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. 142 RECEIVED NYSCEF: 03/03/2023
EXHIBIT 30
FILED: ERIE COUNTY CLERK 03/03/2023 03:51 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 142 RECEIVED NYSCEF: 03/03/2023
COLGATE PALMOLIVE COMPANY
RAW MATERIAL PURCHASE DESCRIPTION
PLANT EFFECTIVE DATE SYMBOL NO.
JC, JF, KC [ l-May-83 M-6020-3
TITLE: Italian Talc
METHOD EXAMINAT ION DESCRIPTION
2252 Color See Below
2252 Odor Odorless or very slightly earthy
2252 Texture See Below (2)
2273 Apparent Density 0.82 +/- 0. lO gm./cc
2256 Fineness: Thru US #I00 Sieve [00%
Thru US #200 Sieve 98% m±n.
Thru US ~325 Sieve 65% mln.
4[0[ Alkalinity as Na20 2.0% max.
4163 Acid Soluble Iron as Fe203 0.?5% max.
2250 Arsenic as As 3 ppm max.
2286 Lead as Pb 20 ppm max,
4100 Soluble Matter in N/2 2.5% max.
2302 Microbial Contamination See below
2302 Bacteria Count [00/gm. max. (No gas forming organisms)
FIbrous Asbestos (Serpentine, None detected by X-Ray Diffraction,
Amphibole) Optical Microscopy**, TEM and Select-
ed Area Electron D~ffraction,
(I) Color: .~s~ not be darker than standard sample; must not change when
heated to 200 *C. for 5 minutes,
(2) Texture: Free of grit, with good slip and lustre, must match std. sample.
Microbial Contamination: Run ~ost probable number test (Lab SPI 2302) using
15 tubes of Eugon Broth. Innoculate 5 tubes of fluid thlogycollate medium
[5 tubes of Eugon Broth. Innoculate 5 tubes of fluid thlogycollate medium
(containing dextrose) with 1.0ml of the 10% slurry. Incubate all tubes at
37"C for 48 hrs., inspecting for gas bubbles at [8-24 hours & 48 hours.
* The supplier shall analyze for asbestos content (as listed above) and
certify each shipment of Talc as being asbestos-free. Copies of certl-
fication (containing analytical results) and pre-shipment sample of Talc
should be furnished to R&D Sectlon Head-Current Toiltries and Q.A. Man-
ager at the plant designated to receive the shipment at least 2 weeks
prior to actual shipment.
** - in accordance with CTFA J-4-1.
CAS Registry Number = 14807-96-6 Compound Control Number - 18774
Flash Point (TAG Closed Cup) = Not Applicable
CHANGE : REASON FOR CP~NGE :
Relnstat ement. To provide for additional source.
EVERY EFFORT HAS BEEN MADE TO PROVIDE DESCRIPTION WHICH DEFINE THE QUALITY
OF MATERIAL REQUIRED BY COL~TE FOR ITS INTENDED USE, HOWEVER IT IS TO BE
UNDERSTOOD THAT AFTER REGULAR USE OF THE .MATERIAL HAS BEEN ESTABLISHED,THE
SUPPLIER IS NOT AT LIBERTY TO MAKE CHANGES IN HIS RAW MATERIAL OR PROCESSES
WHICH WILL ALTER THE CHEMICAL CObIPOS~TION OR THE PROPERTIES OF HIS PRODUCT
IN ANY WAY, REGARDLESS OF SPECIFIED LIMITS, WITHOUT INFORMING COLGATE OF
HIS INTENTIONS AND ALLOWING A REASONABLE PERIOD OF TIME FOR INVESTIGATION
OF THE EFFECTS ON THE QUALITY OF FINISHED GOODS
EACH SHIPPING UNIT TO BE OF UNIFORM SIZE AND S~IAPE, PLAINLY MARKED WITH
SYMBOL NUMBER, QUANTITY AND OUR PURCHASE ONDER NUMBER
R&D: QUAL. ASSUR.: MF : PURCH.: SUPERSEDES:
DATED :
~ t~ / ~.
