Document x15X2VkMm1mj6vpXp3XypVmx0

FILE NAME: Chrysler (CHR) DATE: 1992 Sept 4 DOC#: CHR089 DOCUMENT DESCRIPTION: Legal - Deposition of William Watt with Attached Memo - 1986 Feb 5 w iM a mams a c . r c . n r u K o o n u h l n m t m a m i i <c>m m i c i i <#*h * * * o t i *2 0 44 AFFIDAVIT OF WILLIAM WATT STATE OF MICHIGAN J )5S COUNTY OF WAYNE ) william watt, being first duly sworn on oath, deposes and states: 1. I am a Manager of the Industrial Hygiene and Toxicology Department at Chrysler Corporation and I am authorized to make this Affidavit on its behalf. 2. As used in the Affidavit, the term "toxic" refers to a chemical's capacity to cause injury to humans. The term "hazard" refers to the possibility or probability that injury to employees may result from- the handling or use of asbestos under ,certain conditions. 3. I am informed and believe that during the time period from October 1, 1978 to February 5, 1986, Chrysler Corpo ration f"Chrysler"5, purchased from the defendants A.T. Callas and Alma Products a product called "Calidria", as indicated by the attached Exhibit 1, letter of Fred Roskopp, dated February 5, 1986. Calidria contained asbestos and was used as a thixotropic : agent for automotive sealants at the Chrysler Chemical Plant. \ 4. I have been assigned to the Industrial Hygiene and [ Toxicology Department during zhe period of August, 1977 to the [ present. j* ' 5. h The Industrial Hygiene and Toxicology Department was responsible fcr anticipating, recognizing, evaluating and DC 5276 recommending procedures co control environmental factors or stresses that could cause injur/ to or impair the health of Chrysler employees who worked in the company's production facili ties. Prior to and since October 1, 1978, Chrysler employed numerous industrial hygienists, toxicologists, medical personnel, and other employees with similar functions, whose responsibili ties included the evaluation and prevention of potential health hazards associated with the use of chemicals including asbestos, In the workplace, Including the Chrysler Chemical Plant. 6. At least since October 1, 1978, one category of environmental factors cf primary concern to Chrysler was chemi cals, including asbestos, used in the production process, because the company recognized that hazards to its employees could arise as a result of over exposure -- to toxic substances used in the production process. 7. As part of its evaluation of the potential health hazards associated with the use of asbestos in its facilities during the October 1, 1978 to February 5, 1986 time period, Chrysler employees assigned to th Industrial Hygiene and Toxi cology Department routinely reviewed literature concernine asbestos' toxic properties and potential hazards, and the methods and practices necessary to safeguard employees from such poten tial hazards. 8. Based upon their evaluation of the wo environment at Chrysler's production facilities, including tht Chrysler Chemical Plant, and their review of pertinent litera- ture, attendance at various seminars and programs, and their owi 'Min tifiti tinn m in t i f i t i DC 5277 Wt* * MARbAc. c c . u n i t t o o n u rn . a u ii-o m a , OiT.iOtj. h icu iua n <*i z * t a m 2 0043 jtraining and education, prior to October i, 1978, Chrysler's | industrial hygienists and toxicologists knew of asbestos1 toxic ,jproperties and the potential hazards associated with the use .of !asbestos. Chrysler knew that asbestos was a toxic substance | that posed a potential hazard i n "the event that its employees \ inhaled particulate matter ii.e., dusts), that contained asbesjtos. Chrysler had this knowledge prior to and during the October 1, 1978 to February 5, 1986 time period and utilized its knowl edge in an effort to eliminate the hazards posed by worker exposure to asbestos through the use of certain engineering controls, including designing its production machinery to control the airborne concentration of asbestos and