EPIDEMIOLOGY EPIDEMIOLOGY ENGINEERING

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					                                                                                                             I
                                                                                                                             11FR
           INDEX   OF     DEPOSITION               OF   ARTBUR         M     LANCER            PHD

                             TAKEN            NOVEMBER          16     1983                                           UT

                                                                                                                 MJ
  PAGE                                                                                                                     CR
                                                      TEXT

  52324              ASSOCIATE                PROFESSOR           OF       ENVIRONMENTAL MEDICINE                           AT
                    MT     SINAI               SCHOOL        OF   MEDICINE

 713819             BS           DEGREE        IN GEOLOGY    BUNTER   COLLEGE 1956   NO
                    COURSES
                    COURSE               IN    MEDICINE   EPIDEMIOLOGY ENGINEERING
                     INDUSTRIAL                HYGIENE    PUBLIC    HEALTH   BIOLOGICAL
                    SCIENCES
                    SCIENCE                   OCCUPATIONAL EPIDEMIOLOGY
                    ENVIRONMENTAL                                            RADIOLOGY
                                                      HEALTH      OR       TOXICOLOGY
 82399              MASTER
                    MASTERS             IN    GEOLOGY             COLUMBIA             1962

 910102             NO COURSES
                        COURSE   IN MEDICINE  PUBLIC HEALTH   BIOLOGICAL
                    SCIENCE
                    SCIENCES     EPIDEMIOLOGY ENGINEERING     INDUSTRIAL
                    HYGIENE    RADIOLOGY ENVIRONMENTAL  HEALTH OR TOXI
                    COLOGY
 1039               PHD               COLUMBIA           1965

 1011115            NO                        IN
                          COURSES
                          COURSE  MEDICINE    PUBLIC HEALTH  BIOLOGICAL
                    SCIENCES EPIDEMIOLOGY ENGINEERING EXCEPT
                    SCIENCE                                         FOR
                    SOIL MACHANICS
                         MACHANIC     INDUSTRIAL   HEALTH  RADIOLOGY OR
                    TOXICOLOGY
11613               FIRST          EMPLOYMENT                AFTER         COMPLETION               OF    EDUCATION
                   WAS      AT     MT         SINAI

141115             PRIOR  TO  WORKING FOR MT        SINAI                                           HE    HAD     NEVER
                   WORKED AND WAS  NEVER   CONSULTED   RE                                          THE   HEALTH        EF
                   FECTS
                   FECT  OF EXPOSURE    TO MINERALS

1427168            HAS     NOT
                            ENROLLED   IN ANY COURSES
                                               COURSE    IN MEDICINE    PUB
                   LIC   HEALTH    BIOLOGICAL    SCIENCE
                                                 SCIENCES    EPIDEMIOLOGY
                   OCCUPATIONAL    EPIDEMIOLOGY ENGINEERING          INDUS
                                                                     INDU
                   TRIAL  VENTILATION    INDUSTRIAL   HYGIENE   RADIOLOGY
                   ENVIRONMENTAL   HEALTH    TOXICOLOGY INDUSTRIAL TOX
                   ICOLOGY OR AUTOMOTIVE     ENGINEERING SINCE     GOING TO
                   MT      SINAI

161017             DOE
                   DOES     NOT       CONSIDER           HIMSELF           TO     BE   AN     EXPERT IN           DIAG
                   NOSING        OR      TREATING ASBESTOSRELATED                               DISEASE

16231822           CONSIDER
                   CONSIDERS   HIMSELF                     TO     BE EXPERT  IN                    PUBLIC HEALTH
                   RE    TOXIC EFFECTS
                                EFFECT                     OF     MINERAL DUST                      ACQUIRED EX
                   PERTISE         OVER        THE      LAST      18   YEAR
                                                                       YEARS           AT     MT     SINAI
2015214            HAS     NEVER             TAUGHT           FULLSEMESTER                    COURSE         BY HIM
                   SELF



                                                                           8006    1446
                                                                                                     P0
 215216     HAS NOT TAUGHT ANY REQUIRED COURSES
                                        COURSE                                                            AT    MT        SINAI
            ONLY CONTINUING EDUCATION COURSES

 3668       DURING            HIS        EDUCATION HE                          NEVER         RECEIVED  ANY                 INFOR
            MATION            CONCERNING                  THE        HAZARDS
                                                                     HAZARD                  OF ASBESTOS
 38122      HE     IS      NOT       AN        EPIDEMIOLOGIST                            BUT      HE CONSIDERS
                                                                                                     CONSIDER                   HIM
            SELF           TO       HAVE                 GOOD            WORKING               KNOWLEDGE OF                       THE
            FIELD             WHICH            ALLOW
                                               ALLOWS           HIM            TO      EVALUATE            AND        CRITIQUE
            STUDIES

 3826393    HAS      GOOD                   UNDERSTANDING OF                        INDUSTRIAL                        HYGIENE
            BUT HE DOES
                      DOE                   NOT        CONSIDER                HIMSELF   TO  BE                  AN        EXPERT
            IN  FIELD

