Document 4aqVM9Oj0yggwd5My826kb7Vx
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
LAVERNE E. BERRANG, Administratrix of the Estate of CHARLES BERRANG, and LAVERNE E. BERRANG, in her own right.
Plaintiff,
vs.
EAGLE-PICHER INDUSTRIES, INC., et al.,
Defendants.
CIVIL DIVISION NO. G.D. 87-01249 Issue No. JURY TRIAL DEMANDED
REPLY TO PLAINTIFF'S REQUEST FOR PRODUCTION AND ANSWERS TO INTERROGATORIES DIRECTED TO ASBESTOS DEFENDANTS
Code: 012/Asbestos
Filed on Behalf of: EAGLE-PICHER INDUSTRIES, INC. , Defendant
Counsel of Record for This Party: WILLIAM R. HAUSHALTER, ESQUIRE PA I.D. #15830
ROSENBERG, KIRSHNER P.A. Firm #244' 1500 Grant Building Pittsburgh, PA 15219 (412) 281-4256
- - - w -jc- -- " - ^ wi 11 . C ^' wc c-
or SvJbsidia* so engaged. See the first introductory paragraph.
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12. Has Defendant, Defendant's predecessors or any of Defendant's subsidiary companies, at any time, engaged in the mining, milling and/or subsequent sale of asbestos fiber? 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 why;
)
E. The geographical area into which you claim the asbestos was
sold; and,
..
F. Identify the organizational unit of Defendant, the predecessor or subsidiary so engaged.
The Company never mined asbestos and never sold raw asbestos. Also, the Company never sold processed asbestos for manufacturing purposes. However, on occasion as a convenience to contractors, the Company sold Eagle ''20" or 7M asbestos.
13. Has Defendant, Defendant's predecessors or any of Defendant's subsidiary companies, at any time, engaged in the marketing and/or sale of any asbestos-containing product? If so, please state: YES.
See page 14 and 14(a) for Answer to Interrogatory No. 13.
>
13
B. The years during which such activity took place;
C. The date when such activity was terminated;
A. - C. See Exhibit I and II.
D. If such activity was terminated, the reason why; and,
See page 14(a) for Answer to Interrogatory 13(D).
E. The geographical area into which you claim the asbestos-containing product(s) were sold.
These products were used throughout the U.S. and Canada; occasionally there were export shipments.
14. For the period 1930 to date, state the addresses and business telephone numbers of each facility, building, mine, mill or location v'hich was used by you as a mining, milling, manufacturing, processing, distribution or marketing facility for asbestos-containing products, state the inclusive dates each such facility was in operation, and further state its function (e.g., manufacturing, warehousing finished products, sales office, etc.).
See page 14(a) for Answer to Interrogatory No. 14.
15. Please list each asbestos-containing product mined, ..:;;-'acturod, sold, marketed and/or distributed by Defendant, Defendant's predecessors, and/or Defendant's subsidiaries at any time since 1930; and please state the following for each named product:
A. The year it was first mined, manufactured, sold, marketed, or distributed, and if discontinued, the year and the reason such mining, manufacture, sale, marketing or distribution stopped;
See page 15 for Answer to Interrogatory No. 15.
14
Answer to Interrogatory No. 13(D).
The Company discontinued manufacturing asbestoscontaining insulation products in August, 1971 except for small quantities of "43" Finishing Cement which were manufactured and shipped for the balance of 1971 and in January and April, 1972, pursuant to special orders. The only asbestos-containing pro ducts the Company sold after 1972 were mastics. In these products the asbestos fibers were suspended in a wet solution and could noi- be released into the air upon application. Mastics were dis continued from the general product line in 1974. However, the Company filled special orders for small quantities of mastics into March, 1978, some of which were for overseas destinations.
The Company discontinued manufacturing asbestos-containir.g insulation products because it had developed products which did not require asbestos fibers, the diminished demand for some products did not justify their continued manufacture, and to eliminate the possibility of harmful health effects.
Answer to Interrogatory No. 14.
The products listed in Exhibit I were manufactured at and shipped from the Company's facility in Joplin, Missouri. See Exhibit III for the addresses of the companies from which the products listed in Exhibit II were purchased.
