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.

Vista Chemical Company / 15990 North Barker's Landing Road Post Office Box 19029 Houston, Texas 77224 Phone (713) 531-3200 February 2, 1989 'i Ms.

See Lead Industries Ass'n v.

John Copeland Lead Engineer November 10, 1980 Deane F.

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.

See Lead Industries Ass'n v.

PLAINTIFF'S EXHIBIT DUP-1987 QUALITATIVE VS.

MANAGEMENT ASSUMES THE RESPONSI BILITY FOR SAFETY AND HEALTH WHICH IS MAINTAINED THROUGH EFFECTIVE PLANNING, ORGANIZATION, LEADING AND CONTROLLING AT EACH LEVEL OF SUPERVISION.

He also took the lead in expand not less, regulation ing the agency's policy of trying to ami cably settle cases with cited employers rather than go through lengthy and costly litigation.

Inhaled asbestos causes chronic lung diseases that impair breathing and can lead to lung cancer decades after the initial exposure, scienlists say.

MANAGEMENT ASSUMES THE RESPONSI BILITY FOR SAFETY AND HEALTH WHICH IS MAINTAINED THROUGH EFFECTIVE PLANNING, ORGANIZATION, LEADING AND CONTROLLING AT EACH LEVEL OF SUPERVISION.

MANAGEMENT ASSUMES THE RESPONSI BILITY FOR SAFETY AND HEALTH WHICH IS MAINTAINED THROUGH EFFECTIVE PLANNING, ORGANIZATION, LEADING AND CONTROLLING AT EACH LEVEL OF SUPERVISION.

Lead levels in blood samples taken from Compound West employees remain low, which indicates that long term lead exposure is not a serious problem.

This is different from the medical examination requirements in the lead and coke oven emission standards, both of which use 30 days of exposure as the criterion.

. * , 038 Not )ated Illumination 038 Information: Study of occupa- tional Safety & Health 1979 1979 Folder A 1977 1979 Folder B 038 1978 1978 Occupational Exposure to Lead (2) (3) (4) v^-v 038 K- 038 1977 1977 1977 1978 Occupational Epidemiology Carcinogens, Toxic Substances (5) (6) IiMmb r.T;.r 1 lib.