Document gDOXq0VD4NKLYr5oxeveMj9XG

m IN THE CIRCUIT COURT FOR BALTIMORE CITY * * ALL CT-1 CASES * ALL CT-2 CASES * ALL CT-4 CASES * ALL CT-5 CASES * * DEFENDANT CELOTEX CORPORATION'S ANSWERS TO PLAINTIFFS' MASTER INTERROGATORIES TO ALL DEFENDANTS TO: All Defendants, to be answered individually and separately by each Defendant. Plaintiffs, by their attorneys, John T. Enoch, John Amato, IV, and Goodman, Meagher & Enoch, request Defendants to answer the following Interrogatories. The Interrogatories are to i be read and answered in accordance with the following instructions and definitions. a. These interrogatories are continuing in character and, in accordance with the Maryland Rules, you are required to supplement your answers promptly after you obtain further material information. b. Where knowledge or information of a person is requested or possession or control by a person is inquired of, such request or inquiry includes knowledge, information, possession or control of or by the person's agents, representatives, and, unless privileged, the person's attorneys. c. When the identity of a natural person is requested, the request or inquiry includes the home address, business address, and his former and present position or job title and business affiliation, and, if the person is a corporation or association, the address of its principal place of business. d. When the identity of a document is requested, the request or inquiry includes the type or title of the document, its date, its author, and its present custodian. In lieu of identifying any document, a copy may be annexed to the answers to these interrogatories. The term document shall be read to include any paper, graphic material, film, tape, disc, recorded matter, or stored computer data. e. As used herein, the terms "you" and "your" refer to-the defendant corporation answering these interrogatories, its predecessors, parents, subsidiaries and affiliates, if any, its -2- present and former officers, executives, directors, agents and employees, and all other persons acting or purporting to act on behalf of Defendant. f. Present tense should be construed as also including the past tense where appropriate. g. The singular should be construed as also including the plural and the plural should be construed as also including the singular where appropriate. h. If you are unable to answer any of these interrogatories completely, answer to the extent possible, specifically, and state whatever information or knowledge you have concerning the unanswered. i. As used herein, "asbestos products" and "asbestos-containing products" are inclusive terms, used interchangeably, and include, but are not limited to: asbestos, raw asbestos, mined asbestos, milled asbestos, asbestos compounds, material and products containing asbestos and the asbestos particles, dust and fibers resulting therefrom. PRELIMINARY STATEMENT The Celotex Corporation (hereinafter Celotex) is a successor-in-business to various companies and corporations which were engaged in the manufacture and sale of asbestos-containing industrial insulation products. Celotex's involvement in the industrial asbestos insulation business began with its purchase of Panacon Corp. in 1972. Prior to that date, Celotex did not have any interest in the industrial asbestos insulation field. -3- Most of the events which may be relevant to the issues presented in this and related cases occurred prior to Celotex's purchase of Panacon Corporation. For this reason and the fact that many of the matters inquired about took place several decades ago, information furnished in this response may be incomplete. Nevertheless, Celotex has endeavored to fully investigate all relevant happenings and circumstances and the following responses are based upon its investigation. However, Celotex cannot exclude the possibility that its continued investigation may reveal more complete information. Furthermore, a considerable amount of the information supplied in these responses was obtained from employees of predecessor corporations. Accordingly, Celotex can only relay this information; it cannot attest to the accuracy or truthfulness of such responses. Information of this nature is being supplied because it may lead to the discovery of admissible evidence. To the extent that the information contained herein differs in any respect from any prior response to discovery, these answers shall be deemed to update and supersede such prior answer in any and all cases. Celotex does not concede that any of its responses to these Interrogatories are or will be admissible evidence at a trial of this action and Celotex does not waive any objection, on any ground, whether or not asserted herein, to the use of any such answer at trial. PRELIMINARY OBJECTION -4- # Defendant, The Celotex Corporation, objects generally to Plaintiff's definitions of "you", and "your", as it is vague and overbroad and Defendant is unable to formulate the correct response. In an attempt to be cooperative, this Defendant, The Celotex Corporation, has prepared the following responses which are limited to information pertaining to The Celotex Corporation and its predecessor-in-business. These are uniform preliminary matters that precede responses to any discovery on a national basis. PART I - GENERAL INTERROGATORIES Interrogatory No.l: State the name, address and official capacity of each person who has supplied information used in answering these interrogatories and indicate for which interrogatory each such person is responsible. Response No. 1: It is impossible for Defendant to respond to these questions with specificity, as various persons and various documents from many departments are/were consulted in answering these Interrogatories. The responses to these Interrogatories are prepared by the Legal Department of the parent corporation of The Celotex Corporation. They are signed by D.S. Gibson, Manager of Safety and Property Conservation, as authorized agent of the Corporation, and not on the basis of his personal knowledge of the facts stated herein. Interrogatory No. 2: (2) Identify each document that was examined, reviewed and/or used in answering each interrogatory, specify the interrogatory and identify the present custodian of each document. -5- Response No. 2: Defendant objects generally to Plaintiff's Interrogatories which are unnecessarily broad and which would be unduly burdensome, expensive and oppressive for Defendant to answer in the manner requested. The documents reviewed and consulted in connection with the preparation of answers to these Interrogatories are far too voluminous and cover too large a period of time to expeditiously identify with the specificity requested. Moreover, the type of document identification requested is unnecessary, unreasonable, and would be literally impossible to render for many of the answers supplied. Furthermore, the party serving these Interrogatories will be given reasonable opportunity to inspect the records and make copies, compilation, abstracts or summaries of these records pursuant to Maryland Rule 2-421, because the burden of ascertaining the documents which contain responsive information is substantially the same for the parties serving these Interrogatories as for this Defendant. Interrogatory No. 3: State whether you are a corporation. If so, state: your corporate name; state of incorporation; date of incorporation; address of principal place of business; address(es) of any other place of business; whether, if you are a "foreign corporation" as defined in Maryland General Corporation Law Sec. 1-101(1), you are now or have ever been registered or qualified to do business in the State of Maryland; and the corporate name, state of incorporation and date of incorporation of any subsidiary, predecessor or affiliate corporation. -6- > Response No. 3: Yes. a) The Celotex Corporation. b) Delaware. c) The Celotex Corporation was re-incorporated on August 6, 1964. d) 1500 N. Dale Mabry Highway, Tampa, Florida, 33607. e) Manufacturing facilities which produced asbestos-containing industrial insulation materials, which are relevant to this litigation, are or were located at the following locations: Lockland, Ohio, 1906 to 2/70 (high temperature industrial insulation); 2/70 to 1984 (other miscellaneous and encapsulated products; Plymouth Meeting, Pennsylvania, 1906 through 1962 (high temperature insulation products only); Linden, New Jersy, 1969 through 10/83 (asbestos paper products). f) Yes. Qualified to do business in the State of Maryland on November 3, 1977. Also, see Response No. 5. Interrogatory No. 4; you have existed. (4) Identify all prior names by which -7- Response No. 4: Refer to Corporate History attached, marked Exhibit "A". Also, refer to Response No. 5 below. Since Celotex has assumed all ordinary liabilities of its predecessors, further response is irrelevant. Celotex has specifically not assumed any responsibility for punitive liabilities of its predecessors-in- business. Interrogatory No. 5: If you have divisions which have ever mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce asbestos products, identify each such division and state the names, addresses and job titles of each person who supervised each division, specifying the applicable time periods. Response No. 5; Due to the record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond in full as requested. However, the Defendant is able to provide the following responsive information. Refer to Response #4 above. In addition, The Celotex Corporation manufactured, sold and distributed some asbestos-containing industrial insulation products until 1984. Its predecessors-in-business manufactured, sold, and distributed a variety of asbestos-containing products from 1906 until 1972. Defendant, The Celotex Corporation, has three divisions: the Building Product Division, Industrial Product Division; and Roofing Product Division. In addition, Carey Canada Inc. (formerly known as Carey-Canadian Mines, Ltd.) was incorporated in the dominion of Canada on February 14, 1955. This Corporation was an independent wholly-owned subsidiary of Celotex's predecessor in business and -8- > has been an independent wholly-owned subsidiary of The Celotex Corporation since 1972. Defendant declines to respond further on behalf of a separate, independent entity. Interrogatory No. 6: Have you controlled, purchased or in any way acquired any interest in any corporation or business entity which mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce asbestos products? Response No. 6: Refer to Response #4 and #5 above. In addition, neither Celotex nor its predecessors-in-business mined raw asbestos. However, Carey Canada, Inc. was engaged in the mining and milling of raw chrysotile asbestos fibers from 1958 until April, 1986. All sales of the raw asbestos fibers took place in Canada. Interrogatory No. 7; If your Answer to Interrogatory No. 6 is in the affirmative, identify and attach copies of all documents related thereto and state: (a) The name(s), including prior name(s), and the business address(es) of any and all such corporation(s) or business entity(ies); (b) The date(s) on which you first controlled, purchased or acquired said interest; (c) The manner in which you acquired said interest, i.e., cash purchase, merger, consolidation, exchange or sale of assets, etcetera; (d) The percentage of assets, ownership and/or control acquired by you; business entity(ies) the acquisition and, ceased; (e) Whether the corporation(s) or acquired by you continued to exist following if not, the date on which its existence (f) The nature of and/or amount of consideration paid by you for said interest; -9- (g) The terms and conditions of any contracts or agreements by and between you and such corporation(s) or business entity(ies), including, but not limited to, the terms and conditions relating to the transfer of liabilities for obligations of such corporation(s) or business entity(ies); (h) Whether you continued the manufacture, sale and/or distribution of such corporation's or business entity's asbestos products and, if so, whether you used the same product name(s) in so doing; and (i) Whether there was an identity of name, officers, directors, personnel, property, suppliers, distribution outlets and/or clients between you and such corporation(s) or business entity(ies); Response No. 7: Defendant objects generally to Plaintiffs' Interrogatory as vague, overbroad, irrelevant, immaterial and not reasonably calculated to lead to the discovery of admissible evidence. In an attempt to be responsive without waiving its objection, Defendant refers to Response #5 and #6 above. Interrogatory No. 8: If you have directly or indirectly mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce asbestos or asbestos-containing products, state as to each such product, indicating separately those products dealt with by you, your predecessor(s) in interest, your subsidiary(ies), and your affiliate(s), if any, the following: trade-mark; (a) Brand name, trade-name, and/or (b) The generic name or identity; (c) Description, including size, shape, color and composition, i.e. solid, powder or other form; (d) Chemical and physical composition, including, but not limited to, the percentage of asbestos by weight and volume; (e) Type of asbestos, i.e. chrysotile, amosite, crocidolite, actinolite, anthophyllite, or tremolite, indicating the percentage of each such asbestos fiber by weight and volume; -10- (f) Intended marketable use; and (g) Dates during which each asbestos product was mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied, distributed and/or otherwise placed in the stream of commerce. Response No. 8: Defendant objects to responding on behalf of subsidiaries or affiliates which are separate, independent entities. Further, as to this Defendant and its predecessors- in-business, Defendant objects to providing a description of the intended uses of each such product on the grounds that this request is overbroad and unduly burdensome. Likewise, the Defendant objects to providing a description of the physical characteristics of each such product on the grounds that this request is overly broad and unduly burdensome. If Plaintiff will specify those products to which he was exposed, Defendant will attempt to provide the requested information. Moreover, Defendant objects generally to Plaintiff's Interrogatories as vague, overbroad, irrelevant, immaterial and not reasonably calculated to lead to the discovery of admissible evidence, insofar as they relate or refer to unidentified asbestos products and materials. Asbestos fiber has over 3,000 uses and is found in a wide variety of products and forms, including floor tiles, wallboards, ceiling tiles, gloves, roofing felts, protective matting, gaskets, automotive brakes, machine and pipe insulation, etc. Defendant may not reasonably be required to delineate its product characteristics until Plaintiff has fully disclosed the basis upon which he claims Defendant's products caused him injury. -11- m In an attempt to be responsive without waiving its objections, Defendant states: (A-D, G) The Celotex Corporation manufactured, sold and distributed some asbestos-containing industrial insulation products until 1984. Its predecessors-in- business manufactured, sold, and distributed a variety of asbestos-containing products from 1906 until 1972. Attached is a list, marked Exhibit "B", of asbestos-containing insulation/industrial products manufactured and distributed by The Celotex Corporation and/or its predecessors-in-business, including the percentage of asbestos in each product. (E) The asbestos contained in the products previously identified in Exhibit B was chrysotile asbestos fiber with the following exceptions: 1) Tempcheck, Hightemp (#12, 15 & 19) and A-101 Cement contained amosite and chrysotile; 2) Careytemp 2000 and Thermalite contained amosite only; 3) Two types of millboard, made until 1973, utilized crocidolite in a mixture with chrysotile fibers; and 4) In addition, 85% Magnesia and Super Light 85% Magnesia for an undetermined period in or about 1946 may have contained some amosite due to a material shortage. (F) Refer to above objections. Interrogatory No. 9: State whether you presently mine, manufacture, produce, fabricate, import, convert, compound, process, sell, merchandise, supply, distribute and/or otherwise place in the stream of commerce any asbestos product(s) listed in your Answer to the preceding interrogatory. -12- Response No. 9: Neither Celotex nor its predecessors-in- business mined raw asbestos. The Celotex Corporation manufactured, sold and distributed some asbestos-containing industrial insulation products until 1984. Its predecessors-in- business manufactured, sold, and distributed a variety of asbestos-containing products from 1906 until 1972. Products were discontinued due to lack of demand and/or technological advancements and improvements. Interrogatory No. 10; Identify each individual who participated in the design and preparation of manufacturing specifications for each asbestos product identified in your Answer to Interrogatory No. 8. Response No. 10: Defendant objects generally to Plaintiff's Interrogatory as overbroad, unduly burdensome and speculative, insofar as they relate to the details of various actions which ) allegedly occurred between 10 and 80 years ago. Detailed information from this time frame is manifestly unreliable and in most cases amounts to speculation and conjecture, which has no probative value. Defendant objects to this Interrogatory as it is vague, overbroad and unduly burdensome. Without waiving its objection Defendant states that numerous employees were involved in product design and specifications. Due to the record retention policy and for the reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. However, the most knowledgeable person in.this area would be Arthur P. Mueller, retired Manager of Design and Engineering of Industrial Products, 320 S. Wayne Avenue, Lockland, OH 45215. -13- Interrogatory No. 11: State whether any written memoranda, specifications, blueprints or other written materials of any kind or character now exist relating to the design and preparation of the asbestos products identified in your Answer to Interrogatory No. 8. If so, identify: document; and (a) Each such written material or (b) The custodian, identity and location of each written material or document. Response No. 11: Defendant objects to this Interrogatory as irrelevant, overbroad and unduly burdensome. Without waiving this objection, in an attempt to be responsive. Defendant states that products specifications and batch formulae for asbestos- containing insulation products of predecessors-in-business are located at Defendant's manufacturing facility in Lockland, Ohio. Due to record retention policies. Defendant cannot verify that these records are complete. These documents will be made available for inspection upon proper notice to all parties. Interrogatory No. 12: Identify, by location and product, each plant of your in which the asbestos products identified in your Answer to Interrogatory No. 8 have been manufactured and/or assembled and the dates said plants have been in operation. Response No. 12: The Celotex Corporation and its predecessors-in-business have operated manufacturing facilities, which produced asbestos-containing industrial insulation materials, at the following locations: Lockland, Ohio - 1906 to 2/70 (high temperature industrial insulation); 2/70 to 1984 (other miscellaneous and encapsulated products); -14- m Plymouth Meeting, Pennsylvania - 1906 through 1962 (high temperature insulation products only); Linden, New Jersey - 1969 through 10/83 (asbestos paper products). Interrogatory No. 13: If you have discontinued mining, manufacturing, producing, fabricating, importing, converting, compounding, processing, selling, merchandising, supplying, distributing and/or otherwise placing in the stream of commerce any asbestos products listed in your Answer to Interrogatory No. 8, identify the products discontinued, give the date of discontinuance and specify the reason(s) for such discontinuance. Response No. 13: Neither Celotex nor its predecessors-in- business mined raw asbestos. As to asbestos-containing products, due to record retention policy. Defendant does not have complete records of its predecessors-in-business. Products were discontinued due to lack of demand and/or technological advancement and improvements. Refer to Product List attached, marked Exhibit "B" for dates of manufacture. Interrogatory No. 14: If you have done so, when did you first determine that any other material could be used in place of asbestos for high-temperature insulation or any other use to or for which asbestos has been applied. If you have, in fact, substituted other material(s) for asbestos in your product(s), then states material(s); substituted material(s) (a) The identity of such substituted (b) When the product(s) with such was first marketed; and (c) The tradename(s) and brand name(s) of the product(s) marketed with such substituted material(s). -15- Response No. 14: Predecessors-in-business began manufacturing Careytemp as an asbestos-free high-temperature insulation product in 1969. This product line was developed because reinforcement with glass fiber made the product less susceptible to breakage. Also, this change was made as a result of the awareness of the controversy that existed concerning the health hazards associated with the use of asbestos-containing products. Interrogatory No. 15: State whether you have ever made any changes to or alterations of your asbestos products from 1930 to the present. If so, state: (a) The identity, by brand name and tradename, of each such product; changed or altered; (b) The date(s) each such product was (c) The manner in which each such product was changed or altered, including, but not limited to, any changes in the asbestos content or chemical composition of each such product; alteration; and (d) The reason for each change or (e) The identity of the person(s) responsible for instituting each change or alteration. Response No. 15: In approximately I960, Celotex's predecessors-in-business developed premolded high-temperature insulation products. These products did not require cutting, sawing or grinding. Celotex continued to manufacture premolded insulation. All of the high-temperature insulation products manufactured by Celotex were asbestos-free, or manufactured in a non-dust producing form. Also, refer to Response #14 above. Interrogatory No. 16: Do you contend that any of the asbestos products listed in your Answer to Interrogatory No. 8 require change or modification before they may be used? If so, specify what change or modification is required for each such product. -16- Response No. 16: Defendant objects to this interrogatory on the ground that "change" and "modification" are terms which are susceptible to several meanings. Moreover, Defendant is unable to respond as such products were generally sold to distributors and sophisticated vendees, and Defendant has no way of knowing what, if any, changes or modifications were made. Interrogatory No. 17; Identify all patents issued, or any applications made therefor, for any asbestos product listed in your Answer to Interrogatory No. 8. Specify the number of each patent, the date(s) of application, issuance and renewal, if applicable, to whom each patent was issued and the product(s) for which each patent was issued. Response No. 17: ASBESTOS FIBER PIPE INSULATION PATENTS Patent Number Date 1931795 1974519 2042096 2262953 2225032 2284439 2288170 2348829 2348898 2884380 2971878 3367871 3408316 3639276 10/24/33 9/25/34 5/26/36 11/18/41 3/03/42 5/26/42 6/20/42 5/16/44 5/16/44 4/28/59 2/14/61 2/10/68 10/29/68 2/01/72 Interrogatory No. 18: Identify all trademarks registered for any products listed in your Answer to Interrogatory No. 8. Specify the number and date of registration, the term thereof, the date(s) of renewal, if applicable, by whom each trade-mark was registered and the product(s) for which each trade-mark was registered. -17- Response No. 18: #6. Refer to Responses to Request for Production Interrogatory No. 19: State whether you have distributed or sold any asbestos or asbestos-containing products which was/were mined, manufactured, produced, fabricated, imported, converted, compounded, processed, sold, merchandised, supplied and/or otherwise placed in the stream of commerce by persons and/or business entities other than you or your predecessor(s) in interest or subsidiary(ies), if any. If so, state: (a) The identity of each such person and/or business entity whose asbestos products you sold or distributed on a product-by-product basis; (b) The terms of all assignments, agreements, licenses and other arrangements which relate to same. Identify and attach copies of all such documents; (c) As to each product, the brand name, tradename and/or trademark adopted and used by the source from which you obtained said product for distribution or sale; (d) As to each product, the brand name, tradename and/or trademark adopted and used by you for purposes of distribution or sale of said product; each such product; (e) The generic name or identity of (f) The dates during which you distributed or sold each such asbestos product; (g) As to each such product, a description, including size, shape, color, composition, i.e., solid, powder or other form; (h) As to each such product, the type of asbestos and the percentage of asbestos, by weight and volume; (i) As to each such product, its intended marketable use; (j) The identity of each person and/or business entity in the State of Maryland to whom or to which you sold or distributed each such product; (k) The identity of each contractor, subcontractor, installer or other business in the State of Maryland which ultimately installed, applied or used each such product; and -18 (1) The custodian, identity and location of each document which refers to or contains information relevant to such sale or distribution. Response No. 19: Defendant objects to responding on behalf of subsidiaries which are separate, independent entities. As to this Defendant, neither Celotex nor its predecessors-in-business mined raw asbestos. Also, Defendant objects to providing a description of the intended uses of each such product on the grounds that this request is overbroad and unduly burdensome. If Plaintiff will specify those products to which he was exposed. Defendant will attempt to provide the requested information. Without waiving its objections, in an attempt to be responsive Defendant states: (A), (C), (E), (F) A small amount of calcium silicate pipe and block insulation is believed to have been purchased by the Philip Carey Manufacturing Company from Baldwin-Ehret-Hill (or its successor Keene Corp.) for a few years in the late 1950's and early 1960's, and relabeled "Carey Calcium Silicate". Also during this time frame, predecessors may have purchased a small amount of this product from PABCO (now Fibreboard), and may have purchased a minimal amount of asbestos products from Eagle-Picher. In 1968, after a semi-halt in 1967, Defendant's predecessor stopped manufacturing MW-50 cement; thereafter, Defendant sold this product after purchasing it from Keene Corp., Forty-Eight Insulations, Santaler Bros, and Eagle-Picher. The product purchased from Keene Corp. was known as "Super Power -19- House Cement", and was sold until about 1977. It is not known if Defendant or predecessors-in-business relabeled MW-50 prior to resale. (B) Celotex's predecessors-in-business issued a license to B & B Engineering Company of Houston, Texas, under its patent number 2884380 to manufacture the following product: a) Careytemp. b) The period of the license agreement was November 24, 1959, through April 22, 1976. c) The license was not exclusive. d) Although we do not have complete records of our predecessors-in-business, it is believed that there was no agreement concerning liability for third party claims. (D) Between 1956-1965 predecessors-in-business may have sold a small quantity of some asbestos-containing products to Eagle-Picher. It is believed that a minimal amount of All-Temp and Careytemp was sold in this time frame, and relabeled "Hy-Lo" by Eagle-Picher. (G) Defendant objects to providing a description of each such product on the grounds that this request is overbroad and unduly burdensome. If Plaintiff will specify those products to which he was exposed. Defendant will attempt to provide the requested information. (H) Refer to Response #8 above. -20- (I) Defendant objects to providing the intended marketable use of each such product on the grounds that this request is overbroad and unduly burdensome. If Plaintiff will specify those products to which he was exposed, Defendant will attempt to provide the requested information. (J) Refer to Response #19 (L) below. (L) Defendant is unable to respond as requested for the following reasons: Celotex and predecessors-in-business were engaged in highly diversified businesses in which asbestoscontaining insulation sales constituted a minimum of the business. Accordingly, available invoices reflecting general sales are predominantly comprised of non-asbestos products. Sales invoices may contain sales of both asbestos-containing products and non-asbestos-containing products. There are no separate invoices available which itemize only asbestoscontaining products. In addition, sales invoice records are not available prior to 1967. Celotex has a limited number of invoices of predecessors-in-business dating back to 1967. These invoice records are likewise not segregated into asbestos products and non-asbestos products. Also, many of these records are not indexed according to purchaser; rather, they are indexed according to the plant where the product was manufactured and the date of manufacture. The plants manufactured many other products which did not contain asbestos. These records are stored at Defendant's plant in Lockland, Ohio. -21- Sales records, dating from 9/1/72 are maintained by Celotex in Tampa, Florida. Sales invoices from September 1, 1974 can be retrieved by the Billing Department; however, a manual search must be made which involves the following procedures: 1. Manual search of all books of customer listings from 1974 through 1983 to obtain customer I.D. number. 