 39415      CONSIDER
            CONSIDERS                  HIMSELF            TO BE EXPERT RE                                 TOXICOLOGICAL
            EFFECTS
            EFFECT              OF       CERTAIN          MINERAL DUSTS
 4016419    SUMMARYOF HIS   KNOWLEDGE RE                                                          MR       RICHARDSONS
                                                                                                           RICHARDSON
            WORKEXPOSUREHISTORY
 411018     DID      NOT         READ          RICHARDSON
                                               RICHARDSONS   DEPOSITION OR TALK                                                      TO
            HIM               ONLY          TALKED    TO PLAINTIFFS
                                                         PLAINTIFF     ATTORNEY                                                   FOR
            ABOUT             TEN        MINUTES
                                         MINUTE                RE    WORK            HISTORY
4123        HIS      QUESTION
                     QUESTIONS                           MR
                                               RE                   RICHARDSON

4215431    ASSUME
           ASSUMES              PLAINTIFF                WAS        EXPOSED               TO      PIPE         INSULATION
           BUT       HE    WAS           NOT      TOLD

4325       WAS       NOT         TOLD THAT  PLAINTIFF                                  WAS        ENGAGED            IN    MANU
           FACTURE              OF PIPE  INSULATION
4367       HE     WOULD          LIKE          TO      KNOW         ALL        OF      PLAINTIFFS
                                                                                       PLAINTIFF                 HISTORY
4394423    DOE
           DOES         NOT         BELIEVE            THAT          DETAILS
                                                                     DETAIL               OF        PLAINTIFFS
                                                                                                    PLAINTIFF                   EX
           POSURE             ARE        IMPORTANT                  BECAUSE               EVERY           EXPOSURE              IN
           CREASE
           CREASES              RISK        AND        ADDS
                                                       ADD          TO     HEALTH              EFFECTS
4424471    HIS     ASSUMPTIONS
                   ASSUMPTION                       RE         PRODUCTS
                                                               PRODUCT                   TO       WHICH         PLAINTIFF
           WAS     EXPOSED

47211      HAS     NO      WAY         TO      QUANTIFY PLAINTIFFS
                                                        PLAINTIFF                                      EXPOSURE            AS     AN
           INSULATOR                OR      AUTO  BODY REPAIRMAN
48327      NO     QUANTITATIVE                      DATE        RE             EXPOSURE                   DOE
                                                                                                          DOES  NOT    BE
           LIEVE        SHIPYARD               EXPOSURE              WAS         HEAVY              BUT     IT ACCOUNTS
                                                                                                               ACCOUNT
           FOR     PART         OF       PLAINTIFFS
                                         PLAINTIFF                       ASBESTO
                                                                         ASBESTOS              DISEASE
481921     BELIEVES
           BELIEVE              EACH              OF      PLAINTIFFS
                                                          PLAINTIFF                            EXPOSURE
                                                                                               EXPOSURES                  CAUSED
           DISEASE            AND NO            EXPOSURE                 CAN        BE    DISCOUNTED
482527     EACH      AND EVERY   ONE OF                         PLAINTIFFS
                                                                PLAINTIFF                         EXPOSURES
                                                                                                  EXPOSURE                 COULD
49110      HAVE       CAUSED   PLEURAL                              THICKENING                    OR       PARENCHYMA
           SCARRING



                                                                                8006         1447
  4923502         PLAINTIFF
                  PLAINTIFFS                  EXPOSURE    AT              ARMSTRONGCORKCOULD
               AND                                                                                                        IN
                        OF    ITSELF             BE CAUSE                 OF    PLAINTIFFS
                                                                                PLAINTIFF               DISEASE
  50717        WAS      TOLD           THAT       PLAINTIFF               PERFORMED BRAKE                   WORK      35
               TIME
               TIMES         PER        MONTH

  501823       WAS     NOT  TOLD WHY PLAINTIFF  WORKED ON                                            BRAKES
                                                                                                     BRAKE     OR     HOW
               MANY      WHEELS
                         WHEEL   HE WORKED UPON AT    TIME
  50245117     THINGS
               THING          HE        WOULD           LIKE        TO    KNOW        TO      DETERMINE
               TIFF
               TIFFS                                                                                           PLAIN
                              EXPOSURE

 5126528       DOE
               DOES         NOT        HAVE        ANY  DETAILS
                                                        DETAIL                                PLAINTIFFS
                                                                                              PLAINTIFF
               DUTIES
               DUTIE         OR        WORK
                                                                                  RE                                 JOB
                                                  PRACTICE
                                                  PRACTICES    FROM                   19521978
 52917         BELIEVE
               BELIEVES                OTHER          MECHANICS
                                                      MECHANIC
               REPAIRS
               REPAIR             IN
                                                                               WERE        PERFORMING              BRAKE
                                         SAME         AREA


 5218536      DOE
              DOES      NOT         BELIEVE             DETAIL
                                                        DETAILS            OF    PLAINTIFF
                                                                                 PLAINTIFFS                 WORK     EN
              VIRONMENT                ARE       IMPORTANT
 531220       DOE
              DOES      NOT            EVEN       KNOW                      OF PLAINTIFFS
                                                               NAME
                                                               NAMES           PLAINTIFF                     VARIOUS
                                                                                                             VARIOU
              EMPLOYER
              EMPLOYERS                OR     TIME       PERIODS
                                                         PERIOD            HE WORKED THERE

