Document 0J1x4Dxb3eoZxV5ZZOwQrj5VV
FILE NAME: Warning Labels (WL)
DATE: 1983
DOC#: WL005
DOCUMENT DESCRIPTION: Legal - Objections of Defendant Fibreboard to Plaintiffs' Interrogatories
/
IN RE ASBESTOSIS CASES
IN THE UNITED STATES DISTRICT FOR THE EASTERN DISTRICT OF TEXAS
OBJECTIONS OF THE DEFENDANT FIBREBOARD CORPORATION TO THE
PLAINTIFF'S INTERROGATORIES
TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, the Defendant, Fibreboard Corporation, in response to interrogatories
propounded under Rule 33, Federal Rules of Civil Procedure, served on Defendant's counsel, and files this its objections to certain interrogatories. Such objection to each interrogatory bears the same number as the numbered interrogatories:
20.
sscoulad,h e ddiissttrriibbuitreHdf,eonr3n u,tsefd?Sbkyer yocuorncecronmipannSy ditfhfeenresnptecipfryodutchtes dmifafneurfeancttured,
products by exact manufacturers name and popular name!
alterant
^
is a difference in your answer depending on the vear or years in
a Partic^lfr Product was used, then specify in detail what Itlr or
and thl ?elreinvolved!S " " d tha specific Products you are referring to
OBJECTION TO INTERROGATOR? NO. 20:
Defendant objects to Interrogatory No. 20 because the question is vague, ambiguous, unclear and misleading in that it talks about "liberating asbestos fibres" without defining the quantities, if millions of fibres were released every second the product was applied or if one fibre was released during a year of application
work, and the answer would be misleading and'prejudicial without an involved explanation.
2 1 . i1: 3 oreseea*>le use of your asbestos-containing insulation products that
they may have to be removed, stripped or replaced at any time after installation-
s L ? a U'nn5?San^ 5 0nCef d5 t!?e Pla*atiff(s) misused any o f your products then
state now ana under what circumstances your product was misused.
OBJECTION TO INTERROGATORY NO. 21:
21(a) Defendant objects because this is a compound interrogatory, containing two separate distinct and unrelated questions,
21(b) Defendant objects to the first question, 'W s it foreseeable," because the question is too vague, indefinite, ambiguous and unclear - foreseeable to whom?; foreseeable when?; foreseeable under what conditions?
Further, the foreseeability relates to whether or not products "may have to be removed, stripped," etc. This would require pure guess, speculation, .conjecture and cannot be answered under oath.
21(c) Defendant objects to the second part of the interrogatory as a plaintiff's "misuse'' would depend upon the circumstances of each case and cannot be answered generally. Examples of raisuseage are continuing to work with asbestos products without use of respirators, and without exhaust fans after warning,
22, Prior to releasing the products listed in Interrogatory No. 6 to the public for sale, were any tests conducted on same to determine potential health hazards involved in the use of materials contained therein?
OBJECTION TO INTERROGATORY NO. 22; '
Defendant objects to Interrogatory No. 22 because this defendant did not sell Insulation products containing asbestos to the "public," therefore the interrogatory requires defendant to assume a fact which Is not true. Products were sold to distributors - contractors who were highly experienced in the insulation field. 56. Give the trade names of your high temperature heat insulation products which
do not contain asbestos, and state fully what such insulation contains. OBJECTION TO INTERROGATORY NO. 56:
This defendant would object to this interrogatory because the question as framed calls for confidential information and trade secrets and this defendant should not be required to reveal the content of any insulation product protected by patent which product does not contain asbestos. This defendant prays for a protective order.
59. In what decade was each of the following products commercially available for use
and sale?
'
(a) Fiberglass;
(b) Calcium silicate; (c) Mineral wool; (d) Rock wool;
(e) Foamglass;
(f) Ceramics;
(g) Wood pulp;
00 Organic pulp.
OBJECTION TO INTERROGATORY NO. 59:
(a) Defendant objects to interrogatory Ho. 59 because this interrogatory is overly broad.
(b) Defendant objects to interrogatory No. 59 because this defendant did not manufacture insulation products containing the materials in (c) (d) (e) (f) and an
answer would involve research and opinions which defendant is not required to answer.
(c) Defendant further objects because any research on items (c) - (h) is a resear work project performed at request of counsel for this defendant after the asbestosis litigation began.
60. List all insulation products sold in the 1940*sT 1950's and 1960's which did not contain asbestos and give the physical and tensil strength and temperature decomposition data for each product.
OBJECTION TO INTERROGATORY NO. 60:
(a) Defendant objects to Interrogatory No. 60 because such calls for an engineerit
study which this defendant is not required to make. Defendant has given the infonaatioi
on all the insulation products manufactured by it containing asbestos and discontinued
the manufacture of asbestos containing insulation products in September, 1971. Defendat
should not be required to research and answer to this question and refuses to do so.
(b) Defendant objects to Interrogatory No. 60 because this question is overly
broad and unduly burdensome and this Defendant could not possibly know or determine
what insulation products were sold in the years set forth which did not contain asbestos
there could have been many or few,
.
64. Was your medical department or industrial health department or industrial hygienist responsible for contracting unit employees?
OBJECTION TO INTERROGATORY NO. 64:
This Defendant objects to Interrogatory No. 64 because it is overly broad and
unduly burdensome and is vague and indefininite in that it asks if the medical departmer
etc. was responsible for contracting unit employees. The question is too vague and
indefininte to make a responsive answer.
69. When did any official with your company first have knowledge, information or understanding that asbestos would or could or might produce the diseases of:
(a) Asbestosis;
(b) Mesothelioma;
(c) Lung cancer:
.
(d) Any other diseases;
(e) With reference to your company give the name of such official who first had such knowledge, information or understanding:
(f) If there are any documents, records or memorandums of any kind concerning such knowledge, list them and attach copies.
OBJECTION TO INTERROGATORY NO. 69:
Defendant objects to Interrogatory No. 69 because the question is too value,
and indefinite and is couched in the terms of when did any official of the company
first have knowledge that asbestos would or could or might produce the diseases
asbestosis, mesothelioma, lung cancer or other diseases. Defendant also objects
because the question is too general and is not related to the asbestos insulation
worker and insulation products containing some asbestos and is therefore too general.
Defendant objects to Interrogatory No. 69(d) Inquiring when did any official
with the company first have knowledge, information or understanding that asbestos
would or could or might produce any other diseases for the reason that the interrogator;
is too vague and indefinite as there is no meaning to the phrase any other diseases
to which this defendant can intelligently respond. 72. Set forth a list of photographs, plats, sketches or other documents in the
possession of the party that will potentially be used as an exhibit at the trial of this case by you.
OBJECTION TO INTERROGATOR? NO. 72: The Defendant objects to this interrogatory because the photographs which will
be used or any exhibits which may be drafted which will be used upon the trial of any
particular case will depend upon the facts in that particular case and there can be
no general answer to such interrogatory. Defendant further objects to answering said interrogatory because these are
matters to be listed in any pre-trial document or pre-trial order and it will depend
upon the facts of each individual case and the nature of the claim as to what document or documents may be used in the trial of that particular case. Defendant prays that it be excused from answering this general interrogatory. 73 Were you or any of your agents, servants, employees aware of any of the articles
described on Exhibit A prior to the year 19507 OBJECTION TO INTERROGATORY NO. 73; This defendant objects to Interrogatory No. 73 for each of the following reasons.
(a) It is too broad in scope. (b) It is too vague and indefinince to require an answer under oath. (c) The period covered by the interrogatory would be between the years 1929 to 1950 and those officers and employees are no longer employed by Fibreboard Corporation
and it would be impossible to determine the knowledge of each and every former officer
or employee of the company. (d) Only those documents found on Exhibit A, Page 1, Page 2 and the first two
articles on Page 3 were published prior to 1950. It would have been impossible to have any knowledge of the documents beginning with Item No, 3 on Exhibit A, Page 3 through the remainder of the document prior to 1950 because they were all published
subsequent to that date, so the question is totally inappropriate.
74. If vou answered the foregoing question "Yes." Then answer the following:
(a)' Set forth such article you had knowledge of and the date you acquired
such knowledge.
OBJECTION TO INTERROGATORY NO. 74:
_
Defendant repeats the same objections to Interrogatory No. 73.
77. Dsooldyoutocoornteenvder thraetachneodne tohfe pyroeumrisaessbesoftosa-nyconortaianllingofintsheulacotnicoenrnpsrodluicsttesdweirne Exhibit B attached hereto? If so, indicate which and explain the factual basis
for this contention.
OBJECTION TO INTERROGATORY NO. 77:
Defendant objects to Interrogatory No. 77 for each of the following reasons:
(a)
The interrogatory is unlimited as to date and therefore does not limit
the consideration of the answers to these interrogatories to any specific case or
any specific claimed exposure and it would be impossible to give an intelligent answer
to said question covering periods of 20 to.25 years or more dating back from 1972.
Respectfully submitted,
WELLER. WHEELUS & GREEN
STATE BAR NO. 21138000
ATTORNEYS FOR THE DEFENDANT FIBREBOARD CORPORATION CERTITICATE OF SERVICE I hereby certifv that a true and correct copy of the foregoing has been mailed to plaintiff's counsel, certified m a i l r e t u r n receipt requested _and to all other interested counsel of record this
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS
IN RE ASBESTOSIS CASES
MASTER SET OF FIBREBOARD CORPORATION'S ANSWERS AND OBJECTIONS TO PLAINTIFFS' MASTER SET OF INTERROGATORIES
1. As to the person answering these interrogatories, state:
(a) Name;
Cb) Title or position with defendant:
(c) Business address:
(d) Length of time employed by defendant:
(e) State year by year all other positions, titles or jobs that person has held with the defendant.
ANSWER:
(a) R. A. Beck.
(b) House attorney.
(c) 22 Battery Street, Suite 404, San Francisco, California, 94111. (d) 30 years.
(e) Chemist Patent Administrator
Patent Attorney
Attorney
1950-- L96 L , 1961-1971 1971-1978 1978-1982
2. State the following concerning this defendant:
(a) Full and correct name:
(b) Principle place of business: (c ) State of incorporation: ( d ) Date of incorporation, and name of corporation: (a ) Is this defendant authorized to transact business in the State of Texas?
If so, state the date such authority was first issued and last renewed:
(f) Does this defendant have an agent, representative or place of business in Texas? If so, state the name and address of such agent, representative, or place of business.
(S) Does this defendant have an agent for service-in the State of Texas? If so, state the name and address of the registered agent.
ANSWER: (a)
Fibreboard Corporation.
(b) 1300 S.W. 5th Avenue, Portland, Oregon, 97201.
(c) Delaware.
(d) This defendant was incorporated in 1917 under the name The Paraffine
Companies, Inc. In 1950, the name was changed to Pabco Products, Inc. In 1956, the
name was changed to Fibreboard Paper Products Corporation, and in 1966, the name was
changed to Fibreboard Corporation.
(e) Yes. Date issued: 1928. Date last renewed: Still in effect.
(f) Defendant has a sales office at 9300 N.W. Freeway, Suite 103, Houston,
Texas, 77092.
(g) Yes, Joe Heffington, 416 Littlefield Building, Austin, Texas, 78701.
3. Has this defendant been sued under its correct name? If not, state the correct legal name of the defendant and provide the information requested in No. 2 above concerning the defendant as correctly named.
ANSWER:
Yes, this defendant's correct legal name is Fibreboard Corporation.
4. Has this defendant ever acquired through purchase, reorganization or merger another corporation, company, or business which manufactured, sold, processed, distributed or contracted to apply insulation products containing asbestos?
ANSWER:
In 1928, The Paraffine Companies, Inc. purchased Plant Rubber and Asbestos
Works, San Francisco, California, which was set up and operated as a wholly-
owned subsidiary. In 1947, Plant Rubber and Asbestos Works was dissolved (as a
separate corporate entity) and The Paraffine Companies, Inc. assumed the manufacturing
of asbestos-insulation products. Simultaneously, the name "Plant" was sold to a
company in Emeryville, California.
5. If the answer to Interrogatory No. 4 is "Yes," then state the following concerning such predecessor:
(a) Full and correct name:
(b) The principle place of business:
(c) State of incorporation:
(d) Date of acquisition by defendant:
(e) Was this business authorized to transact business in the State of Texas?
(f) Attach copies of all papers pertaining to the acquisition.
ANSWER:
(a) Plant Rubber & Asbestos Works. (b) San Francisco, California, (c) California.
(d) 1928, (e) Unknown.
(f) Objection: Unduly burdensome, harassing, irrevelant. 52_ years ago; documents are not readily available.
This happened
6. As to any product containing asbestos in any form, has this defendant, or any predecessor(s):
(a) Ever designed such a product?
(b) Manufactured such a product? (c) Processed such a product?
(d) Sold such a product?
(e) Distributed such a product?
(f) Patented such a product?
(g) ANSWER:
Relabeled such a product which was manufactured, sold, or distributed by another company?
(a) Defendant "designed" the precision molded process for manufacture of insulation.
(b) Yes.
(c) Do not understand the question.
(d) Yes,
(e) Yes.
(f) In the past, defendant has owned patents related primarily to methods of manufacture of such product,
(g) Yes, products were manufactured by this defendant, relabeled and sold to another.
7. If your answer to No. 6(b), 6(d) and 6(e) is "Yes", then give the trade name of the product, the year the defendant or predecessor first sold or distributed such product, and the year the defendant last sold or distributed such product.
ANSWER:
See Exhibit "A" attached. None manufactured since September, 1971.
8. Have any of the products listed above in Interrogatorv No. 6 been altered in chemical composition since first being marketed?
ANSWER:
Yes.
9. If so, please state:
.
(a) The trade name of each such product.
(o) The date each such product was altered.
(c) The nature of the alteration.
(d) The reason for the alteration.
ANSWER:
.
(a) Minor day to day formulation changes of no substantial significance
were undoubtedly made. However, the only major change commenced with a research
project, begun in 1967, to develop substitutes for asbestos fiber in thermal insulation.
Asbestos content was gradually reduced and, in September 1971, all use of asbestos
was discontinued.
(b) See Answer No. 9(a).
,
(c) See Answer No. 9(a).
(d) Information was received which claimed that even the small percentage of
asbestos in these products could be harmful to health if used without respirators
or adequate ventilation.
10. What is the name, address, and the job title of each individual who participated in the design and preparation of manufacturing specifications for each such product?
ANSWER:
We are not certain of the meaning of "who participated in the design and
preparation of manufacturing specifications for each such product." We will presume
it means those personnel who developed the product.
Information not available for Prasco or original 85Z magnesia'product.
Precision molded process for manufacture developed by S. A. Abrahams, believed
to be deceased, R. Lewon, deceased and L. Collogne, present whereabouts unknown.
Other products by the above and/or H. P. Hoopes, former Director of Insulation
Research, now retired, 1160 Oxford Street, Berkley, California; C. E. Miller, former
Research Chemist, deceased; H. L. Weber, former Research Chemist, now in Seattle,
Washington.
11. Do any written memoranda, specifications, blueprints or other written materials of any kind or chracter relating to the design and preparation of said products now exist?
ANSWER:
.
None have been located.
'
12. In so, please state:
(a) List each -written material or document.
(b) (c) ANSWER:
Who presently has possession of each such document. Where is it located.
(a) See Answer to No. 11.
.
(b) See Answer to No. II (c) See Answer to No. 11.
t*le ?fen*aJ first begin selling or distributing insulation
products containing asbestos?
ANSWER:
See Exhibit "A".
asbestos?'331' did ^ deenclan las seH he insulation product which contained
ANSWER: See Exhibit "A".
15. As to the named defendant or any predecessor(s) or acquired business, state tne various types of products, such as blocks, pipe covering, cements, tape, spray on insulation, mastics, and cloth, and in connection with each type ai
for sale UCt* staia ^ow t^la sana was packaged (i.e., bags, boxes, sacks, etc.)
ANSWER:
\
See Exhibit "A" . Defendant manufactured and sold blocks, pipe covering and
insulating cements. Blocks and pipe covering were packaged in corrugated paperboard boxes; insulating cements packaged in bags.
16. Is your company, as of the date of answering these interrogatories, still manufacturing, selling or distributing any insulation products containing asbestos: so, give che brand names of such products, the binding material and date first manufactured.
ANSWER;
No.
17. Were each of your insulation products generally expected to reach, or were packaged to reach, the consumer or user, without substantial change in the conditic m which it was sold?
ANSWER:
Yes, they were packaged to reach the consumer or user without substantial change.
18. If vour answer to Interrogatory No. 17 is "No," with respect to any product,
explain in vnat way the_defendant claims its products were altered or substantial!-
changed after sale or distribution and before reaching the insulation helper or *
mechanic.
*
ANSWER:
Not applicable.
19. Do you admit that asbestos insulation applicators, helpers or mechanics, were foreseeable users of defendant's asbestos-contained insulation products, such as:
(a) Pipe covering:
(b) Blocks;
_
(c) Asbestos cloth:
(d) Mastics:
(e) Spray-on insulation:
(f) Rope or tape:
(g) Asbestos sheeting or millboard:
(h) Cements:
'
ANSWER: (a) Yes. (b) Yes. (c) - (g)
We did not make or sell these.
(h) Yes.
20. Based upon the material contents of your products, the method of manufacturing., of the method of application for the purpose of insulation, can your products be generally applied oy an insulator without liberating asbestos fibers?
(a) If there is a different answer concerning different products manufactured, sold, distributed, or used by your company then specify the different products by exact manufacturers name and popular name.
(b) If there is a difference in your answer depending on. the year or years in which a particular product was usad, than^spacify in detaxi what year or years you axe referring to and the specific products you are referring to and the year involved.
ANSWER:
OBJECTION TO INTERROGATORY NO. 20:
.
Defendant objects to Interrogatory No. 20 because the question is vague,
ambiguous, unclear and misleading in that it talks about "liberating asbestos fibres"
without defining the quantities, if millions of fibres were released every second
the product was applied or if one fibre were released during a year of application work, and the answer would be misleading and prejudicial without an involved explanation
ANSWER SUBJECT TO OBJECTION: As the question is framed in the present tense the answer is "yes."
