On December 10, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Patsy Young,
and
Aventis Inc.,
Avon Products, Inc.,
Block Drug Company, Inc.,
Block Drug Corporation,
Brenntag North America, Inc.,
Brenntag Specialties, Inc. F K A Mineral Pigment Solutions, Inc.,
Charles B. Chrystal Company, Inc.,
Chattem, Inc.,
Colgate-Palmolive Company,
Cyprus Amax Minerals Company,
Cyprus Mines Corporation,
Glaxosmithkline Llc (Sued Individually And As Successor-In-Interest To Block Drug Corporation, Successor-In-Interest To The Gold Bond Sterilizing Powder Company A K A The Gold Bond Company And As A Successor-In-Interest To Novartis Corporation And
Novartis Consumer Health Inc.),
Gsk Consumer Health, Inc. F K A Novartis Consumer Health Inc. F K A Ciba Self-Medication, Inc.,
Insight Pharmaceuticals Corporation, A Subsidiary Of Prestige Brands Holdings, Inc.,
Insight Pharmaceuticals Llc,
Macy'S Inc. F K A Federated Department Stores, Inc.,
Novartis Pharmaceuticals Corporation,
Prestige Brands Holdings, Inc.,
Prestige Consumer Healthcare Inc. F K A Prestige Brands, Inc.,
Sanofi-Aventis U.S. Llc,
Sanofi Us Services, Inc.,
Whittaker Clark & Daniels, Inc.,
for Torts - Asbestos
in the District Court of Erie County.
Preview
FILED: ERIE COUNTY CLERK 03/03/2023 03:51 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 139 RECEIVED NYSCEF: 03/03/2023
EXHIBIT 27
FILED: ERIE COUNTY CLERK 03/03/2023 03:51 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 139 RECEIVED NYSCEF: 03/03/2023
COLGATE-PALMOLIVE COMPANY
RAW MATERIAL PURCHASE SPECIFICATIONS
Mc 5857
.E_.--------------- #804·Nor-··· - -·----------
brn 29, 1976
TITLE
MONITAL 60h0 TALC
METHOD EXAMINATION SPECIFICATl0N
2252 COLOR See belov (1)
2252 000R Odorless or Very.Slightly Earthy
2252 TEXTURE See below (2)
2273 Apparent Density 0.82 ± 0.10 gm/ce
2256 Fineness thru U.S. #100 Sieve 100%
thru U.S. #200 Sieve 98$ Minimum
thru U.S. #325 Sieve 88% Minimum
41Ò1 Alkalinity as Na O 2.0% Maximum
4163 Acid Soluble Iron as Fe
03
2250 Arsenic as As 3 ppm Maximum
2s86 Lead as Pb 20 ppm Maximum
4100 $oluble Matter in N/2 HC1 2.0% Maximum
Microbial Contamination
2302 Bacteria Count 100/gm Max. (No gas-forming organism
Fibrous Asbestos (Serpentine, Amphibole) None detected by X-ray diffraction....
optical microscopy, TEM & Selected
Area Electron Diffraction.
. (1) Color: Mus not be darker than standard sample; must not change when heated to
200 C. ror 5 minutes.
(2) Texture: Free of grit, vith good slip and lustre; must match standard sample.
"Microbial Contamination: Run most probable number test per Lab SPI 2302, using 15
tubes of Eugon Broth. Innoculate 5 tubes of fluid thioglycollate medium (containing
. dextrose) with 1.0 m1 of the 10% alurry. Incubate all tubes 8 37°C. for 48 hours,
inspe ting for -gas-surface -linibbles at 18-24 Wurs -and 48 hours.
**Prior to shipment, the Supplier.shall analyze for.asbestos-content (as---listed.above)
and certify each shipment Of talc as being asbestos-free. Analytical results for the
certification vill be listed with each shipment 4. Asbestos analysis shall be done as
sample" anal-
follows: A "grab from each 5 tons of production shall be composited for
ysis (i.e.; for a 100 ton lot, a composite of 20 grab samples, each representing 5
tons of production vill be analyzed). Composited samples shall be divided into 3
parts: (1) sample sent to asbestos test (2) sample retained (3) sam-
lab, by Supplier,
ple sent to R&D Section Head - Current Toiletries.
ø Copies to be furnished to R&D and H,0,Q.C. STANDAlf DS
551s material-is compriseli oféC Montana Tas & 10% Italfan-falc.
Flash Point (TAG Closed Cup): ITot amplic le. -- - - - --
CHANGE REASON FOR CHANGE - To provide a certified
Nev. asbestos-free source of tale.
EVERY EFFoRT HAS s££N MADE TOPROVIDESPECIFICATIONSWHICH DEFTNE THE QUALITY OF MATERIAL REQUIRED SY
COLGATE FOR ITS INTENDEO USE. HOWEVER,ITISTO BE UNDERSTOoO THAT AFTER REGULAR USE OF THE MATERIAL HAS
BEEN ESTABLISHEO, THE SUPPLIER IS NOT AT LIBERTY TO MAKE CHANGES IN HIS RAW MATERIALSOR PROCESSES WHICH
WILL ALTER THE CHEMICAt. COMPoSITION OR THE PROPERTIES OF HIS PRODUCT IN ANY WAY, REGARDLESSOF SPECIFIED
LIMITs, WITHouT INFORMING COLGATE OF HIS INTENTIONS ANO ALLOWING A REASONABLE PEM1OCOFTIME FOR INVESTI-
GATIohi OF THE EFFECT ON THE QUAt.ITY OF FINISHED PRODUCTS. .