 532127       DOES NOT
              DOE       KNOW                     SIZE         OF
              IN OR
                                                                    BUILDING
                                                                    BUILDINGS PLAINTIFF                       WORKED
                    WHETHER                      THEY        HAD     VENTILATION               SYSTEMS
 546552       ONLY REVIEWED                      DR      ABRAHAM
                                                         ABRAHAMS               REPORT         AND     DR     GROS
                                                                                                              GROSS
              NOTES

 55526        HAS     NOT     EXAMINED                TISSUE             SPECIMEN
                                                                         SPECIMENS   READ ANY DEPO
              SITION
              SITIONS              INSPECTED PLAINTIFFS
                                             PLAINTIFF                           PLACE
                                                                                 PLACES OF EMPLOY
             MENT        REVIEWED                 XRAY
                                                  XRAYS            OR     LOOKED AT ANY PICTURES

                                         PPM IONS
                                             ION

56512        PLAINTIFF  WAS LIKELY EXPOSED TO ASBESTOS
                                               ASBESTO   FIBER    IN
             AT      LEAST
                       THREE INSTANCES
                             INSTANCE      TODD   SHIPYARD     ARM
             STRONG CORK BRAKE REPAIR
561322       BELIEVE
             BELIEVES         CHRYSTOTILE ASBESTOS
                                          ASBESTO   WOULD
                              FOR
                                                            MORE                                              LIKELY
             ACCOUNT             PLEURAL THICKENING     BELIEVES
                                                        BELIEVE                                               SHORT
             FIBER      CAUSES
                        CAUSE    PLEURAL PLACQUES
5713         BELIEVE
             BELIEVES             THAT EACH AND                         EVERY      ONE        OF     PLAINTIFF
                                                                                                     PLAINTIFFS
             EXPOSURES
             EXPOSURE               CONTRIBUTED                         TO      PLAINTIFFS
                                                                                PLAINTIFF                   PRESENT
             STATE

5747         TOLD       THAT                PLAINTIFF               HAS         PLEURAL              THICKENING
             PLEURAL          PLAQUE
                              PLAQUES                   AND        VERY         LIMITED              PARENCHYNIA
             SCARRING
571018       NO     INFORMATION                  RE     PLAINTIFFS
                                                        PLAINTIFF                 PULMONARY FUNCTION
             TEST     RESULTS
                      RESULT                      HIS
                                            OR               PRESENT           DISABILITY IF  ANY




                                                                           8006        1448
  61613          HE     HAS    GREAT              GREAT           RESPECT               FOR        JERRY ABRAHAMU
  6225631        HIS   DEFINITION                     OF        SHORTFIBER                 CHRYSOTILE                        IS     ANY
                 FIBER   LESS
                         LES    THAN                       MICRON
                                                           MICRONS                IN    LENGTH
  63213          USE
                 USES          MICRON
                               MICRONS                AS    STANDARD                   BECAUSE               OF    NIOSHOSHA
                 STANDARD

  631425         HIS  DEFINITION                      OF        ASBESTOS
                                                                ASBESTO                 FIBER                IS        DIFFERENT
                 THAN OSHAS

 641724       OSKA              FIBER            IS        OBJECT WHICH
                                                           AN            IS                                       AT    LEAST
                 TIME
                 TIMES        GREATER           IN     LENGTH THAN DIAMETER
 651024      SINCE   1973                 THERE             HAVE        BEEN
             OF
                                                                                       AN        INCREASINGNUMBER
                  REPORTS
                  REPORT                  INDICATING                    THAT            CHRYSOTILE                    IS          MOST
              FREQUENTLYINVOLVED                                  IN     PLEURAL DRIFT                               AND          MOST
             FREQUENTLY OCCURS
                        OCCUR                               AT        PLEURA    SHORT                             FIBER           PRE
             DOMINATE
             DOMINATES               IN    PLEURA

 66314       STUDIE
             STUDIES            WHICH           INDICATE        THAT  SHORT  FIBER
                          IN                                                          PREDOMI
             NATES
             NATE                  PLEURA             HAVE DISCUSSEDFOUND FIBERSFIBER    WHICH
             ARE                          AND           MICRONS
                                                        MICRON     IN LENGTH

 6616        RELIE
             RELIES            UPON       STUDIE
                                          STUDIES                BY          LE        BOUFFANT   SEBASTIEN
             FONDIMARE                POTT             RUTH            FREIDRICH
                                                                       FREIDRICHS
             AND                                                                              IRWIG   BOCHUM
                        TREMBJLL

 79920       POTT              CONCLUDES
                               CONCLUDE             THAT               MAXIMUM
             CAUSED                                                                          CARCIRIOGENCITY                        IS
                              BY    FIBERS
                                    FIBER          OF 20               MICRON
                                                                       MICRONS               IN     LENGTH              AND       AC
             TIVITY           OF    FIBER         REMAINS
                                                  REMAIN               UNTIL                 MICRON
 8125824     TREMBIL       BELIEVES
                           BELIEVE                              TOTAL         DUST           IS     MORE           IMPORTANT
             THAN   LENGTH
821922      NONE         OF  THE          STUDIES
                                          STUDIE                 LANGER RELIES
                                                                        RELIE                           ON    DEALT           WITH
            BRAKE         DUST

