The Clinic I'm' I'm:ple Witlluut Health Insurance Ben MJ). 1135 N. Main -Avenue. um) -mt.-13311 nu mm} <<@2333 FL-Jaruary H. 2005 MAIL Safety and lid" .'iuilu NC 276% He: at |1etIrt>>ufp:in at Royal C_mul1'u1 liualing Plant #2 an 633 sum I-"lam: saw. 28613 A uupy my Iclh.'.r In Mr. Willie ltoyni Scaling. Pt') Bun 1135-, 2368 1. A copy the letter is |1::inp, mil In an mlwcu: uf untlmacl. letter Itself is Hon1u Imwuvcr, I learned that grunt uI'i'urI:s are undmw:-my in thu In cnrr-cut Ihc I an um knuw Mr. ?"uckru'll but my arm, Pilot wurld's Iurgust utmxlul cubic (im-s_1-tnnw Mr. and he Hm": Mr. E'uukrull was probably LIl'lflWi.ll'l'.' of the until 'nut: at" my earlier letters, fouml its why In him. I cxcucdimgly ru-lu::tum In sent! :1 unpy of 10 won, and did su unly an um mivict: uf cuurmui. 'l'hL-ru are prub_lc:11:s an the plant. um: lacing an general lnuk in the cunapa-1115' caafmcria. I wmild ham to set: this plant's multiph': siumrtuolning-.94 reamli in its being s_hnt dawn. A would he nu-'1 uh: job. Many I-I11: my patients and am: alnmtiy in tdirvz straights [hm sand. I am distressed :11 the terrible' playsical umulitum of' mu: unipluycct. El [.:1IiIm. H1: is utld. may well L_liI: ii rt.-mull {If his In ihis bilfl, but rm; quite. is the plighl Lil' :1 I..;uinn film is the s::1u three -cluildnm. 1'-filu: mu llnlilwly -HI find mark if Ihu Hf lhu nuunnumin as my consultuzuts thinks may bu. Wlizu is In bucmnc 01' this falnilyi' 11 myhcart. Well. said. Ben Wu-l't'urd. Mr. lhiyal Suntilig. ?D'd xv: ;3nuasv1 an ZTIEEITT Ben ord, Ill'5_' Mflitl NEWIHII. -It't6~133lI 2-l-H15 willie Mm, ltuyttl Pt") 23$ NC Mr 1 mn writing. tn you and zitittclittg at to' ::t'ml I-lufultli mt failure: in bttiltg ht ::rt1l1:tesuu:ttil and in and t'etlt:rul tit" yuttr us my with signs t1I1't1 u'r'i:ting from lit at yttur ltlunt #2 at 633 lilacc -aw. NC 3. I itittiurstittui l'hn:; oftltis is it stir.-zumtr spray A-il wcn: it:-asignutl In 11 littc" Iltcfifl wart: used in am mt A copy uf r:iu:h htl-sel he Hllilcillitil. the All seven with gait. tit' thu legs}. gmiit. i'tI'tt'l punt i_ntthi|i_ty up wtillt the the. rtuttl. hr in tandem 'lltu pt'-ittcipttl tin tit' the wits. givutt .1 letter i't-tr dttlivmr tn the ttl' yttur plant' in ?T.irtt_1t.tvur. I:-i I am tine. and his letter that hit with the in-mat severely pt.-rettitt t.'li' tht: gmup. Indmitl. he die its l.l ol'It|tis lcli.-4 initial visit 31. Hr: tbllinw-up 5, his" had I disutlitscd w__it_lt with the- he mt pray 'lltiti is nut is pertitt?nt tu pu'u't'l nut that MH.l:t.: tjuf are nut likely lu yiultt "l"hcy may sltuw cjtc.. lftut 'flan ?lI1t'lt11i'| utnliruly (scvutt itlikctetl an the ztaintt job) and on ctmurilmtl "I'h:it' an-iti. tettantirtattitm by l."l is still in utder. tltit" is very ttguitt any at-' tlmse sew.-n pa-oplt-. wurl: hunt the "g--iuu As liar glut: is In vapttn-it are awn_|_r in spite into tint rule at' unwilling it:-ti:-tfmunt. I stili like tu he ul' -I he I-ht Hun A us: m. tilunti tut. 2 39 'ti -xtu. tut at 5" 5 . - A . 4.3 ~34. . -- 5} ..L.. Ju . an ya. 341..- . . 5gULw-?ua um. Lfii =13.Crv . "2 Fr; rm L.) 'was .0 5 La . ., 'wig'?12 ~35OSHAIS FOI777 300 (Fiev.01t'2004} log of Workfieiated Injuries and illnesses possible while the information is being used for occupational safety and health purposes. Attention: This form contains information relating to employee health end must be used in a manner that - protects the confidentiality oi employees to the extent I O: Etlpl flu 'rear 20 U.S. Department of Labor fill Saul: and Health urn: an-r-n-. 9- use must record htorrnation about every days away tram work, or medrcat treatment beyond first aid. You must 8150 care protesstonat. mu must also record use fines tor a singie case it you need to. term. it you're not sure whether a case is recordable. cal 05"' N533 'Of WP- worti-retatect death and about every '.-mic (D) can Employees, name Job 131]: Dale of injury "mere Ill! occurred or 011"! Nfiflh (Nd) of illness list;-' l'nI|Iu' n-panting hunk-n Ear llnil uvuntlinlnl ufitninmu-Iii' 5' '9 the iunnu Ii--us and Iflln-I I|u- u'l'.ul'.u In-L-tlul. and cunn|I'k'" Ind ul' In qnuul In iuliu-I-Iuu'unu uul-:-I II . :Jmn| then "m mum? Ilunun ('ampI3IuI'um NW. Pr' hi. it -tetated tam or iiness toss at consciousness. restricted wort: acawry or jot: transfer, . record signtticent work-related hitxies and itnesses that are diagnoses' by a physician or licensed health mzutr-related hiuries and messes that meet any at the specific recordng Jnimnn pa" ind-nliny Iitm: In mieur inn. |'uru.m inc uul require-I run tunnel uumbcz. lfgnu have my rutumcnn Ilentu-I mum OSI 111'! lie ml menu! the umugnlneal Iianm In this nflke. cdteda fistedh 29 CFR Part 1904.8 Feettree to . 30t) or term tar each hiury at ittnass recanted on 5 Describe injury or illness, puns ofhody aflected. end objectlsuhuance Ihnl directly injured or nude person ill Strand uh-git: butstx nu tamiasets? . Le it - -1 <>0fVtheTbz3ciyjfrom 'the contrai fhai mania' mt remair": sta and I Qtherss is gm ta _"F:his -assay u-new work on Jworsanad and i ..we;rrt 'to in'-itiative and to raiumio 'because The com; any "semi on page 53%' 3 to who" is the uiara wariae-rs: give: ma rnvse Bate: .. 67 2: Pidaeg. SeatingS2. Paaw Sim. 38:23:' Gig-at 1 fir: Emgk?ajmd 1 he-raigy fiepasa>>. anei saws': firaesantigaf am mti? ta vvacdiarazi Wm: farbid me: its exams-re the giasra, aapi?es? nezvw as 5 -new": hat; taiks. nave: af?ersazi ans? was nexzey .ab??ge{i inwear :3s2r5.s'n22: proiect-?ve saqu?pmenig startecf ?'aeiin:g dizzy and 4% iasi strength am} {if Vmy wen: 12:: 'am 333$ they did Vzza?i find Why: i% am 2' We: 55:: 'trzati; sen: tr; Wmadford wins specifieira "thy: $35: thj?sz - and to rratumtcv fine: if-w auHiv'es, 'Now i carzmr-ai-.v !%wEth'? an p-age in-Athe or?gtna.? nhxsai-cian. 3 amused Signature: fjaii?i ?%%n-zest" E?sirth Eijmgzioyeci -2735:: R.:.:wafe :3-eaiing 833.>> S: Pi-ace Tmccugzamnr Glue: Timaa in Qcaupattoai Empioyed fromf 't{3T7j?7 Thar: 5 hereby degose stopped Vpa'-r of phys'ic%an fram Newtcm was free 'of exasmi-nerd Twere; affectea' at the workpi-ace'. i am prerzieivirzg foam for rzushians, and giue %wa-5. never trained in safeiy-at "the ha_zar,d3. tar pezsanai aqui'pme*nL gr Tmater?sat safety data waa _9rQie'ciic2r; equipmen': and was nave": re?auireci wear ii, . with 'tiredness; the tags" -week IA manna: remain Isianding-Tfar veryjinng. The this situ.aii.os because thaa doctor 3-egnfg %st=w:era? iette:-3 in %{?2ferenTce is :.,base. Rd' the: cases 0? cxther -empiayaea wLhic;'n were: in ':.piage .2 in mg". Maw i 1 the :1 anyth'?ng 2 weary: isadk -.E-mam 311.: 2 Timsta xvSKA, .3: 1 . mam' izszreiazx cfegsezses? and going it: wmr?; physician V'v'a9dia.rQ ma nan ts: ihas factary, i 'fs::rm. am} fiber vvith giufi agm?tez? by :3 spray gun, nave; trained an az memsica? -h-azartis, lszaietzy azam sheets was: never required wear pessonai siariasc? were bending and 2' so-um rm? stay star1>>dmg; anti fiat? 1:3 rm. Iabisa in aim =15: started wifi: am; dizzinessg. Then ism': "from {he wake: azicsvm and i "fee-3% my icas?: rm}; 'nar1.c?s, and 5 was me: ea: give-{mi gainggfizzs Afte-r see-km: -another hes as {mum to mrarkz. is 71:31-e wiifs ?3515: s-qiue. Kwhen fnisj: nae: sen: dzziatm. T. -r cm :12; wig-imasi Ci: ggzimt. mgz: aiirsfi' 3.21:: meiw-a::i in am} mas: zigzag: ?22 Eifii' haxr?zzgz mas': an ii?rzc? gum" .1 .. ifitt' Em': ;*z:3vw" xvzaf?: {mm sank: brzci; spaaznw ?7 :33. mi of . in gram 1 hair; my fades; ma: 21:25: gins?! mic nzmzir re miltzz" . toicf 425::-:21:-3 3 .. 3.3332; war: wen: 33;: <30 .10 mam {?1221 zzftemnxorz an E): -. 13:25; mm: A 213.3-7 remexvafi ?723; szazfurszs 213;: . fer)? am?' 1 wign xivm if an wa-rt-= Slim 21 ':2-mzz {$2.12 szimilzzr .2. ant; 1:3 ixmj?yfi. .:m:Li - Waiimrzfi GI: r?iprii .13. 2111:} 21:3 Lima Lima 2: 3:1; 21:5: tin bin: Dr. an 211.; 12:: izzaavaz CmEFebru21r;= :1 cfaznpiarnx wzu; was: ta . mi. '(frat 1.32:. Tm: Hfiijk has E8. in r;sm:n- izv.-mzczimm. 1330;: :1 2! me. praxbicnz oi "nu: mm"; z-ixrmziz-::* c?ziteci was: explaining if); ma: {ha In =51 cm uiyf' tram: . am} I iifoifiia mg. Hilifi imvicr-; ma-2 my 13:21:: 2:01:22 ?infilib" I - . .. 1. (mm requeatez? an 112:: gum. .awarE:% rscaixaefi zz flue. - .12 zarzsm 33:02:: the: .53 asiittii 5355:': -flaeir' L.=22tc.r, they $12221: ziyixnim arsaf snmia? firzizd {?122 ms zs?gi in" ma: Wfirrzr cm: mm} tr": to (same mm 11nzii mes: Tim . {ii-ztzaz Wm15.. Zliiffi L"f3"" 22:32" Ii)" ts. A: war-2;-. 3 1'0 :22: ?33" ifrztaziz {gm lfliki? Iii. 3 find': wm mtzz.' at: zzms: zsma :5 3111:1221' . 3:1 sampim; :3 {mm rasisirs 1 line '4 W121: M1311 an itmw TERA 5:53' ras; sazngieai tn: za EC, :33 of' fin? am. Zimla?r 3 c; msizzi?zga; 3:2" W35: 32.} 1 iffi?, EEITK -Q, EUR34: J3 2 . 1 4 mm>> .4. ifizvzruua 35%" 357"?! wf 23:35:: 35%. am: wag WW: -WE 53.51'? i7 'mi 95} if ii: EUPTW may: . - i {in :3 RMQLENIF fink . - 7 3 ENCLUKFEK.) 23*! ECPDFENCS . . Fififi IN PR .1. 1&3' <>, m?aum mew mmwcai 3* #21: mi: an sis>>: wan: as yont??sxssi? mm s-amraw; n?mm for ilfihmary Hi Ttumsci an arm' fitiffi-115$ Itumezi ariaxrm 21:. -had .13 fauna: tn be clausiraphahic, me:-2 - Fe%bruax?2 28, C?ifianefi Give: Beaathsz and under P3rsnm3 Eiquigamemi, 9 1.. January-'j 32;, fie}: Wmfihrd. :31" exposure Kifeci. .3001? [1 4 Respimtarsz briierad i mdcreci mam' far' Eifibztzargg? ordera? n?zspirawr and . Fa--bmary' bmmiatie A E. 36 {ppm at tin:-I 0f""'Ies1'i11g: 9 Testers} restricted. iG~iue.fisre2: 3 . 33;, padiocig and lager mew?' 1 S2:-ampicxyaes ciearexi ii): trespitzfamrs, --ciaared. far r?spiratarg. Fs:bmm:y system: Wm. %Reryn<:1fi:s; jfiouth centinue in search -.a?iaeslivs, ardared Tflisp. 'respirators adfied fima' fans {gins ijne ar?arafi GJi{z.vs gii-{urea fir; Gkte emp.l?ryees G133 f9r;r:s;2iratfirs% Ixiarch Pym;-aicie *wifl1 .2. Tc-arzri gas, Mamh IO. Lmdate? an safsi}<<= Tegiacfi WELC- TABLE OF CONTENT 1. $0 INFRODUCTION ATTENDANCE, VACATION, BENEFETS AND HOURS sewm' Dam SHEETS: BLOQDBORNE PATHOGENS EXPOSURE PLAN BRUG SCREENING POLICY TOUR OF FACILETY BREAK AREA AND SMOKING INTRODUCTION I INSURANCE ACCIDENTS -OF. nzasa Norm suraimsor: 93 "'_'35rD T0 55 msraucnom. QUESTIONS - 1 LOCATION OF INFORMATION I SAFETY Dfii.T? SHEE LOCATION: FRONT BVSURKNCE, AFLAC, SAVING PLAN AND ANY OTHER CHANGES OR GENERAL WEL BE POSTE-D IN FOR YOU A FULL - MUSTBE AVAILABLE TO WORK 40 HRSPER WEEK AS FOLLOWS: MONDAY - - 4 - 1 THERE IS A 30 BEGINNING AT I ALSO Two (21 I0 MINUTE BREAKS AT YOU ARE. REQUIRED TO PUNCH IN AND om AT LUNCH REGARDLESS or WHETHER onus'? YOU LEAVE THE PREMISES. vacanox YOUMUSTTBE A TIME EMPLOYEE TO RECEIVE ANY BENEFITS. AFTER 3 CONTINUOUS SERVICE EACH IS ENTWLED TO RECEIVE 8 HOURS PAY FOR . LABDRDAY . FRIDAY AFTER C.-JIJ AFTER 6 SERVICE ONETFULL EITHER ET 4TH DPIIULY OR CHRISTMAS-. IS CLOSES 6-MONTHS. ONE FULLYEAR-OF CONTAINERS .-SERVICE ZND FULL WEEK OF PAID VACATION OFF WITH PAY AFTER YEARS-OP 3RD -WEEK PAID VACATTON TO RECEIVE PAYFOR SINGLE HOLIDAY OR EMPLOYEES MUST WORK THE DAY BEFOREANDTI-IELDAY AFTERTHE I-HOLIDAY. BENEFITS PIEALTH INSURANCE CARRIER IS UNICAEE SUPPLEMENTAL INSURANCE .. AFLAC PLAN .. FIRST UNION AND SA VING PIANARE A VAILA BLE ONL A FTER 60 DA Y3 OF CONTINUOUS EIMPLOYJVIENT AHENDANCE one ABSENCE OR 'n-mes (3) TARDIES IN A ONE (1). Monmpamon. UNABLE To WORK ON A SCHEDULED WORKDAY OR IF GOINGTO BE TARDY. EMPLOYEE IS REQUIRED TO CALL IN -ANIP TALKS THEIR SUPERVISOR OR PLANT SUPERVISOR RESPONSIBLE FOR DECIDING IF THE ABSENCE OR TARDY IS BE EXCUSED. EACH EMPLOYEE IS RESPONSIBLE FOR THEIR OWN WAY TO ANDFROM WORK. TRANSPORTATION IS NOT AN ACCEPTABLE EXCUSE. THE FIRST 60 DAYS EMPLOYMENT ARE CONSIDERED A PROBATIONPERIOIE. DURING THIS TIME. ARE EVALUATEDON PERFORMANCE. THE ABILITY TO WORK WITH -OTHERS. THE ENIPLOYE-E ROYALE COMFORT SEATIN G. RESERVES THE RIGHT FOR ANY REASON DURING THE 60 DAY PROBATIONARY PERIOD TY DATA SHEEFS ROYALI3 CONIFORT SEATING has developed a HAZARD COMMUNICATION STANDARD in our faculty to reduce" the occurrence of workplace illnesses and injuries caused by hazardous chemicals. This st-andarcl is designed to provide information for all new and --existing -employees ofofhercompany, Depending on which area of the plan': you will be working, you will most likely be or around some of "chemical. We have a written plan for all chemicals at this plant. Eachechemicals isiisted on 2 MSDS (Material Safety.Data Sheet) and all information about these chemicals are -found on these -sheets as well as firs: aid for exposure, sideiefiects of exposure, adverse --reactions of exposureand protective equipmew: you can prevent illness or injury. The MSDS 'Boole located in the -front ofiice for-your inspectionoat any time during your employment. You may or may not work with these chemicals, but you should beoaware of their existence in our-plant. You should also know some of the chemicals-'that you will be working around. YOUR SUPERVISOR WILL BE-RESPONSIBLE FOR PROVIDING PROPER PROTECTIVE FOR VOU. IF ANY YOU FEEL THAT YOU AREFEELING SICK NOTIFY, YOU SUP-ERVISOR IMMEDIATEEY. THE FOLLOWING LIST OF CHEMICALS USED IN THIS ADHESIVE used at the glue line. The glue gives of'? vapor when spraying. If the vapors bother you, masks are avaiiable for you protection at no cost. It is "recommendation tat you wear the mast: when working in the spray area. Ifyou get the giuein-you eyes, seek help immediately. If you develop a headache, feel dim andior nauseated, notify your supervisor limrnediateiy. If you accidentally ingest this chemical please contact your supervisor. THINNERICLEANEK used at glue line. This product is used to thin giue or clean glue.-from an abject. inhalation of vapors or mist can cause headaches, nausea, in'itation- of'tl-iernose, throat and lungs. it is recommended that you wearamasl: when using this -product. When :splash'ed on skin, may cause mild irritation, was immediately If you accidentally ingest this product or get in eyes, contact your supervisor hnmediateiy. used.in.:several areas of the: plant. Sewing machine operators use this product to keep their sewing area, (needie and table) slick for ease of sewing material. Cutters use it to acicuiate cutting. Cushion stufiers this sprayjto make stuffing seats smoother. May cause dizziness in high concentration. If appear contact supervisors. immediateiy. No srnoiting in or around this chemiw. SPRAY used by-glue..arealor cushion stufier to make small repair in cushion. -High -vapor content may cause.(iizz.iness or irritation of skin. Avoid contact with skin and eyes. Flush area immediateiy--'with water. No smoking in orarouncl area -where thischemicalis being used or stored. C-60 SOLVENT used in seat, shipping departments and other areas where stains appear on cushions. "This chemical may cause some..irritation'.to the mucous membranes or skin. It ma-ytalso cause drying of the skin. Always -wash the -skin .immeo'iatel_y after contact with soap and water. If accidentally splashed or sprayed in eyes, flush with water immediately. Avoid .breathing va'p'ors. -rnasl: are provided if needed. INK used by cutters to marl: style numbers on material. Proiong breathing of vapors may cause headache or dizziness. Notify supervisor if any appear. FIBER polyester fiber has no know physical or health hazards associated with it. However, exposure to chemieai substances may occur as a result of processing these fibers. Masl:-should be worn -when blowing the fiber into bags; The poiymeriifiher will burn if exposed to flame. No smoking in or around area where fiber is being used or . stored. -EUR20.10 a glycerin base hand cieaner. Should pose no health -problems to user. It' irritation does occur with use, discontinue using this product. Should avoid 'spiashing or rubbing in to eyes. If"-eye exposure does occur. flush immediateiy. PROVON SKIN MOISTURIZER WITH ALOE VITAMINS .. is a hand cream usedzo Wolect your skinizfiom irritation when working around fibers and fabrics. There should be reaction, except for mii? irritation. If irritation does discontinue use. These are the chemicsis.-presens in ourplant. If you wilfi be working in or around any--of the above--mentioned areas you may want tar read more ?nim-lnatiora. The. MSDS -are iocated sin office for your inspection at any {time during your MTHGENS Royaie Comfort Seating, 1113., has a strict policy regarding the handiing of human biood or body. fluids. "If-you witness a cc>>-worker or friend. that has had a 'mjury in the piant, you are not to the--biood orrtouch >>any~surface- ti"l3.t".bi90d' may tainted. 1l7'nere- are certain viruses in sornc human biood that can cause a serious illness. These virusesor micrcv-organisms are calied bloodborne pathogens. "They arrive their name from the fact that they are spread through direct blood contact from a person that has a bloodborne 'illin'ess-suciz (Hepatitis or C) or HIV (Human Immunodeficiency} AIDS. There is no wajryou can tell if a an oilincss, sotrcat -ail biood as if it might be contagious. Should you seerany surface that has biood orblood you -should contact your supervisor immcdiateiy. It is not your to ciean it up, but it is your to Wehavc people trained to handle ali injuries and biood clean 'up. ALWAYS YOU SUPERVISOR IF YOU WFFNESS AN ACCIDENT OE AN ACCIDENTE If you have any questions or ccmcems "regarding in the woricpiace, Royals Comfort Scati inc. hasan BBP Exposure Control Pian iocated in the front ofiice that wit? . -. . explam oranswer your quesuons. Piease feel free to 'read it at any urns. FIRE SAFETY Royals Comfort Seating has a fire -evacuation poiiej; that will be-expiained to you at this time. in theevent of a fire, the building-"wilt be evacuated. The aisrmwill sound and you wilt exit the that will be assigned to you. Each department has an assigned door in which 10 exit. "You wilt aiso have an alternate door should the fire be in the area of your assigned door. Gnee? you are outsfdethe'I.buiiding; you"wi}1" 'fot"you department. Each department has a .difi'erent.area'.to meet. This is very impor'tant'.thatyou adhere to this ruie. You mustbe accounted for bgyour supervisor assoon as the is -'emptied. If you are -not in your group and cannot be -found, someone-L-will haveto boot: for you. Iffor some reason you are in another area ofxthe piant when the alarm sounds you shoutd exit at thernearest doortend continue to yottrown gathering area. When you tour the piant, your supervisor should point these doors out to you and explain the gathefing procedure. If you supervisor faiis to identify these areas, please remind them to do so. These are very important facts you should be aware of. PLICY Royaie Comfort Seating-has estabiished 3 epoiicyand procedure-regarding 3 machine or piece of equipment be serviced or-repaired. Maintenance personnel 'wili.piace a tag on the machine. This Iag will remainunti? it has been repaired or Employees are not to use the machine or in woricingzorder. I '2 NC Department of Labor Inspection Number: 125307636 Division of Occupuiaml Safety-and Health Inspection Dates: - . .. - Date: 11203196 Company Heme: Royale Comfort Sealing. Inc. Inspection Site: Hwy. 16 3.. Teyiorsville, NC 28681 Type ofviolationz Nonserious 29 CPR Employees were not provided information and mining as specified in29 CF11 1910.120!) 00(1) and [Zion henndotu chemicals intheir worlurea thetime oftheir initial assignment end whenever: new hanrd was introduced into their work area: a) facility-for the employees who are exposed to poxentiaiiy huudous chemicals in the foam depamneln. -F :4 3 - .- 0-90. for cm: H. 1 Director Seepageslweughidfia Page mm.-2 me-r.6l93) State of North Carolina Department of Labor Division of Occupational Safety Health WORKPLACE MEASUREMENT SUMMARY Cheri: E-L Berri' John H. Johnson Deputy Director Company: Royaie Comfort Scaring, Inc. PO. Box .235, Taytorsville, NC 28681-0235 Sampiing date(s): Compiiance Officsrz Pat O'Brien OSHA IMIS No; 305088643 During a recen: compliance inspection. employee exposure: monitoring was per;fo1T'medT fol? pcneimr workplace hazards. Ali personal andfor area sampling data was obtained with prc- and postcalibratcd equipment used accordance pracucc. Thcpexposurc are summarized beiow. Empioyeeioper. -Hazard .Sam=pied Exposure Levei Permissibie Exposure finger} .1.-innit (PEL) I lGluc I-bro-mopropan: .245-_pprn 1* 100 "ppm in: Line I-bromopropan: 130 o' I00 .lue Lin: i-bromopropanc 83.9 This record must be maintnined.>>in.4accordance -with 29 CFR l9l0.l020 (Access to Employee Exposure and Medicai Records}. at this timc, does not havc a pcrmissibic exposure limit for E-bromopropanz. The exposure limit listed in the coiumn is the exposure Eirniz. If and' when OSHA docs enforce 2 -PE-IL for 1--broznopropane. it may be Iower than the mannfacturefis recommended limit of 100 ppm. - pam; of comanuinanz per million pans of air. cc: Cu: I CHERIE BERRY TIM CHILDERS COMMISSIONER WEST BUREAU CHIEF Februawry 25 2092 Division or OCCUPATIONAL 'smrehr AND OSH Inspection 305033643 OSH Complaint 203507868 Following your complaint, health compliance officer from the 'Bureau-of'Complianm, Division of Occupational Safety :ancl'Hea'lth' conducted an inspection of Royale Comfort Seating. inc. in Taylorsville, NC~-on Enclosed are copiesof citations tesulting from the inspection. Your complaint (itemizecl and underlmed) is restated below, followed by our findings. 1. Em lovees have not received eic . i . location: of the MSDS boo}: and -ciiemical wig,' tr such gs glue. as gesnlz, em lovees have no -owl . - c. -e Substantiatecl. Employee interviews revealed that some employees who worked' -on the glue line had not received the required hazard communication training. A citation was issued for this item. to 'thenffinieslcreatefl gm 9 mg Substautiatecl. The review of the material safety data sheet (MSDS) for the eadhesleve used on the glue line revealed that the 'adhesive did not contain any chemicals for which the North Carolina Division of Occupational Safety and "Health (N enforced a permi.ss.ible exposure limit The primary ingredient of the glue was I-Bromopropane. The rnanufaculrefs recommended exposure limit was 100 -ppm. according to the MSDS. 901 CREEK - NORTH . (336? 75$ (3363 '76?-2326 Since the health compliance officer (HCO) had no established exposure limit to enforce. the HCO decided to no air sampling to show the employer how the exposure level in their facility compared to the manul-'aetut-er's recommended exposure limit. The results of the air sampling showed that 2 of the 3 sampled employees were exposed to I-Bromopropane at levels above the rnanufactuter'.s recommended exposure limit. Three fans were installed in the wall adjacent to the glue line to provide dilution ventilation. The ECU recommended that the employer install local exhaust ventilation at each of the 9 booths on the glue line. As a result of the lack of enforceable exposure limits, the employer was not required to make employees use respirators. The HCO recommended to the employer "that they' keep National Occupational Health (NIDSI-I) approvetl respirators for organic vapors available for .-employees who wanted to use them. No citations were issued for this item. in the elite line area. . "Cl dfizinssa .Part'tall}' su'ostanti=ateci. The review of the MSDS "for the adhesive used on. the glue line. revealed that the adhesive did not contain any chemicals for - which NCOS-H enforced 2 PEL. The primary ingreclient of the glue was t- Bromopropane. The manufacturer's exposure lirnit was 100 ppm, according to the MSDS. Ls) Since the H00 had no established exposure limit to enforce, the HCO .decidecl to do air. sampling to show the employer how the exposure level in "their facility compared to the rnanufacturcr's recommended <95 percent 2-BP for up to two years, it was reported that amenorrhea accompanied by high follicle stimulating hormone (FSH) levels occurred in 64 percent (16 ex. 25) of the exposed females; azoospermia (absence of sperm), oligospermia (deficiency of sperm), or reduced sperm motility occurred in 75 percent (6 ex. 8) of the exposed males; pancytopenia (reductions in erythrocytes, leukocytes, and platelets) occurred in 21 percent (7 ex. 33) of the workers (23). Reportedly, typical 2-BP concentrations in this setting averaged about 20 ppm, but this information may not be reliable. An investigation of a Chinese chemical plant that produced 2-BP found sperm abnormalities and anemia among exposed workers (24). The Nagoya University group has shown similar reproductive effects in male (25) and female rats (26) exposed to 2-BP. Male rats exposed to 300 ppm and above had significant reductions in testis weight, sperm count, and sperm motility. Erythrocytes, leukocytes, and platelet counts in the peripheral blood were also significantly reduced at the same exposures. There were significant irregularities in the estrous cycle and decreased numbers of ovarian follicles in female rats exposed to 300 ppm and above. Another halogenated propane, 1,2dibromo-3-chloropropane, is a well-recognized testicular toxicant. The close structural analog, bromoethane (BE), underwent toxicity testing by the National Toxicology Program (27). In these studies, two-year inhalation exposures to female B6C3F1 mice resulted in a significant increase in benign and malignant neoplasms of the uterus at the highest exposure (400 ppm). On this basis, the test report concluded that there was clear evidence of carcinogenic activity for the female mouse. There was some/equivocal evidence of carcinogenicity for other species/sex/site combinations. BE was also mutagenic in Salmonella strain TA100 and induced sister chromatid exchanges in Chinese hamster ovary cells. References: (21) Jones, A. and Walsh, D. The Oxidative Metabolism of 1-Bromopropane in the Rat. Xenobiotica 9: 763-772, 1979 (22) Khan, S. and O'Brien, P. 1-Bromoalkanes as New Potent Nontoxic Glutathione Depleters in Isolated Rat Hepatocytes. Biochem. Biophys. Res. Commun. 