Defendant's
insulation products have contained no asbestos for the last eleven years (1971-1932)
and thus can be applied without liberating asbestos fibres. If the question is reframed to apply to years prior to 1971 when Eibreboard
Corporation was manufacturing insulation products containing some asbestos, the answer
would have to be "No."
21 Was it a foreseeable use of your asbestos-containing insulation products that they may have to be removed, stripped or replaced at any time after installation; If your company'contends the plaintiff(s) misused any of your products then state how and under what circumstances your product was misused.
ANSWER
OBJECTION TO INTERROGATORY NO. 21;
21(a) Defendant objects because this is a compound interrogatory, containing
two separate, distinct and unrelated questions.
21(b) Defendant objects' to the first question, "was it foreseeable," because
the question is too vague, indefinite, ambiguous and unclear - foreseeable to whom?;
foreseeable when?; foreseeable under what conditions?
Further, the foreseeability relates to whether or not products "may have to be
removed, stripped," etc. This would require pure guess, speculation, conjecture and
cannot be answered under oath.
21(c) Defendant objects to the second part of the interrogatory as a plaintiff's
"misuse" would depend upon the circumstances of each case and cannot be answered
generally. Examples of misuseage are continuing to work with asbestos products
without use of respirators, and without exhaust fans after warning.
22. Prior to releasing the products listed in Interrogatory No. 6 to the public .
for sale, were any tests conducted on same to determine potential health hazards involved in the use of materials contained therein?
ANSWER:
.
OBJECTION TO INTERROGATORY NO. 22:
t
Defendant objects to Interrogatory No. 22 because this defendant did not sell
insulation products containing asbestos to the "public," therefore the interrogatory
requires defendant to assume a fact which is not true. Products were sold to
distributors - contractors who were highly experienced in the insulation field.
ANSWER SUBJECT TO OBJECTION:
'
The high temperature thermal insulation containing some asbestos manufactured
by this defendant comprised a single line of products first sold in the late 1920's
by predecessors, up to September, 1971, the only changes made during that time period v<
reductions in asbestos content.
Defendant has no record of any tests conducted on this line of products prior to
the first sale in the late 1920's, nor does it have any indication that information was available at that time which would have indicated the need for tests.
23. If so, please state:
.
(a) The name, address, and job classification of each individual who conducted such tests.
(b) The results of such said tests.
(c) Date of such studies.
ANSWER:
Not applicable.
24. Do any written memoranda, specifications, blueprints or other written materials of any kind or character exist relating to the testing of such products?
ANSWER:
Not applicable.
25. If so, please state:
(a) List each such written material or document.
(b) ANSWER:
Who presently has possession of each such document and where it is located.
Not applicable.
26. Did defendant or any of its subsidiary companies make any design changes as a result of such' tests?
ANSWER:
Not applicable. See Answer to Interrogatory No. 22.
27. If so, please state:
.
(a) The nature of the change made.
(b) The name, address, and job classification of each person in charge of
making a change.
.
ANSWER:
Not applicable.
28. After releasing said products to the public, were any tests conducted thereon
to determine potential health hazards involved in the use of materials contained therein?
ANSWER:
'
No. When information became available indicating the small percentage of asbestos
in -these products might create sufficient airborne asbestos dust to be a potential
health hazard if respirators or adequate ventilation were not used, defendant chose
to apply a warning and begin research to eliminate asbestos.
29. If so, please state:
(a) The name, address, and job classification of each person conducting said tests.
(b) ANSWER:
The results of said tests.
(a) Not applicable. See Answer to No. 28.
*
(b) Not applicable. See Answer to No. 28.
30. Prior to 1970, did you or your predecessor(s) ever have any labor inspectors
or anyone from your company whose job it was to go to areas where your products
were being used or installed to make a dust level count? If so, state when this
procedure started, the purpose of such procedure, and what action, if any was
taken in response to the findings, and attach results.
t
* .
ANSWER: No, we did not regularly inspect the area where workers were using products
manufactured by our company. Scientists engaged by the United States Government and
others, as well as published literature, indicated that in areas where workers were
using our products dust counts were below the threshold limit values set by the
American Conference of Governmental Industrial Hygienists. As a seller of products,
we had no right to enter a customer's premises for inspection.
31. If your company performed or had performed any dust level counts, what action based on the results did your company take?
ANSWER:
Not applicable. See answer to Interrogatory No. 30.
32. Has your company or its predecessor(s) ever conducted any studies concerning
the effects of the inhalation of asbestos dust or fibers on one using or being
exposed to any of the asbestos materials manufactured, sold or distributed by
you, or your predecessor(s)? In answer to this question, give the date and
_
nature ot such studies, if any; the name or names of the persons conducting suen
studies and their addresses; what the purpose of the studies were; and attach a
copy of any reports based upon such studies, showing to whom such reports were
given, and the date.
ANSWER:
No studies were made directly by this defendant.
33. Has your company or its predecessor(s) ever conducted or caused to be conducted any studies designed to minimize or eliminate the inhalation of asbestos dust and fibers by those exposed to the use of your company s insulation products? If so, give the following:
(a) Name of the person or firm conducting such studies:
(b) The date the studies began and the date completed:
(c) Any publication or dissemination, of the results of the studies: .
(d) The nature of any action to eliminate or minimize inhalation of asbestos dust or fibers:
(e) Attach copies.
ANSWER:
- See Answer to Interrogatory No. 32.
'
34. If your answer to Interrogatory No.33_was "Yes." state the name and address of such industrial hygienist or hygienists.
ANSWER:
Not applicable. See answer to Interrogatory No. 32.
35. Does your company have, has it ever had, or has your predecessor(s) ever had,
a Research Department? If so, give the year such Research Department was
established, and whether or not such Research Department has operated contin
uously since being established.
*
(a) How much expended each year on research, etc.:
(b) What percentage of gross sales did your company or its predecessor spend on research concerning the health effects or asbestos.
ANSWER: Yes, we had and have a company Research Department for our Insulation Division,
since the 1930's or early 1940's until today. With respect to Subparts (a) and (b)
this information has not been retained. 36. State in detail the purpose, duties and responsibilities of such Research
Department.
ANSWER: The Research Department concerns itself with the improvement and development
of insulation products which are manufactured and to be manufactured by the corporation,
37. Does your company have, has it ever had, or has your predecessor ever had, a
Medical Department? If so. give the year such Medical Department was established, and* wh ether o__r. not^ 'such Medical Dn ep.aa rtme*n*t "Uh*as o*peratc>eAd mcnornTtninnnunou s1lvy c sl fit fn' Pc.e hbeei in n2g established. (a) Name each director, chief, or head of your Medical Department year by yezr
with the first year you had a medical director or Medical Department. Give the last known address of each.
ANSWER: Defendant had a medical department from about 1930 until about 1957. (a) Medical Director: Dr. Wahle, 1930's and early 1940 s; deceased.
Plant Physicians, Emeryville Plant: Dr. Henry Perlmuttar, 1940's part-time; present address:
460 Valle Del Oro Road, Tucson, Arizona Dr. Christopher Adamson, 1950's, part-time:
1178 San Pablo Avenue, Berkeley, California
38. State in detail the duties and responsibilities of such Medical Department.
ANSWER:
'
Primarily First Aid.
,,
,q p t Io o to 1965 did vour company, or any predecessor(s), ever at any time give 39' inflation mechanics or S t a t i o n helpers who would be applying or.removing your
products instructions concerning safety precautions to use in applying s products? If so, describe such instructions, to whom they were given, aie cates
they were given, and the manner of giving such instructions.
ANSWER:
No. 40 Did vour company, or vour predecessor (s), ever place any w a n i n g signs on the-
containersin3wnich asbestos insulation products were packaged?
ANSWER:
Yes.
41. It you have answered Interrogatory No. 40 in the affirmative, please state:
(a) On what date did your company, or your predecessor(s), issue an order
directing a warning be placed on your insulation proouCvS,
(b) On what date was such warning actually first placed on your insulation* products or containers?
ANSWER:
Yes, we had and have a company Research Department for our Insulation Division,
since the 1930's or early 1940's until today. With respect to Subparts (a) and (b)
this information has not been retained.
36. State in detail the purpose, duties and responsibilities of such Research
Department,
ANSWER:
'
The Research Department concerns itself with the improvement and development
of insulation products which are manufactured and to be manufactured by the corporation.
37. Does your company have, has it ever had, or has your predecessor ever had, a Medical Department? If so, give the year such Medical Department was established, and whether or not such Medical Department has operated continuously since being established.
(a) ANSWER:
Name each director, chief, or head of your Medical Department year by year with the first year you had a medical director or Medical Department. Give the last known address of each.
Defendant had a medical department from about 1930 until about 1957.
(a) Medical Director: Dr. Wahle, 1930's and early 1940's; deceased.
Plant Physicians, Emeryville Plant:
Dr. Henry Perlmuttar, 1940's part-time; present address:
460 Valle Del Oro Road, Tucson, Arizona
Dr. Christopher Adamson, 1950's, part-time:
1178 San Pablo Avenue, Berkeley, California
38. State in detail the duties and responsibilities of such Medical Department.
ANSWER:
Primarily First Aid.
,
39-, Prior to 1965, did your company, or any predecessor(s), ever at any time give Insulation mechanics or insulation helpers who would be applying or removing your products instructions concerning safety precautions to use in applying such products? If so, describe such instructions, to whom they were given, the dates they were given, and the manner of giving such instructions.
ANSWER:
No.
40. Did your company, or your predecessor(s), ever place any warning signs on the. containers in wnich asbestos insulation products were packaged?
ANSWER:
Yes.
-
41. If you have answered Interrogatory No. 40 in the affirmative, please state:
(a) On what date did your company, or your predecessor(s), issue an order directing a warning be placed on your insulation products, or containers?
(b) On what date was such warning actually first placed on your insulation-
products or containers?
'
(c) On vhat data did your insulation products, accompanied by such warning, first reach the insulation contractor?
(d) State the exact wording of the first warning.
(e) State the exact size of the warning printed on your asbestos insulation products or containers.
(f) Did your company, or its predecessor(s), dictate the exact size of the printed warning?
(g) Why did your company or its predecessor(s) place such warning on your asbestos insulation products or containers?
(h) Did vour company or its predecessor(s) place such warning on your asbestos insulation products or containers because you received a directive, command, suggestion, legal opinion, or any type of communication (written or otherwise) from any person, firm, corporation, governmental agency, committee, association, attorney or institute: If so, from whom and on date did you receive such directive, command, suggestion, legal opinion, or other type of communication.
(i) If the wording of,the warning has ever been changed or.altered, state when it was changed, and the exact change in the wording.
ANSWER: (a) No record or recollection of such date exists. (b) 1966. It was first stenciled on all containers, then a printed
"caution" notice was pasted on; the warning was printed on cartons when cartons were
manufactured.
(c) Unknown: presumed to be L966.
(d) See Exhibit "B". (e) See Exhibit "B". Size may have been changed.
(f) Yes. (g) To alert users of potential hazards.
(h) A combination of factors was involved.
'
(i) Not changed.
42. Did your company or its predecessor(s) ever place any warning directly on any
of its asbestos insulation pipe covering itself, block itself, cloth
itself, or millboard itself?
.
ANSWER:
Warning on containers only. We did not manufacture cloth or millboard.
43. Did your company ever stamp the name of the company, its initials, or any
identifying logo on any o f its asbestos pipe covering, blocks, cloth, or
_
millboard?
ANSWER: Not to the best recollection of employees. We did not manufacture asbestos
cloth or millboard.
44 Did the warning inquired about in Interrogatories Nos. 42 and 43, or similar ' warning, ever appear in any of your sales literature? If so, attach copies of such sales literature, showing the date such literature was printed.
ANSWER:
No, it was never used in sales literature. We did distribute materials from
the National Insulation Manufacturers Association in about 1957.
45. On what date was the sales literature inquired about in Interrogatory No. 44
first provided to distributors or sellers of your company's products, or your
predecessor(s) s products?
*
ANSWER:
Not applicable.
46. Has your company, or your predecessor(s), ever devised a high temperature heat insulation which does not contain asbestos? If so, state tne date that such insulation was first placed on the market.
ANSWER:
'
Yes, this defendant conducted a research and development program from the mid-
1960's to 1971 on asbestos-free high temperature insulations. Such insulation was placed on the market in 1971 and contains no asbestos.
47. Were any material safety data sheets ever prepared by your company or its predecessor(s)? If so, attach copies.
ANSWER:
We do not understand the meaning of "material safety data sheets".
48. Did your company or its predecessor ever recall any products containing asbestos rrora the common market?
(a) State all details of such recall, giving the name of the product, the time of recall and any further action taken in connection with the recall.
ANSWER:
No.
49. Has your company or its predecessor(s) ever directly advised any contractor
to whom you sell your products containing asbestos of threshold limit values for
exposure to asbestos dust recommended by the America Conference of Governmental
Industrial Hygienists? If so, state the date or dates that you so advised such
contractors, the manner in which you advised such contractor, and the name of eacH
contractor.
'
ANSWER:
No, but in about 1967, by recollection of employees, a brochure published by
NIMA was distributed to customers. A copy of this brochure is attached as Exhibit "C " .
50. Prior to 1964 did your company or its predecessor(s) ever manufacture insulation products containing asbestos without a warning? "List the years.
ANSWER;
-
Yes. L928 to 1964.
51. After 1964 did you ever manufacture insulation products containing asbestos without a warning? If so, list the name of the product and the years.
ANSWER:
Yes. Beginning in 1966 through September, 1971, all containers of our
products contained a warning. See attached Exhibit "B".
52. Prior to 1970, did your company, or any predecessor(s), ever manufacture and sell a nign temperature heat insulation which does not contain asbestos? If so, state the date that such insulation was first placed on the market.
ANSWER :
No.
53. Is your company, as_of the date of answering these interrogatories, still manufacturing, selling or distributing any insulation products containing asbestos? Ir so, give the brand names of such products and the binding material and date of first manufacture of such product.
ANSWER:
No, this defendant has not manufactured any insulation products containing
asbestos since September 1971,
54. If your_company, or your predecessor(s), ever devised a high temperature heat insulation which does not contain asbestos, state what nromnted vour company to aevise such high temperature heat insulation not containing asbestos.
ANSWER :
In 1966, (the mid 1960's), medical information and studies began to indicate
possible harm to insulation workers from insulation products containing some asbestos.
Defendant then began research on development of an asbestos-free product.
55. Has such high temperature heat insulation not containing asbestos performed
satisfactorily; that is, is such insulation suitable for the purpose for which it is to be used?
ANSWER:
Yes, although it was not as efficient or strong as the prior product.
56. Give the trade names of your high te n iD e ra tu re heat insulation products which do not contain asbestos, and state fully" what such insulation contains.
ANSWER:
OBJECTION TO INTERROGATORY NO. 56
'
This defendant would object to this interrogatory because the question as framed
calls for confidential information and trade secrets and this defendant should not
be required to reveal the content of any insulation product protected by patent which
product does not contain asbestos. This defendant prays for a protective order,
ANSWER SUBJECT TO OBJECTION:
Fibreboard Corporation has devised a high heat temperature heat insulation which
does not contain asbestos. The trade name is Pahco Super Calteap. Counsel will .
submit to the Court the exact content of the non-asbestos containing insulation and
the Court can determine whether it is necessary to release this confidential informatici
to plaintiff's counsel.
"
57. State the decade that there first existed manufacturing technology for commercial purposes the use of chemicals and minerals for combining into a nigh heat insulatir product a substitute for asbestos in insulation materials.
ANSWER;
' >
This question does not make sense. We developed a substitute in 1971.
5S. To yur company's knowledge, in what decade was fiberglas first commercially available for insulation over 350 F.?
ANSWER:
Not known, this would require research on the part of Defendant and opinions which this Defendant is not required to answer.
59 and^sale^^3^6 was eac^ -f the following products commercially available for use
(a) (b) (c) (d) (e) (f) (g) (h) ANSWER:
Fiberglass; Calcium silicate; Mineral wool; Rock wool; Foamglass; Ceramics; Wood pulp; Organic pulp.
OBJECTION TO INTERROGATORY NO. 59
(a) Defendant objects to interrogatory No. 59 because this interrogatory is overly broad.
(b) Defendant objects to interrogatory No. 59 because this defendant did not manufacture insulation products containing the materials in (c) (d) (e) (f), and an answer would involve research and opinions which defendant is not required to answer.
(c)
Defendant further objects because any research on items (c) - (n) i's a resear<
work project performed at request of counsel for this defendant after the asbestosis litigation began.
ANSWER SUBJECT TO OBJECTION:
(a) See Answer to Interrogatory No. 58.
(b) First commercially available, containing asbestos in 1940's, from others.
commercially available without asbestos in 1971, from this defendant
only, as Pabco Super Caltemp.
60. List all insulation products sold in the 1940's, 1950's and 1960's which did'not
contain asbestos and give the physical and tonsil strength and temperature ---
decomposition data for each product.
^
ANSWER:
OBJECTION TO INTERROGATORY NO. 60:
(a) Defendant objects to Interrogatory No. 60 because such calls for an engineeri:
study which this defendant Is not required to make. Defendant has given the ;informariot on all the Insulation products manufactured by it containing asbestos and discontinued
the manufacture of asbestos containing insulation products in September, 1971, Defender
should not be required to research and answer to this question and refuses to do so.
(b)
Defendant objects to Interrogatory No. 60 because this question is overly
broad and unduly burdensome and this Defendant could not possibly know or determine
what insulation products were sold in the years set forth which did not contain asbesto;
there could have been many or few,
_
61, Did your company or any predecessor(s) ever have a division or subsidiary company engaged in tne contracting business of applying insulation products? If so, give the name of such division or subsidiary company, the full address of the home office of such division or subsidiary company, and the dates such division or
subsidiary company was engaged in the contracting business.
ANSWER:
Prior to 1947, a wholly-owned subsidiary of this defendant named Plant Rubber &
Asbestos Works did some contracting work. This subsidiary was dissolved in 1947. Durit
the period 1959-1961, a wholly-owned subsidiary named Pabco Insulation Corporation did
contracting work. This subsidiary was dissolved in 1961.
