failed to provide adequate training, instructions, warnings and directions as to safety precautions necessary for the safe use of said chemicals.

33. At all relevant times, the defendants negligently failed to provide adequate respiratory protection, ventilation, air circulation, and other safety precautions necessary for the safe use of said chemicals.

34. As a result of exposure to said chemicals, the Plaintiffs and Plaintiffs decedents suffered, and the Plaintiffs will continue to suffer, serious injury, illness and disease, and have and will incur substantial medical expenses.

35. As a result of exposure to said chemicals, the Plaintiffs decedents set forth in the Fourth Cause of Action suffered conscious pain and suffering prior to their death.

A SECOND CAUSE OF ACTION FOR STRICT PRODUCTS LIABILITY

36. Plaintiffs reallege and incorporate by reference each and every allegation contained in the First Cause of Action, as if fully set forth herein.

37. As a result of the foregoing, each of the defendants is liable to each of the Plaintiffs under the doctrine of strict products liability, for defective design of said chemicals, defective manufacturing of said chemicals, and failure to provide adequate training, directions, instructions and warnings concerning