8212        DAVI
            DAVIS                  CONJAM                  CONCLUDED   THAT THERE                                      WAS        NOT
            ENOUGH SURVIVING                          FIBER    IN  BRAKE DRUM DUST                                     TO     ELI
            CIT       CLASSICAL            RESPONSES

832884
            EPIDEMIOLOGIST
            EPIDEMIOLOGISTS                      AT        MT      SINAI
            HAMMOND                CONSULTS
                                   CONSULT
            SIEDINAN

8579        NO     INDUSTRIAL              HYGIENIST
                                           HYGIENISTS                   AT        MT        SINAI            NOW

8510        INDUSTRIAL              HYGIENIST
                                    HYGIENISTS                   IN     PAST
            DUNCAN        HOLLIDAY                     1970S
                                                       1970
            BILL        REITZE             196770
            CAROL        RICE             MID 70S                THROUGH80S
8618        MT        SINAI        LAB     IS     NOT           ACCREDITED                  BY    ANY INDUSTRIAL
            HYGIENE FOUNDATION ASSOCIATION                                                  OR    ORGANIZATION


                                                                                   8006          1469
  89413             FIRST          TLV        RE   ASBESTO
                                                   ASBESTOS                            DREESEN            IN      1938
                    5000000               PARTICLES
                                          PARTICLE    PER CUBIC                        FOOT  OF         AIR     IN    EF
                    FECT     FROM         19381972

  9016                 FIBER
                       FIBERS           GREATER         THAN          MICRON
                                                                      MICRONS                 77276
  907           PRESENT             TLV     IS     05        FIBER
                                                             FIBERS         PER       CUBIC        FOOT
  91259724      GENERAL              QUESTION
                                     QUESTIONS               RE       AIR         SAMPLING              IMPINGERS
                                                                                                        IMPINGER
                CASSETTES
                CASSETTE               BRITISH              METHODS

  991119        DOE
                DOES         NOT
                          DEFINE FIBER
                                 FIBERS WHEN HE USES
                                                USE     ELECTRON MIC
                ROSCOPE   HE SIMPLY IDENTIFIES
                                     IDENTIFIE MATERIAL       DOES
                                                              DOE  NOT
                DISTINGUISH BETWEEN FRAGMENTS AND FIBERS
                                      FRAGMENT
 100623         FIBER
                FIBERS          LES
                                LESS THAN               05        MICRON
                                                                  MICRONS             BEHAVE       AS    GAS     MOLE
                CULES
                CULE          AND CANWILL                BE       EXHALED         AFTER        BEING INHALED
 1012123        HE     FIRST        PUBLISHED               ARTICLE          RE        ASBESTO
                                                                                       ASBESTOS          IN    1967
 1051210628     ASBESTO
                ASBESTOS                  EXPOSURE DURING                     BRAKE           LINING          MAINTE
               NANCE          AND        REPAIR   1976                       HE WAS         RESPONSIBLE             FOR
               ELECTRON             MICROSCOPEPORTION
               ROB                WEISINAN         AN       ELECTRICAL                ENGINEER            TOOK       AIR
               SAMPLES
 10713         ROHI         WAS     TRAINED            IN   AIR     POLLUTION
               BUSTION
                                                                                            SAMPLING AT          COM
                                   ENGINEERING
 1071
               EDUCATIONOCCUPATJON BACKGROUNDOF                                                    COAUTHOR
                                                                                                   COAUTHORS
               NO      MEDICAL            DOCTORS OR
                                          DOCTOR       INDUSTRIAL HYGIENISTS
                                                                  HYGIENIST                                           NO
               EXPERT
               EXPERTS       IN           PUBLIC HEALTH OR TOXICOLOGISTS

1101ILL        ARTICLE             DOE
                                   DOES          NOT        REFER       TO        VIOLATIONS
                                                                                  VIOLATION               OF     TIME
               WEIGHTED             AVERAGE
                                    AVERAGES                   IT     DEAL
                                                                      DEALS            WITH
               SHORT                                                                               SPIKE
                                                                                                   SPIKES             OR
                             EXCURSIONS

1121316        NO     INDUSTRIAL            HYGIENIST               TOOK      AIR      SAMPLES
                                                                                       SAMPLE           THAT     WERE
               REVIEWED            IN     THE     ARTICLE

114221154     THEY          MEASURED         CHRYSOTILE WHICH                         WAS     PRESENT            THEY
              DID      NOT        MEASURE         FIBERS

              THEIR          STATEMENT
                             STATEMENTS             OF 215     CHRYSOTILE IN RESIDUAL
              MATERIAL  COUNTS
                        COUNT                      FREE  ASBESTO
                                                         ASBESTOS AND ASBESTOS
                                                                      ASBESTO    BOUND
              IN PARTICULATE                     RESIN  MATERIAL

1161323       HICKISH               KNIGHT FOUND LESS
                                                 LES                         THAN       1     OF    CHRYSOTILE
              WAS      FREE        FIBER

