Document 9wvO1YEZ3yYKzjgYxynBJVwL

IL050E.ASB 10/27/94 PLAINTIFF'S EXHIBIT STATE 07 ILLINOIS IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT COUNTY OF MC LEAN GEORGE and MYRA KROUTIL, Plaintiff, v. OWENS-CORNING FIBERGLAS CORPORATION, et al., Defendants.____________________ ) ) ) No. 94 L14 ) ) ) DEFENDANT, OWENS-ILLINOIS, INC.'S RESPONSES TO PLAINTIFFS' FIRST REQUEST FOR DISCOVERY FROM DEFENDANT. OWENS-ILLINOIS. INC. PRELIMINARY STATEMENT Some of the events which may be relevant to the matters inquired about by Plaintiffs'. Requests for Production apparently occurred more than thirty-five years ago. In addition, effective April 30, 1958, Owens-Illinois, Inc. disposed of the business involved in this action by way of sale of that business to OwensComing Fiberglas Corporation. Since that time, Owens-Illinois, Inc. has not engaged in the asbestos-containing insulation products manufacturing business. It does not now and it has not since that sale manufactured, distributed or sold any of its Kaylo asbestos-containing insulation products. As a result of the foregoing factors, many of the individuals who might have had personal knowledge of the matters to which plaintiffs' requests relate are deceased, or are otherwise unavailable to OwensIllinois, Inc., and investigations to date indicate that at least some documents which relate to matters inquired about by these requests were transferred to Owens-Corning Fiberglas Corporation with the transfer of the business in question in 1958. OwensIllinois, Inc. is engaged in a continuing investigation in an attempt to locate, confirm the transfer of, or confirm the absence of, such documents and is also engaged in a continuing investigation into the matters inquired about in these requests. Nu V 1 4 t&r- ^ Unless otherwise stated in a response to a specific requ <, the responses set out hereinafter are limited to the period oiing which Owens-Illinois, Inc. manufactured asbestos-containing Kaylo insulation products and to the facilities related to that business. The following is a part of and is incorporated by reference in every response provided hereinafter: This response is accurate as of the date made. However, Owens-Illinois, Inc.'s investigation is continuing, and Owens-Illinois, Inc. cannot exclude the possibility that it may be able to obtain more complete information or even information which indicates that the response being supplied is incorrect. OwensIllinois, Inc. objects to responding to this request in regard to any period of time other than the period during which it engaged in the manufacture and sale of the Kaylo products alleged to be involved in this case which ended in mid-1958 or concerning any facility not related to that business, on the basis that any such response would be irrelevant to the subject matter of the pending litigation, would not be reasonably calculated to lead to the discovery of admissible evidence, and would be burdensome and oppressive. Commencing in 1963 and continuing through 1977, Kimble Glass Company, a unit of Owens-Illinois, Inc., offered for sale gaskets, inserts and spacers as accessory parts intended for use in conjunction with Kimble's conical end glass piping system. Some of these accessory parts contained asbestos as one of their ingredients. These accessory parts were not manufactured by Kimble, but were purchased from other suppliers. From approximately 1966 through 1977, the Kimble Division also offered for sale a field beading kit which included a small plate and a covering over each of two small hoses. The plate and hose coverings may possibly have contained asbestos, but Owens- 2 Illinois cannot yet confirm the ingredients of these materials based upon its business records presently reviewed. Kimble also sold Glass Lined Reactors manufactured by Schwelm for a period of time presently unknown which incorporated g&skets containing asbestos as one of their ingredients. At the end of 1977, OwensIllinois transferred its interest in the glass pipe and Schwelm Reactor product lines and related assets to 01/Schott Process Systems, Inc. in exchange for 50% of the stock of the Corporation and, pursuant to a Sales Agreement dated May 24, 1990, sold its interest in 01/Schott Process Systems, Inc. to Schott Corporation. From 1982 through 1985, Kontes Glass Company, a subsidiary of Owens-Illinois during that time period, purchased certain asbestos-containing materials from other manufacturers and incorporated those materials into four of its products. Based upon the information available to Owens-Illinois to date concerning the nature of Plaintiff's claim, it is Owens-Illinois' understanding that the only Owens-Illinois asbestos-containing product to which the Plaintiff alleges exposure is Kaylo. Therefore, Owens-Illinois objects to responding to these requests in regard to the above described asbestos-containing products sold by Kimble Glass Company and Kontes Glass Company on the basis that any such response would be irrelevant to the subject matter of the pending litigation, would not be reasonably calculated to lead to the discovery of admissible evidence and would be burdensome and oppressive. In the event that OwensIllinois is subsequently informed that the Plaintiff alleges exposure to asbestos-containing products sold by Kimble Glass Company or Kontes Glass Company, Owens-Illinois will supplement these responses to requests within a reasonable time after receiving such notice to the extent that a supplementation is necessary in order to respond to the requests in light of the alleged exposure to asbestos-containing products sold by either Kimble Glass Company or Kontes Glass Company. 