Document rpDZM9D8QzBqrJqOB0LRe3Rbq

FILE NAME: BF Goodrich (BFG) DATE: 2002 DOC#: BFG055 DOCUMENT DESCRIPTION: Legal - Defendant's Responses to Interrogatories Subject: Goodrich From : Michael Shepard <mshepard@shepardla\vlirm.com> D ate: Wed, 23 A pr 2008 17:49:14 -0400 To: "Barry Castleman (baiTy.castleman@gmail.com)" <barry.castleman@gmail.com> Barry, Here is some Goodrich discovery from Rhode Island. Attached as Exhibit F to the discovery answers is a list of publications to which Goodrich subscribed. Attached as Exhibit A is a list of medical employees of Goodrich over the years. I hope this helps your research project. Best regards, Mike 1 of 1 4/24/2008 8:37 AM. 1 WILLIAM G. HOBACK, ESQ., Bar No:088655 JOSEPH J. MINIOZA, ESQ., Bar No!'197379 2 VANESSA JARVIS, ESQ., Bar No. 201585 . CHASTINE A. FISH, ESQ., Bar No. 206663 3 ERICKSEN, ARBUTHNOT, KILDUFF, DAY & LINDSTROM, INC. 530 Water Street, Suite 720 4 Oakland, CA 94607 - (510) 832-7770 5 Attorneys for Defendant, ECEIVED 6 GOODRICH CORPORATION rLbF2 5 2002 7 KAZAN,McO^W, EDISES,ABRAM& FERNANDEZ, CYONS&FARRJSE 8 9 10 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO 11 ' : UNLIMITED JURISDICTION 12 IN RE: ) No.: 828684 13 . ) ) DEFENDANT GOODRICH 14 COMPLEX ASBESTOS LITIGATION ) CORPORATION'S RESPONSES TO 15 ) GENERAL ORDER NO. 129 ) INTERROGATORIES 16 ________________________________________________________________________________________________________________________________ ) 17 COMES NOW, the defendant, GOODRICH CORPORATION, and pursuant to San 18 Francisco Superior Court General Order No, 129, answers the interrogatories propounded to 19 20 it as follows. 21 Defendant and its attorneys have not completed their discovery or preparation for 22 trial, nor have they completed their analysis Or review of the investigation and other trial 23 preparation matters and subjects obtained conducted to date. These answers, therefore, state 24 the present information and analysis of the defendant and its attorneys as acquired and 25 26 reviewed to date, without prejudice and to-defendant's right to present additional facts, 27 contentions or theories at the trial based on information evidence or analysis hereinafter 28 obtained or evaluated. The following answers state the information, facts, evidence, and -1 Responses to General Order 129 Interrogatories - 2002 1 contentions presently known to and evaluated by defendants and its attorneys. The following 2 answers at this time are preliminary only in light of the severe time constraints placed upon 3 : defendant by plaintiffs in responding to these detailed interrogatories which seek information 4 5 from many sources over one hundred years. These answers to interrogatories are an ongoing 6 project and most likely will change as more information is discovered and reviewed Over 7 the years this defendant has acquired a number of smaller companies whose product lines 8 may have discontinued many years ago. The information regarding those prior products, 9 from years past, is limited if not totally non-existent. Defendant and its attorneys are 10 11 attempting to go back in time through various avenues to obtain as much information as is 12 possible. As that information comes to light, these answers will then be supplemented and 13 modified accordingly. Therefore, these answers should not, and cannot, be construed as final 14 or complete answers to any of the questions posed, 15 RESPONSE TO INTERROGATORY NO. 1: 16 17' Jerry A. Smith, consultant to the Goodrich Corporation, do Canal Place Ltd. 520 18 South Main Street, Suite 2511, Akron, Ohio 443311-1010. 19 RESPONSE TO INTERROGATORY NO. 2: 20 Objection. Defendant objects on the grounds that this interrogatory is overly broad, 21 unduly burdensome and irrelevant to any issue in this case not reasonably calculated to lead 22 23 to discovery o f admissible evidence. Notwithstanding this objection, Defendant answers as 24 follows: Mr. Smith began his employment with fee Goodrich Corporation on January 15, 25 1959. He held clerical position in fee mail and telecommunication department s until 1964. 26 From 1964 to 1974, Mr. Smith held supervisory and management position in fee 27 telecommunications department In 1974, he was appointed director, MIS 28 -2 Responses to General Order 129 Interrogatories - 2002 1 Telecommunications. In 1981, Mr.JSmith was appointed director of Administration and 2 Information Services Support and in 1982 was appointed director of Administrative Services. , ' * . ' 3 Mr. Smith retired from the Goodrich Corporation on February 1,1990. He has been a 4 5 consultant for Goodrich since February 1,1990. 6 RESPONSE TO INTERROGATORY NO. 3: 7 Yes. . . 8 A) Goodrich Corporation; . 9 B) New York; 10 11 C) May 2, 1912; 12 D) Four Coliseum Centre, 2730 West Tyvola Road, Charlotte, North Carolina 28217; 13 E) Yes. August 1,1934 to date; . 14 F) Not applicable. 15 G) Ther are several Goodrich plants located in California. Goodrich Corporation's 16 17 principal place o f business is Four Coliseum Centre, 2730 West Tyvola Road, Charlotte, 18 North Carolina 28217 ' 19 RESPONSE TO INTERROGATORY NO. 4: 20 Yes. ' 21 RESPONSE TO INTERROGATORY NO. 5: 22 23 Goodrich started in 1879 when it formed the partnership of Goodrich, Tew & Co. In 24 1874, the partnership changed to the name B.F. Goodrich & Co, On May 10,1880, B.F. 25 Goodrich transformed the partnership into an Ohio-chartered corporation until such time that 26 it was reincorporated as a New York business on May 2,. 1912. The company name had 27 28 remained the same until June 1, 2001, when it changed its name to Goodrich Corporation. -3 - _ . Responses to Gemerai Order 129 Interrogatories - 2002 - 1 RESPONSE TO INTERROGATORY NO. 6: 2 Not applicable. 3 RESPONSE TO INTERROGATORY NO. 7; 4 Not applicable. . 5 6 RESPONSE TO INTERROGATORY NO. 8: 7 Not applicable. 8 RESPONSE TO INTERROGATORY NO. 9: 9 Mr. Smith, previously identified in interrogatories 1 and 2, has access to relevant 10 11 business records at the company. 12 RESPONSE TO INTERROGATORY NO. 10: 13 Defendant is unable to fully and completely respond to this interrogatory at this time 14 as no available dates have been forth encompassing the requested period for information and 15 defendant's investigation and discovery have not yet been completed. However, based on 16 17 information available to date, defendant responds as follows: 18 A. Goodrich Corporation has no current employee with this knowledge, however, 19 20 21 . 22 23 Mr. Smith, previously identified has researched and is familiar with this subject. B. With respect to certain aircraft brake products designed, manufactured and sold by the company, Roland E. Cecil, Supervisor Configuration Control with the Goodrich Aerospace Landing Systems, in Troy, Ohio. Mr. Cecil has worked for the Goodrich 24 Corporation since 1958. . 25 C. Not applicable. Discovery is continuing. 