Document X8nXEyvERZaxV07Zwg80VY1xK

PLAINTIFF'S EXHIBIT IL050B.ASB 04/18/91 STATE OF ILLINOIS IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT COUNTY OF FORD ANNA WOELLMS, Individually and as ) Special Administrator for the ) Estate of Willie Woellms, deceased ) Plaintiff, ) vs. ) No. 89 L 29 ARMSTRONG WORLD INDUSTRIES, ) INC., et al., ) Defendants. ) DEFENDANT, OWENS-ILLINOIS, INC'S RESPONSES TO PLAINTIFFS' FIRST REQUEST FOR DISCOVERY TO DEFENDANT. OWENS-ILLINOIS. INC. PRELIMINARY STATEMENT Some of the events which may be relevant to the matters inquired about by Plaintiffs' Request for Production apparently occurred more than thirty-five years ago. In addition, effective April 30, 1958, Owens-Illinois, Inc. disposed of the business involved in this action by way of sale of that business to OwensCorning Fiberglas Corporation. Since that time, Owens-Illinois, Inc. has not engaged in any such business. It does not now and it has not since that sale manufactured, distributed or sold any asbestos-containing products. As a result of the_^ foregoing factors, investigations to date indicate that at least some documents which relate to matters inquired about by these re quests were transferred to Owens-Coming Fiberglas Corporation with the transfer of the business in question in 1958. OwensIllinois, Inc. is engaged in a continuing investigation in an attempt to locate, confirm the transfer of, or confirm the absence of, such documents and is also engaged in a continuing investigation into the matters inquired about in these requests. Unless otherwise stated in an answer to a specific request, the answers set out hereinafter are limited to the period during y:- ; which Owens-Illinois, Inc. manufactured asbestos-containing insulation products and to the facilities related to that business. The following is a part of and is incorporated by reference in every answer provided hereinafter: This answer is accurate as of the date made. However, Owens-Illinois, Inc.'s investigation is continuing, and Owens-Illinois, Inc. cannot exclude the possibility that it may be able to obtain more complete information or even information which indicates that the answer being supplied is incorrect. Owens-Illinois, Inc. objects to answering this request in regard to any period of time other than the period during which it engaged in the business involved in this case which ended in mid--1958 or concerning any facility not related to that business, on the basis that any such answer would be irrelevant to the subject matter of the pending litigation, would not be reasonably calculated to lead to the discovery of admissible evidence, and would be burdensome and oppressive. Furthermore, Owens-Illinois, Inc. objects to the instruc tions and definitions supplied by plaintiffs with regard to these requests, on the basis that the definitions are overbroad, vague, and often inconsistent with the normal usage and meaning of such words, and the instructions are overbroad, burdensome and consti tute an unreasonable expansion of the requests themselves. Owens-Illinois, Inc. therefore gives notice that it does not consider itself bound by the instructions and definitions pro pounded by plaintiffs, and instead shall answer the requests in a manner consistent with a normal understanding of the language used in the requests and to the extent necessary to fairly and fully answer the requests. 2 REQUEST HO. 1. All witness statements of any sort, whether signed or unsigned (together with all documents purporting to reflect the same), and a list of those statements for which a privilege from disclosure is claimed; RESPONSE NO. 1. Neither this defendant nor its counsel is in possession of materials referred to in this request. This defendant reserves the right to supplement its response at any time in the future. REQUEST NO. 2. All data as to the physical or mental condition of Willie Woellms, excluding all documents provided you by Plaintiff's counsel and excluding all documents, copies of which have already been provided Plaintiff's counsel through formal discovery; RESPONSE NO. 2. Neither this defendant nor its counsel is in possession of materials referred to in this request. This defendant reserves the right to supplement its response at any time in the future. REQUEST NO. Woellms: 3. All photographs or sketches of Willie RESPONSE NO. 3. This defendant has found no documents responsive to this request. REQUEST NO. 4. All photographs, models, sketches or diagrams of any of the sites at which Willie Woellms worked; RESPONSE NO. 4. Neither this defendant nor its counsel is in possession of materials referred to in this request. This defendant reserves the right to supplement its response at any time in the future. 