3 REQUESTS REQUEST NO. 1. all witness statements of any sort, whether signed or unsigned (together with all documents purporting to reflect the same), and a list of those statements for which a privilege from disclosure is claimed; RESPONSE NO. 1. This defendant objects to this request in that it seeks information protected by the attorney- client and/or the attorney work-product privilege. Without waiving the above objection, neither this defendant nor its counsel is in possession of materials referred to in this request. This defendant reserves the right to supplement its response at any time in the future. REQUEST NO. 2. all data as to the physical or mental condition of George Kroutil, excluding all documents provided you by plaintiffs' counsel; RESPONSE NO. 2. This defendant objects to this request in that it seeks information protected by the attorney- client and/or the attorney work-product privilege. Without waiving the above objection, neither this defendant nor its counsel is in possession of materials referred to in this request. This defendant reserves the, right to supplement its response at any time in the future. REQUEST NO. 3. all pamphlets, brochures or other documents prepared, distributed or utilized by Defendant to advertise or promote any product containing asbestos; RESPONSE NO. 3. This defendant objects to this request on the basis that it seeks information which is not 4 relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this defendant engaged in the manufacture, Sale and distribution of its Kaylo asbestos-containing products. This defendant ceased the manufacture, sale and distribution of its Kaylo asbestoscontaining products in 1958. Without waiving the above objection, refer to Exhibit I. This defendant ceased the manufacture, sale and distribution of its Kaylo asbestoscontaining products in 1958. REQUEST MO. 4. all documents reflecting or evidencing a summary of periodic chest x-rays or other medical examinations of the workers employed at any location wherein Defendant used asbestos at any time. Stated another way, Plaintiff is requesting the summaries or reports of the health surveys or employee health surveys, which were prepared or used to evaluate the health hazards, if any, arising from the use of asbestos; RESPONSE NO. 4. This defendant objects to this request on the grounds that the phrase "health hazards" is vague, ambiguous, and overly broad, seeks information which is not relevant to the subject matter of this litigation, and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this defendant engaged in the manufacture, sale and distribution of its Kaylo asbestos-containing products. Without waiving the above objection, this defendant has found no documents in its business records responsive to this request for the relevant time period. The documents referred to in defendant's answer to Interrogatory No. 11 in the George and Mvra Kroutil case filed simultaneously herewith may contain information related to the subject matter of this request. Further, this defendant has no 5 records indicating that any of its employees at its Kaylo manufacturing plants developed any asbestos related disease during the time defendant manufactured Kaylo. REQUEST NO. 5. each policy of insurance which may be construed to provide coverage for the claim stated in the Complaint; RESPONSE NO. 5. This defendant objects to this request on the ground that it seeks irrelevant and immaterial information which is not reasonably calculated to lead to the discovery of admissible evidence. Expressly reserving and without waiving its objections, and subject to them, this defendant states that the issues surrounding its insurance coverage for asbestos claims are complex. Because of disputes over possible insurance coverage, this defendant has engaged in litigation against certain insurance carriers which may provide coverage for asbestos claims. One such lawsuit resulted in a decision of the United States District Court of the District of Columbia in Owens-Illinois. Inc, v. Aetna Casualty and Surety Company. 597 F.Supp. 1515 (D.D.C. 1984). The litigation between this defendant and Aetna Casualty and Surety Co. has been settled. The terms and conditions of the settlement agreement are confidential, and as a consequence, the parties are precluded from disclosing the terms jsr contents of the agreement. Litigation with other insurance carriers is ongoing. REQUEST NO. 6. all documents reflecting payments or agreements for payments made under any of the policies described in the preceding paragraph which the carrier claims or could claim as a full or partial exhaustion of the policy limits or otherwise affect the amount of coverage available in this case; 6 iji RESPONSE NO. 6. Refer to this defendant's objection * i/.nd answer to Request for Production No. 5. REQUEST NO. 7. each document authored by an employee of Defendant in the course of his employment, dealing in whole or in part with the consequences of exposure to asbestos; RESPONSE NO. 7. This defendant objects to this request as being cumulative, burdensome and oppressive, not relevant to the subject matter of this litigation and not reasonably calculated to lead to the discovery of admissible evidence. REQUEST NO. 8. all medical records of those present or former employees of Defendant who have filed claims for worker's compensation or occupational disease benefits alleging an injury or disease from exposure to asbestos and all personnel and employment records which evidence or reflect the duration, quantity and quality of his or her exposure to asbestos while employed by Defendant; RESPONSE NO. 8. This defendant objects to this request on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this defendant engaged in the manufacture, sale and distribution of its Kaylo asbestos-containing products. This defendant ceased the manufacture, sale and distribution of its Kaylo asbestos- containing products in 1958. Without waiving the above objection, this defendant ceased the manufacture, sale and distribution of its Kaylo asbestos-containing products in 1958. During the period in which this defendant engaged in the 7 manufact ..e of its Kaylo asbestos-containing products, it received''uo workers' compensation claims for any asbestos-related disease. REQUEST NO. 9. each written warning, caution or other document which was intended by Defendant to reach those persons who would breathe or ingest the asbestos from asbestos containing products manufactured and/or sold by Defendant; RESPONSE NO. 9. This defendant objects to this request on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this defendant engaged in the manufacture, sale and distribution of its Kaylo asbestos-containing products. This defendant ceased the manufacture, sale and distribution of its Kaylo asbestos- containing products in 1958. Without waiving the above objection, this defendant ceased the manufacture, sale and