., DEER PARK MANUFACTURING COMPLEX SUBJECT: REVISED ASBESTOS STANDARD Attached for your information is the revised asbestos standard.

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.

(asbestos users from the St.

Met Life prepared its own report of the Canadian studies, which included dust study information as well, entitled "Effects of the Inhalation of Asbestos Dust Upon the Lungs of Asbestos Workers, Canadian Study."

If not, state the correct legal name of- the defendant and provide the information requested in No. 2 above concerning the defendant as correctly named.

The words "trade organization," or "trade association" mean any organizations or associations of business or industrial entities that are associated and/or meet for the purpose of achieving common goals and/or exchanging information related to common needs or interests, and/or learning information or facts of interest to the various members of the organization or association. 13.

The information provided in these answers to requests and interrogatories is based upon such information as is presently available to Abex, and Abex expressly reserves the right to supplement or amend these answers when and if additional relevant information or documentation is discovered.

Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs for all associated business entities that were involved, in any manner, in the sale, manufacture, distribution, and/or mining of asbestos and/or asbestos containing products.

In fact, new information not referred to by OSHA strongly suggest that 2 or perhaps more fibers/cc is not associated with an excess incidence of pulmonary cancer.

Has THIS DEFENDANT engaged in the KARTOTlng of ASBESTOS- 21 CONTAINING PRODUCTS comprised in whole or in part of chrysotile 22, asbestos fiber?

Such information will not be disclosed herein.

If so, identify the document containing such information by date and location.

It was also pointed out that the Asbestos Information Association (AIA) was referring the question of a captive to a consulting group, Tillinghast, Nelson and Warren of New York City.

SUPPLEMENTAL ANSWER TO INTERROGATORY NO. 5(d): In addition to Answers previously given, Mallinckrodt states that there is little information to provide.

The training ~ * addition, OSHA will toon publish a .. consists ofrevisions to the existing ,, ^progam will Include instruction on separate notice ofproposed rulemaking ' Standard covering occupational ; v mpirotor fitting and use. handling of * > ^tbat fartherexplains the luue* under , exposure to asbestos, 29 CFR 1910.1001* . asbestos* medical Information, tht ' ` f consideration for the permanent ~ . f* la order to protect employee* from a >*> relationship between smoking and tung / standard and which raises some : r*rP>v*dangerbomo(mtinuedexpottne .'.