Document vB71Er3z1w94GOVR2epZwdGG8

Page 1 Page 3 1 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS 2 STATE OF MISSOURI 3 4 GLENN BROWN, et al, 5 Plaintiffs, 1 IT IS HEREBY STIPULATED AND AGREED by and 2 between Counsel for the Plaintiff and Counsel for the 3 Defendant, that this continued deposition may be taken in 4 shorthand by TOD MINNIGERODE, a Certified Shorthand 6 vs. Cause No. 862-00694 5 Reporter and Notary Public, and afterwards transcribed 7 MONSANTO COMPANY, 8 Defendant. 9 10 11 6 into typewriting, and signed by the witness. 7 8 9 o-O-o 12 Volume IV 10 13 Deposition of R. EMMET KELLY, M.D. 14 On behalf of Defendant 15 June 13, 1990 16 17 11 R. EMMET KELLY, M.D., 12 of lawful age, being produced, sworn and examined on the 13 part of the Plaintiffs, deposes and says: 14 EXAMINATION 18 QUESTION FOR CERTIFICATION 15 QUESTIONS BY MR. MC CREA: 19 Pg. 46, Ln.1 20 Q 1 would ask you to bring it with you Friday 21 so that you may fully amplify all the -- 22 23 16 Q Good morning Dr. Kelly. 17 A Good morning, sir. 18 Q Dr. Kelly, could you describe for me 19 conditions which you would consider unsafe in a industrial 24 WALLER REPORTING, INC. 20 setting with respect to the use of PCB's and worker 25 515 Olive Street, Suite 1506 26 St. Louis, Missouri 63101 27 (314)621-2571 28 29 21 exposure? 22 A 1 think wherever a worker's exposed to 23 repeated or continuous skin contact or breathing the fumes 24 at elevated temperature or possibly in confined spaces for 30 25 prolonged periods of time that would be unsafe. Page 2 Page 4 1 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS 2 STATE OF MISSOURI 3 4 GLENN BROWN, et al, 1 Q Doctor, could you give us your definition of 2 a significant exposure to PCB's? 3 A No, sir. It varies all over the place. 1 5 Plaintiffs, 4 couldn't quantify that. 6 vs. Cause No. 862-00694 7 MONSANTO COMPANY, 8 Defendant. 9 10 5 Q After Paul Wright was indicted do you know if 6 there was any review of the long term PCB studies which 7 Monsanto contracted with I.B.T. to perform, was there any 8 review by Monsanto? 11 DEPOSITION OF R. EMMET KELLY, M.D., produced, 12 sworn and examined on behalf of the Defendant, June 13, 13 1990, between the hours of eight o'clock in the forenoon 14 and five o'clock in the afternoon of that day, at the 15 offices of Communitronics, 1907 S. Kingshighway, St. 9 A Yes. Dr. Levinskas reviewed it. 10 Q Did he review it as a result of the 11 indictment, i.e., to look for particular shortcomings? 12 A 1 don't know. 1 was gone from the company at 16 Louis, Missouri, before TOD MINNIGERODE, a Certified 17 Shorthand Reporter and a Notary Public within and for the 18 State of Missouri. 19 20 13 that time. 14 Q You don't have any independent knowledge of a 15 review by Monsanto of the data as a result of the 16 indictments? 21 APPEARANCES 17 A Well, 1 don't know what you mean by 22 The Plaintiff was represented by Mr. Thomas M. 18 independent knowledge. 1 have talked to Dr. Levinskas and 23 Carney of the law firm of Husch, Eppenberger, Donahue, 24 Cornfeld & Jenkins, 100 N. Broadway, St. Louis, MO 63101. 19 he said 1 checked it all over, 1 checked figures and it 25 20 looks fine to me. He said, I'm sure the government has 26 The Defendant was represented by Mr. David 21 reviewed it; they are as interested as we are. They have 27 McCrea, of the lawfirm McCrea & McCrea, 119 South 28 Walnut Street, Bloomington, Indiana 47402. 29 30 22 copies of the results, we have never heard anything pro or 23 con from the government. 24 Q Do you know which agency of the government 31 25 was involved in reviewing it? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 1 - 4 LEXOLDMONOQ6889 Page 5 Page 7 1 A It would be the FDA. Remember the PCB work 1 the Bloomington workers, 1 said the Bloomington population 2 was not to the best of my knowledge a subject of this 2 who were exposed to the sludge of the Bloomington outflow 3 trial. 3 of the city. 4 Q 1 agree and that's stipulated. 4 Q All right, sir. Do you know of any other 5 A Yes. 5 epidemiological studies other than that one particular 6 Q Did Monsanto ever construct any chemical 6 study in Bloomington either of the citizens or the workers 7 analyses to determine if dioxins were a contaminant of 7 at the Westinghouse capacitor plant? 8 PCB's? 8 A Well, 1 don't know if this was the 9 A I'm sure not only Monsanto did but the EPA 9 Westinghouse people or not. 1 do not know if Brown and 10 did and at no time were dioxins found. In fact 10 Jones' work in 1981 was related to the Bloomington study 11 scientifically they could not occur from PCB. 11 or not, Bloomington workers or not. 12 Q Did Monsanto conduct any studies to determine 12 Q Do you have a list of epidemiological studies 13 if dioxins were a byproduct of the heating of PCB's? 13 on cards that you are referring to? 14 A 1 can't be sure, but it certainly has been 14 A Yes, 1 do. 15 conducted by other people and the same answer is the 15 Q Can you identify for us those studies and 16 government has stated -- the government meaning the EPA 16 tell us what information was produced by each of those 17 has tested PCB's as far as the presence or occurrence of 17 studies? 18 dioxins under any kind of conditions and they do not occur 18 A Yes. You realize this is pretty vast -- a 19 for PCB. 19 small abstract of the studies but I'll give it to you. 20 Q Do you know if there have been any studies in 20 Baker Bureau of Epidemiology of the Center for Disease 21 which trichlorobenzene and PCB as a transformer fluid have 21 Control of NIOSH, Metabolic Exposure to PCB's in Sewage 22 been tested to determine if heat produces dioxins? 22 Sludge, American Journal of Epidemiology, 1980. 148 23 A 1 don't know if they have been tested 23 people, PCB levels 17 to 37 parts per billion, all 24 together. Trichlorobenzene will produce dioxins under 24 negative findings. 25 certain conditions. 25 SAFE, S-a-f-e, IEEE, technical bulletin No. 86 Page 6 Page 8 1 Q Would it be your opinion that there would be 1 health effects of PCB, and this is a direct quote, 2 certain conditions in which dioxins could be produced as a 2 "relatively few adverse health effects." Gostasfawn, 3 result of heating the combined fluid of PCB and 3 G-o-s-t-a-s-f-a-w-n, 1986, American Journal of Industrial 4 trichlorobenzene? 4 Medicine; no increase in cancer. 5 A Yes. 5 Brown and Jones, 1981, United States Public Health 6 Q Do you know of any studies in which mineral 6 Service, Archives of Environmental Health. He found an 7 oil contaminated with PCB's has been heated to test for 7 increase in liver cancer but the increase was inversely 8 the byproduct of dioxin? 8 related to exposure. In other words, he found fewer 9 A 1 don't recall any. 9 cancers in people who worked longer than people who workec 10 Q Do you know if the heating of mineral oil 10 shorter intervals. 11 contaminated with PCB's can produce dioxin? 11 Smith, Communicable Disease, Center for Disease 12 A 1 don't know that. 1 would doubt it. 12 Control, 1982, British Journal of Industrial Medicine. 1 13 Q Yesterday you mentionedthat you called Paul 13 quote again, page 387 -- he worked with capacitor 14 Wright preliminary to the trial in Texas and chatted with 14 manufacturing -- quote: "None of the published 15 him about the trial. Who asked you to call Paul Wright? 15 occupational or epidemiological studies," paren, 16 A One of the counsels in Texas. 1 forget his 16 "including ours," close paren, "have shown that 17 name. 17 occupational exposure to PCB's is associated with any 18 Q What reason did he give you? 18 adverse health outcome except some clinical biochemical 19 A Well, he said he'd like Paul to testify but 19 alterations." 20 he doesn't want to testify. You know Paul, you want to 20 That means some will have, some may have some liver 21 call him and see if he's changed his mind. 21 enzyme changes. Kimbrough, Health and -- she's, 1 think 22 Q Dr. Kelly, yesterday you made reference to 22 we discussed her qualifications yesterday. Health and 23 epidemiological studies of the Bloomington workers; can 23 Environmental Digest, August, 1988, two quotes. "Several 24 you tell us us -- 24 occupational studies have presented no conclusive 25 A 1 said the Bloomington people. 1 didn't say 25 scientific evidence that PCB's have caused cancer in Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 5 - 8 LEXOLDMON006890 Page 9 Page 11 1 humans." 1 Q And by publishing you would mean that it was 2 Another quote: "Thus despite positive laboratory 2 approved by the individuals who publish periodical and 3 animal data and except for chloracne exposure to PCB's -- 3 distributed in the public domain? 4 except for chloracne, comma, exposure to PCB's has led to 4 A Well, you mean the editor of the magazine, 5 no convincing demonstrable health effects in humans." 5 sure. 6 That's it. 6 Q Right, so this information would be in the 7 Q Thank you. 7 public domain -- 8 (Whereupon, Plaintiffs Deposition Exhibit No. 5 8 A Yes. 9 was marked for identification.) 9 Q -- as a result of being published? 10 Q Dr. Kelly, have there been any 10 A Yes. 11 epidemiological studies of Monsanto's workers? 11 Q But you do not know in which publication it 12 A There have been two. One by Zack and Musch, 12 was printed? 13 which was a mortality study and sometime after 1954, which 13 A Well, it's easy to find out. 14 was published, and the other by Gaffey of all Monsanto 14 Q Did you know Judith Zack when you were 15 workers at the Krummrich or East St. Louis plant. That 15 employed at Monsanto? 16 included the PCB workers but they were a small fraction of 16 A No, she was not employed when 1 was there and 17 the total. Not a small, maybe ten percent of the total. 17 1 never met her. 1 never talked to her. 18 Q I'm going to hand you what is marked as 18 Q Did you know David Musch? 19 Plaintiff's Exhibit No. 5 and ask you if you can identify 19 A No. 20 the exhibit? 20 Q On the second page it was Monsanto Company 21 A Yes, sir. 21 Department of Medicine and Environmental Health. Do you 22 Q Is that the mortality study which you 22 see that? 23 referenced? 23 A Yes. 24 A Yes, that is true. 24 Q Did Monsanto have a department of 25 Q Was this study conducted on workers at the 25 Environmental Health when you were there? Page 10 Page 12 1 Sauget plant who were exposed to PCB's? 1 A 1 think we changed our name from Medical 2 A This study was devoted to death certificates. 2 Department to Department of Medicine and Environmental 3 Q Of workers who had worked with PCB's? 3 Health sometime, one or two years before 1 left. 4 A That's correct. 4 Q And the address 1751 Legend Lane, St. Louis, 5 MR. CARNEY: It might be simpler, 1 think we 5 Missouri, is the address of the Monsanto Department of 6 referenced to that as the East St. Louis plant and since 6 Medicine and Environmental Health? 7 people in St. Louis know where that is more than Sauget it 7 A No, 1 don't know whose it is. My guess is 8 might be helpful. 8 it's Judith Zack. 9 THE WITNESS: Or Krummrich. 9 Q Yes, you're right. It's footnoted above, 10 MR. CARNEY: Yeah, Krummrich doesn't mean much 10 that would be her address. 11 either. 11 Q Can you turn to Page 5 of the study? 12 MR. McCREA: All right. We'll refer to it 12 A Yes, sir. 13 as the East St. Louis manufacturing plant of Monsanto. 13 Q Can you go down to the fourth line from the 14 Q (By Mr. McCrea) Dr. Kelly, when was this 14 bottom on that page which reads, "While no industrial 15 report first made available to you? 15 hygiene monitoring data were available to quantify the PCB 16 A It appeared in a medical journal sometime in 16 exposure levels during the study time, interviews with 17 '95 or '96 1 think. She certainly didn't do it when 1 was 17 plant personnel established the fact that PCB exposure 18 there and 1 left at the end of ninety -- '74, so 1 can't 18 levels did not vary considerably within the PCB 19 tell you when 1 think it was published, but 1 don't know 19 department." Is that an accurate statement as far as you 20 where, whether 1 saw it before it was published or not, 1 20 know? 21 can't remember, but -- 21 A Yes. 1 am really a little confused by what 22 Q Do you know where it was published? 22 she means by the study time. Does that mean the study 23 A It's easily found. 1 think it was in the 23 time means when this -- this is a mortality study, if you 24 Journal of Industrial Occupational Medicine or something 24 remember. She goes back to the death certificates of 25 like that. 1 don't know. 25 people who worked there from a period of 1945 to 1965, if Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 9-12 LEXOLDMONOQ6891 Page 13 Page 15 1 that's what she means, the study time. 1 Q (By Mr. McCrea) This is a study to determine 2 Q '35 - 2 the number of deaths and the cause of deaths of workers 3 A '45 to '65. 3 exposed to PCB's, is that correct? 4 Q Is that statement accurate that Monsanto had 4 A Yes. 5 no monitoring data? 5 Q And can you determine from this report, Dr. 6 A No, that doesn't mean that at all. It says 6 Kelly, the time period that those workers were exposed to 7 it wasn't available to her. 1 don't know where those 7 PCB's? 8 records were, from 1965. She did this study ten years 8 A No, because she studied workers who were 9 later? 9 exposed for twenty years, from '45 to '65. 10 MR. CARNEY: I'm going to object also that the 10 Q Right. 11 question calling for speculation as to what the time 11 A That doesn't mean that all the people stopped 12 period was. 1 don't think she indicates what it was and 12 working in 1965. 13 it might call for Dr. Kelly to speculate as to what she 13 Q Correct. 14 meant by that. 14 A Some may have worked up to 1972 and died, but 15 Q (By Mr. McCrea) 1 think in the beginning of 15 she had a cut-off period of anybody who worked for six 16 that paragraph, Dr. Kelly, the authors state under 16 months during that period of '45 to '65 -- 17 materials and methods, during the period from 1936 to 1977 17 Q Correct? 18 PCB's were manufactured at Monsanto Company, Sauget, 18 A - were included. 19 Illinois plant, which we understand is the same as East 19 Q Correct. 20 St. Louis? 20 A That was where the eighty-nine workers she 21 A Yes, sir. 21 studied. 22 Q Then the sentence to which we're referring 22 Q Correct. 23 states, "While no industrial hygiene monitoring data were 23 A So my - now what she's saying if that's the 24 available to quantify the PCB exposure levels during the 24 study period then this PCB exposure levels during this 25 study time, interviews with plant personnel established 25 study time refers to 1945 to 1965. Page 14 Page 16 1 the fact that PCB exposure levels did not vary 1 Q Right, and she states there was no industrial 2 considerably within the PCB department." What -- to what 2 hygiene monitoring data available to quantify the PCB 3 is she -- to what are the authors referring when they 3 exposure levels. Is that consistent with your 4 state monitoring data? 4 recollection of what was done at the East St. Louis plant 5 A Well, that's - 5 that there was no monitoring date? 6 MR. CARNEY: Again, let me just object that 6 A No, that isn't what she says at all. She 7 it may call for the witness to speculate inside the mind 7 says it wasn't available to her. We did have some 8 of somebody else. It may be that Dr. Kelly will know but 8 monitoring there, we did not have regular monitoring in 9 1 caution him not to speculate. 9 1945. I'm not sure how good our PCB analysis of air was. 10 A If you look, Mr. McCrea, on page two in the 10 But we did have, not routine analysis but we had 11 abstract she says a total of eighty-nine workers exposed 11 monitoring analysis at the PCB department. Whether those 12 to PCB's for a minimum of six months during a period of 12 records were available to Zack in 1977, 1 don't --they 13 1945to 1965. Now, 1 don't know if that's the study time 13 obviously weren't. Whether she asked for them and they 14 '45 to '65 or '36 to '77 or '45 to '77. 14 weren't there or whether 1 don't know, but that does not 15 Q (By Mr. McCrea) Wouldn't that indicate that 15 by any matter of means state that we didn't monitor at 16 she was looking at workers who were employed at the East 16 that time. 17 St. Louis plant from 1945 to 1965 and she looked for 17 Q When did you begin to monitor for PCB levels? 18 death -- she looked for death certificates through 1977? 18 A Well, we didn't monitor it on a routine basis 19 MR. CARNEY: Well, I'm going to object again. 19 until sometime after 1 left. During my time we did not-- 20 It also could mean the time that she did her study, which 20 we did random analysis at times and 1 don't recall the 21 would be different than any of those dates. So 1 think 21 date. 22 we're in the realm of trying to speculate inside the mind 22 Q Describe how you would perform a random 23 of Judith Zack, and it might be more appropriate to ask 23 analysis at the East St. Louis plant before your departure 24 herwhat she meant unless she says what she meant in the 24 from Monsanto in 1974? 25 report, then you wouldn't have to speculate. 25 A You would go in with an industrial hygiene Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 13-16 LEXOLDMONOQ6892 Page 17 Page 19 1 gadget called an impinger that had a solution that would 1 A No, but 1 have talked to people about it, but 2 dissolve a PCB and you would pump air in at a certain rate 2 1 don't recall seeing it. 3 until you get a certain level of air whether that was a 3 Q In the East St. Louis plant where PCB's were 4 certain quantity of air, whether it was six cubic meters 4 manufactured what chemicals did they monitor on a routine 5 or ten cubic meters, then you would analyze it and see 5 basis of'74? 6 what you had with it, what you had there. 6 A 1 don't know. 7 Q With what frequency was that done before 7 Q Do you know if they checked for chemicals 8 1974? 8 other than PCB's in the PCB manufacturing section? 9 A Pretty irregular. 1 don't know the 9 A Well, first of all I'm not -- 1 can't place 10 frequency. 10 in my own mind exactly where the PCB department was as to 11 Q Was that data recorded? 11 other departments, but sometime after 1975 the OSHA and 12 A Well, sure, it was recorded someplace. 12 put out standards of workplace levels and so whenever 13 Q Was it reported to the plant manager? 13 there was a standard it is my impression that the company 14 A Whether it was reported to the plant manager 14 took monitoring levels on that, but again 1 cannot answer 15 or the doctor or the safety department 1 don't know. 15 your question as to how many other chemicals they 16 Q Do you recall any of that data, any of the 16 monitored for, they did not monitor. I'm sure they did 17 numbers? 17 not monitor the PCB for any particular hazard it presented 18 A No, but remember at that particular time we 18 but there was a standard for it and they wanted to follow 19 had a level that was decided on, if it were 1254 it was 19 the standard. 20 under one cubic -- one milligram per cubic meter, .5 20 Q Who conducted the random testing before 1974? 21 rather, and if it were 1242 it could be under the 21 A Either Wheeler 1 believe would be the one. 22 allowable concentration at that time. 22 Q Is he still with Monsanto? 23 Q Which was what for 1242? 23 A No, he retired ten years ago. 24 A One milligram per cubic meter. 24 Q Did you ever discuss those results with him? 25 Q Was this data recorded and filed in the 25 A He probably told me about them. 1 mean, 1 Page 18 Page 20 1 medical department? 1 don't know what you mean by discussing. 2 A Yes. We did have it, yes. 2 Q Did you ever discuss the results as to 3 Q Was it ever expunged from the records? 3 whether they were at a level that exceeded what you 4 A Well, 1 don't think expunged, that has a 4 thought was appropriate or safe? 5 connotation that 1 believe, removed. 5 A Well, again, when you say appropriate or safe 6 Q Well, was it ever discarded, or - 6 it depends, a standard is for an eight hour day for your 7 A We had at Monsanto what we called a record 7 life time so if you exceed a standard for one or two days 8 retention system. It really is a record destruction 8 or a week, that's still safe. You have to take the figure 9 system. Every five years you go through relevant data, 1 9 in relationship to what a standard is, and standard is a 10 mean files and discard material that isn't relevant. So 10 lifetime of forty hours a week and if it's twice that 11 back in the days of the seventies some things were 11 standard for a week it doesn't make a bit of difference. 12 discarded because we'd be up to our neck in paperwork. 12 Q Are there standards which apply to a single 13 So if it isn't available now I'm sure it was 13 day which are considered -- 14 discarded sometime either during my tenure or in the 14 MR. CARNEY: Talking about today or-- 15 fifteen years since I've been there. I've never seen it 15 Q (By Mr. McCrea) - safe or unsafe? 16 since I've been back. 1 mean back as a - on these cases, 16 MR. McCREA: No. 17 not back working for Monsanto. 17 Q (By Mr. McCrea)Before 1974 did you have in 18 Q 1 understand. After your departure in'72, 18 addition to the standard for exposure over a lifetime did 19 '74, monitoring became more routine? 19 you have maximum allowable contamination standards? 20 A Yes. 20 A Concentrations? 21 Q Can you explain the difference between the 21 Q Concentrations. 22 random monitoring and the routine monitoring? 22 A Well, that's the same as thethreshold limit 23 A Yes. The routine monitoring was at a 23 value. 1 mean, it's just a little different. Some 24 definite time, they did more of them. 24 standards had been proposed that allow a set, a limit on 25 Q Did you ever see any of those results? 25 fifteen minute exaggerated exposure, 1 do not know when Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 17-20 LEXOLDMONOQ6893 Page 21 Page 23 1 those came in. They were not very current before 1974. 1 people. 2 Q Doctor, the authors of this study of the 2 Q All right. What is your opinion of that 3 workers at the East St. Louis plant describe a number of 3 finding? 4 studies that were conducted throughout the world in the 4 A Well, maybe they did, maybe they didn't. 5 first several pages and 1 will draw your attention to page 5 Whatever it was was pretty minor. 6 eleven which is the reference page for the cited studies, 6 Q If 1 called you in 1958 from the Bloomington 7 and with regard to references one through twenty-five, 7 Westinghouse plant and asked you if workers could have 8 with which of those references are you familiar? Which 8 chloracne and not know and if chloracne could consist of a 9 have you read, of which do you have a working knowledge? 9 few blackheads what would your answer be? 10 A You mean without -- off-the-cuff without 10 A 1 would have to see the worker. 1 don't 11 looking at the reports? 11 believe 1 could make a telephone diagnosis. 12 Q Right. Are you able to discuss any of those 12 Q If 1 asked you in 1958 if a worker could have 13 studied based upon your having read them in the past, and 13 chloracne and not know it what would your -- just a 14 tell us about them? 14 second -- What would your answer be? 15 A Well, let's start off with number one; 1 know 15 MR. CARNEY: I'm going to object to it. 16 that one. That was chloracne from the use of PCB's as a 16 A That would be very unusual. That would be 17 heat transfer agent that leaked or not -- Yes, leaked and 17 very unusual, 1 would say. 18 these people had four or five cases of chloracne, some 18 Q (By Mr. McCrea) The next article, Doctor? 19 didn't even know they had chloracne till they saw the 19 A This next article is an epidemiological study 20 doctor. 20 of Yusho, poisoning caused by the ingestion that's taken 21 Q Where was that incident? 21 by mouth of rice oil contaminated with a commercial brand 22 A New England some place. The man was at Yale 22 of polychlorinated biphenyls, the Japanese Kanechlor and 23 that wrote it. So 1 think it was in -- 23 the PCB that was contaminated with benzofuran and 24 Q When you say some of them didn't even know 24 chlorinated quaterphenyls. 25 they had chloracne until they saw the doctor, can you 25 Q And the third article? Page 22 Page 24 1 explain that? 1 A That's also by the Japanese -- That's a 2 A Yes, they had a few blackheads and they 2 Chinese episode of Yucheng, 1 presume, Formosa. That's 3 didn't pay any attention to them and they went to the 3 China. 4 doctor because the doctor wanted to see everybody who was 4 MR. CARNEY: Taiwan. 5 exposed and the doctor had seen people with demonstrable 5 THE WITNESS: Taiwan. 6 chloracne and he looked at these people with a few 6 Q (By Mr. McCrea) Doctor, would you go to page 7 blackheads and said 1 think you got chloracne. 