Document OEemRex3D0qeDYr5Kb4V5E1DK

IL050a.ASB 08/21/90 STATE OF ILLINOIS IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT COUNTY OF MC CLEAN DELMAR ASLENE AND MARY ALSENE, ) ) Plaintiffs, ) ) vs. ) ARMSTRONG WORLD INDUSTRIES, ) INC., et al., ) ) Defendants. ) -----------------------------------------------------------------) ) No. 89 L141 DEFENDANT, OWENS-ILLINOIS, INC'S RESPONSES TO PLAINTIFFS' FIRST REQUEST FOR DISCOVERY TO DEFENDANT. TT.LTNOIS. INC. PRELIMINARY STATEMENT Some of the events which may be relevant to the matters inquired about by Plaintiffs' Request for Production apparently occurred more than thirty-five years ago. In addition, effective April 30, 1958, Owens-Illinois, Inc. disposed of the business involved in this action by yay of sale of that business to OwensComing 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 asbestos-containing products. As a result of the foregoing factors, investigations to date indicate that at least some documents which relate to matters inquired about by these re quests 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 investiga tion in an attempt to locate, confirm the transfer of, or confirm the absence of, such documents and is also engaged in a continu ing investigation into the matters inquired about in these requests. Unless otherwise stated in an answer to a specific request, the answers set out hereinafter are limited to the period during which Owens-Illinois, Inc. manufactured asbestoscontaining 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 Owens-Illinois, 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 request 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. Furthermore, Owens-Illinois, Inc. objects to the instruc tions and definitions supplied by plaintiffs with regard to these requests, 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 consti tute an unreasonable expansion of the requests themselves. Owens-Illinois, Inc. therefore gives notice that it does not consider itself bound by the instructions and definitions pro 2 pounded by plaintiffs, and instead shall answer the requests in a manner consistent with a normal understanding of the language used in the requests and to the extent necessary to fairly and fully answer the requests for production. REQUEST NO. 1. All witness statements of any sort, whether signed or unsigned (together with all documents purporting to reflect the same), and a list of those statements for which a privilege from disclosure is claimed. RESPONSE NO. 1. Neither this defendant nor its counsel is in possession of materials referred to in this request. This defendant reserves the right to supplement its response at any time in the future. REQUEST NO. 2. All data as to the physical or mental condition of Delmar Alsene, excluding all documents provided you by plaintiffs' counsel and excluding all documents, copies of which have already been provided plaintiffs' counsel through formal discovery. RESPONSE NO. 2. Neither this defendant nor its counsel is in possession of materials referred to in this request. This defendant reserves the right to supplement its response at any time in the future. REQUEST NO. Alsene. 3. All photographs or sketches of Delmar RESPONSE NO. 3. This defendant has found no documents responsive to this request. REQUEST NO. 4. All photographs, models, sketches or diagrams of any of the sites at which Delmar Alsene worked. 3 RESPONSE NO. 4. Neither this defendant nor its counsel is in possession of materials referred to in this request. This defendant reserves the right to.supplement its response at any time in the future. REQUEST NO. 5. All photographs, models, sketches or diagrams of any of the products involved in this litigation. RESPONSE NO. 5. Refer to Exhibit I which may contain information relevant to the subject matter of this request. REQUEST NO. 6. All pamphlets, brochures or other documents prepared, distributed or utilized by defendant to advertise or promote asbestos-containing products during the 1950's or 1960's. RESPONSE NO. 6. Refer to Exhibit I. REQUEST NO. 7. Each document authored by an employee of Defendant in the course of his employment, dealing in whole or in part with the consequences of exposure to asbestos. RESPONSE NO. 7. This defendant objects to this request as being unintelligible, overly broad, burdensome and oppressive, not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. REQUEST NO. 8. All medical records of those present or former employees of defendant who have filed claims for worker's compensation or occupational disease benefits alleging an injury or disease from exposure to asbestos and all personnel and employment records which evidence or reflect the duration, quantity and quality of his or her exposure to asbestos while employed by defendant. 