Document 3NdZKMzYoXdOOqpYDmM3Nv5BJ

v^r ? 7-- ""Vr. M-' '... V': PLAINTIFFS I EXHIBIT ICI-17 IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO ANTHONY MARIO GRECO et al.. Plaintiffs, CASE NOS. 323629-323678 (HANNA, J.) Vs. A-BEST PRODUCTS COMPANY, et al.. IN RE: ALL BARON & BUDD ASBESTOS CASES Defendants. ANSWERS TO PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO INSUL COMPANY. INC. TO: INSUL COMPANY, INC., by and through its attorney of record, John W. Thomas, Zimmer Kunz, 3300 USX Tower, Pittsburgh, PA 15219-2702. Defendant is hereby requested to answer under oath the interrogatories numbered 1 to 58, inclusive, as shown below, within sixty (60) days of the time service is made upon the Defendant, in accordance with Ohio Civil Rule 33. GENERAL OBJECTIONS AND PRELIMINARY STATEMENT Insul Company, Inc. was incorporated-in 1960. Its founding fathers and principals have since passed on and therefore, Insul Company, Inc.'s responses to these discovery requests are limited to knowledge and information available at this time. These-- responses are based on facts known or believed to be true by the Defendant Insul Company, Inc.sat-theiime of the answering of these discovery requests. Much of the--' information requested date back many years and thus, it is difficult if not impossible to reconstruct or retrieve this information. Insul Company, Inc. reserves the right to amend or supplement these responses, as information becomes available. Insul Company, Inc. objects to these Interrogatories/Production of Documents insofar as they seek information which is subject to the attorney/client privilege and which constitutes the attorney work product or which is otherwise not discoverable under the Ohio Rules of Court. This Defendant further objects on the grounds that this discovery is unnecessarily repetitive and therefore oppressive and burdensome and not reasonably calculated to lead to the discovery of admissible evidence. This Defendant further objects to this discovery insofar as the requested information purports to require that this defendant "identify" documents on the grounds that it is overly broad, burdensome and oppressive. This Defendant further objects to this discovery insofar as it calls for responses, which are not relevant to the time period during which the Plaintiffs worked or to the locations at which any of the Plaintiffs worked. Thus, they are irrelevant, overly broad, burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Insul Company, Inc.'s answers to this discovery are limited to the extent that this discovery request seeks the disclosure of any mental impressions of its attorneys, their conclusions, opinions memoranda or summaries of legal theories. Insul Company, Inc.'s response to this discovery is in good faith and in the spirit in cooperation and is continuing into an investigation into the subject matter sought, and thus cannot exclude the possibility that its continuing investigation may reveal more complete information or even information which indicates that a response is inaccurate. The Plaintiffs have requested that this Defendant respond to locations listed in- Exhibit A. To the extent that the locations are titled or otherwise labeled in terms that are unfamiliar.:to this Defendant, same are objected to, but without waiving this, objection, this Defendant admits to selling products to Armco Steel, Ashland, Kentucky; Armco Steel, Hamilton, Ohio; Armco Steel, Houston, Texas; Armco Steel, Middleton Ohio; Republic Steel, Canton, Ohio; Republic Steel, Cleveland, Ohio; Republic Steel, Warren, Ohio; Republic Steel, Youngstown, Ohio; Weirton Steel, Weirton, West Document#: 16774 3380.0001 -2 - Virginia; Wheeling Pitt Steel, West Virginia; Youngstown Sheet and Tube, Youngstown, Ohio. This Defendant, however, did not sell asbestos-containing products to all of these facilities. It is believed and therefore averred that both asbestos and non-asbestos- containing products were sold to Republic Steel, Canton; Republic Steel, Warren, Ohio; Republic Steel, Youngstown, Ohio; Republic Steel, Cleveland, Ohio and Youngstown Sheet and Tube, Youngstown, Ohio. INSTRUCTIONS 1. Answer each interrogatory separately and fully in writing under oath, unless it is objected to, in which event the reasons for objection must be stated in lieu of answer. 2. An evasive or incomplete answer is deemed to be a failure to answer under Ohio Civil Rule 37(A). 3. Each Defendant is under a continuing duty to seasonably supplement its response with respect to any question directly addressed to the identity and location of persons having knowledge of discoverable matters, and the identity of each person, expected to be called as an expert witness at trial and the subject matter on which he or she is expected to testify. Furthermore, each Defendant, pursuant to Rule 26(E) of the Ohio Rules, is under a similar duty to correct any incorrect response when the Defendant later learns that it is incorrect, including in such supplemental answer the date upon and manner in which- such further or different information came to each Defendant's attention. 4. Unless otherwise specified, each of these interrogatories are meant to apply to the time period from 1920 until the present. 5. Should the Defendant assert a privilege with respect to any information,--, defendant is requested to provide the following as to each such document or item of information: (1) The type of document or information (e.g., letter, notebook, telephone conversation, etc.). Document#: 16774 3380.0001 -3- (2) The date of the document or transaction involving the information; (3) Identification of the author and/or all participants with respect to the information; (4) Identification of the signatory or signatories of the document, if any; (5) Identification of the documents current custodian; (6) The present whereabouts of the document and/or the names of all persons with personal knowledge with respect to the information; and (7) A statement of the grounds on which the claim of privilege rests with respect to each such document or piece of information withheld. 6. If your answer states that the Defendant is undertaking an investigation of the subject matter of the interrogatory, state when the investigation began, what steps comprise the investigation and what documents are being reviewed as part of the investigation. 7. The following terms are defined as follows for the purpose of these Interrogatories: DEFINITIONS As used in this set of Interrogatories and Request for Production, the following terms mean: 1. The words "Defendant" "You," "Your,"'Your company," all mean the corporate Defendant separately answering these Interrogatories, and any of its merged, consolidated, or acquired predecessors, divisions, subsidiaries,... foreign subsidiaries, foreign subsidiaries of predecessors, and/or affiliates. This includes, but is not limited to, those known to have mined, manufactured, sold, marketed, utilized or distributed asbestos or asbestos-containing products or that incorporated asbestos or asbestos-containing products at any work site. This Document M: 16774 3380.0001 -4 - definition includes present and former officers, directors, servants, agents, employees, and all other persons acting or purporting to act on behalf of the corporate Defendant or its predecessors, subsidiaries, and/or affiliates known to have mined, manufactured, sold, marketed, utilized or distributed asbestos or asbestos-containing products. "Predecessors" further means any business firm, whether or not incorporated, which had all or some of its assets purchased by you or came to be acquired by you whether by merger, consolidation, or otherwise known to have mined, manufactured, sold, marketed, utilized, or distributed asbestos or asbestos-containing products. "Subsidiaries" further means any business firm, whether or not incorporated, which is or was in any way owned or controlled, in whole or in part by Defendant or its predecessors and which is known to have mined, manufactured, sold, marketed, utilized or distributed asbestos or asbestos-containing products. 2. "Document" includes, but is not limited to, correspondence, letter, memoranda, message, note, report cable, telegram, photograph, film, tape, and all other written communications of every kind and character; note, recording disk, or any other record of oral communication; microfilm; worksheet; schedule; exhibit; demonstrative aid; letter; contract; agreement; deeds, bills of sale, deeds of trust, security agreements, leases and other instruments or documents of title; maps; diagrams; logs; summaries; printouts; graphs, charts; compilations, tables; publications; manuals; minutes; by-laws; articles of incorporation; resolution; shareholder endorsements; partnership documents; minute books, diaries; calendars, bank statements, tax returns; lists; tapes, video tapes; and any other data compilations from which information can be obtained and translated. 3. "Identify" means to give the date, title, origin, author, and addressee to enable plaintiff to retrieve it from a file; and further, identify means to give the name, address, position, title, and whether a person is employed or Document P 16774 3380.0001 -5 - \ -f not employed by the Defendant. 4. The words "person" or "persons" include natural persons, firms, partnerships, associations, joint ventures, corporations, and any other form of ;: -v business organization or arrangement, and officers, directors, shareholders, employees, agents, and contractors of any business organization or arrangement. 5. The words "meeting" or "meetings" may mean any coincidence or presence of any persons, whether or not such coincidence or presence was prearranged, was formal or informal, or was in connection with some other activity. 6. The words "describe" or "description", when referring to a place, thing, or occurrence, mean to identify with sufficient particularity the place, thing, or occurrence so as to enable one to locate, examine and fully comprehend or understand the place, thing, or occurrence described. 7. The words "product containing asbestos fibers," "asbestoscontaining products," "asbestos products" all refer to any products or materials prepared in any way for sale and/or distribution that contained any kind of asbestos in any possible form. 'Me words "asbestos materials" refer to any and all materials, substance, or matter used or assembled or fabricated during the .-"S' manufacture of a product, and that contain at least some asbestos fibers. "Product" includes, but is not limited to, pipecovering, turbines, cement, block, gaskets, packing, plaster, joint compound, floor and ceiling tiles, mastics, boilers, * raw fibers, fireproofing, shingles, panels, sheets, boards, millboard, refractory cement, boilers, firebrick, brake and clutch linings, finishing compound, texture, and other construction, building, drywall, lath and insulation materials. 8. The words "design changes," and "modifications" mean alterations in the makeup and/or components of a particular product, including but not limited to, variations in the amount or type of asbestos used in the process Document#: 16774 3380.0001 -6- of manufacturing the product. 9. The words "distribute," "distributed," "distributor," and "distribution" all refer to the sale, marketing, dispersal and/or shipment.of asbestos-containing products for purposes of their sale, resale and/or for purposes of filling orders provided by other business concerns. The word "distributor" specifically refers to a company or its sales representatives, whether dependent or independent, responsible for sales or marketing of products. 10. The words "marketed," and "market" mean and include all efforts to assist in the distribution and/or sale of products. More generally, these terms refer to only efforts on your part or the part of manufacturers or distributors to sell or otherwise distribute products. 11. The words "medical advisory capacity" refer to the duties, abilities or capabilities of any member of Defendants staff, or any individual or organization who has contracted with Defendant, to provide services'of a medical nature, including but not limited to providing medical advice. 12. The words "trade organization," or "trade association" mean any organizations or associations of business or industrial entities that are associated and/or meet for the purpose of achieving common goals and/or exchanging information related to common needs or interests, and/or learning information or facts of interest to the various members of the organization or association. 13. The word "plant" means a manufacturing or assembly facility where products are assembled, manufactured, constructed, fabricated, or where component parts, materials, substances, or matter of such products are fabricated, assembled, or manufactured or are prepared for further fabrication and/or assembly. 14. The word "manufacture," or "manufactured" means to fabricate, to construct, to assemble, prepare for fabrication or assembly, or any other action Document U 16774 3380.0001 -7 - taken prior to completion of the product or material before the time of its shipment. 