Birk Paint allegedly exposed Milutin Suzberic to ultrahazardous lead during the course of his employment.

Inorganic Lead 1.

FROM GARY C.

The background level of airborne lead is high and there is an excessive level of lead during a lead production run.

Lead handling by the 9" A-line operator needs to be improved.

But, one thing that could lead to more litigation, according to Mr.

Location 6 was a major distribution line leading from a ground 640 S T0044142 h flow ) *l!

Lead Operator Duties 3.

.- Figure Effect of Lining Pressure Distribution on Brake 1 Effectiveness for a Leading Shoe Drum Brake .......- Figure Fade Characteristics of Good Friction Materials . 2...

The volume of lead-chroma

As a starting point, the Department of Safety Assessment (DOSA) ;3 evaluating the specific reproductive hazards associated with the chemicals we use which contain barium, GGC 000048 Page 2 REPRODUCTIVE HAZARDS November 3, I960 boron, cadmium, lead, phthalat.es, and cyclohexanone.

Answer: Raymark objects to this interrogatory because is is overly broad and seeks information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

John Copeland lead Engineer November 10, 1980 ,b)-~-Deane F.

John Copeland Lead Engineer November 10, 1980 Deane F.

See Lead Industries Ass'n v.