Document r62QmmJzDo6d0B0ZpM5oOGEoe

FILE NAME: Garlock (GAR) DATE: 1986 Dec 4 DOC#: GAR001 DOCUMENT DESCRIPTION: Legal - Deposition of George Ellwood Houghton with Handwritten Notes 'fl\. Y /)<^Ll^^ la /3. 1Y Y 0 -t~- C4sC3-is %>i^-&*s3 A* 4t f f / 'A /?- <Yl /T V / / -/Ai / f \ / 4 i te 33 V, W x y / ? - 3 f ' M * 3S* ^ e t A J c ^ A U / * &> 3> & ^tsts&-eJi C sT^/^c-c^y/AcA/ci,---O. 3 ff/p a -Y % L - y i s ' A & ' / * /-* yo 'y&H yy ^ h/-^y , ^ y j 4to*0i*& i c f /? Y 0 'p c y n r Y ^ ^ ""'* & yP lA s(< / co < /A ^ yy^ p / y ^ ^ 7 3'7 ? C ^* y< /4 fp ^ i s^Y/A/ ,yy~3&-i'7'ss''sl (Yi A (Y /u Y ^Y cx-P Y ul 'y*? / ^ y ^ </ ^yykr^^-2_ ^?y y S / 3 AY-Y j J /Y j . Y /Y Y -Y Y L ^t Y y y c yj C * - % / y /^ U L p y /y y ^ fy T 7- ^ 3 i^ /y ? / p y^H '//u > c /A /7/ y ^ Y ^ y <f2$^--^r' &a, c^^v.- /? r t~ ''tY -'^. y y /- - - ^ y //I 'i-Y y y --7 c k 9 A / / 9 k 7 '/- / Y .// 7 y / y /~ '//H tsZys?- , /7 '> 3 ' - / /~Ai? $ k p s - ^ ' p / jy a * //Y Y ' ^''7h .<- <KA / y s,/yc& ^ff^-x. s / y ^ u s /3> / p ? A tj y/a 3 u /p < .-/ff / y ^ ff-p /fts c /Y c 110 1 WITNESS CERTIFICATION 2 3 I, GEORGE ELWOOD HOUGHTON, do hereby certify that I have 4 read the transcript of my testimony taken under oath on the 5 4th day of December, 1986; 6 that my testimony in the transcript herewith, pages 1 7 through 109 is a true, complete and correct record of what 8 was asked, answered and said during the deposition; 9 and that the answers on the record as given by me are 10 true and correct, except for anything duly noted on the 11 attached errata sheet. 12 13 14 15 GEORGE ELWOOD HOUGHTON 16 17 Subscribed and sworn to before me 18 this ___ day of ____________. 1986. 19 20 21 22 My Commission Expires: NOTARY PUBLIC 23 ' March ___, 19____ . ! i v u own h^eporliny S<r,, H(J0 j CIRCUIT COURT OP THE CITY OP CHESAPEAKE, VIRGINIA WILLIAM STACEY OVERBY, versus GARLOCK INC. Plaintiff, Docket No. 20555-M Defendant. ElJLVJJOOD Deposition of GEORGE ELW66&- HOUGHTON, held at 516 West Main Street, Palmyra, New York on December 4, 1986, commen cing at 10:00 a.m. APPEARANCES: GLASSER and CLASSER, ESQS. Suite 400 125 St. Paul Boulevard Norfolk, Virginia 23510 Appearing on behalf of the Plaintiff By: RICHARD S. GLASSER, ESQ., of Counsel DUANE and SHANNON, ESQS. The Joynes House 209 West Franklin Street Richmond, Virginia 23220 Appearing on behalf of the Defendant By: JAMES C. SHANNON, ESQ., of Counsel ALSO PRESENT: BERNARD L. LEVINTHAL, ESQ. HELEN ZORNOW REPORTED BY: CAROL P. RAES Midtown Reporting Service 1100 Times Square Building Rochester, New York 14614 (716) 325-2130 aMidtourn cRepoztincj Service 5Of ima cSquare `Huildiny cRockesUx, cN cuj ^yoxle !46I4 2 INDEX TO WITNESSES GEORGE ELWOOD HOUGHTON Examination by Mr. Glasser Examination by Mr. Shannon 3 - 106 106 - 107 INDEX TO E X H I B I T S EXHIBIT NO. DESCRIPTION MARKED 1 Four-page document; first page reading "Mr. Bristol" and "Important" 49 2 Asbestos Textile Institute minutes of June 19, 1946 meeting 69 3 March 13, 1946 Dust Control Meeting minutes 64 4 June 13, 1946 Dust Control Committee minutes 67 5 85 pages of documents; first document being "Report Preliminary Dust Investi gation For Asbestos Textile Institute, June 1947" 75 6 Minutes of March 8, 1956 meeting of Asbestos Textile Institute 81 7 Minutes of March 7, 1956 meeting of Asbestos Textile Institute 81 ItOO Dim*i ^oeLstidf, Yjtw 1/jori f46/4 MR. SHANNON: There is one stipulation. I'll read it from a letter of September 5 to me from Robert Hatton. Paragraph 4 of that letter \?\W>ccA states, "The deposition of George Elwood Houghton will proceed at a time and place L. convenient to Garlock and the witness, within three weeks of this date and, of course, we have by agreement abrogated that particular date requirement. And upon completion of such deposition, it shall be placed under seal and not be used under evidence except in cases in which the law firms of Glasser and Glasser or Patten, Wornom and Watkins are counsel of record. This deposition will be noticed in a case in which Garlock is the only defendant and no defense counsel shall attend the deposition other than Garlock's counsel. However, in the event that such deposition reveals information which would be relevant and material to the liability of other defendants in asbestos products liability litigation, then in that event, Garlock agrees that the deposition may be ..^ v* . / " ' . . r 'J~' cM idtown cRepozting cSczaicc 501 Uimet eStjuate CBuifJiny cRocftttttx, cNcui ^TJoxt 14614 4 1 renoticed to permit defense counsel an 2 opportunity to participate in the deposition 3 and have it in a form that would be 4 admissible in litigation in which other 5 defendants were involved." 6 As a follow up to that letter of 7 September 5, I responded to Bobby Hatton on 8 September 18, and the following portion of my 9 letter of September 18 is also pertinant to 10 the taking of this deposition. "Also, I 11 understand that your agreement not to use 12 this deposition other than in a case in which 13 you are counsel of record refers to your 14 involvement .as counsel who originated a 15 particular plaintiff's case. We do not 16 understand," we, being Garlock, "that we have 17 agreed that you are eligible to be associated 18 in other plaintiffs' lawyers' cases around 19 the country and use your status as counsel of 20 record to offer this deposition against 21 Garlock therein." So under those terms and 22 conditions w e 're here today to proceed with 23 Mr. Houghton's deposition. Midtourn Reporting cSczaice 50/ 0 im<t uate {J3uifdiny cRockestcx, cNeui T/otj? /4614 5 1 MR. GLASSER: 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 If I may make a preliminary comment, as Jim Shannon is well aware, I am associated with Bobby Hatton, and I am aware of both Bobby's letter of September 5, 1986 and Jim Shannon's response of September 18, 1986, both of which you have accurately reported to the record. I do want to make sure that my feelings are known that the letter of September 5, 1986 confirmed a settlement that was made in ten cases in which Garlock was a defendant. These ten cases were either handled by my office or by Bobby Hatton's office or by our offices jointly, and they were pending either in the state of Virginia or in the state of Texas. The provision concerning M r. Houghton's deposition and that it be placed under seal and other provisions calling for basically a temporary moritorium in discovery were requested by Garlock, were a part and parcel of the settlement procedure, and as Jim has consented to so that we could in fact resolve the differences for the ten plaintiffs that we were <zMidtoum czRcpoztiny cSezuice SOt *Jimca cScjuaT <zRoc&aUx$ cN tw I46t4 6 1 representing. They were consented to by the 2 plaintiffs; myself, included. I make this 3 statement because I'm not in favor of sealed 4 depositions. It was not my desire that it be 5 placed under seal, but it was, as Jim 6 reported, a part of the discussions that 7 ended with the resolution of ten cases. With 8 that comment, I 'm prepared to proceed and I L* 9 would ask you please to swear the witness. 10 MR. SHANNON; 11 12 MR. 6LASSER: We're reserving all objections except as to the form of the question. That's correct. 13 tU-VMOOb 14 G E O R G E E-fr-W-0-0 D H O U G H T O N , called herein 15 as a witness, having first been duly sworn, was examined 16 and testified as follows: 17 18 EXAMINATION BY MR, GLASSER: 19 Q Before I ask you any formal questions, I just wanted to 20 let you hear my voice a little bit as I will be talking 21 to you once the formal questioning starts to make sure 22 that you can hear me and understand me. Do you 23 understand? czMidtourn czRepoztiny cSezuice 501 <3im a eStjuare `Building cficxftetUx, eN tw njoxi 146/4 t 7 1A 2Q Yes. I noticethat you'rewearing two -- 3A 4Q I have it in both ears, yes. -- two hearing aides, and you have told me before the 5 deposition started you might need questions repeated, 6 so if at any time you don't understand my question or 7 I'm not clear, please don't hesitate to ask me to 8 repeat or to rephrase. 9A I won't. 10 Q 11 And if at any time you wanttotake a break or a rest for whatever reason, if you will tell us we will 12 promptly do so. 13 A Yes. 14 Q And we have here with us today at everyone's request 15 Helen Zornow who is a nurse and she'll also be looking 16 out for you. 17 THE WITNESS: You can see my eyes, all right? 18 MRS. ZORNOW: Yes. 19 Q You're comfortable and you're ready to begin? 20 A I'm relaxed. 21 Q Thank you, sir. Just so the record will be clear, Mr. 22 Houghton, would you state your full name? 23 A My full is name is George Elwood, E-l-w-o-o-d, czMiJtoujn dRepoztincj Service 50! Uimt! cSquau `Building cRoc&cstei, <zN c\jj ryo xi 14614 8 1 Houghton, H-o-u-g-h-t-o-n. I go by my second name, 2 Elwood. 3Q And today is December 4th, 1986? 4A Correct. 5Q And we are at your home at 516 West Main Street in 6 Palmyra, New York. 7A Yes, 14522. 8Q Mr. Houghton, have you given anypast sworn testimony 9 in any asbestos-related matter? 10 A 11 Q 12 A 13 Q Yes, we have had the investigations. And what type of investigations were they? I'd say similar to what you're going to carry out. And can you tell me about how many times you have had 14 testimony like this that you have given? 15 A I'd say similar. I've beenaskedquestions. 16 Q Have they been with the presence of a court reporter? 17 A I don't recall any of that being done. 18 Q Were they involving only attorneys from Garlock or did 19 they also involve attorneys like myself who -- 20 A It would be both. 21 MR. GLASSER: Off the record. 22 (Whereupon a dicsussion was held off the record.) 23 Q Have you ever been called upon to give any statements eMidtourn ^Reporting cSezuice 50 / 'Jimct cStjuaxe `BuiUiny H- cRockattx, cMcw H/oxi 14614 9 1 2 3A 4 5Q 6 7 8A 9 10 Q 11 12 A 13 14 Q 15 16 A 17 18 19 20 Q 21 22 A 23 . to any legislative body or to any trade association concerning asbestos? I was the representative from Garlock to Asbestos Textile Institute. I will discuss that with you later on in our discussion. Have you ever written anything concerning asbestos? My major writings have been regarding the asbestos spinning operation. And do you have copies of what you wrote concerning the asbestos spinning operation? I might possibly have some, but they would be buried in file papers. I'd have to search. I don't know. Can you tell me during what time frame you did writings concerning asbestos spinning? Well, that was while I was active with Asbestos Textile Institute. I think it was probably about 1962 to 1970. Any report I might have made would have been probably about 1968, in that neighborhood. I'm going to drop back, Mr. Houghton, and ask you if you will review for me your educational background. I graduated from Westown's School in Pennsylvania in 1924. That was a college preparatory school. I cMidtoum czRepoztiny cSezuice 5 0 1 <Jimes <Stfuaze cRocficsttt, ry xi 14614 10 1 2 3 4 5 6 7Q 8A 9Q 10 11 A 12 Q 13 14 A 15 Q 16 17 A 18 19 Q 20 21 A 22 23 attended Philadelphia Textile -- Philadelphia Textile-- no, it was called -- Yes, Philadelphia Textile School was the name of it. It was located at Broad and Pine in Philadelphia at that time. It has been changed from Philadelphia Textile to Philadelphia College of Textiles and Science now. How long did you attend there? That was a three-year course. Did you learn anything during that schooling period, about the use of asbestos as a textile? No. Did yougraduate from thePhiladelphia Textile School approximately 1927? 1927. And following your graduation, what was the first type of employment that you had? I moved from school right to Johns-Manvilie Corporation in Manville, New Jersey. What was the nature of your employment at Johns-Manvilie or field? I was in theasbestos textilemanufacturing which involved fiber preparation, spinning and twisting and weaving asbestos cloths and yarns. cMidtoujn Reporting cSezaice 50! cSquar* cRocftesUi, <zNcw H/oxi !46l4 11 1Q 2A 3 4 5 6 7 8 9 10 11 Q 12 13 14 A 15 Q 16 17 18 A 19 20 21 Q 22 23 That was your specific responsibility? Yes, I was there for 12 years, and so I moved from learning the trade and then up to you might say an engineer of various operations. I had exposure to all of the operations from the fiber preparation where fibers were sold as such and spinning into asbestos yarn, carding and twisting, weaving. I became acquainted with braiding, which was in the neighboring department, so I had a pretty broad education; also in safety clothing manufacturing. Primarily, if I understand you correctly, your experience at Johns-Manville was with the manufacturing of asbestos cloth and asbestos yarns? That's right. How much occasion did you have to see and be around the machines where the fibers were prepared, spun and twisted in the manufacturing process? I'd say complete knowledge of the mechanical processes. I was sent to set up textile and instruct people on the handling of the equipment. And did your job responsibility relate to the equipment itself and how it should be set up from an engineering standpoint? cM idtawn czRepozting cSczaice 50/ 'Oimti (Square cBuitJioq cRocfeitct, cNeuj 146/4 12 1A 2Q Yes. Did you also have a role concerning how the dust would 3 be ventilated or controlled? I'm speaking of asbestos 4 dust that was generated during the various processes of 5 the manufacturing that you've described. 6A Yes. 7Q 8 9A 10 11 12 Q 13 A What was available inthe 1927-1939 time frame to enable you to help control asbestos dust? More or less your own ingenuity. I don't think we had much in actual magnifications or dust-studying equipment. Did they have exhaust fans and ventilation? Yes. 14 Q Did they have hoods that could fit over dusty areas to 15 gather and remove the dust? 16 A That was particularly true in fiber preparation and 17 carding. Some hooding was applied to looms. 18 Q Did they alsounderstand that youcould separate or 19 isolate a dusty process so that the dust that was being 20 created would not go all over the work environment? 21 MR. SHANNON: I object to the leading of that 22 question. 23 A The hooding was designedfor that, yes. cMldtoujn czReporting cSeruicc SOt ZJimct cStfuate ^BuliJioy c/?oc/>etter, czNcxo ^ o z t 14614 13 1Q 2 You were aware that in the 1927 to 1939 time frame there were also respirators that were available? 3 MR. SHANNON: I object to the leading. 4A 5 6 7Q 8 We used respirators for the men that worked in the dustier areas like fiber preparation and carding, handling of stock, and so forth. How were respirators used by the men who handled the stock and were in the various manufacturing processes? 9 MR. SHANNON: I object to that. It mischaracterizes 10 11 A 12 13 his former testimony. It would be used because it was recognized as a dusty area. There were limits set by the federal government at that time where dust should be not 14 exceeding 5 microns per cubic foot, in the type of 15 studies that were done at that time. We had samples 16 sent away, we had some outside insurance companies come 17 in and make analyses, and our efforts were to try and 18 19 Q 20 live under the federal requirements. You mentioned 5 microns per cubic foot. Could that have been 5 million particles per cubic foot? 21 A A micron, I think, is a ten thousandth of a 22 millimeter. I think. I'm not positive on that, but a 23 micron was a microscopic measurement. Midtoion Reporting cSetoice 501 Oimei cStjuate HuitJlAin.fgt!A. 14 1Q I understand what a micron is. My question, Mr. 2 Houghton, is that the standard that you described? 3 Think back and say would you agree that that standard 4 5A was 5 million particltes of total dust in a cubic foot? No, it would be 5 microns in an examination microscopic 6 examination area. I think the sampling was taken 7 against a glass plate, and that area was magnified, and 8 the particles are counted in a certain area on that 9 magnified sample. 10 Q Let me try to clarify. There was a standard that you 11 tried to stay within, and in determining size, there 12 were microscopes available in order to allow the dust 13 that had been gathered in testing to be counted. 