sawyer, R.N., Swoszowski, EJ. and Todaro, J.D. Control of Sprayed Asbestos Surfaces in School Buildings: A Feasibility Study. Report to the National Institute of Environmental Health Sciences. June 15. 1978. , - Sawyer, R. Non-occupationaJ indoor asbestos pollution. In: Dusts and Disease. Proceedings of conference on Occupational exposures to fibrous and paniculate dust and their extension into the environment. R Lemen and J Dement, Ed. 1979. Sawyer, R. Indoor Asbestos Pollution: Application of Hazard Criteria. Ann. N.Y. Acad. Scl Vd. 330. 579-586, 1979. - Sawyer, R. and Swoszowski. EJ. Asbestos Abatement in Schools: Experience and Observations. Ann. N.Y. Acad. Scl Vof. 330. 765-776, 1979. Sawyer, R. Environmental Chemical Contamination Control in Aspheric Element Production. Proc. Optical Fabrication and Testing Workshop. Proceedings Optical Society America. September 22.1980. Lory, E.E. Coin, D.S., Cohen, K.S.. Dyer. J.S., Hienzsch, M.J.. and Sawyer, R.N. Asbestos Friable Insulation Material (F1M) Risk Evaluation Procedure for Navy Facilities. Technical Report R883. Civil Engineering Laboratory. Port Hueneme. CA. February. 1981. Sawyer, R.N. An Outline of Asbestos Material Management in Bufldings. Proceedings of Conference: Asbestos. A National Problem. Greater London Council, Technics Ltd., Lynton House. London. UK. November. 1984. Sawyer, R.N., Rohl, A.N., Langer. A.M. Airborne Fiber Control In Buildings During Asbestos Material Removal by Amended Water Methodology. JER. Vd. 36:1, 46-55, Feb. 1985. Sawyer. R.N. Asbestos Material Control and Abatement Methods. Proceedings: Occupational Health Meeting. National Aeronautics and Space Administration. Cdorado Springs, CO. November 4-6,1985. *OtC*T M SAWYA M 0 . AAtVtKITVt MO OCCU*ATW*M. M(OONC SAWYER. M D C'JnniCLL-M ViTAE Sawyer. R.N. and Morse. R.G. An Inventory Process for Determining Asbestos Control Neeas and Costs. Arcnitecture. Decemoer. 1SS6. Sawyer. R.N. Asbestos Material Inventory. Control Concepts, and Risk Communication. In Press. Harvard University. 1989. - Sawyer. R.N. Asbestos material inventory, control concepts, and risk communication. Presented at Symposium on Health Asects of Exposure to Asbestos in Buildings, Energy and Environmental Policy Center. Harvard University. June 28. 1989. In Press. ' PUBLICATION CONSULTATION ANO CONTRIBUTIONS U.S. Environmental Protection Agency. Hazard Abatement from Sprayed Asbestos-Containing Material in Buildings: A Guidance Document EPA-68-02-2607. 1978. U.S. Environmental Protection Agency. Asbestos Containing Materials in School Buildings: A Guidance Document. Part 1. Office Toxic Substances C00090. March 1979. U.S. Environmental Protection Agency. Asbestos Containing Materials in School Buildings: A Guidance Document. Part 2. Office of Air and Waste Management. Office of Air Quality Planning and Standards. RTP. NC.EPA 450/2-78*014. 1978. U.S. Environmental Protection Agency. Evaluation of Sealants for Sprayed-On Asbestos Containing Material in Buildings. Batteile Columbus Laboratories. 1981. U.S. Environmental Protection Agency. Evaluation of New Technologies in Asbestos Removal. PEDCo International Research. Cincinnati. Ohio. 1981. - Indoor Pollutants, National Research Council. Assembly of Life Sciences: Committee on Indoor Pollutants. National Academy Press. 1981. U.S. Environmental Protection Agency. Asbestos in Public and Commercial Buildings. Geophysical Corporation of America. Bedford. Mass. 1982. U.S. Environmental Protection Agency. Guidance Document, Control of Asbestos in Buildings. EPA 560/5-85-024. Batteile Memorial Institute. June, 1985. National Institute of Building Sciences. Model Guide Specification for Asbestos Abatement in 8u3dings. October 15. 1985. ' - U.S. Environmental Protection Agency. Guidance for Assessing Asbestos Exposure and Selecting Abatement Methods. 1986. U.S. Environmental Protection Agency,, Operations and Maintenance Program for Asbestos Control. 1986. MAJOR CONSULTATION ACTIVITIES A list of consultation activities wil be provided on written request The listed consultation activities will be appropriate to the requirements of the request and diem confidentiality. N SAWVtft M O . **CVTJVT AMO OCCUPATIONAL MCOONC r.vj'ccr,: iAVA c" .Mu. ^v_r.niCw__ .I.r-c AWARDS. OTIZENSHiP: BIRTH OATS: BIRTH PLACE: SSAN: US PASSPORT: U.S. Navy Surgeon General Award. 1964: Submarine Service (Polaris). Submarine Force Atlantic Commendation. 1966: Researcn in toxic materials control and" deveiocment of meaical care systems on nuclear submarines. . U.S. Navy Commendation Medal. 1968: Special projects activities as submanne medical officer. Bureau of Medicine and Surgery Commendation. 1971: Performance as physician in human hyperbaric research experiments. University of Pennsylvania institute of Environ mental Medicine. Nominee. Excalibur Award. 1979: Service to the U.S. Govern ment Environmental Protection Agency. Nominee. Rockefeller Public Service Award. 1979: Advancing the Health of the American People. Environmental Protection Agency. United States May 14.1935 -5^ Buffalo. New York 090-26-9251 100233099 Preparation of this document: October 9. 1989 "Owwr H JAWVIA u o A*tVtWTlvt MO OCCm*ATX>Ot MCOCMC CURRICULUM VITAE Stanley B. Fielt MD. July lu1991 QfOre-Addres S-Qdai.-Srcurity.NQ Pale oLBirth MaritaLStatus Education: 1969 1973 Military Service: 1208 Drayton Lane Wynnewood, PA 19096 - Pulmonary Disease and Critical Care Section Medical College of Pennsylvania 3300 Henry Avenue Philadelphia, PA 19129 - 199-36-8729 August 9, 1948 Married: Children: Carol Rae Kurman Jami Marissa, 1976 Seth Jordan, 1983 Marla Anne, 1987 _ B.S.-University of Connecticut, Storrs, CT. M.D.