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BRAID 203 FLAX,LEAD WIRE, TALLOW/W, RED POLISHING COMPOUND , SQ, BRAID 304 FLAX, TALLOW/kAX, SURFACE GRAPHITE, SO.

This would lead to a reduction in Silicosis and improvement in haulage efficiency while leading to safer working conditions as "carry-back" cleaning will become unnecessary.

K&L GATES August 28,2008 Kfrkpatrick & Lockhart Preston Gates Ellis ilp A Deisiare IMled SaisEty partiBrsItfp One Newark Center, Tenth Floor Newark, NJ 07102-5285 t 973.848,4000 m.klgates.oom Mark D.

ICRC expressly objects to each and every discovery request to the extent that it seeks any information in those cases wherein a special appearance is pending for the reason that such discovery requests are not related to any special appearance motion or likely to lead to the discovery of evidence admissible in a special appearance hearing.

ABD00026412 Process Safety Institute A Division of ABS Consulting January 17, 2002 BUSINESS CONFIDENTIAL Mr Ben Drone Engineering Manager Georgia-Gulf Corporation P O Box 91 Aberdeen, MS 39730-0091 PHA LEADER AND PHA REVALIDATION TRAINING COURSE PROPOSAL PROP-128C-02 Ben, based on your discussion with Mr Mark Taylor, the Process Safety Institute (PSI) division of ABSG Consulting Inc , operating as ABS Consulting, is pleased to submit this proposal to provide process hazard analysis (PHA) leader and PHA revaluation training to Georgia-Gulf Corporation (GGC) personnel at the Aberdeen, Mississippi, facility These training services will include (1) mclass instruction by an experienced trainer, (2) notebook material describing how to organize and lead hazard and operability (HAZOP) analyses, what-if/checkhst analyses, and PHA revaluations, (3) practical, process-onented workshop problems, and (4) a copy of A Manager's Guide to Reducing Human Error We use a hands-on approach to training -- several practice sessions throughout each course will provide course attendees with expenence in leading and documenting a PHA This proposal includes course descriptions, instructor information, references, information on both the class size/schedule and opportunities to obtain PHA leader and/or PHA revalidator certification, course options and costs, and statements concerning liability and work acceptance COURSE DESCRIPTIONS PHA Leader Training Course As outlined m Attachment 1, the PSI training course for PHA leaders incorporates two proven teaching techniques (1) lectures on the mechanics of performing an analysis and (2) workshops in which attendees lead and document HAZOP and what-if/checkhst analyses In the lecture portions of the course, our instructor will descnbe the following 1 The concepts of risk assessment and process safety management (PSM) 2 How to organize a PHA 3 How to prepare for a PHA, including Collecting information Selecting team members Scheduling Dividing a process system into sections (nodes) for analysis 4 How to lead a PHA, including Assigning team member responsibilities Using the HAZOP analysis technique Using the what-if/checkhst analysis technique 0 ABSG Consulting Inc. 10301 Technology Drive Knoxville TN 37932-3392 USA Telephone (865)675-2580 Fax (865)671-5851 ABD00026413 BUSINESS CONFIDENTIAL Mr Ben Drone PHA LEADER AND PHA REVALIDATION TRAINING COURSE PROPOSAL Page 2 PROP-128C-02 Addressing facility/stationary source siting Addressing prior incidents Addressing human factors Conducting a qualitative consequence assessment Expediting an analysis Handling common meeting problems 5 How to document a PHA, including Descnbing elements of a PHA report Resolving action items Our training will address all of the OSHA requirements for PHAs described in paragraph (e) of 29 CFR 1910 119 and the EPA requirements described in 40 CFR 68, and we can modify it to include any GGC corporate requirements Some topics, such as facility/stationary source siting, are more suited to what-if/checklist analysis than to HAZOP analysis What-if/checklist analysis is also very effective in addressing process changes (for management of change) and in addressing the hazards of simpler, less hazardous systems (such as auxiliary process systems) during PHAs Therefore, we offer to teach your prospective leaders both the HAZOP and what-if/checklist techniques so they can optimize their PHA process Our training includes several ways that human factors can be considered during PHAs Most companies find this training extremely useful because many of their accidents/incidents involve human error, particularly during startup and shutdown procedures We explain how to use the HAZOP and what-if/checklist analyses techniques to identify potential human errors during batch and nonroutine operations and to eliminate their causes In the workshop portions of this course, attendees will lead what-if/checklist and HAZOP analyses of process systems Our instructor first descnbes the process to be analyzed (our first problem is usually a chlorine unloading system), then begins the meeting The instructor initially acts as the team leader and assigns the scnbe's duties (i e , taking extensive notes of the meeting) to one of the team members