Document rxVD96OBp5BB050wmmO8zn0oe

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA Southern Division CHARLES RIDLING and BETTY RIDLING, Plaintiffs, VS ' ARMSTRONG WORLD INDUSTRIES, INC., et al., Defendants. ) ) ) ) ) CIVIL ACTION NO.: ) ) CV84-1198-X ) ) ) ) ANSWERS TO PLAINTIFFS' FIRST SET OF INTERROGATORIES COMES NOW one of the defendants in the above case, Raymark Industries, Inc., and for answer to those interrogatories pro pounded to it by the plaintiffs, sets down and says the follow ing with the express understanding that the interrogatories are being answered pursuant to the provisions set forth in the Ala bama Rules of Civil Procedure and the law in Alabama and not by any instructions from the plaintiffs which may contradict or conflict with the rules of law. 1. John Kutzler, Controller and Assistant Secretary, Raymark Industries, -Industrial Division of Raymark Industries, Inc., 100 Oakview Drive, Trumble, Connecticut Q6611 has signed the interrogatory answers solely for the purpose of satisfying any verification requirements. These interrogatory answers are based upon information developed through conversations with various present and former Raymark personnel and the review of thousands of corporate do cuments. It is not possible to correlate specific answers to interrogatories and sources of information. 2. Raymark Industries, Inc. is a corporation which was incorporated under the laws of Connecticut with its principal place of business being located at 100 Oakview Drive, Trumble, Connecticut. 3. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither re levant nor reasonably calculated to lead to the discovery of admissible evidence and it is vague and ambiguous in that the phrase 'regularly conducted business" is capable of numerous interpretations. Without waiving the foregoing objections and subject thereto, Raymark has held a certificate of authority to do business in the State of Texas and has, on occasion, sold asbestos-containing textile products in the State of Alabama. 4. Raymark objects to this interrogatory because it seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence and that the phrase "regularly conducted" is vague and ambiguous and capable of various interpretations. Furthermore, the date on which such a certificate of authority was obtained is a matter of public record and within the power of plaintiff to obtain. 5. Yes. 6. (a-c) On June 28, 1982, Raymark Industries, Inc., a wholly-owned subsidiary of Raymark Corporation, merged with and acquired the assets of Raybestos-Manhattan, Inc. Raybestos- Manhattan, Inc., was incorporated on July 5, 1929 for the pur pose of merging the Raybestos Company, Bridgeport, Connecticut; General Asbestos and Rubber Company, Charleston, South Carolina (then a subsidiary of the Raybestos Company); the Manhattan Rubber Manufacturing Company, Passaic, Hew Jersey; and United States Asbestos Company, Manheim, Pennsylvania. Both Raymark Industries, Inc. and Raymark Corporation are Connecticut cor porations and were incorporated on April 30, 1982 and June 17, 1981 respectively; their corporate charters are a matter of public record and copies of the same can be obtained from the Secretary of the State of Connecticut upon request. Their cor porate headquarters are now located at 100 Oakview Drive, Trumble, Connecticut. . 5. (Typographical error) See response to 5 above. 6. (Typographical error) See response to 6 above. 7. No. 8. N/A. 9. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither re levant nor reasonably calculated to lead to the discovery of admissible evidence and it is vague and ambiguous in that it fails to specify a particular, relevant product or time period. Without waiving the foregoing objections and subject thereto, Raymark has, on various occasions, manufactured and sold asbestos-containing textile products. 10. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither re levant nor reasonably calculated to lead to the discovery of admissble evidence and it is vague and ambiguous because it fails to specify a particular, relevant product or time period. Without waiving the foregoing objections, and subject thereto, Raymark has never mined or milled raw asbestos fiber. However, in 1953, Raymark bought 400,000 shares of Cassiar Asbestos Corporation Ltd. That corporation owned the Clinton Mine, British Columbia. All of that stock was sold in 1980. 11. See response to 9 above. 12. Raymark objects to this interrogatory because it is overly broad and that it seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence and it is vague and ambiguous in that it fails to specify a particular, relevant product or time. With out waiving said objections and subject thereto Raymark states: (a - h) See attached Rider A on specific product information. 13. Yes. 14. (a - c) Novatex's patents for cloth that can be used to cover thermal insulation are as follows: #3806572, issued April 23, 1974; #3453818, issued November 29, 1967; #3062697, issued November 6, 1962. Patton ap plication #600929, filed August 31, 1976, is pending. 15. Yes. 16. (a - d) New treatments, formulas and processes have been developed by Raymark to minimize airborne dust generations. Raymark has pioneered in the development of dust control systems and continues to devote sub stantial resources for continuing improvements of such systems and the development of dust-free products and manufacturing processes. In 1975, it instituted a program for restructuring asbestos yarn and textile manufacturing operations. This four year, $11,000,000.00 undertaking, financed by internally- generated funds, was based on expansion of Raymark's wet process" system of manufacturing Novatex asbestos yarns, which operate within OSHA standards for air borne dust concentrations. Raymark is the only manu facturer of asbestos textiles in the United States utilizing a *wet process* system. It developed this system and the system is protected by patents and sub stantial additional proprietary knowledge. In addi tion, Raymark has worked closely with the environ mental protection agency and the development of emis sion effluent regulations to eliminate the possibility of environmental contamination. Except as stated above, no substantive changes, alterations or modifi cations have been made to Raymark Products sold for use by insulation mechanics since the materials were first developed. Similarly, none of the asbestos tex tile products produced by Raymark were altered in chemical composition since first being marketed; nor has Raymark conducted any recall campaigns, opera tions, programs, or activities in connection with the products that it assembled and manufactured. Raymark did, however, discontinue production of some asbestos textile products due to lack of sales and did develop non-asbestos textile products suitable as substitutes for asbestos textiles in some applications. 17. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither re levant nor reasonably calculated to lead to the discovery of admissible evidence, it is vague and ambiguous in the term 'participated* is undefined and capable of various interpreta tions, it fails to specify a particular', relevant product or time period and it is unduly burdensome and oppressive. 18. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither re levant nor reasonably calculated to lead to the discovery of admissible evidence, it is vague and ambiguous in the term preparation* is undefined and capable of various interpreta tions and it fails to refer to a particular, relevant Raymark asbestos-containing textile product. 19. The objections set forth in response to number 18 above are incorporated herein by reference. 20. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither re levant nor reasonably calculated to lead to the discovery of admissible evidence, it is vague and ambiguous in the term 'po tential health hazards* is undefined and capable of various interpretations. Without waiving said objections and subject thereto, see Rider B attached. 21. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither re levant nor reasonably calculated to lead to the discovery of admissible evidence, it is vague and ambiguous in the term 'po tential health hazards* is undefined and capable of various interpretations. without waiving said objections and subject thereto, see Rider B attached. 22. See Rider B attached. 23. See Rider B attached. 24. Although Raymark cannot say that any specific changes were made a result of any specific tests, all changes made in the development of Raymark products have previously been set forth in response to interrogatory 10 above. 25. See response to 24 above. 26. Raymark objects to this interrogatory in that it is overly broad in that it seeks information which is neither re levant nor reasonably calculated to lead to the discovery of admissible evidence and it is vague and ambiguous in that the phrase "potential health hazards' is undefined and capable of various interpretations. Without waiving said objections, and subject thereto, all tests conducted by Raymark have previously been set forth in response to answer 20. 27. See response to 20. 28. Raymark objects to this interrogatory in that it is overly broad in that it seeks information which is neither re levant nor reasonably calculated to lead to discovery of admis sible evidence and it is vague and ambiguous in that the phrase potential health hazards" is undefined and capable of various interpretations. 29. Raymark objects to this interrogatory in that it is overly broad in that it seeks information which is neither re levant nor reasonably calculated to lead to discovery of admis sible evidence and it is vague and ambiguous in that the phrase "potential health hazards" is undefined and capable of various interpretations. 30. See Rider C attached. 31. See Rider C attached. 32. Yes. 33. See Rider D attached. 34. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither re levant nor reasonably calcuated to lead to the discovery of admissible evidence, it is vague and ambiguous in that the phrase "claiming injury" and "using asbestos products" are un defined and capable of various interpretations and it is unduly burdensome and oppressive. Without waiving the foregoing ob jections and subject thereto, Raymark first received a claim from a manufacturing plant employee for Asbestosis in 1933, carcinoma in 1950 and Mesothaleoma in 1962. 