14 MR. SHANNON: I object as the leading. He hasn't 15 testified to that. 16 A This measurement device I 'm mentioning was not 17 available to me until I was at Garlock. 18 Q I understand, but at Johns-Manville, they were able to 19 take dust counts. 20 A The insurance company did that. 21 Q And when they took dust counts, they will then count 22 it under a microscope, is that correct? 23 A That's the way I understand they did it. <-zMidtoujn Reporting Service SO! 0 met cSguate 'Building cRochatex. tzNcvj '~Uozl 146/4 15 1Q 2 3A 4Q 5 6A 7 8Q 9 10 11 A 12 13 Q 14 A 15 Q 16 17 18 A 19 Q 20 21 22 A 23 And they had a standard that they tried to stay within when they were dealing with asbestos dust? Yes. Why was there a standard for asbestos dust in the 1927 to 1939 time frame? That was in the hands of the insurance company and it was not discussed with us. Do you know whether the insurance company that handled and studied Johns-Manville was the Metropolitan Life Insurance Company? I can't answer that accurately. It may have been, but it was not my knowledge. Did you ever have occasion to meet Dr. Anthony Lanza? I don't remember that name. You do recall, however, that the insurance companies came into Manville and made studies and dust counts concerning the asbestos textile operation? I think my answer would be I know they have come in. Do you know, Mr. Houghton, whether the results of those studies were ever published and made available in the literature? Not that I could -- not that I was exposed to, no. Polks up the ladder may have heard it, but I was down cMidtoujn Reporting cSezuice 501 ^Dimcs cStjuaxe czRoccst<x, <zNc\u ^IJoxle 146/4 17 1 approach as closely as possible to the movements that 2 were taking place to be effective. 3Q And you wanted to remove the asbestos dust from the 4 work environment to avoid any hazards associated with 5 breathing too much asbestos dust? 6 MR. SHANNON: I object to the leading questions, 7 Richard. He hasn't said anything about 8 asbestos dust. He's talked about dust. If 9 10 11 MR. GLASSER: you're going to ask why, ask him. Don't tell him. I want to make it very clear that I 12 have a right to lead this witness, and that I 13 don't think an objection as to leading is 14 appropriate, and I feel that ray questions are 15 proper as structured. I understand your 16 objection, and you may object as to form if 17 you feel it's appropriate, and obvioulsy, I 18 would want to have an chance to rephrase it, 19 but I do feel that leading is permissible 20 here. 21 MR. SHANNON: I understand that under the conditions 22 we're working under today. I feel you might 23 be advised to be very circumspect in your cMidtoujn aRepoztincj Sctaice SOI Oimcs cStjuate <3uitJiny cRocftatci, cNcui T/or* 146/4 18 1 leading questions considering Mr. Houghton's 2 age and considering his hearing difficulties. 3 MR. GLASSER: 4, I'm trying but I feel my questions are proper in terms that he is a long-term 5 Garlock employee. 6Q Don't you concern yourself with the lawyers talking. 7 We're talking to the judge who didn't want to come up 8 and brave the snow with us. 9 (Whereupon the reporter read back the pending 10 question.) 11 Q Do you remember my question that I asked before I 12 talked with Jim Shannon? 13 A I didn't have a machine like that, I know. 14 Q Let me repeat my question as best I can. We were 15 talking about the vacuum effect that was used on the 16 machines. The looms and the spinners were making 17 asbestos cloth, am I correct? 18 A The looms were making asbestos cloth. 19 Q And asbestos cloth was generally about 75 percent or 20 more asbestos fiber by weight, am I correct? 21 A Yes, that's correct. 22 Q And even higher running to 80 percent or 90 percent 23 asbestos percentage by weight. <cM idtown dRcpoztincj cSezaice cR5o0c1fitiOUitm, ticN<cSu<jjuaTr</oiHiulfd1i4n6y14 19 1A Sometimes 95 percent. 2Q And the concern about the vacuum effect was to remove 3 as much of the asbestos dust as could be done so as to' 4 reduce any hazard to the workers who would be breathing 5 the dust? 6A Yes. 7Q And that's because it was known that the breathing of 8 asbestos dust could be harmful to those who breathed 9 it? 10 MR. SHANNON: I object to that. I think it was 11 known that the breathing of any dust could be 12 harmful to those breathing it, as we know 13 that people who worked in cotton mills today 14 have brown lung and other diseases. I object 15 to your question as it implies special 16 knowledge that this man has about the hazard 17 of asbestos dust, and no such knowledge has 18 been established. 19 Q Mr. Houghton, wasn't it known by you in the 1930's that 20 it was important to limit the amount of asbestos dust 21 that a person breathed? 22 A 23 You're looking at history where people have been learning. We look back and we can see some things we cMidtoum czRepoztiny cSezaice 5 0 / Uimts cSquare <J3ui(Jiny cRocheitc*. cNcui T/orjf 14614 20 1 have been learning over the years; in other words, 2 we've made some sort of progress. We have not been 3 aware all that time of everything that we now know. 4Q I understand, but they knew in the 1930's when you were 5 at Johns-Manville that it was important to try to 6 control and limit the amount of asbestos dust that the 7 manufacturing process was generating? 8A Yes. 9Q And part of your job as an engineer working in the 10 asbestos textile manufacturing was to help with the 11 design to limit the dust. 12 MR. LEVINTHAL: I object to that. It mischaracterizes 13 his prior testimony as to what involvement he 14 had with it. 15 MR. GLASSER; Jim and I are nodding at each other. 16 If we can have one, it will make the sides 17 fair and conform to our court rules. 18 MR. SHANNON: That's right. I will have to make 19 the objections. I will make that my 20 objection and we'll proceed. 21 (Whereupon the reporter read back the pending 22 question.) 23 Q Is that correct? cMidtourn cRcpoztiny Service SO! `Dima cS<jua*< 'Building cRochcticr, cNeuj '"yoil 146/4 21 1A 2Q 3 4 5 6A 7 8 9Q 10 11 A 12 Q 13 A 14 Q 15 16 17 A 18 19 Q 20 21 22 A 23 That's one of the duties, yes. What progress can you describe to me that was made in limiting dust while you were at Johns-Manville? Did you play any role in helping to reduce the dust of the workers? I get confused with knowing that I did more actively work here, but at Johns-Manville, ray job was not designing particularly for dust control. And you say when you became more active "here," you mean once you became an employee at Oarlock? I was a superintendent here. And "here" is the Oarlock plant at Palmyra, Hew York? Yes. While you were at Manville, was there any discussion that you can recall concerning the hazard that could occur to a person who breathed too much asbestos? To my position there, I think I did not get in on those engineering discussions. Can you tell me how you learned that there was a standard that you should strive to stay within when dealing with the quality of asbestos dust? X can't g i v e y o u a g o o d a n s w e r w h e n I learned that it would be best to keep it at a certain level. I think cMidtoum aRepoztintj cSezuicc SOI Uinta cSquate HuifJiny <z/?oc/iatct. cNcw UJorC 14614 22 1 2 3Q 4A 5Q 6 7 8 9A 10 11 Q 12 13 14 A 15 16 17 Q 18 A 19 Q 20 A 21 22 Q 23 probably casual discussions would be the best I could say. While you were at Manville? Johns-Manville. While you were at Manville, did you have any occasion to attend any meetings or educational seminars concerning your engineering expertise relative to asbestos textile manufacturing? No seminars. Practical experience on the job was probably the major -- where I picked up information. Who were, in your opinion, the most knowledgeable people at Manville concerning the need to control dust while you were there? I think Mr. Cannon, Phil Cannon was probably the closest. I don't think you'd have much information from him now. He's deceased? Yes. Did you know CliffordSheckler? I think I know the name, but I don't think I associated with him any. Did they have a medical department at the Manville plant? czMidtoiun (zRcpozting Sezaice 23 1A Later they worked Into a need for a nurse, but when I 2 . was there, they had a doctor, but most of the medical 3 treatments were made in the office of the factory; 4 very limited medical service at the beginning. 5Q Were you aware as to whether there had been any 6 Workmen's Compensation suits filed against Manville in 7 the 1930's for asbestos disease? 8A I was not aware of suits at that time. 9Q You're aware now that they had suits in the 1930's? 10 A Yes. 11 Q Did you have occasion while you were working at 12 Manville to travel around to any other Manville plant 13 other than the textile manufacturing facility at 14 Manville, New Jersey? 15 A I only picked up equipment at the Waukegan factory 16 when -- This is 1933. I was asked to move equipment 17 from both Manville and Waukegan to the asbestos factory 1I 18 at Asbestos, Quebec. Factory at Asbestos, Quebec was a j 19 plant with a number of departments making similar { 20 products to those at Manville. 21 Q They also had some mining facilities that Manville 22 23 A owned in Asbestos? That was the major. V\\e\r" What was going on there was there icMidtoum tzRepoztinj cSezaice SOI c3imti <<]uaze `JBuihling cRocftatcz, cA/eui HJozi 14614 24 1 2 3 4 5 6 7Q 8 9 10 A 11 Q 12 13 14 A 15 Q 16 A 17 18 19 20 21 Q 22 23 mining, but they had set up a production plant there, too, for Canadian product and I was sent up there when they wanted to set up a textile plant, and so I went up there with equipment from Manville and Waukegan, but I saw very little of Waukegan's production, I was just taking some machinery away. Did you help in setting up the layout for the asbestos textile manufacturing facility that was being set up in Asbestos, Quebec? Yes. And you were aware at that time it was important how to lay it out and also to lay it out so that you could control the dust that would be generated? Yes. We -- the cards already had hooding on them. The carding machines? Yes, the carding machines had hooding, so I had them lay out a dust recovery department with fans exhausting the hoods of the cards and blowing into a recovery system so that you weren't blowing the dust over the countryside. And in that fashion, you were able to remove much of the asbestos dust from the work environment and then capture it so it would not, like you say, be blown' cMidtoum cReportinp Service. SOI Clime] cSquaic <33ui(diny I46U. 25 1 2A 3Q 4 5A 6 7 8 9 10 11 Q 12 13 A 14 15 Q 16 17 18 A 19 Q 20 21 A 22 Q 23 outside the plant to the neighborhood? Yes, it was filtered. How advanced was the thinking at Manville concerning the need to control asbestos dust in the 1930's? They had made good advances. The old system was fans on top of the building, not down where the dust are generated. The dust was in the room. Then when I got there, they had just installed 48 sets of cards with dust recovery systems blowing into a filter house on the roof. And the dust recovery system on the cards was close to the source where the dust was being generated? Yes, completely covering the hooding and the machine; also drawing out from underneath the card, too. Now, while you were at Manville, did you have occasion to see any of their asbestos product manufacturing facilities other than textiles, like the pipe covering? Yes. And they also hada pipe coveringfacility right at Manville? Yes. And were they also using engineering devices for dust control in the other operations, other than textile cM idtown cRiepoxtincj cSezoice 50/ <<juaze `BuifJing (zRocfiatci, cN cuj T/oti 14614 26 1 2A 3 4 5 6Q 7 8 9A 10 Q 11 A 12 13 Q 14 A 15 16 17 Q 18 19 A 20 21 22 Q 23 A manufacturing? There was some hooding where dry asbestos was handled to feed into mixers. There was hoods over that area. Mostly, though, the recovery systems were connected with the cards and the looms. Did you have occasion during your time at Manville ever to see the manufacturing processes at another manufacturer's plant? Yes. Can you tell me whose plants you had occasion to visit? Keasbey St Mattison. That was I think at north -- or it was in Pennsylvania, yes. Was that Ambler, Pennsylvania? Yes. And it became -- They were purchased by American Asbestos, so Keasbey St Mattison disappeared and American Asbestos took it over. Do you know whether Nicolet also purchased some of Keasbey & Mattison? I never went to any Nicolet plant in Pennsylvania. I went by the Nicolet mines in Canada, but I didn't visit it. You did not go into the Nicolet mines? No. (Midtou/n (Reporting Setoice 5 0 t `Jim et cStfuate CBulfdinj cRocfttiici, cNcio H /ott 14614 27 1Q 2 3A 4Q 5 6A 7 8Q 9 10 A 11 12 Q 13 14 15 A 16 17 18 19 Q 20 A 21 Q 22 23 A When you went to the Keasbey & Mattison textile plant, how up to date as compared to Manville -- The date? No, how up to date, how advanced were they as compared to Manville in their efforts to control asbestos dust? Keasbey & Mattison were not as advanced as Johns-Manville. What was the purpose of your going to Keasbey & Mattison? They wanted me to take a job there as supervisor. I didn't go. Did you have occasion to go to any other asbestos companies other than Keasbey & Mattison while you were at Manville? There's one other I visited, may have been a Raybestos division. I think it's a Raybestos factory but it was owned -- it was a different name. It was in about central Pennsylvania. It was an asbestos textile facility? Yes. How advanced, from what you could observe, was the Raybestos-Manhattan facility? I think they were somewhat similar to Johns-Manville. czMidtoum ^Reporting cSezaice SOt `Jim ei cSquare 'JSuifcliny cRocfttster, c/fcui HJoti 146)4 28 1Q 2 3A 4Q 5 6 7A 8 9Q 10 11 A 12 13 14 15 16 Q 17 18 19 A 20 Q 21 22 23 A By similar, you mean that they had made some of the same advances to control dust? Hooding and so forth, yes. Did you ever have contact while you were at Manville with anyone from Raybestos concerning asbestos or engineering dust control measures? No. It was more observation of the unit. That's all. Not dust control or problems. Why did you go to the Raybestos-Manhattan facility? Was that in the 1930's? It was in the 30*s. I'm hazy on that. I was sent there by Johns-Manville for some purpose. It may have been for picking up cylinders or equipment. They may have had something for sale, and so other than that, I can't give you an answer. Other than Keasbey & Mattison and Raybestos, do you recall seeing any other asbestos manufacturer's operation? I've seen several after being here, not at Manville. Still at Johns-Manville, another question, did you ever have a chance to see the gasket manufacturing operation at the Manville facility? Yes. aMidtoum czRepoztinp cSezuicc 50/ ima cSlyuate ^Buifdiny cRocfictlcx, /4 6 /4 29 1Q 2 3A 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Can you tell us what you observed concerning the gasket manufacturing operation at Manville? Cloth from asbestos textile was shipped to them. There were more than one operation. One was dipping, passing the cloth through a gasoline rubber -eharacry and then passing it up through a drying t-owel to remove the gasoline fumes, so fully impregnated asbestos cloth was made as one of the products that's particularly used in frictioning where two pieces of cloth are pressed together in making a gasket. Then the other method was c.oieiv^.e/ frictioning and skimming by colander , and a large percentage of the cloth was used that way making slabs. These slabs were used in cutting packing rings for gaskets. They wore a punch press type of operation. More cloth was used in either impregnating or in frictioning than used as dry cloth. Dry cloth was used in their clothing manufacturing for safety clothing. They had a plant at Johns-Manville for making gloves and coats and pants for firefighting, working in steel mills, where you were exposed to high temperatures, that they made them. (Whereupon a brief recess was taken.) cs^idtoum czRepoztinj Service SOI Uimet eStjuatt rBui(diny <zRocftestet, ur T/oti 14614 30 1 BY MR. GLASSER: (Continued) 2Q Do you recall the names of any of the people you met at 3 the Raybestos facility? 