Document BR0kBQznNy2KNn3JZ70J9qp0w

V 7, S'O, 9 9 IN THE CIRCUIT COURT FOR BALTIMORE CITY * * * ALL CT-1 CASES * ALL CT-2 CASES * ALL CT-4 CASES * ' ALL CT-5 CASES * * DEFENDANT OWENS-ILLINOIS, INC.*8 ANSWERS TO PLAINTIFFS' MASTER INTERROGATORIES TO ALL DEFENDANTS To: All Defendants, to be answered individually and separately by each Defendant. Plaintiffs, by their attorneys, John T. Enoch, John Amato, IV, and Goodman, Meagher & Enoch, request Defendants to answer the following Interrogatories. The Interrogatories are to be read and answered in accordance with the following instructions and definitions. a. These Interrogatories are continuing in character and, in accordance with the Maryland Rules, you are required to supplement your answers promptly after you obtain further material information. RESPONSE NO. 2: This Defendant objects to this Interrogatory on the basis that it is overly broad and unduly burdensome, and calls for information which is immune from discovery under the attorney work product doctrine. Without waiving above objections this Defendant states that it has referred to the relevant business records of the Owens-Illinois Glass Company, which ere still in the possession of Owens-Illinois, Inc., in connection with the preparation of answers to these Interrogatories unless otherwise indicated. INTERROGATORY NO. 3: State whether you are a corporation. If so, state: your corporate name; state of incorporation? date of incorporation; address of principal place of business; address(es) of any other place of business; whether, if you are a "foreign corporation" as defined in Maryland General Corporation Law Sec. 1-101(1), you are now or have ever been registered or qualified to do business in the State of Maryland; and the corporate name, state of incorporation and date of incorporation of any subsidiary, predecessor or affiliate corporation. RESPONSE NO. 3: Owens-Illinois Glass Company was incorporated in the State of Ohio in 1929. Owens-Illinois Glass Company changed its name to Owens-Illinois, Inc. on April '28, 1965. The address of the principal place of business is One SeaGate, Toledo, Ohio 43666. INTERROGATORY NO. 4: which you have existed. Identify all prior names by RESPONSE NO. 4: Owens-Illinois Glass Company changed its name to Owens-Illinois, Inc. on April 28, 1965. -6- (g) The terms and conditions of any contracts or agreements by and between you and such corporation(s) or business entity(ies), including, but not limited to, the terms and conditions relating to the transfer of liabilities for obligations of such corporation(s) or business entity(ies); (h) Whether you continued the manufacture, sale and/or distribution of such corporation's or business entity's asbestos products and, if so, whether you used the same product name(s) in so doing; and (i) Whether there was an identity of name, officers, directors, personnel, property, suppliers, distribution outlets and/or clients between you and such corporation(s) or business entity(ies); RESPONSE NO. 7: Refer to Response No. 6. INTERROGATORY NO. 8; If you have directly or indirectly mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce asbestos or asbestos-containing products, state as to each such product, indicating separately those products dealt with by you, your predecessor(s) in interest, your subsidiary(ies), and your affiliate(s), if any, the following; (a) Brand name, trade-name, and/or trade-mark; (b) The generic name or identity; (c) Description, including size, shape, color and composition, i.e. solid, powder or other form; (d) Chemical and physical composition, including, but not limited to, the percentage of asbestos by weight and volume; (e) Type of asbestos, i.e. chrysotile, amosite, crocidolite, actinolite, anthophyllite, or tremolite, indicating the percentage of each such asbestos fiber by weight and volume; (f) Intended marketable use; and (g) Dates during which each asbestos product was mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/cr otherwise placed in the stream of commerce. -9- RESPONSE NO. 8: (a) Kaylo and Kaylo-20; (b) This Defendant's asbestos-containing products were hydrous calcium silicate materials; (c) Owens-Illinois Glass Company began limited pilot plant operations involving the production of "Kaylo" asbestos- containing products in 1943. It began the manufacture of commercial quantities of "Kaylo" asbestos-containing products in about 1948 and continued such manufacture until about April 30, 1958. (d) This Defendant ceased the manufacture, sale and distribution of its asbestos-containing products in 1958. Its investigation as to the composition of each such product, including the type of asbestos-contained therein (i.e., amosite or chrysotile) and the quantitative percentage of asbestos, is continuing, although this Defendant now believes that this Defendant's commercially produced asbestos-containing products were hydrous calcium silicates containing between 13% and approximately 20% asbestos. Chrysotile asbestos was the primary type apparently used. Amosite was used to a lesser extent. (f) The asbestos-containing products manufactured by this Defendant were intended to be used for industrial high temperature thermal insulation such as pipe covering and block insulation, and to increase fireproofing and fire protection and for insulation through use as a roof deck or fireproof material or door core material. -10- (g) Owens-Illinois Glass Company began limited pilot plant operations involving the production of "Kaylo* asbestoscontaining products in 1943. It began the manufacture of commercial quantities of "Kaylo" asbestos-containing products in about 1948 and continued such manufacture until about April 30, 1958. INTERROGATORY NO. 9: State whether you presently mine, manufacture, produce, fabricate, import, convert, compound, process, sell, merchandise, supply, distribute and/or otherwise place in the stream of commerce any asbestos product(s) listed in your Answer to the preceding interrogatory. RESPONSE NO. 9: This Defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. It does not now, and it has not since that time, manufactured, sold or distributed any asbestos-containing products. INTERROGATORY NO. 10: Identify each individual who participated in the design and preparation of manufacturing specifications for each asbestos product identified in your Answer to Interrogatory No. 8. RESPONSE NO. 10: This Defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to plaintiff's counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. -11- INTERROGATORY NO. ll: State whether any written memoranda, specifications, blueprints or other written materials of any kind or character now exist relating to the design and preparation of the asbestos products identified in your Answer to Interrogatory No. 8. If so, identify: (a) Each such written material or document; and (b) The custodian, identity and location of each written material or document. RESPONSE NO. 11: This defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to Plaintiff's counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. INTERROGATORY NO. 12: Identify, by location and product, each plant of your in which the asbestos products identified in your Answer to Interrogatory No. 8 have been manufactured and/or assembled and the dates said plants have been in operation. RESPONSE NO. 12: This defendant's manufacturing plants were located in Berlin, New Jersey and Sayreville, New Jersey. The Berlin plant was in operation from approximately 1943 until on or about April 30, 1958. The Sayreville plant was in operation from February, 1948 until about April 30, 1953. INTERROGATORY NO. 13: If you have discontinued mining, manufacturing, producing, fabricating, importing, converting, compounding, processing, selling, merchandising, supplying, distributing and/or otherwise placing in the stream of commerce any asbestos products listed in your Answer to Interrogatory No. 8, identify the products discontinued, give the date of discontinuance and specify the reason(s) for such discontinuance. -12- RESPONSE NO. 13: In 1953, this Defendant entered into a sales agreement with Owens-Corning Fiberglas Corporation under which it agreed to the sale of asbestos-containing products to that corporation. This Defendant believes tHat it ceased the general marketing and sales of its asbestos-containing thermal insulation products at that time, disbanded its sales force, and that thereafter, Owens-Corning Fiberglas Corporation was the i primary marketer of its product until the sale of the division to Owens-Corning Fiberglas Corporation in 1958. INTERROGATORY NO. 14: If you have done so, when did you first determine that any other material could be used in place of asbestos for high-temperature insulation or any other use to or for which asbestos has been applied. If you have, in fact, substituted other material(s) for asbestos in your product(s), then state: (a) The identity of such substituted material(s); (b) When the product(s) with such substituted material(s) was first marketed; and (c) The tradename(s) and brand name(s) of the product(s) marketed with such substituted material(s). RESPONSE NO. 14: This defendant has located - information in its records indicating that several efforts were made to substitute other materials for the asbestos in its Kaylo products; however, such efforts were unsuccessful. Defendant will make available to plaintiffs' counsel through its local counsel reports on such experiments. Some of the reports are contained on microfilm which is old and of poor quality. -13- INTERROGATORY NO. 20: Identify the distributors of your asbestos products at any time during the period from 1930 to the present and attach copies of all documents relating to said distributors. For each distributor, indicate: (a) The terms of all assignments{ agreements, licenses and other arrangements by and between you and said distributor; exclusive; (b) Whether the distribution relationship was (c) The year or years in which the distribution relationship was in effect; *' (d) The identity of your asbestos products which the distributor was authorized to and did distribute; and (e) The quantity of your asbestos products distributed by the distributor on a year-by-year and product-by product basis. RESPONSE NO. 20: To the extent that this Interrogatory seeks information for any state other than Maryland, this Defendant objects to this Interrogatory on the basis that it is overbroad and it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the above objection, and insofar as this Interrogatory pertains to Maryland, this Defendant states that McCormick Asbestos Company was a distributor of this Defendant's asbestos-containing products. In 1953, this Defendant entered into a sales agreement with Owens-Corning Fiberglas Corporation under which it agreed to the sale of asbestos-containing products to that corporation. This Defendant believes that it ceased the general marketing and sales of its asbestos-containing thermal insulation products at that time, -18- disbanded its sales force, and that thereafter, Owens-Corning Fiberglas Corporation was the primary marketer of its products until the sale of the division to Owens-Corning Fiberglas Corporation in 1958, and that these circumstances are the reason that it does not have records or correspondence which would enable it to answer this Interrogatory for the period after 1954. INTERROGATORY NO. 21: State whether you have ever sold, distributed or otherwise furnished any of your asbestos products to any other person and/or business entity for resale or redistribution at any time from 1930 to the present. If so, state: (a) The identity of each such person and/or business entity; (b) The brand name, tradename and/or trademark adopted and used by you for each such product; (c) The brand name, tradename and/or trademark adopted and used by each such person and/or business entity for each such product; product; (d) The generic name or identity of each such (e) The year(s) in which each such product was sold, distributed or otherwise furnished to each such person and/or business entity, and for each year, the quantity of each product sold, distributed or otherwise furnished; product; (f) The intended marketable use for each such (g) Whether each such product was intended to be used, resold, or distributed by such other person and/or business entity in the same or substantially the same condition as it was when shipped or delivered by you; and (h) The custodian, identity and location of all documents pertaining to agreements for the resale, distribution, or furnishing of your asbestos products to each other person and/or business entity. -19- RESPONSE NO. 21: This Defendant ceased the manufacture, sale and distribution of asbestos-containing thermal insulation products in 1958. This Defendant states that in 1953 it entered into a "Sales Agreement" under which it agreed to sell certain amounts of its asbestos-containing thermal insulation products to Owens-Corning Fiberglas Corporation. Furthermore, this Defendant has found information sin its records which indicate that in at least 1956, it placed Owens-Corning Fiberglas Corporation's logo on some of its boxes. This Defendant does not have information sufficient to further respond to this Interrogatory. INTERROGATORY NO. 22: State the following with respect to the packages and containers in which you sold, distributed or otherwise furnished each of the asbestos products described in your Answer to Interrogatory Nos. 8 and 19 on a year-by-year and product-by-product basis; (a) A description of the package or container in which each product was sold, distributed or otherwise furnished, including composition, si2e, shape and color; (b) A description of the markings or printed material that appeared on each package or container, indicating the size and color of the same; (c) A description of any logo or other design appearing on the package or container; (d) A verbatim description of any caution or warning notice appearing on the package or container, setting forth the year(s) in which each such notice appeared on each such product; and (e) A verbatim description of any instructions appearing on the package or container. -20- defendant made appropriate efforts to provide ventilation and to control the emissions of all dust emitted during the manufacturing process within recognized save levels of exposure, including the use of respirators in some instances, dust collection equipment and other devices as necessary. Therefore, during the period in which this defendant was in the business of manufacturing Kaylo it had no reason^ to believe that the foreseeable use of Kaylo would create a hazard to users. The documents produced by Owens-Coming Fiberglas Corporation indicate that the September, 1955 publication in the A.M.A. Archives of Industrial Health was a publication of inhalation experiments. To the extent that this -interrogatory seeks the production of documents, such documents, as outlined in this response, have not been found as part of this defendant's records and, to the extent that this defendant is in possession of copies of documents, it possesses copies only of documents collected in preparation for litigation. This defendant objects to producing the same. The documents are available from their proper source. INTERROGATORY NO. 39: Identify all trade organizations, associations or other entities to which you belong or belonged. Said organizations, etc., include, at a minimum, the following: Asbestos Textile Institute (ATI); Industrial Hygiene Foundation and/or Industrial Health Foundation (IHF); Mineral Wool Institute; Industrial Mineral Insulation Manufacturers Institute; -38- Magnesia Silica Insulation Manufacturers Association; National Insulation Manufacturers Association (NIMA); Thermal Insulation Manufacturers*Association (TIMA); Asbestos Information Association (AIA); Quebec Asbestos Mining Association (QAMA); National Safety Counc'il; Asbestos Cement Producers Association; Refractories Institute. RESPONSE NO. 39: This defendant objects to this interrogatory on the grounds that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence except as it relates to the period of time within which this defendant manufactured its asbestos-containing products. Without waiving the above objection, this defendant states that insofar as this interrogatory refers to associations or organizations of which this defendant was a member during the time when it manufactured asbestos-containing products, it was a member of the Industrial Hygiene Foundation (which changed its name to the Industrial Health Foundation in 1970) for the years 1936 through 1975. This defendant was not a member of any of the other organizations about which this interrogatory inquires. INTERROGATORY NO. 40: For each trade organization, association or other entity identified in your Answer to Interrogatory No. 39, state: -39- (c) All documents relating to Saranac Laboratory studies or tests which were received or submitted by you, either directly or indirectly through predecessor(s) in interest, subsidiary(ies) or affiliate(s), if any, through other companies, or through any trade associations, organizations or entities; (d) All recommendations or findings of such studies in relation to: (i) adequacy or inadequacy of the threshold limit values; (ii) the substitution of materials for asbestos; and (e) The custodian and location of all documents and/or communications identified in your Answer to this Interrogatory. RESPONSE NO. 45: Refer to response to interrogatory no. 44. INTERROGATORY NO. 46: State the amount of money spent or contributed by you annually from 1930 to the present for research of the relationship between exposure to asbestos dusts, fibers and/or products and any pulmonary pathology and identify each person or organization to whom the expenditure or contribution was made. RESPONSE NO. 46: This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 47; State whether you have ever maintained a library (or libraries) which contains books, articles, periodicals, journals and/or reference materials that relate to the subjects of asbestos, industrial hygiene, medicine, safety, occupational disease and/or engineering. If so, state: (a) The date each such library was established; (b) The location of each such library; (c) The identity of each librarian or other person in charge of the operation and materials of each such library; -43- established; (d) For whose use each such library was (e) The title, publisher and dates of subscription to or acquisition of each such periodical or journal for each such library; and (f) The title, author, publisher, date and dates of acquisition of each such article and book for each such library. RESPONSE NO. 47: During the period of time pertinent to these actions, this defendant did, not maintain an entity which would be characterized as an industrial hygiene, medicine, safety and/or engineering library. However, this defendant believes that a separate engineering library may have been maintained by its technical facility. This defendant also states that although it has no records indicating the existence of such a library, upon becoming involved in asbestos-related litigation this defendant listed all the publications which were in its then- existing industrial hygiene library. These publications are listed on Exhibit II. This defendant has not yet determined which, if any, of these publications were in this defendant's possession during the time it manufactured, sold and distributed asbestos-containing products. INTERROGATORY NO. 48: State whether any of the co defendants in asbestos litigation have ever furnished you with any information as to the state of the medical knowledge at any time regarding the relationship between exposure to asbestos dusts, fibers and/or products and the contracting of diseases, including asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers. RESPONSE NO. 48: This defendant objects to this interrogatory as being irrelevant and not reasonably calculated to lead to the discovery of admissible evidence and not limited -44- to any issue which is the subject of this case. This defendant further objects to this interrogatory on the grounds that it seeks information within the work-product privilege and on the ground that it is oppressive and burdensome in that it would have to review all of the files and all of the records of all of its attorneys all over the country to respond to this interrogatory. INTERROGATORY NO. 49: If your Answer to Interrogatory No. 48 is in the affirmative, identify: (a) How the information was furnished; (b) Who furnished said information; (c) When said information was given to you; and (d) The substance of said information. RESPONSE NO. 49: Refer to objections to interrogatory no. 48. INTERROGATORY NO. 50: State whether, at any time since 1930, you have interchanged, exchanged or communicated, the results of research, tests, studies or experiments regarding the relationship between exposure to asbestos dusts, fibers and/or products and the contracting of diseases, including asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers, with any other person, corporation or other business entity, including co-defendants in this action. RESPONSE NO. 50: This defendant objects to this interrogatory insofar as it may seek to discover work product of counsel and trial preparation material. Without waiving such objection, this defendant states that it ceased the manufacture, sale and distribution of asbestos-containing products and does not have any records of having interchanged any of the material referred to in this interrogatory with any of the other defendants named in this case; however, this defendant states that defendant Owens-Corning Fiberglas Corporation was entitled -45- to receive and may have received from this defendant material of the type specified in this interrogatory pursuant to an Agreement dated March 9, 1958 by which this defendant sold the Kaylo Division to Owens-Corning Fiberglas, if in fact this defendant had any material of said type at that time. This defendant's investigation into the subject matter of this interrogatory is continuing. <, INTERROGATORY NO. 51: If your Answer to Interrogatory No. 50 is in the affirmative, state: (a) When said interchanges, exchanges or communications occurred; (b) The identity of those persons, corporations or business entities who participated in said interchanges, exchanges or communications? (c) The content of'said interchanges, exchanges or communications; and (d) The identity of the custodian of any documents which relate to said interchanges, exchanges or communications. RESPONSE NO. 51: Refer to objection and response to interrogatory no. 50. INTERROGATORY NO. 52:, Identify all persons who have testified on your behalf before' the Occupational Safety and Health Administration, the National Institute of Occupational Safety and Health, any United States congressional committee, sub-committee, administrative hearing or investigative proceeding on the subjects of the human health consequences of exposure to asbestos dusts, fibers and/or products and the setting, modification, feasibility and acceptance of allegedly safe or proper levels of exposure to said asbestos and asbestos products. RESPONSE NO. 52: This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not -46- RESPONSE NO. 97: Not applicable. Refer to response to interrogatory no. 96. INTERROGATORY NO. 98: Identify any and all insurance agreements entered into by and between any person carrying on an insurance business and you which may be available to satisfy part or all of a judgment that might be entered in this action or to indemnify or reimburse you for payments made to satisfy the judgment. As to each such agreement, identify the insurance carrier, the amount of coverage and the applicable dates of coverage. RESPONSE NO. 98: This defendant objects to this interrogatory on the grounds that it seeks information which is not relevant to the subject matter of this litigation and is not calculated to lead to the discovery of admissible evidence. Without waiving the above objections, this defendant has liability coverage by its insurer, Aetna, for some of the actions brought against it which allegedly result from the use of asbestos-containing products. INTERROGATORY NO. 99: Describe the method by which you have maintained records concerning the manufacture, sale, advertising, distribution, delivery and installation of each of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. RESPONSE NO. 99: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 pursuant to the sale of its Kaylo division to Owens-Corning Fiberglas Corporation on April 30, 1958. It has not found any information in its records pertinent to a record or document retention policy during the period when it manufactured its asbestos-containing products or for the period of years shortly thereafter. In accordance with the contract for the sale of the Kaylo division, in the ordinary course of business -72- relating to such sale, and because of the production of certain documents by counsel for Owens-Corning Fiberglas Corporation in several jurisdictions involving asbestos-related litigation in the United States, this defendant believes that most of its records pertinent to the Kaylo division were either transferred or made available to the purchaser of the division in 1958. This defendant states that it has not destroyed any documents or records pertaining to the Kaylo division which have been found in its records in 1975 (the year in which this defendant first became aware of asbestos-related actions against it) and thereafter. INTERROGATORY NO. 100: With regard to the record keeping method described in your Answer to Interrogatory No. 99, identify: (a) Each present and former corporate department, division or subdivision responsible for maintaining the records; (b) How the records are kept, e.g.,in boxes, files, on microfilm, microfiche or computer tape or disk; (c) The inclusive dates of manufacture, sale, advertising, distribution, delivery and installation that the record keeping system covers; (d) The location(s) where such records are maintained; and (e) The identity of each person employed by you at any time from 1930 to the present, in the highest supervisory capacity, who is or was directly responsible for the collection and maintenance of such records. RESPONSE NO. 100: Refer to response to interrogatory no. 99. INTERROGATORY NO. 101: If the record keeping system described in your Answer to Interrogatory No. 99 includes use of microfilm, microfiche, computer tape or disk or any other system in which data is taken from other records, state whether you have -73- AFFIDAVIT STATE OF OHIO COUNTY OF LUCAS )SS: ) " M. F. MCCARTHY, being duly sworn according to law, deposes and says that he is an Assistant Secretary of OwensIllinois, Inc., a defendant herein; that as such he is authorized to make an Affidavit on its behalf; and that the facts set forth in the foregoing DEFENDANT, OWENS-ILLINOIS, INC.'S ANSWERS TO INTERROGATORIES, are true and correct to the best of his knowledge, information and belief. M. F. MCCARTHY SWORN TO and subscribed 1987. Notary Public My Commission Expires: .a'bImer\vj ea r. l. y IN THE CIRCUIT COURT POR BALTIMORE CITY * * ALL CT-1 CASES * ALL CT-2 CASES * ALL CT-4 CASES * ALL CT-5 CASES * * DEFENDANT OWENS-ILLINOIS, INC.'S ANSWERS TO PLAINTIFFS' MASTER INTERROGATORIES TO ALL DEFENDANTS To: All Defendants, to be answered individually and separately by each Defendant. Plaintiffs, by their attorneys, John T. Enoch, John Amato, IV, and Goodman, Meagher & Enoch, request Defendants to answer the following Interrogatories. The Interrogatories are to be read and answered in accordance with the following instructions and definitions. a. These Interrogatories are continuing in character and, in accordance with the Maryland Rules, you are required to supplement your answers promptly after you obtain further material information. b. Where knowledge or information of a person is requested or possession or control by a person is inquired of, such request or inquiry includes knowledge, information, possession or control of or by the person's agents, representatives, and, unless privileged, the person's attorneys. c. When the identity of a natural person is requested, the request or inquiry includes the home address, business address, and his former and present position or job title and business affiliation, and, if the person is a corporation or association, the address of its principal place of business. d. When the identity of a document is requested, the request or inquiry includes the type or title of the document, its date, its author, and its present custodian. In lieu of identifying any document, a copy may be annexed to the answers to these interrogatories. The term document shall be read to include any paper, graphic material, film, tape, disc, recorded matter, or stored computer data. . e. As used herein, the terms "you" and "your" refer to the defendant corporation answering these interrogatories, its predecessors, parents, subsidiaries and affiliates, if any, its present and former officers, executives, directors, agents and employees, and all other persons acting or purporting to act on behalf of Defendant. f. Present tense should be construed as also, including the past tense where appropriate. -2- g. The singular should be construed as also including the plural and the plural should be construed as also including the singular where appropriate. h. If you are unable to answer any'of these interrogatories completely, answer to the extent possible, specifically, and state whatever information or knowledge you have concerning the unanswered. i. As used herein, "asbestos products" and "asbestos-containing products" are inclusive terms, used interchangeably, and include, but are not limited to: asbestos, raw asbestos, mined asbestos, milled asbestos, asbestos compounds, material and products containing asbestos and the asbestos particles, dust and fibers resulting therefrom. PRELIMINARY STATEMENT Some of the events which may be relevant to the matters inquired about by Plaintiffs' Interrogatories apparently occurred more than thirty-five years ago. In addition, effective April 30, 1958, Owens-Illinois, Inc. disposed of the business involved in this action by way of sale of that business to Owens-Corning Fiberglas Corporation. Since that time, Owens-Illinois, Inc. has not engaged in any such business. It does not now and it has not since that sale manufactured, distributed or sold any asbestoscontaining products. As a result of the foregoing factors, many of the individuals who might have had personal knowledge of the matters to which Plaintiffs' Interrogatories relate are deceased, or are otherwise unavailable to Owens-Illinois, Inc., and 3- investigations to date indicate that at least some documents which relate to matters inquired about by these Interrogatories may have been transferred to Owens-Corning Fiberglas Corporation with the transfer of the business in question in 1958. Owens- Illinois, Inc. is engaged in a continuing investigation in an attempt to locate, confirm the transfer of, or confirm the absence of, such documents and is also engaged in a continuing investigation into the matters inquired about in these Interrogatories. Unless otherwise stated in an answer to a specific Interrogatory, the answers set out hereinafter are limited to the period during which Owens-Illinois, Inc. manufactured asbestos-containing insulation products and to the facilities related to that business. The following is a part of and is incorporated by reference in every answer provided hereinafter: This answer is accurate as of the date made. However, Owens-Illinois, Inc.'s investigation is continuing, and OwensIllinois, Inc. cannot exclude the possibility that it may be able to obtain more complete information or even information which indicates that the answer being supplied is incorrect. Owens-Illinois, Inc. objects to answering this Interrogatory in regard to any period of time other than the period during which it engaged in the business involved in this case which ended in mid-1958 or concerning any facility not related to that business, on the basis that any such answer would be irrelevant to the subject matter of the pending litigation, would not be reasonably calculated to lead to the discovery of admissible evidence, and would be burdensome and oppressive. -4- Furthermore, Owens-Illinois, Inc. objects to the instructions- and definitions supplied by Plaintiffs with regard to these Interrogatories, on the basis that the* definitions are overbroad, vague, and often inconsistent with the normal usage and meaning of such words, and the instructions are overbroad, burdensome and constitute an unreasonable expansion of the Interrogatories themselves. Owens-Illinois, Inc. therefore gives notice that it does not consider itself bound by the instructions and definitions propounded by Plaintiffs, and instead shall answer the Interrogatories in a manner consistent with a normal understanding of the language used in the answer and to the extent necessary to fairly and fully answer the Interrogatory. PART I - GENERAL INTERROGATORIES INTERROGATORY NO. 1: State the name, address and official capacity of each person who has supplied information used in answering these interrogatories and indicate for which interrogatory each such person is responsible. RESPONSE NO. 1: This Defendant states that it has referred to the relevant business records of the Owens-Illinois Glass Company, which are still'in the possession of Owens- Illinois, Inc., in connection with the preparation of answers to these Interrogatories unless otherwise indicated. INTERROGATORY NO. 2: Identify each document that was examined, reviewed and/or used in answering each interrogatory, specify the interrogatory and identify the present custodian of each document. -5- RESPONSE NO. 2: This Defendant objects to this Interrogatory on the basis that it is overly broad and unduly burdensome, and calls for information which is immune from * discovery under the attorney work product doctrine. Without waiving above objections this Defendant states that it has referred to the relevant business records of the Owens-Illinois Glass Company, which are still in the possession of Owens-Illinois, Inc., in connection with the preparation of answers to these Interrogatories unless otherwise indicated. INTERROGATORY NO. 3: State whether you are a corporation. If so, state: your corporate name; state of incorporation; date of incorporation; address of principal place of business; address(es) of any other place of business; whether, if you are a "foreign corporation" as defined in Maryland General Corporation Law Sec. 1-101(1), you are now or have ever been registered or qualified to do business in the State of Maryland; and the corporate name, state of incorporation and date of incorporation of any subsidiary, predecessor or affiliate corporation. RESPONSE NO. 3: Owens-Illinois Glass Company was incorporated in the State of Ohio in 1929. Owens-Illinois Glass Company changed its name to Owens-Illinois, Inc. on April 28, 1965. The address of the principal place of business is One SeaGate, Toledo, Ohio 43666. INTERROGATORY NO. 4: which you have existed. Identify all prior names by RESPONSE NO. 4: Owens-Illinois Glass Company changed its name to Owens-Illinois, Inc. on April 28, 1965. -6 'w*'> INTERROGATORY NO. 5: If you have divisions which have ever mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce asbestos products, identify each such division and state the names, addresses and job titles of each person who supervised each division, specifying the applicable time periods. RESPONSE NO. 5: This Defendant does not now and has not in the past engaged in the mining, milling, sale, supply or distribution of asbestos of any type. This Defendant, likewise, does not now and has not in the past engaged in the business of manufacturing, selling, supplying or distributing asbestos- containing textile products, asbestos-containing thermal insulation products, or any asbestos-containing products, except asbestos-containing thermal insulation products in the form of pipe covering and block. Further, this Defendant does not now or has not in the past operated "contract units" or any other entity that installed or contracted to install asbestos-containing products. Owens-Illinois Glass Company began limited pilot plant operations involving the production of asbestos-containing products in 1943. It began the manufacture of commercial quantities of asbestos-containing products in about 1948 and continued such manufacture until about April 30, 1958. American Structural Products Company, a wholly owned subsidiary of Owens-Illinois Glass Company, engaged in the manufacture, sale and distribution of asbestos-containing products from about January, 1948 until about June, 1949 when it became the Kaylo Division of Owens-Illinois Glass Company. The Kaylo Division of this Defendant continued to manufacture such -7- products until about April 30, 1958 when it was purchased by Owens-Corning Fiberglas Corporation from this Defendant effective on that date. As of that time, this Defendant ceased the manufacture and sale of asbestos-containing products, and it has not engaged in any such business since that date. INTERROGATORY NO. 6: Have you controlled, purchased or in any way acquired any interest in any corporation or business entity which mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce asbestos products? RESPONSE NO. 6: No, however, Owens-Illinois Glass Company changed its name to Owens-Illinois, Inc. on April 28, 1965. INTERROGATORY NO. 7: If your Answer to Interrogatory No. 6 is in the affirmative, identify and attach copies of all documents related thereto and state: (a) The name(s), including prior name(s), and the business address(es) of any and all such corporation(s) or business entity(ies); (b) The date(s) on which you first controlled, purchased or acquired said interest; (c) The manner in which you acquired said interest, i.e., cash purchase, merger, consolidation, exchange or sale of assets, etcetera; (d) The percentage of assets, ownership and/or control acquired by you; (e) Whether the corporation(s) or business entity (ies) acquired by you continued to exist following the acquisition and, if not, the date on which its existence ceased; (f) The nature cf and/cr amount of consideration paid by you for said interest; -8- (g) The terms and conditions of any contracts or agreements by and between you and such corporation(s) or business entity(ies), including, but not limited to, the terms and conditions relating to the transfer of liabilities for obligations of such corporation(s) or business .entity(ies); (h) Whether you continued the manufacture, sale and/or distribution of such corporation's or business entity's asbestos products and, if so, whether you used the same product name(s) in so doing; and (i) Whether there was an identity of name, officers, directors, personnel, property, suppliers, distribution outlets and/or clients between you and such corporation(s) or business entity(ies); RESPONSE NO. 7: Refer to Response No. 6. INTERROGATORY NO. 8: If you have directly or indirectly mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce asbestos or asbestos-containing products, state as to each such product, indicating separately those products dealt with by you, your predecessor(s) in interest, your subsidiary(ies), and your affiliate(s), if any, the following; (a) Brand name, trade-name, and/or trade-mark; (b) The generic name or identity; (c) Description, including size, shape, color and composition, i.e. solid, powder or other form; (d) Chemical and physical composition, including, but not limited to, the percentage of asbestos by weight and volume; (e) Type of asbestos, i.e. chrysotile, amosite, crocidolite, actinolite, anthophyllite, or tremolite, indicating the percentage of each such asbestos fiber by weight and volume; (f) Intended marketable use; and (g) Dates during which each asbestos product was mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce. -9- RESPONSE NO. 8: (a) Kaylo and Kaylo-20; (b) This Defendant's asbestos-containing products were hydrous calcium silicate materials; (c) Owens-Illinois Glass Company began limited pilot plant operations involving the production of "Kaylo" asbestos- containing products in 1943. It began the manufacture of commercial quantities of "Kaylo" asbestos-containing products in about 1948 and continued such manufacture until about April 30, 1958. (d) This Defendant ceased the manufacture, sale and distribution of its asbestos-containing products in 1958. Its investigation as to the composition of each such product, including the type of asbestos-contained therein (i.e., amosite or chrysotile) and the quantitative percentage of asbestos, is continuing, although this Defendant now believes that this Defendant's commercially produced asbestos-containing products were hydrous calcium silicates containing between 13% and approximately 20% asbestos. Chrysotile asbestos was the primary type apparently used. Amosite -was used to a lesser extent. (f) The asbestos-containing products manufactured by this Defendant were intended to be used for industrial high temperature thermal insulation such as pipe covering and block insulation, and to increase fireproofing and fire protection and for insulation through use as a roof deck or fireproof material or door core material. -10- (g) Owens-Illinois Glass Company began limited pilot plant operations involving the production of ''Kaylo* asbestoscontaining products in 1943. It began the manufacture of commercial quantities of "Kaylo" asbestos-containing products in about 1948 and continued such manufacture until about April 30, 1958. INTERROGATORY NO. 9: State whether you presently mine, manufacture, produce, fabricate, import, convert, compound, process, sell, merchandise, supply, distribute and/or otherwise place in the stream of commerce any asbestos product(s) listed in your Answer to the preceding interrogatory. RESPONSE NO. 9: This Defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. It does not now, and it has not since that time, manufactured, sold or distributed any asbestos-containing products. INTERROGATORY NO. 10: Identify each individual who participated in the design and preparation of manufacturing specifications for each asbestos product identified in your Answer to Interrogatory No. 8. RESPONSE NO. 10: This Defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to plaintiff's counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. -11- INTERROGATORY NO. 11: State whether any written memoranda, specifications, blueprints or other written materials of any kind or character now exist relating to the design and preparation of the asbestos products identified in your Answer to Interrogatory No. 8. If so, identify: (a) Each such written material or document; and (b) The custodian, identity and location of each written material or document. RESPONSE NO. 11: This defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to Plaintiff's counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. INTERROGATORY NO. 12: Identify, by location and product, each plant of your in which the asbestos products identified in your Answer to Interrogatory No. 8 have been manufactured and/or assembled and the dates said plants have been in operation. RESPONSE NO. 12: This defendant's manufacturing plants were located in Berlin, New Jersey and Sayreville, New Jersey. The Berlin plant was in operation from approximately 1943 until on or about April 30, 1958. The Sayreville plant was in operation from February, 1948 until about April 30, 1953. INTERROGATORY NO. 13: If you have discontinued mining, manufacturing, producing, fabricating, importing, converting, compounding, processing, selling, merchandising, supplying, distributing and/or otherwise placing in the stream of commerce any asbestos products listed in your Answer to Interrogatory No. 8, identify the products discontinued, give the date of discontinuance and specify the reason(s) for such discontinuance. -12- RESPONSE NO. 13: In 1953, this Defendant entered into a sales agreement with Owens-Corning Fiberglas Corporation under which it agreed to the sale of asbestos-containing products to that corporation. This Defendant believes that it ceased the general marketing and sales of its asbestos-containing thermal insulation products at that time, disbanded its sales force, and that thereafter, Owens-Corning Fiberglas Corporation was the primary marketer of its product until the sale of the division to Owens-Corning Fiberglas Corporation in 1958. INTERROGATORY NO. 14: If you have done so, when did you first determine that any other material could be used in place of asbestos for high-temperature insulation or any other use to or for which asbestos has been applied. If you have, in fact, substituted other material(s) for asbestos in your product(s), then state: (a) The identity of such substituted material(s); (b) When the product(s) with such substituted material (s) was first marketed; and (c) The tradename(s) and brand name(s) of the product(s) marketed with such substituted material(s). RESPONSE NO. 14: This defendant has located information in its records indicating that several efforts were made to substitute other materials for the asbestos in its Kaylo products; however, such efforts were unsuccessful. Defendant will make available to plaintiffs' counsel through its local counsel reports on such experiments. Some of the reports are contained on microfilm which is old and of poor quality. -13- Adequate copies may not be made from it, and reading it requires a reader device. Its investigation into the subject matter referred to in this Interrogatory is continuing. * INTERROGATORY NO. 15: State whether you have ever made any changes to or alterations of your asbestos products from 1930 to the present. If so, state: (a) The identity, by brand name and tradename, of each such product; altered; (b) The date(s) each such product was changed or (c) The manner in which each such product was changed or altered, including, but not limited to, any changes the asbestos content or chemical composition of each such product; in (d) The reason for each change or alteration; and (e) The identity of the person(s) responsible for instituting each change or alteration. RESPONSE NO. 15: This Defendant objects to this Interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this Defendant engaged in the manufacture, sale and distribution of its asbestos-containing products. Without waiving its objection this Defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to Plaintiffs' counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires -14- a reader device. The Defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. INTERROGATORY NO. 16: Do you contend that any of the asbestos products listed in your Answer to Interrogatory No. 8 reguire change or modification before they may be used? If so, specify what change or modification is required for each such product. RESPONSE NO. 16: This Defendant objects to this Interrogatory on the grounds that the terms "change" and "modification" are vague and ambiguous. Without waiving its objection, this Defendant states that its asbestos-containing industrial insulation was manufactured in two forms, block and pipe covering. It was a premolded, rigid