Document qdrnKGvLMMZ3nB303VdZoLrE5

K 343 IN THE UNI'T&EysfcJTATES. DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ,............................................................................................................................................. X In Re: :No. . Asbestos Products Liability :MDL 875 I Litigation (No. VI) : ------------------- - x. UNITED STATES DISTRICT COURT FIFTH DIVISION DISTRICT OF MINNESOTA x CONWED CORPORATION, Plaintiff, -against- UNION CARBIDE CHEMICAL AND PLASTICS COMPANY, INC., (f/k/a UNION CARBIDE CORPORATION), Defendant. UNION CARBIDE CHEMICALS AND PLASTICS COMPANY, INC. (f/k/a UNION CARBIDE CORPORATION), Case No. 5-92-88 x Third-Party Plaintiffs, - against - OWENS-CORNING FIBERGLAS CORPORATION, WALKER JAMAR COMPANY, A.W. KUETTEL & SONS, INC., API, INC. and MacARTHUR COMPANY, ' Third-Party Defendants. x I November 18, 1994 EDWARD B. ILGREN Doyle Reporting, Inc. CERTIFIED STENOTYPE REPORTERS Total Litigation Support WALTER SHAPIRO. CSR CHARLES SHAPIRO. CSR r 369 LEXINGTON AVENUE NEW YORK. N.Y. 10017 .' (21.2) 867-8220 : FltE COPY UCAREF00009177 r 344 i November 18, 1994 - 9:45 a.m. Continued deposition of EDWARD B. ILGREN, taken by Plaintiff, pursuant to adjournment, held at the offices of Kelley Drye & Warren, Esqs., 101 Park Avenue, New York, New York, before David Ocanas, a Certified Shorthand Reporter and Notary Public within and for the State of New York. I \ UCAREF00009178 345 Appearances: STITCH ANGELL KREIDLER & MUTH, ESQS. Attorneys.for Plaintiff The Crossings Suite 120 250 Second Avenue South Minneapolis, Minnesota 55401 By: ROBERT D. BROWNSON, ESQ., of Counsel -and- RUDNICK & WOLFE, ESQS. 203 North LaSalle Suite 1800 Chicago, Illinois 60601 By: MICHAEL GOLDMAN, ESQ., of Counsel FOLEY & LARDNER, ESQS. Attorneys for Defendant 777 East Wisconsin Avenue Milwaukee, Wisconsin 53202-5367 By: TREVOR J. WILL, ESQ., of Counsel KELLEY DRYE & WARREN, ESQS. Attorneys for Defendant 101 Park Avenue New York, New York 10178 By: ALAN GERSON, ESQ., of Counsel Also Present: VIRGINIA RUSZCZYK .oOo- UCAREF00009179 1, 1 1 l 1 4( 1 , ' J 1 * 1 9i! | j * ( 1 1 l j 1 ' i 0 1 346 2 EDWARD B. ILGREN, resumed, 3 having been previously duly sworn, was 4 examined and testified further as follows: 5 6 7 8 9 10 ' 11 12 13 14. 15 16 MR. BROWNSON: We're back continuing your deposition in the case of Conwed versus Union Carbide. And this is a continuation of the prior deposition in this case. I want to start with a few preliminary matters that hopefully we can dispense quickly. The issue of the documents we requested at the last deposition. I understand you made a search for and have been able to produce some things and maybe not some other things. 17 What I would like to do is ask you what you 18 looked for, what you produced and what- you 19 didn't produce. And maybe the easiest way 20 is for me to go through my list of things. 21 unless you think it might be easier for you 22 to explain to us what you did. I'll take 23 suggestions from you. 24 MR. WILL: Do you have the list we . 25 provided you? That would probably -- DOYLE REPORTING,' -INC-. - 21.2-867-8220-.' UCAREF00009180 r 1 Ilgren 347 2 MR. BROWNSON: The list you 3 provided? No. _ 4 MR. WILL: You got the Federal 5 Express documents. 6 MR. BROWNSON: I got the box, but 7 there wasn't a list. ; t8 MR. GERSON: There was a list in 9 mine. 10 MR. BROWNSON: Off the record. 11 (Discussion off the record) 12 (Whereupon, document entitled 13 "Unpublished Materials & Correspondence 14 Pertaining to Calidria Reviewed for Conwed 15 Versus UCC by Dr. E.B. Ilgren as of 10 16 November '94" marked Plaintiff's Exhibit 13 17 for identification, as of this date.) 18 (Recess taken) 19 EXAMINATION BY \ 20 MR. BROWNSON: 21 Q. Now we've marked as Deposition i 22 Exhibit 13, an alphabetical typewritten list, i 23 looks like you prepared, of various publications 24 and documents. Is that what this is? '25 . . A , . ' , Yes. . . DOYLE REPORTING, INC. - 212 - 867 - 8220 UCAREF00009181 r 1 Ilgren 348 2 Q. And it's entitled "Unpublished 3 Materials & Correspondence Pertaining to Calidria 4 Reviewed for Conwed Versus UCC by Dr. E.B. Ilgren 5 as of 10 November '94." 6 A. That's correct. 7 Q. And I guess can we take that to mean 8 what it says, these are things you have reviewed 9 in connection with this case as of a week ago? 10 A. As- stated, yes. 11 Q. Have you reviewed anything else since 12 November 10 that pertains to this case or any 13 opinions you intend to give in this case? 14 A. Off the top of my head, no. But 15 there may be other things that just don't spring 16 to my mind. 17 Q. If there were other things, would i 18 those be in the nature of published things or 19 manuscripts as opposed to specific Conwed 20 documents? 21 . A. I believe so, though I'm not 100 22 percent sure. 23 MR. WILL: I don't know whether 24 you're categorizing generally, but I think 25 Dr. Ilgren has seen'since then the portions " "` DOYLE REPORTING, 'INC'.- ' - '212- 867-8220. ' UCAREF00009182 1 Ilgren 349 2 of Fred Bergstrom's deposition, and James 3 Ministo's deposition and the U.S. G sample - 4 survey that was marked in Ken Brule's 5 deposition. . 6 MR. BROWNSON: Just to complete that 7 point, you've seen portions of James ' 8 Ministo's deposition in his Ministo versus 9 Union Carbide case? 10 A. I presume so. 11 Q. Portions of a deposition of Fred 12 Bergstrom, do you know which deposition that was? 13 A. I don't recall. 14 Q. Do you know what was the topic or 15 subject matter of the portions of that deposition 16 that you reviewed? 17 Q. Could you ask that again? 18 Q. What was the subject or topic matter, 19 of the Bergstrom transcript that you reviewed? ' ' ` 20 A. This X recall where Bergstrom worked 21 in the Conwed facility, what he worked with, 22 whether the conditions under which he worked were 23 dusty or not. 24 Q. Have you been asked by Union Carbide 25 or lawyers for Union Carbide to review the DOYtB REPORTING, INC.'. - 212-8 6 7-822 0 UCAREF00009183 'r " Il'gren' 355 2 MR. BROWNSON: What files? 3 MR. WILL: His files. 4 A. You asked us to bring -- 5 Q. I asked you to bring the records you 6 reviewed. 7 A. That's it. 8 Q. Did those files contain anything 9 other than records you reviewed? Do they contain 10 letters or reports that you generated? 11 A. There are a few annotated notes here 12 about different aspects of the case, but there are 13 no individual reports here. 14 MR. WILL: I think what they tend to 15 be are just excerpts from the records, just 16 put in one place. 17 Q. For instance I'm looking at your file 18 on Stanley Fleisch. The file contains some 19 medical records, a letter from the Mayo Clinic, a 20 letter to myself. Dr. Mark Wick, University of 21 Minnesota from the Duluth Clinic to Mr. Clark's 22 lawyers. Some treatment record from the Duluth 23 Clinic with history and that sort of thing. And a 24 pathology report from a pathologist from the 25 Duluth clinic. In addition to those records, it DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009184 Ilgren 356 contains some notes which looks like things that you have generated. I'll just show those to you and ask you, first of all, are these things that you generated or were those - A. I generated it. Q. I take it you have notea of that type that you generated in each of these six files? A. I've got them here on Broeffle. This is an empty folder. I don't think I did it every single case. There's none in Maki. Let's see. None on Manisto. I don't see any here on Roseth. Q. Now for the record just so we can identify, you got files which you produced here today. One on Mr. Fleisch, one on Roseth, one on Ministo, one on Maki and one on Broeffle. And then you say you have one on Mr. Bodway but you don't have it here today? A. I don't believe so. Q. Now have you reviewedanything else with respect to the medical condition or diagnosis of these Conwed mesothelioma cases. A. Like what? Q. Other than what's here in your file. A. Like slides or anything like that? DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009185 I 1_ ". , f ' ,, ' . I 1 '` Ilgren '' 358 1 2 A. No. Were any done? 3 Q. Not that I'm aware. That's why I'm i} 4 asking you. [ 5 A. No. 6 Q. Have you made any request of Union .\ 7 Carbide or Union Carbide lawyera that, you would '] 8 like to either do that yourself or see that done 9 on any of those people? I [ 10 A. I would like to see it done, but 1 i 11 haven't made a specific request at this point in J 12 time. . ! 13 Q. Are you aware of any such work that's :j 14 contemplated or being undertaken at the present "J 15 time on behalf of Union Carbide? 2 16 MR. GOLDMAN: What do you mean by 1 17 "such work"? j1 18 Q. Do you know whether -- as far you as 1 19 know, is either contemplating or is actually doing - 20 lung tissue fibre burden analysis on any of these 21 Conwed mesothelioma cases? 3 A. Do I know Union Carbide -- 1 ' 23 Q. Union Carbide or people acting on IBS' 24 their behalf. 1 A. I don't know. 1 DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009186 I * ' * . ' ** ,, w.< t ' ' > *. * * . 1 ;* ... . * \ * * . *` Ilgren ' . * . , 359 1 2 Q. If it has, it hasn't come to your / 1 3 attention? y 4 A. I don't know what Union Carbide [ s thinks. ,) 1 6 Q. The question is not meant to be \1 7 tricky. Have they told you or do yon know if -- "t 8 A. No. ) 9 Q. All right. i 10 A. No one has said anything about it ) 11 being done. 12 Q. And how about with respect to Mr. . jl 13 Bergstrom, do you know whether there's any such - 3 14 lung tissue fibre burden analysis being 15 contemplated on behalf of Mr. Bergstrom's on 1 0.1 16 behalf of Union Carbide? -J 17 A. I might be wrong, but I believe he 18 didn't have a post-mortem. I don't think there's ] 19 any available tissue, but no one has asked me to 2 0 do such. m! 21 Q. Do you have a file with respect to 'Jifi 22 Mr. Bodway? 1 "' A. I believe so, yes. 24 Q. Do you also have a file with respect I 25 to Mr. Bergstrom? I guess all you've seen is a 1 DOYLE REPORTING, INC. - 212-867-8220 UGAREF00009187 1 Ilgren `360 2 portion of his deposition. Have you opened a file 3 on that? 4 A. I don't think so, not yet. 5 Q. Do you plan to do that? 6 A. Sure, when I get information. 7 Q. Now you've told us that :in your view, 8 one or two or more of these six putative 9 mesothelioma cases among Conwed workers raised 10 questions in your mind, but you can't recall 11 exactly which ones as to the diagnosis? 12 A. That's right. 13 Q. Were there any among of those group 14 of six which in your mind were unquestionably 15 mesothelioma that you did not have questions on? 16 A. Yes. 17 Q. Do you remember which one those were? 18 * A. I don't remember which ones they 19 were, but there were certainly cases that I think 20 one would accept as confirmed mesothelioma. 21 Q. As you sit here today, do you 22 remember how many there were? 23 A. No. 24 Q. If we looked at your five files here, 25 could you tell from looking at those which ones DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009188 1 Ilgren 361 2 you would accept as confirmed diagnoses of 3 mesothelioma? -_ 4 A. I haven't reviewed them in detail in 5 some time. I would have to go through them again 6 and make some more notes. 7 Q. Let me ask you this. I note that 8 your files contain -- I didn't look at all of 9 them, some of them contain reports from Mark Wick, 10 a pathologist from St. Louis? ' 11 A. Yes. ` 12 Q. Are you aware that Dr. Wick was a 13 pathologist that we retained on behalf of Conwed 14 to review these cases? 15 A. Yes. 16 Q. With respect to these six cases, 17 would you be in agreement with Dr. Wick, that is 18 in cases where he says the diagnoses of 19 mesothelioma are confirmed? Are those the 20 cases - 21 MR. WILL: Unless he takes the time 22 to review these records, I don't think 23 that's an appropriate question. 24 MR. BROWNSON: Let me rephrase it. 25 Q. Was it the report of Dr. Wick that DOYLB REPORTING, INC. - 212-867-8220 U CAR E F00009189 1 Ilgren . 3 62 2 you relied on in making the statement that some of 3 these cases were uncontested -- not Union Carbide. f 4 contested but confirmed mesothelioma, in your J 5 view? 6 A. It was more than his report. It was ] 7 certainly a contributing factor. There were a lot J 8 of different things. I would like to be able to 9 go in detail if we're going to talk about them, 1 10 just to refresh my memory. 3 11 Q. Can you do that here today during the 12 course of this deposition or is that something 13 that would take longer? i 14 A. It would take longer. ' 15 Q. But suffice it to say as we sit here .3 16 today in this deposition on November 18, there are ] 17 certain of the six cases that you accept as 18 confirmed mesothelioma diagnoses? 3 19 A. It's my recollection that's the case. 1 20 Q. And do you recall if there was more 21 than one of the cases where that is true? 22 A. I believe so. 23 Q. Do you recall if it's more than two? 24 A. Perhaps. I don't recall exactly. 25 Q. All right. Now, in addition to DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009190 1 ' _ ' ilgren - 3 64' . . ; 2 facilities where they may have had amphibole 3 exposure. At least one, I think it was Ministo, 4 discussed how he worked with amosite under very 5 dusty conditions. 6 Q. Is it your opinion. Dr. Ilgren, that 7 chrysotile asbestos has nothing to do with the 8 mesothelioma in these six cases? 9 MR. WILL: In general. 10 Q. In general at this point? - 11 A. No, I don't believe it did. 12 Q. No, you don't believe it did - t 13 restate your answer. 14 A. I don't believe chrysotile 15 contributed to the development of any of these 16 mesotheliomas. 17 Q. Let me ask you some questions about 18 that. What do you base that statement upon, what 19 facts? 20 A. My sense is that virtually all of the 21 chrysotile is Union Carbide chrysotile and Union 22 Carbide calidria. 23 Q. It's your view that 24 chrysotile-exposed workers who develop 25 mesothelioma get that disease from something else DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009191 1 ) 1 Ilgren . ' ` ' 3.65 . ' 2 other than chrysotile? 3 A. That's correct. 4 Q When you looked at the six cases of 5 Conwed workers, what you were doing was looking to 6 see if they had any exposure to amphibole- type of 7 asbestos? 8 A. That's correct. 9 Q. Do you believe that amosite can cause 10 malignant mesothelioma? 11 A. I do. 12 Q. Do you believe that any of the 13 mesotheliomas among these these six Conwed workers 14 were exposed to amosite asbestos? 15 A. Conceivable. 16 Q. Do you have any firm opinion on that 17 one way or the other? 18 A. Probably. 19 Q. What is that opinion? 20 A. Probably. 21 ' Q. Probably that some were or probably 22 that all were or what? 23 A. Certainly some were. 24 Q. Do you know which ones? 25 A. No. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009192 1 Ilgren 366 2 Q. Now do you believe that some of these 3 mesotheliomas among Conwed workers were caused to-- 4 exposure to crocidolite asbestos? 5 A. I do. 6 Q. What is the factual basis for that 7 opinion? 8 A. To the best of my recollection, I 9 would have to go back and read the details of the 10 case. Both Mr. Ministo and Mr. Bergstrom worked 11 under very dusty conditions with crocidolite in 12 the R&D facility for, I think it was several 13 years, at least a couple of years, and based on my 14 appreciation of the types of levels and exposures 15 and settings in which people who use crocidolite 16 develop these mesotheliomas, I would say their 17 mesotheliomas were due to the crocidolite they 18 used. 19 Q. Is it your view there has never been 20 a reported case in this country of a malignant 21 mesothelioma caused by exposure to chrysotile 22 asbestos only, free of amphibole? 23 A. Could you read it back. 24 (Question read) 25 A. People have claimed to report them in DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009193 1 Ilgren 367 2 the country. I don't necessary accept they: have 3 proven that they're because of chrysotile alone-. 4 Q. Whatever case reports there may be 5 of malignant mesothelioma is due to chrysotile 6 asbestos, it's your view that they were not - 7 it's your view they were caused by something else? 8 A. I would like to look at the 9 individual papers, that's my opinion. In that 10 question, were you referring to chrysotile free of 11 amphibole? 12 Q. By chrysotile, I mean pure 13 chrysotile. 14 A. All right. 15 Q. I assume that opinion means that in 16 your view, calidria brand asbestos, which we're 17 talking about in this case, is incapable of 18 causing malignant mesothelioma? 19 A. That's correct. 20 Q. Do you know why if that's true. Union 21 Carbide has settled the mesothelioma cases arising 22 on the Conwed workers? 23 MR. WILL: Don't answer that 24 question. It's absolutely not an 25 appropriate question under Rule 408. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009194 1 Ilgren 3 68 '' ' 2 MR. BROWNSON: So you're instructing 3 him not to answer? - 4 MR. WILL: Yes. 5 Q. I asked you a few questions in this 6 regard last time. Let me just finish the point 7 here. - 8 Have you done work on behalf of Union 9 Carbide in any personal injury cases outside of 10 the Conwed workers which involve exposure or 11 alleged exposure to Calidria asbestos? 12 A. Yes. 13 Q. In particular I want to focus on 14 mesothelioma cases. Have any of those involved 15 mesothelioma? 16 A. Not that I recall. 17 Q. Do you know if any of them involved 18 any other cancer, lung cancers? 19 MR. GERSON: Or esophageal? 20 A. Esophageal. 21 Q. How many cases were there, was that 22 one case or more than one? 23 A. How many esophageal cases, I think 24 one. 25 Q. Other than that esophageal case, have DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009195 I. I' ll 2 3 ,) 11 1 Ilgre'n 369 2 you worked on behalf of Union Carbide on any. other 3 cases involving exposure or alleged exposure to 4 Calidria asbestos? 5 A. I believe there has been three 6 Curry, Hodges, Holmes. . 7 Q. Which of those three cases was the 8 esophageal cancer? 9 A. I don't recall right off the top of 10 my head. 11 Q. Were the other two asbestosis or some 12 other pulmonary problem? 13 A. I believe one was asbestosis. 14 Q. Do you recall what the third was? 15 A. No. 16 Q. Do you know whether in any of those 17 three cases , there was a lung tissue fibre burden 18 analysis done? . 19 A. No. 20 Q. By that, do you mean you don't know 21 or it wasn' t done? 22 A. I don't know. The cases settled very 23 quickly, I did very little work on it. 24 Q. Do you recall whether you ever saw 25 any lung tissue fibre burden analyses in any of DOYLE REPORTING, INC. 212-867-8220 UCAREF00009196 1 Ilgren ' 370 2 those cases? 3 A. I don't remember. I don't recall. 4 Q. Just to finish up on these three 5 cases, do you remember where those cases were 6 venued, in what court? 7 A. Let's see, at least one was in Texas 8 and the other two, I don't recall. 9 Q. And do you remember what the exposure 10 to Calidria asbestos was in that Texas case? 11 A. I don't recall. 12 Q. Other than those three cases, have 13 you ever done any work on behalf of Union Carbide 14 or on your own reviewing or looking in any way at 15 groups of workers exposed to Calidria asbestos 16 other than the Conwed workers or other than the 17 people out at King City? 18 MR. GOLDMAN: Other than the three 19 cases we talked about? 20 MR. BROWNSON: Those were three 21 individuals cases, I'm now asking about 22 groups of exposed workers. 23 A. Such as? 24 Q. Well, I don't know, that's why I'm 25 asking the question. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009197 1 Ilgren `3 71 2 A. It'a a bit vague. Give me an 3 example. 4 Q. For example. Union Carbide sold 5 Calidria asbestos over the years to many different 6 customers who used it in many different settings, 7 whether in plants or factories or oil fields or 8 different things. And what I'm wondering, you've 9 reviewed or looked at these three individual cases 10 you told us about. 11 A. Right. ` 12 Q. In addition you've done some work 13 with respect to the Conwed workers? 14 A. Yes. 15 Q. And in addition to that, I know that 16 you've at least looked at in some respects at 17 information dealing with the workers out at the 18 line at King City? 19 A. Yes. 20 Q. What this question is,are there 21 other workers anyplace exposed to Calidria 22 asbestos that you reviewed or looked at? Are 23 there any other workers? 24 A. No. 25 Q. Are you awareof any sort of DOYLE REPORTING, -INC. - 212-867-8220 UCAREF00009198 1 ' Ilgren 3 72' 2 epidemiological study done by anyone dealing with 3 any other group of Calidria-asbestos-exposed 4 workers other than King City, Conwed? 5 A. Not that I can remember. 6 Q. I'm not just talking about published 7 work. I think you work -- there is no 8 epidemiological work with Calidria-.exposed 9 workers. My question went to unpublished work 10 that you may have heard of or seen. 11 A. Nothing comes immediately to mind. 12 Q. Now let's go back to the six Conwed 13 workers. 14 A. Could you ask the question again. 15 Q. I'll have the record read back. 16 (Record-read) 17 A. I don't think so. 18 Q. I wanted to go back to the six Conwed 19 mesothelioma cases you reviewed. You've told us 20 that one of the purposes of your reviews - - of 21 your review of those six cases was to look at the 22 diagnosis and another purpose was to try to 23 make -- establish some opinion as to the causation 24 of those mesothelioma. Did you review them for 25 any other purpose? Was there any question that DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009199 1 Ilgren 373 ' 2 you answered as a result of your review? 3 A. Not that I'm aware. 4 Q. With respect to possible crocidolite 5 exposure on those six workers, I understand you 6 identified the use of some crocidolite in the 7 research and development setting with respect to 8 Mr. Manisto and Fred Bergstrom, is that correct? 9 A. That's correct. 10 Q. Other than the crocidolite, are you 11 aware of any other crocidolite or potential 12 crocidolite exposure among the Conwed cases that 13 you've reviewed? 14 A. There is crocidolite marked in at 15 least five different places within the plant. 16 There was piping or some component in the plant, 17 so I really couldn't exclude some additional 18 potential exposure. The people came up who tore 19 up the pipe and one of these were were near by. 20 Q. Do you have any specific information 21 in that record from crocidolite exposure from pipe 22 covering? 23 A. Have I seen anything that says 24 crocidolite in pipe covering in Conwed plant? 25 Q. Yes. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009200 . 1.. ' '. ' . *. . 'iigr.en ' - ' 3 74 2 A. Yes. 3 Q. What have you seen in that regard? 4 A. How do w& call -- USG sample survey? 5 Q. That's USG, you mean U.S. Gypsum? 6 A. Yes. 7 Q. These are asbestos -- an asbestos 8 survey that USG has conducted after they purchased 8 9 the plant from Conwed, is that what you're talking 10 about? 11 A. Yes. 12 Q. That indicates that some samples of 13 pipe covering contained crocidolite asbestos? 14 A. Yes. 15 Q. And theinformation that you saw - 16 first of all, did you actually see a survey or did 17 you read in a deposition about this? 18 A. I sawfour large -- I guessabout 19 four foot by two foot plans, detailed plans of the 20 plant. And then a smaller plan of the plant. And 21 then a five or six-page document which listed 22 about 200 sites. So for example in the left-hand 23 column there, there was a number running from - 24 the numbers ran from 1 to 200. In, say, I don't 25 remember exactly, but the next column, there DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009201 1 Ilgren 375 2 was -- the location from which the sample was 3 taken, and then the next column was the type of 4 asbestos found, either chrysotile, crocidolite or 5 amosite. There were about -- they went from, say, 6 1 to 132, consecutively, and then for some reason 7 there were five or six missing. Then it went for 8 another ten and then there were five or six 9 missing. The number was virtually intact but 10 there were some things missing and there were 11 about 30 records where they didn't actually say 12 .crocidolite or amosite, it said positive or 13 negative. 14 Q. Do you know what the date of the 15 survey was? 16 A. I don't recall. 17 Q. Was there any information that you 18 saw, either on the survey or anywhere else, which 19 indicated when those materials were installed in 20 the plant? 21 A. When they were installed? 22 Q. Right. 23 A. I don't recall. 24 Q. Was there any information,either in 25 the survey or anywhere else, that you reviewed DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009202 1 ' Ilgren 376 2 that stated whether or not any of these six 3 mesothelioma cases we've been talking about worked 4 with pipes or pipe covering or had'any exposure to 5 those particular products that you mentioned? 6 A. Could you ask the first part of the 7 question again. i 8 (Record read) 9 A. Are you asking to my recollection if 10 any of these guys worked with pipe covering? 11 Q. Right. ' 12 A. I believe so. 13 Q. Do you know who? 14 A. No. 15 Q. All right. 16 Q. Would the information you had in that 17 regard be retained in the files we looked at 18 earlier and are going to have copied here? 19 A. I believe so. 20 Q. Really what I'm getting at, I'm 21 trying to find the sources of your information 22 with respect to that question whether any of these 23 six mesothelioma cases would have had exposure to 24 crocidolite and pipe covering. You told us you 25 got six case files -- five, of them here other than DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009203 1 .' ' ' ' Ilgren . 377 ' " 2 Mr.Bodway. Then you told us you have this USG 3 survey. Is there any other data or information 4 that you've seen - 5 A. Let's look at the list for a second. 6 MR. WILL: You're talking about the 7 exposure of the individuals? 8 MR. BROWNSON: Right. 9 A. Mr. Bergstrom, I've looked at the 10 three documents which are Bergstrom something. 11 They make reference, I think in at least two 12 documents, to the use of crocidolite. 13 Q. Let's stop there. With respect to 14 whether Mr. Bergstrom was exposed to crocidolite, 15 you have seen three documents. Are those the 16 three which are listed on the first page of 17 Exhibit 13 under Bergstrom? 18 A. Right. 19 Q. I guess maybe my question wasn't 20 clear, maybe it was. What I am wondering is, have 21 you seen any other.information concerning exposure 22 to pipe covering among these six cases? 23 A. I don't recall. I may have, I may 24 not have. 25 MR. WILL: I have not given him DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009204 1 Ilgren 378 2 their depositions, but based on your line 3 of questioning, maybe I should do that . He- 4 did read Manisto, excerpts from that. 5 Q. Now, do you have a copy of this USG 6 survey that you were talking about? 7 A. Yes. : 8 Q. And would your copy be the copy that 9 you relied on for the statements you made here 10 today for the USG survey? 11 A. Yes. ' 12 MR. BROWNSON: Can we get a copy of 13 that? 14 MR. WILL: I think you have a copy 15 of that. 16 MR. BROWNSON: I would like to 17 see -- he said there were some pages 18 missing. 19 MR. WILL: There aren't pages 20 missing. If you look on the sample survey, 21 it's missing numbers, not pages. They went 22 around the plant and took samples out of 23 each of the pipes and they put a number on 24 them. The survey that he has lists samples 25 1 through 185. But there are some numbers DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009205 I I ' 9 .1 1 1 .] ] J 1- Ilgren - 379 2 in the sequence -- there are some sample 3 numbers in the sequence that are not 4 reported. I can give you a copy of it. 5 Q. I'm just wondering, Mike Goldman ' 6 asked, is that survey listed on your Exhibit 13? 7 A. I don't think so. 8 Q. It's not something we requested 9 earlier. Just to follow-up. Mr. Will advises 10 this is something you've seen in the last week? 11 A. Yes. 12 Q. And it came from Mr. Will? 13 A. Yes. 14 Q. And you have a copy in your 15 possession? 16 A. Yes. 17 Q. So if we wanted to see the specific 18 survey that you reviewed, you still have that 19 copy? 20 A. I do. 21 Q. Now, have you been asked by Mr. Will 22 or anybody else on behalf of Union Carbide to 23 attempt to render any opinions in this case 24 against Owens - Corning or any of the third-party 25 defendants in this lawsuit? DOYLE REPORTING, INC. 212-867-8220 UCAREF00009206 1 Ilgren 380 2 A. NO. . 3 Q. Are you aware that there are 4 third-party defendants in the lawsuit? 5 A. Yes. 6 Q. And whether or notyou'vebeen asked 7 to render any opinions at the present time with 8 respect to those third-party defendants, do you 9 have any opinions as to whether any of those 10 third-party defendants, based upon the material 11 you have seen, have anything to do with any of 12 these six mesothelioma cases? 13 A. No. 14 Q. By that, youmean you have no 15 opinion? 16 A. I haven't reviewed any. 17 Q. Okay. Let's go back to Exhibit 13. 18 (Recess taken) 19 BY MR. BROWNSON: 20 Q. When we broke, we were about to look 21 at Plaintiff's Exhibit 13, which is your list of 22 documents requested at the last deposition. 23 Before we do that, can you think of anything else 24 that is not on this list Exhibit 13 that you've 25 reviewed in connection with this case or your DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009207 1 . ` Ilgren. ' -381 ' ' 2 opinions in this case? 3 A. Pertaining specifically toCalidria? 4 Q. Right. . 5 A. Nothing comes to mind. 6 Q. Have you reviewed any of the 7 deposition exhibits or documents from Dr. Kagan's 8 deposition taken earlier this week? 9 A. No, I haven't. 10 Q. Let's take a look atExhibit 13. 11 What I want to do is go through the request that 12 we had made for documents and see if I understand 13 where these things fall on the list. 14 A. All right. 15 Q. And the first thing I want to look 16 at, we had documents he maintained the in office 17 at Bryn Mawr. There were some specific things. 18 The first is the medical summaries of the six 19 Conwed workers, and I've seen five and you have 20 number six of Mr. Bodway which you'll provide to 21 us. 22 The second thing, correspondence with 23 Dr. Kevin Brown. . 24 A. I checked my files and I didn't see 25 anything -- I was mistaken, I didn't see anything DOYLE REPORTING, INC. - 212-867-8220 U CARE F00009208 CHARACTERISTICS OF AEROSOLIZED CHRYSOTTLE 47 TABLE 7 Fue* Length Distribution--Optical Microscopy Dispersion Percentage longer than stated length (jtm) Preparation Method Study 4 5 10 20 40 UICC B UICCB UICC B UICC 8 UICC B Aerosol Present 100 68.2 Aerosol Beckett" 100 32 Aerosol Timbrel? 100 22J Alcohol Timbrel? too 46.9 Celloidin Timbrel? 100 33.6 Fiber Length Distribution--Electron Microscopy 404 11 tt 21.3 16.9 12.6 3 1.7 7.0 34 Asbestos* dispersion method Instrument Study Percentage longer than stated length (tun) 0.2 l 2 3 to 20 UICC B aerosol UICC B aerosol JEFFREY aerosol TEM SEM SEM TimbrelP Present Present 100 73.6 M. 27.0 9.6 too 88.2 64.2 234 6.7 100 83.0 J0.7 24.9 8.0 3 10 20 30 30 3.2 1.9 2.7 <0 UICC B aerosol UICC B aerosol JEFFREY aerosol SEM SEM SEM Beckett" Present Present 100 43 12 100 26.4 7.4 100 32.1 10.8 6 2.3 0.8 34 2.7 l * From Figure 1a in Beckett. 1973. * Modified from Tables 6. 7. or S in Timbrell, 1970a. panicles analyzed were greater than 10 pin in length and had a mean diameter of 0.42 iim. In the present study using aerosolized samples drawn directly upon Nucleopore filters and subsequently gold coated, it was found that 34.0% of the combined fibers and fiber clusters or 28.1% of all panicles (fibers, fiber clusters, and nonfibrous panicles) in the Coalinga preparation were greater than 10 nm. in length and had a mean diameter of 2.92 /im. In a subsequent study by Siegrist and Wylie (1980), the Coalinga preparation (referred to as short-range chrysotile) was characterized for panicle size distribution by both transmission and scanning electron microscopy. The samples were prepared by hand swirling in distilled water and dishwashing liquid (for SEM analysis) and-by ultrasonification in water for 10 min (for TEM analysis). The results demonstrated that by both SEM and TEM more than 90-93% of the panicles were less than 10 /am in length and more than 93% of the panicles were less than 1 pm in diameter. In our study using aerosolized samples 71.9% of the total number of panicles were less than 10 pm in length and 68% of the total number of particles were less than 1 pm in diameter. The differences between these two methods of sample preparation and analysis UCAREF00009474 1 Ilgren 383- 2 comments or his comments with respect to those? 3 A. Possibly. 4 Q. And are there any particular cases 5 that you can recall where -- that you have 6 discussed with Dr. Kevin Brown where the issue 7 was, was this a pure chrysotile mesothelioma or 8 was it something else? 9 A. X don't recall specific things. 10 Q. Just backing up a minute, do you know 11 if that was a question in that esophageal cancer 12 case you mentioned earlier with Union Carbide, the 13 question being whether there was exposure to 14 something other than Calidria, another kind of 15 asbestos, other than Calidria? 16 A. I don't remember the case. 17 Q. Whether there was a question or not, 18 you just don't recall? 19 A. I don't remember. 20 Q. Do you maintain any file with respect 21 to that case? 22 A. I believe so. 23 Q. And do you maintain any file with 24 respect to those other two cases you worked on 25 that dealt with Calidria exposure? DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009210 1 Ilgren 384 2 A. I believe so. 3 Q. And to the extent those files still 4 exist, would they be at your office in Bryn Mawr? 5 A. Yes. 6 Q. Do you know if you reviewed any 7 tissue or tissue slides in that esophageal cancer 8 case? 9 A. I don't believe so. 10 Q. Do you know if going back to Exhibit 11 13 in the correspondence with Dr. Kevin Brown, do 12 you know if that correspondence dealt in any way 13 with the question of -- or any questions dealing 14 with the Yeager and Langer paper about the 15 exposure or the test performed with macrophages? 16 A. I don't recall, it's possible. 17 Q. And the reason I bring that up, we'll 18 get to it in a minute. One of the documents was a 19 critique of that paper by Dr. Addison. Do you 20 recall that? 21 A. Yes. 22 Q. Are you aware of any similar 23 critiquing with respect to that paper done - - 24 which would be reflected in your correspondence 25 with Dr. Kevin Brown? DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009211 1 Ilgren 385 2 A. Formal critique -- 3 Q. But any critique? 4 A. Critical comments? 5 Q. Yes. 6 A. I don''t-recall. Perhaps. 7 Q. All right. 8 Q. You were about to saysomething. Did 9 something pop in your mind on that question? 10 A. Indigestion. 11 Q. Are you aware of any other written 12 critique, whether formal or informal, of that 13 particular paper, the Yeager and Langer paper 14 other than the one you provided to us by Dr. 15 Addison? 16 A. No. 17 Q. The next thing we requestedwas the 18 category of documents, a file maintained in Bryn 19 Mawr, Conwed hygiene data. Did you find anything 20 that fell under that category? 21 A. Yes. 22 Q. Wherewouldthat be reflected in 23 Exhibit 13? 24 A. I don't thinkI realized that you 25 wanted that to be listed so it's probably not DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009212 35 1 Ilgren 2 A. No, sir. 3 Q. Are you aware ofsuch modeling he has 4 done with respect to other types of chiysotile 5 fiber? 6 A. Yes. 7 Q. Has that been published work? 8 A. Yes. 9 Q. Is there also unpublished work? 10 A. I assume. 11 Q. Is there any that you have seen? 12 A. No, sir. 13 Q. So what you have seen is his published 14 work concerning modeling ofchiysotile 15 degradation or dissolution? 16 A. Yes. 17 Q. Do you recall ofihand which chiysotile 18 he used? First ofall, was it all Canadian? 19 A. I don't recall whether it was Canadian 20 or Rhodesian. I don't recall 21 Q. That's kind ofa small point, but 22 let's put it this way, do you know if he has 23 done -- when I earlier asked you whether he had 24 done such modeling with respect to Coalinga, I 25 wasn't limiting myself to Union Carbide Coalinga, 0072 1 Ilgren 2 I was limiting myself to the deposit 3 A. Yeah, sure. Yes. 4 Q. So basically if I can summarize the 5 request you have made of Rimstidt, it's that you 6 would like him to model the dissolution or 7 degradation of Coalinga type chiysotile and 8 compare it with other types that he has modeled? 9 A. Yes, sir. 10 Q. Is that a request that you have made 11 ofUnion Carbide, to do that work? 12 A. Not yet 13 Q. Is that a request that you intend to 14 make? 15 A. Yes, sir. 16 Q. Let me ask you the same question. Do 17 you have any estimate of how long that work would 18 take, ifyou get the go-ahead to do it? 19 A. No, sir. 20 Q. Have we now covered ail of the 21 original topic, laboratory work that you have 22 requested with respect to Coalinga asbestos7 23 Have we now covered it all? 24 A. Off the top of my head, yes. 25 Q. Have you requested any TEM analysis of 0073 1 Ilgren 2 the fiber itself? UCAREF00009348 1 Ilgren 387 2 establish what's what and what's where. 3 A. I think that's why it's not, on the 4 list. We discussed this and he said he would 5 provide you with things which -- he would not 6 provide you things that you thought you already 7 have. 8 Q. So with respect to the. category of 9 Conwed hygiene data, what you have is three 10 things, the in-test report, the Union Carbide air 11 testing, and then this portion of this report from 12 Dr. Gaffney? 13 A. I believe so. 14 Q. Is there anything else that you have 15 considered in your mind to be high general testing 16 data or exposure-type data from Conwed? 17 A. Not to my knowledge. 18 Q. The next thing, Cloquet's answers to 19 Trevor, he didn't provide because we have it. You 20 reviewed certain certain interrogatory answers 21 from Conwed? ' ' 22 A. Yes. 23 Q. Have those included interrogatory 24 answers in this case? 25 MR. WILL: I.don't know if he knows. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009214 1 . ' / ' Ilgren ' 390 ' ' 2 dealing with Calidria fibre, but they're listed on 3 the list? 4 A. Exactly. 5 Q. Were those some of these things -- I 6 should address this, to Trevor. 7 MR. BROWNSON: Is it your position a we can get it as well as you can, so we 9 should get it ourselves? 10 MR. WILL: That's part of it. The 11 things that I told you that he paid for 12 maybe are a little different category. 13 Q. Let's do this. I'm trying to move 14 this along. Exhibit 13 is a list of everything 15 that you found responsive to the document request 16 from the first deposition? 17 A. That's correct. 18 ' Q. And all this stuff on Exhibit 13, 19 however, has not been copied and provided to us, 20 is that the case? 21 A. That's correct. 22 Q. As I understand it, certain things 23 were not copied and provided because we had it 24 already in the opinion of Trevor Will? 25 A. Correct. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009215 Ilgr'en 3 92 University." A. Page 2, top of the page Butler, 1980._ Q. That's a PhD thesis by Butler? A. That's correct. Q. All right. A. All of the entry documents on the bottom of page 2 and top of page 3.. Q. That would be eight documents? A. That's correct. Yes, eight documents. Q. Now anything else other than those things? A. I don't believe so, no. Q. Let's just go through these things - MR. WILL: There are nine of them. THE WITNESS: Nine entries. MR. BROWNSON: Nine entries, I'm sorry. MR. WILL: Also we didn't send you a copy of a medical screening, we talk about' the fact you that you had that. MR. BROWNSON: What I'm wondering is there are certain documents that are reports Dr. Ilgren has that you didn't DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009216 1- '' Ilgren . 393 2 provide because Dr. Elgren being -- you 3 take the position that Dr. Elgren took some, 4 time and expense to get these. If he just 5 gives them to us we'll get the benefit of 6 that time and expense without paying for 7 it. . 8 MR. WILL: Right. If you care to 9 ask him, he can tell you how to get them 10 yourself; They're available. 11 MR. GERSON: You reviewed this in 12 connection with this case and you're taking 13 the position that you won't turn them over. 14 MR. WILL: I'm not saying we won't 15 them turn over. We're not going to give 16 you the benefit of the cost that he 17 incurred. 18 MR. BROWNSON: Let me -- whether or 19 not that's -- let me ask some questions 20 about it. 21 (Recess taken) 22 BY MR. BROWNSON: 23 Q. I wanted to ask you about these items 24 on Exhibit 13 that we've highlighted under the 25 category of identified but not provided because of DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009217 1 Ilgren 394 2 cost. And the first one is this Butler PhD- thesis 3 from the University of Cardiff, Wales in Britain. 4 A. That's right. 5 Q. Is that something that you relied on 6 in any way for any of your opinions in this case? 7 A. I would have gotten the document, 8 yes . 9 Q.. Do you know if any of the serpentine 10 rocks and minerals discussed in that PhD thesis 11 came from California? 12 A. They were Coalinga samples mentioned. 13 Q. Do you know if they were specified as 14 coming from the Union Carbide mine or just 15 Coalinga samples? 16 A. I just can't recall, I'm not sure. 17 Q. For the record, I think we're 18 entitled to get this stuff. But after stating 19 that, what expense would you view as reasonable to 20 compensate Dr. Ilgren for his trouble? 21 MR. WILL: Can you give me two 22 minutes to go talk with the doctor for a 23 second about this? 24 Q. You also identified, Dr. Ilgren, 25 these nine entries which fall under the category DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009218 1 Ilgren ' 395 2 of things you got and are responsive but you don't 3 want to produce because of this cost. Did you 4 rely on any of those nine reports in reaching any 5 conclusions or opinions which pertaining to this 6 case? . 7 A. I have to recheck it. I believe so, 8 but I have to recheck the details. 9 Q. The final thing is thePinkerton 10 thesis in 1982. Is that something you relied on 11 in any way for opinions and conclusions on this 12 case? 13 A. Yes. 14 Q. And I just had a discussion with 15 Trevor Will in the hallway and agreed at the end 16 of the deposition we'll discuss with him making a 17 request for this stuff, but we still do request 18 i't. We'll discuss what arrangements can be made, 19 if any, to get that. 20 Q. Let me ask you this. In your 21 published book, Mesothelioma of Animals, that we 22 were talking at the last session of the 23 deposition? 24 A. Right. 25 Q. Do you compile or list any of the DOYLE REPORTING, INC. - 212-867-8220 U CARE F00009219 j 13 :i ) j j i i 1 Ilgren 397 ' 2 And again, are those things you looked for and 3 listed on Exhibit 13? 4 A. Right. 5 Q. . All right. # 6 A. The only thing I couldn'tfind was 7 this J. Haart, Jean Haart. I was mistaken, I 8 didn't have it, I thought I had it.. But I didn't 9 Q. What's listed as Haart, J., which is 10 Jean Haart? 11 A. Yes . 12 Q. Correspondence? 13 A. Yes. 14 Q. You couldn't find that? IS A. Correct. 16 Q. And on my letter I talked about 17 documents or correspondence from. Dr. Haart, is 18 that the same person? 19 A. I think that's the same person. 20 Q. Now let me ask you this question. 21 With respect to these published and unpublished 22 documents or reports concerning - - that we 23 requested at the deposition, did. you limit your 24 review to those which specifically deal with 25 Calidria asbestos? . DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009220 1 Ilgren . 398 2 A. I think there are some others here in 3 fact that deal with JM Coalinga, so.the answer is 4 no. 5 Q. Earlier you had made the distinction 6 between Coalinga and the other Coalinga fibers, 7 and I'm wondering if your review-here was reviewed 8 to just Coalinga or was a broad category of - 9 A. I would say there are a number where 10 I couldn't categorize, like it was a Union Carbide 11 product or something else. ' 12 Q. Then the other thing we listed was 13 NAAC, which is an acronym, letters to Conwed, is 14 that shown on Exhibit 13? 15 A. It's third from the bottom, page 1, 16 Bergstrom, 21, October 1960, letter from Algerd E. 17 Jerome. 18 Q. Next is correspondence from NIOSH, 19 another acronym of Dr. -- Drs. Jean Haart and 20 Charles Lorberau. I think it's NIOSH. I did see 21 some documents in that regard. So you have 22 produced some documents. Are there any of those 23 documents that you found but did not produce? 24 A. No, not to my knowledge. 25 Q. The other things were documents that DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009221 1 Ilgren 399 2 are not on file at Bryn Mawr. The first thing is 3 the Oxford calendar. Were you able the find that? 4 A. Yes. 5 Q. -One of the things you produced, X 6 noticed, there was some photocopy pages from 7 something about -- was it green collegiate Oxford? 8 A. Yes. 9 Q. What was that? 10 A. That's the Oxford calendar. 11 Q. Then the final thing was theinterim 12 or final report on this Shubik study on the health 13 and safety executive interim report, Oxford 14 calendar listing of Professor P. Shubik. 15 Q. Was that something that was provided 16 to us? 17 A. Yes. 18 Q. Was that something that was provided 19 to us? 20 A. Yes. 21 MR. GERSON: Now I want to look at a 22 few of these documents in a little more 23 detail. The first thing I got, why don't 24 we mark this as Exhibit 14. 25 (Whereupon, letter dated February DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009222 1 Ilgren 400 2 16, 1994 marked Plaintiff's Exhibit .14 for 3 identification, as of this date.) 4 Q. Exhibit 14 is one of the documents 5 you produced after your last deposition. This is 6 a letter to you from -John Addison. 7 A. Right. 1 8 Q. What's the date? 9 A.. 16 February, 1994. 10 Q. I'm looking at the first page, which 11 is the message to you from Dr. Addison, and he 12 makes reference to transcript discussions. What 13 transcript are we discussing here? 14 A. A portion of Art Danger's deposition. 15 Q. Do you know -- was Dr. Art Langer's 16 entire deposition sent to Dr. Addison or were some 17 portions sent to Dr. Addison? 18 A. A portion. 19 Q. What portion was sent to - 20 A. It could be the first line at the 21 top -- I believe -- "In a given amount of amosite 22 would you expect to find more or less or the same 23 number of fibers as an equivalent weight of 24 Calidria." 25 Q. All right. So what you sent to Dr. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009223 1 Ilgren '4 0i 2 Addison was the portion of the transcript where 3 that question was asked? 4 A. Yes. It was more than this. I think 5 a whole page. But I thought I had put it in. But 6 maybe I didn't put it in. 7 Q. What you sent to Dr. Addison was a 8 page from the transcript that contained one 9 question and an answer or were there other 10 questions and answers? ' 11 A. I think there were three or four ' 12 questions and answers. 13 Q. And were all of those questions and 14 answers on this topic of comparing Calidria to 15 amosite in terms of mass or number of fibers? 16 A. Yes. 17 Q. . And whose idea was that to send that 18 to Dr. Addison for his comments? 19 A. Mine. 20 Q. And why was it that youwanted Dr. 21 Addison's comments on those questions and answers? 22 A. I didn't understand what Art was 23 talking about. 24 Q. And Dr. Addison'sletter says, there 25 is not much to say about the transcript DOYLE REPORTING, INC. - 212-867-8220 UCARE F00009224 1 ` Ilgren' 402 2 discussions except that they seem to be fairly 3 uninformed about the nature of asbestos. Is he 4 referring there to the question or the answer? 5 A. Both. 6 Q. Then hesays, "I have put a few ideas 7 down on paper for you." And what I'm wondering is 8 where do his ideas start here? Is that on the 9 third page of this exhibit? 10 A. In fact, I believe the entire 11 thing -- the entire document, these three pages 12 are written by Addison. The Q and A page that I 13 sent to him is not here. 1 14 Q. So what we got in this Exhibit 14 is 15 we got the first page is a cover letter from Dr. 16 Addison. Then there are three pages of Dr. 17 Addison's commentary. 18 A. Right. 19 Q. And Dr.Addison'scommentary is on - 20 is with respect to Dr. Langer's description of 21 this comparison between amosite and Calidria 22 fibers, is that fair to say? 23 A. Right. 24 Q. Now toward thebottom of the second 25 page of the exhibit, which is Dr. Addison's DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009225 1 ' Ilgren 403 2 commentary, he states -- I'm reading from down 3 here. He states - 4 A. All right. 5 Q. -- "If something is to be made of the 6 differences in size of the different asbestos 7 varieties, the most important thing to do is to 8 compare fibre populations." Do you see that? 9 A. Yes. 10 Q. He goes on to say, "The best fibre 11 populations to compare are the airborne fibers 12 since they are the one that constitute the hazard 13 and create the risk." 14 A. I see it. 15 Q. Is that a statement you agree with? 16 MR. WILL: Which part of it? 17 MR. BROWNSON: That the best fibre 18 populations to compare are the airborne 19 fibers since they're the ones that 20 constitute the hazard and create the risk. 21 MR. WILL: Are you asking him to 22 agree with the statement that the airborne 23 fibers constitute the hazard and create the 24 risk? Are you asking him to agree to the 25 part of the statement that the best fibre DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009226 1 Il-gren 404 2 populations to compare are the airborne 3 ones or are you asking him to agree with 4 both? S MR. BROWNSON: I'm asking whether he 6 agrees with the statement as written by Dr. 7 Addison, whatever its implications may be. 8 A. Well, I would like to know what the 9 airborne fibers look like. I would like to know 10 if there's any fibre information from what you see 11 in the lung, of course, when you dig it out of the 12 ground. 13 Q. Is Dr. Addison saying here, as you 14 understand it, that in terms of looking at the 15 fibre populations, what is important to him is 16 what's in an aerosol as opposed to what's in the 17 ground or in a pellet or something else? 18 A. I believe so, yes. 19 Q. Do you agree with thegeneral 20 proposition that in a given unit mass of fibre, 21 there are more Calidria and amosite fibers simply 22 because they're smaller? 23 A. Yes. 24 Q. Now, have you received any other - 25 or is there any other communication or DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009227 1 ' ' il-gren 405 2 correspondence or letters or reports or documents 3 from Dr. Addison dealing with this case? 4 A. Not that I recall. 5 Q. So as far as his involvement in this 6 case such as it is,- y,,ou sent him this page of 7 pages of Dr. Langer's deposition that you had 8 questions on and he returned Exhibit 14 as his 9 comments? 10 A. Yes. 11 Q. And other than that, there'snothing 12 in writing from Dr. Addison with respect to this 13 case that you're aware of? 14 A. Aside from comments on Yeager -- 15 Q. Let's go to that next. 16 (Whereupon, Dr. Addison's comments 17 document marked Plaintiff's Exhibit 15 for 18 ` identification, "as of this date.) 19 Q. Exhibit 15 are comments from Dr. 20 Addison dealing with this paper by Yeager and 21 other authors, is that correct? 22 A. . Yes. 23 Q. Is this exhibit something that Dr. 24 Addison typed up and sent to you? 25 A. Yes. DOYLE REPORTING, INC. - 212-867-8220 U CAR E F00009228- I I 1 `' Ilgren ` ` 406 . ' 2 Q. What was the request that you 3 presented to Dr. Addison that resulted in this 4 Exhibit 15? '} 5 Q. What question or request did you pose 6 to Dr. Addison that resulted in this exhibit, what 7 prompted him to write this, what was the question? 8 A. Principally, more information about 9 the fibre types and the populations and 6he 10 lengths and widths because he's used all. these 11 different fibre types. ' 12 Q. Now first of all, you're familiar 13 with this paper that is being critiqued, the 14 Yeager paper. 15 A. I haven't looked at it in a while but 16 I'm familiar with it. ' 17 Q. Are you aware of any study other than 18 the study reported in this paper where human cells 19 of any type, whether macrophages or other types of 20 cells, were dosed with Calidria asbestos to see 21 what the effects were? 22 A. I think it's Russo et al., which I 23 should have put on here. 24 Q. All right. 25 A. 1988. Yes, I put it on here. It's DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009229 1 Ilgren 407 2 on page 7, Russo, et al. 3 Q. So that's page 7 of Exhibit 13, your 4 list of papers? 5 A. Yes. . 6 Q- You list a paper by Russo, et al. 7 Q. And as you understand it, what he did 8 was took some macrophages in vitro and dosed them 9 with asbestos? 10 A. It's an extension of Yeager, et al., 11 1983 . 12 Q. Do you know what types of asbestos 13 were used in that paper? 14 A. I recall it was Coalinga and 15 something' else. 16 Q. By Coalinga, do you know if it was 17 Calidria or not ? 18 A. I don't recall. I think it was 19 RG-144. 20 Q. Did you ask Dr. Addison for any 21 critique of that paper as well or just of the 22 Yeager paper? 23 A. Just Yeager. 24 Q. Other than this paper by Russo 1988, 25 are you aware of any other experiments where human DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009230 1 Ilgren 408 2 cells were dosed with Calidria asbestos to see 3 what the results would be? 4 A. Langer et al. 1988. 5 I'm sorry, 1978. 6 Q. Any others? 7 A;.-- ' T&ld :i's.. in Vitro- * r-.- :.." : : 8 Q`. I'm not talking aboutjust published 9 papers, I'm talking -- the question was 10 experiments. 11 A. Nothing immediatelysprings to mind. 12 Q. Have you suggested to Union Carbide 13 or Union Carbide representatives, there ought to 14 be experiments of this nature to see what the 15 results would be? IS MR. GOLDMAN: Can you just 17 characterize "this nature." 18 Q. Dosing human cells with Calidria 19 asbestos? 20 A. No. 21 Q. Have you suggested any animal 22 experiments to Union Carbide or Union Carbide 23 representatives whether they are inhaling or 24 injecting or whatever with respect -- using 25 Calidria asbestos? . DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009231 1 Ilgren 401 ' 2 Addison was the portion of the transcript where 3 that question was asked? 4 A. Yes. It was more than this. I think 5 a whole page. But I thought I had put it in. But 6 maybe I didn't put it in. 7 Q. What you sent to Dr. Addison was a 8 page from the transcript that contained one 9 question and an answer or were there other 10 questions and answers? ` 11 A. I think there were three or four ' 12 questions and answers. v 13 Q. And were all of those questions and 14 answers on this topic of comparing Calidria to 15 amosite in terms of mass or number of fibers? 16 A. Yes. 17 Q. And whose idea was that to send that 18 to Dr. Addison for his comments? 19 A. Mine. 20 Q. And why was it that youwanted Dr. 21 Addison's comments on those questions and answers? 22 A. I didn't understand what Art was 23 talking about. .2 4 Q. And Dr. Addison'sletter says, there 25 is not much to say about the transcript DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009232 Ilgren ' . 402 discussions except that they seem to be fairly uninformed about the nature of asbestos. Is he referring there to the question or the answer? A. Both. Q. Then he says, "I have put a few ideas down on paper for you." And what I'm wondering is where do his ideas start here? Is that on the third page of this exhibit? A. In fact, I believe the entire thing -- the entire document, these three pages are written by Addison. The Q and A page that I sent to him is not here. Q. So what we got in this Exhibit 14 is we got the first page is a cover letter from Dr. Addison. Then there are three pages of Dr. Addison's commentary. A. Right. Q. And Dr.Addison'scommentary is on - is with respect to Dr. Langer's description of this comparison between amosite and Calidria fibers, is that fair to say? A. Right. Q. Now toward thebottom of the second page of the exhibit, which is Dr. Addison's DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009233 1' Ilgreh 403 2 commentary, he states -- I'm reading from down 3 here. He states - 4 A. All right. 5 Q. -- "If something is to be made of the 6 differences in size of the different asbestos 7 varieties, the most important thing to do is to 8 compare fibre populations." Do you see that? 9 A. Yes. 10 Q. He'goes on to say, "The bestfibre 11 populations to compare are the airborn'e fibers 12 since they are the one that constitute the hazard 13 and create the risk." 14 A. I see it. 15 Q. Is that a statement you agree with? 16 MR. WILL: Which part of it? 17 . MR. BROWNSON: That the best fibre 18 populations to compare are the airborne 19 fibers since they're the ones that 20 constitute the hazard and create the risk. 21 MR. WILL: Are you asking him to 22 agree with the statement that the airborne 23 fibers constitute the hazard and create the 24 risk? Are you asking him to agree to the 25 part of the statement that the best fibre DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009234 I i \ \ J ] 1 ) 1 ii 1J J ^ 1 ^ 3 1 "* J )a 1 ' Ilgren '' 404 2 populations to compare are the airborne 3 ones or are you asking him to agree with 4 both? 5 MR. BROWNSON: I'm asking whether he 6 agrees with the statement as written by Dr. 7 Addison, whatever its implications may be. e A. Well, I would like to know what the 9 airborne fibers look like. I would like to know 10 if there's any fibre information from what you see 11 in the lung, of course, when you dig it out of the 12 ground. 13 Q. Is Dr. Addison saying here, as you understand it, that in terms of looking at the 1"5 fibre populations, what is important to him is 16 what's in an aerosol as opposed to what's in the 17 ground or in a pellet or something else? 18 A. I believe so, yes. 19 Q. Do you agree with the general 2 0 proposition that in a given unit mass of fibre. 21 there are more Calidria and amosite fibers simply 22 because they're smaller? . A. Yes. " 2 4 Q. Now, have you received any other -- 25 or is there any other communication or DOYLE REPORTING, INC. - 212-867-8220 UGAREF00009235 1 '- Ilgren '' 405 2 correspondence or letters or reports or documents 3 from Dr. Addison dealing with this case? 4 A. Not that I recall. 5 Q. So as far as his involvement in this 6 case such as it is,- you sent him this page of 7 pages of Dr. Langer's deposition that you had 8 questions on and he returned Exhibit 14 as his 9 comments ? ] 10 A. Yes. 11 Q. And other than that, there's nothing 1 12 in writing from Dr. Addison with respect to this 13 case that you're aware of? 14 A. Aside from comments on Yeager -- 15 Q. Let's go to that next. J 16 (Whereupon, Dr. Addison's comments 17 document marked Plaintiff's Exhibit 15 for J 18 * identification, "asof this date.) I 19 Q. Exhibit 15 are comments from Dr. 20 Addison dealing with this paper by Yeager and J 21 other authors, is that correct? 3 22 A. ,Yes . 23 Q. Is thisexhibit something that Dr. 3 24 Addison typed up and sent to you? 25 A. Yes. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009236 1 Ilgren 406 2 Q. What was the request that you - 3 presented to Dr. Addison that resulted in this 4 Exhibit 15? 5 Q. What question or request did you pose 6 to Dr. Addison that resulted in this exhibit, what 7 prompted him to write this, what was :the question? 8 A. Principally, more information about 9 the fibre types and the populations and the 10 lengths and widths because he's used all these 11 different fibre types. ' 12 Q. Now first of all, you're familiar 13 with this paper that is being critiqued, the 14 Yeager paper. IS A. I haven't looked at it in a while but 16 I'm familiar with it. ' 17 Q. Are you aware of any study other than 18 the study reported in this paper where human cells 19 of any type, whether macrophages or other types of 20 cells, were dosed with Calidria asbestos to see 21 what the effects were? 22 A. I think it's Russo et al., which I 23 should have put on here. 24 Q. All right. 25 A. 1988. Yes, I. put it on here. It's DOYLE REPORTING, INC. - 212-867-8220 ............... .......-- 0CARE F00009237 1 ' Ilgren ` . .407 . 2 on page 7 , Russo, et al. 3 Q. So that's page 7 of Exhibit 13, your 4 list of papers? ] 5 A. Yes. 6 Q. You list a paper by Russo, et al. 7 Q- And as you understand it, what he did 8 was took some macrophages in vitro and dosed them ) 9 with asbestos? ) 10 A. It's an extension of Yeager, et al. , 11 1983 . 12 Q. Do you know what types of asbestos 13 were used in that paper? 14 A. I recall it was Coalinga and IS something ' else. 16 Q. By Coalinga, do you know if it was 17 Calidria or not? 18 A. I don't recall. I think it was 19 RG-144. 20 Q. Did you ask Dr. Addison for any 21 critique of that paper as well or just of the 22 Yeager paper? 23 A. Just Yeager. 24 Q. Other than this paper by Russo 1988, 25 are you aware of any other experiments where human .DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009238 1 Ilgren 408 2 cells were dosed with Calidria asbestos to see 3 what the results would be? - 4 A. Langer et al. 1988. 5 I'm sorry, 1978. 6 Q. Any others? 7 A. This is in vitro - - 8 Q. I'm not talking about just published 9 papers, I'm talking -- the question was 10 experiments. 11 A. Nothing immediately springs to mind. 12 Q. Have you suggested to Union Carbide 13 or Union Carbide representatives, there ought to 14 be experiments of this nature to see what the 15 results would be? 16 MR. GOLDMAN: Can you just 17 characterize "this nature." 18 Q. Dosing human cells with Calidria 19 asbestos? 20 A. No. 21 Q. Have you suggested any animal 22 experiments to Union Carbide or Union Carbide 23 representatives whether they are inhaling or 24 injecting or whatever with respect -- using 25 Calidria asbestos? DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009239 1 Ilgren 409 2 A. As mentioned in my first deposition, 3 only the recharacterization of Muhle dusting 4 cloud, I haven't actually said we should dust 5 animals. - 6 Q. Do you know when it was that you 7 requested of Dr. Addison that he review the Yeager 8 paper? 9 A. The date? 10 Q. Well, not the exact date, when was it 11 that you made that request? 12 A. I don't recall. 13 Q. Do you know -- was it in connection 14 with the deposition that Dr. Langer gave in this 15 case or was it independent of that? 16 A. I don't recall. 17 Q. Is there anything in the comments of 18 Dr. Addison in Exhibit 15 that you specifically 19 disagree with or -- let's cover that question - 20 MR. BROWNSON: Let's break now. I 21 have a series of questions. Maybe it will 22 help to move it along if you look it over 23 at lunch. 24 (Lunch recess: 12:30 p.m.) 25 DOYLE REPORTING, INC. - 212-867-8220 UGAREF00009240 1 `410. 2 Afternoon Session - 3 1:30 p.m. 4 EDWARD B. I L G R E N, previously 5 sworn , resumed: 6 (Record- read) 7 MR. BR0WNS0N: I'll poae the 8 question again. 9 MR. WILL: I object to the form. 10 The document is four or five pages long and 11 it's hopelessly vague and multiple 12 questions. 13 Anyway go ahead. 14 A. Anything specific? IS Q. Right. 16 A. You would like to point to -- point 17 to a sentence? 18 ' Q- I'm going to go through it. But 19 before X did that, I want to ask the general 20 . question, is there anything you wanted to point 21 out to that you can disagree with? 22 A. General answer, I disagree with list 23 conclusions. 24 Q. Let me point you to the last sentence 25 of the text, which reads - - should we see - - do DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009241 1' Ilgren 411 2 you have a copy of that? Specifically I'm : 3 pointing to the last sentence of text that reads 4 as follows: "The fact that large numbers (5 times 5 10 to the ninth) of fine Calidria chrysotile 6 fibers were cytotoxic to human macrophages is 7 scarcely surprising and the fact then that even 8 larger numbers (1.15 times 10 to the eleventh) 9 were more toxic in even less surprising." 10 Q. Do you agree with that statement? 11 A. Yes. 12 Q. Now, why was it that you asked Dr. 13 Addison to comment on the Yeager, et al. paper? 14 A. I had questions about the validity of 15 comparing certain Calidria fibers about UICC 16 fibers. 17 Q. What I'm wondering, why did you go to 18 Dr. Addison as opposed to someone else for answers 19 to those questions? 20 A. Such as who? 21 Q. Why was it that you chose Dr. Addison 22 to ask the questions to as opposed to someone 23 else? 24 A. He's a great world authority. 25 Q. What is the area in which Dr. Addison DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009242 1 2 3 4 S 6 7 8 9 10 11 '12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ilgren 412 is a world authority? A. The quantitative assessment and. qualitative assessment of mineral fibers. Q. And do you know if Dr. Addison has done any of his own characterization of Calidria asbestos fibre? A. I believe he has. . Q. And do you know if that work has been published anywhere? A. I believe it hasn't. Q. But despite the fact that Dr. Addison has not published his work, you still rely upon him as a leading authority in the end, in the area of characterization of Calidria asbestos fibre? MR. GOLDMAN: Object to form. I believe the response is -- as to what was unpublished was only one particular piece of work, not his work in general. MR. BROWNSON: I understand that. A. Yes. ` ` Q. The answer is yes? A. Yes. Q. Now in addition to the comments by Dr. Addison which are contained in thisExhibit DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009243 1. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ' Ilgren ' 413 15, did Dr. Addison provide you with any other written material or comments on the Yeager paper? A. No. Q. Now the copy I have of Exhibit 15 doesn't have table 1, it just tables 2 and 3. Do you know where table 1 is? A. I can't find it. Mr. Will made me aware that table 1 wasn't there'and there were two copies of tables 2 and 3. I need to find that. I searched for it and if I don't find it'. I'll call Dr. Addison. Q. There's a table 1? A. As far as I recall. I'm not sure. He obviously mentions table 1 in the text. Q. Can you get a copy of that and provide it to us? A. Yes. MR. GOLDMAN: He can try. Q. Now did you have to pay Dr. Addison to do this review and write this report? A. Yes. Q. And how much did he charge for that work? A. Three hours at $300 an hour. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009244 1 Ilgren 414 ' 2 Q. And is that something you paid 3 personally or did you pass that bill on to Union 4 Carbide? 5 A. Initially paid it myself andthen 6 passed it on. ' 7 Q. So Union Carbide reimbursed you for 8 that? 9 A. Yes . 10 Q. That charge by Dr. Addison? 11 A. Yes. 12 Q- In addition to the charge for Dr. 13 Addison, have you incurred other outside charges, 14 by that I mean charges from other people in 15 connection with your work with Union Carbide in 16 this case, something other than charges for your 17 own time? 18 A. Yes. ` 19 Q. Can you tell us what those are? 20 A. I think in acquiring the 21 IITRI documents, I paid Jean Graf for the time and 22 expenses incurred in getting those materials. 23 Q. And again that charge was something 24 that came in an invoice from her and was 25 ultimately paid by Union Carbide? DOYLE REPORTING, INC. - 212-867-8220 UGAREF00009245 '1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ' Ilgren . ' ' 415 A. I believe so. Q. Now can you give us anexact figure if you can, an estimate of how much you have charged Union Carbide all together for your work on this case? ' A. An exact figure? Q. If you have an exact figure. If you don't, can you give us a ballpark? MR. WILL: I object. Go ahead and answer, on relevance. Q. All right. A. Let's say I've put over 1,000 hours. Q. And what is your charge that you charge for your work in this case? A. $200 an hour. Q. And of the $1,000 plus hours put into this case, how much of that has been in the last year, if you can give me an estimate? A. I don't know. It's mainly over the last two years. Q. The last two years? A. Yes. Q. Over that period of time, let's take the last two years, what portion of your time, to DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009246 1' 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ilgren ' . . 416. use a lawyer's term, billable time, have you spent working on this case? A. And Coalinga-related matters? Q. Let me ask you if you break it down just for this case. A. I can't. Q. Well, then, let me ask some more general question of Coalinga-related matters, which I understand would include this case? A. All right.. Q. What's the question? A. The question, Q. The question is what's the percentage of your billable time or billings for the last two-year period that have been devoted to these Coalinga-related matters that include this case? MR. GOLDMAN: Let me object to form. Bob, this is a good time to clarify this point. The only asbestos fibre sold by Union Carbide is what Union Carbide mined in King City. You know from our interrogatory responses and Dr. Ilgren has been retained by us as a scientific medical expert on matters pertaining to what Union DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009247 I ./ 1 ' ` Ilgren- ' ' ` 41? ' ' ` 2 Carbide mined, that same source. If. you're 3 going to use as general terms as pertaining 4 or relating to, I mean it was clear as 5 we've said in our interrogatory responses, 6 all of Dr. Ilgren's consulting for Union 7 Carbide pertains to Calidria and 8 Calidria -- all of Calidria comes from 9 Coalinga and so there are -- all of his 10 time in some way would have to be related 11 to that. 12 MR. BROWNSON: Maybe my question 13 wasn't clear. I wasn't implying otherwise. 14 I understood that. 15 Q. I'm not asking at this point other IS work you might have done for Union Carbide, for 17 radiation or something. I'm just asking for work 18 you've done for Union Carbide with respect to 19 Calidria or Coalinga asbestos. 20 A. And the question is? 21 Q. My question is, what percentage of . 22 your billable time has that constituted during 23 this past two years since you've been doing this? 24 MR. GOLDMAN: All the billable time 25 for all matters -- DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009248 1 ' \ > *' 1 t 1 i f * 1 | ( V l 1 V [ F f 1 '. ' Ilgren ' 4i9 ' 2 practice or has your time been spent on these 3 different projects? 4 A. Different projects. 5 Q. I wanted to ask you when we were 6 talking about the charge from John Addison -7 A. Yes. 8 Q. - - I forgot to ask you earlier with 9 respect to Exhibit 14. io A. Yes. ii Q. Which was his comments on the Langer 12 deposition. 13 A. Yes. 14 Q. Was that included in that $900 or was 15 that charged separately? 16 A. I don't recall. I think it was 17 included, but I don't recall. 18 (Whereupon, letter dated January 5, 19 1994 marked Plaintiff's Exhibit 16 for 20 identification, as of this date.) 21 Q. We're now looking at Exhibit 16, 22 which is one of the documents you produced since 23 the time of your last deposition. This appears to 24 be a letter from you to Dr. Charles Lorberau of January 5, 1994. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009249 Ilgren 423` A. No. Q. Was there anyone who told you that they were using the samples to - - for any animal experiments or had used them for any animal experiments? - A. No. Q. Was there anyone on the list who told you that they were using the samples in connection with any lawsuits arising out of exposure to Calidria asbestos? . A. No. Q. As best you can recall, what were the purposes that were given to you by these people for wanting these Calidria samples? A. Analytical. Q. And why was it as related to yoii that these people wanted to analyze these samples? A. I don't understand what yourquestion is. Q. I assume -- did any of these people tell you why they wanted to analyze these samples? A. I mean, as I recall, one, Brian Davis was interested in the x-ray spectra. Q. Any other -- DOYLE REPORTING, INC. - 212-867-8220 UGAREF00009250 1 Ilgiren '42 4- 2 A. Another, Verma -- Davis's paper is on 3 page 5 of the Exhibit 13. 4 The Ontario group on page 2, Nancy 5 Clark of the Health Sciences Center at McMaster 6 had been doing some infrared-type of analyses. 7 That work is mentioned on Exhibit 13, page 4, 8 under Verma, D. She's the head of that 9 department. Verma is the head of that department 10 Q. 11 curves. Reference in page 4, it says IR 12 A. Infrared. 13 Q. Does that complete your answer then? 14 A. Infrared? 15 Q. Do you know what, the reason was that 16 anyone other people on this list obtained these 17 Calidria samples? 18 A. No. . 19 Q. Have you found out or been told what 20 any of these other people were doing with the 21 Calidria samples? 22 A. No. 23 Q. Did you receive a response from 24 Sergeant Mike Wantland, Occupation and Analytical 25 Department at Brooks Air Force Base in Texas. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009251 1 Ilgren 425 ' 2 What was he doing? 3 A. Nothing. 4 Q. 5 samples? Do you know why he requested these ' 6 A. It was. just a standard that they 7 wanted to have as a. reference standard. When I 8 spoke to him, as I recall, he wasn't doing 9 anything with it. ' 10 Q. Do you know if his work at Brooks Air 11 Porce Base had anything to do with asbestos 12 sampling or analysis in terms of 13 asbestos - contained materials in the buildings at 14 the air force base? 15 A. It might have, I'm not sure. 16 Q. How about C.J. Martin at Oxford 17 University, did you talk to that person? 18 A. Yes. 19 Q. And is this someone you knew from 20 Oxford or is this a new name to you? 21 A. It was a new name. He's not at the 22 university. He's at what they call at the open 23 university, which is a different outfit up on the 24 hill. 25 Q. And what did you learn from him when DOYLE REPORTING, INC. - 212-867-8220 ... UCAREF00009252 1 Ilgren 427 2 Q. Have you ever done any work with 3 Richard Wilson? 4 A. No. 5 Q. Do you know him at all? 6 A. I know of him. I've seen him. I've 7 heard him speak. 8 (Whereupon, document headed "fibre 9 Size Determination and Distribution of 10 Calidria Chrysotile Asbestos by 11 Transmission Electron Microscopy" marked 12 Plaintiff's Exhibit 18 for identification. 13 as of this date.} 14 Q. Now we're looking at Exhibit 18, 15 which is another document that you produced to us 16 following the last deposition, and it's entitled 17 fibre Size Determination and Distribution of 18 Calidria Chrysotile Asbestos by Transmission 19 Electron Microscope." 20 21 paper? Have you had a chance to read this * 22 A. Very quickly. 23 Q. When did you receive this? 24 A. I don't recall. 25 Q. All right. DOYLE REPORTING, INC! - 212-867-8220 UCAREF00009253 '1'' ' ' Ilgre'n ' ' 429 * ' 2 A. No. . 3 MR. BROWNSON: Then Trevor Will has } 4 something on you there, because he has. 5 Q. But in any event, you've had. 1 6 telephone discussions with Mr. Meyer's? :] 7 A. Yes. ') 8 Q. Have you had any telephone 9 discussions with anyone else from KCAC? 10 A. No. 11 Q. Have you had any correspondence with 12 Mr. Meyers? 13 A. Yes. 14 Q. is that substantive correspondence or 15 enclosed as a paper or send me a paper sort of 16 thing? 17 A. I don't recall? I think it's more 18 substantive . 19 MR. GOLDMAN: John Meyers is retired 20 from KCAC Inc. 21 Q. Let me ask you this. I thought I 22 asked you this. Have you had conversations with 23 anyone from KCAC other than John Meyers? 24 A. Not that I recall. 25 Q. This particular document, Exhibit 18, DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009254 ' 1' ' Ilgren ` 43 0 I 1 2 came from Mr. Meyers? * 3 A. I believe so. I don't recall. 1 4 Q. What was the request that you made that resulted in this document? In other words, J6 did you say, give m.e any documents you have, size '} 7 distribution, or was it a more general question? . 8 A. I believe it was size distribution. 'I ' 9 Q. Why were you interested in seeing 1 10 what he had on that issue? 11 A. I'm interested in any data pertaining '| 12 to Calidria. j 13 Q. Have you received any data from KCAC 14 other than this Exhibit 18 and then the other one, 1 > 15 actually there's a second one which we'll get to ] 16 in a minute which is a similar paper with a 17 different date. You said you received those two ') 18 things from him. Did you receive anything else? 1 19 A. I said I wasn't sure whether I rJ 20 received these. I may have received them. I 2 X don't believe I received anything else from KCAC. 3 22 MR. BROWNSON: Let's mark this other 23 one. j 24 (Whereupon, document headed "fibre J 25 Size Determination and Distribution of '[ft DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009255 '1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ilgren ' ' ' ' ' 431 ' RG-244 Calidria Chrysotile Asbetos by Transmission Electron Microscopy" marked Plaintiff's Exhibit 19 for identification, as of this date.) . Q. Exhibit 19 is a second fibre size distribution paper done for KCAC Inc. Except this one is dated February 3, 1993, and Exhibit 18 was dated March 30, 1991. A. Yes. . Q. And as a general matter, it looks to me what Exhibit 18 is is a TEM size distribution analysis of four different sample types of Calidria asbestos, wherein 19 they just did RG-244? A. I believe so. Q. Has Mr. Meyers or anyone else communicated to you why they -- this follow-up TEM size distribution analysis was done on the RG-244? A. No. Q. Can you tell from yourreview of the papers why the follow-up was done on the 244? A. I haven't read this in a while so I couldn't say at this time. MR. WILL: I believe you misspoke. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009256 1 Ilgren 43.5 2 analyses with TEM. 3 Q. All right. 4 A. I think that's it. 5 Q. You're looking at Exhibit 13, which 6 is your list here. With respect to this analysis 7 by Naumann, there are four entries by Naumann on 8 your paper. Is it one of these that you think is 9 this TEM analysis? 10 . A. Yes. I don't thinkit was solely a 11 TEM analysis. I'd have to go back and check. I 12 think it contains some TEM data. 13 Q. Do you know if it contains any size 14 distribution data? 15 A. I believe it contains internal and 16 external diameter, fibril diameter data. I think 17 Naumann and Dresher, 1966. 18 Q. How about fibre and language, is that 19 data contained in there? 20 A. I think it's just diameter. 21 ' Q. How about the series of articles on 22 Exhibit 13, how about the series of Yada, you 23 mentioned some of that may be TEM size 24 distribution? 25 A. Yes. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009257 1 ' ` ' Ilgren' . 436 ' ' 2 Q. Can you refer me to one or more of 3 those that might contain that information? 4 A. I think it's Yada 1979. Not 100 5 percent positive, but X think it's the 1979 paper. 6 Q. Have you - - 7 A. There was also -- I believe some EM 8 data -- I don't quite recall, he had duplicated 9 Naumann. I seem to recall EM data and X seem to 10 recall Chwastiak. . 11 Q. On this Chwastiak reference on page 12 two. Exhibit 13, it doesn't indicate a source. 13 A. I'm sorry, tha't's a UCC document. 14 Q. That's one of the things you produced 15 in the documents? 16 A. - ' Yes. 17 A. It's one of the documents X assume 18 you would get from Kelley Drye. 19 Q. It's not one you got from your box? 20 MR. WILL: It was in there. 21 THE WITNESS: I don't think so. I 22 don't know. 23 MR. WILL: I think it was in there. 24 Q. In any event, you got it from Union 25 Carbide or their lawyers, Kelley Drye & warren? DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009258  1. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ' ` Ilgren - . ' 43 7 ` . A. Yes. , MR. WILL: Off the record. (Discussion off the record) MR. BROWNSON: On the record. Q. On Exhibit 18, I would like to refer you to page number TEM-3, in paragraph number 4 at the bottom of that page reads, "The breathing of asbestos dust may cause serious bodily harm and we can make no warranty or guarantee that the results contained herein indicate that safe levels of exposure exist." Do you see that? A. Yes. Q. I take it that with respect to the Calidria asbestos that they're analyzing in this Exhibit 18, you disagree with that statement? A. It's dust. People do take precautions for high levels of dust, such as nuisance dust. Q. Let me ask you this. It's your opinion, I understand, that Calidria asbestos dust in any concentration cannot cause mesothelioma? A. That's correct. ' Q. Is it alsoyour contention that Calidria asbestos dust in any concentration cannot DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009259 1 Ilgren 439 2 find was 1.03 FML. My understanding, for example, 3 the types of activities at the Conwed plant that 4 would have produced high levels, or the highest 5 levels would be, say, blow-downs as opposed to 6 finish or sanding. - 7 I attempted to, say, reconstruct the 8 type of cumulative fibre-year dose a Conwed 9 workman would have incurred in a more or less 10 worst case scenario, and in that context I would 11 have estimated that a man in the plant in a 12 so-called blow-down setting would not have worked 13 there in that kind of situation for more than six 14 hours a week. And that would have gone on for 50 15 weeks a year, which would have been 300 hours a 16 year. If one takes 2,000 hours as the standard 17 work year and divides 300 by 2,000, one ends up 18 with 0.15 years. 