7 three where those articles are referenced, specifically 8 Q So did that establish that a few blackheads 8 paragraph three on page three? 9 was chloracne? 9 A Yes, sir. 10 A Not in my mind, but it did in his. 10 Q And let me read that into the record. The 11 Q So you disagree with that? 11 first two sentences, "Accidental ingestion of rice oil 12 A Well, no, 1 don't disagree with him, but 12 contaminated with PCB's has resulted in several outbreaks 13 here's a man that's got people working in the same 13 of common symptomatology, reported from Japan," 14 environment with people with frank chloracne but if a man 14 parentheses, quote, "Yusho," quote, "disease and Taiwan," 15 walks in the street with a few blackheads and had never 15 parenthesis, "Yucheng," quote, "disease," Parentheses. 16 even heard of PCB's that doesn't mean he's got chloracne. 16 The most common acute symptoms observed were 17 Q Did this article establish that there were 17 hyperpigmentation and acne-like lesions, discharge from 18 workers who didn't know they had chloracne until they went 18 the eyes, neuroendocrine disturbances, emesis and 19 to the doctor, the doctor looked at them, found a few 19 diarrhea. Doctor, did all of those individuals who had 20 blackheads and determined it was chloracne? 20 neuroendocrine disturbances have chloracne? 21 A In his mind he thought it was chloracne. 21 A In the first place, 1 don't know what she 22 Whether he determined it, 1 do not believe he took 22 means by neuroendocrine disturbances. 1 really don't know 23 biopsies of these people. 23 what she means by that, and 1 cannot say from those two 24 Q Do you dispute that finding? 24 pages you gave, two para -- sentences whether they did 25 A 1 can't dispute it because 1 haven't seen the 25 have chloracne but it is my impression that the vast Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 21 - 24 LEXOLDMONOQ6894 Page 25 Page 27 1 majority of the people had chloracne, the vast majority. 1 determination; whether 1 read this particular one 1 don't 2 Q That's your impression? 2 recall. 3 A Well, 1 could get the article and look it up, 3 Q No. 6; do you recall having read that? 4 but that's my opinion that he did, yes. 4 A 1 don't recall the individual ones, Mr. 5 Q Do you know any author who has made the 5 McCrea. There were about fifty or sixty articles on Yusho 6 statement that all individuals who suffered in Yusho and 6 and Yucheng in the years from 1972 to 19 -- up to now, and 7 Taiwan had chloracne? 7 so 1 can't -- 1 may very well have seen it. I'm not 8 A 1 can't answer that without a pretty 8 certain 1 read it. 9 extensive search through the literature but chloracne has 9 Q Could you go to page four? 10 been recognized by many authors and in many papers 10 A Yes, sir. 11 chloracne has been recognized as a hallmark of PCB - of 11 Q Can you read the last sentence in paragraph 1 12 PCB effects, it's the hallmark of it. 12 which states, "Chloracne, dermatitis, mild liver function 13 Q Doctor, what is the term emesis? 13 abnormality" -- 14 A Vomiting. 14 A Wait a minute. We're on page four? 15 Q Vomiting? 15 Q Page four, paragraph one? 16 A Vomiting. 16 A Lest sentence in paragraph one? 17 Q And the next sentence, "There was a 17 Q The first full paragraph? 18 dose-response relationship between the amount of oil 18 A Oh, the first one. 19 ingested and the proportion of persons reporting 19 Q Begins, "The Yusho incident" -- 20 symptoms," is that self-explanatory? 20 A Oh, the first sentence in paragraph two. 21 A 1 would think so. It just means that the 21 Q Fair enough. The last sentence in paragraph 22 more oil you ate the more people had symptoms. 22 two, "Chloracne, dermatitis, mild liver function 23 Q "After six years many of the patients still 23 abnormalities and increased triglycerides levels were 24 reported such symptoms as headache, stomach pain, numbness 24 reported with some consistency from these studies." What 25 of the extremities, arthralgia and respiratory symptoms." 25 is dermatitis? Page 26 Page 28 1 Did you read that? 1 MR. CARNEY: Let me object to your - again 2 A Yes. 2 you are now reading a summery from an article that is 1 3 MR. CARNEY: Let me object here. You're 3 assume available and then asking and 1 think in this 4 reading from a summery of some literature and then you're 4 particular case the doctor hasn't even indicated that he's 5 just reading pieces of this summery of the literature in 5 sure that he's read the article. You're not showing him 6 the record and 1 don't see any purpose to your just 6 the article, you're just reading him a one sentence 7 reading isolated sections of a summary of literature when 7 summery out of an article and 1 think without showing the 8 we ought to have the literature itself so the witness can 8 doctor what the article that the summery comes from so he 9 look at this literature that you are referring to in 9 can -- 10 context rather than pull out, not only pulling out a 10 THE WITNESS: This is the article, this 11 sentence from the literature but pulling out a sentence 11 particular one is the article in question. This is from 12 from the summary of the literature which 1 don't think is 12 Zack's article. 13 appropriate and 1 object to it. 13 MR. CARNEY: Oh, this is from Zack's, I'm 14 Q (By Mr. McCrea) Doctor, what is arthralgia? 14 not - 15 A Pain in the joint, joints. 15 MR. McCREA: The article is"A Retrospective 16 Q All right, Doctor, the next two articles back 16 Mortality Study of Polychlorinated Biphenyls Manufacturing 17 on page eleven, number -- 1 would believe we went through 17 Workers, by Zack and Musch, Monsanto Company Department of 18 3, No. 4, have you read that one? 18 Medicine and Environmental Health." This is your study. 19 A At some time in the past 1 have. 19 MR. CARNEY: It's not my study. 20 Q No. 5? 20 MR. McCREA: Well, Monsanto's study. 21 A That was a determination that of the 21 MR. CARNEY: All I'm saying is I'm trying to 22 chlorinated dibenzofurans in Kanaclor which is a Japanese 22 look over your shoulder because you don't have an extra 23 PCB's. 23 copy for me. 1 thought you were reading from the summary 24 Q Do you recall having read that article? 24 but if that's the original article then 1 withdraw the 25 A I've read articles that showed the 25 objection. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 25 - 28 LEXOLDMONOQ6895 Page 29 Page 31 1 MR. McCREA: All right. 1 in fat. 2 Q (By Mr. McCrea) Doctor, what is dermatitis? 2 So if you have exposure to PCB you will get - if 3 A Dermatitis is an inflammatory or a condition 3 you have triglycerides for any reason you will get a 4 of the skin. 4 higher level of PCB's in your blood because a PCB is fat 5 Q Is it your testimony that all individuals who 5 soluble in triglycerides. So you could get increased 6 would have dermatitis associated with PCB's would also 6 triglycerides from any number of causes without chloracne. 7 have chloracne? 7 Q What is the consequence to the human body of 8 A No. 1 never said that. 8 inused triglycerides? 9 Q Can you have dermatitis associated with PCB's 9 A Depends how much. None, but some it's like 10 and not have chloracne? 10 too much cholesterol. If you're obese it may have adverse 11 A Sure. PCB acts as a paint remover, you put 11 effects down the road. 12 it on, your skin will get red. 12 Q Doctor, I'd like to go back to page 3? 13 Q Can you have mild liver function 13 A Three? 14 abnormalities would chloracne? 14 Q Yeah, and the symptom of arthralgia, 15 A It depends on what you mean by mild liver 15 a-r-t-h-r-a-l-g-i-a. Did the Yusho and Taiwan poisoning 16 function abnormalities. If by that you mean a transient 16 result in reports of pain in joints? 17 or very minor alteration in one or two of the enzymes you 17 A 1 don't know. 1 mean, I'm not taking Zack's 18 may have it, but then you have to decide where these 18 word for this. I'd have to read the results and see how 19 enzyme changes came from. Here we're talking about people 19 many - you have a thousand people in Yusho itself and 1 20 who ate Japanese PCB oil, it was contaminated. If you are 20 don't know how many in Yucheng. Certainly some of them 21 talking about a mild liver abnormality without chloracne 21 may have pains in their joints, but the significance of 22 you have to check where did this person get this mild 22 it, I'd have to read the articles. 23 liver abnormality. Did he ever have hepatitis from eating 23 Q Can you explain the mechanism by which the 24 shellfish in his life. Did he take three drinks alcohol 24 ingestion of the PCB oil in Yusho and Taiwan could cause 25 in the last two days? You have to differentiate where he 25 arthralgia? Page 30 Page 32 1 got it from. 1 A No, sir, 1 couldn't. 2 Q Are these symptoms related to industrial 2 Q Have you ever conducted any investigation as 3 exposures? 3 to the mechanism by which those substances cause 4 A And 1 might also add, extend my last 4 arthralgia? 5 question, amplify my last answer, 1 mean. If a person has 5 MR. CARNEY: Well, let me object. 1 think 6 an acute episode of adverse effects from PCB's he can get 6 you're assuming facts that aren't in evidence and that's 7 mild liver abnormalities because he would -- these would 7 that there is a cause and effect relationship in your 8 occur long -- It takes some time for chloracne to show up. 8 question. 9 If a person were exposed to a leaking trans -- heat 9 Q (By Mr. McCrea) Have you ever done any 10 transfer unit, hot stuff came out and he breathed it for 10 investigation as to that particular complaint in Yusho in 11 eight hours, he could develop liver abnormalities. 11 Japan and the relationship to PCB's and how that was 12 He would not development chloracne within 12 discussed? 13 twenty-four or forty-eight hours, but he would develop 13 MR. CARNEY: Are you talking about now an 14 liver abnormalities. But 1 have to repeat chloracne is 1 14 investigation about the Japanese PCB's that were 15 think accepted by all the workers, the majority of the 15 contaminated with the furans? 16 workers in the field as the hallmark of PCB adverse 16 MR. McCREA: Right. 17 effects. 17 A 1 have never had any Japanese PCB's that were 18 Q Could a worker have increased triglycerides 18 contaminated with furans and only way you would test 19 as a result of exposure to PCB's and not have chloracne, 19 arthralgia, see the if the person has arthralgia is give 20 is your answer the same? 20 people it; because you can't tell whether a dog or rat has 21 A No. He could have it because he's too fat 21 pain in his joints. 22 and also 1 think it's been disproved since 1977 when she 22 Q (By Mr. McCrea) Did you ever ask a single 23 wrote this, '77 or '78 because she's carried this study up 23 worker in the East St. Louis plant if he had pain in his 24 until the deaths in 1977, followed through '77 so it's 24 joints? 25 after probably '78; triglyceride is a fat. PCB is soluble 25 A 1 might very well have, 1 don't recall it. 1 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 29 - 32 LEXOLDMONOQ6896 Page 33 Page 35 1 can't tell you positively; but let me tell you when you do 1 L. Heet, Monsanto, 800 North Lindbergh Boulevard, St. 2 an examination of workers in an industrial setting they 2 Louis, Missouri to David P. Brown, NIOSH, Robert A. Taft 3 are far from reticent about giving voice to a symptom. If 3 Laboratories, 4676 Columbia Parkway, Cincinnati, Ohio. 4 they have symptoms they tell you. 4 "Dear David: Enclosed is a photocopy ofthe report 5 Q Dr. Kelly, are you familiar with the study at 5 on mortality of PCB workers at the Monsanto plant in 6 the Bloomington, Indiana capacitor plant where thirty-nine 6 Sauget, Illinois by Judith Zack and David Musch. As far 7 percent of the workers exposed to PCB's complained of 7 as 1 know this is is final report, although the report was 8 joint pain? 8 never published in the scientific literature." 9 A What is the study? 9 A What date is that? 10 Q Are you familiar with the study? 10 Q February 27, 1985? 11 A Well, show it to me. 1 don't know it. 11 A Well, 1 would be very, very surprised if 1 am 12 MR. CARNEY: I'm going to object. There's 12 wrong in my statement, 1 was certainly - My impression is 13 thousands of studies or at least hundreds, let me put it 13 the report has been. 14 that way. 14 Q And 1 will represent to you that this report 15 Q (By Mr. McCrea) The study in which Dr. 15 has not been published in the scientific literature and 16 Raymond Suskind oversaw the morbidity epidemiological 16 that we did not get it from Monsanto, that we got it by 17 survey ofthe Bloomington workers using the Yusho symptoms; 17 freedom of information request to the Center of Disease 18 as a guideline in which Dr. Alexander Blair Smith found 18 Control in Atlanta, Georgia. 19 that thirty-nine percent of the active workers in if 19 MR. CARNEY: Well, I'm going to object, Mr. 20 Bloomington Westinghouse plant complained of joint pain. 20 McCrea, you're testifying and making speeches. You can 21 MR. CARNEY: Would you -- Do you have that 21 ask questions but you're not under oath. You're not a 22 study? I'm going to object to claiming that you have a 22 witness in this case, Mr. McCrea, and now you're trying to 23 study that Dr. Suskind -- Is it a Dr. Suskind study? 23 make these speeches. If you have a question you can ask a 24 MR. McCREA: Dr. Suskind oversaw the project 24 question but to make a speech where you're reading from 25 which was carried out by Dr. Alexander Blair Smith. 25 documents or claiming that you got documents from a Page 34 Page 36 1 MR. CARNEY: Wait a minute, 1 don't know - 1 certain place, 1 don't have the opportunity of 2 MR. McCREA: Just a second. 2 cross-examining you as to where you got the documents. 3 Q (By Mr. McCrea) Have you ever heard of that 3 I'm not saying you're misleading anybody, but 1 think it's 4 study? 4 inappropriate for you to make these speeches not under 5 A Wait, just a minute, has it been published? 5 oath about where you got certain documents. 6 Q No? 6 Q (By Mr. McCrea) Would you turn to the -- 7 A Well, how would 1 know about it? 7 A Well, can 1 finish my - 8 Q Well, this report wasn't published and 1 got 8 MR. CARNEY: Yes. 9 it. 9 A 1 said 1 would be extremely surprised if 1 am 10 A Yes, it was published. 10 wrong but I'm going to see you again on Friday and 1 will 11 Q Where? 11 check to see if 1 can find - it would be easy enough to 12 MR. CARNEY: Let me object. You - number 12 find tomorrow whether the Zack report was published. If 13 one apparently it was published according to Dr. Kelly and 13 it was published I'll give you the citation; if it wasn't 14 number two, you've asked for hundreds and thousands of 14 I'll admit that 1 was confused. 15 documents from Monsanto and we've produced documents; so 15 Q (By Mr. McCrea) All right. We know at least 16 you have had ofthe advantage through this lawsuit of 16 as the February 27, 1985, if you can find that? 17 getting these Monsanto documents. Here you're asking 17 A Well, no, we don't know that. We know that 18 about an unpublished study that you don't have and are not 18 fellow didn't find it. 19 willing to show the doctor if you do have. I'm going to 19 Q No, it says as far as 1 know. 20 object to it. 20 A As far as he knows, well - 21 Q (By Mr. McCrea) All right,number one, let 21 Q Just a second. "As far as 1 know this is the 22 me read you a letter dated February 27, 1985? 22 final report," comma, "although the report was never 23 A Wait, what did you say? Let me read you 23 published in the scientific literature." 24 what? 24 A May 1 see that. 25 Q A letter datedFebruary 27, 1985 fromTerry 25 Q It's right in your stack. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 33 - 36 LEXOLDMONOQ6897 Page 37 Page 39 1 A In what stack? 1 MR. McCREA: I'll be happy to show him the 2 Q In what 1 gave you. 2 report, and but I'm also stating that there are a number 3 A In the Zack report? 3 of unpublished reports. 4 Q Right, it's part of it. 4 MR. CARNEY: And he may have seen it or he 5 A What page? 5 may not have. 1 think if you're going to want to find out 6 Q Well, it comes right after -- It's right 6 if he's seen it -- 7 before the final report. 7 A 1 can simplify this by saying I've never seen 8 A Oh, 1 see. Oh, 1 see. Well, I'll be 8 it. 9 extremely surprised but I'll look it up. 9 Q (By Mr. McCrea) Or heard of it? 10 Q Now, Doctor, you asked me about unpublished 10 A Or heard of it. 11 reports. 1 would be the first to agree that it's very 11 MR. McCREA: Break. 12 difficult to get ahold of an unpublished report, but you 12 (Whereupon, a short break was taken.) 13 do not, do you have -- Have you ever tried to get 13 Q Dr. Kelly, would you please turn to page 14 unpublished reports? 14 eight of the Zack Musch study? 15 MR. CARNEY: In what area, what type of 15 A Yes, sir. 16 reports? 16 Q And the first full paragraph states, "This 17 MR. McCREA: On PCB health effects. 17 investigation dealt with the mortality experienced in the 18 MR. CARNEY: From who? 18 cohort of eighty-nine male workers involved for at least 19 MR. McCREA: From Centers for Disease 19 six months in the production of PCB's between January 31, 20 Control. 20 1945 and December 31, 1965. The only cause of mortality 21 MR. CARNEY: What particular time? 21 which showed a statistically significant excess in 22 A 1 don't think 1 have. 22 observed deaths was circulatory diseases exclusive of 23 Q (By Mr. McCrea) All right. But at any rate 23 arteriosclerotic heart disease." Can you interpret that 24 you are not familiar by any means available to you with 24 for us? 25 the data that thirty-nine percent of the active workers at 25 A Interpret the whole sentence? Page 38 Page 40 1 the Bloomington Westinghouse plant complained of joint 1 Q Yes, sir. 2 pain or arthralgia? 2 A She's stated she found more deaths in this 3 MR. CARNEY: I'm going to object to that 3 group of circulatory diseases exclusive of high blood 4 question. Here you're asking him about a report that you 4 pressure disease. Arteriosclerotic disease is known as 5 haven't identified as to date, as to the -- where it was 5 hardening of the arteries. 6 published, if it was published. 6 Q What does the phrase statistically 7 MR. McCREA: Didn't we already state it 7 significant mean? 8 wasn't published? 8 A Well, this will take a little explanation. 9 MR. CARNEY: You haven't said who put it out, 9 If you have time, I'll be happy to do it. 10 what organization. 10 Q Explain it to the jury if you could. 11 MR. McCREA: Alexander Blair Smith, NIOSH, 11 A Fine. Whenever one's study carries out an 12 Centers for Disease Control under the guidance and 12 epidemiological study there are four main rules that have 13 auspices of Raymond Suskind. 13 to be observed. One, the condition has to be - the study 14 MR. CARNEY: When was it published? 14 has to be reproducible, repeat -- you have to be able to 15 MR. McCREA: It was never brought out. 15 repeat it the same way. In other words, if you find high 16 MR. CARNEY: When was it prepared? 16 blood pressure in one case, diabetes in another case but 17 MR. McCREA: It was prepared about 1979, 17 no high blood pressure, tumors of the stomach in a third 18 1980. 18 but no high blood pressure, or no diabetes they aren't 19 MR. CARNEY: Do you have a copy of it you 19 reproducible. So the condition has to be reproducible. 20 could show? 20 Secondly, there must be a dose response. In other 21 MR. McCREA: Yes, 1 do. 21 words, if you're studying a worker group of people who 22 MR. CARNEY: Well, it would seem to me that 22 work ten years should have more of a condition than the 23 you are asking somebody if they have ever seen a report 23 people who work two years. If you find an excess of brain 24 and if you have a copy 1 think it would be very simple for 24 tumors in people who work two years and don't find it in 25 the jury to see if he knows by showing him the documents. 25 people who work ten years that is a big flaw in an Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 37 - 40 LEXOLDMONOQ6898 Page 41 Page 43 1 epidemiological study. 1 A Well, 1 think I'll have to turn that question 2 The third, there has to be a dose response -- or 2 around; I've never seen anybody in any scientific 3 no, the third would be there would be no confounders in 3 literature say that rheumatic fever or phlebitis was 4 it. Now confounders is a term that really means obscures 4 caused by PCB's. 5 the results. If you were studying deaths from heart 5 Q With respect to this study do you know if 6 disease and don't pay any attention to obesity, that's a 6 anyone has suggested that those deaths of the workers in 7 confounder that will throw out your study and a fourth is 7 the East St. Louis plant resulting from circulatory 8 it has to be a significant excess. 8 disease were not caused or contributed to by their 9 Now this is to answer your question; there are 9 exposure to PCB's? 10 statistical methods for showing whether there's a 10 A Well, I'm sure there are an awful lot - 1 11 statistical significant excess, statistically significant. 11 mean, 1 can't give you the names, but she supposes one 12 That means if you had a group of twenty people and three 12 would postulate that there may be a relationship, she's 13 people had the condition and you had the control group of 13 got an awful lot of factors if there. She doesn't say 14 twenty people and one person had the condition on the 14 that it's caused by PCB's. She goes on to say a great 15 surface it might look like you've got three times as much 15 deal of things about the lipids, about the triglycerides 16 illness here as you do here but that also could occur by 16 associated with the heart disease; but it's been proven 17 chance and there are statistical ways of evaluating these 17 that -- accepted by the scientific community that high 18 figures. 18 triglycerides are not caused by PCB. That's an 19 I'm not a statistician so 1 won't bore you with 19 association with high PCB's in the blood. 20 that but there are ways, and they generally have what they 20 So 1 don't take this as gospel at all. 1 mean, if 21 call a P factor which means the probability that this 21 she has an excess of-How many did she have? Eight 1 22 might be due to chance is a certain percent, five percent, 22 belief. Let me look. She had nine other diseases of the 23 twelve percent or something of that sort. Now to put a 23 circulatory system, expected four, 3.98. Two of these 24 figure on it 1 would have to say it has to be run by a 24 were rheumatic fever, one was phlebitis. That would bring 25 statistician to see if these eight cases or whatever he 25 it down to seven, and that's not statistically Page 42 Page 44 1 had, she had, was statistically significant. Well she 1 significant. 2 says they were, so I'll take her word for it. Does that 2 Q Where do you see the two with rheumatic 3 answer your question? 3 fever? 4 Q And how do you interpret that for the jury 4 A Well, 1 checked with her, 1 checked the raw 5 with respect to these workers dying of circulatory 5 data. 1 know it was two had rheumatic fever. 6 diseases who were exposed to PCB's, what's the 6 Q And that was one of the questions which the 7 significance of that for the jury? 7 Monsanto attorneys asked our plaintiffs, correct? 8 A Well, that's the question; because we were 8 MR. CARNEY: I'm going to object. 1 don't 9 having workers who died from these illnesses but two of 9 think Dr. Kelly was at the depositions of the plaintiffs 10 them had rheumatic fever and rheumatic fever by no stretch 10 and he already testified he never saw the depositions, so 11 of the imagination can be connected with PCB exposure. 11 1 don't know how -- 12 The other one was cerebrovascular disease, to the best of 12 A 1 don't know what you mean by that sentence, 13 my knowledge was an infected veins in the leg. She had 13 by that question, Mr. McCrea? 14 phlebitis like Nixon had, 1 mean the employee had 14 Q (By Mr. McCrea) Yesterday, when 1 read you a 15 phlebitis in the lower legs, like Nixon had. That is no 15 list of signs and symptoms which 1 took from the 16 relationship. 16 depositions in which the Monsanto attorneys questioned our 17 What she is saying is the statistically significant 17 plaintiffs, one of the health conditions was rheumatic 18 excess, but you have to look at the cases and see what 18 fever, which they asked our plaintiffs? 19 other causes there are for the excess. Just because 19 A 1 don't know if they asked them. 1 think 20 there's an excess of deaths doesn't mean it's caused by 20 there were a hundred and twenty questions or something 21 PCB's and occurred to PCB workers and that's what she 21 that allegedly were asked. 