35. See response to 34 above. 36. No. However, from 1969 until 1974, Raymark manufac tured certain asbestos products for Johns-Manville Corporation according to Johns-Manville*s product specifications. This was done as part of Raymark's purchase of the Marshville, N. Caro lina plant from Johns-Manville. In addition, some of the Ray mark customers may have resold asbestos textile products pur chased from Raymark, but Raymark has no record of any such re sales. In addition, from the iate 1940's or early 1950's Raymark's Manheim, Pennsylvania plant manufactured certain packag ing products sold by Anchor Packing Company and shipped in Anchor Packing packaging. That arrangement terminated in 1981. Thereafter, Raymark's former North Charleston, South Carolina plant sold in June, 1982 manufactured similar products for Anchor Packing. 37. See response to 36 above. 38. Raymark objects to this interrogatory in that the phrase "indicate that asbestos fibers can be hazardous to the health of human beings" is vague and ambiguous and capable of various interpretations. Without waiving said objection, and subject thereto, for many years, Raymark has collected miscel laneous documents, journals, articles, and books pertaining to the effects of asbestos upon human health. These materials have been gathered and maintained over the years by a number of individuals and are currently maintained by John H. Marsh, Director of Environmental and Government Affairs and by Raymark's Health and Safety Department. Raymark subscribes to the following publications, most of which from time to time contain information or articles con cerning asbestos: Archives of Environmental Health, Lancet, British Medical Journal, Annals of Occupational Hygiene, Occu pational Health and Safety, Medical News Digest, British Jour nal of Industrial Medicine, Chest, Environmental Research, American Journal of Medicine, New England Journal of Medicine, Asbestos Journal of Occupational Medicine, Science, Toxic Material News, OSHA Compliance Letter, Federal Register, En vironmental Health Letter, Occupational Health and Safety Let ter, Environmental Issues, Occupational Hazards, National Safety News, American Industrial Hygiene Association Journal, Industrial Hygiene Digest, Journal of the Air Pollution Control Association, Environmental Science and Technology, Science News, Bureau of National Affairs Occupational Safety and Health Reporter, Environment, Environmental Health Letter, Water Pol lution Control Federation, Business Insurance, Wall Street Journal, Pollution Engineering, and Bureau of National Affairs Chemical Regulations Reporter. 39. See response to 38. 40. Yes. 41 . (a) Starnes fc Atchison, Lawyers, One Daniel Plaza, Daniel Building, Birmingham, Alabama 35233. (b) Upon advice of counsel, defendant objects to this interrogatory in that the information requested is privileged and/or part of the attorney's work product. (c) Not as yet. (d) N/A. 42. Yes. 43. (a - c) Raymark has performed studies at the below listed customer locations to determine the extent of airborne concentrations of asbestos fiber during their use. Installation or fabrication of its textile asbestos products; Detyens Ship Yard, Mt. Pleasant, S. Carolina (April 8, 1975)(cloth); Horth Brothers, Inc., (National Service Industries), Atlanta, Georgia (August 13, 1975)(cloth); A-Best, Corporation, Cleve land, Ohio (November 11, 1975)(safety clothing); C.D. Genter Company, Chattanooga, Tennessee, (February 25, 1976)(gloves); W.E. Palmer Company, South Boston, Mas sachusetts, (November 8, 1976)(curtains); Abney Mills Company, Greenville, South Carolina (January 20, 1976)(papermaker's felts); Hoechst Fiber Company, Spartenburg, South Carolina, (September 29, 1976) (weaving cloth); Westinghouse Electric Company, Hamp ton, South Carolina, (March 9, 1976), W.E. Palmer, Boston, Massachusetts, (December, 1978)(curtains); Prommelt Industries, Debuke, Iowa, (March, 1979) (cloth); Lanco Industries, Jackson, Missouri (March, 1979)(cloth). These tests were performed principally under the direction of Patrick Cooper, Manager of Environmental Services, Raybestos-Manhattan Industrial Products Com pany, North Charleston, S. Carolina (1975 and 1976 tests) and John O. Pierson, Raymark's corporate in dustrial hygienest (1978 and 1979 tests). In each of these tests, the fiber counts recorded were below pre scribed limits. In no case which Raymark has con ducted dust counts in areas involving the use of Raymark materials sold for use by insulation mechanics has there been any indication that allowable airborne fiber concentrations in effect at the time of such tests have ever been exceeded. 44. Raymark manufactured asbestos textile products at the following locations: North Charleston, S. Carolina (1929 1982); Marshville, N. Carolina (since acquisition from JohnsManville in October of 1969); and Manheim, Pennsylvania (since 1929). To the extent of this interrogatory seeks additional information, it is objected to because it is overly broad, seeks information which is neither relevant nor reasonably cal culated to lead to the discovery of admissible evidence, and it is unduly burdensome and oppressive. 45. Raymark from time to time advertised its asbestoscontaining products. 46. Raymark objects to this interrogatory in that it is overly broad in that it seeks information which is neither re levant nor reasonably calculated to lead to the discovery of admissible evidence, it is vague and ambiguous in that it fails to specify a particular, relevant product or time period and it unduly burdensome and oppressive. Without waiving said objec tion and subject thereto, see Rider E. 47. Raymark objects to this interrogatory in that it seeks irrelevant information not reasonably calculated to lead to the discovery of admissible evidence and it is overly broad in that it fails to specify a particular, relevant product. Without waiving said objection and subject thereto, see Rider F. 48. See response to 47 above. ' 49. Yes. 50. Pursuant to OSHA's asbestos products standards issued in June, 1972, Raymark began placing, in July of 1972, warning labels on its products. Since approximately 1974, warning labels have been placed on all Raymark products containing as bestos which are not encapsulated and certain other products. The warning is located on the outside of the package and states: 'CAUTION: CONTAINS ASBESTOS FIBERS: AVOID BREATHING DUST; BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM". Since sometime in 1975, Raymark has directed a pamphlet, published by Asbestos Institute of America (AIA) entitled "Re commended Work Practices, Use and Handling of Asbestos Textile Products", to purchasers of Raymark textile products. Also, in ^mark commenced diet r a .actions with all friction material . .xonally, early in 1977, Raymark distributed t ronmental package* to its asbestos textile customers package contained a copy of the aforementioned booklet, with an up to date copy of the OSHA asbestos regulatio summary of the results of certain laboratory tests of l released from asbestos fabrics conducted at McGill Universi a list of suppliers of protective equipment, a list of labor tories and consultants offering asbestos dust monitoring ser vices, and a list of suppliers of vacuum cleaners and sources of information on design and control of local exhaust systems. It is believed that plaintiff was aware of the danger of asbestos and of the warnings distributed by Raymark and failed to take adequate precautions for his own safety. It is also believed that the plaintiff failed to adhere to the recommended work pratice as set forth in the aforementioned booklet distri buted by Raymark. Additionally, the potential dangers of prolonged asbestos dust inhalation were well known to insulation workers and the responsibility for supervising their work prac- tices remains with their supervisors and employers. It is also believed that insulation workers are provided with warnings concerning the dangers of asbestos exposure by their union re- presentative. 51. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither re levant nor reasonably calculated to lead to the discovery of admissible evidence, it is vague and ambiguous in that the phrase *tbe likelihood of asbestos being hazardous to human health* is undefined and capable of various interpretations and it fails to refer to a particular, relevant Raymark asbestos containing textile product. 52. See Rider G referring to awareness of hazards. 53. See response to 52 above. 54. See response to 52 above. 55. See. Rider H and 1. 56. See Rider J. 57. See response to 55. 58. Raymark objects to this information in that it is overly broad and seeks information which is neither relevant nor reasonably calculated to lead to the discovery or admis sible evidence. Furthermore, it is vague and ambiguous as it fails to specify a specific relevant time period, product and application. Without waiving said objection and subject there to, see Rider K. 59. See response to 60. 60. See Rider L. 61. See Rider M. 62. Raymark objects to this interrogatory as it is vague in that the term "available* is capable of various interpreta tions. The groups listed would be better situated to provide a response. 63. See response to 61. 64. See response to 61. 65. See Rider N and 0. 66. Raymark objects to this interrogatory in that it seeks information which is irrelevant and not calculated to lead to the discovery of admissible evidence in that the term poten tial health hazards* is vague and ambiguous. 67. See response to 66. 68. Raymark objects to this question because it is overly broad and seeks information which is neither relevant nor rea sonably calculated to lead to the discovery of admissible evi dence. Without waiving said objection and subject thereto, Raymark recently marketed non-asbestos textile products sui table for use as substitutes for asbestos textile products in some applications. Pyroglas, a spun glass fiber woven mate rial, was introduced in 1979 for use in thermal and electrical insulation applications. Flextra, made from Kevlar/Nomex aramid fibers was introduced in 1981 in the form of cloth, tape and tubing. Pyroglas cloth was removed from the market in 1980 due to poor sales; Pyroglas tape is still marketed. In recent years, Raymark experimented extensively with tex tile products based on non-asbestos fibers. Fiber types tested included refractory (leached glass), ceramic, kaowool and fiberfrax fibers. All of these fibers were found to be too fragile to be incorporated in textile products. Raymark also conducted extensive research to develop yarns from glass, poly ester and acrylics for use in paper felts. Pyrosleeve is a spun glass product coated with silicone or other rubbers and braided into tubing. 