62. Did any division of your company or subsidiary company engaged in the contract business of applying insulation products or your workmen's compensation insurance carrier ever have any claims for lung diseases or death from lung diseases, whethei directly or indirectly attributed to asbestosis, mesothelioma, lung cancer, or any
exposure to asbestos products prior to 1972? If the answer is "Tes," give the nam of such employees and attach copies of such claims and copies of all documents relating to tne disposition and handling of such claims.
ANSWER:
Retained records of this defendant do not distinguish among types of employees;
thus, the question cannot be answered from available information. Workmen's Compensatic
records will be made available for inspection at a reasonable time upon request.
63. Give the location of the state industrial accident board handling each such claim, the disposition of such claims, and the amounts paid in workmen's compensation benefits to each such employee, and the name of the compensation carrier.
ANSWER:
See answer to Interrogatory No. 62.
64. Was your medical department or industrial health department or industrial hygienist responsible for contracting unit employees?
ANSWER:
OBJECTION TO INTERROGATORY NO. 64:
This Defendant objects to Interrogatory No. 64 because it is overly broad'and
unduly burdensome and is vague and indefinite in that it asks if the medical department
etc. was responsible for contracting unit employees, -The question is too vague and
indefinite to make a responsive answer.
65. Did your company or its predecessor(s) ever make any_industrial hygiene surveys? If so, give the date of such surveys, and attach copies of such surveys.
ANSWER:
.
'
None were made. V
66. State the year that this defendant or any predecessor(s) was first advised of either threshold limit values or maximum allowable concentrations o both asbestos dust and total dust by the American Conference of Governmental Industrial nygienists, ana state the name of the employee-official of the company receiving such advice and attach copies of the instrument communicating such advice.
ANSWER:
Defendant through its employees had general knowledge of recommended Threshold
Limit Values from the late 1960's. Name of the specific employee is not recalled; perh
Mr. H. P. Hoopes, now retired, of 1160 Oxford Street, Berkeley, California. No
written instrument has been located.
-
67. Was such threshold limit values or maximum allowable concentrations inquired about in Interrogatory No. 66 TOTAL dust and not just asbestos dust?
ANSWER:
Asbestos dust.
68. State in detail what test, if any, your company ever made with regard to the quantity, quality of threshold limit values of asbestos dust or particles to which insulators were exposed while using your products containing asbestos.
(a) ANSWER:
If there were any such tests or studies, give the-name or names of the
person(s) conducting the tests, the date of the tests and attach true
copies of any reDorts, findings or memorandums concerning such tests
or studies.
`
No tests have been made by this Defendant.
Beginning-in 1966, containers of our products had the following warning labels on them: "CAUTION. This.product contains asbestos fibers.. If- dust is created when
this product 'is; handled-,: avoid breathing the'.dust;- If adequate ventilation control
is not possible, wear; respirator .approved-- by- Ur -S. Bureau of Mines."
We-were of the opinion that contractors' engaged, in th*;Jtojyiiai^:b.^Aesst and insulation workers, were well aware of the- prablemureatedby. inhalatibn-ofdust, and
that respirators or masks had been in use by asbestos worker's^ o^a-^ndmberiof .years.
69. When did any official with your company first have knowledge, information or understanding that asbestos would or could or might produce the diseases of:
(a) Asbestosis;
(b) Mesothelioma;
(c) Lung cancer;
'
(d) (e) (f) ANSWER:
Any other diseases;
With reference to your company give the name of such official who first had such knowledge, information or understanding;
If there are any documents, records or memorandums of any kind concerning such knowledge, list them and attach copies.
OBJECTION TO INTERROGATORY NO. 69:
:
Defendant objects to Interrogatory No. 69 because the question is too vague,
and indefinite and is couched in the terms of when did any official of the company
first have knowledge that asbestos would or could or might produce the diseases asbestosis, mesothelioma, lung cancer or other diseases. Defendant also objects because the question is too general and is not related to the asbestos insulation worfce and insulation products containing some asbestos and is therefore too general.
ANSWER SUBJECT TO OBJECTION: (a) Insofar as can be determined from corporate records, the first knowledge
of an actual case of asbestosis was in 1957 when an employee who had worked for many
years in very dusty insulation manufacturing operations, including the use of pure
asbestos, developed asbestosis. However, this type of exposure was regarded as
entirely different from that of users of products containing a small percentage of
asbestos. (b) (c)
Defendant has been unable to determine a specific date or the approximate
date it might have heard of an association between the inhalation of asbestos fibers
and the contraction of lung cancer, nor do we have a specific recollection of its source. We believe that we may have heard of the claims of the possibility of such
associations in the late 1960's; the course may have been the articles published by
Dr. Irving J. Selikoff, who first reported there were no greater incidences of lung cancer in asbestos insulators who did not smoke cigarettes than the average American, f
There ware increased instances of lung cancer in smokers, and further increased incidences of lung cancer in smokers who were insulators exposed to asbestos dust.
According to these reports of Dr. Selikoff, claims of an association of exposure to
asbestos insulation products with mesothelioma occurred at the same time.
(d)
Any other diseases - Defendant objects to Interrogatory-No. 69(d) inquiring
when did any official with the company first have knowledge, information or understand!: that asbestos would or could or might produce any other diseases for the reason that
the interrogatory is too vague and indefinite as there is no meaning to the phrase
"any other diseases" to which this Defendant can intelligently respond. (e) Referring to (c) above, Ms. Dorothy Hansen, retired, 575 Corbett St.,
San Francisco, CA.
Referring to (b), (c) Mr. F. A. Nordstrom, retired, P. 0. Box 970,
.
Murphy's, CA, or H. P. Hoopes, retired, 1160 Oxford St., Berkeley, CA. (f) A corporate file exists as to (a) above, which may be examined at a
reasonable time. As to (b) and (c), see publications by Dr. Selikoff et al. 70. Asstatteo esvpeercyifipcrodtuycpte oofr ytoyupress wohficahsbeysotuosh,ave(I.ied.e,nticfrioecdidoilnitper,evicohursysoitnitleer,rogatories
amosite or any others) wnich your products contained. If you have any percentage figures available, then give the percentage as to each product.
ANSWER:
See Exhibit "A".
_
,,
Up to September, 1971, products contained either amosite, a mixture of amosite ana
chrysotile or chrysotile asbestos. We did not manufacture products containing asbestos
after September, 1971. 71. Does defendant contend that plaintiff.improperly used its products.
ANSWER: We don't know if Plaintiff used our product.
Such interrogatory cannot be
answered generally. As to individual plaintiffs, it can only be answered after
discovery.
trial of this case by you.
ANSWER:
OBJECTION TO INTERROGATORY NO. 7_2:
_
__
The Defendant objects to this interrogatory because the photographs which will
be used or any exhibits which may be drafted which will be used upon the trial of any
particular case will depend upon the facts in that particular case and there can be
no general answer to such interrogatory.
Mf.nj . n t fntthnt object. to ..rins . . U int.trogatoty bec.uee
re
natters to b. listed in euy pre-triol doonm.nt or pre-Kiel order end it nil depend
open the foots of each individual cese end the neture of the c l a m as to hat
document or documents -ay be used in the trial of that particular case. Bef.ndant
prays that it be excused from answering this general interrogatory..
73` a r tic le s S L S ib S S K x h l b f t l p r f o f t h e ^ e f r ^ f S ? " f " T f ^
ANSWER:
7~Z I OBJECTION TO INTERROGATORY NO. 73:
This defendant objects ,,tao jInnrtfenrrrroogeaattoorryv Nio . 73 for each of the following reasons: (a) It is too broad in scope. (b) It is too vague and indefinite to require an answer under oath. (c) The period covered by the interrogatory would be between the years 1929 -to 1950 and those officers and employees are no longer employed by Fibreboard Corporation and it would be impossible to determine the knowledge of each and every former offxcer
or employee of the company. (d) Only those documents found on Exhibit A, Page 1, Page 2 and the first two
articles on Page 3 were published prior to 1950. It would have been impossible to have any knowledge of the documen beginning with Item No. 3 on Exhibit A, Page* 3 through the remainder of the document prior to 1950 because they were all published subsequent to that date, so the question is totally inappropriate.
ANSWER SUBJECT TO OBJECTION:
Defendant has no record and has no recollection of any such awareness.
74. If you answered the foregoing question "Yes." then answer the following: (a) Set forth such article you had knowledge of and the date you acquired such knowledge.
ANSWER:
'
OBJECTION TO INTERROGATORY NO. 74:
Defendant repeats the same objections to Interrogatory No. 73.
ANSWER SUBJECT TO OBJECTION:
See answer to Interrogatory No. 73.
75. As of January 1, 1965, what quantity of the following asbestos-containing insulation products were stored in your warehousing tacility or facilities awaiting sale to contractors or other concerns:
(a) Pipe covering (state figure and number of boxes);
(b) Block (state figure and number of boxes);
(c) Cement (state figure and number of bags),
ANSWER:
As to (a), (b) and (c) we have no inventory as of January 1, 1965, giving the
quantity of pipe covering, or block, or cement which was in warehousing facilities
at that time and therefore the interrogatory cannot be answered.
76. Do you have any photographs of the products inquired about above or their packages or containers? If so, please attach exact copies.
ANSWER:
See answer to No. 75.
We do not have photographs of the packaging containers inquired about which
were in our warehouse in 1965.
'
77. Do you contend that none of your asbestos-containing insulation products were sola to or ever reached the premises of any or all of the concerns listed in Exhibit B attached hereto? If so, indicate which and explain the factual basis for this contention.
ANSWER:
OBJECTION TO INTERROGATORY NO. 77:
Defendant objects to Interrogatory No. 77 for each of the following reasons:
(a) The interrogatory is unlimited as to date and therefore does not limit _
the consideration of the answers of these interrogatories to any specific case or
any specific claimed exposure and it would be impossible to give an intelligent answer
to said question covering periods of 20 to 25 years of more dating back from 1972.
ANSWER SUBJECT TO OBJECTION; Yes, Fibreboard Corporation did not sell directly to industrial plants but sold
to insulation contractors. No asbestos-containing products were manufactured after
September, 1971. You have asked defendant to explain the factual basis for this
answer and we will give several examples.
Regarding Consolidated Shipyard, Orange, Texas, there have been a number of
cases filed by individual plaintiffs contending they were exposed to certain products
at the Consolidated Shipyard, Orange, Texas, during World Warr II. Fibreboard
has at all times denied that its product was used in this shipyard. All testimony
of all witnesses to counsel's knowledge has been that no one has ever identified a
Fibreboard Corporation product at Consolidated Shipyard. This defendant has refused
to settle or contribute to any settlement of any case originating from exposures at
Consolidated Shipyard.
Regarding Union Oil, Fort Neches, Texas, this defendant's counsel has made
extensive investigation at this plant and it has been determined that Fibreboard
Corporation products were not used by Union Oil Company prior to June of 1972.
Another example is that the two main suppliers of the Texaco Refinery in Port
Arthur, Texas, were Thorpe Insulation, Houston, Texas, which was a distributor for
Johns-Manville Products, and Sabine Insulation, which was largely a distributor
for KAYLO or Ovens-Corning Products.
Fibreboard Corporation did not sell products to Texaco Refinery, Port Arthur,
Texas; Gulf Oil Corporation, Port Arthur, Texas; or Arco Polymers Refinery, Port
Arthur, Texas.
,
Respectfully submitted,
WELLER, WHEELUS & GREEN POST OFFICE BOX 350 BEAUMONT, TEXAS 77704-0350
Y. GEORGE ~WELLER
STATE BAR NO. 21138000
ATTORNEYS FOR DEFENDANT FIBREBOARD CORPORATION
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been
mailedj ,t--o plaintiff's counsel, .coerrttiiffiioejd mmaa-isil, returju>teceipt requestedj and
to all other interested counsel of record this
day
,_J.983,
<r
GEORGE L WELLER
STATE OF CALIFORNIA ) SS.
COUNTY OF SAN FRANCISCO )
ROBERT A. BECK, being first duly sworn and under oath, does depose and say that he is an employee of the defendant, FIBREBOARD CORPORATION, and is duly authorized to make the foregoing Answers to Interrogatories; that he does so acting on such authority and authorization; and that he has read over the foregoing Answers and the same are true and correct to the best of his information and belief. The Answers are based on information secured from various sources within the company and otherwise.
ROBERT A. BECK
SUBSCRIBED AND SWORN TO
before me by the said ROBERT A. BECK,
to certify which witness my hand and
{'Seal of office on this
day of
INSULATION PRODUCTS
Since 1948, Insulation products have been sold under the trade name,
"PABCO*. Prior to 1948, all insulation products were manufactured and
sold by a wholly-owned subsidiary under the name, "PLANT*. Unless
otherwise noted, products were sold as blocks, pipe covering' segments
and insulating cements. Products contained chrysotile or amosite
asbestos or'mixtures thereof, No asbestos in any products manufactured
after September, 1971.
BRAND NAMES; 1. PRASCOi
85%'diatomaceous earth and binders; 15% asbestos;
manufactured from about 1923 to 1957.'
2. 8S% MAGNESIA; 8SV basic magnesium carbonate; 15% asbestos;
manufactured from about 1958 - 1966.
3. FI: Insulating cement only; 95%+ calcium silicate, 5%- asfcescc:
manufactured 19S3 - 1966
4- NO.' 127; Insulating cement only, same as FI, hut no asbestos
after September, 1971; manufactured from 1966.
5. CALTBMP: 88%+ calcium silicate, 12%- asbestos. (called
Caltherm in 1952). Manufactured from about 1952 through 1968.
6. SUPER, CAITFMP;; Primarily calcium silicate; asbestos content
was gradually decreased from about 10% in 1968 to about 3-1/2%
in 1971. All asbestos removed from product in September, 1971.
Manufactured from about 1968 to date.
MOTS; From i960 to 1972, defendant manufactured "XAYLO" for Owens
C o m i n g Fiberglas under a rebrand contract to OCF's specifi
cations and packaged in OCF's containers for the 13 western
states. From 1964 to 1972, "LX" Insulation was manufactured for
Armstrcng Contracting & Supply under a similar contract for
the west and midwest.
From 1968 to 1971, "PYROCAL" insulation was manufactured_for
. PPG Industries under a.similar, but oral, contract.
Formulas for the three preceding products were the same as
Caltemp or Supercaltemp made at the same time; blocks and
Pipe Covering only.
In a recent deposition of a prior employee, testimony was giver,
that in the early l?40s, an aircell product containing 'asbestos
was sold under the name, "PLANT*. Precise composition is not
known.
OTHER PRODUCTS
At tiroes in the past, certain other products containing
asbestos -were made and sold by this Defendant. Very little
information remains with respect to these products, but the
following is known:
.
`
1. At some time in the 1950s, it is believed for only a
short tiros, a floor covering containing asbestos was made and sold.
2. From about 1948 until about 1962, shingles and siding
made from Portland cement and asbestos were made and sold.
3. At tiroes not specifically known between the late 1340s
>
v
and about 1969, Defendant made and sold rolls'of what is commonly
called "tar paper" comprising a base~`sheet-saturated with asphalt.
In some instances, the base sheet was made of asbestos. roof patching compound contained some asbestos.
Also, a
4. Information indicates a paint product containing some asbestos was also made and sold. Further information not available
All of the foregoing were sold under the brand name, "PA3CO".
i.
=*x ,*T;.rrr
d. the name and address of any intermediate supplier or distributor who sold this defendant's products to plaint;:': 1s employer during che peri id referred ce amove;
insignia on th'e packages of asbestos containing insulation products that it distributed and sold? If so, describe the type of logo or insignia which was used, indicate which products it was affixed to, and set forth the inclusive dates that each insignia or log was utilized. Annex hereto a photograph or copy of each such logo described in this matter;
f. please describe in detail the type of packages in which defendant has sold, distributed or manufactured asbestos material, listing the dates each type of package was used, a physical description thereof and description of any printed material or trademark that appeared thereon.
ANSWER: and C.15.
See answer to Interrogatory Nos. B.19., C.6., C.9 ..
Asbestos containing pipe covering and block were wrapped with kraft paper and sold in cardboard boxes. Asbestos cements were sold in multi-ply kraft paper bags and heavy duty, polyethylene bags. Asbestos yarns were wound on paper tubes and shipped in fiberboard cartons or wooden boxes. Asbestos cloth was rolled, wrapped in laminated kraft paper, and tied with tape or twine. The roll was then placed in burlap tubing. In later years, the burlap tubing was replaced by reinforced paper.
Asbestos tubing, depending on the specified size, was packaged on spools, wound on reels or cut to specified lengths, and placed in fiberboard cartons. Asbestos tape was rolled, bound with white twine, and placed in fiberboard cartons. Asbestos sheeting was rolled on tubes then wrapped in laminated kraft paper, tied with tape then placed in fiberboard cartons with paper lining between each roll. Larger sheets, which were individually wrapped in kraft paper, were placed in corrugated fiberboard cartons or placed in wooden crates
Printing on the cartons or bags usually included the J-M logo, the name* "Johns-Manville:i, the product name, the size and the weight. Additional language may have been used from time to time. Photographs and product literature are located at the document repository maintained by the Fund in Denver, Colorado, and will be produced at a time agreed upon by the parties.
C.8.
Have any of the products listed in Interrogatory
C.7. above been altered in chemical composition since being
marketed? If so, set forth the following information:
66
a . the date of each alteration;
'
b.
h L * 3 v"= '*" ' *
a detailed description of ode oacure of - oo
c. the reason for such alteration.
ANSWER: The Fund is not aware of particular uses of Manville asbestos and asbestos containing products by plaintiff's employer that might have altered the chemical composition of the asbestos sold by Manville Corporation or related entities.
C.9.
Have you discontinued manufacturing and/or
distributing and/or supplying or selling any asbestos or asbestos
products referred to in C.7.? If so, set forth the following
information:
a. what such product is;
b. the reasons therefor;
c. when the discontinuance took place.
If your answer to C.6. is either "No" or "unknown" but your
answer to E>.14. is "Yes" provide answers to c.io. through C.18
Otherwise you may proceed to C.19.
