IN THE UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
In Re: Asbestos Litigation :

Master File No. Misc. 85-100
Limited to:
C.A. No. 85-61 (Brown)
C.A. No. 82-79 (O'Neal)

_ DEFENDANT HERCULES, INCORPORATED AND CHAMPLAIN
CABLE CORPORATION'S ANSWERS TO STANDING ORDER #4
INTERROGATORIES

•

1.
Describe in detail, with specificity and particularity
each product mined, produced, mianufactured or sold by the
answering defendant or its predecessors in title or subsidiaries
which contained asbestos for each year from 1936 until 1980; and
for each such product, describe:
(a)
Its chemical ingredients;
(b)
State the manner in which it was intended to be
used, i.e., in the construction and/or insulation of buildings
and/or equipment, etc.;
(c)
For each ingredient contained therein, state:
(i)‘ The name or chemical composition of each
substance, what harmful effects, if any are known, that it
,
produces in man or mammals and whether it produces its harmful
effects through ingestion, inhalation, absorption or a
combination of these;
(ii)
When you determined and/or learned that the
substance produced harmful effects and how such effects were
'
produced;
(iii)
Identify each individual who participated
in such determination and/or obtained such knowledge;
(iv)
Identify each document that refers, reflects
or relates to any information pertaining to the properties of
each of the ingredients and/or how the harmful effects -are
produced as well as your determination of those toxic effects and
the manner by which they are produced;
(v)
As to any information received orally in
answer to this interrogatory, identify each person who supplied
such information and state the full substance of the information
supplied;

mt

71986

(vi) Which products or ingredients were mined,
which were manufactured and which were distributed by answering
defendants.
ANSWER OF BOTH HERCULES AND CCC:

The following information is

answered only in relation to those asbestos-containing products
produced, manufactured and sold by Haveg Industries, Inc. for the
years 1940 to 1979.

Haveg Industries, Inc. produced,

manufactured and sold corrosion-resistant chemical process
equipment, "Haveg" designed for the maintenance free handling of
sulfuric, hydrochloric and phosphoric acids and cholorinated
solvents.

For more further and detailed information, refer to

the Product Catalogs in possession of defense counsel, Biggs and
Battaglia, which have been produced for review, inspection and
copying at request, and are contained in Request/Subpoena File
A-49.

For information regarding suppliers, refer
to files Al-57
t

and A2-58-77.
Briefly, the information contained in those Product Catalogs
is as follows:
HAVEG PIPE AND FITTINGS are designed for handling abrasive
environments ( which tend to erode protective coatings on line
pipe).

Pipes and Fittings may also be used in a submerged state

or in areas having severe atmospheric corrosion problems.
Split Flanged Pipe - designed for standard application,
i.e., handles abrasive environments.

2

Threated Pipe and Bell End Pipe - for applications where
immersed pipe required.
Pipe Fittings - connect pipe systems.

Fittings include:

Sleeves

Rings

Couplings

Crosses

Flanges

45° Lateral

Discs

Caps

Ells: 90°, 45°, 60°, 30°, 22-1/2°
Reducers

Plugs

Fume Duct and Fittings - handle gases or fumes in ventilator
lines, gas distribution systems and similar applications.
Expansion Joints are for piping lines which may be subject
to bending, distortion or vibration regardless of temperature.
Expansion Joint Sleeves •- method of connecting piping to
allow for expansion.
Valves - designed for which all the surfaces of the valve in
contact with a solution are made of HAVEG. Regulates liquid flow.
Furnished with ah asbestos graphite packing unless otherwise
specified.
Types of valves include:

*

Y, Diaphragm, Flush, Check (vertical and horizontal), Foot,
Angle, Butterfly damper (regulates gas flow). Gate damper.

3

*****************************************************************
TANKS AND TOWERS are construction materials designed for
maximum corrosion resistance and physical strength in the
chemical process industries.
Types of tanks and towers include:
Cylindrical tanks - used as pressure reactors, horizontal
and vertical tanks in the chemical process industry.
Cylindrical towers - used for adsorbing, absorbing,
stripping, scrubbing and fractionating columns in the chemical
process industry.
Rectangular tanks - used in the chemical process industry
for storage, reaction tanks, filters; also, pickling, cleaning
and etching by the metallurgical industry.
Tank and tower accessories are designed primarily for use
with tanks and towers.
Accessories include:
Grid bars - standard Haveg packing support.
Distributor Trough - standard Haveg liquid distributor.
Nozzles - pipe connectors on tanks and towers.
Dished Cover - used to cover cylindrical tanks vented to the
atmosphere; can also be supplied as a loose cover, i.e., resting
and not fastened to the top of the tank.
Scrubber Cover - designed to cover cylindrical tower.

4

Thermowells - container for temperature sensing devise;

internally installed on tanks and towers.
Gauge glasses
Sight glasses - designed to be mounted on tanks with or
without valve cut-offs to permit observation of the tank
contents.
Heater & Coil Supports - designed to support any type
heater, either plate or coil type, either molded or placed
loosely in the tank.
Plug Outlets are designed for use as drop valves, emergency
closures for storage tanks.
Plugs - for use in conjunction with plug outlets.
Circulating Tank Heaters and Steam Pipes
Liquid Seals and Stuffing Boxes for use as seal on agitator
shafts.
Manholes - covers vessels, tanks and towers.
Bubble Cap
Carbon Bed Support - are perforated plates with a filter
cloth in between, designed as method to support carbon particles
in adsorption towers.

-

Agitators are designed for stirring free-flowing liquids and
thin sludges.

5

n

Haveg Rolls - designed for use in textile agers, dye tubs,
pickling tanks.
Cements - manufactured and designed for the repair,
alteration and installation of Haveg chemical equipment; a
putty-like molding mixture for general use in alteration of Haveg
equipmet, which provides hard and strong joints or building-ups
on the original equipment.
Sheet Stock - constructional material used in towers,
vessels and pipes to make parts, e.g., to construct rectangular
vessels.
*****************************************************************
The above-referenced Haveg equipment was available in a
variety of different formulations, depending on the precise
nature of the chemical application involved.

The different Haveg

formulations or grades were as follows:
Grade Haveg 41 produced for the years 1940-1979
Haveg 41 consisted of approximately 50% (by weight) or an
acid-leached anthophyllite asbestos which was completely
encapsulated in a phenol-formaldehyde resin approximately 50% (by
weight).

Haveg 41 was a thermoset type plastic, i.e.,-the resin

is "set" and cannot be fostened when subjected to heat.

Grade 41

was recommended for processes involving mineral acids, salts and
chlorinated hydrocarbons.

6

Grade Haveg 61 produced for the years from approximately
1955-1979
Haveg 61 consisted of approximately 50% (by weight) of an
acid-digested anthophyllite asbestos filler which was completely
encapsulated in a furfuryl alcohol-formaldehyde resin
approximately 50%

(by weight).

Haveg 61 was a thermoset type

plastic, i.e., the resin is "set" and cannot be softened when
subjected to heat.

Grade 61 was recommended for processes

involving acids, alkalis and chlorinated aromatic hydrocarbons.
Haveg 4120 consisted of approximately 50% (by weight) of an
acid-digested anthophyllite asbestos filler which was completely
encapsulated in a modified phenol-formaldehyde resin,
approximately 50% (by weight).

Haveg 4120 had exceptional

resistance to some chemicals for which neither Haveg 41 nor 61
are recommended, e.g., monochloracetic acid.
Haveg 31 consisted of approximately 50% (by weight) of an
acid-digested anthophyllite asbestos filler which was completely
encapsulated in a modified phenolic resin approximately 50% by
weight).

Haveg 31 was recommended for use in the chlorine

industry in the form of cell connectors, headers and chlorine
coders; 31 provided excellent resistance to we chlorine gas.
Haveg 91

7

p

Acid Washed/Digested Anthophyllite Asbestos, sold uni
trademark HAVESTOS - acid leaching process which removed

c

soluble materials, making material more chemically resistc
Mixed with resin to make Haveg equipment or plastic produc
Acid Washed/Digested produced for the years 1932 thro
1979
- -*******•*•*■**■**************■*•*■***■★***********■**********■**■*■***

CHEMTITE piping systems - designed for conveying corrc
fluids for demanding process operations on drain conditions
indoor, outdoor or underground.

Piping systems were design

high pressure or low pressure applications with complimenta
fittings.
Fittings - connect the piping systems.

Fittings indue

Couplings, Flanges (external or internal). Ells - 90°,
threaded, flanged or socket, close nipples, Reducing bushing
Tees (threaded or flanged). Valve body (internal thread or
flanged). Countersink plug. Step plug. Repair sleeve.

A’***********************************************************')
CHEMTITE DIAPHRAGM VALVE - designed to seal off fluids
gases from working parts.
Chemtite equipment was avalable in two formulations:
Produced for the years 1971-1979

8

i

•i

Chemtite PB consisted of approximately 40%

(by weight) of

crocidolite asbestos paper or chrysotile asbestos which was
completely embedded in an inert phenolic resin matrix
approximately 60% (by weight).
Produced for the years from approximately 1971-1976
Chemtite EB consisted of approximately 40% (by weight) of
crocidolite asbestos paper or chrysotile asbestos which was
completely imbedded in an inert epoxy resin matrix approximately
60% (by weight).
Crocidolite is a complex sodium-iron silicate of the flat,
solid fiber (amphibole) group.
»

Chrysotile is an hydrous

magnesium silicate of the bubular fiber type.

Anthophyllite is ;

magnesium-iron silicate of the flat, solid fiber (amphibole)
group.
Hercules objects to responding beyond the information
provided and limits its answer to the operations of the
Marshallton plant on the bases that such information is not
relevant or calculated to lead to the discovery of any relevant
or admissible evidence.
In addition. Aerospace products were manufactured-at the
Haveg Marshallton plant during the early 1960's until 1965.

For

information concerning the composition of those products, refer
to the deposition of Jack Mertz taken in June 1985; also the

9

depositions of Leon DeBrabander taken on 10/4/83, 11/18/84,
1/19/84 and 2/21/84 and the depositions of Eugene O'Neill taken
on 10/7/83, 1/17/84, 2/22/84 and 2/23/84 would contain
information concerning the chemical and raw material compositio.
of Haveg products.
2.
If any product identified in answer to
Interrogatory No. 1 was produced, manufactured and/or sold under
a trade name, identify that trade name(s) and state the time
period that each such product was sold under such trade
name.
.
ANSWER OF HERCULES AND CCC:
HAVEG

1940-1980

CHEMTITE

1971-1980

HAVESTOS

from approx. 1962-1968

Further information may be found in the Product Catalogs
contained in File A-49.

Refer to the answer to Interrogatory #1

3. For each product identified in answer to Interrogatory
No. 1, state:
(a)
The address of each plant where it was
manufactured, processed or packaged;
(b)
Whether you were the sole producer, manufacturer
and/or distributor of the product and, if not:
(i) The name and address of each other person,
firm or other entity engaged in the production, manufacture
and/or distribution of the product (including companies which
rebranded for the answering defendant);
(ii) Whether any other manufacturer produced the
product by virtue of a franchise or license from you;
(iii)
The persons or firms who produced the
product for distribution in the United States;
(iv) The person or firms who produced the product
for distribution in the State of Delaware.
10

(c)
All products the answer defendant manufactured,
mined or sold which it would relabel for others and the name of
any entity such relabeling occurred for, including when, where
and with whom defendant dealt with.
(d) Any changes answering defendant made in the
product or packaging for others of its products and any changes
answering defendant requested be made in products or packaging of
products others rebranded for the answering defendant.
ANSWER OF HERCULES AND CCC;
(a) 900 Greenbank Road, Wilmington, DE 19808
(b) Each product identified in Answer to Interrogatory No.
1 was produced, manufactured and distributed from 900 Greenbank
Road, Wilmington, DE 19808.

Also, from approximately 1962 to

1968, HAVESTOS was sold by Asbestos Corporation of America, 31
North Avenue, Garwood, New Jersey.
(ii)

No.

(iii)

Other than Haveg, no other firm known to

defendants Haveg and Hercules produced the products for
distribution in the United States.
{iv)

Refer to answer to Interrogatory No.

3(b)(iii).
4.
For each product identified in answer to Interrogatory
No. 1, state:
(a)
How the product was sold and/or distributed for
use in the United States and/or the State of Delaware;(b) (i)
Identify all persons, firms or other entities
to whom these products were sold for distribution during the
period 1936 to 1980;
(ii) Identify all entities to which a sale was
made from 1936 to 1980 in Delaware, Pennsylvania, New Jersey and
Maryland between 1936 and 1980.

11

(c)
For each such person,'firm or other entity
identified in answer to subpart (b) above, state the following:
(1)
The specific product sold and/oir distributed;
(2)
The quantity (i.e. boxes, linear feet) of the
product sold and/or distributed;
(3)
The dates which these products were sold,
shipped and delivered to each entity;
(d)
Identify each individual who has any knowledge of
these sales and/or distribution and state with specificity and
particularity the substance of each individual's knowledge;
(e)
Identify and produce all documents which refer,
reflect or relate to all sales and/or distribution of each such
prodouct to each such entity identified above.
ANSWER OF HERCULES AND CCC:

Sales representatives were employed

by Haveg Industries, Inc. in various states to promote sales.
5. For ech product identified in answer to Interrogatory
No. 1, state whether you, your subsidiaries or predecessors in
business engaged in any advertising program to promote the sale
of that product and, if so state:
(a)
The name or description of each advertising media
that you have used to promote the product during the period 1936
to 1980;
(b)
The name of each national magazine or periodical
in which you have advertised the product during the period 1936
through 1980.
(c)
The date of each issue of such magazine or
periodical in which such advertisement appeared;
(d)
The name and address of each newspaper in which it
advertised the product during the period 1936 through 1980;
(e)
The date of each publication of each newspaper in
which the advertisement appeared;
(f)
Identify and produce each document which refers,
reflects or pertains to each such advertisement which was
published in each such magazine, periodical and/or newspaper;
(g)
State whether the advertising of the product was
handled by an agency and, if so, state the name and address of
each advertising agency that handled any portion of the
advertising of the product during the period 1936 through
1980.