3 REQUEST NO. 5. All photographs, models, sketches or diagrams of any of the products involved in this litigation; RESPONSE NO. 5. Refer to Exhibit I which may contain information relevant to the subject matter of this request. REQUEST NO. 6. All pamphlets, brochures or other documents prepared, distributed or utilized by Defendant to advertise or promote asbestos-containing products during the 1950's and 1960's; RESPONSE NO. 6. Refer to Exhibit I. REQUEST NO. 7. All medical articles, case reports, textbooks or other documents which relate to any "state-of-the- art" defense you will present. RESPONSE NO. 7. The documents which this defendant intends to rely upon at trial are not known at the present time. This defendant reserves the right to designate documents to be used at trial at a later date. As a partial listing, however, the following materials may be relied upon; "A Study of Asbestosis in the Asbestos Textile Industry," Dressen, W.C. (1938); an article published in the Transactions of the Eleventh Annual Meeting, Industrial Hygiene Foundation, November 7, 1946, by J. J. Bloomfield; "A Health Survey of Pipe Covering Operations in Constructing Naval Vessels," Fleischer, Drinker, et al., (1946); "Asbestos Exposure During Naval Vessel Overhaul," Marr, William T. (1964); "Prevalence of Chronic Respiratory Disease," Ferris, B. G., Jr. (1971); "Asbestosis and Bronchogenic Carcinoma," Isselbacher, K. J. (1953); Annals of the New York Academy of Sciences Volumes 132 and 330; and the Threshold Limit Values promulgated by the American Conference of Governmental Industrial Hygienists for the years 1946 through 1958. 4 REQUEST HO. 8. A transcript (including exhibits) of each instance where an expert witness has testified in support of Defendant's "state-of-the-art" defense in asbestos disease litigation; RESPONSE NO. 8. This defendant objects to this request as being vague, ambiguous, irrelevant, overly broad, burdensome and oppressive, not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. REQUEST NO. 9. Each document authored by an employee of Defendant in the course of his employment, dealing in whole or in part with the consequences of exposure to asbestos; RESPONSE NO. 9. This defendant objects to this request as being unintelligible, overly broad, burdensome and oppressive, not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. REQUEST NO. 10. All medical records of those present or former employees of Defendant who have filed claims for worker's compensation or occupational disease benefits alleging an injury or disease from exposure to asbestos and all personnel and employment records which evidence or reflect the duration, quantity and quality of his or her exposure to asbestos while employed by Defendant; RESPONSE NO. 10. This defendant objects to this request on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this defendant engaged in the manufacture, sale and distribution 5 of its asbestos-containing products. Without waiving the above objection, during the period in which this defendant engaged in the manufacture of its asbestos-containing products, it received no workers' compensation claims for any asbestos-related disease. REQUEST NO. 11. Each written warning, caution or other document which was intended by Defendant to reach those persons who would breathe or ingest the asbestos from asbestos- containing products manufactured and/or sold by Defendant; RESPONSE NO. 11. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has not found information in its records sufficient to enable it to answer this request. However, it does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm. REQUEST NO. 12. A transcript (including exhibits) of each instance where an employee of Defendant testified at deposition or trial in asbestos disease litigation; RESPONSE NO. 12. This defendant objects to this request as being vague, ambiguous, irrelevant, overly broad, burdensome and oppressive, not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. REQUEST NO. 13. A transcript (including exhibits) of each instance where an individual whom Defendant listed, retained or called as an expert witness, testified at deposition or trial in asbestos disease litigation; RESPONSE NO. 13. This defendant objects to this request as being vague, ambiguous, irrelevant, overly broad, 6 burdensome and oppressive, not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. REQUEST NO. 14. All agreements to which Defendant is a party and which relate to the manner in which this case shall be evaluated, delayed or defended, including, but not limited to, all Wellington agreements and all documents exchanged by the parties thereto; RESPONSE NO. 14. This defendant objects to this request on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. REQUEST NO. reports; 15. Defendant's last three annual RESPONSE NO. 15. This defendant objects to this request on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. REQUEST NO. 16. A list of the names, addresses and employers of each person involved or consulted in the preparation of your response to this Request; RESPONSE NO. 16. This defendant states that it has referred to the relevant business records of the Owens-Illinois Glass Company, which are still in the possession of Owens- Illinois, Inc., in connection with the preparation of answers to these interrogatories unless otherwise indicated. 