product which was not intended or required to be molded or mixed in application. It was manufactured in standard premolded shapes and sizes intended to minimize cutting of pieces in application. It appears that the product was applied by methods including gluing, tying, strapping, or wiring it to pipe. It appears that a limited amount of its product was cut during application. Roof deck was intended to be laid on or fastened to building frame members and waterproofed. Core material was intended to be used as a center layer for fire doors. INTERROGATORY NO. 17: Identify all patents issued, or any applications made therefor, for any asbestos product listed in your Answer to Interrogatory No. 8. Specify the number cf each patent, the date's) of application, issuance and renewal, if applicable, to whom each patent was issued and the product(s) for which each patent was issued. -15- RESPONSE NO. 17: This Defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. Its investigation as to information concerning any such United States Patents is continuing. However, it appears that the following patents may have been related to this Defendant's asbestos-containing products at one time: PATENT NO. INVENTOR ISSUE DATE 2,425,610 2,439,724 RE.23,228 2,534,303 2,540,354 2,547,127 2,570,835 2,574,667 2,665,996 2,748,008 2,787,345 2,788,304 Finley Finley Frasor Serinis Selden Kalousek Mooney, et al. Shuman Kalousek Kalousek Soubier, et al. Scovronek 8-12-47 4-13-48 5-09-50 12-19-51 2-06-51 4-03-51 10-09-51 11-13-51 1-12-54 5-29-56 4-02-57 4-09-57 INTERROGATORY NO. 18: Identify all trademarks registered for any products listed in your Answer to Interrogatory No. 8. Specify the number and date of registration, the term thereof, the date(s) of renewal, if applicable, by whom each trade-mark was registered and the product(s) for which each trade-mark was registered. RESPONSE NO. 18: Refer to documents attached hereto as Exhibit I. INTERROGATORY NO. 19: State whether you have distributed or sold any asbestos or asbestos-containing products which was/were mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied and/or otherwise placed in the stream of commerce by persons and/or business entities other than you or your predecessor(s) in interest or subsidiary(ies), if any. If so, state: (a) The identity of each such person and/or business entity whose asbestos products you sold or distributed on a product-by-product basis; -16- (b) The terms of all assignments, agreements, licenses and other arrangements which relate to same. Identify and attach copies of all such documents; (c) As to each product, the brand name, tradename and/or trademark adopted and used by the source from which you obtained said product for distribution or sale; (d) As to each product, the brand name, tradename and/or trademark adopted and used by you for purposes of distribution or sale of said product; product; (e) The generic name or identity of each such (f) The dates during which you distributed or sold each such asbestos product; (g) As to each such product, a description, including size, shape, color, composition, i.e., solid, powder or other form; (h) As to each such product, the type of asbestos and the percentage of asbestos, by weight and volume; (i) As to each such product, its intended marketable use; (j) The identity of each person and/or business entity in the State of Maryland to whom or to which you sold or distributed each such product; (k) The identity of each contractor, subcontractor, installer or other business in the State of Maryland which ultimately installed, applied or used each such product; and ' (1) The custodian, identity and location of each document which refers to or contains information relevant to such sale or distribution. RESPONSE NO. 19: This Defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. It presently believes that it did not distribute or sell asbestos-containing insulation products manufactured by another company. -17- INTERROGATORY NO. 20: Identify the distributors of your asbestos products at any time during the period from 1930 to the present and attach copies of all documents relating to said distributors. For each distributor, indicate: (a) The terms of all assignments, agreements, licenses and other arrangements by and between you and said distributor;' exclusive; (b) Whether the distribution relationship was (c) The year or years in which the distribution relationship was in effect; (d) The identity of your asbestos products which the distributor was authorized to and did distribute; and (e) The quantity of your asbestos products distributed by the distributor on a year-by-year and product-by product basis. RESPONSE NO. 20: To the extent that this Interrogatory seeks information for any state other than Maryland, this Defendant objects to this Interrogatory on the basis that it is overbroad and it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the above objection, and insofar as this Interrogatory pertains to Maryland, this Defendant states that McCormick Asbestos Company was a distributor of this Defendant's asbestos-containing products. In 1953, this Defendant entered into a sales agreement with Owens-Corning Fiberglas Corporation under which it agreed to the sale of asbestos-containing products to that corporation. This Defendant believes that it ceased the general marketing and sales of its asbestos-containing thermal insulation products at that time, -18- disbanded its sales force, and that thereafter, Owens-Corning Fiberglas Corporation was the primary marketer of its products until the sale of the division to Owens-Corning Fiberglas Corporation in 1958, and that these circumstances are the reason that it does not have records or correspondence which would enable it to answer this Interrogatory for the period after 1954. INTERROGATORY NO. 21: State whether you have ever sold, distributed or otherwise furnished any of your asbestos products to any other person and/or business entity for resale or redistribution at any time from 1930 to the present. If so, state: (a) The identity of each such person and/or business entity; (b) The brand name, tradename and/or trademark adopted and used by you for each such product; (c) The brand name, tradename and/or trademark adopted and used by each such person and/or business entity for each such product; product; (d) The generic name or identity of each such (e) The year(s) in which each such product was sold, distributed or otherwise furnished to each such person and/or business entity, and for each year, the quantity of each product sold, distributed or otherwise furnished; product; (f) The intended marketable use for each such (g) Whether each such product was intended to be used, resold, or distributed by such other person and/or business entity in the same or substantially the same condition as it was when shipped or delivered by you; and (h) The custodian, identity and location of all documents pertaining to agreements for the resale, distribution, or furnishing of your asbestos products to each other person and/or business entity. -19- RESPONSE NO. 21: This Defendant ceased the manufacture, sale and distribution of asbestos-containing thermal insulation products in 1958. This Defendant states that in 1953 * it entered into a "Sales Agreement" under which it agreed to sell certain amounts of its asbestos-containing thermal insulation products to Owens-Corning Fiberglas Corporation. Furthermore, this Defendant has found information in its records which indicate that in at least 1956, it placed Owens-Corning Fiberglas Corporation's logo on some of its boxes. This Defendant does not have information sufficient to further respond to this Interrogatory. INTERROGATORY NO. 22: State the following with respect to the packages and containers in which you sold, distributed or otherwise furnished each of the asbestos products described in your Answer to Interrogatory Nos. 8 and 19 on a year-by-year and product-by-product basis; (a) A description of the package or container in which each product was sold, distributed or otherwise furnished, including composition, size, shape and color; (b) A description of the markings or printed material that appeared on each package or container, indicating the size and color of the same; (c) A description of any logo or other design appearing on the package or container; (d) A verbatim description of any caution or warning notice appearing on the package or container, setting forth the year(s) in which each such notice appeared on each such product; and (e) A verbatim description of any instructions appearing on the package or container. -20- RESPONSE NO. 22: (a-c, e) This Defendant believes that some of its asbestos-containing insulation products were packaged in corrugated cartons with the trademark Kaylo on the carton. This Defendant ceased the manufacture,' sale and distribution of asbestos-containing products in 1958 and does not have information sufficient to further answer this Interrogatory. (d) This Defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This Defendant has not found information in its records sufficient to enable it to answer this Interrogatory. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this Defendant had reason to believe that the use of its products would result in a foreseeable risk of harm. INTERROGATORY NO. 23: If your Answer to Interrogatory No. 22 reflects that any changes were made to the packages and containers in which you sold, distributed or otherwise furnished each of the asbestos products described in your Answer to Interrogatory Nos. 8 and 19, indicate as to each such package or container: (a) The nature of each such change, e.g., changes in composition, size, shape and color, and/or changes regarding the placement, modification or removal of any color, logo, design, name, word, number, instruction, warning or other marking on the container; change; (b) The date on which you decided to make the -21- (c) The date the container was in fact changed; (d) The reason for the change? (e) The identity of each present or former employee, officer, representative or agent of yours at any time from 1930 to the present with knowledge or information regarding your decision to change any aspect of the package or container; and (f) The custodian, location and identity of each document in your custody, control or possession which contains information relevant to your decision to change any aspect of the package or container. RESPONSE NO. 23; This Defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This Defendant has not found information in its records sufficient to enable it to answer this Interrogatory. INTERROGATORY NO. 24: For each asbestos product identified in your Answer to Interrogatory Nos. 8 and 19, as being manufactured, sold, distributed or otherwise furnished by you, state: (a) Whether you have actual packages or containers or photographs of packages or containers in which said products were sold, distributed or otherwise furnished; and (b) The identity of the custodian of said packages or containers or photographs thereof. RESPONSE NO. 24: This Defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This Defendant has not found information in its records sufficient to enable it to answer this Interrogatory. INTERROGATORY NO. 25: State whether you prepared or published any catalogues, brochures or other documents, describing products containing asbestos or asbestos components. If so, identify each such catalogue, brochure or other document and the custodian thereof. -22- RESPONSE NO. 25: Refer to Exhibit III. This Defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This Defendant has not found information in its records sufficient to enable it to further answer this Interrogatory. INTERROGATORY NO. 26: Identify each present or former employee, officer, agent or representative of yours who directed, handled, solicited, supervised, promoted or otherwise participated in the sale, supply, distribution, delivery, installation or removal in Maryland, at any time from 1930 to the present, of any asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. RESPONSE NO. 26: This Defendant objects to this Interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 27: For each person identified in your Answer to Interrogatory No. 26 who participated in the advertising in Maryland of any asbestos products identified in Interrogatory Nos. 8 and 19 at any time from 1930 to the present, state: (a) His or her duties, responsibilities and inclusive years of employment; (b) The identity of each product advertised, marketed or promoted; and (c) The method by which each product was advertised, marketed or promoted, and if by print, the name of the publication, the inclusive dates during which the advertisement or promotion appeared therein and the publisher. -23- RESPONSE NO. 27: This Defendant objects to this Interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 28: Describe your corporate structure and policy concerning the subject of employee safety in the design, development, manufacture, testing and use of asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 from 1930 to the present. In your Answer to this Interrogatory, identify each present or former corporate department, division, subdivision or other group responsible for the above-described activities and, with respect to each, identify the name, title, duties, responsibilities, and current or last known business and residential address of the highest supervisory employee with knowledge of any of those activities during any time from 1930 to the present. RESPONSE NO. 28: This Defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to Plaintiffs' counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This Defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. INTERROGATORY NO. 29: Describe your corporate structure concerning the subject of research and development of asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 from 1930 to the present. In your Answer to this Interrogatory, identify each present or former corporate department, division, subdivision or other group responsible for any of these activities and, with respect to each, identify the name, title, duties, responsibilities, and current or last known business and residential address of the highest supervisory employee during any time from 1930 to the present. -24- RESPONSE NO. 29: This Defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to Plaintiffs' counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This Defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. INTERROGATORY NO. 30: Describe your corporate structure concerning medical directors, industrial hygienists or consultants in these fields from 1930 to the present. In your Answer to this Interrogatory, identify the name, title, duties, responsibilities, period of employment, to whom the individual reported, and the current or last known business and residential address of each medical director, industrial hygienist or consultant of yours, or of your predecessor(s) in interest or subsidiary(ies), if any. RESPONSE NO. 30: This Defendant objects to this Interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this Defendant engaged in the manufacture, sale and distribution of its asbestos-containing products. Without waiving its objection, Defendant states that the following individuals acted as chief medical officers from the date when Defendant first manufactured asbestos-containing products until the present time. Charles Shook, M.D., deceased, employed from March 25, 1946 until June 30, 1960 was the Medical Director during the period in which this Defendant manufactured, sold or distributed asbestos- -25- containing products. This Defendant's chief medical officer is responsible for assuring and promoting preventive and corrective medical programs, services and practices to protect and preserve employee health and productivity throughout Owens-Illinois, Inc. The individual in this position develops, organizes, introduces and implements pre-employment and periodic examinations as well as new health programs in order to insure the continued well being of Defendant's employees in a safe and healthful environment. The person in this position is also responsible for the quality of medical services at Owens-Illinois locations. W.G. Hazard was employed as this Defendant's industrial hygienist during the period of time in which this Defendant engaged in the manufacture, sale and distribution of asbestos-containing products. Mr. Hazard has retired from this Defendant's employ and currently resides at 3609 Mapleway Drive, Toledo, Ohio 43614. This Defendant objects to further answering this Interrogatory on the grounds that it seeks information not relevant to the subject matter of this litigation and not reasonably calculated to lead to the discovery of admissible evidence except as it relates to the period of time within which this Defendant manufactured its asbestos-containing products. This Defendant has no records which describe the precise duties and responsibilities of its industrial hygienist during the time when it manufactured its asbestos-containing products, nor is its industrial hygienist currently an employee of this Defendant. However, Defendant believes that the industrial hygienist was responsible for the health aspects of employee working environments. -26- INTERROGATORY NO. 31: Identify any medical examination program offered or sponsored by you or your insurance carrier, from 1930 to the present, for employees handling or otherwise exposed to asbestos and/or asbestos products. With respect to each such program, indicating applicable time periods, state: . (a) The manner of communicating with employees about such program; (b) Whether examination was optional or mandatory and, if the latter, how frequently such examination was required; (c) What percentage of employees permitted to undergo such examination actually participated; (d) What percentage of employees who underwent such medical examination were found to have pneumoconiosis, asbestosis, mesothelioma, lung cancer or other cancers; and (e) With respect to the employees referred to in your Answer to Part (d) of this Interrogatory, what percentage of these employees were paid disability, and/or worker's compensation benefits and for what percentage of employees were medical expenses paid for purposes of treatment of such condition. RESPONSE NO. 31: This Defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 and does not have any records from which it can obtain information sufficient to answer this interrogatory. During May, 1979, various papers and reports were produced by an employee of the Trudeau Institute, Mr. Allan Logie, regarding animal experiments conducted at laboratories at Saranac Lake involving dust collected during the Kaylo manufacturing process. These papers and reports may contain information relating to the substance of this interrogatory. The employee, Hr. Logie, had no personal knowledge about the course or conduct of any such experiments, the preparation of papers and reports he produced or the retention or completeness of those -27 papers and reports. Therefore, he could not authenticate these papers and reports. This defendant has not been able to find these papers and reports in its business records or correspondence although it has searched for and continues to search for them. This defendant's counsel obtained copies of some of the papers and reports produced by Mr. Logie. However, these copies constitute only a portion of a larger volume of papers and reports which this defendant has not copied. They are available at Milbank, Tweed, Hadley & McCloy, One Chase Manhattan Plaza, New York, New York. This defendant also has reason to believe that plaintiffs' counsel has copies of the documents produced by Mr. Logie. Other documents possibly relating to this interrogatory may have been produced by Owens-Corning Fiberglas Corporation. Those documents found at Saranac Lake and at OwensCorning Fiberglas Corporation and elsewhere, which this defendant cannot authenticate, indicate that during the period of time when Owens-Illinois was in the business of manufacturing asbestoscontaining products, those products contained a relatively small proportion of asbestos. The inhalation of asbestos dust in excessive amounts over a prolonged period of time (years), under certain conditions, could lead to the potential hazard to factory workers of contracting a disease known as asbestosis. Those documents further indicate that the asbestos dust produced in the manufacture of Kaylo apparently could lead to this potential hazard where exposures were in excess of recognized safe limits, -28- that plant workers were not exposed to levels above the recognized safe limits that users were not exposed to dust levels above the recognized safe limits, and that Kaylo plant employees were x-rayed annually and displayed no asbestos-related chest disease. From the foregoing documents, it further appears that this defendant made appropriate efforts to provide ventilation and to control the emissions of all dust emitted during the manufacturing process within recognized save levels of exposure, including the use of respirators in some instances, dust collection equipment and other devices as necessary. Therefore, during the period in which this defendant was in the business of manufacturing Kaylo it had no reason to believe that the foreseeable use of Kaylo would create a hazard to users. The documents produced by Owens-Corning Fiberglas Corporation indicate that the September, 1955 publication in the A.M.A. Archives of Industrial Health was a publication of inhalation experiments. INTERROGATORY NO. 32: State whether you or anyone on your behalf ever conducted, engaged in or participated in any tests, studies and/or research, concerning the human health consequences of persons coming in contact with and/or inhaling asbestos fibers or asbestos dust during the manufacture and/or use of asbestos products. If so, identify: done; (a) What tests, studies and/or research were done; (b) When said tests, studies and/or research were (c) The individuals who ordered and supervised the tests, studies and/or research; (d) The individuals or groups engaged in or participating in the tests, studies and/or research? -29- (e) The substance of any recommendations and/or suggestions given as a result of the tests, studies or research. State when, by whom and to whom said recommendations were made, including the addresses of these individuals; (f) All written documents including, but not limited to, reports, memoranda, specifications and correspondence which refer, relate or pertain to said tests, studies and/or research; and (g) The present custodian of the written documents identified in your Answer to Part (f) of this Interrogatory. RESPONSE NO. 32; This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 and does not have any records from which it can obtain information sufficient to answer this interrogatory. During May, 1979, various papers and reports were produced by an employee of the Trudeau Institute, Mr. Allan Logie, regarding animal experiments conducted at laboratories at Saranac Lake involving dust collected during the Kaylo manufacturing process. These papers and reports may contain information relating to the substance of this interrogatory. The employee, Mr. Logie, had no personal knowledge about the course or conduct of any such experiments, the preparation of papers and reports he produced or the retention or completeness of those papers and reports. Therefore, he could not authenticate these papers and reports. This defendant has not been able to find these papers and reports in its business records or correspondence although it has searched for and continues to search for them. -30- ,,J This defendant's counsel obtained copies of some of the papers and reports produced by Mr. Logie. However, these copies constitute only a portion of a larger volume of papers and reports which this defendant has not copied, they are available at Milbank, Tweed, Hadley & McCloy, One Chase Manhattan Plaza, New York, New York. This defendant also has reason to believe that plaintiffs' counsel has copies of the documents produced by Mr. Logie. Other documents possibly relating to this interrogatory may have been produced by Owens-Corning Fiberglas Corporation. To the extent that this interrogatory seeks the production of documents, such documents, as outlined in this response, have not been found as part of this defendant's records and, to the extent that this defendant is in possession of copies of documents, it possesses copies only of documents collected in preparation for litigation. This defendant objects to producing the same. The documents are available from their proper source. INTERROGATORY NO. 33: State whether any of the medical directors, industrial hygienists or consultants in these fields identified in your Answer to Interrogatory No. 30 ever made any recommendations and/or suggestions to you pertaining to the risks or hazards to persons involved in the manufacture or use of asbestos products. If so, identify: (a) The date when said recommendations and/or suggestions were made; (b) The individual to whom said recommendations and/or suggestions were made; (c) The individual who made said recommendations and/or suggestions; (d) The substance of the recommendations and/or suggestions; and -31- (e) What actions, if any, were taken by you as a result of said recommendations and/or suggestions. RESPONSE NO. 33: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 34: State whether you have ever conducted or directed any studies to determine the amount of asbestos dust in your asbestos product manufacturing facilities. If so, identify: (a) The date of each such study; study; (b) The individual or group conducting each such (c) The result or conclusion of each such study; (d) All documents which refer, relate or pertain to each such study; and (e) The present custodian of all documents identified in your Answer to Part (d) of this Interrogatory. RESPONSE NO. 34: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 35: State whether any written memoranda, specification, blueprints or other written materials of any kind or character exist relating to any testing of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. If so, identify: (a) Each such written material or document; and (b) The custodian, identity and location of each such written material or document. RESPONSE NO. 35: This defendant has in its records technical reports relating to the development and testing of Kaylo, and Will make available to plaintiffs' counsel through its 32 local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This defendant further states that its investigation into the subject matter referred to in this interrogatory is continuing. INTERROGATORY NO. 36: State whether, after you released to the public any of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19, you ever conducted or directed any tests thereon to determine potential health hazards involved in the use of the materials. RESPONSE NO. 36: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 and does not have any records from which it can obtain information sufficient to answer this interrogatory. During May, 1979, various papers and reports were produced by an employee of the Trudeau Institute, Mr. Allan Logie, regarding animal experiments conducted at laboratories at Saranac Lake involving dust collected during the Kaylo manufacturing process. These papers and reports may contain information relating to the substance of this interrogatory. The employee, Mr. Logie, had no personal knowledge about the course or conduct of any such experiments, the preparation of papers and reports he produced or the retention or completeness of those papers and reports. Therefore, he could not authenticate these papers and reports. This defendant has not been able to find these papers and reports in its business records or correspondence although it has searched for and continues to search for them. -33- This defendant's counsel obtained copies of some of the papers and reports produced by Mr. Logie. However, these copies constitute only a portion of a larger volume of papers and % reports which this defendant has not copied. They are available at Milbank, Tweed, Hadley & McCloy, One Chase Manhattan Plaza, New York, New York. This defendant also has reason to believe that plaintiffs' counsel has copies of the documents produced by Mr. Logie. Other documents possibly relating to this interrogatory may have been produced by Owens-Corning Fiberglas Corporation. Those documents found at Saranac Lake and at OwensCorning Fiberglas Corporation and elsewhere, which this defendant cannot authenticate, indicate that during the period of time when Owens-Illinois was in the business of manufacturing asbestoscontaining products, those products contained a relatively small proportion of asbestos. The inhalation of asbestos dust in excessive amounts over a prolonged period of time (years), under certain conditions, could lead to the potential hazard to factory workers of contracting a disease known as asbestosis. Those documents further indicate that the asbestos dust produced in the manufacture of Kaylo apparently could lead to this potential hazard where exposures were in excess of recognized safe limits, that plant workers were not exposed to levels above the recognized safe limits that users were not exposed to dust levels above the recognized safe limits, that Kaylo plant employees were x-rayed annually and displayed no asbestos-related chest disease. From the foregoing documents, it further appears that this -34- defendant made appropriate efforts to provide ventilation and to control the emissions of all dust emitted during the manufacturing process within recognized save levels of exposure, including the use of respirators in some instances, dust collection equipment and other devices as necessary. Therefore, during the period in which this defendant was in the business cf manufacturing Kaylo it had no reason to believe that the foreseeable use of Kaylo would create a hazard to users. The documents produced by Owens-Corning Fiberglas Corporation indicate that the September, 1955 publication in the A.M.A. Archives of Industrial Health was a publication of inhalation experiments. To the extent that this interrogatory seeks the production of documents, such documents, as outlined in this response, have not been found as part of this defendant's records and, to the extent that this defendant is in possession of copies of documents, it possesses copies only of documents collected in preparation for litigation. This defendant objects to producing the same. The documents are available from their proper source. INTERROGATORY NO. 37: State whether, prior to 1970, you ever had any labor inspectors or persons from your company go to job sites or other areas where your asbestos products were being used or installed to make a dust level count. If so, indicate when such a practice or procedure began, the purpose of the practice or procedure and what action, if any, was taken by you in response to the findings made as a result of said practice or procedure. -35- RESPONSE NO. 37: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 38: State whether you ever conducted or directed any studies designed to learn how to minimize or eliminate the inhalation and ingestion of asbestos dust and fibers by those who use your asbestos products or are exposed to asbestos dust or fibers therefrom. RESPONSE NO. 38: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 and does not have any records from which it can. obtain information sufficient to answer this interrogatory. During May, 1979, various papers and reports were produced by an employee of the Trudeau Institute, Mr. Allan Logie, regarding animal experiments conducted at laboratories at Saranac Lake involving dust collected during the Kaylo manufacturing process. These papers and reports may contain information relating to the substance of this interrogatory. The employee, Mr. Logie, had no personal knowledge about the course or conduct of any such experiments, the preparation of papers and reports he produced or the retention or completeness of those papers and reports. Therefore, he could not authenticate these papers and reports. This defendant has not been able to find these papers and reports in its business records or correspondence although it has searched for and continues to search for them. -36- This defendant's counsel obtained copies of some of the papers and reports produced by Mr. Logie. However, these copies constitute only a portion of a larger volume of papers and reports which this defendant has not copied, they are available at Milbank, Tweed, Hadley & McCloy, One Chase Manhattan Plaza, New York, New York. This defendant also has reason to believe that plaintiffs' counsel has copies of the documents produced by Mr. Logie. Other documents possibly relating to this interrogatory may have been produced by Owens-Corning Fiberglas Corporation. Those documents found at Saranac Lake and at OwensCorning Fiberglas Corporation and elsewhere, which this defendant cannot authenticate, indicate that during the period of time when Owens-Illinois was in the business of manufacturing asbestoscontaining products, those products contained a relatively small proportion of asbestos. The inhalation of asbestos dust in excessive amounts over a prolonged period of time (years), under certain conditions, could lead to the potential hazard to factory workers of contracting a disease known as asbestosis. Those documents further indicate that the asbestos dust produced in the manufacture of Kaylo apparently could lead to this potential hazard where exposures were in excess of recognized safe limits, that plant workers were not exposed to levels above the recognized safe limits that users were not exposed to dust levels above the recognized safe limits, that Kaylo plant employees were x-rayed annually and displayed no asbestos-related chest disease. From the foregoing documents, it further appears that this -37- defendant made appropriate efforts to provide ventilation and to control the emissions of all dust emitted during the manufacturing process within recognized save levels of exposure, including the use of respirators in some instances, dust collection equipment and other devices as necessary. Therefore, during the period in which this defendant was in the business of manufacturing Kaylo it had no reason to believe that the foreseeable use of Kaylo would create a hazard to users. The documents produced by Owens-Corning Fiberglas Corporation indicate that the September, 1955 publication in the A.M.A. Archives of Industrial Health was a publication of inhalation experiments. To the extent that this interrogatory seeks the production of documents, such documents, as outlined in this response, have not been found as part of this defendant's records and, to the extent that this defendant is in possession of copies of documents, it possesses copies only of documents collected in preparation for litigation. This defendant objects to producing the same. The documents are available from their proper source. INTERROGATORY NO. 39: Identify all trade organizations, associations or other entities to which you belong or belonged. Said organizations, etc., include, at a minimum, the following: Asbestos Textile Institute (ATI); Industrial Hygiene Foundation and/or Industrial Health Foundation (IHF); Mineral Wool Institute; Industrial Mineral Insulation Manufacturers Institute; -38) Magnesia Silica Insulation Manufacturers Association; National Insulation Manufacturers Association (NIMA); Thermal Insulation Manufacturerfe Association (TIMA); Asbestos Information Association (AIA); Quebec Asbestos Mining Association (QAMA); National Safety Council; Asbestos Cement Producers Association; Refractories Institute. RESPONSE NO. 39: This defendant objects to this interrogatory on the grounds that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence except as it relates to the period of time within which this defendant manufactured its asbestos-containing products. Without waiving the above objection, this defendant states that insofar as this interrogatory refers to associations or organizations of which this defendant was a member during the time when it manufactured asbestos-containing products, it was a member of the Industrial Hygiene Foundation (which changed its name to the Industrial Health Foundation in 1970) for the years 1936 through 1975. This defendant was not a member of any of the other organizations about which this interrogatory inquires. INTERROGATORY NO. 40: For each trade organization, association or other entity identified in your Answer to Interrogatory No. 39, state: . -39 (a) Dates of membership; associate; (b) Type of membership, i.e., regular or (c) The dates and type of meetings you attended and the identity of the individuals who attended such meetings on your behalf; (d) The identity, title, duties and responsibilities of any individual who held an elected, appointed or self-designated position within said organization, etc.; (e) The names of any publications or written materials distributed by or on behalf of said organization, etc.; and (f) The identity of the present custodian of all written materials, notes, summaries, minutes or transcripts relating to the transactions and proceedings of said organization, etc.; RESPONSE NO. 40: Refer to response to interrogatory no. 39. INTERROGATORY NO. 41: For each trade organization, association or other entity identified in your Answer to Interrogatory No. 39, identify all studies, tests, research, recommendations, suggestions, seminars, symposia and/or speeches conducted or made which concerned, discussed, addressed or dealt with the actual, alleged or possible health hazards associated with exposure to asbestos. RESPONSE NO. 41: This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this defendant engaged in the manufacture, sale and distribution of its asbestos-containing products. Without waiving its objection, defendant states that it has not found any information in its records sufficient to answer this interrogatory. -40- INTERROGATORY NO. 42: With respect to each study, test, research project recommendation, suggestion, seminar, symposium or speech identified in your Answer to Interrogatory No. 41, identify: (a) The individuals or groups involved therein; (b) The date(s) thereof; * (c) The complete results thereof; (d) The recommendations, if any, which were made as a result thereof; and (e) The custodian, identity and location of each document which represents, refers to or contains information relating thereto. RESPONSE NO. 42: Refer to objection to interrogatory no. 41. INTERROGATORY NO. 43: Describe each action taken by you as a result of each study, test, research project, recommendation, suggestion, seminar, symposium and/or speech identified in your Answer to Interrogatory No. 41. In your Answer to this Interrogatory, state the date of each action and the identity of the individual(s) who initiated said action. RESPONSE NO. 43: Refer to objection to interrogatory no. 41. INTERROGATORY NO. 44: State whether you directed, sponsored, financed, participated in or received the results of any studies and/or tests performed by the Saranac Laboratory of the Trudeau Foundation concerning the human health consequences of exposure to asbestos. RESPONSE NO. 44: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 and does not have any records from which it can obtain information sufficient to answer this interrogatory. During May, 1979, various papers and reports were produced by an employee of the Trudeau Institute, Mr. Allan Logie, regarding animal experiments conducted at laboratories at -41- Saranac Lake involving dust collected during the Kaylo manufacturing process. These papers and reports may contain information relating to the substance of this interrogatory. The employee, Mr. Logie, had no personal knowledge'about the course or conduct of any such experiments, the preparation of papers and reports he produced or the retention or completeness of those papers and reports. Therefore, he could not authenticate these papers and reports. This defendant has not been able to find these papers and reports in its business records or correspondence although it has searched for and continues to search for them. This defendant's counsel obtained copies of some of the papers and reports produced by Mr. Logie. However, these copies constitute only a portion of a larger volume of papers and reports which this defendant has not copied. They are available at Milbank, Tweed, Hadley & McCloy, One Chase Manhattan Plaza, New York, New York. This defendant also has reason to believe that plaintiffs' counsel has copies of the documents produced by Mr. Logie. Other documents possibly relating to this interrogatory may have been produced by Owens-Corning Fiberglas Corporation. INTERROGATORY NO. 45: If your Answer to Interrogatory No. 44 is in the affirmative, identify: (a) All documents in your possession or control which summarize or explain the results of said studies or tests; (b) All communications, oral or written, between you and Saranac Laboratory personnel, including but not limited to Gerrit W. Schepers, M.D.; -42- (c) All documents relating to Saranac Laboratory studies or tests which were received or submitted by you, either directly or indirectly through predecessor(s) in interest, subsidiary (ies) or affiliate (s), if any, through other companies, or through any trade associations, organizations or entities; (d) All recommendations or findings of such studies in relation to: (i) adequacy or inadequacy of the threshold limit values; (ii) the substitution of materials for asbestos; and (e) The custodian and location of all documents and/or communications identified in your Answer to this Interrogatory. RESPONSE NO. 45: Refer to response to interrogatory no. 44 . INTERROGATORY NO. 46: State the amount of money spent or contributed by you annually from 1930 to the present for research of the relationship between exposure to asbestos dusts, fibers and/or products and any pulmonary pathology and identify each person or organization to whom the expenditure or contribution was made. RESPONSE NO. 46: This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 47: State whether you have ever maintained a library (or libraries) which contains books, articles, periodicals, journals and/or reference materials that relate to the subjects of asbestos, industrial hygiene, medicine, safety, occupational disease and/or engineering. If so, state: (a) The date each such library was established; (b) The location of each such library; (c) The identity of each librarian or other person in charge of the operation and materials of each such library; IL -43- established; (d) For whose use each such library was (e) The title, publisher and dates of subscription to or acquisition of each such periodical or journal for each such library; and (f) The title, author, publisher, date and dates of acquisition of each such article and book for each such library. RESPONSE NO. 47: During the period of time pertinent to these actions, this defendant did not maintain an entity which would be characterized as an industrial hygiene, medicine, safety and/or engineering library. However, this defendant believes that a separate engineering library may have been maintained by its technical facility. This defendant also states that although it has no records indicating the existence of such a library, upon becoming involved in asbestos-related litigation this defendant listed all the publications which were in its then- existing industrial hygiene library. These publications are listed on Exhibit II. This defendant has not yet determined which, if any, of these publications were in this defendant's possession during the time it manufactured, sold and distributed asbestos-containing products. INTERROGATORY NO. 48: State whether any of the co defendants in asbestos litigation have ever furnished you with any information as to the state of the medical knowledge at any time regarding the relationship between exposure to asbestos dusts, fibers and/or products and the contracting of diseases, including asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers. RESPONSE NO. 48: This defendant objects to this interrogatory as being irrelevant and not reasonably calculated to lead to the discovery of admissible evidence and not limited J 'VHv4^ -44- to any issue which is the subject of this case. This defendant further objects to this interrogatory on the grounds that it seeks information within the work-product privilege and on the ground that it is oppressive and burdensome in that it would have to review all of the files and all of the records of all of its attorneys all over the country to respond to this interrogatory. INTERROGATORY NO. 49: If your Answer to Interrogatory No. 48 is in the affirmative, identify: (a) How the information was furnished; (b) Who furnished said information; (c) When said information was given to you; and (d) The substance of said information. RESPONSE NO. 49: Refer to objections to interrogatory no. 48. INTERROGATORY NO. 50: State whether, at any time since 1930, you have interchanged, exchanged or communicated, the results of research, tests, studies or experiments regarding the relationship between exposure to asbestos dusts, fibers and/or products and the contracting of diseases, including asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers, with any other person, corporation or other business entity, including co-defendants in this action. RESPONSE NO. 50: This defendant objects to this interrogatory insofar as it may seek to discover work product of counsel and trial preparation material. Without waiving such objection, this defendant states that it ceased the manufacture, sale and distribution of asbestos-containing products and does not have any records of having interchanged any of the material referred to in this interrogatory with any of the other defendants named in this case; however, this defendant states that defendant Owens-Corning Fiberglas Corporation was entitled -45- to receive and may have received from this defendant material of the type specified in this interrogatory pursuant to an Agreement dated March 9, 1958 by which this defendant sold the Kaylo Division to Owens-Corning Fiberglas, if in fact this defendant had any material of said type at that time. This defendant's investigation into the subject matter of this interrogatory is continuing. INTERROGATORY NO. 51: If your Answer to Interrogatory No. 50 is in the affirmative, state: (a) When said interchanges, exchanges or communications occurred; (b) The identity of those persons, corporations or business entities who participated in said interchanges, exchanges or communications; (c) The content of said interchanges, exchanges or communications; and (d) The identity of the custodian of any documents which relate to said interchanges, exchanges or communications. RESPONSE NO. 51: Refer to objection and response to interrogatory no. 50. INTERROGATORY NO. 52: Identify all persons who have testified on your behalf before the Occupational Safety and Health Administration, the National Institute of Occupational Safety and Health, any United States congressional committee, sub-committee, administrative