69. Raymark objects to this question because it is overly broad and seeks information which is neither relevant nor rea sonably calculated to lead to the discovery of admissible evi dence/ as Raymark's customers, and not Raymark, were responsi ble for the working conditions of their employees. Without waiving the foregoing objection and subject thereto, Raymark states that it occasionally recommended to customers to conduct dust counts on their work sites in order to determine whether their employees should be wearing protective equipment. 70. Raymark's asbestos textile products were shipped by truck to specific destinations. For many years, cloth products were wound on cardboard cores and wrapped in burlap. Starting in approximately 1973, the outer wrapping was polyurethane film inside of burlap. Tape products were wound in rolls and packed in cardboard cartons with Raybestos-Manhattan printed on the cartons. Starting in approximately December, 1978, tape was furnished in individual packages covered with heat-shrunk poly urethane film. A number of packages were placed in cardboard cartons for shipment. 71. No. However, from 1969 until 1974, Raymark manufac tured certain asbestos products for Johns-Manville Corporation according to Johns-Manville's product specifications. This was done as part of Raymark's purchase of the Marshville, North Carolina plant from Johns-Manville. In addition, some of Raynark's customers may have resold asbestos textile products pur chased from Raymark, but Raymark has no record of any such re sales. In addition, from the late 1940's or early 1950's Raymark's Manheim, Pennsylvania plant manufactured certain packing products sold by Anchor Packing Company and shipped in Anchor Packing packaging. That arrangement terminated in 1981. Thereafter, Raymark*s former North Charleston, South Carolina plant (sold in June, 1982) manufactured similar products for Anchor Packing. 72. See response to 71 above. 73. See response to 71 above. 74. N/A. 75. Raymark objects to this interrogatory in that it is overly broad, seeking information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence and because it is unduly burdensome and oppressive. 76. The objections set forth in response to interrogatory 75 are incorporated and herein by reference. 77. Raymark has not yet selected expert witnesses. When such experts are selected, plaintiff will be notified as to their names, qualifications, etc., accordingly. 78. See response to 77 above. 79. Other than the plaintiff and the other defendants herein, Raymark has no such knowledge as yet. 80. Raymark objects to this interrogatory upon advise of counsel in that it seeks information protected by the attor ney's work product in that it necessarily calls for the dis closure of the mental impressions, conclusions, opinions, or legal theories of Raymark's counsel concerning the litigation. 81. Raymark does not contest service of process. 82. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence as it fails to specify a particular, relevant product, time period and condition of exposure, it is vague and ambiguous because the phrase 'asbestos containing or thermal insulation products* is undefined and capable of various interpretations, and it is unduly burdensome and oppressive. Without waiving the foregoing objections and subject thereto, Raymark states that to the extent the information sought in this interrogatory can be ascertained from a review of Raymark's asbestos product sales records, the burden of deriving the information is the same for Raymark as for the party propounding this interrogatory. Such records are located in a document depository at the offices of Pitney, Hardin, Kipp & Szuch, 163 Madison Avenue, Morristown, New Jersey 07960. Gathered from Raymark's facilities around the country, the documents are maintained in the same manner as they were discovered. Upon reasonable notice, counsel will be permitted to review any non-privileged documents in a manner consistent with Raymark's obligation to maintain the documents in its possession in the order in which they were discovered at Raymark's facilities and consistent with its obligation to make the documents available for inspection by other counsel throughout the country. At the time of the inspection, Raymark will designate those file drawers within the document depository in which responsive information is most likely to be found. Copies of documents requested will be provided at the propounding party's expense. 83. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence as it fails to specify a particular, relevant product, time period and condition of exposure, it is vague and ambiguous as it fails to specify particular relevant products, and time period, and it is unduly burdensome and oppressive. Without waiving the foregoing objections and subject thereto, Raymark states that to the extent the information sought in this interrogatory can be ascertained from a review of Raymark's asbestos product sales records, the burden of deriving the information is the same for Raymark as for the party propounding this interrogatory. Such records are located in a document depository at the offices of Pitney, Hardin, Kipp & Szuch, 163 Madison Avenue, Morristown, New Jersey 07960. Gathered from Raymark's facilities around the country, the documents are maintained in the same manner as > they were discovered. Upon reasonable notice, counsel will be permitted to review any non-privileged documents in a manner consistent with Raymark's obligation to maintain the documents in its possession in the order in which they were discovered at Raymark's facilities and consistent with its obligation to make the documents available for inspection by other counsel throughout the country. At the time of the inspection, Raymark will designate those file drawers within the document depository in which responsive information is most likely to be found. Copies of documents requested will be provided at the propounding party's expense. 84. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence as it fails to specify particular, irrelevant products, time period, it is vague and ambiguous because of the phrase "responsible for sales" is undefined and capable of various interpretations and is unduly burdensome and oppressive. Without waiving the foregoing objections and subject thereto, Raymark states that to the extent the information sought in this interrogatory can be ascertained from a review of Raymark's asbestos product sales records, the burden of deriving the information is the same for Raymark as for the party propounding this interrogatory. Such records are located in a document depository at the offices of Pitney, Hardin, Kipp & Szuch, 163 Madison Avenue, Morristown, New Jersey 07960. Gathered from Raymark's facilities around the country, the documents are maintained in the same manner as they were discovered. Upon reasonable notice, counsel will be permitted to review any non-privileged documents in a manner consistent with Raymark's obligation to maintain the documents in its possession in the order in which they were discovered at Raymark's facilities and consistent with its obligation to make the documents available for inspection by other counsel throughout the country. At the time of the inspection, Raymark will designate those file drawers within the document depository in which responsive information is most likely to be found. Copies of documents requested will be provided at the propounding party's expense. 85 Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence as it fails to specify a particular, relevant product, time period and condition of exposure, it is vague and ambiguous because the products referred to are not defined and as phrased in the interrogatory are subject to various interpretations and is unduly burdensome and oppressive. Without waiving the foregoing objections and subject thereto, Raymark states that to the extent the information sought in this interrogatory can be ascertained from a review of Raymark's asbestos product sales records, the burden of deriving the information is the same for Raymark as for the party propounding this interrogatory, such records are located in a document depository at the offices of Pitney, Hardin, Kipp & Szuch, 163 Madison Avenue, Morristown, New Jersey 07960. Gathered from Raymark's facilities around the country, the documents are maintained in the same manner as they were discovered. Upon reasonable notice, counsel will be permitted to review any non-privileged documents in a manner consistent with Raymark's obligation to maintain the documents in its possession in the order in which they were discovered at Raymark's facilities and consistent with its obligation to make the documents available for inspection by other counsel throughout the country. At the time of the inspection, Raymark will designate those file drawers within the document depository in which responsive information is most likely to be found. Copies of documents requested will be provided at the propounding party's expense. 86. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence as it fails to specify a particular, relevant product, time period and condition of exposure, it is vague and ambiguous because the phrase "products . . . containing asbestos fibers" is undefined and capable of various interpretations, and it is unduly burdensome and oppressive. Without waiving the foregoing objections and subject thereto, Raymark states that to the extent the information sought in this interrogatory can be ascertained from a review of Raymark's asbestos product sales records, the burden of deriving the information is the same for Raymark as for the party propounding this interrogatory. Such records are located in a document depository at the offices of Pitney, Hardin, Kipp i Szuch, 163 Madison Avenue, Morristown, New Jersey 07960. Gathered from Raymark's facilities around the country, the documents are maintained in the same manner as they were discovered. Upon reasonable notice, counsel will be permitted to review any non-privileged documents in a manner consistent with Raymark's obligation to maintain the documents in its possession in the order in which they were discovered at Raymark's facilities and consistent with its obligation to make the documents available for inspection by other counsel throughout the country. At the time of the inspection, Raymark will designate those file drawers within the document depository in which responsive information is most likely to be found. Copies of documents requested will be provided at the propounding party's expense. 87. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence as it fails to specify a particular, relevant product, time period and condition of exposure, it is vague and ambiguous because the phrase "asbestos containing products" is undefined and capable of various interpretations. and it is unduly burdensome and oppressive. Without waiving the foregoing objections and subject thereto, Raymark states that to the extent the information sought in this interrogatory can be ascertained from a review of Raymark*s asbestos product sales records, the burden of deriving the information is the same for Raymark as for the party propounding this interrogatory. Such records are located in a document depository at the offices of Pitney, Hardin, Kipp & Szuch, 163 Madison Avenue, Morristown, New Jersey 07960. Gathered from Raymark*s facilities around the country, the documents are maintained in the same manner as they were discovered. Upon reasonable notice, counsel will be permitted to review any non-privileged documents in a manner consistent with Raymark's obligation to maintain the documents in its possession in the order in which they were discovered at Raymark's facilities and consistent with its obligation to make the documents available for inspection by other counsel throughout the country. At the time of the inspection, Raymark will designate those file drawers within the document depository in which responsive information is most likely to be found. Copies of documents requested will be provided at the propounding party's expense. 88. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence as it fails to specify a particular, relevant product, time period and condition of exposure, it is vague and ambiguous because the phrase "asbestos containing products" is undefined and capable of various interpretations, and it is unduly burdensome and oppressive. Without waiving the foregoing objections and subject thereto, Raymark states that to the extent the information sought in this interrogatory can be ascertained from a review of Raymark's asbestos product sales records, the burden of deriving the information is the same for Raymark as for the party propounding this interrogatory. Such records are located in a document depository at the offices of Pitney, Bardin, Kipp k Szuch, 163 Madison Avenue, Morristown, New Jersey 07960. Gathered from Raymark's facilities around the country, the documents are maintained in the same manner as they were discovered. Upon reasonable notice, counsel will be permitted to review any non-privileged documents in a manner consistent with Raymark's obligation to maintain the documents in its possession in the order in which they were discovered at Raymark's facilities and consistent with its obligation to make the documents available for inspection by other counsel throughout the country. At the time of the inspection, Raymark will designate those file drawers within the document depository in which responsive information is most likely to be found. Copies of documents requested will be provided at the propounding party's expense. 89. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence as it fails to specify a particular, relevant product, time period and condition of exposure, it is vague and ambiguous because the phrase "asbestos containing products" is undefined and capable of various interpretations, and it is unduly burdensome and oppressive. Without waiving the foregoing objections and subject thereto, Raymark states that to the extent the information sought in this interrogatory can be ascertained from a review of Raymark's asbestos product sales records, the burden of deriving the information is the same for Raymark as for the party propounding this interrogatory. Such records are located in a document depository at the offices of Pitney, Hardin, Kipp 6 Szuch, 163 Madison Avenue, Morristown, Mew Jersey 07960. Gathered from Raymark*s facilities around the country, the documents are maintained in the same manner as they were discovered. Upon reasonable notice, counsel will be permitted to review any non-privileged documents in a manner consistent with Raymark's obligation to maintain the documents in its possession in the order in which they were discovered at Raymark's facilities and consistent with its obligation to make the documents available for inspection by other counsel throughout the country. At the time of the inspection, Raymark will designate those file drawers within the document depository in which responsive information is most likely to be found. Copies of documents requested will be provided at the propounding party's expense. 90. Raymark objects to this interrogatory because it is overly broad in that it seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence as it fails to specify a particular, relevant product, time period and condition of exposure, it is vague and ambiguous because the phrase *asbestos containing products" is undefined and capable of various interpretations, and it is unduly burdensome and oppressive. Without waiving the foregoing objections and subject thereto, Raymark states that to the extent the information sought in this interrogatory can be ascertained from a review of Raymark*s asbestos product sales records, the burden of deriving the information is the same for Raymark as for the party propounding this interrogatory. Such records are located in a document depository at the offices of Pitney, Hardin, Kipp & Szuch, 163 Madison Avenue, Morristown, New Jersey 07960. Gathered from Raymark*s facilities around the country, the documents are maintained in the same manner as they were discovered. Upon reasonable notice, counsel will be permitted to review any non-privileged documents in a manner consistent with Raymark's obligation to maintain the documents in its possession in the order in which they were discovered at Raymark's facilities and consistent with its obligation to make the documents available for inspection by other counsel throughout the country. At the time of the inspection, Raymark will designate those file drawers within the document depository in which responsive information is most likely to be found. Copies of documents requested will be provided at the propounding party's expense. 91. See our objections to the preceding interrogatories. VERIFICATION STATE OF CONNECTICUT ) 'COUNTY OF FAIRFIELD ) JOHN KUTZLER, being duly sworn, according to law, upon his oath, deposes and says: I am Controller and Assistant Secretary of Raymark Industries, Inc. and am authorized to make this verification on its behalf; I have read the foregoing Answers to Interrogatories and know their contents; the facts stated therein are not within my personal knowledge, the facts have been assembled by authorized employees of Raymark Industries, Inc., and I am informed and believe and, based upon such information and belief, declare that the facts stated therein are true. JOHN KUTZLER CERTIFICATE OF SERVICE I hereby certify that I have this the day of , 1985, served a copy of the foregoing on all counsel by mailing same to each by U.S. Mail, postage prepaid and properly addressed. OF COUNSEL: STARNES & ATCHISON One Daniel Plaza Daniel Building Birmingham, AL 35233 (205) 252-9333 OF COUNSEL cc Ronald L. Motley, Esq. BLATT & PALES P. 0. Box 365 Barnwell, South Carolina 29812 Jack J. Hall, Esq. MCDANIEL, HALL, PARSONS, CONERLY, SCOTT & LUSK 725 First Alabama Bank Building Birmingham, Alabama 35203 Erlining Riis, Jr., Esq. VICKERS, RIIS, MURRAY & CURRAN P. O. Box 990 Mobile, Alabama 36601 Robert A. Huffaker RUSHTON, STAKELY, JOHNSTON & GARRETT P. O. Box 270 Montgomery, Alabama 36195 Edward J. Vulevich, Jr., Esq. AUSA P. O. Drawer E Mobile, Alabama 36601 Edward P. Turner, ESq. P. O. Drawer 130 Chatom, Alabama 36518 J. Garrison Thompson, Esq. PITTS, PITTS & THOMPSON P. O. Box 537 Selma, Alabama 35701 Lawrence J. Hallett, Jr., Esq. 503 Government Street Mobile, Alabama 36602 John W. Clark, Jr., Esq. CLARK & SCOTT 14 Office Park Circle Suite 207 Birmingham, Alabama 35223 Bernard Starr, Esq. 538 Anderson Avenue Cliffside Park, NJ 07010 Thomas W. Tardy, III, Esq. THOMAS, PRICE, ALSTON, JONES & DAVIS P. 0. Drawer 1532 Jackson, Mississippi 39205 Ben H. Harris, Jr. JOHNSTONE, ADAMS, BAILEY & GORDON P .0. Box 1900 Mobile, Alabama 36633 Thomas J. Kirkland, Jr. SATTERFIELD 6 ALLRED 1000 Plaza Building P. 0. Drawer 1120 Jackson, MS 39205 John H. Carlson, Esq. P. O. Box 149 Pascagoula, MS 39567 W. F. Goodman, III, Esq. P. N. Harkins, III, Esq. WATKINS 6 EAGER P. O. Box 650 Jackson, MS 39205 Horace Moon, Jr., Esq. MOON & JONES 2151 Government Street Mobile, Alabama 36606 J. Don Foster, Esq. FOSTER, BRACKIN & BOLTON, P.A. 1715 North McKenzie Street Foley, Alabama 36535 W. A. Kimbrough, Jr., Esq. TURNER, ONDERDONK, BRADLEY & KIMBOUGH, P.A. P. 0. Box 2821 Mobile, Alabama 36652 Larry W. Harper, Esq. PORTERFIELD, SCHOLL, BAINBRIDGE, MIMS k HARPER #2 Office Park Circle Birmingham, Alabama 35223 Bibb Allen, Esq. LONDON, YANCEY, CLARK k ALLEN 1250 Park Place Tower Birmingham, Alabama 35203 Donald Stewart, Esq. CABANISS, JOHNSTON, GARDNER, DUMAS k O'NEAL P. O. BOX 2906 Mobile, Alabama 36652 Larry V. Sims, Esq. James B. Newman, Esq. COALE, HELMSING, LYONS k SIMS P. O. Box 2767 Mobile, Alabama 36652 Tom McAlpine, Esq. SINTZ, PIKE, CAMPBELL k DUKE 3763 Professional Parkway Mobile, Alabama 36609 Christopher G. Humr, III, Esq. GAILLARD, LITTLE, HUME & SULLIVAN P. O. Box 164 Mobile, Alabama 36601 James C. Johnston, Esq. JOHNSTON, JOHNSTON & KENDALL P. O. BOX 550 Mobile, Alabama 36601 Bert S. Nettles, Esq. NETTLES, BARKER & JANECKY 3311 First National Bank Bldg. P. O. Box 2987 Mobile, Alabama 36602 Robert M. Galloway, Esq. Robert H. Smith, Esq. COLLINS, GALLOWAY & SMITH P. O. BOX 16629 Mobile, Alabama 36616 Grey Redditt, Jr., Esq. KILBORN & REDDITT P. O. Box 1072 Mobile, Alabama 36633 