15. The words "sales materials," or "written sales materials" mean any and all documents or literature of a promotional nature that were created or printed for the purpose of assisting in the marketing or distribution of the products. Such documentation may include, but is not limited to, sales invoices, order slips, and other written indicia of orders received and sales made. 16. The words "rebranding agreement" mean an agreement of any kind whereby one party to the agreement is provided products by the other party to the agreement and the agreement contemplates that the first party will place the brand name of its choice upon the products, either by repackaging or otherwise, and then proceed to sell, market, distribute and/or place the product in the stream of commerce, utilizing its new brand name. 17. The words "research" and "research department" refer to efforts, whether scientific or otherwise, to develop new and/or different types of products, processes or designs of pre-existing products and is meant to incorporate all efforts that specifically contemplated the possible alteration of products. 18. The words "medical department" refer to an individual or a section or group of individuals working for Defendants, either directly or in a contractual capacity, whose purpose was or is to provide guidance, assistance, or advice concerning any aspects of medical health, including but not limited to, the safety of Defendants workers and the safety, of-individualsaising products manufactured by the Defendant. Document#: 16774 3380.0001 -8- 19. The words "industrial hygiene surveys" mean surveys, tests, interviews, or other procedures taken or effectuated for the purpose of determining air quality, air contamination, dust content, safety of a facility or hazards at any site or facility. 20. The words "health hazards," or "potential health hazards" refer and relate to any injury, effect, damage, scanning, wound, impairment or disability of any part of the human anatomy, including but not limited to the lungs and lung linings. 21. The terms "test" and "testing" are used in their broadest sense, including but not limited to, studies of atmospheric dust samples, studies of the concentration of asbestos in such airborne test samples, studies of the lung i':r& conditions of workers (by x-ray or other means of medical surveillance), pulmonary function studies of workers, animal studies, pathological studies, industrial hygiene studies, risk assessment studies, cost-benefit analyses and any other studies on the product concerning health and safety required by any governmental agency. CORPORATE NAME 1. For each Interrogatory below, please state the name and last known address of each person answering it, including whether he/she is employed by Defendant and if employed by Defendant include job title, length of time employed by Defendant and a year by year list of all other positions, titles or jobs held .when working for Defendant. Document#: 16774 3380.0001 -9- ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection: Michael D. LaBate, II Insul Company, Inc. P.O. Box 151 East Palestine, OH 44413 President 1.1 Please identify all documents used, related to, or referred to in connection with the preparation of or answers to these Interrogatories and state the number of the Interrogatory and its subpart to each such document. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, it is difficult for this_ Defendant to respond to this interrogatory with specificity as various persons were consulted and the Defendant reviewed invoices, billing records and corporate record books. 2. Document#. 16774 3380.0001 Please state whether or not Defendant is a corporation. If so, please state: (a) Your correct corporate name; (b) The state of your incorporation; (c) The address of your principal place of business; (d) Your registered agent for service in the state of Ohio; (e) For each Defendant claiming that this Court lacks personal jurisdiction, list year by year the total amount of income received by the Defendant from -10- ANSWER: entities in Ohio, any and all years that Defendant, as defined, has been licensed to do business in Ohio, and any real property owned at any time by Defendant or its present or past subsidiaries. This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, Insul Company, Inc. is a corporation which was incorporated in the state of Ohio in 1960. The corporate address is 110 North Market Street, East Palestine, OH. The registered agent for service is J. Bradley Allison. 3 . State Defendant's complete corporate or business history, including dates of incorporation, mergers, consolidations, rei-ncorporations, and the like. Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs. In addition: a. if defendant or any of its predecessors or subsidiaries at any time purchased, assumed, or in any other manner acquired ANY of the assets and/or liabilities of any corporation or entity at any prior time engaged in any aspect of the placing of asbestos containing products into the stream of commerce or the insuring of asbestos related risks, then please state the following as to each acquisition: b. the name or description of each corporation, entity or assets acquired by Defendant, that entity's state of incorporation and principal place of business, its date of in/corporation, and the name of Defendant at the time of acquisition;" c. the manner by which each such corporation, entity or interest therein, was acquired (e.g., merger, consolidation, change of name, stock sale, transfer or purchase of assets or product line); Document#: 16774 3380 0001 d. the date of each such acquisition; - 11 - > e. the state in which each such acquisition was effected; f. the state law governing each such acquisition if specified by contract; g. whether Defendant became legally responsible for the past torts of each such corporation or entity; h. identify each document reflecting or related to the history and/or transactions(s) set forth in answer to this Interrogatory. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, Insui Company, Inc. was incorporated in the state of Ohio in 1960 and its offices are located at 110 North Market Street, East Palestine, Ohio and its manufacturing facility it also located in East Palestine, Ohio. Insui Company, Inc. has the following wholly owned subsidiaries: American Exo Corporation Corp. of Texas 1971 Cravens-Insul, Inc. 1972 D.Q.R. Packaging, Inc. 1992 Heather Metallurgical, Inc. 1976 Insui International, Inc. -1991 Lakewood Chemical and Supply Company, Inc. 1991 Ritetherm, Inc. -1992 Southern Exo-Chemical Corporation - 1983 The American Runner Company, Inc. -1981 Triple L Trucking Company, Inc. -1992 Valley Sportsman and Supply, Inc. - 1971 Wagner-Insul Company,-Inc.-- 1975 Youngstown Chemicals, Inc. -1978 4. Please state whether or not the Defendant has purchased, assumed, or in any other manner acquired any of the assets and/or liabilities of any corporation or entity (such corporations or entities being limited to those engaged in the mining, selling, manufacturing, Document#: 16774 3380.0001 -12- marketing or distribution of asbestos-containing products.) If so, please state the following: a. the name or description of each corporation, entity or assets acquired by Defendant, its state of incorporation and principal place of business, its date of incorporation, and the name of Defendant at the time of acquisition; b. the manner by which each such corporation, entity, ' or interest therein, was acquired (e.g. merger, consolidation, change of name, stock sale, transfer or purchase of assets or product line); c. the date of each such acquisition; d. the state in which each such acquisition was effected; e. the state law governing each such acquisition if specified by contract; f. whether Defendant became legally responsible for the past torts of each such corporation or entity; g. whether the acquisition concerned asbestoscontaining products. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, see response to No. 3 above. 4.1 For each corporation, other dm the answering defendant ("the entity"), that has at any time in the past been involved in the placing of asbestos containing products into the stream of commerce for which officers of the answering defendants corporation have also served as officers, directors or served in any managerial position while employed by the answering defendant, state: ! Document#: 16774 3380.0001 - 13 - ... i v,. : - V : -r ."ri.-'-S . v: r -7i-?s- 7i r M - . a. the name of the entity involved in the placing of asbestos products into the stream of commerce; b. the manner in which the entity was involved in the placing of asbestos containing products into the stream of commerce (i.e., mining, milling, manufacturing, distributing, installing, rebranding, etc.); c. the specific products placed into the stream of commerce by the entity year by year and by brand or trade name; d. the name, positions and a brief description of the responsibilities of the person or persons serving the answering defendant and the entity simultaneously including the positions held with the entity and with the answering defendant. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Moreover, this Interrogatory calls for a response which is not relevant to the locations at which any of the Plaintiffs worked and. therefore, is irrelevant, overly broad, burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving said objection, this Defendant incorporates by reference it response to Interrogatories Nos. 5 and 11. EVER SELL ASBESTOS 5. Has Defendant ever engaged in the mining, manufacturing, selling, marketing, installation or distribution of asbestos-containing products? If so, please state the following: (a) The name of the company engaged in the activity (whether it is Defendant, Defendant's predecessor, or Defendant's subsidiary); (b) As to each product mined, manufactured, sold, marketed, installed or distributed, please state the following: Document#. 16774 3380.0001 - 14- Document#: 16774 3380 0001 1 The trade or brand name. 2. Its identification number (model, serial number, etc.). 3. The time period it was manufactured, mined, marketed, distributed or sold. 4. its physical description including color, general composition, and form. 5. A detailed description of its intended use and purpose. 6. A detailed description of the type package in which it was sold, listing the dates of each type of package used, a physical description of the package, and a description of any printed material or trademarks that appeared thereon. 7. The percent of asbestos which it contained. 8. The percent of asbestos by asbestos type (amosite, crocidolite, tremolite, anthophyllite). (c) The time period during which each of these products were on the market; (d) The material components ingredients of each such productrgiving specific or approximate percentage both by weight and by volume of each material component ingredient (this interrogatory is not limited to the asbestos component of the product but seeks information as to the nature, weight and volume of non-asbestos ingredients, as well) of each such product; (e) How each of these asbestos-containing product can be distinguished from those of competitors; (f) A description of the physical appearance of such product; -15- (g) A detailed description of the intended uses. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant provides the following response. Instil Company, Inc. manufactured both asbestos and non-asbestos hot tops/rings from the early to mid 1960s to early to mid 1970s. The product, which was manufactured, was a gray limestone hot top and rings containing no identification number. The hot tops were to provide a liquid reservoir for molten steel, which would flow into the solidifying ingot cavity for an extended period of time. The rings were used in the base of the ladles to prevent the flow and when used, the ring was completely consumed and dissolved within the slag. Products were palletized and wrapped. The chemical composition of the hot tops were approximately 71 percent limestone, 21 percent silica, and approximately 3 percent fiber. The rings were approximately 81 percent silica, 9 percent carbon and, five percent asbestos. 6. Does Defendant or any of its subsidiary companies claim that any patent would cover any product listed in answer to Interrogatory No. 5? If so, please state the following: (a) The date of each patent; (b) The date same was issued; (c) The number of each patent application that is pending. ANSWER: Document# 16774 3380.0001 -16- This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant does not have a patent on the products listed above, but did have a patent which was issued in 1963. 7. Have any of the products listed above in answer to Interrogatory No. 5 been altered in chemical composition since first being marketed? If so, please state the following: (a) The trade name of each such product; (b) The date each such product was altered; (c) The nature of the alteration; (d) The reason for the alteration. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant manufactured both asbestos and non-asbestos hot tops/rings for a limited time period, and ceased manufacturing asbestos hot tops in the early to mid 1970s. 8. Have any of the asbestos-containing products listed in response to Interrogatory No. 5 ever been marketed, distributed, packaged, labeled, and/or sold by any other company or business? If so, please state the following: (a) The name and address of each such company. (b) The names and address of Defendant's distributors in Ohio, and Illinois since 1940. (c) The date of each sale. (d) The name of the person at each location with whom you primarily dealt. Document#: 16774 3380.0001 - 17- (e) A list of all asbestos-containing products that you sold to each location from 1945 to 1980. (f) The amount of each asbestos product sold to each location during this period. (g) Please identify all documents relating to this distributor for the particular location. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, no. 8.01 Has this defendant ever purchased asbestos containing products from any other defendant? ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not that this Defendant is aware. 8.02 If the answer to the preceding-interrogatory is yes, please state the following: (c) name each defendant from whom this defendant purchased any asbestos containing product; (c) list each product purchased from each co defendant; (c) list the dates of each purchase of asbestoscontaining products from each co-defendant. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not ^applicable. 8.03 Has this defendant ever sold asbestos containing products to any other defendant? Document#: 16774 3380.0001 - 18- >1 M; > V>r ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not that this Defendant is aware. 8.04 If the answer to the preceding Interrogatory is yes, please state the following: (a) name each defendant to whom this defendant sold any asbestos-containing product; (b) list each product sold to each co-defendant; (c) list the dates of each sale of asbestos-containing products to each co-defendant. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not applicable. 8.05 Has Defendant engaged in the manufacture and/or sale and/or distribution and/or marketing and/or supply and/or purchase and/or use of non-asbestos-, containing products for use in connection with temperatures above 125 Fahrenheit since 1930. If so, please state: (a) the date such activity began; (b) the years during which such activity took place; (c) the date when such activity was terminated; (d) if such activity was terminated, the reason(s) why; (e) the geographical area into which you claim the product(s) were sold, purchased, or used; Document#: 16774 3380.0001 - 19- (f) identify the organizational unit of defendant so engaged; (g) the site(s) at which each such product was manufactured; (h) the material, components of each such product, giving specific or approximate percentage both by weight and by volume of each material component of each such product; the temperature ranges for which each produces) was intended to be used; the products generic name; (k) the products trade or brand name; (l) the container in which the product was shipped (i.e., paper bags, cardboard boxes) including the size and amount of the container; (m) a description of any logos, writing impressions or identifying markings which appeared on the product, as well as a description of the package used, the dates that type of package was used, and any logos, product names, trademarks, etc. which appeared on the package; (n) whether the words "non-asbestos" or 'asbestos fibers" were used on the package; (o) a detailed description of the intended method of preparation and application of the product; (p) a description of the physical appearance of the product, including size, shape, color and texture. Document #: 16774 3380.0001 -20- ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, Insul Company, Inc. was incorporated in 1960 and manufactured hot tops and rings from that point in time through the present. Both asbestos and non-asbestos-containing hot tops and rings were manufactured and sold between the early to mid 60s and early to mid 70s to specific plants. Insul Company, Inc. sold its products out of Ohio, PA, WVA and Alabama. The products were manufactured in East Palestine, OH and Wampum, PA. The typical chemical composition of the products are attached hereto. The hot tops did not have to be altered cut or modified. They were set into the metal and placed on top of the ingot mold. The hot tops were grayish in color with a course texture. No logos, writing, impressions appeared on the product itself, but the products were palletized and wrapped. There was no marking relative to "non-asbestos or asbestos free". 8.06 Did Defendant ever market or distribute any asbestoscontaining product manufactured in whole or in part by someone else? If so, please state the following for each such product: (a) the name and address of the manufacturer; (b) the product s trade and brand name; (c) the organizational unit of Defendant who did so;~ (d) date(s) beginning, ending and during which the marketing or distributing took place; (e) whether the product was distributed through the same channels as those used for products manufactured by Defendant, and if not, please explain the exact channels of distribution; (f) identify all documents relating the marketing or Document#: 16774 3380 0001 -21 - ANSWER: distribution. This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, no. 8.1 Does Defendant have reason to believe that any of the asbestoscontaining products listed in response to Interrogatory No. 5 were used at any of the sites listed on Exhibit A, attached hereto. If your answer is "yes", please state: (a) The basis of your answer. (b) Please state which of Defendants asbestoscontaining products listed in Interrogatory No. 5 were used at each job site listed on Exhibit A. Document#: 16774 3380.0001 -22- ANSWER: This Defendant incorporates by reference its preliminary statement and objection. To the extent that the locations are titled or otherwise labeled in terms that are unfamiliar to this Defendant, same are objected to, but without waiving this objection, this Defendant admits to selling products to Armco Steel, Ashland, Kentucky; Armco Steel, Hamilton, Ohio; Armco Steel, Houston, Texas; Armco Steel, Middleton Ohio; Republic Steel, Canton, Ohio; Republic Steel, Cleveland, Ohio; Republic Steel, Warren, Ohio; Republic Steel, Youngstown, Ohio; Weirton Steel, Weirton, West Virginia; Wheeling Pitt Steel, West Virginia; Youngstown Sheet and Tube, Youngstown, Ohio. This Defendant, however, did not sell asbestos-containing products to all of these facilities. It is believed and therefore averred that both asbestos and non-asbestos-containing products were sold to Republic Steel, Canton; Republic Steel, Warren, Ohio; Republic Steel, Youngstown, Ohio; Republic Steel, Cleveland, Ohio and Youngstown Sheet and Tube, Youngstown, Ohio during the early to mid 1960s to early to mid 1970s. 8.2 For each company or business that Defendant knows may have marketed, distributed, installed, and/or sold, those products listed in response to Interrogatory No. 5, please state the following as to each job site listed on Exhibit A. (a) The name and address of each such company; (b) The date of each sale from Defendant to such other company; (c) The name of the person at each other company with whom" Defendant primarily dealt. (d) Names and quantities of the asbestos-containing products that you marketed, distributed, installed, and/or sold to each such company from 1950 to 1974. Document#: 16774 33*0.0001 -23 - -V''`-M .- 1 V-: > -v:;ivV --A-V'v . >' m- (e) Please identify all documents relating to the sales to each such company. ANSWER: This Defendant incorporates by. reference its preliminary statement and objection. Without waiving said objection, this Defendant does not have specific information relative to other corporations who may have marketed, distributed, installed or sold products to the companies listed in Exhibit A. 8.3 If you do not know any business that may have marketed, distributed, installed, and/or sold the products listed in response to Interrogatory No. 5 to any of the job sites listed on Exhibit A, please state the names and last known addresses of those companies who Defendant knows marketed, distributed, installed and/or sold their asbestos-containing products in Ohio from 1950 to 1974. For each of those companies, please state the following: (a) Name and address of each such company; (b) The dates of each sale from Defendant to such other company; (c) The name of the person at each other company with whom Defendant primarily dealt; (d) The names of the asbestos-containing products that Defendant marketed, distributed, and/or sold to each such company from 1950 to 1974. ANSWER: This Defendant incorporates by reference itspreliminary statement and objection. , Withoutsr waiving said objection, this Defendant knows that its major competitors were PMP, Foseco, Universal and Ferro during certain times but cannot state with any certainty that these corporations sold asbestoscontaining products in Ohio between 1950 and 1974. Document#: 16774 3380 0001 -24- 8.4 Does Defendant have records and/or any knowledge that reflects sales of their asbestos-containing products to any of the sites listed on Exhibit A, attached hereto? If so, please state the following as to each job site listed on Exhibit A: (a) The names and last known addresses of those people with such knowledge. (b) The location of such records. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, after reasonable investigation, this Defendant has sales records but does not believe they reflect sales of asbestos-containing products. 9. Did Defendant or any of Defendant's distributors, as listed in response to Interrogatory Nos. 8.1, 8.2, and/or 8.3 have sales representatives who specifically called, on the sites listed on Exhibit A, attached hereto, from 1945 to 1975? If your response is yes, as to each site listed on Exhibit A, please state the following: (a) The name and last known address of each such representative and whether they are still employed by Defendant; (b) The period of time they acted as your representative; (c) Their general responsibility as to each facility; (d) Whether that person is still alive; and (e) Any documents relating, referring or pertaining thereto. Document#: 16774 3380.0001 -25 - ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, the primary sales responsibility was provided by Michael LaBate, Jim LaBate and Dale White. There may have been other sales people that called on facilities listed in Exhibit A, however, at this time this Defendant cannot state with any certainty the identify of individuals that were sales representatives to those locations between 1960 and 1975. 9.1 Identify all managers and sales personnel responsible for your sales or installation of any asbestos-containing products in Ohio from 1930 to the present and state their position, last known address and the local or regional office through which they were employed. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, see response to No. 9 above. 10. Did Defendant ever have any division or subsidiary engaged in the contract business of applying or removing asbestos-containing products? If so, please state: (a) The name of each subdivision; (b) The full address of the home office and the date such subdivision or subsidiary was engaged in this contracting business; and (c) Whether said division or subsidiary conducted such business at any of the sites listed on Exhibit A, from 1940 to 1975? If so, please state the following as to each job site listed on Exhibit A: (1) The dates of such contracts; Document#: 16774 3380.0001 -26- (2) The specific asbestos-containing products that were used ore removed in each contract. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, no. 11. Did Defendant ever have any division or subsidiary engaged in the contract business of applying or removing asbestos-containing refractory? If so, please give the name of each subdivision, the full address of the home office and the date such subdivision or subsidiary was engaged in this contracting business. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, no. >' 12. Please identify by location and product produced, each plant in which products listed in your answer to Interrogatory No. 5 have been manufactured and/or assembled and the dates said plants have been in operation. 'f-m ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, East Palestine, Ohio from early 1960s through the present; Wampum, PA mid 1960s through 1984. 13. Has Defendant, at any time, entered into a "rebranding" agreement with any other company, either as a buyer or a seller, concerning any asbestos-containing products and/or materials? If so, please state: (a) The name of the company manufacturing the asbestos products under such agreement; Document#: 16774 3380.0001 -27- (b) The trade name affixed to such products; (c) The periods of time covered by each such agreement; (d) The volume (in dollars amounts) of each such transaction; (e) The purchaser of such products; (f) Does Defendant currently have in its possession any of the writings or contracts concerning such rebranding agreement? ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant never re branded any hot tops or rings which are the subject of this litigation. 13.1 Have you ever owned or operated a business or portion thereof which engaged in construction, erection or tear out of furnaces, pipes, boilers, turbines, lehrs, ovens, kiln, etc? if so, please state: (a) the same of said business; (b) the date of commencing business and cessation of business, if applicable; (c) type of construction or tear out performed; (d) state whether said business installed or supplied asbestos-containing products on the furnaces, pipes, boilers, turbines, lehrs, etc., i.e., gaskets, pipecovering, block, cement, rope, cloth, clothes, etc., containing asbestos, asbestos pipe, board, etc.; Document#: 16774 3380.0001 -28 - (e) state the trade name and/or manufacturer of any asbestos-containing product which you installed or supplied to any site on Exhibit A. (f) provide the dates for the applicable construction, installation or tear-out project. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, no. 13.2 Do you have within your custody, possession, or control any packages that presently or formerly packaged asbestos-containing products or were produced for the purpose of packaging asbestos-containing products contemporaneous with your manufacture sale or distribution of such asbestos-containing products? If so, provide the following: (a) a description of each such package; (b) the present location and custodian of each such^ package; (c) the date or approximate date on which each such package was produced. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, no. INFORMATION ABOUT DESIGN/TESTING 14. What is the name, address and job title of each individual who participated in the design and preparation of manufacturing specifications for each such product listed above in answer to Interrogatory No. 5? Document#: 16774 3380.0001 -29- : ... ..V f -: . - .V- ; "J 1j r" -'& --- ii ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection: Michael D. LaBate Joseph Greco James LaBate Jack Patterson 15. As to each product listed in response to Interrogatory No. 5, please describe how each product was to be cut, shaped, scribed, mixed and applied on the job. (In answering this question, give particular reference as to whether or not the materials were to be sawed or cut on the job, blown into confined areas, mixed with water in a cement or paste.) ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, the hot tops and rings did not have to be altered, cut or modified. 16. Based upon the material contents of the asbestos-containing products, the method of manufacturing, and the method of application, please state which products listed in Interrogatory No. 5 could be applied by a worker without creating dust. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, the hot tops and rings could be applied without creating dust. 17. Do any documents, including but not limited to, written memoranda, specifications, recommendations, blueprints or other written materials of any kind or character now exist relating to the design and preparation of the products listed in answer to Interrogatory No. 5? If so, please: (a) List each such written material or document; Document#: 16774 3380.0001 -30- (b) Identify the person or persons presently in possession of each such document; (c) State where each such document is located. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not that Defendant is aware. 18. Prior to releasing the products listed in Interrogatory No. 5 for sale and usage, were any tests (either animal or human) conducted on said products to determine potential health hazards involved in the use of, or exposure to, the materials and/or products? If so, please state: (a) The name of the products tested and the date of each test. (b) The name, address, and job classification of each individual who conducted such tests; (c) The results of such tests. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not that this Defendants aware.. 18.1 Prior to releasing any products for sale and usage (whether asbestos-containing or not), were any tests (either animal or human) conducted on said products to determine potential health hazards involved in the use of, or exposure to, the materials and/or products? If so, please state: (a) The name of the products tested and the date of each test. (b) The name, address, and job classification of each individual who conducted such tests; (c) The results of such tests. Document# 16774 3380.0001 -31 - - v. 'v : `v. - -?.- ' /-rv; 'N 'y,^ 3S V `:-Ak vv^ .-c.1 XS: V'?;3 -5 '7#r-V - .-r- . S3 ; ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not that this Defendant is aware. 19. Does Defendant have or control any documents, including but not limited to, written memoranda, specifications, recommendations, blueprints or other written materials of any kind or character relating to the testing of the products listed in Interrogatory No. 5 herein above? (a) Identify each such written material or document; (b) Identify each person who presently has possession of each such document; (c) State where each such document is located. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not that this defendant is aware. 20. Were any design changes or modifications made as a result of such tests listed in answer to Interrogatory No. 18 herein above? If so, please state: (a) The trade name of the product changed or modified; ,, (b) The nature of the change made and the date of such .changes, or modifications; (c) The name, address, and job classification of each person in charge of making a change. Document#: 16774 3380.0001 -32 - ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not applicable. 21. After releasing for sale, distribution or marketing the products listed in answer to Interrogatory No. 5, did Defendant conduct any tests (either on animals or humans) to determine potential health hazards involved in the use of said materials and/or products? (a) The names of the products tested and the dates of said tests; (b) The name, address, and job classification of each person and/or agency conducting said tests; (c) The results of said tests; (d) Whether, as a result of any tests conducted, any products were removed from the market; (e) The names of all products removed from the market as a result of said tests. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not that Defendant is aware. 22. Has Defendant.ever conducted or caused to be conducted any studies concerning the effects of the inhalation of asbestos dust and/or fibers on workers or other persons applying; using and/or working around any of the asbestos products manufactured, sold, distributed and/or relabelled for distribution by you or your predecessor? If so, please state: (a) The dates and nature of such studies; Document#: 16774 3380.0001 -33- (b) The names and addresses of persons conducting such studies; (c) The purpose of such studies; (d) Identify and list those persons to whom such reports were given and the date of such dissemination; (e) State any publication or other written dissemination of the results of such studies; (f) State the nature of any action to effeminate or minimize the inhalation of asbestos dust fibers; and (g) Attach a copy of reports based upon such studies. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not that Defendant is aware. INFORMATION ABOUT SAFETY 23. Before placing in the market the asbestos-containing products that Defendant, mined, manufactured, sold, marketed, installed or distributed on the market, did Defendant make or cause to be made, any studies to determine whether their asbestos-containing products would be hazardous to people? If so, please state: (a) The date ofsakLstudies; (b) What studies were done; and (c) The titles of each study. ANSWER: This Defendant incorporates by reference its preliminary Document#. 16774 3380 0001 -34- statement and objection. Without waiving said objection, not that Defendant is aware. 24. Please state whether or not Defendant ever conducted or caused to be conducted any tests in the field (where asbestos-containing products were applied, removed or utilized) to determine the nature and extent of asbestos dust and/or fiber exposure to insulators, applicators fellow employees, or other workers removing and/or tearing out asbestos-containing products, and/or other workers in the vicinity thereof? If so, please identify: (a) The date, place and nature of each and every test; (b) The particular asbestos-containing products to which each test applied; (c) The results of each test with particular reference to the number of asbestos fibers per cubic centimeter of air found at each site; and (d) The persons to whom the results said tests were given and the date of such dissemination. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not that Defendant is aware. 25. Please state whether m not Defendant ever obtained any knowledge concerning the.likelihood of asbestos being hazardous to human health. If so, please state: (a) When Defendant first became aware of the hazardous potential of asbestos dust and asbestos fibers; (b) The manner in which the Defendant, Defendants predecessor, or Defendants subsidiary companies Document#: 16774 3380.0001 -35- first obtained this knowledge and became aware of said hazards and from what source this information was obtained; (c) What information was disseminated within Defendant's company, or its subsidiary or predecessor regarding such adverse consequences or effects; (d) Whether any such information is still maintained by Defendant or its subsidiary or predecessor in any written form. (e) The name, address and job classification of the custodian of such information. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Interrogatory seeks "corporate knowledge" and thus, this Interrogatory is difficult if not impossible for Insul to answer. With waiving said objection, this Defendant cannot state with certainty when it first obtained knowledge concerning the likelihood of asbestos being hazardous to human health generally. 26. Please state when Defendant first became aware of the possible association between inhalation of asbestos dust and/or fibers and the contraction of asbestosis and cancers including, but not limited to gastrointestinal cancer, laryngeal cancer, renal cancer, lymphoma, lung cancer and mesothelioma. As to each disease or condition, please state the source of that. information, including a description of all tests conducted relative to the possibility of such a relationship. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Interrogatory seeks "corporate knowledge" and thus, this Interrogatory is difficult if not impossible for Insul to answer. Document#: 16774 3380.0001 -36- Without waiving said objection, this Defendant cannot state with certainty when it first obtained knowledge concerning the likelihood of asbestos being hazardous to human health generally. 27. Please identify all physicians, industrial hygienists, and other employees (including their names and addresses) who were employed, retained or otherwise engaged by Defendant for research, investigation or study concerning asbestos or asbestos-related diseases. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant did not employ, retain or otherwise engage physicians, industrial hygienists and other employees to research, investigate or study asbestos or asbestos related diseases during the time in which the product was . being manufactured. 28. As to each person who acted in a medical advisory capacity (as it relates in any way to asbestos) to Defendant, please list their name, the date individual acted in this capacity, and that person's current address and job title. answer: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not applicable. 29. Please state if any medical officer or industrial hygienist or medical consultant ever made at any time any recommendations and/or suggestions to Defendant pertaining to the risks or hazards to persons involved in the manufacture or use of asbestos products and, if so, please state when, by whom or to whom such recommendations and/or suggestions were made and the substance of each recommendation. Document#: 16774 3380.0001 -37- ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant did not employ, retain or otherwise engage physicians, industrial hygienists and other employees to research, investigate or study asbestos or asbestos related diseases during the time in which the product was being manufactured. After reasonable investigation, no. 30. Please state the scientific and/or medical periodicals to which Defendant, its medical department, research department, industrial hygiene divisions, engineering department or consulting physicians subscribed between 1945 and 1975? ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant did not employ, retain or otherwise engage physicians, industrial hygienists and other employees to research, investigate or study asbestos or asbestos related diseases during the time in which the product was being manufactured. Moreover, this Defendant did not have a medical department or an industrial hygienist division during the relevant time periods. Insul Company subscribed to Iron and Steel magazine for approximately 25 years, and 33 Magazine from 1983. And received Refractory Institute Newsletter Industry Trade Journal. 