distribution of its Kaylo asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm. REQUEST NO. 10. a transcript (including exhibits) of each instance where an employee of Defendant testified at deposition or trial in asbestos disease litigation; RESPONSE NO. 10. This defendant objects to this request as being vague, ambiguous, irrelevant, overly broad, 8 burdensome and a iressive, not reasonably calculated to lead to the discovery oi..dmissible evidence and not limited to any issue which is the subj-tct of this case. REQUEST NO. 11. a transcript (including exhibits) of each instance where an individual whom Defendant listed, retained or called as an expert witness, testified at deposition or trial in asbestos disease litigation; RESPONSE NO. 11. This defendant objects to this request as being vague, ambiguous, irrelevant, overly broad, burdensome and oppressive, not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. REQUEST NO. 12. all agreements to which defendant is a party and which relate to the manner in which this case shall be evaluated, delayed or defended; RESPONSE NO. 12. This defendant objects to this request in that it seeks information protected by the attorney- client and/or the attorney work-product privilege. This defendant also objects to this request on the basis that it is vague, ambiguous, and overly broad, seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. REQUEST NO. 13. all documents which Defendant provided or should have provided to the Environmental Protection Agency in response to the Asbestos Information Act of 1988 (15 9 use S2607) and the regul. ions issued April 18, 1989 (54 CFR 15622) and August 7, 198 (54 CFR 32430). RESPONSE NO. 13. This defendant objects to this request on the basis that this defendant's submission is a matter of public record, and therefore, plaintiff's counsel has equal access to same. This defendant objects to producing same. The documents are available from their proper source. REQUEST NO. 14. an affidavit stating whether production is complete according to the knowledge of Defendant and Defendant's insurance carriers, attorneys, agents and employees. RESPONSE NO. 14. Refer to the attached affidavit. 10 AFFIDAVIT STATE OF OHIO COUNTY OF WOOD ) )SS: ) * H. G. BRUSS, being duly sworn according to law, deposes and says that he is an Assistant Secretary of Owens- Illinois, Inc., a defendant herein; that as such he is authorized to make an Affidavit on its behalf; and that the facts set forth in the foregoing DEFEN DANT, OWENS-ILLINOIS, INC.'S RESPONSES TO REQUEST FOR PRODUCTION, are true and correct to the best of his knowledge, information and belief. SWORN TO and subscribed before me this/T? day of My Commission Expires^ 7. 19^- SEAL Notary Public ***** MWT CBAWTOftO ****? ftifefic, SfSE *f Ohio *** Cntwlmn *4*86 , 19 EXHIBIT I A NEW HEAT INSULATION WITH REMARKABLE COMBINATION OF ADVANTAGES.... A l%aylo Heat Insulating Bloc a new type of lightweight miners, sulation that ij efficient enough tc used at ordinary room temperate and resistant enough to perform er tiveiy up to 1200 F. Few new products of any kind h been so thoroughly researched bet being placed on the market. Ka Heat Insulating Block is the achit ment of many years' work by Owt Illinois Glass Company engine physicists and chemists. No other material, new or old effectively combines the most de able characteristics of the ideal h insulation. For instance . . . LOW DENSITY Kaylo Heat Insulating Blc weighs only 11 pounds per cubic 1c This light weight (less than one poi to the board foot) simplihes handh shipping and application. It gre; reduces weight -- an important ad' tage on ships, for an example. Notice the clean, straight edg on these insulated precipitator he per;. Applicators find it easy to do ti kind'of work with Kaylo Heat Insui ing Block because they are so easv cut and yet they have a - .lively hi flexural strength. The ...s abo'e i hoppers are also insulated with Kav Heat Insulating Block. ow THERMAL CONDUCTIVITY The coefficient of conductivity, or K". of Kayio Hen Insulating Block, s iwn on the chart on page four, i. it among the most efficient in* ulations for medium high temperaares. Its insulation value comes prinipally from its fine, interlaced cellular trucrure. These cells are so tiny and o numerous that they present a raaerial surface of approximately 140 cres per cubic foot of insulation. Experience shows that the insula* ion value of Kayio insulation im proves when the material is put into ervice. EFFECTIVE OVER WIDE TEMPERATURE RANGE Kavlo Heat Insulating Block perorms efficiently not only on temperaures in the low pressure steam and hot water range but on temperatures in -he superheated steam range as well. This is shown by the flatness of the conductivity curve. One-material cov erage with Kayio insulation handles applications which often require two thicknesses of different materials. HIGH COMPRESSIVE STRENGTH compressive strength is unusl ,v high for a mineral product of such light weight. Kayio Heat Insu lating Block withstands compression values equivalent to those of a man s walking on it or even to those of a heel s being ground into it. HIGH FLEXURAL STRENGTH Its flexural strength is higher than the normal requirement for heat insu lation of this type. This strength makes for easy handling and applica tion. and contributes to long service with low maintenance. NO ADDED BINDER Kavlo insulation is an inorganic compound, containing no added binder. Its performance characteris tics. therefore, are not affected by additives, which often reduce insulat ing value, modify effective tempera ture range or otherwise limit per formance. EASY TO APPLY WELL Kavlo Heat Insulating Blocks are clean-cut and trim. They are easy to fit into place to make a good-looking installation. Their "feef" is piMMM and now-tmrating. They can be cut, scored and sawed with ordinary wood working tools. Finishes that go over the block, whether cement, cloth or other types, can be applied smoothly and with a minimum of effort. No special tools are needed. LOW MOISTURE ABSORPTION Moisture absorption is no problera with Kayio insulation. Even w.V.n subjected to an atmosphere of % relative humidity and a tempera of 120 F., in standard tests, sp mens absorb less than 1 % moisture hy volume. RETAINS