11624L174     HATCH   REPORTED THAT                         LES
                                                            LESS    THAN          1    OF     RESIDUAL          DUST
              WAS  FREE  ASBESTOS




                                                                            8006       1450
 117512         BOILAT                  LOB        ALSO      REPORTED                      FINDING        OF     LESS
                                                                                                                 LES       THAN
                1

 11814          MUCH        OF    THE     ASBESTOS
                                          ASBESTO                 IN       BRAKE            LINING
                                                                                            LININGS            ALTER
                                                                                                               ALTERS      INTO
                ANHYDROUS FORM
                ANHYDROU

 12025          THERE        WAS              GENERAL             CONCEPT                  THAT  FIBER WAS   CON
                VERTED           TO    FORSTERITE                    ALWAY
                                                                     ALWAYS                 WITHOUT VARIATION
 1211127        LYNCH            HICKISH KNIGHT                          HATCH              CONTENDED THAT                  AS
               BESTO
               BESTOS            DECOMPOSEDAS                          RESULT               OF HIGHPOINT                   CON
                TACT        TEMPERATURES
 1241828            MILLION            PEOPLE ENGAGED                       IN        BRAKE        REPAIR
 125211        APPROXIMATELY                   45          MILLION               WORKED            IN    SHIPYARDS
                                                                                                         SHIPYARD                IN
               WWRI

 12757         LANGER            HAS                       VISITED
                                         NEVER                                             BRAKE        MANUFACTURING
               PLANT

 1302413117    LANGER        DID        NOT PERFORM ANY INDEPENDENT RESEARCH
                                                                                                                              TO
               DETERMINE               TEMPERATURE
                                       TEMPERATURES INVOLVED  IN BRAKE USAGE
 13327         ROHI      COLLECTED              RESIDUAL               DUST            SAMPLES
13424135       FOR STUDY    THEY                   USED      FOLLOWINGCRITERIA                                 FOR    DETER
               MINING FIBERS
                      FIBER


                       MORPHOLOGY
                       REFRINGENT CHARACTERISTICS
                                  CHARACTERISTIC

1353           HE     CANNOT           RECALL         SEEING                     SINGLE FIBER                    IN     BRAKE
               DUST    BECAUSE   PARTICLES
                                 PARTICLE                                                    TOO        SMALL
                                                                             WERE                                     TO   BE
              CLASSIFIED    AS FIBERS

1392214013    THERE IS     MARGIN                          OF                         WITH
                                                                     ERROR                         THE     XRAY         DIF
              FRACTION METHOD  OF                               20     TO        25

1421216       MOST      FIBER
                        FIBERS           WERE        TOO      SMALL    TO  BE SEEN                         BY OPTICAL
              MICROSCOPYAND                    WERE         UNDER   04    MICRON
                                                                          MICRONS                         IN LENGTH
1431824       IN BRAKE DRUM DUST  AT LEAST                                            50     OF     FREE        FIBER      WAS
              ABOUT   MICRON IN LENGTH

14413         NO     PERSONAL            AIR        SAMPLE
                                                    SAMPLES             WERE               TAKEN        OVER      PERIOD
                                                                                                                  PERIODS
              LONGER THAN                     TO          MINUTE
                                                          MINUTES             IN           LENGTH
14449         OSHA       SAMPLING REQUIRES HOURS
                                  REQUIRE HOUR                                                THE         LONGER           THE
              SAMPLE         THE       BETTER         IT     IS

1441014524    THE   REASON              THEY DID                     NOT      FOLLOW OSHA  SAMPLING
              METHODS
              METHOD                    THAT        THEY
                         WAS                                    WERE         JUST ATTEMPTING TO DE
              TERMINE        WHETHER ASBESTOS FIBER
                                       ASBESTO        SURVIVED   AND                                                    WHE
              THER     IT    WAS PRESENT DURING BRAKE OPERATIONS
              DID
                                                                                                                        THEY
                      NOT    ATTEMPT TO QUANTIFY AMOUNT   OF FIBER



                                                                             8006           1451
  145251461        IN     1974        AND        1975          SCIENTIFIC             COMMUNITY               WAS     SPECU
                   LATING            AS     TO
                                             WHETHER                   FREE        ASBESTO
                                                                                   ASBESTOS                SURVIVED       THE
                   BRAKING            PROCESS

  1462             HE     DID     NOT VISIT     GARAGES     DOE
                                                            DOES NOT                                        KNOW     SIZE     OF
                   GARAGE
                   GARAGES           DOE
                                     DOES  NOT   KNOW TIME   OF YEAR                                        THAT     SAMPLE
                                                                                                                     SAMPLES
               WERE            TAKEN   AND DOES NOT
                                            DOE         KNOW WEATHER                                       CONDITIONS
                                                                                                           CONDITION          AT
                   TIME        OF     SAMPLES
 1471014       BELIVE
               BELIVES                OSHA        RECOMMEND
                                                  RECOMMENDS               15     MINUTE          SAMPLES
                                                                                                  SAMPLE             FOR    EX
               CURSION                LEVEL        SAMPLING
 148123        HE       HAS          NO    REAL          KNOWLEDGECONCERNING                               ACTUAL      LOCA
               TION
               TIONS            OF        SAMPLING
 1491216       FIBERS
               FIBER                 SHORTER       THAN   4                 MICRON
                                                                            MICRONS              PREDOMINATED                 IN
               SAMPLE
               SAMPLES               OF     RESIDUAL    DUST