2. Utilize customer I.D. number, a manual search of all monthly books of invoice number listings to locate the individual invoice number. There are approximately (20,000) sales invoices generated during an average month within a given year. (Note that sales invoices are note distinguished from invoices that may reflect credit memos, remittance differences, stock transfers or freight charges). 3. Utilizing individual invoice number, a manual search to determine a particular location of stored invoice by box number. (Maintained in a record retention log which lists individual invoice numbers and corresponding box numbers). 4. Pulling each individual invoice manually. (Invoices are stored in a separate warehouse). 5. Reviewing each invoice to determine whether the sale was of asbestos-containing products or general non asbestos sales. (Note the vast majority of sales did not involve asbestos-containing products). -22- A group of invoices, from April, 1974 through August, 1974, are in chronological order only. There is no index or method of sales information retrieval from these records other than by a manual review of each document. Defendant will make these records available for inspection at their respective locations upon proper notice to all necessary parties. Interrogatory No. 20: Identify the distributors of your asbestos products at any time during the period from 1930 to the present and attach copies of all documents relating to said distributors. For each distributor, indicate: (a) The terms of all assignments, agreements, licenses and other arrangements by and between you and said distributor; (b) Whether the distribution relationship was exclusive; (c) The year or years in which the distribution relationship was in effect; (d) The identity of your asbestos products which the distributor was authorized to and did distribute; and (e) The quantity of your asbestos products distributed by the distributor on a year-by-year and product-by-product basis. Response No. 20: Defendant objects to the Interrogatory as vague, overbroad and unduly burdensome. Without waiving this objection, in an attempt to be responsive, Defendant states due to the time period involved, Defendant is unable to respond with absolute accuracy. The best information presently available is indicated on the attached exhibit(s). Attached and marked Exhibit "C" is a list of Philip Carey distributors and sales offices from 1927 - 1972. Attached and marked Exhibit "Dw is a -23- list of other distributors and sales offices handling Philip Carey products form 1927 - 1952. For a list of Defendant's recent distributors/contractors, please refer to the attached, marked Exhibit "E". Defendant has no documents regarding such distributors. For information regarding volume and type of product, Defendant suggests you contact the appropriate distributors. Refer also to Response #19(L) above. Interrogatory No. 21: State whether you have ever sold, distributed or otherwise furnished any of your asbestos products to any other person and/or business entity for resale or redistribution at any time from 1930 to the present. If so, state: (a) The identity of each such person and/or business entity; (b) The brand name, tradename and/or trademark adopted and used by you for each such product; (c) The brand name, tradename and/or trademark adopted and used by each such person and/or business entity for each such product; each such product; (d) The generic name or identity of (e) The year(s) in which each such product was sold, distributed or otherwise furnished to each such person and/or business entity, and for each year, the quantity of each product sold, distributed or otherwise furnished; each such product; (f) The intended marketable use for (g) Whether each such product was intended to be used, resold, or distributed by such other person and/or business entity in the same or substantially the same condition as it was when shipped or delivered by you; and (h) The custodian, identity and location of all documents pertaining to agreements for the resale, distribution, or furnishing of your asbestos products to each other person and/or business entity. -24- \ Response No. 21: Defendant objects to the repetitive nature of this Interrogatory and refers to Response #19 (D) and #20 above. Interrogatory No. 22: State the following with respect to the packages and containers in which you sold, distributed or otherwise furnished each of the asbestos products described in your Answer to Interrogatory Nos. 8 and 19 on a year-by-year and product-by-product basis; (a) A description of the package or container in which each product was sold, distributed or otherwise furnished, including composition, size, shape and color; (b) A description of the markings or printed material that appeared on each package or container, indicating the size and color of the same; (c) A description of any logo or other design appearing on the package or container; (d) A verbatim description of any caution or warning notice appearing on the package or container, setting forth the year(s) in which each such notice appeared on each such product; and (e) A verbatim description of any instructions appearing on the package or container. Response No. 22; Defendant objects to providing the requested information for each such product on the ground that this request is overbroad and unduly burdensome. If Plaintiff will specify those products to which he was exposed, Defendant will attempt to provide the requested information. Without waiving its objection, Defendant states that due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. In an attempt to be responsive regarding Defendant's and/or predecessors-in-business asbestos-containing products generally, Defendant responds as follows; -25- (A) Defendant's industrial insulation products were shipped in bags, boxes, crates and gallon drums. (B-E) Application instructions were printed on predecessors' bags of MW-1 and MW-50 cement. Celotex is continuing its efforts to locate and review records of its predecessors-in-business, but cannot at this time state what other instructions, if any, were given by predecessors-inbusiness. Warning labels were placed on Celotex's products containing asbestos. Research indicates that warning labels first appeared on such products in 1972. Because of record retention policies, we do not have complete records of our predecessors-in-business . The warning label had the following information printed in bold, black letters on a white background: CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM This warning also appeared in the sales literature brochures of Celotex in 1974. The above warning was revised, and the following warnings were used by The Celotex Corporation from 1976 to early 1979: WARNING THIS PRODUCT IS (ASBESTOS FIBER) OR (CONTAINS ASBESTOS FIBER). THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA), AN AGENCY OF THE UNITED STATES GOVERNMENT BELIEVES THAT REPEATED INHALATION OF ASBESTOS FIBERS IS A HEALTH HAZARD AND MAY CAUSE VARIOUS DISEASES INCLUDING CANCER AND ASBESTOSIS. CAUTION -- These products contain asbestos fiber, and any working area where packages are opened, materials being cut or mixed, or handled in any way, should be inspected in accord with applicable regulations of the U.S. Occupational Safety and Health Agency (OSHA). These regulations may -26- 0) require special ventilation equipment, or the wearing of approved protective masks. OSHA has found asbestos fibers to be a health hazard, if repeatedly inhaled, which may cause diseases including cancer and asbestosis of the lungs. (OSHA standards are published in Volume 30, Code of Federal Regulations, Part 1910 and your supplier can obtain guidance from Celotex, if needed.) These warnings appeared on printed labels as well as in sales literature brochures. In July, 1979, Celotex revised the warning label to read as follows: CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM, INCLUDING CANCER AND ASBESTOSIS. IF DUST IS CREATED, PERSONS EXPOSED TO THIS MATERIAL SHOULD USE ADEQUATE PROTECTIVE DEVICES. SMOKING GREATLY INCREASES THE RISK OF SERIOUS BODILY HARM (G) Refer also to Request for Production Response ,6 Interrogatory No. 23: If your Answer to Interrogatory No. 22 reflects that any changes were made to the packages and containers in which you sold, distributed or otherwise furnished each of the asbestos products described in your Answer to Interrogatory Nos. 8 and 19, indicate as to each such package or container: (a) The nature of each such change, e.g., changes in composition, size, shape and color, and/or changes regarding the placement, modification or removal of any color, logo, design, name, word, number, instruction, warning or other marking on the container; make the change; (b) The date on which you decided to changed; (c) The date the container was in fact > -27- (d) The reason for the change; (e) The identity of each present or former employee, officer, representative or agent of yours at any time from 1930 to the present with knowledge or information regarding your decision to change any aspect of the package or container; and (f) The custodian, location and identity of each document in your custody, control or possession which contains information relevant to your decision to change any aspect of the package or container. Response No. 23: Due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. Our best information indicates that packages were purchased from Container Corporation of America, 9960 Alliance Road, Cincinnati, Ohio, and Inland Container Corporation, 912 Nelbar Street, Middletown, Ohio. These companies should be contacted for further information. Additionally, Defendant is unable to respond as such products were generally sold to distributors and sophisticated vendees, and Defendant has no way of knowing what, if any, changes were made. Interrogatory No. 24; For each asbestos product identified in your Answer to Interrogatory Nos. 8 and 19, as being manufactured, sold, distributed or otherwise furnished by you, state: (a) Whether you have actual packages or containers or photographs of packages or containers in which said products were sold, distributed or otherwise furnished; and (b) The identity of the custodian of said packages or containers or photographs thereof. > -28- Response No. 24: (A) As to actual containers, no. However, Defendant has in its possession reproductions of actual photographs of some of predecessors' products. Also, products literature brochures contain reproductions of actual photographs. Our best information indicates that packages were purchased from Container Corporation of America, 9960 Alliance Road, Cincinnati, Ohio, and Inland Container Corporation, 912 Nelbar Street, Middletown, Ohio. These companies should be contacted for further information. (B) The above-mentioned are in the custody of the Legal Department, The Celotex Corporation located at 1500 N. Dale Mabry Highway, Tampa, FL 33607. Interrogatory No. 25: State whether you prepared or published any catalogues, brochures or other documents describing products containing asbestos or asbestos components. If so, identify each such catalogue, brochure or other document and the custodian thereof. Response No. 25; Sales literature brochures have been prepared by the marketing department of Celotex and similar departments of its predecessors-in-business. These brochures were mailed to various distributors and contractors. Celotex will make available for inspection all product literature brochures in its possession for the years 1930 through the 1970's. Brochures do not exist for each year inclusively. Interrogatory No. 26: Identify each present or former employee, officer, agent or representative of yours who directed, handled, solicited, supervised, promoted or otherwise participated in the sale, supply, distribution, delivery, installation or removal in Maryland, at any time from 1930 to the present, of any asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. -29- Response No. 26: Defendant objects that this Interrogatory is vague, misleading, overbroad and ill-defined. Without waiving its objections, Defendant states that due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to.respond as requested. Interrogatory No. 27: For each person identified in your Answer to Interrogatory No. 26 who participated in the advertising in Maryland of any asbestos products identified in Interrogatory Nos. 8 and 19 at any time from 1930 to the present, state: (a) His or her duties, responsibilities and inclusive years of employment; (b) The identity of each product advertised, marketed or promoted; and (c) The method by which each product was advertised, marketed or promoted, and if by print, the name of the publication, the inclusive dates during which the advertisement or promotion appeared therein and the publisher. Response No. 27: Refer to Response #15 above. In an attempt to be responsive as to Defendant's and/or predecessors-in- business asbestos-containing products in general, Defendant states that from 1974 - 1982, Celotex retained the Mike Sloan Advertising Agency, 101 S.W. 15th Road, Miami, Florida. Such matters are currently handled internally by the Advertising Department of The Celotex Corporation. All of Celotex's advertising contains warnings that comply with OSHA and other governmental regulations. Magazines and trade publications which advertised Philip Carey products are as follows: 1. Sweet's Catalogues 2. Asbestos -30- 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. Power Plant Engineering Pulp & Paper Petroleum Age Chemical Engineering News Iron Age Chemical Processing Industrial Research & Development Paper Age Chemical Industry & Product News Air Conditioning, Heating & Refrigeration News Industrial Equipment News Power Engineering Product Design and Development Pacific Marine Review Celotex has no advertising copy and no additional information regarding advertising of predecessor's asbestos products. Refer also to Response #25 above. Interrogatory No. 28: Describe your corporate structure and policy concerning the subject of employee safety in the design, development, manufacture, testing and use of asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 from 1930 to the present. In your Answer to this Interrogatory, identify each present or former corporate department, division, subdivision or other group responsible for the above-described activities and, with respect to each, identify the name, title, duties, responsibilities, and current or last known business and residential address of the highest supervisory employee with knowledge of any of those activities during any time from 1930 to the present. Response No. 28; Defendant objects to this question on the grounds that it is irrelevant to the instant action and not calculated to lead to the discovery of admissible evidence as Plaintiffs were not employees of this Defendant. Defendant further objects to this Interrogatory as overbroad and unduly burdensome in that the Plaintiff seeks information for a 56 year time period. Without waiving its objections. Defendant states relevant asbestos products were generally sold to insulation -31- application contractors, who carried the main burden of responsibility for safety on the job. Defendant had no jurisdiction over such workers nor any right to inspect such job sites. However, Defendant's predecessors-in-business have had Managers of Safety & Property Conservation responsible for in- plant safety programs. The present Manager of Safety & Property Conservation is D.S. Gibson. Various safety booklets and bulletins have periodically been distributed to employees. Plant safety bulletins such as those marked Exhibit "J" date back at least to 1944. Further, various safety booklets and bulletins have periodically been distributed to employees. In addition, Celotex and its predecessors-in-business have instituted in-plant safety programs. Interrogatory No. 29; Describe your corporate structure concerning the subject of research and development of asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 from 1930 to the present. In your Answer to this Interrogatory, identify each present or former corporate department, division, subdivision or other group responsible for any of these activities and, with respect to each, identify the name, title, duties, responsibilities, and current or last known business and residential address of the highest supervisory employee during any time from 1930 to the present. Response No. 29: Defendant objects to the form of this Interrogatory, in that it is vague, misleading, overbroad and ill-defined. Without waiving its objection, Defendant states that in 1931, Philip Carey Manufacturing Company organized a Research and Development Department. This Department was operated until June 30, 1972, when Panacon Corporation merged into The Celotex Corporation. There are no former department heads presently affiliated with, or employed, by, The Celotex -32- Corporation. From 1972 to 1982, Celotex owned a subsidiary whose primary function was the research and development of new products and processes. Interrogatory No. 30: Describe your corporate structure concerning medical directors, industrial hygienists or consultants in these fields from 1930 to the present. In your Answer to this Interrogatory, identify the name, title, duties, responsibilities, period of employment, to whom the individual reported, and the current or last known business and residential address of each medical director, industrial hygienist or consultant of yours, or of your predecessor(s) in interest or subsidiary(ies), if any. Response No. 30: Defendant objects to responding on behalf of subsidiaries which are separate, independant entities. As to this Defendant and its predecessors-in-business, Defendant objects that this Interrogatory is vague, misleading, overly broad, and ill-defined. Without waiving its objection, Defendant states neither Celotex nor its predecessors-in-business had a person employed as a medical officer or director. For a period of one year ending in 1963, a predecessor-in-business retained Dr. Thomas Mancuso as a Consulting Medical Director, to review the Occupational Health Program at the Lockland, Ohio, plant. Dr. Mancuso is employed at the University of Pittsburgh, Pittsburgh, Pennsylvania. Due to record retention policies, Defendant does not have complete records of its predecessors-in-business? however. Defendant is aware that the following physicians were at some time employed or retained by predecessors-in-business. Those doctors were: Dr. Virgil A. Plessinger 2700 Central Trust Tower Cincinnati, OH -33- > Dr. C. G. Ruehlman 83 South Eagle Road Hebrewtown, PA Dr. Robert G. Loudon address unknown Lee B. Fosdick, address unknown, was hired by Celotex's predecessors-in-business in December 1962, to perform an industrial hygiene survey of dust levels at the Lockland, Ohio plant. The following industrial hygienists were employed to take dust level counts: ' B.I. Stallings, address unknown; 1967, 1972. Edward B. Eagle, address unknown; May, 1968. Professor D. W. Yeager, Institute of Environmental Health, Kettering Laboratories, University of Cincinnati, Cincinnati, Ohio; August, 1974 and April, 1978. Fred T. Lyon, address unknown; February, 1976 and April, 1976. Michael B. Amster, address unknown; April 1, 1978 and July, 1977. Robert L. Sweeney, address unknown; October, 1974 and June, 1973. E.B. Engel, address unknown; March, 1971. D.B. Troup, address unknown; July 1973. S.R. Wheeler, address unknown; Linden, New Jersey plant, date unknown. Interrogatory No. 31: Identify any medical examination program offered or sponsored by you or your insurance carrier, from 1930 to the present, for employees handling or otherwise exposed to asbestos and/or asbestos products. With respect to each such program, indicating applicable time periods, state; (a) The manner of communicating with employees about such program; -34- (b) Whether examination was optional or mandatory and, if the latter, how frequently such examination was required; (c) What percentage of employees permitted to undergo such examination actually participated; (d) What percentage of employees who underwent such medical examination were found to have pneumoconiosis, asbestosis, mesothelioma, lung cancer or other cancers; and (e) With respect to the employees referred to in your Answer to Part (d) of this Interrogatory, what percentage of these employees were paid disability, and/or worker's compensation benefits and for what percentage of employees were medical expenses paid for purposes of treatment of such condition. Response No. 31: Defendant objects to this question on the grounds that it is irrelevant to the instant action and not calculated to lead to the discovery of admissible evidence as Plaintiffs were not employees of this Defendant. In an attempt to be responsive without waiving its objection, Defendant states Celotex is informed and believes that Philip Carey Manufacturing Company first offered chest x-rays to its employees in some plants as early as 1950. Also, its employees were informed when the x-ray unit, sponsored by the Anti-Tuberculosis League, was in the area and were encouraged to undergo x-ray examinations since approximately 1965. Since 1972, The Celotex Corporation has provided comprehensive medical examinations, on an annual basis for its employees working with asbestos, including chest x-rays and pulmonary function tests. Professional Health Services, Irtc., performed these medical examinations form 1972-1977. Hearex Corporation performed the examinations from 1978 until early 1982, and since that time Medi-Systems has been retained -35- for these functions. Additionally, Defendant does not maintain such data in the ordinary course of business and is unable to respond as requested. Interrogatory No. 32: State whether you or anyone on your behalf ever conducted, engaged in or participated in any tests, studies and/or research concerning the human health consequences of persons coming in contact with and/or inhaling asbestos fibers or asbestos dust during the manufacture and/or use of asbestos products. If so, identify: were done; (a) What tests, studies and/or research research were done; (b) When said tests, studies and/or (c) The individuals who ordered and supervised the tests, studies and/or research; (d) The individuals or groups engaged in or participating in the tests, studies and/or research; (e) The substance of any recommendations and/or suggestions given as a result of the tests, studies or research. State when, by whom and to whom said recommendations were made, including the addresses of these individuals; (f) All written documents including, but not limited to, reports, memoranda, specifications and correspondence which refer, relate or pertain to said tests, studies and/or research; and (g) The present custodian of the written documents identified in your Answer to Part (f) of this Interrogatory. Response No, 32: Celotex's predecessor-in-business was a member of the Asbestos Information Association of North America. The Association may have conducted such research and should be contacted for further information regarding their research. -36 As to research relating specifically to predecessor's product, a study was conducted March 10, 1961, at the Indianapolis, Indiana, by John Kehoe, Chemical Engineer, Indiana State Board of Health, 1330 W. Michigan Street, Indianapolis, Indiana. Attached and marked Exhibit "F" is a letter from Albert Edwards, Industrial Hygiene Engineer, to F.P. Ray, Indianapolis Contract Manager, of the Philip Carey Manufacturing Company. This letter is dated April 13, 1961, and reached the following conclusion: "Under present operating conditions, it is concluded that no serious dust exposures are associated with the installation of Careytemp insulation." In addition, a