3071 Please state whether Defendant, its medical officer or industrial,, hygienist or medical consultant or physicians were ever involved in testing or received literature or correspondence from the Mellon Institute. Document#: 16774 3380.0001 -38- ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant incorporates by references its Responses to Nos. 27 and 30 above. Also, no. 30.2 Has any engineer, industrial hygienist or physician in your employ been a member in any professional group, trade group or any of the following groups: Asbestos Textile Institute National Insulation Manufacturers Association Thermal Insulation Manufacturers Association Quebec Asbestos Mining Association Asbestos Information Association Industrial Health Foundation Industrial Hygiene Foundation Iron and Steel Institute National Safety Counsel Refractories Institute Air Hygiene Foundation of America, Inc. Sprayed Mineral Fiber Association If the answer is yes, state the following: (a) The name of the group or groups in which the individual(s) were members; (b) The name and position individual(s) within the Defendant, as .defined, who were members; (c) The years the individual(s) were members of the groups; (d) Whether the Defendant paid the individual(s) dues or membership fees or reimbursed the individual(s) for dues or membership fees in the group. Document#: 16774 3380.0001 -39- ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, Michael D. LaBate and Michael LaBate, II were members of the Iron and Steel Institute and the Refractories Institute. Insu] Company, Inc. paid the individual dues. 31. State in detail what test, if any, Defendant ever made with regard to the quantity, quality, or threshold limit values of asbestos dust, fibers or particles to which workers were exposed while using, working with and/or around, knowledge and/or applying your asbestos-containing products. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not that this Defendant is aware. 32. For each test described in Interrogatory No. 3 1, please give the name of the person conducting the test, the date of the test, and attach true copies of any documents, including but not limited to, reports, findings or memoranda concerning such tests or studies. ANSWER: This Defendant incorporates by reference its preliminary natement and objection. Without waiving said objection, not applicable. 33. Please state the year that Defendant 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 Document#: 16774 3380.0001 -40- Hygienists and state the name of the employee/official of the company receiving such advice. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Interrogatory seeks "corporate knowledge' and thus, this Interrogatory is difficult if not impossible for Insul to answer. Without waiving said objection, this Defendant cannot state with certainty when it was first advised of the threshold limit values or maximum allowable concentrations of asbestos dust and total dust by the American Conference of Governmental Industrial Hygienists. 33.1 State whether this defendant at any time caused to be conducted on- any job site, any air sampling, dust counts, tests or other activities to determine air quality or worker safety. If your answer is in the affirmative, please indicate: (a) the date of any such air samples, tests, or activities; (b) by whom such activities were performed; (c) where such activities were performed; (d) the results of any such activities. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, during the relevant time- periods this Defendant did not conduct any customer job site air sampling. 34 Does Defendant maintain a library dealing with industrial hygiene, medicine, safety and engineering and/or research? If so, state: Document#: 16774 3380.0001 -41 - (a) The date each such library was established; (b) The location of each library; (c) The name(s) of the librarian(s) since 1930; (d) List all journals subscribed to by you concerning asbestos, industrial hygiene, medicine, safety, and/or engineering; (e) List all books and articles dealing with asbestos and asbestos-related diseases and the date acquired. ANSWER: This Defendant incorporates by reference its preliminary statement and objection, without waiving said objection, This Defendant does not have a formal library. 35. Did Defendant in the 1920's or 1930's commission, or participate in the arrangements with Metropolitan Life Insurance Company for studies at the Trudeau Foundation at Saranac Lake, New York, concerning the effect of inhalation or ingestion of asbestos fibers upon human and/or animal bodies. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, no. 36. When was Defendant first aware of reports of studies of the Trudeau Foundation at Saranac Lake, New York, entitled "Effects of the Inhalation of Asbestos Dust in the Lungs of Asbestos Workers" by A.J. Lanza, Assistant Medical Director published in the J. Public Health Report Vol. 50, No. 1, dated January 4, 1935 ("Lanza Report")? Document#: 16774 3380.0001 -42- ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, no. 36.1 Did you ever contract with Saranac Laboratories to study the hazards of any dust producing product manufactured by you (whether asbestos containing or not)? If so, identify by date and author all documents concerning or any way related to such study. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without vx\. waiving said objection, no. :?.- 32. Did you ever contract with Saranac Laboratories to analyze dust or products? If so, identify by date and author all documents concerning or any way related to such analysis. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, no. 37. Please state whether the Defendant at any time has been a member of any "trade organization" or "trade association" composed by other manufacturers, miners, distributors, and/or sellers of asbestos-containing products and, if so, please identify the name and address of'each such association or organization, the dates of membership, and the names of any publications issued or written by such association or organization. Document#: 16774 3380.0001 -43 - .r \v~Vi: V.. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant has been a member of trade organizations and association but cannot state with any certainty that members were manufacturers and/or sellers of asbestos-containing products. To the best of our knowledge, this Defendant was a member of the following groups: The Refractory Institute American Association of Iron and Steel American Mining and Institute of engineers Publication for the Refractory Institute and Metal Industry Trade Journal 38. With respect to each trade organization or association listed in answer to Interrogatory No. 37, please state whether the minutes of the group's meetings and any correspondence between the members of such groups concerning the hazards of asbestos exposure are available. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant is unaware of any minutes or correspondence relative to the hazardous of asbestos exposure. 39. Please identify by name the technical and trade association periodicals to which the Defendant subscribed, and state whether Defendant had knowledge of any articles being printed, or withheld from printing, in said periodicals pertaining to the potential hazards of asbestos. If so, please state the following: (a) The title of each such article; " (b) The periodical in which each such article was published; (c) The date each such article was published; Document#: 16774 3380.0001 (d) A detailed explanation of the reason for withholding any such article for printing; -44- v- k$ VY-1; -! r&:! (e) Produce documentation which refers, alludes or mentions articles which were withheld for publication. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, see Response to Nos. 30 and 37 above. 40. Please state whether, prior to 1975, the Defendant sponsored, or attended any meeting, seminar, conference, convention or legislative hearing where the subject of occupational health and exposure to asbestos was discussed and, if so, please state the date and place of such meeting and the name and address of any speakers or participants. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant is not aware of any meetings, seminar conferences, conventions or legislature hearings concerning asbestos which were attended by employees of this Defendant. WARNINGS/SALES PROMOTION 41. As to each product listed in response to Interrogatory No. 5, please state whether Defendant, at any time, published and/or distributed any printed materials, including but not limited to brochures, pamphlets, catalogs, packaging s or other written materials of any kind or character that contain any warnings, cautions, caveats or directions concerning the possible health effects of the products on a person.' If so, please' state as to each product: (a) The name of each relevant product; (b) The wording of each such warning; (c) A description of each such printed material; (d) The method used to distribute the warning to persons who are likely to use the products; Document#: 16774 3380.0001 -45 - (e) The date each such warning was issued; (f) Whether any warning accompanied any of your asbestoscontaining products' sales literature, handout or pamphlets; (g) Please attach a copy of the warning and date said warning was issued; (h) The name, address, and job classification of each person who presently has possession of the above-described documents; (1) The name or names and addresses of the company who provided, produced, or manufactured the boxes or containers on which the warning appeared and dates these boxes with the warnings appeared. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant's products did have warnings, however, none of the warnings concerned asbestos. 42. Has sales material been prepared by Defendant or its agents for purposes of marketing or advertising the asbestos products listed in answer to Interrogatory No. 5? If so, please state: (a) The name and address of each person or entity who prepared same; (b) The name, address and job title of each person who presently has possession of same; (c) The date same was prepared; (d) The media used to disseminate the sales material. Document#: 16774 3380.0001 -46- ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not that this Defendant is aware. 43. Has any written material of any kind or character been prepared by Defendant, Defendant's predecessor or any of Defendants subsidiary companies or their agents indicating how the products listed in answer to Interrogatory No. 5 should be used or maintained by the ultimate user or those working in facilities or at job sites where the product was used, installed or removed, including, but not limited to, those sites listed on the job site list attached Exhibit A. If so, please state the following: (a) The name, address and job classification of each person who prepared same; (b) The name, address and job classification of each person who presently has possession of same; (c) The dates and manner in which said material was distributed to purchasers of the products in answer to Interrogatory No. 5. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant is unaware of any documents which .exists relative to the use of its asbestos-containing products. 44. Was any written material of any kind prepared by Defendant and distributed to those individuals listed in response to Interrogatory No. 9? If so, please state the following: Document#: 16774 3380.0001 (a) Identify the written material by content and date; -47- (b) To whom was it delivered. (c) Does Defendant contend that asbestos-containing products can be manufactured so as to eliminate all potential health hazards to persons working with or around, installing or applying same? If so, please state the following: (d) The date that Defendant first determined that another product could be used in place of asbestos; (e) The chemical of the substitute; (f) Whether the substitute is suitable for the purpose for which they are to be used; (g) Whether Defendant used the substitute for asbestos to 1971; (h) Whether Defendant ever used the substitute for asbestos for high or low heat insulation. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, Moreover, This Defendant objects to this interrogatory as to the working environment and/or condition at the defendant's manufacturing plant. Employees' exposure during the manufacturing process has no relevance to any danger or hazard that may have existed with respect to end users of the products. But without waiving the objection,-nofcasbestos.hot tops were also being manufactured during-Tthe same time period and continued to be manufactured. 46. Did Defendant give any warnings to any individuals at the sites listed on Exhibit A, including any individuals who owned, operated, or managed the facilities at the sites listed Document#. 