19 If one then takes as the reasonable 20 estimate of the kind of upper working limit, 21 maximum working limit that one might find in a 22 ceiling tile plant for Calidria as one being the 23 highest level that they found, the most one could 24 incur in terms of a fibre year dose in a year 25 would be 0.15 years. The generally recognized DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009260 1 Ilgren ' 440 2 threshold figure for clinically manifested is 50 3 fibre years which is generally placed on the 4 Rochedale Textile Work as cited by Doll & Peto 5 into their 1985 asbestos document. 6 Q. All right. 7 A. If one then asks the question how 8 many years that Conwed workman would have to work 9 in order to achieve a 50-fibre year cumulative 10 so-called threshold dose, one would then I believe 11 need to divide 50 by 0.15. But the threshold dose 12 of 50 fibre years is truly predicated on'a textile 13 milling situation in which there is not, say, 4 14 percent or 8 percent -- where 5 micro fibers, but 15 there would be 30 or 40 or 50 percent long fibers. 16 So what I would do is I would take the so-called 17 300 years and multiply it by at least two. 18 ` Q. Where do you get 300 years? 19 A. That's 50 fibre years divided by 0.15 20 years. 21 Q. All right. 22 A. That's 333, I think, something like 23 that. 24 Q. So your bottom line is that a worker 25 in the Conwed plant would need 666 fibre years? DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009261 1 Ilgren 441' 2 A. My bottom line is that an individual 3 would need to work for 666 continuous years in 4 order to achieve sufficient exposure, in theory to 5 get Calidria-related asbestosis. 6 Q. How do you define clinical asbestosis 7 -- 8 A. A S T. 9 Q. That is 1/1 - 10 A. Whatever -- you know the standard 11 reference. The 1986 document in the American 12 Review of Respiratory Disease. 13 Q. As a result Of these calculations you 14 made, you believe a worker would have to work 666 15 years in the Conwed plant to get clinical 16 asbestosis? 17 A. Prom Calidria chrysotile exposure. 18 Q. How do you explain the fact that many 19 workers do have clinical asbestosis after working 20 in that plant? ,, 21 MR. WILL: I object to the question. 22 It assumes a fact that is not in evidence. 23 Do you want him to assume for the sake - 24 MR. BROWNSON: I want him to answer 25 the question if he can. DOYLE REPORTING, INC. 212-867-8220 UCAREF00009262 I I. ] a a i j j j 1 Ilgren 442 2 A. I want you to ask the question' again. 3 Q. I'll ask this, are you saying there's 4 no worker in that plant that has clinical 5 asbestosis, no worker has come out of that plant 6 with clinical asbestosis? 7 A. I don't know what the MDA documents 8 documents say with precise instance, of disease. 9 Q, Are you saying there is no worker who 10 has come out of that plant with clinical 11 asbestosis? 12 A. I don't know. 13 Q. Have you reviewed the case of Mr. 14 Eugene Smith? 15 A. No. 16 Q. Have you-ever reviewed. any of the 17 asbestosis cases? 18 A. No. 19 Q. We spoke earlier when we started this 20 answer, your opinion on asbestosis from a Calidria 21 asbestos basis based upon a 79 HSE document. And 22 I assume that HSE is Health Safety Executive? 23 A. Yes. 24 Q. Which is a British government group? 25 A. Yes . DOYLE REPORTING, INC. 212-867-8220 UCAREF00009263 1 Ilgreri ' 443 2 Q. As I understand it, the HSE published 3 a document dealing with a tile plant in Oxbridge. 4 A. Yes . 5 Q. Do you know where that was published? 6 A. What was published? 7 Q. That document. .: 8 A. It comes out of HMSO, Her Majesty's 9 stationer's office in London. 10 Q. Do'you have a copy of that? 11 A. Yes. ' 12 Q. What do you know about the tile plant 13 in Uxbridge? Was that a plant where ceiling tile 14 was manufactured? 15 A. I believe so. 16 Q. And do you know when the ceiling tile 17 was manufactured in that plant? 18 A. I believe from 1947 to 1981. 19 Q. And is it your understanding that 20 amosite asbestos was a component in that ceiling 21 tile? 22 A. 23 Q. 24 amosite? It is almost pure amosite. The tile was made of almost pure 25 A. I believe so. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009264 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ilgren 4 44 Q. And does that document contain- asbestos air level measurements in the plant during production of that tile? A. I believe so, yes. Q. Do you know what those are? A. What -- Q. The air level measurements of asbestos during production of tile in that plant? A. Yes. Q. What are they? A. They're categorized I think by sanding, sawing, finishing, measurements in the office, measurements in the plant floor. I can't recall exactly every specific data set, but the high readings, as I recall, were from 6 to 10. Q. Fibers per cc? A. Yes. ` Q. All right. A. There was some activity that said it was greater than 20, but the highest reading that was categorize, as far as I can recall, was 6 to 10 . Q. All right. And in taking that data and trying to translate it to the environment DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009265 1 Ilgren 445 2 within the Conwed plant when Conwed was producing 3 tile, was using Calidria asbestos, what you've 4 done is used the data from the 1972 Union Carbide 5 air monitoring survey to get your vessels in the 6 Conwed plant? . 7. A. Yes, in conjunction with these other 8 data. . 9 Q. And of course if a particular worker 10 had an exposure greater than 1.03 fibers per cc, 11 he would need less than 666 years of work in the 12 plant to develop clinical asbestosis? 13 A. Yes. 14 Q. So are yousaying a person couldn't 15 get asbestosis from exposure to Calidria asbestos 16 because it's dose-dependent, and in your view a 17 very large dose would be needed? 18 A. Yes. 19 Q. You have attempted to calculate that 20 dose by -- based upon the data from the Oxbridge 21 plant as reported in the HSE 1979 report? 22 A. And the Conwed plant. 23 Q. Well, maybe we're arguingabout 24 semantics. I understand you're attempting to 25 translate the English data or superimpose it to DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009266 1 Ilgren 446 2 the Conwed plant experience? _. 3 A. To some extent, yes. 4 Q. As I understand youropinion, you're 5 predicating your opinion upon the fact that you 6 believe none of the workers in the Conwed plant 7 have clinical asbestos, is that right? 8 A. No. 9 Q. So there may or may not be some 10 clinical asbestos, you just don't know? 11 A. There may be, there may not be, X 12 don't know. 13 Q. What this opinion was that you just 14 gave us is an opinion which is a calculation based 15 upon data from the Oxbridge ceiling tile plant in IS England, transferred over to what you understand 17 about the exposure levels in the Conwed plant, 18 would that be fair to say? 19 A. To some extent. 20 Q. And with respect todata concerning 21 exposure levels in the Conwed plant, one piece of 22 data you have is the 1972 Union Carbide air level 23 survey, correct? 24 A. Yes. 25 Q. And what other pieces of data do you DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009267 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ilgren ' '447 have concerning exposures in the Conwed plant? A. As I recall, there are only three. The UCC 1972 document, the in-test document, and one other which I can't remember. Q. All right. MR. WILL: The Gaffney. A. The Gaffney report. Q* The in-test document, you understand that to be a test done in connection with some work on pipe covering in the boiler room of the plant, or the steam plant? A. I believe so. Q. With respect to trying to calculate the exposure levels of what you call a worst case scenario. did Conwed have a plan in doing blow-downs; with the air hose? A. Yes . Q. Did you calculate or assume some value for those exposure levels? A. Yes. ' ' Q. What was that? A. One. Q. One fibre per cc? A. Yes. DOYLE REPORTING, INC. - 212-867-8220 U CARE F00009268 1' ` Ilgren 448 2 Q. So what you were doing when you-made 3 this calculation was you were assuming that a man 4 doing blow-downs would be exposed to one fibre per 5 cc during his blow-down work? 6 A. Yes. 7 Q. Going back to Exhibit 18> which is 8 the lecture on microscopy data done in KCAC 9 November 30, 1991, look at page TEM-4, which is 10 under the heading of "Discussion," towards the 11 bottom of the: page, the second to the'last 12 paragraph 13 A. Yes . 14 Q. All right. 15 Q. There they're talking about fibre 16 width. 17 A.. Yes. 18 Q. With respect to what they term fibre 19 width, is that fibre diameter they're talking 20 about there? 21 A. I believe so. 22 Q. And they talk about what the means 23 and what the medians are? 24 A. Yes. 25 Q. And then they say, I'm reading at the DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009269 1 Ilgren' 449 2 end, the last line, "all samples had their largest 3 component in the range from 0.03 to 0.05 microns," 4 as reported in table 4. Do you see that? 5 A. Yes. 6 Q. I guess that means just what it says, 7 they - - 8 Q. Most of the fibre diameters - - if I 9 can summarize, most of the fibre diameters they 10 found of the Calidria asbestos with the TEM 11 analysis was in the .03 to .05 microns? 12 A. Yes. 13 Q. The reason I was asking that, when I 14 was looking back at Dr. Addison's criticism of the 15 Yeager paper, which is Exhibit 15, on page 2, one 16 of the things he criticizes is the fact that 17 Yeager makes his calculation assuming an average 18 fibril diameter of 0.0333 microns, do you see 19 that? 20 A. Yes. 21 Q. I understand that to meanthat Dr. 22 Addison thought that was not a proper calculation 23 to use, is that what he appears to be saying? 24 A. I don't think so. 25 Q. Would you agree with me in the Yeager DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009270 .1 Ilgren. '45 0 2 paper the average fibril diameter was reported or 3 was -- or assumed to be .0333 microns? 4 A. I don't have the paper in front of 5 my. According to what Dr. Addison said, yes, 6 that's the case. . 7 Q. If you read further in that paper, 8 Dr. Addison appears to be critical of the 9 assumption that the average fibre diameter is 10 .0333 microns, he says because the assumption 11 made - 12 A. Where are you reading did. 13 Q. The last line, "would have an 14 influence on the calculated fibre numbers per 15 milligram." ' 16 A. That's what he says. 17 Q. Now, let me refer you to Exhibit 18 18 on table 2, which is at page TEM-7. And there - 19 they give a mean and a median for these Calidria 20 asbestos fibers, all right, for these samples. 21 A. Yes. 22 Q. With respect to the median length, 23 are those values generally consistent with other 24 published size distribution data that you have 25 seen? . DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009271 1 Ilgren 451 2 A. X have to check again. 3 Q. I want to ask the same question with 4 respect to table 3 at page TEM-8, which is fibre 5 length breakdown or distribution. Are those 6 generally consistent with other published data 7 you've seen? 8 A. I've only seen RG-144. It's 9 basically consistent. 10 Q. Are you generally familiar with the 11 different grades of the Calidria asbestos and how 12 they're processed? 13 A. To some extent, yes. 14 Q. Does this table, table 3, generally 15 seem to indicate that the more the Calidria 16 asbestos is processed or the greater processing it 17 undergoes, the greater the number of fibers, 18 number one, and the great number of fibers less 19 than five microns, number two? 20 A. Say that again, the greater the 21 processing, the higher the percentage -- 22 Q. The higher percentage of short 23 fibers? 24 A. It suggests the opposite, doesn't it. 25 Q. Let me ask it this way. Can you draw DOYLE REPORTING, INC. 212-867-8220 UCAREF00009272 1 Ilgren' 452 . 2 any conclusions as to what table 3 suggests in 3 terms of the more milling, what happens? 4 MR. WILL: When you say milling, 5 processed in the mill? 6 MR. BROWNSON: Right. 7 A. I don't recall the precise details as 8 to how one transforms RG-144 to RG-.244, but I 9 think there's a siliconization there. I don't 10 think it refers to any more milling. 11 Q. Do you hold any opinions as a general 12 matter how milling affects Calidria chrysotile in 13 terms of size distribution? . 14 MR. WILL: Can you be more specific 15 when you mean by milling? As you know, 16 there have been some experiments that 17 involve ball milling, which is what goes on 18 in the mill in King City in terms of 19 processing this ore? 20 MR. BROWNSON: Process milling? 21 MR. WILL: In the plant in King ' 22 City. 23 A. I don't know anything about it. 24 Q. That's all I have on this exhibit. 25 I want you to look next at Exhibit DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009273 1 ' Ilgren 453 2 number 19, which is the second fibre size - 3 determination and distribution paper done for 4 KCAC, this was done in 1993, and it involves 5 testing of RG-244, one of which was treated with 6 silicon and one was untreated. Have you had a 7 chance to review this paper? - 8 A. I've haven't looked at it in great 9 detail. 10 Q. Do' these two papers. Exhibit 18 and 11 19, form a basis of any of your opinions in this 12 case? 13 A. They may. I need to go over them in 14 more detail. 15 Q. But at least at the present time, 16 they do not? 17 A. I don't think I can say anything at 18 the present time. 19 Q. Would it be fair to say if they do 20 form a basis of your opinion, you don't know what 21 22. that is? A. I think --my impression particularly 23 with respect to Exhibit 18 is that the sample that 24 I've become familiar with most, the RG-144, 25 doesn't indeed have a rather small percentage of DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009274 i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ilgren 454 fibers that reflect microns. That seems to-be confirmed by Exhibit 18, and that the widths generally going between 3 and 500 angstroms is not that different from what I envisage as the size range for Coalinga fibre widths. I think I would like to be able to say yes. I would.rely on this to say it's consistent with other data that I have seen. Q. So in terms of these two exhibits, 18 and 19, there's nothing in here that startles or surprises you in terms of their conclusions for these size measurements and size distributions? A. I would have to study it a bit more. There is the RG-244, which is in the table 3, Exhibit 18, it shows 11 to 18 percent fibers * greater than five microns and 57 percent fibers greater than 10 microns. I found that a bit high, but I don't know much about the RG-244. Q. And you say you find that a bit high because it's higher than what you seen in RG-144 samples? A. Yes. Q. Now onExhibit 19 on the front, there's some stuff blacked out there. Is that DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009275 1 ' Ilgren 455 2 something you did or is that the way it came to 3 you? 4 A. That's something -- I had some funny 5 scribbling there. 6 Q. And did. the funny scribbling have 7 anything to do with editorial comments on your 8 part? 9 A. No. It's just some odd marking. 10 Q. All right. 11 A. I remember something. Could I say 12 something with respect to the threshold 13 characterizations I made with regard to Coalinga 14 asbestos? Just to simply indicate that it's not IS only my belief that one would have to work for, IS say, 600-odd years under that situation, it's also 17 my belief that it may in fact be much longer than 18 that because the calculations which I mentioned 19 were based on, say, standard Canadian type of 20 fibers. The Rochedale, I assume that's -- that's 21 either a Canadian or a long South African fibre. 22 I think what's worth commenting upon is that fact 23 this the Calidria fibre or fibril in my opinion is 24 equally different from the Canadian in being much 25 more likely to dissolve, being much more soluble DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009276 1 1 ' Ilgren ' 456 2 than the so-called standard Canadian fibre. 3 Q. Is that a function of its chemistry 4 or its size? 5 A. it could be both. It's certainly in 6 my opinion the function of its size in that the 7 vast majority of Coalinga or Calidria fibers are 8 actually single fibrils. In that sense they're a 9 lot thinner and in theory would be a lot more 10 susceptible in the dissolution in the body fluids. J 11 There may be peculiar chemical differences and 12 physical -- and chemicals are in a sense interlink i 13 features. But there's certainly evidence in data 14 in my opinion to suggest that the Canadian fibers 15 composite of at least six or seven .fibrils :j 16 cemented together with a matrix of unknown 17 character, it's often regarded as a silicate of 18 some sort. But the Calidria so-called fibre for i 19 all purposes is a naked fibril about no amorphous ;,j 20 cementacious material. 21 Q. So if I can summarize what you just 3 22 said, do I understand that you believe that the 23 Calidria asbestos because it's shorter and thinner 24 than UICC standard grade Canadian asbestos, it's 25 less or requires longer to cause asbestosis a DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009277 1 Ilgren' 457 ' 2 because it's more easily dissolved in the body? 3 A. If it were at all, plus these other 4 properties of -- other properties lacking the 5 inner fibril or matrix and other different 6 properties. 7 Q. But one of those properties, as I 8 understand it, is simply its size? . 9 A. Yes. 10 Q. It's shorter and thinner, it's 11 smaller in essence? 12 A. Yes. 13 Q. All right. 14 A. But I'm actually saying given equal 15 lengths, say, of 7 microns in lenght, Coalinga 16 fibre as opposed to a- 7-micron lenght in 17 Coalinga -- Canadian as opposed to Coalinga, it's 18 my firm belief that the Coalinga fibre is much 19 more susceptible to dissolution. 20 Q. If you look at Exhibit 18, let's take 21 RG-144, which you say it is the type of Calidria' 22 you're most familiar with. It's indicated on page 23 7, table two, that the mean length of these fibers 24 is 1.1 micron? 25 A. That's what it says are. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009278 1 Ilgren 458 2 Q. For RG-244 ranges from two 2.45 to 3 3.22 in mean lenght? 4 A. Yes. 5 Q. If I understand what you just told 6 us, that's shorter than standard UACC Canadian 7 chrysotile? - 8 A. I believe so. 9 MR. WILL: If you took a mean -- a 10 mean is just an average? 11 MR. BROWNSON: Right. ' 12 Q. There's a media reported here, but I 13 was talking about the mean which is average. 14 Median means middle and mean means average in 15 layman's terms? 16 A. Yes. 17 Q.. Are you familiar - 18 A. The percentage -- just to clarify, 19 the percentage of fibers in a UICC sample to my 20 recollection, would be on the order of 25 percent 21 and above where the percentage of fibers of 22 fibrils and Coalinga above 5 microns would be in 23 the order of 1 to 4 percent or 1 to 6 percent, 24 according to the literature. 25 Q. ' You're talking about the size DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009279 1 Ilgren 460 2 A. I'm not familiar with -- I don't 3 believe I have read it. Could I see a copy of it? 4 Q. Yes. 5 A. All right. 6 Q. What they're doing,they're 7 discussing Dr. Dement's data from the textile 8 plant in Charleston, South Carolina. 9 The first question I wanted to ask 10 you. I'll wait -- have you ever read their paper 11 before? 12 A. I don't believe so. 13 Q. If you look at the second page, which 14 is - 15 Q. First of all, are you familiar with 16 Rood and Streeter of the Occupational Medicine and 17 Hygiene Laboratories, health and Safety Executive, 18 London, England? 19 A. I've heard of Dr. Rood at the HSE, I 20 don't know them personally. 21 Q. Are these the same Health and Safety 22 Executive that you were talking about with the 23 British amosite ceiling tile factory? 24 A. Yes. 25 Q. If you look at the second page of the DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009280 I 1 Ilgren 461 . 2 paper, which is actually page number 334. 3 A. All right. 4 Q. They say "Dement and Harris 1979 5 report several TEM-derived fibre size 6 distributions for asbestos. 7 A. All right. ) 8 Q. We calculated the following from 9 their data: in the chrysotile-using textile plant. J 10 for the processes of fibre preparation, twisting .] 11 and weaving. the geometric mean lengths were 2.2, 12 1.8 and 2.0 on microns respectively." Do you see ) 13 that? 14 A. Yes. 15 Q. First of all, have you ever seen that 16 data reported before anywhere else? 17 A. I think so, but I don't recall. 18 Q. All right. 19 A. You mean the Charleston data? 20 Q. Right. 21 A. I think so, I think it's in Dement's 22 thesis. 23 Q- If you look at page 336, which is 24 table 1. 25 A. All right. DOYLE REPORTING, -INC. - 212-867-8220 UCAREF00009281 1'' '' . ilgren. ' 462 ' ' 2 Q. It summarizes this data, and they 3 show the mean and medium lengths of the fibers in 4 these different, carding, weaving and spinning. 5 operations. Do you see that? 6 A. Yes. 7 Q. Now first of all, you're familiar 8 with the fact that the asbestos we're talking 9 about is Canadian chrysotile asbestos? J 10 A. Yes . .] 11 Q- And have you ever seen any different 12 size distribution data other than what we're ) 13 looking here on table 1 -- any different size 14 measure data other than what we see in table 1 for 15 the asbestos in the Charleston textile plant? 16 A. I believe so. 17 Q- And where is that data reported? 18 A. I don't recall. j 19 Q. ` All right. :i 20 A. More in in terms of the percentage 21 over 5, 10 and 20 microns. ` 22 Q. Right. 23 (Whereupon, document entitled 24 "Characterization of Three Types of 25 Chrysotile Asbestos after Aerosolization" DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009282 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 2 3' 24 25 Ilgren 463 marked Plaintiff's Exhibit 21 for identification, as of this date.) Q. We're now looking at Exhibit 21, which I think is a paper you're familiar with. A. I'm familiar with it. Q. So just to add some familiar ground. Exhibit 21 is a paper by Pinkerton and other authors characterizing three types of chrysotile asbestos after aerosolization? A. Yes. ' Q. You're familiar with this, of course? A. Yes. Q. One of the three types is what they call Coalinga mine chrysotile, but that's Union Carbide chrysotile? A. I believe so, yes. Q. And in the abstract andlater in the body of the paper, they state, "The characterization of these chrysotile preparations in the aerosolized state, in particular the Coalinga Mine chrysotile, demonstrated different fibre length and fibre width distributions when compared with previous characterizations of samples that had been dispersed in a liquid medium DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009283 I 1 ' '` ilgren ` 464 2 by ultrasonification"? 3 A. Yes. 4 Q. Do you seethat? .) 5 A. Yes. - 6 Q. I'm readinginthe abstract. 7 A. Yes. 8 Q. Then it goes on to say, "These 9 observations emphasize the importance of 10 determining the size distribution of fibers in the 11 aerosolized state for inhalation studies and the 12 size distribution of fibers in a liquid suspension 1 13 for oral ingestion, instillaton, or inj ection J 14 studies." 15 A. Yes. ` J 16 Q. Finally say they, "Because of 3 17 differences in length-width distributions, each of 18 the studied chrysotile preparations would be 3 19 expected to have different patterns of deposition 20 in the alveolar regions of the lung after an 21 inhalation exposure. 22 A. Yes. 23 . Q. I want to ask you some questions 24 about what we just read. 25 A. All right. DOYLE REPORTING, INC. 212-867-8220 UCAREF00009284 1 Ilgren ' 465 2 Q. In all of the fibre size distribution 3 data that you have seen for Calidria asbestos,- 4 have you seen any size distribution data for that 5 asbestos in an aerosol state, dust in the air 6 other than what's reported in this paper? 7 A. I think the only other data set is 8 Muhle, et al., 1987, I think it's Muhle and 9 Pinkerton who have ever done that. . 10 Q. Do you agree with the statement we 11 just read that for purposes of inhalation studies, 12 the size distribution in the aerosolized state is 13 important? 14 A. Yes. 15 Q. And if I can put that in simple 16 layman's terms, is that because inhalation studies 17 of breathing asbestos, and obviously when you 18 breathe something, what's important is what's in 19 the air that you're breathing? 20 A. Yes. 21 Q. Now have you ever seen any animal 22 inhalation data on Calidria asbestos? 23 A. Yes. 24 Q. What is that? 25 A. Pinkerton et al., Muhle, et al. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009285 I 1 . Ilgren ' - ' -466 ' 2 Q. And is that reported in your book? ) 3 A. Muhle, et al. certainly is. 4 Q. All right. 5 A. Pinkerton et al. may not bebecause I 6 got it just a couple of years ago. 7 Q. I got a copy of your book here and 8 I'm trying -- I want to go -- to the inhalation - 9 the compilation -- or the reference to inhalation j 10 data from thei Calidria fibre. I don't know if i 11 we - - if you can find it higher. 12 A. Let me see. 13 A. It's on page 136. 14 Q. Let me put my tab there. 15 A. All right. j 16 Q. And what you pointed out to us is the 3 17 reference to the Muhle, et al. paper of 1987? 18 A. Yes . I 19 Q That's reported in your book as a J 20 chrysotile Calidria inhalation experiment on 21 Wistar rats? 22 A. Yes. 23 Q. Have you read that paper? 24 A. Yes . 25 Q. And does that paper form any basis DOYLE REPORTING, INC. 212-867-8220 UCAREF00009286 1 Ilgren- ' 467 2 for your opinions in this case? 3 A. Yes. 4 Q. An if you can tell us what is the 5 fact or facts which you derive from that paper 6 that form ithe basis for your opinion in this case? 7 A. To me it indicates Calidria 8 chrysotile in high doses cannot induce tumors in 9 rats. 10 Q. Is that because in 50 female rats. 11 there were no mesothelioma tumors reported? 12 A. No tumors. 13 Q. All right. 14 A. No pathological changes at all. 15 Q. Of any sort? . 16 A. Of any sort. 17 Q Now with respect to Pinkerton's paper 18 about inhalation, is that reported in your book? 19 A. No, it hasn't been reported yet. 20 Q. Is that because you're saying it was 21 too recent to go into the book? ` 22 A. Yes. 23 Q. Now you also report at least three 24 animal studies with respect to injection of 25 Calidria asbestos in your book, is that correct? DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009287 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ilgrexi ' 468 ' A. Yes. Q. And we talked about those a little hit last time, but I would like to ask you some questions about those and I'm not sure the best way to do it since I got the book. Maybe we have to look at it together. A. All right. Q. The first reference I see is page X. A. Roman 10. Q. Roman 10, I'm sorry. Table 3. Chrysotile 25 milligram, intraperitoneal injection of rats. A. Yes. Q. You report here Maltoni, et al. 1982. A. Right. Q. And it's listed as Calidria. My question is. is that Calidria? A. I don't know. Q. Have you read those papers? A. Yes. Q. As you sit here today, you don't recall whether it's Calidria or some other -- A. As I believe I said in the first deposition, I wrote to Maltoni and I said is it DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009288 1 Ilgren 469 2 California Calidria or Coalinga and he didn't 3 reply. 4 Q. Is it your best understanding it's 5 one of the Coalingas or it's fibre from the 6 Coalinga deposit? ' 7 A. No, it could be -- there are a lot of 8 different chrysotile deposits around Calidria. 9 Q. Now the other one I wanted to refer 10 you was at page 90, that is the Suzuki paper 1984. 11 That's actually is Calidria, at least as reported 12 by you? 13 A. By Suzuki, it's RG-144 that he got 14 from Art Langer. 15 Q. All right. Then we got at page 94, 16 we got entries for Muhle, et al. which we talked 17 about before, but now we're talking about 18 injection and the inhalation. That is Calidria? 19 A. Right. 20 Q. And then we gotPott, andthis is 21 injection and that's Calidria? 22 A. Yes. 23 Q. And then we got Rittinghausen, et 24 al., 1990? 25 A. All right. This isbasically the DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009289 1 Ilgren 470 2 same lab. 3 Q. And that's Calidria? 4 A. Yes. 5 Q. Then, now on page 101, we got Maltoni 6 again, but it's just, recorded as Calidria 7 chrysotile, we can't be sure what that is? 8 A. Right, that is the samestudy as I 9 did in the beginning. 10 Q. Now I didn't find -- other than those 11 injection studies we looked at and the inhalation 12 study that you pointed to a minute ago, which I've 13 now underlined by Muhle, is there any other animal 14 data reported in your book which either are or 15 could be Calidria asbestos? ' 16 A. There's one I found the other day 17 with Maltoni and Minardi 1988 which I haven't 18 actually seen before. 19 Q. Now that's reported in your index, 20 but I didn't find it in your book here. 21 A. But again is Calidria. I don't -- on 22 page 103. 23 {Discussion off the record) 24 Q. You've now identified on page 103 of 25 your book that Maltoni and Minardi, which is DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009290 1 `` Ilgiren ' '4471 2 listed as Calidria chrysotile 1988 -- . 3 incidentally, it's listed as '89. Do you know if 4 it' s '88 or ' 89? 5 A. I believe it's '89. It came out in 6 the IACC, but the galley I got was '88. You know 7 how it is. 8 Q- Here - 9 Q. I have it here. We'll mark it here. 10 (Whereupon, document entitled 11 "Non-Occupational Exposure to Mineral 12 Fibres " marked Plaintiff's Exhibit 22 for 13 identification, as' of this date.) 14 Q. So now we've got Exhibit 22 and this 15 is a photocopy I made of the 1989 Maltoni, et al. 16 A. Maltoni and Minardi. 17 Q- Yes. Injection. 18 A. Yes. 19 Q. That's reported in your book on page 20 102? 21 A. Right. 22 Q. What number is this? 23 A. 22 . 24 a. Now what I was trying to figure out 25 on this, and first of all, have you read their DOYLE REPORTING, -INC. - 212-867-8220 UCAREF00009291 1 Ilgren 2 3 A. Yes. 4 Q. It doesn't say anywhere in here that 5 this is actually Calidria asbestos. And you had 6 told us earlier that you asked Maltoni whether - 7 what this Calidria was with respect to the 1982. 8 Did you ask the same with respect to this one? 9 A. I can't recall. I just called him in 10 Bologna and his secretary answered and I said, 11 "What's your fax number?" So I faxed him. I 12 don't recall exactly what I put in the fax, 13 whether I just said Maltoni '82 or in your studies 14 using Calidria without actually specifying a 15 paper. 16 Q. So you don't know as you sit here 17 today, you haven't received a definitive answer 18 whether this is Calidria or not? 19 A. No. 20 Q. If you look on page 49, under the 21 heading "Materials and Methods." It makes a ` 22 reference that the asbestos materials were 23 obtained from Mount Sinai School of Medicine in 24 New York? 25 A. Yes. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009292 $8 3 A. Yes. 4 Q. So to try to move this along, the 5 actual laboratory research you have done 6 concerning asbestos is shown in your CV in two 7 places, one on page 2, second to last entry at 8 the bottom, and then it appears again on page 7 9 in this entry in the middle from '85 to '877 10 A. Are you asking me does this broadly 11 apply to every -- let me say it differently. In 12 terms of sitting in the lab and injecting rats, 13 doing animal studies, specifically hands-on 14 asbestos work? 15 Q. Right. 16 A. That's correct. 17 Q. I just want to ask some basic 18 questions. The study ofpathology is basically 19 looking at tissue from the body, correct? Thai's 20 what a pathologist docs? 21 A. It's a compound question, really. 22 What did you ask me, what was the first part? 23 Q. A pathologist, what a pathologist does 24 is look at or study tissue samples, would that be 25 fair to say? 0182 1 Ilgren 2 A. It could be tissue samples. It could 3 be various fluids. It's a whole range of 4 materials. 5 Q. Materials from the body? 6 A. A pathologist can also be an 7 experimental pathologist. A pathologist can also 8 be a research -1 think there is a whole array 9 ofcategories of pathologists. The person who 10 studies disease may be a fundamental research 11 pathologist who never looks at a body, doesn't 12 look at a whole organism, may spend his entire 13 life doing in vitro studies or theoretical 14 modeling. 15 Q. A pathologist does not treat living, 16 breathing patients and put a stethoscope to their 17 chest? 18 A. That's correct. 19 Q. The pathologist studies or analyzes 20 samples of tissue and fluid and that sort of 21 thing? 22 A. Pathology is the study of disease. A 23 pathologist is a person who studies diseases. 24 Q. I'm not trying to make more of this 25 than there is. but an epidemiologist also studies 0183 1 Ilgren 2 diseases, but a pathologist studies diseases from 3 the perspective of looking at or studying or 4 analyzing tissues and parts from the human body? UCARE F00009401 1 Ilgren 474 2 Q. First of all, have you seen that 3 before? 4 A. Yes . 5 Q. And you had a chance to read it? 6 A. Yes. ' 7 Q- When did you first obtain a copy of 8 this - - when did you first see this report? 9 A. I don't recall, nine, ten months ago. 10 Q. Is it fair to say that this is not 11 included in your book? 12 A. Yes, it is. 13 Q. Is this report included in your book? 14 A. No. 15 Q. Why is that? 16 A. Too recent. 17 Q. So at the time you reviewed the 18 literature and for this compendium which resulted 19 in your book , you did not have a copy of this at 20 your disposal? 21 A. No. 22 Q. Now let me ask you this, had you had 23 a copy of this at your disposal, would you have 24 included it in your book? 25 A. Yes. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009294 1' Ilgren 47-5 ' 2 Q. And where did you first get a copy of 3 this exhibit? 4 A. Mr. Gerson. 5 Q. What is the time period during which 6 you researched and- compiled the literature that's 10 7 tabulated in your book? When did you start and 8 when did you finish? 9 A. Six, seven years. 10 Q. All right. 11 A. Probably more like five years, 12 thinking about it. 13 Q. You mentioned that you obtained this 14 Mellon Institute report. Exhibit 23 -- I'm 15 wondering what was the cutoff date for material 16 that went into your book? 17 A. '91. 18 . 19 20 21 MR. BROWNSON: Let's mark one more. (Whereupon, Mellon Institute report dated September 3, 1971 marked Plaintiff's Exhibit 24 for identification, as of this 22 date.) 23 Q. This is the September 3, 1971 Mellon 24 Institute report. 25 MR. WILL: What date? DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009295 1 Ilgren . 476 2 MR. BROWNSON: September 3, 1971. 3 Q. And I would like to ask you the same 4 series of questions. This is not included in your 5 book, is it? 6 A. No. I 7 Q. And why not? , ] 8 A. Same reason. 9 Q. Because you obtained it after you ) 10 compiled the material for your book? 11 A. Yes. 1 12 Q. And did you obtain this report. 13 Exhibit 24, at the same time you got the other 14 Mellon Institute report? 15 A. Yes. J 16 Q. And you got them both f rom Alan 17 Gerson? ] 18 A. Yes. i 19 Q. Now, you told us earlier that with ] 20 respect to the six or seven with Mr. Bergstrom, 21 Conwed cases dealing with mesothelioma, you did i 22 not believe that those mesotheliomas were caused 23 by the Union Carbide asbestos because you just 24 don't believe that could cause mesothelioma? 25 A. Correct. DOYLE REPORTING, -INC. - 212- 867-8220 UCAREF00009296 1 Ilgren 477 2 Q. Is it your opinion that there is a 3 background or threshold level of chrysotile 4 asbestos exposure below which you simply cannot 5 get mesothelioma? 6 A. I just said chrysotile cannot make 7 mesothelioma. 8 Q. I'm just talking about chrysotile 9 generally? 10 A. You mean like a tremolite 11 contaminated. 12 Q. Let's talk about Canadian. 13 A. I believe there's a tremolite 14 threshold from 200 to 300 fibre years. 15 Q. Is it your opinion that Canadian 16 chrysotile by itself cannot cause mesothelioma 17 under any circumstances? 18 A. In the absence of tremolite 19 contamination? 20 Q. Yes. 21 A. I would say in light of my knowledge 22 of the literature and study, yes. 23 Q. And is it your view that Canadian 24 chrysotile asbestos as it exists with its 25 tremolite contamination can cause mesothelioma but DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009297 1 ' Ilgren' 478 2 there ia a threshold below which it cannot?.-; 3 A. Yes. 4 Q. In humans? 5 A. Yes. 6 Q. And do you base that in part upon the 7 animal data which is reported in your book? 8 A. No. 9 Q. So the animal data reported in your 10 book is not a basis for that conclusion? 11 A. No, it's more an understanding of the 12 Thetford Cohort. 13 Q. So what you're talking about 14 basically is studies by correspondence Corbet 15 MacDonald up in Canada or Quebec? 16 A. Yes. 17 Q. . Based on that data, you deduced that 18 there is a threshold exposure to that Canadian 19 chrysotile below which you cannot get mesothelioma 20 and above which you can? 21 A. Yes. And and also the Libby1 22 vermiculytes and tremolyte data. 23 Q. It's also your view, is it not, that 24 there's a threshold level of exposure to amosite 25 asbestos below which humans cannot get DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009298 1 Ilgren 479 2 mesothelioma and above which humans can get. 3 mesothelioma? 4 A. Yes. 5 Q. Is that threshold based upon the 6 animal data in your book? ' 7 A. No. 8 Q. It's not. What is that based upon? 9 A. Uxbridge Patterson Cohorts. 10 Q. That's based upon studies of 11 workers - - 12 A. Perhaps you could ask your question 13 again to make sure. 14 Q. What I'm trying to find out, let's 15 start with your opinion that there is a threshold 16 or cutoff level of exposure to amosite asbestos 17 below which humans don't get mesothelioma and 18 above which they do. ' 19 A. Certainly the animal data contribute 20 and support the idea that there is a threshold in 21 humans, because in animals there are apparently 22 levels beneath which one doesn't get mesothelioma. 23 I was thinking more you were talking about the 24 sort of specific figures we had derived, Kevin 25 Brown and I, for amosite, the number of fibre DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009299 1 Ilgren 481 '' 2 A. I don't know what the WDC samples had 3 in terms of potential tremolite. I don't feel by 4 any means that enough work has been done to 5 exclude the possibility that there is an analogous 6 situation in the animal studies, i.e. there's 7 amphibole present. I think there has been lung 8 burden analyses done of rats from Chris Wagner's 9 study published in 1986, I don't remember, which 10 have shown amphilbole in the lungs of these 11 animals. 12 Q. How aboutthe injection studies you 13 reported in your book with Calidria asbestos where 14 tumors were produced, are you saying that those 15 tumors were not caused by the Calidria injected 16 into those rats? 17 A. You were talking a second ago about 18 Canadian - - 19 Q. Now I've changed topics. 20 A. In terms of changed topics, I feel 21 that tumors produced by Calidria in the Suzuki and 22 Maltoni studies were due to exceedingly high dose, 23 non specific mass effects predominantly. 24 MR. WILL: Is that assuming that 25 Maltoni used Calidria? DOYLE REPORTING,INC. - 212-867-8220 UCAREF00009300 1 Ilgren 482 ' 2 THE WITNESS: Yes. 3 Q. With respect to Suzuki, you'll agree-- 4 that the Suzuki injection studies produced tumors 5 of mesothelioma. You're just claiming that they 6 used too much? 7 A. Yes. 8 Q. A very high dose in essence? 9 A. Yes, with 25 milligrams minimum into 10 the peritoneal cavities of a mouse. 11 Q. Going back to the question of amosite 12 asbestos and this idea of a threshold or cutoff 13 level below which will not produce mesothelioma 14 and above which it will. As I understand it, that 15 concept in your mind is based partly on the animal 16 data and partly on studies of plant workers at the 17 unarco plant in New Jersey and the Uxbridge plant 18 in Britain? 19 A. Yes. 20 Q. Let me change gears a little bit and 21 ask you about background levels of mesothelioma/ 22 A. Right. 23 Q. Which you talkabout in your book. 24 A. Yes. 25 Q. And again referring to the text of DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009301 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ` Ilgren : 483 ' the book, at the front of the book you make the statement, and I'm paraphrasing, you find a certain background or I guess idiopathic level of mesothelioma in animals? A. Yes. Q. And you translate that to humans, is that right? A. Christ Wagner and I did compare idiopathic background types, in a sense non nonasbestos - related mesotheliomas found in humans. There's a certain degree of comparability. Q. Let me put it to you this way. In reviewing this literature that you tabulated in your book, you have come up with this idea there's a certain number of mesotheliomas that occurred in animals that are not related to asbestos? A. Yes. Q. You say this lends support to the idea there are a certain number of mesotheliomas in humans that are not caused by asbestos exposure? A. Yes. Q. Is it your opinion that any of the seven cases at Conwed of meso.thelioma were caused DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009302 1 Ilgren 484 2 by background or nonasbestos causes? 3 A. X have to look at the case. 4 Q. As you sit here today, you don't 5 recall - - 6 A. . They're very detailed cases. 7 Q. You have stated in your book that in 8 a particular animal study, if one mesothelioma is 9 seen -- does not indicate to you that it's related 10 to asbestos, is that fair to say? 11 A. Yes. 12 Q. Now you compile all of these 13 different animal studies and the rates, whether 14 they are injection or inhalation studies and the 15 various percentages or rates of mesothelioma 16 found, and what I'm wondering as a general 17 statement, is there a level in animals, in the 18 animal studies that you regard as background, be 19 it 10 percent, 20 percent, 30 percent, whatever? 20 A. In my 1989 note to ASI, I discussed 21 exactly that point. One mesothelioma in an 22 inhalation study -- I think -- again, I would like 23 to have the paper in front of me. I think it was 24 25 percent in the intraperitoneal study and 25 somewhere 10 to 12 percent in the intraperitoneal DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009303 1 Ilgren . ' 485 2 injection study. 3 Q. If we start with intraperitoneal 4 injection studies in animals - 5 A. Yes. ' 6 Q. -- it.'s^ your general view, I'm not 7 going to hold you to exact percentages, that about 8 20 to 25 percent of mesotheliomas that would show 9 up in those studies are background or 10 nonasbestos-related, is that fair to say? 11 A. Yes. In the context of the 12 experiment. 13 Q. And do you make any sort of 14 extrapolation or transference to human experience 15 based on that fact? - 16 A.' Yes. 17 Q. And what is that? 18 ` A. To my mind it suggests that the 19 number of asbestos fibers that need to be injected 20 into the peritoneal cavity to produce a level 21 which exceeds this level of background figure is 22 extremely high. 23 Q. I don't follow you. You don't inject 24 asbestos into the peritoneal cavity, you're 25 talking about the animals? DOYLE REPORTING, INC. - 212-867-8220 ......... UCAREF00009304 1 Ilgren 486 2 A. I think I got the question wrong. 3 Q. My question is, if we take as a 4 proposition your conclusion that the 5 intraperitoneal studies show about a 20 to 25 6 percent background rate of mesothelioma in 7 animals - - 8 A. Yes. 9 Q. -- I'm wondering if we can take that 10 percentage and use that as a basis that a certain 11 percentage of human mesotheliomas are not caused 12 by asbestos? 13 MR. GOLDMAN: I object to the form 14 of the question. 15 A. The problem is that the manner in 16 which you arrive at the 20 to 25 percent figure is 17 that you take the number of tumors which just 18 simply arise spontaneously in the animal - 19 Q. Let me stop you there. You get that 20 from the control group? 21 A. Yes. 22 Q. All right - 23 A. You get that -- fromcomparing the 24 different amounts injected? 25 A. You get that from the untreated DOYLE REPORTING,.INC. - 212-867-8220 ' UCAREF00009305 1 Ilgren 487 ' 2 control group. 3 Q. All right. 4 A. And then if you take the treated 5 control group, in other words, a sham-treated 6 control where you just inject the needle into the 7 cavity, you get a certain percentage of tumors 8 from that manipulation. If you then do a 9 vehicle-alone treated control, so if the stuff is 10 injected in saline solution, you just inject 11 saline solution, you get another percent. Then if 12 you inject what they call a nonfibrous dust alone 13 control, you get another percent. 14 So this 20, 25 percent figure is the 15 composite of the untreated control, the 16 sham-treated control, the vehicle-alone treated 17 control, the fibrous control, which is to focus on 18 what specifically the agent is. That's the 19 variation of the figures. 20 When you go to humans, the only 21 element of that composite that is really . 22 comparable, since we don't inject things into 23 animals, asbestos, would be the so-called 24 untreated control. That I think is running about 25 1 to 2 percent. I would have to look at the data. DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009306 13 1 Ilgren 488' 2 Q. Now which data would you look at to 3 get that percentage? 4 A. I would look in humans, what data -- 5 Q. in humans -- I thought that's what 6 you said? 7 A. No. 8 Q. Let's back up. 9 A. In animals, I would look at the 10 so-called spontaneous peritoneal examples. 11 Q. Is that the 1 to 2 percent? 12 A. I don't recall what the number is. 13 Or I would look at the untreated control group and 14 I would say, well, there's a low level of 15 mesothelioma arising in the peritoneal cavity of 16 animals and there is indeed a certain percentage 17 of peritoneal mesotheliomas arising in clearly 18 nonasbestos - exposed humans. And it's very small. 19 Q. You say peritoneal -- 20 A. We're talking about the peritoneal -- 21 Q. We should leave the discussion there. 22 EXAMINATION BY 23 MR. WILL: 24 Q. I would like to ask you two follow-up 25 clarification questions on this. Exhibit 18 and DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009307 1 ' . . ' Ilg'ren 489 2 Exhibit 20. 3 On Exhibit 18, Mr. Brownson asked you 4 some questions about something on page 4' where it 5 said that the -- all samples had their largest 6 components in the range of ..03 to .05 microns 7 referenced in table 4. Does that indicate that 8 the majority of the sample was in that range or 9 can you tell from that statement alone? 10 A. I can tell. 11 Q- It could be just a plurality? 12 A. Yes. 13 Q. With respect to Exhibit 20, the Rood 14 and Streeter article. 15 A. All right. 16 Q. Mr. Brownson asked you a question 17 about the igeometric mean out of a text. I'm 3 18 referencing table 1. Does that also give the 3 19 arithmetic mean? 20 A. Yes . 21 Q. And to your understanding, the table; 22 in Exhibit 18 from ASTECO, are they geometric or 23 . arithmetic means? 24 A. I don't know. 25 Q. If you wanted to compare them, would DOYLE REPORTING, INC. - 212-867-8220 U CARE F00009308 1' Ilgren 490 2 you need to know whether they are arithmetic or 3 geometric, which to compare them to? 4 A. Yes. The most appropriate analysis 5 would be a total fibre dimensional analysis. 6 Q. I'm j.ust asking if you wanted to - 7 A. Apples to oranges. 8 Q. You have to compare arithmetic to 9 arithmetic or geometric to geometric? 10 MR. BROWNSON: Unfortunately we 11 didn't get that done, so we'll not conclude 12 the deposition, but could we just ask that 13 the reporter take the exhibits marked today 14 . and put them with the transcript, $.nd I 15 want a copy of the transcript. . We have 16 five exhibits which are the five 17 mesothelioma files -- we'll do it at the 18 ' next session. We'll do it next time. 19 (Time noted: 4:30 p.m.) 20 21 22 Subscribed and sworn to before me 23 thisday of, 1994. 24 25 DOYLE REPORTING, INC. - 212-867-8220 ........... UCAREF00009309 STATE OF NEW YORK COUNTY OF NEW YORK ss I, DAVID OCANAS, a Certified Shorthand Reporter and Notary Public within and for the State of New York, do hereby certify: . That I reported the proceedings in the within entitled matter, and that the within transcript .is a true record of such proceedings. I further certify that I am not related, by blood or marriage, to any of the parties in this matter and that I am in no way interested in the outcome of this matter. IN WITNESS WHEREOF, I have hereunto set my hand 1994 DAVID OCANAS, C.S.R UCAREF00009310 1 492 2 November 18, 1994 3 4 wltnggja. 5 Edward B. Ilgren 6 IE fi I X Page. 346 . t.. . . '' .................. . " " . .ilaiiiia 8 Plaintiff's 9 ppy ?dQht, . , ' ' . " . Page 10 13 Document entitled "Unpublished Materials & Correspondence 11 Pertaining to Calidria Reviewed for Conwed Versus UCC by Dr. 12 E.B. Ilgren as of 10 November '94" 347 13 14 Letter dated February 16, 1994 400 14 15 Dr. Addison's comments document 405 15 16 Letter dated January 5, 1994 419 J 16 17 Document headed "Partial List of 17 J 18 Persons Receiving Sample of Chrysotile (CH-29)" 421 18 Document headed "fibre Size ] 19 Determination and Distribution of Calidria Chrysotile Asbestos 20 J 21 by Transmission Electron Micros.copy" 42 7 19 Document headed "fibre Size 3 22 Determination and Distribution of RG-244 Calidria Chrysotile 23 ,1 24 Asbetos by Transmission Electron Microscopy" 431 1 25 DOYLE REPORTING, INC, 212-867-8220 U CAREF00009311 i 1 ' 493 2 November 18, 1994 3 4 5 6 > 89 10 R X S L R L X 3. (Continued) Plaintiff's For Tdent. Pace 20 * Document entitled "Size Distributions of Occupational Airborne Asbestos Textile Fibers , * s as Determined; By Transmission Electron Microscopy" ` .. ` ` . ' 459' 21 Document entitled "Characterization of Three Types of Chrysotile Asbestos after Aerosolization" 463 11 22 12 Document entitled "Non- Occupational Exposure to Mineral Fibres" 471 13 23 14 24 -15 Document entitled "Mellon Institute, Special Report" Mellon Institute report dated September 3, 1971 473 475 16 17 ] 18 ] 19 20 ] 21 ] 22 23 j 24 oOo 25 DOYLE REPORTING, INC. 212-867-8220 UCAREF00009312 1 494 2 November 18, 1994 3 INDEX OF DOCUMENTS/INFORMATION RBOITESTED 4 Page Line 5 367 20 6 7/ 8 9 INDEX OF QUESTIONSMARKED FOR RULING 10 li ' . Page Line . 413 16 12 J 13 .1 14 15 oOo 16 17 3 18 j 19 20 ;] 21 3 22 23 . j 24 25 DOYLE REPORTING, INC. - 212-867-8220 UCAREF00009313 J 1 0001 1 2 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA 3------------------------------------ x In Re: 4 Asbesos Products Liability Civil Action Litigtion (No. VI) No. MDL 875 5----------------------------------------x UNITED STATES DISTRICT COURT 6 FIFTH DIVISION DISTRICT OF MINNESOTA CONWED CORPORATION, 8 Plaintiff, -against- 9 UNION CARBIDE CHEMICALS AND PLASTICS COMPANY, INC., (ffk/a UNION 10 CARBIDE CORPORATION), Defendant, 11 -and- Case No. Civ. 5-92-88 12 UNION CARBIDE CHEMICALS AND PLASTICS COMPANY, INC., (ffk/a UNION 13 CARBIDE CORPORATION), Third-Party Plaintiffs, 14 . -against- OWENS-CORNING FIBERGLAS CORPORATION, 15 WALKER JAMAR COMPANY, A.W.KUETTEL& SONS, INC., API, INC., and MacARTHUR COMPANY, 16 Third-Party Defendants. x 17 . 18 19 20 21 22 23 24 25 0002 1 2 June 21,1994 3 10:25 a.m. 4 5 Deposition of EDWARD B. ILGREN, 6 taken by Plaintiff, pursuant to Notice, at the 7 offices of Kelley Drye & Warren, 101 Park 8 Avenue, before Douglas M. Burke, a Shorthand 9 Reporter and Notary Public within and for the 10 State of New York. 11 12 UCAREF00009314 2 13 14 13 16 17 18 19 20 21 22 23 24 25 0003 1 2 APPEARANCES: 3 4 STITCH ANGELL KREIDLER & MUTH 5 Attorneys for Plaintiff 6 The Crossings, Suite 120 7 250 Second Avenue South 8 Minneapolis, Minnesota 55401 9 BY: ROBERT D.BROWNSON, ESQ., 10 of Counsel 11 -AND12 RUDNICK & WOLFE 13 203 North LaSalle, Suite 1800 14 Chicago, Illinois 60601 15 BY: MICHAEL GOLDMAN, ESQ., 16 of Counsel 17 18 FOLEY & LARDNER 19 Attorneys for Defendant 20 777 East Wisconsin Avenue 21 Milwaukee, Wisconsin 53202-5367 22 BY: TREVOR J. WILL, ESQ., 23 of Counsel 24 -AND- 25 0004 1 2 APPEARANCES: (Continued) 3 4 KELLEY DRYE & WARREN 5 Attorneys for Defendant 6 101 Park Avenue 7 New York, New York 10178 8 BY: ALAN GERSON, ESQ., 9 of Counsel 10 11 ALSO PRESENT: 12 VIRGINIA RUSZCZYK 13 14 UCAREF00009315 3 15 16 ' 17 18 19 20 21 22 23 24 25 0005 1 2 EDWARD B. ILGRBN, 3 having been duly sworn by the Notary Public, 4 was examined and testified as follows: 5 EXAMINATION BY 6 MR BROWNSON: 7 Q. I'mBobBrownson. We are here today 8 to take your deposition in a case entitled Conwed 9 Corporation versus Union Carbide versus two or 10 three third-party defendants. 11 I better state for the record that 12 none of the third-party defendants are present 13 here today. They were told about the deposition, 14 so we are going to go ahead without them. 15 With that being said, as I understand 16 it, you have had your deposition taken before, is 17 that correct? 18 A. Yes. 19 Q. Have you ever had it taken in any 20 context other than in asbestos litigation? 21 A. No. . 22 Q. So it would be fair to say that any 23 depositions that have been taken ofyou as a 24 witness have been in the context of asbestos 25 litigation, correct? 0006 1 Ilgren 2 A. Yes. 3 Q. And that includes both personal injury 4 and property damage litigation, as I understand 5 it, correct? 6 A. Yes. 7 Q. Let me briefly run throughthose 8 depositions. Before I do, first of all, you 9 understand the deposition procedure, I know, but 10 for the record is it clear to you what the 11 procedure is here today and how the questions are 12 asked and answers given, you understand that? 13 A. Why don't you just review it. 14 Q. Let me say this. First of all I'll 15 ask questions and you can give answers and 16 there's a couple of things I would like to say. UCAREF00009316 4 17 First of all, it's difficult for the 18 reporter to take us both talking at once, so try 19 to wait until the question is completed and I 20 will wait until the answer is completed. 21 Secondly speak up audibly and don't 22 mumble or shake your head or shrug your 23 shoulders. 24 If any ofthe questions are unclear. 25 tell me that before we answer them so we can be 0007 1 Ilgren 2 assured we have a record of answers in response 3 to questions that you understood. 4 A. Okay. 5 Q. Let's go back to these prior 6 depositions that have been taken where you were a 7 witness. 8 With respect to personal injury 9 asbestos cases, can you run down for me the 10 depositions that you have given in those cases? 11 A. I believe it's Doherty versus 12 W.R. Grace. The exact date 1 can't remember. 13 Somewhere around two years ago. 14 The second and third were together, 13 Ciliento and Seuss versus OCF. 16 The fourth would be Hermannson versus 17 W.R. Grace/Cooper Industries. 18 I believe there are only four personal 19 injury cases. 20 Q. The case ofDoherty versus W.R. Grace, 21 was that in Tampa, Florida? 22 A. Yes. 23 Q. In that particular case were you 24 working on behalf of W.R. Grace7 25 A. Yes. 0008 1 Ilgren 2 Q. Any others or was it just Grace7 3 A. Just Grace. 4 Q. As I understand it, your deposition 5 was taken in that case, but do you know ifthe 6 case ever went to trial following that time? 7 A. Yes. 8 Q. Did it go to trial? 9 A. Yes. 10 Q: Did you testify at trial? 11 A. Yes. 12 Q. That was in Tampa, was it? 13 A. Yes. 14 Q. Do you recall on that occasion when 15 you testified at the trial of the Doherty case 16 whether that testimony was completed in one 17 or did you have to stay over? 18 A. One day. -- UCAREF00009317 5 19 Q. The other two cases, the Ciliento and 20 Seuss, just so I'm clear, was your deposition 21 taken in connection with both cases in two 22 sessions or did they take it once for one of the 23 cases and then a second lime for the other one, 24 or how did that work? 25 A. Two cases, one session, one day. 0009 1 Ilgren 2 Q. So there was a single session of that 3 deposition and it applied to both ofthose cases? 4 A. Yes. 5 Q. Where was that case pending, do you 6 recall? 7 A. Jacksonville. 8 Q. Is that Duval County Circuit Court? 9 A. I believe so. 10 Q. On that particular case were you 11 working on behalf of OCF or someone else? 12 A. OCF. 13 Q. In connection with this particular 14 case, Conwed versus Union Carbide, let me ask 15 have you done any work on behalfofOCF in this 16 case? 17 A. No. 18 Q. Until you came here today were you 19 aware that they were a third-party defendant in 20 this case? 21 A. Yes. 22 Q. When did you first become aware of 23 that fact? 24 A. I don't recall. 25 Q. In any event, going back to the case 0010 1 Ilgren 2 in Jacksonville where the deposition was taken, 3 do you recall ifthat case went to trial 4 following the taking ofyour deposition? 5 A. Yes. 6 Q. Did it go to trial? 7 A. Yes. 8 Q. Did you testify at the trial? 9 A. Yes. 10 Q. Do you recall ifthat trial testimony 11 all took place on one day or did that go over a 12 second day? 13 A. One day. 14 Q. Were there defendants in this case 15 other than OCF other than at trial, as far as you 16 know? 17 A. Not that I recall. 18 Q. So as far as your best recollection 19 today, there were the two plaintiffs and then 20 defendant OCF? UCAREF00009318 6 21 A. Yes. 22 Q. And those three parties went to trial? 23 A. Yes. 24 Q. Who was representing OCF in that 25 trial, do you recall? 0011 1 Ilgren 2 A. Mr. Richard Hines. 3 Q. Who is he with, what firm, do you 4 know? 5 A. I cant recall. 6 Q. In preparing for your deposition or 7 trial testimony in that case, did you meet with 8 ary attorneys other than Mr. Hines? 9 A. I don't recall 10 Q. Do you recall ifMr. Garrard was 11 involved at all in the preparation of that trial? 12 A. No, he wasn't. 13 Q. How about Mr. Shaw from Columbia, 14 South Carolina, was he involved, Bruce Shaw? 15 A. No. 16 Q. Jim Crosby, was he involved? 17 A. No. 18 Q. The third case you mentioned is this 19 Hermannson case. That was a case in the Cook 20 County Circuit Court in Chicago, is that correct? 21 A. I believe so. 22 Q. As I understand it, your deposition 23 was taken in that case prior to trial, is that 24 correct? 25 A. Yes. 0012 1 Ilgren 2 Q. You also testified during the court 3 proceedings at trial in that case? 4 A. Yes. 5 Q. I was unclear, but was a second 6 session ofyour deposition also taken just before 7 you testified in that case or how did that work? 8 A. I think a month before. 9 Q. Maybe I can help you out I didn't 10 bring it with me today, but I got a transcript of 11 your deposition that was taken in the case. It 12 seemed to indicate that there had been a prior 13 session but you couldn't tell by reading the 14 comments, and that's where I got the idea that 15 maybe there was another session. 16 Does that help you at all recall 17 whether there were two sessions or one? 18 A. There were two sessions. 19 Q. So you recall one being about a month 20 before trial? 21 A. Yes. 22 Q. And then the second one on the eve of UCAREF00009319 7 23 trial? 24 A. No, sir. 25 Q. When was the second one in relation to 0013 1 Ilgren 2 the trial? 3 A. I believe a month before. 4 Q. So the first, then, would have been 5 sometime about a month before trial? 6 A. Yes. 7 Q. Do you recall why it was they had a 8 second session of that deposition? They just 9 didn't get done? 10 A. I believe I was initially retained by 11 W.R. Grace and they settled and then I received a 12 call from the representative of Cooper, and she 13 said we would like you to continue to work with 14 us on the case. 15 Q. 1 understand you prepared two written 16 reports in that case, is that correct, do you 17 recall that? 18 A. 1 recall one. I don't recall two. 19 Q. Let me see if I can move this along. 20 I saw a copy ofone report you issued in the case 21 which was a report addressed to, I believe, the 22 lawyer for Grace, and then following that time 23 you sent some either tumor tissue or clear lung 24 tissue to Dr. Gibbs for some tissue burden 25 analysis, and then there was much arguing and 0014 1 Ilgren 2 discussion among the lawyers on the record over 3 whether that evidence could be admissible and 4 there seemed to be a reference to a subsequent 5 report about that, but I couldn't tell if there 6 was or not Do you remember? 7 A. I can't recall if a subsequent report 8 was ever filed. 9 Q. Going back to these other three 10 personal injury plaintiffs that you mentioned, 11 Doherty, Ciliento and Seuss, do you recall ifyou 12 had tissue examined by either Dr. Gibbs or 13 Dr. Pooley in either of those three cases or for 14 either of those three plaintiff? 15 A. Possibly ail three, though I don't 16 recall exactly. 17 Q. Do you recall if it would have been 18 Dr. Gibbs or Dr. Pooley or both? 19 A. I think it's Gibbs' and Pooley's lab. 20 Q. So21 A. To some extent they work together. 22 Q- Pooley is in Wales, correct, in 23 Cardiff? 24 A. They are both in Wales. They are both UCAREF00009320 8 25 in Cardiff 0015 1 Ilgren 2 Q. Do they share the same laboratory in 3 Cardiff? 4 A. I don't know. I just don't know their 5 physical setup. 6 Q. But in your experience, ifyou send 7 some tissue for a fiber burden analysis to that 8 lab, it could be done either by Pooley or Gibbs 9 or do you designate one or the other, or how does 10 that work? 11 A. Alan Gibbs receives the tissue and I 12 believe works with Fred Pooley to do the count, 13 the identification ofthe fibers, but I might be 14 wrong. I don't know. 15 Q. As 1 understand it. Dr. Gibbs is a 16 pathologist, is that correct? 17 A. Yes. 18 Q. And Dr. Pooley is not a medical 19 doctor, he is a mineralogist? 20 A. Yes. 21 Q. It's your understanding at least in 22 those three cases that they work together in 23 analyzing tissue, but you're not sure in those 24 three cases ifit goes to Pooley first and then 25 Gibbs or vice versa, would that be a fair 0016 1 Ilgren 2 summary? 3 A. It goes to Gibbs first, but beyond 4 that I don't know. 5 Q. I'm going to jump ahead a little bit, 6 but in this particular case, Conwed versus Union 7 Carbide, do you know ifany tissue of any worker 8 from the Conwed plant in Minnesota has been 9 examined by either Dr. Gibbs or Dr. Pooley? 10 A. I don't know. 11 Q. At least as far as any examination of 12 tissue being done through you, do you know if 13 that's been done or not by either Dr. Gibbs or 14 Dr. Pooley? 15 A. Not through me. 16 Q. So put another way, you have sent no 17 tissue to either Dr. Gibbs or Dr. Pooley for 18 analysis in connection with the present lawsuit, 19 would that be feir to say? 20 A. Yes. 21 Q. Have you seen any tissue samples, 22 whether they are blocks or slides, of any of the 23 Conwed workers involved in this particular case? 24 A. No. 25 Q. Have you seen any of the pathology 0017 UCAREF00009321 9 1 Ilgren 2 reports ofany ofthe Conwed workers involved in 3 this case? 4 A. Yes, sir. 5 Q. Do yon recall the disease of the 6 workers? 7 MR. WILL: You mean as alleged? 8 Q. The diseases alleged in the workers 9 you have seen the reports of. 10 A. Alleged mesothelioma. 11 Q. How many of those have yon seen ofthe 12 Conwed workers? 13 A. Six. 14 Q. Well get into that later, but let's 15 move on to the other depositions that you have 16 given. 17 Other than the personal injury cases, 18 I understand that you have worked in at least two 19 building lawsuits concerning asbestos, is that 20 correct? 21 A. Yes. 22 Q. Was one ofthem the Adams-Arapahoe 23 School District case in Colorado? 24 A. I don't believe so. 25 Q. Do you recall the names ofthe two 0018 1 Ilgren 2 cases you were involved with in terms of giving 3 depositions? 4 A. Cincinnati Schools, national Class 5 Action and City ofBaltimore. 6 Q. In the Cincinnati School case was that 7 for GAP or was that someone else? 8 A. Celotex. 9 Q. In the National School Class action, 10 who did you give a deposition on behalfof in 11 that case? 12 A. I don't recall. Either Celotex or 13 GAF. One or the other. 14 Q. In the City ofBaltimore case, do you 15 recall who the deposition was fOT in that case? 16 A. The same as the National Class. 17 Q. So it would be either Celotex or GAF? 18 A.. I just don't recall: 19 Q. Let me ask you this: Do you recall if 20 in the City ofBaltimore case the product at 21 issue that you were concerned with was floor 22 tile? 23 A. I just don't recall. 24 Q. Other than those three cases, have you 25 given any depositions in any asbestos building 0019 1 Ilgren 2 litigation? UCAREF00009322 10 3 A. No, sir. 4 Q. Have you testified at any trials in 5 any asbestos building litigation? 6 A. No, sir. 7 Q. Have you given any depositions or 8 testified in any asbestos insurance-related 9 litigation? 10 A. No, sir. 11 Q. So would the depositions you have now 12 told us about in the four personal injury 13 plaintiffs and the three building plaintiffs 14 comprise the depositions you have given? 15 A. I believe so. 16 Q. Likewise with the trials, it looks 17 like you have testified in the three personal 18 injuty trials? 19 A. Yes. 20 Q. Would that comprise all of the trials 21 that you have testified in? 22 MR.GERSON: Relating to asbestos? 23 MR. BROWNSON: Right 24 A. Yes, sir. 25 Q. Let me change topics a little bit and 0020 1 llgren 2 talk about the present lawsuit 3 My first question concerning this case 4 is when were you first retained in connection 5 with this case? 6 A. Perhaps two years ago. 7 Q. Do you maintain any sort of written 8 record or file in connection with that that 9 would contain any materials in connection with 10 this case? 11 A. A small file. 12 Q. Where do you maintain that file? 13 A. My office in Bryn Mawr. 14 Q. What are the contents ofthat file? 15 A. Records of alleged mesothelioma 16 cases. Literature. Hygiene records. Related 17 papers. 18 Q. Under the category of related papers, 19 does that include correspondence? 20 A. Some. 21 Q. Is there a correspondence with any 22 other medical doctors that you maintain in the 23 file? 24 A. Yes. 25 Q. Is the correspondence between yourself 0021 1 llgren 2 and other doctors? 3 A. Medical doctors or doctors? 4 Q. Is there correspondence between you UCAREF00009323 11 5 and other medical doctors maintained in the file? 6 A. Who is a medical doctor? I don't mean 7 to be silly or stupid. 8 Q. An MD. 9 A. It doesn't have to be a treating 10 physician? 11 Q. No, anyM.D. 12 A. Related specifically to this case? 13 Q. Right 14 A. Kevin Browne is an M.D., and that's 15 all I remember at the moment. 16 Q. You didn't bring the file with you 17 today to the deposition? 18 A. No. 19 Q. Did you review the file in preparation 20 for the deposition today? 21 MIL GERSON: Which file are you 22 referring to? 23 MR. BROWNSON: The file we havejust 24 been talking about that he maintains at Bryn 25 Mawr concerning this case. 0022 1 Hgren 2 A. At some point. 3 MR. BROWNSON: Trevor, do you have any 4 objection to us getting a copy ofhis file? 5 MR. WILL: I think so. Can we be a 6 little more specific? I don't think he 7 reviewed the correspondence with Kevin 8 Browne in preparation for the deposition, if 9 that's what you're asking. 10 MR. BROWNSON: I don't know what he 11 reviewed. Let me ask more about that. 12 Q. Let me zero in a little bit. As I 13 understand it, you have a specific file you 14 maintained in Bryn Mawr in which you keep papers 15 in connection with this case, Conwed versus Union 16 Carbide, is that fair to say? 17 A. I don't know if it's exactly specific 18 to this particular case. 19 Q. You do have certain medical records 20 specific to this particular case, correct, 21 regarding -- 22 A. Very few. Just the six case 23 summaries. 24 Q. The six case summaries. 25 A. Yes. 0023 1 Ilgren 2 Q. Let me start with those. When you say 3 you have six case summaries, are those summaries 4 of records or are they actual medical records? 5 A. It's a sort of mixture, as I recall. 6 Some are summary pages from medical records and UCAREF00009324 12 7 then one or two are like path reports and a 8 radiology report. It's certainly not a 9 voluminous, full record for each case. 10 Q. Do you know by whom the summaries of 11 the records were prepared? 12 A. No. 13 Q. But in any event, at your office at 14 Bryn Mawr in Pennsylvania you do have records 15 concerning six Conwed workers alleged to have 16 mesothelioma, would that be fair to say? 17 A. Yes. 18 RQ MRBROWNSON: I request you to give 19 us a copy of the records that he has 20 concerning the six mesothelioma cases. 21 MR. WILL: Yes, I think we can get a 22 copy ofthose. 23 Q. Other than the records ofthe six 24 cases involving mesothelioma, do you have records 25 of any other Conwed workers currently in your 0024 1 Ilgren 2 possession at Bryn Mawr or in that file or 3 anywhere else? 4 A. No, sir. 5 Q. Have you seen records involving any 6 other Conwed workers other than those six cases? 7 A. No, sir. 8 Q. Do you have any other plans that 9 you're aware ofat the present lime to review 10 records of any workers other than those six 11 cases? 12 MR. GERSON: Conwed workers? 13 MR. BROWNSON: Right. 14 A. Perhaps. 15 MR WILL: Given Fred Bergstrom's 16 allegations, ifwe ever get any information t 17 on Fred, we may ask Dr. Ilgren to take a 18 look at that. You know the situation with 19 him. You're very aware of that 20 Then depending on what your Dr. Kagan 21 and Dr. Harber say, we may ask him for 22 things in response to that. 23 Q. At the present time would it be fair 24 to say that you have been asked to examine 25 records ofmesothelioma cases from the Colgate 0025 1 Ilgren 2 plant, as opposed to asbestosis cases, for 3 example? 4 MR GERSON: Beyond the six he said he 5 examined? I don't understand your 6 question. 7 Q. First of all, as I understand it, you 8 have been asked to examine six cases, correct? UCAREF00009325 13 9 A. No. 10 Q. You have been asked to look at records 11 of six cases? 12 A. No. 13 Q. What have you been asked to do in 14 connection with those six cases? 15 A. Nothing. 16 Q. Have you been asked to make a 17 determination as to the diagnosis on those six 18 cases? 19 A. No, sir. 20 Q. Would you be able to determine the 21 adequacy of the diagnosis based on the records 22 currently in your possession or would you want 23 further information to do that on those six 24 cases? 25 A. I would have to review the individual 0026 1 Ilgren 2 cases again, but probably further information. 3 Q. Have you arrived at any conclusions, 4 sitting here today, as of June 21,1994, as to 5 the diagnosis of those six cases? 6 A. No, sir. 7 Q. Have you spoken to any of the treating 8 physicians on those six cases? 9 A. No, sir. 10 Q. By treating physicians, I mean to 11 include pathologists who may have done stains or 12 looked at tissues, have you spoken to any of 13 those people in connection with those six cases? 14 A. No. 15 Q. Have you been requested to do so in 16 connection with those six cases? 17 A. No. 18 Q. I understand from Mr. Will's comments, 19 and he can probably correct me, but it's my 20 understanding that Union Carbide has asked you to 21 or has advised you that you may be looking at 22 further Conwed worker records in the future. 23 Would that be a fair statement? 24 A. No, sir. 25 Q. So they have told you nothing in that 0027 1 Ilgren 2 regard? 3 A. No, sir. 4 Q. Other than what Mr. Will said here 5 today? 6 A. Yes, sir. 7 Q. Have you seen any x-ray films from any 8 of the Conwed workers? 9 A. No. 10 Q. Have you seen any of the pulmonary UCAREF00009326 14 11 function tests ofany of the Conwed workers? 12 A. Perhaps, but I don't recall 13 Q. Ifyou had seen pulmonary function 14 testing would it be of some of the six you have 15 described or ofsomeone else? 16 A. Ofthe six. 17 Q. So would it be fair to say that other 18 than the six cases you have described for us, you 19 haven't seen any of the records of the other 20 Conwed workers? 21 A. Correct 22 Q. Or summaries of the records? 23 A. Correct 24 Q. Or x-ray films? 25 A. Correct. 0028 1 Ilgren 2 Q. Have you spoken to any physicians who 3 have seen airy of the Conwed workers either as 4 consultants or as treating physicians? 5 A. No, sir. 6 Q. Have you been asked to speak to any of 7 those physicians? 8 A. No, sir. 9 Q. Going back to this file you maintain 10 at Bryn Mawr, is there an actual file that 11 contains material specifically related to this 12 case other than the medical materials on the six 13 cases you have toid us about7 14 A. Just a file. 15 Q. Does the file have a title? 16 A. No. 17 Q. Does it have any writing on the jacket 18 or the file folder? 19 A. Just the names of the six. 20 Q. Of the six workers? 21 A. Alleged mesothelioma workers. 22 Q. In addition to that, have you 23 collected any documents or other information 24 relating to the Conwed case? 25 MR. GERSON: Objection to form as it's 0029 1 Ilgren 2 overly broad, but ifyou can answer it, go 3 ahead. 4 A. I mean I don't want to annoy you, 5 perhaps you could just qualify it a bit 6 Q. Let me put it this way. You were 7 retained approximately two years ago to work on 8 this case, correct? 9 A. Yes. 10 Q. Since that time, other than the 11 records of the six patients that you have 12 described for us, have you collected any other UCAREF00009327 15 13 records or documents for your use in working on 14 this case? 15 A. I believe I have some Conwed hygiene 16 data, and there is some answers to 17 interrogatories which describe the manner and 18 type of asbestos used at the plant between 1958 19 and 1970,1 think 1970 or '73. 20 Q. In connection with your work in this 21 case, have you reviewed any literature, published 22 literature, upon which you rely fbr any opinions 23 you are rendering in this case? 24 A. Yes, sir. 25 Q. Is that maintained in some file? 0030 1 Ilgren 2 Where is that kept? 3 A. The same. 4 Q. That's in the same file that we were 5 just talking about? 6 A. I guess not to be semantical, but it's 7 not physically within the same file. It's within 8 other file cabinets. It's a typical office with 9 different file cabinets. 10 Q. Have you, for example, reviewed in 11 connection with this case any ofthe published 12 literature dealing with chrysotile fiber from the 13 Coalinga mine in California? 14 A. Yes. 15 Q. Is that maintained somewhere inyour 16 possession? 17 A. Yes. 18 RQ MR. BROWNSON: I request a copy ofthe 19 published literature dealing with Coalinga 20 fiber that he has reviewed in this case. 21 MR. WILL: Let's go through this and 22 let's discuss exactly how we are going to 23 handle this. Let's do that and figure out 24 the best way to get you what you need that's 25 appropriate. I think you're going to want 0031 1 Ilgren 2 to talk to him about what else he has, so 3 let's deal with this offthe record and then 4 put it on the record. 5 MR. BROWNSON: We can do that, but 6 since I am a methodical person, my notes are 7 in outline form. I'll just note them as we 8 go along. I'm not doing it because I'm 9 making multiple requests, but because that's 10 the form 1 have. 11 Q. Have you also reviewed in connection 12 with this case any unpublished documents or 13 reports or studies concerning the Coalinga fiber 14 from California? UCAREF00009328 16 15 A. Yes. 16 Q. Or analyses of that fiber? 17 A. Yes. 18 Q. Do you maintain copies of those 19 reports or analyses? 20 A. Some. 21 Q. Do you maintain copies ofall ofthe 22 reports or analyses, unpublished reports or 23 analyses ofthe Coalinga fiber that you have 24 reviewed in connection with this case7 25 A. Yes. 0032 1 Ilgren 2 RQ MR. BROWNSON: I ask to get a copy of 3 those too. 4 MR. WILL: Same thing. 5 Q. Do you recall what form those reports 6 or analyses take? 7 A. Paper. 8 Q. They are on paper as opposed to 9 computer disk, correct, or some other format? 10 A. Yes. 11 Q. Do you recall if those were reports or 12 analyses which were done specifically in 13 connection with this case or are they reports or 14 analyses that were done in some other context 15 that you obtained for use in this case? 16 A. Another context. 17 Q. Who were the authors ofthose? 18 MR. GERSON: Ofall the unpublished? 19 MR. BROWNSON: Right. 20 MR. GERSON: You're asking about the 21 unpublished reports which he reviewed in 22 connection with this case? 23 MR. BROWNSON: Right, concerning the 24 Coalinga fiber. 25 A. Off the top of my head. I'll do my 0033 1 Ilgren 2 best. 3 Q. Give the ones you can recall. 4 A. Nauman. Dresher. Wooleiy. Park. 5 Jordan. Hodgson. Addison. Bright Thickstun. 6 Addison. Mumpton. Graf. Haartz. Martin. 7 IITR1. Browne. 3 Q. Is that Kevin Browne? 9 A. Yes. Langer. Morgan, Arthur Morgan. 10 Q. Those are what you recall? 11 A. At the moment. 12 Q. Have you seen any -- 13 A. Weiss. Then the MDH Conwed report. 14 Q. That's the Minnesota Department of 15 Health? 16 A. Yes, 1989. UCAREF00009329 17 17 Q. That's March 1, 1989? 18 A. I don't recall. March or September. 19 Q. It's a thick report? 20 A. Yes. 21 MR. WILL: You're giving the publish 22 ones now? 23 THE WITNESS: No, unpublished. 24 Q. I guess you included that because I'm 25 not quite sure if that's published or 0034 1 Ilgren 2 unpublished. 3 A. Published as in standard 4 peer-reviewed, scientific, off the shelf, yes. 5 They would be not in that category. 6 Q. That's the context in which I was 7 asking the question. When I said published, I 8 meant peer-reviewed publications. 9 A. Yes. 10 Q. Airy others? 11 A. Again off the top of my head, I don't 12 recall. 13 Q. In addition to the reports or papers 14 that you havejust described to us, unpublished 15 reports or papers that you have reviewed in 16 connection with this case, have you reviewed any 17 other unpublished reports or papers dealing with 18 Coalinga asbestos that you did not consider in 19 connection with this case? 20 MR. GERSON: Referring to papers 21 specifically about the Coalinga? 22 MR.BROWNSON: Right, which deal with 23 it in some fashion. Let me put the question 24 another way. 25 0035 1 Q. Were there some papers or reports or Ilgren 2 analyses dealing with the Coalinga asbestos fiber 3 ofwhich you are aware and you looked at and you 4 decided thisjust has no relevance to the Conwed 5 versus Union Carbide case or I'm not going to 6 consider it in the context of that case? 7 A. Not to my knowledge. The question is 8 slightly complicated, but not to my knowledge. 9 Q. Let me ask you a little bit about the 10 reports you have described. 11 First of all, the Minnesota Department 12 of Health report, I actually brought a photocopy 13 of it here and I'm sure it's the one you're 14 talking about, a report to the Minnesota 15 legislature and a picture of the Conwed plant on 16 the front? 17 A. I don't recognize the cover. 18 Q. Actually in its published, and I use UCAREF00009330 18 19 that term in quotation marks, version, it's a 20 brown or tan or yellowish cover. Does that help 21 you? 22 A. Yes. 23 Q. So I have just shown you a report 24 which is a photocopy ofa report entitled 25 "Medical Screening for Asbestos-Related Lung 0036 1 Ilgren 2 Disease among Conwed Corporation Cloquet Workers 3 And Their Spouses, Preliminary Report To The 4 Legislature, March 1, 1989," by the Minnesota 5 Department ofHealth. 6 I will show you the photocopy of the 7 report Is that the report that you mentioned? 8 MR. GERSON: Do you want to mark that 9 as an exhibit? 10 MR. BROWNSON: No, I don't. I do have 11 a clean copy we could mark. 12 Q. Is this a report that you reviewed? 13 A. It appears to be so. 14 Q. They always look a little different in 15 photocopy form. 16 A. Yes, it appears to be. 17 Q. Do you recall if the version that you 18 reviewed and is in your possession is an actual 19 bound version that has the yellow or tan cover on 20 it? 21 A. No, as I recall it's unbound. i 22 Q. In addition to that report, have you 23 seen or reviewed any other materials from the 24 Minnesota Department of Health in connection with 25 the Conwed workers? 0037 1 Ilgren 2 A. I think one set of hygiene data came 3 from the MDH. I don't recall. 4 Q. When you say one set of hygiene data, 5 do you recall what sort of material was in that? 6 Was it air samples? 7 A. Yes. 8 Q. Is that something that you maintain in 9 your possession? 10 A. Yes. 11 Q. Do you recall that being some data 12 that was compiled by the Minnesota Department of 13 Health? 14 A. I believe so, but I don't recall. 15 Q. Did you receive it directly from the 16 Minnesota Department of Health, as you recall? 17 A. No. 18 Q. Do you recall the date or approximate 19 date of the air samples that were taken in that 20 data? UCAREF00009331 19 21 A. No. 22 Q. Do you know if those samples were 23 taken on or before 1974? 24 A. I think so, but I don't recall the 25 exact date. 0038 1 Ilgren 2 Q. Have you seen any of the 3 air-monitoring data taken by Union Carbide 4 industrial hygienists at the Conwed plant in 5 approximately 1972? 