-Medical College of Pennsylvania, Philadelphia, PA. None. Postgraduate-Training and Fellowship Appointments: 1973-1974 Intern in Medicine, Temple University Hospital, Philadelphia, PA. 1974-1976 Medical Resident, Temple University Hospital, Philadelphia, PA. 1976-1978 Fellowship, Pulmonary Disease Section, Hospital of the University of Pennsylvania, Philadelphia, PA. Hospital Appointments: 1978-1991 1982-Prcs. 1988-1991 1991- Temple University School of Medicine American Oncologic Hospital St. Christopher's Hospital for Children Medical College of Pennsylvania - Faculty Appointments: 1978 1983 1990 1991 Assistant Professor of Medicine, Temple Univ. School of Medicine. Associate Professor of Medicine, Temple Univ. School of Medicine. Professor of Medicine, Temple University School of Medicine. Professor of Medicine, Medical College of Pennsylvania. Special. Cgrtificatigi?; - 1976 1978 1985 1985-1989 American Board of Internal Medicine, A.B.I.M., Candidate #054-569 Pulmonary Board of Internal Medicine, A.B.I.M. Certified NIOSH "A" Reader of Pneumoconiosis Certified NIOSH "B" Reader of Pneumoconiosis Licensure; 1976-present Pennsylvania - MD015547E - Agacfe. Honocs.and Membcrsbo-in.Hg.narary Societies; 1969 1972 1973 1973 1973 1973 1978-82 1984-88 1986-88 1987-88 1989-91 Graduate Cum Laude, University of Connecticut Alpha Omega Alpha . . Lange Book Award in Medicine Rittenhouse Book Award Mosby Book Award Graduate Cum Laude, Medical College of PA Pulmonary Academic Award, National Heart, Lung and Blood Institute (#lK07-HL446-01-05 MR) Special Projects of Regional & National Significance (SPRANS) - Awarded by Maternal and Child Health Care (MCHC). "Transition of Patients with Cystic Fibrosis to Adult Care.'1 Smith Kline French Pharmaceuticals: Grant for studying Genetics of Cystic Fibrosis. Cystic Fibrosis Foundation - Heart-Lung Transplantation (#A0Q88-2) Preventive Pulmonary Academic Award - NIH (1K07-HL02103-01A! 2 ttatiunaJ; 1972-present Alpha Omega Alpha 1975-present American Thoracic Society 1975- present American College of Chest Physicians 1977-present Association of American Medical Colleges 1977- present American College of Physicians 1979-present Society of Clinical Decision-Making 1982-present American Federation of Clinical Research Local: *. 1976- present Philadelphia County Medical Society 1976-present Pennsylvania Medical Society 1978- present LAENNEC Society _ 1978-present Pennsylvania Thoracic Society Fellowship in_Professional and Scientific Societies: 1983 1983 FCCP - Fellow of the College of Chest Physicians FACP - Fellow of the American College of Physicians Publications; Watkins, D.T., Cooperstein, S.J. and Fiel, S.B.: Studies on the selectivity of alloxan for the Bceils of the islets of Langerhans: Effect of pH on the in vitro action of alloxan. J. Pharm. & Exo. Therapy 208:184-189, 1979. Glanz, K., Fiel, S.B., Walker, L.R. and Levy, M.R.: Preventive health behavior of physicians. L. Medical Education. 57:637-639, 1982. '. Fiel, S.B., Swartz, M., Glanz, K. and Horowitz, J.: The efficacy of short-term corticosteroid therapy in the out-patient treatment of acute bronchial asthma. Amer. J. Med.. 75:259-262, 1983. Glanz, K. and Fiel, S.B.: Attendance at lectures and medical school performance. J. Med. Ed. 59:516-518,1984. Fiel, S.B. and Swartz, M.: Letter to the Editor, Importance of route of administration of steroids in asthma. Am. L-Med. 76:A101-102, 1984. Glanz, K., Fiel, S.B., Swartz, M.A. and Francis, M.E.: Compliance with experimental drug regimen for treatment of acute asthma in adults: Its magnitude, importance and correlates. L S.B. Fiel, MD 3 Publications (continued) Fid, S.B. and Drezner, D.: Clinical problem-solving. Pennsylvania Medicine. 88(6):46-51. 1985. Fid, S.B.: Cystic fibrosis in the adult. Philadelphia Medicine. 81:197-201. 1985. Fid, S.B.: Corticosteroids should be routinely used^for acute episodes of asthma requiring emergency care or hospitalization. Pharmacotherapy. 5(6):327-335, 1985. Fid, S.B. and Friedman, A.E.: The use of MRI in cystic fibrosis. Chest. 91(2): 181 -182 1987. Fid S.B.: Experiences with a CF transition program. International Association of Cystic Fihm^i<j Adults. 11:13-15, 1987. Huang, N., Schidiow, D.V. and Fid, S.B., et al. Clinical features, survival rate, and prognostic factors in young adults with cystic fibrosis. Am. J. Med. 82(5):871-879, 1987. Hoffman. I. and Fiel, S.B.: Oral vs repository corticosteroid therapy in acute asthma. Chest. 93:11-13, 1988. *. Friedman, A.C. and Fiel, S.B.: High resolution: CT evaluation of occupational lung disease. Amsr*.J ,qf RosoigaiQlgOL 150:269-275, 1988. Rindsberg, S., Friedman, A.C. and Fid, S.B., et al.: MRI of tracheomcgaiy. J. Can. Assoc. Radiol. 38:126-128, 1988. _ Fid, S.B.: Cystic Fibrosis in the Adult. Emergency Medicine. Jan. 1988. Fid, S.B.: Heart-Lung Transplantation in Cystic Fibrosis - Overview. Ped. Pulmonology, Supplement 2:63-64, 1988. Fid, S.B.: Manifestations of CF in Adult Patients - Are They Different? Ped. Pulmonology. Supplement 2:81-82, 1988. Friedman, A.C., Radeclri, P. and Fid, S.B.: Detection of asbestosis with HRCT. Radiology. 170:278-279, 1989. Dillman, N.J., Ceglowski, W.S., and Fid, S.B.: False-positive tests for human immunodeficiency virus (HIV) in patients with cystic fibrosis. Annals of Int. Med. 110:94, 1989. Fid, S.B., Friedman, A.C. and Radecki, P.D.: Evaluation of pulmonary disease: Clinical role of conventional and high-resolution CT. Radiology Report. 1(2): 188-205, 1989. S.B. Fid, MD 4 Publications (continued) A'F" H'gh reSOlUti0n CT "d asb"'0s exPsure- Radiology Reoon Fiel, S.B.: Clinical Consultation - ER care of asthma: Which is better, oral or I.M. steroids? L Reso. Pis.. 10(3): 12, 1989. Friedman, A.C. and Fiel, S.B.: Roentgenograph under estimatation of early asbestosis by ILO classification system. Chest 95:1166-1167. 1989. . Fiel, S.B., et ai.: Hean-iung transplantation in cystic fibrosis - Overview. Clinical Transplantation. 3:162-163, 1989. Cooney, G.F., Fiel, S.B., Shaw, L.M., and Cavarocchi, N.C.: Cyclo- sporine bioavaiiability in heart-lung transplant candidates with cystic fibrosis. Transplantation. 49(4):821, 1990. Friedman, A., Fiel, S.B.: CT of Benign Pleural and Pulmonary Parenchymal Abnormalities Related to Asbestos Exposure. Seminars in CT. Ultrasound and MRI 11(5): 393-408, Oct. 1990. Fiel, S.B., Widerman, E.: Transplantation of CF in the United States. 1990 International . Association of Cystic Fibrosis Adults. Issue 23 pg. 8-10, 1990. Fiel, S.B.: Mechanical ventilation in the severely ill adult with cystic fibrosis. Pediatric Pulmonology Suppi 5 147-150, 1990. Fiel S.B.: Heart-lung transplantation - A test of clinical wisdom. Archives of Internal Medicine. 