12

ANSWER OF HERCULES AND CCC:

Sales were through sales

representatives, trade journals and product catalogs.

Refer to

Exhibit "A" attached for listing of advertising agents.
6.
With regard to each form of asbestos fibers identified
in the answer to Interrogatory 1(a) and 1(c), state:
(a)
Where it was purchased, if it was not purchased
where it was obtained;
(b)
From whom it was purchased;
._
(c)
The manner in which it was received, stored and
used in the production of the product.
ANSWER OF HERCULES AND CCC:

In response to this interrogatory,

refer to Request/Subpoena documents already produced, in
particular Files Al-57, A2-58-77.

In addition, refer also to the

deposition of Jack Mertz for Aerospace purchases and the
depositions of Eugene O'Neill and Leon DeBrabander for the
identity of suppliers, storage and use of the materials
purchased.

Also, the depostions of Paul Reynier from 2/10/81,

9/15/82 and 8/16/84 regarding suppliers and contacts with
suppliers.
7. If you have ever manufactured or had a subsidiary or
predecessor in the corporate chain manufacture any insulation
products which are commonly used by insulators and which contain
asbestos;
(a)
Describe the process or method of how the products
listed in 1 are cut, shaped, mixed and applied on the jobs giving
particular reference as to whether or not the materials have to
be sawed or cut on the job, blown into confined areas, or mixed
with water into a cement or paste;
(b)
State if there is any way known to the defendant
that the products listed below can be used and applied without
the worker inhaling any of the asbestos dust or fibers:
(1)
Asbestos cement; Asbestos Finishes;
(2) Asbestos pipe covering;

13

(3)
Asbestos bricks or blocks;
(4)
Asbestos sheeting;
(5)
Asbestos insulation used to cover extremes of
heat as well as cold;
.
(6) Asbestos insulation in loose form which may be
blown into homes or buildings;
(7) Asbestos in spray form;
Asbestos mineral in fiber form or particulate
(8)
form;
(9) Asbestos Millboard, rope, gaskets, paper
gloves or blanket.
ANSWER OF HERCULES AND CCC:

This interrogatory is objected to in

that it appears to request information not relevant to the
plaintiffs involved in this case nor the issues presently
involved in this matter, and is not calculated to lead to the
discovery of further relevant or admissible evidence.

The

purpose of this interrogatory is confusing and unclear to these
answering defendants.

Based upon defendants' understanding of

this question and not waiving any objects that have been raised
previously, Haveg Industries, Inc. manufactured asbestos
containing products which could have been used by insulators.
Neither defendant has any knowledge as to how each product was
used by each customer on each job.
8. 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, 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;

14

(c)
The identity of each document which reflects,
refers or relates to any information set forth in answers to this
interrogatory.
(d)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCCt

To the best of defendants' present

knowledge, no equipment was invented, developed or first made by
them for the use in applying any of the products listed in
response to Interrogatory No. 1.
However, any patents regarding the Haveg product are
available for inspection and review.

To the best of defendants'

knowledge, none were attributed or developed by Hercules.
9. For each process and/or method identified in answer to
Interrogatory No. 7(a) developed or first made by you or any
person associated with you or any related company or association,
state:
(a) When and where it was developed;
(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;
(d)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

To the best of these defendants'

knowledge, Hercules did not develop the process and/or method by
which any products listed in response to Interrogatory No. 1
would be applied or contained in Interrogatory No. 7(a).

15

ANSWER OF CCC;

To the best of defendant's knowledge, it did not

develop the process and/or method by which any products listed in
response to Interrogatory No. 1 would be applied as contained in
Interrogatory No. 7(a).

To the extent that information is sought

regarding the patents of Haveg products, these records are
available for review, inspection and copying.

,

10.
For each product identified in the answer to
Interrogatory No. 1, describe what, if any, tests were made to
determine the safety of said product and:
(a)
State when and where each such test was made;
(b)
Describe the results of each such test;
(c)
Identify each individual who participated therein
and describe in detail the extent of his participation;
(d)
Identify each document which relfects, refers or
relates to any information set forth in answer to this
interrogatory;
(e)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER:

The tests presently known to defendants performed by

Haveg Industries, Inc. were tests that fall into the category of
corrosion resistance tests and physical property tests.

For more

detailed information regarding tests, refer to the depositions of
Leon DeBrabander.
11.
For each label, brochure, or other written material
describing or relating to the use of each product identified in
answer to Interrogatory No. 1, produced by you or any entity
associated with you or any related company or association;
(a)
Describe its contents;
(b)
State when, where, how and to whom it was
distributed;
(c)
State the manner in which it was placed on or in
the product container or whether it was separate from the product
16

container, or whether it was separate from the product or
container;
(d)
State whether any written, printed or graphic
matter was present to warn of any potentially toxic ingredient
including asbestos it might contain.
If so, state:
(i)
Whether a signal word, i.e. "danger",
"warning" or "caution" was present;
(ii) Whether the signal word was printed in
boldface, capital letters or different colored inks. Which?
(iii) The wording of the statements describing any
toxic ingredient.
_
(iv)
The wording of all directions and/or
instructions pertaining to any method of use to avoid any danger
resulting from the toxic ingredient.
(v)
List the instructions provided for each
product's use.
(e)
Identify each individual who participated in the
writing of the label, brochure or other written materials and
describe in detail the extent of his participation;
(f)
Identify each document which reflects, refers or
relates to the information contained on the labels, brochurs or
other written materials and/or the decision to include such
information (if there are multiple documents, list any index of
the documents and how and where stored).
(g)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:
(a) and (b):

Product catalogs would have been distributed

to customers or potential customers of Haveg products.
(c) and (d): Refer to Product Catalogues Pile A49 in which
loose sheets regarding Haveg Cement can be found.

These sheets

were attached to all Haveg cement, that is Cement 41F and Cement
6 IF.

17

Effective on January 17, 1973, all acknowledged copies of
customer orders or mill orders for Haveg chemical equipment and
Chemtite were sent with the following information sheet.
"HAVEG PROCESSING EQUIPMENT CONTAINS ASBESTOS
ENCAPSULATED IN A BONDING AGENT WHICH PREVENTS
THE DISPERSION OF ASBESTOS FIBERS.
IF THIS PRODUCT IS MODIFIED, E.G. BY SAWING,
GRINDING OR DRILLING, IT IS POSSIBLE THAT
AIRBORNE DUST WOULD BE GENERATED.
IN THIS
REGARD, YOUR ATTENTION IS DIRECTED TO PART 1910
OF TITLE 29 OF THE CODE OF FEDERAL OCCUPATIONAL
FEDERAL REGULATIONS, SECTION 1910.1001 OF THE
OCCUPATIONAL SAFETY AND HEALTH ACT OF 1970,
WHICH REGULATION PRESCRIBES METHODS AND
PROCEDURES FOR THE PROTECTION OF WORKMEN."
Effective 2/14/77 the information sheet above, with the
exact wording typed in red ink was applied to every piece of
Haveg and Chemtite products in the form of a pressure-sensitive
label.

Material Safety Data Sheets are contained in C70 and were

distributed to customers upon request.
Warning tags and labels are found in File C65.
(e)

The identity of those individuals presently known who

assisted in the wording of any warning labels, including the
pressure sensitive label, are as follows:
Edmund Painter and Dudley Barton.

Emil Christofano,

There may have been other

individuals who assisted from Hercules' legal department, such as
Edward Wolper.

18

Refer also to the deposition of Dudley Barton dated
2/1/83.
12. For each product identified in answer to Interrogatory
If state whether warnings or any harmful or potentially harmful
effects of the product were printed on the cartons or packing
cases in which individual containers were packed and if so:
(a)
State the printed warning's contents;
(b)
State when the warning was used;
(c)
Describe the manner in which it was placed on or
in the product container;
(d)
Identify each individual who participated in
writing of the label or brochure and describe in detail the
extent of his participation;
(e)
Identify each document which reflects, refers or
relates to the information contained on the cartons or packing
cases and the decision to include that information;
(f)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
suppplied.
ANSWER:Refer to the answer to Interrogatory No. 11.
13.
With regard to the production, distribution and/or
sale of each product identified in answer to Interrogatory 1,
state whether you have ever been accused of violating any of the
provisions of the Federal Labeling of Hazardous Substances Act,
OSHA {P.L. 91-596, 29 U.S.C.
Section 651 et seq and regulations
promulgated thereunder or NIASH and its regulations and, if so,
state:
(a) The date of each indictment, complaint or
information that accused you of such violation;
(b)
The court in which the proceedings were
instituted;
(c)
The plea you entered;
(d)
The verdict and/or judgment in each such case;
(e)
The date set for trial of any pending case;
(f)
Identify each document which reflects, refers or
relates to information pertaining to such accusation;
(g)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.

19

ANSWER OF HERCULES AND CCC:

Neither defendant has been cited for

any violations for labeling in relation to Haveg products.
14.
For each product identified in answer to Interrogatory
1, state whether you contend it is a "hazardous substance" as
defined in 15 United States Code, Section 1261(f) and, if so,
state with specificity and particularity the facts which you rely
on to support the contention.
ANSWER OF HERCULES AND CCC:

This interrogatory is objected to in

that the reference, 15 U.S.C.A. §1261(f) is misleading and is not
relevant to the issues in the present action.

It is part of the

consumer safety act in reference to that code section which deals
with the protection of users and consumers.

No reference in that

section is made to employees.
15. With regard to each product identified in answer to
Interrogatory 1, state whether any quantity of that product has
ever been seized by any agency of any government because of its
containing a toxic ingredient and not having a proper label or
required instructions for use? and if so,
(a)
State the date of each such occurrence;
(b)
State the name or description of the violations of
which you were accused?
(c)
State the court in which the action was filed;
(d)
Describe the judgment that was rendered;
(e)
State the date that has been set for trial of any
pending case;
(f)
Identify each document which reflects, refers or
relates to information pertaining to such seizure;
(g) As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
„
ANSWER OF HERCULES AND CCC:

To the best of defendants'

knowledge, no product manufactured at the Haveg Marshallton plant
has ever been seized by any government agency.
20

16. State what action and when it was undertaken, if any,
you have taken since 1935 to reduce or eliminate any risk of
occupational disease or personal injury to those using your
asbestos containing products which arises from the inhalation of
dust and fibers.
ANSWER OF HERCULES AND CCC;

The portion of the interrogatory

relating to the use of asbestos products is objected to on the
basis that it is not relevant to any of the issues involved in
this case as related to these defendants and the bases of the
actions against them, irrelevant to the plaintiffs involved in
this matter and is not calculated to lead to the discovery of any
further relevant or admissible evidence.

However, in an effort

to be responsive, the following measures were taken at the Haveg
plant to reduce or eliminate the risk of occupational disease or
personal injury to those employed in the manufacture of asbestos
products.

They are as follows:

mask and respirators,

ventilation system, dust collecting system, and vacuum system,
change rooms, encouraged non-smoking, films and brochures
regarding asbestos and smoking, safety meetings (education of
employees), health evaluations and programs and medical treatment
made available through the company, issuance of protective
clothing, issuance of warning to employees who violated the
safety procedures and the placing of warning signs throughout the
Marshallton plant, isolation and enclosure of certain areas of
the plant and the monitoring of the air.

21

Refer to files Cl, 4-11, 19, 23, 27-28, 30, 32, 34, 36,
39-45, 48, 50-55, 58-62, 69, 71, 72, 75, 76.

In addition, air

monitoring records were maintained since 1972 and can be found in
files Bl-24, 26.
For further explanation of safety measures taken, refer to
the depositions of Robert Good 2/3/83, Leon DeBrabander, John
Ward 2/1/83, Martha Vogler (safety)

(plant nurse) 8/3/82, Dudley

Barton 9/15/82 and 2/1/83, Clare Deptula (plant nurse) 10/5/83,
Elizabeth Elliott (plant nurse) 10/5/83, Barbara Genereaux (plant
nurse) 2/2/83, Elizabeth Tull (plaintiff and personnel manager)
2/1/83.

17.

Describe in full and complete detail each of the

activities which you have undertaken with the intention of
warning the public of the effects of any product identified in
answer to Interrogatory 1 as to the health of the user or general
public and give the inclusive dates of each such activity, and:
(a)

Identify each individual who participated therein

and describe the nature of his participation;
(b)

Identify each document which reflects,

relates to information pertaining to such warning;

22

refers ro

(c)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

This interrogatory is objected to in

that it is irrelevant to the plaintiffs in this matter,
irrelevant to the issues involved in this case and is not
calculated to lead to the discovery of any further relevant or
admissible evidence.

However, in an attempt to be responsive and

not waiving the objections raised, refer to the answer to
Interrogatory No. 11.

In so responding to this interrogatory,

defendants are not referring to workers or employees.
18. Have you or any of your subsidiaries or corporate
predecessors (defendant) conducted or contracted to have any
entity conduct studies concerning the effects of inhalation of
asbestos dust or fibers on a person using or being exposed to any
of the asbestos materials manufactured by "defendant"? In answer
to this question, please state:
(a)
The date, nature and location of the studies;
(b)
The name or names of the persons conducting the
studies and their address and describe in detail the extent of
their participation;
(c)
The purpose of the studies;
(d)
The identity of each document which refers or
relates to any information set forth in answer to this
interrogatory;
(e) As to any information received orally in answer
to this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

None known presently.

However, air

monitoring studies at other Hercules plants were analyzed at the

23

(c)

As to any information received orally in answer to

this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

This interrogatory is objected to in

that it is irrelevant to the plaintiffs in this matter,
irrelevant to the issues involved in this case and is not
calculated to lead to the discovery of any further relevant or
admissible evidence.

However, in an attempt to be responsive and

not waiving the objections raised, refer to the answer to
Interrogatory No. 11.

In so responding to this interrogatory,

defendants are not referring to workers or employees.
18.
Have you or any of your subsidiaries or corporate
predecessors (defendant) conducted or contracted to have any
entity conduct studies concerning the effects of inhalation of
asbestos dust or fibers on a person using or being exposed to any__
of the asbestos materials manufactured by "defendant"? In answer’
to this question, please state:
(a)
The date, nature and location of the studies;
(b)
The name or names of the persons conducting the
studies and their address and describe in detail the extent of
their participation;
(c)
The purpose of the studies;
(d)
The identity of each document which refers or
relates to any information set forth in answer to this
interrogatory;
(e) As to any information received orally in answer
to this interrogatory, identify each person who su pplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

None known presently.