6 A. I believe so, yes. 7 Q. Is that the data you're speaking of or 8 were you speaking of something different than 9 that? 10 A. Different than what? 11 Q. You said earlier you had seen some 12 hygiene data that you thought might have come 13 from the Minnesota Department ofHealth. I'm 14 wondering ifthat data is the data that was taken 15 by the Union Carbide industrial hygienists in 16 Cloquet in October 72 or if it's some other 17 data. 18 A. I don't recall. It might be the UCC 19 set It might also be another set. I just don't 20 recall. 21 Q. Do you recall, sitting here today, 22 seeing any air sampling or air-monitoring data 23 out of the Conwed Cloquet Minnesota plant other 24 than taken by Union Carbide industrial 25 hygienists? 0039 1 Ilgren 2 A. Ijust dont recall. 3 Q. Would it be fair to say that whatever 4 data you have seen, you have a copy of it in your 5 possession somewhere? 6 A. Yes, sir. 7 Q. So when you spoke earlier about seeing 8 hygiene data and having a copy of hygiene data, 9 to use your term, is that what you're speaking 10 of or were you talking about something in 11 addition to that? 12 MR. WILL: I lost the reference to 13 "that,'' ' 14 Q. You have told us that you do recall 15 seeing Union Carbide air-monitoring data from the 16 Conwed plant, correct? 17 A. Yes. 18 Q. In addition to that, you thought maybe 19 there was something else that you got through the 20 Minnesota Department ofHealth, but you couldn't 21 be sure. 22 A. Yes. UCAREF00009332 20 23 Q. My question is when you spoke earlier 24 about having in your possession copies of hygiene 23 data from Conwed, are those the materials you 0040 1 Iigren 2 were speaking ofor were you including something 3 else? 4 A. Those were the materials. 5 Q. You also told us about Interrogatory 6 answers that you have seen and reviewed and you 7 maintain in your possession. 8 A. Yes. 9 Q. Who was answering these 10 interrogatories? Is it Union Carbide or is it 11 Conwed or is it both or somebody else? 12 A. I don't recall. I think it was 13 Conwed, but I don't recall 14 MR WILL: I can help you. They are 15 your answers to interrogatories, the 16 question that asks about the purchase of 17 asbestos fiber. 18 A. There is also the NAAC letter to I 19 guess Conwed. 20 Q. You're speaking of a letter from the 21 North American Asbestos in Chicago? 22 A. Yes. 23 Q. To Conwed? 24 A. Yes. 25 Q. You have seen that letter and you 0041 1 Iigren 2 maintain a copy ofthat letter in your 3 possession? 4 A. Yes. 5 Q. In addition to that, as I understand 6 it, you have some interrogatory answers that 7 describe the shipments or use of asbestos to the 8 Cloquet plant? 9 A. Yes. 10 Q. Included with that did you get copies 11 of invoices showing shipment of fiber to the 12 plant? 13 A. No. 14 Q. Sitting here today, can you give us a 15 sketch ofwhat you recall the use of asbestos at 16 the Conwed plant based upon those materials? 17 A. A sketch of it? 18 MR WILL: What do you mean, by date, 19 by fiber type, by amount? Are you asking 20 him to describe the production process? 21 Q. I'm asking based on the materials you 22 have described to us, I want your understanding 23 of what type of asbestos was used and when and ' 24 how much, as you recall it UCAREF00009333 21 25 A. The document is eight or nine pages 0042 1 Ilgren 2 long. The first halfseems to list the 3 chrysolite. The second halfseems to list the 4 amosite. The initial date of input for 5 chiysotile I think was 1966, though I can't be 6 sure, and it comes in the form of what they 7 describe as cationic pellets, a few odd shipments 8 of loose form, and I think there is another form 9 again that seemed all to be Union Carbide. 10 Then it's broken down, ifI recall, 11 several installments per year from 1966 to, 1 12 think it's 1973. 13 I don't remember the tonnage per year, 14 but there seemed to be from several hundred to 15 several thousand. 16 Then the amosite began, as I recall, ' 17 in 1958. It was from NAAC/Cape, I assume the 18 Cape distributor. It was grades G, GK and D, I 19 think. Again the tonnage, as I recall, ranged 20 from several hundred to several thousand tons, 21 though I wouldn't say that was per annum. Again 22 I would have to sit down with the numbers. 23 Q. Let me ask you this. Have you 24 obtained information concerning the amount and 25 type of asbestos used at the Cloquet plant from 0043 1 Ilgren 2 any source other than the interrogatory answers 3 and the letter from North American Asbestos that 4 you have described? 5 A. Yes. 6 (Recess taken.) 7 BY MR. BROWNSON: 8 Q. The last question was have you seen 9 other documents concerning the use, amount, type 10 or date, the use of asbestos at Conwed other than 11 those that you have described to us? 12 A. I think so, but I can't recall the 13 titles. 14 Q. Whatever those would be, would copies 15 of those also be maintained in your possession? 16 A. Yes. 17 Q. In connection with your work in this 18 case, you mentioned to us earlier that you had 19 either obtained or reviewed or relied to some 20 extent on correspondence with others. 21 MR. WILL: I don't think he said 22 that. 23 Q. I thought you did, so let me ask the 24 question. 25 In connection with your work in this 0044 UCAREF00009334 22 1 Ilgren 2 case, Comved versus Union Carbide, have you 3 collected or obtained or used correspondence from 4 other medical doctors, as we discussed before? 5 MR. WILL: That's actually kind of a 6 multiple question. I'm hot trying to be too 7 difficult. 8 A. You asked me about Kevin Browne. 9 Q. You said there was some correspondence 10 between yourselfand Kevin Browne. 11 A. Yes. 12 Q. Is that correspondence to Browne or 13 from Browne or both? 14 A. I don't recall. I think it's both. 15 It could be both. 16 Q. Is that correspondence that was 17 generated in connection with your work on this 18 case? 19 A. Perhaps not specifically. 20 Q. Was it correspondence that was 21 generated in connection with the issue of 22 Coalinga chrysolite fiber? 23 A. In part, I think. 24 Q. Does the correspondence mention 25 Coalinga chrysotile fiber? 0045 1 Ilgren 2 A. I think so, but -1 said before I 3 thought so. I'm not a thousand percent sure. 4 Q. Is it something that you relied upon 5 in any way in your work in connection with this 6 case, that correspondence? 7 A. No, sir. 8 Q. Is it something you relied upon in any 9 way in connection with any opinions you hold as 10 to the biological potential of Coalinga 11 chrysotile asbestos? 12 A. I think it's safer for me to actually 13 look at the correspondence, because I can't 14 recall at the moment the nuts and bolts of the 15 contents. 16 Q. Have you spoken to Dr. Kevin Browne 17 concerning this case, Comved versus Union 18 Carbide? 19 A. Not specifically this case. 20 Q. Have you spoken to Dr. Browne 21 concerning the issue of any biological potential 22 or health effects of Coalinga chrysotile asbestos 23 fiber? 24 A. Possibly. 25 Q. Do you know ifyou had any record of 0046 1 Ilgren 2 those conversations? Has that been reduced to UCAREF00009335 23 3 writing in any way? 4 A. I don't think so, but possibly. 3 Q. In addition to this correspondence you 6 mentioned between yourself and Dr. Brown, do you 7 have any other correspondence with anyone that 8 deals with this particular case that you maintain 9 in your possession? 10 A. Could you repeat the question. 11 (The record was read.) 12 A. There are a couple of letters from 13 Trevor WilL 14 Q. To you? 15 A. I believe so. 16 Q. Other than those couple of letters 17 from Trevor Will to you, do you know ofany other 18 correspondence that you have in your possession 19 in connection with this case? 20 A. Nothing springs to mind. 21 Q. Do you know ifthere has been any 22 correspondence generated in connection with this 23 case that may no longer be in your possession? 24 MR. GERSON: Generated by anyone? 23 MR.BROWNSON: Right, that he has seen 0047 1 Hgren 2 in connection with this case. 3 A. Off the top of my head, no. 4 Q. You had mentioned earlier that you 5 maintain in your possession copies ofwhat you 6 described as related papers and you indicated 7 that correspondence was one ofthe things that 8 would be a related paper. 9 Other than correspondence can you 10 think ofwhat else these related papers would 11 comprise? 12 A. Papers related to Calidria. 13 Q. Just for the record, Calidria is a 14 trade name that Union Carbide used and maybe 13 successor companies have used for the Coalinga 16 asbestos that comes from the New Idria deposit, 17 is that correct? 18 A. 1 just thought, it may be incorrect, I 19 thought the derivation was Cal for California and 20 Idria for the Idria serpentinite. 21 Q. So our record is clear, we have been 22 speaking at this deposition about Coalinga. You 23 mean Coalinga asbestos and we have been speaking 24 of Calidria, and those are one and the same 23 thing, is that correct? 0048 1 Ilgren 2 MR. GERSON: I don't recall that I 3 recall your question referred specifically 4 to Union Carbide Calidria. I think your UCAREF00009336 24 5 question was with respect to Calidria 6 generally. 7 A. I would say that there is a Calidria 8 fiber that may have been mined by Union Carbide 9 or JM or Atlas or not mined, just left in the 10 mountain. I use them interchangeably, Coalinga 11 fiber and Calidria fiber, I use them 12 interchangeably, not with reference specifically 13 to Union Carbide. 14 Q. And that's what caused the confusion. 15 A. Right. 16 Q. Yon are aware that there is this 17 serpentine deposit which is the New Idria deposit 18 which is sometimes called the Coalinga deposit, 19 and it's referred to as Coalinga fiber, is that 20 correct? 21 A. Yes. 22 Q. In that deposit in California which 23 Trevor Will has visited, as I understand it, 24 there have been over time three operating mines 25 or pits and one is the Union Carbide, one Is the 0049 1 Ilgren 2 Johns-Manville and one is the Atlas, is that 3 correct? 4 A. Probably one or two smaller, but 5 that's correct. 6 Q. When you use the term Calidria, you 7 use that term generically to mean the Calidria 8 deposit, and it could be fiber from actually any 9 of those three commercial mines? 10 A. Yes. 11 Q. In addition to that, and this is maybe 12 what caused the confusion, Union Carbide uses 13 Calidria with a capital C as a trade name or did 14 for some of its asbestos. 15 A. I didn't know. 16 Q. Were you aware of that? 17 A. I don't believe so. 18 Q. Let me back up a little bit and ask 19 you about the unpublished papers, reports or 20 analyses that you have reviewed and you have in 21 your possession that you listed for us, and I 22 want to just run through them and have you 23 briefly describe for me what they are. 24 Let's start, you mentioned Weiss. Is 25 that a report by Dr. William Weiss? 0050 1 Ilgren 2 A. Yes. 3 Q. He is a medical doctor in 4 Philadelphia? 5 A. Yes. 6 Q. Is that a written report? UCAREF00009337 25 7 A. Yes. 8 Q. Does it deal specifically with this 9 case or does it deal with more general issues? 10 A. Conwcd hygiene, Conwed MDH survey. 11 Q. Is that a commentary or a review or a 12 critique or an analysis ofthe Minnesota 13 Department ofHealth data that's been prepared by 14 Dr. Weiss? 15 A. Yes. 16 Q. Do you know what the date of that is? 17 A. Precisely, no. Recent. 18 Q. Does it take the form ofa letter or a 19 report or 20 A. To be specific, I haven't actually, I 21 don't posess a copy. He and I discussed it I 22 have taken some notes per his various criticisms, 23 but I don't actually physically have a copy of 24 the critique. 25 Q. Do you maintain a copy of the notes 0051 1 Ilgren 2 you have taken per your discussions with 3 Dr. Weiss7 4 A. Yes. 5 Q. In addition to those notes, have you 6 seen any sort of writing prepared by Dr. Weiss in 7 connection with his critique of the Minnesota 8 Department of Health report? 9 A. No. 10 Q. So what you have had is oral 11 conversations with Dr. Weiss7 12 A. Yes. 13 Q. Have the two ofyou actually sat down 14 face to face and discussed his thoughts and 15 critiques of the Minnesota Department of Health 16 report? 17 A. Yes. 18 Q. Do you recall when that occurred? 19 A. Months ago. 20 Q; Was it done in connection with this 21 particular lawsuit, in whole or in part? 22 A. In large part 23 Q. In addition to this particular 24 lawsuit, did that conversation concern any other 25 cases, legal cases or claims on which you are 0052 1 Ilgren 2 working concerning the Calidria or Coalinga 3 fiber? 4 A. No, sir. 5 Q. In addition to this lawsuit, have you 6 ever done any consulting work or other type of 7 work in connection with a case or a patient or a 8 claim involving exposure to Calidria fiber? UCAREF00009338 26 9 A. I believe there was one, but I can't 10 recall the name, a few years ago. 11 Q. Do you recall ifit was a case ofa 12 worker from the Conwed plant? 13 A. No, it wasn't 14 Q. Were you aware of the fact that many 15 of the Conwed workers in cases separate and 16 distinct from this one have brought legal cases 17 for injuries as a result ofexposure to Calidria IS fiber? 19 A. Would you read that back. 20 (The record was read.) 21 A. Not specifically, no. 22 Q. First ofall, are you aware of the 23 fact that in this particular lawsuit, Conwed is 24 suing Union Carbide to try to collect 25 reimbursement for past and future workers 0053 1 Ilgren 2 compensation costs? Are you generally familiar 3 with that claim? 4 A. Yes. 5 Q. What I'm asking is are you aware of 6 separate lawsuits brought by actual workers 7 against Union Carbide separate from this lawsuit 8 where they're trying to seek recovery for 9 injuries they claim were as a result ofexposure 10 to Calidria asbestos? 11 A. No, sir. 12 MR. GERSON: Were you asking if he is 13 aware of the particular cases or aware 14 generally that such cases exist? 15 MR. BROWNSON: That's a good 16 distinction. 17 Q. Were you aware generally that such 18 lawsuits existed? 19 A. No, sir. 20 Q. Have you ever worked on any particular 21 case brought by any worker alleging injury as a 22 result of exposure to Calidria asbestos from 23 Conwed? 24 A. No, sir. 25 Q. Have you ever worked on any cases 0054 1 Ilgren 2 brought by any worker alleging injury as a result 3 of exposure to Calidria asbestos at any other 4 place other than Conwed? 5 A. Yes, sir. 6 Q. Was that the one you just mentioned a 7 minute ago? 8 A. Yes, sir. 9 Q. Do you recall if that was one case or 10 more than one case? UCAREF00009339 27 11 A. I believe one case. 12 Q. Were you working on behalfof Union 13 Carbide in that case or somebody else? 14 A. Union Carbide. 15 Q. Do you recall where that case was 16 located? 17 A. I think it was Texas. 1 don't recall 18 Q. Do you recall Ifthat case arose out 19 ofa Georgia-Pacific wallboard plant in Texas? 20 Does that ring a bell at all? 21 A. No bells. 22 Q. Do you recall what work it was that 23 you did in connection with that case? 24 A. I don't recall specifically. Just 25 reviewing a lot of medical records, perhaps 0055 1 Ilgren 2 seeing some path slides. 3 Q. Do you recall ifthat case was a 4 mesothelioma? 5 A. No, sir, I don't recall the details. 6 Q. Do you recall if it was a cancer of 7 the larynx? 8 A. I just don't recall. 9 Q. So basically sitting here today, you 10 don't recall what disease was either involved or 11 alleged to be involved in that case? 12 A. No, sir. 13 Q. Do yon recall seeing any tissue in 14 that case, either slides or actual samples of 15 tissue? 16 . A. No, sir. 17 Q. Do you recall seeing any reports from 18 Dr. Pooley in that case? 19 A. No, sir. 20 Q. Do you recall ifDr. Pooley was 21 involved in that case? 22 A. No, sir. 23 Q. Do you recall asking Dr. Pooley or 24 Dr. Gibbs or anyone else to do any fiber burden 25 analysis in that case? 0056 1 Ilgren 2 A. No, sir. 3 Q. Do you know ifeither Dr. Gibbs or 4 Dr. Pooley did any fiber burden analysis in that 5 case? 6 MR. GERSON: I object to relevance. 7 That case is that case and we are here for 8 this case, so I don't quite see the 9 connection. You can answer, but I want to 10 put that on the record. 11 A. No, sir. 12 Q. Other than yourself, are you aware of UCAREF00009340 28 13 any other consultants who may have been working 14 fbr Union Carbide in that particular case? 13 MR. GERSON: Same objection. 16 A. No, sir. 17 Q. Do yon recall discussing that case 18 with any other consultants who may have been 19 working for Union Carbide? 20 A. No, sir. 21 Q. Do you recall preparing any critiques 22 of the work of anyone else in that case, experts 23 for the plaintiff or other defendants? 24 A. No, sir. 25 Q. Do you know with whom you were working 0057 1 Ilgren 2 on behalfof Union Carbide in that case? 3 A. Yes, sir. 4 Q. Who was that? 5 A. Gary Elliston. 6 Q. Mr. Elliston, is he with Henry 7 Garrard's office? 8 A. No. 9 Q. Where is he from? 10 A. I don't recall. 11 Q. Is he from Texas? 12 A. Yes. 13 Q. Other than that particular case and 14 the present case, have you done any consultation 15 work of any type for Union Carbide in connection 16 with Coalinga asbestos? 17 A. Yes. 18 Q. Can you describe for us what that 19 consulting has been or that work has been? 20 A. Yes. Just an ongoing analysis of 21 literature relevant to the biological, physical 22 and chemical characteristics of Calidria. 23 Q. When did that begin? 24 A. On behalf ofUCC? 25 Q. Right, on behalfof UCC 0058 1 Ilgren 2 A. I don't recall exactly. Four years 3 ago, five years ago. 4 Q. So would it be fair to say that by the 5 time you were first retained or did your first 6 consulting in this case, you had already been 7 doing some consulting with Union Carbide in 8 connection with the Calidria asbestos? 9 A. Yes. 10 Q. By whom were you retained initially to 11 do that consulting? 12 A. Mr. Gerson. 13 Q. I assume that from time to time you 14 have had discussions with Mr. Gerson about what UCAREF00009341 29 15 you're doing, you report to him and that sort of 16 thing? 17 A. Occasionally. 18 Q. Other than Mr. Gerson, is there anyone 19 else to whom you have reported concerning your 20 consulting work for Union Carbide with respect to 21 the Calidria asbestos? 22 A. Not that I recall. 23 Q. Are you on some sort of retainer for 24 that work or do youjust do work as requested and 25 then charge for it or how does that work? 0059 1 Ilgren 2 MR. GERSON: Objection. Go ahead and 3 answer. 4 A. As requested. 5 Q. Going back over the four years or so 6 that you have been doing this consulting work, 7 can you describe for me the type ofprojects or 8 work that you have done in connection with the 9 Calidria asbestos? 10 A. It's not a hyper-defined, mandated 11 project Just an ongoing analysis of the 12 biological, physical, and chemical 13 characteristics of Calidria per existent 14 literature. 15 Q. If I could summarize this in a short 16 capsule, which TU attempt to do, would it be 17 fair to say that about four years ago you were 18 asked by Mr. Gerson to monitor the literature 19 concerning Calidria asbestos and stay on top of 20 it and analyze that literature as it comes out? 21 A. Yes, sir. 22 Q. In connection with doing that, as I 23 understand it, you have actually become involved 24 in at least two specific lawsuits, one is this 25 one and one is that one from Texas? 0060 1 Ilgren 2 A. Yes, sir. 3 Q. Other than those two, can you recall 4 any other specific claims or lawsuits which you 5 have been asked to work on in connection with the 6 Calidria asbestos? 7 A. No, sir. 8 Q. Have you been asked to do any 9 laboratory research in connection with the 10 Calidria asbestos? 11 A. No, sir. 12 Q. Have you done any laboratory research 13 in connection with the Calidria asbestos? 14 A. No. 15 Q. Have you requested anyone else to do 16 any research in a laboratory with respect to the UCAREF00009342 30 17 Calidria asbestos? 18 A. Yes. 19 Q. Who is that? 20 A. Hartwig Muhle. Arthur Morgan. Walter 21 Bastes. DonRimstidt. That's all 1 can recall. 22 Q. Let me just go through those. What 23 did you ask Hartwig Muhle to do? 24 A. To regenerate the Calidria or Coalinga 25 dust cloud in a manner similar to the way he did 0061 1 Ilgren 2 it in 1987. 3 Q. Are you familiar with the paper that 4 he was one of the co-authors on which talked 5 about generating an aerosol dust cloud from, 6 among other things, Calidria asbestos? 7 A. Yes. 8 Q. Are you saying that what you asked him 9 to do was do that again? 10 A. Yes. 11 Q. Why did you make that request? 12 A. I wanted to understand why he had only 13 130 foil out of 6 mg/m3. 14 Q. Are you saying in his paper he got 130 15 per foil? 16 A. Circa, about that 17 Q. In his aerosol dust cloud from a 18 certain mass of Calidria fiber? 19 A. Yes. 20 Q. Basically you were asking him to 21 replicate that, to see ifthose results would be 22 duplicated or not? 23 A. Yes. 24 Q. Did you ask him to use any different 25 technique or the same technique? 0062 1 Ilgren 2 A. Same. 3 Q. Was that done? 4 A. No. 5 Q. Do you have any knowledge or 6 indication that it will be done? 7 A. Yes. 8 Q. Is the work underway? 9 A. Perhaps. 10 Q. Do you know ifit is or not? It A. Probably, but I don't know. 12 Q. Do you expect that work is going to be 13 done? 14 A. Yes. 15 Q. In other words you have gotten the 16 go-ahead or given him the go-ahead to do the work 17 and you expect that he is going to do it? 18 A. Yes. i t i UCAREF00009343 31 19 Q. Do you expect that there will be any 20 written report generated as a result of that 21 work? 22 A. I don't know. 23 Q. Have you asked him to prepare any 24 report as a result of that work? 25 A. No, sir. 0063 1 llgren 2 Q. Where is he doing this work? 3 A. Hanover, Germany. 4 Q. That's at his laboratory? 5 A. Yes. It's not specifically correct to 6 say he is doing it. He may do it. 7 Q. Where would you expect the work to be 8 done? 9 A. Hanover, Germany. 10 Q. Why are you interested, jumping ahead. 11 why are you interested in the aerosol generated 12 by Muhle? 13 A. It failed to produce any pathological 14 lesions in the rats. 15 Q. You are referring to his inhalation 16 studies? 17 A. Yes. 18 Q. From the aerosol generated with a 19 number of materials, including Coatinga asbestos? 20 A. Yes. 21 Q. On that topic, you're again speaking 22 of these inhalation studies he did as published 23 in, I think it was published in '88, is that 24 right? 25 A. I have the galley proof he gave me in 0064 1 llgren 2 '87, so it may have come out in '88. I wouldn't 3 be surprised. 4 Q. I have it here, but I'm trying to move 5 along here. He has published once in the peer 6 review medical literature concerning these 7 inhalation data, has he not? 8 A. Yes. 9 Q. So whenever that turns out to be. 10 that's the one we are talking about, around '87 11 orW 12 A. I believe it's only once. I believe 13 that's the case. Annals of Occupational 14 Hygiene. 15 MR. BROWNSON: Muhle, Pott, etal.. 16 Annals of Occupational Hygiene by the 17 British Occupational Hygiene Society. 18 Q. Is that the one we are talking about? 19 A. Yes. 20 Q. I highlighted here, it says as a U CAR E F00009344 32 21 result of a conference in October '86, and the 22 publication date looks like 1987? 23 A. Yes. 24 Q. You mentioned that you have asked 25 Dr. Muhle to do some work and we have talked 0065 1 llgren 2 about you requesting that he regenerate this 3 aerosol. Have you asked him to do any other 4 work? 5 MR. GERSON: In relation to Calidria? 6 MR. BROWNSON: Right All these 7 questions deal with Coalinga. 8 A. Possibly finalize the lung burden 9 analysis, same study. 10 Q. When you say possibly finalize, have 11 you actually asked him to do something or you 12 might have asked him and you don't remember? 13 A. I think I asked him and then unasked 14 him and then I can't remember whether we decided 15 to go ahead and ask him again. 16 Q. Do you know ifthat work is underway? 17 A. It's not underway. 18 Q. Do you have any expectation that that 19 work would be done in the next year or so? 20 A. I just don't know. 21 Q. What was it that you were considering 22 when you made that request or may have made that 23 request? What was the question that you were 24 asking? 25 A. Potential retention of Calidria 0066 1 llgren 2 chrysotile in the lung, is it retained. 3 Q. Were you asking that he go back and 4 look at tissue from the rats in his 1986 5 inhalation study? 6 A. Yes. 7 Q. Basically you asked him to go look at 8 that same tissue, as opposed to do another 9 inhalation study and take a burden from the new 10 rats? 11 A. Yes. 12 Q. Have you asked him to do anything 13 else? 14 A. Not that I recall. 15 Q- You mentioned you have asked Arthur 16 Morgan to do some work. What work have you asked 17 him to do? 18 A. Differential solubility studies. 19 Q. Of what, Calidria fiber as opposed to 20 something else? 21 A. Yes. 22 Q. What's the something else? UCAREF00009345 33 23 A. Other chrysolite types. 24 Q. Have you asked him to do a 25 differential solubility with respect to specific 0067 1 Ilgren 2 other chrysolites such as like a UICC/A or Bor 3 any chrysotile at his discretion or what? 4 A. He counter-proposed with a series of 5 other types. I don't recall which ones. AA,B, 6 F, UICC/B. 7 Q. This is solubility in what medium? 8 A. I think his system is 25 degrees 9 centigrade, 1 normal HCL. 10 Q. Are you aware ofany work that Arthur 11 Morgan has done to date concerning the solubility 12 of Calidria compared to other types of 13 chrysotile? 14 A. No. 15 Q. So when you spoke earlier about papers 16 or reports you have seen from Arthur Morgan, that 17 was something else, this question of solubility 18 of Calidria as opposed to other chrysolites? 19 A. Yes. 20 Q. Do you know whether that work has been 21 done yet by Dr. Morgan? 22 A. It has not 23 Q. Do you know if it's underway? 24 A. It's not underway. 25 Q. Do you know ifit will be underway in 0068 1 Ilgren 2 the next year or two? 3 A. It may be, yes. 4 Q. Have you asked Dr. Arthur Morgan to do 5 any other work other than that differential 6 solubility? 7 A. Not that I recall. 8 Q. How about Walter Eastes, who is Walter 9 Eastes? 10 A. He is another in vitro Morgan-type. 11 He works in Ohio. 12 Q. I'm not familiar with him. Where is 13 he located in Ohio? 14 A. I can't remember. Grandville 15 someplace. 16 Q. Is he affiliated with some university? 17 A. I would have to go check. He is a 18 colleague ofArthur Morgan's. He has a 19 physiological system rather than an HCL system 20 for looking at differential solubility. 21 Q. Do you know has he done any work to 22 date with respect to Calidria asbestos of which 23 you're aware? 24 A. No, sir. UCAREF00009346 34 25 Q. As far as you know, your request to 0069 1 Ilgren 2 him that he do some work with respect to Calidria 3 would be the first work he has done on that 4 fiber? 5 A. Yes, sir. 6 Q. Do you know has that work been done? 7 A. No. 8 Q. Has it been started? 9 A. No. 10 Q. Do you expect it to be started in the 11 next year or two? 12 A. Hopefully. 13 Q. Has Union Carbide given the go-ahead 14 to do that project? 15 A. No, sir. 16 Q. Is this a project that you have 17 requested that Union Caibide undertake or is this 18 something you're doing independently on your own? 19 A. The former. 20 Q. So the request has been made ofUnion 21 Carbide, you just haven't gotten the go-ahead 22 yet? 23 A. Yes. 24 Q. Is the same true with the solubility, 25 differential solubility study by Arthur Morgan? 0070 1 Ilgren 2 A. Yes. 3 Q. You havemade the request to Union 4 Carbide but have not yet gotten the go-ahead? 5 A. Yes. 6 Q. Ifyou did get the go-ahead, how long 7 do you anticipate it would be before you get 8 results from either of those two studies? 9 A. I really don't know. Hopefully within 10 a year, but I don't know. 11 Q. I suppose that's dependent on many 12 things, such as how busy they are and that sort 13 of thing. I'mjust asking for some ballpark 14 estimate. 15 A. Sure. 16 Q. You mentioned Don Rimstidt. Can you 17 describe who he is? 18 A. I don't know how you would label 19 Rimstidt, a something-ologist. I don't know 20 whether he is specifically a mineralogist or 21 geochemist, but he models the rate of chrysotile 22 dissolution using certain computer software in 23 his so-called shrinking fiber model. 24 Q. Do you know has he done such modeling 25 to date with respect to Calidria chiysotile? 0071 UCAREF00009347 35 1 Ilgren 2 A. No, sir. 3 Q. Are you aware ofsuch modeling he has 4 done with respect to other types of chiysotile 5 fiber? 6 A. Yes. 7 Q. Has that been published work? 8 A. Yes. 9 Q. Is there also unpublished work? 10 A. I assume. 11 Q. Is there any that you have seen? 12 A. No, sir. 13 Q. So what you have seen is his published 14 work concerning modeling ofchiysotile 15 degradation or dissolution? 16 A. Yes. 17 Q. Do you recall ofihand which chiysotile 18 he used? First ofall, was it all Canadian? 19 A. I don't recall whether it was Canadian 20 or Rhodesian. I don't recall 21 Q. That's kind ofa small point, but 22 let's put it this way, do you know if he has 23 done -- when I earlier asked you whether he had 24 done such modeling with respect to Coalinga, I 25 wasn't limiting myself to Union Carbide Coalinga, 0072 1 Ilgren 2 I was limiting myself to the deposit 3 A. Yeah, sure. Yes. 4 Q. So basically ifI can summarize the 5 request you have made of Rimstidt, it's that you 6 would like him to model the dissolution or 7 degradation of Coalinga type chiysotile and 8 compare it with other types that he has modeled? 9 A. Yes, sir. 10 Q. Is that a request that you have made 11 ofUnion Carbide, to do that work? 12 A. Not yet 13 Q. Is that a request that you intend to 14 make? 15 A. Yes, sir. 16 Q. Let me ask you the same question. Do 17 you have any estimate of how long that work would 18 take, ifyou get the go-ahead to do it? 19 A. No, sir. 20 Q. Have we now covered ail of the 21 original topic, laboratory work that you have 22 requested with respect to Coalinga asbestos7 23 Have we now covered it all? 24 A. Off the top of my head, yes. 25 Q. Have you requested any TEM analysis of 0073 1 Ilgren 2 the fiber itself? UCAREF00009348 36 3 A. Possibly surface microtopography and 4 some other detailed analytical things. 5 Q. ByTEM7 6 A. I don't know what the machine is. 7 It's a form ofelectron microscopy. 8 Q. When you say possibly, have you 9 actually made a request for some work or you 10 can't remember ifyou did or not? 11 A. Request from whom? 12 Q. The original question was have you 13 requested any TEM analysis of Calidria fiber, and 14 you said you might have possibly requested some 15 surface topography analysis. 16 A. I discussed some with Professor Frank 17 Apian at Penn State, and obviously Eric Chatfield 18 in Ontario. 19 Q. So you think you may have discussed it 20 with one or both of those? 21 A. Possibly others. I dont recall. 22 Q. Do you have any record of that? 23 A. Not to my knowledge. 24 Q. Has any such work been done? 25 A. No. 0074 1 Ilgren 2 Q. Do you have any anticipation that it 3 will be done? 4 A. Perhaps. 5 Q. Have you gotten any go-ahead? Have 6 you requested of Union Carbide that such work be 7 done? 8 A. No. 9 Q. So you obviously haven't gotten any 10 go-ahead from Union Carbide to do such work. 11 A. Yes. 12 Q. What question in particular are you 13 looking at with respect to surface analysis of 14 Calidria fiber? 15 A. What am I looking for? 16 Q. Right. 17 A. Anything unusual about the surface. 18 Q. Have you requested that any TEM or 19 other microscopic analysis be done on Calidria 20 with respect to size distribution of the fiber, 21 either in an aerosol or in a wet solution or in 22 any other form? 23 A. Yes, sir. 24 Q. Has that work been done? 25 A. No, sir. 0075 1 Ilgren 2 Q. To whom did you make that request? 3 A. Eric Chatfield. 4 Q. Have you asked Union Carbide for UCAREF00009349 37 5 authorization to do that work? 6 A. I think so. 7 Q. Do you know if that's been granted? 8 A. I believe so. 9 Q. Do you know if that work has begun? 10 A. It has not 11 Q. Do you anticipate that it will begin 12 within the next foreseeable future? 13 A. Hopefully. 14 Q. What specifically is that project? Is 15 that size distribution in an aerosol or in lung 16 tissue or in a solution or what? 17 A. All three. 18 Q. All three of those forms? 19 A. Yes, sir. 20 Q. Have you provided any lung tissue to 21 Dr. Chalfield for purposes ofdoing that size 22 distribution? 23 A. No, sir. 24 Q. Do you anticipate that he would use 23 tissue from a Conwed worker or from some other 0076 1 Ilgren 2 source to do that? 3 A. Possibly both. 4 Q. Do you have available to you any lung 5 tissue from any Calidria-exposed workers that can 6 be used for that worker? 7 A. No, sir. 8 Q. So ifthat was to be done, you would 9 have to obtain some tissue, would that be fair to 10 say? 11 A. Yes. 12 Q. How would you go about obtaining that 13 tissue, ifyou wanted to go ahead with that 14 project? 15 A. Call Mr. Gerson. 16 Q. Have we now covered the requests for 17 analytical work that you have made with respect 18 to Calidria asbestos, or can you think of 19 anything else? 20 A. At the moment I can't think of 21 anything else. 22 Q. Let's go back to where we originally 23 started this discussion, and that was with 24 respect to the unpublished reports, papers or 25 analyses you have seen with respect to Calidria 0077 1 Ilgren 2 asbestos. 3 Believe it or not, we started this 4 discussion, we covered the Minnesota Department 5 of Health and Dr. Weiss, and that's where we 6 began, so let's go to the next name, Arthur UCAREF00009350 38 7 Morgan. 8 We have already talked a little bit 9 about Dr. Morgan, but you indicated you have seen 10 some sort of paper or report from him for 11 something other than this dissolution work you 12 have requested him to do. Do you recall what 13 that was? 14 A. Specific to Calidria? 15 Q. Right. 16 A. I don't think I said - was he among 17 the unpublished? 18 Q. Right. 19 A. Take him out He is not unpublished. 20 Q. You have seen unpublished work by 21 Langer. What unpublished work have you seen by 22 Langer? All these questions deal with Calidria 23 asbestos. 24 A. His mineralogy report 25 Q. The mineralogyreport generated in 0078 1 llgren 2 connection with this case? 3 A. Yes. I think that's all. 4 Q. Have you seen any fiber burden 5 analysis oftissue that Langer has generated in 6 any workers exposed to Calidria? 7 A. No, sir. 8 Q. Have you seen any reports or 9 unpublished work by Langer other than his 10 mineralogical analysis in this case? 11 A. No. 12 Q. Next was Kevin Browne. What have you 13 seen from him relating to Calidria? 14 A. You should take him out 15 Q. You told us earlier about discussions 16 you had with Kevin Browne. 17 A. Yes. 18 Q. But are you saying now that you can't 19 recall any specific written reports? 20 A. No, there'would be no reports. 21 Q. Or data from Browne. 22 A. There is someone I forgot, Chwastiak. 23 (Recess taken.) 24 BY MR. BROWNSON: 25 Q. Before we went off the record we had 0079 1 llgren 2 just stricken the name of Kevin Browne from the 3 list ofpeople who have provided you with 4 unpublished reports or papers and you substituted 5 a different name and I didn't catch it. What was 6 that name? 7 A. I wrote it down. It's Chwastiak. 8 Q. I am not familiar with that. Who is UCAREF00009351 39 9 that? What's his first name? 10 A. Steven. 11 Q- Where is he located? 12 A. Presently? 13 Q. What's his current affiliation? 14 A. I don't know. 15 Q. Is he a medical doctor? 16 A. No. 17 Q. What is he? 18 A. I think he is an analytical chemist. 19 Q. What have you seen from Chwastiak? 20 A. Documents. 21 Q. Are these analytical work with respect 22 to Calidria? 23 A. Yes, analytical work. 24 25 0080 1 Q. Is it chemical analysis? A. Some. Ilgren 2 Q. Does it deal with dissolution of 3 Calidria? 4 A. Some. 5 Q. Degradation of Calidria? 6 A. Some. 7 Q. How about differential dissolution or 8 degradation compared to other chrysotiles? 9 A. I think so. 10 Q. What form does this work take? Is it 11 a report or tabular data or what is it? 12 A. I think it's just a UCC report 13 Q. When you say a UCC report, it's a 14 report prepared for UCC? 15 A. I believe so. 16 Q. Is this something that was provided to 17 you by Mr. Gerson or did you get this from 18 Chwastiak? 19 A. Gerson. 20 Q. Do you recall when this report was 21 prepared? 22 A. I think 1963. 23 Q. The Chwastiak report, did you 24 understand Chwastiak to be an employee ofUnion 25 Carbide at the time he generated that report? 0081 1 Ilgren 2 A. Yes. 3 Q. So what you saw was a report circa 4 1963 generated by some sort of analytical chemist 5 named Chwastiak concerning the Calidria fiber, 6 would that be a description of what it is? 7 A. Yes. 8 Q. Was that a single report or was that a 9 series of documents or what was that? 10 A. I don't recall. UCAREF00009352 40 11 Q. The next name you gave me was IITRI. 12 What have you seen by them? 13 A. Analytical studies of Calidria 14 chrysolite. 15 Q. Who is IITRI, what's the name? 16 A. Illinois Institute ofTechnology and 17 Research Institute. 18 Q. So ITTRI is an acronym for Illinois 19 Institute ofTechnology and Research or something 20 along those lines? 21 A. Yes. 22 Q. When was this study prepared? 23 A. 1975 through 1984. 24 Q. Was this a series ofanalyses that 25 were done over that time period? 0082 1 Ilgren 2 A. I believe so. 3 Q. What sort ofanalyses were these? 4 A. Physical and chemical analyses. 5 Q. Offiber? 6 A. Yes. 7 Q. Was it fiber in any particular medium 8 or circumstance or just fiber? 9 A. I think it would be air, water and 10 animal feed. 11 Q. Animal feed? 12 A. Yes. 13 Q. Do you recall the context in which 14 these studies were performed, why they were being 15 done? 16 A. I believe it was at the request of 17 NIESH. 18 Q. Were these provided to you by 19 Mr. Gerson? 20 A. No. 21 Q. Where did you get that from? 22 A. From IITRI. 23 Q. How did you come to find out about 24 them7 25 A. Indirectly through Hartwig Muhle. 0083 1 Ilgren 2 Q. So in your conversations with Hartwig 3 Muhle, he indicated to you that the IITRI group 4 had done some analytical work? 5 A. No. I asked him where he got his 6 sample for inhalation testing from and he said 7 NIESH, and I asked him for a copy of the NIESH 8 report describing the sample used, and in the 9 NIESH report it said that the material had been 10 prepared by IITRI. 11 Q. Did you then go to IITRI and ask what 12 material they had? UCAREF00009353 41 13 A. Yes. 14 Q. What they sent you was this series of 15 analytical work done from 1975 to 19847 16 A. Eventually, yes. 17 Q. What was this, was this microscoiiy or 18 chemical analysis? What are we talking about 19 here7 20 A. Microscopy, chemical analysis, XRD, a 21 great number of different. I can't remember them 22 all. 23 Q. XRD is x-ray diffraction? 24 A. Yes. 25 Q. Did this report take a narrative form 0084 1 Ilgren 2 or was it tabular data or what did it look like? 3 A. Both text and tables, graphs, figures. 4 Q. What you understood this analysis to 5 be, then, was a sample or samples of Coaiinga 6 asbestos that was then used by Muhle for his 7 aerosol generation? 8 A. One of the samples he had used, yes. 9 Q. Have you ever seen any other NIESH or 10 documents or data concerning Coaiinga asbestos? 11 A. I think so. 12 Q. Have you ever seen the NIESH air 13 measurements of dust at the mill in King City, 14 California done in about 1984 or thereabouts? 15 MR. GERSON: Objection to relevance. 16 Go ahead. 17 A. I think so. I don't recall. 18 Q. I didn't catch your answer. 19 A. Yes, I believe so. 20 Q. Do you have a copy of that in your 21 possession? 22 MR. GERSON: With him today or 23 generally? 24 MR. BROWNSON: Not with him today, but 25 in his possession in Btyn Mawr or wherever. 0085 1 Ilgren 2 A. I'm hesitating because I can't 3 remember whether it was done, I think it was done 4 by NIESH, but ifit was and ifI have it, it 5 would be in Bryn Mawr. 6 Q. When you hesitate, let me ask some 7 broader questions. Do you recall seeing air 8 sampling data from the milt at King City, 9 California from some source and you'rejust 10 trying to remember if there was one from NIESH? 11 A. Exactly. 12 Q. Does some NIESH ofabout 1984 ring a 13 bell and you can't pin it down? 14 A. Yes, sir. UCAREF00009354 42 15 Q. Other than that data and this I1TRI 16 data, to the extent that that's NIESH data, I 17 guess it realty isn't, is there other NIESH data 18 you have seen concerning Coalinga fiber? 19 A. Not that I recall. 20 Q. Have you spoken to anyone at NIESH 21 about Coalinga fiber? 22 A. Yes. 23 Q. Who is that? 24 A. I spoke to Dr. Jean Haartz. I spoke 25 to Dr. Charles Loiboreau. I think they are the 0086 1 Ilgren 2 only two. There may be one or two others. 3 Q. Are they both at NIESH in Cincinnati? 4 A. Yes, I believe they are in Cincinnati. 5 Q. Do you know when you spoke to them? 6 Was that recently or when? 7 A. Last year sometime. 8 Q. Was that done in connection with this 9 case or for other purposes? 10 A. Probably both. 11 Q. Did that generate any sort ofwritten 12 correspondence or notes or documents? 13 A. Some small correspondence. 14 Q. That would be correspondence back and 15 forth between you and those two NIESH doctors? 16 A. Yes. 17 Q. Do you still maintain copies ofthat 18 correspondence? 19 A. I don't know. 20 Q. Ifyou did, would they be in your 21 materials at Bryn Mawr? 22 A. Yes. 23 Q.What was the reason for your inquiry 24 to those doctors? What was the question or the 25 topic that you posed to them? 0087 1 Ilgren 2 A. It was my understanding that IITRI 3 prepared samples for NIESH of both Calidria and 4 non-Calidria chrysolite types that would serve as 5 worldwide standards, and I wanted to track down 6 anyone in the world who had ever done any 7 research on Calidria, so I wanted to try to get a 8 listing from them of everyone in the world to 9 whom they had sent samples. 10 I also wanted to try to clarify 11 exactly what kind of Calidria preparation they 12 had been using. 13 Q. First ofall, are those two men 14 medical doctors or are they industrial 15 hygienists, or who are they? 16 A. I think Jean is a woman, but that's UCAREF00009355 43 17 not important 18 Q. Those two individuals? 19 A. Yes, individuals; and I think they are 20 both PhJD.'s. 21 Q. What answer did you get to your 22 inquiry to them about who had standardized 23 samples of Calidria fiber for analysis? 24 A. What answer? 25 Q. What did you learn? First of all, had 0088 1 Hgren 2 they done that? 3 A. Had they done what? 4 Q. Had they prepared some standard 5 preparations of Calidria? 6 A. Yes. 7 Q. Was that done again for NIESH or for 8 who? 9 A. I don't know why they did it I guess 10 that's just what they do. 11 Q. As long as we are on that topic, I 12 have a paper which you have probably seen 13 entitled "Characterization OfThree Types Of 14 Chrysotile Asbestos After Aerosolization" 15 published in Environmental Research in 1983 by 16 Pinkerton, Arnold, Brody and others. 17 Are you familiar with that paper? 18 A. Yes. 19 Q. In that paper it is said that what 20 they were trying to do was prepare some standard 21 preparations of Coalinga fiber and some fiber 22 from the Jeffrey pit in Quebec for use in 23 experimental research by the National Institute 24 of Environmental Health Sciences. 25 A. That's not exactly correct I don't 0089 1 Ilgren 2 think they were preparing standards. I think 3 they werejust characterizing potential 4 standards. It's semantical. 5 Q. I guess it is kind of semantical, but 6 as you understand it, they were trying to 7 characterize samples, some standard samples that 8 had been prepared ofthese two types of fiber? 9 A. I think they are one and the same. 10 Q. I think we are getting into a semantic 11 argument here, but when you were talking about 12 these two Ph.D.'s at NIESH, as you understand it 13 they were doing the same thing, trying to get 14 some standard samples for -- 15 A. I think theyjust served as a 16 respository so that ifone wants to do some 17 Calidria research, research on Calidria fiber, 18 you call them up. I don't know how one becomes UCAREF00009356 44 19 aware that they serve as a respositoiy, but say 20 you want a gram or whatever of material to do a 21 study with, you just call them up and say I would 22 like to do this. 23 I guess by analogy to the UICC 24 standard samples, they probably serve as a 25 respositoiy. They had something like 35 0090 1 Ilgren 2 different types ofchiysotile and halfa dozen 3 types of amosite and other fiber types, so this 4 one was CH-29, this one being the Calidria, but 5 they had I think CH-30 was Arizona and CH-27 was 6 something else, so I don't think there was any 7 type of competition. 8 In fact I think the sort of life cycle 9 chain went something like NIESH requests that 10 HTRI serve as outside contractor to characterize 11 a sample of Calidria fiber. I1TRI contacts Union 12 Carbide, requests a sample. Union Carbide sends 13 HTRI material for analysis, HTRI analyzes the 14 sample. 15 It would then go back to NIESH within 16 the respositoiy, and then NIESH - i.e., 17 Pinkerton, et cetera - may wish to use that, or 18 the 25 other groups through the world who made 19 subsequent requests after the respositoiy was set 20 up. 21 I think that's the way it works. 22 Q. So, for instance, ifyou wanted to do 23 some further characterization of Calidria 24 samples, like let's say this project you were 25 talking about with Muhle, is that where you 0091 1 Ilgren 2 anticipate you would go to get samples, that 3 respositoiy at NIESH in Cincinnati? 4 A. Perhaps. 5 Q. Let me ask a different question. 6 Would samples be available at that 7 respositoiy if you requested them for work of 8 that type? 9 A. I believe so. 10 Q. Let me ask one more name. The next 11 name you gave us was Martin. What Martin is 12 that? 13 A. I don't think that's unpublished, I'm 14 sorry. I was mixing there. I think he is 15 published, so let's take him off the unpublished 16 list. 17 Q. Let's put him on the published list. 18 Which Martin is that and what has he published? 19 A. I think his first name is Colin, but I 20 can't remember. I think it was something like UCAREF00009357 45 21 "Thermographic Aspects Of Chiysotile Asbestos," 22 Mineral Magazine 1977. 23 Q. Do you understand that one of the 24 types ofchiysotile that was included in that 23 thermographic analysis was Coalinga? 0092 1 Ilgren 2 A. Yes. 3 Q. You say that was published in Mineral 4 Magazine in approximately 1977? 3 A. I think so. 6 Q. Who is Colin Martin, is he a 7 mineralogist? 8 A. I think so. 9 Q. Where is he located or was he at the 10 time he published? 11 A. Oxford. 12 Q. How did you come to find out about 13 that publication? 14 A. From the literature. 15 Q. My search of the literature didn't 16 turn that up, using databases I had. I'm just 17 curious what search you made that turned up that 18 reference. 19 (Continued on the following page.) 20 21 22 23 24 25 0093 1 Ilgren 2 A. I can't recall. I don't recall. 3 Q. But in any event it turned up and it 4 was published, as you recall, and not 5 unpublished, is that fair to say? 6 A. That's correct . 7 MR. GERSON: Why don't we take a 8 break. 9 (Luncheon recess taken at 12:40 p.m.) 10 11 12 13 14 15 16 17 IS 19 20 21 22 UCAREF00009358 46 23 24 25 0094 1 Ilgren 2 AFTERNOON SESSION 3 {2:20 p.m.) 4 EDWARD B. ILGREN, 5 resumed, having been previously duty sworn, 6 was examined and testified further as 7 follows: 8 EXAMINATION (Cont'd.) 9 BY MR. BROWNSON: 10 Q. When we broke for lunch we were going 11 through the list of individuals you had named 12 from whom you have unpublished material dealing 13 with Coalinga fiber. 14 The next name we had on the list is 15 that of Jean Haartz. You had earlier told us 16 about a Dr. Haartz at NIESH. Is this the same 17 one? 18 A. Yes. 19 Q. The published reports you spoke of 20 earlier from this Dr. Haartz, are those the same 21 standardized preparation reports from NIESH that 22 you mentioned earlier or is it something else? 23 A. The same. 24 Q. Next was Graf. 25 A. Right. 0095 1 Ilgren 2 Q. Who was that? 3 A. She was the research chemist analyst 4 at IITRI who did a lot of the hands-on research. 5 Q. Would the reports where her name 6 appears be the same ones you mentioned earlier, 7 the IITRI studies? 8 A. Right. 9 Q. Next you mentioned Mumpton, Fred 10 Mumpton? 11 A. Yes. 12 Q. Do you know what papers or reports you 13 have from Fred Mumpton? 14 A. Again, I think I have a Union Carbide 15 report. 16 Q. Do you recall that this was one or a 17 series of reports he did back in the mid-'60s 18 where he was analyzing the ore from the deposit, 19 or is it something other than that? 20 A. It would be that. 21 Q. Where did you obtain the Mumpton 22 reports, do you know? 23 A. Either from Virginia or Alan. 24 Q. I don't mean to quibble over this UCAREF00009359 47 25 because it's a small point, but Mumpton has two 0096 1 Ilgren 2 papers that I didn't bring with me that actually 3 saw the light of day in journals. 4 I think they are the same ones you are 5 talking about, but do you recall them being 6 published anywhere or do they appear to you to be 7 unpublished? 8 A. They appear unpublished. 9 Q. Have you seen any published work by 10 Mumpton? 11 A. Yes. 12 Q. So this is something other than work 13 you have seen published injournals? 14 A. Yes. 15 Q. Again, do you recall how many reports 16 it is? Is it a couple? 17 A. It's at least one. 18 Q. Ifyou can recall, does that report 19 have in it photographs, I guess it wouldn't be an 20 original photograph, but a photo of, actually I 21 guess it would be a photomicrograph under the 22 electron microscope of the Calidria fiber? 23 A. I can't recall. 24 Q. Do you recall seeing such photos that 25 Mumpton took in the '60s, whether in the 0097 1 Ilgren 2 published papers or in those reports? 3 A. I certainly believe there is a TEM 4 shot in the published papers. I don't recall in 5 this unpublished document 6 Q. Do you have any information as to the 7 date or the approximate time frame when Union 8 Carbide had available in its own laboratories a 9 transmission electron microscope? 10 A. When did they first buy a scope? 11 MR. WILL: An electron microscope. 12 A. No idea. 13 Q. The next name you mentioned was 14 Thickstun. Who was that? 15 A. I think Thickstun was one of the 16 geologists that worked cither independently or 17 with Condor between 1950 and 1957 on the New 18 Idria serpentinite. on the body, and he was the 19 one who met Bill Cohan and Ary. Cohan was the 20 chief geologist for UCC and Ary was the vice 21 president at UCC Nuclear up in Reno, and 22 Thickstun was the one in this kind of 23 semi-anecdotal account, entitled something like 24 Hell's Lid, Asbestos As Hell's Lid, a funny 25 title, but he was just a geologist who describes 0098 UCAREF00009360 48 1 Ilgren 2 the deposit 3 Q. Does it appear to be a description 4 based on his own analysis of things, or is it 5 kind of a historical perspective ofthis? 6 A. It's a mixture of historical analysis, 7 some of his own or his colleagues' analyses. It 8 refers to different samples that he had analyzed 9 because some people say it was mountain leather 10 or an amphibole, but then the report came back 11 that it was only chrysotile, so there is a 12 mixture of historical description, personal 13 analysis and allusion to analyses done by the 14 Department ofMineralogy in California early on 15 in the early '50s. 16 Q. Then you also mentioned Bright. Who 17 was that? 18 A. Bright again was another geologist who 19 wrote this document in 1959, and I can't remember 20 if it's a.UCC document or what 21 Q. So at any rate you got it through 22 Mr. Gerson's office, but you don't know ifit was 23 actually prepared by UCC originally? 24 A. That's correct. 25 Q. Do you know who Bright was affiliated 0099 1 Ilgren 2 with at the time he wrote that report? 3 A. I don't recall. 4 Q. Next you mentioned Addison. 5 A. Yes. 6 Q. Which Addison is that? 7 A. John. 8 Q. What do you have from John Addison? 9 A. Just a letter. 10 Q. Is this a letter addressed to you or 11 someone else? 12 A. Tome. 13 Q. What's the topic of the letter? 14 A. Just a small discussion of I think 15 Yeager's '83. 16 Q. Is this a paper by Yeager and Kagan 17 and other authors dealing with dosing human 18 macrophages with Calidria and other fibers? 19 A. Yes. 20 Q. Would it be fair to say that what you 21 have is a letter from John Addison written to you 22 commenting on that paper by Yeager? 23 A. Yes. 24 Q. What occasioned Dr. Addison to write 25 you about the paper? Had you sought a critique 0100 1 Ilgren 2 from him or did he send this out unsolicited or UCAREF00009361 49 3 how did that come into your possession? 4 A. I asked him to critique a certain part 5 of the minerological statement, if I recall, the 6 fiber analysis aspect. 7 Q. Do you recall what you asked him to 8 critique specifically? 9 A. Not at the moment 10 Q. Do you recall what his critique said. 11 what the letter says? 12 A. I have reviewed a lot I would have 13 to have it before me. 14 Q. Next you said Hodgson? 15 A. Yes. 16 Q. What Hodgson is that? 17 A. That's Alan A. Hodgson. 18 Q. What do you have from Hodgson? 19 A. He wrote a small report on sort of his 20 thoughts on Calidria fiber. 21 Q. When you say a small report, is it in 22 the form ofa letter? 23 A. Yes, a letter. 24 Q. It's a letter addressed to whom? 25 A. I think it's to me or for me. 0101 Ilgren Q. Is it a letter in any event that you asked be written by Dr. Hodgson? A. I think hejust said he would put some thoughts down. Q. Was this in response to an inquiry from you? A. We had just been discussing Calidria fiber, what might be peculiar about it Q. You said could you please put some of your thoughts down and he followed that up with writing a letter where he put some of his thoughts down? MR. WILL: Objection. I think he previously testified it was Alan Hodgson would put some thoughts down. MR. BROWNSON: I don't follow you there. MR. WILL: You suggested that Mr. Ilgren had proposed that this be reduced to writing. The earlier answer was that Dr. Hodgson had suggested that THE WITNESS: That's correct Q. So let's see if I can get the sequence straight. At some point you and Dr. Hodgson were UCAREF00009362 50 5 after you were first hired by Union Carbide to 6 look into aspects of Caiidria or before that 7 time? 8 A. Probably before. We might have first 9 talked in '87, '88, a long time ago. 10 Q. How was it, as best you can recall, 11 that the subject of Caiidria fiber came up at 12 that conversation? 13 A. In the context of slip fiber. 14 Q. Did this conversation arise in the 15 context where you had some sort ofscientific 16 meeting or assembly or what? 17 A. 1 was asked by Celotex to research the 18 potential biological effects of slip versus cross 19 fiber in '86. 20 Q. Was that in connection with fiber from 21 Carey Canada, the Celotex subsidiary? 22 A. Yes. 23 Q. I assume that Carey was mining some 24 slip fiber in Canada? 25 A. It is slip fiber. 0103 1 Ilgren 2 Q. Do you know what mine or pit that was 3 coming out of? 4 A. Pennington Dike, East Broughton. 5 Q. So ifwe can finish the topic of the 6 Hodgson discussion, you were doing some 7 investigation for Celotex in connection with the 8 Carey Canada slip fiber in about '877 9 A. Yes. 10 Q. Do you know who requested you to do 11 that investigation? 12 A. I think the request came from some 13 senior person at Celotex. 14 Q. Do you know if it came from one of the 15 lawyers at the Montgomery McCracken firm in 16 Philadelphia? 17 A. It came through Phil Vogler, I think. 18 Q. As you can recall, and I know it's 19 going back seven years, was that in connection 20 with some of the asbestos building litigation 21 that Phil was working on for Celotex at that 22 time? 23 A. No, I don't think it was specific to 24 any building litigation. It was a general 25 inquiry because their deposit was largely slip. 0104 1 Ilgren 2 Q. In any event, in conducting that 3 investigation did you contact Dr. Hodgson? 4 A. Yes. 5 Q. The two of you then met? 6 A. Yes. UCAREF00009363 51 7 Q. He then followed up the meeting with a 8 letter to you? 9 A. This is years ago. I mean we have 10 been friends and colleagues for a long time. 11 Over the last six or seven months or in fact the 12 last couple ofyears I have been talking to him 13 olfand on about Calidria fiber. 14 Q. This particular letter that you 15 mentioned that got this discussion going, I 16 understood that letter was dated at or around 17 1987. 18 A. No, that letter would be quite recent, 19 a few months ago. 20 Q. The next name you gave me was Jordan. 21 A. Yes. 22 Q. What Jordan is that? 23 A. I think he is either an analytical 24 chemist or an engineer, a UCC employee. 25 Q. What report or documents do you have 0105 1 Ilgren 2 from him? 3 A. Commercial properties of Calidria 4 fiber. 5 Q. There were a series of papers put out 6 by UCC people, including Jordan, dealing with the 7 properties of Calidria fiber in three basic 8 industries. One was paper-making, one was 9 plastics and one, I believe, could have been 10 floor tile, but I know one was drilling mud for 11 the oil drilling industry. 12 Do you recall in which context this 13 paper appeared? 14 A. I haven't the details of the papers. 15 I don't recall drilling mud. I don't recall any 16 specific. I think these were more theoretical 17 papers. 18 Q. Let me narrow it down. 19 Do you recall the Jordan paper as 20 dealing with the commercial properties of 21 Calidria asbestos for use in paper-making? 22 A. I believe so. It's more of a guess. 23 MR. WILL: Don't guess. 24 Q. Do you recall the date ofthat paper? 25 A. Mid-'60s. 0106 1 Ilgren 2 Q. The next name is Park. Who is that? 3 A. I think his name is Kisoon Park, 4 another UCC scientist working on Calidria fiber 5 for quite some time. 6 Q. This was another of this series of 7 Union Carbide papers dealing with Calidria fibcr7 8 A. Yes. UCAREF00009364 52 9 Q. Then you mentioned Woolery, Robert 10 Woolery? 11 A. Yes. 12 Q. - What do you have from him? 13 A. Again other papers describing 14 commercial applications. 15 Q. Morgan in particular wrote a paper or 16 authored a paper called "The Use of Coalinga in 17 the Paper-Making Process." Do you have a copy of 18 that? 19 A. Yes. 20 Q. Are there others that you can recall 21 other than that? 22 A. Not by detailed title, but I do recall 23 others. 24 Q. Would it be fair to say that you have 25 more than one Woolery paper but you don't know 0107 1 Hgren 2 how many? 3 A. Unpublished or published? 4 Q. Unpublished. 5 A. I think I have more than one. 6 Q. Do you have any published material by 7 Woolery? 8 A. Yes. 9 Q. Do you recall what the published 10 papers are that you have? 11 A. I think one is the TAPPI paper. I 12 think that's Technical Applications of the Paper 13 and Pulp Institute, whatever. The otherjournals 14 don't immediately spring to mind. 15 Q. Next you mentioned Dresher. 16 A. Yes. 17 Q. What is that? What do you have? 18 A. Who is he? 19 Q. Okay, who is Dresher? 20 A. Dresher again was an analytical 21 chemist who worked for UCC. 22 Q. Do you have a paper that he authored? 23 A. Yes. 24 Q. Is there more than one orjust one? 25 A. I believe there is more than one. 0108 1 Ilgren 2 Q. Do you recall ifany of those papers 3 deal with the properties or the use of Coalinga 4 fiber in the paper-making process? 5 A. I believe so, but I'm not sure. 6 Q. Then the final name you gave us is 7 Nauman. 8 A. Yes. 9 Q. What do you have from Nauman? 10 A. He worked with Dresher. Again I have UCAREF00009365 53 some unpublished papers. Q. Let me turn to a different topic. That's your CV. Let's mark a copy of a CV which Mr. Will provided to me about a month ago, recently. (Ilgren Exhibit 1, Ilgren CV, marked for identification, as of this date.) (Ilgren Exhibit 2, Ilgren CV, marked for identification, as of this date.) (Ilgren Exhibit 3, Ilgren CV, marked for identification, as of this date.) Q. Let's look at Exhibit 1. We have marked as Exhibit 1 a curriculum vitae that has a date stamp ofMay 3, 1994 on it, which is an undated CV. Ilgren Is this an up-to-date CV7 A. It looks fairly up to date. Q. This date stamp on the front, I assume that's a date stamp, it's not one from my office but maybe from Mr. Will's office? MR. WILL: No, it's not from my office. Q. Do you know where that came from? A. No. Q. Would it be fair to say that this is up to date at least as ofMay 5,1994? A. Yes. Q. Is there anything since that time that we should add to this or change? A. I would have to go through it in detail Not off the top of my head, no. Q. I would like to go through a few things on the CV in Exhibit 1. First of all, is this a CV that you prepared yourself? A. Yes. Q. It indicates that you have an M.A. from Oxford? A. Yes. Ilgren Q. An M.D. from where? A. Hahnemann. Q. Then it says D.Phil. from Oxford? A. Yes. Q. Then MACPath.7 A. American Board ofPathology. Q. And the last reference is MRCPath.? A. Royal College, sort of the English equivalent to boards in neuropathology. Q. What does MRCPath. stand for? A. Member of the Royal College of UCAREF00009366 54 13 Pathology. 14 Q. On the second page of the CV there is 15 the heading "Education." 16 The first category is "Institute and 17 Location," and then it says in the second column 18 "Degree and Field of Study," and third is "Year 19 Confirmed." Do you see that? 20 A. Yes. 21 Q. That indicates you got an M.D.from 22 Hahnemann in 1974, is that correct? 23 A. Right. 24 Q. Then the secondthing on there is 25 American College of Pathology. 0111 1 Ilgren . 2 A. That would be Board certification. 3 Q. Then ifyou look at degree and field 4 of study under that one, it says MACPath. Does 5 that stand for Member, American College of 6 Pathology? 7 A. In England, this CV was written 8 largely for English people, so they don't have 9 boards of some specialty. They have colleges of 10 specialties. Instead of getting the boards, you 11 get a membership, so I was trying to Anglicize 12 this for people to understand in Europe and in 13 England rather than America. 14 Q. So what this reference refers to is 15 that you're Board-certified in pathology in the 16 United States? 17 A. Yes. 18 Q. It doesn't refer to the fact that 19 you're a member of the American College of 20 Pathologists? 21 A. Yes, that's true. 22 Q. Was my statement correct, you're not a 23 member of the American College of Pathologists? 24 A. I guess it's a diplomate of the 25 American Board ofPathology. 0112 1 Ilgren 2 Q. I'm not Hying to make a big 3 distinction here, but in this country in the 4 United States you can be Board-certified in 5 pathology, which is something that comes from, 6 actually I guess it's down in Tampa or someplace, 7 the Board certificatioa 8 A. Chicago. 9 Q. But then there also is an American 10 College ofPathologists? 11 A. Really? 12 Q. I guess what I'm getting is what this 13 indicates is you're Board-certified? 14 A. Correct. UCAREF00009367 55 15 Q. It's not an indication that you're a 16 member of the American College of Pathologists? 17 A. I didn't even know there was a College IS of Pathologists. 19 Q. It indicates here that the Institute 20 is the American College of Pathology. 21 A. I should correct that The American 22 boards. 23 Q. The next is University of Oxford, 24 D.Phil. from Oxford University in England? 25 A. Yes. 0113 1 Ilgren 2 Q. 1980? 3 A. Yes. 4 Q. That was in the field of 5 zoology/biology? 6 A. Yes. 7 Q. I'm going tojump ahead, but the last 8 entry, University of Oxford M.A.? 9 A. Yes. 10 Q. In biology and medicine, 1983? 11 A. Yes. 12 Q. My question is how come you got the 13 D.Phil., which I shouldn't call a Ph.D., before 14 the M.A.? 15 A. It's an M.A. that's conferred, it's 16 not a thesis M.A. where you write a treatise or 17 something. It's a degree which they give you as 18 a senior member of the university so that you can 19 vote in university matters so you can be a thesis 20 adviser. It's not equivalent to going to 21 Columbia to do a master's in art history or 22 something. 23 Q. So would it be fair to say that that 24 is a degree from Oxford in 1983 that was not as a 25 result ofa specific dissertation or course of 0114 1 Ilgren 2 study that you took? 3 A. Yes. 4 Q. It was like a conferred degree of some 5 sort? 6 A. Yes. 7 Q. Then the next entry on there is Royal 8 College of Pathology. 9 A. Yes. 10 Q. 1982? 11 A. Yes. 12 Q. It says under degree and field of 13 study, MRCPath. neuropathology. What does that 14 stand for? 15 A. That's the Royal College of 16 Pathologists membership, which again you sit down UCAREF00009368 56 17 and take your exam and look at slides. It's the 18 same as the American boards of neuropathology. 19 Q. That was obtained in 19827 20 A. Yes. 21 Q. It indicates degree. That's not 22 actually a degree, is it? Isn't that, it's 23 similar to American Board-certification in 24 pathology? 25 A. My understanding in England is that's 0115 1 Ilgren 2 a degree. In this country it wouldn't be a 3 degree. I guess it's definitional, sort of. 4 Q. Did you earn any degrees since 1983? 5 A. No. 6 Q. Would it be fair to say that the last 7 earned degree would be the D.Phil. you got from 8 Oxford in 1980? 9 A. By American standards. 10 Q. Up until that time, had you treated 11patients with any asbestos-related disease? 12 A. Say that again. 13 Q. Up until 1980, had you treated 14 patients with asbestos-related disease? 15 A. Treatment in the broadest sense of 16 having looked at any slides from asbestos-related 17 disease cases or whatever? 18 Q. Let's back up. I understand that you 19 received your medical degree in 1984 and the 20 degree was - 21 A. 1974. 22 Q. At that time, that was what's known as 23 an M.D., a medical degree, correct? 24 A. Yes. 25 Q. Was it in any particular specialty at 0116 1 Ilgren 2 that time? 3 A. You don't specialize in that 4 Q. Let's start there. My point is as of 5 the time that you got out ofHahnemann, received 6 your degree in 74 ofM.D., up until that time in 7 your medical school training had you ever 8 actually treated patients with any 9 asbestos-related disease? 10 A. Had I ever seen anybody with an 11 asbestos-related disease in medical school? 12 Q. Right. 13 A. Probably, but I don't recall. 14 Q. Then after 1974 and until 1980 you 15 were involved in various residencies or programs 16 of one sort or another in this country and in 17 England and you got this D.Phil. degree in 18 zoology and botany in 1980, would that be a UCAREF00009369 57 19 thumbnail summary for that time period? 20 A. Yes. 21 Q. Would it be fair to say that what you 22 were studying during that time period was 23 neuropathology or not? 24 A. 1974 to UO, not at alL 25 Q. So up until 1980 you were not involved 0117 1 Ugren 2 in the field of neuropathology? 3 A. No, except for maybe two months of my 4 residency. 5 Q. At what point in the residency and 6 where were you involved in neuropathology? 7 A. I did my residency at Cornell here in 8 the city and as part ofthe anatomic pathology 9 residency you do two months of neuropathology, 10 two months of pediatric pathology, ten months of 11 surgical pathology, eight months of autopsy 12 pathology. I can't remember. A month or two of 13 psychological pathology. 14 Q. This resume indicates that you are a 15 member of the faculty ofbiological and 16 agricultural sciences at University of Oxford? 17 A. That's correct 18 Q. Is that true today? 19 A. Yes. 20 Q. But you don't live in England at the 21 present time? 22 A. No. 23 Q. Where do you currently reside? 24 A. Bryn Mawr, Pennsylvania. 25 Q. Is that your office location? 0118 1 Ilgren 2 A. Office and home. 3 Q. What's your office address? 4 A. Department 503,830 Montgomery Avenue, 5 Bryn Mawr, Pennsylvania. 6 Q. How long have you had your office at 7 that address at Bryn Mawr? 8 A. About two years now. 9 Q. Do you still maintain an office in 10 Oxford? 11 A. No. 12 Q. How is it, I'm not up to date on the 13 English system, but how is it you're still on the 14 faculty at Oxford when you haven't lived there 15 for two years? 16 A. It's a more liberal system. I mean 17 it's not an appointment where I have to do a set 18 number of teaching hours or administration or 19 anything of that sort. It's more a question of 20 just continuing on with research and writing. I UCAREF00009370 58 21 had planned to go back next year. I suppose 22 there was a question of going back, so it makes 23 sense. 24 Q. Is there a certain time period that 25 you can be away from the University ofOxford and 0119 1 Ilgren 2 still be on the faculty? 3 A. I would imagine five or six years. 4 Q. In other words they haven't said to 3 you get bade here by next year or we are going to 6 kick you off the faculty? 7 A. No. 8 Q. The faculty that you're on, as I 9 understand it, is the biological and agricultural 10 sciences? 11 A. Yes. 12 Q. Is that a particular school or college 13 at Oxford? 14 A. I guess you could compare it to the 15 school of dentistry or the school of medidne or 16 the school ofbiology or whatever. 17 Q. Is there any separate and distinct 18 school of medicine at Oxford? 19 A. Yes. 20 Q. So this faculty, then, is not in the 21 school of medidne? 22 A. No. 23 Q. It's in a different school? 24 A. Yes. 25 Q. Is St. Edmund Hall a specific school 0120 1 Ilgren 2 at Oxford? 3 A. That's one of the 38 colleges at the 4 university. 5 Q. Is the faculty ofbiological and 6 agricultural sciences only within St Edmund Hall 7 or does it cross within several of those 8 colleges? 9 A. It crosses within all colleges. 10 Q. So see if I have this straight 11 You're a member of St Edmund Hall? 12 A. Correct 13 Q. What specifically docs it mean when 14 they say you are a member of one of the colleges 15 at Oxford? 16 A. You have to be a member ofa college 17 to be a member of the university. That'sjust I 18 suppose, a formality. It's your college. They 19 are separate. The college system to some extent 20 is separate from the faculty. 21 Q. So when you say it's your college, 22 that's the college where you received your UCAREF00009371 59 23 degree, for example? 24 A. Yes. 25 Q. Was St. Edmund Hall? 0121 1 Ilgren 2 A. Yes. 3 Q. In describing your current faculty 4 position, would it be fair to say you're on the 5 faculty of St Edmund Hall? 6 A. No. 7 Q. You're on the faculty ofbiological 8 and agricultural sciences? 9 A. Yes. 10 Q. And you're affiliated, then, with the 11 college of St Edmund Hall? 12 A. Yes. 13 Q. Do you have a term or is there a word 14 or description that they use to describe that 15 affiliation with St Edmund Hall? 16 A. Just a research fellow or research 17 scientist 18 Q. Do you have any laboratory or research 19 facilities at St Edmund Hall College? 20 A. No. 21 Q. Do they pay you any sort offaculty 22 salary there? 23 A. No. 24 Q. So when they say you're a research 25 fellow or research scientist that's a voluntary 0122 1 Ilgren 2 position? 3 A. More or less, yes. 4 Q. Do you have to pay anything like 5 tuition to maintain that position? 6 A. No. 7 Q. You'rejust there. They don't pay 8 you, you don't pay them, you just hold that 9 position? 10 A. Yes. 11 Q. Are you required to do any certain 12 work to maintain that position at St. Edmund 13 Half? 14 A. No. 15 Q. Do you do any teaching at the college 16 of St Edmund Hall? 17 A. Not at the moment. 18 Q. When is the last time you did any 19 teaching at that college. St. Edmund Hall? 20 A. University teaching between 1980 and 21 1985 was the last time I did formal teaching. 22 Q. At St. Edmund Hall or anywhere at 23 Oxford? 24 A. It would be at the University Medical UCAREF00009372 60 25 School. 0123 1 Ilgren 2 Q. Oxford University MedicalSchool? 3 A. Yes. 4 Q. Are you required (o do any research to 5 be on the faculty of St Edmund Hall? 6 A. No. 7 Q. How about to be on the faculty of 8 biological and agricultural sciences? 9 A. That's the principal duty, just to do 10 your research. 11 Q. Here you hear the term or phrase 12 "publish or perish" in American colleges. Is 13 there such a concept at Oxford, where you are 14 required to do so much publication? 15 A. Obviously they like you to keep 16 publishing. I would say that's important 17 Q. So is there any particular requirement 18 or is it kind of an unspoken rule? 19 A. I suppose it's unspoken. 20 Q. You say you're supposed to continue to 21 do your research. What research are you 22 currently doing as a member of the faculty of 23 biological and agricultural sciences? 24 A. I look into fiber type differences for 25 different forms of asbestos, different forms of 0124 1 Ilgren 2 zeolite. The research is indicated in the CV, 3 page - the research experience is outlined on 4 page 6,7 and 8 and the sorts of things I have 5 been doing lately are outlined at the end of 6 page 8-1. 7 MR. BROWNSON: Let's mark this as 8 Exhibit 4. 9 (Ilgren Exhibit 4, letter dated 25 10 April 1994, Moss to "Dear Sir or Madam," 11 marked for identification, as of this date.) 12 Q. We have marked as Exhibit 4 a letter 13 that I received or actually I had my paralegal 14 receive because Fm unfamiliar with the system at 15 Oxford. I made an inquiry as to your faculty 16 position and I received this letter of April 25, 17 1994 firom P.W. Moss. 18 Do you know who that is? 19 A. I have no idea. 20 Q. It indicates he is the head clerk. Do 21 you know what that position is? 22 A. I guess it's one of those antiquated 23 titles that they have in the administration. 24 Q. Here it says Dr. Ilgren, paraphrasing, 25 was a member of the university staff from 1984 to 0125 UCAREF00009373 61 1 Ilgren 2 1987 when he left. 3 Do you know why it is (hat the head 4 clerk at Oxford would indicate that you left in 5 19877 6 MR. GGRSON: Left what? 7 MR. BROWNSON: Oxford. 8 MR. WILL: It doesn't say that in the 9 letter. 10 MR. GERSON: Why he left the 11 university staff specifically? 12 MR. BROWNSON: Right. It says he was 13 a member of the university staff from 1984 14 to 1987, when he left. 15 Q. Did you leave the university staffat 16 Oxford in 19877 17 A. It's news to me. 18 Q. Then he says "I do not have a 19 forwarding address." 20 Is it your testimony that at all times 21 since 1987 you have had an address of some sort 22 at Oxford? 23 A. Well, I have gotten mail from 24 St. Edmund Hall, so 1 assume, and I have sent 25 letters to SL Edmund Hall. 0126 1 Ilgren 2 Q. Have you actually had an office at 3 Oxford since 1987 at any time? 4 A. I was working with the Imperial Cancer 5 Research Fund and I assume that was my base until 6 at least 1989. I would have to go and check the 7 dates. 8 Q. Is the Imperial Cancer Research Fund a 9 school or college of Oxford or is that something 10 else? 11 A. It's in the Nuffield Department of 12 Clinical Medicine. It was under Richard Peto. 13 Q. So it's your testimony that since 1987 14 you have had an office address at the Imperial 15 Cancer Research Fund in that department at 16 Oxford? 17 A. Up until I would say 1989. Again, I 18 would have to check the dates. 19 Q. Then he goes on to say "He was a 20 member of St. Edmund Hall within the University. 21 I suggest you contact the College Office for 22 possible farther information." 23 I read this to mean that as of 24 April 24, 1994 you were no longer a member of 25 St. Edmund Hall, is that a fair statement? 0127 1 Ilgren 2 MR. WILL: Are you asking him is that UCAREF00009374 62 3 what he thinks Moss is saying or are you 4 asking him whether it's a fact that he was 5 no longer a member of the university staif 6 as of'877 7 Q. I will rephrase the question. As of 8 April 23, 1994, were you a member of St. Edmund 9 Hall within the university? 10 A. I believe so, but as I say, I didn't 11 know any dilferently. 12 Q. When you say you believe so, did you 13 actually have a physical office with a desk and 14 chair and that sort of thing? 15 A. No. 16 Q. Did you have like a post office box or 17 what would it be? 18 A. Just a member of the college. If 19 you're not living there, you don't keep a post 20 box or mailbox. 21 Q. So is it your testimony that you were 22 a member of the College ofSt Edmund Hall as of 23 April 25, 1994 but you weren't physically present 24 there? 25 A. Yes. 0128 1 Ilgren 2 Q. You were in Bryn Mawr, Pennsylvania? 3 A. Yes. 4 Q. T really don't understand this Oxford 5 system, but is it fair to say or is it your 6 testimony that you are currently a member of the 7 staff at St. Edmund Hall? 8 A. The college staff, again accepting 9 that this is a different system, but the college 10 staff I would interpret as ten or twelve 11 so-called fellows or dons that would have the 12 principal teaching responsibilities at the 13 college. They would give tutorials or lectures. 14 So I would not be college staff. 15 Q. So you're not one of those people who 16 teach on the staffof the college. 17 A. No. 18 Q. You never have been? 19 A. No. 20 Q. Do you currently do any teaching in 21 the medical school at Oxford? 22 A. No. 23 Q. Have you ever done teaching in the 24 medical school at Oxford? 25 A. Yes. 0129 1 Ilgren 2 Q. When was the last time you did that 3 teaching? 4 A. I think I said the teaching was done UCAREF00009375 63 5 between 1980 and '85. 6 Q. Since that time have you presented any 7 lectures in the medical school at Oxford? 8 A. No. 9 Q. In your current position you testified 10 you're on the faculty ofbiological science. I 11 have seen that expressed both as biological 12 science and biological and agricultural science. 13 Do you know which one it actually is? 14 A. Perhaps they dropped. It used to be 15 BAS. I think now it'sjust biological science. 16 Q. In that capacity are you actually a 17 fellow or a don, as you have described it? 18 A. No. 19 Q. Do you have an actual title in terms 20 of what you are? Do they call you something? 21 A. No. 22 Q. You just say you're on the faculty? 23 A. Yes. 24 Q. Are you a senior lecturer? 25 A. No. 0130 1 Ilgren 2 Q. Have you ever been a senior lecturer? 3 A. 1 was a senior registrar who gave 4 lectures, but the title ofsenior lecturer is a 5 very specific title. 6 There were times when people might 7 refer to me as a senior lecturer, but the 8 neuropathology position was senior registrar. I 9 gave lectures and sometimes one could be termed a 10 senior lecturer. 11 Q. There actually is a title there called 12 senior lecturer, correct? 13 A. I believe so. 14 Q. My question is. I guess it's a simple 15 question, have you actually held that faculty 16 title of senior lecturer? 17 A. I don't believe so. 18 (Ilgren Exhibit 5, excerpt from 19 Official ABMS Directory of Board-Certified 20 Medical Specialists 1994, marked for 21 identification, as of this date.) 22 Q. I show you Exhibit 5. This is a 23 photocopy ofa title page and a reference from 24 the Official ABHS Directory ofBoard-Certified 25 Medical Specialists 1994. 0131 1 Ilgren 2 Are you familiar with that particular 3 work or that reference guide? 4 A. Not really. 5 Q. This is a reference to American 6 Board-certified specialists. Have you ever seen UCAREF00009376 64 7 that before that you can recall? 8 A. Something similar, probably. 9 Q. What I have attached is the page where 10 your reference appears in the 1994 edition, which 11 is the 26th edition. 12 It states that current hospital 13 appointment is Radcliffe Inlirmary at Oxford, 14 United Kingdom. Was that true in 1994? 15 A. No. 16 Q. Then it says senior lecturer, 17 University of Oxford. Was that true in 1994? 18 A. No. 19 Q. Then under that there is some 20 designations. The first one is BSN. Do you know 21 what that stands for? 22 A. I think it's British Society of 23 Neuroscientists. 24 Q. Is that a society that you're a member 25 of, was or are? 0132 1 Ilgren 2 A. British Society of Neuropathologists, 3 yes, I was a member of that. 4 MR.GERSON: Let's take a two-minute 5 break. 6 (Recess taken.) 7 BY MR. BROWNSON: 8 Q. We were looking at Exhibit 5. Again 9 looking at this entry, and I'm trying to 10 interpret what this means, the first entry there 11 is Certificate Path. AP '77. Do you know what 12 that refers to? 13 A. That's Board certification in 14 pathology, 1977. 15 Q. As I look at Exhibit 1, which is the 16 CV, it indicates you were Board-certified in 17 1976. Do you know which one is correct? 18 A. I would have to go back and check. It 19 was the end of 76 or '77. 20 Q. So sitting here today, you don't know 21 ifyou received your Board certification in 22 pathology in 1976 or 1977? 23 A. It might be'77. 1 would have to go 24 back and check. 25 Q. But you don't know which one it is 0133 1 Ilgren 2 without checking? 3 A. No, I'll check. 4 (ilgren Exhibit 6. fax, St. Edmund 5 Hall to Waskosky, marked for identification, 6 as of this date.) 7 Q. I show you Exhibit 6, a letter 8 addressed to Renee Waskosky, my paralegal, from UCAREF00009377 65 9 Mr. Gosling, principal, St. Edmund Hall, Oxford. 10 A. I just got a letter from him 11 yesterday. 12 Q. As you can see, this was in response 13 to a followup from the previous exhibit where it 14 said inquire of St. Edmund's Hail. 15 Gosling writes -- first ofall can you 16 read what he wrote? Have you read it? 17 A. Yes. 18 Q. Is that all correct, what he says 19 there? 20 A. It's correct I thought it was that I 21 am a member, but it looks like the membership 22 lapsed. 