1991; 151:870-872. First, W.H., Fox, P.W. Campbell, Fiel, S.B., Loyd, J.E. and Meniil, W.H. Cystic Fibrosis Treated with Heart-lung Transplantation: North American Results. Transplantation Proceedings 1991; 23(1): 1205-1206. . -. Hewitt, A., Glanz, JC, Fiel, S.B.: Preventive Pulmonary Medical Education - review of its importance, status and challange. - Chest 100;487-93, 1991. Schidlow, D., Fiel, S.B. et al.: - Guidelines for cystic fibrosis patient care in Cyscit Fibrosis Centers. Accepted - Archives of Diseases of Children - 1991. Fiel, S.B. Providing comprehensive care to adults with cystic fibrosis. J. Reso. Pis. 12(7):669- 682, 1991. - Fiel, S.B.: Therapeutic options in cystic fibrosis - Ann. Int. Med. Submitted 1991. Lewiston N, Fiel, S.B., Rosenstein B., et al.: Clinical charactistics of CF patients accepted as candidates for heart lung transplantation in the U.S. - Submitted Chest 1991. S.B. Fiel, MD 5 Published Abstracts Fiel, S.B., Atkinson, B.F. and Ochs, R.H.: Reasons for failure and suggestions for rebiopsy in tiansbronchial lung biopsies. ARRD 117(4): 113, 1978. Fiel, S.B., Swartz, M., Glanz, K. and Frances, M.: The efficacy of short term corticosteroid therapy in the out-patient treatment of acute bronchial asthma. Clin. Res. 30(20):428a, 1982. Yeung, W.H., Schidlow, D.V., Fiel, S.B. and Kueppers, f.: Antibody to pseudomonas cepacia in sera of patients with cystic fibrosis. Cvstic Fibrosis Club Abstracts. 1986. Bethesda. MD. Fiel, S.B., et al.: Transition of young adults with cystic fibrosis to adult care. Pediatric Pulmonary. 1986, Bethesda, MD. Fiel, S.B. and Friedman, A.C.: High resolution CT evaluation of asbestos exposed individuals. ARRD 35(4):A133, 1987. Fiel, S.B. et al. MRI in Adults with Cystic Fibrosis. Respiratory Diseases Digest. 8:4-5, 1987. Cooney, G.F., Fiel, S.B.t Hoffman, I.B. and Rocci, M.D.: Effect of disease severity on Tobramycin clearance in adult cystic fibrosis patients. ARRD 137(4):502, 1988. Fiel, S.B., Christensen, G.C. and Cavarocchi, N.: Transbronchial biopsy (TBB) in the diagnosis of chronic rejection of heart-lung transplantation (HLT). ARRD 137(4):468, 1988. Quitteil, L.M., Fiel, S.B., Schidlow, D.V. and Cavarrocchi N.: Transplanted lungs retain normal potential differences in cystic fibrosis. ARRD 137(4):302, 1988. Fiel, S.B., Muza, S.R., Silverman, M.T. and Kelsen S.C.: Impaired perceptual acuity of inspiratory resistive loads by heart-lung transplant recipients. Presented at FASEB, Las Vegas, NV, May 1988. Fed. Proc. 2(4):A514, 1988. Cooney, G.F., Rocci, M.L., Fiel, S.B., Boczar K.E. and Lazin, B.M. Does Tobramycin clearance differ in adults with cystic fibrosis? Clin Pharmacol Ther. 42(2) 1988. Cooney, G.F., Rossi, M.L. and Fiel, S.B.: Does tobromycin clearence differ in adults with cystic fibrosis? Pharmaco Ther Vol 8 *2, 1988. Muza, S., Silverman, M., Kelsen, S. and Fiel, S.B.: Cardiopulmonary responses during exercise in cystic fibrosis heart-lung transplant candidates. Pediatric Pulmonology. 1988, Supplement 2. Fiel, S.B., Christensen, G.C. and Cavarocchi, N.C.: Transbronchial biopsy in the diagnosis of chronic rejection of heart-lung transplantation. Pediatric Pulmonology 1988, Supplement 2. S.B. Fiel, MD 6 Published Abstracts (continued) Fiel, M.D., and Friedman. A.C: Literature Review: Journal of Abstracts. Radiology Rep^q i(2):279-280, 1989. ~.... " Lewiston, N., Fiel, S.B.. Rosenstein, B.t Muza, S.t Ross, D., and Theodore J.: Clinical characteristics of cystic fibrosis patients accepted as candidates for heart-lung transplantation. ARRD 139(4): A566, 1989. - Fiel, S.B. and Hoffman, I.B.: Oral vs. respository corticosteroid therapy in acute asthma. Int. Synopses. In Press 1989. Cooney, G.F., Fiel, S.B., Shaw, L.M. and Cavarocchi, N.C.: Bioavaiiabiiity of oral cyclosporin A in heart-lung transplant candidates with cystic fibrosis. Pediatric Pulmonology, p. 144 (supplement 4), 1989. Lewiston, N., Fiel, S.B., Rosenstein, B., Muza, S., Eddy, G., Starnes, V., and Baldwin, J.: Clinical characteristics of cystic fibrosis patients accepted as candidates for heart-lung transplantation. Pediatric Pulmonology, p. 143 (supplement 4), 1989. Fiel, S.B., Friedman, A.C. et al.: Respiratory diseases and function in a group of firefighters. Chest 96(2) (supplement) August 1989. Boczar, K., Widerman, E., and Fiel, S.B.: Symptoms, self perception and illness severity in the adult with cystic fibrosis. Pediatric Pulmonology Suppl. 5, pg 278, 1990. MonQgraphLand -Chapters Fiel, S.B.: Clinical simulations in the management bf a pneumoconiosis. In: Temple University Bulletin. Continuing Medical Education, 1980. Fiel, S.B.: Restrictive lung disease. Audio Digest. Family Practice. 29:9, 1981. Fiel, S.B.: Smoking, occupational exposure and neoplasms: Their relationships. Audio Digest. Eanuly.Prastigfi 31:8,1982, Fiel, S.B.: "Infections in the immunosuppressed patient-. In: The Respiratory System - A Core Curriculum. Gong^H. and Drage, C., eds. Norwalk, Conn.: Appleton-Century-Crofts, 1982, 217-223. * Fiel, S.B.: Clinical simulations in the management of a pneumoconiosis (update). In: Temple University Bulletin. Continuing Medical Education, 1983. S.B. Fiel, MD 7 Monographs and Chapters (continued) Computer program for computer assisted instruction on "COPD." 1983. Fiel. S.B.: Emergency management of severe bronchial asthma. Monograph for the Upjohn Company, March, 1984. *. Fiel, S.B. and Fein, A.: "Asthma." In: Pulmonary Disease Reviews V. Bone, ed., 1984. Fiel, S.B. and Fein, A.: "Asthma." In: Pulmonary Disease Reviews VI. Bone, ed., 1985. Fiel, S.B.: "Pulmonary Diseases." In: Outline of Medicine. Myers, A., ed., 1986, Hanvail Publications. Fein, A.M., Fiel, S.B. et ai. "When the pneumonia does not get better." Clinics in Chest Medicine. Niederman, ed. Vol 8(3) 9/87. Fiel, S.B., Schidlow, D.V., Bronheim, S., MacGrab, P.: "Transitioning chronically ill adolescents - CF prototype" Georgetown University Press 1988. Fid, S.B.: Chronic obstructive pulmonary disease. Monograph for Temple University Continuing Medical Education, 1988. Fid, S.B.: Transitioning of patients from pediatric to adult care. Surgeon General's Conference, 1989. _ Fid, S.B. and Cooper J.: "Lung Transplantation". In: Chronic Obstructive Pulmonary Disease. Cherniak, N., ed. W.B. Saunders Co. Chapter 59, pg 546*553. Schidlow, D.V., Fid, S.B.: Life Beyond Pediatrics: Transisiton of chronically ill adolescents from pediatric to adult health care systems. Medical Clinics in North America. 