16774 3380.0001 -48- on Exhibit A, regarding the potential health hazards of any product listed in response to Interrogatory No. 5. If yes, please state: (a) Name of person most knowledgeable about this communication. (b) Name of person at the sites listed on Exhibit 1, attached hereto most knowledgeable about this communication. (c) Dates of each communication. (d) Contents of each communication. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not concerning asbestos hazards. KNOWLEDGE OF PREVIOUS INJUREES 47. Did any person prior to 1970, file a claim against any Workers' Compensation carrier covering Defendant alleging that he or she contracted a disease as a result of exposure to asbestos? If so, please state the following: (a) A list of each such claim by claimants name, date filed, the caption and jurisdiction involved; (b) The disease alleged in each such claim; (c) A brief summary'of the disposition of each such claim; and (d) The name, address and job classification of the person or persons having custody of the records pertaining to each such claim. Document#: 16774 3380.0001 -49- '-=-\Sv-Sr V. ;y. W-yj * v/yy ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, no. 47.1 Please identify all documents concerning or in any way related to any decisions made by you to cease manufacturing asbestos-containing products. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant is unaware of any documents which relate to the decision to cease manufacturing of asbestos-containing products. 47.2 Has any person or company from which you purchased asbestos-containing products ever issued a recall of their products or taken any action to take those products off the market after said products were in your possession? If so, provide: (a) the date of said recall; (b) the name of the company which issued the recall; (c) a copy of the recall. ANSWER: This Defendant incorporates by reference its preliminary statement and objection.- Without waiving said objection, not that this Defendant is aware. 47.3 State what action, if any, you have ever taken since 1930 to minimize or eliminate any risk of occupational.disease or pneumoconiosis to those at any time engaged in the manufacture or production of asbestos-containing products. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Moreover, this Interrogatory calls for a response which is not relevant to the locations at which any of the Plaintiffs Document#: 16774 3380.0001 -50- y.i \-i<: ;:V Mi i " worked and therefore, is irrelevant, overly broad, burdensome and not reasonably calculated to lead to the discovery of admissible evidence. 47.4 State what action, if any, you have ever taken since 1930 to minimize or eliminate any risk of occupational disease or pneumoconiosis to those at any time engaged in the use, as distinguished from the manufacture, or exposed to the use of asbestos-containing or industrial insulation products or who were otherwise exposed to asbestos-containing or industrial insulation products. (a) describe such action; (b) state when such action was taken;\ (c) state what written material exists related to such action; (d) state the names, job titles and last known address of the individuals who undertook such actions. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Moreover, objection as Interrogatory No. 47 is unintelligible. Without waiving said objection, this Defendant provided warnings relative to the risk of exposure to silica dust. 48. Did Defendant.receive notice prior to 1968 that any person was claiming injury as a result of using asbestos products manufactured, sold, installed, and/or distributed by Defendant? If so, please state: Document #: 16774 3380.0001 (a) The name and address of each claimant; (b) The date of notice of each claim; -51 - (c) A description of the claim; (d) The type of injuries allegedly sustained; (e) The name and address of each attorney representing the individuals making such claims; (f) The style and court number of each such claim; (g) The resolution of each claim. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, no. 48.1 Describe the method by which you have maintained records concerning the manufacturer, sale, supply, distribution, use, advertising, delivery and/or installation or tearout of each of asbestos-containing products. For each description provide the following: (a) each present and former company or corporate department, division or subdivision responsible for maintaining such records; (b) the manner in which the records are kept (e.g., boxes, computer tape, microfilm, etc.); (c) the inclusive dates of any such manufacturer, sale, supply, distribution, use, advertising, delivery, and/or installation or tear-out which such record keeping system covers; (d) . r the present location at which all such records are maintained; (e) the identity of each person employed by you at any time from 1930 to the present who is or was responsible for the collection and maintenance of such records. Document#: 16774 3380.0001 -52- ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant has a document retention program in which documents are maintained up to seven years and then destroyed. The invoices, sales records from early to mid 1970s have been maintained due to this litigation. Said boxes of invoices are in the custody of counsel representing this Defendant. 48. State whether any records concerning the manufacture, sale, supply, distribution, advertising, delivery, use or installation or tear-out of asbestos-containing products have been destroyed or discarded and if so, indicate: (a) the date and location of such destruction or discard; (b) the custodian and location of such records prior to their destruction or discard and the identity of each employee, representative, official or agent who ordered, authorized or supervised such destruction or discard. ANSWER This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, see response to No. 48.1 above. 48.3 For all documents, other than invoices, work orders and/or purchase orders, which relate to matters relevant to the all the preceding interrogatories: (a) Is there any kind of index for the documents? (b) How many pages is the index of documents? (c) How many documents are referred to in the index? (d) Is the index maintained in electronic format (i.e. database, word processing or other computerized format)? Document #: 16774 3380.0001 -53- (e) What manner of electronic format is used? ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant has had at its counsel's offices' invoices and sales records, etc. 48.4 For all invoices, work orders and/or purchase orders, which relate to matters relevant to the all the preceding interrogatories: (a) Is there any kind of index for the documents? (b) How many pages is the index of documents? (c) How many documents are referred to in the index? (d) Is the index maintained in electronic format (i.e. database, word processing or other computerized format)? (e) What manner of electronic format is used? ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Moreover, objection in that this.Interrogatory requests information relative to attorney work product. This Defendant does not maintain an index for relevant documents. PLAINTIFF/DECEDENT 49. Has Defendant obtained statement from any witnesses including the Plaintiffs? If so, please: Document#: 16774 3380.0001 -54- (a) list each witness who has given a statement and the name, address, and job title of each person having custody of any such statement. ANSWER This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant has not obtained any statements from any witness other than deposition testimony taken in this litigation. 50. Do you contend that the Plaintiff/Decedent improperly used those products listed in response to Interrogatory No. 5? If so, please set out in detail in what respect the product was improperly used. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Moreover, objection in that it is overly broad and burdensome. Without waiving said objection that this Defendant has not had an opportunity to depose each and every Plaintiff to determine if and how they used the product manufactured by this Defendant, and thus, cannot respond completely to this Interrogatory. 51. As to the sites listed on Exhibit A, and as to each Plaintiff/Decedent, please state whether Defendant contends that there was any substance other than asbestos which contributed or caused Plaintiff/Decedent's injuries. If your answer is yes, please state the following:' (a) The facts upon which you rely; (b) The identity of the sources upon which you rely which substantiate these facts. Document#: 16774 3380.0001 -55 - ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Moreover, objection in that it is overly broad and burdensome. Without waiving said objection that this Defendant has not had an opportunity to depose each and every Plaintiff and to review all medical documentation to determine if and how they used the product manufactured by this Defendant, and thus, cannot respond completely to this Interrogatory. RESPIRATORS 52. Would any respirator, mask or other breathing devices prevent inhalation of the asbestos dust and fibers contained in products listed in answer to Interrogatory No. 5? If so, states (a) When the respirator was sold; (b) A detailed description of such respirator or other breathing devices, including name of manufacturer and model number; (c) The basis of your claim that such respirators or other breathing devices will prevent the inhalation of such dust and fibers; (d) Identify any tests performed regarding the efficaciousness of such respirators and other breathing devices in preventing the inhalation of asbestos dust and fibers including date, title, author and number; (e) List all documents which mention, allude or refer to tests performed on breathing devices which prevented the inhalation of asbestos dust and/or; fibers. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Document#: 16774 3380.0001 -56- 53. Does Defendant expect to call expert witnesses at the trial of this case? If so, please state the following: (a) Their identity, last known address; (b) The subject matter on which the expert is expected to testify ; (c) The expert's specific conclusion, and specific opinions and the specific basis therefore; (d) The expert's qualifications to render the opinions set forth above; (e) Whether any person identified in sub-paragraph (a) above has provided a report or other documentation to you, and if so, identify such document or report; (0 Identify all documents that you have provided to each person identified in response to sub-paragraph (a) above; and (g) Describe in detail the education and work history of and identify any books, treaties, article, published and unpublished reports, studies or other scholarly works authored by any individual identified in response to subparagraph (a) above. Alternatively, in lieu, of said response, attach a copy of a resume or curriculum vitae and a list of publications to your answer. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, this Defendant will most likely call a witness at trial, however, has not determined the identity and/or content of the testimony that will be offered. This Defendant will supplement the response as the information becomes available. Document#: 16774 3380.0001 -57- 54. Please state the name and last know address of each expert witness who is not retained or employed for that purpose who is an employee of Defendant and will render an opinion within his expertise at the time of trial. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, see Response to No. 53 above. 55. Does Defendant admit that service of process was properly had on it in these cases? If not, please state why. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, yes. 55.1 For each and every affirmative defense asserted in the answering defendant's Answer to Plaintiffs' Complaint, the Cross-Claims or Counter-Claims of any party against this answering defendant state: (a) the facts upon which the answering defendant relies for each and every affirmative defense; (b) each and every document which will be offered to prove each and every affirmative defense; and (c) each and every witness who will testify in support, of each and every affirmative defense. (d) the substance and subject matter of the anticipated testimony of each witness identified in the preceding response. Document #: 16774 3380.0001 -58- ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, investigation and discovery are continuing and this Interrogatory will be supplemented as information become available. 56. Does Defendant have policies of insurance that might cover the claims that have been made by the Plaintiffs herein? (a) If so, please list the name of each insurance carrier who may have coverage, the amount of such coverage, and the dates of each such policy. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, yes. Travelers Property Casualty Company, formerly, Aetna Life and Casualty Company. The specific policy information is unavailable. 