As worded, this document request could reach information BSR\504538 -4- which is confidential and/or proprietary business information.

ASARCO objects to plaintiffs definition of "product containing asbestos fibers," "asbestos-containing products," "asbestos products," "asbestos" or "asbestos materials" on the grounds that it is overly broad, vague, ill-defined, and not susceptible to a precise response. 6.

Without waiving the foregoing objections, Defendant answers that it is impossible to know in an organization the size of this Defendant exactly what year it would have obtained this kind of information. 4 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).

As worded, this document request could reach information which is confidential and/or proprietary business information.

Without waiving the foregoing objections, Defendant answers that it is impossible to know in an organization the size of this Defendant exactly what year it would have obtained this kind of information. 4 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).

PREFACE The Notice of Deposition and its associated topics of testimony or areas of inquiry (Exhibit A) and requests for documents (Exhibit B) seek information and documents for a period of over 80 years.

Defendant objects to Plaintiffs definition of the words "trade organization" and "trade association" because it is overbroad and unduly burdensome.

As worded, this document request could reach information BSRA508611 -5- which is confidential and/or proprietary business information.

As worded, this document request could reach information which is confidential and/or proprietary business information.

List any and all such sources of information relied upon, including, but not limited to, identifying any and all records or documents reviewed and persons providing information.

Without waiving the foregoing objections, Defendant answers that it is impossible to know in an organization the size of this Defendant exactly what year it would have obtained this kind of information. 5 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).

As worded, this document request could reach information which is confidential and/or proprietary business information.

Without waiving the foregoing objections, Defendant answers that it is impossible to know in an organization the size of this Defendant exactly what year it would have obtained this kind of information. 4 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, jhe 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).

Dangerous Premises was written with the hope that, by revealing what happens during and as a result of an inspection, readers will be able to make informed judgments about the need for OSHA and how OSHA could better realize its goals.

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