hearing or investigative proceeding on the subjects of the human health consequences of exposure to asbestos dusts, fibers and/or products and the setting, modification, feasibility and acceptance of allegedly safe or proper levels of exposure to said asbestos and asbestos products. RESPONSE NO. 52: This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not -46- reasonably calculated to lead to the discovery of admissible evidence. Without waiving its objection, this defendant states that no such testimony has been given. INTERROGATORY NO. 53: Identify all documents presented to or utilized in the preparation of testimony before the organizations, agencies or committees referred to in Interrogatory No. 52, specifying which documents were presented or utilized for each such body and the present custodian and location of each document. RESPONSE NO. 53: Not applicable. Refer to objection and response to interrogatory no. 52. INTERROGATORY NO. 54: For all testimony or presentations identified in your Answer to Interrogatory No. 52, identify: (a) The dates and descriptions of the hearings and proceedings; (b) The relationship between the person who testified or responded and you; and (c) All studies, test results, scientific and/or medical documents relied upon by each person as the basis for any recommendation made or testimony given; RESPONSE NO. 54: Not applicable. Refer to objection and response to interrogatory no. 52. INTERROGATORY NO. 55: State your knowledge relating to the meaning of "threshold limit value" as it pertains to asbestos exposure and disease. RESPONSE NO. 55: This defendant understands the term "threshold limit value" as it pertains to the asbestos trade to mean the maximum average atmospheric concentration of asbestos dust to which workers may be exposed for an eight hour day without injury to health. During the period of time this defendant manufactured, sold and distributed asbestos-containing products, the threshold limit value for asbestos dust, as taken -47- from the published transactions and other material of the American Conference of Governmental and Industrial Hygienists was 5,000,000 particles of asbestos dust per cubic foot of air. INTERROGATORY NO. 56: With reference to "threshold limit value" (which, for purposes of this interrogatory, means how much asbestos dust and/or fibers one can safely inhale, absorb or ingest without risk of disease or illness), state: (a) When and by what means you obtained information related thereto; (b) The substance of any information imparted to you regarding the same; and (c) Whether and by what means you advised or warned anyone of details relating thereto. RESPONSE NO. 56: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. It has not located information in its records that would enable it to answer this interrogatory. However, it appears that this defendant was aware of the TLV for asbestos dust and other dusts as published by the American Conference of Governmental Industrial Hygienists (ACGIH) in the mid- to late- 1940s or 1950s. During the 1940s and after, it appears that an employee of this defendant subscribed to and received the Journal of Industrial Hygiene and Toxicology which contained, in 1946, an article entitled "A Health Survey of Pipe Covering Operations in Constructing Naval Vessels," by Fleischer, Drinker and others which discusses safe levels of asbestos. Also, this defendant was a member of the Industrial Hygiene Foundation in 1946. The transactions of the Eleventh Annual Meeting, Industrial Hygiene Foundation, dated November 7, 1946 contain, beginning at page 71, -48- an explanation by J. J. Bloomfield of then-existing threshold limit values including the TLV for asbestos, it also appears that an employee of this defendant subscribed to and received the * journal, Industrial Hygiene and Occupational Medicine, which \ contained in 1951, an abstract of an article entitled "A Contribution to the Study of Asbestosis" by P. Cartier, which refers to the TLV for asbestos. Further, in May, 1979, various papers and reports were produced by an employee of the Trudeau Institute, Mr. Allan Logie, regarding animal experiments conducted at laboratories at Saranac Lake, New York purportedly involving dust collected during the manufacture of Kaylo. These papers and reports may contain information related to the substance of this interrogatory. This defendant has not been able to find those papers and reports in its business records or correspondence although it has searched for and continues to search for them. Among those papers and reports is a paper dated May 29, 1951 which refers to the TLV for asbestos dust. Additionally, Owens-Corning Fiberglas Corporation produced, in various cases in 1979, papers purporting to relate to this defendant's asbestos-containing product business. One such paper is a copy of a letter to Dr. Miriam Sachs, Chief, Bureau on Adult and Industrial Health, State of New Jersey Department of Health, Trenton, New Jersey regarding State standards. Neither the documents produced by Owens-Corning Fiberglas Corporation nor those produced by Mr. Logie have been located in this defendant's records. -49- INTERROGATORY NO. 57: State whether you ever knew that any governmental, private agency, and/or other entity issued guidelines suggesting a "threshold limit value" (as defined in Interrogatory No. 56} for exposure to asbestos dust and/or fibers. If so, state: (a) The identity of the agency br other entity which issued said guidelines; (b) The verbatim content of said guidelines; (c) The date said guidelines were issued; (d) The date you were first aware of the purpose of said guidelines; and (e) The custodian, location and identity of all documents related thereto. t RESPONSE NO. 57: Refer to response to interrogatory no. 56. INTERROGATORY NO. 58: State whether you ever possessed knowledge of documents indicating that existing or proposed threshold limit values (as defined in Interrogatory No. 56) were not safe or proper or that lower threshold limit values were necessary in order to prevent diseases caused by exposure to asbestos. If so, identify: (a) The source of such knowledge; (b) The persons who obtained such knowledge; (c) All documents relating thereto; and (d) The custodian and location of all documents . identified in your Answer to Part (c) of this Interrogatory. RESPONSE NO. 58: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 59: State whether you were ever made aware that the proper method for determining safe levels of asbestos dust was to test concentrations of asbestos fibers in the air rather than the total number of asbestos particles in the air. If so, state: -50- (a) The source of such knowledge; (b) The persons who obtained such knowledge; (c) All documents relating thereto; and (d) The custodian and location of all documents identified in your Answer to Part (c) of this Interrogatory. RESPONSE NO. 59: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. The threshold limit value ("TLV") for asbestos during the period in which this defendant manufactured asbestos- containing products, and for some time thereafter, was based upon a time weighted average under a count of asbestos only, including asbestos particles and asbestos fibers. This interpretation is described at various times in the literature. In that regard, see, for example, the Fleischer-Drinker report of 1946, which breaks out the asbestos component of total dust for analysis. Also, see a 1953 article by Isselbacher, Klaus, and Hardy, "Asbestosis and Bronchogenic Carcinoma'', American Journal of Medicine, p. 721 (Nov. 1953), in which the authors note that "experience has led to the acceptance of five million particles of asbestos per cubic foot of air, of small enough size to be respirable, to be the safe working concentration for asbestos." Also, please see a report of the committee of the American College of Chest Physicians in 1964, "Asbestosis - Report of the Section on Nature and Prevalence Committee on Occupational Diseases of the Chest", 45 Disease of the Chest, p. 107 (1964), in which it noted that several governmental agencies recommended five million asbestos particles of any length per cubic foot of -51- air as a safe value for asbestos exposure while other hygienists in 1964 were considering 10 million particles of total dust to be a safe limit. This confirms that the five million standard was then interpreted to be a standard applicable to'asbestos dust and not the total dust. Other articles which this defendant would call to your attention are the Fleischer-Drinker article as noted previously, the Dreessen article as noted previously, and the article by J. J. Bloomfield as noted previously. Further, this defendant would call to your attention the annually published threshold limit values of the American Conference of Governmental Industrial Hygienists. Defendant would also call to your attention an article by E. L. Schall, "Present Threshold Limit Value in the U.S.A. for Asbestos Dust: "A Critique", 132 Annals New York Academy of Sciences, p. 316 (1965) ; and articles by Balzer and Cooper beginning in 1968 entitled, "The Work Environment of Insulating Workers", Vol. 29, American Industrial Hygiene Assoc. Journal, p. 22 (May-June 1958) in which compliance with threshold limit values in shipyards is discussed. There it is indicated that even on a topal dust standard, compliance with the TLV was being observed by the authors. INTERROGATORY NO. 60: State in detail what tests or studies, if any, you ever conducted or directed with regard to the quantity, quality, or threshold limit values as defined in Interrogatory No. 56 of asbestos dust, fibers or particles to which insulators and others who use your asbestos products and/or others working in the same vicinity are exposed. RESPONSE NO. 60: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in -52- its records sufficient to enable it to answer this interrogatory. However, information indicating that the level of exposure of insulation workers was below recognized TLV's was readily available in the medical literature after 1946. INTERROGATORY NO. 61: State in detail what research, tests or studies, if any, you ever conducted or directed to determine whether the exposure of insulation workers or others to asbestos dust exceeded the American Conference of Governmental Industrial Hygienists' (A.C.G.I.H.) recommended threshold limit values. RESPONSE NO. 61: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 62: State in detail what steps, if any, you ever took to determine whether the American Conference of Governmental Industrial Hygienists' (A.C.G.I.H.) recommended threshold limit values for exposure to asbestos dust were accurate or reliable. RESPONSE NO. 62: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 63: State your knowledge relating to the meaning of "dose response relationship" as it pertains to exposure to asbestos dusts, fibers and/or products and the contracting of disease, including: asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers. RESPONSE NO. 63: It is the defendant's understanding of the term "dose response relationship" that the amount of a substance one is exposed to is related to the possibility of development of disease and related to the latency period. Dose is related to intensity and duration of exposure. During the -53- time this defendant was involved in the asbestos-containing product business, it was this defendant's understanding of the state-of-the-medical art that there was a safe "dose" or level of asbestos to which one could be exposed without risk of disease and that workers such as plaintiff were not exposed to levels above this safe level. INTERROGATORY NO. 64: State whether you have ever placed any warranties, guarantees or other such representations on any asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 and/or on or in the containers or packages in which said products were sold, distributed or otherwise placed in the stream of commerce. RESPONSE NO. 64: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 65: If your Answer to Interrogatory No. 64 is in the affirmative, for each such product and/or container or package, identify: (a) The inclusive dates on which each such warranty, guarantee or other representation appeared on or with the product and/or on or in the container or package; (b) A verbatim description of each such warranty, guarantee or other representation; (c) A description of the location on the product and/or container where each such warranty, guarantee or other representation was placed; (d) Each of your present or former highest supervisory employees with knowledge of the decision to place any such warranties, guarantees or other representations on or with the product and/or on or in the container or package; and (e) The custodian of all documents in your . custody, possession or control which relate to or describe any such warranties, guarantees or other representations or the decision to place any of these on or with the product and/or on or in the container or package. -54- RESPONSE NO. 65: Refer to response to interrogatory no. 64. INTERROGATORY NO. 66: State whether the content and/or placement of any warranty, guarantee or other representation described in your Answer to Interrogatory Nos. 64 and 65 was ever changed. If so, for each such change, identify: (a) The nature of the change, including a verbatim description, if applicable; (b) The date when the change was made and the inclusive dates during which such change appeared on or with the product and/or on or in the container or package? (c) The persons with personal knowledge of the reasons for making the change; and (d) The custodian of documents in your custody, possession or control which relate to the decision and process of making the change. no. 64. RESPONSE NO. 66: Refer to response to interrogatory INTERROGATORY NO. 67: State when and by what means you became aware of the alleged hazards of exposure to asbestos dusts, fibers and/or products to the health of persons coming into contact with, handling or using asbestos products. RESPONSE NO. 67: Insofar as this interrogatory pertains to asbestos-containing products other than Kaylo, this defendant states that it ceased the manufacture, sale and ' distribution of asbestos-containing products in 1958 and does not have any records from which it can obtain information sufficient to answer this interrogatory, nor can it locate any present employees with knowledge thereof. Insofar as this interrogatory pertains to its own asbestos-containing product, Kaylo, this defendant states that it ceased the manufacture, sale and distribution of asbestos- containing products in 1958 and does not have any records from -55- which it can obtain information sufficient to answer this interrogatory. During May, 1979, various papers and reports were produced by an employee of the Trudeau Institute, Mr. Allan Logie, regarding animal experiments conducted at laboratories at Saranac Lake involving dust collected during the Kaylo manufacturing process. These papers and reports may contain information relating to the substance of this interrogatory. The employee, Mr. Logie, had no personal knowledge about the course or conduct of any such experiments, the preparation of papers and reports he produced, or the retention or completeness of those papers and reports. Therefore, he could not authenticate these papers and reports. This defendant has not been able to find these papers and reports in its business records or correspondence although it has searched for and continues to search for them. This defendant's counsel obtained copies of some of the papers and reports produced by Mr. Logie. However, these copies constitute only a portion of a larger volume of papers and reports which this defendant has not copied. They are available at Milbank, Tweed, Hadley & McCloy, One Chase Manhattan Plaza, New York, New York. This defendant also has reason to believe that plaintiffs' counsel has copies of the documents produced by Mr. Logie. Other documents possibly relating to this interrogatory may have been produced by Owens-Corning Fiberglas Corporation. -56- Those documents found at Saranac Lake and at OwensCorning Fiberglas Corporation and elsewhere, which this defendant cannot authenticate, indicate that during the period of time when Owens-Illinois was in the business of manufacturing asbestoscontaining products, those products contained a relatively small proportion of asbestos. The inhalation of asbestos dust in excessive amounts over a prolonged period of time (years), under certain conditions, could lead to the potential hazard where exposures were in excess of recognized safe limits, that plant workers were not exposed to levels above the recognized safe limits, that users were not exposed to dust levels above the recognized safe limits, that Kaylo plant employees were x-rayed periodically and displayed no asbestos-related chest disease, and that therefore during the period in which this defendant was in the business of manufacturing Kaylo it had no reason to believe that the foreseeable use of Kaylo would create a hazard to users. The documents produced by Owens-Corning Fiberglas Corporation indicate that the September, 1955 publication in the A.M.A. Archives of Industrial Health was a publication of inhalation experiments. To the extent that this interrogatory seeks the production of documents, such documents, as outlined in this response, have not been found as part of this defendant's records and, to the extent that this defendant is in possession of copies of documents, it possesses copies only of documents collected in preparation for litigation. This defendant objects to producing the same. The documents are available from their proper source. -57- INTERROGATORY NO. 68: State when and by what means you became aware that exposure to asbestos dusts, fibers and/or products was acknowledged to be hazardous to the health of persons coming in contact with, handling or using asbestos products. no. 67. RESPONSE NO. 68: Refer to response to interrogatory INTERROGATORY NO. 69: State whether you ever learned that there is a causal connection between exposure to asbestos dust and: (a) Asbestosis; (b) Pneumoconiosis; (c) Lung Cancer; (d) Mesothelioma; and (e) Other cancers. RESPONSE NO. 69: (a-b) During the period of time in which this defendant engaged in the manufacture, sale and distribution of its asbestos-containing products, it was this defendant's understanding that the inhalation of asbestos dust in excessive amounts over a prolonged period of time (years), under certain conditions, could lead to the potential hazard of, contracting a disease known as asbestosis. However, in 1958 and before and for some years thereafter, the state of the medical and scientific knowledge was to the effect that there was a safe level of asbestos to which a person could be exposed without risk of injury and to the effect that persons such as plaintiffs were not exposed to excessive amounts of asbestos. (c-e) This defendant objects to this interrogatory on the basis that the term causal connection is vague, ambiguous and unintelligible. Defendant also objects on the basis that its -58- present knowledge is irrelevant to this action in that evidence of a causal connection between mesothelioma or any form of cancer and asbestos was first accepted by medical science after the period of time defendant ceased the manufacture of asbestos- containing products. Without waiving its objections, defendant is informed and believes that at no time prior to 1958 was there reason to believe that the medical and scientific community accepted that there was a causal connection established between exposure to asbestos and a risk of contracting mesothelioma or any form of cancer. INTERROGATORY NO. 70: If your Answer to Interrogatory No. 69 is in the affirmative, identify the following as to each such disease listed therein: (a) When and by what means you first became aware of such causal connection; (b) If your awareness of such causal connection was obtained at any conference, lecture, convention, symposium, or other such meeting, identify the event, the person who attended on your behalf and/or any documents obtained from such event; and (c) If your awareness of such causal connection was obtained from a medical or scientific study, or from any other published works, identify the same. no. 69. RESPONSE NO. 70: Refer to response to interrogatory INTERROGATORY NO. 71: State whether you ever specifically informed the purchasers and/or users of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 that exposure to asbestos dust could cause asbestosis, pneumoconiosis, lung cancer, mesothelioma and/or other cancers. If so, state: users; (a) The date(s) of such notice to purchasers or notice; (b) The means used for transmittal of such -59- (c) The custodian, identity and location of each document which refers to or contains information relevant to such notice; and (d) The identity of each person .who made decisions regarding the furnishing of such notice to purchasers and/or users. RESPONSE NO. 71: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm. INTERROGATORY NO. 72: State whether you ever specifically informed the distributors identified in your Answer to Interrogatory No. 20 and/or those identified in your Answer to Interrogatory No. 21 who resold or redistributed your asbestos products that exposure to asbestos dust could cause asbestosis, pneumoconiosis, lung cancer, mesothelioma and/or other cancers. If so, state: notice; (a) The date(s) of such notice; (b) The means used for transmittal of such (c) The custodian, identity and location of each document which refers to or contains information relevant to such notice; and (d) The identity of each person who made decisions regarding the furnishing of such notice to distributors and/or those engaged in the resale or redistribution of your asbestos products. RESPONSE NO. 72: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. -60- 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. INTERROGATORY NO. 73: State whether you ever provided any caution, notice, warning or other statement or explanation of the potential health hazards of exposure to asbestos on or with the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. RESPONSE NO. 73: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm. INTERROGATORY NO. 74: If your Answer to Interrogatory No. 73 is in the affirmative, state as to each product identified in your Answer to Interrogatory Nos. 8 and 19: (a) The date(s) on which such caution, notice, warning or other statement or explanation first appeared; (b) The identity of each person with knowledge of decisions made regarding the use of such caution, notice, warning or other statement or explanation; (c) The verbatim content of each caution, notice, warning or other statement or explanation when it was first used; (d) Whether the caution, notice, warning or other statement or explanation was ever altered, amended or changed. If so, how, when and why was it altered, amended or changed; and (e) The location of the caution, notice, warning or other statement or explanation on each such product and/or its container or package. -61- no. 73. RESPONSE NO. 74: Refer to response to interrogatory INTERROGATORY NO. 75: State when you first became aware that asbestos products were being labeled 'with a caution, warning, notice or other statement or explanation concerning the potential health hazards resulting from the use of asbestos products and/or exposure to asbestos dust or fibers and identify the product(s) and manufacturer(s) with which such label was connected. RESPONSE NO. 75: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. However, defendant is of the belief that other companies did not issue warnings until after this defendant ceased its operation in 1958. ' INTERROGATORY NO. 76: Identify the officer, agent, servant, employee or other representative of yours who first obtained an awareness that asbestos products were being labeled as described in Interrogatory No. 75. no. 75. RESPONSE NO. 76: Refer to response to interrogatory INTERROGATORY NO. 77:, Identify the custodian, identity and location of all documents related to the knowledge obtained by you regarding the labeling of asbestos products as described in Interrogatory No. 75. RESPONSE NO. 77: Refer to response to interrogatory no. 75. INTERROGATORY NO. 78: State when and by what means you first became aware that Johns-Manville Corporation or any of its affiliated companies placed on its asbestos products a caution, warning, notice, other statement or representation concerning the potential health hazards resulting from the use of asbestos products and/or exposure to asbestos dust or fibers. -62- ) RESPONSE NO. 78: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 79: Identify the officer, agent, servant, employee or other representative of yours who first became aware that asbestos products of Johns-Manville Corporation or its affiliated companies were being labeled as described in Interrogatory No. 78. RESPONSE NO. 79: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 80: Identify the custodian, identity and location of all documents related to the knowledge obtained by you regarding the labeling of asbestos products by Johns-Manville Corporation or its affiliated companies as described in Interrogatory No. 78. RESPONSE NO. 80: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 81: If upon learning that Johns- Manville Corporation or its affiliated companies labeled its asbestos products as described in Interrogatory No. 78 you did not apply such labels to the products identified in your Answer to Interrogatory Nos. 8 and 19, state: (a) The reason(s) for such a decision? (b) The identity of any agent, servant, employee, officer or representative of yours involved in discussions and decisions regarding the same; and (c) The custodian, identity and location of all documents pertaining to such a decision. -63- RESPONSE NO. 81: Not applicable to this defendant. INTERROGATORY NO. 82: State whether you specifically informed your employees, agents, servants and/or contract units that use of asbestos products and/or exposure to asbestos dust or fibers was either actually or alleged to be hazardous to their health. RESPONSE NO. 82: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 83: If your Answer to Interrogatory No. 82 is in the affirmative, state: (a) When and in what manner you first provided such information to these persons; (b) The identity of any agent, servant, employee, officer or representative of yours involved in discussions and decisions regarding providing information to these persons; (c) The verbatim content of any written documents and/or communications containing such information; and (d) The custodian, identity and location of all documents which relate or pertain to providing such information to these persons. no. 82. RESPONSE NO. 83: Refer to response to interrogatory INTERROGATORY NO. 84: Describe in detail any precautionary procedures which you urged or required your employees, agents, servants and/or contract units to follow so as to reduce and/or avoid the potential hazards or dangers associated with use of asbestos products and/or exposure to asbestos dust or fibers and state when and how each such procedure was introduced to these individuals. RESPONSE NO. 84: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958, and does not have any records from which it can obtain information sufficient to enable it to answer this -64- interrogatory . Documents which have been located in places other than Owens-Illinois, Inc., indicate that plant workers received periodic chest x-rays pursuant to established company policy, that such x-rays and related health evaluations showed no asbestos-related plant worker lung disease. From the foregoing documents, it further appears that Owens-Illinois, Inc. made efforts to provide ventilation and to control the emissions of dust emitted during the manufacturing process within recognized safe levels of exposure, including the use of respirators in some instances, dust collection equipment and other devices as necessary. INTERROGATORY NO. 85: State whether you ever required your employees, agents, servants and/or contract units who worked with and around asbestos and/or asbestos products to wear respirators, gas masks, protective clothing and/or other protective devices. If so, state: (a) Which employees, agents, servants and/or contract units, by type of employment and department, were required to use each such protective device; (b) The date(s) on which the directive relative to each such protective device was issued for each type of employee and each department? , (c) Which type of protective device was required to be used or worn by each type of employee and each department; (d) The identity of any agent, servant, employee, officer or representative of yours involved in discussions and decisions regarding the same; and (e) The custodian, identity and location of all documents pertaining to protective devices. RESPONSE NO. 85: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 and does not have any records from which it can obtain information sufficient to answer this interrogatory. -65- During May, 1979, various papers and reports were produced by an employee of the Trudeau Institute, Mr. Allan Logie, regarding animal experiments conducted at laboratories at Saranac Lake involving dust collected during the Kaylo manufacturing process. These papers and reports may contain information relating to the substance of this interrogatory. The employee, Mr. Logie, had no personal knowledge about the course or conduct of any such experiments, the preparation of papers and reports he produced or the retention or completeness of those papers and reports. Therefore, he could not authenticate these papers and reports. This defendant has not been able to find these papers and reports in its business records or correspondence although it has searched for and continues to search for them. This defendant's counsel obtained copies of some of the papers and reports produced by Mr. Logie. However, these copies constitute only a portion of a larger volume of papers and reports which this defendant has not copied. They are available at Milbank, Tweed, Hadley & McCloy, One Chase Manhattan Plaza, New York, New York. This defendant also has reason to believe that plaintiffs' counsel has copies of the documents produced by Mr. Logie. Other documents possibly relating to this interrogatory may have been produced by Owens-Corning Fiberglas Corporation. INTERROGATORY NO. 86: State whether at the commencement of an individual's employment with you, from 1930 to the present, you inform that person as to possible health ramifications of working with and around asbestos fibers, dust and/or products. If so, set forth: -66- (a) The nature of the warning; (b) The manner in which said information is communicated and, if the communication is in writing, attach a copy hereto; (c) When such practice was initiated; and (d) By whom such information is communicated. RESPONSE NO. 86: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm. ' INTERROGATORY NO. 87: State whether, based upon the material contents, the manufacturing methods and the method of application or installation of your asbestos products, your asbestos products can generally be applied by an insulator or others without liberating asbestos fibers. RESPONSE NO. 87: This defendant objects to this interrogatory on the basis that the term "liberating" is,vague, ambiguous and unintelligible. Without waiving its objection, defendant states that it ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 88: State whether it was foreseeable to you that your asbestos-containing insulation products would have to be removed, stripped or replaced at any time after installation. -67- . ,t RESPONSE NO. 88: This defendant objects to this interrogatory on the basis that it constitutes an improper form of discovery in that plaintiff in effect is submitting a disguised request for admission. This defendant further objects to this interrogatory on the basis that it is vague in that no time period as to when the submitted fact was foreseeable is indicated. INTERROGATORY NO. 89: State whether you ever provided insulators and others who would be applying or removing your asbestos products instructions concerning safety precautions to use during use of or exposure to such products. RESPONSE NO. 89: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 90: State when you first received notice that any person was claiming injury as a result of use of and/or exposure to asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. RESPONSE NO. 90: This defendant received its first lawsuit alleging asbestos-related disease in 1975. INTERROGATORY NO. 91: With regard to the first notice of claim of injury described in your Answer to Interrogatory No. 90 and regarding all claims filed prior to 1970 for injury resulting from use of and/or exposure to asbestos products, state: (a) The identity of each claimant; (b) The date of notice of each claim; (c) A description of each claim; (d) The type of injury allegedly sustained by each claimant; (e) The identity of each attorney representing the individuals making such claims; -68- (f) The style, case number and court applicable to each claim; (g) The resolution of each claim; and (h) The custodian, identity and, location of all documents which relate or pertain to each claim. RESPONSE NO. 91; This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the above objection, refer to answer to Interrogatory No. 90. INTERROGATORY NO. 92: State whether, prior to 1970, any person filed a claim against any worker's compensation insurance carrier which provided coverage for you alleging that he or she contracted a disease as a result of use of and/or exposure to asbestos products identified in your Answer to Interrogatory No. 90. RESPONSE NO. 92: During the period in which this defendant engaged in the manufacture of its asbestos-containing products, it received no workers' compensation claims for any asbestos-related disease. INTERROGATORY NO. 93: If your Answer to Interrogatory No. 92 is in the affirmative, provide the following information: (a) A list of each such claim by claimant's name, date claim filed and jurisdiction; and such claim. (b) A brief summary of the disposition of each RESPONSE NO. 93: Refer to response to interrogatory no. 92. INTERROGATORY NO. 94: State whether you ever received any reports or communications from your worker's compensation insurance carrier or products liability insurance carrier with regard to potential health hazards incident to use of asbestos products and/or exposure to asbestos fibers or dust. 69 RESPONSE NO. 94: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958, and does not have any records from which it can obtain information sufficient to enable it to answer this interrogatory. A document produced at the deposition of E. C. Shuman on June 12, 1979 in a case then pending in the United States District Court for the Eastern District of Virginia, C/P 77-I-N indicates that a "dust survey" was done by the Aetna Casualty and Surety Company, and this defendant believes that it was obtained from Aetna. This document may contain information related to the substance of this interrogatory. This defendant was not a party to that case, the deponent, Mr. Shuman, had no personal knowledge about the contents of the document, its preparation or authenticity. This defendant has not been able to find this document in its business records or correspondence, although it has searched for and continues to search for it, and therefore cannot attest to its authenticity. To the extent that this interrogatory seeks the production of documents, such documents, as outlined in this response, have not been found as part of this defendant's records and, to the extent that this defendant is in possession of copies of documents, it possesses copies only of documents collected in preparation for litigation. This defendant objects to producing the same. The documents are available from their proper source. INTERROGATORY NO. 95: If your Answer to Interrogatory No. 94 is in the affirmative, state: -70 (a) The substance of the contents of such reports or communications; (b) The identity of the insurance carrier from which you received each report or communication; (c) The dates of each such report or communication; and (d) The custodian, identity and location of all documents which relate or pertain to such reports or communications. RESPONSE NO. 95: Refer to response to interrogatory no. 94. INTERROGATORY NO. 96: State whether you ever maintained or operated a unit or units of your corporation, including, but not limited to, divisions, subsidiaries or any other entity, which was/were under contract to apply or install the asbestos products described in your Answer to Interrogatory Nos. 8 and 19. RESPONSE NO. 96: This defendant has never formed nor maintained a group or groups known as "contract units," such "contract units" being a division or group within or maintained by the corporation which, inter alia, engaged in the actual installation of insulation products containing asbestos at job sites. INTERROGATORY NO. 97: If your Answer to Interrogatory No. 96 is in the affirmative, identify any and all claims filed by workers in such contract units for disease arising out of use of asbestos products and/or exposure to asbestos fibers or dust and, as to each such claim, state: (a) The date on which you first received notice; (b) The identity of the claimant; (c) The nature of the claim; (d) The style, case number and jurisdiction; (e) The resolution of the claim; and (f) The custodian, identity and location of all documents which relate or pertain to each claim. -71- RESPONSE NO. 97: Not applicable. Refer to response to interrogatory no. 96. INTERROGATORY NO. 98: Identify any and all insurance agreements entered into by and between any person carrying on an insurance business and you which may be available to satisfy part or all of a judgment that might be entered in this action or to indemnify or reimburse you for payments made to satisfy the judgment. As to each such agreement, identify the insurance carrier, the amount of coverage and the applicable dates of coverage. RESPONSE NO. 98: This defendant objects to this interrogatory on the grounds that it seeks information which is not relevant to the subject matter of this litigation and is not calculated to lead to the discovery of admissible evidence. Without waiving the above objections, this defendant has liability coverage by its insurer, Aetna, for some of the actions brought against it which allegedly result from the use of asbestos-containing products. INTERROGATORY NO. 99: Describe the method by which you have maintained records concerning the manufacture, sale, advertising, distribution, delivery and installation of each of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. RESPONSE NO. 99: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 pursuant to the sale of its Kaylo division to Owens-Corning Fiberglas Corporation on April 30, 1958. It has not found any information in its records pertinent to a record or document retention policy during the period when it manufactured its asbestos-containing products or for the period of years shortly thereafter. In accordance with the contract for the sale of the Kaylo division, in the ordinary course of business -72- relating to such sale, and because of the production of certain documents by counsel for Owens-Corning Fiberglas Corporation in several jurisdictions involving asbestos-related litigation in the United States, this defendant believes that most of its records pertinent to the Kaylo division were either transferred or made available to the purchaser of the division in 1958. This defendant states that it has not destroyed any documents or records pertaining to the Kaylo division which have been found in its records in 1975 (the year in which this defendant first became aware of asbestos-related actions against it) and thereafter. INTERROGATORY NO. 100: With regard to the record keeping method described in your Answer to Interrogatory No. 99, identify: (a) Each present and former corporate department, division or subdivision responsible for maintaining the records; (b) How the records are kept, e.g.,in boxes, files, on microfilm, microfiche or computer tape or disk; (c) The inclusive dates of manufacture, sale, advertising, distribution, delivery and installation that the record keeping system covers; , (d) The location(s) where such records are maintained; and (e) The identity of each person employed by you at any time from 1930 to the present, in the highest supervisory capacity, who is or was directly responsible for the collection and maintenance of such records. RESPONSE NO. 100: Refer to response to interrogatory no. 99. INTERROGATORY NO. 101: If the record keeping system described in your Answer to Interrogatory No. 99 includes use of microfilm, microfiche, computer tape or disk or any other system in which data is taken from other records, state whether you have -73- retained the documents or other material from which the information entered into these modes of storage was obtained. not, indicate: If (a) The date when and location where the original records were destroyed or discarded; . (b) The custodian and location of the records prior to their destruction; and (c) The identity of each employee, representative, official or agent of yours who ordered, authorized or supervised said destruction. RESPONSE NO. 101: Refer to response to interrogatory no. 99. INTERROGATORY NO. 102: State whether, at any time . from 1930 to the present you made any representations that the presence of asbestos in the products identified in your Answer to Interrogatory Nos. 8 and 19 made these products superior, in any way, to any asbestos-free product or material intended for the same or similar use. RESPONSE NO. 102: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 103: If your Answer to Interrogatory No. 102 is in the affirmative, indicate with respect to each such representation: made; (a) The date(s) on which the representation was (b) Its exact content; and (c) The manner in which it was communicated. RESPONSE NO. 103: Refer to response to interrogatory no. 102. INTERROGATORY NO. 104: State whether, at any time from 1930 to the present, you made any representations that the use of asbestos or the use of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 was safe, harmless or not dangerous. -74- RESPONSE NO. 104: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm. INTERROGATORY NO. 105: If your Answer to Interrogatory No. 104 is in the affirmative, indicate as to each such representation: made ; (a) The date(s) on which the representation was (b) Its exact content; and (c) The manner in which it was communicated. RESPONSE NO. 105: Refer to response to interrogatory no. 104. INTERROGATORY NO. 106: State whether any of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 were ever stored or warehoused by you in Maryland at any time from 1930 to the present. RESPONSE NO. 106: This defendant objects to interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this defendant engaged in the manufacture, sale and distribution of its asbestos-containing products. Without waiving its objection, this defendant states that it ceased the manufacture, -75- sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 107: If your Answer to Interrogatory No. 106 is in the affirmative, identify: facility; (a) The address of each warehouse or storage (b) The asbestos products stored or warehoused at each warehouse or storage facility identified in your Answer to part (a) of this Interrogatory; (c) The year(s) of such storage or warehousing; and (d) The custodian, identity and location of each document in your custody, possession or control which describes or relates to such storage or warehousing. RESPONSE NO. 107: Refer to response to interrogatory no. 106. INTERROGATORY NO. 108: Identify the means by which the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 were transported to Maryland at any time from 1930 to the present and state: (a) If the asbestos products were transported by rail, identify the name(s) of the railroad company(ies) providing that service and the year(s) during which such service was used; (b) If the asbestos products were transported by truck, identify the name(s) of the carrier providing that service and the year(s) during which such service was used; (c) If the asbestos products were transported by vessel, identify the name(s) of the shipline providing that service and the year(s) during which such service was used; (d) The identity of each employee of yours responsible for coordinating the transport or delivery of such products to Maryland? (e) The identity of each employee, officer, agent or representative of yours with personal knowledge of the transport or delivery of such products to Maryland; and -76- (f) The custodian, identity and location of each document which describes or relates to the transport or delivery of such products to Maryland. RESPONSE NO. 108: This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 109: Identify each person whom you expect to call as an expert witness at trial, state the subject matter on which each expert is expected to testify, state the substance of the findings and opinions to which each expert is expected to testify and a summary of the grounds for each opinion and produce any written report made by each expert concerning those findings and opinions. RESPONSE NO. 109: The identity of expert witnesses to be called at trial is not known at the present time. This defendant reserves the right to designate at a later date expert witnesses to be used at trial. INTERROGATORY NO. 110: With regard to expert witnesses identified in your Answer to Interrogatory No. 109, identify by case name, date, court and case number any deposition or testimony given by each such expert and state the custodian and location of transcripts thereof. RESPONSE NO. 110: Refer to response to interrogatory no. 109. INTERROGATORY NO. Ill: Identify each person who has testified on your behalf at trial or by deposition in a case alleging asbestos-related injury, state the custodian and location of transcripts thereof, and set forth the case name, number, court and date with respect to each proceeding in which the witness testified. -77- RESPONSE NO. Ill: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant is aware that the following present or former employees have testified at trial or by deposition in asbestos-related litigation: Edward C. Ames 10/8/79, 1/10/80, 2/12/81, 3/26/81 and 10/7/81. Robert Grim 9/6 & 7/84, 10/11/84 Richard L. Grimmie 7/10/79, 10/24/79 (trial) and 10/29/79 (trial). David Innis 9/27/83. William Justice 7/11/79 and 5/3/82. John Pershing 7/26/79. John Rhoads 7/11/79. June Welser 7/11/79. Everett Shuman 4/26/79, 6/12/79, 7/15/80, 8/19/80, and 3/4/81. Willis G. Hazard 2/11/80, 2/11/81, 3/27/81, 12/14/81, 1/27/82. Richard R. Beck 4/1/81 and 8/12/82. Samuel F. Schillaci 4/7/81, 7/31/81 (trial), 11/9/81 (trial), 11/17/81, 3/10/82, 4/26-27/82, 6/4/84, 8/28/84, 9/6/84, 11/14/84, 2/5/85, 3/4/85 (trial), 4/30/85, 12/19/85 (trial) and 10/8/86. George N. Bates, M.D. 4/6/81. Thomas A. Meehan, Esq. 8/3/81 (trial), 11/9/81 (trial), 12/15/83, 1/16/84, 8/28/84, 6/4/84, and 11/13/84. Effective April 30, 1958, this