Document M9LX7mX5JYxGwM4k5d7gNqbL

FILE NAME: Exxon (EXX) DATE: 0000 DOC#: EXX057 DOCUMENT DESCRIPTION: Attorney Notes Summarizing Statements of Exxon IH Jim Hammond's Statements about Asbestos & Exxon Table sum m arizing Exxon IH Jim Ham m ond's statem ents about asbestos and Exxon Compiled by attorney JC Metcalf, <jcmetcalf@cox.net> Date 0000 Source Hammond Depo 7/6/90 pp 372-4 0000 Hammond Depo, 7/7/90, pp 452-53 0000 Hammond Depo, 7/7/90, pp 454 0000 Hammond Depo, 7/7/90, pp 457 0000 Hammond Depo, 7/7/90, pp 459 0000 Hammond Depo, 7/7/90, pp 460 0000 Hammond Depo, 7/11/90, pp 652 0000 Hammond Depo, 7/7/90, pp 412 Information Necessary to make dust measurements to know if you were below the TLV. Use your experiences and other's experience to know if particular operations were potentially exceeding the TLV. You would immediately evaluate exposures and you would make sure that you took precautions that would be reasonable, whether wet methods or some other procedure. And make sure that the workers are supervised so they stayed in line with the practices you recommended, and your safety inspectors did that. Exxon's approach to exposure limits was a different approach than trying to achieve the 5 million paricles. "We reduced it to the lowes level we could under the conditions that were practical. We didn't tolerate 5 mppcf if we could get it lower than that. "We lowered them to the lowest practical value that we could arrive at." (455, 456) If it was a more temporary operation where the levels could not be reduced far enough, we put respirators on our people so they would be exposed to none." (457) Never found a condition were asbestos levels were above 5 mppcf. If there had been levels in excess of 5 mppcf, as found by Bonsib in 1937, the employees would have been wearing respirators. any time levels exceeded 5 mppcf the workers would be wearing respirators. And the workers were under the constant supervision of the safety inspectors who enforced the respirator requirement. When there was visible dust in the air the men were already wearing respirators. Although Hammond claims that he never saw visible dust in the air at the Baytown refinery. If the safety inspectors were suspicious of the presence of asbestos dust that might reach a great level or any level, they put respirators on their employees." Visible dust Exxon's contractors (Brown and Root) worked under the supervision of Exxon's safety inspectors. Exxon did not depend upon the presence of visible dust in any way. We depended upon the evaluation of the dust levels by techniques of scientific proof. 0000 Hammond Depo, 7/7/90, p 414 Assuming that you are dealing with a toxic material such as asbestos and silica, the amount that you see would only indicate that you probably had many, many fold greater than reasonable exposure levels for that type of material. There would be no way to see the material unless it was far in excess of the amount you were concerned about." You have to rely on actual 1 measurements. Visible dust. 0000 Hammond Depo, 7/7/90, pp 418-19 0000 Hammond Depo, 7/7/90, pp 418-19 0000 Hammond Depo 7/11/90 p 581-2 0000 Hammond Depo 7/11/90 p 683 0000 Hammond Depo 7/7/90 p 433 0000 Hammond Depo 7/7/90 p 465 0000 Hammond Depo 7/7/90 p 477 0000 Hammond Depo 7/11/90 p 640-41 To put a worker in a situation were there was enough dust in the air for him to see would be rather cruel situation to put him in. "We could have a lethal dose of asbestos. . . there would be no way of us knowing. We couldn't feel it by senses or detect it by odor." Don't depend on your senses with these materials. Visible dust. Hammond says, "We never permitted asbestos dust to create visible concentration in the air." "We put respirators on people before it got to that level." Explain what the practice of industrial hygiene is. It --it's application of the science and art dealing with prevention of occupational diseases both by being able to recognize potential diseases and then to be able to evaluate the significance o f-- and extent of the exposures that the employees may have and then how would you go about controlling exposure and bringing them under the acceptable levels that you would find to be safe. And then it goes on out into the field of education of the employees or the workers as well as the matters of working with medical supervision or surveillance of these employees throughout the period to make sure that you have accomplished in the workplace the goal that you set out to do. It was Exxon/Humble company policy to tell contractors of a hazard such as the asbestosis/lung cancer hazard. "Yes. The company policy was to do whatever necessary to prevent asbestosis and, therefore, asbestos exposure. The Humble safety manuals were provided to the supervisors of the contract workers at the Humble refinery. "It was a separate action of giving it to them before they began work for us." Dust counts for asbestos were done at the Humble refinery contractor's worksites during Hammond's 30 years with the company. They would be around them as quickly as around our employees. The mortality studies done of refinery people with respect to cancer did not include contract workers or contract employees. The study was strictly of Humble employees. The Exxon/Humble guidelines or requirements for contractors such as Brown & Root, were "that they follow the same rules that our employees in very regard as far as protection from any exposure to asbestos or other hazardous materials. Before the contractors started work "we had drawn it to the attention of the contractors that they would be required to do this. To maintain and to comply with all of our safety and health regulations in doing the work. And then we also took on the supervisors as a group - if there were more than one - and taught them the principles that we expected him to enforce among the- the employees that he might have under his command." 