Document VKbEB7j9d3vj0wxo117ep1x8w

SUMMON* IN A CIVIL ACTION . * err, u ti~) a<rm4T 0. C. fmrm H#, U* <*->> ffimtgfi ^fatgg SHatrict Ofonirt FOR THE . EASTERN DI8TRICT OF TEXAS, BEAUMONT DIVISION ! A civil Action File No_ 402 CliAUDE J. TOMPLAIT "C3 <* Plaintiff Is a v. _ m combust: ON ENGINEERING, Ilfjj., j ET AD -1 ! Defendant JS P ro O 5C CO MM s o u 1 *<t4r C3 <o HMM o s .O <4 f 1 i SUMMONS r ,,. . rw j . EAGLE-PI C1IEH INDUSTRIES, INC., service to be Bade To the above named Defendant . upon itfc agent, C. T. Corporation System, Republic National Bank Building, Dallas, Texas. Xflip.. nuq 8<; vipi n* d^.x- [etyt] Hon. Ward Stephenson ' qsXoi *13 * plaintiff'* attorney , whose address is: ' gcnypvciipwj ou'qi smolu *fo petoLC mSet.'eaphenson _Bu.i.ld.i.ng .................... ' Orange, Texas 77630 geLwcc -- ........................ BX-------- tpra . Y>0>nth vi0V*VnV an answer to the complaint which is herewith served upon you, within twentjdaJfi-yitA^ifcrvJSf'oTIHis yivTfEitvr.a legs .................. ................................................... `summons-upon you, exclusive of the day of service. If you fail to do so, judgement by default will be taken against you for the relief demanded in the complaint ___ JAMES R. COONEY t jtj-- UrkolCnn. Deputy CTe't Date: December 23, 1966 [Seal of Court] I uccciAGq rpia snuiwoue truq sGLxeq ;r roKctpci /r.irp fpo couihpiur poiciu tn ;o|]Oit3L N*C i--Thla iDnmftM la lecaed porioanl io Role t ,f the Federal Rale, of QtU Free.dare. I pcupX cstruX voq tcrm.u' fpt/f ou epe qvX lfEinU'/ OV. 8El!/.ICE OF. W.HU. 10  A* ^ .\\ \ at 4H m*1 <9 .Q HOJTOA JtVtO A HI CHOMMUa % . t*jna3D tunisiCS aaini^ dsiinEE i 3HT H03 Momma TKomjAafl ..saxsITtp/too TQorIratTxaSiIau jJjJ/, rxra.v? 215JE ____OM 3JH MOITOA JIVIO SVlOMKUe N g i! co G ? I 1' B* 2 no I o Ias>. as 3 . 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I [IrnoO lo ka?.| tif91 tCS 'Xi!'i"03oO :*js<3 :cmo(Io; sb aiawq lurqduios sqi qiiM .reqisScq 11 p:/-res pus suomuins srtf) paAtaodJ 1 lifi'.) lo - *ItM Ul'.. i i'll !' t *liOl .11 ; icl(.*_ i *1 nomme* oiilT--: 61 JU AV\i JJ Iv..: "OJil^-J f J'v j!V"SJ o09-'0n j UU.M JO 331AU3S K'O \'Uni3a IN THE UNITED STATES DISTRICT COURT Ttwya FOR THE EASTERN DISTRICT OF TEXAS j^`co^y,'5terfc7u."3* Court BEAUMONT DIVISION / / CLAUDE J. TOMPLAIT :/ ^( HAZEL E. STUDDARD ------------------ Deputy " VS. " : CIVIL ACTION NO COMBUSTION ENGINEERING,: INC., ET AL : . COMPLAINT TO THE HONORABLE JUDGE OF SAID COURT: . COMES NOW CLAUDE J. TOMPLAIT, hereinafter called plaintiff, complaining of "COMBUSTION ENGINEERING, INC., yR. 5 I. REFRACTOR AND INSULATION CORPORATION, \lOHNSMANVILLE SALES CORPORATION, ^OHNS-MANVILLE PRODUCTS CORPORATION, - JOHNS-MANVILLE FIBER GLASS, INC,,"OWENS-CORING FIBER GLASS CORPORATION,^PITTSBURGH CORNING CORPORATION,^GUSTIN-BACON MANUFACTURING COMPANY/PITTSBURGH PLATE AND GLASS COMPANY, ' VlBREBOARD PAPER PRODUCTS CCfRPORATION and EAGLE-PICHER INDUSTRIES, INC., hereinafter called defendants, and for , .cause of action, -plaintiff alleges: '' : 1. . That the ground upon which the jurisdiction of ` this Court depends is diversity of citizenship of the -. parties hereto. - '. 2. " That the amount in controversy herein exceeds the sum of Ten Thousand ($10,000.00) Dollars, exclusive' -- of interest and costs, . 3. . That plaintiff is a resident of the. State" of Texas, and resides in Orange County, State of Texas. **,"* i cftnrr 4. That defendant COMBUSTION ENGINEERING, INC. is and during all of th.e' times h/rein mentioned was | *l t ' a corporation dulyorganized,created and existing /. under and by virtue of the laws of the State of Delaware; that such defendant has an agent for service, to-wit, C. T. Corporation System, Republic National Bank ' Building, Dallas, Dallas County, Texas. 5. That defendant, R. 5 I. REFRACTOR AND INSULATION CORPORATION is and during all of the times herein `' mentioned was a corporation duly organized, created '. and existing under and by virtue of the laws of some -State, with an agent for service; however at this time, plaintiff does not know the name and address of such . .. agent for service. ' 6. . . ' That defendants JOHNS-MANVILLE SALES ' CORPORATION, JOHNS-MANVILLE PRODUCTS CORPORATION and JOHNS-MANVILLE FIBER GLASS, INC. were and during all '^ of the times herein mentioned were corporations duly . . v;. organized, created and existing under and by virtue of the laws of the State of Delaware; that all of such defendants have an agent for service, to-wit: Prentice- ` Hall Corporation System, Littlefield Building, Austin', Travis County, Texas. That plaintiff is suing all of these corporations and alleges that he is suing * whichever one is responsible for the manufacture, production and distribution of the insulation materials hereinafter mentioned, but it is not known by plaintiff at this time which of said corporations is responsible. -2- 7. That defendant OWENS-CORING FIBER' GLASS CORPORATION is and during all,/of ;the tines herein ' .'mentioned was a-corpbration.-</tfly organized, created ' and existing under and by virtue of the laws of the State of Delaware; that such defendant has an agent for service, to-wit: C. T. Corporation System, Republic National Bank Building, Dallas, Dallas County, Texas. 8. . That defendant PITTSBURGH CORNING CORPORATION is and during all of the times herein mentioned was a corporation duly organized, created and existing under and by virtue of the iaws of the State of Pennsylvania; . that such defendant has an agent for service, to-wit, >C, T. Corporation System, Republic National Bank Building, Dallas, Dallas County, Texas. 9. That defendant GUSTIN-BACON MANUFACTURING COMPANY is and during all of the times herein mentioned was a corporation duly organize'4, created and existing under and by virtue of the law: of the State- of Missouri; that such defendant has an agent for service, to-wit: Paul 0. Craig, SS31 Armour Drive, Houston, Harris County, Texas. ` -' - 10` That defendant PITTSBURGH PLATE AND GLASS COMPANY is and during all of the times herein mentioned was a corporation duly organized, created and existing under and by virtue of the laws of the State of Pennsylvania; that such defendant has an agent `for service to-wit: C. T. Corporation System, Republic National Bank Bulging, Dallas, Dallas County, Texas. -3- That defendant FIBREBOARD PAPER PRODUCTS CORPORATION is and during all o the times herein mentioned was a corporation duly organized, created and existing under and by virtue of the laws of the State of Delaware; that such defendant has an agent for service, -to-wit: C. T. Corporation System, Republic National Bank Building, Dallas, Dallas County, Texas. .12, That defendant EAGLE-PICHER INDUSTRIES, INC. is and during all of the times herein mentioned was a corporation duly organized, created and existing under and by virtue of the laws of the State of Ohio; that such defendant has an agent for service, to-wit: C. T. Corporation System, Republic National Bank Building, Dallas, Dallas County, ^fexas. . 13. That defendants during all times herein mentioned and for a long time prior thereto, have been and now are engaged in the manufacture of materials used for insulation, such materials containing fiber glass, rock wool, foam glass, magnesium insulation-, mineral wool, calcium silicate and asbestos; that the products manufactured, compounded and prepared by defendants, acting through their servants, employees, representatives and agents were and are placed on the ~ market to be purchased and used by the public. 14. That the various types of insulation compounded manufactured and placed in containers and sold by the ' defendants contained chemicals and minerals and . deleterious substances and matter which were highly poisonous, dangerous and' harmful Jco human beings and f` and were not suitable for the purposes for which they . were intended. That each of the defendants knew, or t should have known, that the chemical compounds and deleterious substances and matter in said insulation as compounded, prepared and manufactured by defendants were highly poisonous, dangerous and harmful to human beings and to the health of man and that such materials . were defective and were n.t suitable for the purposes . for which they were intended.' IS That at all times herein mentioned, the plaintiff .was employed as an insulator, and in the performance of his employment as an insulator he was required to handle large quantities of the said - ` insulation, compounded, manufactured and prepared ,l,.i ...i.. . .. by the defendants. .ic. l i< it'. ` 16.' That during the period of time in which the I .i plaintiff was employed as an insulator, in the course .ill*' of his employment, due to the negligence and >i,i .i . carelessness,of the defendants, he was caused to'come in contact with the insulation produced by defendants (I..- i- .!: and its chemical compounds, deleterious substances !' . )' ~ and matter and directly in consequence of said w. i y i .im; . i negligence and carelessness of the defendants did sustain In- ! *. Ili* tin* ;i* .i i severe, permanent and disabling injuries as hereinafter - wri i. i. j.v<* iml v 'I' <i< ' set forth. loi tliry ucr `^ -S111 yt ;i t :i .j'i l.imiiM vKif* c`ij 1 uyt jicm furut.iim r (f his c*`n, * II * 'll' Ilf I ( II *.n 11. i . r ,i u- i 17. That the Injuries and damages complained of herein were directly and" proxima^el/ caused by the ' ' .negligence and carelessness of Jhe defendantsiin the * . * /'* l following additional' particulars': (a) That the defendants knew, or in the exercise of ordinary or reasonable care, ought to have V known that the insulation they so prepared and manufactured were deleterious, poisonous and highly harmful to : i 'i v . ' plaintiff's body, lungs, respiratory system, skin and K, '4; **' . health, and that plaintiff would not know of such danger' to his health, notwithstanding which defendants negligently failed to take any reasonable.precautions or exercise reasonable care to warn plaintiff of the danger and harm to which he was exposed while handling the defendants' said insulation; (b) That the defendants knew or, in the exercise of ordinary care, ought to have known that'their ' said insulation was deleterious, poisonous and highly '. harmful to plaintiff's body, lungs, respiratory system, skinand health, and that the plaintiff would not know of such dangerous character, notwithstanding which defendants failed and omitted to provide plaintiff with the knowledge as to what would be reasonably safe .and sufficient wearing apparel and proper protective equipment and appliances to protect him from being poisoned and disabled as he was by exposure to such - deleterious and harmful compound substances and other material contained in said defendants' insulation. (c) That the defendant knew or, in the_exercise of ordinary or reasonable care, ought to have known that *6- their insulation was deleterious, poisonous and highly harmful to plaintiff's body, lungs, respiratory system, skin and health, notwithstanding w^ich defendants negligently and carelessly packaged said insuiation /f so that in the ordinary handling for installation thereof, this plaintiff would come in contact with such deleterious, poisonous and highly harmful compound substances and other- material contained in said defendants' insulation. (d) That the defendants knew or, ir. the exercise of ordinary or reasonable care, ought to have . known that the insulation they produced contained ' deleterious, poisonous and highly harmful substances to human body, lungs, respiratory system, skinar.d health, * notwithstanding which defendants negligently failed to take any reasonable precautions or exercise reasonable care by placing any warnings on their containers of . said insulation to warn the handlers th<reof of the dangers to health in coming in contact with said Insulation. (e) That the defendants knew or, in the .' exercise of ordinary or reasonable care, ought to have known that its insulation contained deleterious, poisonous and highly harmful substances to the human . body, lungs, respiratory system, skin and health, notwithstanding which defendants negligently supplied ' to plaintiff containers of said insulation which were broken open and could not be transported withcut coming in contact with plaintiff's skin and body, (f) That the defendants knew or, in the exercise of reasonable care, ought to have known that their tnsulation contained deleterious and highly'-harmful.substances to -3- plaintiff's health, body, lungs, respiratory system, and skin, and defendants knew or, in the exercise of ordinary or reasonable care, should have known that plaintiff.would not know the .dangerous characteristics of their said insulation, notwithstanding which defendants negligently*failed to take reasonable precautions or ` exercise reasonable care to warn the plaintiff of said danger and to instruct the plaintiff in the proper handling of their said insulation, or to take any reasonable precautions or exercise any reasonable care to protect plaintiff from harm and negligently failed to adopt and enforce a reasonably safe plan and method of handling and installing said insulation. (g) That the defendants knew or, in the exercise of reasonable care, ought to have known that their insulation was defective and that such insulation was not suitable for the purposes for which it was. ; intended, 18, . That as a direct and proximate cause of the aforesaid occurrences and circumstances and the negligence and carelessness of the defendants, plaintiff was permanently and severely injured; that he has sustained' a very serious and permanent injury to his lungs and respiratory system, which has affected other parts of ais body; that ho suffers from shortness of breath, inability to breathe, clubbing of the fingers and toes; that it is necessary that plaintiff have available to him at all times a container containing oxygen in order that he may be able to breathe; that plaintiff has extreme difficulty with sleeping; that he tires easily; that he the t . . ,.11 t i .*11 U.l ; ' l/:i % -*ii.-ii| i 1 lit ' >*l 1 constantly coughs; that he has suffered from an extreme loss of weight; that his future outlook is very dim;" `Vh'at he 'has'sduglittthe' service^ of many physicians 1 ''in* an'effort to cure or arrest/the conditions from which *He''is suffering, but to no avail; that the plaintiff has `'lost'his'good health, all of which is permanently disabling*to him'." h t r. 1 ' : t ir * l> <i 19. :I I That by reason of the negligence and careless t nhes' s of the defendants, and each of them, as hereinbefore "alleged, and because of the harm and injury to his health *'and' the resulting disability therefrom, plaintiff has buffered'a`total loss of wages and earnings and will ' continue to suffer such loss; that he was unable to continue in his employment as an insulator, an employment that he had been engaged in for many years, or to engage in any gainful activity at the present time, and his earning capacity has been greatly and forever'pennanently diminished and impaired. .20 That in an effort to treat, re .ve and heal himself of said injuries and to regain his health, . the plaintiff was obliged to incur and will incur in ' the future an expense amounting to a considerable sum . pf money for medical and hospitalization care, expenses for medicines-, supplies, and so forth, the exact amount of which plaintiff is unable to accurately estimate at this.time. . 21. ` That by reason of the facts hereinbefore- alleged, plaintiff Has suffered and sustained at the. hands of the defendants, and each of them, general and special damages in the sum of Five Hundred Thousand ($500,000.00) Dollars. , / V: WHEREFORE, plaintiff demands .judgment against ' : the defendants, andeach of /hem, In the sue of Five Hundred Thousand ($500,000.00) Dollars, together with his costs and disbursements herein. ' STEPHENSON, THOMPSON AND MORRIS By /^/ [4/4 R3 Attorneys for Plaintifts Stephenson Building Orange, Texas S%&` ./ 10 l IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS BEAUKONT/DIVISIONy 5'\ CLAUDE J. TOMPLAIT ; VS. COMBUSTION ENGINEERING, , INC., ET AL . ' Jt CIVIL ACTION NO. 5402 PLAINTIFF'S FIRST AMENDED COMPLAINT TO THE HONORABLE JUDGE OF SAID COURT: * . f* COMES NOW CLAUDE JTOMTLAIT, hcreinaf ter called plaintiff, complaining of COMBUST-ION ENGINEERING, INC., R A I REFRACTOR AND INSULATION CORPORATION, JOHNS-MANVILLE' SALES CORPORATION, JOHNS-MANVILLE PRODUCTS CORPORATION, JOHNS-MANVILLE FIBER GLASS, INC., OHENS-CORING FIBER GLASS CORPORATION, PITTSBURGH CORNING CORPORATION, GUSTIN-BACON MANUFACTURING COMPANY, PITTSBURGH PLATE AND GLASS COMPANY, I .FIBREBOARD PAPER PRODUCTS CORPORATION and EACLE-PICHER INDUSTRIES, INC., hereinafter called defendants, and for cause of act.ion, plaintiff allege ; - . 1. ' . ' That Che ground upon which the Jurisdiction of this Court depends is diversity of citizenship of the parties hereto. . 2. - That the amount in controversy herein exceeds - the sum of Ten Thousand ($10,000.00) Dollars, exclusive of interest and costs. 3. '_ That plaintiff is a resident of the State of Texas, and resides in O.rangc County, State of Texas. v Ji '' . * 7. That defendant OWENS-COKINC FIBER CLASS CORPORATION la and during all of ^Lhe times herein . . - mentioned waa a corporation duly/^organized, created and existing under and 'by vircue'of the lava of the State of Delaware; that such defendant ha's an agent - for service, to-wlc: C. T. Corporation System, Republic National Bank Building, Dallas, Dallas County, Texas. 8. That defendant PITTSBURGH CORNING CORPORATION i* and during all of the times herein mentioned was a corporation duly organized, created and existing under and by virtue of the laws of the State of Pennsylvania; that such defendant has an agent for service, to-wlc, C, T. Corporation System, Republic National Bank Building, Dallas, Dallas County, Texas. ' 5.' That defendant GUSTIN--BACON MANUFACTURING COMPANY is and during all oi the times herein mentioned w.s a corporation duly organized, created and existing unoer and by. virtue of the laws of the State of - Missouri; chat such defendant has an agent for service, to-wit: Paul 0. Craig, 5511 Armour Drive, Houston, Harris County, Texas. . .' 10. ' -That defendant PITTSBURGH PLATE AND GLASS COMPANY is and during all of the tines herein mentioned was a corporation duly organized, created and existing under and by virtue of the laws of the State of Pennsylvania; that such defendant has an agent for service to-wit, C. T. Corporation System, Kcpubllc National Bank Building, Dallas, Dallas County, Texas. ' V' . 4. . That defendant COMBUSTION ENGINEERING, INC. '` i is and during all of the.-'tlmes hegreln mentioned was a . -corporation duly organised, created and existing under and by virtue of the laws of the State of Delaware; that such defendant has an agent for serv'ice, to-wit, C. T. Corporation System, Republic National Bank Building, Dallas, Dallas County, Texas.. . 5. That defendant, R & I REFRACTOR AND INSULATION CORPORATION is and during all of the times herein mentioned was a corporation duly organised, created and existing under and by virtue' of the laws of some State, with an agent for service; however, at this time, plaintiff does no.t know the name and address of such agent for service. 6. ' That defendants JOHNS-MANVILLE SALES ' CORPORATION, JOHNS-MANVILLE PRODUCTS CORPORATION AND JOHNS-MANVILLE FIBER GLASS, INC. were and during all ' . of the times herein mentioned were corporations duly' * organized, created and existing under and by-virtue of the laws of the State of Delaware; that all of ` such defendants have an agent for service, to-wit: Prentice^Hall Corporation System, Littlefield' Building, Austin, Travis County, Texas. That plaintiff is suing all 'of these "corporations and alleges that he is suing whichever one -is responsible for the manufacture, production and distribution of the insulation materials hereinafter mentioned, but it is not known by plaintiff at this time which of said corporations is responsible.  ** ; That defendant FIBREDOAKD PAPER-PRODUCTS. ; "' ` j CORPORATION is and during all of chef tines herein : .* 1 mentioned vac a corporation duly organised, created } and exiscing under and by virtue of: the laws of the . ' State of Delaware; that such defendant has an agent ` for.service, to-wic, C. T. Corporation System,. Republic National Bank Building, Dallas, Dallas County, Texas. -r ' 12. ' That defendant EAGLE-PICKER INDUSTRIES, INC. is and during all of the tines herein mentioned was a corporation duly organized, created and exiscing under and by virtue of the laws of the State of Ohio; that such defendant has an agent for service, to-wic, - C. T. Corporation System, Republic National Bank Building Dallas, Dallas County, Texas. .' ' i3. ; .......... That defendants during all times herein - mentioned and for a long time prior thereto, have | been and now are engaged in the manufacture of materials used for insulation, such materials containing ' fiber glass, r.ock wool, foam glass, magnesium insulation, mineral wool, calcium silicate and asbectos; 'that the products manufactured, compounded and prepared by defendants, acting through chair servants, employees', 'cprcsentatives and agents ware and are placed on the arket to be purchased and used by the public. ` . 14. That the various types of insulation compounded, inufactured and placed in containers and sold by the _ defcndants contained chemicals and minerals and deleterious substances and matter which were highly ' poisonous, dangerous and harmful to lyiman beings and ' to Che health of-Ban; that such materials were defective and were not suitable for the purposes for which They were intended.