EFFECTIVENESS AFTER LONG SERVICE Kayio Heat Insulating Block re mains strong, free from excessive powdering, and shows lirrle loss m weight or shrinkage after long appli cation to temperatures up to 1200 F. Even conventional tumbling tests, run after prolonged heating, produce relatively little crumbling or break down of the material. STANDARD SIZES Lengths (inches) 36 36 36 36 36 36 36 36 36 36 Widths Thicknesses (inches) (inches) 61 6 1 >A 62 6 2'A 63 12 l 12 | 12 1 1 'A 2 12 1 12 , f>A 3 Other sizes ire available on special order HD A REMARKABLE VERSATILITY On large or small equipment, in side or out. Kavlo Heat Insulating Block performs efficiently and with a minimum of maintenance. Here it is be applied to the walls of a large p itator Workmen are laying block over 6" x 6" wire mesh welded to the stiffeners. The block are then covered with finishing cement and asphalt mastic weatherproofing. Kavlo Heat Insulating Block cov ers both flat and curved surfaces on the power house equipment pictured here. At the right are fresh air intakes; the center compartments house in duced draft fans; and at the left are conduits leading to a precipitator. Kavlo insulation means continuous fuel savings to this power plant. Hoc water is always ready when needed in the office building where this hot water storage tank is installed, thanks to Kavlo Heat Insulating Block. This permanent insulation holds water temperature constant w irh a minimum of power consumption. Other applications for Kayio Heat Insulat ing block are listed on the hack page PRINCIPAL FEATURES OF KAYLO HEAT INSULATING BLOCK \v DC3S0O=Z5\TfOb5@ Q3iLg-;i Heat Loss, Surface Temperatures and Efficiencies ***tO -C** MSiA>r>NC ftiooc ;os$ to* *i>r An as***- o' **a*tion ^ 10*1 ^ ^ ~n<i $e*4(f r*wo*rMK # toenfrww %w>eut 0iS^rw"<3n8U---r-s---f*c8*4---c----SB-A-a--r--*fsa-------m-----TIB-- Inside or outside, for large" >v,i^^.v2binoas primal I. from 0 q^200t 3-^f' *** Kayto-.Heat Inutaring x~~ ~ v * insuIsjeryvR.- - " r> T - - 9r&>. Breeching*''' Hoc Air'Ducts Autoclaves'* Tanks ` '.-'* Ovens ` '- Towers Dryers Furnaces - '-t Turbines"'*7 Evaporators J~ f v Chilling Pro Heat Exchangers Boilers Condensers.^- -" ^ Precipitators 3 - iEocomodves^SS^.-.-*' yz&r SOURCES OfJEST .D__A__T__A_ ^ *-.,;j*>--The dJa't*a)* s'.hSownfrc-"o?n> t*hrVe*se p~a"g'eAs' #,*-& are supported by, tests run at-various ,f- rt. laboratories, ^!! well known to the insulation industry. - They are further supported by. the performance of the product in service, " ' ~'"*- WlO fAT- TKSmATlNG stoctwatHOti on 'ia* sjMACts AA**cw &cdi A_ SO* ' More detailed ioformatioo on Raylo Heat Insulating Block is avail able on request. American Structural Products Company, Toledo 1, Ohio. Subsidiary of Owens-Illinois Glass Company. 2*- cs *' Sw"<* >e Ate ** PHYSICAL CHARACTERISTICS (. AT A GLANCE -'I' `'AftcrlieaangTprJZOu * v 7Tt ' " J-^rT ax 1000* F.i.; .' After boiling for 24 hours (while wet)w3FL... .-J4 lb. per iss^Sesb' After hearing for 24 hours. - '' ' ^~ - at 750* F. <v 'AL.' ........-- -........... 5-5* at 1000 F....................... ....................... ............. f.___ 7.9 % * at 1200* F----- C............. %,..............9-8% After boiling for 24 hours.?;.............. ...........'......... ......................,,-.. 0.2% . . J-H , . *. - -i..- _^Ts; -- - - - --'. < , ; i j*) - --!*>- - "V** (Conventional Tumbling Ten--Loss in weight after 10 minutes) v'Clv ^ Before hesdng. iV-' i-i ' . ' .-if ^r". - 1 Mi --: r^zz-\}'\r-u - y.v'j: * **- After hesdng for 24 hours.: ; at.750* F.'. Sf .^^T . `n lOOO* F.r?5:? -^itnoo ' ^LVV*r w w< > # * 4 u i * i <# # %. . 4r. Z-aZ:-' - - -*fc- ~r*&l' jp.-. rJ-: Linear Shrinkage after heaang for 24 hrs-f ^ ` ... 't>;- at 750* f. .___ 0.8% at iooo* F.. r.'v. ..~. .Trr.::'................"....... 0.9% at 1200* F................... V."............... .V................................. 1.5% Eloogadon after saturation (max.).................. ................................ 0.4% 1 'P1 'lOj ij-3in7v|,*?>' (velum*) After 6 hours exposure in atmosphere of 120" F. and 90% Relative Humidity..................................................... 0.9% I I > l I ' ! At 300 F. mean temperature............................................................... 0.474 <*<1- A new WITH A REMARKABLE COMBINATION OF KAYIO HEAT INSULATING BLOCK is a new type of lightweight mineral insulation that is efficient enough co be used at ordinary room temperatures and resistant enough to perform effectively up to 1200 F. Few new products of any kind have been so thor oughly researched before being placed on the market. Kavlo Heat Insulating Block is the achievement of many vears work by Ow'ens-Illinois Glass Company engi neers. physicists and chemists. It combines the most desirable characteristics of the ideal heat insulation. LOW DENSITY. Kaylo Heat Insulating Block weighs oaly 11 pounds per cubic foot. This light weight (less than one pound to the board foot) simplifies handling, shipping and application. LOW THERMAL CONDUCTIVITY. The coefficient of conductivity, or 4. of Kaylo Heat Insulating Block places it among the most efficient insulations for medium high temperatures. Its insulation value comes principally from its fine, cellular structure. These cells are so tinv and so numerous that they present a material surface of approximately 140 acres per cubic foot of insulation. Experience shows that the efficiency of Kaylo insula tion improves after exposure to service temperatures. EFFECTIVE OVER WIDE TEMPERATURE RANGE. Kaylo Heat Insulating Block performs efficientlv not only on temperatures in the low pressure steam and hot water range but on temperatures in the super heated steam range as well. One-material coverage with Kaylo insulation handles applications which often require two thicknesses of different materials. HIGH COMPRESSIVE STRENGTH. Its compressive strength is unusually high for a mineral product of such light weight. HIGH FLEXURAL STRENGTH. Its flexural strength ,s higher than the normal requirements for heat insula tion of this type. This strength makes for easy hand ling and application, and contributes to long service with low maintenance. NO ADDED BINDER. Kaylo insulation is an inorganic compound, containing no added binder. Its per formance characteristics, therefore, are