Document wg89dY5V2E3jnwRDBkveXO9gV

Page 335 Page 337 ! 1 evidence shows. But you are going to have the 1 summarized the results for Owens-Illinois. 2 evidence back in that jury room to look at. 2 Now, Saranac did not expose these laboratory 3 You are going to have the benefit of the 3 animals to five million particles per cubic foot of 4 documents that Mr. Shellenberger talked about, and you 4 air, the standard that we have been talking about. 5 are going to have the benefit of the testimony of the 6 industrial hygienist who worked for Owens-Illinois, 7 Mr. Hazard. 5 Instead, they exposed the animals to 120 6 million particles and up to 200 million particles per j 7 cubic foot, and they did it 24 hours a day, five and a j 8 And he is going to be able to tell you - 8 half days a week. They overexposed the animals. 9 and, unfortunately, it has to be through deposition, 9 Saranac updated Owens-Illinois as to the 10 because all of this happened a lot of years ago, and 10 results of the studies. And you are going to see the 11 Mr. Hazard is deceased - to explain to you what 11 documents. 12 Owens-Illinois did with the material that it received 12 During the first three years, all of the 13 and what it thought about it. 13 tests were negative. Owens-Illinois was advised, and 14 I want to take a few minutes to talk to you 14 everything is going well. 15 about the Saranac Laboratory. It was the preeminent 15 The fifth year into the study, Owens- 16 testing facility in the 1940s and the 1950s. 16 Illinois was advised that, under these test 17 What Owens-Illinois did was, it hired it. 17 conditions, the extremely high concentrations of 18 And it said, Saranac, can you help us out here? Can 18 asbestos dusts, mild fibrosis was induced in one of 19 you test our product? 19 the three species of animals that were being tested. 20 Why did we do that? Because Kaylo contained 20 As a result of that, at that time, 21 two raw ingredients, asbestos and silica. And there 21 Owens-Illinois took certain actions. It hired Saranac Page 336 Page 338 1 was a lot of concern back then about silica and 1 to come to their manufacturing facilities and do test 2 silicosis and its ability to cause disease. So can 2 measurements of the workers there and take X-rays of 3 you go ahead and test this product and give us the 3 their workers to see whether or not there was any 4 results. 4 fibrosis showing up on the people working in the 5 Owens-Illinois was familiar with the silica 5 manufacturing plant with the pure raw asbestos. 6 because of its experience in the glass industry. 6 No cases of asbestosis were found in our 7 Silica is one of the ingredients that is used to make 7 employees. No workers' compensation claims were filed 8 glass. 8 by our employees during the time that we manufactured 9 They are aware of TLVs also because of their 9 Kaylo. 10 experience in the glass industry. And as I told you, 10 We had no communication or correspondence 11 there was a TLV for asbestos that Owens-Illinois knew 11 from anyone using Kaylo in the field that said, dear, 12 about. So it did the prudent, responsible thing and 12 Owens-Illinois, I am using your product, and I think I 13 had the Kaylo tested. 13 am sick. 14 Now, Saranac didn't laugh at Owens-Illinois 14 So when all of the tests were done, what was 15 in 1943 and say, what are you hiring us to do this 15 Owens-Illinois told? Keep the exposures below the 16 for? Everybody knows everything there is about 16 then accepted TLV, and you will provide a safe working 17 asbestos. They didn't say that. 17 environment. 18 They developed tests and did them for the 18 Nowhere in the report to Owens-Illinois does 19 company. And from 1943 up through 1952 when they 19 it say, Kaylo causes cancer. Not one of the animals 20 issued their final report, Saranac designed and 20 developed cancer. 21 performed a series of animal inhalation tests and 21 Nowhere in the report was Owens-Illinois 47 (Pages 335 to 338)