Document 3JrREoooME714DBODzmapYXM0
^FNTft'-L
IL017.ASB
IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS
JUI.16 1987 J
JdiRR. Of' U3tU)U. .UHJRtf
fTHAD JUDfOAi: CRGUrQ <a**&*OM COfEODOt ftWMOM
ROY CARSON, BRUCE LUSK, EDWARD MEINERS, and WILLIAMS ADAMS through LEWIS FLEURY,
-vs-
ANCHOR PACKING COMPANY, et al
NOS. 86-L-824, 86-L-83 6, 86-L-834, 86-L-1827 through 86-L-2 458
DEFENDANT, OWENS-ILLINOIS, INC.'S ANSWERS TO INTERROGATORIES TO DEFENDANTS
PRELIMINARY STATEMENT
Some of the events which may be relevant to the matters inquired about by Plaintiffs' Interrogatories apparently occurred more than thirty-five years ago. In addition, effective April 30, 1958, Owens-Illinois, Inc. disposed of the business involved in this action by way of sale of that business to OwensCorning Fiberglas Corporation. Since that time, Owens-Illinois, Inc. has not engaged in any such business. It does not now and it has not since that sale manufactured, distributed or sold any asbestos-containing products. As a result of the foregoing factors, many of the individuals who might have had personal knowledge of the matters to which Plaintiffs' Interrogatories relate are deceased.
1 HRV-PL-1510
or are otherwise unavailable to Owens-Illinois, Inc., and investigations to date indicate that at least some documents which relate to matters inquired about by these interrogatories may have been transferred to Owens-Corning Fiberglas Corporation with the transfer of the business in question in 1958. OwensIllinois, Inc. is engaged in a continuing investigation in an attempt to locate, confirm the transfer of, or confirm the absence of, such documents and is also engaged in a continuing investigation into the matters inquired about in these interrogatories. Unless otherwise stated in an answer to a specific interrogatory, the answers set out hereinafter are limited to the period during which Owens-Illinois, Inc. manufactured asbestos-containing insulation products and to the facilities related to that business. The following is a part of and is incorporated by reference in every answer provided hereinafter:
This answer is accurate as of the date made. However, Owens-Illinois, Inc.' s investigation is continuing, and Owens-Illinois, Inc. cannot exclude the possibility that it may be able to obtain more complete information or even information which indicates that the answer being supplied is incorrect. OwensIllinois, Inc. objects to answering this interrogatory in regard to any period of time other than the period during which it engaged in the business involved in this case which ended in mid-1958 or concerning any facility not related to that business, on the basis that any such answer would be irrelevant to the subject matter of the pending litigation, would not be reasonably calculated to lead to the discovery of admissible evidence, and would be burdensome and oppressive.
2
HRV-PL-X5XX
Furthermore, Owens-Illinois, Inc. objects to the instructions and definitions supplied by plaintiffs with regard to these interrogatories, on the basis that the definitions are overbroad, vague, and often inconsistent with the normal usage and meaning of such words, and the instructions are overbroad, burdensome and constitute an unreasonable expansion of the interrogatories themselves. Owens-Illinois, Inc. therefore gives notice that it does not consider itself bound by the instructions and definitions propounded by plaintiffs, and instead shall answer the interrogatories in a manner consistent with a normal understanding of the language used in the answer and to the extent necessary to fairly and fully answer the interrogatory.
Q. 1.
As to the person answering these
interrogatories, state:
(a) Name;
(b) Title or positionwith 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;
(f) The years during which defendants have
been licensed to do business within the State of Illinois, or
State of Missouri and with regard to such years please state:
(1) The type of business conducted
within the State of Illinois or State of Missouri;
(2) The names and addresses of any
franchise holders, dealers, or customers located in the State of
Illinois or State of Missouri during the last three years;
(3) Whether or not defendant
directly or indirectly supplies the persons or entities
identified in 1(f)(2) with any products or services; if so,
please describe the relationship between defendant and those
3
HRV-PL-1512
persons or entities and state the approximate dollar value of defendant's 1930 to present sales to them.
A. 1.
(a-e) Michael F. McCarthy, Assistant
Secretary of Owens-Illinois, Inc., One SeaGate, Toledo, Ohio
43666.
(f) This defendant objects to this
interrogatory on the basis that it seeks information which is not
relevant to the subject matter of this litigation and is not
reasonably calculated to lead to the discovery of admissible
evidence. Without waiving the above objection, this defendant
was authorized to do business in Illinois in 1929 and in Missouri
in 1958.
Q. 2.
Has the person answering these
interrogatories made reasonably inquiry of all available sources
of information such that plaintiff may rely on these answers as
the truthful and complete answers made on behalf of this
answering defendant? state the proper legal name and the present
address of the principal place of business of each of defendant's
related companies. For each related company identified, please
state:
(a) Whether or not the company is licensed
to do business in the State of Illinois;
(b) The business relationship between the
company and defendant;
(c) The nature of the products or services
that defendant sells to or purchases from the company;
(d) The type of business of the company
conducts within the state of Illinois;
(e) Whether or not the company advertises
defendant's products or services within the State of Illinois;
(f) Whether or not the company sells
defendant's products or services within the State of Illinois;
4
HBV-PL,- 1513
and, if so, the approximate value of those sales or sales during 1930 to present;
(g) Whether or not the company pays any type of taxes to the State of Illinois or any political body located within the State of Illinois;
(h) Whether or not defendant has any control, directly or indirectly, over the company's advertising of defendant's products or services.
A. 2.
This defendant states that it has referred to
the relevant business records of the Owens-Illinois Glass
Company, which are still in the possession of Owens-Illinois,
Inc., in connection with the preparation of answers to these
interrogatories unless otherwise indicated.
This defendant's name is Owens-Illinois, Inc. The
address of the principal place of business is One SeaGate,
Toledo, Ohio 43666.
This defendant objects to further answering this
interrogatory on the basis that it seeks information which is not
relevant to the subject matter of this litigation and is not
reasonably calculated to lead to the discovery of admissible
evidence. Defendant ceased all involvement in the asbestos-
containing product business in 1958.
Q. 3.
State the following concerning this
defendant:
fa) Full and correct name;
(b) Principal place of business;
` (c) State of incorporation;
(d) Date of incorporation, and name of
Corporation;
(e) Is this defendant authorized to
transact business in the State of Illinois? If so, state the
date such authority was first issued and last renewed;
5
HRV-PL-1514
(f) Does this defendant have an agent,
representative or place of business in Illinois? If so, state
the name and address of such agent, representative, or other
place of business;
(g)
Does this defendant have an agent for
service in the State of Illinois? If so, state the name and
address of the registered agent.
A. 3.
(a-e) Owens-Illinois Glass Company was
incorporated in the State of Ohio in 1929. Owens-Illinois Glass
Company changed its name to Owens-Illinois, Inc. on April 28,
1965. Owens-Illinois, Inc. was acquired pursuant to a tender
offer dated 3/16/87 and is now a Delaware corporation. The
address of the principal place of business is One SeaGate,
Toledo, Ohio 43666. Refer to answer to Interrogatory No. 1.
(f,g) Yes, CT Corporation System, Chicago,
Illinois, 60604.
Q. 4.
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. 3 above
concerning the defendant as correctly named.
A. 4.
This defendant does not contest service.
Q. 5.
Has this defendant ever acquired through
purchase, reorganization or merger another corporation, company,
or business which manufactured, sold, processed, distributed or
contracted to - apply asbestos products?
A. 5.
No. However, Owens-Illinois Glass Company
changed its name to Owens-Illinois, Inc. on April 28, 1965.
Q. 6.
If the answer to Interrogatory No. 5 is
"yes", then state the following concerning such predecessor:
6
HRV--PL--1515
(a) Full and correct name; (b) The principal 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 Illinois? (f) Attach copies of all papers pertaining to the acquisition.
A. 6.
Refer to answer to Interrogatory No. 5.
Q. 7.
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) Relabeled such a product which was
manufactured, sold, or distributed by another company?
A. 7.
(a) This defendant has in its records
technical reports relating to the development and testing of
Kaylo, and will make available to plaintiffs' counsel through its
local counsel these records. Many of the reports are contained
on microfilm which is old and of poor quality. Adequate copies
may not be made from it, and reading it requires a reader device.
This defendant further states that its investigation into the
subject matter referred to in this interrogatory is continuing.
(b-e) This defendant engaged in the business
of commercially manufacturing and selling an asbestos-containing
product from 1948 through mid-1958.
(f) This defendant ceased the manufacture,
sale and distribution of asbestos-containing products in 1958.
7
HRV-PL-15 16
Its investigation as to information concerning any such United States Patents is continuing. However, it appears that the following patents may have been related to this defendant's asbestos-containing products at one time:
Patent No.
2,425,610 2,439,724 RE.23,228 2,534,303 2,540,354 2,547,127 2,570,835 2,574,667 2,665,996 2,748,008 2,787,345 2,788,304
Inventor
Finley Finley Frasor Serinis Selden Kalousek Mooney, et al. Shuman Kalousek Kalousek Soubier, et al. Scovronek
Issue Date
8-12-47 4-13-48 5-09-50 12-19-51 2-06-51 4-03-51 10-09-51 11-13-51 1-12-54 5-29-56 4-02-57 4-09-57
(g) This defendant ceased the manufacture, sale and distribution of asbestos-containing thermal insulation products in 1958. This defendant states that in 1953 it entered into a "Sales Agreement" under which it agreed to sell certain amounts of its asbestos-containing thermal insulation products to Owens-Corning Fiberglas Corporation. Furthermore, this defendant has found information in its records which indicate that in at least 1956, it placed Owens-Corning Fiberglas Corporation's logo on some of its boxes. This defendant does not have information sufficient to further respond to this interrogatory.
` Q. 8.
If your answer to No. 7(b), 7(d) and 7(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.
A. 8.
Owens-Illinois Glass Company began limited
pilot plant operations involving the production of "Kaylo"
asbestos-containing products in 1943. It began the manufacture
of commercial quantities of "Kaylo" asbestos-containing products
8
hrv-pl- a 5 1 *7
in about 1948 and continued such manufacture until about April 30, 1958.
Q. 9.
Have any of the products listed above in
Interrogatory No. 7 been altered in chemical composition since
first being marketed?
A. 9.
This defendant has in its records technical
reports relating to the development and testing of Kaylo, and
will make available to plaintiffs' counsel through its local
counsel these records. Many of the reports are contained on
microfilm which is old and of poor quality. Adequate copies may
not be made from it, and reading it requires a reader device.
This defendant further states that its investigation into the
subject matter referred to in this interrogatory is continuing.
Q. 10. altered;
If so, please state: (a) The trade name of each such product; (b) The date each such product was
(c) The nature of the alteration; (d) The reason for the alteration.
A. 10.
Refer to answer to Interrogatory No. 9.
Q. 11. What is the name, address, and the job title of each individual who participate in the design and preparation of manufacturing specification for each such product?
A. 11.
Refer to answer to Interrogatory No. 9. This
defendant ceased the manufacture, sale and distribution of
asbestos-containing products in 1958. This defendant has not
found information in its records sufficient to enable it to
answer this interrogatory.
9
HRV-PL-1518
Q. 12.
Do any written memoranda, specifications,
blueprints or other written materials of any kind or character
relating to the design and preparation of said products now
exist?
A. 12.
Refer to answer to Interrogatory No. 9.
Q. 13 document; such document;
If so, please state: (a) List each written material or
(b) Who presently has possession of each
(c) Where is it located?
A. 13. Refer to answer to Interrogatory No. 12.
Q. 14. In what year did the defendant first begin selling or distributing any products containing asbestos?
A. 14. Refer to answer to Interrogatory No. 8.
Q. 15.
In what year did the defendant last sell the
any product which contained asbestos?
A. 15.
Effective April 30, 1958, this defendant sold
its asbestos-containing manufacturing division to Owens-Corning
Fiberglas Corporation. As of that time, this defendant ceased
the manufacture, sale and distribution of asbestos-containing
products and has not engaged in any such business since that
date.
Q. 16.
As to the named defendant or any
predecessor(s) or acquired business, state the various types of
products, such as blocks, pipe covering, cements, tape, spray-on
insulation, mastics, and cloth, or any other asbestos-containing
10
HRV-PL-15 19
products in any connection with each type of such product, state how the same was packaged (i.e., bags, boxes, sacks, etc.) for sale.
A. 16.
This defendant ceased the manufacture, sale
and distribution of asbestos-containing products in 1958. it
believes that Kaylo and Kaylo-20 were premolded, rigid products,
and were manufactured in two forms, block and pipe covering.
This defendant believes that some of its asbestos-
containing insulation products were packaged in corrugated
cartons with the trademark Kaylo on the carton. This defendant
ceased the manufacture, sale and distribution of asbestos-
containing products in 1958 and does not have information
sufficient to further answer this interrogatory.
Q. 17.
Is your company, as of the date of answering
these interrogatories, still manufacturing, selling or
distributing any products containing asbestos? If so, give the
brand names of such products, the binding material and date first
manufactured.
A. 17. No. Refer to answer to Interrogatory No. 15.
Q. 18. Were each of your asbestos-containing products generally expected to reach, or were packaged to reach, the consumer or user, without substantial change in the condition in which it was sold?
A. 18. Defendant believes that its product was not expected to be altered before it reached the user.
Q. 19.
If your answer to Interrogatory No. 18 is
"No", with respect to any product, explain in what way the
defendant claims its products were altered or substantially
11
HRV-PL-1520
changed after sale or distribution and before reaching the helper, mechanic or bystander.
A. 19. Refer to answer to Interrogatory No. 18.
Q. 20. Based upon the material contents of your products, the method of manufacturing, and the method of application, can your products be generally applied or installed 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 used, then specify in detail what year or years you are referring to and the specific products you are referring to and the year involved.
A. 20. This defendant's asbestos-containing industrial insulation was manufactured in two forms, block and pipe covering. It was a premolded, rigid product which was not intended or required to be molded or mixed in application. It was manufactured in standard premolded shapes and sizes intended to minimize cutting of pieces in application. It appears that the product was applied by methods including gluing, tieing, strapping, or wiring it to pipe. It appears that a limited amount of its product was cut during application. Roof deck was intended to be laid on or fastened to building frame members and waterproofed. Core material was intended to be used as a center layer for fire doors.
Q. 21.
Was it a foreseeable use of your asbestos-
containing products what they may have to be removed, stripped or
replaced at any time after installation? If your company
12
HRV-PL-15 2 1
contends the plaintiff(s) misused any of your products then state how and under what circumstances your product was misused.
A. 21.
This defendant objects to this interrogatory
on the basis that it seeks information which is not relevant to
the subject matter of this litigation and is not reasonably
calculated to lead to the discovery of admissible evidence. This
defendant further objects to this interrogatory on the basis that
it is vague and no time period as to when the submitted fact was
foreseeable is indicated.
Q. 22.
Prior to releasing the asbestos products
manufactured, sold, etc. to the public for sale, were any tests
conducted on same to determine potential health hazards involved
int eh use of materials contained therein?
A. 22.
This defendant ceased the manufacture, sale
and distribution of asbestos-containing products in 1958 and does
not have any records from which it can obtain information
sufficient to answer this interrogatory.
During May, 1979, various papers and reports were
produced by an employee of the Trudeau Institute, Mr. Allan
Logie, regarding animal experiments conducted at laboratories at
Saranac Lake involving dust collected during the Kaylo
manufacturing process. These papers and reports may contain
information relating to the substance of this interrogatory.
This defendant has not been able to find these papers and reports
in its business records or correspondence although it has
searched for and continues to search for them.
This defendant's counsel obtained copies of some of the
papers and reports produced by Mr. Logie. However, these copies
constitute only a portion of a larger volume of papers and
reports which this defendant has not copied. They are available
at Milbank, Tweed, Hadley & McCloy, 1 Chase Manhattan Plaza, New
York, New York. This defendant also has reason to believe that
13
HRV-PL-15 2 2
plaintiffs' counsel has copies of the documents produced by Mr.
Logie. Other documents possibly relating to this interrogatory
may have been produced by Owens-Corning Fiberglas Corporation in
the asbestos litigation.
Those documents found at Saranac Lake and at Owens-
Corning Fiberglas Corporation and elsewhere, indicate that during
the period of time when Owens-Illinois was in the business of
manufacturing asbestos-containing products, the state of
government, industrial hygiene and medical community knowledge
was that there was a recognized safe exposure level for asbestos
dust and that persons installing insulation were not exposed to
excessive or hazardous levels of asbestos dust. The foregoing
documents also indicate that Kaylo plant employees were x-rayed
periodically and displayed no asbestos-related chest disease;
that this defendant made appropriate efforts to provide
ventilation and to control the emissions of all dust omitted
during the manufacturing process within recognized safe levels of
exposure, including the use of respirators in some instances,
dust collection equipment and other devices as necessary; and
that therefore during the period in which this defendant was in
the business of manufacturing Kaylo it had no reason to believe
that the foreseeable use of Kaylo would create a hazard to users.
The documents produced by Owens-Corning Fiberglas
Corporation indicate that the September, 1955 publication in the
A.M.A. Archives of Industrial Health was a publication of
inhalation experiments.
,
To the extent that this interrogatory seeks the
production of documents, such documents, as outlined in this
response, have not been found as part of this defendant's records
and, to the extent that this defendant is in possession of copies
of documents, it possesses copies only of documents collected in
preparation for litigation. This defendant objects to producing
the same. The documents are available from their proper source.
Q. 23.
If so please state: 14
HRV-PL-1S 2 3
(a) The name, address, and job classification of each individual who conducted such tests.
(b) The results of such said tests. (b) Date of such studies.
A. 23.
Refer to answer to Interrogatory No. 22.
Q. 24.
Do any written memoranda, specifications,
blueprints or other written materials of any kind or character
exist relating to the testing of said product?
A. 24. This defendant objects to this interrogatory on the grounds that it is vague and ambiguous in that it does not indicate what type of testing about which it seeks information. Without waiving the above objection, refer to answers to Interrogatory Nos. 9 and 22.
Q. 25.
If so, please state:
(a) List each such written material or
document.
(b) Who presently has possession of each
such document and where it is located.
A. 25. Refer to answer to Interrogatory No. 24.
Q. 26.
Did defendant, or any of its subsidiary
companies make any design changes as a result of such tests?
A. 26. This defendant objects to this interrogatory on the grounds that it is vague and ambiguous in that it does not indicate what type of testing about which it seeks information. Without waiving the above objection, refer to answer to Interrogatory No. 9.
Q. 27.
If so, please state: 15
HRV-PL-1524
(a) The nature of the change made. (b) The name, address, and job classification of each person in charge of making a change.
A. 27. Refer to answer to Interrogatory No. 26.
Q. 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?
A. 28. Refer to answer to Interrogatory No. 22.
Q. 29.
If so, please state:
(a) The name, address, and job
classification of each person conducted said tests;
(b) The results of said tests.
A. 29. Refer to answer to Interrogatory No. 28.
Q. 30. Prior to1970, 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 made 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.
.
A. 30. This defendant objects to interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the above objection, this defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory.
16
HRV--PL--1525
Q. 31.
If your company performed or had performed
any dust level counts, what action based on the results did your
company take?
A. 31.
Refer to objection and answer to
Interrogatory No. 30.
Q. 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)? If answer to this question is "yes",
give the date and nature of such 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.
A. 32. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 and does not have any records from which it can obtain information sufficient to answer this interrogatory.
During May, 1979, various papers and reports were produced by an employee of the Trudeau Institute, Mr. Allan Logie, regarding animal experiments conducted at laboratories at Saranac Lake involving dust collected during the Kaylo manufacturing process. These papers and reports may contain information relating to the substance of this interrogatory. This defendant has not been able to find these papers and reports in its business records or correspondence although it has searched for and continues to search for them.
This defendant's counsel obtained copies of some of the papers and reports produced by Mr. Logie. However, these copies constitute only a portion of a larger volume of papers and reports which this defendant has not copied. They are available
17
HRV-PL-1526
at Milbank, Tweed, Hadley & McCloy, 1 Chase Manhattan Plaza, New York, New York. This defendant also has reason to believe that plaintiffs' counsel has copies of the documents produced by Mr. Logie. Other documents possibly relating to this interrogatory may have been produced by owens-Corning Fiberglas Corporation in the asbestos litigation.
Those documents found at Saranac Lake and at OwensCorning Fiberglas Corporation and elsewhere, indicate that during the period of time when Owens-Illinois was in the business of manufacturing asbestos-containing products, the state of government, industrial hygiene and medical community knowledge was that there was a recognized safe exposure level for asbestos dust and that persons installing insulation were not exposed to excessive or hazardous levels of asbestos dust. The foregoing documents also indicate that Kaylo plant employees were x-rayed periodically and displayed no asbestos-related chest disease; that this defendant made appropriate efforts to provide ventilation and to control the emissions of all dust omitted during the manufacturing process within recognized safe levels of exposure, including the use of respirators in some instances, dust collection equipment and other devices as necessary; and that therefore during the period in which this defendant was in the business of manufacturing Kaylo it had no reason to believe that the foreseeable use of Kaylo would create a hazard to users.
The documents produced by Owens-Corning Fiberglas Corporation indicate that the September, 1955 publication in the A.M.A. Archives of Industrial Health was a publication of inhalation experiments.
To the extent that this interrogatory seeks the production of documents, such documents, as outlined in this response, have not been found as part of this defendant's records and, to the extent that this defendant is in possession of copies of documents, it possesses copies only of documents collected in preparation for litigation. This defendant objects to producing the same. The documents are available from their proper source.
18
HRV-PL-152V
Q. 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 asbestos 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.
A. 33.
This defendant ceased the manufacture, sale
and distribution of asbestos-containing products in 1958. This
defendant has not found information in its records sufficient to
enable it to answer this interrogatory.
Q. 34.
If your answer to Interrogatory No. 33 is
"yes", state the name and address of such industrial hygienist or
hygienists.
A. 34. Refer to answer to Interrogatory No. 33.
Q. 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 continuously
since being established.
(a) How much expended each year on
research, etc.
19
HRV -- PL -- 15 2 s
(b) What percentage of gross sales did your company or its predecessor(s) spend on research concerning the health affects of asbestos.
A. 35.
This defendant objects to this interrogatory
as being vague, ambiguous, irrelevant, overly broad, not
reasonably calculated to lead to the discovery of admissible
evidence and not limited to any issue which is the subject of
this case.
Q. 36.
Prior to 1965, did you company, or any
predecessor(s), ever at any time give persons who would be
applying or removing your asbestos 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.
A. 36.
This defendant objects to interrogatory on
the basis that it seeks information which is not relevant to the
subject matter of this litigation and is not reasonably
calculated to lead to the discovery of admissible evidence,
except as it relates to the period of time during which this
defendant engaged in the manufacture, sale and distribution of
its asbestos-containing products. Without waiving the above
objection, this defendant ceased the manufacture, sale and
distribution of asbestos-containing products in 1958. This
defendant has not found information in its records sufficient to
enable it to answer this interrogatory.
Q. 37.
Did your company, or your predecessor(s),
ever place any warnings signs on the containers in which asbestos
products were packaged?
20 HRV-PL-15 2 9
A- 37. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm.
Q. 38.
If you have answered Interrogatory No. 37 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 asbestos products, or containers?
(b) On what date was such warning actually
first placed on your asbestos products or containers?
(c) On what date did your asbestos
products, accompanied by such warning, first reach the
contractor?
(d) State the exact wording of the first
warning.
(e) State the exact size of the warning
printed on your asbestos products or container.
(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 products or
containers?
(h) Did your company or its predecessor(s)
place such warning on your asbestos products or containers
because you received a directive, command, suggestion, legal
opinion, or any type of communication (written or otherwise) form
any person, firm, corporation, governmental agency, committee,
association, attorney or institute? If so, from whom and on what
21
HRV-PL-1530
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.
A. 38.
Refer to answer to Interrogatory No. 37.
Q. 39.
Did your company or its predecessor(s) ever
place any warning directly on any of its asbestos pipe covering,
block, cloth, millboard or other asbestos products?
A. 39. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm.
Q. 40.
Did your company ever stamp the name of the
company, its initials, or any identifying logo on any of its
asbestos pipe covering, blocks, cloth, millboard or asbestos
product?
A. 40.
This defendant does not believe that its
asbestos-containing product or the product's covering or wrapping
contained any logo or identifying marks.
Q. 41.
Did the warning inquired about in
Interrogatories 39 and 40, 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.
22
HRV-PL-1531
A. 41.
Not applicable.
Interrogatory Nos. 39 and 40.
Refer to answers to
Q. 42.
On what date was the sales literature
inquired about in Interrogatory No. 41 first provided to
distributors or sellers of your company's asbestos products, or
your predecessor(s)'s products?
A. 42.
Not applicable.
Interrogatory No. 41.
Refer to answer to
Q. 43.
Were any material safety data sheets ever
prepared by your company or its predecessor(s)? If so, attach
copies.
A. 43.
This defendant objects to this interrogatory
as being vague, ambiguous, irrelevant, overly broad, not
reasonably calculated to lead to the discovery of admissible
evidence and not limited to any issue which is the subject of
this case.
Q. 44.
Did your company or its predecessor(s) ever
recall any products containing asbestos from 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.
A. '44. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory.
Q. 45.
Has your company or its predecessor(s) ever
directly advised any contractor to whom you sell your products
23
HRV--PL--1532
containing asbestos of threshold limit values for exposure to asbestos dust recommended by the American 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.
A. 45.
This defendant ceased the manufacture, sale
and distribution of asbestos-containing products in 1958. This
defendant has not found information in its records sufficient to
enable it to answer this interrogatory.
Q. 46.
Prior to 1964 did your company or its
predecessor(s) ever manufacture products containing asbestos
without a warning? List the years.
A. 46. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm.
Q. 47.
After 1964 did you ever manufacture products
containing asbestos without a warning? If so, list the name of
the product and the years.
A. 47. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. Not applicable to this defendant.
Q. 48.
Is your company, as of the date of answering
these interrogatories, still manufacturing, selling or
distributing any products containing asbestos? If so, give the
24
HEV-PL-1533
brand names of such products and the binding material and dates of first manufacture of such product.
A. 48.
This defendant ceased the manufacture, sale
and distribution of asbestos-containing products in 1958.
Q. 49.
Did your company or any predecessor(s) ever
have a division or subsidiary company engaged in the contracting
business of applying asbestos 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.
A. 49.
This defendant has never formed nor
maintained a group or groups known as "contract units," such
"contract units" being a division or group within or maintained
by the corporation which, inter alia, engaged in the actual
installation of insulation products containing asbestos at job
sites.
Q. 50.
Did any division of your company or
subsidiary company engaged in the contract business of applying
asbestos products or your workmen's compensation insurance
carrier ever have any claims for lung diseases, whether directly
or indirectly attributed to asbestosis, mesothelioma, lung
cancer, or any exposure to asbestos products prior to 1972? If
the answer is "yes", give the name of such employees and attach
copies of such claims and copies of all documents relating to the
disposition and handling of such claims.
A. 50.
During the period in which this defendant
engaged in the manufacture of its asbestos-containing products,
it received no workers' compensation claims for any asbestos-
related disease.
25
HRV --PL, - 15 3 4
Q. 51.
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.
A. 51.
Not applicable.
Interrogatory No. 50.
Refer to answer to
Q. 52.
Did your company or its predecessor(s) ever
make any industrial hygiene surveys concerning its asbestos
products? If so, give the date of such surveys, and attach
copies of such surveys.
A. 52.
Refer to answer to Interrogatory No. 22.
Q. 53.
State the year that this defendant or any
predecessor(s) was first advised of either threshold limit values
or maximum allowable concentrations of both asbestos dust and
total dust by the American Conference of Governmental Industrial
Hygienists, and state the name of the employee-official of the
company receiving such advise and attach copies of the instrument
communicating such advise.
A. 53.
This defendant ceased the manufacture, sale
and distribution of asbestos-containing products in 1958. It has
not located information in its records that would enable it to
answer this interrogatory. However, it appears that this
defendant was aware of the TLV for asbestos dust and other dusts
as published by the American Conference of Governmental
Industrial Hygienists (ACGIH) in the mid to late 1940's or
1950's.
During the 1940's and after, it appears that an
employee of this defendant subscribed to and received the Journal
of Industrial Hygiene and Toxicology which contained, in 1946, an
26
HRV-PL-1535
article entitled "A Health Survey of Pipe Covering Operations in Constructing Naval Vessels," by Fleischer, Drinker and others which discusses safe levels of asbestos. Also, this defendant was a member of the Industrial Hygiene Foundation in 1946. The transactions of the Eleventh Annual Meeting, Industrial Hygiene Foundation, dated November 7, 1946 contain, beginning at page 71, an explanation by J. J. Bloomfield of then existing threshold limit values including the TLV for asbestos. It also appears that an employee of this defendant subscribed to and received the journal, Industrial Hygiene and Occupational Medicine, which contained in 1951, an abstract of an article entitled "A Contribution to the Study of Asbestosis" by P. Cartier which refers to the TLV for asbestos.
Further, in May, 1979, various papers and reports were produced by an employee of the Trudeau Institute, Mr. Allan Logie, regarding animal experiments conducted at laboratories at Saranac Lake, New York purportedly involving dust collected during the manufacture of Kaylo. These papers and reports may contain information related to the substance of this interrogatory. This defendant has not been able to find those papers and reports in its business records or correspondence although it has searched for and continues to search for them. Among those papers and reports is a paper dated May 29, 1951 which refers to the TLV for asbestos dust.
Additionally, owens-Corning Fiberglas Corporation produced, in various cases in 1979, papers purporting to relate to this defendant's asbestos-containing product business. One such paper is a copy of a letter to Dr. Miriam Sachs, Chief, Bureau on Adult and Industrial Health, State of New Jersey Department of Health, Trenton, New Jersey regarding State standards. Neither the documents produced by Owens-Corning Fiberglas Corporation nor those produced by Mr. Logie have been located in this defendant's records.