However, air

monitoring studies at other Hercules plants were analyzed at the
23

Marshallton plant.

In addition, air monitoring studies were

analyzed at the Marshallton plant on behalf of defendant Herty.
Information concerning these studies may be found at files B25,
D3-12.
19.
Has the answering defendant (see definition in No. 18)
conducted any studies designated to minimize or eliminate the
inhalation of asbestos dust and fibers by those exposed to the
use of any of the products containing asbestos materials
manufactured by it? If so:
(a)
The date, nature and location of your studies.
(b)
The name or names of the persons conducting such
studies and their address and describe in detail the extent of
this participation;
(c)
State what action, if any, was taken based upon
such studies in an effort to minimize or eliminate the effects of
inhalation of asbestos dust or fibers upon those using or being
exposed to the dust and fibers contained in such products as
manufactured by your company;
(d)
Identify each document which refers or relates to
any information set forth in answer to this interrogatory.
(e)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

The wording of this interrogatory

suggests studies done for the benefit of customers.

None were

done by Hercules or CCC for that purpose, nor were any requested.
However, air monitoring, warnings and other safety measures were
done and instituted at the Haveg Marshallton plant.
20. What technique, if any, did and/or do you use to make
dust samplings in the manufacturing and packaging production
environment or at job sites where your materials have been used?
(a)
Set forth in detail the technique used, when it
was commenced and when, if ever, it was concluded;
(b)
State the purrpose for administering such
samplings;

24

(c)
State the results of such samplings;
(d)
State what action, if any, has been taken in
response to the findings as to the dust samples;
(e)
Identify each document which refers or relates to
such sampling;
(f)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
(gj
Identify the living person who has the most
knowledge of matters discussed herein.
ANSWER OF HERCULES AND CCC:

Refer to the answer to

Interrogatories No. 16 and 19 and File in B.

To the best of

these defendants' knowledge, any studies by these defendants were
not done at job sites where Haveg asbestos containing products
were used.

'

21. State what, if any safety measures were taken since 1935 by
defendant with regard to its employees, during the processing,
manufacturing and packaging of products containing asbestos which
relate to dust abatement or elimination of the discharge into the
work environment of asbestos particles.
If any such safety
measures were taken, state:
(a)
The reason for the use of such measures, equipment
or clothing;
(b)
The date of implementation of safety measures;
(c)
Identify each document relating to safety
proceudres taken by employees or plant personnel in the
manufacture, processing and packaging of such products;
(d)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information.
ANSWER OF HERCULES AND CCC:
ies No. 16 and 19.

Refer to the answers to Interrogator

Those individuals who provided information in

responding to this interrogatory, in addition to those
individuals whose depositions are referred to in the answer to

25

Interrogatory No. 16, Edward Painter, Drs. Flanders, Heckler and
Reed, and Emil Christofano.
22.
State for the period of time the answering defendant
manufactured or used at its own plants asbestos containing
products the following:
(a)
Knowledge as to any respirator or other breathing
device which was on the market during the relevant period which
would prevent the inhalation of asbestos dust and fibers;
(b)
A detailed description of such respirator or other
breathing device, together with all information as to how such
device prevents the inhalation of asbestos dust and fibers.
(c) What tests, if any, were conducted, by whom and
where, with regard to the effectiveness of any such device;
(d)
Identify each document in any defendant's
possession which refers or relates to the subject matter of this
interrogatory.
(e)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

Refer to files Al, Cl-3, 6-11, 16,

19, 23, 25, 28, 30, 34, 36, 41, 43-44, 50, 53, 58-62, 76.

Robert

Good is believed to be the individual having the most knowledge
regarding the respirators used at Marshallton, and reference
should be made to his deposition.

In addition, other individuals

having knowledge regarding respirators are Dudley Barton, John
Ward, Emil Christofano, Edmund Painter, Eugene O'Neill and Leon
DeBrabander.
23.
Has the "defendant" or any entity (including
associations to which the defendant is or has been a member)
conducted or had conducted any investigation of the statistical
and/or epidemiological relationship between the use of any
product identified in answer to Interrogatory 1 and the
contraction by humans or animals of cancer including but not
limited to mesothelioma.
If so:
26

(a)
Identify each person participating in such
investigation and describe in detail the extent of this
participation;
(b)
State when the investigation was conducted;
(c)
Identify the person or persons who authorized the
investigation;
(d)
Identify each documetn which refers or relates to
any information set forth in answer to this interrogatory;
(e)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF CCC:

To the best of defendant CCC's knowledge, no

formal investigation was conducted by this defendant.

However,

safety measures were instituted at the Haveg plant and health
records of its employees were maintained.

Refer to the answer to

Interrogatory No. 16.
24.
Has the "defendant" or any entity (including
associations to which the "defendant" is or has been a member)
conducted or had conducted any investigation of the statistical
and/or epidemiological relationship between the use of any
product identified in answer to Interrogatory 1 and the
contraction by humans of pulmonary asbestosis.
If so:
(a)
Identify each person participating in such
investigation and describe in detail the extent of his
participation;
(b)
State when the investigation was conducted;
(c)
Identify the person or persons who authorized the
investigation;
(d)
Identify each document which refers or relates to
any information set forth in answer to this interrogatory;
(e) As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF CCC:

None presently known.

25.
If the answering defendant did not respond
affirmatively to interrogatory 1, but undertook the types of

27

inquiries indicated in interrogatories 23 and 24, answer said
interrogatories under this question, including all subparts.
ANSWER OF HERCULES AND CCC;

These answering defendants did

respond to Interrogatory No. 1, but have no idea what information
is being requested in Interrogatory No. 25.
26. Describe in detail all written and oral reports
including those reports concerning users of any of the products
identified in answer to Interrogatory 1, including doctors,
insurance companies, employees and agents of the defendants
concerning any relationship between the use of these products and
the development of pulmonary asbestosis in humans or animals;
(a)
Identify all persons making said reports and to
whom said reports were made;
(b)
State whether any report or series of reports
initiated changes and/or reevaluation of the production, sale or
use, or recommendations for sue, of any of those products;
(c)
Identify each document which refers or relates to
any information set forth in answer to this interrogatory.
(d)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

None except the information

contained in Files A16, 18, C57.

Medical articles and newspaper

articles are contained in files C66 and 68.

Some information was

forwarded to Marshallton by Hercules Medical or Hercules Safety
department, such as changes in OSHA regulations found in files
D14-15, 16-17, 20.

It is believed that no such information was

supplied to CCC by users of Haveg products.

Refer also to the

reports of Liberty Mutual and Employers of Wausau found in files
C2-3.

28

Doctors employed by defendant CCC prepared lists of
employees who had contracted asbestosis as contained in file C72
and the OSHA Logs, file 71.
27. Describe in detail all written and oral reports
including those reports concerning users of any of the products
identified in answer to Interrogatory 1, including doctors,
employees and agents of the defendants concerning any
relationship between the use of any of those products and the
development of cancer including but not limited to mesothelioma
in human's or animals:
(a)
Identify all persons making said reports and to
whom said reports were made;
(b)
State whether any report or series of reports
initiated changes and/or reevaluation of the production, sale or
use, or recommendations for use, of any of those products;
(c)
Identify each document which refers or relates to
any information set forth in answer to this interrogatory;
(d)
As to any information received orally in answer to
this interrogatory, identify each person who suppplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

Refer to the answer to Interrogatory

No. 26.
28. For each product identified in answer to Interrogatory
1, state whether the production and/or sale of the product has
been discontinued, limited or curtailed, and, if so:
(a)
State when it was discontinued;
(b)
State with specificity and particularity all the
reasons for the discontinuance.
(c)
Identify each individual who participated in the
decision to discontinue production and/or sale and describe in
detail the extent of his participation;
(d)
Identify all documents which reflect, refer or
relate to each such discontinuance;
(e) As to any information received orally in answer
to this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.

29

ANSWER OF HERCULES AND CCC:

This interrogatory is objected to in

that it is overly burdensome to determine when each and every
Haveg product containing asbestos was discontinued and specific
dates.

The invoices and supplier information already produced

for plaintiffs found in files Al-57, A2-58-77 and the depositions
taken of former Haveg personnel and Hercules personnel indicate
that asbestos was used at the plant, but removed entirely by the
time of the sale to Ametek on October 8, 1980.

Refer also to

C54-55, files concerning the clean-up.
29. Do you contend that each of the products identified in
Interrogatory 1 or 70 do not or did not create any health risk to
one who applies or uses the product?
(a)
If so, state the factual basis for each such
contention;
(b)
If not, state:
(i) The degree and kind of risk which is created
by such use;
(ii) The conditions under which such risk is
created, increased or decreased;
(iii)
Identify each document which reflects,
refers or relates to your answers to this interrogatory;
(iv) As to any information received orally in
answer to this interrogatory, identify each person who supplied
such information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

(a)

These defendants do not

presently contend that loose airborne asbestos does not cause any
risk to one who uses or applies the product;
(b)

Refer to the warning label information as contained in

response to Interrogatory No. 11 and the documents already
produced.

30

Asbestos products manufactured’at Marshallton contained
encapsulated asbestos.

Potential for exposure to asbestos

related conditions depended upon the amount of and type of
alterations done to the finished product, the length, degree and
extent of exposure, the safety protection devices used and also
upon the working habits and conduct of the worker.
30.
Do you contend that it was not your responsibility to
warn the ultimate user listed in interrogatories 1 or 70 of any
health risk related to products/asbestos?
(a)
State the factual basis for such response;
(b)
Identify each document which reflects, refers or
relates to your answers to this interrogatory;
(c)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER:

This interrogatory is objected to since the exposure

alleged was the result of employment at the Marshallton plant.
Whether or not there was any responsibility to main users of

.

Haveg products is not in issue as to those defendants and
therefore is not relevant.
31.
Do you contend that it was only the responsibility of
the employing company involved, or entities other than the
answering defendant, to so warn the workers of the health risks
or harm to users health arising from the use of your product or
of the danger of asbestos to their health?
(a)
State the basis for such contention;
(b)
Identify which others were so responsible;
(c)
Identify each document which reflects, refers or
relates to your answer to this interrogatory;
(d)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.

31

ANSWER OF HERCULES AND CCC:

It is the position of these

defendants that a responsibility existed on the part of supplier
and insurers to provide warnings.

Hercules was in an advisory or

consultant capacity only when and if information was requested.
For the factual bases, refer to the depositions of Dr. Frawley,
Reed, Flanders and Heckler, John Ward, Dudley Barton and Robert
Good.
32. Do you contend that the health danger to any plaintiff
was not foreseeable by the answering defendant at the time the
products alleged to have caused plaintiff's injuries were sold?
If so, as to each plaintiff:
(a)
State the factual basis for such contention;
(b)
Identify each document relied upon in support of
such contention;
(c)
As to any information received orally in answer tc
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

Plaintiffs were made aware of the

risks and dangers to asbestos exposure at Haveg Marshallton.
Plaintiffs were also advised of the potential hazards by the
physicians employed at Haveg Marshallton, the plant nurses, and
by the administration.

Refer to plaintiffs' medical, employment

and personnel files, files C4-5, 7-11, 16, 19, 23, 25, 28, 30,
34, 36 that deal with the safety committee minutes which were
posted, 39 (dealing with employee suggestions), 41 (dealing with
safety talks), 42 (safety memos), 43 (safety programs), 44
(safety rules), 49 (OSHA folders), 5 (asbestos booklets.

32

pamphlets and movies which were distributed and shown
throughout the plant and 51 (chest x-ray program memos), 52
(physical examinations and memos), 58-62 (memos and warnings to
employees), 69 (physical exam and x-ray procedure manual), 71
(OSHA logs which were posted and 76 (films), the depositions of
Barbara Generaux (plant nurse), Robert Good, Dr. Howard Reed,
Clare Deptula, Elizabeth Elliott, Martha Vogler, Dudley Barton
and John Ward regarding the advice and information orally
provided.
33.
Do you contend that the health consequences to each
plaintiff from the use by each plaintif of products containing
asbestos was obvious? If so, as to each plaintiff:
(a)
State the factual basis for such contention;
(b)
Identify all documents relied upon in support of
such contention;
(c)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

Plaintiffs were made aware of the

risks and dangers to asbestos exposure by Haveg.
also advised

Plaintiffs were

of the potential hazards by the physicians employed

by Haveg, the plant nurses, and by the administration.

Refer to

the answer to Interrogatory No. 32.
34. Do you contend that each plaintiff knew, understood and
appreciated the danger to his/her health arising from his contact
with asbestos products which the answering defendant mined,
distributed, manufactured or allowed to be used within their
production facilities? If so, as to each plaintiff:
(a)
State the factual basis for such contention;

33

(b)
Identify each document relied upon in support of
such contention;
(c) As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

Plaintiffs were made aware of the

risks and dangers to asbestos exposure by Haveg.

Plaintiffs were

also advised of the potential hazards by the physician employed
by Haveg, the plant nurses, and by the administration.

Refer to

the answer to Interrogatory No. 32.
35. Do you contend that plaintiff unreasonably exposed
himself to the danger arising from his contact with asbestos
products which the answering defendant mined, distributed,
manufactured or allowed to be used within the confines of a
facility of the answering defendant? If so, as to each
plaintiff:
(a)
State the factual basis for such contention;
(b)
Identify each document relied upon in support of
such contention;
(c)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

Plaintiffs were made aware of the

risks and dangers to asbestos exposure to Haveg.

Plaintiffs were

also advised of the potential hazards by the physicians employed
by Haveg, the plant nurses, and by the administration.
the answer to Interrogatory No. 32.

Refer to

After receiving such

warnings as indicated above and having the information noted,
failure to follow the procedures recommended by their employer
would be unreasonable.