7 REQUEST NO. 17. An affidavit stating whether production is complete according to the knowledge of Defendant and Defendant's insurance carriers, attorneys', agents and employees. 8 AFFIDAVIT STATE OF OHIO COUNTY OF LUCAS ) )SS: ) A. H. SMITH, being duly sworn according to law, deposes and says that he is an Assistant Secretary of Owens- Illinois, Inc., a defendant herein; that as such he is authorized to make an Affidavit on its behalf; and that the facts set forth in the foregoing DEFEN DANT, OWENS-ILLINOIS, INC.'S RESPONSES TO REQUEST FOR PRODUCTION, are true and correct to the best of his knowledge, information and belief. ff~, H. A H. SMITH MARY JANET CRAWFORD Notary Public, State of Ohio My Commission Expires 1-4-96 EXHIBIT I A NEW HEAT INSULATION WITH A REMARKABLE COMBINATION OP ADVANTAGES.... ICaylo Heat Insulating B a nw type of lightweight air. sulacioo that ii tjfieirnt enougr. used at ordinary room temper and rtuutnt enough to perform lively up to 1200* F. Few ocw product! of iav kin been to thoroughly researened being placed on the market. Heat Iaaulatiog Block u the ac meat of many yean work bv C lUiooil Gian Compaav eng; pbytidsu and chemists. No other material, new or c effectively combine! the most able chantcteriitic! of the idea iosuiatioo. For instance . . . LOW DINS1TT Kaylo Heat 1 aiulaung weighs only 11 pounds per eubt This light weight (less than one to the board foot) simplifies r.an shipping sod application I: : reduces weight --an important tage on ships, for an example Notice the clean, urngnr OO these insulated preopnaior pen. Applicators find n *' hind of work with ICa*lo Heat 1 ing Block because :ne i f -o r cut and yet they han a < flexural strength. The hoppers are also mm.i'U * 1 Heat Insulating Bioc OW THERMAL CONDUCTIVITY The coefficient of conductivity, or of Kayio Heat Insulating Block, s own on che chut on P*f* four. *. it among the mo*t efficient in. uUuom for medium high temperajrei. Its insulation value come* prto* ipailv from us fine, interlaced cellular trucrure. These ceils are so tiny end o numerous chat they present a raaertai surface of approximately 140 cres per cubic foot of insuiattoa. Experience shows that the insulaion value of Kayio insulation ire'roves when the material is put into ervice. EFFECTIVE OVER WIDE TEMPERATURE RANGE Kayio Heat Insulating Block per forms efficiently not only on temperaures in the low pressure steam and hot water range but on temperatures in he superheated steam range as well. This is shown by the flatness of the conductivity curve. One-material cov erage with Kayio insulation handles applications which oftea require two thicknesses of different materials. JH COMPRESSIVE STRENGTH s compressive strength is unus*. ,y high for a mineral product of such light weight. Kayio Heat Insu lating Block withstands compression values equivalent to those of a man s walking on it or even to those of a heel s being ground into it. HIGH FLEXURAL STRENGTH Its flexural strength is higher than the normal requirement for heat insu lation of this type. This strength makes for easy handling and applica tion. and contributes to iong service with low maintenance. NO ADDED BINDER Kayio insulation is an inorganic compound, containing no added binder. Its performance characteris tics. therefore, are not affected by additives, which often reduce insulat ing value, modify effective tempera ture range or otherwise limit per formance. EASY TO APPLY WELL Kayio Heat Insulating Blocks are clean-cut and trim. They arc easy to fit into place to make a good-looking installation. Their "feet'* it pieeaeoe aad now irritating. They can be cut. scored and sawed with ordinary wood working tools. Finishes that go over the block, whether cement, doth or other type*- can be applied smoothly and with a minimum of effort. No special tools are needed. LOW MOISTURE ABSORPTION Moisturt absorption is ao prob lem wuh Kayio insulation. Even wnen subjected to an atmosphere of 90 ^ relative humidity and a temperature of 120* F., in standard tests, ipecimeat absorb less chaa 1 mourure by volume. RETAINS EFFECTIVENESS AFTER LONG SERVICE Kayio Heat Insulating Block re mains strong, free from excessive powdering, and shows little ,oss m weight or shn nkige after long appli cation to temperatures up to 12 00* F. Evo conventional rumbling test], run after proloaged heating, produce relatively little crumbling or orea*down of the material. STANDARD SIZES Lengths (inches) 36 36 36 36 36 36 36 36 36 36 Widths Thicknesses (inches) (inches 1 6 6 6 6 6 12 12 12 1 12 12 t -1 * i 2* 3 1 1 >4 2 i ; Other sixes are available on spec * lull VIRSATIIITY On large or small equipment, in side or out. Kayio Heat insulating lock performs efficiently