27
HRV-PL-1536
Q. 54. Was such threshold limit values or maximum allowable concentrations inquired about in Interrogatory No. 53 TOTAL dust and not just asbestos dust?
A. 54.
This defendant understands the term
"threshold limit value" as it pertains to the asbestos trade to
mean the maximum average atmospheric concentration of asbestos
dust to which workers may be exposed for an eight hour day
without injury to health. During the period of time this
defendant manufactured, sold and distributed asbestos-containing
products, the threshold limit value for asbestos dust, as taken
from the published transactions and other material of the
American Conference of Governmental and Industrial Hygienists was
5,000,000 particles of asbestos dust per cubic foot of air.
Q. 55. State in detail what test, if any, your company ever made with regard to the quantity, quality or threshold limit values or asbestos dust or particles to which applicators or consumers of your product were exposed while using your products containing asbestos.
(a) 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 reports, findings or memorandums concerning such tests or studies.
A. 55. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory.
Q. 56.
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;
28
HRV -- PL- 1 5 3 *7
(b) Mesothelioma; (c) Lung Cancer; (d) Any other diseases; (e) With reference to yourcompany give the name of such official who first had such knowledge list them and attach copies. (f) If there are any documents,records or memorandums of any kind concerning such knowledge, list them and attach copies.
A. 56.
(a, d-f)
To the extent this
interrogatory inquires as to asbestos-containing products
manufactured or sold by other defendants, this defendant states
that it does not have any records from which it can obtain
information sufficient to answer this interrogatory, nor can it
locate any present employees with knowledge thereof.
Insofar as this interrogatory inquires as to asbestos-
containing products manufactured by this defendant, this
defendant states that it ceased the manufacture, sale and
distribution of asbestos-containing products effective April 30,
1958 and has not engaged in any such business since.
During May, 1979, various papers and reports were
produced by an employee of the Trudeau Institute, Mr. Allan
Logie, regarding animal experiments conducted at laboratories at
Saranac Lake involving dust collected during the Kaylo
manufacturing process. These papers and reports may contain
information relating to the substance of this interrogatory.
This defendant has not been able to find these papers and reports
in its business records or correspondence although it has
searched for and continues to search for them.
This defendant's counsel obtained copies of some of the
papers and reports produced by Mr. Logie. However, these copies
constitute only a portion of a larger volume of papers and
reports which this defendant has not copied. This defendant also
has reason to believe that plaintiffs' counsel has copies of the
29
HRV-PL-15 3 8
documents produced by Mr. Logie. They are available at Milbank,
Tweed, Hadley & McCloy, 1 Chase Manhattan Plaza, New York, New
York. Other documents possibly relating to this interrogatory
may have been produced by Owens-Corning Fiberglas Corporation.
Those documents indicate that experiments referred to in the
documents produced by Mr. Logie were published in an AMA
publication in September, 1955. As with the documents produced
by Mr. Logie, the documents produced by Owens-Corning Fiberglas
Corporation have not been found as part of this defendant's
records.
The foregoing documents indicate that during the time
in which this defendant engaged in the manufacture, sale and
distribution of asbestos-containing products, its products
contained a relatively small proportion of asbestos when compared
to other asbestos-containing products in use during and prior to
the same period of time.
It appears that this defendant's
employees at its asbestos product manufacturing plants were x-
rayed periodically and displayed no asbestos-related chest
disease, although in the course of their employment they were
exposed to the raw materials of this defendant's products as well
as the dust of the finished product. Furthermore, these
documents indicate that there were no worker's compensation
claims filed by its employees for asbestos-related diseases.
It was this defendant's understanding of the state of
medical and industrial hygiene knowledge that exposure to
asbestos in excessive amounts over a prolonged period of time
(years), in the conditions typically experienced in factories,
workshops, and possibly mines and mills could lead to the
potential hazard of contracting a disease known as asbestosis.
However, the state of medical and industrial hygiene
knowledge was also to the effect that there was a safe level
(threshold limit value) of asbestos to which a person could be
exposed without risk of injury. This defendant was aware of the
threshold limit value for asbestos as published by the American
Conference of Governmental Industrial Hygienists (ACGIH) in the
30
HRV-PL-1533
1940's and 1950's through publications by the Industrial Hygiene Foundation, ACGIH and from the above referenced "Logie" and "OCF" documents.
In addition, it appears that an employee of this defendant subscribed to and received the Journal of Industrial Hygiene and Toxicology which contained in January, 1946 an article published by the Navy entitled, "A Health Survey of Pipe Covering Operations in' Constructing Naval Vessels," by Fleischer, Viles, Gade and Drinker. This article stated that persons who worked as insulators in shipyards were not exposed and did not work in conditions similar to those experienced in factories, workshops, mines and mills, and were not exposed to levels of asbestos above the recognized safe limits. Therefore, the article concluded that such persons were not engaged in a hazardous occupation.
From the foregoing papers, reports and articles, this defendant had no reason to believe that exposure to its asbestoscontaining products would result in a foreseeable risk of harm to users.
This defendant reserves the right to supplement this response as discovery and the case warrant. This defendant has reason to believe that plaintiffs' counsel is in possession of a substantial library of asbestos-related literature containing articles that defendant may wish to rely upon.
To the extent that this interrogatory seeks the production of documents, such documents, as outlined in this response, have not been found as part of this defendant's records and, to the extent that this defendant is in possession of copies of documents, it possesses copies only of documents collected in preparation for litigation. This defendant objects to producing the same. The documents are available from their proper source.
(b-c) This defendant objects to this interrogatory on the basis that it is vague, ambiguous and unintelligible. Defendant also objects on the basis that its present knowledge is irrelevant to this action in that evidence
31
of a causal connection between cancer or mesothelioma and asbestos was first accepted by medical science after the period of time defendant ceased the manufacture of asbestos-containing products. Without waiving its objections, defendant is informed and believes that at no time prior to 1958 was there reason to believe that the medical and scientific community accepted that there was a causal connection established between exposure to asbestos and a risk of contracting cancer or mesothelioma.
Q. 57.
Do you have any photographs of the products
inquired about above or their packages or containers? If so,
please attach exact copies.
A. Exhibit I.
57.
Refer to documents attached hereto as
Q. 58.
Has the answering defendant or any of its
predecessors ever mined asbestos? If so, state the dates in
which such mining too place and the locations of the mines.
A. 58. This defendant does not now and has not in the past engaged in the business of mining, milling, or selling raw asbestos.
Q. 59.
List by brand name every products containing
asbestos which defendant or defendant's predecessors has
manufactured since 1910. As to each such product, please state
the following:
(a) The type of product (e.g., acoustical
plaster, fireproofing, concrete, etc.);
(b) The date the product fist went into
production;
(c) The date the product was discontinued
from production;
(d) The last date the product was sold;
32
HBV-PL-1541
(e) All manufacturing locations of the product;
(f) The identify of the plant manager(s) or managing agent(s) of the defendant who has knowledge of the products manufactured by defendant and its predecessor(s), and who may be called upon by plaintiffs to testify by deposition.
A. 59.
Kaylo and Kaylo-20.
(a) This defendant's asbestos-containing
industrial insulation was manufactured in two forms, block and
pipe covering.
(b-d) Owens-Illinois Glass Company began
limited pilot plant operations involving the production of
"Kaylo" asbestos-containing products in 1943. It began the
manufacture of commercial quantities of "Kaylo" asbestos-
containing products in about 1948 and continued such manufacture
until about April 30, 1958.
(e) This defendant's manufacturing plants
were located in Berlin, New Jersey and Sayreville, New Jersey.
The Berlin plant was in operation from approximately 1943 until
on or about April 30, 1958. The Sayreville plant was in
operation from February, 1948 until about April 30, 1953.
(f) This defendant objects to this
interrogatory on the basis that it seeks information which is not
relevant to the subject matter of this litigation and is not
reasonably calculated to lead to the discovery of admissible
evidence;
Q. 60.
As to each product identified in response to
the foregoing interrogatory please indicate:
(a) The type of asbestos contained in the
product as it was first manufactured;
(b) The percentage of asbestos contained
in the product as it was first manufactured;
33
HRV -- PL--15 4 2
(c) Any modification to the product which altered the percentage or type of asbestos in the product and the dates of such modification;
(d) The source of asbestos in each product;
(e) The color, physical characteristics, and appearance of each product;
(f) A full and complete description of the package in which the product was sold, including, but not limited to, type of package, size, color(s), and writings thereon;
(g) All other names under which the product was sold;
(h) The number and date of each patent or patent application as to the product;
(i) If the product continued to be produced after the deletion of asbestos, all reasons why the asbestos was deleted, the identity of the person who made the decision to delete the asbestos, and the date the product was first produced without the asbestos;
(j) If the product is no longer produced, all reasons it was discontinued, the identity of the person who made the decision to discontinue the product, the brand name of the replacement product, and the date the replacement product first went into production;
(k) The identify of the custodian, managing agent, or employee who has photographs, drawings, or labels of each product;
(l) The reasons why asbestos was used as an ingredient in each product;
(m) The content of any warning labels, inserts or other writings provided with such product with ever such printed warning, what period of time it has or had accompanied the product, the exact wording of the warning, any amendments made to the wording, whether the warning was located
34
HRV-PL-1543
on each product or packaging, and on what asbestos products the warnings appear(ed);
(n) Any special instructions provided with such product regarding the use, protection or safety procedures to be employed by persons handling such product.
A. 60.
(a-b) This defendant ceased the manufacture,
sale and distribution of its asbestos-containing products in
1958. Its investigation as to the composition of each such
product, including the type of asbestos contained therein (i.e.,
amosite or chrysotile) and the quantitative percentage of
asbestos, is continuing, although this defendant now believes
that this defendant's commercially produced asbestos-containing
products were hydrous calcium silicates containing between 13%
and approximately 20% asbestos. Chrysotile asbestos was the
primary type apparently used. Amosite was used to a lesser
extent.
(c) This defendant has in its records
technical reports relating to the development and testing of
Kaylo, and will make available to plaintiffs' counsel through its
local counsel these records. Many of the reports are contained
on microfilm which is old and of poor quality. Adequate copies
may not be made from it, and reading it requires a reader device.
This defendant further states that its investigation into the
subject matter referred to in this interrogatory is continuing.
(d) This defendant believes that the
chrysotile which was the primary type of asbestos used in its
insulation products was imported from Canada, and that at least
some of this chrysotile was purchased from Canadian Johns-
Manville, Ltd. This defendant further believes that the amosite
asbestos used in some of its insulation products was imported
from South Africa and at least a portion of such amosite was
purchased from the African and European Agencies. This defendant
ceased the manufacture, sale and distribution of asbestos-
35
HRV-PL-15 4 4
containing products in 1958 and does not have information sufficient to further answer this interrogatory.
(e) This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. It believes that Kaylo and Kaylo-20 were premolded, rigid products, and were manufactured in two forms, block and pipe covering. Kaylo was white or off-white in color, and Kaylo-20 was pinkish in color.
(f) This defendant believes that some of its asbestos-containing insulation products were packaged in corrugated cartons with the trademark Kaylo on the carton. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 and does not have information sufficient to further answer this interrogatory.
(g) Kaylo and Kaylo-20. (h) This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. Its investigation as to information concerning any such United States Patents is continuing. However, it appears that the following patents may have been related to this defendant's asbestos-containing products at one time:
Patent No.
2,425,610 2,439,724 RE.23,228 2,534,303 2,540,354 2,547,127 2,570,835 2,574,667 2,665,996 2,748,008 2,787,345 2,788,304
Inventor
Finley Finley Frasor Serinis ` Selden Kalousek Mooney, et al. Shuman Kalousek Kalousek Soubier, et al. Scovronek
Issue Date
8-12-47 4-13-48 5-09-50 12-19-51 2-06-51 4-03-51 10-09-51 11-13-51 1-12-54 5-29-56 4-02-57 4-09-57
(i) This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 pursuant to the sale of its Kaylo Division to Owens-Corning
36
HRV-PL-15 4 5
Fiberglas Corporation. This defendant did not manufacture Kaylo without asbestos.
(j) Effective April 30, 1958, this defendant sold its asbestos-containing manufacturing division to Owens-Corning Fiberglas Corporation. As of that time, this defendant ceased the manufacture, sale and distribution of asbestos-containing products and has not engaged in any such business since that date.
(k) Refer to documents attached hereto as Exhibit II.
(l) This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the above objection, refer to answer to Interrogatory No. 60(c).
(m) This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm.
(n) This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory.
Q. 61.
With respect to your answer in Interrogatory
No. 60, did you specifically inform the purchaser or user of your
products during the same time period that your products were
manufactured and sold that such products would cause cancer,
asbestosis, and other serious diseases?
37
HRV-PL- 15 4 6
A. 61.
This defendant ceased the manufacture, sale
and distribution of asbestos-containing products in 1958. This
defendant has not found information in its records sufficient to
enable it to answer this interrogatory. However, it does not
appear that any warning concerning asbestos was given in that it
does not appear that this defendant had reason to believe that
the use of its products would result in a foreseeable risk of
harm: Further, during this time period, the state of medical and
scientific knowledge was such that there was no reason to believe
that there was an association between exposure to asbestos and
the risk of contracting cancer.
Q. 62.
Identify the distribution chain of
defendant's asbestos products since 1925 along with any documents
evidencing or confirming such chain, including but not limited to
distribution from and to other defendants.
A. 62.
This defendant objects to this interrogatory
on the basis that it seeks information which is not relevant to
the subject matter of this litigation and is not reasonably
calculated to lead to the discovery of admissible evidence.
Without waiving the above objection, in 1953, this defendant
entered into a sales agreement with Owens-Coming Fiberglas
Corporation under which it agreed to the sale of asbestos-
containing products to that corporation. This defendant believes
that it ceased the general marketing and sales of its asbestos-
containing thermal insulation products at that time, disbanded
its sales force, and that thereafter, Owens-Corning Fiberglas
Corporation was the primary marketer of its product until the
sale of the division to Owens-Corning Fiberglas Corporation in
1958. Refer to Exhibit III.
Q. 63.
Identify your distributors and/or suppliers
of raw asbestos, asbestos cement and other asbestos products with
which you had business contact.
38
HRV -- FH,-- 15 4 7
A. 63.
Refer to answer to Interrogatory-No. 60(d).
This defendant was not involved in any business relating to
asbestos cement.
Q. 64.
Is this defendant aware or has it possessed
knowledge concerning the reported causal connection between
exposure to asbestos or asbestos products and:
(a) asbestosis?
(b) lung cancer?
(c) mesothelioma?
(d) other cancer?
A. 64.
(a)
During the period of time in which
this defendant engaged in the manufacture, sale and distribution
of its asbestos-containing products, it was this defendant's
understanding that the inhalation of asbestos dust in excessive
amounts over a prolonged period of time (years), under certain
conditions, could lead to the potential hazard of contracting a
disease known as asbestosis. However, in 1958 and before and for
some years thereafter, the state of the medical and scientific
knowledge was to the effect that there was a safe level of
asbestos to which a person could be exposed without risk of
injury and to the effect that persons such as plaintiffs were not
exposed to excessive amounts of asbestos.
(b-d) This defendant objects to this
interrogatory on the basis that the term causal connection is
vague, ambiguous and unintelligible. Defendant also objects on
the basis that its present knowledge is irrelevant to this action
in that evidence of a causal connection between lung cancer,
mesothelioma, and other cancers and asbestos was first accepted
by medical science after the period of time defendant ceased the
manufacture of asbestos-containing products. Without waiving its
objections, defendant is informed and believes that at no time
prior to 1958 was there reason to believe that the medical and
39
HRV-PL-1548
scientific community accepted that there was a causal connection established between exposure to asbestos and a risk of contracting lung cancer, mesothelioma, and other cancers.
Q. 65.
If answer to preceding interrogatory as to
any or all of its subparts, is in the affirmative, identify:
(a) When and how defendant first learned
of such connection;
(b) If knowledge was obtained by
attendance at any conference, lecture, convention, symposium or
meeting, identify such meeting and provide the identify of
persons attending and documents obtained;
(c) If knowledge was obtained from medical
or scientific studies, or any other published work, identify
same;
(d) If otherwise obtained, identify manner
of receipt of document or communication.
A. 65.
Refer to answers to Interrogatory Nos. 64 and
56.
Q. 66. With regard to any knowledge obtained subsequent to that identified in your answer to Interrogatory No. 65 (a) above, identify:
(a) All documents or communications, oral or written, concerning the causal- connection between exposure to asbestos products and disease, and identity of persons so communicating;
(b) Did answering defendant obtain from or transmit any such information to other defendants in this case? If so, identify:
(1) Manner of receipt or communication for each contact;
(2) All documents and persons involved.
40
HRV--PL--1549
A. 66.
This defendant objects to this interrogatory
as being irrelevant and not reasonably calculated to lead to the
discovery of admissible evidence and not limited to any issue
which is the subject of this case. This defendant further
objects to this interrogatory on the grounds that it seeks
information within the work-product privilege and on the ground
that it is oppressive and burdensome in that it would have to
review all of the files and all of the records of all of its
attorneys all over the country to respond to this interrogatory.
Q. 67. As to any knowledge possessed by answering defendant at any time referred to in your answer to Interrogatory No. 64, did you educate your employees, distributors or purchasers of the hazards known to you and the safety precautions necessary to guard against cancer and other diseases arising from the use and handling of your products? If so, identify:
(a) When and in what manner customers, insulators, factory workers and the general public were so informed;
(b) Documents communicating or otherwise disseminating such information;
(c) Programs initiated or sponsored to establish or promote safety procedures, methods or usage of equipment;
(d) Published articles or reports by employees (present or prior), including those of medical directors, scientists, engineers or other professionals;
(e) Symposia or lectures sponsored for the benefit of asbestos workers and/or the general public.
A. 67 .
Refer to answer to Interrogatory No. 64.
Q. 68 .
When and by what manner were you first aware
41
HHV -- PL. -- 15 6 9
of the hazards relating to exposure to asbestos or asbestos products;
(a) For inside insulators and contractors. (b) For outside insulators and contractors.
A. 68.
Not applicable to this defendant. During the
time defendant was involved in the asbestos-containing product
business, the state of medical and scientific knowledge was such
that defendant had no reason to believe that the use of its
product would result in a foreseeable risk of harm.
Q. 69.
If you have knowledge or information
concerning the following, answer in the affirmative or negative,
whether:
(a) Early detection of mesothelioma
results in any appreciable rate of cure or arrest;
(b) A single exposure to asbestos may
cause mesothelioma, other cancers or asbestosis;
(c) Cumulative or multiple exposures to
asbestos result in a greater risk of harm to the exposed person;
(d) An outside insulator has a risk of
harm from exposure to asbestos or asbestos products;
(e) Stripping or removing old asbestos
creates a greater risk of harm than installation of asbestos or
asbestos products;
.
(f) Cancer resulting from exposure to
asbestos develops generally after:
(1) 1-5 years.
(2) 6-10 years.
(3) 11-20 years.
(g) There is any known relationship
between smoking and mesothelioma;
(h) There is any reported cause of
mesothelioma other than exposure to asbestos.
42
HRV-PL-1570
A. 69.
This defendant objects to this interrogatory
on the basis that it seeks an expert opinion which this defendant
is not qualified to render.
Q. 70.
As to each answer to Interrogatory No. 69,
identify at least one person or document upon which answering
defendant relies.
A. 70.
Refer to objection to Interrogatory No. 69.
Q. 71.
Did you perform, direct to be performed,
finance, sponsor or receive the results of any studies or tests
concerning the relationship between asbestos exposure and
asbestosis and/or cancer? If so, identify:
(a) When, where and at what intervals such
studies were performed;
(b) Were such studies in writing or
reported at a later date in writing;
(c) Were the results of such studies
published or otherwise disseminated? If so, state to whom and
when;
(d) Who performed such studies;
(e) Will you produce the results of such
studies at this time or state where the results are maintained.
. A. 71. Refer to answer to Interrogatory No. 22.
Q. 72.
Identify the scientific or medical
periodicals to which defendant, its medical department or
industrial hygiene division subscribed from 1925 to the present,
and the dates of such subscriptions.
A. 72. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This
43
HRV ---- 1 5 *7 1
defendant has not found information in its records sufficient to enable it to answer this interrogatory. Refer to answer to Interrogatory No. 73.
Q. 73.
Did defendant, its medical department or
industrial hygiene division maintain a medical and/or scientific
library at any time from 1925 to the present? If so, state:
(a) The dates such library existed;
(b) The number of volumes maintained
therein;
(c) The number of employees, part-time or
full-time, assigned to maintenance of said library, and to whom
in the corporate structure those employees report(ed).
A. 73.
During the period of time pertinent to these
actions, this defendant did not maintain an entity which would be
characterized as an industrial hygiene, medicine, safety and/or
engineering library. However, this defendant believes that a
separate engineering library may have been maintained by its
technical facility. This defendant also states that although it
has no records indicating the existence of such a library, upon
becoming involved in asbestos-related litigation this defendant
listed all the publications which were in its then existing
industrial hygiene library. These publications are listed on
Exhibit IV. This defendant has not yet determined which, if any,
of these publications were in this defendant's possession during
the time it manufactured, sold and distributed asbestos-
containing products.
Q. 74.
Identify all trade organizations,
associations, or other entities, including but not limited to
A.T.I., I.H.F., N.I.M.A., A.I.A., N.I.C.A., T.I.M.A., Q.A.M.A.,
P.I.C.A., or Q.A.P.A., to which you have belonged or in which you
have participated since 1925, stating the applicable dates of
such membership or participation.
44
HBV-PL-1572
_ A. 74. This defendant objects to this interrogatory on the grounds that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence except as it relates to the period of time within which this defendant manufactured its asbestos-containing products.
Without waiving the above objection, this defendant states that insofar as this interrogatory refers to associations or organizations of which this defendant was a member during the time when it manufactured asbestos-containing products, it was a member of the Industrial Hygiene Foundation (which changed its name to the Industrial Health Foundation in 1970} for the years 1936 through 1975. This defendant was not a member of any of the other trade associations about which this interrogatory inquires.
Q. 75.
Identify all persons attending on your behalf
any meetings held by trade organizations, associations, or other
entities identified in answer to Interrogatory No. 74.
A. 75.
This defendant ceased the manufacture, sale
and distribution of asbestos-containing products in 1958. This
defendant has not found information in its records sufficient to
enable it to answer this interrogatory.
Q. 76.
Identify the names or nature of all notes,
reports, studies, or other writings submitted by you or received
by you at meetings held by organizations described in answer to
Interrogatory No. 74.
A. 76. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it *to answer this interrogatory.
45
HRV --PL--15 73
Q. 77.
Identify any documents received by you from
or submitted by you to those trade organizations, associations or
other entities identified in answer to Interrogatory No. 74
relating to the relationship between asbestos exposure and
disease.
A. 77.
This defendant ceased the manufacture, sale
and distribution of asbestos-containing products in 1958. This
defendant has not found information in its records sufficient to
enable it to answer this interrogatory.
Q. 78.
Identify all agreements, oral or written,
between you, any of the other defendants in this lawsuit, and/or
any other organizations, associations or other entities
identified in your answer to the Interrogatory No. 74 or any
medical or scientific foundations, relating to the
standardization of:
(a) Specifications for asbestos cloth
products;
(b) Specifications for paper or burlap
bags, or other packaging to be used for the transport and/or
storage of asbestos cement;
(c) Warning or caution labels to be
applied to asbestos products and/or their packaging, cartons,
containers, or boxes;
(d) Methods of dissemination of public
relations information to defendant's purchasers, advertisers,
distributors, factory workers, contractors, insulators, users,
consumers of asbestos products and/or the general public;
(e) Safety equipment and/or protective
clothing to be utilized while handling defendant's asbestos
products;
(f) Medical programs to be offered or
sponsored by defendant.
46
HRV-PL-1574
A. 78.
This defendant ceased the manufacture, sale
and distribution of asbestos-containing products in 1958. This
defendant has not found information in its records sufficient to
enable it to answer this interrogatory.
Q. 79.
Did you direct to be performed, sponsor,
finance, receive the results of or were you aware of any studies
or tests performed by the Saranac-Lake Laboratory of the Trudeau
Foundation relating to asbestos exposure and its effects upon
human life? If so, identify:
(a) All documents summarizing findings or
results of those studies or tests which you have in your
possession or control;
(b) All communications, oral or written,
between answering defendant and Saranac personnel, including but
not limited to Gerrit W. H. Schepers, M.D.
(c) All documents relating to Saranac
studies received or submitted by you either directly though
associated or predecessor companies, through other companies, or
through any trade associations, organizations or other entities;
(d) All recommendations or findings of
such studies relating to:
(1) Adequacy or inadequacy of
threshold limit values;
(2) Substitution of materials other
than asbestos to be used in the insulation process.
(e) Where documents and/or communications
identified in answers to (a) - (d) of this interrogatory are
maintained.
A. 79.
Refer to answer to Interrogatory No. 22.
Q. 80.
How many employees of answering defendant are
known by defendant to be suffering from, have suffered from or
47
HRV-PL-1S V 5
whose deaths have been caused by asbestosis? State the date such disease of any employee was first known by defendant.
A. 80.
This defendant objects to this interrogatory
on the basis that it seeks information which is not relevant to
the subject matter of this litigation and is not reasonably
calculated to lead to the discovery of admissible evidence.
Q. 81.
How many employees of answering defendant are
known by defendant to be suffering from, have suffered from or
whose deaths have been caused by lung cancer? State the date
such disease of any employee was first known by defendant.
A. 81.
This defendant objects to this interrogatory
on the basis that it seeks information which is not relevant to
the subject matter of this litigation and is not reasonably
calculated to lead to the discovery of admissible evidence.
Q. 82.
How many employees of answering defendant are
known by defendant to be suffering from, have suffered from or
whose deaths have been caused by mesothelioma? State the date
such disease of any employee was first known by defendant.
A. 82.
This defendant objects to this interrogatory
on the basis that it seeks information which is not relevant to
the subject matter of this litigation and is not reasonably
calculated to lead to the discovery of admissible evidence.
Q. 83.
Do you send or have you at any time sent
counsel or other representatives to courses at defending asbestos
cases? If so, identify.
A. 83.
This defendant objects to this interrogatory
on the basis that it seeks information which is not relevant to
48
HRV-PL-1 5 *7 6
the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence.
Q. 84.
Identify all expert witnesses who have
testified in other cases, pending or otherwise, on behalf of
answering defendant.
A: 84.
This defendant objects to this interrogatory
on the basis that it seeks information which is not relevant to
the subject matter of this litigation and is not reasonably
calculated to lead to the discovery of admissible evidence.
Q. 85.
Identify all present or former employees or
answering defendant, other than plaintiffs, who have testified
against this defendant in a litigation matter or before a
governmental agency or unit.
A. 85.
This defendant objects to this interrogatory
on the basis that it seeks information which is not relevant to
the subject matter of this litigation and is not reasonably
calculated to lead to the discovery of admissible evidence.
Without waiving the above objection, defendant states that no
such testimony has been given.
Q. 86. With respect to your answers to Interrogatory No. 84 and 85, identify all documents, including but not limited to transcripts or notes of testimony employed by or resulting from the testimony of such expert witnesses or employees.
A. 86. Refer to objections and answers to Interrogatory Nos. 84 and 85.
49 HRV--PL--1577
Q. 87.
Identify:
(a) Any expert whom you intend to call as
a witness or otherwise utilize in connection with this
litigation;
(b) The subject matter on which the expert
is expected to testify;
(c) The substance of the facts and
opinions to which the expert is expected to testify;
(d) A summary of the grounds for each
opinion;
(e> field or expertise;
The address of such person and his
(f) Identify and produce each treatise,
article or text upon whether the expert will rely in his
testimony.
A. 87.
The identity of expert witnesses to be called
at trial is not known at the present time. This defendant
reserves the right to designate at a later date expert witnesses
to be used at trial.
Q. 88.
Identify and produce all board meeting
minutes at which asbestos products, the hazards of asbestos
exposure, the possible application of warning labels on a
asbestos-containing products were discussed by the Board of
Directors of your company.
.
A. 88.
This defendant objects to this interrogatory
on the basis that it seeks information which is not relevant to
the subject matter of this litigation and is not reasonably
calculated to lead to the discovery of admissible evidence.
Without waiving the above objection, defendant states that it has
no such board meeting minutes.
50 HRV-PL-1578
Q. 89.
Please identify by name, address and phone
number each person who has provided this answering party with
statements in connection with this litigation.
A. 89. This defendant has not engaged in sufficient discovery to enable it to respond fully to this interrogatory.
Q. 90.
Please identify each person who has been
interviewed in the course of preparing for the trial of this
matter.
A. 90.
This defendant has not engaged in sufficient
discovery to enable it to respond fully to this interrogatory.
Q. 91.
Has this defendant ever sold any asbestos-
containing products to Insulation and Material Company of St.
Louis, Missouri or any other individual, corporation, partnership
or other business entities within a 100 mile radius of Madison
County, Illinois since 1920 including but not limited to St.
Louis County, St. Louis City, St. Charles County, Missouri or
Madison County or St. Clair County, Illinois, if so, state:
(a) List all individuals, corporations,
partnerships or other business entities you have sold asbestos-
containing products to.
(b) State all dates when asbestos-
containing products were sold to these entities.
(c) State what asbestos-containing
products were sold to these entities and identify by brand name.
(d) State what quantity of asbestos
products were sold to these entities.
(e) Provide copies of all purchase orders,
specifications, contracts or correspondence with the entities
identified in (a) above or otherwise identify all documents
relating to the sale.
51
HRV-PL--15 V 9
A. 91.
This defendant objects to this interrogatory
as being vague, ambiguous, irrelevant, overly broad, burdensome
and oppressive, not reasonably calculated to lead to the
discovery of admissible evidence and not limited to any issue
which is the subject of this case. Without waiving the above
objection, this defendant has found no information in its records
indicating sale of its asbestos-containing products to Insulation
and Material Company of St. Louis, Missouri. This defendant
objects to further answering this defendant on the basis that
plaintiff has not provided any company names and time periods for
reference. Upon receipt of such information defendant will make
available any relevant documents, subject to any objections at
that time.
