Document e7bz4GXRLzrgoq79rE8VE1gmq

i I do-MJLo l/Jiriay! IJ, r- JAMES D. WRIGHT MAERTIN v ARMSTRONG Page 1 to Page 194 JULY 30, 1998 CONDENSED TRANSCRIPT PREPARED BY: BYERS & ANDERSON, INC. COURT REPORTERS & RECORDS COLLECTION 2208 North 30th Suite 202 Tacoma, WA 98403 Phone: 206 627-6401 FAX: 206 838-4884 TOWOLDMONOQ51483 BSA { 1) UNITED STATES DISTRICT COURT f 2) FOR THE DISTRICT OF HEW JERSEY f 3} JOAN HAERT1K, Executrix of ) ( <) the Estate of Lothar ) Maertin; JOAN MAERTIK, ( 5) Individually and in her own right, et al, ( 5) i 1) Civil Action L-95-cv 02849 (JBS) ( 7) ARMSTRONG WORLD INDUSTRIES, ) ( 9) INC., ) ( 9) vs. (10) MONSANTO COMPANY, AMERICAN MINERAL SPIRITS COMPANY and (11) SOLUTIA, INC. 0?) DEPOSITION OF JAWS D. WIGHT (13) (14) (15) JULY 30, 1998 OlYtPIA, WASHINGTON 00 07) (19) (Continued) (19) (20) BYERS A AHOERSOK, INC. (21) COURT REPORTING AND VIDEO (22) 2208 North 30th Street First Interstate Center Suite 202 999 Third Avenue (23) Tacona, Washington 98403 Suite 3800 (2S3) 627-6401 Seattle, Washington 98104 (24) Faxi (253) 383-4884 (206) 340-1316 (25) ( 1) APPEARANCES: ( t) For the Plaintiff (via telephone): ( 3) BRIAN O'CONNOR Attorney at Law ( <} Atriun II, Suite 101 3000 Atriun Way ( S) Ht. Laurel, Hew Jersey 08054 (609) 727-1991 ( 6) ( 7) For the Defendant Armstrong World Industries: ( 9) MATTHEW A. TATLOR Attorney of DUANE, WRRIS & ( 9) HECK5CHER One Liberty Place (10) Philadelphia, PA 19103 ' (215) 979-1140 01) (12) For Hsnsanto Company and Solutia, Inc: 03) JOSEPH E. HOPKINS Attorney of LATHAM & WATKINS (H) One Newark. Center Newark, Hew Jersey 97101 (IS) (973) 639-1234 OS) GERARD H. DAYIDSON, JR. (37) Attorney of SMITH, HELMS, HULLISS k MOORE, LLP (la) 300 Horth Greene Street Suite 1400 (19) Greensboro, K.C. 27420 JULY 30,1998 JAMES D. WRIGHT Page 1 (Continued) (919) 378-5267 (M) (21) For American Mineral Spirits Conpany: (22) JAACS C. OPR Attorney of WILSON, ELSER, (23) MOSKOWITZ, EDELHAH k DICKER Two Gateway Center, 12th Floor (20 Newark, Hew Jersey 97102 (973) 624-0800 .(25) XMAX(1/1) Page 2 ( 1) EXAMINATION INDEX ( 2) EXAMINATION BY: PAGE NO. ( 3) HR. TAYLOR 11 ( *4)0O1S*) 03 HR. ORR 160 ( 5) W. HOPKINS 191 ( 6) ( 7) ( 9) ( 9) 00) EXHIBIT INDEX 01) EXHIBIT NO. DESCRIPTION 02) 1 1-page handwritten notes from 03) Mr. Wright PAGE NO. 17 04) 2 05) S-page Notice to take deposition and produce documents directed to J.D. Wright 17 04) 07) 3 3-page Sales Surmary all PCB containing products, American 73 08) Mineral Spirits 1954-1977 MAE 001073-75 09) (20) 4 8-page Sales Sumury all PCB 76 Page 2 (Continued) (21) (22) s (23) (2) (25) containing products, Union AMSCO 1954-1977, MAE 000523-30 2-page Sales Siramary all PC8 containing products, Armstrong Cork Company 1954-197? MAE 000001*2 Page 3 Page 3 MAERTIN v ARMSTRONG Page 1 to Page 3 TOWOLDMONOQ51484 BSA (1) deposition would also be In response to a 30b6 (2) notice with regard to the relationship between (3) Monsanto and AMSCO. (4) Having made that determination, on Monday we (5) taxed a letter to all counsel, informing them of (6) the 30b6 designation. (7) We produced documents by overnight mall. They (8) were delivered to counsel on Tuesday morning. I (9) personally gave a set of documents to Mr. Taylor at (10) his hotel on Tuesday evening, that relate to that (11) 30b6 notice. (12) Although I was not personally Involved In (13) Identifying and producing these documents, except (14) to have sent them out on Monday, it is my (15) understanding that some of these documents (16) previously were produced, and I'm not going to (17) comment any further on the documents at this time. (18) I will await whatever letter or formal . (19) objections or comments that the parties want to (20) make, so that I can respond when I've had the (21) chance to gather all of the Information (22) together with regard to the documents and that (23) production. (24) And that's all I have to say at this time. (25) MR. TAYLOR: Just to respond. JAMES D. WRIGHT XMAX(3/3) Page 8 (1) Monsanto's rights, I will note that objection for (2) the record. (3) Anybody else? (4) MR. O'CONNOR: I would just like (5) to know what Jim Orr has to think about all of (6) that? (7) MR. ORR: I have no comment (8) MR. O'CONNOR: Neither do I, Jim. . (9) MR. HOPKINS: We are going to (10) bring the witness in and get going. Page 11 HD (12) **** (13) (14) JAMES D. WRIGHT, having been first duly sworn (15) by the Notary, deposed and (16) testified as follows: (17) (18) (19) EXAMINATION (20) BY MR. TAYLOR: (21) Q Mr. Wright, if you could state your full name and (22) address and Social Security Number for the record, (23) please. (24) A My name is James D. Wright. 3144 Lubbers Lane, (25) Olympia, Washington 98502. Social Security Number (1) This is Matt Taylor on behalf of Armstrong World (2) Industries. (3) Mr. Hopkins' statement is consistent with what (4) he put on the record yesterday at Jim Springate's (5) deposition, and my position is stated on that (6) record as well. (7) The only thing I do have to add, Is that I did (8) not receive the documents until late Tuesday (9) evening in San Francisco. Did not- I had a (10) deposition the next day. When I say "documents,-1 (11) mean the documents which Monsanto produced pursuant (12) to the 30b6, a 30b6 notice. (13) It did not describe which notice it was (14) being- they were being produced for. They were (15) not specific to the AMSCO relationship 30b6 notice. (16) But In any event, I did receive them late (17) Tuesday evening, when I was preparing for (18) Springate's deposition yesterday. (19) Last night at 10:00, when I finally arrived in (20) my hotel in Seattle to review those documents, I (21) noticed, one, that they are in a heavily redacted (22) form. They do not have accompanied with it a (23) privilege lock. So I have no basis of knowing what (24) is redacted. (25) And my objection stands as far as the 30b6 Page 9 (1) 493-09-8026. (2) Q Good morning, sir. My name is Matt Taylor, and I (3) represent Armstrong World Industries in the matter (4) that you have been- that you are here entitled (5) Maertin, et al. versus Armstrong World Industries, (6) which Is pending in the United States District (7) Court in New Jersey. (8) Sir, have you had your deposition taken (9) before? (10) A Not for this case, no. (11) Q I understand that. Ever? .(12) A Oh, yes. (13) Q Could you give me an idea of how many times you (14) have been deposed? (15) A At least once that I can recall. Lately as a port (16) commissioner, past port commissioner for the Port (17) of Olympia in relationship to a case with the Port (18) and the Insurance companies relating to (19) contamination of soil on the port property. (20) Q In case you were not given the instructions in (21) those depositions, or at least that one deposition, (22) the court reporter is going to take down my (23) questions and then your answers. (24) A Okay. (25) Q Try to wait until I finish, if you can, my Page 12 (1) deposition stated in the Springate transcript, but (2) I'm going to expand that objection in relation to (3) my discovery deposition for today, because we are (4) out here on a discovery notice deposition, which we (5) have noticed months ago. And,this has been (6) scheduled for weeks as a discovery deposition, not (7) a 30b6 designation. (8) And I reserve the right to redepose (9) Mr. Wright, based upon the documents which were (10) sent to us for the first time just late- well, (11) they were sentTuesday, which l.did not receive. (12) I'm the one taking the deposition. I got those (13) late Tuesday night while I was on the road. (14) It may not be necessary, but I'm going to (15) reserve the right and, again, certainly I (16) appreciate Mr. Hopkins' statement on the record (17) that the 30b6 deposition will take place at a later (18) date mutually convenient to the parties. (19) MR. HOPKINS: Just for the (20) record, I'm noting my objection to Mr. Taylor's (21) reservation of rights, just to the extent it has to (22) do with the fact witness portion of this (23) deposition. (24) We are here. It's already 9:30. We are going (25) to proceed with that today. So just to preserve Page 10 (1) question, even though you may anticipate what my (2) question is going to be, so that the record is (3) clear, so we are not speaking over one another. (4) That is sometimes difficult when you are sure (5) you know how I'm going to finish my question and (6) you know the answer. So just try to let me finish (7) and then go on. (8) if you don't understand any of my questions, 1 (9) speak too quickly, or for any reason you don't (10) understand the question, just tell me that. I will (11) rephrase It and try to ask it in a way that you (12) will understand It. (13) If you need a break at any time, just ask. (14) You control that. The only limitation on that is .(15) that if a question is pending, you must answer it, (16) and then you can take a break. So any time that (17) you need a break, just ask. (18) Sir, are you aware of the nature of the (19) lawsuit in which you are here today for? (20) A Generally, yes. (21) Q What is your general understanding? (22) A In relationship to what? (23) Q Do you know what the case is about? (24) A Well,J understand that the case Is against (25) Armstrong, with Armstrong Cork In relationship to Page 13 JULY 30, 1998 MAERTIN v ARMSTRONG Page 8 to Page 13 TOWOLDMONOQ51485 BSA JAMES D. WRIGHT Page (1) A 1947. (2) Q What was your first position with Monsanto? (3) A Sale** trainee. (4) Q Were you In any particular division or department (5) ot the company as a sales trainee? (6) A Organic chemical* division. Can I get a glass of (7) water? (8) Q Sure. (9) (Pause In the proceeding.) (10) (11) Q (By Mr. Taylor) Mr. Wright, as sales trainee, (12) where were you located? (13) A St. Louis. (14) Q And how long were you a sales trainee? (15) A About a year, I guess. (16) Q Describe that for me. What Is a sales trainee? (17) What was your function? (18) A We went through all of the various departments and (19) various plants, spent time with some the regional (20) managers and distract managers, was sort of a broad (21) exposure to the company. (22) You might recall back in those days there (23) weren't very many people In the company. It was (24) fairly small In comparison to what It Is today. (25) Q And as a sales trainee In the Organic Chemical (1) Q What were the products that you were selling? (2) A Everything the Organic Chemicals Division had a. (3) the time, except petroleum chemicals. (4) Q Now, was the sales force split up Into the (5) plasticizer group at that point, or were you (6) selling plasticizers and all of the products? (7) A All of the products. I was out in the hinterland. (8) A lost man In the field. (9) Q Who were the customers that you were- who were the (10) customers you remember calling on, the larger (11) customers? (12) A French Foods In Rochester, many of the chemical (13) companies in Niagara Falls, steel companies In (14) Buffalo. (15) Q Were you selling PCB-containlng plasticizers at (16) that time? (17) A Very possibly. (18) Q Do you remember being, as part of your training, (19) trained In the application and uses that the (20) PCB-containlng plasticizers could be sold for? (21) MR. HOPKINS: I will object to (22) the form. You can answer. Go ahead. (23) THE WITNESS: Say that again, (24) please. (25) Q (By Mr. Taylor) During your training, whether it (1) Division, I take It you were trained in the various (2) products within the division, or were you limited (3) to a certain product group? (4) A Just a broad, broad familiarization. (5) Q Of the various products? (6) A Of the various products. (7) Q 'Was there a training course that you took then? (8) A Well, we had training courses by the various (9) product groups. 11 was fairly, fairly loose. It (10) was more a familiarization course. (11) Q You were in that position for about a year? (12) A Yeah. (13) Q 1948, did you change positions? (14) A No. (15) Q Tell me what you did? Tell me how long were you a (16) sales trainee? (17) A From there I went to New York as a sales (18) correspondent, which was the usual procedure for (19) most sales trainees, and then later moved to (20) Buffalo, New York, as a salesman In the Buffalo (21) area, still reporting to the New York office. (22) Q Let me stop you there. When did you move to New (23) York as a sales correspondent? (24) A 1948,1 guess. (25) Q How did that- did your duties change from a sales Page 21 (i) was either on-the-job training, or while you were a (2) sales trainee, were you trained in the applications (3) for PCB-containing plasticizers? (4) A I would say, generally, yes. (5) Q Okay. And at that time, In the early 1950s, do you (6) remember what your customers were using the PCB (7) plasticizers for? (8) A I don't recall at all. (9) Q I think I believe your testimony is in 1952 you (10) were in as a Buffalo sales rep until around 1952. (i i) What was your next stop? What was your next (12) position wllhin Monsanto? (13) A Well, then I moved as a sales representative to (14) Pittsburgh. Just a larger territory, moved from (15) Buffalo to Pittsburgh. (16) Q That was in 1952? (17) A '52. (18) Q How long were you-were you still a sales rep? (19) A Yes. ` (20) Q And how long were you in that position? (21) A For six years. (22) Q What did that- what was your geographical (23) territory when you were the sales rep for (24) Pittsburgh? (25) A Well, It just changed directions. I took on a Page 24 Page 22 (D trainee to a sales correspondent? (2) A We answered letters, answered telephones, took (3) orders, the Inside person for the sales people In (4) the field. (5) Q So you worked out of the New York(6) A Office. (?) Q Was It the New York City office? (8) A Yes. (9) Q So you were not out in the field calling on (10) customers at that point? (11) A No, not at that time. . (12) Q What position did you hold when you moved to (13) Buffalo, New York area? (14) A Salesman. (15) Q Salesman. That was how long? When was that? What (16) year was that? (17) A I think about a year and a half or so. (18) Q How long were you a salesman? (19) A From '49 to '52. 1949, May of '49 to January of (20) '52. (21) Q (22) A (23) Q As a salesmen? A sales rep In Buffalo. This was still within the Organic Chemical (24) Division? (25) A Yes. Page 25 (1) broader area of Pennsylvania and Western New York. (2) Q Was it the western part of Pennsylvania, or did you (3) get into the eastern part of Pennsylvania? (4) A Just about to Altoona. (5) Q Altoona and west- 16) A Yes. (7) Q - would you say? (8) Did your status, or did your job title change (9) between 1952 and 1958, or were you still- were you (10) still referred to as a sales rep? (11) A Yes. (12) Q During that time, did you have any occasion to call (13) on Armstrong? (14) A No. (15) Q What was your next position after 1952? (16) A District sales manager In Pittsburgh from '58 to (17) '61. (18) Q How did your duties change from a sales rep to a (19) district sales manager? (20) A I had more responsibility. I had another salesman (21) working with me, and they recognized me as a (22) district salesman, which was the sales manager. (23) Q Did that still include the same area that you (24) covered as the sales rep in the Pittsburgh area? . (25) A Basically the same, yes. - JULY 30, 1998 MAERTIN v ARMSTRONG Page 20 to Page 25 TOWOLDMONOQ51486 BSA JAMES D. WRIGHT XMAX(7/7j ' Page 32 (1) A Well, It wae a management decision trom a marketing (2) standpoint to try to relieve our salesmen from (3) calling on small accounts, drums of product, as a (4) comparison of what our efforts were. (5) Q Well, tell me how that- you said there was (6) resistance. Who resisted that? (7) A Salesmen and district managers and many others. (8) You know, they didn't see the value from a credit (9) standpoint (10) When you are a salesman, you always look at (11) credits, as we were not on commission, but they (12) were very closely graded or assessed by their (13) performance by credits of sales. (14) Q Well, did you have someone that-either one person (15) or a committee that you were reporting to in (16) connection with the negotiations or the process of (17) engaging a distributor or the distributors? (18) A Yes. (19) Q Who was that? ' (20) A It would be both of the regional managers or (21) district managers In New York, who was really (22) looking for ways to make his sales people more (23) efficient and also the product managers. (24) Q Who was that regional managers in New York that you (25) were dealing with In that Issue, the (1) You can answer. (2) THE WITNESS: I would assume so, (3) and along with other people, Input from other (4) regional managers and district managers and product (5) managers. (6) Q (By Mr. Taylor) Okay. What did you do in that (7) regard as far as researching what distributor (8) Monsanto would ultimately use? (9) A I talked to the distributors. (10) Q And had you had experience with distributors in (i i) your career prior to 1961 ? (12) A No. (13) Q So how did you go about finding what distributors (14) would meet your needs? (15) A Who could offer the best services. (16) Q 1 understand that. How did you go about doing It? (17) How did you go about researching It? (18) MR. TAYLOR: Excuse me, (19) Mr. Davidson, do you have something to say on the (20) record? (21) MR. DAVIDSON: I will, If you (22) want me to. (23) MR. TAYLOR: You are not admitted (24) in this case. (25) MR. HOPKINS: Well, wait a Page 35 Page 33 (1) distributorship issue? (2) A Too long. I don't remember. (3) Q Okay. Do you remember any of product managers that (4) you were dealing with on that distributorship (5) topic? (6) A Howard Bergln was the- was the product manager as (7) I recall. (8) Q Were you given that assignment to work out the (9) details of bringing on the distributor? (10) A Yes. (11) Q When did that process start? (12) A Well, during the period I was there as industry (13) sales manager, which I was there for about three (14) years, (15) Q Did it start in 1961? (16) A I don't recall. (17) Q Well, did those efforts regarding bringing on (18) distributors begin prior to you becoming industry (19) sales manager in 1961, while you were a district (20) sales managers in the Pittsburgh area? (21) A Say that again? I don't think I followed you on (22) that (23) Q Did the efforts to bring on a distributor begin (24) when you took the position of Industry sales (25) manager in 1961 in New York, or did it begin while (1) minute. ' (2) MR. TAYLOR: Counsel, is here, (3) and I would just appredate- (4) MR. DAVIDSON: I was just (5) speaking to counsel. (6) MR. HOPKINS: Mr. Davidson is (7) not speaking on the record. He was speaking to me (8) in a quiet voice that was not interrupting you at (9) all. (10) MR. TAYLOR: Fine. Okay. (11) MR. HOPKINS: As to being (12) admitted in this case, Master Judge Rosen has (13) already indicated previously that Mr. Davidson can (14) make an appearance without being formally admitted. (15) MR. TAYLOR: Is that right? (16) MR. HOPKINS: That's right. (17) MR. TAYLOR: I was not aware of (18) that. I don't think that is accurate. (19) MR. HOPKINS: That is completely - (20) accurate. If you want to take it up with the (21) Court, we can do that. (22) MR. TAYLOR: We may. But as long (23) as he doesn't speak on the record, I'm not going to (24) raise the objection. (25) MR. HOPKINS: He is not speaking Page 36 Page 34 (1) you were a district sales manager in the Pittsburgh (2) area? (3) A When I was Industries sales manager In New York. (4) Q Did you research what distributors would be (5) appropriate for this role or this situation? (6) MR. HOPKINS: Object to the form. (7) You can answer. Go ahead. (8) THE WITNESS: Well, the main (9) reason that we took on distributors was because of (10) the competition of some of our major competitors, (11) such as, for example, Carbide, yvho had a (12) combination of products for solvents and (13) plasticizers and other chemicals, and that seemed (14) to thwart some of our sales people in the field for (15) combination of truckloads of plasticizers and (16) solvents were delivered to a customer, thereby, (17) they could- they could take advantage of a (18) truckload pricing as against a single LTL shipments (19) of which we could only offer. (20) Q (By Mr. Taylor) What is "LTL shipments'? (21) A Less than truckload. (22) Q I appreciate that. But my question Is: Did you (23) approach- did you research what distributor would (24) be appropriate to fill Monsanto's needs for that? (25) MR. HOPKINS: Object to the form. Page 37 (1) on the record. . (2) MR. TAYLOR: If he does, I'm (3) going to object to it. (4) MR. HOPKINS: He is not speaking ' (5) on the record. (6) Q (By Mr. Taylor) What did you do to research, for (7) example, AMSCO to find them, seek them out? (8) A Well, they were well-known In the field for product (9) lines that they had, because they were already (10) distributing products, a combination of products. (11) They just needed a plasticizer line to augment (12) what they had. So they were known In the field, as (13) well as other distributors. (14) Q You were aware of AMSCO in your prior experience (15) before you took on this position as industry sales (16) manager? (17) A No. (18) Q Okay. How did you become aware of AMSCO? . (19) A Through recommendations of our district manager and (20) salesmen in the field. (21) Q Okay. Did you then seek out a meeting with AMSCO? (22) A Sure. (23) Q As well as the other distributors? (24) A Sure. (25) Q Who did you first meet with from AMSCO? - JULY 30, 1998 MAERTIN v ARMSTRONG Page 32 to Page 37 TOWOLDMONOQ51487 BSA JAMES D. WRIGHT Page 44 (1) Q Well, did-I'm going to get back to the agreement (2) with AMSCO. But after you left the position in New (3) York as the industry sales representative, or (4) industrial sales representative, did someone else (5) take over as the point person, for lack of a better (6) word, to deal with AMSCO or Central Solvents? (7) A No. I don't think so. ft was Just, again, the (8) reorganization of the structure of the field (9) offices. (10) Q Well, after you left, would AMSCO contact you if (11) they had an issue regarding the distribution (12) contract that they had with Monsanto? (13) A No. (14) Q Who would they contact? (15) A Regional district managers and the product (16) managers. (17) Q Was there someone in the home office In St. Louis (18) that had a responsibility to deal with the (19) distributor? ' (20) A The product managers. (21) Q Who was that tor plasticizers? (22) A Whoever was in the product manager Job at the time. (23) We had a lot of changes, and so I can't quite- (24) can't help you on that unless we look at some kind (25) of records. (D customer. (2) Q Okay. Between 1968 and 1972, as a field salt (3) manager, was part of your responsibility to (4) research who the distributors were selling the (5) products to? (0) A We did not ask our distributors to, and they were (7) reluctant to give us names of their customers. (B) Q Why was that? (9) A It's the general method of operation. They have (10) their customers. We sell the product to the (11) distributors, and then they buy it and resell IL (12) Q And it was the policy of Monsanto not to ask the (13) distributors to- not to ask the distributors who (14) they were selling to7 (15) MR. HOPKINS: Object to the form. (16) MR. TAYLOR: On what basis is (17) that? (18) MR. HOPKINS: Pardon me? (19) MR. TAYLOR: What basis is the (20) form? Tell me what the objection to the form is on (21) that? (22) MR. HOPKINS: Because I don't (23) know that he has any knowledge as to what the (24) policy of Monsanto is, and you have already (25) indicated today that he is not being taken as a Page 45 (1) Q And maybe we can when we go through that. (2) A Okay. (3) Q Your position as regional sales manager in the (4) Atlanta office began that 1968? (5) A Yes. (6) Q How long were you in that position? (7) A My records show that was April of '68. (0) Q Okay. How long were you a regional sales manager? (9) A It looks like about four months. (10) Q I'm sorry. What was your next position? (11) A Then I moved to SL Louis as field sales manager. (12) Q In 1968? (13) A Yes. (14) Q What did that position- what was that about? (15) A Well, I was responsible for working with all of the (16) fields, the regional district managers, and (17) salesmen, throughout the company for the organic (18) chemicals division. (19) Q Which would Indude the plastidzer line? (20) A Which would Include the plasticizer. (21) Q How long were you a field sales manager out of the (22) St. Louis office? (23) A Until 1972, January. (24) Q Now, as field sales manager, did you have any (25) responsibility in dealing with the distributors and Page 48 (1) 30b6 witness. (2) MR. TAYLOR: Sir, I'll rephrase (3) the question. (4) Q (By Mr. Taylor) You stated that Monsanto did not (5) ask the distributors who they were selling the (6) products to, correct? (7) MR. TAYLOR: Why don't we read (8) back that question and answer about three questions (9) ago, and I will take It from there. (10) (Questions and Answers on (11) Page 47, Lines 2 through (12) 11, read by the court (13) reporter.) (14) (15) Q (By Mr. Taylor) I will take it from there. (16) You testified that it was, as I understand (17) your testimony, and correct me if I'm wrong, was it (18) the general method of operation of Monsanto not to (19) ask the distributors who they were selling the ~ (20) product line to? (21) A The relationship of distributors with the Monsanto (22) field people was a matter of developing strong (23) joint efforts In many cases. (24) Generally, the field regional managers and (25) salesmen were aware from time to time as who the (1) their contracts? (2) A Sure. (3) Q Okay. Tell me about what those responsibilities (4) included, just In relationship to distributors? (5) A Well, In an administrative Job, so we worked with (6) the district manager and the product manager in (7) trying to maintain and maximize our sales of (8) product. That's the Job of the field sales (9) manager, . (10) Q I'm want to zero in on dealings with your (11) distributors. Did you have dealings with the (12) distributors directly while you were a field sales (13) manager in SL Louis between 1968 and 1972? (14) A Well, I had dealings with distributors and (15) customers at that time. (16) Q Okay. I'm talking about distributors. (17) A Okay. (18) Q What were your responsibilities in relation to the (19) distributors? (20) A No direct responsibility at the time, Just only as (21) an overview and administrative order. (22) Q Tell me what you would do In that regard, overview (23) or administrative? (24) A ' Analysis of sales, analysis of sales effort, the (25) growth of product lines, the growth of the Page 46 (1) distributors were selling to, but we did not (2) receive any formal notice from any distributor, as (3) I recall, that these were their customer lists. Page 49 (4) Q Okay. As field sales manager, in St Louis between ' (5) 1968 and 1972, did you seek information as to who (6) the distributors were selling your products to? (7) A I don't recall. (8) Q As a general method of operation, did Monsanto have (9) a concern as to where its plasticizer products were (10) being sold, and how they were being used? (11) MR. HOPKINS: Object to the form. (12) You can answer. (13) THE WITNESS: Well, I think- say (14) that again. (15) MR. TAYLOR: Can you read the (16) question back. (17) (Question on Page 49, Lines (18) 8 through 10, read by the (19) court reporter.) (20) (21) THE WITNESS: I can't speculate (22) on that, because my contacts with the distributors (23) and our salesmen were only from an administrative (24) basis. (25) Any of the proprietary products I'm sure that - JULY 30, 1998 MAERTIN v ARMSTRONG Page 44 to Page 49 TOWOLDMONOQ51488 BSA JAMES D. WRIGHT XMAX(11/11) Page 56 (1) A So lor 12 years. (2) Q 1992, roughly? (3) A Yeah. (4) Q Was that an elected position or an appointed (5) position? (6) A Elected. (7) Q How long were your terms? (8) A Six years, two terms. (9) Q During that time between 1980 and 1992, did you do (10) any consulting work tor Monsanto? (11) A No. (12) Q Have you ever been an expert witness in any piece (13) of litigation? (14) A No. (15) Q In 1992, what was your- what did you do after Port (16) Commissioner? Were you employed? (17) A Not employed. I was on the board of several (18) companies, but other than that, that's It (19) Q Sir, We are going to go back to the time when you (20) were In New York, roughly 1961, as an industrial (21) sales manager, and when you were leading up to the (22) time when Monsanto entered an agreement with AMSCO (23) and also Central Solvents. (24) Were those distributors required to go through (25) any training in Monsanto's products? (1) A Oh, yeah. (2) Q Tell me what- describe to me the training? Just (3) if you can, generally, not specifically? Just (4) generally, where was It, and tall me how It was (5) conducted? (6) I believe you said It was done In your New (7) York office? (8) A No. (9) Q I'm sorry. (10) A Done at thedistributors'offices, the training. (11) Q For the training you would go to the distributors' (12) offices? (13) A Yes. Because they would have their salesmen In. (14) Q And would the training be done in one location or (15) would you go around the country to the various (16) outlets of the distributors? (17) A What period are you talking about? (18) Q Well, I'm talking about In the beginning, when they (19) first came on-board as a distributor, either of (20) these companies? (21) A Well, our relationship In the New York area was (22) primarily In the New York area. That's where It (23) started. (24) Q Okay. Tell me how It progressed, the training, and (25) where It progressed to? Page E Page 57 (D A That was the responsibility of the product manager, (2) so there were general familiarization courses or (3) training periods with all of the distributors to (4) Introduce them to our line of plasticizers. (5) Q You remember that taking place? (6) A Oh, yes. (7) Q Where were those training courses held? (8) A Generally, In the district offices of the (9) distributor. (10) Q And who would conduct those courses for Monsanto? (11) A Well, we had product specialists for each of our (12) product lines within the plasticizer group. And we (13) might have had three or four product lines within (14) the plasticizer group. (15) Q So the product specialists would come in and train (16) the distributors' people? (17) A Yeah. (18) Q And were AMSCO and Central Solvents trained at the (19) same time, or did they have separate training? (20) A Separate training. Different companies. (21) Q How did it work between AMSCO and Central Solvents, (22) were they given exclusive territories or not? (23) A No. (24) Q Who was- which company, AMSCO or Central Solvents, (25) had a larger volume business for Monsanto? (1) MR. HOPKINS: Object to the form. (2) You can answer. Go ahead. (3) THE WITNESS: The training was (4) arranged by the district manager, our district (5) manager and his salesmen who serviced the AMSCO (6) account, or district, wherever they were located. (7) And then they would call on the- they would (8) call. I would help coordinate the people from St. (9) Louis to show up,' and we would put on a training (10) session. (11) Q (By Mr. Taylor) Tell me about the training (12) sessions. How long would they last? (13) A Oh, a number of hours, sometimes a half a day H (14) not longer. (15) Q Would it ever last more than a day? (16) A No. I don't think so. (17) Q Was it a one-time training, or would you go back (18) for follow-up? (19) A Depending upon the need. ' (20) Q Was there ever a situations where after the Initial (21) training, the distributor would call Monsanto and (22) schedule additional training for those same (23) people? (24) A Very possibly. (25) Q Do you ever remember that happening? Page 60 Page 58 (1) A What period? (2) Q Well, why don't we start from the beginning, from (3) the early '60s. (4) A I think Central Solvents grew In their sales- In (5) their sales probably faster In some cases than (6) AMSCO. (7) Q And did that change? Did AMSCO catch up or become (8) equal to Central Solvents? (9) A We always felt that AMSCO was a very Important (10) person In the group within our distributor (11) function. . (12) Q Did they catch up to Central Solvents? (13) A I don't recall. I don't think so. (14) Q Well, did it change over time, where AMSCO began (15) to sell more of your products than Central (16) Solvents? (17) A I don't recall. (18) Q Back to the training of the distributors. Anyone (19) else besides the product specialists train the (20) distributors' people? (21) A Some of our research people generally would (22) participate on occasion, but I don't-1 can't be (23) specific. (24) Q Well, did you ever sit In on any of these training (25) session of the distributors' people? (1) A 1 don't recall. (2) Q Now, what topics were covered in these training (3) sessions? (4) A Generally, all of our plasticizer line. So each (5) product Is different In how It's used, where Its (6) applications might be and the markets that we see (7) It. V (8) Q Would the distributor- distributor trainee, would (9) be their salesmen? (10) A Yes. (11) Q Did they have any of their own technical people (12) that were being trained, for example, at AMSCO? (13) A I don't recall. (14) Q And were there demonstrations of applications on (15) products conducted during these training sessions (16) or was It all bookwork, went through the books? (17) A Bookwork. (18) Q And were Monsanto's technical bulletins and (19) literature distributed during those- (20) A Yes. (21) Q -meetings? (22) A Generally, I would say, yes. (23) Q And were the distributors- were the distributors (24) authorized- were the distributors given copies (25) ol- distributor salesmen, given copies of the Page 61 . - JULY 30, 1998 MAERTIN v ARMSTRONG Page 56 to Page 61 TOWOLDMONOQ51489 BSA JAMES D. WRIGHT XMAX(13/13) (1) AMSCO? Page 68 (1) THE WITNESS: It would be the Page (2) A Ye*. (3) Q Was AMSCO ever invited to Monsanto's sales (2) responsibility of the product manager and the (3) district manager and the salesmen, not necessarily (4) meetings? (5) A No. (6) Q Mr. Wright, did AMSCO have Its pwn technical people (4) my Job. (5) Q (By Mr. Taylor) Were you ever Involved with the (6) plasticizer council within Monsanto? (7) in-house? (8) A I don't know. (9) MR. ORR:You said you don't (10) know? (7) MR. HOPKINS: (8) You can answer. (9) THE WITNESS: (10) our contracts. Object to the form. Only in writing up (11) THE WITNESS: I don't know. (12) Q (By Mr. Taylor) In your career at Monsanto, did (11) Q (By Mr. Taylor) What was your understanding of (12) what the plasticizer council was? (13) you ever deal with Armstrong Cork Company? (14) A No. (15) Q When you were a- between 1968 and 1972, when you (16) were the field sales manager, did you review the (17) sales of Monsanto to Armstrong? (18) A With our district manager. (13) A It was out of our legal department and the (14) particular lawyer that It was attached to or (15) department or division. (16) Q Did you ever travel to any of the Armstrong plants (17) or corporate offices? (18) A No. (19) Q That wasn't an articulate questions. (20) Did you deal with Armstrong, I meant, In any (21) way? Not face-to-face, but did you deal- did any (19) Q Did you ever meet with any personnel from (20) Armstrong? (21) A I don't recall. (22) of your Job duties Include sales to Armstrong? (23) A As the plasticizer division or product group, yes. (22) Q Were you involved in any of the committees studying (23) whether the PCB-containing plasticizers should be (24) Q Tell me about that Tell me about your involvement (25) in any way with Armstrong? (24) withdrawn from the market? (25) A No. (1) A Armstrong was a very Important customer of (2) Monsanto, primarily In the floor tile field. (3) Q What other products do you remember- besides (4) floor products- do you remember Armstrong (5) Manufacturing? (6) A That's all. (7) Q .Atthetime-r (8) A That's It. (9) Q - that you were at Monsanto, did you- were you (10) aware that Armstrong manufactured ceiling tiles? (11) A No. (12) Q Was part of your function as the district sales (13) manager or field sales manager between 1968 and (14) 1972, did you get involved in any of the marketing (15) activities of the sales group. (16) A Well, explain that. That Is the whole Job of a (17) field sales manager. (18) Q Fair enough. Did you get Involved in marketing (19) Intelligence? (20) A Such as? (21) MR. HOPKINS: I will object to (22) form. (23) Q (By Mr. Taylor) Have you heard of the term (24) `marketing intelligence'? Are you familiar with (25) that term? Page 69 Page 72 (1) Q Were you aware that there were committees formed to (2) study that topic? (3) A Yes. (4) Q What were you aware of? When did you become aware (5) of it? (6) MR. HOPKINS: Object to the form. (7) You can answer. (8) THE WITNESS: I don'trecall. (9) Q (By Mr. Taylor) Well, what committees do you (10) remember that were studying that topic? (11) A I don't recall. (12) Q Were you advised, as the field sales manager, that (13) there was a- prior to the Arodors being pulled (14) from the market for the plasticizer group, were you (15) advised that that topic was being studied and that (16) that was a possibility? (17) MR. HOPKINS: Object to the form. (18) You can answer. (19) THE WITNESS: I don't recall. ` (20) Q (By Mr. Taylor) Do you recall that the (21) PCB-containing Arodors were withdrawn from the (22) market? (23) A Yes. (24) Q Do you remember when thatwas? (25) A No. (1) A No. (2) Q Was part of your duties to obtain information as (3) to what products your customers were (4) manufacturing? (5) MR. HOPKINS: When he was a field (6) sales manager? (7) THE WITNESS: No. (8) MR. TAYLOR: That's right. (9) THE WITNESS: No. (10) Q (By Mr. Taylor) What I meant by that is, was part (11) of the sales group, was there efforts made to (12) determine for purposes of knowing what products (13) your customers may need, what products the (14) customers were manufacturing or planning to (15) manufacture In the future? (16) MR. HOPKINS: Object to the form. (17) You can answer. (18) THE WITNESS: Say that again. (19) MR. TAYLOR: If you can just read (20) that question back. If you don't understand it, I (21) can rephrase It. (22) (Question on Page 70, Lines (23) 10 through 15, read by the (24) court reporter.) (25) Ill Page 70 Page 73 (1) Q Do you remember how long prior to that taking (2) place, that you were advised that that was the way (3) the company had dedded to go? (4) A No, (5) Q Were you involved in any way in drafting the (6) communications to either the distributors or the (7) customers that the Arodor plastidzers containing (8) PCBs were going to be withdrawn from the market? (9) A No. (10) Q Do you remember who was? (11) A The sales manager at the time, I think. (12) Q Who was that? (13) A Walter Schalk, or, yeah, I guess that's who It was. (14) MR. TAYLOR: If we could,we'll (15) mark this as Wright No. 3. This Is the sales (16) summary, 'All PCB-containing products, American (17) Mineral Spirits, Conshohocken, PA, 1954 to 1997.' (18) It bears Bates MAE 001073 through 75. (19) (Exhibit No. 3 marked lor (20) identification.) (21) (22) Q (By Mr. Taylor) If you could, Mr. Wright, just (23) review that and tell me if you recognize that type (24) of document? (25) A No. JULY 30, 1998 MAERTIN v ARMSTRONG Page 68 to Page 73 TOWOLDMONOQ51490 BSA JAMES D. WRIGHT XMAX(15/15) (1) Q What types of documents would you review? (2) MR. HOPKINS: Object to the form. (3) Q (By Mr. Taylor) If you look at the second and (4) third page of the document there seems to be (5) another type of form. It's a product/customer (6) sales report (7) A Yes. (8) Q Is the type of document you would review? (9) A Yes. (10) Q Obviously, this has been redacted, but it does have (11) certain Information on It. For example, `Union (12) AMSCO, Philadelphia, PA.1 (13) Do you see that? ' (14) A Where are you looking? (15) Q I'm sorry. Turn to the next page. (16) A (Witness complies.) Okay. (17) Q Is that right? (18) A Yes. (19) Q Was Union AMSCO one of your distributors, or was (20) that a direct customer situation? (21) A That Is the Union Oil, AMSCO. It Is one and the (22) same. (23) Q Okay. Let's go back to the page you ware looking (24) on, the second page of the document. You will see, (25) what 1 think is American Mineral Spirits, Page 80 (1) refresh my memory at all. (2) Q (By Mr. Taylor) So this is-you will agree with (3) me, that this Is a Monsanto company document, (4) correct? (5) A Yes. (6) Q And that, at least on this document, Monsanto was (7) aware of who the distributor was selling their (8) product to, correct? (9) A Yes. (10) Q And In all of the cases, all of the shipments of (i 1) product, plasticizer products to AMSCO, was (12) Monsanto aware of who they were going- who AMSCO (13) was going to sell that product to? (14) MR. HOPKINS: Object to the form. (15) You can answer. (16) THE WITNESS: In this case it (17) appears to be a drop shipment. In other words, we (1B) shipped directly from the plant to this particular (19) location In Philadelphia. And what Pecora Chemical (20) Corporation is, I don't know. It could be a (21) warehouse. (22) Q (By Mr. Taylor) And was(23) A And you notice that they were full truckloads. (24) Q 1 didn't notice that. Point to me where that (25) information is? Page 6j (1) Philadelphia, PA, 5715, Arodor 1254. (2) Do you see that? (3) A Yes. (4) Q And can you tell what date that was shipped? (5) A No. (6) Q Is there any significance to the(7) A ft Is a sales report for December 1970. It was a (8) monthly report(9) Q Okay. (10) A - of total sales to the distributors. (11) Q Is there any significance- is this a year-end (12) report or is this a monthly report? (13) Up on top It says: 'Organic Division, (14) Plastidzers, No. 4, customer/product sales report (15) for December 1970.' (16) A That's right. (17) Q So does this Indicate that In December of 1970, (18) 156,600 pounds of Arodor 1254 was shipped to (19) American Mineral Spirits, Philadelphia, PA? (20) A That's right. (21) Q And Is a plastidzer form? (22) MR. TAYLOR: Just for the (23) record- Mr. Davidson. 