Document v10Ebq0Qj1r933mZrypBazeQ9
IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS
LAURA PAZ, INDIVIDUALLY and SPECIAL ADMINISTRATOR OF the Estate of FARHAD DEHGHAN, Deceased, CHARLES T. MITCHELL, HANS J. RADDATZ and MELITTA RADDATZ,
Plaintiffs,
v.
A.W. CHESTERTON, et. al.;
Defendants
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No.
MR. LARRY ROSLINSKI VIDEOTAPED DISCOVERY DEPOSTION
2/24/2004
Summarized by: Jill Angle - 2/3/2005
Appearances for Plaintiff: J. David Butler of Richardson, Patrick, Westbrook & Brickman, LLC
Appearances for Defendants, The Scotts Co: Robert Raleigh f Armstrong Teasdale, LLP
For D, Freightline, Sprinkmann Sons of IL: Robert Raleigh of Armstrong Teasdale, LLP
For D, Bondex International Inc, The Flintkote Co, Georgia-Pacific Corp: George Kiser of Burroughs, Hepler, Brrom
For D, Carborundum Co, Georgia-Pacific Corp: George Kiser of Burroughs
For D, Bondex Inter'1, Carborundum Co, Flintkote, GP Corp, Repubic Powdered Metals: Geroge Kiser of Burroughs
For D, Riley Stoker, AW Chesterton, Advance Auto Parts, Discount AutoParts, Parts America, Western Auto, Daimler Chrysler: Angie Donovan of Cates, Kurowski, Bailey and Shultz
For D, Ford Motor Co: Robert Krause of Dickinson Wright
For D, Kaiser Gypsum Co: John Bitzer and Tamara Chandler of Dunham, Boman, & Leskera
For D, BMI Refractories, Kentile Floors, Sidener Supply: Paul Lore, Gunty & McCarthy
For D, Certainteed Corp, Union Carbide Cor; TH Agriculture and Nutrition, LLC, Maremont Corp. Dana Corp, Harcros, St. Gobain, Amchem: Ed Johnston of Heyl, Royster
For D, Fiat Allis: Jeff Chrones
For D, John Crane, Sepco: Sean Fergus of O'Connell and Assoc.
For D Honeywell and Allied Chemical: Dennis Dobbels of Polsinelli, Shalton & Welte
For D, Quigley: Nicole Wright of Secrest, Wardle, Lynch, Hampton, Truex and Morley
For D, General Motors: Gary Wiseman, of Law Offices of Thomas Noonan
For D, Goodyear: Mary Rychnovsky of Williams, Venker and Sanders
Court Reporter: Dawn Brown
Examination Index:
Page 13
He retired from Ford in 2002. Has own consulting firm, Chess consulting, consults for Ford.
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Policy at Ford, that if they had docs regarding asbestos you had to give them to the office of general counsel, policy in effect in early 1990s.
ford bought raw asbestos fibers starting in late 1960.
Ford bought asbestos fibers for heating and air conditioning housing for ford vehicles. Phase out process started in late 1970's. Last year used asbestos fibers would have been shortly after phasing out began.
Industrial Flygiene dept is where he worked. Has seen tests done from this dept.
started with ford in 1973. Head of the dept was Paul Toth who retired in late 1980s. Successor was roger wabeke who is no longer with ford.
Ford had inside OSHA dept to make sure they were in compliance with osha. Ford had Med director under him industrial hygiene, safety dept, and medical dept.
Added epidemiologist and ergonomists. Toth was head of industrial hygiene. Bud Deary was head of safety. He retired in late 1970s replaced by Dale Gray.
Gray was head of safety until late 1990s. Med dept headed by drs and nurses and corp individuals to give guidance.
safety dept function to keep workers safe. Industrial hygiene was corporate function and would evaluate potential physical or chemical hazards.
safety engineers, education came from formal education and training courses.
Head of med was Duane block. He left in 1987. Replaced by John Tribwasser.
Witness believes there has been worker comp claims filed from asbestos exposure.
Ford belonged to Society of toxicology, american board of toxicology, board of industrial hygiene, american hygiene assoc., society of safety engineers.
Industrial health foundation, society of automotive engineers.
American medical ass., society of epidemiologists. Ford hired own epidemiologist. First one was Dave Sugano hired in mid 1970s. Worked under occupational health and safety dept in Ford.
one epidemiologists was Gordon Reeve.
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ford had medical program where yearly evaluations were made. Routine testing done.
Besides heating and air conditioning in the vehicles, there was no asbestos manufacturing within ford during the time the witness worked there.
a non dimensional chemical takes the form of its container.
Witness graduated from U of Michigan in 1964, degree in experimental biology.
Worked for Bureau of industrial hygiene in detroit, Graduate school at Wayne State for occupational environmental health graduated in 1966. Doctorate degree in pharmacology and physiology in 1968 from Wayne. Worked in DC, then worked for EPA, then in 1973 to Ford.. Learned of asbestos hazards in grad school in 1974.
retired from ford in 2002. Consults for them now. $350 an hour.
earned 50,000 in consulting for ford.
Has reviewed Selikoff reports on asbestos and friction products.
This case is related to repair on vehicles.
Has reviewed deps in prep for trial from Amie Anderson in scientific research dept.
Anderson did study, resulting in that chrysotile in brake pads, majority of it is destroyed in braking process. In 1973, asbestos potential for meso.
He believes there are insignificant asbestos amounts off of brakes.
Reviewed Jocko report from Bendix Corp. Another study by Williamson from GM.
Brake wear dust does contain unaltered chrysotile fiber above 5 microns in length of regulatory size.
He thinks there are no hazards regarding asbestos, regardless of type. Claims Selikoff studies confirm this.
Believes there are safe levels of exposure.
His opinion supported by Pedo and Doyle studies. Henry Lick was a manager of industrial hygiene did test in Arizona Proving grounds.
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He believes dust in certain amounts can constitute health hazard. Does not believe asbestos shorter than 5 microns can be health hazard.
He agrees brake wear dust does contain some amount of chrysotile asbestos greater than 5 microns.
He is familiar with studies by Hickish and Knight done in 1968. Industrial hygiene dept conducted air samplings some times.
since he's left ford he has kept current on heath literature regarding asbestos.
In late 1980's Ford produced vehicle with asbestos free brakes.
Arthur Rohl and Mt. Sinai did study, exhibit 1.
He is familiar with Sinai study.
Does not agree with Rohl's study that states free asbestos fibers were in brake wear dust. Methodology was not accepted then. They used xray defraction .
X-ray defractions are questionable. OSHA only counts those greater than 5 microns in length.
He does not believe brake and clutch servicing was hazardous.
Precautionary to use the vacuuming method. Technical services bulletins was available to the public.
Ford did label brake materials in mid 1980's.
He recalls no warnings given with regard to asbestos.
In 1973, Ford knew that breathing asbestos dust could cause asbestosis and cancer.