Q. 92.
Have you ever sold any asbestos-containing
products to:
Monsanto, East St. Louis, Illinois
Marathon Oil Refinery, Robinson, Illinois
Shell Oil Refinery, Roxana, Illinois
Amoco Refinery, Wood River, Illinois
Clark Oil Company Refinery, Hartford, Illinois
Granite City Steel, Granite City, Illinois
Illinois Power Company (Alton Powerhouse)
Central Illinois Power Service (Coffeen Powerhouse)
Commonwealth Edison (Kinkaid Powerhouse)
Illinois Power Company .(Portage Des Sioux Powerhouse)
Central Illinois Power Service (Meredosia Powerhouse)
Illinois Power Company (Grant Fork Powerhouse)
Owens-Illinois Glass Company, Alton, Illinois
Central Illinois Power Service (Baldwin Powerhouse)
Central Illinois Power Service (Pearle Powerhouse)
Central Illinois Power Service (Marion Powerhouse)
Central Illinois Power Service (Newton Powerhouse)
Texaco Oil Company Refinery, Lawrenceville, Illinois
American Steel, Granite City, Illinois
52
HRV--PL-1580
Cerro Copper, Granite City, Illinois Consolidated Aluminum Company, Granite City, Illinois Olin Corporation, Easton Alton, Illinois Laclede Steel Company, Alton, Illinois Sinclair Oil Refinery, Hartford, Illinois Apex Oil Refinery, Hartford, Illinois and if so:
(a) List all individuals, corporations, partnerships, or other business entities you have sold asbestoscontaining products to.
(b) State all dates when asbestoscontaining products were sold to these entities.
(c) State what asbestos-containing products were sold to these entities and identify by brand name.
(d) State what quantity of asbestoscontaining products were sold to these entities.
(e) Provide copies of all purchase orders, specifications, contracts or correspondence with the entities identified in (a) above or otherwise identify all documents relating to the sale.
A. 92. This defendant objects to answering this
interrogatory on the basis that no dates were stated in reference
to any of the companies. Upon receipt of such information
defendant will make available any relevant documents, subject to
any objections at that time.
.
Q. 93.
Has this defendant ever been a General
Contractor or Subcontractor where it used asbestos-containing
products at any of the following locations:
Monsanto, East St. Louis, Illinois
Marathon Oil Refinery, Robinson, Illinois
Shell Oil Refinery, Roxana, Illinois
Amoco Refinery, Wood River, Illinois
Clark Oil Company Refinery, Hartford, Illinois
53
HRV-PL-1531
Granite City Steel, Granite City, Illinois Illinois Power Company (Alton Powerhouse) Central Illinois Power Service (Coffeen Powerhouse) Commonwealth Edison (Kinkaid Powerhouse) Illinois Power Company (Portage Des Sioux Powerhouse) Central Illinois Power Service (Meredosia Powerhouse) Illinois Power Company (Grant Fork Powerhouse) Owens-Illinois Glass Company, Alton, Illinois Central Illinois Power Service (Baldwin Powerhouse) Central Illinois Power Service (Pearle Powerhouse) Central Illinois Power Service (Marion Powerhouse) Central Illinois Power Service (Newton Powerhouse) Texaco Oil Company Refinery, Lawrenceville, Illinois American Steel, Granite City, Illinois Cerro Copper, Granite City, Illinois Consolidated Aluminum Company, Granite City, Illinois Olin Corporation, Easton Alton, Illinois Laclede Steel Company, Alton, Illinois Sinclair Oil Refinery, Hartford, Illinois Apex Oil Refinery, Hartford, Illinois and if so:
(a) List all individuals, corporations, partnerships, or other business entities you have sold asbestoscontaining products to.
(b) State all dates when asbestoscontaining products were sold to these entities.
(c) State what asbestos-containing products were sold to these entities and identify by brand name.
. (d) state what quantity of asbestoscontaining products were sold to these entities.
(e) Provide copies of all purchase orders, specifications, contracts or correspondence with the entities identified in (a) above or otherwise identify all documents relating to the sale.
54
HRV-PL- 1 5 8 32
A. 93. Refer to answer to Interrogatory No. 49.
Q. 94. Did this defendant ever provide any warning concerning the hazards of asbestos to any of the following companies:
Monsanto, East St. Louis, Illinois Marathon Oil Refinery, Robinson, Illinois Shell Oil Refinery, Roxana, Illinois Amoco Refinery, Wood River, Illinois Clark Oil Company Refinery, Hartford, Illinois Granite City Steel, Granite City, Illinois Illinois Power Company (Alton Powerhouse) Central Illinois Power Service (Coffeen Powerhouse) Commonwealth Edison (Kinkaid Powerhouse) Illinois Power Company (Portage Des Sioux Powerhouse) Central Illinois Power Service (Meredosia Powerhouse) Illinois Power Company (Grant Fork Powerhouse) Owens-Illinois Glass Company, Alton, Illinois Central Illinois Power Service (Baldwin Powerhouse) Central Illinois Power Service (Pearle Powerhouse) Central Illinois Power Service (Marion Powerhouse) Central Illinois Power Service (Newton Powerhouse) Texaco Oil Company Refinery, Lawrenceville, Illinois American Steel, Granite City, Illinois Cerro Copper, Granite City, Illinois Consolidated Aluminum Cgropany, Granite City, Illinois Olin Corporation, Easton Alton, Illinois Laclede Steel Company, Alton, Illinois Sinclair Oil Refinery, Hartford, Illinois Apex Oil Refinery, Hartford, Illinois If so, identify what the warning was, how the warning was delivered and when the warning was delivered. Provide copy of warning and correspondence concerning the warning.
55
HRV-PL--1583
A. 9944..
This defendant ceased the manufacture, sale
and distribution of asbestos-containing products in 1958. This
defendant has not found information in its records sufficient to
enable it to answer this interrogatory. However, it does not
appear that any warning concerning asbestos was given in that it
does not appear that this defendant had reason to believe that
the use of its products would result in a foreseeable risk of
harm.
Q. 95.
Has this defendant ever had any
correspondence with any of the following companies or facilities
concerning products containing asbestos:
Monsanto, East St. Louis, Illinois
Marathon Oil Refinery, Robinson, Illinois
Shell Oil Refinery, Roxana, Illinois
Amoco Refinery, Wood River, Illinois
Clark Oil Company Refinery, Hartford, Illinois
Granite City Steel, Granite City, Illinois
Illinois Power Company (Alton Powerhouse)
Central Illinois Power Service (Coffeen Powerhouse)
Commonwealth Edison (Kinkaid Powerhouse)
Illinois Power Company (Portage Des Sioux Powerhouse)
Central Illinois Power Service (Meredosia Powerhouse)
Illinois Power Company (Grant Fork Powerhouse)
Owens-Illinois Glass Company, Alton, Illinois
Central Illinois Power .Service (Baldwin Powerhouse)
Central Illinois Power Service (Pearle Powerhouse)
Central Illinois Power Service (Marion Powerhouse)
Central Illinois Power Service (Newton Powerhouse)
Texaco Oil Company Refinery, Lawrenceville, Illinois
American Steel, Granite City, Illinois
Cerro Copper, Granite City, Illinois
Consolidated Aluminum Company, Granite City, Illinois
Olin Corporation, Easton Alton, Illinois
Laclede Steel Company, Alton, Illinois
56
HHV-PL-1584
Sinclair Oil Refinery, Hartford, Illinois Apex Oil Refinery, Hartford, Illinois If so, provide copy of any correspondence with any of the above companies concerning asbestos-containing products.
A. 95.
This defendant objects to answering this
interrogatory on the basis that no dates were stated in reference
to any of the companies. Upon receipt of such information
defendant will make available any relevant documents, subject to
any objections at that time.
57 HRV-PL 1585
AFFIDAVIT
STATE OF OHIO COUNTY OF LUCAS
)SS:
M. F. MCCARTHY, being duly sworn according to law, deposes and says that he is an Assistant Secretary of OwensIllinois, Inc., a defendant herein; that as such he is authorized to make an Affidavit on its behalf; and that the facts set forth in the foregoing DEFENDANT, OWENS-ILLINOIS, INC.'S ANSWERS TO INTERROGATORIES, are true and correct to the best of his knowledge, information and belief.
M. F. MCCARTHY
SWORN TO and subscribed
before me
day
1987.
My Commission Expires:
BEVERLY A. McNEAR Notary Public -- State of OtttO My Commission Expires Jan. 29, 1890
HRV-PL-1586
EXHIBIT
I
HRV--PL--1550
r
i Owens-Illinois
BERLIN, NEW JERSEY
rUBLISHED BY AND FOR THE PEOPLE OF
THE BERLIN PLANT
KAYLONIZER
ONE OF THE
FAMILY
Volume 1
July 1956
Number 3
NEO SERINIS, "POPPY" SCURTI RETIRE
Retired at the end of last month vere two men familiar to most Plant 95 Onlzers. They were'NEO SERINIS and DOMINIC "POPPY" SCURTI.
?-----"iwyiii. >. \
t'
- - ` * -t
atoH
NEO SERINIS, who had been employed with the Company for 13 years, was born in
Caesaria, Turkey in 1889 and attended
high school and Anatolia college in that country.
Coming to the United States in 1919> at the age of twenty, he completed his ed ucation at Drexel Institute in Phila delphia, where he majored in chemistry. Recently he attended his graduation class's 4oth year reunion at that school.
DOMINIC SCURTI
NEO SERINIS
DOMINIC "POPPY" SCURTI, a nine-year employ ee in the Berlin Plant, was born in a town near Naples, Italy in 1891. Arriving in this country,then he lived in Philadelphia and Jersey City before moving to W. Berlin.
He began work here in 19^7 In the Maintnance Department, was transferred to Per sonnel as office Janitor, and his last Job was in the Production Department.
The father of three children, POPPY lives on Pine Avenue in West Berlin. His son, JOE SCURTI, works in the Mold Repair Department.
POPPY will long be remembered for his many fine games of bocci and morra on the Diamond Derby Days.
NEO came to the Berlin Plant of OwensIllinois in 19^3 and- 'became plant chem ist, a position he was to hold until his retirement last-month.
In his research capacity he played a major part in the development of the SID (Simultaneous Indurating and Drying) process currently used in the production of Kaylo which speeded up the operation and proved more economical, than the previous method.
The father of four children, Neo lives at 5 South Cedar Avenue in Berlin.
In the future he will be assisting in the General Research Department on a consultation basis.
NO-ACCIDENT MARK SET
The people of 0wen3-Illinois Plant 95 have worked over six months without a lost-time accident, comprising a total of 201,041 accident free man-hours.
Now that he has retired, he will occupy his time with gardening which has been his hobby for some time.
The last lost-time accident was Decem ber 7, 1955-
T Q Q T -Id L -A H H
PS & QUIPS Charles Congdon ByWalt Townsend
Well, here we are at the beginning of the vacation season* Several Onlzers from the "Maintenance Department have already departed to spend a few romantic and leisurely weeks in some far away place.
EARL "Baldy" FITTING and his wife have left for Florida and from there to Havana, Cuba* We are sure EARL will have a wonderful time, lucky fellow. Perhaps, when our bills are all paid up, we will be able to make a similar trip.
STAN ZELIilY and his family have also left for the tropical paradise of Florida. STAN said he was certain he would do some of that much publicized gulf fishing.' STAN did not have much luck fishing locally at Bamegat Bay. We certainly hope that his luck changes with the diaate*
These summer weekends seem to take their
toll in more ways than one, you know the
ones where Saturday and Sunday are
crowded into a trip to the beach. Well,
TCM PITALE came back fran Atlantic City
on Monday a sadder and wiser person. He
told your reporter he got burned. TOM
really meant that he acquired a bad case
of sun burn.
`
Although SANDY LISA is not a member of the Maintenance Department, her presence as a secretary to HERALD CCIEGROVE, Plant Engineer, makes her an honorary member of the department* SANDY also was unable to report for werk for a fbw days due to an over exposure of the sun. Both SANDY and TOM will feel sorry for any further lobsters they see in restaur ants, knowing Just hew they must feel.
Speaking of fishing CHARLIE STRECK, one of our Dowtherm Experts,tells of a beautiful catch of fish he and four friends made last Sunday. Fifty Flukes, he said, all over two pounds each. CHARLIE said that the only thing wrong with the trip was that the captain and the first mate insisted on baiting the hook, hauling in the fish, taking the fish from the hook and in general making, nuisances of themselves* CHARLIE might Just as well have stayed home and bought the fish after the boat docked.
Your reporter, CHARLIE CONGDON, has pro duced the first dahlias of the season. He presented a fine bouquet to recep tionist, IODISE McCAFTREY, and hopes to keep her desk decorated with flowers as
they become available. He also has zinnias blooming and hopes to have asters in the near future.
WAIT GRAZIANO, being ever alert, informed us that the word acetylene was mis spelled on the safety sign by the front entrance on the dbchine shop. Following up this bit of news, we found that WAIT was right.
HERALD COITGROVE sure was a happy fellow the other week. The reason, you see, was that his daughter, RUTH, was to be narried. We extend our best wishes to RUTH and her husband. HERALD also sports a great big smile viienaver his son JIM'S name is mentioned* JIM is a Jet pilot in the U. S. Air Force. Well, HEJLAID you talk about JIM and his Jets and in a few ysars I hope to talk about ny son and his rockets unless he decides to be a machinist like his dad, then I will try to get him a Job with Owens-Illinois.
mRALD, incidantly. Just returned from the first half of his vacation. He tells us that he spent it in Ohio visiting his folkB.
We hear PRES DAW50N is quite a trapper. Perhaps some of you ladies are wearing coats made of some animals that FRES has caught such as muskrats, coons and even skunks. FRES also likes to dabble in herb tonic. If PIES had been born sooner he could have been a medicine man and had his own show. You know what we mean, the real old fashioned kind with Indians, banjo playing and pet snakes.
HRV-PL--1552
KNOW YOUR REPORTER
SPOTLIGHTS AL PIERCE
When he had completed his tour of duty in Japan, AL was given his discharge. He took a vacation after that, like many a returning serviceman.
Upon his return to Plant 95* AL accepted the Job of Inventory Tally Clerk, in the Warehouse and Shipping Department, a posi tion he is still holding.
AL is an active worker in civic affairs . He holds the rank of Lieutenant in the Berlin Volunteer Fire Company and is a member of the Berlin V. F. W. Post, No.
6253-
Among AL's many hobbies are fishing, hunt ing, photography and water skiing. In fact, he Is such an enthusiast that any one venturing near the sea,-shore resort of Grassy Sound on a weekend can be almost certain of seeing AL skimming across the bay on his water skis.
AL PIERCE
The featured reporter in this issue is ALVIN PIERCE, our ace newspaperman from the Warehouse and Shipping Department who writes the column titled "Inter Nos."
AL, like many other Onlzers employed at
Plant 95, Is a home town boy, born, reared
and educated right In Berlin. He attended
Berlin grammar school and Haddon Heights
high school.
.
AL and his wife, Darlene, who live on Jackson Road in Berlin, are the proud parents of a twenty-month-old daughter, Allene.
He tells us that his life's greatest am bition is to own and operate his own bus iness .
The most thrilling experience in AL's life, he says, happened to him in the Air Force while on tour of duty in Japan.
He became a member of the Owens-Illinois family on October 1, 1950, when he took a Job in the Mold Repair Department.
But he was not destined to remain long, for in November of 1951 AL received his greetings from Uncle Sam and Joined the U.S. Air Force.
After completing his basic training at Turner Air Force Base in Georgia, he was transferred to a number of bases before being sent to Japan.
While he was in the process of checking out a Jet plane, it made a sudden lunge forward. AL averted what could have beer. a disaster by being quick on the trigger. He stopped the plane before any damage was done.
AL thinks that this incident aged him all of five years in the few seconds it happened.
If you haven't figured it out by this time, "Inter Nos," the name of AL's column, means "between us" in latin.
J <
k
t " f
(
[
KNOW YOUR REPORTER
SPOTLIGHTS AL PIERCE
When he had completed his tour of duty ir.
rv Japan, AL was given his discharge. He
r took a vacation after that, like many a returning serviceman.
Upon his return to Plant 95, AL accepted
the Job of Inventory Tally Clerk, in the Warehouse and Shipping Department, a posi tion he is still holding.
AL is an active worker in civic affairs. He holds the rank of Lieutenant in the Berlin Volunteer Fire Company and is a member of the Berlin V. F. W. Post, No.
6253-
,
Among AL's many hobbies are fishing, hunt ing, photography and water skiing. In fact, he is such an enthusiast that any one venturing near the sea-shore resort of Grassy Sound on a weekend can be almost certain of seeing AL skimming across the bay on his water skis.
AL PIERCE
The featured reporter in this issue is ALVIN PIERCE, our ace newspaperman from the Warehouse and Shipping Department who writes the column titled "Inter Nos."
AL, like many other Onlters employed at
Plant 95, is a home town boy, born, reared
and educated right in Berlin. He attended
Berlin grammar school and Haddon Heights
high school.
.
AL and his wife, Darlene, who live on Jackson Road in Berlin, are the proud parents of a twenty-month-old daughter, Allene.
He tells us that his life's greatest am bition is to own and operate his own bus iness .
The most thrilling experience in AL's life, be says, happened to him in the Air Force while on tour of duty in Japan.
He became a member of the Owens-Illinois family on October 1, 1950, when he took a Job in the Mold Repair Department.
But he was not destined to remain long, for in November of 1951 AL received his greetings from Uncle Sam and Joined the U.S. Air Force .
After completing his basic training at Turner Air Force Base in Georgia, he was transferred to a number of bases before being sent to Japan.
While he was in the process of checking out a Jet plane, it made a sudden lunge forward. AL averted what could have beer. a disaster by being quick on the trigger. He stopped the plane before any damage was done.
AL thinks that this Incident aged him all of five years in the few seconds it happened.
If you haven't figured it out by this time, "Inter Nos," the name of AL's column, means "between us" in latln.
JJ M
^
^
U
* ]
1S54
Robert Adams William Fitting Richard Geissinger
Warren Irvin Walter Eitelbach
Stanley Zellny
John Rhoads' Herman HcCurry Anthony Melevin
Charles Juliano Russell Hand
Thomas Knott Charles Tomlinson Rodger Cook Antin Kapij Elmer Goetz
July lU July 16 July 22 July 26 July 29 July 29 July 30 August 3 August 3 August U August 7 August 7 August 7 August 10 August 10 August lit
ISV
HRV-PL-15 5 S
sanoy'b
cophep
THE LI ST tNING KE
By Sandy Lisa
For you Gecrge Gobel fans Wio wish to see e live version of the *ow you nay do so ty coming to the Service Depart* raent and a siting DARIO BE1F0NTI to do his version of Lonesome George* We hear that he does a real good Job.
LOUISE McCAFFREI is really patriotic. We hear that ^ie gets her sun Ian in the farm of a "V".
Congratulations to JEAR DiBLASI on the birth of a son, IEO, JR. JEAN was a former receptionist at Plant 95.
A hearty welcome to CHARIES "Chuck" AUSTIN. CHUCK joined the Industrial Engineering Department of Plant 95 on July 1, 1956. CHUCK is a graduate of Guilford College there he majored in History, and Business Administration. CHUCK, and his wife BEVERU, make their home in Pitman, N. J. CHUCK recently returned from a two year hitch in the Marines.
DARIO BEIFONTI and JOE PLICX are cur rently enjoying their vacations. Your reporter will have more to add to this article upon their return to work.
A farewell luncheon was given to LEE FHJELL by the girls in the office on July 29, 1956. The affair was held at the Old Tavern. LEE was presented with a lovely evening bag as a rememberance gift. She was also presented with a very unusual corsage.
WALT EHELBACH, who recently spent three days in Chicago on compary business, had quite an experience. It seems the fligfc WAIT was scheduled to return on had been over sold. The air line then offered WAIT $50.00 for his ticket plus a seat on another flight. Too tired to get up? Money isn't everything! We think it was just "Do or Die" for old 0-1. Walt just bad to get back on the job.
SUZANNE ERICKSON is the latest addition to the office staff. SUZANNE recently accepted a job in the Bonus Department. She hails from Manteno, Illinois and is currently living in Berlin, N. J. while her husband, who is serving in the U. S* Amy, is stationed at a nearby Niki Station. SUZANNE and her husband recently purchased a Pekingese puppy and is currently in the process of find ing a name for it.
PARKER ELECTED PRESIDENT
BILL PALLIES from the local freight office is spending a three week vacation In Seattle, Washington. (We wonder if he is looking for some of EARL SHARP'S shipments?).
CHARLEY PARKER, Safety Director in the Glassboro, New Jersey Plant of the Closure and Plastics Division of OwensIllinois, recently was elected Presi dent of the South Jersey Indvs*r_3l Council. The Council is composed of safety directors of leading industries in the South Jersey area.
All the girls in the front office are completely happy again. EIMER GCETZ has received a deferment from the Arny and it has done wonders for the*girls' morale.
FOR SALE
1 - U cyUnder motor completely over hauled minus generator, starter, mani fold, water pump, fan and carburetor. Contact C. H. INGERSOLL.
HRV-PL-1556
THREE-HC ,R FIRE TEST PROVES KAYLO 20 PROTECTS STEEL WELL
EARL FITTING lights the fuel oil to start the three-hour fire test
In order to demonstrate to visiting engi neers that Kaylo 20 makes an excellent protection for structural steel, a fuel oil fire was started and continued for three hours.
Temperatures of the fire approached 2CCC degrees Fahrenheit at times, while the steel remained safe.
The results of the test were highly sat isfactory to our visiting customers vho witnessed it.
GROUND BROKEN FOR O-l CUBA PLANT
Following ground-breaking ceremonies for the new Owens-Illinois Plant at San Jose de las Lajas, June 15, crews of workmen and huge bulldozers went to work prepar ing the site for the one-story glass plant.
ident Batista at the end of the ceremonies which were attended by a large crowd of Cuban people. Mr. Megowen spoke to the gathering in English and his remarks were translated for the audience into Spanish by an interpreter.
President of the Republic of Cuba, Fulgencio Batista y Zaldivar, and Carl Me gowen, President of Owens-Illinois, per formed the ground-breaking ceremony with a glass shovel, the handle of which was made of Cuban mahogany.
The glass shovel vas presented to Pres
In his short address, President Batista welcomed Owens-Illinois to Cuba.
Other speakers were Dr. Emeterio S. Santovenia, Chairman of the Board and President of BANFAIC; Mayor Navarro of San Jose de las Lajas and Dr. Joaquin Martinez Saenz, President of the National Bank of Cuba.
This is an artist's drawing of the new . Owens-Illinois Glass Company plant located at San Jose de Las Lajas, a few miles from Havana. Ground breaking ceremonies were held June 15. The plant is sched uled for completion the latter part of 1957.
HRV -- PL--1557
.Bjr Dick Cassaiio
Safety Director
SAFETY ABOUND HOME CALI5 FCR OH THE JOB CARE
It is a startling fact that more accidents occur in and around the home than any where else. This simply means that if the same safety rules used at w<rk were applied in practice in our homes, th<y would bo much sefer places to live in.
Wc 311 know that many times home accidents oncoming car. A moment of carelessness
can cause suffering and expense to the family involved. Safety is catching.
may mean a lifetime of regret.
Whole families should catch it and re
solve to keep their homes as safe as possible.
HEAT SICKNESS
The best way to do this is to have a heme
ISsafety check list. This list should
cover such items as these:
AVOIDABLE
INSIDE THE HOUSE Keep all'medicines, poisons, insecticides and cleaning fluids out of reach of young children. Read labels carefully and the directions twice before using medicine. Only use medicine as properly prescribed by the doctor.
Heat sickness may be divided into three types.* 1* Heat Cramps ihich arc caused by the excessive loss of SALT and WATER which have not been replaced. This condition can be avoided.
Be careful of slippery floors and throw rugs. Keep stairways arri floors free of articles which might cause people to fall.
OUTSIDE THE HOUSE Sec that hoso, rakes and sharp tools are never left with the edges up; all nails should be removed from broken boxes and boards. Be sure that your clothesline is strung high enough to prevent aryone from running into it.
2. Heat Exhaustion which is caused by the excessive loss of SAIT, SUGAR and WATER which has not be replaced. This condition can be avoided.
3. Heat Stroke which is caused by heat retention. The heat regulating mech anism of the body is put out of order because the individual is not in good ` condition and has not taicn daily baths to bring down the body temperature.
Garage doors should always bo left open vhen the car is running. Go slow in and out of the driveway and make sure no one is in the way. Sound your horn. Many small children have been fatally injured by cars backing over them.
STREETS AMD SIDEWALKS See that ^he "whole family crosses at intersections only, and always on the green light* Never cross behind a parked car or truck. Mary children are injured every year darting out from parked cars into the path of another
This condition builds up over a period of many hours or several days* This condition can bo avoided. Prompt treat ment may influence the cutcome.
In the cases of heat sickness, it is probably not any one factor which is entirely responsible. Temperature, humidity, air motion, muscular exercise, physical condition all contribute to heat sickness.
HBV--PL--1558
TOM HUBER NAMED O-I'S
HAVANA PLANT MANAGER
Tom M.-Huber has recently been Darned Plant Manager of the Company's nev plant in Ha vana Cuba, according to an announcement by John L. Gushman, Vice President in charge of the International Division.
LIBBEY SALES CHANGES
ANNOUNCED
The growing importance of the nation's Southeastern area has resulted in two ma jor changes in the sales organization for Owens-Illinois, according to William M. Beckler, General Sales Manager.
Mr. Huber, formerly supervisor of the Quality and Specifications Department in the Alton Plant of the Company's Glass Container Division, will spend several months in training to give him additional training for his nev assignment, the an nouncement said.
Mr. Huber joined Owens-Illinois in Janu ary, 19^6, and this year will receive his 10-year service pin at the Toledo Cere mony in October.
Changes call for the promotion of George B. Skinta to the position of Southeastern Regional Sales Manager, and the appoint ment of Thomas F. Bensinger as Manager of a new branch office in Miami, Florida.
Mr. Skinta, former Atlanta Branch Manager, will be responsible for the operation of Libbey sales branches in Atlanta, Georgia, Richmond,Virginia, Nev Orleans, Louisiana, and Miami, Florida.
He joined the Libbey sales staff in 19^0
and in 19^3
assigned to the Nev York
sales office and four years later was
named Manager at Atlanta.
Mr. Bensinger has been with Libbey since 1950. In 1952 he was appointed Manager of Libbey*s branch at Richmond and in 195^ was named Assistant Manager of the Chicago Libbey Office.
DID YOU KNOW?
New Jersey's Garden State Parkway was rated as the safest super-highway in the country during 1955*
TOM M. HUBER
His first duties at the Alton Plant vere in the Central Shops and in the Control laboratory. In June, 19^9> he was as signed as junior project engineer in the Glass Control Laboratory and in 1953 be came Control Laboratory Supervisor at Alton.
Later the same year, Mr. Huber was named Quality and Specifications Supervisor. He gained his Bachelor of Science degree at the University of Illinois.
There are almost twice as many automobiles in Los Angeles alone as in all of South America.
Since 1900 the number of people over 6p has quadrupled while the total popula tion has only doubled.
As a result of technological growth, there are more than U0,000 different ways in which Americans can earn a living.
HRV-PL-X 5 5 9
CM PROMOTES SPECIAL BEFR BOl TLE 5
TOLEDO, 0. -- Owens-Illinois Glass Comparer, a principal supplier of bottles to the brewing industry, will spend a million dollars this year on initial promotion of special no-deposit quart size beer bottles which the company predicts will boost national beor consumption.
The comprehensive marketing program, spearheaded by a heavy magazine and newspaper advertising campaign which began recently, is based on long-term research and on O-I's sales experiences during the last decade which indicate that with postwar changes in the American way of life, beer has become more of a family and social get-together beverage.
0-1 says this is emphasized by two major marketing facts*
1. More than 50% of all beer taken into the home is consuse d after evening meals and -iiien guests or friends are present.
2. h6% of all beer used at home is consumed by television viewers.
The glass company 1s staking its promotional investment on the belief that this is a large market vhich will be receptive to its no-deposit no-return quart bottles because they combine the convenience of multiple servings with other appeals particularly suited to family usage.
These special advantages are hammered home in the advertising campaign which appeared in recent issues of UFB and LOOK. The full-page ads to be followed by 18 mere in the same magazines and by It77 newspaper ads in 37 major markets will point out that:
1. "Beer stays cold (within the just-right ItO - 50 degree temperature
range)
longer in these special quart bottles than in 12 oz. cans."
2. "The no-deposit, no-retum bottles are more convenient -- you don't have
to take than back."
.
3. "pouring through a bottle neck makes it possible, by proper aeration, to serve beer at its best."
U. "Glass is unmatched as a inert protector of beer's sensitive flavor. Glass has no teste of its own."
5* "The 'party size' quart serves five fill glasses of your favorite beer at its best."
Owens-Illinois officials believe that the quart no-deposit bottles offer 0. S* brewers a natural and economic medium to use in increasing the per capita consumption of beer.
O-I backs its faith in these no-deposit bottles on its experiences as a supplier of lorgc volume glass containers to other packagers of foods, beverages and household products.
Smith L. Rairdon, vice president in charge of marketing, said that many factors point up the potential of the larger no-deposit battles.
- continued -
HRV -- PL-- 15 6 0
"Today," he said, "more and more foods and beverages are i^eing bought in larger unit3 because they combine convenience and econony.
"No-deposit quart beer bottles not only combine convenience and economy, but in addition offer the consumer newly-verified advantages of temperature maintenance and the flavor protection that comes with the pouring of beer from a bottle.
"AH these factors should add up to acceptional acceptance in the growing 'beer at home1 market," Mr, Rairdon said. He noted that a unit purchase of a no-return quart beer bottle carries 2 2/3 time3 the quantity of a standard 12 oz. container.
"It is a market axiom," he pointed out, "that the more of a product there is at hard, the more of that product is consumed."