From time to time, the Company used a warehouse in Newark, New Jersey, to store and ship minimal quantities of its products during the period from sometime prior to 1955 to 1971.
The Company's sales offices were located in Cincinnati, New York and Chicago. There were also salesmen in various localitie working from their homes.
The addresses of the New York and Chicago offices were: Chicago Sales Office
At least as early as 1955 - 10/31/63
1 North LaSalle Street Chicago 2, Illinois
11/1/63 - 10/31/67
633 South LaGrange Road LaGrange, Illinois
11/1/67 - 11/1/73
2720 Des Plaines Des Plaines, Illinois
New York Sales Office 1933 - 5/14/67
5/15/67 - 5/14/70
5/15/70 - 9/23/70
. 14 (a)
420 Lexington Avenue New York 17, New York
1209 Anderson Avenue Fort Lee, New Jersey
60 Westervelt Avenue Tenafly, New Jersey 07670
The years during which the product was mined, manufactured, sold, marketed or distributed;
A. - B. See Exhibits I and II as well as Answer to No. 11(D).
C. Which unit of Defendant, predecessor or subsidiary, mined, manufactured, sold, marketed and/or distributed the product;
See Answer to No. 11(E).
D. Whether or not said product was ever manufactured, sold, marketed or distributed in the Commonwealth of Pennsylvania and the time period during which such manufacture, sale, marketing or distribution took place; and
The Company does not have such information for each year. However, for a listing of asbestos-containing insulation products sold to or shipped to customers in Pennsylvania by the Company, be ginning in 1965 and for 1961, see Exhibit IV, which was prepared from available invoices only. The Company has no sales invoices prior to 1965, except for some invoices for 1961 and a few miscella neous invoices received through litigation. Sales data are based on the Company's fiscal year which is December 1 through November 30.
E. The plants and address(es) at which the product was mined or
manufactured.
'
See Answer to No. 14.
IS. Please list each asbestos-containing product mined, manufactured, sold, marketed and/or distributed by Defendant, Defendant's predecessors, and/or Defendant's subsidiaries at any time since 1930; and state the following for each named product:
A. Its generic name;
B. Its trade or brand name;
See page 16 for Answer to No. 16.
15
v-- A~,- c z-n.-^cn, coo u<ar or s i dng names :-y wmcn tne proC^:z as
. re'er rc-d, $ well as the type of prod,-"t involved Ce.g.. pipecover, j, cement, etc);
A. - C. See Exhibits X and II. The Company did not
refer to its products by slang names.
-
D. Its chemical composition (include the specific asbestos fiber type(s) - e.g., amosite, chrysotile, or crocidolite - and percentage by weight of each asbestos fiber type contained in the product, as well as identify the percentage by weight of all other ingredients of the product);
See page 16(a) and 16(b) for Answer to No. 16(D).
E. The intended use of the product, including the temperature ranges for which the product was recommended;
See page 16(b) and 16(c) for Answer to No. 16(E).
F. The form in which the product was shipped (i.e., burlap bags,
paper bags, drums, cardboard boxes, wooden crates, etc.), including the size and amount of the container;
See page 16(c) for Answer to No. 16(F).
'
G. The name of the company mining, manufacturing, marketing and/or selling said product, if not Defendant;
See page 16(d) for Answer to No. 16(G).
H. A detailed description of the intended method of preparation
and application of the product;
`
See page 16(d) for Answer to No. 16(H).
I. A description of the physical appearance of the product, including size, shape, color and texture;
See Exhibits I and II. Super "66" Insulating Cement was gray' and One-Cote Finishing Cement was off-white to white.
See also Answer to No. 16(H).
)
. 16
Answer to Interrogatory No. 16(D).
Defendant objects to this portion of the interrogatory, for it is overly broad, unduly burdensome, irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving said objection, see Exhibits I and II.
