Document zoX2y4g6r6drjdOrJqdEELY4B

Hicks, et al. v. ACandS,'Inc., et al. 6/1/01 Paul L. LeCour Page 150 Page 152 1 shears off ihe lining. 2 Q. Those brake shoes that go to the chopper do 3 not go to the burner? 4 A. Do not go to the burner. 5 Q. So the chopper, again, is after the brake shoe 6 . has been used ind is coming back to the plant for T . retnanufacturing? 8 A. Yes. 9 Q. Why would the asbestos levels be in excess of ' 10 recommended amounts in the chopper area? 11 A,' Because the way in which the lining is 12 removed; It breaks It up, chops It up. Again, t made 13 improvements in that area. We had vacuuming units there 14 .to begin with. 13 To correct both areas, we started wetting them 16 down, and that solved Ihe problem, because the way in 17 which'the. lining was coming off of Ihe shoe, removing 18 it, you were actually fracturing it. (9 Q. So this is a process. When you say you made 20 improvements, this is a process ihal started with 21 feedback from your insurance company as early as 1971 . 22 and was continuing on through 199 T? 23 A. Yes. 2< Q. And each year or each report, there would be 23 some changes or efforts made to address problems that 1 ihe levels changed dramatically over ihe 2 20 years. 3 Q. (8y Mr. Dumler) You can answer. 4 MR. RJLEY: 1 objecl lo the form of the 3 question. You'can rephrase the question. 6 Q. (By Mr. Dumler) Well, I'm going to let my 7 question stand. Ifyou can answer it, you can answer 8 il. `. 9 A. We made changes. 1]iif where we made the 10 changes was o( on the output, it was on the input. So 11 if was basically the beginning uf the process. It had . .12 nothing to do*-- where wc made changes had nothing to do 13 with the end product being boxed going back out to the 14 customer. Where \re made the changes was at the. IS beginning of removing of the product or removing of . 16 the friction material. 17 (Plaintiffs' Exhibit LeCour 34 was marked.) 18 Q. (By Mr. Dumler) I'll give you whet's been 19 marked as Exhibit 34 and ask you if you can identify 20. that for me? 21 A. It's an Engineering Report -- 22 MR. RILEY: Wait a minute. 23 A. (Continued) -- Ccnuine Parts Company, Rayloc 24 Division, Hancock, Maryland, January 23at, 1992, 23 prepared by Travelers and David NV. Classman, who was ' Page .151 Page 153 I came up 2 MR. RJLEY: Maybe. 3 Q. (By'Mr. Dumler) - if there was a problem 4 that came up. 5 To the extent that (here was s problem in 6 these documents, we at Rayloc, you at Rayloc, made 7 some efforts to change the procedures that you were 8 using? 9 " A. Absolutely, yes. 10 Q. Okay. So by 1991, you had 20 years of having It your insurance company provide you feedback and make 12 changes to various products, but still there were levels 13 in excess of recommended amounts; is that correct? 14 MR. RJLEY: Objection to the form of ihe IJ question. You said "products" instead'of 16 "processes." 17 Can you read.il back for him so he could IS hear it? 19 MR. DUMLER: I'll rephrase it. 20 Q. (By Mr. Dumler) Are you saying that 20 years , 21 after your first insurance company sent air sampling, 22 it was still necessary for you to make changes in your 23 processes to ensure that there were not exposures to 24 asbestos in excess of recommended levels? 25 MR. RILEY: I'll object to (hat. because l with the Environmental Service Unit. .. 2 Q. Are you familiar with that document? 3 A. No, I'm not. 4' Q. You did not receive a copy ofthat document 5 when il come? 6 A. No, 1 did not. 7 Q. Did anyone advise you of the results of ihal 8. study?' 9 A. No, they did not. 10 Q. Do you have an understanding of why a variety 11 of studies done by Tra velers at your manufacturing 12 operation showed impermissible levels of exposure lo 13 asbestos? 14 A. No, I do not. 15 Q. Do you have any idea as to whether or noi it 16 was the particular equipment that was being used, as 17 opposed to other problems? Do you have any reason or 18 understanding of why, over time, various air sampling 19 came back showing that there was an impermissible 20 exposure level? 21 A. If the laws changed, that could be one 22 incident, where prior to the change in law, what we had 23 in place was sufficient. In other cases, it was the 24 equipment itself. 25 Q. At any time during your employment at Genuine . WHEELER REPORTING COMPANY, INC..-404-35V-4577 39 (Pages 150 to 153)