22 says. 22 MR. CARNEY: Yeah. Dr. Kelly doesn't know 23 Q Do you know if anyone in the scientific or 23 what questions were asked, and you are claiming that 24 medical community has ruled out any of the deaths caused 24 rheumatic fever was caused by PCB exposure. 25 by the circulatory disease as not being related to PCB? 25 MR. McCREA: Am 1 claiming? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 41 - 44 LEXOLDMONOQ6899 Page 45 Page 47 1 MR. CARNEY: Yes. 1 minutes ago. How can 1 ask something about which 1 have 2 MR. McCREA: 1 would not think that PCB 2 no knowledge? 3 exposure would be good for a person who had rheumatic 3 MR. CARNEY: You have the report you say for 4 fever and it could contribute to morbidity and/or 4 at least a year and you know that there's data, backup 5 mortality? 5 data for the report like there would be for any report. 6 MR. CARNEY: So PCB's could cause rheumatic 6 MR. McCREA: 1 don't know that there's any 7 fever? 7 data other than what's in here. 8 MR. McCREA: Did 1 say that? 8 MR. CARNEY: You think that was just a 9 MR. CARNEY: No. I'm asking you, is that 9 made-up report? 10 what you're saying? 10 MR. McCREA: 1 assume that when they have 11 MR. McCREA: No, I'm not saying that, I'm 11 these umpteen pages of data that that's it. 1 didn't know 12 asking the doctor. Number one, I'm not a doctor, you're 12 that they had broken these categories down and that that 13 not a doctor -- 13 information is on file at Monsanto. They might have lots 14 THE WITNESS: Is there a question on the 14 of other information there that we'd be interested in. 15 board right now? 15 Q (By Mr. McCrea) Doctor, all I'm asking you 16 MR. McCREA: No, we're moving very slowly. 16 to do is give them a call and ask them if they can make 17 THE WITNESS: That's all right. 17 that data available to you and bring that with you Friday? 18 Q (By Mr. McCrea) Doctor, you interpreted data 18 MR. CARNEY: Well, I'm going to instruct the 19 supporting this report. You actually went to the files of 19 doctor not to respond to these requests that you are 20 Monsanto and got data that doesn't appear on the exhibit? 20 making at the last minute. You have been asking questions 21 A That's correct. 21 of Dr. Kelly over a period of a week and a half and 1 22 Q Do you have that data with you? 22 think this is is third day you've indicated that you 23 A No, 1 don't. 23 aren't able to - 24 Q Could you bring it with you Friday? 24 MR. McCREA: Mr. Carney, what does that have 25 A 1 doubt it, but -- 25 to do with the request? Page 46 Page 48 1 Q 1 would ask you to bring its with you Friday 1 MR. CARNEY: Well, 1 think you are being a 2 so that you may fully amplify all the - 2 little bit unreasonable here after three days of asking 3 A Well - 3 Dr. Kelly questions, and 1 asked you to continue the 4 Q Just a minute - 4 deposition this afternoon and you're not going to do that. 5 MR. CARNEY: Just a minute. Let him finish 5 1 asked you to continue the deposition last week when we 6 the question and I'm going to make an objection. 6 had the - to get, to not impose on Dr. Kelly any further 7 Q (By Mr. McCrea) So that youmay show us the 7 and you're bringing him back now a third time so you can 8 data to which you're referring so that we may use that 8 go back and regroup and ask more questions, and now you're 9 data to develop further questions. If that courtesy would 9 asking for documents into the third day of your cross 10 be extended it would be appreciated. 10 examination. 1 think it's improper and I'd like to 11 MR. CARNEY: Well, you know, I'm going to 11 conclude this deposition. We're in the third day of your 12 instruct the doctor just not to answer that at this point 12 examination. 13 and indicate that you have not - you have had this case 13 THE WITNESS: This is a little -- 14 pending for a number of years and you have not asked for 14 MR. CARNEY: And 1 would think - I'd like to 15 this data and you've had the right to ask for this data 15 just say one other thing, that we're talking about death 16 and now to have Dr. Kelly who's retired from the company 16 certificates and those are public records that you have 17 and has been for fifteen years to go back in and try to 17 access to as well as Dr. Kelly. Probably better access to 18 find some data, when you haven't given the courtesy of 18 them. 19 asking for it in the last two or three years when you 19 MR. McCREA: Not if 1 don't- 20 could have 1 think is highly improper. 20 THE WITNESS: 1 know you instructed me not to 21 MR. McCREA: 1 asked the doctor a question, he 21 answer -- 22 gave me an answer. His answer was based on data he 22 MR. McCREA: Not if 1 don't know their 23 reviewed at Monsanto Company. I'm asking him to supply 23 names. 24 the data which he reviewed to support his answer. 1 24 THE WITNESS: You instructed me not to 25 didn't know he reviewed the data until he told me ten 25 answer, but this may simplify it, but at the break 1 went Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 45 - 48 LEXOLDMON006900 Page 49 Page 51 1 out to call the epidemiology department to find out 1 that the document which 1 gave you includes the draft and 2 whether the Zack study was published or not. All of them 2 then it includes the final report, the first half of the 3 are out of the office at a convention. So I'm afraid 1 3 document, Dr. Kelly, is the draft? 4 won't be able to do it. 4 A Uh-huh. 5 MR. McCREA: Well, 1 appreciate you're doing 5 Q The second half is the final report, are you 6 it. 6 with me on that? 7 THE WITNESS: Well, how can 1? They are all 7 A Yes, uh-huh. 8 gone. 8 Q Can you go to the final report; do you have 9 MR. McCREA: Oh, you can't; but 1 appreciate 9 that? 10 the fact that you made the call. 10 A Yes. 11 THE WITNESS: Yeah, okay. 11 Q There's a reference to page two, is there 12 MR. McCREA: I'd like to certify the request 12 not, to Monroe County, Indiana, second paragraph? 13 made to Dr. Kelly that he bring the data to which he made 13 A Yes. 14 reference in order that we may examine that data to 14 Q Can you interpret that for us? 15 cross-examine the doctor. 15 A Well, it says that Monroe County Board of 16 Q (By Mr. McCrea) Dr. Kelly, what other data 16 Health conducted biochemical tests among Bloomington 17 did you review other than the cause of death from 17 Indiana, residents exposed to PCB's. Serum levels of GGT, 18 rheumatic fever for the two individuals? 18 that's a liver enzyme, and plasma triglyceride levels were 19 A Well, that's all 1 say that 1 reviewed. This 19 found to show a direct relationship to serum PCB's. 20 was the one, 1 called Bill Gaffey, he was also an 20 Q Can you explain that to the jury in terms 21 epidemiologist who is no longer with the company, and 1 21 they can understand? 22 said what were these eight cases that we had and he told 22 A Well, they found that people who had higher 23 me one was a phlebitis, two were rheumatic fever and 1 23 PCB levels have higher enzyme levels and higher 24 don't know what the other one was, 1 think one was a 24 triglycerides. How much higher 1 can't explain, whether 25 stroke. 25 they were abnormal values 1 can't explain because it Page 50 Page 52 1 Q Do you have the names of these eighty-nine 1 doesn't say. 2 people who died? 2 Q This report, they calculated the number of 3 A No, sir, 1 don't. 3 deaths they would expect in an average group of workers, 4 Q Your counsel suggested that 1 could go down 4 is that a fair way to state it? 5 and get their death certificates. Do you know how anyone 5 A Wait a minute, back -- Now we're away from 6 could do that if you don't know their names? 6 Indiana, we're back on Zack? 7 A You'd have to ask Counsel. 7 Q We're back on the mortality study. 8 Q How do 1 do that, Tom? 8 MR. CARNEY: Which page? 9 MR. CARNEY: Well, why don't you ask Dr. 9 MR. MCCREA: The tables at the end of the 10 Kelly. 10 final report. 11 MR. McCREA: He said to ask you. 11 Q (By Mr. McCrea) Statistically, Dr. Kelly, 12 MR. CARNEY: Well, as 1 understand it I'm not 12 the authors of this study made a prediction as to how many 13 under oath. As 1 understand it the deposition is Dr. 13 deaths should occur in this group of eighty-nine workers, 14 Kelly, if you would focus on that maybe you could finish 14 is that a fair way to state it? 15 this deposition. 15 A No, it isn't. 16 A Well, 1 would say maybe you could call 16 Q Can you explain it? 17 over -- 17 A Well, yes. They used standard mortality 18 Q (By Mr. McCrea) Call over? 18 tables to say what, if they carried out this study in the 19 A Call Zack, wherever she is. 19 way usual epidemiological studies are carried out they 20 Q You don't know the names of those folks? 20 would have standard mortality which means that certain 21 A Oh, no, 1 don't. 21 people, people of a certain age, certain sex would be 22 Q This study, the results of the study are in 22 expected to die of this illness, whether these things 23 tables attached to the narrative, is that correct? 23 were -- they used as a control on males of the United 24 A That's correct. 24 States, males in Illinois, other males in the chemical 25 Q And there are two reports, do you understand 25 company, other males in St. Charles County - St. Clair Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 49 - 52 LEXOLDMON006901 Page 53 Page 55 1 County, 1 don't know what you used as a control. 1 Q You're familiar with this study? 2 Q You have no reason to doubt the accuracy of 2 A Well, 1 am familiar with it, but 1 haven't 3 their format? 3 gone into detail. 4 MR. CARNEY: Well, let me object, 1 don't 4 Q You have been asked about it in other 5 know what you mean by accuracy of their format. He just 5 depositions? 6 testified that they're a control group. You could use 6 A Yes, but not in those particular terms. 7 males of the United States, males of St. Clair County, 7 It says here general mortality studies were made in 8 males of other chemical workers at Monsanto, and he 8 comparison to the general United States population. 1 9 doesn't know what the control group is, so 1 don't 9 think that's a flaw. If you've got a bunch of industrial 10 understand your question, it's vague. 10 workers and you're in an industrial community where 11 Q (By Mr. McCrea) Do you have any reason to 11 there's smog and God knows what else you have got a 12 believe that the protocol used by Zack and Musch was not 12 different mortality rate than you do in the standard 13 done pursuant to acceptable scientific standards? 13 United States population. 14 A Well, 1 just don't know if it was, frankly, 14 Q What effect does smog and everything else 15 because 1 do not know what she used for the controls. In 15 have on the mortality rate? 16 the Gaffey study of all the employees when they used the 16 A Well, 1 think it's obvious that city dwellers 17 controls for the United States they showed an excessive 17 seem to have a higher incidence of lung diseases and a 18 lung cancer. When they idea a control the people in the 18 higher incidence of mortality than people in less 19 neighboring county, St. Clair County there was no 19 contaminated areas. 20 excessive lung cancer. So 1 think it depends on an 20 Q All right. Any other flaws? 21 epidemiological study who your control group is. 21 A Well - 22 Q Doctor, do you feel qualified to comment on 22 MR. CARNEY: I'm going to object again to the 23 this mortality study? 23 question because 1 think you're, you know, unless you give 24 A Yes, 1 do. 24 the doctor a chance to read the report, you know, may or 25 Q And do you find any flaws in the study from 25 may not contain information about confounding factors such Page 54 Page 56 1 an epidemiological standpoint based upon your education, 1 as smoking for example. We know that smokers have higher 2 your training and your knowledge? 2 death rates, and 1 think in order to answer that question 3 A Yes, 1 do. 1 find flaws in the fact she 3 1 don't mind you asking it to get his recollection. 1 4 stated that there was an increase in statistically 4 know he's read the article, but 1 don't think he's put it 5 significant increase in non-arteriosclerotic heart disease 5 to memory so that he has that kind of detail about a 6 and she tried to make some assumptions that these may be 6 multi-page -- you have got a quarter of an inch thick 7 related to PCB exposure, when some of the things have 7 report that he's looking at. 8 never, ever been considered to be associated with PCB 8 Q (By Mr. McCrea) Doctor, is it your opinion 9 exposure, namely rheumatic heart disease and phlebitis or 9 based on medical probability that the smog from an 10 inflammation of the veins in the lower legs, inflammation 10 industrial area contributes to a higher incidence of lung 11 of varicose veins, certainly those are flaws. 11 disease; is that what you're saying? 12 Q Any other flaws? 12 A Well, yes, but let me clarify something, that 13 A Well, I'm not sure about what her control 13 you are picking small bits out of here, you neglected to 14 group was. 14 mention that on the last page of this report the author 15 Q Any other flaws? 15 stated, "The high S.M.R" --, that's standard mortality 16 MR. CARNEY: You want the doctor to read the 16 rate for white males -- "is for the most part explained by 17 study? 17 the excess of deaths from circulatory disease exclusive 18 MR. McCREA: No, only to tell us what flaws 18 of arteriosclerotic heart disease. This cause of death 19 there are in the report. 19 category concludes deaths from rheumatic heart disease, 20 MR. CARNEY: Off the top of my head without 20 cerebrovascular disease and other forms of heart disease 21 reading it? 21 all of which are unlikely to be related to exposure in the 22 MR. McCREA: He's familiar with it. 22 workplace." And that's what the author says and that's 23 Q (By Mr. McCrea) Doctor, you're familiar with 23 what 1 said before was that 1 did not believe that it was 24 this study? 24 related to the work. 25 A Beg your pardon? 25 Q Well, then you agree with the author? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 53 - 56 LEXOLDMON006902 Page 57 Page 59 1 A 1 agree there, certainly yes. 1 didn't 1 the people in the plant than there were in the general 2 realize that she had come to this conclusion until 1 read 2 population of the United States? 3 this last bit. 3 A Well, you're asking for a flaw and 1 said you 4 MR. CARNEY: Again 1 think that just points 4 have to rule out those confounders. So if she is talking 5 out you're asking the doctor to read a sentence out of a 5 about diseases of the respiratory system where she has got 6 thirty page report or however long it was without giving 6 four as opposed to 1.53. If she hasn't ruled out smoking 7 him the opportunity to review it. When you ask in that 7 and compared smoking in this group with an average amount 8 kind of detail 1 think it's inappropriate to just ask him 8 of people, of males in the United States, that's a big 9 to read a sentence without having a chance to review the 9 flaw. 10 article. Turns out what he said earlier his testimony the 10 Q All right. Doctor, can you go to table 4? 11 author happens to agree with. 11 A That's where 1 read this last one from. 12 Q (By Mr. McCrea) What were the number of 12 Q And the S.M.R. for all causes of death was 13 expected deaths? 13 one point, was 131, is that correct? 14 A Twenty-three. 14 A That's correct. 15 Q 22.88? 15 Q So that would mean it was 131 percent 16 A Yes, that's twenty-three. 16 increase or a 31 percent increase of observed deaths 17 Q How many people died? 17 compared to what they thought they would find? 18 A Zero. 18 A Well, that's correct. Now again, if you 19 Q How many more deaths were there than expected 19 notice there's an asterisk on all other diseases of the 20 than, 7.12. 20 circulatory system, that means that scientifically 21 A 7.12. Remember again we're saying this, we 21 significant, the others are not. 22 are using all standard mortality rate for all males in the 22 Q Yeah, the others are not? 23 United States. 23 A Under 131, that could be explained by any 24 Q Not the St. Louis area? 24 number of factors including chance, a 131 S.M.R. over 100 25 A Huh? 25 is not statistically significant. Page 58 Page 60 1 Q Not the St. Louis area? 1 Q Is it suggestive? 2 A Or the St. Charles area, that's correct. 2 A No, 1 don't think so. 3 Q St. Charles? 3 Q What does suggestive mean in epidemiology? 4 MR. CARNEY: Well, St. Clair. 4 A 1 don't know if they use that term, 1 don't 5 A St. Clair. 5 know. I'm not an epidemiologist. 6 Q (By Mr. McCrea) St. Clair area? 6 Q Could it be probable? 7 A Right. 7 A Huh? 8 Q You have given us your explanation as to why 8 Q Could it be probable? 9 those rates are higher? 9 A No, 1 don't think so. Could occur by chance, 10 A Yes, and also she did not -- there may be 10 could occur by a lot of reasons, but she only picks one 11 other confounders in this. What 1 said about the four 11 thing as scientifically or as statistically significant, 12 rules of epidemiology, 1 don't think she had corrected for 12 the others she didn't. 13 smoking in here at all, she's not corrected for 13 Q There were 4.46 expected malignant neoplasms 14 alcoholism, she's not corrected for obesity. 14 and eight people died of that. 15 Q Are there smokers in the general population 15 Q What is malignant neoplasm? 16 of the United States? 16 A It's a cancer. 17 A Yes. 17 Q So in this study that number was almost 18 Q Are there people that abuse alcohol in the 18 double? 19 general population? 19 A Yes, sir, but again, there are confounders. 20 A Yes. 20 She did not check if for smoking and she did not say that 21 Q Are there people that are obese in the 21 this was statistically significant. That's the point 1 22 general population in the United States? 22 made earlier. 23 A Yes. 23 Q If it was twenty-one points higher would it 24 Q Is there any indication that there were more 24 be statistically significant? 25 smokers or more abuse of alcohol or and more obesity in 25 A That 1 don't know, but if it were Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 57 - 60 LEXOLDMON006903 Page 61 Page 63 1 statistically significant she would have put an asterisk 1 that subscribe to that, that PCB's are a health cure. 2 on there and said it was. But 1 can't say whether 2 MR. CARNEY: 1 don't think that - 1 tend to 3 twenty -- if we had instead of eight if she had twelve 3 agree with Dr. Kelly that having one death for more or 4 would that be significant? 1 don't know, but according to 4 less or any amounts that are not statistically 5 her, her figures shows that this is not statistically 5 significant, 1 wouldn't make any point one way or another 6 significant and also she did not check her smoking and the 6 about those. 1 couldn't say that PCB's are a benefit or a 7 majority of these cancers were lung cancers. 7 harm based on that study. So 1 would agree with Dr. 8 Q Diseases of the circulatory system, expected 8 Kelly. 9 11.17 and observed 16, is that correct? 9 MR. McCREA: Well, we may have you testify. 10 A Yes, sir. 10 MR. CARNEY: Well, if you want to take my 11 Q Diseases of the respiratory system were about 11 deposition, you're welcome. 12 the same, digestive system, slight increase, all other 12 Q (By Mr. McCrea) Dr. Kelly, did you report, 13 diseases, about the same, external cause of death, what's 13 did Monsanto report this information to its workers? 14 that mean, like somebody gets in a car wreck? 14 A 1 don't know, this was finished in what, 15 A Maybe you're shot or a car accident. 15 19 -- 1977, so 1 don't know. 16 Q They expected 2.38 and there was only one. 16 Q Now Dr. Zack and Mr- 17 Now that wouldn't have anything to do with PCB's, would 17 A She isn't a doctor. 18 it? 18 Q She's a what, master, has her master's 19 A No of course not, but it shows that, 1 don't 19 degree? 20 know. 1 mean, external cause of death, if a man is killed 20 A Let's see what it says. Master of public 21 in a holdup or it's an auto accident on the way back from 21 health. 22 work that has very little to do with PCB exposure. 22 Q And she was hired by Monsanto to do this work 23 Q On the S.M.R. the numbers that did exceed a 23 so they felt she was -- 24 hundred are one, two, three, four, five, six, seven, 24 A Just a moment. She was hired by Monsanto 25 eight, nine, ten. The numbers that are less than a 25 after 1 left. Doing this work was part of her duties. Page 62 Page 64 1 hundred are one, two, three, four, five, six, correct? 1 She was not hired by Monsanto to do this epidemiological 2 A Well, correct; but it doesn't mean a thing. 2 study. 1 don't know when she was hired, it was sometime 3 When 1 say correct, 1 mean you added them up correctly but 3 after 1974 and when she started this study 1 don't know, 4 it doesn't mean a thing. 4 but 1 do not believe she was hired to do this work. 5 Q Now if this report - 5 Q Was she competent? 6 MR. CARNEY: Just a minute, you're 6 A 1 don't know her at all. 7 interrupting. 7 Q Has anybody at Monsanto suggested that she 8 A It doesn't mean a thing because the only 8 was not competent? 9 thing that is statistically significant is the increase in 9 MR. CARNEY: I'm going to object. There's no 10 all other disease. The circulatory disease-- 10 foundation that Dr. Kelly knows about her since she was 11 Q (By Mr. McCrea) Dr. Kelly, if 1 -- Excuse 11 hired after he retired. 12 me. 12 Q (By Mr. McCrea) Have you heard anyone 13 MR. CARNEY: Just a minute. 13 suggest that she was not competent? 14 Q (By Mr. McCrea) Were you finished? 14 A But the same-- Well, 1 can't answer that. 15 A No, because if you have -- take this, we have 15 I'm not sure that 1 ever heard anybody say that she was 16 one case of a death from genitourinary it's kidney and 16 the best epidemiologist west of the Mississippi. 17 bladder, expected half a death, so we have got a figure of 17 Q Would you turn to page ten of the draft 18 196 but from epidemiological and scientific point of view 18 report, the last sentence. The last sentence states and 19 that proves nothing so the fact that you have added these 19 this sentence, this was part of the report dated -- 1 20 up over a hundred proves nothing. 20 don't see a date -- 1 don't know when the draft report was 21 MR. CARNEY: 1 assume you don't think, Mr. 21 prepared, but the last sentence states, "A future study of 22 McCrea, that the fact that there were six or seven 22 this cohort could evaluate the mortality of workers 23 diseases where it was less than expected that that means 23 involved from the initial through the final year of PCB 24 PCB was actually a benefit with regard to those diseases? 24 production and thus have more power to detect any possible 25 MR. McCREA: No, that's -- you're the people 25 hazards of PCB exposure." Did Monsanto do another study? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 61 - 64 LEXOLDMON006904 Page 65 Page 67 1 A Well, first of all to answer the question, 1 1 the first document which was page one? 2 don't know. 2 A Yes, sir. 3 Q All right. Thank you. 3 Q Can you identify the document? 4 A But relate me say that if you read any 4 A It's a material safety data sheet form 5 epidemiological study that's almost standard boilerplate, 5 submitted by the -- of the United States Department of 6 "Let's do a further study down the road and see if we find 6 Labor, presumably filled by Monsanto Company on Inerteen 7 out anything else." It's not unique to this study. 7 100 dash 2 - dash 42. 8 Q Doctor, your interpretation of the study for 8 Q Will you turn to page two at the bottom and 9 the jury is what? 9 give us the date of the preparation of this document? 10 MR. CARNEY: I'm sorry, what? 10 A 1/26/72. 11 Q (By Mr. McCrea) Your interpretation of this 11 Q Doctor, what is a material safety data sheet? 12 mortality study for the jury is what? 12 A It gives information about the safe handling 13 A It's that -- 13 of various materials. 14 MR. CARNEY: I'm gong to object to the form. 14 Q Did you ever suggest on any labels which you 15 THE WITNESS: Sorry. 15 used at Monsanto that the worker should read the material 16 MR. CARNEY: Go ahead. 16 safety data sheet before working with the particular 17 A That it showed no scientific statistical 17 chemical? 18 evidence of any illness associated with work with PCB. 18 A No, sir. 1 have never seen that type of 19 Q (By Mr. McCrea) All right. Doctor, let's 19 information on any label; no matter what company's product 20 move to the exhibits and if your counsel could hand you 20 it was. 21 the exhibits which are numbered pages 1 through 261 and 21 Q If 1 called you in 1972 and asked you if 1 as 22 we'll have the court reporter mark that as a single 22 a worker at the Bloomington Westinghouse plant should read 23 exhibit and then if Counsel and 1 can agree to reference 23 and understand the material safety data sheet before 24 the various documents by exhibit number and page numbers. 