74(5): 1113-1120, 1990. Fiel, S.B.: "Pulmonary Diseases an Outline of Medicine" 2nd Edition, Myers et al, Harwell Publications (Submitted) 1991. Fid, S.B.: "Medical Aspects of Lung Transplantation" Seminars of Respiratory Medicine. In press, 1991. S.B. Fid, MD 8 Selected Invited Papers and Visiting Professorships: 05/06/78 Pennsylvania Association of Clinical Pathologists Meeting, Hershey, PA,"Transbronchial lung biopsies." 05/06/78 Pennsylvania Association of Clinical Pathologists Meeting, Hershey, PA, "The effect of monocrotaline and its pyloric metabolic DHMC on the lung and pulmonary circulation of the dog." . 12/03/79 The University of California at San Francisco, "Experimental pulmonary hypertension." 03/10/80 Community College of Philadelphia, "Pulmonary Diseases." 03/80 Lancaster County Hospital, Lancaster, PA. "Restrictive lung disease." - Part of a Family Practice Symposium. 04/80 University of Michigan, Ann Arbor, "Short course steroids in the emergency room treatment of asthma." 05/80 American Thoracic Society Meeting, Washington, DC, Pulmonary Academic Awardee Conference. 05/81 American Thoracic Society Meeting, Detroit, MI, Pulmonary Academic " Awardee Meedng. 08/26/81 ' Scranton Hospital, "Hypersensitivity pneumonitis" 11/16/81 New York University, "Newer trends in treatment of COPD." 12/06/81 Nazareth Hospital, Philadelphia, PA, "Bronchodilator treatment." 01/08/82 Riddle Hospital, Philadelphia, PA, "Bronchodilator treatment." 01/20/82 Presbyterian University of Pennsylvania Medical Center, "Pulmonary hypertension." 01/26/82 Millville Hospital, Millville, NJ, "The adult respiratory distress syndrome." 02/03/82 Jeanes Hospital, Philadelphia, PA, "Oxygen therapy." 03/04/82 Lancaster County Hospital, Lancaster, PA. "Cigarette smoking and how it affects the genesis of carcinoma among workers exposed to particular matters." S.B. Fid, MD 9 Selected Invited Parers and Visiting Professorships fcflmiDtfCd) 03/28/82 Washington County Hospital, Hagerstown, MD, "Newer trends in the treatment of COPD." 04/16/82 "Workshop on clinical interpretation arterial blood gas measurements." Sponsored by General Diagnostics Corporation, Philadelphia, PA. 04/21/82 St. Agnes Hospital, Philadelphia, PA; "Interstitial Lung Disease." 05/15/82 The American Thoracic Society Meeting, Los Angeles, CA, "The pulmonary academic award and its future." 06/08/82 New York University, New York, "Regional report on the pulmonary hypertension registry." 07/20/82 Medical Center of Princeton, NJ, "Cystic fibrosis in the adult." 09/17/82 St. Francis Medical Center, Trenton, NJ "Newer trends in oxygen treatment. 11/82 Medical faculty utilization of student lecture evaluations. Am. Public Health Association Annual Meeting, Montreal, Canada. 11/10/82 New Jersey College of Medicine and Dentistry, "Steroid therapy in asthma." 11/11/82 Hershey Medical Center, Hershey, PA, "Newer trends in chronic airflow obstruction." 11/19/82 NIH - Pulmonary Hypertension Quarterly Meeting, New York, NY. 11/27/82 Critical Care Conference - Director, ACP Course, Atlantic City, NJ. 01/12/83 Philadelphia Pediatrics Symposium, "Arterial Blood Gases." 01/27/83 Computers in medidne, Scottsdale, AZ. 03/22-3/23 Visiting Professor, Charlotte Memorial Hospital. 03/25/83 - Philadelphia Pediatrics Symposium "Primary pulmonary hypertension." 04/21/83 Guifffe Medical Center, Philadelphia, PA, "Update: Bronchodilators. " 04/26/83 Millville Hospital, NJ, "Newer trends in COPD." S.B. Fiel, MD 10 Selected Invited Papers and Visiting Professorships (continued) 04/27/83 Sacred Heart Hospital, Philadelphia, PA, "Interstitial lung disease," 05/08/83 Pulmonary Academic Awardees - "Overview." Annual ATS Meeting, Kansas City, MO, ~ * 06/16-17/83 NTH, Chicago, IL, "Primary pulmonary hypertension registry update." 09/23/83 Brandywine Hospital, "Respiratory failure." 10/04/83 Metropolitan Hospital, Philadelphia, PA, "Pulse steroid therapy of asthma." 10/19/83 Methodist Hospital, Philadelphia, PA, "Cystic fibrosis". 10/26/83 Mercer Medical Center, Trenton, NJ, "Office spirometry." 11/16/83 American Public Health Association, Annual Meeting, Dallas, TX, "Asthma and compliance." ** 11/83 Temple University Sugarloaf Conference Center, Philadelphia, PA, Cystic fibrosis retreat, "Adult cystic fibrosis." 12/15/83 - Temple University School of Pharmacy, Philadelphia Philadelphia, PA, "Asthma medication for the pharmacologists." 2/8/84 Berks County Medical Society Grand Rounds, "Update of chronic obstructive pulmonary disease." 3/8/84 Hospital of the University of Pennsylvania, Philadelphia, PA, "Pulmonary functions and asbestos related disease." 3/21/84 Pennsylvania Thoracic Society, Marriott Motor Lodge, Philadelphia, PA, "Current topics in pulmonary disease." 3/29/84 Memorial Hospital, Burlington County, Mt. Holly, NJ, "Update on chronic obstructive pulmonary disease." 3/21/84 Newcomb Hospital, Vineland, NJ, "Newer concepts in the treatment of asthma and COPD." 4/10/84 Thomas Jefferson University Hospital, Philadelphia, PA, "Steroids in asthma." S.B. Fid, MD 11 Selected Invited Papers and Visiting Professorships (continued) 4/27/84 Pulmonary Academic Awardee Conference, New York, NY. 5/84 American Thoracic Society Meeting, Miami, FL, "Update on pulmonary question bank." . 7/84 WPEN Radio Talk Show, Philadelphia, PA, "COPD and Smoking." 7/18/84 Presbyterian-University of Pennsylvania Hospital, Philadelphia, PA, Grand Rounds, "Update: COPD." 7/25/84 Chestnut Hill Hospital, Philadelphia, PA., Medical Grand Rounds, "Corticosteroids in asthma." 9/5/84 Channel 10 - WCAU Television, Philadelphia, PA, "Asbestos in today's environment." 9/11/84 Abington Hospital, Abington, PA, Grand Rounds. Management of asthma." 9/23-24/84 Chicago, IL. Two-day Symposium on "Lysine Acetylsalicylate as an antipyretic." Sponsored by Lorex Pharmaceuticals. 10/3/84 WPEN Radio, Philadelphia, PA, "Cystic fibrosis in adult, population." 10/5/84 Temple University Hospital, Philadelphia, PA, Grand Rounds, "Cystic fibrosis ' in the adult" 10/12-13/84 Regional Cystic Fibrosis Retreat, Sugarioaf Conference, Philadelphia, PA. 10/24/84 11/7/84 Pediatric Pulmonary Center, Philadelphia, PA, "Arterial blood gases." Hahnemann University Hospital, Grand Rounds, Philadelphia, PA, "PgEl in ARDS." 11/12/84 Nassau Hospital, Nassau, NY, Grand Rounds, "Cystic fibrosis in the adult, pulmonary update series." 3/12/85 -- Current topics in pulmonary disease for the 7th Annual Pulmonary Disease Course for the Pennsylvania Thoracic Society. 