0000 Hammond Depo 7/11/90 p 641 0000 Hammond Depo 7/11/90 p 654, 670, 671 0000 Hammond Depo 7/11/90 p 681-82. 0000 Hammond Depo 7/11/90 p 686 0000 Hammond Depo 7/11/90 p 689-90 1933 Hammond letter to Siegel, 1994 08 17, page 2 1933 Hammond depo 7/5/90, p 44-5 The Brown & Root supervisors were daily supervised by our safety inspectors, and if they were not keeping in line or keeping up with our requirements, they were informed immediately, even to have them stop work and get adjusted to the right practices or the right equipment that they would need to do the work. Exxon safety personnel told any other contractors that came into the plant that they were to follow your standards. We made no exceptions. This included telling the contractors about asbestos problems with any job that the contractors were doing. The connection between asbestos, asbestosis and lung cancer was discussed with the contractor's foremen as to why they must not have any exposure. This was done early in Hammond's career. If a contractor's employee was violating an asbestos safety rule, not wearing a respirator, the Exxon safety inspector could close down the job or they could have the employee fired or have the contractors remove him from the job. Without reservation Exxon enforced all of the safety regulations that the contractors were supposed to follow in Exxon's plant. In the first third of this century the control measures with regard to hazardous dusts were that of isolation of the exposure to the material, exhausting the dust away from the breathing atmosphere, capturing the dust by filtration or removal, by wetting the dust-generating material so that the dust wouldn't be generated, housekeeping or housecleaning by using the vacuum hoses or vacuum cleaners, and educating the employees in methods for producing the least amount of dust in their work. I believe that there are many different procedures, and they were all being used in some degree by 1940 in Humble and Esso generally. The control measures for asbestos in the first third of the century were that of isolation of the exposure of the material. The second would have been to exhaust the dust away from the atmosphere, to capture dust by filtration or removal, by wet methods, so that the dust wouldn't be generated, and by proper housekeeping or housecleaning by using vacuum hoses or vacuum cleaners, and by education of the employees in the method of doing the the method with the least amount of dust production. I believe that there are about 12 or 14 different procedures used in some degree in the early 1900s. 1933 Hammond depo 7/5/90, p 95 1937 Hammond letter to Siegel, 1994 08 17, page 3 1937 Hammond letter to Siegel, 1994 08 17, page 3 1937 Hammond depo 7/5/90, p 102 1937 Hammond Depo 7/5/90 p 82 It's so important to have this educational part of the program in effect. Bonsib's findings and recommendations were made public to the industry and anyone who was interested; in fact, I saw this publication in the medical department library ten years after it was initially published, and when I asked Mr. N. V. Hendricks who was the Chief Industrial Hygienist for the Standard Oil Company at that time, to send me a copy, he sent me the copy I still have to this day, my original copy with the buckslip on it. It met fully the "state of the art" for good industrial health practices for 1937 -1947. This publication describes safety measures Esso Oil employed at the time, and it also sets out guidelines and standards for safe handling of asbestos materials, based on al/ available technology and information at the time. So for instance, he describes designing the plant for dust control, providing proper building ventilation, storing potentially dusty materials in dusttight bins, enclosing material handling equipment isolating the dusty processes. Furthermore, not have men in the area who were not necessary for that operation, providing wet methods of operation, designing equipment to control dust, providing exhaust systems, establishing maintenance and good housekeeping procedures, and, where these measures are inadequate, providing respirators and other personal protective measures. They included periodic clinical medical examinations, x-ray of chest annually or more often. I cannot over emphasize the educational part of it to get the employees to understand what to do and how to do it and why you're asking them to do it, and in that manner I had very little resistance on the part of the employees to do whatever I requested of them. Re: the 1937 Bonsib report, "it has applications for most dustproducing problems even today. It's a very good sound program if you had a problem with dust, yes sir. 4 1937 Hammond letter to Siegel, 1994 1994 08 17, page 13 1942 Hammond Depo 7/11/90 p 682 1943 Hammond Depo 7/6/90 p 250 1943 Hammond Depo 7/6/90 p 301 1946 Hammond Depo, 