Document DvXpnGarJLn3ZmBr0Z0QQVrk5

FILE NAME: Kaiser Gypsum (KG) DATE: 1986 DOC#: KG043 DOCUMENT DESCRIPTION: Legal - Supplemental Responses to Interrogatories ... J) I \ 1 PATRICK J. HAGAN, ESQ. EDWARD M. PRICE, ESQ. 2 KINCAID, GIANUNZIO, CAUDLE & HUBERT A Professional Corporation 3 200 Webster Street Oakland, California 94607-3789 4 Telephone: (415) 465-5212 5 Attorneys for Defendants KAISER CEMENT CORPORATION and 6 KAISER GYPSUM COMPANY, INC. 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO 10 DEPARTMENT FIVE 11 12 IN RE: 13 COMPLEX ASBESTOS LITIGATION 14 15 ) NO. 828684 ) KAISER CEMENT CORPORATION AND ) KAISER GYPSUM COMPANY, INC.'S ) SUPPLEMENTAL RESPONSES TO ) PLAINTIFFS' STANDARD ) INTERROGATORIES TO DEFENDANTS 16 17 PROPOUNDING PARTY: Plaintiffs 18 RESPONDING PARTY: 19 20 SET: Defendants, KAISER CEMENT CORPORATION and KAISER GYPSUM COMPANY, INC. Standard 21 DATE: May 6, 1986 22 COME NOW defendants, KAISER CEMENT CORPORATION (hereinafter 23 "KAISER CEMENT") and KAISER GYPSUM COMPANY, INC. (hereinafter 24 "KAISER GYPSUM") and provide supplemental answers to the standard 25 interrogatories propounded by plaintiffs as follows: 26 DATED : May 6, 1986 27 28 OF ZIO, KINCAID, O, c a u d Q: & HUBERT By______ X EDWARD M. PRICE Attorneys for Defendants KAISER CEMENT CORPORATION and KAISER GYPSUM COMPANY, INC. 1 SUPPLEMENTAL ANSWER NO. 6 2 Kaiser Cement and Kaiser Gypsum incorporate herein their 3 objections and response previously given to this interrogatory and 4 its subparts. By way of further response/ Kaiser Cement states 5 that some of its business records may be located at its manu 6 facturing plants located at Permanente and Cushenbury/ California. 7 However/ those records so located relate primarily to plant 8 operations and industrial relations matters rather than to sales 9 or other subjects relevant to asbestos litigation. 10 SUPPLEMENTAL ANSWER NO. 10(b) 11 (i) and (ii) The records of Kaiser Cement and Kaiser Gypsum 12 Company concerning the test or experimental marketing of its 13 asbestos-containing products are incomplete so that these 14 defendants are unable to respond to this interrogatory with the 15 specificity reguired. However, based on information presently 16 available, these defendants state that, in general, their asbestos- 17 containing products were marketed on a test or experimental basis __ 18 for anywhere from a few months to a year before being marketed 19 generally. Additionally, some asbestos-containing products of 20 these defendants underwent field testing prior to general 21 marketing. Records presently available indicate that Kaiser 22 Gypsum's wallboard accessory products and possibly Kaiser Cement's 23 plastic cement and masonry cement underwent such field testing 24 prior to being marketed generally. 25 SUPPLEMENTAL ANSWER NO. 10(d) 26 Kaiser Cement and Kaiser Gypsum incorporate herein their 27 objections and response previously given to this interrogatory 28 subpart. By way of further response, these defendants state that 5F :io, - 2- " J: \ * . , ' 1 the percentages of asbestos shown on Exhibit A attached 2 hereto are percentages by weight as contained in the products 3 at the time of sale. Those products intended to be mixed with sand 4 and/or water, such as plastic cement, masonry cement and powdered 5 wallboard accessory or texture paint products, would have a lower percentage of asbestos at the time of application which 7 would vary depending upon the quantity of sand and/or water mixed 8 in. 9 SUPPLEMENTAL ANSWER NO. 10(e) 10 Kaiser Cement and Kaiser Gypsum incorporate herein their 11 response previously given to this interrogatory subpart. By way 12 of further response, these defendants state that the best source 13 of information concerning the physical appearance and nature of 14 their asbestos-containing products is existing product brochures 15 and/or other literature depicting the products a n d `packaging 16 thereof. Such documents are available for inspection and/or 17 copying at a mutually agreeable time at or near the corporate - 18 headquarters of these defendants in Oakland, California. 