Mr, Rairdon cited the convenience factor as of extreme importance.
"The modern caisuner seeks convenience products," he declared, "and many sales records prove the point. In the last seven years, instant coffee sales have jumped Ii39, cake mix sales 13ii and frozen fruit juices have increased 5ii80S, all stimulated ty the virtues of the convenience they offer. The no-deposit quart bottle because it doesn't have to bo taken bade to the store and because it allows easy multiple servings, answers the same demands for convenience.
"Thorough consideration of all these recognized factors and trends," he concluded, "has resulted in this timely initiation of our broad marketing effort."
The no-deposit, quart bottle advertising schedule for the remainder of 1956 includes 20 full-page blade and white ads in LIFE and LOOK starting in July and continuing twice-a-month through October and once a month thereafter*
Full-page ads will appear bi-weekly during July and August in 53 newspapers covering 37 najor beer markets. These will be followed in September and October by 1500 line ads.
Beer retailers will also be reached with two-page spreads in FOOD TOPICS and SUPERMARKET NEWS on a bi-weekly schedule during July and August and monthly in September and October.
The newspaper advertising on a Thursday evening Friday morning schedule will
appear in the Philadelphia Bulletin and numerous other leading newspapers through
out the United States*
GROUP INSURANCE FOR JUNE
Sickness disability insurance peid six employees
$658.57
Hospital bills paid twoemployees U07.15
Five hospital bills paid
dependents
391.27
Three bills paid forsurgery
205.00
Total for the month
$1,661.99
BATHINS NOW PERMITTED FROM STEEL PIER
The Steel Pier has added to its many fine attractions the privilege of bathing from the pier.
Anyone desiring to bath from the pier may do so by requesting a bathing club tickat upon paying admission to pier.
No additional cost is required for this privilege. Towels may be rented for a sira 11 fee.
HRV-PL--1561
THE ROVING CAMERAMAN CATCHES ONIZERS AT BOWLING BANQUET
Sere are last season's bowling league cham pions , the "Bowl Weevils." From left they are: team captain, JOHN PERSHING, DARIO BELFONTI, BART BOWERS, MOE BRADDOCK, HUGH WHELAN, and THOMAS PITAIE. League presi dent, THOMAS PITAIE, makes the presenta tion of the championship plaque to them.
A group of Onlzers and their husbands are snapped as they watch the evening's enter tainment. They are, from left: FRANNY FIDELL, YOLANDA FIDELL, AL McCAFFREY, LOUISE McCaffrey, lee fidell, doris teske and SANDY LISA.
Among those who attended the intra-plant Bowling Banquet at Moffa's Farm were; MRS. RAY ALLCOTT, EDDIE FANZ, EVELYN FANZ, BOB FITTING and GLORIA FITTING. They seem to be having a fine time.
STEPHANIE INGERSOLL is shovr. receiving the award trophy for having captured the highest average in the women's class. THOMAS PITALE makes the presentation to her.
HRV-PL-1562
FINISHING -NEWS
By Richard Kreis
THE DCCTOR SAYS
By Dr, Henry C. Schwartz
A little bird tells us that ALLTE HEDGAN JR, and his wife are expecting the stork to pay them a visit in the fall. Try to be patient ALLIE these things take tine.
The medicine your doctor told you to take right after breakfast should bo taken the: not as an afterthought just before lunch according to Today's Health.
JCE SC 10LI played a fine game at first base for tbs plant softball team the other night.
ALBERT HUFF'S son BUDDT, who has been at hone on a three week furlough from the Air Force, left the other day for California. AL tells us that he will be assigned to an air unit stationed in Japan.
Tour doctor has important reasons for telling you to take one kind of pill before meals, another right after meals, cr another first thing in the morning.
Far example , same capsules he prescribes have built-in timing mechanisms so they can produce delayed action, repeat action or controlled release over a certain period of time.
Best of luck to "POPPI" SCURTI who re
tired from Owens-Illinois the end of
June. "F0PFT" win always be remembered
for a job well done on the Flatware
Finishing Line,
'
CHARLIE SIEFERT returned recently from a two week -ra cation. We hoar that he is building a new home and spent most of his vacation working on it. CHARLIE says that he will have plenty of time for pleasure when his home Is complete.
Take the capsule at the wrong time and you throw that whole schedule off.
Certain drugs arc more effective on an empty store ch. On the other hand, others can be irritating to the stomach lining if taken before meals--the reason the doctor specified they be taken irnnediatel. after a meal.
In short, just as important as the medi cine you take is \*en you take it.
Now that the Circle "A* ranch is open again, TOUT DiSTEFAMD is back in his glory. TONI, we are told, is an ardent horseman*
lour reporter RICHARD KREIS is toying with the idea of building a new home. He Is undecided whether to build a home or save his money for his anticipated trip to Europe next year.
BERLIN OPIZEES
HAVE WORKED
Don't tip off the opposing teams in the Inter-Plant Softball League but anyone venturing into the vicinity of Penbiyn in the evening can see BOB FITZPATRICK practicing his secret pitch for the second half of the season.
Understand SAL MARANO'S wife has been on the sick list ibr a few weeks. Hope she is up and around in the near future.
DATS
WITHOUT A LC6T-TIME ACCIDENT THE LAST LOST-TIME ACCIDENT OCCURRED
DECEMBER 7. 1955
HRV--PL--1563
nURSE"5 nOTES
On the aide list:
LEE HENRI is home from the Naval Hos pital after an operation, LEE is coming along fine, and after some more of his wife's good home cookin' should be back on the job in the near future.
CHARLIE SINNOTT returned home from the hospital after undergoing another oper ation on his injured arm and leg. All the pins have now been removed from both his arm and leg,
A hearty welcome is extended to the following new Onlzers recently hired or returned from the service: HARGIS BERG, WALTER SIMFSCN, HAROLD WCLFRUM, JOHN GORSKI, SETH TOWNSEND, RICHARD CAVALUCCI, CHARLES AUSTIN, SUZANNE ERICKSON, WOLFGANG FRANKE and JAMES KNOLL. WOLFIE recently returned from the U, S. Air Force and Jim finished a hitch in the Army.
JUNE WELSER has returned to work after mdergoing an operation at Cooper Hos pital, Good to see you back JUNE,
ONIZED DOINGS
By Yolanda Fidell
SANDY LISA was on the sick list for a few days due to a bad case of sun burn,
JOHN GGtSKI has been absent ill for a few days due to a bad case of tonsilitis.
Sorry to see you leave:
LEE FIDELL, who replaced MARI DI BLASE while MARI was on a leave of absence, left us on July 1, 1956, LEE certainly did a swell job pinch hitting for MARI. IEE did much of the ground work and assisted in making the first two issues of the KAILONIZER a success, Mary thanks, LEE, for a job well done.
Stork news:
MARI and JCSEFH DI BIASE are now the proud parents of a beby boy, bom on June 11, 1956, JOSEPH, JR. weighed 7 pounds and 11^ ounces and is 19 inches tall.
JEAN DI BLASI gave birth to a 3on on June 28, 1956, LEO, JR, weighed in at 6 pounds 8 ounces and was 20 inches tall.
EDNA STEWART had a son on June 27, 1956. He weighed 8 pounds and 1: ounces and wes 21 inches tall, (June must be baby boy month)
Congratulations to the proud parents and hello to all the new Onlzers.
During the latter part of June, letters with an enclosed postcard were mailed
out to all Plant 95 Onlzers. The pur
pose of the letters was to acquire the ideas of all Onlzers on hew to make our Qnlzed Club a better organization* To date the response has been very ligir. lour Executive Council urges all who have not returned their cards to do so as soon as possible. Get your ideas in. This is your club and it will only be as good as you, the cambers, make it.
The Social Council is now in the process of making plans for the Annual All Plant Picnic, The date for the picnic has been set for Monday, September 3, 1956. Check the next issue of the KAILONIZER for the time and location.
Rruit baskets were sent to the following Onlzers last month: CHARIES JULIANO anc JUNE WEXEER.
HUGH IE WHELAN, JEAN DI BLASI, EDNA STEWART, and MARY DI BLASE were fee recipients of baby blankets in June. All the new arrivals last month were boys. We believe this sets a record in the Onlzed Family,
There are nine times as many Jobs in the United States today as there were a century ago.
HRV -- PL. -- 1564
THE ROVING CAMERAMAN
Here AL CLOUD, chief test clerk, of the Quality and Control Department compiles the previous day's figures.
LOU DESTEFANO and ALLIE HEGGAN vork on a special order on the Finishing Department,
PAUL FITZPATRICK and BUD DUMMIRE of the Warehouse and Shipping Department load a carload of Kaylo products for shipment.
DICK GEISSINGER, of the Finishing Depart ment, inspects ware at the discharge end of one of four saws used to trim Kaylo before it is packed and shipped to custom ers .
HBV-PL-1565
SICE LET ON 5 IN KAYLO PRODUCTS
Did you know that every cubic foot of Kaylo contains millions and millions of skeletons?
IVs true, for one of the materials that goes into the production of Kaylo prod ucts is diatomaceous silica which is made up of the tiny skeletons of single celled plants called diatoms.
Diatoms, which are types of algae that live in the water, cannot be seen in dividually with the unaided eye, but in colonies they appear as jelly-like globs either floating free or attached to other plants*
Through a microscope the thousands of different diatom types can be seen. Some are shaped like discs, others have eliptical, triangular or rectangular shapes, while still others are thread-like in appearance.
The cell walls of these plants have un usual designs on them, arranged in or nate patterns and resembling jewels. They are some of the most beautiful crea tures of the microsoopic world.
The unique thing about the diatom is that it lives in a glass house. The living diatom is composed of live matter Inside two walls held together by a band or "girdle," so that it looks much like a pillbox.
The cell walls are made of silica which the plant extracts from the water and incorporates initself. The walls have a glassy, transparent quality and the plant, in reality, lives behind "windows" of a sort.
Some diatom sizes and designs and anatomy diagram.
conditions were right for diatoms. And too, because of the many volcanoes, the oceans of the Miocene era were full of soluable silicas* The wealth of silica permitted these algae to multiply very quickly.
As huge numbers of these plants repro duced and died, their skeletons sank to the bottom of the sea, gradually build ing up thick deposits.
In following ages, the crust of the earth buckled and the ocean floor was lifted into the air, becoming mountain ranges and laying bare the layers of diatoms, now white and chalky in appear ance.
But it was not until a relatively few years ago, in 1890, that anyone real ized the value of these deposits. It was discovered that this diatomaceous earth was an excellent insulating ma terial and mining operations were be gun. Since, the demand for this mater ial has grown as new uses far it are discovered.
At certain times in the past when condi tions were favorable for growth and re
production, huge numbers of them existed in the oceans. One such period was the Miocene age, millions of year before man made his appearance on the scene.
At that time, food, temperature and light
Besides its ordinary insulating proper
ties, diatomaceous silica is used in Kaylo products because it can withstand very high temperatures without melting and thus is valuable as insulation in areas where great heat is generated.
HRV-PL-1566
WINS O - / GRANT
A Woodward High School Senior in Toledo is the* first boy to avail himself of the opportunity to further his education under the recently-established OwensIllinois university scholarship fund.
He is John D. Sutton and he won the scholarship, worth $5#525, for a fiveyear period at Cornell University in Ithaca, New York.
"INTER NOS"
By A1 Pierce
All of us in the Warehouse and Shipping Department are waiting for BUD DUNMIHE to build that swimming pool he has been talking about all winter. Rignt now it is still one of his many ideas. We hope that it will soon become a reality now that sumrer is here.
Officials at Cornell announced the scholarship had been awarded on the basis of Mr. Sutton's high grades, class leadership and extracurricular activities* Woodward officials said Mr. Sutton would
AL DAVIS has moved his boat to Wildwood this summer. He can now be seen buzzing around the bay at Grassy Sound, and we do mean buzzing.
be graduated at the top or near the top of his class.
That sure is a fine looking porch that JCE RIESS has added to his home. We
Owens-Illinois established its educat ional aid program benefitting colls ges,
know that JCE will spend mary of his leisure hours on it this summer.
scholars and high school teachers in widely scattered parts of the United States in an announcement May 1, 1956.
Sorry to hear about RAY FIATT'S son having the misfortune of falling from his bicycle and breaking his leg. RAY
tells us that RONNIE is coming along
O-l FILM WINS SECOND PLACE
fine and should he up and around soon.
While fishing in the bay at Grassy Sound the other week, your reporter had the good fortune of hooking on to and
boating a 6:J- pound flounder. Anyone
The sound-slide film, "Do You Fill Pre scriptions Here?" produced by OwensIllinois and the National Wholesale
desiring to see jroof of this catch mzy do 30 by dropping into the Shipping Office.
Druggists' Association# recently received an outstanding honor.
CONNIE SCHAFFER has Joined the plant softball team as a pitcher. He made a
Among 83 slide films in competition, the 0-1 and NWDA film was awarded second place in its field by the National
fine showing in his first appearance on the mound and we are looking forward to sons fine pitching from CONNIE.
Visual Presentation Association and the Sales Executive Club of New York at the 1956 Visual Presentation Competition.
REMINDER
The award was made for outstanding
achievement in the development of a visual presentation, which reflects the best principles of effective communi cation.
All Qnlzers are requested to remember that when calling the plant after h;30 PM or on weekends, the following number should be used: Be 7-968ii.
All other open circuits in the plant are out of hearing distance to the supervisor on duty.
HRV--PL-1567
t HRV-PL-1568
EXHIBIT
II
HRV-PL-158V
A NEW HEAT INSULATION WITH REMARKABLE COMBINATION OF ADVANTAGES....
A
fviylo Hen
J:...
* new type of light* e:g.-.: L sulation ihit is tjr-ifu tzc. used it ordinary room :e\ nd rtttUtnt enough :o per;'o lively up to 12 00* F.
Few new products of m* been so thoroughl* rtseir;.-. being placed on the mince Hear Injuliting Block :t :,-e mant of many yeirs' torn ; Illinois Glass Cortspinv e phystaiti and chemists.
No other material. :ti effectively combines :,it me able characteris'tcs o: -me .
insulation.
For instance
LOW OINSITY
Kayio Heat Intulstm weight oaly 11 pounds per ; This light weight (less thin o to the board foot) sirapiihet shipping and application reduces weight--in impom tige on ships, for sn exam:.
'V
HRV--PL--1589
Notice the clem. >"1 *
on these insulated pre. ;
pers. Applicators nnc
kind of work with Ka* - ' '
ing Block because me* - '
cut and yet they ha*e i r .
rttsturtl strength. The *
hoppers ire also miu.i tt '
Heat Insulating Bloc*.
*nO "**f wiuAtxe boat -t*f iCtl wo* 1>l Wibffl
iL:**a
s* >. . te SOT t '
UM
Inside or outside, for large isra:latioas or *buIL from 0 to 1200* F . on Kayio Heat Insulating Block :s insulate: ' . - ... * . ' - *
Breechings'
Lehrs
Hot Air Ducts
AutocL** es
Tanks
Ovens
Towers
Furnaces
Dryers
Turbia.fi
Evaporators
Calling = -
Heat Exchangers
Boilers
Condensers
Pff;Si:i '
Locomotives
SOURCES Of TEST DATA-
The data shows oa these ?*"
'art supported by testa run tt-var-. o-j
laboratories, all well knoo to - f
insulation industry. They are'fur*--e.-
supported by the performance i` --
produa to jerries. '
"*
More detailed informacos Kayio Heat Insulating Block -i **.* able oa request. American 5\r^--
Products Company. Toledo Subsidiary of Oweos-Ilhnoti _ * Coeapaoy.
HRV-PL--1590
LOW THERMAL CONDUCTIVITY
The coefficient of conductivity, or . K. . of ki'io Heit Insulating Block.
< iro(t on the chart on pig* four. ice* tr among the mo it "efficient tir*
.-iations for medium high tempera_.-et. Iti insulation value come* pnn. i paiIv from it* hne. interlaced cellular structure. The** cell* are o tiny and ;o numtroui that they preiint a matrial surface of approximately HO icre* per cubic foot of insulation.
Experience show* that the insula.on value of Kaylo ioiuiation im proves when the material is put into tervice.
FFECTIVI OVER WIDi TEMPERA TURK RANGE
Kaylo Heat Insulating Block perorm* efficiently not only on tempersart* in the low pressure steam and hot vater range but on temperatures in he superheated steam range as well. This is shown by the flatness of the ooductivity nine. One-material covrage with Kaylo insulation handles ppiications which oftea require two rudenesses of different materials.
-MGH COMPRESSIVE STRENGTH
Its compressive strength is unsually high for a hrintrai product of uch light weight. Kaylo Heat Insu- -
Iiting Block withstands compression values equivalent to those of a man s walking on it or tuen to thore-of a heel s being ground mto it.
high tlexural strength
Its flexural strength is higherthan the normal requirement for heat insu lation of this type. This strength makes for easy handling and applica tion. and contributes ro long service with low maintenance.
NO ADDED UNDER
Kaylo insulation is an inorganic compound, containing no added binder. Its performance characteris tics. therefor*, are not affected by additives. which often reduce insulat ing value, modify effective tempera ture range or otherwise limit per formance.
EASY TO APPLY WELL
Kaylo Heat Insulating Blocks are clean-cut and trim. They art caay to fit into place to make * good-looking installation. Their "feel" is pleasant and non-irritating. They can be cut. scored and sawed with ordinary wood working tools. Finishes that go over the block, whether cement, cloth or other types, can be applied smoothly snd with a minimum of effort. No special tools art needed.
LOW MOISTURE AlSOmtOH
Moriftir* .b(o.'?r,o. ,0 .... ! e m w 11 * SC j v I o i n i u, c:: 3 - r. . . ^ ^ "
subjected to an it--.ot;.-.e.-c relati-.e humidm ana a
of i:0* F-. in standard mtns absorb less than I" by v oium*.
. "
RETAINS EFFECTIVENESS AFTE? LONG SERVICE
Kaylo Heat Insulating Block ,-emains strong, fret from excessive pondering, and shows little j0fi
weight or shrinkage afier long ipp.ication to temperatures up to liio1 f. Even conventional tumbling tests, run after prolonged heating, procure relatively little crumbling or a.-ea*.. down of the material.
STANDARO SIZES
Lengths Widths [ Thieknesies
(inches) (inches) ' finches 1
HS 6
l
56 6
1 >>
56 6 2 ^
56 56 56 1
6 2`A
6 ____ 3:
12 --------- 1------------- :
56
56 56
|
1 1
12 12 12
m :
2!-i
1 12
i'
Oihf m*l *ft tvtiUOlt oft Jptciti orarr
On large or small equipment, in i* or out. Kaylo Heat Insulating lock performs efficiently and wnh a immum of maintenance. Here it is ring applied to the walls 0/ a large ecipiiaior. Workmen are. laying ock over 6" x 6" wire mesh welded
'he stiffeners. The block are then >v*red with finishing cement and phalt mastic weatherproofing.
Kivio Heat Insuiating Block cov ers bom Jif and curved surfaces on the power house equipment pictured here. At me right are fresh air intakes: the center compartment* house in duced draft fans; and at the left are conduits letding to a precipitator. Kaylo insulation means continuous fuel savings to this power plant.
Hot water is always resdv *f needed in the office building this hot w ater storage tank is mui. t: thanks to Kaylo Heat Insulating B.o- This permanent insulation holds *lf temperature constant with a of power consumption.
Other implications for Kitlo Heet I"'- '
me block art lined 00 ihe hack pi|
HRV--PL--1591
PHYSICAL
CHARACTERISTICS at A SLAN'CE
.Approximitelv 11 lb- per cu. ft,
5 0 lb. per sq. in.
(it 5* deformation)
Before besting
130 lb. per sq. in.
After hesdng for 24 boors.
st 7 JO* F.........................
st 1000* F......................
st 1200* F...........7.;.;. . * J ,*' -r*
`
After boiling for 24 hours (while ct)
144 lb. per tq. in. 123 lb. per sq. is. 117 lb. per sq. is.
74 lb. per sq. its.
fc-
%
After hetdotjor 24 hours." :V; a-.-j . tT~'
* ' st 750* F... st 1000* F. st 1200* F.
After boiliaf for 24 hours
5.3*
7.9*
9-#*
0.2*
. : 4 o' * :7r
(Conventions! Tumbling Ten--Loss is weight sftcr 10 minutes)
^ w Before hesdsg*.'*..........
2.2* _
We--^ *C _*
* .^
**8&i
^ 2 . I*' At 1000 C* * * wWs* e^ ^
** 4 ' m * k*
m*-- a*
[ . * **T
At 1
*
* -V**-- *
' ^T;**4'
.*
--* * * + * * * *. + J*/ `C1, T
* **-V .* :
j - \ 7m
' vV^tT.' CilaTTfT*^ oTNTftW-.: '^..r ^
* -s
3.7* \* 3.7 *:" 7'
6.9%
1 - Linesr Shrioitsge sfter besting for 2 4 brs. * " " 7io-F...:::.v~::.^;................ st 1000* F.................................................. st 1200* F..................................................
Elongstioo sftcr iiturstion (mss.).............
0.1*
0.9* 1.3 *
0.4*
1.' (volume)
After 6 hours exposure in atmosphere of 120* F. and 90* Relsdee Humidity........
0.9*
A * * RA*
Z 6 S T - 'Iti- A H H
principal
Features
OF KAYtO HEAT I ?1 5 U L A 7 J ?J G 3 l 0 C :{
EXTREMELY LIGHTWEIGHT
H R V -P L - 1 S 9 3
NO ADDED BINDER
rtrr&tIV _
'vt-DISCHIFTtON
Keyle Structural IntuUiinf tfecfc--is a near-white. rigid mineral insula: material weighing approximately 20 pound* per cubic foot. It is cs.t.pcs* ; principally of calcium silicate. Except for density and for those charac`*~: ncs that are changed by density it is similar to Kvyla Hm Insulai2 a hgr.tweight insulation used to insulate against heat loss from hot y_ri. - Kaylo Structural Emulating Block 20-lb. density) is designed to :* * maximum strength and Are resistance without sacrificing its adva.vj.'Tlight weigr.t aod low t.-.emal conductivity. In fact the practical com.:.*i: of these four properties--strength, weight, insulating value and .vs ** ance--caves it aimost unique as a building material.
It weighi nominally 20 pounds to the cubic foot (actually on an over . * basis from 19-5 to 22 lb.), has a compressive strength of approximate lb. per sq. in., a "k" of 0.66 at 100 mean and outstanding resistance :: navel of heat and flame at building Are temoenruret.
i struct
Kaylo Structural Insulating Block it not 4 finished build* ing'matenai in itself and is not made for exposure to the weather. its principal uses are at a structural roof tile, or roof deck unit, in which a steel reinforcing mat is inserted at the time of forming, and as a core material. In this latter use it serves as the core of laminated structures where the facts or laminates are applied with adhesives, and also as the core of structural shells or envelopes where the Kaylo core material is simply inserted is the open spaces and held by its own contact or by such conven* tional methods as clips or other attachments.
In any of these applications it adds rigidity to the structure and vastly increases insulation value and fire resistance.
PHYSICAL rPROPERTIES
light weight--Nominal 20-lb. density Kaylo Block is about a third lighter than yellow pine. On an oven-dry basis it weigr.s from 19.5 to 22 pounds per cubic foot.
High Strength--Its compressive strength is approximately ,
500 lb. per sq. in. with a deformation of 5 per cent. Flexural
strength is approximately 175 lb. per aq. in.
,
Kr*ere*#--Kaylo 20*lb. density Structural Insulating Block has been tested at the Underwriters' Laboratories m Chicago and given the following' rating; based on com panion with untreated Red Oak as 100.
Flame spread........................ 0.0
Fuel contributed......... .. negligible
Smoke produced.
0.0
For use in fabrications that are to be Under*-- -
atones inspected. Kaylo Structural Insu.at:*V = ~".
furnished bearing the Underwriters' laoei icr.
classification for building material.
' ""
o-;----------- -------- --------
\ CONOUCnvrTY "K
fio
n
Mean
`f.
Oeed Intvletfen
At low mean temperature*
Structural Insulating Block is one of the mes:
structural mineral insulations. At high mean :e-rr-i-
it still compares favorably with heat insulating -
of its own weight.
High light fteflectivity--TVhere left exposed art as with the underside of a roof deck: Kayic i Insulating Block has high light reflectivity I:: flection factor is from 70* to 80 per cent.
.
Nen-Abretive Surfec*-- Its surface is non-abras. * ' a somewhat "soapy feel that makes it pleasant it -. At the samt time it has a firm surface that auu-1-- .
contact with surfaces applied over it.
He Added Under--It contains no added binder : '
stead constitute* its own binder. Hence its cr.i.-. -
are not modified as to temperature limit, soi-t ' '
tan on value, fire resistance or otherwise
'
limitations."
HRV -- PL--1595
0*d
Kaylo Structural Insulating Block is
responsive to wood working tools. It can be sawed with a
hind saw or power saw, can be routed, tongue-and-
grooved, sanded, and, in fact, run through most wood
working equipment.
HijK Mdwlv* ef lfe*rtfty--The modulus of elasticity of JC'-lb. density block is approximately 160.000 lb. per sq. in.
Uw Sp*Hl H*r--The specific heat of Kaylo Structural Insulating Block is approximately 0.22.
CelMer Sfruetvre--Kaylo Structural Insulating Block is
about SO per cent inter-communicating air cells. The cells are extremely small, leaa than a micron is diameter.
Lew Meifture AbserptUn--Kaylo Structural Block is hy
groscopic. It will absorb moisture from humid air and will reach equilibrium at lower moisture contents when exposed to lower humidities. However, because of its extremely small pore site and other characteristics, its behavior with respect to moisture differs from that of most porous ma terials. It has unusual capacity to distribute moisture within its mass, and to give it off to surrounding air of ,'ower moisture content.
Its moisture absorption when surrounded by humid air ; o\ Test specimens dried for 24 hours at 215" F.. cooled
ir.d `her. exposed on all surfaces to an atmosphere of 90 net cent relative humidity and a temperature of 120* F.
s:x hours, absorbed less than one per cent of moisture by volume.
rm.iistent with the common practice for good construc
tion involving porous insulating materials of high interna! surface area, Kaylo Structural Insulating Block should
oe sealed against moisture on the wans sdt when it is subjected to extremely low temperatures.
Hi9h w*t Strength--Kaylo Structural Insulating Block,
..ke most other insulating materials, is not intended to ;?rve immersed in water or exposed to extremely damp or numid conditions, yet its flexural strength wnen wet .im mersed 10 hoursj is reduced only about 15 per cent.
Oimn*inlty
The dimensions of Kaylo
-
ural Insulating Block change little with char.res
-
ure content. Experience has shown from the manii'a-"
of thousands of units of laminated structures that
have unusual dimensional stability and unusuai'freect'--
from warping,
"
Available with end withevt teintercinf-- In :he fo*--
roof tile Kaylo Structural Insulation is aviyVoie
sue! reinforcing mat. In the form of core material -.-a-,
ious t}-pes of structure it is available without reir.f:::..-::.
Atceptt Neils end Screws--Both nails and screws car. re used with Kaylo Structural Block. Tables showing ,-c. power of both art available on request. Kails snou.c be the cement-coated typ without barbs that abrace sides of the opening they make as thev art driven into
block. Galvanized or non-ferrous nails may be used w.-.e-? greater resistance to corrosion is required.' Screws miv r-* inserted either with or without drilling a pilot hole. `
Slits--Kaylo Structural Insulating Block is made ir. i standard size at IS x 36 inchea.
Since most uses involve manufacturing operations.
nesses that are practical can best be worked out
manufacturer oi Kavio Insulating Products after izzrz-: -
mate quantities needed are known. These will usua..y z
between one and two inches thick.
*
Cer.ain thicknesses are suggested by certain buiitirr -=quirements. A thickness of from l** to 2 inches o: Ka . Structural Insulating Block is required to atthsurt _ typical bunding nre for one hour--usually somew.-.a: .r - fora partition than for a door because of the greater formanct required of a partition.
PO-Lb. end 11-th. Density lleek Cen 9 Used in Cembine-'O"-
Wher* two thicknesses of insulation are used to bu..t -r an insulating structure it is possible to us* the two sities in comoination to develop the best insulation va. -e strength and fire resistance.
jr
r AMERICAN STRUCTURAL r 1 PRODUCTS COMPANY
Telede I, Okie
the sen-ice re^u-f.T.ents of the ~n-*-e*i ::
LAMINATION
still offer some cr.c:.e :n cunrip a.-actc'-res.
Some adht-.vc-s wive- nr.- be ..-i
fee a "ate.raJj are
V -..f
;
Lo.ot.n *v*e * **yl* 1"*uJ
^ ia t;ni
r.al may b* boiwl to ^>lo otrocturJln u.atm?
to be com: e-.e. it.;
-e -s -a
'.i it of adhesr.e;. The-e have bee a foorc t a a.-:
;n 3nc 3
f.?h<*>'->. ' *- -- " - -
'
-
QJ/JS & )adhesives for joining
73
ADHESIVES FOR joining Like material:
STRUCTURAL INSULATING BLOCK TO:
W4 V*n*or
Aluminum
5fiinl*t Sl*tl
ln*ultinf ftticfc
ti
Intulvtinf llik
f
S
Aluminum
*
Aluminum
Sl>n(*t SUl SlainUtt Su*J
Ovr*t N*. 39344 ^0 ^
302*4 WM?7
f
3024* w*
1
Oi
0113'
M* C*'< 7W
M* 31-11
o* o
fit*
U.'t 703*
o
o
***
i
!.-< O: K<Il g u
-- -12'. w Owl
I
Ov~* n*. 303** A
*MW 311 Wl !**
U**4,i *, 1
Qf
I
0 i' Qf
oo
41*3
VHi(*J*(t
00
0v**<"
&****
0. L 3W3 C. L 3031
-4 31-H
44*4*1`**
MU
*<* (K '31
t(*V4
o o
o
o o
Ovr<*t Mt 303* Q
M. 4. nh3*7
HI 04
,-K ooo
O
M*. \ Q
*t*:
v *******
00
oo
*JJ
0V****
0 I. 3U3 C. I. 3031
t* Jin
4 * MU
*.* 703*-'
o o
o
o
0 o
Ova** 343**
>wH* 01131
wU>m4
1 S. L 1U3
eia>**H *11
SUnr-- 3003
Vwflwal M* 31-lt
o o o o
o
o o
M14 U.r-* 703*
o
!>>* (If 13* o
(u'iuw 1.<icr J O
**U( f O
!. 1134*.. O -- 1JOIW Oiw
VUtvlMk
hm 4*33
0>.**
00
ooo
ooo
0. f. 7031 ki* 393*
M HI 131 t*Uu
o
o
o
o
<4*33 30
G. t. *331
*<-( 733*
(|
Uu.i in
!*
{|
d
-* r
A 69X
( Ctimp*! oi mm
lie 2* h*urt.