not affected bv additives, which often reduce insulating value, modifv effective temperature range or otherwise limit per formance. EASY TO APPLY. Kavlo Heat Insulating Blocks are clean-cut and trim. They are easy to fit into place to Notice the dean, straight edges on these insulated pre cipitator hoppers. Applicators And it easy to work with Kaylo Heat Insulating Block because they arc so easy to cut and yet have a high flexural strength. On large or small equipment, inside or out, Kaylo Heat Insulating Block performa efficiently and with a minimum of maintenance. Here it is being applied to the walls of a large precipitator. * 3 ation >VANTAGES... take a good-looking installation. Thi* -"tmi" i*. leasanc and non-imrtnng. They can be cut. scored nd sa ed with ordinary woodworking tools. Finishes -lat go over the block, whether cement, cloth or other tpes. can be applied smoothly and with a minimum <t effort. No special tools are needed. OW MOISTURE ABSORPTION. Kaylo Heat Insulat- ng Block absorbs little moisture from surrounding uimid air. EFFECTIVE AFTER LONG SERVICE. Kaylo Heat Insulat- ng Block remains strong, free from excessive powderng. and shows little loss in weight or shrinkage after ong application to temperatures up to 1200* F. E'en conventional tumbling tests, run after prolonged neating. produce relatively little crumbling or break down of the material. TYPICAL APPLICATIONSi lr r outside, for large installations or small, up to 1 2oo f.. use Kaylo Heat Insulating Block to insulate: Breechings Hoi Air Ducis Tanks Towers Dryers Evaporators Heat Exchangers Condensers Lehrs Autoclaves Ovens Furnaces Turbines Chilling Pits Boilers Precipitators Locomotives <aylo Heat Insulating Block covers both flat and curved unices on the power house equipment pictured here. By njntmizinft heat loss, it saves fuel and keeps temperatures tmhm the room at comfortable levels. At TV II *? PHYSICAL CHARACTERISTICS ..... tu DENSITY........................ SLIXUlAi JTIINOTN........ COMP.ISS.V. ST..NOT* C s% ........ . 5Q m. *' *" ' , },, tb. ... letor* heet*................................. **,,, beenne 'r 14 750* ............................................ ai 1000* ............................................ .... Hi lb. ' " . ..ltl lb. pet e-"> .. . II7 lb. per *" alter bJ"' * 24 ...... 74 ........... . IOSS 1H WtlOMT ................ ...................... a. 750* ........................................ .......................... r.9% at I 000* ..................................... .......................... '-`5 jZ'S**'^""'***....................... * 221STSS- --* ~ 1* ~r`... l.tw* rv ' " Alter heoie ^4 *"" , ....................................... ... 7S0* ............................................................... ,i 1000* ................................................ .................. at 1 tOO* t........................................ ........-- ..... at 1000'/..................... ........................................... etiev ...................................... ... f. o% ............................... COHOUCtlVITT (K) ... a, 100' t. .. ", J00' f. .................. 0 04% ... oal fc*w w 354 -.5P-* _ ____ THICKNESS (inches) r n:ir"Jc~.o^_riro& 'QTr-FTTb. .L o. r LT 1(B-------- ____0 THT._ 0____L- O - ;:~ / _!rzr . c. ~ ; ;r -- r ro;' i HEAT INSULATING BLOCK Heat^ **, Surface Temperatures, and Efficiencies Temperature Difference, Bore Surface to Air. 'F. cu 300 aOO 500 600 700 800 900 Temperature Difference, Flat Surface to Air, *F. SOURCES OF TEST DATA: The data jhown oa these pages are supported by tests run at var ious laboratories, all well known to the insu lation industry. They are further supported by the performance of the product in service. Mere detailed Information on Kaylo Heat Insulating Block is available on request. American Structural Products Company, ~ '**' ... &&*>(-J&myl Structural Insulating Block--is a near-white, rigid mineral insulating ^-"material weighing approximately 20 pounds per cubic foot. It is composed principally of calcium.silicate. Except for density and for those characteris tics that are changed by density it is similar to Kayio Heat Insulating Block. ' a lightweight insulation used to insulate against heat loss from hot surfaces. Kayio Structural Insulating Block f20-lb. density) is designed to deveiot) maximum strength and fire resistance without sacrificing its advantages of light weight and low thermal conductivity. In fact the practical combination of these four properties--strength, weight, insulating value and fire resist- ance -makes it almost unique as a building material. It weighs nominally 20 pounds to the cubic foot actually on an over, d-. basis from 19.5 to 22 lb.', has a compressive strengtr. of apcroximaie v 5 ' ;b. per sq. in., a "k" of 0.66 at 100 mean and outstanding resist!--e to : travel of heat and flame at building fire temperatures. STRUCT! For use in fabrications that are to be Underwriters' Lab< atones inspected, Kaylo Structural Insulating Block furnished bearing the Underwriters' label for fire haza classification for building material. Kaylo Structural Insulating Block is not a finished build ing material in itself and is not made for exposure to the weather. Its pnncipal uses are as a structural roof tile, or roof deck unit, in which a steel reinforcing mat is inserted at the time of forming, and as a core material. In this latter use it serves as the core of laminated structures where the faces or laminates are applied with adhesives, and also as the core of structural shells or envelopes where the Kaylo core material is simply inserted in the open spaces and held by its own contact or by such conven tional methods as clips or other attachments. In any of these applications it adds rigidity to the structure nd vastly increases insulation value and fire resistance. PHYSICAL PROPERTIES Light Weight--Nominal 20-lb. density Kaylo Block is about a third lighter than yellow pine. On an oven-dry basis it weighs from 19.5 to 22 pounds per cubic foot. High Strength--Its compressive strength is approximately 500 lb. per sq. in. with a deformation of 5 per cent. Flexural strength is approximately 175 lb. per sq. in. Fireproof--Kaylo 20-lb. density Structural Insulating Block has been tested at the Underwriters' Laboratories in Chicago and given the following rating, based on com parison with untreated Red Oak as 100. Flame spread....................... 