34

36. Do you contend that plaintiffs used any asbestos
product in other than their usual, customary and expected manner?
If so, as to each plaintiff:
(a)
State the name and chemical composition of the
product claimed to have been used in other than its usual,
customary and expected manner?
(b)
State in detail the manner in which plaintiffs
used said product in other than its usual, customary and expected
manner;
(c)
Identify each document relied upon in support of
such contention?
(d)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:
asbestos products.

Hercules did not manufacture

Haveg products manufactured contained

asbestos (chemical equipment and cement).

Plaintiff-employees

did not use said products, but were employed in the manufacture,
production and processing of said products.

Plaintiff-spouses,

to the best of defendants' present knowledge, never used or came
in direct contact with the products made at Marshallton.
37.
Has the answering defendant ever been named as a
defendant in a proceeding including any other civil action.
Workmen's Compensation actions, filing of Workmen's Compensation
consent agreements, or other proceedings, to recover damages for
injuries resulting from any accident or alleged occupational
disease (including asbestosis, cancer, etc.) as a result of
exposure at the complainant in such proceedings to asbestos from
1925 to 1975?
(a)
State the name and address of each plaintiff;
(b)
State the name and address of each co-defendant;
(c)
State the date it was filed;
(d)
State the name of the Court in which itwas filed;
(e)
Describe the judgment rendered;
(f)
State the date that has been set for hearing or
trial of any case still pending;

35

(g)
Describe the terms of any settlement reached
before or during trial;
(h)
State whether any appeal is pending from any
judgment that has been rendered;
(i)
State the exact nature of the condition alleged in
such action to have resulted from the plaintiffs' use of or
contact with said product and identify the product involved;
(j)
Identify each document which reflects, refers or
relates to any information pertaining to that complaint.
(k)
State the first date any notice of the
complainants' problems came to the attention of the answering
defendant.
(l)
State whether any appeal is pending from any
judgment that has been rendered.
ANSWER OF HERCULES AND CCC;

This interrogatory is objected to in

that it refers to injuries received as a result of using products
identified in Answer to Interrogatory No. 1.

Plaintiffs in the

instant action were involved in the manufacture of certain of
these products, and not in their use.
By way of further objection, the only claims which are
considered relevant are those filed against either defendant
prior to October 8, 1980, the date of the sale of the Marshallton
plant, since defendants believe the intent of this interrogatory
is to establish knowledge of alleged injuries due to exposure to
asbestos or asbestos-containing products.

Without waiving the

objection, refer to Exhibit B.
38. With respect to the period from 1940 through 1980,
state the names, addresses and company title of position of each
person who at any time during that period was in charge of the
following activities with regard to each of the products
identified in answer to Interrogatory 1:
(a)
Production;
(b)
Marketing;

36

I
»

(c)
(d)
(e)
(f)
(g)
ANSWER OF CCC;

Labeling;
’
Advertising;
Product evaluation;
Research and development;
Distribution.
This interrogatory is difficult to answer by the

categories established by the plaintiffs.

However, in an attempt

to be responsive, the following individuals held the following
titles related to the activities contained in this
interrogatory:
(a)

Plant Manager or General Manager, whose

responsibilities would include some degree of involvement in and
final responsibility for all of the activities contained in this
interrogatory: P.L. McWhorter (deceased), 1950-1960; J.V. Norris
(deceased), approximately 1951-1960; J.M.

Ward, 1962-1976; H.

Dudley Barton, 1976-present; G.P. Lynam (prod,

superintendent,

then plant manager), 1952-1954; G.L. Squire (plant manager),
1976-10/80.
(b)
Superintendent or manufacturing manager, whose
responsibilities would include production activities:
R.w. Laird
(superintendent), 1950-1952; E. Bryden, 3/64-12/70; J.W. Cregg,
12/70-6/73; E.G. McDowell, 3/75 to present.
(c)
There was no one person in charge of labeling.
Explained in the deposition of Dudley Barton and answer to
Interrogatory No. 11 was the development of warning or safety
labels.
Regarding any other labels or brochures pertaining to
the properties and uses of the products themselves, it is
presently unknown who would have been "in charge" of that
activity.
(d)
Regarding advertising, this is presently unknown.
(e) and (f) Leon DeBrabander.
4
ANSWER OF HERCULES:
(a) None
‘
(b) None;

37

<

(c)
Refer to the answer to Interrogatory No. 11 and the
depostion of Dudley Barton regarding preparation of warning
labels;
(d) Refer to Exhibit A;
(e) and (f) There was no person presently known to Hercules
who would have been "in charge" of these activities as related to
Haveg products.
39.
Identify the living parties or persons who are the most
knowledgeable about asbestos mined and products containing
asbestos sold and/or distributred by you from 1940 to present.
Identify all documents which relate to such sales and/or
distribution.
ANSWER OF HERCULES AND CCC:

This interrogatory is objected to on

the following bases: the action against defendants is by
employees and their spouses related to exposure in the workplace.
No claim has been raised outside this relationship on or based
upon exposure to products after sold or distributed.

Neither

defendant has been sued in the capacity of a supplier or
distributor.

The information requested is not relevant to the

issues involved, nor calculated to lead to the discovery of
further relevant or admissible evidence.
40.
Has the answering defendant or has anyone on its behalf
attended and/or participated in any conference, seminar, lecture
of symposium dealing with the health hazards of using any product
identified in answer to Interrogatory 1 or 7 or of asbestos in
general and, if so, state:
(a)
The date and place of such conference, seminar,
lecture or symposium;
(b)
The person or persons conduction such conference,
seminar, lecture or symposium;
(c)
The person or persons who attended on your
behalf;
(d)
The subject matter of such conference, seminar,
lecture or symposium;
(e)
The speakers and/or moderators at such conference,
seminar, lecture or symposium;

38

(f) Whether any reports or memoranda were made
concerning the subject matter of such conference, seminar,
lecture or symposium? identifying each such report or memorandum.
ANSWER OF CCC;
From the information presently available, refer
to the deposition of Robert Good regarding the seminars or
conferences that he attended.

It is believed that Mr. Good

attended two AIA meetings in Arlington, VA, in either 1977 or
1979 or .possibly one in each year.

He also attended a conference

in New York City sponsored by the New York Academy of Science in
either 1978 or 1979.

It is believed that Leon DeBrabander and

technicians within his department (Laboratory) attended the NIOSH
training seminar or conference in the late 60's or early 70's to
be educated and trained in the method of measuring dust counts.
Refer to his depositions.
In February 1979, Ed Painter attended a NIOSH seminar in
Cincinnati, Ohio dealing with the sampling and evaluation of
airborne asbestos.
No presently known formal memoranda or reports were made
regarding those conferences? however, the information learned
were included in the safety policies and procedures at
Marshallton.

Information learned from those seminars or

conferences would be contained in files Bl-26.
ANSWER OF HERCULES:

Refer to the deposition of Dr. Flanders

pertaining to the conferences or seminars he attended.

39

It is believed that Dr. Heckler attended the annual meetings
of the American Occupational Medical Association, at which
asbestos and asbestos related conditions may have been discussed.
He also attended the annual meetins of the Academy of
Occupational Medicine in alternate years beginning in 1975, at
which asbestos and asbestos related conditions may have been
discussed.

Dr. Heckler attended the International Chest Disease

Conference in 1979 that did deal with asbestos.

Refer to his

deposition.
41.
Is the answering defendant, any association it belonged
to or any carrier that it had asbestos product liability with,
submit to make a statement at the hearing concerning the dangers
of asbestos conducted in March, 1967 before the House of
Representatives of the United State Congress Sub-Committee on
Labor? If so, identify those persons who are or were associated
with you that participated, and identify any writing concerning
said participation.
ANSWER OF HERCULES AND CCC:

Without more specific information to

identify the hearing, defendants Hercules and CCC are unable to
form a response to this Interrogatory.

At present, neither

defendant has any knowledge.
42.
State when, if at all, answering defendant received
knowledge of the following publications or matters discussed
therein, who received such knowledge and identify all documents
relating to such knowledge:
(a) Fleischer, Viles, Gade and Drinker, "A Health
Survey of Pipe-Covering Operations in Construction Naval
Vessels," 28 J. Indus. Hyg. 9-16.

40

(b)
Selikoff, et al.. "Asbestosis and Neoplasia," 42
Am. J. Med. (1967);
(c)
Selikoff, Churg and Hammon, "The Occurrence of
Asbestosis Among Industrial Insulation Workers," 132 An.. New
York Acad. Sc. 139 (1965);
(d)
"Documentation of the Threshold Limit Vlaues for
Substances in Workroom Air," A.C.G.I.H. (3rd 1971);
(e)
"Threshold Limit Values for 1961," A.C.G.I.H.
(1961).
(f)
1906 report by Dr. H. Montague Murray.
(g)
1934 study by Dr. Anthony J. Lanza, Assistant
Medical.Director of Metropolitan Life Insurance Company.
ANSWER OF HERCULES:

Hercules has no present knowledge of

receiving publications (a)-(c) and (e).
copy of (d).

Hercules does have a

Date received is believed to be around the date of

publication and contained in Hercules Medical Library.
ANSWER OF CCC;

CCC has no specific recollection of these

particular publications.

Information regarding publications

contained in (d) and (e) may be contained in any files found in
Box C.
43. Identify each publication contained in your research
library, or otherwise in your custody, including but not by way
of limitation, your Research and Development Center, all medical
journals, industrial medical journals, industrial hygiene
journals, technical literature in the area of asbestos mining,
manufacture, application and use, and Governmental publications,
dealing with occupational diseases arising from the manufacture
and use of asbestos-containing products. As to all such
publications, state the volumes which are in your custody and
control, when each such volume was received and the present
location of such publications.
ANSWER OF HERCULES:

Refer to Exhibit C.

Defendant Hercules is

unable to state when the publications identified in Exhibit C

41

were received.

The publications are located in Hercules' Medical

Library.
ANSWER OF CCC:
library.

Haveg did not maintain a medical or research

Any such publications presently known that were

received by CCC which were retained have been produced.
44.
As to any threshold limit values published by the
American Conference of Governmental Industrial Hygienists, state
whether you have brought such information to the attention of
those using your products or asbestos products on your premises.
(If yes, how?)
If you have not done so, state the reasons why
you have not done so.
ANSWER OF HERCULES:

Defendant Hercules is not aware of informing

CCC's customers of threshold limit values published by the
A.C.G.I.H.

Contacts with customers were made by CCC's employees.

ANSWER OF CCC:

This defendant at present is unable to state

whether or not such matters were orally discussed with its many
customers over the relevant time period of this litigation.
However, this defendant has no evidence and documentation that
such levels were discussed with customers.
45.
Has answering defendant or any of its employees been:
(a) a member of or (b) affiliated in any manner with or (c)
received reports or (d) subscribed for reports or publications to
the Industrial Hygiene Foundation organized in Pittsburgh,
Pennsylvania?
ANSWER OF CCC AND HERCULES:

(a),

(b) and (d): No, to the best of

these defendants' knowledge.

With regard to (c), reports or

publications of the Industrial Hygiene Foundation may have been
received from time to time.

42

46. With regard to Interrogatory 45, what years did
answering defendant or its employee(s) participate under (a),
(b), (c) or (d)?
ANSWER OF HERCULES AND CCC:

See answer to Interrogatory No.

45.
47. With regard to Interrogatory 45, do you have any
documents obtained from the Industrial Hygiene Foundation? If
so:
..
(a)
List all such documents;
(b)
Who currently has them in their possession?
(c)
When was each received?
(d)
State the name of the individuals who received
such documents or information contained in such documents.
ANSWER OF HERCULES AND CCC:

To the best of these defendants'

knowledge, neither has any such documents in their possession.
If any such reports or publications were received by employees of
CCC or Hercules, such documents were not retained pursuant to
Hercules' Record Retention Policy.
48. Have you received any reports or documents prepared by
Metropolitan Life Insurance Company from 1929 to about 1960,
concerning statistical and other studies of asbestos workers? If
so, state:
(a)
The documents received;
(b)
Who received them and when;
(c)
The current location of the documents.
ANSWER OF CCC AND HERCULES:

No, to the best of these defendants'

present knowledge.
49.
State all chemical, industrial, medical or trade
associations to which you have belonged since 1936.
ANSWER OF HERCULES AND CCC:

Contained in file D19 at Biggs &

Battaglia for review.

43

50. With regard to the associations enumerated in the
answer to Interrogatory 49, state:
(a)
The names of each individual associated with the
answer defendant since that date who have had dealings with each
said association;
(b)
Describe the nature of their dealings with each
such association;
State their last known address;
(c)
(d)
If still employed, their current job and title.
(e)
List all documents related to said
affiliation.
ANSWER OF CCC AND HERCULES:

Defendants object to this

interrogatory as overly broad, burdensome and not likely to lead
to relevant and/or admissible evidence.
51. Name each corporate officer and/or member of corporate
management who attended any meeting and/or conference concerning
the health, safety or medical aspects of asbestos and/or the use
of products containing asbestos, and for each person identified,
state the nature of his participation in each such meeting or
conference.
(a) If any papers were received or given by the
individuals listed for answer to 51, list each such document and
who has copies of them.
ANSWER OF CCC AND HERCULES:

To the best of these defendants'

present knowledge, no corporate officer or member of corporate
management attended any such meetings.

For the purpose of

responding to this interrogatory, these defendants consider
corporate officers and corporate management as synonymous.
52.
State the sources of all asbestos and/or asbestos
containing products which have been incorporated in any product
manufactured or distributed by answering defendant in its own
facility (including installing on its equipment or buildings) or
utilized from 1936 to 1980.
(a) State the names of all individuals associated with
the above stated sources who dealt with or handled your account;

44

(b)
Identify any such document which refers, reflects
or relates to any information provided in answer to this
interrogatory;
(c)
As to any information received orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.
ANSWER OF HERCULES AND CCC:

Hercules was not a purchaser of raw

asbestos or asbestos material to be used in the manufacturing of
any of Haveg products.

As to CCC, the information regarding

suppliers has been provided to plaintiffs by reference to
Interrogatory No. 1 and Files Al-57, A2-58-77.
The individual at Marshallton who is most knowledgeable
regarding suppliers was Paul Reynier.
Ward also have knowledge.

Dudley Barton and John

Refer to their depositions.