Oimp*! in
t 120*F. fir 1 hiur.
Symbols fir mtHioA if cunt [
For Minimum Slronyth ;
Flit*! in pf** at 10 p-a.i. * 300* F. fir 10-30 nrinulrt.
Q Ft<*l .n putt it 100 p.*a. mt VX? f. fir 10-30 minufi*.
Clomp*! in *n t 250* Ft firt-J&SO mmuM*.
H:t.'i-f3*uu#ncy cunnf haj boon tnrd tuccaaafully on an n-j*nrnitil b**it ttn vood. jiununum *nd (Uinlti <ta*i bondtd 'o 4 iCayia. '.MiiUnrj cor*. Many o( th* roanufactumt mainnf tn* aoov* .uc*l *d.k.nn can proved* tdba'' tuiLaoU (or hicn-frrquancy cnrmv.
asauEJSffiKi ausiasTias^-
PESOQJCTS (3M(?&SCT
TOlfDO I. OHIO
IwlailiMr * OWfH-tUie*Ort .* CO-'*--
_ r.
T/T U
AKTASSS...
-uke a good-looking installation. Their "feel" is -Icasim and non-irritating. They can b* cue. scored nd sawed with ordinary woodworking tools. Finishes nat go o'er the block, whether cement, cloth or other . pes. can be applied smoothly and with a minimum f effort. No special tools are needed.
OW MOISTURf ABSORPTION. Kaylo Heat Insulat-
ng Block absorbs little moisture from surrounding umsd air.
FffCTtVl AFTIR LONG SIRV1CL Kaylo Heat Insulat-
ig Block remains strong, free from excessive powder* ig. and shows little loss in weight or shrinkage after sng application to temperatures tip to 1200* F. v ea conventional rumbliog tests, ruo after prolonged eating, produce relatively little crumbling or break* own of the material.
TPKAL APPUCATIONS:
Tilde or outside, for large installations or small, up to 200' F.. use Kaylo Heat losulating Block to insulate:
*e<fcChhilnAe|s o3t Air Ducts IIU1 o**rl .-vers - iporsiori
Heat Exchangers Condensers Lehrs
Autoclaves
0ens Furnaces
Turbtnes Chilling Pics Boilers Precipitators Locomotives
iy(o Hoot Inswloting Hock cavers both Has and curved -facts on the power houao equipment pictured here. By nimiimg heat lost, it saves fuel aod keeps lempemures :hm the room at cotafonable levels.
PHYSICAL CHARACTERfSTiCS
OINfltr...............................................*eve.ettr 11 rt t. >
Htaueaa STttNdtM................................................. S0'
,,.
co*ets*m staiMOtH * t?t *f*r* **(...................................................... 1 SO Ik. ... .
i(i. -rve fe. 1* vest
at <
WI00-*.*.........................................................................
< t :oo- r............................................. Afr .s f*r Ja a**-i thA <i.. .
I Si ' *' .v "
123 *' V *
7t t v*
Ti *
lOt IN vetlOMT
Aftvr
]i Uui
710' f..................................................................
t tC't......................................................................
ei 1100' r......................................................................
*her VvU*e <w I* hours tetter ery*3........................
aiCtestnatvawNCei ttyowoatuapaasttOueNw * *et ** t 0 --iUiI
Setere *eoff...................................................................
Afteetr h7ve1t0w*e7......l..a....h...e..u..n................................................ i icoo1 *.................................................................... <1 1200' ................................................................
OIMfNSIONAC STaaitlTV
V-vver
fw*
<er Jl *rfs
710* *..............................................
et ' 000 *...................................................
*1 1 ISO *..................... -........................
tlvf***w #". ** l*eA.l...................
oi*Tuai aasoeertON i..tvi *tir a uvi ** - *tAWiehv'v t
'20 f ** *0r, ar e*.'V "v*..*v
3 5"
..0.2*
**. :i
CONPWCTIVITT 1*1
mmim.At 100*' * ********......................
** 200' 7.
teeremr*.........................
*
a 8 <
l
d
eUNCfHfe
r
o o
o o
o 1K
o o o GI
o o <D
0 o
o 0
o 0
CO
0 00
?- HEAT (NSULATfKQ SIOCK
Haaf lo*i, Surfoc# Tamparofurt, and EfficI netei
^.=*ca.
111 '
:jc/
LOSSlftOM. R>TjURfACE5 _ rr^. =?=y'--- ' j
-- sun?Acr^riMJunjRe_Df. iNSUunoN_r^-- ^=ziE^~z
~ 7 '7^J
"i55 553 555 355 355 555 733 B5 SB i4M " n4T4--Tjoo Tmpfotura Oiffaraact, Bora Surfoca to Air, *f.
SOUtCIS OP Tin DATA: The dmes >bo*a oa
these page* u supported bj tests rus *t **r*
ioui laboratories. *U well kaowa to cbe iomlittoa iadustrj. They it* further supported
by the performance of the product ia service.
'
M*r* detailed li*rermtieM oa ICayto Heut losuiatiog Block ie available oa request. Americas Structural Product*
HRV-PL-1599
* = -JF` JrV*
-
O O 9 X -ld -A H H
Keyje Sirvtwl IruMri IJedt---is a near-white. rigid mineral ir.su.a: - TBatarial weighing approximately 20 pounds per cubic foot. It is cctr.:-:" -^principally-of caldumailiace. Except for density and for those cha.*ac'-"
'tics that are changed by density it is similar to Kayio Htoi InsuLau^ : a lightweight insulation used to Insulate against heat loss from hot s.: * . Kaylo Structural .Insulating 3lock f20-lb. density} is designed to maximum strength and fire resistance without sacrificing its adva.vj.--tight weight and low thermal conductivity. In fact the practical corn: "a of these four properties--strength, weight, insulating value and r.rr *ance--makes it aimost unique as a building material.
It weighs nominally 20 pounds to the cubic foot (actually on an o' *" basis from 19.5 to 22 lb.), has a compressive strength of approximate lb. per *q. in., a "k" of 0.66 at 100 mean and outstanding resistance .. travel of heat and flame at building Are urnpencum.
20.LS.
OENsirr
For um in fabrication* tea: are to be Undenvrcerj La---,
atones inspected. Kayi; Structural Insulating 2:c<.Z' -
furnished bearing the Underwriters4 labei for icrs -a--.
clarification for building material.
' *" *
O----------------------------------------------------------------------
Kavlo Structural Insulating Block is not a finished buildmg'matenal in itself and is not made for exposure to the veather. Its principal uses are as a structural roof tile, or roof deck unit, in which a steel reinforcing mat is inserted at the time of forming, and as a core material. In this latter use it serves as tht core of laminated structures where the faces or laminates are applied with adhesives,
and also as the core of structural shells or envelopes whert the Kavlo core material is simply inserted in the open spaces and held by its own contact or by such conven
tional methods as clips or other attachments.
In any of these applications it adds rigidity to the structure and vastly increases insulation value and fire resistance.
PHYSICAL PROPERTIES
Light Weight--Nominal 20*!b. density Kaylo Block N about a thirc iizr.ter tnan yellow pine. Oh an ov*n-dry basis it weighs from 19.5 to "22 pounds per cubic foot.
High Strength--Its compressive strength is approximately 500 ',b. per sq. in. with a deformation of 5 per cent. Flexural strer.gtr. is approximately 175 ib. per sq. in.
Krepree#--Kaylo 20-lb. density Structural Insulating
Block has been tested at the Underwriters' Laboratories m Chicago and given the following rating, based on com parison with untreated Red Oak as 100.
Flame spread........................ 0.0
Fuel contributed...................negligible
Smoke produced . *
0.0
<Ge*4 inswfetien V(ee--At low mean temperature* Kaylo
Structural Insulating B'ock is one of the most etf.cier.: structural mineral insulations. At high mean temperatures it sr.U compares favorably with heat insuiatir.g mater.a.i of its own weight.
High tight tefleetiviry--TThtre left exposed and xntreatez as with the underside of a roof decio Kaylo Si.*uc:,_,x. Insulating 3!ock has high light reflectivity. Its flection factor is from 70 to 50 per cent.
hfen-Abseiiv* Svrigc*--Its surface is non-abrasive, it tu a somewhat ``soapy4' feel that makes it pleasant to har.c.e At the same Otoe it has a firm surface that assures gooc contact with surfaces applied over it.
Ne A44*4 Hfidw--It contains no added binder, but rstead constitutes its own binder. Hence its characteristics are not modified as to temperature limit, solubility, ms-lation value, fire resistance or otherwise by "bince.* limitations."
TRUCTURAL IWSUE.ATIMG BLOC EC
Gek W#fkWlfty--Kaylo Structural Insulating Block is responsive to wood working tools! It can be sawed with a hand saw or power saw, can be routed. tongue-and-
grooved, sandec, and. in fact, run through most wood
working equipment.
0im*nfiftlly iieW*--The dimensions of Kav:o _____
ural Insulating Block change little with changes
ure content, Experience has shown from the mar.y'a--
of thousands of units of laminattd structures that '--Y-
have unusual dimensional stabiiicv and unusual
from warping.
` "'
Mifh MeWului *
The modulus of elasticity
of 20-lb. density block is approximately 160.000 lb.
per $q. in.
AveileWe wtth end wtfhewt teinfertlng--In the '0rm
roof rile Kaylo Structural Insulation is available wv-Y steei rem/oreing mat. In the form of core material ,'c* Y--
Lew Seetihe Meet--The specific heat of Kaylo Struc ious types of structure it is available without reinforcing.
tural Insulating Block is approximately 0.22.
Net]* and Jeiwwt--Both nails and screws ca
Ceiluler Strvctwrw--Kaylo Structural Insulating Block is used with Kaylo Structural Block. Tables showing hole: - g
about 80 per cent inter-communicating air cells. The power of both are available on request. N'ails should be
cells are extremely small, lesa than a micron in diameter. the cement-coated type without barb* that abrade
rides of the opening they make a* they are driven inro Lew Meittvre Abterptie*--Kaylo Structural Block is block. Galvanized or non-ferrous nails may be used where
hygroscopic. It will absorb moisture from humid air and greater resistance to corrosion is required. Scre#s may oe
will reach equilibrium at lower moisture contents when inserted either with or without drilling a pilot hole.
exposed to lower humiditie*. However, because of its extremely small pore size and other characteristics, iu
C behavior with respect to moisture differs from that of most porous materials. It has unusual capacity to dis
tribute moisture within iu mass, and to give it off to surrounding air of lower moisture content.
Site*--Kaylo Structural Twnirmy Block is made in a standard size of IS x 36 inches.
Since most uses involve manufacturing operations, thick nesses that art practical can best be worked out wu- :.-.e manufacturer of Kaylo Insulating Products after approx -
Its moisture absorption when surrounded by humid air mate quantities needed are laiown. These will usual,v ;-i
is low. Test specimens dried for 24 hours at 215* T.. between one and two inches thick.
'
cooied and then exposed on all surfaces to an atmos phere of 90 per cent relative humidity and a tempera ture of 120* r. for six hours, absorbed less than one per cent of moisture by volume.
Certain thicknesses are suggested by certain buiicir.g re quirements. A thickness of from I:* to 2 inches of Ka- . Structural Insulating Block is required to wu.nstarr typical building fire for one hour--usually somewna; rr.t'e
Consistent with the common practice for good construc tion involving porous insulating materials of high
for a partition than for a door because of the greater per . formance required of a partition.
internal surface area. Kaylo Structural Insulating Block snould be sealed against moisture on the warm side when it is subjected to ezoameiy.low temperatures.
20-lk. end 11-Lk. Density Deck Can le Ui4 in
Where two thicknesses of insulation art used to buuc -r an insulating structure it is possible to use the two ten
Htfh Wet Strength--Kaylo Structural Insulating Block, like most other insulating materials, is not intended to serve immersed in water or exposed to extremely damp or humid conditions, yet iu flexural strength when wt (immersed 10 hours) is reduced only about 15 per cent.
sities in combination to develop the best insulation w-e strength and fire resistance.
Kaylo Division
OWENS-ILLINOIS
GLASS COMPANY
Telede 1, Okie
*
* 4 ogg. I i
b
HRV-PL-1602
f=
LAMINATION
lominetien aver e Ky( Inivletmf C*f*--Almoit 37.V face material may be bonded to Kaylo Structural Insul ating Slock surfaces. Bonding agenci'can be *i*cted co meet the requirement! of the particular facing--a iso co satufv the service requirements of the finiihed product --and still offer lome choice in curing procedure*.
Some adhesive and various types of fate
list is not inter.red :?
primers whicn mav
materials are be complete. Its
ic:-f.r:UV
oe
5e
-
-
identify a pa*-.'.a! ' s: o: acnesives. \-
ditec cots rot ~.~/m :*a*:: u *c:
been four.d to prov.de a tensile screr.r:.-
square inch a.* a a mtr.tm.um shear strer.
per square me * wit; cured accord:.-; ::
turers recommendation. They art ho:
order of their adhesive strength.)
A0MISIV1S AND MIMIM PO JOINlNO nf7/I\V7rU^ STKUCTUHAL INSULATING ILOCK TQ
Weed Veneer er Peeer
er Ple*ttc*
Ownte Me. J01**
0
*** dljt
0
'cere 71* Ceiebene 730
o o
WnyOeei ma 2*-'*
o
aaeemre et la
0
SeaA 701*
0
taCai
O
otyrnm S-l3a#*U0tW IPWl
0
A/Mme J-"*J
o
oTee
Jteef, Steinle** Steel
1!'Oelventel. er Aluminurti
Intuletinf Iteck er Cement* A tbeate* leerd
CW.e r*e. 302** er n. a *1*7
UlOO
1
w
9i
o--e j;:*a r**aei,i* 61111
0 0
e*eere ril
O j ArMarreef i 11*1
0
laK lie 11 Jl
009 o
hs<M 1
ax Dai
'0 9
h<U rae, I
0 lilimeeiOOl
0
hwiete at*l
90
Vuyeeet MA 1X1*
9
VvUeMtt
00
i*e Mn ee-ia
0
OkAe 4*JJ
900 t--fc73*
0
OuTue 44a*
909 tea* mill
0
nanakeu e.l 1
O la ten SScete
o
OX 1141
9 lr*va
o
ax ron
9 0Srme I.*JAfU0t.w (Owl
*eu*791*
O liwninx t-t}
0
hue ttl US
0 %e
o
h<M 1007
O
vUtA.1 aaa 31.i*
9
.ceereia et.la `
O
O--
.Ifl--I J-1141
O
Clemped et teem tempereture fee 24 heur*.
Symbols for method of cure:
Per Meximum Strength
Clemped in even et 120* P. fee 1 heur.
et3 Pieced in preaa 10 *.*.<. et 300* P. fee 1Q>30 minute*.
Pieced in pret* el 100 p.a.i. et 300* P. fer 10*30 minute*. 1
[ Clempoe m even et 250* P. fer 10-30 minute*.
t:
t
8
8 <
l
d
i R 0 0
u
Hi(h-freoueney cunrif hu been tried meeeeofully on an aipefi mental baaia enth *oed. aluminum and ftamleet iteei bonded to t Kaylo inaulaonj tore. Many of the runufaettirer* malnn( the above luted odhenveo con provide adhemvee >uitable lor hijh-freoueney curmt-
Kaylo Division OWENS-ILLINOIS GLASS COMPANY
rU4 ?, OkU
c
>
r
f t
_
L~-
G
i
w
c;
5
c
a
WITH A REMARKABLE COMBINATION C
KAnO HUT INSULATING UOOC is * new type 0/
lig htweigbt mineral insuladon that it tfititHt enough to b* us<l tt ordinary room remperitursi md mhutt enough to perform effecdvely up to 1200* f-
Few new product* 0/ toy kind heve been to thor oughly researched before being placed oa th market. Kaylo Heat Insulating Block is the achievement of many years' ork by Owens-Illinois Glut Company engi neers, physicists and chemists. It combines tb most desirable characteristics of tht td*Ai beat insulation.
LOW DENSITY. Kaylo Hat Insulating Block weighs
only 11 pouodt par cubic foot. Thit light weight (Itit thaa one pound to tht board foot) simplifies handling, shipping and application.
LOW THCXMAL CONDUCTIVITY. The coetfdent of
conductivity, or i, of Kaylo Heat Iaiulatiag Block placet it aaoag tha most efficient iotuladoai for medium high temperatures. Iti insulation vtlu cotaai priodpally from at* fine. cellular structure. Theta ceili are 10 day aad 10 numerous that they prcieat a material surface of approximately 140 acre! par cubic foot of ioiuladoa.
Experience shows that the eAdeacyof Kaylo insulauoo improves after exposure to service temperatures.
EFFECTIVE OVER WIDE TEMPERATURE RANGE.
Kaylo Heat lasuladng Block performs tficicnuv only oa temperatures in the low pressure iteam hot water range but 00 temperaturss m the lupe.-heated steam range u welL One-mattnal eo-eri-e with Kaylo insulation handles applications h.;: often require two thicknesses of different matcrta.s
HIGH COMPRESSIVE STRENGTH, in compress.-e
strength is unusually high for a mineral proauc: 2* such light weight.
HIGH FlEXURAl STRENGTH. Its flexural scrcng'.n
higher thaa the normal requiremeats for hear iai 1tioo of thia typo. Thii strength makes foi easy hi.-rcling aad appiicatioa, aad contributes to long ter-ice wits low maintenance.
NO ADDED UNDER. Kaylo insulation is to inorganic
compound, containing no added binder. Its per formance characteristics, therefore, are not affecrec r . additives, which often reduce insulating - slue. moc.-. effective tempenture range or otherwise iimt: per formance.
EASY TO APPtY. Kaylo Heat Insulating BIocxs .-r
clean-cut and trim. They are easy to At into z i.t
Notice tha clean, straight edges oa these insulated pro. eipuator hopper*. Applicators tod it eaar <* work with ICaylo Heat teselating Bloch became they an so easy to cut aed yet ba*e t high fosnl strength.
On large oe smell equipment. iaside or owe lasulsuag Slock perform* eAcioetly tad with t aimm.-- .r msinientiice. Hers is is being spptiod to ibe *n o( * *
precipitator.
j,
' ry -
i
The Right Material... Expert Application
Pint. Kayto Hut Imitation it proved a taster material-- hydreua calcium uJicato. Ita li*ht weifht. Rienfth. waterinsolubility. low conductivity and wide temperature ran| pvt you extra advantaft* at no xtra coir.
Second. Kaylo diatributors have the technical knowiedje and experience to provide you with a complete injulaunr service. Their trained appheaton are skilled craftsmen no da neat and eiTtaent installation.
To. be sure of fettinf the moat out of your insulatinj doUara for your next job. call the noairoBt Kaylo diambutor. Chancea ere you can find him listed in the yellow pates of your phone book. If not contact ue and we'll five youhia name.
went roe sett too*--"Xrw ,
***/. Ow*. M.irc. 0n Ti SlM
first in calcium silicate
... pioneered by OWENS v^j)> ILLINOIS Glass Company
m*>H oKt teuee i. esie^ane um emcit tnaer* * owcaee woustoe toes * nnuinrwi nmuise* if =-
Ovoe-tnioM GUse 1
HRV-PL-1606
v For tfadii Trom /^J LLi.Cdi.Le e
Nesting Kaylo Heat Insulation Requires Fewer Pieces Per Job
The complete nnji of Kaylo Insulation include* pip* covennf in Simplified Dimenaional Standards for diameter* from tn. to 72 in., curved block from 72 in. to 60 ft. end flit block for surface* of leee curvature whose radii approach infinity. With its wide selection of interchanfeable size* and shape*. Kaylo Insu lation reduces the number of items needed per job ana permits substantial aavinp in warehousinc maintenance stock.
wtm rot rttl loot--'.
*#*** OeP *i?V O'l" b' & C
terO wee^. F---- 1
first in calcium silicatm
...pioneered by OWENS Q 1 L LI N O I S GIosj Company
* .** i *. . *
***! lean f**tet
aj, wa.w^eei Me 4 1>i vflt
Qfu%%a*tQm j**1
Company 4 * <* tM**w-_*
Mm i mi
uti u. inj
HRV-PL-1607
L wl i'iCkL. 1 IIUI!I
o_
Nesting Kaylo Heat Insulation Requires Fewer Pieces Per Job
Tha complata rang* of Kayic Insulation indudaa pipt cov*nnj is Siroplifiad Dimensional Standard* for diASMUrt from H in. to 72 in., curved block from 72 in. to 60 ft. and flat block for rurfacM of taaa curvatur* whose radii approach inAmty. With its wide selection of istarchanfaabl* tu* and shape*. Kaylo InsuLatioo raducae tha number of ittms needed par job and permits substantial tavinp in warehoueinf maintananr* stock.
wtiTT rot rtn loot--
........ wt n-lTI. o r-- i.
first in dbicium silicatm
pion**r* d by OWENS (*) 1 LLINOIS Glass Company
*
**# !**
*
asi4a* * "** * ** 3
exhibit
III
HRV-PL-1609
Sales Agreement
Owens-Illinois Glass company, hereinafter referred to as "3=llern, and Owens-Corning Fiberglas corporation, hereinafter
referred to as "Buyer", have this day agreed as follows:
1. During the term of this Agreement*, Buyer will purchase from Seller and Seller will sell to Buyer, subject to the provisions of this Agreement, the following amounts of Kaylo Heat Insulating Products:
$ 750,000 during the period April 1, 1953 to December 31, 1953# and
$1 ,000,000 during each calendar year subsequent to 1953;
provided, however, that In the event that at any time or times the prices for Kaylo Heat Insulating Products shall be Increased or decreased in accordance with the provisions of paragraph 4 hereof, the amounts hereinabove specified will be increased or decreased In the same proportion as such prices shall have been Increased or decreased, prorated for the portion of the current period unexpired at the date of such price change. On or before the first day of each calendar quarter. Buyer will notify Seller in writing of the total amount of Kaylo Heat Insulating Products vjhich it intends to purchase from Seller during such quarter.
2. As used in this Agreement the terra "Kaylo Heat Insulating Products" means only those heat insulating products listed in Exhibit A, attached hereto and made a part hereof.
3. The prices for Kaylo Heat Insulating products set forth In Exhibit A will remain in effect until October 1, 1953# and thereafter until Increased or decreased in accordance with the provisions of paragraph 4 hereof.
4. Seller may increase or decrease the prices to Buyer for I'aylo Heat Insulating products on October 1, 1953, and on the firs:; day of any subsequent calendar quarter, by giving notice in viritir.y to ?u- er of such increase or decrease at least fifteen (15) days prior thereto, lu-er ma- , _y giving notice in writing to Seller at any time within thirty (30) days after receipt of notice _fror. Seller of a price Increase terminate this Agreement six (5) months after t ie effective dace cf such price Increase.
5. Ail orders for Kaylo Meat Insulating products plated by Buyer and accepted Ly Seller will be at the prices in
HRV-PL-1610
effect at' the time of shipment by Seller and will ce subject to
the conns set forth in Exhibit A and the following terms and
conditions:'
''
(a) Prices shall be P.0.3, plant of manufacture, in the event that Seller prepays the freight on any shipment, Buyer will reimburse Seller the full amount thereof. Title and possession shall pass to Buyer on delivery of product to the carrier consigned to Buyer or Buyer*s' customer.
(o) in the event of a price increase, the Buyer nay, within thirty (30) days after receipt of notice thereof, request price protection cn specific outstanding contracts and outstanding contract proposals. Shipments with protected prices must be made within sixty (60) days of effective date of price increase.
(c) orders and shipping instructions will ce given by Buyer reasonably in advance of desired delivery dates and, subject to the other provisions herein stated. Seller will make shipments as nearly as possible in accordance with such shipping Instructions as shipping facilities and Seller*s scheduling and facilities of manufacture permit. Sailer's failure to meet shipping instructions will not be deemed a breach of this Agreement.
(d) Seller warrants that all Kaylo Heat Insulating products sold to Buyer pursuant to this Agreement will meet Seller's performance specifications in effect at the time of sale. Seller will furnisn Buyer a copy of said performance specifications currently in effect and of each revision thereof.
(e) Buyer shall, within ninety (90) days after shipment of any products covered by this Agreement, give written notice io Seller of any claim for errors, shortages, imperfectior.3, deficiencies or any failure of the products to conform with the term's of this Agreement. Buyer's failure to give such notice within such time or Buyer's failure to give Seller an opportunity to make an adequate Investigation, either by on the spot inspection or by having the products returned to Seller, shall constitute a waiver by Buyer of all claims with respect thereto. Any advice or assistance furnished by
Seller in respect of installation or use of the products are purely gratuitous and without consideration, and Seller shall have no liability by reason there of. Seller shall not be liable for any breach of this Agreement in any amount in excess of the agreement price for the products with respect to which such breach occurs and Seller shall not be liable in any event for special or consequential aama.ves: and ^-r.-sr
- 2-
HRV-PL-1611
will rive notice that Seller's trademark is registered ly ais- plaving with the mark as used the letter "R" enclosed within a circle. Buyer's right to use Seller's trade name and mark shall be limited to the advertisement ar.d sale of products manufactured by Seller and sold to Buyer pursuant to this Agreement and such right shall terminate upon the termination
of this Agreement.
10. unless sooner terminated in accordance with the provisions of paragraphs 4, 11, or 12 hereof, this Agreement shall remain in full force and effect until January 1, 1959. Except as otherwise provided in paragraph 13 hereof, the giving of any notice of termination shall not, prior to the effective date of such termination, relieve Buyer from its obligation to purchase, or relieve Seller from its obligation to sell, the amount of Xaylo Heat insulating products set forth in paragraph 1 here of, and any termination shall be without prejudice to any other remedy or remedies which either party may have against the other for any breach of this Agreement.
11. Either party may at its option terminate this
Agreement effective at the end of any calendar month by giving
notice in writing to the other party at least one (1) year prior
to the effective date of such termination.
*
12. In the event that Seller determines to discontinue the manufacture of Kaylo Heat Insulating Products, Seller- may terminate this Agreement effective at the end of any calendar month by giving notice in writing to Buyer at least six (5) months prior to the effective date of such termination.
13. In the event- that Buyer shall give notice to Seller of termination of this Agreement pursuant to the provisions of paragraph 4 hereof, or in- the event that Seller shall give notice .to Buyer of termination of this Agreement pursuant to the provisions of paragraph 12 hereof. Buyer, at its option, may elect to be relieved of its obligation to purchase, during the six (5) months immediately preceding the effective date of such termination, Kaylo Heat Insulating Products in the amounts prescri`ad in paragraph 1 hereof, by givir... notice cf sue., election within thirty (30) days after notice cs such termination. In the event that Buyer elects, as herein provided, to oc relieved of its o' ligation to purchase the amounts so prescribed. Seller shail .e relieved cf its ojligation t: s;li tne amounts so pre scribed.
Cl
it
<
1
T
f i
h
ff
h
N
14. fhe right of eacn part; to require strict performance of the other party's obligations hersur.ter shall not be affected in an; way by any previous waiver, forbearance or course of dealing.
15. Any civil action, against Seller arising out of this Agreement or oy reason of any sale hereunder, or by reason
of an; federal or state statutory provision relating thereto.
shall include this same limitation upon che amount of Zeller's liabilities in contracts effecting all resales by uyer to third persons and Zuyer shall indemnify and save' Zeller harmless from any liabilities arising from Buyer's failure so to contract in making resales.
(f) All claims made cy 3uyer against Seller in accord ance with subparagraph (e) hereof shall be subject to approval by Seller. In the event that 3uyer disagrees with seller's disposition of any such claim. Buyer may by giving notice in writing to seller within thirty (30) days after receipt of notice.of Seller** disposition of such claim, require the same to be submitted to arbitration in Lucas County, Ohio, in accordance with the Ohio Arbitration Act, 'oy three (3) arbitrators appointed as follows: Seller and Buyer shall each appoint one (1) arbitrator and the two (2) arbitrators thus appointed shall appoint a third arbitrator. In the event that the arbitrators appointed by Seller and Buyer shall be unable within thirty (30) days to agree upon the appointment of the third arbitrator, the Court of Common Pleas of Lucas county, Ohio, may, upon application of either party hereto, appoint the third arbitrator. The decision in writing of a majority of the arbitrators will be final and binding upon both parties.
6. If, by reason of fire, earthquake, flood, explosion, accident, difference with or inability to secure workmen, lack of material, lack of facilities. Act of God or of any public enemy, voluntary or involuntary compliance with any valid or invalid order, regulation, request or recommendation of any government agency or authority, lack of transportation facilities or other cause beyond the control of seller or Buyer, respectively, whether or not of the kind hereinbefore specified. Seller or Buyer shall be unable to perform, or is delayed in the performance of, any obligation under this Agreement, such nonperformance or delay shall be excused.
7. ' In the event that Seller 3hall be unable to fill all orders for Kaylo Heat Insulatin: Products placed both by Buyer anc by other customers of Seller, Seller shall prorate shipments to Zuyer and such other customers on an equitable basis.
8. Orders placed by Zu"-er for Kaylo insulating products not specifically listed and priced in Exhibit A will be subject to approval by Seller in each case ar.d will he subject to suen prices and shipping dates as may be set forth in such approval.