* That each of the defendants .knew, or should have known, that the chemical compounds and ' ' deleterious substances and matter in said insulation as compounded, prepared and manufactured by defendants were highly poisonous, dangerous and harmful to human beings and to the health of man.and that such materials were defective and were not suitable for the purposes for which they were intended. * __ ' 15. The plaintiff says that in the year 1959, the exact dates being unknown.' he was employed by B & B Engineering and Supply Company at the DuPont Plant in Orange, Texas, and that in the course of his employment as an insulator, he was required to tome in contact * x* * with the following materials: Foamglas, magnesium and irepxo-ef-ing. Id. `, The plaintiff says-chat in the year 1959, for approximately nine to ten months, he was employed by brooks-Fisher Insulating Company at tne Csllitar. Power 'House-in-Callican, Tennessee, and chat in the course of his employment as an insulator, he was required to come in contact .with the following materials: Asbestos and magnesium. ` * 17. The plaintiff 6ays that in the year I960,' for ,\1*S* - y Mr Ot V Vi -5- ,* (" I approximately two months, he was employed by The Fluor Corporation, Ltd. at Kaplan, Louisiana on the Cow Island Job, and that in the course of his/employment as an X: insulator, he was required to com/e. in' contact with ,' magnesium. " ' . * - ' 18. - ' The plaintiff says that in the year 1900, the exact dates being unknown, he was employed by B & B Engineering 0 Supply Company, Inc. at the DuPont Plant in Orange, Texas, and that in the course of his employment as an insulator, he was required to come in contact with }(. foamglas, magnesium and fi'reproo.fing. 19. - ' The plaintiff 6ays that in the year 1960, the exact dates being unknown, he was employed by Armstrong Contracting and Supply Corporation at the Firestone Plant in Orange, Texas, and that in' the course of lii6 employment tas an. insulator, lie was required to come in contact with magnesium. .' . 20. ' The plaintiff says chat in the year 1561, the exact dates being unknown but being for approximately nine months, he'was employed by Armstrong Contracting and Supply Corporation at the Firestone Plant in Orange, Texas, and that in'the course of his employment as an insulator, ric/waa required to come in contact with magnesium and 'X Careytemp. * 21. _ The plaintiff says that in the year 1961, from September, 1961, to January, 1962, he was employed by Th-e Aber Company, Inc., at the Gulf States Power House, in Bridge -6- i \ City, TexaG, and that in the course of his employment as an insulator, he was required to come in contact with the - ^ followingmaterials: Kaytherra{calcium -* J silicate); * x .2 co 3 .(cement); -Sealfas: 3149 (mas.tlc); Aluminum ells , 4*1 .(mastic); Foamglas (foamed silicate); aluminum ro'iis Aber ., r*V - Vs ' *. S) * -(foamedsilicate);Ovcrkotc' (asphalt emulsion); Unibestos y/ <4 sbestos .fiber)Cllmaseal (mastic); x and Aluminum seals (mastic). x Steel bands (na6tic); ` ' 22. The plaintiff says that from March, 1962, to May, 1962, he was employed by The Aber Company, Inc., at the Culf Oil Refinery, in Port- Arthur, Texas, and that in the course of his employment as an insulator, he was required to come in contact with the following materials: Vo' * -v' ` * Kaytherm (calcium 'silicate.); Aber 2 to 3 (cement); Sealfas I o'- x y' K 3149 (mastic); Aluminum ells (mastic); Foamglas (foamed - . ' 'V\ - -- ' o' t, silicate); Aluminum rolls (foamed `silicate); Overkote . (asphalt emulsion); Unibestos (asbestor fiber); Cllmaseal V *}N (mastic); Steel bands (mastic); and Aluminum *eals (mastic).' \ 23. ' , . The plaintiff says that during the year 196 he worked for Sabine Insulation Company, Inc., at the Firestone ` Plant in Orange, Texas, ana at Lcvingscon Shipbuilding Company in Orange, Texas, and chat in the course of his employment ' as an Insulator, he was required to cone in contact with the .J following materials: Calcium silicate, mineral wool insulating x -ement and"aluminun jacketing. ' .* 24. U1' The plaintiff say6 that during the year 1962, he >rkcd for Armstrong Contracting 6 Supply Corporation, the .act dates being unknown to him,, at the Firestone Plant in. OrAngo, Texa6(- and that in the course of Ills employment as an insulator, he vas required to cone in contact with magnesium. * - 25. . . ! i iV . The plaintiff says chat during the yea; 1962, the exact dates being unknown to hin, he -worked for Johns-Manville Sales Corporation at the Bridge City (Power House, in Bridge City, Texas, and chat in the course of his employment as an insulator, he was required to come 'in contact with the following aaterials: .< - .silicate); Aber 2 to 3 (cement); Seaifas Llumin'um-ells (mastic); Foamglas (foamed Kaythcrn (calcium 3149 (mastic); silicate);' Aluminum Rolls (foamed silicate); Overkote (asphalt emulsion); Unlbestos (asbestos fiber); Cllmaseai (mastic); Steel bands (mastic); an$l Aluminum seals (mastic). I' ' ' * 1 26. . . The plaintiff says that in the year 1962, from about June 11th to June 15c'n, 1962, he was employee by d 6 B Engineering 6 Supply Company, at the Big Three Welding Plant in Orange, Texas, and chat in the course of nis employment as an insulator, he was required to ccme in contact with the following materials: Foamglas, Careytemp Thermogl*a6 and Rock wool. ' . 27. '" ' ' . The plaintiff says chat from November 30, 1962, to January 18, 1963, he was employed by The Aber Company at ` the Gulf States Power House in Bridge City, Texas, and that in the course of his employment as an insulator, he was required Co come in contact with the following materials: Kaycherm (calcium silicate); Aber 2 to 3 (cement); Seaifas- 3149 (mastic); Aluminum ells (mastic); Foamglas (foamed I silicate); Aluminum rolls (foaned silicate); Cverkote , (asphalt emulsion); Unibcstos (asbestos fiber); Climaseal ' Cmastic); Steel ,band6 (mastic); and Aluminum seals (mastic), . - 28. . . * i* V* The plalnti says that in the year 1963, the ' /t exact date being unknown, he was cmployecT by Sabine ' . .. nsulation.Company, Inc., at the Firestone Platt in irange Texas, and and Lev'ingstoh Shipbuilding Company in Orange, that in the course of his employment as an - ' ' Insulator, he vat required to come in contact with'the following materials: Calcium silicate, mineral wool insulating iement, aluminum jacketing, and flberglas. - . 29. The plaintiff says that in the year 1963, he '' was employed by B & B-'Engineering Company, at the DuPont I ' . Plant in Orange, Texas, the exact dace being unknown to him, and chat in the course til his employment as an Insulator, he was required to cone an contact with the I following material: Careytem?. 30. The plaintiff says that '.n July and August, 1963, plaintiff was employed by Insulation Engineers, Inc., at f some refinery in Pascagoula, Mississippi (the exact name being unknown to plaintiff), and that in the course of his employment as an insulator, he was require; to come .'"f - ` . in contact with the following materials: Foam-las ana- magnesium. ' '' ' 31. The plaintiff says that in the year 1963, he va6 employed by Triangle Insulation Company at the lloustofi Chemical Plant, in' Beaumont, Texas, and that it the course -9- of hie employment, as an ineulacor, he waa required to come in contact with 85X magnesium.- - . .. 32. ` "Plaintiff.says that during the month of '_ - .. i -January, `1964, He was employed by B &-B`Engineer & Supply Company at the Big three Welding. Company plant *i k Orange, Texas, and that in the course of hic-enployment, . he was required to come in contact with Foamglae. ' 33. '' ' the plaintiff 6ays that in the year 1964, he was employed by triangle Insulation Company at the. i Hbu6ton Chemical Plant, in Beaumont, Texas, and that in the course of his employment as an Insulator, he was required to come in contact with 051 magnesium. The plaintiff says that during the year 1964 he was employee by Industrial Insulation, Inc., at the Jefferson Chemical Plant, in Pert Xeches, Texas, and chat in the' course of his enplcyment, he was required to come in contact with asbestos insulating material, fibcrglas and magnesium; and he also was employed by Industrial Insulation, Inc. at the Atlantic Refinery, in Port Arthur, Texas, and that in the course cf his employment, he was . * \\ required to come in contact with macnesium. 35. i^'The plaintiff says that during the year 1964, he was employed by Sabine Insulation Company, Inc. at the - Firestone Plant in Orange, Texas, and Levingston Shipbuilding Company, in Or; nge, Texas, anc that in the cour.se of his employment, he was required to come in contact with calcium * silicate, mineral wool insulating cement, aluminum Jacketing -10- ('. ! and fiberglas. . 336C* . The plaintiff aays that during the year 1966, he waa alao employed-by Johns-ManvJtlle Sales Corporation at . ' . i- \ the Gulf States Power Plant, Bridge Cityr Texas, and that ' in `the course of his employment, he waa required to come in contact with calcium silicate, rock wool and 8^2 magnesium. 37. That at all times herein mentioned, the plaintiff . w|s employed as an insulator, an.d that in the performance ' . of his' employment as an insulator, he was required to handle large quantities of the 6aid insulation hereinabove mentioned compounded, manufactured and prepared by the defendants. . ' I* '.33. , That during the period of time in which the plaintiff was employed as an insulator, :>i ;r.e course 0. o'f his employment, due to Che negligence and-carelessness of Che defendants, he was caused to cone an contact with ' the insula.cion produced by defendants and its chemical compounds, deleterious substances and matter and directly . , in consequence of said negligence' and carelessness of the . - * defendants did suscain severe, permanent and disabling injuries -as hereinafter sec forth. 39. ' ""'* That the injuries and damages complained of herein ."were directly and proxinacely caused by the negligence an<f carelessness of the defendants -in the following additional particulars: - . (a) That the defendants knew, or-in the exercise of ordinary or.reasonable care, ought to have known that the -11- insulation they so prepared and manufactured were deleterious, poisonous and highly harmful to .plaintiff's body, lungs, r :spiratory system, skin and health, and' chat plaintiff -viuld not know of- such danger to his health,'notwithstanding' which defendants negligently failed-to t^ake any eisonable ' precautions or exercise reasonable care to warn plaintiff - ' o; the danger and- harm -to which he wae exposed while handling; :tne defendants' said insulation; , .. - (b) That the defendants knew or, in the exercise of ordinary care, ought to have known that their said . insulation was deleterious, poisonous and highly harmful co plaintiff's body, lungs, respiratory system', skin and. ' health, and that the plaintiff would not know of such . dangerous character, notwithstanding which defendants failed and, omitted to provi-de plaintiff with the knowledge as to what would be reasonably safe and sufficient wearing apparel and proper protective equipment and appliances co protect Aim from being poisoned and disables as he was by exposure to such delecerlous and harmful compound substances and o'ther , material contained in said defendants' insulation. - (c) That the defendant knew or, in the exercise of ordinary or reasonable care, ought co have known chat their, insulation was deleterious, poisonous hnd highly '' harmful co plaintiff's body, lungs, respiratory system, . skin .and health^ notwithstanding which defendants negligently. i.a'nd^cat'elessly packaged said insulation so that: in the * o'rdVnary handling for installation chereof, this plaintiff' would' coma--in- contact 'with such delecerlous, poisonous and highly harmful compound substances and ocher material contained 'in said defendants' insulation.' _ ** \ *` . (d) - -That the defendants knew or, in the exercise t* -12- A-' of ordinary or reasonable cate, oughc Co .have known chat Che insulaclon they produced contained deleterious, poisonous and' highly harmful substances Co human body, lungs, respiratory . system, skin and-health, notwithstanding which*defendants . negligently failed to take any reasonable precautions or ' . exercise reasonable care by placing any -warnings on their containers of said 'insulation to warn the handlers thereof ' of Che dangers to health in coming in contact with said insulation. . (e) 'That the defendants knew or, in the exercise of ordinary or reasonable care, ought to have known -that - its insulation contained deleterious, poisonous and highly harmful substances to the human body, lungs, respiratory system, skin and health, notwithstanding which defendants negligently supplied to plaintiff containers of said insulation which were broken open and could not.be transported without coming in contact with plaintiff's skin and body. (f) That the defendants knew or, in the exercise of reasonable care, oughc to have known that their insulation contained deleterious and highly harmful substances to plaintiff's health, body, lung6, respiratory syscem, and skin, and defendants knew or, in the exercise of ordinary or reasonable care, should have known chat plaintiff would not'-know the dangerous characteristics of their said insulation, notwithstanding which defendants negligently j'ai'led' to take reasonable precautions or exercise reasonable care to warn the plaintiff of 6aid danger and to instruct the 'plaintiff in the proper handling of their said insulaclon, or to take any reasonable precautions or exercise any reasonable care to protect plaintiff from "harm and negligently 'failed.to adopt and enforce a reasonably safe -13-  I. . ` plan and method o handling and installing said"insulation. * (g) That the defendants knew or, in the exercise . of reasonable care, ought to have known that their , .. insulation was defective and- that such insulation was V / .i . i \ ' hot suitable for the purposes for which it was intended, - 40. - ' That as a direct and proximate cause of the ' aforesaid occurrences and circumstances and the negligence and carelessness of the defendants, plaintiff was permanently and severely injured; that he has sustained' a very serious and permanent injury to his lungs and respiratory system-, which has affected other parts of his body; chat he suffers from-shortness of breath, inability, - to breathe, clubbing of Che fingers and toes; chat it is necessary that plaintiff have available to him at all times I. ' a container'containing oxygen in order that he may bo able -to breathe; chat plaintiff-has extreme difficulty with "sleeping; that he tires easily; chat he constantly coughs; that he has suffered from an extreme loss of weight; that his future outlook is very dim; chat he has sought the services of many physicians in an effort to cure*or arrest the condition from which he is suffering, but to no avail; that the plaintiff has lost hi6 good health, all of which" is permanently disabling to him. . ' " . 41. That by reason of the negligence and carelessness ` of the defendants, and each of them, as hereinbefore '* alleged, and because of the harm and injury to his health and Che resulting disability therefrom, plaintiff has suffered a total loss of wages and earnings and will continue to suffer such loss; that he was unable to continue in his -14- / 'w- I employment as an Insulator, an employment that he had ' been engaged In for many years, or to engage In any gainful activity at the present time, and his' earning - (capacity has been greatly and forever permanently diminished '.and impaired. ' . i / 1 -. 42. * That in an effort to treat, relieve and heal himself lof said injuries and to regain hi6 health, the plaintiff was* obliged to incur and will incur in the future an expense amounting to a considerable sum of money for medical and hospitalization care; expenses for medicines, supplies, land so forth, .the exact amount of which plaintiff is unable . to accurately estimate at this .time. . . 43. That by reason of the facts hereinbefore alleged, I. * 'plaintiff has suffered and sustained at the hands of the defendants, and each of Chen, general.and special damages 'in the sum of Five Hundred Thousand ($500,000.00) Dollars. * ''-'WHEREFORE, plaintiff demands judgment against the defendants, and each of them, in the sum of Five Hundred Thousand ($500,000.00) Dollars, together vie is costs and disbursements herein. " STEPHENSON. THOMPSON AND MORRIS . '. : '. by. Attorneys for Plaintiff Stephenson Building Orange, Texas -- *15- CERTIFICATE . A copy of the foregoing Amended -Complaint has been forwarded to the' following attorneys of record: .. Mr, Ben -hi Reynolds Royston, Rayzor & Cook .Attorneys at Law ' ' 877 San Jacinto 'Building * ' . -Houston, Texas 77002 ,j ' - ' . ^| * ' ' ' '- . Attorney for Defendant EAGLE-PICHER' '' INDUSTRIES, INC. . Mr. John D. Rienstra Attorney at Law 707 Beaunont Savings Building Beaumont, Texas 77701 - ` 1 . Attorney for Defendant OWENS-CORKING FIBER GLASS CORPORATION . , Mr. John D. Tucker Attorney at Law Orgain, Bell A Tucker Beaumont Savings Building Beaumont, Texas 77701 . . Attorney'for Defendant GUSTIN-BACON MANUFACTURING COMPANY . ' Mr. George A. Weller. Attorney at Law P. 0. Box 350 Beaumont, Texas 77701 ^ ' Attorney for Defendant FIBERB0ARD PAPER PRODUCTS CORPORATION . Mr. Charles S. Pipkin Attorney at Law P. 0. Box 1632 Beaumont, Texas 77704, . _ . Attorney for Defendants COMBUSTION ENGINEERING, INC. and REFRACTORY L INSULATION CORPORATION Mr. George E. Duncan Attorney at Law Beaumont Savings Building Beaumont, Texas 77701 '' ' Attorney for Defendants PITTSBURGH PLATE GLASS COMPANY and PITTSBURGH CORNING CORPORATION Mr. Gordon R. Pate, Attorney at Law 1119 Beaunont Savings Beaumont, Texas Building - V . Attorney for Defendants JOHNS-flAKVILLE SALES ' CORPORATION, JOHKS-MANVILLE PRODUCTS CORPORATION, V *.. and JOHNS-MANVILLE FIBER CLASS, INC. Attorney for Plaintiff -16- IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS BEAUMONT DIVISION CLAUDE J. TOHl'LAiT VS. COMBUSTION ENGINEERING,: INC., ET AL : CIVIL ACTION NO. 5402 INTERROGATORIES TO DEFENDAN' TO: COMBUSTION ENGINEERING, INC n R & I REFRACTOR AND INSULATION CORPORATION, JOUNS-MANVILLE SALES CORPORATION, JOHNS-MANVILLE PRODUCTS CORPORATION, JOHNS-MANVILLE FIBER GLASS, INC., OWENS-CORING FIBER GLASS CORPORATION, PITTSBURGH CORNING CORPORATION, GUSTIN-BACON MANUFACTURING COMPANY, PITTSBURGH PLATE AND GLASS COMPANY, FIBREBOARD PAPER PRODUCTS CORPORATION, EACLE-PICHER INDUSTRIES, INC., Defendants: CLAUDE J. TOMPLAIT, plaintiff, hereby serves upon the above named defendants the following written interrogatories to be answered ful'y and fairly in writing under oath, which shall be signed by the person or persons making such answers, a copy of such answers to be served upon plaintiff's attorney within fifteen (15) days after service herein, in accordance with Rule 33 of the Federal Rules of Civil Procedure: INTERROGATORY NO, 1: Give the names and trade names of all types of insulating materials manufactured by you, giving the dates that you began to manufacture such materials, starting in 1950, a description of the materials and what they contain. INTERROGATORY NO. 2: Did you ever ac any time give warnings to workers of the dangerous nature of such materials? If so, describe your warnings and to whom such warnings were given. INTERROGATORY NO. 3! What studies have you made to determine the effect of your products on the lungs and physical condition of persons employed as insulators and asbestos workers who use the materials ? INTERROGATORY NO. 4: Who made such studies, when were they made, and attach copies of the reports of the studies. INTERROGATORY NO. 5: Did you package and sell any one of the products named in plaintiff's first amended original complaint, and if so, how were the products sold, how were the products packaged, and were these products universally used throughout the United States? INTERROGATORY NO. 6: If these products were used primarily ,.in any specific location or area, please explain where such products were primarily used. INTERROCATORY NO, 7: Do you not recognize that prolonged use of the insulating materials manufactured by you can cause or contribute to cause various occupational diseases including asbestosis, silicosis and dermatitis? INTERROGATORY NO. 8: . ' Did you manufacture or sell any insulating products which were used by any of the named contractors or employers: B & B Engineering and Supply Company, Brooks-Fisher Insulating Company, Fluor Corporation, Ltd., Armstrong Contracting and Supply Corporation, The Aber Company, Inc., Sabine Insulating Company, Inc., Johns-Manville Sales Corporation, Insulation Engineers, Inc., Triangle Insulation Company, Industrial Insulation, Inc., between the years 1950 to date? -2- STEPHENSON, THOMPSON AND MORRIS By. Attorneys fo-f: /Plaintiff Stephenson BwXlding Orange, Texas CERTIPICATE OF SERVICE BY HAIL A copy of the- foregoing Interrogatories has been forwarded to the following attorneys of record on this the 2nd day of November, 1967, by Certified Mail, Return Receipt Requested: . .......... ' Mr. Ben L. Reynolds Royston, Rayzor and Cook Attorneys at Law 877 San Jacinto Building Houston, Texas 77002 ' Attorney for Defendant EAGLE-PICHER INDUSTRIES, INC. Mr. John D. Rienstra Attorney at Law 707 Beaumont Savings Building Beaumont, Texas 77701 . Attorney for Defendant OUENS-CORNINC FIBER GLASS CORPORATION ' Mr. John D. Tucker Attorney at Law Orgain, Bell and Tucker Beaumont Savings Building Beaumont, Texas 77701 Attorney for Defendant GUSTIN-BACON MANUFACTURING COMPANY Mr.'George A. Weller Attorney at Law P. O. Box 350 Beaumont, Texas 77701 ' Attorney for Defendant FIBERB0ARD PAPER PRODUCTS CORPORATION 2 Hr. Charles S. Pipkin Attorney at Law P. 0. Box 1632 Beaumont, Texas 77704 Attorney for Defendants COMBUSTION ENGINEERING, INC. and REFRACTORY & INSULATION CORPORATION Mr. George E. Duncan Attorney at Law Beaumont Savings Building Beaumont, Texas 77701 ` Attorney for Defendants PITTSBURGH PLATE GLASS COMPANY and PITTSBURGH CORNING CORPORATION ' Mr. Gordon R. Pate Attorney at Law 1119 Beaumont Savings Beaumont, Texas Building Attorney for Defendants JOHNS-MANVILLE SALES CORPORATION, JOHNS-MANVILLE PRODUCTS CORPORATION, and JOHNS-MANVILLE FIBER GLASS, INC. ;r defendants, and each of then, general and special damages ' in the sun of Five Hundred Thousand ($500,000.00) Dollars. . WHEREFORE, plaintiff demands judgment against . .. . the defendants, anu each of then, in the sun of Five Hundred Thousand ($500,000.00) Dollars, together with his costs and disbursements herein. _ t .. ' . L' STErnj-h'SON, TncMrsc:; and .morris gy /"*/ i.