and with a Ainimum of maintenance. Here it is be-** applied to the walls of s large p tutor. Workmen are laying block over 6" x 6" wire mesh welded to the stiffeners. The block are then covered with finishing cement and asphalt mastic wearherproofing. Kayio Heat Insulating Block cov ers both flat and curved surfaces on the power house equipment pictured here. At the right arc fresh air intakes; the canter compartments house in duced draft fans; and at the left are conduits leading to a precipitator. Kayio insulation means continuous fuel savings to this power plant. Hot sparer is always reads >' needed in the office building this hot water storage tank n mm. thanlu to Kayio Heat Insulating Bio- a Thia permanent insulation ho.d * temperature constant wuh a **, of power consumption. Other appiicirioos for Kivio *.............. mg block are listed on ths mo PRINCIPAL FEATURES OF KAY LO H I AT INSULATING BLOCK PHYSICAL CHARACTERISTICS AT A OLANCI ruaioiii ' ^ ' ''I irlwOO* Y.d v wSp* '<* .123 lb* , 7* ttfio* r.:.;. :,:.^y|r.:^.^'.:*i 17 jitf5SKij1 After boiling for 24 hours ^while wet'iZSSfi.^.S 1-74 lb-. per^3^lC^ After headng for 24 houra.-^',-'" ~ - * * T' ' '* at iooo* F........................................................... 7.9* AC 1200 f* 4?. *>i *, sp<f 9*0% - After boiling for 24 hours.'^v......... ................... ................... <r. ~0.2% . r. - iY ->^.-; "'.rrriv r ry^roiff^ id ffcviijpS^' [^r"1 - '"**' (Conrtndonal Tumbling Test--Lose in weight afar 10 ninetes)' :sT._ Before beefing.' hotting i * ... ' **# gggg^Mf ShHnkige'tfar headiigfor 24 hjjk' .,^ 'Z tt^iO* c .............. 0.*% u iooo* ."rvr:^:Wri?1:..T.t'rrr.:T:......... ...'.... .*. o.9%- tt uoo* F................V:.*1:..v.V.............. .......-- t.s* Elongsdon after saturadoo (max.)................ ............................ 0.4% Zlt'Vy'XQ ZZZZHjZZ!:P' (velum*) After 6 hours exposure io sunoaphtrt of 120* F. and 90% Relative Humidity.............................................. 0.9% i r n.t i' f ' At 300* F. oni temperature....................................................... 0.474 0QBhr DKJSGDl^'u'DKjO CD-G=@(:c Haf Loss, Surface Temperature* and Ifficienclts ... WiO *Af nUaHNC nooc OAT ii| 0 Vf ] SUtfea fMfurjaj 0* MOJUTCN > m** wt j" 2> *!*4f * - 3JSk Kat!o>Hm lMakxif TJlodur -i/i Bcaocfcingr: Lehrs * -v , . Autoclaves Ovens f ` ". Towacs Furnaces t -f ' Dtytrfr - <- V . Torbioes " Irsponrors ^.7' Chilling Pit Haas fachaagars Boilers -e- .DATA I'S' * these page- 'ron ic 'inouc :.bbenaon^.'>llusMll-known to ch iaaaiadoa iadaaoy. - They art mrtbcj - * > pportsd by^tbe parforauoce ot ,b< - pw<a ia aairrica. ,*t. Afc ' : ** i '' ' \i *-' - - - ** Moca dosailad in/ormsaoa oc Kayla Haat lasaladng Block > >ul Ala oo raiyiaci. American S<rucrura. Prodaci* Company, Toledo t On.o Sobmdlary of Ow#as*Ill>oo11 G ii Company. A WITH A REMARKABLE COMBINATION 0 KAYLO HEAT INSULATING HOCK is a new ryp of lightweight mineral insulation chat is tjffieitnt enough to be used at ordinary room temperatures and mutant enough co perform effectively up co 1200* F. Few new products of any kind have been so thoroughly researched before being placed on the market. Kaylo Heat Insulating Block is chc achievement of many years' work by Owens-Illinois Glass Company engi neers. physicists and chemists. It combines chc most desirable characteristics of the ideal heat insulation. LOW DENSITY. Kaylo Heat Insulating Block weighs only 11 pounds per cubic foot. This light weight (less than ooe pound to the board foot) simplifies handling, shipping and application. LOW THERMAL CONDUCTIVITY. The coefficient of conductivity, or k, of Kaylo Heat Insulating Block places it among the most efficient insulations for medium high temperatures. Its iosuiation value comes principally from its fine, cellular structure. These cells are so tiny and so numerous that they present a material surface of approximately 140 acres per cubic foot of insulatioo. Experience shows that the eftdeacy of Kaylo insulatioo improves after exposure to service temperatures. EFFECTIVE OVER WIDE TEMPERATURE RANGE Kaylo Heat Insulating Block performs efficient.v -eonly on temperatures in the low pressure steam me hot water range but on temperatures in tne super heated steam range as well. One-material co'e-agt with Kaylo insulation handles applications *mc.often require two thicknesses of different materia.s HIGH COMPRESSIVE STRENGTH, its compress^ strength is unusually high for a mineral product osuch light weight. HIGH FLEXURAL STRENGTH. Its flcsrural strength it higher than the normal requirements for heat msuia tioa of this type. This strength makes for easy hinc ling and application, and contributes to long semet with low maintenance. NO ADDED BINDER. Kaylo insulation is an .r.oriiz: compound, containing no added binder !:s per forraance characteristics, therefore, are not mec-e: additives, which often reduce insulating talue -uo. effective temperature range or