179: 436-441, 1991 (23) Kim, Y. et al. Hemopoietic and Reproductive Hazards of Korean Electronic Workers Exposed to Solvents Containing 2-Bromopropane. 10 Scand J Work Environ Health 22: 387-391, 1996 (24) Takeuchi, Y. et al. A Review of 2-Bromopropane: Mainly on its Reproductive Toxicity. J Occup Health 39: 179-191, 1997 (25) Ichihara, G. et al. Testicular and Hemopoietic Toxicity of 2Bromopropane, a Substitute for Ozone Layer-Depleting Chorofluorocarbons. J Occup Health 39: 57-63, 1997 (26) Kamijima, M. et al. Ovarian Toxicity of 2-Bromopropane in the NonPregnant Female Rat. J Occup Health 39: 144-149, 1997 (27) National Toxicology Program. Toxicology and Carcinogenesis Studies of Bromoethane in F344/N Rats and B6C3F1 Mice. Technical Report-363. October, 1989 V. Summary: Two consulting firms, ICF Inc. and Environ (the latter group continuing to provide comments to EPA under the name Life Sciences Consultancy), have evaluated the toxicological data and reached slightly different conclusions. ICF concluded the NOAEL was 400 ppm based on its interpretation of the reproductive endpoints. Environ concluded that the NOAEL was 200 ppm based on the studies of Ichihara et al. (12-14) showing decreased sperm counts at 400 ppm and greater. 400 ppm is also a LOAEL for white matter vacuolization in the brain of rats. More recent work by Ichihara et al. and by Wang et al. (15) suggest that effects on the male reproductive system are visible even at 200 ppm. OSHA suggests that there is a pressing need to pin down the "true" NOAEL--even better, to use standard study designs and statistical methods to establish a "benchmark dose" for each compound, so that regulatory agencies can rationally consider setting risk-based exposure limits. Moreover, until twoyear cancer bioassays are conducted on each compound, agencies have no way to assess whether reproductive toxicity is indeed the most sensitive adverse endpoint. VI. Ongoing Toxicological and Environmental Studies in the Government, Industry, and Academia: OSHA is aware of two ongoing efforts to expand the toxicological data base for 1-BP. In a May, 1999 letter expressing support for the approval of 1BP as a substitute for ozone-depleting substances in EPA's SNAP program, the Brominated Solvents Committee (BSOC), a consortium of three 1-BP 11 producers, acknowledged sponsoring a two generation reproductive effects study and a developmental study in rats by inhalation (28). The study design will presumably exceed current EPA and OECD guidelines and include evaluation of sperm morphology and estrous cycle. The current status, study protocol, and timetable for completion of these studies was not stated in the submission. OSHA learned recently that these studies were halted in mid1999 because of infertility in the control groups. BSOC has restarted the studies very recently (although reportedly using the same contractor and supplier of lab animals) and expects to provide results to EPA by July 2000. Given the preliminary data presented at the recent Annual Meeting of the Japan Society for Occupational Health, research to further understand the reproductive and neurological effects of 1-BP in experimental animals will likely be pursued by investigators at Nagoya University and elsewhere in Japan. Reference: (28) Brominated Solvents Committee. Letter to EPA Air Docket #A-91-42 Regarding Support for SNAP Approval of n-Propyl Bromide. May, 1999 VII. Rationale for Recommendation and Suggested Studies: Beyond the potential for widespread occupational and possible environmental exposure, the information provided by preliminary toxicological studies on 1-BP and data from related alkyl bromides raise various concerns with regard to human health. The effects on reproductive tissue of male rats caused by short exposures to 1-BP suggest the need for longer term studies to assess reproductive function. The reproductive impairments in female and male workers exposed to its isomer, 2-BP, reinforce the need to evaluate this endpoint in both sexes along with effects on human development. The mixed results in the limited genotoxicity testing of 1-BP, its alkylating potential, and the tumorigenicity of the structurally-related BE suggest the need for additional short-term tests and a cancer bioassay. The clear neurotoxicity at high doses combined with abnormal neurophysiology at lower exposures indicate the need for more complete evaluation of neurological function. Additional toxicity testing would provide the necessary data to better identify hazard and estimate risk to workers which are essential to deriving exposure limits that protect worker health. Suggested studies are as follows. Input from the various National Toxicology Program (NTP) committees is encouraged. OSHA believes it is essential that both reagent-grade 1-BP and 2-BP be tested separately, if at all possible. Because commercial 1-BP contains significant trace levels of 2-BP, a "negative" result from testing 1-BP alone may 12 not shed light on the hazard potential of the commercial product. On the other hand, a positive result if the commercial product were tested might not indicate that pure 1-BP (assuming it could be formulated in quantity) is necessarily hazardous. OSHA recommends that NTP consider the following tests: ? Carcinogenicity Study - The full two year National Toxicology Program (NTP) bioassay protocol in both sexes of rats and mice is recommended for both compounds. The test compounds should be administered by inhalation at the maximum tolerated exposure and at least two other non-zero exposures. Specialized studies evaluating DNA binding, oncogene activation, cell proliferation, etc. should be considered as appropriate. ? Multi-generation Reproductive Study - Unless there is a successful and thorough completed study from industry sponsors, a reproductive study in exposed rats of both sexes covering at least two generations of mating is recommended. Exposure should be by inhalation and conducted by accepted NTP protocols. It is strongly recommended that spermatogenesis, estrous cycle, and hormonal endpoints be measured as well as the standard fertility and pregnancy outcomes. ? Developmental Studies - It is recommended that developmental effects be evaluated in two species. Test compounds should be administered to pregnant animals by inhalation from the period of implantation to the end of gestation. The studies should be conducted by standard protocols and the usual maternal and fetal endpoints examined. ? Subchronic Neurotoxicity Study - It is recommended that neurological endpoints be evaluated during the standard 14 week exposure study in rats. These should include a Functional Observation Battery, neurophysiological endpoints, and specialized neuropathology as appropriate. ? Genotoxicity - A battery that adequately evaluates mutagenicity and clastogenicity in mammalian systems using sensitive in vitro and in vivo test methods is recommended. ? Toxicokinetic/Mechanistic Studies - It is recommended that toxicokinetics of the test compounds be evaluated following inhalation exposure over the appropriate dose range. The extent of absorption, tissue distribution, body residence time, major metabolites and pathways of elimination should be identified. Additional studies that provide a better understanding of target organ dosimetry, mode of action or dose - response is also suggested. Date: 11-16-2006 Subject: Conversation, which included Dr. Hillel Magid, to review nPB usage distribution between adhesive, aerosol and solvent applications Participants: M. Sheppard (EPA), K. Schlueter (EPA), J. Cromwell (Stratus Consulting), Dr. H. Magid (Environmental Consultant) 1. How much nPB is used in Aerosol Cleaning? Boeing, Clean Tech Article, using nPB to clean air wings (wipes) China produces large quantities of cheap, good cleaner and the only concern by users is compatibility with products it is cleaning Large companies proactive about nPB use but should be, they are afraid to use nPB because of large lawsuits from users (workers) o CA--Health Department to regulate nPB o European Union--labeling nPB as highly flammable Liability concern o Smaller companies are less concerned because wages are low and likely employ illegal immigrants o Big companies are more concerned with liability because they are more susceptible o OSHA is tough but their budget is small and are not going to crack down on small businesses o Large companies in the long run avoid rework and have improved processes which eliminates the need for portable cleaners 2. How many fume hoods being used per firm? o Small companies have a need for rework operations o Engineer in house hose/motor apparatus to pull fumes out of rework area (fume hood device) o Or rework all components at one time--end of shift all items for rework at one time o Price for fume hood: $1000-1500 o Use of nPB much cheaper than using flammables o Firms will write off ventilation costs o Ventilation costs will not be a deterrent to using nPB Expnsuresand Recnmmended Limits ldwering i1: limits fr::Im 1-II -3.1 EPA esljmated that air 1-II meters a plant using high amdun1: ::IfnFEl spravglue wduld df s::Ime feelingin 1:heirt::Ies afierhreathing between-3.9 and 49 dunng an eight-hdur shi1'L [|:hihaIa et al, Dn December 2-939, Ealifdrnia DE-H set a state 5 e:-:p:rsed td rdughlv E.E ::IfnFEl suffered signifi ant nerve damage IJ et al, In 1999, Envirdn Edrp, aresear:h firm, that e:-rpdsures l:Ie|imitedt::I between 2 and [1999] The |I::Inferen:e df |ndus1:ria| Hvgienisl: an EHF|El'5lJFEiil'l'li't ::if1-II in 2-934. levels as high as 15.4 in the breath exhaled l:Iv:ushi::In makers after an eight-h::IurshiFt [Han|ev et a|:I With help NIDEH, dne :ushi::In Eustdm Fr::Idu:1:, In: redu-:ed mean 1EE.9ppm td 19ppm resdmmend ed in 23-3? that emp|::Ivers refrain exp::rsingv.r::irl:erst::I levels al:I::rve ppm. Dne stud-,r ::Ifv.r::Irl:ers using nFEl as a sdlventfdund thevtvere levels as high as 9-3.2 inspe:t::Irsfind hrea1:l1ing up t::I 91ppm at Fdam in l'l::Irth Eardlina. [fi.ugust, at a :|eaner using nFElt::I :|ean :l::Ithing were t::I levels as high as SE EHPCIEIJFEE in plants using average amdunts df nFEl in averageventilatidn will be rdughlv E-II ppm, finds [June Eight rl-cers an unnamed :ushi::In-mal:ing plant in l'l::Irth Eardlinawere t:I have an e:-rpdsure average ::If 91 plant and findvv::Irl;ers l:Irea1:l1ingin nFBat levels as high as 2-311:: At Highland Fdam in Eardlina, fdund lzlreathing glue fumes up ta in In an 2-II2 lettertd Flep. Franl: Falldne, argued that a 1-3-3 limit is safef::IrnFEl a plant in Edndver l:Iread1ing nFE.furnesat levels up td investigatdrs fdund wdrkers l:Irea1:l1ing nFEl atTh::imasvi||e, Eushidn Edmpanv at Chinese plant: v.-hish manufa:tu re have been td levels as high as in Utahfdund td he l:Ireathingl:Ietween 91 and df hdspitalized. pr::Il:I|erns in rats e:-:p::Ised ta 233 ppm, Wang et al repdrt. [1999] At Franklin in H::Iust::In, Mississippi, l:Irea1:l1ingfumes at levels as high as 219 sampling results shdwed d1ree rkers e:-ipdsed td high levels at Fldvale E-eating. Iidrnpanies using an average amdunt in expdse 299 ppm, estimated. [2-939:! at Mar:-: lndustnes in .5-aw fdund 17-' expdsedtd levels as high as E9 [June 1999:! inspe:ted a :ushi::In-making plant in 2-939 ::Iv.rned Edntdur Enterprises LI: and fdund e:-:p:Ised td 1997-' studv, l:Iv:hemi:3| in rats e:q:I::Isedtd41-II-Elppm f::Ir19v.reel:s. In June, 23-39, EFF-. predi:ted that heavv users ::If nFEl-l:Iased glueswith average ventilatidn e:-:p::Ise v.r::Irl:erst::I ILev al of ppm] Elf-Atochem statement . 1of3= ornocarbon 2 reenpeace The following is a statement published by Elf-Atochem IS as been reproduced verbatim and any errors are their's). Please note that the formatting of bulleted phrases has been modified to suit our theme: Product Health Safety Department 5tl1 December 1997 n-Propvl Bromide and solvent use Elf Atochem's position relating to potential health risks Because of a recent information jromthe Environmental Protection Agency in the US, we feel it has become necessary to clarify Elj"Atochem '3 position regarding potential eflects of to health and reiterate our reservations on its use as a substitute for main halogenated solvents. Our fears revolve around the serious risks and worries of solvent use: genotoxicity, carcinogenicity, and toxicity on reproduction. This is for the following reasons: is a chemical reaction agent for alkylation, and this reaction is potentially present at a biological level where it can cause the following serious effects: 0 genotoxicity/carcinogenic (by altering DNA) effects on reproduction (by attacking the cells of male and female reproduction organs; teratogenic effects/foetus) haematological problems (by attacking bone marrow cells) is part of a high risk group: several made up of a bromoaliphatic structure show the above mentioned toxicological properties (for example, ethyl bromide, isopropyl bromide, dibromoethane, bromohloroethane, dibromochloropropane); The available toxicological information on shows a doubt concerning its genotoxicity Used as a solvent, there is a total lack of toxicological data relating to carcinogenicity and reproduction (see attachment) However, one must remember that when Elf Atochem, CFC producer, wanted to substitute CF Cs with the new HF Cs, complete toxicological programmes had already been launched (PAFY), in collaboration with other producers, to show the harmlessness of each of these substitutes, especially in the fields ofgenotoxicity, carcinogenicity and reproduction. Today, we think that a similar route should be followed to evaluate the health risks if we wish to develop a new main halogenated solvent instead of the old chlorinated and fluorinated solvents. Furthermore, it is advisable to remember recent incidents occurred to man due to early and uncontrolled use of isopropyl bromide in a solvent application. In 1995 we learnt that in Korea isopropyl bromide had caused some 20 serious cases involving problems with reproduction (stopping sperrnato genesis, stopping ovarian cycle) and anaemia following use as a degreasing solvent. This information is now published in toxicology literature (KIM H.Y., JUNG et al "Hematopoietic and Reproductive Hazards of Korean Workers Exposed to Solvents Containing 2 bromopropane" Scand. J. Work Environ, Health 1996, 22, 387 - 391). A year later, 25 similar cases, discovered in China confirmed the reprotoxic and hernatotoxic impact of BiPon humans (ICHIHARAM. et al "Study from 11/03/1999 9:50 Elf-Atochem statement -Q. 2of3 . Ql a View Point of Labour Hygiene of 2--bromopropane Producing Plant in China" presented by Nagoya University to Japanese Industrial Hygiene Society, April 9 - ll, 1997). At the same time, tests on rats showed the same type of toxic effects from concentration of 300 by inhalation (ICHIHARA G. et al. "Testicular Toxicity of 2-bromopropane". J. Occup. Health, 1996, 38, 205 -- 206.) In the context of following "Responsible Care" to which Elf Atochem subscribes, this data on isopropyl bromide has driven Elf Atochern to the voluntary class of reprotoxic for isopropyl bromide in its Health and Safety Data Sheet which has led to the labelling ("toxic", skull) and 60 ("can affect fertility"). At the same time, we have informed the French authorities according to the Control of Chemical Products Law (1977) and in June 1997 we sent them a request for classification as "toxic for reproduction in category 1 (effect proved in humans)" and submission to the EU. France wished to add a phrase 48/20, to give the anaemic affects observed in humans.. In conclusion, given current knowledge, our worries on the toxicology of remain intact. As long as the necessary toxicological studies are not carried out, it will not seem reasonable to recommend in solvent use for which exposure is not easily controlled. fit ATTACHMENT I1-PROPYL BROMIDE TOXICOLOGICAL DATA NEEDED ACUTE TOXICITY oral route available dermal route available inhalation route available LOCAL EFFECTS - cutaneous irritation available ocular irritation available sensitisation available 9 GENOTOXICITY Ames test available micronucleus test available gene mutation in cultured cells - (L 5178 mouse avaflable cells) DNA alkylation assay to be (DNA adducts) performed* in vivo unscheduled DNA to be performed 0 TOXICITY FOR REPRODUCTION teratogenicity study in rats goefiimed teratogenicity study in to be rabbits performed fertility study in rats ll-'joegeonned REPEATED DOSE TOXICITY 11/03/1999 9:50 AM Elf-Atochem statement . . REPEATED DOSE TOXICITY subacute toxicity done subchronic toxicity done . .. - to be tox1c1ty performed to be CARCINOGENICITY STUDY perfmmed *The co|our of the text in red has been added by Protonique to highlight the tests that have not yet been performed. We, at Protonique SA, are grateful to the authors for the kind permission to reproduce this Elf Atochem data. To return to where you left off, on the page on bromocarbon solvents. click here This page last revised 13.09.98 (30 to Text--on|v Home Page .2. All Trade Marks and Registered Trade Marks used in any page of this site are acknowledged as the property of their owners. Any technical or commercial questions may be addressed-to postmaster@protonique.com Any questions or remarks regarding this site may be addressed to webmaster@protonique.com E3 The contents of all the pages on this web site are copyright (C) Protonique SA, Romanel-3-Lsn, 1 996- 1 999. (For conditions of reproduction, please consult the Legal Notices on our Home Page) 3 0f3 - 11/03/1999 9:Page 1 FRANKLIN CORPORATION v. PAULINE TEDFORD, LORA SMITH, JUDY HAIRE AND SAMANTHA MIXON NO. 2007-CA-01454-SCT SUPREME COURT OF MISSISSIPPI 18 So. 3d 215; 2009 Miss. LEXIS 426 September 10, 2009, Decided May 14, 2009, Filed PRIOR HISTORY: [**1] COURT FROM WHICH APPEALED: CALHOUN COUNTY CIRCUIT COURT. DATE OF JUDGMENT: 07/26/2007. TRIAL JUDGE: HON. ANDREW K. HOWORTH. Franklin Corp. v. Tedford, 2009 Miss. LEXIS 169 (Miss., Apr. 16, 2009) DISPOSITION: AFFIRMED. CASE SUMMARY: PROCEDURAL POSTURE: Appellee employees sued appellant employer alleging multiple claims for batter and intentional infliction of emotional distress that arose from injuries sustained in the course of their employment. A jury returned a verdict in favor of the employees. The Calhoun County Circuit Court (Miss.) denied the employer's motions for judgment notwithstanding the verdict (JNOV), or in the alternative for a new trial or remittitur. The employer appealed. OVERVIEW: The employer was a furniture manufacturer. The employer used a certain adhesive that contained a neurotoxin and it was necessary to have the area well ventilated. Despite the savings the employer enjoyed from using the adhesive it did not install mechanical ventilation exhausts outside the building on the glue line. The employees eventually were hospitalized because of their exposure to the neurotoxin. At issue on appeal was the application of the intentional tort exception to the Mississippi Workers' Compensation Act. Miss. Code Ann. ? 71-3-1 et seq. The Supreme Court found that given the considerable amount of testimony offered by the employees and the management personnel of the employer the denial of the JNOV motion was proper. The experts' testimony was properly admitted under Miss. R. Evid. 702 because their qualifications were not legitimately questioned, and their testimony was sufficiently relevant and reliable. There was sufficient evidence to meet the "clear and convincing" standard required for punitive damages under Miss. Code Ann. ? 11-1-65 and the court's determination of the employer's net worth at the time of judgment was proper. OUTCOME: The judgment was affirmed. CORE TERMS: exposure, ventilation, glue, punitive damages, glue-line, net worth, ppm, intent to injure, exclusivity, intentional torts, knowingly, willful, air, expert testimony, deposition, scientific, neurologic, symptoms, booth, exclusive remedy, reliable, workmen's, recommended, respiratory, worker's compensation, recommendations, workplace, hazardous, battery, exposed LexisNexis(R) Headnotes Workers' Compensation & SSDI > Coverage > Actions Against Employers > Intentional Misconduct Page 2 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** Workers' Compensation & SSDI > Remedies Under Other Laws > Exclusivity > Exceptions [HN1] Miss. Code Ann. ? 71-3-9 (2000) provides, in part, that the liability of an employer to pay compensation shall be exclusive and in place of all other liability of such employer to the employee. However, based upon the statutory requirement that the "injury" be "accidental" to be compensable under the Mississippi Workers' Compensation Act, Miss. Code Ann. ? 71-3-1 et seq., the Mississippi Supreme Court has found that some intentional torts are outside the scope of the exclusivity provision in ? 71-3-9. Miss. Code Ann. ?? 71-3-3(b), 71-3-7. The Act does not bar an employee from pursuing a common law remedy against his employer for an injury caused by his employer's wilful and malicious act. Where an injury is caused by the willful act of an employee acting in the course and scope of his employment and in the furtherance of his employer's business, the Act is not the exclusive remedy available to the injured party. This limitation on the Act's exclusivity reflects the public policy that certain courses of conduct (intentional torts) are so shockingly outrageous and beyond the bounds of civilized conduct that the person responsible should not be rewarded with tort immunity. Workers' Compensation & SSDI > Coverage > Actions Against Employers > Intentional Misconduct Workers' Compensation & SSDI > Remedies Under Other Laws > Exclusivity > Exceptions [HN2] With regard to the Mississippi Workers' Compensation Act, Miss. Code Ann. ? 71-3-1 et seq., a mere willful and malicious act remains insufficient to give rise to the exception under the Act. Reckless or grossly negligent conduct is not enough to remove a claim from the exclusivity of the Act. The employee also must establish that the egregious act was accompanied by an "actual intent to injure" in order to except the Act's grant of exclusivity. Thus, Mississippi is in concurrence with an overwhelming majority of states in requiring an "actual intent to injure" the employee. Civil Procedure > Appeals > Standards of Review > De Novo Review Workers' Compensation & SSDI > Coverage > General Overview [HN3] The applicability of the Mississippi Workers' Compensation Act, Miss. Code Ann. ? 71-3-1 et seq., is a question of law. This Court reviews questions of law de novo. Workers' Compensation & SSDI > Coverage > Actions Against Employers > Intentional Misconduct Workers' Compensation & SSDI > Remedies Under Other Laws > Exclusivity > Exceptions [HN4] With regard to the Mississippi Workers' Compensation Act, Miss. Code Ann. ? 71-3-1 et seq., certain intentional torts are outside the scope of the exclusivity provision contained in Miss. Code Ann. ? 71-3-9 (2000). Where an injury is caused by the willful act of an employee acting in the course and scope of his employment and in the furtherance of his employer's business, the Act is not the exclusive remedy available to the injured party. The Act does not bar an employee from pursuing a common law remedy against his employer for an injury caused by his employer's wilful and malicious act. Mississippi law clearly provides that certain intentional torts lie beyond the scope of the Act's exclusivity. Workers' Compensation & SSDI > Coverage > Actions Against Employers > Intentional Misconduct Workers' Compensation & SSDI > Remedies Under Other Laws > Exclusivity > Exceptions [HN5] With regard to the Mississippi Workers' Compensation Act, Miss. Code Ann. ? 71-3-1 et seq., a mere willful and malicious act remains insufficient to give rise to the exception under the Act. Reckless or grossly negligent conduct is not enough to remove a claim from the exclusivity of the Act. Before recovery may be had for the specific injuries and/or diseases which the plaintiffs claim, there must be proof of actual intent to injure by the employer. Workers' Compensation & SSDI > Coverage > Actions Against Employers > Intentional Misconduct Workers' Compensation & SSDI > Remedies Under Other Laws > Exclusivity > Exceptions [HN6] With regard to the Mississippi Workers' Compensation Act, Miss. Code Ann. ? 71-3-1 et seq., in order for a willful tort to be outside the exclusivity of the Act, the employee's action must be done with an actual intent to injure the employee. It is not enough to destroy the immunity that the employer's conduct leading to the injury consists of aggravated negligence or even that the conduct goes beyond this to include such elements as knowingly permitting hazardous conditions to exist or willfully failing to furnish a safe place to work or knowingly ordering the employee to perform a dangerous job. Workers' Compensation & SSDI > Coverage > Actions Against Employers > Intentional Misconduct Page 3 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** Workers' Compensation & SSDI > Remedies Under Other Laws > Exclusivity > Exceptions [HN7] With regard to the Mississippi Workers' Compensation Act, Miss. Code Ann. ? 