James H. Crosby, Esq. BROWN, HUDGENS & RICHARDSON, P.C. P. O. Box 16818 Mobile, Alabama 36616 Janes A. Phillips, Esq. P. 0. Box 81437 Mobile, Alabama 36689 Dennis McKenna, Esq. INGE, TWITTY, DUFFY & PRINCE P. 0. Box 1109 Mobile, Alabama 36633 Bibb Allen, Esq. LONDON, YANCEY, CLARK & ALLEN 1250 Park Place Tower Birmingham, Alabama 35203 James W. Tarlton, III, Esq. HAMILTON, BUTLER, RIDDICK, TARLTON & ALLEN P. 0. BOX 1743 Mobile, Alabama 36601 Sam W. Irby, Esq. TAYLOR, BENTON, IRBY & GIBSON P. O. Box 1031 Fairhope, Alabama 36533 Jack Morgan, Esq. MORGAN & BURNS P. O. Drawer 1583 Mobile, Alabama 36633 Wesley Pipes, Esq. Walter M. Cook, Jr., Esq. LYONS, PIPES & COOK P. 0. BOX 2727 Mobile, Alabama 36652 Richard Vollmer, Esq. REAMS, TAPPAN, WOOD, VOLLMER, PHILLIPS & KILLION, P.C. P. 0. Box 8158 Mobile, Alabama 36608 Richard F. Pate, Esq. PATE & PETERS P. 0. Drawer 1308 Mobile, Alabama 36633 Mary Elizabeth M. Rouse, Esq. 718 Downtowner Boulevard Mobile, Alabama 36609 Richard L. Josephson, Esq. BAKER fc BOTTS 3000 One Shell Plaza Houston, Texas 77002 Edward B. McDonough, Jr. MCDONOUGH & BROOME P. O. Box 1943 Mobile, Alabama 36633 Clerk of Court United States District Court Southern District of Alabama United States Courthouse 113 St. Joseph Street Mobile, Alabama 36602 C:1038 Ride.t' ft ^7 / A. RAYMARK TEXTILE PRODOCTS AND TRADE NAMES X. Chrvsotile Products Product Approx. Date First Sold Approx. Max. Appearances Asbestos % Intended Use Lap* Roving Cable filler Glassbestos Yarn Rovatex Sealsafe 1935 1929 1938 1940 1929 1972 1975 100 Convolute coiled Electrical felt insulation 95 Untwisted thread Raw material for textiles 100 Twisted thread Electrical cable 80 Twisted thread insulation 95 9 100 9 80 9 9 Raw material for 9 textiles and sewing 9 thread for lagging and heat resistant fabrication Rope* Wide* 1929 1929 90 Twisted Rope Sealing material 90 Loosely twisted 9 9 doth Glassbestos Rhinobestos Polybestos* Silvabestos Rovatex Speedlag* 1929 1940 1946 1955 1959 1967 1969 95 80 W oven fabric Miscellaneous heat and flame resistant 90 9 applications such 9 as welding cur 85 9 tains, fire chedcs. lagging cloth, 75 100 9 laminate reinforeing, etc. 9 65 Adhesive coated Pipe lagging woven fabric T26A  Product Approx. Date First Sold Eleven Thirty- 1971 three Tribestcs* 2971 Sealsafe 1975 Gdcfcestos* 2959 Novabestos* Flurobestos 1947 2955 Terrybestos* 1957 Felts 2938 Approx, Max, Appearances Asbestos % 90 Woven fabric 90 Woven fabric 80 Treated doth 70 Ooated doth 95 Wbven Cloth 75 Fluorocarbon 80 Tufted doth 100 Paper coil or roll Tape Gatortape GLassbestos Sealsafe Novatex Pyrotex Allbestos* Novabestos* Tubing Novatex Sealsafe 1929 2963 1942 2975 1970 2938 1941 2947 1929 2973 1975 85 Convolute coil 80 m 80 9 m 9 80 100 60 m 9 80 9 85 9 100 100 80 m 9 9 9 Intended Use Miscellaneous Safety dothing Safety dothing Ironing board covers Miscellaneous Chemical resistant ooated doth Gloves Electrical insulation and/or laminate reinforcement Electrical and/or thermal insulation and/ or fire resistance Filtering and protective aovering for pipes and tubing Discontinued products: Novabestos - 2964 Terrybestos - 1960 Goldbestos - 2970 Speedlag - 1976 Polybestos - 1979 Tribestos - 1979 Lap - 2981 Rope, Wick - 1981 Allbestos - 1981 W T26B % Product Approx. Date Approx. Max. Appearances Pi rat Sold Asbestos % n. Crocidollte Products Intended Use Packings* Valve Rings* 2929 1950's Cbiled or twisted Mechanical rope applications Untwisted Thread Mechanical applications Discontinued products: Packings - 1972 Valve rings - early 1970's HI. Amoslte Products Blankets* 1929 Tape* 1940 100 Woven blanket Electrical and/or thermal insulation for U.S. Navy Convolute coil Electrical and/or thermal insulation Discontinued products: Blankets - 1944 (also manufactured between approx. 1950-53) Tape - 1970 IV. Anthochyllite Products Paper 1958 100 Compressed threads Automatic trans mission applica tions f T26C  fVidcr 'b Itaym ark bat performed studies at the below listed customer locations to determine the extent of airborne concentra tions of asbestos fiber during the sse, installation or fabrication of its textile asbestos products: Detyens Shipyard, Mount Pleasant, S.C. (April 28, 1975) (cloth) Worth Brothers, Znc. (National Service Industries), Atlanta, Georgia (August 13, 19*75) (cloth) A-Best Corp., Cleveland, Ohio (November 11, 1975) (safety clothing) C.D. Genter Co., Chattanooga, Tenn. (February 25, 1976) (gloves) W.S. Palmer Co., South Boston, Mass. (November 8, 1978) (curtains) Abney Kills Co., Greenville, S.C. (January 20, 1976) (paper makers felts) Boechst Fiber Co., Spartanburg, S.C. (September 29, 1976) (weaving cloth) * Westingbouse Electric Co., Hampton, S.C. (March 9, 1976) W.E. Palmer, Boston, Mass. (December, 1978) (curtains) Frosaelt Industries, Dubuque, Iowa (March, 1979) (cloth) . Lanco Industries, Jackson, Mo. (March, 1979) (cloth) These tests were performed principally under the direction of Patrick Cooper, Manager of Environmental Services, Baybestos-Manhattan Industrial Products Company, North Charleston, S.C. (1975 and 1976 tests) and John 0. Pearson, Bayaark's Corporate Industrial Eygienist (1978 and 1979 tests). In each of these tests, the fiber counts recorded were below prescribed limits. In no case in which Raymark has conducted dust counts in areas involving the us*e of Raymark materials sold for use by insulation mechanics has there been any indication that allowable airborne fiber concentrations in effect at the time of such tests have ever been exceeded. Xn addition, Rayiirk conducted ilillir tests at Its (onir Vorth Charleston, t.C. location on the following Raymark textile asbestos productst* Allbestos Tape (Kerch 16, 1977) 9F13SN AAAA Sealsafe Cloth (June 6, 1977) 1-71-1133 Sealsafe Cloth (June 6, 1977) BP125R AAAA Heoprene Coated Cloth (Kay 16, 1977) 201R Am 1-1/2* s 1/16* tape (September 26, 1977) PL-6164 Catalytic Converter Seal (January 13, 1978) 1-75-1996N Sealsafe Coated Braided Tubing (January 13, 1978) During the years 1974 through 1976, Raysark funded tests at McGill University, Montreal, Canada in order to deteralne relative "dustiness* of different types of asbestos fabric and to compare relative rates of fiber release between dif ferent fabrics during severe use or abuse. The studies were conducted by Grahas V. Gibbs, KSC, PhD., L.R.2.C. and were authorised by John B. Marsh, Director of Snvironaental and Governaent Affairs, on Kay 11, 1973. The results of the tests set forth airborne fiber concentrations recorded during laboratory tests of various asbestos fabrics but did not Indicate the concentrations which sight be found if these naterials were tested under different conditions, or in another testing system, or during the normal use, fabri cation or handling of the materials. Four reports were issued as a result of these studies: "Tests of Fiber Re lease from Three Asbestos Fabrics,* (July 3, 1975); Laboratory Tests of Fiber from 19 Asbestos Fabrics," in (September 1976); *Fiber Release from Asbestos Garments"; and "Dimensions and Concentrations of Airborne Fibers En' countered in the Work Environment During Conventional and HOVATEX Asbestos Processing.* The results demonstrate only the relative release of fibers by fabrics when subjected to the stresses as applied in the laboratory tests. To the best of Raymark's knowledge, no statistical analysis was made of the test results. 37B Riole r C With the exception of the development of the patented "wet process" system for manufacturing Novatex asbestos yarns and textiles, there were no modifications of the basic composition of Raymark's asbestos textile products from the time of their original development until 1982, when Raymark sold its asbestos textile plant in North Charleston, South Carolina. During that time Raymark did discontinue the manufacture of some products due to lack of sales and did develop non-asbestos substitutes for some asbestos textile products. t United States Chamber of Commerce 1615 B St., N.W. District of Columbia 20062 N/A - present r i T8C ftid&r D A. No such notice was deemed necessary because exposure to airborne fiber levels generated by the installation of Raymark products furnished for use by insulation mechanics ( are below those limits at which health effects are known to occur and below limits recommended by industrial hygiene authorities. Raymark's asbestos products furnished for use by insulation mechanics were basically textile in nature, composed of relatively long textile grade asbestos fiber that does not readily become airborne during normal use, fabrication and/or handling in the environment of in dustrial insulation mechanics. Raymark does not believe these materials presented health hazards to mechanics who used them in the course of their work. However, beginning in July 1972, in an attempt to further insure against misuse of its products, Raymark placed caution labels on products where asbestos fibers were not encapsulated. This was done in accordance with the OSHA standard, effective in June 1972. Beginning in 1974, cautions were placed on all asbestos products furnished by Raymark stating, in accordance with OSHA requirements: CAUTION. CONTAINS ASBESTOS FIBERS. AVOID CREATING DUST. BREATHING DUST MAY CAUSE SERIOUS BODILY HARM. The caution label has been on each package of each shipment from Ray mark plants since the date that the warnings first were used. The cautions were placed on products by means of ink, sten* cil, pressure sensitive adhesive label, preprinted adhesive tape, preprinted packaging or wrapping material and printed paper tags. These cautions are in regular. use at each T42A > hipping location that handles asbestos-containing prod ucts. In addition, since sometime in 1975, Raymark distributed a booklet entitled "Recommended Work Practices, Use and Hand ling of Asbestos Textile Products" to customers of textile products. Since mid-1975, Raymark has distributed an asbestos "information list" to many of its customers and other Interested parties. This list contains recommended work practices and information on monitoring services and protective equipment, among other things. In addition to caution labels on packages, printed work practice instructions have been included in all shipments of asbestos-containing friction materials since in or about mid-1975. These instructions read as follows: IMPORTANT ASBESTOS DUST HAZARD Do not breathe dust Do not use air hoses for