test was conducted at the Union Carbide Plant in Institute, West Virginia in 1967. Celotex has a document, attached and marked Exhibit "G", dated January 2, 1968, addressed to Art Mueller and authorized by J. Pierce, Assistant Professor of Environmental Health at the Kettering Laboratory in Cincinnati, Ohio. The document reports and analyzes samples of air taken during fabrication of Careytemp insulation at the Union Carbide plant in Charleston, West Virginia. Dust counts taken at the sawing and fabrication operation indicated dust levels far below the threshold limit value for nuisance dust as established by the ACGIH. Because of the low asbestos content of Careytemp, x-ray defraction tests failed to pick up any airborne asbestos fibers. However, the study recognized that trace amounts (less than 5%) of crystalline silica and asbestos fiber are not often detectable using x-ray defraction techniques. Nevertheless, it -37- m was felt that the amount of airborne asbestos fiber, if any, was certainly below the accepted threshold limit value for asbestos fiber. Mr. J. Pierce reported his objective findings, but did not state any conclusions after conducting the dust count. Interrogatory No. 33: State whether any of the medical directors, industrial hygienists or consultants in these fields identified in your Answer to Interrogatory No. 30 ever made any recommendations and/or suggestions to you pertaining to the risks or hazards to persons involved in the manufacture or use of asbestos products. If so, identify: (a) The date when said recommendations and/or suggestions were made; (b) The individual to whom said recommendations and/or suggestions were made; (c) The individual who made said recommendations and/or suggestions; (d) The substance of the recommendations and/or suggestions; and (e) What actions, if any, were taken by you as a result of said recommendations and/or suggestions. Response No. 33: Defendant object to the form of this Interrogatory, in that the terms "risks or hazards to persons involved in the manufacture or use of asbestos products" are vague, misleading, overbroad and ill-defined. Without waiving its objection, Defendant states that due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. In an attempt to be responsive, Defendant refers to the attached reports from Dr. Mancuso date May 23, 1963 and -38- August 15, 1963, marked Exhibit WH". Refer also to the Preliminary Industrial Hygiene Survey attached, marked Exhibit "I". Interrogatory No. 34: State whether you have ever conducted or directed any studies to determine the amount of asbestos dust in your asbestos product manufacturing facilities. If so, identify: (a) The date of each such study; each such study; (b) The individual or group conducting such study; (c) The result or conclusion of each (d) All documents which refer, relate or pertain to each such study ; and (e) The present custodian of all documents identified in your Answer to Part (d) of this Interrogatory. Response No. 34: Defendant objects to this question on the grounds that it is irrelevant to the instant action and not calculated to lead to the discovery of admissible evidence as Plaintiff was not employed in Defendant's manufacturing facilities. Without waiving its objections, in an attempt to be responsive Defendant refers to Response #33 above. Interrogatory No. 35: State whether any written memoranda, specification, blueprints or other written materials of any kind or character exist relating to any testing of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. If so, identify: document; and (a) Each such written material or (b) The custodian, identity and location of each such written material or document. -39- Response No. 35: Defendant objects to the form of this Interrogatory, in that it is vague, misleading, overbroad and ill-defined. In an attempt to be responsive without waiving its objection, Defendant refers to Response #11 and #32 above. Interrogatory No. 36: State whether, after you released to the public any of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19, you ever conducted or directed any tests thereon to determine potential health hazards involved in the use of the materials. Response No. 36: Defendant objects to the repetitive nature of this Interrogatory and refers to Response #32 above. Interrogatory No. 37; State whether, prior to 1970, you ever had any labor inspectors or persons from your company go to job sites or other areas where your asbestos products were being used or installed to make a dust level count. If so, indicate when such a practice or procedure began, the purpose of the practice or procedure and what action, if any, was taken by you in response to the findings made as a result of said practice or procedure. Response No. 37: Defendant has no information indicating that such tests were conducted to determine possible health hazards associated with exposure to asbestos-containing products. Prior to the mid 1960's, it was generally believed that no potential health hazards existed for those working with or around finished asbestos-containing products. It was not until the mid 1970's that the medical community first concluded that exposure to finished (manufactured) asbestos-containing products might present a potential health hazard. Relevant asbestos products were generally sold to insulation application contractors, who carried the main burden of responsibility for safety on the job. Defendant had no jurisdiction over such workers nor any right to inspect such job sites. -40 Interrogatory No. 38: State whether you ever conducted or directed any studies designed to learn how to minimize or eliminate the inhalation and ingestion of asbestos dust and fibers by those who use your asbestos products or are exposed to asbestos dust or fibers therefrom. Response No. 38: Refer to Response No. 32 above. Defendant's predecessors-in-business developed and advocated the use of certain products which greatly minimized the release of airborne asbestos fiber. In the late 1950's, predecessors-in-business developed premolded products to fit around elbows and T's, which did not require cutting or shaping. Since the mid-1950's, predecessors recommended the use of an asbestos-free cement in conjunction with their high-temperature industrial insulation products. During the mid to late 1960's, predecessor's principal high-temperature insulation product contained a significantly lower percentage of asbestos fiber than did comparable competitor's products. Then in 1969 predecessors removed all asbestos from its principal high-temperature industrial insulation product. Defendant is informed and believes that respirators approved by the U.S. Bureau of Mines will prevent the inhalation of dangerous quantities of asbestos dust and fibers. Defendant has relied upon the U.S. Bureau of Mines for the testing and reliability of respirators. Interrogatory No. 39: Identify all trade organizations, associations or other entities to which you belong or belonged. Said organizations, etc., include, at a minimum, the following: Asbestos Textile Institute (ATI); Industrial Hygiene Foundation and/or Industrial Health Foundation (IHF); -41- Mineral Wool Institute; Industrial Mineral Insulation Manufacturers Institute; Magnesia Silica Insulation Manufacturers Association; National Insulation Manufacturers Association (NIMA); Thermal Insulation Manufacturers Association (TIMA); Asbestos Information Association (AIA); Quebec Asbestos Mining Association (QAMA); National Safety Council; Asbestos Cement Producers Association; Refractories Institute. Response No. 39: The Celotex Corporation and its predecessors-in-business were members of the following organizations; Asbestos Information Association of North America, 1970-1972. Thermal Insulation Manufacturers Association, since 1978. Asbestos Cement Products Association, up until 1965. National Mineral Wool Association, up until 1965. Magnesia Insulation Manufacturers Association, prior to mid1950's. National Insulation Contractors Association (and predecessors), since early 1960's through 1982. Sprayed Mineral Fiber Manufacturers Association, 1969-1971/72. Gypsum Association, since 1939. National Safety Council, since 1944. To the best of Defendant's knowledge, neither Defendant nor its predecessors-in-business belonged to any of the other organizational associations listed in this Interrogatory. -42- Interrogatory No. 40: For each trade organization, association or other entity identified in your Answer to Interrogatory No. 39, state: (a) Dates of membership; associate; (b) Type of membership, i.e., regular or (c) The dates and type of meetings you attended and the identity of the individuals who attended such meetings on your behalf; (d) The identity, title, duties and responsibilities of any individual who held an elected, appointed or self-designated position within said organization, etc.; (e) The names of any publications or written materials distributed by or on behalf of said organization, etc.; and (f) The identity of the present custodian of all written materials, notes, summaries, minutes or transcripts relating to the transactions and proceedings of said organization, etc.; Response No. 40; Refer to Response #39 above. Various persons attended regular meetings of these organizations. Exact dates and names of attendees are unknown. Also, due to record retention policies and for reasons given in the Preliminary Statement, the subjects discussed at particular meetings are unknown to this Defendant. Interrogatory No. 41: For each trade organization, association or other entity identified in your Answer to Interrogatory No. 39, identify all studies, tests, research, recommendations, suggestions, seminars, symposia and/or speeches conducted or made which concerned, discussed, addressed or dealt with the actual, alleged or possible health hazards associated with exposure to asbestos. Responses No. 41: Due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. -43- n Defendant may have received routine reports from such organizations sent in the regular course of business, but Defendant has no specific information regarding such reports. Celotex's predecessor-in-business was a member of the Asbestos Information Association of North America (AIA/NA) which organization has conducted research on the effects of asbestos. The Associations should be contacted directly for this information. Interrogatory No. 42: With respect to each study, test, research project recommendation, suggestion, seminar, symposium or speech identified in your Answer to Interrogatory No. 41, identify: therein; (a) The individuals or groups involved (b) The date(s) thereof; (c) The complete results thereof; (d) The recommendations, if any, which were made as a result thereof; and (e) The custodian, identity and location of each document which represents, refers to or contains information relating thereto. Response No. 42: Refer to Response #41 above. Interrogatory No. 43: Describe each action taken by you as a result of each study, test, research project, recommendation, suggestion, seminar, symposium and/or speech identified in your Answer to Interrogatory No. 41. In your Answer to this Interrogatory, state the date of each action and the identity of the individual(s) who initiated said action. -44- Response No. 431 Refer to Response #41 above. Interrogatory No. 44: State whether you directed, sponsored, financed, participated in or received the results of any studies and/or tests performed by the Sarance Laboratory of the Trudeau Foundation concerning the human health consequences of exposure to asbestos. Response No. 44: To the best of Celotex's knowledge, at this time Celotex has never directed to be performed, sponsored, financed or received the results of any studies or tests performed by the Sarance Lake Laboratory of the Trudeau Foundation, relating to asbestos exposure and its effect on human life. Interrogatory No. 45: If your Answer to Interrogatory No. 44 is in the affirmative, identify: (a) All documents in your possession or control which summarize or explain the results of said studies or tests; (b) All communications, oral or written, between you and Sarance Laboratory personnel, including but not limited to Gerrit W. Schepers, M.D.; (c) All documents relating to Sarance Laboratory studies or tests which were received or submitted by you, either directly or indirectly through predecessor(s) in interest, subsidiary(ies) or affiliate(s), if any, through other companies, or through any trade associations, organizations or entities; (d) All recommendations or findings of such studies in relation to: (i) adequacy or inadequacy of the threshold limit values; (ii) the substitution of materials for asbestos; and (e) The custodian and location of all documents and/or communications identified in your Answer to this Interrogatory. -45- Response No. 45: Refer to Response #44 above. Interrogatory No. 46; State the amount of money spent or contributed by you annually from 1930 to the present for research of the relationship between exposure to asbestos dusts, fibers and/or products and any pulmonary pathology and identify each person or organization to whom the expenditure or contribution was made. Response No. 46; Defendant objects to this question on the grounds that it is irrelevant to the instant action and not calculated to lead to the discovery of admissible evidence. Without waiving its objection, Defendant states Celotex's predecessor-in-business was a member of the AIA/NA and made annual contributions. It is Celotex's understanding that this organization has conducted research on the effects of asbestos. As to what expenditures the association has made or what reports it has developed, inquires should be directed to the association. Further, due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. The Association should be contacted directly for this information. In addition, Defendant does not maintain such data in the ordinary course of business and is unable to respond as requested. Interrogatory No. 47: State whether you have ever maintained a library (or libraries) which contains books, articles, periodicals, journals and/or reference materials that relate to the subjects of asbestos, industrial hygiene, medicine, safety, occupational disease and/or engineering. If so, state: established; (a) The date each such library was -46- (b) The location of each such library; (c) The identity of each librarian or other person in charge of the operation and materials of each such library? established; (d) For whose use each such library was (e) The title, publisher and dates of subscription to or acquisition of each such periodical or journal for each such library; and (f) The title, author, publisher, date and dates of acquisition of each such article and book for each such library. Response No. 47; Neither Defendant nor its predecessors-in- business have maintained such libraries. Interrogatory No. 48; State whether any of the co-defendants in asbestos litigation have ever furnished you with any information as to the state of the medical knowledge at any time regarding the relationship between exposure to asbestos dusts, fibers and/or products and the contracting of diseases, including asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers. Response No. 48; Defendant objects generally to Plaintiff's Interrogatories as they seek information about the activities of "other defendants" about which Defendant has either no direct knowledge or merely unconfirmed hearsay knowledge. Information of this nature should be sought form the proper source. Without waiving its objection, this Defendant states that it never received such information other than in conjunction with pending litigation. Interrogatory No. 49; If your Answer to Interrogatory No. 48 is in the affirmative, identify: -47- (a) How the information was furnished; (b) Who furnished said information; you; and (c) When said information was given to (d) The substance of said information. Response No. 49; Refer to Response #48 above. Interrogatory No. 50; State whether, at any time since 1930, you have interchanged, exchanged or communicated, the results of research, tests, studies or experiments regarding the relationship between exposure to asbestos dusts, fibers and/or products and the contracting of diseases, including asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers, with any other person, corporation or other business entity, including co-defendants in this action. Response No. 50; Defendant objects on the grounds that the Interrogatory is overbroad, unduly burdensome, assumes facts and seeks privileged information. Without waiving its objection, Defendant states to the best of its knowledge, neither this Defendant nor its predecessors interchanged research results other than in conjunction with pending litigation. Interrogatory No. 51; If your Answer to Interrogatory No. 50 is in the affirmative, state: (a) When said interchanges, exchanges or communications occurred; (b) The identity of those persons, corporations or business entities who participated in said interchanges, exchanges or communications; (c) The content of said interchanges, exchanges or communications; and (d) The identity of the custodian of any documents which relate to said interchanges, exchanges or communications. -48- Response No. 51: Refer to Response #50 above. Interrogatory No, 52: Identify all persons who have testified on your behalf before the Occupational Safety and Health Administration, the National Institute of Occupational Safety and Health, any United States congressional committee, sub-committee, administrative hearing or investigative proceeding on the subjects of the human health consequences of exposure to asbestos dusts, fibers and/or products and the setting, modification, feasibility and acceptance of allegedly safe or proper levels of exposure to said asbestos and asbestos products. Response No. 52: Neither Celotex nor its predecessors-in- business had employees or agents testify before any governmental agency regarding injury or death from exposure to asbestos. However, E. A. DiSalvo, Vice President of Panacon, a predecessor-in-business of the Celotex Corporation, made a statement before the Department of Labor on March 16, 1972, outlining our general compliance with the existing exposure standards and discussing the difficulty involved in meeting a lower standard. Interrogatory No. 53: Identify all documents presented to or utilized in the preparation of testimony before the organizations, agencies or committees referred to in Interrogatory No. 52, specifying which documents were presented or utilized for each such body and the present custodian and location of each document. Response No. 53: Refer to Response #52 above. Further, due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. Interrogatory No. 54: For all testimony or presentations identified in your Answer to Interrogatory No. 52, identify: (a) The dates and descriptions of the hearings and proceedings; (b) The relationship between the person who testified or responded and you; and -49- (c) All studies, test results, scientific and/or medical documents relied upon by each person as the basis for any recommendation made or testimony given; Response No. 54: Refer to Response #52 above. Interrogatory No. 55: State your knowledge relating to the meaning of "threshold limit value" as it pertains to asbestos exposure and disease. Response No. 55; This Interrogatory is interpreted as requesting the Threshold Limit Value standards set by the Occupational Safety and Health Administration. OSHA standards are a matter of public record and are equally available to Plaintiff. In addition, Celotex and its predecessors-in-business have been advised of the following Threshold Limit Value; 1) OSHA 1971 and all subsequent regulations. 21) Safety and Health Standards for Federal Supplied Contracts, U.S. Department of Labor, Wage and Hour Public Contracts Division, Washington, D.C. (Walsh-Healy Act 1961). Celotex did not enter the business of manufacturing asbestos-containing insulation products until 1972. J. F. Kegenith, Manager of Employee Relations for The Celotex Corporation, received "Safety and Health Standards for Federal Supplied Contracts". Celotex has been informed that E. A. DiSalvo, Vice President of Panacon Corporation, received OSHA notices. Celotex and its predecessors-in-business have applied the Threshold Limit Standards required under the Walsh-Healy Act since 1961 and the standards required under the Occupational Safety and Health Act since 1971. Also, Philip Carey -50- Manufacturing Company followed the recommended Threshold Limit Standards for Nuisance Dust, enacted by The Industrial Commission of Ohio, Division of Safety and Hygiene in approximately 1949. Interrogatory No. 56: With reference to "threshold limit value" (which, for purposes of this interrogatory, means how much asbestos dust and/or fibers one can safely inhale, absorb or ingest without risk of disease or illness), state: (a) When and by what means you obtained information related thereto; (b) The substance of any information imparted to you regarding the same; and (c) Whether and by what means you advised or warned anyone of details relating thereto. Response No. 56: (A) & (B) Refer to Response #55 above. (C) Defendant objects generally to Plaintiff's Interrogatories insofar as the question assumes facts which render the answer misleading, prejudicial and without any probative value. Without waiving its objection, Defendant refers to Response #22 above for information as to warnings. Interrogatory No. 57: State whether you ever knew that any governmental, private agency, and/or other entity issued guidelines suggesting a "threshold limit value" (as defined in Interrogatory No. 56) for exposure to asbestos dust and/or fibers. If so, state: (a) The identity of the agency or other entity which issued said guidelines; guidelines; (b) The verbatim content of said issued; (c) The date said guidelines were (d) The date you were first aware of the purpose of said guidelines; and (e) The custodian, location and identity of all documents related thereto. -51- Response No. 57: Refer to Response #55 above. Interrogatory No. 58: State whether you ever possessed knowledge of documents indicating that existing or proposed threshold limit values (as defined in Interrogatory No. 56) were not safe or proper or that lower threshold limit values were necessary in order to prevent diseases caused by exposure to asbestos. If so, identify: (a) The source of such knowledge; knowledge; (b) The persons who obtained such (c) All documents relating thereto; and (d) The custodian and location of all documents identified in your Answer to Part (c) of this Interrogatory. Response No. 58: Defendant objects to the form of this Interrogatory, in that it is vague, misleading, overbroad and ill-defined. Without waiving its objection, Defendant states that due to the record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. In an attempt to be responsive, Defendant states not to the best of its knowledge other than as referred to in Response #55 above. Interrogatory No. 59: State whether you were ever made aware that the proper method for determining safe levels of asbestos dust was to test concentrations of asbestos fibers in the air rather than the total number of asbestos particles in the air. If so, state: (a) The source of such knowledge; knowledge; (b) The persons who obtained such (c) All documents relating thereto; and (d) The custodian and location of all documents identified in your Answer to Part (c) of this Interrogatory. -52- Response No. 59: Defendant objects to this question on the grounds that it is irrelevant to the instant action and not calculated to lead to the discovery of admissible evidence. Further, Defendant objects generally to Plaintiff's Interrogatory insofar as it requests Defendant to render a scientific opinion. Defendant is not a scientific expert and is not qualified to render scientific opinions. Interrogatory No. 60 State in detail what tests or studies, if any, you ever conducted or directed with regard to the quantity, quality, or threshold limit values as defined in Interrogatory No. 56 of asbestos dust, fibers or particles to which insulators and others who use your asbestos products and/or others working in the same vicinity are exposed. Response No. 60: Defendant objects to the repetitive nature of this Interrogatory and refers to Response #32 above. Interrogatory No. 61: State in detail what research, tests or studies, if any, you ever conducted or directed to determine whether the exposure of insulation workers or others to asbestos dust exceeded the American Conference of Governmental Industrial Hygienists' (A.C.G.I.H.) recommended threshold limit values. Response No. 61: Defendant objects generally to Plaintiff's Interrogatory insofar as the question assumes facts which render the answer misleading, prejudicial and without any probative value. Without waiving its objections, refer to Response #32 and #55 above. Interrogatory No. 62; State in detail what steps, if any, you ever took to determine whether the American Conference of Governmental Industrial Hygienists' (A.C.G.I.H.) recommended threshold limit values for exposure to asbestos dust were accurate or reliable. > -53- Response No. 62: Defendant objects generally to Plaintiff's Interrogatory insofar as it requests Defendant to render a medical opinion. Defendant is not a medical expert and is not qualified to render medical opinions. Further, Defendant objects generally to Plaintiff's Interrogatory insofar as the question assumes facts which render the answer misleading, prejudicial and without any probative value. Without waiving its objection, Defendant refers to Response #55 above. Interrogatory No. 63: State your knowledge relating to the meaning of "dose response relationship" as it pertains to exposure to asbestos dusts, fibers and/or products and the contracting of disease, including: asbestosis, pneumoconiosis, mesothelioma, lung cancer and other cancers. Response No. 63: Defendant objects generally to Plaintiff's Interrogatories insofar as they request Defendant to render a medical opinion. Defendant is not a medical expert and is not qualified to render medical opinions. Interrogatory No. 64: State whether you have ever placed any warranties, guarantees or other such representations on any asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 and/or on or in the containers or packages in which said products were sold, distributed or otherwise placed in the stream of commerce. Response No. 64: Yes. Interrogatory No. 65; If your Answer to Interrogatory No. 64 is in the affirmative, for each such product and/or container or package, identify: (a) The inclusive dates on which each such warranty, guarantee or other representation appeared on or with the product and/or on or in the container or package; (b) A verbatim description of each such warranty, guarantee or other representation; -54- > (c) A description of the location on the product and/or container where each