 1492028       ROHI             NOT  LANGER                     REVIEWED            AIR        SAMPLE
                                                                                               SAMPLES          BY     OSHA
               NIOSH            TECHNIQUES
 152815319     RUBOUT        NOT                   RECOMMENDED                BY OSHA BREAKS BUNDLES
                                                                                        BREAK    BUNDLE
               INTO   FIBRIL
                      FIBRILS                      CAN        CAUE         HIGHER FIBER   COUNTS

 156727        OSHA          COULD          NOT      CITE            THE    GARAGE
                                                                            GARAGES             THEY SAMPLED                FOR
               VIOLATION
               VIOLATIONS                  OF      PLVS

15718          DOESNT                THINK          THE         AIR        SAMPLE
                                                                           SAMPLES             WERE        EXAMINED          BY
               ANYONE               OUTSIDE           OF         MT        SINAI           OR         AN     INDUSTRIAL
               HYGIENIST

157919         SOME              BUT       NOT     ALL          FIBER
                                                                FIBERS          HAD   RESIN            BINDER        PARTI
               CULATE            MATERIAL               ON     THEM

159241606     THEIR            AIR        SAMPLE
                                          SAMPLES            MEAN      NOTHING            IN     TERM
                                                                                                 TERMS        OF     CALCU
               LATING POSSIBLE                          EXPOSURES
                                                        EXPOSURE             TO     ASBESTOS
                                                                                    ASBESTO                 FIBER
                                                                                                            FIBERS     OVER
                    PERIOD            OF    YEARS

1591418       THEIR            SAMPLE
                               SAMPLES            ARE        ONLY RELEVANT                 TO     DETERMINE            WHE
              THER        OR        NOT     FREE         FIBER         ASBESTOS
                                                                       ASBESTO             WAS     PRESENT
159221606     STUDY             CANNOT       BE USED       TO APPROXIMATE AN  INDI
              VIDUALS
              VIDUAL                              LEVEL
                                      EXPOSURE             TO ASBESTO
                                                              ASBESTOS JUST TO ES
              TABLISH               SOME   ASBESTO
                                           ASBESTOS     DOE
                                                        DOES EXIST IN WORKPLACE

1619          ASBESTO
              ASBESTOS    CONTENT  OF DUST   ENCOUNTERED                                                       IN    BRAKE
              MAINTENANCE   AND REPAIR  1977
1641217       80        OF      CHRYSOTILE                           FREE FIBRIL
                                                          WAS                                  FORM AND            SHORTER
              THAN        04         MICRON
                                     MICRONS             IN     LENGTH
1641618       OVER        57         WAS      02         MICRONS

16617         ASBESTO
              ASBESTOS             EXPOSURE                   OF     BRAKE               WORKER
                                                                                  REPAIR WORKERS IN                     THE
              US                1976



                                                                             8006         1452
  1692717018     WARNING   SHOULD     HAVE  BEEN PLACED ON BRAKES IN 1964
                                                             BRAKE
                 65      BECAUSE OF MCVITTIE     PUBLICATION    RE
                 SATION   OF                                       COMPEN
                              BRITISH     BRAKE REPAIR WORKERS UNDER BRI
                                                         WORKER
                 TISH WORKERS
                        WORKER      COMPENSATION LAWS
  170191712      ADMIT
                 ADMITS     THAT   HE PREVIOUSLY TESTIFIED                                      IN  1969
                 COULD         EITHER
                           GO          WAY    AT   THI
                                                   THIS TIME                                     HE THINKS
                                                                                                     THINK
                 MCVJTTJES
                 MCVJTTJE        COMPENSATION CITATION   IS                                     REASONABLE
                 POINT

  1711722        AWARE        CROCIDOLJTE                WAS        USED     IN       BRAKE
                                                                                      BRAKES       IN     GREAT
                 BRITAIN

 1722022                CITE
                CANNOT                           CASE          OF     INLOTHELJOMA
                                                                                 IN                      U        S
                BRAKEWORKER                BEING REPORTEDKRJOR 1980
                                                             TO

 1722328        LOW  NUMBER OF    REPORTED  MESOTHEIJOMA
                                            MESOTHEIJOMAS                                          IN     BRAKE
                MECHANICS
                MECHANIC   IN WORLD   BETWEEN 1220
 1741118        VERY FEW REPORTED                     CASES
                                                      CASE          OF MESOTHELIOMA
                                                                                                AMONG        US
                BRAKEWORKERS

 1741927        IN     THOSE     CASES
                                 CASE                   MIXED        EXPOSURE          CANNOT      BE     ABSO
                LUTELY        RULED   OUT

 174281753      HE     CANNOT            RULE    OUT      EXPOSURES
                                                          EXPOSURE              TO  ASBESTO
                                                                                    ASBESTOS             OTHER
                THAN     BRAKE
                         BRAKES             IN   CASE         REPORT       HE     PUBLISHED IN            LAN
                CET