-*' / c /p Attorneys tor TTaTntTiTs Stephenscn Ruilding Orange, Texas fZ '' * ' v ;, . -10 J 1 t` IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO SER27.97* 31 327 ANTHONY MARIO GRECO, et al.,: Plaintiffs, vs. A-BEST PRODUCTS COMPANY, et al., Defendants. Case Nos. 323629-323678 (Hanna, J.) IN RE: ALL BARON & BUDD ASBESTOS CASES DEFENDANT. COMBUSTION ENGINEERING. INC.'S RESPONSES TO MASTER SET OF INTERROGATORIES CUYAHOGA COUNTY. OHIO CASES PRELIMINARY STATEMENT AND GENERAL OBJECTIONS Defendant Combustion Engineering, Inc.'s responses to these Interrogatories each incorporate this Preliminary Statement and these General Objections. Combustion Engineering, Inc. began manufacturing asbesto'' ' ontaining insulation products on June 5,1963 and discontinued the manufacture of all such products on August 30, 1972. As a result, its responses to these Interrogatories respond within that time frame. To the extent that these Interrogatories call for information outside ofthat time frame, this Defendant objects on the grounds that they are overly broad, unduly burdensome, seek information neither relevant nor material to the subject matter of this case, and are not reasonably calculated to lead to the discovery ofadmissible evidence. Combustion Engineering, Inc. makes the following additional General Objections to each ofthese Interrogatories: 1. This Defendant objects to these Interrogatories to the extent that they purport to require it to "identify" documents on the grounds that such requests to "identify" are overly broad, unduly burdensome and oppressive. 2. This Defendant objects to these Interrogatories to the extent that information subject to the attomey/client privilege and/or which constitutes privileged attorney work product is sought. 3. This Defendant objects to the definitions provided with these Interrogatories as being overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. This Defendant asserts that all terms should be given their usual and ordinary interpretation. 4. This Defendant objects to those Interrogatories that request information regarding the ultimate sales or distribution of products manufactured by this Defendant, which sales did not occur in Ohio and that did not directly affect the sale or distribution of products in Ohio, and which may not lead to the discovery of admissible evidence regarding product shipments that may have been utilized at job sites where Plaintiffs are claiming exposure, because information sought regarding other sales or distribution of Combustion Engineering, Inc.'s products is irrelevant and immaterial and not reasonably calculated to lead to the discovery of admissible evidence. ' 1. For each Interrogatory below, please state the name and last known address of each person answering it, including whether he/she is employed by Defendant 2 and if employed by Defendant include job title, length of time employed by Defendant and ; a year by year list of all other positions, titles, or jobs held when working for Defendant. ANSWER: In preparing these responses, reference has been made to responses prepared in the course oflitigation pending over many years. These responses were based on conversations and document reviews occurring throughout this period. It is impossible to relate the preparation of any particular response to any particular person or document. This Defendant further states that these interrogatories are being answered on behalfofthis Defendant by M. John Homik of Combustion Engineering, Inc. based on information and belief. Mr. Homik was employed by Combustion Engineering, Inc. from 1941 to 1985 in the contract administration area. 1.1 Please identify all documents used, related to, or referred to in connection with the preparation of or answers to these Interrogatories and state the number of the Interrogatoiy and its subpart to each such document. ANSWER: See Response to Interrogatory No. 1. 2. Please state whether or not Defendant is a corporation. If so, please state: (a) Your correct corporate name; (b) The state ofyour incorporation; (c) The address of your principal place of business; (d) Your registered agent for service in the state of Ohio; (e) For each Defendant claiming that this Court lacks personal jurisdiction, list year by year the total amount of income received by the Defendant from entities in Ohio, any and all years that Defendant, as defined, has been licensed to do business in Ohio, and 3 any real property owned at any time by Defendant or its present or past subsidiaries. ANSWER: Yes, this Defendant is a corporation. (a) Combustion Engineering, Inc. (b) Delaware. (c) Windsor, CT. (d) CT Corporation, 17 S. High St., Columbus, Ohio 43215. (e) Not applicable. 3. State defendants complete corporate or business history, including dates of incorporation, mergers, consolidations, reincorporations, and the like. Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs. In addition: a. if defendant or any of it s predecessors or subsidiaries at any time purchased, assumed, or in any other manner acquired ANY ofthe assets and/or liabilities of any corporation or entity at any prior time engaged in any aspect of the placing of asbestos containing products into the stream of commerce or the insuring of asbestos related risks, then please state the following as to each acquisition: b. the name or description of each corporation, entity or assets acquired by Defendant, that entity's state ofincorporation and principal place of business, its date of in/corporation, and the name ofDefendant at the time of acquisition; c. the manner by which each such corporation, entity or interest therein, was acquired (e.g., merger, consolidation, change of name, stock sale, transfer or purchase of assets or product line); d. the date of each such acquisition; 4 e. the state in which each such acquisition was effected; f. the state law governing each such acquisition if specified by contract; g. whether Defendant became legally responsible for the past torts of each such corporation or entity; h. identify each document reflecting or related to the history and/or transaction(s) set forth in answer to this Interrogatory. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that it does not have any predecessors as it understands that term. Furthermore, and without waiving this objection, this Defendant states that it has never controlled, purchased or in any way acquired any interest in a corporation or a business entity which has mined asbestos. This Defendant did acquire an interest in the following companies which manufactured and sold asbestos-containing insulation products. On June 5,1963, Combustion Engineering, Inc. acquired substantially all ofthe assets ofthe company previously known as Refractory & Insulation Corporation (a New Jersey corporation). This involved the acquisition of a refractories and insulation manufacturing plant in Port Kennedy, Pennsylvania. The consideration for the purchase was cash in the amount of $1,932,500. Combustion Engineering expressly assumed certain enumerated liabilities, which did not include the assumption ofany tort liability. There were no common directors ofthe two companies and no common management prior to the acquisition. . On April 3,1964, Combustion Engineering, Inc., purchased the Insulation Division assets ofthe M.H. Detrick Company (a Delaware corporation). Again, this acquisition was for cash, i.e., land, building, machinery and equipment - $275,000; existing inventories and pending sale orders $61,503.32. No tort liability ofDetrick was assumed in this transaction. The facilities acquired were in Aurora, Illinois. As in the previous asset acquisition, there were no common directors ofthe two companies. There was no common management prior to the acquisition and the M.H. Detrick Company continued to exist after the acquisition and still exists today. 5 On March 27,1969, Combustion Engineering acquired Walsh Refractories Corporation (a Missouri corporation). This acquisition was by way of statutory merger and thus Combustion Engineering assumed whatever liabilities Walsh may have had. Walsh Refractories was in St. Louis, Missouri. Its principal business was the manufacture and sale ofrefractories, although it did manufacture three or four products containing asbestos, which products were of specialized nature, usually made to order for a limited number of customers. Furthermore, and without waiving this objection, this Defendant states this Defendant was incorporated in Delaware on October 25, 1912, as the Locomotive Superheater Company. On March 1, 1921, the name was changed to the Superheater Company and subsequently changed on December 31,1948, to Combustion Engineering Superheater, Inc., and finally changed on April 15,1953, to Combustion Engineering, Inc. 4. Please state whether or not the Defendant has purchased, assumed, or in any other manner acquired any of the assets and/or liabilities of any corporation or entity (such corporations or entities being limited to those engaged in the mining, selling, manufacturing, marketing or distribution of asbestos-containing products.) If so, please state the following: a. the name or description of each corporation, entity or assets acquired by Defendant, its state of incorporation and principal place ofbusiness, its date of incorporation, and the name of Defendant at the time of acquisition; b. the manner by which each such corporation, entity, or interest therein, was acquired (e.g. merger, consolidation, change of name, stock sale, transfer or purchase of assets or product line); c. the date of each such acquisition; d. the state in which each such acquisition was effected; e. the state law governing each such acquisition if specified by contract; 6 f. whether Defendant became legally responsible for the past torts of each such corporation or entity; g. whether the acquisition concerned asbestos-containing products. ANSWER: See response to Interrogatory No. 3. 4.1 For each corporation, other than the answering defendant ("the entity"), that has at any time in the past been involved in the placing of asbestos containing products into the stream of commerce for which officers of the answering defendant's corporation have also served as officers, directors or served in any managerial position while employed by the answering defendant, state: a. the name ofthe entity involved in the placing of asbestos products into the stream of commerce; b. the manner in which the entity was involved in the placing of asbestos containing products into the stream of commerce (i.e., mining, milling, manufacturing, distributing, installing, rebranding, etc.); c. the specific products placed into the stream of commerce by the entity year by year and by brand or trade name; d. the name, positions and a brief description ofthe responsibilities of the person or persons serving the answering defendant and the entity simultaneously including the positions held with the entity and with the answering defendant. ANSWER: Not applicable. See response to Interrogatory No. 4. 7 EVER SELL ASBESTOS 5. Has Defendant ever engaged in the mining, manufacturing, selling, marketing, installation or distribution of asbestos-containing products? If so, please state the following: (a) The name of the company engaged in the activity (whether it is Defendant, Defendant's predecessor, or Defendant's subsidiary); (b) As to each product mined, manufactured, sold, marketed, installed or distributed, please state the following: 1. The trade or brand name. 2. Its identification number (model, serial number, etc.). 3. The time period it was manufactured, mined, marketed, distributed or sold. 4. Its physical description including color, general composition, and form. 5. A detailed description of its intended use and purpose. 6. A detailed description of the type package in which it was sold, listing the dates of each type of package used, a physical description of the package, and a description of any printed material or trademarks that appeared thereon. 7. The percent of asbestos which it contained. 8. The percent of asbestos by asbestos type (amosite,. crocidolite, tremolite, anthophyllite). (c) The time period during which each ofthese products were on the market; (d) The material components/ingredients of each such product, giving specific or approximate percentage both by weight and by volume of each material component/ingredient (this interrogatory is not limited to the asbestos component ofthe product but seeks information as to the nature, weight and volume of non-asbestos ingredients, as well) of each such product; 8 (e) How each of these asbestos-containing product can be distinguished from those of competitors; (0 A description of the physical appearance of such product; (g) A detailed description ofthe intended uses. ANSWER: (a) This Defendant objects to this subsection of this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states see Preliminary Statement. Furthermore, and without waiving this objection this Defendant states this Defendant never mined asbestos. This Defendant state that asbestos-containing insulation products were manufactured, distributed and sold by a subsidiary, Refractory and Insulation Corporation, a Delaware Corporation, from June, 1963 until 1967, when the name of the subsidiary was changed to R&I Ramtite Corporation. On December 31, 1967, R&I Ramtite merged into Combustion Engineering, Inc., and the asbestos-containing insulation products were thereafter manufactured, distributed and sold by the C.E. Refractories division ofCombustion Engineering, Inc. (b) (1) See Exhibit A attached hereto. (2) Not applicable. (3) See Exhibit A attached hereto. (4) See Exhibit A attached hereto. (5) Actual use of this Defendant's asbestos-containing insulation products varied according to industry practice. The products were generally intended to be used for thermal insulation. Also, see Exhibit A attached hereto. (6) See Exhibits A, B, and C. . (7) See Exhibit A attached hereto. (8) See Exhibit A attached hereto. (c) See Exhibit A attached hereto. (d) See Exhibit A attached hereto. (e) This Defendant objects to this subsection of this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. 9 Furthermore, this interrogatory requires this Defendant to be familiar with all products made by other manufacturers, which it is not. (f) For the most part this Defendant's asbestos containing insulation products were white or off-white in color. See Exhibit A attached hereto. (g) See response to Interrogatory No. 5(b). 6. Does Defendant or any of its subsidiary companies claim that any patent would cover any product listed in answer to Interrogatory No. 5? If so, please state the following: (a) The date of each patent; (b) The date same was issued; (c) The number of each patent application that is pending. ANSWER: This Defendant had no patents with respect to asbestos-containing products. 7. Have any of the products listed above in answer to Interrogatory No. 5 been altered in chemical composition since first being marketed? If so, please state the following: (a) The trade name of each such product; (b) The date each such product was altered; (c) The nature of the alteration; (d) The reason for the alteration. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to 10 the discovery of admissible evidence. Without waiving this objection, the only substantive alteration was the deletion of asbestos from all of this Defendant's asbestos-containing insulation products. 8. Have any of the asbestos-containing products listed in response to Interrogatory No. 5 ever been marketed, distributed, packaged, labeled, and/or sold by any other company or business? If so, please state the following: (a) The name and address of each such company. (b) The names and address of Defendants distributors in Ohio and Illinois since 1940. (c) The date of each sale. (d) The name ofthe person at each location with whom you primarily dealt. (e) A list of all asbestos-containing products that you sold to each location from 1945 to 1980. (f) The amount of each asbestos product sold to each location during this period. (g) Please identify all documents elating to this distributor for the particular location. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that it sold Griptex Block, Super 711 Insulating Cement and Utility Thermal Finish Cement from 1963 through 1972 to Kaiser Refractories for resale under Kaiser's name. Furthermore, and without waiving this Defendant states that its distributors in Ohio were Clark Asbestos, 1964-72, Miller Refractories, 1968-72, Foseco, 1970-72, A.J. Phipps, R.D. Kramig & Co., Ohio Asbestos and Insulation Company, and S. Obermeyer. 11 8.01 Has this defendant ever purchased asbestos containing products from any other defendants? . ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter ofthis case nor reasonably calculated to lead to the discovery ofadmissible evidence. 8.02 Ifthe answer to the preceding Interrogatory is yes, please state the following: (a) name each defendant from whom this defendant purchased any asbestos containing product; (b) list each product purchased from each co-defendant; (c) list the dates of each purchase of asbestos-containing products from each co-defendant. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that it purchased raw asbestos from Chicago Firebrick Co.. See also response to Interrogatory No. 13. 8.03 Has this defendant ever sold asbestos containing products to any other defendant? ANSWER: 12 This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states a review of this Defendant's available sales records indicates the following sales to co-defendants: A.P. Green Chicago Firebrick Co. Clark Asbestos Foseco Pitts. Plate Glass 1970, Pyroscat 1968-72, Griptex; block Stick 1968-1972, Utility Cement, Griptex, Super 711, Permiseal, Pyroscat 1970-72, Block Stick, Lite Wate 50, Griptex, Stictite, Thermal Coat, Super Stictite 1968, Stictite, Griptex $922.86 $28,997.93 $37,172.21 $ 1,129.60 $823.75 8.04 Ifthe answer to the preceding Interrogatory is yes, please state the following: (a) name each defendant to whom this defendant sold any asbestos containing product; (b) list each product sold to each co-defendant; ' (c) list the dates of each sale of asbestos-containing products to each co-defendant. ' ANSWER See response to Interrogatory No. 8.03. 8.05 Has Defendant engaged in the manufacture and/or sale and/or distribution and/or marketing and/or supply and/or purchase and/or use of non-asbestos-containing products for use in connection with temperatures above 125' Fahrenheit since 1930. If so, please state: (a) the date such activity began; (b) the years during which such activity took place; (c) the date when such activity was terminated; 13 (d) if such activity was terminated, the reason(s) why; (e) the geographical area into which you claim the product(s) were sold, purchased, or used; (f) identify the organizational unit of defendant so engaged; (g) the site(s) at which each such product was manufactured; (h) the material components of each such product, giving specific or approximate percentage both by weight and by volume of each material component of each such product; (i) the temperature ranges for which each product(s) was intended to be used; (k) the product's trade or brand name; (l) the container in which the product was shipped (i.e., paper bags, cardboard boxes) including the size and amount of the container; (m) a description of any logos, writing impressions or identifying markings which appeared on the product, as well as a description of the package used, the dates that type of package was used, and any logos, product names, trademarks, etc. which appeared on the package; (n) whether the words "non-asbestos" or "asbestos free" were used on the package; (o) a detailed description of the intended method of preparation and application of the product; (p) a description of the physical appearance of the product, including size, shape, color and texture. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery ofadmissible evidence. 14 8.06 Did Defendant ever market or distribute any asbestos-containing product manufactured in whole or in part by someone else? If so, please state the following for each such product: (a) the name and address of the manufacturer; (b) the products trade and brand name; (c) the organizational unit ofDefendant who did so; (d) date(s) beginning, ending and during which the marketing or distributing took place; (e) whether the product was distributed through the same channels as those used for products manufactured by Defendant, and if not, please explain the exact channels of distribution; (f) identify all documents relating the marketing or distribution. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states see response to Interrogatory No. 13. Also, see Exhibit A. 8.1 Does Defendant have reason to believe that any of the asbestos-containing products listed in response to Interrogatory No. 5 were used at any ofthe sites listed on Exhibit A, attached hereto. If your answer is "yes", please state: (a) The basis of your answer. (b) Please state which of Defendant's asbestos-containing products listed in Interrogatory No. 5 were used at each job site listed on Exhibit A. ANSWER: 15 This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states it cannot answer this interrogatory with specificity. Furthermore, and without waiving this objection, this Defendant states it did manufacture boilers. This Defendant supplied boilers to customers according to the terms and conditions of the contract with each particular customer. Therefore, each transaction represented a "custom" job and varied accordingly, including that aspect of the transaction involving the supply and usage of asbestos-containing insulation for the boiler. Relevant contract documents will be made available for review by plaintiff at a mutually agreeable time at the offices of this Defendant's national coordinating counsel, Arter & Hadden in Columbus, Ohio. This Defendant's records indicate that it supplied boilers to the following jobsites: Armco Steel, Houston TX Contract Nos. 22165 and 19466. Republic Steel, Berger Plant, Canton, OH Contract Nos. 22245 and 24555 U.S. Steel, McDonald Works, Youngstown, OH Contract No. 1295-BV-7727 (1935) Weirton Steel, Weirton, WV Contract No. 18451 (1951) . Contract No. 1165 (1965) Contract No. FIB-SH-1344 (1953) Contract No. FTB-SH-1364 (1954) ' ' This Defer" .t has reviewed its available product sales records which indicate it sold the following products to the locations listed on Exhibit A: Invoice No. 55044 and 55877 None 43475 34894 66303 56730 None 68606 Jobsite Armco Steel, Ashland, KY Armco Steel, OH Armco Steel, Middletown, OH Armco Steel, Middletown, OH Armco Steel, Houston, TX Armco Steel, Houston, TX Republic Steel, Cleveland, OH Timken Roller Bearing, Yr/Product/Amount 1971, Black Stick, $9.60 1971, Griptex, $1,062.87 1968, Super Stictite, $226.00 1970, Griptex, $2,212.71 1970, Super 711, $116.88 1970, Griptex Block, $93.02 1972, Lite Weight 50, $380.00 1971, Griptex Block, $578.34 1968 Super Stictite, $399.65 1971, Stictite, $452.00 16 Invoice No. 37360 (for $226.00) None None None None Meg. 63468 60219 52322 None None None None None None 52344 Jobsite Canton, OH Timken Roller Bearing, Canton, OH Timken Roller Bearing, Canton, OH U.S. Steel, McDonald, Youngstown, OH U.S. Steel, McDonald, Youngstown, OH U.S. Steel, McDonald, Youngstown, OH U.S. Steel, Clairton, PA U.S. Steel, Clairton, PA U.S. Steel, Clairton, PA U.S. Steel, Clairton, PA U.S. Steel, Clairton, PA Weirton Steel, WV Wheeling Steel, Mingo Junction, OH Wheeling Steel, Mingo Junction, OH Youngstown Sheet, Youngstown, OH Youngstown Sheet, Youngstown, OH Youngstown Sheet, Youngstown, OH Yr/Product/Amount 1970 Stictite, $632.56 (total for 1970, but only one invoice available) 1968, Stictite, $452.00 1968, Super Stictite, $216.00 1968, Stictite, $216.00 1969, Block Stick, $19.20 1970 Util. Cement, $260.00 1972, Util. Cement, $221.00 1971, Util. Cement, $221.00 1971, Util. Cement, $520.00 1968, Util. Cement, $108.00 1969 Super Stictite, $63.00 1968 Air Check, $134.25 1969, Utility Cement, $90.00 1968, Block Stick, $118.80 1969, Block Stick, $1,187.20 1971, t Jc Stick, $460.80 8.2 For each company or business that Defendant knows may have marketed, distributed, installed, and/or sold, those products listed in response to Interrogatory No. 5, please state the following as to each job site listed on Exhibit A. (a) The name and address of each such company; (b) The date of each sale from Defendant to such other company; (c) The name ofthe person at each other company with whom Defendant primarily dealt. 17 (d) Names and quantities of the asbestos-containing products that you marketed, distributed, installed, and/or sold to each such company from 1950 to 1974. (e) Please identify all documents relating to the sales to each such company. ANSWER: See response to Interrogatory No. 8.1. 8.3 If you do not know any business that may have marketed, distributed, installed, and/or sold the products listed in response to Interrogatory No. 5 to any of the job sites listed on Exhibit A, please state the names and last known addresses of those companies who Defendant knows marketed, distributed, installed and/or sold their asbestos-containing products in Ohio from 1950 to 1974. For each of those companies, please state the following: . (a) Name and address of each such company; ' (b) The dates of each sale from Defendant to such other company; (c) The name of the person at each other company with whom Defendant primarily dealt; (d) The names ofthe asbestos-containing products that Defendant marketed, distributed, and/or sold to each such company from 1950 to 1974, ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states see response to Interrogatory No. 8 and No. 8.2. 18 8.4 Does Defendant have records and/or any knowledge that reflects sales of their asbestos-containing products to any of the sites listed on Exhibit A, attached hereto? If so, please state the following as to each job site listed on Exhibit A: (a) The names and last known addresses of those people with such knowledge. (b) The location of such records. ANSWER: (a) Frank Christenson, Valley Forge, Pennsylvania. . (b) Invoices are located at this Defendant's National Coordinating Counsel, Arter & Hadden, Columbus, Ohio. 9. Did Defendant or any ofDefendant's distributors, as listed in response to Interrogatory Nos. 8.1, 8.2, and/or 8.3 have sales representatives who specifically called on the sites listed on Exhibit A, attached hereto, from 1945 to 1975? If your response is yes, as to each site listed on Exhibit A, please state the following: (a) The name and last known address of -ach such representative and whether they are still employed by Defendant; (b) The period oftime they acted as your representative; (c) Their general responsibility as to each facility; (d) Whether that person is still alive; and (e) Any documents relating, referring or pertaining thereto. ANSWER: This Defendant states during the time that this defendant manufactured and sold asbestos-containing insulation products, its sales representatives in Ohio were F. Bees (1963-72); T. Bees (1963-66); C. Miles (1967-70); G. Thomas (1967-72); S. Wagner (1967-72); F. Pavlick (1965-71); Mr. Beyers (1967); D. Wauschek (1967-72); Thomas O'Dwyer (1963-70); Ron Opre (1967-72); G. Bondira (1963-69); James Taskington (1963). 9.1 Identify all managers and sales personnel responsible for your sales or installation of any asbestos-containing products in Ohio from 1930 to the present and state their position, last known address and the local or regional office through which they were employed. ANSWER: See response to Interrogatory No. 9. 10. Did Defendant ever have any division or subsidiary engaged in the contract business of applying or removing asbestos-containing products? If so, please'state: (a) The name of each subdivision; (b) The full address of the home office and the date such subdivision or subsidiary was engaged in this contracting business; and (c) Whether said division or subsidiary conducted such business at any of the sites listed on Exhibit A, from 1940 to 1975? If so, please state the following as to each job site listed on Exhibit A: (1) The dates of such contracts; . (2) The specific asbestos-containing products that were used or removed in each contract. ANSWER: This Defendant did not have such a contract division or subsidiary. 20 11. Did Defendant ever have any division or subsidiary engaged in the contract business of applying or removing asbestos-containing refractory? If so, please give the name of each subdivision, the full address of the home office and the date such subdivision or subsidiary was engaged in this contracting business. ANSWER: Although this Defendant had a department which applied non-asbestos containing refractories, it did not have a contract unit which applied asbestos containing products. 12. Please identify by location and product produced, each plant in which products listed in your answer to Interrogatory No. 5 have been manufactured and/or assembled and the dates said plants have been in operation. ANSWER: This Defendant states that its asbestos-containing insulation products were manufactured at the following plant locations: Port Kennedy, Pennsylvania June 5, 1963 through June 30, 1972; Aurora, Illinois - April, 1964 through June 30,1972; St. Louis, Missouri - March 27, 1969 through June 30, 1972. 13. Has Defendant, at any time, entered into a "rebranding" agreement with any other company, either as a buyer or a seller, concerning any asbestos-containing products and/or materials? If so, please state: . (a) The name of the company manufacturing the asbestos products under such agreement; (b) The trade name affixed to such products; (c) The periods of time covered by each such agreement; (d) The volume (in dollars amounts) of each such transaction; (e) The purchaser of such products; 21 (f) Does Defendant currently have in its possession any of the writings or contracts concerning such rebranding agreement? ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states, that it purchased two products called ThermalKote and Trowel Mastic from the Flintkote Company and relabeled and sold ThermalKote as WeatherKote and ThermalKote and Trowel Mastic as Aircheck; see Exhibit A. This Defendant purchased a fibers in emulsion product from The Anderson Prichard Company and relabeled it and sold it as Permiseal. This Defendant purchased a fibers in emulsion product from the Gibson Homans Company and relabeled it and sold it as Duriseal. There are no existing documents reflecting these transactions. 13.1 Have you ever owned or operated a business or portion thereof which engaged in construction, erection or tear out of furnaces, pipes, boilers, turbines, lehrs. ovens, kilns, etc.? If so, please state: (a) the same of said business; (b) the date of commencing business and cessation of business, if applicable; (c) type of construction or tear out performed; (d) state whether said business installed or supplied asbestos-containing products on the furnaces, pipes, boilers, turbines, lehrs, etc., i.e., gaskets, pipecovering, block, cement, rope, cloth, clothes, etc., containing asbestos, asbestos pipe, board, etc.; (e) state the trade name and/or manufacturer of any asbestoscontaining product which you installed or supplied to any site on Exhibit A. (0 provide the dates for the applicable construction, installation or tear-out project. 22 e ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, see response to Interrogatory No. 8.1. 13.2 Do you have within your custody, possession, or control any packages that presently or formerly packaged asbestos-containing products or were produced for the purpose of packaging asbestos-containing products contemporaneous with your manufacture sale or distribution of such asbestos-containing products? If so, provide the following: (a) a description of each such package; (b) the present location and custodian of each such package; (c) the date or approximate date on which each such package was produced. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, see Exhibit A, B, C and E. INFORMATION ABOUT DESIGN/TESTING 23 14. What is the name, address and job title of each individual who participated in the design and preparation of manufacturing specifications for each such product listed above in answer to Interrogatory No. 5? ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that to the best of this Defendant's knowledge, the following persons may have been involved with the design and preparation of the manufacturing specifications: Horace N. Clark (now deceased); Louis Jacobs, Vice President ofResearch and Development (now deceased); Robert Nelson, President, C-E Minerals, Valley Forge, Pennsylvania (deceased); Irving Gower, Manager, Research and Development, Port Kennedy, Pennsylvania (now retired); Thomas Brown, Research and Development, Port Kennedy, Pennsylvania (no longer with company); George Woods (retired) and A1 Momme (retired). 15. As to each product listed in response to Interrogatory No. 5, please describe how each product was to be cut, shaped, scribed, mixed and applied on the job. (In answerii - his question, give particular reference as to whether or not the materials were to be sawed or cut on the job, blown into confined areas, mixed with water in a cement or paste.) ANSWER: See response to Interrogatory No. 5(b). 16. Based upon the material contents ofthe asbestos-containing products, the method of manufacturing, and the method of application, please state which products listed in Interrogatory No. 5 could be applied by a worker without creating dust. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence and improperly assumes that this Defendant's asbestos containing insulation products emitted dust. 17. Do any documents, including but not limited to, written memoranda, specifications, recommendations, blueprints or other written materials of any kind or character now exist relating to the design and preparation of the products listed in answer to Interrogatory No. 5? If so, please: (a) List each such written material or document; (b) Identify the person or persons presently in possession of each such document; (c) State where each such document is located. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calcui i to lead to the discovery of admissible evidence. Without waiving this c :ction, to the best of this Defendant's knowledge, it has no such documents other than a limited number of quality control records in the custody of this Defendant's national coordinating counsel, Arter & Hadden in Columbus, Ohio. 18. Prior to releasing the products listed in Interrogatory No. 5 for sale and usage, were any tests (either animal or human) conducted on said products to determine potential health hazards involved in the use of, or exposure to, the materials and/or products? If so, please state: 25 (a) The name ofthe products tested and the date of each test. (b) The name, address, and job classification of each individual who conducted such tests; (c) The results of such tests. . ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, to the best of its knowledge, this Defendant states no. 18.1 Prior to releasing any products for sale and usage (whether asbestos- containing or not), were any tests (either animal or human) conducted on said products to determine potential health hazards involved in the use of, or exposure to, the materials and/or products? If so, please state: (a) The name ofthe products tested and the date of each test. (b) The name, address, and job classification of each individual who conducted such tests; (c) The results of such tests. . ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, to the best ofthis Defendant's knowledge, no. 26 19. Does Defendant have or control any documents, including but not limited to, written memoranda, specifications, recommendations, blueprints or other written materials of any kind or character relating to the testing of the products listed in Interrogatory No. 5 hereinabove? (a) Identify each such written material or document; (b) Identify each person who presently has possession of each such document; (c) State where each such document is located. ANSWER: See response to Interrogatory No. 17. 20. Were any design changes or modifications made as a result of such tests listed in answer to Interrogatory No. 18 hereinabove? If so, please state: (a) The trade name of the product changed or modified; (b) The nature of the change made and the date of such changes or modifications; . (c) The name, address, and job classification of each person in charge of making a change. ANSWER: See response to Interrogatory No. 18. 27 21. After releasing for sale, distribution or marketing the products listed in answer to Interrogatory No. 5, did Defendant conduct any tests (either on animals or humans) to determine potential health hazards involved in the use of said materials and/or products? (a) The names of the products tested and the dates of said tests; (b) The name, address, and job classification of each person and/or agency conducting said tests; (c) The results of said tests; . . (d) Whether, as a result of any tests conducted, any products were removed from the market; (e) The names of all products removed from the market as a result of said tests. ANSWER: ' This Defendant objects to this interrogatoiy on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, to the best of this Defendant's knowledge, no. 22. Has Defendant ever conducted or caused to be conducted any studies concerning the effects ofthe inhalation of asbestos dust and/or fibers on workers or other persons applying, using and/or working around any ofthe asbestos products manufactured, sold, distributed and/or relabelled for distribution by you or your predecessor? If so, please state: (a) The dates and nature of such studies; 28 (b) The names and addresses of persons conducting such studies; (c) The purpose of such studies; (d) Identify and list those persons to whom such reports were given and the date of such dissemination; (e) State any publication or other written dissemination ofthe results of such studies; (f) State the nature of any action to eliminate or minimize the inhalation of asbestos dust fibers; and (g) Attach a copy of reports based upon such studies. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, to the best of this Defendant's knowledge, no. ' INFORMATION ABOUT SAFETY 23. Before placing in the market the asbestos-containing products that Defendant, mined, manufactured, sold, marketed, installed or distributed on the market, did Defendant make or cause to be made, any studies to determine whether their asbestoscontaining products would be hazardous to people? If so, please state: (a) The date of said studies; (b) What studies were done; and (c) The titles of each study. 29 ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving tins objection, this Defendant states no. Please state whether or not Defendant ever conducted or caused to be conducted any tests in the field (where asbestos-containing products were applied, removed or utilized) to determine the nature and extent of asbestos dust and/or fiber exposure to insulators, applicators, fellow employees, or other workers removing and/or tearing out asbestos-containing products, and/or other workers in the vicinity thereof.? If so, please identify: (a) The date, place and nature of each and every test; (b) The particular asbestos-containing products to which each test applied; (c) The results of each test with particular reference to the number of asbestos fibers per cubic centimeter of air found at each site; and (d) The persons to whom the results said tests were given and the date of such dissemination. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states no. 30 25. Please state whether or not Defendant ever obtained any knowledge concerning the likelihood of asbestos being hazardous to human health. If so, please state: (a) When Defendant first became aware of the hazardous potential of asbestos dust and asbestos fibers; . (b) The manner in which the Defendant, Defendant's predecessor, or Defendant's subsidiary companies first obtained this knowledge and became aware of said hazards and from what source this information was obtained; (c) What information was disseminated within Defendant's company, or its subsidiary or predecessor regarding such adverse consequences or effects; (d) Whether any such information is still maintained by Defendant or its subsidiary or predecessor in any written form. (e) The name, address and job classification ofthe custodian of such information. ANSWER: . (a) (b) This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter ofthis case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that it has no records or other information regarding how it first became aware of certain alleged potential health hazards associated with the use and/or fabrication of asbestos-containing products. Nonetheless, this Defendant had become aware of certain alleged' potential health hazards associated with the use and/or fabrication of asbestos-containing products by 1969 when it began to use warnings. (c)(e) Beginning in 1969 all production workers in Defendants' plant who worked with asbestos were required to wear respirators. This Defendant has no records from which it can determine specifically how employees were informed of the requirement. Also see Exhibit D which is a Combustion Engineering, Inc. Industrial Hygiene Bulletin dated March, 1972. Beginning in 1969, exact date unknown, this Defendant began printing, stamping or stenciling warnings on all of the packages of its asbestos-containing insulation products. See Exhibit B. 31 26. Please state when Defendant first became aware of the possible association between inhalation of asbestos dust and/or fibers and the contraction of asbestosis and cancers including, but not limited to gastrointestinal cancer, laryngeal cancer, renal cancer, lymphoma, lung cancer and mesothelioma. As to each disease or condition, please state the source of that information, including a description of all tests conducted relative to the possibility of such a relationship. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. This Defendant further objects to this interrogatory on the grounds that it improperly call for a medical of scientific opinion which this Defendant in not qualified to give. Without waiving this objection, see response to Interrogatory No. 25. 27. Please identify all physicians, industrial hygienists, and other employees (including their names and addresses) who were employed, retained or otherwise engaged by Defendant for research, investigation or study concerning asbestos or asbestos-related diseases ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that during the time that it manufactured, distributed and sold asbestos-containing insulation products, industrial hygienists were hired primarily to comply with regulations of the Atomic Energy Commission. Robert Hancock was responsible for industrial hygiene during the time frame in which this Defendant manufactured asbestoscontaining insulation products. In addition, the following individuals were responsible for various aspects of health and safety and may have been involved regarding the potential medical, toxicological or industrial hygiene 32 aspects of asbestos or asbestos containing products. Paul Osimo, industrial hygienist; Reynold Hoover, Manager of Health and Safety; Carl L. Green, Environmental Control Engineer. The only physicians employed by this Defendant were employed to conduct routine physical examinations and to handle emergencies. This Defendant is unaware of the identity of these physicians nor is it in the possession oftheir records. . 28. As to each person who acted in a medical advisory capacity (as it relates in any way to asbestos) to Defendant, please list their name, the date individual acted in this capacity, and that person's current address and job title. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that during the time that this Defendant engaged in the manufacture, distribution and sale of asbestos-containing insulation products it did not have a "medical director". . 29. Please state if any medical officer or industrial hygiei or medical consultant ever made at any time any recommendations and/or suggestions to Defendant pertaining to the risks or hazards to persons involved in the manufacture or use of asbestos products and, if so, please state when, by whom or to whom such recommendations and/or suggestions were made and the substance of each recommendation. ANSWER: See responses to Interrogatory Nos. 27 and 28. Also, see Exhibit D. W 33 30. Please state the scientific and/or medical periodicals to which Defendant, its medical department, research department, industrial hygiene divisions, engineering department or consulting physicians subscribed between 1945 and 1975. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discoveiy of admissible evidence. Without waiving this objection, this Defendant states that it has no records regarding what periodicals this Defendant subscribed to during the time period in which it manufactured asbestos-containing products. 30.1 Please state whether Defendant, its medical officer or industrial hygienist or medical consultant or physicians were ever involved.in testing or received literature or correspondence from the Mellon Institute. ' ANSWER: ' This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, see response to Interrogatory Nos. 27 and 28. . 30.2 Has any engineer, industrial hygienist or physician in your employ been a member in any professional group, trade group or any of the following groups: Asbestos Textile Institute National Insulation Manufacturers Association Thermal Insulation Manufacturers Association Quebec Asbestos Mining Association Asbestos Information Association W 34 Industrial Health Foundation Industrial Hygiene Foundation Iron and Steel Institute National Safety Counsel Refractories Institute Air Hygiene Foundation of America, Inc. Sprayed Mineral Fiber Association If the answer is yes, state the following: (a) The name of the group or groups in which the individual(s) were members; (b) The name and position individual(s) within the Defendant, as defined, who were members; (c) The years the individual(s) were members ofthe groups; (d) Whether the Defendant paid the individual(s) dues or membership fees or reimbursed the individual(s) for dues or membership fees in the group. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, seeks information which is neither relevant to the subject matter ofthis case nor reason oly calculated to lead to the discovery of . admissible evidence. Without wai\ ng this objection, this Defendant states other than the Refractories Institute, to the best of its knowledge, it belonged to none ofthe organizations referenced in this interrogatory. 31. State in detail what test, if any, Defendant ever made with regard to the quantity, quality, or threshold limit values of asbestos dust, fibers or particles to which workers were exposed while using, working with and/or around, installing and/or applying your asbestos-containing products. ANSWER: 35 This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence, and improperly assumes that this Defendant's asbestos-containing insulation products emitted asbestos dust, fibers, or particles. Without waiving this objection, this Defendant.states that it did not conduct such tests. 32. For each test described in Interrogatory No. 31, please give the name of the person conducting the test, the date of the test, and attach true copies of any documents, including but not limited to, reports, findings or memoranda concerning such tests or studies. ANSWER: Not applicable. See response to Interrogatory No. 31. 33. Please state the year that Defendant was first advised of either threshold limit values or maximum allowable concentrations of both asbestos dust and total dust by the American Conference of Governmental Industrial Hygienists and state the name of the employee/official ofthe company receiving such advice. ANSWER: This Defendant objects to this interrogatory on the grounds that it. is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that it is unable to state the date or source of its first knowledge ofguidelines for Threshold Limit Values. 36 33.1 State whether this defendant at any time caused to'be conducted on. any job site, any air sampling, dust counts, tests or other activities to determine air quality or worker safety. Ifyour answer is in the affirmative, please indicate: (a) the date of any such air samples, tests, or activities; (b) by whom such activities were performed; (c) where such activities were performed; (d) the results of any such activities. ANSWER: ' This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that to best ofits knowledge no. 34. Does Defendant maintain a library dealing with industrial hygiene, medicine, safety and engineering and/or research? If so, state: (a) The date each such library was established, (b) The location of each library; (c) The name(s) of the library(s) since 1930; . (d) List all journals subscribed to by you concerning asbestos, industrial hygiene, medicine, safety, and/or engineering; (e) List all books and articles dealing with asbestos and asbestosrelated diseases and the date acquired. ANSWER: 37 This Defendant objects to this interrogatoiy on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter ofthis case nor reasonably calculated to lead to the discovery ofadmissible evidence. Without waiving this objection this .Defendant states that it does not maintain a library dealing specifically with industrial hygiene, medicine, industrial safety and industrial engineering; however, this Defendant has for a number of years maintained a corporate library which may contain material dealing with these subjects. The library is located in Windsor, Connecticut. The name of the librarian is Barbara Drelich-Dembek. A number of publications involving occupational health generally have been received over the years. Specific articles containing information with respect to asbestos products would be difficult to ascertain; however, some of the articles would include: Occupational Health, May R. Meyers, M.D., The Williams & Wilkins Company, Baltimore, MD, 1969, pp. 48-50, 58, 294, 296; Industrial Environmental Health, Lester V. Cralley, George D. Clayton and John A. Jurgiel, Academic Press New York and London, 1972, pp. 4-9, 94, 292, 313, 344; Accident Prevention Manual for Industrial Operations, National Safety Council, Chicago, Illinois, 1974, pp. 1030, 1045, 1128; Fundamentals of Industrial Hygiene, Julian R. Oleshifski and Frank E. McElray, National Safety Council, Chicago, Illinois, 1971, pp. 1123, 751 861; Occupational Cancer, U.S. Department ofLabor, July 1975, Vol. 3, No. 7; Asbestos: Airborne Danger, U.S. Department ofLabor, 1972; TLV's ACGIH, including 1976; Job Safety and Health, U.S. Department ofLabor, pp. 13-14, March, 1976; OSHA Federal Register, Title 29 Labor Part 1910, Subpart G - Occupational Health & Environmental Control, 1910.932 - Asbestos; Industrial Hygiene Progress Reports, Environmental Science Laboratory, Mt. Sinai School ofMedicine, New York; Occupational Safety and Health Reporter, BNA, Washington, D.C. 35. Did Defendant in the 1920's or 1930's commission, or participate in the arrangements with Metropolitan Life Insurance Company for studies at the Trudeau Foundation at Saranac Lake, New York, concerning the effect of inhalation or ingestion of asbestos fibers upon human and/or animal bodies. ANSWER: 38 This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states no. 36. When was Defendant first aware of reports of studies of the Trudeau Foundation at Saranac Lake, New York, entitled "Effects of the Inhalation of Asbestos Dust in the Lungs of Asbestos Workers" by A.J. Lanza, Assistant Medical Director published in the J. Public Health Report, Vol. 50, No. 1, dated January 4, 193 5 ("Lanza Report")? ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discoveiy of admissible evidence. Without waiving this objection, this Defendant states that it does not know when it first became aware of such studies but believes it only became aware of such studies through the course of asbestos related litigation after it ceased manufacturing asbestos containing insulation products. 36.1 Did you ever contract with Saranac Laboratories to study the hazards of any dust producing product manufactured by you (whether asbestos containing or not)? If so, identify by date and author all documents concerning or any way related to such study. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to 39 the discovery of admissible evidence. Without waiving this objection this Defendant states no. 36.2 Did you ever contract with Saranac Laboratories to analyze dust or products? If so, identity by date and author all documents concerning or any way related to such analysis. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks* information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection this Defendant states no. 37. Please state whether the Defendant at any time has been a member of any "trade organization" or "trade association" composed by other manufacturers, miners, distributors, and/or sellers of asbestos-containing products and, if so, please identify the name an .ddress of each such association or organization, the dates of membership, and the names of any publications issued or written by such association or organization. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that it belonged to no associations, foundations or organizations relating to asbestos. 38. With respect to each trade organization or association listed in answer to Interrogatory No. 37, please state whether the minutes ofthe group's meetings and any 40 correspondence between the members of such groups concerning the hazards of asbestos exposure are available. ANSWER: Not applicable. See response to Interrogatories No. 37. 39. Please identify by name the technical and trade association periodicals to which the Defendant subscribed, and state whether Defendant had knowledge of any articles being printed, or withheld from printing, in said periodicals pertaining to the potential hazards of asbestos. If so, please state the following: (a) The title of each such article; (b) The periodical in which each such article was published; (c) The date each such article was published; (d) A detailed explanation of the reason for withholding any such article for printing; ' (e) Produce documentation which refers, alludes or mentions articles which were withheld for publication. ANSWER: See response to Interrogatory No. 30. . 40. Please state whether, prior to 1975, the Defendant sponsored, or attended any meeting, seminar, conference, convention or legislative hearing where the subject of occupational health and exposure to asbestos was discussed and, if so, please state the date and place of such meeting and the name and address of any speakers or participants. 41 ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that while it would be impossible to determine whether any employee of this Defendant at any time ever attended any meeting, seminar, conference, convention or legislative hearing, this Defendant to the best of its knowledge, never sponsored or sent a representative to such meeting, seminar, conference, convention or legislative hearing. WARNINGS/SALES PROMOTION 41. As to each product listed in response to Interrogatory No. 5, please state whether Defendant, at any time, published and/or distributed any printed materials, including but not limited to brochures, pamphlets, catalogs, packagings or other written materials of any kind or character that contain any warnings, cautions, caveats or directions concerning the possible health effects of the products on a person. If so, please state as to each product: (a) The name of each relevant product; (b) The wording of each such warning; (c) A description of each such printed material; , (d) The method used to distribute the warning to persons who are likely to use the products; (e) The date each such warning was issued; (f) Whether any warning accompanied any of your asbestos-containing products' sales literature, handout or pamphlets; (g) Please attach a copy ofthe warning and date said warning was issued; 42 (h) The name, address, and job classification of each person who presently has possession of the above-described documents; (i) The name or names and addresses of the company who provided, produced, or manufactured the boxes or containers on which the warning appeared and dates these boxes with the warnings appeared. ANSWER: Yes. (a) See Exhibit A attached hereto;. (b)(c)(g) See Exhibit B attached hereto; (d)(e) Beginning in 1969, exact date unknown, this Defendant began printing, stamping or stenciling warnings on all of the packages of its asbestos-containing insulation products. The warnings were prominently displayed on the packaging.. (f) This Defendant did not advertise its asbestos-containing products. (h) See Exhibit B attached hereto. (i) This Defendant has 10 information regarding the company which provided, produced or manufactured the containers, and therefore, cannot answer this interrogatory. See responses to (d) and (e). 42. Has sales material been prepared by Defendant or its agents for purposes of marketing or advertising the asbestos products listed in answer to Interrogatory No. 5? If so, please state: (a) The name and address of each person or entity who prepared same; (b) The name, address and job title of each person who presently has possession of same; 43 (c) The date same was prepared; (d) The media used to disseminate the sales material. ANSWER: . This Defendant did not advertise its asbestos-containing insulation products. Also, see response to Interrogatory No. 43. 43. Has any written material of any kind or character been prepared by Defendant, Defendant's predecessor or any of Defendant's subsidiary companies or their agents indicating how the products listed in answer to Interrogatory No. 5 should be used or maintained by the ultimate user or those working in facilities or at job sites where the product was used, installed or removed, including, but not limited to, those sites listed on the job site list attached as Exhibit A. If so, please state the following: (a) The name, address and job classification of each person who prepared same; (b) The name, address and job classification of each person who presently has possession of same; (c) The dates and manner in which said material was distributed to purchasers of the products in answer to Interrogatory No. 5. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that although this Defendant did not advertise its asbestoscontaining insulation products it did distribute technical information and materials from time to time. Defendant prepared a booklet in 1970 and also had some incomplete material prepared in 1964. To the best of this Defendant's knowledge, the information contained in the 1970 materials was prepared by Donald Peterson, formally the Administrative Assistant to the 44 Vice-President of Sales, and Kenneth Cohn, formally Office Manager of the Sales Department. This Defendant has no records regarding who prepared the 1964 materials. Copies of such extant materials are attached as Exhibit C. 44. Was any written material of any kind prepared by Defendant and distributed to those individuals listed in response to Interrogatory No. 9? If so, please state the following: (a) Identify the written material by content and date; (b) To whom was it delivered. ANSWER: See response to Interrogatory No. 43. 45. Does Defendant contend that asbestos-containing products can be manufactured so as to eliminate all potential health hazards to persons working with or around, installing or applying same? If so, please state the following: (a) The date that Defendant first determined that another product could be used in place of asbestos; (b) The chemical of the substitute; (c) Whether the substitute is suitable for the purpose for which they are to be used; (d) Whether Defendant used the substitute for asbestos to 1971; (e) Whether Defendant ever used the substitute for asbestos for high or low heat insulation. ANSWER: 45 This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject .matter of this case nor reasonably calculated to lead to the discovery of admissible evidence because this interrogatory relates to products not manufactured by this Defendant, which this Defendant cannot be expected to be knowledgeable about. Without waiving this objection, this Defendant denies that its products posed a potential health hazard to those working with these products. This Defendant states that it knows of no totally equivalent substitute for asbestos. 46. Did Defendant give any warnings to any individuals at the sites listed on Exhibit A, including any individuals who owned, operated, or managed the facilities at the sites listed on Exhibit A, regarding the potential health hazards of any product listed in response to Interrogatory No. 5. If yes, please state: (a) Name of person most knowledgeable about this communication. (b) Name of person at the sites listed on Exhibit 1, attached hereto most knowledgeable about this communication. (c) Dates of each communication. (d) Contents of each communication. ANSWER: This Defendant has no information or documents form which it can respond to this interrogatory with specificity. See response to Interrogatory No. 41. KNOWLEDGE OF PREVIOUS INJURIES 46 KNOWLEDGE OF PREVIOUS INJURIES 47. Did any person prior to 1970, file a claim against any Workers' Compensation carrier covering Defendant alleging that he or she contracted a disease as a result of exposure to asbestos? If so, please state the following: (a) A list of each such claim by claimant's name, date filed, the caption and jurisdiction involved; (b) The disease alleged in each such claim; (c) A brief summary of the disposition of each such claim; and (d) The name, address and job classification of the person or persons having custody ofthe records pertaining to each such claim. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, to the best ofthis Defendant's knowledge, no. 47.1 Please identify all documents concerning or in any way related to any decisions made by you to cease manufacturing asbestos-containing products. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that the production of some of this Defendant's asbestos-containing insulation products was halted during the mid-to-late 47 47.2 Has any person or company from which you purchased asbestos containing products ever issued a recall of their products or taken any action to take those products offthe market after said products were in your possession? If so, provide: . (a) the date of said recall; (b) the name of the company which issued the recall; (c) a copy of the recall. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery ofadmissible evidence. 47.3 State what action, if any, you have ever taken since 1930 to minimize or eliminate any risk of occupational disease or pneumoconiosis to those at any time engaged in the manufacture or production of asbestos-containing products. ' ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states beginning in 1969, all production workers in Defendant's plants who worked with asbestos were required to wear respirators. The requirement to wear respirators was mandatory. Also, because Defendant also manufactured refractory products at its plants, respirators were always available to production employees during the entire time that this Defendant manufactured asbestos-containing products. 47.4 State what action, if any, you have ever taken since 1930 to minimize or eliminate any risk of occupational disease or pneumoconiosis to those at any time engaged 48 in the use, as distinguished from the manufacture, or exposed to the use of asbestos - containing or industrial insulation products or who were otherwise exposed to asbestos- containing or industrial insulation products. (a) describe such action; (b) state when such action was taken; (c) state what written material exists related to such action; (d) state the names, job titles and last known address of the individuals who undertook such actions. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection this Defendant states beginning in 1969, exact date unknown, this Defendant began printing, stamping or stenciling warnings on all ofthe packages of its asbestoscontaining insulation products. Those warnings specifically recommended the use of respirators. See Exhibit B. To the best of this Defendant's belief, marketing, legal and various other departments were involved in the decision to use warnings. 48. Did Defendant receive notice prior to 1968 that any person was claiming injury as a result of using asbestos products manufactured, sold, installed, and/or. distributed by Defendant? If so, please state: (a) The name and address of each claimant; (b) The date of notice of each claim; (c) A description ofthe claim; (d) The type of injuries allegedly sustained; 49 (e) The name and address of each attorney representing the individuals making such claims; (f) The style and court number of each such claim; (g) The resolution of each claim. , ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that to the best of its knowledge, it first received notice of such a claim in 1967 when it was served with a summons and complaint regarding alleged health impacts resulting from exposure to asbestos. The case was filed in Beaumont, Texas in Federal Court by Claude Tomplait. 48.1 Describe the method by which you have maintained records concerning the manufacturer, sale, supply, distribution, use, advertising, delivery and/or installation or tear-out of each of asbestos-containing products. For each description provide the following: (a) each present and former company or corporate department, division or subdivision responsible for maintaining such records; (b) the manner in which the records are kept (e.g., boxes, computer tape, microfilm, etc.); (c) the inclusive dates of any such manufacturer, sale, supply, distribution, use, advertising, delivery, and/or installation or tearout which such record keeping system covers; (d) the present location at which all such records are maintained; (e) the identity of each person employed by you at any time from 1930 to the present who is or was responsible for the collection and maintenance of such records. 