26 RESPONSE TO INTERROGATORY NO. 11: 27 28 Goodrich object to this interrogatory on the ground that it is overly broad, unduly burdensome, irrelevant to any issue in this case and not reasonably calculated to lead to . ' -4 - _ Responses to General Order 129 Interrogatories - 2002 . 1 discovery ofadmissible evidence. To require Goodrich to identify the medical directors, 2 industrial hygienists and physicians it has employed over the years constitutes a request for 3 masses of irrelevant information, is unduly burdensome and beyond the scope o f permissible 4 discovery. Without waiving said objection, defendant responds as follows: Defendant is 5 unable to folly and completely respond to this interrogatory at this time as discovery and 6 investigation are continuing. However, based upon available discovery which has been done 7 to date, defendant responds as follows: for the period 1930 to 1985, the following 8 physicians, medical directors and/or industrial hygienist were employed by the Goodrich 9 Corporation set forth in Exhibit A attached. 10 RESPONSE TO INTERROGATORY NO. 12: 11 Yes. Please see listing of those employees who have given testimony while 12 employed by Goodrich which is attached hereto as Exhibit B. . 13 RESPONSE TO INTERROGATORY NO. 13: 14 15 Goodrich objects to this interrogatory as being overly broad, unduly and unreasonably 16 burdensome.and oppressive and not calculated to lead to the discovery of admissible 17 evidence in that this interrogatory requests information readily accessible to plaintiff from 18 sources other than this defendant. Moreover, Goodrich Corporation never engaged in the 19 marketing of any raw asbestos. Without waiving said objections, Goodrich has, at times, 20 21 belonged to the Industrial Hygiene Foundation and/or Industrial Health Foundation, the 22 National Safety Council, the American Industrial Hygienists and Resilient Floor Covering 23 Institute) or any other name in which it has existed). 24 RESPONSE TO INTERROGATORY NO. 14. 25 26 American Industrial Hygiene Association 27 A. 1975 to the present; personal membership; never a corporate membership. 28 ' B. AfflA Journal. -5 Responses to General Order 129 Interrogatories - 2002 1 C. To our knowledge, none. 2 National Safety Council. 3 A. 1975 to the present; personal membership; never a corporate membership. 4 5 B. Unknown; discovery is continuing; 6 C. None, based, upon this defendant's current corporate knowledge. 7 American Industrial Hygienists\ 8 A. Unknown. 9 B. Unknown. . 10 11 C. Unknown . 12 Resilient Floor Covering Institute. 13 A. Unknown. 14 C,. Unknown. 15 C. Unknown 16 17 RESPONSE TO INTERROGATORY NO. 15: 18 . No, based upon this defendant's current corporate knowledge. 19 RESPONSE TO INTERROGATORY NO. 16: 20 No, based upon this defendant's current corporate knowledge. 21 RESPONSE TO INTERROGATORY NO. 17: 22 23 No. based upon this defendant's current corporate knowledge. 24 RESPONSE TO INTERROGATORY NO. 18; 25 Goodrich objects to this request on the grounds that it is overly broad and 26 burdensome and that it seeks information not relevant to the subject matter o f the information 27 28 not relevant to the subject matter of the litigation and which is not likely to lead to admissible -6 - _ Responses to General Ordr 129 Interrogatories - 2002 .. 1 evidence, in that not all such libraries and/or collection of books and publications would have 2 any relevance to the case at bar 3 Notwithstanding fee foregoing and without waiving any applicable objections, 4 5 Goodrich has maintained several libraries since the Company was formed in 1870, each with 6 many collections o f books and publications. Certain Company libraries, which may have 7 been in existence since 1920, have been closed. Certain company libraries may have been 8 closed or sold along with other various business entities. 9 RESPONSE TO INTERROGATORY NO. 19: 10 11 No, based upon this defendant's current corporate knowledge. 12 RESPONSE TO INTERROGATORY NO. 20: 13 No, based upon this defendant's current corporate knowledge. 14 RESPONSE TO INTERROGATORY NO. 21 : 15 Defendant believes fee answer is yes based on current corporate knowledge. 16 17 A. . 500 South Main Street, Akron, Ohio; and Marion, Ohio, both of which were 18 shut down quite sometime ago. 19 B. Accordingly, documents responsive to this interrogatory, if any exist, can be 20 made available for inspection at defendant's offices were fee documents are kept, at a mutual 21 convenient time during regular business hours. Defendant has not done a separate 22 23 compilation o f the information requested and any such information would exist in any 24 remaining existing documents from these locations. 25 C. Accordingly, documents responsive to this interrogatory, if any exist, can be 26 made available for inspection at defendant's offices were the documents are kept, at a mutual 27 convenient time during regular business hours. Defendant has not done a separate 28 . . - -7- Responses to General Oder 129 Interrogatories - 2002 1 compilation of the information requested and any such information would exist in any 2 remaining existing documents from these locations. 3 D. Accordingly, documents responsive to this interrogatory, if any exist, can be 4 5 made available for inspection at defendant's offices were the documents are kept, at a mutual 6 convenient time during regular business hours. Defendant has not done a separate 7 compilation of the information requested and any such information would exist in any 8 remaining existing documents from these locations. 9 E, Accordingly, documents responsive to this interrogatory, if any exist, can be 10 11 made available for inspection at defendant's offices were the documents are kept, at a mutual, 12 convenient time during regular business hours. Defendant has not done a separate 13 compilation of the information requested and any such information would exist in any 14 remaining existing documents from these locations. 15 RESPONSE TO INTERROGATORY NO. 22: 16 17 No, based upon this defendant's current corporate knowledge. 18 RESPONSE TO INTERROGATORY NO. 23: 19 Defendant is not aware o f any such tests or studies at this time, however, discovery is 20 continuing. . 21 RESPONSE TO INTERROGATORY NO. 24: 22 23 Yes. . . ' 24 A. Yes. . 25 B. See copy of the Goodrich policy OHP001.3.10, Exhibit D. 26 C. See copy of the Goodrich policy OHP001.3.10, Exhibit D. 27 D. Dr. Ray Bennea. (No longer employed by Goodrich) 28 -8 Responses to General Order 129 Interrogatories - 2002 1 RESPONSE TO INTERROGATORY NO. 25: 2 Goodrich objects to this interrogatory on the grounds that the information sought is 3 irrelevant in this case and is not reasonably calculated to lead to discovery o f admissible 4 evidence. The plaintiff has never been a Goodrich employee and does not allege ever 5 6 visiting any Goodrich facility. Notwithstanding this objection and without waiving any 7 applicable objections, the defendant responds as follows: No, based upon this defendant's 8 current corporate knowledge. 