L
QE-CPCO0001411
FILED: ERIE COUNTY CLERK 03/03/2023 03:51 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 142 RECEIVED NYSCEF: 03/03/2023
TITLE: H-6020 Italian Talc
SAMPLE TYPE: A - Grab Sample
TKST KACH SHIPMENT FOR:
Color
Odor
Texture
Microbial Co~tamlnat ion
Apparent Density
Fineness
QE-CPCO0001412
FILED: ERIE COUNTY CLERK 03/03/2023 03:51 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 142 RECEIVED NYSCEF: 03/03/2023
COLGATE PALMOLIVE COMPANY
RAW .~TERIAL PURCHASE DESCRIPTION
PLANT EFFECTIVE DATE SYMBOL NO.
JC,JF,KC |l-May-83 M-6020-3
TITLE; Italian Talc
HETHOD EXAMINATION DESCRIPTION
2252 Co Io r See Below (1)
2252 Odor Odorless or very slightly earthy
2252 Texture See Below (2)
2273 Apparent Density 0.82 +/- O. tO gm./cc
2256 Fineness: Thru US #100 Sieve I O0%
Thru US #200 Sieve 98% mln.
Thru US #325 Sieve 65% min.
410l Alkalinity as Na20 2.0% max.
4163 Acid Soluble Iron as Fe203 O. 75% max.
2250 Arsenic as As 3 ppm max.
2286 Lead as Pb 20 ppm max.
4 tO0 Soluble Hatter in N/2 2.5% max.
2302 Microbial Cont aminat ion See below
2302 Bacteria Count [00/gm. max, (No gas forming organisms)
Fibrous Asbestos (Serpent the, None detected by X-Ray Diffraction,
Amph lbo le) Optical Microscopy**, TEM and Select-
ed Area Electron Diffraction.
(i) Color: Must not be darker than standard sample; must not change when
heated to 200 aC, for 5 minutes.
(2) Texture: Free of grit, with good slip and lustre, must match std. sample.
Microbial Contamination: Run most probable number test (Lab SPI 2302) using
15 tubes of Eugon Broth. Innoculate 5 tubes of fluid thlogycollate medium
(containing dextrose) with [.Oml of the |0% slurry. Incubate all tubes at
37"C for 48 hrs., inspecting for gas bubbles at 18-24 hours & 48 hours.
* The supplier shall analyze for asbestos content (as listed above) and
certify each shipment of Talc as being asbestos-free. CopSes of certl-
fication (containing analytical results) and pre-shipment sample of Talc
should be furnished to R&D Section Head-Current Toiltries and Q.A. Man-
ager at the plant designated to receive the shipment at least 2 weeks
prior to actual shipment.
** - in accordance with CTFA
CAS Registry Number -- 14807-96-6 Compound Control Number = 18774
Flash Point (TAG Closed Cup) = Not Appllcable.
CHANGE: REASON FOR CHANGE:
EVERY EFFORT HAS BEEN MADE TO PROVIDE DESCRIPTION WHICH DEFINE THE QUALITY
OF MATERIAL REQUIRED BY COLGATE FOR ITS INTENDED USE, HOWEVER [T IS TO BE
UNDERSTOOD THAT AFTER REGULAR USE OF THE MATERIAL HAS BEEN ESTABLISHED,THE
SUPPLIER IS NOT AT LIBERTY TO MAKE CHANGES IN HIS RAW mATERIAL OR PROCESSES
WHICH WILL ALTER THE CHEMICAL COMPOSITION OR THE PROPERTIES OF HIS PRODUCT
IN ANY WAY, REGARDLESS OF SPECIFIED LIMITS, WITHOUT INFORMING COL~ATE OF
HIS iNTENTIONS ANI~ ALLOWING A REASONABLE PERIOD OF TIME FOR INVESTIGATION
OF THE EFFECTS ON THE QUALITY OF FINISHED GOODS
EACH SHIPPING UNIT TO BE OF UNIFORM SIZE AND SHAPE, PLAINLY MARKED WITH
SYMBOL NUMBER, QUANTITY AND OUR PURCHASE ORDER NUMBER
R&D: QUAL. ASSUR. : MFG: P URCH. : SUPERSEDES :
~ .~ .o DATED :
,~/~
QE-CPCO0001413
FILED: ERIE COUNTY CLERK 03/03/2023 03:51 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 142 RECEIVED NYSCEF: 03/03/2023
COL CAT E- PA LMOL IVE COMPANY
RAW MATERIAL PURCHASING SPECIFICATION
PLANT EFFECTIVE DATE SYMBOL NO.