The duties of leader and scnbe are then rotated periodically to give each attendee experience in performing these functions As an alternative to our example problems, we invite GGC to supply information on two or three processes familiar to your personnel The class can perform reviews on these processes as part of the course We have found this training approach to be very effective because the attendees (1) generally know the system quite well and require little class time to leam the process and (2) are accomplishing productive work for GGC while learning the various techniques This approach also demonstrates how the analysis techniques can uncover process weaknesses in designs that have already undergone standard review by the company (When PSI's example problems are used, students sometimes rationalize that the error would have been caught by their company's standard review process, thereby failing to fully appreciate the value of PHAs) If GGC elects to provide m-house processes for review, we will need information on the processes no later than 5 working days before the course begins Process Safety Institute A Division of ABS Consulting ABD00026414 BUSINESS CONFIDENTIAL Mr Ben Drone PHA LEADER AND PHA REVALIDATION TRAINING COURSE PROPOSAL Page 3 PROP-128C-02 PHA Revalidation Training Course As outlined in Attachment 2, the PSI training course for PHA revaluation incorporates two proven teaching techniques (1) lectures on the mechanics of performing a revaluation and (2) workshops in which attendees practice their newly learned skills In the lecture portions of the course, our instructor will describe the following Information necessary to gather and evaluate for a PHA revaluation Factors to consider when determining an appropriate approach for PHA revalidations How to effectively address previous PHA deficiencies and process modifications Steps necessary to prepare for, conduct, and document PHA revaluations Our training will address all of the OSHA PSM requirements for PHA revalidations described in paragraph (e) of 29 CFR 1910 119 and the EPA nsk management program (RMP) requirements described m 40 CFR 68 We recommend that the participants in this course should have already been trained in leading PHAs (such as our basic PHA course descnbed previously, or another similar course) INSTRUCTORS Our instructors are internationally recognized experts m process safety management and process hazard analysis They are among the very best m the field because they combine complete theoretical understanding of hazard evaluation techniques with the experience necessary to discriminate between techniques that work only in theory and techniques that work in practice They also have well-documented industry experience, m fact, our instructors wrote the following two books for AIChE's Center for Chemical Process Safety Guidelines for Hazard Evaluation Procedures, Second Edition with Worked Examples (referenced in 29 CFR 1910 119) and the authoritative book on how to revalidate PHAs, entitled Revalidating Process Hazard Analyses If more than one instructor is required, the lead instructor will be assisted by other expenenced PHA leaders m the workshop sessions We can provide you with resumes of the proposed instructors) once you have selected course dates REFERENCES Our students and technical contacts repeatedly tell us that we offer the best PHA and revaluation training available Please contact any of the following persons who will attest to the value and quality of our services (Note: Many of these clients worked with us as JBF Associates, Inc.; the Risk & Reliability Division of ABS Group Inc.; and/or EQE International, Inc.)

Category or Generic Name LEAD COMPOUNDS SECTION 1.

Finally, please contact the attorneys who are the lead counsel in the Leroy Boehl and Malcolm Lee Murphy, Jr. cases to discuss how you would like to proceed.

A furniture stripping compound he had used contained methylene chloride, and, in retrospect, it was believed the patient had generated large quantities of methemoglobin over the course of the day, leading to his headache, which resolved as he sat waiting in the emergency room.

A furniture stripping compound he had used contained methylene chloride, and, in retrospect, it was believed the patient had generated large quantities of methemoglobin over the course of the day, leading to his headache, which resolved as he sat waiting in the emergency room.

s alleged liability in these cases renders Plaintiffs' Discovery as a whole irrelevant to the subject matter of these actions, and not reasonably calculated to lead to the discovery of admissible evidence. 5.

Crane Co. objects to the Discovery Requests to the extent they (1) are unduly burdensome and overbroad, and/or (2) seek information that is not relevant to this lawsuit or are not reasonably calculated to lead to the discovery of admissible evidence.

Model contract language Model Specifications for the Protection of Workers from Lead on Steel Structures.

Defendant objects to the discovery requests to the extent they seek information neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. 4.