23 Q. So ifGosling claims that as of 24 April 28,1994 you are not a member of the 25 faculty ofbiological sciences, would that be 0134 1 Ilgren 2 news to you? 3 A. Yes. I believe so. 4 (Ilgren Exhibit 7, letter dated 8 5 April 1994, Roberts to Waskosky, marked for 6 identification, as of this date.) 7 Q. Would you look at Exhibit 7. This is 8 a faxed letter of April 25,1994 to my paralegal, 9 Renee Waskosky, from Professor Roberts, 10 Registrar, Royal College ofPathologists in 11 London, Patron, Her Majesty, the Queen. 12 Specifically I want to draw your 13 attention to the second paragraph where it 14 indicates that you're an associate member of the 15 Royal College of Pathologists. Is that a correct 16 statement? 17 A. Right, that's what it says here on the 18 front of the CV. 19 Q. Then it says you gained exemption in 20 October 1981 from the first part of the 21 membership examination, the primary, is that 22 correct? 23 A. Yes. 24 Q. It says the exemption was granted on 25 the basis ofyour publications in the 0135 1 Ilgren 2 pathological field. 3 A. Yes. 4 Q. Do you know what those publications 5 were that allowed you to get the exemption from 6 the primary examination? 7 A. The first 25 or 30 papers that 1 8 wrote. 9 Q. So would it be fair to say it would be 10 those papers which would show up on your CV as UCAREF00009378 66 11 published papers as of 1981? 12 A. It would have to be. 13 Q. I'm looking at the list of 14 publications on your CV which is Exhibit 1, and 15 that appears at page 12. I see that before 16 October of '81, and the dates aren't entirely 17 clear, there could be or there are, it appears, 18 nine papers, references 1 through 9, is that 19 correct? 20 A. Yes. 21 Q. Do any of those papers deal with the 22 issue ofasbestos or, deal with any issues 23 pertaining to asbestos? 24 A. No. 25 Q. Going back to Exhibit 7, which is the 0136 1 Ilgren 2 letter from Professor C. Roberts, do you know who 3 that is? 4 A. No. 5 Q. It says "The status of Associate is 6 entirely optional on the part ofthe applicant 7 It does not permit entitlement to designated 8 initials such as ARCPath. but does allow the 9 holder to receive the quarterly mailings ofthe 10 College." 11 A. I think that should be MRCPath. 12 Q. Do you agree with that statement? 13 A. Again, that's news to me, but I would 14 be happy to drop it 15 Q. I notice that that designation does 16 appear on the cover page ofyour CV, correct? 17 A. Right, as associate in neuropathology. 18 Q. So would it be your testimony that at 19 various times since October of 1981 you have used 20 the designated initials MRCPath. on various CVs 21 and designations and publications? 22 A. Sure. 23 (Ilgren Exhibit 8. excerpt from 24 Directory of Royal College of Pathologists, 25 marked for identification, as of this date.) 0137 1 Ilgren 2 Q. We have marked as Exhibit 8 a 3 photocopy I have taken of the cover and an entry 4 from the Royal College ofPathologists Directory 5 of 1993. It lists your entry as Dr. E.B. Ilgren 6 and then it lists last known address at care of 7 Harvard Club, New York City, New York, New York. 8 Would it be fair to say that as of 9 that date you had no address at Oxford, at least 10 with the Royal College of Pathologists? 11 A. Yes, I imagine. I don't know how the 12 Harvard Club of New York got here. UCAREF00009379 67 13 Q. Do you know how come they wouldn't 14 have been at your office in Bryn Mawr? 15 A. They just sent me a bill last week for 16 annual membership, so I'm not quite sure why 17 not. I'll be sure to tell them. 18 MR. WILL: The billing office has the 19 right address. 20 Q. Did you ever during the time period 21 1993 or before reside at the Harvard Club of New 22 York City? 23 A. Yes. 24 Q. When was that? 25 A. I must have been there for two and a 0138 1 Ilgren 2 half, three months in 1991 sometime. 3 Q. Were you actively engaged in any 4 research projects while you were living at the 5 Harvard Club of New York? 6 A. I was doing research with or for 7 W.R. Grace. Actually physically having a lab in 8 the club, are you asking? 9 Q. Let me put the question this way. At 10 the time you were residing at the Harvard Club of 11 New York, my question is what, ifany, research 12 were you engaged in during that time period? 13 A. I was going through documents 14 concerning vermiculite and tremolite for 15 W.R. Grace and documents and animal studies for 16 Carborundum Corporation, ceramic fiber material. 17 I can't remember all the research I 18 was doing at the time. 19 Q. Would it be fair to say you didn't 20 have any laboratory facilities or office 21 facilities at the Harvard Club? 22 A. Yes, that's true. 23 Q. Since 1985 has there been any office 24 or laboratory of any kind at any college or 25 department at Oxford that has been yours? 0139 1 Ilgren 2 A. Personally mine? 3 Q. Right. In other words where it would 4 say on the door Dr. E.B. Ilgren? 5 A. No. 6 Q. When did you actually physically move 7 your address from England to the United States? 8 A. I sold my house, which was at 13 9 Frenchay Road. Oxford, trying to think ofwhen 10 the completion date was. I think it was 1992 when 11 it was officially sold. 12 Q. Since that time have you had any 13 office or laboratory facilities other than the 14 apartment in Bryn Mawr in the United States? UCAREF00009380 68 15 A. No. 16 Q. Would you agree with me that the 17 principal organization of Board-certified 18 pathologists in the United States is the College 19 of American Pathologists? 20 A. You mean the boards of -- 21 Q. Let me back up. 22 A. We went through this business about 23 boards. 24 Q. I understand, but this is a different 25 question. Let me back up and rephrase it. 0140 1 Ilgren 2 Would you agree that the principal 3 organization of Board-certified pathologists in 4 the United States is the College ofAmerican 5 Pathologists? 6 A. I don't understand it 7 MR. WILL: I don't either. 8 (The record was read.) 9 MR. WILL: Are you asking him do most 10 Board-certified pathologists belong to the 11 American College of Pathologists? Are you 12 asking him does the American College give 13 the Board-certification exam? 14 MR. BROWNSON: No. 15 Q. We have already established that you 16 are a Board-certified pathologist in the States 17 and you are not a member of the American College 18 of Pathologists in the United States. 19 A. Yes. 20 Q. My question now is finishing that 21 topic, would you agree that the American College 22 of Pathologists is the principal organization of 23 Board-certified pathologists in the United 24 States? 25 MR. WILL: What do you mean by 0141 1 Ilgren 2 "organization of"? That's why I'm asking 3 the question, do you mean that most 4 Board-certified pathologists belong to that 5 organization? 6 Q. Would you agree to that statement? 7 A. I don't know. 8 Q. You do know what the American College 9 ofPathologists is? 10 A. Not exactly. 11 (Ilgren Exhibit 9. excerpt from CAP 12 Directory, marked for identification, as of 13 this date.) 14 Q. I show you now Exhibit 9. which is a 15 photocopy of the cover and certain entries from 16 the 1994 directory of the College of American UCAREF00009381 69 17 Pathologists. On the cover it reads "The mission 18 of the College of American Pathologists, the 19 principal organization of BoaFd-certiiied 20 pathologists, is to represent the interests of 21 pathologists, patients and the public by 22 fostering excellence in the practice ofpathology 23 worldwide." 24 Do you see that statement? 25 A. Yes. 0142 1 Ilgren 2 Q. Having read that, do you agree with 3 the statement contained on the 1994 Directory of 4 the College ofAmerican Pathologists that they 5 are the principal organization ofBoard-certified 6 pathologists? 7 MR. WILL: I object to the question. 8 You're asking him to agree with something on 9 the basis of having read a self-serving 10 statement on this and that's entirely 11 inappropriate. He has no foundation to 12 agree or disagree with the self-serving 13 statement of this group. 14 MR. BROWNSON: Regardless of the 15 objection, I would like an answer. 16 THE WITNESS: Would you repeat the 17 question. 18 (The record was read.) 19 MR GERSON: I also object to 20 ambiguity and vagueness. The problem is no 21 one is saying what they mean by the word 22 "principal" in this case, so I don't see 23 how the witness has a basis for agreeing or 24 disagreeing without further explication or 25 definition. 0143 1 Ilgren 2 A. If that's what they say. You might 3 argue with the College of American Pathologists. 4 Q. Let's go back to your CV. First of 5 all. since you have been at Bryn Mawr, 6 Pennsylvania, as I understand it, you have no 7 laboratory facilities at the apartment in Bryn 8 Mawr, correct? 9 A. Yes. A microscope. 10 Q. What type of microscope is that7 11 A. A Bausch & Lomb. Just a light 12 microscope. 13 Q. Going back to the CV on page 1 where 14 it says "Chronology ofResearch and Professional 15 Experience," this is Exhibit 1. it indicates that 16 you got your doctorate of medicine in 1971. Is 17 that correct? 18 A. No, that's '74. UCAREF00009382 70 19 Q. That should be 1974? 20 A. Yes. That's a mistake. 21 Q. So that's a typographical error? 22 A. Yes. 23 Q. The entryjust below that indicates 24 visiting resident, the Memorial Hospital for 23 Cancer and Allied Diseases, et cetera, 1973. 0144 1 Ilgren 2 How can you be a resident before you 3 have received your M.D. degree? 4 A. Again that should be'74. I was 3 working with Dr. /ones on a project to deal with 6 choriocarcinoma and malignant trophoblasts. 7 Q. Would it be fair to say that that was 8 after you received your M.D. degree in 1974? 9 A. Yes, that's right. That should be '74 10 as well. 11 Q. So the entry on the CV should read not 12 1973 but 1974? 13 A. Yes, it should. 14 Q. As I understand it, you did your 13 residency following your medical school in New 16 York City, is that correct? 17 A. Yes. 18 Q. That was at NYU Cornell hospital? 19 A. It's at Cornell University Medical 20 Center/New York Hospital. 21 MR. GERSON: The New York Hospital is 22 not the same thing as NYU. 23 Q. So this was Cornell University Medical 24 Center at New York Hospital in New York City? 23 A. That's correct. 0145 ' 1 Ilgren 2 Q. When did you complete that residency? 3 A. I think June '76. 4 Q. Is that indicated on the CV here 5 somewhere? 6 A. Possibly. 7 Yes, it's on page 3 under 8 "Employment." That was right. It runs from 9 June 1974 to June 1976. 10 Q. That's the first entry under 11 "Employment" on page 3? 12 A. Yes. 13 Q. Was that residency actually completed 14 in June of '76 or did you leave to complete your 15 residency elsewhere? 16 A. That was the anatomical pathology 17 residency. 18 Q. So it actually was completed at 19 Cornell University Hospital in New York City? 20 A. Yes. UCAREF00009383 71 21 MR. GERSON: Cornell University 22 Medical Center in New York City. 23 Q. Do you recall at the time you were 24 Board-certified in pathology whether it was a 25 requirement that you have a three-year residency 0146 1 Ilgren 2 before you were eligible to take those exams? 3 A. 48 months. 4 Q. My question is, again going to the CV, 5 where is the 48-month residency before 6 Board<ertification in 1977? 7 A. I have the correspondence with the 8 Boards ofPathology, but I wrote to them my first 9 year at Oxford, I think it was the end of 1976, 10 because I hadn't taken the Board exam yet, and I 11 asked them what would be the required number of 12 months prior to sitting for the exam, and they 13 said you need 48 months. 14 1 asked them if, I guess it was about 15 18 months that I had worked at Rockefeller 16 simultaneously with the Cornell University 17 Medical Center, whether that could also be 18 counted, and they said yes. 19 They said in addition they would 20 accept I think the first six months of my 21 training at Oxford, they would give an allowance 22 I think up to six months for research. 23 They also counted the two months I 24 think in medical school I had, a month or two of 25 neuropathology, so it's sufficient, the American 0147 1 Ilgren 2 Board of Pathology reviewed this request and 3 granted it. 4 Q. So is it fair to say what you did 5 within a two-and-a-half to three-year period, you 6 got credit for 48 months? 7 A. I would say three years, something 8 like that. 9 Q. On the CV under "Employment" on page 10 3, the entry we were looking at where you did 11 your residency in New York City, it indicates 12 that you were assistant pathologist Is that a 13 title that you actually held while you were doing 14 your residency? 15 A. I believe that's the title that's on 16 the big certificate I got from New York 17 Hospital. I don't think they called it intern. 18 I think it was assistant pathologist. 19 Q. But would the practical word for that, 20 ifyou will, be resident? 21 A. Yes. 22 Q. In the common parlance of resident, UCAREF00009384 72 23 that's what that assistant pathologist 24 designation means? 23 A. I think ifyou wrote to the hospital 0148 1 Ilgren 2 and asked what position I held during the two 3 years, they would probably say assistant 4 pathologist 3 Q. Then it says anatomic pathology, and I 6 assume that that refers to not a position at the 7 hospital but to the specialty you were studying? 8 A. Yes. 9 Q. Then it says registrar/senior 10 registrar grade. 11 A. Again that's for the sake of the 12 English, to try to give them an idea of what all 13 those different names are. 14 Q. Is it fair to say that in England, 13 what we call a resident in this country is 16 referred to as a registrar? 17 A. Yes. 18 Q. Are you familiar with the 19 classification in America of senior resident? 20 A. Yes. 21 Q. Did they have senior residents at 22 Cornell University Medical Center at the time you 23 were a resident there? 24 A. Yes, they did. 25 Q. Were you a senior resident? 0149 1 Ilgren 2 A. No. 3 Q. Is it your testimony that your status 4 as a resident there was equivalent to a senior 5 registrar grade in England? 6 A. They don't translate terribly well 7 because the systems are quite different, the 8 postgraduate systems are quite different There 9 could very well have been things I was doing in 10 the second year at Cornell that certain senior 11 registrars would be doing, so it'sjust difficult 12 to translate from the American to the English 13 system. 14 Q. Do you know ifyou were 15 Board-certified in pathology in 1976 or 1977? 16 A. I think it's probably '77. 17 Q. It says '76 on the CV. 18 A. That should be changed. I'll change 19 that. 20 . Q. As Board certifications go. were you 21 relatively young when you received that 22 certification? 23 A. I think I was the youngest in the 24 history of the United States. UCAREF00009385 73 25 Q. Do you know that for a fact? 0150 1 Ilgren 2 A. I think somebody told me that once. 3 Q. It also indicates on page 2 of the CV 4 under the heading "Research And/Or Professional 5 Chronology" that in 1976 you were a visiting 6 worker in the Imperial Cancer Research Fund. 7 A. Yes. 8 Q. Would it be fair to say that at some 9 point in 1976 you moved to England, is that how 10 that worked? 11 A. I arrived Guy Fauikes night, 12 November 5, 1976. 13 Q. Was that for a visit ot did you 14 actually move there? 15 A. I went to do my Ph.D. there. 16 Q. Upon arriving did you go directly to 17 Oxford? 18 A. Yes. 19 Q. Upon arriving there at Oxford, was the 20 first position you held that ofthe visiting 21 worker in the Imperial Cancer Research Fund? 22 A. No. 23 Q. What does it mean when you say 24 visiting worker in the Imperial Cancer Research 25 Fund? 0151 1 Ilgren 2 A. It meant that I was going in the late 3 winter and probably for a portion of 1977,1 was 4 going down to the Imperial Cancer Research Fund 5 to study the tumor slides in the so-called TRC, 6 the tumor reference collection, that Rupert 7 Willis had placed in the ICRF or the cancer fund, 8 and it wasn't as ifI was doing active research, 9 though in fact Dr. Pang, who actually took care 10 of the collection, you can see at the end here, 11 it's Professor R.A. Willis and Dr. Lillian Pang, 12 she and I did subsequently write a paper together 13 and we used some ofthe materials, 1 think there 14 were some lung cancers of dogs and cats that we 15 incorporated into a monograph that I wrote. 16 Q. Was that a paid position? 17 A. No, that's not a paid position. 18 Q. Did someone ask you to do that or how 19 did you come to do that? 20 A. It's a funny story. After I wrote to 21 Chicago and I got permission to go ahead and take 22 the exam in American pathology, there was a major 23 problem that I was working largely in a basic 24 science lab in the zoology/botany environment, 25 but I needed a very fine tumor collection review 0152 UCAREF00009386 74 1 Ilgren 2 for the test, so I had a series ofthese 3 textbooks by Rupert Willis and I opened the page 4 up and I saw that he was at Leeds, so I sent a 5 letter off to Rupert Willis and said because he 6 was a renowned tumor pathologist, 1 thought he 7 had a good tumor slide collection that I might 8 review. 9 I wrote to him and he said sure, you 10 can come and see me and talk to me and you can 11 review my collection that's now under the 12 supervision of Dr. Pang at the Imperial Cancer 13 Fund. 14 So I called Dr. Pang up and she wasn't 15 in charge of the pathology department per se, but 16 they said sure, come on down and we'll help you 17 go through the collection. 18 Q. Do you recall ifas a requirement to 19 get your complete 48 months to sit for the Board 20 certification in pathology in the United States, 21 that when you were trying to get credit for the 22 months in England they said no, you have to do 23 some specific pathology-related work and that's 24 how you got on to this idea? 25 A. No, it was just, it was more of a 0153 1 Ilgren 2 study aid to get probably the finest tumor 3 collection in the entire worldjust so that I 4 could go through it, as most people do in 5 preparation for exam, but no one said you need 6 additional pathology experience. That was 7 already taken care of. 8 Q. So just so I'm clear, when you wrote 9 the Boards or when you wrote to the people who 10 were giving the Boards for pathology in the 11 United States and said I want to get credit for 12 these months I spent over in England toward my 48 13 months, they didn't come back and say well, no, 14 you're in a basic sciences laboratory and that's 15 not really pathology, so you have to do some 16 pathology work? 17 A. No, they liked it I mean a lot of 18 the work was fundamental biological work, but it 19 was clearly applicable to pathology and tumor 20 biology. 21 Q. Then it says in 1977 visiting 22 scientist. University of Southern California. San 23 Diego Zoo Society Hospital. Department of 24 Pathology. 25 Did you actually move to San Diego in 0154 1 Ilgren 2 '77 or did you go there for a visit to compare UCAREF00009387 75 3 the tumor collection there with the one in 4 England for purposes of that paper? 5 A. Again, that's another funny story. 6 Briefly, it partly came about because I had to go 7 to San Diego to lake my Boards in pathology and I 8 didn't have any money. So I went across the 9 street to the Sir William Dunn School of 10 Pathology because there was another American who 11 was a third-year resident in pathology at the 12 time on leave from Columbia, and I asked him do 13 you know anybody in San Diego and he said well, 14 there is this Professor Benirschke who is doing 13 some very interesting work. 16 I wanted the name of someone who might 17 sponsor a fellowship application, so I wrote to 18 Benirschke, I was quite open with him, I said I 19 need to come to San Diego to take my Board exams 20 and I would like to apply for a fellowship. I 21 found out that the UICC had these traveling 22 fellowships and there was one called an ICRETT, 23 they paid you for three weeks' living and paid 24 your travel expenses, so I wrote a number of 23 applications with Benirschke which gave us the 0155 1 Ilgren 2 funding to fly me over to San Diego. 3 It was quite a nice time. I went and 4 took my exams for the first two days and then 5 Benirschke and I sat down and worked up the 6 details of my research project. 7 Q. Would it be fair to say that this 8 entry, visiting scientist, was this project you 9 did in San Diego? 10 A. Yes. 11 Q. To fund your trip over there to take 12 the Boards? 13 A. That's what they called me, a visiting 14 scientist 15 Q. How long were you actually there 16 visiting in that position? 17 A. I think three weeks. 18 Q. Did that then result in this 19 publication of Ilgren, Griner. Benirschke and 20 Pang, "A Comparative Study of Pulmonary Tumors"? 21 A. Yes. it did. 22 Q. Basically that was a study of tumors 23 in animals at the San Diego Zoo compared with 24 these ones over in England? 25 A. Comparatively speaking, it was 0156 1 Ilgren 2 actually animals versus humans, but it 3 incorporated domestic species held at the Cancer 4 Fund in London with the wild animal species that UCAREF00009388 76 5 were held in San Diego, so the comparison really 6 refers to animals versus humans. 7 Q. Does that research form any basis for 8 your opinions concerning asbestos and disease? 9 A. I would have to read the paper again. 10 I haven't read it for a long time. 11 Q. I was afraid you would say that, 12 because I read the paper at my office yesterday 13 and forgot to bring it with me. I guess we don't 14 have a copy here, is that correct? 15 A. I don't have one. 16 Q. So without reading the paper you 17 couldn't answer that question as to whether it 18 forms a basis ofyour current opinions on 19 asbestos and disease? 20 A. Do you have a specific question you 21 wanted to ask me about it? 22 Q. I'mjust asking whether the research 23 which is described in that paper forms any part 24 of the basis of your current opinions concerning 25 asbestos and disease. 0157 1 llgren 2 A. Again I would have to read the paper 3 and see what I put in it. 4 (Recess taken.) 5 BY MR. BROWNSON: 6 Q. Are you currently affiliated with any 7 hospitals? 8 A. No. 9 Q. Do you have staffprivileges at any 10 hospitals? 11 A. No. 12 Q. Are you currently engaged in the 13 practice of medicine? 14 A. Reviewing pathology slides and doing 15 postmortems? 16 Q. Right 17 A. No. I mean I do review, in 18 consultation, pathology slides that are sent to 19 me often for litigation purposes. 20 Q. So if some lawyer representing a 21 company in asbestos litigation would want you to 22 review slides, he would send those to you and you 23 would look at them? 24 A. Or for a benzene case or an arsenic 25 case or whatever the case happens to be. 0158 1 llgren 2 Q. But as a layman I make a distinction 3 between what I guess I would call a research 4 person and a person practicing medicine seeing 5 patients day to day, or in the case of a 6 pathologist being in a hospital and seeing UCAREF00009389 77 pathology generated by the hospital? A. Right Q. You are more in the research category. A. In the Brownson sense, I am not Q. Would that be a fair characterization? A. As you have described it, yes. Q. Are you affiliated with any medical group of doctors? MR. WILL: You mean like a clinic or pathology group? Q. Are you affiliated with any clinical practice, clinical medical practice? A. Like an HMO group or something? Q. Right A. No. ' Q. Are you on the staff of any colleges or univerities in any capacity in the United States? Ilgren A. No. Q. Since you came back from Oxford to the United States, have you been on the staffof any hospitals here in the United States? A. No. Q. Have you been on the staff or faculty ofany colleges or univerities or medical schools in the United States? A. No. Q. Let me go back to the CV. We were on page 2 where we were under "Research And/Or Professional Experience Chronology." We talked about this thing at San Diego. The next thing you list in 1977, traveling research fellow, International Union Against Cancer, Geneva, Switzerland. Do you see that? A. That was effectively the fellowship that sent me to San Diego. That was my title from the fellowship, this ICRETT thing. Q. So this was the group, the International Union Against Cancer? A. Right. Q. That sponsored this thing in San Diego UCAREF00009390 78 9 listed there in 1977, would that he the same as 10 the visiting scientist in 1977? 11 A. Yes. 12 Q. You were never actually stationed or 13 living or working in Geneva, Switzerland, were 14 you, in 1977? 15 A. No. 16 Q. Then the next entry is 1976/77, which 17 is post-doctorate research fellow, et cetera, 18 Department of Zoology. 19 That's something different, as I 20 understand it, than the thing in San Diego? 21 A. Yes. 22 Q. When you moved to England after 23 completing your residency in New York City, you 24 arrived there in 16, and was this then what you 25 started doing? 0161 1 llgren 2 . A. I needed funding to pay for the 3 tuition cost and also to simply live on. So when 4 I first arrived there. I applied for a series of 5 grants or fellowships, one ofwhich was sponsored 6 by the World Health, another was American Cancer, 7 another was NIH, and most of them came through, 8 so this was the first grant that I had applied 9 for which was in the International Agency for 10 Cancer Research Division of the World Health 11 Organization, which is based in France in Lyon, 12 and that was a one-year grant and I don't think 1 13 took the full year because then the American 14 Cancer Society gave me a two-year grant, but I 15 couldn't keep the WHO grant at the same time as 16 the American Cancer Society grant, so I 17 stopped -- I can't remember, it was about eight 18 months of the WHO -- and then I started with the 19 American Cancer Society. 20 Then after a certain number of months 21 I was given a three-year NIH award, so I stopped 22 the American Cancer Society. So they more or 23 less, it wasn't as if WHO ran for a perfect year 24 and then the American Cancer Society ran for a 25 perfect two years and NIH ran for a perfect three 0162 1 llgren 2 years. That was the kind of thing. 3 Q. Let me see ifI can summarize it 4 You arrive in England in 1976, go to 5 Oxford to enroll in the Ph.D. program. You're in 6 the Ph.D. program, and I mean D.Phil., you're in 7 the program and you get the Ph.D. in 1980, 8 correct? 9 A. I think so. 10 Q. During the time you're in England at UCAREF00009391 79 11 Oxford getting the Ph.D,, what we see here looks 12 like five entries on your resume which are 13 entries for research funds that you got from 14 these various organizations, would that be fair 15 to say? 16 A. Yes. 17 Q. Were these research funds actually 18 paying you to do some work or were they paying 19 your tuition and expenses? Were they like 20 scholarships or actually like a job where you go 21 to work and get a paycheck? 22 A. That's a fiinny question. As I recall, 23 they were paid monthly and they were to cover my 24 living expenses, my -1 used some of the funds 25 to pay for the tuition. Some of the research 0163 1 Ilgren 2 expenses like go down to the store. In each 3 department they have a departmental store where 4 ifyou need a bottle of formaldehyde or whatever, 5 you have to buy that, so as I recall. I think 6 they paid the department monthly to cover certain 7 research expenses and they would pay me, again 8 it's a long time ago, but I think they would give 9 me a paycheck or whatever it was to pay mejust 10 to cover rent or food or whatever it happened to 11 be. 12 Q. I'm familiar with the term 13 scholarship, ifyou're in college or graduate 14 school you get a scholarship or fellowship. 15 Was this an equivalent of that, where 16 you were getting in the layman's term 17 scholarships or fellowships from these various 18 organizations? 19 A. I don't know how to interpret it. 20 Part of the problem is I had already finished so 21 much work beforehand that I was already a 22 certified specialist as it were. 23 Q. In pathology. 24 A. Then I literally wanted to start from 25 ground zero again to get this basic science 0164 1 Ilgren 2 experience in a Ph.D. program, so in one sense I 3 was a Ph.D. student and in another sense I was a 4 kind of something else physician, so ifyou want 5 to call it a scholarship. I tried to put down 6 what they called the things. 7 I applied for a traveling research 8 fellowship. I applied for a post-doctoral 9 research fellowship with WHO. I applied for 10 these special post-doctoral research fellowships, 11 American Cancer Society. 12 I applied for the research fellowship UCAREF00009392 80 13 atNIH. That's basically what they call these 14 things that you got, so I assumed ifI was given 15 a research fellowship, I was the research fellow. 16 Q. So these things that you have listed 17 between 1976 and 1980, are those things that you 18 applied for or things that you actually received? 19 A. They were things I applied for and 20 then received. 21 Q. So there weren't any of these entries 22 that you applied for and you didn't actually 23 receive a fellowship or grant between 1976 and 24 1980? 25 A. Just ask that again. 0165 1 IlgTen 2 MR. WILL: Are you asking did he 3 receive all of the things that are entered 4 on that? 5 Q. Did you receive a financial grant of 6 some sort from each of the five things you list 7 between 1976 and 1980 while you were getting your 8 Ph.D.7 9 A. I received. I can't remember the exact 10 money amounts, but I received several thousand 11 dollars for the traveling research fellowship. 12 The World Health Organization fellowship I think 13 was $6,000. The special post-doctoral research 14 fellowship was 1 think $10,000 or $11,000 a year 15 for two years. The research fellowship for NIH 16 was, I can't remember. I think it was $15,000, 17 $16,000 and $17,000 a year. 18 Q. 1970 to 1979, it says research fellow, 19 NIH. 20 A. Right 21 Q. The NIH is the National Institutes of 22 Health in the United States? 23 A. Yes. 24 Q. So basically what you got was, ifI 25 can use layman's terms, a scholarship or grant 0166 1 Ilgren 2 from the National Institutes ofHealth in the 3 United States to help fund your Ph.D. education 4 and research at Oxford? 5 A. Right, plus the post-Ph.D. work too. 6 Q. Look at the entry 1979-1980, visiting 7 scientist. Sir William Dunn School of Pathology, 8 University of Oxford. 9 First of all, did you hold the title 10 ofvisiting scientist in the School of Pathology? 11 A. I think that ms the title. When 1 12 finished my Ph.D. or D.PhiL actually during the 13 six-month period before I had received the Ph.D., 14 I guess he was the regius professor of pathology UCARE F00009393 81 15 at the time, Henry Harris, mote me a letter and 16 asked me to come and see him. 17 He said ifyou would like to spend a 18 year ofcontinuing your work at the Sir William 19 Dunn School, which is right across the street 20 from the zoology department, we would be happy to 21 give you lab facilities and make available basic 22 research things. That was it 23 Q. Was this a paid position from the 24 University of Oxford? 25 A. That was again using more of the NIH 0167 1 Ilgren 2 monies. I had only used say less than a year of 3 the NIH research monies to pay for my last year 4 of the Ph.D. or D.Phil., 1979 to '80. and then I 5 had, I think it was two years when I finished my 6 D.Phil., I had two years of monies remaining on 7 the NIH grant. 8 Q. So you applied some ofthat money to 9 this position? 10 A. The first year I split between the Sir 11 William Dunn School of Pathology and the botany 12 school, and then the last year ofthe NIH was the 13 first year in neuropathology. 14 Q. That other CV that we had marked as 15 Exhibit 3, ifwe can drag that out I'm looking 16 at the second page of it and I see an entry from 17 1979 to 1980, it says visiting research worker, 18 NIH, Sir William Dunn School of Pathology. 19 Is that the same thing as what wejust 20 talked about? 21 A. I guess so. I suppose it's the same. 22 Q. So on one resume you referred to it as 23 visiting research worker and then on the more 24 recent one you referred to it as visiting 25 scientist. 0168 1 Ilgren 2 A. Right. I probably abandoned two words 3 for one for the sake of economy. 4 Q. Is visiting scientist or visiting 5 research worker an actual title at Oxford or are 6 those descriptions you have inserted into the CV 7 to describe what you were doing? 8 A. They are descriptions to convey what I 9 was doing, largely, at the time. 10 Q. You received a license to practice 11 medicine in the State of New York in 1975, is 12 that right? 13 A. Yes. 14 Q. Have you been licensed in any other 15 state to practice medicine in the United States? 16 A. No. UCAREF00009394 82 17 Q. Ifyou look at page 1 of your CV, 18 numbered page 1 on Exhibit 1, the recent CV, it 19 indicates you are licensed in medicine and 20 surgery. State ofNew York in 1975, correct? 21 A. Yes. 22 Q. And then two entries above it says 23 1975, diplomate ofthe National Board ofMedical 24 Examiners. 25 Is that something different? 0169 1 llgren 2 A. When you pass your national boards you 3 get a diploma and basically everybody who, as far 4 as I'm aware, that gets a license has to pass the 5 national boards, so that just meant I passed the 6 national boards. 7 Q. Did you ever obtain a license to 8 practice medicine in England? 9 A. I had or still have, I believe, the 10 equivalent license, which ifyou look on page 2, 11 1982, General Medical Council full registration, 12 so they say you're registered to practice there. 13 Q. So the entry 1982, General Medical 14 Council full registration, in layman's terms 15 means a license to practice medicine in England? 16 A. Yes. 17 Q. Is there some distinction between full 18 registration or full license and some lesser 19 registration? 20 A. You have to be fully registered. You 21 have to be. 22 Q. Then ifyou took at the next entry, as 23 long as we are in 1982, it says locum, 24 consultant, neuropathologist, Radcliffe 25 Infirmary, Oxford. Locum, as I understand it, is 0170 1 llgren 2 from the Latin, and basically it means holding 3 the place of someone else? 4 A. The boss was away. He let me run the 5 shop. 6 Q. That's indicated June 3-7,1983? 7 A. Yes. 8 Q. So I'm trying to figure out what that 9 was. Would it be fair to say that for a couple 10 ofweeks in lune of'83 the boss was away at the 11 Radcliffe Infirmary and you were able to fill in 12 for him? 13 A. I suppose I ran most of the department 14 in his absence. It was kind ofexceptional 15 circumstances that they would let one do that. 16 Q. Why would that be exceptional? 17 Doesn't somebody have to be the neuropathologist 18 when the boss is on vacation? UCAREF00009395 83 19 A. But it's an extremely responsible 20 job. They had a catchment area of3,000,000 21 people. It's one thing to be a training 22 neuropathologist with world class, very senior 23 people around with whom you can show a slide, but 24 if there is no one around and you have to tell 25 neurosurgeons sure, that's this, you have to 0171 1 Ilgren 2 treat them this way, I think as a training 3 neuropathologist that's a pretty weighty 4 responsibility. 5 Q. During that two-year period of time 6 did you actually -- 7 A. Two weeks. 8 Q. During that two-week period of time 9 did you actually see neuropathology material from 10 patients at the Radcliffe Infirmary? 11 A. Always. I didn't leave the 12 infirmary. I was just there in the same 13 department. It didn't mean I went to a 14 peripheral town. 15 Q. Let me see ifI can summarize your 16 experience. After you obtained the Ph.D. in 17 1980, it looks like you then went to work in 18 terms ofyour day-to-day activity and worked at 19 the Radcliffe Infirmary, is that fair to say? 20 A. Yes. 21 Q. At the Radcliffe Infirmary you went to 22 work as a pathologist and in particular a 23 neuropathologist, correct? 24 A. Yes. 25 Q. Was that actually, to use the American 0172 1 Ilgren 2 equivalent, a paid doctor on the staff of that 3 infirmary, is that what that is? 4 A. Yes. 5 Q. Is that like a salaried position? 6 A. Yes. 7 Q. They have the national medical, that's 8 why I'm asking the question, it's not an 9 independent, free-standing medical group or 10 hospital ofsome sort 11 A. National Health Service set salary 12 scale, eveiything. 13 Q. ThePh.D. you obtained in 1980 and the 14 thesis was what? 15 A. Title ofthe thesis? 16 Q. I'm asking for the topic of the 17 thesis. 18 A. I have a description here. It's on 19 page 10. Doctoral dissertation summary. 20 Q. Would the summary on page 10 be at UCAREF00009396 84 21 least what you're presenting at the present time 22 on your CV as the summary ofyour doctoral thesis 23 you obtained in 1980 in the Department of Biology 24 and Zoology? 25 A. Zoology, yes, that's the summary. 0173 1 Ilgren 2 Q. Did the work leading up to that Ph.D. 3 include any work with asbestos? 4 A. Did I do any asbestos work here? 5 Q. Right 6 A. No. 7 Q. In the Ph.D. thesis itself, first of 8 all is that published somewhere? 9 A. In I think twelve different papers. 10 They are listed in the first portion of the 11 bibliography. 12 MR. GERSON: In 12 different 13 ,publications, did you mean? 14 THE WITNESS: Yes. 15 A. It would be papers Nos. 3,4,5,6,7, 16 8,9, not 10,14,15. That's it It looks like 17 nine publications. 18 Q. So those nine publications that you 19 have listed which are all on page 12 of your CV 20 as Nos. 3,4,5,6,7,8, 9.14 and 15, were 21 publications resulting from the Ph.D. 22 dissertation? 23 A. Yes. 24 Q. I assume that you didn't, they don't 25 each parrot the same dissertation nine times. 0174 1 Ilgren 2 Those are different publications resulting from 3 that Ph.D. work? 4 A. All different datasets. 14 is a 5 review article which reviews the whole field, but 6 the rest have individual datasets. There is not 7 a great deal of replication and overlap. 8 Q. So is the entire thesis actually 9 published somewhere in the form ofa thesis in 10 the literature? 11 A. It's published as these papers. 12 MR. WILL: Is the thesis itself 13 entirely published in one place in the form 14 in which you submitted it? 15 MR. BROWNSON: Right. 16 A. It's in the university library. 17 Q. But my question is was it actually 18 published in the peer review medical literature? 19 A. Sure, in these journals. 20 Q. The nine articles you have listed and 21 just told us about are published papers in the 22 scientific literature which were as a result of UCAREF00009397 85 23 your Ph.D. research? 24 A. Ifyou look at the back of my thesis, 23 it will say, again I would like to have it with 0175 1 Ilgren 2 me, but to paraphrase what I think it says, this 3 thesis was compiled according to clause such and 4 such of the University of Oxford regulations 5 whereby an individual may bind publications. 6 The usual route is not to do that 7 It's an exceptional way, but basically I didn't 8 have the time and money to spend an additional 9 year sitting around writing up everything as 10 papers, and my professor basically encouraged us 11 to write up as we went so that ifwe did 12 experiments from say September to December, 13 whenever it was, in January the following year, 14 just sit down and say now I'm going to write that 15 up for publication. You wouldn't stop doing your 16 experiments. So itjust saved -1 mean most 17 Ph.D. people do their thesis, put together a 18 conventional thesis, send it in and then they go 19 bade and write it up. 20 Q. You didn't do (hat. What you did is 21 you submitted nine papers that had been published 22 in the literature as you havejust described, 23 bound them together and submitted those nine 24 papers as the Ph.D. thesis, is that right? 25 A. Yes. 0176 1 Ilgren 2 Q. Then that material was accepted as a 3 Ph.D. thesis and you received a Ph.D. from Oxford 4 in 1980? 5. A. Exactly. 6 Q. Ifwe went and blew the dust off some 7 shelf in some library at Oxford and found the 8 thesis, it would consist of those nine papers 9 bound together? 10 A. It would actually be the galley. They 11 are not the final papers, but they are sort of 12 the galleys. 13 Q. Galley proofs ofthose papers? 14 A. Or the submitted manuscripts. 15 Q. Did you receive any English degree or 16 accreditation as a neural pathologist? 17 A. Just the associate MRCPalh. 18 Q. So I guess what I'm trying to get at, 19 there is not an actual medical degree or graduate 20 degree from a university or a college that you 21received in neuropathology in England? 22 A. No. 23 Q. So at whatever point, and I think we 24 saw it was October of 1981 that you received the UCAREF00009398 86 25 associate membership in the Royal College of 0177 1 Ilgren 2 Pathologists, that would be the date you could 3 officially call yourself a neuropathologist in 4 England, would that be fair to say? 5 A. I imagine so. 6 Q. In terms ofactually practicing 7 neuropathology, would you need that associate S membership in the Royal College of Pathologists 9 to go to the Radcliffe Infirmary and be a 10 neuropathologist? 11 A. I can't remember the exact 12 requirements. I think it depends to some extent 13 on the hospital. I can't remember the actual 14 requirements within the English system, whether 15 they would want you to have the fall membership 16 or whether you could have had, such as I did, a 17 certain number ofyears of experience and have 18 seen so many thousand brain biopsies, done so 19 many neurological autopsies and had the American 20 boards. I don't know how they would read that 21 I don't know what the standard rules would be. 22 Q. Just ifwe could try to summarize your 23 medical accreditation or status as ofOctober of 24 1981, would it be fair to say that as of that 25 point you were a neuropathologist in England, 0178 1 Ilgren 2 whatever was required to do that? 3 A. Plus I was doing all the forensic 4 pathology, most ofthe forensic pathology for the 5 Radcliffe Infirmary as well, so I would say in 6 inverted quotes a forensic pathologist and a 7 neuropathologist 8 Q. Have you ever received any 9 certification or accreditation as a 10 neuropathologist in the United States? 11 A. No. 12 Q. So going back to the original Board 13 certification you got in pathology in 1977, that 14 was just anatomical pathology? 15 A. Yes. 16 Q. Up until October of 1981 when you 17 began your "practice" as a neuropathologist in 18 England at the Radcliffe Infirmary, had you done 19 any medical work with respect to asbestos? 20 A. Medical work with respect to asbestos 21 means what? 22 Q. Up until that point had you seen any 23 patients clinically who had asbestos disease? 24 A. As a medical student I believe I saw a 25 few cases of mesothelioma when I was doing my 0179 UCAREF00009399 87 1 Ilgren 2 residency at Cornell. I went through the James 3 Ewing slide collection, which was 20,000 cases, 4 and they had different examples of mesothelioma 5 there, but I didn't work in a clinic where people 6 were coming in for asbestos-related disease. 7 Q. As of that point in time had you ever 8 reviewed any x-rays as part ofa clinical 9 practice ofpeople with asbestos? 10 A. No. 11 Q. Up until that time had you reviewed 12 pathology material, whether it's slides or actual 13 pathology notes, of asbestos-related tumors as 14 part ofyour work? 13 A. I had off and on. Again largely a few 16 cases of asbestosis and a number of mesothelioma. 17 Q. That was during your residency and 18 medical school training in this country? 19 A. It was either in medical school or 20 residency training here or when I was studying or 21 working, whatever you want to call it, at the 22 cancer research fund in London. You're talking 23 about before'81? 24 Q. Right Would it be fair to say, 23 however, that that was not a subject or a focus 0180 1 Ilgren 2 ofany research you were doing before that time? 3 A. That's correct. 4 Q. If you would have seen such cases, it 3 would have been, how would I say, I don't want to 6 say happenstance, but as part of your broad 7 experience in seeing many kinds oftumors and 8 pathology materials in your training? 9 A. That's right. 10 Q. Have you ever done laboratory research 11 in connection with asbestos? By that I mean 12 something other than reviewing literature, 13 meeting with people, looking at records, that 14 sort of thing? Have you done research in the 13 laboratory? 16 A. Yes, that's described on page 2, 17 second entry from the bottom, and then I think 1 18 may have described that in more detail later on. 19 Very briefly on page 7. There is no 20 publication arising out ofthat. 21 Q. Where is it described briefly on page 22 7? 23 A. Right in the dead middle there. 24 Q. This thing where it says Oxford 23 University, 1983 to 1987, asbestos body chelated 0181 1 Ilgren 2 treatment project? UCAREF00009400 $8 3 A. Yes. 4 Q. So to try to move this along, the 5 actual laboratory research you have done 6 concerning asbestos is shown in your CV in two 7 places, one on page 2, second to last entry at 8 the bottom, and then it appears again on page 7 9 in this entry in the middle from '85 to '877 10 A. Are you asking me does this broadly 11 apply to every -- let me say it differently. In 12 terms of sitting in the lab and injecting rats, 13 doing animal studies, specifically hands-on 14 asbestos work? 15 Q. Right. 16 A. That's correct. 17 Q. I just want to ask some basic 18 questions. The study ofpathology is basically 19 looking at tissue from the body, correct? Thai's 20 what a pathologist docs? 21 A. It's a compound question, really. 22 What did you ask me, what was the first part? 23 Q. A pathologist, what a pathologist does 24 is look at or study tissue samples, would that be 25 fair to say? 0182 1 Ilgren 2 A. It could be tissue samples. It could 3 be various fluids. It's a whole range of 4 materials. 5 Q. Materials from the body? 6 A. A pathologist can also be an 7 experimental pathologist. A pathologist can also 8 be a research -1 think there is a whole array 9 ofcategories of pathologists. The person who 10 studies disease may be a fundamental research 11 pathologist who never looks at a body, doesn't 12 look at a whole organism, may spend his entire 13 life doing in vitro studies or theoretical 14 modeling. 15 Q. A pathologist does not treat living, 16 breathing patients and put a stethoscope to their 17 chest? 18 A. That's correct. 19 Q. The pathologist studies or analyzes 20 samples of tissue and fluid and that sort of 21 thing? 22 A. Pathology is the study of disease. A 23 pathologist is a person who studies diseases. 24 Q. I'm not trying to make more of this 25 than there is. but an epidemiologist also studies 0183 1 Ilgren 2 diseases, but a pathologist studies diseases from 3 the perspective of looking at or studying or 4 analyzing tissues and parts from the human body? UCARE F00009401 89 5 A. Sometimes. 6 Q. When you spoke earlier of breaking it 7 down more specifically, some people are research 8 pathologists who do research and some people are 9 what would you call them, medical or practicing 10 pathologists that actually look at the day-to-day 11 tissue that comes down from the surgeon? 12 A. Hospital clinical pathologist, 13 something like that 14 Q. The specific specialty of 15 neuropathology which you obtained in 1981 or 16 thereabouts, how would that be described? How 17 could you best characterize that specialty? 18 A. Neurological pathology is the study of 19 diseases of the nervous system whereby one is 20 responsible for the diagnosis of neurological 21 diseases which might be inflammatory, tumorous, 22 infectious, any agent or toxin, any agent that 23 would affect the central or peripheral or 24 autonomic nervous systems a pathologist might 25 study ifhe is a neuropathologist. 0184 1 Ilgren 2 Q. Is mesothelioma, for example, 3 considered a neurological disease that would be 4 studied by a neuropathologist? 5 A. Not yet, I suppose. 6 Q. How about asbestosis, is that a 7 neurological disease? 8 A. No. 9 Q. How about lung cancer, carcinoma of 10 the lung? 11 A. No. 12 Q. Let's go back. I think before we get 13 on this topic we were talking about the way. what 14 you described as the hands-on research. That was 15 this project beginning in 1984,1 guess, with 16 Professor Shubik? 17 A. Yes. 18 Q. It looks like it started in 1984 and 19 continued through '87, is that right? 20 A. It was almost two years. It was about 21 two years or so. 22 Q. At page 7 of the resume it indicates 23 that it was from 1985 to 1987 and on page 2 it 24 says the grant was received in 1984. Is that a 25 correct chronology of things? 0185 1 Ilgren 2 A. We may have gotten the grant in *84 3 and the work began in '85. I can't quite 4 remember. I know we worked on writing the grants 5 and making application to the Health And Safety 6 Executive and other agencies for the money. Then UCAREF00009402 90 7 I finished the senior registrarjob July 1, 1985, 8 so part of what I was doing from July 1,1985 9 into '87 was working on this project. 10 Q. That was my next question. Senior 11 registrar, that would be what we talked about 12 before, equivalent to a resident in the United 13 States? 14 A. In England you finish medical school. 15 You do a year as a so-called house officer, which 16 would be the old internship. Then you do one to 17 two years as a senior house officer, SHO, and 18 then you do three years as a so-called registrar, 19 and then four years as a senior registrar. 20 That's the general progression, the 21 two to three years of registrar. It can vary a 22 bit. So I just throw that in so you have a 23 better idea ofthe nomenclature and the way it 24 progresses with house officer and SHO and 25 registrar and senior registrar. 0186 1 Ilgren 2 The resident, most American training 3 programs are shorter, but the medical school 4 period per se is longer, where in England the 5 medical school period is a bit shorter and the 6 postgraduate training is longer, so there is a 7 slightly more protracted, I guess it's just the 8 way the society wants to emphasize either the 9 pregraduate or postgraduate training. 10 Q. Could I characterize your work from 11 the time you obtained the Ph.D. until you became 12 a faculty member at Oxford in 1984, that interim 13 of about four years, could l characterize that 14 work as being a neuropathologist on the staff at 15 the Radcliffe Infirmary with some forensic 16 pathology on the side? 17 A. I also was given a grant from the 18 Medical Research Council when I began at the 19 Radcliffe Infirmary to do neuro-embryological 20 research, so I was really doing three different 21 things. Actually there were more, but three 22 basic things. I was one, doing my 23 neuro-embryological research, which was related 24 to brain tumors. I was doing this forensic 25 business and I was doing this sort of senior 0187 1 Ilgren 2 registrarship, diagnostic hospitat/clinical 3 neuropathologist. 4 Q. Would it be fair to say that your 5 primary interest at that time was still trying to 6 conduct this research but that you were kind of 7 holding down twojobs to fund it. or were you 8 actually practicing neuropathology or how would UCAREF00009403 91 9 you describe your status during that time? 10 A. I think there could easily be an 11 analogy between an associate professor here who 12 would have an NIH grant, who would be doing some 13 research in his department and also doing some 14 diagnostic work, either a pathologist looking at 15 slides or as a clinician looking at patients, so 16 it'sjust the main grant-giving body in England 17 is the Medical Research Council. It's the 18 equivalent of NIH. 19 Q. From 1980 to 1981 were you a faculty 20 member ofany college or university in England? 21 From 1980 to 1984, until 1984, were 22 you a faculty member of any college or university 23 in England? 24 A. The last page of my -- I thought I had 25 a photocopy ofthe faculty membership 0188 1 Itgren 2 certificate. I don't remember when that was 3 dated. 4 Q. That's a good point Actually ifyou 5 look at CV No. 2,1 think that's the one that has 6 it. Let's look at that. 7 A. I think it's'84. Here it is. 8 Q. Where do you find it? 9 A. It's in the very back of Exhibit 3. 10 It's dated 31 January 1984. 11 Q. Soon January 31. 1984 you became a 12 member ofthe faculty at Oxford University, 13 right? 14 A. That's what it says. 15 Q. My question is before that date, from 16 1980 when you got the Ph.D. until January 31, 17 1984, were you on the faculty ofany college or 18 university in England? 19 A. No. 20 Q. Were you doing any teaching of medical 21 students during that interim firom 1980 to January 22 31, 1984? 23 A. I was giving the university lectures 24 in brain trauma, brain infection, brain 25 demyelination. 1 gave either four or five major 0189 1 Ilgren 2 lectures on brain diseases in the pathology 3 course at the University Medical School. It was 4 part of their curriculum. 5 In England when you finish high 6 school, as it were, you go into medical school. 7 It's three years ofa preclinical medical 8 training, then three years ofa clinical medical 9 training, but you're still in medical school. 10 In the first three years, I think it's UCAREF00009404 92 11 in the third year, they are required to take a 12 basic pathology course, and neuropathology and 13 other pathological subspecialties are covered, 14 and the neuropath department always participates 15 in that teaching program, so, for example, in the 16 general pathology department the experts in renal 17 pathology would give a couple lectures on kidney 18 disease. The experts on whatever would give 19 their didactic presentation. 20 Q. So if I could again try to summarize 21 in layman's terms, from 1980 until January 31, 22 1984 you were not a faculty member on the paid, 23 lull-time faculty of the medical school at the 24 University of Oxford, but what you did is you 25 gave some lectures to third-year medical students 0190 1 Ilgren 2 in the specialty of neuropathology, would that be 3 fair to say? 4 A. And house staff and clinical medical 5 students. There was a whole series of different 6 grades of students, of house staff. 7 Q. House staffat the Radcliffe 8 Infirmary? 9 A. Yes. Other residents, we also had to 10 make certain presentations to the entire 11 department, so there is a whole different series 12 oftraining or teaching. 13 Q. Does that appear on the CV, that 14 particular experience? 15 A. Which experience? 16 Q. That you have just mentioned where you 17 gave the lectures in neuropathology to the 18 medical students or the house staff? 19 A. No. 20 Q. This reference in 1983 of subfaculty 21 member, department ofbiochemistry. University of 22 Oxford, that's something different? 23 A. I just took this off ofwhat they sent 24 me. That should be '84. I'm sorry it's so 25 complicated. Look at the back of Exhibit 3. 0191 1 Ilgren 2 You're a member ofa college. You're in that 3 faculty, but you're a member of a subfaculty, 4 because obviously that biological and 5 agricultural sciences has a number of 6 subfaculties, so in that they would have, they 7 probably had physical chemistry, organic 8 chemistry, biochemistry, zoology, cellular 9 pathology. 10 So for each subfaculty they would have 11 maybe 30 people. I can't remember exactly how 12 many. Then you would have subfaculty meetings UCAREF00009405 93 13 every two or three weeks. They would talk about 14 who is doing what research, how they should 15 revise what aspects of the curricula, what should 16 they be teaching, what shouldn't they, all sorts 17 ofthings. 18 Q. On January 31,1984 you became a 19 member of the biological and agricultural 20 sciences faculty at the University of Oxford and 21 also at the same date you became a member of the 22 subfaculty in biochemistry? 23 A. Exactly. 24 Q. So where it says that that occurred on 25 your CV in 1983, that should be 1984? 0192 1 Ilgren 2 A. Yes. - 3 Q. I would like to get back to the 4 research project you did with Professor Shubik. 3 That took place from 1985 to 1987, correct, and 6 during that time period -- you were nodding your 7 head. 8 A. I'm sorry. 9 Q. During that time period you remained a 10 member of the faculty of the Department of 11 Biological Sciences at Oxford? 12 A. Yes. 13 Q. What portion ofyour time during those 14 years when you were on the faculty until 1987 was 15 spent on that research project? Was that your 16 day-to-day activity or was that halfyour time or 17 how did that work? 18 A. It would be hard to estimate. Maybe 19 20 percent of my time. 25 percent of my time. 20 Q. As far as the grant that was awarded 21 by the health and safety executive, first ofall 22 that's the health and safety executive in 23 England? 24 A. Yes. 25 Q. As far as that grant, were you a 0193 1 Ilgren 2 recipient of the grant or was the recipient 3 Professor Shubik, or was it both ofyou? 4 A. We were co-recipients on the grant. 5 Q. So if we went to the grant application 6 and looked, it would list Ilgren and Shubik? 7 A. It should. I haven't looked at it, 8 but it should list that 9 Q. Would it list anyone else7 10 A. No. just the two of us. 11 Q. Do you know ifProfessor Shubik had 12 received any previous grants from the Health And 13 Safety Executive? 14 A. I don't believe so. I just don't UCAREF00009406 94 15 know. I don't believe so. 16 Q. Do you know who it was who came up 17 with the idea for this particular research IS project? 19 A. I think it was largely Shubik in that 20 it was a project based on the idea that there may 21 be a two-stage initiation promotion type reaction 22 that would occur between the iron and the 23 asbestos fiber, whereby perhaps the iron as it 24 bound to the fiber could potentiate its effects. 25 He and I obviously discussed the thing 0194 1 Ilgren 2 in great detail and modified the protocol, but 1 3 would think the fundamental ideas would certainty 4 be his. 5 Q. How was it that you came to be 6 involved in that project, since your prior 7 experience had not been in this field? 8 A. I had a boss in neuropathology, Trevor 9 Hughes, who was also bursar of Green College, and 10 the head of Green College was Sir Richard Doll. 11 The head of Green College, one of the other 38 12 colleges, was Sir Richard Doll. Sir Richard had 13 invited Professor Shubik to be a proper fellow of 14 Green College, a senior fellow, research fellow. 15 He would have been a senior research fellow, an 16 SRF, of Green College. 17 I was one ofthe rare Americans in 18 Oxford, actually working in Oxford I should say. 19 There are lots of Americans around, but actually 20 working in Oxford, and Trevor Hughes must have 21 told Shubik that there was an American working in 22 his department who was terribly interested in 23 cancer of all kinds, so Shubik invited me over to 24 his house for a drink and we struck up a pretty 25 good friendship and he knew I realty enjoyed 0195 1 Ilgren 2 doing experimental work, and he was fundamentally 3 an experimental pathologist. 4 So we were walking across. I remember 5 we were walking across the park behind his house 6 one day and he said well, how would you like to 7 do an asbestos experiment? I said sure. That 8 was how it started 9 Q. Did Shubik receive his appointment on 10 the faculty as a professor or don or whatever you 11 call it at Green College? 12 A. Sure. 13 Q. I know he was affiliated with Green 14 College, but what faculty department would that 15 be? 16 A. He would be in the faculty of clinical UCAREF00009407 95 17 medicine. 18 Q. Is he still there? 19 A. I think so. I don't know. Pretty old 20 now. 21 (Ilgren Exhibit 10, excerpt from World 22 ofLearning 1987, marked for identification, 23 as of this date.) 24 Q. We have marked as Exhibit 10 a 25 photocopy ofa cover sheet and a section ofa 0196 1 Ilgren 2 directory called The World of Learning, 37th 3 edition, 1987. 4 What I did is I pulled out Oxford 5 faculty. I'm trying,to find out ifwe can find 6 where Shubik -- 7 A. No, this is too abbreviated. I 8 shouldn't volunteer materials for you, but I 9 could give you the full, they call it the Oxford 10 calendar. It's a red book about 300 pages long. 11 It lists all the proper fellows. This is a 12 pretty bare-bones -- 13 Q. Would it be fair to take it that 14 what's listed here are the faculty members who 15 have the rank offull professor, and it doesn't 16 list the people who have lesser ranks? 17 A. No, there are other professors here 18 for sure of all different kinds. I can send you 19 the book. 20 Q. In any event, it's a bad list, an 21 incomplete list? 22 A. Very abbreviated and incomplete. 23 Q. Would it be fair to say from 1985 24 through some subsequent period of years, maybe up 25 to the present, maybe not. Professor Shubik was a 0197 1 Ilgren 2 professor in the department ofclinical medicine? 3 A. No, you can't say that. He was a 4 senior research fellow at Green College. To my 5 knowledge, he would have had no professorial 6 status whatsoever. He would have been on the 7 faculty ofclinical medicine and he would have 8 had no teaching duties, no administrative 9 responsibilities. 10 Q. So when we look at your CV. Exhibit 1, 11 at page 2 and at page 7, where he is listed as 12 Professor P. Shubik, we should drop the professor 13 part? 14 A. He was a professor in Chicago at 15 Chicago Medical School from 1953 to 1962.1 16 think. The years might be slightly off. Then he 17 became director ofthe Eppley Institute in 18 Nebraska. I think he was an adjunct professor UGAREF00009408 96 19 with the University of Nebraska or whatever was 20 there. 21 Then he became a visiting fellow at 22 the University of Heidelberg, where I think he 23 was a professor, but to say that he was an Oxford 24 University professor at that time would be 25 incorrect, so you couldjust call him Dr. Shubik. 0198 1 Ilgren 2 Q. So the reference on the CV to 3 Professor P. Shubik at the time this study was 4 underway should not be Professor, it should be 5 Dr., because he wasn't actually a professor at 6 Oxford at the time? 7 A. That's right 8 Q. As I understand it what this research 9 project was was you and Dr. Shubik were trying to 10 chelate the iron in the body to block the 11 formation of asbestos bodies, would that be kind 12 of a thumbnail sketch of what you were 13 attempting? 14 A. And also thereby inhibit or at least 15 ameliorate the pathogenic process. That's pretty 16 much ahead of its day. The last couple ofyears 17 with free radical ion, iron-related free radical 18 ion theoiy coming out is a very important 19 underlying mechanism in certain aspects of 20 cancer, particularly in asbestos-related 21 disease. As far as I know there was basically 22 nothing in the literature that really suggested. 23 There have been subsequent papers, 24 largely in vitro studies where they did manage, 25 using chelators, to block a radical-related 0199 1 Ilgren 2 change. The problem here was a pretty simple 3 one, that ifyou take a rat and you ask the 4 question if I put asbestos fibers into that rat 5 and I try to block by reducing its iron content 6 so that there is insufficient iron going to the 7 fiber, mil the fiber still make disease. 8 In theory it's a great study but in 9 practice you need to kill the rat, so to speak, 10 because there is so much iron in the rat, it's 11 almost impossible to deplete its stores whereby 12 it wouldn't form. 13 Q. So again if I could try to summarize 14 this, the intent of the project was to see ifyou 15 could inhibit or prevent or ameliorate the 16 formation of ferruginous bodies or iron asbestos 17 bodies in the rat? 18 A. Right. 19 Q. By chelating the iron? 20 A. Right. UCAREF00009409 97 21 Q. What happened was in order to take 22 enough iron out of the rat to do that, the rat 23 died of iron deficiency? 24 A. The rats didn't die. The results were 25 not clear. The rats didn't die. In other words 0200 1 Ilgren 2 there was a subacute phase and a chronic phase, 3 but one couldn't -- 4 Q. They got pretty loggy? 5 A. Nothing really untoward happened to 6 the rats. It's just simply you could not say 7 that there was less inflammation in the 8 chelated-treated animals as opposed to the ones 9 without. 10 There was one group of animals that 11 for some reason seemed to get a kind of rebound 12 deposition of iron, if I recall, with again as I 13 recall a lot more inflammation. 14 Q. How many animals were involved? 15 A. I would have to get my lab notebooks. 16 There would be hundreds over the time period. 17 Q. These were rats? 18 A. The rats, I can't remember ifthey 19 were wistars or whatever. 20 Q. But this was not a human study, this 21 was a study on rats? 22 A. This was a study on rats. 23 Q. I don't mean to make more of this than 24 there is. I don't mean to stop you but I think I 25 understand what the thinking was. I'm just 0201 1 Ilgren 2 trying to set some basic information about the 3 study. 4 The animal at issue or used was rats. 5 A. Right. 6 Q. The asbestos was introduced to the 7 rats by what, inhalation or injection or what? 8 A. This is how I met Chris Wagner, in 9 fact. Shubik knew Wagner and we went to Chris 10 Wagner's lab in Penarth to discuss the studies 11 with him and also enlist his senior technologist, 12 Rodney Hill, to help us do the intrapleural 13 innoculation. 14 So we used, as I recall, I think 15 chiysotile, amosite and then we also used 16 erionite. which is not asbestos. I believe those 17 three libers types. 18 Q. Was that introduced into the rats by 19 intrapleural injection, the different fibers? 20 A. Yes. 21 Q. Who actually did that work, was that 22 you or Shubik or Wagner? UCAREF00009410 98 23 A. It was Hill, because he had such 24 experience with the intrapleural injection 25 technique. 0202 1 Ilgren 2 Q. In terms of the iron chelation, how 3 was that physically accomplished? 4 A. We put an experimental iron chelator 5 that we got from Procter & Gamble in the drinking 6 water, a certain level, and we also periodically 7 administered desferoxamine via tail vein 8 injection, and there was a set regimen, drinking 9 water, tail vein injection. Sometimes I would do 10 tail vein injection. 11 Q. The object of that was to get the iron 12 out of the rats, in simple terms? 13 A. Yes. ' 14 Q. Was the study funded in some part by 15 Procter & Gamble? 16 A. As I recall, the whole study was 17 funded by the Health And Safety Executive, which 18 I think is the English equivalent ofNIESH. 19 Q. Was there any participation in the 20 funding by Procter & Gamble? 21 A. I don't think so. I can't remember. 22 Q. Was the study completed or what caused 23 the study to end? 24 A. We just decided that for the reasons I 25 listed, that it wasn't worth pursuing at that 0203 1 Ilgren 2 time. 3 Q. Was there any thought in starting this 4 study or during the study that maybe this could 5 be an actual treatment for people with asbestos 6 bodies in their lung, it could be translated into 7 a human medical treatment? 8 A. I think Shubik and I talked about that 9 a lot in the context of trying to block asbestos 10 body formation in people that might be acutely 11 exposed in a building where all ofa sudden in 12 the newspaper in England you would occasionally 13 read about children who were suddenly immersed in 14 a cloud of asbestos because they walked into a 15 contaminated room. 16 There was thinking about trying to 17 make chelatOT therapy for acute exposure, 18 something like this. 19 Q. But it didn't result in any human 20 therapy for asbestos disease of any kind? 21 A. No. 22 Q. Did it result in any published 23 literature in the medical or scientific 24 literature? UCAREF00009411 99 25 A. No. 0204 1 Ilgren 2 Q. Were any reports issued to the funding 3 agency, the Health And Safely Executive? 4 A. I think we sent at least one interim 5 report in ordei to get the second phase of 6 funding, but I would have to check. 7 Q. Was there a final report at the end of 8 the study with conclusions in it? 9 A. I believe so. 10 RQ Q. Ifwe wanted to get a copy ofeither 11 the interim report or the final report, could 12 that be obtained today? 13 A. You mean this second? 14 Q. Not this second. Does it exist 15 somewhere today? 16 A. I suppose so. David Gompertz at the 17 Health And Safety Executive was the liaison 18 officer there, and as far as I recall we dealt 19 with him. Shubik also dealt with at the time the 20 head of the HSE, but the person really dealing 21 with the grant mainly was Gompertz and he would 22 be the contact person. 23 Q. You don't have a copy in your 24 possession? 25 A. I might have it in my file. 0205 I Ilgren 2 Q. You might or might not, you don't 3 know? 4 A. Do you want a copy? 5 Q. I would like to get a copy. 6 A. I don't know. I'll have to 7 MR. GERSON: We'II review everything 8 Bob wants. 9 A. I will have to check and see if it's 10 there. It's a long time. 11 Q. While you're making a note there, the 12 fiber type that was injected intrapleurally into 13 these rats was what? 14 A. I think the three types of fiber, 15 chrysotile, amosite and erionite, but I can't 16 remember if we also had crocidolite. I don't 17 remember exactly. I think it was chrysotile. 18 Q. Do you remember the type of 19 chrysotile? 20 A. I think it was UICC. 21 Q. Do you recall ifany of these rats 22 succumbed to tumors? 23 MR. WILL: Why don't you refer to your 24 CV where it says secondary to crocidolite, 25 zeolite and erionite. 0206 UCAREF00009412 100 1 Ilgren 2 Q. We are referring to page 7? 3 MR. WILL: Yes. 4 Q. Mr. Will has pointed out that on page 3 7 it says crocidolite. zeolite and erionite, so 6 does that indicate that the type of asbestos 7 fiber was crocidolite? 8 A. It may have been. It's been a long 9 time since I have done this stuff. 10 Q. Do you recall if any of the rats 11 succumbed to mesothelioma tumors? 12 A. No. It was. I think they were 13 six-week and twelve-week study periods, so it's 14 not sufficient time for tumoT formation. 15 Q. Do you recall the dose that was 16 injected, the dose of fiber injection? 17 A. I think these were standard 20 mg 18 inocula. 19 Q. So would it be a single 20-milligram 20 dose in each rat? 21 A. I believe so. I would have to check. 22 I think that's correct. 23 Q. With respect to Professor Shubik, are 24 you saying that this experiment was the first 25 work on the two-stage cancer mechanism or had 0207 1 Ilgren 2 work been done on that before this particular 3 project? 4 A. In terms ofasbestos-related disease? 5 Q. Let's start more generally. First of 6 all, as I understand, Professor Shubik was a 7 chemical carcinogen researcher, would that be 8 fair to say? 9 A. Shubik is acknowledged as a co-founder 10 of two-stage theory with Isaac Berenblum back in 11 1947. 12 Q. Before this project, wasn't Dr. Shubik 13 concerned with chemical carcinogens as opposed to 14 particles? 15 A. I think he did particulate work with 16 Safliotti in the co-administration of iron oxide 17 particles with benzopyrene in hamsters to develop 18 a lung cancer model. I know he had done some 19 particulate research before that, but I think 20 this was probably the first experimental 21 investigation to test the hypothesis that iron 22 may have a role in the pathogenesis of 23 asbestos-related disease. 24 Q. So as far as Dr. Shubik's previous 25 work on the two-stage mechanism of cancer, he had 0208 1 Ilgren 2 done some work with chemical carcinogens like UCAREF00009413 101 3 pyrobenzene and also trace metals? When you say 4 particles -- 3 A- I think he has written almost 300 6 papers, so he has gone through a fair gamut of 7 chemical and physical carcinogens. 8 Q. Are you saying that Shubik 9 hypothesized the two-stage cancer mechanism 10 contemporaneously with Berenblum? 11 A. No, I think Isaac Berenblum was a 12 reader in the Sir William Dunn School of 13 Pathology and he came in in about 1927. One of 14 his particular interests was investigating the 15 factors that would serve as modifiers of tumor 16 formation, so some ofhis early studies would be 17 applying a carcinogenic, a carcinogen to a mouse IS and then burning the mouse. One study was carbon 19 dioxide snow. Another was scratching the skin. 20 So Berenblum over the years before he 21 met Shnbik had developed the thinking about 22 interactions between chemical carcinogens and 23 irritants. Shubik came along and participated 24 with Berenblum in the studies and was second 25 author, co-author, so I would say that Berenblum 0209 1 Ilgren 2 probably laid down a lot ofthe theoretical model 3 on which the study was done. 4 Q. In terms ofchronology, would it be 5 fair to say that Berenblum had hypothesized the 6 two-stage mechanism before he began his work with 7 Shubik? That's all I'm trying to get at. 8 A. That's right 9 Q. So Shubik was not a co-founder 10 contemporaneously in time of the theory? 11 A. Some people may shoot me for saying 12 that, but I mean a lot ofpeople give. I would 13 think, Berenblum and Shubik equal credit for 14 this, but my understanding would be that 15 Berenblum added this additional material. 16 Q. You had mentioned that Shubik earlier 17 had done earlier work at the Chicago medical 18 school from 1953 to 1962. and in 1962 he left to 19 go to the Eppley Institute in Omaha, Nebraska, 20 correct? 21 A. Right. 22 Q. That's called something like the 23 Eppley Institute ofMedical Research? I don't 24 know its exact name, but it's in Omaha. 25 A. Something like that. yes. 0210 1 Ilgren 2 Q. Are you aware of the fact that while 3 he was at the Eppley Institute he had one or more 4 grants from the National Cancer Institute? UCAREF00009414 102 5 A. I think he ran an NCI budget of 6 $6,000,000 to $10,000.000 a year. 7 Q. Did he ever indicate to you that he 8 had gotten in trouble with NCI auditors for 9 commingling that grant money? 10 A. What a mess. 11 Q. You are familiar with that? 12 A. The big scandal, sure. 13 Q. Do you know ifhe ever was indicted 14 for that? 13 A. I had the impression, I didn't know 16 that when I first started working with him, I had 17 the impression that there was some very sloppy 18 bookkeeping at the Eppley. 19 MR. WILL: The question was do you 20 know whether he was indicted. Either you do 21 or you don't. 22 A. I do not know. 23 Q. Do you know ifit was as a result of 24 that scandal which may or may not have resulted 25 in indictment that he left Eppley and went to 0211 1 Ilgren 2 Heidelberg? 3 A. I'm not sure, but it could very well 4 have been so. yes. 5 Q. Once Shubik got to Oxford after, first 6 of all do you know why he left Heidelberg? 7 A. I don't know why he left Heidelberg. 8 Q. In any event he came on the scene at 9 Oxford as you have described. Once he got there 10 he was doing other things other than this 11 particular research project, wasn't he? 12 A. He was, I don't know if he founded the 13 journal, I think it's Cancer Letters there, so he 14 had one of hisjournal offices there. He had 15 founded an organization called Toxicology Fonim, 16 and he ran it from his office there. 17 I think he estimated he spent 200 days 18 a year in an airplane somewhere traveling to 19 meetings and whatnot, so for the time he was in 20 Oxford he devoted some time to our research 21 project, some time to the journal, some time to 22 Toxic Forum matters, some time to other matters, 23 consulting. . 24 Q. Do you know ifToxicology Forum 25 published a newsletter while he was at Oxford? 0212 1 Ilgren 2 MR GERSON: I object to the 3 relevance. 4 MR. WILL: Why are we going through 5 all this about Dr. Shubik? 6 A. I don't know. UCAREF00009415 103 7 Q. Did you ever appear as a co-author on 8 any of the Toxicology Journal or toxicology 9 newsletters that he published while at Oxford? 10 A. The newsletters? I don't know if 11 there are newsletters. 12 Q. Whether there are or not, my question 13 is did you author any articles in any of his 14 publications that he edited while he was at 15 Oxford? 16 A. I published one paper in Cancer 17 Letters. I don't think he was, he wasn't a 18 reviewer for that. 19 Q. Is that paper listed on your CV 20 Exhibit l? 21 (Continned on the following page.) 22 23 24 25 0213 1 Ilgren 2 A. Yes, that's a choriocarcinoma in vitro 3 paper. 4 Q. Look at the publications beginning on 5 page 12 and tell me where that shows up. 6 A. 25. 7 MR. BROWNSON: Why don't we stop 8 there. 9 (Time noted: 5:50 p.m.) 10 11 12 EDWARD B. ILGREN 13 14 Subscribed and sworn to before me 15 this____day of, 1994. 16 . 17 18 19 20 21 22 23 24 25 0214 1 2 CERTIFICATE 3 STATE OF NEW YORK ) 4 : ss. 5 COUNTY OF NEW YORK ) 6 7 I, DOUGLAS M. BURKE, a Shorthand Reporter 8 and Notary Public within and for the State of UCAREF00009416 / 104 9 New York, do hereby certify: 10 That EDWARD B. ILGREN, the witness 11 whose deposition is hereinbefore set forth, 12 was duly sworn by me and that such 13 deposition is a true record ofthe testimony 14 given by the witness. 15 I further certify that I am not related 16 to any of the parties to this action by 17 btood or marriage, and that I am in no way ' 18 interested in the outcome of this matter. 19 IN WITNESS WHEREOF, I have hereunto set 20 my hand this____day of, 1994. 