The district mechanics are mem- bers of the International Association of Machinists & Aerospace Workers (lAM), Marin County lodge No. 238.

Asbestos dust is an example of such a substance, as the findings of OSHA demonstrate: Products containing asbestos are not used consistently [in construction work].

Uniroyal objects to any interrogatory which seeks information about any asbestos containing products it may have manufactured or sold because the plaintiffs have not produced any evidence of exposure to any Uniroyal or United States Rubber Company asbestos containing products.

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.

Keegan for Asbestos Information Association/ 10SHC 1632 Industrial Union Department, AFL-CIO v.

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.

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.

To provide such information would require a nationwide search unlimited by time, location, or type of information, and is thus over broad and unduly burdensome, III.

As worded, this document request could reach information BSRA505298 -4- which is confidential and/or proprietary business information.

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.

Plaintiffs' use of the term "asbestos-containing product" incorporates an assumed release of asbestos dust and asbestos fibers in the use of a product.

Without waiving this objection, see this Defendant's response to Interrogatory No. 4 where information specific to manufacture and/or sale of asbestos-containing products is provided. 4.

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).

Any pertinent information which the employee or premises information can be said to reflect can be requested directly without requesting the irrelevant and immaterial information or documentation about employees or premises.

The purpose of this report is to gather together the available information on asbestos sources and estimate the extent of the overall exposure to the general population.