Document Z8BaYdxBNeZwXne1mOwedLBpd

FILE NAME: Kaiser Gypsum (KG) DATE: 0000 DOC#: KG086 DOCUMENT DESCRIPTION: Legal - Excerpt - Kaiser Cement Supplem ental Responses to P laintiff's Standard Interrogatories - Case & Date Unknown Barry Castleman's Kaiser Gypsum File CD-ROM Document# KG 86 Type of Document jgp) DATEE <^2 0=undatec peer-reviewed journal article trade publication article advertisement newspaper article proceedings from annual meeting conference abstract talk proceedings unpublished or internal report meeting agenda minutes report letter memo govt published report unpubl. inspection industry warning information book excerpt BC n o t e f t * * * " * othe * - * " '* 1 Current addresses, if any, are not known to Kaiser Cement. Some o f these firms are known to have supplied chrysotile asbestos to Kaiser Cement during 1973 (when masonry cement with 2 chrysotile asbestos as a component was manufactured). 3 I. Kaiser Cement's masonry cement was not intended for any o f the special uses of 4 shipyards, power companies or refineries. Kaiser Cement's masonry cement with chrysotile asbestos as a component was not sold to any customer located anywhere in California, and Kaiser 5 Cement has no knowledge that it was used in any premises in California. 6 J. Kaiser Cement will make responsive documents sufficient to substantiate the above 7 information available for inspection upon reasonable notice at the offices o f Jackson & Wallace, 55 Francisco Street, 6th Floor, San Francisco, California, 94133. Kaiser Cement regards and maintains 8 its product formulas as confidential business information. Kaiser Cement is prepared to produce available formulas for masonry cement that contained small amounts o f chrysotile asbestos under a 9 confidentiality agreement. 10 Plastic Cement 11 The only type o f product Kaiser Cement sold to California customers that ever contained 12 chrysotile asbestos was a specialty cement used to make stucco concrete for application on the 13 exterior surfaces o f building walls. During many years, K aiser Cement manufactured plastic cement products that did not contain asbestos as a component. 14 The specific responses to the interrogatory subparts for the plastic cement products with 15 chrysotile asbestos as a component are as follows: 16 A.-C. Kaiser Cement marketed four plastic cement products that contained chrysotile 17 asbestos. Their trade names were Plastite, Plastic Gun Cement, Plastic Cement (hand) and PlastiSpred. Plastite was first marketed with chrysotile asbestos as a component in 1944 and last 18 marketed with chrysotile asbestos as a component in 1945, w hen the product was discontinued. Plastic Gun Cement was first marketed with chrysotile asbestos as a component in late 1959. 19 Manufacture o f Plastic Gun Cement in Northern California w as discontinued in October 1973, when 20 manufacture o f the product was discontinued at Kaiser Cement's Permanente plant. Plastic cement for hand application that did not contain asbestos as a component was first introduced into the 21 Northern California market during World War H Plastic Cement (hand) with chrysotile asbestos as a component was first marketed in Northern California in Decem ber 1961. Manufacture o f Plastic 22 Cement (hand) with chrysotile asbestos as a component was discontinued in Northern California in 23 July 1973, when Kaiser Cement's Permanente plant discontinued manufacture o f the product. The Permanente plant resumed manufacture o f plastic cement for hand application that did not contain 24 asbestos as a component in July 1973. Plastic gun cement with chrysotile asbestos as a component was first manufactured at Kaiser Cement's Cushenbury plant in Southern California in February 25 i960. Chrysotile asbestos was removed from plastic gun cem ent manufactured at Kaiser Cement's Cushenbury plant in July 1976. Plastic Cement (hand) with chrysotile asbestos as a component was 26 first manufactured at Kaiser Cement's Cushenbury plant in September 1963 and was last 27 manufactured at the Cushenbury plant in August 1964. The Cushenbury plant began production o f 32 28 1428034.1 KAISER CEMENT CORPORATION'S SUPPLEMENTAL RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES TO ALL DEFENDANTS 1 plastic cement for band application that did not contain asbestos as a component in late 1964. PlastiSpred, a product similar to plastic cement for hand application, was first manufactured with 2 chrysotile asbestos as a component in late 1961 and was last manufactured prior to the end of 1971, 3 when the product was discontinued. Kaiser Cement has no knowledge that any of the four products with chrysotile asbestos as a component were ever marketed "on an experimental basis" or on a "test 4 basis." None o f these products was ever "recalled from the market." 5 D. The chemical composition of these products w as as follows: 6 Plastite: Approximately 90% portland cement plus adhesive, plasticizing, and water 7 repellent agents. Chrysotile asbestos: 6% by weight. 8 Plastic Gun Cement: Approximately 95% portland cement plus plasticizing and air- 9 entraining agents. Chrysotile asbestos: 2.5% to 5% by weight. 10 Plastic Cement (hand): Approximately 95% portland cement plus plasticizing and air- entraining agents. Chrysotile asbestos: 1% to 5% by weight. 11 Plasti-Spred: Approximately 95% portland cement plus plasticizing and air-entraining 12 agents. Chrysotile asbestos: 1% to 5% by weight. 13 The amount o f chrysotile asbestos used as a component was a specific percentage of the 14 product at any given time. Values stated above in a format such as "2.5% to 5%" mean that some formulas had 2.5% by weight chrysotile asbestos, formulas marketed at other times had 5% by 15 weight chrysotile asbestos, and some formulas had amounts that were between 2.5% and 5% by 16 weight chrysotile asbestos. 17 Kaiser Cement understands that contractors typically mixed one volume of the above products with three to five volumes o f sand, so the percentage of chrysotile asbestos was much 18 lower in the stucco concrete that actually was applied to exterior building surfaces. 19 E. The physical appearance o f Kaiser Cement's plastic cement products with chrysotile 20 asbestos as a component was similar. They all were gray colored powder, which reflected the fact that they were made mostly o f portland cement. Kaiser Cement's plastic cement products that did 21 not contain asbestos also were gray colored powder, for the same reason. Plastite was sold in sacks o f 100 lbs. Plastic Gun Cement, Plastic Cement (hand) and Plasti-Spred with chrysotile asbestos as 22 a component were packaged and sold generally in sacks o f 96 lbs. In years when Kaiser Cement 23 sold plastic cement for hand application that did not contain asbestos, that product also was packaged and sold generally in sacks of 96 lbs. 24 F. Plastite, Plastic Gun Cement, Plastic Cement (hand) and Plasti-Spred all were 25 intended for the same general purpose. They were intended to be mixed with water and sand to form 26 stucco concrete in slurry-like form (like pancake batter). The wet stucco concrete was spread on the exterior walls o f houses or other buildings, where it dried to form a hard stucco concrete layer that 27 served as part o f the building's protection against weather and other outside elements. Plastite, 28 33 1428034.1 KAISER CEMENT CORPORATION'S SUPPLEMENTAL RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES TO ALL DEFENDANTS