Abex also objects to this interrogatory on the ground that it purports to shift the burden of establishing product identification from plaintiffs to Abex Abex further objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the grounds 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 m these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex also objects to this interrogatory on the ground that it assumes the truth of matters not estabhshed or matters not m evidence Subject to and without waiving these objections, insofar as Abex understands this interrogatory, and upon information and belief, some Abex products may have undergone changes after sale by Abex and prior to reaching the ultimate end-user.

c\ \ Fullersper f} v Varnish \ Clear"' \ \V-W5 first fflEPROOUCEB AT THE NATIONAL ARCHIVES SOUTH S/\N I-RAJMC5SCQ Wood Oil Superb Linseed Oil Beckacite 1C01 V-397 Checking Oil Mineral Spirits V-423 Lead Cobalt V-424 Lead Manganese Calculated Yield Manufacturing Loss 3.5 Actual Yield Lbs. 710 80 100 120 450 13.8 _5A Yield fa &!.

He nas a blood pressure central cyanosis, papilledema and retinal he lead in the urine.

Kehoe: Would you kindly send information concerning lead poisoning to the writer.

Gerlach and Don Fowler of the Lead Industries Association.

-PT.J PLANT EHERGEHCIES/ALARKS SAFnr DIRECTOR - KEY ELEMENTS PLANT MANAGER - OPERATIONS INTRO VC8 SAFETY LEAS SAFETY TOXIC SUBSTANCES CONTROL ACT PUNT SAFETY GUIDELINES DuPOKMO EMPLOYEE SAFETY TRAINING LIFTING - 8AOSHOOL FILM KA1A88 COMMUNICATION-PLANT PROGRAM SAFETY-A STATE OF KUOKSIl VCK l LEAD DOSIKETAY FIRST AIO ORIENTATION SECURITY PICTURES `SAFETY EflUIPKEXT ISSUE SCOTT AIR PAK FRESH AIR/3M AIR HAT FORK LIFT - CLASSROOM FORK LIFT - FIELD t LICENSE EQUIPMENT ENTRY - FILM PUKT EKTRT V LOCKOUT PROCEDURE LOOK BEFORE YOU REACH' -SLIDE SHQN DON'T PUSH YOUR LUCK-FILM SAFETY LOCK ISSUE KAKE MEETINGS KEAN GQKEIHIKG-SSI2 THE CONVINCES-SLIDE SKOlf LIKE BREAKIKG-fILK PLANT INTRODUCTION SHON CONIRACTOR VCK HEALTH CONTRACTOR LEAD HEALTH PLANT SAFETY GUIDELINES CONTRACTOR HAIARQ'COKKUKICATIOX BAOGE-KAKE/LQG/UPDATE GUARD LIST VISTA NON-PUNT CONTRACT

The loss of the nonml fat* and oils of the skin leads?

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.

Saar 3ir: TheXational Paint Oil and Varnish Association runs a trad a marie bureau and I roglatarad tha word AHACOHDA with it, for white lead, when we first atarted bu8ineea, nearly three years ago* Just now howarer on looking over the April Bulletin of the S*P,0*h V.Aean I notloe that Qlldds* has registered the word, for "White lead, paste, dry and liquid"* Phis was certainly done without any consultation with as or notlee to ne.

Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to Abex Abex objects to this interrogatory to the extent it purports to seek information or matenals regarding time penods and products that are not at issue in these cases, on the ground that such information or matenals lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence Abex also objects to this interrogatory on the grounds that the information or matenals it purports to seek otherwise lack relevance to the issues ansing m these cases and are not reasonably calculated to lead to the discovery of admissible evidence.

PEL % VCM Lead Total Particulates 92 97 18 95 6 100 Overexposures Job Class Exposure General Mechanic 1.1** ppm, VCM General Mechanic 2.0** ppm, VCM Yard Operator 4.6* ppm, VCM Color Weigh Compounder 56.6* mi^rogram lead/m PEL Overexposures No. % 33 15 00 Source Employee overexposed while welding cracks in the dry blend "gump" screener bowl.

Lead 4 C o lo r Worka Hoporc o f R aceiota______________ Erprc.f f / ' /?

Abex also objects to this interrogatory on the grounds that the information or materials it purports to seek lack relevance to the issues arising in these cases and are not calculated to lead to the discovery of admissible evidence.

c\ \ Fullersper f} v Varnish \ Clear"' \ \V-W5 first fflEPROOUCEB AT THE NATIONAL ARCHIVES SOUTH S/\N I-RAJMC5SCQ Wood Oil Superb Linseed Oil Beckacite 1C01 V-397 Checking Oil Mineral Spirits V-423 Lead Cobalt V-424 Lead Manganese Calculated Yield Manufacturing Loss 3.5 Actual Yield Lbs. 710 80 100 120 450 13.8 _5A Yield fa &!.

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.