4 RESPONSE NO. 8. This defendant objects to this request on the basis that it seeks information .which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this defendant engaged in the manufacture, sale and distribution of its asbestos-containing products. Without waiving the above objection, 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. REQUEST NO. 9. Each written warning, caution or other document which was intended by defendant to reach those persons who would breathe or ingest the asbestos from asbestos- containing products manufactured and/or sold by defendant. RESPONSE NO. 9. This defendant 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 request. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm. REQUEST NO. 10. A transcript (including exhibits) of each instance where an employee of Defendant testified at deposition or trial in asbestos disease litigation. RESPONSE NO. 10. This defendant objects to this request as being vague, ambiguous, irrelevant, overly broad, burdensome and oppressive, not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. 5 REQUEST HO. 11. A transcript (including exhibits) of each instance where an individual whom defendant listed, retained or called as an expert witness, testified at deposition or trial in asbestos disease litigation. RESPONSE NO. 11. This defendant objects to this request as being vague, ambiguous, irrelevant, overly broad, burdensome and oppressive, not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. REQUEST NO. 12. All agreements to which defendant is a party and which relate to the manner in which this case shall be evaluated, delayed or defended including, but not limited to, all Wellington agreements and all documents exchanged by the parties thereto. RESPONSE NO. 12. This defendant objects to this request on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. REQUEST NO. 13. Defendant's last three annual reports. RESPONSE NO. 13. This defendant objects to this request on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. REQUEST NO. 14. All reports, notes, letters, memoranda, or other documents showing or purporting to show what 6 Delmar Alsene knew about the relationship between asbestos dust and health. RESPONSE NO. 14. This defendant objects to this request in that it seeks information protected by the attorney- client and/or the attorney work-product privilege. REQUEST NO. 15. All documents reflecting the taking or testing of any dust counts, air samplings, or other study of the atmosphere of Illinois Power Company in Bloomington, Illinois, and/or Caterpillar Tractor Co. at various locations in Central Illinois from the time of its opening until the present time. RESPONSE NO. 15. 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. REQUEST NO. 16. Each policy of insurance, including all excess and umbrella policies, which may construed to provide coverage for the claim stated in the Complaint. RESPONSE NO. 16. This defendant objects to this request on the ground that it seeks irrelevant and immaterial information which is not reasonably calculated to lead to the discovery of admissible evidence. Expressly reserving and without waiving its objections, and subject to them, this defendant states that the issues surrounding its insurance coverage for asbestos claims are complex. Because of disputes over possible insurance coverage, this defendant has engaged in litigation against certain insurance carriers which may provide coverage for asbestos claims. One such lawsuit resulted in a decision of the United States District Court of the District of 7 Columbia in Owens-Illinois. Inc, v. Aetna Casualty and Surety Company. 