All sales bids for block insulation, gaskets, packing, pipe covering or insulation, millboard, raw asbestos, asbestos spray, rope, refractory, and other thermal insulation asbestos-containing materials specified for use or intended to be installed on each of Defendant's boilers present at Plaintiffs job sites. 6.

All sales bids for block insulation, gaskets, packing, pipe covering or insulation, millboard, raw asbestos, asbestos spray, rope, refractory, and other thermal insulation asbestos-containing materials specified for use or intended to be installed on each of Defendant's boilers present at Plaintiffs job sites. 6.

Corporations generally have the best information about their own products, and are usually aware of the safety risks involved.

If, after answering or producing documents, you obtain or become aware of any further responsive information or document, you are to so notify plaintiffs and supplement your responses hereto.

Washington, D.C. 20460-i^ This letter, submitted on behalf of our client, the Asbestos Information Association/North America (AIA/NA), supplements our earlier letters and calls to your attention further developments since we met with you and Deputy Admin istrator Aim last spring.

Mineral Wool Institute d Industrial Mineral Insulation Manufacturers Institute e. f fifi fl fifi fl i j k Magnesia Silica Insulation Manufacturers Institute National Insulation Manufacturers Association NIMA Thermal Insulation Manufacturers Association TIMA Asbestos Information Association AIA Quebec Asbestos Mining Association QAMA National Safety Council Asbestos Cement Producers Association Refractories Institute m | Chemical Manufacturers Association and its predecessor the Manufacturing Chemist Association n any other organization or associations of manufacturers asbestos insulation contractors miners distributors importers labelers suppliers and sellers of products containing asbestos fibers 14 ANSWER a through m John Crane Inc. was not a member n John Crane Inc. was a member of the Mechanical Packing Association now known as the Fluid Sealing Association from the 1950's until approximately 1970.

I have excerpted some of the more significant parts of the OSHA proposed standard (from a covering letter from the Asbestos Information Association): 1.

I have excerpted some of the more significant parts of the OSHA proposed standard (from a covering letter from the Asbestos Information Association): 1.

Any information produced in response hereto is produced expressly subject to any objections contained herein and is produced without in any way waiving or intending to waive any objections that Answering Defendant may have with respect to the subsequent use of such information and specifically reserves a All questions as to admissibility of any and all such information in whole or in part or of the subject matter thereof b The right to object to the use of any such information in whole or in part or the subject matter covered thereby in any subsequent step or proceeding in this litigation and c The right to object to any and all grounds at any time to interrogatories or other discovery procedures involving or related to the subject matter of the information sought by plaintiffs 3 Answering defendant objects to each and every discovery request to the extent it seeks information that is equally available to or already in the possession of plaintiffs and the burden on plaintiffs to obtain the requested information is no greater than the burden on these defendants -2- BP_FR_00422969 4.

Asbestos almost exclusively chrysotile which in in has been used for decades in brakes was detected in 21 of the locations The amount of asbestos in the dust ranged from 2.26 percent to 63.8 percent See also Cancer victim changed his own brakes for years Asbestos miners producers have fought bans Nation's mechanics at risk from asbestos A mechanic's epitaph Someone has to warn these kids Graphic 60k Asbestos test results Personnel working for the U.S.

Tangible items containing information about the type, identity, brand, description and quantity of goods containing asbestos or vermiculite to any entity identified by you in RESPONSE to paragraph number 3, above.

Any pertinent information which the employee or premises information can be said to reflect can be requested directly without requesting the irrelevant and immaterial information or documentation about employees or premises. 2 INTERROGATORIES INTERROGATORY NO. 1.

Any pertinent information which the employee or premises information can be said to reflect can be requested directly without requesting the irrelevant and immaterial information or documentation about employees or premises. 2 INTERROGATORIES INTERROGATORY NO.

Chandler...........................................................................13 7 Witness' Signature Page.................................................................................333 8 Reporter's Certificate.................................................................................... 334 9 REQUESTED DOCUMENTS/INFORMATION 10 Number Description Pg/Ln 11 (None) 12 CERTIFIED QUESTIONS 13 Number Pg/Ln 14 Certified Question 1 31/9 15 EXHIBIT INDEX 16 Exhibit No.

I was 8 surprised. 9 (Swetonic Exhibit 2-a , laminated card 10 called "Asbestos and Health Questions and 11 Answers," marked for identification, as of 12 this date.) 13 (Swetonic Exhibit 2-B, brochure 14 e