properly maintaining * its production machinery. Chrysler also attempted to eliminate the hazards posed by worker exposure to asbestos by requiring certain general control methods, including the following: a. implementing procedures intended to minimize employee exposure to asbestos; b. utilizing general and local exhaust and ventila tion systems intended to remove from the work environment potentially hazardous levels of toxic materials, including asbestos; c. providing respiratory and other protection for its employees; d. implementing housekeeping rules intended to minimize employee exposure to asbestos; e. utilizing medical screening, surveillance pro grams, and pulmonary function testing of employees working in or near areas utilizing asbestos, and a medical screening program intended to prevent employees with existing medical problems from being assigned to work areas using; DC 5278 I* . H O O H U H I. B U I^O lN C . U fc tllO U , M IC tt^ A N 4 U / 2 . ( 1 3 , 0 1 4 o M j y vi ) 4m training and educating supervisors and worker j concerning the potential hazards associated wit. exposure to asbestos; and <? routinely conducting industrial hygiene surveys. ; 9. Chrysler is in compliance with the Federal Hazard Communication Act which was designed to inform employees of the *1 ;;potential hazards of exposure to potentially hazardous materials ,isuch as asbestos and the precautions necessary to prevent such hazards. 10. Prior to and during the period October 1, 1973 to February 5, 1336 Chrysler conducted air monitoring studies at the Chrysler Chemical Plant. The purpose of such studies was tc measure the levels, if any, of asbestos present in the ambient air in various work areas. 11. As evidenced by the foregoing, prior to and during the period October 1, 1978 to February 5, 1986, Chrysler knew that asbestos was a toxic chemical that posed potential hazarcs to its employees and took affirmative steps to protect its employees from such hazards, including review of available literature, implementation of engineering systems to control tne potential for exposure to asbestos, instituting medical screening jj and surveillance programs, developing and disseminating safety ! literature to management and employees, and performing routine 1 air monitoring to protect employees from overexposure to asbes| . tos. i I 12. This Affidavit is based upon my personal knowledge \ and my review cf Chrysler Corporation's records. If I am sworn Wit** * - 4 - DC 5279 as a witness, I can testify competently ~-e -acrs contained jh e r e i n . .fa t* - William Watt Manager of the Industrial Hygiene and Toxicology Department, Chrysler Corporation j .jSworn to^and subscribed to before me 1this /*Mav of u& uJL 1992: S XSsis%*cJZ' |Notary Public * 5 ....______________ County, Michigan 2My Commission Expires: V- rr t a * ! {_ - 5 * DC 5280 Qtrtr. o rCOU*l d It. SS fAf CHRYSL CORPORA! February 5, 1986 Joseph V. Brennan,* Esquire SULLIVAN, WARD & BONE 220 W* Congress - 5th Floor Detroit, HI 48226 Re: ASBESTOS SUPPLIERS TO CHRYSLER CORPORATION Dear Joe: The following list of data designates the part number, supplier's, and time period in which. Chrysler Chemical purchased Asbestos: PRODUCT IDENTIFICATION /a^Jn3mrKtAmr(rwcron SUPPLIER CHRYSLER* S BASE fri osttTnn F445 Asbestos 7D Asbestos Corp. Ltd 10-1-67 to 8-1-7: F448 Asbestos SK04 International Fibers Manville Bldg* Materials J*M Asbestos Sales 6-1-59 to 1-1-80 1-1-80 to 4-1-84 4-1-84 to Presen FX423 R6244 Union Carbide Metals Div* A.T. Callas Alma Products 10-1-70 to 10-110-1-78 to 1-1-8 1-1-86 to Presen E1488 HG144 Union Carbide Metals Div* A.T. Callas Alma Products 10-1-70 to 10-110-1-78 to 1-1-8 1-1-86 to Presen X have also been advised that there is an additional firm whi Chrysler did purchase Asbestos from, that firm's name is Soeble Chemical Inc. If we can be of any further assistance, please don't ask* Very truly yours, FJR/26/las *0 SOX;H9.0Tft0tr. MICHIGAN*2#8 DC 5281