INTERROGATORY NO. 3: Please list all trade organizations, trade associations and any other industry-wide groups to which you belong(ed) (specifically including but not limited to the following groups: American Hygiene Foundation, Industrial Hygiene Foundation, Chemical Manufacturer's Association, American Chemical Council, American Petroleum Institute, Texas Chemical Council, Ohio Safety Congress, National Safety Council, Asbestos Information Association, Industrial Medical Association) in which information or documents relating to asbestos was discussed, disseminated, or published (including, but not limited to, the effects of exposure to asbestos, industrial hygiene measures relating to asbestos dust, and medical information or research relating to asbestos or its effects on animals or humans, populations at risk).

The words "trade organization," or "trade association" mean any organizations or associations of business or industrial entities that are associated and/or meet for the purpose of achieving common goals and/or exchanging information related to common needs or interests, and/or learning information or facts ofinterest to the various members ofthe organization or association. 13.

Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs for all associated business entities that were involved, in any manner, in the sale, manufacture, distribution, and/or mining of asbestos and/or asbestos containing products.

The words "trade organization," or "trade association" mean any organization or associations of business or industrial entities that are associated and/or meet for the purpose of achieving common goals and/or exchanging information related to common needs or interests, and/or learning information or facts of interest to the various members of the organization or association. 13.

information from the manufacturer, the specific source of asbestos with dates: According to information from the manufacturer, Canada.

Consequently, emphasizes the production processes and emissions associated with brake linings, placing lesser emphasis on other products in the friction ' materials group. 82 TABLE 19.

Paul Gross is circulated to you for advance information.

Beazer East objects to each interrogatory to the extent that the request seeks information unrelated to any of the plaintiffs in the Butler County, Ohio, asbestos litigation, in that such a request is overbroad, and the information sought is not reasonably calculated to lead to the discovery of admissible evidence. 4.

Uniroyal objects to any interrogatory which seeks information about any asbestos containing products it may have manufactured or sold because the plaintiffs have not produced any evidence of exposure to any Uniroyal or United States Rubber Company asbestos containing products. .

The present OSHA Asbestos Standard discussed in this booklet became effective July 7 1972 Thorough understanding of the standard is important to management of any company utilizing asbestos in its manufacturing or processing operations The work practices on the following pages have been prepared by the Standards and Technical Committee of the Asbestos Information Association America They are intended as general guidance for safe and clean workplace conditions in keeping with the spirit and intent of the OSHA Standard for Occupational Exposure to Asbestos Dust : These practices have been developed through careful study and consultation and are recommended as good procedure It is recognized that manufacturing conditions vary Implementation of the practices contained herein cannot be considered as a guarantee of OSHA compliance Where there may be a question of compliance OSHA personnel should be consulted A proposed revision to the OSHA Asbestos Standard was published in the Federal Register on October 9 1975.

Beazer East objects to each interrogatory to the extent that the request seeks information unrelated to any of the plaintiffs in the Butler County, Ohio, asbestos litigation, in that such a request is overbroad, and the information sought is not reasonably calculated to lead to the discovery of admissible evidence. 4.

This Association, along with the Building and Construction Trades Department (AFL-CIO), challenged the 1986 standard in the U.S.

Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs.

We compare the contemporaneous types of knowledge that physicians and others accepted to the available information, illustrating what was known about the association between asbestos brake work and disease over the past 100 years [10].

Any omissions of such information are unintentional.