such warranty, guarantee or other representation was placed; (d) Each of your present or former highest supervisory employees with knowledge of the decision to place any such warranties, guarantees or other representations on or with the product and/or on or in the container or package; and (e) The custodian of all documents in your custody, possession or control which relate to or describe any such warranties, guarantees or other representations or the decision to place any of these on or with the product and/or on or in the container or package. Response No. 65: Due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. In an attempt to be responsive, Defendant states that certain limited warranties have been utilized in regard to some asbestos-containing products. The language used by Philip Carey from at least mid-1957 is; We warrant our materials to be of good quality and will replace material proved defective. This warranty is in lieu of all others express or implied and may not be extended by representatives, written sales information or drawings. While we recommend uses for our material based on tests believed reliable, we in no way guarantee particular methods of use or application or performance under special conditions. The Celotex language, subsequent to 1972, reads as follows: Characteristics, properties, or performance of materials or systems herein described are based on data obtained under controlled test conditions. Celotex makes no warranties, expressed or implied, as to their characteristics, properties, or performance under any variations from such conditions in actual construction. The Celotex Corporation assumes no responsibility for the effects of structural movement. -55- Refer to copies of warranties, attached, Exhibit "L". Interrogatory No. 66: State whether the content and/or placement of any warranty, guarantee or other representation described in your Answer to Interrogatory Nos. 64 and 65 was ever changed. If so, for each such change, identify: (a) The nature of the change, including a verbatim description, if applicable; (b) The date when the change was made and the inclusive dates during which such change appeared on or with the product and/or on or in the container or package; (c) The persons with personal knowledge of the reasons for making the change; and (d) The custodian of documents in your custody, possession or control which relate to the decision and process of making the change. Response No. 66: Refer to Response #65 above. Interrogatory No. 67: State when and by what means you became aware of the alleged hazards of exposure to asbestos dusts, fibers and/or products to the health of persons coming into contact with, handling or using asbestos products. Response No. 67: Defendant objects generally to Plaintiff's Interrogatories as being vague and ambiguous insofar as they use the words "aware", "learned", as such terms are manifestly imprecise when used in a corporate context. It is not clear how or even whether an entity such as a corporation can give or refuse to give "consideration" to any possibility or recognize or agree with a given statement or belief. In essence, questions of this nature are incapable of being intelligently answered by a corporation such as this Defendant. In an attempt to be responsive, without waiving its objection, Defendant states that the best information available to this Defendant indicates that its predecessors-in-business became aware of the existence of the -56- disease of asbestosis sometime prior to 1960. However, it was not until the mid-1960's that this Defendant's predecessors-in- business became aware that the disease of asbestosis could occur in insulators and others who have used asbestos insulation products in previous decades. Earlier studies had indicated that asbestosis was principally a problem of workers in mines and manufacturing facilities, occurring in those who were continually exposed to high concentrations of 100% raw asbestos fiber. Furthermore, it was not until the mid-1960's that this Defendant's predecessors-in-business became aware of the existence of any statistical connection between exposure to asbestos and the contraction of cancer. Celotex has been advised that mesothelioma is a form of cancer and that the actual cause of cancer is unknown. Defendant is aware of the continuing controversy, and is attempting to keep abreast of relevant medical information as it is developed. Interrogatory No. 68: State when and by what means you became aware that exposure to asbestos dusts, fibers and/or products was acknowledged to be hazardous to the health of persons coming in contact with, handling or using asbestos products. Response No. 68: Refer to response No. 67 above. Interrogatory No. 69: State whether you ever learned that there is a causal connection between exposure to asbestos dust and: (a) Asbestosis; (b) Pneumoconiosis; (c) Lung Cancer; -57- (d) Mesothelioma; and (e) Other cancers. Response No. 69; Defendant objects generally to Plaintiff's Interrogatories insofar as they request Defendant to render a medical opinion. Defendant is not a medical expert and is not qualified to render medical opinions. Without waiving its objection, Defendant refers to Response No. 67 above. Further, Celotex has been advised that mesothelioma is a form of cancer and that the actual cause of cancer is unknown. Defendant is aware of the continuing controversy, and is attempting to keep abreast of relevant medical information as it is developed. Interrogatory No. 70; If your Answer to Interrogatory No. 69 is in the affirmative, identify the following as to each such disease listed therein; (a) When and by what means you first became aware of such causal connection; (b) If your awareness of such causal connection was obtained at any conference, lecture, convention, symposium, or other such meeting, identify the event, the person who attended on your behalf and/or any documents obtained from such event; and (c) If your awareness of such causal connection was obtained from a medical or scientific study, or from any other published works, identify the same. Response No. 70; Refer to response No. 69 above. In addition, Celotex is unable to accurately list all of the requested information for reasons specified in its Preliminary Statement. Celotex is informed and believes that predecessors-in-business received the following documents sometime prior to Celotex's -58- 3 acquisition of the Panacon Corporation in April, 1972. However, many of the following were not received at or near the articles' publication. ASBESTOS-RELATED PUBLICATIONS RECEIVED BY CELOTEX'S PREDECESSORS-IN-BUSINESS DATE TITLE AUTHORS PUBLISHER/ PUBLICATION DATE REC'D 1955 "Mortality From Lung Cancer in Asbestos workers" Richard Doll British Journal of Industrial Medicine 1957 "The Asbestos Kenneth W. Industry-Certain Smith, M.D. Health Experiences and Hugh Among Asbestos Jackson Workers" Home Office Life 4/63 Underwriters Association Post 1960 "Nonoccupational Asbestosis" Raimo Kiviluoto Medical Practices 4/24/60 "Diffuse Pleural Mesothelioma and Asbestos Exposure in the North Western Cape Province" J.C. Wagner C.A. Sleggs & Paul Marchand British Journal of Industrial Medicine 12/3/60 "Asbestosis and Abdominal Neoplasms" E.E. Keal The Lancet 2/1963 "Methodology In Industrial Health Studies" Thomas F. Mancuso, M.D. MPH, and Elizabeth J. Coulter, Ph.D. Archives of Environmental Health, Vol. 6 4/5/63 7/1963 "Talc Pneumo coniosis" M. Kleinfield, M.D., C.P. Geil, M.D. J.F. Majeranowski, M.D., and J. Messite, M.D. Archives of Environmental Health, Vol. 7 -59 ) 10/3/63 "Case Records of the Massa chusetts General Hospital" Benjamin Castleman, M.D., Ed. The New England Journal of Medicine 11/5/63 1964 "Occupational Health Study of the Asbestos Products Industry in the United States" L. Cralley, H. Ayer, P. Enterline, A. Henschel, W. Lainhart Dept, of Health, Education and Welfare, Public Health Service, Division of Occupational Health 5/6/64 "Asbestos Exposure & Neoplasia" I.J. Selikoff, M.D., Jacob Churg, M.D., E. Cuyler Hammond, DSC Journal of the American Medical Association 10/23/64 Report and Recommendations of the Working Group on Asbestos & Cancer Delegates who attended the meeting International Union Against Cancer (UICC) 2/16/65 10/12/68 "The Magic Mineral" The New Yorker magazine 11/69 "Asbestos-Public Not at Risk" W.P. Howard Asbestos Information Committee Undated "2100 +/month for Asbestosis" Unknown Unknown 4/5/63 3/2/71 The Facts About Asbestos and Health W.P. Raines AIA/NA 10/71 "Asbestos, The Need For and Feasibility of Air Pollution Controls" (conclusion only received) National Academy of Science 11/22/71 > -60- 1/18/72 "Thetford Highlights" Patricia Motherwell Le Progress de Thetford 1/28/72 Interrogatory No. 71: State whether you ever specifically informed the purchasers and/or users of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 that exposure to asbestos dust could cause asbestosis, pneumoconiosis, lung cancer, mesothelioma and/or other cancers. If so, state: (a) The date(s) of such notice to purchasers or users; (b) The means used for transmittal of such notice; (c) The custodian, identity and location of each document which refers to or contains information relevant to such notice; and (d) The identity of each person who made decisions regarding the furnishing of such notice to purchasers and/or users. Response No. 71: (a-c) Defendant objects generally to Plaintiff's Interrogatories insofar as the question assumes facts which render the answer misleading, prejudicial and without any probative value. Without waiving this objection, Defendant responds: Refer to Response No. 22 above. Refer also to copies of representative sales brochures which contained warnings, marked Exhibit "M". (d) Due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. Refer to the attached correspondence, notes, draft warnings, purchase orders for labels and stamps, marked Exhibit "N" which implemented the Celotex warning program in 1972 which insured compliance with Occupational Safety & Health Administration requirements. -61- Interrogatory No. 72: State whether you ever specifically informed the distributors identified in your Answer to Interrogatory No. 20 and/or those identified in your Answer to Interrogatory No. 21 who resold or redistributed your asbestos products that exposure to asbestos dust could cause asbestosis, pneumoconiosis, lung cancer, mesothelioma and/or other cancers. If so, state: (a) The date(s) of such notice; (b) The means used for transmittal of such notice; (c) The custodian, identity and location of each document which refers to or contains information relevant to such notice; and (d) regarding the those engaged products. The identity furnishing of in the resale of each person who made decisions such notice to distributors and/or or redistribution of your asbestos Response No. 72: Refer to Response No. 71 above. Interrogatory No. 73: State whether you ever provided any caution, notice, warning or other statement or explanation of the potential health hazards of exposure to asbestos on or with the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. Response No. 73: Refer to response No. 71 above. Interrogatory No. 74: If your Answer to Interrogatory No. 73 is in the affirmative, state as to each product identified in your Answer to Interrogatory Nos. 8 and 19: (a) The date(s) on which such caution, notice, warning or other statement or explanation first appeared; (b) The identity of each person with knowledge of decisions made regarding the use of such caution, notice, warning or other statement or explanation; (c) The verbatim content of each caution, notice, warning or other statement or explanation when it was first used; (d) Whether the caution, notice, warning or other statement or explanation was ever altered, amended or changed. If so, how, when and why was it altered, amended or changed; and (e) The location of the caution, notice, warning or other statement or explanation on each such product and/or its container or package. -62- Response No. 74: Refer to response No. 71 above. Interrogatory No. 75; State when you first became aware that asbestos products were being labeled with a caution, warning, notice or other statement or explanation concerning the potential health hazards resulting from the use of asbestos products and/or exposure to asbestos dust or fibers and identify the product(s) and manufacturer(s) with which such label was connected. Response No. 75: The Celotex Corporation obtained such information in 1972 when it acquired predecessors-in-business. Shortly after such acquisition, Celotex affixed warning labels to its asbestos-containing products. The best information Celotex has regarding predecessors'-in-business awareness is that in late October, 1968, Johns-Manville Corporation notified the Secretary of Philip Carey Corporation by letter that it was putting warnings on its insulation products. At the time of such notification, predecessors'-in-business products contained a significantly lower percentage of asbestos than other manufacturers' insulation products, and further, predecessors'- in-business principal insulation products--Careytemp--became asbestos-free in 1969. Interrogatory No. 76: Identify the officer, agent, servant, employee or other representative of yours who first obtained an awareness that asbestos products were being labeled as described in Interrogatory No. 75. Response No. 76: Due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. Also, refer to Response #75 above. Interrogatory No. 77: Identify the custodian, identity and location of all documents related to the knowledge obtained by you regarding the labeling of asbestos products as described in Interrogatory No. 75. -63- Response No. 77: Legal Department, The Celotex Corporation, 1500 N. Dale Mabry Highway, Tampa, FL 33607. Refer also to Response #75 above. Interrogatory No. 78: State when and by what means you first became aware that Johns-Manville Corporation or any of its affiliated companies placed on its asbestos products a caution, warning, notice, other statement or representation concerning the potential health hazards resulting from the use of asbestos products and/or exposure to asbestos dust or fibers. Response No. 78: Defendant objects generally to Plaintiff's Interrogatories as being vague and ambiguous insofar as they use the word "aware", as such term is manifestly imprecise when used in a corporate context. It is not clear how or even whether an entity such as a corporation can give or refuse to give "consideration" to any possibility or recognize or agree with a given statement or belief. In essence, questions of this nature are incapable of being intelligently answered by a corporation such as this Defendant. In an attempt to be responsive, Defendant refers to Response #75 above. Interrogatory No. 79: Identify the officer, agent, servant, employee or other representative of yours who first became aware that asbestos products of Johns-Manville Corporation or its affiliated companies were being labeled as described in Interrogatory No. 78. Response No. 79: Refer to Response #75 above. Interrogatory No. 80: Identify the custodian, identity and location of all documents related to the knowledge obtained by you regarding the labeling of asbestos products by Johns-Manville Corporation or its affiliated companies as described in Interrogatory No. 78. Response No. 80: Defendant objects to repetitive nature of the Interrogatory and refers to Response #77 above. -64- Interrogatory No. 81: If upon learning that Johns-Manville Corporation or its affiliated companies labeled its asbestos products as described in Interrogatory No. 78 you did not apply such labels to the products identified in your Answer to Interrogatory Nos. 8 and 19, state: (a) The reason(s) for such a decision; (b) The identity of any agent, servant, employee, officer or representative of yours involved in discussions and decisions regarding the same; and (c) The custodian, identity and location of all documents pertaining to such a decision. Response No. 81: Defendant objects to the repetitive nature of this Interrogatory and refers to Response #75 above. Refer also to Response Nos. 22, 71 and 72 above as to Defendant's warnings. Interrogatory No. 82: State whether you specifically informed your employees, agents, servants and/or contract units that use of asbestos products and/or exposure to asbestos dust or fibers was either actually or alleged to be hazardous to their health. Response No. 82: Defendant objects to this question on the grounds that it is irrelevant to the instant action and not calculated to lead to the discovery of admissible evidence as Plaintiff was not employed at Defendant's or predecessors' facility and his exposure was not the same as Defendant's or predecessors' employees. In an attempt to be responsive without waiving its objection. Defendant states that Celotex is informed and believes that Philip Carey Manufacturing Company first offered chest x-rays to its employees in some plants as early as 1950. Also, its employees were informed when the x-ray unit, sponsored by the Anti-Tuberculosis League, was in the area and were encouraged to undergo x-ray examinations since approximately 1965. Since 1972, The Celotex Corporation has provided -65- comprehensive medical examinations on an annual basis for its employees working with asbestos, including chest x-rays and pulmonary function tests. Professional Health Services, Inc., performed these medical examinations from 1972-1977. Hearex Corporation performed the examinations from 1978 until early 1982, and since that time Medi-Systems has been retained for these functions. Plant safety bulletins such as those marked Exhibit "J" date back at least to 1944. Further, various safety booklet and bulletins have periodically been distributed to employees. In addition, Celotex and its predecessors have instituted in-plant safety programs. Predecessors-in-business sold and/or disbanded their ') contract units prior to the Panacon-Celotex merger in 1972. Due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. Interrogatory No. 83: If your Answer to Interrogatory No. 82 is in the affirmative, state: (a) When and in what manner you first provided such information to these persons; (b) The identity of any agent, servant, employee, officer or representative of yours involved in discussions and decisions regarding providing information to these persons; (c) The verbatim content of any written documents and/or communications containing such information; and (d) The custodian, identity and location of all documents which relate or pertain to providing such information to these persons. -66- Response No. 83: Refer to Response #82 above. Interrogatory No. 84: Describe in detail any precautionary procedures which you urged or required your employees, agents, servants and/or contract units to follow so as to reduce and/or avoid the potential hazards or dangers associated with use of asbestos products and/or exposure to asbestos dust or fibers and state when and how each such procedure was introduced to these individuals. Response No. 84; Defendant objects to this question on the grounds that it is irrelevant to the instant action and not calculated to lead to the discovery of admissible evidence as Plaintiff was not an employee of Defendant or its predecessorsin-business. In an attempt to be responsive without waiving its objection, Defendant states it is informed and believes that predecessors-in-business made cloth-type respirators available to some plant employees as early as the 1930's. Some time prior to 1945, predecessors-in-business purchased filter-type respirators and instituted a job evaluation plan which required certain employees to wear respirators while working in specified areas. The filter-type respirators were those approved by the U.S. Bureau of Mines and manufactured by the Mine Safety Appliance Company in Pittsburgh, Pennsylvania. Defendant believes that respirators currently approved by the U.S. Bureau of Mines, if used properly, will prevent the inhalation of asbestos dust and fibers. The manufacturer or the U.S. Bureau of Mines should be contacted for any additional information. Interrogatory No. 85: State whether you ever required your employees, agents, servants and/or contract units who worked with and around asbestos and/or asbestos products to wear respirators, gas masks, protective clothing and/or other protective devices. If so, state: -67- (a) Which employees, agents, servants and/or contract units, by type of employment and department, were required to use each such protective device; (b) The date(s) on which the directive relative to each such protective device was issued for each type of employee and each department; (c) Which type of protective device was required to be used or worn by each type of employee and each department; (d) The identity of any agent, servant, employee, officer or representative of yours involved in discussions and decisions regarding the same; and (e) The custodian, identity and location of all documents pertaining to protective devices. Response No. 85: Refer to Response #84 above. Due to record retention policies and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested, however, use of respirator was generally dictated by local union rules. Defendant has been informed from Defendant's predecessors-in-business that respirators were made available in each contract unit upon the request of the union worker. Interrogatory No. 86; State whether at the commencement of an individual's employment with you, from 1930 to the present, you inform that person as to possible health ramifications of working with and around asbestos fibers, dust and/or products. If so, set forth: (a) The nature of the warning; (b) The manner in which said information is communicated and, if the communication is in writing, attach a copy hereto; -68- (c) When such practice was initiated; and (d) By whom such information is communicated. Response No. 86: Defendant objects to this question on the grounds that it is irrelevant to the instant action and not calculated to lead to the discovery of admissible evidence as to predecessors-in-business. In an attempt to be responsive without waiving its objection, Defendant refers to Response #82 above. Interrogatory No. 87: State whether, based upon the material contents, the manufacturing methods and the method of application or installation of your asbestos products, your asbestos products can generally be applied by an insulator or others without liberating asbestos fibers. Response No. 87; Defendant objects to providing such information for each such product on the grounds that this Interrogatory is overbroad and unduly burdensome. If Plaintiff will specify those products to which he was exposed, Defendant will attempt to provide the requested information. In an attempt to be responsive without waiving its objection, Defendant refers to Response #15 above. Interrogatory No. 88: State whether it was foreseeable to you that your asbestos-containing insulation products would have to be removed, stripped or replaced at any time after installation. Response No. 88: Objection. This Interrogatory asks for legal conclusions and is tantamount to having the defense do the research for the Plaintiff. Interrogatory No. 89: State whether you ever provided insulators arid others who would be applying or removing your asbestos products instructions concerning safety precautions to use during use of or exposure to such products. -69- Response No. 89: Defendant objects to repetitive nature of these Interrogatories. Further, Defendant objects generally to Plaintiff's Interrogatory insofar as the question assumes facts which render the answer misleading, prejudicial and without any probative value. Without waiving its objection, Defendant notes that it had no jurisdiction over such workers nor any right to inspect such jobsites. Refer to Responses #22 and #71 above. Interrogatory No. 90: State when you first received notice that any person was claiming injury as a result of use of and/or exposure to asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. Response No. 90; The first lawsuit naming Celotex's predecessor-in-business as a Defendant in which a claimant sought recovery for a disease specifically alleged as resulting from exposure to asbestos was filed byi Samuel Potter in the U.S.D.C., Eastern District, Beaumont Division, Texas, #6329 on May 27, 1969. The lawsuit was subsequently settled. Prior to 1969, Celotex's predecessors-in-business was named as a Defendant in an action which alleged an abrasion to the lungs resulting from claimant's exposure to several different substances, one of which was asbestos. To the best of Celotex's knowledge, an asbestos-related disease was never diagnosed and the case was subsequently dismissed. Gladys Faciane vs. The Travelers Insurance Company, et al., 19th Judicial Circuit, Louisiana. Interrogatory No. 91; With regard to the first notice of claim of injury described in your Answer to Interrogatory No. 90 and regarding all claims filed prior to 1970 for injury resulting from use of and/or exposure to asbestos products, state: -70- (a) The identity of each claimant; (b) The date of notice of each claim; (c) A description of each claim; (d) The type of injury allegedly sustained by each claimant; (e) The identity of each attorney representing the individuals making such claims; (f) The style, case number and court applicable to each claim; (g) The resolution of each claim; and (h) The custodian, identity and location of all documents which relate or pertain to each claim. Response No. 91: Refer to Response #90 above. Interrogatory No 92: State whether, prior to 1970, any person filed a claim against any worker's compensation insurance carrier which provided coverage for you alleging that he or she contracted a disease as a result of use of and/or exposure to asbestos products identified in your Answer to Interrogatory No. 90. Response No. 92: Celotex objects to furnishing a response relating to compensation claims filed by employees at Defendant's and/or predecessors' manufacturing plants. Plant employees worked with and were continually exposed to asbestos fiber in an enclosed plant environment whereas insulation applicators and others were exposed to a manufactured product containing a much smaller percentage of asbestos, and such asbestos fiber was encapsulated in the products manufactured. Without waiving this objection, Celotex sets forth below a list of unverified claims of former employees who worked outside of the manufacturing plants and whose exposure to asbestos may have been similar to the exposure of the Plaintiff. -71- ) WORKMEN'S COMPENSATION CLAIMS The Celotex Corporation, successor-in-business to the Philip Carey Manufacturing Company, believes that the following individuals may have filed a workmen's compensation claim for an illness associated with exposure to asbestos dust. Much of the following information was recently discovered in connection with current asbestos litigation. Accordingly, The Celotex Corporation is unable to verify if, or when, Philip Carey became aware of the claims listed below. The Celotex Corporation has searched its records for additional information and/or verification of these claims. All material information that has been obtained is listed below. It must be emphasized that Celotex is not admitting or verifying the authenticity of any claim listed below. Further, the information is being supplied because it may lead to the discovery of relevant and admissible evidence. The information below does not include any workmen's compensation claims filed by employees working in any manufacturing facility. Employee Name Date Filed (Date Death) State Disposition Alleged Disability Harold Swinson 9/61 (1961) RI Death Claim - Silicosis/ Unknown Asbestosis Wm. E. Latto 1/10/61 (2/22/65) OH Disab. Allowed 5/62 Asbestosis Death Claim Pending Nelson L. Lee 10/1/79 (12/23/78) DE Death Claim Pending Asbestosis Carcinoma of lung -72- Adolpho Serra 8/31/77 MA Death Claim Unknown Adeno Carcinoma The following information was received either from Armstrong Cork Company in their response to a recent plaintiff's production request or from Johns-Manville through exhibits they produced for trial. Celotex has no independent information to deny and/or corroborate the substance of the documents. Defendant is unable to determine where the below listed claimants were employed, as the only relevant employment address lists predecessors home office, where paychecks were issued. However, Defendant believes the claimants probably worked in one of Philip Carey's contract units. The documents indicate the following: Employee Name Date Filed (Date Death) James W. Riley 1954 (1/24/61) State CA Disposition Alleged Disability Disability Pneumo Allowed 11/59 coniosis John E. Swartout Disab. 