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 03/17/2023 08:25 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 263 RECEIVED NYSCEF: 03/17/2023
EXHIBIT 57
FILED: ERIE COUNTY CLERK 03/17/2023 08:25 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 263 RECEIVED NYSCEF: 03/17/2023
;g 21MERYS
Ta/ c
Imerys Tale " 8051 E. Maplewood Ave " Greenwood Village, CO 80111 " (303) 713-5000 " Fax: (303) 713-5788
TECHNICAL REPORT
Project No. A11366
Date: 1-Aug-11
To: N. Sauvageau
From: Andrew Zamurs
Analyst(s): C. Slowik, J. Sulik, A. Zamurs
Copy: M. Mellon, J. Pier, S. Sharma
Title: TEM ASBESTOS ANALYSIS OF YELLOWSTONE PRODUCT SAMPLES
Q2 2011
Request: Three samples, representing products of Yellowstone ore milled at Three Forks and Sappington,
were submitted to the Technical Center for asbestos analysis by transmission electron
microscopy (TEM). This analysis is in partial fulfillment of RTM's Fiber Management Framework
Program.
Results: The attached TEM results were obtained using the current ASTM draft method "Standard test
method for indirect analysis of talc by transmission electron microscopy for asbestos mass
concentration."
This method is currently being developed by ASTM committee D22.07 (Sampling
and Analysis of Asbestos) and is a modification of ASTM method D 5756 "Standard test method
for microvacuum sampling and indirect analysis of dust by transmission electron microscopy for
loading."
asbestos mass surface The modification is to adapt existing methodology to the specific
analysis of talc products and/or ore samples.
"blank"
A program of laboratory analysis is in place and has been used to determine the detection
limit for this analysis according to ASTM method D 6620, "Standard practice for asbestos
counts."
detection limit based on
Page 1
ITA-Greco-001008
FILED: ERIE COUNTY CLERK 03/17/2023 08:25 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 263 RECEIVED NYSCEF: 03/17/2023
Table 1. Result Summary AMPHIBOLE CHRYSOTILE
Number of Fiber Number of Asbestos
Sample Description Sample No. Structures Concentration Structures Concentration
e5µm <5 µm ppm e5 µm <5 µm ppm
Mistron Monomix 2nd Quarter
A11366-1 0 O BDL 0 0 BDL
composite 2011
Sierralite 252HS 2nd Quarter
A11366-2 0 0 BDL 0 0 BDL
composite 2011
Mistron 100 2nd Quarter
A11366-3 0 0 BDL 0 1 BDL
composite 2011
BDL = Below detection limit, as defined by ASTM D 6620
ITA-Greco-001009
FILED: ERIE COUNTY CLERK 03/17/2023 08:25 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 263 RECEIVED NYSCEF: 03/17/2023
Table 2. Analysis parameters AMPHIBOLE CHRYSOTILE
Grid Total
Starting Aliquot Analytical Detection Analytical Detection
Spaces Sample Sensitivity* Sensitivity*
Sample Description Sample No. Weight Filtered Limit Limit
Analyzed Analyzed
g mL # ng ppm ppm ppm ppm
Mistron Monomix 2nd Quarter
A113ee-1 0.2330 0.1 10 22.4 0.042 0.28 0.028 0.18
composite 2011
Sierralite 252HS 2nd Quarter
A11366-2 0.2389 0.2 10 46.0 0.020 0.13 0.014 0.09
composite 2011
Mistron 100 2nd Quarter
A11366-3 0.2525 0.3 10 72.9 0.013 0.08 0.009 0.06
composite 2011
*Analytical Sensitivity is defined by ASTM D 5756 as the detection of one structure with minimum dimensions.
ITA-Greco-001010
Document Filed Date
March 17, 2023
Case Filing Date
December 10, 2020
Category
Torts - Asbestos
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