4A No. I might remember it if the names were recited to 5 me, but no, I wasn't particularly familiar with those 6 7Q 8A 9Q 10 folks. Do you remember any names from Keasbey & Mattison? That was 30 years ago. I'm poor on remembering names. I'm going to shift over now, Mr. Houghton, to Garlock, and I want to ask you first how did you come to be 11 12 A 13 employed by Garlock? In 1938, the superintendent of the textile plant was Harry Elder and he died. I'm not sure why he died but 14 he died in '38, and they were in need of someone to 15 operate the department. They had at least a couple of 16 years of doing the best they could with what they had 17 or Owen Burns was one of the workers and he was in 18 charge when I came here, but Mr. Hubbard, Cecil Hubbard 19 was factory manager. He was later promoted to vice 20 president. George Abbott was president of the company, 21 and I came up here in March of that year and they told 22 me to -- I came in February and they told me to come up 23 in March, so I've been in here, made a good impression czMidtcuun ezReportinp cSezuice 5 0 / 'Dimes cSquate Huifdincj cRockesUs, aNcuJ '~LJosk 146/4 31 1 2Q 3A 4 5Q 6 7A 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 on. That was February, 1938 or 1939? It was '39 when I was called in February to examine the place and I came to work in March the 13th. How did you know about Garlock or how did Oarlock know about you? There was a fairly good relationship between Garlock and Johns-Manville. There was an interchange. There was some people that went from here to work at Johns-Manville and some folks from Johns-Manville had come here, so the companies knew each other. This was in '39, tail end of the depression, and when I told my superintendent, Mr. Cannon, that I had accepted a position here as superintendent, Phil Cannon said to me if there was anyplace other than Garlock, I'd advise you not to go. This was a backside way of a compliment of Garlock, so he didn't stand in my way, but I had already told him I had accepted because I had had a couple of other opportunities to leave and they told me they were glad I stayed at Johns-Manville, so I didn't like -- Usually, when something like that happens, you got a little increase in pay, so I didn't like to keep edging myself up by the saying I got another chance, czMidtourn <zRepoztiny cSezuice 5 0 / Slimei Square SBuifJinq cRocfieilet, cNcui 'TJoti 14614 32 1 2 3Q 4 5 6 7A 8 9 10 11 12 13 Q 14 15 16 17 A 18 19 20 21 Q 22 A 23 Q but anyway, he said if there was anyplace besides Garlock, that I'd advise you not to go. You mentioned that some of the people from Manville had come to Garlock and some from Garlock to Manville. Can you help me with any names of people who transferred from one to the other? I know that there was a Bavis whose brother works here, had gone from here to John Manville. He worked in the packing department, then there was another mechanic that moved down there. His name was -- Oh, nuts. He was a very good mechanic. When I'm not thinking, I'll remember it for you. If you remember it, you just advise us of the name but we'll keep going in the meantime. Had you ever visited any facility owned by Garlock while you were at Manville? No, I didn't know of Garlock until I heard that there was an opportunity here. I may have heard the word but I didn't really know much about it, but I never saw Garlock until I came here to visit. You started with Garlock in March 1939? Yes. And that was in Palmyra, New York, where your home is? cMidtaian ^Reporting cSezuice 50! cJimcs cSyuatt cRockaUz, uNevj njozl !46t4 33 1A 2Q 3 4A 5 6 7 8 9 10 11 12 13 14 15 Q 16 17 18 A 19 Q 20 A 21 22 23 That'3 right. What type of facility did Garlock have in existence in 19397 What did they produce in Palmyra? Well, they have about a dozen departments. They make CLvA V\OJr\Agaskets, folded gaskets., make gasket rings, -had' pern-- V,c\e. heiod- gaskets for boilers and then they made varieties of packings, rings and compressed asbestos sheet gaskets. They sell sheeting, but they also punch out millions of disk rings for valve stems or they make felt packings for ball bearings. They make large variety of molded parts in high temperature molding for vulcanizing rubber. They make rubber sheets for sale. They furnish cloth to others to make safety clothing. They now make Teflon products. If we can, going back to the 1939 time frame when you came, were the gasket materials that you described asbestos-containing gasket materials? Some. The folded gaskets, did they contain asbestos? The folded gaskets were rubberized asbestos and then folded together to make multiple-plied products, but most of them were rubberized either by dipping or frictioning, and then they might be made into aMidtoum czRepoztiny cSeruicc oSOIr C../.imei ,c/Syuactne.-`BtuitJIiMnAyt M 34 1 laminations. 2Q And the compressed asbestos sheets, are they the sheets 3 from which gaskets can hi: cut to a specific size? 4A Yes, most of them in single sheet from a 64 on up to 5 maybe as far as an and then they laminate if they Ci* 6 want to go thicker than^8'ti'rv 7Q And the folded gaskets and the compressed asbestos 8 sheets and the packings, did those contain or do you 9 know the percentage of asbestos by weight in those 10 products, the general range? 11 A Well, most of time used the commercial blend, which is 12 the 75 percent, and then there would be a good 50 or 60 13 percent rubber on top of that, so we're down now to 14 maybe 30 percent asbestos in some of these rubberized 15 products. 16 Q And the ones that did not have the rubber, then, would 17 more or less be like the commercial grade of asbestos 18 cloth, roughly about 75 percent asbestos by weight? 19 MR. SHANNON: I object. I don't think that he said 20 there were any that didn't have the rubber 21 22 A 23 that were used for gaskets. Well, others dipped in maybe Teflon. Again, they're coated. A small percentage might be used in a dry ezMidtoion cRcpoztiny cSezuice 5 0 / 'Oimti cSquazt cRocfitsUx, cN cvj n jo x t 14614 35 1 2Q 3 4A 5 6Q 7A 8 9 10 11 12 13 14 Q 15 16 A 17 18 Q 19 20 21 A 22 23 cloth, but mostly they're coated or impregnated. Am I correct that Garlock Packing Company had been in business for a good while before you came here in 1939? Yes, I guess Garlock was probably about 1880 or somewhere around there. 1887 sound about right? That's somewhere around when it started. I think it started with rubberized fabric using somebody's rubber boots for strings for making packing^power plants. The fella was using anything he could get. Finally he used this and it worked, so he moved from the power plant over to making rubber slabs like rubber boots, and from there he progressed into using other materials. When you came to Palmyra, Mr. Houghton, can you tell me overall about how many people were employed? Oh, I don't know, maybe less than 200. 200. Maybe around Approximately how many of those 200 would have been involved in manufacturing items that contained asbestos? That's kind of a broad figure you're asking. I could say maybe 35 to 38 making the asbestos parts, then the k. other parts like high-pressure manufacturing and the <cMidtoum zRcpoztincj cSczuice 5 0 f Uim a cSyuaxt <JBui(diny tzRoc&cster, <zNc\a ^ o x i 14614 36 I 2 3 4 5Q 6 7A 8Q 9 10 A 11 12 13 Q 14 A 15 16 Q 17 18 A 19 20 21 Q 22 A 23 CoXe'sxke*' mill and ocHbandor, they all handled the products, maybe another hundred there. You're now reaching out into a range of products, so to give you an exact figure, I couldn't do it. The type of asbestos that was used was primarily the chrysotile or the white asbestos? Mostly, yes. And you also had some of the blue asbestos or the crocidolite? A certain percentage of the crocidolite was used. We didn't do any weaving or spinning of crocidolite. That was purchased maybe from Germany. Or Rhodesia? The Rhodesian would be thesource but the spinning was done maybe in Germany. The crocidolite, was that used in products other than gaskets or was it strictly used in gaskets? I think it was used where chemical resistance was a major factor because crocidolite is better against acids than the chrysotile. Less corrosive when it comes in contact with -- Yes, it would resistcorrosion or resist decomposition better than the crocidolite. czMidtoum <zRepozting cSeztrice 501 Himes cStjuaxe CBuifdiny cRocfiatet, cNew ^ o i i 14614 37 1Q 2A 3 4 5Q 6 7 8A 9 10 11 12 13 14 15 16 17 18 19 20 21 Q 22 23 A Than the chrysotile? CVirv^scfVAe Ghrysoite. That would be damaged. The blue, which is harsher and not as easy to handle, does resist chemical action better than the -- From the engineering standpoint, what efforts did you observe that Garlock was taking to control dust when you first came aboard in 19397 Quite a lot of work had been done by Harry Elder in improving the dust control over the carding machines. He had done a major job of constructing hooding, but then by the time I came here, Whiten Machine Works had fabricated hoods, wooden hoods that fitted tightly against the cards so the Whiten Machine Works had done a lot of work in improving dust control for cards. In removing dust, you take a lot of vacuum and that actually removes a fairly high percentage of your product, so in manufacturing, you do have to remove quite a percentage. I believe 20, 25 percent has to go up to the filterhouse just as a means of keeping it clean. And then you can recapture what you've got in the filterhouse? The filter bags are shaken every day so that material czMidtoum <zRepoztiny cSczaicc 501 Otmts eSquate HuifJiny cRockeitet, yVcuj cJJaxi 14614 38 1 2Q 3 4 5 6A 7Q 8 9A 10 Q 11 A 12 13 14 Q 15 16 A 17 18 19 20 21 22 Q 23 falls and is removed once a week. And the hoods and the vacuum ventilation system that you've described was basically to remove the asbestos dust that was being generated in the manufacturing process? That's right. And you used the same type of engineering both for the chrysotile and for the crocidolite? We did not process any crocidolite. Through carding and through the looms. That's right. We didn't make any fabrics. We bought some yarns for braiding, but those were dipped in oils or greases and then braided. What was your specific job responsibility as superintendent when you started with Garlock in 1939? Run the plant, which included fiber preparation, carding, spinning, twisting, weaving and upkeep of the equipment, purchasing equipment to make repairs when all of these machines subject to wear or breakdown, lubrications, and so forth; you worked up schedules for maintenance. When you came to Garlock in 1939, was Garlock also aware of the need to keep asbestos dust to a certain <zMidtoiun cRcpoztin^ cSezuice SOI Uimti cSituate <3uiiJiny erfioe&esiet. Jd6fd i III 39 1 2A 3 4Q 5 6 7A 8Q 9 10 11 A 12 13 Q 14 15 16 A 17 18 19 20 21 Q 22 23 A level? I think the federal requirement was in existence at that time. Were there any laws that you were aware of from the State of New York that related to the work site and dust? I don't recall any New York State law. How would you compare the knowledge concerning the importance of controlling asbestos dust at Garlock to what you had observed at Manville? I think we were better here than Manville. I think the dust recovery system was functioning more efficiently. Did your responsibilities as plant manager, superintendent, include keeping an eye over how well the dust control system was operating? I was probably the only one that was closely related to these jobs. I would call the maintenance department for cleaning up once a week or coming in to do any of those operations to keep place working right. It was my job. Did Garlock have any respirators available for the men who were working with and around the asbestos? Yes. Those people that worked for the maintenance i^yjidlown j^eporlinj -Stf tlOO $ocLdtUr, fyjiw IjorL 14614 40 1 department had to wear the improved mine respirators 2 when they were cleaning up at the end of the week, when 3 they were removing dust from the filterhouses or from 4 cleaning up around the machinery. We used respirators 5 for those men that carried stock. W e 'd have those box 6 trucks and they would bring the material that had been 7 blended. Rayon and asbestos was loaded into these 8 trucks and brought up the elevator and then brought to 9 feed into the cards, so those men were required to wear 10 respirators during handling of stock by hand. 11 Q How much textiles were produced, asbestos textiles were 1 12 produced at the Palmyra plant of Garlock? 13 A Oh, I guess it was probably about two million pounds a 14 year. 15 Q And that was sold commercially? 16 A The highest percentage was used within the factory, 17 either in the dipping machines or in the high- pressure 18 19 Q 20 A manufacturing where they coated it with rubber. So some of it -- Most of it was that way. Then we shipped some rolls, 21 22 Q 23 II but the most of it was internally used. And was any of the textiles that you have described also used to make further products like the Garlock yrjdiou/n $<iporliny ^trvics ItOO t j o* I46/4 41 1 gaskets? 2A Yes. That was after the coating process. There is 3 very little requirement for asbestos just as a dry 4 cloth. 5Q 6 Once you had made a compressed asbestos sheet out of which gaskets could be cut, you were able to print on 7 that compressed asbestos sheet, am I correct? 8A They would put a label on it, yes. 9Q 10 A And you could put Garlock's name on it? It might be a label, the brand, and a style number 11 might be on there, so it could be identified as a 12 Garlock product. 13 Q 14 A And that would be right on the product itself? That would be printed right on the sheet. 15 Q And Garlock made gaskets in various light and dark 16 colors? 17 MR. SHANNON: You're talking about compressed- 18 asbestos sheet gaskets? 19 Q Compressed-asbestos sheet gaskets, what colors did they 20 come in? 21 A Color? 22 Q 23 A Yes, sir. Oh, might be in a black, one a dark gray. They had W uLwn porting 1100 Uurtsi $ocl*lUr, lyJorL I4SJ4 42 1 some in the white. 2Q Would that be a white or a light gray? 3A It would be off color white. Once you start using 4 white rubber on white asbestos, you come up with a 5 dirty gray, and they might have a -- I think they may 6 have used some blue and some red. 7Q Now, the style number, does the number 7005 ring a bell 8 for you from the gasket materials? 9A I was not majorly connected with that, so -- 700'a, I 10 heard those numbers, but I didn't handle them enough to VOAie- 11 be- a good answer for you. 12 Q Am I correct that many of the gaskets produced by 13 Garlock, but not all, had the name of Garlock on the 14 material itself? 15 MR. SHANNON: Again, compressed-asbestos sheet 16 gaskets. 17 A Well, many of the products might have a number and then 18 be boxed in a Garlock-labeled box. I don't think the 19 word "Garlock'' would show on everything that they made. 2.0 Q 21 I understand, but the name was put on some of the compressed-asbestos sheet gasket material? 