Document rp5b183xgB3NG7wEOoE6YZNdE
UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF WEST VI#<JIt*IA
FILER 0
ft,
BARBARA CANTWELL CHRISTMAN, et al. ,
Plaintiffs,
v. AMERICAN CYANAMID COMPANY,
Defendant.
) ) )
)
)
) ) Civil Action ) No. 80-0024-P )
) )
)
DEFENDANT AMERICAN CYANAMID COMPANY'S FIRST SUPPLEMENTAL AND AMENDED NONCONFIDENTIAL RESPONSES TO PLAINTIFFS' SECOND INTERROGATORIES
Pursuant to the Court's Order entered on January 18, 1983 and pursuant to Federal Rules of Civil Procedure 26(e) and 33, defendant provides the following First Supplemental and Amended Nonconfidential Responses to Plaintiffs' Second Inter-
roga. tori. es. 1/
*J Assisting in the compilation of material used in the
preparation of the first supplemental responses to Plaintiffs'
Second Interrogatories were: C. Ballard, J.C. Caporossi, R. Heilman, W. Fead, G.E. Mercer, P. Shopene, J. Tobin, J. Noble, R. Smith, J. Calitri, M. Friedman, C. Peterson, R. Clyne, L. Long, H. Kiltie, W. Andresen, H.C. Gaffney, J.
White, and H.M.D. Utidjian.
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In addition, to the best of Cyanamid's knowledge the
following identifies permanent and temporary female laboratory
workers who, since 1970, routinely ran pigments process samples
in the laboratories during the dates and for the percentage of
time stated below:
Name
Date
Percentage of Time*/
Linda L. Hall
5/28/74 - 8/9/74 5/24/76 - 8/20/76
80-90% 56-63%
Cathy J. Radcliffe
6/7/76 - 7/30/76
40-60%
Lisa R. Smith
6/1/78 - 8/15/78
10-15%
JoAnn Stewart
2/1/76 - 11/1/77 7/16/79 - 5/1/80
10-15% 10-15%
Mary Anne Chambers (Poole)
7/16/79 - 5/1/80
10-15%
Deborah C. Allen
5/1/74 - 5/1/75
80-90%
Pavanne P. Canary
8/23/73 - 5/16/74
80-90%
Terrie L. Davis (Piersol)
10/25/77 - 9/16/78
80-90%
Sharon A. Czajkowski 9/1/78 - 4/1/80
10-15%
The percentage of time exposed to lead is an estimate based upon the knowledge of plant personnel of the laboratory positions held by these persons and the processes they were required to perform while holding those positions.
c. To minimize exposure to lead and lead chromate, the importance of good personal hygiene was reinforced through periodic safety meetings and close
_*/ No routine lead or lead chromate exposure occurred after the Pigments Department closed in January 1980.
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Name Mary A. Cottle Deborah A. Short Brenda K. Sams JoAnn Stewart Virginia E. Davis Sally A. Whited Mary Anne Chambers (Poole) Linda L. Hall
Penny K. Northcraft Cathy J. Radcliffe Lisa R. Smith JoAnna L. Rose Deborah C. Allen Pavanne P. Canary Terrie L. Davis (Piersol) Rozella R. Baum
Sharon A. Czajkowski Sally L. Demyan Denise A. Tillery (Robinson) Rebecca D. Garst (Cutlip)
Dates*/ 6/6/77 - 8/11/77 6/13/77 - 8/5/77 6/10/74 - 8/8/75 8/11/75 - 5/1/80 2/16/78 - 1/14/80 9/16/78 - 11/1/80 2/16/78 - 5/1/80 5/28/74 - 8/9/74 5/24/76 - 8/20/76 6/19/79 - 8/15/79 6/7/76 - 7/30/76 6/1/78 - 8/15/78 6/1/76 - 9/30/76 5/1/74 - 5/1/75 8/23/73 - 5/16/74 10/25/77 - 9/16/78 6/16/77 - 4/1/79 7/16/79 - 11/1/80 6/7/76 - 4/1/80 2/9/76 - 4/30/76 6/1/76 - present 7/22/74 - 1/1/81
*J No lead and lead chromate analysis occurred routinely
after the Pigments Department closed in January 1980.
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e. See response to Interrogatory 25 (i), part II (A-D). Cyanamid's health professionals also relied on informa tion obtained in the course of their professional experience.
49. Identify all female laboratory workers at Willow Island who, since 1970, were routinely exposed to lead or lead chromate. For each such worker:
a. state the inclusive dates of employment in the laboratory;
b. state the percentage of time exposed to lead or lead chromate and explain in detail the method for calculating this percentage;
c. describe in detail any actions taken by Cyanamid to reduce exposure to lead and chromate; and
d. describe all tests and studies monitoring expo sure to lead and chromates including, without limitation, air sampling, blood testing and physical examination; state the frequency of each such test or study, and identify all documents containing the results of each such test or study.
Answer: a-b. To the best of Cyanamid's knowledge, the following identifies permanent and temporary female laboratory workers at Willow Island who, since 1970, were assigned to laboratory areas where lead and lead chromate analysis occurred routinely and the dates during which they were assigned to those laboratory areas.