Document v62B6M6pG5VmGoE6ZpaGZQdDY

266 1 Sayers 2 Q. '64. 3 Let me see if 1 can ask some real 4 general questions, and then maybe I can shorten 5 this up a little bit. 6 When you went to work for Union Carbide 7 in 1964, did you have an understanding that 8 asbestos was hazardous? 9 A. Before joining Union Carbide I probably 10 had no idea. 11 Q. At what point did you become aware that 12 asbestos was hazardous? 13 A. 1 became aware that there were 14 allegations of it being hazardous during 1965 when 15 1 started as a sales representative. 16 Q. What was the information that you had 17 then that led you to believe that? 18 A. Customer comments and then obviously 19 when researchers found the factory inspector 20 regulations and their work from there.' 21 Q. Did you ever have the opportunity to 22 review the regulations that existed in the U.K. in 23 about 1965 concerning asbestos? 24 A. Yes, 1 actually read them. 25 Q. Did you conclude, after reading the 268 1 Sayers 2 your report. I'm just wondering if you asked 3 Dr. Demehl's department, that is, the medical 4 department in New York, in the United States, prior 5 to 1967 as to what information they possessed 6 concerning the hazards of asbestos. 7 A. No, and in those days line management 8 adherence was not very important I would not have 9 written directly to Dr. Demehl in any case. 10 Q. Were you at liberty to request your It supervisor to do so? 12 A. Yes. 13 Q. Would you have been interested in 14 knowing what Dr. Carl Demehl's views were on 15 asbestos prior to you issuing your report in '67? 16 A. Yes. But I regarded this as the 17 mechanism to unleash that information. 18 Q. Well, how did you know that the New York 19 medical department of Union Carbide in 1967 didn't 20 know everything that is in your report? 21 A. 1 didn't. 22 Q. Would you agree with me that you could 23 have saved yourself some substantial time in 24 research and writing by simply requesting that 25 information from New York had the New York medical 267 1 Sayers 2 regulations, that asbestos was harmful? 3 A. Being a non-medical man, 1 wasn't 4 capable of making (hat judgment. 5 Q. Did you conclude at any time, between 6 that time in about 1965 and the time of your report 7 in 1967, that asbestos was harmful? 8 A. Again, being a non-medical man, all 1 9 could do was read the text and relay it. 10 Q. Let me ask you this: Have you ever been 11 provided with a copy of the deposition of Dr. Carl 12 Demehl? 13 A. No, sir, 1 have not. 14 Q. As you sit here today, do you have any 15 information as to what Dr. Carl Demehl's testimony 16 was concerning his personal knowledge regarding the 17 hazards associated with asbestos before 1967? 18 A. 1 have no idea at all. 19 Q. Did you ever write to Dr. Carl Demehl 20 preparatory to your report and ask him: 21 Dr. Demehl, what does Union Carbide's medical 22 department know about asbestos? 23 A. No, I did not, because that was the 24 purpose of the report that 1 wrote. 25 Q. 1 understand that was the purpose of 269 1 Sayers 2 department had it? J A. It's possible, but I liked at that time 4 to do my own research in understanding the subject. 5 Q. And did you feel that after your report 6 issued in May of 1967 that you were -- that you had 7 obtained the knowledge? 8 A. Some of the knowledge. 9 Q. And 1 understand that you're not a 10 medical man, but you're a bright man. And the II question is based on your own research did you come 12 to a conclusion after issuing that report that 13 there was a potential for asbestos to be hazardous 14 to human health. 15 A. I understood the various documents that 16 had been written, which were then collected into 17 what 1 sent. So yes, 1 understood the documents. 18 Q. Yes. And you understood the documents 19 that you had reviewed had concluded, without any 20 reasonable doubt whatsoever, that asbestos was 21 harmful to human health: true? 22 MR. WILL: Object to the form of the 23 question. He specified the conditions. 24 A. 1 don't think it was fully 25 established. SPHERION DEPOSITION SERVICES r>nt aon-tam 68 (Pages 266 to 269)