You are authorized to verify all information.

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).

-/ *9 Discussion of the Technological Feasibility of Attaining a 0.5 Fiber/Cubic Centimeter Time-Weighted Average Airborne Concentration of Asbestos Fiber in the Workplace as Proposed by OSHA in the Federal Register of Thursday, October 9, 1975 by Johns-Manville Corporation April, 1976 DUP U52470 DU 061785 C- / INDEX Title Page Summary & Conclusions ----- -----------------i Johns-Manville's Involvement in the Asbestos Industry - - 4 Plant Data (Table A) - .5 Major Problem Areas - -- -- -- -- -- -- 7 Fiber Introduction -------------7 Bag Opening Stations Fiber Handling Product Finishing -- - -- -- -- -- -- -8 Machining Sanding Case History 1 - Asbestos Bag Opening Stations - - - - 10 Process Descriptions ---------- Asbestos-Cement Pipe ---------Case History 2 - Reduction of Asbestos Fiber Exposures in Asbestos Cement Pipe Plants Case History 3 - Waukegan Pipe Plant - - Asbestos-Containing Boards ------ - - - - 22 Asbestos-Cement Asbestos/Calcium-Silicate -' Case History 4 - Billerica Plant - - Roofing - -- -- -- -- - - - _

Medical Removal Protection; (Z), Employee Information and Training; (m), Signs; (n), Recordkeeping; (o), Observation of Monitoring; (p), Effective Date; (q).

Asbestos Corporation Ltd., is prohibited from disclosing such information by the requirements of the Quebec Business Concerns Records Act, Chapter D-12 of the Revised Statutes of Quebec PAGE I (1977).

Please review same and advise me whether there is additional information which you seek.

If any piece of equipment which was used at any time to install, cut, shape, etc. products identified in answer to interrogatory no. 1 or 7(b) was invented, -7- developed or first made by answering defendant or any person associated with you or any related company or association, state: (a) When it was invented, developed or made (including changes or improvements to previously available equipment); (b) The identity of each individual who participated therein and describe in detail the extent of his participation; (c) The identity of each document which reflects, refers or relates to any information set forth in answer to this interrogatory.

The answers are based on information secured fro company and otherwise.

The training * addition, OSHA will toon publish a . corolsls ofrevisions to the exiitlng , , ^progam wit) Include instruction on separate notice ofproposed rulemaking ' Standard covering occupational s setpirator fitting and use. handling of * > ^tbat fartherexplains the luue* under , . 4 axposura to asbettos, 29 CFR 1910.1001* . asbeatoe* medical Information, tha ' ` f consideration for the permanent .

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.

ste ee APPENDIX A - OSHA ASBESTOS STANDARD 1910.93a APPENDIX B - VACUUM CLEANING STATIONS SKETCHES 3 Page 1 Page 2 Pages 3-7 Pages 8-10 Page 11 Page 12-19 Page 13 Page 14 Page 15 Page 16 Pages 17-18 Page 19 Page 20-43 Pages 21-30 Pages 31-37 Pages 33-42 Page 43 Pages 44-45 INTRODUCTION The Occupational Safety and Health Act was signed into law on December 29 1970 and became effective on April 28 1971 The Act has the stated objective of assuring every American worker a safe and healthy workplace On December 7 1971 the Secretary of Labor issued an emergencytemporary standard for exposure to asbestos dust As required by the Act a permanent standard for asbestos exposure was promulgated six months later on Asbestos Standard discussed in June this 7 1972. booklet The present OSHA became effective on July 7 1972 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 consultation and are been developed recommended as through careful good procedure study and It is recognized that manufacturing conditions vary Implementation of the practices contained herein cannot be considered as a guarantee of OSHA compliance of compliance OSHA personnel Where should there may be a be consulted question Thorough understanding of the OSHA Asbestos Standard is important to management of any company utilizing asbestos in its manufacturing or processing operations The proposed revised standard contained in the Federal Register of Thursday October 9 1975 Vol 40 No. 197 Part II will not be a subject of discussion in this manual since it is a proposal without an effective date When the final revisions are promulgated this manual will be dated PRODUCTS AND OPERATIONS Types of asbestos sheet products covered by these work practices are Flat asbestos sheets - plain and pigmented - press produced Corrugated asbestos sheets - press produced Flat asbestos sheets - plain and pigmented - wet machine produced Corrugated asbestos sheets - wet machine produced Asbestos sheets and shapes - extruded Flat asbestos calcium silicate sheets - press produced Structural sandwich panels - sheets with insulating core flat asbestos Operations to which these work practices may apply are Handling and warehousing Drilling General Housekeeping including waste disposal Shaping Sawing Sanding PRODUCED JM PRODUCED SUMMARY OF THE REQUIREMENTS OF THE OSHA ASBESTOS STANDARD 1910.93a General Comments After extensive public hearings OSHA published a Standard for Exposure to Asbestos Dust in the Federal Register Volume 37 No. 110 dated Wednesday June 7 1972.

Testimony will be presented by several companies and the Asbestos Information Association.

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.

N W WASHINGTON, 0 C. 244-354 FOR THE ASBESTOS INFORMATION ASSOCIATION PLAINTIFF'S 6 EXHIBIT | 'j SB.C..A-- 5...0-5-1--- |x PROGRAM ABC News Closeup s ta tio n WJLA-TV A8C Network DATE July W , 197 8 10:00 PM CITY Washington, D.C.

Testimony will be presented by several companies and the Asbestos Information Association.