19 SUPPLEMENTAL ANSWER NO. 10(g) 20 Kaiser Cement and Kaiser Gypsum incorporate herein their 21 objections previously given to this interrogatory subpart. By way 22 of further response, these defendants--state that they presently 23 have no knowledge of any of their asbestos-containing products 24 ever being on the U. S. Government's 1Qualified Products List . 25 Further, the best source of the information being sought in this 26 subpart would be the United States Government. 27 SUPPLEMENTAL ANSWER NO. 10(h) 28 Kaiser Cement and Kaiser Gypsum incorporate herein their DF :io, 3- 1 responses previously given to this interrogatory subpart. By way 2 of further response, these defendants state that, as a result of 3 their document retention programs, information concerning the time 4 periods that raw asbestos fiber was supplied by the entities 5 identified herein is not available and these defendants cannot 6 respond to this subpart with the specificity required. 7 SUPPLEMENTAL ANSWER NO. 1 0 (i) 8 Kaiser Cement and Kaiser Gypsum amend their response pre 9 viously given to this interrogatory subpart as follows: 10 Yes 11 (i) These answering defendants are unable to respond to this 12 subpart with the specificity required because most of their sales 13 records predating 1968 no longer exist or cannot be located and, 14 as to those sales records which presently do exist, a complete 15 review of them has not been performed by these defendants. How 16 ever, on the basis of their partial review of existing sales 17 records, as well as information obtained from former and present 18 employees, these defendants state that their asbestos-containing 19 products were primarily sold to contracting or construction 20 companies and to building materials dealers. Such sales may also 21 have been made to manufacturing entities and to companies using 22 the products for their own construction projects. These 23 defendants have no information whatsoever indicating that they 24 sold asbestos-containing products to any shipyards. 25 (ii) The inclusive dates that the asbestos-containing 26 products of these defendants were generally marketed, as well as 27 the trade name or brand name of each such asbestos-containing 28 product sold by them are shown on Exhibit "A" attached hereto, DUFO, - 4- 1 which is a revised version of Exhibit "A" attached to these 2 defendants' initial responses to these interrogatories. 3 (iii) Yes. Existing sales records of these defendants are 4 located at 100 Webster Street, Oakland, California, under the 5 general custody of Cliff W. Rogers, Manager, Administrative 6 Services, Kaiser Cement Corporation, 300 Lakeside Drive, Oakland, 7 California. Said records are in the physical custody of these 8 defendants' attorneys of record. 