56.1 Have you ever been involved in any litigation concerning potential insurance coverage for asbestos products liability matters? If so, please state: Document#: 16774 3380.0001 (a) the case caption, court and date of filing of each case in which you have been involved; (b) whether you were plaintiff or defendant; (c) a brief statement of the issues; (d) identify by date, author and recipient(s), (including recipients of carbon copies) all documents listed as exhibits by either party in this litigation; (e) identify by deponent and date all individuals who were deposed in these cases; -59- (0 identify by date, author and recipient(s) all documents that have been placed on a protective order in such litigation; (g) identify all expert witnesses retained for use at trial in any of the above s litigation by name, address and telephone number. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Without waiving said objection, not that this Defendant is aware. 57. Please state the name and address of each person who has knowledge of relevant facts regarding claims and defenses of this lawsuit. ANSWER: This Defendant incorporates by reference its preliminary statement and objection. Moreover, objection in that Interrogatory No. 57 is overly broad and ambiguous. Without waiving said objection, this Defendant has not determined the identity of individuals it intends to call regarding the defense of this lawsuit other than individuals listed in these Answers to Interrogatories. 58. State the last date that this Defendant sold, distributed, manufactured, installed, and/or otherwise placed asbestos-containing products into the stream of commerce. ANSWER: Early to mid 1970s. Document#: 16774 3380.0001 60- Respectfully submitted, BARON & BUDD A PROFESSIONAL CORPORATION The Centrum Suite 11 00 3102 Oak Lawn Avenue Dallas, Texas 75219 (214) 521-3605 FAX: (214) 520-1181 STEVEN D. WOLENS Texas State Bar No.: 21847600 -AND- BARON & BUDD A PROFESSIONAL CORPORATION 43-B New Garver Road Monroe, Ohio 45050 (513) 539-2912 FAX: (513) 539-2907 BRUCE CARTER Ohio State Bar No.: 0059084 RESPONSES BY: ZIMMER KUNZ PROFpSSfOfojAL CORPORATION BY ,/ 2^: ( 3jNI"\L^I^GINO,/ESQUi Attorney/ for'Defendaht, / Insul Company, Inc/ Document#: 16774 3380.0001 -61 - EXHIBIT A BARON & BUDD SITE LIST Anchor Hocking Glass, Lancaster, OH Anchor Hocking Glass, Plant One, Lancaster, OH Anchor Hocking Glass, Plant Two, Lancaster, OH Armco Steel, Ashland, KY Armco Steel, Hamilton, OH Armco Steel, Houston, TX Armco Steel, Middletown, OH Armco Steel, Muskingham County, OH Armco Steel, Washington Courthouse, OH Babcock & Wilcox, Canton, OH Blaw Knox Corp., Wheeling, WV Buckeye Steel, Columbus, OH Cardinal PS/Brilliant PS/Tidd PS, Brilliant, OH Centre Foundry, Wheeling, WV Champion Paper, Hamilton, OH Contours, Inc., Orrville, OH Cooper Tire, Findley, OH Dayton Walther, Portsmouth, OH Harrison PS, Shinnston, WV Ideal Foundry, Newton Falls, OH Jones & Laughlin Steel, Youngstown, OH Jones & Laughlin Steel, Cleveland, OH LTV Steel, Cleveland, OH LTV Steel, Jennings Road, Cleveland, OH LTV Steel, East 45th Street, Cleveland, OH LTV Steel, Campbell Road, Cleveland, OH LTV Steel, West Third Street, Cleveland, OH" LTV Steel, Massillon, OH LTV Steel, Warren, OH LTV Steel, Youngstown, OH LTV Steel Briar Hill Works, Youngstown, OH LTV Steel Campbell Works, Youngstown, OH Lucans Steel, Massillon, OH Martin Marietta, Woodville, OH McComber Steel, Canton, OH Meade Paper, Chilicothe, OH Republic Engineered Steel Inc. (RESI), Canton, OH Republic Steel, Canton, OH Republic Steel, Eighth Street Plant, Canton, OH Document#: 16774 3380.0001 -62 - Republic Steel, Plant A, Canton, OH Republic Steel, Plant B, Canton, OH Republic Steel, 3 Shop, Canton, OH Republic Steel, 4 Shop, Canton, OH Republic Steel, Berger Plant, Canton, OH Republic Steel, Culvert Division, Canton, OH Republic Steel, Stark Division, Canton, OH Republic Steel, Cleveland, OH Republic Steel, Massillon, OH Republic Steel, Union Drawn Steel, Massillon, OH Republic Steel, South Division, Massillon, OH Republic Steel, Warren, OH Republic Steel, Youngstown, OH The Timken Company, a.k.a. Timken Roller Bearing, Canton, OH The Timken Company, a.k.a. Timken Roller Bearing, Navarre Road SW, Canton, OH 'Me Timken Company, a.k.a. Timken Roller Bearing, Dueber Avenue, Canton, OH U.S. Rubber, Clinton, OH U.S. Steel, Canton, OH U.S. Steel, Clairton, PA U.S. Steel, McDonald Works, Youngstown, OH U.S. Steel, Ohio Works, Youngstown, OH U.S. Steel, Homestead, PA Washington Steel, Massillon, OH Weirton Steel, Weirton, WV Wheeling-Pitt Steel, Allenport, PA Wheeling-Pitt Steel, Beechbottom, WV Wheeling-Pitt Steel, Benwood, WV Wheeling-Pitt Steel, Yorkville, OH Wheeling-Pitt Steel, Martins Ferry, OH Wheeling-Pitt Steel, South Plant (Mingo Junction) Wheeling-Pitt Steel, East Plant (Follansbee, WV) Wheeling-Pitt Steel, North Plant (Steubenville) Wheeling-Pitt Steel, Monessen, PA Youngstown Sheet & Tube, Youngstown, OH Document #: 16774 3380.0001 -63 - CONSUMABLE CU2 TypicAl. Chmitpy CaCOg S i Op Fe203 A1 jOq NapO MgO <S3-?W 20-30V. < l.OX < 1 . O'/. < 1 -.(IX< 1.0*/. I I. i oM Uleipht Hi oh Exo-J Typical Chemistry ai203 A1 S i 02 LOI CaCi 35-40*/. 23-27*/. J 5-2(1*/. 9-137. < 5.07 V OXYTHERM LSX (Hot Toddino Compound) Typical Chemistry A1 ?03 A1 S i O2 c MgCJ CaO Fe2C,3 K?0 n*2q Dens j ty -- -- 37-41*/ 20-22*/. 6-12/. 7-1\'A A 2-4*/. < 3.0*/. < 1 . W. < 1 .0*/. 32-3/ #/Kt3 l DCUt * ------ In*ul Coapany,loc. uiit,nti* *rnr com 11C North Market Street, East Palestine, OH *M13 Tdj( tieriil data sheet covert the (cllouing product!: LI.k'T. HIGH EX0/EI0 1PC/HEAVY DUTY EXO*3/HEAVY DUTY EX0*32 ChlHICtl fUMir 04 4400UCT TYPI EXOTHERMIC FIFER HOT TOF/SLEEVE SECT ION III COMPOSITION CHinlCAl MHI X COMAOM ere* y /m cam - > k. STRATTON (2lfe) <2d>-M5l . *v F726/E5 (REV. 1E/E/E5) MtMMl Vl (IPOIUAI ACIIH TwV V / CELLULOSE :i-ie CALCIUM SILICATE il-ie PHENOL FORMALDEHYDE ! 1-16 alumna :ie-3e ALUMNur. : i c-3C UREA FORMALDEHYDE 11-1C ALUMINA SILICATE !1B-3B CRYOLITE !1 -1B silica(crystalline):i-ie ; I PAPER PULP t WOLLASTONITE t RE SIN 1 ALUMINA :ALUMINUM :RES 1N !CERAMIC FIBER ICRYOLITE iSJLICA ; ! Y!9BB4-34-4 ; Y1659Y7- 17*3 ; ----------------- !1Bag/a cube! N !1Eg/1 cube t N ;k: naif :y: i3^A-2e-1 : Y 17429-90-5 !15'gj/ cube ; --------. ------ llBrc/t ! 1 e; / !1 Bag/a cube! cube! cube ! N N N :k: naif ; --------- ; --------- !N : Y ; t59?7-17-3 ! notes page:2 : IN'. 15C96-52-3 : notes page!2 :n 1 Y:14BeE-6B-7 i Table 2-3 !36n/a cube! N ; ; : tOuart: * 3*. Regulated at per listsi OSHA 2<?CFR 1 *? 1C, subpart 2( AC61H,HHS/NTPi l 1ARC. SECTION IIIi PHYSICAL AND CHEMICAL DATA 02k)M POINT vfcppp pftieiuKi N/A I1 RKLT1NI fCJKT n/a 1 % VDkATUI N/A : rtciric NNNVJTV .5-,75 1 VtrOA DINIITY H/A IVM0NAT1DN MATI K/A SDI.Uell.XTV IN --T" Slioht ... Fjis. W'*T BO" T*n-6roNn~No Ddor 'ivr'Ff^ and'eVplosidw-uazard "data___'.............. iii~~ vliali3~Jwi~to-Tp" **aaV/*i"i~ ~ti u~i nJ to not use oiler, Material sill tuttiin coabustior,. Product ail) theraite. <">. fii riMiiaTmcciSu*' ----- " ' ----- -- - >- ,*iteri chioriMteo hyerccarpons. Avoid dust clouds. cFiivruesliogiohaterws imshoioulTd us~e~ KI~OSK ippr"oved....s.e..l.i.-.c.o..n..tiined breathing apparatus----end lull piro tei ctive clothing. Obtains cnciiibie eetdl (All. SECTION Vs HEALTH,FIRST AID AND MEDICAL DATA 0r1^rRSHRtlS1 i (Cm MB CHRDKi: HEALTH EFFECTS MU EFFETE OF OVER EXPOSURE 7*iil^#Tx5 ~~ ~ ------ ----1 " ....... .. 1 1 i- hiy cause respiratory trict irrititior.. Pre-existing aecical concitions tiy be aggravated ty eiposurt: SotcHically, tronchiil hyper reictivity end enrorue oroncnial or lunc diseese. 1--C1TIC~~ 11 ' --------------------------------------------------------------- -- hiy ciuse gastrointestinal disturbances,.. Syap.toai..aay.inciuoi irritation, niusei, voaiting, ind diarme*. Ccr7yohte is toxic by inoestior.. ----- -------- ----------------------------------- ---- --------------------- htniv "c'ause irritation :th---o--r-o-l-o-n-o-e--:--c-o--n-t-a--c-t-.-------------------------------------------- ...-------------- irritant 'mmrrnnn OF ENTRY FIRST Alt ItfttttTlD* T>MA-4TT&i fcetovt otrsoTi to irtsf. i\r me consult pf-rs:;t;.. ______________________________ till phYsriir.. Alt ~~ ` - -- . - _________ ______ .. basr. eicostd areas ith soap and attr. being a urn creu or 1 otior. alter aashinc aay be nelt'^uK rfi "* Fiust. vitt. large apur,i* ci *r.er. Seel tt:::al a*, tendon irritation ot'siste. `*c f-'mt - j-a * 4 fast * ION Vi l Uurvwoivii i ^, vuTim'SccS Nter, eiteliet, Miiuiftf egett, halaftMted ergenici. tifwrNTTiM 11 1 -- ............ I- --i Urtoe dioxue, tertoe MMsidt, phenols, tarneldehyde end imUmo. Kydroete fee. ciKTUwrrswn----------------------------------------------------- to tot use nth tolIce etUl hee deep. J SECTION VI11 NOAdMH, ITftMN M( NmKJM Lp cry. STORAGE, HANDLING AND USE PROCEDURES iiOAAAL WM Utp dry end avoid breathing dust or tunes. ir?pTc%'TSini*t454*5f`uS2i'ii*i?uj koreel then-up procedures. mih iT>o*a. wtwor*'"' *' ........... .. ............... - -- -- feury or lnontralt m accordance itfa iot.il, state and federal regulations. SECTION Vlllt PERSONAL PROTECTION INDORSATION____ H above 2 Fibtrs/cc e K1QSH approved respirator should fct used. Alter product has been subjected to lfcitr crystalline silica .ay bt loretd. bet KIOSK approved respirator. ______________________________________ 5 5TKiyT6S7TocJ"'' Aoequate ventilation to teep dust conctntretioo helot TLV. vcdT)i.*Tib*7 .............. ............................. Aflfpuitt ventilation te keep dusi concentration belo* TLV. * SAftt AS ABOVE horee] ort gloves. n NDTicrifid ............. ...............................----.................... ...... ................. --Llt"L" feo^oles or safety classes oith side shields. Do not war contact lenses. otnk* umwJir*"""" ........................... .................. .................... .............. Loop sleeved, ioost -fitting clothing. ___ m*sa *S*"*JTiStESUScT'of cetSiI**Tcr *5Iije5n #*? *** c*Staci *ii* hvoie oust, inhalation, ingestion, tyt contect. list aoequate ventilation. bo not etcetd lLV. - - ... miui^ ittp cry. Te *t TMUUI 1* SECTION IXI SPECIAL PRECAUTION EiJiti...................... -- i. b*sh iorl ciotnes seperettly end rinst .ashing eechint liter ust.* ** hinintiie potentiel For transter tc strut clothes, ttc. NOTES _ ____________________________ Urrtotly there ere no toow chronic hteltk eFFects io husens Frot long tere ecposurt te ttraic Fiber. Anital studies here been contredictory iith soet studies indicating e potentiel tenctr baiart. Further enieel end hueen studies ere plenned. Fending these results, strict -edherence te recoeeended seFe tori practices is advised. **TLV * 2.5tg/e cube es F in eir. t** IfliKMliM 4M FOR COMPANY USE :.apMt t #m dtt e tea*. # e m Mf(M r. If. Mite * ..erenty .i th t* tf* eciumcr d A2P : :NO t*kLi:hLl nponhat on pound % .ctHMie * tM tilt * mr t# tnlUelltf N/A - *OT 4*LIC4iC AF EJY_ DATA BHEE - ^* jV "i^e ~f*o "product lnsul Coepany, Inc. * t IITAHT.ITATI, AM* ItA COIII rth Market Street, East Palestine, DH 44413 CONTACT CARL A. STRATTOM <2U) 426-4IS1 rONSUHABLE INIMICAL FAMILY OM PAOftOCT TVFI lONSUMABLE/EIOTHERMIC HOT TOP CHtniCAL NAM SECTION III COMPOSITION COnnON NAM V/N CAM C.S< rev. n/ie/ee --A--l-AartMwI~V*I UAOlURt UMT AC* I N TWA "tlXUA T /MOIBN* 1UICA(CRYSTALLINE! 111*30 lALCIUH CARBONATE 1 >61 11 i <a 1a ei ii ii iI p,r 1 SAND/S1L1CA FLOUR Y: 14808-68-7 I Table Z-3 i.leg/a Cubel Y* iLINESTONE 11 ! aa 1a ii ia a< il Y11317-63-3 1 :i *t a* aa ea a1 a aa aa aa i1 i: iiii -------- 1 lBag/e cube N t i* aa ai aa a1 alai ti iiii 0BHA 29CFR HI. lubpart Z; ACGIH,HH8/NTPj l_IARC. 0 IQ POINT v-1" *" K/A IVMPOANTION NATO Jj / J HILTIMI POINT JJ/fl J * VOLATILI If VOLUni IGLUilklTY IN HATKN ^eg. JOPOCIPIC NNNVITV J. 5~2.8 JVNPON HNIITV ^/A *!!!!!!!!!!.!!! *! Srey .Solid-No Odor ................................ ^"cfioN ~ivVVi^'7^'x^osToN"HAZWD'data <jA* WiiT" *|(/" " (MIMA? ~M~ iruwMMJ klNin ifiiKiiiririHU---------- :---------U fire haiard. mciAk. fii flfTim~FSciiSNHr nroid breathing turn. .ir^nSToi'WttiriUk. " 1 "" OM. BEET X_0N_V l__HE*U-TH,_F_I RST AID AND MQJICALJDATA tlRMY MUTE ll) f ETTRT "* Tia OTE Ml OtUlC HEALTH EFFECTS MB EFFECTS OF OVEI E1P0SURE Ur cause respiratory tnct irritation. Pre-eiistiog tedical conditions tay be aggravated by uposurei -ptcifically, bronchi*! hyper meting and chronic bronchial or lung disuse. (Silicotis) _____ jy cme gastrointestinal disturbances-Syaptoas:wy include irritation, nausea, voeiting, and diarrhea. K2*` *`*~*~*~--................................................................................. --*---------------------- -- L-..------ ------ -- -------------- ------ - --------------------- * ay cause irritation eith prolonged contact. __ ___ _ ___ rrilint ^HTKT^^*' I F1R*T * MCL IHFMMTICM ------------------------------------ ------------------------------------------------------------.