7/7/90, pp 488 1947 Hammond letter to Siegel, 1994 08 17, page 3 1947 Hammond letter to Siegel, 1994 08 17, page 4 All in all, OSHA had little more than a technical impact and an extra layer of authority over the programs of control and monitoring that we had been maintaining and improving upon since the 1930's. You will find, in fact, that Roy S. Bonsib's program from 1937 is one of the primary resource documents referenced by NIOSH precisely because the program he outlined is based on good industrial hygiene practices and is still valid today, with allowance for improvements in technology and some advances in medical knowledge. Hammond was aware of the connection between asbestos and lung cancer as far back as 1942, in cases where people had asbestosis. And it was then, wasn't it, that you first became aware of the connection between asbestos and lung cancer? Let's say that it was then that I became aware that I had to protect the employees that were under my supervision or my plants that did not get asbestosis because in addition to asbestosis they would then become potentially exposed, would become potentially liable to develop cancer Okay you had that knowledge in 1943? `43 Okay A. No. Let's see. Yeah. Yeah. 1943, yes, sir. Professor Hammond- you understood, then, in 1943 when you learned about the asbestos/lung cancer/asbestosis connection from Dr. Lynch that if you could prevent a man from getting asbestosis you would prevent the lung cancer. How would you prevent a worker from getting asbestosis? It's --obviously, you prevent his exposure to asbestos dust in such concentration as to produce this disease. in 1946 when the ACGIH made is 5 mppcf proposal it was at least 10 years behind the state of art in the industry with dust control. The best knowledge available at that time concerning unsafe levels of exposure 'to hazardous dusts was published by the United States Public Health Service in collaboration with the investigating committee for the American Conference of Government Industrial Hygienists. The American Conference of Government Hygienists is a group that is still looked to in setting M. AC.s or T.L.V.s or T.W.As With regard to potential exposures to dust containing asbestos fibers, the standard recommended by these bodies was to keep prolonged occupational exposures to dust containing asbestos below a concentration of 5 million particles per cubic foot. In 1947, Humble was already well established with the program and knew, based on repeated routine sampling, what the potential levels of dust were in the areas where we could not completely control the dust and all workers would have to use respirators. So we had the knowledge to require workers to wear respirators when there was any potential exposures, and the safety inspectors on the job daily, who would be observing, would make sure they did. 1947 Hammond letter to Siegel, 1994 08 17, page 4 1947 Hammond letter to Siegel, 1994 08 17, page 5 1947 Hammond letter to Siegel, 1994 08 17, page 5 1947 Hammond letter to Siegel, 1994 08 17, page 5 This monitoring allowed you to evaluate the workers potential exposure and take any precautions that would be necessary, whether it be wet methods of operation or some other procedure, you would also make sure that these people were supervised to stay in line with what practices you recommended. And our safety inspectors did that. They patrolled all units and work areas daily. We took the attitude that if there was a substantial chance of a hazardous dust potential," then we would not wait until they got above 5 million particles per cubic foot or even 1 million particles before we would require "dust control measures and" respiratory protection. This was on a case by case basis, based on the judgment of the industrial hygienist and the safety people. For example, we had not been requiring men who handled asbestos insulation packages in the warehouse to wear respirators and respiratory protection unless there were broken sacks because many times those sacks came in on pallets and we removed them out of the boxcars into the room and they never were disturbed and that required nothing more than just care to make sure they didn't break them. But if they broke them, they had to wear respirators because there was no way to take care or clean up that spill without potential dust exposure. When making mortar, it was a general practice to prevent any dust by injecting water into the sack and wetting it before you opened it then when you dumped it out into the pan or whatever mixture pot you were making up the mortar in it was already wet and generated no dust. In the early years of my employment with the company, many times we took men right out of the labor pool and made insulators out of them by training them, and part of their training was the safety aspect of it, including the proper use of respirators. In 1947 the respirator program was very organized. It meant that when you were assigned to a position or a job that you may need a respirator, you were supplied a new one in a box; and then, when you used that respirator on the job, - and the safety inspectors made sure you did use it when you should - then you were to put it in the rack, which was picked up daily, returned to the respiratory protection warehouse, and the respirator then was washed, sterilized, dried, and examined for any misfit or any broken parts and a change of filters. 