HHJP: objection sustained
JB: these residue levels that were found and tested are equal to what you might find in common cleaning products?
yes.
JA: did you find any other substances that were from cleaning products?
I was tasked with looking for chloroform.
JA: you talked about low, very low, residue but those are vague terms?
yes subjective terms
JA: ever been called on in your career to look for chloroform on in a dry form, ususally liquid?
there have been unknown liquids where chloroform was identified?
JA: product tampering?
yes, or unknown where they don't know what it is
JA: what would be high or low?
I don't have anything to reference, have to do test and doing a validation kind of study.
JA: in reference to states exhibit the spare tire cover, how did it come to you? how was it packaged
JB: objection
overrulled
JA: how was it packaged?
found inside a box
JA: card board box like here?
JA: what effect would that have on a volitile thing like chloroform?
it would leak out
JA: why were you surprised?
normally chloroform does not stay around, to have a package like that I was surprised to get results for chloroform
JA: you figured it should have(been gone)
yes, was surprised
JA: general numbers?
the intenstity of the peak the hight the area of the peak...
JA: that is what you are referring to not a quanitative analysis but...
not right to say quanitiative but can get...
JA: ?
the



control was a known amount of chloroform, 0.01% in water. 100 parts per million
JA: so that is the standard which you compare to determine a general idea of how much there is
so I wouldn't put too much on or two little. I use it to detect the



quanitative control
JA: this 100 ppm?
yes, later on I was asked to give indication of quanity and this was the only way
JA: so this is a very rough...it was a piece of spare tire cover in a can?
yes
JA: is that better than keeping in a box?
submitted it in the can is the appropriate way to do it
JA: Q22 rough amount you found compared to the control
compared the high of the peak is significantly less
JA: rough percentage?
can I give an idea about percentage, I did give
JA: what is the comparison to the standard
I do not have information in front of me, (looks) based on the hight counts it is five percent based on the comparasion of the control
JA: very rough estimate?
yes
JA: somewhere in five percent
that is my calucation.
JA: Q23? how about?
approx .1 percent
JA: and Q23 is the actual unsealed spare tire cover?
that is correct
JA: would it be fair to say the sealed container contained more chloroform than the one in the box
for Q22, yes but there were more
JA: skip the ones you say are consistent with...trunk liners...how about Q44 was that a sample in a sealed container?
yes
JA: rough percentage on that?
the rough percentage is 5% as compared to the positive controll
JA: Q45
.2%
JA: the highest is on Q22 in a sample in a can?
yes, but must take into account the sample was not the same. If I have a bigger cutting on Q and a smaller out of the next, I will find more. This is not the best way to relate these numbers.
JA: what ever the amount in the sample would that chloroform have evaporated before you could test?
I could
JA: open car, chloroform would be the same as before?
objection
overruled
based on the properties of chloroform if it was open atmosphere I would expect less than I found.
JA: if these figures accurately reflect would it add up to the low parts per mill rank?
yes
JA: other than testing for chloroform in air samples?
no
JA: any knowledge of what is high or low in a air sample?
objection
overrulled
no
JA: the context you said of high, low or shocking that is from liquid?
?
JA: prior to this it would have been liquid?
objection
overruled
HHJP: she did
JB: highly misleading
HHJP: overruled
JA: in the context of your experience(?)mostly testing for chloroform
correct