21 22 23 24 DOUGLAS M. BURKE 25 0215 1 2 INDEX- 3 WITNESS EXAMINATION BY PAGE 4 Edward B. Ilgren Mr. Brownson 5 5 6 7 INFORMATION REQUESTS 8 DIRECTIONS: 9 RULINGS: 10 TO BE FURNISHED: 11 REQUESTS: 23,30,32,204 12 MOTIONS: 13 14 -----EXHIBITS----- 15 ILGREN FOR I.D. 16 Ilgren Exhibit 1, Ilgren CV 108 17 Ilgren Exhibit 2, Ilgren CV 108 18 Ilgren Exhibit 3. Ilgren CV 108 19 Ilgren Exhibit 4, letter dated 25 124 20 April 1994, Moss to "Dear Sir or Madam, 21 Ilgren Exhibit 5, excerpt from 130 22 Official ABMS Directory of Board-Certified 23 Medical Specialists 1994 24 Ilgren Exhibit 6, fax, St. Edmund 133 25 Hall to Waskosky 0216 1 2 Ilgren Exhibit 7, letter dated 8 134 3 April 1994. Roberts to Waskosky 4 Ilgren Exhibit 8. excerpt from 136 5 Directoiy of Royal College ofPathologists 6 Ilgren Exhibit 9, excerpt from CAP 141 7 Directoiy 8 Ilgren Exhibit 10, excerpt from World 195 9 of Learning 1987 10 UCAREF00009417 UGAREF00009418 1 EXHIBIT S/ff /? /i i Comments on the paper "Cytotoxicity of a Short-Fibre Chrysotile for Human Alveolar Macrophages; Preliminary Observations (1983). Yeager H, Russo D A, Yanez M, Gerardi D, Nolan R P, Kagan E, Langer A.M. Environmental Research; 30,224-232.". . The paper presents a series of results which demonstrate higher cytotoxicity for a "short-fibre" chrysotile from Calidria than for the reference UICC chrysotile A from Zimbabwe despite a virtually identical number of fibres longer than 5 pm in the applied doses. Progressively milled derivatives ofthe Calidria fibre were even more cytotoxic even though there were no long fibres in the milled forms. This conclusion was presented as having important biological implications for the use ofshort fibre chrysotile in industry. ' The Calidria fibre and the milled forms used by Yeager were those produced and described by Langer et al (1978). The UICC chrysotile was that prepared by Timbrell, Rendall and others in the late 1960s and described in the report of the Johannesburg Pneumoconiosis Conference (1970). Langer et al. (1978) reported decreasing hemolytic activity for the Calidria fiber and the progressively milled derivatives of it This result was unexpected because milling results in smaller particles, increased surface area, and increased particle numbers per unit mass, all of which are normally associated with increased biological activity including hemolysis. Langer exp lained this apparent contradiction by the observation that the milling had significantly changed the surface characteristics of the fibers and produced an impressive amount of physico-chemical data to support this argument. The fiber lengths were measured by Transmission Electron Microscopy from high magnification photographs. The sample preparation for the TEM measurement invo Ived dispersion of 1 mg of the bulk fiber in 0.1 ml ofnitrocellulose (1% in amyl acetate). This preparation technique ought not to introduce any size selection in the'sample, and all size ranges should be fully represented. Approximately 1000 particles were measured for each fiber sample with a specific set offiber and fibril definitions viz: "a particle composed ofat least two fibrils, the shorter being contiguous with and comprising at least one-halfofthe first, was called a fiber; objects counted as fibers possessed a length/width aspect ratio of at least 3:1; objects with smaller aspect ratios, composed of many fibrils, were counted as clumps; single fibrils, ofany aspect ratio, including contiguous fibrils that did not meet the fiber criterion, were called fibrils.". These fiber definitions are not standard but would help to reduce inter-observer differences within that study. The minimum fiber length UCAREF00009419 recorded was 0.1 urn but no fiber diameter measurements were reported. A separate record was kept ofthe fiber or fibril nature of each particle and the data were presented in separate tables for fibers and fibrils each classified by length. Yeager combined the data from the two tables ofLanger et aL and simplified the length classes but did not explain fully how the mass/number indices were obtained. The numbers of fibers per microgram of dose were calculated assuming an average fibril diameter of 0.0333 pm and an average fiber diameter of9 times this figure, i.e. 0.3 pm (Yeager did not explain that Langer et al had made this distinction). A particle with a diameter of0.3 pm would have to have a length ofat least 0.9 pm in order to be classed as a fiber but Yeager did not explain how the mass of fibers shorter than 0.9 pm were calculated even though Langer et al recorded more than 65% offibers in the range of 0.1 pm to 1 pm for the unmilled Calidria fiber. The assumptions made about the diameters to be used for these particles would have an influence on the calculated fiber numbers per milligram. Yeager et aL did not explain how the mass/number indices were calculated for the UICC chrysotile or what assumptions were made about the diameter distributions. They stressed the point about the absolute numbers of fibers in different length ranges in the actual doses used, correctly pointing out that 30% of 100,000 fibers is the same as 3% of 1,000,000 fibers. If this were genuinely the case for the fibers in this study then it might be very important However there are good grounds for suggesting that the problem was oversimplified and too many assumptions were madein the arguments. For example, it appears that Yeager assumed that the diameter distributions of the UICC and the Calidria fibers were the same. There are no grounds for this assumption and since the diameter is a controUing factor in the calculation ofnumbers offibers per unit mass it could make a critical difference. Yeager used the length distribution data from the paper by Timbrell (1970) as the source of fiber numbers of the UICC chrysotile A. However, in contrast to Langer, Timbrell carried out TEM analysis ofsamples co llected using a thermal precipitator dust sampling instrument from airborne dust clouds generated by a dust dispenser in a chamber. Timbrell did not describe his sample preparation methods but this dust generation and sampling method could not avoid some size selectivity for the sample as measured by TEM. Also Timbrell measured only particles greater than 0.2 pm, he provided no other indication of fiber counting criteria and made no distinction between fibers and fibrils. UCAREF00009420 . Table l shows how different assumptions about fiber diameters can produce radically different mass/number indices for. UICC chrysotile and Calidria chrysotile from Yeagers own length distributions. Fibers per unit mass forall fibers range from 1.4 million to 110 million for the UICC chrysotile and from 9.2 million to 540 million for the unmilled Calidria fibre. For fibers ionger than 5 pm the numbers range from about 3 50,000 to 28 million So iffiber numbers from Yeagers data were calculated using different assumptions about fiber diameter, then d*ifferent conclusions might be made about the absolute fiber numbers although because the assumptions are made equally for both fiber types the relative fiber numbers are the same. The Calidria chrysotile would still have the same number oflong fibers as the UICC chrysotile A, and still have more fibers ofall lengths. However, since there were no actual diameter distribution data, it is difficult to see how fiber number comparisons can be made, given the ranges shown above. Yeager et aL also cited a paper by Rendall (1970) with respect to the UICC asbestos minerals but they did not use the fiber length data ofRendall even though it was critically different from that of Timbrell (1970) and similar to the data for the untreated Calidria fiber ofLanger (1978). As with Timbrell the lower length limit for measurement offibers was 0.2 pm. The data from Gibbs and Hwang 1980, which are more amenable to fiber mass calculations, show how strong are the influences of the dimensions of a small proportion of the long, thick fibers measured and that the actual fiber dimensions measured are critical to the calculated numbers of fibers per unit mass. Ina pair ofairborne chrysotile samples from mining and bagging operations they found that fibers longer than 5 pm constituted only 1.3% and 3.94% ofthe fiber numbers but 3 9% and 59% of the mass of the fibers. Any assumptions about fiber dimensions, diameters or lengths, ofjust a small number of long fibers in the sample have a dominant effect on the fiber numbers calculated The total fiber numbers for these samples of 1.8 x 107 and 1.2 x 107 per milligram respectively are controlled mostly by the diameters and numbers of these few long fibers. The statement by Yeager that the numbers oflong fibers in the doses ofunmilled Calidria fiber and in the UICC chrysotile are the same despite the differences in the total fiber numbers is then really only a function ofthe assumptions made about fiber diameters used in the calculations. The lesser importance of the short fibers in this calculation and an indication that the apparent difference between the two fibers may be largely a result ofthe assumptions made by Yeager are shown by the following calculations. If25% offibers shorter than 1.0 pm are added to the data of either Timbrell or Rendall and the fiber numbers per unit mass are recalculated then it shows that while the absolute fiber numbers increase dramatically (as expected) the numbers of long fibers per unit mass remain virtually the same.The numbers of long fibers per unit mass then are very insensitive to the fiber counting rules for short fibers or to the analytical methods that might influence the numbers ofthe finest and shortest fibers. UCAREF00009421 These two data sets produced by different observers (Timbrell and Rendall, both intimately involved in the production of the UICC asbestos) still differed by a factor of 2 despite apparently using the same methods on the same samples, indicating that conclusions based upon differing fiber numbers should be treated with caution. * Not only were the measurements offiber dimensions by Langer er aL and by Timbrell and Rendall based upon different sample types and used different preparation procedures but they also used different criteria for inclusion of fibers in the count. In addition to this, the same assumptions about fiber sizes were wrongly applied to fiber populations with different length classes in calculating fiber numbers in the doses. There was in fact no sound basis for making comparisons of the size distributions or the fiber numbers of the UICC and the Calidria fibers and no basis for discussions about the relevance offiber length to toxicity. The fact that large numbers (5x10*) of fine Calidria chrysotile fibers were cytotoxic to human macrophages is scarcely surprising and the fact then that even larger numbers (1.15 x 10*') were more toxic is even less surprising. References: Gibbs, GW, Hwang,CY. (1980) Dimensions ofAirborne Asbestos Fibres. In Biological Effects of Mineral Fibres, ed. J.C. Wagner, VoLl, International Agency for Research on Cancer, Scientific Publications No. 30, Lyon, 69-78. Langer AM, WoliT MS, Rohl AN, Selikoff IJ. (1978). Variation of properties of chrysotile asbestos after milling. J. Tox. Env. Health, 4:173-188. Rendall REG. (1970) The data sheets on the chemical and physical properties of the UICC standard reference samples. In Proceedings ofthe International Conference on Pneumoconiosis, Johannesburg, ed. H.A. Shapiro, 23-27. New York: Oxford Timbrell V (1970) . Characteristics of the International Union Against Cancer Standard Reference Samples of Asbestos. In Proceedings of the International Conference on Pneumoconiosis, Johannesburg, ed. H. A Shapiro, 28-36. NewYork: Oxford Addison-Lynch Edinburgh 25.1.94 UCAREF00009422 Table2. Fiber numbers per microgram forUICC chrysotile calculated from the data ofTimbrell and ofRendall (1970) and adjusted by the addition of25% offibers shorter than 1pm. UICC Original Data Short fibers added Original Data Short fibers added Timbreil 3.6x 10s 4.9 x10s 0.9289 x 10s 0.9287 x10s Rendall 7.1x10s 9.5 x10s 0.4333 x10s 0.4332 x10s Table 3 .Fiber number per microgram ofchrysotile as used by Yeager, as recalculated for this review,, and compared to other chrysotiles. YEAGER UICC A TIMBRELL(1970)UICCA (Recalculated JA) RENDALL (1970) UICC A (Recalculated JA) YEAGER Calidria, unmilled. LANGER Calidria Unmilled (Recalculated JA) GIBBS & HWANG 1980 Mining GIBBS St HWANG 1980 Bagging ALL FIBERS 0.1x10* 3.7x10s 7.1x10s 1.1x10* 2.2 x 107 1.8x 10T 1.2x 107 FIBERS L>5pm 2.5 x10s 9.3 x 10s 4.3 xlO5 2.1x10s 4.5 x10s 2.3 x10s 4.5 x10s UCAREF00009423 Dr. E. B. Ilgren, MA, MD, DPhil, MACPath, MRCPath Faculty of Biological Sciences, Subfaculty of Biochemistiy, University of Oxford, St Edmund Hall, . Oxford Conwyn Apartments, Apartment No. 503, 830 Montgomery Avenue, Bryn Mawr, Penna., USA 19010 Tel: 215 525 5960/Fax: 215 520 1156 Dr Charles Lorberau, PhD Division of Physical Science & Engineering, Measuements Research Branch, National Institute of Occupational Hygiene, Cinn., Ohio tel 513 841 4301 {fax 4500} 5 January 1994 Dear Dr Lorberau, Thank you for offering to check your files in an attempt to identify the individuals to whom you may have sent the Calidria chrysotile samples. As discussed, I would be very interested to know of further data pertaining to fibre size, elemental analyses, and tremolite content. Thank you. yours most sincerely. EXHIBIT UCAREF00009424 'V PARTIAL LIST OF PERSONS RECEIVING SAMPLE OF CHRYSOT1LE (CH-29) SOURCE: UNION CARBIDE, CALIDRIA ASBESTOS copy of list received from Loberau of individuals who requested Calidria samples for research - original not found; date not known ca Feb 94. Paul Laraia Wastex Corp. 510 Heron Or.. Suite 107 Bridgeport, NJ 08014 David Rodriguez, American Analytical Laboratories 100 Lincoln Akron, OH 44308 C. Edward Howard Center for Environmental Measurements Research Triangle Park Research Triangle Park, NC 27709 John FoyHoppe Southern Illinois University Dept, of Chemistry Carbondale, IL 82901 Dr. Brlant Davis South Dakota School of Mines Inst, of Atmospheric Sciences 501 E. SL Joseph Rapid City, SD 57701 Alan Johanns Ames Environmental 3910 Uncoin Way Ames, Iowa 50010 Dr. John Roulston DCM Science Labs 12975 W. 24th PI. Golden, CO 80401 Jerry Krause Colorado School of Mines Research Institute PO Box 12 exhibit U CAR EF00009425 2 PARTIAL LIST OF PERSONS RECEIVING SAMPLE OF CHRYSOTILE (CH-29) SOURCE: UNION CARBIDE, CALIDRIA ASBESTOS Golden. CO 80401 ' Mr. Lee Stone Asarco Inc., Tech. Reseach Center 3422 south 700 W Salt Lake City. UT 84119 - T SgL Mike Wantland Occupational Environmental Analytical Department Brooks AFB.TX 78235 Gregory Bromley, Core Laboratories, Inc. 5295 Hotlister Rd. Houston. TX 77040 Mr. William E. Gardner Technology of Materials 721 East Gutierrez Santa Barbara, CA 93103 Dr. Lily Prtgge Microanaiytical Services, Inc. 201 S. LakeAve., Suite 402 Pasadena, CA 91101 Barbara Przybylska EMS Laboratories 507 Mission St. South Pasadena, CA 91030 ^ MaritLanne Swedish State Power Board Box 816 S-721 22 Vasteras SWEDEN Nancy Clark Health Sciences Center, Occupational Health Lab McMaster University, 1200 Main SL W. Hamilton, ONT CANADA L8N 3Z5 CJ Martin Oxford Research Unit, Foxcombe Hill, Boars Hill, Oxford - Dr. Claudio MartinelU UCAREF00009426 3 PARTIAL LIST OF PERSONS RECEIVING SAMPLE OF CHRYSOT1LE (CH-29) SOURCE: UNION CARBIDE, CAL1DRIA ASBESTOS Sezione Rscia Amblentale Presidio MuRizonale di Prevenzlone - ULSS 25 via 3. D*Acquiso 7 37122 Verona, ITALY Blancotto Dott Renzo U.L.S.S.N. 25 - Regions Veneto Fisica DelPAmbiente Via Salvo O'Agusto 7-37122 Verona, ITALY * Drs. Gabriele Fomaclai and Moreno Beriincioni Servizio MuRizonale di Prevenzlone UnRa Operative di Chimlca Amblentale 4 via del Ponte alle Mosse 211 50100 Firenze, ITALY : Or. Giuseppe Scanarello Istituto 01 Medldna del Lavoro Unlversita' degii Stud! de Diena Via del Tufi 1 53100 Siena, ITALY Or. Luigi Paolettl Laboratorid di Ultrastructure Istituto Superiors di Santta Viale Regina Elena 299 00161 Roma, ITALY Dr. DInesh J. Parikh Head, Occupational Hyg. Division and Asst. Director National InstRute of Occupational Health Meghan! Nagar, Ahmedabad, 380010 INDIA UCAREF00009427 FIBER. SIZE DETERMINATION AND DISTRIBUTION OF CALIDRIA CHRYSOTILE ASBESTOS BY TRANSMISSION ELECTRON MICROSCOPY for: Client: KCAC Inc. P.O. Box K King City, California 93930 Ee: Fiber Size Determination and Distribution Job Number: 8032 Date: November 30, 1991 Analysts: D. R. Miller S. P. Breloff B. E. Lisk C. D. Browning exhibit Director T. J. Spengler ASTECO, INC. PO BOX 179 MIDDLEFORT. NEW YORK 14105 (716) 735-3894 UCAREF00009428 SgJ&XlVE: t To determine che fiber size and. distribution of Chrysotile fibers in 4 different samples of Calidria Chrysotile Asbestos using Transmission Electron Microscopy. The four samples being SG-130 (Standard Crade), RC-144 (High Purity Open), RG-244 and Short Fiber Chrysotile Ore. 2EU5: _ The samples were prepared for analysis by water filtration while trying to disturb them as little as possible and thus attempting keep any ctiange in che fiber size of che sample co a minimum. A known amount of each sample was added to one liter of water and mildly shaken by hand co disperse che sample into suspension. A series of dilutions of each suspension was then filtered through 0.1pm pore size mixed cellulose eschar filters and prepared for TEM analysis using a modified Jaffa wash and acetone condensation wash. The different dilutions of each sample were chen evaluated for in che TEM for fiber loading and preparation acceptability, and one preparation was chosen for analysis. Analysis begun on che selected preparation and proceeded until 400 fibrils were counted. Asbestos fibers which normally would be counted as complex structures (bundles, clusters or macrices), were examined closely and che individual fibrils which composed che structure were counted and measured individually as accurately as possible. The length and widths of che fibrils counted were measured at 20,000 and 60,000 magnification respectively. For each sample a morphology photomicrograph was taken of a typical fibril in each of three categories: s 5pm, > Spm but < 10pm and a 10pm. It was assumed chat all fibers in che samples were Chrysodle, therefore only one diffraction photomicrograph and EDXA spectra were obtained from each sample during che course of che analysis (che morphology of che fibers counted support this assumption). After che analysis of samples SC*130, RC-144 and RG-244 were completed it was requested chat an additional sample be analyzed. This sample was a portion of RG244 which had not been created with silicon by che manufacturer. Also it was requested that che original sample of RG-244, which had been treated with silicon be reanalyzed after steps were taken co disperse che sample better. The original sample of RG-244 was immersed in an ulcrasonie bach for 30 minutes along with the new sample of RG-244. Both samples were refilcered and reanalyzed. The short fiber chrysotile ore was analyzed using both PLM and TEM analysis. The course portion of che sample was first separated using a stereo microscope and forceps. The largest portion of this subsample was measure^ using the stereo microscope and ruler until it was no longer feasible. At this point che portions of che sample were immersed in refractive index liquid and analyzed using Polarized Light Microscopy until 400 particles were counted and measured. The remaining finer portion of che sample was then separated into two similar samples. One of which was suspended in water and filtered while che other was mortared and immersed in an ultrasonic bath for 30 minutes before filtration. Boch samples were chen analyzed. TEM - 1 UCAREF00009429 CALCULATIONS AND DEFINITIONS: , Fibers were distributed into different categories according to their length, width and aspect ratio. For che purposes of this report a fiber is defined as a particle possessing parallel sides and an aspect racio of 3:1 or greater where aspect ratio is defined as che numerical proportion of length to width with che width being defined as 1: Aspect Ratio = *:1 A*w where x - che aspect racio L - length of che fiber in microns (pm) W - widch of che fiber (pm). Note: The larger che aspecc racio che longer che fiber. Thus each sample has chree distributions, one each for their length, width and aspecc racio. The mean, mode and median of each of che sample's distributions was also calculated. The mean used in this report is che arithmetic mean and is defined as; n E p- n where p -- the arithmetic mean (lengch, widch or aspecc ratio) n - the number of fibers counted Xi- che quantity of che i1* fiber (lengch, widch or aspecc racio) i - che i* fiber. The median is defined as che middle variate for a population of variates arranged in either increasing or decreasing order for a population with an odd number of variates and che arithmetic mean of che two middle variates if Che population has an even number of variates. The mode is the most frequently appearing variate in a population. In the report the mode is reported as an interval cacegory of either length, width or aspect racio. Positive Skewness is defined as a distribution in which the majority of the population is smaller chan che mean, and the largest component is below che midpoint. ' TEH 2 UCAREF00009430 REMARKS: ( This report has been prepared for KCAC. Inc . and Is noc Intended to be relied upon by ochers. Any reproduction of the report is to be in its entirety. The samples have been submitted to ASTECO for analysis and qc> sample collection activity has been performed. All aspect ratios are referred co by the length or x component, thus e graph category of 3 - 6 would correspond to a range of aspect racios from 3:1 to 6:1. * All length bar graph x values correspond co the midpoint of a length range. An x value of 1.7S would refer to a length range of 1.3 pm to 2.0 pm. An assortment of graphs are included to help illuscrate sample distributions and various samples comparisons. Graphs which refer co the short fiber ore sample as uncreaced are the of che sample which was ulcrasonicated but noc mortared, graphs which refer to che short fiber ore sample as ulcrasonicated are of che sample which was ulcrasonicaced and mortared. QUALITY ASSURANCE: ASTECO is accredited by che American Industrial Hygiene Association for the analysis of asbescos. Our accreditation number is 336. This accreditation may be verified by contacting che American Industrial Hygiene Association at (216) 762*7296. The laboratory is also accredited by che New York State Environmental Laboratory Approval Program (ELAP) for che analysis of fibers and asbescos. Our accreditation number is 10834. This accreditation may be verified by contacting ELAP at 318 474-4471. The laboratory has accreditation by NIST (National Institute of Standards and Testing) for the NVLAP program (National Voluntary Laboratory Accreditation Program). This accreditation may be verified by contacting NIST at (301) 975-4016. LIMITS_AND_C0NDITI0NS 1. In compiling this report ASTECO INC. (hereinafter We/Our) has followed procedures which we believe co be accurate and reliable but there may be other methods for evaluating asbesciform minerals which may produce different quantitative results. 2. The analytical results reported herein are noc co be viewed as exactly equal to the results which may be found at different sampling locations due to the nonuniformicy in concentration of these types of substances. 3. Any use of, or reliance upon, che data, or ocher information, contained herein by yourself, or any ocher party, shall be without any recourse co, or liability on Our part. 4. The breathing of asbescos dust may cause serious bodily harm and tfe can make no warranty or guarantee chat the results contained herein indicate that safe levels of exposure exist. It is che responsibility of any user of asbestos or an asbestos-containing product co ensure that safe handling procedures are employed and chat applicable government regulations are complied with. TEM - 3 UCAREF00009431 DISCUSSION: / In Che following discussion RG-244 SS will refer Co the preparation of the original silicon created RG-244 sample after ic had been ulcrasonicaced, RG-244 SN will refer to che original silicon created RG-244 sample which was not ulcrasonicaced and RC-244 NS will refer to che second RC-244 sample sane which was not created wich silicon and was ulcrasonicaced. All three samples of che milled chrysotile which was originally submitted for analysis were silicon treated. Analyses of these samples showed chat che fiber lengths of SC-130 and RC-144 have similar mean and median values (Table II) wich SC- 130 (0.89 and 0.63) being slightly shorted chan RC-144 (1.10 and 0.70). This can also be seen in comparison of their aspect ratios (Table V). Sample RG-244 SN has mean and median fiber lengchs and aspect racios which are longer chan either chose of SG-130 or RC-144, which can be seen in Tables II and V. Ic should be noted that che mode of RG-144 and RG-224 SN are che same (0.S - 1.0) but che mode of SC-130 is lower chan either of che ocher two original samples (0.0 - 0.5). The mode of each of che chree original samples are lower chan either choir means or medians which indicates chat all of these distributions are positively skewed. That is che largest component of each sample Is smaller than eicher cheir mean or midpoint. ` Another sample of RG-244 (RG-244 NS) was submitted, this one was not silicon treated. This sample was ulcrasonicaced and analyzed. The original sample of silicon created RG-244 (RG-244 SS) was also ulcrasonicaced and reanalyzed. Table 11 and Table V show chat these cwo samples were shorter chan che original preparation of chis sample. All chree analyses of RG-244 are positively skewed, mosc of the fibers in the samples RG-244 SS and RC-244 NS were between aspecc racios 12 - 24 while sample RG-244 SN had ics largesc portion fall between 24 48. In comparing efte chree different milled varieties of Chrysotile, sample RG-244 NS was used in comparison wich SG-130 and RG-144 because it possessed closest che average values from all chree RC-244 samples. Though shorter chan che original values obtained for RC-244, sample RG-244 NS is scill much longer than eicher SG-130 or RG-144 (See Tables II and V). In comparing che finer porcion of che Short Fiber Ore, che sample which was not ulcrasonicaced yielded closest to a standard distribution though it was also positively skewed wich ics largesc component being in che range of 1.0 1.5 microns in lengch and 48 96 in aspecc ratio. The ulcrasonicaced sample is shorter and is also positively skewed wich its largesc component falling in the range of 0.5 1.0 microns in lengch but wich an aspecc ratio of 48 - 96 as in the non-ulcrasonicaced sample (Tables II and V). All samples had approximately che same results for fiber width distributions. The means ranged from 0.042pm to 0.055pm, che medians ranged from 0.040pm to 0.054pm and ail samples had cheir largesc component in che range from 0.03 - 0.05 microns (Table IV). Ail sample were comprised of at least 75% fibers t 5pm wich SG-130 and RG-144 having che largest components at 100% and 99% respectively. The chree RG-244 samples ranged from 75 co 89 percent with sample RC-244 SS having che greatest portions under 5pm followed sample RG-244 NS and RG-244 SN respectively (See Table III). - TEH - 4 UCAREF00009432 r>< scussion (continued): / The course portion of the shore fiber ore is difficult to catagorize, the sample seems to be bi-modal with the primary mode of the length at 3.2 - 6.4 cm and the width at 0.0 - 0.1 cm. The secondary mode of the length distribution is at 0.0 0.1 cm and of the widch at 0.8 1.6. The aspect ratio has one primary mode at 1.3-3. Ic should be noted that the course portion of the ore in its natural state is approximacly 64% non-fibrous. Only 36% of the course particulate of this sample has an aspect racio of 3:1 or larger. TEM - 5 UCAREF00009433 TABLE I # FIBER CLASSIFICATION CATEGORIES CLASSIFICATION OF FIBERS WITH TUBULAR,MORPHOLOGY Tubular Morphology, noc sufficiently characteristic for'classification as Chrysotile Characteristic Chrysotile Morphology Chrysotile SAEO pattern Chrysotile composition by Quantitative EDXA Chrysotile Morphology and composition by Quantitative EDXA Chrysotile SAED pattern and composition by Quantitative EDXA Non*Asbestos Mineral CLASSIFICATION OF FIBERS WITHOUT TUBULAR MORPHOLOGY Unidentified Fiber Amphibole by random orientation of SAED (shows layered pattern of 0.53 nm spacing) Amphibole by qualitative EDXA. The spectrum has elemental components that are consistent of an Amphibole. Amphibole by random orientation SAED and qualitative EDXA Amphibole by quantitative EDXA Amphibole by one Zone Axis SAED pattern Amphibole by random orientation SAED and Quantitative EDXA Amphibole by one Zone Axis SAED pattern and Quantitative EDXA Amphibole by two Zone Axis SAED patterns with consistent inter-axial angle Amphibole by two Zone Axis SAED patterns, with consistent inter-axial angle and Quantitative EDXA Non-Asbestos Mineral TEM - 6 UCAREF00009434 // TABLE IIt Central Tendencies - Length (All Values In Microns) t Sample # SG-130 RG-144 RG-244 SS RG-244 NS RC-244 SN Short Fiber Ore Not Treated Short Fiber Ore Mortared and Ulcrasonicated Mean 0.89 1.10 2.43 2.86 3.22 3.67 2.89 Median 0.63 0.70 1.51 1.25 1.90 3.00 1.75 Mode 0.0 - 0.5 0.5 - 1.0 0.5 - 1.0 0.5 - 1.0 0.5 - 1.0 1.0 - 1.5 0.5 - 1.0 RC-244 SS RC-244 NS RG-244 SN *This sample was silicon treated and ultrasonicaced. -This sample was not silicon created buc was ulcrasonicated. -This sample was silicon created buc not ulcrasonicated. TEM 7 UCAREF00009435 / TABLE III Fiber Length Breakdown (All Values Are Percent Of Total Fibers) Sample SC-130 Fibers s 5pm 100 Fibers > Spa and < lOum 0 Fiber a 10pm 0 RG-144 99 l 0 RG-244 SS 89 9 2 RG-244 NS 84 11 5 RG-244 SN 75 18 7 Short Fiber Ore Not Treated 76 20 4 Short Fiber Ore Mortared and 82 15 3 Ultrasonicated RG-244 SS RG-244 NS RG-244 SN This sample was silicon treated and ultrasonicated. This sample was not silicon treated but was ultrasonicated. This sample was silicon treated but not ultrasonicated. TEM - 8 UCAREF00009436 TABLE IV Central Tendencies - Width (All Values In Microns) Sample # SC-130 RG-144 RG-244 SS RG-244 NS RG-244 SN Short Fiber Ore Not Treated Short Fiber Ore Mortared and Ulcrasonicated Mean 0.0S2 0.054 0.055 0.054 0.043 0.042 0.046 Median 0.043 0.043 0.043 0.054 0.040 0.040 0.040 Mode 0.03 - 0.05 0.03 - 0.05 0.03 - 0.05 0.03 0.05 0.03 - 0.05 0.03 - 0.05 0.03 0.05 RC-244 SS RC-244 NS RG-244 SN This sample was silicon created and ulcrasonicated. This sample was not silicon created but was uLcrasonicaced. This sample was silicon created but not ulcrasonicated. TEM - 9 UCAREF00009437 TABLE V Central Tendencies - Aspect Ratio (All Values As Length:Width Ratio) t Sample 0 SC-130 RC-144 RC-244 SS . RC-244 NS RC-244 SN Short Fiber Ore Not Treated Short Fiber Ore Mortared and Ultrasonicated Kean 17.3 23.4 49.9 52.6 78.0 91.8 65.7 Median 12.6 15.0 27.9 26.2 47.5 75 37.2 Mode 12-24 12 - 24 12 - 24 12 - 24 24 48 48 96 48 96 RC-244 SS RC-244 NS RG-244 SN - This sample was silicon treated and ultrasonicated. - This sample was not silicon treated but was ultrasonicated. - This sample was silicon treated but not ultrasonicated. TEH 10 UCAREF00009438 Transmission Electron Microscopy Analytical Report Asteeo Job Number: 8032 Report Date: November 30, 1991 Electron Optics Analysts: Barbara E. Lisle Laboratory Director: UCAREF00009439 FIBER SIZE DETERMINATION AND DISTRIBUTION OF RG-244 CALIDRIA CHRYSOTILE ASBESTOS BY TRANSMISSION ELECTRON MICROSCOPY for: Client: KCAC, Inc. P.O. Box K King City, California 93930 Re: RG-244 Fiber Size Determination and Distribution Job Number: 12515 Date: February 3, 1993 Analysts: N. J. Uiedemer D. R. Miller Supervisor: T. J. Spengler exhibit f/Fri ) 'T it ASTECO, INC. PO BOX 179 HIDDLEPORT. NEW YORK 14105 (71$) 735*3894 UCAREF00009440 OBJECTIVEL V To determine the fiber length and distribution of Chrysotile fibers in two unique samples of milled RG*246 Calidria Chrysotile asbestos, one treated with silicon, one untreated, by Transmission Electron Microscopy. PROCEDURE: The samples were prepared for analysis by water filtration and ultrasonic agitation in order to disperse the sample as completely as possible. A known amount of each sample was added to 500 ml of water and submersed in an ultrasonic bath for 30 minutes to disperse the sample into suspension. A series of dilutions of each suspension was then filtered through 0.1/tu pore size mixed cellulose esther filters and prepared for TEM analysis using a modified Jaffe wash and acetone condensation wash. The different dilutions of each sample suspension were then evaluated for fiber Loading and preparation acceptability. Then one dilution of the untreated sample was chosen for analysis while all dilutions of the silicon treated samples were deemed unsuitable. The main problem evident in the treated sample was that Che fibers clumped together and did not disperse sufficiently to allow measurement of individual fibrils. The silicon treated sample was they* resuspended in fresh water and ultrasonic agitation in excess of Che original suspension was applied. The results of the second suspension of this sample did not improve significantly <fo5n the first. The process was repeated with extended ultrasonication only to produce similar results. The silicon treated sample was then resuspended a fourth time in a fresh 500 ml of water and placed in a mechanical shaker for slow agitation for 3 hours. The suspension was then immersed in an ultrasonicated bath for 30 minutes, after which dilutions were made and filtered. The preparations were evaluated and deemed to be slightly better chan the previous three attempts and were used for the analysis of the silicon treated sample. Analysis begun on the selected preparation and proceeded until 420 fibrils were counted. Asbestos fibers which normally would be counted as complex structures (bundles, clusters and matrices), were examined closely and the individual fibrils which composed the structure were counted and measured individually as accurately as possible. Complex structures which could not be accurately counted and measured as individual fibrils were discarded and not Included in the fiber analysis (there were a great deal of complex structures discarded in the silicon treated sample). The lengths of the fibrils counted were measured at 20,000 magnification. CALCULATIONS AND DEFINITIONS: Fibers were distributed into different categories according to their lengths, for the purposes of this report a fiber is defined as a particle possessing parallel sides and an aspect ratio of 3:1 or greater. Aspect ratio is defined as the numerical proportion of length to width with the width being defined as 1. Although JjQ fiber widths were not measured, fibers were observed on screen and particles which appeared to be close to the 3:1 fiber limit were measured in both length and width dimensions to verify the classification of the particle. TEM 1 UCAREF00009441 /TAI.CULATIQNS AMD DEFINITIONS (continued!: The mean, median and mode were also calculated for each sample. The mean used in this report is the arithmetic mean and is defined as : t x, n_ n . where p -- the arithmetic mean (length, width or aspect ratio) n - the number of fibers counted Xi- the quantity of the 1th fiber (length, width or aspect ratio) i - the ith fiber. The median is defined as the middle variate for a population of variates arranged in either increasing or decreasing order for a population with an odd number of variates and the arithmetic mean of Che two middle variates if the population has an even number of variates. The mode is the most frequently appearing variate in a population. In the report the mode is reported as an interval category of fiber lengths. Positive Skewness is defined as a distribution in which the majority of the population is, smaller than the mean, and the largest component is below the midpoint. ' REMARKS: This report has been prepared for KCAC. Inc.. and is not intended to be relied upon by others. Any reproduction of the report is to be in its entirety. The samples have been submitted to ASTECO for analysis and E2 sample collection activity has been performed. All aspect ratios are referred to by the length or x component, thus a graph category of 3 - 6 would correspond to a range of aspect ratios from 3:1 to 6:1. All length bar graph x values correspond to the midpoint of a length range. An x x value of 1.75 would refer to a length range of 1.5 jim to 2.0 pm. An assortment of graphs are included to help illustrate sample distributions and various samples comparisons. TEM - 2 UCAREF00009442 mscussiON: i The two sample, RG-244 silicon created and Non silicon created, show few major differences, this can be clearly seen in Che Semi-Log Comparison of the two samples. The only difference is in percentage of total fibers made up by the smallest subdivision (0.0pm - 0.5pra), where there is clearly a greater percentage of the smallest fibers present in the uncreated sample. The percentage of fibers 5pm are comparable (89% in the silica treated sample and 92% in the untreated sample) and the largest division (^lOprn) is identical in both samples. ^ The mean, and median fiber length of the untreated sample (1.83pm, 1.00pm) is noticeably lower chan chat of the silicon treated sample (2.22pm, 1.25pm) and while the mode for each sample was different, Che untreated sample possessed almost equal separation between the length categories 0.0pm 0.5pm and 0.5pm - 1.0pm which could possibly be considered to be one larger mode (0.0pm - 1.0pm) as a combination of the two smaller categories. j All samples were posltlv]^ skewed. QUALITY ASSURANCE: ASTECO is accredited by the American Industrial Hygiene Association for the analysis of asbestos. Our accreditation number is 356. This accreditation may be verified by contacting the American Industrial Hygiene Association at (216) 762-7294. The laboratory is also accredited by the New York State Environmental Laboratory Approval Program (ELAP) for the analysis of fibers and asbestos. Our accreditation number is 10834. This accreditation may be verified by contacting ELAP at 518 474-4471. The laboratory has accreditation by NIST (National Institute of Standards and Testing) for the NVLAP program (National Voluntary Laboratory Accreditation Program). This accreditation may be verified by contacting NIST at (301) 975-4016. LIMITS AND CONDITIONS 1. In compiling this report ASTECO INC. (hereinafter We/Our) has followed procedures which we believe to be accurate and reliable but there may be other methods for evaluating asbestiform minerals which may produce different qualitative results. 2. The analytical results reported herein are not to be viewed as exactly equal to the results which may be found at different sampling locations due to the nonuniformity in concentration of these types of substances. 3. Any use of, or reliance upon, the data, or other information, contained herein by yourself, or any other party, shall be without any recourse to, or liability on Our part. 4. The breathing of asbestos dust may cause serious bodily harm and We can make no warranty or guarantee that the results contained herein indicate that safe levels of exposure exist. It is the responsibility of any user of asbestos or an asbestos-containing product to ensure that safe handling procedures are employed and that applicable government regulations are complied with. TEH - 3 UCAREF00009443 TABLE 1 f FIBER CLASSIFICATION CATEGORIES - CLASSIFICATION OF FIBERS WITH TUBULAR MORPHOLOGY TM - Tubular Morphology, not sufficiently characteristic for classification as Chrysotile CM - Characteristic Chrysotile Morphology CO - Chrysotile SAED pattern CQ Chrysotile composition by Quantitative EDXA CMQ - Chrysotile Morphology and composition by Quantitative EDXA CDQ Chrysotile .SAED pattern and composition by Quantitative EDXA NAM - Non-Asbestos Mineral CLASSIFICATION OF FIBERS WITHOUT TUBULAR MORPHOLOGY UF - Unidentified Fiber AD - Amphibole by random orientation of SAED (shows layered pattern of 0.53 nm spacing) AX Amphibole by qualitative EDXA. The spectrum has elemental components that are consistent of an Amphibole. ADX - Amphibole by random orientation SAED and qualitative EDXA AQ - Amphibole by quantitative EDXA AZ - Amphibole by one Zone Axis SAED pattern t ADQ - Amphibole by random orientation SAED and Quantitative EDXA AZQ Amphibole by one Zone Axis SAED pattern and Quantitative EDXA AZZ - Amphibole by two Zone Axis SAED patterns with consistent inter-axial angle AZZQ - Amphibole by two Zone Axis SAED patterns, with consistent inter-axial angle and Quantitative EDXA NAM Non-Asbestos Mineral TEM - A UCAREF00009444 Sample # RG-244 s RG-244 N TABLE ZI Central Tendencies - Length (All Values In Microns) Mean 2.22 1.83 Median 1.25 1.00 t Mode 0.5 - 1.0 0.0 - 0.5 TABLE XXI Fiber Length Breakdown (All Values Are Percent Of Total Fibers) Sample # RG-244 S RG-244 N Fibers 5pm 89 Fibers > 5pm and < 10am 9 Fiber a 10pm 2 92 6 2 RG-244 S RG-244 N Sample was treated with silicon. Sample was not treated with silicon. TEM - 5 UCAREF00009445 Transmission Electron Microscopy Analytical Report Asteco Job Humber: 12515 Report Date: February 3, 1993 Electron Optics Analysts: Noelle J. Wiedemer 'L.L. Daniel R. Miller Laboratory Director: TEM 6 UCAREF00009446 GRAPHS Fiber Size Distributions UCAREF00009447 f Fiber Length Distribution RG--244 .23 1.23 2.23 3.23 4.25 5.23 6.23 7.23 0.23 9.23 10.23 11.25 > 12 .75 1.75 2.75 3.73 4.75 5.75 6.75 7.75 8.73 9.75 10.75 11.75 Treated w/ Silicon. Ullrosonicnted Semi-Log Distribution Length (|im) Cumulative Distribution Porconl of Fltirn. Prnl of Fltiwo UCAREF00009448  o 3 pQ . pH w <v a N C cn &? OS S2 Ev os --a Ao A 00 a m ll v Silicon Treated, Ultrasonicated UCAREF00009449 f Fiber Length Distribution RG--244 .25 1.25 2.25 3.25 4.25 5.25 0.25 7.25 0.25 0.25 10.25 11.25 > 12 .75 1.75 2.75 3.75 4.75 5.75 6.75 7.75 0.75 9.75 10.75 11.75 Length (urn) Not Treated w/ Silicon. Ullrnsonicnled Semi-Log Distribution Cumulative Distribution Ptreirit of Hbtn Percent of Fiber* UCAREF00009450  o 2 u I o UCAREF00009451 9 Not Silicon Treated, Ultrasonicated f u*. voi a, no. x pft m-m iwa EXHIBIT 7^7 nowP4cmrfi/a*o4oP.oroog*aLouLo SIZE DISTRIBUTIONS OF OCCUPATIONAL AIRBORNE ASBESTOS TEXTILE FIBRES AS DETERMINED BY TRANSMISSION ELECTRON MICROSCOPY A. P. Rood and R. R. Streeter* (veymuooal Medicine and Hygiene Laboratories. Health and Safety Executive, 403 Edgware Read, ^^ London NW2 6LN, U.1C XtetraO--The size distributions of airborne chiyeocile fibres, associated with the processes of aiding. spinning and weaving in an asbestos textile factory, have been evaluated by transmission cigcuoa microscopy. The distributions were approximately tog-oorrnaL with little change betwtea processes. Median lengths and diameters were 1.6 and (LOS pm, respectively.The results indicatethat tboul 40% of fibres would not be seen by scanning electron microscopy, under the usual conditions. ad an even larger proportion would be missed by optical microscopy. For fibres longer ihsn 3 pm, that,about 70% offibres would be seen by tbe scanning electron microscope. An optical microscope witha resolution of0.3 pm would see approximately one quarter ofaU fibres greaterthan this length. INTRODUCTION Transmission electron microscopy (TEM) allows the observation of even the smallest asbestos fibre (the chrysotile fibril), which can have a diameter as low as 0.01 pm (Gibbs and Hwang, 1975). The complete fibre size distribution of a sample of asbestos may iherefore be evaluated by TEM, in contrast to scanning electron microscopy (SEM) and optical microscopy, which in practice can only detect diameters much larger than ihe smallest asbestos fibres. TEM-derived size distribution data for asbestos manufacturing industries are rather scarce in the literature, probably because the analyses areexpensive compared with those by the other techniques. This paperreports TEM measurements of airborne chrysotile fibres in an asbestos textile factory. Current mouiloring of airborne asbestos dust in factories (Health and Safety Executive. 1983) involve collecting the dust on membrane filters and counting fibres longer than 5 pm. according to certain rules, under a phase-contrast optical ( microscope (PCOM). The detection limit ofa good, correctly adjusted PCOM may be 0.13 pm (Rooker et aU 1982); however, under normal operating conditions, the " detection limit is not so low (Hwang and Wang, 1983; Ashcroft and Heppleston, 1973; Hwang and Gibbs. 1981) and we shall assume a limit of OJ pm. Earlier work by Gibbs and Hwang (1975), using SEM, found that chrysotile fibres traded to be smaller in both length and diameter at later stages of processing. For carding in a textile plant, the median length and diameter were 1.0 and 0.15 pm. respectively; 23 % of fibres were longer than 5 pm. However, there is a possibility that tome fine fibres were lost in sample preparation (Walton, 1982). Moreover, because of Present address: Software Sciences Limited. Abbey House, 282/292 Famborough Road, Famborough. Hampshire GU14 7NB. U.K. <; Crown copyright 119841. 333 UCAREF00009452 334 A. P. Rooo and R. R. Streeter the SEM's detection limit, fibres thinner than 0.1 /un were unlikely to be (Middleton, 1982). *** Dement and Harris (1979) report several TEM-derived fibre size distribution asbestos. We calculated the following from their data: in the chrysotile-usiag tm? plant, for the processes of fibre preparation, twisting and weaving, the geometrical lengths were IX 1.8 and 2.0 /un, respectively, and the geometric mean diaw^^^r** ^ 0.17,0.14 and 0.14 /un, with 41%, 57% and 58% thinner than 0.1 /un; 85%, 84V 78% thinner than 0.3/jm; and 11%, 10% and 11 % longer than 5 /im. Hwanq has reported TEM distributions for chrysotile mining and milling; his diameter* ui lengths were considerably smaller. METHOD Static samples, collected on either Geiman DM Metricel DM450 or DM800 fifcaj... (25 mm diameter), at flow rates of0.4 and 1.5 L min'1, respectively, were taken whlaj ' about 2 m of machines and the extraction systems associated with the 4 carding, spinning and weaving. Sampling times of 60 and 120 min were used. The filters were mounted onto nickel. 200-mesh high-transmission TEM grids, using the direct transfer technique (Burdett, 1983). Analysis was carried out on a Philips EM400T analytical transmission electron microscope, equipped for energy, dispersive X-ray analysis (EDXA) and for scanning (transmission) electron microscopy (STEM). The grid was first inspected at low magnification for an even distribution ofdeposit; if it appeared uneven, the sample was rejected. Only chrysolite was to be included in the study; chrysotile fibres were identified b\ their characteristic EDXA spectrum and morphology (Carton and Kalifer, 1980). A note of any other fibres found was made so that they would not be included at a later stage. A fibre has in the past been defined, by the Health and Safety Executive, as a particle having an aspect ratio greater than three and having parallel sides for most ofits length Crossed fibres, fibre bundles, and piles offibres wereselected for measurementusing the rules adopted in France (Carton and Kaufer, 1980); these rules are similar to those in the European Directive method (Health and Safety Executive, 1983k except for the requirement concerning parallel sides, and that fibres are not rqected on the grounds of attachment to non-fibrous particles. Only fibres with diameters less than 3 /im. that is. respirable fibres, were included. The unit counting area was one grid square of 55 /un side length. Between two and ten randomly selected squares were analysed, such that, except for samples ofvery low fibre density, a minimum of 100 fibres per grid were counted. Only those fibres wholly in the counting area and those crossing either the upperside or the leftside and ending in the field were included (Asbectosis Research Council. 1971k A micrograph ofeach complete counting area was taken for reference. The fibresin each area were then photographed at the higher magnification of 3600.- Since the boundaries of the counting area were the electron-opaque grid bars, any fibres that crossed one of the counting sides were photographed on the STEM facility in the secondary electron imaging mode (various magnifications used). Fibre measurements were made using a Reichert-Jung `Videopian' semi-automatic UCAREF00009453 n were unlikely to he ''vn ed fibre size distributions ft, n the chrysotile-using textii weaving, the geometric mea imetric mean diameters wr than 0.1 tan: 85%. 34% an :r than 5 pm* Hwang (193] .d milling; his diameters an .el DM450 or DM800 filters .pectively,were taken within hated with the processes of d 120 min were used, -.h-transmission TEM grids, .alysis was carried out on a scope, equipped for energy, u'sston)electron microscopy even distribution ofdeposit: tile fibres were identified bv rton and Kaufer. 19801. A .d not be included at a later ifety Executive, as a particle l sides formost ofits length ;ted for measurement using : these rules are similar u> Safety Executive. 1983 i. at fibres are not rejected on res with diameters less than ie length. Between two and ept for samples of very low j. Only those fibres wholly r or the left side and ending . 1971). for reference. The fibres in cation of 3600. Since the - grid bars, any fibres that the STEM facility m the used). 'ideoplan' semi-automatic Si dutnbuuoos of ubeuo* libra by TEM 331 juge analysis system, calibrated using a micrograph of a standard cross grating ;jt0lines mm-1), also taken at 3600 magnification: the micrograph negatives were ^larged by a factor of 9.5 by projection onto a measuring tablet, and the true fibre yagtb (<he length ofthe fibre after straightening) and the true fibre diameter (the width ya central portion of the fibre) (Gibbs and Hwang, 1975) were measured using a cursor. anti-parallax cross-hairs, and a x 7 magnifying eyepiece, giving edge ggasufcmems to an accuracy of 3 nm. The aspect ratio (true length/true diameter) was calculated for each fibre. RESULTS AND DISCUSSION Fourteen samples were analysed: four from the spinning process, from which 424 hie fibres were measured, and five samples from each of carding and weaving, bomwhich 519 and 495 fibres, respectively, were measured. Some non-chrysotile fibres terc observed but not included in the study. Means and standard deviations, both arithmetic and geometric, and the median tahiesibr each of the parameters, true fibre length, true diameter and aspect ratio, for thethreeprocesses, carding, spinning and weaving, are summarized in Table 1. Figures I to 3 show the cumulative frequency distributions for each process. Figure 4 summarizes the individual sample details: these graphs show that there little variation between samples. The frequency distributions were approximately log-normal. Comparison of the diitnbutions shows that there was little variation between processes. The group means. Fio I. Length distribution of airborne fibres. i \ UCAREF00009454 UCAREF00009455 Size distributions of asbestos fibres by TEM t 337 mi 1 i i n ji n 1 mh Conwtw firowiQi Lm tan Sim** Aama IUt 1 -... h tee . Fw. 3. Aspect ratio distribution for airborne fibres. UCAREF00009456 t 338 A. P. Rooo and R. R. Stmete* *CMn| >r r II #*Va I CJ ? S. Fk>. 4. Individual (ample results. Tasle 2. PnorocTiON or aarouaia roam or (a) all lemhiis and (b) unoihs >pn>, as a function or oiameiex (> Process Percentage of fibres (i0 lengths) with diameter greater thin (pm) 0.1 02 02 0.4 Carding Spinning Weaving 41 35 37 17 It 13 8J 3.4 7.8 4.9 6.9 4.7 (b) Process Percentage of fibres (lengths > 5 iim) with diameter greater than (pm) o.t 02 02 0.4 Carding 77 49 26 20 Spurning 69 31 19 14 Weaving 78 38 26 24 standard deviations and medians for each of the three parameters also show dose agreement. For all respirable fibres, the geometric mean diameter for carding was 0.09 pm and for spinning and weaving was 0.08 pm. About 60% of all fibres had diameters under 0.1 pm (the SEM detection limit) and 93% were under03 pm (the optical limit) (Table 2a). The geometric mean length for carding was 13 pm and for spinning and weaving was 1.7 pm. About 11 % were longer than 5 pm; of these, about 74% had diameters exceeding 0.1 pm and 25% exceeding 03 pm (Table 2b). The fibres found In the factory visited forour study tended to be thickerand slightly longer than those from the factory ofDementand Harris (1979). In neither studywere there any substantial differences in size distributions of the various processes in the same factory. . Airborne size distributions may be a function of the fibre characteristics, such as grade and origin, rather than the processing equipment. ' UCAREF00009457 EETCT u a 1 M.ei*i (um) t rtnlaniO ultt. ass or la) all TtoN or ouusrex .engths) with .n Onn) 3 04 3 3.4 3 4.9 9 4.7 -ths >5 /rail Han brai) 3 0.4 20 14 24 t Size distribution* or asbestos fibres by TEM 339 i CONCLUSIONS , (a) Then was not much difference in the size distribution of respirable fibres tgwcefl individual samples and processes. (b) The distributions wen approximately log-normal, with a median length of 1.6/on (geometric standard deviation 2.4) and a median diameter of 0.08 pm (2J). (c) About 60% of all fibres had sizes below the detection linfit of tbe usual SEM method and about 93% had sizes below the detection limit of the PCOM. (d) For fibres longer than S /mu then, about 26% of fibres wen of <iw below the detection limit ofthe usual SEM technique and 73 % had sizes below the detection limit of the PCOM. Hluswitdgcntxs--We would like to thank Or S. J. Kookcr for the samples used in this work. REFERENCES maioao Rbcaxch Council (1971) Technical Note I. revised September 1971. Asbextoca Research Council. Rochdale. UHCltorr. T. and Hamesrow. A. G. (1973) J. Clin. Pathol. 26,224-234. Bt uerr. G. J. (19831 In Free. Asbestos International 4th Colloquium on Oust Measurment. Technique aid Strategy, pp.4t<W24. Edinburgh. 20-23 September 1982. AsbestosInternational Association. London. Citiw. B. and Kaukh. K. (1980) Atmos. Enrir. 14,1181-1196. dcnt. J. M. and Hsana. R. L. (1979) National Institute for Occupational Safety and Health. U.S. Department of Health. Education and Welfare. OHEW (NIOSH) Publication No. 79-133. April 1979. (its. G. W. and Hwano. C. Y. (1973) Am. ind. Hyq. Ass. J. 36.439-466. Health and Saiety Exxctmve (1983) Asbestos fibres in air: detemunauon by the European Reference version of the membrane filter method. 'Methods for the Determination of Hazardous Substances' Series. Health and Safety Executive, London. Hwang, C 11983) Br. J. ind. Med. 40. 273-279. Hwano. C. and GlUS. O. (1981) Ann. oeeup. Hyq. 24, 23-41. Hwang. C. and Wako. Z. M. (1983) Arch, tnriron. Hlth 38, 3-10. MiDOUTON. A. P. (1982) Ann. attup. Hvq. 23. 33-62. RooKBt. S. I- Vaughan. N. P. and La Guar. J. M. (1982) Am. ind. Hrq. Ass. J. 43. 303-313. Walton. W. H. (1982) Ann. occup. Hyq. 23. 113-240. :e parameters also show dose sr for carding was 0.09 pm and ail fibres had diameters under -3 pm (the optical limit) (Table and for spinning and weaving ie. about 74% had diameters !). nded to be thicker and slightly s (1979). In neither study were ` the various processes in the fibre characteristics, such as UCAREF00009458 environmental research 31.32- 33 (1983) NOTICE: THIS MATERIAL MM BE BY COPYRIGHT LAW (TiTlc 17 U.S. CODE) Characterization of Three Types of Chrysotile Asbestos after Aerosoiization . Kent E. Pinkerton,** Arnold R. Brody,+ Daniel A. McLaurin,$ Bernard Adkins, Jr,S Robert W. O'Connor,! Philip C. Pratt.* and James D. Crapo* Departments of Pathology and Medicine. Duke University and Durham Veterans Administration Medical Center, Durham. North Carolina 2770S: *Laboratory of . Pulmonary Function and Toxicology. National Institute of Environmental Health Sciences. tBecton-Dicklnson Research Center, and Northrop Services Inc.. Research Triangle Park. North Carolina 27711 Received December 22. 1981 Jeffrey Mine and Coalinga Mine chrysoliie. two asbestos samples prepared for experi mental research by the National Institute of Environmental Health Sciences, and the UICC B chrysotile reference sample have been characterized in the aerosolized state using gravimetric measurements. light microscopy, scanning electron microscopy, and x-ray energy spectrometry. These methods revealed (1) a greater " respirable" mass fraction in the Jeffrey and U1CC 8 preparations compared to the Coalings sample. (2) for fibers greater than 3 nm in length and less than 3 pm in diameter. Jeffrey Mine chrysolite contained a significantly greater fraction of fibers longer than 40 pm in length compared to the UICC B or Coalinga Mine chrysolites, and (3) Jeffrey and UICC B chrysolite contained no libers or fiber clusters which exceeded 2 pm in diameter while Coalinga chrysotile contained numer ous fibers and fiber clusters which were greater than 2 pm in diameter. The characterization of these chrysolite preparations in the aerosolized state, in particular the Coalinga Mine chrysotile. demonstrated different fiber length and Sber width distributions when compared with previous characterizations of samples that had been dispersed in a liquid medium by ultrasonification. These observations emphasize the importance of determining the size distribution offibers in the aerosolized state for inhalation studies and the size distribution of fibers in a liquid suspension for oral ingestion, instillation, or injection studies. Because of differences in length-width distributions, each of the studied chrysotile preparations would be expected to have different patterns of deposition in the alveolar regions of the lung after an inhalation exposure. INTRODUCTION There is increasing evidence that asbestos-induced pulmonary fibrosis and neoplasia are due to the physical and chemical characteristics of the inhaled fibers (Wagner, 1965: Seaton, 1975; Stanton and Layard, 1978: Pott, 1978). This makes it important to use well-characterized fiber preparations in experimental research to more clearly identify those factors leading to lung injury. The purpose of this paper is to describe two new samples of chrysotile which have been prepared for experimental research by the National Institute of Environmental Health Sciences (NIEHS). A third chrysotile, UICC B, has also been characterized in this paper. * To whom correspondence and reprint requests should be addressed: Box 3177, Duke University Medical Center. Durham, N.C. 27710. 0013-9331/83 S3.04 Copyrtat 190 by Andtirw Prtsi. tee. Ail f*tbu of reproduction m aay form mrr4. exhibit U CAR EF00009459 characteristics op aerosolized chrysotile 33 Chrysotile represents over 90% of the world's asbestos production and is ubiq uitous in our environment. The properties of Ore retardance, chemical inertness, tensile strength, and flexibility make chrysotile important in numerous applica-' tions such as insulation, ceiling tiles, brake linings, and cement products. These utilizations of asbestos enhance the frequency of inhalation of chrysotile by people not directly involved with the mining or processing of this material. Chrysotile is a member of the serpentine, family of minerals, whereas all other asbestos minerals belong to the amphibole family (Sinclair, 1959). Mechanical agitation of chrysotile can lead to disruption of the fiber at weak points along the fiber. This disruption can cause the fiber to "open up" into its fibrillar subunits, creating new fibers of smaller diameter and/or shorter length, fibers with splayed ends, fibers with an uneven diameter along the length, or combinations of the above (Assuncao and Com, 1975). These features make chrysotile more complex to analyze in terms of fiber size and number than the amphibole types of asbestos in which fibers are basically straight and uniform in diameter. The characterization of a chrysotile preparation in terms of particle and fiber size distribution is influenced by a number of factors. These include (1) the state in which the chrysotile is found, i.e., in bulk, in suspension, or in an aerosol. (2) the method of sample collection, i.e.. on a slide or filter, (3) the manner in which the collected sample is prepared for examination, i.e., by utirasonification. transfer or direct preparation of the filter or slide, (4) the instrument used to measure the particles and fibers in the sample, i.e., the optical microscope, transmission elec tron microscope, or scanning electron microscope, and (5) the criteria used for defining fibers, i.e.. a minimum fiber length, a 3 to l aspect ratio, or characteristics of fiber morphology. Characterization of chrysotile in the aerosolized state has been done for the U1CC A and B reference samples (Timbrell. 1970a: Beckett, 1973). Two new research samples of chrysotile have been prepared in bulk (approximately 1000 pounds of each) and are available for experimental research through the National Institute of Environmental Health Sciences. Research Triangle Park. North Carolina. These new preparations (Jeffrey and Coaiinga chrysotile) have been characterized for elemental composition, mineral composition, particle surface area and density, and thermal properties using optical emission spectrography, x-ray diffraction, thermogravimetry, pycnometry, and a number of petrographic microscopic techniques (Campbell et al., 1980). Particle size analysis has been done with samples dispersed in a liquid medium in which measurements of fiber length and diameter were made (Wylie, 1979; Campbell ei al., 1980; Siegrisl and Wylie, 1980). Particle size analysis of these preparations in the aerosolized state was not done. The purpose of this study is to characterize in the aerosolized state the Jeffrey and Coaiinga chrysotile preparations along with the UICC B reference sample. To characterize each preparation, gravimetric dust measurements, optical microscopy, scanning electron microscopy (SEM), and x-ray energy spectrometry .were used. Information obtained using these techniques has helped identify char acteristics of these asbestos preparations which may influence their deposition S' em when inhaled as an aerosol and which could potentially contribute to their Ley to cause pulmonary injury. 34 PINKERTON ET AL. MATERIALS ANO METHODS Fiber Preparations _ Chrysotile samples were obtained from (he following locations: the Coalinga Mine in California (Union Carbide), the Jeffrey Mine in Quebec, Canada (Johns-Manville), and the Canadian reference sample prepared by the Interna* tional Union Against Cancer (UICC B). A brief history for each preparation is given. * Coalinga Mine fiber. Identified as COF-25, this unique form of chrysotile is obtained from the New Idria serpendnite mass located in the Diablo range in California. The deposit is unusual in that the fibers are randomly oriented as a mat, rather than as parallel fibers running in veins, and the mining process is done with bulldozers. The deposit is almost pure chrysotile. The fibers are short in length and are not of spinning grade. Because of the absence of long fibers in this chrysotile, a great deal of interest has been generated in using this chrysotile as a "short-range fiber'* preparation. Preparation of this short fiber material for experimental research was done in the following manner. The ore from the mine was first screened to remove con* laminating rocks. From this point the material was processed in water as a slurry of 196 solids and 99% water. The slurTy was passed through a grinder and a magnetic separator three times to open the fiber bundles and to remove any iron-containing minerals. Between each grinding the slurry was passed through a particle size separator (hydroclone) under pressure. The aqueous slurry was ro tated inside the hydroctone forming a vortex. Heavy particles escape from the hydroclone through a side port located near the bottom of the hydrocione. These coarse particles were reground and put through the hydroclone again. The light particles leave the hydrocione through a side port located near the top of the vortex. These particles were fed into a series of hydrociones in which the top exit ports (overflow port) are progressively smaller to allow for the collection of finer and finer chrysotile fibers. The final hydrocione port had an external diameter of 25 mm from which the chrysotile preparation was collected. (For industrial pur poses the final hydrocione port is usually six inches (personal communication. Asbestos Group, Union Carbide, Niagara Falls, N.Y.).) Langer et al. (1978) described in detail a chrysotile sample also obtained from the Coalinga Mine deposit, referred to as Calidria RG-144. The differences be tween COF-25 and RG-144 are a result of the differences in the processing of the raw material. COF-25 has a finer particle size than RG-144. This finer particle size is a result of differences in the pressure, vortex characteristics, and overflow port diameters used in the hydrocione. COF-25 is not derived from RG-144 by farther grinding or pellet milling. Jeffrey Minefiber. Identified as Plastibest-20, this form of chrysotile is a grade 4 asbestos used by the plastics industry. The fibers run in parallel bundles, oriented crosswise in veins in serpentine rock and for this project were purified by roller milling and air separation using standard industrial techniques. The final fiber preparation by volume is greater than 98% chrysotile (Campbell et al.. 1980). Preparation of the material for experimental research was accomplished by pas sing the material through a hurricane pulverizer three times to open fiber bundles. ibt UCAREF00009461 CHARACTERISTICS OF AEROSOLIZED CHRYSOT1LE 35 UICC B chrysolite reference sample. Tbis preparation is a grade 4 chrysotiie (Timbreil et al.. 1968) obtained from eight different Canadian chrysotiie mines and mixed according to the proportional production of each mine during the year of 1950. The approval of this preparation was made in 1966 by the Union Inter* nationale Contre Cancer (UICC) to standardize asbestos samples used in expetimental research. The literature is replete with information regarding the physical and chemical makeup of this chrysotiie preparation (Timbreil et al.. 1968: Tim* brell, 1970a. b: Rendall, 1970. 1980: Morgan and Cralley, 1973; Beckett, 1973). We have reexamined UICC B chrysotiie in the aerosolized state with a twofold pur pose: (1) to compare our results for the UICC B fiber size distribution with those found in prior studies in the literature, and (2) to correlate the size distribution of the Coalinga and Jeffrey Mine fibers to the UICC chrysotiie fiber preparations available for experimental inhalation research. No manipulation of these chrysotiie preparations was done prior to aerosolizing the fibers. Fiber Aerosolization A modified Timbreil generator (Timbreil, 1968) was used to create a dust cloud within a 5-m*-stainless steel-exposure chamber. Each asbestos preparation was hand compressed with a plunger in a 2.8 x 9.0-cra cylinder to form a plug. This was mechanically advanced into the pathway of a blade rotating 1500 rpm to create an aerosol of fibers within the dispersing bowl of the generator. A copper tube connecting the dispersing bowl to the exposure chamber facilitated the pas sage of aerosolized fibers into the exposure chamber. The concentration of the asbestos dust cloud was regulated by adjustment of the airflow through the expo sure chamber. This resulted in the flow of air being maintained between 200 to 400 liters per minute. Total Dust Mass Concentration Once the exposure chamber had stabilized (normally after 1 hr of dust genera tion), a gravimetric measurement of the dust concentration within the exposure chamber was made. This was accomplished by sampling 100 liters of chamber air drawn through a 0.8-jum Nudeopore filter housed within a Gelman filter holder. The sample time was 10 min at a flowrate of 10.0 liters per minute. Respirable Mass Concentration The respirable mass concentration in the exposure chamber for each chrysotiie preparation was measured using two different instruments: a Casella sampler and a Cascade impactor. The term "respirable mass concentration'' is arbitrary in that it was decided by totally different parameters for each apparatus used. Using the Caseila sampler, a gravimetric estimate of the respiratory mass concentration was made by collecting fibers and particles with an equivalent aerodynamic diam eter of 7.1 ptn or less on a glass fiber filter. Fibers and particles larger than this equivalent diameter were prevented from depositing on the filter by a multichan nel horizontal elutriator. Each sample was collected over a 6-hr period at a flow rate of 2.5 liters per minute with the Casella sampler placed inside the exposure chamber. Using the Cascade impactor, the respirable mass concentration was defined to UCAREF00009462 t 36 PINKERTON ET AL. include filters on which the majority (>50%) of fibers collected were less than 10 Itm in length. This was determined by examination of the filter by optical micros copy. This respirable mass was obtained by using precutter stages in the Cascade- impactor to eliminate the longer and thicker fibers and by adjusting the flowrate to obtain a fiber size distribution (cut point) of 10 mui or less in length. The volume of air sampled through the Cascade impactor was 200 liters. A total sample mass was also collected on the same day by sampling 0.2 m3 of chamber air at a flowrate of 10.5 liters per minute for 19 min 3 sec using the same setup minus the Cascade impactor. All gravimetric measurements were expressed in mg/m3. Gravimetric measurements of the respirable mass collected in the Cascade impac tor were done for the Jeffrey and Coalinga Mine preparations only, because of the known similarity between Jeffrey and UICC B chrysotile. - Collection of Fiber Samples The same apparatus Used to collect samples for dust concentration mea surements was also used to collect fiber samples. Samples to be analyzed by light microscopy were collected on Millipore-type AAWP membrane filters at a flow rate of 0.1 liters per minute for 3 to 5 min depending upon the chamber concentra tion of the chrysotile preparation. Before use, the filters were treated in a 0.1% solution of Hyamin 2389 and dried at room temperature overnight to prevent static charging of the filter. Samples analyzed by scanning electron microscopy were collected on a 0.2-^m Nucleopore filter for 2 sec and 5 sec at a flowrate of 10 liters per minute. Preparation of Filters for Examination Light microscopy. After sampling, the filter was placed on a 25 x 75-mm glass microscope slide, sample side down. The filter was cleared by holding the slide over an evaporadng flask of boiling acetone. After clearing, a drop of glyceroltriacetate (Permount) was placed on the dissolved filter and a cover slip applied. Electron microscopy. Filters were secured to the polished side of a Gough planchet with carbon paint and were gold coated. The thickness of the gold coat was 100 to 150 nm. Fiber Characterization Light microscopy. A Beckett G22 graticule was used. At 300x, the magnifica tion used for sizing and counting, the graticule was a square, 100 Mm on each side, rhe lattice on the graticule had a spacing of 5 pxa in one direction and 3 Mm in the perpendicular direction. The following rules were used for fiber characterization: All fibers counted had at least a 3 to 1 length-to-diameter ratio (aspect ratio). Only fibers 5 Mm in length or longer were counted. A fiber bundle which met the 3 to 1 aspect ratio requirement was counted as a fiber. Bundles with a diameter greater than 3 Mm were not counted. Only fibers whose midpoint was located within the graticule were counted. At least 200 fibers were counted from 20 to 100 random graticule fields for each filter sample. The characterization of each chrysotile preparation by light microscopy was based upon measurements from filters col lected on a daily basis (5 days/week for 12 months). ^ Electron microscopy. The magnification used for panicle sizing and counting was. tion* wen poir esse equ; dart dec nifk of t selc wet chr .T filh ( wa fib: dia OCw att. cot po* i qu bu ler its mi IT su of pl m ti s'. P v P f UCARE F00009463 CHARACTERISTICS of aerosolized chrysotile 37 was 10.000. To facilitate measurement of long fibers and fiber width, magnifica tions ranging from 1200 to 18.000X were used. Counting' and sizing of panicles were done directly on the electron microscope screen. Only particles whose mid point fell within the area of the viewing screen were analyzed. This procedure essentially reduced all particles to points, thus causing every particle to have an equal probability of being counted. To assure accuracy in measurement, a stan dard was made consisting of latex beads 1.099 nm in diameter on a 0.2-Mtn Nucleopore filter. The filter and beads were gold coated and used to verify the mag nification prior to each counting session. The area of the filter analyzed consisted of bands randomly selected across portions of the filter. A field was randomly selected at 10.000 magnification and then moved to the right. Several bands were counted per filter and a range of 4 to 8 filters was analyzed for each chrysotile preparation. The following three categories were used to characterize the material on the filters for each of the chrysotile preparations: (1) Fiber (a) At least a 3 to 1 aspect ratio was required, (b) Generally, a fiber was cylinder-shaped with a uniform diameter. However, a slight separation of the fibrils along any section of the fiber or at the ends was permissible, (c) The diameter of the fiber was measured at the widest portion of the fiber whether it occurred at the end or at some point along the fiber, (d) Smaller fibrils solidly attached to the major body of the fiber constituted a portion of the fiber. It was not counted as a separate fiber. The diameter of the fiber would be measured at this point if it constituted the widest portion of the fiber. (2) Fiber duster (a) A fiber mass with at least a 3 to I aspect ratio was re quired. (b) It was composed of small fibrils usually oriented in the same direction, but partially separated. Separation of fibrils may occur at any point along the length of the bundle or cluster, (c) The diameter of the cluster was measured at its greatest combined width along the fiber mass. A fiber cluster usually has a more variable width than a "fiber." (3) Nonfibrous particle: (a) Any panicle with less than a 3 to 1 aspect ratio, (b) The longest dimension was measured as well as the greatest perpendicular mea surement. Fiber "fiocs" or dumps were also occasionally present on the filter consisting of tangled fibers and fiber dusters. These were not analyzed because their com plexity prevented accurate separation into individual fibers and fiber clusters. Representative fibers, clusters, and nonfibrous panicles were analyzed for ele mental composition using x-ray energy spectrometry for each chrysotile prepara tion. Each particle was analyzed for the presence of an element by a scoring system ranging from 0 to 4+. At 10,000 x, 50 nonfibrous particles whose mid points fell within the viewing area of a randomly selected band across the filter were analyzed. In addition, the magnesium-to-silicon ratio was determined for all particles containing these two elements. RESULTS Dust Concentration Measurements The total mass concentration and corresponding respirable mass concentration for each chrysotile preparation are given in Table 1 using both the Casella sampler ?. i i 38 PINKERTON ET AL. ' TABLE l Gravimetric Measurements for Each Chrvsotils Preparation* in the Exposure Chamber Preparation (A) Chamber dust mass concentration (mg/m (B) Respirable concentration' (mg/m3)* Ratio B/A Jeffrey UICC B Coalinga Jeffrey Coalinga 11.36 = 2.18 10.99 = 2.11 7.76 = 1.46 12.29 = 3.33* 15.63 = 2.41' Casella sampler 9.90 = 1.63 8.32 = 1.75 3.28 = 0-83 * 0.871 0.757 0.423 Cascade impactor 2.62 = 0.81* 0.80' 0.213 0.051 * All dan are means = SO. n 240 for each chrysoiile preparation. * For Jeffrey all data are means = SD. n " 12. ' For Coalinga the chamber mass concentration is based on three samples and the respirable concen tration is a single sample. ,* and the Cascade impactor. When comparing the ratio of the respirable mass concentration to the total dust concentration found in the exposure chamber, the Jeffrey Mine chrysolite and UTCC B chrysolite have a relatively high percentage of respirable material based upon the Casella sampler measurements (87% for the Jeffrey chrysolite and 76% for the UICC B chrysolite). The ratio of the respirable mass concentration to the total mass concentration is significantly lower for Coalinga Mine chrysoiile (42%). Using the Cascade impactor a substantially smaller fraction of the total dust concentration was found to be respirable. For the Jeffrey fiber 21% of the total dust concentration was respirable and 5% of the total dust concentration was respirable for the Coalinga fiber. Fiber Characterization--Light Microscopy ' Table 2 lists the percentage of fibers found for each given length interval by light microscopy for each of the three chrysotile preparations. Fibers greater than 100 jam in length and less than 3 Mm in diameter were found in each preparation. The percentage of fibers present from 5 to 30 fim in length was similar for ail three aerosolized preparations with greater than 70% of all counted fibers falling within this length interval. For the fiber-lengch intervals of 40-50, 50-100. and greater than 100 mih, the percentage of fibers contained within each of these length inter* vals was significantly greater (P < 0.05) for the Jeffrey Mine preparation than for either the UICC B preparation or the Coalinga Mine preparation. Fiber Characterization--SEM The length, width, and aspect ratios for the combined fibers and fiber dusters are illustrated in Figs. 1-3. Figures 1A-D illustrate fiber length characteristics. Those fibers or fiber clusters having a diameter greater than 0.6 m are shown by the crosshatched portions in these figures. This cutoff was chosen because fibers A! samp) `Fi P > P great do tl the i chr\ lengt offi\ simil in C fiber Ft, comi 52% less * the J thee than .Tt Jeffr fiber fiber prep Ti the r (Fig: fibei fiber T= UCAREF00009465 Hometown. Clams. 00 Kleea Ananases C, MO Kbsasito. franca V. MO Utta. Brian W, MO. PM) Sees. Ralph H, MO ABno Part Crat Pedro A. MD Oetoar. Andrew. MO Edwards, Rosemary, MO Sped! Clams 3, MO Jourdain, Uas M, MO Brads WUSaa X, MD Sasfl. Eugene M, MO Stanrield. Baraare L. MO Atom Sank maps. Earl l, MO Hatiht Hagaty, John X. MO AonriOe Carnany, Thomas B, MO Carrel Deborah X. MO Smith. M. Sue, MO Was*. Martas A, MO Rnkrisakt. Sydney 0. MO Nhrita. Donald A. MO Btat Yongdng, MO Ootooa Qawd James, MO Ootoon. Lynn H, MO Bale Cynayd forest Jean U MO Meyers. Kart A. MO Urt. Amass A. MO Yaren, Noamt tana, MD Bearer Septa. Combo M, MO Marcus. Gary J. MO Mia. Tas C, MO Rate John Oi. MO Hunter, Robert Grey, MO Schavmt Harry A, MO Badtol Part Preplan. SutodansUM) Schubert Erie 0, MO Bant Edward JL MO CNaks Jamas M, MO Ftotar. Joseph K, Jr, MO Sonatez. ROM 0, MO Hat Leon A. MO Longa. Sana. MO brit Ronald 0, MO Lufeazaye. Thomas A, MO MBareus. isidora. MO Over, Jorge M, MO K0MB&&T9 . Oonon, A Patrick. MO Martin. John C, MO TBman. William E, MO Bbre Bali Uebarman. Jill MazzeL MO Baottaryn CampOed, WllSam N, MO Bowmmmflle Lane. CL OarrelL MO Casa* Augusta 0, MO Kritelar. Charles MO Briatai Stag, Sang Wen, MO Bruettmn VWson. Roma A, MO Bmekrita Hsverty, Gary f, 00 Chaddt ford Malar. Frederick A, MO Chaffont Aagerar. Ernest E, MO OaM HQ Ayres. WHBam W, MO '`^RaregasMagaret M, MO HoRoaa. Howard L. MO Rarnkst Constanen A, MO Batin. Arthur A. MO. PhO Laws. Janas. DO Sparer. Haney 8, MD Cteriea Pudrett Jamas L, 00 Osrts SatmnS O'Connor, Jamas J, Jr, MO Ross Gary W,, MO CtesrtMd KaruardL John F, MO Real Michael P, MO CstosrriSa Casas Angelina W, MO Oaure. Saw S, MO Barer. Susan M, MO Bryn Mawr Hauaman. Oarid H, MO Hetan, Sarnia A, MO Kaahgegiaa Albert A, MO, PHO Ladcnlh. Ckariae r, MO Mguat Namasto U Jr, MO flatrs. Btasaapa 8, MO Strands Paul V, MO VWRams Jamas R, MO Kbit Yang K, MO Moon, Sangpu. MO Plrreha, Ankeny M, Jr, MO fatdas Judus MO Lasts. Linda S, MO IMmk. Baorge E. Jr, MO IMas KsakL C. WSaren, Jr, MO Mtelalak. wnam A, MO WHkta, WHBam L. MO CareM AMtuntf. Nat* MO JanUns Rosamay, MO Maas Anthony E, MO Madgris Rcsano. MO Pores Judai w,, oo BhaaenajL Susaaa 1C. MO Syak.TanaataAZ.MD Carilsto Oiana Oudt-Kyu. MO Crist Hiery S, MO Smith. James M, MO CadarRas Canon. Margaret L. MO amt Oarid A. 00 Care. Poor j. Jr, MO Faring, C. Jantt MO Gates Aicttonadea 0, MO Hatred, Husan f, MO Mms John J.MO Ptacucd, May f, 00 Plates Rfchard It ngooL ffichad M, MO Sehuarch. Corral MO Wash. Gaorgs E, MO Oaky ZofrreUs Matare. MO Oarea Moreno, Catos MO StynansU Mat 3, MO Bailee hare Hnrireley, Vaugtn C, MO 417 PENNSYLVANIA Schaats Heinz G, MO OresstMB Chet John A. MO. PhO Mattlaws Uwrenca M, Jr, MO Marts Stover A, MO Oi Sals - Costs Jose M.L, MO OtSala Surioa, Gregory A, MO - EastSOwdrtsrg Cana Cann&re J, MO Grusiks francs A. MO Itatoy, John P, MO Akmaa Arthur A. MO Banal Chates P,, MO 8mm. John M, MO Oorman, Sandy A, MO fonrecs Cartos A. MO Saute X Oauda MO Haads WQEam A. MO Satoato, Wtoredo a. MO Otaaud COy WOtans Kail E. MO Aaaar. Robert A. 00 Matotoatos Thaodore X. MO Cota Peter Christopher. MO Mp Swnbaa Rfchard E. MO Frankta. Normal MO Gerran. Amono L. MO Jktgns Xamtok K. MO KhaiRHa MO Ktaraa Oawd L. MO laa Henry AC, MO Rate Mary . MO ftanredewsM. Jack V, MO Zlagtor. Thomas A, MO Tatoma Thames &. MO Wtaoa Stoven Henry, MO fart Wasktogtoe CaMaaa MO Sadffl. Rabam Sains OO Onto. Bridge! A. MO Skareart. Jotor W, MO Suk. JlnH, MO Crtapaa John W, MO Mondsir Magdalena 0, MO at up graM a mm tits UCAREF00009552 a os t UNsCTMxi []>)so <oo' COAUNGA MINE CHRYSOTIIE sn sow ItNGTM (no) s-io SO 100 liNGTM |,,n| FiO. (. Frequency distribution of length for combined fibers and fiber clusters in each of the aerosolized chrysolite preparations. (A) Jeffrey Mine chrysolite plotted on a linear scale for length. (B-D) Chrysotile preparations plotted on a log scale for length. fiber clusters, each as a separate category. The fibers and fiber clusters are ex pressed as numbers counted per length interval, the percentage of the total found in each length interval, the cumulative percentage, and the mean diameter of fibers or fiber clusters in each length interval. The fibers and fiber clusters for each preparation are also expressed in terms of their respective aspect ratios in Tables 3-5. A comparison of Tables 3--5 demonstrates that the mean diameter of fibers or fiber clusters for any given length interval is similar for the Jeffrey and U1CC B preparations. There was no fiber or fiber cluster measured in either the Jeffrey or UICC B preparation that exceeded 2 jun in diameter. The aspect ratio increased for both fibers and fiber clusters with increasing length in the Jeffrey and UICC B preparations. The Coalinga preparation has a similar mean fiber and fiber cluster diameter below the 5jtm length interval. However, for fibers and fiber clusters longer than 5 fim in length, the mean diameter in the Coalinga preparation is significantly greater for both fibers and fiber dusters compared to the Jeffrey and UICC B preparations. In general, as the fiber or fiber cluster length increased in the Coalinga preparation, the width also increased. The presence of "thick" fibers UCAREF00009467 UCAREF00009468 UCAREF00009469 001 00 0 080 001 to P A M ici.e S i z e D i s t k i s u i i o n o p UICC U C iiR v s o r iL e i n t h e A e e o m u z e d S t a t e 17.0 0 .2 17.0 9 9 .8 0.19 0.30 Nantibrout particle, a * 138 CHARACTERISTICS OP AEROSOLIZED CHRYSOTILE 43 ocoeoQogoo o o a o a c o og o. 9SI oooo^ooee **3 oooeoomn ^too- e- -' - d5 on -- o -*3 eedo^ogdco tn P4; 0 1 - -s- n v3 eeonnovoee " V\ 0b s g2 -- on q OMMpoooeo nwtt = ss 4 no X 5c d -?3 'n n f d d 1 S^o nnoooooeeo <r 2 2? gooaoeoooo 0o 9 *V^ ooocoooo o IgOOi TeooQ< -- --n C^ BOOOOQ UCAREF00009470 UCAREF00009471 *Noflfibroui particle* n 224 N uiabef characteristics of aerosolized chrysotilb 45 tit diameter and greater than 5 m in length. The criteria for fiber-Tiber cluster counting by scanning electron microscopy includes fibers of ail lengths and diam eters so long as they possess at least a 3 to 1 aspect ratio. By these standards. 75% of the fiber-fiber clusters in the aerosolized Jeffrey and UICC B preparations counted by scanning electron microscopy would not have been counted by optical microscopy. For the aerosolized Coalinga preparation, 60% of the fiber-fiber clusters would not have been counted by optical microscopy (10% of the total fiber-fiber cluster number exceeded the 3-jxm-diameter limit and 50% of the total fiber-fiber cluster number was less than 5 fta in length). Nonfibrous Particle Analysis The elements detected in the 50 randomly selected nonfibrous particles for each chrysolite preparation are shown in Table 6. One half of the nonfibrous panicles analyzed in the Jeffrey and UICC B preparation samples demonstrated the pres ence of magnesium and silicon only. The magnesium-to-silicon ratio for fibers and fiber clusters analyzed in all three preparations ranged from 0.62 to 1.34. Although not a means of identification, panicles with a Mg-to-Si ratio in this range are likely to represent fragments of chrysolite. The percentage of panicles possessing the same Mg-to-Si ratio as chrysotiie is 40% in the Jeffrey Mine preparation, 52% in the UICC B reference sample! and 20% in the Coalinga Mine preparation. The particles with low magnesium-to-silicon ratios of 0.30 to 0.40.