24 working with Inerteen 100 dash 42 in order to secure my 25 MR. CARNEY: That's agreeable. 25 health, what would your answer be? Page 66 Page 68 1 (Whereupon, Defendant's Deposition Exhibit No. 6 1 A 1 would say, "You are working at the 2 was marked for identification.) 2 Bloomington plant, of the Westinghouse Electric Company?" 3 Q (By Mr. McCrea) Doctor, what is the exhibit 3 Q Yes, sir? 4 number on there? 4 A "And you have foremen there and you have 5 A Six. 5 manufacturing people who have information of their own and 6 Q Doctor, the court reporter has marked a stack 6 information they received from us concerning the safety of 7 of documents with Plaintiffs Exhibit No. 6; do you have 7 working with PCB's." 1 would say ask your foreman about 8 that in front of you? 8 it. 9 A Yes. 9 Q And if 1 told you my foreman doesn't know 10 Q And does that show pages numbered 1 through 10 anything what would you tell me? 11 261 on the bottom of the entire stack? 11 A Go to the plant manager. 12 A Yes, sir. 12 Q And if 1 told you he can't answer my 13 Q Doctor, you have had those documents for a 13 questions? 14 couple of days. Are there - Have you had a chance to 14 A 1 would say have the plant manager call me. 15 look through them or not? 15 Q If 1 asked you to send me a material safety 16 A Well, 1 skimmed them, 1 really haven't gone 16 data sheet, would you do it? 17 through word by word. 17 A Yes. 18 MR. CARNEY: Let me just mention that 18 Q What does it mean form number OSHA dash 20 at 19 yesterday was the first time that you gave these documents 19 the upper righthand corner? 20 to me. 1 did not give these to the doctor to have 20 A Haven't the slightest idea. 21 overnight and 1 think he thumbed through them during a 21 Q Why is an emergency telephone number printed 22 break for maybe five minutes. So he hasn't had a chance 22 on Section 1? 23 to read them more than a five minute just thumbing 23 A In case there's a spill or some -- these 24 through. 24 safety data sheets have been used primarily and were 25 Q (By Mr. McCrea) Doctor, would you turn to 25 originally designed for use during the transportation of Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 65 - 68 LEXOLDMON006905 Page 69 Page 71 1 materials and they were used in case there was a truck 1 A Oh, yes. 2 extent or something like that and there's a whole bunch of 2 Q What is Inerteen 100 dash 42? 3 drums spilled and that's why they have all this other 3 A Inerteen is a Westinghouse product that 4 data, not only health data but fire and explosion, what to 4 consists of PCB's and seventy percent and a certain amount 5 do about spills, leaks and precautions. 5 of trichlorobenzene . 1 don't know which PCB it is, 6 Q It's your testimony that material safety data 6 whether it's 1248, 1252 and 1 believe the trichlorobenzene 7 sheets were intended for the people who transport the 7 is around thirty percent. 1 don't know what 42 means, 8 chemicals? 8 whether that's 42 percent trichlorobenzene, but it is a 9 A Oh, 1 said primarily. 9 significant amount of trichlorobenzene in it. 10 Q Primarily, and the number 314 694-1000, who 10 Q It says chemical family, chlorinated 11 would answer that phone? 11 aromatic? What is chlorinated aromatic? 12 A Oh, the telephone you mean. 12 A Well, it's a -- an aromatic chemical is one 13 Q Correct. 13 that has the benzene ring in it. Chlorinated means it has 14 A Well, that depends when it came in. 1 mean, 14 the chlorine molecule on it, chlorine atom on it. 15 if it came in at nighttime, the night watchman would do 15 Q Do you list the hazardous ingredients of 16 it. If you said we have got a fire here, he's got a list, 16 Inerteen 100 dash 42? 17 fires, explosions, here's the people you call. 17 A We list the thing as a whole. 18 Q And there were people? 18 Q That doesn't tell you what's in Inerteen 100 19 A Yes, there were people -- if he said we've 19 dash 42, does it? 20 got a person here who wanted to know about the toxicity of 20 A No, it did not. 21 this particular product, it would come to the group, in 21 Q Why not? 22 the medical department. We had our own people, a list of 22 A 1 don't see why you need to tell the 23 those with the night foreman and if it came in in the 23 ingredients. You tell them what to do and what the 24 daytime it would come to our, the medical department, 24 hazards are. 25 unless it was a fire. 25 Q Well, it's got a section, Section 2, Page 70 Page 72 1 Q Did you have people with specialized 1 hazardous ingredients, were there hazardous ingredients in 2 knowledge to answer questions with regard to potential 2 Inerteen 100 dash 42? 3 problems from Inerteen 100 dash 42? 3 A Yes. 4 A Well, yes. We didn't have specialized 4 Q And but you don't know what they are today? 5 knowledge about fire and explosion, that was outside our 5 A What do you mean 1 don't know what they are 6 realm. We certainly didn't have specialized knowledge 6 today? Sure 1 know what they are today. 7 about what you would do to get the stuff out of the 7 Q What were they? 8 ground, whether you dig it up or put kitty litter on it or 8 A PCB's and trichlorobenzene. 9 God knows what, but we certainly had expertise as far as 9 Q What does it mean TLV, under hazardous 10 what safety precautions should be used in cleaning it up. 10 ingredients, it has a column TLV? 11 Q Your testimony was you didn't have 11 A Threshold limit value. 12 specialized knowledge with respect to fire and what to do 12 Q Explain to the jury. 13 if it got in the ground? 13 A The threshold limit value is a figure that 14 MR. CARNEY: Are you talking about Dr. Kelly 14 shows the amount of the material that can be at the safe 15 or Monsanto? 15 level of a material that can be in the air in an eight 16 MR. McCREA: Monsanto. 16 hour day over a worker's lifetime. 17 A Oh, Monsanto did. 1 said the medical 17 Q If you exceeded that level by four or five 18 department was responsible for the health and safe 18 times for one day would that be a problem? 19 handling. We had people in the manufacturing group that 19 A No. Are you assuming that here is a truck 20 would be available and the transportation group that would 20 spill on Interstate 70 -- 21 be available to tell them how to clean it up. 21 Q No, in a plant, in a plant. That doesn't 22 Q (By Mr. McCrea) So there were various people 22 apply to a truck spill, does it? 23 with specialized knowledge who could answer questions 23 A Yeah, sure it does. 24 regarding the use and/or emergencies involving Inerteen 24 Q TLV? 25 100 dash 42? 25 A The man isn't going to be taking a TLV when Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 69 - 72 LEXOLDMON006906 Page 73 Page 75 1 he's got a truck leak out on Highway 70. 1 A 1 would tell the caller -- he asked me, if-- 2 Q That applies to the person using it? 2 Let me get this very definite. You've told me that this 3 A That's correct, but it also applies primarily 3 caller has said we're going ten times the maximum 4 as 1 said to transportation, that was what this -- the 4 allowable concentration for a month, what do you think is 5 genesis of this. That's what these things started with, 5 liable to happen or is this all right? 6 the Department of Labor, not OSHA, not NIOSH. 6 Q Correct. 7 Q And if you exceeded the TLV by three or four 7 A 1 would say one, no, it isn't all right, you 8 times for one day for a week or a month would that be 8 should get back, you should police up the thing so that 9 problem? 9 you get back under the allowable concentration. If you 10 A 1 don't think so. 10 ask me then 1 would say as far as 1 know there are reports 11 Q And if Westinghouse called you on January 26, 11 in the literature that shows people who have worked in 12 1972 and asked you if you exceeded the TLV by three or 12 exposures over the TLV for longer periods than a month and 13 four or ten times for a one one day period your answer 13 have showed nothing with the exception of some foreign 14 would have been the same? 14 places where they have showed chloracne, but we do not 15 A Yes, 1 would say get it under control but 1 15 recommend that you keep doing this. 16 don't think you're going to have any trouble; because 16 Q If 1 called you in 1972 and 1 say, "Dr. 17 there are reports of people, places where they have 17 Kelly, we just tested our manufacturing area and we found 18 exceeded it for a considerable period of time with no ill 18 out that for the last six months the abient air levels 19 effects. 19 have exceeded the TLV by three or four times and we have 20 Q And if 1 called you from Westinghouse and 20 workers complaining, complaining of lassitude, or loss of 21 asked you that same question, Dr. Kelly, are there reports 21 appetite and loss of libido, but they do not have any 22 of people who were exposed to excessive levels of PCB and 22 chloracne, should we be concerned?" 23 trichlorobenzene and would your answer be yes, there have 23 A 1 would say yes, you should be concerned 24 been and they suffered no ill effects? 24 because you have exceeded the TLV and you should examine 25 MR. CARNEY: Well, let me object to the form 25 the workers to see if they have any demonstrable physical Page 74 Page 76 1 of the question. When you ask about excessive levels you 1 effects. 2 have not defined that. So it's a vague question. 2 Q 1 have said Dr. Kelly these workers are 3 A Yes, I'd say what levels? 3 complaining of lassitude, loss of appetite and loss of 4 Q (By Mr. McCrea) Four or five times the TLV? 4 libido, but -- and we know they have had a heavy exposure 5 A For how long? 5 but -- or at least it's about two times the TLV but none 6 Q A week. 6 of them have chloracne. Dr. Kelly, in your opinion, based 7 A I'd say that wasn't going to bother anybody. 7 on your experience with Monsanto do you feel there is a 8 Q Ten times the TLV for a month? 8 causal relationship between their exposure and those 9 A 1 would say you better -- there have been - 9 symptoms? 10 1 would say there have been no reports of any ill effects 10 A No. 11 in the electrical industry. In 1972 you're calling me 1 11 MR. CARNEY: I'm going to object. Are we 12 will say there have been no reports of any illness in the 12 talking about what type of plant? 1 don't think he 13 electric industry from using PCB or we're talking about 13 mentioned PCB's but I'm assuming that you are talking 14 here Pyrenol. We certainly do not recommend that you 14 about a plant with PCB's where they are exceeding the 15 exceed the TLV ten times for a month but there have been 15 levels and 1 think he has said two times -- 16 no reports of ill effects. You certainly should--well 16 A Well, I'd say these people do not have 17 that's it. 17 chloracne. You have examined them 1 presume? 18 Q By stating to the caller that there have been 18 Q (By Mr. McCrea) Yes. 19 been no reports of ill effects that indicates that in all 19 A And they have no other findings? 20 of the industry situations with all of the exposure there 20 Q Yes. 21 were no problems? 21 A They have no other findings, physical 22 A No, it doesn't at all. 1 said there have 22 examination is negative, laboratory examination is 23 been no reported ill effects. 23 negative, 1 would say 1 would -- if these were negative 24 Q And you would have communicated that in 1972 24 and they have no chloracne 1 do not believe that these 25 and intended the caller to rely on that statement? 25 symptoms were a result of their exposure at work. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 73 - 76 LEXOLDMON006907 Page 77 Page 79 1 Q Thank you, Dr. Kelly. Section 3, physical 1 A Yes, sir. 2 data; can you briefly explain that to the jury? 2 Q The next page, section 5, "Health Hazard 3 A Well, 1 don't know what there is to explain. 3 Data," and it says, "Threshold limit value, not 4 The physical data means is it a solid, is it a liquid, is 4 available." You've already defined the threshold limit 5 it a gas, what's the specific gravity, is it soluble in 5 value, why was it not available? 6 water, what's its vapor pressure, does it have an odor? 6 A The mixture. 7 Q So it's odorless oil? 7 Q Why was there no, why were there no numbers 8 A Colorless oil, it says. 8 for the threshold limit value? 9 Q Colorless? 9 A Because it hasn't been run on a mixture, it 10 A It says aromatic odor. 10 hasn't been set by the government hygienist group on the 11 Q Aromatic odor, sorry, 1 couldn't read that on 11 mixture. They had set it for trichlorobenzene. 12 my copy. So that just tells you those things? 12 Q What was it? 13 A Yes. 13 A And 1 presume they had set it for -- 14 Q Fire and explosion hazard data, section 4, 14 Q PCB? 15 flash point COC 180 degrees C. What does that mean? 15 A The PCB. 16 A Well, again, I'm not a fire and explosion 16 Q But not the combination? 17 expert. Flash point means at what temperature does this 17 A Not the combination. 18 material explode, 1 believe. 1 can't answer that, that's 18 Q All right. It says effects of overexposure, 19 an fire question, it gets a little involved. 1 don't know 19 what is overexposure, what does that mean? 20 what C.O.C., that's a type of test that they do; but 180 20 A If you get too much -- 1 don't know if 1 can 21 degrees C is a pretty high temperature inasmuch as a 21 define exposure, you get either inhalation or absorption 22 hundred degrees C is boiling water, so you've got to get 22 through your skin, that's the exposure and you get too 23 it up there before it ex- before it catches on fire. 1 23 much. 24 can't -- 1 can't explain it any more than that. 24 Q All right. Break time. 25 Q Special fire fighting procedures. It says 25 (Whereupon, a short break was taken.) Page 78 Page 80 1 where respiratory protection when fighting fires, where 1 Q Dr. Kelly, back on the record after a short 2 exposure to vapors or gases is possible, why? Why is that 2 break. 3 in there, Doctor? 3 A Yes, sir. 4 A Why is it in it? Because we want them to 4 Q Under section 5, Health Hazard Data, which is 5 wear a respirator around a fire where this is burning. 5 page two, Exhibit 7? 6 Q And what are the concerns? 6 A Yes, sir, what -- 7 A Well, 1 don't think you want to inhale the 7 Q What's the exhibit number? 8 product of combustion of any fire. 8 A Six. 9 Q But Doctor, this material safety data sheet 9 Q Of Exhibit 6, there is a box under section 5, 10 doesn't concern anything but Inerteen 100 dash 42? 10 health hazard data and the first heading you explained 11 A Well, 1 know that, but if Inerteen is burning 11 threshold limit value, the next one is effects of over 12 and you've got a lot of fumes coming off you want to wear 12 exposure. Can you as the medical director of Monsanto 13 respiratory protection. If you got a bunch of clothes and 13 Company give us a working definition of overexposure for 14 papers burning in the garage, I'd advice the same thing. 14 Inerteen 100 dash 42? 15 You don't want to be around a fire where you can inhale a 15 A No, sir. 16 lot of fumes, that's not good for you. 16 Q If 1 called you up on January 26, 1972 and 17 Q All right, sir. Next it says and 1 can't 17 informed you that 1 was a worker at the Bloomington 18 read the small print -- 18 Westinghouse plant and 1 would like to you to define 19 A "Highly toxic gases, chloride" -- 19 overexposure for this product you could not do it? 20 Q Above that is what 1 am talking about. It 20 A Well, 1 couldn't do it as a matter of 21 says something fire and explosion hazards? 21 figures. 1 would tell him how to avoid overexposure which 22 A Oh, 1 can't read it, 1 -- 22 1 believe is what the man would want. 23 Q All right. At any rate, it says, "Highly 23 Q If 1 asked you for a definition of 24 toxic gases, chloride and chlorine could be evolved in 24 overexposure could you do that? 25 fires of this product." Is that a correct statement? 25 A Well, 1 would say tell me what you're doing Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 77 - 80 LEXOLDMON006908 Page 81 Page 83 1 and 1 will tell you whether you're overexposed or not. 1 think that was overexposure, Doctor? 2 Remember this overexposure was not my definition, that's 2 A Well, I'd have to ask him how much. How long 3 government's definition, that's Department of Labor. 3 were you in there? How long did the eyes burn? How long 4 Maybe you should call them and ask what's overexposure. 4 did your nose burn? How long did your skin itch? 5 Q But Monsanto is answering and supplying the 5 Q Thirty minutes a day once a week for four or 6 information in thatbox, correct? 6 five years. 7 A Yes, sir. 7 A 1 would have to see it for myself. 1 would 8 Q TLV has a definition, correct? 8 not be able to answer whether exposure in a plant based on 9 A Yes, sir. 9 a telephone description of somebody's job, 1 would not be 10 Q But there is not a working definition for the 10 able to answer that. 11 common man of overexposure, he says under what conditions 11 Q If a worker called you and stated that he had 12 is there overexposure, you couldn't tell him? 12 headaches twenty-five percent of the time that he was 13 A Well, 1 guess 1 could tell him. 1 would say 13 working in the area with PCB's would you think that was 14 if you're breathing the material at elevated temperature 14 overexposure? 15 and if you're breathing material at amounts over the 15 MR. CARNEY: I'm going to object, 1 don't 16 accepted TLV for the ingredient of this material and if 16 think you've given enough facts. Describe the conditions, 17 you're getting your clothes repeatedly or continuously 17 describe the other chemicals, describe the severity of the 18 soaked and contaminated with the clothing, that's 18 headaches. 1 think there's a whole myriad of facts that 19 overexposure. 19 you'd have to give to be able to answer the question. 20 Q If he asked you for a definition of 20 A 1 wouldn't answer them. 1 would say, "Look, 21 overexposure on a long term basis could you give him the 21 1 don't know what the cause of your headaches are. What 22 same answer? 22 you should do is go and see your plant physician and ask 23 MR. CARNEY: Are you talking about safety 23 him to find out what the cause of your exposure is" -- 1 24 data sheet? 24 mean, "what the cause of your headaches is, and whether or 25 MR. McCREA: No. 25 not exposure to PCB has caused these headaches." 1 would Page 82 Page 84 1 Q (By Mr. McCrea) If a worker called in 1972 1 say, "We do not have headaches in our workers, but 1 don't 2 and asked you to define over exposure to Inerteen 100 dash 2 know what the situation you're working in is." 3 42 over a period often years could you have given him a 3 Q (By Mr. McCrea) It would be your response 4 definition? 4 then that you don't know if headaches can be a symptom of 5 A Well, 1 wouldn't be able to tell him what, 5 exposure to PCB's? 6 tell him what his working conditions were over ten years. 6 A That isn't what 1 said. 1 said 1 do not know 7 1 mean, if he would explain his working conditions to me 1 7 if you're headaches are coming from your PCB exposure. 8 could tell him whether that was overexposure or not. 8 Q Well, if he said he works in PCB's and that's 9 Q If he said he defected the odor of Inerteen 9 all he works in and he experienced headaches, would you 10 every day he was in the plant every day for ten years, 10 consider that as a sign of overexposure? 11 maybe not all day but during portions of the day and he 11 A No. 1 would not, because there are a myriad 12 asked you, "Doctor, do you think that amounted to 12 of causes of headaches, ranging from brain tumors to 13 overexposure and should 1 be medically monitored?" What 13 constipation. 14 would you tell him? 14 Q You understand we're talking about a 15 MR. CARNEY: Objection to the form. 15 worker- 16 A No. This'not overexposure, the threshold 16 A Yes, a worker-- 17 limit value is much higher than the odor threshold. 17 Q -with PCB's? 18 Q (By Mr. McCrea) The threshold limit value is 18 A -working with PCB and he says, "1 have got 19 much higher- 19 headaches, am 1 overexposed to PCB?" 20 A You can smell it. You can smell it well 20 Q The answer would be no? 21 below the threshold limit value. 21 A 1 would say, "You'renot giving me enough 22 Q If he said that, "1 worked in the plant for 22 facts. 1 don't know whether there are other causes, other 23 six years and once a week we would open the vapor flume 23 conditions that may be giving your headaches. 1 do not 24 and this is the Muncie transformer plant, my eyes would 24 know what the conditions of your presumed overexposure is. 25 burn, my nose would drain, my throat would burn," do you 25 1 don't know if you're overexposed." Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 81 - 84 LEXOLDMON006909 Page 85 Page 87 1 Q If he called you and said that he's 1 overexposure at fire, you would get, you may get systemic 2 experienced nausea? 2 intoxication, which would lead to nausea, vomiting, loss 3 A 1 would certainly not make a diagnosis over 3 of weight, edema and abdominal pain. 4 the phone on an interstate telephone call. 4 Q Doctor, where does it say the effects of 5 Q But he's just asking for your advice and he 5 overexposure from a fire in Section 5, Health Hazard Data? 6 wants to know could that be an indication of overexposure, 6 Where does it say the that? 7 what would your answer be? 7 A It doesn't state that at all. You're trying 8 A 1 don't believe it would. 8 to cover all the bases in two lines. 9 Q He said he's experienced vomiting, what would 9 Q 1 want to ask you where it states -- 10 your answer be? 10 A It doesn't state it. 11 MR. CARNEY: You're asking - first of all, 1 11 Q Is it your -- 12 think the Doctor said he wouldn't make a diagnosis. He 12 MR. CARNEY: On this page or on the prior 13 told you how elaborate his examinations are, and now 13 page? It talks about fire right in the section 14 you're asking him to say if somebody calls him up and says 14 immediately adjacent to it. 15 they have had vomiting and he worked with PCB's -- 15 MR. McCREA: 1 understand that. I'm asking 16 MR. McCREA: He just want his advice as to 16 the doctor where in Section 5 it suggests or implies that 17 whether or not that would be an overexposure to PCB. 17 the overexposure is the result of a fire as he just 18 A My advice would be get yourself examined and 18 testified. 19 find out. 1 can't tell him whether that's an indication 19 A No, it does not. 20 or not, barring everything else, no, 1 wouldn't dream of 20 Q (By Mr. McCrea) It says effects of 21 doing that. 21 overexposure, period, correct? 22 Q (By Mr. McCrea) If he said he's experiencing 22 A Is that right? 23 loss of weight, and he wants to know if that could be a 23 Q There's no -- 24 sign of overexposure, what would you say? 24 MR. CARNEY: 1 don't see any period. 25 A 1 would say find out what the cause of your 25 MR. McCREA: Well, 1 didn't mean, Tom, a Page 86 Page 88 1 loss of weight was. 1 period like that, (indicating). What 1 meant was effects 2 Q He said he experienced edema, what would your 2 of overexposure, period, no more information. 3 answer be? 3 MR. CARNEY: Well, there's some words below 4 A Edema where? 4 that. 1 thought 1 was trying to be accurate. 5 Q 1 don't know? 5 A What is your question, Mr. McCrea? 6 A Well, 1 sure wouldn't know either. 6 Q (By Mr. McCrea) My question is that nausea, 7 Q He says he experiencedabdominal pain and he 7 vomiting, loss of weight, edema and abdominal pain 8 wants to know if that could be a sign of overexposure, 8 according to you in your testimony would not be signs of 9 what would be that be? 9 overexposure; yet on the material safety data sheet 10 A 1 would say you better get your abdominal 10 published by the company for whom you worked during the 11 pain diagnosed. 11 time period you worked they're all listed as effects of 12 Q Dr. Kelly, would you read the effects of 12 overexposure; how do you explain that? 13 overexposure as published by Monsanto Company? 13 A Well, I'll explain it very easily. 1 wrote 14 A Yes, sir. Skin irritation, in the form of 14 and 1 put this dope because those symptoms did occur from 15 chloracne, systemic intoxication leads to nausea, 15 overexposure from inhaling the material at elevated 16 vomiting, loss of weight, edema and abdominal pain. 16 temperatures. 17 Q Emergency and first aid procedures? 17 Q Where do you get the information that nausea 18 A Yes, sir. May 1 add something to that 18 resulted from exposure to inhaling the materials at 19 effects of overexposure? You realize we are talking here 19 elevated temperatures? 