597 F.Supp. 1515 (D.D.C. 1984). The litigation between this defendant and Aetna Casualty and Surety Co. has been settled. The terms and conditions of the settlement agreement are confidential, and as a consequence, the parties are precluded from disclosing the terms or contents of the agreement. Litigation with other insurance carriers is ongoing. REQUEST HO. 17. All documents reflecting payments or agreements for payments made under any of the policies described in (16) which the carrier claims or could claim as full or partial exhaustion of the policy limits or otherwise affect the amount of coverage available in this case. RESPONSE NO. 17. This defendant objects to this request on the ground that it seeks irrelevant and immaterial information which is not reasonably calculated to lead to the discovery of admissible evidence. Expressly reserving and without waiving its objections, and subject to them, this defendant states that the issues surrounding its insurance coverage for asbestos claims are complex. Because of disputes over possible insurance coverage, this defendant has engaged in litigation against certain insurance carriers which may provide coverage for asbestos claims. One such lawsuit resulted in a decision of the United States District Court of the District of Columbia in Owens-Illinois. Inc, v. Aetna Casualty and Surety Company 597 F.Supp. 1515 (D.D.C. 1984). The litigation between this defendant and Aetna Casualty and Surety Co. has been settled. The terms and conditions of the settlement agreement are confidential, and as a consequence, the parties are precluded from disclosing the terms or contents of the agreement. Litigation with other insurance carriers is ongoing. 8 REQUEST NO. 18. An affidavit stating whether production is complete according to the knowledge of the Defendant and the Defendant's insurance carrier, attorneys, agents and employees. RESPONSE NO. 18. 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. 9 AFFIDAVIT STATE OF OHIO ) )SS: COUNTY OF LUCAS ) A. H. SMITH, being duly sworn according to law, deposes and says that he is an Assistant Secretary of Owens- Illinois, Inc., a defendant herein; that as such he is authorized to make an Affidavit on its behalf; and that the facts set forth in the foregoing DEFEN DANT, OWENS-ILLINOIS, INC.'S RESPONSES TO REQUEST FOR PRODUCTION, are true and correct to the best of his knowledge, information and belief. ff- // A. H. SMITH SWORN TO and subscribed before me this c cday My Commission Expires: SHIRLEY J. SROCZYNSKI Notary Public, State of Ohio My Commission Expires Oc. 15, J 992 EXHIBIT I A NEW HEAT INSULATION WITH REMARKABLE COMBINATION OF ADVANTAGES.... Kaylo Heat Insulating Block a new type of lightweight mineral i sulation that is tjfiritnt eoough to I used at ordinary room tempcrarur and rtiistsnt enough to perform effe lively up to 1200 F. Few new products of aoy kind ha been so thoroughly researched befo being placed on the market. Kay Heat Insulating Block is the achic ment of many years' work by Ower Illinois Glass Company enginee physicists and chemists. No other material, new or old. effectively combines the most des able characteristics of the ideal hi insulation. For instance . . . LOW DENSITY Kaylo Heat Insulating Bio weighs only 11 pounds per cubic to This light weight (less than one pou to the board foot) simplifies handlii shipping and application. It grea reduces weight --an important ads tage on ships, for an example. ir iw ,J )***( *r*4tfr* hMtt< U VA. Notice the clean, straight edg on these insulated precipitator h< pers. Applicators find it easy to do t. kind of work with Kaylo Heat Insul ing Block because they ire so eisv cut and yet they have a .mely hi flexural strength. The * s ibo' e t hoppers are also insulated nh kn Heat Insulating Block. OVV THERMAL CONDUCTIVITY The coefficient of conductivity, or K' . of Kaylo Heat Insulating Block, s iwn on the chart on page four, i. it among the most efficient inulations for medium high temperaures. Its insulation value comes prinipally from its fine, interlaced cellular trucrure. These cells are so tiny and o numerous that they present a maenal surface of approximately 140 .cres 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 per'orms efficiently not only on tempera:ures in the low pressure steam and hot water range bur 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 '$ compressive strength is unu .v 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 pleaset and non-trritaring. 