This case involves a number of individuals who recently passed away from lung cancer, or have been diagnosed with the same, after working for a major railroad operator for an extended period of time. All of the men involved in the suit were employed as engineers by the railroad for a number of years, and worked with and were exposed to asbestos. It was unknown, however, how much asbestos the men were exposed to over time, requiring an expert assessment of the severity of their likely exposure.
Question(s) For Expert Witness
- 1. Do you have experience reviewing asbestos related matters?
- 2. Are you able to perform a dose calculation as described?
- 3. Please describe your experience as an industrial hygienist and why you would be qualified to review this case.
Expert Witness Response E-008419
I am a Certified Asbestos Consultant (CAC), have set up 2 different Certified Asbestos Counting Labs, and have performed asbestos sampling and analysis for 37 years. I have performed Retrospective Exposure Assessments (REAs) in the past, but have not done a legal case involving asbestos. I would have to construct an REA for this case. This would involve examining work processes, job tasks, and possibly interviewing other the workers directly involved by taking a detailed occupational history, and finding out what they do or did on the job. Sometimes there is historical company data that can be used when occupational histories are not available. Once the who, what, when, where, and how, of the exposure profile is established, the patterns of exposure can be analyzed. Determining the frequency, duration and intensity of exposure provides the essential quantitative input to the REA and permits the industrial hygienist to model the pattern of exposure of individuals and groups.