20 about acute overexposures, we are talking here about the 20 A In the article by Dr. Spoyer about the three 21 individuals who inhaled the material at elevated 21 people that inhaled the material in a jury rigged heat 22 temperatures from the heat transfer units. We are talking 22 transfer unit where they were exposed for one to three 23 here also about a safety data sheet that's supposed to, 23 days of the material leaking at elevated temperatures 24 was originally designed to cover transportation accidents 24 where they had nausea, vomiting, loss of weight, edema and 25 where there's a fire and what we could expect if you had 25 some abdominal pain due to an enlarged liver. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 85 - 88 LEXOLDMONOQ6910 Page 89 Page 91 1 Q Now you wrote this and you mentioned edema 1 which would give an edema, but that doesn't seem a very 2 but you don't explain where it is. Can you tell us now 2 prominent to me. 1 -- if 1 remember writing this in 1980, 3 where the edema occurred? 3 1990 1 probably wouldn't put edema in. I'd put the others 4 A No, 1 don't. 4 in. 5 Q But you wrote it? 5 Q Emergency and first aid procedures under 6 A 1 wrote it eighteen years ago and 1 don't 6 Section 5, Health Hazard Data again, page two, states 7 know where the edema was. 7 "Remove from exposure, remove contaminated clothing, wash 8 Q Do you appear down at the bottom under any of 8 contacted area with large amounts of water and soap, refer 9 the initials JAG, HOH, GTG, WVP? 9 to physician." Define contaminated clothing. Did you 10 A No, sir, I'm REK. I'm not on any of those. 10 write this portion? 11 Q But you did write this? 11 A Yes. 12 A Yes, 1 wrote that part, 1 wrote the health 12 Q Define what you mean by that. 13 hazard data certainly. 13 A Contaminated clothing is wearing apparel that 14 Q What is meant by edema? 14 has something on it that you don't want. 15 A Swelling. 15 Q It says refer to a physician. Do you -- did 16 Q Where? 16 Monsanto have a method in place wherein they educated 17 A Any place, you have edema under the eyelids, 17 local doctors on the effects of overexposure to PCB's and 18 you have an edema of the legs from heart disease, you get 18 what the local doctor should do? 19 edema a lot of places. 19 MR. CARNEY: Let me object to the form of the 20 Q What areas of the body can be affected by 20 question, it's compound. 21 edema from overexposure to Inerteen 100 dash 42? 21 A Well, to answer your question, no, we did 22 MR. CARNEY: Objection to the form of the 22 not. We did have numbers that any physician could call us 23 question. 23 and ask for information about the first aid or further 24 A 1 don't know. It's never been reported to my 24 treatment of workers and as 1 said in my thirty-eight 25 knowledge. 25 years with Monsanto 1 probably had less than five calls. Page 90 Page 92 1 Q (By Mr. McCrea) 1 thought you put this down 1 Q (By Mr. McCrea) A doctor calls you in 1972 2 as a result of your report? 2 and he says, "Dr. Kelly, I'm Dr. Smith in Bloomington, 3 A Yes, but one of the ingredients of Inerteen 3 Indiana. 1 have a worker from the Westinghouse plant who 4 was a PCB which was used in the heat transfer unit. 4 has skin irritation in the form of chloracne, systemic 5 Q You included edema as an effect of 5 intoxication which led to nausea, vomiting, loss of 6 overexposure based on a report which you read, where did 6 weight, edema and abdominal pain. What should 1 do for 7 the edema occur in that report? 7 him?" What's your answer? 8 A 1 don't remember where it occurred; but 1 8 A Remove him from any exposure to PCB. Here we 9 really don't know what difference it makes. If they did 9 have a man who has exposure, sufficient to give him 10 have swelling any place, it wouldn't make much difference 10 chloracne, sufficient to give him deranged liver function. 11 whether it was swelling under the eyes or in the legs. 11 Remove him from exposure, send him to a dermatologist for 12 Q How do you explain the abdominal pain as a 12 the treatment of the chloracne, give him a high 13 result of overexposure to PCB's or Inerteen 100 dash 42? 13 carbohydrate diet for his liver, follow him closely and 14 A Involvement with the liver. 14 call the plant and say, "1 have this man who has what 1 15 Q And what involvement with the liver causes 15 have diagnosed as a condition resulting from PCB. 1 think 16 the pain? 16 you ought to look into this matter." And then 1 would 17 A Swelling of the capsule of the liver. 17 call the plant myself if 1 had gotten that call. 18 Q How do you explain loss of weight as a result 18 Q If he asked you if there were any other signs 19 of overexposure to Inerteen 100 dash 42? 19 or symptoms that he should check for what would you tell 20 A If they are nauseated and they are vomiting 20 him? What would you have told him in 1972? 21 and their liver isn't working well, at subpar 21 A 1 wouldn't have told him anything. He told 22 functioning you could have loss of weight. 22 me everything he needed, he had liver problems and he had 23 Q How do you explain edema? 23 skin problems. And -- 24 A 1 can only explain it if the liver were so 24 Q If he asked you if he should check-- 25 swollen that it would press on the veins leading into it 25 MR. CARNEY: Just a minute. Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 89 - 92 LEXOLDMONOQ6911 Page 93 Page 95 1 A He had liver problems and he had skin 1 because of PCB exposure? 2 problems, they are treating the whole individual. He 2 A I'd say not because of the PCB exposure; I'd 3 doesn't care what other symptoms he has. He wants the man 3 say you presumably have a liver problem. If you have a 4 to get well, so he's treating his liver and he's treating 4 liver problem you don't want to add any other problems to 5 his skin. 5 it and alcohol is one of them. 6 Q (By Mr. McCrea) If he asked you to be on the 6 Q And would that hold true for a person who has 7 lookout for any other consequences to his health what 7 a mild liver problem? 8 would you tell him? 8 A What is meant by mild. 9 A I'd say check on any possible peripheral 9 MR. CARNEY: Objection to the form. 10 neuritis. 10 Q (By Mr. McCrea) What is meant by mild is 11 Q Anything else? 11 what we discussed in the Zack article as reported in the 12 A No. I'd probably also say you ought to 12 City of Bloomington, Indiana which stated in 1976 the 13 report this case because that would be the first in the 13 Monroe County Board of Health conducted biochemical tests 14 literature. 14 among Bloomington, Indiana residents exposed to PCB's 15 Q If he mentioned he had joint pain and he 15 serum levels of gamma glutino -- 16 wanted to know if that was a cause of the exposure ha 16 A GGT. 17 would your answer have been in 1972? 17 Q GGT, and plasma triglyceride levels were 18 A Same as today. 1 don't believe it's related. 18 found to show a direct relationship to serum PCB levels. 19 Q If he said he had loss of libido, what would 19 If that doctor called you and said, "Dr. Kelly," and said 20 your answer be in '72? 20 "This individual has elevated GGT and plasma and 21 A 1 would check out other causes. 21 triglyceride should he drink alcohol?" What is your 22 Q If he said he had lassitude what would your 22 answer? 23 answer have been? 23 A First of all you have made several earlier 24 A Well, I'd say if you have got loss of weight 24 comments about the Zack article in this question and when 25 and you have liver problems you could very well have 25 1 answered the question you said liver problems. Zack did Page 94 Page 96 1 lassitude. 1 not say these people has liver problems. She said they 2 Q Let said he was irritable, would you have 2 had -- that the levels of GGT and the triglycerides were 3 related that to the exposure? 3 proportional to the PCB levels. 4 A 1 don't know. 1 mean, it all depends, you'd 4 Q Correct. 5 have to tell me more about the situation. Just irritable, 5 A She didn't say they were increased as 1 saw 6 how long, when? But 1 think you're a little unrealistic 6 them. 7 because the doctor would be call me about the man's 7 Q That's true. 8 medical condition at the present time. He would not be 8 A So if this man said this person has high 9 interested in the symptoms. He'd be interested in is 9 triglycerides and 1 said that doesn't bother me, 10 there anything else of a major condition that 1 could 10 particularly alcohol bringing up high tri -- gives you 11 expect and 1 would give him the only other one that 1 11 high triglycerides anyway. I'd say as far as the GGT is 12 would think would be important. 12 concerned I'd say how high is it, and if it's elevated 13 Q If he asked you if there were any medications 13 twice as much I'd say he shouldn't take alcohol until it 14 which he should got give to the person, what would you 14 comes down. 15 tell him? 15 Q All right, sir.Any other medications that 16 A 1 would say don't let him take any alcohol. 16 you would advise the doctor not to administer to this 17 Q Why? 17 individual with these symptoms which Monsanto has listed 18 A Because alcohol has an effect on the liver. 18 under its Health Hazard Data, January 26, 1972 for 19 If you drink alcohol you destroy some liver cells. 19 Inerteen 100 dash 42? 20 Q Is that particularly true if a person's been 20 A I'd have to remember what medications were 21 exposed to PCB's? 21 being used in 1972. 1 mean, there may have been some and 22 A No. But it's true of everybody in the United 22 1 am more familiar with them but 1 can't answer that right 23 States. 23 now. 24 Q If he said he wanted to go out and have 24 Q You stated that you had less than five calls 25 something to drink would you tell him no, you shouldn't 25 from doctors, can you recall any of them? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 93 - 96 LEXOLDMONOQ6912 Page 97 Page 99 1 MR. CARNEY: 1 don't think that was his 1 dioxin. 2 testimony. 2 Q Anything else? 3 MR. McCREA: He said during the time that he 3 A No, sir. 4 was medical director at Monsanto he probably had less than 4 Q Spill or leak procedures, do you know what is 5 five calls from physicians. 5 meant by an improved chemical landfill? 6 MR. CARNEY: 1 don't know what he said -- 1 6 A Sure. It's a landfill that's approved by 7 think he had a total of five calls with regard to problems 7 government authorities. 8 with PCB's. 1 don't think they were all from doctors, as 8 Q Did Monsanto dispose of its PCB's in an 9 1 recall. 9 approved chemical landfill in 1972? 10 A No, one was a call that 1 initiated myself to 10 A 1 think they burned it in the incinerator we 11 the Indiana one. 11 had over at the East St. Louis plant. 12 Q (By Mr. McCrea) To the whom? 12 Q Did they ever use landfills? 13 A The Indiana one, where the heat transfer 13 A 1 don't know whether they did or not. They 14 outfit. 14 may very well have, 1 don't know. 15 Q Indiana? 15 Q Do you know where your PCB's were disposed? 16 A It was Indiana, in Indiana, it was written up 16 A No, 1 don't. 17 by Dr. Spoyer, the Department of Industrial Hygiene or 17 Q Were there PCB's that were disposed from 1936 18 Public Health of Indiana. Another one was this, a 18 to 1974? 19 thermometer company someplace in New England where the 19 A Is that a question? 20 people had some of the women had chloracne from dipping 20 Q Yes. 21 their hands into the material, that was the first call 1 21 A What was the question? 22 had so 1 wanted to see it because 1 wanted to see what 22 Q Were there PCB's that were disposed by 23 they were doing and 1 said why don't you use some sort of 23 Monsanto from 1936 to 1976? 24 a gimmick that you don't have to put your hands in there 24 A Yes, 1 am sure there were. 25 and it went away. That was number two. 25 Q But you don't know when you started, you Page 98 Page 100 1 The third was from some company, 1 believe it was 1 don't know anything about that? 2 the Crown Chemical Company in the East someplace where the 2 A No, 1 don't know when landfills were first 3 man said again we had an exposure but - he didn't, again, 3 approved. 4 but he said, "We had an exposure of people inhaling hot 4 Q Under special protection information, 5 PCB's from a heat transfer unit. These people are - have 5 respiratory protection, Bureau of Mines approved 6 some nausea. They do have" - 1 don't know if he said 6 respirator for organic vapors, if 1 called you in 1972 and 7 they had vomiting or not. "What do you think?" 1 said 7 1 said, "Dr. Kelly, when should 1 as a worker wear a 8 "Well. Obviously, correct the situation, get them out of 8 Bureau of Mines approved respirator for organic vapors for 9 there and watch for liver involvement," and 1 followed it 9 Inerteen 100 dash 42? What would you tell me? 10 up in a week or so and he said, "Yes, they did show some 10 A I'd say you have to tell me what you're doing 11 slight jaundice." Followed up in couple months and they 11 and I'll tell you whether you need a respirator at that 12 were all well. 1 conditions - so 1 said less than five, 12 time. 13 1 don't recall any others. Those are the three. 1 never 13 Q If 1 told you 1 was working an F-30 near the 14 got a call from anybody in Bloomington, Indiana. 14 capacitor impregnation tanks? 15 Q Reactivity data, hazardous decomposition 15 A I'd say 1 do not know what the levels would 16 products, it lists CO, can't read it. 16 be at that capacitor impregnator plant. 1 believe you 17 A Yes, carbon monoxide, carbon dioxide, smoke, 17 will have to ask your plant safety man about that. 1 said 18 soot, chloride and chlorine. 18 we recommended against inhaling of fumes at elevated 19 Q And that was the information known in '72? 19 temperatures. 20 A That's correct. 20 Q And if 1 ask -- Go ahead, excuse me. 21 Q Would you now list furans? 21 A And 1 don't know if there was a TLV located 22 A 1 think we would, yes, if we were making it 22 at that particular time because remember now we're talking 23 still. 23 about capacitors, we're not talking about Inerteen. 24 Q Would you list anything else? 24 There's a transformer fluid, it's not used in capacitors. 25 A Well, in this Inerteen we would probably list 25 Q If 1 asked you for the best guidelines Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 97-100 LEXOLDMONOQ6913 Page 101 Page 103 1 available as to when 1 should wear a Bureau of Mines 1 Q Under Section 8, special protection 2 approved respirator based on this information in your 2 information, local exhaust for vapors. If a worker called 3 material safety data safety sheet what would you tell me? 3 you and asked you under what conditions a local exhaust 4 MR. CARNEY: Other than what he's already 4 should be used for vapors, what would you tell him in '72? 5 said? 5 A 1 would say, "1 can't give you a general 6 MR. McCREA: Correct. 6 statement on this. 1 don't know in the first place 7 A 1 don't know. 1 don't think 1 have anything 7 whether local exhaust could be available for your 8 to add to it. 8 particular application and other modalities must be used." 9 Q (By Mr. McCrea) What are the best 9 1 would also say 1 don't know -- Well, 1 would say, "1 10 guidelines, what can you tell me? 10 think you will have to ask the manufacturing people in 11 A Well, if the material is used at elevated 11 your group as to where this should be done." This says if 12 temperatures for more than a short time and 1 couldn't 12 this local exhaust needed; yes, it's needed if there are 13 quantify a short time because 1 don't know how long he's 13 vapors around there, but 1 can't define how much vapors is 14 working and I'd say he ought to put a respirator on. If 14 at somebody's plant. 15 you're in doubt put one on. 15 Q If 1 asked to you define that, could you? 16 Q Did you ever issue a warning to that effect? 16 A How much is too much? 17 A We told them to avoid inhalation of the fumes 17 Q Yes, sir. 18 at elevated temperatures and when they are in confined 18 A No, sir. 1 can't define how much is too 19 spaces and there are any number of ways that you can do 19 much. Too much is what will give you harm. 20 that. One is not go in there, No.2 is wear a respirator, 20 MR. CARNEY: 1 didn't get a chance to object 21 No. 3 is have changes of air and No. 4, would be a kind of 21 but I'm going to object to the form of the question, 22 vacuum, a collection of the fluid, of the material. 22 because it's vague. 23 Q Did you ever issue a warning that workers 23 Q (By Mr. McCrea) Special Precautions, Avoid 24 should wear a Bureau of Mines approved respirator when 24 Skin and Eye Contact. If 1 asked you in 1972 to tell me 25 working with Inerteen 100 dash 42 at elevated 25 why 1 should avoid skin and eye contact and what is meant Page 102 Page 104 1 temperatures? 1 by that, what would your answer have been? 2 MR. CARNEY: Objection. He just answered 2 A There is two questions now, lets' separate 3 that question, you're getting awfully repetitive. 3 them, will you? 4 MR. McCREA: 1 did not get an answer. 4 Q If 1 asked you why to tell me why 1 should 5 MR. CARNEY: 1 think he did answer. You 5 avoid skin contact? 6 didn't like his answer. He said he didn't did warn about 6 A Because the material may be harmful. If you 7 elevated temperature and there's a number of ways you can 7 get enough of it on you and it gets absorbed. 8 do that. He didn't spell out all the ways. 8 Q Did you ever issue a warning that PCB's go 9 MR. McCREA: 1 agree that was the answer. 9 through the skin and can poison the body? 10 I'm asking did he ever warn a worker that he should wear a 10 MR. CARNEY: Let me object to the form of the 11 Bureau of Mines approved respirator when working with 11 question. It contains undefined terms. A warning to who? 12 Inerteen 100 dash 42 at elevated temperatures? 12 MR. McCREA: To the workers. 13 A 1 don't remember ever talking to a worker. 13 A 1 said 1 gave the warning to avoid the skin 14 Q (By Mr. McCrea) Did you ever put it in 14 contact, on a gasoline truck; it says avoid smoking, it 15 writing? 15 doesn't say this is going to blow up if you smoke around 16 A 1 said avoid it. 1 left this to the users. 16 here. 1 mean, to answer your question, no, 1 did not, in 17 Q Did you ever put it in writing? 17 those words, but 1 said, avoid skin, repeated or 18 MR. CARNEY: Are you talking about-- 18 continuous skin contact, that's certainly -- 19 MR. McCREA: Just a second. Just a second 19 Q (By Mr. McCrea) That could mean everything 20 please. 20 from irritation to poisoning of the body with PCB's? 21 Q (By Mr. McCrea) Did you ever put in writing 21 A Was that a question? 22 a warning that a worker should use a Bureau of Mines 22 Q Yeah. Did you tell them why to avoid skin 23 approved respirator when working with Inerteen 100 dash 42 23 contact? 24 at elevated temperatures? 24 A No, but if you tell a person what to avoid, 25 A 1 don't know if 1 did or not. 25 you are avoiding any illness. You don't have to tell them Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 101 - 104 LEXOLDMONOQ6914 Page 105 Page 107 1 what illness is it he's avoiding. 1 Inerteen 54201 KJ is? 2 Q But if the worker thinks it's going to result 2 A 1 would not know what the other thing outside 3 in a little skin irritation it may not bother him. If he 3 of it does contain PCB's. 4 knows it's going to poison his body it could. 4 Q Can you go to page 9? Can you tell us what 5 A Well, 1 don't agree with that because we have 5 Aroclor 1242 is? 6 had these warnings for forty years and we've had no 6 A That's a PCB chlorinated to 32 percent. 7 trouble, no report of illnesses. 7 Q Anything else other than PCB? 8 Q We'll debate that as another day, Doctor? 8 A No, sir. 9 A 1 cannot hear that. 9 Q And can you go the health effects, excuse me, 10 Q We'll debate that at another day. 10 can you go to Section 5, Health Hazard Data. Is that 11 A That's fine. 11 precisely and identically the same as the health hazard 12 Q Special precautions, eye contact, why should 12 data for Inerteen 100 dash 42? 13 you avoid eye contacts, why should you avoid PCB's in the 13 A Yes, sir. 14 eye? 14 Q And you prepared that information? 15 A The same reason you'd avoid putting 15 A Yes, sir. 16 turpentine in your eye, it's irritating to your eye. 16 Q And give it to Mr. Garrett? 17 Q Is that all? 17 A Uh-huh. 18 A That's all. 18 Q And he put it on the sheet? 19 Q Can it be absorbed through the eye into the 19 A Yes, sir, or he gave it to the person that 20 body? 20 made the final editing of it. 21 A A drop of it, sure, it would be, but that 21 Q Please turn to Page eleven, what an Aroclor 22 would be of no consequence. It's the local effect you're 22 1016, MCS if 1 am reading that correctly, 1016? 23 worried about. 23 A That is an Aroclor, a PCB chlorinated to 24 Q Avoid inhalation of vapors. What's the 24 fifteen percent, and 1 think MCS was a phrase used when it 25 reason for that? 25 was used for other than electrical uses. Page 106 Page 108 1 A Because you're getting absorption of the 1 Q It's chlorinated to sixteen percent? 2 material through your lungs. 2 A That's correct. 3 Q All right. Doctor, turn to page three. Can 3 Q And the same effects of overexposure appear 4 you identify for us what Capacitor 21 is under Section 1 ? 4 but the second line, Emergency and First Aid procedures is 5 A No, 1 can't. 5 blank; is that a fair statement? 6 Q Did you prepare this? 6 A Yes. 7 A Yes, sir. 7 Q As to what appears in Section 5, Health 8 MR. CARNEY: Are you talking about the entire 8 Hazard Data, page 12? 9 document? 9 A Yes, sir. 1016 as 1 recall was a more or 10 A No. The health hazard, the data. 10 less an experimental product that was never used widely at 11 Q (By Mr. McCrea) You prepared the data? 11 all, if at all, in the industry. 12 A Yes, 1 gave the data to J.T.G., who was Jack 12 Q But it was on the market on the date of 13 T. Garret, who was in our department and he put this in, 13 January 25, '72? 14 he was also the environmentalist in our department. 14 A No, 1 can't say it was on the market. They 15 Q Okay. 15 may have shipped out experimental quantities or they may 16 A At the time 1 prepared that 1 knew what 16 never have shipped any, 1 don't know. 17 Capacitor 21 was. 17 Q All right. Next page, thirteen. Can you 18 Q Can you go to Page 5? Can you tell us under 18 identify this exhibit, Dr. Kelly, which is titled Monsanto 19 Section 1 in the material safety data sheet what Inerteen 19 Product Specification, Monsanto Industrial Chemical 20 PPO is? 20 Company, date effective June 10, 1975 which would be after 21 A It's a transformer fluid that contains some 21 your departure from Monsanto? 22 PCB, 1 don't know which one and a certain amount of 1 22 A Yes, sir. 1 can identify it not anymore than 23 believe trichlorobenzene. I'm not a hundred percent 23 what you just said, its a product specification of 1016. 24 certain. 24 Q All right. Sir. Page fourteen, can you 25 Q Can you go the page 7? Can you tell us what 25 identify this Monsanto document which at the top has Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 105 - 108 LEXOLDMONOQ6915 Page 109 Page 111 1 Monsanto, Monsanto Company Corporate Medical Department, 1 when they would try to nest on these eggs there would 2 Toxicity Information, Toxicity Information on Aroclor with 2 obviously be no progeny, no chicks. It was also had 3 looks like a trademark sign, 1016, capacitor dielectric? 3 toxicological effects on lower marine organisms, shrimp 4 A Well, it's just what you said. 4 and species below the shrimp so that's what they meant by 5 Q Have you seen this document before? 5 adverse ecological, it's bad for the peregrine falcon, the 6 A No, 1 haven't. This 1 believe also occurred 6 bald eagle and the toxicological effects on the bald eagle 7 after 1 left. 7 and peregrine falcon. You had to read that in context 8 Q Under the sixth paragraph it says, "Aroclor 8 with environmental hazards what you're talking about. 9 1016 has a negligible vapor pressure at room temperature 9 They are not talking about people there. 10 around it is not expected to present a significant vapor 10 Q Was there a risk to people as a result of the 11 inhalation hazard under ambient conditions." Does that 11 environmental contamination by PCB's? 12 mean it doesn't evaporate? 12 A No, sir. There was none. 13 A That's right, ambient means the air in this 13 Q Is it your opinion today based on all of the 14 room. 14 knowledge which you have from Monsanto Company and you 15 Q It says, "However, precautions should be 15 sixteen years of experience since last working for them 16 observed to avoid inhalation of increased vapor 16 that there is no risks to humans from environmental 17 concentrations, which may occur if Aroclor 1016 is used at 17 contamination by PCB's? 18 elevated temperatures." Is that -- 18 A Yes, and you could add to that all the 19 A Is that a question. 