71-3-1 et seq., the employer's conduct may have been reckless, negligent, or grossly negligent, but that is not enough to remove this case as an "intentional tort" from the exclusivity of the Act. The Mississippi Supreme Court holds that the employer's action must be done with an actual intent to injure the employee, and that an intentional tort is an act of intentional behavior designed to bring about the injury. Workers' Compensation & SSDI > Coverage > Actions Against Employers > Intentional Misconduct Workers' Compensation & SSDI > Remedies Under Other Laws > Exclusivity > Exceptions [HN8] With regard to the intentional tort exception to the Mississippi Workers' Compensation Act, Miss. Code Ann. ? 71-3-1 et seq., to be deemed intentional, the employer's acts or inaction must be designed to bring about the injury. Civil Procedure > Appeals > Standards of Review > Substantial Evidence > General Overview [HN9] "Substantial evidence" has been defined as information of such quality and weight that reasonable and fair-minded jurors in the exercise of impartial judgment might have reached different conclusions. Evidence > Testimony > Experts > Admissibility [HN10] Under Miss. R. Evid. 702, trial courts are charged with being gatekeepers in evaluating the admissibility of expert testimony. The Mississippi Supreme Court is confident that the learned trial judges can and will properly assume the role as gatekeeper on questions of admissibility of expert testimony. Accordingly, the trial judge has the sound discretion to admit or refuse expert testimony; an abuse of discretion standard means the judge's decision will stand unless the discretion he used is found to be arbitrary and clearly erroneous. The Supreme Court performs only the comparatively narrow analysis of whether the district court's determination that the opinion was sufficiently grounded in "good science" to assist the jury constituted an abuse of that court's discretion. Evidence > Testimony > Experts > General Overview Evidence > Testimony > Experts > Admissibility [HN11] Miss. R. Evid. 702 states: if scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education, may testify thereto in the form of an opinion or otherwise, if (1) the testimony is based upon sufficient facts or data; (2) the testimony is the product of reliable principles and methods; and (3) the witness has applied the principles and methods reliably to the facts of the case. Evidence > Testimony > Experts > General Overview Evidence > Testimony > Experts > Admissibility [HN12] The trial judge must ensure that an expert's testimony both rests on a reliable foundation and is relevant to the task at hand. Pertinent evidence based on scientifically valid principles will satisfy those demands. This rule makes it necessary for a trial court to apply a two-pronged inquiry when evaluating the admissibility of expert testimony: (1) is the witness qualified; and (2) is the testimony relevant and reliable? Evidence > Testimony > Experts > Daubert Standard [HN13] In Daubert v. Merrell Dow Pharms., Inc., the United States Supreme Court set out four non-exclusive factors to aid in the determination of whether the methodology is reliable. They are: (1) whether the theory or technique has been tested; (2) whether the theory or technique has been subjected to peer review and publication; (3) the known or potential rate of error of the method used and the existence and maintenance of standards controlling the technique's operation; and (4) whether the theory or method has been generally accepted by the scientific community. This approach is a flexible one. Its overarching subject is the scientific validity -- and thus the evidentiary relevance and reliability -- of the principles that underlie a proposed submission. The focus, of course, must be solely on principles and methodology, not on the conclusions that they generate. Evidence > Scientific Evidence > General Overview Evidence > Testimony > Experts > General Overview Page 4 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** [HN14] With regard to expert testimony, "scientific" implies a grounding in the methods and procedures of science. Evidence > Testimony > Experts > General Overview [HN15] With regard to expert testimony, "knowledge" applies to any body of known facts or to any body of ideas inferred from such facts or accepted as truth on good grounds. Of course, it would be unreasonable to conclude that the subject of scientific testimony must be "known" to a certainty. Furthermore, in order to qualify as "scientific knowledge," an inference or assertion must be derived by the scientific method. Civil Procedure > Appeals > Standards of Review > Abuse of Discretion Evidence > Procedural Considerations > Rulings on Evidence [HN16] In Mississippi, only if the circuit judge abused his discretion in an evidence ruling, acting in an "arbitrary and clearly erroneous" manner, will the Mississippi Supreme Court find error. Evidence > Testimony > Experts > General Overview [HN17] With regard to expert testimony, while case-study review is certainly an accepted methodology, trial courts still must be certain that the content of those case studies is relevant to the facts at hand. Torts > Negligence > Causation > General Overview [HN18] Under some circumstances, a strong temporal connection is powerful evidence of causation. Civil Procedure > Trials > Jury Trials > Jury Instructions > General Overview [HN19] In Mississippi, in reviewing the grant or denial of jury instructions, the Mississippi Supreme Court has stated that reviewing courts are required to review all of the instructions as a whole. No instruction should be reviewed in isolation. When analyzing the grant or refusal of a jury instruction, two questions should be asked: Does the instruction contain a correct statement of law and is the instruction warranted by the evidence? Defects in specific instructions will not mandate reversal when all of the instructions, taken as a whole fairly -although not perfectly -- announce the applicable primary rules of law. The Supreme Court will not hesitate to reverse if the instructions, when analyzed in the aggregate, do not fairly and adequately instruct the jury. Workers' Compensation & SSDI > Coverage > Actions Against Employers > Intentional Misconduct Workers' Compensation & SSDI > Remedies Under Other Laws > Exclusivity > Exceptions [HN20] In Mississippi, the Mississippi Workers' Compensation Act, Miss. Code Ann. ? 71-3-1 et seq., is exclusive absent an actual intent to injure the employee. Workers' Compensation & SSDI > Coverage > Actions Against Employers > Intentional Misconduct Workers' Compensation & SSDI > Remedies Under Other Laws > Exclusivity > Exceptions [HN21] With regard to whether a claim is exemption for the Mississippi Workers' Compensation Act, Miss. Code Ann. ? 71-3-1 et seq., as an intentional tort, it is well settled that intent may be shown by circumstances. Civil Procedure > Trials > Jury Trials > Jury Instructions > General Overview [HN22] The law requires all jury instructions to be read together. The instructions must be taken together and be construed as a whole, one as modifying, explaining or qualifying another; and, if the instructions taken as a whole correctly announce the law applicable to the case, a reviewing court will not reverse the judgment because of an imperfect single instruction. Where it may be fairly charged that one or more instructions may have been confusingly worded, a reviewing court should not reverse if other instructions clear up the confusing points. Defects in specific instructions do not require reversal where all instructions taken as a whole fairly -although not perfectly -- announce the applicable primary rules of law. Civil Procedure > Trials > Jury Trials > Jury Instructions > General Overview [HN23] A conflict between jury instructions does not justify reversal, if the evidence overwhelmingly supported the plaintiffs' claims and does not result in a miscarriage of justice. In short, the conflict in the evidence made the jury the judges of what the truth was with reference thereto, and courts are unable to say that the jury reached the wrong result. Page 5 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** Civil Procedure > Remedies > Damages > Punitive Damages Torts > Damages > Punitive Damages > General Overview [HN24] The primary purpose of punitive damages is to punish the wrongdoer and deter similar misconduct in the future by the defendant and others. Miss. Code Ann. ? 11-1-65(1)(e) (2002). Punitive damages may not be awarded if the claimant does not prove by clear and convincing evidence that the defendant against whom punitive damages are sought acted with actual malice, gross negligence which evidences a willful, wanton or reckless disregard for the safety of others, or committed actual fraud. Miss. Code Ann. ? 11-1-65(1)(a) (2002). Punitive damages are only appropriate in the most egregious cases so as to discourage similar conduct and should only be awarded in cases where the actions are extreme. The trial court is the gatekeeper for the issue of whether punitive damages, in cases involving both intentional and non-intentional torts, should be submitted and considered by a jury. Civil Procedure > Remedies > Damages > Punitive Damages Civil Procedure > Appeals > Standards of Review > Abuse of Discretion Torts > Damages > Punitive Damages > General Overview [HN25] An abuse of discretion standard is implemented when a reviewing court reviews the trial court's decision of whether a case warrants punitive damages to be sent to the trier of fact. Civil Procedure > Remedies > Damages > Punitive Damages Civil Procedure > Appeals > Standards of Review > De Novo Review Torts > Damages > Punitive Damages > Award Calculations > Appellate & Posttrial Review [HN26] The proper assessment of punitive damages under Miss. Code Ann. ? 11-1-65(3) is a question of law, to be reviewed by the Mississippi Supreme Court de novo. Civil Procedure > Remedies > Damages > Punitive Damages Torts > Damages > Punitive Damages > Award Calculations > Factors [HN27] Miss. Code Ann. ? 11-1-65(3) (2002) provides, in part, that: (a) In any civil action where an entitlement to punitive damages shall have been established under applicable laws, no award of punitive damages shall exceed the following: (v) $ 5 Million Dollars for a defendant with a net worth of more than $ 50 Million Dollars but not more than $ 100 Million Dollars; or (vi) Four percent of the defendant's net worth for a defendant with a net worth of $ 50 Million Dollars or less. (b) For the purposes of determining the defendant's net worth in paragraph (a), the amount of the net worth shall be determined in accordance with Generally Accepted Accounting Principles. COUNSEL: FOR APPELLANT: JAMES LAWTON ROBERTSON, JENNIFER HUGHES SCOTT, ELIZABETH G. HOOPER, BRIDGET E. KOBS. FOR APPELLEES: HEBER S. SIMMONS, III, WILLIAM MELVIN ROSAMOND, DOUGLAS G. MERCIER, JOHN ROBIN BRADLEY, JR. JUDGES: WALLER, C.J., CARLSON, P.J., RANDOLPH, LAMAR AND PIERCE, JJ., JOIN THIS OPINION. GRAVES, PRESIDING JUSTICE, SPECIALLY CONCURRING. DICKINSON, JUSTICE, SPECIALLY CONCURRING. OPINION BY: RANDOLPH OPINION [*219] ON MOTION FOR REHEARING NATURE OF THE CASE: CIVIL - WORKERS' COMPENSATION EN BANC. RANDOLPH, JUSTICE, FOR THE COURT: Page 6 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** P1. The motion for rehearing filed by Franklin Corporation is denied. The previous opinions of this Court are withdrawn and these opinions are substituted therefor. P2. Today we are presented with the latest conflict in the ongoing legal struggle between industry and labor regarding compensation and medical indemnity for employees injured in the workplace. The appellees/employees seek to expand the scope of egregious conduct excluded from the Mississippi Workers' Compensation Law ("Act") to include acts which are "substantially certain" to cause injury to the employee. [**2] Not surprisingly, the appellant/employer clamors for the opposite, requesting that this Court overrule Miller v. McRae's, Inc., 444 So. 2d 368 (Miss. 1984), and its progeny and retreat from these decisions, which exclude employers' tort immunity for certain egregious acts accompanied by an "actual intent to injure" the employee. After due consideration and deliberation, this Court chooses to do neither. The constitutionally delineated forum for change is the Mississippi Legislature, not this Court. We find that the correct balance is in place and so shall remain, unless the Legislature should decide otherwise. P3. In the case sub judice, Pauline Tedford, Lora Smith, Judy Haire, and Samantha Mixon ("Plaintiffs") filed suit alleging multiple claims against multiple defendants, including claims against their employer, Franklin Corporation, for battery and intentional infliction of emotional distress arising from injuries sustained in the course and scope of their employment. Franklin Corporation filed a "Motion to Dismiss" and a "Motion for Summary Judgment," contending that the exclusive remedy for the Plaintiffs was provided by the Act. After due consideration by the circuit court, the [**3] trial judge denied the relief sought and set the matter for trial. At trial, the jury found in favor of the Plaintiffs, awarding both compensatory and punitive damages. Thereafter, the circuit court denied Franklin Corporation's "Motion for J.N.O.V., or in the Alternative, for New Trial or Remittitur," but reduced the punitive damage award. From those rulings, Franklin Corporation appeals. HISTORICAL BACKGROUND P4. The demand of labor for the protection of workers' compensation laws is well-established. See O.W. Holmes, The Path of the Law, 10 Harv. L. Rev. 457, 466-67 (1897) ("[s]ince the last words were written, I have seen the requirement of such insurance put forth as part of the programme of one of the best known labor organizations."). This was largely in response to the denial of employer indemnity in the majority of workplace accidents, due to the lack of proof of employer fault 1 or employer defenses such as contributory negligence, assumption of risk, and the fellow-servant rule. See Downey, History of Work Accident Indemnity in Iowa at 5, 17, 78. The prevailing view of labor was that: [a]n indemnity system which tediously grinds out such results as these is no better than a [**4] gamble -- a gamble which awards a few prizes to injured persons and deludes all other injured persons [*220] into thinking they are going to draw prizes, too, when, as a matter of fact, they are going to draw blanks; a gamble which makes the employer pay preposterous sums to certain people and so prevents him from paying reasonable sums to all. It is on the same level as faro. Id. at 80 (internal quotation marks omitted). See also P.V. Fishback & S.E. Kantor, A Prelude to the Welfare State: The Origins of Workers' Compensation, 11 (University of Chicago 2000) ("[r]eformers decried the common law system" for uncompensated injuries, "uncertain and unequal payouts," high transactional costs, and delay). By the early 1900s, President Theodore Roosevelt included "comprehensive workmen's compensation acts" within his progressive program for economic reform, the "Square Deal." T. Roosevelt, The New Nationalism (Aug. 31, 1910), in 13 The Annals of America 250, 253 (Encyclopedia Britannica, Inc. 1976). 1 For example, "[e]very mechanical employment has a predictable hazard: of a thousand men who climb to dizzy heights in erecting steel structures a certain number will fall to death, and of a thousand [**5] girls who feed metal strips into stamping machines a certain number will have their fingers crushed." E.H. Downey, History of Work Accident Indemnity in Iowa 5 (Benjamin F. Shambaugh, ed., State Historical Society of Iowa 1912). P5. The subsequent "advent of state workers' compensation laws after 1910 marked the removal from the tort system of most suits by injured workers against employers." Note, Exceptions to the Exclusive Remedy Requirements of Workers' Compensation Statutes, 96 Harv. L. Rev. 1641, 1641 (1983). In fact, "[b]etween 1911 and 1920, 41 states enacted workers' compensation statutes." Id. at 1641 n.1 (citing E.H. Downey, Workmens' Compensation, 162 n.18 (1924)). Initially, some courts deemed such statutes to be so radical as to constitute Page 7 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** an unconstitutional deprivation of the employer's property without due process of law. See Ives v. South Buffalo Ry., 201 N.Y. 271, 94 N.E. 431 (1911); J.C. Satterfield, An Introduction to the Mississippi Workmens' Compensation Act, 20 Miss. L.J. 27, 31 (1948) ("three of the four acts adopted prior to 1911 were declared unconstitutional . . ."). However, after their widespread acceptance had been established: Mississippi became the last [**6] state to adopt a system of Workmen's Compensation. This type of legislation is generally viewed as a compromise between the interest of labor and business. Because of the exclusive nature of the remedy labor surrenders the right to assert a common law tort action along with the attendant possibility of achieving punitive damages. In exchange it receives assurance that an award is forthcoming. Industry surrenders its three major common law defenses: contributory negligence, assumption of risk, and the fellow servant rule. In exchange it receives the knowledge that there will be no outrageously large judgments awarded to injured employees. 2 The entire system was designed to insure that those injured as a result of their employment would not be reduced to a penniless state and thereby become dependent on some form of governmental public assistance. Miller, 444 So. 2d at 370. See also Stevens v. FMC Corp., 515 So. 2d 928, 932 (Miss. 1987) (quoting Sawyer v. Head, 510 So. 2d 472, 477 (Miss. 1987)) ("[b]y the exchange, the remedy of workers' compensation benefits, insofar as the right of the employee [*221] against [the] employer and fellow employees are concerned, is abrogated."); John R. Bradley [**7] & Linda A. Thompson, Mississippi Workers' Compensation ? 1:1 (2007) ("[t]hus, compensation by the employer for most employment injuries has been taken out of the tort law and placed within a separate branch of law -- worker's compensation, a no-fault plan 3 handled in an administrative setting by an executive branch agency."). Ultimately, the workers' compensation system lends valuable predictability to both employees and employers. Employees receive guaranteed compensation for covered injuries, bypassing the civil-litigation risks of either no recovery or uncollectible judgments against insolvent employers. Employers receive fixed levels of potential liability which they can anticipate and treat as a general "cost of doing business." 2 The mutual benefit of the workers' compensation system in Mississippi was described as follows: both the employers and employees will be materially benefitted by this legislation. The psychological effect upon industries coming into Mississippi is good, and it appears that the employers on the average will reap a financial saving and the employees a financial benefit. On the whole the Act is fair and workable, and compares favorably with the statutes now [**8] in existence in the other states. Satterfield, An Introduction to the Mississippi Workmens' Compensation Act, 20 Miss. L.J. at 48. 3 These "no-fault" aspirations of the Act have been largely met, as statistics from 2007 reveal that more than seventy-eight percent of lost-time cases in Mississippi are uncontested. See Mississippi Workers' Compensation Commission, Annual Report Cumulative Information Tables, at http://www.mwcc.state.ms.us/info/_annreportcumu.asp ("Total Claims by Year") (last visited Sept. 1, 2009). P6. [HN1] Mississippi Code Section 71-3-9 provides, in part, that "[t]he liability of an employer to pay compensation shall be exclusive and in place of all other liability of such employer to the employee . . . ." Miss. Code Ann. ? 71-3-9 (Rev. 2000) (emphasis added). However, based upon the statutory requirement that the "injury" be "accidental" to be compensable under the Act, see Mississippi Code Sections 71-3-3(b), 71-3-7, this Court has found that some intentional torts are outside the scope of the exclusivity provision in Mississippi Code Section 71-3-9. Miss. Code Ann. ?? 71-3-3(b), 71-3-7 (Rev. 2000). See Royal Oil Co. v. Wells, 500 So. 2d 439, 442 (Miss. 1986) ("the [Act] [**9] does not bar an employee from pursuing a common law remedy against his employer for an injury caused by his employer's wilful and malicious act"); Miller, 444 So. 2d at 371 ("where an injury is caused by the willful act of an employee acting in the course and scope of his employment and in the furtherance of his employer's business, the [Act] is not the exclusive remedy available to the injured party") (emphasis added). This limitation on the Act's exclusivity "reflects the public policy that certain courses of conduct (intentional torts) are so shockingly outrageous and beyond the bounds of civilized conduct that the person responsible should not be rewarded with tort immunity." Bradley & Thompson, Mississippi Workers' Compensation at ? 11:8. P7. In Peaster v. David New Drilling Co., 642 So. 2d 344 (Miss. 1994), this Court held that [HN2] "[a] mere willful and malicious act remains insufficient to give rise to the exception under the Act." Id. at 348. See also Blailock v. O'Bannon, 795 So. 2d 533, 535 (Miss. 2001) ("[r]eckless or grossly negligent conduct is not Page 8 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** enough to remove a claim from the exclusivity of the Act."). The employee also must establish that the egregious act was accompanied [**10] by an "actual intent to injure" in order to except the Act's grant of exclusivity. See id.; Peaster, 642 So. 2d at 348-50; Griffin v. Futorian Corp., 533 So. 2d 461, 464 (Miss. 1988). Thus, Mississippi is in concurrence with an overwhelming majority of states in requiring an "actual intent to injure" the employee. See 6 Arthur Larson, Larson's Workers' Compensation Law ? 103.01 nn.4-6, ? 103.04[1] (2008). P8. Having set forth the law in existence at the time the subject events unfolded, we turn to the specific facts developed and stipulated in this case. [*222] FACTS P9. Franklin Corporation is a furniture manufacturer located in Houston, Mississippi. In January 1999, George Parker, an employee of Mid-South Adhesives, Inc. ("Mid-South"), made a presentation to Franklin Corporation regarding Mid-South's Soft Seam Adhesive ("Soft Seam") product. During the presentation, Parker provided Franklin Corporation with a May 22, 1998, "Material Safety Data Sheet" ("MSDS") 4 and warning label for Soft Seam. The MSDS disclosed that Soft Seam contained a neurotoxin known as propyl bromide ("1-BP") and included a "[m]anufacturer's recommended exposure limit" of no more than 100 parts per million ("ppm"). [**11] Under "Section VI - Health Hazard Data," the MSDS further declared that the product was an "[i]rritant to upper respiratory tract. Symptoms may include coughing, headache, nausea, dizziness, wheezing, laryngitis, shortness of breath and vomiting. These short term acute [e]ffects of exposure are noticed above 150 to 250 ppm." Regarding symptoms of exposure to the skin, the MSDS revealed a risk of "[i]rritation, defatting of skin, and dermatitis." Furthermore, "[p]rolonged exposure to [1-BP] can cause adverse effects to the liver, kidney, central nervous system and respiratory system." "Section VII - Precautions for Safe Handling and Use" included, "Warning! Vapors harmful! Use only with adequate ventilation!" "Section VIII - Control Measures" provided: [a]bove PEL/TLV ["permissible exposure limit/threshold limit value"], an approved organic vapor type respirator is acceptable. Approved self-contained breathing apparatus or air line respirator with full face piece, is required for vapor concentrations above 1000 ppm and for spills and emergencies. .... Do not use in confined space. Open doors and/or windows. Use ventilation to maintain employee exposure levels below the manufacturers [**12] recommended exposure limit. .... Avoid contact with skin and avoid breathing vapors. By June 30, 1999, and later, on July 31, 2002, the PEL/TLV in the MSDS for Soft Seam was reduced to "100 ppm." As stipulated by the parties, Franklin Corporation: was aware of the contents of the MSDS and warning label and the language relating to ventilation, 5 respiratory, skin and eye protection requirements for use of [Soft Seam] as well as the potential harmful effects to humans for prolonged, unprotected exposure to [1-BP] at levels that exceeded the applicable exposure levels. 4 According to John T. Gordon, a "Technical Director Chemist" responsible for creating the MSDS for Mid-South, "[t]he purpose of an MSDS sheet is to inform workers of hazardous chemicals in the workplace." 