50 ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection this Defendant states that during the time period that it manufactured asbestoscontaining insulation products, it had no written record retention pciir \ However, it generally retained its records for a six-year period, after which they were destroyed, except for records required by law to be kept, such as Internal Revenue Service Records, and certain contract documents. Available invoices regarding the sale of asbestos containing products are located at Defendar.:s' national coordinating counsel, Arter & Hadden in Columbus, Ohio. 48.2 State whether any records concerning the manufacture, sale, supply, distribution, advertising, delivery, use or installation or tear-out of asbestos-containing products have been destroyed or discarded and if so, indicate: (a) the date and location of such destruction or discard; (b) the custodian and location of such records prior to their destruction or discard and the identity of each employee, representative, offtcicl or agent who ordered, authorized or supervised such destruction cr discard. ANSWER: This Defendant is unable to determine what records may have been destroyed in the past. See response to Interrogatory No. 48.1. 48.3 For all documents, other than invoices, work orders and/or purchase orders, which relate to matters relevant to the all the preceding interrogatories: (a) Is there any kind of index for the documents? (b) How many pages is the index of documents? (c) How many documents are referred to in the index? 51 (d) Is the index maintained in electronic format (i.e. database, word processing or other computerized format)? (e) What manner of electronic format is used? ANSWER: See response to Interrogatory No. 48.1. 48.4 For all invoices, work orders and/or purchase orders, which relate to matters relevant to the all the preceding interrogatories: (a) Is there any kind of index for the documents? (b) How many pages is the index of documents? (c) How many documents are referred to in the index? (d) Is the index maintained in electronic format (i.e. database, word processing or other computerized format)? (e) What manner of electronic format is used? ' ANSWER: See response to Interrogatory No. 48.1. PLAINTIFF/DECEDENT 49. Has Defendant obtained statement from any witnesses including the Plaintiffs? If so, please: (a) list each witness who has given a statement and the name, address, and job title of each person having custody of any such statement. 52 ANSWER: This Defendant objects to this interrogatory on the grounds that it seeks protected attorney work product and privileged attorney client communications. Without waiving this objection, this Defendant has not obtained any such statements other than deposition testimony. 50. Do you contend that the PlaintifF/Decedent improperly used those products listed in response to Interrogatory No. 5? If so, please set out in detail in what respect the product was improperly used. ANSWER: When discovery is completed, all proper contentions will be made. 51. As to the sites listed on Exhibit A, and as to each PlaintifF/Decedent, please state whether Defendant contends that there was any substance other than asbestos which contributed or caused PlaintifBDecedent's injuries. Ifyour answer is yes, please state the following: (a) The facts upon which you rely; (b) The identity of the sources upon which you rely which substantiate these facts. ANSWER: When discovery is completed, all proper contentions will be made. RESPIRATORS w 53 52. Would any respirator, mask or other breathing devices prevent inhalation o of the asbestos dust and fibers contained in products listed in answer to Interrogatory No. 5? If so, state: (a) When the respirator was sold; (b) A detailed description of such respirator or other breathing devices, including name of manufacturer and model number; (c) The basis of your claim that such respirators or other breathing devices will prevent the inhalation of such dust and fibers; (d) Identify any tests performed regarding the efficaciousness of such respirators and other breathing devices in preventing the inhalation of asbestos dust and fibers including date, title, author and number; (e) List all documents which mention, allude or refer to tests performed on breathing devices which prevented the inhalation of asbestos dust and/or fibers. ANSWER: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence and further on the grounds that it incorrectly assumes that this Defendant's asbestos containing insulation products emit asbestos dust and fibers and improperly calls for an expert scientific opinion. Without waiving this objection, this Defendant states that the warning label attached as Exhibit B specifically referenced the use of respirators. , 53. Does Defendant expect to call expert witnesses at the trial of this case? If so, please state the following: (a) Their identity, last known address; (b) The subject matter on which the expert is expected to testify; 54 (c) The expert's specific conclusion, and specific opinions and the specific basis therefore; (d) The expert's qualifications to render the opinions set forth above; (e) Whether any person identified in sub-paragraph (a) above has provided a report or other documentation to you, and if so, identify such document or report; (f) Identify all documents that you have provided to each person identified in response to sub-paragraph (a) above; and (g) Describe in detail the education and work history of, and identify any books, treaties, article, published and unpublished reports, studies or other scholarly works authored by any individual identified in response to subparagraph (a) above. Alternatively, in lieu, of said response, attach a copy of a resume or curriculum vitae and a list of publications to your answer. ANSWER: Because discovery in this matter is ongoing, this Defendant is unable to identify its witnesses at this time, but will timely identify such witnesses and relevant information regarding their testimony prior to trial. 54. Please state the name and last know address of each expert witness who is not retained or employed for that purpose who is an employee of Defendant and will render an opinion within his expertise at the time oftrial. ANSWER: Because discovery in this matter is ongoing, this Defendant is unable to identify its witnesses at this time, but will timely identify such witnesses prior to trial. 55. Does Defendant admit that service of process was properly had on it in these cases? If not, please state why. 55 ANSWER: Yes. 55.1 For each and every affirmative defense asserted in the answering defendant's Answer to Plaintiffs' Complaint, the Cross-Claims or Counter-Claims of any party against this answering defendant state: (a) the facts upon which the answering defendant relies for each and every affirmative defense; (b) each and every document which will be offered to prove each and every affirmative defense; and . (c) each and every witness who will testify in support of each and every affirmative defense. (d) the substance and subject matter of the anticipated testimony of each witness identified in the preceding response. ' ANSWER: Defendant is unable to answer this interrogatory fully and completely based upon incomplete discovery. Defendant will provide an appropriate response once discovery is completed. 56. Does Defendant have policies of insurance that might cover the claims that have been made by the Plaintiffs herein? (a) If so, please list the name of each insurance carrier who may have coverage, the amount of such coverage, and the dates of each such policy. ANSWER: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to 56 the subject matter of this case nor reasonably calculated to lead to the discoveiy of admissible evidence. Without waiving tins objection, this Defendant states during the time that this Defendant manufactured asbestoscontaining insulation products, it carried liability insurance with the Travelers Insurance Company, Hartford, Connecticut, primary policy $500,000; umbrella policy $5,000,000; plus various layers of excess insurance, all subject to varying deductibles depending upon the year of coverage and subject to the terms, limitations and conditions ofthe respective policies. Have you ever been involved in any litigation concerning potential arage for asbestos products liability matters? If so, please state: (a) the case caption, court and date of filing of each case in which you have been involved; (b) whether you were plaintiff or defendant; (c) a brief statement of the issues; . (d) identify by date, author and recipient(s), (including recipients of carbon copies) all documents listed as exhibits by either party in this litigation; . (e) identify by deponent and date all individuals who were deposed in these cases; (f) identify by date, author and recipient(s) : documents that have been placed on a protective order in such migation; (g) identify all expert witnesses retained for use at trial in any of the above litigation by name, address and telephone number. This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discoveiy ofadmissible evidence. STATE OF CONNECTICUT COUNTY OF HARTFORD VERIFICATION ) )SS. ) M. John Hornik, of Combustion Engineering, Inc., being first duly sworn says that he is authorized to execute this Affidavit on behalf of Combustion Engineering, Inc. and that the foregoing Responses of Defendant Combustion Engineering, Inc. to Plaintiffs' Master Set of Interrogatories and Request to Produce are true based upon information and belief. M. John Hornik Sworn to before me and subscribed in my presence on this day of __________ , 1997. Notary Public - **.> y,` ; V -Ti % >. V ', - C.- '" - ' A h * ' . " " --- INSULATING BLOCK EXHIBIT A ' C-E ESTIMATED START STOP PERCENT AND TYPE OF ASBESTOS CONTAINER (a) #12 Insulating Block (R) (a) #19 Insulating Block (R) (b) Criptex* Mineral Wool Block (R) (s) Kaiser M. Block (D) 1963 1963 1964 Unknown 1966 1966 1972 1971 6.2CA) 4.6(A) 2.0(C) 2.0(0 Cardboard Carton Cardboard Carton Cardboard Carton Cardboard Carton INSULATINC CEMENTS (a) Stie-tite* (R)-(D) 1963 8/30/72 (a) Supar Stlc-tite (R)-(D) 1963 8/30/72 (b) Super Finish Stie-tite (R) 1963 6/27/72 (b) Super Finish (R) 8/10/65 1/10/68 (a) Super 711 (O) 1964 6/27/72 (a) Kaiser Flastic Insulation (D) 1964 1971 (a) Utility Thermal Finish Cement CD) 1964 2/28/72 (a) Kaiser Hard Top (0) 1964 2/28/72 (a) Casing Cement (0) 1964 1969 (a) MHD Finishing Cement (D) 1964 1968 (a) Pyroseat* Fireproofing Cement CD) 1964 6/8/72 (a) Bilite Insulating Cement CD) 1964 1968 (a) A-1199 Insulating Cement (R) 1963 1966 (a) SDK 50 (R) 1963 1966 Ca) Buck Stay Cement A-1360 (R) 1965 1966 (a) Castahloc* (R) 1965 1/19/66 (a) Stirrup Cement (R) 1965 1966 (a) Calcrete 30 (D) 1964 1970 38.6-42.2(0 9.89-10.2(0 11.5-13.1(0 .. S 14.2(C) 13.7(C) 13.7(C) 5.0(C) 5.0(0 5.0(C) 68.03(0 3.0(0 9.1(C) 43.4(C) 0.4(A) 0.8-1.54(A) 1.2(A) 42.7(0 7.8(0 50 lb. bags 50 lb. bags 50 lb. begs 40 lb. begs 50 lb. bags 50 lb. bags 50 lb. bags 50 lb. bags SO lb. bags 50 lb, bags 50 lb. bags 50 lb. bags 50 lb. bags 50 lb. bags 50 lb. bags ' 50 lb, bags 50 lb. bags 50 lb. bags MISCELLANEOUS PRODUCTS Ca) Block Stiek (R) Ca) Cuninsul (R) Ca) Mix A (R) Ca) Fibrous Adhesive (D) (a) Hy-Tsap Flexible Ceaent CR) Ca) Expansion Joint Material CR) 1963 6/28/72 22.0(0 1963 1963 1964 1963 1966 6/27/72 1965 1972 Approx. 1.0(A) 6.0(0 15.0(C) 30.0(C) 1963 1966 100.0(A) 6 gal. staal containers 50 lb. bags 40 lb. bags staal containers 5 gal. staal containers 25 lb. bags 1 X insulating refractories () Lite Wete 22 (W) (b) Lite Wets 50 (W) PRODUCTS DISTRIBUTED BY C-E (d) Asbestos Rope (d) Peraisesl (fibers in emulsion) (d) Weetherkote , (fibers in emulsion) (Thermelkote sinee 1976) (d) Duriseel (fibers in enulsion) (d) Theme 1 Cost (fibers in enulsion) (d) Air Cheek (fibers in emulsion) C-E START 1969 ESTIMATED STOP- 6/26/72 1969 1972 PERCENT ADD TYPE OF ASBESTOS CONTAINER 10.0(0/ 27.0(0 50 lb. begs 10.0(0 50 lb. begs 1964 1964 1963 1965 1974 1977 1964 1964 1963 1973 1964 1971 100.00(C) Approx. 3.0(0 Approx. 3.0(0 tied 100 ft. 5 6 54 gel. steel conteiners 5, 30 & 55 gel. steel conteiners Approx. 3.0(C) Approx. 3.0(C) Approx. 3.0(C) 5, 30 6 55 gel. steel conteiners 5, 30 & 55 gsl. steel conteiners 5, 30 & 55 gsl. steel conteiners EZTi - __ .............. (r) - & 4 1| Port Kennedy,' pennsylvsnis (D) - Detrickj Aurors, Illinois (V) - Welsh) St. Louie, Missouri () - enufsetured (d) - distributed (C) - eonteining ehrysotile (A) - eontsining eaosite (*) - Tredenerk s3.; `r i .~-f- > i EXHIBIT B 3 o g5*- n > S' SLS OQ3 S$22. -o O-- CT 3 po sS <D Q (A cr SJ* CD (A o <D <A o CA oQm 3"5. 3 c n Q < o cr CD A o 3 Q ar Q Q# *D -t 5* 3^ (A O <* Q o (A M D" CD Q CA CL CD o CA JQ C 3. cr CD CD CD < CD .?C 3 8 if CD </> CA C A m s CD (AA I* n 't",/.'*/w*,v, ,'. BS^DUSTPS8AL IGV9SULATJOBVSS TECHNICAL DATA REFRACTORIES A DIVISION Of COMBUSTION CNCINCCNINC. INC. afi.ni^iunns;it3 1 A 04VISION OA COMBUSTION CNOlNCCftlNa. INC. rw ASBESTOS HOPE too* POPE is A COMMERCIAL GRAOE. WHITE CHRYSOTILE AS6EST0S fHER. 1000* ROPE IS A PURE 96/100% WHITE CHRYSOTILE ASSESTOS RISER. APPLICATIONS OF CE ASBESTOS ROPE . . HERE ARE SOME OF THE MANY SERVICES STEEL MILLS AND FOUNDRIES Um (or C-E Asbestos Rope are almost endless. Sealing molds, vacuum-pouring equipment {where can *un an entire bill*:), und molds oil from pouring ladles, calking joint* In targe cores which must be segmented. . ATOMIC ENERGY e * ' ' . 1000* is standard in the Industry because it withstands an integrated neuvon flu* of 10** Nfv units. MARINE SERVICE C-E Asbestos Rope is essential in the Engine Room for general boHer ""'**"* expansion joints, wrapping hard-to-reach steam lines and in emergencies, for Ru P* lines. amaged GENERAL INDUSTRY ! Anywhere heat sealing is required, whether heat-treating furnaces, boilers or processing operations. POWER PLANTS . ` Between boiler walls end brick-work to allow for expansion and contraction, wrapping staam and axhaust tines where space limitations preclude formed insulation, covering small duets, calking hard-to-reach spaces, insulating hot pipes passing through fire-walls and bulkheads. It is the standard for use in grooves for door scaling, between boiler sections, expension joints end in handling hot gases. * ASBESTOS ROPE CAN HANDLE EFFICIENTLY AND ECONOMICALLY CHEMICAL INDUSTRIES M 1000'k W .* contains no organic components, H a used as Y*rmC "2* * oth-r dwnicaWtandling operations such as the chemically inert characteristics othT application* whJe this property is packing for carboy-stoppers, and in Cryoen services, ano app* eaquired. ALUMINUM PLANTS Anywhere th* control of heat and sealing is needed-heat-creating ovens, grooves for door sealing, pouring vauum seals on crucibles, and in many other dry heet-sealing applications, C- Rope * recommended. T- w C^-xE'^RyEFVRAsiC5TfeORfVIEASL^LAE\YQ.IfVO1RS6I0EHr;F.0.W? NSYLVAHyA I9<B1 - - .^rV E- HU--wr ca*4 u*tih CMoiMruiiNa. snc. CRIPTEX BLOCK INSUU' C^h^^aem.bined__wrfiituhijphoigrhnttfeiTmpineraintusruelabtioonndionfgfemriantgerialusn, ipqruoe*Wcoempbraincatli"c*e** t-ri*:*S**c*- m*W****l oJrtS EX, Strength and Strong pdherion < <*r~" ftni^ T* combuuuon ,, mmltm P'Wrw** /*__ j. ___ ,, without nre-drUmg. The Mutr<i PH of Giiptn jtfr* Hunt against corrosive ectmn. This parttaiiarty * ^ aluminum jacketing. '` *' (tytkauHc setti.ng eements anJd castable refractories may bKe* aoappaiiado doirrewc. tlyr *> Gnptex_ Slock without premature ion of mixing water needed for proper hydration. EFFICIENT The felted fiber core of Griptex Block offers the maximum buffering action against heat penetration up to 1800*F. The thermal conductivity at 200*F. meant temperature k .37 BTU; at 600* F. h b .49 8TU. . APPLICATION METHOOS . Griplcx may be simply impaled over standard welded pins and aeeured with speed dips or may be **ed in place with metal bands. A sharp knife is the only tool needed to fabricate Grlptex " equipment. Simply press over bolt heads and projections without additional cutting. Outdoor applications should be weatherproofed. . RECOMMENDED USES BOILERS Drums Headers Walls Economisers Air Preheaters FURNACES Heating ' Heat Treating Forging Annealing Norma!icing OVENS, KILNS A ORYERS FIREPROOFING TANKS & VESSELS TURBINES A PUMPS FAN HOUSING DUCTS ft'SREECHINGS SPECIFICATION REFERENCES High Tamperatwre mineral fiber block (nutation shall be GRIPTEX complying with the performance requirements of ASTM 0397. Class 2; Federal Specification HH-1-564 and/or Commercial Standard CS-117 .of the U. S. Department of Commerce. A C-C trade name. ^*7>;783O4S0.: .TWX S10460-4S37> wcs-ftMCi OKIES A DIVISION Of COMSUSTlON CMOINCCftlMO. INC. SUPER FINISH STIC-TITE A SMOOTH, ONE-COAT PLASTIC FINISH INSULATION Super FMah Stic-Titc provides a pnooth, Herd. fibrous finish covering (or Iruuiatinf Markets. Modi, atwf,^ Stie-Tle and other insulations. It k a dry. (indy (round, pur white mixture of high quality inwiI wool ^ dbtefflMNut earth which, when mixed with the proper amount of water, b raady for instant use. Uk* standard Stk-THt, It forms a spongy matt of daad air eefls which stops air infiltration and reaulunt hast toss. NO ROUGHING COAT-FINISHES SMOOTH Supar Finish Stic-Tiu h applied in a single coat. ll am be tro**bd ***y smooth for phasing whiu appaaranc*. No roughing coat is needed. thereby saving rmtarlafs and tabor. It doat not dvink or crack. Thara is no pointing up or patching nacassary aftar Supar FWtnh Stic-Tha hat dried. USE SUPER FINISH STIC-TITE WHEN a perfectly pnooth, one<ott plastic finish insulation is specified for temperatures tip to 170C*P. WHEN necessary to cover blankets, block or standard Stic-Tha In order to provide a smooth, hard, white surfact. - OOESNT COME OFF Super Finish Stk-Tit* adheres strongly to overhead, vertical txS curved surfaces and rounded comers. Once it has dritd, the bend is unaffected by vibration. Impact or moisture. . CAN BE APPLIED ON COLO OR HOT SURFACES . Because it doesn't shrink during drying. Super Finish Stk-Tit* can be applied directly to cold or hot metal or brick surfaces up to 175*F. It dries hard, without shrinking, in about 2 hours. When applied to hotter surfaces, a rough coat of standard Stic-Titc is recommended. ' GOES A LONG WAY ' . Super Finish Stie-Titc gives excellent coverage. One hundred pounds cover an 80 sq. ft. surface with s 1/2" thick layer; 120 sq. fi with a 3/f thick layer; or 160 sq. ft. with a l/4~ thick layer. This is by far the lowest cost coverag* of any other one-coat finish insulation avaBabtc. . HOW TO APPLY SUPER FINISH STIC-TITE 1. Mix Supar Finish Stic-Titc thoroughly with 5 to 6 gals, fresh water per 25 lb. beg. 2. Alow the cement mix to soak for one-half hour before using to imxs maximum workability. 3. Mix no more than will be applied in 4 hours. .4. If any of ih* hatch has dried out, do not remix it with water or (rcdi. dry material at the resultant finish will not be hard. Use only (red* batches. 5. For smoothest finish. Vowel the cement to at least 3/8" thickness. 6. Where tried as a finish coat over mi insulating cement roughing coat, be sure the undercoat h*s aat Overnight before applying Super Finish Stk-Tite. 7. Where e given area cannot be finished In a continuous application, the Joints should be feather-edged 1104*0 SUMMARY OF PHYSICAL PROPERTIES Use Limit Sintering Temper*tuff Therm*! Conductivity'Compressive Strength Oenslty StaMity Retiittnce to Moisture Resistance to Corrosion Handling Characteristics Up to 1800*F. 2100*F. S* Accompanying Graph 18 psi 1.25 IbsJbd. ft. Inert durable Water-repellent Non-corrosive Excellent ' 'THERMAL COHOUCTIVJTT-CtIPTEX ItOClC I u 3 a z o u < MEAN TEMPERATURE -- f STANOARD SIZES 6-X12** 8"x18** 6~*38" 12~*12" 12"x18~ 12"x24~ 12-*3618~x2424"x36" thicknesses range from 1 to 4**--in 1/2" increments. TEAR TAPE CARTON GripttK block n packaged in the new___ easy open____ tear tape carton. ThH easy open carton simply tips in halt, forming two convenient containers ... (fss waste . . . lets damage ... (ess la** time. --- -- rn. a-a(W> OaJ 14 8 l *3 t A.*VIl#e Of COM1USTION ZMQINSSRINQ, INC. SUPER 711 INSULATING Cm^ SUPER 711 tnautating Cement W a mixture of high temperature mineral <a"r* pWy ****** hf wool nodules, combined with asbestos end suitable binder* to form h*^ '*fl'P*r*k**.^**t,c ^^bon, Wet* Mod according to directions gives voweUMe consistency ttut I* rtody for eppieabon on oqwpmont to N operated at tamperatures up to 1SOO*F. - WIDE USAGE SUPER 711 U a vtrutilt material for many types of insulation raouifwrwnU. Applied over block or blanket Insulations. It fin* opon Joints and provides monolithic *jrfac for wh*tovrtyp* of aubseouent finish h specified. Its plastic flexibility permits opplicition diroctfy to regular or curved axfeets - tueh os valvn. fittings, tanks and vessels. EASY TO APPLY SUPS* 711 has excellent adhesive qualities. Its increased stiekabifity means a better Job in less time, from wet to dry. Will not slip or roll under vowel epotication and may be easily fun applied. This superior workability is a result of fine mineral nodules, special manufacturing methods and quality control. MAXIMUM COVERAGE LOW SHRINKAGE . .* . * ** * SUPER 711 Insulating Cement eiajres maximum coverage and low dirlnkage. The resilient nodules of mineral fiber do not collapse whan mixed with water. See table of Physical Properties for coverage. RECOMMENDED USES BOILERS . Drums' ' Headers Walls Economizers Air Preheaters OVENS. KILNS 4 DRYERS VALVES i> FITTINGS TANKS 4 VESSELS FURNACES Heating Haat Treating Forging Annealing Normalizing TURBINES 4 PUMPS FAN HOUSINGS DUCTS 4 BREECHINGS SPECIFICATION REFERENCES .. SUPER 711 Mineral Fiber Insulating Cement conforms to ASTI* C19S-<S; Federal Specification HH-C-168 {Ora Ci: and/or Commercial Standard CS-117 of the U. S. Department of Commerce. 2JV783O4S0. r2y &105gCM837:i- PHYSICAL PROPERTIES OF SUPER 711 INSULATING CEMENT Service Temperature Kiw Ratio Cry Gaarae Malarial Requirement* Compressive Strength Canity (Applied and Dried) Shrinkage (Wat to Cry. by Volume) Thermal Conductivity RadaJmabta to Adhesion to Steal (Wet) Adhaaion to Steal (Dry) Corrosion Resistant* to Steal Shipping Container* (Sewn Closure) 1800*F. 12 gal*, par 50 Ibt. bag SO #q. It. 1" thick par ICO a*. 2 lbs. par aq. ft. 1" thick 45 psi 24 tbs. par cubic loot 1SX Sat Chart 1000*p. 6 pti 8 pti Non-corrosive 60 lb. popaf bags Tabulated valuas repratant typical performance leva!* of SUPER 711 Inautating Cement Trowel Grade. SUPER 711 Grade Cement consixts of the tame betic materials that smaller mineral wool nodules are utilised to facilitate application. - THERMAL CONDUCTIVITY OF SUPER 711 INSULATING CEMENT THERMAL CONDUCTIVITY - (BTU tn ./ q . f t . / r *. / h r . ) mean temperature -f. 1000 1200 1400 Lsa-Lfej-REFfiflCTORfES A WVIIKW or COMSUtTlON CNOlNCZfttMQ, INC. UTILITY THERMAL FINISH CMk7 (UMtitUatryLfTch. eUrmtiafiltyFbctobmhbCineemsetnhteh'feleoxmtepaositayd. hoifghhigthemqpuearlaittyurme infeermaltafinbcetr..