However, the Defendant is able to provide the following responsive information.

What we're trying to do, Mr. 1 2 Myers, obviously is just find out information 13 about Unit>n Carbide in regard to some specific ] 4 items.

Pl.AlNTHT'S EXHIBIT '[ CAP-1734 [ [ Technological Feasibility and Economic Impact of OSHA Proposed Revision to the Asbestos Standard Prepared for: Asbestos Information Association/North America Washington, D.C.

INDUSTRY -- GOVERNMENT CONFERENCE Hi SEPTEMBER 19 - 20,1979 ARLINGTON, VIRGINIA Asbestos Information Association A1& [north 1745 Jefferson Davis Highway Arlington, Virginia 22202 .

Enclosures 21882\0RANGE\ltr3 .rla.doc cc: Brent Coon & Associates (w/enc.)

By its own terms, the construction industry standard for asbestos limits the application of the negative-pressure enclosure requirement, paragraph (e)(6)(i), to those asbestos removal, demolition, and renovation operations for which airborne concentrations exceed or can reasonably be expected to exceed the PEL.

Recently asbestos has been associated with bronchogenic carcinoma, pleural mesothelioma, peri toneal mesothelioma, and cancer of the stomach, colon, and rectum.

Pigg Asbestos Information Asso.

Celanese further states on present information and belief that it was never a member of the American Hygiene Foundation, the American Petroleum Institute, the Ohio Safety Congress, the Asbestos Information Association or the Industrial Medical Association.

PLAINTIFF'S EXHIBIT A(3 FRCW A/C Pipe Producers Association `ydie-d mtemaf Correspondence Executive Committee International Affairs Committee Q'^.UXelc.Llp/0 j/lj.

Gypsum to engage in unduly burdensome research, divulge privileged information and produce privileged documents.

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 Informa

Exports -- By Country -- of Asbestos Manufactured Products in 1975 35 v FMS1 04826 ASBESTOS INFORMATION ASSOCIATION NORTH AMERICA 1835 K Street.

Subject to and without waiving these objections, Celanese states that it cannot say with any certainty the first year any one of its employees first became aware of a health risk potentially associated with asbestos exposure, or how such information may have been acquired.

In the course of answering interrogatories over several years, various persons have provided information and referred to documents, which persons and documents this defendant is -5- presently unable to identify individually or in relation to specific items of information.