5 Parker discussed ventilation with Don Livingston, vice-president and director of purchasing at Franklin Corporation, who replied "it was going to be awfully expensive." Livingston denied this statement and testified that "Parker never told me that it needed ventilation." P10. The parties stipulated that Franklin Corporation had purchased and used Soft Seam "on its glue line in the production and manufacture of furniture[,]" [**13] beginning in 1999. According to Livingston, Soft Seam provided a significant cost savings to Franklin Corporation, as the glue line was reduced from three shifts to one shift. However, Franklin Corporation decided not to install mechanical ventilation [*223] exhausts outside the building on the glue line. 6 7 Page 9 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** 6 The building did have a downdraft system which exhausted air outside the booths in which glue-line employees worked, along with roof fans. 7 Linda Bean, a glue-line employee in 1999, testified that another glue-line employee had directly confronted Hassell Franklin, the president, CEO, and principal shareholder of Franklin Corporation, in the old building about the need for ventilation. She further testified that Franklin had responded that he was not going to spend any more money as they would be moving into the new building soon. P11. In September 2000, Franklin Corporation moved its poly department, including the glue line, into a new, 90,000-square-foot building. Although the facility had air conditioning, no mechanical ventilation was installed exhausting outside the building. 8 On February 7, 2001, Franklin Corporation temporarily ceased purchasing Soft Seam due to a change in its [**14] production methods. On April 10, 2001, an "Industrial Hygiene Evaluation" was performed by industrial hygienist Kevin C. Housman on behalf of Franklin Corporation's workers' compensation insurer, Liberty Mutual Insurance Company, addressing "noise reduction and hearing protection, wood dust exposure, and exposure to organic vapors including but not limited to [1-BP] on the glue line." The May 8, 2001, report issued by Housman notably found that: [m]ost exposures were either below our lab's quantifiable limits and/or below the corresponding TLVs, except for Ms. [Linda] Bean's exposure to [1-BP]. Her 8-hr TWA ["time-weighted average"] exposure was calculated to be 75 ppm. 9 This particular chemical has a manufacturer's recommended workplace exposure limit of 10 to 25 ppm. Thus, substitution of this gluing agent currently in use at the Polyfoam Plant is strongly encouraged. Ventilation of this process should be considered a secondary control and is also recommended. 10 (Emphasis added.) Scott Shempert, the safety director at Franklin Corporation at all relevant times, wrote a note on his copy of Housman's report providing "contacted [Livingston] 5-16-01[,] said he would look into it." No [**15] glue-line employees at Franklin Corporation were notified of the results reported or the recommendations provided in Housman's report concerning 1-BP. None of the ventilation or respiratory-protection recommendations in Housman's report were implemented by Franklin Corporation. 11 On January 30, 2002, Franklin [*224] Corporation resumed purchasing Soft Seam from Mid-South. On July 31, 2002, the MSDS for Soft Seam was revised to include an "EPA proposed acceptable exposure limit" of 25 ppm regarding 1-BP. 12 8 According to Frank Casteel, an electrician in the maintenance department at Franklin Corporation, John Lyles, the vice-president of manufacturing at Franklin Corporation at all relevant times, instructed him not to run electricity to the downdraft system in the new building. 9 Specifically, Housman measured 28 ppm over 161 minutes and 110 ppm over 216 minutes. 10 Other pertinent recommendations by Housman included the implementation of a respiratory protection program, the installation of a chemical review process regarding MSDSs, future air monitoring, and informing glue-line employees of the present exposure levels. 11 Shempert maintained that prior to July 31, 2002, the MSDS for Soft Seam [**16] provided that the "[m]anufacturer's recommended exposure limit" was 100 ppm, which was greater than the 75 ppm time-weighted average in Housman's report. On that basis, and despite Housman's reference to 10-25 ppm as the "manufacturer's recommended workplace exposure limit," Franklin Corporation consciously chose not to inform glue-line employees of the exposure risks associated with 1-BP or to implement the recommendations related to 1-BP included in Housman's report. 12 However, according to Gordon, the "EPA does not regulate the workplace." Shempert added that "the fact that it was a proposed acceptable exposure limit did not put it in place, in my opinion as the safety director [at Franklin Corporation]." On the other hand, the expert testimony of occupational toxicologist Gaku Ichihara, M.D., was that the EPA regulates 1-BP "because . . . [1-BP] is the alternative to the freon or other ozone-depleting solvents." P12. Regarding the Plaintiffs, their employment on the glue line began as follows: Tedford -- April 12, 1999; Haire -- September 16, 2002; Mixon -- September 15, 2003; and Smith -- October 22, 2003. Their wages varied between eight and nine dollars per hour. On the glue line, [**17] the Plaintiffs would use "a pressurized spray system to apply [Soft Seam] to foam used in the manufacture of furniture produced and sold by Franklin Page 10 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** Corporation." 13 In September 2003, new wooden spray booths for the glue-line employees were constructed. The new booths were draped in plastic and were primarily occupied by Plaintiffs Smith, Mixon, and Haire. 14 According to glue-line employee Vicki Veazey: when you was in those booths, . . . the scent was too strong because it could not escape. Naturally, if you had had ventilation or even the top was open, it would have been better . . ., but at the time the . . . booths had the little plastic tops across the top of them. 15 Shempert did not consider the installation of these new booths to be a manufacturing change, and thus did not request updated air testing on the glue line. 13 The parties stipulated that the Plaintiffs' entire exposure to 1-BP occurred at Franklin Corporation, while in the course and scope of their employment. 14 The booth in which Tedford worked was slightly larger and did not have a plastic cover over the top. 15 By Haire's description, "most of the vapors would come right back into you. It didn't have nowhere to go." P13. [**18] Throughout the Plaintiffs' employment, numerous glue-line employees testified to making repeated complaints to supervisors and upper management about the ill symptoms they were experiencing, the need for ventilation, and the need for protective gear. The adverse symptoms experienced by glue-line employees frequently were exacerbated when operating in the new booths. P14. The Plaintiffs testified that their complaints routinely were dismissed or ignored by supervisors and upper management. 16 Tedford testified that when she initially complained to James R. Clark, the superintendent of the poly department from January 1999 until September 2003, "he told me that it wasn't the glue. They had been using it for years." Later, Clark informed Tedford that Franklin Corporation was not "going to ventilate it because of the money." Mixon testified that Jeff Clements, the superintendent of the poly department beginning in September 2003, told her that ventilation "was too expensive. It would probably never happen." 17 [*225] When Tedford complained to Jimmy Pumphrey, a superintendent in the poly department, "[h]e just played it off. [He said] [t]here's nothing wrong with you. Go on back in your booth [**19] and go to work." 18 Casteel testified that when one employee complained to vice-president Lyles that the glue was "burning our hands and making us dizzy, . . . he just smiled and walked off." 16 For instance, according to Veazey, when she informed her supervisor that the glue was causing her headaches, she was simply told to take some Tylenol. 17 According to Smith, in response to her request for ventilation, Clements "looked at the ceiling, and he said, there's no way to put ventilation in here. He said that . . . it was too expensive and they couldn't afford it." Haire testified that Clements told her that "he had already asked and they told [him] that there was no money appropriated for it at the time." 18 Mixon and glue-line employees Jackie Davidson and Lynn Byars testified to similar responses from Pumphrey. According to Smith, Pumphrey would occasionally "laugh at us, saying y'all are high. I believe that glue has gone to y'all's head or something." Casteel heard Pumphrey tell one employee, "[e]ither do the job or go home." Smith further testified that Pumphrey's response to her request for ventilation was "[t]hat there will never be, and [he] walk[ed] away." P15. According to Clark: [**20] 19 I had complained to [Livingston] about the fumes and problems being reported by the workers in the glue line. 20 He stated at that time that he knew that Franklin [Corporation] needed to install a ventilation system on the glue line, but that he didn't believe that Hassell Franklin had decided to "let me put a hole in the ceiling" to install such a ventilation system. 21 When Clark informed Lyles of further complaints by glue-line employees, Lyles "told [him] that [he] was not doing a good enough job of convincing the Plaintiffs that their complaints were 'all in their heads' and that I had to be a 'better salesman' to convince the Plaintiffs that their complaints were not real." 22 Clark additionally provided that in a meeting with Franklin and Lyles, Franklin informed him: Page 11 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** that he "was not going to throw money at this problem." He said that no ventilation system would be installed as the company was not going to spend money on a glue line ventilation system for an adhesive that was probably not going to be allowed much longer anyway, and that it would be a waste of money . . . regardless of any complaints from the workers on the glue line. 23 Moreover, Clark testified that Franklin [**21] and Lyles had maintained that "we're not going to suck the air-conditioning out through holes in the ceiling." According to Clark, Franklin had referred to glue-line employees as performing a "grade two job" 24 and that "if they don't like it . . . they can go to work somewhere else." Furthermore, Clark testified that Lyles had stated "there are people lined up out there for jobs; if they start dropping like flies, or something in that order, we can replace them today . . . ." 19 This Court notes that Clark did not testify at trial. His testimony, derived from his November 2, 2004, affidavit and November 2, 2005, deposition, was, however, considered by the circuit court in ruling on Franklin Corporation's "Motion for Summary Judgment." This Court considers Clark's testimony only for purposes of assessing that ruling. See P 33 infra. 20 Livingston denied having knowledge of any employee complaints prior to January or February 2004. 21 Jim Tidwell, a supervisor at Franklin Corporation in 1999 and 2000, testified that he personally had observed Franklin discuss ventilation and then refuse its installation. 22 By contrast, Lyles asserted that he did not become aware of complaints by glue-line [**22] employees until mid-February 2004. 23 Franklin denied stating that he would not install ventilation because it was too expensive, and testified that he was unaware of any ventilation complaints prior to 2004. According to Franklin, when he learned of the problem, "we installed the ventilation system." 24 Clark stated that a "grade two job" means "the lowest level in the house, anybody can do it." [*226] P16. The Plaintiffs further assert that they were not provided with adequate protective gear. Smith testified that she asked Pumphrey for respiratory masks "[a]t least once a week[,]" but that "[t]hey just always said they would get it, and it never came." 25 Following a spill of approximately 330 gallons of Soft Seam in September 2000, Clark testified that he and Pumphrey were "instructed by . . . Lyles to clean up the spill with no ventilation, protective clothing or protective respiratory equipment." When Clark experienced dizziness and nausea, he claims that Lyles "told me to go outside and take a break, but do whatever it took to get it cleaned up." 25 According to Shempert, however, white paper dust masks manufactured by 3M were always available to glue-line employees. On this subject, Clements [**23] testified that glue-line employee Norma Pettit was the only employee from whom he had heard complaints. Thereafter, Clements stated that he gave her a face mask. P17. Following complaints of Tedford, after her review of the MSDS, Clark stated that Lyles directed Pumphrey "to keep all information away from employees . . . . In accordance with these instructions, all MSDS[s] were thereafter removed from the [Soft Seam] containers by [Pumphrey] . . . ." 26 Relatedly, numerous employees testified that the MSDSs were removed from the glue drums. 27 In one instance, when Smith asked Pumphrey where the MSDS was, "he said, there's not one." 26 An updated MSDS sheet was attached to the glue drum of every shipment of Soft Seam. 27 Conversely, Pumphrey testified that when glue-line employees began taking the MSDSs off the glue drums, "I started taking them off and putting them in the office." P18. On January 27, 2004, Smith was placed on medical leave by Franklin Corporation, and subsequently was admitted to the hospital on January 29, 2004. Smith reported symptoms to her treating physician, Dr. Kevin Merigian, of "numbness and tingling from waist to toes, nervous -- shakin[g], headache, dizziness, [**24] Page 12 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** nausea, vomiting -- cramping in toes, feet and . . . calf." On February 9, 2004, Haire was placed on medical leave by Franklin Corporation, and then was admitted to the hospital on February 12, 2004. Haire stated symptoms to Dr. Merigian of "stinging in feet and numbness from waist to my feet." On February 14, 2004, Mixon was admitted to the hospital after being placed on medical leave by Franklin Corporation that same day. Mixon reported symptoms to Dr. Merigian of "numbness in butt, lower back, legs, and feet; feels like they are asleep and tingling; vomiting; headaches; dizziness; trouble breathing." 28 On April 21, 2004, Tedford was placed on medical leave by Franklin Corporation, and thereafter received medical treatment on April 22, 2004. Tedford experienced symptoms of leg numbness, heaviness in her lower extremities, and difficulty walking. 29 28 On April 12, 2004, Mixon returned to Franklin Corporation and began working in the backfilling department, where she remained employed at the time of trial. 29 Nearly three years later, on March 17, 2007, Dr. S.H. Subramony, a board-certified neurologist, examined the Plaintiffs and found permanent residual neurological deficits causing [**25] continued motor difficulties in Tedford and "significant disability" in Haire and Smith. At trial, Dr. Merigian opined, to a reasonable degree of medical certainty, that the chances of Smith's condition improving were "quite poor" and that Haire's and Tedford's conditions "will not improve[.]" P19. On February 16, 2004, Franklin Corporation placed its final order for Soft Seam. That same day, Livingston informed [*227] Parker that several glue-line employees (specifically, Smith, Haire, and Mixon) had been hospitalized, and that further air testing was necessary. On February 17, 2004, Parker conducted an air-sampling test on the glue line at Franklin Corporation. This was only the second air test performed on the glue line in the five years since Franklin Corporation had begun using Soft Seam. According to Tedford, glue-line operations were slow that day. Parker's subsequent letter to Shempert and Livingston provided that "[v]enting the exhaust through the roof with mechanical air assisted motors is required to meet the 25 PPM standard in the work area." (Emphasis added.) On February 23, 2004, an industrial hygienist from the Occupational Safety and Health Administration (OSHA) arrived unannounced [**26] and tested the air quality on the glue line. Glue-line employees testified that glue-line operations were typical that day. The inspection report from OSHA, issued April 26, 2004, found time-weighted averages of 1-BP of 205 and 219 ppm. According to the report, 219 ppm "is 9 times the [MSDS] recommended level of 25 [ppm] and 43 times the target limit of 5 [ppm] recommended by OSHA Technical Center." 30 The report noted the absence of ventilation, respiratory protection for employees, or sufficient air testing performed by Franklin Corporation. 31 30 At the time of trial, OSHA had not yet set exposure limits for 1-BP. However, according to Gordon, the American Conference of Governmental Industrial Hygienists set the threshold value limit for exposure to 1-BP at 10 ppm in June 2004. 31 On April 27, 2004, OSHA issued a "Citation and Notification of Penalty" to Franklin Corporation. For the "serious" violation of excessive exposure of glue-line employees to 1-BP, OSHA proposed a $ 3,500 penalty. For the "serious" violation of the absence of employee "training on the hazards on the [S]oft [S]eam adhesive[,]" OSHA proposed a $ 1,125 penalty. On May 19, 2004, an "Informal Settlement Agreement" [**27] was reached between Franklin Corporation and OSHA whereby Franklin Corporation "agree[d] to correct the violations" and OSHA amended the penalties to $ 2,000 and $ 500, respectively. P20. On February 27, 2004, Franklin Corporation began purchasing a new glue containing acetone from Mid-South. On March 10, 2004, new ventilation booths were installed on the glue line at Franklin Corporation and were fully operable. Fabrication and installation of the new ventilation booths by Kline Heating and Air cost $ 11,165. Following installation of ventilation, glue-line employees were instructed on the nature and use of the acetone glue. P21. From February 16, 2004, until March 10, 2004, Franklin Corporation continued to use Soft Seam without providing additional ventilation or respiratory protection to glue-line employees, and without informing them of the overexposure reported by Parker. According to Shempert, "[m]y position as the corporate representative 32 would be that we would follow the OSHA regulations provided to us by these MSDS, and we did so." Shempert maintained that the absence of recommended exposure limits by OSHA weighed heavily in the decision not to ventilate. Shempert testified [**28] that: Page 13 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** OSHA is the governing body over which workers should be able to come in and have a safe workplace . . . . They don't have an exposure limit. The manufacturer sets 100 [ppm], so that's what I was going on as a secondary measure, but OSHA would take precedence over anything else in any of these. [*228] By contrast, industrial hygienist John Spencer testified: I can't think of [a plant] that was worse[,] to put . . . a group of individuals, into an enclosed area and spray a solvent day in and day out for hours upon hours . . . without any ventilation, without proper respiratory protection is not only [a] violation of a variety of occupational health standards; but it's just, it's difficult for me to explain why someone would do that, especially in light of the complaints that were coming from those individuals conducting that work. Spencer opined, "if they had followed [Housman's] recommendations and followed [Parker's] recommendations, they would have likely significantly reduced those exposures where it wouldn't have been a harmful level." 32 According to Livingston, however, the ultimate decision on ventilation would have been made by Franklin. P22. On August 16, 2004, a Complaint was filed [**29] in the Circuit Court of Calhoun County by the Plaintiffs, along with Clark, Sandra Darlene Clark, 33 Tommy Tedford, Harold E. Haire, and Joshua Mixon 34 against Franklin, Lyles, Livingston, Clements, Pumphrey, and John Does 1-10 ("Franklin Defendants"), 35 Franklin Corporation, and Mid-South. 36 The causes of action asserted in the Complaint included: breach of warranty, negligence, and negligence per se by Mid-South; misrepresentation, intentional misrepresentation, fraud, 37 and civil conspiracy 38 by Mid-South, Franklin Corporation, and the Franklin Defendants; battery by Franklin Corporation and the Franklin Defendants; and intentional infliction of emotional distress by Mid-South, Franklin Corporation, and the Franklin Defendants. The Complaint added that "the actions of Defendants are so egregious, willful, wanton and [*229] malicious in nature that punitive damages are requested . . . ." 33 On May 7, 2007, an "Order of Voluntary Dismissal" was entered by the circuit court as to "all of the claims plead[ed] by Plaintiffs, James R. Clark and Sandra Darlene Clark . . . against all of the Defendants . . . ." 34 Tommy Tedford, Harold E. Haire, Joshua Mixon, and Sandra Darlene Clark claimed [**30] losses of consortium. 35 On May 7, 2007, the Plaintiffs agreed to dismiss with prejudice the claims asserted against the individual Franklin Defendants. Per that agreement, "the individual defendants will execute affidavits, the form and content of which have been agreed to by counsel for the individual defendants and counsel for the plaintiffs." The affidavit of each "Franklin Defendant" provided: [a]t all relevant times plead [sic] in the Complaint for this civil action, and at all relevant times of my employment with Franklin Corporation to which I testified in my deposition, all of my acts and omissions, including my intentional acts and omissions, if any, were in the course and scope of my employment with Franklin Corporation as a management level employee, as a means to accomplish the purposes of my employment, and in furtherance of the business of Franklin Corporation. All of my actions and omissions, including my intentional acts and omissions, if any, were authorized and/or ratified by Franklin Corporation. (Emphasis added.) 36 The Second Amended Complaint, filed in the circuit court on January 26, 2007, added Locke Barkley, Bankruptcy Trustee for Pauline and Tommy Tedford, and [**31] Selene Maddox, Bankruptcy Trustee for James and Sandra Darlene Clark, as Plaintiffs. Based upon the May 7, 2007, "Order of Voluntary Dismissal," all claims of the Clarks, by and through Maddox, also were dismissed. 37 On May 25, 2007, the circuit court entered an "Agreed Order and Rule 54(b) Judgment of Dismissal with Prejudice as to Plaintiffs' Intentional/Fraudulent Misrepresentation Claims" against Franklin Corporation and Mid-South. 38 On May 22, 2007, the circuit court entered an "Agreed Order and Rule 54(b) Judgment of Dismissal with Prejudice as to Plaintiffs' Civil Conspiracy Claims" against Franklin Corporation and Mid-South. P23. On October 21, 2004, Franklin Corporation filed a "Motion to Dismiss," relying on the "exclusive remedy" provision of the Act, Mississippi Code Annotated Section 71-3-9 (Rev. 2000). At the hearing thereon, Circuit Judge Andrew K. Howorth conceded that "[t]his is a tough one." Ultimately, however, the motion was denied as Page 14 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** "the [c]ourt specifically finds that the Plaintiffs have alleged sufficient facts and causes of action, which under the relevant standard of review, satisfy the intentional tort exception to the application of [the Act]." Franklin Corporation [**32] subsequently filed a "Petition for Interlocutory Appeal and to Stay Enforcement of Circuit Court Order Pending Appeal" regarding the exclusivity of the Act, which the circuit court granted. This Court initially granted Franklin Corporation's "Petition for Interlocutory Appeal," but thereafter dismissed it as improvidently granted. P24. On May 19, 2006, Franklin Corporation filed a "Motion for Summary Judgment" in the circuit court, reiterating that the Plaintiffs' "exclusive remedies are pursuant to the [Act] . . . ." At that hearing, the circuit judge stated: while I'm not aware of any law on this, I think intent can be like scienter is in the law. . . . We know that in scienter you knew or should have known; and I think with intent you either intended it or you were possessed with sufficient facts where you could be deemed to have intended it even if you didn't intend the specific consequences . . . . That's just kind of my view of the thorniness of this thing. (Emphasis added.) On that basis, while deeming the matter to be "very close," the circuit judge denied the motion, finding there "are genuine issues of fact as to whether or not there was intent to injure." (Emphasis added.) P25. [**33] Following a three-week trial, the jury found in favor of the Plaintiffs on the claims of battery and intentional infliction of emotional distress against Franklin Corporation. The "Final Judgment" recited that "[t]he jury found in favor of [Mid-South] on the claim of negligence asserted against it by Plaintiffs." 39 All liability was attributed to Franklin Corporation, and compensatory damages were assessed, as follows: Mixon -- $ 75,000; Tedford -- $ 800,000; Smith -- $ 250,000; Haire -- $ 800,000. 40 39 Thereafter, a "Final Judgment" was entered by the circuit court dismissing the Plaintiffs' claims against Mid-South with prejudice. 