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% relative humidity and a temperature of 120 F., in standard tests, speci mens absorb less than l % 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 12 Thicknesses (inches) 1 I'A 2 2Vi 3 1 i Vi 2 24 5----------- Other sixes 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-- applied to the walls of a large - itator. Workmen are laying .K 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. Kaylo insulation means continuous fuel savings to 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 water temperature constaat with a minimum of power consumption. Other applications for Kaylo Hex Iniulatmg block are lilted on ihe back page. PRINCIPAL FEATURES OF KAYLO HEAT INSULATING BLOCK PHYSICAL CHARACTERISTICS AT A GLANCE After boiling for 24 hours (while wet) - :v-T~i*-- - " After headng for 24 hours. ' , - ' -A it 750* f.................. ................... .......................................... s.s\ at 1000* F....................... f...................... ............. V!......... 7.9 % * at 1200* F... ,?.... ............................................ : 9.8% After boiling for 24 hours.?;';. ..........-................. .................... -r.. 0.2 % ; - , - -- * . i.. Ta." wTV.~C,1y TTl - . * -'! v... .... .. (Convendonal Tumbling Test--Loss in weight after 10 minutes) . --Af* ' dfc"C-- -*,** ' Before heating......... ^~3)A0U-.. .1". ..^.7\........^2:2 ' ^ .W?*' Linear Shrinkage 1 it 750* F. .... ;3jjTv vv't- '......... 0.8 % atiooo*F..V/V;v;w?k..h................ ... 0.9% at 1200* F.....................V..-............../................................ 1.3% Elongation after saturation (max.)................. ............................. 0.4% ^i^i if) - .'1 ( (velum*) After 6 hours exposure in atmosphere of 120* F. and 90% Relative Humidity................................................ 0.9% 4 t l|8ke|'f 1 At 300* F. mean temperature 0.474 oEssk&irouo Heat Less, Surface Temperatures and Efficiencies... jlatiO hcat insulating iiOOt <at loss noM fur surfaces ... "3---- 3---- sd m---- BE----5RT*Mro*w, 0>**rMC. Mr Swrfoc* * Air *f L.vr -i35MS*r (*00 0*wr* nno HjAT iNluii-iNO HOC< EinotNot} on u- sutfACts Arnbt#** S*dl A*_ SO* * - -S'. Inside or outride, for large insmljF U ti-% .Sarions or smell, from 0 tq-fl.lOOVJL^* A* ^ik'. To. u... vw-- * Vr**v '" Breechings '' Hoc Air Ducts Lehrs - Autoclaves *~- Tanks ' rr ,, Towers - Ovens Furnaces *- Dryers f r. 5< Evaporators . Heat Exchangers . _ Turbines " Chilling Pits" Boilers -' Condensers... ` < ?- - Predpitaxors^ r. - v*. . j .. rLocomodves^S*; it'" - ~ SOURCIS OrjIST DATA , x'.* err - e? j.- vt-;<The dam' sfaowd^o these' pagesy' are tamponed by^hests run at various . . _,*Va. laboratories, >11 well known to the^' '_** v**JT-.r insulation industry. They arc 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. A new neq& insi WITH A REMARKABLE COMBINATION OF KAYLO HEAT INSULATING BLOCK is a new type of lightweight mineral insulation that is efficient enough to be used at ordinary room temperatures and resisunt enough to perform effectively up to 1200 F. Few new products of any kind have been so thor oughly researched before being placed on the market. Kaylo Heat Insulating Block is the achievement of many years' work by Owens-Illinois Glass Company engi neers, physicists and chemists. It combines the most desirable characteristics of the ideal heat insulation. LOW DENSITY. Kaylo Heat Insulating Block weighs only 11 pounds per cubic foot. This light weight (less than one pound to the board foot) simplifies handling, shipping and application. LOW THERMAL CONDUCTIVITY. The coefficient of conductivity, or k, of Kaylo Heat Insulating Block places it among the most efficient insulations for medium high temperatures. Its insulation value comes principally from its fine, cellular structure. These cells are so tiny and so numerous that they present a material surface of approximately 140 acres per cubic foot of insulation. Experience shows that the efficiency of Kaylo insula tion improves after exposure to service temperatures. EFFECTIVE OVER WIDE TEMPERATURE RANGE. Kaylo Heat Insulating Block performs efficiently not only on temperatures in the low pressure .steam and hot water range