9. All sales and advertisements of Kaylo Heat Insulat ing Products shall be under Seller's trade name and trade mark "Kaylo". in using Seller's trade name and mark. Buyer will indicate that the products sold or advertised are manufactured by Seller and
- 7_
HRV-PL-1613
seal'
comment-id within or:s (1) year from cbe date sued cause
of =;:;sp. arises; otherviise the sar.a shall be barred, notwi-.-.-
star.:e ; any statutory period of limitations to the contrary.
IS. This Agreement is not assignable by Buyer except wit'". - -.e written consent of Seller.
17. The entire agreement of the parties, is contained herein. There is no warranty, agreement, or understanding, express, statutory or implied, either in fact or in law, with reference to or a part of this Agreement, except such as is set forth herein. Except as otherwise provided herein, no change or alteration of this Agreement shall be effective unless the same is in writing
and signed by both parties.
18. This Agreement shall be binding upon the parties, their successors and assigns, and shall be construed in accordance with the laws of the State of Ohio applicable to contracts made and to be performed in the State of Ohio.
IN WITNESS WHEREOF, the parties have caused this Agreement to be executed as of April 1, 1953* this JS xfc day of March, 1953-
-P
HRV-PL-1614
ziMi^rr "a" j:- sales k~zz:z:\
OSENS-ILLINOIS GLASS CC.'PANY
Nominal Pipe Sizes--
Inches
1/2
3/L
1
KAfLO SECTIONAL z17Z INSDLaTICK
Net Billing Prices - F.O.B. Berlin, N.J.
' Tents Let 30 Days Nominal Thickness of Insulation & Prices per Lineal Foot
1" 1-1/2" 2" 2-1/2* 3"
9 .lk2
i .297
e .k85
$ .6k6
.775
.155 .317 517 .679 .873
.175 036 .550 .711 -90k
1-l/k 1-1/2
2
.19k .21k .233
.362 .388 .kl3
.531 .6lk *6k6
7k3 .775 .808
.937 1.00 1.06
2-1/2 3
3-1/2 k
k-l/2 5
.258 .291 .323 .388 *k20 .k52
U52 .k91 .530 .568 .607 .6k6
.679 .7k3 .08 .873 .937 1.00
.873 .969 1.06 1.16 1.26 1.36
1.13 1.23 1.32 l.k2 1.52 1.62
6
.517
.711 1.10
l.kS
1.75
7
X
.775
1.19
1.55
1.S6
8; 9'
X X
.873 .969
1.29 1.L2
1.65 1.81
2.0k 2.20
10
X 1.06 1.55 1.97
X
11 X 1.13 1.65
12 X 1.19
X
X X
X X
-Note:
(1) (2)
(3)
(L) (5)
Prices listed are for single layer only.
Double layer prices are the sum of the prices for the two single layer sizes used. Prices include standard canvas jackets and 2-1/2 aluminum bands per 3 ft. section up to and including 2-1/2" thicknesses. No allowance is made for omission of canvas jackets cr bands. Extra charge for special canvas Jackets. Sctra charge for any canvas jackets on covering over 2-1/2" thickness.
exhibit
or sales agp.ee;:
QtVENS-ILLINOIS CLaSS CCflPANT
Nominal Pipe Gizes-
Ir.z.-.-s
KAILO beveled ug pipe insulation
Net Baling Prices - P.0.3. Berlin. N.J.
Tema -'at 30 Pars Nonlnal Thickness of Insulation k Prices per Lineal
1-1/2"
2" 2-1/2"
3"
10
$1.02
$l.ii8
$1.88 ' $2.25
n
1.00
1.57
1.97
2. Li
12
l.lii
1.66
2.10
2.53
Ik
1.29
1.85
2.35
2.5k
15
1.39
1.9U
2.U7
3.00
16
l.kS
2.0li
2.59
3.11a
17
i.a*
2.13
2.72
3.30
18
1.60
2.22
2.82a
3.L5
19
1.70
2.35
2.97
3.58
20
1.76
2.L7
3.09
3.70
21
1.85
2.56
3.20
3.86
22
1.91
2.66
3.33
lt.01
23
1.97
2.72
2k
2.0L
2.78
26 -*
--
2.19
3.00
3.15 3.55 3.82
ii.17 it. 32 It. 63
27
2.25
3*11
3.95
U.75
28
2.32
3.17
ii.10
1.91
30 32 - 33
3ii
2.L7 2.66 . 2.72 2.81
3.39 }.6k 3.73 3.e6
U.29 U.57 k.69 L.82
5.18 5.61 5.67 5.86
36
2.97
li.OL
5.06
6.1L
9 1 9 1 -- T c l A H H"
Note:
Cl) (2)
Prices listed are for sii^le layer only.
Double laver orlces are `.he ww of t.h -.--^i***
*u
-*
EXHIBIT "A" or S'lrS AlTZr.T.'r;
OTEHS-aLItfOIS glass cc:t>an?
KAILO HEAT IKSULATDB BLOCK Net Billing Prices - F.O.B. Berlin, N.J.
Terms Net 30 Days
ThicknessInches
Prices per Square Foot
1 .173
1-1A 1-1/2
.21? .260
1-3/U 2
.305 3U6
2-lA 2-1/2 2-3A
.392 A33 A78
3 519
HRV-PL 1617
EXHI3IT
C" SAL.-5 AC-Rirrr-'l.'T
OWENS-ILLINOIS OLaSS COiaPANY
KAILO HEAT INSULATION EXTRA CHARGES Additions to Net Billing Prices
% Addition to Billing
Price
Standard Canvas for Sectional Covering Over 2-1/2" Thickness
h.5X
6 oz. Canvas for All Sizes and Thicknesses
9.0
8 02. Canvas for All Sizes and Thicknesses
13*5
Laminated Products
7.5
LCL Orders Special Shapes, Sizes and Thicknesses 'Keathercoating
$2.00 each Quotation Quotation
HRV-PL-1618
AMENDMENT OF SALES AGREEMENT
Owens-Illinois Glass Company and Oweas-Corning Fiberglas Corporation have this day agreed that the Sales Agreement between them relating to Kaylo Heat Insulating Products, executed as of April 1, 1953 on March 20, 1953, shall be amended as follows:
(1) The schedule marked Exhibit A and attached hereto shall be
substituted for the schedule marked Exhibit A attached to said Sales Agree
ment, and all references to Exhibit A in said Sales Agreement shall be deemed
to refer to Exhibit A attached hereto.
*
(2) This amendment shall be effective as of April 1, 1953.
IN WITNESS WHEREOF, the parties have caused this amendment to be executed this /J cC day of April, 1953.
OWENS-CORNING FIBERGLAS CORPORA TIC /* / J
By I j ;
Vice 'President
HRV-PL-1619
E' hibic A OWENS-ILLINOIS GUSS "GLPjUHf
April 13, 1953
Net Billing PricesF.O.B. Berli.-.. M J.Terns ret 30 Pavs . KAYLO SECTIOILVL PIPE INaULATION
Nominal
Pipe Sizes Inches 1/2 3A
1
1-1/L 1-1/2
2 2-1/2
3 3-1/2
U
li-l/2 5 6 7
/ .8
9 10
11
12
Nominal Thickness of Ins ulation & Prices per Lineal Foot
1" 1-1/2" 2" 2-1/2"
3"
S .12:2 .155 .175
$ .297 .317 .336
0 .1:85 .517 .550
0 .61^6 -679 .711
0 .775 .873 .901:
.19U ,2lU
.#2
.383
.581 .611:
71:3 .775
.937 1.00
.233 .258 .291 .323 .388
.1*13 .li52 .L91 .530 .568
.61:6 .679 .71:3
.873
.608 .873 .969 1.06 1.16
1.06 1.13 1.23 1.32
1.12
.1:20
.607
.937
1.26
1.52
.1*52
6U6
1.00
1.35
1.62
.517
.711
1.10 .
l.Ii5
1.75
x
.775
1.19
1.55
1.88
X
.673
1.29
1.65
2.01:
X
.969
1.L2
1.81
2.20
X 1.06 1.55 1.97
X
X 1.13 1.65
X
X
X 1.19
X
X
X
*
COD
CO
O Z 9 T -a d -A H H
Note: (1) (2)
(3)
(1:) (5)
Price3 listed are for single lay? r only. Double layer prices are the sur. o ; 'he prices for the two single
layer sizes used. Prices include standard canvas ia ckets and 2-1/2 aluminum bar.d3 per 3 ft. section up to and including 2-1/2" thicknesses. Ko allovranee
is made for omission of canvas ji ckets or bands,
Extra charge for special canvas j ackets. Extra charge for any canvas jack*'is on covering over 2-1/2" thickness
OiTENS-ILLIUCIS GLASS COilPAlT
April 13, 1953
Net Hilling Prices
F.0, 9. Berlin, N. J.
Terns Net 30 Days
KAYLO TRI-SSGJEI.TAL PE'S INSULATION
Nominal Pipe Sizes-
Inrr.es
6
9
10
Nominal Thickness of Insulation & Prices per Lineal Foot
1-1/2"
2" . 2-1/2"
3"
X
Sectional Pipe Insulation
x
X for These Sizes x
X
X X X 82.36
11
X
X
62.07
2.52
12
X
S1.7U
2.20
2.6$
Hi
61.36 "
1.9U
2.US
2.97
15
1.U5-
2.03
2.58
3.13
16
1.52-
2.13
2.71
3.27
17
1.62-
2.23
2.81*
3Ii6
18
1.68
2.33
2.97
3-62
19
1.99
2.76
3.1i8
L.21
20
2.07
2.90
3.63
U-35
.
21
2.18
3.01
3-77
X
22
2.25
3.12
X
X
23
2.32
X
XX
Note: (1) (2)
(3)
Prices listed are for single layer only. Double layer prices are the sun of the prices for tiro single layer sizes used.
Extra charge for any canvas jackets or bands.
HRV-PL-16 2 X
r PTEBIT A OBESS-ILLINOIS CUSS ^,, ~A' <%|r.f
April 13, 1953
Net Billing ?ri ces
F.O.B . Berlin, N. w *
Terms Net 30 Days
KAYLO BEVELED UG PIPE r::suuTic?i
Noninal Pipe Sizes-
Inches
20
21
Nominal Thickness of Insuiiticn L Prices per Lineal Foot
1-1/2" 2" 2-1/2" 3"
X X Tri-segnental pipe insulation
X
X for these sizes
3.86
22
X
X 3.33
It. 01
23
X
2.72
3.1i5
lt.17
2h
2.0U
2.78
3.5?
It.32
26 27 28 30 .
2.19 2.25 2.32 2.1*7
3.00 3.11 3.17 3.39
3-82 3.95 lt.10 li.29
It.63 It. 75 It. 91 5.18
32
2.66
3.6U
t.57
5-61
33
2.72
3.73
li.69
5.67
3h
2.81
3.86
ii.82
5.86
36
2.97
h.oh
5.06
6. lit
Note: (1) (2)
(3)
'. Prices listed are for single layer only. Double layer prices are the sun of the prices for the tno single layer sizes used. Extra charge for any canvas or bands.
HRV -- PL-- 16 2 2
' GT.'.'EiS-ILLIxiOIS C-L-.5S CCitPANY
April 13, 1553
Net Hilling PricesF.O.D. Berlin. N. J."eras Net 30 Pays
KAYLO fEAT INSULATING BLOCK
Thickness Inches
Prices per Square Foot
1
1-1/2 2
$ .173 .260 .3U6
2-1/2 3
*U33 .51?
Note:
Block in these thicknesses can be furnished in 6", 12" and IS" widths.
Page U
HRV-PL-1623
aVENS-ILLIJIGIS CLASS CCl^AIJf
April 3J, 1?$3
r;et Dilline Prices
r.O.B. Berlin, IT. J.
"err.s f*st 30 Days
KATLO HEAT IlgULAiIOtf SX??A C.:L;?.GSS
Standard Canvas for Sectional Covering Over 2-1/2" Thictaess
% Addition to Billing
Price
h.5%
6 oz. Canvas for All Sizes and Thicknesses
9.0
8 oz. Canvas for All Sizes and Thicknesses
13.5
lamination of Sectional Pipe Covering to Provide Greater Thicknesses.
(This addition to sin of the prices of the ttro thicknesses used)
7.5
All orders for less than carload quantity Special Shapes, Sizes and Thicknesses Ueathercoating
.
$2.00 each Quotation Quotation
Page 5
HRV-PL-16 2 4
Memorandum of Agreement
Owens-Illinois Glass Company, hereinafter referred to as "Seller", and Owens-Corning Flberglas Corporation, hereinafter re ferred to aa "Buyer", have this day agreed as follows:
1. During the term of this Agreement, Buyer will purchase from Seller and Seller will sell to Buyer, in accordance with the terms and provisions of paragraphs 5 end 9 and Exhibit A of the Sales Agreemen this day executed by the parties, a copy of which is attached hereto as Exhibit I and made a part hereof, and subject to the provisions of this Agreement, the following amounts of Kaylo Heat Insulating Products:
$1,800,000
during the period April 1, 1953 to December 31, 1953 and
$2,400,000
during each calendar year subsequent to 1953;
provided, however, that in the event that at any time or times the prices for Kaylo Keat Insulating Products shall be increased or de creased in accordance with the provisions of paragraph 6 hereof, the amounts hereinabove specified will be increased or decreased in the same proportion as such prices shall have been increased or decreased, prorated for the portion of the current period unexpired at the date of such price change. On or before the first day of each calendar quarter. Buyer will notify Seller in writing of the total amount of Kaylo Keat Insulating Products which it Intends to purchase from Seller during such quarter.
2. The amounts of Kaylo Heat Insulating Products specified In paragraph 1 hereof are in addition to the amounts specified In para graph 1 of the. Sales Agreement of which Exhibit I is a copy.
3. Seller reserves the right to sell Kaylo Keat Insulating Products to other purchasers; and the amount of Kaylo Keat Insulating
Products sold' by Seller to such other purchasers during any calendar year may, at option of Seller, be credited, in whole or In part,
against Seller's obligation to sell during chat period the amount specified In paragraph 1 hereof.
4. As used in this Agreement the terra "Kaylo Heat Insulating
Products" means only those heat insulating products listed in Exhibit
A of Exhibit I hereto.
*
HRV-PL-1625
5. The prices, for Kaylo Heat Insulating Products set forth In Exhibit A of Exhibit i will remain in effect until October 1, 1953, and thereafter until Increased or decreased in accordance with the provisions of paragraph 6 hereof.
6. Seller may increase or decrease the prices to Buyer for Kaylo Keat Insulating Products on October 1, 1953* and on the first day of any subsequent calendar quarter, by giving notice in writing to Buyer of such increase or decrease at least fifteen (15) days prior thereto. Buyer may, by giving notice in writing to Seller at any time within thirty (30) days after receipt of notice from Seller of a price Increase terminate this Agreement six (6) months after the ef fective date of such price increase.
7. If, by reason of fire, earthquake, flood, explosion, ac cident, difference with or inability to secure workmen, lack of material, lack of facilities. Act of God or of any public enemy, voluntary or In voluntary compliance with any valid or invalid order, regulation, request or recommendation of any government agency or authority, lack of trans portation facilities or other cause beyond the control of Seller or Buyer, respectively, whether or not of the kind hereinbefore specified. Seller or Buyer shall be unable to perform, or is delayed in the perform ance of, any obligation under this Agreement, such nonperformance or delay shall be excused.
8. Buyer will offer Its standard form of distributorapplicator contract to all of Seller's existing distributor-applicators. Where such a standard form of contract Is accepted by any such distributor applicator. Buyer will service all orders, unfilled at the time of such acceptance, placed with Seller by such distributor-applicator, and will, within thirty C30} days after receipt of notice from Seller of shipxenf on .any. such order, remit to Seller one hundred seven and one-half per cent (107-1/2J5) of the purchase price set forth in Exhibit A of Exhibit I hereto, together with the amount of freight, if any, pre paid by Seller on said shipments.
9. Unless sooner terminated in accordance with the provisions of paragraphs 6,. 10, 11 or 13 hereof, this Agreement shall remain in full force and effect until January 1, 1959 Except as otherwise pro vided in paragraph 12 hereof,-the giving of any notice of termination shall not, prior to the effective date of such termination, relieve Buyer from its obligation to purchase, or relieve Seller from its ob ligation to sell, the amount of Kaylo Heat Insulating Products set forth, in paragraph 1 hereof, and any termination shall be without prejudice to any other remedy or remedies which either party may have against the other for any breach of this Agreement.
HRV-PL-1626
10; Either party may at its option terminate this Agreement effective at the end of any calendar month by giving notice in writing to the other party at least one (1) year prior to the- effective date of ouch termination.
11. In the event that Seller determines to discontinue the manufacture of Kaylo Heat Insulating Products, Seller may terminate this Agreement effective at the end of any calendar month' by giving notice in writing to Buyer at least six (6) months prior to the effective date of such termination.
12. In the event that Buyer shall give notice to Seller of termination of this Agreement pursuant to the provisions of paragraph 6 hereof, or in the event that Seller shall give notice to Buyer of termin ation of this Agreement pursuant to the provisions of paragraph 11 hereof Buyer, at its option, may elect to be relieved of its obligation to pur chase, during the six (6) months immediately preceding the effective date of such termination, Kaylo Heat Insulating Products in the amounts pre scribed in paragraph 1 hereof, by giving notice of such election within, thirty (30) days after notice of such termination. In the event that Buyer elects, as herein provided, to be relieved of its obligation to purchase the amounts so prescribed. Seller shall be relieved of its obligation to sell the amounts so prescribed.
13. the event that the Sales Agreement, copy of which i3 attached hereto as Exhibit I, is terminated by either party thereto, this Agreement shall automatically be terminated effective the sane date.
lA. The right of each party to require strict performance of the other party's obligations hereunder shall not be affected in any way by any previous waiver, forbearance or course of dealing.
15* Any civil action against Seller arising out of this Agree ment or by reason of any sale hereunder, or by reason of any federal or state statutory provision relating thereto, shall be commenced within one (1) year from the date such cause of action arises; otherwise the -ame shall be 'barred, notwithstanding any statutory period of limitations to the contrary.
- l6. This contract is not assignable by Buyer except vxith the written consent of Seller.
3 HRV--PL-1627
17. Che entire agreement of the parties Is cor.taintd nerein. "here lu r.o warranty, agreement, or understanding, express, statutory or lEtlii-d, either in fact or in law, with reference to or a part of" this Agreement, except such as is set forth herein. Except as otherwise provided nerein, no change or alteration of this Agreement snail be effective unless the same is in writing and signed by both parties.
18. This Agreement shall be binding upon-the parties, their successors and assigns, and shall be construed in accordance with the laws of the State of Ohio applicable to contracts made and to be per formed in the State of Ohio.
IN WITNESS WHEREOF, the parties have caused this Memorandum of Agreement to be executed as of April 1, 1953* this Jt.cC day of March, 1953-
HRV--PL--1628
AMENDMENT OF MEMORANDUM . OF AGREEMENT
Owens Illinois Glass Company and Owe ns Corning Fiberglas Corporation have this day agreed that the Memorandum of Agreement between them relating to Kaylo Heat Insulating Products, executed as of April 1, 1953 on March 20, 1953, shall be amended as follows:
(1) The schedule marked Exhibit A and attached hereto shall be substituted for the schedule identified as Exhibit A of Exhibit 1 attached to 3aid Memorandum of Agreement, and all references to Exhibit A of Exhibit 1 in said Memorandum of Agreement shall be deemed to refer to Exhibit A attached hereto.
(2) This amendment shall be effective as of April I, 1953. IN WITNESS WHEREOF, the parties have caused this amendment to be executed this t) **C day of April, 1953.
HRV-PL-1629
AHSNE-ELT OF MEMORANDUM OF AGREEMENT
Ovens-Ulinals Glass Company and Owens-Coming Fiberglas Corparaticn bars this day agreed that the Memorandum of Agreement between them relating to Kaylo Heat Insulating Products, executed as of April 1, 1953 on March 20, 1953> shall be acsaded as follows i
(1) The schedule marked Exhibit A and attached hereto shall be substituted for the schedule Identified as Exhibit A of Exhibit I attached to said Memorandum of Agreement, and all references to Exhibit A of Exhibit I in said Memorandum of Agreement shall be deemed to refer to Exhibit A attached hereto,
(2) This amendment shall be effective as of August 1, 195h*
HI WITNESS WHEREOF, the parties hare caused this amendment to be executed this 30th day of July, 195U*
OWENS-ILLINOIS GLASS CQHPASI
Attest:
*/
' /r^ibHr._ /
Asst. Secretary
//
By President
OWES-COSIISO FIEEPJGLAS C02P0RMI0JT
HRV-PL-1630
August 1, 195^
\ Exhibit A
OWENS-ILLINOIS
Net pilling PricesF.O.B. Berlin, N. J.Terns Net 30 Day? KATLO SECTIONAL PIPE INSULATION - NO BANDS
Ncsiinal Pipe SizesInches
Nominal Thickness of Insulation 4 Prices per Lineal Foot
1"
l-l/2" .
2"
2-1/2'*
3"
1/2
0 .11j9
$ .312
$ .509
0 .679
$ .818
3A
.163 .33 k
.5iU '
.711*
.920
1
.IflU
.353 .579
.71*8
.951
i-iA
.2 Ok
.361
.611
.781
.98U
1-1/2
.225 .Lod
.6h$
.818
1.05
2
.2u$ .1*31*
.679
.81*8
1.11
2-1/2
.271
.1*75
.711*
.920
1.19
3
.306
.516
.782
1.02
1.30
3-1/2
,3ho .557
.81*3
1.11
1.39
1;
.1*08
.597
.920
1.22
1.1*9
U-l/2
M2 .636
.981*
1.32
1.60
5
.1*75
.679
1.05
1.1*3
1.71
6
.51*1*
.71*8 .
1.16
1.52
1.81*
7
.818
1.26
1.63
1.97
8
.920
1.35
1.7U
2.13
9.
1.20
1.L.9
1.90
2.31
10
1.17
1.72
2.18
11
1.25
1.33
12 1.32
Note: (1) Prices listed are for single layer or.lv.
(2) Double layer prices are the sun of the prices for the two single { layer sites used.
(3) Prices include standard canvas Jackets up to and including 2-1/2" thicknesses. Ho allowance is nade fcr emission, of canvas jackets.
(M Extra charge for special canvas jackets. (5) Extra charge for any canvas jackets cn covering over 2-l/2n thickness.
Exhibit A (WSKS-ILLItfOIS
AugttSt 1, 195^
Net Billing Prices
F.O.B. Berlin, N. J. KATLO SECTIONAL PIFE r?.(3DIATI0N - ^TH BAUDS
Kcri.-al Pipe SizesInchss
Nominal Thickness of Insulation St Prices per Lineal Foot
1" 1-1/2"
2"
2-1/2"
3"
1/2
C .150
C .315
3 .512;
$-.686
$ .826
3/h
.161*
,337
.51*9
.721
.929
1
.166
.356
.585
.755
.960
1-iA
,206
.385
.617
.789
.992;
1-1/2
.227
M2
.652
.826
1.06
2
.21x3
M8
.686
.8*7
1.12
2-1/2
.271:
.2*60
.721
.929
1.20
3
.309
.521
.790
1.03
1.31
3-1/2
.313
.562
.857
1.12
l.liO
lx
,l2
.603
.929
1.23
1.50
1-1/2
M7
.61*2*
.991;
1.33
1.6l
5
.it 80
.686
1.06
1.2*2;
1.73
6
.Sh9
.755
1.17
1.53
1.86
7
a. -
9
.826 . .929 1.03
1.27 1.37 1.50
1*62; 1.76 1.92
1.99 2.15 2.33
10
1.18
1.73
2.2Q
11
1.26
1.85
12 Note:
1.37
(1) Prices listed are for single layer only.
(2) Double layer prices are the sun of the prices for the two single
layer sizes used.
(3) Prices include standard canvas jackets up to and including 2-1/2"
thickness. Ho allcr./ance is made for cnission of canvas jackets,
(h) Extra charge for special canvas jackets,
(5) Extra charge for any canvas jackets on covering over 2--1/2" thickness.
(6) Prices include 2-1/2" aluminum bands per 3 it, section.
2 E 9 T --r id --W dW
Exhibit A
August 1, 19 5 It
OWENS-ILLINOIS
Net Billing Prices
.
F. O.B. Berlin, N.J.
Terns Net 30 Days
KAYLO TRI-SEGMENTAL PIPE INSULATION
Nominal Pipe SizesInches
Nominal Thickness of Insulat;ic.n L Prices per Lineal Foot
1-1/2"
2"
2-1/2" -
3"
10 $ 2.61
11
$ 2.29
2.79
12
$ 1.93
2.1:3
2.91:
1U
$ 1.51
2.15
2.71
3.28
15
1.60
2.25
2.85
3.&
'
16
1.68
2.36
3.00
3.6k
17
1.79
2.1:7
3.U*
3.83
ia
1.86
2.58
3.28
I:.01
19
2.00
2.77
3.1:9
20
2.08
2.91
3.61:
21
2.19
3.02
3.78
j22
2.26
3.13
3.93
23.
2.33
j 3-20
li.07
2ti - 2.1:0 3.27 lul8
Ii.22 li.37
J U.51t Quad-Seg
li.72 1:.90 5.09
Note:
Cl) Prices listed are for single layer only. (2) Double layer prices are the sum of the prices for t'-ao single
layer sizes used. . (3) Extra charge for any canvas jackets cr bands.
HRV-PL-1633
Net rilling Prices
Nominal Tube SizesInches
3/3 1/2 5/3
3/U 1 1-1/li 1-1/2 2 2-1/2
3
Actual Tube 0. D.
.500
.625 .750
.575 1.125 1.375 1.625 2.125
2.625 3.125
Exhibit A
August 1, 1954
OWENS-ILLINOIS* 1 2 3 * 5
P.0.3. Berlin, N.J.
Terms Net
KATLO TUBS INSULATION - NO BANDS
Nominal Thickness of Insulation Ac Prices ; Lineal Foot
1" 1-1/2"
$ .lit?
$ .312
.Ill9
.312
.163
33 It
.163 .I31i .204
.33lt .3 53 .331
.225
*408
*21*5
.434
.271
*475
.306
.516
Hate:
.
(1) Prices listed are for single layer only.
(2) Double, layer prices are the sun of the prices for the two single
layer sizes used.
(3) Prices include standard canvas jackets. No allowance is mad for
emission of canvas Jackets.
(Ii) Extra.charge for special canvas jackets.
(5) Ths O.D.'s of all tube insulation ccrtforr. to pipe insulation
simplified dimensional standards. Use nesting pipe insulation
for outer layer if greater thickness is required. V.Tten double
layer tube insulation is required, use pipe insulation for outer
layer.
HBV--PL--1634
August Ir 195k
. Exhibit A
c7^Effs-iun;oi3
Hat Billing PricesP.O.B.- Berlin, N.J.Terms Net 30 Days
KATLO TUBE INSULATION - WITH BANDS
Nominal Tube SizesInches
Actual
Nominal Thickness of Insulation & Prices per
Tube
__________________ Lineal Foot_______ ___________
0. D.* 1 2 * * 5
3/3 .500
$ .150
$ .315
1/2 .625
.150
-315
5/8 .750
JA .875
.161* 161*
-337 337
1
1-iA
1.125 1.375
.166 .206
.356 085
1-1/2
1.625
.277
-&12
2 2.125
.21*6
.1*33
2-1/2
2.625
.271*
.1*80
3 3.125
.30?
021
Note:
,
(1) Prices listed are for single layer only,
(2) Double layer prices are the sua of the prices for the two single
layer sizes' used.
O) Prices include standard canvas jackets ar.d 2-1/2 aluminum. bands
per 3 ft, section. No allowance is Bade for omission of canvas
jackets.
(It) Extra charge for special canvas jackets.
(5) The O.D.'s of all tubs insulation conform to pipe insulation
simplified dimensional standards. Use nesting pip* insulation
for outer layer If greater thickness is required. Hhen double
layer tube insulation is required, use pipe insulation for cuter
layer.
HRV--PL-1635
August 1, 1
Exhibit A
OWESS-ILLIKOIS
Net rilling Prices_________
F.O.B. Berlin, N.J.Terms Nat 30 Days
Nominal Pipe SizesInches
18
1?
20
21
22
KATLO BEVELED LAG PIPS INSULATIOM
Nominal Thickness of Insulati on tt Prices per Lineal
1-1/2"
2"
2-1/2"
3"
$ 1.68
$ 2.32
* 2.97
$ 3.62
1.77
2.2*5
3.09
3.71*
1.81;
2.58
3.23
3.88
1.91*
2.67
3.36
I*.03
2.00
2.78
3.1*8
2* .19
23
2.07
2.81*
3.61
2* .36
21*
2.13
2.91 .
3.71
lt.52
26
2.29
3.13
3.99
It.81*
27
2.36
3.26
1*.13
I*.96
28 30 32 ' 33 3L 36
2,1*3 2.58 2.78 2.81* 2.9U 3.10
3.32 3.51* 3.81 3.90 lx-03 It. 22
1*.29 I*.I*8 I*.78 l*.90 5.01* 5.29
5.13 ' 5.la
5.87 5.93 6.13 6.L2
Note:
(1) Prices listed are for single layer only. (2) Double layer prices are the sun of the prices for the two single
layer sizes used. (3) Extra charge for any canvas or bands.
HRV-PL-1636
August 1, 1951* . Exhibit A
OWENS-ILLINOIS
Net Billing PricesF.O.B. Berlin, N.J.Terns Net 30 Day?
RATIO HEAT INSULATING BLOCK
ThicknessInches
1 1-1/2 2 2-1/2
3
Prices per Square Foot
$ .182
.273
.363 hSk .5UU
Note:
"
Block in these thicknesses can be furnished in. 6", 12" and 18" widths.