40 The jury awarded no damages to Plaintiffs Tommy Tedford, Harold E. Haire, and Joshua Mixon on their loss-of-consortium claims. P26. The issue of punitive damages was then presented to the jury, which returned a verdict of $ 7,500,000 for the Plaintiffs against Franklin Corporation. The "Final Judgment" of the circuit court, "upon due consideration of the net worth and financial condition" of Franklin Corporation at the time the complaint was filed, concluded that the proper amount of punitive damages to be awarded was $ 1,836,213, pursuant to Mississippi Code Annotated Section 11-1-65(3)(a) [**34] (Rev. 2002). P27. Franklin Corporation subsequently filed a "Motion for J.N.O.V., or in the Alternative, for a New Trial or a Remittitur," and the Plaintiffs filed a "Motion to Reconsider Punitive Damages, to Alter or Amend Final Judgment, for Relief from Final Judgment, or for Other Relief." The Plaintiffs sought amendment of the "Final Judgment": [*230] by either: a) adjusting and amending that . . . punitive damages figure from $ 1,836,213 to $ 5,000,000 to comport and comply with Miss. Code Ann. Section 11-1-65 (Supp. 2003) by application of the statutory cap to the "net worth" figure of $ 61,543,082 for . . . Franklin Corporation, which was its "net worth" at the time of trial; or b) amending and adjusting the punitive damages . . . from $ 1,836,213 to the $ 7,500,000 punitive damages amount awarded by the verdict of the jury without statutory reduction if Miss. Code Ann. Section 11-1-65(3)(a-c) (Supp. 2003) is found to be void, unconstitutional and/or inapplicable. (Emphasis added.) Thereafter, the circuit court entered an "Order Granting Motion to Reconsider Punitive Damages, to Alter or Amend Final Judgment, for Relief from Final Judgment, or for Other Relief," finding that: the proper [**35] net worth of [Franklin Corporation] to be utilized in the application of the legislative caps is the current net worth . . . which is $ 61,543,082. This figure was the net worth of [Franklin Corporation] for the 2006 fiscal year, and was substantially the same at the time the jury rendered its verdict and at the time the court conducted its hearing on the Defendant's motion to reduce the punitive damages award . . . . (Emphasis added.) Pursuant to Mississippi Code Section 11-1-65(3)(a-b), the circuit court ordered that "the punitive damages awarded by the jury . . . are to be reduced to $ 5,000,000 and that the Final Judgment dated Page 15 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** May 31, 2007, be amended to reflect this adjustment." That same day, the circuit court entered an "Order Denying Franklin [Corporation's] Motion for J.N.O.V., or in the Alternative, for New Trial or Remittitur." On July 30, 2007, the "Amended Final Judgment" was entered in favor of the Plaintiffs and against Franklin Corporation in the total amount of $ 7,475,593.59, with post-judgment interest of 8.25 percent. From that ruling, Franklin Corporation filed a "Notice of Appeal," from which the circuit court entered an "Agreed Order for Stay Pending Appeal" [**36] as to enforcement of the "Amended Final Judgment." ISSUES P28. This Court will consider: (1) Whether the Act precludes the Plaintiffs' claims. (2) Whether the circuit court abused its discretion in admitting the expert testimony of Dr. Kevin Merigian, Dr. Jennifer Majersik, Dr. S.H. Subramony, and Dr. Gaku Ichihara. (3) Whether the circuit court's granting of certain jury instructions constituted reversible error. (4) Whether the circuit court abused its discretion in permitting the jury to consider punitive damages. (5) Whether the punitive damages assessed in the circuit court's "Amended Final Judgment" were erroneous as a matter of law. ANALYSIS I. Whether the Act precludes the Plaintiffs' claims. P29. [HN3] The applicability of the Act, Mississippi Code Section 71-3-1 through 71-3-225, is a question of law. This Court reviews questions of law de novo. See Miss. Ethics Comm'n v. Grisham, 957 So. 2d 997, 1000 (Miss. 2007) (quoting 32 Pit Bulldogs v. County of Prentiss, 808 So. 2d 971, 973 (Miss. 2002)). P30. Paragraphs three through six supra set out the historical background of the Act, along with our pertinent decisions addressing intentional-tort exceptions to the Act. In Miller, this Court found [**37] that [*231] [HN4] certain intentional torts are outside the scope of the exclusivity provision contained in Mississippi Code Section 71-3-9. See Miller, 444 So. 2d at 371 ("where an injury is caused by the willful act of an employee acting in the course and scope of his employment and in the furtherance of his employer's business, the [Act] is not the exclusive remedy available to the injured party") (emphasis added). See also Royal Oil, 500 So. 2d at 442 ("the [Act] does not bar an employee from pursuing a common law remedy against his employer for an injury caused by his employer's wilful and malicious act"). Mississippi law clearly provides that certain intentional torts lie beyond the scope of the Act's exclusivity. P31. However, in Peaster, we held that [HN5] "[a] mere willful and malicious act remains insufficient to give rise to the exception under the Act." Peaster, 642 So. 2d at 348. See also Blailock, 795 So. 2d at 535 ("[r]eckless or grossly negligent conduct is not enough to remove a claim from the exclusivity of the Act."). Before recovery may be had for the specific injuries and/or diseases which the Plaintiffs claim, there must be proof of actual intent to injure by Franklin Corporation. [**38] In Griffin, this Court stated: Dunn, Mississippi Workmen's Compensation, (3d ed. 1982 & Supp. 1984), notes that [HN6] in order for a willful tort to be outside the exclusivity of the Act, the employee's action must be done "with an actual intent to injure the employee. It is not enough to destroy the immunity that the employer's conduct leading to the injury consists of aggravated negligence or even that the conduct goes beyond this to include such elements as knowingly permitting hazardous conditions to exist or willfully failing to furnish a safe place to work or knowingly ordering the employee to perform a dangerous job. [Footnote omitted]." Id. at ? 22. Griffin, 533 So. 2d at 464 (emphasis added). After referencing the above-quoted portion of Griffin, this Court addressed the requisite level of "intent" in Peaster. See Peaster, 642 So. 2d at 347-49. Issue II therein succinctly placed before the Court the question of whether "this Court should recognize an exception to the exclusive liability provision where the employer has knowingly permitted hazardous conditions to exist which are substantially certain to result in injury or death." Id. at 348. According to this Court: Page 16 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** [t]he appellants [**39] urge this Court to "consider enlarging the scope of the intentional tort exception to include those acts which consist of the employer willfully permitting hazardous conditions to exist which are substantially certain, although perhaps not specifically intended, to result in the injury or death of an employee." .... There is nothing novel about the approach suggested by the appellants of enlarging the scope of the exemption test. We have stated consistently our position on this issue. The legislature has had every opportunity to include into the Act such a liberal exception suggested by the appellants, yet failed to do so. If this Court were to include what the legislature did not, we would violate the "purpose, spirit and philosophy of the [Act]." Brown v. Estess, 374 So. 2d 241, 242 (Miss. 1979). Peaster, 642 So. 2d at 348-49 (emphasis added). In conclusion, the Peaster Court held: [HN7] [t]he employer's conduct may have been reckless, negligent, or grossly negligent, but that [is] not enough to remove this case as an "intentional tort" from the exclusivity of the [Act]. This Court has held repeatedly that the employer's action [*232] must be done "with an actual intent to injure the employee," [**40] and that "an intentional tort is an act of intentional behavior designed to bring about the injury." We do not today choose to expand this Court's interpretation of what constitutes an intentional tort exception. 41 Id. at 349-50. This view repeatedly has been acknowledged by federal and state courts in Mississippi. See Bailey v. Lockheed Martin Corp., 432 F. Supp. 2d 665, 671 (S.D. Miss. 2005) (citing Peaster for the proposition that [HN8] "[t]o be deemed intentional, [the employer's] acts or inaction must be designed to bring about the injury."); Thornton v. W.E. Blain & Sons, Inc., 878 So. 2d 1082, 1086 (Miss. Ct. App. 2004) (citing Peaster for the proposition that this Court "already has declined to create a 'substantial certainty' exception to the exclusivity provision of the Act . . ."). We conclude, once again, that the Act is exclusive absent an actual intent to injure the employee. 41 This is in accord with the standard applied by the majority of states. Of the forty states which recognize an intentional-tort exception to their workers' compensation statutes, only twelve have adopted a broader definition than "actual intent to injure." See 6 Larson, Larson's Workers' Compensation Law ? 103.01 [**41] nn.4-6; ? 103.04[1]. "Under the most popular formulation, adopted by eight states, an employer is suable in tort if it knows that its conduct causing the injury is 'substantially certain' to cause injury or death." Id. at ? 103.04[1]. See also Bazley v. Tortorich, 397 So. 2d 475, 480 (La. 1981) (example of application of the "substantially certain" standard). P32. No party contests that the Plaintiffs' injuries "arose out of and in the course of employment . . . ." Miss. Code Ann. ? 71-3-3(b) (Rev. 2000). The circuit court was presented with the issue of whether the Act precluded the Plaintiffs' claims at three distinct stages of this proceeding: Franklin Corporation's "Motion to Dismiss," Franklin Corporation's "Motion for Summary Judgment," and Franklin Corporation's "Motion for J.N.O.V." At each stage, the circuit court rejected Franklin Corporation's contentions otherwise and denied the respective motions. Regarding the "Motion to Dismiss," the circuit court found "that the Plaintiffs have alleged sufficient facts and causes of action, which under the relevant standard of review, satisfy the intentional tort exception to the application of [the Act]." Taking the allegations set [**42] forth by the Plaintiffs as true, see Penn National Gaming, Inc. v. Ratliff, 954 So. 2d 427, 430 (Miss. 2007), this Court finds no error in that ruling. P33. As to the "Motion for Summary Judgment," based upon the collective "pleadings, depositions, answers to interrogatories and admissions on file, together with . . . affidavits," 42 Mississippi Rule of Civil Procedure 56(c), the circuit court concluded that there were "genuine issues of fact as to whether there was intent to injure[,]" with respect to the Plaintiffs' claims of battery and intentional infliction of emotional distress against Franklin Corporation. This Court finds no error in that ruling. 42 Including Clark's testimony from his November 2, 2004, affidavit and November 2, 2005, deposition. See footnote 19 supra. P34. Finally, regarding the "Motion for J.N.O.V.," the circuit court found "that during the course of the three week trial . . . there was substantial, credible evidence presented . . . to support the Plaintiffs' causes of action for battery and intentional infliction of emotional distress . . . ." Accordingly, the circuit court concluded that: [i]n considering the evidence in the light most favorable to the non-movant, [**43] giving that party the benefit of all favorable inferences that may be reasonably [*233] drawn from the evidence, and finding that the evidence was of Page 17 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** such quality and weight that reasonable and fair-minded jurors in the exercise of impartial judgment might have reached different verdicts, the court finds that Defendant Franklin [Corporation's] Motion for J.N.O.V. should be denied. Given the considerable testimony offered by employees and management personnel of Franklin Corporation, viewed "in the light most favorable to [the Plaintiffs], giving that party the benefit of all favorable inference that may be reasonably drawn from the evidence[,]" Spotlite Skating Rink, Inc. v. Barnes, 988 So. 2d 364, 368 (Miss. 2008) (citation omitted), this Court affirms the denial of J.N.O.V. given the "substantial evidence 43 to support the verdict." Adcock, 981 So. 2d at 948. 43 [HN9] "Substantial evidence" has been defined as "information of such quality and weight that reasonable and fair-minded jurors in the exercise of impartial judgment might have reached different conclusions." Adcock v. Miss. Transp. Comm'n, 981 So. 2d 942, 948-49 (Miss. 2008) (citation omitted). II. Whether the circuit court abused its discretion [**44] in admitting the expert testimony of Dr. Kevin Merigian, Dr. Jennifer Majersik, Dr. S.H. Subramony, and Dr. Gaku Ichihara. P35. This Court has stated that: [HN10] [u]nder Mississippi Rule of Evidence 702, trial courts are charged with being gatekeepers in evaluating the admissibility of expert testimony. [Irby v. Travis, 935 So. 2d 884, 912 (Miss. 2006)]. "We are confident that our learned trial judges can and will properly assume the role as gatekeeper on questions of admissibility of expert testimony." Miss. Transp. Comm'n v. McLemore, 863 So. 2d 31, 40 (Miss. 2003). Watts v. Radiator Specialty Co., 990 So. 2d 143, 146 (Miss. 2008). Accordingly, "[t]he trial judge has the sound discretion to admit or refuse expert testimony; an abuse of discretion standard means the judge's decision will stand unless the discretion he used is found to be arbitrary and clearly erroneous." Troupe v. McAuley, 955 So. 2d 848, 856 (Miss. 2007) (quoting Poole v. Avara, 908 So. 2d 716, 721 (Miss. 2005)) (emphasis added). See also Bonner v. ISP Tech., Inc., 259 F.3d 924, 932 (8th Cir. 2001) ("[w]e perform only the comparatively narrow analysis of whether the district court's determination that the opinion was sufficiently [**45] grounded in 'good science' to assist the jury constituted an abuse of that court's discretion."). P36. [HN11] Mississippi Rule of Evidence 702 states: [i]f scientific, 44 technical, or other specialized knowledge 45 will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education, may testify thereto in the form of an opinion or otherwise, if (1) the testimony is based upon sufficient facts or data, (2) the testimony is the product of reliable [*234] principles and methods, and (3) the witness has applied the principles and methods reliably to the facts of the case. Miss. R. Evid. 702. In short, [HN12] the trial judge must "ensure that an expert's testimony both rests on a reliable foundation and is relevant to the task at hand. Pertinent evidence based on scientifically valid principles will satisfy those demands." Daubert, 509 U.S. at 597. See also Watts, 990 So. 2d at 146 ("[t]his rule makes it necessary for a trial court to apply a two-pronged inquiry when evaluating the admissibility of expert testimony: (1) is the witness qualified, and (2) is the testimony relevant and reliable?"). [HN13] In Daubert, [**46] the United States Supreme Court: set out four non-exclusive factors to aid in the determination of whether the methodology is reliable. They are: (1) whether the theory or technique has been tested; (2) whether the theory or technique has been subjected to peer review and publication; (3) the known or potential rate of error of the method used and the existence and maintenance of standards controlling the technique's operation; and (4) whether the theory or method has been generally accepted by the scientific community. Curtis v. M&S Petroleum, Inc., 174 F. 3d 661, 668-69 (5th Cir. 1999) (quoting Daubert, 509 U.S. at 593-94). This approach is "a flexible one. Its overarching subject is the scientific validity -- and thus the evidentiary relevance and reliability -- of the principles that underlie a proposed submission. The focus, of course, must be solely on principles and methodology, not on the conclusions that they generate." Daubert, 509 U.S. at 594-95. Page 18 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** 44 [HN14] "'[S]cientific' implies a grounding in the methods and procedures of science." Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 590, 113 S. Ct. 2786, 2795, 125 L. Ed. 2d 469, 481 (1993). 45 [HN15] "Knowledge" applies to "'any body of known [**47] facts or to any body of ideas inferred from such facts or accepted as truth on good grounds.' Webster's Third New International Dictionary 1252 (1986). Of course, it would be unreasonable to conclude that the subject of scientific testimony must be 'known' to a certainty." Daubert, 509 U.S. at 590. Furthermore, "in order to qualify as 'scientific knowledge,' an inference or assertion must be derived by the scientific method." Id. P37. Dr. S.H. Subramony, Dr. Kevin Merigian, Dr. Gaku Ichihara, and Dr. Jennifer Majersik were among the Plaintiffs' designated experts. The deposition testimony of Dr. Subramony, a board-certified neurologist, was that after reviewing the Plaintiffs' medical records, along with pertinent literature on 1-BP, 46 "my interpretation of these four patients is that they had varying degrees of this same problem[,]" namely, residual neurological deficits from exposure to 1-BP. In offering this opinion, Dr. Subramony conceded that he was unaware of the exact concentration of 1-BP to which the Plaintiffs had been exposed. Nonetheless, Dr. Subramony averred that his conclusions and opinions "are supported by the overwhelming facts and the extensive data available on [**48] the effects of 1-BP on animals as well as humans, and were reached by using sound methods that are widely accepted in the medical and scientific community." 46 This literature included, most notably, the abstract to a case report by Dr. Majersik indicating that "[1-BP] is reportedly [harmful to humans at] about 25 [ppm]." Dr. Majersik's case report, co-authored by E. Martin Caravati, M.D., and John D. Steffens, M.D., was subsequently published as "Severe neurotoxicity associated with exposure to the solvent 1-bromopropane (n--propyl bromide)" in Clinical Toxicology 45 at 270-76 (2007). P38. The deposition testimony of Dr. Merigian, the treating physician for the Plaintiffs, was that their injuries were caused by exposure to 1-BP. 47 In rendering this opinion, Dr. Merigian admitted that he was unaware of the exact concentration of 1-BP to which the Plaintiffs were exposed or the precise exposure level at which 1-BP becomes harmful to humans. [*235] Nonetheless, Dr. Merigian based his conclusion upon his examination of the Plaintiffs, an internet search regarding 1-BP, 48 the "common finding" in tests run by other physicians on the Plaintiffs, his review of the Soft Seam MSDS, and the fact that [**49] "[t]hey all worked within a spray area that had been modified [in September 2003] and they were using a type of glue that is a known neurotoxin. And as [Franklin Corporation] manipulated the environment to prevent the glue from going onto other individuals within the factory itself, the symptoms and signs arose." As Dr. Merigian stated, "[t]he bottom line is it all fits together." He added that when he spoke with Shempert by phone, "[Shempert] . . . commented that the glue caused these issues but . . . he would not be responsible because he was ignorant to the fact that the glue would cause the problem." 47 This comports with the deposition testimony of Franklin Corporation's expert, Dr. George Wilkerson, that exposure to 1-BP was sufficient to, and did, cause the neurologic injuries suffered by Plaintiffs Tedford and Haire. 48 According to Dr. Merigian, "[t]here was a physician who had written some case reports or a case report about some exposures to [1-BP], and then there was a lot of animal data on rats with [1-BP]." Dr. Merigian later identified this case report as that authored by Dr. Majersik. See footnote 46 supra. P39. The deposition testimony of Dr. Ichihara, an occupational toxicologist [**50] and a leading expert on 1-BP toxicity, 49 was that "we . . . believe if exposure level is higher than some levels, . . . such overexposure to [1-BP] can cause neurological damage in humans even [if] we don't know the . . . very precise relationship of the dose response." He based this opinion upon case reports which he had both authored and reviewed. 50 While conceding that he had not examined the Plaintiffs and was not aware of the exact concentration of 1-BP to which they were exposed, Dr. Ichihara offered his opinion to a reasonable degree of medical and scientific probability that the Plaintiffs' symptoms and health problems were due to exposure to 1-BP. 51 Page 19 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** 49 According to the deposition testimony of Dr. Caravati, "it would be difficult to find anyone anywhere who would be more qualified to render" an expert opinion on the toxicity of 1-BP to humans than Dr. Ichihara. Even Franklin Corporation's expert, Dr. Robert Cox, stated that Dr. Ichihara "is one of the leading researchers that published on [1-BP]." 50 These include the case report entitled "Encephalomyeloradiculoneuropathy following exposure to an industrial solvent" by Gary Schlar in Clinical Neurology and Neurosurgery 101 at [**51] 199-202 (1999); Dr. Ichihara's own case report entitled "Neurological Disorders in Three Workers Exposed to 1-Bromopropane" in Journal of Occupational Health 44 at 1-7 (2002); and Dr. Majersik's case report. See footnote 46 supra. 51 He added that he had never seen a workplace using 1-BP for five years without any ventilation system. Dr. Caravati found the opinions of Dr. Ichihara to be "based upon sufficient data and facts[,]" the byproduct "of reliable principles and methods that are acceptable and utilized in the community of expert toxicologists[,]" and the result of "correctly appl[ying] the pertinent principles and methods to the relevant facts and data . . . ." P40. The deposition testimony of Dr. Majersik, a board-certified neurologist, was that few studies have been done on the effect of 1-BP on humans. Based upon her case report, "[w]e know that my patients had neurologic damage at . . . [108 ppm]. . . . We don't know how long it takes, . . . how many weeks, months, days, hours of exposure it takes. All we have are discrete points in time to say somebody had this problem . . . ." 52 52 As Dr. Majersik stated, the underlying problem in determining the precise lower level of 1-BP [**52] exposure which causes neurologic damage in humans is that a physician cannot ethically "put a bunch of people in a room . . . expose them to glue and see what happens as a case series." P41. Franklin Corporation subsequently filed or joined motions in limine to [*236] conduct a Daubert hearing, seeking to exclude the expert opinion testimony of Dr. Subramony, Dr. Merigian, 53 Dr. Ichihara, and Dr. Majersik. The Plaintiffs responded that "[a]t the core of the Defendants' motions, the Defendants invite the [c]ourt to ignore the sworn testimony of experts in their respective fields, and they seek to have the [c]ourt journey down the road of 'microanalysis' of each expert's opinions." Following hearing, the circuit court denied Franklin Corporation's Daubert motions as to each physician. Regarding Dr. Ichihara, the circuit judge stated "that is the one that is not hard for me . . . . [I]t's logical to[ward] that the jury understands that this stuff is dangerous and, . . . so, yes. I think it has a value. I think that this testimony is . . . going to assist the jury, finder of fact." As to Dr. Subramony, Dr. Merigian, and Dr. Majersik: the [c]ourt is going to make a provisional ruling here today [**53] so that the parties can go forward and that will be the [c]ourt will accept them as tendered in their fields of expertise and that they meet the Daubert criteria for expert testimony assisting the trier of fact. Specifically, including that they are qualified in their fields. That their opinions are helpful to the jury and the opinions that they render are relevant and that their opinions are based upon reliable methodologies. I think this is a field with limited reliable methodology . . . . I reserve the right to change my mind but that is the ruling here today and that is the one I would ask that you rely on in proceeding hence forth. (Emphasis added.) 53 Franklin Corporation's motions with respect to Dr. Subramony and Dr. Merigian specifically stated that their opinions on causation were "offered despite [their] inability to state: (1) what level of exposure to [1-BP] is needed to cause neurologic injuries in humans; and (2) what levels of exposure the Plaintiffs experienced." The affidavit and testimony of Dr. Robert Cox, a board-certified physician in medical toxicology and emergency medicine, was offered by Franklin Corporation to support this criticism. In response, the Plaintiffs [**54] offered the deposition testimony of Dr. Caravati, whom Dr. Cox acknowledged to be an expert in the field of toxicology, providing "[i]t is my opinion that Dr. Merigian's opinions that he initially formulated as a treating physician with a toxicological background were based upon sufficient data and facts to enable Dr. Merigian to render his opinions." P42. At trial, each physician was tendered and accepted in his or her respective field of expertise without objection. 