Westinghouse Corporation

1988

"The majority of the documents in Industrial Hygiene's files are potential "smoking guns" documents. . . .Industrial Hygiene audit and trip reports certainly qualify as potential smoking guns. . . . If the information was not conveyed to customers, the public, etc, the potential future problems are readily apparent....these files show corporate knowledge of hazards but no actual implementation of corrective measures. Consequently, the documentation is potentially harmful. . . .In order to determine whether or not to discard any of the records , the risks of keeping the files must be balanced against the advantages of maintaining the records....We recommend that all such files generated prior to 1974 should be discarded."

Corporate Lawyer advising Westinghouse in internal legal memoranda.