1 don't know if it was- (24) did you take down what Mr. Davidson said? (25) THE COURT REPORTER: No. Page 81 Page 84 (1) A 37,800 pounds Is a full truckload of drums. (2) Q Of drums? (3) A Yes. (4) Q Not a tank car? (5) A That is right. (6) Q And when you- 1 believe you said `drop shipment1? (7) A Yes. (8) Q Is there some other type of shipment that is (9) different than a drop shipment? (10) A Directly to- directly to AMSCO's warehouses. (11) Q And a drop shipment would be? (12) A To the third party, (13) Q To a third party. Okay. (14) And if you turn to the last page of that (15) document, of that exhibit, that being No. 4, Wright (16) No. 4, bearing Bates MAE 000530. (17) A (Witness complies.) (18) Q Is this another example of a drop shipment? (19) A Yes, ~ (20) Q You see there where it says: `Harleco Chemicals"? (21) Do you see that? (22) A Yes. (23) Q Is that a- do you remember that company? (24) A No. (25) Q Do you know whether that is a customer of AMSCO? (1) MR. TAYLOR: Fine. (2) Q (By Mr. Taylor) What was your understanding of (3) that document, sir? (4) A That Is a monthly report. (5) Q That this is a plastidzer product? (6) A Aroclor 1254, sure. (7) Q If you could go back to- If you go back to the (8) fourth page of this document. Again, that is a (9) Monsanto company form. You said this is an (10) Invoice, or Is this- (11) A This is a shipping- a shipping form. Monsanto's (12) shipping forms and invoices would be on a similar (13) facsimile of this, where the pricing and the total (14) value would be involved tor Invoicing. So this Is (15) a shipping notice. (16) if you notice down here on July 13,1970, they (17) expect to ship. This went to the customer as well (18) as to the product group. (19) Q Does that refresh your recollection, sir, of (20) whether Monsanto kept records- kept records of who (21) American Mineral Spirits was selling your (22) plasticizer products to? (23) MR. HOPKINS: Object to the form. (24) You can answer. (25) THE WITNESS: No. That doesn't Page 82 (1) A We billed AMSCO. (2) Q 1 understand that. (3) Do you know whether Harleco was a customer of (4) AMSCO's from this document, or was that a direct (5) customer of Monsanto? (6) A Oh, no. A customer of AMSCO. (7) Q Okay. And when was this- this shipment In the box (8) in the right-hand corner was expected to be shipped (9) on October 6th, 1970? (10) A Yes. (i 1) Q And this was a plasticizer product? (12) A Yes. (13) Q And Arodor 1254? (14) A Yes. (15) Q 6,000 pounds? (16) A Yes. (17) Q And do you see there where it says steel'under (16) description? (19) A No. Oh, steel drums. (20) Q Steel drums. Okay. I didn't know. (21) Where It says here, I noticed this on the (22) other similar forms It says: 'Less distributor1(23) A - "discount." (24) Q 'Five percent.1 Tell me how that worked? (25) A Very simple. Page 85 JULY 30,1998 MAERTIN v ARMSTRONG Page 80 to Page 85 TOWOLDMONOQ51491 BSA JAMES D. WRIGHT xmax(i7/17) Page 92 (1) Number 6, Wright No. 6, with today's date, Is a (2) document entitled: "Your Guide To Top-Quality (3) Plasticizers.' It bears Bates stamp MAE 059457 (4) through 059464. (5) And H you could, review that for a moment and (6) let me know when you are finished. (7) A (Witness compiles.) Okay. (8) Q 0) A (10) It. (") Q (12) A Is this a Monsanto publication? It appears to be since It has the Monsanto label on And do you remember this document? No. (13) Q How would you describe this document? (14) MR. HOPKINS: Object to the form. (15) You can answer. (16) THE WITNESS: A sales Item. (17) Q (By Mr. Taylor) This Is a sales- (18) A A sales. (19) Q - sales bulletin? ' (20) A Bulletin. (21) Q II you can turn to the back page. (22) A (Witness compiles.) (23) Q You will see AMSCO's Insignia on the bottom left, (24) towards- on the left. Do you see that? (25) A Uh-huh. (Witness answers affirmatively.) Page 9i (i) in, on the document bearing 059461. (2) A (Witness compiles.) Okay. (3) Q Sir, were you, when you were at Monsanto, either as (4) a salesman or as a field sales manager, conversant (5) in the qualities ol the Arodor products? (6) MR. HOPKINS: Object to the form. (7) You may answer. (8) THE WITNESS: Was 1 conversant (9) with the Arodor products? Yes. (10) Q (By Mr. Taylor) Their positive qualities which you (11) used to market to customers? (12) A Yes. (13) Q And do you remember the Issue of whether a product (14) was flame resistant or flame retardant? (15) MR. HOPKINS: Object to the form. (16) THE WITNESS: Yes. (17) Q (By Mr. Taylor) And was there a distinction in (18) your mind between flame resistant and flame (19) retardencey? (20) A It's a matter of terminology. (21) Q Is there- I'm sorry. (22) A Probably used. Not probably. Okay. A matter of (23) terminology. (24) Q What do you mean by that, "a matter of (25) terminology"? 1 asked you if there was a Page 93 (D Q You'll see addresses across the country. Do you (2) see that? (3) A Uh-huh. (Witness answers affirmatively.) (4) Q Under American Mineral Spirits Company? (5) A Uh-huh. (Witness answers affirmatively.) (6) Q Can you explain why AMSCO's Insignia and outlets or (7) locations are part of this document? (8) A 1 cannot. (9) Q Does that in your experience seem unusual? (Id) MR. ORR: Object to the form of (11) the question. (12) MR. HOPKINS: Join. (13) THE WITNESS: 1 can't comment on (14) that. (15) Q (By Mr. Taylor) Well, if you look at the language (16) on the last page above the AMSCO's Insignia, (17) saying: 'We can ship you plasticizers and other (18) chemicals promptly out of nearby stocks." (19) Do you see that? (20) A Oh, yes. (21) Q Did Monsanto have "nearby stocks'? (22) MR. HOPKINS: Object to the form. (23) Q (By Mr. Taylor) Or is that AMSCO writing that (24) message? (25) MR. ORR: Object to the form. (D distinction between the two? (2) A 1 think we use them Interchangeably. (3) Q Okay. You are aware of no distinctions between the (4) two phrases? (5) A No. (6) MR. HOPKINS: (7) to the form. Note my objection (8) Q (By Mr. Taylor) I'm going to show you what was (9) marked yesterday as Springate No. 4. It Is a (10) "Minutes of Arodor Ad Hoc Committee, first (11) meeting." (12) It bears Bates MAE 021976 through 021979. It (13) was marked in a deposition yesterday of James (14) Springate, Springate No. 4. (15) 1 ran out of copies of the thing. There is an (16) extra. (17) 1 had asked you earlier, Mr. Wright, if you (18) remember committees that were formed studying the (19) Arodor PCB issue. Do you remember that? - (20) A Yes. (21) Q When did you become aware that there were (22) allegations that the Arodor PCB products were (23) harmful to the environment? (24) MR. HOPKINS: Object to the form. (25) THE WITNESS: 1 don't recall. Page 96 Page 94 (1) THE WITNESS: 1 can't comment. (2) Q (By Mr. Taylor) Well, can you comment whether (3) Monsanto had stockyards of- or stock- for lack of (4) a better word- centers of products around the (5) country? (6) MR. HOPKINS: Object to the form. (7) THE WITNESS: Oh, yes. (8) Q (By Mr. Taylor) They did? (9) A Yes. (10) Q And; sir, does this refresh your recollection when (11) 1 asked you earlier if Monsanto and AMSCO published (12) joint sales materials? (13) MR. HOPKINS: Object to the form. (14) MR. ORR: Join that. (15) THE WITNESS: I'm not aware of (16) jointly publishing sales materials. (17) Q (By Mr. Taylor) Were you aware of- did AMSCO have (18) its Insignia and locations around the country at (19) the end of all of Monsanto's sales literature? (20) A No. No. (2.1) Q Do you remember that- do you remember it ever (22) appearing on Monsanto's sales literature; that (23) being AMSCO's insignia and locations? (24) A No. (25) Q If you can turn to the fourth page in, fifth page Page 97 (1) Q (By Mr. Taylor) Do you remember how you became (2) aware of that? (3) A No. (4) Q Was it on your own, through your own observations (5) of the media, or was it through the company? (6) A Had to be through the company. (7) Q And am 1 correct in remembering your testimony that (8) you were aware that there were committees within (9) the company studying the Issue and how the company (10) was going to respond to the allegations regarding (11) PCBs? (12) MR. HOPKINS: Object to the form. (13) THE WITNESS: 1 wasn't in the (14) loop. (15) Q (By Mr. Taylor) But were you aware? 1 understand (16) that you weren't in the loop, but were you aware (17) that those discussions were going on at some level (18) within the company? (19) MR. HOPKINS: Object to the form. (20) THE WITNESS: 1 don't recall. (21) Q (By Mr. Taylor) Well, between 1968 and 1972, when (22) you were the field sales manager, was there any (23) scuttlebutt or rumors going around among the sales (24) troops regarding the allegations being made in the (25) press about PCBs? - JULY 30, 1998 MAERTIN v ARMSTRONG Page 92 to Page 97 TOWOLDMONOQ51492 BSA JAMES D. WRIGHT XMAX(19/19) Page 104 (1) THE wrTNESS: Okay. (2) Q (By Mr. Taylor) Okay. Were you Involved at all In (3) assisting the salesmen on how to respond to (4) customers' questions relating to the PCB issue? (5) A No. (6) MR. HOPKINS: Object to the form. (7) Q (By Mr. Taylor) Do you remember this document? (8) A No. (9) Q Springate No. 12? No? (10) A No. (11) Q From looking at Ihe document, can you-do you know (12) who would have prepared this document? (13) MR. HOPKINS: Object to the form. (14) Go ahead. (15) THE WITNESS: It would have come (16) out of product group, obviously. (17) Q (By Mr. Taylor) Why do you say`obviously'? (18) A That Is their responsibility. (19) Q That would have been Cumming Paton, the group he (20) was in? (21) A Yes. (22) Q Was Walter Waychoff the product manager during the (23) time that you were field sales manager In St. Louis (24) for the plasticizer product? (25) A I don't recall, because he had different jobs, so Page 1.7: (1) Q (By Mr. Taylor) It you go down to Question 3 It (2) says: 'Does Monsanto intend to continue (3) manufacture of Arodor 1254/1260, et cetera?' (4) And the answer, suggested answer that Is given (5) under answer, under three, on the last page, Is: (6) 'I have been given no Indication otherwise.' (7) Do you see that? (B) A Yes. (9) Q Was that accurate? Is that an accurate statement (10) that the salesmen were not given any indication (i 1) that the Arodor containing PCBs may be pulled from (12) the market? (13) MR. HOPKINS: Object to the form. (14) THE WITNESS: I can't answer (15) that, because I don't know what the indications (16) are. (17) Q (By Mr. Taylor) What Indications? (IB) A But, you know, read It. Read It yourself, because (19) It simply says- that's the answer. That Is the (20) given answer at the time. (21) Q What is the given answer? That'I have been given (22) no indication otherwise.' (23) A Yeah. That's the answer. (24) Q I'm going to show you what was previously marked in' (25) the deposition of Edward John, as John No. 16. And Page 105 (1) did Cumming Paton, so did I. (2) Q I understand. (3) A We turned around quite a bit. (4) Q You remember Cumming Paton was the product guy, (5) correct? (6) A Or In the technical aspects of the product group. (7) Q From you looking at this, why are you so sure that (8) it came out of a product group? (9) MR. HOPKINS: Object to the form. (10) THE WITNESS: The product groups (11) were responsible for all of their products that (12) they handled in that particular assignment, and (13) therefore, that was the responsibility to handle (14) the communications and the product. (15) They saw that the product was, you know, (16) communicated with, and that Is their (17) responsibility. (18) Q (By Mr. Taylor) So this would not be questions (19) posed to the salesmen? (20) A What do you mean? (21) Q Well, it would be the product groups' (22) responsibility to field questions from customers, (23) as opposed to the salesmen? (24) A This appears to be a communication to the sales (25) people on how to answer the questions concerning (1) for the record, It's entitled 'Presentation to (2) Field Sales, Personal and Confidential.' It bears (3) Bates MAE 033475 through 033484. (4) And it you could just take a moment, sir, and (5) review that. (6) A (Witness complies.) (7) MR. ORR: Are you going to mark (8) that? (9) MR. TAYLOR: 1 am not going to (10) mark this. It was marked as John No. 16. (11) MR. HOPKINS: Off the record. (12) (Discussion off the record.) (13) (14) THE WITNESS: Okay. (15) Q (By Mr. Taylor) Do you remember this document, (16) sir? (1?) A No. (18) Q Is this document also something that would likely (19) to have been prepared by the product group? - (20) MR. HOPKINS: Object to the form. (21) THE WITNESS: Yes. (22) Q (By Mr. Taylor) Yes? (23) A Yes. (24) Q Turn to the second page. (25) A (Witness complies.) Page 108 (1) Aroclors. (2) Q So It would be- (3) A During this period of time. (4) Q It would be the product groups' advise to the sales (5) force? (6) A Yes. (7) Q And as field sales manager, you would not have- 18) would you have gotten, likely to get a copy of (9) this? (10) A I would Imagine so. (11) Q You just don't remember this document- (12) A No. ' (13) Q - sittinghere today? (14) A No. (15) Q If you can turn to Page 11 of the document, the (16) last two pages of the document. (17) A (Witness complies.) (18) Q You will see under 'Applications." Question No. 1, (19) the sample question Is: 'Could Arodor 1254/1260 (20) escape from my sealant/adhesive/coating whatever (21) into the environment?*1 11 (22) Do you remember that being an issue that you (23) dealt with? (24) A No. (25) MR. HOPKINS: Object to the form. Page 106 (1) Q I'm sorry. Go to the third page of the document. (2) A (Witness compiles.) (3) Q It says- referring to a letter, the second page, (4) last paragraph. It says: This letter goes to (5) plasticizer customers only.' (6) Do you remember letters sent to the customers (7) advising them of the PCB situation? (8) MR. HOPKINS: Object to the form. (9) THE WITNESS: 1 don't remember. (10) Q (By Mr. Taylor) Do you remember that happening, 01) generally, that the customers were advised that (12) there was issues or allegations concerning PCB (13) products? (14) A Generally, yes. (15) Q Well, on Page 3 of this document, it says: 'A copy (16) of this letter, together with a cover letter, will (17) be mailed to the head office of each of our Arodor (18) distributors.' (19) Do you see that? (20) A Yes. (21) Q Do you remember that happening? (22) A It was done. It was done by the product group. (23) Q Were you involved at all in that letter sent to ihe (24) distributors? (25) MR. HOPKINS: Object to the form. Page 109 - JULY 30, 1998 MAERTIN v ARMSTRONG Page 104 to Page 109 TOWOLDMONOQ51493 BSA (1) ensure better control of end uses.' (2) A Uh-huh. (Witness answers affirmatively.) (3) Q Do you &ee that? (4) A Uh-huh. (Witness answers affirmatively.) (5) Q Do you remember that taking place, that all sales (6) ceased through distributors? (7) MR. HOPKINS: Object to the form. (8) Q (By Mr. Taylor) Do you remember that? That is all (9) the question Is. (10) A I don't recall. (11) Q You donl recall that sales of the Aroclor (12) containing PCBs were terminated through (13) distributors? (14) MR. HOPKINS: Object to the form. (15) You can answer. (16) THE WITNESS: I don't recall the (17) time or date or when or If. (18) Q (By Mr. Taylor) Well, It says: `We are (19) terminating all sales to distributors to erisure (20) better control of end uses.' (21) Do you remember there being a concern that (22) there was a lack of control of end uses through (23) sales through distributors? (24) MR. HOPKINS: Object to the form. (25) THE WITNESS: I don't recall. JAMES D. WRIGHT XMAX(21/21) Page 116 (1) Q Do you remember that as an Issue? (2) MR. HOPKINS: Object to the form. (3) THE WITNESS: This Is a product (4) management responsibility to determine how they are (5) going to market their product. (6) Q (By Mr. Taylor) I'm asking you, at the time as a (7) field sales manager in the plastidzer- Involved (8) with plasticizer products, at this time of this (9) memorandum, whether you remember the Issue that (10) none of the applications of the plasticizers were (11) considered controllable? (12) MR. HOPKINS: Object to the form. (13) THE WITNESS: I donl recall. (14) Q (By Mr. Taylor) Do you remember the control at (15) all? (16) MR. HOPKINS: Object to the form. (17) Q (By Mr. Taylor) In relation to plasticizers? (18) A No. (19) Q Turn to the second page, under the'Plan of (20) Action." It says: '1. Contact AMSCO and Central (21) Solvents central offices to inform them of our (22) plans.' (23) It says: 'This was completed in early May on (24) a confidential basis.' Do you remember that being (25) done in early May of 1970? Page 1 (1) Q (By Mr. Taylor) You don't recall that issue coming (2) up? (3) A No. (4) Q No? (5) A No. (6) MR. HOPKINS: Can I just ask (7) Mr. Wright if he wants to take a break? (8) MR. TAYLOR: Sure. 0) MR. HOPKINS: We don't have to. (10) It is up to you. (11) THE WITNESS: Let's continue for (12) another half hour. (13) MR. TAYLOR: Okay. Fine I want (14) to mark this as No. 8. (15) (Exhibit No. 8 marked for (16) Identification.) (17) (18) Q (By Mr. Taylor) I ask you, sir, to review this (19) document, which is a May 14, 1970, memorandum from (20) Willis Clark, to a host of individuals, on which (21) you were copied. (22) It's entitled 'Confidential.1* 1i1t11be*ars Bates (23) MAE 060748 through 750. Just let me know when you (24) have finished reviewing it. and you are ready to (25) proceed. Page 117 Page 120 (i) A I don't remember any specifics. . (2) Q Do you remember that It was done on a `confidential (3) basis'? (4) MR. HOPKINS: Object to the form. (5) THE WITNESS: The direction of (6) this memo is to the district managers who were (7) responsible for calling on the distributors and all (8) of their customers. (9) Q (By Mr. Taylor) I understand. If you look on the (10) right-hand side It shows that you were copied. (11) A That's right. I was copied, along with others. (12) Q And I believe your testimony was that It was (13) likely that you would have been involved in (14) contacting the distributors regarding the (15) withdrawal of the PCB plasticizers from the (16) market? (17) A Yes. (18) Q And I'm asking if this reference here refreshes (19) your recollection regarding your contacting AMSCO " (20) or Central Solvents? (21) A We had-the regional managers had direct contact (22) with Central Solvents and AMSCO at their (23) headquarters, as well as I, from an overview (24) standpoint. So I'm sure that this was done. (25) Q That you would have been involved? Page 118 (1) A (Witness complies.) Okay. (2) Q Do you remember John Mason of Monsanto? (3) A No, I don't. (4) Q Do you remember the name? (5) A No. (6) Q It says, in the second paragraph, he is referring (7) to a presentation to the corporate management (8) committee. (9) Do you see that? (10) A Yes. (11) Q And It's referring to two b.aslc recommendations. (12) It says: 'And second, that we phase out all of the (13) nonblodegradable PCB products where control Is not (14) possible and replace these with materials with (15) biodegradable PCBs or other suitable products.' (16) A Uh-huh. (Witness answers affirmatively.) (17) Q And It says: The Corporate Management Committee (18) approved these recommendations.' (19) Do you see that? (20) A Uh-huh, (Witness answers affirmatively.) (21) Q The second paragraph, third paragraph: 'In the (22) plasticizer area, none of our applications are (23) considered to be of a controllable nature.' (24) Do you see that? (25) A Uh-huh. (Witness answers affirmatively.) Page 121 (1) A I would have been Involved at some point. (2) Q The last sentence of point one says: The regional (3) offices should not have been contacted by the (4) central offices.' . (5) Do you know what that means? (6) MR. HOPKINS: Object to the form. (7) THE WITNESS: I don't know what (8) that means. (9) Q (By Mr. Taylor) It says, No. 5: 'Contact all (10) distributors and inform them In writing of our (11) decision to remove these products from the market (12) and to stop all shipments on 8/30/70.' (13) Do you see that? (14) A Uh-huh. (Witness answers affirmatively.) (15) Q Did all shipments stop on 8/30/70? (16) MR. HOPKINS: Object to the form. (17) THE WITNESS: I don't know. (18) Q (By Mr. Taylor) Were you aware of AMSCO requesting (19) shipments of Aroclor 1254 after August 30, of 1970? (20) A No. (21) Q If they had, would product be shipped to them? (22) MR. HOPKINS: Object to the form. (23) THE WITNESS: I don't know. I (24) doubt it. . (25) Q (By Mr. Taylor) Why do you doubt it? - JULY 30, 1998 MAERTIN v ARMSTRONG Page 116 to Page 121 TOWOLDMONOQ51494 BSA JAMES D. WRIGHT XMAX(23/23) Page 128 (1) again. (2) Q (By Mr. Taylor) Was there any restriction ot (3) AMSCO- AMSCO's ability to call on customers that (4) were already direct customers of Monsanto? (5) A No. They could call on any customer they wanted, (6) and It's a matter ot who could service them the (7) best. (8) They were primarily Interested In handling our (9) drum accounts and to service the drum Industry, (10) which is distinctly different from the bulk (11) Industry. (12) Q It says here under No. 4 that'Monsanto does not (13) expect to solicit small order business for the (14) product line in the area.' (15) Is that what you mean, drum quantities? (16) A Drum accounts. (17) MR. HOPKINS: Note my objection (IB) to the question. (19) Q (By Mr. Taylor) It goes on: 'but dxpects to refer (20) some inquiries to distributor.' (21) When It says 'refer to distributor,' was it (22) the practice of Monsanto, H it got an order for (23) say a drum quantities of Arodor, not to fill that (24) order, but to give it to AMSCO or another (25) distributor? Page 131 (1) MR. HOPKINS: It's my (2) understanding the redaction log and the privilege (3) log are going to be produced. (4) It is my understanding there were other (5) products that are listed- that are listed there (6) that were redacted. (7) MR. TAYLOR: Do you know the (8) reason why they were redacted? (9) MR. HOPKINS: I think the basis (10) for the redaction- and this Is going to be (11) reflected In the redaction log- is that those (12) products are not at issue in this case. (13) And that is by no means an admission that (14) Santicizer 160 or 141 are at issue in this case, (15) but they have been asked about previously, and the (16) Court has instructed us to produce information (17) about that, therefore, they were Identified. (18) MR. TAYLOR: I object to, (19) obviously, the deletion. We will call and ask for (20) a totally unredacted version of this document, but (21) we can talk about that later. (22) Q (By Mr. Taylor) Did Monsanto have the right to (23) reject any requested tor product made by AMSCO. (24) A Products made by AMSCO? (25) Q No. Products requested by AMSCO; could they reject ' Page 129 (1) A If the customer would agree to that, then we would (2) refer It to AMSCO. (3) Q Do you remember-I'm sorry. Are you finished? (4) A Go ahead. (5) Q Do you remember if Monsanto referred to AMSCO (6) Armstrong Cork's business? (7) A .1 don't have any knowledge of that. (8) Q On the term, you will see where it says: 'One (9) year, commencing January 1,1962.' And then it (10) says in asterisks Term of contract: See Exhibit (11) A. Paragraph 24." (12) ff you could turn to Exhibit A, Paragraph 24, (13) and Just read that for a moment to yourself. (14) A (Witness compiles.)Go ahead. (15) Q Do you remember any amendment to this provision, (16) the term provision, between the contract between (17) AMSCO and Monsanto? (18) MR. HOPKINS: Object. You can (19) answer. (20) THE WITNESS: I don't remember (21) any amendment. It was a very good contract, and we (22) found AMSCO to be an outstanding distributor. (23) Q (By Mr. Taylor) Exhibit B, contained the price (24) list, correct? (25) A Yes. (i) an order for any reason? ` Page 132 . (2) A No. We had our product line available to them, and (3) it was a matter ot what their market had an (4) Interest In, In plasticizers. We are talking about (5) plasticizers. (6) Q That's right. (7) MR. HOPKINS: Off the record. (8) (Discussion off the record.) (9) (10) Q (By Mr. Taylor) Paragraph 22 of the attachment, I (i i) believe it's called Exhibit A of this document (12) A Right (13) Q Can you describe to me what-you can read it to (14) yourself- what is Involved here In connection with (15) bulk terminals and warehouses? (16) A Very simple. Shipping bulk plasticizer was very (17) expensive. Santicizer 160 was made on the west (18) coast and In St. Louis, and it's a matter of (19) utilizing the most efficient bulk facility. ~ (20) And from time to time If it was necessary, we (21) could pull on AMSCO's inventory to make bulk (22) shipments to customers. (23) I don't think that was a normal norm at all, (24) but at least it was there and where they maintained (25) bulk plasticizers, that was available. Page 130 (1) Q Was that modified or amended from time to time as (2) the years went on? (3) A Yes. (4) Q And were you involved in those, the changing of the (5) price list? (6) A No. (7) Q Who was that? (8) A Product group. (9) Q On Exhibit A, which is the third page in, in the (10) document, underneath- well, in the center of the (11) page beginning with 'In C/L or T/L of drums.' (12) What does that refer to? (13) A Carload of truckload of drums. (14) Q It says: 'Hereinafter referred to as 'proprietary (15) products.*1"1T1hat is in quotations 'proprietary (16) products.' (17) A Right. (18) Q Were there other-and maybe Counsel can answer (19) this, but is this the whole list that is shown in (20) this exhibit, or were certain products deleted from (21) this document? (22) MR. HOPKINS: I'll volunteer, If (23) I might, because I think Mr. Wright had no (24) involvement In the production of this document. (25) MR. TAYLOR: Okay. . Page 133 (1) Q Okay. Paragraph 23 talks about meetings (2) approximately twice a year between Monsanto and (3) AMSCO. (4) Can you discuss what those meetings were . (5) about? (6) MR. HOPKINS: Object to the form. (7) You can go ahead. (8) THE WITNESS: Generally, to my (9) recollection, generally, the meeting was a result (10) of the progress of where their sales were going; (11) how they were doing; how we were servicing their (12) account; how the regional managers and salesmen (13) were working with their salesmen, you know, (14) whatever. (15) Q (By Mr. Taylor) Are these the meetings that you (16) referred to earlier in your deposition that you (17) would go to their meetings and sometimes either (18) talk to the group or meet with them, with your . (19) technical people? (20) A Generally, this was with their executive group, and (21) also with their district managers. (22) Q The Paragraph 23 goes on and says: To insure that (23) Monsanto Is kept abreast of market conditions'- (24) A Yeah. (25) Q - 'of new uses.' Do you see that? - JULY 30,1998 MAERTIN v ARMSTRONG Page 128 to Page 133 TOWOLDMONOQ51495 BSA JAMES D. WRIGHT XMAX(25/25) (1) Is giving AMSCO names of accounts of which we were (2) servicing so that they could service them more (3) efficiently than we. (4) Q Okay. (5) A Okay. (6) Q Well, If you read- and I'm obviously reading this (7) wrong, but you tell me where l`m not dear here. (8) Under witness In the first page of Wright No. 10. (9) A Yeah. (10) Q The agency agreement. (11) A Yeah. (12) Q It says: "Prindpal hereby appoints agent.' The (13) 'prindpal' Is Monsanto, correct? (14) A Right. (15) Q And the `agent" Is AMSCO, correct? (16) A Right Right. (17) Q 'It's nonexduslve sales agent for the sale of its (18) proprietary plastldzers, namely:' and there Is (19) some named here. ' (20) A Yes. (21) Q It includes the Arodors. Do you see that? (22) A Yes. (23) Q 'In bulk to those of the accounts listed In Table 1 (24) attached hereto.' Do you see that? (25) A Yes. Page 140 Page 143 (1) A By the simple sale of a product to AMSCO. (2) Q Would that 5 percent commission also correspond (3) with this agency agreement, as well? (4) A Yes. It Is on the last page. (5) Q That's what I'm looking for. (6) MR. ORR: Top of Page 3. (7) MR. TAYLOR: I see it (8) Q (By Mr. Taylor) It says: 'Monsanto reserves the (9) right to solicit business in competition with (10) agent.' (11) What does that mean? (12) A Simply that. That we couldn't restrict them from (13) their calls and who they call on and they don't (14) restrict us. That is against the law. (15) Q So that there may be a customer on the list which (16) you gave them- . (17) A Yes. (18) Q - that they were allowed to ship these bulk . (19) shipments to- (20) A Yes. (21) Q - but that you could also sell that same customer (22) a bulk shipment? (23) A Yeah. Sure. If he wanted to buy from us. (24) Q Now, who was on this exhibit list; do you remember? ~ (25) A Who? What do you mean? Page 141 (1) Q Am I missing something, as far as whether they were (2) selling drum accounts or larger quantities as In (3) tank cars or tank trucks? Do you see that? (4) A I see that. What are you saying? (5) Q I'm saying that pursuant to this agency agreement, (6) Monsanto was turning over certain accounts where (7) sales were going to be made in bulk? (8) A Yes. That's right. (9) Q Does that refresh your recollection? (10) A Yes, It does. (11) Q Your previous testimony was Inaccurate? (12) A Yes. (13) Q Okay. Why would Monsanto turn over bulk accounts (14) to AMSCO? (15) A They could service them better than we, In (16) relationship with mixed bulk shipments of solvents (17) and plasticizers, which was common in the Industry (18) at that time. (19) Q 'Mixed bulk?' (20) A Mixed bulk.. (21) Q Explain that to me. (22) A They would have departmental tank trucks that could (23) carry as much as four different products, several (24) different solvents, maybe two plasticizers, and (25) things of this nature, to make up a full tank (i) Q What types ol companies? (2) A I don't have the slightest Idea. (3) Q Well, I'm assuming that Exhibit A, Table 1, was not (4) blank at the time this contract was signed? (5) A Well, certainly. (6) Q Did you see an unredacted version of that? (7) A My signature Is on this. (8) Q The contract, but the exhibit. Did you see an (9) unredacted version of this document prior to your (10) deposition? (11) A What is the date? (12) MR. HOPKINS: I don't know if he (13) understands what you are asking. (14) THE WITNESS: Yeah. 1961. How (15) is that. (16) Q (By Mr. Taylor) That Is when you saw the (17) unredacted version? (18) A Yes. (19) MR. TAYLOR: They have been (20) redacted? (21) MR. HOPKINS: Yes. (22) MR. TAYLOR: On what basis? (23) MR. HOPKINS: The customer names. (24) It is proprietary. We have a continuing objection (25) to providing customer names, and it has been Page 144 Page 142 (1) truck, which then gives the customer the (2) opportunity to purchase at the lowest bulk price? (3) Q Okay. (4) A Something that we could not participate In because (5) we only had plasticizers; whereas, AMSCO then with (6) their big list of solvents, which are generally (7) used together with plasticizers In the Industries, (8) then could service the account. (9) Q I'm not- okay. That Is the answer to my question (10) of why they did that, because AMSCO could do it (11) more efficiently? (12) A Yes. . (13) Q And AMSCO was responsible for arranging for these (14) carloads which could segregate the product in say, (15) four? (16) A Yes. Yes. Sure. (17) Q But AMSCO, I'm sorry. Monsanto typically would (18) send truckloads all of one product in a big tanker (19) truck? (20) A That's right. One of the real advantages of having (21) a distributor that had a product line that (22) complimented ours. (23) Q And what was the- how was Monsanto compensated on (24) these type of transactions, which are governed by (25) the agency agreement? (1) ongoing and it Is not relevant either. (2) MR. TAYLOR: Obviously, relevancy (3) is not a proper objection. (4) MR. HOPKINS: The Court has (5) allowed you to redact numberous lab notebooks for (6) relevancy purposes. (7) I don't see why we shouldn't be entitled to (8) the same right, especially with the proprietary (9) information. (10) That is a fight for another day, I suppose. (11) MR. TAYLOR: That is a fight for (12) another day. (13) But for the record, there are many documents (14) that have been produced that have the customers' (15) names on them, which were unredacted. So it has (16) been inconsistent. I'm just curious why In this (17) case? (18) MR. HOPKINS: I think it has been (19) consistent in this case. But there Is no point in (20) getting into the definition of distinction as to (21) what has been consistent and not. (22) MR. TAYLOR: Again, this is an (23) example, just for the record- and Mr. Hopkins Is (24) right, it is a fight for another day- of why we (25) are probably going to have to reconvene your Page 145 . - JULY 30, 1998 MAERTIN v ARMSTRONG Page 140 to Page 145 TOWOLDMONOQ51496 BSA id have the same agency agreement as AMSCO had with (2) Monsanto? (3) MR. HOPKINS: Object. (4) THE WITNESS: 1 don't recall. (5) MR. O'CONNOR: Excuse me. We are (6) going to sign off now. (7) MR. TAYLOR: Do you want to ask (8) any questions? (9) MR. O'CONNOR: No questions. (10) (Mr. O'Connor hangs up.) (11) (12) MR. TAYLOR: Would you mark that (13) as the next exhibit. (14) (Exhibit No. 14 marked tor (15) identification.) (16) (17) Q (By Mr. Taylor) Mr. Wright, you are looking at (IB) what has been maked as Wright No. 14. It Is an (19) August 14, 1970, letter from Walter Sdialk. It (20) bears Bates MAE 060487, and it has attached to it (21) 'General Policy Concerning Distributors' Return of (22) Arodors.1 (23) And 1 just ask you just to take a look at this (54) document, and there is a third page- is there a (25) third? That Is a mistake. JAMES D. WRIGHT Page 152 (D questions on all four. (2) They bear Bates MAE 060614 through 617. Just (3) take a look for a minute at these documents. (4) A (Witness complies.) Okay. (5) MR. HOPKINS: Counsel, the (6) documents that we had, were all separate. They (7) weren't stapled together. (8) MR. TAYLOR: 1 could be mistaken, (9) but 1 thought they were stapled together. (10) MR. HOPKINS: They weren't (11) intended to be. If the copies we gave you were (12) stabled together, then that must have been a (13) copying error, because they are four Individual (14) documents as they were reflected In our original (15) production form. (16) Q (By Mr.