but on temperatures in the super heated steam range as well. One-material coverage with Kaylo insulation handles applications which often require two thicknesses of different materials. HIGH COMPRESSIVE STRENGTH. Its compressive strength is unusually high for a mineral product of such light weight. HIGH FLEXURAL STRENGTH. Its flexural strength is higher than the normal requirements for heat insula tion of this type. This strength makes for easy hand ling and application, and contributes to long service with low maintenance. NO ADDED BINDER. Kaylo insulation is an inorganic compound, containing no added binder. Its per formance characteristics, therefore, are not affected by additives, which often reduce insulating value, modify effective temperature range or otherwise limit per formance. EASY TO APPLY. Kaylo Heat Insulating Blocks are clean-cut and trim. They are easy to fit into place to Notice the dean, straight edges on these insulated pre cipitator hoppers. Applicators find it easy to work with Kaylo Heat Insulating Block because they are so easy to cut and yet have a high flexural strength. On large or small equipment, inside or out, Kaylo Heat Insulating Block performs efficiently and with a minimum of maintenance. Here it is being applied to the walls of a large precipitator. ation )VANTAGES... lake a good-looking installation. Ttww "ke*4" i leasant and non-irntaring. They can be cut, scored nd sawed with ordinary woodworking tools. Finishes hat go over 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 Insulat- ng Block absorbs little moisture from surrounding tumid air. EFFECTIVE AFTER LONG SERVICE. Kaylo Heat Insulat- ng Block remains strong, free from excessive powderng, and shows little loss in weight or shrinkage after long application to temperatures up to 1200 F. Even conventional tumbling tests, run after prolonged neating, produce relatively little crumbling or break down of the material. TYPICAL APPLICATIONS: ' .- or outside, for large installations or small, up to i. . F., use Kaylo Heat Insulating Block to insulate: Breechings Hot Air Duct Tanks Towers Dryers Evaporators Heat Exchangers Condensers Lehrs Autoclaves Ovens Furnaces Turbines Chilling Pits Boilers Precipitators Locomotives <oylo Heat Insulating Block covers both flat and curved urfaccs on the power house equipment pictured here. By mmmiiing heat loss, it saves fuel end keeps temperatures within the room at comfortable levels. physical CHARACTERISTICS .,.. Appreaiiae'aly \ 1 lb. ear CV. h. OINSITT....................................... ...................... .50 lb. *' * nisuiat SHIHOSH............. " * -----------______________ sesst*-1''" I aa lb. a' w at 730" ............................... I 25 lb. * at 1000" ................................ 117 lb. ' >a Ah.', 'bwitfio Va bo-r, I--'a --................. 7a lb. ear LOS* WSIOMT Ati.t haot*e e U h*** ........... at 7 50" ........................................ ............. at 1000" *.............................. ;;;;;................. at I 200 Attar bwl*e 14 iahar ary**!......... MttSIANCf TO ^"^av-alebtat..- 10 [Co#,vetv.ierol hitablme last-low m ............... letara ltaot.9 ' Attar haot* toe 2* ho"r* ............... at 750" *..................................... ............. at 1000* *....................................... ......... at I 200" ........................................... wtetl 2J% at 750" ...................................... ........... ,t 1000' .................." " '........... iitAeo*" ................ .0,.TM.. ........ *a^*0% *at.v. Hu.bi<v rffii--..... at 500' f. *" .............. IkM. VIOIH ( inchei) [ THICKNESS -vches) -.iL Ezro: ][~o^____ :<e :r^oncr. or. rr:r:[f o. ____ .T~~o~:~T r o 3fhtr tf.tl or* arailobl# p#cie) r6*r HEAT INSULATING BLOCK Htat Loss, Surfaco Tomporaturos, and Efficiencies Temperature Difference. Bore Surface o Air. *F. SOURCES OF TEST DATA: The data shown on these pages are supported by tests run at various laboratories, all well known to the insu lation industry. They are further supported by the performance of the product in service. Mere detailed information on Kaylo Heat Insulating Block is available on request. American Structural Products Company, Toledo l, Ohio. 