12/55 Death 6/56 (5/30/56) CA Death Claim Allowed Asbestosis Steve Gilivich 11/61 CA Disability Respiratory Settled 1965 Injury Anthony J. Onofrio 1962 CT Disability Unknown Claim Unknown Allen Everitt 5/27/63 CA Disability Pulmonary Claim Unknown Disease William Crader Sr. 6/10/66 CA Death Claim Asbestosis (3/7/66) Allowed Clifford Harding Unknown CA Disability Asbestosis Claim Settled -73- Edward L. Pfleghaar 11/68 CA Disability Asbestosis Claim Settled 3/71 Henry C. Puetz 7/26/66 CA Disability Asbestosis Allowed, Appeal Settled In addition, Celotex is aware of the possibility that the following individuals may have contracted an asbestos-related disease. The below-listed information was obtained from a handwritten list of names which Celotex has been unable to verify. Celotex has no information on these individuals other than, in some cases, their address, date of employment and treating physician: Name John Tyler, dec'd. Robert Horseman Wayne E. Boyer State CA CA NE Disposition Settled 10/24/68 Unknown Unknown Clyde Nicholson CA Unknown William McCormick CA Unknown As to Defendant's plant employees and the first claim filed for an asbestos-related disease, Defendant states that although Defendant lacks complete records of our predecessors- in-business, it is informed and believes Clarence Hulette filed a compensation claim alleging asbestos/silicosis in 12/1946. This claim was disallowed. However, a later claim by Mr. Hulette was allowed in 1958 for asbestosis. Mr. Hulette's claim was filed with the Ohio Bureau of Workmen's Compensation, Claim Number 0D47978. -74- Interrogatory No. 93: If your Answer to Interrogatory No. 92 is in the affirmative, provide the following information: (a) A list of each such claim by claimant's name, date claim filed and jurisdiction; and such claim. (b) A brief summary of the disposition of each Response No. 93: Refer to Response #92 above. Interrogatory No. 94: State whether you ever received any reports or communications from your worker's compensation insurance carrier or products liability insurance carrier with regard to potential health hazards incident to use of asbestos products and/or exposure to asbestos fibers or dust. Response No. 94: Not to the best of this Defendant's knowledge. Interrogatory No. 95: If your Answer to Interrogatory No. 94 is in the affirmative, state: (a) The substance of the contents of such reports or communications? (b) The identity of the insurance carrier from which you received each report or communication; (c) The dates of each such report or communication; and (d) The custodian, identity and location of all documents which relate or pertain to such reports or communications. Response No. 95: Refer to Response #94 above. Interrogatory No. 96: State whether you ever maintained or operated a unit or units of your corporation, including, but not limited to, divisions, subsidiaries or any other entity, which was/were under contract to apply or install the asbestos products described in your Answer to Interrogatory Nos. 8 and 19. Response No. 96: Celotex's predecessors-in-business operated Contract Branches and Sales Unit as early as 1937. Celotex's best information indicates these Contract Units became a separate -75- division in 1953. All Contract Units were sold and/or disbanded in 1970 or 1971. The purpose of these units was to secure contract jobs and apply the insulation at the jobsite. Interrogatory No. 97: If your Answer to Interrogatory No. 96 is in the affirmative, identify any and all claims filed by workers in such contract units for disease arising out of use of asbestos products and/or exposure to asbestos fibers or dust and, as to each such claim, state: (a) The date on which you first received notice; (b) The identity of the claimant; (c) The nature of the claim; (d) The style, case number and jurisdiction; (e) The resolution of the claim; and (f) The custodian, identity and location of all documents which relate or pertain to each claim. Response No. 97: Refer to Response #92 above. Interrogatory No. 98: Identify any and all insurance agreements entered into by and between any person carrying on an insurance business and you which may be available to satisfy part or all of a judgment that might be entered in this action or to indemnify or reimburse you for payments made to satisfy the judgment. As to each such agreement, identify the insurance carrier, the amount of coverage and the applicable dates of coverage. Response No. 98: Please refer to the attached list of liability carriers for Celotex (1972 - 1984) and its predecessors-in- business, marked Exhibit *K*. The extent and proper application of this coverage is the subject of litigation. Therefore, Defendant is unable to state with any certainty the extent to which these policies of insurance will be applicable to lawsuits involving asbestos-related diseases. > -76- Interrogatory No. 99: Describe the method by which you have maintained records concerning the manufacture, sale, advertising, distribution, delivery and installation of each of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. Response No. 99: Defendant objects to this Interrogatory as vague, overbroad, irrelevant and unduly burdensome. In an attempt to be responsive without waiving its objection, Defendant refers to the attached copy of its record retention policy, marked Exhibit "0", as well as to the above responses. Interrogatory No. 100; With regard to the record-keeping method described in your Answer to Interrogatory No. 99, identify: (a) Each present and former corporate department, division or subdivision responsible for maintaining the records; (b) How the records are kept, e.g.,in boxes, files, on microfilm, microfiche or computer tape or disk; (c) The inclusive dates of manufacture, sale, advertising, distribution, delivery and installation that the record keeping system covers; (d) The location(s) where such records are maintained; and (e) The identity of each person employed by you at any time from 1930 to the present, in the highest supervisory capacity, who is or was directly responsible for the collection and maintenance of such records. Response No. 100; Refer to Response #99 above. Interrogatory No. 101: If the record keeping system described in your Answer to Interrogatory No. 99 includes use of microfilm, microfiche, computer tape or disk or any other system in which data is taken from other records, state whether you have retained the documents or other material from which the information entered into these modes of storage was obtained. If not, indicate: (a) The date when and location where the original records were destroyed or discarded; (b) The custodian and location of the records prior to their destruction; and -77- (c) The identity of each employee, representative, official or agent of yours who ordered, authorized or supervised said destruction. Response No. 101: Refer to Response #99 above. Interrogatory No. 102: State whether, at any time from 1930 to the present you made any representations that the presence of asbestos in the products identified in your Answer to Interrogatory Nos. 8 and 19 made these products superior, in any way, to any asbestos-free product or material intended for the same or similar use. Response No. 102: Due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. Refer to Response Nos. 25 and 65 above. Interrogatory No. 103: If your Answer to Interrogatory No. 102 is in the affirmative, indicate with respect to each such representation: made; (a) The date(s) on which the representation was (b) Its exact content; and (c) The manner in which it was communicated. Response No. 103; Refer to Response #102 above. Interrogatory No. 104; State whether, at any time from 1930 to the present, you made any representations that the use of asbestos or the use of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 was safe, harmless or not dangerous. Response No. 104: Due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. Refer to Response Nos. 15 and 67-70 above. -78- Interrogatory No. 105: If your Answer to Interrogatory No. 104 is in the affirmative, indicate as to each such representation: made; (a) The date(s) on which the representation was (b) Its exact content; and (c) The manner in which it was communicated. Response No. 105: Refer to Response #104 above. Interrogatory No. 106: State whether any of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 were ever stored or warehoused by you in Maryland at any time from 1930 to the present. Response No. 106: Due to record retention policy and for reasons given in the Preliminary Statement, Defendant does not have complete records and is unable to respond as requested. Refer to distributor information in Response No. 20 above. Interrogatory No. 107: If your Answer to Interrogatory No. 106 is in the affirmative, identify: facility; (a) The address of each warehouse or storage (b) The asbestos products stored or warehoused at each warehouse or storage facility identified in your Answer to part (a) of this Interrogatory; and (c) The year(s) of such storage or warehousing; (d) The custodian, identity and location of each document in your custody, possession or control which describes or relates to such storage or warehousing. -79- Response No. 107: Refer to Response #106 above. Interrogatory No. 108: Identify the means by which the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 were transported to Maryland at any time from 1930 to the present and state: (a) If the asbestos products were transported by rail, identify the name(s) of the railroad company(ies) providing that service and the year(s) during which such service was used; (b) If the asbestos products were transported by truck, identify the name(s) of the carrier providing that service and the year(s) during which such service was used; (c) If the asbestos products were transported by vessel, identify the name(s) of the shipline providing that service and the year(s) during which such service was used; (d) The identity of each employee of yours responsible for coordinating the transport or delivery of such products to Maryland; (e) The identity of each employee, officer, agent or representative of yours with personal knowledge of the transport or delivery of such products to Maryland; and (f) The custodian, identity and location of each document which describes or relates to the transport or delivery of such products to Maryland. Response No. 108: Defendant objects to this question on the grounds that it is irrelevant to the instant action and not calculated to lead to the discovery of admissible evidence as the means of transportation is of no significance to this cause of action. Interrogatory No. 109: Identify each person whom you expect to call as an expert witness at trial, state the subject matter on which each expert is expected to testify, state the substance of the findings and opinions to which each expert is expected to testify and a summary of the grounds for each opinion and produce any written report made by each expert concerning those findings and opinions. -80- Response No. 109: The identity of expert witnesses expected to testify at trial and related information have been provided to Plaintiffs pursuant to the Pretrial Scheduling Order applicable to these cases. Interrogatory No. 110: With regard to expert witnesses identified in your Answer to Interrogatory No. 109, identify by case name, date, court and case number any deposition or testimony given by each such expert and state the custodian and location of transcripts thereof. Response No. 110: Defendant objects to this question on the grounds that it is not related to the subject matter of the instant cases and unduly burdensome. Interrogatory No. Ill: Identify each person who has testified on your behalf at trial or by deposition in a case alleging asbestos-related injury, state the custodian and location of transcripts thereof, and set forth the case name, number, court and date with respect to each proceeding in which the witness testified. Response No. ill; Defendant acknowledges being a named defendant in numerous lawsuits which allege injury resulting from asbestos-containing dust. Defendant does not have the capabilities to produce the requested information without it constituting an undue or impossible burden. Without waiving this objection, please see the attached list, marked as Exhibit "N", of former and current employees who have testified or given a deposition in an asbestos-related case. Interrogatory No. 112: State whether you contend that asbestos products can be manufactured or treated so as to eliminate all potential health hazards to workers who use asbestos products and/or are exposed to asbestos fibers or dust. If so, explain in detail the factual basis for this contention. -81- Response No. 112: Defendant objects to this Interrogatory on the grounds that the phrase "so as to eliminate all potential health hazards" is vague and ambiguous. Also, any answer to this question would be meaningless, inasmuch as a manufacturer is not a guarantor and cannot be held to such a standard of eliminating "all" potential health hazards. Furthermore, the question is without any evidentiary value, because it deals with a possibility rather than a probability. Without waiving any of the aforesaid objections. Defendant states that it believes previously manufactured asbestos products (such as asbestos paper, asbestos roofing felts, asphalt saturated asbestos roofing cement, etc.) did not present any substantial health hazards to workers applying or otherwise using the products in a reasonable fashion. Interrogatory No. 113: State whether you contend that any person or business entity not presently a party to this action is responsible in whole or in part for any of the plaintiffs' damages. If so, identify each such person or business entity and state the facts which form the basis for each such contention. Response No. 113; Defendant does not have sufficient information at this time to respond to this Interrogatory. As discovery is still continuing in this case, Defendant is unable to state the requested information at the present time. However, Defendant intends to assert any and all defenses properly raised in the pleadings. Interrogatory No. 114: State whether you contend that asbestos products are not inherently dangerous. If so, state all facts and documents which form the basis for such a contention. -82- Response No. 114; Objection. This Interrogatory asks for legal conclusions and is tantamount to having the defense do the research for the Plaintiff. Moreover, it improperly attempts to shift the burden of proof to Defendant. Interrogatory No. 115: State whether you contend that you did not have a duty to warn users of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19 of the hazards and risks of use of and exposure thereto. If so, state all facts and identify all documents which form the basis for such a contention Response No. 115: Refer to Response #55 and #73 above. Moreover, Defendant objects to this interrogatory on the grounds that it is indefinite, overbroad and unduly burdensome and improperly attempts to shift the burden of proof to Defendant. Interrogatory No. 116; State whether you contend that you performed adequate tests of the safety of the asbestos products identified in your Answer to Interrogatory Nos. 8 and 19. If so, state all facts and identify all documents which form the basis for such a contention. Response No. 116: Defendant objects generally to plaintiff's Interrogatory insofar as the question assumes facts which render the answer misleading, prejudicial and without any probative value. Without waiving this objection. Defendant refers to Response #32 above. Interrogatory No. 117: State whether you contend that you did not conspire with others to allow asbestos products to be used without adequate warnings, or without any warnings, regarding the hazards or risks of use of and/or exposure thereto. If so, state all facts and identify all documents which form the basis for such a contention Response No. 117: Objection. This Interrogatory asks for legal conclusions and is tantamount to having the defense do the research for the Plaintiff. Moreover, it improperly attempts to shift the burden of proof to Defendant. -83- m Interrogatory No. 118: State whether you contend that there are circumstances under which asbestos products can safely be handled and used. If so, state all facts and identify all documents which form the basis for such a contention. Response No. 118: Defendant is informed and believes that respirators approved by the U.S. Bureau of Mines will prevent the inhalation of dangerous quantities of asbestos dust and fibers. Defendant has relied upon the U.S. Bureau of Mines for the testing and reliability of respirators. Refer also the Responses #15 and #112 above. Interrogatory No. 119: State whether you contend that there is now or has ever been a distinction between one or more of the following with respect to use of and exposure to asbestos products and the health hazards or risks relating thereto: miners, millers, textile workers, asbestos plant workers, insulators, shipyard workers, steel plant workers, building tradesmen, industrial workers, and brake lining mechanics. If so, state all facts and identify all documents which form the basis for such a contention. Response No. 119: Asbestos dust exposure comparisons are highly prejudicial and misleading in a disease process which entirely depends upon the level and duration of an individual's fiber inhalation. For example, predecessors' manufacturing plant employees worked with and around 100% raw asbestos fiber in an enclosed plant environment; whereas insulation applicators experienced relatively casual, intermittent exposure to an insulation product which usually contained between 5% and 15% asbestos. Interrogatory No. 120: State whether you contend that there are differences between asbestos fiber types (chrysotile, amosite, crocidolite, actinolite, anthophyllite or tremolite) with regard to diseases they may be capable of causing. If so, state all facts and identify all documents which form the basis for such a contention. -84 Response No. 120: Defendant objects generally to Plaintiff's Interrogatories insofar as they request Defendant to render a medical opinion. Defendant is not a medical expert and is not qualified to render medical opinions. Interrogatory No. 121: Name any person not heretofore mentioned having personal knowledge of the facts material to this case. Response No. 121: Not applicable to this Defendant. PART II ~ SPECIFIC INTERROGATORIES TO BE ANSWERED SEPARATELY AS TO EACH PLAINTIFF For the following Interrogatories, use the following definitions: "Plaintiff's working years" means the years 19__ thru 19__; "plaintiff's employers" mean the companies listed on the attached Rider A, and "plaintiff's employment locations" mean those worksites listed on the attached Rider A. PRELIMINARY STATEMENT The Celotex Corporation (hereinafter Celotex) is a successor-in-business to various companies and corporations which were engaged in the manufacture and sale of asbestos-containing industrial insulation products. Celotex's involvement in the industrial asbestos insulation business began with its purchase of Panacon Corp. in 1972. Prior to that date, Celotex did not have any interest in the industrial asbestos insulation field. Most of the events which may be relevant to the issues presented in this and related cases, occurred prior to Celotex's purchase of Panacon Corporation. For this reason and the fact that many of the matters inquired about took place several -85- decades ago, information furnished in this response may be incomplete. Nevertheless, Celotex has endeavored to fully investigate all relevant happenings and circumstances and the following responses are based upon its investigation. However, Celotex cannot exclude the possibility that its continued investigation may reveal more complete information. Furthermore, a considerable amount of the information supplied in these responses was obtained from employees of predecessor corporations. Accordingly, Celotex can only relay this information; it cannot attest to the accuracy or truthfulness of such responses. Information of this nature is being supplied because it may lead to the discovery of admissible evidence. To the extent that the information contained herein differs in any respect from any prior response to discovery, these answers shall be deemed to update and supersede such prior answer in any and all cases. Celotex does not concede that any of its responses to these Interrogatories are or will be admissible evidence at a trial of this action and Celotex does not waive any objection, on any ground, whether or not asserted herein, to the use of any such answer at trial. PRELIMINARY OBJECTION Defendant objects to responding separately or specifically as to each Plaintiff, as the referred to "Rider A" is not attached to these Interrogatories. -86- 1. Have you undertaken an investigation of the occurrence(s) alleged in plaintiff's Complaint? If so, state: a. The identity of the person(s) participating in each such investigation; b. Whether you have obtained statements from any witness(es) and, if so, identify: (i) The identity of each such witness; and (ii) The identity of the person in possession of each such statement. RESPONSE (A) Counsel for the Defendant have undertaken an investigation on Defendant's behalf. (B) Defendant is in the process of deposing fact and expert witnesses named by Plaintiff. Plaintiff is aware of these witnesses and is in possession of all deposition transcripts which have been completed. In addition, because counsels' investigation is continuing, this Response may be supplemented as discovery progresses. 2. State whether you contend that you had no reason or duty to warn the plaintiff or the plaintiff's employer of the hazards and risks of use of and exposure to asbestos products. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE Defendant objects to this Interrogatory on the grounds that it calls for a legal conclusion and improperly attempts to shift the burden of proof to Defendant. Moreover, the Interrogatory is further objectionable as it is overbroad. > -87- indefinite as to time and unduly burdensome. Without waiving these objections, refer to Response to Interrogatory No. 115, above. 3. State whether you contend that you gave adequate warnings to users of and to those exposed to your asbestos products, including the plaintiff, of the hazards and risks of use of and exposure thereto. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE Defendant objects to this interrogatory on the grounds that it calls for a legal conclusion or opinion and assumes facts which render the answer misleading, prejudicial, and without any probative value. 4. State whether you contend that you recommend safety procedures regarding the use of and exposure to asbestos products to the plaintiff or the plaintiff's employer. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE Refer to Response Nos. 22 and 71 of Part I, above. 5. State whether you contend that the plaintiff was exposed, if at all, to a safe amount of asbestos or to less than the "threshold limit" of exposure to asbestos dust and fibers from the use of and exposure to asbestos products. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE Defendant contends that Plaintiff was not exposed to its asbestos-containing products. In support of its contention. Defendant will rely upon the Plaintiff's own statements, the statements of his coworkers and his employer and/or its representatives or agents. -88- 6. State whether you contend that the plaintiff's disabilities or injuries are unrelated to the use of and exposure to asbestos products. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE Defendant believes that Plaintiff's disabilities or injuries are unrelated to his alleged exposure to asbestos products. In support of this contention, Defendant will rely upon Plaintiff's own statements of his coworkers and the opinions of Defendant's medical experts. 7. State whether you contend that the plaintiff's injuries are related in whole or in part to cigarette smoking. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE . Defendant contends that Plaintiff's injuries are related to his cigarette smoking. In support of this contention. Defendant will rely upon Plaintiff's own statements, in deposition and in his Answers to Defendant's Interrogatories, the statements of Plaintiff's coworkers, the opinions of Defendant's medical experts and Plaintiff's medical records. 8. State whether you contend that the plaintiff's injuries are due to an act of the plaintiff's employer. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE Defendant contends that Plaintiff's injuries are due to an act of the Plaintiff's employer. In support of this contention. Defendant will rely upon Plaintiff's own statements, -89- the statements of his coworkers, the statement of his employer and/or its representatives or agents and the opinions of Defendant's "state of the art" experts. 9. State whether you contend that the plaintiff did not work with and was not exposed to any asbestos products mined, manufactured, sold and/or distributed by you. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE Refer to Response No. 19(J) of Part I above. 10. State whether you contend that the asbestos products which the plaintiff used and/or was exposed to were not under your exclusive control. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE Defendant does contend that any of its products allegedly used by the Plaintiff were not under its exclusive control when used. At the time of any use, products would have t been under the control of Plaintiff or his employers. In support of this contention, Defendant will rely upon the Plaintiff's own statements, the statements of his coworkers and the statements of his employer and/or its representatives and/or agents. 11. State whether you contend that there were changes made to your asbestos products after they left your control. If so, state all facts and identify all documents which form the basis of such a contention. -90- RESPONSE Defendant contends that changes were made to its asbestos-containing products after they left its control. In support of this contention, Defendant will rely upon Plaintiff's own statements, the statements of his coworkers and the statements of his employer and/or its representatives or agents. 12. State whether you contend that the plaintiff's claim is barred by the applicable statute of limitations. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE Defendant contends that Plaintiff's claim is barred by the applicable statute of limitations. In support of this contention. Defendant will rely upon Plaintiff's own statements, the statements of his coworkers, the statements of his treating physicians and the opinions of Defendant's medical experts. 13. State whether you contend that the plaintiff's claim is barred by the doctrine of assumption of the risk. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE Defendant contends that Plaintiff's claim is barred by the doctrine of assumption of the risk as Plaintiff continued to work with and around asbestos-containing insulation products despite his awareness of potential health hazards involved. Despite his awareness, Plaintiff voluntarily undertook to work with and around asbestos-containing products, failed to use available safety devices and failed to take other necessary precautions. In support of this contention, Defendant will rely -91- upon the Plaintiff's own statements, the statements of his coworkers, the statements of his employer and/or its representatives or agents and the opinions of Defendant's "state of the art" experts. 14. State whether you contend that the plaintiff's claim is barred by his alleged contributory negligence. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE Defendant contends the Plaintiff's claim is barred by his contributory negligence since Plaintiff applied, used or otherwise worked with asbestos-containing products in a negligent fashion, and failed to take special precautions or use safety equipment while handling, applying or working with asbestoscontaining products. In support of this contention, Defendant will rely upon the Plaintiff's own statements, the statements of his coworkers, the statements of his employer and/or its representative 15. State whether you contend that the plaintiff's claim is barred by his alleged misuse of the asbestos products with which he worked. If so, state all facts and identify all documents which form the basis of such a contention. RESPONSE Defendant contends that Plaintiff's claim is barred by his misuse of the asbestos products with which he worked. In support of this contention. Defendant incorporates by reference itjs responses to Interrogatory Nos. 13 and 14, Part II. 16. State whether you contend that the plaintiff's injuries were caused by any intervening acts or superseding negligence. If so, state all facts and identify all documents which form the basis of such a contention. -92- RESPONSE Defendant contends that Plaintiff's alleged injuries were caused by intervening acts or superceding negligence on the part of the Plaintiff himself and third parties. In support of this contention, Defendant will rely upon Plaintiff's own statements, the statements of his coworkers, the statements of his employer and/or its representatives or agents, Plaintiff's medical records and the opinions of Defendant's medical and "state of the art" experts. 17. Did this defendant, by itself or through its distributors, engage in the sale of asbestos products to (or application of asbestos products at) any of the plaintiff's employment locations to or any of the plaintiff's employers during the plaintiff's working years? This Interrogatory is not limited to defendant's review of existing sales records? moreover, you are expressly asked to state what steps you took, and persons or documents you consulted, other than reviewing available sales records, in effort to answer this Interrogatory. RESPONSE Defendant objects to answering this interrogatory on the grounds that the Plaintiff has not specified worksites where, or employers for whom, he contends he worked. Defendant therefore cannot answer. Defendant further objects to stating what steps it might take to answer this interrogatory, if answering was possible, because this information is irrelevant and not calculated to lead to the discovery of admissible evidence, protected by the attorney/client privilege and work- product doctrine, and unduly burdensome. 18. If the answer to one or more parts of Interrogatory No. 2 above is affirmative, please state as to each affirmative answer the following: -93- a. the date on which this defendant began such sales or activity; b. the date on which this defendant ceased such sales or activity; c. the type of product, and quantity sold, on each such date. RESPONSE Defendant objects that this interrogatory is incomprehensible in that neither "Interrogatory No. 2 above" relate to Defendants' sales of asbestos-containing products. 19. State the names and addresses of all individuals who have identified this defendant as a source of asbestos products to any of plaintiff's employment locations or employers in any proceeding (whether by way of answers to interrogatories, court appearance or deposition) to which this defendant was a party. RESPONSE Defendant objects to answering this interrogatory on the grounds that the Plaintiff has not specified worksites where, or employers for whom, he contends he worked. Defendant therefore cannot answer. Defendant further objects to stating what steps it might take to answer this interrogatory, if answering was possible, because this information is irrelevant and not calculated to lead to the discovery of admissible evidence, protected by the attorney/client privilege and workproduct doctrine, and unduly burdensome. Also, refer to Preliminary Objection to Part II. In addition, Defendant does not maintain such data in the ordinary course of business and is unable to respond as requested. -94- The undersigned, D. S. Gibson, is Manager of Safety and Property Conservation of The Celotex Corporation. He has no personal knowledge of the facts set forth herein, since the present Celotex organization did not control the personnel and facilities involved at times relevant to this lawsuit, and further, such facts are the result of the investigation by attorneys on behalf of Celotex, and he affirms these Answers for purposes of taking necessary official action by The Celotex Corporation only. THE CELOTEX CORPORATION D. S. Gibson Manager of Safety & Property Conservation STATE OF FLORIDA ) COUNTY OF HILLSBOROUGH) Before me the undersigned, a Notary Public in and for the County aforesaid, this day appeared D. S. Gibson, who stated he is authorized to execute the foregoing Answers and Objections to Interrogatories on behalf of The Celotex Corporation, and that the matters stated in said Answers are true and correct to the best of his knowledge, information and belief. SUBSCRIBED AND SWORN to before me, this 198 /X_. ^2 sidL day of Notary Public State of Florida County of Hillsborough IWlrvMlllcSWiofFl^11iny My Commission Expires July 9.l989> My Commission expires: exhibit CORPORATE history OF THE PHILIP CAREY MANUFACTURING COMPANY The Philip Carey Manufacturing Ccrrpany was organized in Chio in 1888 and remained an independent ccnpany until 1966, when Glen Alden Corporation (a wholly-owned subsidiary of Rapid-American Corporation) acquired control. In 1967, Glen Alden merged Philip Carey Manufacturing Company into itself, and immediately formed a new wholly-owned subsidiary named Philip Carey Manufacturing Company (new Carey). In 1968, The Philip Carey Manufacturing Company (new Carey) changed its name to Philip Carey Corporation (Chio). Philip Carey Corporation (Chio) acquired the Snith & Kanzler Corporation (Smith & Kanzler), a wholly-owned subsidiary of Dana Corporation, by way of a Stock Agreement dated 2/18/69. Snith & Kanzler became a wholly-owned subsidiary of the Philip Carey Corporation (Chio) and on 2/28/69 changed its name to the Philip Carey Corporation (New Jersey). In April, 1970, Philip Carey Corporation (Chio) was statutorially merged into Briggs Manufacturing Company, a Michigan corporation, and simultaneously, Briggs changed its name to Panacon Corporation. Certain assets of the Philip Carey Corporaton (New Jersey) were sold to Asbestospray Corporation of New Jersey on January 7, 1972. Philip Carey Corporation (New Jersey) was dissolved in 1972. On June 30, 1972, Panacon Corporation was merged into The Celotex Corporation, a Delaware corporation. This merger was also statutory, and The Celotex Corporation assumed the assets and ordinary liabilities of Panacon Corporation. ` EXHIBIT B > ASBESTOS-CONTAINING INSULATION/INDUSTRIAL PROOUCTS MANUFACTURED BY PHILIP CAREY AND/OR ITS SUCCESSORS* Name. Trade Name and Description i Pipe coverings & blOCic Date of Manufacture 5 Asbestos a) 855 Magnesia pbc b) Super Light 855 Magnesia pb c) All temp pb d) Careytemp pb e) Paper Pipe Products: 1906 to 1961 1951 to 1958 1954 to 1958 1958 to 1969('69-asb.removed) 11-155 155 10-125 6-75 Aircel pb Careycel pb Carocel p Defendex p Excel pb Glosscell pb Multi-Ply pb Asbestos Sponge pb Fyrex p f) Other Pipe Coverings Manufactured: 1906 to 1960,1969 to early 70's 60S 1920's to 1960 605 1925 to 1960 60S WWII 605 1925 to 1960 605 1935 to 1960 60S 1930 to 1960 60S 1930 to 1960 605 1969 to early 70's 60+5 Tempcheck pbc 1952 to 1958 Hi-temp #19 pbc 1906 to 1958 HI-temp #12 & #15 pbc 1906 to 1952 Careytemp Alum. Jacketed A Traced Pipe Insul. 1961 to 1968 Careytemp 2000 be 1964 to 02/70 Dual Careytemp p 1964 to 1967 ACCESSORY PRODUCTS TO INSULATION LINE 205 205 205 6-75 6.45 105 a) Cements: 707 Cement Super 606 Cement 100 Cement 303 Cement Careytemp Finishing Cement MW-40 Cement MW-50 Cement LF-20 Asbestos Cement Vitricel Cement (#10 & #19) A-101 Cement 7M-90 Asbestos Shorts Cement Specialty Cements b) 8oards: 1906 to 1960 1906 to 1960 1906 to 1967 1906 to 1967 1966 to 1968 1950 to 1952 1940 to 1967 Unknown to 1967 1940 to 1967 1906 to 1967 1950 to 1977 (Brokered) Unknown to 1960's 435 105 505 555 225 105 105 60-705 15-255 1005 1005 Various 5 Thermo-bord 4.2 Careystone Sheets Industrial A-C Boards Cemesto Board Careyflex Board Marine Panel Panel Board Careystone Sheathing 1 Baffles c) Miscellaneous Accessories: 1925 to 1969 1925 to 1970 1925 to 1970 1930's-early 1960's 1925 to 1969 1941 to 1950 1941 to 1950 1925 to 1969 205 225 225 Unknown 255 605 605 225 Fireguard Fired ad Jacketing 45-pound Asbestos Waterproof Jacket Asbestos Rope & Wick MISCELLANEOUS PROOUCTS I960 to 1976 1965 to 1982 1906 to 1982 1925 to 1945 855 655 855 855 Asbestos Papers k Roll Boards 1906 to 02/82 60-855 Millboards Asbesto-Sorb 1906 to 02/82 1944 to 1950rs 65-975 Unknown Spraycraft 1969 to 1971 355 Asbestos Felts 1960 to 1984 855 Asbestos Tank Jackets Careyduct 1906 to 1945 1940 to 1955 605 60-855 Thermal Ite 1906 to 1937 855 Flrefoll Board & Panel 1940 to 1960 605 Vitricel Asbestos Sheets 1941 to 1960 60-705 MATERIALS WHERE ASBESTOS IS FULLY ENCAPSULATED Thermotex-B 228 Fibrated Emulsion 1906 to 1984 1906 to unknown 145 3.65 Insulation Seal 1930 to 1984 205 Fire Resistant Insul Seal Fibrous Adhesive BTU Cement Unknown 1906 to 1984 1930 to 1965 205 155 25-305 Carey Asphalt Floor Tiles 1930's to 1975 405 Careytemp Adhesive 1961 to 1968 155 Careyduct Adhesive 1940 to 1955 155 * All product names are listed, even If quantities sold were small, p * pipe covering b block c cement EXHIBIT C MINNESOTA Minneapolis - 1927, 31, 39, 40, 41, 42, 43, 45, 46 MISSOURI St. Louis - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47, 52, 54, 55, 56, 58, 59, 61, 62, 63, 65, 67, 68, 69, 70, 71 Kansas - 1927, 31, 39, 40, 41, 42, 43, 45, 46 NEBRASKA Omaha - 1927, 31 NEW JERSEY Edison - 1963, 69, 70 Edgewater - Celotex 1972 Perth Amboy - 1953, 59, 61, 63, 65, 67, 68, 69, 70, 71 Saddle Brook - Panacon 1971 NEW YORK Albany - 1931 Buffalo - 1927, 31, 39, 40, 41, 42, 43, 45, 46 New York (Foreign Div.) - 1931 - 1931, 39, 40, 41, 42, 43, 45, 46, 47, 52, 54,'55, 56, 57, 58, 59, ' 62, 63, 65, 67, 68, 69, 70, 71 NORTH CAROLINA Charlotte - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47, 55, 56, 57 Greensboro - 1945, 46 Goldsboro - Celotex 1972 Raleigh - 1945, 46 OHIO Akron - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47 Canton - 1927, 31, 39, 40, 41, 42, 43, 45, 46 Cincinnati - 1931, 30, 40, 41, 42, 43, 45, 46, 47, 52, 54, 55, 56, 57, 58, 59, 61, 62, 63, 65, 67, 68, 69, 70, 71, 72 Cleveland - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47, 52, 54, 55, 56, 57, 58, 59, 61, 62, 63, 65, 67, 68, 69, 70, 71 Columbus - 1927, 31, 39, 40, 41, 42, 43, 45, 46Dayton - 1927, 31, 39, 40, 41, 42, 43, 45, 46 Elyria - 1945, 46 Lima - 1945, 46 Mansfield - 1945, 46 Sandusky - 1945, 46 Toledo - 1927, 31 Youngstown - 1931, 39, 40, 41, 42, 43, 45, 46, 47, 52 PENNSYLVANIA Altoona - 1945, 46 Erie - 1927, 31, 39, 40, 41, 42, 43, 45, 46 Philadelphia - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47,51, 52, 58, 59, 62, 63, 65, 67, 68, 69, 70, 72 Pittsburgh - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47, 52, 56, ST, 55, 56, 58, 59, 57, 62 * Piii Tip Carey Pi s `b'j ti on and Sales Offices . i .Page 3 RHODE ISLAND Providence - 1963, 65, 67, 68, 69, 70 SOUTH CAROLINA Greenville - 1945, 46 TENNESSEE Chattanooga - 1939, 40, 41 Knoxville - 1931, 39, 40, 41, 42, 43, 45, 46 Memphis - 1957, 58, 59, 61, 63, 65, 67, 63, 69, 70, 71 UTAH Salt Lake City - 1931 TEXAS Dallas - 1539, 40, 41, 42, 43, 45, 46', 52 (Oil Industry Div. - 1931) (Celotex - 1972) Houston - 1955, 56, 57, 58, 59, 61, 63, 65, 67, 68, 69, 70, 71 VIRGINIA (See also District of Columbia) Norfolk - 1939, 40; 45, 46, 47 Richmond - 1927, 31, 40, 41, 42, 43 WASHINGTON Seattle - 1939, 40, 41, 42, 43, 45, 46, 47, 52, 54, 55, 56, 57, 58, 59, 61, |) 62, 63, 65, 67 WEST VIRGINIA Wheeling - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47 WISCONSIN Milwaukee - 1945, 46 > EXHIBIT D OTHER DISTRIBUTORS & SALES OFFICES HANDLING PHILIP CAREY PRODUCTS ALABAMA Birmingham - The Young & Vann Supply Co. - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47, 50 & 52 Mobil - Turner Supply Co. - 1950, 52 Gulf States Insul. Co. - 1950, 52 ARIZONA Fort Smith-- Dyke Brothers - 1927, 31 Phoenix - Southwestern Mfg. & Supply - 1931 A. N. Borquist - 1939, 40, 41, 42, 43, 50, 52 ARKANSAS Little Rock - Fischer Cement & Roofing - 1927, 31, 42, 43, 45, 46 United Insulating Co. - 1946, 47, 50, 52 CALIFORNIA Los Angeles - Warren & Bailey Co. - 1927, 41, 42, 43, 45, 46, 47, 50 Oakland - Silicair Insulation - 1950, 52 Sacramento - Allyn L. Burr Co. - 1931 San Francisco - Jones Brothers Asbestos Supply Co. - 1927, 31 Warren & Bailey Co. - 1939, 40 Van Arsdale-Harris Co. - 1940, 41, 42, 43, 45, 46, 47 Charles Ayres Co. - 1950, 52 (COLORADO Denver - Standard Military Mfg. Co. - 1927, 31 Rocky Mountain Supply Co. - 1946, 47, 50, 52 CONNECTICUT Bridgeport - Asbestos Distributors Inc. - 1939, 40, 41, 42, 43, 45, 46, 47, 50, 52 Hartford - The Insulation Co. - 1950 DELAWARE Wilmington - Delaware Insulating Co. - 1950, 52 DISTRICT OF COLUMBIA (Area) Washington, DC ) Alexandria, VA ) - Asbestos Covering & Roofing Co. - 1927, 31, 39, 40, 41, 42, 43 Beltsville, MD ) FLORIDA Jacksonville - The Cameron & Barkley Co. - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47, 50, 52 Miami - The Cameron & Barkley Co. - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47, 50, 52 Tampa - The Cameron & Barkley Co. - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47, 50, 52 Asbestos Insulating Co. - 1950, 52 GEORGIA Atlanta - Asbestos Insulation Co. - 1952 Oth?'r Qistril uto-~s & les Offices ^ch? ling Pm i m- Carc< . <'cruets Page 2 ILLINOIS Chicago - Asbestos, Asphault & Insulation Mfg. Co. - 1939, 40, 41 Paul J. Krez - 19^6, 47, 50, 52 Luse-Stevenscn Co. Inc. - 1945, 46 Illinois Roofing & Insulation Co. - 1945, 46, 47, 50, 52 Peoria - Sprinkman Sens Corp. - 1945, 47, 50, 52 INDIANA Evansville - General Insulation Co. - 1950, 5*2 Fort Wayne - Asbestos Insul. & Roofing Co. - 1942, 43, 45, 46, 47, 50, 52 South Band - The General Roofing & Insulation Co. Inc. - 1950, 52 IOWA ' Davenport - Economy Roofing & Supply - 1945, 46, 47, 50, 52 DesMoines - Madden Insulation Co. - 1950, 52 Sioux City - Kelly Asbestos Products - 1952 Waterloo - J. A. Neymeyer - 1950, 52 KANSAS Wichita - Kelly Asbestos Products - 1952 KENTUCKY Louisville - Walter L. Lacy Co. - 1927, 31 Louiville Builders Supply - 1945, 47, 50 ) Wholesale Service - 1952 LOUISIANA New Orleans - J. J. Clark Co. Ltd. - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47, . 50, 52 Reilly Denton Co. - 1945, 46, 47 Orleans Insulation & Sales Co. - 1950, 52 Shreveport - R. F. Zimmerman & Co. - 1942, 43 MARYLAND (See also District of Columbia) Baltimore - McCormick Asbestos Co. - 1939, 40, 41, 43, 45, 46, 47, 50, 52 MASSACHUSETTS Boston/Cambridge - Curtis Asbestos Co. - 1950 MICHIGAN Grand Rapids - Alexander Stafford Corp. - 1945, 45, 47, 50, 52 Jackson - Jackson Insulation Co. - 1942, 43, 45, 46, 47, 50, 52 Lansing - Engineer Service Co. - 1942, 43 Garlock-Ennis Co. - 1945, 46, 47, 50 Garlock Insulation - 1952 MINNESOTA Duluth - A. W. Kuettcl Co. - 1942, 43, 45, 46, 47 ^ Christofferson - 1950, 52 J Minneapolis - W. S. Nott Co. - 1927, 31, 39, 40, 41 Asbestos Insulation & Supply Co. - 1946, 47, 50, 52 Cthe-* Distributors S^lns Offices jr- > , -7 rhiliu >.'~rL-y i ~~0'*;jC'S f a r> a `MISSISSIPPI Jackson - Stokes Engineering Inc. - 1950, 52 KISSQ'JRI Kansas City - Kelly Asbestos Products - 1939, 40, 41, 42, 43, 45, 46, 47, 50, 52 NEBRASKA Omaha - Holland Lumber Co. - 1931, 39, 40, 41 Kelly Asbestos Products - 1952 NEW JERSEY Collingswcod - Geo. L. Moffett - 1952, NEX MEXICO Albuquerque - Sorenson Brick & Material - 1927, 31 NEW YORK Buffalo - Frontier Insulation & Roofing - 1950, 52 Industrial Roofing & Asbestos - 1946, 47 Jamestown - Laco Asbestos & Roofing Co. - 1946, 47, 50, 52 New York - Amour Products Inc. (Exports) - 1941, 42, 43, 45, 46 Robert A. Keasbv Co. (Insul. Dept.) - 1927, 31, 39, 40, 41, 42, 43, A 45, 46, 47, 50, 52 ) Port Chester - Asbestos Distributors Inc. - 1939, 40, 41, 42, 43, 45,46, 47, 50, 52 Rochester - Elmer W. Davis Inc. - 1942, 43, 45, 46, 47, 50, 52 NORTH CAROLINA Charlotte - Guy M. Beatty Insulation - 1931 Southeastern Magnesia & Asbestos Co. - 1939, 40, 41 Greensboro - Starr Davis - 1950, 52 OHIO Akron - Asbestos Supply Co. - 1950, 52 Cincinnati - R. E. Krainig & Co. - 1927, 31, 39, 40, 42, 43, 45, 46, 47, 50, 52 Columbus - Earl E. Bright - 1942, 43, 45, 46, 47,'50, 52 Dayton - Crawford Insulation - 1950, 52 Toledo - George L. Freeman Co. - 1939, 40, 41, 42, 43, 45, 46, 47, 50, 52 Youngstown - Stanley P. Davis Co. - 1950, 52 OKLAHOMA Oklahoma City - Kelly Asbestos Products - 1952 Tulsa - Kelly Asbestos Products - 1939, 40, 41, 42, 43, 45, 46, 47, 52 OREGON Portland - Pacific Bldg. Materials - 1931 Pacific Asbestos & Supply - 1939, 40, 41, 42, 43, 45, 46, 47, 50, 52 Pennsylvania Jamestown - Quaker Sales Corp. - 1946, 47, 50, 52 Norristown - Asbestos Insulating Co. - 1942, 43, 45, 46, 47, 50, 52 TENNESSEE Chattanooga - Hojocoa Corp. - 1946, 47, 50, 52 cvj James Supply Co. - 1927, 31, 39, 40, 41, Reilev Insulation - 11 O. K^OW ) 52 43, 45, 46 Knoxvi He - A. G. Heins Co. - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47, 50, 52 Nashville - T. L. Helbert & Sons - 1927 , 31 , 39, 40, 41 , 42 , 43, 45, <16, 47, KO 52 Memphis - Fischer Lime & Cement - + U l ) '31, 39, 40, 41, 42, 43, 45, 46, 47, Goncen Roofing & Insulation - 1950, 52 UTAH Salt Lake City - The Galiher Co. - 1927, 31 TEXAS Dallas - Rogers Asbestos Co. - 1927, 31 El Paso - Mcmsen-Dunnegan-Ryan Co. - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47, 50, 52 Fort Worth - E. 0. Wood & Co. - 1942, 43, 45, 46, 47, 50, 52 Houston - B. & B. Engineering - 1946, 47, 50, 52 Rogers Asbestos Co. Inc. - 1927, 31 Warren W. Bates - 1942, 43, 45, 46 VIRGINIA (See also District of Columbia) ' Grundy - Buckhannon-Williamson Supply Co. - 1950, 52 Norfolk - C. E. Thurston & Sons Inc. - 1950 Richmond - Virginia Insulation Co. Inc. - 1942, 43, 45, 46, 47, 50, 52 WASHINGTON Seattle - Pioneer Sand & Gravel Co. Inc. - 1931, 39, 40, 41, 42, 43, 45, 46, 47, 50, 52 Charles R. Brower Co. - 1946, 47, 50 Spokane - Nott Atwater Co. - 1931, 39, 40, 41, 42, 43, 45, 46, 47, 50, 52 Tocoma - George Scofield - 1931, 42, 43, 45, 46, 47, 50, 52 Tocoma Asbestos Co. - 1946, 47, 50, 52 WEST VIRGINIA Charleston - Capital City Supply Co.- 1945, 46, 47, 50, 52 Huntington - Banks Miller Supply - 1927, 31, 39, 40, 41, 42, 43, 45, 46, 47, 50, 52 Williamson - Williamson Supply Co. - 1950, 52 WISCONSIN Appleton - Bartelt Asbestos & Cork Co. - 1945, 46, 47, 50, 52 Green Bay - Bay Asbestos Co. - 1952 Madison - Johnson Insulation Co. - 1950, 52 Milwaukee - Industrial Roofing & Insul. - 1950, 52 Racine - Badger Roofing S Siding - 1945, 46, 47, 50, 52 I Wausau - Asbestos Supply Inc. - 1950, 52 EXHIBIT E INDUSTRIAL INSULATIONS DISTRIBUTOR/CONTRACTOR MAILING LIST______ A. C. & S. 501 Amsterdam, N. E. Atlanta, GA 30306 Attn: W, K. Jones A C & S. 2919 3rd Avenue N. Birmingham, AL 35202 A. C 6c S. 11 Keeler Ave. Chicopee, MA 01020 A. C. & S. 25 East 76th Street Cincinnati, OH 45216 Attn: R. R. McElhaney A . C 6c S . 7700 Wall Street Valley View Cleveland, OH 44125 A, C. 6c S, 9620 Gerwig Lane Guilford Industrial Center Columbia, MD 21046 A* C. 6c S. 1515 Delashmut Ave. Columbus, OH 43212 Attn: R. D. Collier A. C, 6c S 9140 Premier Row Dallas, IX 75247 A. C. 6c S. 898 Providence Highway Dedham, MA 02026 Attn: Warren A. Magglo A, C. 6t S. 4801 E. 39th Ave. Denver, CO 80207 Attn: G. H. Stewart A. C. 6c S. 466 E. Manlius St. E. Syracuse, NY 13057 Attn: L. E. Willits A. C. 6c S. P. 0. Box 4316 Harrisburg, PA 17111 A. C. 6c S. 749 S. Grant Ave. Indianapolis, IN 46203 Attn: W. L. Roberts A. C. 6c S 569 Nixon Street Jacksonville, FL 32203 Attn: E. P. Avery A. C. 6c S. 1809 Liberty Kansas City, IK) 64102 Attn: D. T. Norton A. C. 6c S. 180 Church Street, P. 0. Box "T" King of Prussia, PA 19406 Attn: D. F. Andrew T. E. Decker A. C. 6c S. 1301 Laura Lane Lake Bluff, IL 60044 Attn: J. L. Griggs A. C. 6c S. 120 N. Lime St. Lancaster, PA 17604 Attn: George C. Follmer Doris Harlem H. W. March A. C. 6c S. 15 East 21st Street Linden, NJ 07036 Attn: J. Acello A. C. 6c S. 2316 Watterson Trail Louisville, KY 40299 Attn: C. L. Wright A. C. 6c S. P. 0. Box 25379 Menomonee Falls, WI Attn: E. F. Keane 53225 A. C. & S. 611 Cowan Street Nashville, TN 37207 A C & S. 468 Park Avenue, South Rms. 1704-5 New York, NY 10016 Attn: S. Andersen I. H. Greiff A. C. & S. 21251 Meyers Road Oak Park, MI 48237 Attn: J. Blair A, C. & S 4229 Lafayette Omaha, NB 68131 Attn: Bill Gilmore (2) A. C & S 922 West Detweiller Drive Peoria, IL 61614 Attn: T. J. Scherer A C . & S 4485 Campbell's Run Road Parkway West Pittsburgh, PA 15205 Attn: J. A. Ockerman A. C. & S 9601 Balmoral Avenue Rosemont, IL 60018 Attn: L. B. McNabb A C & S 6 Enterprise Dr. Savannah, GA 31402 Attn: E. J. Valence A. C. & S. 6800 Odell St. St. Louis, MO 63139 Attn: J. S. Taylor 2- A. C. A S. 5225 W. 75th St. Shawnee Mission, KS Attn: C. W. Fowler 66208 A. C. & S. 352 Morris Street Toledo, OH 43602 Attn: R. J, Sine A. C. & S. 223 E. Archer St. Tulsa, OK 74103 Attn: B. W. Page A. C. & S. Quaker Lane Industrial Park 99 Telmore Road Warwick, RI 02818 Attn: R. G. Stephenson A. C. & S. 980 Silasdeane Highway Wethersfield, CT 06109 Attn: R. H. Lee A. C. & S. 721 Jordan Parkway White Hall, PA 18052 Attn: F. L. Blanchard A. C. & S. . 