- Taylor) Well, I'm not going to ask you (17) questions on the first page. Tum to the second (18) page where there is some handwritten notes. And is (19) that your handwriting? (20) A No. (21) Q It says at the top: Mr. Nell Gronon, AMSCO, (22) Plainfield, New Jersey. Do you recognize that (23) name? That may be an 'A.' It may be Aronon, (24) A No. (25) Q Do you recognize that name? xmax(27/27) Page 15;. - Page 153 (1) A (Witness complies.) Okay. (2) Q Do you remember this issue on the return goods (3) policy? (4) MR. HOPKINS: Object to the form. (5) Q (By Mr. Taylor) Return of product policy? (6) A The policy was established by Walter Schalk and the (7) produpt group. (8) Q Do you remember it? (9) A Yes. (10) Q And the second paragraph, the first page, it says: (11) The same two-month extension will apply to our (12) distributors.' (13) Can you explain to me why there was an (14) extension given to the customers and the (15) distributors on the return of product? (16) MR. HOPKINS: Object. You can go (17) ahead. (18) THE WITNESS: 1 can't tell you (19) why. 1 don't know. (20) Q (By Mr. Taylor) Do you remember that happening? (21) A Again, it Is the policy of the plasticizer group. (22) Q Do you remember what the policy was? (23) A It says it right here. (24) Q Without just- okay. (25) Well, do you remember whether the distributors Page 156 (1) A No. (2) Q It looks to me, unless Counsel has another (3) interpretation to be A-r- (4) MR. HOPKINS: It could be o-n-a-n (5) or o-n-o-n. (6) MR. TAYLOR: Right. (7) MR. HOPKINS: That Is how 1 see (8) it. (9) Q (By Mr. Taylor) Do you remember an AMSCO outlet in (10) Plainfield, New Jersey? (11) A Plainfield Is south, In the southern part of New (12) Jersey? (13) Q That's right. (14) A 1 don't recall. (15) Q It says a little bit lower, 'Stop off American (16) Mineral Spirits Co. 350 Roosevelt,' and is that- (17) MR. HOPKINS: Carteret. (18) Q (By Mr. Taylor) - 'Carteret, New Jersey.' (19) Do you remember that outlet, or that AMSCO - (20) location? (21) A 1 think that was their warehouse or bulk station. (22) 1 don't know what this pertains to. (23) Q Okay. II you turn to the last page, Mr. Wright, it (24) looks like a memorandum type form, bears Bates MAE (25) 060617. And it looks like a message to you from (1) asked for a continuance of the policy for two (2) month's? (3) MR. HOPKINS: Object to the form. (4) You can answer. (5) THE WITNESS: 1 think it's clear (6) in the second paragraph as to what was the policy (7) and relating to direct customers as well as (8) distributors. (9) Q (By Mr. Taylor) The second paragraph of what? (10) A Of the first page. They Involved a two-month (11) extension for the customers, and a two-month (12) extension for the distributors. (13) Q My question is: Do you know why there was a (14) two-month extension granted? (15) A No. (16) MR. TAYLOR: Would you mark this, (17) please. (18) (Exhibit No. 15 marked for (19) identification.) (20) (21) Q (By Mr. Taylor) Before you, marked as Wright No. (22) 15, Is a four-page document. This is how it was (23) produced to us. (24) 1 don't know if there is- if they naturally (25) all belong together, but I'm going to ask you Page 154 Page 157 (D J.J. McNamara, Everett. (2) Do you see that? (3) A Yes. (4) Q That Is Everett, Massachusetts? . (5) A Yes. (6) Q And McNamara was a regional manager? (7) A Yes. (8) Q And it says: 'Each salesman will personally (9) contact their accounts during the week of 5/25' and (10) 1 can't read- oh-`to explain situation.' (11) And this memo refers to AMSCO. Do you see (12) that? (13) A Yes. (14) Q Do you remember that happening, that every salesman (15) contacted their AMSCO office In their area? (16) A It was the responsibility of each district manager (17) or regional manager, to see that the requirements (18) for notification were carried out by their (19) salesmen. (20) This was simply a confirmation to me that (21) AMSCO had been notified in the Everett area. (22) Q Do you remember that each, that, in fact, happened, (23) that each salesman- because this says: 'Each (24) salesman will personally contact.' (25) Do you remember that that happened, that each - JULY 30, 1998 MAERTIN v ARMSTRONG Page 152 to Page 157 TOWOLDMONOQ51497 BSA JAMES D. WRIGHT XMAX(29/29) Page 164 (1) MR. TAYLOR: Would you mark this (2) as the next exhibit. (3) (Exhibit No. 17 marked tor (4) Identification.) (5) (6) Q (By Mr. Taylor) Mr. Wright, you are looking at (7) Wright No. 17. It Is a Monsanto call report, dated (8) 6/23/70, to Willis Clark from J.R. Beightel. (9) A Yea. (10) Q II you could take a moment and review this (11) document (12) A (Witness complies.) (13) Q Do you remember- I'm sorry. Are youfinished? (14) A Go ahead. (15) Q Do you remember Fred Schroeder, regional manager of (16) AMSCO. Do you remember Fred Schroeder? (17) A It's been so long. I really 1 can't place him. (18) Q How about Jim Cally, C-a-l-l-y- (19) A No. . (20) Q -of AMSCO? (21) A No. (22) Q Do you see this was dated 6/20- (23) MR. TAYLOR: I'm sorry. I'm -(24) going to mark this. (25) III Page Id' (1) Q The gist of this was that this customer was looking (2) for a replacement for the Arodor 1262? (3) A That's right (4) Q And that they, you see that they purchased (5) approximately 60,000 pound of Arodor 1262 per year (6) through AMSCO? (7) A Yes. (8) Q Was that a large customer for AMSCO? (9) A I think that would be a good-sized customer for (10) AMSCO. (11) Q And It says: 'Samples are being rushed and this (12) customer will make a dedsion whether to stock up (13) additional inventory to cover their needs following (14) determination date of August 30.' (15) Do you see that? (16) A Yeah. (17) Q Was It Monsanto's practice toallow the customer to (18) make the dedsion whether they wanted to stock up (19) on inventory to cover their needs following the (20) termination date of August 30? (21) MR. HOPKINS: I'll object. You (22) can answer. . (23) THE WITNESS: I don't understand (24) that statement - (25) Q (By Mr. Taylor) What don't you understand about ' Page 165 (1) (Exhibit No. 18 marked for (2) identification.) (3) (4) Q (By Mr. Taylor) Wright No. 18, sir, is a Monsanto (5) call report, dated 6- well, there is a question (6) mark for the date of call. (7) But on the date received it says, 6/26/70, to (8) Willis Clark from Beightel. And it says: 'Joint (9) call with Jim Cally, AMSCO.' (10) And my question is: Do you remember the name (11) Jim Cally from AMSCO? (12) A No. (13) Q Do you seeunder'Objective'where it says (14) "discussed PCB discontinuation'? (15) A Yes. (16) QWas that a usual- was It the practice that a (17) member of the sales force of Monsanto would (18) accompany an AMSCO salesman to advise the AMSCO (19) customer of the discontinuation? (20) A No question about It, wherever there was a need, (21) that was the support we were trying to give to our (22) distributor. (23) This was a highly emotional thing In the (24) Industry. There were few replacement products for (25) the Aroclors. Page 16i (i) that? .(2) A I don't understand the "cover their needs following (3) the determination date of August the 30th." (4) Q Do you think that is a typo? Would you agree with (5) me that that is probably a typo, and it means (6) termination date, not determination date? (7) MR. HOPKINS: I'll object, but (B) you can answer. (9) THE WITNESS: I cant comment on (10) this. It's out of my-you know, I just don't (11) understand what he is trying to say. (12) Q (By Mr. Taylor) Do you remember a salesman from (13) AMSCO by the name of Nelson Bock, B-o-c-k? (14) A No. (15) Q And do you remember asalesman for Monsanto named (16) E.G. McCabe? (17) A Yes. (18) QOut of the Wilmington Service Center? (19) A Yes. _ (20) MR, TAYLOR: I'm not going to (21) repeat It, Mr. Orr, but I'm going to request that (22) all of these gentlemen that I'm naming from AMSCO, (23) if they are identifiable, and for purposes of (24) taking their depositions. These are documents (25) which we have not seen before. Page 166 (1) MR. TAYLOR: I'm going to mark (2) the next document. (3) (Exhibit No. 19 marked for (4) Identification.) (5) (6) Q (By Mr. Taylor) Wright No. 19, sir, that Is being (7) shown, Is a Monsanto call report, dated 7/1/70. (8) And do you remember a salesman, J.H. Gannon? (9) A Yes, (10) Q In the northeast region? (11) A Right. (12) Q You see the purpose of the call, it says: 'Joint (13) call with AMSCO salesman to discuss replacement of (14) Arodor"? (15) A Yes. (16) Q Was Arodor 1262 a PCB-containing Arodor? (17) A Yes. (18) Q Who received these call reports? (19) A The district manager and product group. (20) Q Would you ever receive copies of these? (21) A Not necessary. (22) Q Unless It was spedfidy- as a matter of course? (23) A No. (24) Q Unless it was copied to you, shown on the document? (25) A Yes. (1) Just for the record, Mr. Bock is referred to , (2) on a call report, dated 7/27, 1970, bearing Bates (3) MAE 060630. (4) MR, ORR; I suppose I should say . (5) for the record, my silence is not acquisition- 16) MR. HOPKINS: Acquiescent? (7) MR. ORR: Acquiescent rather, to (8) this request. I'm not sure- I understand you (9) just saw the documents, but I'm not sure of the (10) status of requests for previous witnesses. So you (i i) will send me a letter anyway, and we will take it (12) from there. (13) MR. TAYLOR: Correct. I (14) appreciate that. (15) Would you mark the next document, which Is a (16) document I just Identified, the 7/27 call report. (17) MR. HOPKINS: 21? (18) MR. TAYLOR: 7/27/70, (19) MR. HOPKINS: I mean, the exhibit (20) number. (21) (Exhibit No. 20 marked for (22) Identification.) (23) (24) Q (By Mr. Taylor) Sir, have you reviewed that? (25) A Yes. Page 169 JULY 30, 1998 MAERTIN v ARMSTRONG Page 164 to Page 169 TOWOLDMONOQ51498 bsa______ JAMES D. WRIGHTxmax(31/31) Page 176 (1) court reporter to note the date. 1 think you might (2) have misspoken, it is December 15, '67. (3) MR. TAYLOR: What did 1 say? (4) MR. HOPKINS: 1 think you might (5) have said '64. (6) MR. TAYLOR: I'm sorry. 1967. (7) Q (By Mr. Taylor) Do you recognize that name from (8) American Mineral Spirits Company? (9) A No. (10) Q How about Elmer Wheeler? (11) A Yes. (12) Q Who Is he? (13) A Manager Environmental Health Medical Department. (14) Q Did you, as part of your duties at any time at (15) Monsanto, did you have dealings with Mr. Wheeler? (16) A Very possibly. (17) Q Do you remember any offhand? (18) A No. (19) Q Why do you say "very possibly"? (20) A After all, he was on the staff and always available (21) for any comments or questions. (22) (Exhibit No. 25 marked for (23) identification.) (24) (25) Q (By Mr. Taylor) Sir, before you is Wright No. 25, Page 17; id EXAMINATION (Continuing) (2) BY MR. TAYLOR: (3) Q Before you is Wright No. 26, which is a February (4) 10, 1971, letter to Mr. George Nietzel, American (5) Mineral Spirits Company, Cranford, New Jersey, from (6) James Belghtel, Sales Representative, Organic (7) Chemicals Division. (8) Do you remember a George Nietzel(9) A No. (10) Q - From AMSCO? (11) A No. (12) Q From the Cranford, New Jersey office? (13) A No. (14) Q Do you remember the Cranford, New Jersey office? (15) A This is the one down In the southern part of (16) Jersey, or not, or the central part? (17) MR. ORR: Central. (18) MR. TAYLOR: I'm not sure. (19) MR. HOPKINS: It Is central. (20) THE WITNESS: Central. (21) Q (By Mr. Taylor) That name doesn't ring a bell? (22) A No. Are we through with that? (23) Q Yes, we are. (24) MR. TAYLOR: Sir, 1 think that is (25) all 1 have. I'm going to turn It over to Mr. Orr. Page 177 (1) is a document, "Product Classification Chart." It (2) bears Bates MAE 060727. (3) Can you Identified this document? (4) A No. (5) Q Have you ever seen this type of document before? (6) A No. (7) Q Can you tell from what- well, is this a Monsanto (8) document? (9) MR. HOPKINS: Object. You can (10) answer. (11) THE WITNESS: 1 don't know. (12) Q (By Mr. Taylor) It says "American Mineral Spirits (13) Company" in the top left-hand comer; does it not? (14) Do you see that? (15) A Yes. (16) Q And there are some columns on the document: (17) "Irritant." Do you see that? "Carcinogen." Do (18) you see there on the left? (19) A Yes. (20) Q Do you know if AMSCO had its own in-house research (21) staff? (22) A I'm not aware of their organization at that level. (23) Q How about its own medical staff? (24) A I'm not aware of that. (25) Q It says down at the bottom towards the left MCA and (1) I'm going to check my notes. 1 may have a couple (2) of follow-up, but I'll let you know. (3) MR. ORR: 1 don't have a whole (4) lot ol questions, but usually, when lawyers say (5) that that means they will be awhile, but I'll try (6) to be faithful here. (7) (8) (9) EXAMINATION (10) BY MR. ORR: (11) Q 1 notice on your card Mr. Wright, Mar(12) A Mar Rep. (13) Q What Is that? (14) A Mar Rep. (15) Q Mar Rep Associates. What is the nature of that (16) business? (17) A Marketing representative, but that's not- It is an (18) old card. (19) Q Old card. Okay. You are out of that business? (20) A Yeah. (21) Q In your various positions over the years with (22) Monsanto, did you become familiar with a way in (23) which smaller quantities; that is, in barrels, were (24) shipped from Monsanto to their various (25) distributors? Page 180 0) LAB 1 Guide label slates. Do you know what that (2) refers to? (3) A No. (4) MR. HOPKINS: It could also be (5) LAPI; couldn't It? (6) MR. TAYLOR: It could be LAPI. (7) It could be that. 1 thought it was LAB, but 1 may (8) be wrong. There Is a line going right through the (9) end of that letter, which is either a B or a P, 1 (10) think. Cl) MR. ORR: 1 don't want to get (12) into this, but it could be an F, in any event. (13) MR. TAYLOR: It could be. That's (14) right. (15) THE WITNESS: Can we get a break? (16) MR. TAYLOR: Sure. Let's take (17) five, and 1 am going to be finished in about 20 (18) minutes. (19) (Recess.) (20) (21) MR. TAYLOR: We'll mark this. (22) (Exhibit No. 26 marked for (23) identification.) (24) /// (25) m Page 178 Page 181 (1) A Yes. (2) Q Were the barrels labeled in any way? (3) A Oh, yes. Certainly. (4) Q Had Monsanto's name on the barrel, as well as on . (5) some kind of paper- (6) A Yes. (7) Q - labeling on it? (8) A Yes. (9) Q Okay. Did you understand the manner in which AMSCO (10) would then resell the Monsanto product? In other (11) words, did they repackage it? Did they sell it the (12) way they got It, or did they do something else with (13) it? (14) A They would sell It the way they got K. Generally, (15) If we ship it In our barrels, they would simply (16) resell It as such. (17) Q Is that what you understood would take place when (18) you participated in negotiating the distributorship (19) agreement? (20) A Yes. (21) Q To your knowledge, over the years did AMSCO honor (22) that agreement, in that it would ship Monsanto (23) product Identifying it as a Monsanto product? (24) A Yes. (25) MR. ORR: 1 don't know If Counsel -' JULY 30,1998 MAERTIN v ARMSTRONG Page 176 to Page 181 TOWOLDMONOQ51499 BSA JAMES D. WRIGHT XMAX(33/33) Page 188 (D through a distributor? (2) A I don't know. (3) Q Matter of fact, do you know whether that other(") what was that other company? (5) MR. HOPKINS: Central Solvents. (6) Q (By Mr. Orr) Do you know whether that distributor (7) may have sold to Armstrong? (8) A I don't know. I don't have any record* of It. (9) Q Do you have any tact or basis to believe that AM SCO (10) sold Arodor 1254 after the notice of cancellation (11) to Armstrong? (12) A I have no reason- I have no understanding of that. (13) Q Wright 6, which Is the guide. (14) A Oh, ye*. (15) Q You were asked some questions about the fact that- (16) well, first of all, this document, does It appear (17) to you to be a Monsanto sales brochure? You know, (18) what I mean? (19) A Yes. This appears to me to be a Monsanto sales (20) brochure. (21) Q Do your know whether there was any arrangement (22) made with Monsanto to print American Mineral (23) Spirits on a Monsanto document, as It is on the (24) last page? (25) A I see this on the last page, and that- well, they (1) MR. HOPKINS: I Just have two (2) questions. (3) (4) (5) EXAMINATION (6) BY MR. HOPKINS: (7) Q Mr. Wright, there were a number of Monsanto (8) products that were sold through distributors, such (9) as, AMSCO? (10) A Uh-huh. (Witness answers affirmatively.) (11) Q That included the Santidzer products; Is that (12) right? (13) MR. TAYLOR: Objection. (14) THE WITNESS: Santidzer. (15) MR. TAYLOR: Objection to the (16) form. (17) Q (By Mr. Hopkins) The Santidzer products? (18) A Yes. (19) Q It also induded PCB-containing Arodor products? (20) A Yes. (21) MR. TAYLOR: Objection to the (22) torm. (23) Q (By Mr. Hopkins) In your experience at Monsanto (24) between'61, when.the distributorship agreement (25) went into affed with AMSCO, and 1970 when Page 19' ~ . Page 189 (1) represented us, and we backed them up, so that that (2) was a decision by their marketing department and (3) American Mineral Spirits to put that on. I have no (4) other comment concerning IL (5) Q Well, that sheet on the top has, would you agree (6) with me, appears to be a Monsanto sales sheet? (7) A Yes. (8) Q It has got the little Monsanto logo on the top? (9) A Sure. (10) Q What(11) A I think It was a particularly good brochure that (12) could be used as a sales tool by all of our (13) salesmen, Including American Mineral Spirits. (14) Q Do you have any recollection ol seeing a document (15) like this printed with the name of the other (16) distributor on It? (17) A I don't have any recollection. (18) Q Okay. Is this a document that you would have seen (19) in the ordinary course of one of your many (20) positions? (21) A I would assume so. (22) Q Do you ever recall any discussions with management (23) as to whether or not Monsanto would print up a (24) quantity of these documents naming its distributor, (25) as opposed to giving authority to the distributor Page 192 (1) PCB-containing Arodor products were withdrawn from . (2) the market, do you have any recollection as to what (3) percentage ol sales of all of the plastidzer (4) products, the PCB-containing Arodor products (5) represented? (6) MR. TAYLOR: Object to the form. (7) THE WITNESS: No. I have no (8) recollection of the percentage of sales. (9) Q (By Mr. Hopkins) Was it a significant- (10) A Of the Aroclor products. (11) Q Was it a significant percentage of all of the (12) plastidzer products or a smaller percentage? (13) MR. TAYLOR: Objection to the (14) form. (15) THE WITNESS: I thinkrelatively (16) probably small, but I can't- I would have to take (17) a look at the record here for 1970 for AMSCO as (18) indicative of that. We made millions of pounds of (19) plasticizer. - (20) Q (By Mr. Hopkins) You are referring to the record (21) that showed that for the year of 1970 there was (22) approximately 156,000 pounds of Arodor 1254 sold (23) to AMSCO? (24) A That's right. (25) Q Was AMSCO a distributor and also a customer with Page 190 (1) to print their name on a Monsanto document? (2) MR. TAYLOR: Objection to the . (3) form. (4) THE WITNESS: I can't comment on (5) that, primarily because I'm not- I'm not aware. (6) Q (By Mr. Orr) You just don't know? (7) A I think we were pretty- pretty- our objective was (8) to cooperate and assist our distributors in any (9) fashion that we could. (10) Q As it assisted sales and ft was cost-effective? (11) A Sure. (12) Q Do you ever remember working with a fellow named (13) Roy Sullivan? (14) A Yes. (15) Q He was at AMSCO? (16) A No. Monsanto. (17) Q I'm sorry. I'm sorry. Okay. (18) A Wilmington. (19) Q He was- that's right. You are right. You know, (20) did you work with a fellow named- I may have this (21) pronounced wrong, Greacan at AMSCO? (22) A I don't recall the name. (23) MR. ORR: Okay. Thanks. I have (24) nothing further. (25) MR. TAYLOR: I have nothing. (1) regard to Aroclor 1254; if you know? (2) A Only as a distributor lor our product. H they (3) were buying it tor their own use In some other (4) process, I wouldn't have any Idea. . (5) Q Do you know if they were a customer of other (6) Monsanto products? (7) A I don't believe so. (8) Q Okay. (9) MR. HOPKINS: I have no further (10) questions. (11) MR. TAYLOR: Thank you, (12) Mr. Wright. I appredate your time. (13) MR. HOPKINS: Thank You very much (14) for your time. (15) (Signature reserved.) (16) (Deposition concluded at (17) 4:00 p.m.) (18) (19) (20) (21) (22) (23) (24) (25) Page 193 _ JULY 30,1998 MAERTIN v ARMSTRONG Page 188 to Page 193 TOWOLDMONOQ51500 TOWOLDMONOQ51501 BSA Look-See Concordance Report unique Words: 2,149 TOTAL OCCURRENCES: 10,620 NOISE WORDS: 384 TOTAL WORDS IN FILE: 29,726 SINGLE FILE CONCORDANCE CASE SENSITIVE COVER PAGES = 5 INCLUDES ALL TEXT OCCURRENCES DATES ON INCLUDES PURE NUMBERS POSSESSIVE FORMS ON - DATES - 3/24/98 [1] 91:15 6/2/21 [1] 16:3 6/5/70 [1] 160:7 . 6/23/70 [1] 164:8 6/26/70 [1] 165:7 7/1/70 [1] 166:7 7/27/70 [1] 169:18 8/30/70 [3] 121:12, 15; 122:6 April [1] 45:7 April 3 [2) 100:4; 101:11 April 3,1970 [i] 99:18 April 20, 1970 [1] 115:4 August [1) 170:9 August, 1970 [i] 162:18 August 14, 1970 |1] 152:19 August 30 (3] 121:19; 167:14, 20 August the 30th [1] 168:3 December [1] 42:7 December, 1970 [3] 81:7, 15; 185:19 December 15 [1] 176:2 December 15, 1967 [1] 175:20 December of 1970 [2] 81:17; 185:16 February 10,1971 [1] 179:3 JULY 30, 1998 JAMES D. WRIGHT January [2] 22:19; 45:23 January 1,1962 [i] 129:9 January 10 [1] 170:25 January 10,1972 [1] 171:7 July, 1998 [2] 6:2; 194:8 July 9,1970 [1] 79:1 July 13, 1970 [1] 82:16 July of 1970 [1] 78:24 May [2] 22)19; 119:23 May 14, 1970 [1] 117:19 May 25, 1970 [1] 148:8 May of 1970 [1] 119:25 November 27, 1961 [1] 123:24 October [1] 42:1 October 6th, 1970 [1] 85:9 October 8 [1] 87:12 - 0- 0 [1] 99:21 000001 [1] 89:11 000523 [1] 77:2 000526 [2] 77:16; 88:17 000530 [3] 77:2; 84:16; 87:8 001073 [1] 73:18 021976 [1] 96:12 021979 [1] 96:12 033475 [1] 108:3 033483 [1] 112:17 033484 [1] 108:3 034803 [1] 103:20 034814 [1] 103:20 04081 [1] 100:21 040881 [1] 100:22 040934 [11 100:21 058638 [1] 114:23 058659 [1] 114:23 . 059457 [1] 92:3 059461 [1] 95:1 059464 [1] 92:4 060388 [1] 122:25 060391 [2] 723:3, 5 060392 [1] 135:17 060414 [1] 135:18 060445 [1] 147:5 060453 [1] 148:10 060487 [1] 152:20 060614 [1] 155:2 060617 [1] 156:25 060630 [1] 169:3 060723 [1] 173:15 060724 [1] 174:17 060727 [1] 177:2 060748 [1] 117:23 .063391 [1] 122:25 06455 [1] 150:21 -1 - 1 [9] 17:12, 16; 90:19; 106:18; 119:20; 129:9; 140:23; 144:3; 178:1 10 (12) 16:16; 49:18; 70:23; 114:22; 135:9, 16, 25; 139:19; 140:8; 170:25; 171:7; 179:4 10/8(1] 87:9 10:00 [1] 9:19 11 [5] 48:12; 99:18; 106:15; 147:1, 4 11,400 [1] 89:22 113 [1] 114:6 12 [10] 16:16; 17:5; 55:21; 56:1; 62:19; 103:18; 104:9; 148:3, 4, 8 1248 [3] 173:15; 174:20; 175:8 1254 (16) 78:21; 81:1, 18; 82:6; 85:13; 88:3; 89:16, 22; 91:7; 121:19; 174:22; 175:11; 186:5; 188:10; 192:22; 193:1 1254/1260 [2] MAERTIN v ARMSTRONG Look-See 106:19; 107:3 1262 [3] 166:16; 167:2, 5 12:00 [1) 90:11 13 [4] 82:16; 150:17, 18, 21 137 [1] 137:11 14(6] 62:19; 114:7; 117:19; 152:14, 18, 19 141 [1] 131:14 15 [6] 70:23; 114:7; 154:18, 22; 175:20; 176:2 156,000 [2] 185:17; 192:22 156,600 (3] 81:18; 185:25; 186:6 16(5] - 107:25; 108:10; 160:1, 2, 5 160 [4] 76:6; 131:14; 132:17; 186:18 17 [2) 164:3, 7 18 [4] 16:1; 67:4; 165:1, 4 19(3] 19:4; 166:3, 6 1945 [1] 19:17 1947 [3] 18:18; 19:25; 20:1 1948 [2] 21:13, 24 1949 [1) 22:19 1950s [1] 24:5 1952(5] ' 24:9, 10, 16; 25:9, 15 1954 [3] 73:17; 76:25; 89:10 1958 [1] 25:9 1961 [11] 26:14, 16; 28:7; 30:2; 33:15, 19, 25; 35:11; 56:20; 123:24; 144:14 1962 [1] 129:9 1964 [2] 42:20; 43:19 1967 [2] 175:20; 176:6 1968 [15] 42:20; 43:3, 19; 45:4,12; 46:13; 47:2; 49:5; 51:7; 52:21; 68:15; 69:13; 89:12, 19; 97:21 1970 [25] 16:8; 78:3, 4, 25; 79:1; 81:7, 15, 17; 82:16; 85:9; 99:19; 115:4; 117:19; 119:25; 121:19; 148:8; 152:19; 162:18; 169:2; 185:17, 19; 186:5; 191:25; 192:17, 21 1971 [1] 179:4 . 1972 [13] - From 3/24/98 to 197k TOWOLDMONOQ51502 BSA________________________________ advertising [3] 127:5, 8, 12 advice [3] 149:17, 24 advise [2] 106:4; 165:18 advised [5] 72:12, 15; 73:2; 88:20; 109:11 advising [1] 109:7 affect [i] 191:25 affirmatively [20] 89:14, 18, 21; 92:25; 93:3, 5; 110:7; 115:23; 116:2, 4; 118:16, 20, 25; 121:14; 127:7; 149:8; 161:20, 25; 162:3; 191:10 affixed [1] 194:19 afterwards (1) '64:14 age [2] 150:10, 12 agencies [3] 102:15, 20; 103:1 Agency [2] 135:17, 24 agency [17] 137:6, 19; 138:4, 23; 139:9, 18, 25; 140:10; 141:5; 142:25; 143:3; 146:9, 11; 152:1; 187:7, 11, 14 agent [6] 138:8, 22; 140:12, 15, 17; 143:10 agree [4] 83:2; 129:1; 168:4; 189:5 agreed [1] 7:8 Agreement [1] 135:17 agreement [31] 31:24; 38:11, 21; 41:6, 14; 44:1; 56:22; 67:25; 135:24; 137:7, 20; 138:4, 23; 139:9, 18; 140:10; 141:5; 142:25; 143:3; 146:9, 11; 151:19; 152:1; 181:19, 22; 182:1, 6; 187:8, 11, 14; 191:24 agreements [2] 182:12, 18 AI-15 [1] 173:18 Air [2] 18:23; 19:1 al[l] 12:5 alert [1] 111:17 alive [3] 136:23; 137:1; 150:5 allegations [5] 96:22; 97:10, 24; 98:9; 109:12 allow [1] 167:17 Allowance [1] 125:16 allowed [3] 86:17; 143:18; 145:5 Altoona [2] JAMES D. WRIGHT 25:4,5 - amended [1] 130:1 amendment [2] 129:15, 21 amendments [1] 124:4 American [23] 73:16; 78:10; 80:25; 81:19; 82:21; 93:4; 112:3; 136:6, 12; 148:9, IS; 156:15; 173:19, 21; 174:22; 175:22; 176:8; 177:12; 179:4; 186:5; 188:22; 189:3, 13 amount [1] 186:9 AMS.CO [176] 6:25; 8:3; 9:15; 31:9, 12; 37:7, 14, 18, 21, 25; 38:5, 8, 21; 40:1, 6, 13; 41:1, 5, 13; 44:2, 6, 10; 53:17; 54:6; 55:4; 56:22; 57:18, 21, 24; 58:6, 7, 9, 14; 60:5; 61:12; 64:10, 12, 16, 21; 65:5, 9, 12, 17, 18, 25; 66:4, 8; 67:8; 68:1, 3, 6; 74:2, 10; 75:9, 13, 17, 21, 23, 24; 76:25; 77:12; 78:16; 79:3; 80:12, 19, 21; 83:11, 12; 84:25; 85:1, 6; 86:8, 9, 11; 87:17; 93:23; 94:11, 17; 101:6, 17; 110:8, 24; 119:20; 120:19, 22; 121:18; 122:5; 123:20, 23; 124:5, 25; 125:2, 5; 126:25; 127:1; 128:3, 24; 129:2, 5, 17, 22; 131:23, 24, 25; 133:3; 134:20; 138:3, 5, 14; 140:1, 15; 141:14; 142:5, 10, 13, 17; 143:1; 146:8; 149:16, 23; 151:19; 152:1; 155:21; 156:9, 19; 157:11, IS, 21; 158:1, 12; 159:4, 9; 161:6, 12,21; 164:16,20; 165:9, 11, 18; 166:13; 167:6, 8, 10; 168:13, 22; 171:12, 20; 172:22; 173:1; 174:7; 177:20; 179:10; 181:9, 21; 182:7; 183:18; 184:9, 15, 19; 185:11; 186:14; 187:4, 10, 15; 188:9; 190:15, 21; 191:9, 25; 192:17, 23, 25 AMSCO's [20] 39:21; 66:14; 79:12, 18; 84:10; 85:4; 86:23; 92:23; 93:6, 16; 94:23; 124:22; 127:18; 128:3; 132:21; 138:21; 159:6, 11, 15; 172:19 AMSCOs [1] . 65:2 Analysis [1] 46:24 analysis [1] 46:24 Analytical [1] 173:17 Anderson [2] 14:14, 15 announced [1] 162:4 annual [1] 65:25 Answer [3] 64:1; 67:3; 90:17 answer [63] 13:6, 15; 23:22; 34:7; 35:1; 38:14, 17; 40:17; 48:8; 49:12; 51:3, 12; 60:2; 62:23; 63:13, 21; 64:19; 66:11; 67:2; 70:17; 71:8; 72:7, 18; 82:24; 83:15; 90:15; 92:15; 95:7; 98:2, 12; 99:3; 105:25; 107:4, 5, 14, 19, . 20,21,23; 110:1; 114:2; 116:15; 122:13; 127:24; 129:19; 130:18; 134:6; 137:9, 22; 142:9; 151:11, 21; 154:4; 158:4, 15, 19; 162:13; 163:12; 167:22; 168:8; 170:16; 177:10 answered [2] 22:2 Answers [1] 48:10 answers [24] 12:23; 89:14, 18, 21; 92:25; 93:3, 5; 110:7; 115:23; 116:2, 4; 118:16, 20, 25; 121:14; 127:7; 149:8; 161:4, 20, 25; 162:3; 175:3; 191:10; 194:10 anticipate [1] 13:1 Anybody [1] 11:3 anybody [2] 18:5, 7 anyway [1] 169:11 anywhere [3] 31:17; 79:2; 88:14 apologize [2] 77:3; 114:20 apparently [2] 14:5; 147:11 appear [2] 102:23; 188:16 appearance [1] 36:14 appeared [1] 6:5 appearing [1] 94:22 appears [9] 83:17; 92:9; 105:24; 182:19, 21, 25; 183:10; 188:19; 189:6 application [2] 23:19; 134:12 Applications [1] 106:18 applications [6] 24:2; 61:6, 14; 118:22; 119:10; 134:11 apply [1] 153:11 appointed [1] 56:4 appoints [1] 140:12 appraised [1] 172:18 appreciate [5] 10:16; 34:22; 36:3; 169:14; 193:12 approach [3] 31:23; 34:23 appropriate [3] Look-See(i 34:5, 24; 149:10 approved [4] 87:18, 20, 22; 118:18 approximately [4] 74:21; 133:2; 167:5; 192:22 April [5] 45:7; 99:18; 100:4; 101:11; 115:4 area [22] 21:21; 22:13; 25:1, 23, 24; 26:16; 29:5; 30:19, 22; 31:15; 33:20; 34:2; 59:21, 22; 118:22; 126:20; 128:14; 157:15, 21; 171:24; 173:4; 185:8 areas [3] 126:24; 127:1, 2 arises [2] 65:13, 14 Armstrong [36] 6:23; 7:3, 9, 11; 9:1; 12:3, 5; 13:25; 25:13; 68:13, 17, 20, 22, 25; 69:1, 4, 10; 71:16, 20; 75:22; 76:2, 12, 15; 89:9, 16; 129:6; 137:5; 146:8; 172:11; 187:10, 20, 25; 188:7, 11 Aroclor [50] 42:14; 52:9, 11; 73:7; 76:11; 78:21; 81:1, 18; 82:6; 85:13; 88:3; 89:15, 22; 91:7; 95:5, 9; 96:10, 19, 22; 99:20; 100:20; 102:8; 106:19; 107:3, 11; 109:17; 110:5; 112:25; 116:11; 121:19; 128:23; 162:5; 166:14, 16; 167:2, 5; 170:4; 173:15; 174:20; 175:8; 182:16; 186:5; 188:10; 191:19; 192:1, 4, 10, 22; 193:1 Aroclors [10] 72:13, 21; 76:8; 1_06:1; 122:4; 140:21; 152:22; 161:16; 165:25; 186:19 Aronon [1] 155:23 arranged [1] 60:4 arrangement [3] 123:23; 183:3; 188:21 arrangements [1] 26:7 arranging [2] 142:13; 161:21 Arrival [1] 87:9 arrive [1] 87:11 arrived [1] 9:19 articulate [1] 68:19 asking [6] 29:15; 100:25; 119:6; 120:18; 144:13; 159:18 aspects [1] 105:6 assessed [1] 32:12 assignment [2] 33:8; 105:12 assimilation [1] JULY 30, 1998 MAERTIN v ARMSTRONG From advertising to assimilation TOWOLDMONOQ51503 BSA Carteret [2] 156:17, 18 case [14] 12:10, 17, 20; 13:23, 24; 15:20; 35:24; 36:12; 83:16; 91:15; 131:12, 14; 145:17, 19 cases [3] 48:23; 58:5; 83:10 catch [2] 58:7, 12 caution [3] 63:10, 15; 114:13 CCR [2] 6:4; 194:2 ceased [1] 116:6 ceiling [2] 14:2; 69:10 Center [1] 168:18 center [2] - 75:2; 130:10 centers [1] 94:4 Central [25] 31:9, 12; 39:11; 40:1; 44:6; 53:17; 54:6; 56:23; 57:18, 21, 24; 58:4, 8, 12, 15; 112:3; 119:20; 120:20, 22; 150:22; 151:17, 25; 179:17, 20; 188:5 central [4] 119:21; 121:4; 179:16, 19 CERTIFICATE [1] 194:1 certify [1] 194:5 cetera [1] 107:3 CH-UR-CS-L461QJ [1] 194:2 chance [1] 8:21 change [8] 21:13, 25; 25:8, 18; 26:12; 27:16; 58:7, 14 changed [7] 24:25; 26:10; 27:3, 10; 54:20; 139:11; 172:15 changes [3] 27:9; 44:23; 52:24 changing [2] 54:24; 130:4 charge [4] 63:2; 86:17, 24; 87:1 Chart [1] 177:1 charts [i] 52:25 check [3] 126:7, 9; 180:1 Chemical [15] 20:25; 22:23; 79:5, 10, 11,17, 20; 83:19; 88:10; 122:22; 135:16; 146:15; 151:8, 18; 183:1 chemical [4] 23:12; 29:8; 30:10; 42:16 Chemicals [4] 23:2; 27:8; 84:20; 179:7 chemicals [20] 20:6; 23:3; 27:1,15; 29:10; JAMES D. WRIGHT 34:13; 42:12, 13, 19, 21; 43:8, 10, 23; 45:18; 54:17, 21, 22; 88:14; 93:18; 186:16 Chemist [1] 160:22 Chief [1] 160:22 chlorinated [2] 113:1, 5 CHURCHILL [2] 6:4; 194:2 City [7] 22:7; 26:14, 16, 18; 28:5, 6; 41:25 Clark [7] 87:19, 22; 88:6; 117:20; 160:8; 164:8; 165:8 class [1] 89:25 Classification [1] 177:1 classify [1] 89:25 clear [4] 13:3; 140:7; 154:5; 175:13 client [3] 79:18, 21 clientele [1] 27:16 Co [1] 156:16 coast [2] 126:22; 132:18 coating [1] 106:20 collect [1] 88:22 college [1] 18:13 column [3] 183:12; 185:22 columns [2] 177:16; 185:23 combination [3] 34:12, 15; 37:10 comfortable [i] 98:6 coming [5] 101:23; 103:7; 117:1; 162:16; 172:10 commencing [1] 129:9 comment [13] 8:17; 11:7; 93:13; 94:1, 2; 110:11; 113:18,25; 114:1; 158:5; 168:9; 189:4; 190:4 comments [4] 7:17, 19; 8:19; 176:21 commission [3] 32:11; 125:19; 143:2 Commissioner [3] 55:20, 22; 56:16 commissioner [2] 12:16 Committee [4] 96:10; 115:3, 10; 118:17 committee [3] 32:15; 115:9; 118:8 committees [5] 71:22; 72:1, 9; 96:18; 97:8 Commodity [2] 50:7, 8 commodity [6] 40:9, 23; 50:2, 9; 52:7; 186:16 common [1] 141:17 communicated [1] 105:16 communication [8] 98:18, 19, 22; 105:24; 110:8, 15, 22; 111:3 communications [2] 73:6; 105:14 companies [9] 12:18; 23:13; 56:18; 57:20; 59:20; 144:1; 183:6; 184:5 Company [16] ' 6:22; 68:13; 78:10; 79:20; 89:9; 93:4; 122:22; 135:16; 146:15; 148:10, 16; 173:14; 176:8; 177:13; 179:5; 183:1 company [16] 20:5, 21, 23; 45:17; 57:24; 73:3; 82:9; 83:3; 84:23; 88:25; 97:5, 6, 9, 18; 188:4 comparison [2] 20:24; 32:4 compensated [1] 142:23 Competition [1] 112:20 competition [2] 34:10; 143:9 competitive [2] 113:9, 21 competitors [1] 34:10 complete [2] 161:16; 194:9 completed [3] 119:23; 183:19; 194:7 completely [1] 36:19 complies [22] 17:3; 77:17; 80:16; 84:17; 87:7; 88:18; 92:7, 22; 95:2; 99:25; 106:17; 108:6, 25; 109:2; 112:21; 118:1; 125:12; 129:14; 148:13; 153:1; 155:4; 164:12 complimented [1] 142:22 computer [1] 75:5 concentrate [1] 27:12 concentrated [1] 27:13 concentrating [1] 53:12 concentration (1) 27:1 concern [5] 49:9; 52:3, 11, 14; 116:21 concerned [3] 51:22; 52:2; 158:21 Concerning [1] 152:21 concerning [4] 75:12; 105:25; 109:12; 189:4 concluded [1] 193:16 Look-See(39) conditions [2] 133:23; 151:22 conduct [1] 57:10 conducted [2] 59:5; 61:15 conducting [3] 39:3, 8, 10 conference [2] 7:18, 23 Confidential [2] 108:2; 117:22 confidential [2] 119:24; 120:2 confirmation [1] 157:20 confirming [1] 15:15 conjunction [2] 39:5, 6 connection [5] 14:11; 15:4; 32:16; 110:9; 132:14 Conshohocken [5] 65:2; 73:17; 78:15; 159:11, 16 consider [1] 79:8 considered [3] 52:7; 118:23; 119:11 consistent [3] 9:3; 145:19, 21 construction [1] 161:17 consulting [1] 56:10 consumer [1] 42:23 Contact [2] 119:20; 121:9 contact [13] 14:8; 15:1, 17; 18:4, 7, 10; 44:10, 14; 111:8;-120:21; 157:9, 24; 184:24 Contacted [1] 160:17 contacted [3] 121:3; 157:15; 158:1 contacting [2] 120:14, 19 contacts [2] 49:22; 54:5 contained [1] 129:23 containing [5] 63:7; 73:7; 107:11; 116:12; 161:15 contaminants [1] 113:6 contamination [1] 12:19 continuance [1] 154:1 continue [2] 107:2; 117:11 continued [3] 65:11; 124:8; 187:24 Continuing [4] 64:7; 90:23; 135:13; 179:1 continuing [i] 144:24 Contract [1] - JULY 30,1998 MAERTIN v ARMSTRONG From Carteret to Contract TOWOLDMONOQ51504 BSA 161:16 details [1] 33:9 determination [4] 8:4; 167:14; 168:3, 6 determine [3] 7:25; 70:12; 119:4 develop [1] 30:9 developing [1} 48:22 differ [2] 27:4; 28:16 difference [7] 88:8; 137:4, 17, 24, 25; 138:12, 21 differently [1] 175:21 difficult [2] 13:4; 139:4 dloctyl [1) ' 50:10 direct (11) 46:20; 50:21; 79:21; 80:20; 85:4; 86:17; 91:8; 120:21; 128:4; 149:7; 154:7 direction [3] 120:5; 162:10; 194:8 directions [i] 24:25 directive [2] 122:1, 10 directives [1] 162:16 directory [1] 76:15 discharged [2] 19:17, 20 disclose [1] 187:15 disclosed [1] 187:20 discontinuation [8] 161:15; 162:8, 17; 163:9, 16, 19; 165:14, 19 discontinued [1] 158:17 discount [7] 85:23; 86:3, 8, 10, 12, 18, 25 discourage [2] 162:11; 170:13 discouraged [1] 162:19 discovery [5] 7:21; 10:3, 4, 6; 146:1 discuss [3] 98:25; 133:4; 166:13 discussed [6] 7:15; 98:7; 99:6, 12, 13; 165:14 Discussion [5] 77:5; 90:7; 108:12; 132:8; 171:5 discussion [2] 99:15; 111:5 discussions [2] 97:17; 189:22 Distilled [2] 89:15, 22 distinction [4] 50:4; 95:17; 96:1; 145:20 JULY 30, 1998 JAMES D. WRIGHT distinctions [1] 96:3 distinctly [1] 128:10 distract [1] 20:20 distribute [3] 55:4; 62:6; 126:20 distributed [2] 61:19; 137:18 distributing [3] 37:10; 40:6; 41:2 distribution (4) 44:11; 123:22; 126:21; 187:4 Distributor [i] 122:22 distributor [59] 26:6; 32:17; 33:9, 23; 34:23; 35:7; 43:21, 24; 44:19; 49:2; 52:1; 53:2, 3, 12, 15; 54:7, 16; 55:1; 57:9; 58:10; 59:19; 60:21; 61:8, 25; 83:7; 85:22; 126:19; 128:20, 21, 25; 129:22; 136:15; 137:6, 18; 138:11, 22; 139:14; 142:21; 146:18; 149:9; 151:9, 13, 19; 165:22; 182:1, 7, 12, 17; 183:1, 3; 184:24; 188:1, 6; 189:16, 24, 25; 192:25; 193:2 distributor's [1] 126:20 Distributors [2] 138:17; 152:21 distributors [109] 26:3, 8, 13; 30:4, 11, 13, 18, 23; 31:1, 2, 5, 8, 16, 21, 23; 32:17; 33:18; 34:4, 9; 35:9, 10, 13; 37:13, 23; 38:25; 39:25; 45:25; 46:4, 11,12,14, 16, 19; 47:4, 6, 11, 13; 48:5, 19, 21; 49:1, 6, 22; 50:24, 25; 51:8; 53:14, 24; 54:3, 6; 56:24; 57:3, 16; 58:18, 20, 25; 59:10, 11, 16; 61:23, 24; 62:10, 12, 25; 63:5; 73:6; 80:19; 81:10; 86:2; 101:9; 109:18, 24; 110:4, 9, 12, 17, 24; 111:3, 6, 9, 14, 18, 24; 112:2; 115:25; 116:6, 13, 19, 23; 120:7, 14; 121:10; 122:6; 126:13; 138:16; 149:1; 153:12, 15, 25; 154:8, 12; 172:16; 180:25; 182:15; 183:6; 190:8; 191:8 distributorship [4] 33:1, 4; 181:18; 191:24 District [4] 12:6; 25:16; 42:5; 162:25 district [53] 25:19, 22; 26:2, 15, 17; 27:4, 19, 21, 23, 25; 28:4; 32:7, 21; 33:19; 34:1; 35:4; 37:19; 43:20; 44:15; 45:16; 46:6; 50:16; 51:14, 18, 19, 21, 24; 57:8; 60:4, 6; 65:17; 66:12, 14, 16; 67:9, 10; 68:18; 69:12; 71:3; 74:16, 22; 78:1; 87:23; 88:7; 120:6; 133:21; 138:25; 157:16; 162:24; 166:19; 185:1 districts [2] 29:7, 20 Division [7] 21:1; 22:24; 23:2; 27:8; 81:13; 88:10; 179:7 division [13] 20:4, 6; 21:2; 43:9, 10; 45:18; 53:2; 54:17, 19, 21; 68:23; 71:15; 160:6 divisions [i] 184:5 document [99] 17:20; 73:24; 76:18, 23; 77:7; 78:13, 19; 79:2, 23; 80:4, 8, 24; 82:3, 8; 83:3, 6; 84:15; 85:4; 87:5; 91:11, 12; 92:2, 11, 13; 93:7; 95:1; 99:24; 100:1; 101:2; 104:7, 11, 12; 106:11, 15, 16; 108:15, 18; 109:1, 15; 112:11, 16; 115:6, 7; 117:19; 122:16, 21; 123:13, 16; 124:1, 15; 125:21; 130:10, 21, 24; 131:20; 132:11; 135:8, 19, 23; 144:9; 147:18; 148:12; 152:24; 154:22; 164:11; 166:2, 24; 169:15, 16; 171:10; 173:13; 175:8,15, 22; 177:1, 3, 5, 8, 16; 182:8, 19, 21, 24; . 183:9, 19, 23, 25; 184:8, 14; 185:10, 19; 186:4, 21; 187:8; 188:16, 23; 189:14, 18; 190:1 documents [22] 8:7, 9, 13, 15, 17, 22; 9:8, 10, 11, 20; 10:9; 17:23; 38:5; 80:1; 145:13; 147:12; 155:3, 6, 14; 168:24; 169:9; 189:24 doesn't [5] 36:23; 82:25; 151:23; 179:21; 186:13 DOP [2] 40:10, 20 doubt [2] 121:24, 25 drafting [1] 73:5 drafts [1] 124:14 drop [6] 79:9; 83:17; 84:6, 9, 11, 18 dropped [1] 185:3 Drum [1] 128:16 drum [10] 128:9, 15, 23; 138:5; 139:25; 141:2; 186:23; 187:1, 2 drums [10] 32;3; 78:21; 84:1, 2; 85:19, 20; 130:11, 13; 139:16; 185:2 duly (3) 11:14; 194:3, 11 duties [9] 21:25; 25:18; 26:24; 27:3; 30:15, 18; 68:22; 70:2; 176:14 duty [i] 19:9 - E- E.G. [2] 160:10; 168:16 E.M. (1) 148:9 Look-Soe{41 early [8] 24:5; 26:8; 58:3; 74:15; 119:23, 25; 139:6; 149:11 east [1] 126:22 eastern [2] 25;3; 43:13 Economics [i] 18:21 educational [1] 18:14 Edward [1] 107:25 efficiency [1] 187:18 efficient [2] 32:23; 132:19 efficiently [2] 140:3; 142:11 effort [7] 26:9; 31:19; 39:7; 46:24; 65:16; 66:22; 162:9 - efforts [9] 30:22; 32:4; 33:17, 23; 48:23; 70:11; 103:12, 15; 134:13 Elected [1] 56:6 elected [1] 56:4 electrical [1] . 88:2 Elmer [2] 175:24; 176:10 emanated [1] 110:16 emotional [i] 165:23 Emphasis [1] 43:23 emphasis [2] 42:18; 103:1 _ employed [5] 18:8; 19:23; 55:13; 56:16, 17 employee [2] 194:13, 14 employees [1] 14:10 employment [2] 41:23; 55:17 encourager [1] 66:17 end [7] 88:19; 94:19; 116:1, 20, 22; 162:18; 178:9 engage [3] 30:3, 12, 18 engaged [1] 31:1 engaging [2] 32:17; 41:1 England (1) 126:22 enroll [1] 19:19 ensure [2] 116:1, 19 entail [1] 26:25 entered [4] 38:11; 56:22; 64:9; 78:3 entering [3] MAERTIN v ARMSTRONG From details to entering TOWOLDMONOQ51505 BSA______ ___________________________ JAMES D. WRIGHT_________________ Loo!<-See(43) 82:12; 85:22 formulations [1] 158:22 found [2] 126:9; 129:22 four [7] 19:2; 45:9; 57:13; 141:23; 142:15; 155:1, 13 four-page [1] 154:22 fourth [3) 77:15; 82:8; 94:25 FR-1 (3) 171:22; 172:1, 12 frame [2] 67:20; 74:4 Francisco [1] 9:9 Fred [2] 164:15, 16 free [2] '63:2; 126:19 French [1] 23:12 frequent [1] 38:23 frequently [1] 27:10 front [3) 88:17; 115:13; 122:20 full [7] . 11:21; 79:9; 83:23; 84:1; 115:19; 141:25; 194:9 function [5] 20:17; 58:11; 69:12; 86:3; 138:17 functional [2) 88:9, 15 functions [i] 54:20 future [2] 7:8; 70:15 -G- G-i-l [1] 39:19 G-i-l-o-t-h [1] 39:20 Gannon [1) 166:8 gather [1] 8:21 gave [9] 8:9; 86:2, 10, 12; 114:24; 126:12; 143:16; 155:11; 187:10 generated [1] 134:24 gentleman [1] 150:7 gentlemen [i] 168:22 geographical [1] 24:22 George [2] 179:4, 8 Georgia [2] 173:2 Gerald [2] 14:14, 15 Gerard [3] 14:25; 15:8, 10 Giloth [51 39:13, 18; 150:22, 23; 151:2 gist [1] 167:1 give [10] 12:13; 47:7; 62:23; 63:15; 87:16; 114:16; 128:24; 161:22; 165:21; 184:6 given [15] 12:20; 30:12; 33:8; 57:22; 61:24, 25; 101:8; 107:4, 6, 10, 20,21; 112:25; 153:14 gives [1] 142:1 giving [2] 140:1; 189:25 glass [1) 20:6 goes [10] 89:13; 103:9; 109:4; 110:3; 113:8; 115:24; 128:19; 133:22; 149:9; 161:16 good-sized [1] 167:9 goods [1] 153:2 gotten [1] 106:8 governed [1] 142:24 Grabell [1] 172:22 grade [i] 88:2 graded [1] 32:12 graduated [1] 18:17 granted [1] 154:14 Greacan [1] 190:21 Great [3] 146:15; 151:17, 25 great [1) 42:22 grew [1] 58:4 Gronon [1] 155:21 Group [1] 185:23 group [35] 21:3; 23:5; 57:12, 14; 58:10; 68:23; 69:15; 70:11; 72:14; 74:7; 82:18; 87:21; 104:16, 19; 105:6, 8; 108:19; 109:22; 110:16; 122:1; 126:14; 130:8; 133:18, 20; 134:7, 16, 17; 138:24; 153:7, 21; 162:16, 24; 166:19; 170:10; 185:24 group's [1] 122:10 groups [4] 21:9; 105:10, 21; 106:4 growth (2) 46:25 guess [12] 16:7; 18:8; 20:15; 21:24; 29:1; 55:24; 63:10; 73:13; 114:14; 159:13; 183:14; 184:25 Guide [2] 92:2; 178:1 guide [1] 188:13 guy [3] 105:4; 136:4; 171:3 -H- half [3) 22:17; 60:13; 117:12 hand [1] 194:19 handle [1] 105:13 handled [6] 40:9; 74:15, 16; 105:12; 137:5; 151:14 handling [3] 128:8; 138:18; 185:2 handwriting [4] 147:6; 155:19; 174:18 handwritten (1) 155:18 handy [1] 182:1 hangs [1) 152:10 happening [6] 60:25; 109:10, 21; 153:20; 157:14; 163:21 Harleco [2] 84:20; 85:3 harmful [1] 96:23 haven't (2) 18:7; 41:7 head [2] 109:17; 112:2 heading [1] 102:3 headquarters [5] 31:12, 14; 74:18; 120:23; 148:25 Health [1] 176:13 heard [3] 69:23; 123:9; 185:15 hearing [1] 184:7 Heat [1] 172:6 heat [3] 171:9; 172:7, 20 heavily [1] 9:21 held (2) 57:7; 66:1 help (3) 44:24; 53:24; 60:8 helped [1] 138:13 helps (1) 17:4 hereby [2| 140:12; 194:5 herein [1] 6:6 Hereinafter [1] 130:14 hereto [2) 125:25; 140:24 hereunto [1] 194:18 herewith [1] 194:16 high-cost [1] 138:18 High-level [2] 115:17, 18 high-level [1] 115:16 Highly [1] 52:10 highly [1] 165:23 Hill [2] 124:18; 146:7 hinterland [1] 23:7 Hoc [1] - 96:10 hold [1] 22:12 home [7] 44:17; 74:23, 25; 78:1, 2, 4, 6 honor [1] 181:21 HOPKINS [164] 6:18; 10:19; 11:9; 23:21; 30:6, 20; 34:6, 25; 35:25; 36:6, 11, 16, 19, 25; 37:4; 38:13, 16; 40:16; 47:15, 18, 22; 49:11; 51:2,11; 60:1; 63:9; 64:18; 66:10; 67:19; 69:21; 70:5, 16; 71:7; 72:6, 17; 74:4; 77:4; 78:7; 80:2; 82:23; 83:14; 90:2; 91:21; 92:14; 93:12, 22; 94:6, 13; 95:6, 15; 96:6, 24; 97:12, 19; 98:1, 11; 99:2, 8; 100:8, 22; 102:1; 103:8,23; 104:6, 13; 105:9; 106:25; 107:13; 108:11, 20; 109:8, 25; 110:14; 111:1, 22; 113:16, 23; 114:12; 116:7, 14, 24; 117:6, 9; 119:2, 12, 16; 120:4; 121:6, 16, 22; 122:8, 12; 123:2, 6, 9; 125:3; 126:6; 127:13, 20, 22, 24; 128:17; 129:18; 130:22; 131:1, 9; 132:7; 133:6; 134:5, 21; 137:8, 21; 144:12, 21, 23; 145:4, 18; 147:8, IS, 20; 148:1; 149:19; 150:1; 151:10, 20; 152:3; 153:4, 16; 154:3; 155:5, 10; 156:4, 7, 17; 158:3, 14, 18; 159:17; 160:25; 161:3; 162:12; 163:11; 167:21; 168:7; 169:6, 17, 19; 170:15; 171:4; 175:6, 11, 25; 176:4; 177:9; 178:4; 179:19; 182:3; 183:24; 185:23; 188:5; 191:1, 6; 193:9, 13 Hopkins [9] 6:13, 15; 9:3; 10:16; 145:23; 191:17, 23; 192:9, 20 host [1] 117:20 hotel [2] 8:10; 9:20 . hour [i] ' JULY 30,1998 MAERTIN v ARMSTRONG From formulations to hour TOWOLDMONOQ51506 BSA___________________________ 178:1, 7 lab [1] 145:5 label [2] 92:9; 178:1 labeled [2] 181:2; 187:5 labeling [1] 181:7 Laboratory [1] 173:14 laboratory [1] 173:24 lack [5] 44:5; 94:3; 103:10, 14; 116:22 Lancaster [2] 89:10, 16 Lane [1] 11:24 language (2J .93:15; 183:17 LAPI [2] 178:5, 6 large [2] 146:2; 167:8 larger [4] 23:10; 24:14; 57:25; 141:2 Last [2] 9:19; 15:15 last [25] 7:17, 23; 18:4; 41:5; 60:12, IS; 63:21; 67:2; 84:14; 87:5; 90:15; 93:16; 106:16; 107:5; 109:4; 112:17; 121:2; 123:2, 16; 143:4; 156:23; 170:8; 175:22; 188:24, 25 late [4] 9:8, 16; 10:10, 13 law [1] 143:14 lawsuit [1] 13:19 lawyer [2] 14:16; 71:14 lawyers [1] 180:4 leading [3] 38:10; 56:21; 163:16 left-hand [1] 177:13 legal [2] 71:13; 183:4 Let's [6] 66:23; 80:23; 90:8; 117:11; 159:25; 178:16 let's [3] 19:4; 74:25; 91:12 letter (17) 8:5, 18; 15:8; 109:3, 4, 16, 23; 110:4, 10; 148:8; 152:19; 169:11; 171:7; 175:20; 178:9; 179:4 letters [5] 15:12; 22:2; 109:6; 110:25; 149:13 level [2] 97:17; 177:22 Lieutenant [1] 19:16 light [2] 161:17; 175:5 JAMES D. WRIGHT limitation [1] 13:14 limited [1] 21:2 Line [1] 67:4 line [19] 37:11; 40:2, 3, 22; 42:9; 43:6; 45:19; 48:20; 52:9, 12; 57:4; 61:4; 102:14; 124:19; 128:14; 132:2; 142:21; 178:8 Lines [9] 48:11; 49:17; 62:18; 64:2; 70:22; 90:18, 19; 114:6; 137:11 lines [10] 17:5; 27:13; 37:9; 42:18; 46:25; 57:12, 13; 102:3; 125:9; 158:21 list [9] 100:2; 129:24; 130:5, 19; 142:6; 143:15, 24; 148:13, 14 listed [3] 131:5; 140:23 lists [1] 49:3 literature [4] 61:19; 94:19, 22; 98:10 litigation [1] 56:13 live [1] 16:17 lived [1] 15:25 lives [1] 171:3 living [1] 16:16 loads [1] 139:20 locate [1] 159:14 located [4] 20:12; 26:22; 39:14; 60:6 location [4] 59:14; 65:6; 83:19; 156:20 locations [6] 17:6; 30:24; 65:10; 93:7; 94:18, 23 lock [1] 9:23 log [3] 131:2, 3, 11 logo [2] 63:6; 189:8 long-time [1] 31:19 . looks [7] 45:9; 77:20; 156:2, 24, 25; 174:20; 183:14 loop [4] 97:14, 16; 111:4; 162:23 loose [1] 21:9 loose-leaf [1] 17:5 lose [2] 139:7 lost [1] 23:8 Lot [1] . 