------------------- ** r!l*S!.iLllll!L!ir ^^Consult physician._ _ _ _ _ _ _ ___ _ ,, _ __ ,, . ..yticim. __ ___________ ini eiposed area ith soap and eater. tlf>9 f ltn_creai or lotion alter eashing aajf be heljlul. _ ,4^er- Seet aelical attention H irritation persists r" *o ff mt'Uncim ** jui~' mv. > SECTION VI* TUl|Tf 0*811 gei5?Sf5Krfn5ifiii*ti*f aveur cessivi heat and Htlf. _jRRQBIVITY AND REACTIVITY N.MIUni MILL MI OCCUR * >m* " * U. a oxide and carbon dteude gas. Hrcrogrn gas, silicon tetrafluoride. eOMTtlM^-TB-Weil* *~ fro not use m th sol ten Mill *heo dup * SECTION VI11 BTORA0E, HftNDLINa^^ANO^l^E^PftOCEDURES^ MfrtfWH. ITMM4 Ml HMKIIH Keep Pry. Uepdry and avoid briathisg dust or ion. UH"5"W liSi'H'lUi'if Liitlln aaluJ Clsaa-up procedures dttifotd 1 uaiaiit Out generation tnd eipoture. MirilWMiC MtSm**-* * " * * " *" ** *ifIiL.Lncifterii! in accordance aiUi locil, stite and federal regulations. SECTION VIIII PERSONAL PROTECTION INFORMATION MM1M1MY MOIICTIM (IfICIPV Uffl for si Hu protection tec notes ** VtfrrUkATIOni LOCJK. Adequate ventilation to keep dust concintntioa btloir 1VA, muiutimi mcmmical iumidu Adequate ventilation to keep dust concentration title* TKA. sV utTIMi BTHtA js abovr. wniicTlw'it5'vi`"" "* * ` Uorial *ork gloves. Krf5iic"ii -- --- * *" " -- boggles or safety UmiTiiSifnmi (lasts ith side shields-. Do not * eir contact ltnsts. -* ..... * ton; sleeved, loose fitting clothing. l H5vST*utT5"iS"aiWIS Avoid dust, inhalation, ingestion, eye contact. Use adequate ventilation. fro not itcMd TM. .....................................................SECTION IXi 8PECIAL PRECAUTIONS eucauvimn Tt K 1MU la MMMklao awToTOMac' deep dry, iiMi'Iiiuwutii" ' ' ............. .. - ........ - - Hash aork clothes separately and rinse tusking uckine after use. Uniiiit potential for transfer to street clothes, etc.___________________________ NOTES * MfsC r.onooraphs on the Evaluation-of-the_Carcinogenic Risk of Cheaicals to Huaans (volute (2, 19B7I states: 'There is liaited evidence for carcinogenicity of crystalline silica to huaant'. 1ARC Class 2A ** Only N10SN approved or HSHA approved equipeent should be csed. for eiposuris btlo* S i PEL use standard dust respirator, Above 5 x PEL dateriine the proper respirator type. I FOR COMPANY USE ,M Ml rtcMMMiini lit (rtd htfiln <ri Ins iMnii IiIIimi tt b fricMit* * t* uti AMOvor OOba n oarr m( r mma te arcu'xv . a i.iarM'ia* *a* 4Uii.h|u. **> 1 n m i c.n i hi BEl Lakewood Cheoical l Supply Co. Onr a JN~Vs~"nAP "aw'VrQDUCT COMtfhCT CARL A. STRATTON ... iB North Market Street, East Palestine, OH 44113 (216) 426-4151 OX-LSX CHIKlCtL FAHICY OB"PRODUCT tVPI rt] XTURE SECTION III COMPOSITION CHEMICAL NAHI * COMMON MAMS VM/SMS* CAS* C.S. DATS REV. 2-4-89 PSK*LNAIMOHITlUIIAtSVI A TCMAt M OMNt ALUMINUM !18-38 1 DROSS/GRINDINGS !Y 17429-98-5 ( -------- 1 lBog/o cube! N ALUMINA 138-61 1 DROSS 1Y11344-28-1 1 -------- 118og/ cube! N AMORPHOUS SILICA 11B-36 1 PERLITE 1YI NAIF 128 MPPCFE ! IBag/a cube 1 N HOOD DUST ! 1-11 1SAMDUST/FL0UR INI NAIF 1 -------- 1 lng/o cube! N MAGNESIUM OXIDE 1 1 -1B 1 MAGNESIA IY11389-48-4 115eg/a cube 118og/a cubel N Na S1L1C0FLU0R1DE : l-ie ' Na FLU0R0S1L1CATE I Y116693-65-9 1 NOTES PAGE 12 !N CALCIUM CARBONATE : l-ib !AGRICULTURAL LIME 1Y!1317-65-3 5 -------- 1IBag/a cube! N GRAPHITE NATURAL ! 1-18 1 EXPANDABLE GRAPHITE!Y!7782-42-5 115 MPPCFE ilBog/n cube! N SILICA(CRYSTALL1 HE)t 1-18 !SILICA IItI 1YS14808-68-7 1 Table Z-3 IItt 11 1.log/ cube! Ye II \1 Regulated at per lists: OSHA 29CFR 1918 , subpart 2{ ACSIH,HHS/NTP| V IARC. lILINt POINT SECTION XXXa PHYSICAL AND CHEMICAL DATA i KILTIHI POINT JJ/A jBPBCSPIC *IT B.4"6.6 V. I PKIMUKI j * VOkATUt BY VOLUhl EVAPORATION T'"JotUBlUITV ^N~NATSN HQ(j . J VAPOR DBNBITT ppimci nb ooon grey PoBder--No Odor -^^^|^'-y--y^--j^)-^-pilcef5N"HAftRD "data"'""""""""'"' euwww--jyj-------------- '&?---------------------------------------ViSsssavisrT;------------------------------------- fiTrtrftjXBHfttf"ttffTft """ *,*****l"``*** m mm m mmmm m to not use *atcr, (Uteri al Bill not noraally sustain coebustion. bpbcial rta> FiawriBB paocioupei *...................... " ` In case of coabustion, blanket aitk inert (at or dry inert ponder. tinaalOH POTENTIAL Ctotaini auditable aetal (All. SECTION Vi HEALTH,FIRST AID AND MEDICAL DATA (FEtfTCY*0^81 I ^ M C*0UC V**-TM EFFICTE Att EFFECTS OF OVER EIPOSUS YBHiUTloi"" ` 111 J l*" * , ---- ' ' 1 ........... .... .............. for eiposure ie excess of TKA. Graphite say lead to pulaonary (ibrotii and eaphyteu. Sodiua silicofluoride it poitooout if inhaled. Crystalline silica aay cause lung diwatc. (S1LIC3SIS)_______________________________________________ _____________ lAMITtOA Sodu* Silicofluoride is toxic by ingestion. BASH TrrBrBr.B . -. (lay cause irritation nith-prolongedncontact. Vt .--.-i.i Treat as dry particulate. ... OFENTRYTM F,MT MG KDICAL WTI KSuHS----"" Em physcian. iiiTtM* 11 physcian. h- exposed areas aith_soap andjjater. flush eith eater. Seek aedical attention if irritation persists. ctnm PofiaTiaa. * * NAIF SECTION VI ITWIUT1 SUM iiciifiiiiiCnrwtfuiiki t*~woIi hoistore, strong acid, or alkalies. TRRQSIVITY AND REACTIVITY fKnwiwio KILL I0T OCCUR TA kr ?s mmdU uhen daop, releases hydrogen io contact ntb acids or alkalies. Si Itcoo tetrafluoride. {oMtff&N*fr*vr Store in $ry area. EJECTION VI11 STORAGE, HANDLING AND USE PROCEDURES MUM. ITOMAM MUD MMK1M Store in dry treat free of tcidt and alkalies. droid creating cicmive dutt. itCrSTTtliu1 it'cMTiTiSiit'M'irliu loraal clean-up proceduret. MT| fttNPONAL METHOD " * --*** --~ krprctape and ute if dry. Folio* local, ttaie, and federal regulations. SECTION VIHi PERBONAL PROTECTION INFORMATION MMMIMMTOMT MUTICTIU It^tCirV TYMMI For silica protection see notes helon <. For other conponents use nornal dust respirator if TKA is exceeded. WNTILATIonT LOCAL " Use Adequate atbient air to keep below TM. 'n ^"r 1 1r viNT ILATTpid"HECMANl CAL~*1 iittAALT* 11 ' " " r`-"***" Use adequate abient air to keep below Tttft* _ T T, .r--r--x. -- VCNTTlATtb?'"OTMift ^ 1 1 ' ''' *1 .. * TlVC GLOWS ~~ -- Hot mil work gloves. ivt PROTECTION ~ T -- T"` * ' Safety glasses* (AUlMmia ornal urk clothes. .............. 1' ' ' H >S* Nam ninii aai~iMn>Tijuaca~o7~caiiTM?MTii~iauiniiNV iSr m MiatriiifSrilfi'KU'BRUlN. - Avoid out, inhalation, inflation, oyt contict. Ifto tdoqutc vontilation. k not oictod TUh. ..................................................... EJECTION _IXj^jBPECIAL_ PRECAUTIONS MHMm-- T M tub ta ....7 in"iin~ ~BiiiiM Utp dry. "* " ----- SriisM'MScaimsm ... . Practice pood housekeeping. .......... .. ------ ............ -------------- NOTES 1ARC Honographs on the Evaluation of the Carcinogenic Risk of Cheoictli to Kunant (volute A2. IT871 states: 'There is United evidence for carcinogenicity of crystalline silica to hunans*. 1ARC Clans 2k ** Only KIOSK approved or'HSHA approved equipment should be used. For nposures belou 3 x PEL ust standard dust ***TUA for Sodiut Silicofluoride is 4.1ig/t cube. J J FOR COMPANY USE indorootlM * mow* mm 00 4 nnOMO* do* rotmnndntlon onrruty ith Uobllttp io any , i **t #*^t* roct to i**r t.***-mml tM . *r* UkM rM *. oocorocr # tM inf* PwrtOorMro w* occoft ny hnrMul oMocto bM ch > * caw* m4 **> X a **~ *** ..........ioo ook iovoo ia b Mowriia m4 IN* dot* t*r**| ill** #r in* OMitakllllr m* IN* r< i r***A%*Nll(|y m lioclot* *11 1 h *Nl 11 It -J MUf*CTUIM NANI Insul Company, Inc. 8r--"on xi Nrt and phouuui CON^ CARL >. STRATTON North Market Street, East Palestine, OH 44413 Cvm nahe.cohhon name or PtciricTi* E' ''LEND CONSUMABLE (216) 426*4151 APPAOVCD BY c.s. REV. 11/18/88 CNtMCAL PAN1LV Oft PRODUCT TYPI CONSUMABLE/EXOTHERttIC HOT TOP CHEMICAL MARK SECTION III COMPOSITION OIHA V/M* COMMON NAME . CAB* mcmm iinvi KKPOIUA1 LIMIT ACI X H TNA CAAC I N QI|N v/n SILICA(CRYSTALLINE)110-30 SAND/SILICA FLOUR Y114B08-60-7 ! Table Z-3 l.lag/a cube! Yt ALUMINUM il-ll ALUMINUM Y!7429-90-5 I -------- !10ag/a cube! N ALUMINA 11-10 ALUMINUM DROSS Y!1344-28-1 ! -------- I10.g/. cube! N CALCIUM CARBONATE i <60 LIMESTONE Y!1317-65-3 ! -------- !10.g/. cube! N IRON OXIDE (1-10 11 1 11 1 1 RED DUST/SCALE Y!1309-37-1 !10.g/. cube 1 Sag/, cube! N !! IIII 1I1I II II1 1! 11 4 * 1 IIII <1 1 Regulated as per listsi OSHA 29CFR 19101 subpart Z; AC61H.HHS/NTPj l_IARC. ......................... secti on "fiiV"physTcal 'and" chemical" DATa """ SOI t I Ni POINT 1 niLTlUt POINT jR |IP(CIPIC MHVITT 1.5~2.0 V J* PlUt M/A I * VOLAT I LI V VOLUnl M/A [VAPOR DENI I TV OR A T ION RATE M/A ! OOI.UBIt.ITY IN HATER Meg. APP.ANCNCE AND oooN Red Solid--No Odor SECTION IVi FIRE AND EXPLOSION HAZARD DATA........................... KJrww"i/ ErriMAUIEHIM REIT* ....... to tot use titer, (literill till sustain coabustion Product till theraite. . y/liiiiaViSrTl [L~rig/l "for *Alutl nut ... ACCZAL FtAt PIBMTIIM FftOCCSuftci r ^ rrT "' Avoid titer, chlorinated hydrocarbons. Avoid dust clouds. '" Firefighters should use KIOSK approved self-contained breathing apparatus and full protective clothing. CIFUMXOA PQT|I(T1AL ' ""' --------. n T--Ft-- - -- Contains oxidi:able aetal (Al.) ............................. SECTION Vi HEALTH,FIRST AID AND MEDICAL DATA SIEK7RTR0UTEI8) i fcCUTE ** cmKIC HEALTH EFFECTS Att EFFECTS Of OVER EXPOSURE iaaSlatTipn-^* ^ rm*"m - -- i -- -.. ...------------- _- Kay cause respiratory tnct irritation. Pre-existing aedical conditions aay be aggnvited by exposurei Specifically, bronchial hyper reactivity md chronic bronchial or lung disease. (Silicosis) IMIITIM ' "T_T'n V ....................... -- -- --r T- "' " --1 R--a-y-- -c-a--u-s--e---g--a--s--t-r-o--i-n--t-e--s--t-in--a--l-"di-s-t-u--r-b--a--n--c--e-s--.---S--y--i-p-t-o--a--s---a--a-y----in--c--lu--d--e----i-r-r-i-t--a--t-i-o---n--,---n--a--u-s--e--i-,--v--o--a--i-t-i-n--g--,---a-n--d---d--i-a--r-r-h--e--a--. Kay cause-irritation ith prolonged contact. EVE Irritant . . ------------------------------------------- . . PR1KART ROUTE(SI OF EKTRY FIRST AID AND HED1CAL IlffDRKATIDK )> Nation" I Person to fresh air and consult physician. Cali ppihysician. exposed areas with soap and ater. Using a skin creaa or lotion after uashing aay be helpful. Flush ith large atounts of uater. Seet aedical attention if irritation persists. of*~Pflf(TtAL HEALTH aTeE*-------------------------------------------------------------------------------------------------------------------------------------------- See notes page 2. SECTION VII ''HRROSIVITY AND Kfc*uuvin f?mm IICHMTMIUTT IMTUIU TS IWItl inter, alkalies, oxidizing agents, halogeoated organics. NkVMIItlAtIH ILL NT OCCUR Hyd<--'engas, silicon tetrafluoride. Mi*. rlSw'SrXvSU;------------~~ to lot use with oolten oettl ohen daop. SECTION VIIi STORAGE, HANDLING AND USE PROCEDURES UMIML ITOAAAf AMO HAMBLIN! Keep dry. Keep dry end avoid breathing dust or fues. vert to M taku to coot or looks o* spills Clean-up procedures designed to niiioize dust generation and exposure. ooift sTsposkl mtSob . Bury or incinerate in accordince with local, state and federal regulations. SECTION Villa PERSONAL PROTECTION INFORMATION RCRP|RATO*V PROTECTION BOPCCIPt TYPE) Bust respirator in coapliance uith QSHft standard 29CFR191B134. For silica protection see Notes beloi ** VCNTILATZOMi LOCAL" "' "" Adequate ventilation to keep dust concentration beloi TNA. VCHTILATIIM. MCHAMICAL ISSKSSSLI Adequate ventilation to keep dust concentration beloi TNA. VUTILATIOM. OTHCK Saee as above. r ctivc olovu I 1 lOTk gloves. CTC MOTKCTIOH Goggles or safety glasses lith side shields. Do not war contact lenses. -------------------------------------------------------------------------------------------------------- ------ Long sleeved, loose fitting clothing.____________________________________________________________________________ ____ HU!UMM TO K TAKU MMIM HUAIA AKB HAIKTUAMCC Of CMTNIIMTU KOUirmMT THAT MM MU IK CONTACT KITH THU HATWIAL Avoid dust, inhalation, ingestion, eye contact. Use adequate ventilation. Do not exceed TNA. ........................................ ............ SECTION IXi SPECIAL PRECAUTION PMfCAUTIONS TS M TAM* 1 Hit LIMA AMS ATPAA-- ttep dry... DTMR PRCCAUTIOMS ~ ' "" 1 ".............................. ' "" ' ' "" Nash iork clothes separately and rinse lashing aackine after use. Hiniaixe potential for transfer to street clothes, etc.__________________________________ NOTES * 1ARC Nonooraphs on the Evaluation of the Carcinogenic Risk of Cheticals to Huaans (voluae 42, 1967) states: `There is iiiited evidence for carcinogenicity of crystalline silica to huoans*. 1ARC Class 2A ** Only KIOSH approved or NSKA approved equipment should be used, for exposures beloi S x PQTuse standard dust respirator. Above 5 x PEL deteroine the proper respirator type. ^- C' FOR COMPANY USE TNa BAdATMtlM and ff...nd>uwit o.t lartA h^.im srs thM 4rmm Q.uro.e u.lIt kt MCwrtlt tt M BM dot* iMPttdi AMtvtr ttbt ms prMtv .lit rsssset ts tkt tccuf.cr td tN# BalMMlltn m* ths swltAAt 11 tgr Ad IM fttooo.ndau % AA4 AMUMd MS llAAlllty ts Ay Htar tMsrs4. RlKth^MPS M ASSSSt Its PStfMtMtUty AMR OlSAlAiA dll ll*AiI4ty 4sr Av Nsrstsl sHtctt oMilcfc ssgr as cawssS Sf tt#twrs ts twr tridirti i U.lttof at ttsrt sd ap prtiMtlt ssti saaaI f ||h til *sP>4cAIs Ms*It* sotA Mdtlr Bam Psftiatlsste a4 Miset. NAIF NO APPL1CAILI NPOAHATION POUND M/A NOT APPUtCAILK r '^y y-,ss \ vl:-' *' ^ \ 'A-- CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Answers to Plaintiffs' Master Set of Interrogatories Propounded to Insul Company, Inc. has been served upon Plaintiffs' counsel by mailing same by United States First Class mail, postage prepaid, this 9th day of October, 1997. ZIMMER KUNZ^ PROFESSION '"CORPORATION BY j JONI M. MANGINO, ES i^Attorney f^Defendant, Insul Company, Inc. Document #: 16774 3380.0001