1947 Hammond letter to Siegel, 1994 08 17, page 5 1947 Hammond letter to Siegel, 1994 08 17, page 5 1947 Hammond letter to Siegel, 1994 08 17, page 6 1947 Hammond letter to Siegel, 1994 08 17, page 6 1947 Hammond letter to Siegel, 1994 08 17, page 6 1947 Hammond letter to Siegel, 1994 08 17, page 6 1947 Hammond letter to Siegel, 1994 08 17, page 7 When we had a potentially continuous exposure, we would swap out employees, since we could not expect them to wear a respirator for hours on end, and we could not let them have any unprotected potential exposures. We did monitor the air as often as needed to determine if there was exposure at a point we had enough confidence in our results from past experience with certain activities, materials, sites, and work conditions that we were able to anticipate the potential for exposures. In some cases, it was sufficient to periodically monitor to review and confirm our prior experience and findings. To clean up a spill wherein we had a broken sack of asbestos, we put respirators on the men. Temporarily in cleaning it up we may have had more than the 5 million particles per cubic foot. But this was not of concern to us because the men cleaning up the spill were protected. The safety inspectors would know when a particular job was going to potentially expose the men, based on past experience, they had the men wear respirators. The men were under constant supervision of the safety inspectors who enforced the use of protective equipment. And since the maximum allowable concentration values that the AC.G.I.H published in 1947 spoke to the particles of asbestos per cubic foot of air. at Exxon we were stricter than that standard. Also, we did not use any of the disposable paper-type masks: We used a Comfo M.S.A, filter mask approved by U. S. Bureau of Mines standard. It is also important to note that we never permitted asbestos dust to create visible concentration in the air. We put respirators on workers before they entered that level. Whenever that possibility could occur, we had respirators on the workers. We had the experience of finding that workers will comply fully with our insistence on using respirators if we first showed them that we did everything reasonable -such as wet methodsto control the dust before we required a respirator. But where they did need respirators, then they were convinced that we had done our job and they needed to cooperate and they were required to do so. We furnished only the most comfortable approved type of protection. 7 1947 Hammond Education of employees began with employees being letter to Siegel, introduced into operations where asbestos might be. They were 1994 08 17, educated or were trained in the precautions that were required page 7 to work with these materials. The Safety Department made sure that the equipment that might be needed in the way of personal protective equipment was in stock. The operating supervisor understood how to go about controlling the dust from a practical standpoint on the job. And they would strictly enforce those procedures for all employees. And the old employees were already indoctrinated, and they felt a sense of responsibility to the new ones and made sure that they continued to practice all of those features of the program. And they were supervised by the safety inspectors who patrolled constantly and observed and enforced these safety regulations. Jobs could be stopped immediately if not in line with our safety guidelines. 1947 Hammond Equally important to our engineering of dust controls was our letter to Siegel, medical surveillance program with regard to asbestos. Medical 1994 08 17, monitoring through examinations of employees began before I page 7 came to Exxon. New employees as well as those that may be old employees new to a craft involving asbestos were given a thorough physical examination, a clinical examination to make sure they were in good condition so far as it might relate to any occupational disease brought on by dusty conditions or by asbestos, even in 1947 the Humble medical program included pre-employment physicals for the employees; because to apply it to industrial hygiene you would be concerned that you did not let the susceptible employee go to work at the wrong location- and be exposed to the wrong materials. 1947 Hammond In this connection, I recall that Dr. Kenneth Lynch, whom I had letter to Siegel, known in South Carolina (1942-1946) before I joined the 1994 08 17, Company, had autopsied the asbestosis victims cases that had page 8 come from the textile mill there in Charleston. He had spoken on that matter; and his associate Dr. Henry Zerbst told me that Dr. Lynch said that he had never seen a case of cancer in these lungs unless the cancer was superimposed on top of the asbestosis. His message was that if you control asbestosis then you will have controlled the cancer problem. Our x-ray program insured that we would be able to detect any asbestos-related changes in workers' lungs. 1947 Hammond In the early years of my employment with the company, many letter to Siegel, times we took men right out of the labor pool and made 1994 08 17, insulators out of them by training them, and part of their page 5. training was the safety aspect of it, including the proper use of respirators. 