19 government publications and all the government writers and 20 Q No. It states that, correct? 20 all the scientific community have stated there's no risk 21 A Yes. 21 to humans from the PCB's that are presently from the 22 Q Why is that stated? 22 environment. 23 A That reason if you heat it up, more comes off 23 Q Is it your opinion today that there is no 24 and you shouldn't breath the fumes. 24 risk to humans from the presence of furans in the 25 Q Under the last paragraph, environmental 25 environment? Page 110 Page 112 1 hazards, it states, "During the past several years 1 A Yes. 2 evidence has accumulated to indicate the polychlorinated 2 Q Is it your opinion today that there's no risk 3 biphenyls are widely dispersed throughout the environment 3 to humans from the presence of dioxins in the environment? 4 and that they can have adverse ecological and 4 A Well, it depends on what you mean by 5 toxicological effects. Do you agree with that statement? 5 environment. If you spill a bunch of material that 6 A Yes, but remember we have got to define what 6 contains dioxin in somebody's backyard that's one thing, 7 is a meant by toxicological effects. Toxicological 7 but if you take the general public throughout the United 8 effects on shrimp, toxicological effects on birds? 8 States there's no risk but there may be isolated cases 9 Q Does that -- Would you define that for us? 9 where there's spillage of dioxins that could put people at 10 What is meant in that paragraph when Monsanto states 10 risk. 11 toxicological effects? 11 Q If 1 called you today and asked you if you 12 MR. CARNEY: Let me object to the question. 12 know of any particular environmental situation which 13 1 think this document is dated 11/4/1975, at least that's 13 presents a risk to the health of humans from PCB's, furans 14 the date that appears at the bottom of the left-hand side 14 or dioxins what would your answer be? 15 and 1 think there is no foundation that Dr. Kelly wrote 15 MR. CARNEY: I'm going to object to the 16 this or even saw this document. He may be able to answer 16 question, it's compound, you have lumped three things 17 your question but if you're asking him to say what does 17 together that are totally -- that are dissimilar and so 1 18 some words mean where he didn't author them might be 18 object to the form. 19 asking for speculation. 19 MR. McCREA: 1 agree but 1 did it to save 20 A 1 have an answer. This is under 20 time. 21 environmental hazards? 21 MR. CARNEY: Well, 1 think that's a - 22 Q (By Mr. McCrea) Yes, sir. 22 Q (By Mr. McCrea) If 1 called you today, Dr. 23 A At that particular time in 1975 the 23 Kelly, and 1 asked you if you know of any particular 24 environmental hazards were to avian species which were 24 situation involving PCB and contamination of the 25 birds because they will lay eggs with thin egg shells and 25 environment which presents a risk to human health what Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 109 - 112 LEXOLDMONOQ6916 Page 113 Page 115 1 would your answer be? 1 But 1 haven't finished yet, have 1? 2 A My answer would be if you were asking me 1 do 2 Q No, 1 don't think so. 3 not know of any. If you're asking people in the 3 A No, 1 don't think so. So 1 would say you 4 government -- 4 have to qualify what you mean by risks. There are 5 Q I'm asking you -- 5 certainly a financial risk and there is a possibility of a 6 A Yes, but you're calling me and 1 have got to 6 medical risk. 7 give you my answer. I'm not going to answer yes or no to 7 Q And how long have you known that there's a 8 the people calling me. I'm going to explain what the 8 possibility of a medical risk to an individual as a result 9 situation is; and I'm going for explain that dioxin is not 9 of a transformer burning and contaminating a building? 10 only a toxicological problem, it's a medical problem. 1 10 A '81 or'82. 11 would also say that the government has paid three hundred 11 Q And how did that information come to you? 12 million dollars to buy out or clean out Times Beach 12 A It's in the newspapers, eventually it was 13 because of the problem there although there have been no 13 written up in some scientific articles. 14 cases of any illnesses to individuals at Times Beach, so 1 14 Q If a worker from the Bloomington Westinghouse 15 would have to explain to them that here is my opinion, 15 plant called you and informed you that for fifteen years 16 here is what your elected representative's opinion is. 16 he worked in the plant and the carousel which was used to 17 Q All right, sir, fair enough. 17 test capacitors after they had been manufactured would 18 MR. CARNEY: When we were talking about 18 have explosions on an almost daily basis, sometimes 19 dioxin, they are not PCB's. 19 several times day, sometimes maybe none for a few days and 20 A Yes, dioxin. 20 that when these explosions would occur in the Bloomington 21 Q (By Mr. McCrea) We started with PCB's. If 1 21 Westinghouse plant fumes would permeated the plant and 22 called you -- 22 that he was exposed to these fumes for a period of fifteen 23 A Yes, but wait, PCB's and dioxin are a hundred 23 years, and he wanted to know if he should be medically 24 percent different and there is no dioxin in PCB. 24 monitored for adverse - for possible health problems, 25 Q (By Mr. McCrea) Yes, 1 understand. Dr. 25 what would you tell him? Page 114 Page 116 1 Kelly, if 1 called you today and 1 asked you if you know 1 MR. CARNEY: I'm going to object again. 1 2 of any use of an electrical equipment that presents a risk 2 don't think you've given enough facts in your question. 3 of contamination of the environment that could cause 3 Dr. Kelly is not familiar with the Bloomington plant. You 4 problems to human health and I'm talking about electrical 4 don't indicate on what the exhaust facilities were, what 5 equipment containing PCB's or PCB's and trichlorobenzenes, 5 the area was, whether the explosions were caused any fumes 6 whatever, what would your answer be? 6 and burning of PCB's, to what extent, and a whole myriad 7 MR. CARNEY: I'm going to object to the form 7 of things. So I'm not sure it's possible to answer 8 of the question, it's vague. 8 without all the facts. 9 A Is there any use? Do you use use or 9 You can try to answer it again? 10 misuse -- 10 A Well, 1 would tell him in the first place, 11 Q (By Mr. McCrea) Use. 11 yes, 1 think you ought to be examined. 1 would say no 12 A Use? 12 amount of exposure can give you a disease you don't have, 13 Q Not misuse, use. 13 and so if he doesn't have anything the exposure was not 14 A 1 would say that the only risk would be in a 14 sufficient to cause it obviously because it wasn't there. 15 transformer that could be effected by a fire and there 15 1 would say also 1 am not in a position to evaluate the 16 were no precautions to prevent the spread of that material 16 extent of your exposure. This is something that you 17 throughout the buildings. There is a risk there, there's 17 should talk to your manufacturing people about, 1 don't 18 a risk that would involve expensive cleanups. 1 would say 18 know these conditions and 1 can't give you an expert 19 that the risk to human health in those particular building 19 advice on it. 20 occupants and in the fire department personnel has been 20 Q (By Mr. McCrea) If he asked you to recommend 21 minimal, did not show any harm to those workers in the 21 doctor who has expertise in the toxicological effects of 22 building or in the people that take care of the fire. 22 PCB's, who would you recommend? 23 Q Are you talking about specific instances like 23 A What year is he calling me. 24 Binghamton? 24 Q He's calling you today. 25 A Yes, Binghamton, yes or One Market Plaza. 25 A Today, and he's in Bloomington? Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 113 - 116 LEXOLDMONOQ6917 Page 117 Page 119 1 Q Correct. 1 reference to liver enzymes. 2 A I'd have too look it up. I'd have to look it 2 MR. CARNEY: Let me have just -- We've got 3 up in the journal -- 1 mean in the Directories of the 3 one minute left on the tape and before we cut out on this 4 Industrial Medical, Occupational Medical Association, see 4 tape 1 think we have to - we have agreed to continue this 5 who's in Indiana. I'd have to look up people who were 5 deposition on Friday, the day after tomorrow at 8:30 and 6 certified in occupational medicine and see who's certified 6 you agree that you will finish in one more day? 7 around Bloomington. 7 MR. McCREA: You're going to bring the lists 8 Q He also informed you that he has made inquiry 8 of all the cases until which he's testified which we have 9 of the Old Monroe Medical Society which includes all of 9 requested, correct? 10 the physicians that were in Bloomington and there's not 10 MR. CARNEY: 1 don't -- as 1 have indicated 11 one physician with expertise in the toxicological 11 to you 1 don't think there is any such list. 12 properties and possible adverse effects of PCB's and he 12 MR. McCREA: Have you made inquiry? 13 wants your advice as to a doctor? 13 MR. CARNEY: 1 have not made inquiry, but all 14 A Well, 1 would say then go to the best 14 I'm saying is you have never requested it in the three 15 internist in Bloomington and find out if something is 15 years - Are we going to go on Friday or not and are you 16 wrong with you. If he had to just call me. 16 going to complete on Friday? 17 Q If he asked you to recommended a medical 17 MR. McCREA: 1 don't, Tom - 18 protocol, in other words, the tests and clinical 18 MR. CARNEY: You represented to me the last, 19 evaluation that should be performed, what would you 19 two days ago or last week that you would need one more 20 recommend? 20 day. We have now gone a day and a half. Are you saying 21 A 1 would recommend - 21 now in two and a half days we can finish or not? 22 MR. CARNEY: I'm going to object. We're 22 MR. McCREA: It might take more than one 23 talking about something so unrealistic, a Bloomington 23 day. Are you, can you do Kowan's in less than four? 24 worker or any non-medical person can go for a medical 24 MR. CARNEY: That would be my estimate, yes. 25 protocol would be highly unlikely. We're getting off into 25 But 1 - Page 118 Page 120 1 never-neverland here. 1 MR. McCREA: It might take more than one day 2 A 1 would tell him to have the doctor you 2 and 1 would like for you to bring with you the list of 3 select call me after you see me and I'll be happy to 3 cases in which Dr. Kelly has testified. 1 also would like 4 discuss the case with you, and tell me if 1 have any 4 for Dr. Kelly to bring the raw data which he reviewed 5 further suggestions on tests he wants to run 1 will tell 5 relative to - 6 him. 6 THE WITNESS: 1 didn't review it. 1 said 1 7 Q (By Mr. McCrea) He wants to know what tests 7 called Bill Gaffey and asked him. 8 should be run? 8 MR. McCREA: Okay, that takes care of that. 9 A Well, I'm not going to tell him. I'm not 9 Break. 10 treating him. I'm not going to tell him to go to a doctor 10 (Whereupon, a short break was taken.) 11 and say, "Look, this doctor three hundred miles away said 11 MR. McCREA: But I'll represent that we'll 12 this is what you should do to me." The doctor would say 12 finish on Saturday. 13 go to that fellow then. 13 MR. CARNEY: And you will finish on Saturday? 14 Q If he asked you for treatment what would you 14 THE WITNESS: Well, I'm not representing that 15 do? 15 lam going to be hanging around all next week. 16 A I'd say no, 1 don't treat you. 1 diagnosis 16 MR. McCREA: But we'll go on Friday? 17 people, but 1 don't treat. 17 MR. CARNEY: Go on Friday and if necessary go 18 Q If he came to you and gave you the history 18 on Saturday. 19 which we have recited, what medical protocol would you, 19 MR. McCREA: Absolutely. 20 Dr. Kelly, institute for this individual? 20 (Deposition continued.) 21 A 1 would do a complete history and physical 21 22 examination, non-occupational as well as occupational 22 23 examination. 1 would do a complete examination including 23 24 neurological and dermatological examination. 1 would run 24 25 a battery of clinical tests, the S.M.A. 21 with special 25 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 117-120 LEXOLDMONOQ6918 Page 121 1 COURT MEMO 2 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS 3 STATE OF MISSOURI 4 5 Glenn Brown, et al, vs. Monsanto Company 6 862-00694 7 8 CERTIFICATE OF OFFICER AND 9 STATEMENT OF DEPOSITION CHARGES 10 11 DEPOSITION OF R. EMMET KELLY, M.D. 12 TAKEN ON BEHALF OF THE DEFENDANT 13 6/13/1990 14 Name and address of person or firm having custody of 15 the original transcript: 16 Mr. Thomas M. Carney 17 Husch & Eppenberger 18 190 Carondelet Plaza, Suite 600 19 St. Louis, MO 63105 20 21 22 23 24 25 Page 122 1 ORIGINAL TRANSCRIPT TAXED IN FAVOR OF: 2 Mr. Thomas M. Carney 3 Husch & Eppenberger 4 190 Carondelet Plaza, Suite 600 5 St. Louis, MO 63105 6 Total: 7 8 Upon delivery of transcripts, the above 9 charges had not been paid. It is anticipated 10 that all charges will be paid in the normal course 11 of business. 12 GORE PERRY GATEWAY & LIPA REPORTING COMPANY 13 515 Olive Street, Suite 700 14 St. Louis, Missouri 63101 15 IN WITNESS WHEREOF, I have hereunto set 16 my hand and seal on thisday of 17 Commission expires 18 19 Notary Public 20 21 22 23 24 25 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 Pages 121-122 LEXOLDMONOQ6919 [& - 81] Transcript Word Index & 19 20 & 2:24,27 121:17 122:3,12 1 1 27:11 65:21 66:10 68:22 106:4,19 1.53. 59:6 1/26/72 67:10 27:6 63:15 190 121:18 122:4 1907 2:15 1936 13:17 99:17,23 1945 12:25 14:13,17 15:25 16:9 39:20 1954 68:18 21 106:4,17 118:25 22.88 57:15 25 108:13 26 73:11 80:16 96:18 261 65:21 66:11 9:8,19 12:11 17:20 26:20 79:2 80:4,9 87:5,16 91:6 106:18 107:10 108:7 515 1:25 122:13 54201 107:1___________________ 6 10 9:13 27 27:3 66:1,7 80:9 108:20 1958 100 23:6,12 2:24 59:24 67:7,24 70:3,25 196 34:22,25 35:10 36:16 3 6/13/1990 121:13 600 71:2,16,18 72:2 78:10 62:18 121:18 122:4 80:14 82:2 89:21 90:13,19 1965 26:18 31:12 77:1 101:21 621-2571 96:19 100:9 101:25 102:12 12:25 13:8 14:13,17 15:12 102:23 107:12 15:25 39:20 1016 1972 107:22,22 108:9,23 109:3,9 15;14 27:6 67:21 73:12 3.98. 43:23 30 100:13 1:27 63101 1:26 2:24 122:14 63105 109:17 11.17 61:9 11/4/1975 110:13 119 2:27 12 108:8 1242 17:21,23 107:5 1248 71:6 1252 71:6 1254 17:19 13 1:152:12 31 74:11,24 75:16 80:16 82:1 92:1,20 93:17 96:18,21 99:9 100:6 103:24 1974 16:24 17:8 19:20 20:17 39:19,20 59:16 314 1:27 69:10 32 107:6 21:1 64:3 99:18 35 1975 19:11 108:20 110:23 1976 95:12 99:23 1977 13:2 36 14:14 37 13:17 14:18 16:12 30:22,24 23 63:15 1979 38:17 1980 7:22 38:18 91:2 1981 7:10 8:5 8:13 26:18 59:10 77:14 101:21 4.46 60:13 121:19 122:5 65 13:3 14:14 15:9,16 694-1000 69:10____________ 7 80:5 106:25 7.12. 57:20,21 70 72:20 73:1 700 122:13 72 18:18 93:20 98:19 103:4 108:13 74 10:18 18:19 19:5 131 59:13,15,23,24 148 7:22 1506 1:25 1982 8:12 1985 34:22,25 35:10 36:16 1986 8:3 42 77 67:7,24 70:3,25 71:2,7,8,16 14:14,14 30:23,24 71:19 72:2 78:10 80:14 78 82:3 89:21 90:13,19 96:19 30:23,25_______________ 100:9 101:25 102:12,23 107:12 8 16 1988 45 8 61:9 8:23 13:3 14:14,14 15:9,16 103:1 17 1990 46 8:30 7:23 1:152:1391:3 1:19 119:5 1751 4676 800 12:4 35:3 35:1 180 77:15,20 67:7 71:25 2.38 47402 2:28 81 115:10 61:16 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMON006920 [82 - aroclor] 82 115:10 86 7:25 862-00694 1:6 2:6 121:6 9 Q 1074 QC 1017 QC 1017 a abdominal 86:7,10,16 87:3 88:7,25 90:12 92:6 abient 75:18 able 21:12 40:14 47:23 49:4 82:5 83:8,10,19 110:16 abnormal 51:25 abnormalities 27:23 29:14,16 30:7,11,14 abnormality 27:13 29:21,23 absolutely 120:19 absorbed 104:7 105:19 absorption 79:21 106:1 abstract 7:19 14:11 abuse 58:18,25 acceptable 53:13 accepted 30:1543:1781:16 access 48:17,17 accident 61:15,21 accidental 24:11 accidents 86:24 accumulated 110:2 accuracy 53:2,5 accurate ahead answer (cont.) 12:19 13:4 88:4 65:16 100:20 84:20 85:7,10 86:3 91:21 acne ahold 92:7 93:17,20,23 95:22 24:17 37:12 96:22 102:4,5,6,9 104:1,16 active aid 110:16,20 112:14 113:1,2,7 33:19 37:25 86:17 91:5,23 108:4 113:7 114:6 116:7,9 acts air answered 29:11 16:9 17:2,3,4 72:15 75:18 95:25 102:2 acute 101:21 109:13 answering 24:16 30:6 86:20 al 81:5 add 1:4 2:4 121:5 anticipated 30:4 86:18 95:4 101:8 alcohol 122:9 111:18 29:24 58:18,25 94:16,18,19 anybody added 95:5,21 96:10,13 15:15 36:3 43:2 64:7,15 62:3,19 alcoholism 74:7 98:14 addition 58:14 anymore 20:18 alexander 108:22 address 33:18,25 38:11 anyway 12:4,5,10 121:14 allegedly 96:11 adjacent 44:21 apparel 87:14 allow 91:13 administer 20:24 apparently 96:16 allowable 34:13 admit 17:22 20:19 75:4,9 appear 36:14 alteration 45:20 89:8 108:3 advantage 29:17 appeared 34:16 alterations 10:16 adverse 8:19 appears 8:2,18 30:6,16 31:10 110:4 ambient 108:7 110:14 111:5 115:24 117:12 109:11,13 appetite advice american 75:21 76:3 78:14 85:5,16,18 116:19 7:22 8:3 application 117:13 amount 103:8 advise 25:18 59:7 71:4,9 72:14 applies 96:16 106:22 116:12 73:2,3 afraid amounted apply 49:3 82:12 20:12 72:22 afternoon amounts appreciate 2:14 48:4 63:4 81:1591:8 49:5,9 age amplify appreciated 3:12 52:21 1:21 30:5 46:2 46:10 agency analyses appropriate 4:24 5:7 14:23 20:4,5 26:13 agent analysis approved 21:17 16:9,10,11,20,23 11:2 99:6,9 100:3,5,8 101:2 ago analyze 101:24 102:11,23 19:2347:1 89:6 119:19 17:5 archives agree animal 8:6 5:4 37:11 56:25 57:1,11 9:3 area 63:3,7 65:23 102:9 105:5 answer 37:15 56:10 57:24 58:1,2,6 110:5 112:19 119:6 5:15 19:1423:9,1425:8 75:1783:1391:8 116:5 agreeable 30:5,20 41:9 42:3 46:12,22 areas 65:25 46:22,24 48:21,25 56:2 55:19 89:20 agreed 64:14 65:1 67:25 68:12 aroclor 3:1 119:4 69:11 70:2,23 73:13,23 107:5,21,23 109:2,8,17 77:18 81:22 83:8,10,19,20 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6921 [aromatic - briefly] aromatic attorneys based (cont.) 71:11,11,1277:10,11 44:7,16 111:13 arteries august bases 40:5 8:23 87:8 arteriosclerotic auspices basis 39:23 40:4 54:5 56:18 38:13 16:18 19:5 81:21 115:18 arthralgia author battery 25:25 26:14 31:14,25 32:4 25:5 56:14,22,25 57:11 118:25 32:19,19 38:2 110:18 beach article authorities 113:12,14 22:17 23:18,19,25 25:3 99:7 beg 26:24 28:2,5,6,7,8,10,11,12 authors 54:25 28:15,24 56:4 57:10 88:20 13:16 14:3 21:2 25:10 beginning 95:11,24 52:12 13:15 articles auto begins 24:7 26:16,25 27:5 31:22 61:21 27:19 115:13 available behalf asked 10:15 12:15 13:7,24 16:2,7 1:142:12 121:12 6:15 16:1323:7,12 34:14 16:12 18:13 28:3 37:24 belief 37:1044:7,18,19,21,23 47:17 70:20,21 79:4,5 43:22 46:14,21 48:3,5 55:4 67:21 101:1 103:7 believe 68:15 73:12,21 75:1 80:23 average 18:5 19:21 22:22 23:11 81:20 82:2,12 92:18,24 52:3 59:7 26:17 53:12 56:23 64:4 93:6 94:13 100:25 103:3,15 avian 71:6 76:24 77:18 80:22 103:24 104:4 112:11,23 110:24 85:8 93:18 98:1 100:16 114:1 116:20 117:17 avoid 106:23 109:6 118:14 120:7 80:21 101:17 102:16 benefit asking 103:23,25 104:5,13,14,17 62:24 63:6 28:3 34:17 38:4,23 45:9,12 104:22,24 105:13,13,15,24 benzene 46:19,23 47:15,20 48:2,9 109:16 71:13 56:3 57:5 59:3 85:5,11,14 avoiding benzofuran 87:15 102:10 110:17,19 104:25 105:1 23:23 113:2,3,5 awful best associated 43:10,13 5:2 42:12 64:16 100:25 8:17 29:6,9 43:16 54:8 awfully 101:9 117:14 65:18 102:3 better association 43:19 117:4 b 48:17 74:9 86:10 big assume 28:3 47:10 62:21 assuming 32:6 72:19 76:13 assumptions 54:6 asterisk 59:1961:1 ate 25:22 29:20 atlanta 35:18 12:24 18:11,16,16,1726:16 40:25 59:8 31:12 46:17 48:7,8 61:21 75:8,9 80:1 52:5,6,7 bill 49:20 120:7 backup billion 474 7:23 backyard 1126 bad 1115 binghamton 114:24,25 biochemical 8:18 51:1695:13 baker 7:20 biopsies 22:23 biphenyls atom 71:14 attached 50:23 attention 21:5 22:3 41:6 111:6,6 barring 23:22 28:16 110:3 birds 8520 110:8,25 based 21:13 46:22 54:1 56:9 63:7 bit 20:11 48:2 57:3 76:6 83:8 90:6 101:2 bits 56:13 blackheads 22:2,7,8,15,20 23:9 bladder 62:17 blair 33:18,25 38:11 blank 108:5 blood 31:440:3,16,17,1843:19 bloomington 2:28 6:23,25 7:1,1,2,6,10 7:11 23:6 33:6,17,20 38:1 51:16 67:22 68:2 80:17 92:2 95:12,14 98:14 115:14 115:20 116:3,25 117:7,10 117:15,23 blow 104:15 board 45:1551:1595:13 body 31:7 89:20 104:9,20 105:4 105:20 boilerplate 65:5 boiling 77:22 bore 41:19 bother 74:7 96:9 105:3 bottom 12:14 66:11 67:8 89:8 110:14 boulevard 35:1 box 80:9 81:6 brain 40:23 84:12 brand 23:21 break 39:11,12 48:25 66:22 79:24 79:25 80:2 120:9,10 breath 109:24 breathed 30:10 breathing 3:23 81:14,15 briefly 77:2 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6922 [bring - circulatory] bring caller carries certify 1:20 43:24 45:24 46:1 74:18,25 75:1,3 40:11 49:12 47:1749:13 119:7 120:2,4 calling case chance bringing 13:11 74:11 113:6,8 116:23 28:4 35:22 40:16,16 46:13 41:17,22 55:24 57:9 59:24 48:7 96:10 116:24 62:16 68:23 69:1 93:13 60:9 66:14,22 103:20 british calls 118:4 changed 8:12 85:14 91:25 92:1 96:24 cases 6:21 12:1 broadway 97:5,7 18:1621:1841:25 42:18 changes 2:24 cancer 49:22 112:8 113:14 119:8 8:21 29:19 101:21 broken 8:4,7,25 53:18,20 60:16 120:3 charges 47:12 cancers catches 121:9 122:9,10 brought 8:9 61:7,7 77:23 Charles 38:15 capacitor categories 52:25 58:2,3 brown 7:7 8:13 33:6 100:14,16 47:12 chatted 1:4 2:4 7:9 8:5 35:2 121:5 106:4,17 109:3 category 6:14 building capacitors 56:19 check 114:19,22 115:9 100:23,24 115:17 causal 29:22 36:11 60:20 61:6 buildings capsule 76:8 92:19,24 93:9,21 114:17 90:17 cause checked bulletin car 1:6 2:6 15:2 31:24 32:3,7 4:19,19 19:7 44:4,4 7:25 61:14,15 39:20 45:6 49:17 56:18 chemical bunch carbohydrate 61:13,20 83:21,23,24 85:25 5:6 52:24 53:8 67:17 71:10 55:9 69:2 78:13 112:5 92:13 93:16 114:3 116:14 71:12 98:2 99:5,9 108:19 bureau carbon caused chemicals 7:20 100:5,8 101:1,24 98:17,17 8:25 23:20 42:20,24 43:4,8 19:4,7,15 69:8 83:17 102:11,22 cards 43:14,18 44:24 83:25 116:5 chicks burn 7:13 causes 111:2 82:25,25 83:3,4 care 31:6 42:19 59:12 84:12,22 china burned 93:3 114:22 120:8 90:15 93:21 24:3 99:10 carney caution Chinese burning 2:23 10:5,10 13:10 14:6,19 14:9 24:2 78:5,11,14 115:9 116:6 20:14 23:15 24:4 26:3 28:1 cells chloracne business 28:13,19,21 32:5,13 33:12 94:19 9:3,4 21:16,18,19,25 22:6,7 122:11 33:21 34:1,12 35:19 36:8 center 22:9,14,16,18,20,21 23:8,8 buy 37:15,18,21 38:3,9,14,16 7:20 8:11 35:17 23:13 24:20,25 25:1,7,9,11 113:12 38:19,22 39:4 44:8,22 45:1 centers 27:12,22 29:7,10,14,21 byproduct 45:6,9 46:5,11 47:3,8,18,24 37:19 38:12 30:8,12,14,19 31:6 75:14 5:136:8 48:1,14 50:9,12 52:8 53:4 cerebrovascular 75:22 76:6,17,24 86:15 c.o.c. 77:20 calculated 52:2 c 54:16,20 55:22 57:4 58:4 42:12 56:20 62:6,13,21 63:2,10 64:9 certain 65:10,14,16,25 66:18 70:14 5:25 6:2 17:2,3,4 27:8 36:1 73:25 76:11 81:23 82:15 36:5 41:22 52:20,21,21 83:15 85:11 87:12,24 88:3 71:4 106:22,24 89:22 91:19 92:25 95:9 certainly 92:4,10,12 97:20 chloride 78:19,24 98:18 chlorinated 23:24 26:22 71:10,11,13 107:6,23 108:1 6:15,21 13:13 14:7 41:21 47:1649:1,10 50:16,18,19 68:1469:17 81:4 85:4 97:1,6 101:4 102:2,5,18 103:20 104:10 106:8 110:12 112:15,21 113:18 5:14 10:1731:20 35:12 chlorine 54:11 57:1 70:6,9 74:14,16 71:14,14 78:24 98:18 85:3 89:13 104:18 115:5 cholesterol 91:22 92:14,17,17 94:7 97:10,21 98:14 117:16 118:3 called 6:13 17:1 18:7 23:6 49:20 114:7 116:1 117:22 119:2 certificate 119:10,13,18,24 120:13,17 121:8 121:16 122:2 certificates carondelet 10:2 12:24 14:18 48:16 121:18 122:4 50:5 31:10 Cincinnati 35:3 circuit 1:1 2:1 121:2 67:21 73:11,20 75:16 80:16 carousel certification circulatory 82:1 83:11 85:1 95:19 100:6 103:2 112:11,22 113:22 114:1 115:15 120:7 115:16 carried 30:23 33:25 52:18,19 1:18 certified 2:16 3:4 117:6,6 39:22 40:3 42:5,25 43:7,23 56:17 59:20 61:8 62:10 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6923 [citation - convincing] citation 36:13 cited 21:6 citizens 7:6 city 1:1 2:1 7:3 55:16 95:12 121:2 claiming 33:22 35:25 44:23,25 clair 52:25 53:7,19 58:4,5,6 clarify 56:12 clean 70:21 113:12 cleaning 70:10 cleanups 114:18 clinical 8:18 117:18 118:25 close 8:16 closely 92:13 clothes 78:1381:17 clothing 81:1891:7,9,13 coc 77:15 cohort 39:18 64:22 collection 101:22 colorless 77:8,9 Columbia 35:3 column 72:10 combination 79:16,17 combined 6:3 combustion 78:8 coming 78:12 84:7 comma 9:4 36:22 comment 53:22 comments conclude 95:24 48:11 commercial concludes 23:21 56:19 commission conclusion 122:17 57:2 common conclusive 24:13,1681:11 8:24 communicable condition 8:11 29:3 40:13,19,22 41:13,14 communicated 92:15 94:8,10 74:24 conditions communitronics 3:19 5:18,25 6:2 44:17 2:15 81:11 82:6,7 83:16 84:23 community 84:24 98:12 103:3 109:11 42:24 43:17 55:10 111:20 116:18 company conduct 1:7 2:7 4:12 11:20 13:18 5:12 19:13 28:17 46:16,23 49:21 conducted 52:25 67:6 68:2 80:13 5:15 