INTERROGATORY NO. 56; Has Defendant, any predecessor or any related company, or any person or entity actmg on behalf thereof, including but not limited to any insurance company, at any time, gone into any area where any product identified in response to Interrogatory Nos. 19 and 42 was being manufactured, used, applied or installed to perform a dust level count or similar test?

in building insulation products and/or asbestos-containing automotive friction products, and/or among the different types of asbestos fibers.

HSE Health & Safety Executive Review of FIBRE TOXICOLOGY \ \ by M Meldrum HWBUI0010318 HSE Health & Safety Executive 1 Review of FIBRE TOXICOLOGY HWBUI0010319 Crown copyright 1996 Applications for reproduction should be made to HMSO First published 1996 ISBN 0 7176 1205 8 ASrights reserved.

t - i' S' `Vf V 212 WILLIAM V LORIMER ET AL TABLE IV Personal Samples--Truck Brake Service Operation Concentration (ftbers/ml) Beveling new linings Beveling new linings Beveling new linings Beveling new linings Beveling new linings 31 7 237 32 7 72 0 263 Background Samples--Truck Brake Seruice Operation Distance Background to beveling linings Background to beveling linings Background lo beveling linings Background to beveling linings Sft ' 12 ft 12 ft 30 ft Concentration (fiben/ml) 06 05 03 03 TABLE V Automobile Broke Lining Service Operation Comparison of Optical and E M Fiber Counts Optical Microscopy Electron Microscopy Light grinding of new linings before installation Grinding new Immgs before installation Blowing dn<it ofT drum with air jet Cleaning brake drum with hand brush Background to blowing out brake drum (10 feet away) Bar kgrourid to blowing out brake drum (20 feet away) ( background to blowing out brake drum (65 feet away) iftben/ml) 4.8 27 04 36 03 08 1 fig/m' 530 660 11 65 02 01 02 x ray, and pulmonary studies Three men were-excluded from analysis because they had worked m a shop for less than 10 years Also excluded from analysis were nine men whose occupational history raised the possibility of other asbestos exposure Two men'Were excluded because of known1 chest disease The remaining 90 believed themselves to fee healthy{ all either were currently working (84) or'had retired because of age (6), !

2- - Challenge the decision in court m order to either maintain the 2 f/crtP or to buy us additional time for the purpose of developing new materials.

AJIS HI C A N' 3SAKSr-0'i CAM *AM wO COMHT jltnioa1 5sif IT.%*.

f; VORWALD ET AL.

-E- Asbestos and The Friction Material Industry Ocher requirements concerning use of callings for surfacing roads, the regulation of demolition activities, and. controlled application of spray-on materials are of little concern to friction materials processors.

BUILDING SERVICE INDUSTRIAL SALES CO., INC.

SHIPPING' DATE ' THANK- YOU FOR- ORDER NO.

BSIS-Roberson03281

DATE _ THANK YOU FOR ORDER NO BLDG.

BSIS-Roberson03369