Contained

in the files referring to suppliers are the names of those
persons associated with the various suppliers who dealt with or
handled the Marshallton account.
53. State the names of all individuals associated with you
who had any dealings with the requisition and/or procurement of
asbestos or products containing asbestos as indicated in answer
to Interrogatory 52 and for each such person:
(a)
Identify the nature of his associations), the
locations and the dates of their occurrence;
(b)
Identify each document which refers, reflects or
relates to any information provided in answer to this
interrogatory;
(c)
As to any information reeived orally in answer to
this interrogatory, identify each person who supplied such
information and state the full substance of the information
supplied.

45

ANSWER OF HERCULES AND CCC:
No. 52.

Refer to the answer to Interrogatory

54.
State the names of all individuals who dealt with or
handled the account with and/or made any sales to the employers
of the plaintiff of asbestos and/or products containing
asbestos.
(a)
Describe in detail the nature and dates of each
such association with the said accounts;
(b)
Identify each document which refers, reflects or
relates to any information provided in answer to this
interrogatory.
ANSWER OF HERCDLES AND CCC:

This interrogatory appears to be

directed solely to suppliers to which no response is required.
However, for such information, refer to files Al-57, A2-58-77.
55.
Identify each individual whom you expect to call as an
expert witness at the trial of this litigation, and for each
person identified:
(a)
The subject on which the expert is expected to
testify and the substance of the facts and opinions to which he
or she is expected to testify and a summary of the grounds for
each opinion;
(b)
Identify each document referring, relating or
containing any such facts and/or opinions and identify each
individual having custody of each document identified.
ANSWER OF HERCULES AND CCC:

No experts have been retained for

trial.
56.
Identify each individual who you have retained or
employed or anticipate retaining or employing in any way in
preparation of or anticipation of trial in this litigation who is
not expected to be called as a witness at trial, and for each
such individual:
•
(a)
State the substance of any facts or opinion which
he or she has discussed with any agent, employee or
representative of the answering defendant, together with a
summary of the grounds for each opinion;
(b)
Identify each document referring to or containing
such facts and/or opinions, and identify each person having
custody or each document identified.

46

ANSWER OF HERCULES AND CCC;

This interrogatory is objected to on

the basis that it requests information beyond the scope of
Superior Court Civil Rule 26(b)(4).

.

57. State the names, last known addresses and telephone
numbers of each and every person whom you intend to call as a
witness at the trial of this litigation.
(a)
State the substance of any facts or opinion which
he or she has discussed with any agent, employee or
representative of the answering defendant, together with a
summary of the grounds for each opinion;
(b)
Identify each document referring to or containing
such facts and/or opinions, and identify each person having
custody of each document identified.
(c)
Specify witnesses you intend to use at the trial
of this case with respect to the occurrences and/or cause of
plaintiffs' illnesses or with respect to the claimed damages or
with respect to your liability.
ANSWER OF HERCULES AND CCC;

This interrogatory is objected to on

the basis that it requests information beyond the scope of
F.R.C.P. Civil Rule 26, including information subject to the
attorney-client privilege and attorney work product.
Those persons whom defendants presently intend to call as
witnesses at trial are those present and former Hercules and
Haveg personnel and Ametek personnel who have been deposed and
identified to date.
58.

State whether your corporation is and has been insured
(a)
product liability insurance, including "excess or
umbrella" policies;
(b) Workmens' compensation
(c)
For product liability coverage, state:
(i)
If so, the limits of coverage;
(ii)
The name of the insurance company;

for:

47

(iii) Whether this claim has been accepted or
whether a letter of intent to deny coverage has been received.
ANSWER OF HERCDLES AND CCC:
Refer to Exhibit "D".
59.
In whose possession are your and your predecessors*
annual reports from 1936 to the present?
ANSWER OF CCC;

The corporate minutes have been produced and are

contained in files Fl-24.

The only available annual reports are

from 1955-1963 in the possession of H. Dudley Barton.
ANSWER OF HERCULES;

From 1964 to 1980, the Hercules Annual

reports are in the office of the Secretary for Hercules
Incorporated, available for inspection at Hercules.
60.
Describe in detail your policy with respect to the
destruction of records pertaining to each of the products
identified in answer to Interrogatory 1.
(a)
Identify all documents pertaining to your policy,
if any, regarding the destruction of such records;
(b)
Identify the person or persons having custody of
such policy documents;
(c)
Identify the person or persons in charge of
destroying records pertaining to each such product;
(d)
Identify each document which refers, reflects or
relates to any information provided in answer to this
interrogatory.
(e)
Describe what steps, if any, you have taken since
the institution of this action or other actions involving
asbestos to prevent the destruction of any documents relating to
asbestos.
ANSWER OF HERCULES AND CCC;

There was no known records retention

or descruction program at Haveg Marshallton before Hercules'
purchase of the plant.

Retention and destruction of records

depended upon the department or individual with whom the records
were kept.

48

61. State the names of all individuals who aided in the
preparation of these answers, and for each such person, state:
(a)
Which interrogatories they helped prepare or the
particular subject area for which they supplied information.
(b)
Their current position with the company;
(c)
Their current or last known home and business
address and phone numbers.
ANSWER OF HERCULES AND CCC:

Dudley Barton, General Manager of

Ametek, home address contained in his deposition;
Elizabeth Tull, Personnel Manager, Ametek, home address
contained in her deposition;
Dr. Howard Reed, retired Medical Director of Hercules,
address contained in his deposition;
Dr. James F. Flanders, retired Medical Director of Hercules,
address contained in his deposition;
Dr. George B. Heckler, present Medical Director of Hercules,
address contained in his deposition;
Emil Christofano, toxicologist employed at Hercules, work
address: 900 Market Street, Wilmington, DE;
Robert Good, address and position contained in deposition;
Barbara Generaux, address and position contained in
depostion;
Eugene O'Neill, address and position contained in­
deposition;
Leon DeBrabander, address and position contained in
deposition;

49

Clare Deptula, address and position contained in
deposition;
John Ward, address and position contained in deposition;
Harold Haney, retired, address and position contained in
deposition;
Paul Graybeal, retired, address and position contained in
deposition;
Martha Vogler, address and position contained in
deposition.
62.
State all processes used by plaintiff's employer, known
to any defendant where asbestos was an ingredient.
ANSWER OF HERCULES AND CCC: Refer to the answer to Interrogatory
No. 1.
63.
State all use of asbestos insulation by plaintiff's
employer, known to any defendant.
(a) Types of asbestos insulation used;
(b)
Manufacturer and/or brand names;
(c)
Locations in said plants where said insulation was
used;
(d)
The person most knowledgeable in said corporation
about the purchasing of insulation by distributors that covered
the states of New Jersey, Delaware Pennsylvania and Maryland.
ANSWER OF HERCULES AND CCC;

Not applicable to these defendants.

The only information available is contained in file A2-62.
64.
State whether you have entered into any agreement,
either oral or written, with any other defendant in this action
regarding:
(1) Settlement or non-settlement and/or
(2) allocation of damages, should the plaintiffs
prevail on liability.
If the answer is yes to either of the above, state the substance

50

of each such agreement and such parties who have entered into
this agreement:
(a)
Identify those persons who participated in the
preparation of each such agreement and describe in detail the
nature and extent of his participation? and
(b)
Identify each document which contains, refers or
relates to each such agreement.
ANSWER OF HERCULES AND CCC:

This interrogatory is objected to on

the basis that it requests information not relevant to the issues
in this matter.

However, without waiving this objection, the

answer is no, except for the indemnification provisions in the
contract of sale to Ametek.
65.
Do you or your attorneys know of any person or persons
not listed in the preceding answers having knowledge of facts
relevant to the allegations in this lawsuit including witnesses
to the accident, injury, illnesses, etc. in question? If yes,
please state the names, addresses, home telephone numbers, places
of employment, relationship to you, the present whereabouts of
all such persons, and which of said persons you intend to produce
as witnesses in the trial of this action.
ANSWER OF HERCULES AND CCC:

Those individuals who may have

knowledge include any family members of plaintiffs, the
physicians who performed examinations at the Marshallton plant
(Dr. Renzulli, Joseph F. Kestner, M.D., Parviz Sorouri, M.D.,
Roger Thomas, M.D.), treating physicians of plaintiffs as
contained in their medical records, and co-workers of plaintiffs.
At present, defendants would expect to call any and all treating
physicians of plaintiffs.
66.
Do you or your attorneys have any written statements
from any persons having knowledge of facts relevant to the
subject matter of this lawsuit, including witnesses to the

51

accident, injury, illnesses, etc. in question? If yes, please
state the names, addresses, home telephone numbers, places of
employment, relationship to you and the present whereabouts of
all such persons.
ANSWER OF HERCULES AND CCC:

None presently known, except for the

depositions presently taken to date*
67.
State whether you were a member of the Asbestos
Information Association (A.I.A.) or in any manner received
information or participated in any of the association's
activities.
ANSWER OF HERCULES AND CCC:

Neither defendant was a member of

the Asbestos Information Association.

Haveg Industries, Inc. did

receive copies of this organization's monthly newsletter.

The

originals of thhse newsletters are contained in File A50 and have
been provided to plaintiffs' counsel.
believed Haveg Industries, Inc.

As an approximation, it is

received copies of the A.I.A.

Newsletter from 1976 to 1980.
According to the deposition of Robert Good while in the
employ of Haveg, it is believed that Mr. Good attended some
A.I.A. meetings in Arlington, VA in either 1977 or 1978 or
possibly one in each year.
68.
If your answer to any part of Interrogatory No. 67 is
in the affirmative, please state:
(a)
The date, times and places of any A.I.A.- meetings
attended.
(b)
The date and time period during which you received
any publication of the A.I.A.
(c)
The name, address and telephone number of each and
every person who attended such meetings and to whom any such
publications were sent.

52

(d)
The nature of the information that was furnished
at meetings or in such publications.
(e) Name, address and telephone number of the present
or last known custodian of any copies of A.I.A. newsletters,
correspondence or publications.
ANSWER OF HERCULES AND CCC:

Refer to the answer to Interrogatory

No. 67.
69.
If answering defendant or any of its agents or
employeejs received Asbestos Magazine, please state:
(a)
The date and time periods during which you
received such publication.
(b)
The frequency of receipt, e.g., regularly,
occasionally, rarely, etc.
(c)
The terms, circumstances or requirements of
receipt of such publication, e.g., free, by subscription,
distributed at meetings, etc.
(d)
Name, address and telephone number of the present
or last known custodian of any copies of such magazine.
ANSWER OF HERCULES:

To the best of defendant's knowledge, this

magazine was not a publication received directly by Hercules.
ANSWER OF CCC:

This publication was received at the Marshallton

plant through subscription on a monthly basis from 1973-1981.
Copies of these magazines were in the custody of Dudley Barton at
the time litigation was instituted.

Copies of magazines

available have been produced and are contained in File A-3.
70.
Does the answering defendant have in its possession any
medical records, not previously produced in this case relating to
any of the plaintiffs, including, but not limited to, charts,
x-rays, physical examination reports, summaries, tape recordings
of interviews and any and all other records pertaining to the
medical condition of the plaintiffs? If so, plaintiffs request
that such records be produced in accordance with Rule 34.
ANSWER OF HERCULES AND CCC:

None presently known.

53

71.
With respect to each denial and affirmative defense
contained in your response to the Complaint, state the
following:
(a)
Identify which defense it relates to;
(b)
Each fact upon which your contention is based;
(c)
The names and present or last known addresses and
present or last known employer of all persons having knowledge of
any of the facts set out in answer to subparagraph (b) hereof;
(d)
The description or designation of each document
which in any way reflects, relates or refers to any of the facts
set out in answer to subparagraph (b) hereof.
ANSWER; To be provided.
72.
Describe in detail, with specificity and particularity
each product which was being installed, repaired, removed or
otherwise used on the answering defendant's premises at all
relevant times which contained asbestos, and for each such
product describe:
(a)
Its chemical ingredients;
(b)
For each ingredient contained therein state: ,
(i)
The name or chemical composition of each
substance, what harmful effect, if any are known, that it
produces in man or mammals and whether it produces its harmful
effects through ingestion, inhalation, absorption or a
combination of these;
(ii)
When you determined and/or learned that the
substance produced harmful effects and how such effects were
produced;
(iii) Identify each individual who participated in
such determination and/or obtained such knowledge;
(iv)
Identify each document that refers, reflects
or relates to any information pertaining to the properties of
each of the ingredients and/or how the harmful effects are
produced as well as your determination of those toxic effects and
the manner by which they are produced;
(v)
As to any information received orally in
answer to this interrogatory, identify each person who supplied
such information and state the full substance of the information
supplied;
(c)
Whether any of these products were mined,
manufactured or distributed by answering defendant;
(d)
The location within defendants' premises where
said product was being installed, repaired or removed.
ANSWER:

To be provided.

54

73. Provide the information requested in Interrogatory No.
2 for products listed in No. 72.
ANSWER:

To be provided.

74.
For each product identified in answer to Interrogatory
No. 72, identify:
(a)
The general contractor on the project which was
responsible for or participated in the installation, repair or
removal of said product;
(b)
Any subcontractor or other contractor which was
responsible for or participated in the installation, repair or
removal of said product; and state:
(i)
The type of agreement under which each named
contractor was responsible for or participated in such
installation, repair or removal (e.g. subcontractor, independent
subcontractor);
(ii) The extent of each named contractor's
expressed responsibility or participation under said agreement.
(c)
Any other person, firm or entity who was
responsible for or participated in the installation, repair or
removal of said products;
(d)
Each document which refers, reflects or pertains
to any information provided in the answer to this interrogatory;
(e)
As to any information received orally in answer to
this interrogatory, identify each person who has supplied such
information and state the full substance of the information
supplied.
ANSWER: To be provided.
75.
Identify any supervisory personnel of answering
defendant or the entity performing the functions enumerated in
Interrogatory No. 72 who were present during some or all of the
installation, repair or removal of the products identified in
answer to Interrogatory Number 72, and for each such person,
state:
(a)
The name of the person, firm or other entity who
had the authority to hire him/her;
*
(b)
The name of the person, firm or other entity who
had the authority to fire him/her;
(c)
The name of the person, firm or other entity who
actually paid his/her wages;
(d)
The name of the person, firm or other entity who
had control over his/her day to day performance.
ANSWER: To be provided.
55

76.
Identify each and every worker on ans
job site who participated in the installation,
of the products identified in answer to Interro
all relevant times, and for each such person, s
(a)
His job title at the job site?
(b)
His duties at the job site;
(c)
The local union to which he beloi
if any?
;
(d)
The name of the person, firm or c
had the authority to:
(i)
Hire him/her;
(ii)
Fire him/her;
(iii) Pay his/her wages?
(iv)
Control his/her day to day
the job.
ANSWER: To be provided.
77.
For each product identified in answer t
No. 72, state what person, firm or other entity \
or participated in providing said product to the
job site?
(a)
How was the product purchased or c
acquired, before being distributed for use on the
ANSWER: To be provided.
78.
For each product identified in answer t
Number 72 state:
(a) What person, firm or other entity i
obtained said product;
(b) Where it was purchased, and/or obtc
(c)
From whom it was purchased;
(d)
The dates it was purchased;
(e)
The manner in which it was received
distributed for use on the job site.
ANSWER: To be provided.