4/3/85 Temple University Hospital, Pharmacologists, Philadelphia, PA, "Pharmakinetics of drugs in cystic fibrosis." S.B. Fiel, MD 12 Selected Invited Papers and Visiting Professorships (continued) 4/9/85 Princeton Hospital, Princeton, NJ "Adult cystic fibrosis." 4/23/85 West Jersey Hospital, Grand Rounds, "New therapies in pulmonary hypertension." 5/12/85 Lankenau Hospital, Bryn Mawr, PA, Grand Rounds, "Cystic fibrosis in the adult." - 5/29/85 Presbyterian-St. Luke's Hospital, Chicago, IL, Grand Rounds, "PgEl in ARDS." 8/8-10/85 Cystic fibrosis journey on the Argo - Presentation of use of Ceftazidine in cystic fibrosis - Monterey, CA. Sponsored by Glaxo Pharmaceudcals. 9/20/85 V.A. Medical Center, Wilkes Barrc, PA, "New approaches to chronic airway obstruction." 9/27/85 Jersey City Medical Center, Jersey City, NY, "The adult with cystic fibrosis." 9/30/85 Medical College of Virginia, "Asbestos in the workplace." 11/1/85 CF Retreat, Philadelphia Pediatric Group, Philadelphia, PA, "The use of MRI in cystic fibrosis." 12/26/85 Good Morning America, WPVI-TV, Channel 6, Philadelphia, PA, "Humidifiers and Pulmonary Disease." 1/7/86 Frankford Hospital, Philadelphia, PA, "The adult with cystic fibrosis." 1/12/86 Society of Gastroenterologic Radiology, Acapulco, Mexico "Abdominal ultrasound vj MRI in cystic fibrosis." 1/29-30/86 Scramon/Temple Residency Affiliated Hospital, Scranton, PA - Visiting Professor. . 4/1/86 Albert Einstein Medical Center, Philadelphia, PA "Adult Presentations with Cystic Fibrosis." 4/2/86 Hahnemann University, Philadelphia, PA - "The adult with cystic fibrosis." Visiting Professor. 4/14-18/86 ' Amer. Roentgen Ray Society, Washington, DC, "MRI in cystic fibrosis." S.B. Fid, MD 13 Selected Invited Papers and Visiting Professorships (continued) 5/2/86 5/13/86 5/16/86 6/7/86 6/16/86 8/21/86 10/23 11/9/86 12/2/86 4/3/87 4/7/87 4/10/87 4/27/87 5/11/87 6/14/87 2/4/88 CF Club, Bethesda, MD, "Transitioning patients in cystic fibrosis." American Thoracic Society Meeting, Kansas City, "Use of MRI in cystic fibrosis." Children's Rehabilitation Center, University of Virginia, Charlottesville. VA. "Transitioning of patients in cystic fibrosis." Issues of Transition Conference. 30th Anniversary Celebration of MCHC (Maternal Child Health Care), Washington, DC. "Transition issues for chronic illness." - Surgeon's General Conference. Springfield Township School District - Panel Discussion: "Asbestos in Schools." Eagle Lodge, Philadelphia, PA Seminar in Occupational Medicine through Temple University School of Pharmacy, "Asbestos-Related Disease.'- . People's Republic of China, Seminar through Temple Continuing Medical Education, "Pulmonary diseases." Delaware Valley Hospital, "Update COPD." _ Georgetown University, Pediatric Grand Rounds "Transition to adult care in cystic fibrosis." Abington Hospital, Abington, PA, "Adult respiratory distress syndrome." Cystic Fibrosis Foundation, "Heart-lung transplantation indications and protocol for patient follow-up." American Roentgen Ray Society, Miami, FL, "Asbestos-related pulmonary disease - Evaluation with CT." American Thoracic Society, New Orleans, LA. "Occupationally related diseases evaluated by high resolution computerized tomography, HRCT." Surgeon Generals Conference, Houston, TX, "Improving care of young adults with cystic fibrosis." York Hospital, "Corticosteroids in asthma." S.B. Fiel, MD 14 Selected Invited Papers and Visiting Professorships (continued) 2/9/88 LANNEC Society, Heart-lung transplantation - FocuS-CF. ..... 3/25/88 Family Practice Review -"Asbestos related diseases." 4/29/88 Deborah Hospital, Brownsmiil, NJ, "Management of the adult with cystic fibrosis." 5/8/88 American Thoracic Society Meeting, Las Vegas, NV - Meet the Professor Seminar "Management of the adult with cystic fibrosis." 5/19/88 Allied Health School, TUH Eagle Lodge, Phila. PA. "Occupational diseases." 5/25-26/88 Georgetown University - Keynote speaker for Transition Conference "Disability of children with CF." 6/2/88 Visiting Professor - University of Wisconsin "Heart-lung transplantation." 7/12/88 Cystic Fibrosis Foundation - Ad Hoc Committee on adult care in cystic fibrosis - focus on 1990's . 7/24/88 KYW News Radio - Philadelphia, PA. Smoking and Pulmonary Disease. 9/28-10/1/88 North American Cystic Fibrosis Foundation Conference - Orlando, Florida. Symposium leader on the adult with cystic fibrosis and symposium presenter on heart-lung transplantation - The North American Experience. 10/12-26/88 Group leader for CME Course from Temple University Medical School Kenya, East Africa - Lectures and medical visits. 11/11/88 Michigan State University - Visiting Professor - Heart-lung transplantation in the adult with cystic fibrosis. 11/13/88 American Heart Association - Washington, DC - Symposium presenter on International Experience of Heart-Lung Transplantation. 11/21-23/88 Guest Speaker for French Thoracic Society - Paris, France (Cyclosporin and Nutrition in Transplanted Patients with Cystic Fibrosis). 12/6/88 Grand Rounds - Abington Hospital - Philadelphia, PA. Adult with Cystic Fibrosis. S.B. Fiel, MD 15 Selected Invited Papers and Visiting Professorships (continued) i/9/89 Cornell University - Lung Transplantation and the Denervated Lung. - Visiting Professor. 3/13-15/89 Surgeon General's Conference - Youth with Special Health Care Needs Presenter - Jekyil Island, GA? 5/17/89 American Thoracic Society - Cincinatti, Ohio. "Meet the Professor" Respiratory Infection in CF. _ 6/2/89 University of Pennsylvania Hospital - Manifestation of CF in the Adult. 6/9-11/89 GAP Conference - Cystic Fibrosis Foundation - "Xenograft and Transplantation - Symposium participant and presenter. 9/11/89 Preventive Pulmonary Academic Award Meeting - Portland, Oregon - Smoking Cessation in the Workplace. 10/12-14/89 North American Cystic Fibrosis Conference - Tarpon Springs, Florida Symposium leader and presenter on Heart-Lung Transplantation in CF. 10/25-27/89 Grant review for NIH Preventive Pulmonary Academic Award. 11/1/89 American College of Chest Physicians - Poster presenter - Asbestos Related Pulmonary Disease in Firefighters. 03/26/90 Philadelphia College of Osteopathic Medicine - Emergency Room Treatment of Asthma. 04/5/90 Continuing Education Center for Health Pro- fessionals - Triton College, Chicago, Illinois - Visiting Professor - Cystic Fibrosis and Lung Transplantation. 