'structural Inculotlng Block--is a near-white, rigid mineral insulating WjrM weighing approximately 20 pounds per cubic foot. It is composed rr'x* principally of calcium.silicate. Except for density and for those characteris' '' ties 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 TpariTniiTn 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<X` lb. per sq. in., a "k" of 0.66 at 100 mean and outstanding resistar.ee to :te travel of heat and flame at building fire temperatures. \ 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 \nd vastly increases insulation value and fire resistance. i PHYSICAL PROPERTIES i ___________ _ 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 Volvo--At low mean temperatures Kay! Structural Insulating Block is one of the most efhcier. structural mineral insulations. At high mean temperature it still compares favorably with heat insulating mater.a. of its own weight. High Light Reflectivity--Where left exposed and untreate (as with the underside of a roof deck) Kaylo Structure Insulating Block has high light reflectivity. Its light n flection factor is from 70 to 80 per cent. Non-Abrasive Surfaco--Its surface is non-abrasive. It hs a somewhat "soapy" feel that makes it pleasant to hand!. 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 i: stead constitutes its own binder. Hence its character, sti. are not modified as to temperature limit, solubility, ins: lation value, fire resistance or otherwise by "bind limitations." L INSULATING BLOCK (20-LB. DENSITY) e*4 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-androoved, sanded, and, in fact, run through most woodorking equipment. igh Modulus of Elasticity--The modulus of elasticity of O-lb. density block is approximately 160,000 lb. per sq. in. ow Specific Hoot--The specific heat of Kaylo Structural nsulating Block is approximately 0.22. :*llulor 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 Moistur* Absorption--Kaylo Structural Block is hyToscopic. It will absorb moisture from humid air and will each equilibrium at lower moisture contents when exposed o lower humidities. However, because of its extremely mall pore size and other characteristics, its behavior with espect to moisture differs from that of most porous maeri It has unusual capacity to distribute moisture vit '.ts mass, and to give it off to surrounding air of owej 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. t six hours, absorbed less than one per cent of moisture y volume. onsistent with the common practice for good construcon involving porous insulating materials of high interna! irface area, Kaylo Structural Insulating Block should ? sealed against moisture on the warm side when it is ibjected to extremely low temperatures. High Wt 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 hours; is reduced only about 15 per cent. Dimantionally 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. Accept* Nail* 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 at 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. Sixes--Kaylo Structural Insulating Block is made in s 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 to 2 inches of Kaylo Structural Insulating Block is required to withstand s 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 Mack Can Be Used In Combination. Where two thicknesses of insulation are used to build up an insulating structure it ii ssible to use the two den sities in combination to deve.jp the best insulation value strength and fire resistance. AMERICAN STRUCTURAL PRODUCTS COMPANY Taleda 1, Obla LAMINATION ------------------------------------------------------ :------------- ominotion over a Kayla 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 ^ ............. i ADHESIVES FOR JOINING E&T7I1' ^- - STRUCTURAL INSULATING BLOCK TO: Weed Veneer Aluminum Stainless Steel the service requirements of the finished product--an* still offer some choice in curing procedures. Some adhesives which may be used with various tvpes of face materials are listed below. (This list is not intended to be complete. Its only purpose is to identify a partial list of adhesives. These have been found to provide a tensile 35 lb. per sq. in. and a minimum shear strength of 100 lb. per sq. ip. when cured in the manner indicated.) ADHESIVES FOR JOINING LIKE MATERIALS: Insulating Block to Insulating Black Aluminum to Aluminum Stainless Steel te Stainless Steel Ovr.lv Ne. 303SA 0 J034AWNI07 303SAWS 01131 Severe 711 0 Cetebend 710 0 VinyUoal ma 2e-1 a Amborlito MU lo.t.k 702* 0 Bodux STn<e XI34I 0 -T1301W IDW) Dwrito M*. 