otherwue ..m- per formance. EASY TO APPLY. Kaylo Heat Insulating Blocm m clean-cut and trim. They are easy to fit into p.i.e Notice the doom sMfM edges oe these insulated pre cipitator hoppers. AMttneers tod it mat wori with Kaylo Hest loseiaetaf ttM hoesn they ass ao easy to cut and yet have a high lenMNamiA 'ation ) VANTAGES... -.ike * good-looking installation. i*> inMtii ai*4 wfl-imnnnf They can be cut. scored nd sawed with ordinary woodworking tool*. Finishes nit go over the block, whether cement, doth or other vpes. can be applied smoothly and with a minimum f effort. No special tools are needed. OW MOISTURE ABSORPTION. Kaylo Heat Insulat* ng Block absorbs little moisrure from surrounding tumid air. FffCTIVl AFTER LONG SCRVia. Kaylo Heat Insulat* ng Block remains strong, free from excessive powderng. and show s Little lost in weight or shrinkage after long application to temperatures up to 1200* F. Even conventional rumbling tests, run after prolonged nesting, produce relatively little crumbling or break* d-'-n of the material. PfC4i APPLICATIONS: lr : or outside, for large installations or small, up to l2uo* F.. use Kaylo Heat Insulating Block to insulate: Breechings Hot Air Ducts Tanks Towers Dryers Evaporators Heat Exchangers Condensers Lehrs Autoclaves Ovens Furnaces Turbines Chilling Pits Boilers Precipitators Locomotives <oyto Heot Insulating Block unices on the power nmimmng hell lots, it *Hthm :hc room si c Structural Insulating Meek--is a near-white, rigid mineral material weighing approximately 20 pound* per cubic foot. It is pendpelly-of calcium.silicate. Except for density and for chose tica that are changed by denaity it ia similar to Kayic Htat Inruia: a lightweight insulation need to insulate against heat loss from r e Kayio Structural Insulating Block (20*lb. density) it dengned : wrmum strength and fir* resistance without sacrificing iu aclight weight and low thermal conductivity. In fact the practical :: of them four properties--strength, weight, insulating value arc ance--makes tt aimost unique as a building material. It weighs nominally 20 pounds to the cubic foot actually or. abasis from 19.5 to 22 lb.), has a compressive strength of approx ~ lb. per sq. in., a W of 0.66 at 100 mean and outstanding res; travel of heat and flame at building fire temperatures. HEAT INSULATING BLOCK Htol Less, Surface Temperatures, and Efficieneits Tamparatura Sara Surfaca to Air,*f SOUtCSS Of TtST DATA: Tha data showa oa thasa pages are supported by caau rua at *ar ioat laboratories, all wall kaowa to tha iasulatioa industry. Thay ara farther aapponad by tha perforaaaca ot tha product ia aorncs. Mara detailed lefermetlea oe Kaylo Haat Iasulatiag Block is arailable oa request.  <t STRUCT For use in fabrication* that are to be Underwriters __ atone* inspected, Kaylo Structural Insulating 3!<x furnished bearing the Underwriters label 'or nre r.a classification for building material. Kaylo Structural In*ulating Block i* not a finished build* ing material in itself and is not made for erpoeure to the weather. Its principal usee are a* a structural roof tile, or roof deck unit, in which a steel reinforcing mat is inserted at the time of forming, and as a core material. In this latter use it serves as the core of laminated structures where the faces or laminates are applied with adhesives, and also as the core of structural shells or envelopes where the Kaylo core material is simply inserted in the open spaces and held by its own contact or by such conven tional methods as dips or other attachments. In any of these applications it adds rigidity to the structure ind vastly increases insulation value and fire resistance. PHYSICAL PROPERTIES light Weight--Nominal 20-lb. density Kaylo Block is about a third lighter than yellow pine. On an oven-dry basis it weighs from 19.5 to 22 pounds psr cubic foot. High Strength--Its compressive strength is approximately 500 lb. per sq. in. with s deformation of 6 pm cent. Flexural strength is approximately 175 lb. per aq. in. Firepreef-- Kaylo 20-lb. denatr Structural Insulating Block has been teetedai tbs Underwriters' Laboratories in Chicago and given as following rating, based on com- panson with untBtd Oik is 100. Flame spread... Fuel contributed Smoke produced 0.0 Sf**1* f% m m Mmh Tgifgf m Owed Intwietien Veiww--At low mean tempera:..-?