Document BR31avNgYeRgZzVJYEmpXO0jk

8-92 WED 13 = 10 T h ^ Wor-d C ^ t `afV3 =>* ifjtf.' t-KOM WRIGHT ROBINSON RIC. CMImio fWavvjtOficnpco R _ 05 PAGE. 01 <1 to J. Konxen T/li subject Interrogatories Received in Asbestos Litigation Intra-company correspondence fwm K* 0. Gould - T/26 . . February 12, 1981 date cc.* 1 have recently received a set of Interrogatories .from Texas in the asbestos litigation which raises Questions concerning silica and health hazards resulting frost silica produced from the Kaylo product* There are three questions that I would like to have you provide answers to me for: . 1. Did the asbestos-containing Kaylo contain silica* and if *o^ what grade? 2 am aware that Kaylo contained calcium silicate, but I do not know whether or not this is the same mineral as is commonly referred to as silica* 2* The plaintiff's interrogatory reads thus* "Assuming that you stated that the Kaylo produet has as one of its ingredients silica, please state under what circumstances these particles could be inhaled by human beings? If these particles are not capable of being inhaled by human beings* please state why not?" 3. The plaintiff's interrogatory reads thus, "Has Owens-Corning Flberglas Corporation done any research whatsoever et aRy of its facilities or at any of its locations wherever located in the world as to the danger to humans who come in contact with or inhale silica particles?4 2 appreciate any help you can provide to me in responding to these interrogatories, K0G;Uc:O2-ft23 02- oo4> /Z-7*?