DUSTRiES, INC . 

EPENDENCE, KENTUCKY 4105J, 

7^1! HAR l b A q:0 1 ^fiCEfVE V4D 

D 

u s Department of Transportation FAA Docket No. CPIOSOOOIO^ Ci^R/M/* ^ H A/^lx v 

Office of Hearings FAACaseNo. 2010SO700313, *''^V3I UUUKcT 

Washington,DC I f PO 2O/0'/og i 

This letter is in response to the FAA Request for Production letter received by Magni on February 28,2011. 

Interrogatories: 

1. Please state the name, occupation, address, and phone number of each person respondent intends to call as a witness 

in this proceeding. State the subject matter to which each witness will testify and include a summary of the expected 

testimony of each witness. 

Ed Yung 

Environmental Health and Safety Coordinator/Warehouse Manager 

10250 Toebben Drive, Independence, KY 41051 

859-746-1777 

Ed was the employee directly involved in this incident. Ed Yung's testimony will include a brief 

summery of his experience as a Health and Safety Coordinator including experience relating to 

Hazardous Materials. 

Ed Yung will discuss specific training past and present relating to this incident. 

2. Please state the name, occupation, address and phone nxmiber of each witness who is expected to present expert 

testimony. Include a summary of the expected testimony including facts and opinions. Also state the basis for the 

opinion includmg but not limited to a description of any documents, reports, records or tangible evidence relied 

upon. 

Magni will not have a witness to present expert testimony 

3. Please state the name, address, and phone number of each employee or agent of Respondent responsible for 

accepting, transporting, or offering the alleged shipment of hazardous materials, hi or her title while employed vyith 

Respondent, and the responsibilities of his or her position. 

Ed Yung 

Environmental Health and Safety CoordinatorAVarehouse Manager 

10250 Toebben Drive, Independence, KY 41051 

859-746-1777 

Ed Yung is responsible for matters involving Health and Safety training with new and existing employees at 

the Magni Industries Kentucky location. Ed is responsible for EPA, OSHA, DOT, lATA compliance at the 

Magni Industries Kentucky location. 

Requests for Production: 

1. Please provide a copy of each exhibit that Respondent intends to introduce into evidence at trial. 
Magni will not have any exhibits to produce as evidence. 

2. Please provide a copy of any hazardous material traming records maintained by Magni Industries or any of its 

agents, at the time of this incident, for the employees involved in this matter. 

Doc # 1: Certificate of Completion for 49CFR/IATA/IMDG Training that took place subsequent to the FAA finding. 

Doc #2: External Trainmg Courses completed by Ed Yung since hire date. Magni will have corresponding Training 

Completion Certificates available at the hearing. 

Doc#3: Internal Training Courses completed by Ed Yung 

If any additional information is required by the court, please do not hesitate to ask. 

Sincerely, 

Todd R. Pahner 

General Manager 

Magni Industries, Inc 

Mailed by Certified mail to the Following: 

Hearing Docket 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

The Honorable Richard C. Goodwin, Administrative Law Judge 

Office of Hearuigs, M-20 

U.S. Department of Transportation 

1200 New Jersey Ave.,SE 

East Buildmg Ground Floor, Room El2-230 

Washmgton, DC 20590 

>oC * zExternalTrailing -EdYung 

ID Type of Training Training Notes 

14 Comprehensive New Hire / Safety Orientation 

15 Chemical Hygiene Plan 

16 Hazmat, DOT 49CFR 

17 Hazardous Waste Mgmt. 

18 lATA/IMO Regulations 

19 Sink or Swim Sam. 

252 OSHA 10-Hour 

253 Fire Protection and Life Safety 

254 Adult CPR/AED Training 

272 Advanced RCRA 

294 PPE - Respirator Fit Testing 

305 49CFR USDOT - Recertificatlon 

306 49CFR Security Awareness Training 

356 International Maritime DG by Ocean - Initial 

Certification 

357 lATA/ICAO DG by Air - Recertificatlon 

365 Adult CPR/AED 

408 Export Compliance 

527 Practical Compliance with EPA Regulations 

587 DG training program: 49CFR/IATA/IMDG 

588 Security Awareness Training 

596 Security Awareness Training 

609 40 CFR 60 Appendix A visable emissions 

evaluator 

610 EPA Method 9 certification 

8/01 

4/03, 6/14/10 Retrained 

2/03, 7/8/10 Retrained 

2/03 

2/03 

6/03 

6/15-16/04 

5/12/04 

1/26/05 

09/02/05 Resource Conservation & Recovery 

Act 

Zee Medical/S. Sheveland 

02/09/06 GTTS 

02/09/06 GTTS 

11/08/2006 GTTS 

11/07/2006 GTTS 

2/15/07 

7-23-07 

6/9/08-6/10/08 15.5 Hours 

7/8/10 

6/22/10 

7/8/10 

11/4/10 

11/4/10 

Tuesday, March 01, 2011 Page 1 of 1 
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Training Table Query -EPA, OSHA, Health/Safety 

Related - Internal 

Employee Name Date Requirement 

jEd Yung 

8/19/2008 Fovklift Safety Training 

8/29/2008 W-P1024.R07 Filling Instruction Acct Ref # 08082806 

9/17/2008 Eye and Face Protection 

10/1/2008 Update H.^ZMAT Training For Shipping 

11/3/2008 Lock Out / Tag Out 

12/2/2008 Personal Protective Equipment (PPE) CFR 29 1910.132 (f) 

1/7/2009 Hazardous Communication 1910.1200 (h) OSHA 

2/6/2009 OSHA 29 CFR 1910.134 Respirator Training 

3/5/2009 Hazardous Waste OSHA 1910.120 (e) 

4/4/2009 Bloodbome Pathogens OSHA 1910,1030(d) 

8/20/2009 Flammable Liquid Safety 

12/10/2009 Electrcial Safety 

12/10/2009 Safety Glasses Training 

2/2/2010 Fire Drill 

2/17/2010 Feb Safty Training - P-Cl 003.R01 Safety and Environmental 

Orders, W-C1008.R03 Disosal of Hazardous Waste, WW1005.R02 Tipping Empty Containers 

3/16/2010 Flammable Liquid Safety 

4/19/2010 Good Hygiene on the Job 

6/14/2010 Chemical Hygiene Plan 

6/22/2010 Security Awareness Training 

7/19/2010 Keeping a Lid on Flammable Liquids 

11 /24/2010 Safety Glasses 

1/25/2011 Fire Alarm Drill 

Tuesday, Marc h 01 , 2011 Page 1 of 1