According to the Company's annual cost of production accounting records, the approximate asbestos content of the insula tion products formerly manufactured by the Company was as follows:
Product
Approx. Asbestos Content (by Weight) ___________________Percentage
CEMENTS:
Super "66" Insulating Cement
8.8 to 12.0 8.5 to 10.0 4.0 to 4.4 3.5 to 3.6
(1930-1934) (1935-1963) (1964-1968) (1969-Sept.1971]
"43" Finishing Cement
73.0 to 76.3 75.7
(1944-1971) ( Tan.& April,197;
Fireproofing Cement
3.5 to 3.6 2.8 to 3.1
(1948-1960) (1961-1965)
One-Cote Finishing Cement
4.8 to 2.8 to
3.3 6.3 3.2
(1960) (1961-1967) (1968-Sept.1971)
Hylo Finishing Cement
4.8 to 5.5 2.7 to 6.9
(1963-1967) (1968-Sept.1971)
Hi-Stick Insulating Cement
4.3 to 6.3
(1964-1969)
"33" Insulating Cement
7.8 to 10.8 13.8 to 14.7
(1935-1944) (1945-1949)
"99" Finishing Cement
72.2 to 82.6
.
(1935-1962)
"106" Finishing Cement
25.2 to 28.5
(1948-1962)
"111" Finishing Cement
2.1 to 3.7
(1935-1966)
"330" Insulating Cement
8.9 to 10.0
(1939-1940) (1942 & 1945)
"1003" Finishing Cement
4.7
(1947 only)
Navy Grade Cement
14.6 to 16.2 8.3 to 8.8
(1955-1956) (1958-1959)
Navy Special Cement
11.9
(1945 only)
MASTICS: Insulseal Insulseal-All Purpose Insulstic-Trowel Grade Insulstic-Brush Grade
Swetchek
16.8 to 20.8
6.0 to 6.9
12.5 to 16.0
7.1 to 16.4 7.5 to .13.5
1.6 to 11.3 1.5 to 1.9
. '
(1935-1968)
(1968-1969)
(1939-1962)
(1942-1953) (1957-1959)
(1945-1947) (1948-1961)
16(a)
Answer to Interrogatory No. 16(D) continued.
Product
Approx. Asbestos Content (by" Weight) __Percentage
SLOCK:
Vercel Block
4.1 to 7.5
(1937-1944)
DE 85 Block
4.2 to 10.3
(1947-1953)
DE 95 Block
9.7 4.0 to 9.1
(1949) (1950-1953)
Supertemp Block
1.0 to 4.0 0.3 to 1.6
(1938-1940) (1941-1945)
The Company used only chrysotile asbestos in asbestoscontaining insulation products it formerly manufactured, except for D.E. Block, which contained chrysotile and amosite asbestos.
The products sold, but not manufactured, by the Company contained chrysotile asbestos, except Hylo Block and Pipe Covering which was produced by Owens-Corning Fiberglas, and which at times contained chrysotile and amosite asbestos. The Company is uncer tain what type of asbestos 85% Magnesia Pipe Covering and Block -Insulation contained.
The percentage of asbestos in each asbestos-containing insulation product which the Company formerly sold, but did not manufacture, may be available from the manufacturer.
) Answer to Interrogatory No. 16(E).
See Exhibits I and II.
The Company's -asbestos-containing insulation products were intended for a number of high temperature industrial insulation applications. High temperature applications require products de signed for service temperatures in excess of 800 degrees F.
The products were intended to be used and handled by the insulation workers in the manner which was standard to their trade.
According to presently available product brochures, which were used as sales aids and were supplied from time to time, the following were the service temperatures for the various insulation products, (including protective coatings) for which information is available:
Product
Service Temperature
Super "66" Insulating Cement
to 1800 degrees F
"43" Finishing Cement
to 1000 degrees F
Fireproofing Cement
to 2000 degrees F
One-Cote Finishing Cement
to 1200 degrees F
Hylo Finishing Cement
to 1200 degrees E
* Hi-Stick Insulating Cement
to 1200 degrees F
16(b)
Answer to Interrogatory No. 16(E) continued.