4/23-24/90 Pan American Conference of the College of Chest Physicians - San Juan, Puerto Rico - Symposium leader and presenter on asthma and cystic fibrosis. 5/17-18/90 7th Canadian Cystic Fibrosis Foundation "Broken Arrow" Conference Transplantation in CF. 05/20/90 American Thoracic Society "CF Beyond the Gene" -Symposium leader Boston, MA. S.B. FieL MD 16 Selected rnvited Papers and Visiting Professorships (continued) 05/23/90 American Thoracic Society - Meet the Professor Seminar on the Adult with Cystic Fibrosis - Boston, MA. 06/7/90 Visiting Professor - University of Oklahoma. 10/3/90 North American Cystic Fibrosis Conference - Crystal City, VA - (l) use of Mechanical Ventilation in CF and (2) heart-lung transplantation in CF. 11/2/90 Medical College of Pennsylvania - Visiting Professor - Emergency room treatment of asthma. 2/20/91 University of Texas, San Antonio - Visiting Professor. 4/9/91 University of Pittsburgh - Visiting Professor. 4/17/91 State University of New York at Stony Brook - Visiting Professor. . 5/15/91 American Thoracic Society - Symposium Leader - Management of the Adult with Cystic Fibrosis. Admingtratlyg.RMnsit?niti; . 7/91-present Chief, Pulmonary Disease <fc Critical Care Medicine Section, Medical College ` of Pennsylvania Departmental (Temple University Hospital) 1989-1991 Program Director, Fellowship Program 1988- - Director, Lung Transplant Program 1987- Deputy Chief, Pulmonary Disease Section and Director Clinical Services 1982- * Residency Advisory Committee, Department of Medicine 1985- ' Practice Plan Committee 1985- * Director, Respiratory Care Department 1984- Director, Adult Cystic Fibrosis Program 1983- " Senior Student Advisor - Dean Appointed 1982- * Residency Selection Committee, Department of Medicine 1983-1988 ' Laser Committee 1985-1987 Acting Chief, Pulmonary Disease Section 1983-1984 Chairman of Long Range Planning Committee - (Sub-Committee of Curriculum Committee). 1982-1985 Planning New Hospital, RICU, Respiratory Therapy and Pulmonary Function Laboratory S.B. Fiel, MD 17 Administrative Responsibilities: (continued) Departmental (Temple University Hospital) 1982-1984 1982-1984 1981-1985 1980-1985 1978-1985 Short Procedure Unit Steering Committee Curriculum Committee Director, Fiberoptic Bronchoscopy Service, Pulmonary Disease Section * Director, Systems Disease T & II (Introduction to Clinical Medicine), Department of Medicine Organizing and Standardizing the Systems Disease I and II Courses for the Department of Medicine. I am supervising all course directors in faculty evaluation, test production and course syllabi. Director, Medical Student Education, Pulmonary Disease Section National 1990-present ACCP - Steering Committee - Clinical Problems Assembly 1989- " Planning Committee - Surgeon's General Conference on "Transition in Health Care- 1988- " Exec. Committee, Pennsylvania Thoracic Society 1988- " Adult Care Subcommittee - CF Foundation . 1982- " Representative of American College of Chest Physicians Forum on Infection and Immunology 1981-1988 Pulmonary Data Bank Committee of Pulmonary Academic Awardees; Creating a National Question Bank for Pulmonary Disease Course Directors in Medical Schools. 1983-1984 Publication Committee of NIH Registry for Pulmonary Hypertension 1982-1983 - Charter Member of Society for Clinical Decision Making and Member Education Committee 1980-1983 --Chairman of the Steering Committee of Pulmonary Academic Awardees Local 1987-present Pulmonary Thoracic Society, Executive Committee 1984- " Medical College of Pennsylvania, Awards Committee 1983-1991 Sl Christopher's Hospital for Children/Temple University Hospital, Director of Cystic Fibrosis Program for Adults 1984 Pennsylvania Thoracic Society, Planning Committee for Annual Pulmonary Course 1991 St. Christopher's Hospitai/Medical College of Pennsylvania, Director, Cystic Fibrosis Program Systems Disease Course is a lecture/small group discussion course involving all the medical subspecialities. The course plans the last six months of the sophomore year. Pulmonary Academic Awardee (PAA) - National Institute of Health Five year Award for Pulmonary Education. (PAA) S.B. Fiel, MD 18 Outside Activities 1988-Present Reviewer, Abstracts for CFF National Meeting 1988 -" NIH Grant Review Study Section - Ad Hoc - Pulmonary Education &. Asthma Management. 1987-1988 Ad Hoc Committee - Cystic Fibrosis Foundation - Grant Reviewer - Adult Demonstration Education Outreach Grant. 1983-1987 Director of an NIH Registry Center for Primary Pulmonary Hypertension 1982-1985 Professional Standard Review Organization of Philadelphia Evaluation of Physician Behavior in the Treatment of COPD and Pneumonia 1980-1987 National Committee of PAA*s to Write Test Question Bank for Computerized Testing Service for Pulmonary Disease Section Editorial Easttionsi 1985-present American Journal-of Medicine (Reviewer) 1985- " Research Grant Review Committee, Pennsylvania Thoracic Society 1985- " Archives of Internal Medicine (Reviewer) 1985- " Tempie Medicine 1986- " Chest (Reviewer) 1987- Journal of Laboratory & Clinical Medicine (Reviewer) 1988- " Annals of Internal Medicine (Reviewer) 1989 " - Journal of Allergy & Clinical Immunology (Reviewer) 1989- * American Review Respiratory Diseases (Reviewer) Areas nf Research; Ginical studies involving asthma, cystic fibrosis, pneumoconiosis, and heart-lung transplantation. Preventive Pulmonary Disease - Applications for Teaching Work-in. Eromssi Corticosteroids in cystic fibrosis Protocol for early rejection and follow-up in patients with heart-lung transplantation Aerosolized antibiotics in cystic fibrosis Use of a neutrophil dastasc inhibitor in cystic fibrosis Use of Amiloride in cystic fibrosis S.B. Fiel, MD 19 Courses and Conferences Organized; 1981 10/16-18/82 10/83 3/84 10/88 1/89 10/89 5/90 10/90 5/91 11/5/91 11/91 Pulmonary Function Tests and Arterial Blood Gases Post Graduate Course for the American Medical Association Critical Care Medicine for the American College of Chest Physicians Critical Care Medicine for the American College of Chest Physician Pennsylvania Thoracic Society - Pulmonary Diseases Symposium Organizer - Adults with Cystic Fibrosis - North American Cystic Fibrosis Foundation * Planning Committee - Surgeon's General Conference on Transition Symposium Organizer - Heart-Lung Transplantation in Cystic Fibrosis - North American Cystic Fibrosis Foundation Symposium Leader - American Thoracic Society - CF Beyond the Gene Symposium Organizer - National Cystic Fibrosis Conference Symposium Organizer - American Thoracic Society - Adult Care of CF Symposium Presenter - American College of Chest Physicians "Aerosol therapy in cystic fibrosis" Symposium Leader and Presenter - North American Cystic Fibrosis Meeting Dallas. * *' Cflures.Attcndgd; 12/13-16/82 Scientific Basis for Evaluation of Asbestos Associated Disease. Irving J. Selikoff, M.D., Course Director, Mt. Sinai Medical Centex, NY. 6/83 Laser's in Medicine, Philadelphia College of Osteopathic Medicine. Hands on Course for Laser Certification. 