1947 Hammond The Company safety manuals were not provided to each of the letter to Siegel, employees of contractors who worked in the Baytown refinery, 1994 08 17, but were provided to the supervisors of the contract workers. page 9 They were available to the individual if he wanted one, but we seldom required that they study it. 1947 Hammond letter to Siegel, 1994 08 17, page 9 1947 Hammond letter to Siegel, 1994 08 17, page 9 1947 Hammond letter to Siegel, 1994 08 17, page 9 The safety manual was not provided to the contractors just as an attachment to the contract documents and the specifications. It was a separate action of giving it to them before they began work for us by the Operating Manager or his representative of the safety department in the refinery, gas plant or chemical unit. In every case our contractors, Brown & Root and other contractors, were required to follow the same guidelines as employees, to follow the same rules as our employees in every regard as far as protection from any exposure to asbestos or other hazardous materials. Brown & Root, for instance, had a very active safety department when 1 came to Exxon, and later they employed a staff of industrial hygienists. But these specialist seldom visit our operations because they respected our health and safety programs for being superior. Before contractors began to work, we drew it to the attention of the contractors that they would be required to maintain and to comply with all of our safety and health regulations in doing the work. And then, we also took on the supervisors as a group - if there were more than one - and taught him or them the principles that we expected to have enforced among employees that he might have under his command. For example, we required that they also wear the equivalent type of approved respirator wherever our people were wearing respirators or needed to wear respirators or we thought that they might need to wear respirators. They were required to have those; if they didn't have them, we would in a neighborly way lend them the respirators to do the job if it was short term. If they were going to be rather permanently contracted by us in that type operation, we expected them and required them to furnish their own personal protective equipment These same supervisors were watched by our safety inspectors; and if they were not keeping in line or keeping up with our requirements, they were informed immediately, even to have them stop work and get adjusted to the right practices or the right equipment that they would need to do the work. Safety inspectors had the authority to close down the job or have the contractors removed from the job As a result of all the above, during my 31 years with Exxon the contractors supervisors who worked in our facilities were educated by our safety personnel of the hazards associated with the jobs they were going to be doing, including any potential exposures to asbestos dust, where that might have occurred. So, for example, to the extent that the job might involve tearing off asbestos insulation, our safety people routinely would advise them of the hazards that would be associated with that and what they needed to do about it They would make no exception regardless of what job they were going to do They'd tell them about all o f the problems that were associated with any job they were going to do. 1947 Hammond Depo, 7/11/90, pp 647 1947 Hammond Depo, 7/11/90, pp 651 1947 Hammond Depo, 7/11/90, pp 651 1947 Hammond depo 7/6/90, p 367 1947 Hammond depo 7/6/90, p 368 1947 Hammond depo 7/6/90, p 377 1947 Hammond depo 7/7/90, p 409 1947 Hammond depo 7/7/90, 411 Hammond saw the Hemeon report and it contained nothing new re: asbestos. "Not anything new." Hammond cannot say why Hemeon was never published. "We were concerned with all dust (re: counting for total dust or just for asbestos dust) and we didn't make any differentiation knowing that the asbestos was a small percent of the composition of the insulation that was being evaluated. Hammond says that the TLV was for asbestos dust, and since Exxon counted total dust, asbestos or not, the Exxon exposure limit was more more stringent than the ACGIH TLV. "In accordance with what Mr. Bonsib reported and what he recommended, yes we would be better from that standpoint and anyone else who uses his principles. Normally when an employee comes in he knows, at least he is hired for a certain unit, and he would be trained specifically for that unit and all o the potential occupational problems associate with that unit and not the entire complex of the refinery. Education A necessary part of the safety program is education and re education of the employees. The employee was very cooperative because he knew I was concerned about his health as much as I wold be about my son if he worked in the same area for 40 years. You injected water into the sack and wetted it before you opened it so that when you dumped it out into the pan or whatever mixture pot you were making up the mortar in it was already wet and no dust. It wa suggested by Bonsib so we followed it right on, right on through from the beginning. The employee "should know all the potential health problems that may occur to him if he doesn't have the protection otherwise. Then he is happy to cooperate with you if he knows that you've already looked at all the angles and applied all the other methods. It's a part of education. 