9 SUPPLEMENTAL ANSWER NO. 1 0 (j) 10 Kaiser Cement and Kaiser Gypsum amend their response pre 11 viously given to this interrogatory subpart as follows: 12 The existing sales records of these defendants are stored in 13 approximately 600 Bekins boxes which are organized by year and 14 consist of invoices, sales orders, bills of lading and other 15 documents. Sales orders are in numerical sequence by year. The 16 invoices are also arranged alphabetically by customer. Records 17 pertaining to sales of asbestos-containing products are not 18 separated from those of non-asbestos products. See response to 19 Interrogatory 1 0 (i)(iii) for the location and custodian of these 20 records. Existing sales records of these defendants are 21 available for inspection by plaintiffs' counsel at a mutually 22 agreeable time at 100 Webster Street, Oakland, California at 23 plaintiffs' expense. 24 SUPPLEMENTAL ANSWER NO. 11 25 Kaiser Cement and Kaiser Gypsum amend their response pre 26 viously given to this interrogatory as follows: 27 To the extent that the purchasers of the asbestos-containing 28 products of these defendants may be deemed to be distributors >F :io, - 5- " y ^ . 1 of such products, these defendants have no knowledge or informatior 2 that such purchasers were "exclusive distributorships". 3 SUPPLEMENTAL ANSWER NO. 13 4 Kaiser Cement and Kaiser Gypsum amend their response pre 5 viously given to this interrogatory by stating that neither Kaiser 6 Gypsum nor Kaiser Cement have any knowledge that they rebranded 7 asbestos-containing products and/or materials imported, manu 8 factured, sold, distributed and/or supplied by another company. 9 Both Kaiser Gypsum and Kaiser Cement are continuing their 10 investigation and discovery in this regard. 11 SUPPLEMENTAL ANSWER NO. 15 12 Kaiser Cement and Kaiser Gypsum amend their response pre 13 viously given to this interrogatory as followsi 14 Yes. Beginning in 1972, warning labels were placed on 15 containers of the asbestos-containing products manufactured by . 16 both Kaiser Cement and Kaiser Gypsum described on Exhibit "A" 17 attached hereto except Kaiser Gypsum "Null-A-Fire" Type X ^ 18 Wallboard. 19 (a) Initially, these labels were 4" x 8" in size. Records 20 currently available indicate that the labels had yellow back 21 grounds with red letters. They were affixed to the package or 22 container of the product by adhesive. Later, as new packaging 23 and containers were purchased, the labels were printed onto the 24 outside of the package or container and are believed to have 25 been the same color or colors as the package/container or the 26 printing thereon. The warning labels were prominently displayed 27 on the side of each can or bag or product; however, these 28 )F defendants' records are not sufficient to enable them to describe :io, - 6- 1 the exact location of every warning label on each of their 2 asbestos-containing products. Labels were not placed on the 3 products themselves, since most of the products come in the 4 form of either powder or paste. The warning label read as 5 follows: "Caution: Contains asbestos fiber; avoid breathing 6 dust; breathing dust may cause serious bodily harm". (See 7 Exhibit "B" attached to these defendants' initial responses to 8 these interrogatories.) 9 (b) and (c) Kaiser Cement and Kaiser Gypsum incorporate 10 herein their responses previously given to these subparts. 