3315 Capitol Trail Wilmington, DE 19808 Attn: J. A. Lore Hi A. D. C. Contractor & Supply Corp. 209 Center Street Bridgeport, CT 06604 Attn: Jim Noll A & K Midwest Insulation Company Highway 45 East Metropolis, IL 62960 Attn: Jim Alexander A & M Insulation Company 2614 Clybourn Avenue Chicago, IL 60614 Attn: Phil Schneider Jim Gibbons A & M Insulation Company 1818 W. Chunute Rd. Peoria, IL 61600 Attn: Dick Stevenson A. P. I., Inc. 2366 Rose Place St. Paul, MN 55113 Attn: Lee R. Anderson Paul W. Abbot Company 708 Vandalia St. Paul, MN 55114 The Aber Company, Inc. P. 0. Box 2683 Houston, TX 77001 Attn: D. G. Adair Alexander Stafford Company 32 Grandville Avenue Grand Rapids, MI 49502 Alfol, Inc. 9839 York Road Charlotte, NC 28210 Attn: Steve Watson Allied Insulation Supply 315 N. 12th Street Milwaukee, WI 53233 Attn: Jack Flack Allied Rubber & Gasket Co. P. 0. Box 518 Waverly, TN 37185 Attn: J. L. McCraskey Allied Service, Inc. P. 0. Box 9132 Charleston, WVA 25309 All Temp Insulation, Inc. 1501 North C Street Sacramento, CA Attn: Ed Seifiert American Asbestos Company 600 Alabama St. San Francisco, CA 94110 Attn: Ray Colman American Industrial Contractors 263 E. Beaver Sewickley, PA 15145 Anco Insulations P. O. Box 66596 Baton Rouge, LA 70806 Attn: T. L. Virgets (6) Anco Insulation 100 Distribution Drive Birmingham, AL 35209 -3- Anco Insulations, Inc. 7762 Braniff St. Houston, TX 77061 Attn: Don Gideon Anco Insulations 102 North 20th Street Tampa, FL 33605 Attn: Ed Swindel Ed H. Anderson Company P. 0. Box 2759 St. Paul, MN 55112 Attn: Ed Anderson Jay L. Angel 701 N. Wheeling St. Toledo, OH 43605 Apex Insulation Company 432 Margaret St. Box 40066 Jacksonville, FL 32203 Applied Mechanical Insulation, Inc. P. 0. Box 5362 Lenexa, Kansas 66215 Attn: David Hall Arkansas Ind. Insulator 209 S. Redmon Road Jacksonville, AR 72076 Arnold Insulation, Inc. 505 Harvester Ct. Wheeling, IL 60090 Asbestos Insulating Co., Inc. 311 W. Marshall St. Norristown, PA 19401 Attn: W. McClure Aabestos Insulation and Rfg. Co. 312 South Harrison Avenue Fort Wayne, IN 46801 Asbestos Insulation & Supply Co. 1132% Stinson Blvd., N. E. Minneapolis, MN 55413 Attn: John Carlson Atlantic Gasket Corp. 3908-18 Frankford Avenue Philadelphia, PA 19124 Atlas Insulations, Inc. 530 Bell Avenue Carnegie, PA 15106 ******************* -4- B & B Contracting & Supply Company 4831 Lakawana Dallas, TX 75247 B & B Insulations P. 0. Box 2531 Houston, TX 77001 Attn: John Pyle B & W Construction Company Copley, OH 44321 Attn: Purchasing Department B & W Company 4282 Strausser Street, N. W. North Canton, OH 44730 Attn: J. F, Baumgartner Jack Barsh Insul. Company 1935 E. Beaver Jacksonville, FL 32201 Attn: Jack Barsh Bartell Insulation Supply, Inc. 1330 Ballard Road Appleton, WI 54911 Attn: Larry Fondow E. J. Bartells Company 700 Powell Avenue SW Renton, WA 98055 Attn: Dave Pollard Battey Machine Company P. 0. Box 33 Rome, GA 30161 Bay Insulations Company P. 0. Box 532 Green Bay, WI 54305 Attn: Arnold W. Schmidt Guy M. Beaty Company 520 S. Elliot Street Charlotte, NC 28201 Attn: Mr. Roy Beaty Guy M. Beaty Company 1105 Carter St. Chattanooga, TN 37401 Attn: Melvin Cooper Guy M. Beaty Company Box 3598 Greenville, SC 29608 Attn: Dick Crowe Blgham Insulation & Sply Co. P. 0. Box 22146 Ft. Lauderdale, FL 33315 Attn: Dan Bigham Bodwell-Lemmon Company 10701 Broadway Cleveland, OH 44125 Attn: Steve Powell (3) Boss Insulation Company Pringle Street N. Charleston, SC 29410 Attn: Mike Malone Brand Insulations 40 Patton Road E. Providence, RI Attn: Ray Krupa 02916 Brand Insulations Company 216 Powhattan Avenue Essington, PA 19029 Attn: T. G. Stewart Brand Insulations 1420 Renaissance Drive Park Ridge, IL 60068 Attn: H. N. Ferreira Branton Insulations, Inc. P. 0. Box 5513 Fulton Road Station Mobile, AL 36605 Attn: Howard Sheppard Branton Insulation Company P. 0. Box 10536 New Orleans, LA 70181 Attn: Steve Miller Breeding Insulation P. O. Box 5207 Chattanooga, TN 37406 Breeding Insulation Co* Box 1005 Little Rock, AR 72203 Attn: Curtis Breeding Breeding Insulation Company 800 Ewing Avenue Nashville, TN 35202 Attn: Jim McClure -3- Brennan Insulation 2541 Mitchell Avenue Knoxville, TN 38917 Attn: Dave Gardner Earl E, Bright, Inc. 970 Higgs Avenue Columbus, OH 43205 Attn: J. R. Hunsinger The Brower Company 818 S. Dakota Street Seattle, WA Attn: Ben Kingsman Brown Insulation Company 16200 Hubbell Detroit, MI 48235 Brown Refactory Company 3545 W. Morris Street Indianapolis, IN 46241 Building Services Ind. Sales 620 N. 108th Place Milwaukee, WI 53226 Attn: George Leisenring A1 Simmonsen Building Sprinkler Company P. 0. Box 2864 Fargo, ND 58102 Attn: W. C. Sornsin Burnett Process Inc. Court Street Road Syracuse, NY 13206 **************** Calon Insulation Corp. 1130 Convery Blvd. Perth Amboy, NJ 08861 Attn: C. Hnatt Carolco 8509 May St. Tampa, FL 33614 Attn: Sammy Ward Cajnrdle~Hyatt Inc. P. 0. Box 127 Hopewell, VA 23860 Attn: 0. E, Hyatt Cardinal Industrial Insul. Co. 123 S. Eighth St. Louisville, KY 40202 Cid Carpenter Marine Corp. 528 North Marine Wilmington, CA 90744 Attn: Cid Carpenter Central Insulation 2020 Wyandotte St. Kansas City, MO 64108 Attn: Jack Mclnnes (2) Champaign A & K Insulations P. 0. Box 522 Champaign, IL 61820 Chicago Asbestos Mfg. Co. 510 N, Dearborn Street - Rm 526 Chicago, IL 60610 Attn: Jay Golinkin Chicago Pipe and Boiler Covering 800 Setoh Court Wheeling, IL 60090 Attn: William Briggs Clark Asbestos Company 1893 East 55th St. Cleveland, OH 44103 Claxton Asbestos Company 31 Colt Street Buffalo, NY 14296 Cleland Company 1415 Park Avenue Lynchburg, VA 24501 Attn: Mr. Cleland Colombia Asbestos Inc. 723 N. Tillamook St. Portland, OR 97227 Attn: Charles Stilson Commercial Insul. Sply. Co. 8517 Directors Row Dallas, TX 75247 Complete Insulation Service 90 Vermont St. Dayton, OH 45404 -6- Consolidated Western Contr. Inc. 14935 East Clarke Avenue City of Industry, CA 91744 Attn: Dick Austin (2) Covil Insulation 721 Roosevelt Avenue Albany, GA 31701 Attn: Don Moore Covil Insulations Company One Ninth St. Augusta, GA 30902 Covil Insulation Company Box 6174 Greensboro, NC 27405 Attn: Gerald Greeson Covil Insulation Company P. 0. Box 1804 Greenville, SC 29602 Attn: Sonny Garren Covil Insulation P. 0. Box 265 Wilson, NC 27893 Attn: A. C. Hardison Cox Insulation Service 2867 Stanton Avenue Cincinnati, OH 45206 Crossroads Sales, Inc. P. 0. Box 26 Western Springs, IL 60558 Attn: William Smurdon Cummings Insulation Co. 198 State Street Meriden, CT 06450 Attn: Joe Pasquale **************** Daniel International P. 0. Box 161 Gonzalez, FL 32560 Attn: C. A. Adams J. R. Deans Company 25 Ann Street Charleston, SC 29403 Attn: James Rock Decker Assoc. Inc. P. 0. Box 206 Orefield, PA 18069 Delaware Insulation Company 5th Avenue & Coleman St. Wilmington, DE 19805 Attn: G. Stagliano' Dill Insulation Prod. Company 1002 Murphy Avenue Joplin, MO 64801 Attn: G. Dill **************** E & S Insulation Company 7100 Medicine Lake Road Minneapolis, MN 55427 Attn: Larry Sawatzke Eagle Asbestos and Packaging P. 0. Box 51568 New Orleans, IA 70118 Attn: Bill Yetta Eagle Company, Inc. P. 0. Box 81045 Lincoln, NB 68501 Attn: F. Blatt Eastern Industrial Insulation Company 101-119 Pear Street Reading, PA 19602 Attn: Donald Duffy Eastern Refractories Co., Inc. 20 Flanders Road Belmont, MA 02178 Attn: William Bragdon Econotherm Insulation Company P. 0. Box 18247 Houston, TX 77023 Attn: Wayne McClelland Ellington Insulation Company 2010 N. Kerr Avenue Wilmington, NC 28401 Attn: Hoss Ellington Empire Ace Insulation Mfg. 1 Cozine Ave. Brooklyn, NY 11207 **************** -/- Gabler Insulation 1330 Tihoupitoulas Street New Orleans, LA Attn: Chas Gabler Gastonia Pipe, Boiler & Duct Insulation, Inc. 320 E. Davidson Avenue Gastonia, NC 28052 Attn: Bill Dye General Insulation Company 22 Cross Street East Somerville, MA 02145 Attn: Ed Urquhart General Insulation, Inc. 129 McKinley Street East Peoria, IL 61611 Attn: Virgil Fawer General Pipe Covering, Inc. 6801 W. Lake Street St. Louis Park, Minnesota 55426 Attn: Sheldon Dingley Goodwin Insulation 1083 E. Main St. Toraington, CT 06790 J. Graves Insulation Company P. 0. Box 8830 Shreveport, LA 71108 Great Barrier Insulation Co. Route 2 Decatur, AL 35601 Attn: Paul Kennard Great Barrier Insulation Company 212 E. Garden Street Pensacola, FL 32585 Attn: Jim Busby (10) **************** Hajoca Corporation P. 0. Box 351 Chattanooga, TN 37403 J. F. Harrison, Inc. 5050 North Port Washington Road Milwaukee, WI 53217 Attn: J. F. Harrison R. P. Hedley & Company 153 W. Main Street Redonia, NY 14063 Attn: R. P. Hedley Hefco, Inc. Box 1747 Greenville, SC 29602 Attn: Dave Heafner A. G. Heins 127 Heins Street Knoxville, TN 37901 Attn: Ruth Love Heller Enterprises, Inc. 4310 N. 3rd Street Philadelphia, PA 19140 Attn: F. Heller Hickory Insulation 1750 Thomas Avenue St. Paul, MN 55104 Attn: Charles Wiley Hinman Corporation 24 Cross Street E. Sommerville, MA Attn: Bill Hinman 92144 Hippier Insulation Services Box 1141 St. Cloud, MN 56301 Attn: Ray Hippier Holt Insulations, Inc. 38th & Nona Street N. Little Rock, AR 72118 Attn: Bill Holt, (2) Hullinghorst Industries, Inc. Rt 5, Leisure Road Baton Rouge, LA 70817 Attn: J. E. Duvie **************** Illinois Indiana Insulations P. 0. Box 2127 Hammond, IN 46320 Attn: Don Schrader Illinois Insulation & Const. Co. 3636 South Iron Street Chicago, IL 60609 Attn: Howard Johnson Bob Goodhardt 8- Industrial Assoc., Inc. 1510 Adams Street East P. 0. Box 3996, Station F Jacksonville, FL 32206 Attn: R. A. Andrea Industrial Insulations 2101 Kenmore Buffalo, NY 14207 Attn: Ed Kemerer Industrial Insulations, Co., Inc 146 Cumberland Memphis, TN 38105 Attn: Mr. Curley (2) Industrial Insulations, Inc. Germania & Main Streets Bay City, MI 48706 Attn: Jim Graham Industrial Insulation Corp. 1314 W. College Avenue Appleton, WI 54911 Attn: William Bero, Jr. ) Industrial Insulations, Inc. 3142 Bellaire Kansas City, M0 64129 Insul, Inc. 169 James Avenue North Minneapolis, MN 55405 Attn: Nels Gronqulst Insulating & Materials 1042 Central Industrial Drive St. Louis, MO 63110 Attn: Elmer Mittler (3) Insulating Contracting, Inc. Conception Street Mobile, AL 36601 Attn: Roy Coffer, Jr. Insulation & A/C Supply 5332 W. Crenshaw Box 15581 Tampa, FL 33814 Insulation Distributors 356 Hertel Avenue Buffalo, NY 14240 Insulation Sales Company 3001 Grand Avenue Neville Island, PA 15225 Attn: Bill Hager Insulation Sales Service P. 0. Box 3474 Baton Rouge, LA 70821 Attn: Angelo Reno Insulation Sales, Inc. 16200 Hubbell Detroit, MI 48235 Insulation Services P. O. Box 7726 Tulsa, OK 73105 (12) Insulation Specialties 3113 Hillsborough Road Durham, NC 27705 Insulco P. 0. Box 375 Lima, OH 45801 Insulco Supply & Mfg. Co. 519 East Marine View Avenue Belmont, CA 94002 Attn: John Voorhees Insulcon, Inc. 4333 Merriam Drive Overland Park, Kansas Attn: Elton Burner 66203 Iowa Asbestos 112 S. W. 2 Des Moines, IA 50309 Attn: B. Townsend (2) Iowa Illinois Thermal Insulation 1304 West 4th Street Davenport, IA 52804 Attn: Jim Groves Iowa Illinois Thermal Insulation P. 0. Box 442 Waterloo, IA 50704 Attn: Russ Martin **************** J. W. R. Sales Company P. 0. Box 3375 Charleston, SC 29407 -9- Janos Industrial Insulation Co. 80 Commercial Avenue Moonachie, NJ 07084 Attn: T. J. Connolly Johns-Manville Sales Corporation P. 0. Box 5730 Jacksonville, FL 32207 Attn: Ben Bryan Johns-Manville Sales Corporation P. 0. Box 565 Madison Heights, MI 48071 (2) Johns-Manville Sales Corp. 11525 Rock Island Court Maryland Heights, Missouri Attn: J. A. Grimmer 63043 Johns-Manville Sales 1222 Quebec North Kansas City, MO Attn: C. Martin (2) 64116 Johns-Manville Sales Corp. P. 0. Box 16989 Temple Terrace, FL 33687 Attn: Bob Zeigler **************** K - T Insulation, Inc. 1001 East MacArthur Street - #66 Wichita, Kansas 67216 Attn: Rock Kilgore Kankakee Insulations P. 0. Box 1748 Kankakee, IL 60901 Attn: Mike Coleman Kansas Insulation, Inc. 504 East Douglas Wichita, KS 67202 (2) Robert A. Keasbey Company 139-149 W. 19th Street New York, NY 10011 Robert A. Keasbey Company Commercial Building Syracuse, NY 13211 Attn: Bert Kime Korner Rfg. & Sheet Metal Co. 7860 E. Pleasant Valley Road Independence, OH 44131 R. E. Kramig Company 323 South Wayne Avenue Cincinnati, OH 45215 Attn: R. E. Kramig. R. Staubitz Paul J. Krez Company Westmoreland Building Old Orchard Road Skokie, IL 60076 Attn: Phil Albracht Paul Helmer **************** LK Material Services 4433 E. Park Drive Bay City, MI 48706 Attn: Paul Lurer L & L Insulation & Supply Co. 107 3rd Street Des Moines, IA 50309 Attn: L; L. Thompson L & S Insulation Company 616 S. 89th Street Milwaukee, WI 53214 Attn: Elmer Borchardt Lance Construction Supplies 4225 West Ogden Avenue Chicago, IL 60623 Attn: J. Lance Land Coast Insulation Company P. O. Box 52823 Lafayette, LA 70501 Attn: Ed Morton Louisville Insulation & Sply. 4601 Indian Trail Louisville, KY 40213 Ludeman Insulation 203 N. Handley Box 888 Wichita, KS 67201 Attn: J. Pfister (4) Luse Stevenson Company 4934 West Fifth Avenue Gary, Indiana 46406 Attn: Gary Geovanelll Luse Stevenson Company 2050 North 15th Avenue Melrose Park, IL 60160 10 **************** MBM, Inc. 231 North Weber Avenue Sioux Falls, South Dakota Attn: Ed Scott 57102 H & L Industrial Insulation, Inc. Highway 2 and 52 East Minot, North Dakota 58701 Attn: Darrel Larson MacArthur Company 3201 Brighton Blvd. Denver, CO 82016 Attn: Bob Stockhouse (3) MacArthur Company 936 Raymond Avenue St. Paul, MN 55114 Attn: Len Krumrie MacArthur Company 1416 "B" Avenue Sioux Falls, SD 57104 Attn: Jim Nelson Maroco, Inc. P. 0. Box 3756 Port Arthur, TX 77640 Attn: Mark Coleman Mattew Balich Corporation 37-08 34th Street Long Island City, NY 11101 Attn: F. Brady T. G. MacCracken, Inc. 1818 Bible Road Lima, OH 45802 Attn: D. Bowers McCarty Corporation P. O. Box 53277 Baton Rouge, LA 70805 Attn: Larry Simon McDowell Insulation Co. 9204 Collins Ave. Pennsauken, NJ 08110 Joe McGill Company, Inc. P. 0. Box 1600 Wichita, KS 67202 The McCormick Asbestos Company 3620 Woodland Avenue Baltimore, MD 21215 Attn: J. Shunk Mechanical Insulation Company P.- 0. Box 623 Bloomington, IL 61701 Mechanical Insulation Co. P. 0. Box 423 Kewanee, IL 61443 Attn: T. E. Sleeper Mechanical Insulation Services Box 4568 Florence, SC 29501 Attn: Larry Crawford Mechanical Insul. Services, Inc. 6409 Ambassador Drive Tampa, FL 33651 Attn: K. C. Buchanan Metalclad Insulation Corp. 2911 East Harcourt St. Compton, CA 90221 Attn: Bob Dodge Metalclad Kircher 2114 W. Fillmore St. Phoenix, AZ 85009 Attn: Gene Samson Midcontinent Supply Co. P. O. Box 189 Ft. Worth, TX 76101 Attn: Mel Hogan Middletown Development & Sply. Co. P. 0. Box 369 Middletown, OH 45042 Midwest Insulation Services, Inc. 1016 Douglas St. Omaha, NB 68102 Attn: A1 Wotherspoon (2) Midwest Materials Company P. 0. Box 5 Joplin, M0 64801 Midwest Materials Company M.P.O. Box 845 Springfield, Missouri 65801 Attn: Bill Mauldin -11- Monroe Rubber & Gasket Company 317 Walnut St. Monroe, LA 72101 Joe Moore & Son P. 0. Box 6531 Raleigh, NC 27608 Attn: Joe Moore Moore Insulation Company 7505 W. 80th St. Overland Park, KS 66204 John J. Moroney & Company 6817 Minnesota Drive Bedford Park, IL 60501 Attn: Jack Calmeyn Bill Humprey Mundet Company 14401 Prairie Street Detroit, MI 48238 ft*************** Nashville Rubber & Gasket Company 600-4th Avenue, South Nashville, TN 73211 Attn: Steve Maddox Nelson Roanoke Corporation P. 0. Box 2827 Roanoke, VA 24012 Attn: H. R. Davis New England Insulation Company 155 Will Drive Canton, MA 02021 Attn: Don Kautman New Haven Supply Company 2000 Bullhead Road New Haven, OH 44850 Niagara Insulations, Inc. 79 Perry Street Buffalo, NY 14203 Attn: R. C. Braun North Bros. Company P. 0. Box 252 Atlanta, GA 30301 North Bros. Company Ruffner Road Birmingham, AL 35210 North Bros. Company P. 0. Box 6786 Birmingham, AL 35210 North Bros. Company 79 Reid Street Charleston, SC 29403 Attn: L. C. Koon North Bros. Company Box 3338 Columbia, SC 29203 Attn: William Hope North Bros., Inc. 901 S. W. 21st Terrace Ft. Lauderdale, FL 33312 Attn: Buddy Hammond North Bros., Inc. 2221 Pearl St. Jacksonville, FL 32202 Attn: Jim Valentine North Bros. 5800 Middlebrook Knoxville, TN 37901 Attn: Jim Rogers North Bros. Company Box 8443, 995 N. Hollywood Memphis, TN 38108 Attn: Tony Hope (5) North Bros., Inc. P. 0. Box 7817 Orlando, FL 32804 Attn: Monty Wells North Bros. Company Box 26146 Raleigh, NC 27611 Attn: Billy Jackson North Bros., Inc. P. 0. Box 5296 Tampa, FL 33605 Attn: DeForest Whitcomb Northwestern Insulation Company, Inc* P. 0. Box 521 Ballevue Road 1 Green Bay, WI 54305 Attn: Norman Vance **************** Ohlo ET, Inc. 950 Main St. Columbus, OH 53205 O'Malley Bros. Inc. 3925 W. Oakton St. Skokie, IL 60076 Ohio Valley Insulating Co. 823 Adams Avenue Huntington, WV 25704 Owens Corning 7000 McLarin Road Fairburn, GA 30213 Owens Corning 434 Ingeraham Bldg. 25 S. E. 2nd Avenue Miami, FL 33131 Owens Corning Fiberglas 592 W. Swedesford Road Berwyn, PA 19312 Attn: R. Adams **************** Pacific Insulation 5716 N. E. Hassolo Street Portland, OR 97213 Attn: John Bruniengo Palco Insulation & Sales 221 Oak Street Quincy, IL 52301 Attn: Mark LeGrand Pamrod, Inc. P. 0. Box 335 McQueeny, TX 78123 Penns Valley Insulation 15 Mt. Pleasant Dr. Rolling Hills Ind. Park Aston, PA 19014 Petrin Insulation Co. P. 0. Box 1215 Thibodaux, LA 70301 Piedmont Insulation P. 0. Box 784 Salisbury, NC 28144 Attn: Darrell English Pipe Shields, Inc. 12- Plant Insulation Company 1300 64th Street Emeryville, CA 94662 Attn: Ray Scott Plateau Supply 2401 E. 40th Denver, CO 80204 Attn: E. Holiman Porter-Hayden Company 32 South Street Baltimore, MD 21202 Attn: Bob Schwenson Porter-Hayden Company P. O. Box S Charlotte, NC 28203 Porter-Hayden Company Box 476 Edison, NJ 08817 Attn: 0. Richards Porter-Hayden Company Box 10142 Norfolk, VA 25513 Attn: J. A. Apple Porter-Hayden Company P. 0. Box 2116 Ashland, VA 23005 Attn: R. L. Huggins Power Insulation Co. 2335 Nevada Avenue N. Minneapolis, MN 55427 Precision Insulation Company 7792 Braniff Road Houston, TX 77017 Attn: Chas Lancaster Presnell Insulation 501 Alando Avenue Charlotte, NC 28206 Attn: Jack Presnell Price Contracting Company 2536 Northline Industrial Drive Maryland Heights, Missouri 63043 Attn: B. S. Price Pro Con Inc. 30 U.O.P. Plaza Algonquin & Mt. Prospect Roads Des Plaines, IL 60016 Ratican Insulation Company 6324 Bartmer Avenue St. Louis, MO 63130 Attn: Walter Ratican Rite Way Insulation Ltd. 1011 Lunt Avenue Schamburg, IL 60193 Roughrider Supply, Inc. 5 N. 23rd St. P. 0. Box 1222 Fargo, ND 58102 Attn: Arlin Foss F. P. Rutherford Insulation Co. 5701 Manchester Avenue St. Louis, Missouri 63110 Attn: Frank Rutherford **************** Sabine Industries P. 0. Box 15377 Houston, TX 77020 Attn: Herb Hillberg Sabine Industries P. 0. Drawer 1 Orange, IX 77630 Attn: T. Bowers Sadler Ind. Services, Inc. P. 0. Drawer 1 Clute, TX 77531 Sandel Corp. P. O. Box 23 Westerville, OH 43081 Service Products, Inc. 57 North Westwood Avenue Toledo, OH 43607 Shook & Fletcher Insulation Co. P. 0. Box 2957 Birmingham, AL 35212 Shook & Fletcher 112 W. 13th St. Chattanooga, TN 37402 Attn: Penny Bloomer Shook & Fletcher 3315 Sexton Road, S. E, Decatur, AL 35601 13 Shook & Fletcher Insulation Co. P. 0. Box 7337 Western Dr. Meadow Warehouse Mobile, AL 36607 Attn: Grace Thompson Shook & Fletcher Marine Division 308 Krebs Avenue P. 0. Box 1363 Pascagoula, MS 39567 George L. Slmonds Company P. 0. Drawer 32 Winter Haven, FL 33880 Attn: Roy Eggleston Smith & Cassidy, Inc. 182 Donnelly Road Box 749 Brandon, FL 33511 Attn: E. Smith Smith-Sharpe Company 117-27th Avenue S. E. Minneapolis, MN 55414 Attn: Lyman Moore South Insulation Co. 433 Sadler St. Montgomery, AL 36109 Attn: T. W. Woodard Southwestern Insulation fit Materials 1912 N. Weller Springfield, M0 65803 Attn: C. Flood (3) Sprinkman Sons Corporation 12100 West Silver Spring Road Milwaukee, WI 53225 Attn: John Locher Bud Luken Sprinkman Sons Corporation 1010 S. Washington Street Peoria, IL 61602 Attn: Skip Carlton Stafford Insulation Co. Box 9337 Charleston, SC 29410 Attn: Joe Byron Standard Asbestos Mfg. Company P. 0. Box 1105 Borger, TX 79007 Attn: Harvey Jones (4)  I Standard Asbestos Mfg. Company 401 N. Olive St. Kansas City, MO 64120 (4) Starr Davis Company Box 584 Charlotte, NC 28201 Attn: Jim Fisher Starr Davis Company P. 0. Box 19145 Greensboro, NC 27410 Attn: Dick Looman State Insulation 525 Johnstone St. Perth Amboy, NJ 08861 Stonaber, Inc. 2508 Fairway Park Drive Houston, TX 77018 Attn: D. J. Brown The Stovey Company 2360 59th Street St. Louis, MO 63110 Attn: Walter Sidney Styrothane, Inc. P. 0. Drawer GG Freeport, TX 77541 Attn: Bill McCoy Superior Sterling Company P. 0. Box 1599 Bluefield, WV 24701 Attn: William Poston Syracuse Insulation Dist. Inc. P. 0. Box 338 Liverpool, NY 13088 **************** Taylor Insulation Company 1609 2nd Avenue Moline, IL 61265 Attn: Jon Nelson c Thermal Acoustics 81 Farwell Avenue W. Haven, CT 06516 Attn: Ken Ford Thermal Products 3020 Mascot St. 14- Thermo Tech Inc. P. 0. Box 22209 Houston, TX 77027 Attn: Wesley Smith Thiessen Insulation Co. P. O. Box 437 E. Moline, IL 61244 Attn: C. Edward Thiessen P. S. Thorsen Company 45 L Street S. Boston, MA 02127 C. E. Thurston & Sons 700 Dinwiddle Avenue Richmond, VA C. E. ThurstonA Sons P. 0. Box 2411 Norfolk, VA 23501 Attn: P. B. Robbins C. E. Thurston A Sons Box 1481 Roanoke, VA 24007 Attn: Jack Owens Three I Supply Company P. O. Box 1884 Midland, MI 48640 Attn: D. Simpson Topeka Insulation & Supply 2515 N. Topeka Topeka, KS 66601 Triangle Insulation Company R. R. 7 & Box 86 Paducah, KY 42001 Triple B. Corp. P. 0. Box 96119 Houston, TX 77015 **************** United Insulation Co. 817 N. Lewis Place Tulsa, OK 74110 United Refactories 5597 Commercial Blvd. Winter Haven, FL 33880 Universal Insulation Engineering Corp. '>'U flier St. -15- Universal Mfg. & Supply Co. P. 0. Box 751 Aiken, SC 29801 **************** Valley Insulation 2601 S. Kings Avenue Box 1031 Brandon, FL 33511 Attn: V. Redford (2) Vaughn Insulation Co. 2815 North 22nd Street East Omaha, NB 68110 Attn: Charles Vaughn **************** The W J Company P. 0. Box 142 1901 E. 4th St. Sioux City, IA 51102 Attn: Don Wilber Waco Insulation, Inc. P. 0. Box 24347 Richmond, VA 23224 Attn: E. G. Nippes Waco Insulation of Tidewater, Inc. 23rd Street & Huntington Ave. Newport News, VA 23607 Attn: W. McIntyre Walker Jamar Co. 365 S. 1st Avenue East Duluth, MN 55802 Attn: Walker Jamar Wallace & Gale Company 2832 Maisel Street Baltimore, MD 21230 Attn: B. Peltzer Wayne Oakland Building Supplies Div. Oakland Wholesale Inc. 25018 Plymouth Road Detroit, MI 48239 Webco Insulating Co. 56 E. Chase St. Pensacola, FL 32502 Attn: Dan Bragg Wentz Insulation Company 2949 Cornhusker Highway P. 0. Box 30205 Lincoln, NB 68503 Attn: Stan Wentz West Metal Works, Inc. 201 Dulton Avenue Buffalo, NY 14211 Western State Insulation Company P. 0. Box 5332 Roanoke, VA 24102 Wilmington Supply 1275 Alameda Street Wilmington, CA 90744 Attn: Roy Peterson E. 0. Wood Company 712 N. Beach Ft. Worth, TX 76111 Worchester Industrial Insulations 42 Granite Street Worcester, MA 01604 R, H. Wyatt Insulation Company 115 N. La Salle St. Durham, NC 27705 **************** Young Insulation Company P. 0. Box 9187 Melrose Branch Nashville, TN 37204 Attn: Bob Dean Young Sales Corporation 195 Washington Avenue Memphis, TN 38103 Attn: Mr. Joiner (3) Young Sales Corporation 1054 Central Industrial Drive St. Louis, MO 63110 Attn: J. S. Royer EXHIBIT F 1 AAHtsj w: lo<iii3J Sui Board of HvitS 1330 V.'es: Mich:5r\ Succc l^niimrolu. lncjaru fj ?S1 ry U> A Jl V A. U OF BUDSAH A (hibrh t~ Mr. F. P. Ray Indianapolis Contract Manager Philip Carey Manufacturing Company 1432 Kentucky Avenue Indianapolis, Indiana Fear Jt:. Pay: At the request of Mr. R, J. Scctt, Business Representative of Local 18 of the International Association cf Heat and Frost Insulators and Asbestos Workers, a visit was nude vith you te the Indianapolis Fewer and light Company :s Harding Street plant by Mr. John Kehoe, Chemical engineer, on March 1C, 1961, to evaluate di;st conditions associated wiuh tbs installation of Careyterp insulation. Hie employees installing this insulation had experienced irritation to the eyes, nose and throat ana vc-re concerned about the potential health hazards associated vith the exposures to dust iron this nsteric.1. Observations during this visit indicated dust exposures vere not great enough to constitute a health hazard. It vas ncxed that hand saws vere being used to cut the insulation, Ihe irritation is probably duo to the fiberglass in the insulation and can be minimized by instituting the usual precautionary reasr.re5 er.jl.oyed when handling other fiberglass insulations. Since power driven sba.'s would evolve greater dust concentrations than hand saws, they should be equipped vith local exhaust ventilation to control the dust problem should they te used to cut the insulation. Under present operating conditions it is concluded that no serious dust exposures are associated vitn. tLe installation of Careytemp insulation. b Ufa f>>fiy ' +hyjlr.v tir.1 nrc'Jirin:cy Hr. E. ?. Iiay Indianapolis, Indiana -2- IjTil 13, 1961 Thank you for your cooperation during this visit. If ve nay be of service to you in the future, please feel free to contact us. .Tours very truly. JX:cn - Albert Edwards, ...Industrial Hygiene Engineer I 4 EXHIBIT G I c Jaw,* O PllCC. SC D. uminiNO LAo*AToir tOCN AND rtHtSOA AVCNUC Cincinnati. OniO ajii* cthibif- January 2, 1968 Mr. Arthur P. Mueller Research Division Philip Carey Manufacturing Company 320 South Wayne Avenue Cincinnati, Ohio 45215 Dear Mr. Mueller: We have completed our analyses of samples of air taken during fabrication of Carey Temp insulation at the Union'Carbide Plant . inCharleston, West Virginia. I do not know if you wish to have a formal report, complete with recommendations, etc., for methods of control of dust. .Unless I hear otherwise, I will assume that this letter will suffice. I do not feel it necessary to describe to you the conditions under which these samples were taken, since you were present during the entire operation. All of the impinger samples were breathing zone samples collected directly below the face'of the operator. These samples are representative of an individual's exposure to the dust produced at the operation in question. The impinger samples numbered 1 through 3 were collected during one "run," whereas numbers 4 through 6 were taken during the second cutting operatidn. The electrostatic precipitator samples were located near the saw table and could not be as representative of breathing zone samples as are the impinger samples. In addi tion, a high volume air sampler was used to collect dust frcm the air during the total period of time we were there. This sample naturally includes some down-time. The samples were analyzed by standard procedures. A sample of dust collected with the high volume air .sampler was prepared for examination by X-ray diffraction to determine the per cent of crystalline free silica and asbestos in the airborne dust. The X-ray diffraction pattern failed to indicate the presence of crystalline material in the dust. The probable limit of detection by X-ray diffraction for asbestos or quartz in untreated samples is approximately 5 per cent for each material. Mr. Arthur P. Mueller Philip Carey Mianufacturing Company January 2, 1967, continued -2- Microscopic examination of the samples of dust indicated the presence of some fibers, but it was not always possible to differentiate between glass fibers or asbestos fibers. As you are aware, the threshold limit value for asbestos is 5 million particles per cubic foot of air and for inert or nuisance particu lates this value is raised to 50 mppcf or 15 mg/m^, whichever is the smaller (source: Threshold Limit Values for 1967, ACGIH). Since asbestos is known to be an ingredient of the parent material my personal recommendation would be to use the lower value even though the analysis indicated that the dust contained less than 5 per cent asbestos. The results of the sampling are given in the attached table. If additional information is required, please do not hesitate to let me know. Also enclosed is a statement of charges involved, indluding charges for analyses incurred by the Kettering Laborator Please make the check payable directly to me personally for the full amount and I will reimburse the Laboratory. Sincerely yours JOPiegm Enclosures J. 0. Pierce, Sc.D. Assistant Professor of Environmental Health  c ' RESULTS OF SURVEY AT THE UNION CARBIDE PLANT, CHARLESTON, WEST VIRGINIA DURING FABRICATION OF PHILIP CAREY (CAREY TEMPE) INSULATION BOARD DESCRIPTION AND LOCATION IMILLIONS OF PARTICLES OF SAMPLER . PER CUBIC FOCT OF AIR MDOCf MILLIGRAMS OF PARTICULATE PER CUBIC METER OF AIR Mo/M3- #l-lmpinger- located at breathing zone of Mr. D. E. Raines, operator at saw #1 during unload ing and cutting of insu lation board #2-Impinger- same as #1 except `attached to other operator, Mr. W. L. Alford 16.4 15.9 - ----- #3-Impinger- located at breathing zone of Mr. J. Jordan, operator at saw #2 during 1st phase of sawing 19.5 - #4-Irrpinger- located at breathing zone of Mr. W. L. Alford, operator at saw #2 during second phase of sawing operation 19.9 - #5-Impinger- located at breathing zone of Mr. J. Jordan, operator at saw #2 during second phase of sawing operation 23.8 - #6-Impinger- same as 45 except attached to other operator, Mr. H. Witt 27.3 - ^ #7-Electrostatic Precipitator sampler- located app: 5" above plate of saw #1 during first unloading and cutting cycle # 8.65 64.3 \ Survey i\ -. t DESCRIPTION and location OF SAMPLER MILLIONS OF PARTICLES PER CUBIC FOOT OF AIR Moocf MILLIGRAMS OF PARTICULATE PER CUBIC METER OF AIR Ma/M3 #8-Electrostatic Precipi tator- located at same location as #7 during cl^an-up operation be tween runs #9-Electrostatic Precipi tator- located at saw *?2, left side, appr, 8-10" above plate of saw during second phase of cutting operation #10-High Volume Air Sam pler using fluted filterlocated at the right sice, appr. 41 from saw #1 during entire operations 5.5 3.0 - 29.1 21.1 37.3* * X-Ray Diffraction indicates no detectable crystalline material present in this sample \ d EXHIBIT H UiE PHILIP Ci-^ w MF-G. COMPaCv'.