9:25 19:20 21:4 32:2 86:13 88:10 97:19 98:1,2 51:1695:13 108:20 109:1 111:14 121:5 confined 122:12 3:24 101:18 company's confounder 67:19 41:7 compared confounders 59:7,17 41:3,4 58:11 59:4 60:19 comparison confounding 55:8 55:25 competent confused 64:5,8,13 12:21 36:14 complained connected 33:7,20 38:1 42:11 complaining connotation 75:20,20 76:3 18:5 complaint consequence 32:10 31:7 105:22 complete consequences 118:21,23 119:16 93:7 compound consider 91:20 112:16 3:19 84:10 con considerable 4:23 73:18 concentration considerably 17:22 75:4,9 12:18 14:2 concentrations considered 20:20,21 109:17 20:13 54:8 concern consist 78:10 23:8 concerned consistency 75:22,23 96:12 27:24 concerning consistent 68:6 16:3 concerns consists 78:6 71:4 constipation 84:13 construct 5:6 contact 3:23 103:24,25 104:5,14,18 104:23 105:12 contacted 91:8 contacts 105:13 contain 55:25 107:3 containing 114:5 contains 104:11 106:21 112:6 contaminant 5:7 contaminated 6:7,11 23:21,23 24:12 29:20 32:15,18 55:19 81:18 91:7,9,13 contaminating 115:9 contamination 20:19 111:11,17 112:24 114:3 context 26:10 111:7 continue 48:3,5 119:4 continued 3:3 120:20 continuous 3:23 104:18 continuously 81:17 contracted 4:7 contribute 45:4 contributed 43:8 contributes 56:10 control 7:21 8:12 35:18 37:20 38:12 41:13 52:23 53:1,6,9 53:18,21 54:13 73:15 controls 53:15,17 convention 49:3 convincing 9:5 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6924 [copies - died] copies cut deaths deposition (cont.) 4:22 15:15 119:3______________ 15:2,2 30:24 39:22 40:2 120:20 121:9,11 copy d 41:5 42:20,24 43:6 52:3,13 depositions 28:23 38:19,24 77:12 daily 56:17,19 57:13,19 59:16 44:9,10,16 55:5 corner 68:19 115:18 dash debate 105:8,10 deranged 92:10 cornfeld 67:7,7,24 68:18 70:3,25 decernber dermatitis 2:24 71:2,16,19 72:2 78:10 39:20 27:12,22,25 29:2,3,6,9 corporate 80:14 82:2 89:21 90:13,19 decide dermatological 109:1 correct 96:19 100:9 101:25 102:12 102:23 107:12 29:18 decided 118:24 dermatologist 10:4 15:3,13,17,19,22 44:7 data 17:19 92:11 45:21 50:23,24 58:2 59:13 4:15 9:3 12:15 13:5,23 14:4 decomposition describe 59:14,18 61:9 62:1,2,3 16:2 17:11,16,25 18:9 98:15 3:18 16:22 21:3 83:16,17 69:13 73:3 75:6 78:25 81:6 81:8 87:21 96:4 98:8,20 101:6 108:2 109:20 117:1 119:9 corrected 58:12,13,14 correctly 37:25 44:5 45:18,20,22 46:8,9,15,15,18,22,24,25 47:4,5,7,11,1749:13,14,16 67:4,11,16,23 68:16,24 defected 83:17 82:9 description defendant 83:9 1:8,14 2:8,12,26 3:3 121:12 designed 69:4,4,6 77:2,4,14 78:9 defendant's 68:25 86:24 79:3 80:4,10 81:24 86:23 87:5 88:9 89:13 91:6 96:18 66:1 define despite 9:2 62:3 107:22 98:15 101:3 106:10,11,12 79:21 80:18 82:2 91:9,12 destroy counsel 106:19 107:10,12 108:8 103:13,15,18 110:6,9 94:19 3:2,2 50:4,7 65:20,23 120:4 defined destruction counsels 6:16 date 16:5,21 35:9 38:5 64:20 74:2 79:4 definite 18:8 detail county 67:9 108:12,20 110:14 18:24 75:2 55:3 56:5 57:8 51:12,15 52:25 53:1,7,19 dated definition detect 53:19 95:13 34:22,25 64:19 110:13 4:1 80:13,23 81:2,3,8,10,20 64:24 couple 66:14 98:11 course 61:19 122:10 court 1:1 2:1 65:22 66:6 121:1,2 courtesy dates 14:21 david 2:26 11:18 35:2,4,6 day 2:14 20:6,13 47:22 48:9,11 72:16,18 73:8,13 82:10,10 82:4 degree 63:19 degrees 77:15,21,22 delivery 122:8 determination 26:21 27:1 determine 5:7,12,22 15:1,5 determined 22:20,22 develop 46:9,18 82:11,11 83:5 105:8,10 demonstrable 30:11,1346:9 cover 115:19 119:5,6,20,20,23 9:5 22:5 75:25 development 86:24 87:8 120:1 122:16 department 30:12 crea 3:15 days 18:11 20:7 29:25 48:2 11:21,24 12:2,2,5,19 14:2 devoted 16:11 17:15 18:1 19:10 10:2 cross 66:1488:23 115:19 119:19 28:17 49:1 67:5 69:22,24 diabetes 36:2 48:9 49:15 119:21 70:18 73:6 81:3 97:17 40:16,18 crown daytime 106:13,14 109:1 114:20 diagnosed 98:2 cubic 69:24 deal departments 19:11 86:11 92:15 diagnosis 17:4,5,20,20,24 43:15 departure 23:11 85:3,12 118:16 cuff dealt 16:23 18:18 108:21 diarrhea 21:10 39:17 depends 24:19 cure 63:1 dear 35:4 20:6 29:15 31:9 53:20 69:14 94:4 112:4 dibenzofurans 26:22 current death deposes die 21:1 10:2 12:24 14:18,18 48:15 3:13 52:22 custody 49:17 50:5 56:2,18 59:12 deposition died 121:14 61:13,20 62:16,17 63:3 1:13 2:11 3:3 9:8 48:4,5,11 15:14 42:9 50:2 57:17 50:13,1563:11 66:1 119:5 60:14 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6925 [dielectric - electric] dielectric diseases dope 109:3 39:22 40:3 42:6 43:22 88:14 diet 55:1759:5,1961:8,11,13 dose 92:13 62:23,24 25:18 40:20 41:2 difference dispersed double 18:21 20:11 90:9,10 110:3 60:18 different dispose doubt 14:21 20:23 55:12 113:24 99:8 6:12 45:25 53:2 101:15 differentiate disposed dr 29:25 99:15,17,22 3:16,18 4:9,18 6:22 9:10 difficult disproved 10:14 13:13,16 14:8 15:5 37:12 30:22 33:5,15,18,23,23,24,25 dig dispute 34:13 39:13 44:9,22 46:16 70:8 22:24,25 47:21 48:3,6,17 49:13,16 digest dissimilar 50:9,13 51:3 52:11 62:11 8:23 112:17 63:3,7,12,16 64:10 70:14 digestive dissolve 73:21 75:16 76:2,6 77:1 61:12 17:2 80:1 86:12 88:20 92:2,2 dioxide distributed 95:19 97:17 100:7 108:18 98:17 11:3 110:15 112:22 113:25 dioxin disturbances 116:3 118:20 120:3,4 6:8,11 99:1 112:6 113:9,19 24:18,20,22 draft 113:20,23,24 doctor 51:1,3 64:17,20 dioxins 4:1 17:15 21:2,20,25 22:4,4 drain 5:7,10,13,18,22,24 6:2 22:5,19,19 23:18 24:6,19 82:25 112:3,9,14 25:13 26:14,16 28:4,8 29:2 draw dipping 31:1234:1937:1045:12,12 21:5 97:20 45:13,18 46:12,21 47:15,19 dream direct 49:15 53:22 54:16,23 55:24 85:20 8:1 51:1995:18 56:8 57:5 59:10 63:17 65:8 drink director 65:19 66:3,6,13,20,25 94:19,25 95:21 80:12 97:4 67:11 78:3,9 82:12 83:1 drinks directories 85:12 87:4,16 91:18 92:1 29:24 117:3 94:7 95:19 96:16 105:8 drop disagree 106:3 116:21 117:13 118:2 105:21 22:11,12 118:10,11,12 drums discard doctors 69:3 18:10 91:17 96:25 97:8 due discarded document 41:22 88:25 18:6,12,14 51:1,3 67:1,3,9 106:9 duties discharge 108:25 109:5 110:13,16 63:25 24:17 documents dwellers discuss 34:15,15,17 35:25,25 36:2 55:16 19:24 20:2 21:12 118:4 36:5 38:25 48:9 65:24 66:7 dying discussed 66:13,19 42:5 8:22 32:12 95:11 dog discussing 32:20 20:1 doing disease 49:5 63:25 75:15 80:25 7:20 8:11,11 24:14,15 85:21 97:23 100:10 35:17 37:19 38:12 39:23 dollars 40:4,4 41:6 42:12,25 43:8 113:12 43:1654:5,9 56:11,17,18 domain 56:19,20,20 62:10,10 89:18 11:3,7 116:12 donahue 2:23 e eagle 111:6,6 earlier 57:10 60:22 95:23 easily 10:23 88:13 east 9:15 10:6,13 13:19 14:16 16:4,23 19:3 21:3 32:23 43:7 98:2 99:11 easy 11:1336:11 eating 29:23 ecological 110:4 111:5 edema 86:2,4,16 87:3 88:7,24 89:1 89:3,7,14,17,18,19,21 90:5 90:7,23 91:1,3 92:6 editing 107:20 editor 11:4 educated 91:16 education 54:1 effect 32:7 55:14 90:5 94:18 101:16 105:22 effected 114:15 effective 108:20 effects 8:1,2 9:5 25:12 30:6,17 31:11 37:17 73:19,24 74:10 74:16,19,23 76:1 79:18 80:11 86:12,19 87:4,20 88:1,11 91:17 107:9 108:3 110:5,7,8,8,11 111:3,6 116:21 117:12 egg 110:25 eggs 110:25 111:1 eight 2:1320:6 30:11,13 39:14 41:25 43:21 49:22 60:14 61:3,25 72:15 91:24 eighteen 89:6 eighty 14:11 15:20 39:18 50:1 52:13 either 7:6 10:11 18:14 19:21 79:21 86:6 elaborate 85:13 elected 113:16 electric 68:2 74:13 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6926 [electrical - factors] electrical eppenberger 74:11 107:25 114:2,4 2:23 121:17 122:3 elevated equipment 3:24 81:14 86:21 88:15,19 114:2,5 88:23 95:20 96:12 100:18 establish 101:11,18,25 102:7,12,24 22:8,17 109:18 established eleven 12:17 13:25 21:6 26:17 107:21 estimate emergencies 119:24 70:24 et emergency 1:4 2:4 121:5 68:21 86:17 91:5 108:4 evaluate emesis 64:22 116:15 24:1825:13 evaluating emmet 41:17 1:132:11 3:11 121:11 evaluation employed 117:19 11:15,16 14:16 evaporate employee 109:12 42:14 eventually employees 115:12 53:16 everybody enclosed 22:4 94:22 35:4 evidence england 8:25 32:6 65:18 110:2 21:22 97:19 evolved enlarged 78:24 88:25 ex entire 77:23 66:11 106:8 exactly environment 19:10 22:14 110:3 111:22,25 exaggerated 112:3,5,25 114:3 20:25 environmental examination 8:6,23 11:21,25 12:2,6 3:14 33:2 48:10,12 76:22 28:18 109:25 110:21,24 76:22 118:22,23,23,24 111:8,11,16 112:12 examinations environmentalist 85:13 106:14 examine enzyme 49:14,15 75:24 8:21 29:19 51:18,23 examined enzymes 2:12 3:12 76:17 85:18 29:17 119:1 116:11 epa examining 5:9,16 36:2 epidemiological example 6:23 7:5,12 8:15 9:11 23:19 56:1 33:1640:1241:1 52:19 exceed 53:21 54:1 62:18 64:1 65:5 20:7 61:23 74:15 epidemiologist exceeded 49:21 60:5 64:16 20:3 72:17 73:7,12,18 epidemiology 75:19,24 7:20,22 49:1 58:12 60:3 exceeding episode 76:14 24:2 30:6 exception explosions 75:13 69:17 115:18,20 116:5 excess exposed 39:21 40:23 41:8,11 42:18 3:22 7:2 10:1 14:11 15:3,6 42:19,20 43:21 56:17 15:9 22:5 30:9 33:7 42:6 excessive 51:17 73:22 88:22 94:21 53:17,20 73:22 74:1 95:14 115:22 exclusive exposure 39:22 40:3 56:17 3:21 4:2 7:21 8:8,17 9:3,4 excuse 12:16,17 13:24 14:1 15:24 62:11 100:20 107:9 16:3 20:18,25 30:19 31:2 exhaust 42:11 43:9 44:24 45:3 54:7 103:2,3,7,12 116:4 54:9 56:21 61:22 64:25 exhibit 74:20 76:4,8,25 78:2 79:21 9:8,19,20 45:20 65:23,24 79:22 80:12 82:2 83:8,23 66:1,3,7 80:5,7,9 108:18 83:25 84:5,7 88:18 91:7 exhibits 92:8,9,11 93:16 94:3 95:1,2 65:20,21 98:3,4 116:12,13,16 expect exposures 52:3 86:25 94:11 30:3 75:12 expected expunged 43:23 52:22 57:13,19 60:13 18:3,4 61:8,16 62:17,23 109:10 extend expensive 30:4 114:18 extended experience 46:10 76:7 111:15 extensive experienced 25:9 39:17 84:9 85:2,9 86:2,7 extent experiencing 69:2 116:6,16 85:22 external experimental 61:13,20 108:10,15 extra expert 28:22 77:17 116:18 extremely expertise 36:9 37:9 70:9 116:21 117:11 extremities expires 25:25 122:17 eye explain 103:24,25 105:12,13,14,16 18:21 22:1 31:23 40:10 105:16,19 51:20,24,25 52:16 72:12 eyelids 77:2,3,24 82:7 88:12,13 89:17 89:2 90:12,18,23,24 113:8 eyes 113:9,15 24:18 82:24 83:3 90:11 explained 56:16 59:23 80:10 explanation 40:8 58:8 explanatory 25:20 explode 77:18 explosion 69:4 70:5 77:14,16 78:21 f farilitipQ 1164 fact 510 1217 141 4910 54 3 62:19,22 factor 41 21 fartnrQ 43:13 55:25 59:24 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6927 [facts - genitourinary] facts final folks 32:6 83:16,18 84:22 116:2 35:7 36:22 37:7 51:2,5,8 50:20 116:8 52:10 64:23 107:20 follow fair financial 19:1892:13 27:21 52:4,14 108:5 113:17 115:5 followed falcon find 30:24 98:9,11 111:5,7 11:1336:11,12,16,1839:5 footnoted familiar 40:15,23,24 46:18 49:1 12:9 21:8 33:5,10 37:24 54:22 53:25 54:3 59:17 65:6 foreign 54:23 55:1,2 96:22 116:3 83:23 85:19,25 117:15 75:13 family finding foreman 71:10 22:24 23:3 68:7,9 69:23 far findings foremen 5:17 12:19 33:3 35:6 36:19 7:24 76:19,21 68:4 36:20,21 70:9 75:10 96:11 fine forenoon fat 4:20 40:11 105:11 2:13 30:21,25 31:1,4 finish forget favor 36:7 46:5 50:14 119:6,21 6:16 122:1 120:12,13 form fda finished 65:14 67:4 68:18 73:25 5:1 62:1463:14 115:1 82:15 86:14 89:22 91:19 february fire 92:4 95:9 103:21 104:10 34:22,25 35:10 36:16 69:4,16,25 70:5,12 77:14 112:18 114:7 feel 77:16,19,23,25 78:5,8,15 format 53:22 76:7 78:21 86:25 87:1,5,13,17 53:3,5 fellow 114:15,20,22 formosa 36:18 118:13 fires 24:2 felt 69:17 78:1,25 forms 63:23 firm 56:20 fever 2:23 121:14 forty 42:10,10 43:3,24 44:3,5,18 first 20:10 30:13 105:6 44:24 45:4,7 49:18,23 10:15 19:9 21:5 24:11,21 found fewer 27:17,18,20 37:11 39:16 5:10 8:6,8 10:23 22:19 8:8 51:2 65:1 66:19 67:1 80:10 33:18 40:2 51:19,22 75:17 field 85:11 86:17 91:5,23 93:13 95:18 30:16 95:23 97:21 100:2 103:6 foundation fifteen 108:4 116:10 64:10 110:15 18:15 20:25 46:17 107:24 five four 115:15,22 2:14 18:9 21:7,1841:22 21:1827:9,14,15 30:13 fifty 61:24 62:1 66:22,23 72:17 40:12 43:23 58:11 59:6 27:5 74:4 83:6,12 91:25 96:24 61:24 62:1 72:17 73:7,13 fighting 97:5,7 98:12 74:4 75:19 83:5 119:23 77:25 78:1 flash fourteen figure 77:15,17 108:24 20:8 41:24 62:17 72:13 flaw fourth figures 40:25 55:9 59:3,9 12:1341:7 4:1941:1861:5 80:21 flaws fraction file 53:25 54:3,11,12,15,18 9:16 47:13 55:20 frank filed fluid 22:14 17:25 5:21 6:3 100:24 101:22 frankly files 106:21 53:14 18:1045:19 flume freedom filled 82:23 35:17 67:6 focus frequency 50:14 17:7,10 friday 1:20 36:10 45:24 46:1 47:17 119:5,15,16 120:16 120:17 front 66:8 full 27:17 39:16 fully 1:21 46:2 fumes 3:23 78:12,16 100:18 101:17 109:24 115:21,22 116:5 function 27:12,22 29:13,16 92:10 functioning 90:22 furans 32:15,18 98:21 111:24 112:13 further 46:9 48:6 65:6 91:23 118:5 future 64:21 g gaagei 17:1 914 49 20 53 16 1207 95:15 garage 78:14 garret 106:13 107:16 gas 77-c 78 2 19 24 10414 gateway 12212 55:7,8 58:15,19,22 59:1 103:5 112:7 generally 41 20 genesis 73:5 genitourinary 6216 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6928 [georgia - i.e.] georgia gospel 35:18 43:20 getting gostasfawn 34:1781:17 102:3 106:1 8:2 117:25 gotten ggt 92:17 51:17 95:16,17,20 96:2,11 government gimmick 4:20,23,24 5:16,16 79:10 97:24 99:7 111:19,19 113:4,11 give government's 4:1 6:18 7:19 32:19 36:13 81:3 43:11 47:16 55:23 66:20 gravity 67:9 80:13 81:21 83:19 77:5 91:1 92:9,10,12 94:11,14 great 103:5,19 107:16 113:7 43:14 116:12,18 ground given 70:8,13 46:18 58:8 82:3 83:16 group 116:2 40:3,21 41:12,13 52:3,13 gives 53:6,9,21 54:14 59:7 69:21 67:12 96:10 70:19,20 79:10 103:11 giving 33:3 57:6 84:21,23 gtg 89:9 glenn guess 1:4 2:4 121:5 12:7 81:13 glutino guidance 95:15 38:12 go guideline 12:13 16:25 18:9 24:6 27:9 33:18 31:1246:1748:8 50:451:8 guidelines 59:1065:1668:11 83:22 100:25 101:10 94:24 100:20 101:20 104:8 h 106:18,25 107:4,9,10 117:14,24 118:10,13 119:15 120:16,17,17 god 55:11 70:9 goes ha 93:16 half 47:21 51:2,5 62:17 119:20 119:21 hallmark 12:24 43:14 25:11,12 30:16 going 9:18 13:10 14:1923:15 hand 9:1865:20 110:14 122:16 33:12,22 34:19 35:19 36:10 handling 38:3 39:5 44:8 46:6,11 47:18 48:4 55:22 64:9 72:25 73:16 74:7 75:3 76:11 83:15 103:21 104:15 105:2,4 112:15 113:7,8,9 67:12 70:19 hands 97:21,24 hanging 12015 114:7 116:1 117:22 118:9 118:10 119:7,15,16 120:15 happen 755 gong 65:14 good 3:16,17 16:9 45:3 78:16 gore 122:12 happens 57:11 hapov 39:1 40:9 118:3 hardening 40:5 harm hereunto 63:7 103:19 114:21 122:15 harmful high 104:6 40:3,15,17,1843:17,19 hazard 56:15 77:21 92:12 96:8,10 19:17 77:14 79:2 80:4,10 96:11,12 87:5 89:13 91:6 96:18 higher 106:10 107:10,11 108:8 31:4 51:22,23,23,24 55:17 109:11 55:18 56:1,10 58:9 60:23 hazardous 82:17,19 71:1572:1,1,9 98:15 highly hazards 46:20 78:19,23 117:25 64:25 71:24 78:21 110:1,21 highway 110:24 111:8 73:1 head hired 54:20 63:22,24 64:1,2,4,11 headache history 25:24 118:18,21 headaches hoh 83:12,18,21,24,25 84:1,4,7 89:9 84:9,12,19,23 hold heading 95:6 80:10 holdup health 61:21 8:1,2,5,6,18,21,22 9:5 hot 11:21,25 12:3,6 28:18 30:10 98:4 37:1744:1751:1663:1,21 hour 67:25 69:4 70:18 79:2 80:4 20:6 72:16 80:10 87:5 89:12 91:6 93:7 hours 95:13 96:18 97:18 106:10 2:1320:1030:11,13 107:9,10,11 108:7 112:13 huh 112:25 114:4,19 115:24 51:4,7 57:25 60:7 107:17 hear human 105:9 31:7 112:25 114:4,19 heard humans 4:22 22:16 34:3 39:9,10 9:1,5 111:16,21,24 112:3 64:12,15 112:13 heart hundred 39:23 41:5 43:16 54:5,9 44:20 61:24 62:1,20 77:22 56:18,19,20 89:18 106:23 113:11,23 118:11 heat hundreds 5:22 21:17 30:9 86:22 33:13 34:14 88:21 90:4 97:13 98:5 husch 109:23 2:23 121:17 122:3 heated hygiene 6:7 12:15 13:23 16:2,25 97:17 heating hygienist 5:13 6:3,10 79:10 heavy hyperpigmentation 76:4 24:17 heet 35:1 helpful 10:8 hepatitis 29:23 i.b.t. 4:7 i.e. 4:11 i Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6929 [idea - japanese] idea 53:18 68:20 identically 107:11 identification 9:9 66:2 identified 38:5 identify 7:15 9:19 67:3 106:4 108:18,22,25 ieee 7:25 illinois 13:19 35:6 52:24 illness 41:16 52:22 65:18 74:12 104:25 105:1 illnesses 42:9 105:7 113:14 imagination 42:11 immediately 87:14 impinger 17:1 implies 87:16 important 94:12 impose 48:6 impregnation 100:14 impregnator 100:16 impression 19:13 24:25 25:2 35:12 improper 46:20 48:10 improved 99:5 inappropriate 36:4 57:8 inasmuch 77:21 inch 56:6 incidence 55:17,18 56:10 incident 21:21 27:19 incinerator 99:10 included 9:16 15:18 90:5 includes inflammatory 51:1,2 117:9 29:3 including information 8:16 59:24 118:23 7:16 11:6 35:17 47:13,14 increase 55:25 63:13 67:12,19 68:5 8:4,7,7 54:4,5 59:16,16 68:6 81:6 88:2,17 91:23 61:12 62:9 98:19 100:4 101:2 103:2 increased 107:14 109:2,2 115:11 27:23 30:18 31:5 96:5 informed 109:16 80:17 115:15 117:8 independent ingested 4:14,18 25:19 indiana ingestion 2:28 33:6 51:12,17 52:6 23:20 24:11 31:24 92:3 95:12,14 97:11,13,15 ingredient 97:16,16,18 98:14 117:5 81:16 indicate ingredients 14:1546:13 110:2 116:4 71:15,23 72:1,1,10 90:3 indicated inhalation 28:4 47:22 119:10 79:21 101:17 105:24 indicates 109:11,16 13:12 74:19 inhale indicating 78:7,15 88:1 inhaled indication 86:21 88:21 58:24 85:6,19 inhaling indicted 88:15,18 98:4 100:18 4:5 initial indictment 64:23 4:11 initials indictments 89:9 4:16 initiated individual 97:10 27:4 93:2 95:20 96:17 inquiry 115:8 118:20 117:8 119:12,13 individuals inside 11:2 24:19 25:6 29:5 49:18 14:7,22 86:21 113:14 instances industrial 114:23 3:19 8:3,12 10:24 12:14 institute 13:23 16:1,25 30:2 33:2 118:20 55:9,10 56:10 97:17 108:19 instruct 117:4 46:12 47:18 industry instructed 74:11,13,20 108:11 48:20,24 inerteen intended 67:6,24 70:3,24 71:2,3,16 69:7 74:25 71:18 72:2 78:10,11 80:14 interested 82:2,9 89:21 90:3,13,19 4:21 47:14 94:9,9 96:19 98:25 100:9,23 internist 101:25 102:12,23 106:19 117:15 107:1,12 interpret infected 39:23,25 42:4 51:14 42:13 interpretation inflammation 65:8,11 54:10,10 interpreted 45:18 interrupting 62:7 interstate 72:20 85:4 intervals 8:10 interviews 12:16 13:25 intoxication 86:15 87:2 92:5 inused 31:8 inversely 8:7 investigation 32:2,10,14 39:17 involve 114:18 involved 4:25 39:18 64:23 77:19 involvement 90:14,15 98:9 involving 70:24 112:24 irregular 17:9 irritable 94:2,5 irritating 105:16 irritation 86:14 92:4 104:20 105:3 isolated 26:7 112:8 issue 101:16,23 104:8 itch 83:4 iv 1:12 j j.t.g. 10612 jack 106:12 jag 89:9 january 39:19 73:11 80:16 96:18 108:13 24:13 32:11 japanese 23:22 24:1 26:22 29:20 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMON006930 [Japanese - located] japanese (cont.) knew lane levinskas 32:14,17 106:16 12:4 4:9,18 jaundice know large liable 98:11 4:5,12,17,24 5:20,23 6:6,10 91:8 75:5 jenkins 6:12,20 7:4,8,9 10:7,19,22 lassitude libido 2:24 10:25 11:11,14,18 12:7,20 75:20 76:3 93:22 94:1 75:21 76:4 93:19 job 13:7 14:8,13 16:14 17:9,15 law life 83:9 19:6,7 20:1,25 21:15,19,24 2:23 20:7 29:24 joint 22:18 23:8,13 24:21,22 lawfirm lifetime 26:15 33:8,20 38:1 93:15 25:5 31:17,20 33:11 34:1,7 2:27 20:10,18 72:16 joints 35:7 36:15,17,17,19,21 lawful limit 26:15 31:16,21 32:21,24 42:23 43:5 44:5,11,12,19 3:12 20:22,24 72:11,13 79:3,4,8 jones 44:22 46:11,25 47:4,6,11 lawsuit 80:11 82:17,18,21 7:10 8:5 48:20,22 49:24 50:5,6,20 34:16 lindbergh journal 53:1,5,9,14,15 55:23,24 lay 35:1 7:22 8:3,12 10:16,24 117:3 56:1,4 60:4,5,25 61:4,20 110:25 line judith 63:14,15 64:2,3,6,20 65:2 lead 12:13 108:4 11:14 12:8 14:23 35:6 68:9 69:20 71:5,7 72:4,5,6 87:2 lines june 75:10 76:4 77:3,19 78:11 leading 87:8 1:152:12 108:20 79:20 83:21 84:2,4,6,22,24 90:25 lipa jury 84:25 85:6,23 86:5,6,8 89:7 leads 122:12 38:25 40:10 42:4,7 51:20 89:24 90:9 93:16 94:4 97:6 86:15 lipids 65:9,12 72:12 77:2 88:21 98:6 99:4,13,14,15,25 leak 43:15 k 100:1,2,15,21 101:7,13 73:1 99:4 liquid kanaclor 26:22 102:25 103:6,9 106:22 107:2 108:16 112:12,23 leaked 21:17,17 77:4 list kanechlor 23:22 keep 113:3 114:1 115:23 116:18 leaking 118:7 30:9 88:23 knowledge leaks 7:12 44:15 69:16,22 71:15 71:17 98:21,24,25 119:11 120:2 75:15 kelly 4:14,18 5:2 21:9 42:13 47:2 69:5 54:2 70:2,5,6,12,23 89:25 led listed 88:11 96:17 1:132:11 3:11,16,18 6:22 111:14 9:4 92:5 lists 9:10 10:14 13:13,16 14:8 15:6 33:5 34:13 39:13 44:9 44:22 46:16 47:21 48:3,6 48:1749:13,16 50:10,14 51:3 52:11 62:11 63:3,8,12 64:10 70:14 73:21 75:17 76:2,6 77:1 80:1 86:12 92:2 known 40:4 98:19 115:7 knows 36:20 38:25 55:11 70:9 105:4 kowan's 119:23 64:10 left 98:16 119:7 10:18 12:3 16:1963:25 literature 102:16 109:7 110:14 119:3 25:9 26:4,5,7,8,9,11,12 leg 35:8,15 36:23 43:3 75:11 42:13 93:14 legend litter 12:4 70:8 95:19 100:7 108:18 110:15 112:23 114:1 116:3 118:20 krummrich 9:15 10:9,10 legs 42:15 54:10 89:18 90:11 little 12:21 20:23 40:8 48:2,13 120:3,4 121:11 kidney 62:16 killed 61:20 kimbrough label 67:19 labels 67:14 labor 1 lesions 24:17 lest 27:16 letter 34:22,25 61:22 77:19 94:6 105:3 liver 8:7,20 27:12,22 29:13,15 29:21,23 30:7,11,14 51:18 88:25 90:14,15,17,21,24 92:10,13,22 93:1,4,25 8:21 kind 5:18 56:5 57:8 101:21 kingshighway 2:15 67:6 73:6 81:3 laboratories 35:3 laboratory 9:2 76:22 level 94:18,19 95:3,4,7,25 96:1 17:3,19 20:3 31:4 72:15,17 98:9 119:1 levels ln.1 7:23 12:16,18 13:24 14:1 1:19 15:24 16:3,17 19:12,14 local kitty landfill 27:23 51:17,18,23,23 73:22 91:17,18 103:2,3,7,12 70:8 kj 107:1 99:5,6,9 landfills 99:12 100:2 74:1,3 75:18 76:15 95:15 95:17,18 96:2,3 100:15 105:22 located 100:21 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6931 [long - mississippi] long male mccrea (cont.) medicine (cont.) 4:6 30:8 57:6 74:5 81:21 39:18 45:18 46:7,21 47:6,10,15 28:18 117:6 83:2,3,3,4 94:6 101:13 males 47:24 48:19,22 49:5,9,12 memo 115:7 52:23,24,24,25 53:7,7,8 49:16 50:11,18 52:9,11 121:1 longer 56:16 57:22 59:8 53:11 54:18,22,23 56:8 memory 8:9 49:21 75:12 malignant 57:12 58:6 62:11,14,22,25 56:5 look 60:13,15 63:9,1264:1265:11,19 mention 4:11 14:10 25:3 26:9 28:22 man 66:3,25 70:16,22 74:4 56:14 66:18 37:9 41:15 42:18 43:22 21:22 22:13,14 61:20 72:25 76:18 81:25 82:1,18 84:3 mentioned 66:15 83:20 92:16 117:2,2 80:22 81:11 92:9,14 93:3 85:16,22 87:15,20,25 88:5 6:13 76:13 89:1 93:15 117:5 118:11 96:8 98:3 100:17 88:6 90:1 92:1 93:6 95:10 met looked manager 97:3,12 101:6,9 102:4,9,14 11:17 14:17,18 22:6,19 17:13,1468:11,14 102:19,21 103:23 104:12 metabolic looking man's 104:19 106:11 110:22 7:21 14:1621:11 56:7 94:7 112:19,22 113:21,25 meter lookout manufactured 114:11 116:20 118:7 119:7 17:20,24 93:7 13:18 19:4 115:17 119:12,17,22 120:1,8,11,16 meters looks manufacturing 120:19 17:4,5 4:20 109:3 8:14 10:13 19:8 28:16 68:5 mes method loss 70:1975:17 103:10 116:17 107:22,24 91:16 75:20,21 76:3,3 85:23 86:1 marine mean methods 86:16 87:2 88:7,24 90:18 111:3 4:17 10:10 11:1,4 12:22 13:1741:10 90:22 92:5 93:19,24 mark 13:6 14:20 15:11 18:10,16 mild lot 65:22 19:25 20:1,23 21:10 22:16 27:12,22 29:13,15,21,22 43:10,13 60:10 78:12,16 marked 29:15,16 30:5 31:17 40:7 30:7 95:7,8,10 89:19 9:9,18 66:2,6 42:14,20 43:11,20 44:12 miles lots market 53:5 59:15 60:3 61:14,20 118:11 47:13 108:12,14 114:25 62:2,3,4,8 68:18 69:12,14 milligram louis master 72:5,9 77:15 79:19 82:7 17:20,24 1:1,26 2:1,16,24 9:15 10:6 63:18,20 83:24 87:25 91:12 94:4 million 10:7,13 12:4 13:20 14:17 master's 96:21 104:16,19 109:12 113:12 16:4,23 19:3 21:3 32:23 63:18 110:18 112:4 115:4 117:3 mind 35:2 43:7 57:24 58:1 99:11 material meaning 6:21 14:7,22 19:10 22:10 121:2,19 122:5,14 18:1067:4,11,15,23 68:15 5:16 22:21 56:3 lower 69:6 72:14,15 77:18 78:9 means mineral 42:1554:10 111:3 81:14,15,16 86:21 88:9,15 8:20 12:22,23 13:1 16:15 6:6,10 lumped 88:21,23 97:21 101:3,11,22 24:22,23 25:21 37:24 41:4 mines 112:16 104:6 106:2,19 112:5 41:12,21 52:20 59:20 62:23 100:5,8 101:1,24 102:11,22 lung 114:16 71:7,13 77:4,17 109:13 minimal 53:18,20 55:17 56:10 61:7 materials meant 114:21 lungs 13:1767:1369:1 88:18 13:14 14:24,24 88:1 89:14 minimum 106:2 matter 95:8,10 99:5 103:25 110:7 14:12 m m.d. 1:132:11 3:11 121:11 magazine 11:4 main 40:12 16:15 67:19 80:20 92:16 maximum 20:19 75:3 me 3:15 mccrea 2:27,27,27 10:12,14 13:15 14:10,15 15:1 20:15,16,17 110:10 111:4 minnigerode mechanism 2:16 3:4 31:23 32:3 minor medical 23:5 29:17 10:16 12:1 18:1 42:24 56:9 minute 69:22,24 70:17 80:12 94:8 20:25 27:14 34:1,5 46:4,5 97:4 109:1 113:10 115:6,8 47:20 52:5 62:6,13 66:23 117:4,4,9,17,24,24 118:19 92:25 119:3 9410 majority 25:1,1 30:1561:7 making 35:20 47:20 98:22 23:18 24:6 26:14 27:5 medically 28:15,20 29:1,2 32:9,16,22 82:13 115:23 33:15,24 34:2,3,21 35:20 medications 35:22 36:6,15 37:17,19,23 94:13 96:15,20 38:7,11,15,17,21 39:1,9,11 medicine 44:13,14,25 45:2,8,11,16 8:4,12 10:24 11:21 12:2,6 minutes 47:1 66:22 83:5 misleading 36:3 mississippi 64:16 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6932 [missouri - oil] missouri mouth neurological 1:2,26 2:2,16,18 12:5 35:2 23:21 118:24 121:3 122:14 move neverland misuse 65:20 118:1 114:10,13 moving new mixture 45:16 21:22 97:19 79:6,9,11 multi newspapers mo 56:6 115:12 2:24 121:19 122:5 muncie night modalities 82:24 69:15,23 103:8 musch nighttime molecule 9:12 11:1828:1735:6 69:15 71:14 39:14 53:12 nine moment myriad 14:11 15:20 33:6,19 37:25 63:24 83:18 84:11 116:6 39:18 43:22 50:1 52:13 monitor n 61:25 16:15,17,18 19:4,16,17 monitored name 6:17 12:1 121:14 ninety 10:18 19:1682:13 115:24 names niosh monitoring 12:15 13:5,23 14:4 16:2,5,8 43:11 48:23 narrative 50:1,6,20 7:21 35:2 38:11 73:6 nixon 16:8,11 18:19,22,22,23 19:14 