11 SUPPLEMENTAL ANSWER NO. 19 12 Kaiser Cement and Kaiser Gypsum amend their prior response 13 to this interrogatory as follows: 14 (a)-(e) On August 1, 1952, Kaiser Cement purchased for cash 15 from Henry J. Kaiser Company the business and certain assets of. 16 the Gypsum division of that company which engaged in the manu 17 facture of wallboard and related gypsum products. As part of 18 that acquisition Kaiser Cement acquired the manufacturing rights 19 for some joint compound and texture paint products which may have 20 contained small amounts of asbestos at the time of that 21 acquisition and contained asbestos for limited periods of time 22 thereafter. However, the existing business records of Kaiser 23 Cement are incomplete and insufficient to enable it to determine 24 w i t h ,certainty whether such products did contain asbestos at the 25 time of the said acquisition or to provide the specific informa 26 tion requested in this interrogatory regarding such products. 27 The "terms of purchase and sale agreement" concerning said 28 acquisition are described hereinabove. Kaiser Cement will make a )F :io, - 7- 1 copy of the sales agreement with Henry J . Kaiser Company 2 available for inspection by plaintiffs' counsel at a mutually 3 agreeable time and place. 4 The "manufacturing facilities" acquired as part of the 5 purchase described herein consisted of two manufacturing plants 6 located at Redwood City and Long Beach, California. 7 SUPPLEMENTAL ANSWER NO. 22 8 Kaiser Cement and Kaiser Gypsum amend their response pre 9 viously given to this interrogatory as follows: 10 On the basis of these defendants' partial review of their 11 existing sales records, as well as information obtained from 12 present and former employees, neither Kaiser Cement nor Kaiser 13 Gypsum have any knowledge of having sold, shipped or distributed U any asbestos-containing products to the General Services 15 Administration. . 16 17 - 8- >. ] 1 VERIFICATION 2 3 The undersigned says: 4 I am an officer, to wit: Assistant Secretary of defendants, 5 KAISER CEMENT CORPORATION and KAISER GYPSUM COMPANY, INC., herein; The foregoing document(s) is/are true of my own knowledge, 7 except as to the matters which are therein stated on my informa 8 tion and belief, and as to those matters, I believe them to be 9 true. 10 I declare under penalty of perjury that' the foregoing is 11 true and correct. 12 Executed this / Vy7\ day of Ma _______________r 19_86___ / at 13 Oakland, California. 14 15 DONNA ANDERSON 16 17 18 19 20 21 22 23 24 25 26 27 28 OF Zio, 1 PROOF OF SERVICE BY MAIL 2 (C.C.P. 1013a, 2015.5) 3 I, the undersigned, declare: 4 That I am employed in the City of Oakland, County of Alameda, State of California; that I am over the age of 18 years and 5 not a party to the within cause; that my business address is 200 Webster Street, 2nd Floor, Oakland, California 94607-3789. 6 7 That on the day of ______ May______________ , 1986, I served the within: 8 KAISER CEMENT CORPORATION AND KAISER GYPSUM COMPANY, INC.'S 9 SUPPLEMENTAL RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES TO DEFENDANTS 10 11 12 13 on the parties in said cause by placing a true copy of each document enclosed in a sealed envelope with postage thereon 14 fully prepaid, in the United States mail at Oakland, California, addressed as follows: 15 16 SEE ATTACHED MAILING LIST 17 18 19 20 21 22 23 I declare under penalty of perjury that the foregoing is true and correct. 24 Executed at Oakland, California this 15th day of M a y _____________ , 1986. 