0.0 Fuel contributed..................negligible Smoke produced.................. 0.0 Good Insulation Value--At low mean temperatures Kay Structural Insulating Block is one of the most efficiei structural mineral insulations. At high mean temperatur it still compares favorably with heat insulating materia of its own weight. High Light Reflectivity--Where left exposed and untreat (as with the underside of a roof deck) Kaylo Scructur Insulating Block has high light reflectivity. Its light r flection factor is from 70 to 80 per cent. Non-Abrasive Surface--Its surface is non-abrasive. It h a somewhat "soapy" feel that makes it pleasant to hand At the same time it has a firm surface that assures goc contact with surfaces applied over it. No Added Binder--It contains no added binder, but i: stead constitutes its own binder. Hence its charactenst;> are not modified as to temperature limit, solubility, inslation value, fire resistance or otherwise by "bind' limitations.'' INSULATING BLOCK (20-LB. DENSITY) ood Workability--Kaylo Structural Insulating Block is sponsive to wood working tools. It can be sawed with a and saw or power saw, can be routed, tongue-and-ooved, sanded, and, in fact, run through most woodorking equipment. igh Modulut of Elasticity--The modulus of elasticity of 0-lb. density block is approximately 160,000 lb. persq. in. ow Specific Hoot--The specific heat of Kaylo Structural nsulacing Block is approximately 0.22. Ilulor Structure--Kaylo Structural Insulating Block is bout 80 per cent inter-communicating air cells. The cells re extremely small, less than a micron in diameter. ow Moisture Absorption--Kaylo Structural Block is hyToscopic. It will absorb moisture from humid air and will each equilibrium at lower moisture contents when exposed o lower humidities. However, because of its extremely mall pore size and other characteristics, its behavior with espect to moisture differs from that of most porous macri It has unusual capacity to distribute moisture riti. cs mass, and to give it off to surrounding air of ower moisture content. ts moisture absorption when surrounded by humid air s low. Test specimens dried for 24 hours at 215* F., cooled ind then exposed on all surfaces to an atmosphere of 90 ^er cent relative humidity and a temperature of 120* F. r six hours, absorbed less than one per cent of moisture y volume. or.sistent with the common practice for good construe* on involving porous insulating materials of high internal irface area, Kaylo Structural Insulating Block should s sealed against moisture on the warm side when it is objected to extremely low temperatures. High Wot Strength--Kaylo Structural Insulating Block, ike most other insulating materials, is not intended to ?erve immersed in water or exposed to extremely damp or -umid conditions, yet its flexural strength when wet (im mersed 10 hours/ is reduced only about 15 per cent. Dimensionally Stable--The dimensions of Kavlo Struct ural Insulating Block change little with changes in moist ure content. Experience has shown from the manufacture of thousands of units of laminated structures that they have unusual dimensional stability and unusual freedom from warping. Available with and without Reinforcing--In the form of roof tile Kaylo Structural Insulation is available with a steel reinforcing mat. In the form of core material for var ious types of structure it is available without reinforcing. Accepts Nails and Screws--Both nails and screws can be used with Kaylo Structural Block. Tables showing holding power of both are available on request. Nails should be of the cement-coated type without barbs that abrade the sides of the opening they make as they are driven into the block. Galvanized or non-ferrous nails may be used where greater resistance to corrosion is required. Screws may be inserted either with or without drilling a pilot hole. Sizes--Kaylo Structural Insulating Block is made in a standard size of 18 x 36 inches. Since most uses involve manufacturing operations, thick nesses that are practical can best be worked out with the manufacturer of Kaylo Insulating Products after approxi mate quantities needed are known. These will usually be between one and two inches thick. Certain thicknesses are suggested by certain building re quirements. A thickness offrom 1*4 to 2 inches of Kaylo Structural Insulating Block is required to withstand a typical building fire for one hour--usually somewhat more for a partition than for a door because of the greater per formance required of a partition. 20-Lb. and 11-Lb. DensityAlack Can Bo Used in Combination. Where two thicknesses of insulation are used to build up an insulating structure it is .ssible to use the two den sities in combination to deveiop the best insulation value strength and fire resistance. AMERICAN STRUCTURAL PRODUCTS COMPANY Toledo 1, Obi# LAMINATION :1 amination over a Kaylo Insulating Cor*--Almost any face material may be bonded to Kaylo Structural Insulating Block surfaces. Bonding agents can be selected to meet the requirements of the particular facing--also to satisfy the service requirements of the finished product--an<f still offer some choice in curing procedures. Some adhesives which may be used with various types of face materials are listed below. (This list is not intended to be complete. Its only purpose is to identify a partial list of adhesives. These have been found to provide a tensile strength of 35 lb. per sq. in. and a minimum shear strength of 100 lb. per sq. in. when cured in the manner indicated. 1 ADHESIVES FOR JOINING f CIZIXYTQa | STRUCTURAL INSULATING BLOCK TO: Wood Vonoor Aluminum Stainless $t**l ADHESIVES FOR JOINING LIKE MATERIALS: Insulating Black ta Insulating Black Aluminum ta Aluminum Stainless Steal ta Stainless Steel Dun** N*. 3024A Q 3024AWH207 1Q24AW? 6Aoc*itt* GIU1 Pfrm 711 720 Q Vlisylt**! MtA 3*11 AmBe'fiN 6814 it.k 7026 Q Q ltdwa St"co I 1341 O - 1301 w 1OW1 Dun** N*. 3024A ^ Fmotb 718 WiMwggd imalut* N* .. O O 0 lMtdlok* 4162 OO Vukel*k Dv**t 4452 00 OOO Dup** 4464 OOO G. 1. J143 G t 7031 v,-yUl ma 28*11 0 0 0 Amkt*Hi 6814 8*ttk tXC 134 R*4u 0 0 0 Cunt* No. 3034 0 No. A. NHIS7 M100 O 3 MIC 124 OOO WaMweed 0 lABtfiwt* N*. 