-found only in the Jeffrey Mine aerosolized sample, may represent talc particles. DISCUSSION Two of the chrysotiie preparations designed for experimental research and characterized in this study have not been previously studied in the aerosolized state. UICC B chrysotiie has been studied extensively by both Timbrell (1970a) and Beckett (1973) in the aerosolized state. To fit the Coalinga Mine and Jeffrey Mine samples into the spectrum of chrysotiie preparations available for experi mental inhalation research, UICC B chrysotiie was used as a reference to link the present study to the work carried out by other investigators, in particular, the aerosolizarion studies of Timbrell and Beckett. Although differences exist in the manner of fiber collection from the dust chambers and in the preparation and analysis of samples, the studies of Timbrell and Beckett on UICC B are compara ble to the present study (Table 7). By light microscopy we found a greater propor tion of the fibers falling into longer fiber length intervals than did the studies of Beckett and Timbrell. This difference may reflect differences in fiber preparation and/or counting techniques. By electron microscopy, the results of this study for UICC B chrysotiie are nearly identical to those of Timbrell for the distribution of fiber lengths. Beckett (1973) used SEM to determine fiber length and evaluated only fibers longer than 5 f*m. When our present results were recalculated and expressed in a similar fashion (Table 7), we found a similar pattern, but propor tionally fewer long fibers than did Beckett. Some of these differences may be due to differences in the manner in which the aerosols were generated and the samples collected. The Jeffrey Mine and Coalinga Mine chrysotiles have been elegantly analyzed Number UCAREF00009472 / 46 PINKERTON ET AL. TABLES Elemental CoMfoamoN op thb Nonpibhous Pakticles in each Chrysqyile Preparatiok* Percentage occurrence Elements detected NaMgAlSiCa N*A1 NaAlSiKCaFe Ms MgAl MjAlSi MgAlSiKFe MtAiSiCaFe MfAlSICrFe MsAISiFe M(Si ratio MaSl-0.3-0.4 Me to Si 0.6-1.1 Mg to Si - 1.0-lQ MeStCa MgSiFe MgK Al AlSi MSICl AiSIK AlSiCr AISiFe AIK AJKCa AlCr SiCr CiCr Cr Fe None Jeffrey 2 -- i z 4 14 2 -- -- 6 JO (41 (40) (4) -- -- -- 6 2 _ -- CM 2 2 -- -- -- 2 2 UICCB -- -- -- 2 -- 30 -- 2 -- -- J4 (-) (32) (2) 2 -- 2 4 -- -- -- -- -- -- -- -- -- 4 Coalinga 6 -- 4 -- to -- --2 2 20 (--) (20) t--> -- 6 -- 14 4 -- * 4 2 -- 2 14 2 2 4* -- -- * 30 random nonfibrouj particles were analyzed for each chrysolite preparation. * May represent a contaminant Grom the rotary blade used to aerosolize the preparation. by others using the sample preparation technique of fiber dispersion in a liquid medium (Wylie. 1979: Campbell et al., 1980: Siegrist and Wylie. 1980). This type of analysis is satisfactory for studies in which the preparations are to be ingested or injected in suspension. However, these studies do not provide an adequate characterization of the asbestos preparations for inhalation studies since the pro cess of aerosolization is generally less efficient in fiber dispersion. A case in point is the Coalinga Mine chrysotile preparation. This asbestos preparation was characterized by Campbell et al. (1980) using fiber samples which were dispersed in a liquid medium by ultrasonification for 10 min. The samples were analyzed by transmission electron microscopy. They found that 2.1% ^f the total chrysotile UCAREF00009473 CHARACTERISTICS OF AEROSOLIZED CHRYSOTTLE 47 TABLE 7 Fue* Length Distribution--Optical Microscopy Dispersion Percentage longer than stated length (jtm) Preparation Method Study 4 5 10 20 40 UICC B UICCB UICC B UICC 8 UICC B Aerosol Present 100 68.2 Aerosol Beckett" 100 32 Aerosol Alcohol Timbrel? 100 22J Timbrel? too 46.9 Celloidin Timbrel? 100 33.6 Fiber Length Distribution--Electron Microscopy 404 11 tt 21.3 16.9 12.6 3 1.7 7.0 34 Asbestos* dispersion method Instrument Study Percentage longer than stated length (tun) 0.2 l 2 3 to 20 UICC B aerosol UICC B aerosol JEFFREY aerosol UICC B aerosol UICC B aerosol JEFFREY aerosol TEM SEM SEM SEM SEM SEM TimbrelP Present Present Beckett" Present Present 100 73.6 M. 27.0 9.6 too 88.2 64.2 234 6.7 100 83.0 J0.7 24.9 8.0 3 10 20 30 30 100 43 12 6 100 26.4 7.4 2.3 0.8 100 32.1 10.8 34 2.7 3.2 1.9 2.7 <0 l * From Figure 1a in Beckett. 1973. * Modified from Tables 6. 7. or S in Timbrell, 1970a. panicles analyzed were greater than 10 pin in length and had a mean diameter of 0.42 iim. In the present study using aerosolized samples drawn directly upon Nucleopore filters and subsequently gold coated, it was found that 34.0% of the combined fibers and fiber clusters or 28.1% of all panicles (fibers, fiber clusters, and nonfibrous panicles) in the Coalinga preparation were greater than 10 nm. in length and had a mean diameter of 2.92 /im. In a subsequent study by Siegrist and Wylie (1980), the Coalinga preparation (referred to as short-range chrysotile) was characterized for panicle size distribution by both transmission and scanning electron microscopy. The samples were prepared by hand swirling in distilled water and dishwashing liquid (for SEM analysis) and-by ultrasonification in water for 10 min (for TEM analysis). The results demonstrated that by both SEM and TEM more than 90-93% of the panicles were less than 10 /am in length and more than 93% of the panicles were less than 1 pm in diameter. In our study using aerosolized samples 71.9% of the total number of panicles were less than 10 pm in length and 68% of the total number of particles were less than 1 pm in diameter. The differences between these two methods of sample preparation and analysis UCAREF00009474 Fig. 4. (A) Aerosolized Jeffrey Mine chrysolite collected on a O.I-nm Nucleopore Alter and gold coaled. Bar - 10 pm. (Bl Aerosolized LilCC B chrysotiie. Bar to 4m. (Q Aerosolized Coalings Mine chrysolite. Bar < 10 11m. Examples or' a Aber (short arrow) and a fiber cluster (long arrow) are indicated in this micrograph. 10) Higher magnification of ah aerosolized Coalinga Mine chrysotiie fiber duster demonstrating the Abnltar subunit composition. Bar l 4m. U CARE F00009475 UCAREF00009476 / SO PINKERTON ET AL. suggest that either uitrasoniflcaiion breaks down fiber bundles into smaller bun* dies and fibrils or that fibers tend to cluster in the aerosolized state. Other inves tigators have shown that uitrasonification can result in the breakdown of chrysotile into smaller fibers (Spumy er al., 1980). In addition, clustering of fibers caused by the aerosolization does not seem likely since the Jeffrey and UICC B chrysotile preparations collected in the same manner as the Coaiinga chrysotile have distinctly different particle size distributions from that seen in the aerosolized Coaiinga preparation. The illustration of each fiber preparation on the Nucleopore filters (Fig. 4) also show a distinct fiber morphology for the Coaiinga chrysotile compared to the Jeffrey and UICC B chrysotile. Some of the differences between each of the chrysotile preparations were also reflected by the gravimetric measurements taken of each chrysotile aerosol in the exposure chambers. Comparisons made between each chrysotile preparation of the ratio of respirable mass concentration to total mass concentration demonstrate a distinct difference between the Coaiinga chrysotile and the other two prepara tions of Jeffrey and UICC B chrysotile. It would appear that compared to the Jeffrey and UICC B fibers the Coaiinga preparation contains a greater proportion of particles which are captured in the elutriator system of the Casella sampler and in the precutter stages of the Cascade iropactor. These fibers and particles are captured because of their greater mass. Using scanning electron microscopy we found that the range of diameters of fibers and fiber clusters was greater for the Coaiinga preparation than for the Jeffrey and UICC B preparations in the aerosolized state. The trend of increasing diameter with increasing length was found only in the Coaiinga preparation. Fi bers and fiber clusters greater than 10 pm in length with diameters exceeding 2 pm were present in the aerosolized Coaiinga preparation while in the Jeffrey and UICC B preparations no fiber or fiber cluster of any length exceeded 2 pm in diameter. The characterization of chrysotile in the aerosolized state in terms of fiber length and fiber diameter is paramount in understanding the nature of any prepa ration used for inhalation studies. Although the physical characteristics of a fiber may not be the only factor in causing lung injury, fiber diameter and, to a lesser degree, fiber length play key roles in the potential for a fiber to reach the alveolar regions of the lung where injury as a result of asbestos inhalation appears to be more severe. The potential for each of these chrysotile preparations to cause lung injury by inhalation can be best assessed by a review of what is known about the physical characteristics a fiber must possess in order to reach the alveolar portions of the lung. Spherical particles below a certain diameter (approximately 3-4 pm) can reach the alveolar airspaces of the lung (Lippman and Albert. 1969). Larger parti cles are eliminated by deposition in the upper airways primarily through sedimentation and impaction as a result of their greater mass. Timbrell. Harris and Fraser have examined the more complex aerodynamic properties of fibers by comparing the deposition pattern of fibers to those of artificial spheres (Timbrell. 1965). In general they fouad that fibers have a similar deposition pattern to that of spheres of three to four times greater diameter. This would suggest that fibers mi air tio dir pr mi 19 en fit ch 19 re: ah T * tl ar dl ro in P' si rt n a a it I I s i UCAREF00009477 bun* wesn of '.hers :ci otili t che n the linga also 1 the n of irate iara ) the rtion 'and < are rs of * the ising . FiJpir. and nt in fiber epanber sser .olar o be y by sical f the can >arti>ugh and s by >rell, at of bers CHARACTERISTICS OP AEROSOLIZED CHRYSOT1LE 51 much greater than l pm in diameter would not be likely to reach the alveolar airspaces although the curvature of the fiber should also, be taken into considera tion (Timbrell. 1970b). Additional studies have shown that an equivalent fiber diameter of 0.5 to 2.0 pm results in deposition within respiratory bronchioles and proximal alveolar ducts, while fibers of smaller equivalent diameters result in maximal deposition in the more distal portions of the lung (Harris and Fraser, 1970). Pooley and Gark (1979) measured the diameter of chrysolite fibers recov ered firom lung specimens after tissue digestion. They found that only 0.00% of the fibers had a diameter exceeding 0.5 pm. Although it is possible that these chrysotile fibers have fragmented longitudinally while in vivo (Suzuki and Churg, 1909), these results suggest that few fibers with a diameter greater than 0.5 pm reach the alveolar regions of the lung. If this limit in fiber diameter is true for alveolar lung deposition and the length of the fiber plays the major role in Ebiogenesis and cell injury, the potential for the three asbestos preparations reported in this study to cause lung injury by inhalation wUl be different. Only the Jeffrey and UICC B chrysotile preparations have fibers which are less than 0.0 pm in diameter when length is greater than 30 pm. The Coalinga Mine chrysotile does not possess this property; instead, with increasing fiber length, fiber diameter also increases. Most fibers longer than 20 pm in length in the aerosolized Coalinga preparations are also greater than 0.0 pm in diameter. Thus, in an inhalation study, more fibers of greater length distribution would be deposited in the alveolar region of the lungs for che Jeffrey and UICC B chrysotile preparations than for the Coalinga chrysotile preparation. At this point one may ask the question, what constitutes a short-range fiber prepa ration? We have seen that the Coalinga preparation originally thought to be a shortfiber preparation contains numerous long fibers in the aerosolized state. The answer to this question should be based on the potential of a fiber to reach the alveolar regions of lung. In other words, is the fiber respirable? The work of investigators who have studied the aerodynamic properties of fibers (Timbrel!, 1965, 1973) and the physical dimensions of respired fibers (Pooley and Gark. 1979), would suggest that the Coalinga chrysotile in the aerosolized state repre sents a short-fiber preparation since only fibers less than 30 pm in length are likely to be respirable. In contrast, the Jeffrey and UICC B chrysotile preparations contain fibers greater than 30 pm in length possessing a diameter which would permit penetration of the fiber into the alveolar regions of the lung. Based on these observations, the Coalinga Mine chrysotile preparation can be considered to rep resent a "shorter" fiber preparation in the aerosolized state. In summary, the three chrysotile preparations characterized in the aerosolized state in this study demonstrated distinct properties. Gravimetric measurements of each chrysotile preparation revealed that both the Jeffrey and UICC B prepara tions have a significantly greater portion of the total chamber dust concentration which is respirable compared to the Coalinga preparation. By light microscopy it was found that for fibers greater than 5 pm in length, the Jeffrey preparation in the aerosolized state has a significantly greater fraction of fibers exceeding 40 pm in length than does UICC B chrysotile or Coalinga chrysotile. Finally, by scanning electron microscopy it was found that the Jeffrey and UICC B preparations pos- UCAREF00009478 t 52 PINKERTON ST AL. sess fibers and fiber clusters which cross a large length range (the longest mea sured was 150 uta). but none which exceeded 2 jun in diameter. The Coalinga preparation also possessed fibers and fiber clusters across a similar length range, but many exceeded 2 jim in diameter. In terms of respirability, the Jeffrey and UICC B aerosolized fibers constitute a mixed short-range and long-range fiber prepa ration, while the Coalinga aerosolized fibers represent a somewhat shorvfiber prepa ration in which very long respirable fibers are not present. In applying the above fiber characterization studies to experimental research it is essential to remember that further manipulation of these chrysotile preparations by grinding (Langer et at., 1978) or by fiber separation techniques may alter the fiber size distribution from that presented in this paper. ACKNOWLEDGMENTS This work was supported in part by NIEHS Contracts NOt-ES-04)CO4 and NOI-4-21-64-BCD. REFERENCES Assuncao. J.. and Corn. M. (1975). The effects of milUng on diameters and lengths of fibrous glass and chrysotile asbestos fibers. Amtr. fad. Hyg. Assoc. J. 36. Stl-819. Beckett. S. T. (1973). The evaluation ofairborne asbestos fibres using a scanning electron microscope. Ann. Ccctip. Hyg. 16.405-408. Campbell. W. 1.. Huggins. C. W.. and Wylie. A. G. (1980). "Chemical and Physical Characterization of Amosite. Chrysotile. and Nonfibrous Tremolite for Oral ingestion Studies by (he National Institute of Environmental Health Sciences." U.S. Bur. Mines Rep. Invest. 8452. Harris. R. L.. and Fraser. D. A. (1976). A model for deposition of fibers in the human respiratory system. Amtr. fad. Hyg, Assoc. J. 37,73. Langer. A. M.. Wolff. M. S.. RohL A.N.. and Seilkoff. I. F. 0978). Variation of properties of chrysotile asbestos subjected to milling. J. Toxicol. Environ. Health 4. 173-188. Lippman. M.. and Albert. R. E.( 1969), The effect of particle size on the regional deposition of inhaledaerosols in the human respiratory tract. Amtr. fad. Hyg. Assoc. J. 30, 257-375. Morgan. A., and Crailey. L. J. (1973). Chemical characteristics of asbestos and associated trace ele ments. fa "Biological Effects of Asbestos" (J. C. Wagner. Ed.), pp. 03--118. IARC Scientific Publication. Lyon. Pooley, F. D., and Clark, N. (1979). Fiber dimensions and aspect ratio of eroddolite. chrysotile and amosite panicles detected in lung tissue specimens. Ann. S.Y. Acad. Set. 330,70-716. Port. F. (1978). Some aspects on the dosimetry of the carcinogenic potency of asbestos and other fibrous dusts. Staub-Rtlnhali Luft 38.486-490. Rendall, R. E. G. (1970). The dan sheets on the chemical and physical properties ofthe UICC standard reference samples, fa "Pneumoconiosis: Proceedings of the International Conference. Johannes burg. 1969" (H. A. Shapiro. Ed.), pp. 23-27. Oxford Univ. Press. London. Rendail. R. E. G. (1980). Physical and chemical characteristics of UICC reference samples, fa "Biological Effects of Mineral Fibres. (J. C. Wagner, Ed.), VoL I. pp. 87-96. IARC Scientific Publication No. 30. IARC. Lyon. Seaton. A. (1975). Asbestosis. fa "Occupational Lung Diseases" (Morgan, C. Keith, and A. Seaton, Eds.). Saunders. Philadelphia. SEegrist. H. G.. and Wytle, A. G. (1980). Characterizing and discriminating the shape of asbestos pilticles. Environ. Rts. 23, 348--361. Sinclair. W. E. (1959). "Asbestos--Its Origin. Production, and Utilization." Mining publication. Londoa. Spumy. K. R-. Optela. H.. and Weiss. G. (1980). On the milling and ultrasonic treatment offibres for biological and analytical applications, fa "Biological Effects of Mineral Fibres" (J. C. Wagner, Ed.), pp. 931-936. IARC Scientific Publication No. 30. IARC Lyon. Stanton. M. Asbesti Suzuki. M. 55.79- TimbrelL V Timbrel]. V asbeset TimbrelL \ sample nesbur Timbrel!. \ Confet Tlmbreil,' (J.C. Tlmbreil.' J. Cm Wagner.J Wylie. A. Scl. 3 UCAREF00009479 CHARACTERISTICS OP AEROSOLIZED CHRYSOTILE 53 Stanton. M. F.. and Layard. M. (1978). "The Carcinogenicity of Fibrous Minerals. Workshop on Asbestos: Definitions and Measurement Methods.'* pp. 143-151. MBS Special Publication 306. Suzuki. M. D.. and Churf. J. (1969). Structure and development ofthe asbestos body.Amtr. J. Pathol. 55.79-107. Timbrel!, V. (1965). The inhalation of fibrous dusts. Amt. N.Y. Acad. Set. 132.255-273. Ttmbreil, V. (1968). A simple dispenser far generating dust clouds from standard reference samples of asbestos. Ann. Occur. Hyg. 11, 273--281. Ttmbreil. V. (1970a). Characteristics of the International Union Against Cancer standard reference samples of asbestos. In "Pneumoconiosis: Proceedings of the International Conference, Johanf nesburg, 1969" (H. A. Shapiro. Ed.), pp. 28-36. Oxford Urriv. Press. London. t Timbrel). V. (1970b). The inhalation of fibers. In "Pneumoconiosis: Proceedings of the International n Conference. Johannesburg, 1969" (H. A. Shapiro, Ed.), pp. 3-9. Oxford Univ. Press. London. Timbrel). V. (1973). Physical factors as etiological mechanisms. In "Biological Effects of Asbestos" (J. C. Wagner. Ed.), pp. 295-303. LARC Scientific Publication. Lyon. Timbrel!. V.. Gibson, J. C. and Webster, L (1968). UICC standard reference samples ofasbestos. Ini. J. Cancer 3.406-408. Wagner, J. C. (1965). The sequelae of exposure to asbestos dust. Ann. N.Y. Acad. Sci. 132,691. Wylie. A. G. (1979). Fiber length and aspect ratio of some selected asbestos samples.Ann. N. Y. Acad. Set. 330,605-610. UCAREF00009480 Confidential Report 29-55 R: 7-8-66 IfrJ ' 7'*+-l (o MELLON INSTITUTE Special Report EXHIBIT 9 tt-W'T7\ The Fibroccnie Potential of Asbestos Proc------ via Intraoerieoncal Injection in Cuinoa Pics. Rats and Rabbits and bv the Intratracheal Route in the Rat Chemicals Division, Union Carbide Corporation Industrial Fellowship 276-29 . Summary ** The resulcs of intrapericoneal administration indicate that the asbestos products studied produced fibroelc lesions of che visceral organs in rats and guinea pigs regardless of fiber length. Of the three products* CMS-100 (refined fiber)* produces the most severe reaction. JT-100 (standard fiber) and JM-3K (Johns Manville screened fiber) produced similar but less severe reactions. The resulcs on rabbits were inconclusive. - Both JT-100 and CMS-100 produced specific lesions in rats by che intra tracheal route but wich JT-100 they were more severe. No lesions were found in che rats which received JM-3K fibers'. . > These resulcs indicate chat these three asbescos fibers may be fibrogenlc by either roucc. No specific lesions were observed in che lungs of the JM-3K intratracheal rats, but only two rats survived to be examined. . Samples The following samples were shipped to Mellon Institute at che request of Mr. Paul W. McDaniel who furnished che descriptive information. Deslcnation of Asbestos Product Source Quan tity H. I. Dace Sample Received / Number *CTS-100 Fiber (same as JT-100 Fiber) Sterling Forest "Standard Fiber" containing impuri ties in che form of clay and magne- cite. A short fiber. 8 02. 8-16-63 26-220 *CMS-1Q0 Fiber "Refined Fiber" with lesser impurities than jr-lGQ. A short fiber. Sterling Forest 8 02. 8-14-63 26-219 -A~- The individual fibers far most part had lengths of 0.9-to 10 microns, but there were some as long as 30 microns and^some that were less than 0.5 micron. The diameters of the fiber were generally 0.3 co 1.2 microns, but cheru were smaJlcr sites noted. The clay-magnetite particles were fj^^ostly 0.5 to J.O mic-rcn* :< .Jjs.t,..- - ----------- UCAREF00009481  r Deslcnation of Asbestos Product JM-3K Pibor. "Long Fiber"(brushed through screen to reduce fiber length cu 1 mm. or less before injecting.) Source Manville, N.J. . * i Report 29-55 Page 2 Quan tity 8 oz. Date Received 8r26-63 M. I. Sample Number 26-227 Intraoeritoneal Inlections Methods Hie JH-3K asbestos was brushed through a 1 nun. screen to reduce its fiber length to < 1000 micra (1.0 nun.) in order to facilitate dosing. The- CMS--100 and JT-100 asbestos samples were used as received. Each asbestos product was pre pared as a 2.52 (W/V) suspension in 0.852 saline. All needles, syringes and suspensions were sterilized prior to use. The animals were divided into three groups--each consisting of eleven male albino guinea pigs (?), six male albino. rats (R), and two male albino Mew Zealand rabbits (H). The guinea pigs and rab bits received incraperitoneal injections of 2 ml. (50 mg.) and the rats, 1 ml. . (25 mg.) of the respective asbestos suspensions. Eleven guinea pigs' and six rats received control incraperitoneal injections of saline. There were no rabbit controls. All injections were made in the lover right quadrant of the abdomen. Tables 29-92 through 29-95 contain the results on individual animals. Results CMS-100 produced the most severe reaction in the form of granulomas with giane cells in six of the seven guinea pigs examined micropachologically. Typical granulomas with giant cells were observed in three of four rats and the one rabbit. JT-100 asbestos fiber produced a granulomatous reaction in all of the 8 guinea pigs as well as the one rat subjected to micropathological examination. The rabbits had incidental lesions unrelated to the asbestos fibers. The JM-3K. asbestos fibers produced granulomas with fibers visible in five of the five guinea pigs examined. One of two rats had granuloma formation which was visible on gross examination. Methods Intratracheal In-lections One per cent (W/V) suspensions of JT-100, CMS-100 JM-3K and a 0.52 suspension of CMS-100 were prepared in 0.852 saline as for the intraperitoneal injections. UCAREF00009482 Report 29-55 Page 3 Famals albino rats weighing in excess of 200 grams were given 1 ml. of the respective asbestos suspensions by intratracheal injection. The rats were anesthetized with saturated vapor of anhydrous diethyl-ether. The trachea was exposed by blunt dissectiou and the injection was made directly and the incision dosed with a Midliael Wound Clamp. Eight rats were injected with 1 ml. of a 1Z JT-100 suspension (10 mg. asbestos). Eight rats were injected with 1 mi. of a 1Z JM-3K suspension (10 rag. asbestos). Because uf Ilia flocculcnt properties of CMS-100, only three rats were dused with 1 ml. of a 1% suspension (10 mg. asbestos). Eight rats were injected with 1 ml. of a 1Z CMS-100 suspension (5 mg. asbestos). Six rats injected with physiological saline served as controls. Tables 29-96 through 29-99 contain results on individual animals. : Results * Specific lesions were found in most of the rats given CMS-100 and JT--100 thac consisted of marked granuloma formation with bluish foreign body material present (magnetite?). Marked bronchiolitis obliterans was noted in most rats, also . with bluish foreign body material within the lesions. The JT-100 rats had a more severe fibrotic reaction to this foreign material. Multinucleate giant cells were a common feature with the granulomas of the JT-100 rats but were conspicu ously absent in the lungs of the rats.given CMS-100. Micropathology was performed on only two rats receiving JM-3K asbestos. Neither of these animafs had lesions similar to JT-100 or CMS-100. Cc^-u-^ (P Edwin R. Kinkead, B.S. * . Research Associate ( 22^7 4 Urbano C. Pozzani, m;s. Senior Fellow Approved: Acknowledgments: ' Technical Assistance Pacliological Examination Data in Book 868, pp. 63 to 90 and 99-109. Typed*. July 11, 1966 - aid ________-______ Charles P. CarpenteryVh.D. Assistant Administr^active( Fellow Charles C. Haun, B.S., Junior Fellow John M. King, Ph.D., DVM, Fellow umi) nwn .......-' , , i ............ "'"M1. 1 1 '' . UCAREF00009483 In tra p e rito n e a l In le c tio n s o f A sbestos CHS-100 s1 2l O u o ci c <*4 a 9 x 41 *a 01 e i*4 6 9 X 9 u O z 439U0 XH9 e -o O C ^41 (A HO bH-h uo 41 gy > p4 O * nu 9 G9 3 9U y 4*0 m9u *3 *3 p* JZ 3 4C1 V6 (68 -H4 US HH --* <0 3 --1 6 9 B 9 H VS 9 VS HU9aO 99U e U yy 9 > 0 9 OO9 9Mi VS 3 4OJ Aa O h 3 C 9 Wi 00 *3 41 ^w0 9 G w 9 > --4 u *0 U 3 VI .u93 Co e O ^4 w U 9 A3H g o -4 3 c 9 u Cl J "93 w9 3I 9aOas we V9I 90sW0 -91 p3CH pOgH490^H4i ^A C3 *H3 O 40 m vs u3 341 40 e(Q u o U **4 41 4>1 (9 C e *h eO H-h ,3 U If) * VH 9 yi 9 3 3 e G 9 *b4 HH Xy u u 9 vs 9 J9 X 9 > *4 s u 4J e 9 ph G oh e h ^h a js ti a uA be vs u 9 O ) >\ _ U* -ft o (9 H S9 * a; aG vU g pcH O yJ -* U V) vs c >% O>4 g .9 **4 V 9 CO O H 9 40 W o99 9 *H 3 o9 X vs 9 e Hi 3 W o y S < pH o 3 a 6 o 3* Q 1U9 40 9c A US B 1OA 3u -- M pH p* 9 VH X1 AH I pH U a. 9 9> pH oj u 00 *>3* i-4* O *-4 X flj * C 00 pH H4i Ae bH OB U* o 3 X9 c w P4 o ah 9 V) a E 9 B oQ Hi PM 41 X 4H ua O Ul e 0 hVI 41 pH 01 9 O mm 9g o *H a c 9 <9 L> 9 i-H 41 VI -o s 9 U 41 > * -h X g 9Q o y UI p9at g US I Z z V) ml -- N4 o ml o 3 41 UU OO Hi Vh4 UI y W > 9 9 9 9 19 Q Q 91 HJ a o -4C0 a o vs 4 e o V) V9 S 3 u *e 9 6 0 >> a 9 u UI VI (0 e o u yo V) > VI 9 Hi 4) 0 10 >*- "x3 to a 9 t>o U4 41 O 9eH BO e04 US X9 X3 >Uv 99 peH pH4 w9 e 9 us -h **4 (Q ^4 ucU *H cac u "3 4N1 vs O Hi O1 e vs 9 3 s 4-1 o o O 41 >o au ^*4 9X Wpl ->4 b O bH HOi VI I* <9 --w uO 04b1 . O4h1 303 a o a a VI o CM Irt r- . a oX MP PH X CM CM CM uVI *4 >Us 10* 9 ou CL C a9 3 US 3 S X-- U9 (9 C 6 Ow ui US w9 Hoi e u p9>HH xp9 #c4 O -3 9 (A U c9 oH Hi Hi VI 9 9U US 5 Cfl X X CM UI O o. 9 3 "3 C u9 4 9 C w 4) 3 o4 VI p04 VS 9 H63i c *3 <9 o pH 99 SX p3i Hi cc 9 hH a o HQi UI c 4oH VS . us pH 9*-- 9 US VS 9 -H 9 9 4H C9 *4* C Hi pH 9B O9 AH U| c HH XX XX XX CM CM Wi 4>1 VS o E VI o u (AH tH4 e O UI 9 VS X 9O 9 4H U< X X X CM US 9 e us 9 3 C 9 X u m 6 O w 9 > 1 UI c 0 pH UI 9 5 < X X X CM U >9 UW pH -H H 0) o O Ob U 41 3 9 AJ 3^ ^4 3 3 e a3 -4 W ee O 9. *3 6 XO 9 3 tu S O9 01 X cu 0#4 9 B 9 9 uO US 5 < X X CO CM I 39 Sf4 9X U9 40 U 9 *3 6 99 Me 96 PH M- 9us X a. 4J 9 "H s* 9 * e H 9 UI X pH 9 PH 9 9 9M C 3W9 H CL U B9 9 vH ui y X a. 9 e 9 Hi hh Hi e9 Q HH P4 -- X 03 zS 93 Uu C 9 9 XC a o 9 pH o us u o 0) 9 9 Xui Jh e 99 > iu 0 UI /* ctn* u 4-* * o 9 H 3 US 9 US *3 OC99 &HIH NJ ai 3 vs 9 9 US Hi 9 >* W a e pH 9 ou pH PC4. P9H 9 3s Hoi AH 3 y 3 ZZ VI o o rX CM Report 1% Page 4 ` 3 9 9 C e c3 A O N <9 9 6x -* 6 CO X c* X X 01 ~4 a o co oo co X01 X01 V0O\ <C s3i: 1-4 o X X 01 o X X 3i pH H X X 01 CM p4 X X 0\ -T pH X X 9> ^4 CM X X CN cu a. a* aJ cu eu cl fip r* aT n CH rn (A XX Cl 01 * H vn CM p-k e yo o vs U h cg I e e cl VS ui c O cm 3 d vW UCAREF00009484 V 7431 8e a O' **1 01 8 C o u 73 u 8C r a (0 X 4) u o / *j u 3 4u8i c8 m***- emu.i *4eN31 <#48419 U O i > eH eH --03O814 C3h303 *4U3U33J C8uO Hu uVu3) 48J p83^ VI C<33 so J454J u 01 8 HHO 3c8U 00 8 a p4 3 3Oam A40o08V<J119I *e83 VI -J 88 c63CooQ3H. JosOw3 PUd cow* <J u8c fp>V4 V 3 m 80O61 C8wo30 -868w10 (C o n tin u e d ) >v 4J p* 8 >C VI 8 Pd Q J 01 U pad e o *o VI AV d c 83 Us C8 8 e0 VI H pd 8 3 73 c 3 8 8 JO 8 > at O o 4J IQ Q. o09il O U O .a C 8 VI H 86u O3 *8 U a 3 mS 8 8 eo > *-e u 3 O w s(0 e3o 0t&1 JuSo C J 0o1 3 a. ^ *3 4) 73 431 3U Uai Ww (0 O 4/ CD C O <a U ID J<4aV31)I 8 k8v 6 C **4 Pd 8 *4 w 41 u 2 e 8 J J35 O VI --41 3 1 H -4 8 * Pad 8 C >d 6 o 73 .3 (0 7e3 -7 u(0 Uc 41 * 8 c 8 >% U 8 44VeJ1I 46) 4) 4) O c VaI (A 41 O0a1. <ow 41 U 8 w pj #3 8 u) 3 C6 Q ECU) caVN03I vO*o0H1i Vv304e11 -3U08O1 u *&33 "0wC3J C -^*wi C JJ O v <u Juu3 c*Unq O V wO UO y >td( , S'3 S* Q O Cfl 31 CO 33 33 pi oo lA C4 00 m (S 00 GO V7 V> CM CM r* Od 83 a js i> <A oo r-* \Q e\ CM 8 r7 <* O n *o VO vO C py >y D* *T <^ ec os ac os ac $4 V> M ac o c8i s8c 0ccoa1i. V Rporc 29-55 Page 5 UCAREF00009485 In tra p e rlto n e a l In fe c tio n s o f Asbestos JT-100 9 OwC ul > 4 09.1 o8(01| u c kl 9u1 Q O >h< 4* lu| 9-Au L**' Q>(Q% a94J vmU: (A * 8 (A 6 *O9 a 3 *4 1I 3 <9 e9 B 8 u 9 8 8 U | rt 3 00 B 8 B H 00 <H 9 U 9 U < 9 9Q I 39U B (M 8 W "9 QA 9 U ko 00 CM 60 u >V 3 9 68 3 8 UI 8^ 8 60 o UM OA 9 3 8 aa 4 9 X 8 M 41 A0 8. 9 8 86 OB9 8 n .6 (A 41 u 3 41 M 0) 3 *-< a qa .ug # 4i 0 M U 9 8B 9 9 * 8 9 8* <1 C HU 6 9* 9 2O 3 9 e *.4 8 9 4 9 U O 2 T3 9 6 HU a 9 X 9 u O 2 5oc. a -e S b H >S Q 9 4. 41 8 3 O Uu 2 CO 0C 9 M 8 M 3 9 M 8 9 A 00 U 8M 9 41 2 M 8 9 (J 4 HUM 8 3 O C. U >4 WH 39> 8 H 8 44 9 9 <J 82 9 8u e 9c seo ou 3 9 8 M U9 9 uaU 9 o M 2a 3 <H > a 8 Cl > uu ceou in H> --i3' o -9t SU to 9 2B9 u VMe -o9a< uc0) hl (St -UH O. Veia - M H M 1H *4 *3 V 3 2o**a>* 2o H U 8Cc o 4e8(k9I1) Cm Cl M(UC>4S%W*9W-4 H aQ (o0 ow 3 9 9 (0 (o0 2w(004 (<09 (p0* m *4 c >* m*< >(U3 t*e(0* f= 9 u 9> 9aCUO 2C9H* 3 u 29 3C9 o^ 40Q0 *Ma3 3<U4 -(MH9 U 4J A"V38 CC>l o CCa3 a98 J49S4 CM O 86 -O9 23<99 <9 U9 9 (0 M > 0) fP--44* 93 *4 -9eu A3(5C9 -9u* U C Cl > u --4 C8 3Au90 p4 9w w9e > A40J *CM 8 4-1 p4 Vo&e)i uO'On 04 U U kl 3 ^4 awe.i S U4me4i 204 >> 19 23 O 5h Hc1U 8a3 HBU >to 4J A O -m U(0 8 uO .u a> (a0, 32*4*3UJ (eo0 p(<044 (9 tu 3 0>1 >u (39 8e H *B 2 3O M -a o 01 ^ 2c *u9 0to4 Uc e04 04 p `M <9 (U9 41 9 3 c04 > HU 8 4(01 O8 * -9 <9 28 4* u VeI O (0 A*4 o (0 JO O (9 *9 *99 <4M1 8eo ^haU. 3 VI Mcj 4i 04 e hu B (0 2 3S uUo0>1i Oft <9 U aUaoO H-run&3*m 4(0* p1U0 O 0a| *9 5<9 9 4B 064 2O e u04 Soo 8 u)w4> ob<ue49e J- 3 O. (9 W9V (0 H84 9M O C 9 O..04 flU 8 J3 04 8 O 4* O Na U a P< VI s A(8M0 "99 8 *CJ 8 O8 U 8> A8 44 *9 B (A 8 >u\ *COu^i 88 41 JB B *9 8081 9 8 u9 p-9. C 98 C *u** OH (0 B W8 >4n4 e3 8 9- 4* 3 e - O 4(aU01*) 9B *8o9 9a. 8 a a Q to HH ampM 80PM0 0M0 (A (A VI VI vi w NtnoO N0CNO0* Nc(NoO NO o<Mo 2cco* (A >9 NCO p* u <S0 29 cI <4 2, <<NO"OojNr* CL 2t2OnN a. O02OO0NN # a *<0AO<3nNr 4 a it0AUnn0N PrxH 0AO0 cNOOcoOnNN o CAOON CvaOOx Q2O on a a a a vO a\ o96u oU aa c9 (8A Ui Uc9W01'` UHI m4 O.^ >9 9 93 V8rf U 88 41 b 9 U 4J B6 0U 9C4 e8> 9 U 41 C * ueo ^9 wT O6 C. 9 9^ 9 O9 >% A 9w j9; -9o ou Uu9>O 9w Co 9 9 >* 9^^ (A u 99 (A * W9e <A t/1 Oa PMH fCHN AO ON ON .- , Report 29-55 Peg 6 . 8 5 u m u0 8 H8PN| P-S *M o ta *-i s8 on wN HO8CU 9a939 UCAREF00009486 (C o n tin u e d ) e3 19 Ueo COi *JO33 3 -O ^ e0w0 33 3 .*sCr4 6i*sd *6pa4 a* S4 tXo 3 4t 41 *4e*41 xa8 41 4) Uo <n O sO sO: o w3 3 e *3 4) 0) U 4) * <H0 o U >> "O d 4d <3 OM <c0 u A U(0 > 3 >k -4 U w > Ok o 0 u* a4) (A 441 4 4) 4J e (J c 4) o wd 4J 6 UO VI 48i 3 T2 X w 3 . (A d C.O 3 ft 41 w 4d H o Cl <0 (A O U 41 u c 3 VI -*d 0* 4) > 44 .o2 W e VI "O Be-* V) o 4J > < u VI 3 V) <J N *4 84 -3 4J 4 3 ** 4) H 3 * e3 N uC 3o O c. 3 40 TS 3 3u e'.O xo 3 o O 4J e o 85 4J 41 Ad 3 u Jg 00 3 6 w Q. 41 4J ^rv O Q 3 4) e o < C. Co VI 4)1 4J tM .C M <0 u u 19 u 433 Q O V) Q <3 oO O no O n *4 <M a VJ N CO sy m C4 U 189 J4O1 s i < Ai O V) <r ts (A m in in tn 09 09 ec Xm M o -e eowcw 00 4) li 6) Q fl 0wC 3Mw r* * vO . u so ON m jr 04 Report 29-55 Page 7 UCAREF00009487 c In tra p e rito n e a l In je c tio n s o f Asbestos JH-3K o If 1' 0C; s Cil -o 91 'eH *a9 J991 44 O 2 *C3l 091 *CH 1C4 tXS9o1 -X5m91 uu 0A 20; w--4 >1 o X. 1 9c1 ;> M0 -9Wka1# 91 1o0 30 <e1 mmt 0 ^4 -A6o3 0 W 4u0941 e 40U4 9>31 40k4 9>e1 ft.Ml a O 00 ! 0o u c: 4o4 0 0 XUI 06 *9 *W0U63) M0GOir4t <9 C X 91 hH 0 UI "O((J *co u 03 uu0* i449a0HeJ1Ji TMcJi 4M94 a0* CU *-* <n O wQ 3 0 44 bi a a a 03n 00 0U O Q CO <o <r x M 9C1 *9e31 9a1 fCj 9X(s91 X<s9 91 6a X01 u ZO u Z0 44 0 X J-*a9UU0o321t 4991S0 C<h9 Ou u 73 .`XGO60 g 0s 404 U) 0 'J *o m* 44k994J11 0 o0 b<9 M e 91 3 >. O *C(*9* 6O x3 UUQI u91i XUI 3 <U9 pH 0J Obw 9| (9 <9 <e9 X*o m ui I ^ U WC ci 3 *H MM oe u Q X(9 u V)I -4CH4- i VI O +* 3 91 M fM9t1* O MmC s *"A4OU004* 33t 0UAO 44 00 6 10ce-4 v0i 33 U0 --0 U3 pj 00 03 "O 4J A0 0 404 33 h0H 0U 404 CC4- u 0 3 -I *0e4 0 0s ~o4 1c 0u 0*4 H4030B30OC4 l'4C0*00UBO4 t40W0e0>)4S U0 90 ** W0 a -a m(14 NOM e 0 i0n 0 3 4*4 03 0 30 -4 0e 3 3O ~u *40044 44 -4 u o S30 900 J40S44 a 0 0a -0h C3 U0 90 3s OO3 *e0m8 0U Cot Report 29-55, 44 3 0 0 U0 Ok M4 *0fHcj 404 0 E *39r40 0U 1O44 **1b40e040Ua9P0013He00Ok0qaU444440Ip*003cO0a000ue3e0c9wH0o0*fVXM*0700Oa000O0o03v3aw30-40fHHPri*4tifk<ple00a0bO0iB00b364k090be0eHOJ444m0 QH pH * 0 E5 c0 3 0e04 g 0X pp>HH 40P4i 0e u 0 0 z0 U0i 73 c0 g4 :; 0x 0 ua z age *3 05* <gH 0x 0 u 0 2- 8 g.B -a -a Oe O5 --C1 *C* *f-4> --4t 9 e# a n<9 it X U U eV e| yo yo 0ui u0i Z2UU .w03 4O4 00 k *0c4 0 44 H--3* 0 u0 6 0 44 <o44 03J 0 * 2O6x 4cS34 00 x2 So 0 ^0 *4f04t4- " JuS 40&O4 *3s3?* 0 * 4 0 0 0 30 --4 0e 6 0 0 44 .930 U 3O . 40w4 o00Ok a *4 u 0cH >04 S *4 *o3 kol *004 e pHH 0 a pH 0 *4 M0b e 30 0e o* 0 X0 5 u0 90 4o4 M0 f* 0 --474> 0c o4 0 X0 *c004 ao X 0 H 4V04* e 0 3 B 40M4 M2 C 0OCk a0Q *03 X 33 0 13 0 0*4 404 s 0EO >40*44 4O4 3 0WM 0p 5 *004 0e014 ^p*4e 0a m0Cm PH **-3P o0a 09 0 b0 H> 99 X pJ * 4>4S 4 > 0U pH Q u0cO H4eQ4 u 10H *0e0 - H <44 b0 0O* C 40H4 0 40O4 44 0 X000 40O4 0 0 O X00 z< *b 91 JkS/ X404 404 lo 'TO 0 0 u931 0 w3* 91 44s41 UI -3 6 44 91 e b 0 0 404 ge 3 0 0e 44 0 404 kcH *i0H c 06 C03Cm pHH 0a pH 40u4 e 0> 0e*4 , 0 e 0 6a 0c 0 PH u0a 404 O0i -<e49 6O *3 X <9 ^ 9W1 kII oS g a3e. *3 U <9 pNh >Ns w41 Q k90 <3 2(9. *B34 cu 6 O 91 x O 0 oC -04h1 x-a < e 0 *UOH 9i u (9 Cl **9H01 -ma X Q X a 00 V0 CO to sPCOOI CO nNC3O CO CO CO \C<3MO VCCOMO XCCMO CO a 0 af*. N Q VA cn X 0C7 <M ft O Cfl M T ^ O Nn NCT lNA WNN <9 b, 1x eI O<NN CXO o r7 rn O n CO 00 XX 0 X CM 00 X 0 ao <M OO X ON CnaMo XCN n<M XXON rOCXoMN XCCXMN rCsM XOXN 00 vO c\ < asi ftk A* ftp * CL CL S' UN cm p-% up eo O NH t pH coVjI e Q. O_> N c^3* M<rsJ3. Orx*-' X NO ON 9) X CM CM CM XX M O 2B $X9 n X 00 ro CM pH P7 x X X UN w-l O X O sf 2 OC Oft eft o ^eQ --* 0 e00 e cCi 9ccV1I. UCAREF00009488 In tra o e rlto n e a l In je c tio n s o f S aline C onrrol h u -c Cl a VI V) w CI > t0J1 ' 1? e <9 --4 U4 19 O -*0* w5 VI 3 0 e 19 8 a a 0 0 14 3 01 VI 0) b 91 e 8 C 0) e >1 ^4 <9 <-49 0w H M H a c u ans X 01 s (9 X a 6 <9 X or 6 (9 X p(9* 4J 01 e 0w1 w01 0 e a or a c u 4J 0 SB u Q SB 4J O 25 w 0 2 0 VI VI tu 44 19 O V) e Q. a a M 4 ** t . *1 -- -4 . 1 .-4 19 a ui a 3 la C u *uh 8 w 0 c vi 0 is e u e a >* >S --1 --a W c as H *4 ^4 <49 mi m49* LJ ij *+4 aH 4) see aa0 3 ImS IaS xb VI VI US Ul CJ hi oe Bae 8 a. via V> M W (a9 VI O Q o O * 01 e a e c *0 o 9e1 xVI >*n >s *>*s >s *-1 *9 B *-4 pH 5 (9 <9 <9 (9 ('X9 8^ *Up4 *UP4 *U*4 *UH 01 *h c c c c VI 91 QJ 91 01 u H n IS V) (A zO s9uISuISuISuIS o wo a (f) u w >s J O a a mi Q ex vai (9 (9 as Uu QO ec a B a *x4 a4s a pH pH c 0 pa4 u a*4 u 6 C6 a a a VI a VI c V) VI c hi US a Jau3* Cu V0>)Is *cos p4 X Q>J xu aaa Xo 9 9 V) E 6 - U U 4J O O i- ccu 4 *3 > >s X CL >* H a ph B 4-4 ua a a a 4J *aH 44 U4 a <Un u a S us N H a e a a a us s a a a us C aw X U B aa a UJ Q Q O (A V) V) cn co cn vi 00hv0\0 HV) prs4 CoH 0N3 <CMO S0O0 O-J X n0 n0 N0 CNO PCO4 GNO NQO <9 01^ u|5 X 6 es *0 m 90 N ON a V") m a a a 0B 90 90 CO CO CO 0 NO vO vO vo <0 0 ON o> ON ON ON O N0 GO NO *7N m4 (N m \Q X NO N0 GO CO GO GO O o sO N0 ON CN ON ON <^ cu flu CU flu ol flu CU X ol ol Op eo s e&3l a 13 o Seu u5 000 u bse a X p>H% S* >s >v Ha4 B a a up4 <p4 a --4 4J M *Pa4 u -- a u ** a* u e *B 3Q aW cX B a a a a a a a b a a a e a a a cu u Ul US hi U Ifl W Ifl Ifl w ca- oo 00 00 aa Ninmininn H N N NM N * cn ** o n f>* 00 to n m m >r *r m in m in T O' T ^ T os os os os ee ee I Report 29-33 Pago 9 Qv rg I c UCAREF00009489 I v o es ""-*e2oe aa <3* 3c e u CW *0. x44 au o VI ** X c3B -50H1l c99 xWbo TO ja r-4 Cl 3 U CuO taS M30 Oa60OeM V9> 9 <v u * a 1 *J <3 77 C o VeI oH w Mo QCU^CO <q 0b1 a C9l felu to 9U s 031 ae. X-4 Q . #99u o*u xu e *Qb *c9 9 ^u b a 73 > u C 9x9 9 * 60 Xo Mo M "H Se 4 <yhVI ug u U -4 9 VI COMO B 901 0uol*nyX C00 9b 4041 eob auOi xm9t W9u 0 b* m4 4> S SS 9C1 vaB> ot*a X9 9b ^3U 00 M X -* >c(HaSnA* 9 e ue -MrBOHa <7e>bU>19 3w S Ub19i O--.3 -b n t<ol bc3omVh c u a. 3Bm <W*i a H vx s1OsJ u"t ><-9 a.-u* HU U| 3 z t2a ba> 1aB 9(WuUA *3hue 3uO a eow 0 3c 9e 09) AO 99 bU CO u41 031 H*M b dQ 4041 o Cl 0| -BO C9 C9MC3O*4Mb0U41 M XO 9 U M 44' M9 9 y C u01 9 -y4* * O 9 ^c x*po4 9a 9 9w m44 *94 Miue 9G.*Ol CO 41 X 44 U 0.9 W 9 01 X 494 3O CU9 0b0 99 m m m a vo b *H 9 o 01 x Cl M 4y4 Ue a 9 * 9 a9 Ow 9 **4 U00 9 a CO 73 9 9 VeI 01 u 60 eCO 9 01 9-4 3* 9 4444 3 f*4 C VI 9 9 4J 9 i 8 b3 CO O C 9 --O1 9 XU 01 CO 01 3 3 M 3 44 C O CL O * 9 b m U w* b co 41 a 44 M X 44 X O 33 Report 29-5! Rage 10 In tra tra c h e a l In le c tio n s o f Asbestos CHS-10Q to Rata 9 eu 9 9 O W C 9 ^4 9 H ee oo aa 33 41 CJ ec flu cu 01 u Cl oo (M X 9 44 b ere ere >s 9 <4 re oi re Q n o 04 a o c/s 01 re Xca Xn X 9 X OL SC, QO co (*Hw g* o e 3 41 e & u e o|4 X o ere o 040 04 K>o0T0 o co -- 9y 6C to a E uC Va) 0 w0 9w P*A 9 e b O 6 *o 41 73 b 01 9 N 01 44 ru 04 u 99 X1 "H f 3 CO S6 93 U pJ 9 C o H 9 9 9-4 O ss * 9 CO 9 9 e CO *e 3 a e -4 3 o s e 3 -re e 01 01 94 3 73 M CL U U *94 re oo u U UM Q C 01 y p e o b -re H a > 3 bpa 44 Q O 7U re oi ue G X X CO flu a vs CM o a ore o 9 ore co vs ere ore ao o& o as oo 00 00 04 M *4 ay y Cr9re4 ^c0-n4 r* oo tn <n sT eo* 9 Ua C O 0c1. 9 *e2 93 9VN 6 C<n O 9 WO a aa on Nwn xN CM N axOo xOa r* ^ UCAREF00009490 In tra tra c h e a l In je c tio n s o f Asbestoa JT-100 to Rats >3 ^O4 0 3 (I yu u 23 u3 U39 44 O 3 3 3U <3 S O 3w 3<n a8r9* *`03>* * a. c U 0 - cHi aOCa ac 0e 0b 3 04 u prf y U3O A e8 3 3 3 (3 *O4 C9 a3. 8CU8 43J 4#4 Brf s od o Qe'A HoO. <k3H* 3 --14 -H WHO O3 300 FU8-i 8 wH H 83 O **4 Ho Au -4 c 9O ew 3u A 0t4rf (0 01 cO633_ oe IM3-A4 C * 3 H H V u 36 -4 8e ^3 8W 3 434 rf 3 i-4' 306 dQ 0 9e *w*8"4 3-4 00 eorf 3 JS 3U oe H3 oW 6 eO 3 *34 44 HH eo4 AU -33804 3Ofcrf fl 3 98 e3w 3o v V3I 36 bCl -Q4 4i e3 O3 <b9 v) O V) 3 V3 4C4l 3 a 00 e 3 4o4 bO 3y H**e 3. Q3 44 O33 Vby3) s O 00 Vw3C)l --cs4 u 3A 3. ** e Oe 3- 3C 3O 3S 'fit 33 U . 3C *4 3 -H Q. .3 Cl -* ~4 * U ** oC uu -bo* 3 S6 U3Qe *3 O DS33U | (8L b -US 00 oNO O mN o t*--o44 VS oo e os3 4e1 a. c ou VI no 1*1 31 u .3E1 3S OS IS; f9M% *3 09 n VO 3Sc0v Nnr>0 ^ 'V < 00 49 oo mon NO eo 3s3 o v3 V3UI -3 VI 3 a3 Xbf eQ 6 o*4 c 3Oow 33 ou u e a. Au ^Q cn VS 0 oON OoN O00 sO H NO nnO nnO 00 aa ao M oe o -4 VI SC 050 3 3CL 0_ 0C V9I w VI s & o Au\ 3. <9* *H n taa it ea 41 4> b y *4a1 ta3t -ua -vtj ss cc -- T* *H -H 5 a <e9 e<3 cao cao JuS u, 3e au ta 5uo 3 U cob J3 U -a uh U4) XXXX 41 41.41 V BC ao O O Q Q uu zzzz Cu Repot 29-! Page 491 OS C. 8 t a * -34b 33 00 *b3rf co on NON 3 c 3U * 3 6 yeO 33 ASrf 33 33vi 39* eOe9 3b 3 -3 * >* >* JS 3 C8. 3 "3ae* *3 6 W00 *9 3 3H 5O6 3938 *333 w3B cQe9 0c0 a 3e a* 3 0*rf 3C -j & Q3O Cl o ee (X & 3W -4 44 (cii u P4 oc b Xu eOe O393e 9ue4 UWo5 u4 -4 e3 y *4 kQCi A CJ o Brf uCO A U w 3 *Oe3 U 3U1 Wo o *+ m **4 wb >% 3 y O3 O3 C3O1 aaoa Orf nHio C3 otn s I* Cu3S 5630 UNtfl ^ N O0c3>0vbnO0T nMC9O* 0hH^0. o vO va H *oT OS CO V) u0V) x 3 l 44 0 M --i 01 B0 a cl E 4) 0. _ C l 0-- W0 9(Q UCAREF00009491 eo s 0eO3)m ^ HH C N H E g<s9 (80 a(9 u0 g<9 ftl n m UOB UcO eUO .BUS ebo Uo a e o b >*>*> O >,>>>>% -H --I r* HHH H --I --I *1 | H >4 H H lba>eb f<lbtdVm-Hn<Hjwia<H UUUbUWUU CU CU CU ajC B CJ C UwlidnltlnllbsUitnUintUtnliUn Report 29-55 Page L2 In tra tra c h e a l In le c tio n s of S aline to Hats ^o uo --4uJ| n>> an aua tku/na aUge U2ae 2oeU -Uins <o abe ----n=_>*-">n<4c*>----nC <Auu0J u-- --Ui --u i3n C >, min* --ui -->****>-*44* (9 <9 <9 B* c bu eoa ci in in >. in 0ue1i ,Uin Winhini <n bm4 UVII W1 W0,ww w SOOOeoottoeooooo b *J A(2! <0 SI tc sd nnwN^^^fs N^NtMOnnisnio^oiAvoN^ 93 00 00 CO i7 h/ nT Nrsr^NQcooooo oj ci (*/9I I1 E tt c o UCAREF00009492 </ MAILING LIST Medical Departments 4 - C. U. Demehl 1 - E. Q. Hull 1 - R. E. Joyner 1 - R. J. Sexton 1 - F. E. Medford 2 - R & D Department Library S. Charleston, W. Va. 10 - P. McDaniel 1 - H. H. Keccham * UCAREF00009493 Cscfieencial Special r.eport 3--70 7 rages JJ L-T I V e. v AUG 3 11982 H. C. IBiSlNSQHH, W.D. 9 ?>: 9-3-71 Chemical Hygiene Fellowship MEU.OK INSTITUTE Carnegie-Hellon University Caiidria^Asbe^tos^Reslji^Grsde^^RG^Iflil. EXHIBIT y/frcvr //'/9*y Tracheal Insufflation of P.ac Lungs vith Istersretaticr. of Pathology after 30, 60, 90 end 180 Dave Editor: C. ?. Carpenter Contributor*i D. L. Geary, Jr., E. R. Kinkead, R. C. Myera, 3. J, Nachrelner For: UNION CARBIDE CORPORATION, Chenical* and Plastics Operations Division Sample A 500-gram sample of Resin Crade RG 244 CCC Cslidrie Asbestos was received 11-30-70, from Ring City, California, pursuant to arrangements made by Paul McDaniel of the New York Office. The sample was identified by the Chemical Hygiene Fellowship 033-251. " Tracheal Insufflation A 12 (V/V) suspension of the RG 244 sample was prepared in 0.852 saline. All needles, syringes end suspensions were sterilised prior to use. Either 1 ml or 0.5 ml amounts of the sterile 12 suspension were injected into the rat lung through the crsehee, exposed by blunt diseection, after e midline cervical incision. Following Injection of these 200 to 300 gram, male albino, Harlan Uistar rats the incisions were closed with Michael wound damps until healing ensued. A total of 13 re to were doeed with 1 ml end IS with 0*5 ml of the 12 suspension while 11 control rate received 1 ml of sterile 0.852 HeCl. Three rats from each asbestos dosed group and 2 controls were killed for histopathologicexamination of -the lung after intervals of 30, 60 and 90 days which left groups of 4, 6 and 5 rats on the 1 ml, 0.5 ml asbestos and control for Cha 180 day sacrifice* Summary of Microscopic Pathology Found 30, 60, 90_and__180_Days Following Tracheal Insufflation of Rats The 30-day pathology vas narked by the presence of granulation tissue with chickening of the-structural elements of the lung (stroma) and cha accumulation of giant cells often associated with foreign bodies. v. iC/'b/ UCAREF00009494 ( ?.eport 24-70 Fae 2 After 60 days one rat on cha 0.5 si doeage level had** inflame den and in growth of connective clseue wnlch blocked a seminal bronchua. Two of 3 rats on both tr.e 1.0 and 0.5 cl doeage level had aceleesaala (collapae) of one or core lobes of the lung. Fibroeie foreign body nodules were present is all eases. After 90 days thare was chronic foreign body pneumonia is 2 of 3 rats at both dosage levels, fibroeie foreign nodules is 3 of 3 and esphysesa in 2 of 3. Chronic inflammatory cell foci and atelectasis were present. Bronchioles were dilated is 2 of 3 rats on both dosage levels and all but one on both dosage levels had sooe lung heeiorrhage. . The final ISO day sacrifice revealed interstitial pneuaonia in 4 rats on the 0.5 si dose. This la a ckrcsic fora of pneumonia of interstitial tissue with decrease of the normal lung tissue. Atelectasis was present in the 4 rats on 1 cl and on 1 rat on the 0.5 ml dose of asbeseos with the 5 controls noraal. Fibroeie foreign body tissue was present in all dosed lungs with none in the controls, Fink, hyalin aaterial was found in 2 of 4 lungs from rats on Che 1 al dose while la 3 of 4 there was a bluish homogeneous material evident* In essence, a total of 10 of 13 rats on the 1 ml dose and. 12 of 25 on Che 0.5 al dose had fibrotle foreign body nodules or tissue. There were 3 cases of emphysema on the high dose and 4 on the low dose and 1 in the control. Atelectasis (essentially collapae of lung alveoli) was present in 9 rats on 1 ml and 6 on. 0.5 ml of asbestos with none reported in cha controls. In general, because of the over whelming preponderance of effect in the asbestos dosed lungs versus the controls, wa have sufficient evidence of damage to warn us to do our best to prevent inhalation of ccscentrations of ssbestos is excasa of the Threshold Limit Value proposed for 1970, (Threshold Licit Values of Airborne Contaminants and Intended Changes. Adopted by ACCXH for 1970. American Conference of Governmental Hygienists, 1014 Broadway, Cincinnati, Ohio 45202). ' Summary Tables for each of cha four sacrifices are`included. Detailed pathology reports on each animal are available and copies can be furnished if the need for them arises. A literature review prepared in connection with another request for information is attached although noc requested. Acknowledgments: Inhalation Studies ) --* * , m m i September 7, 1971 - md ^ At .A'< Charles P. Carpenper, Fh.D. Administrative Fellow Daniel L Geary, Jr,, M.Ed. Research Associate Edvln R. Kinkaad, B.S. Fellow Roy C. Myers, B.S. ' Research Aselstant Donald J. Kachrelner, B.S. Research Assistant UCAREF00009495 r.eps: rage * j able 34-19 Tracheal Insufflation to Uses Sacrificed 30 Dave A^tei' Doeins TOTAL SUMEES TXAMIKED GROSSLY: LUKG: Nunoer Examined Pneumonia Hemorrhage Pleural adhesions Stromal thickening Foam cell accumulations Granulation tissue foci Mulsinucleated giant calls Abscess bronchopneumonia Round cell accumulations TRACHEA: Humber Examined Chronle tracheitis - U1 of IT Solution 1me ' 0.5 33 <M) 3 3 (C) 3 3 CO- 1 0 CG) 1 . 2 (M) 3 2 CM) 3 2 CM) 3 3 (X) 3 2 00 0 1 CM) 0 0 00 ` 3 3 <M> 0 0 0.0 2 2 0 0 0 0 0 0 0 0 1 The foiloxring tissues vere examined microscopically on all ianimals: Lung, Liver, Kidney, Heart, Spleen, Adrenal, Thyroid , Parathyroid , Trachea and Esophagus. G - Gross M " Microscopic Tabla 34-20 Tracheal 'insufflation to Rats Sacrificed 60 Daws After DosIns t Ml of IT Solution _1 O.S 0.0 TOTAL NUMBER EXAMINED GROSSLY: 33 2 LUNG: Humber Examined CM) 3 3 2 Uemorrhage . (G) 0 0 1 Pneumonia . (G) 33 0 Atelectasis (G) 0 2 0 Edema CC) 1 2 0 Hemorrhage 00 1 0 0 Atelectasis CM) 22 0 Flbroclc foreign body nodules CM) 3 3- 0 Bronchiolitis fibrosa obliterans CM) 01 0 KIDNEY: Humber Examined---------------- CM) 3 3 2 Round cell accumulations CM) 1 0 0 HEART: Humber Examined . CM) 33 2 Focal myocarditis CM) 0 1 0 MUSCLE: Humber Examined CM) 1 0 0 ) Purulent mass Large suppurative process,-, striated muscle (C) CM) 10 1 0 as _ 'r .i.`~ The following ciseues were examined microscopically on, all animals: Lung, Liver, KidneyrTteart, Spleen, Adrenal, Thyroid, Parathyroid , Trachea and Esophagus. C - Gross M - Microscopic UCAREF00009496  . u- Report 34--70 Page 4 Table 34-21 \ tracheal Ineufflatlon to Rati Sacrificed 90 Dave After Poeina TCTAL STHBER EXAMINED CROSSLY: L*JHG i Number Examinee Pleural adhesions Hemorrhage Edema * Pneumonia Chronic foreign body pncnonis Fibrotie foreign body nodules Emphysema Chronic inflasaatory cell foci Sound cell foci Atelectasis Bronchiectasis Stromal thickening Hemorrhage Inhaled blood * KIDNEY: Number Examined Hydroaephroala Uydroaephroala Round call foeua TRACHEA.: Humber Examined Chronic tracheitis HEART: Humber Examined Myxoid change, interatitium <M) (C) (C) (<) < 00 (M) 00 00 00 00 00 CO 00 00 00 CO 00 (H) (H) - 00 00 00 Ml of 1* Solution .1 0.5 0.0 3 3 0 0 3. 3 2 3 2 3 0 3* 2 1 3 o3 0 0 0 3 2 3 0 3 3 2 2 3 3 2 3 2 3 1 3 2 0 Z 1 3 0 0 1 3 1 3 1 2 2 0 0 0 0 0 0 0 0 1 0 0 0 0 '0 3 1 1 0 3 2 3 0 the following tiaeuee were examined micros cop ieally on all anlmalai Lung, Liver, Kidney, -Heart, Spleen, Adrenal, Thyroid, Parathyroid, Trachea and Esophagus* G - Gross K " Hieroscople ) .icCL UCAREF00009497 Report 34-70*'' Page 5 'able 34-22 S Tracheal Insufflation to Race Sacrificed 130 Peye After Dosing TOTAL NUMBER EXAMINED CROSSLY; LUNG: Nu-br tMEinea Edema Pneumonia Ateleccaaia " Esphyecna Emphysema Atelectasis Inhalation pneumonia Ineers tidal pneumonia Abscess bronchopneumonia Suppurative bronchiectasis Acute bronchitis Lymphoid eell accumulations Foam cell accumulations Flbrocic foreign body eljsue Cranulatien tissue foci Pink hyalin material ` Bluish homogeneous material Numerous mononuclear cells Mucoid infiltration Proliferation bronchiole epithelium LIVER: Number Examined ' Bile duet proliferation Round cell foci KIDNEY:. Humber Examined Hydronephrosis Sand calculi Hydronephrosis Sand calculi ' ` Dilated tubules Pink casta Interstitial nephritis Cellular infiltration Slight tubular regeneration Moderate tubular regeneration TRACHEA: Number Examined Acute tracheitis Chronic tracheitis <M> cc> * CC) (C) (G> 00 09 <M) (M) (M) CM) CM) CM) 00 00 00 00 00 CM) 00 CM) 00 CM) 09 CM) CG) <e> CM) CM) CM) 00 00 00' CM) CM) 00 00 CM) - Ml of 11 !Solution 1 7 4 2 4: 0.3 6 6 0 5 0.0 5 5 *n i 20 i 00 12 41 10 i i 0 0 0 4- 0 00 1 10 0 00 1 30 0 2 1 .3 46 0 0 i 20 31 0 0 0 10 20 0 0 00 1 46 5 02 10 46 .0 i 1 0 5 0 0i 0i 0. i 0 0 0 02 02 01 0i 2 1 0 0 0l 00 3 1 46 10 04 5 0 0 The- following ciaauea were examined microscopically on all animalat lung, Liver, Sidneys, Heart, Spleen, Adrenal, Thyroid, Parathyroid, Trachea and -- Eeephagua* C - Croae M " Hieroacopie . cioei UCAREF00009498 Report 3^-70 Page 6 Asbestos r Addicgley, C. C. Asbestos Ouse and Its Measurement. Aria. Occur. Kvs. ' 73 (1966). Anon. Occupational Hazards of Asbestos CIS (International Occupational Safety and Health Information Centre.) (Abstracts on Asbeatoais 1939 to 1967). . Collins, T. F. Asbestos the Lethal Oust. S. Afr. Med. J. 42i 218-9,(1968). As cited in Index Hedieus, 9(08), 1966, p, 7C. . Cor=ittee on Hygiene Standards. Hygiene Standards for Chrysoclle Asbestos Dust. Ccssittee on Hygiene Standards of the British Occupational Hygiene Society, Snterline, ?. E. Asbestos-Dust Exposures at Various Levels and Mortality, Arch. Ecjrtjron^Jlealth, -3. p. 181, (1967), ~` Kogan, ?. M.; Svirskli, . L.; Belobragina, C. V, Ole. Tr. Prof. 2abol. 13. pp. 9-12 (Buss) (1969), Hygienic Charaeeeristlea of the Dust Generated in the Production of Asbestos-containing Thermal Insulating Materials Asbestos-VeriBiculice and Asbestos Perlite. As cited in C.A. V. 72(26). p. 253(136090y) 1970. Parazsi, Elena, ec al. Cytotoxicity of Asbestos Dusts. Med. Lav,. 1968. 59(10). 561-76 (Eng). As cited in C.A. Vol. 71, 02, p. 256(6374n) (1969). Report from a Viorklng Group of the International Union Against Cancer. The - Association of Exposure to Asbestos Duse and Cancer. Ann. Occur. Hvg. 8, p 267, (1965). ~ Roach, S, A. Hygiene Standards for Asbestos. Ann. Occuo. Hyc. 13, pp. 7*15, (1970). Selikoff, Irving J., et al. Asbestos Exposure, Smoking, and Neoplasia. JAMA, 201, 02, p. 106/104, 1968. Tinhrell,. V., et al. A Simple Dispenser for Generating Dust Clouds from Standard Reference Sasrples of Asbestos. Ann. Occuo. Hyg. 11, pp. 273-281,1968. Asbestosis .1 Bslzer, J. LeRov, Industrial Hygiene for Ineulation Workers. 10, 01, (1968),. J2ajofaiaOcieuOj>BaMe^. Gross, Paul and R. T. P. deTreville. Experimental Asbestosis. Arch. Environ. Healtn IS, p. 638 (1967). Cross, P. and R. T.- P. deTreville.__ Experimental Asbestosis. Studies on the Progres siveness of the Pulmonary Fibrosis Caused by Chrysotile Dust. Arch. Enviyon. Health. 15. 638-649' (1967), As cited in Industrial Hygiene Digest, 32 (05), May 1968, 0449. A* McDonald, -J, C.,- et al.' Mortality in Chrysotile Asbestoa Mines end Kills of Quebec. Arch. 'Environ.' Health. 22, 677<-86, June 1971. As reported in the JAMA p. 1658, June .7, 1971, Vol. 216 No, 10. ClU Z UCAREF00009499 C T j14*'w rage 7 / v Editorial* Quae Asbestosis in Urban Populations. JAMA 196 732* (1966). . ~- Gross, Paul, et al. Asbestos Veraua Nonasbestos Fibers. Arch. Environ. Health. 2S. pp. 571-578 (1970). * Holt, F. F., J. Mills, and D. K. Young* the Early Effects of Chrysotile Asbestos Duse on the Rat Lung. J. Pathol. & Bacterlo!.. 87: 15-23 (1964). Hvgjenlc Standards. Ind. Hve. J.< 19(02). o. 161. (1956). Harr, William I. Asbestos Exposure During Havai Vessel Overhaul. AIKAJ. 25 (03), pp. 264-268, Hey-June 1964, Thomson, J. C., and V, M. Craves. Asbestos as an Urban Air Contaminant. Arch. Pathol. 81: 458 (1966). Westlake, George *, Harlan J. Spjut, and Marilyn N. Smith. Penetration of Colonic Mucosa by Asbestos Particles. An Electron Microscopic Study in Rats Fed Asbestos Dust. Lab. Investigation. 14: 2029 (1965). Analytical Crable, John V, Quantitative Determination of Chrysotile, Amoeite and Croeidolite by X-ray Diffraction. AIHA, Vol. 27 (#3), JJay-June, 1966 - p`. 293-298. Crable, John V., and Marta J. Knott. Application of X-ray Diffraction to the Deteminacion of Chrysotile in Bulk or Settled Dust Samples. AIHA, Vol. 27 (04), July-Aug,, 1966 - p, 383-387. Crable, John V., and Marta J. Knott. Quantitative X-Ray Diffraction Analysis of Croeidolite and Aaosite in Bulk or Settled Dust Samples. .AIHA, Vol* 27 ((5), Sept.-Oct., 1966 - p. 449-453* Lynch, Jeremiah R., and Hevard E. Ayer. Measurement of Dust Exposures in the Asbestos Iextile Industry. AIHA, Vol. 27 (05), Sept.-Oct., 1966 - p. 431-437. f. * The Method For Determining Asbestos Dust Concentration. This publication sells for $1.00 and may be obtained from the Asbestos Textile Institute, P. 0. Box 239, Pompton Lakes, Hev Jersey 07442, AIHA, Sept.-Oct., 1965. ' Review Tissue Response to Asbestos (Report of a Meeting by C. K. Davies), Ann. Oecup. Uyg. Vol. 13 pp. 241-245. Pergaxcmon Press, 1970. ) UCAREF00009500 Medical Directors U - C. C. Demehl 1 - E. G. Hull 1 - R. E, Joyner 1 - R. J. Sexton 1 - X. X. Speeeer Ocher Distributions 1 - H. 3. VerMooy 2 - N. H. Kaechaa 1 - P. V. McDaniel 1 - H. R. Guest Libraries 2 - Chemicals Division (1 aet each Library) Building 701 and 770 Libraries South Charleston, Vest Virginia Project Initiator--co distribute as you aee fit. No copies have been sent to ~ others in your business or operations team, except susaaries to the R/D Directors, V.P.'s and Libraries. More copies vlll be furnished upon your request. Project Initiator 6 - P. v:. McDaniel COLLECTED C G. H, Daniels 1 SR. 1. Hoaglin ( J. J. Saleh 1 - T. T. Ssabo 1 - T. a. Welch 1 - N. L. Zutty &-L1 reports are sent to List A at aonthly ~' intervals. List A recipients are* 1 - J. V. Murray, Jr. 1 - W. B, Ackarc 1 - L. Sheehter 1 - E. A. Barr 1 - Plastics Division Library 1 - P. V. Tauber ------------------Bound Brook, N. J. 1 - Mining and Metals Library Tuxedo, N. Y. 2 - Chemicals and Plastics Division^ ' Bldg. 701 & 770 Libraries , South Charleston, W, Va. 1 - R & D Library Tarrytown, N. Y. "ikm rr; X UCAREF00009501 'V1 * * * * * EXHIBITS * * * marked at the * * * deposition of * * * * EDWARD B. ILGREN * * * on * * * * * * JUNE 21, 1994 * * * * * * * * * # * * * * * * * * * * * * * * * * * * * * * * * * * * * * * DAVID FELDMAN & ASSOCIATES/USA/LTD. 342 Madison Avenue New York, NY 10173 (212)986-4545 Fax (212) 557-5972 COMPUTERIZED COURT REPORTING WORLDWIDE KSQ. C COMPANY UCAREF00009502 CURRICULUM VITAE ___sx--L hjfmiz DR E. B. ILGREN MA (Oxon.), MD, D.Phfl. (Oxon.), MACPath*, MRCPath (Associate / Neuropathology) Date of Birth: 13viii50 Place of Birth: Philadelphia, Pennsylvania, USA Nationality: American Member of Faculty of Biological and Agricultural Sciences and Subfaculty of Biochemistry, University of Oxford UCAREF00009503 Institute and Location Hahnemann Medical University Americas College of Pathology University ofOxford Royal College ofPathology UK (Primary) University ofOxford Education Degree Year Conferred Field of Study MD Medicine 1974 MACPath 1976 Anatomic Pathology (Boards) D.Phil (Oxon) Zoology/Botany 1980 MRCPath Neuropathology 1982 MA(Oxon) 1983 Biology / Medicine Research and / or Professional Experience - Chronology 1973 Student Worker, Dept ofComparative Neuroanatomy, Bryn Mawr College, Bryn Mawr, Penna.. USA. 1971 Doctorate ofMedicine. The Hahnemann Medical College, Philadelphia. Pennsylvania. USA. 1973 Visiting Resident. The Memorial Hospital for Cancer & Allied Diseases, attached to Dr W.B. Jones, Consultant Gynaecological Surgeon. Trophoblastic Disease Centre. 1974 Assistant Pathologist, The New York Hospital - Cornell University Medical Centre, New York City. 1974 Asasttnt Forensic Pathologist. Office of the Medical Examiner, The New York Untvenity Medical Centra. Dr. M.C Baden (Sponsor) - ChiefMedical Examiner. 1973 Diplomate ofthe National Board ofMedical Examiners (USA). ' 1973/ 76 Visiting Scientist Rockefeller Insdmtc ofMedical Research. Professor A.C Braun (Head of Department), Dr EGL Diacumakos (Laboratory ofCytobiatogy, HcadofDcpann>cm). 1973 Licensed in Medicine and Surgery, State ofNew York, No. 124849. 1976 Board Certified, American Bond of Pathology. Anatomic Pathology. X UCAREF00009504 Research and / or Professional Experience - Chronology [976 Visiting Worker. The Imperial Cancer Research Fond. London Prof. R.A. Willis /Dr L.S.C. Pang 1977 Visiting Scientist (Lfniv. South Calif. San Diego Zoo. Soc. HospitaL Dept Path. Professor K. Bcnirschke 1977 Travelling Research Fellow (International Union Against Cancer) - Geneva. Switzerland. 1976/77 Postdoctoral Research Fellow (International Agency for Cancer Research/World Health Organisation). Dept, ofZoology. University of Oxford. Professor R.L Gardner. FRS Sponsor. 1976/79 Special Postdoctoral Research Fellow (American Cancer Society - spf-14). Lab. Experimental Mammalian Embryology, Unhr. ofOxford. Prof R.L. Gardner, FRS. 1978/79 Research Fellow (NIH). Dept ofZoology. Lab. Experimental Mammalian Embryology, Univ. of Oxford. Prof RX. Gardner, FRS . 1979/80 Visiting Scientist (NIH), Sir William Dana School ofPathology, Univ. ofOxford 1979/80 Research Fellow (NIH), Botany School. Lab.ofCytology, Univ. of Oxford. Prof F. Whatley, FRS / Dr C. Vosa . 1980 Di'hiL (Oxon), Dept ofZoology & Botany, Univ. ofOxford. Member. St Edmond HaiL 1980/81 Honorary Senior Registrar, Neuropathology, The Raddifle Infirmary, Oxford. 1980/81 Research Fellow (NIH), Dept, ofNeuropathology, The Raddifib Infirmary, Oxford. 1982 Senior Registrar, Neuropathology, The Raddifib Infirmary, Oxford. 1982 Pathologist to RM. Coroner, Mr N.G. Gardiner (Oxfordshire). 1982 General Medical Connol. Foil Registration. 1983 (Locum) Consultant Neuropathologist. The Raddifib Infirmary, Oxford, Jane 3*17,1983. 1983 Subfbcuity Member, Department ofBiochemistry, University ofOxford. 1984 Faculty Member. Biological Sciences. University ofOxford. 1984 CO^edpieat, Health & Safety Executive project grant award: co-recipient with ProfP. Shnbik, Iron Chelation: An attempt to develop a possible therapy for those at risk from exposure to asbestos by inhibiting formation, persistence, and effects ofasbestos bodies in vivo'. 1983 Recipient OxfordArea Health Authority / District Research Grant Award 'Embryonic regulation ofneural neoplasia*. 2 UCAREF00009505 PUBLICATIONS 33. Dgren. EB. and Stiller. C (1987) Review article: Cerebellar astrocytomas. Pan 0. Pathologic fames indicative of malignancy. Gin. Neuropath.. 6:201*214 34. Dgren. EB. (1988). Multi System Atrophy: Possible central aetiology of the laryngeal dysfunction and the role oflymphocytic inflammation. Arch. Suing Neura. Psych. 139:73. 35. Ilgrea. EB. (1989). Mesothelioma Threshold. In: Effects ofMineial Dusts os felt* (Mossman. B. and Begin. R.X Springer-Vertag, Heidelberg; 1989, voL EJO, 455-464. 36. Dgren. E and Wagner. I. (1989). The value of experimental animals in analyzing the hazards of exposure to mineral fibres; H. Consideration ofnatural background incidence of mesotheliomas and itonphysiological imraperitoneal technique. Submission to the German MAK Commission on Mineral Fibre Safety. ISBN [0*9516339-0-51. 37. Dgren. EB. and Wagner. J.C (1991). Background incidence of mesothelioma: Animal and human evidence. Reg. Ton. PhantL, 13:133*149 38. Hgres. EB. and Browne. K. (1991). Asbestos-related mesothelioma: Evidence for a threshold in hntnans and animals. Reg. Tax. PharnL, 13:116*132 39. Brawn. R~ Davis, Douglas; D.. Gnxber. U.. Hoskins. Ogren, E. Johnson. N,, Ressner; G and Wagner. J. (1991). Carcinogenicity ofthe insulation wools Reassessment ofthe (ARC Evaluation. Reg. Tox. Phatm, 14:12*23 40. Ilgren. EB. (1991) The potential health eflfcca from low dare exposure to tremolite in vernncnlite: An overview ofthe Libby. Enoree. and the Palaore experience. (Ahstrao|. Fourth International Conference, Environmental Lang Disease. 25*28. Sept 1991 MaaneiL . 41. Dgren. E (1992) Potential hypermsceptibility to the induction of mesotheliomas m beifltstBKS exposed to ceramic fibres Theoretical biological mechanisms. Reg. Tax Phann (submitted! . Boobs: Ogren, E [1991] Initiation and Promotion in Skin or Liver Neoplasia: A 65 year annotated bibliography ofinternational literature. CRC press. 928 pp. ISBN - 0-8493-4407-7 Ogren, E [1993] Mesotheliomas of Animals: A comprehensive; tabular compendium ofthe world's literature. CRC press. 356 pp. ISBN - 0-8493*4308-9 14 UCAREF00009517 Employment Oates (month <& year) From To Name and address of jpansorfemployer PosMra April 1987 July 1989 Juno 1989 Present Imperial Cancer Research Fund University ofOtford, St Edmund Hall Research Officer (Hon.) Clinical Trials Study Unit. Univ. Oxford. Member. Faculty (Biological Sciences). Subfaculty (Biochemistry) s~ 4 UCAREF00009507 Research Experience The basic and clinical aspects of the tumour problem and neuzodegenerative disease have h--^ persistent themes of the research conducted to date. . Rockefeller University, 1975 * 1976: "Control of Trophoblastic HCG Secretion: Gene Mapping": EBI. in collaboration with Dr E.G. Diacumafcos (Rockefeller University) and Dr W.B. Jones (Memorial Hospital for Cancer), was the dm to grow choriocarcinomas in vttro without recourse to animal hosts, work conducted in a combined clinical and experimental study of the relationship between HCG secretion and malignant trophoblastic growth. The results of this study suggested that the secretory activity and cellular proliferation of malignant trophobiast may. at times, be dissociated phenomena in van. a conclusion confirmed by observations .made, on taro occasions, in vivo. Since these experiments were originally aimed at mapping the HCG gene via ceil hybridisation. EBI also mastered techniques, developed by Dr Diaounakos. for miaosurgical cell fosion. chromosome extraction, nuclear and cytoplasmic ceil injection, and single cell dotting as well as methods needed for the cytogenetic analysis of such dotted ceil lines. Whilst at Rockefeller, EBI also had numerous discussions with Prof Armin Braun on Epigenetic theory, tumour suppression, and recovery. These were based on Prof Braun's Crown Gall Teratoma Model System and laid the foundation for some of EBT* forme experiments. Imperial Cancer Research Fund, Tumour Reference Collection (TRQ and the San Diego Zoological Research Hospital (SDZ), 1976: "Comparative Pulmonary Neoplasia": EBI made an extensive histopatbologjcal review of a large series of pulmonary turnouts found in captive wild animals (SDZ) and various domestic species (TRQ, the results confirming previous reports that most animal lung tumours are of the alveolar type, Le. the one not generally seen in association with smoking. Oxford University, Dept Zoology, 1976 - 1981: "Control of Trophoblastic ChOoiar Division": The perplexities of working with a malignant tissuethat, even in their normal state, behave in a manner similar to tumour tissues, led EBI to pursue studies of normal trophoblastic growth and developmental mechanisms generally thought to be related to neoplasia. Such studies were pursued in Oxford in the microsurgery laboratory of Prof R.L. Gardner, a leading experimental mammalian embryologist. These studies employed microsurgical injection, dissection, enzymatic separation, and / or tissue culture of pre- and post-implantation embryos and their constituent tissues. The latter wen analysed biochemically. histodtemicaUy, cytoktgically, cytogenetically, histologically, and cytophotometricaUy using, in some cases; methods developed by the EBL Embryo transfer and amour inoculation methods were also employed in these studies. Oxford University, Dept, of Botxny, 1980 - 1981: "Cytological and Cytogenetic Analysis of Polyploid Cells": Preparations of trophoblastic giant cells were analysed cytologically, cytogenetically, and cytophotomeaically in the Botany School under the supervision of two eminent cytologisu. Dr C.G. Vosa and Dr F.A.L. Clowes. These analyses were primarily directed at assessing DNA synthesis and chromosome structme. 5 UCAREF00009508 Research Experience Oxford University, Sir William Dunn School of Pathology, 1980-1981: ''Regulation and Suppression of the Tumorous State: Analysis of Heterotopic Embryonal Carcinoma (EC) cell-derived Chimeric tissues In Vitro and /it Vhon: Embryonal carcinoma (EC) eeil-denved mouse chimaeias were produced by EBt using Prof Gardner's blastocyst injection methods and the mature chimaenc tissues were subsequently dissected into their constituent parts, ecropically transferred to syngeneic hosts, and observed in host sites fbr tumour growth of donor ceil origin. Since eoopicaity transferred, chimaenc placental tissues were the only ones to form tumours, it was concluded that placental, in contrast to somatic tissues, lacked the ability to suppress the tumorous phenotype ' Oxford University, Dept, of Neuropathology, The RaddHTe Infirmary, 1981-1985. "Embryonic Regulation of Neural Neoplasia": Discussions with Prof Annin Braun subsequently led EBI to ask if tumour cell types other than those of EC cell origin, could colonise the embiyo and. in nun. be suppressed or regulated by the embryonic environment. Since it was likely that this would occur with 'deveiopmentally synchronised', donor-host cell combinations, eg. when neuroblastomas were injected into the normal neuroblastic tissues of the embryo, a nucrosurgtcal method was developed chat could inject marker substances and ceils into the brain of the developing mouse embiyo in uttro. "Unusual associations between different tumour types and bamartomatous dysgenetic disorders of neural crest (e.g. intra-crenial melanoma and Naevus of Ota) or non-oenrel crest (e.g. Tuberous Sclerosis with Sarcomas and Adenocarcinomas) origin": EBI was to first to provide evidence to suggest that the NF gene in Neurofibromatosis may not only predispose neural crest-derived Schwann cells to undergo malignant change but also may affect in a similar way, non-aeural crest glial derivatives ofthe cerebellum. "Clinical Pathological Correlation Studies": The largest series of ependymomas, cerebellar astrocytomas, medulloblastomas, and craniopharyngiomas were analyzed to determine clinical and pathological prognostic indices. "Involvement of Nucleus Amhiguui and Chronic Inflammation in MuMSystemic Atrophy (MSA)": EBI was the first to demonstrate chronic inflammation in the Shy-Orager Syndrome (Multi System Atrophy with Autonomic Involvement) and to confirm upper motor neuron loss within the nucleus amhiguus by histologically reviewing serial sections of the brainstems of more than 20 MSA patients, perhaps the largest collection in the world. "Ncuraepidemiological Studies: Mercury containing pesticides An assessment of the exposure, neuromuscular ftmcriou, and nenrapathotogical statua of seed dressing merchants and agricultural workers": A multidisciplinary investigation to assess the exposure, neuromuscular function, and possible neuropahotogicai changes in seed dressing merchants and workers exposed to mexany-comaining pesticides in Oxfordshire was outlined though not conducted. The investigation had received the approval of the University Dept, of Neurology, The RaddiiTe Inflatory. Oxford (Prof B. Matthews); the National Hospital (hr Nervous Disease. Dept, of Neurophysiology, Queen's Square. London; DKSS St Bartholomew's Medical College: London (Prof A.D. Dayan (Toxicology) and Prat N.J. Wald (Epidemiology)); the Oxford Scanning Proton Microprobe Group. Dept, of Nuclear Physics. University of Oxford (Dr F. Watt): and the Dept of Neuropathology, The Raddifle Infirmary, Oxford Dr EB. Ogren). Extensive discussions were conducted with the Health and Safety Executive (UK) (Dr D. Gompenz)*. the Pesticide Regulation Depc. Ministry of Agriculture. Food & Fisheries (MAFF) (Dr XM. 6 UCAREF00009509 Research Experience Sty): Advisory Committee on Pesticide Use (UK) (Prof R. Kilpatnck): the Myaesthenia Gravis Foundation (USA) (Or E. Lambert): the Executive Director. British Agrochemical Association (Mr l. Abbott): the Product Safety and Plant Protection Division. Imperial Chemical Industries (UK): Or G. Worthing. Advisor. Pesticide Safety. British Crop Protection Council: Or S. Logan. Medical Advisor. Shell International (The Hague): Or E Burgess. Medical Advisor. Dow Chemical (UK): Dr G. BonsaiL Plant Protection Advisor. Fisons Boots Co. (UK): Mr B. Syde. Daigety (UK): and Weed Research Organization (Oxford). Oxford University, Dept, of Nuclear Physics, 1984: "Nuclear Proton Mfcroprobe Study of CNS Tissues": In collaboration vith the Oxford Proton Microprobe Group. EBI was the first to demonstrate the endogenous elements of the human brain with the proton microprobe thereby generating an 'elemental map' which closely corresponded to the normal architecture of that tissue. Oxford University, 1985 - 1987: "Asbestos Body / Chelator Treatment Project". With the assistance of Prot P. Ahnfrty EBI investigated methods of modifying the inflammation secondary to crotidolite and the zeolite. granite to see ifthe inhibition offerruginous body formation could suppress neoplasia. Oxford University, Imperial Cancer Research Fund, Clinical Trials Studies Unit, 1985 -1989: "Initiation and Promotion in SWo or Liver Neoplasia: A 65 year annotated Bibliography of International Literature": The terms tumor 'initiator" and "promoter* have engendered much confesion particularly within the regulatory agencies responsible for their control Because of this. Prof P Shubik was asked by the American Industrial Health Council (AJHCX the National Cancer Insitute (NCI), and the Health aid Welfare Department of Canada to attempt to darify such confusion and reach a greater consensus on the present day meaning and definition of such terms. Prof Shubik then asked EBI to comprehensively compile and critically review every original whole animal andy ever performed that was daimed to be related to initiation and promotion in the skm or liver ofany species as a first step towards achieving this goaL The firs 13 months of the project was supported by the A1HC (ca. 5S0.000} but was completed with the support of the Imperial Cancer Research Fund (ca S200.000} under the supervision of Or Richard Pen. FRS ewer tbs ensuing 32 months. The vasmess at the literature reviewed for the project (over 2000 original studies from 200 different journals in 9 languages) is reflected in the feet that the articles upon which the study was primarily based occupied more than 25 feet of shelf space. The phenomenon at initierion and promotion has substantially influenced past and current theories of human cancer and continues to be the fbeta of much research. The project described in a 928 page (microtext) compendium published by CRC press in (991. attempts to make the relevant experimental evidence readily accessible. A greater aim was to bring together studies that relate importantly to phenomena that have been of increasing concern to those involved with environmental protection legislation namely events penaining to possible human exposures to agents with delayed cancer causing effects and to the potential synergism between different agents. Overall, however, one must be cautious about overinterpreting the animat dam found in many studies that daim to investigate initiation and promotion since the majority have nriitred nanphysioiogicai models, unduly sensitive strains, and excessive exposures often in excess ofthe maximum tolerated dose. 7 UCAREF00009510 Research Experience "Irreversibility at the Initiated State": Early initiator promoter studies claimed that initiation was irreversible ie that a dose of carcinogen insufficient to induce turnon was soil sufficent to produce a cancer risk that would remain unabated for life However, this concept (which Forms the basis of the no threshold concept) defies biological sense in the light of our present day knowledge especially on repair mechanisms. Thus, in order to demonstrate that the studies subsequent to the earlier ones Sail to support the concept of irreversibility, ail of the studies which claimed to test the reversibility of initiation were therefore assembled and cntiqued. The results were then presented as invited tenures, to universities (Bryn Mawr College), industrial centres {ICT. Ell Lilly), and to government (FDA). The work was supported {ca SIO.OOO) by the DHSS. Dept, ofToxicology. London. Dr Barbara MbcCibbon and Dr John Steadman. Oxford University, Faculty, Biological Sciences, St Edmund Hall, 1989 to present. "Mesotheitoaias of Animals: A Comprehensive, Tabular Compendium of the World's Uteramre":EBI produced the first book to comprehensively compile the diverse, disparate literature on animal mesotheliomas. The compendium presented evidence in support of the existence of so called "background* or nonasbestos related mesotheliomas as well as the threshold concept "Mesothelloffla Background: Honasbestos related tumors":In collaboration with Dr J C Wagner. EBI assembled, analyzed, and published the animal and human evidence which suppons the view that mesotheliomas may be caused by agents other than asbestos. EBI is presently gvtenHiwg this work by assessing the possible presence of fibrous zeolite - related disease in the United States. "Mesothelioma Threshold": In collaboration with Dr K Browne. EBI assembled, analyzed, and published the animal and human evidence that suppons the view that the doses of agents required to induce mesothelioma display no observable effect levels or threshold. This was done primarily for the two major commercial amphibotes. amostte and croctdolim. EBI is presently extending these studies to tremolite. the common contaminant of duysotile. venniculhe. and talc In particular, the pathology Libby venniculite / tremolite miners and millers with lung cancer and mesothelioma being analyzed for publications in conjunction with hmg burden, hygiene, and other occupational exposure data. "Chrysotfle: Biological Effects of Naturally Occuring Short Fibre Preparation from Calldrla":ln collaboration with Dr Kent Pinkerton and Dr E C Me Connell. EBI is finalizing the results obtained from a long term bioassay using two standard tong fibre duyadle preparations, UtCC / B and Jeffrey, and the shen fibre preparation from Calidria. California. "Amocitn Related Mesothelioma": EBI is producing a critical overview of the mesotheliomas noted in association with amositB exposure, lb is also attempting to set up a UK based, multidisciplinary study to update and finalize both the Gentiston and the Uxbridge amoshs factory cohorts with a particular view towards "profiling*, in detail, tho mesothelioma cases. 8 UCAREF00009511 Memberships Sc Edmund Hail (Middle Common Room). Univ. Oxford . 1975 British Society Development Biologists (BSDB) 1979 Tuberous Sclerosis Association (UK) 1981 Neurofibromatosis Foundation (USA and UK) {98 { v ' Royal College of Pathology (Asso.) 1981 British Society ofNeuropathologists (BSN) 198 { Neutosdences Specialty Group, University of Oxford {98 { Oxford Proton Microprobe Group. Nuclear Physics, Univ. Oxford {983 British Medical Association (BMA) 1984 Subfacutty of Biochemistry, Univ. of Oxford 1984 Faculty of Biological Sciences, Univ. of Oxford 1984 Oxford University Computer Centre Users Group {985 International Fibre Safety Group (IFSG) 1990 Technical Services Group (TSG), Wash., DC 1991 American Medical Association (AMA) 1992 Pennsylvania Medical Society 1992 Montgomery County Medical Society 1992 Awards American Cancer Society Special Postdoctoral Award (Control ofTrophoblastic Growth) IntL Agency for Cancer Research Postdoctoral Award (Control ofTrophoblastic Growth) IntL Union Against Cancer (TCRETT) Award (Comparative Pulmonary Oncology) National Inst Health Postdoctoral Training Award (Control ofTrophoblastic Growth) Medical Research Council Project Growth Award (Embryonic Regulation ofNeuraJ Neoplasia) Health & Safety Executive Project Grant Award (Potential Therapy... Asbestosis) Oxford District Research Grant Award (Embryonic Regulation ofNeural Neoplasia) American Industrial Health Council Award (Tumor Promotion Project) Imperial Cancer Research Fund Award (Tumor Promotioo Project) : W R Grace & Co. Research Award (Health Effects ofTremoiite Project) June 1976 June 1978 Dee. 1976 - June 1977 June 1977 - July 1978 June 1978- Sept 1980 April 1982- Sept 1984 Sept 1984- July 1983 Nov. 1984- July 1985 Aug. 1985 - Feb. 1986 Mar. 1987 -Aug. 1989 Aug. 1990-Sept 199^ 9 UCAREF00009512 Doctoral Dissertation - Summary 1. Control of trophoblastic proliferation in early postimplantatjon mouse development: Several conditions are needed to promote die growth of postintplamanon mouse trophoblast. Firstly, an appropriate tissue shape and close cell contacts are needed to suppress die trophoblastic giant cell transformation and maintain these tissues in a largely diploid, non-giant state. Moreover. since an appropriate tissue shape cannot, on its own. promote trophoblastic cell division. ICM-derivatives. e.g. ecoaembryonic endodenn and / or mesoderm, are probably also needed to stimulate normal trophoblastic growth. 2. Control of trophoblastic proliferation in the guinea pig: The growth of guinea pig aophccrodcrm and its early postimplantation derivatives appear to be under TCM control. Thus, the multilayered attachment cone of the guinea pig blastocyst is probably not due to an ICM-independent proliferation of trophectoderm but is most likely derived from a transient accumulation ofabembryonic trophectodemtal cells. 3. Origin of the trophoblastic giant cells: binudeation: In the mouse, postimplantation trophoblast appears to become giant through a binudeate phase. Thus, the growth of mouse trophectoderm occurs, to a certain extent, in a manner similar to the polyploidisation of mouse liver. 4. Origin of the trophoblastic giant cell: multinudeatiowThe finding of muJtinucieates in pure, tropbectoderm-derived tissues suggests that trophoblastic aiuitmudeation, at least in the mouse, does not depend upon prior contact with mesenchyme or mesenchymal tissues. Multipolar, polyploid mitotic figures were found in mouse decidua, tissues known to contain mttitimicteates similar to the ones seen in the trophoblastic derivatives of nmrinams. This suggests that the muitimideate cells seen in same forms of trophoblast may arise in a manner similar to those found in rodent decidual tissues, ie. via a multipolar mitosis withoutconcomitant cytokinesis. 5. Mechanism by which DNA accumulates during the trophoblastic giant eel] transformation: Polyploid meaphases were found within postimplantation mouse trophoblast that had chromosomes arranged either randomly or in pain. This suggests that at least some mouse trophoblastic cells increase their DNA via polyploid nutate and/or cndomitoric cycles. 6. Control of the trophoblastic giant cell transformation: The degree to which tropbectoderm-derived cells cadoreduplicate their nuclear genome and thus become giant can be influenced by changes in tissue shape and the extent ofheteroeflular contact Thus, cell separation, spreading, and stretching appear to promote foe gtiua ceil change not only within trophcoodcrmal derivatives but also within tissues known to behave in a maimer similar to trophectoderm. namely exnaembryonic entoderm. Moreover, the giant cells found in normal and neoplastic extraembryamc tissues are not necessarily terminal and incapable of cell division since they may be found in mitosis either before and / or following mitogenic stimulation. Comparative studies also suggest that the onset of the giant ceil change in one extraembryontc membrane may be temporally correlated whfa the development and/or degeneration of a nearby placental tissue layer. ' V UCAREF00009513 Invited Lectures 1982 British Neuropathology Society (London) ('Prognostic Indices for Hunan Ependymomas") 1983 Ludwig Institute for Cancer Research. University of Bern ("Regulation of Neural Neoplasia") 1984 Faculty of Medicine. University ofLausanne ("Regulation of Neural Neoplasia") 1984 Institute for Brain Research. Zurich ("Elemental Mapping of the Human Brain") 1988 Swiss Neuropathology Society (St Moritz) ("Chronic Inflammation and Involvement of the Nucleus Ambiguus in Multisystem Atrophy") 1989 Alfred P. Sloan Lecture. Bryn Mawr College ("Transplacental inttfatim / postnatal Promotion: Fetal Risk from Maternal Exposure") : 1989 ID (UK) - Central Toxicology Laboratory ("Complete Carcinogenesis: Ultraviolet Light and . Chemical Carcinogens") 1989 ID (Americas) Wilmington. Delaware ("Initiation Irreversibility*) 1989 Food and Drug Administration - Toxicology (Wash. D.C.) (Tmtialion Irreversibility: Epidermal Studies") 1990 Food and Drug Administration - Toxacology (Wash. D.C) ("Imriation IncvcaMity: Non-Epidennal Studies") 1990 Eli Lilly - Central HQ, Ind. Ind. ("Carcinogenesis / Promotion Project") 1991 American College of Chest Physicians. Environmental Lung Disease. Fourth International conference 25 * 28 Sept 1991 ("The potential health effects from low dose exposure to tremolite in venmculits: An overview of the Libby, Eaoree, and the Paiabom experience".) (Montreal). 