9 RESPONSE TO INTERROGATORY NO. 26: 10 11 See attached listing of liability insurance carriers that is attached hereto as Exhibit C. 12 RESPONSE TO INTERROGATORY NO. 27: 13 No, based upon this defendant's current corporate knowledge. 14 RESPONSE TO INTERROGATORY NO. 28: 15 No, based upon this defendant's current corporate knowledge. 16 17 RESPONSE TO INTERROGATORY NO. 29: 18 Not applicable. 19 RESPONSE TO INTERROGATORY NO. 30: 20 Yes. 21 A. Yes, based on available records from 1939 to 1985 22 23 Bi No, based upon this defendant's current corporate knowledge. 24 C. See subpart A above. 25 JD. See subpart A above. 26 E. See subpart A above. 27 28 F. Unknown. - 9- Responses to General Order 129 Interrogatories - 2002 1 G. See subpart A above. . 2 H. No, based upon this defendant's current corporate knowledge. 3 Discovery is continuing. 4 RESPONSE TO INTERROGATORY NO. 31: $ 6 Defendant is unable to fully and completely respond to this information because of 7 the extensive time period to which these interrogatories pertain. Only limited information is 8 still available. Notwithstanding this difficulty and without waiving any applicable objections 9 and the fact feat investigation and discovery are still continuing, defendant responds as 10 11 follows: See Exhibit E attached. 12 RESPONSE TO INTERROGATORY NO. 32 (PREMISES DEFENDANTS onlvl 13 Not applicable. 14 RESPONSE TO INTERROGATORY NO. 33 (CONTRACTOR DEFENDANTS onlvl: 15 Not applicable. 16 17 RESPONSE TO INTERROGATORY NO. 34: 18 Goodrich Corporation has never manufactured or distributed any raw asbestos. Wife 19 respect to exclusive distributorship, defendant responds as follows: No, based upon this 20 defendant's current corporate knowledge. 21 RESPONSE TO INTERROGATORY NO. 35: 22 23 From approximately 1955 to 1976, Goodrich Corporation manufactured an asbestos^ 24 containing adhesive known as "R-907-T" and "pennate" and placed the adhesives in drums 25 and pails for Lexsuco, Inc. with "Lexsuco" labels. The products were not rebranded per se. 26 Lexsuco, Inc. purchased the adhesives from Goodrich and Goodrich packaged the adhesives 27 28 -10Responses to General Order 129 interrogatories - 2002 1 in drum and pails bearing the name "Lexsuco." Lexsuco became part of Goodrich 2 Corporation in 1976. 3 RESPONSE TO INTERROGATORY NO. 36: 4 5 Not applicable. 6 RESPONSE TO INTERROGATORY NO. 37: 7 To the best of defendant's knowledge and believe, no. 8 RESPONSE TO INTERROGATORY NO, 38: 9 Goodrich objects to this interrogatory for the reason that the only products at issue in 10 11 this case ar those to which plaintiff alleges to have been exposed. To require Goodrich to 12 identify any logo, design, marking or printing for every product it has sold and/or distributed 13 over the years constitutes a request for masses o f irrelevant information, is unduly 14 burdensome and beyond the scope of permissible discovery. 15 ' Notwithstanding this objection, defendant responds as follows: Goodrich's name, 16 17 trade name and/or logo may have appeared on certain asbestos-containing sheet rubber and 18 hose products. 19 RESPONSE TO INTERROGATORY NO, 39: 20 Defendant is unable to fully and completely respond to this interrogatory as discovery 21 22 is continuing. However, based upon discovery to date, responding party answers in 23 approximately the 1940's defendant acquired an asbestos containing asphalt floor tile product 24 from Hood Rubber in Watertown, Massachusetts. Additional information is no longer 25 available. 26 RESPONSE TO INTERROGATORY NO. 40: 27 28 No, based upon this defendant's current corporate knowledge. . -11- Responses to General Order 129 Interrogatories - 2002 1 RESPONSE TO INTERROGATORY NO. 41: 2 Goodrich Corporation has never manufactured, sold, or distributed raw asbestos 3 material. With respect to asbestos-containing products listing in Exhibit E, various 4 5 documents currently exist but generally consist of catalog listing, advertising, price list, etc. 6 The printing dates vary. See Exhibit E for information concerning location and the 7 custodian of records. 8 In addition, any answer to this interrogatory would require a compilation of 9 documents which do not exist. It would not be substantially less expensive for responding 10 11 party to make this compilation that it would be for the party propounding the interrogatories 12 to do so. Accordingly, the documents responsive to this interrogatory that have been located 13 can be made available at the corporate office of the Goodrich Corporation. 14 RESPONSE TO INTERROGATORY NO. 42: 15 No, based upon this defendant's current corporate knowledge. 16 17 RESPONSE TO INTERROGATORY NO. 43: 18 No. Subparts (A) through (D) are not applicable. ' 19 RESPONSE TO INTERROGATORY NO. 44: 20 Goodrich has in its Industrial Hygiene Library some publications which suggest a 21 relationship between asbestos exposure and asbestos dated in the 1930s. An awareness of a 22 23 possible relationship between asbestos exposure and the occurrence of mesothelioma and 24 some lung cancers existed in the Industrial Hygiene Department since 1976, but defendants 25 do not know when the awareness may have exited prior to 1976. . 26 27 an 28 ////. . -12Responses to General Order 129 Interrogatories - 2002 1 RESPONSE TO INTERROGATORY NO. 45: 2 Goodrich had in its library publications about the relationship o f disease to exposure 3 to asbestos. 4 5. RESPONSE TO INTERROGATORY NO. 46: 6 See the list of publications from defendant's Industrial Hygiene Library, attached 7 hereto as Exhibit F. . 8 RESPONSE TO INTERROGATORY NO. 47: 9 Defendants have been unable to locate any documents regarding when Goodrich 10 11 Corporation first warned its employees that exposure to asbestos could be hazardous to 12 human health, however, it is believed that subsequent to the regulations issued following the 13 institution of OSHA, Goodrich Corporation complied. 14 RESPONSE TO INTERROGATORY NO. 48: 15 Goodrich objects to this interrogatory on the grounds that the information sought is 16 irrelevant in this case and is not reasonably calculated to lead to discovery o f admissible 17 evidence. The plaintiffhas never been a Goodrich employee and does not allege ever visiting 18 any Goodrich facility. Notwithstanding this objection, defendant responds as follows: No, . 19 based on this defendant's current corporate knowledge. 20 RESPONSE TO INTERROGATORY NO. 49: 21 22 No, based upon this defendant's current corporate knowledge. 23 RESPONSE TO INTERROGATORY NO, 50: 24 No, based upon this defendant's current corporate knowledge. 25 RESPONSE TO INTERROGATORY NO. 51: 26 .Not applicable. . 27' 28 HU -13Responses to General Order 129 Interrogatories - 2002 1 RESPONSE TO INTERROGATORY NO. 52: 2 Not applicable.. 3 RESPONSE TO INTERROGATORY NO. 53; 4 No, based upon this defendant's current corporate knowledge. 