EACHSHIPPINGUNITTOBE0FUNIFORMSIZE&SHAPE,PLAINLYMARKE0WITHSYM8OL#,QUANTITY&DURPURCHASEORDERe
Ra /. PRoDUCTIoN PURCHASING SUPERSEDES SYMBoL No.
DATED
19-26-5
MK-CPC-00000358
Document Filed Date
March 03, 2023
Case Filing Date
December 10, 2020
Category
Torts - Asbestos
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FILED: ERIE COUNTY CLERK 03/03/2023 03:51 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 139 RECEIVED NYSCEF: 03/03/2023 EXHIBIT 27 FILED: ERIE COUNTY CLERK 03/03/2023 03:51 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 139 RECEIVED NYSCEF: 03/03/2023 COLGATE-PALMOLIVE COMPANY RAW MATERIAL PURCHASE SPECIFICATIONS Mc 5857 .E_.--------------- #804·Nor-··· - -·---------- brn 29, 1976 TITLE MONITAL 60h0 TALC METHOD EXAMINATION SPECIFICATl0N 2252 COLOR See belov (1) 2252 000R Odorless or Very.Slightly Earthy 2252 TEXTURE See below (2) 2273 Apparent Density 0.82 ± 0.10 gm/ce 2256 Fineness thru U.S. #100 Sieve 100% thru U.S. #200 Sieve 98$ Minimum thru U.S. #325 Sieve 88% Minimum 41Ò1 Alkalinity as Na O 2.0% Maximum 4163 Acid Soluble Iron as Fe 03 2250 Arsenic as As 3 ppm Maximum 2s86 Lead as Pb 20 ppm Maximum 4100 $oluble Matter in N/2 HC1 2.0% Maximum Microbial Contamination 2302 Bacteria Count 100/gm Max. (No gas-forming organism Fibrous Asbestos (Serpentine, Amphibole) None detected by X-ray diffraction.... optical microscopy, TEM & Selected Area Electron Diffraction. . (1) Color: Mus not be darker than standard sample; must not change when heated to 200 C. ror 5 minutes. (2) Texture: Free of grit, vith good slip and lustre; must match standard sample. "Microbial Contamination: Run most probable number test per Lab SPI 2302, using 15 tubes of Eugon Broth. Innoculate 5 tubes of fluid thioglycollate medium (containing . dextrose) with 1.0 m1 of the 10% alurry. Incubate all tubes 8 37°C. for 48 hours, inspe ting for -gas-surface -linibbles at 18-24 Wurs -and 48 hours. **Prior to shipment, the Supplier.shall analyze for.asbestos-content (as---listed.above) and certify each shipment Of talc as being asbestos-free. Analytical results for the certification vill be listed with each shipment 4. Asbestos analysis shall be done as sample" anal- follows: A "grab from each 5 tons of production shall be composited for ysis (i.e.; for a 100 ton lot, a composite of 20 grab samples, each representing 5 tons of production vill be analyzed). Composited samples shall be divided into 3 parts: (1) sample sent to asbestos test (2) sample retained (3) sam- lab, by Supplier, ple sent to R&D Section Head - Current Toiletries. ø Copies to be furnished to R&D and H,0,Q.C. STANDAlf DS 551s material-is compriseli oféC Montana Tas & 10% Italfan-falc. Flash Point (TAG Closed Cup): ITot amplic le. -- - - - -- CHANGE REASON FOR CHANGE - To provide a certified Nev. asbestos-free source of tale. EVERY EFFoRT HAS s££N MADE TOPROVIDESPECIFICATIONSWHICH DEFTNE THE QUALITY OF MATERIAL REQUIRED SY COLGATE FOR ITS INTENDEO USE. HOWEVER,ITISTO BE UNDERSTOoO THAT AFTER REGULAR USE OF THE MATERIAL HAS BEEN ESTABLISHEO, THE SUPPLIER IS NOT AT LIBERTY TO MAKE CHANGES IN HIS RAW MATERIALSOR PROCESSES WHICH WILL ALTER THE CHEMICAt. COMPoSITION OR THE PROPERTIES OF HIS PRODUCT IN ANY WAY, REGARDLESSOF SPECIFIED LIMITs, WITHouT INFORMING COLGATE OF HIS INTENTIONS ANO ALLOWING A REASONABLE PEM1OCOFTIME FOR INVESTI- GATIohi OF THE EFFECT ON THE QUAt.ITY OF FINISHED PRODUCTS. . EACHSHIPPINGUNITTOBE0FUNIFORMSIZE&SHAPE,PLAINLYMARKE0WITHSYM8OL#,QUANTITY&DURPURCHASEORDERe Ra /. PRoDUCTIoN PURCHASING SUPERSEDES SYMBoL No. DATED 19-26-5 MK-CPC-00000358