22 A Oh, I guess the word "Garlock" showed on some of the 23 sheet, yes. cMidtoion cRepoztiny cSczoicc SOI Uimtt cSguate 'Building cRocfiaUx, cNtuj njoxH 14614 43 1Q 2 3 4 5 6A 7 8 9 10 11 Q 12 13 14 A 15 16 17 18 19 Q 2.0 21 22 23 In the mid to late 40's, would it be fair to state that .Garlock's employees that were exposed to dust, asbestos dust, were aware that asbestos could possibly be harmful to them if they breathed it without necessary protection? Most people do not live in a state of awareness of danger hanging over their head all the time. We had probably more long-term workers in textile than in most of the other plants. There was no sense of fear in the plant. Was there awareness that it was important to keep the ventilation and exhaust equipment working and to use respirators when you were around asbestos dust? When you were working in a dusty area, yes. Generally, we had a pretty clean department, so the respirators were not worn by everybody. It was only where you were handling dusty material like feeding a card or laying a batch. Were there any programs that you recall, Mr. Houghton, at Palmyra to advise the employees of the importance of keeping the ventilation and vacuum equipment working so j that the asbestos dust level in the air could be kept low? j cJ\ltJtoLun czRepoztiny cSezuice 5 0 / imes cSquate cBuifJing cJ^ocfidtiz, <zNew cy<Q*{t 146/4 tii i 44 j --------- ----- -- ------------ ----------------- ---- -------- i 1A 2Q 3 4 5A 6 7 8 9 10 11 12 13 14 Q 15 A 16 17 18 19 20 Q 21 A 22 q 23 A That was responsibility of the supervision. And what did the supervision do to make sure that the men were aware of the importance of keeping the asbestos content low? I don't think that generally people are aware of details like that. They depend on their supervision to keep things up to date and keep adjustments right. Now, you make improvements, then it's up to us to see that the improvements are kept in the proper shape, and that was the foreman's job. The superintendent might be checking by casual moving through the department to see that it was being done, but you had foremen that were also responsible. How many buildings were there at Palmyra? Oh, the numbers were something like up to 25. Numbers of buildings is kind of a hard thing to do because here's a shed and it's given a number, so roughly, there were around 25 different types of manufacturing going on. Who was Mr.Bristol? Bristol? Yes, sir. He was in charge of the machine shop, and I guess he cMidtoum <zReporting Service 501 Oimci eStjuart IBuifJtny t * d. I M 45 1 had yard gang for maintenance of the whole factory 2 outside as well as the tinsmith and the electrical 3 departments were all under Bristol. 4Q In some of the buildings, for example, Building 15, are 5 you able to identify what Building 15 was or what 6 service was performed there, do you recall, in the 1942 7 time frame? 8A 15? I was in Building 7. 15 I don't think is clear 9 enough in my mind just which it was. 10 Q In Building 8 or Building 15, in June of 1942, I have a 11 paper which I will share with you, but I want to ask a 12 clarification first. A comment was made of the need to 13 remove ftimes and impurities on the second floor that 14 were created, generated or released by filling bins 15 with powdered materials. Would the powdered materials 18 being referred to be asbestos? 17 MR. SHANNON: Why don't you let him see the 18 document? It might help. Are you talking 19 about Building 8 or 15? You said both at the 20 beginning of the question. 21 MR. GLASSER: There's a reference, Jim, and I think 22 I'll need his help to clarify it, but I have 23 extra copies of the same document. czMidtoum czRepoztinj cSezuice 501 rJimci cSqaaxe rBui(diny cRodtatex, <zNcuj n jo zt 4614 46 1Q 2 3 4 5 6A 7Q 8 9 10 A 11 12 13 14 Q 15 A 16 Q 17 A 18 Q 19 20 21 22 23 This is the document, Mr, Houghton, I'm showing to you. At the same time I've got another copy here for your counsel. Let me turn to the first page. I'm going to move back just for a second and it is marked June 5, 1942. Do you see that, 6-5-42? Yes. And it has "Mr. Bristol" then the word "important" and it has some initials. Do you know whose initials those are? I can see a C there, but that number 8 doesn't tell me much. Let's see, I don't know whether that might be C. R. Hubbard. C. R. Hubbard was the vice president in charge of the factory, the molding department. If you will turn to the next page -- It likes like Frisbee Walborth. That looks like who? This, looks like Walborth. This might be a signature from the industrial commissioner. What I was questioning, if you look at the paragraph numbered 1, it talks about the need to "Provide an exhaust system to remove fumes or other \ impurities from your factory on second floor, created, generated or released by filling bins with powdered aMidtoujn <zRepoztiny cSezaice irt/ H;m u f t u i Ui | 1 materials." Do you see where I read that? 2A Yes. 3Q Is the powdered material that they're referring to 4 there asbestos? 5A It sounds like it may be where they were making up 6 compounds, second floor. 7 MR. GLASSER: Jim, to answer your question, it says 8 Building 8 and 15. 9A 10 Manufacturing didn't do much blending on the second '"Vrve're. floor. That was blending in the basement. 11 Q Now, with regard to that on the basement, look with me 12 at paragraph marked number 2. Here the direction is to 13 "Construct and locate hood so that dust from grinding 14 gaskets will fall or be drawn into the hood," and then 15 it has a parenthesis, "(gasket grinding machine - 16 basement - building 8 and 15.)" 17 A They had a mill in the basement for re-- well, they 18 would chop up gasket trimmings to be reprocessed in the j 19 mixing, gasket grinding. There might be some type of a 20 gasket tolerance that required a certain thickness, and 21 then they would put it through a grinder which would 22 have a surface grinding operation. That could make a 23 rubber dust and be a nuisance and it could be a fire cM idtown cRepozting cSczuice <zSROoct&eiici, <zNccSuyjuaOt/tot*il}uitc/l4in6y/4 48 1 2Q 3 4 5A 6 7Q 8 9A 10 Q 11 12 13 14 A 15 Q 16 17 18 A 19 20 21 22 23 hazard if you didn't keep your machinery clean, Do you have any recollection of a document such as this being delivered to the Garlock Packing Company by the Department of Labor? No. I being not connected with maintenance, I would not see any report like this. Can you identify the writing that appears on the lefthand margin of page 2 of this exhibit? No. If anydirectionor order were given to the plant to collect certain fumes or grindings that were escaping into the work environment, would those have generally been brought to your attention? No. Are you awarethat in the 1942 timeframe,there were documents such as this received by the Garlock Packing Company at its Palmyra plant? They wouldn't have come to me. I was not in the health department. The problems of textiles would come to me. In fact, only to me because it was -- if I needed any help, I'd go to maybe Bristol for electrical or other upkeep business, but for the maintenance of dust control was mine, designing was mine. cM idtourn (Reporting Sezoice SOI Uimei cSquate `BuitJiay cRochatci, cMcuj HJoxt 14614 49 1Q 2 3 4 5 6 7 8 9Q 10 11 12 13 14 A 15 16 17 18 Q 19 A 20 Q 21 22 23 A Thank you, Mr. Houghton. I'm going to give this to the court reporter and ask her to identify that please as Houghton Humber 1 so they can see what you and I were sharing and talking about. (WHEREUPON HOUGHTON EXHIBIT 1 - Fourpage document; first page reading "Mr. Bristol" and "Important" - WAS MARKED FOR IDENTIFICATION.) When problems were brought to your attention that needed correcting as it related to the vacuum system or the need to keep asbestos dust low? What sources of information did you have to turn to in addition to your own past experience? We had a very good man, a John Kattenack, who was a big help in designing dust recovery systems like a cyclone, and he was the one I would go to, and he was very helpful. Is he available today? No, he's also in the ground. Was there anyone at or available to you at Gar lock who kept up with industrial hygiene or medicine as it related to the asbestos hazard? I think not. czMidtoivn (zRepaztinj cSezuice cR5oc0f1tcit'Ucxim, eci NccSvtjjuar7ie/ot`BfuifJ1i4n6y14 50 1Q My question is had you any time, say, in the 1930's, 2 while you were at Manville or in the early part of your 3 career at Garlock heard of Dr. Merewether over in 4 England and the studies that he had done on asbestos 5 textile plants over there? 6A I think ray answer is no. 7Q I'm going to show you, and it's a thick document 8 consisting of 34 pages, but I'm showing it to you just 9 to see whether or not that in any way refreshes your 10 recollection. This is only a photocopy of what the 11 document was. t 12 MR. SHANNON: Can we idcntifd-cd it for the record? 13 MR. GLASSER: For the record, I'm showing him the 14 "Report on the Effect of Asbestos Dust on the 15 Lungs and Dust Suppression in the Asbestos 16 Industry." It is a two-part paper by E.R.A. 17 Merewether and W.C. Price. It is dated 1930. 18 A One shilling, three pence. No, I did not know of him, 19 and the report that this covers did not come to me. 20 Q I thank you, and I will show you another report and ask 21 you whether you have seen or heard of this. 22 MR. GLASSER: For the record, this is an United 23 States Treasury Department Public Health c^Midtoum czRepoztinj cSezuice cR5o0c1ftctUtciim, ctcNetSu<)fuaTze/oti 14614 51 1 2 3 4 5 6 7 8 - 9 10 11 12 13 MR. SHANNON: 14 15 16 MR. GLASSER: 17 18 19 20 21 22 23 Report which was done by the United States Public Health Service. It is the January to June, 1935 volume, and specifically from that is an article which carries the date January 4, 1935 entitled, "Effects of the Infiltration of Asbestos Dust on the Lungs of Asbestos Workers." It is signed by Dr. A.J. Lanza. Now, one thing that I would show Mr. Houghton and ask him to read is the introduction or the introductory paragraphs on this article to see if that has any . meaning to him. You're asking him whether he knew that in 1929 the Metropolitan Life Insurance Company was approached? I'm asking him basically does he have any familiarity with Dr. Lanza's 1935 study, and what I'm showing him which might tie in with what we've discussed on the record is whether or not the Metropolitan Life Insurance Company was the plant that studied Manville. The reference is made that this report emanated out of Manville studies, and ccMidtoian czRepoztinq Sczaicc <i5Ro0c/fitiUUitm, a<zNctSuc3juacyieo\^iBuifd1i4n6g14 52 1 I believe also Raybestos-Manhattan studies. 2A Well, this was not brought to my attention while I was 3 at Johns-Manville. It was not brought to my attention 4 at Oarlock. It may be that most -- some of these 5 information were not -- That didn't excite people yet. 6Q Let me ask was it known while you were at Manville in 7 the 1927-1939 time frame that if you and I went out for 8 the first time today and breathed asbestos, that it 9 would not hurt us or show up on our x-ray tomorrow or 10 next month or even next year but that it took time for 11 the injury which may result from asbestos to show up? 12 MR. SHANNON: Wait, Mr. Houghton. I object to that 13 question. I don't quite understand it, and 14 are you asking whether he knew in the 1930's 15 that there was a lag, that your question? 16 MR. 6LASSER: I'll be happy to re -- 17 Q Do you understand my question? 18 A I think so, and I don't think that then consciousness 19 of the industry had become too much aware of the 20 seriousness of it, and they weren't preaching to us who 21 were working in the factory you must get going on 22 this. It wasn't the same awareness that you have now 23 was not then. czMidtoivn czRcpoztinj cSezuice 5 0 / *Dimes uaw *]iui(diny cRocfitiiet, cN cvj ^t/ort 146/4 i 53 1Q 2 3 4 5A 6 7 8 9 10 Q 11 A 12 Q 13 A 14 Q 15 16 A 17 Q 18 A 19 20 Q 21 22 23 A I understand, but to clarify my question, were you aware that the hazard of breathing asbestos fibers in the 1930's was that over a period of time, it could cause problems? No. We knew that some folks were sent to be checked by x-ray, but it was not the same plantwide type of study that was undertaken at Garlock. We were sent every two years to Clifton Springs, all of us, for an x-ray check. Why? For an x-raycheck. Was there -- There was no discussion to the individual why. Did you understand why they were taking periodic chest x-rays? I did, yes. What was your understanding, Mr. Houghton? Well, the reports came back only to those that might be cautioned you'd better move to another department. And the reports would reflect that there were some change on your x-ray that related to your breathing asbestos dust? Not described as such, but we might assume that. cM idtoum cR cp o ztin j cSezuicc 5 0 / cJimei cScjuaQtc/rttfJiBui(JtAinAy/A l 54 1Q Let me show you still a third report that I will share 2 with your attorney. 3 MR. GLASSER: This is a report, for the record, from 4 the U.S. Treasury Department Public Health 5 Service, Public Health Bulletin No. 241, 6 dated August 1938, and this was a "Study of 7 Asbestosis in the Asbestos Textile Industry," I 8 and the primary author is Waldemar C. 9 Dreesen. 10 A Now, this bulletin did not come to my hand. It was 11 dated -- 12 Q 1938. 13 A -- 38. 14 Q Were you aware that the U.S. Public Health Service had 15 evaluated and reviewed four textile plants? 16 A We were aware that the insurance companies would make 17 periodic checks. 18 Q And the standard that you and I have described that 19 limited the quantity of asbestos dust, was that 20 developed, according to your understanding, by the 21 insurance company investigations? 22 A Well, there was a U.S. Bureau of -- I don't know 23 whether it's the Bureau of Safety or something that cM idtown ^Reporting Service 50/ 'Dimes (Square DSuifJioy cRockestex, cNt\u HJotl 14614 55 1 2 3 4 5 6 7 8 9Q 10 11 12 13 A 14 Q 15 A 16 Q 17 18 19 A 20 Q 21 A 22 Q 23 Issued their requirements. I'm not sure of the wording of the department, but there was a Safety Department in the U.S. Government that issued these health notices, and that's the one that -- well, Public Health Service, right in front of me. I don't think it was all from the insurance company. I think the federal government did it maybe because of the insurance company, but I was not in on that kind of a discussion at all. I understand. Let me try to find one thing in this report. I'm reading on page 117, and I just wanted to refer in line 3 to the wording where it says "Less than 5 million particles per cubic foot." Do you see that? Yes. Was that standard 5 million particles percubic foot? That was the top limit. And that was the top limit, and if Iunderstand, beyond that limit, there was a recognized hazard to people breathing asbestos? That was where you were supposed to use respirators. And that -- And it was our problem, to keep it below that. And am I correct that it did not make any difference where the person worked but if the air that he was czMidtoum cRepoztiny cSezuicc SO! Uimei cSquate ^Buiidina i 56 1 breathing had asbestos in it and the measurement was 2 greater than 5 million particles of total dust per 3 cubic foot, there was need for protection, regardless 4 of what his job was? 5A That's true. 6 (Whereupon a brief recess was taken.) 7 8 BY MR. GLASSER: (Continued) 9Q You mentioned earlier, Mr. Houghton, the Asbestos 10 Textile Institute. What was the Asbestos Textile 11 Institute? 12 A It was a membership of all asbestos manufacturing 13 companies as well as the different mining companies in 14 Canada. I guess you have one mining company in 15 Vermont, but it was made up of the manufacturing 16 companies as well as the mines. 17 Q And was it an organization formed to render service to 18 buyers and uers and makers of asbestos textiles? 19 A Not so much for the uers as the producers. I think it 20 was mainly for the manufactures to discuss problems. 21 Each might come up or bring to the organizations some 22 of their thoughts. 