. % VCM Lead Total Particulates 80 16 9 98.8 94.1 100.1 > PEL (OVEREXPOSURES) NO.

The amount of barium and lead landfilled was reduced due to this change.

Cohen VVV 000000624 ALFOL 4 ALCOHOL AQUEOUS ALUMINUM CHLORIDE BLANE FVC COMPOUNDS BUTADIENE CONCENTRATE CATAPAL G AND GST ALUMINA EDC/VCM HEAVY ENDS ETHYLENE ETHYLENE DICHLORIDE (EDC) HEAVY AROMATIC DISTILLATE (HAD) LIGHT AROMATIC CONCENTRATE (LAC) MURIATIC ACID PREMIERE PVC COMPOUNDS ROTOFLEX RIGID COMPOUNDS (LEAD STABILIZED) RIGID DRYBLENDS (LEAD STABILIZED) PROPYLENE SPENT SULFURIC ACID VINYL CHLORIDE VINYL CHLORIDE LIGHT ENDS VISTA PVC COMPOUNDS VISTA 610 PLASTICIZER OOoo

Plaintiff's decedent, for example, ceased working at Goodrich in 1974 and no information obtained by any representative of Goodrich thereafter could possibly* lead to the discovery of information relevant to the subject matter of the complaint herein. 2.

Potter Lead Project Engineer RSP:ams 10000097

Abex further objects to this interrogatory on the ground that the information it seeks otherwise lacks relevance to the issues arising in this case, and is not reasonably calculated to lead to the discovery of admissible evidence.

Drumwright, M.D. - Houston VAB.0001178063 ABERDEEN CHEMICAL PLANT CHEMICAL DOSIMETRY TRENDS f b 100 Lead 0 IOC Total Particulates 0 VAB.0001178064

The Institute enjoys a reputation as one of the leading institutions in these fields.

. *" Lead & copied to ^ 30th May, 1931.

March - Health Training This program will cover-the health effects of VCM, lead, and noise and will be conducted by supervisors.

Abex also objects to this interrogatory on the ground that it purports to shift the - burden of establishing causation from plaintiffs to Abex Abex further objects to this interrogatory to the extent it purports to seek information or materials regarding time penods and products that are not at issue in these cases, on the ground that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex also objects to this interrogatory on the grounds that it assumes the truth of matters not established or matters not in evidence Abex further objects to this interrogatory on the ground that it seeks to impose upon Abex a legal duty or obligation to which it was not subject.

There is a similar provision in the lead standard for employees whose exposure exceeds the action level for more than 30 days per year.

. % VCM --^-Lead Total Particulates 87 30 5 100.0 96.6 100.0 > PEL (OVEREXPOSURES) NO, % 0 0.0 1 3.2 0 0.0 Overexposures JOB CLASS Compound Line Operator EXPOSURE 35 .9 Micrograms Lead per M SOURCE Employee overexposed while operating Line I mill during a period of high dusting.

Legendre- Ponca City December 3, 1982 ALL SAMPLE RESULTS: Chemical VCM Lead Antimony Total Particulates OVEREXPOSURES: ^ PEL No

As of August 22nd, 1985, we have one employee with a six month r. blood lead average of 50 or above.