 1752528       ADMIT
               ADMITS          THAT   THERE  WAS   POSSIBLE                          EXPOSURE      TO    TREM
               CUTE          IN  CASE    HE REPORTED

176828         ADMIT
               ADMITS         THAT               MEMBER
                                                 MEMBERS
                                          MANY                      OF  SCIENTIFIC           AND    MEDICAL
               COMMUNITY BELIEVE                   SHORT             FIBERS
                                                                     FIBER    CANNOT            CAUSE    IN
               JURY
1771           BELIEVE
               BELIEVES          THAT   ARTICLES
                                        ARTICLE                 TESTING BRAKE DUST                  IN    ANI
               MALS
               MAL       DO     NOT           IT               IS
                                      PROVE                       NONPATHOGENIC                     BECAUSE
               THEY      DO        NOT      ISOLATE           THE     ASBESTOS
                                                                      ASBESTO
               WITH                                                                          THEY       TESTED
                        ASBESTOS
                        ASBESTO              IN    MATRIX

178311         AGREE
               AGREES         THATBRAKE DUST EXPERIMENTS HAVE NOT
                                               EXPERIMENT           PRO
               DUCED         THE
                               CLASSICAL    DISEASE
                                            DISEASES  PRODUCED BY ASBES
                                                                  ASBE
               TOS         THEY HAVE PRODUCED GRANULATOMOUS LESIONS
                                                  GRANULATOMOU  LESION
               WHICH      HE BELIEVES
                             BELIEVE        NOT
                                        ARE      TOTALLY BENIGN
1781216        ADMITS
               ADMIT         THAT        SOME    OF     THE     TEST    ANIMAL
                                                                        ANIMALS  WERE                         TO
                                                                                      PRONE
               DEVELOPING GRANULATOMOU                                LESION
                                                                      LESIONS   REGARDLES
                                                                                REGARDLESS                    OF
               WHAT     IS     INJECTED          INTO         THEM

18058          DOE
               DOES  NOT  BELIEVE   THERE IS                               SUITABLE          SUBSTITUTE
                    ASBESTO
               FOR ASBESTOS    IN BRAKE LININGS

1801518        IN  1980         THERE WAS             STILL         SOME   DEBATE       AS   TO WHETHER
               ASBESTOS
               ASBESTO          SURVIVED          BRAKING            PROCESS




                                                                           8006       1453
 1801922      RECALL
              RECALLS             TESTIFYING                    THAT     1970       WAS             KEY        DATE   RE
              GARDING             THE     SUSPICION                OF    THE       SURVIVAL          OF        ASBESTO
                                                                                                               ASBESTOS
               IN    BRAKE
                     BRAKES          BECAUSE               OF    HICKJSH                 KNIGHT
 1813         STILL  BELIEVES
                     BELIEVE                        1970        IS       BENCH MARK YEAR   FOR                          MOST
              OF SCIENTIFIC                     COMMUNITY                 BUT NOT  FOR HIM

 1811026      HE      FIRST  EXAMINED   BRAKE                            DUST        IN      1968         OR      1969
              AFTER      LYNCH
                         LYNCHS   STUDY
 1811618      LANGER DID                 NOT        PUBLISH          ANYTHING            AFTER      HIS        STUDY          IN
              196869

 181281822    DID      NOT        TRY          TO     REFUTE            LYNCHS
                                                                        LYNCH             STUDY BECAUSE                      IT
              WAS            GOOD STUDY

 1823017      BRAKEWORKER
              BRAKEWORKERS                HAVE  THE   SAME AMOUNT  OF ASBESTOS
                                                                      ASBESTO
              BODIES
              BODIE          IN     THEIR   LUNGS AS THE POPULATION AT LARGE
                                            LUNG
              INCLUDING                DOCTOR  OR   LAWYER
 1821823      BRAKEWORKERS
              BRAKEWORKER   HAVE                                 SUBSTANTIALLY                LOWER             RISK         OF
              CONTRACTING ASBESTOS
                          ASBESTO                               DISEASE           THAN     INSULATORS
 1831726      BELIEVE
              BELIEVES    NICHOLSON     PUBLISHED PAPER        RE                                          RISK
                                                                                                           RISKS             OF
             ASBESTO
             ASBESTOS     DISEASE    IN   US      WORK   FORCE                                              BELIEVES
                                                                                                            BELIEVE
             PAPER   STATED    INSULATORS
                               INSULATOR      HAD     10   RISK                                       AND        BRAKE
             WORKERS
             WORKER     HAD      04  RISK    1125TH
             THINKS
             THINK     NICHOLSON   ARTICLE                              WAS        PUBLISHED              IN     AMERI
             CAN   JOURNAL   OF INDUSTRIAL                               MEDICINE

185728       HE  HAS  BECOME AWARE                               OF     SEVERAL            OTHER          CASE
                                                                                                          CASES              OF
             MESOTHELIOMA   AMONG                        BRAKEWORKERS
                                                         BRAKEWORKER    SINCE                              HE          PUB
             LISHED         HIS      CASE           REPORT   BECAUSE DOCTORS
                                                                     DOCTOR                               HAVE         CON
             TACTED         HIM