175:9 lot [4] 44:23; 173:18; 174:20; 180:4 loud [1] 112:18 Louis [23] 16:5, 6, 16; 18:18; 20:13; 44:17; 45:11, 22; 46:13; 49:4; 51:7; 52:19; 53:7, 8; 55:11; 60:9; 67:14; 91:6; 100:5; 104:23; 132:18; 163:1, 6 lower [1] 156:15 lowest [1] 142:2 LTL [2] 34:18, 20 Lubbers [1] 11:24 Luckett [2] 151:14, 15 Lunch [1] 90:10 lunch [3] 90:9, 16; 91:1 - M- M-a-t-h-e-k-e [1] 175:22 M-a-t-i-c-k-i-e [1] 175:2 M.J. [1] 175:21 MAE [23] 73:18; 77:2; 84:16; 89:11; 92:3; 96:12; 100:21; 103:19; 108:3; 114:22; 117:23; 122:25; 135:17; 147:5; 148:10; 150:21; 152:20; 155:2; 156:24; 169:3; 173:15; 174:17; 177:2 Maertin [1] 12:5 magazines [1] 127:15 mail [2] 8:7; 110:4 mailed [1] 109:17 main [1] 34:8 maintain [4] 41:24; 46:7; 127:5; 139:1 maintained [2] 74:8; 132:24 major [1] 34:10 Malone [4] 88:20, 21, 23, 24 man [2] 23:8; 87:25 Management [3] 115:3,9; 118:17 management [5] 32:1; 118:7; 119:4; 124:17; 189:22 Manager [4] 42:5; 54:16; 136:3; 176:13 manager [92] 25:16, 19, 22; 26:3, 15, 17, Look-See(45) 25; 27:5, 6, 12, 22, 23; 28:1, 6, 13; 29:9, 25; 30:16; 33:6, 13, 19, 25; 34:1, 3; 37:16, 19; 39:6; 41:25; 43:4, 20; 44:22; 45:3,8, 11,21,24;46:6,9, 13; 47:3; 49:4; 50:16,19; 51:7, 14, 18; 52:15, 19; 53:2, 3; 56:21; 57:1; 60:4, 5; 65:17; 68:16, 18; 69:13, 17; 70:6; 71:2, 3; 72:12; 73:11; 75:15; 76:3; 79:24; 87:23; 88:7; 89:20; 91:6; 95:4; 97:22; 100:5; 104:22,23; 106:7; 119:7; 138:20; 151:14; 157:6, 16, 17; 158:11; 159:10; 163:6; 164:15; 166:19; 185:1 managers [33] 20:20; 27:19; 28:4, 18; 29:6; 32:7, 20, 21, 23, 24; 33:3, 20; 35:4, 5; 39:6; 44:15, 16, 20; 45:16; 48:24; 51:19, 21, 25; 65:17; 111:7; 120:6, 21; 133:12, 21; 138:25 manner [1] 181:9 manufacture [2] 70:15; 107:3 manufactured [3] 14:2; 40:23; 69:10 manufacturers [2] 40:11; 41:2 Manufacturing [1] 69:5 manufacturing [2] 70:4, 14 Mar [4] 180:11, 12, 14, 15 Mark [2] 170:19; 174:12 mark [28] 17:14; 73:15; 76:17; 89:3; 91:10, 12; 100:14; 108:7, 10; 117:14; 122:15; 135:7; 146:23; 148:2; 150:16; 152:12; 154:16; 159:23, 25; 164:1, 24; 165:6; 166:1; 169:15; 173:8; 175:15; 178:21 marked [43] 17:16; 73:19; 76:19, 23; 89:4; 91:15, 18, 25; 96:9, 13; 99:17; 100:15, 19; 103:17; 107:24; 108:10; 114:20, 22; 117:15; 122:17; 135:9, 15; 147:1; 148:4, 8; 150:18; 152:14, 18; 154:18, 21; 160:2; 164:3; 165:1; 166:3; 169:21; 170:20, 23; 173:9; 174:13; 175:16; 176:22; 178:22; 182:2 market [15] 71:24; 72:14, 22; 73:8; 95:11; 107:12; 119:5; 120:16; 121:11; 132:3; 133:23; 134:14; 162:5; 182:15; 192:2 Marketing [1] . 180:17 marketing [9] 26:9; 28:17; 32:1; 69:14, 18, 24; 98:18, 19; 189:2 markets [1] 61:6 _ marking [1] JULY 30, 1998 MAERTIN v ARMSTRONG From lab to markino TOWOLDMONOQ51507 BSA________________________________ 137:4, 17, 25; 143:8; 144:16; 145:23; 146:6; 147:4; 148:7, 9, 15, 20; 149:3, 17, 23, 24; 150:3, 5, 21, 22; 151:2, 4, 6, 12, 15, 22; 152:10, 17; 153:5, 20; 154:9, 21; 155:16,21; 156:9, 18, 23; 158:7, 16; 159:3, 18; 160:5, 10; 161:1, 8; 162:17; 163:15; 164:6; 165:4; 166:6; 167:25; 168:12, 21; 169:1, 24; 170:2, 17, 23; 171:7, 8, 18; 172:22; 173:12; 174:16, 23; 175:19, 21; 176:7, 15, 25; 177:12; 179:4, 21, 25; 180:11; 182:5; 183:15; 184:1; 185:24; 188:6; 190:6; 191:7, 17, 23; 192:9, 20; 193:12 Murray [2) 124:18; 146:7 mutually [2] 7:10; 10:18 myself [2) 124:17; 147:14 -re name [25] 11:21, 24; 12:2; 52:5, 7; 91:16; 100:2; 118:4; 136:12; 148:23; 155:23, 25; 159:6, 7; 161:10; 165:10; 168:13; 174:25; 175:2; 176:7; 179:21; 181:4; 189:15; 190:1, 22 named [4] 140:19; 168:15; 190:12, 20 namely [2] 122:4; 140:18 names [8] 38:4; 47:7; 115:12, 14; 140:1; 144:23, 25; 145:15 naming [2] 168:22; 189:24 nation-wide [1] 31:7 national [i] 66:4 nationally [2] 53:25; 54:5 naturally [i] 154:24 nature [6] 13:18; 75:5; 118:23; 127:17; 141:25; 180:15 Navy [5] 18:19, 23; 19:1, 15, 20 nearby [2] 93:18, 21 needs [5] 34:24; 35:14; 167:13, 19; 168:2 negatively [1] 175:3 negotiated [5] 40:1; 182:7; 183:2, 18; 184:9 negotiating [1] 181:18 negotiation [1] 183:18 negotiations [3] 32:16; 41:5; 183:21 Neil [1] JAMES D. WRIGHT 155:21 Nelson [1] 168:13 Niagara [1] 23:13 Nietzel [2] 179:4, 8 night [2] 9:19; 10:13 nonbiodegradable [1] 118:13 nonexclusive [ij 140:17 norm [1] 132:23 normal [1] 132:23 North [3] 64:17, 22 north [1] 29:1 northeast [i] 166:10 Nos [1] 17:16 Notary [4] 6:4; 11:15; 194:3, 23 notation [3] 87:8, 15; 88:19 Note (2) 96:6; 128:17 note [3] 11:1; 147:8; 176:1 notebooks [ij 145:5 notes [4] 16:25; 17:6; 155:18; 180:1 notice [18] 6:23; 7:2, 12; 8:2, 11; 9:12, 13,15; 10:4; 17:15; 49:2; 82:15, 16; 83:23, 24; 137:2; 180:11; 188:10 noticed [4] 6:14; 9:21; 10:5; 85:21 notification [1] 157:18 notified [3] 149:13; 157:21; 158:12 notify [1] 149:7 noting [1] 10:20 November [1] 123:24 Number [4] 11:22, 25; 92:1; 150:21 number [14] 27:9; 42:10; 52:23; 54:20; 60:13; 77:16; 88:13; 112:13; 115:21; 123:2, 8; 169:20; 173:18; 191:7 numberous [i] 145:5 nylon [2] 158:23, 25 - 0- O'CONNOR [4] 11:4, 8; 152:5, 9 O'Connor [i] 152:10 o-n-a-n [1] 156:4 o-n-o-n [i] 156:5 Object [88] 30:6; 34:6, 25; 40:16; 47:15; 49:11; 51:2, 11; 60:1; 64:18; 66:10; 70:16; 71:7; 72:6, 17; 80:2; 82:23; 83:14; 90:2; 92:14; 93:10, 22, 25; 94:6, 13; 95:6, 15; 96:24; 97:12, 19; 98:1, 11; 99:2, 8; 100:8; ' 102:1; 103:8; 104:6, 13; 105:9; 106:25; 107:13; 108:20; 109:8, 25; 110:14; 111:1, 22; 116:7, 14, 24; 119:2, 12, 16; 120:4; 121:6, 16, 22; 122:8, 12; 125:3; 127:13, 20, 22, 23; 129:18; 133:6; 134:5, 21; 137:8, 21; 149:19; 151:10, 20; 152:3; 153:4, 16; 154:3; 158:3, 14, 18; 160:25; 161:3; 162:12; 163:11; 170:15; 177:9; 192:6 object [9] 23:21; 37:3; 69:21; 78:7; 113:16, 23; 131:18; 167:21; 168:7 Objection [7] 30:20;38:13; 190:2; 191:13, 15, 21; 192:13 objection (15) 9:25; 10:2, 20; 11:1; 36:24; 38:17; 47:20; 96:6; 128:17; 144:24; 145:3; 147:9, 16; 150:1, 2 objections [2] 8:19; 194:10 Objective [1] 165:13 objective [1] 190:7 observations [1] 97:4 observer [ij 66:17 observing [ij 66:19 obtain [2] 70:2; 75:16 obtained [1] 18:15 Obviously [4] 80:10; 100:25; 114:24; 145:2 obviously [8] 100:1; 104:16, 17; 126:7; 131:19; 140:6; 147:22; 182:20 occasion [3] 25:12; 58:22; 185:2 occurred [1] 6:19 October [3] 42:1; 85:9; 87:12 offer [2] 34:19; 35:15 offhand [2] 163:14; 176:17 Office [1] 22:6 office [33] Look-See(47) 15:18; 21:21; 22:7; 26:18, 19, 22; 28:23, 24; 29:12; 41:16, 19; 42:20; 44:17; 45:4, 22; 59:7; 74:23; 75:1; 78:1,2, 5, 6; 109:17; 124:21; 125:1, 7; 146:6; 157:15; 159:11, 16; 179:12, 14 offices [20] 29:4; 39:21; 44:9; 54:12,13; 57:8; 59:10, 12; 64:17, 21; 67:10; 71:17; 74:16, 23; 112:3; 119:21; 121:3, 4; 125:5; 148:25 official [1] 194:19 officially [1] 67:16 Oh [14] 12:12; 55:18; 57:6; 59:1; 60:13; 85:6, 19; 93:20; 94:7; 115:15; 134:18; 181:3; 187:6; 188:14 - oh [2] 75:23; 157:10 Oil [3] 78:9; 80:21; 172:23 Okay [94] 12:24; 14:23; 15:16; 16:14; 17:4, 22; 24:5; 33:3; 35:6; 36:10; 37:18, 21; 40:25; 45:2, 8; 46:3, 16, 17; 47:2; 49:4; 50:23; 53:1; 59:24; 62:24; 75:7; 77:11, 14, 17, 18; 78:12, 16; 80:16, 23; 81:9; 84:13; 85:7, 20; 86:1, 6; 87:4, 15; 88:16; 91:21; 92:7; 95:2, 22; 96:3; 99:17; 100:3; 104:1, 2; 108:14; 110:19; 112:21; 117:13; 118:1; 123:6; 125:8, 12; 130:25; 133:1; 135:21, 22; 136:17; 139:22; 140:4, 5; 141:13; 142:3; 147:15; 148:1; 153:1; 155:4; 156:23; 159:24; 172:22; 173:5, 6; 174:11; 175:15; 180:19; 181:9; 182:19, 24; 183:9; 184:7; 185:8, 13; 187:3, 23; 189:18; 190:17, 23; 193:8 okay [3] 19:13; 142:9; 153:24 Old [1] 180:19 old [3] 150:7, 14; 180:18 Olympia [6] 6:3; 11:25; 12:17; 15:25; 16:4; 55:23 on-board [i] 59:19 on-the-job [1] 24:1 one-time [1] 60:17 ongoing [1] 145:1 operated [1] 86:2 operation [3] 47:9; 48:18; 49:8 opportunity [i] 142:2 - JULY 30,1998 MAERTIN v ARMSTRONG From Murray to opportunity TOWOLDMONOQ51508 BSA points [1] 43:14 Policy [i] 152:21 policy [10] 30:9; 47:12, 24; 153:3, 5, 6, 21, 22; 154:1, 6 Port [6] 12:16, 17; 55:20, 22, 23; 56:15 port [3] 12:15, 16, 19 portion [1] 10:22 portions [1] 183:22 Portland [1] 146:16 posed [1] 105:19 poses [1] - 102:7 position [33] 9:5; 20:2; 21:11; 22:12; 24:12, 20; 25:15; 29:24; 33:24; 37:15; 41:24; 42:4, 6; 43:3; 44:2; 45:3, 6, 10, 14; 53:1, 9, 19, 20, 21, 22; 54:2, 9, 15; 55:7, 11, 19; 56:4, 5 positions [3] 21:13; 180:21; 189:20 positive [i] 95:10 possibility [1] 72:16 pound [1] 167:5 poundage [1] 90:1 pounds [10] 78:22, 24; 81:18; 84:1; 85:15; 89:22; 185:17; 186:6; 192:18, 22 practice [5] 86:23; 128:22; 162:11; 165:16; 167:17 prepaid [1] 88:22 prepare [1] 124:16 prepared [2] 104:12; 108:19 preparing [1] 9:17 preprinted [1] 183:10 present [1] 115:13 Presentation [1] 108:1 presentation [i] 118:7 presented [3] 183:19; 184:8, 14 preserve [1] 10:25 President [1] 148:9 president [3] 136:5, 6; 146:20 press [2] JAMES D. WRIGHT 97:25; 98:9 presume [i] 159:17 pretty [2] 190:7 previous [3] 7:19; 141:11; 169:10 previously [4] 8:16; 36:13; 107:24; 131:15 Price [1] 125:23 price [5] 125:24; 126:12; 129:23; 130:5; 142:2 . pricing [2] 34:18; 82:13 Primarily [2] 76:6; 186:16 primarily [13] 39:13; 43:23; 59:22; 69:2; 128:8; 134:8; 138:19; 139:25; 161:17; 162:22; 186:15, 19; 190:5 primary [2] . 54:4; 126:21 Principal [i] 140:12 principal [1] 140:13 print [3] 188:22; 189:23; 190:1 printed [4] 182:21, 25; 183:22; 189:15 printout [i] 185:20 Prior [7] 7:17; 14:25; 15:16; 16:4, 16; 40:25; 54:7 prior [25] 6:13; 7:21; 14:21; 15:18; 17:20; 18:18; 26:7; 31:24; 33:18; 35:11; 37:14; 38:21; 40:7; 41:14; 54:8; 64:13; 72:13; 73:1; 123:16, 25; 124:1; 144:9; 162:17; 163:9, 18 privilege [2] 9:23; 131:2 privy [i] 134:23 problem [1] 98:14 problems [2] 102:7, 12 procedure [2] 21:18; 86:7 proceed [3] 7:7; 10:25; 117:25 proceeding [2] 20:9; 66:25 proceedings [1] 6:8 process [7] 30:7; 32:16; 33:11; 38:10; 75:8, 9; 193:4 Processed [1] 75:2 processed [1] 75:1 produce [1] 131:16 produced [9] 8:7, 16; 9:11, 14; 91:3; 131:3; 145:14; 147:21; 154:23 producing [i] 8:13 Product [5] 130:8; 134:7, 16; 173:15; 177:1 product [102] 21:3, 9; 27:13; 32:3, 23; 33:3, 6; 35:4; 37:8; 39:6; 42:9, 17; 44:15, 20, 22; 46:6, 8, 25; 47:10; 48:20; 50:19; 52:8; 57:1, 11, 12, 13, 15; 58:19; 61:5; 65:22, 23; 68:23; 71:2; 74:7; 79:4; 80:5; 81:14; 82:5, 18; 83:8, 11, 13; 85:11; 86:3, 9; 87:3, 20; 88:5; 95:13; 104:16, 22, 24; 105:4, 6, 8, 10, 14, 15, 21; 106:4; 108:19; 109:22; 110:16; 111:7; 119:3, 5; 121:21; 122:1, 2, 3, 4, 10; 124:17; 128:14; 131:23; ' 132:2; 134:17; 138:24; 142:14, 18, 21; 143:1; 153:5, 7, 15; 158:21; 162:16, 24; 166:19; 170:10; 171:9, 22; 173:17; 174:3, 5, 8; 181:10, 23; 187:4; 193:2 production [3] 8:23; 130:24; 155:15 Products [3] 89:9; 131:24, 25 products (ill) 14:1; 21:2, 5, 6; 23:1, 6, 7; 26:4; 28:15; 30:4; 31:17; 34:12; 37:10; 40:2, 3, 7, 14, 22, 23; 41:3; 42:14, 21, 23, 25; 43:1, 6, 17; 47:5; 48:6; 49:6, 9, 25; 50:14, 25; 51:9; 52:4; 55:2, 4; 56:25; 58:15; 61:15; 62:14; 63:7; 69:3, 4; 70:3, 12, 13; 73:16; 74:2; 75:10, 13, 18, 21; 76:1, 5, 11, 14, 25; 82:22; 83:11; 88:13, 14; 90:1; 94:4; 95:5, 9; 96:22; 105:11; 109:13; 118:13, 15; 119:8; 121:11; 126:14, 20, 22; 130:15, 16, 20; 131:5, 12; 134:11; 137:5, 18; 139:16; 141:23; 146:8; 149:10; 162:7; 165:24; 172:13; 173:24; 182:13, 15, 16; 185:11; 186:17; 191:8, 11, 17, 19; 192:1, 4, 10, 12; 193:6 program [3] 67:17; 127:9, 10 programs [3] 43:24; 102:6, 11 progress [1] 133:10 progressed [2] 59:24, 25 prohibition [2] 63:5; 86:20 project [1] 67:12 promising [1] 102:25 promote [1] 127:10 Look-See (4t promoting [1] 103:2 promotion [3] 27:22; 28:15; 127:8 promptly [3] 93:18; 110:5; 194:17 pronounced [1] 190:21 proof [1] 113:6 proper [1] 145:3 properly [1] 134:13 property [1] 12:19 proposed [1] 110:10 proprietary [13] 49:25; 50:5, 12; 51:9, 23; 52:4; 87:1; 130:14, 15; 140:18; 144:24; 145:8- providing [1] 144:25 provision [2] 129:15, 16 Public [3] 6:4; 194:3, 23 public [2] 102:15, 20 publication [3] 92:8; 101:3, 5 publish [1] 103:1 published [2] 94:11; 126:15 publishing [1] 94:16 pull [3] 132:21; 162:5; 182:3 pulled [2] 72:13;107:11 ' pulling [1] 16:23 purchase [2] 142:2; 170:8 purchased [2] 167:4; 170:4 purity [2] 174:3, 8 purports [i] 89:15 purpose [3] 50:9; 166:12; 174:2 purposes [3] 70:12; 145:6; 168:23 pursuant [6] 9:11; 138:23; 139:18; 141:5; 146:9; 187:10 putting [1] 63:6 - Q- qualities [2] 95:5, 10 quality [1] 88:5 quantities [5] 128:15, 23; 139:16; 141:2; 180:23 JULY 30, 1998 MAERTIN v ARMSTRONG From points to quantities TOWOLDMONOQ51509 BSA _______________________________ JAMES D. WRIGHTLook-See(51) replacement 14] 165:24; 166:13; 167:2; 172:12 Report [1] 173:14 report [17] 52:20; 80:6; 81:7, 8, 12, 14; 82:4; 160:6, 15; 164:7; 165:5; 166:7; 169:2, 16; 170:2; 173:17 reported [2] 28:4, 7 REPORTER [1] 81:25 reporter [11] 12:22; 48:13; 49:19; 62:20; 64:4; 67:6; 70:24; 90:20; 114:8; 137:13; 176:1 reporting [3] 21:21; 28:1; 32:15 reports [7] 134:24; 160:9, 11; 163:8, 17; 166:18; 173:24 represent [2] 12:3; 138:7 representation [2] 138:9; 147:23 Representative [1] 179:6 representative [5] 24:13; 44:3, 4; 161:7; 180:17 representatives [1] 41:13 represented [2] 189:1; 192:5 representing [i] 40:15 reprint [1] 63:1 request [3] 136:25; 168:21; 169:8 requested [2] 131:23, 25 requesting [1] 121:18 requests [1] 169:10 required [2] 7:20; 56:24 requirements [1] 157:17 research [7] 34:4, 23; 37:6; 47:4; 58:21; 134:12; 177:20 researching [2] 35:7, 17 resell [3] 47:11; 181:10, 16 reservation [1] 10:21 Reserve [3] 18:23, 24, 25 reserve [3] 10:8, 15; 146:2 reserved [2] 193:15; 194:12 reserves [2] 19:5; 143:8 reside [1] 16:4 residing [2] 194:4, 23 resistance [2] 31:20; 32:6 resistant [3] 95:14, 18; 172:4 resisted [1] 32:6 respect [2] 182:13; 183:22 respective [1] 158:1 respond [4] 8:20, 25; 97:10; 104:3 response [5] 6:22; 8:1; 114:14; 158:12; 159:4 responsibilities [4] 43:16; 46:3, 18; 53:11 responsibility [22] 25:20; 30:12; 43:21; 44:18; 45:25; 46:20; 47:3; 51:15; 57:1; 71:2; 88:12; 104:18; 105:13, 17, 22; 111:17, 25; 119:4; 126:21; 157:16; 163:5; 171:24 responsible [4] 45:15; 105:11; 120:7; 142:13 rest [1] 41:22 restrict [3] 126:18; 143:12, 14 restriction [i] 128:2 result [1] 133:9 Results [2] 161:14; 170:1 retardant [1] 95:14 retardencey [1] 95:19 retired [4] 16:15; 18:6; 55:8, 17 retirement [2] 18:9; 55:14 Return [2] 152:21; 153:5 return [2] 153:2, 15 returned [1] 185:5 ' review [14] 9:20; 17:23; 68:16; 73:23; 79:24; 80:1, 8; 92:5; 99:23; 101:1; 108:5; 115:5; 117:18; 164:10 Reviewed [1] 161:15 reviewed [3] 17:20; 77:7; 169:24 reviewing [2] 117:24; 163:7 revised [1] 126:15 revision [1] 100:6 Right [9] 79:5; 130:17; 132:12; 140:14, 16; 149:15; 156:6; 166:11 right [53] 10:8, 15; 16:9; 36:15, 16; 53:18; 65:1; 70:8; 75:3; 79:19; 80:17; 81:16, 20; 84:5; 86:16, 22; 99:16; 111:20; 115:18; 120:11; 123:3, 17; 127:18; 131:22; 132:6; 136:7, 9, 15; 139:17; 141:8; 142:20; 143:9; 145:8, 24; 146:2; 147:17; 153:23; 156:13; 167:3; 172:21; 174:10; 175:14; 178:8, 14; 183:12; 185:7; 186:2, 12; 190:19; 191:12; 192:24; 194:12 right-hand [2] 85:8; 120:10 rights [2] 10:21; 11:1 ring [2] 151:23; 179:21 ripped [1] 147:18 road [1] 10:13 Rochester [1] 23:12 Roder [1] 171:8 role [4] ' 34:5; 54:8; 138:21, 22 Roman [2] 175:9, 12 room [1] 6:15 Roosevelt [1] 156:16 Rosen [2] 7:22; 36:12 rosen [1] 42:23 Rosen's [2] 7:17, 19 roughly |4) 16:8; 56:2, 20; 78:22 routing [1] 88:23 Roy [1] 190:13 rubber [3] 27:1, 14; 29:10 Rule (1) 6:23 rumors [1] 97:23 rushed [1] . 167:11 - s- sale [4] 140:17; 143:1; 185:16; 186:2 Sales [10] 20:3; 26:21; 28:20, 21; 53:2; 89:8; 108:2; 115:20; 136:3; 179:6 sales [176] 20:5, 11, 14, 16, 25; 21:16, 17, 19, 23, 25; 22:1, 3, 22; 23:4; 24:2, 10, 13, 18, 23; 25:10, 16, 18, 19, 22, 24; 26:2, 15, 17, 20, 25; 27:3, 4, 5, 6, 17, 13, 27, 22, 23, 25; 28:6, 12, 17; 29:6, 9, 25; 30:10, 76; 32:73, 22; 33:13, 79, 20, 24; 34:1, 3, 14; 37:15; 41:25; 43:4; 44:3, 4; 45:3, 8, 11, 21, 24; 46:7, 8, 12, 24; 47:2; 49:4; 51:7; 52:14, 19; 53:3, 25; 54:4, 16; 56:21; 58:4, 5; 64:12; 66:1, 5, 9; 68:3, 16, 17, 22; 69:12, 13, 15, 17; 70:6, 11; 72:12; 73:11, 15; 74:1, 2, 8; 75:15; 76:3, 24; 79:24; 80:6; 81:7, 10, 14; 89:15, 79; 91:4, 5, 6, 8; 92:16, 17, 18, 19; 94:12, 16, 19, 22; 95:4; 97:22, 23; 98:8; 99:1; 100:5; 101:17; 103:11, 15; 104:23; 105:24; 106:4, 7; 111:8; 115:25; 116:5, 11, 19, 23; 119:7; 125:6; 133:10; 138:20; 139:8, 19; 140:17; 141:7; 158:11; 161:6, 12; 162:24, 25; 163:6, 7, 17; 165:17; 185:10; 186:4, 11,15; 188:17, 19; 189:6, 12; 190:10; 792:3,8 " Salesman [3] 22:14, 15; 160:10 salesman [19] 21:20; 22:18; 25:20, 22; 28:14; 32:10; 95:4; 112:23; 157:8, 14, 23, 24; 158:1; 160:14; 165:18; 166:8, 13; 168:12, 15 Salesmen [1] 32:7 salesmen [38] 22:27; 27:20; 28:9; 32:2; 37:20; 45:17; 48:25; 49:23; 50:17; 59:13; 60:5; 61:9, 25; 64:24; 65:12; 71:3; 88:6, 9, 10, 12; 101:6, 8; 103:13; 104:3; 105:19, 23; 107:10; 113:12; 124:25; 133:12, 13; 139:5; 157:19; 158:6; 159:6, 10, 16; 189:13 sample [1] 106:19 Samples [1] 167:11 samples [i] 761:22 San [1] 9:9 SANDRA [2] 6:4; 194:2 Santicizer [11] 52:5, 7, 12; 76:6, 14; 131:14; 132:17; 186:18; 191:11, 14, 17 saying [9] 6:13; 63:14; 93:17; 141:4, 5; 158:8; 170:11; 171:3; 186:23 Schalk [4] 52:23; 73:73; 152:19; 153:6 Schalk's [2] 149:17, 24 schedule [2] 16:20; 60:22 scheduled [1] 10:6 scheme [i] 186:8 school [1] JULY 30, 1998 MAERTIN v ARMSTRONG From replacement to school TOWOLDMONOQ51510 BSA stands [1) 9:25 stapled [2] 155:7, 9 start [5) 6:12; 26:12; 33:11, 15; 53:2 started [i] 59:23 Starting [1] 74:13 starting [1] 18:13 STATE [1] 194:2 State [5] 6:5; 62:15; 127:25; 194:4, 23 state [2] 11:21; 137:2 state-side [1] 19:13 stated [4] 6:13; 9:5; 10:1; 48:4 statement [9] 6:16; 7:13; 9:3; 10:16; 107:9; 111:21; 139:23; 167:24; 182:10 statements [1] 184:3 States [2] 12:6; 19:12 states [2] 126:23; 178:1 station [1] 156:21 status [2] 25:8; 169:10 Steel [1] 85:20 steel [4] 23:13; 85:17, 19; 186:23 Steilacoom [2] 194:4, 24 sticker (i) 91:13 stock [6) 94:3; 162:2, 6; 163:9; 167:12, 18 stocking [2] 162:19; 163:18 stocks [2] 93:18, 21 stockyards [i] 94:3 Stop (1] 156:15 stop [4] 21:22; 24:11; 121:12, 15 Stroeble [2] 160:17; 162:1 strong [1] 48:22 structure [2] 27:10; 44:8 studied [1] 72:15 study [1] 72:2 studying [4] 71:22; 72:10; 96:18; 97:9 subject [3] 99:20; 183:18; 184:22 JMIV1CS U. WKIUM I substance [1] 14:19 substantial [1] 186:9 suffice [1] 54:22 suggested [1] 107:4 suggestion [2] 113:11,21 suing [1] 14:6 suitable [1] 118:15 Suite [1] 6:3 Sullivan [1] 190; 13 summarize [1] 6:19 Summary [1] 89:8 summary [4] 73:16; 76:24; 91:4; 185:10 supervisor [1] 171:9 supplied [4] 62:4; 63:2; 183:4; 184:4 supply [2] 170:4, 8 support [2] 103:1; 165:21 suppose [2] 145:10; 169:4 surprised [1] 150:15 switch [1] 74:19 sworn [2] 11:14; 194:11 system [1] 172:7 -T- Tab [5] 151:8, 17, 23, 25 Table [2] 140:23; 144:3 tactic (1] 113:14 Taipale [2] 171:8, 18 talk [2] 131:21; 133:18 talked [2] 35:9; 123:19 talking [6] 29:10; 40:3; 46:16; 59:17, 18; 132:4 talks (1) 133:1 tank [6] 84:4; 139:19; 141:3, 22, 25 tanker [1] 142:18 TAYLOR [114] 6:12; 8:25; 11:20; 17:11; 35:18, 23; 36:2, 10, 15, 17, 22; 37:2; 47:16, 19; 48:2, 7; 49:15; 62:16; 63:16, 20; 64:8; 66:23; 67:1, 21; 70:8, 19; 73:14; 74:5; 76:17; 81:22; 82:1; 89:2; 90:5, 8, 14, 24; 91:10, 24; 100:13, 23; 103:25; 108:9; 112:14; 114:4, 19; 117:8, 13; 122:15; 123:4, 7, 11; 126:4; 130:25; 131:7, 18; 135:4, 7, 14; 136:25; 137:15; 143:7; 144:19, 22; 145:2, 11, 22; 146:5, 23; 147:13, 17, 24; 148:2; 149:21; 150:16; 152:7, 12; 154:16; 155:8; 156:6; 159:13, 19, 22, 25; 164:1, 23; 166:1; 168:20; 169:13, 18; 170:19; 171:1; 173:7; 174:12; 175:4, 10, 14; 176:3, 6; 178:6, 13,16, 21; 179:2, 18, 24; 190:2, 25; 191:13, 15, 21; 192:6, 13; 193:11; 194:17 Taylor [155] 7:4; 8:9; 9:1; 12:2; 17:19; 20:11; 23:25; 30:7, 25; 34:20; 35:6; 37:6; 38:20; 39:19; 40:19; 48:4, 15; 50:4; 51:6, 16; 60:11; 62:22; 64:23; 66:14; 67:8, 22; 68:12; 69:23; 70:10; 71:5, 11; 72:9, 20; 73:22; 74:9; 76:22; 77:7; 78:12; 80:3; 82:2; 83:2, 22; 89:7; 90:3; 91:25; 92:17; . 93:15, 23; 94:2, 8, 17; 95:10, 17; 96:8; 97:1, 15, 21; 98:5, 15; 99:5, 11; 100:10, 18, 25; 102:3; 103:9; 104:2, 7, 17; 105:18; 107:1, 17; 108:15, 22; 109:10; 110:3, 19; 111:10; 112:1, 16; 113:20; 114:1; 115:5; 116:8, 18; 117:1, 18; 119:6, 14, 17; 120:9; 121:9, 18, 25; 122:9, 13, 20; 123:13; 125:8; 126:10; 127:14, 21; 128:2, 19; 129:23; 131:22; 132:10; 133:15; 134:9, 23; 137:4, 17, 25; 143:8; 144:16; 146:6; 147:4; 148:7; 149:23; 150:3, 21; 151:12, 22; 152:17; 153:5, 20; 154:9, 21; 155:16; 156:9, 18; 158:7, 16; 159:3; 160:5; 161:1, 8; 162:17; 163:15; 164:6; 165:4; 166:6; 167:25; 168:12; 169:24; 170:17, 23; 171:7; 173:12; 174:16; 175:19; 176:7, 25; 177:12; 179:21 Taylor's [2] 10:20; 114:14 team [3] ; 39.7; 66:21 Technical [5] : 100:6, 10, 20; 103:14; 127:15 technical [14] 61:11, 18; 62:1, 4, 13; 63:1; 66:20; 67:14; 68:6; 101:4, 15, 24; 105:6; 133:19 telephone [3] 7:18, 23; 15:19 telephones [1] 22:2 tells [1] 87:19 Ten [1] Look-Soo(;>; 16:7 tended [2] 6:21; 7:1 Term [1] 129:10 term [6] 69:23, 25; 98:5, 6; 129:8, 16 terminals [1] 132:15 terminated [3] 115:20; 116:12; 139:12 terminating [2] 115:25; 116:19 termination [3] 167:20; 168:6; 170:9 terminology [3] 95:20, 23, 25 terms [6] 56:7, 8; 125:24; 146:11; 151:22; 184:9 territories [3] 30:19; 31:9; 57:22 territory [7] 24:14, 23; 28:22; 31:7; 43:11, 12; 126:19 Test [1] 173:14 test [1] 173:24 testified [2] 11:16; 48:16 testify [1] 194:11 testimony [8] 24:9; 40:19; 48:17; 97:7; 120:12; 141:11; 187:13; 194:9 testing [1] 174:9 Texas [1] 43:13 Thank [2] 193:11, 13 - Thanks [2]~ 89:1; 190:23 thereabouts [1] 30:2 thereafter [1] 194:8 thereby [1] 34:16 thereof [1] 194:15 Therminol [3] 171:22; 172:1, 12 Therminols [1] 172:13 third [11] 77:14; 80:4; 84:12, 13; 109:1; 115:19; 118:21; 130:9; 136:1; 152:24, 25 Three [1] 102:3 three [5] 19:4; 33:13; 48:8; 57:13; 107:5 Thursday [1] 6:2 thwart [1] 34:14 tile [2] 14:2; 69:2 _ JULY 30, 1998 MAERTIN v ARMSTRONG From stands to tile i TOWOLDMONOQ51511 BSA withdraw [i] 149:21 withdrawal [i] 120:15 withdrawn [4] 71:24; 72:21; 73:8; 192:1 WITNESS [94] 23:23; 30:21; 34:8; 35:2; 38:15, 19; 39:18; 40:18; 49:13, 21; 51:4, 13; 60:3; 64:20; 66:12; 68:11; 70:7, 9, 18; 71:1, 9; 72:8, 19; 74:7; 78:9; 82:25; 83:16; 92:16; 93:13; 94:1, 7, 15; 95:8, 16; 96:25; 97:13, 20; 98:3, 13; 99:4, 9; 100:9; 102:2; 104:1, 15; 105:10; 107:14; 108:14, 21; 109:9; 110:2, 15; 111:2, 23; 113:18, 25; 114:10; 116:16, 25; 117:11; 119:3, 13; 120:5; 121:7, 17, 23; 125:4; '127:25; 129:20; 133:8; 134:7, 22; 135:2; 137:23; 144:14; 146:3; 152:4; 153:18; 154:5; 158:5, 20; 161:5; 162:14; 163:13; 167:23; 168:9; 177:11; 178:15; 179:20; 190:4; 191:14; 192:7, IS; 194:18 Witness [43] 17:3; 77:1,7; 80:16; 84:17; 87:7; 88:18; 89:14, 18, 21; 92:7, 22, 25; 93:3, 5; 95:2; 99:25; 106:17; 108:6, 25; 109:2; 110:7; 112:21; 115:23; 116:2, 4; 118:1, 16, 20, 25; 121:14; 125:12; 127:7; 129:14; 148:13; 149:8; 153:1; 155:4; 161:20, 25; 162:3; 164:12; 175:3; 191:10 witness [14] 6:6, 22; 7:2, 6, 20; 10:22; 11:10; 48:1; 56:12; 91:17; 140:8; 194:9, 11, 12 witnessed [1] 136:10 witnesses [1] 169:10 won't [1] 175:14 word [4] 15:16; 44:6; 94:4; 103:11 words [4] 27:25; 64:23; 83:17; 181:11 work [4] 33:8; 56:10; 57:21; 190:20 worked [6] 22:5; 30:23; 31:8; 46:5; 85:24; 125:1 working [11] 25:21; 26:8, 12; 27:19; 42:15, 16; 45:15; 51:18, 20; 133:13; 190:12 World [5] 6:23; 7:3; 9:1; 12:3, 5 world [1] 19:11 wouldn't [4] 158:10; 162:15; 163:13; 193:4 WRIGHT [3] 6:6; 11:14; 194:7 JAMES D. WRIGHT Wright [65] 6:14, 21; 7:1, 5, 9; 10:9; 11:21,24; 17:12, 14; 20:11; 63:10; 68:6; 73:15, 22; 76:18, 23; 84:15; 87:4, 6; 89:3, 8; 91:1, 2; 92:1; 96:17; 100:19; 112:12; 114:13; 115:10; 117:7; 122:15, 21; 130:23; 135:15, 25; 136:3, 14; 139:15, 18; 140:8; 148:8; 152:17, 18; 154:21; 156:23; 160:5, 10; 164:6, 7; 165:4; 166:6; 170:24; 174:16; 175:19; 176:25; 179:3; 180:11; 182:1; 185:10; 186:21; 188:13; 191:7; 193:12 Wright's [1] 7:25 writing [5] 71:9; 93:23; 121:10; 124:4; 160:15 written [1] 124:8 wrong [5] 48:17; 139:22; 140:7; 178:8; 190:21 yours [1] 30:19 yourself [5] 66:7; 107:18; 112:19; 129:13; 132:14 yourselves [2] 98:25; 99:7 zero [1] 46:10 - Y- Yeah [28] 15:21; 19:8; 21:12; 26:11; 29:8; 41:17; 52:23; 55:10; 56:3; 57:17; 65:21; 79:5; 91:24; 99:9; 107:23; 133:24; 136:9, 17; 140:9, 11; 143:23; 144:14; 151:16; 167:16; 172:9; 174:21; 180:20; 187:13 yeah [6] 55:18; 59:1; 64:22; 73:13; 79:13; 160:14 year [10] 20:15; 21:11; 22:16, 17; 112:24; 129:9; 133:2; 146:4; 167:5; 192:21 year's [2] 170:4, 8 year-by-year [1] 124:9 year-end [1] 81:11 year-to-date [2] 185:18, 25 years [21] 16:1, 7, 17; 18:15; 19:2, 3, 4, 6; 24:21; 33:14; 41:9; 52:20; 53:10; 55:21; 56:1, 8; 65:11; 91:5; 130:2; 180:21; 181:21 Yesterday [2] 14:24; 123:18 yesterday [9] 7:16; 9:4, 18; 14:25; 96:9, 13; 99:18; 114:20, 24 York [34] 21:17, 20, 21, 23; 22:5, 7, 13; 25:1; 26:14, 16, 18, 19; 27:12; 28:5, 6, 22, 24; 29:12; 30:19, 22; 31:15; 32:21, 24; 33:25; 34:3; 39:15; 41:19, 25; 44:3; 56:20; 59:7, 21, 22; 146:4 You'll [1] 93:1 JULY 30, 1998 MAERTIN v ARMSTRONG Look-Soe(5S) From withdraw to zero TOWOLDMON0051512 TOWOLDMONOQ51513 A/3. T'/JMJ Aw t> lU'7~^/^f A$4 -///2 A&d- yj A J A/ ^\- ?- / S'^ " 7 ; 'r.M. >4^ 7///, ///V -;A/,f_____ 1 ^4^ Vt,j'vAs -^<Wf /U/y)~ /&<? ^/d>(f - 7^ _____ ... -_____ ,Jz^- y^Au//tWZ Si//, /^jder s/yf - z/7/ - EXHIBIT . 1t TOWOLDMONOQ51514 TOWOLDMONOQ51515 DUANE MORRIS & HECKS CHER, a Pennsylvania Limited Liability Partnership By: Nolan N. Atkinson, Jr. (NNA 9315) Craig F. Turet (CFT 1718) 51 Haddonfield Road, Suite 340 Cherry Hill, NJ 08002-4810 (609) 488-7300 Attorneys for Defendant/Third-Party Plaintiff, Armstrong World Industries, Inc. UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY JOAN MAERTIN, Executrix of the Estate of Lothar Maertin, JOAN MAERTIN, individually and in her own right, et al. v. ARMSTRONG WORLD INDUSTRIES, INC. v. MONSANTO COMPANY, AMERICAN MINERAL SPIRITS COMPANY and SOLUTIA, INC. Civil Action L-95-cv 02849 (JBS) Simandle, U.S.D.J. Rosen, U.S.M.J. NOTICE TO TAKE DEPOSITION AND PRODUCE DOCUMENTS DIRECTED TO J. D. WRIGHT TO: Christopher M. DiMuro, Esquire Latham & Watkins One Newark Center Newark, NJ 07101-3174 PLEASE TAKE NOTICE that the pursuant to Rule 30 of the Federal Rules of Civil Procedure, Defendant and Third-Party Plaintiff, Armstrong World Industries, Inc. ("Armstrong") will take the testimony by deposition upon oral examination before a person authorized to administer oaths, on Thursday, July 30,1998 at 9:00 A.M. (Pacific Time) in the Law Offices of TOWOLDMON0051516 Parr & Younglove, 924 E. 7th Avenue, Suite A, Olympia, Washington and to continue from day to day thereafter until completed, with respect to the subject matter of this action, at which time and place the deposition of Monsanto will be taken by and through J. D. Wright. As counsel for Monsanto, you are requested to arrange for the attendance of J. D. Wright, and are invited to attend and cross-examine. ' PLEASE TAKE FURTHER NOTICE that, at the time and place specified above, J. D. Wright is directed to produce all of the following documents, in accordance with the Definitions and Instructions attached hereto as Exhibit "A": 1. Any and all documents authored, generated, received or reviewed by J. D. Wright that refer or relate in any way to PCBs or PCB-containing products, sold for use as plasticizers. 2. Any and all documents authored, generated, received or reviewed by J. D. Wright that refer or relate in any way to the withdrawal by Monsanto (or decision to withdraw) PCBs or PCB-containing products from the market for open applications. 3. Any and all documents authored, generated, received or reviewed by J. D. Wright that refer or relate in any way to sales of PCBs or PCB-containing products by Monsanto to Armstrong World Industries, Inc. 4. Any and all documents authored, generated, received or reviewed by J. D. Wright that refer or relate in any way to sales of PCBs or PCB-containing products by Monsanto to American Mineral Spirits Company (AMSCO). 5. Any and all documents authored, generated, received or reviewed by J. D. Wright that refer or relate in any way to sales of PCBs or PCB-containing products by Monsanto to customers through American Mineral Spirits Company (AMSCO). TOWOLDMON0051517 6. Any and all documents authored, generated, received or reviewed by J. D. Wright that refer to, relate to or reflect the terms of any distributorship or other agreemeent between Monsanto andAmerican Mineral Spirits Company (AMSCO) at any time between 1960 and 1975. 7. Any and all documents (including, but not limited to, calendars, diaries or date books) that refer to, relate to or reflect the activities of J.D. Wright while employed by Monsanto at any time between 1960 and 1975. 8. Any and all documents authored, generated, received or reviewed by J. D. Wright that refer or relate in any way to meetings or communications between representative(s) of Monsanto and representative(s) of Armstrong between 1960 and 1975. 9. Any and all documents authored, generated, received or reviewed by J.D. Wright that refer or relate in any way to meetings or communications between representative(s) of Monsanto and representative(s) of American Mineral Spirits Company (AMSCO) between 1960 and 1975. DUANE, MORRIS & HECKSCHER LLP DATED: July 27, 1998 ______________________________ By: Nolan N. Atkinson, Jr. Craig F. Turet 51 Haddonfield Road, Suite 340 Cherry Hill, NJ 08002-4810 (609)-488-7300 Attorneys for Armstrong World Industries, Inc. TOWOLDMON0051518 EXHIBIT "A" - DEFINITIONS AND INSTRUCTIONS As used herein, "document" or "documents" means, by way of illustration and not by way of limitation, the following items, whether printed or recorded or reproduced by any other mechanical process, written, produced by hand or produced by or stored in a computer, regardless of origin or location: books, records, communications, reports, correspondence, letters, telegrams, memoranda, summaries or records of telephone conversations, summaries or records of personal conversations or interviews, applications, booklets, brochures, catalogues, circulars, magazines, pamphlets', periodicals, bulletins, instructions, minutes, other communications (including, but not limited to, inter- and intra-office communications), purchase orders, bills of lading, bid tabulations, questionnaires, surveys, contracts, agreements, options to purchase, memoranda of agreements, assignments, licenses, books of account, orders, invoices, statements, bills, checks, vouchers, ledger sheets, accounts, journals, canceled checks, bank statements, bank passbooks, confirmations, statements of accounts, analyses, diaries, graphs, notebooks, charts, tables, working papers, plans, indices, summaries or records of meetings or conferences, summaries or reports of investigations or negotiations, opinions or reports of accountants or consultants, data sheets, data processing cards, photographs, photographic negatives, phono-records, tape recordings, discs, wire recordings, transcripts of recordings, drawings, motion picture film, advertisements, press releases, drafts, and marginal comments appearing on any such documents, all other written or printed matter of any kind, or any other and all other data compilations from which information can be obtained and translated if necessary. Each request for a document or documents shall be deemed to call for the'production of the original document or documents to the extent that they are in or subject to, directly or indirectly, the control of Monsanto. In addition, each request should be considered as including all copies and to the extent applicable, preliminary drafts of documents which, as to content, differ in any respect from the original or final draft or from each other (e.g., by reason of handwritten notes or comments having been added to one copy of a document but not on the original or other copies thereto). As used herein, the term "PCBs" shall mean Polychlorinated Biphenyls, and the term "PCB-containing" shall mean consisting of, including, or containing PCBs. TOWOLDMON0051519 CERTIFICATE OF SERVICE I, Craig F. Turet, certify that a true and correct copy of the foregoing Notice To Take Deposition And Produce Documents Directed To James Beightol was served on all counsel of record on this 25th day of Maroh, 1998 via facsimile (to counsel for Monsanto only) and firstclass mail to all counsel, addressed as follows: Christopher M. DiMuro, Esquire Latham & Watkins One Newark Center Newark, NJ 07101-3474 Carolyn O'Connor, Esquire Wilson, Elser, Moskowitz, Edelman & Dicker Two Gateway Center Newark, NJ 07102-5311 Brian O'Connor, Esquire Atrium II, Suite 101 3000 Atrium Way Mt. Laurel, NJ 08054 PH2V256408.1 Craig F. Turet TOWOLDMONOQ51520 TOWOLDMONOQ51521 SALES SUMMARY ALL PCB CONTAINING PRODUCTS AMERICAN MINERAL SPIRITS - CONSHOHOCKEN, PA 1954 - 1977 1954 - 1957 " Sales books are incomplete for these years. 0 lbs. 1958 - 1963 1 ' No sales found for these years. 0 lbs. 1964 Aroclor Dist. Aroclor Dist. Aroclor Dist. Aroclor Dist. Aroclor Dist. Aroclor Dist. Aroclor Dist. 1221 1232 1242 1248 1254 1262 1268 1965 '. ` ' r1 ' ' ' / 1,000 lbs. 80,000 lbs. 25,000 lbs. 27, 000 lbs. 209,000 lbs. 29,000 lbs . 16,000 lbs. + k k k Aroclor Dist. Aroclor Dist. Aroclor Dist. Aroclor Dist. Aroclor Dist. Aroclor Dist. Aroclor Dist. 1221 1232 1242 1248 1254 1262 1268 ' 500 lbs. 41,250 lbs. 31,100 lbs. 55,425 lbs. ' 230,940 lbs. 6, 000 lbs. 25,000 lbs. 1966 Aroclor Dist. 1221 Aroclor Dist. 1232 Aroclor Dist. 1242 Aroclor Dist. 1248 Aroclor Dist. 1254 Aroclor 1260 10% TOL Aroclor Dist. 1262 Aroclor 1262 10% TOL Aroclor Dist. 1268 2, 600 lbs. 43,400 lbs. 34,373 lbs. 48,000 lbs. 310,200 lbs. 3, 000 lbs. 0 lbs. 39,850 lbs. 28,000 lbs. t t HAE 001073 * Sales for these years are rounded to the nearest thousand pounds. Sales less than 500 pounds are recorded as 0 pounds sold. t See Invoices ff 4 E X H i BIT WKl k HT7 O' TOWOLDMONOQ51522  AMERICAN MINERAL SPIRITS - CONSHOHOCKEN, PA * PAGE 2 1967 Aroclor Dist. 1221 Aroclor Dist. 1232 Aroclor Dist. 1242 Aroclor-Dist. 1248 Aroclor Dist. 1254 Aroclor 1254 10% TOL Aroclor 1260 10% TOL Aroclor Dist. 1262 Aroclor 1262 10% TOL Aroclor Dist. 1268 0 lbs. 28,000 lbs. 54,000 lbs. 57,000 lbs. 316,000 lbs. 3,000 lbs. 0 lbs. 116,40G lbs-. 15,000 lbs. 6, 400 'lbs. t t t 1968 Aroclor Dist. Aroclor Dist. Aroclor Dist. Aroclor Dist. Aroclor Dist. Aroclor Dist. 1232 1248 1254 1260 1262 1268 19,250 lbs. 38,000 lbs. 309,000 lbs. " 600 lbs. 120,000 lbs. 3,000 lbs. 1969 Aroclor Dist. 1232 Aroclor Dist. 1242 Aroclor Dist. 1248 Aroclor Dist. 1254 Aroclor Dist. 1260 Aroclor 1260 10% TOL Arolcor Dist. 1262 Aroclor Dist. 1268 10,450 lbs. t ' 51,600 lbs. Jr 52,800 lbs. * 444,600 lbs. Jr 9, 600 lbs. Jr 5, 000 lbs. t 204,600 lbs. 8, 400 lbs. Jr * 1970 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1260 10% TOL Aroclor 1262 Aroclor 1268 1971 Aroclor 1221 7,280 lbs. 1,100 lbs. 117,600 lbs. 39,600 lbs. 518,580 lbs. 1,200 lbs. 29,400 lbs. 229,800 lbs. 18,800 lbs. t t t 10,400 lbs. t MAE 00107* * Sales for these years are rounded to the nearest thousand pounds. Sales less than 500 pounds are recorded as 0 pounds sold. t See Invoices. TOWOLDMONOQ51523 AMERICAN MINERAL SPIRITS - CONSHOHOCKEN, PA 1972 - 1977 No Sales found for these years. PAGE 3 0 lbs. HAE 001075 * Sales for these years are rounded to the nearest thousand pounds. Sales less than 500 pounds are recorded as 0 pounds sold. t See invoices. TOWOLDMONOQ51524 TOWOLDMONOQ51525 SALES SUMMARY ALL PCB CONTAINING PRODUCTS UNION AMSCO - PHILADELPHIA, PA 1954 - 1977 1954 - 1957 - Sales books are incomplete for these years. 0 lbs. J.958- - 1969 . , ... ' No sales found for these years. , 0 lbs. 1970 Aroclor 1254 SHIPPED TO: 1971 - 1977 156,600 lbs. PECORA CHEMICAL CORPORATION -fjIctCi C Lt'x'h No Sales found for these years. 0 lbs. MAE 000523 TOWOLDMONOQ51526 sm'\ kk'P* ORT B1476-A W 01/14/71_________ ORGANIC DIV - PLASTI_CUERS_ _ NO. 4* "CUS TO ME A/P~RODUCT * SALES REPORT' lFOR " DEC 1970 -IN ACTUAL POUNDS AND frOLLARS- PAGE --1-139 TOTAL MONTH SALES Y-T-O'' " SALES ' PfiUNPS OSLLAaS. ______ PflONflS ____ DOLLARS TOtAL LAST YEAR SALES POUNDS DOLLARS TOTAL YEAR CUST ID GOAL LUS MAJA-GRD-GP I I c MAE 00052*1 AM MIN SPIRIT PHILADELPHIA PA 5715 AROCLOR 1254................................. ......................... .......... , , .. ___ 156.400 27,266 AR "023266 10004276 1040-280-04 ' TOWOLDMONOQ51527 0Ni> Li 1 L31 -- A 0IReC 1 01/127/2 O M C K S*.S A NAME OF PRODUCT/CUSTOMER AROCLOA 1254 ORGANIC DIVISION SPECIALLY PRODUCTS PRODUCT/,CUSTOMER SALES REPORT I FOR 1971 PAGE 290 LJWU KMtNKW. rtAJi FOACUML ***** tfil cu**. JAN. - FEE. ' MAR. APR. MAY JUNE JULY- AUG. SEPT. OCT. NOV. DEC CUM. uo / MJUA-CAO-CP. 003 >1A 1040-280-1- I l |5l}0Cj UNION AHSCO PHILAOEL PA '| [ 1571 | I I I I I I I I I I I I I iU~0042T&_'1 HAE 0 0 0 5 2 5 TOWOLDMONOQ51528 CO 220 t-** MONSANTO COMPANY VWJOl/JWO/Mli/Haa/a/ZIZM/FH/QZQ^ iRijmormsr oftrtwkrr j oAFt cttTKhtfl bbBYfiUtivi-OAoCTTWr 5642 19 mrn*------ VL C/30/70 206-423C T 30 DAYS 'niPAlb o* coujtcr-ftouTIffir atS5 <?p J ( dkivk*Y~F. 0.1." MALONE-CR ANNISTON ALABAMA IriiMZD FROM WHJ. '406IT booked thru ANNISTON 09 53-07--5 7-15 ORQ DSOS Shipping 4 INVOICK OATC TRv^Tc dAtk SHIPPED CA iNITIALi Aub 1^-10 COPIC* COOC 2-1-2 5uIT7" FOAM S HANKS OAMERICAN MINERAL SPIRITS COMPANY 23268 ' A DIVISION OF UNION OIL COMPANY OF CALIFORNIA 3100 SOUTH MTACHAM ROAD .' o PALATINE ILLINOIS 60067 IfPECORA CWCMICAL CORPORATION ;300-4 00 V SEDGLEY AVENUE 'l PHILADELPHIA PENNSYLVANIA 1/13/0 SEND COPY OF SILL OF LADING TO MR KEN DALEYAMSCff COLVELL5PL10IE-CONSHOHQCKEN PA 19428- ADVISE S MANN3-VILH OFFICE IF WE CANNOT MEET SHIP DATE- CUSTOMER HAS ADVISED MALONE OF PICX UP u . c o N MAE 000526 TOWOLDMONOQ51529 CO 220 JJU Rm MONSANTO COMPANY miMCA'i war OltTntCT bATK CHTXrtltB 564220 WL 6/30/70 Ytwa------------------------------------------------------------------------------------- *T 30 DAYS UAT6mR' order no. 206-424C ORG DSOS ' ~THvaiet OAT* iNVOtCC NUMoVr 1- OATt SHIPPED CAR INITIALS ANO NO. fsnjvrxv MALONE-Cfl A NS I ST OH ALABAMA 4hIM fmh---------------------------------------- ANNISTON WHtiC. OOOC OS bOOKCD THRU 53-07--57-15 copies cods 2-1-2 | OUST. | S MANNS SAPERICAN MINERAL SPIRITS COMPANY 23268 A DIVISION OF UNION OIL COMPANY OF CALIFORNIA 3100 SOUTH MEACHAM ROAD PALATINE ILLINOIS 60067 TPECORA CHEMICAL CORPORATION 300-400 V SEDGLEY AVENUE PHILADELPHIA PENNSYLVANIA 36 "33 11 DESCRIPTION JSftf- 600 LB DR "'ROCLOR 1254 104 0-280-04-09 30 LESS DISTRIBUTOR DISCOUNT 5 PCT PLUS FRT FROM ANNISTON ALABAMA AT MALONE RATE ) CXPCCT TO SHIR T 7/1V70 JOMM. s I--tHintikd 6/T ARRIVAL OAtT -SHIP JULY 17 SEND COPY OF BILL OF LADING TO MR KEN DALEY- - ARS'CO^'COLV^LLSPLANE^COISHOHOCKEN PA 19428- ADVISE S MANNS-VILM OFFICE I IF VE CANNOT MEET SHIP DATE- CUSTOMER HAS ADVISED MALONE.OF PICK UP YJ. MAE 000527 TOWOLDMONOQ51530 CO 220 l~U Am MONSANTO COMPANY VUH9U/JM30/141 6/1433/2/Z1206/FH/QZQ ImipFIH' HO.