'
, ANSWER: Yes. Manville Corporation or related entities discontinued the manufacture of most asbestos containing thermal insulation products in the 1972 to 1973 time period. See Exhibit
A for dates of manufacture. These products were discontinued in part due to concerns about the health consequences of occupational exposure to asbestos. Manville Corporation or related entities developed asbestos free replacement products for many of the
asbestos containing products which were manufactured previously. No asbestos containing products have been manufactured by Manville since 1985.
With respect to asbestos fiber, Manville Corporation sold its
interests in asbestos mining and milling operations in 1983, and
has not sold asbestos fiber since that date.
'
C.IO.
Give a complete and detailed description of each and
every asbestos containing product that your company has designed,
manufactured and distributed into the stream of commerce. Include
in your description the trade, brand and generic names of each such
product and indicate the type and amount of asbestos that was
contained in each particular product. Include in this answer the
inclusive dates that each particular product was manufactured and
distributed.
ANSWER:
See answer to Interrogatory No. C.9.
67
_ C,1A
With reference to your answer to B.1 3 . state the
arr.es and addresses of the entities to v.-hom the products ;ara SC "'j
A ''S ~ 0
^ *-> q * ^ 1
. 5 ' 1 2 ' , Dld .your company and/or its affiliates or subsidiaries do business with or utilize any distributors in the
State. of
Jersey for purposes of selling or installing its
asbestos products? If so, identify each such entity, indicate and
f f f h 16 "a!ure,, 0 the business that you did with each s u S entity, and set forth the dates this business relationship existed."
ANSWER; The following organizations were New Jers^v
distributors of asbestos containing products manufactured bv
Manville or related entities: Seashore Supply company; L & H
Piurobing & Heating; Porter-Hayden Company; s. Franklin & sons
Medford P i u m b m g supply; Fiber Flex, Inc. ; York Sheet
'
K l t a e r n t ^ ^ P rr t i 0 n ; Wallwork Somerset; Dumphey Smith Company;
Cfflpany; United Suppiy company; Viking Insulatioi; SJB Pipe, Wallwork Brothers. See answer to Interrogatory No. B.40.
S'13' Vw Has your COInPany ever employed any employees or salesmen whose responsibility it was to sell your company's the stfte C0fn wainiTn9 prducts t0 a geographical area encompassing the State of New Jersey? If so, for each such employee or salesman hie nemeetnd0 eddres3C."Pny ' lndiCat6 tha dataS his " P ^ e n t ,
^ ANSWER: The following individuals were responsible for sales of asbestos containing products in New Jersey:
Percival Coggins 3993 Park Avenue Seaford, n y 11783
A1 Feininger 909 Midland Avenue Yonkers, NY 10704
August Pocius 113 Camino Trail Pontre Bedra Beach, FL 32082
Dudley G. Porter 909 via Tuins P.0. Box 1324 Puntagorda, FL 33950
Thomas P. Williams 2261 s. Interlocken Drive Evergreen, CO 80439
68
J
mannerc. 14:n. nicGhiveyouar cocmopmlpeatney apnadckdaeateadileedachdesocfriptthieon of he
c o n t a m i n e products that t r.anu-racture'd ar.d/cr distric
asbestos ci in the
~ " 2 CT
I*2 T 3 2 1'. I
;do__ - _
packaging teat -.'as ..sea a: u t.'.e c a__t e n a , eac.r
comprised of.-
----
ANSWER: See answer to Interrogatory Nos. C.7 and c.is,
rr q
C !15, _ Did yur company affix its corporate loqo o
insignia on the packages of asbestos containing products that i
distributed and sold in the state of New Jersey? if so describe
the type of logo or insignia which was used, indicate which
products it was affixed to, and set forth the inclusive' dates'ha
each insignia or log was utilized. Annex hereto a photograph or
copy of each such logo described in this answer.
^ g r a p n or
. ^wANSER: I e s ' Photographs of various products are located
at the document repository maintained by the Fund m Denver
Colorado, and will be produced at a time convenient to the parties'
See also answers to Interrogatories No. B.39"and No. c.7.
'
C*16.
Did the packages or containers for the asbestos
containing products that your company sold or distributed in the
State of New Jersey contain any writing or labels? If so, for each
such package or container which contained a label, set forth the
following information about the writing on the package or label:
a. the size of each label;
b. the substance of all writing on the label;
c. the inclusive dates that each writing or label
appeared on each type of product?
.
. . , ..
annex hereto copies of or photographs of each such
label that your company used.
ANSWER: and C.15.
See answer to Interrogatory Nos. B.19., B.39., c.7.
C.17.
Give a complete and detailed description of each and
every asbestos containing product that your company has designed
manufactured and distributed into the stream of commerce. Include
m your description the trade, brand and generic names of each such
product and indicate the type and amount of asbestos that was
contained in each particular product. Include in this answer the
inclusive dates that each particular product was manufactured and distributed.
69
ANSWER: See answer to Interrogatory No. C.9. for information regarding asbestos containing products manufactured by Manville Icrpcration or related entities. The following list nroviaes
PRODUCT DESCRIPTION AND USE
SHEETS AND BLOCKS
85% Magnesia - A high temperature insulation, composed of carbonate of magnesia and asbestos fiber, for service up to 600 degrees F.
ASBESTOCEL - An inexpensive insulation constructed of alternating layers of plain and corrugated asbestos paper for temperatures up to 300 degrees F.
Air-Cell - Very similar to ASBESTOCEL, constructed of alternating layers of plain and corrugated asbestos paper.
Asbestos. "Navy Brand" FIRE FELT - A special-grade of insulation, particularly adapted for marine work, or wherever a light weight insulation may be required.
Asbestos FIRE FELT - Insulating material made from felted and molded asbestos fiber for temperatures up to 1000 degrees F.
Asbestos Molded Blocks - Composed of a mass of felt-like asbestos fibers closely cemented together with a non-conducting compound.
Asbestos Sponge CFelted. Sectional. Molded) - -An insulation made of layers of thin felt, composed of .asbestos.fiber and particles of finely ground spongy material forming''an extremely cellular felt, built up like a book in laminated form, thereby, confining a large volume of minute dead air cells in the felt and between the layers; for temperatures up to 700 degrees F.
EQUALITY - A material consisting of 50% carbonate of magnesia combined with asbestos and other fire-proof materials. It is especially manufactured to meet government specifications.
Flexible MIN-K - A fibrous insulating material designed principally for use on rockets, missiles, and jet aircraft; can withstand high heat and has an extremely low thermal conductivity.
High Temperature Insulation - Composed of a refractory material base of high insulating value combined with asbestos fiber and some carbonate of magnesia.
MAGNO - Consists of 35% carbonate of magnesia combined with asbestos fiber and other insulating materials. It is particularly
70
i J
adaptable for insulating heating systems and is specified by '1.S . and state governments for this purpose.
_20L - A molded fibrous insulating
principally fir -se :n rorheos, missiles, an
..lcnstand u-g.. .".eat
isgre^s c , -*'-* `-v
thermal conductivity.
MIN-K 2000 - See MIN-K 1301; can withstand heat to 2000 degrees F.
MIN-K 500 - See MIN-K 1.301; can withstand heat to 500 degrees F.
SONTTE - Made of MIN-K insulation and used by the U.S. Navy as an underwater sound insulation.
s u p e r EX 1900 - A high temperature insulation for service up to 1900 degrees F made from asbestos fiber, diatomaceous silica, and other insulating materials.
SUPEREX 2000 - A high temperature insulation for service up to 200C degrees F; replacement product for SUPEREX 1900, with asbestos removed by 1973.
SUPEREX-M - A high temperature insulation for service up to 1600 degrees F made from asbestos fiber, diatomaceous silica, and other insulating materials; replaced by asbestos free SUPEREX 1600 in 1973.
SUPEREX SG - A block of SUPEREX insulation bonded to a fiberglass blanket.
Si H e a t e d THERMOBESTOS - Dry granular sodium silicate added to THERMOBESTOS. See THERMOBESTOS.
Super FIRE FELT - A lighter weight variation of Asbestos FIRE FELT; temperature limit of 700 degrees or 1000 degrees F, depending on constr iction.
THERM-O-BESTOS - A waterproofed asbestos material of high insulating value used for building underground conduit systems designed to house hot lines.
THERMOBESTOS - A high temperature insulation, made from lime, diatomaceous silica, and asbestos fiber, for service up to 1200 degrees F.
Thermo FIRE FELT - Similar to Asbestos FIRE FELT, except that it has a cellular asbestos structure completely enclosed in the center of the sheet, giving it increased efficiency and resiliency; for temperatures up to 1000 degrees F.
71
VITRIBESTOS - Made of asbestos felts which have been corrugated and built up to fora a cellular sheet, then vitrified to make then mors resistant to moisture and high temperature. The vitrified product r.as lower insulating value tnan untreated prccucts. Vsed :cr
vnerever a strong, stiff product is required m a t will resist temperatures up to 800 degrees F.
Vitro FIRE FELT - similar to Thermo FIRE FELT except that the cellular asbestos structure is vitrified to increase rigidity.
SECTIONAL PIPE INSULATION
85% Magnesia - See 85% Magnesia under SHEETS AND BLOCKS.
ANTI-SWEAT - Made from water-proof insulating paper and wool felt, it prevents condensation from cold water pipes by insulating the pipe from warm air.
AQUA Covering - Solid laminations of wool felt one-half inch thick with one layer of asbestos paper. See Wool Felt Sectional Pipe Insulations.
ASBESTOCEL - See ASBESTOCEL under SHEETS AND BLOCKS; in this design, the air channels run around the pipe instead of lengthwise, which prevents the circulation of air.
Air-Cell - See Air-Cell under SHEETS AND BLOCKS; in this design, the air channels run lengthwise, parallel to the pipe.
Asbestos "N a w Brand" FIRE.FELT Covering - See Asbestos "Navy Brand" FIRE FELT under SHEETS AND BLOCKS.: '.:
Asbestos Air-Chamber Covering - Formed by layers of fire-proof Asbestos Lining Felt, Hair Felt, Asbestos Sheating, and canvas. An additional layer of Hair Felt and Asbestos Sheating form Double Air Chamber.
Asbestos Combination Spiral Pipe Insulation - Consists of a layer
of CEILINITE (see under PAPER, FELTS, BLANKETS) over which is
wrapped a layer of asbestos listing. Used on irregular runs of
pipe, or where severe vibration is encountered, as an automobile exhaust pipes and on locomotives; temperature limit of 1000 degrees
F.
Asbestos FIRE FELT Covering - See Asbestos FIRE FELT under SHEETS AND BLOCKS.
Asbestos Molded Sectional Covering - See Asbestos Molded b l o c k s under SHEETS AND BLOCKS.
72
Asbestos Sectional Covering - composed of a fire-proof con-
conducting lining of asbestos, surrounded by alternate layers or
asbestos and non-conducting felt.
.
under SHEETS AND 3L0CKS.
Asbestos and Hair Felt Removable Covering - A form of Air Chamber Covering composed of standard hair felt with an inner layer of asbestos fiber of equal thickness, the whole enclosed in a strong wrapper or case of wool sheathing and a lining of asbestos
sheathing.
Asbestos Hair Felt Covering - Consists of layers of Asbestos Hair Felt, composed of long fiber asbestos and cattle hair, built up on the pipe.
CHAMPION Sectional Covering - Solid laminations of wool felt threequarters of an inch thick with one layer of asbestos paper. See Wool Felt Sectional Pipe insulations.
EQUALITY - See EQUALITY under SHEETS AND BLOCKS.
EUREKA Covering - Made of one-quarter inch asbestos felt on the inside of the section, and the balance (three-quarters of an inch) of alternate layers of asbestos and wool felt.
EXPRESS Covering - Solid laminations of wool felt three-quarters of an inch thick with one layer of asbestos paper. See Wool Felt Sectional Pipe Insulations.
F i n e corrugated ASBESTOCEL - Similar to ASBESTOCEL, except the
corrugations are smaller; however, there are 50% more laminations
per inch of thickness and the additional small enclosed air cells
provide greater efficiency.
'
High Temperature Insulation - See High Temperature Insulation under SHEETS AND BLOCKS.
INDENTED - Made up of several layers of pure indented Asbestos Felt, wire stitched together; the indentations cause air spaces to be formed between the layers, improving insulating efficiency.
MAGNO - See MAGNO under SHEETS AND BLOCKS.
METAL-ON - THERMOBESTOS pipe insulation with a factory applied jacket of aluminum; joints are sealed with special aluminum "snapstraps'1 and metal bands.
NATIONAL Sectional Covering - Composed of corrugated soft wool felt, lined on the inside and alternated for three layers with
73
asbestos lining felt; an economical covering for use on low pressure steam lines.
?ERFrC'r'T'''N Sect'cr.a1 Cc''srmcj - Zorcossd of one-naif men. _nda road
STANDARD Sectional Covering - Solid laminations of wooi felt one inch thick with an interlining of two layers of asbestos paper. See Wool Felt Sectional Pipe Insulation.
BUPF.REX 1900 - see SUPEREX 1900 under SHEETS AND BLOCKS.
SUPEREX-M - See SUPEREX-M under SHEETS AND BLOCKS.
safety Blow-Off Covering - Protects boiler blow-off pipes against corrosion by hot gases and prevents explosions resulting from sudden changes of temperature when operating boilers.
Silicated THERMOBESTOS - See Silicated THERMOBESTOS under SHEETS AND BLOCKS.
THERM-O-BESTOS - See THERM-O-BESTOS under SHEETS AND BLOCKS.
THERMOBESTOS - See THERMOBESTOS under SHEETS AND BLOCKS.
VTTRIBESTOS Covering - See VITRIBESTOS under SHEETS AND BLOCKS.
wool Felt Sectional Pine Insulations - An inexpensive insulation made of wool felt and asbestos paper. See STANDARD, EXPRESS, CHAMPION, and AQUA for more detail.
ASBESTOS MILLBOARD
ASBESTOS MILLBOARD (All Grades) - Made of asbestos fiber and suitable binders, this is recommended where relatively thin sheets or boards are required for protection against fire, heat, and acid fumes. Used as a fireproof lining for floors, partitions, ceilings, and elevator shafts. Also used in ranges, stoves, grates, etc. Made in various degrees of hardness and temperature resisting properties.
BOARD
ASBESTOS EBONY - A densely pressed hard sheet of asbestos fiber and binding cements, impregnated with an insulating compound and used for switchboards, controller plates, switch bases, etc. Has high dielectric strength, insulation resistance, strength, and durability.
DEKERAN - A mineral glaze surfacing with exceptional abrasion and stain resistance that is completely fireproof. Available on 3/16 Marine Veneer either plain or perforated.
74
Flat Transite - Incombustible asbestos-cement sheets, resistant ro corrosion and weather.
--- *__ ----- ----- --------- -
---------
'
_ --
feeding and conveying nonferrous metals up to 1500 degrees r .
MARINITE - A composition of asbestos fiber, diatomaceous silica and lime formed with calcium silicate sheets which have structural strength, fire resistance, and insulating value; used as fire-safe wall partitions in ship construction and as a fireproof base for wood veneers; also used to construct industrial ovens and other insulating enclosures, for handling molten metals, as drying trays in dielectric core drying ovens, for back-up of electrotype printing mats, and for fireproof doors.
MARINITE 23 - The MARINITE panel with the best thermal insulating characteristics; recommended where strength and hardness are of secondary importance, in applications where the material is not subjected to direct abuse or where it serves as a core for veneering; the 23 indicates a density of 23 lbs. pcf.
0
MARINITE 36 - The MARINITE panel that provides the best combination of structural strength, surface hardness, and insulating value; recommended for most applications; the 36 indicates a density of 36 lbs. pcf.
MARINITE 65 - The MARINITE that is recommended where structural strength and surface hardness are of primary importance; the 65 indicates a density of 65 lbs. pcf.
MOLTEN m e t a l MARINITE - A board insulation made of ampsite fiber, diatomaceous silica, and an inorganic binder; it is an ideal material for feeding and conveying molten metals up to 13 50 degrees F. Also available as heat treated MOLTEN METAL MARINITE.
Marine Acoustical Unit - Square sections of perforated Marine Veneer with attached elements of sound-absorbing material; used for acoustical treatment in ship construction.
Marine Veneer - Strong, flexible, fire-resistant sheets made of asbestos and cement; used for low-maintenance ceilings and wall facings on ships.
Metal Veneered MARINITE
PALLITE - Sheet material formed from asbestos fiber and inorganic binder; used in drying operations in ceramic plants.
75
REEFERITE - An incombustible, corrosion-proof panel composed of a solid aluminum core faced on both sides with Marine Veneer.
waterways.
TRANSITE Acoustical Panel - A panel made of an asbestos-cement facing used in conjunction with a mineral fiber sound absorbing element.
t r a n s i t e Core Plate - Smoothly sanded, hydrothermally cured asbestos-cement board especially compounded to properly support cores during drying or baking; widely used in the manufacture of castings of brass, aluminum, gray iron, malleable iron, and steel.
Veneered MARINITE
FINISHES
AERTITE - An asphalt-asbestos coating for - troweling over the outside of boiler walls.
TNSULKOTE ET - A non water-vapor barrier, non-burning, weather proof coating for use over insulation where "breathing" is required.
TNSULKOTE SG AND ST - Weatherproofing and vapor barrier coatings for insulations on refrigerated equipment. INSULKOTE SG is an excellent anti-corrosion coating.
PAPER. FELT, BLAMKEES
#50 Asbestos Weatherproofing Felt - An asphalt-saturated asbestos felt used in waterproofing asphalt for work below grade.
#12 Asbestos Paper Tape - Paper tape made from 12 lb. asbestos paper it is felted, composed of asbestos fiber and binder. It comes in 2 or 3 inch rolls, and is used to wrap duct joints and in
many other applications.
15A Asbestos Jacket - A lightweight asphalt-saturated asbestos finishing felt.
45A Asbestos Jacket - An asphalt saturated asbestos felt with a sand finish; a heavy, long life weatherproofing jacket.