1861216      HE     ONLY      HAS        PERSONAL            KNOWLEDGE
                                                                     REGARDING                            ONE     MESO
             THELIOMA             CASE         IN          BRAKEWORKER

1881215      DOE
             DOES      NOT         KNOW          IF        GARAGES
                                                           GARAGE            MT      SINAI     SAMPLED ARE
             REPRESENTATIVE                     TO    CALIFORNIA                  AUTO     REPAIR GARAGES
188211896    HE     BELIEVE
                    BELIEVES             THAT         BRAKES
                                                      BRAKE             AS     WELL  AS          EVERY           ASBES
                                                                                                                 ASBE
             TOSCONTAINING PRODUCT                                   USED     IN  WORK        PLACE              SHOULD
             HAVE  WARNING LABEL
192231937    IN THE ABSENCE OF ANY EXPOSURE     TO OTHER    CHEMICALS
                                                            CHEMICAL
             MATERIAL
             MATERIALS    OR  SUBSTANCES
                              SUBSTANCE     EXCEPT     ASBESTOS
                                                       ASBESTO       THE
                          OF MESOTHELIOMA
             OCCURRENCE                              WORKER
                                             AMONG WORKERS      IN CER
             TAIN OCCUPATIONS IS
                    OCCUPATION       RELIABLE   INDICATOR    OF    RISK
             OF CONTRACTING ASBESTOSRELATED       DISEASE

1942124      HAS                   BEEN
                    NEVER                           LICENSED            FOR       ANYTHING          OTHER          THAN
             DRIVING              CAR




                                                                                   8006      1454
197814       HE    AUTHORED      1971                         ARTICLE    WHICH   CONCLUDED      THAT
             JUST    ABOUT  EVERYONE                           IN   GENERAL   POPULATION     OR   AT
              LEAST   THOSE  IN NYC                              HAVE  CHRYSOTILE ASBESTOS
                                                                                     ASBESTO       IN
              THEIR   LUNGS

19859        CHRYSOTILE               ASBESTOS
                                      ASBESTO             IS                        AIR
                                                                     COMMON                    POLLUTANT
1981027      MT   SINAI
                  SINAIS                  AIR    POLLUTION             STUDY        WAS        BASED     UPON        AN
             EXAMINATION               OF       TISSUE         FROM    28            29    OF    3000
                                                                              OR                          AUTOP
              IES

2021019      THINKS
             THINK            GROS
                              GROSS        HAS     MADE         VALUABLE           CONTRIBUTIONS
                                                                                   CONTRIBUTION                 BUT
                    DISAGREE
             LANGER DISAGREES                      WITH         MANY OF        GROSS
                                                                               GROS             CONCLUSIONS

204620518    KNOW
             KNOWS          OF    CASES
                                  CASE      OF ASBESTOSIS
                                                ASBESTOSI                    IN     BRAKEWORKER
                                                                                    BRAKEWORKERS               AS
             RESULT          OF      NICHOLSONS
                                     NICHOLSON       STUDIES

205428       STUDIE
             STUDIES    OF BRAKEWORKERS
                            BRAKEWORKER                               SHOWED         MINIMAL            SCARRING
             AND ABNORMAL    XRAY     NO                         ONE    OVER              11     IL0           RAT
             ING     80   SMOKED

205262062    HAS  NO PERSONAL KNOWLEDGE RE                                         CONFIRMED                        OF
                                                                                                        CASE
             PLEURAL PLAQUES IN SOMEONE
                     PLAQUE             WHO                                        WORKE         EXCLUSIVELY
             WITH       BRAKES

207614       OSRA
             OSRAS            ANTICIPATED            EXPOSURE   OF PEOPLE ENGAGED IN
             BRAKE          REPAIR         IS    LOWER THAN   EMERGENCY  TLV OF 05

211192123    BELIEVE
             BELIEVES             CURRENT      05              STANDARD  WOULD PROTECT AUTO
             BODY REPAIR                  WORKERS
                                          WORKER              FROM   DANGERS OF CONTRACTING
                                                                     DANGER
             ASBESTO
             ASBESTOS           IS

2122521619   CANNOT           STATE         WHAT                             LEVEL         HAS   TO   BE  TO
                                                         EXPOSURE
             CAUSE          ASBESTOSI
                            ASBESTOSIS                 PLEURAL          PLAGUES
                                                                        PLAGUE               MESOTHELIOMA
             OR      CANCER


213262143    LATENCY            PERIOD           FOR          ASBESTOSI
                                                              ASBESTOSIS                          INSULATORS
                                                                                                  INSULATOR
                                                                                 AMONG
             MT         SINAI         STUDIED            IS     ON     THE    AVERAGE             20    YEARS

214192151    CANNOT           STATE    THAT  PLAINTIFF   WOULD                                 HAVE
                                                                                     NOT                PLEURAL
             PLAQUING             IF PLAINTIFFS
                                       PLAINTIFF      ASBESTO
                                                      ASBESTOS                        EXPOSURE           CEASED
             IN      1955      OR   1960




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