54 Based upon her education and expertise, her review of the Plaintiffs' medical records, her research on the subject of 1-BP toxicity, and her case report, 55 Dr. Majersik opined "that the levels at which these [P]laintiffs were exposed was sufficient to cause the neurologic damage as I read about the damage from the physicians' reports." While admitting that the lower level of harmful exposure to 1-BP has not yet been discovered, she stated that "it seems that the exposure levels and the conditions the patients had is adequate for my expert opinion." Dr. Subramony testified that: Page 20 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** I concluded that their history of exposure was causative because they all had [*237] a very similar story. They all had similar findings on neurological [**55] examination, and they all were getting better after the exposure was removed, and none of the laboratory studies and brain scan studies . . . done by other people had revealed any other cause for this. Although Dr. Subramony conceded that he did not know the Plaintiffs' level of exposure to 1-BP, his opinion, to a reasonable degree of medical probability, was that their exposure level was injury-causing, based upon "temporal association" and research reflecting that exposure to 1-BP can cause neurologic injury. At trial, Dr. Merigian acknowledged that he did not know the lower level of exposure to 1-BP that causes neurologic injury to humans, but he reiterated his opinion, to a reasonable degree of medical probability, that 1-BP caused the Plaintiffs' injuries. 56 54 Dr. Subramony was tendered and accepted as an expert in the field of neurology. Dr. Merigian was tendered and accepted as an expert "in the field of general practice and as a treating physician of the [P]laintiffs in this case." Dr. Majersik was tendered and accepted as an expert "in the field of neurology and clinical findings associated with the [1-BP] toxicity and neurological injury." 55 According to Majersik, based upon [**56] the OSHA report, the Plaintiffs experienced "about twice the exposure level" of Majersik's case-report patients. Moreover, the patients in her case report exhibited "very similar" symptoms to the Plaintiffs. 56 According to Dr. Merigian, the results of the air testing at Franklin Corporation "helped solidify" his opinions. P43. On appeal, Franklin Corporation argues that "[e]ach of the Plaintiffs' four experts exhibits a fatal flaw. None knew of the [1-BP] exposure level at which injury occurs in humans . . . . None knew of the exposure experienced by the particular Plaintiffs." As such, Franklin Corporation contends that their "testimony does not meet the requirements of admissibility of expert testimony under M.R.E. 702." P44. At trial, Franklin Corporation did not object to the tender of Dr. Subramony, Dr. Merigian, Dr. Ichihara, and Dr. Majersik as experts, or to their actual testimony. Therefore, this Court will limit its analysis to the circuit court's denial of Franklin Corporation's Daubert motions as to each physician. [HN16] Only if the circuit judge abused his discretion in so ruling, acting in an "arbitrary and clearly erroneous" manner, will this Court find error. See Troupe, 955 So. 2d at 856. P45. [**57] The neurological impact of 1-BP on humans is a relatively new field of study. As the circuit judge stated, "this is a field with limited reliable methodology . . . ." Furthermore, as Dr. Majersik noted, determining the exact lower level of 1-BP exposure which causes neurologic injury in humans is challenging, given appropriate, ethical constraints. At best, nondefinitive determinations have been rendered via relevant case reports, 57 MSDSs, 58 and organizational recommendations. This Court finds such sources to be sufficient. "[I]t would be unreasonable to conclude that the subject of scientific testimony must be 'known' to a certainty." Daubert, 509 U.S. at 590. "[T]he first several victims of a new toxic tort should not be barred from having their day in court simply because the medical literature, which will eventually show the connection between the victims' condition and the toxic substance, has not yet been completed." Bonner, 259 F. 3d at 928 (quoting Turner v. Iowa Fire Equip. Co., 229 F. 3d 1202, 1208-09 (8th Cir. 2000)). Similarly, this Court finds that the absence of data on the exact exposure level at which humans suffer neurologic injury ought not preclude the Plaintiffs' [**58] experts from testifying, when combined with Franklin Corporation's [*238] stipulation that 1-BP is a neurotoxin which can cause neurologic injury to humans and the testimony of its expert, Dr. George Wilkerson, that exposure to 1-BP caused the neurologic injuries suffered by Plaintiffs Tedford and Haire (despite not knowing the exact level at which 1-BP causes injury in humans). 57 [HN17] "While case-study review is certainly an accepted methodology, trial courts still must be certain that the content of those case studies is relevant to the facts at hand." Watts, 990 So. 2d at 146 (emphasis added). 58 As the expert in Curtis noted, "the MSDS is a valid and accurate portrayal of the hazards . . . because [MSDSs] are prepared to have all of the information regarding health and environmental hazards, and because the manufacturer is required to research the best, peer-reviewed scientific literature to form these [MSDSs]." Curtis, 174 F. 3d at 669. Page 21 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** P46. The collective case reports, MSDSs, and organizational recommendations, paired with the direct and circumstantial evidence in the case sub judice, support a causal connection between the Plaintiffs' exposure to 1-BP and their injuries. See Curtis, 174 F. 3d at 670 [**59] ("[i]n the present case, both scientific literature and strong circumstantial evidence support the causal connection."). " [HN18] Under some circumstances, a strong temporal connection is powerful evidence of causation." Bonner, 259 F. 3d at 931. Causal connection is further validated by the results of the air testing performed by Housman, Parker, and OSHA. These tests established that the Plaintiffs were "exposed to a quantity of the toxin that 'exceeded safe levels.'" Id. (quoting Bednar v. Bassett Furniture Mfg. Co., 147 F. 3d 737, 740 (8th Cir. 1998)). As such, this Court finds that there was sufficient "'evidence from which a reasonable person could conclude' that [the Plaintiffs'] exposure probably caused [their] injuries." Id. at 928. Accordingly, we find no abuse of discretion by the circuit judge in admitting the expert testimony of Dr. Subramony, Dr. Merigian, Dr. Ichihara, and Dr. Majersik, as their qualifications were not legitimately questioned, and their testimony was sufficiently relevant and reliable. See Watts, 990 So. 2d at 146. III. Whether the circuit court's granting of certain jury instructions constituted reversible error. P47. On appeal, Franklin Corporation argues that [**60] Instructions P-2, P-3, and P-4A, considered as a whole, incorrectly state the law and exist in "substantial conflict" with Instruction D1-2, thereby requiring reversal. Instruction D1-2 states: [t]he Court instructs the Jury that in order to recover on their claims against Defendant Franklin Corporation, the Plaintiffs have the burden of proving by a preponderance of the credible evidence that Franklin knowingly exposed the Plaintiffs to unreasonably dangerous levels of the industrial solvent which contained [1-BP] with an actual intent to cause them injury. It is not enough for the Plaintiffs to prove that Defendant Franklin negligently or even knowingly permitted hazardous conditions to exist, or that it negligently or even willfully failed to furnish the Plaintiffs with a safe place to work, or that it knowingly ordered the Plaintiffs to perform a dangerous job. If, and only if, you find from a preponderance of the credible evidence that Defendant Franklin engaged in conduct designed to cause the injuries for which the Plaintiffs claim damages, may you find for the Plaintiffs. If you find by a preponderance of the credible evidence that the Plaintiffs have failed to prove that Defendant [**61] Franklin knowingly exposed them to unreasonably dangerous levels of the industrial solvent which contained [1-BP] with an actual intent to cause them injury, then it is your sworn duty to return a verdict for Defendant Franklin Corporation on each of the Plaintiffs' claims. Instruction P-2 provides, in part, that: [i]n order to establish that an intentional tort was committed by Defendant, Franklin Corporation, Plaintiffs must prove that, more likely than not, Defendant, Franklin Corporation either desired to cause the consequences of its acts, or believed that the consequences were substantially certain to result from [*239] it. Said another way, if Franklin Corp. knew that the consequences were certain, or substantially certain, to result from its acts, and still goes ahead, Franklin Corp. is treated by the law as if it had in fact desired to produce the result. Instruction P-3 states: [t]he Court instructs you that with regard to the intentional torts alleged by Plaintiffs against Defendant Franklin Corp., battery and intentional infliction of emotional distress, intent may be inferred from the circumstances of the case. Intent is an emotional operation of the mind, and is usually shown by [**62] acts and declarations of the defendant coupled with facts and circumstances surrounding him at the time. A defendant's intention is manifested largely by the things he does. Instruction P-4A regarding battery provides, in part, that: if you find by a preponderance of the evidence that Franklin Corp. intended that the Plaintiffs used the glue containing [1-BP], and that Defendant Franklin Corporation knew that Plaintiffs would inhale the vapors/fumes and that such inhalation was known to Franklin Corporation to be causing physical harm to the Plaintiffs, and/or substantially certain to cause physical harm to the Plaintiffs, and that such harmful or offensive contact with the glue vapors/fumes occurred, and that such harmful or offensive contact caused or contributed to cause injury to the Plaintiffs, then it is your duty to return a verdict in favor of the Plaintiffs and against Franklin Corp. P48. [HN19] In reviewing the grant or denial of jury instructions, this Court has stated that: we are required to review all of the instructions as a whole. Richardson v. Norfolk & Southern Ry., 923 So. 2d 1002, 1010 (Miss. 2006). No instruction should be reviewed in isolation. Burr v. Miss. Baptist Medical Ctr., 909 So. 2d 721, 726 (Miss. 2005). [**63] When analyzing the grant or refusal of a jury instruction, two questions should be asked: Does the instruction contain a correct statement of law and is the instruction warranted by the evidence? Hill v. Dunaway, 487 So. 2d 807, 809 (Miss. 1986). Defects in specific instructions will not mandate reversal when all of the instructions, taken as a whole fairly -- although not perfectly -- announce the applicable primary rules of law. Burton v. Barnett, 615 So. 2d Page 22 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** 580, 583 (Miss. 1993). The above standards notwithstanding, this Court will not hesitate to reverse if the instructions, when analyzed in the aggregate, do not fairly and adequately instruct the jury. Richardson, 923 So. 2d at 1011. Beverly Enters. v. Reed, 961 So. 2d 40, 43 (Miss. 2007). P49. We find that the conflict between Instruction D1-2 and Instructions P-2 and P-4A does not rise to the level of reversible error when read in conjunction with the other instructions. Without doubt, the references to "substantially certain" in Instructions P-2 and P-4 were erroneous. [HN20] The Act is exclusive absent an actual intent to injure the employee. See P 31 supra. However, that phrase was not presented to the jury in isolation, for [**64] they also received Instructions D1-2, P-3, and the special interrogatory (Instruction P-10a). P50. Franklin Corporation's Instruction D1-2 includes the appropriate standard. Had that standard not been furnished to the jury, the outcome which we reach likely would be different. However, as this Court stated in Lamar Hardwood Co. v. Case, 143 Miss. 277, 107 So. 868 (1926), "[w]e think the law as given to the [*240] defendant upon this proposition gives him the benefit of all that he was entitled to have upon the question." Id. at 289. P51. Instruction P-2, read in its entirety, is a correct statement of the law but for the reference to "substantially certain." Instruction P-3 is a proper statement of law without flaw. 59 Finally, a special interrogatory (Instruction P-10a) confirmed that the jury specifically found for each individual Plaintiff on his or her battery and intentional-infliction-of-emotional-distress claims against Franklin Corporation, while exonerating Mid-South. 59 Regarding Instruction P-3, Franklin Corporation objected to the language that "intent may be inferred from the circumstances of the case." The circuit judge overruled that objection, deeming the above-quoted language [**65] to be a correct statement of the law. This Court agrees. See Miss. Bd. of Nursing v. Wilson, 624 So. 2d 485, 494 (Miss. 1993) (citing Hollingsworth v. State, 392 So. 2d 515 (Miss. 1981)) ( [HN21] "[i]t is well settled that intent may be shown by circumstances."). P52. [HN22] The law requires all instructions to be read together. See id. at 290 ("the instructions must be taken together and be construed as a whole, one as modifying, explaining or qualifying another; and, if the instructions taken as a whole correctly announce the law applicable to the case, we will not reverse the judgment because of an imperfect single instruction."). "Where it may be fairly charged that one or more instructions may have been confusingly worded, we should not reverse if other instructions clear up the confusing points." Payne v. Rain Forest Nurseries, Inc., 540 So. 2d 35, 40 (Miss. 1989). "Defects in specific instructions do not require reversal 'where all instructions taken as a whole fairly -- although not perfectly -announce the applicable primary rules of law.'" Burton, 615 So. 2d at 583 (quoting Payne, 540 So. 2d at 40). P53. We also have held that [HN23] a conflict between instructions does not justify reversal, given [**66] that the evidence overwhelmingly supported the Plaintiffs' claims and does not result in a miscarriage of justice. See Smith v. Mack Trucks, Inc., 819 So. 2d 1258, 1261 (Miss. 2002); Smith v. Jones, 335 So. 2d 896, 897 (Miss. 1976). In short, "[t]he conflict in the evidence made the jury the judges of what the truth was with reference thereto, and we are unable to say that the jury reached the wrong result." Case, 143 Miss. at 289. IV. Whether the circuit court abused its discretion in permitting the jury to consider punitive damages. P54. " [HN24] [T]he primary purpose of punitive damages is to punish the wrongdoer and deter similar misconduct in the future by the defendant and others . . . ." Miss. Code Ann. ? 11-1-65(1)(e) (Rev. 2002). "Punitive damages may not be awarded if the claimant does not prove by clear and convincing evidence that the defendant against whom punitive damages are sought acted with actual malice, gross negligence which evidences a willful, wanton or reckless disregard for the safety of others, or committed actual fraud." Miss. Code Ann. ? 11-1-65(1)(a) (Rev. 2002) (emphasis added). See also Paracelsus Health Care Corp. v. Willard, 754 So. 2d 437, 442 (Miss. 1999) (citation [**67] omitted) ("[p]unitive damages are only appropriate in the most egregious cases so as to discourage similar conduct and should only be awarded in cases where the actions are extreme."). "[T]he trial court is the gatekeeper for the issue of whether punitive damages, in cases involving both intentional [*241] and non-intentional torts, should be submitted and considered by a jury." Doe v. The Salvation Army, 835 So. 2d 76, 79 (Miss. 2003). " [HN25] An abuse of discretion standard is implemented when this Court reviews the trial court's decision of whether a case warrants punitive damages to be sent to the Page 23 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** trier of fact." Id. at 81 (citing Hurst v. Sw. Miss. Legal Servs. Corp., 708 So. 2d 1347, 1351 (Miss. 1998)) (emphasis added). P55. According to the circuit judge: [t]here's no question that the matters submitted in this [c]ourt's opinion, submitted to the jury as to the burden of proof required in this case for the showing required to avoid . . . the exclusive remedy of Workers' Comp is, in fact, higher than the standard called for in the statute for punitive damages. There's no good resolution of that, but we just have to act the best we can based on the information we do have. The [c]ourt finds that [**68] in consideration of all the proof that has . . . gone into evidence over the last three weeks that . . . the jury . . . did make an award of compensatory damages; and it was more than a nominal amount of money; and the [c]ourt believes, based on the proof offered here at this hearing, that it's absolutely appropriate that the jury consider the question of punitive damages . . . . (Emphasis added.) In short, the circuit judge found there was sufficient evidence to meet the "clear and convincing" standard required for punitive damages. We find that the circuit court did not abuse its discretion in permitting the jury to consider punitive damages. V. Whether the punitive damages assessed in the circuit court's "Amended Final Judgment" were erroneous as a matter of law. P56. [HN26] The proper assessment of punitive damages under Mississippi Code Section 11-1-65(3) is a question of law, to be reviewed by this Court de novo. See Grisham, 957 So. 2d at 1000. P57. For all actions filed before September 1, 2004, 60 [HN27] Mississippi Code Section 11-1-65(3) provided, in pertinent part, that: (a) In any civil action where an entitlement to punitive damages shall have been established under applicable laws, no [**69] award of punitive damages shall exceed the following: . . . (v) Five Million Dollars ($ 5,000,000.00) 61 for a defendant with a net worth of more than Fifty Million Dollars ($ 50,000,000.00) but not more than One Hundred Million Dollars ($ 100,000,000.00); or (vi) Four percent (4%) 62 of the defendant's net worth for a defendant with a net worth of Fifty Million Dollars ($ 50,000,000.00) or less. (b) For the purposes of determining the defendant's net worth in paragraph (a), the amount of the net worth shall be determined in accordance with Generally Accepted Accounting Principles. Miss. Code Ann. ? 11-1-65(3) (Rev. 2002). 60 The Complaint in the case sub judice was filed on August 16, 2004. 61 On and after September 1, 2004, this figure became $ 2,500,000. Miss. Code Ann. ? 11-1-65(3)(a)(v) (Rev. 2002). 62 On and after September 1, 2004, this figure became two percent (2%). Miss. Code Ann. ? 11-1-65(3)(a)(vi) (Rev. 2002). P58. Jeffrey Cox, the chief financial officer and general counsel for Franklin Corporation, testified that the net worth of [*242] Franklin Corporation was $ 45,905,326 in 2003 and $ 37,810,166 in 2004. According to Cox, as of December 31, 2006, the net worth of Franklin Corporation [**70] was "approximately [ $ 61,500,000]." He did not believe that figure was substantially different at the time of trial, and further testified that "Generally Accepted Accounting Principles" were applied in determining that figure. In the "Order Granting Motion to Reconsider Punitive Damages, to Alter or Amend Final Judgment, for Relief from Final Judgment, or for Other Relief," the circuit court stated: the language of Miss. Code Ann. Section 11-1-65 which relates to the imposition of the legislative caps to a punitive damage award provides that the net worth of the defendant "shall be determined" in accordance with Generally Accepted Accounting Principles, and that such language implies that the current net worth of the defendant is to be considered. Further, other portions of the statute refer to the net worth of the defendant as a factor to be considered in an effort to determine the defendant's financial ability to pay the award, and likewise implies that the current net worth of the de- Page 24 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** fendant is to be utilized . . . . Further, there is no language in the statute which provides that the past net worth of the defendant is to be utilized, and without such distinguishing language, this [**71] court must apply the common meaning of the term "net worth," as well as the common interpretation as afforded by a reading of the statute as a whole. 63 (Emphasis added.) Applying "the current net worth" of Franklin Corporation, the circuit court reduced the punitive damages owed to $ 5,000,000 pursuant to Mississippi Code Section 11-1-65(3)(a)(v). 63 The circuit judge added that this application furthers the policy behind the imposition of punitive damages, "result[ing] in financial punishment to the defendant in an amount that makes the defendant earnestly consider its actions in the future." P59. This Court previously has considered the net worth of a defendant at the time of trial. See Willard, 754 So. 2d at 445. See also Cash v. Beltmann North American Co., 900 F.2d 109, 111 n.3 (7th Cir. 1990) ("[f]inancial data prepared for income tax purposes and four years old at the time of trial provides weak evidence of Beltmann's true net worth."). Furthermore, "the primary purpose of punitive damages is to punish the wrongdoer and deter similar misconduct in the future by the defendant . . . ." Miss. Code Ann. ? 11-1-65(1)(e) (Rev. 2002). As such, the circuit court's application of the pre-September [**72] 2004 version of the statute and Franklin Corporation's net worth at the time of judgment was proper. CONCLUSION P60. Accordingly, this Court affirms the "Amended Final Judgment" of the Circuit Court of Calhoun County. P61. AFFIRMED. WALLER, C.J., CARLSON AND GRAVES, P.JJ., DICKINSON, LAMAR, KITCHENS, CHANDLER AND PIERCE, JJ., CONCUR. GRAVES, P.J., SPECIALLY CONCURS WITH SEPARATE WRITTEN OPINION. DICKINSON, J., SPECIALLY CONCURS WITH SEPARATE WRITTEN OPINION JOINED BY WALLER, C.J., CARLSON, P.J., RANDOLPH, LAMAR, AND PIERCE, JJ. CONCUR BY: GRAVES; DICKINSON CONCUR GRAVES, PRESIDING JUSTICE, SPECIALLY CONCURRING: P62. I fully concur with the majority that the judgment of the trial court must be affirmed. However, I write separately [*243] to address the use of the phrase "substantially certain" in the jury instructions. P63. The majority finds that the references to "substantially certain" in Instructions P-2 and P-4 were in error. 64 I disagree with the majority inasmuch as the instructions contain a correct statement of the law. The majority cites Peaster v. David New Drilling Co., 642 So. 2d 344 (Miss. 1994), Blailock v. O'Bannon, 795 So. 2d 533, at 535 (Miss. 2001), and Griffin v. Futorian Corp., 533 So. 2d 461 (Miss. 1988), [**73] in attempting to define "actual intent." However, these cases neither stand for nor support the proposition suggested by the majority. In Peaster, this Court found: In the complaint it was alleged that David New Drilling "willfully" disregarded its duties to Jimmy Wilcoxson, "intentionally" failed to repair the brakes on the tractors and trailers, acted with "gross and reckless disregard for the rights and safety of the public in general and particularly of Plaintiffs' decedent" and with "knowledge of substantial certainty of injury." Despite these allegations, the overwhelming language and facts point to negligence, including gross negligence. Peaster, 642 So. 2d at 346 (emphasis added). 64 Even so, the majority ultimately finds any error to be harmless. P64. Clearly, the upshot of the Peaster decision was that this Court found that Plaintiff Peaster had failed to prove the allegations, which included "knowledge of substantial certainty of injury," and thus had failed to Page 25 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** establish "actual intent." There was no discussion or finding in Peaster to support the proposition that the "actual intent" exception cannot and does not include "knowledge of substantial certainty of injury." Moreover, [**74] the majority's discussion of Griffin likewise fails to support this proposition. In Peaster, this Court quoted the following from Griffin: Dunn, Mississippi Workmen's Compensation, (3d ed. 1982 & Supp. 1984), notes that in order for a willful tort to be outside the exclusivity of the Act, the employee's [sic] action must be done "with an actual intent to injure the employee. It is not enough to destroy the immunity that the employer's conduct leading to the injury consists of aggravated negligence or even that the conduct goes beyond this to include such elements as knowingly permitting hazardous conditions to exist or willfully failing to furnish a safe place to work or knowingly ordering the employee to perform a dangerous job." Peaster, 642 So. 2d at 347 (quoting Griffin, 533 So. 2d at 464). This Court further said: Griffin [sic] absolutely bars an intentional tort claim even where the probability of gross negligence exists. Thus, in the case sub judice, even if the appellants could prove that David New Drilling was guilty of gross negligence, such a finding would remain insufficient to create an intentional tort and accordingly remove the appellants' claim from under the Workmens' [**75] [sic] Compensation Act. A mere willful and malicious act remains insufficient to give rise to the exception under the Act. Id. at 348. P65. Notably, in discussing Peaster's assertion that this Court recognize a substantially-certain exception and apply the Restatement definition of intent, this Court found that: What the appellants propose is not particularly new or inconsistent with the previous decisions of this Court. As noted, this Court has previously [*244] considered the Restatement's interpretation of intent. The problem is that the allegations of the complaint and all evidence before the lower court fall far short of the substantial certainty which is required. Id. at 349 (emphasis added). P66. Further, Black's Law Dictionary defines "intentionally" as follows, in relevant part: "To do something purposely, and not accidentally . . . . Person acts 'intentionally' if he desires to cause consequences of his act or he believes consequences are substantially certain to result . . . ." Black's Law Dictionary 810 (6th ed. 1990) (citation omitted) (emphasis added). Black's defines "actual" as: "Real; substantial; existing presently in fact; having a valid objective existence as opposed to that [**76] which is merely theoretical or possible . . . ." Black's Law Dictionary at 34 (emphasis added). Black's also notes the following in the definition of "intent": "The word 'intent' is used throughout the Restatement of Torts, 2nd, to denote that the actor desires to cause consequences of his act, or that he believes that the consequences are substantially certain to result from it . . . ." Black's Law Dictionary at 810 (emphasis added). P67. Therefore, I would find that there is no error in including substantially-certain language in the jury instructions along with language of actual intent. DICKINSON, JUSTICE, SPECIALLY CONCURRING: P68. Although I concur with the majority, I write separately to address two points. I. P69. The majority correctly holds that -- absent an actual intent to injure the employee -- the "exclusive-remedy" provisions of the Mississippi Workers Compensation Act (the "Act") apply to injuries inflicted by employers upon employees. The vast majority of states, including Mississippi, hold this view, even where the employer's conduct is substantially certain to result in injury. 