HBV--PL-1637
Xupist 1, 195^ Exhibit A OHEKS-ILLIiJOIS Wet Billing PricesP.O.B. Berlin, H.J.Terms Net 30 Days
Addition to Billing Price
Standard Canvas for Sectional Covering Over 2-1/2* Thickness 7.02
Standard Canvas far Tri-Sag and Quad-Seg Insulation (not attached)
7.02
6 ot. Canvas for All Sizes and Thicknesses
8.02
6 oz. Canvas for All Sizes and Thicknesses
10.52
Lamination of Sectional Pipe Covering to Provide Greater Thicknesses. (This addition to sum of the prices of the two thicknesses
used.)
7.52
18" Length Block
% .01 per sq. ft.
Special Shapes, Sizes and Thicknesses
Quotation
HRV-PL-1638
Owens-Illinois
CENERaL OITICES 0 TOLEDO 1, OHIO
February 17, 1956
Hr* J* Marshall Bril*7, 7ice President Owena-Coming Fiberglaa Corporation National Bank Ball ding
Toledo, Ohio
-.
Dear Marshall*
This tdll confirm our telephone conversation and eerre as Tonal notice that effactive loril 1, 1956, our prices to your coopany Tor Saylo heat insulating pro* ducts sill be revised as Indicated in the enclosed schedules narked Exhibit *A."
In connection with this increase, you hare requested price protection in the following situations*
1* All distributor saterial orders received prior to February 22, 1}$6, provided shipment is nade before March 22, 1556, be priced at the old prices*
2. Crders Alrea<r Entered - Orders entered prior to February 22, 19io, covering oona Tide contract Jobs to receive price protection on ell naterials shipped prior to August 22, 1956*
Orders to be entered against bids or contract pro-- potals~ace orlor to February 22,' 1j5o - these orders to be.entered .not later tnaa March 22, 1^56* Katerial against these orders shipping prior to August 22, 1956, to receive price protection*
It is cur understanding that the reason Tor your re quest arises out of your bavins extended correspondin' price pro toe-ion to those of your customers in the situa
tions above described.
As I have already explainad, such price protection yoes beyond our contractual obligation and ctrtviply uill affect cur revenue in connection vith our price increase* We rsalios.
,,
^ '
HRV-PL-1639
OWEVS.rU.lNO 15
; r. J* Marshall Briley
? K #2
"jarva117 17, 1956
hcwtTar, tint there is a real busiaeaa nacassity for jour
^ing such coKiitarots and c nUling to do our part la
insisting 70a to carry than out*
feel, however, that
la return for our agreeing. to 7cur requeet, that you should
oniva the provision la our contract limiting our rigjit to
oaka tha pretest priea increase at tha bayinning of a
calendar quarter, whieh, in this case, would ba April 1,
and agree that it nay ba effective aa of February 22, 1956,
uhloh la tha data frees Wiloh you raquast priea protacticM*
If you ara Killing to accept oar priea increase ef fective February 22, 1956, va, in tun, will grant you tha priea protection aa requested by you aid deeerlbad herein*
If tha foregoing arrangement is satisfactory to you, etll you plaaaa affix your signature in tha apace provided below and return a copy to us for our files*
eje
leea?tadi criS2S*<xit::c fishc-las coHx^-Ticy
HRV-PL--1640
Owens-Illinois
CZNXXAL Oinctl (J) TOLEDO L OHIO
ir. J. Marshall Brtl*7 Vic# Prooidaot CvmwCoraifl^ Fiboralaj Corpcrati* National Ldk Stilling lolado, CMo 5*r ,ir Lriluyt
V>* bar# rodocad our nricaa oa Kaylo oroducts to tho adjuataunt n*da by your arsaoixatioa for
j our LCL prlcM on pin# insulation* Attached is tba .icv pile# list published *a a raauit oi this chan^a. ihaaa oriccs vill bo uaad iXoetiv vith asiprunts iraa .May 1* 1^56, sod our billing Tor Xhm mats of ^
..*111 to 1sj'vati accordingly*
Additional cool*a oi this list ar* also bciaj isruardad to ysur sales and service ouraonnol ho ro rJXactad by tdia chan-,a*
lour* truly.
. i ear.**-#
HRV--PL-
Nat Billing Price F.O.B* Berlin, N. J.
thicknessInches 1
1-1/2 2 2-1/2
3
'
Bchibit A WENS-ILLliJUB
JUna 1, 1956 Terw Net 30 Days
KATLO HEAT XN5ULATIN0 BLOCK
36 Inch Lengths Prices ner Souare 1
* .19It .292 .389 .1*86 .583
18 Inch Lengtha
$ .20ti
1-1/2
.302
.399
2-1/2
.
.1*96
___ i_______ :_____ ____ :__________________________________ .593 Note t
Block in these thicknesses can be furnished in 6", 12**
aid 23" widths.
(21)
HRV-PL-16 4 2
Exhibit A
OWENS-ILLINOIS
Net-Billing Price* F.O.B. Berlin, N. J.
1 19 6 TeriB3 Nt 30 Days
KAILO 20 SECTIONAL PIPE INSULATION With Regular Cmu - 1* through 2-1/2" Thicknesses
No Canrae -3* thickness No Banda
Nominal Pipe SiieaInchea
Thickness of Insulation St Prices Par Lineal Foot
T3727 "
IE
2-r7T"~
1/2
$ .177
$ .370
% .603
I .3 Cl*
* .965
3A
.193
39U
.61*3
.81*1*
1.09
1
.217
.1*13
.683
881*
1.13
1-1A
.21*1
.1*50
.721*
.925
1.17
1-1/2
2
2-1/2
.265 .289 .322
.1*62 .515 .563
.761*
.SOU
.81*1*
.965 1.01 1.09
1.25 1.33 1.1*1
3 3-14
.
.362
.1*02
.611 .659
.925
l.CC.
1.21 1.33
1.53 1.65
U
.1*82
.708
1.09
1.1*5
1.77
U-1/2
.523
.756
1.17
1.57
1.89
5
.563
J&Ok
1.25
1.69
2.01
6
61*3
.88U
1.37
U1
2.17
7
z
.965
1.L9
1.93
2.33
8
X 1.09
1.61
2.05
2.53
9
X 1.21
1.7?
2.25
2.73
10
X 1.33
1.93
2.1*5
u
X 1.1*1
2.05
x
12__
Note 1 (1) (2)
(3)
X 1.1*9
x
X
Prices listed are for single layer only. Double layer prices are the sum of the prices for the two
single layer sizes used. No allowance is made for the emission cf canvas Jackets.
x
(22)
Exhibit A
0WEI5 -ILLINOIS
Nat Billing Prices F.O.B. Berlin, N. J.
KATLO 20 THI-SBOMDfTA^ PIPE INSULATION Segular Canvas - No Bands
May 1, 1956 Term* Nat 30 Days
Ncoinal Pip* SiresInches
10 *U
12
Hi
15 16
17
IB
19 20 21 22
23 2U '
e
Ncainal Thickness of Insulation & Prices Per Line si
1-1/2*
2*
2-1/2*
*3"
XX
X $ 3.11
X
X
$ 2.73
3.32
X *2.30
2.90
3.1i9
$ 1.79 2.56 * 3.2li
3.92
1.92 2.66
3Jtf. * U.13
2.00
2.81.
3.58
U.35
2.1$
2.9U
3.75
U.56
2.22
3.07
3.92
U.77,
2.39
3.31
U.18
5.05
2.18 3.L8
U.35
5.22
2.61
3.61 *
U.52
5.U2 Oiad-Seg
2.70
3.7U
li.66
5.611
2.78 3.81.
lu86
5.85
2.86 3.90
U.99
6.07
See footnotes on Page 36, Exhibit A.
f
07)
t
HRV -- PL* 1 e 4 4
Exhibit A OVEfS-ILLINOIS
Net .Billing Pric* F.Q.B. Berlin, If* J.
May 1, 1956 Tana* Nat 30 Day*
EAILO 20 TUBE INSOLATION 8 os. Canva* and Band*
Nominal Tub* SisaInch**
3/5
1/2
Actual Tub*
0.0.
*5oo
.625
Knorin*1 Thiclmaaa of Insulation & Price* Per Lineal Foot
p : l-i/?*------------
% .198
.103
.198 .103
5/s
.750
.
.216
.liltO
3A .875
.216
ItlxO
1 1.125
,2ii2
.1*67
1-1/U
1.375
.269
.503
1-1/2
1.625
.296
.539
m
(M
.
2 2.125
.575
2-1/2
2.625
.359
.629
a__________________ 3.125
.liOit
Saa footnote on Page 31, Exhibit A.
.682
(35)
HRV-PL-1645
fichibit A
CWOE-ILLINOIS
Net Billing Price* F0 9* ctrliA| N*' J*
My 1, 1956 Terns Net 30 Days
IATL0 20 TUBE INSULATION 6 os. Cenrs* tnd Bands
Nominal Tub* SireInches
Actual
Tub* O.D.
No*inel Thldm*** at Dwulation, & Prices Per
Lineal foot
----- Z*
: 1-1/2 *
3/8 .500
* .191 .
8 .Loo
1/2 .625 .191 Loo
5/8 .750 .209 .L26
3A .875 .209 .1x26
1 1.125 .235 .L52
1-1/L
1.375
.261
.L87
t-
CO
.
1-1/2
1.625
.521
2 2.125 .313 *556
2-1/2
2.625
.3LB
6C6
1__________________ 3.125
_______________
.660
Sm footnotes on Psg* 31, Exhibit A
(33)
HKV-PL-1646
Exhibit A
OVENS -ILLINOIS
Net Billing Pries* F.O.B. Berlin, If.. J.
KAILO 20 TUBE INSULATION 6 os. Canvas - No Banda
Kay 1, 1956 Tens Net 30 Days
Nominal tubs Si*#Indies
Actual
Tub* O.D.
Nominal Thickness of Insulatic. A Prices Per
Lineal Poot
1* * 1-1/2*----------
3/6 .5oo
t .190
$ .397
1/2 .625 . .190
.397
5/8 .750
.207
Ii22
3A .875
.207
.122
CM
1 li!25
*hh3
1-1/U
1.375
.259
.L63
1-1/2
1.625
28U
.517
2 2.125 .310 .552
2-1/2
2.625
3li5
.603
3 3.125
.388
.655
See footnotes on Page 30, Exhibit A.
.
(32)
HRV--PL--164V
Exhibit A
OWENS-ILLINOIS
Net ..Billing Prices F.O.B. Berlin, N., J.
KiXLO 20 TUBS INSOLATION Regular Canvas tnd Binds
M*y l, 1556 Terms Net 30 Days
Nominal Tube SizeInches
Actual Tube
O.D.
Nominal Thickness of Insulation & Prices Per
Lineal Foot
------- ---------------------------
7 1-1/2* .
3/8 .500
1/2 .625 S/8 .750
.178 .178 .155
t .373 .373 .397
3A
1
i-1/U
1-1/2 2
.875 1.125 1.375 1.625 2.125
.155 .215 .210 .268 .292
.397 ,li22
.1tSk
.1*87 .519
2-1/2
2.625
.32U
.566
1_________________ 3.125 __________________ -365 _____________
Not# i
.616
(1) Prices listed are for single layer only.
(2) Double layer prices an the sub of the prices far the two single
layer sizes used.
(3) No allovalce is made for emission of esnras Jackets.
(U) The O.D.'s of all tube insulation conform to pipe Insulation
simplified dimensional standards.' Use nesting pipe insulation
fck outer layer if greater thickness is required* Wien double
layer tube insulation is required use pipe insulation for
outer layer,
(5) Prices include 2-1/2 aluminum bands per 3 foot section*
(31)
HRV-PL-1648
Sxhlhit A
Net billing Prices F.Q.B. Berlin, N. J.
CW2JB-ILLINOIS
Kay l, 1956
Tonne Net 30 Day*
KAILO 20 THI-SBQH3TEAL PIPS INSULATION No Canvas - No Banda
Nominal Pipe SizesJnchea
10
Nominal Thickness of ^isolation & Prices Per Lineal Foot
1-1/2
2*
2-1/2"
3. . .
XX
X $ 2.93
U
X
X
$ 2.57
3.1U
12
X $ 2.17
2.73
3.30
Hi
$ 1.69
2.U
3.06
3.70
15
i.ai
2.53
3.22
3.90
16
1.89
2.65
3.38
iulO
17
2.01
2.77
3.5U
U.30
16
2.09
2.89
3.70
U.50
19
2.2lt
3.10
3.92
U.73
20
2.33
3.26
li.08
U.90
21
2.1i5
3.39
li.2ii
5.10 Cuad-Seg.
22
2.53
3.51
ii. la
5.30
23
2.61
3.59
U.57
5.51
2U
Notet (1) (2)
(3)
2.69
3-67________ li.69
5.71
Prices listed are for single layer only, Double layer prices are the sun of the prices for the two single layer sizes used. Extra charge for bands.
(36)
HRV-PL-1649
Exhibit A
OWEJG- ILLINOIS
Net "Billing Price* F.Q.B. Berlin, N.- J.
May 1, 1956 Terns Net 30 Days
piLO 20 TUBE INSULATION 8 os. Canras - No Benda
Ncednal
Tube Site* Inches
Actual
Tabs ' 0.0.
Nosinal Thicbiees of Insolation & Prices Per
Lineal Poot
-
------------ ~------- -
1-1/2**
3/8 5oo
$ .196
$ .klO
&
vn
1/2
.196
klO
5/B .750
.au . .It37
3A .875
.21k .k3?
1 1.125
,2kl 163
l-l/k
1.375
.267 .159
1-1/2
1.625
29U .535
2 2.125
.321 .570
2-1/2 '
2.625
.356 .62lt
l________ -- 3.125
.kOl
See footnotes on Page 30, Miibit A.
' .677
(31)
HRV-PL--1650
Exhibit A
owd;s-Illinois
Net Billing Prices P.O.B. Berlin, N. J.
JCATLO 20 TRI-SSOMEOTAL PIPS ISSUULTION 6 o*. Canvas - Mo Bends
Ky 1, 1956 Terms Set 30 Days
Nosdnal Pipe SixesIndies
10
Nominal thickness of Emulation & Prices Per Lineal Poot
1-1/2*
2*
2-1/2*
TM---------------------------
XX
X $ 3.15
11
X
X
$ 2.76
3.36
12
X $ 2.33
2.93
3.53
lit
$ 1*81
2.59
3.28
3.97
15
1.9U
2.72
3.1*5
lul&
16
2.03
2.81a
3.62
k.iiO
17
2.16
2.97
3.79
It.6l
18
2.2lt
3.10
3.97
it^3
19
2.112
3.35
U.23
5.11
20
2.51
3.52
u.ic ?-29
21
2.6U
3.66
it. 58
5.5l Qoad-Seg.
J22
2.73
3.79
it.76
5.73
23
2.82
3.88 '
L.93
5.95
2h '
- 2.91
3.96
5.0?
6.17
See footnotes on Pigs 36, Exhibit A.
(38)
HRV -- PL--16 5 1
Exhibit A
OWENS-ILLINOIS
Net Billing Price# F.O.8. Berlin, N- J.
EAUO 20 TUBS mStAXICN iiegular Canvae - Ho Bands
May 1, 1956 Terms Net 30 Days
Nominal Tube SixesInches
Actual
Tube O.D.
Nominal Biickneaa of Insulation. & Prices Par
Lineal Foot
" 1*
.. ............... - 1-1/2*
3/8
.500
.177
1/2 .625
.177
5/3 .750
.153
$ .370 .370 .351;
3A 1 l-i/U
.875 1.125 1.375
.153 .217 .2til
.391* 108 .i0
1-1/2
1.625
.265
.1*82
2 2.125
.285
.515
2-1/2
2.625
.322
.563
3 Note*
(1) (2)
(3) (L)
_____ ________________
.362
611
Prices listed art for single layer only*
Double layer prices are tbe sue of the prlees for the two single layer sixes used. No allowance Is made fer amissian of canvas Jackets. The O.D.'s of all tube Insulation coafona to pipe insulation 3~japl 1 fled, dimensional standards* Use nesting pipe insulation far .outer layer la greater thickness is required* Vhen doable layer tube insulation la required, use pipe insulation far outer layer*
(30)
HR V -- PL. -- 16 5 2
Exhibit A
aois-iLLZNors
N*t BllIin; Pric*#
P.Q.B.
N. J.
Ncadoal Pip# Sis**Inch**
1/2
3A 1
1-1/U
1-1/2
2
uno 20 srcncHAi pips dtsulaiiok With 8 os* Canraa 2nd Bands
ifoadjul Tbietcn*## of Insulation
1* 1-1/2*
2*
$ *196
* .103
% .67U
.236
UliO
.718
.2h2
M
.763
.269
.503
.806
.296
.539
.8S3
.323
.575
.896
2-1/2 3 3-1/2 U k-1/2
,
.359 .bolt Ut9 .539 .58 U
.629 .682 .736 .790 .8liit
.9U3 1.03 1.12 1.21 1.30
5 6 7 8 9 10 n 12 `
.629
.898
.718
.988
* X 1.08 X 1.21
X 1.35
X 1.L8
X 1.57
X 1.66
S* footnot** on Pag* 23 , Exhibit A.
1.39 1.53 1.66 1.80 1.95 2.16 2.29
X
~pL-1633
(29)
Exhibit A
OWENS .ILLINOIS
M*t Billing Fric 7.0.3. Berlin# K., J.
WHOSO S8CTXOUI PIPS INStJUXXON Wltk 8 a*. Cun^M - So B*od
NoJttnil pip* Si***Inch**
lfoin*l Tblckn*** of Hisulition
~TT
l'H/T*.....
2* "
1/2
.19$
$ .lao
1 .668
3A
.211
.U37
.713
1
,2ia
.1*63
.757
i-iA 1-2/2 2
.267 .29U .321
.U99
.535
.570
.602
.8 k6 .891
2-1/2
.356
.62U
.936
3
.101
.677
1.02
3-1/2 '
.U6
,731
^
u
.535
.78U
1.20
U-l/2
.579
.838
1.29
5
.62U
.891
1.33
6
.713
.980
1.5'
7` 8
X 1.07 X 1.20
!*
--*
9
10
VU
le54
12
X 1*3 U
X 1.U7
2
`
X . 1.56
-
X 1.65
S* footnote* on Pig* 22, i&chibit Kt
(26)
Sxhibit A
OWEN S -ILLINOIS
Net Billing Prices F.O.B. Berlin, If. J.
KATLQ 20 IABGE SIZE PIPE INSULATION No Claras - No Bands
^56 Teraa ^ 30 Days
Nondnal
Pip* 31sInches
Nrwin*l Thirimssats of Ihsulation & Prices Per Lineal Foot
--------------------------CT7*--------------------------------------------T^UT*
~3"~
2$
$ 2*90
% 3.96
% 5*06
$ 6.12
26
2.90
3.96
5.06
6.12
27
2.98
k.12
5.22
6.28
28
3.06
It. 20
5.k3
6.k9
29
3.26
lull*
5.67
6.35
30
3.26
k.k9
5.67
6.35
31
3.51
k.81
6.0k
7*k3
32
3.51
k.31
6.0k
7.k3
33
3.59
lu9U
6.20
7.51
3k
3.71
5.10
6.36
7.75
35
3.92
5.3k
6.69
8.12
36
3.92
5.3k
6.69
8.12
37
k.12
5.59
7.02
8.53
38 .
k.12
5.59
7.02
3.53
12____ ________ ____ '________________IuJ2___________5J2_________7.3k
Note t (1) Prices listed are for the single layer only. (2) Doable layer orlces are the sun of the pri :es for the two
single layer sixes used. (3) Bctra charge for any canvas or bands.
8.9k
(kO ;
HBV-PL-1655
Exhibit A
QW3JS-ILLINOIS
Net- Billing Prices P.0.8. Berlin, N.J.
U!LQ 30 SECTIONAL PIPS INSLZATXGM
With 6 os. Cmra*
- No Sends
Kay 1, 1956
Tarn* Net 30 EUya
Nominal Pipe SireInches
1/2 3A 1
i-iA
1-1/2 2 2-1/2 3 3-1/2 U U-l/2 5 6 7' 8 9 10 11 12
Nflinal Thickness of Insalation
IT. '---------- V-l/gg"
2*
&
Pricts
per
Lineal Poet 1w
$ .190
$ .397
* .6L7
* .862 % 1.03
.207
.U22 .690
.905
1.16
.233 .LLfl .733 .918 1.21
.259
.183 .776
.991
1.25
28U
.517
.819
1.03
1.3U
.310
.552
.862
1C6
1.U2
3L5
.603
.905
1.16
1.51
.388
.655
.991
1-29
1-6U
U31
.''07
1.08
1.L2
1.77
.517 .560
.759 .810
1.16 -.-*2
1.55 L.68
1.90 2.03
.603
.862 1.5a
1-81
2.16
.690
-.914
l.u7
1.9 It
2.33
z 1.05 1.59
2.07
2.50
-
X 1.16 1.72
2.20
2.72
X
1.2>
1.90
2,ul
2.53
X I.a2 :.C"
2.6}
X
' X -* : --
XT
X 1.59
X
XX
See footnotes on Pa^je 22, Exhibit A
(26)
HBV-PL-1656
Exhibit A OWENS-ILLINOIS
Nat"Billir*S Price* F.O.B. Berlin, N. J.
KATLO 20 THI-SEGMENTXL PIPE INSOUTION 8 o*. Canva# - NO Bands
May I, IS$6 Tarns Nat 30 Days
Noadntl
Pipa SixesInch*#
'
Nondiul Thickness of Insulation & Prices Par Lineal
1-1/2**
2-1/2**
10
XX
X $ 3.25
11
X
X
* 2.85
3.1t7
12
X $ 2.Ill
3.03
3.65
lit
$ 1.87
2.67
3.3?
lulO
15
2.00
2.81
3.56
Iu32
16
2.09
2.9it
3.7U
U.5U
17
2.23
3.0?
3.92
lu77
IS
2.32
3.21
U.IO
U.99
19
2.51
3.U7
U.39
5.30
20
2.60
3.66
L.57
iM
21
2.7li
3.79
U.75
5.71 Qttad-Seg.
22
2.83
_ 3_*93
lw?U
5.9U
23
2.92
U.02 '
5.12
6.17
2ii -
--3*02
lull
5.26
6.U0
Sa* footnotes on Pag# 36, Exhibit A.
(39`,
HRV -- PL--16 5 7
Exhibit A
OWSJS-ILLINOIS
Nat Billing Prlcaa P.Q.B. Berlin# M- J.
NiT 1* 1956 Xaraa Nat 30 Days
KAILO 20 3SCnDMAl PIPS INSULAnOS Vlth Regular Ciani - 1* through 2-1/2* Tfticlma--aa
No Css?** - 3* thidenaea With Banda - All Biiclcnaaaaa
Ncalnal Plpa SixaaInchaa
1/2
3/L
1
ifcwLnal Thldmass of Insulation & Prlcaa par Linaal Foot
1-1/2*
2*
2-1/2
J*
1 .178
$ .373
8 .606
$ .811
# .973
.195 .397 .61*9
.852
1.09
.21? L22 .669
.892
i.ii*
1-2/1 1-1/2 2
2h3 L5L .730
.933 1.18
.260 .L87 .770
.973
1.26
.292
.519
.82X
1.01
1.3L
2-1/2
.32L .568 .852 1.09 1.L2
3 .365 .616 .933 1.22 1.5L
3-1/2
Lo6
.665 1.01
1.3lt
1.66
L
L07
7lL
1.09
1.L6
1.78
L-l/2 5 6
'
.527 .568 - .6fc9
.762 .811 ' .892
1.18 1.26 1.38
1.58 1.70 1.82
1.91 2.03 2.19
7
X
.973 1.50
1.95
2.35
8
X 1.09
1.62
2.07
2.55
9
X 1.22
1.78
2.27
10
X - 1.3L
1.95
2.L7
1
X 1.L2
2.07
X
12 Notai
Cl) (2)
(3) CL)
X ____ ijio_____
X
X
Prlcaa liatad ara far singlt layar only. Dbubla layar prlcaa ara tha ana of tha prlcaa fa* tha tvo singla layar aiaaa usad.
No tllovanca la nada for tha can..salon of catrma Jack*ta. Prlcaa Lncluda 2-1/2 alnal, mjn bands par 3 foot a action*.
2.76
X X X
--8 9 9 T r T<X. -- y V 3 a ;H
Exhibit A
0WZ3C-ILLINOIS
flat Billing Pricaa F.O.B. Barlln, tf. ,J.
kaxlo 20 arenaai pus astjumoif Hagaiat Cairru No 3nda
May 1, 1956 Tara Nat 30 Days
Nominal Pip# Sila india a
Nominal Thlcknaaa of Insulation k Pricta par Iinaal Foot
1/2 $ 1.00 3A 1.12 1 ' 1*17
i-iA 1-1/2
1.21 1.29
2 2-1/2
1.37 1.1*6
3 1.58
3-1/2 it U-l^
1.71 1.83 1.96
5 2.06
6 2.25
7 ''
2 .1*2
8 2.62
2
2.83
Saa footnotas on Paga 22, Exhibit A*
(2U)
HRV-PL-1659
Exhibit X
OWENS-ILLINOIS
Net BillInc Prices
P*0.S* -- t t nj
<J*
KAHO 20 SECTIONAL PIPS DtSULATIOH Regular Canraa aid Baade
May 1, 1956
Tarns Nat JO Days
Nominal Pipe 3Ileatnehaa
1/2 3A
1
1-1/li
1-1/2
2
Nominal TMeknesa of Insulation 4 Pricaa Par Lineal Poet
'~lr~
'
'
$ 1.01
1.13
a
1.18
1.22
1.30
1.39
2-1/2 3 3-1/2
1.U7 1.60 1.72
U U-l/2
5
1.85 1.97 2.10
6
7-
2.1iU
8 2____________
2.65 2.86
Saa footnotes on Page 23, Exhibit A.
(25)
HRV-PL-1660
HRV-PL -- 16 6 3.
Exhibit A
OWENS-ILLINOIS
Natr BUling Prlcae P.O.B. Berlin, IT.. J.
^*7 1> 1556 . Taraj Nat 30 Day*
30LTL0 20 BEVELED LAG TIPS INSXUTICK No Canvas - No Banda
Noaioal Pipe SitesInches
18
19
tfoalnal Thiclmssa of Insulation 6 Prlcaa Par
Lineal Toot
1-1/5*
2*
2-1/2*'
)*
$ 1*99
8 2.76
$ 3.52
b.29
2*11
2.91
3.68
U.Ux
20
2*18
3.06
3.83
b.6o
21
2.30
3.18
3.98
b.79
22
2*37
3.29
lulb
U.98
23
2.1i5
3.37
lu29
5.17
2k
2.53
3.U5
it* bO
5.36
25
2*72
3.72
U*75
5.75
26
2.72
3.72
tu75
5.75
27
2.80
3.87
Iu90
5.90
28
2.87
3.9U
5.09
6.09
29
3.06
U.21
5.32
6.U3
30
3.06
U.21
5.32
6.b3
31 * . . 3.29
U. 52
5.67
6.97
32
3.29
U.52
5.67
6.97
33
3.37
U.63
5.82
7.05
3U
3.U9
1a.79
5.97
7.28
35
3.68
. 5.02
6.28
7.62
36 Notet
(1) (2)
(3)
3.68
5.02
6.28
Prlcaa listad ara far the single Layer only. Double layer prices ara the sun of the prices for the two single layer sizes used. Extra charge for any canvas or bands*
7.62
(ui;
HRV-PL-16 6 2
Nt BHln Prtc# 7,0.B. 5*rlin, if. J.
Ihiclm***___ Inch*#
1 .1-1/2 2 2-1/2 3
Exhibit A
OWENS-ulinqis
Jun* 1, 1956 Tiaj N*t 30 Daya
IAILO 2Q K2AT INSUIATING BLOC!
36 Inch L*ngth* Pric** p*r Smart Foot
$ .218 .328 .107 *Sh6 .655
18 Inch Lmrtha
1 8 .228
1-1/2
.338
2 .1*7
2-1/2
.556
___ 2______________________________________________________ .665
Not* i
*
....
Block In th*a* thicks***** can b furni*h*d In 6*, 12" and
19" width*.
i
(L2)
HBV-PL-1663
Jum 22, 1956
Mr. J. .txraiiall Urtloy Owana-Osmiivf ?ib*r*lA Corporation National Bank Building Toledo, Jhio
Saar :<r. .Brilayt
Attach ad aro capias or* prise Hat for Xaylo block affective Jana 1, 1956* This replace* the previous list issued February 2?, 1956, and has boon road# to oarer the change in your Ui. prices on block.
Additional couioa of this list are also being seat to your aalas and service personnel who are interested in this chart:#.
Tjure truly,
((
J. T. Trussa
P**
' {laloaursa t - (2)
cci Kr. W. J. Stewart
Kr. -i- C. Lauphlin
fir* J.
HcNarnsj
Mr. C.
Neuhaus
-
.
HRV-PL-1664
Exhibit A OWgg^ILLTNQIS
jft Billing Prices F.O*B. Berlin, K. J*
.
J<*T 1# 1956 Tormm Net 30 Days
EAUfl SSCTKMAL 7175 PSULATIOH With Refular Canraa"- i"_ thro ugh 2-1/2 * TMcJciaaaea
No Cam - 3" Thicfcne** No Bind*
Nominal
Pipe SitesIndia*
Nominal IhicJowss of Insulation 4 Price* par Lineal Foot
-------------1-1/2"
2'" " 2-1/2"
J-
1/2
$ .159
$ .333
% c .51*3
$ .721*
$ .869
3A
.171*
.355
.579
.760
.977
1
.195
.376
.615
.796
1.01
l-i/i*
a?