defendant sold its asbestos-containing product manufacturing division to Owens- Corning Fiberglas Corporation. At that time certain employees who worked in the division, some of whom are mentioned above, transferred to Owens-Corning Fiberglas Corporation. These individuals have been deposed with regard to asbestos-related litigation involving Owens-Corning Fiberglas Corporation. This defendant objects to the production of copies of the transcripts of these depositions on the basis that said transcripts are filed with various courts around the country, they are therefore matters of public record, and therefore plaintiffs have equal access to such documents. Defendant reserves the right to advance additional arguments against the production of such documents if and when plaintiffs file a request for production. INTERROGATORY NO. 112: State whether you contend that asbestos products can be manufactured or treated so as to eliminate all potential health hazards to workers who use asbestos products and/or are exposed to asbestos fibers or dust. If so, explain in detail the factual basis for this contention. RESPONSE NO. 112: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 113: State whether you contend that any person or business entity not presently a party to this action is responsible in whole or in part for any of the plaintiff's(s') damages. If so, identify each such person or business entity and state the facts which form the basis for each such contention. -79- t RESPONSE NO. 113: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 and, to the extent not already pleaded, does not make the contention referred to in this interrogatory at this \ time. However, its investigation is continuing and defendant hereby reserves the right to make such contention at any time in the future as a result thereof. INTERROGATORY NO. 114: State whether you contend that asbestos products are not inherently dangerous. If so, state all facts and documents which form the basis for such a contention. RESPONSE NO. 114: This defendant objects to this interrogatory on the grounds that it is overly broad, vague, not limited to the period of time pertinent to this litigation, burdensome and oppressive, and not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 115: State whether you contend that you did not have a duty to warn users of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 of the hazards and risks of use of and exposure thereto. If so, state all facts and identify all documents which form the basis for such a contention RESPONSE NO. 115: 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. INTERROGATORY NO. 116: State whether you contend that you performed adequate tests of the safety of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. If so, state all facts and identify all documents which form the basis for such a contention. RESPONSE NO. 116: This defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to plaintiffs' counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This defendant further states that its investigation into the subject matter referred to in this interrogatory is continuing. INTERROGATORY NO. 117: State whether you contend that you did not conspire with others to allow asbestos products to be used without adequate warnings, or without any warnings, regarding the hazards or risks of use of and/or exposure thereto. If so, state all facts and identify all documents which form the basis for such a contention. RESPONSE NO. 117: Yes. During the time this defendant was involved in the asbestos-containing product business, the state of medical and scientific knowledge was such that defendant had no reason to believe that the use of its product would result in a foreseeable risk of harm. Further, this defendant was not a member of any asbestos-related trade association. This defendant reserves the right to assert any allegations related to the subject matter of this interrogatory at any time in the future. INTERROGATORY NO. 118: State whether you contend that there are circumstances under which asbestos products can safely be handled and used. If so, state all facts and identify all documents which form the basis for such a contention. RESPONSE NO. 118: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1953. This defendant is aware of evidence in medical -81- and scientific literature which would support such a contention. This defendant states that to the extent such literature exists it is public knowledge. , INTERROGATORY NO. 119: State whether you contend that there is now or has ever been a distinction between one or more of the following with respect to use of and exposure to asbestos products and the health hazards or risks relating thereto: miners, millers, textile workers, asbestos plant workers, insulators, shipyard workers, steel plant workers, building tradesmen, industrial workers, and brake lining mechanics. If so, state all facts and identify all documents which form the basis for such a contention. RESPONSE NO. 119: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant is aware of evidence in medical and scientific literature which would support such a contention. This defendant states that to the extent such literature exists it is public knowledge. INTERROGATORY NO. 120: State whether you contend that there are differences between asbestos fiber types (chrysotile, amosite, crocidolite, actinolite, anthophyllite or tremolite) with regard to diseases they may be capable of causing. If so, state all facts and identify all documents which form the basis for such a contention. RESPONSE NO. 120: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant is aware of evidence in medical and scientific literature which would support such a contention. This defendant states that to the extent such literature exists it is public knowledge. INTERROGATORY NO. 121: Name any person not heretofore mentioned having personal knowledge of the facts material to this case. -82- RESPONSE NO. 121: This defendant objects to this interrogatory on the basis that it is overly broad and ambiguous, seeks information which is not relevant to the subject matter of this litigation and not reasonably calculated to lead to the discovery of admissible evidence. PART II - SPECIFIC INTERROGATORIES TO BE ANSWERED SEPARATELY AS TO EACH PLAINTIFF For the following Interrogatories, use the following definitions: "Plaintiff's working years" means the years 19__ thru 19__ ; "plaintiff's employers" mean the companies listed on the attached Rider A, and "plaintiff's employment locations" mean those worksites listed on the attached R'ider A. INTERROGATORY NO. 1: Have you undertaken an investigation of the occurrence(s) alleged in plaintiff's Complaint? If so, state: a. The identity of the person(s) participating in each such investigation; b. Whether you have obtained statements from any witness(es) and, if so, identify: (i) The identity of each such witness; and (ii) The identity of the person in possession of each such statement. RESPONSE NO. 1: This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence and on the grounds that it may seek to discover work- product material. -83- INTERROGATORY NO. 2: State whether you contend that you had no reason or duty to warn the plaintiff or the plaintiff's employer of the hazards and risks of use of and exposure to asbestos products. If so, state all facts and identify all documents which form the basis of,such a contention. RESPONSE NO. 2: Yes. 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. Defendant reserves the right to assert any allegations relating to the subject matter of this request at any time in the future. INTERROGATORY NO. 3: State whether you contend that you gave adequate warnings to users of and to those exposed to your asbestos products, including the plaintiff, of the hazards and risks of use of and exposure thereto. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE NO. 3: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm. INTERROGATORY NO. 4: State whether you contend that you recommend safety procedures regarding the use of and exposure to asbestos products to the plaintiff or the plaintiff's employer. If so, state all facts and identify all documents which form the basis of such a contention. -84- RESPONSE NO. 4: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this interrogatory. INTERROGATORY NO. 5: State whether you contend that the plaintiff was exposed, if at all, to a safe amount of asbestos or to less than the "threshold limit" of exposure to asbestos dust and fibers from the use of and exposure to asbestos products. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE NO. 5: To the extent this interrogatory refers to a particular plaintiff, this defendant has not engaged in sufficient discovery to answer this interrogatory. Defendant reserves the right to assert any allegations related to the subject matter of this interrogatory at any time in the future. INTERROGATORY NO. 6: State whether you contend that the plaintiff's disabilities or injuries are unrelated to the use of and exposure to asbestos products. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE NO. 6: To the extent this interrogatory refers to a particular plaintiff, this defendant has not engaged in sufficient discovery to answer this interrogatory. Defendant reserves the right to assert any allegations related to the subject matter of this interrogatory at any time in the future. INTERROGATORY NO. 7: State whether you contend that the plaintiff's injuries are related in whole or in part to cigarette smoking. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE NO. 7: This defendant has not engaged in sufficient discovery to answer this interrogatory. Defendant reserves the right to assert any allegations related to the subject matter of this interrogatory at any time in the future. -85- INTERROGATORY NO. 8: State whether you contend that the plaintiffs injuries are due to an act of the plaintiff's employer. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE NO. 8: This defendant has not engaged in sufficient discovery to answer this interrogatory. Defendant reserves the right to assert any allegations related to the subject matter of this interrogatory at any time in the future. INTERROGATORY NO. 9: State whether you contend that the plaintiff did not work with and was not exposed to any asbestos products mined, manufactured, sold and/or distributed by you. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE NO. 9: This defendant has not engaged in sufficient discovery to answer this interrogatory. Defendant reserves the right to assert any allegations related to the subject matter of this interrogatory at any time in the future. INTERROGATORY NO. 10: State whether you contend that the asbestos products which the plaintiff used and/or was exposed to were not under your exclusive control. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE NO. 10: Yes. Refer to this defendant's pleadings and it's pretrial statement. INTERROGATORY NO. 11: State whether you contend that there were changes made to your asbestos products after they left your control. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE NO. 11: Refer to this defendant's pleadings and it's pretrial statement. INTERROGATORY NO. 12: State whether you contend that the plaintiff's claim is barred by the applicable statute of limitations. If so, state all facts and identify all documents which form the basis of such a contention. -86- RESPONSE NO. 12: The affirmative defenses were asserted on advice of counsel to prevent waiver of those defenses. This defendant has not yet engaged in sufficient discovery to answer this interrogatory. INTERROGATORY NO. 13: State whether you contend that the plaintiff's claim is barred by the doctrine of assumption of the risk. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE NO. 13: Yes, this defendant contends that plaintiff assumed the risk to the extent that plaintiff smoked, disregarded warnings, and did not wear a respirator or participate in other safety and health programs provided by his employer. This defendant has not engaged in sufficient discovery to further answer this interrogatory. This defendant reserves the right to supplement its answer to this interrogatory at any time in the future if appropriate under the applicable rules of civil procedure. INTERROGATORY NO. 14: State whether you contend that the plaintiff's claim is barred by his alleged contributory negligence. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE NO. 14: Yes, this defendant contends that plaintiff was contributorily negligent to the extent that plaintiff smoked, disregarded warnings, and did not wear a respirator or participate in other safety and health programs provided by his employer. This defendant has not engaged in sufficient discovery to answer this interrogatory. Defendant reserves the right to supplement its answer to this interrogatory at any time in the future if appropriate under the applicable rules of civil procedure. -87- INTERROGATORY NO. 15: State whether you contend that the plaintiff's claim is barred by his alleged misuse of the asbestos products with which he worked. If so, state all facts and identify all documents which form the basis of such a contention. % RESPONSE NO. 15: This defendant has not engaged in sufficient discovery to answer this interrogatory. Defendant reserves the right to assert any allegations related to the subject matter of this interrogatory at any time in the future. INTERROGATORY NO. 16: State whether you contend that the plaintiff's injuries were caused by any intervening acts or superseding negligence. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE NO. 16: This defendant objects to this interrogatory on the grounds that the terms "intervening acts" and "superceding negligence" are vague ambiguous and unintelligible. INTERROGATORY NO. 17: Did this defendant, by itself or through its distributors, engage in the sale of asbestos products to (or application of asbestos products at) any of the plaintiff's employment locations to or any of the plaintiff's employers during the plaintiff's working years? This Interrogatory is not limited to defendant's review of existing sales records; moreover, you are expressly asked to state what steps you took, and persons or documents you consulted, other than reviewing available sales records, in effort to answer this Interrogatory. RESPONSE NO. 17: This defendant objects to this interrogatory on the grounds that it is overly broad, burdensome and harassing, vague, ambiguous and may seek to discover work- product material and material collected and prepared only in preparation for litigation. INTERROGATORY NO. 18: If the answer to one or more parts of Interrogatory No. 2 above is affirmative, please state as to each affirmative answer the following: a. the date on which this defendant began such sales or activity; -88- b. the date on which this defendant ceased such sales or activity; c. the type of product, and quantity sold, on each such date. RESPONSE NO. 18: Refer to objection to Interrogatory No. 17. INTERROGATORY NO. 19: State the names and addresses of all individuals who have identified this defendant as a source of asbestos products to any of plaintiff's employment locations or employers in any proceeding (whether by way of answers to interrogatories, court appearance or deposition) to which this defendant was a party. RESPONSE NO. 19: This defendant objects to this interrogatory on the grounds that it is overly broad, burdensome and harassing, vague, ambiguous and may seek to discover work- product material and material collected and prepared only in preparation for litigation. -89- AFFIDAVIT STATE OF OHIO COUNTY OF LUCAS )SS: ) M. F. MCCARTHY, being duly sworn according to law, deposes and says that he is an Assistant Secretary of OwensIllinois, Inc., a defendant herein; that as such he is authorized to make an Affidavit on its behalf; and that the facts set forth in the foregoing DEFENDANT, OWENS-ILLINOIS, INC.'S ANSWERS TO INTERROGATORIES, are true and correct to the best of his knowledge, information and belief. <^7 p >*>1 cZj^~ M. F. MCCARTHY SWORN TO and subscribed 1987. Notary Public Ky Commission Expires; c exhibit II c c  American Medical Association Archives Health, published by the American Medical Association, Vol. 11, 1955, through Vol. 1958. ' . American Industrial Hygiene Association Quarterly, 1946 through 1958. Annual Review of Nuclear Science, published by Annual Reviews, Inc., 1952 through 1953; 1955 through 1957. Archives of Industrial Hygiene and Occupational Medicine, published by the American Medical Association; 1950 to 1954. '. British Journal of Industrial Medicine, published by British Medical Association, 1949 through 1958. Industrial Medicine and Hygiene, published by Butterworth and Company, 1954 through 1956. Industrial Medicine and Surgery, 1949 through 1958. C Journal of Industrial Hygiene and Toxicology, The, published by the Williams and Wilkins Company, 1928 through 1949. . Noise Control, published by the Accoustical Society of America, 1955 through 1958. .. Aids to Anatomy, Last, 1951. ' Airborne Contagion and Air Hygiene, An Ecological Study of Traupwood Infections, Wells, 1955. . Analytical Chemistry. By Treadwell, Vol. 1, Quantitative Analysis, 1937. . Chemical Analysis of Industrial Solvents, Jacobs and ^ Scheslan, 1953. Chemical Engineers' Handbook, edited by Perry, 1941. Design of Industrial Exhaust Systems, Alden, 1939. Dictionary of Modern English Usage, A, by Fowler, 1926. Electromagnetically Enriched Isotopes and Mass Spectrometry, Proceedings of the Conference Held in Cockcroft Hall, Harwell, Sept., 1955; . Encyclopedia of Instrumentation for Industrial Hygiene, edited by Yasse, Byers and Hosey, 1956. Fatigue, edited by Floyd and Welford, 1953. -2- _ Fatigue of Workers - Its Relation to Industrial Production, Committee on Work Industry of the National Research Council, 1941. ~ Fuels and Combustion, Smith and Stirison, 1952. C C 1957. Acoustics and Vibrational Physics, Stevens and Bate, 1950; ' Acoustical Engineering, Olson, 1957; Acoustic Measurements, Beranek, 1949; The Measurement of Hearing, Hirsh, 1952; - Man's World of_Sound, Pierce and David, 1958; Technical Aspects of Sound, edited by Richardsdn, 1953; Physiological Acoustics, Weaver and Lawrence, 1954 ; Fundamentals of Acoustics, 2nd Edition, Kinsler and Frey, 1950; Acoustics Noise in Buildings, Parkin and Humphreys, 1958; . Hearing and Deafness, 3-rd Edition, edited by Davis and Silverman, 1947; A Textbook of Sound, Wood, 1249; .. - Noise Reduction Manual, Geiger, 1953;' ~ Physical Acoustics, Supplement 1, edited by Lukasik and Nolle, 1955; Foundry Noise Manual, American Foundrymen's Society, 1958 and 1956; Foundry Ventilation and Dust Control, Harrogate, 1956; Body Temperature, Its Changes with Environment, Disease and Ther-apy, Selle, 1952; Applied Heat Transmission, Stoever, 1941; Heat and Temperature Measurement, Weber, 1950; Life Heat and Altitude, Dill, 1938; Heat Insulation, Wilkes, 1950; Basic Principles of Ventilation and Heating, Bedford, 1948; Heat Transmission, McAdams, 1942; Climate in Everyday Life, Brooks, 1951; Handbook of Chemistry, Lange, 195.6. . Handbook of Emergency Toxicology, Kaye, 1934. Handbook of Glass Manufacture. By Tooley, 1953. Handbook of Material Trade Names, Zimmerman and Lavine, -3-  1957: Handbook of Toxicologyeaited by Spector, 1955 and ^ History of Factory and Mine Hygiene, Teleky, 1948. . Human Machine, The, Shilling, 1955. Industrial Environment and Its Control, The, by Dallaval'e, 1948. " Industrial Medicine and Hygiene, edited by Merevether, 1954 through 1956.. Industrial Methods of Analysis, Willard, Merritt,- and Dean, 1948. _ Industrial Poisons in the United States, Hamilton, 1929. Industrial Toxicology, Hamilton and Johnstone, 1945. 1923. Introduction to Medical Biometry and Statistics, Pearl, .... . ............... .. : Introductory Quantitative Chemistry, Olson, Koch and Pimentel, 1955. . I^ang-uage Habits in Human Affairs, Lee, 1941. Manual of Industrial Eealth Eazards, Ficklen, 1940. Manual of the International List of Causes of Death, U.S. Government-Pr inting-^Office , 1929. Manual of the International Statistical Classification of Diseases, Injuries, and Causes of Death, Vol. 2, Alphabetical Index , 195.0. . Mechanical Engineer's Handbook, edited by Marks, 1951. Methods of Air Analysis. By Haldane, 1935. Noxious Gas and the Principles of Respiration Influencing their Action, Henderson and Haggard, 1927. Odor's Physiology Control, Cord and Witheridge, 1949. Preventive-Medicine and Public Health, Smillie, 1947. Professional Engineer's Examination Questions and Answers, Londe, 1956. ' Radioisotopes in Scientific Research, edited by Extermann, 1958. _ . Roget's College Thesaures, The New American Library, 1958. _ . Standard Methods of Chemical Analysis, Scott, 5th Ed it ion, 192 5." " _. . Symposium on Instrumentation in Atmospheric Analysis, published by The American Society for Testing and Materials, 1958. Toxicology and Hygiene of Industrial Solvents, edited by Lehmann and Flury,- 1943. Women in Industry - Their Health and Efficiency, * Baetjer, 1946-. Proceedings of the 9th International Congress on Industrial Medicine, 1949. The Pneumoconiosis Problem, Thomas, 1958. . ..- -5- American Medical Association Archives Health, published by the American Medical Association, Vol. 11, 1955, through Vol. 1958. ^ American Industrial Hygiene Association Quarterly, 1946 through 1958. Annual Review of Nuclear Science, published by Annual Reviews, Inc., 1952 through 1953; 1955 through 1957. Archives of Industrial Hygiene and Occupational Medicine published by the American Medical Association? 1950 to 1954. British Journal of Industrial Medicine, published by British Medical Association, 1949 through 1958. Industrial Medicine and Hygiene, published by Butterworth and Company, 1954 through 1956. .Industrial Medicine and Surgery, 1249 through 1953. Journal of*Industrial Hygiene and Toxicology, The, published by the Williams and Wilkins Company, 1928 through 1949. Noise Control, published by the Accoustical Society of America, 1955 through 1958. Aids to Anatomy, Last, 1951. ' Airborne Contagion and Air Hygiene, An Ecological Study of Traupwood Infections, Wells, 1955. Analytical Chemistry. Quantitative Analysis, 1937. By Treadwell, Vol. 1, Chemical Analysis of Industrial Solvents, Jacobs and Scheslan, 1953. Chemical Engineers' Handbook, edited by Perry, 1941. Design of Industrial Exhaust Systems, Alden, 1939. Dictionary of Modern English Usage, A, by Fowler, 1926. Electromagnetically Enriched Isotopes and Mass Spectrometry, Proceedings of the Conference Held in Cockcroft Hall, Harwell, Sept., 1955; Encyclopedia of Instrumentation for Industrial Hygiene, edited by Yasse, Byers and Hosey, 1956. Fatigue, edited by Floyd and Welford, 1953. . Fatigue of Workers - Its Relation to Industrial Production, Committee on Work Industry of the.National Research Council, 1941. . Fuels and Combustion, Smith and Stinson, 1952. 19-5 7. .Acoustics and Vibrational Physics, Stevens and Bate, 1950; ' Acoustical Engineering, Olson, 1957; Acoustic Measurements, Beranek, 1949; The Measurement of Hearing, Hirsh, 1952; Man's World of.Sound, Pierce and David, 1958; Technical Aspects of Sound, edited by Richardson, 1953; Physiological Acoustics, Weaver and Lawrence, 1954 ; Fundamentals of Acoustics, 2nd Edition, Kinsler and Frey, 1950; Acoustics Noise in Buildings, Parkin and . Humphreys, 1958; Hearing and Deafness, 3rd Edition, edited by Davis and Silverman, 1947; A Textbook of Sound, Wood, 1949; . Noise Reduction Manual, Geiger, 1953; Physical Acoustics, Supplement 1, edited by Lukasik and Nolle, 1955; . Foundry Noise Manual, American Foundrymen's Society, 1958 and 1956; Foundry Ventilation and Dust Control, Harrogate, 1956; Body Temperature, Its Changes with Environment, Disease and Therapy, Selle, 1952; Applied Heat Transmission, Stoever, 1941; Heat and Temperature Measurement, Weber, 1950; Life Heat and Altitude, Dill, 1938; Heat Insulation, Wilkes, 1950; Basic Principles of Ventilation and Heating, Bedford, 1948; Heat Transmission, McAdams, 1942; Climate in Everyday Life, Brooks, 1951; . Handbook of Chemistry, Lange, 1956. . Handbook of Emergency Toxicology, Kaye, 1954. Handbook of Glass Manufacture. By Tooley, 1953. Handbook of Material Trade Names, Zimmerman and Lavine, 1957: Handbook of Toxicology, edited by Soector, 1955 and * ^ History of Factory and Mine Hygiene, Teleky, 1948. . Human Machi*ne, The, Shilling, 1955. . Industrial Environment and Its Control, The, by Dallaval1*, lj^^. ., . "industrial Medicine and Hygiene, edited by Merewether, 1954 through 1956. Industrial Methods of Analysis,. Willard, Merritt,* and Dean, 1948. _. Industrial Poisons in the United States, Hamilton, 1929. Industrial Toxicology, Hamilton and Johnstone, 1945. 1923. Introduction to Medical Biometry and Statistics, Pearl, Introductory Quantitative Chemistry, Olson, Koch and Pimentel, 1955. Language Habits in Human Affairs, Lee, 1941. Manual of Industrial Health Hazards, Ficklen, 1940. Manual of the International List of Causes of Death, U.S. Government Printing Office, 1929. Manual of the International Statistical Classification of Diseases, Injuries, and Causes of Death, Vol. 2, Alphabetical Index, 1950. Mechanical Engineer's Handbook, edited by Marks, 1951. . Methods df Air Analysis. By Haldane, 1935. Noxious Gas and the Principles of Respiration Influencing their Action, Henderson and Haggard, 1927. Odors Physiology Control, Cord and Witheridge, 1949. Preventive Medicine and Public Health, Smillie, 1947. Professional Engineer's Examination Questions and Answers, Lonae, 1956. . Radioisotopes in Scientific Research, edited by Extermann, 1958. ' 19581 Hoget's Colleae Thesaures, The New American Library, . . Standard Methods of Chemical Analysis, Scott, 5th Edition, 19.2 5. Symposium on Instrumentation in Atmospheric Analysis, published by The American Society for Testing and Materials, 1 958. _ Toxicology and Hygiene of Industrial Solvents, edited by Lehmann and Flury, 1943. Women in Industry - Their Health and Efficiency, Baetjer, 1946'. _ Proceedings of the 9th International Congress on Industrial Medicine, 1949. The Pneumoconiosis Problem, Thomas, 1958. c EXHIBIT II c c - American Medical Association Archives Health, published by the American Medical Association, Vol. 11, 1955, through Vol. 1958. . American Industrial Hygiene Association Quarterly, 1946 through 1958. Annual Review of Nuclear Science, published by Annual Reviews, Inc., 1952 through 1953? 1955 through 1957. Archives of Industrial Hygiene and Occupational Medicine, published by the American Medical Association? 1950 to 1954. . British Journal of Industrial Medicine, published by British Medical Association, 1949 through 1958. Industrial Medicine and Hygiene, published by Butterworth and Company, 1954 through 1956. Industrial Medicine and Surgery, 1949 through 1958. Journal of Industrial Hygiene and Toxicology, The, published by the Williams and Wilkins Company, 1928 through 1949. - Noise Control, published by the Accoustical Society of America, 1955 through 1958. Aids to Anatomy, Last, 1951. ' . Airborne Contagion and Air Hygiene, An Ecological Study of Traupvood Infections, Wells, 1955. _ Analytical Chemistry. - By Treadwell, Vol. 1, Quantitative Analysis, 1937. . ._ Chemical Analysis of Industrial Solvents, Jacobs and Scheslan, 1953. .Chemical Engineers' Handbook, edited by Perry, 1941. Design of Industrial Exhaust Systems, Alden, 1939. Dictionary of Modern English Usage, A, by Fowler, 1926. Electromagnetically Enriched Isotopes and Mass Spectrometry, Proceedings of the Conference Held in Cockcroft Hall, Harwell, Sept., 1955; . Encyclopedia of Instrumentation for Industrial Hygiene, edited by Yasse, Byers and Hosey, 1956. Fatigue, edited by Floyd and Welford, 1953. -2- Fatigue of Workers - Its Relation to Industrial Production, Committee on Work Industry of the National Research Council, 1941. ~ Fuels and Combustion, Smith and Stirrson, 1952. - 1957 Acoustics and Vibrational Physics, Stevens and Bate, 1950; ' Acoustical Engineering, Olson, 1957? Acoustic Measurements, Beranek, 1949; The Measurement of Hearing, Hirsh, 1952; . Man's World of_Sound, Pierce and David, 1958; Technical Aspects of Sound, edited by Richardson, 1953; Physiological Acoustics, V7eaver and Lawrence, 1954 ; Fundamentals of Acoustics, 2nd Edition, Kinsler and Frey, 1950; Acoustics-Noise in Buildings, Parkin and Humphreys, 1958; . Hearing and Deafness, 3rd Edition, edited by Davis and Silverman, 1947; . A Textbook of Sound, Wood, 1949; ................_ Noise Reduction Manual, Geiger, 1953; "* Physical Acoustics, Supplement 1, edited by Lukasik and Nolle, 1955; . Foundry Noise Manual, American Foundrymen's Society, 1953 and 1956; Foundry Ventilation and Dust Control, Harrogate, 1956? Body Temperature, Its Changes with Environment-, Disease and Therapy, Selle, 1952? Applied Heat Transmission, Stoever, 1941; Heat and Temperature Measurement, Weber, 1950; Life Heat and Altitude, Dill, 1938; Heat Insulation, Wilkes-, 1950? Basic Principles of Ventilation and Heating, Bedford, 1948? Heat Transmission, McAdams, 1942; Climate in Everyday Life, Brooks, 1951; Handbook of Chemistry, Lange, 195.6. . Handbook of Emergency Toxicology, Kaye, 1954. Handbook of Glass Manufacture. By Tooley, 1953. Handbook of Material Trade Names, Zimmerman and Lavine, -3- ' 1957: __ Handbook of Toxicology,^edited by Spector, 1955 and \ "' History of Factory and Mine Hygiene, Teleky, 1948. . Human Machine, The, Shilling, 1955. .* Industrial Environment and Its Control, The, by Dallaval1 a,.19 4 8. ~ Industrial Medicine and Hygiene, edited by Merewether, 1954 through 1956. Industrial Methods of Analysis, Willard, Merritt,- and Dean, 1948. _ Industrial Poisons in the United States, Hamilton, 1929. Industrial Toxicology, Hamilton and Johnstone, 1945. 19 23 . Introduction to Medical Biometry and Statistics, Fearl, ..... . .. ... ... . . . Introductory .Quantitative Chemistry, Olson, Koch and Pimentel, 1955. . . language.Habits in-Human Affairs, Lee, 1941. Manual of Industrial Health Eazards, Ficklen, 1940. Manual of the International List of Causes of Death, U.S. Government-Printing -^Office, 1929. Manual of the International Statistical Classification of Diseases, Injuries, and Causes of Death, Vol. 2, Alphabetical Index, 1950. . . Mechanical Engineer's Handbook, edited by Marks, 1951. Methods of Air Analysis. By Haldane, 1935. Noxious Gas and the Principles of Respiration Influencing their Action, Henderson and Haggard, 1927. Odor's Physiology Control, Cord and Wither-idge, 1949. Preventive-Medicine and Public Health, Smillie, 1947. Professional Engineer's Examination Questions and Answers, Londe, 1956. ' Radioisotopes in Scientific Research, edited by Extermann, 1958. -4- Roget's College Thesaures, The New American Library, 1958. _ . Standard Methods of Chemical Analysis, Scott, 5th Edition, 1925. ' .. ,. * - Symposium on Instrumentation in Atmospheric Analysis, published by The American Society for Testing and Materials, 1958. Toxicology and Hygiene of Industrial Solvents, edited by Lehmann and Flury,- 1943. Women in Industry - Their Health and Efficiency, _ Baetjer, 194 6-. Proceedings of the 9th International Congress on Industrial Medicine, 1949. ~ The Pneumoconiosis Problem, Thomas, 1958. _ . -5- c exhibit II c c - American Medical Association Archives Health, published by the American Medical Association, Vol. 11, 1255, through Vol. 1958. ' . American Industrial Hygiene Association Quarterly, 1946 through 1958. Annual Review of Nuclear Science, published by Annual Reviews, Inc., 1952 through 1953; 1955 through 1957. Archives of Industrial Hygiene and Occupational Medicine, published by the American Medical Association; 1950 to 1954. '. British Journal of Industrial Medicine, published by British Medical Association, 1949 through 1958. Industrial Medicine and Hygiene, published by Butterworth and Company, 1954 through 1956. .Industrial Medicine and Surgery, 1949 through 1958. Journal of Industrial Hygiene and Toxicology, The, published by the Williams and Wilkins Company, 1928 through 1949. Noise Control, published by the Accoustical Society of America, 1955 through 1958. Aids to Anatomy, Last, 1951. * . Airborne Contagion and Air Hygiene, An Ecological Study of Traupvood Infections, V7ells, 1955. . Analytical Chemistry. - By Treadwell, Vo.l. 1, Quantitative Analysis, 1937. . .,, Chemical Analysis of Industrial Solvents, Jacobs and Scheslan, 1953. Chemical Engineers' Handbook, edited by Perry, 1941. Design of Industrial Exhaust Systems, Alden, 1939. Dictionary of Modern English Usage, A, by Fowler, 1926. Electromagnetically Enriched Isotopes and Mass Spectrometry, Proceedings of the Conference Held in Cockcroft Hall, Harwell, Sept., 1955; . Encyclopedia of Instrumentation for Industrial Hygiene, edited by Yasse, Byers and Hosev, 1956. Fatigue, edited by Floyd and Welford, 1953. -2- ^ Fatigue of Workers - Its Relation to Industrial Production, Committee on Work Industry of the National Research Council, 1941. Fuels and Combustion, Smith and Stinson, 1952. .' _Acoustics and Vibrational Physics, Stevens and Bate, 1950; ' Acoustical Engineering, Olson, 1957; Acoustic Measurements, Beranek, 1949; The Measurement of Hearing, Hirsh, 1952; . Man's V7orld of_Sound, Pierce and David, 1958; . Technical Aspects of Sound, edited by Richardson, 1953; Physiological Acoustics, V7eaver and Lawrence, 1954 ; Fundamentals of Acoustics, 2nd Edition, Kinsler and Frey, 1950; Acoustics -Noise in Buildings, Parkin and Humphreys, 1958; . Hearing and Deafness, 3rd Edition, edited by ' Davis and Silverman, 1947; . ' A Textbook of Sound, Wood, 1949; ............... - Noise Reduction Manual, Geiger, 1953; ' ~ ^ Physical Acoustics, Supplement 1, edited by ^ Lukasik and Nolle, 1955; . Foundry Noise Manual, American Foundrymen's Society, 1953 and 1956; Foundry Ventilation and Dust Control, Harrogate, 1956; Body Temperature, Its Changes with Environment, Disease and Therapy, Selle, 1952; Applied Heat Transmission, Stoever, 1941; Heat and Temperature Measurement, Weber, 1950; Life Heat and Altitude, Dill, 1938; Heat Insulation, Wilkes, 1950; Basic Principles of Ventilation and Heating, Bedford, 1948; Heat Transmission, McAdams, 1942; Climate in Everyday Life, Brooks, 1951; - Handbook of Chemistry, Lange, 1956. . Handbook of Emergency Toxicology, Kaye, 1954. Handbook of Glass Manufacture. By Tooley, 1953. C 1957. Handbook of Material Trade Names, Zimmerman and Lavine, ' -3- ' Handbook of Toxicology, edited by Spector, 1955 and 1957: ' _ History of Factory and Mine Hygiene, Teleky, 1948. . Human Machine, The, Shilling, 1955. * Industrial Environment and Its Control, Dallaval1e,.194 8. The, by " Industrial Medicine and Hygiene, edited by Mefewether, 1954 through 1956.. Industrial Methods of Analysis, Willard, Merritt,- and Dean, 194 8. 19 23. Industrial Poisons in the United States, Hamilton, 1929. Industrial Toxicology, Hamilton and Johnstone, 1945. Introduction to Medical Biometry and Statistics, Pearl, ......... ... ... : ,, Introductory .Quantitative Chemistry, Olson, Koch and Pimentel, 1955. .. -- : . language.Habits in-Human Affairs, Lee, 1941. Manual of Industrial Health Eazards, Ficklen, 1940. Manual of the International List of Causes of Death, U.S. Government-Printing-Office, 1929. Manual of the International Statistical Classification of Diseases, Injuries, and Causes of Death, Vol. 2, Alphabetical Index, 1950. . . Mechanical Engineer's Handbook, edited by Marks, 1951. Methods of Air Analysis. By Haldane, 1935. . Noxious Gas and the Principles of Respiration Influencing their Action, Henderson and Haggard, 1927. Odor's Physiology Control, Cord and Witheridae, 1949. Preventive-Medicine and Public Health, Smillie, 134 7. Professional Engineer's Examination Questions and Answers, Londe, 1956. ' Radioisotopes in Scientific Research, edited by Extermann, 1958. -4-  . Roget's College Thesaures, The New American Library, 1958. _ . Standard Methods of Chemical Analysis, Scott, 5th Ed ition, 1925. " .. . .. Symposium on Instrumentation in Atmospheric Analysis, published by The American Society for Testing and Materials, 1958. .Toxicology and Hygiene of Industrial Solvents, edited by Lehmann .and Flury,- 1943. Women in Industry - Their Health and Efficiency, ' Baetjer, 194 6-, Proceedings of the 9th International Congress on Industrial Medicine, 1949. ' The Pneumoconiosis Problem, Thomas, 1958. -5- Registered June 18, 1946 Trade-Mark 421,788 Ropublishsd, ury.i?r tl'.e Ac: o: 1946, :.!ar. 2. 1943. ) Owons-Illinais C*l?.ss company, Toledo, Ohio. Affidavit under Section 8 accepted, Affidavit under Section 15 received, Feb 17, 195U UNITED STATES PATENT OFFICE _____ _ _______Owens-Illinois Glass Company. Toledo. Ohio Act of February 20, 1905 Application September 17,1945, Serial No. 488,610 STATEMENT To the Commissioner ot Patents: Owens-Illinois Olass Company.-a corporation duly organized under the laws of the State of Ohio and having Its principal place of business in the Ohio Building, 405 Madison Avenue. Toledo. Ohio, has adopted and used the trade-mark shown in the accompanying drawing, for THERMAL AND SOUND INSULATINO AND BUILDING MATE RIALS. USED FOR STRUCTURAL PURPOSES. FIREPROOFING AND FIRE PROTECTION. SUCH MATERIAL CONSISTING OF CALCIUM SILICATE WITH OR WITHOUT REENFORC ING MATERIALS. AND COMPRISING INSU LATING BOARDS. INSULATINO BUILDING BLOCKS. PIPE COVERING. AND ROOFING TILE, in Class 12, ConstrucUon materials, and presents herewith five specimens showing the trade-mark as actually used by the applicant upon the goods, and requests that the same be regis tered in the United States Patent Office in accord ance with the act of February 20. 1905. Thi trade-mark was used by applicant and ap plied to the said goods on or about October 12. 1943, and bas been continuously used and applied to said goods in applicant's business since that date. The trade-mark is applied to the containers in which the goods are packed and shipped, by print ing or stencilling the mark thereon. Said Owens-Illinois Class Company hereby ap points Rule It Koge (registry No. 14.121). r. O. Box 1035. Toledo, Ohio, (a firm composed of John F. Rule and J. Ralph Hoge). its attorneys..to pros ecute this application for registration, with full power of substitution and revocation, to make alterations and amendments therein, to receive the certificate and to transact all business in the Patent Office connected therewith. OWENS-ILLINOIS GLASS COMPANY. By CARL R. MEGOWEN. Vice-President. Registered Me, ii, 1948 Registration No. 500,210 . PRINCIPAL REGISTER Trade-Mark . UNITED STATES PATENT Owens-Illinois Glass Company, Toledo, Ohio Act ot 1946 Application July 5. 1947, Serial No. 527,466 OFFICE I\ K- (Statement) -- Owens-Illinois Glass Company, a corporation duly organized under the laws of the State of Ohio and having its principal place of business in the Ohio Building, Toledo, Ohio, has adopted and used the trade-mark shown in the accom panying drawing, for PIPS COVERING AND HEAT INSULATING BLOCKS CONSISTING OP CALCIUM SILICATE WITH OR WITHOUT REENPOP-CING MATERIALS, in Class 12. Con struction materials, and presents herewith five specimens showing the trade-mark as actually used in connection with such goods, the .trade mark being applied to the goods by printing or stenciling the trade-mark on the containers in which the goods are packed and shipped, and re quests that the same be registered in the United States Patent Office on the Principal Register. In accordance with the act of July 5.1946. The trade-mark was first used during or about the month of April, 1944, and was first used m commerce In interstate shipments of the goods which may lawfully be regulated by Congress, during or about the month of April. 1944. The applicant is the owner of the trade-mark "Kaylo." registered June 18. 1946, registration No. 421,786. (Declaration) Harold J. Carr, being duly sworn, deposes and says that he Is the Vice-President of Owens-Ulincls Glass Company, the applicant named in the foregoing Statement, that he believes that said corporation is the owner of the trade-mark, which is in use in commerce in interstate ship ments. and that no other person, firm.'corpora tion. or association, to the best of his knowledge and belief, has the right to use such trade-mark in commerce which may lawfully be regulated by Congress, either in the Identical form thereof or ih such near resemblance thereto as might be calculated to deceive, that the drawing and de scription truly represent the trade-mark sought to be registered, that the specimens show the trade-mark as actually used in connection with the goods, and that the facts set forth in the Statement are true. OWENS-ILLINOIS GLASS COMPANY. By HAROLD J. CAP.R. Vice-President. f- United States Patent 09ice PRINCIPAL REGISTER Trademark 639,220 Registered Jan. 1, 1957 Ser. No. 4,049, filed Mar. 7,1950 Owens-Illinois Glass Company (Ohio corporation) 405 Madison Ave. Toledo, Ohio For: THERMAL AND SOUND INSULATING AND BUILDING MATERIALS. AND COMPRISING INSULATING BOARDS. INSULATING BUILDING BLOCKS, PIPE COVERING, AND ROOFING TILE, in CLASS 12. Fine use Dec. 31, 1955; in commerce Dec. 31. 1955. Owner of Reg. Nos. 421,706, 500,210. and 563.443. fr - . c EXHIBIT II c c - American Medical Association Archives Health, published by the American Medical Association, Vol. 11, 1955, through Vol. 1958. . American Industrial Hygiene Association Quarterly, 1946 through 1958. Annual Review of Nuclear Science, published by Annual Reviews, Inc., 1952 through 1953? 1955 through 1957. Archives of Industrial Hygiene and Occupational Medicine, published by the American Medical Association; 1950 to 1954. '. British Journal of Industrial Medicine, published by British Medical Association, 1949 through 1958. Industrial Medicine and Hygiene, published by Butterworth and Company, 1954 through 1956. .Industrial Medicine and Surgery, 1949 through 1958. Journal of Industrial Hygiene and Toxicology, The, published by the Williams and Wilkins Company, 1928 through 1949. Noise Control, published by the Accoustical Society of America, 1955 through 1958. .. Aids to Anatomy, Last, 1951. ' , Airborne Contagion and Air Hygiene, An Ecological Study of Traupwood Infections, Wells, 1955. . . Analytical Chemistry. By Treadwell, Vol. 1, Quantitative Analysis, 1937. . _ Chemical Analysis of_Industrial Solvents, Jacobs and Scheslan, 1953. Chemical Engineers1 Handbook, edited by Perry, 1941. Design of Industrial Exhaust Systems, Alden, 1939. Dictionary of Modern English Usage, A, by Fowler, 1926. Electromagnetically Enriched Isotopes and Mass Spectrometry, Proceedings of the Conference Held in Cockcroft Hall, Harwell, Sept., 1955; . Encyclopedia of Instrumentation for Industrial Hygiene, edited by Yasse, Byers and Hosey, 1956. Fatigue, edited by Floyd and Welford, 1953. -2- Fatigue of Workers - Its Relation to Industrial Production, Committee on Work Industry of the National Research Council, 1941. ~ Fuels and Combustion, Smith and Stinson, 1952. .' _Acoustics and Vibrational Physics, Stevens and Bate, 1950; ` Acoustical Engineering, Olson, 1957; Acoustic Measurements, Beranek, 1949; The Measurement of Hearing, Hirsh, 1952? . Man's World of_Sound, Pierce and David, 1958; . Technical Aspects of Sound, edited by Richardson, 1953; Physiological Acoustics, Weaver and Lawrence, 1954 ; Fundamentals of Acoustics, 2nd Edition, Xinsler and Frey, 1950; Acoustics -Noise in Buildings, Parkin and Humphreys, 1958; . Hearing and Deafness, 3rd Edition, edited by Davis and Silverman, 1947; A Textbook of Sound, Wood, 1949; - -- Noise Reduction Manual, Geiger, 1953;' " ~ Physical Acoustics, Supplement 1, edited by Lukasik and Nolle, 1955; . Foundry Noise Manual, American Foundrymen's Society, 1958 and 1956; . Foundry Ventilation and Dust Control, Harrogate, 1956; Body Temperature, Its Changes with Environment, Disease and Therapy, Selle, 1952? Applied Heat Transmission, Stoever, 1941; Heat and Temperature Measurement, Weber, 1950; Life Heat and Altitude, Dill, 1938; Heat Insulation, Wilkes, 1950; Basic Principles of Ventilation and Heating, Bedford, 1948; Heat Transmission, McAdams, 1942; Climate in Everyday Life, Brooks, 1951; Handbook of Chemistry, Lange, 1956. . Handbook of Emergency Toxicology, Kaye, 1954. Handbook of Glass Manufacture. By Tooley, 1953. 1957. Handbook of Material Trade Names, Zimmerman and Lavine, '' -3- ' Handbook of Toxicology*, edited by Spector, 1955 and 1957; - " ' History of Factory and Mine Hygiene, Teleky, 1948. . Human Machine, The, Shilling, 1955. ' * Industrial Environment and Its Control, The, by Dallaval1e,.1948. " Industrial Medicine and Hygiene, edited by Merevether, 1954 through 1956. Industrial Methods of Analysis, Willard, Merritt,- and Dean , 194 8. .. Industrial Poisons in the United States, Hamilton, 1929. Industrial Toxicology, Hamilton and Johnstone, 1945. 19 23. Introduction to Medical Biometry and Statistics, Pearl, ....... ... :............. : .. ' Introductory .Quantitative Chemistry, Olson, Koch and Pimentel, 1955. . l^ang-uage < Habits in-Human Affairs, Lee, 1941. Manual of Industrial Health Eazards, Ficklen, 1940. Manual of the International List of Causes of Death, U.S. Government-Pr intin.g. -jOffice , 1929. Manual of the International Statistical Classification of Diseases, Injuries, and Causes of Death, Vol. 2, Alphabetical Index, 1950. Mechanical Engineer's Handbook, edited by Marks, 1951. Methods of Air Analysis. By Haldane, 1935. Noxious Gas and the Principles of Respiration Influencing their Action, Henderson and Haggard, 1927. . Odor's Physiology Control, Cord and Wither idae, 1949. Preventive-Medicine and Public Health, Smillie, 1947. Professional Engineer's Examination Questions and Answers, Londe, 1956. ' Radioisotopes in Scientific Research, edited by .Extermann, 1958. Roget's College Thesaures, The New American Library, 1958. _ . Standard Methods of Chemical Analysis, Scott, 5th Edition, 1925. ", - .. '* - Symposium on Instrumentation in Atmospheric Analysis, published by The 'American Society for Testing and Materials, 1958. Toxicology and Hygiene of Industrial Solvents, edited by Lehmann and Flury,- 1943. V7omen in Industry - Their Health and Efficiency, ' Baetjer, 1946-. Proceedings of the 9th International Congress on Industrial Medicine, 1949. ~ The Pneumoconiosis Problem, Thomas, 1958. - .