6 Arthur Larson, Larson's Workers' Compensation Law ? 103.03 (2008). [T]he common-law liability [**77] of the employer cannot under the almost unanimous rule, be stretched to include accidental injuries caused by the gross, wanton, wilful, deliberate, intentional, reckless, culpable, or malicious negligence, breach of statute, or other misconduct of the employer short of a conscious and deliberate intent directed to the purpose of inflicting an injury. Page 26 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** Id. (footnotes omitted). Although thirty-eight jurisdictions (including Mississippi) "follow the rule that actual intent to injure is necessary to come outside of the exclusivity provision," twelve states disagree. Thus, "in recent years there has been a trend toward permitting common law suits when the injury is the result of actions the employer knew were 'substantially certain' to cause injury. About a dozen states 65 now follow this or a similar rule." Larson's ? 103.03 n.1. However, our precedent holds that: [i]t is not enough to destroy [Workers Compensation] immunity that the employer's conduct leading to the injury consists of . . . knowingly permitting hazardous conditions to exist or willfully failing to furnish a safe place to work or knowingly ordering the employee to perform a dangerous job . . . . This Court has held repeatedly [**78] that the employer's action must be done with an actual intent [*245] to injure the employee, and that "an intentional tort is an act of intentional behavior designed to bring about the injury." Peaster v. David New Drilling Co., 642 So. 2d 344 (Miss. 1994) (internal citations omitted). 65 Connecticut, Louisiana, New Jersey, North Carolina, Ohio, Oklahoma, South Dakota, Texas, California, Michigan, Washington, and West Virginia. P70. In 1988, this Court reviewed an injured worker's argument that the Court should "recognize that the injuries sustained by him constitute a new tort outside the exclusivity rule of the [Act]." Griffin v. Futorian Corp., 533 So. 2d 461, 463 (Miss. 1988). Speaking for a unanimous Court, Chief Justice Roy Noble Lee stated that "[s]ome states have amended their worker's compensation acts to make exceptions to the exclusive remedy. Mississippi's act has not been amended in that respect since its passage." Id. at 463. Recognizing (as the majority does today) that an actual intent and design to injure is necessary, the Griffin Court cited with approval the following authority: [I]n order for a willful tort to be outside the exclusivity of the Act, the [employer's] action must [**79] be done "with an actual intent to injure the employee. It is not enough to destroy the immunity that the employer's conduct leading to the injury consists of aggravated negligence or even that the conduct goes beyond this to include such elements as knowingly permitting hazardous conditions to exist or willfully failing to furnish a safe place to work or knowingly ordering the employee to perform a dangerous job." Griffin v. Futorian Corp., 533 So. 2d at 464 (citing Dunn, Mississippi Workmen's Compensation (3d ed. 1982 & Supp. 1984)) (emphasis added). 66 It is of some significance that -- since Griffin was handed down some twenty years ago -- the Legislature has taken no action to address or contradict its holding. 66 The above quoted language from Dunn is correct. However, the Griffin Court mistakenly indicated that the "employee's" act, rather than the employer's act, must be done with actual intent to injure. Thus, the Griffin Court included a typographical error. We therefore now make the correction. P71. Thus, absent the employer's deliberate intent and design to injure the employee, the law in Mississippi -as it currently exists -- does not allow an injured employee to escape the [**80] exclusive-remedy provisions of the Act. The law on this point is so clear that discussion of the contrary view is unnecessary. And upon this point, I fully concur with the majority. II. P72. Another point I believe important concerns the procedure for presenting to the trial court an assertion that the Act provides a plaintiff's exclusive remedy. As a matter of procedure, in order to preserve the issue for appeal, a defendant should raise the matter in the first instance as an affirmative defense or (as in the case before us today) in a motion to dismiss. The converse is also true, that is, the plaintiff has no duty to raise or argue the issue. P73. Black's Law Dictionary defines an affirmative defense as "[a] defendant's assertion of facts and arguments that, if true, will defeat the plaintiff's . . . claim, even if all the allegations in the complaint are true." Black's Law Dictionary 356 (8th ed. 2005). Franklin's position is that -- even though everything the plaintiffs say in this lawsuit may be true -- it is nonetheless entitled to dismissal from this civil suit, because the Act provides the plaintiffs' exclusive remedy. Page 27 18 So. 3d 215, *; 2009 Miss. LEXIS 426, ** P74. As stated, in the case before us, Franklin raised the [**81] question by motion to dismiss, and the trial judge denied the [*246] motion, finding that the issue involved a question of fact. Thus, Franklin properly preserved the issue for appeal. P75. Furthermore, a defendant seeking to escape tort liability via an affirmative defense has the additional duty to seek a jury instruction for that affirmative defense which places the burden of proof (as to the affirmative defense) squarely upon the defendant. See Natchez Elec. & Supply Co., Inc. v. Johnson, 968 So. 2d 358, 361 (Miss. 2007) ("The burden of proving an affirmative defense lies upon the party who relies upon that defense." (citing Jenkins v. Pensacola Health Trust, Inc., 933 So. 2d 923, 927 (Miss. 2006))). P76. Franklin argues that the jury instructions were contradictory and did not properly instruct the jury on its affirmative defense. The instructions which were given address the plaintiffs' burden of proof in establishing the causes of action pending before the circuit court. The instructions (recited in the majority opinion) addressing those causes of action were, in my judgment, correct. The fact that the jury was not instructed exactly as Franklin thinks it should have been should not [**82] be viewed as error on the part of the plaintiffs, who had no duty to offer an instruction from Franklin's perspective. P77. That said, under the facts of this case (as discussed by the majority), any additional instruction offered by Franklin wouldn't have affected the outcome anyway. But in the interest of completeness, I offer this analysis which I believe to be complementary -- rather than contrary -- to the majority. WALLER, C.J., CARLSON, P.J., RANDOLPH, LAMAR AND PIERCE, JJ., JOIN THIS OPINION. 1-Bromopropane (n-Propyl Bromide) 1-Bromopropane can harm the reproductive system and the nervous system. It causes sterility in both male and female test animals, and harms the developing fetus when tested in pregnant animals. 1-Bromopropane can damage the nerves, causing weakness, pain, numbness, and paralysis. It will soon be tested in animals to find out if it can cause cancer, as many similar chemicals do. The effects of 1-bromopropane on human health have not been well studied. However, a few human case reports suggest that 1-bromopropane can harm the nervous system. 1-Bromopropane is a new solvent intended to replace solvents like trichloroethane and some Freons that damage the upper ozone layer. HESIS is issuing this Hazard Alert because 1-bromopropane is being considered for widespread use and is not regulated to protect workers, consumers, or the environment. Health Hazard ALERT How 1-bromopropane How to find out if enters your body you are working with 1-bromopropane 1-Bromopropane is a solvent. It might be used wherever there is a need to dissolve fats, waxes, or resins. So far, two of its main uses are in degreasing and in spray adhesives. It is being considered for use in drycleaning and for many other uses as a replacement for other organic solvents that damage the upper ozone layer. Your employer must tell you if you are working with 1-bromopropane, and must train you to use it safely (California Code of Regulations, Title 8, Sections 3203 and 5194). If you think you may be exposed to 1-bromopropane on the job, ask to see the Material Safety Data Sheets (MSDSs) for the products you are using. The MSDS for a product that contains 1-bromopropane must identify it in Section 2, by the CAS number 106-94-5. 1-Bromopropane is also called n-propyl bromide. Some MSDSs do not fully describe the hazards of the product. 1-Bromopropane enters your body when you breathe its vapor or drops of spray in the air. Some can enter your body through your skin. Your risk of health effects depends on the amount of 1-bromopropane that enters your body. That depends mainly on the amount (the concentration) of 1-bromopropane in the air, your skin contact, and how long you are exposed. How 1-bromopropane can affect your health The toxic effects of 1-bromopropane in humans have not yet been well studied. Because it is a recently introduced chemical, most information comes from animal testing, not from experience with human use. In most of the animal tests, the animals breathed 1-bromopropane in the air. However, you can also absorb 1-bromopropane through your skin. HEALTH HAZARD ALERT JULY 2003 HESIS HAZARD EVALUATION SYSTEM & INFORMATION SERVICE California Department of Health Services Occupational Health Branch 1515 Clay Street, Suite 1901, Oakland, CA 94612 510-622-4300 o www.dhs.ca.gov/ohb California Department of Health Services o California Department of Industrial Relations REPRODUCTIVE SYSTEM LIVER 1-Bromopropane damages the reproductive systems in both male and female animals. In males, it damages the sperm, testicles, prostate, epididymis, and seminal vesicles, and reduces testosterone levels, causing sterility. In females, it damages the ovaries and interferes with the estrous cycle, again causing sterility. 1-Bromopropane also caused delayed growth in the offspring of animals exposed during pregnancy. Some of these effects were seen at exposure levels as low as 200 parts per million (200 "ppm") in air, and possibly even at 100 ppm. Very high exposures may harm the liver. We don't know whether there's any risk to the liver from exposure levels likely to be found in the workplace. Reproductive toxicity of 1-bromopropane has not been studied in humans, but the closely related chemical 2-bromopropane has been found to cause long-lasting ovarian failure and absence of sperm in workers. NERVOUS SYSTEM 1-Bromopropane damages the nerves in the arms, legs, and body. There is evidence that 1-bromopropane may also damage the brain itself. Animal tests have found these effects with exposures as low as 400 ppm. Case reports show that similar effects can occur in humans. EYES, NOSE, THROAT, AND SKIN 1-Bromopropane is irritating to the eyes, nose, and throat, at exposure levels of perhaps 30 ppm. Like other organic solvents, the liquid can dissolve the natural protective oils on your skin and cause dermatitis (dry, rough, red, cracked skin). It can also be absorbed into your body through the skin. 2 CANCER 1-Bromopropane will soon be tested to see whether it can cause cancer. Many similar chemicals, such as dibromochloropropane (DBCP), do cause cancer. In some tests, but not in others, 1-bromopropane has caused genetic mutations. Chemicals that cause mutations often can cause cancer. HOW TO REDUCE YOUR EXPOSURE E ven though there is no Permissible Exposure Limit (PEL) for 1-bromopropane (see page 4), Cal/OSHA's Title 8, Section 5141 requires your employer to protect you from being exposed to chemicals at levels that harm your health. See www.dir.ca.gov/title8/5141.html. Cal/OSHA and the Cal/OSHA Consultation Service can help you and your employer - see "Where to Get Help" on the last page. ? ? Other Engineering Controls. Vapor degreasing systems should include controlled hoists, effective cooling coils, and lids. Vapor degreasing should be isolated from other work areas. If parts are removed wet, the drying area should be vented to the outdoors. ? Respiratory Protection. Respirators may be used only if ventilation and other control methods are not effective and feasible. A halfface respirator with organic vapor cartridge can reduce your exposure. In spraying operations, this should be combined with a mist pre-filter cartridge. A "dust mask" will not protect you, and may even increase your exposure by giving a false sense of confidence. Employers must comply with the Cal/OSHA Respiratory Protection Standard (Title 8, Section 5144). See www.dir.ca.gov/title8/5144.html. Substitution. The best way to reduce exposure is to switch to products that don't contain 1-bromopropane. Avoid using products for which you do not have an MSDS. Switch to water-based adhesives, when possible, for flexible foam fabrication. Hot water-based aqueous cleaning detergents often can be substituted for 1-bromopropane products for vapor degreasing and cold cleaning operations. If you can't switch to 1-bromopropane-free products, take other steps to limit your exposure. ? Using Less. If you must use 1-bromopropane products, use as little as possible. Keep containers closed between uses. 1-Bromopropane can evaporate from 1-bromopropane-soaked rags, so make sure that used rags are kept in a wellventilated area or sealed in an airtight container. ? Ventilation. Make sure that there is good ventilation. "Local exhaust ventilation" is most effective; it captures contaminated air at the source, before 1-bromopropane can spread into your breathing zone. In a study conducted by the National Institute for Occupational Safety and Health (NIOSH), for example, improving the local exhaust ventilation reduced 1-bromopropane levels by about 70% in a cushion manufacturing plant. Next best is general ventilation, which uses a fan-powered system to bring fresh air into the work area. Open doors and windows usually provide very little ventilation. An indoor fan that just blows contaminated air around without removing it from your work area is not effective. ? Skin Protection. It may be hard to avoid getting 1-bromopropane on your hands if you use it for cleaning or gluing. If you must use 1-bromopropane products and it is likely that it will get on your skin, wear protective gloves and replace them often. Chemical protective clothing, such as aprons or sleeves, may also be needed if skin contact occurs at areas other than your hands. California regulation (Title 8, Section 3384) requires employers to supply gloves or any other necessary protective equipment. Viton, Silvershield, and 4H glove materials may resist penetration by 1-bromopropane longer than most other materials. 1-Bromopropane can penetrate some common glove materials within 30 minutes to two hours. 3 Legal exposure limits 1-Bromopropane is a virtually unregulated chemical. Cal/OSHA does not have a Permissible Exposure Limit (PEL) for workplace exposure. Neither the U.S. Environmental Protection Agency (U.S. EPA) nor Cal/EPA has set any limits on 1-bromopropane in the environment. U.S. EPA is considering approving 1-bromopropane for use as an alternative to chemicals that damage the ozone layer in the upper atmosphere. Recommended exposure limits HESIS recommends that workplace exposure be limited to about 1 ppm in order to protect against the reproductive and nerve toxicity of 1-bromopropane. HESIS also recommends a skin notation to require protection against skin contact exposure. Many manufacturers and distributors have made recommendations for occupational exposure limits. These proposals range from 5 ppm to 100 ppm. Measuring your exposure The amount of 1-bromopropane in the air in your workplace can and should be measured. However, until 1-bromopropane is regulated by Cal/OSHA, there may not be any legal standard to compare the results to. Are there medical tests for Regulations that help to protect workers HAZARD COMMUNICATION STANDARD. Under this standard (Title 8, Section 5194), your employer must tell you if any hazardous substances are used in your work area, must train you to use them safely, and must make MSDSs available. See www.dir.ca.gov/title8/5194.html. INJURY AND ILLNESS PREVENTION PROGRAM. Every employer must have an effective, written Injury and Illness Prevention Program (IIPP) that identifies a person with the authority and responsibility to run the program (Title 8, Section 3203). The IIPP must include methods for identifying workplace hazards, methods for correcting hazards quickly, health and safety training at specified times, a system for communicating clearly with all employees about health and safety matters (including safe ways for employees to tell the employer about hazards), and record-keeping to document the steps taken to comply with the IIPP Standard. See www.dir.ca.gov/title8/3203.html. ACCESS TO MEDICAL AND EXPOSURE RECORDS. You have the right to see and copy your own medical records, and any records of toxic substance exposure monitoring (Title 8, Section 3204). These records are important in determining whether your health has been affected by your work. Employers who have such records must keep them and make them available to you for at least 30 years after the end of your employment. See www.dir.ca.gov/title8/3204.html. exposure and health effects? 1-Bromopropane levels in urine reflect recent exposure fairly accurately, but the test is difficult and expensive. Bromine levels in urine also reflect recent exposure, but other exposures may influence the test. Standard tests for reproductive function, nervous system damage, and blood effects may be appropriate if you work with 1-bromopropane. 4 DO YOU USE ANY OF THESE PRODUCTS? Abzol Albatross VDS-3000 Alpha Metals VaporEdge 1000 Amrep Misty Safety Solvent 2000 Ceramichrome Overglazes 6, 8, 9, or 18 Ecolink Hypersolve Ecolink Triagen EnSolv; EnSolv-A; EnSolv-CW Hypersolve NPB; Hypersolve ASC K-Grip 501 Spray Adhesive Leksol LPS Instant Super Degreaser II Micro Care PowrClean Solvent NPB Heavy Duty Cleaner Degreaser NPB Heavy Duty Contact Cleaner NPB Heavy Duty Flux Remover Nye Lubricants Fluorosolvent 507 Nye Lubricants Nyetact 502H-20 Pensolve PB2000 Petroferm Lenium Petroferm nPB Stabilizer Booster Rite-Off Generation 2000 Bromo-Clean Solvon PB, PBA, AER, ACS, DR, or IP Techtride DG Tek-Rap Series 200-20D Low-VOC/HAPs Liquid Adhesive Coating United C174 Aerosol Contact Cleaner Western Chemical These are some products with MSDSs showing that they contain 1-bromopropane. However, products like these can change their ingredients quite often. Be sure to check the current MSDS for whatever products you're using. 5 WHERE TO GET HELP (R) HESIS answers questions about 1-bromopropane and other workplace hazards and has many free publications available. For information on workplace hazards: (510) 622-4317. Please leave a message and your call will be returned. For HESIS Publications: (510) 622-4138. Call, or visit our website www.dhs.ca.gov/ohb, or write to HESIS, 1515 Clay Street, Suite 1901, Oakland, CA 94612. o HESIS Guide to Solvent Safety. Discusses health and safety hazards and protective measures. o Workplace Chemical Hazards to Reproductive Health: A Resource for Worker Health and Safety Training and Patient Education. Explains how chemicals can affect reproduction. o HESIS Publication List. Fact sheets, booklets, and medical guidelines on workplace hazards including chemicals, repetitive motion, and infectious diseases. Visit our website, call, or write for the list. (R) California Division of Occupational Safety and Health (Cal/OSHA) investigates workers' complaints, makes enforcement inspections, and answers questions about workplace health and safety regulations. Complainants' identities are kept confidential. Contact the Cal/OSHA Enforcement District office nearest to your workplace. Offices are listed in the blue government section near the front of the phone book, under "State Government / Industrial Relations / Occupational Safety and Health / Enforcement," or visit their website at www.dir.ca.gov/DOSH/districtoffices.htm. (R) Other resources for employees may include your supervisor, your union, your company health and safety officer, your doctor, or your company doctor. (R) Cal/OSHA Consultation Service helps employers who want free, non-enforcement help to evaluate the workplace and improve the health and safety conditions. Employers can call (800) 963-9424. (R) Occupational health services can be found at: o UC San Francisco/SFGH Occupational and Environmental Medicine Clinic: (415) 885-7580. o UC Davis Occupational and Environmental Medicine Clinic: (530) 754-7635. o UC Irvine Center for Occupational and Environmental Health: (949) 824-8641. o UC San Diego Center for Occupational and Environmental Medicine: (619) 471-9210. Gray Davis, Governor State of California Grantland Johnson, Secretary Health and Human Services Agency Diana M. Bont?, R.N., Dr.P.H. Director, Department of Health Services Steve Smith, Acting Secretary Labor and Workforce Development Agency Chuck Cake, Acting Director Department of Industrial Relations JANE NORLING DESIGN OSP 03 79401 Division of Occupational Safety and Health N.C. Department of Labor 1101 Mail Service Center Raleigh, North Carolina 27699-1101 Cherie K. Berry Commissioner HEALTH HAZARD ALERT 1-Bromopropane (n-Propyl Bromide) 1-Bromopropane (1-BP) is a new solvent that is effective in dissolving fats, waxes and resins. Two of its main uses are in degreasing agents and in spray adhesives. 1-BP is being used in the furniture industry and as a solvent for adhesives used in constructing foam cushions. The dry cleaning industry, among others, has considered using 1-BP as a replacement for other organic solvents that damage the ozone layer in the upper atmosphere. The N.C. Department of Labor's Division of Occupational Safety and Health (OSH), is very concerned about the health effects of 1-bromopropane. OSH is issuing this health hazard alert because 1-bromopropane is being considered for widespread use and is not regulated to protect workers, consumers or the environment. North Carolina does not currently have a permissible exposure limit for 1-bromopropane. The American Conference of Governmental Industrial Hygienists recently published a recommended timeweighted average threshold limit value of 10 parts per million, which is equivalent to 50 milligrams of 1-bromopropane (1-BP) per cubic meter of air.1 Hazards: 1-Bromopropane can harm both the nervous system and the reproductive system. It can damage the nervous system by interfering with nerve conduction, resulting in limb weakness, pain, numbness, and paralysis.2,3 It can cause reduced fertility and/or sterility in test animals, both male and female, and it can harm the developing fetus in pregnant female test animals. It will soon be tested to find out if it can cause cancer, as many similar chemicals do. Other harmful effects include irritation of the eyes and skin.4 Health Effects 1-Bromopropane enters your body when you breathe its vapor or drops of spray in the air. It can also enter through your skin and cause significant problems, depending on the concentration of 1-BP in the air, your skin contact and exposure time. The toxic effects of 1-bromopropane in humans have not yet been well studied. Because it is a recently introduced chemical, most information comes from animal testing and not from experience with human use. In most of the animal tests, the animals were exposed to 1-bromopropane by breathing it in the air. The following outlines health effects that have been studied. Reproductive System 1-Bromopropane damages the reproductive systems in both male and female animals. In males, it damages the sperm, testicles, prostate, epididymis and seminal vesicles and reduces testosterone levels, causing sterility. In females, it damages the ovaries and interferes with the estrous cycle, again causing sterility. 