5 6 DATED; February 21,2002 7 ERICKSEN, ARBUTHNOT, KILDUFF, DAY & LINDSTROM, INC. ' 8 9 WILLIAM G. HOBACK1 10 CHASTINE A. FISH 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 14Responses to Genera] Order 129 Interrogatories - 2002 1 2 STATE OF OHIO 3 COUNTY OF SUMMIT VERIFICATION 4 I hereby certify that I am authorized to respond to Plaintiff's Interrogatories, on behalf of Goodrich Corporation, in my 5 capacity as Consultant ~ Special Projects, and that to the extent that I am personally familiar with the information set 6 forth in these answers, I certify that the answers are correct, and to the extent that I am not personally familiar with the 7 information provided in the said answers, I cetify that the information is correct to the best of my in^rm^tin and belief 8 based on my investigation of. 9 10 11 Sworn to before me this J day. o f , 2002. , 12 13 14 15 MARYJ . MILLER, NOTARY PUBLIC RESIDENCS-WAYNECOUNTY 16 STATEWIDEJURISDICTION, OHIO MYCOMMfSSiQN EXPIRESFEB-9,2005 17 18 19 20 21 22 23 24 25 26 27 28 1 declaration of service b y mail 2 3 I the undersigned, hereby declare: . 4 1. Iam over the age of 18 years, employed in-the county o f Alameda, and not 5 a party to the within action. My business address is 530 Water Street, #720, Oakland, 6 California, 94607. v 7. 2. I am readily familiar with our business' practice for collection and 8 processing o f documents for mailing with the U.S. Postal Service, and that the below-named 9 document will be deposited with the U.S. Postal Service with folly prepaid postage thereon 10 on the date set forth below at Oakland, California. 11 3. On the date set forth below I served the within DEFENDANT 12 GOODRICH CORPORATION'S RESPONSES TO GENERAL ORDER NO. 129 13 INTERROGATORIES by placing a true copy thereof in an envelope, sealing, and placing 14 it for collection and mailing following ordinary business practices addressed as follows: 15 PLEASE SEE ATTACHED LIST 16 I declare under penalty of perjury that the foregoing is true and correct. 17 Executed on February 22,2002 at Oakland, California 18 19 20 CAROL WEICKER 21 22 23 24 25 26 27 28 -16Responses to General Order 129 Interrogatories - 2002 Firm Name Berry & Berry Brayton & Purceli Clapper & Patti Hobtn & Shingler Kazan, McClain, Edises, et al. Law Office of Bruce Ahnfeldt Law Offices of Christopher E. Grell Paul & Hanley Visse & Yanez ' Wartnick, Chaber, etal. Plaintiff Attorney Service List Street Address P.O, Box 16070 222 Rush landing Road 2330 Marinship Way, Ste. 140 1011 A Street 171 - 12th Street, 3rd Floor P.O. Box 6078 360 - 22nd Street, Suite 320 4905 Central Avenue, Ste. 200 1375 Sutter Street, Ste. 120 101 California Street, 22nd Floor City Oakland Novato Sausalito Antioch Oakland Napa Oakland Richmond San Francisco San Francisco State CA CA CA CA CA CA CA CA CA CA Zipcode 94610 94945 94965 94509 94607 94581 94105 94804 94109 94111 / Akron Plant - Medical Center - Full time employees as far as we know, unless noted Dr. Rex H. Wilson Medical Director SD 6/1/46 - 5/1/74, retired, deceased Dr. Arnold V. Gold Medical Director, SD 9/1/66 -11/1/77, retired, deceased Dr. Richard A. Guyton Staff VP, Health & Env. Services, SD 1/2/74 - 7/31/88, retired Dr. Maurice N. Johnson Director o f Toxicology, SD 4/6/72 - 5/31/85, retired (UGTC list), deceased April 1999 Dr. Harold W. Dietz Director o f Health & Env. Services 10/18/76 - 1991. Retired Dr.Charles T. Disney Asst. Dir. o f Env. Health, 7/15/74 - 2/17/75, retired, deceased. Dr. Harold E. May Dir. o f Medical Services (Medical Center) - 6/10/74 1/1/87; retired Dr. Charles Wintrup Medical Center Staff Physician, SD 5/22/67 - 2/25/72, terminated, deceased. Dr. Carolyn McCann Medical Center Staff Physician,. 5/9/77 - 5/31/86*-term. Dr. Edson Freeman Medical Center StaffPhysician, 7/10/73 - 12/31/80, term. Dr. John Spillane Medical Center StaffPhysician, dates of service unknown, deceased. Dr. D. B. Lowe Medical Director 1937-1946, retired 1946, deceased. ' Dr. F. R. Stees- Medical Center StaffPhysician, dates o f service unknown, approx. 1945 - deceased. Dr. J. H. Pollock Medical Center StaffPhysician, approx. 1955 Dr. Glenn Hough Medical Center StaffPhysician, dates unknown, status unknown but believed deceased. Dr. George Donnelly Medical Center StaffPhysician, 4/1/55 - 5/1/62, deceased. Dr. Ernest H. Planck II Medical Center StaffPhysician, 4/16/54 - 3/1/67, retired, deceased. - _ Dr. Harold Reed . Medical Center Staff Physician, 5/3/54 - 3/1/67, retired, deceased. Dr. I R. Bimbaum Medical Center Staff Physician, early 70's,deceased, (fee for service arrangement) - Dr. Zadinsky Medical Center Staff Physician, early 60's, status unknown but believed to be deceased. Dr. Ralph W. Jacobs Medical Center StaffPhysician, was around in 1954, status unknown. Physicians - Akron Plant Dispensary - none were full time, all worked on a fee for services basis. The dispensary was opened July 1980 and closed September 1987. Robert G. Sacella, MD Private practice, Akron Samir Abdo, MD Left Akron area, early 80's. . John A. Pfeiffer, MD Left Akron area David L. Yontz, MD Deceased 10/22/94 Alan Henson, MD. Orthopedic specialist, current location unknown Philip Wilcox, MD Private practice, Akron Thomas Naumoff, MD Private practice, Medina Jerry Tardio, MD Family Medicine, current location unknown Radiologists /Akron Medical Center! Not full time employees, hired on a retainer or fee for service basis. Thomas Oakley, MJD.in private practice . Richard Hirsch, M.D. on staff o f Akron City Hospital : Robert Hamor, M.D. on staff o f Akron City Hospital Carroll Tatum, M.D. 1960's, deceased Ben F. Suffron, M.D. 1970's, deceased List of BFG Industrial Hygienists and other environmental personnel W. E. McCormick Director of Ind. Hyg. & Tox., SD 1946 - 1973 George Wilson . Tom Bialke Industrial Hygienist, Term. 1968? Industrial Hygienist, Term. 1989 ; ' Tom Shepler Industrial Hygienist, Term, date unknown Bob Nash Industrial Hygienist, Term date unknown Mark Kennedy Industrial Hygienist, Term, date unknown Betty Hodgson Industrial Hygienist, Term, from UGTC 1985 Bob Modrell Industrial Hygienist, Retired 1989 Ed Katzenmeyer Industial Hygienist, Term, from UGTC 1988 John. Bom Chemist, Special Assignment in Akron 1971-1974 Retired from Brecksville 1989 John McCool (title?) Retired UGTC 1982 Charles T. Disney, MD Asst. Dir. Env. Health, 1974-1975 (deceased) . Richard G. Carter Industrial Hygienist, late 605s Ronald Callender Industrial Hygienist, late 60's G S S = 5S5XST TESTIMONY OF GOODRICH EMPLOYEES NAME OF DEPONENT jerry A. Smith Jerry A. Smith Dohrman Wells Keith Banke Jerry A. Smith Marilyn Petroski Jerry A. Smith Jerry A. Smith Jerry A. Smith Jerry A. Smith CASE NAME The Mayor and City Council of Baltimore v. Keene Corp. Hartford Fire Insurance Co. v. Westinghouse Electric Corp. City o f Baltimore v. BFGoodrich Co. City o f Baltimore v. BFGoodrich Co. City o f Baltimore v. BFGoodrich Co. City o f Baltimore v. BFGoodrich Co. Mike Norman v. A-C Product Liability Trust Mon Mass II Goldberg Groups 5,6 & 7 Rickey A. Lanier v. Eastern Refractories Company, Inc. COURT Circuit Court Baltimore City, MD District Court Hennepin County, MN Circuit Court . Baltimore City, MD . Circuit Court Baltimore City, MD Circuit Court Baltimore City, MD Circuit Court Baltimore City, MD Circuit Court Wayne County, MI Circuit Court Monongalia County, WI Court of Common Pleas Cuyahoga County, OH Superior Court Middlesex County, MA DOCKET NO. DATE OF TESTIMONY 84268068/CL25639 4/27/93 87-14006 . 