25 26 n /)Q -PAM UNDERKOFFLER 27 Declarant 28 )F 10. \ J m o n t COMPANY, INC. Wild & Jeffrey 1700 Montgomery Street San Francisco, CA 94111 COMBUSTION ENGINEERING/ DEVCON CORP. Knox, Ricksen, et al. One Kaiser Plaza, #850 Oakland, CA 94612 CROWN CORK & SEAL Mark H. Rosenthal, Esq. 3 Embarcadero Center Suite 670 San Francisco, CA 94111 w I i I i GATKE CORPORATION Bennett, Samuelson, et al | 332 - 19th Street ! Oakland, CA 94612 II , GENERAL DYNAMICS ; Pelavin, Norberg, et al. 2 Embarcadero Center ' Suite 2360 | San Francisco, CA 94111 i | GENERAL MOTORS I Parichan, Renberg, et al. i 2350 West Shaw, #154 Fresno, CA 93794 M. H. DETRICK CO./EMPIRE ACE INSULATION/J.P. STE\ Carroll, Burdick, One Ecker Bldg. Ecker & Stevenson San Francisco, CA sret al. MREMONT CORPORATION Armour, St. John, et al. 505 Sansome Street San Francisco, CA 94111 I MEDLLOYD LYNEN B.V./CSEJ ' LAND ! Graham & James i One Maritime Plaza, #30( j San Francisco, CA 94111 EASTBAY GASKET Whitehorn & Ravazzini 2150 Franklin Street Suite 571 Oakland, CA 94612 GEORGIA PACIFIC CORP. Marron, Reid & Sheehy 601 California Street 12th Floor San Francisco, CA 94108 NICOLET St. Clair, Zappettini, t 235 Montgomery, #635 San Francisco, CA 94104 7ERTITE CORP. iddick, Candland & Conti i .43 Danville Blvd.,#100 j P. 0. Box 1057 j Alamo, CA 94507 I! FIRESTONE TIRE & RUBBER/ j BONDEX INTERNATIONAL Ericksen, Arbuthnot, et al Pier 1-1/2 Embarcadero San Francisco, CA 94111 INTERNATIONAL HARVESTER Harrington, Foxx, et al. 611 W. Sixth Street 9th Floor Los Angeles, CA 90017 JANOS INDUSTRIAL INSULATION Meadows, Dorris, et al. 425 California, #170 San Francisco, CA 94104 OWENS-CORNING FIBERGLAS Popelka, Allard, et a l . One Almadn Blvd., #800 San Jose, CA 95115 PPG INDUSTRIES Bishop, Barry, 465 California 11th Floor San Francisco, Howe, et Street CA 94104 FORD MOTOR COMPANY Barfield, Barfield, et al. One California Street Suite 3125 San Francisco, CA 94111 JOHN-CRANE HOUDAILLE, Mackenroth, Seley, et 2221 Hurley Way P. O. Box 255800 Sacramento, CA 95825 INC. al. PLANT INSULATION CO. Martin, Ryan, et al. One Kaiser Plaza Oakland, CA 94612 FOSTER-WHEELER CORP. James E. Martin, Esq. 450 Sansome Street Suite 1310 San Francisco, CA 94111 GAF/RUBEROID M C u t c h en, Doyle, et al ^ ' Narcadero Center ! /raneis co, CA 94111 KAISER ALUMINUM/GEORGIA PACIFIC/KAISER STEEL/ BECHTEL Thelen, Marrin, et al. 2 Embarcadero Center San Francisco, CA 94111 LAKE ASBESTOS ASARCO Pettit & Martin 101 California Street San Francisco, CA 94111 RAYMARK INDUSTRIES Fisher & Hurst 4 Embarcadero Center 25th Floor San Francisco, CA 94111 RICH-TEX Tolpegin, Imai 235 Montgomery San Francisco, & Tadloc] St., #95( CA 94104 GARLOCK INDUSTRIES Glaspy, Elliott, et al. 201 N. Civic Dr. , #245 r.T _ i . ____ _ . . ROCK WOOL MANUFACTURING Branson, Fitzgerald, et al 500 Allerton Street RYDER INDUSTRIES O'Connor, Cohn, et al. P. O. Box 26690 JHlSPY OIL/BORG-WARNER IcGlynn, McLorg, et al. 50 Montgomery St., #300 Jan Francisco, CA 94133 SOUTHERN PACIFIC TRANSP. Corrigan & Whitney )ne Market Plaza, #200 Jan Francisco, CA 94105 Halley, Cornell & Lynch 50 California Street 25th Floor San Francisco, CA 94111 BENJAMIN FOSTER CO. Sheppard, Mullin, et al. 4 Embarcadero Center 17th Floor San Francisco, CA 94111- i McCarthy, Johnson & Miller: BERG-PHILLIPS 22 Second St., 7th Floor 1 Debevec, Jackson, et al. San Francisco, CA 94105 : 479 Mason S t . , #325 Vacaville, CA 95688 5YNKOLOID Jranson, Fitzgerald, et 500 Allerton Street Redwood City, CA 94063 i ! al.: : McQuaid, Bedford P. O. Box 2109 Novato, CA 94948 & Brayton BETHLEHEM STEEL Parrish & Moriarty 1750 Van Ness Avenue San Francisco, CA 94109 7HIOKOL CORPORATION ledsoe, Cathcart, et al. >50 California, #2828 Jan Francisco, CA 94108 -H" ' `E INSULATION CO. r ; E. Cusik, Esq. 120'J.