Product "33" Insulating Cement "99" Finishing Cement "106" Finishing Cement "111" Finishing Cement Hylo Block & Pipe Covering Eagle "20" Cement 85% Magnesia Pipe Covering Vercel Block Supertemp Block "DE 85" Block "DE 95" Block
Protective Coatings Insulseal Spray-Mastic Stalastic (Standard)
(Hi-Temp) Stamastic Swetchek
Service Temperature to 1800 degrees F to 1000 degrees F to 1900 degrees F to 2300 degrees F to 1200 degrees F to 1000 degrees F to 600 degrees F to 1400 degrees F to 1900 degrees F to 1300 degrees F to 2000 degrees F
to 450 degrees F . to 250 degrees F
to 400 degrees F to 700 degrees F to 500 degrees F to 150 degrees F
Answer to Interrogatory No. 16(F).
Cements were packaged in 100-lb., 50-lb., or 25-lb. open mouth multi-wall kraft paper bags, except Eagle "20" Cement, a product merely sold, but not manufactured by the Company, which also was packaged in 100-lb. burlap bags, and "99" Finishing Cement and "111" Insulating Cement, which at some unknown time prior to 1943 were in 100-lb. burlap bags. Mastics and other wet solutions were packaged in 55-gallon open head steel drums and 5-gallon open head steel pails. Pipe covering and blocks were, packaged in cartons. Additionally, for the time periods indicated "66" Cement was packaged as follows: 1949 through 1965, 50-lb., 25-lb. and 8-lb. open mouth multi wall kraft paper bags? 1953 and 1954 only, 50-lb., 25-lb., 8-lb. and 2-lb. bags; 1966 through 1971, 50-lb. and 2-lb. bags. Obser vation: 25-lb., 8-lb. and 2-lb. bags were designed for refractory companies only.
The Company's cement insulation products were packaged in open mouth pasted end or sewn bottom bags and were sewn at the top by cotton thread. Prior to 1958, in addition to cotton thread, some of the bags were closed at the top with tie wire.
16(c)
Answer to Interrog^.ory No. 16(G). Defendant objects to this interrogatory for it is overly
broad and vague. Without waiving said objection, see Answer to No. 14.
See also Exhibit I pages 5 and 6 for a listing of companies for whom the Company rebranded its asbestos-containing insulation products. Answer to Interrogatory No. 16(H).
Cements were in a dry, granulated form. For use, they were mixed with water and trowelled on or applied by hand.
Insulstic was a wet sodium-silicate solution. Insulseal, Spray-Mastic, Stalastic, Stamastic, and Swetchek were wet asphalt emulsions. These were trowelled or brushed on with the exception of Spray-Mastic which was sprayed on. In these products, the asbestos fibers were suspended in a wet solution and could not be released into the air upon application.
Blocks and pipe covering were in dry, solid form. Normally, they were held in place by impaling or banding. Sometimes, they were cut and/or drilled to fit specific applications. Also, see Answer to No. 16(E).
16(d)
- w* a > j lOOwi t ^ ^ i r* ^, mp ^ 5 s c *" i der-ti fyi r markings which appeared on the 'roduct, as we'-' as a descrip...on of the package used, the ^tes that type of package^ was used, and any logos, product names, trademarks, etc. which appeared on the package; See page 17(a) for Answer to No. 16(J).
K. Identify each individual who participated in the design, preparation and approval of the company manufacturing and/or technical specifications for the product;
See page 17(b) for Answer to No. 16(K).
L. Whether the product has been altered in chemical composition since first being made. If so, please state as to each such alteration;
(1) The date of alteration;
(2) Til2 nature of the alteration;
(3) The reason for the alteration;
See page 17(c) for Answer to No, 16(L)(1-3)
(4) Identify the person(s) recommending or approving such alteration;
See page 17(d) for Answer to No. 16(L)(4).
17
Answer to Interrogatory No. 16(J).
No logos, writing, impressions or identifying marks appeared on the products themselves. However, see Answer to No. 16(F).
Defendant does not have complete information on past packaging, but all the Company's products, except private label products, had on the package the name of the product; Eagle-Picher's name; its address; its logo, mixing and/or application instructions, where applicable; and statement of net contents.
See Exhibit V for a copy of the mixing instructions. Also, see Exhibit VI for a copy of logos which appeared on the containers of the Company's asbestos-containing insulation products.
