Document zzkN5BJ42eZV532Lvj83DdRqR

05 I 0 I O''" 1 4.07 Did defendant ever institute a safety program other 2; than pulmonary function tests and x-ray exams for its 3 I asbestos-exposed workers? 4 .ANSWER; S. K. Wellman has taken air samples in its facilities since the mid-1970s. 3 por a time in the 1970s and possibly early 1980s when materials of unknown identity jj were being subject to certain processes in its laboratory, S. K. Wellman made 6 j respirators available to laboratory errplcyees. II 7! i 8 10 , i 11 4.08 If the answer to the foregoing interrogatories is in 12 : the affirmative, state: 13 (a) The nature of such program(s); 14 15 (b) Whether such program was optional or mandatory; if mandatory, when it became so; 16 ; (c) The location(s) of such program(s); 17 18 ri (d) The date of service of such program(s); (e) If any of the program(s) have undergone 19 i! j! modification, the nature and dates of such modification; 20 'j (f) The custodian (by name, address and position) of 21 )' * records of such x-ray test program(s); (g) The highest level of management (by name, address and position) who participated in the decision to institute such program(s). 24 25 26 PLAINTIFF'S FIRST INTERROGS, ETC. - 74 I!,