3034A Q Severe 71* 0 WvWwoed 0 Iniolwt* N*. 1 Intorloko 41*2 Vwl<olck QQ Ovpeni 4433 00A Oueeer 4*44 0OO G. t. 2143 0 G. C. 7031 0 VinylMol MA tt-ll AmWfI'N SSI 4 A Sernk UE 130 0 Seduv 0 Duri'e Ne. 101* Q N. A. NHSS7 N100 o 3 MK 13* ooo Wglrfwoad o Imalvto N . 0 Utgriakc 4143 00 Vulvetevk oo Owpeei 4433 000 Oueeet 4444 000 C- 1. 3U3 G. f. 7031 o o Vieylteel MA 2-II o AmboHiBo SSI 4 o leitik 7034 Sediuei Silivete o 0 tedvi o Dwila 102SA Cl 131 o o WeWweed lnBiwt 1 o o 0. I. 3143 O OQPftkdi 911 SUirA 5003 Vinyl**l MA 31-11 Amtoritt* PB14 letlik 7034 a o o o Settik (XI 131 o Sadiwtm Siticatt o *dv o Synve XS34S o + 1J0LW (OV Vyirele.k Ovpvwt 4433 00 OOO Ovpent 4444 000 O. t 7031 letHk 7034 lettik 1X1 13* o 0 0 l4fi o Ove#' /BOA 4451 O. L 7031 Q levtik 70U leatik UilU Q <S Q Q damped at ream temperature far 24 hours. Q damped in even at 120* F. for 1 hour. Symbols for method of arm 0 Placed in press at 10 p.s.i. at 300* F. far 10-30 minutes, For Maximum Strength f Q Placed in press at 100 p.s.i. at 300* F. ter 10-30 minutes. [ Q damped in oven at 2S0* F. tor 10-30 minutes. High-frequency curing hu been tried successfully on sn experimental buis with wood, aluminum and itainleee steel bonded to a Kaylo juleting core. Many of the manufacturers making the above listed .dhesives can provide adhesives suitable (or high-frequency curing. - MflaOSOGAM SffBlUXStfQDiaM I pts(2)(y3(irs (ckii?5\k]v I TOUDO 1. OHIO Subsidiary et OWINS-IUINOIJ CLASS COMSANT KI23M*4IU Coovffffc* 1941. AimgncgA |tn<tvel Rs*4*<* Cempwny Pnnted * U S A. Kayla Structural Insulating Slack--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 drbasis from 19.5 to 22 lb.:, has a compressive strength of appmimatelv S'-1" lb. per sq. in., a "k" of 0.66 at 100 mean and outstanding resistance to t tr 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. Kavlo 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 %'astly increases insulation value and fire resistance. W M 100 Hi ISO l/$ J00 Tomporoiurt, F. ----------------------------------------------- PHYSICAL PROPERTIES ' Light Weight-- Nominal 20-lb. density Kaylo Block is about a third lighter than yellow pine. On an oven-dry basis it weighs from 19.5 to 22 pounds per cubic foot. High Strength--Its compressive strength is approximately 500 lb. per sq. in. with a deformation of 5 per cent. Flexural strength is approximately 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 Kinder--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." The Right Material... Expert Application First. Kaylo Heat Insulation is proved a better material hvdrous calcium silicate. Its light weight, strength, waterinsolubility, low conductivity and wide temperature range give you extra advantages uf 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 be sure of getting the most out of your insulating dollars for your next job, call the nearest Kaylo distributor. Chances are you can find him listed in the yellow pages of your phone liook. If not contact us and we ll give you his name. WIITI tot till toot--"Koylo H.or l.wloilo. ' Addr*Ift: Dp'- N-370. Ofl-lllino>t Cni. KAYLO portf, Koylo OivW0, Toledo 1. Ofe*o. ... first in calcium silicate ... pioneer ed by OWENS (^ILLINOIS Glass Company MAIN OMICI. tOUDO 1. OHIO-AAYIO IAIII OMICIl: AHANTA CMKAOO HOUSTON NIW TOM tHIlAOtlAHlA mfStUtOM It LOUIS Owens Illinois Cliss Company -- Kaylo Division AOvcn.icmcm No. Kill, .pp*.rin( in the foltowm* public,none: Chcm.val Cncmeenni Jan . 1953 0*1 A Gat Journal -Jan 12 19SJ Plant Entinttrmf Jan . 19$J -- Jan I9S.J Prtrn'eum Raftner - Feb . 19SJ CKem;. at Proccitmi -Feb.. 195J ComDuition -Feh I9SJ I"1 sirv 4 Powrf - Feb 1952 i vi itauai iiuiii /amputee i to Infinity... Nesting Kaylo Heat insulation Requires Fewer Pieces Per Job The complete range of Kaylo Insulation includes pipe covering in Simplified Dimensional Standards for diameters from S 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. wtin rot mi i00K-- KortoH,,.i~~i.ho KAYLO Addrom 0*9*. N-371, 0wfti*Uinoii Oiau Company, Kfie Omwson, Tot*4* l# OM*. ImH Hw, ... first in calcium silicaf ...pioneered by OWENS (j^ ILLINOIS Glass Company MAIN OfPtCI: TOLIDO 1, ONlO-KAYlO SAilS OMtCISi ATLANTA * CMtCAUO HOUSTON HtW fO * PNIlAOILPHtA P'TTMUIOM ST IOUIS Owens-Illinois Glass Company Adymutmint No. KlS4-tppeiag ia tbi foUv>a| suWictiiMi: Piuit aniincwnay-- March. 