- -5- ..... RESPONSE NO.. 2: This Defendant objects to this Interrogatory on the basis that it is overly broad and unduly burdensome, and calls for information which is immune from discovery under the attorney work product doctrine. Without waiving above objections this Defendant states that it has referred to the relevant business records of the Owens-Illinois Glass Company, which are still in the possession of Owens-Illinois, Inc., in connection with the preparation of answers to these Interrogatories unless otherwise indicated. INTERROGATORY NO. 3: State whether you are a corporation. If so, state: your corporate name; state of incorporation; date of incorporation; address of principal place of business; address(es) of any other place of business; whether, if you are a "foreign corporation" as defined in Maryland General Corporation Law Sec. 1-101(1), you are now or have ever been registered or qualified to do business in the State of Maryland; and the corporate name, state of incorporation and date of incorporation of any subsidiary, predecessor or affiliate corporation. RESPONSE NO. 3: Owens-Illinois Glass Company was incorgorated in the State of Ohio in ^Jg9. Owens-Illinois Glass Company changed^t^jjame to Owens-Illinois, Inc. on April 28) ^196. The address of the principal place of business is One SeaGate, Toledo, Ohio 43666. INTERROGATORY NO. 4: which you have existed. Identify all prior names by RESPONSE NO. 4: Owens-Illinois Glass Company changed its name to Owens-Illinois, Inc. on April 28, 1965. -6-/ 1106 (g) The terms and conditions of any contracts or agreements by and between you and such corporation(s) or business entity(ies), including, but not limited to, the terms and conditions relating to the transfer of liabilities for obligations of such corporation(s) or business entity(ies); (h) Whether you continued the manufacture, sale and/or distribution of such corporation's or business entity's asbestos products and, if so, whether you used the same product name(s) in so doing; and (i) Whether there was an identity of name, officers, directors, personnel, property, suppliers, distribution outlets and/or clients between you and such corporation(s) or business entity(ies); RESPONSE NO. 7: Refer to Response No. 6. INTERROGATORY NO. 8; If you have directly or indirectly mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce asbestos or asbestos-containing products, state as to each such product, indicating separately those products dealt with by you, your predecessor(s) in interest, your subsidiary(ies), and your affiliate(s), if any, the following: (a) Brand name, trade-name, and/or trade-mark; (b) The generic name or identity; (c) Description, including size, shape, color and composition, i.e. solid, powder or other form; (d) Chemical and physical composition, including, but not limited tc, tne percentage of asbestos by weight and volume; (e) Type of asbestos, i.e. chrysotile, amosite, crocidolite, actinolite, anthophyllite, or tremolite, indicating the percentage of each such asbestos fiber by weight and volume; (f) Intended marketable use; and (g) Dates during which each asbestos product was mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, discribured and/cr otherwise placed in the stream of commerce. -9- RESPONSE NO. 8: (a) Kaylo and Kaylo-20; (b) This Defendant's asbestos-containing products were hydrous calcium silicate materials; (c) Owens-Illinois Glass Company began limited pilot plant operations involving the production of *Kaylo* asbestoscontaining_^roducts_^iiT_194 3. It began the manufacture of commercial quantities of *Kaylo* asbqstos^^ntajjring_prgducts__in about 1948 and continued such manufacture Until about Aprij_30. 1958. (d) This Defendant ceased the manufacture, sale and distribution of its asbestos-containing products in 1958. Its investigation as to the composition of each such product, including the type of asbestos-contained therein (i.e., amosite or chrysotile) and the quantitative percentage of asbestos, is continuing, although this Defendant now believes that this Defendant's commercially produced asbestos^containing^roduct^ wer^hydrou^calcium^il^catescontainin^between^^^aQ^ approximately 20% asbestos. Chrysotile asbestos was the primary type apparently used. Amosite wa used to a lesser extent. (f) The asbestos-containing products manufactured by this Defendant were intended to be used for industrial high temperature thermal insulation such as pipe covering and block insulation, and to increase fireproofing and fire protection and for insulation through use as a roof deck or fireproof material or door core material. -10- O-l R06 (g) Owens-Illinois Glass Company began limited pilot plant operations involving the production of *Kaylo* asbestoscontaining products in 1943. It began the manufacture of commercial quantities of "Kaylo" asbestos-containifig products in about 1948 and continued such manufacture until about April 30, 1958. INTERROGATORY NO. 9: State whether you preiseritly mine, manufacture, produce, fabricate, import, convert, compound, process, sell, merchandise, supply, distribute and/or otherwise place in the stream of commerce any asbestos product(s) listed in your Answer to the preceding interrogatory. RESPONSE NO. 9: This Defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. It does not now, and it has not since that time, manufactured, sold or distributed any asbestos-containing j products. INTERROGATORY NO. 10: Identify each individual who participated in the design and preparation of manufacturing specifications for each asbestos product identified in your Answer to Interrogatory No. 8. RESPONSE NO. 10: This Defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to plaintiff's counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. -11- H' INTERROGATORY NO* 11 ; State whether any written memoranda, specifications, blueprint* or'ether written materials of any kind or character now exist relating to the design and preparation of the asbestos products identified in your Answer to Interrogatory No. 8. If so, identify: (a) Each such written material or document; and (b) The custodian, identity and location of each written material or document. RESPONSE NO. 11: This defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to Plaintiff's counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. INTERROGATORY NO. 12: Identify, by location and product, each plant of your in which the asbestos products identified in your Answer to Interrogatory No. 8 have been manufactured and/or assembled and the dates said plants have been in operation. RESPONSE NO. 12: This defendant's manufacturing plants were located in Berlin, New Jersey and Sayreville, New Jersey. The Berlin plant was in operation from approximately 1943 until on or about April 30, 1958. The Sayreville plant was in operation from February, 1948 until about April 30, 1953. JJJIggggg^JORYNOJ^ If you have discontinued mining, manufacturingt"^ro3ucing, fabricating, importing, converting, compounding, processing, selling, merchandising, supplying, distributing and/or otherwise placing in the stream of commerce any asbestos products listed in your Answer to Interrogatory No. 8, identify the products discontinued, give the date of discontinuance and specify the reason(s) for such discontinuance. -12- . - RESPONSE NO. 13*------In 1953, this Defendant entered into a sales agreement with Owens-Corning Fiberglas Corporation under which it agreed to the sale of asbestos-containing products to that corporation. This Defendant believes that' it ceased the general marketing and sales of its asbestos-containing thermal insulation products at that time, disbanded its sales force, and that thereafter, Owens-Corning Fiberglas Corporation was the primary marketer of its product until the sale of the division to Owens-Corning Fiberglas Corporation in 1958. INTERROGATORY NO. 14: If you have done so, when did you first determine that any other material could be used in place of asbestos for high-temperature insulation or any other use to or for which asbestos has been applied. If you have, in fact, substituted other material(s) for asbestos in your product(s), then state: (a) The identity of such substituted material(s); (b) When the product(s) with such substituted material(s) was first marketed; and (c) The tradename(s) and brand name(s) of the product(s) marketed with such substituted material(s). RESPONSE NO. 14: This defendant has located information in its records indicating that several efforts were made to substitute other materials for the asbestos in its Kaylo products; however, such efforts were unsuccessful. Defendant will make available to plaintiffs' counsel through its local counsel reports on such experiments. Some of the reports are contained on microfilm which is old and of poor quality. -13- ' RESPONSE NO. 21: This Defendant ceased the manufacture, sale and distribution of asbestos-containing thermal insulation products in 1958. This Defendant states that in 1953 it entered into a 'Sales Agreement' under which it agreed to sell certain amounts of its asbestos-containing thermal insulation products to Owens-Corning Fiberglas Corporation. Furthermore, this Defendant has found information,in its records which indicate that in at least 1956, it placed OWeris-Corning Fiberglas Corporation's logo on some of its boxes. This Defendant does not have information sufficient to further respond to this Interrogatory. INTERROGATORY NO. 22: State the following with respect to the packages and containers in which you sold, distributed or otherwise furnished each of the asbestos products described in your Answer to Interrogatory Nos. 8 and 19 on a year-by-year and product-by-product basis; (a) A description of the package or container in which each product was sold, distributed or otherwise furnished, including composition, size, shape and color; (b) A description of the markings or printed material that appeared on each package or container, indicating the size and color of the same; (c) A description of any logo or other design appearing on the package or container; (d) A verbatim description of any caution or warning notice appearing on the package or container, setting forth the year(s) in which each such notice appeared on each such product; and (e) A verbatim description of any instructions appearing on the package or container. '1 -20- 7 ii, sro} '??' IN THE CIRCUIT COURT' FOR BALTIMORE CITY * * ALL CT-1 CASES * ALL CT-2 CASES * ALL CT-4 CASES * ' ALL CT-5 CASES * * ********* DEFENDANT OWENS-ILLINOIS, INC.'S ANSWERS TO PLAINTIFFS' MASTER INTERROGATORIES TO ALL DEFENDANTS To: All Defendants, to be answered individually and separately by each Defendant. Plaintiffs, by their attorneys, John T. Enoch, John Amato, IV, and Goodman, Meagher & Enoch, request Defendants to answer the following Interrogatories. The Interrogatories are to be read and answered in accordance with the following instructions and definitions. a. These Interrogatories are continuing in character and, in accordance with the Maryland Rules, you are required to supplement your answers promptly after you obtain further material information. `defendant made ^apprcyriate'efforts to' provide venti let ion end to control the emissions of all dust emitted during the manufacturing process within recognized save levels of exposure, including the use of respirators in some instances dust collection equipment and other devices as necessary. Therefore, during the period in which this defendant was in the business of manufacturing Kaylo it had no reason< to believe that the foreseeable use of Kaylo would create a hazard to users. The documents produced by Owens-Coming Fiberglas Corporation indicate that the September, 1955 publication in the A.M.A. Archives of Industrial Health was a publication of inhalation experiments. To the extent that this interrogatory seeks the production of documents, such documents, as outlined in this response, have not been found as part of this defendant's records and, to the extent that this defendant is in possession of copies of documents, it possesses copies only of documents collected in preparation for litigation. This defendant objects to producing the same. The documents are available from their proper source. INTERROGATORY NO. 39: Identify all trade organizations, associations or other entities to which you belong or belonged. Said organizations, etc., include, at a minimum, the following: Asbestos Textile Institute (ATI); Industrial Hygiene Foundation and/or Industrial Health Foundation (IHF); Mineral Wool Institute; Industrial Mineral Insulation Manufacturers Institute; -38- 0I-R OO 'Association;* - " - ' National Insulation Manufacturers Association (NIMA); Thermal Insulation Manufacturers Association (TIMA); Asbestos Information Association (AIA); Quebec Asbestos Mining Association (QAMA); National Safety Council; Asbestos Cement Producers Association; Refractories Institute. RESPONSE NO. 39; This defendant objects to this interrogatory on the grounds that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence except as it relates to the period of time within which this defendant manufactured its asbestos-containing products. Without waiving the above objection# this defendant states that insofar as this interrogatory refers to associations or organizations of which this defendant was a member during the time when it manufactured asbestos-containing products, it was a member of the Industrial Hygiene Foundation (which changed its name to the Industrial Health Foundation in 1970) for the years 1936 through 1975. This defendant was not a member of any of the other organizations about which this interrogatory inquires. INTERROGATORY NO. 40: For each trade organization, association or other entity identified in your Answer to Interrogatory No. 39, state: I -39- Ol-ROb (c) All documents relating to Saranac Laboratory studies or tests which were received or submitted by you, either directly or indirectly through predecessor(s) in interest, subsidiary(ies) or affiliate(s), if any, through other companies, or through any trade associations, organizations or entities; (d) All recommendations or findings of such studies in relation to: (i) adequacy or inadequacy of the threshold limit values; (ii) the substitution of materials for asbestos; dnd (e) The custodian and location of all documents and/or communications identified in your Answer to this Interrogatory. RESPONSE NO. 45: Refer to response to interrogatory no. 44. INTERROGATORY NO. 46: State the amount of money spent or contributed by you annually from 1930 to the present for research of the relationship between' exposure to asbestos dusts, fibers and/or products and any pulmonary pathology and identify each person or organization to whom the expenditure or contribution was made. RESPONSE NO. 46: This defendant objects to this .interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to ,the discovery of admissible evidence. INTERROGATORY NO. 47: State whether you have ever maintained a library (or libraries) which contains books, articles, periodicals, journals and/or reference materials that relate to the subjects of asbestos, industrial hygiene, medicine, safety, occupational disease and/or engineering. If so, state: (a) The date each such library was established; (b) The location of each such library; (c) The identity of each librarian or other person in charge of the operation and materials of each such library; -43- OX *00 established; (d) For whose use each such library was (e) The title, publisher and dates of subscription to or acquisition of each such periodical or journal for each such library; and (f) The title, author, publisher, date and dates of acquisition of each such article and book for each such library. RESPONSE NO. 47: During the period of time pertinent to these actions, this defendant did not maintain an entity which would be characterized as an industrial hygiene, medicine, safety and/or engineering library. However, this defendant believes that a separate engineering library may have been maintained by its technical facility. This defendant also states that although it has no records indicating the existence of such a library, upon becoming involved in asbestos-related litigation this defendant listed all the publications which were in its then- existing industrial hygiene library. These publications are listed on Exhibit II. This defendant has not yet determined which, if any, of these publications were in this defendant's possession during the time it manufactured, sold and distributed asbestos-containing products. INTERROGATORY NO. 48: State whether any of the co defendants in asbestos litigation have ever furnished you with any information as to the state of the medical knowledge at any time regarding the relationship between exposure to asbestos dusts, fibers and/or products and the contracting of diseases, including asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers. RESPONSE NO. 48: This defendant objects to this interrogatory as being irrelevant and not reasonably calculated to lead to the discovery of admissible evidence and not limited -44- oX Ro< Ol QoS American Medical Association, Archives Health, published by the American Medical Association, Vol. 11, 1955, through Vol. 1958. . American Industrial Hygiene Association Quarterly, 1946 through 1958. Annual Review of Nuclear Science, published by Annual Reviews, Inc., 1952 through 1953; 1955 through 1957. Archives of Industrial Hygiene and Occupational Medicine, published by the American Medical Association; 1950 to 1954. . British Journal of Industrial Medicine, published by British Medical Association, 1949 through 1958. Industrial Medicine and Hygiene, published by Butterworth and Company, 1954 through 1956. * *OX 0 .Industrial Medicine and Surgery, 1949 through 1953. * Journal of"Industrial Hygiene and Toxicology, The, published by the Williams and Wilkins Company, 1928 through 1949. Noise Control, published by the Accoustical Society of America, 1955 "through 1958. .............. -^ Aids to Anatomy, Last, 1951. ` Airborne Contagion and Air Hygiene, An Ecological Study of Traupvood Infections, Wells, 1955. Analytical Chemistry. 3y Treadwell, Vol. 1, Quantitative Analysis, 1937. Chemical Analysis of Industrial Solvents, Jacobs and Scheslan, 1953. Chemical Engineers' Handbook, edited by Per ry, 1941. Design of Industrial Exhaust Systems, Alden, 1939. Dictionary of Modern English Usage, A, by Fowler, 1926. Electromagnetically Enriched Isotopes and Mass Spectrometry, Proceedings of the Conference Held in Cockcroft Hall, Harwell, Sept., 1955; Encyclopedia of Instrumentation for Industrial Hygiene, edited by Yasse, Byers and Hosey, 1956. Fatigue, edited by Floyd and Welford, 1953. ROt 06 . Fatigue of Workers Its Relation to Industrial Production, Committee on Work Industry of the Netional Research Council, 1941. Fuels and Combustion, Smith and Stinson, 1952. . ' > .Acoustics and Vibrational Physics, Stevens and Bate, 1950; Acoustical Engineering, Olson, 1957; Acoustic Measurements, Beranek, 1949; ' - The Measurement of Hearing, Hirsh, 1952; . Man's World of.Sound, Pierce and David, 1958; Technical Aspects of Sound, edited by Richardson, 1953; Physiological Acoustics, Weaver and Lawrence, 1954; Fundamentals of Acoustics, 2nd Edition, Kinsler and Frey, 1950; Acoustics Noise in Buildings, Parkin and . Humphreys, 1958; Hearing and Deafness, 3rd Edition, edited by Davis and Silverman, 1947; A Textbook of Sound, Wood, 1949; - . Noise Reduction Manual, Geiger, 1953; Physical Acoustics, Supplement 1, edited by Lukasik and Nolle, 1955; . Foundry Noise Manual, American Foundrymen's Society, 1958 and 1956; ' Foundry Ventilation and Dust Control, Harrogate, 1956; Body Temperature, Its Changes with Environment, Disease and Therapy, Selle, 1952; Applied Heat Transmission, Stoever, 1941; Heat and Temperature Measurement, Weber, 1950; Life Heat and Altitude, Dill, 1938; Heat Insulation, Wilkes, 1950; Basic Principles of Ventilation and Heating, Bedford, 1948; Heat Transmission, McAdams, 1942; Climate in Everyday Life, Brooks, 1951; Handbook of Chemistry, Lange, 1956. Handbook of Emergency Toxicology, Kaye, 1954. Handbook of Glass Manufacture. By Tooley, 1953. 1*57. Handbook of Material Trade Names, Zimmerman and Lavine, 1957: Handbook of Toxicology, edited by Soector, 1955 and * History of Factory and Mine Eygiene, Teleky, 1948. Human Machi'ne, The, Shilling, 1955. Industrial Environment and Its Control, The, by Dallaval'e, 1948. . Industrial Medicine and Hygiene, edited by Merevether, 1954 through 1956. Industrial Methods of Analysis,. Willard, Merritt,- and Dean, 1948. _. Industrial Poisons in the United States, Hamilton, 1929. Industrial Toxicology, Hamilton and Johnstone, 1945. 1923. Introduction to Medical Biometry and Statistics, Pearl, ' Introductory Quantitative Chemistry, Olson, Xoch and Pimentel, 1955. . Language Habits in Human Affairs, Lee, 1941. Manual of Industrial Health Hazards, Ficklen, 1940. Manual of the International List of Causes of Death, U.S. Government Printing Office, 1929. Manual of the International Statistical Classification of Diseases, Injuries, and Causes of Death, Vol. 2, Alphabetical Index, 1950. Mechanical Engineer's Handbook, edited by Marks, 1951. Methods of Air Analysis. By Haldane, 1935. Noxious Gas and the Principles of Respiration Influencing their Action, Henderson and Haggard, 1927. Odors Physiology Control, Cord and Witheridge, 1949. Preventive Medicine and Public Health, Smillie, 1947. Professional Engineer's Examination Questions and Answers, Londe, 1956. . Radioisotopes in Scientific Research, edited by m . Extermann, 1958. 0JC WO0 19581 Roget's College Thesaures, The New American Library, . Standard Methods of Chemical Analysis, Scott, 5th Edition, 19.25. Symposium on Instrumentation in Atmospheric Analysis, oublished by The American Society for Testing and Materials, 1958. _ . "Toxicology and Hygiene of Industrial Solvents, edited by Lehmann and Flury, 1943. Women in Industry - Their Health and Efficiency, Baetjer, 1946`. . Proceedings of the 9th International Congress on Industrial Medicine, 1949. The Pneumoconiosis Problem, Thomas, 1958. ox AFFIDAVIT STATE OF OHIO COUNTY OF LUCAS )SS: ) ' M. F. MCCARTHY, being duly sworn according to law, deposes and says that he is an Assistant Secretary of OwensIllinois, Inc., a defendant herein; that as such he is authorized to make an Affidavit on its behalf; and that the facts set forth in the foregoing DEFENDANT, OWENS-ILLINOIS, INC.'S ANSWERS TO INTERROGATORIES, are true arid correct to the best of his knowledge, information and belief. SWORN TO and subscribed before me this Cz / day M. F. MCCARTHY Notary Public Ky Commission Expires: fiCVERLY A ItAru a . A. ROCt EXHIBIT ffl A NEW HEAT INSULATION WITH REMARKABLE COMBINATION OF ADVANTAGES . . . . A Kaylo Heat Insulating Block a new type of lightweight mineral sulation that is efficient enough to used at ordinary room temperate and resistant enough to perform en lively up to 12003 F. Few new products of any kind h been so thoroughly researched bet" being placed on the market. Ka Heat Insulating Block is the achie ment of many years' work by Oae Illinois Glass Company enginet 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 fc This light weight (less than one poc to the board foot) simplifies handii shipping and application. I: g.-er reduces weight --an important ad' tage on ships, for an example. 1ry ' --IS -- *M *94 8Copyright, , Amer'cc* Structure! Product! Company Printed <n U.S.A. Notice the clean, straight edi on these insulated precipitator hi pers. Applicators find it easy to do : kind of work with Kaylo Heat Insu. ing Block because they are so easv cut and yet they have a tiveiy h: flexural strength. The w > above hoppers are also insulated with K r Heat Insulating Block. OVV THERMAL CONDUCTIVITY Tne coefficient of conductivity, or K", of Kavlo Heat Insulating Block, s r~own on the chart on page four, it among the most efficient in itiations for medium high temperaares. Its insulation value comes prinipally from its tine, interlaced cellular tructure. These cells are so tiny and o numerous that they present a maeriai surface of approximately 140 ores per cubic foot of insulation. Experience shows that the insulaion value of Kaylo insulation im proves when the material is put into ervice. EFFECTIVE OVER WIDE TEMPERATURE RANGE Kaylo 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 Kaylo insulation handles applications which often require two thicknesses of different materials. HIGH COMPRESSIVE STRENGTH 's compressive strength is unust .y high for a mineral product of such light weight. Kaylo 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 Kaylo 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 Kaylo Heat Insulating Blocks are clean-cut and trim. They are easy to fit into place to make a good-looking installation. Their "feel" is pleasant and non-irritating. They can be cut. scored and sawed with ordinary wood working tools. Finishes that go over the block, whether cement, cloth or other types, can be applied smoothly and with a minimum of effort. No special tools are needed. LOW MOISTURE ABSORPTION Moisture absorption is no prob lem with Kaylo insulation. Even when subjected to an atmosphere of 90 Te relative humidity and a temperature of 120: F., in standard tests, spea- mers absorb less than 1 <7c moisture by volume. RETAINS EFFECTIVENESS AFTER LONG SERVICE Kaylo Heat Insulating Block re mains strong, free from excessive powdering, and shows little loss in 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 (inches) 6 6 6 6 6 12 12 12 12 Thicknesses (inches) 1 1 1a 2 24 3j l4 2 24 3 Other sizes are available on special order. On large or small equipment, in side or out. Kaylo Heat Insulating Block performs efficiently and with a minimum of maintenance. Here it is be;-c' 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 w eatherproofing. Kaylo 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 ro this power plant. Hot water is always ready when needed in the office building where this hot water storage tank is installed, thanks to Kaylo Heat Insulating Block. This permanent insulation holds w ater temperature constant with a minimum of power consumption. Other applications for Kaylo Heat Insulat ing block are listed on rhe back page. PRINCIPAL FEATURES OF KAYLO HEAT INSULATING BLOCK 113; i t am; Nfti*-**? g_, EXTREMELY LIGHTWEIGHT^ "wmr&srx Jr* 5fr m EASY TO cv t-*- S&ragsis v's-J*J*t *- - r-*]P 'r '*. - '. / f r ' -- ' -i SIVEfSTRENGTH w*vvt' *a- * a "DURABLE * '^R ''*.. raO?* . :**! * *.**\ /.:. N--*. NO ADDED BINDER av * X iv / _ DOLiz^uv CL'-SjCLJatOZS 2)i(3j: Heal Loss, Surface Temperatures and Efficiencies#.. | KAYIO -gAr INSULAHNG 3lOCK -A-LO >-iAr NSUlAf'NG BLOCK -AT :C55 cSOm 9lAT SURFACES Arc 3U5ACt 1.v^6Ra:jrsS C* inSvIATICN AWS-SW S-i A.t 30* F ;o xC nX xC 600 'OC AX _^CC~ OOC" Bort Surfoe# 0 Air *F <v;o heat inSUIA-ivg HOOF Efficiencies On fla- surfaces Anbtrv Shll Air 30* F 0rmorcaort *0F'O* SuF'OC* Air 'F \ Inside or outside, for large iasral- v ' iladons or small, from 0 to 1200. F., use Kaylo Heat Insulating Block to insulate: -. Breechings Lehrs Hot Air Ducts Autoclaves - Tanks Oveos Towers - Furnaces - Dryers Turbines " Evaporators Chilling Pits Heat Exchangers Boilers Condensers . ` Precipitators Locomotives SOURCES OF TEST DATA ' The data shown on these pages - are supported by tests run at various laboratories, .all well known to the* insulation industry. They are further supported by the performance of the product in service. ' . . More detailed information on Kaylo Heat Insulating Block is avail able on request. American Structural Products Company, Toledo 1, Ohio. Subsidiary of Owens-Illinois Glass Company. PHYSICAL CHARACTERISTICS AT A GLANCE ..-w ir ' - - / -t - .. ` ... Approximately i 1 lb. per ai: fi^-rr c **vv *- isar f PVL&l ' 5%. deformation) Beforenearing r.'ftvr - ,450 lbTpe? After heaunefor 24 hour*3 ,^rv. r- . , . , at 750 F..ivr.'. .... : j".:.-. rj is. pirs^iK ;-v. ** - *. 'T . ' * " ' --- * *. ' at 1000 F. ... `'/-* ***.------123 lb. per sq^Ufcjy- ^ " at 1200 F____.....;: ?T. 7...117 lb. per sqTin. ' ' -' ^ - *' ~ After boiling for 24 hours (while wet)... .. . 74 lb. per sq. icur After heating for 24 hours. .<*** at 750 F............................. .................. ::.................... .'................. 5.5% at 1000 F.................... .......................................................................... 7.9% at 1200 F____::.............. .................................................................... : 9.8% After boiling for 24 hours.;........................................................... .. 0.2% V-" k~' jo]. ^ vr> ^ T (Conventional Tumbling Test--Loss in weight after 10 minutes) _,v: Before heating.. .......... ...'.... ...... . V'................2.2 % ... After heating for 24 hours. AL / / V r< at 1000 F. IT.:. =VT ivi-t' 1200s F. l 1^4 4 * 4*4 * !Ki3fJ&$rr:&`!C 4^ < TV V . 5.7 %'' ' !" 6.9% .44^'''i:r**v.- j ' ; - .>. .? 4?f Linear Shrinkage after heating for 24 hrs. v `- r -. -.. at 750 F.......................;,.r.------ ...v...^................................. 0.8% at iooos F.. .-........... ;.v:;;...v..;.,...'....................:.............. 0.9% at 1200 F........................ .....:................... ..................................... 1.5% Elongation after saturation (max.)......................................................... 0.4% .yxiFK- ' (volume) After 6 hours exposure in atmosphere of 120s F. and 90% Relative Humidity....................................................... 0.9% ( * |Y / V At 300 F. mean temperature 0.474 T _ . ' s ' -T I fe <c? * WITH A REMARKABLE COMBINATION OF KAYLO HEAT INSULATING BLOCK LOW THERMAL CONDUCTIVITY. T- EFFECTIVE OVER WIDE TEMPERATURE RANGE K. . t . . * ' . . rv HIGH COMPRESSIVE STRENGTH. HIGH FLEXURAL STRENGTH. NO ADDED BINDER, k 1 " . rr. rr 'r... 'a > 'n.:: t.c e rr. J: c r. o. or K..!' o . r. > < lv\ro>crc 'o > c r ' o': Terr. per.i cur s' : o r rr. .1 r._ e EASY TO APPLY. : Notice the dean, straight edges on *nese pre- - r * - * \p ~ . a:. easy :o ** ork ** ;:h is. jv c -: . * * --; .. v ' c...' e r, c \ i r s e i n \ Lu J rui vec On large or small equipment. -' I r. > -. i'. 'T ^ ^! 11 ^ v p c r: .* ' c 'h s. e . *. . "Jf DVANTAGES... LOW MOISTURE ABSORPTION. ^ EFFECTIVE AFTER LONG SERVICE, x.. . TYPICAL APPLICATIONS: H-.- Ir.: j :r.su. i:c DIMENSION At jTAftlt'TY I *0STVJflt AasoPTlON ^2<lo Heat Insuiating Block '"*h Hat and ^r-.ed ** ' a.- . -**.cr.t p;s.-ured here. By -r.: - ~ ~ . * " .: , and \c?ps lemperas-re* c- e. 3. HEAT INSULATING BLOCK Heat Loss. Surface Temperatures, and Efficiencies -E-iT .CSS FROM. FLAT SURFACES _____ _Ana _ _ __ SURFACE TEMPERATURES OF 'NSUTATIGN Ap^b'enr Sf:i* Air. 30 ? L SOURCES OF TEST DATA: The data shown on these pages are supported by tests run at var ious laboratories, all w ell known to the insu lation industry. They are further supported hs the performance of the product in service. More detailed information on Kaylo Heat Insulating Block is asailable on request. American Structural Products Company, Toledo 1. Ohio <t. A - KWt -- 9 9 6C oy*' "'t , * , Awrici $f.t<'i ? I:-.- near-white, mineral insulating 1 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 KaylO Heat Insulating Block. a lightweight insulation used to insulate against heat loss from hot surfaces. Kaylo Structural Insulating Block (20-lb. density) is designed to develop 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 oven dry basis from 19.5 to 22 lb.), has a compressive strength of approximately 5"" lb. per sq. in., a "k" of 0.66 at 100 mean and outstanding resistance to the travel of heat and flame at building fire temperatures. ` XX X, STRUCTU 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 and 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 For use in fabrications that are to be Underwriters' Labor atones inspected, Kaylo Structural Insulating Block ; furnished bearing the Underwriters' label for fire bazar' classification for building material. 0 t 7S 100 125 ISO 173 2C Meon Temperature, F. Good Insulation Value--At low mean temperatures Kayl Structural Insulating Block is one of the most emcier. structural mineral insulations. At high mean temperature it still compares favorably with heat insulating materia! of its own weight. High light Reflectivity--Where lfeft exposed and untreate (as with the underside of a roof deck) Kaylo Structure Insulating Block has high light reflectivity. Its light rt flection factor is from 70 to 80 per cent. Non-Abrasive Surface--Its surface is non-abrasive. It ha a somewhat "soapy" feel that makes it pleasant to handh At the same time it has a firm surface that assures goo contact with surfaces applied over it. No Added Binder--It contains no added binder, but ir stead constitutes its own binder. Hence its charactenstu are not modified as to temperature limit, solubility, mst lation value, fire resistance or otherwise by "bind* limitations." l L 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 Modulus of Elasticity--The modulus of elasticity of >lb. density block is approximately 160,000 lb. per sq. in. ow Specific Heat--The specific heat of Kaylo Structural nsulating Block is approximately 0.22. Cellular 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 hyroscopic. 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 macr It has unusual capacity to distribute moisture viti. .. its mass, and to give it off to surrounding air of ower moisture content. its 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 volume. onsistent with the common practice for good construcon involving porous insulating materials of high interna! ;rface area, Kaylo Structural Insulating Block should sealed against moisture on the warm side when it is injected to extremely low temperatures. High Wet Strength--Kaylo Structural Insulating Block, like most other insulating materials, is not intended to serve immersed in water or exposed to extremely damp or humid conditions, yet its flexural strength when wet (im mersed 10 hoursj is reduced only about 15 per cent. Dimensionally Stable--The dimensions of Kaylo 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. N'ails 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 of from l3* to 2 inches of Kayio Structural Insulating Block is requited 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. Density Block Can Be Used in Combination. Where two thicknesses of ir- lation are used to build up an insulating structure it i ssible to use the two den sities in combination to devc.^p the best insulation value strength and fire resistance. AMERICAN STRUCTURAL PRODUCTS COMPANY Toledo 1, Ohio OOOQ LAMINATION j --------------------------------------------------------------------------------- ^ amination over a Kaylo Insulating Core--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 ^ ~ ---------------ADHESIVES FOR JOINING cszixm i______ __________ STRUCTURAL INSULATING BLOCK TO: Wood Vaneor Aluminum Stainless Steel the service requirements of the finished product -arc' still offer some choice in curing procedures. Some adhesives which may be used with various v.-pe; 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 tensne strength of 35 lb. per sq. in. and a minimum shear strensrtn of 100 lb. per sq. in. when cured in the manner indicated.; ADHESIVES FOR JOINING LIKE MATERIALS: Insulating Block to Insulating Block Aluminum to Aluminum Stainless Steel to Stainless Steel oDurito No. 3026A 3026AWH207 3026AWF Penocolifp G113I 0 Pecora 718 Catabond 720 Vinyliool MA 28-18 o 0 o Amberlitp PRU 0 ^oifik 7026 0 Rtdux o Synco X-8348 o -- 1301W 'DW) Durifo No. 3026A Pocora 718 Woldwood Insolule No. 1 Inttrlakt 4162 Vutcalock Dupont 4663 Dupont 4646 G. E. 2142 Q G. E. 7031 Q Vinylttol MA 28-18 Ambtrlite PRU Boitik EXE 138 Q Rpdux Durite No. 3026 No. A, NH267 N100 G 3 MEC 826 GOO Wddwood O oInsalutp No i Intprlokp 4162 GO Vulcalock Dupont 4653 OO GOO Dupont 4646 GOO G. E. 2142 o G. E. 7031 Vinylipal MA 28-18 o o Ambprlitp PRU o Boitik 7026 Sodium Silicat* o Rpdux o Duritt 3026A Ptnocolit# Cl 131 O o Wildwood Inialutt 1 o o G. E. 2U2 Platkon 911 ^O Sploctron 5003 O VinyUiol MA 28-18 O Ambirlitt PRW O Boitik 7026 O Boitik EXE 138 Sodium Silicate O o Rtdux o Synco X-8348 o -f 130LW (OW) UXJ UJ _M m0 Vylcolock Dupont 4653 OO GOO Oupont 4646 GOO G- E. 7031 Boitik 7026 138 O O O Rtdux o Dupont 4653 G. E. 7031 Boitik 7026 Soitik EXE 138 Rtdux | Q Clamped at room temperature for 24 hours. l Q Clamped in oven at 120 F. for 1 hour. Symbols for method of cure: I! Placed in press at 10 p.s.i. at 300 F. for 10-30 minutes. For Maximum Strength d r Placed in press at 100 p.s.i. at 300 F. for 10-30 minutes. - Clamped in oven at 250 F. for 10-30 minutes. High-frequency curing has been tried successfully on an experimental basis with wood, aluminum and stainless steel bonded to a Kaylo sulating core. Many of the manufacturers making the above listed -dhesives can provide adhesives suitable for high-frequency curing. .r AMSIB0<SAK] 7R(ID(STO(3M I ^(yKSTTS j TOLEDO 1, OHIO Subsidiary of OWENS-ILLINOIS GLASS COMPANY KB2-3M-4I13 Copyright 1941; American Structural Product* Company. Printed >n U S A. Kaylo 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 Kaylo Heat Insulating Block, a lightweight insulation used to insulate against heat loss from hot surfaces. Kaylo Structural Insulating Block (20-lb. density) is designed to develop 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 oven drv basis from 19.5 to 22 lb.), has a compressive strength of approximately 50o lb. per sq. in., a `'k" of 0.66 at 100 mean and outstanding resistance to the travel of heat and flame at building fire temperatures. 20-LB. density 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 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 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 and vastly increases insulation value and fire resistance. W rs >00 1M ISO I/} 200 Meon Temperature, F. ............. ~ "" PHYSICAL PROPERTIES 1 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 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 ias with the underside of a roof deck) Kaylo Structural Insulating Block has high light reflectivity. Its light re flection factor is from 70 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--Kavlo Structural Insulating Block is responsive to wood working tools. It can be sawed with a hand saw or power saw, can be routed, tongue-andgrooved, sanded, and, in fact, run through most wood working equipment. High Modulus of Elasticity--The modulus of elasticity of 20-lb. density block is approximately 160,000 lb. per sq. in. Low Specific Heat--The specific heat of Kaylo Struc tural Insulating Block is approximately 0.22. Cellular Structure--Kaylo Structural Insulating Block is about 80 per cent inter-communicating air cells. The cells are extremely small, less than a micron in diameter. Low Moisture Absorption--Kaylo 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 i .most porous materials. It has unusual capacity to dis tribute moisture within its mass, and to give it off to surrounding air of lower moisture content. Its moisture absorption when surrounded by humid air is low. Test specimens dried for 24 hours at 215 F., 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. Consistent with the common practice for good construc tion involving porous insulating materials of high internal surface area, Kaylo Structural Insulating Block should be sealed against moisture on the warm side when it is subjected to extremely low temperatures. High Wet Strength--Kaylo Structural Insulating Block, like most other insulating materials, is not intended to serve immersed in water or exposed to extremely damp or humid conditions, yet its flexural strength when wet (immersed 10 hours) is reduced only about 15 per cent. Dimensionally Stable--The dimensions of Kaylo 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 mav 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 of from l3j 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. Denfity Block Can Be Used in Combination. Where two thicknesses of insulation are used to build up an insulating structure it is possible to use the two den sities in combination to develop the best insulation value strength and fire resistance. Kaylo Division OWENS-ILLINOIS GLASS COMPANY Toledo I, Ohio LAMINATION .amination over a Kaylo Insulating Core--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. borne 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 noi listed does not imply that it is not suitable. These ha\ ( 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: I t. * ` i, Wood Veneer or Paper or Plastics Durite No. 3026A Penacolitp G1131 Pecora 718 Cotobond 720 Vinylsoal MA 28-18 Ambcrlit* PR 14 O O G O G 0 Boitik 7026 Redux Syneo S-8348-M301W (DW) O O O Rasorsobond R-12 0 Armstrong J-1162 Tego O O Steel, Stainless Steel Galvaneal, or Aluminum Duritp No. 3026A or No. ANH267 N100 W G Ppcoro 718 3MEC 836 G GOG Ppnacolitp G1131 O Insalutp No. 1 0 Intprlokp 416 2 Vulcoloek DuPont 4663 DuPont 4646 Rpsorsabond R-12 G.E. 2142 G.E. 7031 Boitik 7026 Boitik EXE 138 Boitik 1007 Vinyltoal MA 28-18 Amborlita PR-14 Rpdux Armstrong J-1162 GO OO GOG GOG O G G O O O G O O O Kaylo Insulating Block or Cement-Asbestos Board F T * tev. Duritd 3026A Pdnocolito G1131 Armstrong J 1162 insoluta 1 G.E. 2142 Saloctron 6003 Vinylioal MA 28-18 Amborlita PR-14 Bostik 7026 Boitik EXE 138 Sodium Silieatp Rpdux Syneo X-8348 + 130LW (DWJ Rpsorsabond R-12 Togo O Q O o G O o o O 0 o o o o o (N. r ' V r f ; \ 1 1 Symbols for method of cure: I For Maximum Strength jj 'j 2 Clamped at room temperature for 24 hours. Clamped in oven at 120 F. for 1 hour. Placed in press at 10 p.s.i. at 300 F. for 10*30 minutes. Placed in press at 100 p.s.i. at 300 F. for 10*30 minutes. Clamped in oven at 250 F. for 10-30 minutes. High-frequency curing has been tried successfully on an experimental basis with wood, aluminum and stainless steel bonded to a Kaylo .isulating core. Many of the manufacturers making the above listed adhesives can provide adhesives suitable for high-frequency curing. Kaylo Division OWENS-ILLINOIS GLASS COMPANY Toledo 1, Ohio KI2 503 3M Copyright )94S, OwontJlisAoi* Glau Company Printed USA. The Right Material... Expert Application First. Kaylo Heat Insulation is proved a bitter material hydrous calcium silicate. Its light weight, strength, waterinsolubility, low conductivity and wide temperature range give you extra advantages tit no extra cost. 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 lie sare of getting the most out of your insulating dollars for your nc .- job. call the nearest Kaylo distributor. Chances are you can find him listed in the yellow pages of your phone hook. If not contact us and we'll give you hi name. KAYLO WRIT! FOR FREE IOOR--"Kaylo Heat Insulation " Address: Dept. N-370. Owens-Illinois Glass Com pany, Kaylo Division, Toledo I, Ohio. ... first in calcium silicate ...pioneered by OW^ENS ILLINOIS Glass Company MAIN OFFICE. TOLEDO I, OHIO --KAYIO SALES OFFICES: ATlANTA CHICAGO HOUSTON NEW YORK PHILADELPHIA PITTSBURGH ST LOUIS Ovwrns-Illinois Glass Company--Kaylo Division Advertisement No. K 15.1. appearing m the following publications: Chemical Engineering Jan.. 1953 Oil At Gas Journal -Jan. 12. 1953 Plant Engineering Jan . 1953 Power - Jan.. 1953 Petrn>eum Refiner Feb , 1953 Chemi.al Processing Feb.. 1933 Combustion Feh . 1953 * :rv V Po*rr- Feb . 1953 For Radii from V* Inch... . 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. KAYLO WRITE FOR FREE I00K ^""KoyloHaatInsulation. ' Address: Oepl. N*371, Owenilliinoit Clots Company, Koylo Division, Toledo 1, Ohio. i ... first in calcium silicate ...pioneered by OWENS ([^ILLINOIS Glass Company MAIN OFFICE: TOlfOO 1, OHIO-KAYLO SAKS OFFICES: ATLANTA CHICAGO HOUSTON NfW YORK PHILADELPHIA PITTSBURGH 5T LOUIS Owens-Illinois Glass Company Advertisement No. K<154--appearing in the following publications: Plant Engineering--March. 1953 Oil A Gas Journal--March 23. 1953 Chemical Engineering- March. 1953 Chemical Processing April. 1953 Petroleum Refiner May. 1953 350 300 O3 X \ 250' 0 a3 \L3n < 1 Oa> X HEAT INSULATING BLOCK Heat Loss, Surface Temperatures, and Efficiencies 300 400 500 600 700 800 900 Temperature Difference, Bare Surface to Air, F. EFfiClENCi^S^OH^FLAT^U R FACES=k --t--Ambf^rit 1200 c U4) w 4) Q_ C 4) U t 300 400 500' 600 700 800 900 Temperature Difference, Flat Surface to Air, *F. SOURCES OF TEST DATA: The data shown on 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. More detailed information on Kaylo Heat Insulating Block is available on request. American Structural Products Company, Toledo 1, Ohio. \ H ;t csfion WANTAGES... lake a good-looking installation. Thr "fool" io leasant and non-irritating. They can be cut, scored nd sawed with ordinary woodworking tools. Finishes hat go oi er the block, whether cement, cloth or other vpes, can be applied smoothly and with a minimum if effort. No special tools are needed. .OW MOISTURE ABSORPTION. Kaylo Heat Insuri ng Block absorbs little moisture from surrounding lumid air. EFFECTIVE AFTER LONG SERVICE. Kaylo Heat Insulat- ng Block remains strong, free from excessive powder ing, and shows little loss in weight or shrinkage after long application to temperatures up to 1200 F. Even conventional tumbling tests, run after prolonged heating, produce relatively little crumbling or break down of the material. TYPICAL APPLICATIONS: lr or outside, for large installations or small, up to 12u0 F,, use Kaylo Heat Insulating Block to insulate: Breechings Hot Air Ducts Tanks Towers Dryers Evaporators Heat Exchangers Cond`ensers Lehrs Autoclaves Ovens Furnaces Turbines Chilling Pits Boilers Precipitators Locomotives <aylo Heat Insulating Block covers both flat and curved urfaces on the power house equipment pictured here. By minimizing heat loss, it saves fuel and keeps temperatures within the room at comfortable levels. 7hysic/u characteristics .. .......................................................... App,,,*imo..iy " '* P' .......................... 50 lb. per >q >" STRINGTH (at S% data""*''*"' CQMPItfSSIVt STMNGTH A ...................i 50 lb. par q * .r hao.ina tor 24 ............................................................... o, ......................................................... ................ |W lb. par *9 ................ , 23 lb. par w. I"- .............. U 7 lb. par .......... .................................... . noo f `............. '.'.'.' ''.o.7% ...... ................. ..... * ............ 3.7% Afur tor * ........................- - ______5,7_%. -- aatt 1 705000' ................................ .....' ..........................................................................6a 9g/o0t at 1 2003 .................................. diminsionai *t*tanY 2i<or hour, Uaor 0,"r ............................................................... r,. wo; f.'. ......... ........................................ 0.04% .. 20 90;f = f. Ond % R.lo'ir* ................................................................... .. CONDUCTIVITY <K> o.*i A, 1005 F. mao" tamparotvra.......... .......................................... 0.54 At 500' F. maoti lepa',' ' ' ' S T AI . .Jr * r C, . -TVS;.; ygj. ^ -r>- LENGTH (inches) | WIDTH (inches) | THICKNESS (inches) jLlZl ZjE :j.. KzzGi^jnin 1...... X______ _______ t _ 0~ T~r"IT~'0 ' ~]r7r~o . I". other sizes are available on special order ^ .. "-'>*. -. '=`-L- `^-^y>cri3l^-y...Sv' ,/f:.y "3v'-- i:fc*T-:x-rv;;^ -/ =- - ...: W'y'r: '^sr J > "-1 -''--i'r~. .c / n ; ! U*'., v - . -. Manufactured by THE K A Y L O. D I V I S t O N :- -- szm^ Here is a really unique door. The Kaylo Firedoor is the only type of wood-faced door that carries a one-hour fire rating from Underwriters'' Laboratories, Inc.official testing agency for the National Board of Fire Underwriters. Many other important advantages are combined in the Kaylo Firedoor: r' Great Dimensional Stability--A Kaylo j Firedoor does not warp, swell or shrink--even Ji ."lI when subjected to extremes of heat or cold, dampness or dryness. High Insulation Value--Installed in an ex terior opening with weather stripping, the Kaylo y Firedoor insulates more effectively than a con ventional door, plus a storm door. : Light Weight plus Strength--A standard 3'4" x - 7' Kaylo Firedoor weighs only 90 lbs., but can support T an 8,000-lb. distributed load with only one-half inch deflection while loaded. After unloading, the door \ returns to its original position. Handsome Appearance--The wood veneer-faced Kaylo Firedoor equals the richness of the most strik ing conventional wood doors. It offers rated fire pro tection, without sacrifice in beauty. THE INORGANIC KAYLO CORE Heart of the Kaylo Firedoor is its core--a chemical composition which is completely inorganic. It does not burn. It is rot-proof and vermin-proof, per manently resistant to termites, cannot be damaged by water. The Kaylo core material has a nominal density of 20 lbs. per cubic foot.and is sufficiently sturdy to insure proper performance of the Kaylo Firedoor under most severe conditions. Kaylo Firedoors offer a great combination of advantages for hospitals, schools, apartment houses, hotels, office buildings--and residences. This label on doors which you specify or install means rated fire protection, safety K and reduced insurance rates for building owners. It appears on every Kaylo-core door, k t i Z. G>! - is Cc --sc*** 5C3 WOema mi wait* I * f! u ----- ,,.