------- rij|(Hi0r| OATI JfNttnu} I CUlVOMM'l OHBIB 3 64221 TEAM* VL 6/30/70 206-423C SET 30 DAYS ORQ D30S tHTFFIBTKSn ANNISTON "whSET^SEI- ftOOKCO thru 09 33-07--57-15 r COTICS COOK 2-1-2 CUST. rORM sjia Ms A DIVISIOM OF UNION OIL COMPANY OF CALIFORNIA '3100 SOUTH MEACHAM ROAD . i PALATINE ILLINOIS 60067 ?---------------------------------------------------------------------- fPECORA CHEMICAL CORPORATION ;300-400 V SEDQLEY AVENUE ! PHILADELPHIA PENNSYLVANIA oncmmoN - ( IxuJj >0 - 600 LB DRUMS-30 'ROCLOR 1254 104 0-280-04-09 LESS DISTRIBUTOR DISCOUNT 5 PCT. l*LUg"FHT FROM ANNISTON ALA5-ANA AT--MALONE RATE--` .B 7/22/70 KXPSCT TO SHIP T 1/22/70 ..SlJlF 30 kzA""'VALDATt 3END COPY OF BILL OF LADING TO MR KEN DALEY- c AMSCO' COLllELLSPLAHE-bONSHOHOCXEN PA 1942H- ADVISE S MANNS-VILM OFFICE 1 IF VE CANNOT MEET SHIP DATE- CUSTOMER HAS ADVISED MALONE OF PICK UP V. MAE 000528 it; TOWOLDMONOQ51531 CO 220 J-** R~ MONSANTO COMPANY VUW904/JH30/1423/144 1/2/Z1203/XR/QZQ AHIPPCA't NO. OATt UNTCMCD 564222 TCTOT VL 6/30/70 205-42 SC s VT 30 DAYS mr T=*S0TTOa &tUVUW7.6.1'. nmonz*ar AKNISTON ALABAMA iHtrriB nWW------------------- WHIL CO&4 booKCb thru awniston 09 53-07--3 7-13 ORG DSOS Shipping . "FWvSItl 6ATC invoice Nuwain S "BATt IMiPFKO ^AB"IHITIAU AND HO. ^r--7Q cone* coo* 2-1-2 "FcOuRlMt. S MANNS AMERICAN MINERAL SPIRITS COMPANY 23263 A DIVISION OF UNION OIL COMPANY OF CALIFORNIA 3100 SOUTH MEACHAM ROAD . PALATINE ILLINOIS 60067 "PECOR A CHEMICAL CORPORATION :300-400 V SED6LEY AVENUE PHILADELPHIA PENNSYLVANIA DESCRIPTION y k 6 - 600 LB DR0MS-30 NR 0 CL OR 1234 1040-2 30-04-09 LESS DISTRIBUTOR DISCOUNT 3 PCT PLUS FRT FROM ANNISTON ALA8AMA AT MALONE RATE 572^ SWCO LBS .B Z/27/70 _ AfimVAL OAT4^ SEND COPY OF BILL OF LADING TO MR KEN DALEY- c AMSCO 'C'CiLvfeLLSPL'A'nE-CONSHOHOCKEN PA 19428- ADVISE S MANNS-VILM OFFICE IF VE CANNOT MEET SHIP DATE- CUSTOMER HAS ADVISED MALONE OF PICX UP MAE 000529 n TOWOLDMONOQ51532 "'is*........ " Monsanto ' 'EjHL 0/UV433/0C06/0740/074 l/2/EIiCQZMZ2LDORG DSPS Nirrcrva no. oilrmCT OATfe CHTCRKD anTOMM'foflOln no- , INVOICC DATC inVoicc numscr \ 564811 TtftM* VL 10/6/70 022-501__________________ OATt IHlPflO CIA INITIALI ANfl HO. ---------- o NMEOTAI63M0l MJ3>UAjYtCST7*OTnRa----------- ~ I0/6/7C COLLECT DCLIVCRY>. o. *T Annioton Htr o/o Admiral Ma-rchgota ANNISTON WHIK. C60T sskhttord 09 53-07--37-15 corn*com 2-1-2 foam S MANNS ^AMERICAN MINERAL SPIRITS COMPANY 23268 `-A DIVISION OF UNION OIL COMPANY OF CALIFORNIA 3100 SOUTH MEACHAM ROAD ' "PALATINE .ILLINOIS 60067 Vharleco chemicals. l;60TH AND WOODLAND AVENUE PHILADELPHIA PENNSYLVANIA DiscnirrioN rmci k unit 10 - 600 LB DRUMS-30 STEEL AROCLOR 1254 . L- 104 0-2 80- 04 - 09 LESS DISTRIBUTOR DISC 5 PCT 6500- 500- 6000 6000 LBS NON-RTTURNASUK RCTURNAU.K CONTAINERS 10/6/70 kxpCct ro hip 10/6/?0 V PRIC* - -- .......... -- / HIPPING OATS ARRIVAL DATE . 8--CI! : THIS TRIP'ME NT APPHo'VED BY W S'CLARK. lELECTRICAL GRADE AROCLOR 1254 " IF NECESSARY RELABEL ' I (J/- C n.. O MAE 000530 TOWOLDMONOQ51533 TOWOLDMONOQ51534 SALES SUMMARY ALL PCB CONTAINING PRODUCTS ARMSTRONG CORK COMPANY - LANCASTER, PA 1954 - 1977 1954 - 1957 Sales books are incomplete for these years. 1958 Aroclor Distilled 1260 1959 No sales found for this year. 1960 Aroclor Crude No. 2565 Pydraul F-9 1961 - Aroclor Distilled .1242 Aroclor Distilled 1254 1962 ' Aroclor Distilled 1242 Aroclor Distilled .1254 1963 No sales found for this year 1964 Aroclor Distilled 1254 1965 Aroclor Distilled 1254 Therminol FR-2 1966 Aroclor Distilled 1248 Aroclor Distilled 1254 Therminol FR-2 0 lbs. 150 lbs. 0 lbs. 0 lbs. * 0 lbs. * 0 lbs, * 0 lbs. * 400 lbs'. 50 lbs. - 0:-lbs. 1,000 lbs. * 2,160 lbs. 9,000 lbs. 165 lbs. 2,460 lbs. 1,200 lbs. MAE OOOOOl Sales for these years are rounded to the nearest thousand pounds. Sales less than 500 pounds are recorded as 0 pounds TOWOLDMONOQ51535 ARMSTRONG CORK COMPANY - LANCASTER, PA 1966 cont. Therminol FR-2 1967 Aroclor Distilled 1254 Axoclor Distilled 1262 Aroclor Distill.ed 4465 Montar 1 Pydraul F-9 1968 Aroclor Distilled 1254 1969 Therminol FR-2 Aroclor Distilled 1254 1970 . Therminol FR-2 ' Aroclor Distilled 1254 1971 Therminol FR-1 1972 - 1977 No Sales found for these years. ' PAGE 2 600 lbs. 5,220 lbs. 60 lbs. 150 lbs. 500 lbs-. 54 lbs. 11,400 lbs. 1,2(70 lbs. 60 lbs. 4,200 lbs. ' 60 lbs. 3,000 lbs. 0 lbs. HAE 000002 Sales for these years are rounded to the nearest thousand pounds. Sales less than 500 pounds are recorded as 0 pounds sold. TOWOLDMONOQ51536 TOWOLDMONOQ51537 Your guide to... TOP-QUALITY PLASTICIZERS 6 Here are plasticizers and resin modifiers for any and every resin system! No matter what the application or performance specifi cation, one or a combination of the plasticizers offered here will do the job. As shown here, you can select from the widest choice of plasticizers available from any single source. They are recommended for use in compounding: Flexible Film and Sheeting Adhesives Lacquers Sealing Compounds Paints Casting Compounds Extrusions Plastisols Fabric & Paper Coatings YOU CAN DEPEND UPON THESE PRODUCTS' QUALITY AND PERFORMANCE open once (or "Competibilily" guide open fully lor lilting o( products end propertiet MAE 059457 * ; EX H I BIT i YYCiCiA cp urTY 6Q ISOONOlAiaiOA/iOl PHTHALATHS Plasticizer-Resin I 3 > TMV0cv i 50 TJZv 4J O >u4>x ?fc*l 5 > D *D C T 41 E 2> * .cV I jTac1C1 50 5 S-< 1H I % C 5 0 V) i1n0 1 c 3 m (V 2 c CmO CM H c A in N M c <3 CCIDMM M 2 M IJ M cc inn A ro s 8 10 N tM c M c A <3 m<0 ItNDn m 0 Nt CH m 2 -V 5 X c c ~c. Aa A 8 1 V c A m s t 1 c A Polyvinyl Chloridt jjJ Polyvinyl Acillti j Polyvinyl Butyiil > PolyYinyWini CMoiidt Polyjtyrini i 30 1 IM IM 1 100 IM so IM ICO IM IM IM IM IM IM IM IM IM IM IM so IM ICO SO 100 1 1 IM 1 1 70 1 IM 1 10 1 1 40 1 1 1 1 1 1 1 1 IM 50 50 25 15 50 15 15 50 25 IM 10 50 20 30 TO 25 25 25 25 20 25 5 20 75 20 75 10 25 50 25 25 20 10 75 50 25 10 15 25 15 20 25 25 10 25 20 10 ICO 20 100 IM IM IM 100 50 70 IM IM IM 75 75 IM SO IM IM IM IM 75 KO to 75 `Nitroctllulori IM 50 100 IM IM 60 IM IM SO IM IM IM 40 40 40 IM IM IM 50 40 40 IM 70 40 -- Ethyl Cillulost 100 50 100 IM IM IM 100 IM 30 IM IM IM 75 75 IM IM IM IM IM IM 75 IM SO 75 <S 5> Cellulou Actlill 25 1 SS 1 1 SO 1 1 1 1 10 1 1 1 1 1 1 1 1 1 1 1 1 1 _J " 1 u CiIIuIom ActUU Bulyrite IM 20 100 50 50 IM 50 50 20 50 IM 50 40 20 40 50 50 40 25 30 20 50 35 20 Ctlluloic Actlitl Ptopionilt 33 10 100 15 20 IM 20 20 10 15 SO 50 20 5 1 25 20 40 5 10 5 20 5 5 CMoriiuled Aubtxf Hi|h Styttm-BuUdiint O V] -------- -- z J Pioltfn Compound* 5 ul SillltK U) tu I Actylic Typo Rtsfai Polyimidij IM 20 25 IM IM 25 50 S3 20 IM 10 IM 25 25 IM 30 IM 50 IM IM 25 IM IM 25 50 20 25 50 50 20 SO 50 20 50 50 50 40 40 40 50 50 50 40 40 40 SO 35 40 | 20 1 20 1 1 20 1 1 1 1 10 1 1 1 1 1 1 1 1 1 1 1 1 1 1 15 1 15 1 1 1 1 1 1 1 1 1 1I 1 1 1 11 1 1 70 25 IM 25 25 IM 25 25 25 25 70 25 15 1 20 70 25 25 10 10 I 25 1 1 25 10 1 20 25 1 25 25 10 20 25 25 1 1 S 20 20 20 1 1 1 20 25 1 Polyeiiir 20 20 10 15 20 5 20 20 20 15 20 20 5 5 5 15 10 15 5 5 5 10 5 5 Epoiy 25 10 10 1 1 1 1 1 10 1 25 10 1 1 1 15 1 10 1 1 1 1 1 1 O------------------------------------- - p Phenolic SO 25 25 25 25 25 25 25 33 25 50 50 25 25 25 25 25 25 25 25 25 25 25 25 b g Alhyd 70 25 25 25 25 25 25 25 25 25 50 SO 25 25 20 25 25 25 25 25 25 25 25 25 2 ------------------------------------- Milimint 11 1 1111 I 1 1 11 1 1 1 111 111111 h Polyuiilhim 25 10 15 25 25 15 25 25 13 25 25 25 20 20. ` 20 25 25 25 20 20 20 25 20 20 Nilrile t Heopunt Rubbers 100 50 IM 33 IM IM IM 50 53 33 IM 50 50 50 40 70 50 50 50 50 50 50 (5 SO I - ImwnpJliWi Fituf - Comptlibilily, PUR MAE 059451 69*650 3VW sno3Nvn30siw XN3NVWH3J saivnooAio ssaiwvNOJins lAIVHiHd S31VHJS0HJ S31VdlQ spins foumedwos TOWOLDMON0051540 Vipor Prtiiwi (mm HgJ _J_________ rT (mI 760 mm. Hf) at ISCTC al20CrC at300X *t ox VHarsity (cantt*tp*ri) _^L_ mi 25*C Thermal- 1 Surface Tension Expansion Coelfic+ent t 2<rc (ticrtQ4<ro at 98.9"C (dyn**/cm.) <cc/ccrC) * Specification Flash-Point FVt Point (C.O.C.) (C.O.C) CO m - Alley (*tar Coolant) (%) Sol fur (Coppertrip tast) In water (at 2SX) (%) w 1 mwin << --. Hi) r* tmmtsMi m.is> m la t . Hi) m H) t MIS < *A3 11 mwKf llwm.NI M At <} m llSmm. N) 3 _ -- -- -- IS _ .It l lit 1SJ -- _ _ _ -- -- -- -- M M 35 1.1 H m _ -- -- -- - 23 ' 12 17 -- 7 t.l 7M U.l __ in -- _ -- -- -- -- -- -- 3S -- M _ -- -- _ 14 _ -- -- -- - Ul __ ii.i tut 1771 14 _ lai _ 1100 _ TSOI -- -- _ CM _ 400,1 4SM 73M -- 1- ISC _ II It 0 sse ii. IX 30 __ ICO 41 1 4SI 17.1 71.4 (J7.T"C) n >4.3 (J7J*C) 0.1 CIA SO -- -- -- -- 2.4 __ 14 K 43 14 4J _ 1 _ 1.1 -- 4.S 4.3 S3 SA 4.4 43 4J -- -- -- -- IS XI (7S*Cf) 733 tJ-C) n -- K 0.000 71 _ - 1.00074 I OC071 0.00011 <* I* 30-C) 11 33 (73*C) __ -- mi <n*o _ 131 (34*C) 111 (74*C) _ M3 (73*C) -- _ -- -- -- -- -- 00071 1 0*074 _ OOOM 0.00031 _ 1.00031 -- .00074 OOQ74 1.00074 . -- M0 403 303 ISO 430 304 4 IS 4?S m 434 7n yy IIS its 413 471 411 313 379 3*3 -- -- -- 313 US 333 370 410 US _ 4M _ -- -- 113 3SS -- 3(3 -- -- -- -- -- -- -- -- M mi*. -- toot iirti *110 an. 9i mi*. mJr*. ! 101 It.t ml* -- Nt4ire hiirili* NcfaHva <1 M lO-Ci <0003 <1 4 (3T*C) __ Ml* III _ -- -- -- -- -- -- _ _ -- -- -- -- -- _ _ -- -- Nffilrn _ _ _ <003 <0A1 - 0001 |M`CI <003 PfactxjJlr rractoHy fitcictlf Wm4vM _ -- .. --_ _ __ -- __ _ __ ? (4 mm. Hi) 714 <S m. HO o - Ok --o J* m Bi - 7IC5H -- I1M$ J7* MS MO J2 IS* IM f.M 2.3 MS IM IM < Ml 7.1 J 1.1 1 IJ 1.4 >sm 0 47 7 M 11 3 0 - -- '-- 71 -- m (JW*> -- -- -- uo IM m -- -- 1730 -- 2MA 111 -- ". ih 771A l7tA 143 (17TT) 1.3 tj/.rc) 13 (373-C) WA 7.1 (Sit) DO 14.4 it i arci li WCI U 441 no 1.4 M 71 2.4 21 00077 00074 00071 M 44.3 11 -- o.oooy - U 47 O.QDOC7 Li X) (21*0 -- --U -- ti 000*1 iscoti T.I it _ 11 0.1 (73-C) - ---- 401 440 377 49 ~ _ 471 413 Or -- -- -- 49 aaaeJt OS __ 03 uo -- ui Its -- M MO - 3*C MO 3ao - _ - _ < M N(i4ifi _ <001 <Mf ___ <1 OBJ c1004 01 l>4*CI <003 -- oi` . 4 i`i - "TT"------------ | firs Nrf 0ol70r*ci ~ Mt I30"C) M0M1 IM-Q TOWOLDMONOQ51541  1______________ M *4 _ _ _ _ _ _ -- J45wm 361 WO -- - 1-- 1 -- 1 _ ---- -- -- -- -- '-- -- __ -- -- ---- -- --- - -- -- -- -- -- -- - 2 15 zw __ 11 mrc) -- u tare) __ 70.1 _ - 11.300 U 13.500 500 U 3.500 9.000 W 9.100 554 1171 4.U2 1M nj OT-r*c) _ 17.5 -- - ---- ---- --- ---- ---- ---- -- -- 00071 -- -- -- - tt.l (75*C) __ -- _ _ __ _ | - |- 555 -- 530 S7t 5*0 -- 475 5J5 US 535 575 MO 525 345 J75 575 373 575 - -- -- -- ~ -- _ _ |- -- - _ flj nkel*t * P'Ktioftr Fiacticrftf lw FfKlfoHf wvoh* PrKtioIf lnM rr*CtOf7 U _ Hrp*erk ; i I FLAME-RETARDANT PLASTICIZERS If you want products that resist burning, build your formulations with one or a combination of flame-retardant plasticizers. Monsanto's liquid and solid flame-retardant plasticizers offer a wide range of compatibilities. Other beneficial properties indude permanence, chemical re sistance, extraction resistance, flexibility and weatherablllty. Santldzer 140 Sanllcizer 141 Trlcresyt Phosphate Trlphenyt Phosphate 11 Arbdor* Plasticizers 6 M.ntar Compounds > m o Ul -e <h FDA REGULATED PLASTICIZERS Monsanto offers more FDA regulated plasti cizers than any supplier for use In compositions related to food packaging and handling, and for artides that come Into close contact with the human body. The following list of plasticizers offer you high specification standards of purity, low odor, minimum taste, flexibility, clearness and water resistance for applications such as: food-wrapping paper coatings, packaging films, label adhesives and Inks, beverage and blood tubing: Dloctyf Phthalate (high-water-content foods only) Dllsooctyl Phthalate (high-water-content foods only) Diethyl Phthalate Dloctyl (2-ethylhexyl) Adipate S.ntldzer 141 Santlclzer E-15 Santldzer R-l 6 Santldzer 160 SOLID PLASTICIZERS Choose from a variety of plasticizers lor use In adhesives, coatings and lacquers, foams, rigid compositions and films. Solid plastldzers decrease your hot processing time at reduced cost. During solvent processing, they require fewer surface-building coats and at less cost. For use such as delayed-tack and heat-seal adhesives and coatings for non-blocking films, easier processing of rigid plastics products, toughness of rigid foams, for even flow and uni form filling of resinous Impregnants. choose from the following: rwited l*T* It) Arodor 5442....................... Triphenyl Phosphate.......... .... 48.5 Montar 1............................... .... Sanllcizer 3.......................... Arodor 4465.......................... . . _ Santollte* MHP.................... Oicydohexyf Phthalate.... .... 63 Dlphenyf FTitholate............. .... 69 Montar 2.................................. Santicizer 1-H........................ ....82.5 Montar 3.................................. Montar 4................................. .... --Arocfor 5460.......................... Santlclzer 9............................ Montar 9................................. .... --Arodor 1268.......................... . . __ Montar 5................................. 46-52 __ 54_-160 60_-66 __ __ 70-170 __ 86-168 92-206 98-105 __ 130-175 150-170 155-195 TOWOLDMONOQ51542 T ~1--1 PUrttofetr Acktfty Mo^cvUf (m*4./100 WelfM trn m*x) App*rone PMTHALATE3 n\m 022 Owr. **r Ml i 1 I MrycWtvrrl KlnUrcrl no.41 272.11 4CC.CS MSA) mu U (rm^f mij 12 SJ2 s.ll lit Ml IK * 1.12 SiMkfcar* HO titkkif ICS SiaMtar 21) Unfextr 2|4 liatidm 7IS SMilcim 202 Si*ar* SO? Uun M3 iMttcitff US StibckN OI SiaUdnr U1 SMkuh U OaatfcimBI )wWi U) )iiji w JILTS _ _ _ _ J*3 _ _ -- _ -- 121 JI SJ7 1.12 IJJ * US *12 J7 III *112 uz uz 0.12 t.12 IJ1 0.12 ADIPATU K xSpctI Diae* **4J M (IWH J7t* * IJS |JS 4 021 ?HOS?HATES T krwyl m.u mjt 4 it*. * IM Uitdiw |4f Ixww Wi ln>iunii IntaM GLTCOtATES M2 His* -- Hitt M Mi* J li '1 1 11' itmntkm MS Sl iStfcir t-IC UmtMm M-IJ mj? 1MJ7 nu4 SULFONAMIDES ImbiXii i n nui 1 iwn All I.U 033 i an Omt. #*t Ml Oaar. ar MM * 0i, dr Onto Oor. a*r Ml * CM*. a*r Ml * CM. lr Ml ImaUdly *4H, tm*4 adlMii *M*Ar HM m Wm cU *OwMI CM. di Ml * CM, dr MM Omt. dr MM CM, dr hnl CM*. Mr Kill Qw, *Jr CM, dr Ind Oaar. a*r*a4 OMr.drMI CM.drtM CMdTMl * CM, dir Oa*to CM#, dr ft<M CM#. ir Ml * Oaar. Mr MM * CMr. Or MM M, *r mM CMr. lr Ml MtWn O-- o~. Mr u<aM 1 b. **r N*< CM#. Mr SMI' CM. Mr MM Onr.drMI !r > ,, . Kj r.-.. iu_. i__i___i -_______ _____ Co*or (APHA) (maximum) MWr* (KF In matr^nr*!) (% nrwxjmvm) Rafractto** lr>dx (at 2S*C) 70 __________________ _ US KM (awBaa) IS so *M f.l MS * MO 0.10 #21 SO 24 * ICO (TOM: 9fed KMr) wo 40 40 21 too WQ lop so log 70 40 lot H * 40 * 40 4 Ml 0.10 21 M 4 MS 4 M2 4 MS MS 4 0.11 4 S IS Ml *M 0.10 US #.ts M0 MO o.w SM. cW*e**rHtic 4 Mlmrti arwudc; itoH a+iTKrik. d*ractm*tk SU|H araMtfc. a. * Sti(M. tkaneteraSc * SEfM. dwractirfeUc. MX. * SMfM. mmOc, ait. 1.0J5W l.rns _ i.mu i.vdio umwiuw I.4JWWI.UM i.smw i.siu * SAffci (M#>darH6c 4 l.OWWlUJO SUfM. cMrvcUrifUc. mi, 1.00 U 1.4130 __ 4 O--r. cMcMiflc * d^Ktditk. mi. 3R<M (U4m to DOT) CMdaidc. yrj to* OMradaridk. TT to* CM*dWk -- CMr*arwbe .*M CMdftM -- --1 _ -- -- 1ST! (e J4*C) 4 l.ai) M 1.054 4 1.USU1340 4 1.4*4 U 1.4*7 4 1.S2I to 1324 * lytn to 1.<M 4 1300to I.H 4 uiitoi.sn * l.urtol.ac 4 1.40ZS to 1.4*91 4 130tS to I51S0 4 1.090 to 1.S04S 4 1.4*4 to 1.407 4 1.471 to 1.4*0 1.472 to 1.471 4 l.4*| to 1.4*0 SO u n MO M0 MO MM4 Cliractartottt 4 MU l.*4*J to 1.4 SIS 4 l.U4tol.4a 1.4*4 to 1.44* 4 7S 20 (aidtop 4 40 * 01 *n 1 tt 4 0.11 -- 0.1S ill 020 1*21 * S dr 4 Vary U< anadc. mm 1234 1360 ( OTC) 4 Cmi iQiff-f aiartoa 4 SHfM. m4 4 OweMXk, tmH * CXmmIiHMM ~ 1354 to 1370 DiTtoTSIi i.u4L l ut "'XStoTUi : 20 4J 4 10 | --me ,1.-) 1 -- O.IS * All 0.11 SS04.*m. * HdC danUMi 3HK dncii Ut, mi. l.t to l.oao lAUto l.att 1304 All I 1 -- >- SpMlfie Crv+ty (25725X) 4 1.K4 to I.0U 121 4 1.111 to MIS 4 OJA) la I.XI 4 0.900 to 1,003 4 l.ltl to 1.112 4 0.1U0 to rim 4 0.900 to 0.1*1 120 4 0.H* to I MS 4 uiitoi.in . 4 o.mtos.tto 4 1>40 to 1.041 4 o>a taf.no 4 0.974 to 1.100 1X1 to 1*57 0.971 to 0.977 4 0.977 to 0.1*7 4 0.907 to 094 4 1.904 to IM 4 OJ74 to 0.9*2 4 0.909 to 1.177 4 Ml to 0.171 4 0371 to 0.I 4 0.902 to 1.17) 0.914 to 1322 * 0.121 to 1377 4 1.117 to l.in 120* {00-/2rt) 4 1203 to 121) * I jo K. i mi * Ulf la l-Cd "nrRTUTTS 4 I.1M to MM 4 1X3 to MOS 4 1217 to 1277 1 ua 0*rt4tr (at 25X) CmUHi<n| Prco)^'l in C- ---- IJS <-SJ Its --S3 utia.cW i 121 >4) 9.12 so (to-r-c i>< LI . - Ml -- 36 tnri yM *tl> ---- 7.1) 9.) <-25 *21 IQ -- MU4 IT --OJ 1.1 Ml 121 U7 1 IS _ 1.11 ' 1*1 _ All - ' , ! | j 70S <-9S 7.0 --S ;.n <--71 9.7 <- j IIS i ----------------------------1 10 t.l ii in <-n | <rjj-----------------------i < ! 9 M 20 >4<|i A1S <-21 7020 <-- > j , 1 1 <to iwiu WUa) ^ ~ | -- TOWOLDMONOQ51543 , r^.I - ah: Th a-t< <*>) I - I f^-i trm*6+rt. -on *rn. rTM W~ yn: I w OH: g ua><-*<*.) I -- I I ini:rHi^iort^) I IJ> -- I -- _________ 1__12* Xawfeilpr 40 SiiHkirv 40 * 1.0 * I .) 1* * 10 . *00 1.1 1.24 Dot. Ilian Kwm4 4 CfeM.KftftU 4 Mft>lyyf<Ww.vhcwaltw4:omipMi<itpdwt 4 Pw.Wyfc^___________ * * Ovt.HJi * Qot. 9f __________________ 150 CV>W; )M ttX WI 0.15 ISO 00*: 50-J Y% iMi) 4 0.15 4 in iV)mi:v>mi n% rntMi) 4 1.15 4 too 1.1$ yoo 0.15 an 4 o.is 4m 4 0.15 OTHER Hl-40 TilpAair;! M**ipMa _ 119.29 _ 4 ox* (mf KCHI/t) 4 0.11 (mi RCW/i) rroctoWy wlirfw. mty l^iiJ 4 150 4 (Wy Ma m ((M-ydW* MW 4 50 * Oh m HM-r^W? ________________________ 4 50 4 in or* `- 4 OwocUrMk Y*t7 Im< edK * jA|*t. chjrdtmi< SMfM. <K*r>dwb<k SUfM. ifcar*drhtk SJrtM. dt*/4dertrfk SB***. durwtorfatk JpM. tAp/sctorfatic _ - i.m 1X54 1.1772 I.rHJ l.im 1.4751 4 lJOlSfe I.30M 1.X0Q to 1.5750 4 1.5(7 to 1 550 4 1.5(7 U 1.550 * 1.171 to | 13J 4 )A0 to 1 0*4 4 1.104 to t ill 4 i.an h i.04< 4 1.077 to 1.071 4 1417 b 1.101 4 1.045 to 1.052 9.41 * 941 170 177 IX -- 114 174 -- - 4 1.001 to 1 007 in"/l5V(J 117 4 I.m to 1.10 (30*/fS.S*C) j.n i.m it i.to otr/is.s-ci m 71 71 GENERAL PROPERTIES OF REPRESENTATIVE AROCLOR PLASTICIZERS AND RESINS (`MONSANTO SPECIFICATIONS) wurr Amptiki Clip*. Mlikma m o 4*J . Moca.00 1221 6 Da/. n*bil pM 14 APKA CM**W. ptt (ml 70.5-21.5 mt K0li/(. mriwim 1414 StRi. Fp*m, mtnimmm Atj, C+pRc**l f hnwlu. a/cc/*t 9.00071 m4.4rc) 5ho4< Cflnlr 1_________________________________ i 0Mr. hm4i prt liAm, 25*C *1.10.1.117 Ol'/BX) U5 DbKptto* *C. onxlil iMTto fr-24. MM) 771-3 1 Lrr* *^. 109*C. ( 4c*n <*3i^ 0-4. iM.) 1U*C. S lni| ru4 PU <C>**Lm4 0ri C**l. *C n>< iciinii.i 0.W cl -c 1.0-1--.5 HM54 tw-m m Ui lAJTR 0-171 tnim IW (A4IM l-rn. Hi acta* U4*M. *e *c .X! Ktorrji*ta*h)) " U17-I.III YHcmM*. Ui*+ IAJ1M 041) |*f IJTJ-C) TWf m.rcj *39-41 31-11 30-11 MOCIO0 1232 6 G/ar, MU tB 109MHA 11.5-O.S *0.014 9.00071 (IS'.WO-C) cn'/iu-o 19.15 WWtt 1.0-1.3 - 157-154 345-114 234 444 --31.5 -O -44 1.C4-I.G2 H4.JI 19-4I 11-0 M0C4.04 1243 6 opc. 9tt MOOMHA 42 1415 10 0.000(1 oi'-wo xju-ij* (75V15JX) UJO 30-3(4 0-0 4 1.0-14 175-110 344-354 0OC** --n 7 -- 1.B7-1471 nf7-5-t4t 34-35 ' A*00.04 12U 6 -cw. mtoUpM 100 MKA 4| *0410 14 040070 (TS'-tSt) *1.405-1.415 (B'/IU-C) 12.04 >44471 04] J.0-4.0 m-m 179-3*4 none m " 1434-1.131 115-244 1314--1370 Moaot 1254 6 lUlH W1 -W4 A3KA 54 -t.ll 10 9.00044 av-ti-c) 1.4T5-L305 w/ijj-c) 12J2 3U-39I t-0.7 I.1-1J AOHt Wt 19 50 -- -- I47UUI 1109-7540 2H40U-14|4 AA0CT.04 1254 + UjM-jtto, tkAf rr*K 150 ATMA to 1414 10 9.000(7 (74*. 100*C) I.SM-1344 (w/ijj-a 1X39 30-420 0-0.1 9.3--0.1 0OMC HORt 11 -- 1447-1.441 3200-4500 -72-n AJTOCtOR 1242 + *tl|H-T<to >lk ttaew rrf 150 ATRA (1.5-423 1.914 -- 0.000(4 czi'-dt) *1477-1.543 0071SJ*C) 1X77 194-C1 94.1 0M4 ROC R0P( 13-34 91 -- 1.C3VI-IAM7 AAO5*C4I7O0 T^W*. cU*f. s4cAy r*M 2 RrA (-) 42 0.05 com 05* ir*c) 1.474 <nvn*c) 1224 715-300 0 91 CU 747 477 uz us K-M UV124 - Kl-lT(O4O-f;?lt) 3*5-<d AJroaoR 44(1 *Uffct.r4to*r. 6*m. toktto m' n RPA (--n-) (1 u 9000(1 0&*-U*C) L(74 ai*/n*c) 13.91 Z39-C4 H . At) M 02 9.2-0J RORC ROM -- *49-44 1*4-151 L444-1.U7 14-154 traf: l3r*o McM a* Ank V Alt M la pai*. Moacm 5*40 0 Oar. pflv> to-paw. to<*ttt tnlp tf RaUt *2 RP* (-A-) 54 5-0 4 0J5 930171 (754.|74*C) 1.(74 (*/n-c> 11.91 ro-si 0 *.RO in RORt ROM - - *54-195.5 20ft-Z27 1.440-1.9(5 -- i 11 AK0C1.04 12(4 o nrwuu pft-Ma 9v4r 1.3 nrK (awllm) U 0.05 -- 0.009(7 I70*.|t) t I75*.'25*cj 15 91 05-150 0.1 12 hone ROM -- *150 I/O 307-114 -- TOWOLDMONOQ51544 We can ship you plasticizers and other chemicals promptly out of nearby stocks. You may find it eco nomical and convenient to place combination orders for plasticizers and other chemicals for delivery at the same time. Let us help you on all your needs for plasticizers and other chemicals for processing, formulation maintenance. MAE ' 059464 AMERICAN MINERAL SPIRITS COMPANY * A Division of Union Oil Company of California ATLANTA, GEORGIA 30309 1252 West Peachtree SL N.W. Tel. 404-873-2751-S BALTIMORE, MARYLAND 21226 1500 Ci/bon Avenue Ttl. 301-a 5-7550 CHARLOTTE, NORTH CAROLINA 28208 P. 0. Box 8242, 2335 Thrill Road Tel. 704-377-1546 CONSHOHOCKEN, PENNSYLVANIA 19428 P. 0. Box 348, Colwells Line Tel. 215-TA 8-1010 imho hi u.ijt- EAST PROVIDENCE, RHODE ISLAND 02914 Pier Road T*L401 -HO 1-1300 NASHVILLE, TENNESSEE 37209 2315 Clifton Awnut TtL 615-238*3324 MEMPHIS, TENNESSEE 38106 P. 0. Box 6011,1235 Riverside Blvd. Tel. 901-948-4487 PLAINFIELD, NEW JERSEY 07060 235 Eist Filth Street Tel. 201-753-6300 (N.Y.) WO 4-0772 MIAMI, FLORIDA 33142 3033 N.W. North River Drive TeL 305-633-7575 TAMPA, FLORIDA 33619 P. 0. Box 102A, Rout* /3 Tel. 813-689-1291 MURRAY HILL, NEW JERSEY 07971 Mountain Avenue Tel. 201-464-0700 TUCKER, GEORGIA 30084 2275 Tucker Industrial Blvd. Ttl. 404-938-558$ TOWOLDMONOQ51545 TOWOLDMONOQ51546 CHN I CA L BULL T I IV (Q-Ae^'rU EXHiBrr no.a-1 N. KUNCAITIS AROCLOR* PLASTICIZERS A series of inen. chemically-resistant. firs retarding plasticizers compatible with wide variety of resins. TECHNICAL BULLETIN 0/PL-304 MAE 040881 TOWOLDMONOQ51547 AROCLOfT PLASTICIZERS A series of inert, chemically-resistant. fire-retarding plasticizers compatible witn wide variety of resins. TECHNICAL BULLETIN 0/PL-306 PLASTICIZERS me wm iiT mmrnim manurt aid m vauaxtiu ai to artm* f*. * t* matii h oouiuuun OrjMK Oomfufc OIimm / IW I. UnAoryk IM. / Si lmo. Mwotan 1)111 MAE 040882 TOWOLDMONOQ51548 Tikli oI Cement* INTRODUCTION...................................................................... 4 DESCRIPTION 4 COMPATIBILITY ......................... 5 AROCLOR IN SYNTHETIC RESINS.. . 6 Polyvinyl Chloride 6 Polyvinyl Acetate.................... . Elhylene/Vinyl Acetate........................................... 13 Epoxies..................................................................... 15 Polyesters............................................................................. .18 Polyethylene............................................................................ .19 Polystyrene.....................................................................................19 Polyurethanes ................................................................................. 20 Phenolic*.................................... 21 AROCLOR IN RUBBERS....................................................................21 Chlorinated Rubber and Polypropylene . .21 Styrene-Butadiene Copolymers................................ 23 Synthetic and Natural Rubbers.................................................. 24 Polysulflde Sealants....................................................................... 26 AROCLOR IN CELLULOSIC RESINS............................................ 27 Ethyl Cellulose.............................................................................. 27 Nitrocellulose............................................................... Cellulose Acetate-Butyrate...........................................................31 AROCLOR IN PAINT, VARNISH, WAX. AND ASPHALT .32 Paint and Vamiih.......................................................................... 32 Wax.................................................................................................. 34 Asphalt.............................................................................................35 Allyl Starch................................................................................... 35 AROCLOR IN MISCELLANEOUS APPLICATIONS................... 36 Dust Prevention and Duit Catching...........................................36 Vapor Suppreuion (Longer-lasting Insecticides).......................36 Moisture Proofing...........................................................................36 Pigment Dispersion........................................................................ 37 Sealing and Impregnation.......... ;............................................ 37 .14 28 t 3 MAE 0A0883 mn TOWOLDMONOQ51549 PROPERTIES OF THE AROCLOR PLASTICIZERS ... 39 Solubility........................................................................... .39 Chemical <fc Physical Properties (Chart)........................ 42, 43 Monsanto Specifications................................................... 42,43 Denaity........................................................................................... 44 Specific Volume............................................................... 44 Volatility....................................................................................... 45 Vapor Pressure.............................................................................. 46 Viicosity............................................................. . 47 Stability........................................................................... 47 Nonflammability........................... ... 48 Nondrying and Thermoplastic Properties .. 48 Electrical Properties......................................... . 48 How to Emulsify Arodor. ... 49 TOXICITY <fc SAFE HANDLING ... . 50 SHIPPING................................... ` .. '51 HAE 040864 TOWOLDMONOQ51550 Int/oductlen DMcriplien . - The unique Aroclor* plasticizers are among the most versatile chemi cally produced materials available. One outstanding characteristic -- trurlniti -- makes Aroclor useful in many ways for many different applications. The major benefits offered by Aroclor include: Chemical Resistance Fire Retardance Compatibility with most resins Nonoxidation Adheaivity Low Cost This bulletin describes some of their many important plasticizing and related applications, including numerous suggested starting formula tions. Examination of their physical properties, also given in consider able detail, may suggest scores of new uses that could not be performed by any other known material. Additional information about the Aroclor compounds is available from your nearest Monsanto district sales office in the following technical bulletins: PI^307............... Monsanto's Plasticizers in Synthetic-Resin Adhesives PL-311............... Aroclor Plasticizers for Chlorinated Rubber PI^321............... Aroclor 1221. 1232, 1242 for Polyvinyl Acetate Emul sion Adhesives PI^327........... : .Monsanto's Plaaticizers in Protective Coatings PL-331.............. Monsanto Modifiers for Polysulfides CS-14..................Aroclor Fire-Retarding Plasticizers and Modifiers in Epoxy Resins CS-18.................Aroclor Compounds (performance with waxes) Monsanto's Aroclor plasticizers comprise a series of chlorinated bi phenyls and chlorinated polyphenyls. They vary from mobile, oily liquids to white crystals and hard, transparent resins. Twelve of the Aroclor plasticizers, each of which represents a series. are discussed in this bulletin. An understanding of the system for designation of each Aroclor should prove useful in the evaluation of the property gradations among them. The last two digib indicate the approximate weight percentage of chlorine in the product, and the first two digits indicate the type of material, as follows: 12 -- chlorinated biphenyls 25 -- blend of chlorinated biphenyls and chlorinated triphenyls (75:25) 44 --blend of chlorinated biphenyls and chlorinated triphenyls (60:40) 54 --chlorinated triphenyla For nearly every Aroclor mentioned, a darker, less-pure grade exists, with about the same physical and chemical characteristics, but Idwer in price. HAE 0A0885 TOWOLDMONOQ51551 Compa ttklllty Aroclor compounds are nonoxidizing, inert, permanently thermoplastic, of low volatility, non-corrosive to metals, and low cost. Aroclor com pounds are not hydrolyzed by water and resist alkalies, acids, and corrosive chemicals. The viscous, more-highly-chlorinated liquids and resins do not support combustion, and they impart fire relardance to other materials. The crystalline Aroclor compounds are relatively insoluble, but the liquid and resinous compounds are soluble in most of Lhe common organic solvents, thinners, and oils. AJ1 Aroclor compounds are in soluble in water ind glycerine. Aroclor 64 60 is insoluble in lowermolecular-weignt alcohols; Aroclor <465 is only partly soluble in the lower alcohols. Aroclor compounds plHsticize a great many resins without softening them unduly. The Aroclor compounds are unsurpassed for the plasti cizing of protective coatings, particularly for use in chemical plants and other facilities that require a tough, chemically resiaunt surface. Aroclor plasticizers can also be used to flexibilize sealing compounds, adhesives, lacquers, inks, varnishes, free films, fabric coatings, and pigment dispersions. They art also used as components or extenders in elastomen and waxes. Th properties of many end products can be improved -- yet at reduced overall cost -- by the use of an Aroclor as either a primary or a secondary plasticizer. The properties imparted by Aroclor compounds (and their usefulness in particular applications) vary in regular gradient over the series. Selection of the right Aroclor for a particular use can generally be made by comparison of the properties, by "blending" two or more, and by adjusting the percentages used in the particular mixture in which the Aroclor compounds ars formulated. Monaanto's Plasticizer Council can provide specific formulation guidance that may help you improve your product or lower your processing cost- Processors are invited to ask the nearest Monsanto office for help on special problem*. The Aroclor plasticizers are compatible with most common plastic materials; they are compatible to the extent of practical use with the following; Asphalt Benzyl Cellulose Camauba Wax Cellulose Acetate-Butyrate Chlorinated Rubber Coumarone-Indene Resins Damar Resin Ester Gum Ethyl Cellulose Ethylene/Vinyl Acetate Epoxy Resins Nitrocellulose Paraffin Phenolic Resins Polyethylene Polyester Resins Polystyrene Resins Polyisobutylene Polysulfides Polyurethanes Polyvinyl Acetate Polyvinyl Butyral Polyvinyl Chloride Polyvinylidene Chloride Rosin Rubber _ Styrene-Butadiene Copolymers MAE 040886 TOWOLDMONOQ51552 Liquid Aroclor SofL, Resinous Aroclor Hard, AR.re1oscinloour s Aroclor plntici7.ers are not compatible with phenolic resins in thp final stage of condensation or with cellulose acetate. Aroclor plasticizers generally impart progressively increasing proper ties in the direction of the arrows in the following diagram: Flame Hardness Flexibility Retardance Volatility Density Viscosity ' ` -r w Usually the desired balance between flexibility and hardness can bo obtained either by selection of an Aroclor with the appropriate physical characteristics or by use of a. blend of two or more Aroclor plasticizers. In evaluation of formulations that contain Aroclor plasticizers, the compounder should thoroughly tesL an experimental product for compatibility, heat and light stability, and other properties according to normal industry practices. Arodif PliilleUtri In Spitkitlc Ruin* Low-cost Aroclor plasticizers are valuable for a variety of applications. They improve chemical resistance, flame retardance, and oxidation resistance. Depending upon the use. the various Aroclor plasticizer offers a number of benefits to the user. In almost all formulations, the use of an Aroclor reduce* the over-all cost per pound. In PohrYinyl Chloride Aroclor is valuable in polyvinyl chloride and copolymers as a secondary plasticizer or as a plasticizer extender. The Aroclor plasticizers impart flame retardance and chemical resistance. Selection of the proper Aroclor enables compounders to impart such special properties to their formulations as: Resistance to migration to nitrocellulose lacquers (Aroclor 1260 and 1262). Fine.unifom cell structure in vinyl foam (Aroclorl2G2 and 1268). Adhesion in vinyl coatings (Aroclor 1260 and 5460). Viscosity stability in plastisols (Aroclor 1248 and 1254). Compitiiilirf Aroclor plasticizers (except Aroclor 1268) are compatible to about 25 per cent of the total plasticizer conLent in polyvinyl chloride and usually somewhat greater in copolymer resins. At these levels, no exudation occurs in the loop-compatibility test, one of the most severe used by the industry. MAE 040887 f #> TOWOLDMONOQ51553 T>* c*otrl kwm rtfrdy: tU tni containing A/Klor* itus not mi igniti. ftrlormiKi ' As an illustration of the performance of Arocior plasticizers. Table 1 shows evaluation of the five most commonly used in polyvinyl chloride. TABLE 1 PERFORMANCE EVALUATION OF FIVE AR0CL0R* PLASTICIZERS IN POLYVINYL CHLORIDE irodor Cones*- tnlioa Irons) Hudtea (Short "A") dolt- tllitf Ktrostoo' (fltsti- Cartctho can (fhstkint lost. X/ lost. %) Lon- Tom? Flotibihrt (Cloth S Sttf) (Tt.. C/ Tinsilt Slitnpth (psi) SiongtModulus t/on (psi/ I'M 124i 15 17 IS 23 -26 2330 1320 342 1254 15 Si 14 24 -24 2310 1360 334 1260 15 S3 11 32 -22 2200 1330 315 465 17.5 (5 .6 IS -13 - - - 5442 17.5 !7 6 16 -20 - - - Inptlditntl 1/ Opalon* (60 PVC nun Oioctrl Phthalaii Calcium Carbonati Stabilirir Arodw ij 24 houri i( S7'C ovir ictivitid carbon c) 36 houn it 25*C ftrti if Wnj/it 100 45 40 3 indicated MAE 040888 TOWOLDMONOQ51554 5 Hut tnd light Stiii/rry Aroclor compound* impart good heat stability but lomewhat reduce the light liability of vinyl formulations, but no more so than do many other secondary plasticizers commonly used in the industry. Light stability of the system may be improved by incorporation of a small amount of light-screening agent, such as 0.1 per cent Tinucin P.' Chtmict!Ricittinct For imparting resistivity to chemical attack, the Aroclor plasticizen are unsurpassed. Independent evaluations of the chemical resistance of vinyl chloride-vinyl acetate copolymer paint, modified by eight types of material* (aJkyd resin, phenoiic-chinawood oil varnish, ester gum-lirueed oil varnish, Aroclor 1254, dioctyl phthalate, tricresyl phosphate, polymeric plasticizer, and acrylic polymer), showed that Aroclor 1254 has the "best all-around chemical resistance, failing badly only in the gasoline test." Paints were sprayed onto solvent-cleaned, unprimed, cold-rolled-stecl panels, which were then immersed in seven types of solutions until failure. The data in Table 2, excerpted from the November 1955 issue of Official Digal of the Federation of Paint and Varnish Production Clubs, compare the chemical resistance imparted by Aroclor 1254 and by dioctyl phthalate. TABLE 2 COMPARATIVE CHEMICAL RESISTANCE OF PLASTICIZERS IN Y1NT1 CHLORIDE - VINYL ACETATE COPOLYMER PAINT Hntkinti Oiocffl fhttnLtd PH 10 Aroclor* mi mi -- - 10 25 - -- 25 40 - - &0 ij -End if tut itrn Sodium Hjiroi- idi fdtnl 120* 120* M 120* to 120' Timt to Ftilert it Convent Mtdit ion Hfdroct/erk Acid (hotrjj 12 1M< 24 120 24 It EtioHot (dm) 0.4 5 0.4 0.4 0.4 0.4 sn Sodiira Hrtociloritt (dm! 4 13 4 14.5 4 11 um Acetic Acid (ItOVtl) 14 16* M 120 41100 linutd Oil Ftttr Acids (dtrs/ IV. Udt it utf Idtrt) to - 21 JO- 22 27 25 JO* 22 22 25 to 22 In other corrosion-reaistance tests of polyvinyl chloride plastisols, containing 70 part* plasticizer per 100 part* resin a formulation that contained 1 pan Aroclor 1254 to 3 pans dioctyl phthalate was much more resistanl to 15 percent nitric acid at either 23* or 50*C for six month* than a compound plasticized with dioctyl phthalate alone. The plastisol modified with both Aroclor 1254 and dioctyl phthalate was also more resiiunt to 25 percent chromic oxide at 50*C for four week* and was equivalent at 23*C for six months in comparison with the dioctyl phthalate-modified vinyl plastisol. MAE 040889 t TOWOLDMONOQ51555 Uiptmon Rtsisnncc The use of Aroclor 1262 as a coplasticizer with dioctyl phthalaie greatly enhances the resistance of plasticizer migration to r.uroceiijiosr lacquers and fiims. Table 3 compares this properly lor four formulations. TABLE 3 plasticizer migration to nitrocellulose lacquers ano films fhstici/tn Oioclyl Phthalete Polymeric Plaeticmr Aroclor 1252 Htrdnen. Shore "A" Turn (witks) Room Temperature 1 2 3 Aroclor" end OOP bins) 55 20 72 No Change No Change No Change 4 No Change 5 ho Change 10 ho Change Control oor Inns) 71 72 Atodor. DOr. tnd Palyminc /fins/ 36 33 20 72 Polymeric end OOP (puts) 38 35 - 73 No Change ho Change ho Chengo ho Change ho Change ho Chingt ho Change No Change Very Slight Marking Very Slight Meriting Very Slight Marking Very Slight Marking Slight Mxrkmg Slight Meriting Slight Marking Slignt Marking Slight Marking Slight Marking 50* C 1 No Change Slight Marking Moderate Marking Very Slight 2 No Oienge Slight Marking Serin Very Slight _____________ '_________________________________ Marking______Spinning 3 No Change Slight Meriting Very Slight Slight ______________ ___ ____________Spinning Spinning 4 No Change Modmu Slight Slight Marking Soltemng Spinning 5 ho Change Moderate Slight Slight MeritingSoftening Softening 10 ho Change Moderate Slight Moderan _______________Meriting_________ Softening Softening 6<neral Motori Lacquer Indentation. Extreme Lifting Enrime Test (15i*F; 72 hr.; Vary Slight Softening Softening X-pei load)_____________ Softening_______ _____________________________ // Fornulation Ingridiints Oyalon* WO PYC Renn Eooir Soybun Oil Barium-Cadmium Leuratt Calcium Carbonate Plteticuer hrts by Wlight 100 3 3 25 u indicated ' MAE 040890 TOWOLDMONOQ51556 Plestisoh The use of ar. Aroclor as a coplaslicizer wich dioctyl phlhaiate ir. polyvinyl chloride plastisois or organosols contributes greailv to the viscosity stability of these mntcrials. especially at eievated tempera tures. This benefit is especially important whenever shelf stability is required. Although the iniiial viscosity of the plastisol or organosol is increased by the use of an Aroclor in the formulation, the viscositv reduction upon temperature elevation (before the fusion temperature is reached) is much greater than when most other plasticizers are used. A comparison of the viscosity stability of plastisol formulations with and wiLhout Aroclor is given in Table 4. TABLE 4 VISCOSITY STABILITY Of PLASTISOLS JS'C Initial 1 On 1 Wnk 2 Wiski 4 Witts Qieetyt Phthe/eU (tO fihf) Viscosity4 (poises) Atoelot* mt (20 pit) Oioctyl Phtht/sn (SO fhr) Viscosity (poises) A/odof S4S0 (20 ph// Oioctyf fbthifete (SO phi} Viscos/if* (poises} 34 43 15 13 17 71 111 75 132 141 32 154 111 171 252 *rc Initial 1 Ur 1 Wist 2 Wlilu 4 Wtsti 37 M 215 305 426 44 SI 101 110 203 61 131 133 114 274 urc Initial t Day 1 Wisk 2 Weeks 4 Wsiki 11 III >4 MO 110 gil 100 470 300 III $) Btootfiild LYE mwnttir. No. 4 spindU. 