* K Structural Insulating Block is one of the r.cs: erf structural mineral insulations. At high mean :emcera: it still compares favorably with heat insuiat;r.; -are of its own weight. High light Kefiedtvity--Where left exposed ar.c (as with the underside of a roof deck) Kay;o 5:-uc Insulating Block has high light reflectivity its i~ flection factor is from 70 to a0 per cent. Nwn-Abrw<v* Swrfeew--Its surface is non-abriii\ e I: a somewhat "soapy" feel that makes it pleasant .0 -.a At the same it has a firm surface that a^s-es contact with surfacee applied over it. Nw Added Under--It contains no added br:er stead constitute* its own binder. Hence >u : are not modified u to temperature limit, so us lation value, fir* reeiatanc* or otherwise ny limitatiota." h. b: L INSULATING BLOCK (20-LB. DENSITY] sod Workability--Kaylo Structural Insulating Block is sponsjve to wood working tools. It can be sawed with a and saw or power saw, can be routed, tongue-and-ooved, sanded, and, in fact, run through most wood* orkang equipment. ih Modulus ef Ile**ity--The modulus of elasticity of 0-lb. density block is approximately 160,000 lb. per sq. in. ow Specie Heet--The specific heat of Kaylo Structural nsulating Block is approximately 0.22. lluler Structure--Kaylo Structural Insulating Block is bout 80 per cent inter-communicating air cells. The cells re extremely small, less than a micron in diameter. w Meistur* AbcerwHen--Kaylo Structural Block is hy* roscopic. It will absorb moisture from humid air and will each equilibrium at lower moisture contents when txpoeed o rer humidities. However, because of its extremely n. pore size and other characteristics, its behavior with espect to moisture differs from that of moet porous ma* or: It has unusual capacity to distribute moisture snti. .. its mass, and to give it off to surrounding air of ower moisture content. its moisture absorption when surrounded by humid air s low. Test specimens dried for 24 hours at 215* F., cooled md then exposed on all surfaces to an atmosphere of 90 ier cent relative humidity and a temperature of 120* F. t six hours, absorbed less than one per cant of moisture > volume. oRsiscene with the common practice for food construe* on involving porous insulating materials of high internal .rface area. Kaylo Structural Insulating Block should 3 sealed against moisture on the warm de when it is .bjected to extremely low temperatures. High wt Strength--Kaylo Structural Insulating Block, ike most other insulating matwials, is not intended to serve immersed in water ormpoaed to extremely damp or humid conditions, yet its flexural strength when wet (im* mersed 10 hours) is reduced only about 15 per cent. Dimentienelly Stable--The dimensions of Kaylo Struc*urai Insulating Block change little wuh changes in moiacure content. Eroerience has shown from the manufacture of thousands of units of laminated structures that trey have unusual dimensional stability and unusuai freeaom from warping. Available wWh and without Roinforciny--In the form of roof tile Kaylo Structural Insulation is available with a steel reinforcing mat. In the form of core material for var ious types of structure it is available without reinforcing. AccepN Nails and Vtrewi --Both nails and screws can be used with Kaylo Structural Block. Tables ahowmg holding power of both are available on request. Nails should be of the cement-coated type without barbs that abrade the sides of the opening they make as they are driven into the block. Galvanized or non-ferrous nails may be used where greater resistance to corrosion is required. Screws may be inserted either with or without drilling a pilot hole. Siset--Kaylo Structural Insulating Block is made n i standard size of 18 x 36 inches. Since most uses involve manufacturing operations :< nesses that are practical can best be worked out w: manufacturer of Kaylo Insulating Products after mate quantities needed are known. These will usua..y : between one and two inches thick. Certain thiclmeates are suggested by certain build:rg ? fuirementa. A thickness of from lHto2 inches of Kn tructural Insulating Block is required to withstand typical building fire for one hour--usually somewr.at -.cfor a partition than for a door because of the greater per formance required ofa partition. 20-U. end 114*. Density Sleek Can Be Used in Cembmvnan Where two thicknenes of insulation are used to o-.a an insulating structure it is - .wible to use the two *.er sities in combination to devrnop the best insuiauoa i .< strength and fire resistance. AMIRICAN STRUCTURAL PRODUCTS COMPANY Telede 1, Okie J lamination ominatian avar Kayfe Insulating Cer^-Almost any face material may be bonded to Kaylo Structural Insulating Block surfaces. Bonding agents can be selected to meet the requirements of the particular facing--also to satisfy the service requirements of the finished product--istill offer some choice in curing procedures. Some adhesives which may be used with various v.-oe: : face materials are listed below. (This list is not intence to be complete. Its .only purpose is to identify a par a list of adhesives. These have been found to provide a ter.s; strength of 35 lb. per sq. in. and a minimum shear strenr of 100 lb. per sq. in. when cured in the manner inaicatec [D2X\7DbADHESIVES FOR JOINING STRUCTURAL INSULATING ILOCK TO: Weed Veneer Aluminum Stainlasi Steel AOHESIVES FOR JOINING LIKE MATERIALS Insulating Hack te Insulating Black Stainlati St*l i# Stainlais St**I to*** M*. 3034A | J014AW307 J0J4AW omi Non 711 CmM 7JO Vtnyltad A JS.II o o o Aa>e'4i* raw o Wik TOSS o o1*4*1 Jr* M)4 o - iiotw (ow) tori'* M*. 