7700 coated Asbestos Jacket - An asphalt-saturated and coated asbestos felt with a smooth outer surface, it is designed to be given a field coating of asphalt.
76
ARMATURO Asbestos Paper -- An asbestos paper integrally reinforced with cotton-serin cloth; used as an insulation in e l e c t n_ al equipment; temperature limit is 300 degrees F.
XLAD INTERLOK and m other aircraft and missile applications; m e n furnished in tape form, called ARP Tacky Tape.
ASBESTOCEL Paper - A corruqated paper formed of successive corrugations of an asbestos felt, held together by an asbestos fireproof backing.
Asbestos Corded Sheathing - Consists of pure Asbestos Sheathing, to the surface of which are attached loosely twisted rolls of asbestos, forming a very strong fabric about one-quarter of an inch thick. It is particularly valuable as a fire-proof, non-conductive covering for furnaces, furnace pipes, and other fire-heated
surfaces, etc.
Asbestos FIRE FELT - See Asbestos FIRE FELT under SHEETS-- AND
BLOCKS.
-
fthesros FTRETARD - A fire-retardant weatherproof jacket consisting of a sheet o f ^ phalt-saturated asbestos felt cemented to a sheet
of unsaturated asbestos felt; used on outdoor pipe insulation and small diameter vessels wherever fire hazards are present.
tshftstos Felt - Composed entirely of pure asbestos, is fireproof, and possesses three times the strength of hair felt.
h n t e s w s W l v Rails - 'wade of
theSS are
used to pack boiler and still-setting expansion ]omts.
Lining Felt - This t j r i a l Sheathing, to one side of which is attached a layer of fiocxea or felted asbestos, forming a strictly fireproof, non-conducting lining for hair felt, protecting it from the injurious effects of
heat when applied to steam pipes, boilers, etc.
Asbestos Lining and peadening Felt - Same as As^ ^ s ^ ^ ng Felt; also used for lining floors, walls, etc., to deaden sound.
lebeattoa Locomotive Lagging - Composed of large strands or twisted
rolls of
asbestos woven in a fine asbestos warp and lined
with a pure Asbestos Sheathing, forming a strong, matted, fel
like material of great non-conducting power.
Acbpstos Pine Blanket - Made of asbestos cloth, filled with asbestos fiber and j i l ted; for pipes, fittings and flanges where inspection is made frequently and necessitates :removal of tne insulation; the asbestos cloth used is special to suit eacn temperature and service condition up to 950 degrees .
77
Asbestos Roll FIRE FELT - See Asbestos FIRE FELT under SHEETS, A M D 3LCCKS,
S w tSJ
Asbestos Sponge Felt - A thin felt, composed of asbestos fiber and particles of finely ground spongy material forming an extremely cellular felt for temperatures up to 700 degrees F.
Asbestos Sponge Hair Felt - Composed of asbestos sponge and hair, it forms a good covering for steam pipes, boilers, mining purposes, etc.; it is very elastic, and owing to the large proportion of asbestos, is not liable to injury from steam heat.
Asbestos Turbine Blanket - Consists of high temperature felted mineral insulation fully enclosed in a wire inserted asbestos cloth for temperature exposure to 850 degrees F, or a stainless steel mesh for temperatures from 850 degrees F to 1100 degrees F .
Asbestos and Hair Woven Felt - Similar to -Asbestos Locomotive Lagging, but contains 25% hair; it is very elastic and practically fire-proof.
CEXLINITE - Made from Asbestos Roll FIRE FELT, reinforced on one side with asbestos cloth; used as an inter-lining, for fireproofing electrical apparatus such as switch boxes, and for similar purposes requiring a strong, flexible, fireproof felt; for temperatures up to 1000 degrees F.
commercial Grade Asbestos Paper - A standard asbestos paper varying in weight from 6 to 32 lbs. per 100 sq. ft: -and -in thicknesses from .015 to .0625 inches. Asbestos paper is formed from asbestos fiber and a suitable binder and used where an insulating material of minimum thickness is required.
n .c . f l e x s t o n e - A high quality asbestos felt, uaturated and coated with asphalt on both sides; used to make weauner-proof jackets for insulated pipe lines located outdoors.
noUBLEX Asbestos Paper - A paper made from asbestos and a line silicate binder used by neon sign manufacturers to make templates or patterns; also used for pouring gates in foundries.
Engineers Insulating Tape
ETSROID Asbestos Paper - Used as an electrical insulation; made from asbestos paper and a binder, it can withstand temperatures up to 500 degrees F.
High Temperature Flexible MIN-K Blankets - See Flexible MIN-K under SHEETS AND BLOCKS.
78
High Strength FIBROID Asbestos Paper - See FIBROID Asbestos Paper; can be used for service up zo 600 degrees F.
sheet for saturating; minimum fiber content 33*.
MTCROBESTOS - A high grade chrysotile asbestos paper which can be readily saturated with various resins to provide a very uniform prepreg reinforcing material; for use in the manufacture of reinforced plastic products and in the ablative field.
MTN-KLAD - A molded combination of MIN-K and asbestos reinforced plastic faces.
NTAGRITE - A felted asbestos tape for wrapping around electrical cables as fireproofing; usually reinforced with burlap or asbestos cloth.
Non-Burn Asbestos Paper - A medium length fiber paper with high fiber content; suitable for continuous service at 400 degrees F.
standard Flexible MIN-K Blankets - See Flexible MIN-K under SHEETS AND BLOCKS
Super FTRE FELT - See Super FIRE FELT under SHEETS AND BLOCKS.
t h f r m o FELT - An asbestos hair felt composed of 50% cattle hair and 50% asbestos, with a burlap center; used in steel passenger cars and street cars.
THERMOMAT - A nonwoven long fiber asbestos felt saturated with phenolic resin; furnished as a molding compound in sheet or tape form; extremely resistant to high temperatures; used as a rocket motor liner and in other aviation and missile applications.
t h f r m o t ^PE - A flexible pipe insulation in strip or roll form made of an asbestos pad in a neoprene coated asbestos cloth jacket; used on locomotives and cars where sectional insulation can't be applied effectively.
THERMQWRAP - A pipe insulation made up of a blanket of asbestos fibers held together by asbestos yarns and enclosed in a neoprenecoated asbestos jacket; primarily designed for steam lines on trains; High Temperature THERMOWRAP is designed for use on diesel exhaust lines and in similar high temperature situations.
welding Paper
White Surface Asbestos Jacket - A pipe insulation jacket made fro asbestos weatherproof felt.
79
SEALING COMPOUNDS
ccr.cour'.r.s ar a Ciistic or in, air, oust, r.ois..urs sealing uses follow.
'=oc.'
Ine procures no
a l b a s EAL - Air conditioners, refrigeration equipment.
AOUASEAL - Threaded or jacketed joints.
BRANCHITE - Sewer Pipe connections.
andY Sealer - Auto, truck, and trailer bodies.
ntlXSEAL - Wires and cables at duct entrances; general purpose.
H-NAVASEAL - Electrical duct apertures aboard ship; a heat (H) resistant, practically incombustible sealer for Navy applications.
h f -n a v a s e a L - Electrical duct apertures aboard ship; a heat and flame (HF) resistant, practically incombustible sealer for Navy applications.
industrial Vent Caulking n o d r s EAL - Refrigeration equipment and general purpose.
fi,nva Puttv - Ovens and hot-water heaters where it is not apt to be exposed to intense heat.
'fftANOSEAL - Oil filled electrical transformers...
Tvne T NQPRSEAL - Refrigeration equipment and general purpose. ttniSEAL - General purpose.
CEMENTS
Cement - General utility short fiber cement, used by the plumbing and steamfitting trade for insulating heating boilers an pipe fittings; temperature limit 1000 degrees F.
inn cement
80
301 cement
insulating value; temperature limit 1000 degrees F.
304 Cement - Insulating cement made from long fiber asbestos for covering surfaces liable to become red hot; temperature limit 1200 degrees F .
319 Semi-Refractorv Cement - A combined insulating and semi refractory cement used to protect block or brick insulation in flues, stacks, etc.; temperature limit 1600 degrees F.
329 Cement - A lagging cement for finishing over sheets and blocks, for insulating large heated surfaces and for irregular surfaces and fittings, where it is impossible to apply either sectional pipe covering or blocks. It is very light, full of confined air, elastic and spongy, and forms an excellent plastic non-conductor.
340 cement - An insulating and finishing cement lower in covering capacity and price the 302 Cement; temperature limit 1000 degrees F.
352 Cement - General utility short fiber cement, used in large quantities by tne plumbing and steamfitting trades for insulating heating boilers and pipe fittings; used as a finish over block insulation and in general applications; temperature limit 1 0 0 0 degrees F.
364 cement - A medium grade insulating cement; temperature limit 1000 degrees F.
4ng cement - A combination of asbestos and other material of high insulating value, ideal for general use where efficiency, strength, and durability are desired; temperatures limit 700 degrees F.
450 Cement - A mineral wool base insulating cement with excellent adhesion which permits it to be readily applied to surfaces too irregular to insulate with sheets or blocks; adheres to hot or cold surfaces but is not a finishing cement; temperature limit 1200
degrees - 1500 degrees F.
5nn cement - A cement composed of asbestos fiber and expanded mica
which combines high covering capacity and heat resistance with good
working qualities. Can be used at temperatures up to 1800 degrees
F if entire reclaimability is not essential.
Completely
reclaimable at temperatures up to 1500 degrees F. Useful for
irregular surfaces where block insulation is not adaptable, but not
ordinarily used for finishing.
81
678 Semi-Refractory Cement - An air-setting, hydraulic cement which
is a combination finishing and semi-refractory cement for use as
a protective coating over bloc:-: insulation linings exposed to the
action of moving gases m flues, orsecnmgs, and scoots. -.'here
rircsiYe iczicu -o
1 - o ~ . is -r.
~~ ^
j ..~u
particularly in area where the gases change direction sharply, the
cement should be protected with temperature resistant metal;
temperature limit 1900 degrees F.
85% Magnesia Cement - Composed of the same material as 85% Magnesia sectional and block insulation, it is essentially an insulating and not a finishing cement; temperature limit 600 degrees F.
ASBESTILE Cement - A heavy bodied cement of asbestos fibers, asphalt, and other mineral ingredients; specifically designed for sealing flashings with a watertight bond.
ASBESTOMENT - A refractory powder which when mixed with water produces an outer coating on the fireproofing of electrical cables; usually used with NIAGRITE.
FIBROFIL - A mixture of diatomaceous silica and asbestos fibers; used as an insulating fill for irregular spaces.
FIREITE Furnace Cement - An asoestos compound for mounting, sealing, and repairing joints in stoves, boilers, furnaces, heaters, and ranges.
Fibrous Adhesive - A strong silicate soda and asbestos fiber cement used for temporary bonding of insulation to brick, concrete, metal, or other surfaces as well as for bonding prefab fittings; . temperature limit 500 degrees F.
Fil Insul - A resilient fill composed of mineral fibers; used for insulating irregular surfaces.
Heat Treating Cement - A ready-mixed refractory cement for use in the heat treating of high carbon steel parts; for temperatures up to 2500 degrees F.
LAPTITE Cement - A heavy brushing fibrated cut-back asphaltic cement with a temperature limit of 140 degrees F. Used for sealing the laps of weatherproof insulating jackets.
m x -- i808 Asbestos Filler
N a w 450 Cement - A specially formulated variation of 450 Cement to meet Navy specifications.
SUPEREX Cement - The same material as used in SUPEREX sectional and block insulation; used with SUPEREX or THERMO-12 pipe and block
82
insulation for patching, pointing up joints, and covering irregular shapes.
5DPZREX cement for h a w - A specially formulated variaf.or, :: 5V?EP,Za C^rr.en'c z z ".eei !*2 v* s z - z i i L z z z i z z s .
THERMOBESTOS -Cement - The same material used in THERMOBESTCS sectional and block insulation.
THERMOMIX 700, 720. 770, 810 - Insulating cements designed for use in missile engines; these compounds contained a special heat resistant phenolic resin system of the dry type.
C.18.
During the years that your company manufactured
and/or sold asbestos containing materials, did your company prepare
and/or publish any sales or promotional literature which depicted
and described these products? If so, describe the particular
literature which your company prepared and indicate the information
the literature contained. Describe who has custody of this
literature at the present time.
ANSWER: All such sales or promotional literature for Manville Corporation or related entities in the possession, custody or control of the Fund is located at the records repository in Denver, Colorado, and will be made available for inspection and copying at a time convenient to the parties. In addition to the documents which will be specifically identified and produced at that time, there may be additional documents responsive to this Interrogatory among the general collection of documents in the repository. This collection of documents will be made available to Plaintiff for review at a time agreed upon by the parties. See Answer to Interrogatory No. 39.
C.19.
Has your company manufactured asbestos containing
products and materials which were distributed by another entity or
corporation under their name or trademark? If so, identify each
such entity which sold or distributed these products, indicate
which of your company's products this company marketed and indicate
the inclusive dates that this particular commercial arrangement
existed.
ANSWER: The Fund has been unable to identify products which were manufactured by Manville Corporation or related entities but which were sold by other companies.
C.20.
Has your company marketed under its own name or
trademark any asbestos containing insulation products which were
manufactured by another corporation? If so, identify each and
every product which your company marketed which was manufactured
by another corporation, indicate the inclusive dates that you
marketed each product and describe the name, trade name and generic
name of each such product which your company marketed.
33
ANSWER: Manville Corporation or related entities have, on occasion, marketed products manufactured by other companies.
Raycestcs-Manr.attar. Cippo.-, iscestcs z z ro.-c. o \r : 'o . .= Asnestos Company manuract-ree ascestos .:iotn -net ascestou tape marketed under the Johns-Manville logo from approximately 1969 through 1974.
Additionally, in 1969, Manville or related entities entered into an agreement with Raybestos-Manhattan, Inc., whereby Manville agreed to market profile calendar brake linings manufactured by Raybestos-Manhattan, Inc. under the style designations HF, SF, and
MF.
Manville or related entities also sold Corrugated Transite, a roofing/sheet product made by GAF, from 1972 through 1977.
The Fund has been unable to identify any other products which were sold by Manville or related entities but which were produced by other companies.
C.21.
Were any of the asbestos containing insulation
products that defendant sold or distributed into the stream of
commerce accompanied by written instructions or package inserts?
If so, indicate which such products were provided with such
instructions and package inserts, indicate when each product was
accompanied by these materials, state the substance of what the
instructions or package inserts stated and annex copies of same
hereto.
ANSWER:. On a continuing basis, Manville Corporation or related entities furnished customers information as to the proper use and application of its insulating products, and directly or indirectly advised industrial insulation contractors to utilize ventilation equipment, such as respirators, at the sites where finished insulation products were being worked with and applied. Those respirators which have been recommended were approved by the federal government for use as protection against asbestos.
Manville Corporation or related entities also affixed caution instructions to products regarding the handling of these products. See response to Interrogatory No. B.19. In addition, Manville1s product literature contained recommendations regarding respirator usage and utilization of adequate dust collection systems when fabricating, handling and applying certain asbestos containing materials.
Manville Corporation or related entities participated in and contributed to the informational and educational program of the National Insulation Manufacturers Association (NIMA). This program
84
was designed to educate the insulation contractors' industry with respect to the health aspects of exposure to asbestos.
To nr.is end, -.if tor tractors in asbestos fibers by asbestos containing approximately eight regional meetings.
sponsored a number of regional meetings to ~ i- i~ 11 m g ~r e .i~ in at ir.tr ~r.~. .r.r.a.'titn of those wnc worked witn, installed or applied thermal insulation products. In 1967 and 1968, hundred insulation contractors attended these
Approximately three hours in length, these programs included a review of: 1) the biological effects of exposure to asbestos; 2) the threshold limit value for asbestos; 3) methods for evaluating concentrations of dust; and 4) engineering and method recommendations designed to assist the contractors in dust abatement and environmental control.
The highlights of these presentations were published in
several booklets prepared by NIMA. One such booklet, entitled
"Recommended Safe Practices for Handling and Applying Thermal
Insulation Products Containing Asbestos," printed May 1, 1968, was
written by members of the NIMA Education and Information Committee.
This booklet was distributed during the 1968 meetings.
In
addition, the booklet was distributed to customers, employees and
other interested parties.
The chairman of the NIMA Education and Information committee
was Clifford L. Sheckler, who, at that time, was Manager, Accident
Prevention and Health Administration at Manville. Other members
of the committee included John Vyverberg, Owens-corning Fiberglass
Corporation; Harry Mesler, Ruberoid Company; Leon Horowitz,
Certain-Teed Corporation; and Jack Barnhart, Executive secretary
* of NIMA.
Manville Corporation or related entities also distributed the following materials to employees who were exposed to asbestos or asbestos containing products in the course of their employment:
An employee notification form entitled "Dear Johns-Manville Employee" reminded employees of the risks associated with asbestos exposure. This was inserted in paychecks of all employees at all Johns-Manville Sales Corporation contract units beginning in 1970.
A pamphlet entitled "Safe Work Manual" published by JohnsManville Corporation in 1971.
A booklet entitled "What Every Employee Should Know About Asbestos" published by Johns-Manville Corporation in 1973. This booklet was distributed to all employees at all locations using asbestos fiber or handling products containing asbestos fiber.
85
A pamphlet entitled "Recommended Safety Practices for Handling Asbestos Fiber" published by Johns-Manville Corporation in November 1973. This booklet vas distributed to all employees at ail locations usino ?.soestos fiber or hardline produotooontaming ascesici racer.
A booklet entitled "What You Should Know Asbestos and Health" published by Johns-Manville Corporation in January 1975. This booklet was distributed to all employees at all locations using asbestos fiber or handling products containing asbestos fiber.
A booklet entitled "Before You Begin" published by JohnsManville Corporation in 197 6 and designed to be given to prospective employees before beginning work in an asbestos using operation.
A booklet entitled "Questions and Answers Concerning Asbestos" published by Johns-Manville Corporation in 1982.
In 1976, Manville Corporation or related entities began to publish a Catalog of Occupational Environmental Health and Safety Programs as listed below. All of the publications, audio-visual programs and other material listed in this catalog were made available to Manville customers and public interest groups as well as to all Manville personnel.