12 rpm Dipping Plastisois. The chemical resistance of Aroclor compounds is uwd to good advantage in chrome-plating-bath coatings and in glove coatings, as illustrated by the following formulation for a clear glove- dipping plastisol: ' Ingredients Puts iy Weight Option0 440 PVC isiin 100 Aroclor* 1254 20 Oiisodscyl ftllhsllli 50 Ssnticusr* 110 25 HB-40* Sicondiry Pliiticuit 20 Liquid Biriufi-Csdmiusi Stibilinr 2 liquid Qiilsier-Stsbilitir 0.5 Smtocil* 54 Silica Atrogil - 3' MAE 040391 f) TOWOLDMONOQ51557 Stolen. The adhesion-imparting characteristics of Aroclor compound.-, their oxidation stability, and their chemical resistance are utilized in the manufacture of automotive sealers, such as the following suggested seining formulations: fofttditftts tuts lr Wtiyhi Odilon* 440 PVC nun Viny/iti' VMCH 'ism Aroclor* 1260 Qiuodicyl Phiniiui Sinliciiir* 160 Cilciun Carbonm Enoiy Soybun Oil Dibasic Lud Phaiphiti 36 < 50 100 26 125 5 3 Fabric-Cootinq Vinyl Dixpcrriom. The use of Aroclor plasticizers in organosol or plastisol formulations enables the manufacture of fireretardant free films and coaled fabrics with a high degree of hardness, yet flexibility. The following typical starting formulation for a vinyl organosol to be used for free film or coaled fabric illustrates this effect: Inffidittrtj tins by Wtif/it Option* 440 PYC ruin Dioctyl' flilhaists Arodor* 1264 Liquid Bsrivm-Csdmiun Slsbiluir Epoxy Sorbun Oil Thinner Xyiint 100 33 10 2.5 3 20-35 15-25 Riqid PlatiuoU. The visectity characteristics of the Aroclor plasti cizers are utilized in the following formulation for rigid, rotationallycast objects. The formulation is very viscous when first made up, but when heat it applied, the viscosity decreases so that a smoothly-flowing plastisol is obtained. The finished object has a Shore "D" hardness of 63. fafndittn tirts by Wtiyht Opslorr* 440 PYC risin 202 PYC ruin Aroclor* 1264 Ssnticiitr* 141 Epoxy Octyl Tsllsts liquid Btrium-Cidmium Slibilutr Liquid Zinc Stlbiliiir Polytlhylsnq Glycol 400 Monoleursti 55 45 36 10 5 2 0.5 1 HiWWlI m CJHW MAE CH0892 TOWOLDMONOQ51558 Yitflfttm Aroclor 1262 and 1268 impart fine, uniform ceil structure and flame resistance to chemically-biown vinyl foam, as inowr, by the following formulations: Ingndiint; Ptrts if Wlight Opelon ttO PVC mm too 100 100 Aroclor 1262 - 20 - Aroclor 1266 Oioctyl PhthtllU 20 - 10 40 - - Diisodecyl Ptithalsti - 50 30 Di-l/i-Octyl. e-Oecyl) Adipen Senticrzsr 214 Smticmr AOS Butyl Olsen Lipoid Baiun-Cadmium Stabilizer Epoxy Raun NeutrW Calcium Petronaii - 10 30 -- 15 - so - - 6 - - 2 33 -22 3.6 3.6 3.6 Caldm Oxide --1 1 Sodiuei Liuryl Sulfite Hitiosm' Qiemicel blowmp ipent - 1.6 16 10 10 5 Flmn-fiilirdii! Flat Titt The nonflammability of the Aroclor compounds suggests their use in the manufacture of flame-retardant vinyl-asbestos floor tile for military applications. In Table 6 ii presented an evaluation of three Aroclor plasticisers in typical vinyl-utbeslos-Ule formulations. SubsLituLion of antimony oxide for part of the limestone is suggested for still greaior fire retardance. TABLE i EVALUATION Of AROCLOR IN FLAME-RETAROANT. VINYL-ASBESTOS FLOOR TILE Senticixer* 1(0 Arodor 1254 Axed* 12(0 Areclsr 54(0 Meiumey Indiomice Hardness BanAury Tins (to raach 260*f. sac.) Tima ta band aa roll mill (sec.) Plasticity Tack Surface ij formoietion Ciatri/4 tnnsj 37 -- 7.1 19 15 Excellent Excellent Excellent Atoclot 1H4 (ptrtij 30 15 -- I.( IS 10 Excellent Excellent Fair Audi! U$0 Inns1 36 - 17 -- 10.4 102 10 Excellent Eicellent Excellent Aroclor S4(0 /pirtsJ 40 -- 20 11.2 115 5 Excellent Eicellent Excellent 1MHN< (. L * * --< 4 6*. m. MAE 040893 e * III TOWOLDMONOQ51559 In Polyvinyl Aeitite Ingrtditnls Opalon* 506 PYC Resin Ssnliciifr 1(0 Aroclor* Asbestos limesiont Titanium Oiaxide Stebilisor hns if Wnf/il 100 As Inaicitad As InOiciKO 160 no 15 5 Aroclor compounds are excellent plasticizers for polyvinyl acetateemulsion adhesives and hot-melt adhesives. The excellent lack ar.a strong bonding power they impart and their low cost cor.tnbutc greatly to the performance and profitability of these adhesives. Emulsion Aditsifis The liquid Arodors -- such as Aroclor 1221, 1232, and 1242 -- blend readily by simple stirring with polyvinyl acetate emulsion at up to 11 parts per 100 parts of emulsion. They greatly improve the quick-lack and fiber-tear properties of the adhesive. The performance of Aroclor plasticizers in polyvinyl acetate-emulsion adhesives is compared with that imparled by dibutyl phthalatc in Table 6. The following is uggested 44 * typical starting formulation for a low-cost, quick-tack adhesive: Irtfrtdiinti .Forts Ir Wtifht Stiff S-55 PYAc Emulsion Aroclor* 1Z32 100 11 TABLE 6 PERFORMANCE Of PLASTICIZERS IN P0LTY1NYL ACETATE-EMULSION AOHESIVES Htrdntss fShort "A") Diiirryl F/ilit/tlt ("/!>,) Si Aroclor* 1221 IV thrJ 66 Aroclor 1222 III fh! 16 Atodot 12V in fin 37 Ltw- Ttaftrilurt Fltiibilitj (dish k Berg, T,. T) -10.2 --5.J 4.0 5.3 Mttilitr (24 hr., WC over minted charcoal) (Plasticizer lost, K) 4.0 4.1 4.3 4.0 Atrastrtt Eititctio* (24 hr.. 25*0) (PUsticher lost X) 4.1 4.5 3.1 4.2 Ftmoltlion fiscosttf |c?.) Initial1 2420 2240 1 Day 2460 - 3 Oayi - 2200 4 Days 2520 - 5 Oays - 2200 7 Oays - 2160 10 Days - - 2260 tj Initial viscosity of imoiasticuib emulsion: 1100 csmipoisc: 2160 - 2060 -- 2040 2020 2060 - - MAE 0^089^ TOWOLDMONOQ51560 In Ethyiina Vinyl Acstilt . When the alight, odor of Arodor is objectionable in an adhesive fo.certain applications, it can be easily masked, at ncgiigibie cost, bv the addition of a small amount of Santomask- II. Hm-Mtll Adhtnrts Arodor compounds are widely used as plasticizers in polyvmvi acetaie hot-melt adhesives for bookbinding and other applications. Four sug gested started formulaiions for evaluation are as follows: Ingudiint Puts Sr Wnght Applicitien Timpimu/i US' - 17S'C Low Me/ii/tf Attifi. Ouptrsabh Polyvinyl Acilili Ooslorr 505 PVC ruin 95' 100* 5- 50' - 38' -- Modifiad Rosin -- 25 - Coumarona-lndina Ruin (soil) Arodor* 1254 A/cdor 12S0 - 50-75 55 - 12 -. 28.3 27 - Oibutyl Phthslsti -- 13 7 Sinlicirtr* 180 (or dibutyl phihalata) 50-75 30 - - Clay Fining Resin (Fibres* Risin WW) - - 25 75 - - -- - Acrnru C` -- - 1 Sodium Santoala --- -- 0.78 Viicotrty (cinlipouisj 2000 (120*C) Non-blocking 3500 (175*C> Non-blockrr.g 1/ Gsiyr* Y-7 i/ G*Wi C-3 Y-10 c) Silvi C-5 V-I8 The Arodor products are among the most compatible, effective, and versatile plasticizer/modifiers available for ethylene vinyl acetate. Roth the liquid and solid Arodor plasticizers are highly compatible with ethylene vinyl acetate and other ingredients commonly used in ethylene vinyl acetate, such as paraffin and microcrystalline waxes and other resin modifiers. Arodor offers special functional properties and reduces formulation costs when used with ethylene vinyl acetaie. Hrt-Mi/t Ad/iisms Arodor in ethylene vinyl acetate hot melts imparts excellent initial tack and high final bond strength. Arodor is particularly useful in providing versatility of adhesive bond to various substrates such as aluminum foil, cellophane, polyethylene. Mylar** polyester film and paper. Liquid Arodor, such as Arodor 1254, provide greater flexibility and lower application viscosities. Solid Arodor 5460 provides adhesive strength, permanence, and lowers the melt viscosity. Both liquid and solid Arodor products are exceptionally heat stable, resistant to oxidation, moisture, and chemical attack and arc. in general, very inert. Flexibility, specific adhesion, and melt viscosity may be adjusted by varying Arodor concentration and by selection of solid and or liquid Arodor plasticizers. - Ca MAE 040895 14 t 0 TOWOLDMONOQ51561 In Enoiy Ruins Putsutt- Sthiilirt Adhtriris Aroclor in elhvlene vinyl acetate pressure-sensitive adhesives imparts excellent specific adhesion and tack. Liquid Aroclor, such as Arocior 1248 or 1254, improve flexibility and adhesion while solid Aroclor 5460 or 54 4 2 imparl a high decree of Lack and bond strength. Suggested starting point formulations for evaluation using Arocior in ethylene vinyl acetate hot-melt and pressure-sensitive adlies.ves are shown below: Hor-Mth Adhtlirt Pirn if Wtighi "Urn"' 40 Aroclor 5480 40 Miciocrnullin* Wi 20 PitssuriStntitiri Adhesire P,,t: if Weight "fim" 150 10 A/o<ior 5-460 40 Aroclor 1254 50 The Aroclor plasticizers probably have greater compatibility with epoxy resins than any other available nonreactive plasticizer-modifiers. The excellent chemical resistance, oxidation resistance, and adhesive qualities imparted by Lhe Aroclor compounds reinforce these important beneficial properties of epoxies and thereby help the compounder reduce his formulation costs materially without significant adverse affect on performance. The lower-molecular-weight, liquid Aroclor plasticizers (such as 1221 and 1232) have maximum plasticizing efficiency and impart the most flexibility to epoxy compounds. The more viscous, resinous Aroclor products have progressively less efTect on epoxy flexibility: the highmolecular-weighl, solid Aroclor plasticizers (1268. 2565. 4465. 5460, etc.), in fact, tend to reinforce the compound. The effects of Aroclor 1221 and 1248 cm the properties and performance of an epoxy resin are indicated by the data in Table 7. . TABLE 7 EfFECT OF AROCLOR* 1221 ANO 1241 ON PROPERTIES OF EPOXY RESINS Fotmuhtion4 Viscasitr* Phfiietl Pioptrlin Phfiietl Piopenf A/tir fiul Aging Atoelor Audit 1221 12U Bt/oti Curing Afint Hod Aim laptot Curing BtststAgtni met CUntf (Light Btiitcttd) (%) Hntdntzs Short "O" (IOstc.1 Htrdnfts Wtight Shut "D" Lon (!0 soc.) ('/! - - 12.100 1300 0.2 3.0 130 rpml 76 16 0.012 25 - 1650 1200 - 3.0 - 25 7700 4300 o.s 3.0 I 40 11 2.111 11 0.612 MAE 040896 15 TOWOLDMONOQ51562 f InfttdiinU Ptrts by H'l/fbr if liquid Epoxy Rosin 100 Titriilhyunipsnlimini S Aroclor 1221 or I24J A1 indicstid Cirri: 10 raihutM it 100'C ij 8rooH/ld LYF No. 4 spindli: SO rpm onltu otherwm specified </ 24 hoirri it M'C in acthrstid cfiircul Development 0/ flame-retardant epoxy resins is of wide-spread interest. Aliphatic amine-cured epoxy-resin formulations are made tef/ ezttnpuuAinq by the use of 20 parts of liquid Aroclor per hundred pans of resin. The incorporation of antimony oxide at 5 phr, with 15 parts of Aroclor per hundred parts of resin, yields nanburninq formulations (Table 8). The uae of liquid Aroclor in aliphatic amine-cured epoxies also improves flexural strength and compressive-yield strength, has little effect on tensile strength, and slightly lowers heat-distortion temperature and compressive ultimate strength. The use of solid Aroclor in phthalic anhydride-cured epoxy systems also reduces flammability and, in combination with antimony oxide, produces nonburning formulations. The solid Aroclor products also greatly improve such important properties as compressive strength, flexural strength, compressive-yield itrength, and tensile strength, although they slightly lower the heat-distortion temperature (Table 9.) Extension of epoxy-resin adhesives with Aroclor greatly reduces the formulation cost, with minimum effect on the bonding characteristic of the adhesive or surface coating. In epoxy-resin protective surface coatings, the use of Aroclor 1254, 1260, or 1262 economically imparts excellent chemical resistance, particularly to acids and alkalies. When resistance to solvents is de sired, however, Arodori should not be used, since they are true plastidaeri and do not combine chemically with the epoxy resin. Frequently, about 10 to 15 per cent Aroclor 1260 or 1262 is added to increase the flexibility of the epoxy composition, with minimum effect on the corrosion resistance and adhesion of the film. MAE 040897 TOWOLDMONOQ51563 TABIC 1 EfrtCT. Of ABOCl OR 1242 AND 12SO ON FLAMMABILITY AND PHYSICAL pnOPCRTIES OF EPOXY RESINS A rod9f 17*2 (p*>) -- 20 - 11 -- foreiatnioa Atoefee AMtmemf 17SO OeUe tr*'! !+) ---- -- .-- 20 -- -- IS S s (Rockwell *'A/*7 104 too 103 102 IM flmnmahilhy (AsrMt3Sserj inches Bit* homed (in.\min.) 4 1.02 2.12S A 1.121 A 0c 0c RestDistortien Temp. fCj 117.5 79.5 07 at 92 Helmut Strength (pi>) 70.100 21.000 73.000 22.200 22.100 Tea lift Strength (?! 11.400 10.700 13.000 12.800 9.000 Cempttxsire Yield Strength (t"i 15,700 17.900 17.250 l(.700 10.950 lefreditmts Teflt Weifkt ej lifuiA Epoiy Rein__________________________________________________________________TOO______ OicIhfUnatriwninc 13 > ___________ AiicIm 1242 or 1260____________________________________________________________it inAiciHd Anlimonir idi _____it inlicmd Cm*: IS Noun il fftun Inwpifilwi. pint 2 hwjn w I OPT______________________________________ . A/ Sell utinpjiihifj____________________________________________________________________________ cj KwAwnini TABLE 9 tffCCT Of SOLID AROCLOR* ON FLAMMABILITY AND PHYSICAL F'flOPtRlllS OF EPOXY RESINS f*rmvlitio` Arec/er Aioclor Artimtty 1261 5400 OiUe If*') 1 (PM lr*ij -- 20 - - - 20 - 15 - 5 - 15 5 Her^MSl (Rockwell W) 113 112 112 112 111 flommokilkf fu.lmtt.J OS 0.31 031 A A Hee< Diitertie* Temp. rej 143 128 135.5 134 135 Tleitrel Srne/ik (rsi) 16.900 25.900 26.300 20.000 19.000 Tenite Stneftk <n>) 11.000 13.500 11.500 11.100 10.200 Ingredients Farts if Weight e) Liquid Epf Hnln Phthilic Anhydiide our jo' tmifti Anclor 1268 if 5464 *. Anlmtny Ondc Cuit 20 howl nt 150'C 100 750.1 s indictlid as indicated h) Nonbuininf |,W 1 A t U Compieisrre YieU Suctfik if") 20,900 22.300 21.000 20.504 21.200 Compretlire Strength (Pl*l 43.000 32.500 32.900 32.400 38.150 Compressire Strength (Pit) 23.400 36.500 41.700 36.700 40.700 B6B0V0 3VW N TOWOLDMONOQ51564 In Polvulir Rmni The hiyhlv chlorinated. less-voiaiile Aroclor compounds such zs Aroclor 1260, 4465, and 5460, arp very effective and economical fire retardants for polyester resins, and they do not significantly aflect the physical properties of the resin. The Aroclor plasticizers are effectively used in combination wjih equal amounts of antimony oxide, aince the two maieriala are synergistic. Aroclor imparts self-extinguishing properties to the resin, and antimony oxide reduces afterglow. Table 10 indicates the degree of flame resistance imparted to a generalpurpose polyester resin iwith a 36 percent styrene content) by various equal concentrations of antimony oxide and one of these three Aroclor plasticizers. TABLE 10 FIRE RETAR0ANCE IMPARTED TO POLYESTER RESINS BY AROCLOR AN0 ANTIMONY OXIDE Attlmotf Osidt tnd Artdar* 12W AiS -- 4485 -- 5480 ILmmaili tj fwruiilm JS Mtndlimisilili flamiwW# nilxtinguiihing M stands 7JS 10S /fS iirillimmail i nilixtinguiihing JO stands tillniinguiihing immtditlt' uHxlinguiifiing S stands nlfixtinguiihing S sacoads niliitinguiiRing immtditit nrtiilinguiihing 5 stands nil- xlingvithing immtditlt /tfrtditt/s Pohrit*r Ruin (gininl pursui) Slrnne Mtlfryl Etlryl Ketone Piruide (SOS in dibirtyi phthalitil Caiilt Niphtheniti (IS wlution| Aroclor intf Antimony aide M'tifdt htztns (2 35 2 1 n indicated Inclusion' of an Aroclor increases the flexural strength of the naturally brittle polyester and makes addition of a more expensive plasticizing polyester unnecessary. At a concentration of 10 percent (enough for fire retardancy), none of the Aroclor plasticizers reduced the flexural atrength of the cure resin lignificantly (Table 11), and their effect was comparable to that of a plasticizing polyester. At 20 percent addition, they improved the impact strength, whereas the plasticizing polyester reduced it. The solid Aroclor plasticizers are preferred for fire-resistartl surface coatings. MAE 040a99 in f 0 TOWOLDMONOQ51565 i TABLE 11 EFFECT OF AROCLOR* ON STRENGTH OF FIBCRGUSS-REINFORCED POLYESTER RESINS fhslicUtt fluunl Sliinft/i W (fill fiixunl Modulus Ipsil /mmc! St/ffiffA fit. -Id im} Non* 0 47.210 2.130.000 1.73 Ploiticmnj Polyoitor 10 20 43.310 33.330 2.000.000 1.560.000 1 $4 1.24 Aroclor* 1260 10 45.600 2.030.000 1.33 20 33.660 1.630.000 ' 2 04 Aroclor 4465 10 40.740 2.130.000 1.41 I i 20 33.390 1.230.000 2.48 i Aroclor 5460 10 37.400 1.700.000 1.85 20 35.830 1.550.000 3.06 In Polytlhylmi i The need to make polyethylene and other polyolefins flame retardant is well recognized. The well-known flame rctardancy of the Aroclor products suggests their evaluation for polyolefin applications such as molded products, coatings, and hot-melt adhesives. Preliminary evaluation of Aroclor 6460 ( 20 percent) and antimony oxide (10 percent) showed good results in imparting flame reuraancy to low-density, noncrystalline polyethylene. Compared to the use of chlorinated aliphatic hydrocarbons, the use of Aroclor greatly improved the heat stability and had considerably less effect on tensile strength, yield, and elongation of the formulation. In Polyjryrmo The Aroclor products are good plasticizers for polystyrene. The lowermolecular-weight Aroclor plasticizers have greater solvating power than the higher-molecular-weight Aroclor products. The gelling rate of various plasticizen in polystyrene resin is shown in Table 12. each plasticizer wai added to the polystyrene resin at a concentration of 2 parts plasticizer per part of reain, and the time required for the material to gel was noted. TAIL! 12 SELLING RATE Of PLASTICIZERS IN P01YSTYHENE fUstkinr (100 ftf) . Aroclor* 1221 Oilthyl Phtholoto Dimethrl Phthilsu Aroclor 1242 Staticutr 141 Ssnticiltr 160 Stnttcutr 8-16 HB-40* " Timt H Ctl (mm.) imatduti 0.6 0.76 2 3 1 11 30 MAE 040900 19 TOWOLDMONOQ51566 In Polrwith**** Arcelor products are useful as plasticizers and'flame retardants in polyurethane rubbers, /oams, adhesives and coalings. Having extremely low moisture content (SO ppm or less), the Aroclor plasticizers are useful in applications where low moisture ia required. Other advantages exhibited by Aroclor in polyurethanes include resistance to oxidation. resistance to alkali and adds, improved adhesion, and low cost. The following formulation illustrates the use of Aroclor 1254 in a polyure thane flocking adhesive: ' Pin A Part B In/ndiiiu Mu/lrmil' FLO Iktthini Ruin Mondut' C liocyinate Arcelor 1254 Mu/inmi FID Maidir C ftns if Wright 100 5 20 100 5-10 ' Part A is applied to the fabric by knife coating and allowed to dry thoroughly. The fabric is then coated with Port B, and the material is flocked immediately. Protective urethane coatings are unusually well suited for application to concrete and metal. Aroclor 1254 is incorporated lo improve ad hesion and sealing. The first of the following formulations is the preferred prime coat for concrete storage tanks for gasoline and fuel oils. The second formulstion is the base coat for a concrete wood-kiln coating, which remained in perfect condition after two-and-one-halfyears' continuous txpoeure to heat, moisture, and wood distillates. The other two formulations, for primer and intermediate light-metal coating, contain Aroclor 1254 for better adhesion to metal. irp^'mU Mttdrr C M*tuu R-4 Polr*ttf Resin tUtBM R-10 Ando* 1254 Pstpriirrl Ariteti Pifyvinyl Btyr*l Mit&yl Gtyesl Acsuti fcrtrl Aetlsu Ethyl Acststi Taluana Pijmant (cstorid) Zinc Chremat# Tilaoiwn Dioxide jrutili) Tile (mie/ontzad) UntiitdCtacnlt him* C**i (nm) 11.0 - 10.0 i.O 0.2 -- 1.7. 1.7 1.7 1.7 12.B -- 12.5 Hif/h Ttttpirifrt Cfcrttt himir !**nj) 12J - 12.0 2.1 - 0.4 1.0 5.4 4.0 !.l - 15.0 13.1 Lifht-Miltl Coitinf himir Imirmtdini farts/ (pins) 21.0 25.1 2.1 7.2 10.5 7.2 2.7 1.1 0.3 0.3 --- 1.0 7.5 1.0 ` 7.5 15.1 14.2 1.7 21.0 7.1 - -- 13.2 4.5 MAE 040901 TOWOLDMONOQ51567 In Phenolic Rjini Considerable interest has been shown in the use of Aroclor plasticizers to make phenolic laminating resins flame retardant. The highermolecular-weighl Aroclor products (1262 and 5460! are usually evalu ated for this purpose. Arocior 1268 and 2565 are useful in the manufacture of brake lining'. Chlorinstpp rubber primer end topcoat, plostlctrod wfth Aroclor?off*r exceJUnt remianca to outdoor watrtonn(, hlfli Humidity, itaam and condensed acid vapora. Aroclor In Rsbberc In Chlorinated Rubber And Otlorinitid Polrpropylcna Protective coatings based on chlorinated rubber generally contain Arodor plasticizers to enhance their chemical resistance (to water, alkali, and acid), corrosion resistance, and electrical insulating proper ties and to impart flame retardance. When properly pigmented, they are unusually weather resistant. Aroclor compounds strengthen the adhesive grip of chlorinated-rubber lacquers, varnishes, and paints to structural materials and improve the flexibility and life of the coaling. Typical applications include protective and decorative coatings for swimming pools, stucco homes, steel structures, tank cars, and both wood and meul maritime equipment. Their outstanding chemical resistance qualifies these coatings for use in manufacturing plants where chemical attack is prevalent. Aroclor 1254 and 1260 are used in chlorinated-rubber coatings a; flexihilizing plasticizers, commonly in combination with Aroclor 5460, which serves as a resin fortifier. A variety of suggested starting formulations based on chlorinated rubber is giver, lti the following tabic. MAE 040902 21 TOWOLDMONOQ51568 Ptints lot Alkilino Surficts Infridimts /V/ Sptc. TT-P-31 /ports/ Conctott Swtmmmp Poo! /ports/ Mtsimom Acid ltd Alitli Riststmct 1Pins1 Wkru Mtnnt Pllllt /Pirtsl Pitlon' (20 co.) Chlorinmd Rubbir 11 10-2 I! 20 Aroclor* 1254 10 5.1 1 6 Aroclor 12(0 -- 6 -- Aroclor 5460 1- -_ Long-oil. oudirmg. ilkyd nun - - -1 Modium-oil. drying, ilWyd nun - 5.1 ---- Csrton Black 0.5 - -- Iron Ondi -- 11 -- Tiltnium Oioiidi 11 11.4 -- 25 Zinc Oiids 2-- -- Asbostioo" 3X (mijnuium liiicslil - 11.7 - - Bintono34 galling igml - 1.3 - - Epichlorohydrin - 0.1 0.03 - Sisbilmr -- 0.9 -- Sohttsso150 12.75 -- --- Sotrust 100 - 3.1 45 -- Tvrpsnuna 4.75 - 5 -- Xylan* - 45.7 - 23 Hi-Fluh Nschths --- -- 20 Aroclor compoundi ire also incorporated in chlorinated-rubber for mulations ucd for heat-sailing adhesives. electrical coatings, paper and textile coatings, and printing inks. The following starting formula tion is for an acid- and Aame-reaislant adhesive: hptditnts Chlonnitid ftubbor (125-co. ty?) Arodor 1254 Aroclor (440 Tolumt Puis kf Wlrftlt 20 1 (I Chlorinated polypropylene, a new film-forming resin, produces dear, colorless Alms, appears equal to chlorinated natural rubber in chemical resistance, and is noticeably more heat and light stable. Aroclor is very compatible with the resin and is recommended in the following start- ing formulations: Ipfrtdiutts Odorinitid Polrpropylini Aroclor* 5460 Aroclor 1254 Oiocryl Sibscsli Eposy lubiiizir Solids, wt. pitcinl in tolumi 50.0* 15.0 24.0 4.3 1.7 50.0 Composition /irt. %/ 55.0' 15.0 24.0 4.3 1-J 50.0 MAE 0409Q3 c 01 i TOWOLDMONOQ51569 200'F but ittbilitj 1 hour 2 hour) 3 hour) 6 hour) 13 hours Film Fru/inns y. il. yi/low i. al. yillow ll. ytllow mod. yiiiow black V. ll. Ytllow >1 yillow mod. yillow - - FillOmitll' lllbility 24 hour) 46 hour) IE hourr 144 how) tl. yillow ll. yillow mod. yillow mod. yillow v. si. yillow tl. yillow il. yillow brown Twt-wttk cJitmicjl ftsisUKt witir 19% hydrochloric icid IS sodium hydrondi ncillint iicallinl ixcallini icilleni ncilltnt ncillint t) Fitlen P (10-cp. 20S in tolutns) -- Hirculu Inc. b) Firlob P (20-cp. 20S m loiuins) -- Hirculu loc. cl Licquirs weri sprsyed on "bondoritid" iiatl psnil). Film win 2.5- to 3.0-mil) thick illir 77-houn' air drying. |n Styrmi-Bulidiini Copolymar) Aroclor plasticizers are very often incorporated in coatings based on styrene-butadiene copolymers to impart resistance to acids, alkalies. moisture, and corrosive chemicals. These coatings are suited for use on masonry, wood, and metal for such applications as concrete floors; architectural finishes; metal primers and finishes on maritime equip ment, structures, and tank cars; baking primers; corrosion-resistant industrial films; and oil- and grease-resistant coatings. The following suggested formulations for typical applications of styrene - butadiene - copolymer coatings offer excellent performance; . lifnliint Chir Will Aluminum Ytkich Sti/ur Intmil Flint (wt. %/ (lb.HOC ill.) (wt. K/ (lb.) Tiilfic Fun! (ptrts) Styrins-Butsdisns 16.60* 123.2* 7.40' 147* 250' ArodorW 1264 41.4 6.00 - 120' A/tdar 1210 - -- -- 31 - A/Kler 5410 1.11 41.4 13.40 - 130 Asw Tsnq Oil 1.B55 - - -- . Hydroqinslsd Methyl Abiititi - - - 1- TnyW ABC Lecithin Says Lecithin Pitrelmm Nsphihi --- 3- 0.545 - -- -- - 6.9 - -- 62.70 246.4 - -- Hi-Flssh Nsohlhi Miniisl Spirits He. 10 Tolusns Xyllni -- - - 395 - 115.3 33.60 - 340 - - - - 340 - - 22.40 - - 1<Mml m AdkH |M)| *----Ci i 9 MAE 04*0904 23 ryrrnrpTumirfM VWiiliTOTlWrTfri i mtp i i ~ - --ISU'W' tMJW. * TOWOLDMONOQ51570 lithopom Titanium Oiondi Aluminum Sturm Aluminum Put* Zinc Oxide Bmum Suflm Asbtuint 3X (migmsium silicate) Calcium Carbonali. ground Dutomicioui Erth Mica - - -- - 333. J 59.2 . 5.9 75.0 - -. 5.55 -- t.00 - 179 90 90 -- 239 79 30 t) Mi/ioi "1200" MV (Trademark of Matron Chemical Dir.. Borg-Watnir Coip.) t) fliolht S-5A (Tredtmerk of Goodyear Tin end Rubber Campon/) e) Msriot "I2M" LV (Marbon Chantical Dir.. Borg-Wirner Corp.) // Fliked fictsHu 120 (Trademark of Pennsylvania Industrial Chemical Corp.) t) Plicliu S-SB (Goodyear Tire ind Rubber Coapin/) I) k Arodor 1241 _ -- -- -- -- -- -- -- -- - In Srnlhetic And ffituril Rubber: The liquid Arodor plasticizers -- 1221, 1232, 1242, and 1248 -- have a strong plasticizing action on both natural and synthetic rubbers. Solid Aroclor -- 1254 and 1260 -- imparts permanent tackiness and adhesion ' to the rubber composition. f/tapitm Compositions containing up to 40 parts of Arodor 5460, 2565, 4465, or 1268 in 100 parts of neoprene rubber are eoctremeiy fire retardant. About 1.5 parts of Arodor 1268 per hundred parts of neoprene imparts excellent working qualities at 225' to 325* F for injection moldings. N'eoprene modified with Arodor compounds has proved extremely useful as a wire and cable coating. Arodor 5460 imparts plasticization and adhesion to decorative and protective coatings that have been commercially used on rubber products for many years. Suggested starting formulations for a clear, dull coating and for three pigmented coatings arc as follows: ' lopttditm Arodor* 5490 Neoprene GflN-10 Chlorinated rubber (21 cpj.l High-at/ren* ruin liobutYl mithecrrlatt Toluene hits kj Wtight Use lot char. MI pipmtnttd coating coiliags 3.70 19.00 3.50 1.00 1.30 - 1.00 4.31 0.40 1.75 90.10 93.17 34 "fi'i i LMrilll*l dhUfrmhn i iiilHd - MAE 040905 c i TOWOLDMONOQ51571 ingnditn(s Pst*: Bui Chromium Oxidf Zinc Oiidt No. } Titinium Dioridi Aluminum Hydriti Toluini grttn coiling whftt {high gloss} mhiti flvsur tnodiltif}* 20.0 410 6.4 16 10.5 - . 15-0 -- 10.0 31.5 23.0 - 25.0 52.0 Rt*+f to-Uu Costing: Bin Puti 10.0 70.0 son 30.0 *To modify the luster of the white, high-gloss coating, the selected amount of the modifier composition is in corporated inLo the high-gloss paste to achieve the desired degree of flatness. ftfyitli-tt Aroclor plasticizers and /ndopol* polybutenes are blended in various proportions to make permanently tacky coatings for fabric or paper. Insecticides, for example, can be blended into tuch coatings to make inaect trxpa or barriers on tree trunks for foliage or fruit protection. Such coalings can also be used for tape and aign backing. Excellent sealing and caulking compoundi are made with blends of Arodor and polybutenea with inorganic fillers, tuch as: Whiting Tile lilhwns Asti iito Ftrttnt SO 30 10 10 By various combination! of selected Aroclor compounds and poly butenes, a wide range of hardness, viscosity, flow, and bonding charac teristics can be produced in durable sealing and caulking compounds. Specialty mastics, too, are obtained by selective blends of Aroclor plasticizers with polybutenes. They have excellent adhesivity for such uses as sutomobile-body sealants. MAE 040906 25 TOWOLDMONOQ51572 Paper-transparentizing liquids (for making tracing paper, window envelopes, and special packaging) can be formulated with Arodor 5460 and polybutenes. A typical economical formulation is as follows: hfttdienl fiirctnf Arodor* 5460 30 Polybuima [Intfopo/ H*30Q) 25 . Toluint 45 Sultditni-Acqrloiiil/ili Rubbtt The Arodor plasticizers -- particularly Arodor 5400 -- are useful as softeners for Buna N rubber. SilicuH fiubbfr Arodor is a very effective flame retardant for silicone rubbers. Crtpi fii/Htr (Nitaril) Arodor 1262 is used as a low-cost plasticizer for crepe rubber in paint compositions. In concentrations of from 6 to 50 per cent of the weight of the rubber, the Arodor increases the films alkali resistance, and adhesivity to steel. PolyxuHid* Rubber Arodor plasticizers are widely used to flexibiiize, improve the bond ing strength, increase the chemical resistance, and reduce the cost of . Thiokot' polysulfide liquid rubbers. Among the many uses of poly sulfide formulations are joint-sealant compounds used in construction, solvent-resistant gaikeu, adhesives for concrete, potting and encap sulation, protective coatings, and binders. Although the Arodor plasticizers are highly compatible with poly sulfide rubbers -- up to 100 phr -- the concentration to be used depends on the handling and performance properties required in the finished compounds. Suggested concentrations of Arodor range from about 15 phr for sealant compounds to about 40 phr for casting formulations. Liquid Arodor (such as Arodor 1248) is used to reduce the viscosity and permit the use of higher filler concentration, whereas the solid Arodor (such as Arodor 5460) is useful where low volatility is desired. The following suggested starting formulations illustrate the use of Arodor 1232 in a joint sealant compound and of Arodor 1248 in a polysulfide casting formulation: ' MAE 0409417 ****=. ' re r .................. rrr - 0 TOWOLDMONOQ51573 4 I Ingrtdient fA/oAo/IP-32 polrxuffid* Thiokol LP-2 polyiullidi Arodor* 1232 Arodor 1248 Cslcium Ctrbonslt Cilcinid Cloy Titanium Dwiid# Phsnollc Rtsin Stosric Acid Zinc Sulfide Sulfur C-5 Pane* Sethnl iPtrts) 100 5-15 20 20 10 5 1 0.1 15 Cistmg Compound lputs} 100 20-40 40 0.1 15 hoftftj Cist ihsill. ihsr curt of 7 dry! it room limpsrilun: Tonsils jtrsnjth, pii 150-200 Elonpslion. porcsnl 500-700 Hsrdntn. Short "A" 30-40 150-200 300-400 25-35 ' tj lud fvtroxid*. SOS; dibirtyl ptithilits. 45X; lliiric acid. 5X: pssisd thru iimcj Uirough a ugnt paint nill. < 4 Arodor la Callulaalc Rosins In Ethyl Cslloloit Ethyl cellulose formulations plasticized with Arodor are used as pro tective lacquers, adhesives, and itrippable coatings. The solids, such aa Arodor 6460, are widely used with ethyl cellulose or cellulose acatate-butyrat* resins in hot-melt applications for the protection of tools and metal parts. The Arodor plastidzers are highly compatible with ethyl cellulose: the liquid Aroelor imparls flexibility; the solids impart hardness. For example, 75 parts of Arodor 1242 with 100 parts of ethyl odluiose produces a very flexible, slightly tacky material. Arodor 5460 at the aame concentration yields a very hard, somewhat brittle composition. Hard films that contain Arodor 4465 are not brittle at ordinary temperatures. For high-gloss coatings with exceptional weathering qualities to be applied to rigid surfaces, compositions containing equal parts by weight of Arodor 6460 and ethyl cellulose are suggested. When u more flexible coating is required, a softer Arodor should replace either all or part of the Arodor 5460. MAE 040908 17 - TOWOLDMONOQ51574 I I I In Nitroctlluiosi 21 The /ollow-ingr five typical formulations indicate the versatility of various Aroclor pluticizen in compounding for widely different types of applications. They are intended as guides to the use of Arocior compounds with ethyl cellulose. fagnd/tnts Ethyl Cilluiou Aroclor* 1254. Aroclor 1250 A/ocJor WSO Dow 276. V-l Octylphanol Si uric Acid Roll'll Trtsniun Olid* Epoxy Ruin Santonor Antioxidant Mi'mciI Oil Castor Oil Epoxidijsd Soys Oil Paraffin Wts |ra.p. 1357) Ltcqutr (pms) SO 60 - - -- Whitt A/Jct/iHtsisttnl Ltcqutr /pins) 25 16 76 1 SO I - - -- liquid Atlhtint (ptns) 50 -- 40 1 2 - -- Striptih/i Csttmq (pins) 41 49 .1 1 - -- Hot-Milt Adhtsivt (pins) 74 - 7 - -- 1 57 5 3 3 The first four of these formulations may be dissolved in suitable solvents, such as mixtures of about four parts of toluene to one part of butanol, to obtain the desired viscosity. In nitrocellulose lacquers, the Aroclor compounds can function either as plasticizers to modify the properties of the film or as resin extenders ' to add film-forming body. They are highly compatible with nitro cellulose and with other resins and plasticizers commonly used in lacquer formulations. They impart weather resistance, luster, adhesion, and flame retardanee, Their excellent electrical characteristics and their ability to retard the passage of moisture and gases through nitrocellulose films make the Aroclor compounds especially valuable in coatings for electric-insulating materials. The following trilinear diagrams (Figure 1), show the limits of practical compatibility of Aroclor 1254, 1260, and 1262 when used in nitro cellulose lacquers in combination with some other resins or plasticizers. The less viscous Aroclor plasticizers (1242 and 1248) are more com patible than those shown: the more resinous Aroclor (1268, 2565. 4465, 5442, and 6460) is less compatible. In these trilinear diagrams, compositions represented by any point in an unshaded area produce homogenous nitrocellulose-lacquer films. On the other hand, compositions represented by points in the shaded areas produce impractical (segregated, brittle, or soft) films. MAE 040909 TOWOLDMONOQ51575 fig. 1 -- Limiu oI Practical Compalibility ol A/oclor* in Nilrocallulou lacquaii .0 PHTHAIIC ANHYDRIDCGUCEROL RESIN. % MAE 040910 iitii i " i ' i'~irfrii*:nirl>rni'irti>rii^MrtWii'`tf*^T^'' ------------------- ------------ --wi~ 79 _ TOWOLDMONOQ51576 Fig. 1 (Confinutd) $1 0 AROCIOR* 1260 or 1262. % The following formulations are given to illustrate modifications thal can be obtained by variations in composition. They all have excellent durability, but the first two are much harder and less flexible than the third. The first two also have excellent sapding and polishing qualities, but No. 3 is too soft for sanding. The cable lacquer (No. i) has ex tremely high flexibility, as required for high-tension automobile cables. MAE 0*09.11 TOWOLDMONOQ51577 hgridiint Nitrocellulose (X 11c.) (vril) Nitroeilluloit {'A tic.) (dry) Nilrocellulose (15-20 sac.) Arcelor* 1242 A/ocIo/ 1260 Arodor S4E0 Dibutyl PMholili Tricresyl Phojpheli Oimor Ruin filer Cum /to. 1 bins! - 100 20-39 20-0 to -- No. } bms) 100 20 20 -- 10 No. J loins) 100 10-70 39-70 - -- No < Cillt licgvi/ bms) 103 80 - - 120 - -- Ho $ Ouom? ItCOutr ifitftSi 103 - - - - 27 32.5 - - In Cilluloit Acilitt-Bulyrttt The high-chlorine-content Arodor plasticreen are highly compatible with cellulose acetate-butyrate and are widely used in the manufacture of low-cost, flame-resistant lacquers. Typical uses for these products include paper coatings, lacquers for plastics, strippable coatings for paint booths, and bot-melt adhesives. Typical starting formulations, illustrative of these uses, are suggested as follows: Infniiitots " Pipit Itegatrs Low-Cost Fhmt Cor! Sisistml Rtsitunt (wl.K) bn. xy Chit Wocxi FiHn bn. xy Half-Second Cellulose Acitili-Butyrili 20 20 7 Arodor* 1260 - 20 - ' Arodor 1262 15 -- - Arodor 5460 - - 15 Oioctyl Pnthilitt -- tooxr Sorbttn oil -- --- Acrylic Ruin Dow 274. Vt - -- -- Bocony Vicuum 200 -- --- "Niwport V40"' pine ruin -- - - Action! -- 10 - Methyl Ethyl Ketone . -- -- Methyl Qieiotyl Kitono - -- Isobutyl Arililo 5 10 22 Ethanol Butanol liobultnol 12 10 -- 5 - -- Toluene SintotiosO Annondenl 4i 30 6 - -- Syn Fleur Ho. t odorinl Asiistint X (mtjntnura Illicit 1) -- - -- 45 1/ Coitingi lor cillophini. cilluloit iciuu. ind cellulose iciult-butyrtlt. Phstics1 Itciun (wt. %) 6 1.5 2.5 1.5 10 5 33.5 25 15 - Flint-Booth Strippihlt Comnf bn. X/ 20 9 9 9.5 2.5 10 - - 5 10 25 - - - Hot-MtN Aihcsirt iwt. Y>) 35 30 15 19.13 - - - 0.1 0 01 - "a ----- # u MAE 040912 31 TOWOLDMONOQ51578 w.-iGr-'v- Aroder In Pilot. Yirnlih. Wli. Aiphilt In Pint And Yuniih Aroclor is soluble in paint and varnish oils and solvents and compatible with most film-forming coating resins. The Aroclor plasticizers improve adhesion to the aubsirate and impart to the film properties that correspond to the particular character o( the Aroclor used: the hard, resinous Aroclor tends to give increased hardness; the viscous Aroclor imparts flexibility. Aroclor 4465 and 5460 produce paints that are very quick drying and yet have excellent durability. The amount of Aroclor used may be from 30 to 50 percent of the weight of the oils. Aroclor 1260 is best for short-oil varnishes that are required to he flexible. The Aroclor plasticizers impart water and alkali resistance and also enhance the value of the other resins used in the varnish. A sug gested starting formulation is two parts of oil, one part of Aroclor 1260, and one part of other resin. These proportions can be varied as required. The Aroclor may be considered to play the same role in the varnish formulation as oil, except that it does not oxidize and lose its flexibility on exposure. The Aroclor plasticizers do not react chemically with oils, hence there is no advantage in heating together in making a varnish. They are best added as a "chill back" or as a cold cut in the thinning operation. The only reason to heat the Aroclor js to fluidize it so that it can be more readily mixed with the oils. Alkyd, phenolic, or ester gum resins, with a harder Aroclor such as 5460, may be used in making varnish formulations. To illustrate the use of Aroclor plasticizers in alkyd resins the following suggetted itarting formulation is shown. hifttiitntz Alkyd (MX Nomolitilll . Kirill Bodild liaiiid Oil (Gardner.Holdt Vise. 2-2) ftiw litsetd Oil AtkIm (480 Trtenivm Dioiidt (RoiiliJ THmram Oioiid* (Anitm) Mtgnttiura Silicitt Mimril Spirits DrierAbiorpiwn Ajiit Pinyf Mircury Niphthiniti (10X Mtrtsrr) Cobalt Nipluhiniti ((X cobalt} Laid Niphthiniti (24X laid) * Aniukinnin; Aptnt (Volitili Type) Ptrts if Wti/hf SI 20 35 34 34 7 100 3S 1.3 2.7 1.5 3.2 0.67 ' MAE 040913 TOWOLDMONOQ51579 I t The following suggested tuning formulation for a fire-retardant enamel illustrates use of the flame reUrdancy of an Arodor in ai'xycs: Ingitditnls 3IX Phthilic Anhydind-Sova AJkyd Aroclor& WSO Solution (Arodor 5450. 53; Hi-Fiajh Niphthi. 23} Whiting Colloidal Grinding ind Oisptriing Agint Antiaony Oxide Titanium Dioxide (Rulili) fins br Wtight S3 75 14 2.7 42 33 ffrW ibart itgnditils. ml thin with: 38X Phlhilic Anhydridi-Soyi AJkyd Yylsni Cobalt Nsphthinits (IS cobalt) Minginm Niphthtnsli (IK nen^enesi) Llid Nephthtnsti (24% leed) 96 38 1 1 2.3 Arodor pluticizen are excellent grinding and dispersion media for pigments used in paints and varnishes. Arodor 1254 is used to disperse aluminum powder in a paste form that can be incorporated easily into paints and varnishes. The Aroclor imparts excellent leafing qualities, brightness, or luster and does not tarnish the aluminum pigment on aging. Moreover, the composition does not support combustion. Arodor is an important ingredient of heat-resistant aluminum paints and enamels that contain silicone resins. For example, thr following suggested formulation for a heat-resistant coating can withstand a maximum temperature of 800* F and continuous-service temperature of 400* F. The heat-resistant enamel can withstand temperatures of 900* to 1000* F in such applications as jet-engine components, exhaust manifolds, and incineraton. The heat-resistant paint has excellent resistance to a programmed heat test, including 8 hours si 1200* F. and to salt-water spray after programmed heating to 500*, 600*, and 900* F. , MAE 040914 - -- - ^................' TOWOLDMONOQ51580 la Want * "Dotr Comm} iOS " fls in (50S Nonvoliliiil G { Silicon* Rmn SR-42 (60% in rylinij G Silicon* R**m SR-IIZ (50% in xyltnt) Slrrtn-8utidi>n< (SOS in lylini) {Plio/ili S-SB) Arodor* 4465 (90S nonvolilili) 60S Arocior Solution (Arodor 4465. 