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

The major areas are: 1} Onfamiliarity with the units used for industrial hygiene or occupational health calculations, and the metric system. 2) Insufficient time for assimilating material presented in "hands on" laboratory exercises. 3) Lack of knowledge of Bell System Hearing Conservation, Lead or Asbestos Guidelines.

Occupational Health Services FlG 40-2 -- Automatic audiometer (left) and manual audiometer (nght) can be used for accurate hearing evaluations Courtesy Erie Mining Co , Hoyt Lakes, Minn examination which warrant extra-careful study A nurse or other specially trained person can secure basic data from the ex aminee, such as height, weight, age, and the history Nurses may also assist in other portions of the examination when specially trained and authonzed to do so This relief from minor details will give the physician more time to devote to an analysis of the whole person Custom requires that a nurse or other female attendant be present when women are being examined Health problems of women There is no reliable evidence to support the view that women are more susceptible than men to occupational health hazards, except during pregnancy The policy of some companies has been to dismiss women on learning of their preg nancy As a result, many women concealed their condition until it became obvious, fre quently until the last half of the pregnancy This policy can work to the disadvantage of both employee and company inasmuch as the early months present the greatest danger of spontaneous abortion It is desirable that women who work during this time be under medical department supervision The woman should consult her own doctor who should, in turn, report her condition to the plant doctor so that he may determine the advisa bility of her continuing to work Both preceding and during pregnancy, exposure to lead is potentially dangerous Lead in the blood, tissue, and body fluids re mains in the system for many months Be cause of change m the physiological mech- 1230

Abex also objects to this interrogatory to the extent it purports to seek information or materials regarding time periods, products and medical conditions 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.

With lead-free fuel, nearly all of the exhaust particulate matter is organic.

Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana.

Chronic exposure to lead can affect kidneys, blood, gums, gastrointestinal system, and central nervous system.

ANSWER TO INTERROGATORY NO. 21: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation Abex also 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 grounds that such information or matenals lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence Abex further objects to this interrogatory on the grounds that the information or matenals it purports to seek otherwise lack relevance to the issues ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections, and insofar as it understands this interrogatory, Abex has not found any documents whereby Abex agreed to rebrand and sell under its own name asbestos-containing brake products manufactured by someone else In addition, see Answer to Interrogatory No 10 -55-

Robert Carlson, the amount of $7*00, for suggesting a method of pumping pulp lead in steel drums for the Color Department.

In regard to your interest in reducing lead output, we do have some exploratory tests under way So far these con sist of a comparison between two identical cars as to lead retention, one car having a standard exhaust system and the other having an additional spark-arrestor type muffler at the end of the system.

c t t r h zo t a t s :^ : ru^lie* Petals: In .roca*a Finished: lead <-dr*r :ilvor Gold dy-?

Can the quality of Ira product bo cont rol lad enough to insure gnttinp out the kind of lead deei radf If there is liable to be this variation in the pvtdust, It would be uaeleee to go on with the hmlntss. 1 expect t o bo in our How Yorit offloo n part of the day Friday.

I asked Mr Williams to have two of each finished for-me thinking they could be used at some future time in the advertising and sales promotion of Euston Lead.

Asbestine 50% Leaded Zinc 343 196 147 294 6.03 5.49 6.18 5.73 .08?

FRAZER PAINT COMPANY 2475 Hubbard Avenue Detroit, Michigan SCHEDULE I TRADE NAME: CATEGORY: COLORi QUALITY: 550 RedLead in Oil Red Lead inOil Red First Pigment: 75# Red Lead Jra2er Pigment Silica Lbs. 1020 125 130 Vehicle: 25% Raw Linseed Oil Heavy Bodied Linseed Oil , Mineral Spirits Turpent ine Drier'< * 350 16 19 19 18: Yield in Gallons Unit Cost Total Cost Weight .095 96.90 per gallon .035 .01 4.38 1.R0 finished Storage Sc handling cost product, through loss - 1% Laboratory record 21. lbs. .13 45.50 102.58 1.03 .143 2.29 .015 .2 * ' " .10 1.90 .07 1.26 Storage Sc handling cost through loss - 3% 51.24 1.54 Calculated Yield Manufacturing Loss - 2i% Actual Yield 1697 80.8 2. 78.8 Cost Analysis; Material cost rer gallon Direct labor cost rer gallon Jhctory overhead per gallon Bulk cost per gallon Complete package cost per gallon, including filling charge Factory cost in nackage per gallon PRICES (a) To a company owned or controlled outlet (b) To an independent wholesaler (c) By company owned or controlled outlet to retail customer (d) To an independent retailer (Dealer) (e) To other (Industrial) (Contractor) 156.39 I.98 .10 .05 2.13 .19 2,32 None None 4.25 3.32 3.81 1.40 REPRODUCED AT THE NAJ.u-v.--------- LS N 5150 OPA 16252