1953 0*1 A Cot Journal-March 23. I9S3 Chemical Entinecftiit-'March. 1953 Chemical Promem* April. 1953 Petroleum RdWr May. 1953 STRUCTURAL I SULATING BLOCK Good Workability--Kaylo 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, sandea, 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 Hoot--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 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 iffof 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 Kavlo Struct- i 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 thev have unusual dimensional stability and unusual freedom from warping. Available with and without Reinforcing--In the form of roof tile Kaylo Structural Insulation is available with a steel reinforcing mat. In the form of core material for var ious types of structure it is available without reinforcing. Accepts Nails and Screws--Both nails and screws can be used with Kaylo Structural Block. Tables showing holding power of both are available on request. Nails should be of the cement-coated type without barbs that abrade the sides of the opening they make as they are driven into the block. Galvanized or non-ferrous nails may be used where greater resistance to corrosion is required. Screws may be inserted either with or without drilling a pilot hole. Sites--Kaylo Structural Insulating Block is made in a standard size of 18 x 36 inches. Since most uses involve manufacturing operations, thick nesses that are practical can best be worked out with the manufacturer of Kaylo Insulating Products after approxi mate quantities needed are known. These will usually be between one and two inches thick. Certain thicknesses are suggested by certain building re quirements. A thickness offrom 1*1 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. Density Slack 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 Tsledt 1/ Okie LAMINATION .animation avar a Kayla Insulating Cora--Almost anv face material may be bonded to Kaylo Structural Insul ating Block surfaces. Bonding agents can be selected to meet the requirements of the particular facing--also to satisfy the service requirements of the finished product --and still offer some choice in curing procedures. Some adhesives and primers which may be used with various types of face materials are listed below, ^This list is not intended to be complete. Its only purpose is to identify a partial list of adhesives. An adhesive no* listed does not imply that it is not suitable. These ha\0 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: Wood Veneer er Paper or Plastics Steal, Stainless Steel Galvaneal, er Aluminum Kayla Insulating Slack er Cement-Asbestos Board Tv Dvrite No. 3024a 8nacolit 01131 oo 8eoro 718 o Catabo*d 720 Vinylfval MA 28-18 o o Ambvrtirt 88 !i Sottih 7026 84wi o o o Syneo S-8348 + I301W (OW) Q Retonabond *>12 Armitroftg J-U62 7*se 0 Dvrifo No- 3026A or N100 8Kere 718 3M8C 826 No. ANH267 W Q O GOO 8wtacolit Cl 131 buaivi* Ne. 1 oo Interlake 4162 Vvkolotk GO oo Dv8onr 4633 GOG DvSont 4646 tMsnsbene 8-1 2 GOO 0 G I. 214 2 G S.L 7031 O Rotrib 7026 G Rotlih Ul 138 Radik 1007 Vlnyheel MA 28-18 0 OG AMbertHe 88-14 G llAtl O AnwWeAf J-1142 O Owe* 3026A tbAocoUtb 01131 Anmirens i 1162 IamM* 1 OX 2142 SblbOf-- 3003 Vmyhl MA 28-18 AabwIMe P8>14 IMS 7024 loAiti mi i3i tetlum SiScete 8dul Srnc* X-8348-M301W I0W| liwniAoM 8-12 TS Q Q 0 0 Q O 0 0 0 0 0 0 0 ft t i r Q Clamped at roam temperature ter 24 hours. Clamped in even at 120* F. for 1 hour. Symbols for method of art: ^ Placed In prect at 10 p.t.i. at 300* F. far 10-30 minutes. For Maximum Strength Q Placed in prate at 100 p.a.i. at 300* F. for 10-30 minutes. 3 Q Clamped in oven at 250* F. far 10-30 minwtas. High-frequency curing hss been crisd successfully on sn experimental basis with wood, aluminum tnd stainless steel bonded to a Kaylo .isulsting core. Many of the manufacturers making the above listed idheaives can provide adhesives suitable for high-frequency curing. Kaylo Division OWENS-ILLINOIS GLASS COMPANY Talodo 1, Ohio KI2 50J C0yr<fM IM, Ose--H-Mb-at Oldll Pruetgd >n \J S *