A pamphlet entitled "Occupational Health Guide - Asbestos" published by Johns-Manville corporation in 1976. This guide was designed as a reference for supervisory personnel.
A 25-minute slide/tape presentation -on 'industrial hygiene
programs at Manville.
' ''
A 20-minute slide/tape program on health aspects of working with asbestos.
A 25-minute motion picture on occupational health risks associated with asbestos fiber.
A newspaper entitled "The Asbestos Report" published by JohnsManville Corporation in 1976.
In 1980, Manville Corporation or related entities published the 1980-1981 edition of the Health, Safety and Environment Catalog which, in addition to the above, included:
"A Study of the Problem of Asbestos in Water," which was a reprint of a report by the American Water Works Association Research Foundation. This report was the result of intensive
86
study and literature search and covered all aspects of the use and safety of asbestos-cement pipe materials.
"Asbestos Facts," published by Johns-Manville Corccraticn, .as
a series of or.e-ceoe face sr.eecs cover mo? various aspects cf
the asoestos and health issue.
'
'
"Asbestos Minerals in Modern Technology," published by JohnsManville Corporation, was a comprehensive review of mineralogy.
"Does Asbestos-Cement Pipe Pose a Health Hazard?" This reprint of an article in California Builder & Engineer discussed the health questions regarding the use of asbestoscement pipe.
"Dust Control Techniques in the Asbestos Industry," published by Johns-Manville Corporation, summarized engineering efforts at Manville to control the emission of asbestos in mining, milling and manufacturing operations.
"The Asbestos Issue: A Matter of Principle," published by Johns-Manville Corporation in 1979, reported on issues related to asbestos health concerns and covered research efforts, Manville health programs and actions.
"Today:
Special Asbestos Update," published by Johns-
Manville Corporation, covered asbestos policy, benefits and
applications, types of diseases and groups affected.
Manville Corporation or related entities cooperated with the Asbestos Information Association in the production of the following booklets:
"Recommended Work Practices - Molding and Fabrication of Asbestos-Containing Plastic Products."
"Recommended Work Practices - Fabrication and Use of Asbestos Friction Materials."
"Recommended Work Practices - Fabrication and Use of Asbestos Paper Products."
"Recommended Work Practices - Shop and Field Fabrication of Asbestos Sheet Products."
"Recommended Work Practices - Use and Handling of Asbestos Textile Products."
Additionally, Manville Corporation or related entities participated in 1971 through the Occupational Health and Safety
87
Committee of the National Insulation Contractors Association in m e preparation of a booklet entitled "Safety Reminders."
ever the years, Manville Corporation or related er.tit.es i.s:
v--- a; cue" 'srsc cr -is
lie u30 cv h.~c ..iv25*,5s
- i'
of cccK.ats which addressee a r.umoer or durrent sarety ana r.eaior
issues m Manville operations. Many of these booklets addressed
safe work practices to minimize exposure to dust.
In addition, until Manville Corporation or related entities ceased manufacturing asbes.tos containing materials, there were many oral presentations and meetings at the plant level concerning safety practices related to asbestos exposure.
Respectfully submitted,
CARL J. VALORE, ESQUIRE MCALLISTER, WESTMORELAND
VESPER & SCHWARTZ, P.A. BAYPORT ONE, YACHT CLUB DRIVE WEST ATLANTIC CITY, NJ 08401 (509) 645-1111
Attorneys for Manville Corporation Asbestos Disease Compensation Fund
.S'/
fc-V Jy\*
88
AFFIDAVIT
I, T jk iP A p rs r& G -M
, being of full age and first duly-
sworn, depose ana state that I am
roe^ jsSt,
of the
Manville Corporation Asbestos Disease compensation Fund, a
defendant in this action; that I am authorized to make this
affidavit on its behalf; that the matters stated in the foregoing
Answers to Interrogatories are not within my personal knowledge;
that I am informed that no single official, employee, or former
employee of either the Fund or of Manville Corporation has personal
knowledge of all such matters; that information contained herein
has been compiled at my direction by counsel for the Fund, and the
responses are in accordance with the information available to them;
and that the answers are true and correct, insofar as it is
possible to verify them.
Further affiant sayeth naught.
Subscribed and sworn to before me this / ^ day of
, 1989.
NOTARY PUBLIC
ici\msp\njOOll. int
\
Exhibit M ^
Manville Asbestos Containing Thermal Insulation or Shipyard Products
Product Name: #12 Asbestos
Product Type: Paper
Fiber Type:
Chrysotile
\ Fiber by Weight: 95.0
Date Manufactured: 1936
Date Discontinued: 1980
Date Labeled: None
Paper
Tape
Product Name: 15A Asbestos Jacket
Product Type: Paper, Felt
Fiber Type:
Chrysotile
% Fiber by Weight: 50.0 - 57.0
Date Manufactured: 1931
Date Discontinued: 1980
Date Labeled: None
Product Name: 45A Asbestos Jacket
Product Type: Felt, Blankets
Fiber Type:
Chrysotile
% Fiber by Weight: 50.0
Date Manufactured: 1931
Date Discontinued: 1980
Date Labeled: None
Product Name: #50 Asbestos Weatherproofing
Product Type: Paper, Felt, Blankets
Fiber Type:
Chrysotile
% Fiber by Weight: 50.0 - 55.0
Date Manufactured: 1923
Date Discontinued: 1976
Date Labeled: 1970
Felt
Product Name: 55 Cable Fireproofing
Product Type: Tape
Fiber Type:
Chrysotile
% Fiber by Weight: 72.0
Date Manufactured: 1956
Date Discontinued: 1982
Date Labeled:
Tape
l
Product: y'ar.e: 35% Magnesia
.-reduce Type: HIecu, Pipe Ir.sulaercr.
.-.car Hype:
Cnryscei.a ar.c.cr .-oosica
% Fiber by'Weight: 7.3 - 15.0
Date Manufactured: 1902
Date Discontinued: 1970
Date Labeled: 1964
Product Name: 85% Magnesia Cement
Product Type: Cement
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: 7.3 - 15.0
Date Manufactured: 1902
Date Discontinued; 1970
Date Labeled: 1965
Product Name: 88 Cloth (Coated)
Product Type: Cloth
Fiber Type:
Chrysotile
% Fiber by Weight: 58.0
Date Manufactured: 1960
Date Discontinued: 1983
Date Labeled: None
Product Name: 89 Cloth (Coated)
Product Type: Cloth
Fiber Type:
Chrysotile
% Fiber by Weight: 58.0
Date Manufactured: 1955
Date Discontinued: 1983
Date Labeled: None
Product Name: 91 Cloth (Coated)
Product Type: Cloth
Fiber Type:
Chrysotile
% Fiber by Weight: 61.0
Data Manufactured: 1957
Date Discontinued: 1983
Date Labeled: None
Product Name: 95 (1/16) Cloth
Product Type: Cloth
Fiber Type:
Chrysotile
% Fiber by Weight: 32.0
Date Manufactured: 1942
Date Discontinued: 1983
Date Labeled: None
(Coated)
2
flier Type:. Chrysotile % Fiber by Weight: 19.0 Date Manufactured: 1942 Date Discontinued: 1983 Date Labeled: None
Product Name: 96 (1/16) Cloth
Product Type: Cloth
Fiber Type:
chrysotile
% Fiber by weight: 25.0
Date Manufactured: 1942
Date Discontinued: 1983
Date Labeled: None
(Coated)
Product Name: 96 (1/8) Cloth
Product Type: Cloth
Fiber Type:
Chrysotile
% Fiber by Weignt: 18.0
Date Manufactured: 1942
Date Discontinued: 1983
Date Labeled: None
(Coated)
Product Name: 101 (1/32,
Product Type: Cloth
Fiber Type:
Chrysotile
% Fiber by Weight: 45.0
Date Manufactured: 1902
Date Discontinued: 1983
Date Labeled: None
3/32)
Cloth
(Coated) -
Product Name: 101 (1/16,
Product Type: Cloth
Fiber Type:
chrysotile
% Fiber by Weight: 39.0
Date Manufactured: 1903
Date Discontinued: 1983
Date Labeled: None
1/4)
Cloth
(Coated)
Product Name: 101 Asbestos Millboard
Product Type: Sheet
Fiber Type;
Chrysotile
% Fiber by Weight: 59.2 - 73.5
Date Manufactured: 1910
(Hard)
3
Date Discontinued: 1951 lace Labeled: None
Product Name: 102 Asbestos Millboard
Product Type: Sheet
Fiber Type:
Chrysotile
% Fiber by Weight: 75.0 - 86.6
Date Manufactured: 1910
Date Discontinued: 1980
Date Labeled: 1970
(Medium)
Product Name: 103 Asbestos Millboard
Product Type: Sheet
Fiber Type:
Chrysotile
% Fiber by Weight: 76.0 - 90.0
Date Manufactured: 1910
Date Discontinued: 1951
Date Labeled: None
(Soft) '
Product Name: 104 Asbestos
Product Type: Sheet
Fiber Type:
Chrysotile
% Fiber by Weight: 92.8
Date Manufactured: 1915
Date Discontinued: 1951
Date Labeled: None
Millboard
Product Name: 105 Asbestos Millboard
Product Type: Sheet
Fiber Type:
Chrysotile
% Fiber by Weight: 77.0 - 92.8
Date Manufactured: 1915
Date Discontinued: 1951
Date Labeled: None
Product Name: 106 Asbestos Millboard
Product Type: Sheet
Fiber Type:
chrysotile
% Fiber by Weight: 70.0 - 91.2
Date Manufactured: 1918
Date Discontinued: 1980
Date Labeled: 1970
Product Name: Product Type: Fiber Type:
106B Asbestos Millboard Sheet Chrysotile
4
% Fiber by Weight: 95.0 Date Manufactured: 1918 Data Discontinued: 1930 Data laceiac: l?"C
Product Name: 106H Asbestos Millboard
Product Type: Sheet
Fiber Type:
Chrysotile
% Fiber by Weight: 87.0 - 88.0
Date Manufactured: 1918
Date Discontinued: 1980
Date Labeled: 1970
Product Name: 135 Tadpole Product Type: Tape Fiber Type: % Fiber by Weight: 36.0 Date Manufactured: 1948 Date Discontinued: 1982 Date Labeled: None
Gasketing
Tape
Product Name: 135-S Tadpole Product Type: Tape Fiber Type: % Fiber by Weight: 36.0 Date Manufactured: 1948 Date Discontinued: 1982 Date Labeled: None
Gasketing
Tape
Product Name: 219 Asbestos Millboard
Product Type: Sheet
Fiber Type:
Chrysotile
% Fiber by Weight: 84.0 - 86.8
Date Manufactured: 1918
Date Discontinued: 1980
Date Labeled: 1970
Product Name: 300 cement
Product Type: Cement
Fiber Type:
Chrysotile
% Fiber by Weight: 100.0
Date Manufactured: 1932
Date Discontinued: 1970
Date Labeled: None
Product Name: 301 Cement
5
Product Type: Cement
Piter Type:
Chrysotiie
Piter ry Weight: 14."
_._ .[riwiiwi- r s ~
Date Discontinued:
1971
Date Labeled: 1965
Product Name: 302 Cement (Originally called Asbestos Cement
Felting; later known as Fire Felt Insulating Cement)
Product Type: Cement
Fiber Type:
Chrysotiie
% Fiber by Weight: 49.4 - 70.0
Date Manufactured: 1858
Date Discontinued: 1970
Date Labeled: 1965
Product Name: 304 Cement (Asbestos Hot Blast Cement)
Product Type: Cement
Fiber Type:
Chrysotiie
% Fiber by Weight: 50.0 - 53.4
Date Manufactured: 1884
Date Discontinued: 1969
Date Labeled: 1965
Product Name: 319 Semi-Refractory
Product Type: Cement
Fiber Type:
Chrysotiie
% Fiber by Weight: 20.0 - 21.0
Date Manufactured: 1925
Date Discontinued: 1969
Date Labeled: 1965
Cement
Product Name: 320 Cement
Product Type: Cement
Fiber Type:
Unknown (Probably
% Fiber by Weight:
Date Manufactured:
Date Discontinued:
Date Labeled: None
Chrysotiie)
Product Name: 329 Cement Product Type: Cement
Fiber Type: % Fiber by Weight: Date Manufactured: 1890 Date Discontinued: 1915 -
Date Labeled: None
1920
6
Fiber Type:
Chrysotile
% Fiber by Weight: 60.0
Date Manufactured: 1908
Date Discontinued: 1969
Date Labeled: None
Product Name: 0352 cement
Product Type: Cement
Fiber Type:
chrysotile
% Fiber by Weight: 25.0 - 40
Data Manufactured: 1931
Date Discontinued: 1969
Date Labeled: 1965
Product Name: 352 Cement
Product Type: Cement
Fiber Type:
chrysotile
% Fiber by Weight: 100.0
Date Manufactured: 1923
Date Discontinued: 1973
Date Labeled: 1965
Product Name: 364 Cement
Product Type: - Cement
Fiber Type:
Chrysotile
% Fiber by Weight: 50.0 - 60
Date Manufactured: 1908
Date Discontinued: 1955
Date Labeled: None
Product Name: 400 Cement
Product Type: Cement
Fiber Type:
Chrysotile
% Fiber by Weight: 21.6 - 23
Date Manufactured: 1915
Date Discontinued: 1969
Date Labeled: 1965
Product Name: 450 Cement
Product Type: Cement
Fiber Type:
Chrysotile
% Fiber by Weight: 7.1 -
Date Manufactured: 1930
Date Discontinued: 1971 Date Labeled: 1965
Produce Name: 500 Cement
Product Type': cement
Fiber Type:
Chrysotile
% Fiber by Weight: 16.7 -
Date Manufactured: 1933
Date Discontinued: 1971
Date Labeled: 1965
20.0
Product Name: 673 Semi-Refractory Cement
Product Type: Cement
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: 20.0 - 35.0
Date Manufactured: 1941
Date Discontinued: 1969
Date Labeled: 1965
Product Name: 7700 Coated
Product Type: Felt
Fiber Type:
Chrysotile
% Fiber by Weight: 24.0 -
Date Manufactured: 1931
Date Discontinued: 1983
Date Labeled: None
Asbestos 26.0
Jacket
Product Name: AAAA Grade
Product Type: Rope
Fiber Type:
Chrysotile
% Fiber by Weight: 99.0 -
Date Manufactured: 1884
Date Discontinued: 1983
Date Labeled: 1972
100.0
Product Name: AAAA Grade Asbestos
Product Type: Cloth
Fiber Types
Chrysotile
% Fiber by Weight: -99.0 - loo.o
Date Manufactured: 1884
Date Discontinued: 1970
Date Labeled: None
Cloth
Product Name: Product Type: Fiber Type:
AAAA Grade Asbestos Tape Tape Chrysotile
3
% Fiber by Weight: 99.0 - 1 0 0 . 0 Date Manufactured: 1384 Date Discontinued: 1980
i C S 1 - C * 'o " "5
Product Name: AAA Grade (788, 857,
Product Type: Rope
Fiber Type:
Chrysotile
% Fiber by Weight: 95.0 - 99.0
Date Manufactured: 1884
Date Discontinued: 1982
Date Labeled: 1972
869,
873)
Product Name: AAA Grade Asbestos
Product Type: Cloth
Fiber Type:
Chrysotile
% Fiber by Weight: 95.0 - 99.0
Date Manufactured: 1884
Date Discontinued: 1974
Date Labeled: 1972
Cloth
Product Name: AAA Grade Asbestos
Product Type: Tape
Fiber Type:
Chrysotile
% Fiber by Weight: 95.0 - 99.0
Date Manufactured: 1884
Date Discontinued: 1983
Date Labeled: 1972
Tape
Product Name: AAA Grade Asbestos
Product Type: Tubing (Braided)
Fiber Type:
Chrysotile
% Fiber by Weight: 95.0 - 99.0
Date Manufactured: 1884
Date Discontinued: 1982
Date Labeled: 1972
Tubing
Product Name: AA Grade Asbestos
Product Type: Cloth
Fiber Type:
Chrysotile
% Fiber by Weight: 90.0 - 95.0
Date Manufactured: 1884
Date Discontinued: 1974
Date Labeled: 1972
Cloth
Product Name:
AA Grade Asbestos Tape
9
Product Type: Tape
Fiber Tyoe:
Chrysotile
Fiber bv W<=i--ht : ?0.3 - 5. 1
lace Discenti r.ued: 19 33 Date Labeled: 1972
Product Name: AA Grade Asbestos
Product Type: Tubing (Braided)
Fiber Type:
Chrysotile
% Fiber by Weight: 90.0 - 95.0
Date Manufactured: 1884
Date Discontinued: 1982
Date Labeled: 1972
Tubing
Product Name: A Grade Asbestos
Product Type: Cloth
Fiber Type:
Chrysotile
% Fiber by Weight: 85.0 - 90.0
Date Manufactured: 1884
Date Discontinued: 1974
Date Labeled: 1972
Cloth
Product Name: A Grade Asbestos
Product Type: Tubing (Braided)
Fiber Type:
Chrysotile
% Fiber by Weight: 85.0 - 90.0
Date Manufactured: 1884
Date Discontinued: 1982
Date Labeled: 1972
Tubing
Product Name: AERTITE
Product Type: Finishes
Fiber Type:
Chrysotils
% Fiber by Weight: 14.7 -
Date Manufactured: 1920
Date Discontinued: 1982
Date Labeled: None
18.0
Product Name: Air-Cell (Generic
Product Type: Sheet/Block, Pipe
Fiber Type:
Chrysotile
% Fiber by Weight: 52.6 - 98.0
Date Manufactured: 1908
Date Discontinued: 1915 - 1920
Date Labeled: None
name for ASBESTOCEL) Insulation
10
Produce Name: ALBASEAL Prozuct Type: Sealing Ccr.pcur.d
' *--
- I fi** `
W.*i^3ww
=
* Fiber by'Weight: 40.0
Date Manufactured: 1953
Date Discontinued: 1975
Date Labeled: None
Product Name: ANTI-SWEAT
Product Type: Sheet/Block, Pipe
Fiber Type:
Chrysotile
% Fiber by Weight: up to 72.0
Date Manufactured: 1903
Date Discontinued: 1965
Date Labeled: None
Insulation
Product Name: ARMATURO Asbestos Paper
Product Type: Paper
Fiber Type:
chrysotile
% Fiber by Weight: 84.0 - 97.0
Date Manufactured: 1920 - 1924
Date Discontinued: Approximately 1980
Date Labeled: 1970
(Insulating
Jacket)
Product Name: ARP-40 (Insulating
Product Type: Paper
Fiber Type:
Chrysotile
% Fiber by Weight: 60.0
Date Manufactured: 1963
Date Discontinued: 1971 - 1975
Date Labeled: Unknown
Jacket)
Product Naas: Asbestica Tape
Product Type: Tape
Fiber Type:
Chrysotile
% Fiber by Weight: 80.0 - 85.0
Date Manufactured: 1948
Date Discontinued: 1982
Date Labeled:
Product Name: ASBESTILE Cement
Product Type: Cement
Fiber Type:
Chrysotile
% Fiber by Weight: 8.2 - 21.8
Date Manufactured: 1930
Date Discontinued: 1982
11
Date Labeled: None