------------ . t V.',1' iV , ? Z^7 r-^5 . Jj J l \J i Ui . tt_7 c' 7 test comparative fire-resistance, a Kaylo Firedoor and conventional wood door, set side by side in a concrete wall, are exposed simultaneously to fire. The fire is set in a wood pile, soaked with 40 gallons of fuel oil. Here's how the two doors looked on the "hot side'' after less than 10 minutes. .`S' On the opposite side of the well, flames lick through the conven tional wood door. But the Kaylo Firedoor has completely checked the fire and most of the heat cs well. Note the men touching the Kaylo Firedoor with their bare hands. " ' ' If00^SlLi^ sfitf ''>5 *j?>v .-r`vr JU -- ---J Fireproofed Edge Banding Face Veneer rj) ./ r; i * ../ "INSIDE VIEW'' SHOWS UNIQUE FEATURES OF THE KAYLO FIREDOOR'S CONSTRUCTION f. f icf ( Look for this metal label on the hinge edge near the top of every Kaylo Firedoor. It is evidence that Underwriters' Laboratories, Inc., have given the door c cr.e-r.our f.re rating for Class B and C openings. Fireproofed Edge Banding-- AH four edges of the Kaylo Firedoor are banded with strips of solid hardwood, which has been treated with Protexol Class A fireproofing agent. Cross Banding--Veneer cross bandings are bonded to the door's Kaylo core with water proof phenolic glue. Kaylo Core--The core is made up of closely fitted sections of inorganic Kaylo material, which have been joined together with tongue-andgroove edges as p.--scribed by Under writers' Laboratories, Inc. Face Veneer--Available in several domestic woods, the face veneer is bonded to cross bandings with water proof phenolic glue. OWENS-ILLINOIS GLASS COMPANY Kaylo Division Toledo 1/ Ohio ATLANTA - BOSTON BUFFALO CINCINNATI CHICAGO -A. I. A. h ie N o. 17 A . TABLE OF CONTENTS G e-e*cI de sc.-Ipi.on...................................Pope* 2 "-5 ie:"n!ccl dcic...........................................Pope* 6 --7 Cc':**::.orv ce'clii.................................. Pope* E -- 11 { (LAMENAirBD PiUiElJ WITH CEMEE-ST-ASBESTOS FACING Introduction of the calcium-silicate insulating material, sold in various forms under the brand name "Kcylo," has opened up an entirely new field of laminated building prod ucts. This inorganic materiel is used as a core in panels faced with wood veneer, plastics, metal and (as described in this booklet) cement-asbestos board. For each laminated product, it provides a core which is incombustible, lightweight and strong end offers insulating value and exceptional di mensional stability. Kcylo cores are being used in a number of laminated products, now on the market, in which fire resistance is a prime consideration. These include firedoors, wall panels and marine bulkheads. Kaylo Laminated Panels with cement-asbestos fac ing provide complete curtainwall or non-loadbearing partition sections which require no finishing on either side--no painting, furring, plastering, siding or insulation. While r.ot required, paint may be applied to these panels by conventional means, if it is desired. Although only two inches thick, Kaylo Laminated Panels with cement-asbestos facing have better insula tion value than 16 inches of solid concrete. Completely inorganic, they Lave unusual dimensional stability. They have remarkable resistance to deterioration from water or exposure to the elements and show virtually no expan sion or contraction, even in extreme weather cycles. QUICK INSTALLATION Lack standard 4' x S' Kaylo panel provides a complete wall section, 32 square feet in area, which weighs only about 200 pounds. Each panel is easily erected complete in place in a few minutes. Compare this speed and sim plicity of erection with the time and work required in the building of conventional masonry walls of various types. For example, an eight-inch brick wail of equal area requires mixing of mortar and laying individually 416 common bricks, resulting in a wall which weighs about 2700 pounds. Panels may be joined to steel or wood framing by any of a wide variety of methods. Only standard tools used in the building trade are needed for erection work. ^ INCOMBUSTIBLE Both the Kaylo core and cement-asbestos facing of these Kaylo Laminated Panels are incombustible. Installed with proper joint systems, the panels provide a wall that will withstand more than one hour's exposure to fire when tested by standard ASTM procedures. MANY APPLICATIONS Possible applications for Kaylo Laminated Panels with cement-asbestos facing include interior partitions or exterior wails for nearly every type of building. A sug gested list follows: INDUSTRIAL: Manufacturing buildings Warehouses Vtility buildings COMMERCIAL: PUBLIC: Stores Warehouses Carcges Office buildings Field stations Schools Hospitals *Depots o. _ 1 THE KAYLD CORE To appreciate the superiority of Kaylo Laminated Panels over ether products of similar appearance, it is neces sary to know something about the physical character istics of the Kaylo core. Near white in appearance, the Kaylo core is a stable, inorganic calcium-silicate material having 4 density of about 20 pounds per cubic foot. This light weight-- lighter than all woods, except Northern White Cedar and Corkwood, contributes vitally to the utility and ease of handling, so characteristic of Kaylo Laminated Panels. The large percentage of microscopic voids in its fine cellular structure gives the Kaylo core high resistance to the passage of heat, and, therefore, provides excellent insulation. Being inorganic it is rot and vermin proof. It is rated "Incombustible" by Underwriters' Labora tories and tests prove its superiority as a protection against the spread of fire-flame or smoke. The physical characteristic possibly most important to a superior laminated panel is dimensional stability of the core. The dimensional stability of the Kaylo core is excellent. For a material so light in weight, it is excep tionally strong when subjected to flexural or compressive loads. Exposure to water produces only negligible change in dimensions and does not warp or swell the panel. Completely saturated, the Kaylo core retains at least 85% of its normal dry strength, which is completely recovered when material again becomes dry. STANDARD PANELS Playio Laminated Panels with cement-asbestos facing are nominally two inches thick. The Kaylo core is nomi nally Ilf " thick and each face veneer is H " thick. Cement-asbestos faces are laminated to the core with a waterproof adhesive. Panel edges are protected by a weatherproof coating. The standard panel size is 4 feet x S feet. Other sizes are available on special order. Complete technical data, including physical char acteristics and typical construction details, are shown zr. tr.e following pages. < WEIGHT AND INSULATING Y A L U E ( 1 *--^ 4^- LAMINATED PANELS COMPARED TO OTHER WALLS U-FA.CT0R WEIGHT (Bhi./ie. ft./hr /*F ) E?b./sc. ft.) 2' KAYLO LAMINATED. PANELS WITH CEMENTASBESTOS FACING 1 J1 614 8' SOLID BRICK 12' CONCRETE .50 \l XLv-^ 84 WM\ . -si 1 | I 8' HOLLOW CINDER BLOCK m 01 \ .42 30 V CEMENT PLASTER ON CHANNEL STUDS AND METAL LATH | INSIDE I PARTITION 11 Vi 5' WALL V. PLASTER BOTH SIDES ON 2X4 STUDS AND METAL LATH INSIDE fug PARTITION 18 i' HOLLOW TILE \ INSIDE PARTITION 18 j^zd:ylo Laminated Parcels provide a neat ^ousside ll'cU, resistant to fire and weather. Inside of well provides clean, light-reflective sur face. Kaylo Roof Deck makes attractive ceiling. T O T A L L O A D . I A S . A P f l U D A T t I I I It 0 P O I N T TECHNICAL DATA < 1 STRENGTH A 4' x S' Kaylo Laminated Panel with cement-asbestos faces, supported on a 7'-9" span, using one-third point loading, carried-an ultimate load of 2920 pounds. A panel restrained by three comers and the free fourth comer leaded three times with a weight of 113 lbs., pro duced a maximum deflection of about A ". When the weight was removed, the panel returned to its original position. From the load-deflection curve, at the left, it is obvious that the panel supported on a 7'-9" span can withstand many times the required design windloads without exceeding its elastic limit. IMPACT RESISTANCE In an impact load test conducted according to Bureau of Standards procedures a 60 lb. weight was dropped on the center of a panel supported on a 7'-6" span. The height of the drop was increased by 6" increments, be ginning at 6". The panel did not break until the drop had reached 6'-0". The instantaneous deflection on the drop of 5'-6" was only 1.07", FIRE RESISTANCE In a fire test conducted in accordance with standard A.S.T.M. test procedure on a 2" Kaylo Laminated Panel with cement-asbestos faces, the average temperature rise on the cool side did not exceed 250c F. until more than 60 minutes time had elapsed. LAMINATED PANELS WITH CEMENT-ASBESTOS FACIK C INSULATION VALUE Tne U-factor of a panel l A " thick, for ambient still air, is 0.26. For outside exposure (one side exposed to 15 mph Rind' it is 0.30. SCREW-HOLDING POWER 'No. 10 wood screws driven 1" into a Kaylo Laminated Panel with cement-asbestos faces, using a No. 17 drill for the pilot hole, had a withdrawal resistance averag ing 190 lbs. SOUND TRAHS MISSION The sound reduction of a panel tested at frequencies from 137 to 2070 averaged 35 decibels. The reduction between frequencies of 1161 to 2070 averaged 42 decibels. VAPOR TRANSMISSION Building materials, to be considered good vapor barriers, are expected to have average vapor transmission rates of less than 1-25 grains per hr. per sq. ft. per in. of mer cury pressure differential between the two faces. Kaylo panels average 1.22. With suitable paints on the cementasbestos faces, vapor transmission is reduced consider ably below this value. For example, an acceptable chlorinated rubber paint reduces vapor transmission of the Kaylo panel to practically nothing. DELAMINATION In order to produce delaminating effects, a panel was heated to 270 F. on one side only, then cooled. This was repeated for ten cycles while a temperature of 70 was maintained on the cool side. No distress and nc apparent delamir.ation resulted. In fact, this same panel was later used in the strength test mentioned previously. Another panel heated to 175 F. on the hot side then cooled while a temperature of 70 F. was maintained on the cool side has gone through 120 cycles of heating and cooling without distress. 'U' V.iV TYPICAL DETAILS Scale l'/j" = r-0 USING GLASS BLOCK WITH KAYIO LAMIKATED PAHELS iK .M! - - - ' ' ! 1 jPj ' I^T 1 ' ' III Ml '1 ' ' 1 ' n " ''""f ... ... . . . : ll u_ j1 ' - ; : 1 1! ! 1, i. . 1 I`1ll 1 ' '.'I---1 i > "- - - - - - - !i 1 !l ii n . i i 1! |l ll 1 LAfiflB HEATED PANELS WITH CEMEKT-AS2EST0S FACIKC Detail "D-D" _________ Detail "F-F" *r> '7 5" CKAXLiEl \ INSl'U'l class eloca II I thC-- ^ :aju Detail "M-M' 2K' KAY10 00f TILE Detail "K-K" w TM rz~r: Detail "L-L" Detail "K-H" c.i;s---- 5`.OCR C C:hTiv.^i--M u A 'cxi" mi.; Detail "L-L" "V B 9 TYPICAL DETAILS AA 1 if 1 M 1 i III 1 H 1 i >h~ ' F i Ig!1 ! 1 1 _ J .. 1 . 1 1!1\ 1 1 ii l i;t 1 r 1 1 11 l li l 1 cf-- B g! Hi i H ir i---- LP E ___ E @ 1__ !____ ^ ....... EIEVAT1DN VERTICAL PANELS J| Jl r rn STEEL FRAMING Scale l'/2'' = l'-0" ELEVATION-FRAMING WITH LAMINATED PANELS CEMEKT-ASBESTOS tr.3\ " ) FACING GIRTS -A<t-L ,1 4 u::n:o lPvih.iUmiTEP SJ COL ' ; T ,,Vf Detail "A-A" ' ziiz*. 'J 1 C-M-NT.AS&tSTDS 1 v'-" :5i sr '? i* \s t Detail "B-B' r g. | iMta' FllVhtrf Whfr "" j JUe Luietf zJ i'TH __ J U-5-&___________ 1 Hi Det2il ``C-C *"Top Side-' Fasteners by H. A B. Enterprise Corp. Trenton, New Jersey or approved equal MPTfcl _ l-tl fUtSKINC Fj Dt2it "E'G Det/'E-E" Alt."E-E" LAMINATED PANELS WITH CEMENT-ASBESTOS FACING Kaylo Division OWENS-ILLINOIS GLASS COMPANY T'O L E D O 1 , OHIO  General product description 2 and 3 Spacficat cm and design dcra for use with hollow box sub-purlin..................................................................4 Construction details for use with hollow box sub-purlin. . .5 Specifications and design data for use with rail sub-purlin . .6 Construction detoils for use with rail sub-purlin..................... 7 Specifications ond design data for use with standard structural members........................................................................ 8 Construction details for use with standard structural members........................................................................ 9 Typical construction details............................................................ 10 Technical data......................................................................................II Photographs....................................................................... back cover Kaylo Roof Tiles have a rare combination of strengtr. an<i light weight. Tiles are easy to handle, easy to carry. Moving loads of tiles across Kavlu Roof Decks in wheelbarrows or dollies is collision practice. KAYLO Insulatinq ROOF TILE SETS A NEW STANDARD FOR LIGHTWEIGHT NON-COMBUSTIBLE ROOF CONSTRUCTION Kaylo Insulating Roof Tile laid on light steel members now makes available for the first time a roof deck in which fire pro tection, structural strength and insulation are all provided in a single lightweight all-mineral unit. LIGHTWEIGHT STRUCTURAL UNIT Kaylo Roof Tile is not merely a roof insulation. It is a rein forced structural unit designed for a total load of fifty pounds per square foot with an adequate safety factor. Its flexural strength is more than sufficient for typical roof deck require ments. Kaylo Roof Tile decks weigh approximately six pounds per square foot, including supporting sub-purlins, or around five pounds to the square foot for the roof tile only. Thus it is now possible to daeign a deck made with a non combustible tile so that the dead load above the main purlins, including an excellent built-up roofing, is about twelve pounds per square foot of roof area. INSULATES AS IT COVERS This lightweight roof deck combines structural strength and thermal insulation in one material. Since Kaylo Insulating Roof Tile provides insulation value equal to that of an inch and onehalf of standard insulating board, no additional insulation is needed for usual installations. A special operation of applying insulation over the structural deck is thus eliminated. 2 KSI-4B8* 10M--Copyright, 1948, American Structural Product} Company Printed in U.SA. FIREPROOF Kaylo Roof Tile provides a new standard of fire protection for lightweight construction. The tile themselves will withstand building fire temperatures as defined by the standard A. S. T. M. fire curve, for more than one hour without failing in load carrying capacity and without permitting a temperature rise on the cold side great enough to constitute failure. Fire originating above a Kaylo roof deck is prevented from producing dangerous temperatures within the building for a period of at least one hour. Because of economy of steel in the supporting structure made possible by a Kaylo roof deck; because of its non-com bustibility; because of its insulation value; because of its liveload-carrying capacity in relation to the dead load of the deck; and because it can be erected rapidly; this new roof construction recommends itself to every architect and engineer who has a major roof construction problem today. FIELD TESTED Kavlo Insulating Roof Tile has been introduced to the public after several years of experimental development and pilot plant manufacture by the Owens-Illinois Glass Company. ,In this development an area of several hundred thousand square feet has been incorporated in the construction of Owens-Illinois and American Structural Products buildings, and others, including plants, laboratories, offices and warehouses. Much of it has been in service for several years. " 'Vf. ' ' ^ *> t . . -*v- - * .* ' GENERAL DESCRIPTION Kaylo Insulating Roof Tile is made in one size only, nominally 2S r 18x^36 inches. It is white, or whitish in appearance and is made entirely of a non-combustible mineral base which is pre dominately a calcium silicate, or combination of calcium silicates, into which mineral fibers have been incorporated for reinforcing at the time of manufacture. This fiber-reinforced mass is ad ditionally strengthened by a welded wire mesh placed in the tile at the time it is formed. The unique cellular structure of Kaylo Insulating Roof Tile makes possible its remarkable combination of desirable char acteristics. Kaylo Insulating Roof Tile has ceils so small they are measured in fractions of a micron, and so tremendous in number that more than 80rr of the tile is composed of air ceils which together have a total wall area of more than one hundred acres per cubic foot of tile! Tile units have a smooth under-surface with a light reflection factor of approximately 80 per cent. SAVES ERECTION COSTS Kaylo insulating roof decks are easier to install than conven tional decks--yet they require no revolutionary new methods. Workmen like Kaylo Roof Tile. When American Structural Products sub-purlins are used, a Kaylo Roof Tile deck is applied in only three steps--laying tile into place, grouting end joints and covering the deck with roofing materials. Kaylo Roof Tile can also be used with other types of framing. No added application of roof insulation is necessary except where special conditions require an unusually high degree of insulation. In such cases light density Kaylo insulation in block form can be mopped in over the Kaylo insulating deck. A twoinch thickness, for example, mopped in over a standard Kaylo insulating deck will provide a U value, or over-all transmission, of approximately 0.10 Btu per hour per square foot per degree difference between inside and outside temperatures. Kaylo Insulating Roof Tile can be fitted to odd-sized spaces at the job-site without special tools. Any saw which will cut the wires, such as a light power saw, is suitable. Kaylo Roof Tile can be readily chipped or gouged to fit irregular surfaces. Because of its light weight and convenient size, Kaylo Roof Tile is easy to carry to the place where'it is to be laid. It has been designed as a simple, one-man tile and weighs only ap proximately 23 pounds per tile (having an area of four and one-half square feet). SPECIFICATIONS, DESIGN DATA AND K NOTE: The general conditions of the contract are hereby made, by reference, a part of this specification. SCOPE This work consists of furnishing all labor and materials neces sary for the installation of Kaylo Roof Tile, including steel sub-purlins, grout and curbs as shown on the drawings, or as specified herein, or both. MATERIALS 1. Sub-purlins. Steel sub-purlins shall be American Structural Products hollow box sub-purlins No. 102. Before leaving the shop, all steel work shall be thoroughly cleaned of all loose rust, mill scale and foreign matter and given one coat of approved metal protection applied thoroughly and evenly. 2. Kaylo Roof Tile. Roof tile shall be precast and reinforced Kaylo Roof Tile. 25s inches thick by 18 inches wide by 36 inches long as made by American Structural Products Company. 3. Anchors. Anchors are not required with American Struc tural Products sub-purlin N'o. 102. 4. Grout. Grout for end joints of'tile shall be composed of the following-materials, measured by volume: PROPORTIONS Ratio Batch Volume Gauging plaster (quick-setting)............... 1.0 1 cu. ft. Expanded vermiculite (vermicuiite plastering aggregate).... 0.6 0.6 cu. ft. Water (approximate).................................... 1.0 7*2 gallons Consistency of grout shall be such that it can be poured, but not so thin that the vermiculite will float. Add water to provide proper consistency. Stir thoroughly to remove all lumps. Dry materials may be mixed in large quantities as desired, but water should be added, only to small batches which can be used immediately. 5. Curbs. Kaylo Insulating Roof Tile 2vs inches thick by 18 inches wide by 36 inches long shall be used for curbs wherever shown on plans. Tiles shall be cut on job to height required. INSTALLATION 1. Sub-purlins. To receive Kaylo Roof Tile, American Struc tural Products hollow box sub-purlins No. 102 shall be accurately spaced 3 -1" on centers. Sub-purlins shall be welded to each support with one fillet weld, inch long placed on alternate sides of sub-purlins Where joints of sub-purlins do not occur over supports, then ends shall be welded together. Where ends of sub-purlins beai on masonry, they shall be securely anchoied to the masonry as shown on the drawings or with one bolt and 2 x 2 x G-inch plate washer at each sub-purlin. 2. Kaylo Roof Tile. Kaylo Roof Tile shall be spaced evenly on sub-purlins to provide a minimum end bearing of *2 inch, with that side up which is marked "top." Tile shall be butted tightiy together at sides. Cut tile to fit at ridges, valleys, parapets, curbs, walls, around vents, pipes, etc. and grout in place. Where necessary to cut standard pieces for fitting, any hand or power saw which will cut the wire mesh is suitable. 3. Grout. Joints at ends of tile over sub-purlins, and at ridges and hips, shall be filled with grout mixed as specified. Where sub-purlin No. 102 is used the stem of the sub-purlin shall be completely surrounded with grout to provide a key anchorage against uplift pressure. Grout shall be poured from an open-spout can into joints until the grout protrudes slightly above the surface of the tile. When grout has reached its initial set (few minutes) scrape joints flush with the tile surface. Sweep all loose and excess grout from the roof, leaving the roof deck free from all foreign matter. 4. Saddles. Where concrete (either lightweight or gravel ag gregate) saddles or cants are used over Kaylo Roof Deck, prime surface of tiles which receive saddles, or cants, with asphalt primer (Federal specifications, SS-S-701). Mop primer over top surface of tile using not less than 7.5 pounds (one gallon) per one hundred square feet of roof. c-1.765 f Size 3 1/4" > 2 13/32" 1 4 ga. Metal ATI FOR HOLLOW BOX SUB-PURLIN NO. 102 Weight Lb. L.F. 3.00 Lb. S.F. of Roof 1.00 Spacing 3-1" On Centers Ix-x In. 4 .955 ly-y In. 4 .384 Sx-x In. 3 .541 ALLOWABLE SPANS FOR VARIOUS LOAD CONDITIONS Total lood Span * Defection {Per Sq. Pt.) f =20,000 f = 18,000 f =20,000 f = 18,000 Southern States & Pacific Slope 32 lb. 9'-8" 9-3" .360 .302 Central States 42 Ib. 8-5" 8'-0" .271 .222 Rocky Mounfom & N.E. States Northwest Stotes 49 Ib. 57 Ib. 7-I0" 7'-5" .227 7` 3" 6'-l 0" .203 .191 .160 i Astumed dead toed, per sq. ft. of roof: Koylo tile end sub*purlins........... 6.0 ib. Built-up roofing (tor and grovel).................... 6.0 Ib. Total dead load.................... 1 2.0 Ib. Assumed mow lead, on horizontal surface per sq. ft of roof: Southern Stores (live load)............. 20 Ib. per q. ft. Central Stote*..............30 Ib. per sq. ft. Rocky Mountains and N. E. States............37 Ib. per sq ft Northwest States.... i5 lb. per sq. ft. M = WI To * Spam thown are for flol roof.. Where .ub-purl.n. run parallel to Ihe ridge of pitched roof* and un.ymmetncal bending occur., reduce ipon. ^Scale J'-O" ^Except as noted *"lf* " J& < ' 5 SPECIFICATIONS, DESIGN DATA AND D NOTE: The genera] conditions of the contract are hereby made, by reference, a part of this specification. INSTALLATION - ' SCOPE This work consists of furnishing all labor and materials neces sary for the installation of Kaylo Roof Tile, including steel sub-purlins, grout and curbs as shown on the drawings, or as specified herein, or both. MATERIALS 1. Sub-purlins. Steel sub-purlins shall be American Structural Products structural steel rail sections No. 101. Before leaving the shop, all steel work shall be thoroughly cleaned of all loose rust, mill scale and foreign matter and given one coat of approved metal protection applied thoroughly and evenly. 2- Kaylo Roof Tilo. Roof tile shall be precast and reinforced Kaylo Roof Tile. 2s* inches thick by 18 inches wide by 36 inches/ long as made by American Structural Products Company. 3. Anchors. Anchors are not required with American Struc tural Products sub-purlins No. 101. 4. Grout. Grout for end joints of tile shall be composed of the following materials, measured by volume: PROPORTIONS Ratio Batch Volume Gauging plaster (quick-setting)............ 1.0 1 cu. ft. Expanded vermiculite (vermiculite plastering aggregate).... 0.6 0.6 cu. ft. Water (approximate).................................. 1.0 71 i gallons Consistency of grout shall be such that it can be poured, but not so thin that the vermiculite will float. Add water to provide proper consistency. Stir thoroughly to remove all lumps." Dry materials may be mixed in large quantities as desired, but water -should be added only to small batches which can be used immediately. _ _ . 5. Curbs. Kaylo Insulating Roof Tile 25s inches thick by 18 inches wide by 36 inches long shall be used for curbs wherever shown on plans. Tiles shall be cut on job to height required. 1. Sub-purlins. To receive Kaylo Roof Tile. American Struc tural Products rail sub-purlins No. 1U1 shall be accurately spaced 3'-l V on centers. Sub-purlins shall be welded to each support with one fillet weld, )* inch long placed on alternate sides of sub-purlins. Where joints of sub-purlins do not occur over supports, their ends shall be welded together. Where ends of sub-purlins bear on masonry, they shall be securely anchored to the masonry as shown on the drawings or with one bolt at each sub-purlin. 2. Kaylo Roof Til*. Kavlo Roof Tile shall be spaced evenly on sub-purlins to provide a minimum end bearing of inch, with that side up which is marked "top." Tile shall be butted tightly together at sides. Cut tile to fit at ridges, valleys, parapets, curbs, walls, around vents, pipes, etc. and grout in place. Where necessary to cut standard pieces for fitting, any hand or power saw which will cut the wire mesh is suitable. 3. Grout. Joints at ends of tile over sub-purlins, and at ridges and hips, shall be filled with grout mixed as specified. `Where sub-purlin No. 101 is used the stem of the sub-purlin shall be completely surrounded with grout to provide a key anchorage against uplift pressure. Grout shall be poured from an open-spout can into joints until the grout protrudes slightly above the surface of the tile. When grout has reached its initial set (few minutes) scrape joints flush with the tile surface. Sweep all loose and excess grout from the roof, leaving the roof deck free from all foreign matter. 4. Saddles. Where concrete (either lightweight or gravel ag gregate) saddles or cants are used over Kaylo Roof Deck, prime surface of tiles which receive saddles, or cants, with asphalt primer (Federal specifications, SS-S-701). Mop primer over top surface of tile using not less than 7.5 pounds (one gallon) per one hundred square feet of roof. FOR RAIL SUB-PURLIN NO. 101 C = 1.330 I Size 2-1/4" X 2-3/8" Weight Ib./L.F. 1 Lb./S.F. . 3.3 I of Roof 1U Spacing 3-1-1/4' On Canters lx*x In. 4 .694 ly-y In. 4 .182 Sx-x In. 3 .522 ALLOWABLE SPANS FOR VARIOUS LOAD CONDITIONS Total Load Spon* Deflection |Per Sq, Ft.) (=20,000 f =18,000 f =20,000 f = 18,000 Southern States & Pacific Slooe 32 lb. 9'-6" 9-0" .454 .370 Central Stotes Rocky Mountain &,N.E. States Northwest States 42 lb 49 lb. 57 lb. 8'-4" 7-9" 7-2" 7-10" i 7-4" 6'-9" .358 .310 .258 .279 .248 .208 Assumed dead load, per squore foot Of 'Oof: Koylo Hie and sub*purlins. . . . 6.0 lb. Built-up roofing (tar and grovel)..................... 6.0 lb. Totol deod lood.................... I 2.0 lb. Assumed snow load on horizontal surface per sqycre foot of roof. Southern Stotes and Pacific Slope Hive load). .20 lb. per sq. ft. Control Stores............. 30 lb. per sq. ft. Rocky Mountains and N E. States............. 37 lb. per sq. ft. Northwest Stotes. . . . 4$ lb. per sq. ft. M *W1 10 *5pans shown are for flat roofs. Where sub-purlins run poroMef to the ridge of pitched roofs and untymmetrical bending occurs, reduce span. 6 ft f RAIL SUB-PURLINS 1 1 Scale 3/4"*= t'-O" ? Except as noted ----;-s'f ujr: -x ~ SPECIFICATIONS, DESIGN DATA A NOTE: The general conditions of the contract are hereby made, by reference, a part'of this specification. " SCOPE This work consists of furnishing all labor and materials necessary for the installation of Kaylo Roof Tile, including (bent studs) (staple clips) (nails), grout and curbs as shown on the drawings, or as specified herein, or both. 1. Kaylo Roof Til*. MATERIALS Roof tile shall be precast and reinforced Kaylo Roof Tile, 2% inches thick by 18 inches wide by 3G inches long as made by American Structural Products Company. 2. Anchorage Materials. (Select one which applies to details used.) ab. Bent Studs (for trussed purlins or standard structural shapes) Bent studs shall be 1 'is" x l'i" X. T. Bent 0. L. E. Studs. (Not threaded; outside loaded end.) Each stud shall have a suitable ferrule. Studs and ferrules shall be as manufactured by Nelson Stud Welding Corp., or approved equal. c. Nails (for wood framing) Nails for fastening Kaylo Roof Tile to wood framing members shall be 20d common x 4" long. d. Nails (for Stran-Steel) Nails for fastening Kaylo Roof Tile to Stran-Steel shall be 12d common x 3" long. dd. Staples (for Stran-Steel) Staples shall be -12 ga. (.105) mill galv. steel wire at least 3" long and 1" wide. 3. Grout. Grout for end" joints of tile shall be composed of the follow, ing materials, measured by volume: PROPORTIONS Botch Gauging plaster Ratio Volumo (quick-setting) .... 1.0 1 cu. ft. Expanded vermiculite 0.6 0.6 cu. ft. 1.0 7H gal. Consistency of grout shall be such that it can be poured, but not so thin that the vermiculite will float. Add water to provide proper consistency. Stir thoroughly to remove all lumps. Dry materials may be mixed in large quantities as desired, but water should be added only to small batches which can be used im- mediately. NOTE: Reduce water content when using Stran-Steel. (Mini mum quantity, 4 gallons per batch.) 4. Curbs. Kaylo Insulating Roof Tile 2*4 inches thick by 18 inches wide by 36 inches long shall be used for curbs wherever shown on plans. Tiles shall be cut on job to height required. , INSTALLATION 1. Purlins (or joists). Purlins or joists shall be furnished and installed by others. They shall be accurately spaced 3'-U'2" on centers to receive Kaylo Roof Tile. 2. Kaylo Roof Tilo. Kaylo Roof Tile shall be spaced on sub-purlins or joists to provide an end bearing of at least l2 inch, with that side up which is marked "top." Tile shall be butted tightly together at sides. Cut tile to fit at ridges, valleys, parapets, curbs, wails, around vents, pipes, etc., and grout in place. Where necessary to cut standard pieces, any hand or power saw which will cut the wire mesh is suitable. 3. Anchorage. (Select one which applies to details used.) ab. Bent Studs (for trussed purlins or standard structural shapes) Bent Studs shall be securely welded to the top chord of purlins by the Nelson Gun Stud Welder or other approved method. They shall be spaced 9" o. c. and lined up accurately on each purlin. c. Nails (for wood framing) Nails shall be spaced 9" o. c. Two nails at each end of tile shall be driven vertically through roof tile and sunk so that heads are flush with top of tile. d. Nails (for Stran-Steel) Nails shall be spaced 3" o. c. and driven into Stran-Steel a minimum of lU". The heads of the nails shall project above the Stran-Steel a minimum of ll-a". dd. Staples (for Stran-Steel) Staples shall be spaced 3" on centers and driven into Stran-Steel a minimum of l'i". Staples shall project above Stran-Steel a minimum of 1H". 4. Grout. Joints at ends of tile over purlins or joists, and at ridges and hips, shall be filled with grout mixed as specified. The grout shall completely fill the joint over the purlins so that the (bent studs) (nails) (staples) are entirely encased in grout to provide anchorage against uplift pressure. Grout shall be poured from an open-spout can into joints until the grout protrudes slightly above the surface of the tile. When grout has reached its initial set (few minutes) scrape joints flush with the tile surface. Sweep all loose and excess grout from the roof, leaving the roof deck free from all foreign matter. 5. Saddles. Where concrete (either lightweight or gravel aggregate) saddles or cants are used over Kaylo Roof Deck, prime surface of tiles which receive saddles, or cants, with asphalt primer (Federal specifications, SS-S-701). Mop primer over top sur face of tile using not less than 7.5 pounds (one gallon) per hundred square feet of roof. 8 Detail SLOW BURNING CONST. ' Detail 0 STRAN-STEEL SUB-PURLINS i. wA-V . j f *. . , 2*y.ittX&-. f-i TYPICAL DETAILS fKAHINE HAD SECTION--"B" FRAMING FOR SUMP PAN {USING STRAH STEEL SUB PURLINS) FLASHING LIGHT WEIGHT F1U W.'Pl'N-k ,'N ---- r -- t m3ls *-2V HATlO ROOF Tlli SU8 PURLIN No. 102 iTE WELDED TO SU8-PURLIN WHERE OPENING IS OVER 2' 10`WIOE PROVIDE HEAOER BETWEEN MAIN PURLINS FRAMING PLAN OPENING BETWEEN SUB PURLINS ^PURLIN^ /HEADERS n-i---- J*t~ 05 open!-- i 3'-1" C.TOC. Of SU8 PURLINS r- SECTIOK--T FRAUING PUR OPENING GREATER THAN 2'10* FRAMING AROUND OPENINGS {USING SU8-PURUN No. 1021 VALLEY DETAIL DETAILS FOR STEEP PITCHED ROOFS--RAFTER FRAMING RIDGE DETAIL 10 7 l H M 3 C M DAT A KAYLO ROOF TILE INSULATING VALUE Thermal conductivity "K" (Btu. sq. ft., hr., 'F., in.)............. 0.62 Overall heat transf. coef. "U" (Btu., sq. ft., hr., *F., thickness) Roof tile only............................................................................ 0.20 Roof tile -- built-up roofing.................................................. 0.19 Roof tile -- l`j" insulation*-- built-up roofing.............. 0.11 Roof tile -- 2" insulation --built-up roofing...................... 0.10 "11-lb. density Kaylo Insulation protect the interior from excessive temperature rise. For a fire originating within the building the limit of endurance is the limit of the supporting steei or the limit of the construction immediately below the roof deck. WEIGHT Approximate weight per square foot (lb.).......................... 5.0 Approximate density (lb. per cu. ft. i .............................. 20.5 Approximate weight per tile (lb.)............................................ 22.0 5 X: STRENGTH FLEXURAL STRENGTH This table shows the factor of safety and deflection of Kaylo Insulating Roof Tile for several uniformly distributed loads. CLEAR SPAN = 34 INCHES-DEFLECTION FOR 1/3*0 OF SPAN =.0945 INCHES TOTAL UNIFORM LOAD (LB., SQ FT.) factor of safety ULTIMATE DEFLECTION [INCHES) 40 11.1 .023 45 9.9 .026 50 8.9 .029 55 8.0 .032 ' 60 7.4 .035 modulus OF rupture. The average modulus of rupture for Kaylo Roof Tile is 175 lb. per sq. in. modulus OF ELASTICITY. The average modulus of elasticity for Kaylo Roof Tile is 160,000 lb. per sq. in. compressive strength. The average compressive strength for Kaylo Roof Tile is 500 lb. per sq. in. DIMENSIONAL STABILITY dimensional CHANGE DUE TO moisture. The linear expansion of Kaylo Roof Tile after repeated cycles of soaking and drying is approximately .04 of 1%. This equals an increase in length for a standard tile of only fourteen-thousandths of an inch. STRENGTH WHEN WET. The flexural strength of Kaylo Roof Tile when soaking wet (after soaking for 10 hours) is approxi mately 85% of its normal strength. ,/ NAIL-HOLDING POWER RESISTANCE TO DIRECT NAIL WITHDRAWAL (SMOOTH NAILS) Size of Noil 6d 7d 8d 9d 10d 1 2d 16d 20d 30d 40d DiomotormInch#* .113 .113 .131 .131 .148 .148 .162 .192 .207 .225 Resistance of Kaylo Roof Tile 20 20 23 23 26 26 28 32 36 40 [Total Pull in lbs. par Inch Pene- frofion). FIRE RESISTANCE Kavlo Roof Tile is non-combustible. It will resist a typical building fire, as defined in the standard A. S. T. M. timetemperature curve, for more than one hour. Thus, a fire originating on the top side can bum off the applied covering and the fire resistance of the tile will enable the tile to carry its required load for more than one hour and at the same time LIGHT REFLECTIVITY Light reflectivity of Kaylo Roof Tile is approximately 80%. 11 In ulatin Structural Products Co., Toledo, Ohio 3 L = r> C O \< Oe*?':! D'ccvc! c e jcrlpfici......................... ............................... 2 crd 3 Szcz ~:z` c-1 c-c ca *' cctc :or ute with Irc ;w :cx ut-puf,'!n. ............................... ............................ Corr.v:: o-i c e ! a I! * 'or use wiih Hollow box sub-purlin . . .5 Spec-C:c'ic-: c~ d c ei'c^ c'dc for use with r cit uc-purlin. .6 Cor.j**v.c*'Cn defoils fer use wjfh rcil subpcr!in........................7 Spec'^cctfOnj c*d design dote for use with stendard structure! members........................................ Cor.itn^c*io.*\ cfci'j for use with stendard sfrurturclrrembers.......................................................... .......9 T-o.c- construction de toils................................................................ 10 %c-.r\::c! e'ctc........................................................................................... 11 Phefojrcphj............................................................................ beck cover Koylo Roof Tiles have a rare combination of s.rer.g.n and hunt we:g.nt. Tiles are easy to handle, easy to carry. Moving loads of tiles across Kayio Roof Decks in wheelbarrows or dollies is common practice. ctsul ce-Steerseg SETS A NEW STANDARD FOR LIGHTWEIGHT NON-COMBUSTIBLE ROOF CONSTRUCTION Xavlo Insulating Hoof Tile laid on light steel members now makes available for the first time a roof deck in which fire pro tection. structural strength and insulation are all provided in a single lightweight all-mineral unit. LIGHTWEIGHT ' .. STRUCTURAL UK IT Kayio Hoof Tile is not merely a roof insulation. It is a rein forced structural unit designed for a total load of fifty pounds per so.uare foot with an adequate safety factor. Its flexural strength is more than sufficient for typical Toof deck require ments. ' Kayio Hoof Tile decks weigh approximately six pounds per squire foot, including supporting sub-purlins, or around five nour.es to the square foot for the roof tile only. Thus it is new possible to design a deck made with a non ce-.': ustibie tile so that the dead load above the main purlins, m.c.ud.r.g an excellent built-up roofing, is about twelve pounds ter scuare foot of roof area. INSULATES AS IT COVERS This lightweight roof deck combines structural strength and thermal insulation in one material. Since Kayio Insulating R.ocf Tile provides insulation value equal to that of ar, inch ar.d cr.ehalf of standard insulating board, no additional insulation is needed for usual installations. A speciai operation of upswing Insulation over the structural deck is thus eliminated. Kfc -4SB- ' JW -- Ceovr<^kf, f/e i ,z'\ Cc*psp? *" L',$A. 1 T\ ' V i< JJ FIREPROOF Kaylo Roof Tiie provides a new standard of f.re protection for lightweight construction. The tile themselves will withstand building f.re temperatures as defined by the standard A. S. T. M. fire curve, for more than one hour without failing in load carrying capacity and without permitting a temperature rise on the cold side great enough to constitute failure. Fire originating above a Kaylo roof deck is prevented from producing dangerous temperatures within the building for a period of at least one hour. Because of economy of steel in the supporting structure made possible by a Kaylo roof deck; because of its non-com bustibility; because of its insulation value; because of its liveload-carrying capacity in relation to the dead load of the deck; and because it can be erected rapidly; this new roof construction recommends itself to every architect and engineer who has a major roof construction problem today. FIELD TESTED Kaylo Insulating Hoof Tile has been introduced to the public after several years of experimental development and pilot"pTant manufacture by the Owens-Illinois Glass Company.' In this development an area of several hundred thousand square feet has been incorporated in the construction of Owens-Illinois and American Structural Products buildings, and others, including plants, laboratories, offices and warehouses. Much of it has been in service for several years. ' GENERAL DESCRIPTION Kaylo Insulating P.oof Tile is made in one size only, nominally gj; xISx36 inches. It is white, or whitish in appearance and --.ace entirely of a non-combustible mineral base which is pre_ ;m;nately a calcium silicate, or combination of calcium silicates, ..v.o which mineral fibers have been incorporated for reinforcing at the time of manufacture. This fiber-reinforced mass is ad ditionally strengthened by a welded wire mesh placed in the tile at the time it is formed. The unique cellular structure of Kaylo Insulating Roof Tiie makes possible its remarkable combination of desirable char acteristics. Kaylo Insulating Roof Tile has ceils so small they are measured in fractions of a micron, and so tremendous in number that more than S09c of the tile is composed of air cells which together have a total wall area of more than one hundred acres per cubic foot of tile! Tile units have a smooth under-surface with a light reflection factor of approximately 80 per cent. SAYES ERECTION COSTS Kaylo insulating roof decks are easier to install than conven tional decks--yet they require no revolutionary new methods. Workmen like Kaylo Roof Tile. When American Structural Products sub-purlins are used, a Kaylo Roof Tile deck is applied in only three steps--laving tile into place, grouting end joints and covering the deck with roofing materials. Kaylo P.oof Tile can also be used with other types of framing. ' No added application of roof insulation is necessary' except where special conditions require an unusually high degree of insulation. In such cases light density Kaylo insulation in block form can be mopped in over the Kaylo insulating deck. A two- inch thickness, for example, mopped in over a standard Kayio insulating deck will provide a U value, or over-all transmission, of approximately 0.10 Btu per hour per square foot per degree difference between inside and outside temperatures. Kaylo Insulating Roof Tile can be fitted to odd-sized spaces at the job-site without special tools. Any saw which will cut the wires, such as a light power saw, is suitable. Kaylo Roof Tile can be readily chipped or gouged to fit irregular surfaces. Because of its light weight and convenient size, Kaylo Roof Tile is easy to car;y to the place where it is to be laid. I: has been designed as a simple, one-man tiie ar.d weighs only ap proximately 23 pounds per tile (having an area of four and ore-naif square feet). I SPECIFICATIONS, DESIGN DATA A M D 'V I i iMi jj_ I'l o l\ZTZ: The general conditions of the contract are hereby made, by refererce. 2 part of this specification. SCOPE This work consists of furnishing all labor and materials neces sary fcr the installation of Kaylo Roof Tile, including steel sub-purlins, grout and curbs as shown on the drawings, or as specif,ed herein, or both. MATERIALS 1. Sub-purlins. Steel sub-purlins shall be American Structural Products hollow box sub-purlins No. 102. Before leaving the shop, all steel work shall be thoroughly cleaned of ali loose rust, mill scale and foreign matter and given one coat of approved metal protection applied thoroughly and ever.lv. 2. Kcylo Roof Tile. Roof tile shall be precast and reinforced Kaylc Roof Tile. 2^ inches thick by IS inches wide by 36 inches long as made by American Structural Products Company. 3. Anchors. Anchors are not recurred with American Struc tural Products sub-purlin No. 102. 4. Grout. Grout for end joints of tile shall be composed of the fcliowrr.g materials, measured by volume: PROPORTIONS Rctio Botch Volume curing plaster (quick-setting)________ 1.0 1 cu. ft. xoar.ced vermiculite (vermiculite plastering aggregate).... 0.6 0.6 cu. ft. '.Voter (approximate)..................................... 1.0 7K gallons Consistency of grout shall be such that it can be poured, but r.ct so thin that the vermiculite will float. Add water to provide urcper consistency. Stir thoroughly to remove all lumps. Dry materials may be mixed in large quantities as desired, but water should be added only to small batches which C2n be used immediately. ' 5. Curbs. Kaylo Insulating Roof Tile 2Vt inches thick by 18 inches -wide by 36 inches long shall be used for curbs wherever shown on plaits. Tiles shall be cut on job to height required. INSTALLATION 1. Sub-purlins. To receive Kaylo Roof Tile, American Struc tural Products hollow box sub-purlins No. 102 shall be accurate! spaced 3'-l' on centers. Sub-purlins shall be welded to each support with one file weld, ti inch long placed on alternate sides of sub-puriinr TVnere joints of sub-puriins do not occur over supports, the: ends shall be welded together. Where ends of sub-purlir.s bea on masonry, they shall be securely anchored to the masonry a shown cr, the drawings or with one bolt and 2 x 2 x Vi-inch platwasher at each sub-purlin. 2. Kaylo Roof Tile. Kaylo Roof Tile shall be spaced evenly o: sub-purlins to provide a minimum end bearing of l,: inch, wit: that side up which is marked "top." Tile shall be butted tight!- together at sides. Cut tile to ft at ridges, valleys, parapets curbs, walls, around vents, pipes, etc. and grout in place. Where necessary to cut standard pieces for feting, any hanc or power saw which will cut the wire mesh is suitable. 3. Grout. Joints at ends of tile-over -sub-purlins',"Ahd at`"ridges and nips, snail be filled with grout mixed as specified. Where sub-pu.-iin No. 102 is used the stem of the sub-purlin shall be completely surrounded with grout to provide a key anchorace against uplift pressure. Grout shall be poured from an open-spout can into joints until the grout protrudes slightly above the surface cf the tile. When grout has reached its initial set (few minutes) scrape joints fiush with the tile surface. Sweep all loose and excess grout from the roof, leaving the roof deck free from all foreign matter. . 4. Saddles. Where concrete (either lightweight or gravel ag gregate) saddles or cants are used over Kaylo Roof Deck, prime surface of tiles which receive saddles, or cants, with asphalt primer (Federal specifications, SS-S-701). Mop primer over top surface of tile using not less than 7.5 pounds (one gallon) per one hundred square feet of roof. r_JL C -1.765 DESIGN DATA FOR HOLLOW BOX SUB-PURLIN NO. 102 Six* 3 1/d" * 2 13/32" 1 4 go. Metol W eight Lb./L.F. 3.00 Lb.'S.F. of Roof 1.00 Spacing 3-1" On Centers U'X. In. 4 .955 lyy In. 4 .5B4 Sx-i In. 3 .541 AV.OWA.EVE SPANS FOR VARIOUS LOAD CONDITIONS Totcl Loed Spc n* Defie ction 'Per Sq.h.J f 20,000 f = 18,000 f =20.000 f = 18,000 E:.-;" S*c!es S = = :r: ' 32 lb. Ce*'*ci 5*c*es 42 It. * - : r ts cun' e .r. L s =. Sieves 49 lb. ^c-'-est , ;':'ts 57 lb. -- 9'-e" 9-3'' .360 6'-5" e'-o" .271 710" 7'-$" .227 7' 3" 6-10'' .203 .302 .222 .191 .160 Assumed dead load, per sq. ft. of roof: Kcylo tile end sub*purlin*.............. 6.0 lb. Built-up roofing {tor c~d grovel)....................... 