36 wt. S) (Arodor 1262. 24 wt. SJ (Solnsio 100, 24 wt. S) (Xrloni. 16 wt. SI A/odor 5410 (60S In irlons) Arodor 1264 Aluminum Pitts (74S nonvoiitili) Cobalt Odotti (6S cobill) Xrlsni Miniral Spirits t) Mull Spec. TT-P-0028 HiilRisisUnt Coiling (It.H00 fi/.J 220 --' -- -- 332 314 114 - Hm-RisiUinl mmil (HUM gil.) ~ 174.2 313.3 -- 425.1 250.0 4.4 - HiilRiiistinl Punt' (It./100 gil J 33.6 ~ 207.9 - 93.1 47.1 240.0 -- 140.1 113.1 The Arocior plasticizers, especially 5460, are compatible with various natural waxes, and are blended with waxes for many uses, including '`lost-wax" casting, impregnating compound*, and inexpensive sealers. Waxes formulated with Arocior are nontacky and atable. Much of the highest quality preciaion-casting wax used in the "lostwax" process is formulated with Arodor, moat frequently 5460. 4465, and 1254. Waxes containing Arocior are widely used in making dental castings, coatume jeweiry, and preciaion-cast aircraft pans. Usually from one-fourth to one-half the composition consists of Arocior 5460, which contributes these desirable properties to the formulation: hardness without brittleness, shrinkage resistance, sharp definition, sharp melting point, fire resistance, low volatility, and volatilization without carbonization during final curing. Excellent impregnating compounds to prevent sticking of furniture drawers, double-hung windows, etc. are made from selected Arocior plasticizers, such as 5460, and various waxes. Combinations of resinous Arocior with waxes mnke excellent and inexpensive sealers for masonry, wood, fiberboard, and paper. Arocior imparts moisture and gas resistance, adhesion, alkali and chemical resistance, flame resistance, lubricity, and insulation to impregnants for doth, paper, wood, and asbestos. They are combined with such materials as waxes, asphalt, tars, sulfur, aluminum stearate, and inorganic pigments so as to provide exactly the physical charac teristics required for the specific purpose: Arodor 1254 , 4465, and 5460 are suggested as most applicable. - " Ill's I i|MS|i Mjfrtrtltttll IT'~'f lTT!`~ ~ ~~ ' MAE 040915 TOWOLDMONOQ51581 In Aiohilt In Allyl Starch % r,ur*r- -- Wood is decidedly toughened, hardened, and made more moistureresistant when impregnated by the vacuum-pressure method with the following mixture: Ingiedtents Aroclor 4-465 Microcrytullini Wsi Sulfur Pei Cent 70 20 10 . The coating is very resistant to acids and alkalies but can be attacked by aliphatic, aromatic, or chlorinated hydrocarbons. The paintabie surface is not appreciably discolored. Various degrees of hardness and adhesion are obtained by variations in the proportions of Lhc ingredients. Blends of Aroclor 1268 and 1242 have the unusual capability to extend camauba wax satisfactorily and at an attractive saving in cost: Ingredients Aroclor 1261 Aroclor 1242 Cimiubi Wsi Ciruin Wu PKidin Wsi Chirictiristicj Color Inters 10 5 5 20 60 Pill Yillow. Whit* Smooth. hi/d. non-ticky Softening point. *C Milting point. *C 60 7 Pitts by Wtight 11.6 30 35 4.9 5 5 6.9 10 30 19.6 20 20 49.0 36 10 P alt Yillow Pill Yellow Pile Crum Smooth, hird. non-ticky 77 79 Smooth, hard. slightly brittli 79 73 Slight lurfaci crystillinity 79 <6 35 5 50 10 - Crum Smootn; cirmuhl ringed surfict 90.5 99 S#lf*extinguishing asphalt formulations for caulking, roof coaLings, and sound-deadening coatings are obtained by incorporation of at least 30 percent Arodor 54 60 or other solid, resinous Aroclor. Substitution of the hydroxy hydrogen atoms of the starch moleeule by allyl groups produces allyl starch, which upon polymerization forms stable, cross-linked molecules. A minimum of 20 weight-jiereeni plasticizer is required to make the film flexibie. The aroclor plasticizers are highly compatible and very efficient plasticizers for allyl starch. MAE 040916 * 3S TOWOLDMONOQ51582 Mlsesllinious Applications Of Aroelor With their wide range of physical properties, their inertness, lubricity, and low vapor pressure -- Aroelor plasticizers are valuable ingredients in an incredible variety of formulated products. They are compatible with many solvents and oils and most resins. They are virtually non volatile and permanently thermoplastic; they do not react with other chemicals in the formulation. Finally, their low cost makes their use for special purposes eminently practical and economical. Dutl Privmiion And Dud Catching Aroelor 1254 is a low-cost dedusting agent that "holds down" the dusting of a variety of chemical materials. Since Arodor 1254 resists both oxidation and combustion, it can even be used to control the dusLing of highly reactive compounds. As a typical example, a few tenths of a percent controls the dusting of calcium hypochlorite. Since Arodor is non drying and tacky, it makes excellent coatings to capture dust, lint, and other fine, airborne particles. Glass fiber, metal mesh, and other materials used to filter air and gas streams are coated with Arodor 1260 and 5460. Vipor Svpprujion (For Longsr Inuctiddi Kill-lift) The effective kill-life of expensive chlorinated insecticides is extended as much as ten-fold by the incorporation of equal parts of Aroelor 5460, which acta both as a vapor suppressant and as a sticking agent. " Hard surface* (painted or metallic) iprayed with lindane or benzene hexachloride fortified with Arodor 54 60 remain toxic to flies, ants, roaches, and ailverfiah for as long as three months, compared with one week for unfortified apraya. The Arodor retard* the rapid evaporation of the volatile insecticides without adding odor or objectionable residue. Formulation into an insecticide is simple: a solution of the Aroclor'in a suitable solvent is _ merely added and mixed into the other ingredients. Aroelor 5460 is also recommended for noncrop insect formulations containing chlordane, aldrin, and dieldrin. The other resinous Aroelor products (1254, 1260, 1262, 4465, and 5442), also nonvolatile and sticky or tacky, likewise merit evaluation as insecticide exlenders. Msisturi Proofing In moisture-proof coatings for wood, paper, concrete, or brick, Arodor is best combined with waxes, especially paraffin or camauba; oils such as mineral oil or drying oils; or synthetic resins, including modified alkyds, phenolic*, chlorinated rubber, polystyrene, styrene-butadiene copolymers, ethyl cellulose, cellulose acelobutyrule, benzyl cellulose, or vinyl resins. The material to be used with the Arodor should be selected according to the end-use requirements of the specific ap plication. ' Some very simple compositions contain only Aroelor and paraffin. One very efficient moisture-proofing compound, consisting of 96 weight percent Arodor 54 60 and 4 percent paraffin (melting point 54*C), has MAE 040917 I TOWOLDMONOQ51583 an ASTM softening point of about 82*C. A timilar compound, based on Arocior 4465. has a softening point of about 58'C. SofLening point and viscosity when melted are further decreased by the use of mixtures of Arocior. For example, a romposilion eonlaming 40 percent Arocior 1260, 56 percent Arocior 54 60. and 4 percent paraffin, is very soft at room temperature. A higher concentration of paraffin also produces softer compounds. An excellent melt coating for paper and cloth, made according to the following suggested formulation, may be applied by knife or roller at 350F, requires no solvent, and provides an extremely flexible coating. Infitdimti Hell-second Cillulou AcilHe-Bulyriii Dioctyl Phthslati Arocior 12S0 Ssntofioi antioxidant Pttctnf 50 8.5 40 0.1 Piymint Oiioiriion - Arocior 4460 is a useful resin in rotogravure and other printing inks. It is an important ingredient in the following mimeograph ink suitable for use on bond paper: li/ndiintt A/odor* 4465 Lrbrititinj Oil (SUV 1200 (5. 1007) firaffin Oil (SUY 76 (a. 1007) Carbon Black Oil-Soluble Dyi ftreint 40 35 20 4 1 Arocior 4465 is also used in the preparation of imitation gold leaf. Bronze powder is spread upon a hot coating of Arocior on one side of a sheet of paper. When the paper treated with Arocior and bronze powder is placed on the object to be imprinted and a hot die is pressed against it, the Arocior softens, sticks the bronze to the object, and coats the powder to prevent tarnishing. Arocior 1254 and 4465 serve as pigment vehicles for decoration of glass and ceramics. When the decorated object is fired, the Arocior volatilizes without carbonization and thus avoids discoloration. Arocior plasticizers are also valuable as grinding and dispersing mediums for pigments used in plastics. Scaling And Imprignition The liquid Arocior plasticizers, 1221 and 1254, because of their low vapor pressures and Arc resistance, are excellent sealants. These non evaporating fluids have good flow at slightly elevated temperatures and are chemically stable at elevated temperatures. These liquid Arocior products therefore are excellent fluid seals wherever the use of oil would create n fire hazard. In the trough of annealing furnaces, for example, Arocior plaslicizers are dependable, fire-safe roof sealants. 4 MAE 040918 37 TOWOLDMONOQ51584 Because of their nonflammability, high resistivity and dielectric strength, and low power /actor, the liquid and resinous Arodor plasti cizers are extremely valuable impregnanls for many electrical applica tions. One important use of Arodor 1260, 4465, and 54 60 is in wire and cable coatings and as impregnants for braided cotton-asbestos insulation. Their high purity and excellent electrical resistance make Arodor 1254, 54G0. and 1268 excellent dielectric sealants: to close the pores of carbon resistors, and to seal electrical bushings and terminals. Arodor plasticizers are essential components of coatings for flame proofing cotton drill for outer garments and for rendering olive-drab canvas fire-retardant, water-repellent, and rot-proof for tents, tar paulins, etc., according to the following formulations: Flamiproofing Formula for Colton Orill Ingredients Ptrts if Wtight (A) Urai-formtldohyd* nun reonoraor 1.52 Cilalrit for rttin 0.40 Wiur 22.26 (8) Oil-modifiad alkyd ruin Arodor 1254 Arodor 5460 Stoddard sohrant 3.19 12.80 14.40 25.15 (C) Antimony oiidi, 100 mtsh or finor 12.21 Dissolve the solids in the indicated solvents, add the aqueous solution (A) to the hydrocarbon solution (B) with stirring, and then disperse the antimony oxide in the emulsion. firo-Rotirdint Wltir-Ropaflant Hot-Proof Canvas Coating Ingredients ht Cut Modified phanol-lcnmldihydi rum 4 A/aclof* 1254 15 Arodor 5460. 4 Antimony Oiidi 1 Tricmyl Phosphata 1.5 Aluminum Staarali 0.5 Coppir Maphthinati (IS coppir) 1 Mica, ground 3 Limastona. ground 6 Iron Oiida, yellow 7 Chroma Orangt 2 V M 4 P Naphtha 40 MAE 0409-19 i 9 t TOWOLDMONOQ51585 ProptrtlM Of Th< Aroelqr Pluticlnrj Mobil* Liquid] Vucous Liquid] Sufi Rjins B'itlli Ruuni Solubility Numerous applications /or the Aroelor plasticizers have been suggested and described in the preceding sections of this bulletin. Their success depends on the general inertness of the compounds and on the range and gradation of their physical properties, including physical stale, density, viscosity, melting and boiling points, volatility, and solubility. These and other pro|>crLies, as well as handling and shipping informa tion, are presented in detail in the remainder of the bulletin. The Aroelor liquids und resins are jradily soluble in most common organic solvents and drying oils. Although all Aroelor plasticizers artinsoluble in water, the hard, crystalline maLerials are generaiiy-`li- soluble than the liquids and softer resins. Solubilities of some Aroelor plasticizers are shown in Table 13. MAE 040920 39 TOWOLDMONOQ51586 o TABLE 1J SOLUBIUMS OF AR0C10R* PtASllCIZtRS IN VARIOUS SOLVENTS Sofrr*t Acid Acetic Acid Oleic Acid Bennie Acid Aroctor 1242 2TC Hot S *S I0.41* " s s -- Aroclor 124$ 25'C Hit _ -11.0^ - Aroc/or 1254 2r'c Hot Ss ss -- ArocUr J2SS CoU Hot __ --- -- Aldehyde 40 Y% F ermafd bfde Furl uni 1111 11 11 VS vs VS vs vs vs ss ss A*int AftiltM Pyridine S 132.5**^ s 440"t -- - - S s -- - nV*"" 425*R-- - - CMofs defiiitirei sAmfl cMoridtl -- mind S s s ss Cwben Telfachletide s s s s s s -- Chlwtlorn s ss s s s ss OichlMethflcne - - - - - .- - - ElhyUnt Bichloride s s s s s s s s Monechlonbtnrtnd s s s s s s -- trthodichlofe<nnn - - -- - - - - - TetiKhlontheoc s s s s s s -- TiicMwelhane s s s s s s -- Tiithlorelhylene s s s s s s -- Drying Oil Tong Oil s s s s s s --- linictd Oil .s s s s s s 1 s Eiln Amfl Acelite s ss s s s ss Butyl Actlilt s ss ss s ss ' Xflloiolri "* Acelite s s s s s s -- Cottonseed 0*1 s s s s s s -- Dibvlfl Phthalate s s s ss s ss Arochr 4445 Coin Hot ss s -. s vs - ArocUr 5440 ire _ - 11 vs. vs - vs vs vs vs -- -- vs vs vs vs vs vs vs vs vs vs vs vs vs vs vs vs vs vs VS vs vs vs vs vs vs vs vs vs vs vs s vs s vs 156 -- -- --- - - - - e TOWOLDMONOQ51587 MAE 0 4 0 9 2 1 0*ethyl Ptriholote S EthflAcetato s flhjl Llctllt s Elhyltnt Gljciil OieciUtt s Melhfl Actltlo s Tiicitiil Phosptato s Ell>er: Ethyl Ether s Ether Aicohot Ct/iiloi' H4*t Ctlloiolrt S DWlhrtint GEjct) - pj' Dtkr&otT ElMrt Etta TiF" s s s s s s s JIT**"1 s - TP*5* s s s s s s s vs s - SS ss ss ss ss ss s s. ss vs I73"t ss -- SS HyAocxten Btrnint (Uaelioe KtlOlIM MkmiU Spicila faraflm PiM OU Toluene IwptnbiM Xylene vs vs vs vs I01M-C s vs vs vs vs vs vs vs s $ vs vs vs vs vs vs vs 2.0^ vs vs vs vs vs vs vs vs s vs vs vs vs vs vs vs . vs - s vs vs vs HpJlt*y Vlvti Areyl Alcohol o-Butyl Alcohol ElM Alcohol (3-A) Gif ceeinc Milhyl AlteSal Phenol - MX Ktlont: Actum. s s 13.1"`t 1 IB"11- s s s W,0""t 1 s s ---- --- -11 - .--- --- s s lljlrt 1 iV*1* SS s Miictllontoui Cbon Oiiulfid* Nitroheoiene Wolti s s ---s s s ---s 11111 I -- Insoluble S3 - SliyMIf Soluble S -- Soluble VS -- Very Soluble. figure* ihew grams ol Aroclor ptr 100 milliliters of solvent tl 25*C unless otherwise indicated. s s s s s s s 15*" s - I0*l't vs vs vs vs s S vs vs vs s s 28^ 1 2'2.2'*^ s s s s 1 -- SS 1 - SS -- s 1 1 - s SS s -- s s s s SS 1 1 1 -- SS 1 s - 1 -S SS s s vs - vs SS s -- SS sS s SS ss -s - SS s vs. - vs s vs s vs -- 3.0 ss s . vs s vs s vs ss SS SS 1 SS 11 - SS ss 1s s vs -- vs 11 vs vs vs -- vs -- s-- s-- -- - -* --- -- - vs M3 vs vs vs ssvs M2 vs -- vs 178 ss - -1-- s-- s 2S0 vs -- --- 1- MAE 0 4 0 9 2 2 TOWOLDMONOQ51588 TABU 14 CHEMICAL AND PHYSICAL PROPERTIES OF REPRESENTATIVE AROCLOR PLASTICIZERS AND RESINS Ftoptrty Appeirinct Arociot 1221 asr. mobile oil A teclot 1222 Clear, mobile oil Arociot 1242 Clur. oiobili oil Arociot 1244 Cleir. mobile oil A toelot I2S4 Light-reflow . menus liquid ' 1 Colot. miumum Chloiim. psrcint Acidity, mg KOH/g. muimu* *100 APHA 20.5-21.5 0.014 100 APKA 31.5-315 0.014 100 APHA 42 0.015 *100 APHA 41 o.oio 100 APHA ; 1 ----------------------- -i 54 I i *0.010 Moislitti. ppm. muimum - - 60 *50 50 Art. Coil/kitnt 0/Csptnsian. cc/cc/'C 0.00071 (ir-wx) 0.00073 (25'-100X) 0.00061 (25--I5X) 0.00070 (2E'-15X) 0.00066 (2S`-!5C*) Specific Gouty 1.112-1.112 (25715.5X) *1-270-1.210 (25715.5X) 1.311-1.332 (25715.5*0 1.405-1.415 (85715.5X) 1.495-1.505 (65715.5X) Density, pounds per-gellon. 2SX 1.15 10.55 11.50 1104 12.12 Distillation Ftnpl. X. ceneclid (ASTM 0-20. modified) 275-320 210-325 325-366 340-375 365-390 Irepottlion loss. X. 100X. 1 hours (ASTM D-E. nod.) 153X. 5 hours 1.0-1.5 1.0-1.5 0-0.4 3.0-3.1 0-0.3 3.04.0 0-0.2 1.1-1.3 Flesh Feint (Qivslond Open Cup). X 141-150 *F 216-302 152-154 305-310 176-180 341-356 113-196 373-314 None to boiling point Fin Feint (Qevelond Opin Cup). X 171 231 Non* to None to None to 'F 141 400 toiling point toiling point boiling point Four Feint (ASTM E-17). X 1 (cnrstils) -35.5 -13 -7 10 X 34 (crystals) -32 2 13.4 SO Settmini Feint (ASTM I -21). X- - - - - *F Fi/rictin tadei. n 0-20 20*C 1.117-1.111 1.520-1.122 1.127-1.121 1.630-1.631 1.131-1.641 Viscosity. Ssconds Siyholt Univerill (ASTM D-H) 1007 (37.IX) 1307 (64.4X) 2107 (JI.IX) 3141 35-37 30-31 44-51 3941 31-32 *12-12 43-56 34-35- 115-240 *73-10 36-37 1100-2500 260-340 44-41 42 HA 040923 YTiu Wn OH MOfTiHAfrr'ii rr IHMH r -- 7- r'- i>ninMw|i imi . goe^-a-ieery*- v < TOWOLDMONOQ51589 tt bZ60*r0 3VH 1------------------------- - (a.OCl - J.99Z) - 051-C4 oov ooc 001*99. I3.1Z :d.09l) 059*009 8 L-U. oosv-oozc - S99*l*099*1 - ZHTWt'l - nsri-iotfi 6WTZHI [luiod tCC ZOC PlM)OZl*OSl. m-m soi-st. luiod Su;|joq 01 non lujod Bu|||oq 01 IUN "" lujod Auipoq oi auopf lUjod Sutfroq 01 tuN zti-m ZZ-II. tii-wi M-OS. " >in*d >iu|ioq -- 01 non luiod *(K^ "" 0) non tzi-su zsn. " 911 M 8MC r*< Ott< imod 01 non Ut Lil lUfld 11 non " 81 It lujod h>!i;oq 01 NON luiod &ui|ieq 01 iuofl ro-i-o 90 0 0 ED'O co-zo co-ro ZO'O-fl ro rt-s'o 180 n>-o ro-so ro-o OSV-SCV (H 5) SCt-MZ (H Tm* V) (H '"i* V) -- ozt-ocz OOC-51Z szv-oc 0ZV-S9C WSl la.jy.sz) un-wi O.ooi-.ozi ztoooo - irti (3.SZ/.SZ) OZJ'l (a.vzi-.sz) ULOO'O - *rn (a.sy.sz) KZ'l (0.99-.SI) WOOO'O - irn (isy.sz) om (3.5J-.JZ) 190000 - VZ*Zl ia.sy.sz) azn (3.W-.SZ) CZIOO'O - ZZ'El (3.S'9l/.M) cm-us'i. (a.st'.sz) rtoooo - orci (a.rsi/.08) 985'l-SSS'l. (3.001*.OZ) 90000 09. soo# M SO'O. S'w-S'n VI SI (uiiipui) VdN S I. (UIIJOIS) VdN Z. jopMod 01 1!MM MI| jo uijj ifimq `jiqurt-oi 0||i* -I|3 Ujtlj l|nq 'inbido 'j(M|g tm jofoojy ms /OfOOJf SIS! JOpOJ/ 90'01 St (uiuoui) VdN Z. m zv |<lU0Ul) VdN Z. HO'O. 578'S'IS VHdV 0S1. UIIIJ M*I3 ssn JOfXUf uiiij A^pill JM||li jo UIIIJ imoiia MoiiiJi.iNtn ms jofMY mi tO/MJf VIO'O. 09 VHdV 0S1. 1 uiiij iv"* 1|0 MO|/iA*njdn I j OStl jopojf j TOWOLDMONOQ51590 Oanstty AJ1 the Aroclor plasticizers are heavier than water, a valuable property /or many applications. Densities are shown in Figure 2. A baotut* CHntJty, f./o c . t*ci(ic Vtkii Fif. 2 -- Denirim si V*clr* Plasticirtrs it Various Tmptrituris . 'i j i l The ipecific volume of Aroclor 1243 at different temperatures is as foUowi: Timftfrtm rn 0 100 200 100 400 too too Artcht }J4I St+ciHc Vtlumt (till/) 0.174 o.m 0.726 0.755 0.7W * 0.121 0.170 ' MAE 040925 nomnws lira*'- TOWOLDMONOQ51591 V&JilHrtT The low vaporization loss of Aroclor plasticizers ii indicated in Ttbie 15. TABU IS VAPORIZATION RATES OF AROCLOR* PLASTICIZERS Phstkiiv (Strftct tfu: J2J$ if. at.) Wt. let: It) iipoim tt tore Hr.) Vipommen ///Jf. CJO.Ihl.) A/oclw 1221 0.5125 24 0.00174 Artdot 1222 0.2572 24 0.000074 Arttiw 1242 OJBtt 24 0.000331 Arsdor 1244 0.0441 24 0.000152 Outfit'-tt-S 0.0745 44 0.000124 Oisciyl Atrthaisu 0.0441 44 0.000117 bxiw" 25 ' 0.0254 24 0.000057 Artdsr 1254 0.0154 24 0.000053 ShtH Dttru 20 0.0047 24 0.000015 Arodw 1212 0.0001 24 0.000013 Artdor 1210 0.0021 24 0.000009 Artclir 4441 0.0014 72 0.000007 Andsr 1442 1.0031 72 0.000004 Artdsr 54*0 0.0032 72 0.000004 Trjosryl ptatphtts 0.0010 24 0.000003 It is concluded that the vaporization rates of Aroclor plasticizers -- especially the moat widely used 1254 and 1260 -- compare most favorably with the similar constants of other plasticizers selected specifically for these tests because of their low vaporization rales. MAE 040926 45 fW 1 ~r' TOWOLDMONOQ51592 Vapor fin ran The vapor pressures 0/ aeveraj Aroclor plaslicizen are indicated in Figure 3 over the temperature range 160* to 300*C. -j. 1 10* T. *K Temperature, *C Fig, 3 -- Vapar fratsurts il Arador* fiirticLnn The estimated vapor pressures of aeveral Aroclor plasticizers at 100*F shown in the following table were determined by extrapolation from the values shown in Figure 3. Afpnimttt Ytfcf hiurn if Anchr* Fhstkiim filmittS rtfOff (31T CJ Arador 1232 8.006 mat Hg Arador 1242 0.001 net. Hg Aroclor 1241 - 0.00037 aia. Hg Arador 1264 0.00001 mm. Hg MAE 040927 TOWOLDMONOQ51593 VueairtY The vi*coitii of the Aroclor pl*4ticizen vary according to whether the base material is a biphenyl or a polyphenyl and on the degree of chlorination. In general the low-chlorinated biphenyls have the lowest viscosities (Figure 4). ' Stabifity , ^ Ttmtri Alkthtt The Aroclor plasticizers are remarkably resistant to the action of either hydrolyzing agents or high temperature. They are not affected by boiling with sodium hydroxide solution. Tmri Adft No hydrogen chloride was evolved when Aroclor 1254 was stirred with an equsd volume of 10 percent sulfuric acid for 160 hours. Even after prolonged treatment (265 hour*) with concentrated sulfuric acid only a alight trace (too small for quantitative measurement) of hydrogen chloride was evolved. Tmi Hut Because of their stability to heat, the Aroclor plasticizers are useful heat-transfer media. Aroclor 1254 and particularly the less viscous Aroclor 1248 are recommended for this purpose, because they may be heated up to 316*C (600*F) in a dosed system for long periods without appreciable decomposition, and because they are nonflammable. Tnurt llfkt The Aroclor plasticizers have good light stability in heavily pigmenled compounds and fair light stability in dear formulations. The materials become discolored, but their physical properties ire not degraded. For critical applications, incorporation of a small amount of a light- HAE 040928. - -iwtun MUM Aw-s***U*--r i. s - 47 TOWOLDMONOQ51594 acreening agent greatly improves light stability at reaionable cost. The following data how that aa little u 0,01 percent Tinurnn p jn Aroeior 1254 nearly doubles the service life in the 60-lo-100-hour range and that 0.1 percent Tinimn P results in a 10-fold improvement. Tinnie F Ctetitlnlree M Fidt-OmHu Eipoiuit (hears) 0 SC 100 HO 100 Cthr (CtrSAtf Utits) 0 0 6 10 11 14 0.01 0 1 1 7 14 0.05 0 0 3 4 11 0.1 0 0 1 2 1 Tentrt Ozktlioe When Arodor plaitidzen are heated to 140'C with oxygen in a bomb at 250 pai, no evidence of oxidation occurs, as judged by abaence of sludge formation or increased acidity. Also, no increase in acidity occurred after 4 hours healing with air at 260*C and 210 pai. Nwiflamnsbilifr The vixcoui Arodor liquids and the reains do not support combustion when heated alone, even at their boiling points -- above 350'C. Most of the Arodor plaatidzers flux readily with resinous and pitch-like material* to give products with decreased fire hazard. Arodor products incorporated in plastic products and rubber foams retard the rate of burning. honoring Naawlias AM ThanwelastidtT The Arodor plasticizers are nondrying. When exposed to the air, even in thin films, no noticable oxidation or hardening takas place. Despite thi* property, Arodor plasticizers do not retard the drying rate of lacquer films. Quick-drying varnish ea and paints may be made with Arodor resins without iflect on drying characteristic*. The Arodor plasticizers are permanently thermoplastic. They appar ently undergo no condensation or hardening upon repealed melting and cooling. Clear Arodor resins are available with softening points up to 105*C. The opaque crystalline solids are available with mdting points up to about 160*C. Electrical ftafertias The electrical properties of Arodor plasticizers are extremdy interest ing: high reaiativity and dielectric strength and low power factor,' as lilted in Table 16. The dielectric constants of the various Aroclor plasticizer* range from 3.3 to 4.9 at 100*C and 1000 cydea. 41 MAE 040929 TOWOLDMONOQ51595 How To Ertulifr Areclw , TABLE II ELECTRICAL PROPERTIES Of AROO.OR Andor DitkcUk Ctntlmt (ASTM D-lSi-47Tj 1000 prhi :rc too-c Volumi Atsistrrtry /ASTM 0-2S7-4S) S00 Vtkj D.C. lore (tAm-cm.J Forrtt Dit/ictnc Ftctat Sl/tnflA (ASTM 0-I50-47T) (ASTM D-US-44) 1000 erdts. 100" C (KYI w 1232 5.7 4.1 1212 5.1 4.1 Abert 500 * 10- Abort 35 Btlow 0.1 1241 l.f 4.1 Abort 500 i 10* Abort 35 tiiow o.i 1254 12S0 5.0 4.3 Abort 500 i 10* 4.3 3.7 Abort 500 i 10* Abort 35 Abort 35 Below 0.1 Below 0.1 1211 2.5 5442 3.0 4.1 Abort 500 1 10* 5454 2.7 4.2 5440 2.5 3.7 4455 2.7 13 EmuUiotu of Arodor plasticizers cn be made simply in several ways; the method can be (elected to ruit the particular Arodor and the type of formulation in which it will be used. ImilsHMlt Sltei S*lrtk*i / A/pehr Stock (olutioni made according to the following formulation are readily emulsified with water. The amount of toluene may be increased as needed to dissolve the more resinous Arodor plasticizers. ItfrrAkwt Artdor Ttlttfie Uovrtfinsl Surer* CO (nenitnic etniHiHitr) Swittmtrtt* Nt. 3 (inionic witlinf tfint) Ftrts Af WtifAl 71 11.70 3.15 1.00 0.75 Fmthtfjitf lift# Arwchf UfrtSiut ftnitt 1 A/kIw 1254 Oltic Ad4 hrtkt 2 Witt/ Amrfomurr Hydrotidi |2IS) firti At WtifAl 100 4 " 100 2 HAE 040930 TOWOLDMONOQ51596 Mix the polystyrene and ammonium hydroxide in-warmed water with vigorous agitation. Mix the Arodor 1254 and.oleic acid, heat to <5'C, and agitate vigorously. Maintain the 45*C temperature and agitation, and slowly add in the aqueous portion (Portion 2). Continue agitation (or one-half hour until phase inversion is complete. imtlslljlirf y/icars Ateciat ItifuJiml Perth* / ' A/#dor12H Slssric Acid Perth* 2 Wstsr Tristhaaolimini Ptrtt >r Weifht H 4 32 1 Heat the Aroclor to a workable viscosity (180*F or higher) and stir in the stearic acid thoroughly. Heat the water almost to boiling (207'F) and atir in the triethanolamine thoroughly. Pour the Aroclor-stearic acid portion into the water-triethanolamine portion with vigorous agitation. Process the combined portions either with a high-speed emulai/ying stirrer or through a colloid mill. Taxlclty (tad late Hsntfhsf ' leJuiith* At ordinary temperature* the Aroclor chlorinated polyphenyls have not presented industrial toxicological problem*. The hazard of potential toxic exposure varies with their volatility: the lower-chlorinated, morevolatile ones present more of a potential problem from the standpoint of both inhalation and skin contact. When Aroclor plasticizers are used at elevated temperatures, engineering controls must be applied, either by the use of closed systems or by effective local-exhaust ventilation together with general workroom exhaust. Vapor of the liquid Arodor plasticizers at room temperature should not be breathed in a confined space, and no vapor of any Aroclor evolved at elevated temperatures should be allowed to be dispersed into the genera] workroom. Inhalation testa on animals indicate that ths maximum safe concen tration of vapor is in the range of from 0.5 to 1.0 milligram of the lower-chlorinated Arodor plastidzero per cubic meter of air. The threahold limits (maximum allowable concentration for an 8-hour working day) aet by the American Conference of Government Hygieniitc arc 1.0 milligram of the lower-chlorinated Aroclor compounds per cubic meter of air and 0.5 milligram of the more-highly-chlorinated compounds, such as Aroclor 1254, per cubic meter of air. Ski* Cettect Schwartz patch tests on 200 volunteers showed that Aroclor 1254 was neither a primary skin irritant or a sensitizer. MAE 040931 TOWOLDMONOQ51597 r Cootinuoui or repeated akin contact with the Aroclor plaaticiierc nun be avoided by the uae 0/ giovea and protective garments, becauie of the poaaible occurrence of a condition called chloracne. Although report* of thia condition earned by Arodor are rare, it can be produced by excessive alcin contact. If any Aroclor ia apilled on the akin the akin ahould be waihed in the uaual manner with a aoap aolution. A bum exuaed by contact with a hot Aroclor ahould be treated like any ordinary bum. Arodor plaitidier adhering to the burned area need not be removed immediately, unless treatment of the bum demands it, in which caae either aoap and water or repeated washing! with a vegetable oil are recommended. Frtighi Clauificatxtm Arodor 1221, 1243, 1242, 1248, 1264, 1280, 1282 Synthetic Resin, Liquid, NOIBN Rad Clatrifcaiion Arodor 1288, 2665, 4465, 5442, 5460 Synthetic Reain, Other Than Liquid, NOIBN Traci Clattxjication Arodor 1288, 2665 Arodor 4465, 5442, 6460 Synthetic Ream, Powder, NOI Synthetic Reain, Lumpa or Solid Man, NOI Rtgalaiumt None Standard Conlaintn Arodor 1221 Arodor 1282 Arodor 1242, 1248, 1264, 1280, 1262 Arodor 1288 Arodor 2665, 4465 Arodor 6442 Arodor 6460 (flaked) Tank car, 520-lb. ateel drum, 60-lb. can Tank car, 550-lb. ateel drum, 60-lb. can Tank car, 600-lb. ateel drum, 50-lb. can 200-Ib. fiber drum, 25-lb. fiber drum 500-lb. ateel drum, 50-lb. can 450-lb. ateel drum, 50-lb. can 100-lb. bag MAE 040932 51 TOWOLDMONOQ51598 DISTRICT SAi.ES OFFICES ALL DIVISIONS ATLANTA. GEORGIA 30326 Ltnas Ttwtn *rl 3400 /'Iicfum Ad. N. L- Su/lt 1711 UL (404) 577-2260 BOSTON. MASSACHUSETTS 02149 r*trt Slitlon TtL (617) 397-5010 CHICAGO. ILLINOIS 3153 0*4 Ahfr}*t An. On PlthttL HUnoti 60019 ' . TtL (312) 236-6633 CINCINNATI. OHIO 45206 1501 Mtdkan Aetd T*L (513) 751-6707 CLEVELAND. OHIO 44122 3645 WtntnrvW* Ctnt* Ad TtL (216) 391-5400 DETROIT. MICHIGAN 48235 600 NofMtnd Ttwtn tn 1*1. (313) 367-0910 HONOLULU. HAWAII 96812 205 AkM'k Irxtfntiknt/ 9tdg. 677 Alt Mott IM, P. 0. 9oi 3324 1*1. (303) 512-744 HOUSTON. TEXAS 77002 1300 4*41 Strr* TtL (713) Ctf*o! 3-4011 LOS ANGELES. CALIFORNIA 90022 6670 . fhlilit 5L TtL (213) 723-2492 MINNEAPOLIS. MINNESOTA 55402 912 Natlhtt* Ctnt* 110 S. StvtnOt SL TtL (612) 339-49S1 NEW YORK. NEW YORK 10017 277 P*t Artnu* TtL (212) 933-4111 PITTSBURGH. PENNSYLVANIA 15222 Nt. 4 Gtinny Ctnur MUf. Atm 534 TtL (412) 361-2154 ST. LOUIS. MISSOURI 63166 900 N. LMbwfA ihrd. TtL. (314) 0**4 4-1000 SAN FRANCISCO BAY AREA 3716 L*twr*4*. i*rn Ckn. cut. 96063 UL (4064343-0614 SEATTLE WASHINGTON 98104 Additions/ Dfrtrfct Offices rt milntbln+d by: Agricultural Olvltlon IUUNG. LOUISIANA 70070 P. 0. lot 174 2*L (904) 744-9293 MEMPHIS. TENNESSEE M114 1073 AnrariM 0* P.O. ku 11741 . Tl. (901) 7.31 It Tortile* Dhrtalon AARON. OHIO *4313 3030 Wmt MM Sl T#L (219) 139*7*41 ATLANTA. OEOROIA 30401 Ai*mj Mtfl 240 P**cM *1. K. W. TM. <404) 177*13*0 CKAALOTTL NORTH CAROLINA 21307 Wxftmt 129 WwfTf*e Sl T*L (704) 279*9971 EKQUWOO CUFFS. H. J. 0701 Ml rtfmitm Ajt*. TL (201) 944*3111 HCW YORK. HEW TOM 330 FVth Av. TN. (201) 941-9100 Hydrocarbon* k Potymari PHrWan-Uon OU 11 OOfLAOO, ARCAKVAI 717)0 Um 04 Mfc| TH. (101) UM Mill JACUON. UfUTUIPFI 29209 f. 0. ki 10927 Wann< tMi TH. (01) 342*3*41 L/TTU ROCK. ARKANSAS 72203 1111 VM Mm m+ *. 7L (101) 4*1437 UlMPHr*. TfHNfltll 3*113 1023 Hhwtt DtN* P. 0. Set 13741 Ttf. (901) VRWimm* 7*3111 WLJtm ***1-6203 SPmmFKLD. /MASSACHUSETTS 01101 730 WmmttwAm. TtL (413) 796-aif WILMINGTON. DELAWARE 19803 200S Coocofd Plkt. ftMiti TtL (302) OLrm*l* 4-6631 MONSANTO, toe N. LINDBERGH BLYO. Organic Chamlcat* DlvUlon (Aubb+r Industry) AARON. OHIO 44311 920 3fumr\ t>w P. 0. Ua 2307 TL (319) HmM 4*1921 ST. LOUIS. MISSOURI S3!St j I i J i J [ f [ , j ! . . . j ( [ \ i . ) 1*2*41 MAE 040933 i ffimm ihmo m y. a. 9 < TOWOLDMONOQ51599 MAE 040934 MONSANTO. tOO N. UNOBENGH &LYB., ST. LOUIS. MISSOURI SJItt t ,--Li * TOWOLDMON0051600 TOWOLDMONOQ51601 lonsanto O I Willis S. Clark - General Offices May 14, 1970 1200 SERIES AROCLORS; Removal of Products from Market D. H. Bechtold - Chicago R. N. Brell - Wilmington E. H. Fording - New York R. V. Johnson - .RJOHN J. J. McNamara - Everett E, C. Wilde - Akron G. W. Buhrmann - GBU11R F. M. Luckett - Chicago W. B. Papageorge ^-WPAPA W. F. Waychoff .. J. D. V/rlght - JWRIG CONFIDENTIAL A8 all of you are aware, Monsanto has been In the process of evaluating our polychlorinated biphenyl (Aroclor) products since late last year, I would like to bring you up-. to date on the present status of these evaluations and to present our plans for these products for the next several months. . .- - ' r i. On May 11, John Mason presented our proposed course of Y action for polychlorinated biphenyls (PCBs) to the Corporate ' Management Committee. In that presentation, he made two basic recommendations; first, that we market non-bio- -' degradable PCBs only for closed system applications "" where control over disposal is possible (e.g. trans former fluids). And second, that we phase out of all non-biodegradable PCB products where control is not : '. possible and replace these materials with biodegradable PCBs or other suitable products. The Corporate Management Committee approved these recommendations. . In the plasticizer area, none of our applications are considered to be of a controllable nature. This means that we will be starting immediately on the Job of re moving non-biodegradable PCB Aroclors and Montars from the market. We will not be able to ship any of these materials after 8/30/70. This will include Montar 1, Aroclor 4465, Aroclors 1232, 1242, 1248, 1254, 1260, 1262, 1268, and the 1100 series Aroclors. Aroclor 1221 will not be withdrawn. The 5000 series Aroclors will not be removed, from the market; indeed, they will figure in our replacement plans. _ - : TOWOLDMON0051602 Regional Managers 2- - May 14, 1970 The plan of action which we have established at thiB time to accomplish the removal and replacement of PCBb is as follows: ' 1. Contact AMSCO and Central Solvents central offices to " Inform them of our plans. This was completed in early May on a confidential basis. The regional offices should not have been contacted by the central offices. 2. Contact and to inform them of our ` plans. Once again, this was accomplished in early May on a confidential basis. 3. Contact other key accounts. This should be done by the field sales people during the week of 5/25/70. Complete the lists of suggested replacement produces for Parlon, styrene butadiene, PVAc and polysulfide sealant systems. These are being compiled now in St. Louis and will be sent out as soon as is possible, at any rate by 5/27/70. - 3. Contact all distributors and inform them in writing of our decision to remove these products from the market and to stop all shipments on 8/30/70. The distributors will be notified by mail from the ' St. Louis office on 5/29/70. . 6, Contact all direct customers and Inform them in' writing of our decision to remove these products from the market and to stop shipments on 8/30/70. The direct customers will be notified by mall from St. Louis on 6/1/70. Both the distributors and the direct customers will be requested to contact the field sales offices on all questions concerning timing and replacement products. 7. The time between 6/I/7O and 8/30/70 will be a frantic, frenzied period when the objective will be to achieve 100$ conversion of the required . products in a completely orderly fashion. In all seriousness, that should be our objective. Need less to say, it is bound to--tax our capabilities, not to mention our frustrations. Just a bit. ha c n a. n 7 4*9 TOWOLDMONOQ51603 Regional Managers -3- Hay lit, 1970 8. On 8/30/70, we v/ill discontinue the shipments of the non-biodegradable Aroclors listed above. 1 think that I am aware of at least some of the problems that this removal of products from the market is going to cause you people. Also, the tight time schedule is pro bably not going to make life any easier. On the other ' hand, we feel that in the interest of equal treatment-'.to all accounts, it is important to stick to the time-table shown above. Therefore, please do not contact any cus tomers on this subject prior to 5/28/70. Also, would : each of you send me the list (as short as feasible) of key accounts which you would like to contact the week of 5/25/70, This will be used to check to see whether we are all interpreting "key account" basically the same way. I will need that list by '5/22/70. . .1 am very interested in your response to this plan. I know that I haven't left you much time for reply, but please let rnc hear from you anyway. /dbw Willis S. Clark (AA& 0607^0 TOWOLDMONOQ51604 TOWOLDMONOQ51605 MONSANTO CHEMICAL COMPANY DISTRIBUTOR CONTRACT CONTRACT between Monsanto Chemical Company, .-ne:-:'.can Mineral Spirits Company ------------- WrUkS* a WHlU OU. MU/Mf ---_________________ :____________________ ("Distributor1'). St. Louis 66, Missouri ("Monsanto") and of Murray Hill, Haw J^vsav -------------------------- ------------* 1. "Monsanto hereby appoints Distributor a non-excluslve distributor of the following products (the "Products") and sells the Products to Distributor subject to the terms and conditions stated below and on the reverse side hereof. PRODUCTS QUANTITY PRICE tc PACKING F.O.B. TERMS *In C/L or T/L cf drums (LCL will be shipped only in an emergency) and/cr cankcar and/or tanktruck quancities- . See Attached Exhibit A *In fi/l or T/L of drums (LCL will be shipped only in an emergency) herair.aria referred to as ''Proprietary products"- See.Attached Exhibit A Less 57. Service Allowance Price' and packing &FOB point & terms on attached Monsanto price s'neej Sxhlbi B attached hereto, QTY. estimated at 2,000,000 lbs, of all types. 2. While nothing In this Contract shall restrict the territory within which Distributor shall be free to distribute the Products, Distributor's area of primary responsibility for distribution of the Products (the "Area") shall h*- East Coast from New England states to Florida and including _ Atlanta-Nashville areas._____________________________________________________ 3. Distributor shall exert its best efforts to exploit fully the potential markets for the Products In the Area. Monsanto plana to maintain-'an advertising and sales promotion program and to furnish Dis tributor with current literature and information concerning the Products; the scope and frequency of such advertising and sales promotion to be determined by Monsanto. 4. Monsanto reserves' the right to make sales direct to customers located within the Area. Without limiting such right, .Monsanto does not expect to solicit 3mall order business for the Products In the Area, but expects to refer such Inquiries to Distributor, except with respect to accounts whose established policy permits purchases only from manufacturers and trial shipments for experimental work. _ 5. Term'. One- (1) year commencing--.______ January 1._________________________________ 19_x?