1034A Q Nm 711 0 WtUS 0 InMlvt* N*. 1 0 l*i*rl*k* 4141 00 00 000 000 O. L 3143 0. L 7031 VmrUMl ma sail o o o re u ! Ul 13S tori'* N*. 303S 0 H A. NM3S7 N1Q0 0 3 MK S2S 0A0 w*w*m4 0 h*. 1 O 4IAJ Vulislwt to***' 4413 oo 000 0. L 3143 & l 7031 *Uk 20-IS mu' to***'__ 4413 ^ & L 7031 Q S*ik 7014 Q Swtik Ul IIS Q 0 o Q Oampad at raam temperature far 34 haurs. Symbols fer method ef ft Maximum Strength 0 Oampad in avan at 1 Vt f. far 1 knur. 0 Wacad in prass at 10 p.e.1. at 300^ F. far 1040 minutas. Q flawd in prass at 100 p.s.i. at 300^ F. far 1040 minvtaa. [ 0 Qampad in avan at 230* f. far 1M0 minwtas. High-frequency curiae has bam triad sucamfulljr oa aa ncparimnatal baaia nth wood, aluminum and stainlma staal bontod to a Kayla tuiatinf ear*. Many o( tba manufactum making lb* abor* liatad dbaaiv caa provide adbanvaa Mutable lor higb^raquency curing. moMHsvmi* PBQDQDGTO <3GK]PAK!~ TOISOO 1. OHIO S*bktdlary ot OWMS'AUNOfS OtASI CO***" KM nan ( Keyie Servcfvrel ImgMni Week---is a near-white, rigid minerai maunal weighing approximately 20 pounds pr cubic foot. It is principally of calcium silicate. Except for density and for those c.-i ties that art changed by density it is similar to Kayla Htat fusuloi; a lightweight insulation used to insulate against heat loss from hot = Kaylo Structural Insulating Block (20-lb. density) is designed maximum strength and Are resistance without sacrificing its ad' a* light weight and low thermal conductivity. In fact the practical cc-: of these four properties--strength, weight, insulating value arc ance--makes it almost unique as a building material. It weighs nominally 20 pounds to the cubic foot actually on abaaii from 19.5 to 22 lb.;, has a compressive strength of appro* lb. per sq. in., a k" of 0.66 at 100 mean and outstanding re>.?travel of heat and 4ame at building fire temperatures. <HnCere--Almost any fact Kaylo Structural Insulating enu can be selected to meet ticular facing--also to satisfy I QOempsd it me temperetufefee 24 twin. ^ 0QdPalmacpeeddininpemveineat*1I0Wp.sP.i..feete9100k*mP.,fat 1040 mtaetes. Q Placed in pmi * 100 p.*.i. et 300* P. far 1040 minutes. t 0 damped in even et UCt P. fee 1040 minutes. *"* aao8p The Right Material... Expert Application First. Kaylo Heat Insulation is prtxtd a better material hydrous calcium silicate. Its light weight, strength, watermsoiubility. low conductivity and wide temperature range give you extra advantage* u( no extra coat. Second. Kaylo distributor* have the technical knowledge and experience to provide you with a complete insulating service. Their trained applicators are skilled craftsmen who do neat and efficient installation. To be '/'(' of getting the most out of your insulating dollars for your next job. call the nearest Kaylo distributor Chances are you can find him listed in the yellow pages of your phone liook. If not contact us and we ll give you his name wtin roe mi mos--tstw h,i A 44fit 0##*. Me >70, G*U ( KAYLA f*T. I, Ofc*. ... first in calcium silicaf ...pioneered by OWENS (j)'ILLINOIS Gloss Compony mem omci touee i, omo-xsTio isut ossscu. aiuMt* emcseO HOuiroH mm rom nnww mnMtAM n Owens-lllmou Class Company--Kaylo Division MMnwm N X IJJ. ssomnas > IPs leOemu Cttfifikil l*SJ OPPiltfAt*fM<CtmAvrmtjtMtwRMmtnmlu-gJta'MJiMim. Ul....If>IUfaU<t i*dMCornvfaevMMwi-ri*F.tlIf-Ul*SJ 1 LAMINATION jminetien ever a Kayfa Insulating Cerw--Almost anv face material may b* bonded to Kaylo Structural Insul ating Block surface*. Bonding agenu can be selected to meet the requirement* of the particular facing--also to satisfy the service requirements of the finished product --and still offer some choice in curing procedures. AOHISIVIS AND PRIMERS FOR JOINING Some adhesives and primers which may be used nh various types of face materials are listed below. (This list is not intended to be complete. Its only purpose is to identify * partial list of adhesives. An adhesive noj^ listed does not imply that it is not suitable. These ha-. ^ been found to provide a tensile strength of 35 lb. per square inch and a minimum shear strength of 100 lb. per square inch when cured according to the manufac turer's recommendation. They are not listed in the order of their adhesive strength.) y STRUCTURAL INSULATING HOCK TO: 7-r * i c .* k 1. f. Weed Veneer er Paper er Plastics Steel, Stainless Steel Gelveneel, er Aluminum Owrita Mo. J01SA tanaaelita GUI' kxi ns Cato-- 7 JO Vwy--el *> JS-'S AaibafWa Si u i 7014 aUa Sr- M***' laianalwt HI arnin--f J.H4J Ta A .. ri-- > * I el teem temperature fer 34 Heart. ,, ... .,. | A damped la even at 120* f. far 1 hear. Symbo,ls fa,,r m.ated sf arm II XA Wared la prats at 10 p.s.i. at 10(f f. far 1040 minutes. Par Maximum Strength *j 0w Wared la prett at 100 p.