*hdy!jf**"*******f.V!"*'"'^ * uniformly nodulated mineral fiber with strength. low shrinkage, *d Mnwnt. Tfc rwutt k quick setting, smooth finish. thermal resistant. single layer aamperatum up to 1200*F. infrifi ^ riftMh earner*^ F QUICK SETTING * Utility Inflating Finish Carnot davalopt mooth. durable. ^.*n<r apoTaution and without tha presence of heat. Subsequent drying produ&J* <*<* f*ck,ft? * duinkMa In thickness. *d occasional watting does no damage after hydraulic att Long dnrfag panodt undar normal condition* ara eliminated. Saves time in applying weatherproofing parnt, or other f*nh*j. Job* ara aaaiar to achaduta; acaffolding costs ara r^uced. . ONE COAT APPLICATION *' . Utility is normally applied in a single layer application. A thiekhesm are specified. Utility Is virtually an alt-purpoaa msulstinfl^**h"'L u* over Griptexbloek or blanket insulations. Utility k widely uiad formulating valves, fitting.. haatsti equipment. and a. an anti-sweat inaulation for cold water tanka, pump*. - . Utility trowata with a good kay on block Inaulation. blanket *j^<'!^****n cement. It ha* good wet adha.ion to elaan ataal aurfaeat, aueh as valvea and f tt nga. PLEASING APPEARANCE Utility dries to a smooth, fight raflactant surface which as an Interior finUh. requfr** no further treatment. Utility, however, b easily painted If desired. Outdoor appliestiorts should be weather protected, tow temperature applications require a vapor aaal type finah. ' EXCELLENT THERMAL QUALITIES ` Utility has a *K" factor of .79 at 600*F. mean temperature. Thi excellent insulating value as compared to ether finish eements is a vary desirable advantage when figuring job and operating costs. PHYSICAL PROPERTIES Service Temperature Water Ratio (Trowel Application) Dry Coverage (Trowel Application) Setting Time Material Requirements (Trow*! Application) Compressive Strength (Air Cured) Compressive Strength {# 1200*FJ Oensity (Applied and Dried) Shrinkage (Wet to Dry) "K** Factor t <0Q*F. Mean Temperature Corrosion Resistance to Steal Surface Treatment Shipping Containers (Sewn Closure MIXING - t200*F. 7 gels, per SO lb. bag 37 sq. ft. 1/2" thick per SO lb. bag 2 to 4 hours average conditions. . 1J tbs. par aq. ft. 1/2** thick. 135 pd. 105 psl. 35 tbs. par cubic foot. Negfigibl*. .79 But. Non-corrosive. Easily painted or weatherproofed when required. 50 tbs. paper bag. - - "Utility Thermal Finish Cement should be mixed In a dean mortar box or mixer, using approximately 7 Korn of water per S3 lbs. bag for a good troweling consistency over most blocks, blanket*. or insulating cements. Because of the hydraulic binder. Utility should not be mixed with water more than two hours in advanc* of lit application. With cold mixing water (below 0*FJ It remains workable up to 4 hn. STORAGE . ' Store in a coof, dry location until ready to uw. % uaaKFRACTDRIES A DIVISION or COMlUtTlON tNCINtlMHO. INC. j=qig^gollt PERMIStAL - THERMAL COAT Basically thee* art three types of asohalt mastics used In the in&rfction Md. They or# umAy dewirkd at ***_, emulsion, sober* cutback, or chemkal ditpanion types. The thimtinf agent or dnpenfan chemkal determine* which batic classification will be given a particular product, and dictatn tha and wsa of tha teaultant product. It k Important to know which thinning agant it used to datarmina tha uathrl quafUles of a particularly biandad e^heh mastic. Tha quality and/or typa of basic asphalt datarminas tha ervicatamperahjre of tha product WATER EMULSION ASPHALT MASTICS Tha water tmulsion typa of asphalt waathar coating arch os Tharmal Coat, Is normally a bland of patroiaum asphalt, asbestos fiber and Bantonh* day. emulsified In wotar. . Water emulsions era primarily used as a breathing mastic. Lc, If ssfuMe Pfta^>ft,^t beneath Its surface, moisture present will pan through to tha stmotphere. However, otmasphanc presorr# is normally not sufficient to pass moisture back through to tha insulation, except, of eoum. on km tamperatury work. In this case, a vapor barrier type mastic such as Owriacd is essential. . Summer grade water emulsions, becuate of the water present, wJ freeze andshould be pr<*tad et eH times prior to and during application. Alcohol is usually added to Winter grade wnulaiona. Tha arnount used determines the resistance to freezing of the resultant product Water amuhiona tisouH *V b* stored and used at temperatures above freezing in any event A *ter emulsion that hae been frozen k uaaless and will "alligator'' if applied. Water emulsions usually are suitable only for trowel application and are weed wherever J required. Because they lack tke adhesive qualities and resiliency of a cutback typema^tiwy**^ be mechanically bonded to poultry netting except on extremely snail oidecm. .They mow be sited in conjunction with a outback or dispersion type flashing compound. Water with such types of mastics since they do not bond to themselves. It It that they be tepaued as soon as possible If a break in the applied surface should occur to inxire service fife of tise product %* * . Thermal Coat may be applied at temperatures up to 20Cf*F. and win withstand a maximum temperature of 450*F. after drying. - CAUTION: Water emulsions arc soluble in water and should not be pptied If floraJs product within twelve hours of the initial application tim-. Keep Winter Grade CHEMICAL DISPERSION TYPE ASPHALT MASTICS . ' ***** washing the '- Chemical dispersion type asphalt mastics, such as PERMISSAL. Incorporate a ofJ*" desirable qualities of the water emulsion and outback types. They normaby. **^1 dispersed in a non-flammable chemical with suitable fillers, blended In one eorwsteney xiitable for.bnre>. trowel or spray applications. Containing non-flammable solvents, they ere fireeafe <***** torches end timftar hezenfoos}* conditions. They have tha breathing charactertoc of period of sixty to ninety days after application. This controlledcure* proce*p*~mts **^*[^*[**. film and permits trapped moisture to escape. The result is a ***** exceptional toughness. A good chemical dispersion product h not affected by freeing and vW?wi alkalies. However. sofubBUy in water is a factor, depending upon hurmdlty condibcws. " twelve hours or longer after application. Tha anodizing and rust inhibiting agmts contained ___ - thk product excellent for metat protection purposes. PERMtSEAL has a useful service temper**** up to 300 F. and a maximum of 400*F. CAUTION: Dispersion type mastics should be treated the same as water emulsion types, in that they should not be applied if there k a dmger of rain washing within eight to Wv hours of the application time. Under proper temperature and humidity conditions. PERMISEAL wilt be dry te touch In lour hours or less. Jt1ft-?CI-04SO.i CLASSIFICATION Ww'r *Jr*~f Slaa inarm Twotratirt Application Tarnbaratwra Csirnw^t-mt Coaorapy Oriad Txi'--1 or Pladi Coat Bnrd* or Spray Coat Ptinfoicarwant *han rrquirad GanarM Ua Adtow** SwrnytS Cm!a( (or ll Knuln flam* Rnitlwict fnM Hmunct Ca>OM<< ftatittanca Van*' Knitunci * Pacfcafod snipping wa^t WEATHER COATINGS ANO SEALERS . WATf ACMULSION THERMAL COAT ' CM* MlCAL OISHKIIQn PCftWUSSAL ------- Tromol 4SO . 40V.o300*F. ft, 1/4~ *<*/*. Mw. ft-V" thick/#*. 1/4" thick Ml TfCM*l only * toutay nattin# traatnar tyt mum coating JIimU h bondrd to poultry ratting Avoid low tamptraturt and hiyh humidity condition* Non-flammablo ' Protact from Wnt Not inhibitad Will brvatho ; SCal. SO Cal. ' . Slaal Container i SSIS*. SSOtb*. . Orv^-Traaol tiny ooV. 40 F, a 3CC/. 10 a*, ft, t/4" thick/gal. tO od. It, 1/r*M*/*al. 30ad.lt, t/t<" thlck/gat. t/4* Oidi out rvdt or Spray two t/S* Puck mi eoau rainforead at rat`4 Suitable fabric Weather ceatinp and aaalar for ' inaulatron. motonry ataal, alum. CccaOam altar curing on clean dry aurlaca Avoid Iom tomporatury and high humidity oond'rtiona Non-flammable Hot affected InMbitod Mainu ttrtt and tarmaien yyui breathe during 3-3 monft euring poriod. ' then beeomcl wpaoil S &t. m* S4 pal. (pteetic tWserl ml container 4SM. 400 Hl u Sttfi"W^CT0f?IE3 8 A O/VISIOM O* CONDUCTION CNCINCCXING. INC. "une OURJSEAL PROTECTIVE ^ATlN^; Typ T-178. T-278 Duriaaal Protective Coatings * blends of mestlcs, combined 'w ?!? provyfe an excellent u*Ung material. Applied ovar masonry eettms, n* f*e-fexistent. air-tight film that impervious to water expo***. chemical ** fur"* Coatuvn alto am used in conjunction with Oatrick Thermal Coat when a flexible flhmflwmpound a raquln corrosion. opinp. . elk* to! to to. to* P--- STANOARD TEMPERATURE GRADES (To 400 F) For ajrfac* temperatures that will not be operated in excess of 3S0400*F tha Standard Grade* art recommended. Standard T ypt T-178 mada to a semi-viscous, troweling consistency. HIGH TEMPERATURE GRADES (To 700 F) Whan aurfacc temperatures will exceed 400*F during operation, but not in JJ of 700 F. Duntaal High Tampcratury Coatings thould ba utad. ' . EASY TO APPLY ! .. Ourittai Coatings may ba applied over any cool, clean, dry wrtaca. coau and for patching purpose*. Where sued, membrane should be lapped 4 t'**JTM *%*** `* applications. For ease of application, the best workable temperature WihF to 100 F Storage tamparature should not exceed 100*F.Ourhea Protective Coating, require no thinning. . COVERAGE .- Material requirements are estimated on wet coverage of approximately S to 6 square feet 0/4" thick) par gallon. CONTAINERS Durbaaf Protaetiv* Coatings arc shipped In 5 or 55 gallon steal containers. CAUTION: - Surface during application should ba above 100*F for indoor applications or T30*F for outdoor applications. Provide adequate ventilation and do not apply in vicinity of open flame, welding arcs. etc. [L-- INC. V fyroscat* FOR FIREPROOFING STRUCTURAL STEEL Pyroseat * * ipacial formulation of high-tamperatura aggregates. **b*s*o* t&*n, hydrw^ic Wndr and othe materials, Jhm ingredients mhiIeiInug with water at tht are job fascitteo.ry_P"yWr-o-a-sn-c-ta-etd isto. ada_aup_tnei_dfo_r_tmo_da_pr,yp*l-*ii-cmaatitounrabdy uf-ti-t-fai--sy* tr-ne-g-a-d.ya-afo-itrtnagppalnicda--ttirmooniwnea*ifjisu*. techniques, depending on job conditions. USES: Pyroseat provides a lightweight, fire-retardent protective treatment for structural steel columns, beam, tower Aim, IP gas tanks, and other exposed applications in refineries and enemies! plants. Pryoseat set: up to ' hard, durable sheath capable of withstanding for hours the 200G*F. flame temperatures and high-pressure water streams commonly encountered fat industrial fires. RECOMMENDED THICKNESSES: of application. For example, fir* ratings for steal columns rtprasant the number of hours required for hast from a "standard fir*" to penetrate the protective treatment at applied, and to increase the steal column temperature to a critical lave! (120Q*FJ The thermal conductivity and heat capacity of a material era of some important in an ASTM Fire Test. Sut the ability of the complete traatmant to withstand tharmal shock without destruction is on* of the most significant factors In determining practical fire ratings In industrial installations. ` The Pyrescat thicknesses recommended below were determined by physical tests on a series of sprayed, cast and trowelled applications. Tests included direct exposure to 100 psl hose pressure, both before and after subjecting the Pyroseat treatment to severe flame conditions. THICKNESS OF PYROSCAT 1" 1-3/4" 2" APPROX. FIRE RESISTANCE RATING 2 Hours 3 Hours (UL`R-3M0) 4 Hours ADVANTAGES OF PYROSCAT *"* "* fLaTM'*TL*' IteM tfu, di.!tTM` n ""m- lighted WEIGHT . . . IV~ w " "*T"-" IbsVeu. ft. for conventional concrete feeproofing. Eaci d.f * trowelled in a protective sheath. Pyroseat weighu about 1/10 as much a. formed concrete at equcvalent thickness per running foot. "A C-E trade name. ADVANTAGES OF PYROSCAT (Continued) SPRAY, CAST OR TROWEL . . /Pyroacat tt specially formulated to permit installation by aptay, trow^ and catting techniques, depending on local job conditions. No other fireproofing material k at wuttte from an application standpoint. Employs conventional aupportlng materials and placement. Only th or* fireproofing malarial k required - no need for subsequent finishing (ayart nor he*ry mastic coatings. OURABLC AND WEATHER-RESISTANT . . . Pyroscat davtlopa (rut atrangdi from ha selected high-temperature aggregates and hydraulic-tatting binders. It withstands eontinuwf eydas of saturated freeae-and-thaw waatharing tests. SUMMARY OF PHYSICAL PROPERTIES Covaragt (Trowelled) Material Required (Trowel Application) Air-Cured Weight (After Hydration and Drying) Compressive Strength Air-Cured Compressive Strength After Firing at 1S00*F. Lineal Shrinkage - Air Cured . Lineal Shrinkage After Firing at 1500*F. Density After Firing at 1500*F. Fusion Temperature , .a Thermal Conductivity (k) at 10Q0*F..Mtan Temp. Setting Time Mixing Water: 1.1 cu. ft/50 lb. bag 45 lbs. par cu. ft. S4.S tbs. par cu. ft. isso ps> 1.5* Lass than 1% 1.5% 39.1 lbs. par cu. ft. 2200 F 150 Btu 4 to 6 hours - . ' . .. For Spray & Trowel Consistency For Casting Consistency 3-1/2 Gal. water/SO Ibe. bag 5 Gal. water/50 lbs. bag .- Curing: Pyroseat u a cementitious material and should be kept moist during the curing period of 72 hours or longer. - oa-J " IN --a use IttfKMGTORfES A QVtIO 09 COMOUSTION CNCHCtUlNC. INC. air-check BOILER WALL COATING CEMENT ELIMINATES AIR INFILTRATION PREVENTS HEAT LEAKAGE SAVES FUEL INCREASES BOILER EFFICIENCY \ Air-Cheek Cement a en espheltie-esbettos fibre mixture in plettic form for to*fwj the outside of both lire brisk and red brick bolter wells. ft I* also utd (or pointing up crocks in boiler watts. its safe. effective limit of usefulness k 350*F. Air-Check Csmsnt h tough, rubbery, ptestie. eesy to sppiy. A 3/19"* thick coot troweled over the surface,'dries to s thickness of slightly more then 1/8**. It remains semi-plastic even though in service (or e number of yeers. '<^1 ------------------------------------------------ ------------------------------------------ -................................. - - .%& REFRASCCTTORf JFS.- AJDIVISIQWVOf .COMSUSTl^^^aiTteRlM.T^ v*VALLEV^FORg&^^NNSYLVAN(>. i uj a e<viioM of combustion cHCNCC*Na. inc. STIC-TITE AND SUPER stic-tite ALL PURPOSE PLASTIC INSULATION Stk-Tfce. and Super Stic-Tite plattic insulations ar* the most nthA teautatinf materials known, u;.^ ^ ve<er. tight on the job. they adhere to any **** fcrtaca -and sxep pe-at afl temperature to 180Q*F. They Bght. strong and iMnuity durable. . Bodt Stic-Tites art a powerful barrier against haat Iocl Composed of a special snbthma of miner* woof ard tRatomaeaout tank, th* applied and driad malarial forms a spongy mats of M1io of daad air cafe, uniform in da* and well isolated from aech other. Thu stops air infiltration and resultant haat iransmiswon. HOW TO SELECT THE RIGHT THICKNESS ' Estimate the operating temperature of your installation, (hot fact). Follow the' hot fact temper*turt (bottom of chart) vertically until It intersects the line connecting the cool face (left herd column) or 8.u>. loss (right hand column). Use the amount of Stic-Tita indicated on the Curve Merest the point of intersection. For example, assume operating temperature is I2S*F. and a cool face of 139* or 128 B.tu. too It desired. Follow the 825* line vertically until it intersects the horizontal 139* and 126 8.t.u. teas Ena. The intersection -it nearest th# 3*1/2** Stic-Tita curve. Therefore. 3-1/2" of Stic-Tita dtowid be vrsad. At the SUM Operating temperature if a cool face of 124* or t.Lu. loo of 96 ts desired, the intersection vsovkf ho Merest the 5" Stic-Tita curve. Therefore, 5** of Stic-The dwuld be need, * v SMi m HOUVPSNIM ono** HOI JVM MManmuswaoiM. WHERE STIC-TITE IS USEO Air Heaters Burner casings Boiler, front, side end rear watts Breechings Cookers _ Orwm heeds - CAN BE USEO ON Elbows Flanges Feed water heaters Fwrneca and Oven; watts, floors, roofs Ces generators Hot air ducts SURFACES Hot air lines Hot piping Hot water heaters Kettles Reaction vesaeit Regenerator facet Steam healers Steam pumps Tanks Tube doors Uptakes Valves and finings AS irregular surfaces Stic-Tite adheres strongly end permanently to metal (ipeoat Mubitors help prevent rusting of metal surface), tile, brick, insulating block and blankets or other clean surfaces, hot or cold. It can be toed in difficult places where other types of insulation ere wntuiteble-on intricate piping, on elbows ard flanges, on slanting vertical or curved surfaces end rounded corners. Stic-Tite provides a monolithic, seamiest, jointless covering which can be troweled perfectly smooth for appearance. *t-Tito adheres permanently without lifting off Of disking loot* even when aubfected to abrasfon'or Impact. _ ' STOPS HEAT LOSS ^atior. The iponfr <"* of dead air.celts chocks tit Infiltration-prevents hoot km. S*w* dry Stic-Tit* ^ dhrtnfc of farm crocks; tho high insulating efficiency h never in^airad. EASY TO APPLY Stic TIto. mixed with tho proper amount of wotor, forms an easily workable, plastic mass which can b troweled or safely applied with tho boro hands. Tho usual practice is to apply first a roughing coat ov th rta to bo covered, than trowel smooth around Joints, over the surface and atbows. curves, etc. LARGE COVERAGE - , Sine* SticTit* dries with practically no ^rinkeg* (an Inch of Stic-TIto applied wet remains practically an inch thick when dry), loss is required to provide sufficient ktsufating thicknets. Mixed and applied n directed, 100 lbs. of the materiel cover 45 aq. ft. with a 1** thick layer. CAN BE REUSED * If used et tempratures below 900*F,, old Stic-Tite can be removed from equipment, crushed, mixed with dean water and reapplied like new Stic-Tite. This makn equipment repairs ten eostiy sinca the insulation can be saved. Reclaimed SticTit* is equal to the tww product in insulating efficiency, adhesion and plasticity. SAVES LABOR AND MATERIALS ' Stic-Tite it to eaty to apply on alt types of regular and irregular surfaces end 0wr other insulations that labor cost is very low. Skilled men ere not needed. Sine* Suc-TIte adheres to strongly, reinforcing wires end ether supports are unnecessary when used up to 1-1/2" thick. . CONVENIENT PACKING ' Stic-Tite is shipped dry in heavy, fined, dustiest paper bags containing 25 lb*, and SO fee. each. It does not deteriorate in dry storage-can be kept Indefinitely If dampness or wet places are Molded. ' HOW TO APPLY ` . I2. 3. 4. - S. 6. Each SO# bag should be mixed with 12 gallons (100 lb*J of fresh water. After thoroughly mixing. Stic-Tite can be applied immediately, but better results can be obtained by allowing it to soak for at least s half hour or longer. . All surfaces to be covered should be free of painty dust, dirt and grease. Roughing coats can be applied by hand or trcnvtl or combination of hand and trowel. If hot airfacts are to be insulated with Stic-Tite, the materiel should be spotted in place with a trowel and dragged down to a feather edge. The spotted material will dry quickly and then a rough coat about 1" thick can be applied over end beTween the spots. . On cold surfaces for covering up to 1-1/2** thick, after being mixed according to directions on the beg. Stic-Th# should be applied by spreading ft over the surface to at even a thickness as possible. After the rough coat has dried out. * finish coat up to 1/2** thick can be applied over the rough surface and finnhed with e trowel to e smooth, attractive finish. Slic-Tite can be used up to 1-1/2" thick without reinforcing. 1. For covering over 1-1/2** thick, apply * rough coat about 1** thick. When rough coat is dry apply another 1** coat and continue until desired thickness is obtained. Each coat should be dried before additional coats are applied. Prior to application of finidt coat. we recommend reinforcing with #20 - 8*ge 2** mesh chicken wire. 8. * Finish coats should be applied from 1/4" to 1/2" thick, troweled to smooth, hard finish. Where desired, Stic-Tite finish can be painted. Best results are obtained by painting with a glue sizing and paint over this. 9. If more Stic-Tite is mixed than can be used, the left over material cen.be laid aside and remixed with water at a later date when it is required. ' *-- _ -- ^ ki W 11/ 7 gals. Pr 50 lb. Dry Coverage (Trowel Application) ' Setting Tim* ,.?*7*sq!*.f"t-*1/7 ^tek cpoemr 5m0olnb. bk*. Material Requirement* (Trowel Application Compreaaiv* Strength (Air Cured) Jm p*r thici Compmsiv Strength ($1200*J\) 105 psi. ' Abrasion Factor (Air Cured) 98 eecondi (MHD Method 102) Density (Applied and Dried) 35 lbs. per cubic foot. * t ,, Shrinkage (Wet to Dry) Negligible. , *'K" Factor at 600 F. Mean Temperature 79 Btu. . . Corrosion Resistance to Steel. . Non-corrosive. Surface Tr.eat.mr.e..n..t. " 2-V. . * painted or weatherproofed -.when required. . * % Shipping Containers (Sewn Closure) SO lb: oaner bag. . MIXING Utility Thermal Finish Cement should be mixed in a clean mortar box or mixer, using approximately 7 gallons ol water per 50 lb. bag for a good troweling consistency over * most blocks, blankets, or in sulating cements. Because of the hydraulic binder, . Utility should not be mixed with water more than two hours in advance of its application. With cold mixing water (below 60FJ,-* it remains workable up to 4 hrs. STORAGE Store in a cool, dry location until ready to use. -*: Utility Gunned on Balloon Flue* _ . * * ^ ** ` *-------- r V, f REFRACTORY Sc INSULATION CORPORATION ... 