Document wDNN7X1rNqx4EMX6Lz15DwY9V
FILE NAME: Union Carbide (UC)
DATE: 1984 July 24
DOC#: UC061
DOCUMENT DESCRIPTION: Legal - Affidavit of John Myers with Barry Castleman Notes
AFFIDAVIT OF JOHN L . MYERS
STATE OF CALIFORNIA ) )
COUNTY OF MONTEREY )
I,
John L. Myers, having been duly sworn and being
of legal age depose and state as follows:
1. I have been involved in various aspects of Union Carbide Corporation's "Calidria" asbestos operations since 1966. From 1970 until 1981, I was Marketing ManagerAsbestos of the Metals Division of Union Carbide Corporation ("Union Carbide"). From 1981 until April 1, 1984, I served as Product and Production Manager-Asbestos of the Metals Division of Union Carbide.
2. Effective April 1, 1984, the asbestos operations of Union Carbide were transferred to Calidria Corporation, a wholly-owned subsidiary of Union Carbide which was formed on that date. I now hold the position of Product and Production Manager for Calidria Corporation. ,
3. The records of sales of "Calidria" asbestos are maintained at our facility in King City, California, where I have my office. I am personally familiar with the records of sales of "Calidria" asbestos fiber, the identity of entities purchasing "Calidria" asbestos fiber and the uses to which "Calidria" asbestos is put; and, if called as a witness, I could and would competently testify thereto.
4. My eighteen years in Union Carbide's asbestos operation allow me to state that Union Carbide did not enter into the business of mining, milling and selling asbestos fiber until 1963. Since 1963 Union Carbide has mined, milled and sold raw chrysotile asbestos fiber under the trade name
"Calidr ia".
5. The "Calidria" brand of asbestos fibers is sold to manufacturers who use such material in other products as a filler, reinforcer, opacifier, thixotrope or thickener. Be cause of the short length of the "Calidria" asbestos fibers, they are not marketed nor are they suitable for use in heat or frost (cold) insulation materials.
6.
Union Carbide has never manufactured or
heat or frost (cold) asbestos-containing insu1ation materia 1s
for the construction, shipbuilding or building trades. The
only asbestos-containing material used for insulation purposes
which Union Carbide has ever sold was the BAKELITE brand of
phenolic molding compounds. Such compounds were sold to ma n u
facturers in granular form and molded into a hard, solid form
for electrical and electronic parts such as switches, switch
boxes, radios, plug-in receptacles or similar products. In
the form in which it was sold to the manufacturers of these
products, the asbestos in the BAKELITE material was encapsu
lated and hence not respirable.
sold
FURTHER THIS DEPONENT SAYETH NOT.
John. Myers
subscribed and sworn to before me this 1984 .
_ day of
My commission expires: My address is:
Notary Pubiic
______________
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