*-i. at iOT P. far 1040 minuter. , 0 damped in even at tVf P. far 1M0 minutes. Kigb-frequney curia* her ben tried eirr--fully ea aa tspariarnul *** trith wood, tlumiaura tad saiaims steel beaded te t Ktyle .isularin* cert. Mtny of the manufacturers malrin* the abort tiscod tdbeavm eta provide tdbeeivm witabir fer hifb-frequncy cunn*. Kaylo DIvIsIgii OWINS-I LLINOI5 GLASS COMPANY Talada 1, OHIa ns ms J* 1 STRUCTURAL INSULATING BLOCK Oaok Workability--Kaylo Structural Insulating Block is responsive to wood working tools. It can be sawed with a hand saw or power saw. can be routed. tongue-andgrooved, sandea. and, in fact, run through mott wood working equipment. Dimensionally Stable--The dimensions of Kaylo Struct ural Insulating Block change little with changes m moist ure content. Experience has shown from the manufacture of thousands of units of laminated structures that they have unusual dimensional stability and unusual freedom from warping. High Modulus of HasHcity--The modulus of elasticity of 20-lb. density block is approximately 160,000 lb. per sq. in. Law Soeciflc Hoot--The specific heat of Kaylo Struc Available with and wHhauf lainfardng--In the form of roof tile Kaylo Structural Insulation is available with a steel reinforcing mat. In the form of core material for var ious types of structure it is available without reinforcing. tural Insulating Block is approximately 0.22. Accepts Nails and Screws--Both nails and screws can be Cellular Structure--Kaylo Structural Insulating Block is about 80 per cent inter-communicating air cells. The cells are extremely small, leu than a micron in diameter. used with Kaylo Structural Block. Tables showing holding power of both art available on request. Kails should be of tht cemcnt-coatad type without barbs that abrade the sides of the opening they make as they are driven into the Law Maietwra Absorption--Kaylo Structural Block it block. Galvanized or non-ferrous nails may be used where hygroscopic. It will absorb moisture from humid air and greater resistance to corrosion is required. Screws may be will reach equilibrium at lower moisture contents when inserted either with or without drilling a pilot hole. exposed to lower humidities. However, because of its extremely small pore size and other characteristics, its oehavior with respect to moisture differs from that of Sites--Kaylo Structural Insulating Block is made in a standard size of 18 x 36 inches. . .most porous materials. It has unusual capacity to dis- Since most uses involve manufacturing operations. : - ck- tribute moisture within its mass, and to give it off to nesses that are practical can best be worked out r.n :-e surrounding air of lower moisture content. manufacturer of Kaylo Insulating Products after aporov::- Its moisture absorption when surrounded by humid air is low. Tut specimens dried for 24 hours at 215* F., matt quantities needed are known. These will usually be between one and two inches thick. cooled and then exposed on all surfaces to an atmos Certain thicknesses are suggested by certain building -e- phere of 90 per cent relative humidity and a tempera quirementa. A thiclmam ofTrom 1** to 2 inches of Kayio ture of 120* F. for six hours, absorbed leu than one per Structural Insulating Block is required to withstand a cent of moisture hy volume. typical building fire for one hour--usually somewhat more Consistent with the common practice for good construc tion involving porous insulating materials of high for a partition than for a door because of tht greater per formance required of a partition. internal surface area. Kaylo Structural Insulating Block 30-Lb. and 11-Lb. Density Mack Can la Used In Combination. should be saalad against moisture on the warm side Where two iliiilmessse of insulation are used to bund up when it is subjected t extremely low temperatures. an insulating structure it is possible to use the two den sities in combination to develop the best insulation .x.e High Wet Sinm*i lCflfee Structural Insulating Block, like most other insulpmc materials, ia not intended to strength and fire resistanca. serve immersed in wafer or exposed to extremely damp or humid conditions, yet its flexural strength when wet (immersed 10 hours) ia reduced only about 15 per cent. Kayife Piviifi OWINS-I LLINOIS CLASS COMPANY Telede 1, Ohio For Radii fm Ve Inch... _ to Infinity Nesting Kaylo Heat Insulation Requires Fewer Pieces Per Job The complete range of Kaylo Ineuiation indudee pipe covering in Simplified Dixnenaionai Standard! for diameter* from >4 m to 72 in., curved block from 72 inf to 60 ft. and flat block for aurfacee of leea curvature whose radii approach infinity. With its wide selection of interchangeable tizes and shapes. Kaylo Insulation reducea the number of iteme needed per job and permits substantial savings in warehousing maintenance stock. Mill Mt M MN W*MI MMaa.' KAYLO A44nm 0$>. H-J7I, OilM e*n i OI C----r. **tN OMNat, Tm* I. ON*. ... First in calcium silicata ...pioneered by OWENS ^ILLINOIS Glass Company (mjm owwt< reuse i, ewe-sane taua swim tnaaM cmcavo Newton ww teas rmwim t' iow Owens-Illinois Glass Company mlhir