__ cSfyi'iSuL^ danceear^u^ra^dea` af ^fs&ng^on^racts by and between Monsanto and Dis tributor for the distribution and sale of the Products. MAE 060388 MON! CHEMICAL COMPANY Date: January 26, 1962 Sales Minager Plasticizers & Rubber Chemicals Organic Chemicals Division Date: November 27, 1961 TOWOLDMONOQ51606 a Deliveries may be suspended by either party 13. Monsanto warrants that any Product sold In of Act of God, war, riots, fire, explosion, flood, pursuant to this contract, except as Is made speci strike, lockout,' injunction. Inability to `obtain fuel, fically for Distributor according to Distributor's spe power, raw materials, labor, containers, or transpor cifications, does not infringe any valid U.3. patent tation facilities, accident, breakage of machinery or This warranty Is given upon condition that Distribu apparatus, national defense requirements, or any tor promptly notify Monsanto of any claim or suit In cause beyond the control of either party, preventing volving Distributor In which such Infringement Is the manufacture, shipment, acceptance, or consump alleged, and, If Monsanto Is affected, that Distributor tion of a shipment of a Product or of a material upon permit Monsanto to control completely the defense which the manufacture of a Product Is dependent. or compromise of any such allegation of infringe If, because of any such circumstance, Monsanto Is ment. Monsanto does not warrant that the use of unable to supply the total demand for the Product, any Product sold hereunder, or articles made there Monsanto may allocate Its available supply among from, either alone or In conjunction with other ma all of Its customers and Itself In an equitable manner. terials, will not Infringe a patent. Such deliveries so suspended' shall be cancelled with out liability, but the contract shad] otherwise remain unaffected. L4. The quantity shipped In any contract month may be limited by Monsanto to either: (a) the average of the monthly quantities ordered by 7. In the case of bulk carload, tank car, or tank Distributor hereunder for the preceding contract truck shipments, Monsanto's shipping weights shall months, or (b) the maximum quantity covered by govern. this contract divided by the number of months In 8. Where shipment requires use by Monsanto the contract period. of carboys, drums, barrels or other returnable con tainers, title to such containers shall remain In Monsanto and a deposit In the amount required by Monsanto must be made at the time the Products 15. Monsanto shall not be bound to tender de livery of any quantities for which Distributor has not given shipping Instructions. are paid for to Insure the return of the container to point of .shipment. Such container must be kept in good condition and may not be used for any material other than that shipped therein and must be re turned within sixty (<KI) days from date of shipment. I.C.C. regulations require that empty drums must have filling and vent holes properly closed and empty carboy- must be thoroughly (completely) drained. On such containers being so returned In good con dition, a refund of the deposit will be made. 18. The price, point of delivery, service allow ance, If any, and terms of payment herein specified for any Product may be revised as of the beginning of any quarterly period commencing on the first days of January, April, July and October after the date hereof (Including the first such quarterly period), by written notice from Monsanto dispatched not leas than fif teen (15) days prior to the date on which any such quarterly period Is to commence. If Distributor does not serve Monsanto with written notice of objection 9. Monsanto makes no warranty or represen thereto prior to the beginning of any quarterly per tation of any kind, express or Implied, with respect iod, the proposed revision will become effective at to any.Product sold hereunder except as provided the start of such quarterly period. Distributor's writ In Condition 13 hereof. Monsanto shall not be liable ten objection to such proposed revision served upon for, and Distributor assumes responsibility for, risk Monsanto prior to Its effective date shall permit of loss or damage resulting from the handling, pos Distributor to purchase elsewhere the quantities due session or use of the Products, whether alone or In during the ensuing quarterly period If Distributor combination with other substances. Claims on ac shall be able to purchase such quantities from re count of weight, quality, loss of or damage to a sponsible United States manufacturers of the Prod Product shall be made in writing as promptly as pos uct, and shall have furnished Monsanto with satis sible. Monsanto's liability for losses or damages from factory written evidence of bona fide offers by such all causes shall In no event exceed the purchase price manufacturers and Monsanto shall have elected not of the particular delivery with respect to which such to meet such offers, In which event Monsanto shall losses or damages are claimed plus any transporta be releasecrfrom Its obligation during such quarterly tion charges paid by Distributor. Unless otherwise period. If Monsanto desires to revise the price, point specified,- Monsanto's standard specifications for of delivery, service allowance, or terms of payment quality shall govern. Transportation charges for re pursuant to this paragraph, but Is restricted to any turned goods shall not be paid by Monsanto unless extent against so doing by reason of any law, decree, authorized by Monsanto. order, or regulation of any government, or If the 10. Any Increase In freight rates paid by Mon price, point of delivery service allowance, or terms santo on shipments covered by this contract, may, of payment then In effect under this contract are at Monsanto's option, be added to the price of the altered by reason of any law, decree, order, or regula Products shipped under this contract. tion of any government, Monsanto shall have the 11. Any tax or governmental charge or In right to terminate this contract. crease In same hereafter becoming effective Increas ing the cost to Monsanto of producing, selling, or delivering the Products or of procuring materials used therein, and any tax now In effect or increase In same payable by Monsanto because of the sale of the Products such as Sales Tax, Use Tax, Retailer's Occupational Tax, Gross Receipts Tax, may, at Mon santo'S option, be added to the price herein specified. 12. Monsanto reserves the right, among other remedies, either to terminate this contract or to sus pend further deliveries under It in the event Dis tributor falls to pay (or any one shipment when same 17. Should Distributor at any time any ship ment Is due under this contract be offered a lower delivered price on material of equal quality, In like quantity as the shipment Involved, for the same use by a responsible United States manufacturer of the Product and furnish Monsanto satisfactory proof of same, Monsanto will either supply such shipment at the lower price or permit Distributor to purchase such quantity elsewhere, and the quantity so pur chased elsewhere will be deducted from the total quantity of this contract. becomes due. Should Distributor's financial respon 18. Distributor may not assign Its rights under sibility become unsatisfactory to Monsanto, cash this contract without the prior written consent of payments or satisfactory security may be required Monsanto and any attempted assignment shall be by Monsanto. .<C Paragraphs 19, 20 21, 22, 23, 2 See Exhibit A MAE 0 6 0 3 8 9 TOWOLDMONOQ51607 MONSANTO CHEMICAL `CCMPAITY DISTRIBUTOR CONTRACT HITH AMERICAN frHNERAL SPIRITS 0; DjiTED EXHIBIT A The fcllcv/ung pucduc ts are offered in Paragraph 1 of the distributer cca:ra: *In C/L 6r T/L of drums (LCL will be shipped only in an emergency) and/or oar.'u- car and/or tan:ctruc:c quantities - . Dioctyl Phthalate* *In C/L or T/L of drums (LCL will be shipped only in an emergency) hereir.af :er referred to as "proprietary products"- Santicizer 160^ Montars* Axoclors*- " Santicizer 141 ^ The following- additional terms and conditions apply to subject distributor contract: 19. Monsanto will make third party shipments only if it agrees to do so prior to each sale contemplating such shipment. Such shipments if allowed by Monsanto will-' he made only by common carrier and only in taniccar, tankfrucu, carload or truckload quantities. Shipnyants will be made prepaid; Monsanto ' will pay the freight on freight allowed products and charge the freight to destination for FOB products. Monsanto will make stop off shipments . only if it agrees to do so prior to each sale contemplating such shipment. If Mons,,anto allows such shipment the distributor will pay stop off charges and any additional freight charge above that which would apply for ship ment to the appropriate distributor terminal. 20. In the event the distributor wishes to use his own trucks to transporc " plasticizers from Monsanto's plant to his terminals or warehouses, Mcnsau-c MAE 060390 TOWOLDMONOQ51608 Page 2 will allow, freight at full tanktruck or truckload rate, regardless c..; quantity taken, for products sold on. a freight allowed basis. A orem .v i of l/2q/lb. will'be charged'for shipments of 1000 to 1999 gallons". Sufficient notice must have been given the Monsanto plant to permit scheduling and prompt loading. 21. The following will apply with respect to inventory price protection. a. In the event of a price decrease, Monsanto will credit x the distributor for the difference between the old price and the new price for all purchases made in the 30 days previous tc the announcement of the price decrease, the date of shipment will govern. b. In the event of a price increase, Monsanto will notify the distributor in accordance with Paragraph 16 of this contract. 22. It is understood that where convenient to Monsanto, Monsanto will utilize'the distributor's bulk terminals and warehouses to service customers to whom it makes direct sales of the products inventoried by the distributor, with suitable through-put charges to be negotiated as1 regards each warehouse and/or bulk terminal. 23. Approximately twice a year the distributor and a Monsanto representative will review the distributor sales of "proprietary products" to insure that Monsanto is kept abreast of market conditions, of new uses, and of applications for its products in order to plan its research and application efforts properly and in order further to insure that the _ \ market is being serviced adequately. Oi :......... 24. This appointment shall bo for a term of one (1) year from date hereof until December 31, 1962, and shall continue from year to year thereafter unless terminated at the end of the first year or at the end of any succeeding year by _ either party serving on the other six (6) months' written notice of its desire to' terminate at least six (6) months prior to the end of any year. MAE 060391 TOWOLDMONOQ51609 TOWOLDMONOQ51610 MONSANTO CHEMICAL COMPANY AGENCY AGREEMENT * THIS AGREEMENT,made and entered into this First day of January, 1962, by and between MONSANTO CHEMICAL COMPANY, a Delaware Corporation (hereinafter referred to as "Principal") and AMERICAN MINERAL SPIRITS ' COMPANY (hereinafter referred to as "agent") . ' WITNESSETH: ' Principal hereby appoints agent its nonexclusive sales agent for the sale of its proprietary plasticizers, namely: Santicizer 160 Santicizer 141 . Montars Aroclors, Aroclors, Distilled Undistilled o 3 UJ < x in bulk (tankcar or tanktruck) to those of the accounts listed in Table I attached hereto, made a part hereof and marked Exhibit A as same may be amended from time to time in the future by mutual agreement of principal and agent, hereinafter referred tc as "listed accounts", which buys for the first time in either tankcar or tanktruck lots, hereinafter referred to as "bulk buyers", subsequent to the end of the year immediately following the year during which agent first made a sale to such account. iBJT TOWOLDMONOQ51611 This appointment shall be for a term of one (1) year from date hereof until December 31? 1962, and shall continue from year to year unieaa thereafter ajctig/ternlinated at the end of the first year or at the end of any succeeding year by either party serving on the other six (6) months' written notice of its desire to terminate at least six (6) months prior to the end of any year. Agent hereby accepts such appointment and agrees to use its best efforts to so sell said proprietary plasticizers. -All sales shall be subject to approval by principal and shall be at such prices, terms, and conditions as principal shall determine upon and advise agent from time to time. Agent shall do the invoicing and may invoice under his own "bill head" provided that agent shows on each invoice that in so billing he is acting as agent of principal. Agent will be responsible for all credit risks involved in connec tion .with any sales made by agent and will either turn over funds collected by it for Monsanto's account on the 15th day of the month following the month in which the sale was made for Monsanto or itself give to Monsanto such sums due which it may not have collected. Should agent enter into any written contracts as contrasted with spot sales they shall be written in principal's name and on principal's forms and the original copy of such contracts shall be retained by principal. . Principal will ship directly to the purchaser such material as agent sells under this agency agreement. MAfc 060393 TOWOLDMONOQ51612 -3- Principa^L shall pay agent a commission of five per cent (5%) of the gross selling price of all such proprietary plasticizers delivered upon orders or contracts obtained by agent during the period of this agency and accepted by principal. Monsanto reserves the right to solicit business in competition with agent. Agent shall not be paid any commission on sales to any ''listed account" who becomes a bulk buyer before the. end of the year immediately following the year during which agent first made a sale to -such account. All expenses incurred by agent in soliciting orders or obtaining sales such as traveling expenses, telephone, telegrams, office expense "and payroll shall' he borne by agent. Principal shall pay agent his commission promptly on receipt fro.a agent of the funds collected by it for Monsanto or receipt of the funds given Monsanto by agent in the event he has been unable to collect the sums due Monsanto within the stated period. . Neither.principal nor agent shall assign this agreement or assign any money to become due hereunder and any such assignment shall be void unless previously agreed to by the other party. Signed at St. Louis, Missouri the day and year first above written. ATTEST: ATTEST: .. / MA& 060394 0 CHEMICAL COMPANY ,c/ ______________________ _ / J^mes D. 'bright, Industry Sales Mgr. AMERICAN MINERAL SPIRITS COMPANY I INI rmf OH. COMMHI November 27, 1961 TOWOLDMONOQ51613 EXHIBIT A TABLE I ATLAKEA AREA Ageocy Agreement with Monsanto ciieuleal - 06^ TOWOLDMONOQ51614 I MAE 060396 TOWOLDMONOQ51615 MAfc 060397 TOWOLDMONOQ51616 EVZKCTT, XAB3* AStt 060399 MAE TOWOLDMONOQ51617 06039S TOWOLDMONOQ51618 I I I I. I f o*01'01 TOWOLDMONOQ51620 060^02 MAE TOWOLDMONOQ51621 060A03 TOWOLDMONOQ51622 MAE 060404 TOWOLDMONOQ51623 TOWOLDMONOQ51624 MAE 060406 * TOWOLDMONOQ51625 HA 6*0? TOWOLDMONOQ51626 MAE 060408 TOWOLDMONOQ51627 ma 0fa0^09 TOWOLDMONOQ51628 TOWOLDMONOQ51629 ymcDsarcg. selaxake arsi HAt 0bQitU TOWOLDMONOQ51630 MAE O60^2 TOWOLDMONOQ51631 TOWOLDMONOQ51632 MAE 0-604L4 TOWOLDMONOQ51633 TOWOLDMONOQ51634 y/:-?/_______ .&3fc . ( ,x,,,<^x ~y-- .'.; -'.v ;............... ... . .. ^Ss^+y^jj<i<j - ........ . .. --............. ............................ ........ . . ....._!. '<*> . ^y^-r- y&" s - . .......................... ................................... dyC^c=S^f^ .QbO^5 ma j|V'X'HJ B'l T'^ TOWOLDMONOQ51635 TOWOLDMONOQ51636 MAY Z 6 ]g/Q bcc: G. W. Buhrmann E. H. Fording - New York. R. V. Johnson F. M. Luckett -- Chicago W. B. Papageorge - ' P C Pq T1 If - w! e! 3chalk/j. E.- ' . Springgate W. F. Waychoff May 25, 1 9?6d- Wright . Mr, E, M, Toby, President American Mineral Spirits Company Division of Union Oil of California 1345 Avenue of the Americas New York, New York 10019 _ . ' ' Dear Mr, Toby: You have received previous communications from us regarding the allegations that certain polychlorinated biphenyls (PCDs) had been found in the environment and were contaminants. Since that time, other reports con cerning PCBs have been published. An examination of the PCD matter now indicates that their use in modifier and plasticiser applications may be a source of the alleged environmental contamination. Monsanto has sold PCB-containing materials under'^the trade name of Aroclor, These Aroclors Included: . Aroclor 1232 ' Aroclor 1242 . Aroclor 1248 Aroclor 1254 Aroclor3 1260 Aroclor' 1262 Aroclor 1268 . Aroclor 4465 Aroclor 1100 Series Montar1^ 1. Toluene or xylene blends of the above products also contained PCB. . MAE 060453 TOWOLDMONOQ51637 Mr. E, M. Toby -2- May 25, 1970 In review of the allegations which have been made con-. cerning PCBs, and being a concerned and responsible member of the world community, we have come to a de- .. cision to discontinue the sale of the above PCB-contain-' ing products for modifier and plasticizer applications effective August 30, 1970. ' - ~ We will notify our direct customers using the above products of this decision by June 1, 197* As a distributor of these products, it would seem appropriate that you follow the same course of action at as early a date as io feasible, A recov'd should be kept of all customers notified, along v/ith the dates on which the letters were transmitted. ' \ 'T'^7 . Recognizing that this action will result in considerable effort to define replacement products on your part and on the part of your customers, we have prepared data sheets outlining suggested alternatives for most appli- cations. Copies of these sheets for your use and for the use of your customers will be sent to you and to your regional offices prior to June 1. Additional copies . may be obtained from the appropriate Monsanto regional office. A list of these sales offices is enoloscd.-'with this letter. . - _ ~ "' V/e regret the work that thl3 action will create for you."' However, us a responsible supplier, we feel that we have a duty to keep our customers informed on matters concernlng the safe handling and use of our products. We appre ' ciate your support in this matter. As in tho past, we stand ready to assist you in any way possible, __ '"- *. Very truly yours, ' /dbw W. E. Schalk Director of Sales Plasticizers MAE QbQhSh TOWOLDMONOQ51638 TOWOLDMONOQ51639 P. V. Oann - B2SF Kay 9, 1973 PCB Warning Letter, August l4, 1970 By Schallc Memo to File This naming letter was sent to the following four distri butors : . : E. H. Toby, President American Mineral Spirits Co. Division of Union Oil of California 13^5 Avenue of the Americas New York, New York 10019 Mr. Carl Oiloth , ---- ... Central Solvents $ Chemical Co, 2540 West Fluorao.jr Street Chicago, Illinois 60612 . Mr. W. C. McCall, President draat Western Chemical Co. 3720 North West Ycon Ave. Portland, Oregon 97210 Mr. C. J. Turriff, President Tab Chemical Co. 4801 South Austin Chicago, Illinois 60638 This is the same list as used in May 25, 1970 letter. P. W. Oenn /me 060^55 TOWOLDMONOQ51640 TOWOLDMONOQ51641 Monsanto Monsanto Company 800 N. lindbaroh Boulovard St. Louis. Missouri G3I6G Phone: (314) 694-1000 August 14, 1970 ORGANIC CHEMICALS DIVISION Dear Sir: . During the week of August 10, 1970, Monsanto io sending - to all its direct customers for Aroclors in plasticizer/ modifier application l) a letter summarizing the latest '' information on PCBs, and 2) the most recent Aroclor technical bulletin. This bulletin replaces and supercedes 0/PL-306 - Aroclor Plasticizers. In as much as some important information concerning recent FDA actions and changes to Monsanto's returned goods policy are discussed, " we strongly urge you to forward copies of this bulletin - and a letter to your Aroclor customers. Copies of both have been enclosed for your use. . iChe'change in returned goods policy for our direct customers involves a two month extension of the deadlines for returning material to Monsanto. The .same two month extension will apply to our distributors. A copy of our revised returned goods policy is attached. We realize that this additional communication provides an added workload for your people. However, in view of the importance of this matter, we feel it is necessary for you as our distributor to assist in this matter. Very respectfully, /dbw Walter E. Schalk Director of Sales Plasticizers 06048 7 TOWOLDMONOQ51642 GENERAL POLICY CONCERNING DISTRIBUTORS' . RETURN OF AROCLORS* 1. The Tollowing policy will be in effect covering returned goods: a. .. . , If unopened containers purchased after September, 1969 are returned to the Sauget, Illinois plant or the Anniston, Alabama plant prior to 10/31/70., 10C$ of the net purchase price will be allowed for the returned goods. No additional handling charges will be assessed. Freight from distributor's warehouse will be paid by Monsanto at truckload rates. . - . b. If unopened containers purchased after September, 1969 are returned to the Sauget, Illinois plant or the Anniston, Alabama plant prior to 12/31/70, 90$ credit will. _ be allowed for the returned goods. No additional handling charges will be assessed. Freight will be paid by the distributor. . c. If unopened containers purchased after - - - September, 1969 are returned to the Sauget, Illinois plant or the Anniston, Alabama -plant prior to 2/28/71., 50$ credit will be allowed for the returned goods. No additional handling charges will be assessed. Freight will be paid by the distributor. - 2. Monsanto will accept orders through July 31 > 1970 and will make every effort to meet these commit ments and to complete shipment as of August 31, 1970. Monsanto reserves the right to limit shipmentsbased on its production capabilities. *Aroclors 1232, 1242, 1248, 1254, 1260, 1262, 1268, 4465, Montar 1, Toluene/Xylene blends. Revised 8/14/70 MAE 060488 TOWOLDMON0051643 TOWOLDMONOQ51644 t-Yl-ffl * I t-UT^cIttiSUV.-VlICBi OAT 2-24-70 8CNOCO-* ACCOUNT NO. 2-00-721 .:33 INDICATE DESIRED SERVICE -r> full rate oay letter night letter Notnoi of addrattoo and tondaf mutt inclvd* initial i, $/w co<np/f addcott (of tologfoms and cabltn. BOOK MESSAGE fee 2,4 R. N. Drell - Wilmington E. H. Fording - New York F. M. Luckett'- Chicago J. J. McNamara -`Everett E. C . Wilde - Akron Yesterday we mailed the following to Presidents of Amsco and Central Solvents re PCBs: ': 1. Monsanto letter to distributor. ' 2. Suggested cover letter for distributor use in notifying customers:. 3. Copy of letter to our direct customers. ": 4. Reprint of article from Chemical Week. I Due to similarity of letters 1 and 3, we addressed letter 3 to Presidents instead of 1. Bechtold contacting Amsco/ by phone_. Corrected 1 set being mailed today. You will receive corrected copy-of letters ` 1 ! 1 and 3 only. Apologies. : ! Cumin ing Paton - St. Louis . __ : g (N--IR nev. 7-OA jor BETTER deruice - Forward to transmitting operator IMMEDIATELY after preparation. jj into OATI TIMK CCNCEfTfi ACCOUNT NO. -* t INDICATE DESIRED SERVICE --> full rate day letter Q night letter.';- Nomoi of addroiiQ* and t*ndor ccwit include initials. Show complol address (or fe/epramf ond cablot. cc: D. H. Bechtold - Chicago R. V. Johnson W. B. Papageorge P, C. Park * W. F. Waychoff/W. E. Schalk J. D. Wright L IN--IR Nf.V. jor BETTER 4ervt.ce - Forward lo Ircincrniltmo oporalor IMMEDIATELY ollor proportion. ^ TOWOLDMONOQ51645 3/& - 4~ yik S / 2~<sr '/ 2^4-0 - 4C?'~^ /^_.'^2r: (^'o -- ~2-^o -- c'~^ A^'-^x c2<-<_s J "Z~h^ ~4/oy. v/: 3. - SZT-^ ^ 'Tfa-n/z^ TOWOLDMONOQ51646 TT1 M O N S A N T O TC RST T3 M O N S A N TO TC V A/NB339/MY22/1052/1054/1/CH386/QZQ WILLIS CLARK STLOUIS /OJ RE UR MAY 14 MEMO VE PLAN TO NOTIFY THE FOLLOWING KEY ACCTS THE WK OF-- 5-25. . AMSCO - ' o t THESE ARE ALL EITHER LARGE USERS OR SENSITIVES SITUATIONS E H FORDING NY -' ^ ;C i f- TOWOLDMONOQ51647 INDICATE DESIRED SERVICE **: j , DATE 5/26/70 --- - --------- * (' IME 10:00 A * - --- rGEUOER S + ACCOUNT NO: 0 FULL RATE 0 DAY LETTER 0 NIGHT L FTT E.R. Nomo< of addtoiico and lender mini include inilioh. Show complei* oddret^-/or fclc cobfg1 ,, p ^ J. D. Yt RIGHT CC:(J\-0Clark - bt. Louis T. LOUIS RE AFOCLOK. A Jit: C,' V.'. Cook - Everett ' J. IL Garmon - Everett . OUR KY ACCOUNT LIST FOR. THOSE FOB'S DEING_lUSeONf INUI.'l ' AMS CO MAE 060617- EACH SALESMAN WILL PERSONALLY CONTACT THEIR ACCOUNTSEDUF INC Y-T EK- Of 5/25 TO :> PLAIN SITUATION. J. J. MC N A M A R A _ t Wt? vtt '" IN- IR rev. T-a* BETTERlo,- Service - Forward lo Ironsmilling operalor IMMEDIATELY after preparalion. L I TOWOLDMONOQ51648 TOWOLDMONOQ51649 MonsantcPp CALI REPORT-ORGANIC DrVKlor? DICTATE IN SEQU-.-iCE: 1. HEADING INFORMATION 2. NAMES OF ADDRESSEES 3 NAMES OF CAR80NEES IMMEDIATE ACTION NEEDED REPORT ON CALL REPORT CAPTIONS: 1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRED cusrom N*e CITY aNO STATE Jmmmr OA/E REC6IVE0 Al Of CAU. 65/70 OAT? TYPED - , Penna, 6/8 6/9 CUSTOMER MAILING LIST CHANGES - SERVICE CENTER USE ONLY - name ano nice PUT ON MP MAG' ' category csoes - REGION SE SERVICE CENTER Wilmington SALESMAN E. G. McCAb-e/sm * - JO___Hi llh CG----Hr--Buhrmann----Sir Contacted: Halter St-rnwhlp - P.__&_----------Wayne Waters - Chief Chemist Called with: Jim Bollinger - Amaco Saloa Rep. Objective: Discuss PCB containing Aroclor3. Results: Reviewed our discontinuation of PCB containing Aroclora in complete detail and explained al1 related policy chances.__________________________________________________________________________ _________ buys 10CM lbs. per year or more of Aroclora.___They hny primarily a-1784, VJAn 1 Ofi? for light construction industry. I discussed our replacement recommendations in detail. However, they expressed concern reqadlnq increased costa, and aakad about the possibility nf nur supplying a Mand/JV" explained the decision to do this would not be made for several months. ~ Bollinger, Amaco, is arranging to give samples so they can begin reformulating. __ Ip., the meantime . Stroeblfl Indicated they will__stork up an much an thny can _^ .. Future Action :!. . ' . ..Coordinate., with Amaco to assure successful transition. - _______ TOWOLDMONOQ51650 TOWOLDMONOQ51651 Monsantrp "iT'v call'' repo rt - organic" DfyiEiof^ OICTATE INSEQJ-NCE: 1. HEADING INFORMATION 2. NAMES OF ADDRESSEES 3. NAMES OF CAR80NEES IMMEDIATE ACTION NEEDED . REPORT ON CALL customer namc sLbbbb&bB- 0*11 Of CAU 6/23/70 CI1Y AND SlAie OAif aeceiveo OAre iypco - ----- ,--N. Y -- 6/JA/70 7/6/70, CUSTOMER MAILING LIST CHANGES - SERVICE CENTER USE ONLY ' * . ~~ nawc ano nrie ~-- ~*i iPinufi ON i 7a1lt i-- MP r ~i MACj CAi.icoY cooes REPORT CAPTIONS: 1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRED ' region service cencec N.Y. Salesman * . .-i J.R. Beightol/la ' TO_________ Wil 1 ia^Claxk--frZ_ . CC__G .... ELermaa. F.M. Luckett -D ;H';--Bcrch E-oi-d- --JLaA ^.Smok.e____ H.H. Fording --J-rTO-Datbv------ CALLED; with Amaco Salesman________________________ ________ __________ L-. - -- ----- GQMTAGTEB-r- Bur-chaslng-agent-,- T-Packaging_MateriL.g___ Chemist, . . Product Manager for Packaging Materials, and - ~--Group~~3t aff-Menagcr-s-------- ---------------------- ------------- ----- :------- ------ BACKOftOUNffT ' ` "~ Fred'Schroadar. Regional Manager of Amaco apecifically requested _tha_ I~ call on thia account to tell them of the discontinuation of TOP'Aroclora. - used to ba - assistant boy^r--at_ -and thus ha and T have been good frienda for about a year. There vaa i* little doubt that i-call.------------------------------------------------------------- -------------~oBjECTTVEnmyrscuss-mjjmtpisc ontthttation~ gf^~fcb~akoclqks-------------------------- ] ' ' bacaroa waomewhat emotional when I attempted to present -tire facta behind our discontinuation of PCB's, Aa a matter of fact, I wai'- -..........-completely-cut- off . and _1 iatened--to. an-CLratlon_.on_hoM_aJtr.QDg_- pegahra-igg-x-peeanaad purchasing power ia and that they buy quite a bit of Mtariair-froarMonaanto-and-Amaco-and-that--we-shouid--be--prepared-to--suff-er the consequences unless we can store indefinitely for their ' requirements" of"10,`000 pounds per yeaf _6f"Afbclof_T2S4l came to bat with us and told ua not to worry about the situation aa It was a. purchasing problem and he could handle it ably. ~ ----- ._ l-^scommanded--a--2-^Lbland-.of-Aroclor--5460-tO-Aroclor 122JLas--a__raplanement for Aroclor 1254. Aroclor 1254 is used in combination with TCP and ' --Antimony-Oxide- In a plaa-tlaol-appilcatiotr-mada-for--thc-U-rS-:--governments-- indicated that there was a government priority number involved but' .......with such a small amount of "material-liT'quea tion there wouTcTTje no ___ problem in replacing it to the best of hia knowledge.__ pointed out__ that Navill Chemical had been in last week bad-mouthing Monsanto and their . . -dia continuation- of-PCB-la-.--Wa--ar<-caaually-raf enrAd .to aa "the guya that, cut you off". lubject-of-rep-lacing'TCP--with 3-14<3 anti --indicated-- that they wars already folng in thia direction. I asked him how they "arrived at_thia approach-and they Indicated that-SEauffer had bean IrTTrT ..............the., last ? going over this approach with them n my call yesterday S-3JI (*CY. I3/4| T -f- CENTRAL OFFICE COPY 060624 TOWOLDMONOQ51652 Mo'risa DICTATE IN SEQlLnCE: 1. HEADING INFORMATION 2. NAMES OF ADORESSEES 3. NAMES OF CARBONEE5 . IMMEDIATE action needed . report on call CUSIOM name CrIY ANO SUIE ,rrrCMrRiroK^^1 11I ,'M JVI^U." T. , N.Y. Oa(C 6CIVEo OAU Of CAU OAie TYPfO NAM6 ANO IlflE PUl ON 'TUT' MP MAG category cooes REPORT CAPTIONS: 1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRED region SERVICE CtNIfcR SAIFSMAN ------- .LR^ 'RflTghtnl. TO... . CC- pk 2 t had _a1 an_i ndT r.a tftd that thi* ** approach to go Idi to .. kastJoDdcx Look* like they and I are \ --------encoura^ng--cuatomers--to--go-in the-exaofc--direetion-- Chafe->te-w*at-------------- them to.______________ _______________________________________________________ ____ ATTENTION JAM SMOKE:_______________________________________________________ ~ jan, I gueia that you should nx call on directly. ' Tfiav.-. only ava-flahL&^vhlch-T--cajL_aea_AtL-thla_accoiintt la POP & - TCP. Amaco currently haa the TCP buaineaa in drum* and I am not ' -..... quite aure^yho-hae-tha POP-.----------------------------------------------------------------- ---------- S 331 (RV. 12/64) 1 *- CENTRAL OFFICE COPr j I I I I *6 0406,, TOWOLDMONOQ51653 TOWOLDMONOQ51654  /WHMH10^^ cWliFoi DICTATE IN SEOUL .~E: 1. heading information 2. NAMES OF ADDRESSEES 3. NAMES OF CARBONEES 4. IMMEDIATE ACTION NEEDED REPORT ON CALL CUSTOMER MAILING LIST CHANGES - SERVICE CENTER USE ONLY name ano mie PUI T' a*C Off ------- 1------- MAG -------c-a--icgorv cooes REPORT CAPTIONS: 1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRED 10-^r0lla -------- 7 / - *ecioN New York SERVICE CNie* - cc G. W. Spears SALESMAN J. E. Beightol/sb - St. Louis E. H. Fording - New York J- .R. _Darhy_ . - Queenv _ ----- --Joint-call with-Jixu caii-y, ntnaco ~ C0NTACTEU; : Cecil Murphy - Owner _______ g*rt--Murphy . r -Owner----------------------------------- .-- ' ;. _ - --------- GrBtTEGTTV&r-------------------------- :-----------;------------------------------------------------------------------------------------- --------- Discuss PGB discodtlmiatlotrr empM^zl!T^''t^t-'546075442, and-5666--------- -- willfi not be involved whatsoever __ purchases about 50,000 lbs. ' per year of Aroclor 5460 and 1221 and the two phosgarda were discussed ---------- ae-poa-slbla-replacements fnr Arnclor 1254 and 126Q.--Curratn PCBs are vsed in polyvinyl acetate emulsions, SBR and acrylic adhesives. Platfticlzen ----------arra~"CurrBntiy~purchagerd--i:hrough~&tony--Mueller--and Peer la as .--Somewhere--:-- between 100,000 and 200,000 lbs. per year of TCP are purchased by . . RESULTSj~ '~V . . ' - ' --------- ileauite-na^bCfl-^a-l-L xmra^enflardonal_M^a_jge_QtL^8_25 drum Aroclor 1254 and 25 drum 20QI Aroclor 1260 order. Accompanied with this, we got ---------- g-pLatrc "trial~vla ~one--drum'of Ar odor 1221,--fewe--drLsss--of--Santicizer--1A0-,-- and two drums of Santicizer 148. Both 140 and S-148 will receive undivided attention to replace TCP. Tim. BaJLghfol 1 - CENTRAL OFFICE COPY TOWOLDMONOQ51655 TOWOLDMONOQ51656 DICTATE IN SEQL^NCE: I HEADING INFORMATION 2. NAMES OF ADDRESSEES 3. NAMES OF CARBONEES 4. IMMEDIATE ACTION NEEDED 5. REPORT ON CALL cusroMf rlamC of cm city Audit OAlE RECEIVED ILUJO oaic rttio . MASSACHUSETTS 7/2/70 vnno CUSTOMER MAILING LIST CHANGES - SERVICE CENTER USE ONLY name and Tine PUT [Tire ON _ MP MAG CAtGOltY_C60ES REPORT CAPTIONS: 1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRE!! REGION NORTHEAST SERVICE CENIEft Eye rett SAIESMAN . J.H.' Gannon/1 ms TO MR. ST. W L CLARK .CC_. CONTACTED:' "Hr~~ '. Chemist - Mr. ; P .A. PURPOSE OF CALL: Joint call witfi 'AMSCO 'salesman to di'sciiss replacement of Aroclor 1 262. RESULTS : manufacture s II 1ubricati ng oiT' for aut omobl les. Th ey use the Aroclor 1262 as an addltiv e to such 1ubricatlng o 11 to Imp ro;V.e : _ he at stability and ch'em f c a 1 resi s fance." " They ha ve used this p rodiict -fo f^^Fye a r' wi th t reme ndous succe ss and feel therev is no re aJ_ecfi valent on the mark e't p'Tace_, i n cl udlng" Chlorinated Paraffins'. They' purchase approximately 60 ,000 lb s. of' Aroc lor 12 62 per year th ro ug h AMSCO. I re commen ded that_they test Aroc lor 5442 as a close s ubs tltute for th e"Aroclor 1 262/and a Isotest blend s of Aroc 1 or -5'460 d 1.221 . Samples are being rus hed and this .cus tomer will ma_k e a d e c 1 s Ion *n ether "to stock"up a <TdTti'on al "1 nven tory to'cove r their needs ' folTowing de te rmination date of Aug us t 30. 1 - CENTRAL OFFICE COPY 06Q6^< TOWOLDMONOQ51657 TOWOLDMONOQ51658 Monsanto _... " CAU. REPORT-ORGANIC DfVISW??? DICTATE IN SEl. 1 _NCE: 1. HEAOING INFORMATION 2. NAMES OF ADDRESSEES 3. NAMES OF CARBONEES IMMEDIATE ACTION NEEDED REPORT ON CALL REPORT CAPTIONS: 1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRE CUSTOMER NAME OAIl Of cau ___ ^ ciiy ano state /I ____________ _ 0AT6 RECEIVED 7/57 /in OAlE-nrFEO U . , Md. ...____ 7/2B__ _ _ ' i n 9 - CUSTOMER MAILING LIST CHANGES - SERVICE CENTER USE ONLY : : NAME ANO Tine PUT TAKE ON OFF MP MAG. CATEGORY COOES .- " REGION SE SERVICE CENlE Wilmincrton SAICSMAN - - E. G, McCabe /sm . jq W. S ark - St. Louis'__________________ QQ. ______Contacted :- Tech. Director _ - Chemist Called with: Nelson Bock - Amaco Salesman Objective: Discuss Aroclor discontinuation. Results: .. `"7I - __ . produces polysulfide sealants and caulks for light construction, using'-abcsrt 10,000 Lbs, aroclor 1254 per year at most. They have purchased a year's supply nf imn.r to be used during reformulation. . ' Future Action: (1) Send samples of S-261, G79, 148 and 213. (2) Follow up thru Nelson Bock. - r. . ' --. TOWOLDMONOQ51659 2- - Prieing information for the two fluid* 1* *b follow* r Quantity 1-4 5-39 T-55 l.05/gal. 975/g*i- T-66- 3.35/gal. 3.20/gal. Qrurn Size Gallons Pound* . 5^ 400 f net 55 46o # net FOB Point Alvin, Texas Anniston, Ala plea** call should you have additional question*. - Vary truly yours, J. J. Rodar Product Supervisor Heat Transfer Fluids os ka 060655 - TOWOLDMONOQ51660 TOWOLDMONOQ51661 bco C. faton/D. E. Roush ->B2SD lQOO D. R. Hansen l800 C. Boutin January 10, 1972 Astaoo Dlvialon Ifni on Oil Company r.0. Box 727 La Mirada, Calif. 90638 .: ' - Attantion Mr. W. Taipale ~ Dear Mr. Taipalat _j Aa diacuaaed by talaphona we wlah to confirm our auggeation of ; - either Therninol 55 or 66 11 1 replacement for your Tharminol .. FR-1 a/at aw. 1 V7y Va suggeat that the Therwinol FR-1 eyateei ba drained completely. . Xealdue fM-1 pan eauaa decowpoaltion of tha new fluid. A aolvent flush with acetone or xylol ia ona method to rewore real- dual MR-1 or you could uaa Theminol 55 for tha aae_purpoae. Tha uaa of Therainol 55 would permit operation at normal opera ting temperature for a couple weak* prior to refilling with a new charge of eithor T-55 or T-66, Both tha uaad FR-l and fluah fluid ahould ba drummed and tightly aaalad for return to Monaanto for diapoaal. We will pay tha return freight and diapoaal coat. Wa will give return lnatruationa on requeat, Wa auggaat that thia converaion from Tharminol FR-1 ba ravlawad with your inauranca company bacauaa neither T-55 nor T-66' la ' fire raaiatant. It nay be neceaaary to install aprinklera, heater snuffers, or other protective derioea.' It la alto important to protect both T-55 and T-66 from oxi dation cauaad by air Contact in tha vapor apace of tha expan- aion tank. Xither an Inert gas blanket or cold seal tank aa ahown in tha attached literature would ba helpful. Rffi'O JAN 10 |-CE3XKHgB'1iT|| MAE 06065A TOWOLDMONOQ51662 TOWOLDMONOQ51663 Moftsamo Monsanto COMPANY LABORATORY TEST REPORT PRODUCT: ArocLor 1248 Anniton, AUbtmt 30202 Phon.: (20SI 236-9331 To: American Mineral Spirits______________ At: Carteret. N. J._________________________ Customer1* Order No, Lot No:AI-15 ' - Container:Data Shipped: PROPERTY Specific Gravity (? 65C Acid No. Color Moisture, ppm Viscosity, SUS . Condition RESULT 1,414 0.001 20 29 77.6 Clear /dp 10/30/67 An I o TOWOLDMONOQ51664 TOWOLDMONOQ51665 ltfooJ<zu'<t,/7~ L^t-iu-^' C/9 tg~t . `A/'Cf, . j?U, yncc ^ yflflrjc/ae 0601Z- TOWOLDMONOQ51667 Deaember 15, 1967 Mr. M. J. Matheke American Mineral spirits Company 3100 South Heaoham Road Palatine, Illinois 6oo6j . Dear Mr. Matheket '' ' Mr. Brell of our New York office has asked roe to reply to your letter of December 6. " The product classification chart accompanying your letter was filled out with the pencil notations when I received it. I don't know who entered the check . marks and the notations. We in the Medical Department did provide answers as shown on the lower half of the sheet. The information on Aroclor 1242 is based on published and unpublished data and our own experience or history of use. The comment* on n-butyl acetate are based on literature references. If I can be of any further assistance, please let me - know. ' " ' Very truly yours Elmer P, Wheeler Manager, Environmental Health Medical Department EPWicjo cot R. N. Brell - New York JM KAE 060726 TOWOLDMONOQ51668 TOWOLDMONOQ51669 American Mineral Spirits Co, ' PRODUCT CLASSIFICATION CHART PRODUCT "M 1, Arochlor 1242 2-, n-Butyl Acetate IRAITAN T, SENSITIZER, CARCINOGEN SPI CLASSIFICATION 1` 1 23456 *. TOXIC POTENTIAL AND EFFECT ON EYES IF IF IF ABSORBED EFFECT ON SWALLOWED INHALED THROUGH EYES SKIN harm- harm- harm causes causes poison ful poison ful poison ful severe .eye i bums irrit. very flammable FLAMMA BIL1TY AND PRESSURE generating POTENTIAL . flammable 1 pressure gene rating / J \j 1/ , "*/ u: - - -- --- -- \J l/\ -- /V, * * y' -- iv; ' *. .* Aroclor 1242 x_ __.X.. X X X . No No No Aroclor 1242 is no t i ?ri` sat: ng to t` ie si in by usu? ;1 ae; 'ini' :ion c r SPI ratin 3 It IS' 1 go od sol ; ft r i orma . fat s and Oil. i of -1 he skin f nd re eated or pro.! ong" ed ski l ;c >nt; LCt v/ ill leac to d Nyinr ; and chai iping. Mor' Impo otant ex'ce so i ve ski 1 'C 5nt; .Ct can ?esu] t in ibsoij 'ptioi l ant i pOSi ible ubseq lent .---------------- -- ........... syst efni c.:.c ffe Z*C 3 - ... . . - -.........- - - ... The I-ibr, san to lab' il : it a es: "Cat tidni Con- ;ains chit >rinat ed hy rocar cons. Avoid -------------- oro~ ong ed ore yth -rig X> tuarxo ** ^_Q T -IVU_St .. naoLd. c.on ;aot .j. es_._pr prole nged _ " cont act Mi th ski 3 . If olein cont act o icur i , re; love by v/r shing v/i th soap ; nd v/atc r;. 1 J-Uj , l-Butyl A.cetate ^ ----------------- ---------------- ** ," ?c llo /in. S A\ re lai i 1UC \C . D pro. c on.ta it 1 call f?. `ush a_ m_ . v; ' Lth * , [ \ X X X * ..... ....... ` ; ' ' / atep ' . Ii ' ` f> cl'oi firing . .X ' ecome o soa: :ed v/ith S1 > 0 ?* --- Flash poin ; 4'72inu, "(C0C) r-------- MCA : LAI I- C uic e :-i abe **, Si1 sates : k 111 ' * ] i , ; J 1 i i "t ,au,tio al 1 veep iv/ay from heat. I rolOn gedL ireat ii-ng of 1 Vi ippr. enti.1 atiq>. i`.,. :A /old lprb.lc >nge`d "< kith- " !'."i \ i__ t ........ j" ' .nd op an fi."1 mp.. AVjtVoid Use. v.; ith 'a> ies^feite >r rbp eate^ ^contact 'with 1'. 1 TOWOLDMONOQ51670 TOWOLDMONOQ51671 FEB 1 Ib/j f bcc: ^Jan \ Gil -BuhTinann F./H. iuckett r IL. Bechtold Ji* Fording New York St, Louis Chicago . Chicago New York ' February 10, 1971 Mr, George Hietxel American Mineral Spirit* Corapany 14 Connerca Drive . Cranford-, Hew Jersey-- 07016 r Caorgai It was like the good old day* Baking a call with you at in , , New Jersey on Tuesday, February 2, 1971. As v* discussed, a coaraunication problea did exist between, and Moosanto/Amaco in two areas t _ (1) Our discontinuation of PC3 Aroclors. (2) Our new lew color Aroclor 5460, Hopefully, our joint call has resolved these problea areas .and we are back-.on first base with a good customer. Certainly with your salaam*s call frequency of twice per month what sweated to be major problems today can be turned into opportunities. : George, opened the door very wide for us in terms of Santicixer 140 replacing RGB with tha current 4<t per pound differential in price. By picking up Santicixer 140 business ___ at you will also plek op solvent and alcohol business ' for Anaco. I would like to review the Santicixer 140 potential ,, with you in about three month* te see if we could make e contribution at getting the business through Aasco. Beat regards. JRB/lbh Janes R. Beightol ' Sales Representative Organic Cheeiicela Division TOWOLDMONOQ51672