JC, JF, KC M-6277-3
~.~_~,~ _~
TITLE: Monltal 6040 Talc
METHOD EXAMINAT ION S PEC tF ICAT ION
2252 Color See below (l)
2252 Odor Odorless or very slightly earthy
2252 Texture See below (2)
2273 Apparent Density 0.82 +/- 0.10 gm./cc.
2256 Fineness: Thru US il |00 sieve I00%
Thru US II 200 sieve 98% Min.
Thru US # 325 sieve 88% Min.
4101 ALkalinity as Na20 2.0% Max.
4163 Acid Soluble Iron as Fe203 O. 75% Max.
2250 Arsenic as As 3 ppm Max.
~517 Lead as Pb 20 ppm..Max.
4[00 Soluble Matter in N/2 HCI 2.0% Max.
2302 Mic rob Hal Cont amlnat ion See below
2302 Barter ia Count |00/gm. Max, (No gas formlng organisms)
Fibrous Asbestos (Serpentine, None detected by X-ray Diffraction &
Amph ibo le) Optical Microscopy**, TEM and Selected
Area Electron Diffraction.
(l) Color: Must not be darker than std. sample; must not change color when
heated to 200%. for 5 minutes.
(2) Texture: Free of grit, with good sllp & lustre, must match std. sample.
Mtcroblal Contamination: Run most probable number test (Lab SPI 2302) using
[5 tubes of Eugon Broth. Innoculate 5 tubes of fluid thiogiycolate medium
(containing dextrose) with l.Omi o[ the 10% slurry. Incubate all tubes for
48 hrs. at 37=C, inspectlng for gas bubbles at 18-24 hours and 48hours.
Supplier shall analyze for asbestos content (a~ Listed above) and certify
each shipment of talc as being asbestos [~ee. Copies of. certification (con-
taining analytlca[ results) & pre-shipment sample of talc should be furnished
to R&D Section Head-Current Toiletries and Q.A..Manager at the pla~t design-
ated to receive the shipment at least 2 weeks prior to actual shipment.
** in accordance with CTFA J-4-1 Methods.
This material ts composed of 60% ~bntana Talc and 40% Italian Talc.
CAS Reglst~y Number: 14807-96-6 Compound Cont¢ol Number: 19640
FLash Point (TAG Closed Cup): Not App[icab[e
CHAN~E: REASON FOR CHANGE:
Revising certification procedure. To simplify operations.
EVERY EFFORT HAS BEEN MADE TO PROVIDE A SPECIFICATION WHICH DEFINES THE QUALI-
TY OF MATERIAL REQUIRED BY COLCATE FOR ITS INTENDED USE. HOWEVER, [T IS TO BE
UNDERSTOOD THAT AFTER REGULAR USE OF THE MATERIAL HAS BEEN ESTABLISHED, THE
SUPPLIER [S NOT AT LIBERTY TO MAKE CHANGES [N HIS RAW MATERIAL OR PROCESSES,
WHETHER OR NOT SUCH CHANGES ALTER THE CHEMICAL COMPOSITION OR THE PROPERTIES
OF HIS PRODUCT IN ANY WAY, RE~d)LESS OF SPECIFIED LIMITS, WITHOUT INFORMING
COLiATE OF HIS INTENTIONS AND ALLOWING A REASONABLE PER[Of) OF TIME FOR THE
[NVESTIC4%TION OF THE EFFECTS ON THE QUALITY OF FINISHED GOODS.
KACH SHIPPING UNIT TO BE OF UNIFORM SIZE AND SHAPE, PLAINLY MARKED WITH SYMBOL
NUMBER, QUANTITY AND OUR PURCHASE ORDER N~MBER.
REQUESTED BY: F. Schebece DATE TYPED: 03-Nov-83 SUPERSEDES; M-6277-2
R&D: ’~ ~,.’~ J Q.A.: MEG: PORCH.: DATED; ~ 6-dun-81
QE-CPCO0001414
FILED: ERIE COUNTY CLERK 03/03/2023 03:51 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 142 RECEIVED NYSCEF: 03/03/2023
TITLE: M-6277 Monlta[ 6040 Talc
CLASS: [
SAMPLE TYPE: A- Grab Sample
TEST EACH SHIPMENT FOR:
Co[or
Odo~
Texture
M~ceob tal Contaminat ion
Apparent Density
Fineness
QE-CPCO0001415