- Wilshire Blvd. jos Angeles,, CA 90010 J.S. STEEL/GENERAL VENEER/ AMERICAN ASBESTOS TEXTILE/ IUXLEY jO W , Ball & Lynch >01 California, 21st Floor Jan Francisco, CA 94121 Jrown & Finney )ne Maritime Plaza, #1500 ilcoa Bldg. Jan Francisco, CA 94111 Jarlson & Robinson .709 Webster Street iakland, CA 94612 Jartwright, Sucherman, etal 0^-- California St., #2600 Ja sancisco, CA 94111 ack K. Clapper, Esq. .00 Shoreline Highway bldg. B, Suite 300 1 1 1 ! \ 7 p i l l o \ r r* tv n / i n n Stemple & Boyajian 1526 Tennessee Street Vallejo, CA 94590 Herron & Herron 600 Montgomery Street 33rd Floor San Francisco, CA 94111 ABEX Sullivan, Roche & Johnson 220 Bush Street San Francisco, CA 94104 AMATEX CORP./KEASBY & MATTISON CO. Stevens & Drummond 1910 Olympic Blvd., #130 Walnut Creek, CA 94596 ASBESTOS CORPORATION/ JOHNSON BROTHERS/ARCO Jedeikin, Connor & Green 445 Washington Street San Francisco, CA 94111 BABCOCK & WILCOX Anderson, Galloway, et al. 2201 Broadway, #319 Oakland, CA 94612 BENDIX CORPORATION Gordon & Rees 601 Montgomery BIGELOW-LIPTAK CO. Cooper, White & Cooper 101 California Street 16th Floor San Francisco, CA 94111 CARLISLE CORP./HAMILTON MATERIALS Archer & McComas P. O. Box 8035 Walnut Creek, CA 94596 CASSIAR MINING CORP. ' BRINCO MINING LIMITED Stark, Stewart, et al. 1999 Harrison S t . , #1300 Oakland, CA 94612 UNION CARBIDE Gibson, Dunn & Crutcher One Almaden Blvd., #1000 San Jose, CA 95115 UNIROYAL McNamara, Houston, et al. P. O. Box 5288 Walnut Creek, CA 94596 WAGNER ELECTRIC/MC GRAW EDISON Ream, Train, et al. 755 Page Mill Place, #131 Palo Alto, CA 94304 WESTERN MAC ARTHUR Hardin, Cook, et a l . One Kaiser Plaza, #2300 J.'^1? 'GRACE/ ZONOLITE :iapp, Moroney, et al. i05 Hamilton Avenue >alo Alto, CA 94301 .EAR SIEGLER/SOUTHERN 'ACIFIC/CHRYSLER Crosby, Heafey, et al. .939 Harrison Street )akland, CA 94612 MENS-ILLINOIS iorgenstein, Ladd, et al .01 Market Street ith Floor !an Francisco, CA 94111 PRODUCT/TRADE NAME Joint and Topping Compounds: Kaiser Cypsum Joint Compound (Dry Powder) r\ Kaiser Cypsum Finishing (Topping) Compound Kaiser Gypsum One-Day Joint Compound Kaiser Gypsum ThreePurpose Compound Kaiser Gypsum Pre-Mix Joint Compound Kaiser Gypsum Pre-Mix Finishing Topping Compound Kaiser Gypsum Pre-Mix Dual Purpose Joint Compound PURPOSE OF PRODUCT DESCRIPTION OF PRODUCT Used to fill gypsum board joints, embed joint reinforcing tape, finish joints and to cover and finish nallheads and metal cornerbead* White to off-white powder. Packaged and sold in sacks of 10 and 25 lbs. and in 5 and 18 lb boxes. Used to top and finish n gypsum board joints. Used to fill gypsum board joints, embed joint reinforcing tape, finish joints and to cover and finish nallhead and metal cornerbead. Used to tape, top and finish gypsum board joints, nallheads and metal cornerbead. S M Used to fill gypsum board joints, embed Joint reinforcing tape, finish joints and to cover and finish nallheads and cornerbead. White to off-white or light buff colored paste. Packaged and sold in bucketB ranging from 12 to 62 lbs. and in cartons of 5 to 50 lbs. Used to top and finish gypsum board joints. Used to fill gypsum board joints, embed joint reinforcing tape, finish joints1 and to cover and finish nallheads and metal cornerbead. L 1ST OF i'RODoC'J S cONTAlNINC A: Manufactured by KAXSKR GYPSUM COMPANY, IN COMPOSITION % ASBESTOS (Approx.) Primarily finely ground materials including casein, clay, talcs, limestone and mica. The asbestos used in this product was chrysotile. 6,8-10.4% 3.7-11% 3.3-3.4% 4.8-4.9% 1.5-6% 0.9-2% 1.5-6% PRODUCT/TRADE N.'-.M Texture Paints; Kaiser Gypuum Cover Tex Wall Texture PURPOSE OF PRODUCT DESCRIPTION OF PRODUCT COMPOSITION X ASBESTOS (Approx.) Used to produce tex ture effects over gypsum wallboard surfaces. White to off-white powder. Packaged and sold In 50-lb. sacks. Primarily casein, lime stone and mica. The asbestos used In this product was chrysotlle. 