6.0 lb. Tote! dead loed.......................12.0 tb. Assumed mow leod, oft boriiontol surfoce Pr sq. ft. of roof-. Southern Sietes (;; Iced) ...... 2C lb. per iq. f. p*rCentre! Snctei...............20 lb. tQ- ^T- Rocky V.Own'cin* end N. Srctei..............27 lb. per iq ft. Northwest S'otet. . . .45 lo. pr f * - M Wl To * Spct-t shown ere for ftot roofs. v`here tub*puriini run porot-r< to the ridge of patched roefi cr*d unsymme'ftco' be^d-nj occurs, ree-ce tpon- ' E L S....................... 7L 5 n SPECIFICATIONS, DESIGH DATA AH 0 I ! Ii _ iUi L XGTa.: The genera! conditions of the contract are hereby made, by reference, a part of this specification. SCOPE This work consists of furnishing all labor and materials neces sary for the installation of Kaylo Roof Tile, including steel sub-purlins, grout and curbs as shown on the drawings, or as specihed herein, or both. MATERIALS 1. Sub-purlins. Steel sub-purlins shall be American Structural Products structural steel rail sections Xo. 101. Before leaving the shop, all steel work shall be thoroughly cleaned of all loose rust, mill scale and foreign matter and given cne coat of approved metal protection applied thoroughly and evenly. 2. Kaylo Roof Tile. Roof tile shall be precast and reinforced Kaylo Roof Tile. inches thick by 18 inches wide by 36 inches .mg as mace by American Structural Products Company. 3. Anchors. Anchors are not required with American Struc tural Products sub-puriins Xo. 101. 4. Grout. Grout for end joints of tile shall be composed of the tallowing materials, measured by volume: PROPORTIONS Ratio Belch Volume Gauging plaster (quick-setting)....... ....... 1.0 1 cu. ft. Expanded vermiculite (verrr.icul.'te plastering aggregate).... 0.6 0.6 cu. ft. ""ater (approximate)...................... .............. 1.0 71c gallons Consistency of grout shall be such that it can be poured, but r.ot so thin that the vermiculite Trill float. Add water to proride proper consistency. Stir thoroughly to remove all lumps. Dry materials may be mixed in large quantities as desired, but water should be added only to small batches which can be used immediately.5 5. Curbs. Kaylo Insulating Roof Tile 2% inches thick by 18 inches wide by 36 inches long shall be used for curbs wherever shewn on plans. Tiles shall be cut on job to height required. INSTALLATION 1. Sub-purlins. To receive Kavlo Roof Tile, American Struc tural Products rail sub-purlins Xo. 101 shall be accurately spaced 3'-lli" on centers. Sub-purlins shall be welded to each support with one f.iiet weld, hi inch long placed on alternate sides of sub-purlins. Where joints of sub-purlins do not occur over supports, their ends shall be welded together. Where ends of sub-purlins bear on masonry, they shall be securely anchored to the masonry as shown on the drawings or with one bolt at each sub-purlin. . 2. Kaylo Roof Tile. Kaylo Roof Tile shall be spaced evenly on sub-purlir.s to proride a minimum end bearing of hi inch, with that side up which is marked "top." Tile shall be butted tightly together at sides. Cut tile to fit at ridges, valleys, paranets, curbs, walls, around vents, pipes, etc. and grout in place. Where necessary tc cut standard pieces for fitting, any hand or power saw which will cut the wire mesh is suitable. 3. Grout. Joints at ends of tile over sub-puriins, and at ridges and hips, shall be filled with grout mixed as specified. Where sub-puriin Xo. 101 is used the stem of the sub-puriir. shall be completely surrounded with grout to proride a key anchorage against uplift pressure. Grout shall be poured from an open-spout can into joints until the grout protrudes slightly above the surface of the tile. When grout has reached its initial set (few minutes) scrape joints flush with the tile surface. Sw-eep all loose ar.d excess grout from the roof, leaving the roof deck free from all foreign matter. ., 4. Saddles. Where concrete (either lightweight or gravel ag gregate) saddles or cants are used over Kaylo Roof Deck, prime surface of tiles which receive saddles, or cants, with asphalt primer (Federal specifications, SS-S-701). Mop primer over top surface of tile using not less than 7.5 pounds (one gallon) per one hundred square feet of roof. f; DESIGN DATA* FOR RA11 SUB-PURLIN NO. 101 Size 2-1/4" * 2-3/8" Weight lb./LF. 3.3 Lb./S.F. of Roof 1.1 Spctvnf ' 3-1-1/4" On Centers Ik>k In. 4 .694 ly-y In. 4 .182 Sx* In. 3 .522 AllOWABlE SPANS FOR VARIOUS IOAD CONDITIONS Se.inern S>e<ei L =c:if,c Slope Tofel toed (PerSq.h.l 32 lo. Spe n * Defle c,lon i *20,000 f *18,000 f *20,000 f=i e.ooo - - - 9-6" 9-0" .4 54 -370 Ie-''c! 5?eit 42 lb. 6-4" 7-10" 35e 49 lb. 7'-9" 7-4" .310 .246 *>: -1 s* S-r'es 57 lb. 7'-2" 6'- 9 " .256 .208 of roof-. ' Kaylo tile ond iub-pvrlint. .. Bu'll-up roofing (ter one* gre*el)........... ' <icc- 'cci........... Atiumed mow food' on hprirenlpf iurfoce per tquere foot of roof: Southern Steiet end PoC'f'C Slope Miv* food). .20 lb. per iq ft. Centro I Stclei..............30 lb. per q. fl. Rocky Mcuntcim end NE.S'etei............... 37 is. perse fl. Ncrthweit Sic'ei. . . . 45 lb. per iq If. MsWl To" 'ipenj jncn ore for fief roof*. Where lub-pu'^ni rwn perclieT f the ricse d pitches rod* end yymr">eiricc! benc>*$ reduce :pc*. } l PAEAFET SECTION to *<oi V* -* S? ' ,^U . . C~-- *rjk~ *; t -'; t .-. ;.v:; V-'- \'v. .'a ' ;" '. uyn j 1 -?i -r-=.*' -'^V AO/j--'. Sccle 5/5"=l'.0" Except cj noted 7 SPECIFICATIONS r DESIGN DATA A K"0[ XOTE: The general conditions of the contract are hereby made, by reference, a part of this specification. SCOPE This work consists of famishing all labor and materials necessary for the installation of Kayio Roof Tile, including (bent studs) (staple clips) (nails), grout and curbs as shown cr. the drawings, or as specified herein, or both. _ 1. Keylo Roof Tile. MATERIALS Roof tile shall be precast and reinforced Kayio Roof Tile, 2's inches thick by IS inches wide by 36 inches long as made by American Structural Products Company. 2. Anchorage Materials. (Select one which applies to details used.) ab. Sent Studs (for trussed purlins or standard structural shapes) Ber.t stucs shall be lh' x l1:" X. T. Bent 0. L. E. Studs. (Xct threaded; outside loaded end.) Each stud shall have a suitable ferrule. Studs and ferrules shall be as manufactured by Xeisor. Stud Weiding Corp., or approved equal. c. Xaiis (for wood framing) Xails for fastening Kayio Roof Tiie to wood framing members shall be 20d common x 4' long. d. Xails (for Strar.-Steel) Xails tor fastening Kayio Roof Tile to Stran-Steel shall be 12d common x 3" long. cd. Staples (for Stran-Steel) Staples shall be =12 ga. (.105) mill galv. steel wire at least 3" long and 1' wide. 3. Grout. Grout for end joints of tile shall be composed of the follow ing materials, measured by volume: PROPORTIONS Bctdi Gauging plaster (cuick-setting) ---------------------------------- Ratio i.o Volume 1 cu. ft. Expanded vermiculite (verm.iculite piastering aggregate).... 0.6 0.6 cu. ft. Water (approximate) --..............-............ 1.0 7H gal. Consistency of grout shall be such that it can be poured, but not so thin that the vermiculite will float. Add water to provide proper consistency. Stir thoroughly to remove all lumps. Dry materials may be mixed in large quantities as desired, but water should be added only to small batches which can be used im mediately. XOTE: Reduce.water content when using Stran-Steel. (Mini mum quantity, 4 gallons per batch.) A. Curbs. Kavl? Insulating Roof Tile 2s; inches thick by IS inches :de hv 2.6 inches long shall be used for curbs wherever she.TM :r. u'.ar.s. Tiles shell be cut on job to height required. INSTALLATION 1. Purlins (or joists). Purlins or joists shall be furnished and installed by others. They shall be accurately spaced 3'-0h' on centers to receive Kayio Roof Tile. * 2. Kayio Roof Tile. Kayio Roof Tile shall be spaced on sub-purlins or joists to provide an end bearing of at least K inch, with that side up which is marked "top." Tile shall be butted tightly together at sides. Cut tile to fit at ridges, valleys, parapets, curbs, walls, around vents, pipes, etc., and grout in place. Where necessary to cut standard pieces, any hand or power saw which will cut the wire mesh is suitable. 3. Anchorage. (Select one which applies to details used.) ab. Bent Studs (for trussed purlins or standard structural shapes) Bert Studs shall be securely weided to the top chord of purlins by the Xelson Gun Stud Welder cr other approved method. They shall be spaced 9" o. c. ar.d lined up accurateiy on each purlin. c. Xails (for wood framing) Xails shall be spaced 9" o. c. Two nails at each end of tile shall be driven vertically through roof tiie and sunk so that heads are flush with top of tile. d. Xails (for Stran-Steel) Xa;:s shall be spaced Z" o. c. and driven into Stran-Steel a minimum-of The heads of the rails shall project above the Stran-Steel a minimum of llj". dd. Staples (for Stran-Steel) Staples shall be spaced 3" on centers and driven into Stran-Steel a minimum of HA". Staples shall project above Stran-Steel a minimum of lVs". 4. Grout. Joints at ends of tile over purlins or joists, and at ridges and hips, shall be filled with grout mixed as specified. The grout shall completely fill the joint over the purlin; s: that the (bent studs) (nails) (staples) are entirely encased in grout to provide anchorage against uplift pressure. Grout shall be poured from an open-spout can into joints until the grout protrudes slightly above the surface of the tile. When grout has reached its initial set (few minutes) scrape joints flush with the tile surface. Sweep all loose and excess grout front the roof, leaving the roof deck free from all foreign matter. 5. Saddles. Where concrete (either lightweight or gravel aggregate) saddles or cants are used over Kayio Roof Deck, prime surface of tiles w-jch receive saddles, or cants, with asphalt prime: (Federal specifications, SS-S-TTi 1). Mop primer over tep sur face of tile using not less than 7.5 pounds (one gallon! per hundred square feet of roof. p ( SECTIGK-V .=:e -A"=V-0" . cept cs nofed j fP.ak:ks puk MONITOR CURB DETAILS (us^; sjs-puruk m.-io SECT13K--"B" CZT * FUSHINC /UCKT vttCHT ffii RDOF mi FL71J:*SJfl!\V^nsu-f*:tpj*ei!*i 9c. ,*K3 k/1S "I,__________Jik -i*i OnSi'HS IS EZJr n^c.-ia s-::-3 \==i I 11 p?:v,s- Kiis-it | / /j ' KAJH MUCINS rM |T-P `-f-Vi z \ --1____ _____ c mxvths rui t^acNS e~un r.i mucks rrr T-- -- r -- -* OveLS/ir---v- C J l^\Z (SPn1cSm1nP;ETs;:DfEcTuiliLni ViLLET DETilL DETAILS FOR STEEP PITCHED ROOFS --F.AFTE3 FRAMING 10 r - r* L _ L tc L. L r i.-- KAYLO ROOF TILE n c* - Yrr' .. NSULATINB VALUE Thermal conductivity "K" (Btu., sq. ft./nr./'F./in.)..............0.G2 Overall heat trar.sf. coef. "U" (3tu./sq. ft/hr./'F./thickness) Hoof tile only________ --.0.20 Roof tile -i- built-up roofing_______________________ _____0.19 Roof tile -r l1,!'' insulation*-!- built-up roofing.............. 0.11 Roof tile -i- 2" 'Insulation -rbuilt-up roofing...................... 0.10 *ll-!b. der.s:tv Kaylo Insulation protect the interior from excessive temperature rise. For a fire originating within the building the limit of endurance is the limit of the supporting steel or the limit of the construction immediately beiow the roof deck. WEIGHT Approximate weight per square foot (lb.). Approximate density (lb. per cu. ft)______ Approximate weight per tile ' (lb.)____ ..... 5.0 ..... 20.5 _____ 213.0 STRENGTH flexural strength This table snows the factor of safety and direction of Koylo lr.su! Roof Tiie for several uniformly -distributed Icadsr CLEAR SPAN = 34 INCHES-DEFLECTION FOR 1/360 OF SPAN*.09S INCHES TOTAL UN.FORM LOAD (LE.'SO FT.) cO 45 50 55 . 60 FACTOR OF SAFETY ULTIMATE 1 1.1 9.9 3.9 S.O 7.4 DEFLECTION (INCHES) .023 .026 .029 .032 .035 modulus OF rupture. The average modulus of rupture for ILaylo Roof Tile is 175 lb. per sq. in. modulus OF elasticity. The average modulus of elasticity for ILaylo Roof Tile is 160,000 lb. per sq. in. compressive strength. The average compressive strength for ILayio Roof Tile is 500 lb. per sq. in. DIMENSIONAL STABILITY dimensional change due TO moisture. The linear expansion of Kaylo Roof Tiie after repeated cycles of soaking and drying is approximately .04 of 19c. This equals an increase in length for a standard tile of only fourteen-thousandths of an inch. STRENGTH WHEN wet. The flexural Strength of Kaylo Roof Tile when soaking wet (after soaking for 10 hours) is approxi mately 859c of its normal strength. KAIL-HOLDING POWER RESISTANCE TO DIRECT NAIL WITHDRAWAL (SMOOTH NAILS) Sit# of Kail id ?d 8<f 9d 104 12d 1 6d 20d 30d A0 i Dions#Urinlfvcfiet .113 .113 .131 .131 ME .US .162 .192 .207 .225 Retistanc# of Kayio Roof T71# 20 20 23 23 26 26 2S 32 36 40 [Total Pull in Ibi. p#f Inch Pene tration), FIRE RESISTANCE Ilavio Roof Tile is non-combustible. It will resist a typical _-"tcirt" fire, as defined in the standard A. S. T. M. time .. ---ernture curve, for more than one hour. Thus, a fire 2' r.- on the top sice car. burn off the applied covering . -- resistance of the tile will enable the-tile to carry ... -ecu;rcC load for more than or.e hour and at the same time LIGHT REFLECTIVITY Light reflectivity of Kayio Roof Tile is approximately S09c. 11 & 1I irweirnceaira S'^rtac'&urcsB ProduCkS Co., TToIedlo, O^bbo -- r~ 1 1 1 .1 .i .r M ' ft-1:0 Iued March !5,1948` KAYLO ROOF TILE DETAILS WITH STRAN-STEEL SUB-PURLINS ^7*"**-Sni' - * V i Taaill --cwm * 11 ' 1$ CA. CAIV. SUU CllP :** < < il Ij i--Si _ur _iiril -- wao soor im 1J v TOP VIEW \ ` ' * . , * . .J CTOJT--^ / HQLC.iT ORfVEW-' IKTO PUKSHa . * * V .' uno *oof mi -J 2 5 1": l*"i 36" mu* pta susPunLw <1 1 __L ! cl y-ro" SECTION ISOMETRIC VIEW OF ROOF STRUCTURE DETAILS OP ANCHORS TO STRAN-STEEL SUB-PURLINS RATIO *oof mi aa>or am WWD *ujl(T GROUT AKOIOT CLIPS ` K>00 KL'10 SWrI0 TO ' jnuAsno. EAVE SECTION WALL KAJHK6 RIDGE SECTION EAVE SECTION ttOnW FRAME :su : PARAPET SECTION SOS WK.IN HK.UI to fcW. VALLEY SECTION TYPICAL CONSTRUCTION DETAILS PARAPET SECTION si's rjtj* p-FKiKoauF to Ka SEE KVEFSE SSI FC2 SnOlTiSAOSKS AAO titA ----- n-i.-o Issued Msreh IS, 1948 PAGE 2 . KAYLO INSULATING ROOF TILE SPECIFICATIONS NOTE: The genersl conditions of the contract ere hereby cede, by reference, & put of this specification. SCOPE This work consists of furnishing ail labor and materials necessary for the installation of Kaylo Roof Tile, including rieei sub-purlins, grout and curbs as shows oa the drawings, or as specified herein, or both. MATERIALS 3- Sub-purlins. Steel rub-purlins shall be Stran-Sleel joists of sires shows on the drawings. Before leasing the shop, all steel work shall be thoroughly cleaned of all looee rust, mill scale and foreign matter and given one coat of approved metal protection applied thor oughly and evenly, 2. Kaylo Roof Tile. Roof tile shall be precast and rein forced Kaylo Roof Tile, 2$i inches thick by 16 inches wide by 35 inches long as made by American Structural Products Company. . ' 3. Anchors. Anchors to Stran-Steel joists shall be 16-gauge galvanised steel drive clips No. 201, as furnished by American Structural Products Company. 4. Grout. Grout for end joints of tile shall be composed of the following materials, measured by volume: Proportions - Ratio Batch Volume Gauging plaster (quick-setting)_________ 1.0 1 cu. ft Expanded vermiculite (vermiculite plastering aggregate)____ 0.6 0.6 cu. ft Water 0.55 4 gallons Consistency of grout shall be such that it can be poured, but not so thin that the vermiculii* will float Add water to provide proper consistency. Stir thoroughly to remove all lumps. Dry materials may be mined in large quantities as desired, but water should be added only to small batches which can be used immediately. 5. Curbs. Kaylo Insulating Roof Tile inches thick by IS inches wide by 36 inches long shall be used .or curb* wherever shown on plans. Tiles shall be cut on job to height required. INSTALLATION 1. Sub-purlins. To receive Kaylo Roof Tile, Ehan-Steal rub-purlins shall be accurately spaced 3'-0-{" on centers. Sub-purlins shall be welded to each ruppert with one fillet weld, M inch long placed on alternate aider of rubpurlins. Where joints of rub-purlins do not occur over sup ports, their ends shall be welded tor ether. Where ends of sub-pUrlins bear on masonry, they shah be securely anchored, to the masonry as shown on the drawings or wuh cne-hali inch diameter hook-boll at each sub-purlin built into tbe masonry. 2. Kaylo Roof Tile. Kaylo Roof Tile shall be spaced evenly on sub-purlins to provide a minimum end bearing of H-meh. with that ride up which is marked "lop". Tile -.n be kntted tightly together at rides. Cut tile to fit at ndgei, valleys, parapets, curbs, walls, around vents, p:psi, etc., and grout in place. '- `Hies shall be kept dry while being Laid and before end during application of roofing. Tiles may be cut with a hand saw or powar saw where neceaaary to cut standard pieces. 3. Anchors. Ends of tile shall be secured to sub-purlins with two anchors, No. 201, per eighteen-inch tile. Anchors shall be epaeed three inches from each edge of tile. Drive anchors down tightly so that flanges are prectically Cush with top of Kaylo Roof Tile. 4. Grout. Joints at end of tile over sub-purlins, and at ridges and hips, shall be filled with grout mixed as specified. Grout shall be poured from a spouted can into joints until the grout protrudes slightly above tbe surface of the tile. When grout has reached its initial set (few minutes) scrape joints flush with the tile eurface. Sweep all looee and excess grout from the roof, leaving the roof deck free from all foreign matter. 5. Saddles. Where concrete (either lightweight or gravel aggregate) saddles or cants are used over Kaylo Roof Deck, pnme surface of tiles which receive saddles, or cants, with asphalt primer (federal specifications, SS-S-701). Mop primer over top surface of tile using not less than 7.5 pounds (ona gallon) pc: one hundred square feet of roof. DESIGN DATA FOR KAYLO ROOF DECKS KAYLO ROOF TILE Su.......................................................................2K"r ITir W**ckt at Ik. til*), Appre*.........................<K Ik. per aq. ft. Appte*.......... .................... ................ 30 Ik. prt cm. tL Haulers*?................. 3"*3"*10 ?*- ?*lr. w*ld*d win Beak SpwctSe MhI........................................ 0-22 Bte par Ik. par *T. A*. Kadolma <d Hapten..............................ISO Ik. p> aq. lack Ar. Creakia? Straaplk............................... 500 Ik. par aq. lack At. Mad. o! HaAoJy.......................... 160,000 Ik. par aq. lack Licit KaGacsa*....................................................... Appro*. S% OVER-ALL COEFFICIENT OF HEAT TRANSMISSION "U" BTU/SQ.FT./H OUR/*F Eara Tila....................................................................................0.30 -- EuUi-up ... . ............................................... 0.1> 1" Ijui2*&oer * EoUt-up Boeftog ........................0.13 Tu* * iM" iMkalibo* * Rcohog......................0.11 -- 2" l&Jwbo& *r Buili-ttp hoohAf..........................0.10 '11 lb. dainty JwayJ Itrciaboc, STRAN-STEEL SUB-PURLIN Sm ( Wi9bl Spaaag 2" Raaga. ' Lb, /LI.! Lb./tJ. 3'-0>, " 3X"da*p, 2-244 JS 16 *. 1 | Ob Coalat la-s la. 4 1.163 Ir-r I*. 4 .090 S<<c la. 3 .641 ALLOWABLE SPANS FOR VARIOUS LOAD CONDITIONS Soctbar* Stalaa aad PaabcSIopa Camtral Stalaa Bock. Haul, a4 N. E. Suioa Meftbwo* SUtao Total Load (Fat S*. fL) Spaa* 32 Ib. 10`4" Ob. w 491k. I'4" !7 Ik. 7'-l0" DofUebat SI" w SI" .17" Uaa ooaa-br.Sa? accord**? to Str...Steal apaca. Spaa. tkewa ara lot Cat rooia. Wkara uk.purLat rue paralial lo tka ndc* *4 patekab tool* aad uarr&aaaicaj baaaiae eceun, raduea fpaa. Ajiusk daad lead; 12 lb. par *3. ft. of roof nadt up us follow*; laylo Til# aod Stb>p*lia*.. .6.0 lb. BocLag (ur aod gr*al}.................... 6.0 lb. Total daad load................. 13.01b. Aua<( ioaw load o& kenutid ivliea: Soutbarc Stalaa fcaaioadj 20 lb. par aq. ft. CafltraJ Suiaa ...............30 ib. par *5. ft. Keek? Mouauass a*d N. I. u .< .........37 lb. par aq. ft. Korvbwaat Suifi............ 45 lb. pa; ag. ft. kaH |a ri.OOO lb, pat K utei. Bulletin . R-l:4 Iuued July 1,1946 KAYLO ROOF TILE -- DETAILS WITH TRUSSED PURLINS rrm Bulletin B-l:4 Issued July 1.1948 PAGE 2 KAYLO INSULATING ROOF TILE SPECIFICATIONS NOTE: Tli* general conditions of the contract are hereby cade, by reference, a part of tbit specification. SCOPE This work consists of fum: thing all labor and caterial* necessary for the instaPatron of Stylo Roof Tile, inducing bent studs, grout and curbs as thowa on the drawing!, or a* specified herein, or both. ' MATERIALS . Z. Bent Studs Bent Studs thall be lfc" * 1M" N.T. Bent O.LE. Studs. (Not threaded; outside loaded end). Bach stud shall have a suitable ferrule. Studs and ferralea thall be at nanufadar ed by Kelson Stud Welding Corp., or approved equal. 2. Kaylo Roof Tile Roof tile thall be precast and reinforced Kaylo Roof Tile, 25*J inches thick by 18 inches wide by 36 inches long as made by American Structural Products Company. 3. Grout Grout for end joints of tile shall be composed of the follow ing materials, measured by volume: Proportions Ratio Gauging plaster (quick-wrung).................................. 1.0 Batch Volume 1 cu. ft Expanded Ttrmiculite (vermicuhte plastering aggregate). 0.6 0.6 cu. ft. Water (approximate)............................. 1.0 7MsL Consistency of grout shall be such that it can be poured, but net to min that the vermiculite will float Add watar to provide proper consistency. Stir thoroughly to remove all lumps. Dry materials may he mixed in large quantities as desired, but water should he added only to small batches which can he used immediately. i. Curbs Kaylo Insulating Roof Tile 25/i inches thick by 18 inches wide by 36 inches long shall be used for curbs wherever shown on plans.' Tiles shall be cut on job to height required. . INSTALLATION 1. Trussed Purlins Trussed Purlins shall be furnished and installed by others. They shall be accurately spaced 3'-0"$" on centers to receive Kaylo Roof Tile. Trussed purlins shall be adequately braced to prevent lateral deflection. Tae ends of trussed purlins shall have a bearing of at least 4 inches on masonry or concrete and inches on steel supports and each purlin thall be securely anchored to its support . 2. Bent Studs Bent Studs shall be securely welded to the top chord of purlins by the Nelson Gun Stud Welder or other approved method. They shall be spaced 9" o.c. and lined up ac curately on each purlin. 3. Kaylo Roof Tile Kaylo Roof Tile shall be spaced on purlins to provide an ene bearing of at least inch, with that side np which is marked "top". Tile shall be butted tightly together at sidea Cut tile to fit at ridges, valleys, parapets, curbs, walls, around vents, pipes, etc., and groat is place. Where necessary to cut standard pieces, any hand or power saw which will cut the wire mesh is suitable. 4. Grout loints at ends of tile over trussed purlins, and at ridges and hips, shall be filled with grout mixed as specified. The grout shall completely fill the joint over the purlins so that the bent studs are entirely encased in giout to provide anchorage ageiast uplift pressure. Grout shall be poured from an open-spout can into joints until the giout protrudes slightly above the surface of the tie. When grout has reached its initial set (few minutes) scrape joints flash with the tile surface. Sweep all loosa and excess groat from the roof, leering the roof deck free from ell foreign matter. . 5. Saddles Where concrete (either lightweight or gravel aggregate) saddles or cants are used over Kaylo Roof Deck, prime surface of tiles which receive saddles, or cants, with asphalt primer (Federal ipemheations, SS-S-701). Mop primer over top surface of tile using not less than 7 5 pounds (one gallon) per hundred square feet of rooL DESIGN DATA FOR KAYLO ROOF TILE PHYSICAL CHARACTERISTICS Size................................. 2H" * 18" * 36" Weight, (23 lb. tile) Approx.. .. 5 lb. per sq. ft. Density, approx........... 20}<g lb. per cu. ft Reinforcing 3"x3"xl0 ga.galv. welded wire mesh Specific beet................. 0.22 Btu per lb. per *F. Av. modulus of rupture 175 lb. per sq. inch Av. crushing strength .500 lb. per sq. inch Av. mod. of elasticity. . .160,000 lb. per sq. inch Light rejection............ approx. 80% OVER-ALL COEF. OF HEAT TRANS. Bare tile........................................................ 0.20 Tile + built-up roofing.............................. 0.19 Tile + iyi" insulation* -f- built-up roofing* 0.11 Tile -r 2" insulation -j- built-up roofing.. 0.10 *11 lb. density Kaylo Insulation. U" BTU/SQ. FT./HOUR/'F. FOR TRUSS SPANS, SEE TRUSS MFR'S SPECIFICATIONS Issued July 1,1948 PAGE 1 S^jTTTjjrrjs^jTgJS sec uvcrsc sioe m intmiium a*o data Bulletin R-l:5 Issued July 1, 1948 PAGE 2 KAYLO INSULATING ROOF TILE SPECIFICATIONS NOTE: Hie general conditions oi tie contract axe Hereby made, by reference, a part oi this specification. SCOPE Tcjj work consists oi furnishing ail labor and materials necessary for tie installation oi Kaylo Roof Tile, inducing nails, grout and curbs as shown on the drawings, or as specified herein, or both. MATERIALS ' 3. Kaylo Roof Tile Root tile shall be precast and reinforced Kaylo Roof Tile, 2\i inches thick by 18 inches wide by 38 inches long as made by American Structural Products Company. ' - 2. Grout Grout ior end joints oi tile shall be composed oi the follow ing materials, measured by volume: Proportions Ratio Gauging plaster (q-mck-setung)................................ 1.0 Batch Voluma 1 cu. ft. Expanded vermiculile (vermicuiite plastering aggregate) 0.6 0.6 cu. ft. Water (approximate)............................. 1.0 Consistency oi grout shall be euch that it can be poured, hut not so thin that the vermicuiite will Coat. Add water to prov.de proper consistency. Stir thoroughly to remove all lumps. Dry materials may be mixed in large quantities as desired, but water should be added only to small batches which can be used immediately. 3. Curbs Kaylo Insulating Rooi Tile 2% inches thick by 18 inches wide by 35 inches long shall be used for curbs wherever shown on plans. Tiles shall be cut on job to height required. INSTALLATION 3. Wood Purlins or Joists Wood purlins shall be furnished and installed by others. They shall be accurately spaced 3'-0VJ" on centers to receive Kaylo Roof Tile. Wood purlins shall be adequately braced to prevent lateral deflection. ' 2. Kaylo Roof Tile '` Keyio Roof Tile shall be spaced on purlins to preride an nd bearing of at least VS inch, with that tide up which is marked "top". Tile shall be butted tightly together at sides. Cut tile to Ut at ridges, valleys, parapets, curbs, walls, around vents, pipes, etc., and grout in place. Where necessary to cut standard pieces, any hand or power taw which will cut the wire mesh is suitable. Secure each tile to wood joists with two nails at each bearing. Mails shall be 20d s <" long and spaced approxi mately 9" o.c. Drive nail haads flush with suriace of tile. 3. Grout Joists at asds oi tila, at ridges and hips, and where shown on the drawing shall be filled with-gioul mixed as speeded. The grout shall completely Ell the joints. Grout shall be poured from an open-spout can into jcists until tbe grout protrudes slightly above the surface oi the tile. When grout has reached its initial set (iew minutes) scrape joints flush with the tile surface. Sweep all loose and excels grout from the root, leaving the rooi deck free tom all foreign matter. t. Saddles Where concrete (either lightweight or gravel aggregate) saddles or cants are used over Kaylo Roof Deck, prime surface of tiles which receive saddles, or cants, with asphalt primer (Federal speeificaEcns, SS-S-7D1). Mop primer ever top surface of tile using not less then 7.5 pounds (one gallon) par hundred square feet of rooi DESIGN DATA FOR KAYLO ROOF TILE PHYSICAL CHARACTERISTICS Size................................... 2Vf" x 18" x 36" Weight (23 lb. tile) Approx................. Sib. per sq. ft Density, approx............... 20V$ lb. per cu. ft. Reinforcing 3"x3"xl0 ga. galv. welded wire mesh Specific beat....................0.22 Btu per lh. per *F. Av. modulus oi rupture. . 175 lh. per sq. inch Av. crushing strength . 500 lh. per sq. inch Av. mod. cf elasticity.... 160,000 lb. per sq. inch Light reflection................approx. 80& OVER-ALL COEF. OF HEAT TRANS. Bare tile..................................... :................. 0.20 Tile 4 built-up roofing................................ 0.19 Tile 4 1 insulation* 4 built-up roofing 0.11 Tile 4 2" insulation 4 built-up roofing ... 0.10 *11 lb. density Kaylo Insulation. "U" BTU/SQ. FT./HOUR/T. *4 l*tud July 1, 1948 PAGE 1 KAYLO ROOF TILE DETAILS STANDARD STRUCTURAL SHAPES '/2", Va' 1^/T 1/4" GROUT -- r^-^rJST -----T--T*-f E--S-IN- r= owiH$.uu**eit 6i*u ce MlM. BEARING J/g* 1 KAYLO ROOF TILE Z5/t` a 1S'X36 . ' ^ V/ STANDARD STRUCTURAL SHAPE ---------- \A VA \ NELSON BENT STUD SPACED 9* O.C. ANO WELDED TO TOP OF SHAPE HALF SIZE rmin. Z'-oVz'O.C. SECTION THROUGH JOINT SHOWING BEAMS ANO JOISTS RATIO ROOF TILE WOOS WJLER CROUT , FRAME JOISTS l,r LEVEL WITH BEAMS OR SLIGHTLY ABOVE BEAMS ratio root TM-zH'iiri wood KAJUR T'tJ`1" 1 EAVE SECTION KAIL REAAINt RIDGE SECTION EAVE SECTION SKELETON HUME PARAPET SECTION vji rjRjN faaaliel to wall zxi-Tir'- ro* VALLEY SECTION TYPICAL DETAILS PARAPET SECTION SUE MALIK REAnHOQlM TO AU SEE REVERSE SIDE FOR TflCniAllONS AKO OAM 1 Bulletin B-1.-6 Issued July'l, 1548 PAGE 2 KAYLO INSULATING ROOF TILE SPECIFICATIONS NOTE: Tie general conditions of tie contract axe hereby ncde, by refereace, a part of tins specification. SCOPE Tils work consists of furnishing all labor and male rials necessary for tie installation of Kaylo Hoof Tile, including bent rtuds, grout and curbs as shown on tie drawings, or as specified herein, or both. 1. Sent Studs MATERIALS 3en! Studs shall be 1 %" x 1H" N.T. Bent O T. F. Studs. (Sot threaded; outside loaded end). Each etna shall have a suitable ferrule. Studs and ferrules shall be as manufactured by Kelson Stud Welding Corp., or approved equal. 2. Kaylo Roof Tile Boo! tile shall be precast and reinforced Kaylo Roof Tile, 2l-s inches thick by 18 inches wide by 36 inches long as made by American Structural Products Company. 3. Grout Grout for end joints of tile shall be composed of the follow- mg materials, measured by volume: Proportions Batch Ratio Volume Gauging plester (quick-setting)................................ . Expanded vermiculite (vermiculite plastering aggregate) . Water (approximate)............................ . 1.0 0.6 1.0 1 cu. ft. 0.6 cu. ft. 7% gab Consistency of grout shall be such that it can be poured, hut not so thin that the vermieulite will float Add water to provide proper consistency. Stir thoroughly to remove all lumps. Dry materials may be mixed in large quantities as desired, but water should be added only in small batches which can be used immediately. L. Curbs Kaylo Insulating Roof Tile 2% inches thick by 18 inches wide by 36 inches long shall be used lor curbs wherever shown on plans'. Tiles shall be cut on job to height required. ' INSTALLATION L Structural Framework Structural Purlins shall be furnished and installed by others. Tney shall be accurately rpaced 3'-0%'' on cenlen to receive Kaylo Roof Tile. 2. Bent Studs Bent Studs shall be securely welded to the lop chord of purlins by the Kelson Gun Stud Welder or other approved method. Tney shall be spaced 9" o.c. and lined up ac curately on each purlin. 2. Kaylo Roof Tile Kaylo Roof Tile shall be spaced on ourlins to provide an end bearing of at least % inch, with that ride np which it market "top". Tile shall he butted tightly together at rides. Cut tile to fit at ridges, valieyt, parapets, cube, walls, around vents, pipes, etc., and grout in place. Where necessary to cut standard pieces, any hand or power saw which will cut the wire mesh is suitable. <L Grout Joints et ends of tile, st ridges and hips, and where shown on the crewing shall be tilled with grout sized as specified. The grout shall completaly fill the joints so that the bent rtnds are entirely encased in grout to provide anchorage against uplift pressure. Grout shall be poured from an opea-spoul can info joints until the grout protrudes slightly above the surface of the tile. When grout has reached its initial set (few minutes) scrape joints Rush with the tile surface. Sweep all loose and excess grout from the roof, leaving the roof deck free from all foreign matter. S. Saddle* ' Where concrete (either lightweight or gravel aggregate) aaddles or carts are used oyer Kaylo Rooi Deck, prime surface ai tiles which receive sedcies, or cents, with asphalt primer (Federal specifications, SS-S-7Q1). Mop primer over top luxfecc of hie using not lees than 7.S pounds (one gallon) per hundred square feet of roof. DESIGN DATA FOR KAYLO ROOF TILE PHYSICAL CHARACTERISTICS Size.................................... 2%"xl8"x36" Weight (23 lb. tile) Approx..................S lb. per sq. ft. Density, approx... ______20% lb. per cu. ft. Reinforcing 3"x3"zl0 ga. galr. welded wire mesh Specific heat.................... 0.22 Btu per lb. per *F. At. modulus of rupture . . ITS lb. per sq. inch At. crushing strength . . ,S00 lb. per sq. inch Ar. mod. of elasticity. . . .160,000 lb. per sq. inch Light reflection............ approx. 60% OVER-ALL COEF. OF HEAT TRANS. Bare tile.............................. ......................... 0.20 Tile -- built-up roofing................................ 0.19 Tile -f 1%" insulation* -j- built-up roofing 0.11 Tile -f 2" insulation -- built-up roofing ... 0.10 *11 lb. density Kaylo Insulation. "U" BTU/SQ. FT./HOUR/'F. FOR TRUSS SPANS, SEE TRUSS MFR'S SPECIFICATIONS Bul]tia B-h2 Isru.d SfpL 15, 19<8 KAYLO ROOF TILE DETAILS WITH RAIL SUB-PURLIN No. 101 owia$.iuieik Ci.u co * . ^7^ '-- * / , N 'N # " r*- 1-- -- T*. * EAYE SECTION MU. KAAftC bout Z^tfunoeorTU JUWWUI RIDGE SECTION EAYE SECTION VmiONFWME PARAPET SECTION SW-PUBJK PWAUfl. TO PUU. sml J re- YALLET SECTION PARAPET SECTION s- Putin purwscuu* ic mu tic nrviCE sirs rst u>: cm ( Bullstin B-U Issued Sept. 15, 1948 PAGE 2 KAYLO INSULATING ROOF TILE SPECIFICATIONS NOTE: Tie generl conditions of the contract ere hereby made, by reference, t per! of this specification. SCOPE This work consists o! furnishing ail labor and aaterials neces sary for the installation of Kaylo Hoof Tile, including steel sub-purlins, grout and curbs as shown on the drawings, or as specified herein, or both. MATERIALS 1. Sub-purlins. Steel tub-puzlins shall be American Struc tural Products rail sections No, 101. Before leasing the shop, all steel work shall be thoroughly cleaned of all loose rust, mill scale and foreign matter and green one coat of epproeed metal protection applied thoroughly end evenly. 2. Kaylo Roof Ttle, Hoof tile shall be precast and reinforced Kaylo Hoof Tile, 2% inches thick by 18 inches wide by 86 inches long as made by American Structural Products Com- ~ paay. 2. Anchors. Anchors are not required with American Structural Products sub-purlins No. 101. 4.Grout. Grout for end joints of tile shall be composed of the lollowing materials, measured by volume: PROPORTIONS Retie eh VtlutiM Gauging plaster (quick-setting)........... Expanded eermiculite (virmiculite plastering aggregate). . V.'ater (approximate)............................. 1.0 0.6 1.0 1 eu. ft. 0.6 cm ft 7J^ gallons Consistency of grout shall be such that it can be poured, but not so thin that the eermiculite will float Add water to provide proper consistency. Stir thoroughly to remove all lumps. Dry materials may be mixed in large quantities as desired, hut weter should be added only to small betches which can be used immediately. 5. Curbs. Kaylo Insulating Hoof Tile 2% inches thick by 18 inches wide by 36 inches long shall be used lor curbs wherever shown on plans. Tiles shall be cut on job to height required. INSTALLATION 1. Sub-purlins. Co receive Kaylo Roof Tile, American Structural Products rail rub-purlins No. 131 trail be accurately spaced on center*. Sub-purlins mail be welded lo each supper*, with cue fillet weld, i* inch icc; placed cn alternate sices of suh-pcxlins. Where joints of sun-purlins do not occur over rupperis, their ends shall be welded together. Where ends of sub-purlins bear on masonry, they shall be securely anchored to the masonry as shown on the drawings or with one bolt at each sub-purlin.. 2. Kaylo Roof Tile. Kaylo Roof Tile shall be spaced evenly on rub-purlins to provide a r-lniiauxn end bearing of inch, with that side np which is marked "top." Tut shall he bulled tightly together at sides. Cut hie to fit al ridges, valleys, parapets, curbs, walls, around vents, pipes, etc. and grout in place. . . Where necessary to col standard pieces for fitting, any hand or power saw which will cut the wire mesh is suitable. 3. Grout. Joints at ends of tile over sub-purlins, and at ridges and hips, shell he filled with grout mixed as specified. Where sub-purlin No. 101 is used the stem of the sub-purlin shall be completely surrounded with grout to provide a key anchorage against uplift pressure. Grout shall be poured from an open-spout can into joints r--1 the gTout protrudes slightly above the surface of the tile. When grout has reached its initial set (few minutes) scrape joints flush with the tile surface. Sweep all loose and excess grout from the roof, leaving the roof deck free from all foreign mailer. 4. Saddles. Where concrete (either lightweight or gravel aggregate) saddles or cants are used over Kaylo Roof Deck, prime set:are of tiles which receive saddles, or cants, with asphalt :mr (Federal specifications, SS-S-701). Mop prime: -' top surface of tire using not lest than 7.5 pounds (one gallon) par one hundred square feet of roof. DESIGN DATA FOR KAYLO ROOF DECKS KAYLO ROOF TILE .............................. W%igkL (23 lb. til*) appro*. lHm X It- x 36'* .. .5 lb. par *q- *l WcAty, Approx................................. ................ 20.5 2b. per ex. it ....... ,,3"s3"xl0 9A, 9ole. folded urir* mmk SpeaLbe W............................................. 0*22 Btv par lb. per *f. At. modulua I ruptura.............................. 175 lb. per aR. ieeb A*, erutbieg atxaagtb.................................500 lb. per *9. taeb At. nod. oi eJortotr........................... 160,000 2b. per ?. ieeb Limits reOeeSoa........................... .................... .. approx. 00% OVER-ALL COEFFICIENT OF NEAT TRANSMISSION -IT* BTU/SQ.FTe/MOUR/*F Bor* Lj* .......................... ......... TJ* -- built-up roeha9............................. Tut -- 1 ixtul0es* -- buildup r00ba9 7u# -- 2" iBtu'.dhot -- bulit-wp roeheg. . . It. x**ty Kay* Ift*u.*box. .0.20 .C 19 .0.11 .0.10 RAIL SUB-PURLIN NO. 101 Site Weight Sp*e%*g la-s la. 4 ly-y ! 4 S14 lx 3 Ih./U. Lb./SJ. JJ ot Hoot 1.1 wr Ox Ctitan .6*4 IB jsa ALLOWABLE STANS FOR VARIOUS LOAD CONDITIONS TatslU.4 (? Sq. ru Spaa* I tea (-20.000 | t --16.000 I t- 20.000 l-18.000 Seatbara Staiaa 4 Ptcahe Slop# Casfaral State* 32 1k. *2 Ik. V4" r-4** *-4T r-10" .454 251 J7D xn Rock? Moeeieio IK. L State* * lk. ,-a- 7'4" J10 J4 Karlhatd State* 57 tk. ' 7'*2" SI*'* 256 JO* *S?toa tboa tr* lor Sat reeL Wbar* rub*pi roeis tad eatr*meo] bareixq occur*, raduc* ?**- AatuAtd daad load, pa; tquof* loot oi Attued i&o load ox icrjcciol ourlaca pr tquttt foot oi taoL Kaylo lilt tad tu^puiLat........ 6.C lb. Buildup roohag (to: tad gttwol)... ..................6.0 lb. Total ottd lotd................................. 12.0 lb. Soulbtta Stttrt tod Slope (to* load) ... .22 lb- pet a*, h. Ca&ttal Stale*.................... X> lb. par *9- Booty Mouatoiec tad M. E. State* ............ Kone*rt .. 37 lb. pat *9 h- <5 la. par *9 H. v.*1 `I I |11* A I I I M i l a i i i i i m11, 11 M t M l |. |) |O i h | H I 111 J ' l l Vl iif 111 11 . M l* j (111JMl I | j i . i j l l >| || | If j ' l| 11111 O l | 1\ b . I . l i l l |.I|IJ I|U IM H I ' l l *k.l I (>1 I I I A j M ill l.M >1M 11 | W ( ) A 11 11 |M | ' ( I I . M I I i M I I m 11 | )l< ;in i.H | ,|||; u .n .ll i l l11> A J.l \ U III A |l JOI JtX lilH JI'H jJ W M A T K A V L O M A TE R IA L IS ^ ii S T. -- "-=0c XC& ozs --c --vs C0 ^ 2 -* __ ; u Ik co C X.C tf) /) oCo a *" z E IU w oc c0 ZI xo V >. f E 0C? 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Lu. ---- E *~ m= =3cj 3;j -- .= zi =p -J . .m 2J i; OII S J|;{ S SMMS _~_ 0la3 c2lu -c w w w' W Vw c wO fiSSQ Cs CCOJ S O. tfl Cc>f,l -- *T5j co W w E 3e H to -- c3 * v: 3 _^__'1_ s^'ci'ci 1 .i r1 -r -- -- 3 3j -P "i < < <<<<<<<<< ,cot- to U_ .12 .2= C flrOt 2us2 cs:; z^: CJ .3s i: S------ i a c sto to-c r! 2* *2j P k~ -i 9 I III M- i i i . m i l l . d l m i i containers and closures Ion brushes s> <s> --5si> a ss COo S se CO CO ~e* p, e i- V- iS? w$ <S> <S> <s> < & s o u (A (A < d o --ia mn 2 2 --i x ^o IA in IA 0 HI J a 0e ah IN THE CIRCUIT COURT FOR BALTIMORE CITY * ALL CT-1 CASES ALL CT-2 CASES * ALL CT-4 CASES * ALL CT-5 CASES * *** ** ** DEFENDANT OWENS-ILLINOIS, INC.'S ANSWERS TO PLAINTIFFS' MASTER INTERROGATORIES TO ALL DEFENDANTS To: All Defendants, to be answered individually and separately by each Defendant. Plaintiffs, by their attorneys, John T. Enoch, John Amato, IV, and Goodman, Meagher & Enoch, request Defendants to answer the following Interrogatories. The Interrogatories are to be read and answered in accordance with the following instructions and definitions. a These Interrogatories are continuing in character and, in accordance with the Maryland Rules, you are required to supplement your answers promptly after you obtain further material information. Furthermore, Owens-Illinois, Inc. objects to the instructions and definitions supplied by Plaintiffs with regard to these Interrogatories, on the basis that the definitions are overbroad, vague, and often inconsistent with the normal usage and meaning of such words, and the instructions are overbroad, burdensome and constitute an unreasonable expansion of the Interrogatories themselves. Owens-Illinois, Inc. therefore gives notice that it does not consider itself bound by the instructions and definitions propounded by Plaintiffs, and instead shall answer the Interrogatories in a manner consistent with a normal understanding of the language used in the answer and to the extent necessary to fairly and fully answer the Interrogatory. PART I - GENERAL INTERROGATORIES INTERROGATORY NO. 1: State the name, address and official capacity of each person who has supplied information used in answering these interrogatories and indicate for which interrogatory each such person is responsible. RESPONSE NO. 1: This Defendant states that it has referred to the relevant business records of the Owens-Illinois Glass Company, which are still in the possession of Owens- Illinois, Inc., in connection with the preparation of answers to these Interrogatories unless otherwise indicated. INTERROGATORY NO. 2: Identify each document that was examined, reviewed and/or used in answering each interrogatory, specify the interrogatory and identify the present custodian of each document. -5- RESPONSE NO. 2: This Defendant objects to this Interrogatory on the basis that it is overly broad and unduly burdensome, and calls for information which is immune from discovery under the attorney work product doctrine. Without waiving above objections this Defendant states that it has referred to the relevant business records of the Owens-Illinois Glass Company, which are still in the possession of Owens-Illinois, Inc., in connection with the preparation of answers to these Interrogatories unless otherwise indicated. INTERROGATORY NO. 3: State whether you are a corporation. If so, state: your corporate name; state of incorporation; date of incorporation; address of principal place of business; address(es) of any other place of business; whether, if you are a "foreign corporation" as defined in Maryland General Corporation Law Sec. 1-101(1), you are now or have ever been registered or qualified to do ..business in the State of Maryland; and the corporate name, state of incorporation and date of incorporation of any subsidiary, predecessor or affiliate corporation. RESPONSE NO. 3: Owens-Illinois Glass Company was incorporated in the State of Ohio in 1929. Owens-Illinois Glass Company changed its name to Owens-Illinois, Inc. on April 28, 1965. The address of the principal place of business is One SeaGate, Toledo, Ohio 43666. INTERROGATORY NO. 4: which you have existed. Identify all prior names by RESPONSE NO. 4: Owens-Illinois Glass Company changed its name to Owens-Illinois, Inc. on April 28, 1965. -6- INTERROGATORY NO. 5: If you have divisions which have ever mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce asbestos products, identify each such division and state the names, addresses and job titles of each person who supervised each division, specifying the applicable time periods. RESPONSE NO. 5: This Defendant does not now and has not in the past engaged in the mining, milling, sale, supply or distribution of asbestos of any type. This Defendant, likewise, does not now and has not in the past engaged in the business of manufacturing, selling, supplying or distributing asbestos- containing textile products, asbestos-containing thermal insulation products, or any asbestos-containing products, except asbestos-containing thermal insulation products in the form of pipe covering and block. Further, this Defendant does not now or has not in the past operated "contract units" or any other entity that installed or contracted to install asbestos-containing products. Owens-Illinois Glass Company began limited pilot plant operations involving the production of asbestos-containing products in 1943. It began the manufacture of commercial' quantities of asbestos-containing products in about 1948 and continued such manufacture until about April 30, 1958. American Structural Products Company, a wholly owned subsidiary of Owens-Illinois Glass Company, engaged in the manufacture, sale and distribution of asbestos-containing products from about January, 1948 until about June, 1949 when it became the Kaylo Division of Owens-Illinois Glass Company. The Kaylo Division of this Defendant continued to manufacture such -7- products until about April 30, 1958 when it was purchased by Owens-Corning Fiberglas Corporation from this Defendant effective on that date. As of that time, this Defendant ceased the manufacture and sale of asbestos-containing products, and it has not engaged in any such business since that date. INTERROGATORY NO. 6: Have you controlled, purchased or in any way acquired any interest in any corporation or business entity which mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce asbestos products? RESPONSE NO. 6: No, however, Owens-Illinois Glass Company changed its name to Owens-Illinois, Inc. on April 28, 1965. INTERROGATORY NO. 7: If your Answer to Interrogatory No. 6 is in the affirmative, identify and attach copies of all documents related thereto and state: (a) The name(s), including prior name(s), and the business address(es) of any and all such corporation(s) or business entity(ies); (b) The date(s) on which you first controlled, purchased or acquired said interest; (c) The manner in which you acquired said interest, i.e., cash purchase, merger, consolidation, exchange or sale of assets, etcetera; (d) The percentage of assets, ownership and/or control acquired by you; (e) Whether the corporation(s) or business entity (ies) acquired by you continued to exist following the acquisition and, if not, the date on which its existence ceased; (f) The nature cf ar.d/cr amount of consideration paid by you for said interest; -8- (g) The terms and conditions of any contracts or agreements by and between you and such