1991 International Congress ofOccupational Health and Safety. (Montreal) 7-9 Sept 1991 ^Haritgiwiiiil nigyrthaHiymac*} 1991 Defense Research Institute. Asbestos Medicine Seminar (Scottsdale; Arizona) 20 - 23 Oct 1991 Faculty (centre ("Mesothdionsa threshold") 1992 Dow Chrmkal Company (Saginaw, Michigan) 12 July 1992 ("Mechanisms ofFibre related dbene") 1992 International Agency for Research on Cancer. World Health Organization (Lyon. Fiance). Biopeiastence ot mineral Abies ("Potential hypersusceptibility the induction of in Kanmw tn pgramie fihrw thenrgrial biological mechanism*^ 1993 Lead Industries Association (LIA) ("Lead and cancer") 11 October 1993, St Loris, Ma u UCAREF00009514 PUBLICATIONS 1. Ilgren. E.B.. Tang. C.K. and Thorbjarson. L. (1976). Cynadenocarcinoma of the pancreas. New York State Journal of Medicine 76: 348*330. 2. Ilgren. EB.. Symchvk. P.S. and Redo. S.F. (1977). Pneumoperitoneum without rupture viscus in the neonate: a case report and review of the literature. J. Red. Surgery. 12:337*540. 3. Ilgren. EB. (1980). Polyploidfeation ofexoaembiyonic tissues during mouse embryugenesis. J. Emb. exp. Morph. 59: 103*111. <4. Ilgren. E.B. (1980). Die control of trophoblastic growth in tits guinea pig. I. Emb. exp. Morph.. 60: 405-418. . 5. Ilgren. EB. (I98t). The control of trophoblastic giant-cell transformation in the mouse: hotnotypic cellular interactions and polyploidy. J. Emb. exp. Miorph. 62: 183*202. 6. Ilgren. E.B. and Little field. J.W. (1981). The extra embryonic endodexmal differentiation and polyptoidizauon ofembryonal carcinoma ceils in vitro. Differentiation 19:115*20. 7. Ilgren, EE (1981). Die in vitro morphogenesis of the guinea-pig egg cylinder. Anat Emb.. 163: 331-365. 8. Ilgren. EB. (1981). Placental polyploidy: a comparative scidy in the mouse and the guinea-pig Placenta. 2:333-342. 9. Ilgren. EB. (1981). The initiation and control aftrophoMastic growth in the mouse: binudearion and polyploidy. Placenta, 2:317-332. 10. Hgrea. EB.. Oriner. L. Bemischke. K. and Pang; L.S.C. (1982). A comparative study ofpulmonary tumors from the San Diego Zoological Gardens and the Ttanour Reference Collection. Imperial Cancer Research Fond. London. Pathology Annual, 17:331-351. 11. Pearson. J., Ilgren. EB. and Spriggs. AJ. (1982). Lymphoma ceils in cerebrospinal fluid confirmed by chromosome analysis. J. Clin. Path., 35: 1307- 1311. 12. Ilgren. EB.. Brings, M. and Aynesley-Green (1983). Precocious puberty in a 3-year-old girl associated with a parasellar ganglionic hamartomas. Clin. Neuropath.. 2:95-98. 13. Ilgren. EE and Vans, D. (1983). The comparative pathology of teratomas. Cancer Surveys, 2(0:209 - 215. 14. Open, EE (1983). Review article: Control of trophoblastic growth. Placenta. 4:307-328. 15. Ilgren. EE. Evans. EP. and Brmenshaw. M.D. (1983). Origin ofthe mnidimdeate daddual cell of the mouse. Cytologja. 48:313-322. 16. Ilgren. EE (1983% CanMontyogeruc differentiation and tetatocaicinona formation in EC-derived chimacric placentae. Placenta, 4:415-422. 17. Sagar. HL, Etgren. EE. and Adams. C.B.T. (1983). Nevus ofOta associated with meningeal melanosis and intracranial melanoma. J. Neurosurg^ 58:280-283. 12 UCAREF00009515 PUBLICATIONS 18. Ilgrea. EB. and Hemachudha. S. (19831. Dissecting aneurysm of the pulmonary array associated with brain abscess: a case report Clint Neuropath.. 2:179-181. * 19. Ilgren. EE. Stiller. C. Stecfcei. M.. Silverman. P. ami Hughes. J.T. (1984). Ependymomasia finical and pathologicai study. Pan L Biological Features. Clin. Neuropath.. 3:113-121. 20. Ogrett. EB.. Stiller. C. Stedcei. M. SUberman. P.. Hughes. J.T. and Kaye. A. (1984). Ependymomas: a clinical and pathological study. Pan E Survival Features. Clin. Neuropathy 3:122-127. - 21. Ogres. EB.. West Moreland. D. and Adams. C.ET. (1984). Cerebellar mass caused by Candida species. 1. Neurosurgy 60:428-430. 22. Ogren. EB. and West Moreland. D. (1984). Tuberous sclerosis; Unusual associations in (bur cases. J. Gin. PaiiL. 37:272-278. 23. Ogres. EE and Teddy. PJ. ( 1984). Chemodectoma of the Cauda Equine: a case report. CTin Neuropath.. 3:148*132. 24. Ogren. EBy Teddy. PJ.. Vafidis, J., Briggs, M. and Gardiner. N.G. (1984). Clinical and pathological studies ofbrain injuries in horse riding accidents: a description ofcases with a wanting to the mhelwiaed. Gin. NeuropadL. 3: 233*259. 25. Ogren. EB.. and Jones, WJE (1984). A method to establishing short-tens cultures ofhuman gestational choriocarcinoma in vitro. Cancer Letters, 24:187*192. 26. Ogres. EE, Watt. F.W.. Grinre. Gy Takacs. J. and Vaux D. (1984). Elemental mapping of hmmm nervous tissue using the scanning proron microprobe. J. Neuroea. Methods, 12:23-28. 27. Raise. A.&. Ogren. EB., T/riingham. J. and Suit, J. (1984). Cerebral Toxoplasmosis, AIDE and HIV. Lancet 1:983. 23. Ogren. EB.. Saxton. D.Gy Jones. A.E and Duckworth. S. (1983% A potential nskaoneurosurgical method for mgfwpilawini nftin, itewjfaping nenmne tyorn nf>ht> pnawnplaiti-wirtw nrriwyn im L Injection methods. J. Nentoad. Methods. 13:191*197. 29. Ogren. EEy Kinmer-wnscn. LMy and Stiller. C. (1983). Gliomas in neurofibromatosis: a series of 89 cases with evidence for enhanced malignancy in associarrd cerebeiltr astrocytomas. Pathology Annual, 1:1*23. 30. Ogren. EE and Stiller. C (1986). Cerebellar Astrocytomas: Therapeutic management Am Netunchir., 81:11-26. : 31. Ogrem EB. aid Stiller. C (1987). Cerebellar Astrocytomas: Ginicai Characteristics and prognostic indices. J. Neuro-OncoL, 4:293-308. 32. Ogren. EJJ. and Stiller. C (1987) Review article: Cerebellar astrocytomas. Part L Macroscopic and microscopic llauues. CUn. Neuropath.. 6:183*200 UCAREF00009516 PUBLICATIONS 33. Dgren. EB. and Stiller. C (1987) Review article: Cerebellar astrocytomas. Pan 0. Pathologic fames indicative of malignancy. Gin. Neuropath.. 6:201*214 34. Dgren. EB. (1988). Multi System Atrophy: Possible central aetiology of the laryngeal dysfunction and the role oflymphocytic inflammation. Arch. Suing Neura. Psych. 139:73. 35. Ilgrea. EB. (1989). Mesothelioma Threshold. In: Effects ofMineial Dusts os felt* (Mossman. B. and Begin. R.X Springer-Vertag, Heidelberg; 1989, voL EJO, 455-464. 36. Dgren. E and Wagner. I. (1989). The value of experimental animals in analyzing the hazards of exposure to mineral fibres; H. Consideration ofnatural background incidence of mesotheliomas and itonphysiological imraperitoneal technique. Submission to the German MAK Commission on Mineral Fibre Safety. ISBN [0*9516339-0-51. 37. Dgren. EB. and Wagner. J.C (1991). Background incidence of mesothelioma: Animal and human evidence. Reg. Ton. PhantL, 13:133*149 38. Hgres. EB. and Browne. K. (1991). Asbestos-related mesothelioma: Evidence for a threshold in hntnans and animals. Reg. Tax. PharnL, 13:116*132 39. Brawn. R~ Davis, Douglas; D.. Gnxber. U.. Hoskins. Ogren, E. Johnson. N,, Ressner; G and Wagner. J. (1991). Carcinogenicity ofthe insulation wools Reassessment ofthe (ARC Evaluation. Reg. Tox. Phatm, 14:12*23 40. Ilgren. EB. (1991) The potential health eflfcca from low dare exposure to tremolite in vernncnlite: An overview ofthe Libby. Enoree. and the Palaore experience. (Ahstrao|. Fourth International Conference, Environmental Lang Disease. 25*28. Sept 1991 MaaneiL . 41. Dgren. E (1992) Potential hypermsceptibility to the induction of mesotheliomas m beifltstBKS exposed to ceramic fibres Theoretical biological mechanisms. Reg. Tax Phann (submitted! . Boobs: Ogren, E [1991] Initiation and Promotion in Skin or Liver Neoplasia: A 65 year annotated bibliography ofinternational literature. CRC press. 928 pp. ISBN - 0-8493-4407-7 Ogren, E [1993] Mesotheliomas of Animals: A comprehensive; tabular compendium ofthe world's literature. CRC press. 356 pp. ISBN - 0-8493*4308-9 14 UCAREF00009517 --- kfalbiMB e. 8. ILCRSN, KA. HO, OPftll. HACPttli. HRCPacA (AM./NurapcAolo) FACULTY OF BIOLOGICAL SCISHCSS. SUBPACULTY OP AtOCHEMISTRY, university or oxford, sr ecnuho hall, oxford ANO REStARCH orrxcat. IMPERIAL CAHCXR RESEARCH FUND, CLINICAL TRIALS STUDY UNIT NurriSLo department or clinical medicine, JUDCIXITE INFIRMARY, OXFORD. UCAREF00009518 CUMICULUH vitae Or E. I. Ilron, MA (Oxon), MO, O.Phil.(Oxon), MAOPaeh, MHCPteh (A4oci*t/Nuropxthclofy) P*te of Eirta; 13.vili.SO Plxco of Birch: Philadelphia. Ponnxylvanla, USA Mcionalley: Aoxrlean pntsarr positioh Hoabor of faculty of Biolofical usd Africa!rural Seianeaa and Subfaculcy of lioehai*ery, Uhlvoraiey of Oxford floaoarch Ofritif. Imperial Cancer'Jtaaoarch fund. Cancer SCudlca Unie Unlycraley of Oxford ' Kuffixld DepartaenC of Clinical Medicine Dio Badellffe Infiraary Oxford 0X2 6HS UCAREF00009519 r 0 ( EDUCATION tHSTTTTiTTjH AMD LOCATION ' OBCRSZ M. FISLD Of ffimr giffnaRsa IHIimmflg Medical University American Callage of Paeholegy University of Oxford Xoftl College of Pathology OX (Primary) Ualveralty of Oxford, Oxford, UX MD HACPath D.Phil (Oxoa) MSCPash HA (Oxoa) 1974 1976 1980 1982 1963 Medlelaa Aaatonie Pathology Zoology/Boesny Neuropathology Bioiogy/Medleiae rxsrarcx mm professional gpgiswa - chrokqlqgt 1973 Student Worker, Dope, of Cooperative Nauroanaceay, Tho Bryn Mavr Collate,` Bryn Mxvt, Peaaaylvaaia, USA. 197A Doetorasa of Kadleina, Tho Hahaeaann Madleal Collago, Phlladalphia, Peaaaylvaaia, USA. 1973/74 Viaiting Realdane, Tho Ktmorial Hoapital for Caacor 6 Allied Oisaaaea, attached co Or. V.8. Joaoa, Coaauleaae Gynaecological Surgooa, Trophoblastic Dliau 1974 Centre. . Aeaistant Peehologlet, Tho Vow Tork Bbopleal - Caraoll University Medical Castro. / (Tew Tork City. 19fP Aaeiatant Forensic Paehologlat, Offlea of tho Medical Exaoiaar, Tho Saw Tork 1975 Uairereity Madleal Caatra, Or. M.C. Badaa (Spoaaar) - Chief Madleal Exaoiaar. Oiplooata of eho National Board of Madleal Zxaolaerx (USA) 1975/76 Visiting Selaatiat, Roekafallar Zaaeleaea of Madleal laaaaxeh, Profaaaor A.C. Braun (Bead of Oaparteasc). Or. Z.C. Olaeuaakea (Laboratory of Cytcbiology, Hoad of Department). 1975 Licensed la Medicine tad Surgery, State of New Tork, Mo. 124849. 1976 Member, American Collage of Paehologlata, Board Certified, American Board of Pathology, Aaatoole Pathology. 1976 Vuitlag Worker, The laperial Cancer Baaaareh Fuad, Dope, of Pathology, Undos - Profaaaor R.A. VUlia aad Or. L.S.C. Paag (Bead of Departaent). 1977 Vlaitlag Raaaareh Selaatiat (Unlv. of South California at San Diego, San Diego Zoological Society cad Dept, of Pathology, Prefoaeor Scairtehke - Spoaaor. 1977 Travelling Research Fellow (International Union Against Cancer) - Geneva, Svitearland. 1976/77 Poatdoetoral Raaaareh Fellow (Xataraatlonal Agency for Caaear Raaaareh/Vorld Health Organisation), Dept, of Zoology, University of Oxford, Profaeaor R.L. Gardner (7RS) - Spoaaor. . 1976/79 Spoeiel Poatdoetoral Raaaareh Follow (Aaerlean Cancer Society -epf-1.4}, - Laboratory of Experimental Mammalian Embryology, Unit, of Oxford, Professor R.L. Gardner, (FIS). 1978/79 Reeearch Fallow (XXX), Dope, of Zoology, Laboratory of Experimental Kansalian Zabryology, Unlv. of Oxford, Profeasor R.L. Gardner (FRS) - Sponsor. . 1979/80 Visiting liweareh Worker (MIX), Sir Willies Dunn School of Pathology, Unlv. of Oxford, Oxford. 1980 D.Phll (Oxoa), Dope, of Zoology 6 Botany, UnitJ of Oxford, Member of St. Sdouad Hall. 1979/80 Raaaareh Fellow (XIX), Botany School, Laboratory of Cytology, Unit, of Oxford, Oxford. Profoooor F, Vhaclay, FRS, aad Or. C. Voaa (Spoaaore). 1960/81 Honorary Senior Registrar, Neuropathology, The Xadeliffe Infirmary, Oxford. 1980/81 Research Fellow (XIX), Dope, of Neuropathology, Tho Radellffo Infirmary, Oxford. 198#'| Senior Raglacrar. Xauropathology, Tho Radellffo Infirmary, Oxford. 198s Patholegiae to R.M. Coroner. Mr. N.C. Gardiner (Oxfordshire). 1962 General Madleal Council, Full Registration. m 1982 Recipient, MRC Project grant award "Embryonic Regulation of Neural Neoplasia." 1983 MA (Oxoa) - Seatuo: Primary, >MRC?eeh (Neuropathology). UCAREF00009520 1983 1983 1983 1984 1984 1983 (Loess} Consultant Neuropathologist, The Radeliffe Infirsary, Oxford, Juno 3-17, 1983. ' -- Heaber, Depcreaeas of 8iochecietrr, University of Oxford. Subfaculty. Heaber, Oxford Nuclear Physics Proeon Mleroprobe Users Group. KMber. faculty of Blcleeieal Sciences, University of Oxford. ' Co-recipient. Health 4 Seise; Ixecucive project grsnt sward} eo-recipient wish Professor P. Shubik, "tree Chelationi An eeesepe to develop s possible chsrspy for those se risk free sxpasars eo ssbestoe bp iehiblcisf fores doa, porsistenos, sod offsets of asbestos bodies la rive," Reelpleat. Oxford Arse Health Authoriey/Diatrtec Research Grant Award "labryonic regulation of aeoral neoplasia." Daces (aonth 8 year) free JSL June 1974 Juno 1978 June 1978 Sep. 1978 Doe. 1978 Juae 1977 Juno 197^ , Juae 1978 Juae 1978 Sep. 1980 Sep. 19.$L Juno 1983 Sep. 1980 j June 1983 Dee. 1984 'Dee. 1983 I July 1984 | Apr. 1987 Heat and address of saolotir (blockJlsetireL few Tort Hoepltal/Carsell University Med. Ceatre Office of the Modieal Eraaifisr Oft) How fork Uair.Med.Centre lad. Agoney for Research on Caneer/Vorld Health Orf, (Iron) Aaerlcaa Cancer See. (NY) NXS (Bethesda, HD) ' HH Coroner (Oxford) Xoeional Seeleh Service (UT) Health A Safety Executive (Loadon) Univ. of Oxford* Research Follov/Tseulty Keabor/ Biological Seiaaeaa Aasiataat Pathologist. Aaatosie Path. (Xaglstrsr/Sr. Hag. Grade) Assistant Pathologist, Forensic Path. (Sr. leg./Consultant Grade) Research fellow, Zebryology, Cell Biology, Oncology (also see *leaserch Experience') Research follow, Exbryology, Coll Biology. Oncology Reseerch fellow, Eabryology, Cell Biology, Oncology - Foroaaic Neuropathology, (Senior Hagistrar/Conaultant (Locus) Grade) Neuropathologist (Senior Registrar/ Consultant (Locus) Grade)* Research Pathologist (joe 'Research Sxperlenea *) Toxicologist u (' Apr. 196? ?rae Ci U Aaerlcaa Industrial Health Council (AIHC) Xntarnatloaal Life Seiaaeaa Institute (ILSI) Certified Color Meaufacturera Aasoeiatioa (CCMA) flavor Extract Hanuiaeturers Aaaeciaelon (HMA) Research Institute for fragrance Materials (RUM) Cheated Kaaufsecurers Assoeistloa (Ctt) Praetor 4 Cesble ' Coca-Cols Coepeny PepsiCo Unix, of Oxford/Xaperlel Raeooreh Officer Caaeer Roe. fund. Cancer Studies Unit, Nuffield Dept, of Clinical Medicine] Radcliffs Infirmary, Oxford UCAREF00009521 Details af training, Boot qualification raaearch period# 1 f73/T* Visiting Resident, The Memorial Hospital for Cancer & Allied Oiseaeee. attee. co Or W.I. Jones. Consultant Gynaecological Surgeon. Trophoblastic Olsesse Centro. 197* Aeeistanc Pathologist, The New York Hospital - Cornell University Medical Centre. New York City. ' 1973 Aeeletanc Forensic Pathologist. Ofrice of Che Madleal ExaminerThe New York University Medical Centre. Or M.C, Baden (Spenser) Chief Medical Examiner. 197) Oiplomete, National Board of Medical Examiners (USA). 1973/76 Viaitinc Seleneice. Rockefeller Institute of Medleal Research, Professor A.C. Braun (Head of Department). Or B.C. Oiaeumakea (Laboratory of Cyeo* biology, Head of Department). 1979 Lieenaed in Medicine and Surgery, State of New York, No., 12*8*9. 1976 Vlcleinf Worker. The Imperial Cancer Research fund, Oepe. of Paehclogy, London - frofeaaor R.A. Willie and Or L.S.C. Pang (Head of Department). 1977 ' Vtalelnf Research Sc lent let (Unlv. of South California at Sen Olegs, San Oiego Zoological Society and Oepe. of Pathology, Profeeeor X. Benlrechke - Sponeor. . 1977 Travelling Research Fellow (International Union Againat Cancer ) - Cenevi, Switaerland. 1976/77 Peecdacterel Research fellow (International Agency for Cancer Beaeareh/World Health Crganiaatlon). Oepe. of Zoology, University of Oxford. Profeeeor ft.L. Gardner (PRS) - Sponeor. 1976/79 Special Poetdoctorel Research Fellow (American Cancer Society -epf-l*). Laboratory of Experimental Mammalian Embryology, Univ. of Oxford, Oxford * Profeeeor R.L. Gardner, PRS. 1978/79 Research fellow (NZH), Dept, of Zoology, Laboratory of experimental Mammalian Embryology, Unlv. of Oxford, Oxford. Profeeeor R.L. Gardner (FAS) - Sponeor. 1979/80 Viaiting Reeeareh Worker (NZH), Sir William Ounn School of Pathology, Univ. of Oxford, Oxford. 1979/80 Research fellow (NZH), Botany School. Laboratory of Cyeology, Univ. of Oxford, Oxford. Profeeeor F. Whatley, FRS, and Or 0. Voaa (Speneore). 1980/81 Honorary Senior Registrar. Neuropathology, The Radcliffe Infirmary. Oxford. 1980/81 Research fellow (NIK), Oepe. ef Neuropetftology. The Radcliffe Infirmary, Oxford. 1982 Senior Registrar, Neuropathology. The Radellffe Infirmary, Oxford. 1982 Pathalogict to H.M. Coroner. Mr N.G. Cardiner (Oxfordshire). 1983 (Locum) Consultant Neuropathologist, The Redellffe Infirmary, Oxford Juno 3-17, 1983. . * 198* Co-recipiant, Health A Safety Executive project grant award: ce-recipiene . wieft Profeaeor P. Shu hi k, 'Iron Chelation: An attempt to develop a possible therapy for ehooo at risk from expoaure to sebestoe by inhibiting the formation, persistence, and effect# of eabeatac bediee in vivo'. UCAREF00009522 HgHBEMHlPS Oxford Uni** -oity Computor Contrt Uooro Croup faculty of Biolofleal Sclaneoa, Univ. Oxford luhfaculey of Siochaaiaery, Unlv, Oxford Irieixn Hodloal Aoooeixeion (IMA) Oxford frocon Mieroprodo Croup, Dopt. of Nuclear Phyciex, Unlv. Oxford Mourooeioneoa Spoeialty Croup, Unlv. Oxford Irltlah Society of Nuropatftolofi*ta (13N) Royal Collar* of Patholopy (A**o.) Neurofibromataxi* foundation (USA and UK) Tubaroux Seleroei* Aoaociation (UX) Irltixh Society Oevolopment Bioloflete (6308) St fdound Hall (Hlddlo Common Room), Unlv, Oxford 1945 ^ 1964 . 1984 1943 1961 19a! 1961 1961 1941 1979 1976 Ic I f I AWAR03 Oxford 01*triet Roaaaroh Grant Award ' Embryonic Regulation of Neural Neoplaeia) Health * Safety Executive Project Grant Award (Potential Therapy... Aabeacaala) M*dleal R*oaroh Counoll Prelect Crant Award (Embryonic Regulation of Neural Haoplaala) National Inae. Health Poatdoetoral Training Award (Control of Trophodlaaeio Crowed) American Cxnear Society 3o*eial Poatdoetoral Award (Control of Tropftoblaaela Growth)' Inti. Agency for Roareh Cancer Postdoctoral Award (Control of Trophoblaatle Growth) I.itl, Union Againeg Caneor tICRETT) Award (Comparative Pulmonary Oncolofy) How 1949 July 194: Sapp 1944 July 1943 April 1962 Sept 1944 Juna 1978 Sept I960 June 1976 June 1974 Oae 1976 Juna 1977 Juna 1977 July 1978 UCAREF00009523 ftS5AHCH SxrS3!SMCt The applicant *** maintained, *a oeraistenc theme throughout hi* career. iftStp . in both the &**lc and clinical aspaeta of :n# tumour problem. These are outlines iJJ1 Rockefeller Uniworoitv. I97<*t973 * The applicant. in collaboration vita n. t.C.Oiecumako# (Kookafaller University) and Of W.8.Jones (Memorial Hospital TaCencer), *ss tho first to 8**ow choriocarcinoma in vitro without recourse to m,i hast*, work eonductad In combined clinical and experiments! study of the relational n between HOC aeration end malignant trophoblastic groven. The reeulta or tnia study suggested that tnt aoerotory activiey and cellular proliferation of aeli^ane eropno' blaae *y. at tinea, be dlssoeiatad phenomena In vitro. a conclusion confirmed by obaervationa node, on rare occasions. In vivo. Since these experiments were originally toad at mapoing the HOC gene vie cell hybridisation, the applicant also mastered teennicues. developed by Or Oiacumekoe, for aierosurgleal eall fusion, chreesom* extraction, nuelear and cytoplaamlo cell Injection, and single coll cloning as wall at methods needed for the cytogenetic analysis of such cloned cell lines. Whilst at Rockefeller, the applicant also had numerous discussions with Professor Artn-Sraun on Eplganatie theory, tumour suppression, and recovery. These Mrs baaed on Profee tor Sraun'e Crown Call Teratoma Model System and laid eho foundation for son* of the applicant's future experiments. Oxford Unlvartiey, 1978*1981 - Oeot. Zoology - The perplexities of working with a malignant tissue that, even in its normal stats, ofCan behaved in a manner similar to e tumour, led the applicant to pursua studies of normal trophoblastic growth and developmental mechanisms generally thought to be related to neoplasia. Such atudlts were pursued in Oxford in the microsurgery laboratory of Prof. *.1.Gardner, a leading experimental mammalian embryologist. These studies culalnaesd in a seriea of publi cations (described under 'Ooctoral dissertation* J and uaed a wide range of technique* including mieroaurglcal injection, disaeetion, enzymatic separation, and/or tissue culture of pre- and peat* Implants cion embryos and their constituent tissues. The Ut:r wore analysed biochemically, hlstoehemietlly, eytologlcally, cytogenetically, hists- logically, and cytophotomatrically uaing, in acme caaea, method# developed by the applicant. Embryo transfer and tumour inoculation method a were also employed in these studies. . Oxford University, 1980-1981 - Oeot. of Botany - Preparations of trophoblastic giant calls wera analysed eytologlcally, cytogenetically.and eytophetomaerically in the Sotany School with tfta advlea of two eolnant cytaloglits. Or C.C.Voaa and Cr f .A.L.Clowes. These analyses wore primarily directed at aaaaaaing.ONA lyr.tnetis and enromoaoma structure and the results ars deacribtd under 'Ooctoral dissertation*. Cxford University, 1080*1981 * Sir William Ounn School of Pathology - Embryonal carci noma (EC} cell-dariveO mouse cnimaeraa wore produced by the applicant using Prof. Gardner's blastocyst injection methods and the mature chlmeerlc tissues were tubsecuently dissected into their constituent parts, ectoplcslly transferred to syngeneic -hoete, and observed in host aitee for tumour growth of donor eall origin. Since ectoplcslly transferred, ehimaaric, placental tissues were the only ones to fern tumour*, it was concluded that placental, in contrast to somatic tissues, lacked the ability to suppress tha tumorous phenotype. Oiacusilona with Prof. Armln 8raun subse quently led the applicant to ask If tumour eell types other than these of EC cell origin, could colonise tha embryo end, in turn, be tuppreeaad or regulated by :ne embryonic environment. Since it was likely chat this would occur with 'develcpmentally synchronised*, donor-host call combinations, e.g. wnn neuroblastomas were injected into the normal neuroblastle tissues of the embryo, a microaurgieal method -** developed for the manipulation of poet implantation mouda embryo brain in utro. Oxford University, The Padcllff* Infirmary. 1981-1983 Pent, of neuropathology. Th * * method we* developed in the Qept. of Neuropathology, The Aadeliffe Infirmary, OxfsrC. Although tha method permitted Injections to be performed with marker substance*. c*l.| were newer injected. Still Che materiel* needed to produce the appropriate donor-*"*1 eell eamotnetione were obtained, these differing in#-Clueuronias* (-Cue) nn Clues** UCAREF00009524 d I nesEArtCH exrsmewcg The eoblleant h maintained. as a WftUtint them* throughout hit career. interei*. in SoeJ* the basic and clinical aspaeta of the tumour problem. These are outlined j,i3w' Bachefeller Unjyereity. 197 ;?5 - The applicant, in collaboration vica 5r g.C.Piacumekos (Rockefeller University) and Or W.fl.Janes (Memorial Hospital Tar Canesr), was an* firte to grow choriocarcinoma In vitro without recourse ta a/ui hosts. work eondueted in a combined clinical and experimental study of cue relation*#!, between HCC secretion and malignenc trophoblastic growth. Th# results ar enia atudy suggests* that cne aacretary activity and cellular proliferation of malignant tropnc* blaat may. at tinea, be diaaeciatad pftengaana in vitro, a canclutian confirmed by abaarvatiana made, on rare aceaalona, in vivo. Since tneae experiments were originally aimed at mapping the HCC cans via cell hybridisation, the applicant alaa nattered teenniduee. developed by Or Oiaeumskoo, for mieroaurglesl cell fualan, ehrcm.csome eacraction, nuclear and cytoplaamte cell injection, and single cell eloninc aa veil as methods needed for tfte cycogenetle analyaia af such cloned eell linee. Whilst at Rockefeller, tha applicant alee had nuaieraua discussions vitn Professor Araln Braun on Epigenetic theory, tumour auppraeaien, and recovery. Theae were based an Professor Braun's Crown Call Teratoma Model System and laid the foundstion far sane cf tha applicant'a future esperimanca. Oxford University^ 1976tW - Oept. Zoology - Tha perplexities af working with a malignant tiaaua that, even in ita normal atata. oftan behaved in a Banner similar ta a tuaour, lad tha applicant ta puraua atudlaa of normal trophoblastic irewth and developmental aaeftaniana janerally thau*ht ea ba ralatad ea neoplasia. Such atudlaa vara pursued In Oafard in the aicroeurcery laboratory of Prof. R.l.Gardner, a leading experimental mammalian embryologies. Thata teudlea culainatad in a aeries of publi cations (daacrlbad undar 'Ooctotal dissertation') and used a vida range of technigues ineludinc mieroeyrgieal Injection, diaaection, entyoatic eeparaeion, and/or tissue culture of pr- and pas c - tap Ian ta cion aabryoo and their constituent tissues. The lattsr were analysed biochemically, hlstochsnically, eytolafically, cytogenetically, hist:* logically, and eyeaphaeomaerically using, in terns caaet, methods developed by the applicant. Embryo tranafar and tumour inoculation mttnoda wart alto employed in these studies. - Oxford University, 1980*1931 Oept. of Botany Preparation* of trophoblastic citn: cells were enalyeed cycologically, cytogenetically. and eytaphotemterisally in the Botany School with the advice of two eminent eytologiata, Or C.C.Vaaa and 3r P.A.L.Clove*. These analyses were primarily directed et assessing, ONA synthesis and enromoaome structure and the results arc described undar 'Ooetoral dissertation1. Oxford University, 1980-1981 - Sir William Ounn School of Pacholocy - Embryonal ears;* noma (EC) eall-darlved mouse ehlmeerse vara produced by tna applicant using Prof. Gardner's blaaeocyae injection methods and the mature chlmaerie tlaauee were *ub*euently dissected into choir constituent parts, ectoplcally transferred to eyngtnei: hosts, and observed in host sites 'for tumour growth of donor call origin. Since ectoplcally transferred, chlmaerie. placental tissues were ehe only ones to fom tumoure, it was concluded Chat placental. In contrast to somaeic tissues, lacked tnc ability to suppress the tumorous phenotype. Olecusslone with Prof. Araln Braun subs*evencly lad ehe eppllcent to esk if tumour cell types other than those of ES cell origin, could colonise the embryo snd, in turn, be suppressed or regulated by m* embryonic environment. Since it wa* likely that this would occur with 'develepaentaliy synchronised', donor-host call combinations, e.g. when neuroblastoma* were tnjeeted into the normal neuroblastlc tissue* of ,tha embryo, a mlcroaurgleal metnad * developed for tne manipulation of post implants cion mouse embryo brain In utero. Oxford University. The Badcliffe Infirmary. 1961-1381 - Oeae. of Heurooatholagy. Th-.t method was daveloped in the Oept. cf Neuropathology, The Badcliffe Infirmary, Cxfcrd. Although the method permitted injections to be performed with marker substances, cel.* were never injected. Still the material* needad to produce the appropriate Conor*""*' eell eamolnetlons were obtained, theae differing InS-Glucuronldase (-Cue) nd Cl'.cste UCAREF00009525 oocToiui oissEatmoH summahv 1. Control at trophoblastic proliferation tn early goat implantation *wm develoow... Several sandielan* sre needed to promote the growth or poet implants don mouse tropho- blaat. Firstly. an aopropriate dsaue shape and close call contacts art needed to ' suppress tne trophoblastic plane call tranaforinatlon and maintain ttiaaa tissue* in a largely diploid, non.plane testa. Moreover, ainet an appropriate tlseu* aliapa cannot, on Itl own. promote trophoblastic call dlviaion. XCM-derlvatlvaa. e.g. sseraembryonic endedten and/or masodarm, ara probably also naadad to stimulate normal tropnqolaaeic growth. ' 2. Control of trooftobUatlc arollfaratlon tn the guinea ala: The growth or guinea pip tropheetedsrm and lea sarly poaeimplantaeion derivative* appaar to be under tCM control. Thus, tfte multilayered attachment^eon* of eh* guinea pip blastocyst la probably not duo to an !CM>independent ofproliferation tropheccoderm but la moat likely derived from e trenelent accumulation of abembryonle trophettodermal cells. . J. Oriein of the croahablastfc giant cells: blnucleetlon In tftt nouee, postlmplantaclon tropftoblatt appears to become plant tiiroupn a blnueleaee . phase. Thu*. che proven of mouse trephectodara occurs, to a certain astane. in a manner similar eo the polyploldiaatlon of mouse liver. #. Oridn of the erophoblaatic giant cell: multlnucleaelon The flndlnp of multinudeates In pure, trepheetodera-declved tleeuea euppesee that erophoblaatic multlnucleaelon, at least in the mouse, docs not depend upon prior con- teee with aeaenchyae or moaenohymal tissues. Multipolar, polyploid nltotlc figures were found In mouse decidua, tissues known eo contain multlnuclsates similar to the onea seen in the trophoblastic derivatives of ruminants. This suppssts that -the multi* nucleate cells seen in some forms of trophoblast may arise in a manner similar eo those found in rodent doeidual tissues, l.a. via a multipolar mitosis without concomleant cytokinesis. " 5. Mechntm by which OMA accumulates durlne the troohoblssele clsnc cell trn* formation Polyploid metaphaaes were found within poatimplaneatlen Rouse trophoblast that Hod chromosomes arranged either randomly or In pairs. This suggests that at leaet seme mouse trophoblaatle cells Increase their ONA via polyploid mitotic and/or endomitocic cycles. 6. Control of the trophoblastic Slant cell transformation The degree to which trophctodsrm-dsrived cells endoreduplicste their nuclear jenomo and thus become giant can b< Influenced by changes in tisaua shape and the cstent of intercellular contact. Thus, cell separation, spreading, and stretching appear to promote the giant eeil change not only within tropheetodermal derivative* but also witnin tissues known to behave in a manner similar to trophectodsrm, namely escre* embryonic endodorm. Moreover, the giant ceil* round In normal and neoplastic extra* embryonic tiseuee are noe neeeetarlly terminal end incapable of eell division tine* they may be found in mitosis either before end/or following mltogenle stimulation. Comparative studlee also suggest that the onset of the plane cell chance in one-extra* emaryanle membrane may be temporally correlated with the development enc.'or degeneration of a nearby placental tissue layer. - UCAREF00009526 Phosphate laoeicraao (CPI) allelet. The putative donor cello, Spendymoblaseema (S) V4., epl-4 -^j (heel stable> derived fro* A/J nie end the isoct embryos were CPI-8 . (heat labile) derived from C57BU met. the tP tumour being able to trow within and **> C37BU eduita. loth tumour eell Unoa and mouse ealoniee were* maintained for alaaet ce year*. In addition to tfteae experimental studies, aeverel hlstopatholegiesl reviva were performed. The first of theae deaeribed. in separate publications, gnueual aeaociatlana in hamartoma toua dysgenetie disordera either or neural erase fe.g. Intra-ersnloi melanoma and Maavya of Ota) or nonneursl erase (a.g. Tuberous Sclerosis with Sarcomas and Adeneearclnemaa) origin. The second review provided the firse evidence ea suggest that the Hf gene in Neurofibromatosis may not only predlapoae the neural creae-derivd Schwann cella to undargo malignant change but sleo may affect, in a similar way, the non-neural ertae. glial darivaelvea of ehe cerebellum. The epolicane also analysed some of rhe largest icriaa of ependymomas, esrebellar astrocytomas, medulloblastomas, and craniopharyngiomas using computer-assisted techniques and detarmined a variety of clinical-pathological prognostic indices far each of these tumour types. Oaford University. 198b Oeot. of Nuclear Physics - The applieane, in collaboration with the Oaford proton microprobe group, vaa the firse to demons tries ehe endogenous elements of the human brain with the proton mleroprebe ehereby generating an 'elemental map* which closely-corresponded so the normal architecture of that tissue. Imperial Cancer Research fund. Tumour Soferenca Collection (TWC) and the Sen Ditto looloclcal Neacarch Hospital (SOI). 197b - The applicant mads am eatensive hlatonataologicai review of a large scries of pulmonsry tumours found in captive wild anlmaia (S02) and various domestic 'species (TRC), the results confirming previous reports thst most animal lung tumours art of the alveolar eype.i.e.tne one not generally assn in association with smoking. Oaford Unlvartity/Toaicolocy. lffl to present - Under the direction and with `the assistance of Prof. P.Shubik, the applicant has been Investigating methods of modifying ehe inflammatory response eo croeodillee and ehe zeolite, erlonlte. Such investigations are aimed at blocking the formation of the ferrugincuc body and efta accumulation of excess tissue iron in the hope that this will lesaen the inflammatory response and she attendant risk of neoplasia which follows the inflammation. UCAREF00009527 I r a. ( I PUSliWTIOM . 1. 2. ]. 9 5. 6. 7. 8. 9. 10. H. 12. 13* L9. 15- 16. 17. (8. 19 20. 21. 22. 23. Hpron. C.l. (1910). Polypioidlxation of extraembryonic tissue* during emoryopenosls. 7. Emb.exn.Mmrph. 59:103-111. Hpren. C.l. (I960). Tli control of trephoblaatle proven in the puinea p{(. J.Emb.ean.Morph. 60:905-918. ` Hpron, C.l. (1981). Tha control of trophoblastic pro*tft in efts mouse: ftonocynie callulcr interactions and polyploidy. J.Eab.eip.Morpft. 62:183-202. Ilpre. C.8. and Littlefield, J.w. (1981). The eseraembryonle endedo'rmei differentiation and polyploidlsatlon of embryonal esreinoms calla in vit.-p. Differentiation 19:115-20. " Ilcrcn. 5.8. (1981). Tha in vitro merpnopeneais of cn jvinea-pip pp cylinder. Anatomy and Smbryolopy 16):351-365. Ilcrcn. S.8. (1981). Placental polyploidy: a comparative atudy. Plaetntt 2:333-32. Heron. .8. (1981). The control of crepheblaatie proven- in ttio aouaa: hj. nucleitian and polyploidy. Placenta 2:317-332. Heron. C.8.. Crinar, L., loniraehko. X. and Pane, (,.8.0. (1981). A comparative atudy of puloonary tuaourt. Paeholopy Annual 17:331-351. Zleron, E.8., Brlpgs, H. and Aynaaloy-Oroon (1982). Prococloua puberty and eanelionic hamartomaa of the parapituitary. Clin.Neuropath. 2:95-98. Zleron, 5.8. and Vaux. 0. (1982). Comparative morpholoeical atudy of aouaa and human teratoma. Canear Survoya 2(1):210-215. Heron. C.l. (1983). Xsviaw artiela: Conerol of trophoblastic proven. Placenta 9:307-328. Zlpran, 8.8., Svano, 5.P. and Bireenthav, M.D. (1983). Oripin of tha multi- nuelaata dacidual call of tha mouao. Chromotama 98:313-322. Zlpran, C.l. (1983). Cardloayopenic dlffaronelatlon and taratocarelnoma formation In SC-doriyod chimaric placentae. Placenta 9:915*922. Zlpran, 5.8., Stiller, C., Bttckol. X., Silborman. P. and Hucnea. 2.T. (1983). Ependymomas - A aerial atudy of tholr provth, Part Z. Bieloplcal feature!. Clin.neuropath, 3:113-121. Zlpran, .8., Stlllar, C, Stackol, M., Silborman, 0., Hupheo. 2.T. and Xaye, A. (1983). Spondymomaa - A eerial atudy of eheir provth. Part IZ. Survival features. Clln.Mouropath. 3:122-127. Zlpran, 5.8., Westmoreland, 0. and Adana, C.8.T. (1983). Cerebellar Psaudoeumour due to Candida (Cara beliar Candidoma). J.Mauroturp. 60:928-430. Paaraon, J., Zlpran, 5.8. and Spripps, A.7. (1983). Lymphoma cells in cerebro spinal fluid confirmed by enromosome analysis. J.Clin.Path. 35:1307-1311. Sapar, H., Zlpran, C.l. and Adame, C.8.T. (1983). Naevua of Oea. Haninpeal Melanosis and Intracranial melanoma. J.Mouroaurp. 58:280-283. Heron, C.l. and Wilaon, X. (1985). train Tumour* in Mouroflbromaeosis: Evidence for Enhanced Malipncnt Potential. Pctholopy Annuel. 1:1-25. Heron, 8.1. and Mamachudha, S, (1983). Ruptured Pulmonary Areary Aneurysm and Brain Abacas*. Clin.Mouropacn. 2:179-181. Zlpran, 5.1. and Waacaoroland. 0. (1984). Tubcroua scltrosla: unusual associ* atlona in four cases. J.Clin.Path. 37:272*278. Zlpran, 5.3. and Teddy, P.2. (1989). Chcmodedtoma of the Cauda Eculna. Clin. Mouropath. 3:198-152. Zlpren, 8.8., Taddy, P.J., VtfidlX. 7.. Brlpps. M. and Cardlnor, M.C. <195* 1. Clinical and patholopical studies of fatal brain injuries in hors* ridlrp accidents: a description of cases vtth a warning to tha unhelmeeed. Clin, neuropath. 1:253-259. 24. Zlpran, 5.8. (1984). Idiopathic intracerebral haemorrhapt in a case of maturation of mmtastseic Wilts' tumour. Clin.Neuropath. (in press). 25. Ilpren. 5.S., Olacumakoa. .0. end Janet, w.B. (1984). A method for eatablleM.-a snort.term euleuree of humon peStetienel enoriocareinomm In vitro. Ceneer Lette-e J#-ti?-lO? UCAREF00009528 1 r I r 1 26. Xlfreit. .3., Watt. P-W.. Crime*. G.. Takaea. J. and vux. a. (;58i: Elemental mapoinc of human nervoua tiseue ualn* the aeanninc proton aters probe. J.heuroael. Metnoda. 12:25*28. " 27. Aalno, A.G.. Ilcran. .8.. (.edinchaa. J. and Kurt*. J. (1989). Cerebral Toxo piaamoeie, AIDS. and K7LV. lancet. 1:983* 23. Zlcran, 2.3.. Saxton. O.G.. Jenea. A.E,. Duckworth. S. (1984). a poeanti* mieronauroaurcical aaenod for the manipulation of tha dtvaloplnj rfarvou eyatam of tha poatlmplantation oouaa embryo in utaro. I. Injaetia. method*. J. Mcurooci. Methods. 13:191-197. 29. llsran, .3. and Stiller. C. (1986). Carabellar Aatracytaoas: Cli.-.ica Feature* Part Z. Aaea Kauraehir. 8l. 11-26. 30. Zlcran, .8. and Stiller. C. (1987). Cerebellar Aatraeytamaa: CUnlta Paaturaa - Part II. J. Neuro-Oneel. 9, 293-308. 31. Zlcran, .3. and 3elllr. C. (1987). Caraballar Aatraeytamaa: Patholeslta Paaturaa - Part I. Clin. Neuropath. 6, 185-200. 32. Zlcran, .8. and Seillar. C. (1987). Caraballar Aatraeytamaa: Patholocisx Paaturaa Part II. Clin. Kaurapatn. 6. 201-219. 33. Zlcran, .8. Aylavard. 8. and Seillar. C. (1985). Medullablaeeeaaa: Cliniea. and Pathelofieal Paaturaa (in prap.l. 39. Zlcran, .8., ?an, C.K. and Thorbjaraon, L. (1975). Cyaeadaneearelnoaa e the paneraaa. Haw York Seata Journal of Madiaina 70:593-550. 35. Zlcran, E.S. and Symeftyk, P.3.(1976). Pneumoperitoneum without ruptur vlacu* in tha nawbern. J.Pad.Surf. 12:537-590. 36. Zlfran, .6. (1987). Aapartama: Tha Safety Xaauaa. Arch. Toxicol (aubaittad). 37. Zlcran. .3. (1987). Multlayatam Atrophy and larynceal Oyafunetian: Svidanc . for involvement of tha nueleua ambicuua. (in prap.l. Book*. Zlcran. E.3. and Shubik. P. (1988). A erltieal annotated bibliacraphy of epidersa and hepatic tumour promation. Oxford Unlvaraity Preaa. 399pp. Ucran. .. Shubik. P. and Salotti. P. (19871. Tha Irravaraibility sf Initiated Seata - A erltieal reappraisal. Appendix: Method* used to Sstab.ian Interactive Comprenensive Qatabase on Two-Stape Careinocer.esis and Pramoeien. Interim Document. 187pp. UCAREF00009529 . ?6. 27. 28. 29. 30. 31. 32. 33. 34. 33. 36. 37. a Ugren, E.B., Vaet, F.W.i Grimes, G,, Takacs, J. and Faux, D. (1984) Elemental sapping of human nervous tissue using the scanning proton micro probe. J.Maurosci. Method. 12:25--28. Rains, A.G.. Ugren, S.B.. ladingham, J. and Eurtz, J. (1984). Cerebral , . Toxoplasmosis, AIDS, and SILT, lanced 1:983. Ilgrea, E.S., Saxton, D.G., Jones, 4.E., Duckworth. S. (1984). A potential oicroneuroearglcal aethod for the manipulation of the developing nervous system of eheposciaplantation mouse embryo in utero. I. Injection methods. J. ' Seurosel. Methods. 12:191-197. ' Qgren, E.B. and Stiller, C. (1986). Cerebellar Astrocytomas: Clinical Features - Part I. Acta ffeuroehir. 81, 11-26. Ilgrea, E.B. and Stiller, C. (1987), Cerebellar Astrocytomas: Pathological Features - Part I. Clin. Neuropath. 6, 183-200. Ilgrea, E.B. and Stiller, C. (1987). Cerebellar Astrocytomas: Pathological Features - Parr I. din. Neuropath. 6, 198-200. Ilgrea, E.B. and Stiller, C. (1987). Cerebellar Astrocytomas: Pathological Features - Part IX. Clin. Neuropath. 6, 201-214. Ilgrea, E.B~, Tang, C.C. and Thorbjarson, L. (1973). Cystadenocareinoma of the pancreas. New Tork State Journal of Medicine 70:348-350. Hgren, E.3., and Symehyk,-P.S. (1976). Pneumoperitoneum without rupture viscus in the newborn. J.Ped.Surg. 12J537-540. Ugren, E.B. (1988). Multisystem Atrophy and Laryngeal Dysfunction: Evidence for involvement of the nucleus ambiguus. Arch.Swiss Neurol.Psych. 139, 73. Ugren, E.B. (1988). Mesothelioma Threshold. Mato ASX Series (lad. Sympas. on Minora) Fibres: Sherbrooke). (3H Press) Ugren, E.B. (1988). Aspartame: The Safety Issues. Arch. Toxicol, (submitted). Books ' Ugren, E.B. and Shublk, ?. (1988), A critical annotated bibliography of epidermal and hepatic tumour promotion. Oxford Hoivarsity Press, 344 pp. Ugren, E., Shublk, ?. and Salotti, ?. (1987). The Irreversibility of the Initiated State - A critical reappraisal. Appendix: Methods used to Establish an Interactive Comprehensive Database on Two-Stage Carcinogenesis and Tumour Promotion. Interim Document, 187pp. / UCAREF00009530 r p1 owbicuhjh vitas Or 6.8. Ilgren, MA (Oxon). MO.. O.Phil.(Oxon). MACPacft.. MRCPath. (Aasoeiata/Naureoathology) r- Oaf of Birth: 13.vtil.SO Placa of Birth; Philadelphia: Pennsylvania; USA. nationality; African PW6SSHT POSITION Maabr at Faculty of Biological and Agricultural Sciaticas and Subfaculty of Bloeftaalstry. University of Oxford C UCAREF00009531 r INSTITUTE aid LOCATION Mahnpeann Medical University Aaarlean Collage of Pathology Unlvarsity of Oxford Royal College of Pathology UK (Prioary) University of Oxford. Oxford. UK. cCUCAriON CEGREE MD MACPath O.PhtI (Oxon) MRCPsth HA (Oxen) YEAR CONFERRED 1974 1978 1980 1983 1983 FIELD OF STUDY MedicineAnateete Patholeg Zoology/Botany Neuropathology Biology/Medicine RESEARCH AMO/OR PROFESSIONAL EXPERIENCE - CHRONOLOGY 1973 19741973*74 1974 1973 1973 1973/76 1973 1976 1976 1977 1977 1*74/77 t 1*76/79 1976/79 1979/80 1979/80 1980 1980/81 1980/81 1983 1983 1983 1983 1983 1983 1983 1983 1984 1984 1983 Student Worker. Dept. of Coappretlve Neurppnetoay. Bryn Hpwr College, Bryn Mewr-. Pennsylvani. Ooeterete of Medicine. Tim IWmmm Medical College. **Uadelphla. Pennsylvania. USA. visiting Resident. The Manorial Hospital for Csnear & Allied Olsaasas. attached to Or W.8. Jdnos, Consultant Gynaecological Surgeon. Trophoblastic Oisaaso Cantra. Assistant Pathologist. Tho HOw York Hospital Cornoil Univarsity Hadleal Cantra. Nee York City. Csefsitant Forensic Pathologist. Off ica of tha Madieal Exaeinsr. Tho How York Univarsity Hadleal Centra. Or M.C. Baden (Sponsor) * Chief Medical Exaeinsr. Oipleaata of tha Hotional Board pf Mad leal .Examinant (USA). Visiting Selontiat. Poekafallar Institute oY'Mwdleal Raaaareh. Professor A.C. Braan (Head of Oepartaent). Or 6.6. DIecueakos (laboratory of Cytoblclogy, Head of Oapartaant). licensed in Medleine and Surgery. State of How York. Ho. 134849. Mender. American Colley of Pathologists. Board Certified. Aaarlean Board of Pathology. Anateale Pathology. Visiting Marker The laparial Cancer Research Fund. Oapt. of Pathology. London - Professor R.A. Mlllls and Or l.S.C. Pang (Head of Oapartaant). Visiting Rasaarch Selent 1st (Univ. of South California at San Otago. San Olego Zoological Seelaty and Oapt. of Pathology. Professor K. Benirsehhe - Sponsor. Travelling Research Fallow <International-Union "Against Cenesr) - Geneva. Switzerland. Postdoctoral Research Fellow (International Agency for Cancer Research/World Health Organisation) Oapt. of Zootomy. University of Oxford. Professor R.l. Gardner (FRS) Sponsor. Special Postdoctoral Research-Fellow (Aaarlean Canear Society spf-14) laboratory of Experiment Haaaailan Eabryology, Univ. of Oxford, Professor R.L. Gardner (FRS), ^ Research Fallow (N1H), Oapt. of Zoology, laboratory of Sxporlaantal Haaaailan Eabryology, Univ. of Oxford. Professor R.L. Gardner (FRSL?- Soensor. visiting Research Worker (HIHk. Sir Wllllaa Ounn School of Pathology, Univ. of Oxford. Oxford. Research Fallow (HDf), Botany School, laboratory of Cytology, Univ. of Oxford. Oxford. Professor F. Whatley, FRS, and Or C. Vosa (Sponsors). 0. Phil. (Oxon).-Ospe. of Zoology & Botany, Untv. of Oxford. Maabar of St Edaund Hall. Honorary Senior Registrar, neuropathology. Tha Radellf/a infimary. Oxford. Research Fallow Ouh), Oeot. of neuropathology. The RadeUtfe Tntlrwry, Oxford. Senior Registrar, Neuropathology, Tha Radellffe Infimary. Oxford. Pathologist to H.H. Coroner. Hr H.G. Gardiner (Oxfordshire). General Medical Council, Ful) Registration. Redolent. HflC Project grant award 'Sabryonic Regulation of Hours! Neoplasia' HA (Oxen) - Status: Prleery, HRCPath (Nauropathoiogy). (lacua) Consultant NouropatfleTegTst. The Radeliffa Infimary. Oxford. June 3-17. 1983. Header, Oapartaant of Siachoaistry. University of Oxford. Subfaculty. Header, Oxford fkteleer Physics Proton Mteroprobs Users Group. Maabar, Faculty of Biological Sciences, University of Oxford. Co-raeiolant*. Health 6 Safety Executive project grant award: co-rselpient with Professor P. Shubi: `Iron Chelation: An actaapt to develop a possible therapy for those at risk free exposure to ostia: by Inhibiting formation, persistence, and effects of asbestos bodies in vivo*. Recipient. Oxiaat Area Health Authority/District Research Grant Award "ExPrynnie regulation of n* neoplasia. . UCAREF00009532 ,, t983 1983 1W 1874 1989 ___", neuropecnoiogiat, in* Rodeliffe Infirmary. Oxford, June 3-17, 1983, Moabsr, Oeporteont of BIulU--tatry. University of Oxford, Subfacuity. "ixijsi. Oxford Nuclear Physics. Proton- Mlcroprottoi Users Group*. Wotiii-t Faculty of Biological Sciences. University of Oxford. Ce-rocipient. Health 4 Safety Executive- project great award: eo-recipient with Professor P. Shubl* 'Iran Che let loot An atteeot to develoo a possible therapy for those at risk free exposure to sabs' by inhibiting torwation. persistanca. and effects of asbestos bodies In vivo*. Recipient. Oxford Area Health Authority/District Research Grant Award 'EeOryonlc regulation of neu neoplasia". ' Oates (eonth 4 year! Free To Naee end address of sponsor/ eeolever (block letters! Juno 1974 June 1978 One.1978 June I97' June 1978 Sect. 1980 Seot. 1980 Ooft. 1984 July 1984 June 1978 Sept. 1976 June 1977 June 1978 Sept. 1980 June 1989 June 1989 Dec. 1989 Apr. 1987 New York Hospital/Comell University Mad. Centra Office of the Medical Exaelnor (NY) Now York Univ. Mad. Centre Inti. Agency for Research on Cancer/World Health Org. 4Lyonl AatricPl -Cancer See. (NY) NIH Bethesda. HO! N* Coroner (Oxford) National Health Service (UK) Health 4 Safety executive (London) Univ. of Oxford. Assistant Pathologist. Anatonie Path. (Rsgistrpr/Sr. Rag. Grade) Assistant/Paffiologist, Forensic Path. (Sr, Rag./Consultant Grade) * Rassnrch Fallow. Eabryology. Call Biology. Oncology . (also son 'Research Experience') Research Fallow, Eabryology, Call Biology. Oncology Research Fallow, Eabryology, Call Biology . Oncology Forensic Neuropathology. {Senior Registrar/ CdMUlTUft (Locus* Grade) Naoxncnthologlst (Senior Registrar/Consultant (loess) Grade) Rssaerch Pathologist (see 'Research Experience') Toxicologist: Research'Follow: Faculty Meaner (Biological Sciaticas), Subfaculty (Bloehaeistry April 1989 Present Aeerlcsn Industrial Health Council (ADO International Lifa Sciences Institute (1LSX) Certified Color Manufacturers Association (CCMA) Flavor Extract Manufacturers Association (FSMA1 Research Institute for Fragrance Materials- (RIFMl Chseieal Manufacturers Association (CXA) Proctor 4 SenOlo Pops loot Coca-Cola Go. and OKSS. Ospt. of Toxicology (London! 1 tapnrlal Cancer Research Fund, Clinical Trials Study Unit. Nuffield Oept. of Clinical Medicine, University of Oxford. Research Officer (Hon.) Uoivarjitv of Oxtoed. St Edeund Hall Hander. Faculty (Biological Sciences! Subfaculty (Biocheeistry) U CAR E F00009533 *6MB6WgPS Oxford University Coanutor Centro Users Group faculty of Oieloglcat Sciences. University of Oxford ' Subfacuity of Blochanlstry. University of Oxford Grit fan Medical Association (94A) Oxford Proton Mlcroproba Group, 0*01. of Ntieieer Physics. University of Oxford ifeurosciencos Speclelty Group. University of Oxford . Grit lab Society of Neuropathologists <890 Royal College of Pathology (Asso.) , ' Neurolibronetosls Foundation (USA and UR) Tuberous Sclerosis Association lUK) British Society Qevelopeent Biologists (8SCB) St Sdmind hail (Middle Common Ftocn), University of Oxford . 1989 1984 1984 1984 1983 1981 1981 1981 Jg8t I98t, IV9 tg78 AWARCS Oxford District Besearch Grant Award . {Enbryonic Pegu let ion of Neural Neoplasia) Health & Safety Executive Prelect Grant Award (Potential Therapy... Aebestesls) Medical Research Council Project Grant Award (Enbryonic Regulation of Nooral Neoplasia) National Inst. Health Postdoctoral Training Award. . (Control of Trophoblastic Groetb) Acerlean Cancer Society Special Postdoctoral Award (Control ofTropftoblsstle Growth) Inti. Agency for Cancer flesaarch (WHO) Postdoctoral Award (Control of Troohoblastle Growth) Inti. Union Against Cancer (1C8ETT) Award Canonrelive Pulnonary Oncology) Nov. 1984 July 1989 Sept. 1964 July 1989 Apr. 1982 Sept. 1984 ' June 1978 Sept. 1980 1 Juno 1978 ' June 1978 Ode. 1976 June 1977 June 1977 July 1978 UCAREF00009534 OOCTORAL DISSERTATION - 11 Contra! of trophoblastic proliferation In early oostleolantatlow ecus*. dMlecwrit: Severe! condition* are needed to proaato the growth of postleplantation eause trophoblast. Firstly, an aop prlac* tissue ahao* and eiosd call contacts aro naadad to super*** tha trophoblastic giant call transferee and a*intoIn thasa tlssuaa in a largely diploid, non-giant atata. Moreover, sine* an appropriate tissue ahcannot. on its awn, proeot* trophoplastle cell division. ICM-derlvatlvaa. a.g. axtraaaoryonlc encoder* and. eeseder*. are proOoOly also naadad to stlauiat* noreal trophohlaatie growth. 2. Control of trophoblastic proliferation In the guinea pldt The growth of guinea pig tropheetoder* and Its aerly postieplantation derivatives appsar to be under 104 control. Thus, the sultilayered attach--nt con* of the guinea pig blastocyst is probably not due to an'IOt Independent proliferation of trocheetod*rw but is aost likely derived tree a transient accumulation of abeebryonlc tropheetodereel calls. ' 3. Orloin of the eroohoblastlc plant cells: blnucleation In the ecus*, postieplantatlon trophoblast appears to becoe* giant through a blnueleate phaso. Thus, the growth of aeus* tropheetoder* occurs, to a certain extant. In a wear sieilar to the polyploldlsatlan of aeuse liver. - . Orloin of the trophoblastle giant cell: euitlnuoieatlon The finding of auitlnueleates In pur*, trophaetodere-derived tissue* suggests that trophoblastle aultinuciaatlon, at lease In the aouse. does not depend upon prior contact with aoscnchyaa or aasanchyeal tissue Multipolar, polyploid aitotle figures ware found in aouse decidua, tissues known to contain auitlnueleates siatlar to the ones seen in the trophoblastle derivatives of rueinants. This suggests that the aultinueleai ceils seen In so-- fores of trophoblast aay arise in a sender sieilar to these found In rodant decidual tlsaues. l.a. via a aultlpolar altosis without concealtant cytokinesis. 5. Mechanise by which CNA aceueulates during the trophoblastle giant cell transformation Polyploid --taphases were found within postleplantatlpn aouse trophoblast that had ehroeosoass arranged either randoely or In pdlrs. This suggests that at least see* aouse trophoblastle calls increase their ONA via polyploid aitotle and/or ndoeltocle cycles. * . Control of the trophoblastle giant cell transformation The degree to which trophaetodere-derived ceils endoredupllent* their nuclear gariae* and thus becans giant can be lnfluancad by changes In tissue shape and the axtent of Intercellular contact. Thus, call separation spreading, and stretching appear to proeot* the giant cell change net only within tropheetodereel derivativ but also within tissues known to behave in a aartner sieilar to tropheetodera. neeely extraaebryonle ended*r Moreover, the giant cells found In nor--l and nsoplastle extrseaOryonlc tissues are not necessarily ternina and tneaoeel* of cell division since they --y be found in altosIs either before and/or following aitogenle stimulation. Ceaparatlve stadias also suggest that the onset of the giant cell ehang* in one extrasebryonlc --bran* --y be temporally correlated with the developeant and/or degeneration of a nearby placental tissue layer. UCAREF00009535 ryjoCACAriONS - Articles I Ilgmi, E.3. (1980). Polyploidlzatian of wttra--Oi /mile during wh aabrycigaoMStT. Morph. 99: 103-111. 2, tiqrwi. 6.8. (I960). The control of trophoblastic growth in tin guinea pig. J. End. wr Morph; 60 3, Ilgren. 6.8. (19811. The control of tregM>lttle growth in thn ms*: henotypic cellular Interact- snd polyploidy. J. End. esp. Morph. 62:183-203. 4, Ilgren. 6.8. end Littlefield, J.W. (1981). Tho extraeebryonle ndodorool differentiation and poly- pioidization of andryonoi eareincaa calls In vitro. Differentiation 19:119-20. 9. Ilgren, 6.8. (1981). Tho in vitro Morphogenesis of the guinea pig egg cylinder. Anotooy and Eedryol 183:391-389. . . 8. Ilgren. 6.8. (1981). Placental polyploidy: e cooperative study. Placenta 2:333-343. , 7. ilgren. 6.8. (1981). The control of trophoblastic growth in the noose: blnucleetlon and polyploidy. Placenta 2:317:332. ' 8. Ilgren, E.8.. Griner. L.. 8enirschfce. K. and Pang, L.S.C. (1981). A cooperative study of poinonary tuecurs. Pathology Annual 17:331-391. 9. Ilgren. .3.. Griggs. fT and Aynesley-Green (1983). Precocious puberty end ganglionic haoortoaos of perspitultary. Clin. Neuropath. 2:99-98. 10. ilgren, 6.8. and Venn. 0. (1983). Cooperative norphologlcal study of nouse and hueen taretoon. Canec Surveys 2(1):210-219. 11. Ilgren, 6.8. (1983). Review article: Control of trophoblastic growth. Placenta 4:307-338. 13. Ilgren. 6.8.. Evans, 6.P. and Btrtenshaw. M.0. 0983), Origin of tho euitlnueleeto decidual ceil of aoose. Chronoscns 48:313-333. 13. Ilgren. 6.B. (1983). Cerdloeyogenle differentlet loo end toratoeareineea (oreetlon In EC-derived' eh Iv placentae. Placenta 4-4t9-433 14. Ilgren. 6.8.. Stiller, C., Steckel, M,, Silbemen, P. and Hughes. J.T. (1983). Epsndyaoess - A serla ' study of thair growth. Part t. Biological Peeturns. Clin. Naureoeth. 3:113-131. 19. ilgren. 6.8.. Stiller, C.. Stacks!. M.. Silbemen. 0.. Hdghes. J.T. and Kaye. A. (1983). Ependyeaeee A serial study of their growth. Pert 11. Survival Features. Clin. Neuropath. 3:133-137. 18. Ilgren, 6.8.. Vestaorelend, 0. and Adana. C.B.T. (1983). Cerebellar Pseudotueour due to Candida (Cerebellar Candldoea), J. Neuresurg. 80:438-430. 17. Pearson. J.. ilgren. 6.8. and Spriggs. A.Jl^ (1983), Cynphuas calls in cerebrospinal fluid canflneed t chrcaoaoee analysis. J. Clin. Path. 39: 1307-1311. -' 18. Sagar, H.. Ilgren. 6.B. and Adaes, C.B.T. (1983). Haevus of Ota. Meningeal Melanosis and Intracranial Melanoma. J. Naurosurg. 98:280-283. ' 19. Ilgren, 6.8. and Wilson, X. (1989). Brain Tuneurs in Nsuroflbroeatosis: Evldanea for Enhanead Malign? Potential. Pathology Annual. 1;1-29. 20. Ilgren, 6.8. and Henachudha. S. (1983). Ruptured Pulmonary Artery Aneuryse and Brain Abscess. Clin. Neuropath. 2:179-181. ' ; 71. Ilgren. 6.B. and Westnoreland. 0. (1984). Tuberous sclerosis: unusual associations in four casas. J. Cl In. Path. 37:273-278. 23. Ilgren. 6.8. and Teddy, P.J. 09841. Cheeodeetona of tho Cauda Equina. Clin. Neuropath. 3:148-192. 23. tlgren, 6.8.. Teddy. P.J.. Vafldlz. J.. Briggs, M. and Gardiner. N.G. (1984). Clinical and pathologic studies of fatal brain injurlss In horse riding eccldants: a description of eases with a warning t tho unhelnetad. Cttn. Neuropath. 1:293-299. 24. Ilgren, 8.8.. Olacuaakos. 6.G. and Jones. W.8. (19841. A eathod for establishing short-tern cultures of hunan gestational chorlocarolnowe in vitro. Cancer Letters 24-187-192. 29. Ilgren. 6.8.. Watt. F.W.. Grlnee, 6.. Takecs. J. and Vm< 0. (1984). Elemental Mapping of huaen nan tlsaue using the scanning proton aicroprobe. J. Meuroscl. Methods. 13:29-28. 28. Reins. A.G.. tlgren. 6.0.. Ledlngheo, J. and Xertx. J. (1984). Cerebral TeKopiasnosia. AIDS, and HTI.1 Lancet, I:985. 27. Ilgren. 6.B.. Sawton, O.6.. Jones. A.E.. Ouc*worth. S. (1984). A potential aieroneuresurgrlcal Method for the Manipulation of tho developing nervous system of tho post implantation nous# tabrye in utai 1. Injection Methods. J. Neurosci. Methods. 13:191-197. UCAREF00009536 29. ngran. c.3. and Stiiiar. C. <1986). Caraceliar Astrocytoua: Clinical Features Pare I. Acta Naun. 81. If-26. 30. llgran. 8.8. and Stlllar. C. 09871. Cerebellar Astracytoees: Clinical Features - Part II. j. Nauro< ' 4. 2083-308. . 31. llgran. 8.8. and Stiller, C. 09671. Cerebellar Astrecytoaas: Pathological Feature* - Part 1. Clin. Meureoatft. 6* 189-200. 32. Ilgren. 8.8. and Stiller, C. 09871. Cerebellar AstracytcMs: Pathological Feature* Part II. Clin. Neuropath. 6. 201-214. - 33. Ilgren. S.B.. Tang, C.X. and Thorbjarson, L. (1979). Cyatadenccarelncoa of the pancreas. New York St Journal of Medleine 70:948-990. 34. Ilgren, 8.8. and Syeehyk. PIS. 0976). Pneuaoperitoneu* without rupture visas in the newborn. J. Pe Surg. 12:937-940. - 39. llgran, 8,8. 0888). MultiSystaa Atrophy: Possible control aetiology of the laryngeal dyefunction an the role of lyaphoeytle inflaaawtion. Arch. Suiaaee Neural. Payeh. 139:79. ' 36. Ilgren. 8.8. 0909). Mesothelleoa Threshold. In Effects cf Mineral Ouats an Celle. (Hosswan. 8. and Begin. 8.). Sprlnger-Verlsg. Heidelberg, 1889. vol.H.30. 499-464. Cole Cola 0983) P6C (Panel on Caffeine Safety) Zurich 0989-1966) HSC (Holland Swtener Co.) Maastricht (1986-Preaent) UnlPoyal: Technical Aaaosaoent Systeee (TAS): McKenna. Conners. Cuneo (Wash.) Arestrong World Industries/ Calotsx (Asbestos) Sasic Til* (Asbestos) CAP Corporation (Asbestos) R.W. Johnson COWULTAWCttS Position paper: Aspertaae and brain function Caffeine Literature 'safety' assessment Aspertaae Literature 'safety' assesseent . Alar safety aasessasnt Montgeeary, McCracken. Welker, Rhoads (Phlla.) aicoe and Sreen !Cirm., Ohio) Arter A Hadden (Cleveland. Ohio) Sudd. Lamer, Crass (Nswark. N.J.) Sharesn & Plcaddlo (Pittsburgh, Pa.) Retinoid Safety Assesseent LECTURES British Neurooathology Society (London) (Clinical and Prognostic Indices for Huaan Cpendywosas) Ludwig Institute for Cancer Research, University of 8em (Regulation of Neural Neoplasia) . Faculty of Medicine. University of Lausanne (Regulation of Neural Neoplasia) Institute for 8rain Research, Zurich (Elemental of the Hiaaan Brain using the Proton Mlcroorabe) Swiss Naurapsthology Society (St Moritz) (Chronic inflaweatlon and Invoiveeent of the Nucleus Aabiguus in MultiSystaa Atrophy) S7#^, ... .a). ,,..4*1 ,. . A . -W . / 1982 1983 1984 1984 1989 /<fSf UCAREF00009537 made this eighth day of October- 1937 between the Oxford Publisher of the OXFORD UNIVERSITY PR5S"of Walton Street Oxford OXZ D< hereinafter called'the Publisher1 of the one part and Or E.B. Hren, 13 Frenehay Road. Oxford; Or P. Sbublk, 13 Narhea Cardans, Oxford. hereinafter called 'the Author* of the other part WHEREBY IT IS AGREED between the parties hereto for themselves their respective executors adminis trators and assigns (or successors as the case may be) as follows 1 The Publisher shall tubfeet to his approval of the finished typesetipt publish at his own risk and expense a book (hereinafter called *tho Work*) of approximately 5** printed uosds inclusive of notes which the Author has prepared Or is preparing and which is at present entitled 'page* Hepntie and Epidermal Tuaoar Promotion An Annotated Critical Bibliography RIGHTS GRANTED ' ............ Z The Author hereby giants to the Publisher daring the legs! term of copyright indtiding any renewals thereof the sole and exclusive right to produce and publish the Work and any abridgement of the Work and any substantial part of the Work in volume form is the gngK& language throughout the world subject to the terms and conditions hereinafter mentioned but tfaacopyright in the Workshall remain vested in the Author DELIVERY OF THE TYPESCRIPT ; 2 The Author shall deliver to the Publisher not later than 30th June, 1968 in a fit state for the printer two (2) copies of the aompiete typescript of the Work and shall at the same tune supply free af charge and in a form acceptable to the Publisher sub tBusaative material as constitutes an integral pan of the Work or as is agreed by the Author and the Publisher to bo desirable The Author shall correct and return punctually ail the proof sheets of the Work and shall compile an index to the Work if it it the Publisher's opinion that one it required or hereby authorizes. the Publisher to arrange for its compilation at the Author's expense PERMISSIONS 4 The costs of ah fees payable for p*""<*?" to use in the Work any textual matter drawings photographs pictures maps diagrams or other material that is in copyright or is nthjea to any proprietary or other rights of others shall unless otherwise agreed be borne by the Author and the Author agrees to secure such permission if required to do so by the Publisher and in that ose shall send the Publisher written proof that he has done so as soon as possible after signing this Agreement PRODUCTION * ------- 5 The Publisher shall print and publish the Work in sadi edition or editions as he considers appropriate as soon as reasonably may be afterthe compiete typescript (which term shall tfappropriate tnduds any illustrative material referred to in Clauses 3 and 4 above) shall have been delivered to tuns arid he shall have the sole control of all details of production advertising pries sale and terms of sale of (he Work and the right at his dismetion to raise or reduce the published price of the Work CORRECTIONS IN PROOF The Author agrees that apart from prater's errors all charges for carrying out the Author's corrections additions and tetetions in the proof sheets either of the original Work or of any revised edition as hereinafter provided exceeding .0% (ten per cent) of the charge for compositioe shall be borne by the Author The Author also agrees that all charges for carrying out the Author's corrections or deletions in the preparation of artwork (including engraving or photographing) apart from errors for which the Publisher or printer is responsible exceeding 10% (tea per cent) of the charge for preparation of such artwork thall be borne by th^A^thor UCAREF00009538 AMERICAN INDUSTRIAL W C A L T H COUNCIL. INC t JM COf-*OlCU *VtKfMW . *K. MrAtlMMCioiw. Q C. . [Wl W9^MA Or. 0. H. Hughes . Procter 4 Gamble Company ITC - Cincinnati OH 45217 (S3> 627-525 Ha. Sharon Senzik June 20, 1966 ' International Life Sciences Institute 1126 Sixteenth Street, W.W., Suite 111 Washingten DC 20036 Subject: Promotion Project at Oxford University Oear Sharom .' 1 want to thank you for your Association's participation in the support of the carcinogenesis promotion review project being conducted by Or. Gd Ilgren at Oxford University under the supervision of Or. Phil Shubik. The complete list of groups that are providing* financial support is: 1. American Industrial Health Council (A2HCJ - J. Oavid Sandler 2. International Life Sciences Institute CHS!} - Ks. Sharon Senzik 3. Certified Color Manufacturers Association (GQtti - Or. James Noonan 4. flavor Extract Manufacturers Association (FSHA) - Or. Richard L. Hall 5. Research Institute for fragrance Materials (R2FH) - Or. Richard A. Ford 6. Cheaicai Manufacturers Association (CHAf - Hr. Carl (Inland 7. Procter 4 Gamble - Dr. Donald H. Hughes ` * 6. Coca-Cola Company - Or. James Baerson 9* Fepsieo - Or. James V. Stanley As you may recall. Dr. ELgren actually began work on this project in the fall of 1965 with tacit support fros the Rational Cancer Institute.* However, that support disappeared with the emergence of Grams-fludman. Hence, we approached you for help and your positive response was critical to the continuation of this `project. We anticipate this association and Industry support will carry Dr. Ilgren through October of 1986 and eesplete this phase of the project, which is to review and critique the sassive literature on premotion and to have a paper ready for publication and presentation at an appropriate seating at the end of this year. I plan tn get back to you later in the sunaer with a status report and thoughts for the future of this project. Very best regards. Very truly yours OHK/es CTK 0. H. Hughes, Ph.D. For the Science Gsaolttee ee: Dr. Philippe Shubik, Or. Edward Ilgren, Dr. V. Cary Flam, Dr. .Ian Munro, Or. Robert J. Koolenaar, Or. Richard 11. Adamson, Hr. J. Oavid Sandler UCAREF00009539 I l *1 if e it g r s,, r*' c% n ig SS V Kl > r *o t&s 5n J" Ji TR cg c* 9V D & $ t rs I t *f V4fB9#t ! m e5 "m *S V s * is Vts! b! SC * 9 Sr |e eB fg ' tc Z SSfi j ?* 2# ' V5 > e _______0 V i s i<e s g ^ L Jr 9 vS n < X 9wcc*r 1 ^COB *2 4w*n9Oe?. 44 *P Bn9 u0 ew OoIcfMW60Iif , wnwu!i Wwc n 2 w4oW V fi i*JouooV*C . * UCAREF00009540 UNIVERSITY OF OXFORD UNIVERSITY OFFICES WELLINGTON SQUARE OXFORD 0X1 go Ptnoeil Telephone 0 965 270190 RrCNa. 00/S Tree the Bud Cleric 25 April 1994 Owe Sic or Urdu X have received year letter of 21 ipril about Or. K.J. Tigran. He ves eanbeg of the University's ataff free 1984 to Z987 vhan he left} X do sot here a faraerdlag addreu. Bo VU a Erwhftr of 8f toetnit Bell. iHrM * %, s wu*>c v-- contact the oollofe office for poeeihle further information. the far number Is 0805 279090. Tone faithfully lytaae X. Waskoafcy IiOgal iaaiatast Stich, Angell, Eeoidler 8 Hath. FA, the Crossings, Suite 120 Tftniwnnlte Mlmuwote 55401-2122 OSA FW/AJV tom. p.ea UCAREF00009541 # I Medical Specialists 1994 VOLUME 3 e Reference Otolaryngologists Pathologists Pediatricians PM & R Specialists (Physiatrists) Plastic Surgeons Preventive Medicine Specialists Psychiatrists Radiologists and Radiological Physicists 26th Edition fc fvt / i i UCAREF00009542 I I 1 1 I I I I I / t 1 t I I I I I I I r CM PHI AO/CP 90 (Natl JT ca* Swot 0f" SOU. 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I fax no. :... ,9i9T}?r3??rJ-?^9........................................................................... SENDER* Mr J-C.B. Gosling, Principal l MESSAGE Dear Ms Waskosky, Dr E.B. Ilgren did his doctoral studies at this College. Later he had appointments at the Department o Neuropathology, Radcliffe Infirmary Hospital in Oxford, and was a member of the Faculty of Biological Sciences and sub-faculty of Biochemistry. The 'situation at Oxford is somewhat complex, but Dr Ilgren ^ was never actually on the staff of this College, although he was a member of the College in virtue of having beenta graduate student here. J.C.B. Gosling, Principal. CAU.TKSHxu.rox Conmnai Mimm OnortXA Rieirmw I iwotm T... n, U CAR EF00009544 FACSIMILE FRONT SHEET ST EDMUND HALL OXFORD 0X1 4AR . 'ntunwNfc Oxrota (CM3) - Bwuinr Pax 279007 ' 279090 ATTENTION OF:.. .NS .LXWVS .? * .................. PAGE i OF.. A ... INSTITUTION/DEPT____ ?TTTS9. .???????.DATE: .. ,?8..4 ..94 . address: .. .AW.sgr?*?so. second. AyENUETI1!E. .. .. .SQUT5. .9WW.9*. WW?W??J54h... .REF:.....'*;BG/sd USA. FAX NO. : . . . ,91076l?73J3;l,940....................................................... .. SENDER* Mr J*C.B. Gosling, Principal i MESSAGE Dear Ms Waskosky, Or E.B. Ilgren did his doctoral studies at this College. Later he had appointments at the Department of Neuropathology, Radcliffe Infirmary Hospital in Oxford, and was a member of the Faculty of Biological Sciences and sub-faculty of Biochemistry. The situation at Oxford is somewhat complex, but Dr Ilgren was never actually on the staff of this College, although he was a member of the College in virtue of having beenia graduate student here. J.C.B. Gosling, Principal. CailThxHau.10* CbtunUNcxs. Mihihii Qinmexs. Mcimiw f mmu T n> UCAREF00009545 I ft 1 I I 1 i i I i i i i ft i fti MWHWI Nitti in Ms Lynnes X tfaekoaky Legal Assistant . Stioh, Angel1, Krsidler Muth 3S0 Seeohd Avenue Sooth Suite UO Minneapolis KM 99401 USA _ 9ft as April Ut4 a CARLTON HOUSS TBftfUes LONOON SWIY SAP ______ JDL..2. DilB. Dear Ms Waskosky Wf&tor&Sf* X am responding to your lottos od 21 April received by fax* mors are two routes to membershij (HKCFath) of this colleges toy examination (in two parts) or toy submission of published work, Under the old examination system jrtiloh is being phased out this year, it was also possible to gall exemption free ths first part of the membership axanination li tha basis of an approved postgrsduate qualification or sunslssion of publication*. According to our records, Dr ft 2 Ilgren of Apt 503, 930 Montgomery Avenue, Bryn Maur, Pin sylvanla 19010 is an Associate of the collage, having gained oxsi ption in October issi from the first part of the membership exiaination, the Primary, on the basis of his publications in a palhologieal fiaid. The status of Associate is entirely optional on the part of the applicant: it doas not permit entitlement to I designated Initials auoh as AMCPath tout does allow the helper to receive the quarterly mailings of tha college1 X hope this information is of hs fours sincerely Professor C Roberts Registrar tophon* wi SfT II AetnlneWn 0*tl 1 (ft. MHttotarMMpQww) pOTwMnMtBHMnf.ml fi HUtiOTMlION* CHARITY NUMBSRt SHOW UCAREF00009546 UCAREF00009547 3g m323 4 3 g 3 ..-si I 3^ 2 |? pi *5$^ ^ I^3I 2}S(a a >' Sil sOe 1 Sill life Jills 1 UCAREF00009548 UGAREF00009549 (mow ana, fins XL. MO 335 Horn GtanHt Anna SttCi 300 gtnarit CA 91308 918/2844890 FBLOW iMLFaaL MO Amu Soteasr Mad. Santa P.Q. am 9089 Ofcam 31311 SAMS AHA8W FELLOW ' UtrA Cart F. M0 flkattng Hanttl Marital Ctr. Ornmnwi 8 Punoiogy 48tt Astrw Pnt BW. FUring Nr 11333 718/8X0-5479 FELLOW Mtfawo. Vaiaafla T, MO 239 Hariknat un* VBmva PA 19083 213/335-7264 FOLLOW otto, wnnam p, mo 1228 East 2901 Ptaca Tiitt OX 74114 918/743-4394 FELLOW Ihrocan, Roger P, MO iMnooran (rWnkwaLoMvanM Oi*Mv Otuaumm at Piasnogy 4200 W. Conac* PL *234 Oamar CO 80204 bisvtus Fauxw t*. Tang K, MO 2512 Raaln Cl CoMnggan KT 41017 308/341-3878 AMOR MEMBER tan, MaxSam/, MO 51 Oakland Avanut XaatMy NJ 08832-1138 908/293-0013 , FBLOW Imata. Rlaad Hiqva. MO 2118 Aaron St Port Smoot Ft. 33SS2 F910W bntar, Mfeftaai L MO. PTiO 2013 Ponca oa taco Ava. Watt Prim Stan . 33407 400/8394770 ' atoms fbjlow inflrfglia. Joans* E, MO SM& Kran Costa 801 Yaa Avanua. *607 Ssanmncra PA 19081 213/5434471 FELLOW Iran. Franklin C. M0 340 (SUM Or. Mongonwy *L 38117 BtSttUS FELLOW InpartaL Round Lawn. MO 4877 Baoaty urn SadaaaaMO 20014 AMOR MEMOS! tanntaL Samly U. MO 502 Unwanar Avanua Aot *3 Stnenaa K7 13210 313/4258743 atsortis Fauxw EngertaU, Arittaay F, M0 333 QM Otar Rd. NartUtaa NT 10330 FBJLOW tednttrt. Barfa C, MO Mean Star Marital Camar Omranant ta Pauegy 4308 Aim Am MM Bans FL 33140 303/374-2277 atSOTUS FELLOW ladaa. Aartllo Pattr. MO 1840 Skadwmoa U Snnwawn IN 38183 FBJLOW logafl. aiynnis B, PkO, MO Marital Ana Ufiorawy Sutta 100 1111 N. Laa OkSatoma car OX 73103-2828 483/239-7111 JUM0R MEM8ER Ingtarigtam, Jante Ctcatt. MO U(0B0fe0 Hosom ot tndivti Qataremm a Pmmow 1781 Nona Sana SML Manacria IN 48200 317/829-2000 FELLOW lagtte, taiga W, MO P.a 30* 1308 Hunan OX 73070 408/3214370 amor member lagan, Staotan C, MO 1384 San Jaona Court SL ion MO 33139 314/8384580 AMOR MEMOS! tegU, Hartnrinkomsr, MO MMIf Mtocai cwor now Oaotasnant at Faimy 47 Mav Scorind Annua Atari/ NT 12208 518/4484454 FB10W MvmantJUMO uoMat/of Mtaaoat Oapvenant o/Penology On* Hanoi Ortta CQUMa MO 83212 314/882-1319 AM0RMBII96I tann. Mart &. MO 3211 Sltvan Straat Aot #4 Maritan Wl 53703 808/2334134 JUMOR MEMBER tentaa, Sou A, MO rntat Untnrny Hoarita Onnunanc of Pmotcgy Smd & Oman Skaat PWariama PA 19140 213/221-2097 FBLOW taaafflta. raayoaliL MO 2423 Famca Rri. Uovanty Hoqna OH 44118 FBLOW tnaataca. Samoa! X. MO 10814 90 Ava. SW Tacama WA 98498 FBLOW--INSPECTOR Integral. SWra R, MO P Ota Patwogy Aaaoona Ban 12809 FfennetSC 29384 803/387-2034 FBLOW toaagu. Martya E, MO 772 Paras Ava. BRMe NY 14209-1042 FBLOW toaddm, Hang L, HO Lanas HR HoagriM Oapwnant al Ptatagy 100 L 7701 Stm Naa Yortt Hi 10021 212/434-2330 FBLOW toataMtt. Kyriakea, MO flMP flaanai 1330 1381 Avarna, Saudi JtainuiilMt Sacfl R. 32230 904/247-2337 FBLOW nit. Sanaa o, mo Aaaecuad PnnuMtan Ontarad 4330 S. aumam RriL. #230 Laa vagn kv 89119 702/733-7968 ' FBLOW tanrt, Frtd. MO 1782 Am Ott Plata W Oaearila FL 346S6 AMOR MEMOS loan. Neman Pad, MO Mriun CoRsttdna si cmnyAvt. paanun hj 07502 201/904-9177 FELLOW M. tare T, MO 9 tartar Hum Way Tmyiam NY <aai - FELLOW--INSPECTOR bnL Mabnlioori S, MO VA Marital Camar 113 LtaSarv. 2002 Htacomat Hotnm rx 77030 713/794-7248 AMOR MS4SER kanA Shml MO 14835 Bract 8. Oriws SaArard Maranam m Tnpt R. 33913 813/9794978 PSLOW key. Ndaaa t, MO 2729 Oaoal Aari Ckaiy Owa MO 20919 301/880-4741 AMOR MEMBER bnt, Oasis! A* MO 5019 Wlntmo Amua Unman in 48220 FBLOW Maa. Saainr L. MO Aataonal Marital LAS isos-iansnat wua ua w tbjoi 817/723-1473 AM0RMSU8SI Wan. Hakata A, MO 231 Oranga Stas SmngflBri MA 07108 FBLOW bwfn. Komar fl_ M0 Stan Mamma Hoststa 7901 Pros SI Sn Olago CA 92123 819/341-3860 FBLOW Isaac; tana V, JMO 13 Hyria Am Rmrgton N4 08822-9474 FBLOW tasaa. Laoa A^ MO 325 Makasa Avarua BaManam PA 18017 213/8814674 FBLOW--INSPECTOR tana. Pater C- MO____ Entaa Marital Laacraitay p.a aes 20457 Banmnt TX 77720 400/8334420 FBLOW Itasca. Hart Jr, MO CMdmt Hoag- al Sn Saga Oaparenaot of PiBiology 3001 Fran Straat Bn 3007 Sn fltaga CA 92123 319/378-3944 AMOR MEMBER itactoH. CJstaUa. MO Uaat at Ion Hoa& 6 QMea Omnnm at Pafssow 500 Hnm Hoad km C*ytA 52242 319/333-8232 FBLOW--INSPECTOR Mala, AaOwny Frick. Jr, MO 2)03 Stamm Or. Atari/SA 31707 AM0RM8U881 Isartart. Craig S, MO 3407 Knmyma BM CsiMnbBi OH 43??$ FBLOW WOnkL Jotapli YoaklkL MO 22-31 Wg*rtJtonun-CIio Oaao-ts 372 JAPAN 072/031-7088 FBLOW taOar. Saerga K, MO 311 Smdnaa Yaanarea Ml 49001 -i -X 198 UCAREF00009550 OKLAHOMA--PENNSYLVANIA Qjffthonm cay (cm) Sahara. Rfcnart X, MO Otcoank. Ronald X. MO Sndahaw. Oavid L. 00 SiMmnft. James M.. MO Bramback. Roger Am MO Brambiugl Ranr P, MO CM. Ctiai 3_ MO Cavil Oamei ft. MO Ourandl Oawd l, MO EzgL Hulusi. MO GSOcs. Elizabeth M, MO Hargis. Josecn i. MO Kartay, Michael (L MO Harper. Howard Dale. MO Hewett Tommy Uoyd. MO Hoittnai Joim H.. MO IngalL Glynms 3,, PhO. MO Jordan. Frederick 9., MO Keating. James W, Jr,, MO KeOar. Oamei F,, MO KhorsarW-SahMie. Mahrdad. MO KJda. Masatoshi. MO KitidartocKar. Pay. MO LambM-Parry A.. MO Uectl. Richard W,, MD Levina. Statfien J, MO Love. Renjamm P,, MO Magrim-Omyson. Mariana, MO MaUry, Martin EL MO McCMIsl Betty Jane. MO McCormick. Michael 8- MO Mn. Kytmg-Whan. MO ' Moon. Lynn &. MO Myers. Lynn L. MO Ochoa. Mana x. MO Oneson. Rum Harmon, MO ran. Jan V, MO Reset Afchard lei MO Ragan jom r, mo Sddestagar, Reran* &. MO Schnabel, James Joseph. MO. PhO Sedbk. Justin 8.. MO Shriga Stanley &. MO SBvi Prtd <3_ MO SJoara. Janeile Alexander. MO Smffh, Michael 0. OO Stephenson. Jack Mefdrdey, MO Sumner. Hatton W,, MO VbML Theodore W_ MO WtOdnson. Henry Am in. MO Pena cay Oum, 8ruca d, MO Johnson. Donald Alai MO Hessi Robert S. MO - Hoffman. Kenneth d. MO Hubner. Oougtas 0, MO lESg, WHllam P, MO LaMar. Walter L. MO Magun Raymond P., MO Maw. Gilbert Maytoi MO MeCants. Ralph S> MO Medawer. Michel S- Jr. MO MfedeUy, John A. MO PaBk, Emd . MO ' Palmar. James Otm MO Wt Jetty L. MO neehei yymiem W,, MO Strangi Jimmy R. MO Taylor. Jamas Richard. MO WMta. Robert 3. MO WflBams. Gregory P, MO Albny Craw. Kenneth A. MO - Ashtend Jarvis. Thomas EL. MO Rmr+f . Cochran. Terence R, MO Beieertan Oum Robert CL MO Huffy. James M.. MO Huahem Tyra T. MO Bead " Howbart Jamas P, MO. Judd. Jamas l_ MO McSory, Georgs 0. MO Sehnamar. Roger A. MO Yocom, Laura* 8. MO rTqrtrjpm HoMhai Kathleen P,, MO > Caei Bay Hesaek. WIBiam 0. MO MeMyra, Hssdanai M. MO, PRO BonraMt Agor, Roy J. MO lina John U MO Lund. Paul 1C. MO naps, warn* R, MO Vrttskt Frank L. MO Me8rtdt Oavid LeMarr, MO ttBwtor Hafl, Ronald R. MO Tides CatmelL Lany W, Jr,, MO Chapped. R. a. MO Qstalam, Ronald Francis, 00 olai d Terranet MO Fatter, Ron Ardor. MO ' Ferris. Craig A. MO FHtar. WHllam F.. MO GotrL Tarry R.. 00 Hate, Jack L. MO Rah. Mathews a. MO Harm. Mkaur j, md Hoknei Robert 0. MO Houdt Jeffrey A, MD KWH Brant 0. MO Uu. Curtis Roy. MO Mayan Oavid S. MO MUsr, Jarauedne 0. MO Rutz, Oavid A, MO Start. Grier Fonydn MO Vtefcen L Samuel MO tend Pets Hong, Fang-Yea MO Olson. James ft. MO Phdnrt Ted 0. MO Ktemath Fells Edwards. Robert M I, MO U Grande . HekM, Khalil Y, MO late Qawego . OrtbnrtB. Nicholas G, MO Oysna. Albert A. MO SUbae. Chaffee T. MO Buck. Robert R, MO Nawtasd. Gary L MD ' SUphansoi Robert Waym MO Tleger. Thome H, MO . Wesoi Frank H, MO MOmalda Betroth. Margaret . MO . Mehm Laura Sue. MO MBes, Catberim M. MO ' ' MRai Joan c. MO Moon Michael A. mo Ntxoi Randal fl, MO. PhO Odad. X Michael MO Orr. Jamas E_ MO pwj Owfcgs. Raymond m, MO Oyama. Kavm K_ MO' ' ' Parsons. Catherine S,, MO Pfckema Nlgei A, MO Ray. Judith A_ MO . ` Rosenheim, Sidney R. MO Schafer, Donald W.Em MO Schmidt Waldemar A.. MO, PhO Shausi Steven l_ MO Shdflng. JoeLMM MO fltdora m mo aJapm Mm mo Spackman. Kern Alan. MO.PltO Soacnt H. Oavid. MO Thompsoi Steven Keltl MO Thorpe. John Om MO Vetmes, George X, MO Wbt Daniel Ptolemy, MO Cotmad. Robert M,, MO ObMi Malar, Robert H,, MO Ongn CSy Oau, Oemtia P, MO Adnra, Lawraoca X. MO Clausal SallyArm G_ MO Sawyer. Jeran 8. MO AftA Shadab it. MO Amtsai Erie W,, MO Ban OaaM ML. MO Btitay, RUkard E. MO Bondouscuta. Alai d. MO Garmon. Scott l. MO Cook. R. Edward. MO Cart. Franklin 0, MO DeYoung, Pamela A_ MO FwidW. Teresa M, MO irtnfat Daisy A. MO FuMa. Petard. MO SMay. WRSam T, MO Gonata-VRali Juan C. MO Hammer. Bhabatii P., MO Mnte. Homer R. MO Harry, Raymond Chaffee. MO Hnr. Jeffrey 0. MO Hansaot Brgena V. Jr. MO HaughM. Oortaid d. MO Johrtsoa Oavid S_ MO . Jpsapff. Edvard. 00 Juenget Randal Cart. MO Kta&g. Peter X. MO Mm WHQam F,, Jr. MO Kram. Robert X. MO Lnd. RachJai R.MO Landrail Eugene W, MO Longi Julia C, MO Merqndt Victor d. Jr. MO MeOorald, Clark E* MO Rmtburg * Barnes. James l_ MO Reedy, Michael T.. MO jUn . Seal Madssa Lou. MO avis. Stanley K MO Jansei Robert Om MO Landen Roger O. IR MO Uum. Jama H_ MO MdtBloi OoraW 8m MO Patea Roy 8m MO Pear, John Mm MO Racket, Douglas R. MO VanFeenei Hubert JJ MO Taieot Loquvxn George S_ MO Tha Safes Schubert Fred d. Jr., MO TMatb Scrndai Richard M, MO WadH John U MO ' MeMam George Rm MO VHIte Gardm Medesa. MO WSncvlIla Peterson. Oavid Am MO PENNSYLVANIA Auaraael Herbert S. 00 Charaey. PmU X. MB GoHMm. fbetati T,, Jr. MO Hud George F, Jr.. MO KJotzJfM Roy 8, MO Burttwd, Edward X. Jr; MO tar LAP snood * OK 418 HIHHIRlillBiBPiSIBBW UCAREF00009551 Hometown. Clams. 00 Kleea Ananases C, MO Kbsasito. franca V. MO Utta. Brian W, MO. PM) Sees. Ralph H, MO ABno Part Crat Pedro A. MD Oetoar. Andrew. MO Edwards, Rosemary, MO Sped! Clams 3, MO Jourdain, Uas M, MO Brads WUSaa X, MD Sasfl. Eugene M, MO Stanrield. Baraare L. MO Atom Sank maps. Earl l, MO Hatiht Hagaty, John X. MO AonriOe Carnany, Thomas B, MO Carrel Deborah X. MO Smith. M. Sue, MO Was*. Martas A, MO Rnkrisakt. Sydney 0. MO Nhrita. Donald A. MO Btat Yongdng, MO Ootooa Qawd James, MO Ootoon. Lynn H, MO Bale Cynayd forest Jean U MO Meyers. Kart A. MO Urt. Amass A. MO Yaren, Noamt tana, MD Bearer Septa. Combo M, MO Marcus. Gary J. MO Mia. Tas C, MO Rate John Oi. MO Hunter, Robert Grey, MO Schavmt Harry A, MO Badtol Part Preplan. SutodansUM) Schubert Erie 0, MO Bant Edward JL MO CNaks Jamas M, MO Ftotar. Joseph K, Jr, MO Sonatez. ROM 0, MO Hat Leon A. MO Longa. Sana. MO brit Ronald 0, MO Lufeazaye. Thomas A, MO MBareus. isidora. MO Over, Jorge M, MO K0MB&&T9 . Oonon, A Patrick. MO Martin. John C, MO TBman. William E, MO Bbre Bali Uebarman. Jill MazzeL MO Baottaryn CampOed, WllSam N, MO Bowmmmflle Lane. CL OarrelL MO Casa* Augusta 0, MO Kritelar. Charles MO Briatai Stag, Sang Wen, MO Bruettmn VWson. Roma A, MO Bmekrita Hsverty, Gary f, 00 Chaddt ford Malar. Frederick A, MO Chaffont Aagerar. Ernest E, MO OaM HQ Ayres. WHBam W, MO '`^RaregasMagaret M, MO HoRoaa. Howard L. MO Rarnkst Constanen A, MO Batin. Arthur A. MO. PhO Laws. Janas. DO Sparer. Haney 8, MD Cteriea Pudrett Jamas L, 00 Osrts SatmnS O'Connor, Jamas J, Jr, MO Ross Gary W,, MO CtesrtMd KaruardL John F, MO Real Michael P, MO CstosrriSa Casas Angelina W, MO Oaure. Saw S, MO Barer. Susan M, MO Bryn Mawr Hauaman. Oarid H, MO Hetan, Sarnia A, MO Kaahgegiaa Albert A, MO, PHO Ladcnlh. Ckariae r, MO Mguat Namasto U Jr, MO flatrs. Btasaapa 8, MO Strands Paul V, MO VWRams Jamas R, MO Kbit Yang K, MO Moon, Sangpu. MO Plrreha, Ankeny M, Jr, MO fatdas Judus MO Lasts. Linda S, MO IMmk. Baorge E. Jr, MO IMas KsakL C. WSaren, Jr, MO Mtelalak. wnam A, MO WHkta, WHBam L. MO CareM AMtuntf. Nat* MO JanUns Rosamay, MO Maas Anthony E, MO Madgris Rcsano. MO Pores Judai w,, oo BhaaenajL Susaaa 1C. MO Syak.TanaataAZ.MD Carilsto Oiana Oudt-Kyu. MO Crist Hiery S, MO Smith. James M, MO CadarRas Canon. Margaret L. MO amt Oarid A. 00 Care. Poor j. Jr, MO Faring, C. Jantt MO Gates Aicttonadea 0, MO Hatred, Husan f, MO Mms John J.MO Ptacucd, May f, 00 Plates Rfchard It ngooL ffichad M, MO Sehuarch. Corral MO Wash. Gaorgs E, MO Oaky ZofrreUs Matare. MO Oarea Moreno, Catos MO StynansU Mat 3, MO Bailee hare Hnrireley, Vaugtn C, MO 417 PENNSYLVANIA Schaats Heinz G, MO OresstMB Chet John A. MO. PhO Mattlaws Uwrenca M, Jr, MO Marts Stover A, MO Oi Sals - Costs Jose M.L, MO OtSala Surioa, Gregory A, MO - EastSOwdrtsrg Cana Cann&re J, MO Grusiks francs A. MO Itatoy, John P, MO Akmaa Arthur A. MO Banal Chates P,, MO 8mm. John M, MO Oorman, Sandy A, MO fonrecs Cartos A. MO Saute X Oauda MO Haads WQEam A. MO Satoato, Wtoredo a. MO Otaaud COy WOtans Kail E. MO Aaaar. Robert A. 00 Matotoatos Thaodore X. MO Cota Peter Christopher. MO Mp Swnbaa Rfchard E. MO Frankta. Normal MO Gerran. Amono L. MO Jktgns Xamtok K. MO KhaiRHa MO Ktaraa Oawd L. MO laa Henry AC, MO Rate Mary . MO ftanredewsM. Jack V, MO Zlagtor. Thomas A, MO Tatoma Thames &. MO Wtaoa Stoven Henry, MO fart Wasktogtoe CaMaaa MO Sadffl. Rabam Sains OO Onto. Bridge! A. MO Skareart. Jotor W, MO Suk. JlnH, MO Crtapaa John W, MO Mondsir Magdalena 0, MO at up graM a mm tits UCAREF00009552 *. 