23 Q And it was also an organization where you could share cJWidtoiun (cRcpoztiny cSezuice SO! `Dim a cStjuare `Duifdiny cRocfttitei. cNeu> T/ott 14614 57 1 2 3A 4Q 5 6A 7Q 8 9A 10 11 12 13 14 Q 15 16 17 18 19 20 A 21 Q 22 23 A advancements, engineering advancements on matters like dust control? Yes, you could share. Now, you mentioned George L. Abbott as being a president of the Garlock Packing Company. He was president. Was he also the representative to the Asbestos Textile Institute in the 1946 time frame for Garlock? He may have been brought in on some of their organization's side of it, but mostly it would be maybe a purchasing agent, or some other one of the group would be sent to these meetings and I would be usually the one. Look with me, please, at the exhibit that I have passed to you and, for the record, it is some minutes of the Asbestos Testile Institute taken at the general meeting held on June 19, 1946 at the Warwick Hotel in Philadelphia, Pennsylvania. Have you seen minutes from the Asbestos Textile Institute? Some. Those that I attended I would see them. I Is this in the general form of the minutes that you j attended? I don't remember Harris McKinney. This is back right a M id to iu n a R ep o ztin g cSczuicc <z5Ro0c/&cUtleiim, esc^V<<rScayua<t1e)0x1^1uifdi4n6y/4 1 2 3Q 4A 5Q 6A 7Q 8A 9 10 Q 11 A 12 Q 13 A 14 15 Q 16 A 17 Q 18 19 20 21 22 23 in the beginning stages, and so I recognize some of these names like George Fabel. And he was with Southern Asbestos Company? Yes. And do you recognize any of the other names? Well, I think I remember Dillon of Johns-Manville. What about Mr. Weaver of Raybestos Manhattan? I may have remembered him. Waken, I remember, of Johns-Manville. That's Mr. Waken, W-a-k-e-m, Frank J. Waken? Yes. What about Mr. Widmayer of Keasbey St Mattison? I don't remember him. I never really got closely attached to -- What about Mr. J. A. Bettesof Raybestos-Manhattan? N o , I don1t remember him. If you will, turn with me to page 4 of these minutes that Mr. George 1. Abbott attended for Garlock. There's reference to a definition of the Institute, and do these words, in your opinion, reflect the purposes of the Asbestos Textile Institute? "The Asbestos Textile Institute is a voluntary, non-profit organization formed to render service to buyers and cM idtow n cR epoztiny cSezuice 501 U im ti eStfUate 'Building cR o cfta tet, cfiicut T/orjf /4 6 !4 59 1 users of asbestos textiles." 2A They're saying users, then they plan to send out 3 bulletins to customers. I was not in on that. 4Q I understand. 5 MR. GLASSER: I'm going to ask the court reporter if 6 she'd be kind enough to just mark this as 7 Houghton Exhibit Humber 2. 8 (WHEREUPON HOUGHTON EXHIBIT 2 - Asbes 9 tos Textile Institute minutes of June 19, 10 11 12 Q 1946 meeting - WAS MARKED FOR IDENTIFICATION.) Are you aware as to whether or not some time during 13 1946 or maybe prior to 1946 a report from the Garlock 14 Packing Company relative to their dust control system 15 was prepared? 16 MR. SHANNON: What are you referring to there? 17 MR. GLASSER: Let me give you a copy. For the 18 record, I am looking at the reference to 19 appearance, and I have a copy for Mr. 20 Houghton, also, in the minutes of the dust 21 control committee meeting held on Wednesday, 22 March 13, 1946 at the Engineers Club in 23 Philadelphia, Pennsylvania of the Asbestos aM idtourn ezRepoxtinp cSczuice 50/ Uimet ^BulCding <zRoeieitci, cN cvj r y o ti 146/4 tfr 60 1 2Q 3 Textile Institute. On page 2 under paragraph numbered Number 5, there is a statement that "The problem of reduction of dust at the 4 carding engines was then discussed. Mr. McKinney 5 presented a report from the Oarlock Packing Company 6 relative to their dust control system." Did you see 7 where I read that? 8A That's number 5? 9Q Yes, sir. 10 MR. SHANNON: 11 Your question is does Mr. Houghton remember that report? 12 Q Do you remember a report prepared? 13 A No. There's a fair chance that I may havebeen asked 14 to prepare the report, but '46, I was there and nobody 15 else was working in a supervisory state in the textile 16 department but me, so I don't remember any report. 17 Q If a report had been prepared as this copy of the 18 minutes indicates, do you know whether a copy of the 19 report would still be available at Garlock? 20 A 21 22 23 Well, they had copious storage of reports, but I don't know anyone now over there that is responsible for such a thing, but, you know, it might be the thing to do would be to ask -- I don't know who over there, but cJAidtoum czRepoztinp cSezuice 5 0 / C7imei cStjuaze jBuifdintj cRociaU*, cNtw HJoxi !4614 61 1 2Q 3A what13 his name? Is this the current management at Garlock? The current management and the manager -- president was 4 not closely connected with it at that time. W e 've had 5 several changes in the top. Dick Watson would probably 6 be able to dig in to whoever might be having knowledge 7 of times. The one in charge of files is dead. She was 8 a pretty good person to go to, but I think this would 9 have to be brought up to Dick. He would be a much 10 better one to go after than me. 11 MR. GLASSER: Let me make a request to the attorneys 12 that are here. I would request that you ask 13 Mr. Watson whether or not he knows of and can 14 produce a copy of the report from Garlock 15 Packing Company relative to their dust 16 control system that was presented to Mr. 17 McKinney, who is Harris D. McKinney, the 18 Institute Manager of the Asbestos Textile 19 Institute and discussed in these minutes of 20 March 14, 1946, and I have no reluctance, as 21 stated on the record, I have very high regard 22 for Jim Shannon, and if that inquiry can be 23 made, if you think it's more appropriate that czMidtoum ^Reporting cSezaice 5 0 1 Cjimc> cSquaxt cBuitdinq cR ocficttct, cN cuj n jo z i !4 6 t4 V 62 1 we file it with a more formal notice to 2 produce, I will do so, but I 'm trying to 3 accomplish that more informally right now, 4 and if that's permissible to make that 5 request -- 6 MR. SHANNON: We'll note your request and make your 7 8A 9 10 11 12 13 14 request to Mr. Watson. This paragraph 2 refers to a Bausch Sc Lomb dust counter, and we purchased a Bausch Sc Lomb dust counter. That was in effect when you saw that 5 million particles reference. Well, that's when we were using it, and we used it here. It was a device in which there was a combination of a magniriod device and sarvpXe a cylinder with a plunger that would suck in a m i d m a 15 of air and impinge that against a glass plate. We used 16 a piece of paper that we would moisten to give humidity 17 and we put that in the chamber, and when you pulled 18 that plunger, the air was slightly moistened and 19 particles would be lodged on that glass plate. Then 20 you simply pick the thing up and you -- the plate was a 21 disc and that sample would be a little band and you had 22 about 12 positions on that glass plate, so you could 23 make samplings at different places. czMidtoum cRcpoztinp cSezuice SOI Uim<i cSquatc 'Jiulidiny cRochciUr, cNcia T/o/ 146/4 If 63 1Q Looking through a microscope? 2A Right, and then we would -- we had a numbering so we 3 had a record of where we had taken our samples and then 4 I would plug it into the -- There was a light on it and V\ojjL V\oA 5 you would count. It wae a little grid. It tau-a two 6 bars and some vertical marks, and in that area was the 7 equivalent of a reading of a cubic foot. 8Q And you could determine, therefore, what the dust was 9 by making this counting and make a very good educated 10 11 12 A guess as to what the dust concentration was in the area? As you were counting maybe 40 particles on that little 13 plate, the 40 particles times a thousand would be forty 14 thousand. I'm talking a little bit out of the top of 15 my head, but -- 16 MR. SHANNON: Mr. Houghton, excuse me, but don't 17 talk out of the top of your head. Wait for 18 Mr. Glasser to ask you a question and answer 19 what he asks you. If he wants to get more 20 information about this mechanism, I know he 21 will ask. Don't discuss, Mr. Houghton, 22 please do not discuss things he doesn't ask 23 you about. cM idtoum cRepozting cSezuice 50/ `Otma cSijuate CBuifdinj ezRoc&ettcx. cNeuj c"7/or 14614 63 1Q 2A Looking through a microscope? Right, and then we would -- we had a numbering so we 3 had a record of where we had taken our samples and then 4 I would plug it into the -- There was a light on it and V\0uA VnoA 5 you would count. It w*e a little grid. It >**=* two 6 bars and some vertical marks, and in that area was the 7 equivalent of a reading of a cubic foot. 8Q And you could determine, therefore, what the dust was 9 by making this counting and make a very good educated 10 11 12 A guess as to what the dust concentration was in the area? As you were counting maybe 40 particles on that little 13 plate, the 40 particles times a thousand would be forty 14 thousand. I'm talking a little bit out of the top of 15 my head, but -- 16 MR. SHANNON: Mr. Houghton, excuse me, but don't 17 talk o ut of the top of your head. Wait for 18 Mr. Glasser to ask you a question and answer 19 what he asks you. If he wants to get more 20 information about this mechanism, I know he 21 will ask. Don't discuss, Mr. Houghton, 22 please do not discuss things he doesn't ask 23 you about. cz/VlidtoLun cfiepoztincj cSezaice cR5o0c/fia*teJii,macNccSuyjuaTxe/oti 14614  64 1Q But I 'm very interested and I take it from your 2 statements that you did some of the counting yourself. 3A (No verbal response.) 4Q You're nodding your head yes? 5A Yes. 6Q These countings were done at Garlock in the 1946 time 7 frame or earlier? 8A The year we bought it I can't give you, but we had it. 9 MR. GLASSER: I'm going to ask please' that this be 10 marked as Houghton Number 3, and specifically 11 they are the minutes of the dust control 12 committee meeting held March 13, 1946. 13 (WHEREUPON HOUGHTON EXHIBIT 3 - March 14 13, 1946 dust control meeting minutes - WAS 15 MARKED FOR IDENTIFICATION.) 16 Q I'm going to go back to what is marked Houghton Exhibit 17 Number 2, and this is the minutes of June 19," 1946 18 where Mr. George Abbott, George L. Abbott, attended for 19 Garlock. On paragraph Number 2, it states that one of 20 the activities that had been done during the last 21 quarter included the "notification to members and 22 nonmembers on O.P.A removal of ceiling prices." That 23 was one thing they did. Another thing was the c M idtown cRepoztincj cSezuice SOI Uimcs cS<fuaxc cRocfiatex, cN cvj ^ o iH !46I4 65 1 "distribution of the Garlock Dust Control System 2 report," and that's the report that I've asked you did 3 you specifically recall. 4A I do not recall it. 5Q Do you know whether it was the practice of the ATI to 6 keep not only members advised of what was going on but 7 also keeping nonmeraber companies informed of Institute 8 activities? 9 MR. SHANNON: 10 11 Mr. Slasser, please, if you're going to ask him a question, if he knows, ask him, but I think the record should reflect you're 12 pointing out something on that document which 13 evidentally indicates what you've just 14 asked. 15 MR. GLASSER: I'm happy to confirm what I was 16 showing him when I asked the question is 17 paragraph number 3. In fact, let me read it 18 to the record, and I'm reading from Houghton 19 Exhibit Number 2, the minutes of general 20 21 Q n n meeting of June 19, 1946. Was it your understanding that this was a regular pmo! lee, n;;:tv-ly, "The president brought up the matter 23 of keeping nonmember companies informed on Institute czMidtoion czRepoztinp cSezuice 501 Uimti eStjuate building <zRoc&cttX, cN cuj HJoxt 14614 I 66 1 2 3 4A 5Q 6 7 8A 9Q 10 11 12 13 14 15 16 A 17 Q 18 19 20 21 22 23 activities." Do you know whether the Asbestos Textile Institue not only tried to serve its members concerning asbestos matters but also nonmembers? I don't know that. Going back, Mr. Houghton, to the 1946 time frame, again, the mid 40's, were you familiar with the Industrial Health Foundation, the IHF? No, I was not kept up to date on that, no. Do you recall whether or not a study was made of the Garlock Packing Company's plant by a Mr. W.C.L. Hemeon who was a chief engineer for the Industrial Health Foundation in the 1947 time frame? Do you remember people coming or Mr. Hemeon coming to the plant to study and evaluate what you do with regard to dust control? I can't give you an answer. No, I'd say no. I will share some papers with you that may or may not help let me ask this question first. Are you aware that the Asbestos Textile Institute at its meeting as reflected by the minutes of the subcommittee meeting on dust control committee held June 13, 1946 at the Engineers' Club in Philadelphia, was concerned and I'm reading in paragraph 1A of those minutes, of the a M idtotun ^Reporting Service 5 0 t cJim ei cScjuare <dBuifdiny <zRockctext cNevy T/oti 14614 67 1 "Importance of dust control problem to all member 2 companies and the need for immediate cooperative 3 action." My question: Were you aware that the 4 Asbestos Textile Institute was discussing the need to 5 gather information, facts, on dust determination and 6 control procedures in the various plants of its 7 members? 8A I do not remember any report of that action. 9Q Were you aware of any services that were available by 10 the Mellon Institute in Pittsburgh? 11 A I'm not aware now. No, I can't say I was aware. 12 Q And I might have asked this, but were you aware that 13 the Industrial Health Foundation operated out of 14 Pittsburgh and offered industrial hygiene, engineering 15 and medical advice to industry where it was sought? 16 A No. 17 MR. GLASSER: For the record, I will ask that this 18 be marked as Houghton Number 4. 19 (WHEREUPON HOUGHTON EXHIBIT 4 - June 20 13, 1946 Dust Control Committee minutes - WAS 21 MARKED FOR IDENTIFICATION.) 22 MR. GLASSER: Off the record. 23 (Whereupon a discussion was held off the record.) cM idtoujn ezRepozting eSezuicc 5 0 / Utmet cStjuate HuitJiny cRocfteitet, cN cuj T/otjf 14614 68 1Q 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 I'm going to show you a thick document, and though it's all one document, the copy that I give you is divided by some loose pages and then there's a paperclipped portion and then some more loose pages. I'm going to ask the court reporter to mark this entire exhibit as Houghton Number 5, and for the record, I will read it with Mr. Houghton. This is a report of the Industrial Hygiene Foundation of America, Incorporated out of Pittsburgh. It is a "Report of the Preliminary Dust Investigation for the Asbestos Textile Institute," dated June, 1947 by W.C.L. Hemeon, head engineer; specifically, it's dated June 13? I think June 13, 1947. I'd like you to take a moment or as much time as you need and look at that, and I don't want to speed your taking the time. You take your time, but also let me pull out for you the paperclipped portion, and the paperclipped portion is dated July 11, 1947 and it's a "Memorandum on the Plant of the Garlock Packing Company Supplementing the General Report," and the general report is the document that you have, and it identifies that as the "Preliminary Dust Investigation For Asbestos Textile Institute of June, 1947," and you might look specifically at this three-page report to cMidtojun cRepoztincj cSezuice uRSoOctficiUtiirm, acN(cSuqjuanrejo x^lJBuif1J4in6g14 69 1 see whether it has any effect on your memory concerning 2 a study that was done by Dr. Hemeon on the Garlock 3 Packing Company plant. 4A "We rate this as average." 5 MR. SHANNON: Don't read out loud. She'll write it 6 down. Just read it to yourself. 7 MR. GLASSER: Off the record. 8 (Whereupon a discussion was held off the record.) 9 10 MR. GLASSER: While we were off the record, Mr. 11 Houghton had just a matter of several minutes 12 to look at the document, which is a rather 13 large document. We decided we're going to go 14 to lunch. I have told Mr. Houghton in the 15 presence of his counsel that when we return 16 from lunch, I will ask you him whether or not 17 the document has any effect on his memory, 18 whether or not he recalls this study being 19 made; specifically, whether he remembers or 20 recalls a study being made of the Garlock 21 facility, which is included in this report, 22 but in any event, we'll resume those 23 questions following the lunch hour. cMidtoian czRepoztiny cSczuice SOI 'Dimes eStfuare f3uifJing tzRoc&aict. ciNeuj n jo xi 14614 70 1 (Whereupon a recess was taken at 12:50 p.ra. and the 2 deposition reconvened at 1:50 p.m.) 3 4 MR. 6LASSER: We have had a lunch break since 5 approximately an hour ago, and when we 6 returned, Mr. Houghton had not had an 7 opportunity to review the document that we Wcrv-cors 8 left with him, namely the Heaoon document 9 which we marked as Houghton Exhibit Number 10 5. Since we've been back ten minutes or so, 11 he has had time -- 12 MR. SHANNON: Five. 13 14 BY MR. GLASSER: (Continued) 15 Q You've had some time, Mr. Houghton, to review the 16 large document and the three-page paperclipped 17 portion? 18 A I've gone in deatail on the one Garlock. 