5/13/93 84268068 CL25639 84268068 CL25639 84268068 CL25639 84268068 CL25639 94421061NP 9/21/93 9/21/93 6/7/93 9/21/93 . 12/20/95 6/17/97 286145-014 5/10/99 00-0066 3/21/01 > Revised 7/9/2001 . INSURANCE INDEX 10 / 2 3 / 9 3 in s u r e r r c s 3 i9 C C ' = e K S =4 K a = B s a BFGoorfrleli Policios ui> to $20M AMERICAN MOTORISTS INSURANCE CO, LLOYDS LLOYDS LLOYDS LLOYDS LLOYDS LLOYDS LLOYDS LLOYOS LLOYOS LLOYOS . uOYOS LLOYDS LLOYDS LLOYDS EMPLOYERS REINSURANCE CORP. EMPLOYERS.REINSURANCE CORP. GENERAL REINSURANCE COnP. EMPLOYERS REINSURANCE CORP. AMERICAN MOTORISTS INSURANCE CO. AMERICAN MOTORISTS INSURANCE CO. AMERICAN MOTORISTS INSURANCE CO. AMERICAN BANKERS INS.CO. OF FLA. LONOON STONEWALL INSURANCE CO. INSURANCE CO. STATE OF PA. LONDON NORTHBROOK INSURANCE CO. STONEWALL INSURANCE CO. AMERICAN REINSURANCE CO. I.S.L.I.C. dEGUROS LA REPUBLICA SA LONDON DRAKE INS. CO. OF NEW YORK INSURANCE CO. STATE OF PA. LONOON NORTHBROOK INSURANCE CO. LONOON I.S.L.I.C. AVRECO/SEGURUSLA REPUBLICA LONDON HIGH^ANOS INSURANCE CO. AMERICAN CENTENNIAL AMERICAN CENTENNIAL I.S.L.I.C. LONOON LONOON TRANSIT CASUALTY CO. POLICY PERIOD FROM es m s r es a j fee MS 30 TO 68 s s s POUCY NUMBER ts B K a a a 1/1/44 1/1/63 Unknown 1/1/55 11/6/56 Unknown 1/1/55 11/6/56 Unknown 1/1/55 1/1/55 11/6/56 1 1/6/56 U4S508 U45508 1/I/SS 11/6/56 U4555B 1/1/55 11/6/56 U50514 . 11/6/56 1/1/60 Unknown 11/6/56 1/1/60 U62302 11/6/56 1/1/60 U62354 11/6/56 1/1/60 U 62353 1/1/60 . 1/1/63 U 78656 1/1/60 1/1/63 U7865B 1/1/60 1/1/63 U78657 1/t/60 1/1/63 U 78660 1/1/60 10/13/61 P IE -128 10/3/61 1/1/63 . PLE-120 8/8/62 1/1/63 Unknown 8/8/62 1/1/63 P lEr224 1/1/63 1/1/64 3YM 113 800 1/1/64 1/1/69 3YM 113 800 1/1/69 11/12/75 9YM 1 3 800 11/12/75 1/1/77 XL 345 1150 11/12/75 1/1/77 614 NC 1050 11/12/75 1/1/77 35000443 11/12/75 1/1/77 4176-6735 11/12/75 1/1/77 6 1 4 NC 1051 11/12/75 t/1/77 63 001 415 11/12/75 1/1/79 35000444 11/12/75 1/1/77 M1029BS2 1/1/77 1/1/78 GP 2217 1/1/77 1/1/78 X I 0 1-0031 l/t/7 7 t/1/79 614 NC 1050 1/1/77 10/1/7 7 XL 01521 1/1/77 1/1/79 4176-6735 1/1/77. 1/1/79 6 1 4 NC 2917 1/1/77 1/1/79 63 001 415 10/1/77 1/1/78- Unknown 1/1/78 1/1/79 GP 2662 1/1/78 6/1/78 XL 01-0121 1/1/78 1/1/79 6 M NC 1051 1/1/78 1/1/79 SRNO 40321 6/1/78 1/1/79 XC-00-00-17 1/1/79 7/1/79 XCOOQ046 1/1/79 7/1/79 GP 50003 1/1/79 . 7/1/79 614 NC 6524 1/1/79 7/1/80 614 NC 6525 :l/l/7 9 7/1/79 SCU 955-032 TYPE "=" " " CGL UMB UMB XS xs XS xs UM0 XS XS XS UMB XS XS xs xs xs xs xs CGIVUM CGL/UM CGUUM UMB UM8' UMB XS XS xs xs xs UMB UMB UMB XS XS XS xs xs UMB UM8 XS XS UMB UMB UMB UMB XS XS LIMIT 1,000.000 5 0 .000 (PDj 1.000,000 {GL} 1,000,000 (Gif 500;000 (PD) 4 5 0,00 0 (PDJ 1,000,000 '100,000 500,000 400,000 1,000.000 100,000 500,000 400,000 1,000,000 1.000.000 2,000,00b 2,000.06b 4.000.000 11,000,060 20,000,000 20,000.000 500,000 3,000,000 1,500,000 1,000,000 1,890,000 4,500,000 3,000.000 3,610.000 250,000 1.000.000 3,750,000 45o;ooo 2,100.000 2,800,000 5,040,000 450,000 250,000 1,000,000 3.250,000 3,610,000 1,000,000 1,250.000 250,000 3,500.000 10,900,000 2,000,000 LAYER EXCESS OF: fiE*3 =esse>4t2Wss sx m st m xa ss 1,000,000 50,000 1,000,000 1,000,000 ' 500,000 450,000 1,000,000 100,000 500,000 400,000 1,000,000 100,000 500,000 400,000 1,000.000 1,000,000 2,000,000 2,000,000 4,000,000 11,000,000 20.000,000 20,000,000 5,000,000 5,000.000 5,000,000 14,000,000 14,000,000 14,000,000 14,000,000 14,000,000 5,000,000 5,0 0 0 ,0 0 0 5,000.000 14.000,000 14.000,000 14,000,000 14,000,000 14,000,000 5,000,000 5.000.000 14,000,000 14.000,000 5,000,000 5,000,000 5,000,000 5,000,000 15,000,000 15,000,000 . 50,000 550,000 2,000,000 1,000,000 500,000 1,000,000 1,000,000 t.000,000 600,000 1,000,000 1,000,000 2,000,000 2.000,000 4,000,000 6,000,000 sin SIR SIR 5,000,000 5,000,000 5,000,000 5,000,000 5,000.000 SIR SIR SIR 5,000,000 5.000,000 5.000.000 5,000,000 5,000.000 SIR sm 5,000,000 5,000,000 SIR SIR SIR SIR 5,000,000 5.000,000 INSUflANCE INDEX 10/29/93 INSURER GRANITE STATE in s u r a n c e CO. LONDON I.S.U.C. TRANSIT CASUALTY CO. GRANITE STATE INSURANCE CO. I.S .U .C . LONDON TRANSIT CASUALTY CO. GRANITE STATE INSURANCE CO, I.S .U .C . LONDON LONDON LONOON I.S .U .C . LONDON LONOON REPUBLIC INSURANCE CO. LONDON SELF-INSURED WEAVERS ASSICURAZIONI SELF-INSURED WEAVERS NY INS EXCHANGE SEIF-INSUREO WEAVERS ME ME WEAVERS ASSICURAZIONI HE WEAVERS TUREGUM WEAVERS WEAVERS GENERALI HE TUREGUM WEAVERS WEAVERS TUREGUM WEAVERS ZURICH RE ANGLO AMERICAN LLOYDS ZURICH RE VARIOUS ZURICH RE A ANGLO AMERICAN ALLIANZ POLICY PERIOD FROM ^ *S*t* 5* ** W38 S S5 1/1/79 7/1/79 7/1/79 7/1/79 7/1/79 . 7/1/80 7/1/80 7/1/80 7/1/80 7/1/81 7/1/81 7/1/61 7/1/83 7/1/03 7/1/0.3 7/1/85 7/1/05 7/1/85 8/1/86 B/1/86 8/1/86 8/1/86 B/1/86 8/1/86 . 8/1/86 8/1/86 B/2B/S6 8/28/86 8/1/87 8/1/87 8/1/87 8/1/87 ' 8/1/87 8/1/87 8/1/88 8/1/88 8/1/88 8/1/88 8/1/88 8/1/89 8/1/89 8/I/B 9 8/1/90 8/1/90 8/1/90 8/1/90 8/1/90 . 8/1/91 8/1/92 POLICY NUMBER B a S S R E tilB 6679-1D20 6 H N C 6524 GP 50351 SCU 955-237 6679-1323 OP 5 1 3 )8 6 t4 NTA 158 SCU 955 237 6680-2329 GP52768 614 NTA 570 614 NTA 571 614 NTB 380 GP 562 86 614 NTD 381 614 NTB 380 COU-1B248 614 NTB 381 N/A 614 NTD 418 614 NTD 419 N/A 614 NTD 419 S6S85/86 N/A 614 NTD 420 D0L-06980 DDL-08979 977/7GA2012 977/7GA2014 D O L -1 0 4 1 15 9 7 7/7G A 2 013 977/7GA2015 977/7GA2013 977/8GA2002 977/8GA2004 DOL-120540 977/8GA2005 977/8GA2003 977/9GA2003 9G A 20 04 977/9GA2004 9 7 7/0G A 2 00 6 977/OGA20O7 77/91M1073 TYPE LIMIT ss se s sa ss s s s s s s a s r s s a f s t s s xs UMB UMB 2,100,000 4,750,000 . 250,000 XS XS UMB XS XS XS UMB UMB XS UMB UMB XS UMB 2.000,000 2,100,000 250,000 10,900,000 2,000,000 2,100,000 500,000 4,500,000 15,000,000 4,500,000 500,000 15.000,000 4,100,000 UMB XS 900,000 9,525,000 UMB 875,000 UMB XS XS XS . xs XS xs xs xs UMB XS 4,125,000 125,000 875,000 2,000,000 250,000 3,750,000 4,000,000 2,000,000 2.000,000 5,000,000 250,000 XS xs xs . xs 376,000 4,375.000 1.250,000 8,750,000 UMB XS XS 6,000,000 250,000 375,000 XS XS UMB XS XS 1,250,000 13,125,000 5,000.000 1,875,000 13,125,000 UMB UMB XS XS 3,865,000 1,135,000 850,000 8,630,000 XS UMB UMB 9,520,000 22,000,000 4,400,000 LAYER e} cs ss a s cs s 15.000,000 5,000.000 5,000.000 15,000,000 15,000.000 5,000,000 15.000,000 15,000,000 16,000,000 5,000,000 5,000,000 15,000,000 5,000,000 5,000,000 15.000,000 5 ,0 0 0 ,00Q 5.000.000 16.000,000 5,000,000 5.000,000 5.000,000 5,000,000 5.000,000 10,000,000 10,000,000 10,000,000 6,000,000 10.000,000 6.000,000 5.000,000 6,000,000 5,000.000 10.000,000. 10,000,000 6,000.000 15,000,000 15,000,000 15,000,000 15,000,000 5,000,000 15.000,000 15.000,000 6,000,000 5.000,000 17,000,000 17.000.000 17.000,000 22,000,000 22,000,000 EXCESS Of; S.000,000 SIR sm 5,000,000 5,000,000 SIR 5.000,000 5,000,000 5,000,000 SIR SIR 5,000,000 SIR SIR 6,000,000 SIR SIR 5,000.000 SIR sm 5,000.000 5,000,000 5,000.000 10,000,000 10.000,000 10,000,000 5,000.000 10,000,000 sm 6,000.000 5,000,000 S.000,000 10,000.000 10.000,000 SIR 5,000,000 5.000,000 . 