1-Bromopropane also caused delayed growth in the offspring of animals exposed during pregnancy. Some of these effects were seen at exposure levels as low as 200 ppm in the air, and possibly even at 100 ppm. The reproductive toxicity of 1-bromopropane has not been studied in humans, but 2-bromopropane, a closely related chemical, has been found to cause long-lasting ovarian failure and absence of sperm in workers. Nervous System 1-Bromopropane damages the nerves in the arms, legs and body. There is evidence that 1-bromopropane may also damage the brain. Animal tests have found these effects with exposures as low as 400 ppm. Case reports show that similar effects can occur in humans. Eyes, Nose, Throat and Skin 1-Bromopropane is irritating to the eyes, nose and throat at exposure levels of perhaps 30 ppm. Like other organic solvents, the liquid can dissolve the natural protective oils on skin and cause dermatitis (dry, rough, red, cracked skin). Liver Very high exposures may harm the liver. It is not known whether exposure levels likely to be found in the workplace present any risks to the liver. Cancer 1-Bromopropane will soon be tested to see whether it can cause cancer. Many similar chemicals, such as dibromochloropropane, do cause cancer. In some tests, but not in others, 1-bromopropane has caused genetic mutations. Chemicals that cause mutations can often cause cancer as well. 1,000 copies of this public document were printed at a cost of $29, or $.03 per copy. How to Reduce Health Risks Substitution. The best way to reduce exposure is to switch to products that do not contain 1-bromopropane. Using less. If 1-bromopropane products must be used, quantities should be kept as small as possible, and containers should be kept closed between uses. Other engineering controls. Vapor degreasing systems should include controlled hoists, effective cooling coils and lids. Ventilation. Make sure that there is good ventilation. Local exhaust ventilation is most effective because it captures contaminated air at the source. Personal protective equipment. Aprons, gloves, goggles and respirators approved for use with organic chemicals can be effective in helping workers avoid exposure. Respiratory protection. Respirators may be used only if ventilation and other control methods are not effective and feasible. Requirements for Employers: Even if a chemical is not regulated by an OSH standard, employers are still required to "furnish ... conditions of employment and a place of employment free from recognized hazards." Employers also must ensure that employees do not suffer illness or injury from the use of any chemical agent. Rights of Employees: If you think you may be exposed to 1-bromopropane on the job, ask to see the material safety data sheets (MSDS) for the products you are using. The MSDS for a product that contains 1-bromopropane must identify it in Section 2, by the CAS number 106-94-5. 1-Bromopropane is also called n-propyl bromide. Some MSDSs do not fully describe the hazards of the product. Your employer must tell you if you are working with 1-bromopropane and must train you to use it safely (ref. Hazard Communication Standard, Subpart Z 1910.1200, Toxic and Hazardous Substances). Copies of safety and health standards for 29 CFR 1910 (General Industry) and 29 CFR 1926 (Construction) are available from NCDOL/ETTA upon request. Publications can also be ordered online (www.nclabor.com). For more information concerning education, training and interpretations of occupational safety and health standards contact: Bureau of Education, Training and Technical Assistance Fourth Floor, Old Revenue Building, Raleigh N.C. Telephone: (919) 807-2875 Fax: (919) 807-2876 For more information concerning occupational safety and health consultative services and safety awards programs contact: Bureau of Consultative Services Third Floor, Old Revenue Building, Raleigh, N.C. Telephone: (919) 807-2899 Fax: (919) 807-2902 Mailing Address: 1101 Mail Service Center, Raleigh NC 27699-1101 N.C. Department of Labor Web Site: http://www.nclabor.com Toll Free Number: 1-800-NC-LABOR (1-800-625-2267) Information Sources: The information provided in this alert is derived in part from a hazard alert issued by the California Department of Health Services, California Department of Industrial Relations. The source document (printed July 2003) as referenced here is used with permission granted by HESIS. (Source: Hazard Evaluation System and Information Service (HESIS), California Department of Health Services, Occupational Health Branch, 1515 Clay Street, Suite 1901, Oakland, CA 94612; (510) 622-4300; www.dhs.ca.gov/ohb.) American Conference of Governmental Industrial Hygienists, 2005. Yu, et al. Preliminary Report on the Neurotoxicity of 1-Bromopropane, an Alternative Solvent for Chlorofluorocarbons, J. Occup Health 1998; 40:234-235. 3. Ichihara, et al. Neurological Disorders in Three Workers Exposed to 1-Bromopropane, J. Occup Health 2002; 44:1-7. 4. ICSC:1332, International Programme on Chemical Safety and the Commission of the European Communities. 1. 2.           ! "  #$ #%#%&'(             !"#$  %&' ! (")!% !"*#$+,% ! + %# ("-&. !"*$+,% " %"  &/.0 1!2!"2'%!3%4 !"*%4"2 %.%     -5))!* !+$+   5),-./ ! "01-* $6778)" "*,,,23*4-*0*,,.,-**.+5 '676(-*-/-.*,7 ,*,-4 -.+'(0,2- .,-*  ,- ,*8+90-!'*:( *"*..,9 "9 ,-,",/0,2+.2/0.2/".9*'% %(8 *!2+!.2/".9*';% %(8<9 72*" !-*!2 -4 -*  4*, 9." *:-*,2 *!"    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ouse OFHEE RANKING MEMBER WAsH:m3'noN, Uc 20515-5006 HEALTH 1202] 225-45'! at the flutter: ?tates Lcwo Emmcu, NJ 07740 Oceans (732) 57'l--'I1d0 ATIDNAL Pawns. AND Puauc Lance C7 57-'59 57- Edi 20515-3 006 mean Seven DEMOCRATIC FULICY COMMITTE E: NEW BMUINBWICK, NJ 08901 VICE CHAIR 032' 2"5'3352 I.E.i.,AmPon1' 1390 35_ mm NJ WSZI 254-5104 April 10, 2002 The Honorable Christine Todd Whitman Administrator Environmental Protection Agency Ariel Rios Federal Building 1200 Avenue, N.W. Room 3000 Washington, DC. 20004 Dear Administrator Whitman: I am writing to you to express my concern regarding EPA treatment of Enviro Tech International, Inc., and the Agency's ongoing rule making on its petition for Propyl Bromide under the SNAP program. six years without resolutiomand over one year since the EPA again publicly stated it would propose as acceptable, the Agency has yet to publish its role. It is my understanding that EPA's failure to issue its ruling is in order to include a non- binding, unenforceable recommendation regarding workplace exposure levels (W EL). Scientific assessments reveal that there is nothing so unusual about this compound that warrants such delay. In addition, both govemment and industry have incurred great expense due to this postponement for a mere recommendation which is the purview :'of OSHA, and outside EPA's authority. lam also concerned that worker safety may be compromised where industrial users continue to use alternative cleaning agents, which are knownand suspected carcinogens while waiting for SNAP approval ofnPB. - 1 am curious why the SNAP process has held to a much higher standard than any other compound, including mandatory animal testing using unique protocols, as well as the application of an entirely new standardfor cleterrni-ning ozone depletion potential. Is the SNAP program plannin to subject these standards_to the review of new and previously approved compounds? If not, what warrants a change in SNAP program-. standards for - . Industry sponsored workplace exposure assessments by pro-eminent scientists with recognized expertise in setting workplace safety guidelines are the basis for a consensus among industry participants that a 100 WEL is appropriate. Yet, despite SNAP's clear policy and history of deference to industry recommendations, the EPA appears intent on recommending a 25 WBL. Such an arbitrary action ignores credible scientific assessments, the indusn"y"'s 'expert opinion, and 3E.PA's own policy. It is difficult to understand the intentions in this instance. If EPA does, indeed, have valid, significant concerns about we would hope that you would PRINTED ON RECYCLED PAPER 06/05/02 WED 17:50 NO 8855] 8658532882 l?:58 2825552155 GPD 8TH18 share them with industry. Unfortunately, to date, no information like that has been forthcoming from the agency. As a strong proponent of the environment, I am also very concerned that EPA has chosen to operate under a veil of secrecy which has replaced partnership with suspicion and resulted in legal action under the Freedom of Information Act. EPA has refused to disclose the results of prior studies and tests about this chemical. No less than five draft reports (apparently evaluating the same data) are being withheld by EPA. I believe all documents requested under FOM should be made available immediately to the public for their comment. Additionally, I request that these documents be sent to my office for review. Inconsistency and shifting standards in the new alternatives arena can only have chilling effect on the willingness of industry to continue to fund research and development, thereby limiting the advancement of technologies favorable to our environment. I am gravely concerned that a program by which Congress intended to encourage new technology through government partnership with industry has become a barrier to innovation. At the same time, I am very concerned that this process may be underrnining, and substituting itself in place of OSHA regulation of the workplace. I would appreciate a fiill explanation regarding these concerns and a report on the current content and status of this rule rnalcing. Please have this information provided to me by April 30th . I believe that a six--year review process is unacceptable. Combined with a disregard for the scientific assessments of the compound, action is outrageous. Thank you for your prompt attention to this matter. Sincerely, Frank Pallone, Jr. I Metnberof Congress Co: I effrey R. I-Iornstead, Assistant Adminisn-ator for Air and Radiation 06/05/02 WED 17:50 NO 8855] asra5r2aa2 1t:5a 2a25s5215s GPD lfiflfi FACT SHEET on IIPB Review - EPA's SNAP program was created under Section 612 of the Clean Air Act. Epidemiological and animal toxicological studies indicate that elevated exposure to may'impai1' reproductive, liver, kidney, and neurological function. An isomer of IJPB appears to be highly toxic, causing sterility in exposed Workers. - Reports from industry and the National Institute of Industrial and Occupational Safety and Health indicate that workers using as a solvent can be exposed to relatively high levels. In the absence of workplace standards established by the Occupational Safety and Health Administration or another or indust1'y standarcl--setting body, EPA's SNAP program has traditionally issued recommended guidelines for chemicals under review. An evaluation was needed for of-potential risks to workers, and the general public living near facilities where ILPB is used. To resolve uncertaitities pertaining to key pararneters, especially reproductive functions, Inanufactnrers agreed to conduct a multi-generation study. Results were released last summer in a report of several thousand pages; our consultanfs analysis of the data is available in EPA's Air Docket (Docket number A~200l -07). - appeared to be a threat to stratospheric ozone despite its short atmospheric lifetime. EPA convened a meeting of academic and industry experts who agreed that a more detailed modeling approach was necessary. Our review incorporates the most recent analyses. - The Technology and Economic Assessment Panel that reports to the Parties of the Montreal Protocol has issued several warnings on the ozone depletion potential and toxicity of 06/05/(l2 WEI) 17:50 NO 8855] 13:21 GPD P3465 dsi?t PM ifiiahiir FHK N0Avumon at the matter: ?tatefi finalise at Enprmentatimas M: 20515 (5 745-0791 {Fold} lime 5, 2.002 The Honorable Christine Todd Whitman. Administrator .. Environmontal Protection Agency Ariel Rios Federal Building 1200 Avenue, Room 3000 Washington, DC. 20004 Dear Administrator Whitman: It has some to my attontion that the long anraited outside consultant report on "n ptopyi bromide" has finally been submitted to the Significant New Alternatives Program (SNAP) dockat. I also understand that the findings and rcconunundafions of the consuitant's>> report continue: to generate controversy among the indnsuy and the sci entiflc community. As you know, due to increasing concern over scientific practices, the House of Representatives, by a resounding, bipartisan majutity, recently passed H.R. 64,, establishing the po sition of Deputy Administrator for Science and Technology ofthc Environmental Protection Agency. This legislation is designed to strengthen the role science plays in decision-making at the roguiatory level. As EPA begins its final detennination and rulemaking process on and on any petition under its gareview, I would urge that you utilize sound, saicntitic pra-ztica 1 wit] ho watrzl-a.i.ng with interest as your agency completes its action on tho petition. Sincerely, John Sullivan Member of Cong-ass Cc: Dr. John Graham, Administrator Ofiice of Inforrnatiott and Regulatory Affairs Jcffiey R, Homstead, Assistant Administrator for Air and Radiation THU 10:27 NO 8878] GPD lDl'?l'gE: - -- . READ stEXEC. secesrsam Frank Keating Governor April 23, 2002 The Honorable Christine Todd Whitman Environmental Protection Agency 1200 Ave, NW Washington, DC 20460 Dear Administratoi' Whitman, In June, 2001, I wrote to you on behalf of concerned businesses in Oklahoma urging evaluation of a proposed rule enacted by the previous administration which would have established allocation systems for hydroclilorofluorocarbon production, imports and exports. I am now advised of, and call to your attention, mlemal-ring related to nPropyl Bromide (nPl3) as it impacts the operations of such firms as Enviro Tech in Illinois and TULSTAR Products, Inc., of Oklahoma. It would appear that SNAP approval has been delayed concerning and that unique and excessively-stringent rules and procedures are being applied in this case. I would refer you. to previous letters on behalf of Enviro Tech -by Congressmen Rush and .Shimkus,,' and to the concern raised by TULSTAR in hopes that EPA will reevaluate IIPB for VOC exemption under the same standards used to evaluate other chemicals. I am also in-formed that delays and other actions have caused these, and perhaps other companies, to incur excessive expenses. I hope the agency will look closely at all factors involved in this matter, and proceed in the most fair and expeditious manner. Sincerely, rank Keatlng fale/mb STATE CAPITOL BUILDING OKLAHOMA CITY, OKLAHOMA 731515 (405) 52742342 I FAX (405) 521-3353 06/05/02 WED 17:50 NO 8855] l?i58. I GPD a3f1a The Honorable Frank Keating Governor State Capitol Building Oklahoma City, OK 73105 Dear Governor Keating: Thank you for your letter of April 23, 2002 on behalf of Envirc Tech International and TULSTAR Products, Inc. concerning the US. Environmental Protection Agency's (EPA's) process for reviewing n-propyl bromide I want to assure you that HPB is undergoing the same review as other chemicals submitted to EPA under the Significant New Alternatives Policy (SNAP) program and under the Agency's process for issuing VOC exemptions. The SNAP prograrn was established under the 1990 Clean Air Act Amendments to require EPA to evaluate overall risks of substitutes for ozone-depleting substances compared to other alternatives. The SNAP program assesses every substitute for its potential impacts on health and the environrnent. The length of individual reviews depends on the nature of the chemical, how it is used, and the completeness ofthe available data. This chemical has warranted a careful review for several reasons summarized in the enclosed fact sheet. EPA is Working hard to issue a decision expeditiously and the Agency expects to publish a proposed rulemaking for public comment this summer. EPA is currently reviewing Enviro Teclfs request for an exemption from the requirements for volatile organic chemicals (VOCS). The Agency considers each chemical using the same criteria. There must be sufficient evidence that a chemical is no more photochemically reactive than ethane. EPA's Air Quality Strategies and Standards Division in the Office of Air Quality, Planning and Standards is continuing to work with Enviro Tech to resolve outstanding technical issues. The Agency has conducted an open process in its review of We have published notices in the Federal Register in 1999 and 2000 to share the latest information with the public. There are over 100 documents on in our public dockets, including a major report on the toxicity of that Enviro Tech has requested from the Agency. Since 1997, we have attended ten industry conferences and have met with numerous companies to provide continual updates. In the past 18 months alone, we have met with representatives of Enviro Tecli on five occasions concerning EPA's ruling under the SNAP program, as well as additional meetings to discuss the 06/05/02 WED 17:50 ND 88551 l?:58 2825652155 GPD 8431B 2 petition for a VOC exemption. EPA has also exchanged correspondence on 8. number of occasions with both TULSTAR and Enviro Tech. Again, thank you for your letter. A more detailed response to the issues raised by Congressmen Rush and Shimkus is enclosed. I appreciate the opportunity to be of service and trust the information provided is helpful. If you have questions concerning EPA's review of have your staff contact Brian McLean, Acting Director of EPA's Office of Atmospheric Programs, at (202) 564--9l 54. Sincerely yours, Olmstine To dd. Whitman. Enclosure 06/05/02 WED 17:50 N0 8855] 8Ef85f2882 17:58 2825552155 GPD pagg FACT SHEET on IIPB Review under the SNAP Program - EPA's SNAP program was created under Section 612 of the Clean Air Act. . Epidemiological and animal toxicological studies indicate that elevated exposure to may impair reproductive, liver, kidney, and neurological function. An isomer of appears to be highly toxic, causing sterility in exposed workers. - Reports from. industry and the National Iristitute of Industrial and Occupational Safety and Health indicate that workers using as a solvent can be exposed to relatively high levels. In the absen.ce of workplace standards established by the Occupational Safety and Health Administration or another governinent or industry standard-setting body, EPA's SNAP program has traditionally issued recommended workplace guidelines for chemicals under review. An evaluation was needed for of potential risks to Workers, and the general public living near facilities where is used. To resolve uncertainties pertaining to key parameters, especially reproductive functions, nianufacturers agreed to conduct a multi- generation toxicological study. Results were released last sumrner in a report of several thousand pages; our consultant's analysis of the data is available in EPA's Air Docket (Docket nilmber A-2001-O7). appeared to be a threat to stratospheric ozone despite its short atmospheric lifetime. EPA convened a meeting of academic and industry experts who agreed that a more detailed modeling approach was necessary. Our review incorporates the most recent analyses. The Technology and Economic Assessment Panel that reports to the Parties of the Montreal Protocol has issued several warnings on the ozone depletion potential and toxicity of 06/05/02 WED 17:50 NO 8855] EnSo1vi precision cleaning solvent Safety of n--propy1 bromide more rumours and innuendo Rumours in the industrial press The EU will establish DNEL [Derived and various websites and blogs No Effect Level] recommendations are suggesting there are proposals in due course under the REAEH by AEEIH for a reduction ofthe legislation. current recommendations for Exposure "mus For n_PmFy| The manufacturers of EnSo|v, the BmmidE_ This Solver". is widely market leading based vapour used as an alfemafive 1.0 degreasing solvent formulation, frichjoroefhylene for vapour commissioned leading authorities degreasing. As there is no official to 9"aml"E' the VEW W99 dalabase Exposure Hm" Fm. [n_Pmpy| of exposure studies for and Bromide] in Europe or the USA, it theirwork clearly demonstrates is difficult to give credence to this lhal an LTEL 0099'" Offers campaign of innuendo emanating mmplele Safew from manufacturers of f|uorocar- EXDUSUFE Studies in Europe hon solvents who markejmodified submitted to EEHA demonstrate that EnSolv has been extensively tested trans 1,2 Dichloroethylene based Simple Valmul degreasels Ea" control emissions ofnPB to less I . - - than 25ppm_ Information concerning AEEIH is an industry body in the safe]-V' economics and United States, paid for and dominated AS the manufaclums ir mental im a by major chemical companies whose can assure tigers and lml9nl'al on nominated forthe fh are available on the website - - exposure imi is IS er . Flgurels REACH legislation all properly issue are pure eir . I . Dpinmn and mi adapired by any designed and maintained equipment authority including the U.S. EPA who be lmleclly Safe it" use and rejected their proposals when issuing "tier the "ml Emnomltal _a"d SNAP acceptance of as a vapour mghesl 5la"dard5 of Eleanlng degrpaslm-l Snlvenl in the EnSolv distributors are trained to The U.S. EPA rejected the currentA[l3lH msped and advise on The USE Dflhe TLV of and instead recom-- I Vapour dggreasmg pmtess For 1:EndEd2''ppm Undelgnm ma] economical and safe usage with ions oflusel. Howevei even this is not monitoring and Exposure fesfing on an official figure as only DSHA can set requesf exposure standards in the US. I envii-utecri Europe Bermuda Housc-,High Street, Kingston uponThames,EurreyKTl 4EH,Llnited Kingdom The environmentally-friendly vapour Tel +44 [ll]ELlE EH1 E370 - Fax +44 SUE 353i - Email - Website To Whom It May Concern: DrySolv from Dry Cleaning Technologies, a division of Enviro Tech International Inc, is the newest environmentally responsible solvent development on the market. It comes on the heels of major Perc regulations and is the most viable new alternative. DrySolv was developed 11 years ago under a different trade name, EnSolv, in the vapor degreasing industry. EnSolv is a variation of the DrySolv chemistry that has matured into an internationally known solvent and has been approved by large organizations such as Boeing to be the only environmentally friendly alternative used to replace harsher solvents. It is the only patented chemistry of its kind and has proven to be the leading alternative solvent in that industry. Enviro Tech International Inc. now looks to make a seamless transition into dry cleaning, with Dry Cleaning Technologies and DrySolv . DrySolv is superior to all other solvent solutions for many reasons. It will make the dry cleaner more efficient and it will alleviate many concerns of all parties involved and here's why. DrySolv is not listed or expected to be a carcinogen. DrySolv is non-flammable, showing no flashpoint in multiple tests and test methods. (ASTM D-56 TCC, ASTM D-92 COC, ASTM D-93 TCC). DrySolv is also non-chlorinated. DrySolv is non-hazardous. (DOT, OSHA, NESHAP, RCRA, Clean Water Act) DrySolv is not a hazardous air pollutant, is SNAP approved and does not contribute to global warming. (NESHAP, Significant New Alternative Program-SNAP approved (Federal EPA), Not Title V) The USEPA states that DrySolv's main ingredient is less persistent in the environment than many other solvents, is of low to moderate concern for movement in soil, does not warrant listing under the Toxics Release Inventory and is not prone to bioaccumulation. (USEPA - Federal Register May 30, 2007). DrySolv does not have a hazardous decomposition or hazardous polymerization. Veoila Environmental Services, a nationally known waste service company, has established their Drum Express licensed waste-hauling program specifically for DrySolv users. PO Box 293 Dry Cleaning Technologies Harmony, PA (724) 473-8117 fax (724) 473-8119 DrySolv users are given a comprehensive guideline package, helping to assure that all proper methods and measures when dealing with DrySolv and machinery are CONSISTENTLY followed. As for the Dry Cleaners.... DrySolv will work in their existing class IV Perc machine as a "drop in" replacement. It will do a superior job at cleaning garments then Perc in a shorter time, while using less energy to do so. DrySolv is the best alternative for Dry Cleaners to date. The chemistry has an 11-year track record of award winning, environmentally friendly excellence. We at Dry Cleaning Technologies hope to pass this legacy on to the dry cleaners of today assuring a safe and clean future for us all. Please feel free to contact me direct with any questions or concerns. Best Regards, Ray Roccon Division Manager PO Box 293 724-473-8117 rroccon@dctco.com Dry Cleaning Technologies Harmony, PA (724) 473-8117 fax (724) 473-8119