10 1947 Hammond depo 7/7/90 p 470-71 1947 Hammond Depo 7/11/90 p 633 1947 Hammond Depo 7/11/90 p 634 1947 Hammond Depo 7/11/90 p 670-71 1947 Hammond Depo 7/7/90 p 555 Explains the need for the 1972 document, "Guidelines for Handling Asbestos." "It was a continuing education program that we carried on regularly throughout my 31 years with Exxon." Re: relationship of the safety program to OSHA: "Only to call it - necessary to call OSHA n dealing with asbestos teaching If all of our people who may be new and who maybe have not heard about it before." The Exxon program as it relates to asbestos. There was a guide in effect in 1947 when Hammond arrived at Humble. It was a cooperative venture on the part of the medical department and the department of safety. The basis of the program was the Bonsib guidelines. What was required by Humble/Exxon in terms of protection of the workers concerning asbestos. Primarily it began with the new employee or someone being introduced into the operations where asbestos might be that he was educated or he was trained in the precautions that were required to work with this type of material And then, the safety department made sure that the equipment that he might need in the way of personal protective equipment or the operating supervisor might make sure that he understood how to go about controlling the dust from an engineering or from a practical standpoint on the job And they would strictly enforce those procedures for the -- for all employees. And the old employees were already indoctrinated and they felt a sense of --of responsibility to the new ones and made sure that they continued to practice all of their --those features And they were supervised by the safety inspectors who went around constantly during worktime and observed and enforced these safety regulations. With regard to contractors at the Humble refinery. All the supervising personnel who had a responsibility for the work procedures of the employees were carefully educated as to the potential problems associated with the jobs they were going to be doing. The contractors' supervisory personnel were carefully educated by the Humble safety personnel of the hazards associated with the jobs they were going to be doing. They would make no exception regardless of what job they were going to do. They'd tell them about all of the problems that were associated with any job they were going to do. This applied specifically to asbestos, including tearing off asbestos insulation. "I make no exceptions." Regarding contractor employees, there were definite policies dealing with these matters from the safety department, and they strictly enforced them for every worker in the plant. The safety inspectors had the power to make the contractor's employees comply with Exxon/Humble safety regulations. 1947 Hammond Depo 7/11/90 p 602 1947 Hammond Depo 7/5/90 p 77 1947 Hammond letter to Siegel, 1994 08 17, page 6 1947 Hammond 9 letter to Siegel, 1994 08 17, page 12 1962 Hammond letter to Siegel, 1994 08 17, page 10 1962 Hammond Depo 7/11/90 p 679 1962 Hammond Depo 7/11/90 p 680 1962 Hammond Depo 7/11/90 p 683 Contractors like Brown & Root had their own safety departments "when I came and later" - they were awarer of hazards of asbestos and other toxic substances. [and despite that awareness, Exxon still required contractors to comply with Exxon safety rules] Q. Are you saying, then, that the controls, the measures for reduction of the dust hazard that Roy Bonsib prescribed in 1937 were being used in 1947 when you joined the company? A. They had been in sue for 10 years. In work, practices, we always lowered asbestos exposures to the lowest value that we could. If it was in a temporary operation, then we would put respirators on the workers so they would not be exposed to any dust. I should additionally note that we implemented the program described above in the Company's maritime operations. I have ridden on our tankers and barges myself, and in later years my assistants continued to do so, to monitor the potential for shipboard exposures to asbestos and other hazards. Our maritime workers, like our refinery and chemical plant workers, were given physicals at least annually, monitored closely for potential exposures, and regularly trained in safety meetings. We decided that if that was a potential mesothelioma problem and mesothelioma was being brought about by unknown quantities of asbestos, we did not have a practical goal to shoot for except zero. This concerned me because of my insistence that I did not want anyone working with any of the products that I would not feel completely safe working with over a 40year career. When Hammond learned of the connection between asbestos exposure and mesothelioma in 1962, and became convinced of the connection in 1962, he freely discussed it with his superiors at Exxon. Q. What was the response of your superiors when you were freely discussing the mesothelioma and asbestos risk with them in the early 60s? A. The complete - complete agreement to do whatever we needed to do to eliminate any risk. Q. After you perceived the mesothelioma risk associated with asbestos exposure, did you tell anyone at Exxon that the contractors needed to be told of that risk as well? A. It again goes back to the fact that we said we will have to be sure that one one has any exposure to asbestos, period; and that was a topic and the basic of our program. 12