4-8X alser Gypsum K-Spray Celling Texture Celling Board; Kaiser Gypsum Mineral Flbreboard - UL Fire Rated (Underwriters' Laboratories, Inc. design) Used to produce tex ture over gypsum wallboard or Interior concrete ceilings. White powder with polystyrene aggre gate. Packaged and sold in 32-lb. sacks. a* Used for acoustical celling tile and lay in board and partition sound-deadening board. 1/2" or 5/8" thick by 12" or 24" wide by 12", 24" or 48" long sheets, with face side white or colored and with perforated or fissured design for acoustical treatment. Packaged and sold in boxes of various quantities. Primarily mineral wool and various wood fibers, clays and starch. The asbestos used In this product was chrysotlle. 1.3-6.8% 1.6% lhoard: Kaiser Gypsum "Null-A-Fire1 Type X Wallboard Used for interior walls and ceilings to provide fire resistance. $ 1 / 2 " or 5/8" thick by 4' wide by 8' or 12' long sheets, covered with grey or manila colored paper. Two sheets were bound together for purposes of sale. Primarily gypsum, plus additives of glass fiber, paper fiber and vermlculite. The vermlculite contained two lOOths of 1% tremolite (a type of asbestos) which was considered an impurity and was totally encapsulated In the vermlculite. 0 .02% (1) The information In the "Years Containing Asbestos" column pertains to the company as a whole -- the individual plants 1 Where Manufactured" column did not necessarily manufacture each product during all of the stated years. Similarly, the the "Region of Distribution" column did not necessarily correspond to all of the stated years. For example, the Jackso , plants were not built until 1964 and 1965, respectively; thus, distribution of products on the east coast did not comme . after the plants were completed. 5/8 C UKA LIST OF PRODUCTS CONTAINING ASBESTOS * Manufactured by KAISER. CEMENT CORPORATION(D PRODUCT/TRADE NAME Kaiser Permanente Plastic Gun Cement '.er Permanente Plastic Cement (Hand) Kaiser Permanente Masonry Cement PURPOSE OF PRODUCT DESCRIPTION OF PRODUCT COMPOSITION % ASBESTOS (Approx.) Used to make stucco for the exterior of houses and other buildings (applied by gun with a plaster ing machine). Grey colored powder. Packaged and sold in sacks of varying sizes and also in bulk.'. Used to make stucco M for the exterior of houses and other buildings (applied manually with a trowel). Used in masonry mortar in building construc tion. Grey colored powder. Packaged and sold in sacks of varying sizes. Not sold in bulk. Approximately 96% portland cement plus plasticizing and air-entraining agents. The asbestos used in this product was chrysotlle. 2-5% (3) 1-5% (Perm. ) 1% (Custi.)^ Combination of Portland cement, air-entraining ad ditives and supplementary materials selected for their ability to impart workability, plasticity and water retention. The as bestos used in this pro duct was chrysotile. 0.4% (3) (1)i/>K-a.i' ser Cement Corporation was known as Permanente Cement Company from 1939-64 and as Kaiser Cement & Gypsum Corporation fro ( 2 ) 1 : information in the "Years Containing Asbestos" column pertains to the company as a whole -- the individual plants liste Where Manufactured" column did not necessarily manufacture each product during all of the stated years. Similarly, the are the "Region of Distribution" column did not necessarily correspond to all of the stated years. (3) Contractors typically mixed these products with three to five parts by weight of sand so the % asbestos was less than 1% in actually applied. 5/86.' DMA 7192L