Produce Type: Sheet/Block, Pipe Fiber Type: ' Chrysotile % Fiber by Weight: 52.6 - 98.0 Date Manufactured: 1902 Date Discontinued: 1971 - 1975 Date Labeled:
Insulation
Product Name: ASBESTOCEL Paper
Product Type: Paper
Fiber Type:
Chrysotile
% Fiber by weight: 52.6 - 98.0
Date Manufactured: 1902
Date Discontinued: 1924 - 1931
Date Labeled: None
Product Name: ASBESTOCITE
Product Type: Board
Fiber Type:
Chrysotile
% Fiber by Weight: 33.0 -
Date Manufactured: 1927
Date Discontinued: 1975
Date Labeled: 1970
45.0
Product Name: ASBESTOMENT
Product Type: Cement
Fiber Type:
Chrysotile
% Fiber by Weight: 6.0
Date Manufactured: 1923
Date Discontinued: 1970
Date Labeled: None
Product Name: Asbestos Air Chamber Covering
Product Type: Pipe Insulation
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not Available
Date Manufactured: 1880
Date Discontinued: 1893 - 1895
Date Labeled: None
Product Name: Asbestos and Hair Felt Removable
Product Type: Pipe Insulation
Fiber Type:
Unknown (Probably chrysotile)
% Fiber by Weight: Not available
Covering
12
Date Manufactured: 1391 Date Discontinued: 1396 - 1900 Date Labeled: '.'one
Product Name: Asbestos and Hair Woven Felt
asbestos and Hair Lagging)
Product Type: Paper, Felt, Blankets
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Hot available
Date Manufactured: 1884
Date Discontinued: 1890
Date Labeled: None
(Originally
called
Product Name: Asbestos Combination Spiral Pipe
Product Type: Pipe Insulation
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not available
Date Manufactured: 1931
Date Discontinued: 1934 - 1936
'
Date Labeled: None
Insulation
Product Name: Asbestos Corded Sheathing
Product Type: Paper, Felt, Blankets
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not available
Date Manufactured: 1887
Date Discontinued: 1896 - 1900
Date Labeled: None
Product Name: ASBESTOS EBONY
Product Type: Board
Fiber Type:
Chrysotile
% Fiber by weight: 47.0 - 75.0
Date Manufactured: 1911
Date Discontinued: 1984 - 1985
Date Labeled:
Product Name: Asbestos Felt
Product Type: Felt
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1390
Date Discontinued: 1890 - 1891
Date Labeled: None
Product Name:
Asbestos FIRE FELT
13
i )
Product Type: Feit
Fiber Type;
Chrysotile
late Discontinued : 1971 - 1975 Date Labeled:
Product Name: AsbestosFIRE FELT
Product Type: Sheet/ Block
Fiber Type:
Chrysctile
% Fiber by Weight: Not available
Date Manufactured: 1903
Date Discontinued: 1971 - 1975
Date Labeled:
Product Name: Asbestos Fire Felt
Product Type: Pipe Insulation
Fiber Type:
Chrysotile
% Fiber by Weight: 41.0 - 61.5
Date Manufactured: 1891
Date Discontinued: 1971 - 1975
Date Labeled:
Covering
Product Name: Asbestos Fire Felt
Product Type: Sheet/ Block
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1900
Date Discontinued: 1903 - 1906
Date Labeled: None
Locomotive
Lagging
Prod: ot Name: Asbescos FIRETARD
Product Type: Blankets
Fiber Type:
Chrysotile
% Fiber by Weight: 88.9 - 92.0
Date Manufactured: 1931
Date Discontinued: 1980
Date Labeled: 1970
Product Name: Asbestos Hair Felt
Product Type: Pipe Insulation
Fiber Type:
chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1908
Date Discontinued: 1911 - 1915
Date Labeled: None
Covering
14
Produce :,'ane: A.sbestos Jelly Polls Produce Tvee: 31ar./.ees
H Fiber by Weight: Date Manufactured: Date Discontinued: Date Labeled: None
90.0 1930 1968
Product Name: Asbestos Lining and Deadening
Product Type: Paper, Felt, Blankets
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not available
Date Manufactured: 1900
Date Discontinued: 1903 - 1906
Date Labeled: None
Felt
Product Name: Asbestos Lining Felt
Product Type: Paper, Felt, Blankets
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not available
Date Manufactured: 1871 - 1877
Date Discontinued: 1900
Date Labeled: None
Product Name: Asbestos Locomotive Lagging (Originally
Asbestos Lagging)
Product Type: Paper, Felt, Blankets
Fiber Type:
Unknown (Probably Chrysotile)
'
% Fiber by Weight: Not available
Date Manufactured: 1384
Date Discontinued: 1900
Date Labeled: None
called
Product Name: Asbestos Millboard (In Hard, Medium and Soft Grades) Product Type: Sheet Fiber Type: % Fiber by Weight: Not available Date Manufactured: 1896 Date Discontinued: 1910 Date Labeled: None
Product Name: Asbestos Millboard
Board)
Product Type: Sheet
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
(Originally called
Asbestos
15
Date Manufactured: 1371 - 13 7 5 Date Discontinued: 1356 Date labeled: l^r.e
Product Name: Asbestos Molded Blocks
Product Type: Block
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1900
Date Discontinued: 1915 - 1920
Date Labeled: None
Product Name: Asbestos Moulded Sectional
Product Type: Pipe Insulation
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1891
Date Discontinued: 1915 - 1920
Date Labeled: None
Covering
Product Name: Asbestos "Navy Brand"
Product Type: Sheet/Block
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured; 1902
Date Discontinued: 1915 - 1925
Date Labeled: None
FIRE
FELT
Product Name: Asbestos "Navy Brand"
Product Type: Pipe insulation
Fiber Type:
Chi^sotile
% Fiber by Weight: Not available
Date Manufactured: 1902
Date Discontinued: 1915 - 1925
Date Labeled: None
FIRE
FELT
Covering
Product Name: Asbestos Pipe Blanket
Product Type: Blankets
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: 98.0 - 99.0
Date Manufactured: 1898
Date Discontinued: 1960
Date Labeled: None
Product Name: Product Type:
Asbestos Roll FIRE FELT Felt, Blankets
16
fiber Type:
Chrysotile
'> Fiber by Weirnt: 91.0 - 99.0
**-a-- =
^ci-rsdi 1391
Date Labeled: 1970
Product Name: Asbestos Sectional
Product Type: Pipe Insulation
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1888
Date Discontinued: 1890
Date Labeled: None
Covering
Product Name: Asbestos Sheathing
Product Type: Sheet
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not Available
Date Manufactured: 1869
Date Discontinued:
Date Labeled;
Product Name: Asbestos Sponge Hair
Product Type: Felt
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1893
Date Discontinued: 1900 - 1903
Date Labeled: None
Felt
Product Name: Asbestos Sponge Felt
Product Type: Felt
Fiber Type:
Chrysotile
% Fiber by Weight: 68.0 - 96.2
Date Manufactured: 1890
Date Discontinued: 1961
Date Labeled: None
Product Name: Asbestos Sponge (Felted, Sectional,
Product Type: Sheet/Block, Pipe Insulation
Fiber Type:
chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1890
Date Discontinued: 1953 - 1959
Date Labeled: None
Molded)
17
Produce Name: Asbestos Steam Product Type: Pope riz 2r 7vc2 *
- *--*-=* *** "=--*3**-* **w ** Date Manufactured: 1371 Date Discontinued: Date Labeled:
Packing --
Product Name: Asbestos Turbine Blanket
Product Type: Paper, Felt, Blankets
Fiber Type:
Amosite
% Fiber by Weight: 98.0 - 99.0
Date Manufactured: 1951
Date Discontinued: 1977
Date Labeled: 1971
Product Name: Besto-Tak
Product Type: Tape
Fiber Type:
Unknown (Probably
% Fiber by Weight: 75.0 - loo.o
Date Manufactured: 1959 - 1963
Date Discontinued: 1975 - 1978
Date Labeled: 1972
Chrysotile)
Product Name: Body Sealer
Product Type: Sealing Compound
Fiber Type:
Chrysotile
% Fiber by Weight: 37.0 - 41.0
Date Manufactured: 1954
Date Discontinued: 1975
Date Labeled: None
Product Name: BRANCHTITE
Product Type: Sealing Compound
Fiber Type:
Chrysotile
% Fiber by Weight: 50.0
Date Manufactured: 1954
Date Discontinued: 1974
Date Labeled: None
Product Name: C Asbestos Millboard
Product Type: Sheet
Fiber Type:
Chrysotile
% Fiber by Weight: 60.2 - 67.6
Date Manufactured: 1918
Data Discontinued: 1980
Date Labeled: 1970
18
rca _cc -yp e : a * ;
Fiber Type:
Chrysotile
% Fiber by Weight: 50.0 -
Date Manufactured: 1910
Date Discontinued: 1973
Date Labeled: 1970
98.0
Product Name: CELLAMITE
Product Type: Felt
Fiber Type:
Chrysotile
% Fiber by Weight:
Date Manufactured: 1939 -
Date Discontinued: 1959 -
Date Labeled: None
1947 1963
Product Name: CHAMPION Sectional
Product Type: Pipe Insulation
Fiber Type:
Chrysotile
% Fiber by Weight: up to 59.0
Date Manufactured:
Date Discontinued:
Date Labeled:
Covering
Product Name: Commercial Grade
Product Type: Rope
Fiber Type:
Chrysotile
% Fiber by Weight: 75.0 - 80.0
Date Manufactured: 1884
Date Discontinued: 1982
Date Labeled: 1972
(566,
702,
733,
787)
Product Name: Commercial Grade
Product Type: Cloth
Fiber Type:
Chrysotile
% Fiber by Weight: 75.0 - 80.0
Date Manufactured: 1884
Date Discontinued: 1982
Date Labeled: 1972
Asbestos
cloth
Product Name: Commercial
Product Type: Paper
Fiber Type:
Chrysotile
X Fiber by weight: 95.0
Data Manufactured: 1929
Grade
Asbestos
Paper
19
X
Date Discontinued: 1980 Date Labeled: 1970
Product Name: Commercial Graae
Product Type: Tape
Fiber Type:
Chrysotile
% Fiber by Weight: 75.0 - 80.0
Date Manufactured: 1384
Date Discontinued: 1982
Date Labeled: 1970
Asbestos
Tape
Product Marne: Commercial Grade
Product Type: Tubing (Braided)
Fiber Type:
Chrysotile
% Fiber by Weight: 75.0 - 80.0
Date Manufactured: 1884
Date Discontinued: 1982
Date Labeled: 1972
Asbestos
Tubing
Product Name: D.C. FLEXSTONE
Product Type: Felt
Fiber Type:
Chrysotile
% Fiber by Weight: 30.0 - 85.0
Date Manufactured: 1929
Date Discontinued: Approximately
Date Labeled: 1970
1980
Product Name: DEKERAN
Product Type: Board
Fiber Type:
chrysotile
% Fiber by Weight: 29.6 -
Date Manufactured: 1963
Date Discontinued: 1975
Date Labeled: 1970
34.6
Product Name: DOUBLEX Asbestos Paper
Product Type: Paper
Fiber Type:
Chrysotile
t Fiber by Weight: 80.0
Date Manufactured: 1936
Date Discontinued: Approximately 1980
Date Labeled: 1970
Product Name: Product Type:
Fiber Type:
DUXSEAL Sealing Compound Chrysotile
20
% Fiber by Weight: Date Manufactured: Date Discontinued:
52.5 - 69.0 1934 193 2 - Asbestos Content
Product Name; Engineers Insulating
Product Type: Blankets
Fiber Type:
Chrysotile
% Fiber by Weight: Mot available
Date Manufactured: 1926
Date Discontinued: 1956
Date Labeled: Mone
Tape
Product Name: EQUALITY
Product Type: Sheet/Block
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not available
Date Manufactured: 1908
Date Discontinued: 1908 - 1911
'
Date Labeled: None
Product Name: EUREKA Covering
Product Type; Pipe Insulation
.
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not available
Date Manufactured: 1903
Date Discontinued: 1915 - 1920
Date Labeled: None
Product Name: EXPRESS Covering
Insulation)
Product Type: Pipe Insulation
Fiber Type:
Chrysotile
% Fiber by Weight: up to 59.0
Date Manufactured;
Date Discontinued:
Date Labeled:
(See Wool
Felt
sectional
Pipe
Product Name: FIBROFIL
Product Type: Cement
Fiber Type:
Chrysotile
% Fiber by weight: 30.0
Date Manufactured: 1940
Date Discontinued: 1969
Date Labeled: None
21
#
Product Name: FIBROID Asbestos Paper
Product Type: Paper
Fiber Type:
Fbrysotiis
~ 'ber o--' ''?icr.t : -" .~
Fate Manufactu rad: 1311
Date Discontinued: Approximately 1980
Date Labeled: 1970
Product Name: Fibrous Adhesive
Product Type: Cement
Fiber Type:
Chrysotile
% Fiber by Weight: 14.0 - 20.0
Date Manufactured: 1887
Date Discontinued: 1981 - Asbestos
Date Labeled: None
Content
Product Name: FIL-INSUL
Product Type: Cement
Fiber Type:
Chrysotile and/or
% Fiber by Weight: 70.0 - 80.0
Date Manufactured: 1930
Date Discontinued: 1969
Date Labeled: None
Amosite
Product Name: Fine Corrugated ASBESTOCEL
Product Type: Sheet/Block, Pipe Insulation
Fiber Type:
Chrysotile
% Fiber by Weight: 52.6 - 98.0
-
Date Manufactured: 1923
Date Discontinued: 1971 - 1975
Date Labeled:
Product Name: FIREITE Furnace
Product Type: cement
Fiber Type:
Chrysotile
% Fiber by Weight: 1.8 - 3.7
Date Manufactured: 1924
Date Discontinued: 1973
Date Labeled: None
Cement
Product Name: Flat TRANSITE
Product Type: Board
Fiber Type:
Chrysotile and/or
% Fiber by Weight: 22.0 - 69.2
Date Manufactured: 1907
Date Discontinued: 1985
Date Labeled: 19-70
Amosite
22
Produce .Vane: :LEX30ARC
Produce Type: 3card
Purer Type:
Chrysctu..=
% Fiber by Weight: 33.0 -
Date Manufactured: 1927
Date Discontinued: 1983
Date Labeled: 1970
50.0
Product Name: Flexible MIN-K
Product Type: Sheet
Fiber Type:
Amosite
% Fiber by Weight: 20.0
Date Manufactured: 1963
Date Discontinued: 1975
Date Labeled: 1970
Product Name: Heat Treating Cement
Product Type: cement
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: 1.0
Date Manufactured: 1954
Date Discontinued: 1973
Date Labeled: None
Product Name: High Strength FIBROID Asbestos
Product Type: Paper
Fiber Type:
Chrysotile
J
% Fiber by Weight: 85.7 - 88.0
Date Manufactured: 1930
Date Discontinued: Approximately 1980
Date Labeled: 1970
Paper
Product Name: High Temperature
Product Type: Blankets
Fiber Type:
Amosite
% Fiber by Weight: 20.0
Date Manufactured: 1963
Date Discontinued: 1974
Date Labeled: 1970
Flexible
MIN-K
Blankets
Product Name: High Temperature Insulation
Product Type: Block, Pipe Covering
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not available
Date Manufactured: 1924
23
Date Discontinued: 1926 Date Labeled: None
Product Type: Sealing Compound
Fiber Type:
Chrysotile
% Fiber by Weight: 27.0
Date Manufactured: 1955
Date Discontinued: 1975
Date Labeled: None
Product Name: H-NAVASEAL
Product Type: Sealing Compound
Fiber Type:
Chrysotile
% Fiber by Weight: 48.0
Date Manufactured: 1951
Date Discontinued: 1975
Date Labeled: None
Product Name: INDENTED
Product Type: Pipe Insulation
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not available
Date Manufactured: 1908
Date Discontinued: 1924
Date Labeled: None
Product Name: Industrial Vent Caulking
Product Type: Sealing Compound
Fiber Type:
chrysotile
% Fiber by Weight: 53.0
Date Manufactured: 1957
Date Discontinued: 1974
Date Labeled: None
Product Name: INSULKOTE ET
Product Type: Finishes
Fiber Type:
Chrysotile
% Fiber by Weight: 11.7 - 15.5
Date Manufactured: 1929
Date Discontinued: 1982
Date Labeled: None
Product Name: Product Type: Fiber Type:
INSULKOTE SG
Finishes Chrysotile
% Fiber by Weight: 14.7 - 16.7 Date Manufactured: 1929 Data Discontinued: 1992 Data Daceled: None
Product Name: INSULKOTE ST
Product Type: Finishes
Fiber Type:
Chrysotile
% Fiber by Weight: 6.2 - 21.0
Date Manufactured: 1929
Date Discontinued: 1982
Date Labeled: Hone
Product Name: LAPTITE
Product Type: cement
Fiber Type:
Chrysotile
% Fiber by Weight: 10.0 -
Date Manufactured: 1938
Date Discontinued: 1954
Date Labeled: None
16.9
Product Name: Long Fiber Asbestos Paper
Product Type: Paper
Fiber Type:
Chrysotile
% Fiber by Weight: 88.0 - 98.5
Date Manufactured: 1930
Date Discontinued: Approximately 1980
Date Labeled: 1970
Product Name: MAGNO
Product Type: Sheet/Block
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not available
Date Manufactured: 1908
Date Discontinued: 1908 - 1911
Date Labeled: None
Product Name: MARIMET 45 Product Type: Board Fiber Type: Amosite % Fiber by Weight: 43.0 Date Manufactured: 1970 Date Discontinued: 1985 Date Labeled: 1970
44.0
Product Name: MARINITE 25
Produce Type: Fiber Type: h Fiber cv v.'e
Board Amos ite and/or Chrysotiie he: 40.0 - 50.0
Dace Labeled: 1970
.'.O w e d
Product Name: MARINITE 23 Product Type: Board Fiber Type: Amosite % Fiber by Weight: 25.0 Date Manufactured: 1955 Date Discontinued: 1975 -
Date Labeled: 1970
27.0 Asbestos
Content
Product Name: MARINITE 30
Product Type: Board
Fiber Type:
Amosite
% Fiber by Weight: 49.7 -
Date Manufactured: 1949
Date Discontinued: 1970
Date Labeled: None
50.0
Product Name: MARINITE 36
Product Type: Board
Fiber Type:
Amosite and/or Chrysotiie
% Fiber by Weight: 29.7 - 57.0
Date Manufactured: 1955 Date Discontinued: 1975 - Asbestos Content
Date Labeled: 1970
Product Name: MARINITE 65
Product Type: Board
Fiber Type:
Chrysotiie and/or Amosite
% Fiber by Weight: 55.5 - 70.0
Date Manufactured: 1955 Date Discontinued: 1975 - Asbestos Content
Date Labeled: 1970
Product Name: Marine Acoustical
Product Type: Board
Fiber Type:
chrysotiie
% Fiber by Weight: 33.0
.