79.
State whether asbestos products were bei;
repaired or removed on answering defendant's premi:
relevant time in areas where electrical constructs
required to work.
If so, describe:
(a)
Whether and when answering defendanl
of these circumstances;

56

(b)
Any action which defendant took to insure
safety of such workers under these circumstances.
ANSWER; To be provided.
80. State what action, if any, you have taken since
reduce or eliminate any risk of occupational disease or p
injury to those using asbestos products or to those in cl
proximity to those using such products while on your prem
which arises from the inhalation of dust and fibers.
- ANSWER: To be provided.
81.
Describe in full and complete detail each of th
activities which you have undertaken with the intention o
warning workers on your premises of the effects of any pn
identified in answer to Interrogatory 1 as to the health >.
user or those in close proximity to the user and give the
inclusive dates of each such activity, and
(a)
Identify each individual who participated +
and describe the nature of his participation;
(b)
Identify each document which reflects, refe
relates to information pertaining to such warning;
(c)
As to any information received orally in ar
this interroatory, identify each person who supplied such
information and state the full substance of the informatic
supplied.
ANSWER: To be provided.
82.
State what if any safety measures were taken by
to your employees, or other workers on your premises durir.
installment, repair or removal of products containing asbe
If any such safety measures were taken, states
(a)
The reason for the use of such measures, eq
or clothing;
(b)
Identify each document relating to safety
procedures taken by such employee or workers;
(c)
As to any information received orally in an
this interrogatory, identify each person who supplied such
information and state the full substance of the informatio:
ANSWER: To be provided.
83.
Describe in detail all written and oral reports
including those reports originating from suppliers of any r

57

products identified in answer to Interrogatory 72, inclu
doctors, and employees and agents of the suppliers conce
relationship between the use of or proximity to the use <
products and the development of asbestos related illness?
humans or animals:
(a)
Identify all persons making said reports t
whom said reports were made;
(b)
State whether any report or series of repc
initiated changes and/or re-evaluation of the use, or
recommendations for use, of any of those products;
(c)
Identify each document which refers or rel
any information set forth in answer to this interrogatory
(d)
As to any information received orally in a
this interrogatory, identify each person who supplied sue
information and state the full substance of the informati
supplied.

ity all
ction;
ited and
nit, currefers *
nd/or tl
reductic
in answs
such
nation

ANSWER: To be provided.
re the
l of

84.
For each product identified in answer to Interrc
72, state whether the product has been removed from any o:
premises and equipment owned by answering defendant, and,
(a)
State when it was removed;
(b)
State with specificity and particularity al
reasons for the removal;
(c)
Identify each individual who participated i
decision to remove sadi product and describe in detail the
of his participation;
(d)
Identify all documents which reflect, refer
relate to each such discontinuance;
(e)
As to any information received orally in an.
this interrogatory, identify each person who supplied such
information and state the full substance of the informatio
supplied.

for
be
7 the

its
■> V
ntrak.

ANSWER: To be provided.
85.
For each product identified in answer to Interroc
72, state whether the use of that product in any or all of
premises has been limited and/or curtailed, reduced or
discontinued and, if so:
(a)
Describe how it was so limited or curtailed
reduced;
(b)
State when it was so limited, curtailed or
reduced;

es to
se

\
58

? these

y
nswerir
2t fort

these

(c)
State with specificity and particularity e
the reasons for the limitation, curtailment, or reductior
(d)
Identify each individual who participated
extent of his participation in the decision to so limit,
or reduce production and/or sale;
(e)
Identify each document which reflects, ref
relates to the limitation, curtailment or reduction and/o
decision to implement the limitation, curtailment or redu
(f)
As to any information received orally in a:
this interrogatory, identify each person who supplied suclr
information and state the full substance of the informatic
supplied.
ANSWER;

To be provided.

86.
Identify the living parties or persons who are t
knowledgeable about the installation, repair or removal of
asbestos products on your premises during the relevant
dates.
ANSWER:

To be provided.

87.
State what person, entity or firm was responsible for
determining whether asbestos containing products would be
installed, repaired or removed from your premises during th
relevant dates.
;r
s
and
itlon

ANSWER:

To be provided.

88.
(a)
Identify the dates of all sales of
asbestos-containing products by answering defendant (or its
alleged corporate predecessors as set forth in plaintiffs'
complaints) to the railroad defendants in these cases (Amtr
Penn Central Transportation Company and the Pennsylvania
Railroad.)
(b)
Identify all documents concerning such sales
these railroads.
ANSWER OF HERCULES AND CCC:

No answer is required of these

defendants.
89.
Identify all documents concerning sale of
asbestos-containing products by answering defendant to the
railroad defendants and their predecessors to the railroad
defendants:

59

(a)
(b)
hed do

Wilmington, DE railroad shops;
Philadelphia, PA railroad shops.

ANSWER OF HERCULES AND CCC:

No answer is required of the?

defendants.

Notary
1986.

90.
(a)
Describe below in detail each and every
asbestos-containing product sold or manufactured by answer
defendant or its alleged corporated predecessors as set fo
plaintiffs' complaints.
(b)
Describe all similar products that were
-non-asbestos-containing.
ANSWER OF HERCULES AND CCC;

No answer is required of these

defendants.

—

____

M"ary: yat-Trostie "
Bjggg/ & Battaglia
1206 Mellon Bank Center
P.0. Box 1489
Wilmington, DE 19899
Attorney for Defendants
Hercules Incorporated and
Champlain Cable Corporatio

3q.
-t /

■.no

»q.

60

STATE OF DELAWARE:

SS.
NEW CASTLE COUNTY:
This is to certify that copies of the attached doci

Notary Public
Robert Jacobs, Esq.
Jacobs & Crumplar, P.A.
800 Delaware Avenue
P.O. Box 2223
Wilmington, DE 19899

John Elzufon, Esq.
Elzufon & Bailey
1010 Excelsior Center
P.O. Box 434
Wilmington, DE 19899

James F. Davis, Esq.
Hercules, Incorporated
Legal Department
Hercules Plaza
Wilmington, DE 19894

Richard P.S. Hannum, Esq.
Prickett, Jones, Elliott,
Kristol & Schnee
1310 Ring Street
P.O. Box 1328
Wilmington, DE 19899

Warren B. Burt, Esq.
1700 Mellon Bank Center
Wilmington, DE 19801
Roger A. Akin, Esq.
Sawyer & Akin, P.A.
Delaware Trust Building
P.O. Box 112
Wilmington, DE 19899
Jeffrey Austin, Esq.
One Customs House Square
P.O. Box 33
Wilmington, DE 19899

Jeffrey S. Marlin, Esq.
Tybout, Redfearn, Casarino
& Pell
P.O. Box 2092
300 Delaware Avenue
Wilmington, DE 19899
John C. Phillips, Jr., Esq.
Suite 700
200 W. 9th Street
P.O. Box 90
Wilmington, DE 19899

J.R. Julian, Esq.
522 Market Tower
P.0. Box 2171
Wilmington, DE 19899
James W. Kipp, Esq.
Trzuskowski, Kipp, Kelleher
& Pearce, P.A.
11th & Bancroft Parkway
P.0. Box 429
Wilmington, DE 19899

C. Scott Reese, Esq.
Suite 1000
Excelsior Centre
824 Market Street Mall
P.O. Box 1680
Wilmington, DE 19899
Michael Weiss, Esq.
Kimmel & Spiller, P.A.
401 Market Tower
Wilmington, DE 19801

Somers S. Price, Esq.
Potter, Anderson & Corroon
350 Delaware Trust Building
P.0. Box 951
Wilmington, DE 19899
James W. Semple, Esq.
Morris, James, Hitchens & Williams
1105 N. Market Street
P.O. Box 2306
Wilmington, DE 19899
Donald Reid, Esq.
Walter L. Pepperman II, Esq.
Morris, Nichols, Arsht & Tunnell
1105 Market Street
P.O. Box 1347
Wilmington, DE 19899

(
EXHIBIT A
Advertising - Asbestos Products (Prior to 10/9/80)
A.

Agencies

1. Aloysius, Butler and Clark - Approximately May 1980
through October 8, 1980.
2.
It is believed Hercules Incorporated Advertising Dept.(From approximately 2/80 back to approximately 1969-1970)
provided assistance.
3.
Prior to the above, neither Haveg nor Hercules has any
files to indicate any agencies involved.
B.

Media Advertising
1.

8/80 through 10/80 - (proposed and assumed)
a.
Chemical Engineering - August and October 1980;
b.
Chemical Processing - September and October 1980;
c.
Chemical Equipment - September 1980;
d. Consulting Engineer - October 1980;
e. Thomas Register - 1980 Edition.

2.
Prior to 8/80 it is believed advertising divided between
B.l a, b and c plus Chemical Week.
Neither defendant has file
retention prior to this.

EXHIBIT B
RE:

INTERROGATORY NO. 36
Workmen’s Compensation Actions

Answer of Defendant CCC:
Refer to workmen's compensation claims produced in
these actions, as well as the state court, actions.
Answer of Defendant Hercules:
There have been no workmen's compensation actions f
against defendant Hercules with regard to use of products
identified in answer to Interrogatory No. 1.
Civil Action
Answer of Defendant CCC:
Subject to the objection and limitat
contained in answer to Interrogatory No. 36, defendant Haveg h
been named as defendant in the following civil actions: Quattr
v. Armstrong Cork Company, et al.
(a)
Joseph Quattrini, 92 Wheaton Road, East Haven,
Connecticut 06512;
(b)
Co-defendants:
Armstrong Cork Company; Amatex
Corporation; Carey Canada; Celotex Corporation; Combustion
Engineering, Inc.; Eagle-Picher Industries; Empire Ace Insulati
Manufacturing Corp.; Fibreboard Corporation; Forty-Eight
Insulation, Inc.; G.A.F. Corporation; Gale Corporation; Garlock
Inc.; H.K. Porter & Co.; Haveg Industries, Inc.; J.P. STevens
Company, Inc.; Johns-Manville Sales Corporation; NIcolet, Inc.;
Owens-Corning Fiberglass Corporation; Owens-Illinois, Inc.;
Pittsburgh Corning Corporation; Rock Wool Manufacturing Co.,
Inc.; Southern Textile Corporation, Inc.; and Unarco Industries
Inc.
Defendant does not have addresses for the codefendants;

.

(c) and (d) Filed in the U.S. District Court, Districi
of Connecticut, September 18, 1980;
(e)

No judgment has been rendered;

(f)

No date has been set for trial;

(g)
This portion of Interrogatory No. 36 is objected
to as beyond the scope of Rule 26(b);
(h)

Not applicable;

(i) Mesathelioma; plaintiff claims he came in contact
with the following Haveg products: Haveg tanks and pipes;
(j)

Pleadings filed in this actions.

EXHIBIT C

(

C

DOCUMENTS
1 TO
51
PAGE =
1 OF
02000
108
DOCUMENT=
1 OF
51
CLASS
= RP
YEAR
= 71
GENERAL
YEAR=71 DOCNO=
108
DOCCODE=RP
REFCODE=
DA1AC0’
REFERENCE EPA BACKGROUND INFO PRPSD STANDS (DEC 1971)
TERMS *
ASBESTOS / BERYLLIUM / MERCURY / STANDARD NATL EMISSION t02000 1482
DOCUMENTS
2 OF
51
CLASS
= RP
YEAR
= 73
GENERAL
YEAR=73 DOCNO=
1482
DOCCODE=RP
REFCQDE=
DATACd)
REFERENCE NEW YORKER 16PP (1973) BRODEUR P
ASBESTOS / ASBESTOSIS WORKER //
TERMS *
02000 3508
DOCUMENTS
3 OF
51
CLASS
= RP
YEAR
= 70
GENERAL
YEAR=70 DOCNO=
3508
DOCCODE=RP
REFCQDE=
DA1AC0D
REFERENCE ARCH ENVIR HEALTH 20, 481-2(1970) MT SINAI SCHOOL. MED
TERMS
CMC USE / VINYLF'YRIDINE-N-OXIDE POLYMER USE / DRUG ANTlHb
* - CMC / ASBESTOS FIBER HEMOLYTIC / ANTAGONISM //
02000 3523
DOCUMENTS
4 OF
51
** STAIRS/VS UNDER IMS **

r

f

DOCUMENTS
1 TO
51
PAGE =
2 OP
17
CLASS
= RP
YEAR
= 68
GENERAL
YEAR=68 DOCNO= 3523
DOCCODE=RP
REFCODE3
PATACUl)E=
REFERENCE ANN OCCUP HYG 11, 1-6(1968) PHS, EDUARDS GH, LYNCH JR
ASBESTOS DETN / AIR ANAL / ANAL PROC PHS //
TERMS *
02000 3895
DOCUMENT3
5 OF
51
CLASS
= RP
YEAR
= 71
GENERAL
YEAR=71 DOCNO3 3895
DOCCODE=RP
REFCODE3
DATACODE*
REFERENCE IND HYG REV 13, 3-5(JAN 1971) NY DIV IND HYG, SHEINBAUM
TERMS «
ASBESTOS SPRAYING / HANDLING //
02000 3896
DOCUMENT3
6 OF
51
CLASS
= RP
YEAR
= 68
GENERAL
YEAR=6B DOCNO3 3896
DOCCODE3RP
REFCODE3
PATACOPE3
REFERENCE HMSO, FACTORY INSPECTORATE ASBESTOS REGS 1968, 4PP
TERMS *
ASBESTOS / REGS FACTORY INSPECTORATE / ENG //
02000 3906
DOCUMENT3
7 OF
51
CLASS
3 RP
YEAR
3 68