cleaning Do not machine without dust collection equipment Do use vacuum or wet cleaning methods Do dispose of dust in sealed container Do wear mask if unable to avoid dust rr Customers have been apprised of the need for precautions against airborne asbestos dust hazards by means of printed bulletins from time to time since approximately January 1975. Early in 1977 Raymark distributed an "Environmental Pack age" to its asbestos textile customers. This package con tained a copy of the aforementioned booklet, along with an up to date copy of the OSHA asbestos regulation, a summary of the results of certain laboratory tests of fiber release from asbestos fabrics conducted at McGill University, a list of suppliers of protective equipment, a list of laboratories and consultants offering asbestos dust moni toring services and a list of suppliers of vacuum cleaners and sources of information on design and control of local exhaust systems. The "Environmental Package" was assembled by John E. Day, Jr., Director of Environmental Programs at Raymark's former plant in North Charleston, S.C. Beginning in or about October 1977, Raymark provided the following notice on those of its asbestos textile products which, despite being treated with a dust-suppressing binder to fully encapsulate the asbestos fibers, might release airborne fiber levels in excess of OSHA limits if subjected c to significant abuse: T42B NOTICE This asbestos product Is manufactured with a dust-suppressing binder for the express purpose of locking-in fibers during normal use. Care should be used while handling all asbestos products so as to avoid abuse and excessive dust emission. For detailed information, consult the handbook "Recommended Work Practices - Use and Handling of Asbestos Textile Products," published by the Asbestos Information Association. A copy will be sent to you upon request. Write to: Textile Group R/M Industrial Products Company P.0. Box 5205 North Charleston, S.C. 29406 The work practice instruction sheets were authorized by John H. Marsh, Director of Environmental and Government Affairs, Raymark Industries, Inc., 100 Oakview Drive, Trumbull, CT. The booklet entitled "Recommended Work Practices - Use and Handling of Asbestos Textile Products" was obtained from the Asbestos Information Assocation. The caution labels are attached directly to the outside of asbestos products packages prior to shipment from Raymark plants. Work practice sheets are inserted inside friction materials containers prior to shipment. AIA booklets have been distributed by hand and by mail, and to the best of Raymark's knowledge no record has been kept of these distributions. The "Environmental Package" was circulated by mail to asbestos textile customers. Aside from the aforementioned booklets, Raymark did not provide its customers with any special instructions. Raymark as a rule does not furnish application or installation instructions with products sold for use by insulation mechanics. Procedures for the use of these materials are believed to be so old and wellknown as to constitute state of the art technique and are not published or disseminated by Raymark. Rider E A. Raymark from time to time advertised its asbestos-contain ing products in one or more of the following magazines and trade journals: Asbestos Magazine Canadian Cleaner and Launderer Occupational Safety and Health ' National Safety News Design News Machine Design Materials Engineering Occupational Hazards Industrial Laundry Linens Laundry Digest Linen Supply News Business Week Forbes Fortune Power Engineering Chemical Processing Chemical Engineering Industry Week Automotive Industries Automotive Engineering Wards Automotive Yearbook SAE Regional Publications Purchasing Magazine Industrial Fabric Products Review The Guide Fire Journal Hospital Progress Industrial World Transporte Moderno Auto Intenational (Spanish Ed.) Motriz Welding Design and Fabrication Occupational Hazards National Safety News Industrial Safety Products News Samples of typical advertisements in such magazines and journals are attached hereto. Raymark also advertised many of its asbestos-containing pro ducts in catalogs and informational brochures published from time to time. These materials were distributed nationwide upon T11A the request of customers and sales representatives. Those catalogs and brochures contained, inter alia, product descrip tions, product applications, product specifications, price lists and photographs. The following asbestos-containing pro ducts were advertised in these publications: Asbestos Lap; Asbestos Roving; Asbestos Cable Filters; Yarn; Asbestos Thread; Asbestos Cord and Steam Bose Yarn; Twisted Cord and Braided Cord; Woven Asbestos Tape; Thermal Insulating Tape; Beat Insulating Tape; Lagging Cloths for Thermal Insula tion; Asbestos Cloth; Asbestos Cloths for Reinforced Plastic Laminates; Asbestos Cloth for Safety Garments; Braided Asbestos Tubing; Novabestos Papers; Novabestos Insulating Tapes; Pyrotex Felts and Tapes; Tru-Blu Wicking; Woven Glass; Quik Flame; Kindlerite; Speedlag Cloth; Gator Tape Cable Insulating Tape; Novatex Textiles; Sealsafe Asbestos Products. TUB v^r wT Ma 5P r&2 & 9t&gK4&&' w^`^vXv*.1 .V- -.. W* *.*. V*:i* v >. *' \rlC '**'"' *' *** :V*;/Aff,iii^ASsV5!i n fl P^;V^v:;-:. is? vr-l as 1 "u?r - __..t .'j-iv'-- KC - -- -- --i-U*g ** *? --*,'r=~.- >_ .t '.> ` C .-i ; 1 -At . * Zj ^-v *5*35 in c-1 j: >*-. ~.v>* fes r f*rr* ...S^ a?S5gsr-?-t G^'iS^v sra&; -'ZS^tr- ,*Jfr -** _*r, jp^S-ri s^a^38asra: ^Saafaa^- -*:; *rry n--~-.i.'t->.-vr rxw- - *- tall*- C'r./ f-Vi'^vVj",, .-.s ^ . `t ,, r*3l*A^. v-*i- fes3wj r-sg riiy^aLSuppri ^eeq^ne^jrearj^rojecior* t ^uoricdats^sinis'leggingsranrfaprons^alumrnized bfSjpSa Ms.exclu5iveTtew;annin eliminate^crjoanjn artfcwerSibers^frtSm' ittecL ^ icrylicireanjgcapsulates ramatiaI|ffl3HlucJCpn)^[surjebjjun. uo^SWQWTD^ipducfc^treateSlliioJ raciice 3Es5stronge iakmcwt=easierto QVATEXprodu .. *SZ>J .L~\-r\z7>fa> -t*. -r-.7 --- -:... - yjSSSSZtnm* 22*10concmjesion' < > '"-saf >s T^'vts.v rprrr.'VSS.'^r/fs'f./St* Tj;?vf ' otvip abamio blfv; **3pic ?? *. 077 <5*0# 70* 13 * ---:*? ~rr I ESSS*- ?^T*K-JC CfrS:"^fS*\--- * rn _ **>_ *; * c&r^ i* \ , i III B B E E 155a e -J ' .* : _ _j ' 1 fl c b-M 1 TV: ifetaspEJ*-- v^r *.* i ^**4 1 r :A i E 7 li JPE j i.V< . :? A .. . i,.CIiANBi THAN OSHA RBJUIHES ?l^t rtettKt MtfcJ^.NOVATEX!. ^. -.^Vtiw .xdusive NOVATEX process eliminates the ' Raybestos Manhattan has developed an exclusive 'conventional yarn forming with mechanical opening,' . forming process for NOVATEX yams.'The/re ; blending, carding and spinning. Far fewer fibers ' . Jextmdedwef through a'rozzie instead of formed are emitted. What's mo/e, NOVAJEX textiles are . .,, <You can't get protection Eke NOVATEX, anywhere. -` treated with another exclusive Raybestos Manhattan SEALSAFE is an'acrylic which encapsulates asbestos fibers and dramat- . tiles Lighter weight*makes NOVATEX easier trations oTf SfibWersW.* HVeSre?aarethe results:* RM L^71-VJ33"i " : NOVATEX (untreated >1RM SEALSAFE] SEALSAFE torrest) "^] C-71-1133 0 RM9P135N :*.A^ STRONGER Vr-- y.'rv ZS- - | iHr i *tn nr. | let nr i n nr I-1M Hr j 4th Hr '- An average of 35% higher in tensile strength and _ 1.5 -- ... tear strength.7l6vATEX cloths have'b<e*n tested . ~ These test result'show .that when SEALSAFE ' . and used in-piant Even more strength aind^durability .resin treatment was added Jo NOVATEX doth, ' ' / " * ' *" --- fiber,emfssfon wasjreduced.by 63% in the first hour ' ' .. . . conventjonaj Cioth.' determined by counts are re/at/ve per cubic centimeter VOVATEX doth for welding screens, blankets and drop :urtams. Lignt weight long Be. ow cost When neoprene coated t is ideal for tha highly abusive iir carbon-arc gouging if `cations. NOVATEX doth is ideal for lagging over primary insula tion. Readily accepts tha mastics used in industrial and ship board insulation Whan installed. NOVATEX provides an attrac tive white appearance and is easy to wipe clean Use the NOVATEX tubing as a sleeve or collar on hydraulic lines, cables or hot pipes. Protects people and equipment NOVATEX woven and SB tapes available n '/* through thicknesses provides superior insulation lor a wde variety of applications. NOVATEX IS ECONOMICAL Superior protective qualities, a revolutionary manu facturing process, unprecedented cleanliness... yet NOVATEX can actually cost less than many conventional asbestos products! The best for the least*. CLOTH, TAPE ANO TUBING ILCTH... for welding screens, blankets and drop curtains. Insulation for power plants, nuclear reac tors and shipboard and industrial insulating appli cations. Makes superb protective bodywear for coats, suits, leggings and aprons, aluminized or non-aiuminized. NOVATEX cloth coated with neoprene has been tested and used successfully in highly WOVEN ANO SLIT TAPES.... available in y^" through y4" thicknesses for superior insulation protection in a wide variety of applications. TUBING... to keep heat in, to keep heat out. Protects people and equipment as a sleeve or colla tor hydraulic lines, hot pipes or cables. WE CALL rr THE GREAT PROTECTOR. Because the unique NOVATEX process gives you a textile that is cleaner, more protective and more economical than most conventional textiies. It's your greatest choice for welding applications, insulation and protective clothing. 'EC1FY NOVATEX sk for the Great Protector. If :ur welding supply house or stributor can't supply you with OVATEX. call us toll-free. : 1-800-845-8546. T. Microphotography shows a chemical preparation of mineral libers as small as .000025' in diameter. Z A .002-inch Inconel wire strand is directly inserted in a fine NOVATEX yarn Shown compared to the head of a common pin. 1 A new loom operates at high speeds lor specialty woven applications. 4. High-speed loom weaves NOVATEX tapes tor insulation applications. 5. High tensile strength makes NOVATEX yarns ideal tor high-speed braiding. & NOVATEX cloth becomes SEALSAFz NOVATEX cloth with fte addition otacrylic resin This treavnent assures reoucec oust emission and aids corphance with QSHA. Textile Group RM Industrial Products Ca A division cf Hsivbesros Manh*rrAn Inr ( \ 7 SEALSAFE* resintreatment ) - emits fewer fibere tfian'untfeated --.: ; NOVATEX;doth?(See7SEALT .\f*\ . SAF^secSor^uten SafetyGaments-^oyes,'mittens, '*--;r coats! suits, leggings,'botri^- . ' aluminized andJidn-aiuminized!. - -' Industrial Insulatorwiuclear . __ - * reactori power plants, 'shipboard.' 