Date Manufactured: 1941
Date Discontinued: 1975-73
Date Labeled: 1970
Unit
26
Produce Name: Marine '.'ensar
P r : : u : : _% c 0 dc 2 1r -*
r_~r r/ce;
C*irysoc^-e
% Fiber by Weight: 31.0 - 51.o
Date Manufactured: 1938 Date Discontinued: 1985 - Asbestos content
Date Labeled: 1970
.
Product Name: Metal Veneered MARINITE
Product Type: Board
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: 15.0 - 40.0
Date Manufactured: 1951
Date Discontinued: 1973
Date Labeled: 1970
Product Name: METAL-ON
Product Type: Jackets
Fiber Type:
chrysotile
% Fiber by Weight: 7.0 -
Date Manufactured: 1959
Date Discontinued: 1974
Date Labeled: 1966
.
and/or 14.3
. Amosite
Product Name: MICROBESTOS
Product Type: Paper
Fiber Type:
chrysotile
% Fiber by Weight: 40.0 - 97.0
Date Manufactured: 1959 Date Discontinued: Approximately
Date Labeled: None
1980
Product Name: MIN--K 500
Product Type: Sheet/Block
Fiber Type:
Amosite
% Fiber by Weight: 5.0
Date Manufactured: 1958
Date Discontinued: 1977
Date Labeled: 1970
Product Name: MIN-K 1301
Product Type: Sheet/Block
Fiber Type:
Amosite
% Fiber by weight: 5.0 - 12.0
Date Manufactured: 1958
Date Discontinued: 1975
27
Date Labeled: 1 9 7 0
:cr Type: .-.es-,3~~ Z; Fiber Type: ` Amosite % Fiber by weight: 5.0 Date Manufactured: 1959 Date Discontinued: 1975 Date Labeled: 1970
12.o
Product Name: MIN-KLAD
Product Type: Blankets
Fiber Type:
Amosite
% Fiber by Weight: 5.0
Date Manufactured: 1958
Date Discontinued: 1972
Date Labeled: 1970
Product Name: MOLTEN METAL MARINITE
Product Type: Board
Fiber Type:
Amosite
% Fiber by Weight: 38.0 - 40.o
Date Manufactured: 1962
Date Discontinued: 1980
Date Labeled: 1970
Product Name: MX--3808 Asbestos
Product Type: Cement
Fiber Type:
Chrysotile
% Fiber by Weight: 52.0 - 55.0
Date Manufactured: 1951
Date Discontinued: 1970
Date Labeled: 1965
Filler
Product Name: MX 4851 (Aluminized)
Product Type: Cloth
Fiber Type:
Chrysotile
% Fiber by Weight: 75.0
Date Manufactured:
Date Discontinued:
Date Labeled: None
Cloth
Coated)
Product Name: MX 5184 Cloth
Product Type: Cloth
Fiber Type:
chrysotile
% Fiber by Weight: 65.0
(Coated!
28
Date Manufactured: 1971 Date Discontinued: Dsoe labeled : ''one
Product Name: MX 5215 Cloth
Product Type: Cloth
Fiber Type:
chrysotile
% Fiber by Weight: 69.0
Date Manufactured: 1971
Date Discontinued:
Date Labeled: None
(Coated)
Product Name: MX 5243 Cloth
Product Type: Cloth
Fiber Type:
Chrysotile
% Fiber by Weight: 65.0
Date Manufactured:
Date Discontinued:
Date Labeled: None
(Coated)
Product Name: MX 5385 Cloth
Product Type: Cloth
Fiber Type:
chrysotile
% Fiber by Weight: 50.0
Date Manufactured:
Date Discontinued:
Date Labeled: None
(Coated)
Product Name: NATIONAL Sectional covering
Product Type: Pipe Insulation
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not available
Date Manufactured: 1891
Date Discontinued: 1900 - 1903
Date Labeled: None
Product Name: Navy 450 Cement
Product Type : Cement
Fiber Type:
Chrysotile
% Fiber by Weight: 13.5 - 38.5
Date Manufactured: 1941 _
Date Discontinued: Not Active about
Date Labeled: 1965
1972
P ro d u ct Name: Product Type:
NIAGPITE Felt, Blankets
29
Fiber Type:
Chrysotile
V Fiber by Weight: 93,0
Fate Manufactured: 1911
Fite Fisccr.tfr.uac:
Fate Faceied: 1370
Product Mane: NODRSEAL
Product Type: Sealing Compound
Fiber Type:
Chrysotile
% Fiber by Weight: 50.0 - 59.4
Date Manufactured: 1947
Date Discontinued: 1975
Date Labeled: None
Product Name: Non-Burn Asbestos Paper
Product Type: Paper
Fiber Type:
Chrysotile
% Fiber by Weight: 95.0 - 97.0
Date Manufactured: 1900
Date Discontinued: Approximately 1980
Date Labeled: 1970
Product Name: PALLITE
Product Type: Board
Fiber Type:
Amosite
% Fiber by Weight: 50.0
Date Manufactured: 1937
Date Discontinued: 1973
Date Labeled: 1970
Product Name: PERFECTION Pipe Covering
Product Type: Pipe Insulation
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not available
Date Manufactured: 1903
Date Discontinued: 1908 - 1911
Date Labeled: None
Product Name: REEFERITE
Product Type: Board
Fiber Type:
Chrysotile
% Fiber by Weight: 29.0 -
Date Manufactured: 1950
Date Discontinued: 1974
Date Labeled: 1970
37.0
30
Product Name: Safety Blow-Off covering
Product Type: Pipe Insulation
_
liter Type:
Unknown 'Probably Chryscoile;
" irar ry '..'aient: Not i/ailiola
.as Manufactured: 1903
Date Discontinued: 1915 - 1920
Date Labeled: None
Product Name: Silicatea THERMOBESTOS
Product Type: Sheet/Block, Pipe Covering
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: 7.0 - 14.3
Date Manufactured: 1966
Date Discontinued: 1974
Date Labeled: 1966
Product Name: SONITE
Product Type: Block
Fiber Type:
Amosite
% Fiber by Weight: 5.0
Date Manufactured: 1969
Date Discontinued: 1975
Date Labeled: 1970
Product Name: Standard Flexible MIN-K
Product Type: Paper, Felt, Blankets
Fiber Type:
Amosite
% Fiber by Weight: up to 20.0
Date Manufactured: 1963
-
Date Discontinued: 1974
Date Labeled: 1970
Blankets
Product Name: STANDARD Sectional
Pipe Insulation) Product Type: Pipe Insulation
Fiber Type: % Fiber by Weight: up to 59.0 Date Manufactured: Date Discontinued: Date Labeled:
Covering
(See Wool
Felt
Sectional
Product Name: Stove Putty
Product Type: Sealing Compound
Fiber Type:
chrysotile
% Fiber by Weight: 15.0 - 25.0
Date Manufactured: 1934
Date Discontinued': 1971
31
Data Labeled: N o n e
Product Type: Board Fiber Type: % Fiber by Weight: Not available Date Manufactured: 1963 Date Discontinued: 1967 Date Labeled: None
Product Name: Super FIRE FELT
Product Type: Sheet/BlocJc, Paper, Felt,
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: 40.0 - 60.0
Date Manufactured: 1925
Date Discontinued: 1971 - 1975
Date Labeled:
Blanket
Product Name: SUPEREX 1900
Product Type: Sheet/Block
Fiber Type:
Chrysotile and/or
Fiber by Weight:
10.0 - 12.0
Date Manufactured: 1922
Date Discontinued: 1973
Date Labeled: 1965
Amosite
Product Name: SUPEREX 2000
Product Type: Sheet/Block
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: 9.0 - 12.0
Date Manufactured: 1971
Date Discontinued: 1972 - Asbestos content
Date Labeled: 1971
Product Name: SUPEREX Cement
Product Type: Cement
Fiber Type:
Chrysotile and/or
% Fiber by Weight: 8.4 - 15.0
Date Manufactured: 1922
Date Discontinued: 1973
Date Labeled: 1965
Amosite
Product Name: Superex Cement for Navy
Product Type: Cement
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: 7.0 - 20.0
32
Date Manufactured: 1941 Date Discontinued: 1957 line Lscelsd: 1965
Product Name: SUPEREX-M
Product Type: Sheet/Block, Pipe
Fiber Type:
Chrysotile and/or
% Fiber by Weight: 8.4 - 15.0
Date Manufactured: 1930
Date Discontinued: 1971
Date Labeled: 1965
Insulation Araosite
Product Name: SUPEREX-SG
Product Type: Sheet/Block
Fiber Type:
Chrysotile and/or
% Fiber by Weight: 10.0
Date Manufactured: 1969
Date Discontinued: 1973
Date Labeled: 1966
Amosite
Product Name: THERM-o-BESTOS
Product Type: Sheet/Block, Pipe Insulation
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: Not available
Date Manufactured: 1937
Date Discontinued: 1947
Date Labeled: None
Product Name: THERMOBESTOS
Product Type: Block, Pipe Covering
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: 7.0 - 14.3
Date Manufactured: 1950
Date Discontinued: 1974
Date Labeled: 1964
Product Name: Thermobestos Cement
Product Type: Cement
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: 7.0 - 14.3
Date Manufactured: 1959
Date Discontinued: 1969
Date Labeled: None
Product Name: THERMO FELT Product Type: Felt
33
Fiber Type:
Unknown (Probably Chrysotile)
% Fiber by Weight: Not available
Fare Manufactured: 1931
I *sccr.zir.usc i
Product Name: Thermo FIRE FELT
Product Type: Sheet/Block
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1908
Date Discontinued: 1936
Date Labeled: None
Product Name: THERMOMAT
Product Type: Felt, Tape
Fiber Type:
Amosite and/or Chrysotile
% Fiber by Weight: 49.6 - 96.0
Date Manufactured: 1931
Date Discontinued: 1971 - 1975
Date Labeled:
Product Name: Thermomix 700
Product Type: Cement
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1966
Date Discontinued: I S `0
Date Labeled: 1970
Product Name: Thermomix 720
Product Type: Cement
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1966
Date Discontinued: 1970
Date Labeled: 1970
Product Name: Thermomix 770
Product Type: Cement
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1966
Date Discontinued: 1970
Date Labeled: 1970
34
Product Name: Thermomix 310
Product Type: Cement
Fiber Tvoe:
Crccideiirs
' T i b e r b v **^ ^ zr.z ' " z~. z' ~ \
Cate Manufaccused: 1355
Date Discontinued: 1970
Date Labeled: 1970
Product Name: Thermo-Pac 500 (Twisted
Product Type: Rope
Fiber Type:
Chrysotile
% Fiber by Weight: 75.0 - 30.0
Date Manufactured: 1917
Date Discontinued: 1983
Date Labeled: 1972
Asbestos
Rope
Packing)
Product Name: Thermo-Pac 750
Product Type: Rope
Fiber Type:
Chrysotile
% Fiber by Weight: 95.0 - 98.0
Date Manufactured: 1969
Date Discontinued: 1982
Date Labeled: 1972
Product Name: Thermo-Pac 1000
Product Type: Rope
Fiber Type:
Chrysotile
% Fiber by Weight: 98.0 - 100.0
Date Manufactured: 1917
Date Discontinued: 1983
Date Labeled: 1972
Product Name: Thermo-Pac Blue
Product Type: Rope
Fiber Type:
Crocidolite
% Fiber by Weight: 100.0
Date Manufactured: 1917
Date Discontinued: 1973
Date Labeled: 1972
Product Name: THERMOTAPE
Product Type: Tape
Fiber Type:
Chrysotile and/or
% Fiber by Weight: 75.0 - 30.0
Date Manufactured: 1951
Date Discontinued: 1971 - 1975
Date Labeled:
Amosite
35
rrciuc*
Thsrrr.c--*.*r2 o
T!"!1 -r" 7''~a ' ['.sat j17r.`. 712T..13U
Fiber Type*: Unknown (Procably Chrysotile;
% Fiber by Weight: Not available
Date Manufactured: 1939-1950
Date Discontinued: 1971-1975
Date Labeled:
Product Name: THERMOWRAP
Product Type: Blankets
Fiber Type:
Chrysotile and/or
% Fiber by Weight: 90.0
Date Manufactured: 1951
Date Discontinued: 1971 - 1975
Date Labeled:
Amosite
product Name: TRANOSEAL (TRANOLSEAL)
Product Type: Sealing Compound
Fiber Type:
Chrysotile
% Fiber by Weight: 38.0 - 47.1
Date Manufactured: 1947
Date Discontinued: 1974
Date Labeled: None
Product Name: TRANSITE Acoustical
Product Type: Board
Fiber Type:
Chrysotile
% Fiber by Weight: 33.0
Date Manufactured: 1937
Date Discontinued: 1974
Date Labeled: 1970
Panel
Product Name: TRANSITE Core Plate
Product Type: Board
Fiber Type:
Chrysotile and/or Amosite
% Fiber by Weight: 52.0 - 71.0
Date Manufactured: 1938
Date Discontinued: 1985
Date Labeled: 1970
Product Name: Type A Asbestos Millboard
Product Type: Sheet
Fiber Type:
Chrysotile
% Fiber by Weight; 95.7 - 99.0
Date Manufactured: 1918
36
Date Discontinued; 1980 Date Labeled: 1970
- Z
' ; C c - .*w ^ \w
Product Type: Sealing Compound
Fiber Type:
chrysotile
% Fiber by Weight: 50.0 - 55.0
Date Manufactured: 1954
Date Discontinued: 1975
Date Labeled: None
Product Name: Underwriter's Grade
Product Type: Cloth
Fiber Type:
chrysotile
% Fiber by Weight: 80.0 - 85.0
Date Manufactured: 1884
Date Discontinued: 1974
Date Labeled:
Asbestos
Cloth
Product Name: Underwriter's Grade
Product Type: Tape
Fiber Type:
Chrysotile
% Fiber by Weight: 80.0 - 85.0
Date Manufactured: 1884
Date Discontinued: 1983
Date Labeled:
Asbestos
Tape
Product Name: Underwriter's Grade
Product Type: Tubing (Braided)
Fiber Type:
Chrysotile
% Fiber by Weight: 80.0 - 85.0
Date Manufactured: 1884
Date Discontinued: 1982
Date Labeled:
Asbestos
Tubing
Product Name: UNISEAL
Product Type: Sealing Compound
Fiber Type:
Chrysotile
% Fiber by Weight: 53.0 - 59.0
Date Manufactured: 1947
Date Discontinued: 1975
Date Labeled: None
Product Name: Product Type: Fiber Type;
Unspecified Grade, Originally Offered cloth Chrysotile
37
% Fiber by weight: Date Manufactured: Date Discontinued: Date lataiad:
1371 - 1375
Product Name: Veneered MARINITE
Product Type: Board
Fiber Type:
Amosite and/or Chrysotile
% Fiber by Weight: 16.0 - 41.0
Date Manufactured: 1955
Date Discontinued: 1975 - Asbestos Content
Date Labeled: 1970
Product Name: VITRIBESTOS
Product Type: Sheet/Block
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1908
Date Discontinued: 1959
Date Labeled: None
Product Name: Vitro FIRE FELT
Product Type: Sheet/Block
Fiber Type:
Chrysotile
% Fiber by Weight: Not available
Date Manufactured: 1908
Date Discontinued: 1936
Date Labeled: None
Product Name: Welding Paper
Product Type: Paper
Fiber Type:
Chrysotile
% Fiber by Weight: 99.0
Date Manufactured: 1930
Date Discontinued: Approximately
Date Labeled: 1970
1980
Product Name: White Surface
Product Type: Jacket
Fiber Type:
Chrysotile
% Fiber by Weight: 82.0
Date Manufactured: 1931
Date Discontinued: 1971
Date Labeled: None
Asbestos
Jacket
Product Name:
XXX Asbestos Millboard
33
Product Type Fiber Type:
~
^ 2T Z * r
- '
Zata Ziscctt Date Labeled
Sheet Chrysotile r.o : 5~ . "
uaa : 3 o u
1970
39