. *# STAIRS/VS UNDER IMS

**

h

P

F

*

■ '

C

'(

DOCUMENTS
3 OF
1?
51
1 TO
PAGE =
GENERAL
DOCNO= 3906
YEAR=68
DOCCODE=RP
REFCODE=’
DAlACODEs
REFERENCE J OCCUP MED 10, 38-41(JAN 1968) PHS, CRALLEY LJ ET AL
TERMS *
ASBESTOS / HANDLING / RES REV //
02000 3907
D0CUMENT=
8
OF
51
CLASS
= RP
YEAR
= 68
GENERAL
YEAR=68
DOCNO= 3907
DOCCODE=RP
REFCODE=
DATACODE®
REFERENCE J OCCUP MED 10, 25-31(JAN 1968) UNIV CAL, BALZER JL
TERMS *
ASBESTOS USE / HANDLING / INSULATION //
02000 3908
DOCUMENT=9
OF
51
CLASS
= RP
YEAR
= 68
GENERAL
YEAR=68
DOCNO= 3908DOCCODE=RP
REFCODE=
DATAC(Jl)E=
REFERENCE MED TIMES 96, 1223-9(DEC 1968) NY DEPT LABOR, KLEINFELD M
TERMS #
ASBESTOS / ASBESTOSIS / CA MAN //
02000 3909
DOCUMENTS
10 OF
51
CLASS
= RP
YEAR
s_ 68
GENERAL
YEAR=68
DOCNO= 3909
DOCCODE=RP
REFCQDE=
J>ATACOI)F =
REFERENCE J OCCUP MED 10, 21-4(JAN 1968) PHS, LYNCH JR, AYER HE
** STAIRS/VS UNDER IMS **

FI.

fl

Fi

Fi

c

c

DOCUMENTS
1 TO
51
PAGE =
4 OF
1?
TERMS *
ASBESTOS / TLV / TEST PROC //
02000 3910
DOCUMENT=
1 1 OF
51
CLASS
= RP
YEAR
= 68
GENERAL
YEAR=68 DOCNO=
3910
DOCCODE=RP
REFCOI)E=
I)ATACOI)E=
REFERENCE J OCCUP MED 10, 32-7(JAN 1968) UNIV CAL, TABERSHAld IR
TERMS *
ASBESTOS / HANDLING / CA MAN //
02000 3911
DOCUMENT=
12 OF
51
CLASS
= RP
YEAR
= 66
GENERAL
YEAR=66 DOCNO=
3911
DOCCODE=RP
REFCODE=
DATACHDE=
REFERENCE MED SER BULL NO 11, 16PP (1966)
TERMS *
ASBESTOS / HANDLING / RES IND REV //
02000 3912
DOCUMENT=
13 OF
51
CLASS
= RP
YEAR
= 05
GENERAL
YEAR=05 DOCNO=
3912
DOCCODE=RP
REFCODE=
I)ATACODt:=
REFERENCE INTL OCCUP SAFETY HEALTH INF CENTRE CIS BIBLIO NO 6, 39PP
TERMS «
ASBESTOS / HANDLING / ASBESTOSIS / CA MAN / LIT SURVEY //
02000 3913
DOCUMENT=
14 OF
51
** STAIRS/VS UNDER IMS **

FI A

M A

FLA

DOCUMENTS
1 TO
51
PAGE =
5 OF
i?
CLASS
= RP
YEAR
= 69
GENERAL
YEAR=69 DOCNO=
3913
DOCCODE=RP
REFCODE=
DATACOI)E=
REFERENCE OCCUP HEALTH NEWS + VIEWS (PA DEPT HEALTH) 7, 2<WINTER 1969)
TERMS *
ASBESTOS / LABELING //
©2000 3914
DOCUMENT=
15 OF
51
CLASS
= RP
YEAR
= 68
GENERAL
YEAR=68 DOCNO=
3914
DOCCODE=RP
REFCODE=
DATACOI)E=
REFERENCE DIS CHEST 54, 17-19(JULY 1968)INST OCCUP HEALTH (FINLAND)
TERMS *
ASBESTOSIS ULTRASONIC EXAMN //
02000 3915
DOCUMENT=
16 OF
51
CLASS
= RP
YEAR
= 68
GENERAL
YEAR=68 DOCNO=
3915
DOCCODE=RP
REFCODE=
DATACODh=
REFERENCE NEW YORKER, 27PP(0CT 12, 1968) BRODEUR P
TERMS *
ASBESTOS / HANDLING / LIT SURVEY //
02000 3916
-DOCUM'ENT=
17 OF
51
CLASS
= RP
YEAR
= 68

** STAIRS/VS UNDER IMS **

FLA(

FLAi

H_A

DOCUMENTS
1 TO
51
“
PAGE =
6 OF
17
GENERAL
YEAR=68
DOCNO= 3916
DOCCDDE=RP
REFCODE=
DAIACUDE=
REFERENCE FCT 6, 565-6(1968) ROYAL CANCER HOSPITAL LONDON, ROE FjC
TERMS *
ASBESTOS / ASBESTOSIS / CA MAN //
02000 3917
DOCUMENT=
18 OF
51
CLASS
= RP
YEAR
= 68
GENERAL
YEAR=6B
DOCNO= 3917
DOCCODE=RP
REFCOI)E=
DAlACOl>t=
REFERENCE FCT 6, 566-8(1968) ROYAL CANCER HOSPITAL LONDON, ROE ET AL
TERMS #
ASBESTOS / CA MICE //
02000 3918
DOCUMENTS
19 OF
51
CLASS
= RP
YEAR
= 70
GENERAL
YEAR=70
DOCNO= 3918
DOCCODE=RP
REFCGDE=
DAThCuDF=
REFERENCE FCT 8, 207-10(APR 1970) ANONYMOUS
TERMS *
ASBESTOS / ASBESTOSIS / CA MAN //
02000 3919
DOCUMENTS
20 OF
51
CLASS
= RP
YEAR
= 69
GENERAL
YEAR=69
DOCNQ= 3919
DOCCODE=RP
REFCODE=
DATACOI)E=
REFERENCE FCT 7, 649(NOV 1969) ANONYMOUS
** STAIRS/VS UNDER IMS **

FLAG

H.AG

t- LA(-

F LAi

c
DOCUMENTS
1 TO
51
PAGE =
T OF
17
TERMS *
ASBESTOS / HANDLING / REGS STATUTORY INSTRUMENT NO 69© / ENG //
02000 3920
DOCUMENT=
21 OF
51
CLASS
= RP
YEAR
= 68
DATACGDLs
REFCODEs
GENERAL
YEAR=68
DOCNO= 3920
DOCCODE=RP
FLAG
REFERENCE FCT 6, 657-9(DEC 1968) ANONYMOUS
TERMS *
ASBESTOS / ASBESTOSIS / CA MAN //
©2000 3922
DOCUMENTS
22 OF
51
CLASS
= RP
YEAR
= 67
REFCODE=
DAlACODEs
GENERAL
YEAR=67
DOCNO= 3922
DOCCODE=RP
FLAG
REFERENCE ARCH ENVIR HEALTH 15, 177-80(1967) NY DIV IND HYG, KLEINFELD+
TERMS *
ASBESTOS / CA MAN /✓
51
23 OF
©2000 3923
DOCUMENTS
CLASS
= RP
YEAR
= 65
DOCCODE=RP
REFCODEs
DATACODE=
FLAG
GENERAL
YEAR=65
DOCNOs 3923
REFERENCE ARCH ENV.IR HEALTH 11 , 221-9(AUG 1965) INTL UNION AGAINST CA
TERMS *
ASBESTOS / CA //
.
51
02000 3924
DOCUMENTS
24 OF

#* STAIRS/VS UNDER IMS **

c

c

DOCUMENTS
1 TO
51
PAGE =
8 OF
17
CLASS
= RP
YEAR
= 66
GENERAL
YEAR=66 DOCNO=
3924
DOCCODE=RP
REFCODE=
DATACOI)E=
FLAG
REFERENCE ARCH ENVIR HEALTH 13, 171-84(AUG 1966) UNIV CINCINNATTI KEANF U+
TERMS *
ASBESTOS USE / GLASS FIBER USE / INSULATION / PIPE / LIT SURVEY //
©2000 3925
DOCUMENT=
25 OF
51
CLASS
= RP
YEAR
= 66
GENERAL
YEAR=66 DOCNO=
3925
DOCCODE=RP
REFCODE=
DATACOI>E=
FI AG
REFERENCE ARCH ENVIR HEALTH 13, 619-21(NOV 1966) PA DEPT HEALTH. LIEBEN
TERMS *
ASBESTOS / ASBESTOSIS / CA MAN //
©2000 3926
DOCUMENT=
26 OF
51
CLASS
= RP
YEAR
= 68
GENERAL
YEAR=6B DOCNO=
3926
DOCCODE=RP
REFCOI)F=
l)ATAr;()J>F=
FI.A(
REFERENCE AM IND HYG ASSN J, 195-201(1968) INST OCCUR HEALT, NORO
TERMS #
ASBESTOS / ASBESTOSIS / FIN //
02000 3927
DOCUMENT=
27 OF
51
CLASS
= RP
YEAR
= 70

*# STAIRS/VS UNDER IMS **

DOCUMENTS
1 TO
51
PAGE =
9 OF
17
GENERAL
YEAR=70 D0CN0= 3927
DOCCODE=RP
REFCOI)E=
I)ATAOrU)E=
Fi Ai
REFERENCE AM IND HYG ASSN J, 598-604(SEPT-OCT 1970) HEW, LYNCH JR, AYER
TERMS *
ASBESTOS / EXP INDEX //
'
02000 3928
DOCUMENT=
28 OF
51
CLASS .
= RP
YEAR
= 69
GENERAL
YEAR=69 DOCNO= 3928
DOCCODE=RP
REFCODE*
I)A J'ACODF=
FlAf
REFERENCE AM IND HYG ASSN J, 236-44(1969) NIH/NCI, STATON MF+
TERMS *
ASBESTOS / CA RAT //
02000 3929
DOCUMENT=
29 OF
51
CLASS
= RP
'
YEAR
= 66
GENERAL
YEAR=66 DOCNO= 3929
DOCCODE=RP
REFCf)I)E=
DATACODE=
FLA?
REFERENCE CHEM WEEK, P 32(SEPT 10, 1966) ANONYMOUS
TERMS »
ASBESTOS / POLLUTION AIR / CA MAN- //
02000 3930
DOCUMENT=
30 OF
51
CLASS
= RP
YEAR
=
66'
GENERAL
YEAR=66 DOCNO= 3930
DOCCODE=RP
REFCODE=
DATACOPE=
FLA'
REFERENCE CHEM WEEK, 1 P(OCT 8, 1966) LETTER TO ED:JOHNS-MANVILLE, HACKNEY
*# STAIRS/VS UNDER IMS **

<

c

DOCUMENTS
1 TO
51
PACE =
10 OF
1?
TERMS *
ASBESTOS / POLLUTION AIR / CA MAN / CRITICISM //
02000 5763
DOCUMENT=
31 OF
51
CLASS
= RP
YEAR
= 62
GENERAL
YEAR=62
DOCNO= 5763
DOCCODE=RP REFCODE=SM
DATACODE=
REFERENCE CLIN PHARM THERAP 3, 774-813(1962)HUEPER UC
TERMS
CHEM / ORG COMPD
/ METAL / POLYMER / CA / LITSURVEY //
FOOD ADD / FOOD COLORANT / CA / LIT SURVEY //
CA LUNG / ENG / CONN / OHIO / LIT SURVEY //
CA / WORKER / JOB / LIT SURVEY //
«
ASBESTOS / CHROMATE / CA / LIT SURVEY //
02000 6590
DOCUMENT=
32 OF
51
CLASS
= RP
'
YEAR
= 74
GENERAL
YEAR=74
DOCNO= 6590
DOCCODE=RP
REFCODE=
l>fi1At.:ii»E=
REFERENCE BRIT J CANCER 29, 252-69(1974) LLANBOUGH HOSPITAL, WAGNER
TERMS *
ASBESTOS / ASBESTOSIS / CA / INHAL DUST A,C:RaT //
02000 6591
DOCUMENT=
33 OF
51
CLASS
= RP
YEAR
= 74