625 ILLINOIS AVE. - AURORA, ILLINOIS PORT KENNEDY , PENNSYLVANIA UTILITY THERMAL FINISH CEMENT o Utility Thermal finish Cement Is composed of hlfh quality mineral liter, hydraulic * hinders, and other suitable materials. Utility combine s the flexibility, high temper ature resistance, and excellent insulating qualities of uniformly nodulated mineral . fiber with the strength, low shrinkage, and smooth finish of hydraulic setting cement.' The result is a quick setting, smooth finish,, thermal resistant, single layer insulating finish cement. For temperatures up to 1200F. QUICK'SETTING * JI ' 72* pw /// * . ; /// * ;ep sw HgP 41 Utility Insulating Finish Cement develops a smooth, durable, protective finish within a few hours after application and without the presence of heat. Subsequent drying produces no excessive surface cracking or shrinkage in thickness, and occasional wetting does no damage after hydraulic set. Long drying periods under normal ) conditions are eliminated. Saves time in applying weatherproofing, paint, or other finishes. Jobs are easier to schedule; scaffolding costs are reduced. ONE COAT APPLICATION .. * ` '* Utility is normally applied in a single layer application. A second layer is needed only when multiple layer thicknesses are specified. Utility is virtually an all . -purpose insulating finish cement, designed primarily for use over Criptex block \ or blanket insulations. Utility Is widely used for .insulating valves, fittings, heated equipment, and as an anti-sweat insulation for cold water tanks, pumps, etc. . Utility trowels with a good.key on block Insulation; blanket insulation and insu lating cement. It has good wet adhesion to clean steel surfaces, such as valves and fittings. *, . .. . PLEASING APPEARANCE - * Utility dries to a smooth, light reflectanl surface which as an interior finish, requires no further treatment. Utility, however, is easily painted if desired. Outdoor applications should be weather protected. Low temperature applications require a vapor seal type finish. * . * EXCELLENT THERMAL QUALITIES Utility has a "K" factor of .79 at600F.mean temperature.* This excellent insu- - lad& value me compared to other finish cements is a very desirable advantage wfiro*flgurifig*j6b and operating costs. . May, 1964 ' . SUPER 712 Inflating Cement it t mixture of high temperature mineral ffbera epeeially proceeeed into resilient wool nodule i, combined with asbestos tad suitable binder* to form a high tamptratura plattie in filiation. Water added aeeordlag to directioae give* a trowelable consistency that it ready for application oa equipment to be operated at temperaturae up to 18Q0F. WIDE USAGE ' SUPER 721 is a versatile material for many types of insulation requirements. Applied over block or blan ket insulations, it fills open joints and provides a mono lithic surface for whatever type of subsequent finish is specified. Its plastic flexibility permits application directly to regular or curved surfaces -- such as valves, fittings, tanks and vessels. EASY TO APPLY ' SUPER 711 has excellent adhesive qualities. It* increased stickability means a better job in less time, from wet to dry. Will not slip or roll under trowel appli cation and may be easily gun applied. This superior workability is a result of fine mineral nodules, special manufacturing methods and quality eontroL MAXIMUM COVERAGE - LOW SHRINKAGE SUPER 711 Insulating Cement assures maximum coverage and low shrinkage. The resilient nodules of mineral fiber do not collapse when mixed with water. See table of Physical Properties for coverage. . RECOMMENDED USES BOILERS Druma Headers Walls Economixtrs Air Preheaters FURNACES Heating* Heat Ideating Forging * Annealing Normalising . OVENS, KILNS It DRYERS VALVES 4 FITTINGS TANKS 4 VESSELS ' TURBINES 4 PUMPS FAN HOUSINGS DUCTS 4 BREECHINGS SPECIF1 CATION REFERENCES SUPER711 Mineral Fiber Insulating Cement conform* to ASTM C-195-48; Federal Specification HH-C-188 (Gut C); and/or Commercial Standard CS-117 of the U^'Si. tDepartment) pf Commerce. ,, i 4iJ xjr aurz.n HI INSULATING CEMENT Service Temperature' Water Ratio Dry Coveraf* - * Malarial Requirement* * Compratslva Stranfth Density (Applied and Drlad) Shrink*** (Wat to Dry, by Volume) Thermal Conductivity Reclaimabl* to< . * Adhesion to Steal (Wat) Adheaion to Staal (Dry) - Corroaion Raalatanca to Steal ' Shippinf Contalnera (Sewn Cloture) . 1 *oor. 12 tala. pa*" $0 lb. btf SO aq. ft. 1" thick par 100 lb*. 2 lb*, par sq.ft. 1* thick 45 pal 24 lb*, par cubic foot 15% Sea Chart *iooodr. S pal ' 9 pal Non-corrosive . . 50 lb. paper ba*a Tabulated value* represent typical performance levels of SUPER 711 Ir.aulating Cement - Trowel Grade. SUPER 711 "Gun" Grad*`Cement conaiata of the same basic material* that amaller mineral woolnodule* are utilised to facilitate appli cation. * / KEAN TEXPEXATUWE ~*T. REFRACTORY 625 RtUNOtS AVC. AURORA. ILLINOIS INSULATION CORPORATION . PORT KENNEDY ' PENNSYLVANIA , stncAUORY-.i. INSULATION CORPORATION *%>X!*j?*0'0NO.C{MENT^l:- . Apptitglln D'itaJh /orSfee/ Cotvmnt and t+amt #w - A tkhhica. A. Surface Preparation 1. Remove dirt, scale or loose paint from th surface to b treated, than apply rust preventative paint or coating whan specified. 2. For trowal applications to columns and beams, form 3/#" rib lath (or papar-backad lath) to box-in the member. Apply rib`lath with ribs turned in and spanned from flange to flange. On members 24" and - larger, first weld 1/4" rods across the flanges approximately 12" to 18" on centers to provide additional support for the lath. Secure the lath in place with wire or bands. For gun application, use 2 x 2 #18 paper-backed-lath such as Steeltex. . a) Provide 2"firestops on columns at 8* to 12* intervals (or as other wise specified). Form the metal lath into a horixontal shelf ex tending to and supported at the web. Apply pyroseat 2" thick in . . the opening. Provide similar stops at the top elevation of the fire proofing. . b) Plasterer's corner bead may be wired to the metal lath, forming and supporting it to attain the total Pyroseat thickness specified. Corner bead shall be of the type having open-mesh legs to facili- . tate complete filling of the corners. The eorner bead may be spaced the proper distance from the flanges by means of corner clips, rods, studs;, or Pyroseat may be spotted-in to space the corner bead at specified fireproofing thickness. B. Application of Pyroseat 1. Mix Pyroseat to recommended consistency with clean, fresh water, before application. Refer to mixing Instructions on the bag and use no more water than called for. Mix Pyroseat to a homogeneous plastie mass; avoid over-mixing, particularly with mechanical mixers. a) Apply Pyroseat well into the metal lath, installing approximately 1/2 the total thickness in the scratch coat. Leave the first coat rough or scratch the surface. ' . b) On the underside of beams, the application may be in three coats. Apply a thin scratch coat first to Improve adhesion. c) If corner bead was not applied previously, wire it in place when the scratch coat has set. .2 Let the scratch coat harden until well set (4 to 8 hours or longer), then double-back with the finish coat. Apply it flush with the corner bead. Sponge-float the surface to a textured finieh or as otherwise specified. j?,. tr -V a) A^heri application of the fini sh coat is-dferred over night or longer, wet dswn the scratch coat thoroughly before proceeding with il finish coat. / * J. lyrroaeat Is a cementitious malarial; to develop its strength. keep it rajtt for 72 houra or longer. Dapendlaf on atmospheric conditions whan ppii*d tha required water ratantion may ba seeoroplished with wat burlap, period water spray or a hydrostatic (resin-base) staler. Following tha curing period and whan visual moisture has dried, apply * suitable flashing material at all intersecting joints and exposed ends of members treated (Duriseal T-173 Coating). * 3. Fyroscat may ba painted with (1) masonry paint, (3) two coats of asphalt- base aluminum paint, or (3) other finishes as specified for operating conditions involved. (Note: When conventional masonry paint of the hydra- tlng-type is used, wet down the ^yroecat before painting to insure proper . . hydration). * ' ALTERNATES FOR TOWER SKIRTS (VERTICAL) . * A-2 Attach a layer of 1" x 1" square mesh reinforcing, positioned 1M away from the * skirt, i.., at the approximate center of the fireproofing thickness specified. a) Trowel or gun Fyroecat solidly through openings in the square mesh, bringing the scratch coat out approximately 1" thick. Start at the bottom of the skirt and work upward. Leave the surface rough, or acratch ifwhen trowel applied. * ' b) Screed strips may be attached temporarily ovar the square mesh reinforc ing, to eceurately gauge the thickness of the second layer* c) When fireproofing is applied to skirts of heated vessels while they are in operation, heat conducted to the skirt may prematurely dry the initial layer * of Fyroscat. Wet the first coat thoroughly, particularly at the top, before applying the final layer. ' ALTERNATES FOR HORIZONTAL TANKS A-2 Bolster bars are prefarred for anchorage of the reinforcing mesh. The bolster ' bar selected. ~ould have legs extending from the tank surface approximately one-half of t) total thickness of fyroscat to be applied. Form the bolster bars to fit the tan curvature, then weld or wire In place circumferentially approxi mately 3* on center*. Wire the reinforcing mesh to the bolster bars. C-3 When tanks so fireproofed are to be operated below ambient temperature, suit able vapor-aealing treatment is recommended after the Fyroscat has been cured, dried and flashed. * ^EpRACTORY 623 ILLINOIS AVE. AURORA, ILLINOIS .ao * .. INSULATION`CORPORATION . *. - PORT KENNEDY - : PENNSYLVANIA Pyroscat ia a special formulation of high-temperature aggregates, u^utoi fibers, hydraulic binder and other malarial a. Thaaa ingredients ara factory blended to je uniform dry mixture that ia raady for applicatioa after mixing with water at the job site. . Pyroscat la adapted to application by spraying, casting and trowelling techniques, depending oa job conditions. USES: Pyroscat provides a lightweight, fire-retardent protective treatment for structural steel columns, beams, tower skirts, LP fas tanks, and other exposed applications in refineries and chemical plants, Pyroscat sets up to a hard, durable sheath capable of withstanding for hours thc2000F. flame temperatures and High-pressure water streams commonly encoun tered in industrial fires. :, . RECOMMENDED THICKNESSES: Fire-retardent materialsare customarily rated in Hours, based on a given thickness used and on the method of application. For example, fire ratings Sor steel columns represent the number of hours required for heit from a "standard fire" to penetrate" the protective treatment as applied, and to increase the steel column temperature to a critical level (1200 FJ. The thermal conductivity and heat capacity of a material are of some impor tance in an ASTM Fire Test. But the ability of the complete treatment to withstand thermal shock without destruction is one of the ^^st significant factors in determining practical fire ratings in industrl - installations. The Pyroscat thicknessesreeommendedbelow were determined by physical tests on a series of sprayed, cast and trowelled applications. Tests in cluded direct exposure to 100 psi hose pressure, both before and after subjecting the Pyroscat treatment to severe flame conditions. Thickness of Pyroscat 1" 1-3/4" Approx. Fire Resistance Rating 2 Hours * ADVANTAGES OF PYROSCAT Safer While^FTthtlnt Fires .... Many concrete aggregate# and common bricks used for fireproofing purposes will spall and shatter when they are heated and subjected to a hose streang., . Pyroscat remains virtually unaffectedaflertBr^ctfiame exposure and-situration wfm-a lOOpeihose stream. - .AV - * . ' . pop; ' . May, 1364:; 5* *' . . **Aa RVltrad* Mia*. ht ^MoiottrroxWirenigithtiy .15P0 ylbro*,ic/cttuw. ftti.fhfoi r1*c*o*ntvheuntio5n5allbcso.n/ccure.te fireproofingc. omlipeanre*d F^roscat we1ig.h.sUamboinu.tL1d/1. 0Aa*smuuc1h2yaspforr.my.eddocrotnrocrwet.eU.-dattoe*qupivroelte.entut,h.ic,khn,e.tshs. per running foot. " ...... Ct or Trow.l.,.. */ro.e.tl ^dUtyf.raoUUdtopjraa to.un.U 15 Jfspray* trdwT anycasting techniques. defending on la! other fireproofing material ia aa versatile from an *PP^^/^l<!g!f^ro5Se ploys conventions supporting materials *nd placamsnt. ^^ jjaar?mastic material ia required - no need for subsequent finishing layera nor neavy masuc coatings. - RDuerealbeled hanigdh-Wteemaptehreart-uRreisieatgagnret.g. a..tPesyroasndcaht yddevrealouptsicg-sTeftttmjjref^ngth frJotmwitiths. Itands continued cycles of saturated freete-and-thaw weathering teats. SUMMARY OF PHYSICAL PROPERTIES: Coverage (Trowelled) 1.1 cu. ft./501b. bag . Material Required (Trowel Application) * 45 lbs. per cu. ft Air-Cured Weight (After Hydration and Drying) Compressive Strength - Air-Cured 54.5 lbs. per cu. ft. * 1650 psi * Compressive Strength After Firing at 1500F. Lineal Shrinkage - Air Cured 1.5% Less than 1% Lineal Shrinkage After Firing at 1500F. 1.5% Density After Firing st 1500F. 49.1 lbs. per cu. ft. I ision Temperature 2200 F . Thermal Conductivity (k) atl000F.Mean Temp. 1.50 Btu Setting Time 4 to 6 hours . Mixing Water: For Spray fc Trowel Consistency 3-1/2 Gal. water/50 lb. bag For Casting Consistency 5 GaL water/50 lb, bag Curing: ' ' Pyroscat is a cementitious material and should be kept moist during the curing period at^2 hour* or longer. * 625 ILLINOIS AVG# AURORA, ILLINOIS & ,NSOLAT16^ CORTMtRk^2^ PENNSYLVANIA PcNNStuvapi UTILITY THERMAL FINISH CEMENT (J) ' . ' Utility Thermal Finish Cement it composed of high quality mineral fiber, hydraulic hinder*, and other auitahle material*. Utility combine s the flexibility, high temper atuxe resistance, and excellent insulating qualities of uniformly nodulated mineral fiber with the strength, low shrinkage, and smooth finish of hydraulic setting cement. The result is a quick setting, smooth finish,. thermal resistant* single layer insulating finish cement. For temperature* up to . 1200F. QUICK SETTING Utility. Insulating Finish Cement develops a smooth, durable, protective finish within a - few hours after application and without the presence of heat. Subsequent drying 4 produces no excessive surface cracking or shrinkage in thickness, and occasional wetting does no damage after hydraulic set. Long drying periods under normal ) conditions are eliminated. Saves time in applying weatherproofing, paint, or ' other finiahes. Jobs are easier to schedule; scaffolding costs are reduced. ONE COAT APPLICATION ^ Utility is normally applied in a single layer application. A second layer is nesdsd only when multiple layer thicknesses ar* specified. Utility is virtually an all -purpose insulating finish cement, designed primarily for use over Griptex block or blanket insulation*. Utility is widely used for insulating valves, fittings, hsatsd equipment, and aa an anti-sweat insulati m for cold water tanks, pumps, etc. . Utility trowels with a good .key on block insulation, blanket insulation and insu lating cement. It has good wst adhesion to clean steel surfaces, such ss valves and fittings. . PLEASING APPEARANCE Utility dries to a smooth, light reflectant surface which as an interior finish, requires no further treatment. Utility, however, is easily painted if desired. Outdoor applications should be weather protected. Low temperature applications require a vapor seal type finish. EXCELLENT THERMAL QUALITIES Utility has a *'K" factor of .79 at600F.mean temperature. This excellent insu lating value as compared to other finish cements is a very desirable advsntage when figuring job and operating costs.; - ' May, 1964 ** _-- --- * Water Ratio (Trowel Application) 1200UF. 7 gal*, per 50 lb. bag. Dry Coverage (Trowel Application) * 37 aq.ft. 1/2" thick per 50 lb. bag Setting Time 2 to 4 hr*, average condition*. Material Requirement* (Trowel Application) 1.3 1b*. persq.lt. 1/2 thick. Compreeelve Strength (Air Cured) 135 psi. * Compreeeive Strength (61200F.) Abrasion Factor (Air Cured) MSeond. (MHD Method 102), Density (Applied and Dried) 35 lbs. per cubic foot. Shrinkage (Wet to Dry) Negligible. MK" Factor at 600 F. Mean Temperature .79 Btu. * Corrosion Resistance to Steel . Non-corrosive. ... __ Surface Treatment , - Casilv `painted, or weatherproofed a Shipping Containers (Sewn Closure) when required. 50 lb: paper bag. "/ MIXING Utility Thermal Finish Cement should be mixed in a clean mortar box or mixer, using approximately 7 gallons of water per SO lb. bag for a good troweling consistency over most blocks, blankets, or in sulating cements. Because of the hydraulic binder. Utility should not be mixed with water more thantwo hours in advance of its application. With cold mixing water (below60F), .*it remains, workable up to 4 hr*. STORAGE *"i- V ' Store in a cool, dry localiorrr'** until ready to use. *" Utility Gunned on Balloon Flue'. - . "* - :--* ' - ~ 7- - ' - __ *- ' REFRACTORY & INSULATION CORPORATION. 625 ILLINOIS AVHAURORA. ILUNOtS PORT KENNEDY}* . . PENNSYLVANIA} 4*  WAV W k.1 I < IV/M \.um unniiun HILITE INSULATING & FINISHING CEMENT Hilite Insulating & Finishing Cement is com posed of fine nodule high temperature mineral fiber, hydraulic binders, and other suitable ingredients. The result, is a quick setting, smooth finish, thermal resistant and flexible one coat insulating and finishing cement. Hilite successfully combines the excellent low shrinkage, smooth finish and wet strength features of a one coat-type insulating finish cement, and the flexibility, high temperature resistance and thermal qualities of mineral fiber insulating cements. Hilite is designed for use at temperatures up to 1400F. QUICK SETTING Hilite Insulating & Finishing Cement develops a smooth, durable, protective finish within a few hours after, application and without the presence of heat. Subsequent drying produces no excessive surface cracking or shrinkage in thickness, and occa sional wetting does no damage after hydraulic set. Long drying periods under nor mal conditions are eliminated. Saves time in applying weatherproofing, paint, or other finishes. Jobs are easier to schedule; scaffolding costs are reduced. ONE COAT APPLICATION Hilite is normally applied in a single layer application. A second layer is needed only when multiple layer thicknesses are specified. Hilite is virtually an all-purpose insulating and finishing cement, designed primarily for use over Griptex block or blanket insulations. Hilite is especially suited for application over calcium silicate or 85% magnesia insulation products. The high water absorption of these products causes ordinary one coat cements to lose the water necessary for hydration. Hilite effectively resists this tendency. Hilite is widely used for insulating valves, fittings, heated equipment, pumps, etc. Hilite trowels with a good key on block insulation, blanket insulation and insulating cement. It has good wet adhesion to clean steel surfaces, such as valves and fittings. PLEASING APPEARANCE Hilite dries to a smooth, light reflectant surface which as an interior finish, re quires no further treatment. Hilite, however, is easily painted if desired. Outdoor applications should be weather protected. Low temperature applications requij a vapor seal type finish. May, 1964 Hilite has a "K" factor of .78 at600F.Mean Temperature. This excellent insulatinu value is a very desirable advantage when figuring job and operating costs. ** PHYSICAL PROPERTIES Service Temperature Water Ratio (Trowel Application) Dry Coverage (Trowel Application) Setting Time . Material Requirements Compressive Strength (5% Deformation) Density (Applied and Dried) Shrinkage (Wet to Dry) Adhesion to Steel - "K" Factor at600F.Mean Temperature Corrosion Resistance to Steel Surface Treatment Water Resistance Shipping Container ... , . , 1400F. 11 gals, per 50 lb. bag 43 sq. ft. 1/2" thick per 50 lb. bag 2 to 4 hours dependent on atmospheric conditions . 1.1 lbs. per sq. ft. 1/2" thick 41 psi 27 lbs. per cu. ft. Less than 2% Good .78 Non-corrosive Easily painted or weatherproofed when required Withstands repeated wettings 50 lb. paper bag MIXING Hilite Insulating & Finishing Cement should be mixed in a clean mortar box or mixer using approximately 11 gals, per 50 lb. bag for a good troweling consistency over blocks and blankets. Because of the hydraulic bin der, Hilite should not be mixed with water more than two hours in advance of its appli cation. With cold mixing water (below 60F) it remains workable up to four hours. STORAGE Store in a cool, dry location until ready to use. REFRACTORY & INSULATION CORPORATION 625 ILLINOIS AVE. AURORA, ILLINOIS ,, PORT KENNEDY PENNSYLVANIA p INDUSTRIAL HYGIENE BULLETIN . NUMBER.16-MARCH 1972 PROPOSED STANDARD FOR ASBESTOS EXPOSURE STANDARD MEDICAL SURVEILLANCE Five (5} fibers per milliliter greater then five (5) microns in length for an eight-hour time weightad average. A Mdlol SurvelQanee. Program dtouid indude the following; For unprotected workers - Ton (10) fibers'`par mlBBItar . up to IS minutes In an hour for up to 5 hours during an eight-hourwork day. asbestos exposure Exposure to asbestos predomiri fabrication ptana^grindlng, ml cement and IrauBCng material asbestos board. A prolonged Inf between 5 and 50 microns In decease known as Asbcsteeb.Tl of eliminating ariwstos fiber* coated tfawes. Tt* ntinuatior long period of tfar ,10 to 20 1 .fibrosis which ctuM a severe m standard in.terms of S ftberxfeub'< 140,000 fibers^ cubic foat*TI received over an eight-hour pet worker inhaling 15 million fibers CONTROLMEASURES 1. Periodic measurement* of pulmonary function (Forced Vital Capacity FVCJ ' ' . 2. * Forced ExpWtocy Volume (FEV) mtganogrems (Every 2 ytang Smoking Habits . previous known expoeuree to aAestoa tent and Medical Examinations on i of employment of wbastaMxpaari IS. . - . * , . Kw mimofi ncafOi or pmonii mo anitoring and of medical examtna-' I* must be maintained fore period of available for inspection. * Engineering methods arch as end .... .mum sweep log and local exhaust ventilation where feasible.The uee of approved Respiratory Protection and Personal Pro* tactive CJething whore controls are not fets&ie. SAMPLING AND ANALYSIS . Hat of e Personal Sampling Pump with e mlflipore filter (37mm, 0JB micron pore rise) ustd.open fece during sampling^ e rate of 2 Uterx/mlmite. - A IS minute sampling period should be used for evalu ating an Excursion Limit. For evaluating a eight-hour work period, several samples of up to 4 hours duration rftould be taken. ` LABELING * - . A recommended warning-Isbai for asbestos, b drown In figure on.reverse side.'The numerics! designations Indicate the following: 4 TfeaWr Hazard {color code - blue) . Inhalation may cause asbeszorit, pleural or peri toneal mesothelioma, or king cancer. 0 Fir* Hmztcd {color code rsdj - Asbestos Is nonflammable and has negligible vapor procure, volatility, flash point end explosive Omits. - HARMFUL: May Cause Delayed Lung Injury (Asbesiosls, Lung Cancer}. DO NOT BREATHE DUST Use only with adequate ventilation and approved respiratory protective devices. - ' -VA r- w t