12/83 American College of Radiology. "A" reader course in preparation for "B" reader in pneumoconiosis. " - 2/85 Update Pulmonary Disease. Puerto Valletta, Mexico. 3/85 "B" Reader Preparatory Course. Kiawah Island, SC. 5/7-9/87 Primary Pulmonary Hypertension. Registry Summation, NIH, Philadelphia, PA. 1/27-1/30/88 Snowbird Conference - Pulmonary Disease Update, Snowbird, UT. S.B. Fiel, MD 20 DMR &. ass( k :i.vn-:s/ ( > CHI| >tl It 1(1 l-lfiv'lt* >t It 1 K lltill I It N lift 1 < : HISIlllilMIS r Donna M, Rinqo. Certified Industrial Hygienist #3190 Bom: August 31, 1947 604 Pennyroyal Way Louisville, KY 40223 (502) 245-5289 EPVCftTXgiL- M.S.P.H., Industrial Hygiene. Birmingham, March 1982. University of Alabama in Thesis: "Development of Passive Dosimetry for Evaluation of Employee Exposures to Nitroglycerin Vapor." B.S. - Chemistry, Jacksonville State University, 1977. (Three years of credits were earned at Florida State University) . WORK EXPERIENCEi Sept. 1992-Present: DMR & Associates Inc, President. Newly formed Industrial Hygiene Consulting firm (following the sale of CRU, Inc to ORR Safety Corporation). Nov. 1984-Aug. 1992 June 1982-Nov. 1984 1978-1982: CRU, Inc, President. Industrial Hygiene Consultant. Occupational safety and health consulting to a wide variety of "service industries, manufacturing and government. Taught EPA approved asbestos courses. Regional Industrial Hygienist-Hercules. Responsible for industrial hygiene programs in 13 chemical plants, primarily in the Southeastern U.S. Duties included plant evaluations of Health Hazards, providing assistance to plant managers on Industrial Hygiene problems, and guidance on methods of compliance with government regulations. Protection and Hearing Conservation Programs. Control Chemist II, Hercules Inc. Fifty percent of time spent on industrial hygiene testing and evaluations for corporate headquarters in Wilmington, Delaware. Additional duties included OSHA and EPA sampling and reporting, NPDES applications, procedure manual writing, and consultations to new products and engineering groups. P.O. Box 24467 Louisville. Kentucky 40224 (502) 245-5289 1977-1978: 1968-1970: MEMBERSHIPS: Research Chemist, UAB Medical Center Molecular Biophysics Laboratory, Birmingham, Alabama Chemist, Department of Agriculture . Tallahassee,^Florida. American Industrial Hygiene Association American Board of Industrial Hygiene American Academy of Industrial Hygienist American Society of Safety Engineers Past Treasurer and Past President of Kentuckiana Local AIHA Section J. LeRoy Balzer, PhD. 40* Horse Trail Coon Walnut Creek; California 94595 (510)274-0*26 Fax: (510)274-1413 EDUCATION PhD. Environmental Health Sdenccs University of California, Berkeley, California NLS. Public Health / Preventive Medicine / Industrial Hygiene Udvcmiy ofCalifornia. Los Angelos, California B.S. Microbiology 1 Public Health University ofCalifornia, Loa Angela, California Stanford Executive Program Stanford University, Palo Alto, California - . 1971 1963 1962 1979 EXTOTTNOC CONSULTING WDUSTTUAL HYGIENIST 198$- hyyffle, and environmental health and safety - Expert tnnmoay/forensic science/sane ofthe art UNTVERSITY OF CALIFORNIA, SAN FRANCISCO 1993- Retired Assistant Vice Chancellor, Environmental Health and Safely -Leaner in the School ofMedicine and School ofNursiaf -Memberof U.CPrtsiricnrtCouncilcmNsrlnnalLtbocnmies. Panel aa Envuomnenr. Safety sad Health UNTVERSITY OF CALIFORNIA, SAN FHANCISCO 19*7-1993 ASSISTANT VICE CHANCELLOR. ENVIRONMENTAL HEALTH AND SAFETY qyjmnmil hCtltfa t"d Safety ttKhl^ng safety, chemical safety, environmental health, fire safety, hazardous waste, t hyyere, <yctrp*Tirtn*^ h'rttt*1. T*4ffii*?n tafrty and safety *^"*>* - Managed a *4 milling departmental budget with a staffofsixty-five - Supervised health, safety, and environmental policy for the San Francisco campus iv| if wrtwiqy* locations -Rcprcaauad the Udvcmiy on health, safety, and environmental issues before local and state props and agencies - Lectured and researched in the School ofMedicine RHP-UTAH INTERNATIONAL, INC.. San Fraadsco. California MANAGER MARKETING THERMAL COAL AND NON-FERROUS METALS MANAGER CORPORATE MARKETING, INFORMATION AND RESEARCH 1971-1917 1983-19S7 - Partidpaxcd in developing strategy fot gdacxai sale* financing and contract agreements - -Managed a S2 million imenatioml marketing research department with. a staff of 17 people - Coordinated inicrnarinail and domestic sales support programs metudlag development ofa corporate market strategy for five cnmmrvlidcs - - Supervised and planned budgets and tracked overall marketing activities for 60 people with an afvmfyl htti\f*rcif t7 mtlHrm - - Organized market coverage and analysis system for more than 200 costomen in 50 countries with annual tales of SL5 billion DIRECTOR ENVIRONMENTAL QUALITY 1971-1983 - Organized the corpotatt environmental snd lndusmai hygiene programs -Managed a corporate environmental program budge of 333 million with a staff of 14 professionals . - developed, negotiated monitored an environmental aM risk program in five cnmmT** vt the United States Effected responses tt environmental legislative and itgnlaioiy issues - Managed health, safety, toxic waste, water, air quality and hzardoos risk analysis programs (OSHA, NEPA, RCRA and ocher state, federal cod internatioml laws aad regulations) - Represented the corporate p^*^kh? on tppliration for op?