19 Q Do you have any recollection of an examination or 20 evaluation having been made by the representatives of 21 the Industrial Hygiene Foundation of America around the 22 1947 time frame as a part of an investigation of 23 approximately ten plants that the Asbestos Textile tcMidtoivn czReporting cSczuice 501 cSyuaie 2?uifJiny cR ockaittt cNcvj n/orjf 14614 71 1 2A 3 4 5 6Q 7 8 9A 10 Q 11 12 13 A 14 Q 15 16 17 A 18 Q 19 A 20 21 22 23 Institute was overseeing? I can recall making studies myself and insurance companies have also examined it, but as for tying it to a definite report, I cannot accurately say. I know that. As I understand your testimony, were there reports or evaluations made of the Palmyra plant in the mid 1940's? Since you say in the area of the 40's, yes. What you don't have any specific recollection of Dr. Hemeon coming through and reviewing your plant and writing this report. No. Did Garlock havea rather unusual interplant heating system where extra heat fro* one plant was carried over to another plant? Heating? Heating or excess hot air removal. Each plant had its own heating system from the power plant's supply of steam. Our own thermostat would take care of our unit. Each building was a unit, but there was no pumping of air around. It was steam heated by independent heating units. c M id to u jn < zR epoitinq cSezuice SOI 'Dimes cSyuase 'jBuifdiny ezRocfsester, cMcul T/oti 14614 I I 72 I 1Q 2 3 4 5 6A 7Q 8 9 10 11 A 12 13 14 Q 15 16 17 A 18 19 Q 20 21 22 23 A Staying with the period around the date of this report, namely, July 1947, were you aware that there was concern in the Asbestos Textile Industry to try to determine or verify whether the 5 million level was in fact a safe or sure level? No. Were you aware that there were efforts among the various asbestos textile manufacturers through the Asbestos,Textile Institute to exchange information on how to improve things? I think it was an independent effort to improve your particular unit. We weren't -- I was not concerned with other units. But if you had good information, you were willing to share it through the Asbestos Textile Institute with others? Willing. I was always willing but there was not a constant feeding from one to another. Was it your understanding in the mid 1940's that the 5 million particle standard that we have discussed was not positive insurance that no disease would occur, it was more of a goal to strive for, is that correct? It was more as a goal, yes, that's -- I was not in the aMidtomn cRepoztinp cSezuice 5 0 / Himes cStjuate `Building cRocficste*, cNeus HJoti 14614 73 1 2Q 3 4 5A 6 7Q 8A 9 10 Q 11 A 12 Q 13 14 15 A 16 Q 17 18 19 A 20 Q 21 22 A 23 health department. As an engineer, were you aware that there was the electron microscope was in existence in the 1946-1947 time frame? To answer that question, I couldn't say -- no, I was not aware that it was available for our use. But were you aware that it had been invented? Oh, I think I may have heard that they had developed the microscope. The electron microscope? The electron microscope", yes. Am I correct that the electron microscope had an ability to see things at a far greater magnification than a regular light microscope? Yes,I've heard that. Were you aware that there was concern expressed in the 1947 time frame that the light microscope was not a good device for counting very small asbestos fibers? No, I didn't hear that. Did you know the difference between a fiber and a particle? I think the definition was a fiber was of some 5 microns or over; a particle was a spot. czMidtoivn dRcpoztincj (Service. 50/ Uimei cSquaxe ^Buifding cRocftciUx, cNew T/orjf 146 f4 l 74 1Q Would it be fair to say that a fiber was three times 2 longer than it was wide and a particle was more of a 3 rounded shape. 4 MR. SHANNON: I object to that. 5A No, I can't say that. 6 MR. SHANNON: He hasn't testified to anything like 7 that. 8A I can't say that. 9Q I'm showing you a page that comes out of the Hemeon 10 report, Houghton Number 5, that has a copy of what 11 purports to be a photomicrograph. Do you see where I 12 show that? 13 A Yes. 14 Q Have you ever seen in the 1947 time frame pictures or 15 studies of asbestos that were produced under an 16 electron microscope? 17 A No. 18 MR. GLASSER: 19 20 I am going to request the court reporter to confirm that this has been marked as Houghton Number 5 and pursuant to my off- 21 the-record discussion with Jim Shannon, I am 22 going to give you today the cover sheet of 23 that exhibit, and I'll discuss it on the cMidtown cRcpoztinq cSczaice 501 Oimts cSyuaie ^BuifJiny cRocfitslcx, cNtu) njoxi 14614 75 1 recoup. My notations were basically my own 2 cues that give me an abbreviated portion of 3 the text. I really don't have an objection 4 to that being filed. I think it would be 5 nicer to have a nice clean copy, but rather 6 than run the risk I 'm going to leave her this 7 copy and then if I can supply her with a 8 clean copy, then it will be substituted. The 9 copy of the text is identical. 10 MR. SHANNON: I don't have any objection of what 11 ever you want to do. If you want to supply 12 her with a clean copy at a later time, that's 13 perfectly all right. 14 MR. GLASSER: Pusuant to that I'm going to add to 15 page one the rest of this bulk. 16 MR. SHANNON: Off the record. 17 (Whereupon a discussion was held off the record.) 18 (WHEREUPON HOUGHTON EXHIBIT 5 - 6 5 19 pages; first document being "Report of 20 Preliminary Dust Investigation For Asbestos 21 Textile Institute, June 1947 - WAS MARKED FOR 22 IDENTIFICATION.) 23 Q Mr. Houghton, did you have any occasion, sir, in the aMidtoum ^Reporting cSczuice 5Of Crimes cStjuare <-RocficiUxt cNtuj HJori 146 f4 4 76' 1 2 3A 4 5Q 6 7A 8Q 9 10 A 11 Q 12 13 A 14 15 16 17 18 19 Q 20 A 21 Q 22 23 1940' 3 to attend any of the meetings of the Asbestos Textile Institute? I have no record that I know of of my attending in the 40's. I think my start was in the 50*s. Was it Mr. Abbott who attended ATI for Garlock in the 1940's? He probably did. When I attended, he did not. When he attended in the 40's, did he ever report to you what had been discussed? I cannot recall any reports from him. Do you know to whom he would ordinarily report in the 1940's? It might have been through the various different factory managers, Cecil Hubbard for a number of years, and my memory is poor, but there were probably a period of not more than five or six years of any one of the various managers when something took place and they would change or they died. Mr. Hubbard, you told me, is no longer available? He's dead. I guess he's been dead for 20 years. Do you know whether any of the managers of any of the asbestos-producing Garlock plants from the 1940*s are still alive and available? cfAidtojun Reporting cSezuice 50/ cSyuau CBuifJiny cRochcitc*, cNeui T/oi t 14614 77 1A 2 3 4 5Q 6 7 8 9 10 11 A 12 Q 13 14 15 16 17 Q 18 19 A 20 Q 21 22 23 I don't think so.r^Mullen is dead and oh, fella that lived down here, he's dead. No, there aren't many of them alive. All along the line, they've dropped off, and they didn't work in the asbestos plant. We have talked about various dust counting techniques that were used within the plant on the carding and other dust-producing operations. To your knowledge, did Garlock ever run tests to determine the dust count of how the product would act when it was being used by the user? Not that I know of, no. To your knowledge, did Garlock ever publish any booklet or put down in a report for its customers what precautions should be taken when people, users, were using asbestos containing products from Garlock? (Whereupon a discussion was held off the record.) Were you shaking your head before we went off the record? I can't give you any positive answer, no. To your knowledge, at any time while you were with Garlock, did they ever place a warning on their asbestos-containing materials to warn people of any hazard that might be associated with the use of the <cM idtoum aRepoztincj cSezaice <zR5oOcffic%Uteiimt tscflctSwtjuaTxe/otBiuild1i4n6g/4 78 1 products? 2A It was not ray job. I don't know of anyone doing that, 3 but I can't give you an answer. 4Q How long did you remain in the employ of Oarlock? 5A Thirty-one years on salary there, nine years as a 6 consultant after retirement. 7Q And if my mathematics is correct, then, you would have 8 worked for Garlock from 1939 until 1970? 9A That's right. 10 Q On salary? 11 A On salary. 12 Q And then, are served in a consultant capacity from 13 1970 to 1979? 14 A Yes. 15 Q And your answer about never having seen any warnings 16 on any of the asbestos-containing products -- 17 A No. 18 Q -- that would be true from 1939 to 1979? 19 MR. SHANNON: That also assumes that he would have 20 had an opportunity to observe. You didn't 21 ask him where he might have served as a 22 consultant. My father is a consultant now in 23 his old firm, and he hasn't been in the firm cM idtown (^Reporting cSezaice 5 Of cSyuatt CBuifJing ' , c/tocSesiet, cN cuj 14614 79 1 2Q 3 4 5A 6Q 7 8A 9 10 11 12 13 14 15 16 Q 17 A 18 Q 19 20 A 21 Q 22 23 for years. Ara I correct that you never from 1939 to 1979 saw any warning on the asbestos-containing materials manufactured by Garlok? No. (x^ ecaxtcx, states QKSuier WiV W ^ Meb. ) What was the nature of your consultant work from 1970 to 1979 for Garlock? Some was development work in the factory. Mainly concerned with graphite, yarn and Teflon. Some of it has been in foreign countries. I was sent to set up braiding plant and instruct the weavers -- the operators on making braided packings, both in France and in the Philippines. For one period, I examined a textile plant reporting back conditions I found in that plant in Spain. Were these all Garlock plants? All Garlock plants. Has Palmyra always been its primary manufacturing site for gaskets and textiles? Its primary, yes. Did Garlock, to yourknowledge, ever share any of the information it had about the importance of reducing dust where asbestos dust was being generated? Did it aMidtoion cRcporting cSezuice 5 0 f 3 imes cSyuaxe cRocfieitet, c/few 14614 80 T 1 2 3A 4 5Q 6 7 8A 9Q 10 11 12 13 14 A 15 Q 16 17 18 A 19 Q 20 21 22 A 23 Q share that information with any of the uers or purchasers of its product? X was not in on any of that, no. As for Garlock doing it, I can't give you an answer. When did you first become aware of any association between the infiHrafeim of asbestos fibers and any form of cancer? You say when? That I can't give you a good answer. I have a paper that I will be discussing with you in a matter of moments from March of 1956 where the records indicate you attended an ATI meeting, but I want to ask some leading questions first. When did you first start attending ATI meetings? Probably about 1960. But if a record indicates that you had attended earlier, could you have attended as early as March of 1956? Basing on memory, possibly. In Philadelphia. That's correct, that's correct. Did you know the name in the 1950's of the Saranac Laboratories in Saranac, New York? I think I'll have to say no. Did you know the name as best you can recall, Mr. cMidtotun ^Reporting cSezuice 5 d Uimes <Syuaxe `Building cRocfiatcx, cflftuj ^ o x i J46/4 81 1 2A 3Q 4A 5Q 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 . Q 2 3 Houghton, of Dr. Garrett Sceepers? No. Did you know the name of Dr. Wilhelm Hueper? I'll have to say no. Let ae show you the document that I had reference to and I'm going to show you and your attorneys two different documents which I am going to mark numbers Houghton Number 6 and Houghton Number 7. Houghton Number 6 will be the minutes of the general meeting of the Asbestos Textile Institute held March 8, 1956 in Philadelphia, Pennsylvania, and Houghton Number 7, though inconsistent chronologically, will be the minutes of the meeting of the Board of Governors of the Asbestos Textile Institute held on March 7, 1956 in Philadelphia, and let me give a copy of these to counsel. (WHEREUPON HOUGHTON EXHIBITS 6 and 7 Minutes of March 8, 1956 and March 7, 1956 meetings of the Asbestos Textile Institute, respectively - WERE MARKED FOR IDENTIFICATION.) M r. Houghton, I'm turning to now what the court reporter has marked as Houghton Number 6, and in terms c M id ta u m R eporting Service SO! `jim ci cSguate `Building cRocftetici, cNcu] ``P o tt 14614 82 1 of the general form, can you Identify this form as 2 being what you recall the Asbestos Textile Institute 3 minutes generally to look like? * 4A Well, it looks like the type of report that we 5 received. 6Q And do you see your name on page 1? 7A Right here, there and here. (Indicating.) 8Q And so that the record is clear, the two places that 9 you referred to, number one was on the list of those in 10 attendance over on the right-hand side of the page in 11 the middle, in all caps it says, ''Garlock Packing 12 Company," and it says G. E. Houghton, that's you, is 13 that correct, sir? 14 A Yes. 15 MR. SHANNON: Attending as a guest. 16 MR. GLASSER: Attending as a guest, that's right. 17 Q And thesecondplace where your name is listed is in 18 paragraph number one where itstates in the next to 19 last line of that paragraph that Mr. G. E. Houghton, 20 Garlock Packing Company, and Frank Gatke, Asbestos 21 Textile Company were in attendance at the meeting and 22 also were in attendance at the Air Hygiene meeting on 23 March 7th, okay? czMidtoivn (^Reporting cSezuice cRSoOcIfiaUttxim, e<irf/ceSu3quactyeoxiHt uiid1i4n6y14 83 1A 2Q 3 4 5 6 7 8 9 10 11 12 A 13 14 15 Q 16 17 18 19 20 21 22 23 All right. If if you turn over to pages 2, in paragraph number 6, it indicates that at the meeting on March 7th, the day before, that one of the matters that was fully discussed were the comments of Dr. Smith, that's Kenneth Wallace Smith of the Johns-Manville Corporation, which related to the report issued by Dr. Hueper, who was with the National Cancer Institute, on a subject relating asbestosis with lung and heart disease was discussed at great length. Do you see where I'm reading that? I see where you're reading it, yes, but I was not at that earlier meeting. This was an earlier meeting, wasn't it? I understand but if you will turn back with me and see whether this refreshes your recollection. In paragraph number 1 it states, and I'll read it in its entirety and you read with me, "The meeting was called to order by President Wakem and an address of wecome extended to all of the members present. Recognition and welcome was also extended to representatives of two former member companies who attended the meeting of the Air Hygiene Committee on March 7 and were also in cM idtown aRepoztinp cSezuice 501 Utmet (Square ^Buifdiay <zRocfi<itcxt <zNcuj HJoxt 14614 i 84 1 attendance at this meeting, namely, G. E. Houghton, 2 Garlock Packing Company, and Mr. Frank Gatke, Asbestos 3 Textile Company," Do you see where I've read that? 4A This apparently my first meeting with the ATI. 5Q But the question is raised concerning the meeting on 6 March 7th, and for that I would ask that we turn to 7 the other exhibit that I gave you which you now have in 8 front of you, and this is the one for March 7th, and do 9 you see -- and I'd like you to look at paragraph 2A, 10 and take a n o m m s t . It's difficult to read. I'll be 11 happy to read it with you. Can you read it? Sir, 12 while you're flipping on the light to see better, do 13 you remember Dr. Kenneth Wallace Smith from the 14 Johns-Manville Corporation? 15 A I cannot give any accurate remembrance of this man. 16 Q Are you able to read it, Mr. Houghton? 17 A Most of the words I can understand. 18 MR. SHANNON: Off the record. 19 (Whereupon a discussion was held off the record.) 20 Q You and I will read it together. I'm going to read it 21 and she'll take it down so the record is clear. 