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.

Asbestos Information Association Mr.

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.

For historical restoration they could he used either to preserve the historical integrity of a landmark that originally had asbestos-cement shingles, or to replace real slate with a variety of asbestos-cement shingles that resemble slate (Atlas 1986b; National Roofing Contractor's Association 1986).

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

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. -6- 13.

Based upon information provided to DuPont's counsel regarding Jose M.

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

These answers are further limited to the activities of Grace-Conn's Zonolite and Construction Products Divisions ("CPD") associated with the manufacture and sale of such products in the United States during the relevant time period.

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

(f) Information sought in this Interrogatory is available in this defendant's annual reports.

TAC-01-80, Recommended Work Practices Phase II: Transient Asbestos b.