1 tn*Hoka 4163 00 Vwkalecfc 00 Pup*"* 4433 OOO Oue"' 4444 OOO 0. e. 3142 0 a. t. 7031 0 MA 28* 18 ** AmbgHilB PtW 0 Wttih 7024 Si!<** 0 O Mm 0 0wfi*o 3024A Q twOMt* oust A w q IQ C. t 3143 Q Mmkon ftl OO SotoOKo 3003 ^ v<y<M< ma Jt-IS 0 Ambartit# HU SeKk 703S 0 So"k (Xt 131 O Sedlwm SlUcoto l4u Q *re 1134 O + I301W (OW) Vvkeiwk Owpsm 4443 00 OOO Oumm 4444 OOO 0. L 7031 0 IwHk 7034 (MMk 1X1 134 0 O (edvs 0 Oviooot S. I 7031 o twflk 7014 0 iMtik UC 13S Mw o o Q Clamped at roam temperature for 24 hours. Q Clampad in oven at 120s F. lor 1 hour. Symbols (or method of tore: Q Maced in press at 10 p.s.i. at 300s F. far 10-30 minutos. For Maximum Strength f Q Placed in press at 100 p.s.i. at 300s F. far 10-30 minutos. j_ 0 Clamped in even at 250s F. for 10-30 minutos. High-frequency curing his been tried successfully on sn experimental ''Mis with wood, aluminum and stainless steel bonded to a Kaylo ulating cor*. Many of the manufacturers making the above listed -.ahesive* can provide adhesives suitable (or high-frequency curing. r MflSEOS&M SffEQDOTJJiaM ; <S@GKl(PAGflV , TOIIOO 1. OHIO Subsidiary et OWFNS-ILLINOIS CLASS COMPANY KtJ.lM.dlt? *** 1*44 Awsanca* itevgtvewi Prwefacts *nm\i*d # U 1 A. USES 1 For use in fabrications that are to be Underwriters' Labor atories inspected, Kaylo Structural Insulating Block is furnished bearing the Underwriters' label for fire hazard classification for Duilding material. * Kaylo Structural Insulating Block is not a finished build ing'material in itself and is not made for exposure to the weather. Its principal uses are as a structural roof tile, or roof deck unit, in which a steel reinforcing mat is inserted at the time of forming, and as a core material. In this latter use it serves as the core of laminated structures where the faces or laminates are applied with adhesives, and also as the core of structural shells or envelopes where the Kaylo core material is simply inserted in the open spaces and held by its own contact or by such conven tional methods as clips or other attachments. In any of these applications it adds rigidity to the structure anH vastly increases insulation value and fire resistance. M 100 111 ISO l/| 20O Moan Temperature, `f. PHYSICAL PROPERTIES light Weight--Nominal 20-lb. density Kaylo Block is about a third lighter than yellow pine. On an oven-dry basis it weighs from 19.5 to 22 pounds per cubic foot. High Strength--Its compressive strength is approximately 500 lb. per sq. in. with a deformation of 5 per cent. Flexural strength is approximately 1T5 lb. per sq. in. Fireproof--Kaylo 20-lb. density Structural Insulating Block has been tested at the Underwriters' Laboratories in Chicago and given the following rating, based on com parison with untreated Red Oak as 100. Flame spread........................ 0.0 Fuel contributed...................negligible Smoke produced................... 0.0 Good Insulation Value--At tow mean temperatures Kaylo Structural Insulating Block is one of the most efficient structural mineral insulations. At high mean temperatures it still compares favorably with heat insulating materials of its own weight. High Light Reflectivity--Where left exposed and untreated tas with the underside of a roof deck) Kaylo Structural Insulating Block has high light reflectivity. Its light re flection factor is from TO to 80 per cent. Non-Abrasive Surface--Its surface is non-abrasive. It has a somewhat "soapy" feel that makes it pleasant to handle. At the same time it has a firm surface that assures good contact with surfaces applied over it. No Added Binder--It contains no added binder, but in stead constitutes its own binder. Hence its characteristics are not modified as to temperature limit, solubility, insu lation value, fire resistance or otherwise by "binder limitations." ^STRUCTURAL INSULATING BLOCK Good Workability--Kaylo Structural Insulating Block is Dimensionally Stable--The dimensions of Kavlo Struct responsive to wood working tools. It can be sawed with ural Insulating Block change little with changes in moist a hand saw or power saw, can be routed, tongue-and- ure content. Experience has shown from the manufacture grooved, sanded, and, in fact, run through most wood of thousands of units of laminated structures that they working equipment. have unusual dimensional stability and unusual freedom from warping. High Modulus of Elasticity--The modulus of elasticity of 20-lb. density block is approximately 160,000 lb. per sq. in. Available with and without Reinforcing--In the form of roof tile Kaylo Structural Insulation is available with a steel reinforcing mat. In the form of core material for var Low Specific Hoot--The specific heat of Kaylo Struc ious types of stricture it is available without reinforcing. tural Insulating Block is approximately 0.22. Accepts Nails and Screws--Both nails and screws can be Cellular Structure--Kaylo Structural Insulating Block is used with Kaylo Structural Block. Tables showing holding about SO per cent inter-communicating air cells. The power of both are available on request. Nails should be of cells are extremely small, less than a micron in diameter. the cement-coated type without barbs that abrade the Low Moisture Absorption--Kavlo Structural Block is hygroscopic. It will absorb moisture from humid air and will reach equilibrium at lower moisture contents when exposed to lower humidities. However, because of its extremely small pore size and other characteristics, its behavior with respect to moisture differs from that of sides of the opening they make as they are driven into the block. Galvanized or non-ferrous nails may be used where greater resistance to corrosion is required. Screws may be inserted either with or without drilling a pilot hole. Sixes--Kaylo Structural Insulating Block is made in a standard size of 18 x 36 inches. i most porous materials. It has unusual capacity to dis- Since most uses involve manufacturing operations, thick tribute moisture within its mass, and to give it off to surrounding air of lower moisture content. nesses that are practical can best be worked out with the manufacturer of Kaylo Insulating Products after approxi Its moisture absorption when surrounded by humid air mate quantities needed are known. These will usually be is low. Test specimens dried for 24 hours at 215' F., between one and two inches thick. cooled and then exposed on all surfaces to an atmos phere of 90 per cent relative humidity and a tempera ture of 120' F. for six hours, absorbed less than one per cent of moisture by volume. Certain thicknesses are suggested by certain building re quirements. A thickness of mom 1to 2 inches of Kavlo Structural Insulating Block is required to withstand a typical building fire for one hour--usually somewhat more Consistent with the common practice for good construc tion involving porous insulating materials of high for a partition than for a door because of the greater per formance required of a partition. internal surface area, Kaylo Structural Insulating Block snould be sealed against moisture on the warm side when it is subjected to extremely low temperatures. 