22 Starting on A, it says, "The Air Hygiene Committee 23 report was presented by two representatives from that cMidtoum cRepozting Sczaicc 501 `Jimes cSyuaie 'BuiiJiny cRoc&atft, cMew T/ott 14614 % 85 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A 23 Q committee, Dr. Kenneth Smith and Mr. D.R. Holmes, chairman of the committee. Dr. Smith addressed the meeting first with remarks directing attention to a report issued by Dr. Hueper titled 'Public Health Monograph #36, A quest into the environmental causes of cancer of the lung.' Much of the information set forth in this report is unsubstantiated and is in variance with established understanding and knowledge of informed men in the medical profession; however, this article is apparently assumed to be the only authentic treatise today available which may be used as a reference for court action involving asbestosis and its relationship to heart disease and lung cancer. Dr. Smith strongly recommended that the Institute initiate a program of investigation and publicity to counteract the unfavorable publicity presently directed to the asbestos industries as a result of the work of Dr. Hueper. It was recommended that the Industrial Air Hygiene Foundation be engaged to collect the necessary information to publicize the results so obtained." Did I read that correctly? Yes. Do you recall the presentation by Dr. Kenneth Smith cM idtoum csRepoztiny cSezaice SOI Uimts cStfuare jBulfJtny cRockcitt*, <zNe\a T/otjf 14614 86 1 concerning the article that had been written by Dr. 2 Hueper associating asbestosis and lung cancer? 3A If I had seen that, it would have been from a report 4 because I wasn't at that meeting. 5Q If you will turn back with me to Houghton Number 6, do 6 you recall being at the meeting on March 8, 1956? 7A Yes. 8Q Do you recall at that meeting as is reflected by Number 9 6 of those minutes that the report concerning Dr. 10 Hueper's article was discussed at the meeting that you 11 were in attendance at on March 8, 1956? Do you 12 remember any discussion such as is reflected by Number 13 6 of the minutes? 14 A To recall? No. 15 Q Do these minutes, and take your time and review them, 16 and see whether any of the matter the discussed help to 17 serve or refresh your recollection. 18 MR. GLASSER: Off the record. 19 (Whereupon a discussion was held off the record.) 20 MR. GLASSER: Jim Shannon has pointed out to me 21 that in Houghton Number 6, the minutes from 22 March 8, 1956 that there is a very obvious 23 deletion of four or five inches or so in the <cMidtown ^Reporting cSczaice cR5o0e1kettOeirm, eicflcSuqiuaTre/or`Hi uiU1i4n6q14 87 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 A 18 19 20 Q 21 22 23 A middle of page 2 of those minutes. There is a partially visible 5 in the left-hand margin apparently marking paragraph 5 which has been blocked out. My best knowledge is that this is a copy of what we have in our office expressly, so that no question is raised, it is nothing that we have blocked out, and yet I leave open the fact that should anyone be Noc>'r\cx able to produce a bonlfled copy of the minutes of this meeting, that we will be happy to receive that as an exhibit or perhaps a supplemental exhibit which we could mark 6A for whatever value that is. My copy does not reflect paragraph 5, and I have no information as to what it is or how it got blocked out. I remember being at this meeting, but then you asked me do I recall these various items. My answer would be no. My concern, Mr. Houghton, is to determine do you recall any mention associating asbestos or asbestosis with lung cancer from the meeting? Oh, I think I 've absorbed that over the years. czMidtoivn <zRepoztiny cSezoice 501 `Jim ti Square 'Suifdiny cRoekeitet, cNeuj HJatl 14614 88 1Q What about in the time frame around March of 1956? Do 2 you recall having looked at this, and I don't mean to 3 try to ask do you remember everything, but I'm trying 4 to determine do you have any recollection as to whether 5 you had heard anything concerning the association of 6 asbestosis and lung cancer in the 1956 time frame? 7 MR. SHANNON: I object to the question because it's 8 been asked an answered at least two or three 9 times now, and the continued repetition of it 10 11 MR. GLASSER: 12 MR. SHANNON: is beginning to suggest an answer to him. I don't mean for it to do so. I know you don11 mean it . It's going 13 to have that effect if you keep asking it of 14 him. 15 Q Do you understand my question? 16 A I understand do I have that knowledge, but not -- I 17 don't recall when I got the knowledge. 18 Q Do you recall whether or not you would have received a 19 copy of the minutes of the meeting that you attended? 20 21 A 22 Q Wasn't that generally the practice of -- The practice would be about a month after the meeting. And was it your personal practice with regard to 23 meetings that you had attended to read or review the <cMidtourn czRepoztincj cSezaicc 50/ `Uimti cScjuatc CBuitehny <zRocfiitcit T/otf 14614 89 1 minutes that were sent to you? 2A Yes. 3Q And is it not more likely than not that you would have 4 received a copy of these minutes, and I'm referring to 5 Houghton Number 6 which has your name mentioned? 6 MR. SHANNON: I object. That calls for complete 7 speculation. He's he told you that he 8 remembers being at the meeting, but he can't 9 remember the specific topics. Now you're 10 11 12 Q 13 asking if he remembers receiving the document. That's a different question, but do you recall receiving a copy of these minutes? 14 A I recall receiving copies of minutes, yes. This 15 particular one, I canVgive you a positive answer. 16 Q Customarily when you did receive minutes, you would 17 review them? 18 A Yes. Years have goreby, 19 Q I understand that, I really do, Mr. Houghton, and I 20 know that the question is tough. You never had 21 occasion in reading minutes that you received from 22 ATI meetings to say well, that's wrong, that didn't 23 happen or make any correction to any minutes? cM idtotan cRepoztiny cSezaice 5 0 f 'Dima-/Ic/-S.y.,uanxeu *^tBuildlAinAytA 90 1A 2Q 3 4 5 6 7 8 9 10 11 A 12 Q 13 A 14 Q 15 16 17 A 18 Q 19 A 20 21 Q 22 23 No. Going to a different topic, Mr. Houghton, are you aware that in 1957 on November 14, 1957 a Worker's Compensation claim was filed by a lady by the. name of Grace Baylord claiming that she had either pulmonary fibrosis or pulmonary asbestosis and her job or work place was the textile department where she had been employed intermitently for 22 years during the 1923 to 1957 time frame? Do you remember or know Grace Baylord? Yes. That was hermarried name. Was she a worker under your supervision? Yes. Were you aware that in 1957 she filed a Worker's Com pensation claim against Garlock for pulmonary asbestosis? I think my answer would be yes. And you're aware that she was paid funds then? I don't recall seeing that report, but I know she filed a claim. Was she the first claim for asbestosis that you are aware of at Garlock or were there ones earlier than 1957? c M id to u m czR epoitincj S c za ic e 5 0 / Uinta cSquaze (Bui(diny 91 1A 2Q 3A 4Q 5A I can't answer that. You don't recall any before 1957? No, I don't recall any. Do you know what her job was in the textile department? I think she was a twister operator. Twister means a 6 machine that combines two or more threads together and 7 8Q 9 twists it. She was a twister operator. Did the twister have a local exhaust ventilation system? 10 A 11 12 13 No. The yarn is spun so it doesn't produce much dust, so the twister is relatively a clean machine. The spinning frame produced dust. That's the one I put machine dust recovery equipment on. 14 MR. GLASSER: Off the record. 15 16 Q 17 (Whereupon a discussion was held off the record.) What period of time did you attend the ATI meetings yourself? 18 A 19 Q 20 A 21 22 23 Most of the meetings from that date there. From 1956? '56. Most of time I attended up to 1970. I think that there were not many that -- I didn't attend one. There's one I did not attend was down in South Carolina. It was at a Hilton Head. <zMidtocan cRcpoxtincj cSezuice tiR5o0c/katSeJri,me<t zNeSuqJua^rIeJatJ^eBuil1d4ia6q14 92 1Q 2A They had approximately how many meetings a year? It was two, sometimes three. 3Q Did you serve on any committees? 4A Oh, yes, we would break up into committees, but I 5 haven't clear-cut records of committees I served on, 6 but we would have a general meeting, then we would meet 7 in groups, probably mostly reflecting that sections we 8 were involved in. 9Q Did anyone else attend meetings with you from Garlock? 10 A 11 Q 12 Yes. Who generally would attend with you or in addition to you? 13 A It was not always the same one. I can't give you 14 those names. I'd have to work on my memory, which 15 isn't very good. I can't give you a list of names. I S oc\V\ClW 0"\X\V 16 know that Gsdella Siama went with me in the latter part 17 because he came with us in 1967. 18 MR. SHANNON: Off the record. 19 (Whereupon a discussion was held off the record.) 20 Q I understood your testimony that starting with 1956 and 21 continuing through 1970 that you attended many of the 22 meetings yourself and you rarely missed any. 23 A Yes. aMidtoivn cRepoztiny cSezuice 501 'Dimes Square `Buifdiny cRoc&citctf <zNc\u J46t4 93 1Q 2 3A 4Q 5 6A 7 8Q 9A 10 Q 11 A 12 13 Q 14 A 15 Q 16 17 18 A 19 20 21 Q 22 23 The one that you missed was in Hilton Head, that your .aware of? That's the only one that stands out in my mind. And in addition to your attending, there were other people who would, on occasion, attend from Oarlock? Yes, there would be frequently there would be one other. Mr. Kuzmuk? Kuzmuk. Did Al Dayton ever go? I don't think Iremember Al Dayton being with me. He was on the safety committee. Did you go to any meetings of the ATI after 1970? I think not. When you went to meetings of the ATI between 1956 and 1970 and returned to Palmyra, to whom would you report what had happened at the meeting? It would only be the factory manager. Factory manager sometimes was the vice president, but it would be the factory manager that I would directly report to. And your position, Mr. Houghton, when you came in, you were initially, I believe you told us, a superintendent in the textile department? cM idtow n cRcpoztiny cSezaicc 5 0 / 'Dimes cSijuase 'S u itjin j cRocftestex, cffew H joti 146/4 94 1A 2 3 4 5 6 7Q 8 9A 10 11 Q 12 A 13 14 15 16 17 Q 18 19 A 20 Q 21 22 23 Up until 1958 and then they wanted me to go in the new missile department, so I was moved over to the engineering department from then on, I worked in the we. missile department and then fee- worked on development for Chevron and other products, probably mainly Chevron. Did you continue to have contact with those plants that were making asbestos-containing materials? When an Asbestos Textile meeting would take place, they'd ask me if I could go. And you would attend for the company? Yes. I was the -- up until -- now, that was -- yes, 1970. From then on, I didn't attend, but that was 1960 that I started working on engineering, but I was still more or less related to the textile departments, more or less consultant for textile problems. And still attending the Asbestos Textile Institute meetings? \ i Yes. I Is it fair to state that one of the topics that was discussed at many meetings was the health effect associated with exposure to asbestos and ways to control it dust? cfAidtown cRepoztinp cSezuicc 5 0 ! CJimCi tSguazt `Building cRockeitex, cMtut `IJozi 14614 95 1A 2Q 3 4 5 6A 7Q 8 9 10 11 12 A 13 14 15 Q 16 A 17 Q 18 A 19 Q 20 A 21 Q 22 23 Some, not all. It was discussed at some meetings but not all meeting. Did there come a time where you heard any discussion at the Asbestos Textile Institute about the need to place warnings on asbestos-containing products? I recall no discussion on warnings. After 1970, when you were no longer on the payroll but were serving as a consultant to Garlock, were you kept abreast as to dust counts that were going on at the plant and what the asbestos levels were in those dust counts? Only in discussions. We had developed a new plant and I was following that, Out in Sherbrooke. I was aware of what was happening there. Did you know who Mr. H.R. Hughes was? Hughes? That's not clear in my mind. Do you know who Mr. L . A . Green was? Green? Yes, sir. No. Are you aware as to whether or not Garlock was cited for any occupational safety and health violations in the 1972 time frame under the new OSHA law? cM idtoum aReportincj cSezuice oR5o0<//jeiUUitm, cs<zNcSewquatt CBui1fd4i6ng14 96 1A 2Q 3 4 5 6 7 8 9 10 11 12 13 A 14 15 Q 16 17 A 18 Q 19 A 20 Q 21 A 22 Q 23 I didn't hear of it. In your experience as an engineer, did you ever have occasion to use yourself or to hear of anyone else who used a t-f-ndl-o-beam lamp to help visual observation of dust movements, and what I'm showing Mr. Houghton as I speak is a letter dated August 18, 1972 from Turner Ca^OCVe Brothers Asbestos Company Limited to a Mr. D.J. KanrejL, Vice president International Operations, Garlock Inc., 1250 Midtown Tower, Rochester, which has a Garlock "received" stamp on it of August 31, 1972 with the notation "vice president engineering." You see the reference on page 2 of this letter? CoMsiWe I do not remember hearing of that. I knew that Kampd was president, but I did not hear of that. You never had occasion in evaluating any dust to use a TurAcAA fcxndie light -- No. -- to help you to see the dust or the fibers? Only thisBausch & Lomb. The Bausch &Lomnb counter that you described? That one. Mr. Houghton, when you were with Garlock, even in the very late 1930*a and 1940's, were you aware that the czMidtoixm cRepoitinq cSezaice 501 ZJimti cScjuate `ZBuifJing cRocftcitcx, c f/tw H/or* 14614 97 1 Garlock asbestos-containing products were going to be 2 used by various mechanics, asbestos workers, insulators 3 as a part of their day-to-day jobs? 4A 5 The products we made were not of the insulation type. t We made packing rings, gaskets. 6Q But you were aware that Garlock gaskets, for example, 7 would be used on ships to work with flanges and valve 8 covers? 9A Yes. 10 Q Were you aware that Garlock gasket materials were being 11 12 A sold to the government for use aboard ships? S0lju uoere. u & u When you racy you welcm aware, I was not connected with 13 the sales department. I knew gaskets were being made. 14 Q And did you know that gaskets were or some of the 15 gaskets would be used aboard ships? 16 A Well, just in conversation I would say I would assume 17 they would be, but I was not connected with sales. 18 Q Were you also aware that other materials, perhaps from 19 your days at Manville, were being used to go on pipes 20 21 A and boilers, turbines and heat-generating equipment? That type of product was made by Johns-Manville. 22 Q I understand. 23 A I knew that that was being made for boilers and ______________________________________________________ '_________i cJAidtoum (zRepoztincj cSezuice 50/ ^Jima cSV uaXc ^ u ifJin j <zRoc/iciUtr n jo ti 146/4 98 1 2Q 3 4 5A 6Q 7 8 9 10 11 12 .A 13 14 15 16 Q 17 18 19 A 20 Q 21 22 23 turbines. And did you also know that some of the gaskets that were being made by Garlock would also end up being used on boilers and turbines? Not then. I didn't even know who Garlock was. Let me clarify. Once you came to work for Garlock and you knew that they were making compressed gasket sheeting and gaskets, you were aware that some of the Garlock gaskets would be used on boiler and turbine couplings and on pipes leading off of boilers and turbines? List of names did not come to me in the textile department, but I knew Garlock was making gaskets. It was up to the sales department where they were to go to. And you knew that the Garlock gasket materials foreseeably could be used on all of these hot machine processes? My answer is yes. You also knew, did you not, that the gasket materials that Garlock was making, though new at the time that you manufactured them, ultimately had a limited life span when they were subjected to the high temperature czMidtcnun czRepoztinp cSezuice SOI Oimci cSguate 'Building cRochetiez, cNtui 'TJozl 14614 99 1 2 3A 4Q 5 6A 7Q 8 9A 10 Q 11 12 13 14 A 15 Q 16 A 17 18 19 Q 20 21 22 A 23 Q V'-N-YerAe^"? heats for which they were In-tondedcd? They would not last forever. Oh, I know that replacements are needed. You would be out of business if they did didn't need some replacements. I was not a maintenance man. I understand, but you knew that the materials o^eve ultimately to be replaced with new ones. That's almost an axiom. I agree, and you knew that where there were boilers or turbines that were insulated that not only would the insulation have to be replaced but that the gasket fittings would also have to be replaced. Nobody ever discussed that with me. But you are aware of that? No, I wasn't aware of it. I wasn't even thinking about it. How could I be aware of it when I didn't know where it was being used? What I'm trying to clarify is that you knew that the products, the gasket materials that Garlock was making ultimately would have to be replaced. Well, you said those words. Do you agree with me that -- cMidtoum csRepoztiny cSezaicc --SOI* dime) **Squatr-eIt S?Build.i.nq * i 100 1A I agree that generally things have to be replaced. 