*^TM*"** brfrtr y* ff^yi spd gy ipe UNIVERSITY OF CALIFORNIA, BERKELEY INDUSTRIAL HYGIENIST AND ENGINEERING SPECIALIST 1963-1971 1966-1971 Directed and participated in industrial hygiene and air qaality research programs in the School* of Pnbris Health, Mechanical aad Civil Engineering - Actively managed S0.75 million of government, private and foundation giants - Organized* foil health and safety program for the Western States Asbestos Union - Coordinated and conducted indmtmi hygiene consulting for a nnrqiw ofdomestic ,ne^ intrmttri^rral fiftfpnfri*nf HEALTH AND SAFETY TECHNICIAN 1963-1966 -Partidpated in industrial hygiene, safety, health, biological and physical sciences safety, radiation, animal care and air monitoring programs -Managed compliance programs for local, cate and fedaal laws and regulations PROFESSIONAL AFFILIATIONS American Chemical Society American Conference ofGovernmental Industrial Hygienists-AffiEne American Industrial Hygiene Assnaaticn . American Society of Safety Engineers Interrutinrul rnrnmiution on Sigma XI Honorary Soctay August 1994 J. LEROY BJU-ZER^PhD. SELECTED PUBUCATIONS . Biker, JJL: Tnrfnml Hyg*<-np far Tnoilrtlrtn Wnricm" Jnnrnat nf(Vrnjmiftnri Medirinc, Pg. 26-31, September 29,1967. . . Baker, LL. and Cooper, W.C: The Work Eavircmment ofInsulating Workers." ATHAT Volume 29, Mty-June 1961. . - Cooper, W.C. and Baker, IX.: "Evaluation and Cocad ofAsbestos Exposures in the Insulating Trade.' Pmtxftiinfi nf fhr Sfflmri laienwlnml fmifrrracc on the Bintagial Eftoi nf Atacama. Dresden. Germany, April 1961. - Baker, JJL: "Enviroamexual Expoeue* in the Insalaticn Trade." NICA QUTI.OQK. February 1970. - Baker, XL.: "Guide for Respirable Mass Sampling" AIHAI. VoL 31, March-April 1970. -Lim, J., Baker, JX* Wott. CJL, and MUby, TJL: "FSier Qlaa Remfixccd Plastics." Associated (fracnpgtinnri Health Problem*. An* Fnvimn Health VaL TO. April 197H Tcbbens, B2),, Baker, JJL and Fowler, DJPl "Health Effects of Parocalitg AkPolfatiar Characterkltion fl/Tampac* ami HhBM riwpnBuntf * Prefect Hbh Atr 'DnivemQr fCalifenda. Berkeley, VoL 2 No. S-17, September 1970. -Taberabaw, LE^ Cooper, W.C, and Baker, LL.: "A Labor-Management Ooaipatkmal Health Senhee in a Crmmietifla lndmary * Arehn* nfEnviron Health 11; rtaewnhnr 1970 - Fowler, DJP,, Baker, JJL and Cooper; W.C: "Expoaurc oflnsnlation Wodcen to Airborne Fibrous Qlaa*.* AIHAI 32:16-91, Feb. 1971. - Baker, JJL.: "Aerodynamic Behavior erfFferont Aerosol*: Relationship to Selective Sampling * PhD. Disaenatioa, University of California, Bakeley, 1971. , - Baker, JJL, Cooper, W.C and Fouler, D.P.: "FIbnres Glass Lined Air Transmission Systems: An Aaseasneot oftheir EsvbooaentalESecta." AIHAJ 111. 312-311.1971. - Baker; J.L, Fowler, D-P.aad Cooper, W.C: *DfrPnirtnring Potential ofConatroctioa Materials." Safety and Health tn SMptariW+mf and Ship Btyatnny 30 AagUX >2 Srptrmhfr 1971, Qccnpattocal Safety and Health Scries, facrnattoaal Labour Office-Geneva, 1972. - Baker. LL.: Inertial and Grariatiooal Cnltonrs". Air Sampling lrumtmwi for Evaluation of Atmospheric nootammaow 1972. -Baker, JJL: "Environmental Bata: Aitbamc Conormtioni Found in Variona Operations". Ofiflinitinnal Firwawm taFihmpa fibw Svmporimn* IT S TVpt ofHEW PbMir Bwhh K+nit* Pg. 1249, April 1976. - Heinsohn, P,, Jewett, DL, Baker, JJL, Borneo, CiL, SdpeL P. and Roaea, A.: "Aerosols Created by Some Surgical Power Took: Particle Size Distribution and Qualitative Hemoglobin Content" AnpHed Qmmannnal Envhnnmfnft September 199L " IN RE: NOV - y 1994 NO. 94-CI-10078 ...... ~s r\ ri i \ ;< -Z' _ _ ASBESTOS LITIGATION S $ IN THE DISTRICT COURTS OF S BEXAR COUNTY, TEXAS VERIFICATION OF DEFENDANTSf OBJECTIONS, ANSWERS AND RESPONSES TO MASTER INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO: Plaintiffs in Bexar County, . Texas, by and through their attorneys of record, Baron & Budd, A Professional Corporation, The Centrum, 3102 Oak Lawn Avenue, Suite 1100, Dallas, Texas 75219. COME NOW, Garlock Inc and The Anchor Packing Company, Defendants herein and by and through their counsel of record, file the attached Verifications of their Objections, Answers and Responses to Master Set of Interrogatories and Request For Production of Documents. Respectfully submitted. BROWN McCARROLL & OAKS HARTLINE, A REGISTERED LIMITED LIABILITY PARTNERSHIP ATTORNEY IN CHARGE T. JOHN WARD STATE BAR NO. 20848000 WALTER CLAY COOKE STATE BAR NO. 04759800 MELISSA K. FERRELL STATE BAR NO. 06937020 1300 Wortham Tower 2727 Allen Parkway Houston, Texas 77019-2100 Phone: (713) 529-3110 Fax: (713) 525-6295 ATTORNEYS FOR DEFENDANTS GARLOCK INC AND THE ANCHOR PACKING COMPANY Certificate of Service I hereby certify that a true and correct copy of the above and foregoing instrument was sent by certified mail, return receipt requested, to counsel for Plaintiffs and by regular mail to all other counsel of record on the 15 day of November. 1994. Mr. Russell W. Budd BARON & BUDD 3102 Oak Lawn Avenue Suite 1100 Dallas, Texas 75219-4257 ATTORNEYS FOR PLAINTIFFS K:\PSVQARLOQC\53019.1 991.70736 STATE OF NEW YORK COUNTY OF NEW YORK I hereby certify that I am authorized to respond to these interrogatories and requests for production on behalf of Garlock Inc in ray capacity as Assistant Secretary and that to the extent that I am personally familiar with the information set forth in the answers, I certify that the answers are correct, and to the extent that I am not personally familiar with the information provided in the said answers, I certify that the information is correct to the best of my information and belief based on my investigation of these matters. Sworn to and subscribed before me this A9 day of n eTkrl. 1994 NOTARY PUBLIC State of New York My commission expires____ Bexar County, Tcxaa STATE OF NEW YORK COUNTY OF NEW YORK I hereby certify that I am authorized to respond to these interrogatories and requests for production of documents on behalf of The Anchor Packing Company in my capacity as Assistant Secretary and that to the extent that I am personally familiar with the information set forth in the answers, I certify that the answers are correct, and to the extent that I am not personally familiar with the information provided in the said answers, I certify that the information is correct to the best of my information and belief based on my investigation of these matters. fSworn to and subscribed before me this ^ day ofJt ,o NOTARY PUBLIC State of New York My commission expires 31.1996 Travu County, (lt Amended)