Document qdbpLoJ8wvawK9r4EJavLyOgk

I 1 INTERROGATORY NO. 65: 2 At any time prior to 1972 were any tests or studies con 3 ducted or sponsored by defendant to determine: 4 (a) The level of airborne dust or fiber concentration 5 incident to: 6 (i) Arching, sanding, clipping, grinding or bev 7 eling defendant's asbestos-containing products: 8 (ii) Placing the products on/in motor vehicles and 9 other machinery requiring such products; 10 (iii) Tearing down the product during repair and 11 maintenance functions; 12 (b) Whether long-term (5 years or.more) exposure to 13 products containing asbestos below 5 million particles per cubic 14 foot (mppcf) might cause asbestosis or expose the user of said 15 product to an increased statistical risk of developing: 16 (i) Bronchogenic cancer; 17 (ii) Mesothelioma (pleural or peritoneal); 18 (iii) Gastrointestinal cancer; 19 (iv) Asbestosis. 20 RESPONSE: 21 No . 22 INTERROGATORY NO. 66: 23 Was the concentration of the airborne asbestos fibers prior 24 to 1972 at job sites at which defendant's asbestos-containing 25 products were used within the prescribed threshold limit values? 26 If so, state the source of the information and the date said 27 information was obtained. 28 /// ARO '1 6' 60 -35- i I