5,000,000 5,000.000 SIH 5,000,000 5,000,000 SIR SIR 5,000,000 5,000.000 5.000,000 SIR sm 'INSURANCE INDEX ..lO & 9 /9 r~ INSURER ZURICH RE . POLICY PF.fllOD FROM TO 8/1/92 8/1/93 POLICY NUMBER 92MG777 TYPE UMB . LIMIT 17,600,000 LAYER 22,000,000 EXCESS OF: O M I >1 SIR BFGoodrfcb ' O H P G uWWks Document Control Number: _________ Authorized by/date: -- ~ HHMWU.10 Effective 9/1/9S Page 1 of 6 - BFUOoarich -------- ------------------------------------------ ,_____________________ r--f.________________ saaB asaB aB gaB ssagss.--------------- . . . . ___ iv&kstf ; # .",c-:-.j, ^ y a?', .-' tiji OCCUPATIONAL HEALTH EXAMINATION PROCRAM it:., '.r iti ? r i . itits'- ''.' -O ; \-:V?.-. :..-.-, .^ ;r > ^ P * O C C P A T d N A l;E X ? D S llll ^ O m S B E S T O S ' :` Overview . In the United Stales, the Occupational Safety and Health Administration (OS.HA) requires that employees who are exposed to asbestos, tremolite, anthophyllite, aednolite or a combination o f these must participate in annual medical surveillance examinations (29 CFR 1910.1001 and CFR 1926.1101) if they experience any o f the following exposure situations: exposed at or above the permissabie exposure limits (PEL'S) o f O.t fiber per cubic centimeter as an 8-hour rime-weighted-average (TWA) or the excursion limit (EL) o f I fiber per cubic centimeter averaged over 30 minutes, for a combined 3G days of more per year; . are involved in Class I, II or 111 asbestos work for a combined 30 days or more a yeji. (Note -'days involving 1 hour or less in total o f Class II and/or Class IU work performed using the work practices specified in the OSHA standard, are not to be counted.) This applies without regard to the employee's use o f personal protective equipment. While it is unlikely that any BfGoodrich employee will be exposed to asbestos in excess o f the PEL or EL, many employees are involved in Class I, 11 or III tasks including changing asbestos gaskets or transite removal or maintenancejob's involving incidental disturbance o f installed asbestos products. P u rp o se This program is intended to: Insure the effectiveness o f work practices .and use o f personal protective equipment to minimize employee exposure to asbestos and prevent asbestos-related health effects, . Insure that employees may safely use-respiratory protective equipment as required by theirjob (see Section 1.2.3 - Medical Clearance for Respirator- Use), ; ' Identify employees with other medical problems or health risks so that they may be referred for appropriate evaluation. BFGoodricb OHP Guideline . . .. D ocum ent Control Number;_________ O H P-M lJ.i Effective 9/1/95 Pag* 2 or 6 Participation Content Facility health and safety personnel must determine which employees will be included in the asbestos medical program. This determination may require performance o f industrial hygiene sampling to document representative air levels; however, for work around installed buildings materials, the requirements are based on the nature o f the work regardless o f exposure level. All employees whose work involves potential exposure to asbestos must be medically cleared for respirator use. The asbestos and respirator examinations must be conducted prior to placement in a job with potential exposure to asbestos. Employees are not to be issued respirators, St tested or trained for respirator use until they have been medically cleared. Asbestos medical surveillance and respirator clearance require the following: * Review o f respirator use requirements; * Review o f pertinent medical and work histojy with special emphasis on the pulmonary, cardiovascular and gastrointestinal systems; * Pulmonary function test to include FEV,, FEV/FVC, % o f predicted FEV, and % o f predicted FVC; - Physical examination with special emphasis on pulmonary and gastrointestinal systems; - * Chest x-ray. . Chest x-rays must be performed at the time of initial placement and then at five and ten years after placement For employees who have more then ten years since their Erst exposure, chest x-rays must be performed ort the following age-adjusted basis: Age 1 5- 35 Age 3d - 45 Age over 46 every 5 years every 2 years annually All chest x-rays must be interpreted by a certified B-reader, or a board certified or eligible radiologist or other physician with known expertise in the pneumoconioses (dust-related diseases o f the lung). The results must be recorded on the ILO B-reader form (Form CSD/NIOSH M 2.8). BFGoodrcb QHP Guideline t Document Control Number;, OHF-OO 1-3.10 Effective 9/1/95 Page 3 o f 6 Procedure Evaluation of Health Effects Each location must identify a local physician to conduct the examinations. Medical surveillance for asbestos exposure under the OSHA standards requires die use o f the mandatory medical questionnaire (Appendix D) aruched at the end o f this guideline. The physician should be provided with-the following: A copy o f this guideline; , The OSHA Asbestos Standards, including appendices D, E and I o f 29CFR1926.1101; . Representative exposure levels; A description ofjob duties and use o f protective equipment; Results o f past examinations. The examining physician will evaluate overall employee health and fitness, concentrating on any problems which may be related to the workplace exposure to asbestos and the employee's ability to perform his or her job safely. The ' physician will also determine whether the employee is capable o f wearing a respirator, as necessary (see Section 1.2.3 - Medical Clearance for Respirator Use). _ ~ - Acute effects related to asbestos inhalation are minimal and similar lo that o f nuisance dusts. Three chronic medical conditions have been associated with exposure to high levels o f asbestos fibers. These rarely become evident until 10 years from first exposure. They are; Pleural Pleural changes are die most common finding in asbestos-exposed workers. These may occur on any pleural surface. These are usually evident on plain x-rays, although oblique films or CT scanning may better document the presence or absence o f true pleural changes. Pleural asbestosis is usually asymptomatic and uncomplicated. Pleural asbestosis only rarely causes pleural effusion, and this finding should prompt an evaluation for possible pleural mesothelioma. In genera], the presence o f pleural findings supports a history o f significant past asbestos exposure. BFCocdrich OKP Guideline , . Document Control N um ber:________ O H P -00U 110 Effective 9/1/95 Page 4 of 4 Evaluation of Health Effects . (cont'd) * Interstitial Interstitial pulmonary fibrosiscor pulmonaiy asbestosis, is a much more serious development Chest x-ray findings include irregular opacities which are predominately in the lower lobes. The physical examination may reveal coarse rales in the lung bases. Pulmonary function usually shows restrictive impairment (decreased vital capacity) and impaired diffusion. Obstructive changes may also occur, although this is usually confined to smokers. * Mesothelioma Mesothelioma is a malignant tumor o f the pleural or peritoneal cavity which has been particularly associated with exposure to amphibole asbestos (crocidolite, amosite). This may be confused with pooriy differentiated adenocarcinoma, particularly when arising in the abdominal cavity. Proper diagnosis may require review o f the tissue .specimens by an experienced pathologist. * Lung Cancer An excess incidence o f lung cancer has also been reported in epidemiologic studies o f asbestos workers. This excess has primarily been associated with the combination o f asbestos exposure and cigarette smoking. The extent to which asbestos exposure alone is a significant risk factor for developing lung cancer remains uncertain. - *" - * Other Cancer Several other types o f cancer have been considered as possibly being related to asbestos exposure. These include gastrointestinal cancers and kidney cancer. Findings from limited studies in these areas have been inconsistent. Interpretation o f Results . The interpretation o f the significance o f any given finding in an individual with exposure to asbestos requires careful consideration of the following: * The significance o f the finding, , * Tfie intensity o f the exposure, * Other possible causes o f the finding, - Latency between exposure and effect. BFGoodrkh - OHF Cuuteiioe Document Control Number:_____ _ " _ OHP-001-3.10 Effective 5/1/95 : 5 of i Interpretation o f Results (cant'4) Proper diagnosis requires a thoughtful history, careful examination and appropriate testing. The determination of whether an individual has developed asbestos- related health effects requires-a dear understanding-of the pathophysiology o f asbestos-related disease. ' All persons who are diagnosed as having possible, asbestos-related disease should be evaluated by an experienced occupational or pulmonary physician. Part o f this evaluation should indude a review o f (he work and exposure history to determine the factors which contributed to disease development. Individuals who properly follow current recommended work practices should not develop any asbestos- related findings. . Separation/ Retirement Any employee who was exposed to asbestos at or above the PEL and/or EL is to be provided a complete physical examination 30 days before or after the last day worked. This examination is to be provided regardless o f time since last exposure. If the employee has been examined according to this guideline within the prior 12 months, no medical examination is required. Management . Persons who are diagnosed as having developed asbestos-related health effects mustbeadvisedofthefindinganditssignificance. Simple pleural plaques require no specific treatment and should result in no symptoms or disability. In contrast, pulmonary asbestosis may result in significant respiratory impairment. Both mesothelioma and lung cancer can be fatal. Further evaluation and treatment must be managed on a case by basis. Appropriate BFGoodrich occupational health resources should be consulted in all cases o f possible asbestos-related disease. Experts in the field differ on the issue o f whether individuals with asbestos-related findings due to past exposures should be allowed to continue to work in- potential exposure areas using protective equipment. If proper procedures are followed, additional exposure and health risk should be .minima]. Ultimately, the determination must be made on a case by case basis, considering the health o f the , effected individual, the risk o f exposure and the nature o f the work. W ritten Opinion The examining physician must supply the facility with a written opinion on the following for each employee: ' * Whether any. medical condition is present which presents an increased risk o f material health impairment due to exposure to asbestos: Whether there are limitations on employee exposure or use of respirators and other protective equipment; BFGoodrich OHP Geidetie Document Control Number:_______ ` . QHP-401J.10 Effective 9/1/95 Page 6 of 6 W ritten Opinion (cont'd) A statement indicating that the employee has been informed o f the results o f the examination and o f any medical conditions which may result from . exposure to asbestos;-- . ' A statement that the employee has been informed by the physician o f the increased risk o f lung cancer attributable to the combined effect o f smoking and asbestos exposure. Confidentiality A copy o f die physician's written opinion shall be provided to the affected employee within 1S days o f receipt by the employer. The employee should sign a statement indicating that they have been informed o f alltthe results o f the examination. ' The results o f die examination that are not directly related to the employee's health and safety in the work environment are confidential. These findings must not be communicated or released to any individual without the employee's written consent ! ASBESTOS CONTACTING PRODUCTS MANUFACTURED BY TH E BF GO OD RICH COMPANY (Rev. 11-2-00) PRODUCT N * M B W H ERE M AN U FA CTU RED DATE PRODUCT FIRST PLACED ON M ARKET DATEPRODUCT * CEASED TO BE PRODUCED F uraace Door Hose (A kron, OH & . M arina, OH) A pprox. 1953 Approx. 1979 D ESCR IP. O F CH EM ICA L CO M POSITION EPDM Rubber ttfA ib esto jA W ire D ESCRIP. O F PH YSICA L . APPEARANCE OF PRODUCT W ire C overed Hose D E SCR IPTIO N OF INTENDED USE WAS PRODUCT ON US GOVT. Q U A LIFIED PR O D . L IS T W ater cooled doors on . S F ttf/slilx Unknown SU PPLIER OF RAW ASBESTOS Unknown M ISC E L L A N E O U S IN FO RM A TIO N RECORDS AV AILA BLE C U S T O D IA N Industrial H ose business sold to H B D Thennoid -1 9 8 5 F ew ateJog re& rtnces/C astodiaii * See otite I. Pyrotoek* R ocket ' fasnlatfon (A kron, O il) 19S2 Sheet Rubber (A kron, OB) E arly 1900`i A sphalt Floor Tile (W aterlw oa, M A) A pprox. 1945 . K o ro iw l Vinyl A sb u tci Floor T ilt (W atertow n, M A) Approx, 1950 G ubclf (Salen.D O Brake Tube (A kron & T roy, OH) 1959 1963 A ircraft B rake Parte (Troy, OH) . M id 1940's 1974-1975 Approx. 