7 PENNSYLVANIA (Won. filial SL. MO Paym. Husnang M.. MO GSadwyna Kao. Sheda M.. MO Ranga Rena &, MO TeuttL Savenn. MO (Sadaynta Peatman. Eugene S MO HaoraInn. Jamas &. MO Whiteside. Vbguta . MO ip--liU Valeria Salvatore M, MO Graamherg - Boyar. Rands 0- MO CM. Charta X. MO * Jattar. Walter W,, MO Morrow. Thayer K., MO Ranos. Clarita P,, MO BrosmrOls Hawkins. Roger A. MO Mss. Pour (X. MO Gvyasdd Valley BataauOramaman. Manjuia. MO A Smart Kennath W, MO Socratas. Jass It. MO Bear. Robert 1, 00 BaMiasar. S. W,, MO OiSama Susan it, MO 6abrM. Hoda F,, MO Hannan, Ricky 6, 00 Jumper. Bernard w,, MO Qtmstsad. P. Mchaal. MB) Ptper, Janas A, MO Rady, Frank Raymond. MO SlegaL Donald L. MO. PhO Ainsworth, Arm M,, MO SWlyrtte, MO Kmftovm Mayor, Theodore Q, MO Stein. Donald it. Jr.. MO Koenig, Johann A, MO Ihfiuillflt Rtfach, Frederick J, MO Abendrom. Catftenna &, MO Abt Arthur MO Sams, Chary) A. MO FraDsnncffer. EUabath S_ MO Grenfce, Ronald Trent MO Krieg, Arthur K MO Naeyo. R U MO SManr. Marguerite M_ MO Shrtz. Cindy L. MO Shstt. Krag w,, MO ward. SamuefP- MO ZOrn. Richard J* MO MMIsmt 60, Manjit K, MO HaOdaysborg Anton. Amelia MO Cotds. Harold R. MO Kunan, Samhamma. MO Shaua Howard 6. X MB) Baker, Evan E. MO Leo. Young W,, MO Horsham Kohni. Sett It. MO Hummeletnwn Sramatovid, Mlrela. MO Hamtoyjpft * Ifftfttidu Join H, MD HSadagdon Vaflsy Horetmarm. Joseph P,, MO Oban, Harold ML MO Griffin. Staven P,, MO Mardnez-Eskeraey. German. MO OeOceo. Frank A, MtO Haretar, Gerald Alfred. MO Uttyeds Swerrt. Vantta K, MO Aatbany. Chiiataphar R. MO Eastman. Jama T, ill MO Ssennower. Edward A. MO Fibs, taiid R, MO Gerhard. Serm Steghea MO Ktyrdak, Minerva p.. MO Nemolf. John, M, MO ODormell. Ward ML. MO Psnadea Enrique. MO Ragaa Mark 0, MD. PhD Umtkar. William Oliver. MO Young, X Michael MO Lang Name Rayaa Jose ML. MO Bgdaa Patrick OL, DO Langhonre Ahmad. RaaffiL MO Frananhofler, CfuWsghar, MO Gtas. Zenon. MO. PhO SouilUard. Donald R. MO Zftar, Richard E_ MO Hansafl. John R, MO Sa Andrew Lea MO WHght OaM ML. MO BMa*. Patricia A. MO Latmha BanrdL Rosald t, MO Sum. Josaon Conrad. MO Singh, Usha 0. MO Griffith. Chartes 0. MO Bansnoff. Albert M, MO Bosh. Stapha T, MO ernas. HSarr. MO Gotdttatt Sidney A. MB) MonUeom. Pad ft. MO Orttt Roberta MO PaL Suwshchandta A, MO Plana Jama J, MO flhkatt. wineeo ml. MO Vyfladi. Mart R. MO Yousef. Michael ML MO Kkg 01 Pmssia Haa Aaron CL. MD. PhO Kfag of Schmidt R WRSam. MO Rogera. Robert Aflea MO CNIda James , MO Genttnm. Harry L. MO Silnaa JM A. MO Prevenda Ftarenda MD Siaa Jack N, Jr.XlO Tamar. Leonard ML, MO Santa Michael S mo lampartsr, Robert w,, mo McTlgiaL Arthur R, MO Smooka Mark E, MO TrtvadL GocaUotshna ML, MO ucMitf Gordaa Handd Sot MO LBBk Geynor, WBBwn i. MO MartMlrilag Tctang, Fedx ICM, MO Mackiyrlllt English, Walter 6. Jr, MO Mahon Uafcgar, John R, MO ' Maple Sa Khama. Chanchat. MB) Me Km Rocks SchekmaL Hamid &. MO Mo Keesport - Pot Ftoranta P,, MO .. ` iMBimn Rschar. Sandra L. MO Rtsa Thomas A. Jr,, MO Morhrilld. BObO/Joel R. MO Schroacksranm. Richard F, MO ^Kwea'llljn (L. MO . Swamidaaa Stsphsnasa SJ>, MO Marfia England. Jamas M_ MO Peidmaa Michael MO, PhO Olhva Brian X, MO Petal Prabha H, MO Stavenaoa Alan JL MO Adler. Margaret XS, MO Hcfana wafiar L, MO Horegnan. Frederic Herbert MO Lems. Paul L. MO . MMdMtowu McGary. Carl T, MO. PhO Maaca Chnsdna A. MO WMh, James F., MO Movotv9< Afitudm. Nawar M, MO BsdstB. Canos 0^ MO MfeaabeqL Nemauilah, MO Mysrewitt, Richard L. MO Stonra. Kusum. MD Vhwanaffiaa Urn P, MD Mammilla Ahmed. Galal M MO Siam. Bohen M. FensL MO Margahiwn Zamaa Syed Saeed. MO Moeot Pea QanSea Jasper R. MO Mflof Pfeasaat Waddna Slorta X. MO ""SS Arnold P.. MO Nabarti Laasa Jama Arthur. DO Pattsoa James A. MO 418 UCAREF00009553 noon iw^iu *--**, PrtaM V. MO XbalfflaSua MO Uang, Ptng-Tchang, MO Otnria Join S. MO HU. Mtttf. ftj.0. MO M Cute Hearn, H. ft. MD (atom. EBgaca ft. MO Ong, Bdmendo ft. MO Signer, J. Fred, MO w Cmtariaod Muray. Cheryl Lynn. MO Karety-Stowskl. Rosa Maty, MO Ha* Hitman Ahuja SubasbC. MO KHegar, Hainan L. MO Rmna Panluman <L MO . SUarita fflcftart H_ MO Hatarn Sqoara Beatiey. Eugene A. Jr, MO Shat Afififl G. MO McSrw. John j., Jr. MO Nona. Rabat F- MO Parit, Hydow. MO Sobn.Mn.MO Srtsar. Paul Hareer. MO 8argmi Manual A. MO &Mnan. Andrew S. MO, PM Proto, Gregory F. MO ' Gamma vuaa R_ MO Gu*a dan u mo Kaabaoa WHBani Carta*. MO McCtamama May Jana. MO McSnrasa. Kasbln W,, MO Pair Augustin ft. MO Tamad, Kttostt T,, MO QWanto, Danta, 00 HI cay Hta-OPari. Aztah. MO Pianos. Peter P.. Jr. MO -- vaHoy Sakfflar. Mayan. MO Japfea Leonard L MO Adas. Amy Ann. MO Adeems. Adedmto M. MO Al-Sriaem. Tabsaat Isa. MO Atoander, Nancy 1. MO Alexandria Eugene. 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Josa MO Sacbdma Rtjmv MO Stto. lima M MO Salaar. Hamanda MO Samda Sany. MO Sana. Madrtsfet E, MD Sawbtt, David L MO Sebatokar. Bran A. MO ScMTma Raymond J. MO SotaHfrPartmaa Adrtsma MO Sloaa Stsvsn R^ MO. PltO Soldo. CaCmm R MO Swdmran. F. wnam. MO Svsntkdt. Andrl E MO Unsibat Manon Lara. MO Uy-Puano, Antoma A. MO VUaa flbrara. Canos A, MD Von& Garni T..MO tMoft Tsadna MO mrbal, ttcbtal L MO Wanaa WWan J- MO WMaa Charles. MO waila Gragg S, MO. no WoUt, Jobn Hawvd. MO Woa Zungpaa MO Yagltsaiaa Rauosa MO Yomg, Nancy A. MO ZimgwiH. Srucs C, MO ZaopL Mareato S. MO Zsnra. Loukto. MO Zbang, Pdsnu. MO i Mebaal HL. MO Sbnoldna Henry, MO Satoa Ahmed NabH. MO Pkistotallla Com OcaaW ft. MO Sugrura. Henry MO Urtaa C&Hbrd H, MO AbduUa Mobaned A. MO Aburana Akto. MO Antaragui. Antomo J^ MD Andsregg. Katnenm A. MO. PbO Bnnsa t Leon. Jr. MO PENNSYLVANIA Baedt, Mkmael L MO. PbO Bmraa Howard J> MO Bwmaa Metael Antnany. MO Stoefc Robot &. MO Sarachmtz. Osnma MO Baddy. Robera MO Sranaaa Lisa A. MO . Brandoa Jobn M_ MO BredfekL Voiker. MO Cdma Mym* 1. MD Cbonew. Imm M, MO ama. Mania ft. MO Coma Mann. MO , Comoare. Ezio G- MO Codpsr, David Lymt. PbO, MO Cooosr. Jsanm A. MO Oasaaa Robert ft. MO OaLsca Manuel ft. MO DNr. Rayv. MO Odaran. Paul S MO Oust. Jsontta C MO , Edbog. Sanford ft. MO Eddstam. Josepn m.. mo Fwrandes. Simla P.. MO Mar, Edwin ft. MO Pm. KM ft. MO Gayar, Stantay J, MO Gddmaa Andiony J.. MO Hammad. Azzam, MD Hartsock. Robert .L MO Httsia Robert J_ MO Hoorn. WDKam W.. MO Hu. did C, MO braaL Mlcbam MO daa Nadkw S- MO Jainrat. Katherine M.. MO Jama WDHm &. MO XaowSa SiDoo 3- MO Kapan. Sandra S^ MO e--*i' sttamal. MO Nkrafcy, Samard L. MO Kotwd. Krmat O, MO Katt Jobn E^ MO Lattt Susana ft. MO Lodar. Josaob (L MO. PbO land. Joba W. MO MacPlmsoa Trevor A. MO kdbfdftara. Sestu. MO Manack. Lao. MO Matkm A Judo. MO March. Shashi ft. MO McCarty, Ktnmttt ft. Jr. MD MmdtowsM. Jerry J. MO IMdr, Tltomas ft. MO Mttra. anma ft. MO taouftradeb. Mabtnreb ft, MO Myare, Leonard ft. MQ Radanfc. Mdnael A, MO Mkabta Otbrer Klmka MO Mebola Lawrence C_ MO Mna Jeflrey Scon. MO HortuL Alan MO Otari, ft Pad, MO PTC. Room L MO Para, Canos ft. MO Plana Greg ft. MO Quintana Paulina ft. MO RaDMa Michael Scott. MO. PltO Rmdluwa Parmjsst Singh, MO Raa GutD ft. MO Rm. Uma N.H. MO Rmd. W. Gdna MO i to lAP anreto w me w* UCARE F00009554 PENNSYLVANIA--PUERTO RICO PtmhBgO (cant) flattbort. Howard E. MO Rldiart Charta* A. MO Saflnt Ramona. MO Sarto. ReisukA MO Software. Michael Man. MO Setht Pradeeo K. MO Stagft, Gomnddt MO. PTlO Sloman. Andrew J. MO Sftdbt WBOasi L. Jr. MO Song, Kyo CM. MO Stadan. Irena; MO Stavrides. Alexander P. MO Sundarmann, Join M. MO Surempudi. Ramana K, MO Swadarsfcy, Robart H. MO TauiA WNawton. MO Trium. OanaU A. MO Trombley. 'ram K. MO Trans. Robert David. MO Vey, Erie U MO VbP, Moftamad A_ MO. PM WedA Cyril H. MO. JO Wttoy. Clayton A. MO. PhO Wu. Taung-Teh. MO. PM Youaam. Sarmrt A, MO Yunta, Eduardo J. MO Zabkar, Jcbo Henry, MO Zdlar. WDSam 8. 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MO RtagL Horn ft. MO Samtaattan. Thamarat MO Sma Erie 8. MO ZambihP^la. VtaatA MO Yarttoy Kolb. Todd A. MO Utty. Catty A. MO Pad. Champa MO Shaft. Oaksha A. MO Tor* Oarridt Oavid Alan. MO EecarA Qanrio U. MO Gtabta. Joan 6. MO Godtoca, Jadnm A. Jr. MO Owens, A Oavta. MO WMtatay. Jobe P. MO PUERTO RICO Enrtn-Suaret Erich A. MO Arroyo, Axd L. MO CafetA Agusat MO Pamandet Alberto F.. MO Manat Manuel Anget MO Rota-Slem. Jose Antmo, MO vwpeaai hr iap wwwe w nwe lyw. 420 UCAREF00009555 . /C FINLAND--NEW ZEALAND INLANE Millay, Oauda. MO KONG KONC Mm tnoo Clan. Keang-WSi, MO Piri> RoUigtas-Monsos. Mail K. MO Clan. Joan K.C, MO CNck, Wilson K.W,, MO Mafc, Sana Sat, MO --GERMANY" ZIMaddi Psettbut Franz. MO 4 DnuMflft t Mann, Richard. MO 5000 KOta 41 Matin. Utz P., MO 8500 Hnraban Klay, Rotor. MO. PM) RaOng/Sr. Soravfczaiy, Grades &. MO Buattnsr. Hamas. MO, PM) 1 Lommal, Hemarat MO Kipp, Stsfan P. X. MO SMimMed Saar Kupfar, Msrfrad W,, MO --GREAT BHITAIN- Vattuonai John fl_ MO Allans Arvanrtis. tSmitda t_ MO Csvoum, Sad EL. MO Osdgaonji-PolHL Hatan. MO VouBa-PmSIds. Hail . MO las. Jossph OX, MO. PM> Mg, Ho Ksung, MO - ICELANE 121 Rsyfcfsvtk HaUgnirason, Jonas, MO Sangatora Karnataka Krtslrnamunliy, Sarafa, MB8S. Ma MPH Bugatert, Kareitaka Rao. Govtoda. MO Qaftary, Vlnod 8, MO Hyderabad AP Reddy. 0. ahssfcaa. MO Rarnarayan, XonattO. MO dma Ran, Ramaswamy Moftan. MO n Sat QBp Kumar, MO Oaidma. Anted 0* MO IRISH REPUBUI r. Co Mays Sottrt Sand P, MO McOannalt Leonard. MO Steal George's Jayaram, flutarttd B^ MO tttaaacltsyya. Pddsft K. MO Wad fades Bronson. Joat 0, MO Oman, Piter K. MO Kamady, Christopher. MO 8W Cunt James 0, MO ' 10NDU Tegategtepa Caroana-lagez. Vkgfflo. MO Javier'Zepada. Cates K, MO OKsaea, Joha Conor. 1 ConnoUy, Clarias E. MO Montewr. Sapriat MO KSRAEL- 3n-Oor. David J MO SoaiMa ZMdrt Howard J, MO Kflcotovic. Jurt. MO SBdt tdaaonit Manstan. 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MO fBT UP orHM I* MH tm 408 UCAREF00009556 OMAN--YUGOSLAVIA Honady. Aty A.. MO. ftO lee. Kag H. MO -THAILAND-- i Am. Mamabad Ahmad. Nasear. MO liafnaAd^b*b. Pamikh, MO ^ Kf0SakhaMnayrtifAf. Mala. MO Amina. MO anam; Sanchez. SB A, MO ARAGUAY- Molinas. Uds H. MO PHILIPPINE CiHnnn Qhr tr~1 Croz-SwL Antonia O, MO ' Abhates, Rodolfo M.. MO 1"1SAUDI ARABIA -- ABHA ad. Nadar A. MO I- WKhan. Abdur Rauf. MO SSIfttidm. Anwar. MO Bbobar Ham Anwar Ul. MO Atrr, Stair Sami, MO HaM. PazaL MO Pfrog, JosapB MO Sadi Abdeinhman M.. MO ftddsh TaB--cOerfny, Salah E_ MD Alai Mohammad. MO Attar. Mohammed. MO Al-G*ai& laytt A_ MO ___ Al Muhammad A. MO. FRCP Aaat. Hasan M,, MO Baas43angrsco. AttMo 8, MO Haidar. Afiduhaaaa, MO Human. Antomo M. MO KagMwaHa. Yasmeen K. MO Khan Salem Kuasan. MO Matk, Muhammad tqbai. MO Mashkov. Zayd Ahmad AO. MO QunsN. Saouar H_ MO Sham, Kfcdkant V, MO SINGAPORE Chao. Taa Cheng, MO CMang, Shut Chum, MO lea. Yoks Sun. MO Urn-Tan. Soo Kim. MO Raju. Otmgal G. MO 'StanneMBfairaffl. 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Dtetftatm H, MO --UNITED KINGDOM-- Borden Hams waayon, Charles M, MO Carta Hossin, Ian H. MO CMaMwst Kent Sissons, Hubert A. M) Pounder. Derrick J,, MO iMdon Foley. Patrfek . MO Pnnks.LM.MO Mttaets. Leslie. MO Ray, Rome A. MO SMadan. WM*a Chiong. Ng Wing, MBS Man, Pedro, MO OoUrdenea, AM* 8w MO i"-- 'YUGOSLAVIA Bstgrads-Sertia Vaedlevic. Javan 0. MO f i i ji \ Wncm hr LAP pflned la Md free. J437 UCAREF00009557 TheWorld of Learning 1987 THIRTY-SEVENTH EDITION mm EUROPA PUBLICATIONS LIMITED UCAREF00009558 i UNITED KINGDOM WORLD OF LEARNING Smcn, A.J. M, Theoretical Mechanics Whrino, D. A, Organic Chemistry Johnson. M. U. Continuing Education Stdhins, M. D- Adult Bdueatloa WlOTTAKKR. B. N,, Minim Enginaaring Langmuir, K. H, Art History SnviNS, K. W.R, Theoretical Physia Wills, M. R-, Physical Chemistry Martin, C. Litantura SnvutsoN, 0, Social Work Wood, D. J-, Psychology Maswkx, a. J. B, History Stout, R. L, Medieval History Wooo, D. W., AppliedMathematics MaSSSY, D. 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Electrical Engineering Founded 1969 Academic year: Fabrtiary to October; taarhing takas place in the first sight months, with examinslions in October/ November Correspondence courses fully integrated with broadcasts on BBC television and VHP radio, and residential summer schools. Students an over the an of 18, mostly working in full-time employment and studying in their spars time. Couisaa Ron, a P. R, Biology RamnuoL D.G~F?Applltd Educatiooal Scfeacai HlfiBBl. C. A.. Hhtftfv ShaCXLBTUN, a hUEarth Services Smith, a C, Mathematics S?ARMS, J, Electronics Design and Com- miinwiikfflt Stannajui, F. a. Physics Warhir, G^ Eurupean Humanltiaa Studies I RSADSRS AUB1D08. R. J,, Palaeontology Amos, A. T., Mathematics Balls, M., Medical Cell Biology Bknnktt, G. W.. Physiology BtXNvrr, T,, Physiology Bxrkt, H. M., EnglishLanguage ran ba taken as single entities or accumu lated towards a BA degree. There is also a higher degress programme for the BPhil; MPhil and PhD by research, and 4 taught otaatam degrees. Apart from the band* quartan, there era 13 regions sdmintstering 288 study centres throughout the Blackburn, D. A, Engineering Science Buinmx, J. a. Geography CRBXAfT. D.L. Electronics Design end Communications FLuo, R G^ Mathematics FJUHCa, P^W, Barth Sdaacas Hauiday, T. a. Biology BlanshaRO, J. M.V., Pood Science Booth, H-, Organic Chamiauy Brown, G. A, Education Chatham, S. D,, Textile History CHUB, D. R, Politics Clark, M. A- Philosophy CLARK* K. U, Zoology Coats, K. 3^ Sociology and Industrial Relations Chancellor Lota Bnccs or Lorn Pro-Chancellor: Sir KxNNrrH Bbuull Vieo-ChancrilaR Dr J. H. HORLOOt Secretary: 0. J. Cunch Librarian and Director ofMedia Raeounsa: O.J.SlMn0N Number of full-time taorherr e. 660 Numbac of part-time students e. 12CMXX) HaniUNQ. 0., Philosophy HUL Ra!L ChtmttUY MHtBacBdSoVny aMlds-Risoblbl,TMe.anToeloxcuiScill Commuai- Maron, Chemistry Nhjok, R_ Mathamatica Pouthouu, A, Enginaaring Mschanks Sum, P. J, EartaSdancs Ctltj. D. J. A_ Animal Production Solomon, A. L, Msthematical Phyaica COUMAM, G., Blochamiatzy Thompson, a A, Sodoiogy Crao. 0. J,, Physical Chamiatry Faculty of Arta: Mia.J. Bxuamy Walton, A. J, Physics Doorxkamt, J.O, Applied Physical Geography Bavo, L. Theoretical Phyrics Faculty of Mathematica: Prof. R. Howmn FaeuRy of Science: N. Ckalmbm Faculty of Social Sdancaat Dr M. R. Fnx- WOOOB, P. &, School of Education Wright, J. 8,, Earth Science Evans, W. C, Phytochemistry GRammh, A. Madievai History ______________ t: Or G. Perns UNIVERSITY OP OXFORD Gmavuu, N. P, English Lair School of EducarioaeDr A. Floyd University Offieaa, Wellington Square, Out W. A., Thaontical Mechanics Caanwooo, D,, Mkrobiolcgy CwnsON, D.. Plant Physiology Hamilton, B. F,, Madievai History OOMCTOWOfUMia Institute of Educational Technology: Prof D.G, Hawkridob Oxftcd, 0X1 2JD Tataphona: (0688) 27000Q Originated 13th century Harris, S, J., Metallurgy Regional Academic Serricea: Or 0. Sxwabt- Academic yean October to Juno Hasvxy, B- Management Studies Centra for Continuing Education: M.E. Chancellor: The Rt Hon. The Earl of Hugo, W. B., Pharmaceutical Microbiology RaatAaneim Stockton JONB, M. C. EL, French Hiatoty Vice-Chancellor Sir Patrick Null KOX, D.L, Electrical and Flactrnwla Registrar A. J.Dosky Enginaaring Baths, A.W., leadtuts of Educational Secretary-. L Q. THOMPSON LiorrASOWKS, A* Fluid Power Ttehaoloo Secretary of Faculties: A. P. WEAL! Lloyd, R. G* Genetics BLOwm. ALT.. 3odal Sciences Deputy Registrar (Administration): D.W. Logan, N., Inorganic ChaaistTy Bouaw, G-Arta Roexars Marsmn, C. A, Nouropbarmaoology Massol D. W, Pure Mathematica Mayb, R. J., Biochemistry Pauub, D. F., Nou-Unser Mechanics PoUAKorr, M, Inorganic Chemistry Fulham, R. J., Inorganic Chemistry Roans, T. Q- Theoretical Mechanics Roan, K, Mathematics Rudham. R-. Physical Chemirtry Shxasd, F. W., Tbsoraticai Physics Shu, C, Stress Analysis SOMMttsrnDN. A. H- Clamica BUWUN, 0. A, Mathematica Baomt, G. (X, Earth Sciencaa BtOWH, & C. Philosophy Bymmol J- M-i School of Education CHAMAM, P. Energy Studies CBAMm, M- Mathematics Bluqtt, G. F, Physics Fmua, J. K., Elaetronks Fdotmk, R. 1L. Sociology Gap^ L CL. Barth GLATm, 1L. Profraainnil Development in Education Libeary: sse Bodleian Library Aahmoiaan Museum: sse Museums Number of teachers: e. 1^00, indudlng c 160 pmfassors Number of students 12,781 Pnhflcationa: Oxford Univonity Qaxotto (weekly during term-tiine), Undirpaduatt PmptetUM (annually), Gmduatt Studio Prospectus (annually). Statute*, Deems and Rsguiolions. Examination Dttrttt, Umetmty CaUttdar (annually). Tirow, J. 7~, Medieval Economic and Social Hlstovy TllCX, &, Electrical and Elactxonio Engin eering Goodwin, 3. Biology GanM; J. hi, PiycbNogy HHAaJlUlM, ap .T^S( ociology ONtvnBRY TgACHma omens Theinitials in brackets appearing aftereach prefteanris name and subject represent the Wallwouc, S. C. Physical Chamiatry Watxshousk, R.3^ Metallurgy and Mat* tfitfai 3dtoo HAinamca. D. G-, AppUad Hnoan, G, Minis Catlagw to arhich he ii attached. The key is given below: Ana--All Soule College Watts, M. EL, Modtra History HOUSOSN, R. J* Mathematica BaiL--Balllai Collage 1400 U GAR EF00009559 UNIVERSITIES AND UNIVERSITY COLLEGES Brafc--Brasenoet College Camp---Campion Hail Ch. Ch.--Christ Church Corp.--Corpus Christ! College Exeter--Enter CoUege GreyL--Grayfriara Grain Green College . HertL--Hertford College Jaaua--Jesus College Keble--Kefale College LMH--Lady Margaret Hell Llneae-- Linaere College Una--Lincoln College Magd.--Magdalen College Mansf.--Mansfield College Mart.--Merton College New--Nr* Collets Nuff.--Nuffield College Oriel--Oriel College Pemh.--Pembroke College Ql--The Queen's College Reg. P.--Regent's Park College S. Ana.--St Anne's College S. Ant--St Antony's College S. Ben.--SI Benet's Hall S. Cat--St Catherine's College S. Craae--St Crass Collage S. Edm__ St Edmund Hall S. Ha--St Hilda's CoUege S. Hug.-rSt Hugh's College S. Jolt--St John's CoUege S. Pet--St Peter's CoUege Soot--SomerriU* College Trim--Trinity CoUege Univ.--University CoUege Wadlt--Wadham CoUege Wolfe--Wolfson College Wore--Worcester CoUege Faculty of Anthropology and Geography: CUHtim, B. W,, European Archaeology (Keble) GouhS, A. i, Geography (HertL) Harrow, G. K. Biological Anthropology (Uoaen) HAKVgT. D.. Geography (S. Pet) Needham, It. Social Anthropology (All 3.) Faculty of Biological Sciences: AmoTaGS. P.. Bioraathematic* (S. Pet) Edwards, J. H.. Genetics (Keble) Giuham, C. F- Animal Davetepmant (3. Cat) Hamilton, W. D,, Zoology (Royal Society Reeeerch) (New) Mamwlstam. J, Microbiology (Unacro) Pmlups, Sir David, Molecular Biophyaica (Corn.) . Radoa, G. K, Molecular Cardiology (Mart) . Sunn, Sir David, Rural Economy (S. Joh.) Southern, ELM;, Biochemistry (Trio.) Swntwooo. Sir Richard. Zoology (Mart) Spehcbr-Smith. D- Entomology (Jaaua) WHATur. F. . Botany (Megd.) Faculty of Clinical Medidne: Dothib, R. B-, Orthopaedic Surgery (Wort) Gauat M. G,, Psychiatry (Mart) GRAHAMtSMRH. D. G.. Clinical Pharma cology (Corp.) Choosy Evans. J,, Geriatric Medldna (Green) Hams, R, Medidne--Reghn (Ch. Ch.) MoGn, J. 0*0, Morbid Anatomy (Linacra) McMlCHAXL. A. J. Immunology (Trim) Mont*. P. J.. Surgery (Baa) MOXON, E. Rh Pasdiatries (Jaaua) N*BW/8l0mMl-Davb, Jm Clinical Nauralocy (S. Randle. Sir Pmur. Clinical Biochemistry (Hartf.) Sleight, P., Cardiovascular Medldna <Eutef) Sykes. M. 1C, Anaesthetics (Pemh.) Turnbull, A. CL, Ofaatatrica and Gynae cology (Oriel) VksseY, M.P., Social and Community Medidne (S. Craaa) Weathehall, D.J Clinical Medldna (Megd.) Faculty of English Language and Literstun: Baylsy. J. 0.. English Litarature (S. Cat) - Carey, J,, Engibn Uteratun (Mart) Gray, D,, English Language and Litera ture (LMH) Jouat B. U, English Literature (New) Lin. P. C. T Poetry (S. Cat) Romajns, S* English Language (Matt) Stanley, E. CL, Anglo-Saxon (Pemh.) Fine Arts House. J. P. H,, Blade Prafaaaor Intar-faculty Committee far Japanese Studies: Stocxww, J. A. A^ Modem Jepaneee Studiee (S. Ant) Faculty of Law: AttyaH. P. S* English Law (S. Job.) Brownlie, L, Public International Law (AU 3.) DWORKIN, R, M, Jurisprudence (Univ.) Homme. A.M* CWU Law--Regiua (All &) Rax. J, Philosophy of Law (Baa) Rudoeh, B. A* Comparative Law (Brea.) TUITIU G. 1L, English Law (AU S.) Faculty of Litaraa Humaniorac AoouLL. J.L, History of Philosophy (Brat) Boardman. Jn Claarical Archaeology and Art (Line.) DAVtn, A. EL, Comparative Philology (Sqql) DuMMrrT, M. A. S-. Logic (New) FOEOfr, W.G.CL, Ancient History (New) Harmon. R.M. Archaeofagy of the Roman Empire (Line) UwOe a VttncUnt Hiatory (Ch. Ch.) LbOYD-Jotms, P. H. J, Greek--Regius (ChuCh.) MACINTYRE, "A. J, Mathematical Logic (Mart.) MOLAR, P. G. 0, Andant Hbtory (Bras.) Nngr, R. O. ht, Latin Language and Uiarature (Corp.) Pears, D. F, Philosophy (Ch. Ch.) RuontUD. A. F. M^ Classical Literature (S. Joh.) - Branson, Sir Peter, Metaphysical Phil osophy (Magd.) Faculty of Mathematics: ATJTAH, Sir MICHAEL, Mathematics (Royal Society Research) (3. Cat) Benjamin, T.&, Natural Philosophy (Qu.) BIRCH, B. J,, Arithmetic (Brae.) Dohalobon.S.K_ Mathematics (3. Ann.) Hoabe, C. A. iC Computation (Wolfa.) James, L M, Geometry (New) Morton, K. W., Numerical Analysis (Baa) Penhoss, IL, Mathematics (Wadh.) Quillen, D. G., Pun Mathamatim (Magd.) __ Wooes, L.O. Mathematics (Theory of Plasma) (Baa) 1401 UNITED KINGDOM Faculty of Medieval ud Modem Lan guages: Evans. D. B-. Celtic Literature (Jeeus) Grayson, C- Italian Studies (Mmtd.) Habrb, R-. General Linguistics (Wore.) Mango, C. Byzantine and Modem Greek Language and Literature (Exeter) Michael, LD.L, Spanish Studies (Exeter) Posnxx, R-. Romance Languages(S. Hug.) Faculty of Modem History: HaseeU. F. J. a. Hbtory of Art (THn.) Howard. Sir Michael, Modem History-- Regius (Oriel) Leyeex. K. J,, Medieval Hbtory (AU S.) Mathias. P^ Economic Hbtory (AU S.) Monriombry, D-, American Hbtory (Qu.) OTiBLL, R. J- Hbtory of War (All S.) PUTT. D. C. M*HistoryofLatin America (S. Ant) Pou; J. R^ American Hbtory and Insti tutions (S. Cat) Robinson. R. E* Hbtory of the British COBXDOIlWMith (Balia) Stone, N-, Modem Hbtory (Wore.) Inter-faculty Committee for Modem Middle Eastern Studies: Chepun^M, Contemporary Arab World Faculty of Music (vacant) Faculty of Oriental Studies: Bamr, J. R, Egyptology (Quu) Basr, J., Hebrew--Regnw (CK Ch.) Dowsxtt, C. J. F, Armenian Studba (Ptmb.) Gohnuch, R.F, Sanskrit (Baa) Maobuno. W. F,, Arabic (S. Joh.) MattLAL. aiL. Eastm RaUgioa and Ethics (A11S.) van DSR Loon, Chinese (Univ.) Faculty of Physical Sdaneaa: Allin, K. W., Nudaar Structure (Baa) BTO) *** aTM** Blacxwxll, D. En Astronomy (New) Brady. J. M^ Information Engineering (Keble) Carrington, A* Physical Chemistry '(RoyalSodety Research) (Jceua) Chrotun, J. Physical Metallurgy (S. Edm.) DAUR, R. Research Professor of the Royal Society, Theoretical Physics (AU SL) Dswiy, J. F^ Geology (Univ.) ELUortT. R. J.. Physics (New) HmacH, Sir Frier, Metallurgy (S. Edm.) McConnell, J. D. C, Physics and Chem istry of Minerals (S. Hug.) March. N.1L, Thaontical Chemistry (Univ.) Mitchell, a W. j^ Experimental Philo- Paige, J Joh.) Pbeedo, D.R, Elementary Partkle Physics (S. Cat) Rowunbon, J.S^ Physical Chambtzy (Exatar) Sandars. P. G. fL, Experimental Phjreica (Ch-Ch.) SCHULTZ, D. U. Mechanical Engineering (& Hug.) Turner. D. W,, Electron Spectroscopy (Baa) WtLUAU, R. J. P, Royal Society Napier Research Prafaaaor, Inorganic Chem istry (Wadh.) WROTH. C. Engineering Science (Bras.) UCAREF00009560 UNITED KINGDOM Paculty of Physiologic*! Science: BUKIMORR, C. a, Physiology (Mud.) BR0WNU8, G.O, Chemical Pathology (Line) Gardner, a U Pathology, Royal Soeiaty Rasaarch (Ch. Ch.) Guillbry. a W., Anatomy (Haiti) Mattosws. P.8.C. Sonaorimotor Physi ology (Ch. Ch.) Nomj^^D, Cardiovascular Physiology Smith, A. Dn Pharmacology (L. M. H.) Faculty of Psychological Studies Bryant, P. E, Psychology (Wolfa.) Comv, A.. Physiological Psychology (Line.) WRBXRAwrz, L, Psychology (Magd.) Faculty of Social Studies Bats, W., Modern Russian and East Butopean Studies (WoUfc.) CoHIM, G. A Social and Political <n>eety (A11S.) HalsBY, A. H., Social and Administrative Studies (Nuff.) - Haxuwooo, A. D,, Commonwealth Studies, Research Professor (Pamh.) Hxndry, D. P, Economics Mirrlrb, J. A* Economics (Null) . Nicxkll, 3. J., Economics (Nutf.) PSTSS, G. H., Agricultural Economics, Research Professor (Wolfs.) Puma, P. G. J., Govaramsnt and Public Admmistration (All S.) SlN, A. K, Political Economy (All 3.) Stuna, B. IL, American Government (Nutf.) Inter-faculty Committaa for Slavonic and Baat European Studies Zrmah, 7LA.&-. European HUtory, Research Profasaor (S. Edm.) Faculty of Theology: Nicholson, Rav. B. W., Interpretation of Holy Scripture (Oriel) 0*Donovan. Rav. 0. M.T- Moral and Pastoral Thaolocy (Ch. Ch.) Sanmss. & P., Exegaab of Holy Scrip* tura (Qu.) SwmauaM. R. G* Philosophy of the Chr istian Religion (Oriel) Was*, Rev. M. F,, Divinity--Regius (Ch-Ch.) WoLLusa, R. D,, Divinity (Ch. Ch.) RUDOB Faculty of Anthropology and Geography: Lobwardt, R.G, Soda! Anthropology (Wold) Swbibm, Mbs M.M, Geography <8. Hug.) Faculty of Biological Science* Cbowo, F. A. U. Botany (Magd.) McFarland, D.J, Animal Behaviour (Baa) Ny*. p. K, Soil Sdenca (3. Cram) Phujufson, J, Animal Ecology (Unacre) Faculty of Clinical Medicine: Boon, A. J-, Ophthalmology (Unacre) Louhhau. J. G. G* Medicine (New) PRO, It, Cancer Studiea (Green) Team, D,, Pathology (Green) Department of Educational Studiea: Mcbrrraa, D.L, Educational Studlaa (Jama) Faculty of English Languaga and Litera ture: DsOWC*. U. M., Ancient IceUndie Litemturn and Antiquities (Linacre) McKrm&b, D.F,, Textual Criticism (Pemh.) POLUao, M. M, BibUngraphy (LyeU) Stauwortmy, J. R, English Literature ,, (Wolfs.) Wbavbl M.LH.U American Litere. ture (Linacre) Faculty of Law: Barton, J. u Roman Law (Mart) Finns, J. M^ Laws of the British Com monwealth and United States (Univ.) Hooo, IL, Crimmokgy (Alt 3.) Reynolds, F. M.IL, Law (Wore;) Tamr, C.P. H,, (Magd.) Faculty of Litaraa Humantores: Coultoh, J.J., Oeaekai Archaeology (Mart) McClMN, C- Mental Philosophy (Corp.) Wtuto; A. J,, Mental Philosophy (Wold) Faculty of Mathematics: Edwards, D. A, Mathematics (Line.) Murray. J. D,, Mathematics (CorpJ Sroal, 0. Bn Mathamaties (S. Cat.) Faculty of Medieval and Modem Languagaa: Rart, A. W,, French Literature (Magd.) Sttmitr, L, German (Hsrtf.) Faculty of Modem History: CHAflAd P. T. V. M, Diplomatic His tory (Wedh.) Colvin, H.M, Architectural Hbtory (S. Joh.) Dkxson. P. G. M, Modem Hbtory (3. Cat.) O'Bam, P. It, Eeonomk Hbtory (3. Ant.) . RayCHAuDHWU, T, Modem South Asian History (S. Anl) Whro, O, Hbtory ofMsdkino (Corp.) Faculty of Oriental Shelter Vow. G.. Jewish Studies (Wold) Wnmno-MOLU*, P,, SemiticPhilology (3. Pet) Faculty of Physical Science* . Cuin, D. W_ Information Engineering FROman, A, Chemistry(MegdJ Gbacs, M. A- Nuclear Physics (Ch. Ch.) LLtWBXTM SMITH, C.HL, Thaocetkal Physks (3. Joh.) Moomatn. S, Geology (Linacre) Parsons, fl. EL, Geodesy (S. Cross) Rorwuro, H. M., Physics (3. Cat) Solyuar, U, Engineering Science (BraaJ Tatum, F. W* Atmospheric Physics (Jeaual Whsjul M. J, Physical Examination of Matariab (Unacre) Faculty of Physiological Sciences: Buoar, J. C_ Human Physiology (Corp.) Gordon, G- Sensory Physiology (BiasJ Gordon, a. Experimental Pathology (Raster) PotmrtiLD, J. 3^ Bacteriology IWadk) PowiLL, T. P. Nsuroanatomy (S. Joh.) Faculty of Psychological Studies: Aaonx J. ht, Sodal Psychology (Wold) Faculty of Social Studies: BmmMAH. W. Economics (BalL) Bug, C.J, International Economka (Nu) Goodwin, P.B, Transport Studlaa (Liimcm) Hammxrslxy, J. Bit, Mathematical Statisties (Trin.) Hood R. O, Criminology (Afl &) JOtnrnON, N_ Comparative Study of Inatl- tntkna (Nutf.) 1402 WORLD OF LEARNING KAOR, M. C, Economics (S. Ant.) Roexara, B.A^ Internstionai Relations (S. Ant.) Ryan, A. J- Politics (New) Wilson, B. It, Sociology (All S.) DOUCTORS Archasology and tha Hbtory of Art Raasnnrn Laboratory: Haix, B.T. (Wote.) Aaiunoban Museum: WKrn, C. J, (Wore.) - Edward Grey instituteofField Ornithology: Pwim, C. M. (Wold) Clinical Studies: BarriON.B.J. (Grssn) Computing Service: RoetETTS, A. G. (Wold) Computim Teaching Centre: ELLB/S M. R. (Ch. Ch.) Foreetry Institute: Buaun, J. (Green) Language Teaching Centre: Dyson, A. P. (LMH) Mathematical Biology Centre: Moiuuv, J. D. (Corp.) Inetitute of Economics and NtCBBA, S. J. (Nutf.) Department of Educational Studiea: JUdor, H. G. (Bras.) Department for External Studies: Thomas, G. P. (Linacre) Pfletgraduate Medical Studies Pottxr. J. M. (Wedh.) Queen Elbabeth House: Camrn, R. H. (S. Ant.) Social and Administrativa Studies Halixt, A. H. (Nutf,) Transport Studies Unit: Goodwin, P. B. (Linacre) All Bools College Oxford, 0X11AL' teL (0888) 279379: f. 1438; for Fellows only; Warden P. M. FitAam (acting). Ballioi Collage: Oxford, 0X1 3BJ: teL (0886) mrrtx f.l283; Matter A.J.P. Kinky. Braeeaose Coilegs Oxford, 0X1 4AJ; teL (0668) 277830; .1509; Principal J.K.B.M. Nicholas. Christ Chorohi Oxford, 0X1 LDP; taL KWmSatow! 1 lM8: Ma Th* V,iy Rrr' Corpus Chriatl Collage Oxford, 0X1 4JF; taL (0866) 216700; f. 1517; Praa. K. V. THOtSAR. . Exatar College Oxford, 0X1 3DP; teL (0888) 279600; C1314; Rector The Rt. Hon. Lord CaOWTHXR-HUKT. Qrsts College Oxford. 0X2 6HG; taL (0888) 274770; f. 1979, for graduates Warden Sir John Walton. Hertford College Oxford, 0X138W; taL (0886) 279400; f. 1874; Principal Sir Gmr- ran Warnocx. Jeans College Oxford, 0X1 3DW; taL (0688) 279707; f.1571; Principal P.M. NORTH. . Kabla Collage Oxford, OX1 3PG; taL (0885) 272727; f.1870; Warden C.J.B. BAU. UCAREF00009561 UNIVERSITIES AND UNIVERSITY COLLEGES Lady Margaret Hall: Oxford. 0X260A: taL (0888) 274000; f. 1878s Principal D.M. SnwA*r. Uaacra College: Oxford, 0X1 1SY; taL (0886) 271660; 11962. as Linacw House, lor graduates; Principal J. B. Bambohooch. Lincoln College: Oxford. 0X1 3DR: UL (0886) 279800; 11427; Ractor The Rax. V.H.H.GRHH. Magdalen College: Oxford, 0X1 4AU; taL (0866) 276000; C.1408; Pres. K.B. Gaimx. Morton College: Oxford. 0X1 4JD: taL (0866) 276310; 11284; Warden J.M. Roams. New College: Oxford. 0X1 3BN; taL (0886) 248461; f. 1379; Warden H. McGRf. go*. Nuffield College: Oxford. 0X11NP; taL (0666) 278600: f. 1937, for graduates; Warden M.G. Brocx. Oriel College: Oxford, 0X1 4EW; taL (0886) 276666; f. 1328; ProvostThe Rt Hon. SirZlUIANCOWtN. Pembroke College: Oxford. 0X1 1DW; taL (0866) 276444;f. 1624; Matter Sir Roots BAHMSTHL Queen's Collage. The: Oxford, 0X1 4AW; taL (0868) 279138; 11340; Provoat The Rt Hon. Lard BlaU. St Anne't Collage: Oxford, 0X2 6HS; taL (0866) 274800; f. 1893 (at Society of Oxford Homo Students); Principal hue C.D.T. Palls*. St Antony'* Collage: Oxford, 0X2 6JP; taL (0866) 59681; f. I960, for ftadnataa; Warnan A. R. M. Cam. , St Cntherine'a College: Oxford. 0X1 3UJ; taL (0868) 249641; .1868, reeoiMt1totad at a foil College 1962; Matter The Rt Hon. Sir Patmcx Naows. St Croce Collage: Oxford. 0X1 3LZ; taL (0866) 278490; f. 1988. forgraduates; Ma^ C. H. Sta/toma St Bdannd Halb Oxford. 0X1 4AR; taL (0866) 279000; Le. 1278; Principal J.C.B. Gowns. St HUda'e CoUege: Oxford. 0X4 1DY; taL (0888) 276884; .1893: Principal Mrs Q. M. Moons. St Hugh's Collage: Oxford. 0X2 6LS; taL (0868) 274900; f. 1886; Principal MfanM. R. 'nuatziT. St John'* College: Oxford. 0X13JFJ taL (0888) 277300; 11566; Prat. Sir JOHN Kmonw. St Petar*a Collage: Oxford. 0X1 2DL; taL (0866) 278900; 11929aa St Peter's Halt; Mjetar G.E. Aylmbl SemerrUle Collage: Oxford. 0X2 6HD; taL (0868) 270600; 11879; Principal Mbe a M. S. 0. Pakx. Trinity College: Oxford. 0X1 3BH: taL (0868) 279900:11684; Praa. The Rt Hen. Lord Quinton. University College: Oxford, 0X14BH; taL (0886) 276602; .1249; Matter K. Banrera. Wedham College: Oxford. 0X13PN; taL (0866) 277900; l 1612; Warden Sir CtAU9 Moos. Wolfeon College: Oxford, 0X2 6UEK taL (0866) 274100; . 1968. for graduates; Praa. Sir Raymond Hovtsnbixo. Woreeater Collage: Oxford, 0X1 2HB; taL (0666) 278300; L1714; Provost The Rt Hon. Lord Banco. aUANXOT FMVAY8 HAUS Campion Hall: Oxford. 0X1 IQS; taL (0668) 240861; f. 1896; Matter Rax. P. HAOtarr. Greyfriarst Oxford. 0X4 1SB; taL (0865) 243894; .1910; Warden The Very Rax. T.M.MANN. Mansfield Collage: Oxford. 0X1 3TFi taL (0868) 270999; f. 1888; Principal J.L. Worn. Regent's Perk College: Oxford. 0X1 2Uk taL (0888) 69887; .1810; Principal Rev. & R. Wnm St BeaePe Halb Oxford. 0X1 3LN; taL (0688) 818006; .1897; Matter Rax. P. a Koldswobth. ATTACHD INgmVTB Maisoo Prtncaita: tea undar Learned Societies. NBRC Institute of Virology: too under Buaetcb Institutes. Templeton College, Oxford Ctntn for Man* sgsmant Studies tee under Colleges. Oxford inttltuta forBnargy Studies: 29 New Inn H*U St, Oxford. OX12DX; . 1963; Dir R.&.MABML Centra for Poatgraduata Hebrew Stodies: 46 St Giles, Oxford, 0X1 3LW; Praa. D. PATTBttOM. Centra for Sodo-Lanl Stolen Wolfoon Callage, Oxford. 0X2 6UD; Dir D.R. Hamus. ScTaSwTwSTda^pmgat Uodiaa Ian Ramsay Centra: St Crass Collage, Oxford, 0X13LZ; Dir A. R. Psacoca Oxford Centra for Islamic Stodies tee undra Rueardt Institutes. UNIVERSITY OP READING Reading, Berkshire, RG6 2AH Talapboos (0734) 878123 Talas 847813 Uniwrite Bxtanafow College ratablfahad 1892; University Charter granted 1928 Chanarilart The Rt Hon. Lord SnxratP VkeChancafior: & 3. P*a* Deputy VhwChanrallnr: Prof J. Wnour Pro-Vtca-Chancsflor: ProC. C.R.W. Sr*D- RagiatranT. Borrouur Librarian: J. Tbososon library: tea Libraries Number of tsariwrr 680, including 34 pro. Number of students 6,408 PnbBritfncu Awcstdinga of the Uniovtity (annually). FacultyofLattan and Social Sdancar: Prat K. David Faculty of Science: Prat G. W. A. Fma W**1--r-enat* Faculty of Urban and Regional Studies: Prat A. W. Evans School of Education: ProC. R. Wilson (Chair.) - (rams prafemore serve in mors than one foeutty) Faculty of Letters and Social SdaneaK Boost, M. O. History 1403 UNITED KINGDOM Cautbw. P. W,, Politico CAUON. M. C, Economics CootaW.A. Carman David. J. C. R, Sociology David, 1C. Law Davos. M. Cm Franck Davis, &. Psychology Down**, J. 1C HUtory of Art Dunning, J. H,, International Investment and Burinam Studtw Duhov, J. t/L, Murie BMZMM, W. G. van. Franeb Bvam, A. W,, Enviranmantai Eeonomia' PltOV. Mm Fine Art Guoobv, R. Gm Poiltkt Gun, A. Engluh Hau. P. G,, Geography Hutton, Om History Jaodon. Pm Law . KMNUON.J.R- French Lsschy. G. C_ Italian BdATTOIw, D. J. Am History Nona. Iff, Finance ana Accounting PALMDL F. Rm Liiuuudc Sdence Pauunbon. a H.R, Philosophy Pjuuukdbu J. Pm English Rsivxun, W. D, French ' Rudba, W. M. Sm Sociology Salvxsxn. C. G., English SMRH.AT.lL, Law Twyman, M. Lm Typography and Graphic Communication Utton, M. A, Economka WASmnuN, a Mm Psychology WtUOM, D. Am Applied Linguistics Faculty of Scienca: Aook T. IL. Computer Sdanca Alum, J. R. Lm Geology Almoho. J. Wm Mtenbiriogr Anna, A Gm Mechanical Engineering BAUY, D. K. Geology Bakx*. K. Dm Computer Sdanca BaSDT. D. d, Physics BxrcsSMrrH. Dm Organic Chamiitiy Cuxhow, R. Nm AmUsdStatbtici OnowON. H. CL. Plant Cell Genetics DOJ, R. Rm PhysMogy & Biochemistry Dunn, P. Dm Engineering Science Bonn H. P. van. Applied Entomology EVAis,TMPbYri FmranrP. 8m Cybernetics Fowidl G. W. Am Inorganic Chemistry Fxby. H. Mm Physical Chemistry Hahnmns, J. Bm Botany Hmrouo, V. 1L. Botany Honma, 3. Jm Metaorology Harr, J. Nm Applied Mathematics Jknmngs. B. Rm Physks Lownr, P. Jm Physiology and Bto- McCOMsa, C. W, Physics MlAD, R_ Applied Statistics Miua, L Mm Cbamkai Spectroscopy Moon, a Mm Botany Nash-Wiluams, C. Sr J. Am Pure Math* NtmuN. R. C. Phyrica Numtkn, H. Bm Food Sa'saca Puna, R. Pm Meteorology SMU. M. J, Applied Msthemetics SaaoD. K, Zoology Wan. A. Soil Sdnce WhCTtTj. D. Mm Pure Mathematics Faculty of Agriculture and Food: Camtsill-Putt. Gm Food Technology GOD, A Km Farm Management Haryhy. aR, Agricultural BcoaomJcs and Managamant MaxSH. J. Sm Agricultural Economics and Modol^Rm Agricultura UCAREF00009562 1 'I I I I t I I I I I I I I I I 1 I it mOW WIU * _. (./.OfJ >rui_ci 4 tilKUncX.MtLJH ( Ayjvo) ax2aaai34o;# 2/11 ZH THE UHITED STATES DISTRICT COURT FOR TBS EASTERN DISTRICT OP PENNSYLVANIA ----- ------` ------------..I.,g IB RSI ASBESTOS PRODUCTS LIABILITY LITIGATION (MO. VI) civn. action so. mdl 7S X This Document Relate* Toi DMITBD STATES DISTRICT COURT FIFTH DIVISION DISTRICT CP MINNESOTA CONNED CORPORATION, Plaintiff, va. UHIOS CARBIDE CHEMICALS AMD PLASTICS company, ixc. (f/Jc/a union Carbide Corporation), Defendant, aw* UMZOH CARBIDE CHEMICALS AMD PLASTICS COMPANY, INC. (f/k/a union Carbide Corporation), vs. OHENS-CORMIHG FZBSRCLAS CORPORATION, SAUCER JAMAH COHPAHY, A.N. EUBTTEL SONS, 1HC*, API, 1MC., AED HACARTHUR COHPAHY, , Tbird-Party Defendant*. Case Vo. t Civ. 5-91-88 j ) y agm.- U ^Wf.n7 - ORSON CARBIDE CHEMTCATJ AMD PLASTICS COMPAIY, HO.** PBRLXMXRBRY SfAXEMRMT 1B8ABDDW HURT EXTHBSSIS MON COMER union Carbide Chemical* and plastica company. Inc., and it* attorney*, and for its preliminary disclosure U CAR E F00009564 uwi i u4 * -tm aOU"O < wA > 4- *- . r-iant it-OLcr & UKUxER.MUJf-* 0123331940;* 3/11 concerning export witnesses, provides the following objections and information* oikxxax. oBjacnoaw Onion carbldo in net in a position at this point in the case to provide a definitive list of expert witnesses, nor to provide a ceaplete list of the facts, opinions, or subject natter on which any experts it calls say testify. Plaintiff cenwed Corporation has still net furnished reports free two of its three experts, and Obion Carbide still has not received a portion of Art hanger's report, onion Carbide has not had an opportunity to depose two of conwed's experts, and baa not finished the deposition of the third, consequently, onion Carbide does not know exactly what testimony or opinions Convad nay offer, nor what work it experts say produce. Accordingly, onion Carbide cannot at this point know exactly what it will ask its exparts to do in connection with this ease, and so Onion carbide reserves tha right to assnd this disclosure by adding or deleting expert witnesses, or the soope of their testimony, as developments in tha case warrant. Without waiving thssa general objections, onion carbide can provide the following information about its experts as of this timei i. mouaomoozsffl A. Kitchell O. Kayo, M.D. Minnesota Lung Canter Suite 700 930 Bast 38th Street Siimespolls, MH S5407 Or* Kays is a medical doctor and a pulmonologist. Ha -3- UCAREF00009565 i -jili 6UU Uigi i .-<h i <`iira rrwxl 4 UUtDfR, MlLJf-* 8123331340;# 4/11 I will testify, based upon his rsvisv of ths nadieal records, x-rays, test results, and other notarial (possibly including an independent examination), and In light of his training and experience, concerning whether certain former employees at the Comred plant suffer any asbestos-related injury. Or. Kaye aay also be asked to state the extent to which any employee she has an asbestos-related condition has been disabled under Minnesota's worker's ceapensation law, to aaks aaseesaenta of the extent of aay such disability, and to consent on the limitations (if any) that such condition would place upon ths fetaer eaployee. Dr. Kaye aay alao he asked to testify to general nodical knowledge concerning the body and the lunge, and to general knowledge concerning how the body interacts with asbestos. Dr. ' Kaye aay also be asked to give opinion* concerning the prognosis for any particular Centred worker, or for the group of workers* B. Dr. William Weiss, N.D. 3912 xsthsrfield Hoad Philadelphia, PM 19129 Dr. Weiss received hie Bachelors and his N.D. degrees free the university of Pennsylvania. Be was a yellow of the college of chest Physicians, and is a fellow of ths American College of Physicians, m addition to being a pulaonologist, Dr. Weiss has trained as an epidemiologist, and has taught epidemiology. Be is a Professor of Medicine, wasritue of Hshnssnnn university Medical School in Philadelphia. Based upon hie training and axperianca, the scientific literature, inforaetioa provided to bia about tbs Conwed plant and -3- UCAREF00009566 I I*-* I iii-u uvu.i * uiAUlCIt, JtiUl** auiMamu:* 5/11 Conwed employees (or former employee*}, sal information about Calidrla, Dr. Weis* may ba aakod to give opinion* concerning the extent of ashestos-rslatad disease found in former Corned workers; the role, if any, which Calidrla asbestos played in producing that disease; the role which the amoslte used in the plant played in producing that disease; the expected future Incidence of asbestos- related disease In the group of former Conrad workers; and whether the disease that has been identified to this point is actually an asbestos-related disease or is caused by some other factor. Dr. Weiss may also tsstify about general medical knowledge and general knowledge oonoeroing asbestos and its interaction with the human body. C. Sr. Hilton c. Lewinsohn, X.D., B.C.h., F.F.o.H., F.A.C.Q.B.X., F.C.C.P. and D.X.8. Center for occupational and Snvironmental Health at Bxster Hospital, Inc. 108 High Street BXSter, HB 03833 Based upon his training and experience, hie review of the aoientifio literature, hie evaluation of materials relating to the Cenwed plant and to Calidrla asbestos. Dr. Lewinsohn may ba asked to give opinions upon the ability of Calidrla asbestos to cause disease in workers under the conditions during which it was used at the Conwed plant, the role of amoslte and the production of disease in the workers at Corned, the extent to which former Conwed employees at Cloquet suffer from asbestos-related disease, the scientific literature regarding tbs ability of chrysotile and short-fibsrsd chrysotile to cause disease, the appropriateness of the steps taken by Caused's management from an occupational health -4- UCAREF00009567 ia (l -a-W x u- , ( -lulA 'iWjil Cf L^itUlRU, JL|Ufx aizattUiHU;* b/u standpoint la light of the knowledge available to than, and the extent to which alleged health problems la former conwed workers are attributable to factor* other than asbestos, fir. Lawinsoba is also a former employee of union Carbide. zx. ranotoaxszs A. Dr. 2d B. Ilgren, 8.A., M.D., D.P.H.I.L., K.A.C.P.A.VH. , K.8.C.9.A.T.H. Conwyn Apartments, Vo. SOS aao Montgomery Avenue Bryn Her, BA 1S010 . Dr. Ilgren's teetiaony will be based upon hie training and experience, hie review of the scientific literature, hie review of the opinions and'testimony provided by plaintiff's experts, Me review of materials relating to the Conwed plant, and his review of materials concerning calidria asbestos. Or. Ilgren will testify on the biological effects of exposure to Calidria asbastoe, and offer the opinion that of all types of ohrysotilo, Calidria is the least active. Moreover, he will testify that chrysctile uncontaminated with asphibola cannot induce aeeothelioaa* m the Conwed plant, lung cancer would either have been related to amosite exposure, smoking, or soma other cause aside from Calidria asbestos. The putative mesotheliomas noted at Conwed would have been due to amosite exposure or a nonaabeatoerelated cause, fir. Ilgren will show that pleural thickening is not specific for asbestos exposure, while pleural plaques, though possibly specific for asbestos, do not carry any future cancer risk nor iapoaa any significant functional iapaixnant. Dr. Ilgren will also dis cuss the biological difference b etween long and short fiber UCAREF00009568 < I I '*u j iiulu <* l-rtAKtCA, JUjf* oi2wai840;* 7/u using data from animal experiments, human epidemiological studies, and him review of the aedieal literature, especially am it relates to the mineralogical and physical properties of Calidria that distinguish it from other types of asbestos. Or. Zlgren may also refute claims of plaintiff's experts on issues relating to these topics, and say also he asked to give diagnostic opinions concerning the medical status of individual cases of former Canned employees, based upon the olinioal and pathological materials available for review. In the course of this testimony. Or. Xlgren may provide general medical and biological information upon which his opinions are based. B. Mien Gibbs Pathology Department Landough Hospital Psaarth, Glamorgan OK CPC 1 IX If Dr. Gibbs ie called, it will be to testify about the biological offsets of axpoaure to calidria asbestos, and compare and contrast that to tha offsets of axposurs to other types of asbestos. Dr. Gibbs may be asked to give testimony based upon his personal experience concerning asbestos-related diseases in tha united .Kingdom. He may consent upon the biological differences between different types of fibers, based upon data reported in tha medical literature, and upon materials gathered from his own work and observations. Dor. Gibbs may also be asked to ceamont upon the opinions and work of plaintiff's experts. UCAREF00009569 SAZ4 , * im i ctjrJi ,rutxi t-iututtlc,JiiuH 8123331340;* a/ll ( ixz. xnmrasz&z. i*oudizsvs A* Richard J. LM| ph.O. R.J. Lm Sroup, me. 390 Hochberg Read Monroeville, PA 18140 Dr. Lee obtained Me Ph.D. in theoratical solid state physics. His specialty is analysis of notarial# with electron microscopy, quantitative electron diffraction techniques, automated electron diffraction pattern analysis technique# and automated techniques for combined x-ray microanalysie and electron microscopy. Zf aSked, Dr. Lae will review the work of plaintiff's experts as it relates to the composition of cslldria asbestos in materials takan from the KChC mine. Dr. Lm may also be asked, ee an industrial hygienist, to consent on any calculations of dust concentrations or asbestos concentrations la tha atmosphere at the Conwed plant. He may also be asked to examine materials taken from the Conwed plant for their asbestos content. B. Dr. Harrison Rhodes e/o Kelley, Dry# 4 Warren 101 Paris Avenue HSV York, HY 10178 Dr. Rhodes was employed by onion Carbide ae an industrial hygienist, and In that position supervised Obion Carbide's dust count program for Calldria customers until Jtone 30, 1085. If asked. Dr. Rhodes will give his opinion, based upon his experience, training, and information provided to him about tbe Conwed plant, concerning dust concentrations in the plant. Dr. Rhodes may also be asked to ecmaast on any calculations of duet -7- 4 UCAREF00009570 gUM ui `-tit/ +~*k , .ruuir & uKOMX.Jiiu-. 8123331340:# 9/11 concentrations aide by plaintiff's exports. Ee is also knowledgeable concerning the dust counts which were taken at union Carbide's nine and sill in California. C. Or. Bobort Murray c/o Salley, Drye i Warren 101 Park Avenue wev fork, mr ioi78 Dr. Murray is a professor of industrial hygiene in England. Ee has extensive experience inspecting industrial facilities in the united Kingdom. Be la familiar with, and can testify about, the historical developnent of industrial hygiene and safety practices employed by plant managers to protect their workers froa asbsstos when asbestos was used as an ingredient in the sanufacturing process, if asked to testify, professor Murray will explain that Conwad failed to taka atsps to protect the health of its workers fras asbestos, despite the fact that such steps and techniques had bean known and reported since at least the 1930's. Dr. Hurray will also base his testimony upon the information regarding conwed's knowledge end practices concerning asbestos. D. Doug Heel o/o Kelley, Dry* & Warren 101 Park Avenue Hew York, SN 10178 Mt. Heal is a retired Industrial hygienist who previously worked for union carbide. Be has extensive experience with asbestos, and is familiar with and oan testify about the history of the use of asbestos in Industrial facilities, and the history and developnent of Industrial hygiene and safety practices related to that use. If aakad to testify, Mr. Heal will express the opinion . -8- UCAREF00009571 t <4-z , i XLl A il ULli 4 ajUl-i Oi^iwaiMUi #10/11 that under good Industrial hygiene practice, Comrad had the primary responsibility for insuring a safe place tor Its asployees to work, and that Conwed failed to take basic steps to protect its workers. xv. Kxxnuoaxtw A. Mark van Busies Harvard University Cambridge, HA 02138 Mr. van Buelen is a alneralogist who has extensively worked In and studied with the Maw Idris area in California. If asked to testify. Hr. van Buelen will explain the geologic forces that produced the Mew Idria area, the Calidria asbestos deposit, the geological and eiiteralegioel facte that sake Calidria unique, and how those factors affect the final characteristics of calidria asbestos. Mr. Van Buelen is also knowledgeable concerning other minerals found in the BSw Idris deposits, and will testify that there is no fibrous aaphlbole contamination in Calidria asbestos. Mr. Van Buelen also has sanplas of Material taken from the King City mine, and nay be aeked to testify about that Material and/or to critique the work of plaintiff's expert Art Longer. B. Professor Fred Poolay school of Engineering Department of Mining Minerals university of mass P.O. BOX 817 Cardiff, Males CP21KB . Dr. Fooley 1s a alneralogist who has spent such of his career investigating the biological effects of various minerals, particularly asbestos. Bo is knowledgeable concerning the difference la biological impact between Calidria and other typaa of asbestos (including the difference between Calidria and other types UCAREF00009572 - - i w 4 t , <4- *- , /.aura JfULtr A UKDMiMIUH { 6123331S4Q;1/U of chryaotilo). Dr. Fooloy say also testify about the differences in biological effects batman abort and Ion? fibered asbestos fibers, d offar opinion* on tha lack of affaot that calidrla voold have bad on tha boaltb of Conmd workers, and tha fact that tha anoaita usad in tha plant 1* likely responsible for any aabestos-inducsd nasothallana found in tha working population. Or. Foolay nay also ha askad to eritiqua tha work and opinions of plaintiff** exports. c. Dr. yrad wuxptcn 31 Sharvoed Drive Broekport, mr 14420 Plaintiff has already dopoaod or. JCuspton, and is familiar with his areas of expertise and his opinions. If called to testify. Dr. Muxpton will describe tha nature of Calidrla asbestos from s geological and minoralogioal perspective, tha natura of tha irev Xdrla deposit from which it is mined, and what makes Calidrla asbestos unique. Or. Xuapton may also bo asked to testify concerning his work for Union Carbide. M.Dated this day of February, 1994* vounr a uuBDfiEB, Attorneys for anion Carbide Chemicals and Plsstios Co., xne. 777 Beat Wisconsin Avanua Milwaukee, MX 93202 (414) 271-2400 -10- UCAREF00009573 f (he .nee Hi* or us uCld sE: A COMPARATIVE STUDY OF PULMONARY TUMORS FROM THE SAN DIEGO ZOOLOGICAL GARDENS AND THE TUMOR REFERENCE COLLECTION, IMPERIAL CANCER RESEARCH FUND, LONDON E. B. ILGREN, L GRINER K. BENIRSCHKE, AND L. S. C. PANG Spontaneous primary neoplasm of thelung are uncocunon in many animal speci.M The predominant human pulmonary tumors, the squamous-cell and oat-cell car cinomas,*'* are believed to be causally related to cigarette smoking, are more fre quently seen in urban than rural areas, often metastasize early and widely, and repre sent a significant proportion of all types of human tumors. Similar histologic lesions are almost unknown to occur spontaneously In domestic and captive wild animals. This paperexamines in detail most of thf 31 pulmonary tumors found in the cap tive wild animal collection of the San Diego Zoo (SDZ), as well as the 1 lung tumors from the Tumour Reference Collection (TRC) of the Imperial Cancer Research Fund,London. The TRCcases were received from comparative pathologists throughout the world, and have not been described previously. The object of this study was to determine if tumors from either the TRC or SDZ series histologically resembled certain human tumors associated with exposure to dif ferent pulmonary carcinogens, such as cigarette smoke. DESCRIPTION OF CASES Reptiles To date, few primary epithelial or meseachymal pulmonary tumors have been found in reptiles.'*-1* There were 28 reptilian tumors in the SDZ series--12 percent of the total--but only 2 of these were found in the lung. The first case(SDZ-2J95) was that of 331 UCAREF00009574 332 B.S.IIgrenetal .jj_r. Papillary adenocarcinoma extern fl<Wa) Hin&vad^in2g13lun(3gQa2t.2C5a9p9a). cobra (Na/a a Cape cobra (Naja nivea) with a pulmonary adenocarcinoma that extensively in vaded the lung parenchyma as well as the mediastinum. The tumor exhibited the cytologic features ofa peripheral, bronchiolo-alveolar tumor(Fig. 1). Thesecond case (SDZ-4538; AFIP1343278) was that of a timber rattlesnake (Crotahu horridus) with a metastatic lymphosarcoma and an associated urate nephropathy.'* Birds The mortality due to neoplasia in some species of fowl may approach 60 percent; most tumors found in birds are hematopoietic in origin.1*"-1* In addition, Stewart and Ratdjffe found 19 primary pulmonary epithelial tumors in the Philadelphia study,1-17 and at least 6 of these were shown to be malignant. As Campbell states, the primary pulmonary epithelial tumors ofbirdscan be extremely difficult to distinguish from the bronchial epithelial hyperplasias associated with chronic Inflammatory conditions." The infrequency of avian pulmonary tumors is probably related to several factors.I|UU For example, birds have a relatively long trachea, variable numbers of mucous glands, large air sacs, few lymphatics, a diffuse reticuloendothelial system, and a rapid respiratory rate. Such physiologic variables significantly influence the degree, type, and pattern of particle deposition within the avian lung. These differences could in turn account for the low frequency of avian pulmonary tumors which are histologi cally similar to (hose human neoplasias associated with, the deposition ofcarcinogenic particuiatematter. UCAREF00009575 i axtenua (Ns/e /ely fo iled the mdcase <s) with A Comparative Study of Pulmonary Tumors 333 Inthepresentstudy, three avian turnon were examined..'Tie first case, involvinga wood partridge(Rotlulusroulroui SDZ-I0286), was found to be a small tumor arising from a major bronchus. There was no other evidence of endobronchial growth, nor. any clear association with the overlying submucosal glands. Histologically, the tumor resembled the rare oncocytoid variant of a human carcinoid.* Although the argentaf fin ceil system from which the human carcinoids are thought to arise has also been demonstrated in mammals, birds, and some invertebrates, pulmonary carcinoids are rarely found in any nonhuman species.*34** The other two cases included that of a peaceful dove (Geopedla placida SDZ-8362), which died from a metastatic pan* creatic. papillary adenocarcinoma histologically similar to its human counterpart.3' and that of a blackwinged stilt (Hlmantopus leucolopftoius SDZ-89J8), which died from a metastatic squamous-cell carcinoma. The latter arose from a primary rumor associated, with a chronic ulcer of the right wing. The origin of human cancers from sites of chronic inflammation, i.e., old burns and draining sinuses, is also well recognized.* Mammals Marsupials, Previously, only two other pulmonary tumors have been found in mar supials. These occurred in American opossums (Didetphis marsupials) (PhZ~ 99803-''*), one of which died from a bronchogenic, epidermoid carcinoma, while the other (Lndn-64871M) expired with a bronchial adenoma. Thesingfcpulmonary tumor noted in this study arose from a major bronchus within the lung of another American opossum (SDZ-6864). The tumor itself was well circumscribed and glandular, with few mitoses. There was extensive inflammation and necrosis in the adjacent pulmonary parenchyma, but little evidence of invasion by tumor. Microscopically (Fig. 2), the neoplasm resembled one of the atypical pulmonary epithelial prolifera tions of humans.* Edtntata. The pulmonary lesion discovered in a nine-banded armadillo (Dasypus novmcinctusSDZ-10808) has been described in detail elsewhere.* The tumor was a benign, peripheral nodule that histologically resembled human focal adenomatosis.*'* The alveolar lining ceils were replaced by mucus-secreting columnar epithelium, and there was no evidence of endobronchial infiltration."** Similar lesions have been ar tificially induced in the horse and rat with Croiatarta retusa, in the rabbit withdlbenzanthracene and rubidium-173,* and in thesheep by various means.11*41 Rodsntta and Lagomorpha. With the exception of mice, spontaneous pulmonary tumors are relatively rare in rodents.4*"1* This is especially true of hamsters,1-41** guinea pigs,1**' and rats.41 Furthermore, guinea pigs and rabbitsare particularly resis I tant to the development of induced lung tumors.* However, the hamster has, in con trast to Its tow frequency ofspontaneous lung neoplasms, a relatively high incidence of induced squamous-cell tumors of the trachea and major bronchi.13*4 Spontaneous lung tumors of rodents are usually peripheral, solitary adenomata.3**3*4, and are much less common than secondary tumors such as metastatic lymphosarcomas. Fur thermore, induced squamous-cell tumors are more common in the hamster and rat UCAREF00009576 PIG. Z Lsft.A pulmonary adenoma loanAnurlcanopossumtO/de/p/iij marsop/affsKKimblingan atypical epithelial proliferation of the human lung. H4E. *55. Right Detail of tumor to tha right (SOZ-6864). H4. x213. than in most rodents..Although such squamous-cell neoplasms metastasize in frequently, metastasis, when it does occur, is usually to atypical sites such as the kidney, rather than to the liver and the lung, as In humans. The mouse is the only ro dent with a relatively high incidence of spontaneous pulmonary tumors." Such neoplasms are mostly subpleural and adenomatous. As in the rat, these tumors are rarely invasive, and less than 4 percent metastasize."-*1 Only one adenocarcinoma was found in a mouse (n the present study (TRC-1214). it was widely metastatic and in vasive (Fig. 3). No oat-cell carcinomas and very few spontaneous squamous-cell car cinomas have been found in mice."-*1" Thirty percent of the metastases from these rare, spontaneous murine carcinomas become sarcomatous.*' induced murine pulmonary tumors, in contrast to the spontaneous types, are usually multifocal, metastatic, and centrally-situated squamous-cell carcinomas." Extensive genetic studies on murine pulmonary neoplasms have established a relationship between the susceptibility to developing puimonary tumors and genes associated with certain mor phologic characteristics, e.g., flexed, waved, and vestigial tails.** Puimonary tumors are almost unknown in captive wild rodents other than the wild house mouse. No cases have been found in the Philadelphia or London Zoological collections. In this study, multiple, peripheral adenomata were found in an Antelope ground squirrel (Citattus leueums SOZ-9413), These pulmonary lesions (SDZ-9413) (Fig. 4) histologically UCAREFOO009577 UCAREF00009578 * 336 5.B. llgranetal. resembled those seen in a laboratory mouse (TRC-600J) {Fig. J) and a hamster (TRC-6008). Carnivon. Neoplasms are found In S percent of aU breeds of dog,' 43*4 and the brachycephallc strains, such as the boxer, have the highest incidence." Overall, how* ever, pulmonary tumors are relatively rare in dogs, comprising from I to 3 percent of ail canine neoplasms. The average age of dogs with pulmonary tumors is 10 years,1" and there is no urban-rural variation in tumor incidence.1* In one study of 16 lung tumors from over 10,000 dogs," 12 tumors were bronchiolo-alveolar, and these failed to metastasize. The ocher 4 tumors in this series" were also giandular, but were associated either with foci of squamous metaplasia, or, more rarely, with squamous cell carcinoma. Many induced lung tumors in dogs are alveolar, and these rarely metastasize beyond the hilar lymph nodes."*'4 In the present study (TRC-2368). a 9-year-old male English setter died from a bronchogenic adenocarcinoma which had metastasized to the hilar and periaortic lymph nodes (Fig. 6). This animal's tumor ap peared to arise from the bronchial epithelium, and was histologically similar to the feline tumor described below (cf. TRC-3334) (Fig. 7).J Spontaneous lung tumors in cats are even less common than in dogs. They are usually subpieural, multifocal, and glandular.3* Such tumors metastasize more fre quently than those found in dogs, and squamous-cell carcinomas are practically unknown in this species, in contrast to these peripherally situated tumors, those found * ar UCAREF00009579 UCAREF00009580 338 . 8. Ilgren at al. . * rt>nRi.-'v FIG. 8. Bronchogenic adenocarcinoma In a domestic eat. Tumor appeared to arise from subeprtheiiai glands<TRC-430S).H4. *13S. in cases TRC-3334 (Fig. 7), TRC-3266 and TRC-43S8 (Fig. 8) arose from major bronchi, and all three were found in domestic cau. The first two were papillary adenocarcinomas, while the other was a secretory adenocarcinoma which arose from subepitheiiai glands,.Although no squamous-ceil carcinomas were seen in domestic cats, bronchiolar squamous metaplasia, a potentially premaUgnant lesion, was seen in one animal (TRC-3640). - ' Spontaneous primary pulmonary epithelial tumors are extremely rare in captive wild carnivores, and only one such case was found in the present study. This animal, a snow leopard (Panthera uncia SDZ-4793), died with multiple pulmonary adenomata. These unusual lesions were histologically similar to those just described in the domestic cat (TRC-3266), and were also of subepitheiiai glandular origin (Fig. 9). Severalspontaneous secondary neoplasms were also found in the SDZ series. A maned wolf (Chrytocycn braehyurus SDZ-11376) died of a metastatic, papillary renal car* einoma not unlike that described in an earlier study. (See PhZ-190601.) Microscopi cally, these tumors resembled their human morphologic counterparts.14'7 Another maned wolf (SDZ*10282) died from a metastatic fibrosarcoma arising from its right femur. Sarcomas ofbones are particularly common incertain strains o fdomestic dogs (e.g., the Great Dane), and some have suggested that there is an association between extreme leg length, constant mechanical stress, and the development of hind-limb tumors. Although the maned wolf physically resembles these large domesticated strains of dogs, few tumors analogous to the ones found in the Great Dane have been FIG. e/e). thelk UCAREF00009581 A Comparative Study of Pulmonary Tumors 339 na In a s* from Xi3. major Hilary ; from mesiic eenln aptlve -nal.a mata. n Che g. 9>. ianed r lcar> copii other I right dogs I ween limb :ated been FlQ. 9. Pulmonary adenomata arising from *ubpithiial glands tn a snow liopard (Pintlten un* c/e). Left shows normal subeplthelial glands H4. x213. Right demonstrates dysplestlc subeoJthellil glands (SD2-4799). H4. x213. reported in captive wild canines. The other tumors of wild dogs found in this study in cluded a metastatic nasopharyngealcarcinoma (epithelioma) ina goldenjackal (Cams aureus SDZ-10129); this tumor was morphologically similar to that seen in the human and in a Cape hunting dog (lyeaon pictus SDZ-11204) with a metastatic hemangiosarcoma. The latter probably arose from the aorta and was associated with primary carcinomas of the mamma, pancreas, and thyroid. Although aortic sarcomas in dogs are thought to be associated with Spineerm lupl, no parasites were identified in this case.71 Artlodactyia. Althoughvery few primary pulmonary tumors have been found in this order ofmammals,0*'* previous studies have been based largely on the examination of slaughtered animals killed before 8 years ofage. Since most lung tumors in cattle have been found in animals older than 6 years of age, more tumors would obviously have been seen iftheta animals had been allowed to live out their natural life span, which is usually between If and20years.'*<n Few eases of primary squnmous-ceil carcinoma of the lung have been found in cattle.1*** The more common type of bovine lung tumor is a multifocal, scirrhous, peripheral adenocarcinoma with an alveolar infundibular pattern distinct from that UCAREF00009582 340 6. B. Ilgren at el. found in human pulmonary tumors."-" This tumor metastasizes more often than do histologically similar lesions of the dog.73 Most metasuses, however, are confined to the regional lymph nodes, and extranodal spread Is rare." As in other mammals, secondary I ung tumors in cattle are far more common thanprimary neoplasms; These usually arise either from carcinomas of the eye and the uterus, or from lymphosar- coma*.'w' Excluding Jaagsiekte, primary lung tumors are rare in domestic sheep**'11 and in captive wild aniodactyls. In the present study, an impaia (Aepyceros metampus SDZ-7823) was found with multiple scirrhous adenomata histologically similar to those found in domestic cattle (Fig. 10). A pulmonary adenocarcinoma was also seen In a springbok (Antidorcas manupialls SD2-10086). This animal's tumor (SDZ- 10086) was not scirrhous, but was similar to the type of severe secondary bronchiolo alveolar hyperplasia often associated with chronic pulmonary inflammation and con solidation. The lesion was, however, histologically distinct from the cellular variety of Jaagsiekte**-*4 and did not metastasize. This springbok (SDZ-10086) also exhibited marked joint swelling similar to that seea ia birds,11 dogs,*`J,J* monkeys," and humans with pulmonary hypertrophic osteoarthropathy. . A malignant spindle-cell and epithelioid mesothelioma was found in an eland (Taurotragus oryx SDZ-10125). Only two other mesotheliomas in captive wild mam mals have been reported, one in a Cape hunting dog (Ph Z-9604) and the other in a clouded leopard (Ph Z-2516). However, the tumors in both of these cases were y : *' ; -T. tyoe with proo first. cino close mesc MV mesc wild FIG. 10. Scirrhous branchiolo-aiveolar ad* 'Z noma in the lung a11 Kenyan imeafa (Atpy" etrosme/ampua) (SD2-7S23). H4S.x213. FtCL 1 tumor e in a X* (SDZ-E UCAREF00009583 A Comparative Study of Pulmonary Tumors 341 localized, fibrous, and partially composed ofosteoid, in contrast to the highly invasive neoplasm seen in this series (SDZ-10125). Such localized lesions may be similar either to the rare benign, fibrous mesotheliomas of humans or to certain reactive mesotheiiai proliferations often found adjacent to foci of parenchymal inflammation.'* Asbestos particles were not seen in any of the cases (Ph Z or SDZ) described above.1* Tumors of the lung are very rare in domestic goats.' A wild goat (Capra aegagrus SDZ-6474) was found with multiple, peripheral, papillary bronchiolo-alveolar and bronchial hyperplastic nodules. Although some of these nodular lesions were associated with lung worms, this type of reactive bronchial epithelial change is usually not due to such parasites. The most common variety of bovine lung worm, Die- tyocaulus vivtparus, usually elicits an alveolar granulomatous inflammatory reaction with epithelialization of the alveolar lining cells." Less commonly, these parasites may produce a secondary bronchiolitis that leads to consolidation and emphysema. Twocaptive wild aniodactyls in this study had interesting secondary tumors. The first, an impala (Aepyceros melampus SDZ-8313), died from a metastatic adenocar cinoma that appeared to arise from the uterine cervix. Histologically, this tumor very closely resembled the rare human cervical adenocarcinoma of Wolffian or mesonephric duct origin--the well differentiated, tubular mesdnephroma (Fig. 11 )."** Although endometrial carcinomas are well recognized in cattle,1 mesonephroid tumors have not been described before in either domestic or captive wild species. The other secondary tumor In this series--a metastatic squamous-cell Mg FIGL 1L Pulmonary metastasis from eervical tumorof prasumptivomeaoneghrlcduc: origin in a Kenyan impale (Aapyctns mertmpva) (SDZ-8313). H4g. x213. . UCAREF00009584 342 E.B.IIgrenataL carcinoma in a Wyoming pronghorn {Antlhcapra americana SDZ-8957, AFIP 1502033)--arose from the skin of the lower eyelid, not unlike the so-called "cancer eye*' of Hereford cattle.'' Pinnipedia. Little information exists concerning neoplasia in this order of mam mals. No tumors were found in either the Philadelphia or London reports, although one rumor and one hamartoma were seen in this study. The firs: of these involved a California sea lion (Zalophus caltfomianus SDZ-10092: AFIP 1543048) which died from a metastatic renal carcinoma. The tumor was a clear-cell variant microscopically similar to its human counterpart, which showed extensive venous invasion (Fig. 12). In the other case a Baikal seal (Pusasibirica SDZ-39I6) died with an associated ectopic pulmonary thyroid (Fig. 131. Although intraperieardlal thyroid rests are well recog nized in dogs.* deposits of ectopic thyroid near the lung are most unusual In any species including humans. Proboscidea. Previously, only two pulmonary tumors, both of questionable malignancy, have beendescribed in this order of mammals.*** Thecase from the pres ent study (SDZ-8085: AFIP 1472532) was that of an Asian elephant (Elephasmaximus) that died with multiple pulmonary lymphoid nodules and no evidence of systemic disease. The lesions were composed mainly of mature lymphocytes and histiocytes arranged as germinal centers (Fig. 14 Left). There was little evidence of parenchymal invasion. This tumor, as wellas the other two described elsewhere (v.$.), contained herpetic intranuclear inclusions within the bronchial epithelium (Fig. 14 Right). It is unlikely that this was a primary herpedc pneumonitis, for, at least in xr y> .... -v; fig. u adhere sealift. FIG. 12. Pulmonary metastasee from renal^*.1i'vVy* call carcinoma within the vessels and air maces at the lung of a sea lion (Zttopnus eaUtonUanua) with a detail at the metastatic ,, e tumor showing "elearcell'' fsaturaa (S0Z100921. H46.X 213. FIG. l>maxiim Herpeti UCAREF00009585 UCAREF00009586 344 E.B.tlgrenetaL humans, them would have been 4 more hemorrhagic, parenchymal necrosis. Human pulmonary pseudolymphomas, such as those described by Castleman, bear some resemblance to these lesions,"-* but are generally more diffuse. The differential diagnosis of pulmonary pseudolymphoma, lymphosarcoma, or severe, chronic, interstitial pneumonitis may be quite difficult, (t can often only be made in retrospect, and ihe true diagnosis may remain uncertain uniess resolution, recurrence after removal, or dissemination of disease occurs. Similar herpetic lymphoproliferativ* dysplasias and neoplasias are well recognized in birds, mammals, and humans,* although these disorders are rarely confined to one organ such as the lung. 3 1 I * ~ pol. urb con v var the. alri bat tot ma Primates. Ratdiffe states that primates had the lowest tumor incidence of all mam mals at the Philadelphia Zoo and, in over 32 years, he did not find one pulmonary neoplasm in this order of mammals.17 No cases were found in the London series, although several lung tumors are described in other isolated studies.10*1* The one case found in theSDZ series was that of a 22-year-old Guenon monkey (Cercopitheais dlana SDZ-3473) which died with multiple peripheral pulmonary adenomata. There was neither parenchymal invasion nor metastases. The lesions histologically resem bled the atypical epithelial proliferations of the human lung described by Lfebow.* DISCUSSION AND CONCLUSIONS The present report supports the rarity of pulmonary tumors in animals. There is, moreover, a total absence in this study of any tumor histologically similar to the smoking-related h uman lung cancers, namely, the primarypulmonarysquamaus<eii, anaplastic, and oat-ceil carcinomas. The anjmal lung tumors described herein may be histologically, and even biologically, similar to their human counterparts--the bronchiolo-alveolar carcinomas, adenomas, adenomatoses, bronchial glandular tumors, and carcinoids. In general, the most common types of animal lung tumors are adenomas and, less frequently, adenocarcinomas. These tumors are usually multi focal, peripheral, infiltrative,* and oftwomajor types. Thefirst, a papillaryvariety,is the most common, and is especially frequent in domestic animals. It may be scirrhous and contain fod of osteochondral metaplasia. The other is a bronchiolo-alveolar variant and may also be slightly papillary. Only 4 percent of tumors ofthe second type metastasize.01 Although these less common alveolar tumors have been extensively studied In both humans and laboratory animals, confusion still exists as to their possi ble infectious nature, as well as to their precise ceil oforigin.,7,w*", In veterinary praclice, animats are either killed prematurely or cannot be observed continuously. The frequent diagnostic clinical information so helpful in human medicine is therefore often not available to the comparative pathologist. For this reason, it is frequently im possible to precisely diagnose a great a umber of animal tumors, since many of these neoplasias cannot be properly evaluated by histologic criteria alone. Furthermore, studies based on abattoir material may miss primary tumors, e.g., adenocarcinomas Of the uterus"4 or squamous-cell carcinomas of the eyelid, which not infrequently metastasize to the lung. The rarity of certain types of pulmonary tumors in animals may be related, in pan, to various genetic factors. Such cone! usions aresupported by the work of Heston and others.**-"*117 Many mammals, birds, and reptiles are exposed to atmospheric Th un sitr chi ass ass of tiv co gn ca tu: co ca qu fo re-. hi ar ra Pi ar H ei a h. S 4 ts V l t\ Mr UCAREF00009587 Human ar some erencial nic, inrospect, -e after ferative mans,1* II ream* nonary series, >necasc Meats .There resemow. lere Is, to the Js-ceJ), ' iy be .--the ndular trsare multiiety.is rhous /solar dtype sively possiprac.The efore yimthese nore, I omas 1 ently [ d, in I :ston herlc A Comparative Study of Pulmonary Tumors 345 pollutants but have neither an increased Incidence of long cancer nor any obvious urban-rural variation in the frequency of pulmonary neoplasia.1"*111 Atmospheric conditions and pollutants may considerably influence an individual's susceptibility to various pulmonary disorders, such as chronic bronchitis and pneumonia,11*-111 and these factors may, in turn, facilitate the development of lung tumors in humans already exposed to the potential carcinogens in cigarette smoke. The absence ofan ur ban-rural venation in the incidence of lung tumors in animals1Uf-,3U11 may be related to the fact that animals are not directly exposed to cigarette smoke, or at least not in a manner similar to humans. Different factors predispose an individual to developing various types of tumors. These indude chronic inflammation, infection, and irritation. The circumstances under which a number of the tumors in this study developed strongly suggest that similar factors can also initiate the tumorous state in animals as well as humans, e.g., chronic ulcers in a stilt's wing (SDZ-8953) or on a pronghorn's eyelid (SDZ-8957) associated with squamous-cell carcinomas; herpetie intranuclear epithelial inclusions: associated with a pseudolymphoma in an elephant (SDZ-8083); and the fibrosarcoma of the femur in a maned wolf (SDZ-10282). The biologic behavior and, occasionally, the histopathologic patterns of (he cap tive wild animals' tumors in this study were often similar to their domestic and human counterparts. For example, many of the animal tumors were found in older age groups, as they are in humans. Multiple primary tumors, not uncommon in domestic canine species, were seen in a captive wild dog (SDZ-U204). Secondary pulmonary tumors were more frequent than primary neopiastns, a finding consistent with most comparative tumor studies. Scirrhous iung tumors, common in cattle, were found in a captive wild arttodactyl (SDZ-7823). and subepitheliai glandular tumors, not infre quently seen in domestic cats, were noted in1 a clouded leopard (SDZ-4795). There are only several known animal models for the study of the predominant forms of human lung cancer.1" Moreover, spontaneous squamous-cell carcinomas regularly occur in the wild European hamster, but their frequency compared to that in humans is quite low.1-'" In addition, only one oat-cell carcinoma has been reported in any animal,1 and other less common tumors, such as the pulmonary carcinoid, are rarely found in any species but humans.1-*4 Vertebrates other than humans are generally thought to have a low incidence of pulmonary neoplasia. Althougn in most cases this is probably true, many of the animals described in this study may have died in the middte of their potential life span. Human pulmonary carcinomas, however, commonly have a peak incidence near the end oftiie natural life span. Thus, the true incidence of animal lung tumors may actu ally be higher than is currently appreciated. Still, over 2,000 neoplasms from more than 13,000 autopsies were reviewed in the present study, and among all of these there was not one primary puimonary tumorof the type commonly associated with smoking in humans. ACKNOWLEDGMENTS We wish to thank Emeritus Professor R. A, Willis (Liverpool). Dr. Streuon Young (Imperial Cancer Research Fund, London), Professor Ernest Cotchin and Dr. O. Ap pleby (Royal Veterinary College, London), Dr. A. J. Copp (Department of Zoology, UCAREF00009588 346 E.S.Itgranetal University of Oxford), and Professor A. C. Braun (Rockefeller institute. New York) For their many helpful comments and criticisms of the manuscript. We are also grateful to Mr. R. Leach of the Imperial Cancer Research Fund for excellent photographic assistance, and to Mrs. J. Brown for typing the manuscript. This wqrk was performed while the senior author (E.B.I.) was on an International Cancer Research Technology Programme (ICRETT) administered by the International Union Against Cancer (U1CC), Geneva, and completed while an American Cancer Society (ACS) special postdoctoral feiiow (SPF-14). We are most indebted to both of these organizations (UICC and ACS) for their generous support. 1 '19. REFERENCES 1. Gresham GA, Jennings AR: Neoplasms ofthe respiratory tract. Ch. 12. In Introduction to Comparative Pathology; A Consideration of Some Reactions of Human and Animal Tissue* to Injurious Agents. New York, Academic, 1962, pp 249-27) 2. Stewart HL: Comparison of histologic lung cancer types in captive wild mammals and birds and laboratory and domestic animats. In Sever! L (ed): Lung Tumours in Animals, Proceedings of the Third Quadrennial Conference on Cancer. 1946, pp 23-38 3. Stewart HL; Comparative aspects of certain cancers, in Becks' F (ed); Cancer A Com prehensive Treatise, VoL , Biology of Tumours: Surfaces, immunology, and Com parative Pathology. New York, Plenum Press. 1973, pp 303-374 4. Cotchin B: Neoplasms of the domesticated mammals; A review. Commonwealth Agricultural Bureau, Review Seriee, No, 4,1936 5. Walls RA: Epithelial tumours of the trachea, bronchi, and lung, Ch. 19, and Tumours in animals. Ch. 6. In Pathology of Tumours. London. Butterworths. 1967. pp 92-104 6. Krayberg L: Aetiology of Cancer. A Morphological, Epidemiological, and Experimental Analysis. Oslo, Universiteuforiaget, 1969 7. Kreyberg L: Comments on the histological typingoflung tumours. Acta Pathol Microbiol Scand (A]79:409. 1971 ` 8. Spencer H: Pathology of the Lung, vol II. 3rd ed. Oxford, Pergaraon. 1977, pp 772-839 9. Liebow AA: Tumors of the respiratory tram. In Armed Forces Institute of Pathology. Sec tion 3, Fascicle 17. Washington, D.C.. 1932. pp 12-14 (atypical proliferations), pp 42-45 (carcinoids), and p 63 (bronchogenic carcinoma) 10. Elkan 8, Cooper JE: Tumours and pseudotumours in tome reptiles. J Comp Pathol 86:327. 1976 11. Harshbarger JC: Activities Report, Registry of Tumors in Lower Animals (1963-73). Washington, DC, Smithsonian Institution, (973, p 64 (pulmonary adenocarcinoma-, frog.) . ' 12. Harshbarger JC:-Activities Report. Registry of Tumors in Lower Animals. Washington, DC. Smithsonian Institution, 1977, p 8 (mesothelioma-jewflsh) 13. Effron M, Griner L, Benirschke fc Nature and rate of neoplasia found In captive wild mammals, birds and reptiles at necrospsy. J Natl Cancer Inst 39:183, 1977 14. Jones OB: Kidneys. In Anderson WAD. Klssaite JM (eds): Pathology. St. Louis. CV Mosby, 1977, pp 928-973 15. Campbell JG: Epithelial tumours of the respiratory system. In Tumours of the Fowl. Lon don, Wm Heinemann Med Bks Ltd. 1969, pp 121-133 16. Campbell JO. Appleby EC: Tumours la young chickens bred for rapid growth (broiler chickens); A study of 331 cases. J Pathol Bacteriol 92(1 ):77,1966 17. RatcBffe HL: Incidence and nature of tumors in captive wild animals and birds(A review of 32 years* findings at the Philadelphia Zoo). Am J Cancer 17:116,1933 18. Peacock PR: Anatomy, histology, and electron microscopy of the lungs of animals used UCAREF00009589