7 -' Welding-screens, blankets, drop -v^r curtains. ' ^ &7: r'-- ) - BULLETIN 2 : NOVATEX SLIT TAPE-for supreme protection in insulation: 1. Available in 1/16' and 1/32" thickness. 2. NOVATEX slit tape is SEALSAFE resin treated for minimal fiber emission. 3. Replaces ASTM Grades Commercial, Underwriters', AA. AAA. NOVATEX TUBING-superior ` resistant flexible sleeving. Available in 1/16" wall. 2. SEALSAFE resin treatment can be applied to NOVATEX tubing on request for minimal fiber emission. 3. Replaces ASTM Grades Commercial, Underwriters', AA, AAA. NOVATEX YARNS--The ultimate, high tensile, high temperature ASTM Grade AAAA asbestos yams. 1. Variety of inserts available: Monel, Inconel, NOMEX", brass, phosphor bronze, stainless steel etc. 2. SEALSAFE resin treatment can be applied to NOVATEX yams on request for minimal fiber ^mission. v. 3. Replaces ASTM Grades Commercial, Underwriters', AA, AAA. Available for many braiding and weaving applications: -High temperature braided packings -Papermaker Dryer felts -High Pressure Steam Hose Yarn -High Temperature Insulated Wire NOVATEX SEWING THREAD-the definitive high temperature sewing thread. 1. High yield. 2. High tensile. 3. Uniform smooth surface. Five Types-- Safer and More Versatile NOVATEX products have a higher tensile strength than any conventional asbestos textile at equal weights. They're ASTM Grade AAAA--99 to 100% asbestos. * DuPont Rejsterec Trademark. at %!' , mn 'mwgas&gm ifi tiTF1 A . . a wwviww ** **wmi i iw* i iw ?n . ;The best asbestos for protective clothing. V : -v; .A. " % * "* * .* * '*'-'<1* ;* *rV* N * T* THE PATENTED NOVATEX PROCESS: *" NOVATEX processis a new technique of .* ... . 'forming asbestos yams. They are extruded ' wet. through a nozzle, instead of formed dry. Unlike conventional methods where the * . yam forming process involves mechanical opening, blending, carding and spinning. " _ .. NOVATEX yams are formed by an extru- " ; sion process from a wet slurry dispersion. _ NOVATEX yams are ASTM Grade AAAA . * (99-100%) asbestos.They represent a techno logical breakthrough in the asbestos textile . ~ Industry. / ^ ; O1-*''' ' /vi.;-.' ,, ' From these yarns'are*made the family of *. * / NOVATEX asbestos textiles. Cloth, tapes, ' .. tubings, yarns and threads are manufactured * for sale to a variety of markets. Most of the . , NOVATEX products are acrylic treated and ": -; 'dried for reduced dust emissions. When this . . occurs, they are then called SEALSAFE . * * products and help you comply with the - - OSHA standard regarding asbestos (See . V-Vf- 4\ / . ` `* . NOVATEX ^..CONVENTIONAL TEXTILES. . v. NOVATEX gamient cloths are lighter,. stronger and have a higher insulating - value than oW-fashioned conventional . textiles:..^. . . : ; ` -. ' ' v NOVATEX vs. Conventional ` ' - -i ..... . 9P134N 7P150N L-71-1133 -. `Weight. ;. * - , . I (p/sq/yd) 1-3* :.TJ0 .235- ^ ' v Tensile - W F- W F W F V - (#.). ' > 225 X 125 225X120 145 X 55 ... Abrasion* ' . . . (cycles) ` 780' ' 650 - - 450 - " . Temperature :. (Emit) 900* F 900* F ' 450*F : . -. K-Factor** ` .7. .7 . . 1.0 ... . ' Tested on WyzenOeck tester, material changed every . 300 cycles. - .. . . "The tower the K-Factar. the greater the insulating value. - TABLE 1 i ' . .SEALSAFE NOVATEX AND OSHA - SEALSAFE NOVATEX textiles help you and your customers comply witn the OSHA - standard concerning asbestos. . . -SEALSAFE--OUR ACRYLIC RESIN ; -'-. TREATMENT . . t* , ' CLOTH TESTS* ` ` . ; Comprehensive tests' were conducted in an " . - independent laboratory to measure airborne . 'concentrations of fibers. The tests were ' ` . performed on an untreated conventional : - cloth (L-71-ri 33). a SEALSAFE conventional V - cloth (L-71-1133) and a SEALSAFE : NOVATEX cloth. The results" are as - ` follows: Oescrip- R/M L-71 -1123 P./M SEALSAF= NOVATEX tiar. (L'matec L-71 -1122 SEALSAFE - For Test!n/M 9P125N 1st Hr. Hr. 1st Hr, atn r: is: Hr ttr. Hr, Range 4.6 Z Z* 1.6 1.7 ti The results oeircrtstrate tne relative retesse of fibers by tafincs when s^-er.er tc sie stresses as applied m the lassratory tesa Copies at test results available upen tepuest to flavbestps Mannanan insusrai Products Company. Nom Cttanestcn, Soutri Carpcta 23*C6. PROTECTIVE GARMENTS `: 1. SEALSAFE NOVATEX CLOTHS ` . .- FOR GLOVES AND MITTEN$ Strong, lightweight gloves and mittens made of SEALSAFE NOVATEX cloth: High abrasion, excellent seam strength ' for longer life. We offer two cloths for specific applications. 9P134N for tradi- ' tional usages, 7P150N for extended life and endurance. NOVATEX sewing thread enhances the final product . Z SEALSAFE NOVATEX CLOTHS FOR GARMENTS - *-. SEALSAFE NOVATEX cloth offers the . * garment wearer lighter weight with greater protection than conventional asbestos. Fabrication is easier, due to lighter weight and faster sewing. NOVATEX cloths . are suited for aluminizing in the 3-M . heat bank applicator. NOVATEX sewing thread enhances the final product'. . 3. SEALSAFE NOVATEX CLOTH ' .r 0 > WELDING APPLICATION / ! - r <>" ASTM grade AAAA SEALSAFE. . " NOVATEX fabrics are used in applica tions up to 900 F. They are abrasion resistant and offer longer life due to Fighter weight with little tendency to snag or tear in use. Arc-Air Welding? Use neoprene coated NOVATEX doth. . 4. & 5. SEALSAFE NOVATEX CLOTH :: FOR OTHER BODY WEAR ---l When the worker wears other body wear made of SEALSAFE NOVATEX cloths, he is protected by lighter, stronger fabric than the old-fashioned conventional . asbestos. Good seam strength, high abrasion offer longer life. NOVATEX sewing thread enhances the final product. WBESTOS MANHATTAN DVATEX--The best asbestos, e next asbestos, til us today. We'll arrange a no* >liga!ion meeting with a Raybestos anhattan representative anc you ;.n explore the profit potential of DVATEX products in your protective irment operations. 1. Microphotography shows a chemical preparation of mineral fibers as small as .000025" in diameter. 2. A .002 inch Inconel wire strand is directly inserted in a fine NOVATEX yam. Shown compared to the head of a common pin. 1 100% Asbestos NOVATEX yarns are created in a new chemical process plant 4. NOVATEX yarns are beamed r feed high speed looms. 5. A new loom operates at high speeds forspecially woven facres. 6. NOVATEX cloth becomes SEALSAFE NOVATEX cloth with addition of acrylic resin. > ris treatment assures reduced dur. emission. A ( toe isnhetten Industrie! Products Company n* r **___i____ i___ !. ,, _ .  R,-flier F A. In or about 1929, Raymark became aware of a reported rela tionship between exposure to asbestos dust, in certain as bestos products manufacturing operations, and certain ad ' verse health effects if excessive amounts of asbestos fibers were inhaled. The reports originated in England and pertained to exposures in British asbestos textile manufac turing plants. It is believed that the source of the in formation was the "Report of Effects of Asbestos Dust on the Lungs and Dust Suppression in the Asbestos Industry" by E.R.A. Merewether and C.W. Price, published in 1930. It is unknown from whom this information was received and to whom it was directed. Shortly after becoming aware of the alleged relationship, in approximately 1929, Raymark commissioned the Metropoli tan Life Insurance Company to survey its plants and make recommendations for the elimination of conditions that might present health hazards. The Metropolitan studies / concerned only occupational exposure in Raymark manufactur ing operations, which are quite dissimilar from conditions that occur during installation of Raymark products sold for use by insulation mechanics. In other words, the tests dealt with exposures that were significantly higher and over longer periods than those to which insulation workers were thought to be subject in the installation of Raymark's products marketed for use by insulation mechanics. The results of this study, "Effects of Asbestos Dust on the Lungs of Asbestos Workers," were published by Dr. A. J. Lanza, et al. in Public Health Reports (Jan. 4, 1935). It is believed that this was the first study conducted in the United States which reported a relationship between exposure to asbestos in manufacturing plants and the disease of asbestosis in plantworkers. In 1936, Raymark, in cooperation with several other asbes tos products manufacturers, made arrangments to have a study conducted by the Trudeau Foundation at Lake Saranac, N.Y. to determine the relationship, if any, between pul monary pathologies and asbestos dust exposure. These studies were limited to experiments with animals. Results of these studies are contained in a paper entitled, "Exper imental Studies of Asbestosis" by Arthur Vorwald, Thomas Durkan, and Philip Pratt. The paper was published in AMA V Archives of Industrial Hygiene and Occupational Medicine. , January 1951, Volume 3, pages 1-43. In 1947, Raymark participated in an industry study conduct ed by Industrial Health Foundation, Pittsburgh, Pa. under sponsorship of the Asbestos Textile Institute of Philadel phia, Pa. to determine the nature and magnitude of the asbestos/health problem in asbestos textile manufacturing operations. The scope of these studies did not extend to asbestos-containing products or health hazards associated with their use or application. Raymark also participated in fibrous dust studies conducted by the Industrial Health Foundation from 1968 through 1970 and contributed $20,000 to these studies. To the best of its knowledge, Raymark does not have a copy of the final report from these studies. However, copies of several progress reports exist. It was not until late 1964, when Dr. Irving J. Selikoff, et al. made public the contents of a paper entitled, "The Oc currence of Asbestosis Among Insulation Workers in the United States," by X.J. Selikoff, et al., published in the Annals of New York Academy of Sciences, Vol. 132, Art. 1 (Dec. 1965), that the asbestos industry or the scientific or medical world perceived that there was a potential haz ard to the health of those working with and/or installing and/or applying finished industrial insulation products. Prior to that time, the only health hazards thought to be associated with asbestos concerned workers in factories continuously exposed to high levels of airborne respirable fibers generated from working with pure or almost pure asbestos over long periods of time. T41B Rider- F A. Raymark