corporation(s) or business entity(ies), including, but not limited to, the terms and conditions relating to the transfer of liabilities for obligations of such corporation(s) or business entity(ies); (h) Whether you continued the manufacture, sale and/or distribution of such corporation's or business entity's asbestos products and, if so, whether you used the same product name(s) in so doing; and (i) Whether there was an identity of name, officers, directors, personnel, property, suppliers, distribution outlets and/or clients between you and such corporation(s) or business entity(ies); RESPONSE NO. 7: Refer to Response No. 6. INTERROGATORY NO. 8: If you have directly or indirectly mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce asbestos or asbestos-containing products, state as to each such product, indicating separately those products dealt with by you, your predecessor(s) in interest, your subsidiary(ies), and your affiliate(s), if any, the following; (a) Brand name, trade-name, and/or trade-mark; (b) The generic name or identity; (c) Description, including size, shape, color and composition, i.e. solid, powder or other form; 1 (d) Chemical and physical composition, including, but not limited to, the percentage of asbestos by weight and volume; (e) Type of asbestos, i.e. chrysotile, amosite, crocidolite, actinolite, anthophyllite, or tremolite, indicating the percentage of each such asbestos fiber by weight and volume; (f) Intended marketable use; and (g) Dates during which each asbestos product was mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, disrribuued and/or otherwise placed in the stream of commerce. -9- RESPONSE NO. 8: (a) Kaylo and Kaylo-20; (b) This Defendant's asbestos-containing products were hydrous calcium silicate materials; % (c) Owens-Illinois Glass Company began limited pilot plant operations involving the production of "Kaylo" asbestos- containing products in 1943. It began the manufacture of commercial quantities of "Kaylo" asbestos-containing products in about 1948 and continued such manufacture until about April 30, 1958. (d) This Defendant ceased the manufacture, sale and distribution of its asbestos-containing products in 1958. Its investigation as to the composition of each such product, including the type of asbestos-contained therein (i.e.f amosite or chrysotile) and the quantitative percentage of asbestos, is continuing, although this Defendant now believes that this Defendant's commercially produced asbestos-containing products were hydrous calcium silicates containing between 13% and approximately 20% asbestos. Chrysotile asbestos was the primary type apparently used. Amosite was used to a lesser extent. (f) The asbestos-containing products manufactured by this Defendant were intended to be used for industrial high temperature thermal insulation such as pipe covering and block insulation, and to increase fireproofing and fire protection and for insulation through use as a roof deck or fireproof material or door core material. -10- (g) Owens-Illinois Glass Company began limited pilot plant operations involving the production of ^Kaylo* asbestoscontaining products in 1943. It began the manufacture of commercial quantities of "Kaylo" asbestos-containing products in about 1948 and continued such manufacture until about April 30, 1958. INTERROGATORY NO. 9: State whether you presently mine, manufacture, produce, fabricate, import, convert, compound, process, sell, merchandise, supply, distribute and/or otherwise place in the stream of commerce any asbestos product(s) listed in your Answer to the preceding interrogatory. RESPONSE NO. 9: This Defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. It does not now, and it has not since that time, manufactured, sold or distributed any asbestos-containing products. INTERROGATORY NO. 10: Identify each individual who participated in the design and preparation of manufacturing specifications for each asbestos product identified in your Answer to Interrogatory No. 8. ' RESPONSE NO. 10: This Defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to plaintiff's counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. -11- INTERROGATORY NO. 11: State whether any written memoranda, specifications, blueprints or other written materials of any kind or character now exist relating to the design and preparation of the asbestos products identified in your Answer to Interrogatory No. 8. If so, identify: (a) Each such written material or document; and (b) The custodian, identity and location of each written material or document. RESPONSE NO. 11: This defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to Plaintiff's counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. INTERROGATORY NO. 12: Identify, by location and product, each plant of your in which the asbestos products identified in your Answer to Interrogatory No. 8 have been manufactured and/or assembled and the dates said plants have been in operation. RESPONSE NO. 12: This defendant's manufacturing plants were located in Berlin, New Jersey and Sayreville, New Jersey. The Berlin plant was in operation from approximately 1943 until on or about April 30, 1958. The Sayreville plant was in operation from February, 1948 until about April 30, 1953. INTERROGATORY NO. 13: If you have discontinued mining, manufacturing, producing, fabricating, importing, converting, compounding, processing, selling, merchandising, supplying, distributing and/or otherwise placing in the stream of commerce any asbestos products listed in your Answer to Interrogatory No. 8, identify the products discontinued, give the date of discontinuance and specify the reason(s) for such discontinuance. -12- RESPONSE NO. 13: In 1953, this Defendant entered into a sales agreement with Owens-Corning Fiberglas Corporation under which it agreed to the sale of asbestos-containing products to that corporation. This Defendant believes that it ceased the general marketing and sales of its asbestos-containing thermal insulation products at that time, disbanded its sales force, and that thereafter, Owens-Corning Fiberglas Corporation was the primary marketer of its product until the sale of the division to Owens-Corning Fiberglas Corporation in 1958. INTERROGATORY NO. 14: If you have done so, when did you first determine that any other material could be used in place of asbestos for high-temperature insulation or any other use to or for which asbestos has been applied. If you have, in fact, substituted other material(s) for asbestos in your product(s), then state: (a) The identity of such substituted material(s)? (b) When the product(s) with such substituted material(s) was first marketed; and (c) The tradename(s) and brand name(s) of the product(s) marketed with such substituted material(s). RESPONSE NO. 14: This defendant has located information in its records indicating that several efforts were made to substitute other materials for the asbestos in its Kaylo products; however, such efforts were unsuccessful. Defendant will make available to plaintiffs' counsel through its local counsel reports on such experiments. Some of the reports are contained on microfilm which is old and of poor quality.. -13- INTERROGATORY NO. 20: Identify the distributors of your asbestos products at any time during the period from 1930 to the present and attach copies of all documents relating to said distributors. For each distributor, indicate: (a) The terms of all assignments, agreements, licenses and other arrangements by and between you and said distributor; exclusive; (b) Whether the distribution relationship was (c) The year or years in which the distribution relationship was in effect; ' (d) The identity of your asbestos products which the distributor was authorized to and did distribute; and (e) The quantity of your asbestos products distributed by the distributor on a year-by-year and product-by product basis. RESPONSE NO. 20: To the extent that this Interrogatory seeks information for any state other than Maryland, this Defendant objects to this Interrogatory on the basis that it is overbroad and it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the above objection, and insofar as this Interrogatory pertains to Maryland, this Defendant states that McCormick Asbestos Company was a distributor of this Defendant's asbestos-containing products. In 1953, this Defendant entered into a sales agreement with Owens-Corning Fiberglas Corporation under which it agreed to the sale of asbestos-containing products to that corporation. This Defendant believes that it ceased the general marketing and sales of its asbestos-containing thermal insulation products at that time. -18- disbanded its sales force, and that thereafter, Owens-Corning Fiberglas Corporation was the primary marketer of its products until the sale of the division to Owens-Corning Fiberglas * Corporation in 1958, and that these circumstances are the reason that it does not have records or correspondence which would enable it to answer this Interrogatory for the period after 1954. INTERROGATORY NO. 21: State whether you have ever sold, distributed or otherwise furnished any of your asbestos products to any other person and/or business entity for resale or redistribution at any time from 1930 to the present. If so, state: (a) The identity of each such person and/or business entity; (b) The brand name, tradename and/or trademark adopted and used by you for each such product; (c) The brand name, tradename and/or trademark adopted and used by each such person and/or business entity for each such product; product; (d) The generic name or identity of each such (e) The year(s) in which each such product was sold, distributed or otherwise furnished to each such person and/or business entity, and for each year, the quantity of' each product sold, distributed or otherwise furnished; product; (f) The intended marketable use for each such (g) Whether each such product was intended to be used, resold, or distributed by such other person and/or business entity in the same or substantially the same condition as it was when shipped or delivered by you; and (h) The custodian, identity and location of all documents pertaining to agreements for the resale, distribution, or furnishing of your asbestos products to each other person and/or business entity. -19- RESPONSE NO. 21: This Defendant ceased the manufacture, sale and distribution of asbestos-containing thermal insulation products in 1958. This Defendant states that in 1953 * it entered into a "Sales Agreement" under which it agreed to sell certain amounts of its asbestos-containing thermal insulation products to Owens-Corning Fiberglas Corporation. Furthermore, this Defendant has found information.in its records which indicate that in at least 1956, it placed Owens-Corning Fiberglas Corporation's logo on some of its boxes. This Defendant does not have information sufficient to further respond to this Interrogatory. INTERROGATORY NO. 22: State the following with respect to the packages and containers in which you sold, distributed or otherwise furnished each of the asbestos products described in your Answer to Interrogatory Nos. 8 and 19 on a year-by-year and product-by-product basis; (a) A description of the package or container in which each product was sold, distributed or otherwise furnished, including composition, size, shape and color; (b) A description of the markings or printed material that appeared on each package or container, indicating the size and color of the same; (c) A description of any logo or other design appearing on the package or container; (d) A verbatim description of any caution or warning notice appearing on the package or container, setting forth the year(s) in which each such notice appeared on each such product; and (e) A verbatim description of any instructions appearing on the package or container. . -20- defendant made appropriate efforts to provide ventilation and to control the emissions of all dust emitted during the manufacturing process within recognized save levels of exposure, including the use of respirators in some instances, dust collection equipment and other devices as necessary. Therefore, during the period in which this defendant was in the business of manufacturing Kaylo it had no reason< to believe that the foreseeable use of Kaylo would create a hazard to users. The documents produced by Owens-Corning Fiberglas Corporation indicate that the September, 1955 publication in the A.M.A. Archives of Industrial Health was a publication of inhalation experiments. To the extent that this interrogatory seeks the production of documents, such documents, as outlined in this response, have not been found as part of this defendant's records and, to the extent that this defendant is in possession of copies of documents, it possesses copies only of documents collected in preparation for litigation. This defendant objects to producing the same. The documents are available from their proper source. INTERROGATORY NO. 39: Identify all trade organizations, associations or other entities to which you belong or belonged. Said organizations, etc., include, at a minimum, the following: Asbestos Textile Institute (ATI); Industrial Hygiene Foundation and/or Industrial Health Foundation (IHF); Mineral Wool Institute; Industrial Mineral Insulation Manufacturers Institute; -38- Magnesia Silica Insulation Manufacturers Association; National Insulation Manufacturers Association (NIMA); Thermal Insulation Manufacturers Association (TIMA); Asbestos Information Association (AIA); Quebec Asbestos Mining Association (QAMA); National Safety Council; Asbestos Cement Producers Association; Refractories Institute. RESPONSE NO. 39: This defendant objects to this interrogatory on the grounds that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence except as it relates to the period of time within which this defendant manufactured its asbestos-containing products. Without waiving the above objection, this defendant states that insofar as this interrogatory refers to associations or organizations of which this defendant was a member during the time when it manufactured asbestos-containing products, it was a member of the Industrial Hygiene Foundation (which changed its name to the Industrial Health Foundation in 1970) for the years 1936 through 1975. This defendant was not a member of any of the other organizations about which this interrogatory inquires. INTERROGATORY NO. 40: For each trade organization, association or other entity identified in your Answer tb Interrogatory No. 39, state: -39- (c) All documents relating to Saranac Laboratory studies or tests which were received or submitted by you, either directly or indirectly through predecessor(s) in interest, subsidiary(ies) or affiliate(s), if any, through other companies, or through any trade associations, organizations or entities; (d) All recommendations or findings of such studies in relation to: (i) adequacy or inadequacy of the threshold limit values; (ii) the substitution of materials for asbestos; and (e) The custodian and location of all documents and/or communications identified in your Answer to this Interrogatory. RESPONSE NO. 45: Refer to response to interrogatory no. 44. INTERROGATORY NO. 46: State the amount of money spent or contributed by you annually from 1930 to the present for research of the relationship between exposure to asbestos dusts, fibers and/or products and any pulmonary pathology and identify each person or organization to whom the expenditure or contribution was made. RESPONSE NO. 46: This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 47: State whether you have ever maintained a library (or libraries) which contains books, articles, periodicals, journals and/or reference materials that relate to the subjects of asbestos, industrial hygiene, medicine, safety, occupational disease and/or engineering. If so, state: (a) The date each such library was established; (b) The location of each such library; (c) The identity of each librarian or other person in charge of the operation and materials of each such library; -43- established; (d) For whose use each such library was (e) The title, publisher and dates of subscription to or acquisition of each such periodical or journal for each such library; and (f) The title, author, publisher, date and dates of acquisition of each such article and book for each such library. RESPONSE NO. 47: During the period of time pertinent to these actions, this defendant did not maintain an entity which would be characterized as an industrial hygiene, medicine, safety and/or engineering library. However, this defendant believes that a separate engineering library may have been maintained by its technical facility. This defendant also states that although it has no records indicating the existence of such a library, upon becoming involved in asbestos-related litigation this defendant listed all the publications which were in its then- existing industrial hygiene library. These publications are listed on Exhibit II. This defendant has not yet determined which, if any, of these publications were in this defendant's possession during the time it manufactured, sold and distributed asbestos-containing products. INTERROGATORY NO. 48: State whether any of the co defendants in asbestos litigation have ever furnished you with any information as to the state of the medical knowledge at any time regarding the relationship between exposure to asbestos dusts, fibers and/or products and the contracting of diseases, including asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers. RESPONSE NO. 48: This defendant objects to this interrogatory as being irrelevant and not reasonably calculated to lead to the discovery of admissible evidence and not limited -44- to any issue which is the subject of this case. This defendant further objects to this interrogatory on the grounds that it seeks information within the work-product privilege and on the ground that it is oppressive and burdensome in that it would have to review all of the files and all of the records of all of its attorneys all over the country to respond to this interrogatory. INTERROGATORY NO. 49: If your Answer to Interrogatory No. 48 is in the affirmative, identify: (a) How the information was furnished; (b) Who furnished said information; (c) When said information was given to you; and (d) The substance of said information. RESPONSE NO. 49: Refer to objections to interrogatory no. 48. INTERROGATORY NO. 50: State whether, at any time since 1930, you have interchanged, exchanged or communicated, the results of research, tests, studies or experiments regarding the relationship between exposure to asbestos dusts, fibers and/or products and the contracting of diseases, including asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers, with any other person, corporation or other business entity, including co-defendants in this action. RESPONSE NO. 50: This defendant objects to this interrogatory insofar as it may seek to discover work product of counsel and trial preparation material. Without waiving such objection, this defendant states that it ceased the manufacture, sale and distribution of asbestos-containing products and does not have any records of having interchanged any of the material referred to in this interrogatory with any of the other defendants named in this case; however, this defendant states that defendant Owens-Corning Fiberglas Corporation was entitled -45- to receive and way have received from this defendant material of the type specified in this interrogatory pursuant to an Agreement dated March 9, 1958 by which this defendant sold the Kaylo * Division to Owens-Corning Fiberglas, if in fact this defendant had any material of said type at that time. This defendant's investigation into the subject matter of this interrogatory is continuing. . INTERROGATORY NO. 51: If your Answer to Interrogatory No. 50 is in the affirmative, state: (a) When said interchanges, exchanges or communications occurred; (b) The identity of those persons, corporations or business entities who participated in said interchanges, exchanges or communications; (c) The content of said interchanges, exchanges or communications; and (d) The identity of the custodian of any documents which relate to said interchanges, exchanges or communications. RESPONSE NO. 51: Refer to objection and response to interrogatory no. 50. INTERROGATORY NO. 52:, Identify all persons who have testified on your behalf before the Occupational Safety and Health Administration, the National Institute of Occupational Safety and Health, any United States congressional committee, sub-committee, administrative hearing or investigative proceeding on the subjects of the human health consequences of exposure to asbestos dusts, fibers and/or products and the setting, modification, feasibility and acceptance of allegedly safe or proper levels of exposure to said asbestos and asbestos products. RESPONSE NO. 52: This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not -46- RESPONSE NO. 97: Not applicable. Refer to response to interrogatory no. 96. INTERROGATORY NO. 98: Identify any and all insurance agreements entered into by and between any person carrying on an insurance business and you which may be available to satisfy part or all of a judgment that might be entered in this action or to indemnify or reimburse you for payments made to satisfy the judgment. As to each such agreement, identify the insurance carrier, the amount of coverage and the applicable dates of coverage. RESPONSE NO. 98: This-defendant objects to this interrogatory on the grounds that it seeks information which is not relevant to the subject matter of this litigation and is not calculated to lead to the discovery of admissible evidence. Without waiving the above objections, this defendant has liability coverage by its insurer, Aetna, for some of the actions brought against it which allegedly result from the use of asbestos-containing products. INTERROGATORY NO. 99: Describe the method by which you have maintained records concerning the manufacture, sale, advertising, distribution, delivery and installation of each of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. RESPONSE NO. 99: This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958 pursuant to the sale of its Kaylo division to Owens-Corning Fiberglas Corporation on April 30, 1958. It has not found any information in its records pertinent to a record or document retention policy during the period when it manufactured its asbestos-containing products or for the period of years shortly thereafter. In accordance with the contract for the sale of the Kaylo division, in the ordinary course of business -72- relating to such sale, and because of the production of certain documents by counsel for Owens-Corning Fiberglas Corporation in several jurisdictions involving asbestos-related litigation in the United States, this defendant believes that most of its records pertinent to the Kaylo division were either transferred or made available to the purchaser of the division in 1958. This defendant states that it has not destroyed any documents or records pertaining to the Kaylo division which have been found in its records in 1975 (the year in which this defendant first became aware of asbestos-related actions against it) and thereafter. INTERROGATORY NO. 100: With regard to the record keeping method described in your Answer to Interrogatory No. 99, identify: (a) Each present and former corporate department, division or subdivision responsible for maintaining the records; (b) How the records are kept, e.g.,in boxes, files, on microfilm, microfiche or computer tape or disk; (c) The inclusive dates of manufacture, sale, advertising, distribution, delivery and installation that the record keeping system covers; (d) The location(s) where such records are maintained; and (e) The identity of each person employed by you at any time from 1930 to the present, in the highest supervisory capacity, who is or was directly responsible for the collection and maintenance of such records. RESPONSE NO. 100: Refer to response to interrogatory no. 99. INTERROGATORY NO. 101: If the record keeping system described in your Answer to Interrogatory No. 99 includes use of microfilm, microfiche, computer tape or disk or any other system in which data is taken from other records, state whether you have -73- AFflPAYIT STATE OF OHIO COUNTY OF LUCAS ) SS: ) ` M. F. MCCARTHY, being duly sworn according to law, deposes and says that he is an Assistant Secretary of OwensIllinois, Inc., a defendant herein; that as such he is authorized to make an Affidavit on its behalf; and that the facts set forth in the foregoing DEFENDANT, OWENS-ILLINOIS, INC.'S ANSWERS TO INTERROGATORIES, are true and correct to the best of his knowledge, information and belief. SWORN TO and subscribed M. F. MCCARTHY Notary Public Ky Commission Expires; IK THE CIRCUIT COURT POR BALTIMORE CITY * * ALL CT-1 CASES * ALL CT-2 CASES * ALL CT-4 CASES * ' ALL CT-5 CASES * * ********* DEFENDANT OWENS-ILLINOIS, INC.'S ANSWERS TO PLAINTIFFS' MASTER INTERROGATORIES TO ALL DEFENDANTS To: All Defendants, to be answered individually and separately by each Defendant. Plaintiffs, by their attorneys, John T. Enoch, John Amato, IV, and Goodman, Meagher & Enoch, request Defendants to answer the following Interrogatories. The Interrogatories are to be read and answered in accordance with the following instructions and definitions. a. These Interrogatories are continuing in character and, in accordance with the Maryland Rules, you are required to supplement your answers promptly after you obtain further material information. RESPONSE NO. 2: This Defendant objects to this Interrogatory on the basis that it is overly broad and unduly burdensome, and calls for information which is immune from discovery under the attorney work product doctrine. Without waiving above objections this Defendant states that it has referred to the relevant business records of the Owens-Illinois Glass Company, which are still in the possession of Owens-Illinois, Inc., in connection with the preparation of answers to these Interrogatories unless otherwise indicated. INTERROGATORY NO. 3: State whether you are a corporation. If so, state: your corporate name; state of incorporation; date of incorporation; address of principal place of business; address(es) of any other place of business; whether, if you are a "foreign corporation" as defined in Maryland General Corporation Law Sec. 1-101(1), you are now or have ever been registered or qualified to do business in the State of Maryland; and the corporate name, state of incorporation and date of incorporation of any subsidiary, predecessor or affiliate corporation. RESPONSE NO. 3: Owens-Illinois Glass Company was incorporated in the State of Ohio in 1929. Owens-Illinois Glass Company changed its name to Owens-Illinois, Inc. on April 28, 1965. The address of the principal place of business is One SeaGate, Toledo, Ohio 43666. INTERROGATORY NO. 4: which you have existed. Identify all prior names by RESPONSE NO. 4: Owens-Illinois Glass Company changed its name to Owens-Illinois, Inc. on April 28, 19.65. -6- (g) The terms and conditions of any contracts or agreements by and between you and such corporation(s) or business entity(ies), including, but not limited to, the terms and conditions relating to the transfer of liabilities for obligations of such corporation(s) or business entity(ies); (h) Whether you continued the manufacture, sale and/or distribution of such corporation's or business entity's asbestos products and, if so, whether you used the same product name(s) in so doing; and (i) Whether there was an identity of name, officers, directors, personnel, property, suppliers, distribution outlets and/or clients between you and such corporation(s) or business entity(ies); RESPONSE NO. 7: Refer to Response No. 6. INTERROGATORY NO. 8: If you have directly or indirectly mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce asbestos or asbestos-containing products, state as to each such product, indicating separately those products dealt with by you, your predecessor(s) in interest, your subsidiary(ies), and your affiliate(s), if any, the following: (a) Brand name, trade-name, and/or trade-mark; (b) The generic name or identity; (c) Description, including size, shape, color and composition, i.e. solid, powder or other form; ' (d) Chemical and physical composition, including, but not limited to, the percentage of asbestos by weight and volume; (e) Type of asbestos, i.e. chrysotile, amosite, crocidolite, actinolite, anthophyllite, or tremolite, indicating the percentage of each such asbestos fiber by weight and volume; (f) Intended marketable use; and (g) Dates during which each asbestos product was mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce. -9- RESPONSE NO. 8: (a) Kaylo and Kaylo-20; (b) This Defendant's asbestos-containing products were hydrous calcium silicate materials; (c) Owens-Illinois Glass Company began limited pilot plant operations involving the production of "Kaylo" asbestos- containing products in 1943. It began the manufacture of commercial quantities of "Kaylo" asbestos-containing products in about 1948 and continued such manufacture until about April 30, 1958. (d) This Defendant ceased the manufacture, sale and distribution of its asbestos-containing products in 1958. Its investigation as to the composition of each such product, including the type of asbestos-contained therein (i.e., amosite or chrysotile) and the quantitative percentage of asbestos, is continuing, although this Defendant now believes that this Defendant's commercially produced asbestos-containing products were hydrous calcium silicates containing between 13% and approximately 20% asbestos. Chrysotile asbestos was the primary type apparently used. Amosite was used to a lesser extent. (f) The asbestos-containing products manufactured by this Defendant were intended to be used for industrial high temperature thermal insulation such as pipe covering and block insulation, and to increase fireproofing and fire protection and for insulation through use as a roof deck or fireproof material or door core material. -10- (g) Owens-Illinois Glass Company began limited pilot plant operations involving the production of "Kaylo" asbestoscontaining products in 1943. It began the manufacture of commercial quantities of "Kaylo" asbestos-containing products in about 1948 and continued such manufacture until about April 30, 1958. INTERROGATORY NO. 9: State whether you presently mine, manufacture, produce, fabricate, import, convert, compound, process, sell, merchandise, supply, distribute and/or otherwise place in the stream of commerce any asbestos product(s) listed in your Answer to the preceding interrogatory. RESPONSE NO. 9: This Defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. It does not now; and it has not since that time, manufactured, sold or distributed any asbestos-containing products. INTERROGATORY NO. 10: Identify each individual who participated in the design and preparation of manufacturing specifications for each asbestos product identified in your Answer to Interrogatory No. 8. > RESPONSE NO. 10: This Defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to plaintiff's counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. -11- INTERROGATORY NO. 11: State whether any written memoranda, specifications, blueprints or other written materials of any kind or character now exist relating to the design and preparation of the asbestos products identified in your Answer to Interrogatory No. 8. If so, identify: (a) Each such written material or document; and (b) The custodian, identity and location of each written material or document. RESPONSE NO. 11: This defendant has in its records technical reports relating to the development and testing of Kaylo, and will make available to Plaintiff's counsel through its local counsel these records. Many of the reports are contained on microfilm which is old and of poor quality. Adequate copies may not be made from it, and reading it requires a reader device. This defendant further states that its investigation into the subject matter referred to in this Interrogatory is continuing. INTERROGATORY NO. 12: Identify, by location and product, each plant of your in which the asbestos products identified in your Answer to Interrogatory No. 8 have been manufactured and/or assembled and the dates said plants have been in operation. RESPONSE NO. 12: This defendant's manufacturing plants were located in Berlin, New Jersey and Sayreville, New Jersey. The Berlin plant was in operation from approximately 1943 until on or about April 30, 1958. The Sayreville plant was in operation from February, 1948 until about April 30, 1953. INTERROGATORY NO. 13: If you have discontinued mining, manufacturing, producing, fabricating, importing^ converting, compounding, processing, selling, merchandising, supplying, distributing and/or otherwise placing in the stream of commerce any asbestos products listed in your Answer to Interrogatory No. 8, identify the products discontinued, give the date of discontinuance and specify the reason(s) for such discontinuance. -12- RESPONSE NO. 13: In 1953, this Defendant entered into a sales agreement with Owens-Corning Fiberglas Corporation under which it agreed to the sale of asbestos-containing products to that corporation. This Defendant believes that it ceased the general marketing and sales of its asbestos-containing thermal insulation products at that time, disbanded its sales force, and that thereafter, Owens-Corning Fiberglas Corporation was the primary marketer of its product until the sale of the division to Owens-Corning Fiberglas Corporation in 1958. INTERROGATORY NO. 14: If you have done so, when did you first determine that any other material could be used in place of asbestos for high-temperature insulation or any other use to or for which asbestos has been applied. If you have, in fact, substituted other material(s) for asbestos in your product(s), then state: (a) The identity of such substituted material(s); (b) When the product(s) with such substituted material(s) was first marketed; and (c) The tradename(s) and brand name(s) of the product(s) marketed with such substituted material(s). RESPONSE NO. 14: This defendant has located ' information in its records indicating that several efforts were made to substitute other materials for the asbestos in its Kaylo products; however, such efforts were unsuccessful. Defendant will make available to plaintiffs' counsel through its local counsel reports on such experiments. Some of the reports are contained on microfilm which is old and of poor quality. -13- INTERROGATORY NO. 20: Identify the distributors of your asbestos products at any time during the period from 1930 to the present and attach copies of all documents relating to said distributors. For each distributor, indicate: (a) The terms of all assignments, agreements, licenses and other arrangements by and between you and said distributor; exclusive ; (b) Whether the distribution relationship was (c) The year or years in which the distribution relationship was in effect; ' (d) The identity of your asbestos products which the distributor was authorized to and did distribute; and (e) The quantity of your asbestos products distributed by the distributor on a year-by-year and product-by product basis. RESPONSE NO. 20: To the extent that this Interrogatory seeks information for any state other than Maryland, this Defendant objects to this Interrogatory on the basis that it is overbroad and it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the above objection, and insofar as this Interrogatory pertains to Maryland, this Defendant states that McCormick Asbestos Company was a distributor of this Defendant's asbestos-containing products. In 1953, this Defendant entered into a sales agreement with Owens-Corning Fiberglas Corporation under which it agreed to the sale of asbestos-containing products to that corporation. This Defendant believes that it ceased the general marketing and sales of its asbestos-containing thermal insulation products at that time, -18- disbanded its sales force, and that thereafter, Owens-Corning Fiberglas Corporation was the primary marketer of its products until the sale of the division to Owens-Corning Fiberglas Corporation in 1958, and that these circumstances are the reason that it does not have records or correspondence which would enable it to answer this Interrogatory for the period after 1954. INTERROGATORY NO. 21: State whether you have ever sold, distributed or otherwise furnished any of your asbestos products to any other person and/or business entity for resale or redistribution at any time from 1930 to the present. If so, state: (a) The identity of each such person and/or business entity; (b) The brand name, tradename and/or trademark adopted and used by you for each such product; (c) The brand name, tradename and/or trademark adopted and used by each such person and/or business entity for each such product; product; (d) The generic name or identity of each such (e) The year(s) in which each such product was sold, distributed or otherwise furnished to each such person and/or business entity, and for each year, the quantity of each product sold, distributed or otherwise furnished; product; (f) The intended marketable use for each such (g) Whether each such product was intended to be used, resold, or distributed by such other person and/or business entity in the same or substantially the same condition as it was when shipped or delivered by you; and (h) The custodian, identity and location of all documents pertaining to agreements for the resale, distribution, or furnishing of your asbestos products to each other person and/or business entity. 19- defendant made appropriate efforts to provide ventilation and to control the emissions of all dust emitted during the manufacturing process within recognized save levels of exposure, * including the use of respirators in some instances, dust collection equipment and other devices as necessary. Therefore, during the period in which this defendant was in the business of manufacturing Kaylo it had no reason to believe that the i foreseeable use of Kaylo would create a hazard to users. The documents produced by Owens-Corning Fiberglas Corporation indicate that the September, 1955 publication in the A.M.A. Archives of Industrial Health was a publication of inhalation experiments. To the extent that this Interrogatory seeks the production of documents, such documents, as outlined in this response, have not been found as part of this defendant's records and, to the extent that this defendant is in possession of copies of documents, it possesses copies only of documents collected in preparation for litigation. This defendant objects to producing the same. The documents are available from their proper source. INTERROGATORY NO. 39: Identify all trade organizations, associations or other entities to which you belong or belonged. Said organizations, etc., include, at a minimum, the following: Asbestos Textile Institute (ATI); Industrial Hygiene Foundation and/or Industrial Health Foundation (IHF); Mineral Wool Institute; Industrial Mineral Insulation Manufacturers Institute? -38- Magnesia Silica Insulation Manufacturers Association; National Insulation Manufacturers Association (NIMA); Thermal Insulation Manufacturers Association (TIMA); Asbestos Information Association (AIA); Quebec Asbestos Mining Association (QAMA); National Safety Council; Asbestos Cement Producers Association; Refractories Institute. RESPONSE NO. 39; This defendant objects to this interrogatory on the grounds that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence except as it relates to the period of time within which this defendant manufactured its asbestos-containing products. Without waiving the above objection, this defendant states that insofar as this interrogatory refers to associations or organizations of which this defendant was a member during the time when it manufactured asbestos-containing products, it was a member of the Industrial Hygiene Foundation (which changed its name to the Industrial Health Foundation in 1970) for the years 1936 through 1975. This defendant was not a member of any of the other organizations about which this interrogatory inquires. INTERROGATORY NO. 40: For each trade organization, association or other entity identified in your Answer to Interrogatory No. 39, state: -39- (c) All documents relating to Saranac Laboratory studies or tests which were received or submitted by you, either directly or indirectly through predecessor(s) in interest, subsidiary(ies) or affiliate (s), if any, through other companies, or through any trade associations, organizations or entities; (d) All recommendations or findings of such studies in relation to: (i) adequacy or inadequacy of the threshold limit values; (ii) the substitution of materials for asbestos; a'nd (e) The custodian and location of all documents and/or communications identified in your Answer to this Interrogatory. RESPONSE NO. 45: Refer to response to interrogatory no. 44. INTERROGATORY NO. 46: State the amount of money spent or contributed by you annually from 1930 to the present for research of the relationship between exposure to asbestos dusts, fibers and/or products and any pulmonary pathology and identify each person or organization to whom the expenditure or contribution was made. RESPONSE NO. 46: This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 47: State whether you have ever maintained a library (or libraries) which contains books, articles, periodicals, journals and/or reference materials that relate to the subjects of asbestos, industrial hygiene, medicine, safety, occupational disease and/or engineering. If so, state: (a) The date each such library was established; (b) The location of each such library; (c) The identity of each librarian or other person in charge of the operation and materials of each such library; -43- established; (d) For whose use each such library was -< (e) The title, publisher and dates of subscription to or acquisition of each such periodical or journal for each such library; and (f) The title, author, publisher, date and dates of acquisition of each such article and book for each such library. RESPONSE NO. 47: During the period of time pertinent to these actions, this defendant did not maintain an entity which would be characterized as an industrial hygiene, medicine, safety and/or engineering library. However, this defendant believes that a separate engineering library may have been maintained by its technical facility. This defendant also states that although it has no records indicating the existence of such a library, upon becoming involved in asbestos-related litigation this defendant listed all the publications which were in its then- existing industrial hygiene library. These publications are listed on Exhibit II. This defendant has not yet determined which, if any, of these publications were in this defendant's possession during the time it manufactured, sold and distributed asbestos-containing products. INTERROGATORY NO. 48: State whether any of the co defendants in asbestos litigation have ever furnished you with any information as to the state of the medical knowledge at any time regarding the relationship between exposure to asbestos dusts, fibers and/or products and the contracting of diseases, including asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers. RESPONSE NO. 48: This defendant objects to this interrogatory as being irrelevant and not reasonably calculated to lead to the discovery of admissible evidence and not limited -44- to any issue which is the subject of this case. This defendant further objects to this interrogatory on the grounds that it seeks information within the work-product privilege and on the ground that it is oppressive and burdensome in'that it would have to review all of the files and all of the records of all of its attorneys all over the country to respond to this interrogatory. INTERROGATORY NO. 49: If your Answer to Interrogatory No. 48 is in the affirmative, identify: (a) How the information was furnished; (b) Who furnished said information; (c) When said information was given to you; and (d) The substance of said information. RESPONSE NO. 49: Refer to objections to interrogatory no. 48. INTERROGATORY NO. 50: State whether, at any time since 1930, you have interchanged, exchanged or communicated, the results of research, tests, studies or experiments regarding the relationship between exposure to asbestos dusts, fibers and/or products and the contracting of diseases, including asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers, with any other person, corporation or other business entity, including co-defendants in this action. RESPONSE NO. 50: This defendant objects to this interrogatory insofar as it may seek to discover work product of counsel and trial preparation material. Without waiving such objection, this defendant states that it ceased the manufacture, sale and distribution of asbestos-containing products and does not have any records of having interchanged any of the material referred to in this interrogatory with any of the other defendants named in this case; however, this defendant states that defendant Owens-Corning Fiberglas Corporation was entitled -45- to receive and may have received from this defendant material of the type specified in this interrogatory pursuant to an Agreement dated March 9, 1958 by which this defendant sold the Kaylo Division to Owens-Corning Fiberglas, if in fact this defendant had any material of said type at that time. This defendant's investigation into the subject matter of this interrogatory is continuing. .. INTERROGATORY NO. 51: If your Answer to Interrogatory No. 50 is in the affirmative, state: (a) When said interchanges, exchanges or communications occurred; (b) The identity of those persons, corporations or business entities who participated in said interchanges, exchanges or communications? (c) The content of said interchanges, exchanges or communications; and (d) The identity of the custodian of any documents which relate to said interchanges, exchanges or communications. RESPONSE NO. 51: Refer to objection and response to interrogatory no. 50. INTERROGATORY NO. 52:- Identify all persons who have testified on your behalf before the Occupational Safety and Health Administration, the National Institute of Occupational Safety and Health, any United States congressional committee, sub-committee, administrative hearing or investigative proceeding on the subjects of the human health consequences of exposure to asbestos dusts, fibers and/or products and the setting, modification, feasibility and acceptance of allegedly safe or proper levels of exposure to said asbestos and asbestos products. RESPONSE NO. 52: This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not -46- AFFIDAVIT STATE OF OHIO COUNTY OF LUCAS ) SS: ) * M. F. MCCARTHY, being duly sworn according to law, deposes and says that he is an Assistant Secretary of OwensIllinois, Inc., a defendant herein? that as such he is authorized to make an Affidavit on its behalf? and that the facts set forth in the foregoing DEFENDANT, OWENS-ILLINOIS, INC.'S ANSWERS TO INTERROGATORIES, are true and correct to the best of his knowledge, information and belief. m. f. McCarthy SWORN TO and subscribed before me this cr / day 1987 Notary Public My Commission Expires: A McNEAH ZrT/ * 0h, W Jan- 199Q