.1*05
.652
.833
1.05
1-1/2
.239
.lOli
.668
.869
1.12
2
.261
.W3
.721*
*905
1.19
2-1/2
.290
.507
.760
.977
1.27
3
.326
.550
.833
1.09
1.38
3-1/2
.362
59u
.905
1.19
1.1*8
1*
.1*31*
.637
.977
1.30
1.59
U-l/2
.1*71
.681
1.05
1.1*1
1.70
5
.507
.721*
1.12
1.52
1.81
6 ; . ' .579
.796
1.23
1.63
1.95
7
X
.869
1.31*
1.71*
2.10
8
X
.977
1.1*5
1.85
2.28
9
* . 1.09
1.59
2.03
2.1*6
10
_
X 1.19
1.71*
2.21
X
U
X 1.27
1.85
X
X
12 Not* i
(1) (2)
(3)
X ____h&____
X
X
Prlcii listed an for single layer only. Double layer price* an thi sum of thi pricas for th* two
single layer site# used* No Allowanci la aide for omUaion of canvas jackets.
X
AHH
S9 9 X--
Exhibit A
OWDiS-HUNOIS
Net 31111 r-j Pric**
P.O.B. 3#riLn, N.'J.
'
^*7 1 1956
'
Trm Nt 30 Day*
KAILO SECTIONAL PIPS PTSOLATICK With Regular Canra* - i* through 2-1/2* Thickn*as*s
No Caaraa - 3* ThielaMSS With Baade - All Theta*aa*a
Nominal Pip* SizaaInches
1/2
unr*~NTom*--inal --Thiclm**
of -I-n--s-u--l-a-t-i-o-n---&
Prices par 2-1/2*
Lineal
-----------
Foot
* .161
$ .336
$ .514
$ .731
t .877
3/U
.175
.358
.565
.768
.987
1 1-1A 1-1/2
.197 .219
.2ia
.380 U09 .1*39
.621 .656 .69U
80U
ala
.877
1.02 1.06
1.13
2 .263 .1x68 .731 .911* 1.21
2-1/2
.292
.512
.768
.987
1.28
3
.329
.556
.81x1
1.10
1.39
3-1/2
k
.366 li39
.599 .6x*3
.9Zh .987
1.21 1.32
1.50 1.61
U-l/2
.1*75
.667
1.06
1.1x3
1.72
5
.512
.731
1.13
1.51;
1.83
6.
585
8Cit
1.2U
1.6k
7
z
.8??
1.35
1.75
8 . X .56 l.te 1.36
9
X J-* --*
t-
2.05
1.97 2.12 2.30 2,1*5
10
.
X 1.11
l.n5
2.23
X
n
X 1.26
1.86
X
X
12
Not* 1
Cl) (2)
(3)
X ___ Lt35 X X
Pricos llatei irt for jingle Layer only.
Douhl* layer price* irt ta* a_- :f tne picw for th* cvr
a ingle Layer all** u**d.
No allowance U --de far omtajicr, of ceirras Jackets.
r44 i m -4. ?! >*1
V^ t- 4* *.* ^ ^
X
9 9 9 1 -ad-A H H
Exhibit X 0WEJ5-ILLINOIS
Nfct aUlihg Pries* F.0.3. B*rlih# N. J.
.
POLO SSCTIQttAL PIPS IKStLATICW Rsfulsr C*Sr*j ' ' So Band*
Hy 1, 1956 Tra St 30 Days
No*n*l Pip# Six**Inch**
1/2
3/U 1
1-1/U
1-1/2 2
:
Modn*l Piicfcn* at Insulation k Pric** o*r
..............
3*
^
$ ,9Qk
1,02
1.05
1.09
1.17
1.2 L
y00t " ~~-
2-1/2
1J2
3 1.1*3
3-1/2
l.SU
U 1.66
L-l/2
1.77
5 . 1.88
6 -_ 7'
2.03 2.18
8 2.37
2 ' _________________
Sa* footnot** on P*g* 1, Exhibit A.
0) hrv-pl-1667
Exhibit A
OWENS-ILLINOIS
Net wn -^g Pricea F.Q.B. 5rlinj V*-J(
Nonius! Pipe SilM-
Inchea
1/2 3/U
1
1-1A 1-1/2
2
2-1/2 3 3-1/2
3CAIL0 sectional pipe insulation Hegttlar Cicni ad Band*
Hay 1, 1956 tars* Set 30 Days
Ifcatinal Biidtneaa of Insulation & Prices per Lineal Poet 3- ' :
. * .m '
1.03 1.06
1.10
1.18
1.2$
1.33 l.Ui
1.56
U U-i/2 5
1.67
1.79 1.90
6
7 *'
'2.05 2.20
8 2.39
1 _________________________________
2.58
See footnotes on Page 2, Qchiti: A.
HBV-PL-1668 (tt)
Exhibit A
0WE1S-ILLINGE
Nat Billing Mcm r.O.B. Bsrlin, H. J.
,
Kay 1, 1956 Taras Nat 30 Days
IAH0 SECnOSAL PIPE IN5UUnOM With 6 os* C*nras - Bo Bands
NodaAl Pips SisssInchss
1/2
3A
Koadaal Thickns of Ihsulstion k Priess psr Linaal Post
1-1/2
2*
2-l/2
.3*
$ .172
8 .360
1 .587
1 .782
$ .938
.188 .383 .626 .821 1.06
1 1-1/1* 1-1/2 2 2-1/2
.211 .235 .258 .282 .313
.1*07 .1*38 .1*69 .500 .51*7
.665 .701* .71*3 .782 .821
.860 .899 .938 .978 1.06
1.09 1.13 1.21 1.29 1.3?
3 3-1/2
.352 .391
.591; .61*1
.899 .978
1.17 1.29
1.1*9 1.60
h
.1*69
.688
1.06
1.1*1
1.72
U-l/2
.508 .735
1.52
1.81*
-a
r l.
5
.51*7
.782
1.21
1.96
6
- . 626
-.860
1.53
7 ;-
X
.938
1.1*5
1.76 1.88
2.1i 2.27
8
X 1.06
1.56
1.99
2.1*6
9
X 1.17
- m +-
2.19
2.66
10
X 1.29
1.38
2.39
X
11
X . 1*31
1.99
X
X
12
X l.u? X X
X
So* f ootnotaa on Pa^s 1 , Exhibit Ki
HRV-PL-1669
Exhibit A
OWENS-ILLINOIS
Net Billing Price* ?.0.B. Berlin, M..J.
IAZL0 SECTIONAL PIPE INSOLATIONWith 6 os* C*ma and Band#
1, 1956 Teraa Nat 30 Day*
Wnarinal
Pips Sixes^ncbs*
Nominal ThlekRtss of ------ 1-1/2*
I-n---s-o--lajTti-io--n----&---Pr2ie-a1a/2o*--sr Linea3l *?oot
1/2
$ .17U
$ .363
1 .592
$ .789
8 .91*7
3A
.189
.387
.631
.828
1.07
1
.213
.1*10
.671
.868
1.10
1-1/1*
.237
.1*1*2
.710
.907
l.ll*
1-1/2
.260
.1*73
.750
.91*7
1.22
2
.281*
.505
.789
.986
1.30
2-1/2
.316
.552
.828
1.07
1.38
3
.355
.600
.907
1.18
1.50
.3-1/2
.395
.61*7
.986
1.30
1.62
I*
.1*73
.691*
1.07
1.1*2
1.71*
U-l/2
.513
?t*2
l.ll*
1.51*
1.85
5
.552
.789
1.22
1.66
1.97
6
.631
`.868
1.31*
1.78
2.13
7
'. ' X
.91?
1.1*6
1.89
2.29
8
X 1.0?
1.58
2.01
2.1*5 %
9
X I.LD
l.?l*
2.21
2.68
io :
X i.;-:
1.89
2.1*1
11
:
X 1.36
2.01
X
X X
12
X 1.16 X X
X
S footnote# on Pag*
Suhioit a.
HRV-PL-16 7 O
Exhibit A
OWENS-ILLINOIS
Nat Billing Prica# F.O.B. Barlin, N. J.
UILO SECTIONAL PIPS INSULATION With 3 os. Canrta no Banda
Hay 1, 1956 Tara* Nat 30 Days
Ncinal Pipa SlsatJnefaas
1/2 3/k 1 l-i/l* 1-1/2 2 2-1/2
3 3-1/2 U L-l/2
5 6
Xo*rul thicknaaa of Insolation it Prica# par Linaal foot 1-1/2* 2* 2-1/2* 3"
$ .178
.373
$ .606
$ .811
% .973
.195
.397
.61*9
.852
1.09
.219
.1*22
.689
*892
1.11*
.21*3
.1*51*
.730
.933
1.18
.266
.1*07
.770
.973
1.26
.292 .321*
.519 .568
.811 852
1.01 1*09
1.31* 1.1*2
.365
.616
.933
1.22
1.51*
.1*06
.665
1.01
1.31*
1.66
.1*67
.711*
1.09
1.1*6
1.78
.527
.762
1.18
1.58
1.91
.568
811.
1.26
1.70
2.03
.61*9
.892
1.38
1.82
2.19
7 '' 3 9 10
X
.973
i.5o
X 1.09
1.62
X 1.22 . 1.78
X 1.31*
1.95
1.95 2.07 2.27 2.1*7
2.35 2.55
2.76 X
U
'
X 1.1*2
2.07
X
X
12
X 1.50 X X
X
Saa footnotaa on Pago 1 , Exhibit A
HHV-PL-1671
Schibit A
OHEjrS-ILUMQIS
Nat Billing Pile** 7.O.B. Barlln, If. J.
.
**>7 1 1956 Tara* Nat 30 Days
eailo sectional pips pgouTica With 8 o* Canra* tad B*sd*
Nominal pip* Sixa*Incha#
1/2 -
Nominal TMcknaaa of Thrilatlon 4 Pricaa par Linaal Poot
r* 1-V2-
Ji* -- 2-1/2
3"
$ .180
$ .376
% .611*
$ .818
$ .982
3/1*
.196
.kn
.65U
.859
1.10
1 .221 .1*25 .695 .900 1.15
l-i/l*
.215
.158
.736
.9ia
1.19
1-1/2
.270
.1*91
.777
.982
1.27
2
.291*
.521*
.818
1.02
1.35
2-1/2
.327
.573
.859
1.10
1.1*3
3
.368
,622
.9til
1.23
1.55
3-1/2
.109
.671
1.02
1.35
1.68
1*
.151
.720
1.10
1.1*7
1.80
U-l/2
.532
.769
1.19
1.60
. 1.92
5
.573
,818
1.27
1.72
2.05
6
.651*
.900
1.39
1.81*
2.21
7`
X .982 1.51 1.96
2.37
8
X 1.10
1.61*
2.09
2.58
9
X 1.23
1.80
2.29
2*78
10
X 1.35
1.96
2.15
X
U
'
X 1.15
2.09
X
X
12
X 1.51
X
X
X
Saa footnota# on Paga 2, Exhibit A
HRV-PL--1672
Exhibit A
0V2JJS-ILLINOIS
Net Billing Prices P.0.3. Berlin, N; J.
May 1, 1956 Terns Net 30 Days
EAXLO TUBE INSULATION Regular Canvas - No Bands
Tube SixesInches
Actual '
Tbbe O.D.
Nominal Thickness of Insulation & Prices Per
' Lineal Foot
--- _x.--------------
tot?*------------
3/5 .500
$ .159
$ .333
1/2 .625 5/8 .750
.159
.17 Ii
.333 .355
3A .875
17U
.355
1 1.125
.195
.376
1-l/U
1.375
.a?
*2s05
1-1/2
1.625
.239
*Ii3U
2 2.125
.261
it63
2-1/2
2.625
.290
.507
2_____________________ 3.125 Notet
.326
______________ .550
(1) Prices listed are for single layer only*.
(2) Double layer prices art the sun of the prices for the two
single layer sixes used.
(3) No allowance Is Bade for emission of canvas Jackets.
Clt) The O.D.' 3 of all tube Insulation ccnforsi to pipe insulation
simplified itliwerslonal standards. Use nesting pipe insula-
tlon for outer layer if greater thickness Is required. Mien
double layer tube Insulation is required, use pipe insulation
for outer layer.
(9)
HRV-PL--1673
Exhibit A
cwens-Illinois
Net Billing Prices F.O.B. Berlin, Jf.'J.
K*y 1, 1956 Tirw Net 30 Days
, gJgLO TUBS lysuunow Regular Canvas tod Band*
Nominal Tube SixesInches
3/8
1/2
5/8
3A 1
1-iA 1-1/2 2
2-1/2
Actual Tube O.B*
*5oo
.625 .750
.875 1.125
1.375 1.625
2.125 2.625
Mom,Inal Thickness of Insulation k Prices Per
Lineal Podt
.
1* l-in*------------
3 .161
# .336
.161 .336
.175 .358
.175 .358
.197 .380
.a9 .159
212. .109
.263 L68
.292 .512
3
Hotel (1)
(2) (3) (U)
(5)
____ 3**25
_____________ zm_______________ __ ^556
Prices listed srs for single layer only.
Coubls layer prloss srs the na of the prices for the two
single layer sixes used*
No allowsnce is Bade for oeisaion cf csrtras Jackets*
The 0*0*rs of all tube insulation confers to pipe insulation
simplified diasneional standards. Use nesting pipe insulation
for outer layer If greater thickness is required* Vfei double
layer tube insulation is required, use pipe insulation for
outer layer*
.
Prices include 2-1/2 aluadnun bands per 3 foot section*
uo;
HRV-PL-1674
Exhibit A
CWENS.HUNOIS
rr*t ~miiing Price* 7.0.B. Berlin, N. ' J.
*7 1, 1956 Tern* Net 30 Da>*
' KAXL0 TUBE BfSUUTIOtf 6 os. cmra* - No Benia
Noainal
Tub# SiseaInch**
Actual
Tub* O.D.
Nominal Thickzv*** of Insulation & Prices 7r Lineal Toot
1* ---------- : 30177*---------------
3/8 500
$ .172
% .360
1/2 .625
.172
.360
5/8 .750
.188
.383
3A .875
.188 .383
1 1.125
.211
.1x07
l-i/U
1.375
.235
.108
1-1/2
1.625
.258 .1x69
2 2.125
.282 .500
2-1/2
2.625
.313 .51x7
3 .352 .59ix
5 footnote* on ?ip 9$ Exhibit X
01)
HBV-PL-1675
Exhibit A
owag-xiLiNois
Nat Bill! r.j Pricaa F.O.B. 8* riia. If.; J,
'
EATLO TUBS INSOLATION 6 ox. Canra* k Band*
May 1, 1956 Tarmx Nat 30 Days
Nominal Tubs 31l'-
Inch#*
Actual
Tuba0.0.
Nominal Thickna*a of Inflation & Pricaj p#r Linaal toot 1^77*----------- -
3/3 .500
3 .17U
.363
1/2 5/3 3A 1 1-1/U 1-1/2 2 2-1/2
.625 .750 .875 1.125 1.375 1.625 2.125 2.625
o
'O CM
.17U .18? .18? .213 .237
.281. .316
.363 .387 .387 2il0 Mt2 .li73 .505 .552
2______ ____________l^iJS____ __________________ .355 Saa footaotaa on Px^a 10, Exhibit A*
.600
(12) HRV-PL-1676
Exhibit A
cwDiS-nuHois
Nt Billlac PriCM
'
7.O.B. B#rlia, Ml J.
SAHO TUSg DSHUTIOH
fl^amSnTtF^TioTtali
1* 1556 Tnu tf#t 30 Day*
ml
Tab* 3ii-
Inch**
Actual Tab* O.D.
Moaiaal Thldm*** af Insulation k Prlc par Lin*al Foot
--r*"
3/8 .500
$ .178
.373
1/2 .625 5/8 .750
.178 .155
.373 .357
3A .875
.155
.397
1 1.125 .215 .122
1-iA
1.375
.243
.U51;
1-1/2
1.625
266
.107
2 2.125 .252 .515
2-1/2
2.625
.321;
.568
2__________
3.125
i2^i
616
S footnot#* an ?*g 9, Bthlblt A.
(13)
I HRV-PL--1677
Exhibit A
_
CUSS-ILLINOIS
Ht Billing Price* F.O.B. Sariin, I. J.
H*y 1 1$56 Teras Ket 30 Days
SATLO TtrSE IMSOIATIOX 8 os. CMarts end Bead*
Konri nsl Tabs Six** Inches
Actual
Tub* O.D.
Kc*n*l Thickm** af Insulation & Prices Par
Lineal Foot
---------
1-1/2"----------
3/8 .5oo
$ .130
.376
1/2 625 5/3 750
.130
.196
D .376
lid
3A .875 1 1.125
.196
.liQi
.221 1)25
1-l/U
1.375
.215 .153
1-1/2 2
1*625 2.125
.270 .151 .29U 52k
2-1/2
2.625
.327
.573
2_____________
3.125
.363 .622
Se* footnotes on ?sgs 10, Exhibit A*
(1U)
HR V PL-1678
Exhibit A
WSC-ILLINOIS
Kt Hilling Price* F.O.B. B*rlin H. J.
UILO TRI-ggQSHTAL PITS LVSUUTIOT
No Canras - Ho Bands
"
Hay 1, 1956 Tern# Met 30 Daya
Koalas!
Pip# Sis** Inch#*1 2
Nominal Piickneae of Bisulatioc & Prig*a p*r Lineal Foot
1-1/2*
2*
2-1/2*
~~T*
Not* t (1) (2)
C3)
Price* li*t*<i art for single layer only. Double layer price* are the sum of the prices for tfca two single - layer sizes used. Extra charge for bands.
(15?
HRV-PL-1679
Exhibit A
_ Cwms-TT.LTNOIS
Nt Billing Prlcaa F.O.B. Berlin, N.; J.
EAILO TRI-3E3PTAI PIFR INSULATION Sagular Canraa - No Bands
Hjy 1, 1956 Tara* fiat 30 Days
Ncstnal Mpa SitaInch#a
10
Nowlnal Thicknaaa of Insolation k Prlcaa par Llnaal Foot
------------------1-1/2* ~J!------------------ 2-l/2
_
XX
X $ 2.82
11 X X $ 2.U7 3.01
12
X $ 2.06
2.62
3.17
lit
$ 1*62
2.32
2.93
3.55
15
1.7U
2.10
3.09
3.7U
16
1.81
2.55
3.2lt
3.9U
17
1.93
2.66
3.L0
U.13
13
2.Cl
2.78
3.55
lt.32
19
2.17 3.00
3.79
It. 58
20
2.25
3.16
3.95
ti.7ti
21
2.37
3.28
It.n
It.92 Quad-aag
22
2.U5
3.1iO
h.25
5.12
23
2*53
3,h6
U.ltl
5.31
2lt :
2.60
U.S3
-*51
Saa footnotaa on Piga 15, Echibit A.
(16)
HBV-PL-1680
Exhibit A
OWDC-ILLINOXS
Net mil inf Prloee P.Q.B. Berlin, H.-'J*
ftty 1, 1956 Terma Net 30 Days
ElHO TRI-S]!DMEyTAL PIPE DtSOLATIOH 6 ox. Cum - Bo Bands
Ncatinsl Pips SixesInches
10
11
12
Moslnsl Thickness of Insulation k Prices per Lineal Poot
-------------------- 1-372*-- 2*
2-1/2*
---------
X
X -X
$ 245
X X $ 2.50 3.05
X $ 2.11
2.66
3.21
Hi
$ 1.61
2.35
2.97
3.60
15
1.76
2.16
3.13
3.79
16
1.31
2.58
3.28
3.99
17
1.96
2.70
3.lb
!u!8
18
2.03
2.82
3.60
lt.38
19
2.20
3.0b
3.81t
lu 65
20
2.28
3.20
It. 01
ltt81
21
2.lt0
3.32
U.17
5.01 Qtiad-sef
22
2.18
3.Ub
lt.33
5.21
23 2U `
'
2.f6 2.6b
3.52 3.60
It.li9 b.6l
5.1il 5.61
Sm footnotes on Pife 15, Exhibit A*
(17)
HRV-PL-1681
Exhibit A
0W8S-ILLX}f013
Nt Billisj Prlc** F.Q.B. B*r11s* If* J*
EULO TRI-ggagaTTAI PIPS PgUmTCH 3 os. Otar** - Mo Bind*
K7 1, 1956 T*ra* 5#t 30 Dajs
Vrrwrl
Pip* 51M*Inch**
10
u
12
lit
15
16
17
IB
19
nrKo*ia*l Thicks*** of Insalatlon
---------------------------l.USi - T2*-
k Prlc**
TOT
p*e
""
Lln**l
Foot
xx
x
x x I 2*60
X $ 2.19
2.76
I 1.70
2.U3
3.08
1.82
2.S5
3.2it
1.91
2.68
3.U1
2.03
2.80
3.57
2.11
2.92
3.73
2.29
3.17
luOO
3-- footnot** on Pag* 15* Exhibit A.
(18)
HRV -- PL -- 16 8 2
Exhibit A
_
CMOS-ILLINOIS
.
Net Billing Prloee 7.0. B. Berlin, N. J.
'
^7 1# 1956 Term* Net 30 Days
KAILO LABOR 3I2S PIPS INSOLATION No Cane** - No Send*
Nominal Pipe 3i**aIndie a
25
26
Nominal Thlekneaiea of Emulation 6 Prices pe r Lineal Poot
1-1/2*
2* 2-1/2* 3*
$ 2.61
$ 3.57
$ L.56
% 5*52
2.61
3.57
L.56
5*52
27
2.69
3.72
L.71
5*67
28
2.76
3.79
It.8 9
5.85
29
2.91
L.C5
5,22
6.18
30
2.9U
L.05
5.12
6.18
31
3.16
L.3U
5.L5
6.70
32
3.16
It.3It
5.L5
6.70
33
3.21
L.U5
5*59
6.77
3it
3.35
L.60
5.7L
35 3.53 L.82 6.0L
36 3.53 L.82 6.0L
37 38 *
3.72 3.72
5,oit 5. <S*
6.33 6.33
19 .. Note j
CD (2)
(3)
3*9 _____ 5*26
6.62
Prices Hated are Tor single layer only. Double'layer prioee are the sun of the prices for the twc single layer sizes used. Extra charge for any canvas or bands.
6.99 7.32 7.32 7.69 7.69 8.06
(19)
HRV-PL-1683
Exhibit A
OKQtS-ILLINOIS
Net Billing Price* P.O.B. Berlin, J.
'
K*7 1; 1956 Term* Net 30 0*73
LIHO BS7BZP LAP PIPS BSOLATICg ..... ~ No Genre* - No Bend*
Kaad-otl Pipe SireInchee
.
1-1/2*
aictae** of Inanlation & Price* Per
' Lineal foot
.
2~~
2-1/2*
`3*
"
13
$ 1*78
2.U7
$ 3.16
$ 3*8k
19
1*3?
2.61
3.29
3.90
20
1.96
2.7U
3.k3
It.12
21
2*06
2.85
3.57
lu2?
22
2.13
2.95
3.70
Iuk6
23
2.20
3.02
3.8k
lt.63
21a
2.26
3.09
3.9k
lt.80
25
2*2ala
3.33
la.25
5.15
26
2.1*
3.33
It. 25
5.15
27
2.50
3.1*6
k.39
5.28
28
2.57
3.53
k.56
5.1t5
29
2.7k
3.77
k.77.
5.76
30
2.7U
3.77
k.77
5.76
31 *
2.95
k.05
5.C8
6.2k
32
2.95
U.Q5
5.00
6.2k
33
3.02
k.15
5.21
6.51
3k
3.12
It.25
5.35
6.52
35
` 3.2?
. U.lt?
5.63
6.33
36 Notei
(1) (2)
(3)
3.29
It.lt9 _____ ^_____
6.83
Price* Hated ere for the single layer only. Doable layer price* ere the sun of the price* for the two single layer else# used. Extra charge for any canraa cr bands*
fr8 9 t-Id -A H H
EXHIBIT
IV
HRV-PL-1685
American Madical Association Archives Health, published
by the American Medical Association, Vol. 11/ 1335, through Vol.
135.
.
. Aaerican Industrial Hygiene Association Quarterly, 1545 through 1931.
Annual Review of Hue!ear Science/ published by Annual Reviews, Inc., 1952 through 1952; 1355 through 1957.
Archives of Industrial Hygiene and Occupational Medicine, published by the Acer lean- Medical Association; 13 53 to 1954.
3ritish Journal cf Industrial Medicine, published by ish Medical Association, 1349 through 1332.
Industrial Medicine and Hygiene, published by 2utr* :h and Ccr.pany, 1 32 4 through 1535.
HBV- PL-1686
.* mdus::ill Kadicint and Surjtry, 1343 th.-bu^b issa.
Journal of Industrial Syrians and Toxicology, r>.*, published by tht wiliiass and Wilkins Con?any, 1323 thrown 1343
* Hoiso Control, pubiishtd by ah* Aceoustieal Society a America, 1335 through 1351.
Aids to Anatoay, Last, 1331.
'
* .*
*
Airborno Contagion and Air fyfiono, An Icolo*ical Study
of Traupvood Infections, Wells, 1335.
Analytical Chemistry. By Treadwell, Vol. 1, Ouantitativt Analysis, 1337.
Chemical Analysis of Industrial Solvents, Jacobs and
Scheslan, 1333.
.
Chemical Insineecs' Sandbccx, edited by Jerry, 1341.
Sesiga of Industrial Sxhaust Systems, Aldan, 1 3 2 3 .
dictionary of Modern In^lisb "sa?t. A, by
1223.
Sltctronsa^not ioa--y Inrttnso .so*.::ej a nd Mass ceczr onto try, Proceedings ri the Conference Held * /* * V 'all, Harwell, 3apt., 1 *;:;
Incyclopedia :f Instruments:
>d bv yasse, Byers azd
132
: r_ ;
Fatigue, edited :y ricyd and Halford, 1321
HRV-PL-1687
Fatit-a of ~c:kt:s - Its Halation *3 Industrial ?ro^ucion, Conns; 11 a a on 'w*-'* Industry of tit# national Council/ 1941-
fuels Md Ccabustion, Ssith and Stinson, 1932.
Acoustics and Vibrational Physics, Stsvtns and
net/ 1530; Acoustical Infintarinj, Olsen, 1957;
Acoustic Maasucaoants, 3tranak, 1949; The Massurtatnt of Htariny, Hirsh/ 1952;
Man's World of.Sound, Pitres and Savid, 1951;
Technical Aspaets of Sound/ tdittd by Piehardsen, 1953;
Physiological Acoustics, Wtavtr and lawrtnct,
1954;
fundaaontals of Acoustics/ 2nd Sdition, Pinsltr
and fray, 1950;
Acoustics No1st in Buildings, Parkin and Suaphrays, 1955;
Satrinp and Otafntss/ 3rd Id ition, tdittd by
Qavis and Silvarcan, 1547;
.
A Textbook of Sound/ wood/ 1949;
Hoist Xtduction Manual/ Caigar, 1953;
Physical Acoustics, Supplicant 1, tdittd by
tukasik and Holla, 1955;
Foundry Hoist Manual, Aatrican roundrvatn's
Socitty, 1935 and 1955;
Foundry ventilation and lust Control,
Harro?att, 1955;
.
Body Cteptratura, Its Chanfts with Sr.vi;meant, Oistast and Charapy, Stilt, 1552;
Aoplisd Haat Transmission, S;c*vr, 1541;
Haat and Ca.toari:::i Maasorantnt,
1552;
lift Hast and Altitudt, :ili, 1323;
Ftat Insulation, vilkas, 1 533;
asic Principlts of 3ad ford . 1 9 4 3 ;
aa
/
Fa at Cransniss
C * : d j v 1; f , 3:: o < s , - :
S
<
I
*d
p
i
Fane hook of Char.- A , ' /
Far.dhcok :f
T;x :.::v .n a a , . - .
nanotoo< cf Class Ma.rufa
3v Tot:*'-*, .;!
Handbook of ".attrial Trad a Hinas,
a an and lav;.-*
8891
and
of x i
gy* edited y 5:#c
55 and
' History of factory and Mine Hygiene* Tiltxy,
*
--
*
. Human Machine/ The* Shilling/ 1355.
..
IndustriaX Invironment and Its Central/ The, by
CallavalTe* ^341.
...
" Industrial Medicine and Hygiene/ edited by Merestther* 1354 through 1335.
Industrial Methods of Analysis/ Willard* Merritt*- and
Oe an * 19 41.
.
' Industrial ftisons in the United States* Hamilton, 1315.
Industrial Toxicology* Hamilton and Johnstone* 1345.
. 1323.
Introduction to Medical Biometry and Statistics* ?earl* ..
Introductory Quantitative Chemistry, Olson* Hcch and
?imentei* 1355.
.
language Habits in Human Affairs* Lae* 1541.
Manual of Industrial Health Hazards* ficklan* 1343.
Manual of- the International Cist of Causas of leath*. u.5. Government Printing Office* 1325.
Manual cf the International Statistical Classification cf Diseases* Injuries* and Causes of leach, **cl. 2, -.1 phaseoi:a 1 Index, 1332.
Mechanical engineer's Handbook, -diced by Marks, 1331
Matheds of Air Analysis. 3y Haldane, 1533.
Mcxicus Gas and che Principles of ?.t spir atic.n Influencing their Action, Henderson and Haggard, 1521.
Cdcrs Ph'-s iclccv Conor ol, C:
Preventive Medium- i.nd Prblir Health, Intel.re* .3;
t
<
I
* r
\
?rcf ess ic.oal nawers, lends, 1335.
s ;xanmacron Questions and
Hadiciso topes i: So rent;: ic P.esearch, edited :v Ixtermann, 1 33 2,
689t
Socit'. Collet Clitsauras, The .\'*v Xitricm iisr*fv
MSS*.
.
`
"
. Standard: Methods of Chaaical Analysis, Scott, 5:h
Id it ion, 1525;
-
Symposium on Instrumentation in Atmospheric Anaiyji*,
published by The American Society dor.Testing and Materials, 1 55t.
Toxicology and Hygiene of Industrial Solvents) tditd t
Lehmann .and Flury, 1542.
-
Women in Industry - Their Health and Efficiency, Baetjer, 134
Proceedings of the 3tb Intarnational Congress cn Industrial Medicine, 1545.
The Pneumoconiosis Problem, Thomas, 1551.
HBV-PA' -169