1950 Early l? r * 1963 Early 1970's 1970 1985 M ixture o f vvsterglass, d a y , high carbon rubber and chrysodle asbestos (less lhan 9%) Neoprene HycarRubbcr Asbestos B row n o r gray peste Robber Shee& ftolte U ite end insulate rocket m otorcasiags Gasket M aterials A Sheet P ek in g Yes Unknown Asphalt, Asbestos & Cofor, C h fjw tile (% Unknown) Vinyl, Clay, Asbestos, C olor, I'i& sJcizer, C hrysolite (54 Unknown) Unknown 9 "x 9 ' & I 2 ux l 2 w flo o r Tles 9*x9" A 1-X 2- Floor Tiles s G asktt Strip Rubber Tube w/Afibeataa Cover Robber Tube Unknown Brake Assembly Floor C o w in g Floor Covering Gaskets for Dishwasher D oors Aircraft A Off Highway Vehicle Brakes Aircraft B rake A ssem bly Unknown Unknown Unknown ' Yw Ya Johns-M aim ile Theffw d M ines Unknown RuH roW Thetford M ines, JohnsManviUe Rtrbcfotd T b X fo rt M bits, JohnsM nyllte UofcnTwi See N ote 372 " Purchased by N avy so der M EL^C-22508. Made by A dhesives Div, See N oie I 1 i Product generally sold east o f M ississippi River Product gen erally sold east o f M ississippi R iva Few catalog referenccs/C estodlan -See cote 1. A dvertising, clinical roam nls, Castoriian See nue !. Advertising, technical m anuals, C uttodianS eeN o tcl. Unknown Uaknown .. See Note 82 Unknown cn PRODUCT NAME * W HERE M AN UFA CTU RED DATE PRODUCT FU ST PLACED ON M ARKET O ff-H ighw ay B rake P a rts (Troy and A kron; O il) U to 1950'$ Rocket insulation (A kron, OH) 1960 ' A utom ahllV U ght T ru c k Brakes * (M ljg.L ot.N A ) 1930 DW AH (A kron, OH) 1968 PL717-A (Akron OH) PL717-B (A kron, OH) 1969 196 PLTM -3 (A kron, OH) PL-786 (A kron, OH) R-907-T (A kron, OH) 197$ 1972 1955 DATE PRODUCT CEASED TO BE ' PRODUCED D ESCRIP. O F CH EM IC A L CO M PO SITIO N 198$ - Unknown D E SC R IP. O F PH YSICA L APPEARANCE OF PRODUCT Broke Assembly DESCRIPTIO N O F INTEN DED USE Off-Highway Vehicle Brake Assemblies WAS PRODUCT ON US G O V T. Q U A LIFIED PR O D . UST Unknown SU PPLIER O F RAW ASBESTOS See Note # 2 1985 1935 ' Unknown 149W54 Unknown Unknown Replacem ent Brake A ssembly . Used as insulation in Y tt Phoenix Rockets Auto T ru c k Brakes Unknown Unknown See N ote #3 I97S I9S5 1985 1985 . 1985 198S Rubber Resin, Inorganic Filler, Chiyeottfc 20% Epoxy Resin, Chrysolite < S% (C ah d ris) Epoxy FUm. d ay to flle < 1% (C d id ria) . Thick Adhesive Drywsli Adhesive No Amber Film Bonding A irae ft Part Unknown Ll CrcftirtiTea F ilm Bonding Material , (Aircraft) Unknown Epoxy FBm, Chrysotilc < 2% . (C alid rts) Epoxy Film , Chrysolite 15% Rubber, A sphalt, Inorganic. FiUer, Q rryso6le6% Beige Film - A lum inum Colored FUoi Slack Adhesive _ Bonding Aircraft P am Bonding Aircraft Parts R oof Vapor Barrier A dhesive Unknown Unknown No Carey J o h n sM mviNe K.CAC. See N ote M KCAC KCAC Corey & JohnsM anville Carey J o h n sM aavilfo M ISCELLANEOU S IN FO RM A TIO N RECORDS A V A ILA BLE CU STO D IA N BFG to ld business to Carlisle B rak in g Sys., Bteoraiagtoo, IN 1990 Unknown Unknown Tire Center business sold is Tire Centers, Inc. -1 9 8 5 . N o w owned by M ichelin. None. (M iohciti?) 1 i Adhesive Systems (See N ote S) Adhesive Systems (See N ote 5) A dhesive Systems (See N ote 5) Adhesive Systems (See Note S) Adhesive Systems (See Note 5) Adhesive Systems (See Note S) 2 PRODUCT NAME & WHERE MANUFACTURED DATE PRODUCT FIRST PLACED ON MARKET Penmate 1955 (Akron, 023) PL-200 19 (Akron, OH) PL-400 19 (Akron, QH) K-U06-T 1971 (Akron, OR) BA-106 IW2 (Akron, OR) A-14S4-B 1979 (Akroo,OR) PL731 1976 (Akron, OH) PU410&4 (Akron, OH) DSA 100 (Akron, OH) 1968 Unknown DATE PRODUCT . CEASED TO BE PRODUCED DESCRIP. OF CHEMICAL COMPOSITION 1985 1980 1980 1980 IMS' 1983 J 1989 1992 Unknown Rubber, Asphalt, Inorganic Filter, Chrysolite 6ft Rubber, Resin, Inorganic Filler, Chrysolite 2i% Rubber, Resin, Inorganic Filler, Chrysolite 19ft Reclaimed Rubber, Resin, Filler & Solve, Chrysolite 6ft Rubber, Resist, Filler, Solvent, Chrysolite 20% Vioyl, Solvent, Filler, Chrysolite 2H (Cslldrie) Aluminum Filled Epoxy Film, Chiytttile< 2ft (Calidria) ' Amino Fillers, Oil, Chrysolite < 5ft Resm, Rubber, Filler Solvent, Chrysolite 20ft &E5CRIP. OF PHYSICAL appearance of PRODUCT Blade Adhesive Blade Adhesive Grey Adhesive . Grey Mastic Blade Mastic White Putty Amber Film Thick Crew Blade Mastic DESCRIPTION OF INTENDED USE RoofVapor Barrier Adhesive WAS PRODUCT ON US GOVT. QUALIFIED PROD. LIST . No ' SUPPLIER OF RAW ASBESTOS Carey & JoliasMteiviHe . Faeci Adhesive No Carey & Johns* ManvxUe Sub Floor Adhesive No Carey & Johns* Manville Temporary Branding Searching of Cattle Carey Johns* Maovilte Drywall Adhesive No Vinyl Window Putty No Carey & JohnsManville KCAC Bonding Aircraft Parts No KCAC Urethane Sealant . Yes Drywall Adhesive No Johns-Manvic Carey & Jotes* Manvilte MISCELLANEOUS INFORMATION RECORDS ` AVAYIaABLE - CUSTODIAN Adhesive Systems (See Note 5) Adhesive Systems (See Note 5) Adhesive Systran (See Note 5) . i Adhesive Systems (See Note 5) Adhesive Systems (See NoteS) ' Adhesive Systrata (See Note S) Adhesive Systems (See Note 5) Adhesive Systems (See Note 5) Adhesive System* (See Note 5) 3 PRODUCT NAME & WHERE MANUFACTURED DATEPRODUCT FIRST PLACED ON MARKET DSA300 (Akron,OH) Unknown DATE PRODUCT. CEASED TO BE PRODUCED Unknown DESCRIP. OP CHEMICAL COMPOSHTON Rubber Re!a, Inorganic Pilier, Chrysot{Ie25% DESCRIP. OP PHYSICAL APPEARANCE OF . PRODUCT Black A&csiye DESCRIPTION OF INTENDED USE ` Dry Wail Adhesive Notes: 1. 2. 3. 4. 5. Custodian Is Tbe BPGoodricb Company, 4 Coliseum Centre, 2730 W. Tyvals triad, Charlotte, NC 28217. ' Manufhetured asbestos component puts were purchased fiom suppliers and used in brake assemblies manufactured by BFCoodrich. aFGoodrichpurchased endn brake assembly and simply installed as auto service centers. KCAC address is PO Boa K, Cattlemen Road, King City, California 93930. Business sold to Sovereign Engineered Adhesives,' LLC.-3-31-9S (now SiA Adhesives). 123 Badges S t, Akron, OH44311. WAS PRODUCT ON US GOVT. QUALIFIED PROD. LIST No SUPPLIES OF RAW ASBESTOS Carey & Johns* MgaviOe MISCELLANEOUS INFORMATION RECORDS AVAILABLE - CUSTODIAN Adhesivo Systems (Seo Noie 5) I. I 4 Publications subscribed to by Health and Environmental Services with dates where known. 1. American lad. Hygiene Association Journal 1946 through 1991. 2. Archives o f Environmental Health 1961 through 1982. - ' 3. Archives of Industrial Hygiene & Occupational Medicine 1950 through 1960. Note that name was changed to #2 above in 1961. 4. British Journal of Industrial Medicine 1972 through 1993. 5. Cancer Journal , 6. Environment Midwest 7. Environmental Research 1974 through 1980. 8. Environmental Science and Technology 9. . Health and Safety ' 10. Industrial Medicine (19351 and Surgery (1950) 11. Job Safety and Health 12. Journal of Air Pollution Control Association 13. Journal of American Medical Association Kept on current year basis. 14. Journal of Occupational Medicine 1959 (Ongoing). . 15. National Safety News . , 16. Occupational Hazards 17. Ohio State Medical Journal 18. Pollution Engineering - 19. Preventive Medicine 20. Today's Health .. . 21. Toxicology,and Applied Pharmaecologv 1959 (ongoing). 22. Water arid Pollution Control 23. . NIOSH Technical Information ; 1972 (ongoing). 24. NIOSH Criteria For a Recommended Standard 1972 (ongoing). 25. Occupational Safety and Health Reporter 1972 (ongoing). 26. American Industrial Hygiene Association: Hygienic Guidelines NOTE; (Rev. 7-22-99) Per M. B. Butterfield, she shows we started Subscribing at least as far back as 1958. 27. NIOSH Manual of Analytical Methods 1972 (ongoing). . , . 28. ATHA Analytical Abstracts 29. EPA Analytical Quality Control 30. MCA - Chemical Safety Data Sheets 31. OSHA-Standards 32. OSHA - Reporter 33. OSHA- Letter , 34. Environmental Health Perspective , 1973 (ongoing). 35. Journal of Toxicology and Environmental Health ' 1976 through 1977 1983 (ongoing).