** STAIRS/VS UNDER IMS **

FLAf

Ft.A>

c
DOCUMENTS
1 TO
51
PAGE =
11 OF
17
GENERAL
YEAR=74 DOCNO® 6591
DOCCODE=RFREFCODE®
DATACODE®
FLAG
REFERENCE BRIT J IND MED 31, 105-12(1974)FIN CA REGISTRY, MEURMAN UJ+
TERMS *
ASBESTOS ANTHOPHYLLITE / MORTALITY UORKER MINE / C-A LUNG XhilK'lNG /
FIN //
*
ASBESTOS ANTHOPHYLLITE / ILLNESS WORKER MINE / C.A LUNG SMOKING /
FIN //
#
ASBESTOS ANTHOPHYLLITE / ASBESTOSIS / CA LUNG SMOKING / FIN //
©2000 6592
DOCUMENT®
34 OF
51
CLASS
= RP
YEAR
= 75
GENERAL
YEAR=75 DOCNO® 6592
DOCCODE=RP
REFCODE®
DaTACODE®
FLAG
REFERENCE OCCUR SAFETY+HEALTH REPORTER 4, 865(1975)
TERMS *
ASBESTOS / REGS OSAHRC //
02000 6593
DOCUMENT®
35 OF
51
CLASS
= RP
YEAR
= 75
GENERAL
YEAR=75 DOCNO® 6593
DOCCODE=RP
REFCODE®
DAIACODE®
FLAT
REFERENCE FED REG 40, 47652-65(10-09-75)
TERMS *
ASBESTOS / REGS OSHA PRPSD //
02000 7042
DOCUMENT®
36 OF
51
** STAIRS/VS UNDER IMS **

c

c

DOCUMENTS
1 TO
51
'
PAGE 55
12 OF
1?
CLASS
= RP
YEAR
=75
GENERAL
YEAR=75
DOCNO= 7042
DOCCODE=RP
REFCODE55
DATACODE=
REFERENCE AIHAJ 36, 83-90 (FEB 1975) AIHA-ACGIH COMM
TERMS *
ASBESTOS DETN / AIR ANAL / ANAL PROC AIHA-ACGIH //
02000 9040
DOCUMENT55
37 OF
51
CLASS
55 RP
YEAR
= 76
GENERAL
YEAR=76
DOCNO= 9040
DOCCODE=RP
REFCODE55
DATACODE55
REFERENCE EXPERIENTIA 32, 602-4(1976)CASE WESTERN RESERVE, EPSTEIN SS+
TERMS *
ASBESTOS CHRYSOTILE / A OR .'MONKEY /
PANCREAS DNA INCREASE 9-D POST DOSE //
02000 9364
DOCUMENT55
38 OF
51
CLASS
= RP
YEAR
= 75
GENERAL
YEAR==75
DOCNO55 9364
DOCCODE=RP
REFCODE55
DATACf)DE=
REFERENCE J PHARM SCI 64, 1435-49(SEPT 1975)FDA, HALEY TJ
TERMS *
ASBESTOS- / TOX / CA / LIT SURVEY //
*
ASBESTOSIS / TOX / CA / EPIDEMIOLOGY / LIT SURVEY //
02000 9461
DOCUMENT55
39 OF
51
** STAIRS/VS UNDER IMS **

FLAG=

FLAG5

FI ai;

13 OF
17
PAGE =
DOCUMENTS
1 TO
51 .
CLASS
= RP
YEAR
= 72
DOCCODE=RP
REFCODE=
DATACOI)E=
GENERAL
YEAR=72
DOCNO= 9461
FLAG
REFERENCE BRIT J EXP PATH 53, 190-201(1972) CAMBRIDGE UNIV, DAVIS J
TERMS
MINERAL / PLEURAL INJECTION: MICE(DUST) / FIBROSIS VS FIBER ST7.E //
*
ASBESTOS CHRYSOTILE / PLEURAL INJECTION:MICE(DUST)C0N1R0l /
FIBROSIS //
0200010014
DOCUMENT=
40 OF
51
CLASS
= RP
YEAR
= 73
GENERAL
YEAR=73
D0CN0=10014
DOCCODE=RP
REFCODE=
I)AlftCOI>E=
H. *G
REFERENCE LANCET, 807-09(APR 14, 1973) IMP CANCER RES, MAROUDAS NG Ef AL
TERMS *
ASBESTOS / MESOTHELIOMA RAT(FIBER LENGTH) / CA //
0200010253
DOCUMENT=
41 OF
51
CLASS
= RP
YEAR
= 71
GENERAL
YEAR=71
D0CN0=10253
DOCCODE=RP
REFCODE=
DA1AC0DE=
FLAG
REFERENCE NATL ACAD SCI, 40PP (1971)
.
TERMS *
ASBESTOS / EPIDEMIOLOGY / LIT SURVEY //
.
0200010289
DOCUMENT=
42 OF
51
** STAJ.RS/VS UNDER IMS **

c
DOCUMENTS
1 TO
51
PAGE =
14 OF
1?
CLASS
= RP
YEAR
=72
GENERAL
YEAR=72
D0CN0=102B9
DOCCODE=RP
REFCODE=SM
DATACODE=
F| AG
REFERENCE NIOSH 1972 PH, CRITERIA FOR RECOMMENDED STD
TERMS «
ASBESTOS MANUF / INHAL WORKER / REGS NIOSH / LIT SURVEY //
©200010773
DOCUMENT=
43 OF
51
CLASS
= RP
YEAR
= 60
GENERAL
YEAR=60
D0CN0=10773
DOCCODE=RP
REFCODE=
DATaCODF_=
FLAG
REFERENCE CANCER PROG 1960, 81-97(1960) BIDSTRUP PL
TERMS *
CHROMATE / NICKEL / ASBESTOS / CA WORKER / LIT SURVEY //
0200011064
DOCUMENT=
44 OF
51
CLASS
= RP
YEAR
=71
GENERAL
YEAR=71
D0CN0=11064
DOCCODE=RP
REFCODE=
DATACODF.=
FLAi
REFERENCE ANN NY ACAD SCI 172, 757-72(1971)MT SINAI SCHOOL MED,SCHN[fZER R
TERMS *
ASBESTOS FIBER / DIVEMA / CMC / ANTAGONISM / HEMOLYSIS IN VITRO //
0200011641
DOCUMENT=
45 OF
51
CLASS
= RP
YEAR
= 74

** STAIRS/VS UNDER IMS **

c

c

DOCUMENTS
1 TO
51
PAGE =
15 OF
17
GENERAL
YEAR=74
D0CH0=11641
DOCCODE=RP
REFCOI)E=
I)ATACODE=
FI A
REFERENCE BRIT J IND MED 31, 105-12 (1974)
TERMS *
ASBESTOS ANTHOPHYLLITE / HEALTH / MORTALITY / WORKER MINE / F3N //
0200013679
DOCUMENT=
46 OF
51
CLASS
= RP
'
YEAR
= 73
GENERAL
YEAR=73
D0CN0=13679
DOCCODE=RP
REFCODE=
DATACODE=
FLA
REFERENCE FED REG 38, 27876-81(SEPT 28, 1973)
TERMS *
ASBESTOS / FOOD FILTRATION / DRUG FILTRATIUN / REGS FDA FKFSD //
0200014294
DOCUMENT=
47 OF
51
CLASS
= RP
YEAR
= 78
GENERAL
YEAR=78
D0CN0=14294
DOCCODE=RP
REFCQI)E=
DATAL'.m>E=
FI.A
REFERENCE NIH 105P (MAY 1978) PH
,
TERMS «
ASBESTOS / MONOGRAPH NIH / LIT SURVEY //
0200015330
DOCUMENT=
48 OF
51
CLASS
= RP
YEAR
=
79•
GENERAL
YEAR=79
D0CN0=15330
DOCCODE=RP
REFCQDE=
DATAC(U>E=
FI.A
REFERENCE NIOSH 75P (APR 79)PH
•
** STAIRS/VS UNDER IMS **
.

c
DOCUMENTS
1 TO
51
PAGE =
1A OF
1?
TERMS *
ASBESTOS / FIBERGLASS / FIBER DEPOSITION PULMONARY,GJ //
MINERAL(GLASS)WOOL /FIBER DEPOSITION PULMONARY,GI //
0200015514
DOCUMENT=
49 OF
51
CLASS
= RP
YEAR
= 76
GENERAL
YEAR=76
D0CN0=15514
DOCCODE=RP
REFCODE=
DATACODF.=
REFERENCE NIOSH 96P (DEC 1976) PH REVISE CRITERIA DOC
TERMS *
ASBESTOS / REGS NIOSH REVISE / LIT SURVEY //
0200015714
DOCUMENT=
50 OF
51
CLASS
= RP
YEAR
= 79
GENERAL
YEAR=79
D0CN0=15714
DOCCODE=RP
REFCQDE=
DATACODE=
REFERENCE SCIENCE 204, 195-8 (APR 1979) EPA, COOK P + OLSON G
TERMS *
ASBESTOS / PERSORPTION INTESTINAL //
0200017379
DOCUMENT=
51 OF
51
CLASS
= RP
YEAR
= ao
GENERAL
YEAR=80
D0CN0=17379
DOCCODE=RP
REFCODE=
DATACODE=
REFERENCE NIOSH 106P (FEB 1980) F'H
TERMS *
TALC / ASBESTOS / WORKER EXP / MORTALITY / EPIDEMIOLOGY //
** STAIRS/VS UNDER IMS *#

FLAG

FLAG

FLAf

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DOCUMENTS

1

TO

<
51

PAGE =

17 OF

17

liag
R0601

* END OF DOCUMENTS IN LIST - ENTER RETURN OR ANOTHER COMMAND«,
»* STAIRS/VS UNDER IMS **

Asbestos.
Vr,-f F.

mt; ■•( At- !‘t D. }

Little
^A.B.)
Inc,

Impact of proposedOQHA standard for n«
os; : st report to the U.S. Dept, of Labor.
zb, : 972.
r.d.

I-r.

Issued as HB-2B3 ^78

•

621.312.____ A s'b e s_t o b..
.1455
ilonkhouse, Allan.
,
i
Electrical insulating materials.
:
1926..
(Page 188.)

Vert.F..
Asbestos.
U.S.
U.S. Standards bureau
Stan- Building materials and structu.
dards Report 122
Bureau
Physical properties of soaf
of asbestos-cement siding.
19;

Asbestos.
620.195
U53
Jnit« Id States. Standards Bureau.
apecS al Publication 506.
(Proceedings of workshop in asbesto
itior s and measurement methods; ... hel'
lait> ersburg, bd., July 18-20, 1977; ed
Wash., Govt., 19'
JTUVZ tt and others.'
i496o. illus.. tables, charts, diag.

Heferences.

8.850
Eer

Asbestos with plastics and rubber.
N.Y., Chenical Pub. Co., 1966.
Berger, Hans.

f F

■sbestos. Toxicit^.
Air
u.s. National Institute of Occunational Safety
Pollution
a id Health/'-Pub. no. 80-115.
Occupational exposure to talc containing
asbe stos. 1980.
/.DKEW (NIOSH)

_____Asbestos; the need for and feasibility of
Vert.F.
air pollution controls.
1971*
National
Research 'iaticnal Research Council. Division of Medical
Council
Scf ences

<r
-

6.200
BER

C

Asbestos fundamentals
Bergeri Hans

1963.

6.200
Ber

Asbestos fundamentals.. Origin, Pro­
perties, mining, processing, uti­
lization. N.Y., Chemical Pub. Co,
1973.
Berger, Hans.

Vert.F.
Asbestos

Asbestos hazards; selected bibliography.1975
•Environmental Protection Agency.
EPA ’01 '9-78-004.

Asbestos Textile Institute
Chrysotile asbestos test aanual. 3rd ed.
Villov Grove, PA, 1974
Various pagings $20.00
Held by C J Caspbell
frucbcc 7iSbjctcs Hiiii-ag—Ai>socia Lion

A5S-SST0S

Vert.FJ

Asbestos textile Institute.

Textile c?

Handbook of asbestos textiles
ed.
I96".

3rd.

c

C

EXHIBIT D

SCHEDULE OF INSURANCE COVERAGE
HAVEG INDUSTRIES
WORKERS1 COMPENSATION/EMPLOYERS' LIABILITY
Limits
Carrier
Primary
Liberty Mutual
INA

Employers Mutuals
of Wausau

Policy Period

Policy Number

1/1/45-1/1/59

Unavailable

1/1/59-1/1/60
1/1/60-1/1/61
1/1/61-1/1/62
1/1/62-1/1/63

•1
II

'

WC-306958
WC-349396

w.c

E.L.

Statutory

Unknown

n

m

«i

m

m

*

m

n

«*
n
1/1/63-1/1/64
0514-00-062374
ii
•i
1/1/64-1/1/65
0515-00-062374
it
it
1/1/65-1/1/66
0516-00-062374
ii
1/1/66-1/1/67
0517-00-062374
•i
it
1/1/67-1/1/68
0518-00-062374
$5MM
1/1/68-1/1/69
0518-00-062374
Statutory
n
ft
0510-02-062374
1/1/69-1/1/70
N
n
0511-11-062374
1/1/70-1/1/71
■
0512-02-062374
$2MM
1/1/71-1/1/72
This policy was endorsed to exclude Haveg, Marshallton
Location effective 9/1/71.
ii

Self-Insured

9/1/71-10/8/80

(Haveg's Marshallton Location only)

CGL, INCLUDING PRODUCTS LIABILITY
Employers Mutuals

Aetna C&S

1/1/63-1/1/64
1/1/64-1/1/65
1/1/65-1/1/66
1/1/66-1/1/67
1/1/67-1/1/68
1/1/68-1/1/69
1/1/69-1/1/70
1/1/70-1/1/71
1/1/71-1/1/72
1/1/7S-1/1/73

0524-00-062374
0525-00-062374
0526-00-062374
0527-00-062374
0528-00-062374
0529-00-062374
0520-00-062374
0521-00-062374
0522-00-062374
2223-00-03841

B.I. $100,000/person';
$100/000/occurrence.
Aggregate Products
$300,000.
(Same from 1/1/63-73)

1/V73-1/1/74
1/1/74-4/1/75
4/1/75-4/1/76
4/1/76-4/1/77
4/1/77-4/1/78
4/1/78-6/1/78
6/1/78-4/1/79
4/1/79-4/1/80
4/1/80-10/8/80

04AL-240547SCA(Y)
04AL-133108SCA(Y)
04AL-243531SCA
04AL-243596SCA
04AL-247719SCA
04AL-251330SCA
04AL-251330SCA
04AL-251382SCA
04GL-55409SCA

$2M!1/$2MM B.I. , P.D.

Hercules named as an
Additional Insured.

11

f

•
ft
II
n

$1MM/$4MM B.I. , P.D.
■
$2MM/$4MM B.I. , P.D.

m

c

c
SCHEDULE OF INSURANCE COVERAGE CONTINUED

• Limits
Carrier
Excess
Employers Mutuals
of Wausau

Policy Period

Policy Number

1/1/68-1/1/71

0521-06-062374

1/1/71-1/1/74
0524-06-062374
Policy canceled effective
1/1/73

W.C

E.L.

Excess policy - $5MI
limit of liability;
aggregate product
limit of $5MM.
Employers' Liability
$100,000 limit.
Excess Policy - $2MJ
limit of liability;
aggregate product
limit of $2MM;
Employers' Liability
B.I., $100,000/persc
$100,000/occurrence.

if