2 There's nothing that we make that's permanent. 3Q Are you aware that once a gasket had been subjected to 4 the intense heat of a boiler -- 5A What is intense heat? 6Q I can use a number of 600 pounds pressure upwards. 7A What is the temperature? 8Q 600 degrees upwards. 9A The asbestos would stand that, maybe not the rubber. 10 Q Well, that's helpful. Once your gasket material that 11 Garlock made the asbestos containing gaskets, whether 12 it was rubber jcoated or however it was coated, once it 13 had been subjected to high temperature, there would be 14 some deterioration of the carrier product, am I 15 correct? 16 A Probably. 17 Q Are you aware as to how mechanics in the field would 18 remove a worn out or burnt out or gasket that needed to 19 be replaced? Are you aware that they would use knives? 20 MR. SHANNON: I object now. Richard, you asked him 21 a question, now you're trying to go back and 22 23 MR. GLASSER: give him the answer. I have a right to ask questions as I czMidtoum czRepoztiny cSezulce 501 Uimci cSquaK Huiidiny cRodtcitei, cNew 4614 101 1 2Q 3 4 5 6 7A 8 9Q 10 11 A 12 Q 13 14 A 15 Q 16 17 A 18 19 20 21 22 Q 23 see fit and you have a right to object. Are you aware or did you understand that once gasket materials had been used and subjected to heat and had to be replaced, that workers sometimes would have to scrape or file or cut the gasket from the pipe or turbine -- I might ask you that question. How would you answer it? My question for you, Mr. Houghton, is were you aware of how the mechanics installed your product in the field? No. Were you aware of how they removed your products in the field? No. All you were aware of is that ultimately they would need replacement, am I correct? Placed another order. No, that kind of a question is not -- Most of us aren't concerned with that, then you say am I aware. No I wasn't aware, but I know that we've got a replacement order. That's up to the customer not me. I understand, I understand. The point I'm trying to get to, if we can assume that there would be a hazard cMidtoum cRepoztincj cSczuicc 501 `Jim a cSquate `Buitdiny cRokatci, cNeta njoxi 146/4 102 1 when the person who went to scrape an asbestos- 2 containing gasket off of a hot pipe had to remove the 3 old gasket so a new one with a good hot seam could be 4 replaced, whose concern was it at the Garlock 5 organization to make sure that the hazard was reduced 6 or that the people who would be remove the asbestos 7 gasket would be advised of the hazard? Whose 8 responsibility was that in the Garlock organization as 9 you remember it? 10 MR. SHANNON: I object to that question because it 11 implies that someone had a specific respon 12 sibility as you have exactly described it. 13 MR. GLASSER: Then I would amended my question. 14 Q Whose responsibility, if anyone, was that at Garlock? 15 A Not Garlock. How he gets it off there is not Garlock*s 16 responsibility and who was it deciding that it was 17 hazardous? If it's hazardous, why wasn't his director 18 taking care of it? 19 MR. SHANNON: He has to ask the questions and you 20 just have to respond. 21 A I'll leave you to think it out. 22 (Whereupon a brief recess was taken.) 23 BY MR. GLASSER: (Continued) czMidtoum cRepoztinq cSezuice tzR5o0c1AeiUteiim, eicNccSutjfuate xCBtuiid1i4n6y/4 103 1Q 2 3 4 5 6 7 8A 9 10 11 12 Q 13 14 A 15 16 17 18 Q 19 20 21 22 A 23 Q Mr. Houghton, to your knowledge, did Garlock ever go in and take any dust sample or dust counts of any of its asbestos-containing gasket material after it had been on a hot turbine or boiler for a long period of time for the purpose of determining how much asbestos dust was generated trying to remove and clean the pipe flange? I, not being in the sales department or where things were used, I couldn't answer that accurately. I don't remember anything like that being done, but as far as any report to me goes -- Who would be the best person whose available today for me to ask that question to? I don't know many people over there now. Sit down with Dick Watson and see if he can give you some guidance. He's closely associated with the people over there. He would be able to help you. Are you aware in the 1973 time frame of any surveys that were done either at Garlock or made available to Garlock concerning the awareness and attitude towards use of asbestos? No. This has, and I'm showing you a copy and your counsel, cM idtown cReportincj cSezuicc 50/ Uimei cSyuatt Huiidiny cRacficltd, cNtu} n /o tf 146/4 10,4 1 2 3 4 5A 6 7 8Q 9 10 11 12 A 13 Q 14 15 A 16 Q 17 18 A 19 Q 20 A 21 22 Q 23 A a received stamp from Garlock Inc. of June 11/ 1973 with the stamp of vice president of engineering and it's dated May 10, 1973. Have you ever seen this document or can you identify what that document is? I've never seen this kind of a report. I don't think there's 0vJe\s4 . occasionAor anyone to bring that report to me. I'm going to shift questions now to the state of Virginia. Do you know which salesman or sales representatives from Garlock had various or various distributors as their customers? No. Do you know the names of any distributors of Garlock products for the state of Virginia? No. Do you know who at Garlock was in charge of sales to the United States Government? When was that? At any time from 1939 to '79. Sales, our president was connected with sales and service, that was -- he died -- but he's dead. Is that Wes Wright? What? cM idtown czRepoztincj Sezaice 501 Oimei cScjuart cRochaUt, cNeui HJoti 14614 105 1Q Is that Wes Wright? 2A Wes -- 3Q Wright? 4A Oh, Wright? I don't remember that name. 5Q George Townsend? 6A Yes, he became president of the company. He was -- he 7 had, several jobs here at Oarlock. If you could locate 8 him, he could tell you some things. 9Q Are you aware, Mr. Houghton, that in 1977 a decision 10 was made at Garlock by the product liability committee 11 to put a warning on the asbestos-containing gasket 12 materials? 13 A No, I was not in that phase of the company, so I was 14 not aware of what warnings were being proposed. 15 Q Am I correct that in the field of compressed-gasket 16 sheeting, that Garlock was one of the major Sac-tote r , , . 17 juanu'facturco in the United States of compressed-gasket 18 sheeting? 19 A I can't say I was aware of that, but I just by my own 20 judgment, I would say that's probably so. Johns- 21 Manville was a producer of compressed sheet, too, but 22 Garlock probably is a larger producer than 23 Johns-Manvilie of that item. a M idtourn <zRepoztinp cSezoice cR5o0c1&etUUitm, ticNeeSutjjuaTre/ot`Biuild1i4n6g14 I * 106 1Q And Nicolet was a producer of that item, also? 2A Probably, yes. 3Q Do you have an opinion as to whether Garlock was also 4 larger than Nicolet? 5A I'm not aware of that, because I don't know how big 6 Nicolet was. 7Q Have you heard of or had any dealings with Carm Mango? 8A No. 9Q Kenneth Bowen? 10 A 11 Q 12 A Don't know the name. A Mr. C.C. Whiteside from the Department of Labor? No. 13 MR. GLASSER: I have no further questions and I want 14 to thank you for being so patient with me. 15 I'm very grateful. They might have some 16 questions for you, but I do want to thank 17 you. 18 19 EXAMINATION BY MR. SHANNON; 20 Q 21 22 I just have one question. Am I correct that you never did work directly in the making of compressed-asbestos sheet at any time during your career with Garlock? 23 A For about less than two years, I was given the job as-- cM idtovan cficpozting Service 50! `Ihmei cSejuare ^uifdiny cRoc&ittxf cN cuj H Joti 14614 107 1 for want of a better name-- supervisor of the general 2 packing division, and then after I had been in that, n 3 cHam-1no covered compressed-asbestos sheet and high- 4 pressure manufacturing, I was moved to the engineering 5 to start missile filament winding, and so I know what 6 they do there, but didn't stay with it very long, but 7 as you work in a plant for 40 years, you begin to get 8 acquainted with the whole works. 9 MR. SHANNON: That's all I have. 10 MR. GLASSER: And I have no further questions. 11 MR. SHANNON: We're going to ask that he read and 12 sign it so we won't have a waiver of 13 signature. 14 This young lady is going to type this 15 up in a little booklet of what we've said 16 today, and she's going to send it to you, and 17 we want you, if you would to be kind enough, 18 to be sure that she has typed it up 19 accurately. 20 THE WITNESS: She will read it to me? 21 MR. SHANNON: 22 23 Send it to you and you'll read it, and when you've read it, if she's made any mistakes, you'll have a sheet that you can cMidtourn czRepoztinp cSezutce 50t cStjUat* ^Buifdiny <zRochcjtct, <zN cuj n jo r t 14614 108 1 2 3 4 5 6 7 8 THE WITNESS: 9 MR. SHANNON: 10 11 MR. 6LASSER: 12 13 14 15 THE REPORTER: 16 17 18 19 MR. GLASSER: 20 21 22 23 make notes of the mistakes that she may have made. You cannot change your answers, but if she typed something down wrong, you can change that. After you've done that, you need to sign it in the presence of a Notary and have it sent back, and I'm sure Garlock can provide you with a Notary. Who would I return it to, Dick Watson? That will be fine, and he can send it back to her. Can you indicate responding for yourself on the record approximately how long it would take for the record to be prepared without any extra charges? It depends on if you're going to want me to send your copies out at the same time or if you want me to hold all of them until he sends his back. I would request that you do exactly as you've indicated, namely, to send a copy of the transcript once it's prepared to be sent to Mr. Houghton to me, and I understand Jim Shannon and to Mr. Levinthal cM idtown czRepoTtiny cSctaice SOI Uimei cScjuate `BuifJiny /-Rnrticitiz. cNc\o nUori 14614 109 1 at that stage, and then if there are any 2 errata changes that you feel are appropriate, 3 you can send us a copy of the errata sheet 4 once that's returned and perhaps a signed 5 cover sheet, signed by Mr. Houghton so that 6 we'll have an opportunity to review our copy 7 instead of waiting until everything is done 8 at your end. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 cMidtoum czRepoztinj Sczuice. SOI Utmei iSquate Huildtny cRocfititc*, cMcw n jo ti 14614 110 1 WITNESS CERTIFICATION 2 3 I, GEORGE ELWOOD HOUGHTON, do hereby certify that I have 4 read the transcript of my testimony taken under oath on the 5 4th day of December, 1986; 6 that my testimony in the transcript herewith, pages 1 7 through 109 is a true, complete and correct record of what 8 was asked, answered and said during the deposition; 9 and that the answers on the record as given by me are 10 true and correct, except for anything duly noted on the 11 attached errata sheet. 12 13 14 15 GEORGE ELWOOD HOUGHTON 16 17 Subscribed and sworn to before me 18 this ___ day of ___________ . 1986. 19 20 21 22 My C o m m is s io n E x p i r e s : NOTARY PUBLIC 23 March __ , 19____ . M U , R.Portiny iioo 5!rrUi QvuLliAtj ^ochtiLtr, t'farL PI* 1 1 1 3^+ 1 3 Fourth wor d should be - moment - 8'7 9 F i f t h w o r d s.hould b e two w o r d s - b o n a fide - 89 1 5 Fourth word should be - can't - 8'9 1 8 Fourth w o r d 'should be - gone - 9-2 1t Third and fourth words should-be - Sudhakar Dixit 9 `it Fifth word should be - we - 95 12 Seventh word should be - Sherbrooke - 96 7&13 Last word of each line should be - Camille - 96 4&16 Words three a nd one s h o u l d be - T y n d a l l - 97 12 T h i r d to s i x t h w o r d s s h o u l d b e - s ay " w e r e y o u a w a r e " - 99 1 Sixth wor d should be - intended - 99 7 I believe - were - should be inserted at the end of the line. 104 104 105 105 107 6 Second word should be - any 6 Fourth word should be - for 7 First word should be - had 17 F i r s t w o r d s h o u l d b e - m a n u f a c t u r e r s *: T h e wo-rd .'.'examine" d o e s n o t m a k e s e n s e - I d o n o t r e c a l what was said. 79 2-5 U p o n literal r e v i e w of the q u e s t i o n as transcribed, I believe that my proper answer would-have been "Yes" . I did not see warnings on Garlock products between 1939 and 1979. ' * __________________ :_____________ G E O R G E E L L W O O D H O U G H T Q E -------------- Dated this day of , 19 ...... . / errata sheet ?>tt Lint 3 23 29 29 29 29 33 33 34 34 34 35 36 37 42 42 45 47 50 61 62 '62 63 63 63 7( 70 75 77 80 4 ,and several o ther places) Mv m i d d i p n s m e is Ell w o o d . 23 Last w o r d -should be - their - 5 Seventh word should be - solution - 6 Seventh word should be - tower 11 F i f t h w o r d s h o u l d be - calender - 14 T h i r d and fourth words should be - this was - 5 Word seven and eight should be - and hand - 6 First word should be - hole - 4 Tenth word should be - 64th - 5 Sixth word should be - 8th - 6 Sixth word should be - an 8th - 9 End of sentence should read - packing for power plants. 1 Third word should be - calender - 2 First word should be - Chrysotile - 9 The numeral should be - 7,000's - 11 F i r s t w o r d s h o u l d be h a v e - ......... 3 First word should be - departments - 10 S e c o n d - w o r d s h o u l d be - T h e r e - 12 T h i r d w o r d s h o u l d be - i d e n t i f y - 23 Seventh w ord should be - appropriate - 12 E i g h t h w o r d s h o u l d b e - m a g n i f y i n g 12 L a s t w o r d s h o u l d b e - s a m p l e - 5 Fifth word should be - had - 5 Tenth word should be - had 5 Eleventh word 'should be deleted. 8 Sixth word should be - Hemeon - 18 F o u r t h w o r d s h o u l d b e - d e t a i l - 1 First word should be - record 1 Fifth word should be - McMullen - 6 Believe that third word was - inhalation - GEORGE ELLWOOD HOUGHTON Dated this , dav nf . ... t 19 / ERRATA SHEET / 111 1 STENOGRAPHER'S CERTIFICATION 2 3 I, CAROL PIENDEL RAES, do hereby certify that I am a 4 Court Reporter in Rochester, Monroe County, New York; 5 that I reported in Stenotype shorthand the proceedings 6 held on December 4, 1986 at the home of GEORGE ELW00D 7 HOUGHTON, 516 West Main Street, Palmyra, New York in the 8 matter of William Stacey Overby, Plaintiff versus Garlock 9 Inc., Defendant; 10 that the witness, GEORGE ELW00D HOUGHTON, was duly sworn 11 by me; 12 and that the transcript herewith numbered 1 through 109 13 is a true, accurate and correct record of said shorthand 14 notes. 15 16 17 18 19 CAROL PIENDEL RAES 20 21 22 Dated at Rochester, New York 23 this 16th day of December, 1986. FATUI * MF. CO., U JU HV IIA *. KV. PAO* Link LAWYER'S NOTES ' . c ,V- s W ILLIA M A. M AY. C S B . DAVID E. EITCH. C.S R R ICH ARO N. SU TER A. C S R. M id to w h K e p o rtin g S e rv ic e 1100 TIMES SQUARE BUILDING ROCHESTER. NEW YORK 14614 (716) 325-2130 (716) 325-2131 FED.-I D.16-1135023 December 15, 1986 R AYM O N O A MICHEL O O N A L O R FIORINI. C.S.R. SEYM O UR OISRAELY. C S R R O N A LD J. TETTE. C.S.R. George Elwood Houghton 516 West Main Street Palmyra, New York 14522 Re: Transcript in the matter of William Stacey Overby, Plaintiff versus Garlock Inc., Defendant. Dear Mr. Houghton: Enclosed is the original copy of the transcript of the deposition which you gave on December 4th, 1986 regarding the above-captioned litigation. Please review your testimony found on pages 3 through 109 noting any changes or corrections on the attached errata sheet, found after page 110, your witness certification sheet. Also sign all three (3) witness certification pages, as well as the one enclosed in the transcript. After doing so, please return the transcript to me at the above address. Thank you for your consideration in this matter. Very truly yours, TOWN REPORTING SERVICE Enclosures cc: J. Shannon, Esq. R. Glasser, Esq. B. Levinthal, Esq. Carol Piendel'Raes