After being advised in 1964 by the National Insulation Manufac turers A.ssociation (NIMA) that the major producer of asbestos products, Johns-Manville Corporation, had informed the NIMA Board that it was placing a caution on its products that contained asbestos, the Company elected to follow this practice of the industry leader.
-The Company placed the following caution on the containers of its asbestos-containing finishing and insulating cements in June, 1964. This same caution remained on these products until they no longer contained asbestos or they were discontinued.
"CAUTION. This product contains asbestos fiber.
Inhalation of asbestos in excessive quantities- over
long periods of time may be harmful. If dust is created
when this product is handled, avoid breathing the dust.
If adequate ventilation control is not possible, wear
respirators approved by the U.S. Bureau of Mines for
pneumoconiosis producing dust."
The caution was located on the lower portion of the container. See Exhibit VII for a copy of the caution.
Hylo Block and Pipe Covering, which was produced by Owens-Corning
and was merely sold by'the Company, included a caution on the packages
beginning in January, 1967.
.
Also, see Exhibits I, II and VIII regarding Eagle-Picher's trade marks which appeared on the containers of asbestos-containing insula tion products formerly sold by the Company.
In addition, see Exhibit XXIII for a copy of a warranty which
appeared on some of the packages of the Company's asbestos-containing insulation products.
17(a)
t
VERIFICATION
The undersigned,
ROBERT BQCKSTAHLER
aver(s) that the statement of fact contained in the attached REPLY TO PLAINTIFF'S REQUEST FOR PRODUCTION & ANSWERS TO INTERROGATORIES
are true and correct to the best of
information, knowledge
and belief, and are made subject- to the penalties of 18 PA.
CONST. STAT. ANN. SECTION 4904 relating to unsworn falsification
to authorities.
DATED
Robert L. Bockstahler for EaglePicher Industries, Inc.
CERTIFICATE OF SERVICE
I hereby certify that I have served a true and correct copy
of the within REPLY TO REQUEST FOR PRODUCTION & ANSWERS TO
INTERROGATORIES
r.i
on all Counsel of Record this /ftfl day of
198 8/ by U.S. Mail, postage prepaid.
Wi'lliam R. Haushalter, Esquire
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41 *?- ce"*g advised r '.754 :y *.-
I-;. 44 :'
"anu'act.re's Association (wl.MA) -.-it tie -a;:- ;-oo^:e- o'
15355405 products, Jonns-uinv 11 `* Co-oorat' or. -ad '-.'ormea '.re
M1A Board t"at it was placing t ca.con or. ts c-oducts orat
contained asbestos, the Company elected to 'o:'sw th's pracvce o-'
the -"dustry leade'.
The Company o'aced the 'cl'cwing ciufon on t-e screamers 0*' 'ts asbestos-ccntammg fimsnmg and '-su'at'-c ce*ets m June. '.364 This same caut'on 'enameS on these O'cs-cts -nti 1 they no longer contain : asbestos or they ere discent'noec.
"CAL'JTCN. 'his oroduct ccntams asbestos 'lber. .""alaf.o" of asbestos 'n e<cess'<e oua-ft'es over 'o"g oer-oos of time may be harmful If oust -s treated wnen this oroduct is "ansled, avoid b'eathi-g t- oust, adequate venti'ation control is not ooss'c'e. wea'
resoirators aoproved by the U.o. Bureau of "mes 'or pneumoconiosis producing dust."
'he caution was located on the 'owe' third ;f the front of t-e Sag.
Add't'onal'y, 'n a June 2, 1964, 'etter to fose 'or wno.m t"e
Coihoa'y oroouced on .ate-'abel ascestos-contai-'-g '-tjiaticn
products, Hr. Jonn Harrington, Gene'al Sales Manage', enclosed an
eveerot from a meeting of the Board of Directors of the Nat'onal
Insulation Manufacturers Association (NIMA) regarding
Jonns-ManviIle's placing of a caut'onary note on its asbestos
.'reduces; he stated that the Company was pammg to use the same
cautionary note, and asueo those companies they wished the same
action tanen on their behalf.
.
The Comoany no longer manufactures tnese orocucts. However, any available information regarding the caution ;s in tne files of the Corporate Legal Department. Eagle-Sicher Industries, Inc.,
Cincinnati. Ohio.
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