monoxide 50:23 nausea 85:2 86:15 87:2 88:6,17,24 42:14,15 no.2 101:20 98:17 monroe 92:5 98:6 nauseated non 54:5 117:24 118:22 51:12,15 95:13 117:9 monsanto 1:7 2:7 4:7,8,15 5:6,9,12 90:20 near 100:13 normal 122:10 north 9:14 10:13 11:15,20,24 12:5 13:4,18 16:24 18:7,17 necessary 120:17 35:1 nose 19:22 28:17 34:15,17 35:1 neck 82:25 83:4 35:5,16 44:7,16 45:20 46:23 47:13 53:8 63:13,22 63:24 64:1,7,25 67:6,15 70:15,16,17 76:7 80:12 81:5 86:13 91:16,25 96:17 97:4 99:8,23 108:18,19,21 108:25 109:1,1 110:10 18:12 need 71:22 100:11 119:19 needed 92:22 103:12,12 negative 7:24 76:22,23,23 notary 2:17 3:5 122:19 notice 59:19 number 15:2 21:3,1526:1731:6 34:12,14,21 39:2 45:12 111:14 121:5 monsanto's neglected 56:13 46:14 52:2 57:12 59:24 60:17 65:24 66:4 68:18,21 9:11 28:20 negligible 69:10 80:7 97:25 101:19 month 73:8 74:8,15 75:4,12 months 14:12 15:1639:1975:18 98:11 109:9 neighboring 53:19 neoplasm 60:15 102:7 numbered 65:21 66:10 numbers 17:17 61:23,25 65:24 79:7 morbidity 33:16 45:4 morning 3:16,17 mortality neoplasms 60:13 nest 111:1 neuritis 91:22 numbness 25:24 oath o 9:13,22 12:23 28:16 35:5 93:10 35:21 36:5 50:13 39:17,20 45:5 52:7,17,20 53:23 55:7,12,15,18 56:15 57:22 64:22 65:12 neuroendocrine 24:18,20,22 obese 31:10 58:21 obesity 41:6 58:14,25 object 13:10 14:6,19 23:15 26:3 26:13 28:1 32:5 33:12,22 34:12,20 35:19 38:3 44:8 53:4 55:22 64:9 65:14 73:25 76:11 83:15 91:19 103:20,21 104:10 110:12 112:15,18 114:7 116:1 117:22 objection 28:25 46:6 82:15 89:22 95:9 102:2 obscures 41:4 observed 24:16 39:22 40:13 59:16 61:9 109:16 obvious 55:16 obviously 16:1398:8 111:2 116:14 occupants 114:20 occupational 8:15,17,24 10:24 117:4,6 118:22,22 occur 5:11,1830:841:1652:13 60:9,10 88:14 90:7 109:17 115:20 occurred 42:21 89:3 90:8 109:6 occurrence 5:17 o'clock 2:13,14 odor 77:6,10,11 82:9,17 odorless 77:7 office 49:3 officer 121:8 offices 2:15 oh 27:18,20 28:13 37:8,8 49:9 50:21 69:9,12 70:17 71:1 78:22 Ohio 35:3 oil 6:7,10 23:21 24:11 25:18 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6933 [oil - phone] oil (cont.) overexposure (cont.) part people (cont.) 25:22 29:20 31:24 77:7,8 85:6,17,24 86:8,13,19 87:1 3:13 37:4 56:16 63:25 25:22 29:19 31:19 32:20 okay 87:5,17,21 88:2,9,12,15 64:19 89:12 40:21,23,24,25 41:12,13,14 49:11 106:15 120:8 89:21 90:6,13,19 91:17 particular 50:2 51:22 52:21,21 53:18 old 108:3 4:11 7:5 17:18 19:1727:1 55:18 57:17 58:18,21 59:1 117:9 overexposures 28:4,11 32:10 37:21 55:6 59:8 60:14 62:25 68:5 69:7 olive 86:20 67:16 69:21 100:22 103:8 69:17,18,19,22 70:1,19,22 1:25 122:13 overnight 110:23 112:12,23 114:19 73:17,22 75:11 76:16 88:21 once 66:21 particularly 96:1 97:20 98:4,5 103:10 82:23 83:5 oversaw 94:20 96:10 111:9,10 112:9 113:3,8 ones 33:16,24_________________ parts 114:22 116:17 117:5 27:4 P 7:23 118:17 one's page patients percent 40:11 8:13 11:20 12:11,14 14:10 25:23 9:17 33:7,19 37:25 41:22 open 82:23 opinion 6:1 23:2 25:4 56:8 76:6 111:13,23 112:2 113:15,16 opportunity 36:1 57:7 21:5,6 24:6,8 26:17 27:9,14 27:15 31:12 37:5 39:13 51:11 52:8 56:6,14 57:6 64:17 65:24 67:1,8 79:2 paul 4:5 6:13,15,19,20 pay 22:3 41:6 41:22,23 59:15,16 71:4,7,8 83:12 106:23 107:6,24 108:1 113:24 peregrine 80:5 87:12,13 91:6 106:3 pcb 111:5,7 106:18,25 107:4,21 108:8 108:17,24 4:6 5:1,11,19,21 6:3 7:23 perform 8:1 9:16 12:15,17,18 13:24 4:7 16:22 opposed pages 14:1,2 15:24 16:2,9,11,17 performed 59:6 21:5 24:24 47:11 65:21 17:2 19:8,10,17 23:23 117:19 order 66:10 25:11,1229:11,20 30:16,25 period 49:14 56:2 67:24 organic paid 113:11 122:9,10 31:2,4,24 35:5 37:17 42:11 42:21,25 43:18 44:24 45:2 12:25 13:12,17 14:12 15:6 15:15,16,24 47:21 73:13,18 100:6,8 pain 51:23 54:7,8 61:22 62:24 82:3 87:21,24 88:1,2,11 organisms 25:24 26:15 31:16 32:21,23 64:23,25 65:18 71:5 73:22 115:22 111:3 33:8,20 38:2 86:7,11,16 74:13 79:14,15 83:25 84:7 periodical organization 38:10 original 28:24 121:15 122:1 originally 68:25 86:24 os ha 87:3 88:7,25 90:12,16 92:6 93:15 84:18,19 85:17 90:4 92:8 92:15 95:1,2,18 96:3 pains 106:22 107:6,7,23 112:24 31:21 paint 29:11 papers 113:24 pcb's 3:20 4:2 5:8,13,17 6:7,11 7:21 8:17,25 9:3,4 10:1,3 11:2 periods 3:25 75:12 peripheral 93:9 permeated 115:21 19:11 68:18 73:6 ought 25:10 78:14 paperwork 13:18 14:12 15:3,7 19:3,8 perry 21:16 22:16 24:12 26:23 122:12 26:8 92:16 93:12 101:14 18:12 29:6,9 30:6,19 31:4 32:11 person 116:11 para 32:14,17 33:7 39:19 42:6 29:22 30:5,9 32:19 41:14 outbreaks 24:24 42:21 43:4,9,14,19 45:6 45:3 69:20 73:2 94:14 95:6 24:12 paragraph 51:17,1961:1763:1,6 68:7 96:8 104:24 107:19 117:24 outcome 13:1624:8 27:11,15,16,17 71:4 72:8 76:13,14 83:13 121:14 8:18 27:20,21 39:16 51:12 109:8 84:5,8,17 85:15 90:13 personnel outfit 97:14 109:25 110:10 pardon 91:17 94:21 95:14 97:8 12:17 13:25 114:20 98:5 99:8,15,17,22 104:8 persons outflow 54:25 104:20 105:13 107:3 25:19 7:2 paren 111:11,17,21 112:13 person's outside 8:15,16 113:19,21,23 114:5,5 116:6 94:20 70:5 107:2 overexposed parentheses 24:14,15 116:22 117:12 pending pg 1:19 81:1 84:19,25 parenthesis 46:14 phlebitis overexposure 24:15 people 42:14,15 43:3,24 49:23 79:18,19 80:13,19,21,24 parkway 5:15 6:25 7:9,23 8:9,9 10:7 54:9 81:2,4,11,12,19,21 82:8,13 35:3 12:25 15:11 19:1 21:18 phone 82:16 83:1,14 84:10,24 22:5,6,13,14,23 23:1 25:1 69:11 85:4 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6934 [photocopy - putting] photocopy polychlorinated 35:4 23:22 28:16 110:2 phrase population 40:6 107:24 7:1 55:8,13 58:15,19,22 physical 59:2 75:25 76:21 77:1,4 118:21 portion physician 91:10 83:22 91:9,15,22 117:11 portions physicians 82:11 97:5 117:10 position picking 116:15 56:13 positive picks 9:2 60:10 positively pieces 33:1 26:5 possibility place 115:5,8 4:3 19:9 21:22 24:21 36:1 possible 89:1790:1091:16 103:6 64:24 78:2 93:9 115:24 116:10 116:7 117:12 places possibly 73:17 75:14 89:19 3:24 plaintiff postulate 2:22 3:2 43:12 plaintiffs potential 1:5 2:5 3:1344:7,9,17,18 70:2 plaintiffs power 9:8,19 66:7 64:24 plant ppo 7:79:15 10:1,6,13 12:17 106:20 13:19,25 14:17 16:4,23 precautions 17:13,14 19:3 21:3 23:7 69:5 70:10 103:23 105:12 32:23 33:6,20 35:5 38:1 109:15 114:16 43:7 59:1 67:22 68:2,11,14 precisely 72:21,21 76:12,14 80:18 107:11 82:10,22,24 83:8,22 92:3 prediction 92:14,17 99:11 100:16,17 52:12 103:14 115:15,16,21,21 preliminary 116:3 6:14 plasma preparation 51:1895:17,20 67:9 plaza prepare 114:25 121:18 122:4 106:6 please prepared 39:13 102:20 107:21 38:16,1764:21 106:11,16 point 107:14 46:12 59:13 60:21 62:18 presence 63:5 77:15,17 5:17 111:24 112:3 points present 57:4 60:23 94:8 109:10 poison presented 104:9 105:4 8:24 19:17 poisoning presently 23:20 31:15 104:20 111:21 police presents 75:8 112:13,25 114:2 press project 90:25 33:24 pressure prolonged 40:4,16,17,18 77:6 109:9 3:25 presumably prominent 67:6 95:3 91:2 presume properties 24:2 76:17 79:13 117:12 presumed proportion 84:24 25:19 pretty proportional 7:18 17:9 23:5 25:8 77:21 96:3 prevent proposed 114:16 20:24 primarily protection 68:24 69:9,10 73:3 78:1,13 100:4,5 103:1 print protocol 78:18 53:12 117:18,25 118:19 printed proven 11:1268:21 43:16 prior proves 87:12 62:19,20 pro public 4:22 2:173:5 8:5 11:3,7 48:16 probability 63:20 97:18 112:7 122:19 41:21 56:9 publication probable 11:11 60:6,8 publications probably 111:19 19:25 30:25 48:17 91:3,25 publish 93:12 97:4 98:25 11:2 problem published 72:18 73:9 95:3,4,7 113:10 8:14 9:14 10:19,20,22 11:9 113:10,13 34:5,8,10,13 35:8,15 36:12 problems 36:13,23 38:6,6,8,14 49:2 70:3 74:21 92:22,23 93:1,2 86:13 88:10 93:25 95:4,25 96:1 97:7 publishing 114:4 115:24 11:1 procedures pull 77:25 86:17 91:5 99:4 26:10 108:4 pulling produce 26:10,11 5:24 6:11 pump produced 17:2 2:11 3:12 6:2 7:16 34:15 purpose produces 26:6 5:22 pursuant product 53:13 67:19 69:21 71:3 78:8,25 put 80:19 108:10,19,23 19:1229:11 33:1338:9 production 41:23 56:4 61:1 70:8 88:14 39:19 64:24 90:1 91:3,3 97:24 101:14 products 101:15 102:14,17,21 98:16 106:13 107:18 112:9 progeny putting 111:2 105:15 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6935 [pyrenol - result] pyrenol raymond reference report 74:14 33:16 38:13 6:22 21:6 49:14 51:11 10:15 14:25 15:5 34:8 35:4 q reactivity 65:23 119:1 35:7,7,13,14 36:12,22,22 qualifications 8:22 qualified 53:22 qualify 98:15 read 21:9,1324:1026:1,18,24 26:25 27:1,3,8,11 28:5 31:18,22 34:22,23 44:14 referenced 9:23 10:6 24:7 references 21:7,8 referring 37:3,7,12 38:4,23 39:2 45:19 47:3,5,5,9 51:2,5,8 52:2,10 54:19 55:24 56:7 56:14 57:6 62:5 63:12,13 64:18,19,20 90:2,6,7 93:13 115:4 quantify 4:4 12:15 13:24 16:2 101:13 54:16 55:24 56:4 57:2,5,9 59:11 65:4 66:23 67:15,22 77:11 78:18,22 86:12 90:6 98:16 111:7 7:13 13:22 14:3 26:9 46:8 refers 15:25 regard 105:7 reported 17:13,14 24:13 25:24 27:24 74:23 89:24 95:11 quantities reading 21:7 62:24 70:2 97:7 reporter 108:15 quantity 17:4 quarter 56:6 26:4,5,7 28:2,6,23 35:24 54:21 107:22 reads 12:14 realize regarding 70:24 regroup 48:8 regular 2:17 3:5 65:22 66:6 reporting 1:24 25:19 122:12 reports 21:11 31:1637:11,14,16 quaterphenyls 7:18 57:2 86:19 16:8 39:3 50:25 73:17,21 74:10 23:24 question really 12:21 18:8 24:22 41:4 rek 89:10 74:12,16,19 75:10 represent 1:18 13:11 19:1528:11 30:5 32:8 35:23,24 38:4 41:9 42:3,8 43:1 44:13 66:16 90:9 realm 14:22 70:6 relate 65:4 related 35:14 120:11 representative's 113:16 45:14 46:6,21 53:10 55:23 56:2 65:1 73:21 74:1,2 reason 6:18 31:3 53:2,11 105:15 7:10 8:8 30:2 42:25 54:7 represented 56:21,24 93:18 94:3 2:22,26 119:18 77:19 83:19 88:5,6 89:23 91:20,21 95:24,25 99:19,21 102:3 103:21 104:11,16,21 105:25 109:23 reasons 60:10 relationship 20:9 25:18 32:7,11 42:16 43:12 51:19 76:8 95:18 representing 120:14 reproducible 109:19 110:12,17 112:16 114:8 116:2 recall relative 6:9 16:20 17:16 19:2 26:24 120:5 40:14,19,19 request questioned 27:2,3,4 32:25 96:25 97:9 relatively 35:17 47:25 49:12 44:16 questions 3:15 35:21 44:6,20,23 46:9 47:20 48:3,8 68:13 70:2,23 104:2 quote 8:1,13,149:2 24:14,14,15 98:13 108:9 received 68:6 recited 118:19 recognized 25:10,11 8:2 relevant 18:9,10 rely 74:25 remember 5:1 10:21 12:24 17:18 requested 119:9,14 requests 47:19 residents 51:1795:14 respect quotes 8:23_____________________ recollection 16:4 56:3 57:21 81:2 90:8 91:2 96:20 3:20 42:5 43:5 70:12 100:22 102:13 110:6 respirator recommend remove 78:5 100:6,8,11 101:2,14 r 74:14 75:15 116:20,22 91:7,7 92:8,11 101:20,24 102:11,23 random 117:20,21 removed respiratory 16:20,22 18:22 19:20 recommended 18:5 25:25 59:5 61:11 78:1,13 ranging 100:18 117:17 remover 100:5 84:12 record 29:11 respond rat 18:7,8 24:10 26:6 80:1 repeat 47:19 32:20 recorded 30:14 40:14,15 response rate 17:11,12,25 repeated 25:18 40:20 41:2 84:3 17:2 37:23 55:12,15 56:16 records 3:23 104:17 responsible 57:22 78:23 13:8 16:12 18:3 48:16 repeatedly 70:18 rates red 81:17 result 56:2 58:9 29:12 repetitive 4:10,156:3 11:9 30:19 raw refer 102:3 31:16 76:25 87:17 90:2,13 44:4 120:4 10:1291:8,15 90:18 105:2 111:10 115:8 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6936 [resulted - simple] resulted routine second sheet (cont.) 24:12 88:18 16:10,18 18:19,22,23 19:4 11:20 23:14 34:2 36:21 81:24 86:23 88:9 101:3 resulting rule 51:5,12 102:19,19 108:4 106:19 107:18 43:7 92:15 59:4 secondly sheets results ruled 40:20 68:24 69:7 4:22 18:25 19:24 20:2 42:24 59:6 section shellfish 31:18 41:5 50:22 rules 19:8 68:22 71:25,25 77:1 29:24 retention 40:12 58:12 77:14 79:2 80:4,9 87:5,13 shells 18:8 run 87:16 91:6 103:1 106:4,19 110:25 reticent 41:24 79:9 118:5,8,24 107:10 108:7 shipped 33:3 s sections 108:15,16 retired s.m.a. 26:7 short 19:23 46:1664:11 retrospective 28:15 review 4:6,8,10,15 49:17 57:7,9 120:6 118:25 s.m.r 56:15 s.m.r. 59:12,24 61:23 safe secure 67:24 seeing 19:2 seen 18:15 22:5,25 27:7 38:23 39:12 79:25 80:1 101:12,13 120:10 shortcomings 4:11 shorter 8:10 reviewed 7:25 20:4,5,8,15 67:12 39:4,6,7 43:2 67:18 109:5 shorthand 4:9,21 46:23,24,25 49:19 120:4 70:18 72:14 safety select 118:3 2:17 3:4,4 shot reviewing 4:25 rheumatic 17:1567:4,11,16,23 68:6 68:15,24 69:6 70:10 78:9 81:23 86:23 88:9 100:17 self 25:20 send 61:15 shoulder 28:22 42:10,10 43:3,24 44:2,5,17 44:24 45:3,6 49:18,23 54:9 101:3,3 106:19 Saturday 68:15 92:11 sentence show 30:8 33:11 34:19 38:20 56:19 rice 23:21 24:11 120:12,13,18 sauget 10:1,7 13:18 35:6 13:22 25:1726:11,11 27:11 39:1 46:7 51:19 66:10 27:16,20,21 28:6 39:25 95:18 98:10 114:21 44:12 57:5,9 64:18,18,19 showed rigged 88:21 save 112:19 64:21 sentences 26:25 39:21 53:17 65:17 75:13,14 right saw 24:11,24 showing 7:4 10:12 11:6 12:9 15:10 16:1 21:12 23:2 26:16 29:1 32:16 34:21 36:15,25 37:4 37:6,6,23 45:15,17 46:15 55:20 58:7 59:10 65:3,19 75:5,7 78:17,23 79:18,24 87:13,22 96:15,22 106:3 10:20 21:19,25 44:10 96:5 110:16 saying 15:23 28:21 36:3 39:7 42:1745:10,11 56:11 57:21 119:14,20 says separate 104:2 serum 51:17,1995:15,18 service 8:6 set 28:5,7 38:25 41:10 shown 8:16 shows 61:5,19 72:14 75:11 shrimp 110:8 111:3,4 108:17,24 109:13 113:17 righthand 3:13 13:6 14:11,24 16:6,7 36:19 42:2,22 51:15 55:7 20:24 79:10,11,13 122:15 setting side 110:14 68:19 56:22 63:20 71:10 77:8,10 3:20 33:2 sign ring 71:13 risk 111:10,20,24 112:2,8,10,13 112:25 114:2,14,17,18,19 77:25 78:17,21,23 79:3,18 81:11 84:18 85:14 86:7 87:20 91:15 92:2 103:11 104:14 109:8,15 scientific seven 43:25 61:24 62:22 seventies 18:11 seventy 84:10 85:24 86:8 109:3 signed 3:6 significance 31:21 42:7 115:5,6,8 risks 111:16 115:4 road 31:11 65:6 8:25 35:8,15 36:23 42:23 43:2,17 53:13 62:18 65:17 111:20 115:13 scientifically 5:11 59:20 60:11 71:4 severity 83:17 sewage 7:21 significant 4:2 39:21 40:7 41:8,11,11 42:1,17 44:1 54:5 59:21,25 60:11,21,24 61:1,4,6 62:9 63:5 71:9 109:10 robert seal sex signs 35:2 room 109:9,14 122:16 search 25:9 52:21 sheet 67:4,11,16,23 68:16 78:9 44:15 88:8 92:18 simple 38:24 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6937 [simpler - sufficient] simpler smokers 10:5 56:1 58:15,25 simplify smoking 39:7 48:25 56:1 58:13 59:6,7 60:20 single 61:6 104:14 20:12 32:22 65:22 soaked sir 81:18 3:17 4:3 7:4 9:21 12:12 soap 13:21 24:9 27:10 32:1 91:8 39:15 40:1 50:3 60:19 society 61:1066:1267:2,1868:3 117:9 78:17 79:1 80:3,6,15 81:7,9 solid 86:14,18 89:10 96:15 99:3 77:4 103:17,18 106:7 107:8,13 soluble 107:15,19 108:9,22,24 30:25 31:5 77:5 110:22 111:12 113:17 solution situation 17:1 84:2 94:5 98:8 112:12,24 somebody 113:9 14:8 38:23 61:14 85:14 situations somebody's 74:20 83:9 103:14 112:6 six someplace 14:12 15:15 17:4 25:23 17:12 97:19 98:2 39:19 61:24 62:1,22 66:5 soot 75:18 80:8 82:23 98:18 sixteen sorry 108:1 111:15 65:10,15 77:11 sixth sort 109:8 41:23 97:23 sixty south 27:5 2:27 skimmed spaces 66:16 3:24 101:19 skin special 3:23 29:4,12 79:22 83:4 77:25 100:4 103:1,23 86:14 92:4,23 93:1,5 105:12 118:25 103:24,25 104:5,9,13,17,18 specialized 104:22 105:3 70:1,4,6,12,23 slight species 61:1298:11 110:24 111:4 slightest specific 68:20 77:5 114:23 slowly specifically 45:16 24:7 sludge specification 7:2,22 108:19,23 small speculate 7:19 9:16,17 56:13 78:18 13:13 14:7,9,22,25 smell speculation 82:20,20 13:11 110:19 smith speech 8:11 33:18,25 38:11 92:2 35:24 smog speeches 55:11,14 56:9 35:20,23 36:4 smoke spell 98:17 104:15 102:8 spill statistically (cont.) 68:23 72:20,22 99:4 112:5 43:25 52:11 54:4 59:25 spillage 60:11,21,2461:1,5 62:9 112:9 63:4 spilled statistician 69:3 41:19,25 spills stipulated 69:5 3:1 5:4 spoyer stomach 88:20 97:17 25:24 40:17 spread stopped 114:16 15:11 St street 1:1,26 2:1,15,24 9:15 10:6 1:25 2:28 22:15 122:13 10:7,13 12:4 13:20 14:17 stretch 16:4,23 19:3 21:3 32:23 42:10 35:1 43:7 52:25,25 53:7,19 stroke 57:24 58:1,2,3,4,5,6 99:11 49:25 121:2,19 122:5,14 studied stack 15:8,21 21:13 36:25 37:1 66:6,11 studies standard 4:6 5:12,20 6:6,23 7:5,12 19:13,18,19 20:6,7,9,9,11 7:15,17,19 8:15,24 9:11 20:18 52:17,20 55:12 56:15 21:4,6 27:24 33:13 52:19 57:22 65:5 55:7 standards study 19:12 20:12,19,24 53:13 7:6,10 9:13,22,25 10:2 standpoint 12:11,16,22,22,23 13:1,8 54:1 13:25 14:13,20 15:1,24,25 start 21:2 23:19 28:16,18,19,20 21:15 30:23 33:5,9,10,15,22,23 started 33:23 34:4,18 39:14 40:11 64:3 73:5 99:25 113:21 40:12,13 41:1,7 43:5 49:2 state 50:22,22 52:7,12,18 53:16 1:2 2:2,18 13:16 14:4 16:15 53:21,23,25 54:17,24 55:1 38:7 52:4,14 87:7,10 121:3 60:17 63:7 64:2,3,21,25 stated 65:5,6,7,8,12 5:16 40:2 54:4 56:15 83:11 studying 95:12 96:24 109:22 111:20 40:21 41:5 statement stuff 12:19 13:4 25:6 35:12 30:10 70:7 74:25 78:25 103:6 108:5 subject 110:5 121:9 5:2 states submitted 8:5 13:23 16:1 27:12 39:16 67:5 52:24 53:7,17 55:8,13 subpar 57:23 58:16,22 59:2,8 90:21 64:18,21 67:5 87:9 91:6 subscribe 94:23 109:20 110:1,10 63:1 112:8 substances stating 32:3 39:2 74:18 suffered statistical 25:6 73:24 41:10,11,1765:17 sufficient statistically 92:9,10 116:14 39:21 40:641:11 42:1,17 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6938 [suggest - thumbing] suggest system temperature (cont.) things (cont.) 64:1367:14 18:8,9 43:23 59:5,20 61:8 109:9 73:5 77:12 112:16 116:7 suggested 61:11,12 temperatures think 43:6 50:4 64:7 systemic 86:22 88:16,19,23 100:19 3:22 8:21 10:5,17,19,23 suggestions 86:15 87:1 92:4___________ 101:12,18 102:1,12,24 12:1 13:12,15 14:21 18:4 118:5 t 109:18 21:23 22:7 25:21 26:12 suggestive 60:1,3 table 59:10 ten 28:3,7 30:15,22 32:5 36:3 9:17 13:8 17:5 19:23 40:22 37:22 38:24 39:5 43:1 44:9 suggests 87:16 suite 1:25 121:18 122:4,13 tables 50:23 52:9,18 taft 35:2 40:25 46:25 61:25 64:17 73:13 74:8,15 75:3 82:3,6 82:10 tend 44:19 45:2 46:20 47:8,22 48:1,10,14 49:24 53:20 55:9,16,23 56:2,4 57:4,8 58:12 60:2,9 62:21 63:2 summary taiwan 63:2 66:21 73:10,16 75:4 76:12 26:7,12 28:23 summery 26:4,5 28:2,7,8 supply 46:23 24:4,5,14 25:7 31:15,24 taken 3:3 23:20 39:12 79:25 120:10 121:12 talk tenure 18:14 term 4:6 25:13 41:4 60:4 81:21 terms 76:15 78:7 82:12 83:1,13 83:16,18 85:12 92:15 94:6 94:12 97:1,7,8 98:7,22 99:10 101:7 102:5 103:10 107:24 110:13,15 112:21 supplying 116:17 51:20 55:6 104:11 115:2,3 116:2,11 119:4,11 81:5 support talked 4:18 11:17 19:1 terry 34:25 thinks 105:2 46:24 supporting 45:19 talking 20:14 29:19,21 32:13 48:15 59:4 70:14 74:13 76:12,13 test 6:7 32:18 tested 77:20 115:17 third 23:25 40:17 41:2,3 47:22 48:7,9,11 98:1 supposed 86:23 78:20 86:22 81:23 84:14 86:19,20 100:22,23 102:13,18 5:17,22,23 testified 75:17 thirteen 108:17 supposes 43:11 sure 106:8 111:8,9 113:18 114:23 117:23 talks 114:4 44:10 120:3 testify 53:6 87:18 119:8 thirty 33:6,19 37:25 57:6 71:7 83:5 91:24 4:20 5:9,14 11:5 16:9 17:12 18:13 19:1628:5 29:11 87:13 tanks 6:19,20 63:9 testifying thomas 2:22 121:16 122:2 43:10 54:13 64:15 72:6,23 100:14 35:20 thought 86:6 99:6,24 105:21 116:7 surface 41:15 surprised 35:11 36:9 37:9 survey 33:17 tape 119:3,4 taxed 122:1 technical 7:25 telephone testimony 20:4 22:21 28:23 59:17 29:5 57:10 69:6 70:11 88:8 88:4 90:1 97:2 thousand testing 31:19 19:20 thousands tests 33:13 34:14 51:1695:13 117:18 118:5,7 three suskind 33:16,23,23,24 38:13 23:11 68:21 69:12 83:9 85:4 118:25 texas 24:7,8,8 29:24 31:13 41:12 41:1546:1948:2 57:14,16 swelling tell 6:14,16 61:24 62:1 73:7,12 75:19 89:1590:10,11,17 swollen 90:25 sworn 2:123:12 6:24 7:16 10:1921:14 32:20 33:1,1,4 54:18 68:10 70:21 71:18,22,23 75:1 80:21,25 81:1,12,13 82:5,6 82:8,14 85:19 89:2 92:19 thank 9:7 65:3 77:1 thermometer 97:19 thick 88:20,22 98:13 106:3 112:16 113:11 118:11 119:14 threshold 20:22 72:11,13 79:3,4,8 symptom 31:14 33:3 84:4 symptomatology 24:13 symptoms 93:8 94:5,15,25 100:9,10 100:11 101:3,10 103:4,24 104:4,22,24,25 106:18,25 107:4 115:25 116:10 118:2 118:4,5,9,10 56:6 thin 110:25 thing 48:15 60:11 62:2,4,8,9 80:11 82:16,17,18,21 throat 82:25 throw 41:7 24:16 25:20,22,24,25 30:2 tells 71:17 75:8 78:14 107:2 thumbed 33:4,17 44:15 76:9,25 88:14 92:19 93:3 94:9 96:17 77:12 temperature 3:24 77:17,21 81:14 102:7 112:6 things 18:11 43:15 52:22 54:7 66:21 thumbing 66:23 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6939 [till - walnut] till transcribed turn (cont.) users 21:19 3:5 107:21 102:16 time transcript turns uses 3:25 4:13 5:10 12:16,22,23 121:15 122:1 57:10 107:25 13:1,11,25 14:13,20 15:6 transcripts turpentine usual 15:25 16:16,19 17:18,22 122:8 105:16 52:19 18:24 20:7 26:19 30:8 transfer twelve V 37:21 40:9 48:7 66:19 21:17 30:10 86:22 88:22 41:23 61:3 vacuum 73:18 79:24 83:12 88:11 90:4 97:13 98:5 94:8 97:3 100:12,22 101:12 transformer 101:13 106:16 110:23 5:21 82:24 100:24 106:21 112:20 114:15 115:9 twenty 15:9 21:730:1341:12,14 44:20 57:14,16 60:23 61:3 83:12 101:22 vague 53:10 74:2 103:22 114:8 value times transient twice 20:23 72:11,13 79:3,5,8 16:2041:15 72:18 73:8,13 74:4,8,15 75:3,19 76:5,15 113:12,14 115:19 titled 108:18 29:16 transport 69:7 transportation 68:25 70:20 73:4 86:24 20:10 96:13 type 37:15 67:18 76:12 77:20 typewriting 3:6 80:11 82:17,18,21 values 51:25 vapor 77:6 82:23 109:9,10,16 tlv treat u vapors 72:9,10,24,25 73:7,12 74:4 118:16,17 74:8,15 75:12,19,24 76:5 treating uh 51:4,7 107:17 78:2 100:6,8 103:2,4,13,13 105:24 81:8,16 100:21 tod 2:16 3:4 93:2,4,4 118:10 treatment 91:24 92:12 118:14 umpteen 47:11 undefined varicose 54:11 varies today 20:14 72:4,6,6 93:18 tri 96:10 104:11 understand 4:3 various 111:13,23 112:2,11,22 114:1 116:24,25 told trial 5:36:14,15 trichlorobenzene 13:19 18:18 50:12,13,25 51:21 53:10 67:23 84:14 87:15 113:25 65:24 67:13 70:22 vary 12:18 14:1 19:25 46:25 49:22 68:9,12 75:2 85:13 92:20,21,21 5:21,24 6:4 71:5,6,8,9 72:8 73:23 79:11 106:23 unique 65:7 vast 7:18 24:25 25:1 100:13 101:17 trichlorobenzenes unit veins tom 50:8 87:25 119:17 tomorrow 36:12 119:5 top 54:20 108:25 total 9:17,17 14:11 97:7 122:6 totally 114:5 tried 37:13 54:6 triglyceride 30:25 51:18 95:17,21 triglycerides 27:23 30:18 31:3,5,6,8 43:15,18 51:24 96:2,9,11 trouble 30:10 88:22 90:4 98:5 42:13 54:10,11 90:25 united view 8:5 52:23 53:7,17 55:8,13 62:18 57:23 58:16,22 59:2,8 67:5 voice 94:22 112:7 33:3 units volume 86:22 1:12 unpublished vomiting 34:18 37:10,12,14 39:3 25:14,15,16 85:9,15 86:16 112:17 73:16 105:7 unrealistic 87:2 88:7,24 90:20 92:5 toxic 78:19,24 toxicity 69:20 109:2,2 toxicological 110:5,7,7,8,11 111:3,6 113:10 116:21 117:11 trademark 109:3 training 54:2 trans 30:9 truck 69:1 72:19,22 73:1 104:14 true 9:24 94:20,22 95:6 96:7 try 46:17 111:1 116:9 trying 14:22 28:21 35:22 87:7 88:4 tumors 40:17,24 84:12 turn 12:11 36:6 39:13 43:1 64:17 66:25 67:8 106:3 94:6 117:23 unreasonable 48:2 unsafe 3:19,25 20:15 unusual 23:16,17 upper 68:19 use 3:20 21:16 46:8 53:6 60:4 68:25 70:24 97:23 99:12 102:22 114:2,9,9,9,11,12 114:13 98:7 vs 1:6 2:6 121:5 w wait 27:14 34:1,5,23 52:5 113:23 walks 22:15 waller 1:24 walnut 2:28 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMON006940 [want - zero] want white world 6:20,20 39:5 54:16 63:10 56:16 21:4 78:4,7,12,15 80:22 85:16 widely worried 87:9 91:14 95:4 108:10 110:3 105:23 wanted willing wreck 19:18 22:4 69:20 93:16 34:19 61:14 94:24 97:22,22 115:23 withdraw wright wants 28:24 4:5 6:14,15 85:6,23 86:8 93:3 117:13 witness write 118:5,7 3:6 10:9 14:7 24:5 26:8 89:11 91:10 warn 28:10 35:22 45:14,17 48:13 writers 102:6,10 48:20,24 49:7,11 65:15 111:19 warning 120:6,14 122:15 writing 101:16,23 102:22 104:8,11 women 91:2 102:15,17,21 104:13 97:20 written warnings word 97:16 115:13 105:6 31:1842:2 66:17,17 wrong wash words 35:1236:10 117:16 91:7 8:8 40:15,21 88:3 104:17 wrote watch 110:18 117:18 21:23 30:23 88:13 89:1,5,6 98:9 work 89:12,12 110:15 watchman 5:1 7:10 40:22,23,24,25 wvp 69:15 56:24 61:22 63:22,25 64:4 89:9 water 77:6,22 91:8 ways 41:17,20 101:19 102:7,8 65:18 76:25 worked 8:9,9,13 10:3 12:25 15:14 15:15 75:11 82:22 85:15 yale 21 22 y wear 88:10,11 115:16 78:5,12 100:7 101:1,20,24 worker 102:10 3:20 23:10,12 30:18 32:23 10:1031:1444:22 49:11 59:22 72:23 104:22 wearing 91:13 40:21 67:15,22 80:17 82:1 83:11 84:15,16 92:3 100:7 47:4 64:23 116:23 week 102:10,13,22 103:2 105:2 20:8,10,11 47:21 48:5 73:8 115:14 117:24 74:6 82:23 83:5 98:10 workers 119:19 120:15 6:23 7:1,6,11 9:11,15,16,25 weight 10:3 14:11,16 15:2,6,8,20 85:23 86:1,16 87:3 88:7,24 21:3 22:18 23:7 28:17 90:18,22 92:6 93:24 30:15,16 33:2,7,17,19 35:5 12:3 13:8 15:9 18:9,15 19:23 25:23 27:6 40:22,23 40:24,25 46:14,17,19 82:3 82:6,10,23 83:6 89:6 91:25 105:6 110:1 111:15 115:15 115:23 119:15 welcome 63:11 37:25 39:18 42:5,9,21 43:6 52:3,13 53:8 55:10 63:13 6:13,22 8:22 44:14 66:19 went 22:3,18 26:17 45:19 48:25 97:25 west 64:16 westinghouse 64:22 75:20,25 76:2 84:1 91:24 101:23 104:12 114:21 worker's 3:22 72:16 working 24:2,15 27:6 31:20 yusho 23:20 24:14 25:6 27:5,19 31:15,19,24 32:10 33:17 z 7:7,9 23:7 33:20 38:1 67:22 15:12 18:1721:9 22:13 zack 68:2 71:3 73:11,20 80:18 67:16,24 68:1,7 80:13 9:12 11:14 12:8 14:23 92:3 115:14,21 81:10 82:6,7 83:13 84:2,18 16:12 28:17 35:6 36:12 we've 90:21 100:13 101:14,25 37:3 39:14 49:2 50:19 52:6 34:1569:19 105:6 119:2 102:11,23 111:15 53:12 63:16 95:11,24,25 wheeler workplace zack's 19:21 19:12 56:22 28:12,1331:17 whereof works zero 122:15 84:8,9 57:18 Kelly, R. Emmet M.D. (fmr Mons Med Dir) in BROWN Volume 4 LEXOLDMONOQ6941