has been named as a defendant in a number of lawsuits in which plaintiffs allege personal injuries as a result of exposure to asbestos products manufactured by Raymark, among others. To the extent the interrogatory seeks additonal information, it is objected to as being overly broad, seeking information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence and because it is unduly burdensome and oppressive. ( * T9 9 fVidtr H A. Prior to 1976, Raymark did not have a central office or department dealing with medical research. However, from October 1976 through January 1981, Raymark employed Dr. Hilton C. Lewinsohn as its Corporate Medical Director. Dr. Lewinsohn was responsible for supervising and coordinating medical surveillance programs at all Raymark facilities and provided professional guidance and assistance in the ad ministration of a corporate industrial hygiene program. In addition, he participated in various medical and scientific programs relating to occupational health and was involved in research activities on the biological effects of asbes tos both in this country and abroad. Currently, Raymark*s corporate medical program is supervised by David M. / Gioiella, a Certified Industrial Hygienist hired in Sep tember, 1981 as Director of Raymark1 s Health and Safety Department. Both Dr. Lewinsohn and Mr. Gioiella reported to John H. Marsh, Director, Environmental and Government Affairs for Raymark. Although there is no separate medical department, there are individuals who have acted in a medical advisory capacity to Raymark in the past. Also, some Raymark plants have maintained medical departments or dispensaries. Raymark is not aware of the exact dates on which these facilities were established at Raymark's various plants. Occupational health programs by medical personnel have been conducted at each major Raymark manufacturing facility. Programs have included pre-employment and routine periodic physical ex aminations, including annual chest x-rays, medical treat ment of occupational injury and illness and medical record keeping. At smaller Raymark facilities where full time medical personnel are not employed, medical surveillance is provided by local physicians. hr T51 P<kr X Prior to 1976, Raymark employed no chief medical officer. Dr. Hilton C. Lewinsohn served as Raymark1s Corporate Medical Director from October 1976 until January 1981. Dr. Lewinsohn, hired by John H. Marsh, Director of Environ mental and Government Affairs, was responsible for evalua ting, developing, supervising and coordinating medical surveillance programs at all company facilities and pro vided professional guidance and assistance in the admin istration of Raymark's corporate industrial hygiene pro gram. He also participated in various medical and scien tific programs relating to occupational health and was involved in research activities on the biological effects of asbestos. Among the reasons that Raymark hired a medical director were to develop a uniform corporate-wide medical program to be followed at all Raymark facilities and to provide professional guidance and assistance'in the administration of a corporate hygiene program. Currently, Raymark's corporate health program is supervised by David M. Gioiella, a Certified Industrial Hygienist, hired by Raymark in September 1981 to serve as Director of Raymark*s Health and Safety Department. Rider J~ In September of 1977, John B. Marsh, Raymark Director of Environmental and Government Affairs, 100 Oakview Drive, Trumbull, Connecticut, 06611, hired Raymark's first indus trial hygienist, John 0. Pearson, who is presently employed by Raymark in that capacity. Prior to that date, Raymark never employed a certified industrial hygienist on its company payroll, but from time to time Raymark used its technical personnel at various plants to perform air moni toring tests. Raymark hired Mr. Pearson to assist in the development and coordination of its corporate industrial hygiene program. Mr. Pearson's duties are to work with and advise plant production management with respect to safe working prac tices and monitoring procedures and to work with the Corporate Research Laboratory, Stratford, Coiinecticut, to expand in-house analytical capabilities and to make indus trial field surveys and provide consulting services to corporate management, plant management, ventilation con tractors, design engineers and others pertaining to the effectiveness of proposed or existing systems for controll ing hazardous materials in Raymark facilities. In September of 1981, Raymark hired David Gioiella, also a Certified Industrial Hygienist, as Director of Raymark's Health and Safety Department. * Pndc^ K A. Raymark objects to this question because it is overly broad and seeks information which is neither relevant nor reason ably calculated to lead to the discovery of admissible evidence. In addition, the question is vague and ambiguous in failing to define the terms "recommendations and/or suggestions. ** * From time to time, suggestions have been made cautioning against excessive exposure to asbestos dust in manufactur ing operations. Such suggestions were received from Dr. J. L. Goodman, Plant Physician at Raymark's former facility in North Charleston, South Carolina. In addition, John H. Marsh, Raymark's Director, Environmental and Government Affairs and Dr. Hilton C. Lewinsohn, Raymark's former medi cal director, have made numerous recommendations concerning the operations of Raymark's manufacturing facilities and maintenance of healthful working conditions. Both Mr. Marsh and Dr. Lewinsohn contributed to the design and implementation of the corporate-wide occupational health program, which is in part based on observations made during visits to manufacturing facilities. In addition, John Pearson, Raymark's Corporate Industrial Hygenist, regularly visits Raymark's various manufacturing facilities and makes recommendations as necessary. T55 Lr A. For many years, Raymark has collected miscellaneous documents, journals, articles, and hooks pertaining to the effects of asbestos upon human health. These materials have been gathered and maintained over the years by a number of individuals and are currently maintained by John E. Marsh, Director of Environmental and Government Affairs and by Raymark's Health and Safety Department. Raymark subscribes to the following publications, most of which from time to time contain information or articles concerning asbestos: Archives of Environmental Health. Lancet, British Medical Journal. Annals of Occupational Hygiene. Occupational Health and Safety. Medical Hews f Digest. British Journal of Industrial Medicine. Chest. Environmental Research. American Journal of Medicine, New ^ England Journal of Medicine. Asbestos Journal of Occupa... tional Medicine. Science. Toxic Material News. OSHA Com " Pliance Letter. ' Federal Register. Environmental Health Letter. Occupational Health 6 Safety Letter. Environmental Issues, Occupational Hazards. National Safety News. American Industrial Hygiene Association Journal, Industrial Hygiene Digest, Journal of the Air Pollution Control As sociation, Environmental Science and Technology. Science News. Bureau of National Affairs Occupational Safety & Health Reporter. Environment. Environmental Health Letter. Water Pollution Control Federation. Business Insurance. Wall Street Journal, Pollution Engineering, and Bureau of National Affairs Chemical Regulations Reporter. T61A Raymark has held membership in numerous institutes, asso ciations, and organizations. Among these are: Air Pollution Control Association 4400 Fifth Avenue Pittsburgh, Pa. 15213 American Industrial Hygiene Association ' 66 S. Hiller Road Akron, Oh. 44313 American Society for Testing & Materials 1916 Race Street Philadelphia, Pa. 19103 Asbestos Information Association/ North America 1835 K Street, N.W. Washington, D.C. 20006 Asbestos Textile Institute P.0. Box 471 131 N. York Road Willow Grove, Pa. 19090 Automotive Parts Rebuilders Association 6849 Old Dominion Drive McLean, Va. 22101 Automative Service Industries Association 230 N. Michigan Avenue Chicago, 111. 60601 1970 - present 1974 - present 1940 - present 1970 - present 1944 - 1981 pre-1967 - present 1960 - present Brake Lining Manufacturers Association Dissolved in 1949 Approx. 1930-1949 Fluid Sealing Association (formerly Mechanical Packing Assn.) 2017 Walnut Street Philadelphia, Pa. 19103 1933 - 1974, Feb. 1977-present Friction Materials Standards Institute Inc. Bergen Mall Office Center E. 210 Route 4 Paramus, N.J. 07652 1949 - present Grinding Wheel Institute 2130 Keith Building Cleveland, Oh. 44115 1951 - 1971 Industrial Health Foundation, Inc. (formerly Industrial Hygiene f Foundation of America) 5231 Centre Avenue - Pittsburgh, Pa. 15232 1937 - 1957, 1968 - present National Association of Manufacturers 277 Park Avenue New York, N.Y. 10017 1915 - present National Safety Council Box 11171 Chicago, 111. 60611 1936 - present Organization Resources Counselors Inc 1625 I Street, N.W. Washington, D.C. 20006 1974 - present Rubber Manufacturers Association 1901 Pennsylvania Ave., N.W. Washington, D.C. 20006 Approx. 1930present Society of the Plastic Industry Inc. 335 Lexington Avenue New York, N.Y. 10017 1956 - present w T8B Rider A/ A. Z. B. Weaver and J. H. Marsh of Raymark testified at the United States Department of Labor Occupational Health and Safety Administration hearings on proposed asbestos stan dards on March 14, 1972. Dr. H. C. Lewinsohn, Raymark*s former Corporate Medical Director, testified before the Sub-Committee on Labor Standards of the Committee on Education and Labor of the United States Rouse of Repre sentatives on May 1, 1979. To the extent this inter rogatory seeks additional information, it is objected to as overly broad, unduly burdensome and oppressive. I ir Tim The following is a list of articles found in the informal medical library maintained by Raymark. This list may. be incomplete; it , is .not possible to certify that every "article `which may have been in Raymark's possession has been consulted and/or discovered in complying this re sponse. xpco** '. - ' *. . r- x \* 0k + J5 gS xI S *- ?; ** 4 I*.! :: tf. | 88 aa- a8 aa s gg xxa6O4 xi . xi el o X %o* MC s s 2 2S 1 1AA 1A AM| 5 33 / r- aa x 1 S0 .Wa2 5b JJ ie* X* "5 3^*M. taaa | sI 2 S xi > O a2 !?a ssiscS' a 5S Is is 3 -.2s s 2I*s( S3 <s o x* 2a xi aw. 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