20-lb. and 11-lb. Density Block Can Ba Used in Combination. Where two thicknesses of insulation are used to build up an insulating structure it is possible to use the two den High Wof Strength--Kaylo Structural Insulating Block, like most other insulating materials, is not intended to sities in combination to develop the besc insulation value strength and fire resistance. sem e immersed in water or exposed to extremely damp or humid conditions, yet its flexural strength when wet immersed 10 hours) is reduced only about 15 per cent. Kaylo Division OWENS-ILLINOIS GLASS COMPANY ' LAMINATION .omination over a Kayla Insulating Coro--Almost any face material may be bonded to Kaylo Structural Insul ating Block surfaces. Bonding agents can be selected to meet the requirements of the particular facing--also to satisfy the service requirements of the finished product --and still offer some choice in curing procedures. Some adhesives and primers which may be used with various types of face materials are listed below. (This list is not intended to be complete. Its only purpose is to identify a partial list of adhesives. An adhesive nojA listed does not imply that it is not suitable. These ha\ M been found to provide a tensile strength of 35 lb. per square inch and a minimum shear strength of 100 lb. per square inch, when cured according to the manufac turer's recommendation. They are not listed in the order of their adhesive strength.) ADHESIVES AND PRIMERS FOR JOINING STRUCTURAL INSULATING BLOCK TO Weed Veneer or Paper or Plastics Steel, Stainless Steel Galvaneal, er Aluminum Kaylo Insulating Block or Cimtn^Asbtitot Board Ovrit* No. 3026A r#ocoM* 01131 oO P*COr* 718 o Cotabond 730 o v.<.ril<ai ma :s-is o Amborlif* PI Id o lottik 7036 o otdvs oSt-ko S-SJAS-HJOtw (OW) ftoto'taooftd 1-13 o Armitro*? J-H63 o oT9 Dvrlte Mo. 30J6A<x No. A NH347 NI00 7ecor 71* W o o 3 MIC 134 Pmcofit* OT131 btsoMs No. 1 GOO o0 Intdftaho 4163 GO Vukalocb OQ DuPont 4633 GOO DvPont 46d6 loBOaobond 1*12 GOO 0 GX 3143 G GX 7031 G 8orih 7026 O Sotl* Ut 13* O Owe* 3034A FencceSt# Gil31 AnMrsng J 1143 btMbrto 1 0 o 0o GX 3143 SeleOrn 3003 VWtylMl MA 31-1* G0 o r AafcerSte PR.I4 Swap 7034 loeNk (Xi 13* oo0 f Sotbno Sificatd o lodvs Sync* X-I344 + I301W |DW| o o i. ir~ Kotonabond 1*12 Teg# of o *Mlik 1007 Vinybool MA 31*18 O 0 Aioboffit# ft'*14 O ltdvi O I Amitrwf J-1162 O L. Clamped at room lomporatura for 24 hewn. 0 Clampod in oven at 120* F. for 1 hour. Symbols for method of euro: Q Placed in press at 10 p.s.i. at 300* F. far 10-30 minwtas. For Maximum Strength 'i Q Placed in press at 100 p.s.i. at 300* F. far 10-30 minutes. 2 Clamped in even at 2S0* F. for 10-30 minutes. i 1 High-frequency curing has been tried successfully on an experimental sis with wood, aluminum and stainless steel bonded to t Kaylo ulatmg core. Many of the manufacturers making the above listed adhesives can provide adhesives suitable for high-frequency curing. Kaylo Division OWENS-ILLINOIS GLASS COMPANY Telada 1, Ohia (12 503 )m Q*A-uu**e Git Ca**ai i .5* The Right Material... Expert Application First, Kaylo Heat Insulation is proved a better material hvdrous calcium silicate. Its light weight, strength, waterinsolubility, low conductivity and wide temperature range give you extra advantages at no extra coat. Second. Kaylo distributors have the technical knowledge and experience to provide you with a complete insulating service. Their trained applicators are skilled craftsmen who do neat and efficient installation. To lx.* -ore of gelling the most out of your insulating dollars for your next job. call the nearest Kaylo distributor. Chances -ire you can rind him listed in the yellow pages of your phone liook. If not contact us and we ll give > ou his name. KAYLO WIITt FOI Flit 1001-- Xoylo H.al tmwlat'on Aadftti Dapt nO70. Glots Com- pony, Kaylo D'vition, Toledo 1, Ohio. .. first in calcium silicate ...pioneered by OWENS (i^ I LLINOIS Glass Company MAIN Of MCI. TOllOO t OHIO -- K A TIO SALKS OffICIS ATLANTA CHICAO0 HOUSTON NIW TOKK PHIlAOflPHIA PITTSBURGH ST LOUIS Owens Illinois Glass Company -- Kaylo Division Adrffiiifitifni No K l S3 appearing >n the foUowmf publications: Ciifmi, il Cncmecrrif Jan 19$J Oil & Gaa Journal -Jan ! 2 19SJ Plant Engineer.n( Jan . 19S1 Power --Jan . 19$J Pftm'fum Rffiner Feb 19$J Chrmi ai Proceitn Feb. 1953 C .mftutt on eeh 1 9S2 - v o- - *-* ' T s t For Radii from Ye Inch... I to & Infinity. Nesting Kaylo Heat Insulation Requires Fewer Pieces Per Job The complete range of Kaylo Insulation includes pipe covering in Simplified Dimensional Standards for diameters from \\ in. to 72 in., curved block from 72 in. to 60 ft. and flat block for surfaces of less curvature whose radii approach infinity. With its wide selection of interchangeable sizes and shapes. Kaylo Insu lation reduces the number of items needed per job and permits substantial savings in warehousing maintenance stock. WIITf 10* FIEi I00C --* `Koyto Hast Inwtahen. KAYLO Addrout Oa#t. N-J7I, QwavMiftOi G4au Company, Kayto Oiwmow, Toledo I. Otoe. mMl Hw, ... first in calcium silicate ...pioneered by OWENS (j^ILLINOIS Glass Company MAIN OMICI: TOtlOO I. OMIO-KATIO SAMS OMICIS: AHANTA * CHICAGO * HOUSTON . NSW TOK THIlAOIlPHlA T'TTltUaOH ST LOUIS Owens-Illinois Glass Company UvirtiNmnt No. 1C -1S*--appaocins in the foUo*iAA publication.: Plane Eacmecnnf --March. 1953 Oil A Gas Journal --March 23. 19S3 Chemical En|inerint-March. 1953 Chemical Procrstinf Apni. 1953 Petroleum PeAner May 1953