^^T t . s > Kay 23, 1963 Kr. L, J. Knlppa, Plane l'ana^or Too ?hili;; Cc.^-iy r.anufacCuring Coapany Lockloi'd, Cincinnati 13, thro * Dear Hr. iinippu: _ 4 ' / ' Iri accordance vlth ycur Toquo&t, 1 an providinj you with background data and specific vcccmcndntlor.s, which wero discussed in t!:o Jclnt cur.fcrer.ceu with you, lit. Karl Krie;j arsl Hr. Louiu tfcchstcin, VB.ocI--k "I tou--i^rs--!: ' . - . .. ' ' A national awareness is developing rclativo to tho potential and haxrful effects of asbestos and asbestos products. This stasis iron: 1) The relatively recent scientific reports in England, Gcrtinny, Africa j. *( end the United States, chrvir." a strong association between asbestos end lung cancer and ciecothelicaa (cancer) of the pleura and perltoncua. . * This io ou.pcentcd by the technical vuakr:cssc& of tho study conducted by tho Industrial IJy^'icno foundation (at the request of the Asbestos Industry) and the opinion of well qualified poraons tlmt tho con clusion of a negative'' association of aabestosis and lun" cancer ic not really justified in this report. Theso various scientific reports, the lirdtations of the Industrial Hygiene report anJ other unpublished data, wore reviowoJ arJ discuosed in c itcotinj in Washington, U. C., with representatives of tho acbostoo industry and the U. $. Public Health Sorvico over onu'year ero end tho need for extensive research expressed. o y.r. L. J. Kniupa, Plant Hnna^er Tho riiilij) Curoy Hanufucturin:; Ccmyany LocUland, Cincinnati 13, Ohio o . -2Hay 23, 1963 2) Tho federal ovcrrnvental otudy now officially launclicd (although not publicly ennounced) by tho U. S. Public Health Service, Dlvicion of Occupational Health, of tho asbestos industry In the United Stetc3, which will includo corcprehcnsivo r.cdical, engineering, chemical and statistical evaluations and studies of tho work environment of representative situations in tha asbestos industry. The j^ovorn- ocntal investigation at present is in the technical development sta~e and preparations are under way for field otudico in the asbest03 industry, rxcen~i:i.i>Anc?:s 1 Establish an inter-industry Asbestos Research Vrograa on a national and international basis for the development of a coordinated plan of research to cect tho needs of industry; to evaluate present and projected problems; and to establish tho means of identifying and limiting tho particular hazards involved. Although cooperation with state and federal agencies is necessary and de sirable, the asbestos industry should bo in a pooition to cake an independent Judgment, based upon its own appraisal /uid research of the situation amid the factors involved, since this judgment r.ay Imvo very serious implications relative to die pluns and operations of tho asbestos industry. *- fr Affiliation with industry and research ascociutas in Europe end Africa vith similar interests and concerns, voulJ rako j^ossiblo tho benefits of those experiences and avoid duplication; ir-cko possible tho demarcation of Specific areas of research rolative to particular questions; and tho de velopment of a unified approach to the successful continuation of asbestos operations effectively controlled ard accepted by tho conourver in various countries I * o Kr. L. J. Knlgga, Plt.rr I'./uviffQr The 1`hi.lip Carey l-inuLuctuiir.^ Cor.v>any Lackland, Cincinnati 15* Chio -3- Hay 23, 1963 The eshostoa crrvironir.cntal hazards can definitely bo controlled. Uovcver, the Inch of cooperation of other asbestos industries or tho con tinuation of an occupational cancer erpejuro in a particular industry, vlll, in texts of public response end concutar relations* as veil as lau suit3 and Workmen's Compensation, affect nil other asbestos or rolatod industries. II Develop c. "positive" approach to consurar guidance end asr*stance. This would take several farms. a) Tho development of recommended practice manuals containing illustra tive ventilation control designs, safe handling procedures, and other similar guide line3 for tho effective control of dusts under various types'of consumer uses. This could be prepared after an analysis of consuiosr uses and practices had bean made by tha industrial hygiene engineer rccostjcnded in III. The ventilation examples ond rccoc&enicd practices would relate to various preducts end cover broadly all operations of consurjcr uso. This approach could bo initiated by a single asbestos industry for ccrepctitivo sales, or an agreosKjnt de veloped on an inter-industry basis as to tha contents of theso various tianuuls and tl.oir distribution. b) Provide a technical assistance ocrvica through tho company* s in dustrial hygiene engineer for consultation and tho evaluation and ^ control of dust problems, to tho largo or various consumer industries end specific groups in which contractual arrang.cr.cnte bavo been r-cdo. Tha objective in to pro.vcr.t tho development of problems or any change in t.'orkx.xan'c Compensation and liability ctatuo of largo ucovo of tho products, ond to danonatrata and cnphAsir.a that tJw products can bo used oufely and effectively under proper conditions. o Hr. L. J. Krd..pa, L'k-.S-'i->n.i-.ur Tho Phill.i Carey l cnuiacCi\rln:* Cotoj>any LockLuxi, Cincinnati 15, Ohio -4. lifty 23, 1963 111 Employ o vral 1 qualified industrial hygiene engincar to establish, on A company-wide basis, a program of effective environmental, occupational and air pollution control of tho various dusts, furooG, nists, gases, etc., created, edited or used in tlio operations of the varioua company plants, ond to provide technical consultation as required, for consumer relations. Some of tho duties which would effect substantial savings, uould b< as follows; 1> Occupational Disease Control - to conduct technical industrial hygiene surveys of ell work environments at tho various plants, buildings end locations and for all company operations, including Canada. Tlie objective is to Identify ard measure the various concentrations of handful dusts ond , cheaicalo; detemino those operations in t/hich control treasures ere requiredj design the ventilation control measures; and subsequently determine the effectiveness of these control treasures. To accomplish this, the industrial hygiene engineer would carry out all the engineering aspects of environmental evaluation and work closely with Che company checoLstc and laboratory facilities. On specific occupational disease claims, the industrial hygiene engineer would bo able to pruvide precise data relative to tho presonce or absence of various chemicals or dactc, tho concentrations and fonuS of these chord cal a or ducts, aixi tho concentrations and forris of these chemical a at various time periods and operations. This would bo of usciutanco in evaluating the ruorifcs w of occupational disease claims. 2) Air Pollution Control - to conduct tcclinical air pollution surveys in 4 # designated areas in various corrainltics In which cow.any o;>orationa exist. Such otudicc require tho mcccurancnt and analysoa of divorce atrujopheric # 4 9 lir. I. u. Kr.i-r.a, n.?f,er Tho thiii ; Carey f-r.nai.'.cturin^ Company lackland. Cincinnati 15, Chio o -5- llay 23, 1963 Contcr_irunt8 from a variety of sources end tha determination of tha nature And extent of tha company's contribution, as veil os the design of tha Ventilation control and coin tend nant suppression censures required. In con junction with tliis, ha vould develop a program of air pollution surveil lance relative, to company operations} in various locations. Tho industrial hygiene engineer vould represent the company in con ferences and diccussions vith cccounity, state and federal officialo telativo to ccm-plainto and problem pertaining to air pollution. 3) Technical Consumer Assistance - to develop informative engineering control, ventilation and safe handling end use guide lines for consumer use, and provide technical consultation to specific uccr3 for tha prevention and control of actual cr projected problems relative* to the use of the cccipany1 s products. (This has been referred to in II). 4) Process Development and L'roduct Use - to work cooperatively vith the Departments of research and Engineering in evaluating and developing neces sary control ceaaurcs for`tha possible health effects crouted by (1) nevr oanufacturing processes or process changes, and (2) consumer use of now conpany products. ****** In surraary, tho background (lata airl the tecor.;:cndntious made, point to tha need for direct and inr..odiato action. It is readily opparaut tluxt unless the necessary steps hive Leon token, the information desired at subsequent dates uay not ba available to anever the questions v?iich my be posed. V f o4, Ur. L. J. Knippa, Plant Kannr>,ar The Fldlip C.ney Kur.uf:^ctarir.^ Ccrpany LocklAnri, Cincinnati 15, Oliio O GKay 23, 1963 -Such inforrsation and action haa a direct bearing in Uniting tho extent and preventing uturo financial losses. Yours very truly, TFK/kb Cc: Hr. L. A. Pechstein Hr. Karl F. Krieg Lockland, Cincinnati 15, Ohio Thorns F. Unncuso, M. D, Consulting Kedical Director > THE PHILIP CAREY iMANUFACTURING COMPACT BUILDING MATERIALS INDUSTRIAL PROOUCTS CINCINNATI 15. OHIO TELEPHONE: 12V 3000 CABLE AOONCSS "PHILCAYCO** August 15, 1963 Mr. Louis Knippa, Lockland Plant Manager The Philip Carey Manufacturing Company Lockland, Cincinnati 15, Ohio Dear Mr. Knippa: Occupational Health Program In further reference to our latest discussion in your office and in particular, the discussion with Mr. John W. Humphrey, President of your company, I am sending you copies of articles which have appeared in medical literature relating to the hazards of asbestos exposure in industrial employ ment and to the surrounding population. These are recent articles. The most recent and perhaps the ' most Important, is the paper presented at the Medical Association Meeting in Atlantic City on June 17, 1963, which has not yet appeared in medical literature, but which, of course, is known to the medical profession interested in this field of medicine, and is known to your trade unions, whose members were studied and whose unions participated in or partially underwrote the study. A copy of this letter and two sets of the articles are being sent to Mr. L. A. Pechstein, Assistant Secretary, for himself and Mr. E. J. . Fasold, Secretary, and a copy of this letter and one set of the articles are . being sent to Mr. Karl F. Krleg, Employe Relations Manager. Our -coming meeting would be more productive and effective if you are able to review these articles beforehand. With no Intent to alarm you, may we bring to your attention another aspect of this problem. There have been recent law suits and dis cussions in legal and insurance circles in the past two years which would 6eem to indicate chat employes who suffer industrial disabilities can sue fellow employes for personal liability at common law. This refers particularly to the officers and managers of an enterprise to the extent that they do not fulfill their duties and obliga tions in providing a safe place for employes to work, or in detecting and removing occupational hazards and injurious exposures. Mr. Louis Knippa, Lockland Plant Manager The Philip Carey Manufacturing Company Lockland, Cincinnati 15, Ohio -2- August 15, 1963 This personal liability seemed so certain and costly that the 105th General Assembly attempted to rectify it. You will shortly be informed, in an eight-page letter from your Actuaries, John T. Cantlon & Associates, Inc., of the legislative changes enacted, including the particular amendment referring to-this personal liability. The reading of the enclosed articles will also inform you of the advances made in the study and medical findings in your industry. These will later become general knowledge among the unions-and your em ployes, and is a forerunner of the Workmen's Compensation claims of the future. In addition, there is possible liability to persons other than employes from air pollution. Mr. Cantlon and I are looking forward to the opportunity to further discuss this with you and with-others in your, organization. Personal regards, yv*N>o 3* Thomas F. Mancuso, M.D.M.P.H. -------- Research Consultant TFM/kb Enclosures Cc to Hr. Karl F. Krieg, Employe Relations Manager Mr. L. A. Pechstein, Assistant Secretary Lockland, Cincinnati 15, Ohio t> EXHIBIT I OV o ----------- I --.... --------- ... . ....... Preliminary Industrial Hygiene Survey at the PHILIP CAREY !-'A:rLTACTURT::u co:.;pa:jy (December XT, 18, 1$, 1962) # r * o. % o t) Preliminary Industrial Hygiene Survey at the : PHILIP CAJCY : "l U7AC IUH HG COMVJIY A prelininary industrial hygiene engineering survey1 yos conducted at the Philip Carey Manufacturing Company, Cincinnati, Ohio on December 17, 18, 19, 1$62* \ Observations vere made, of the dust-producing operations, namely those involving asbestos and free silica. In addition, various other potentially hazardous environmental conditions vere noted The purpose of this prelininary evaluation vas to establish: 1* a priority schedule - determine vhich dust producing operations sppear to involve the greatest potential hazard. (Firstefforts vould be directed at these operations for proper evaluation and control.) 2* a plan for environmental evaluation - indicate generally where and vhat types of air sasples, ventilation measurements, etc., should be taken to properly define potentially hazardous areas. 3* preliminary time estimates - estimate the approximate time necessary to carry out the steps indicated in (2) above. Environmental Valuation -- Priority Schedule Table I summarizes the areas recommended for environmental evaluation on a priority basis. As indicated, facilities in several of the areas vere not observed in operation. 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P H Cl v4 ;-4 c <H U f>i P4 o VP4i on 4o-> ioi 3 d Vi 4 MM nn Cl i'l 'll nl .<* .ii Ms **41 Li .U Li PRIORIT/I EIJVIKOIIMEUTAL IC2ASURE3EUT3 o <J PUILI? CARET 123. CO. PafiC 7 Representative Mr Sarnies Bio exact number and location of breathing zone and general room air samples has not been specified for each operation. This can only be determined vh.cn detailed area evaluations are undertaken. At that time the measurements necessary to accurately describe each, area vill be determined by such factors as: 1. the quantities and types of materials used 2. how the materials are handled; variations in process 3* vhether the operation is continuous or intermittent 4. how many persons are involved; their locations 5. vhether personnel are exposed to dust from several different operations 6. changes in room air flow patterns; seasonal variations, etc. 7 effect of local exhaust systems The problem of obtaining representative samples is a conplicated one. The time required to obtain dust samples usually is of the order of minutes or hours; vhile a period of some months up to many years is generally required for the development of diseases from dusts. These diseases result from the Integrated effect of dust breathed over a long period. On the other hand, a single in- plant dust determination represents only the amount of dust in the atmosphere at a definite time and place. It cannot give an indication of the average exposure of a over a period of years -- particularly if he has not worked continuously at the one Job. Thus -a proper measure of dust exposures requires a picture' of the variations in dustiness -- the dust floods -- as veil as a measure of the average concentration. The locations of the campling points, the volume of snmplo to be collected, and oo PHILIP CAR2X KF3. CO. Pose 8 the frequency of samplin'* must therefore be chosen carefully through a detailed ctudy of the particular operation. Generally every effort io made to evaluate a dusty area with as few samples as possible -- dust, counts and particle size measurements are tedious and time consuming operations. The casual observer might veil ask why any air samples or atmospheric measurements are necessary -- some of the plant areas are quite obviously very dusty. However, # it is only by actual atmospheric dust measurements that the quantity of respirable contamination can be established. Beyond this, of course, is the major objective of sampling which is to identify the principal sources of dust in order to apply appropriate control measures. Follow-up atmospheric samples then can indicate the effectiveness of such control measures. Time Estimate -- Engineering Evaluation Table II contains time estimates (in man-days) to conduct in-plant and laboratory measurements, to interpret and compute the results, and to formulate recommenda tions. These estimates are the best approximations which can be given at this time, (The actual time will depend largely upon the number of samples necessary, vhich in turn will vary from operation to operation as explained in the previous * section, page 7.) T) jjH. priority (14 Areas) Til'S ES table II Time to Corplc (in icon-days Measurements 5** -'".pies (estimate between 25 and 45 samples) ''Mirplcs (cst. between 10 and 15 samples) vent 11 ,vti0n. local exhaust, general air movement cc*U'.it,ional analysis >" ' V >' >' r y^ Measurem---e---n--ts duct ,.,JUnts (estimate between 25 and 45) . part.sije measurements (cst. between 12 and liij cheun,.<JLi analyses (cst. between 5 ) iter^W'Motion cocx'v.v ntions, data analysis conerecommendations, report 14 16 . 10 2 PRIORITY (19 Areas) In-Plr-. . air ; . bullc . ven' . occv. casurencnts les (estimate between 2o and 43 samples) .pics (cst. between 12 and 17 samples) .ion measurementsj local exhaust, general air - * **'`1 * S ft Labor.'.. . dust . par: . che:-. Measurements ts (estimate between 2o and 4S counts) between 10 and 20) size meas/ure_ m^ ents . (cst. .^nn 5 and 0) Inter." v t.vtion corn-. intions, data analysis . cone.' .sions, rccomr.ondatic.no, report Total 15 16 10 41 Pace 10 TADLE II (cont'd) #3 PHionirr (15 Areas) Tine to Comlcto (in Ban-days) In-Plant Measurements air samples (estinate between 22 and 40 carries) 'bull; samples (est. between 5 and 8 sanples) ventilation measurements j all areas ' occupational analysis 12 Laboratory Measurements dust counts (estimate between 22 and 40 counts) particle size measurements (est. between 6 and 10) chemical analyses (est. between 2 and 4) Interpretation computations, data analysis conclusions, recommendations, report 13 8 4 PRIORITY ( 6 Areas) Total 33. In-Plant Measurements air samples (estir.atc between 10 and 18) . bulk samples (est. between 4 and 8) ventilation measurements occupational analysis 7 Laboratory Measurements 18 dust counts (est. between 10 and ) particle size measurements (est. between 4 and 8) chemical analyses (est. between 2 and 4) 7 Interpretation computations, data analysis conclusions, recommendations, report - Total 5 19 Lee n. PocdJck Industrial Hyjicnc Engineer TilRJLIIOLD limit values In any dusty environment there is the question of "how much'' dust is safe. To help answer this question. Threshold LLv.it Values for various toxic materials have been established by the1 American Conference of Governmental Industrial' Hygienists. These values of allowable air concentrations represent conditions under which most workers may be repeatedly exposed, day after day, without adverse effects. They are guides for the control of health hazards -- not fine I lines between safe and dangerous concentrations. The limits are based on the best available information from industrial experience from experimental studies, and, vhen possible, from a combination*of the two. They are subject to modification as more complete data become available.# In the case of dusts containing at least ^5^ free silica, 5 million particles of dust per cubic foot of air (eppef) has been established as the Threshold Limit Value. For dusty atmospheres containing asbestos, the level similarly has been set at 5 mppef. However, because of the fibrous nature of asbestos, the threshold limit cannot be considered to be as firmly established as are limits for some of the other dusts. Techniques used for evaluating cost other dusts (considered as spher ical particles) may not be entirely valid for asbestos. The etiology of asbestosio still is under study and research efforts are vitally concerned with the effect of the length and diameter of the fibers in producing lung damage. * Icscd on the standard procedure for sarinling and counting dusts adopted by the Fifth Annual Meeting of ACC LI One large manufacturer of products usin asbestos evaluates air samples taken in the plant for both dust and fibers. The respirable dust consists of the more or less spherical particles 10 microns and less in diameter, while the fiber is \ considered to be those elongated particles greater than 10 microns in length. A threshold limit of 5 million particles per cubic foot of air (mppcf) is applied for the dust and 1 mppcf is applied to the fiber. (The 1 mppcf fiber threshold limit is based on experimental vork conducted at the Saranac Laboratories, Saranac, Kew Yorlc and reported in "Experimental Studies of Asbestos is".) These guide lines are said to have worked out well based on this particular industry's clinical experience. > 1 micron is approximately 1 of on inch. 2>,000 J EXHIBIT J EXHIBIT K > BODILY INJURY PRIMARY LIABILITY INSURANCE CARRIERS FOR CELOTEX AND PREDECESSORS FOR ASBESTOS-RELATED PRODUCTS LIABILITY CLAIMS CARRIER Aetna Casualty & Surety CNA American Motorists Employers of Wausau General Accident TERM 10/1/72 - 10/1/77 1/1/71 - 10/1/72 1/1/69 - 1/1/71 1/1/68 - 1/1/69 1/1/49 - 1/1/68 (and all prior coverage) BODILY INJURY EXCESS LIABILITY INSURANCE CARRIERS FOR CELOTEX AND PREDECESSORS FOR ASBESTOS-RELATED PRODUCTS LIABILTIY CLAIMS CARRIER Northbrook North Star Reinsurance Co. Home Insurance Co. First State Insurance National Union American Reinsurance Stonewall Ins. Co. American Home Insurance American Motorist Insurance Lloyd's of London CNA U.S. Fire American Excess California Union International Employers of Wausau Lexington Continental Transit Midland National Surety Old Republic Highland Hudson Integrity Protective National Federal Granite State Central National Employers Mutual Twi n Cl ty Gibralter AIU INA Hartford Royal TERM 7/16/76 - 10/1/81 3/1/75 - 10/1/77 8/1/67 - 1/1/71, 3/1/75 - 10/1/79 11/1/76 - 10/1/84 10/1/76 - 10/1/78, 10/1/79 - 10/1/84 8/1/67 - 1/1/71, 10/9/72 - 10/1/77 3/1/75 - 11/1/76 3/1/75 - 10/1/76 4/18/72 - 7/16/76 8/1/67 - 4/18/72, 10/1/78 - 10/1/84 1/1/55 - 1/1/71, 10/1/78 - 10/1/79 10/1/78 - 10/1/80 10/1/78 - 10/1/83 10/1/79 - 10/1/80, 10/1/81 - 10/1/83 10/1/80 - 10/1/84 10/1/80 - 10/1/84 10/1/80 - 10/1/83 10/1/80 - 10/1/84 10/1/80 - 10/1/84 10/1/81 - 10/1/84 10/1/81 - 10/1/84 10/1/81 - 10/1/82 10/1/81 - 10/1/84 10/1/82 - 10/1/84 10/1/82 - 10/1/84 10/1/82 - 10/1/84 10/1/82 - 10/1/83 10/1/82 - 10/1/84 10/1/82 - 10/1/84 10/1/82 - 10/1/84 10/1/82 - 10/1/84 10/1/82 - 10/1/84 10/1/82 - 10/1/84 10/1/82 - 10/1/84 10/1/82 - 10/1/84 10/1/83 - 10/1/84 ) EXHIBIT L *- Asbestos* Millboard DESCRIPTION: Asbestos Millboard is made trom Canadian asbestos fibre puip mixed with binding materials and formed in sheets. Commercial Millboard is produced in two grades, No. 1 Hard and No. 7 Medium. No. 1 Grade withstands temperatures up to 1000F and No. 7 Grade withstands temperatures up to 0OOF. These two grades satisfy the vast maionty of require ments Special grades can be developed by Celotex laboratories. Asbestos Millboard with pin-point (knurled) finish can also be supplied. SIZES: Asbestos Millboard is furnished m 42" x 48" sheets in the following thicknesses: TYPICAL CHARACTERISTICS COMMERCIAL ASBESTOS MILLBOARD Thickness Pounds*** (Inches) Per Sheet 1/16 5/64 3/32 1/8 5/32 4 3/16 1/4 5/16 3/8 1/2 5/8 t+t 3/4 t+t 1 t+t 3.9 4.9 5.9 7.9 94 11.8 15.8 19.7 23.6 31.5 37.6 45.2 60.2 Ounces*** Per Sq. Ft. 4.5 5.6 6.7 9.0 10.7 13.5 18.1 22.5 27.0 36.0 43.0 51.7 68.8 'Typical weights. ^Available m laminated form on a special order basis only. APPLICATIONS: Asbestos Millboard is used extensively m the electric heating field and glass industries. Characteristics, properties, or performance of materials or systems herein described are based on data obtained unaer controlled test conditions Celotex makes no warranties, expressed or implied as to their characteristics, properties, or performance under any variations trom such conditions m actual construchon.The Ceiotex Corporation assumes no responsibility lor the effects of structural movement. "WARNING These products contain asbestos fiber. The Occupational Safety and Health Administration (OSHA), an agency of the United States Government, believes that repeated inhalation of ssbestos fiber is a health hazard and may cause various diseases including cancer and asbestosis. FOR ADDITIONAL INFORMATION CONTACT YOUR NEAREST CELOTEX REGIONAL OFFICE. 3 INSULATION JACKETING to Is Unac*i -O. 3 T2 FIRECLAD JACKETING Fireclad Jacketing is a durable, weather-resistant jacket ing specifically designed for the protection of outdoor pipe lines where the danger of fire must be minimized. Carey Fireclad consists of a tough, substantial sheet of asphalt saturated asbestos felt, over which is cemented on one side an unsaturated asbestos sheet. The complete sheet is reinforced with a fabric of tough, flexible glass threads. Fireclad Jacketing will not drip aspnalt in the presence of fire and is highly resistant to combus tion. Fireclad Jacketing is recommended for use in the process industries and in oil refineries, where it affords maximum resistance to the spread of fire -- and further protects the insulated surface from weather damage. Furnished in approxi mately 45 lb. rolls 38" wide by 34'6* long, containing 108 sq. ft AS8S3TOS FELT Asbestos felts in various weights are used to protect insulated piping and equipment from weather damage. The asbestos base of these felts is highly resistant to weather damage and provides long lasting protection. ASBESTOS PAPER AND ROLLBOARD Asbestos Paper and Roilboard are strong, flexible, fireresisfant sheets composed of pure Canadian asbestos fibre and free from hard, rocky particles. 6-lb. and 8-lb. Commercial Grade Asbestos Papers are used extensively in the manufacture of various pipe insulation and electri cal insulation. The 10-lb. and 12-lb. papers are used for wrapping hot air furnace pipes. Heavier weights are used for lining stoves, ovens, gas ranges and for making gas kets, filters and discs. Furnished in standard widths of 18", 24", 36* and 37'/*" rolls. Special sizes can be made to order. ASBESTOS MILLBOARD Asbestos Millboard is made from pure Canadian asbestos fibre pulp mixed with binding materials and formed in sheets. Asbestos Millboard is used extensively in the electric heating field and glass industry. It is recom mended for use in fire screens and partitions, as a fire proof lining for ceilings, walls, floors, elevator shafts, motion picture machine booths, ranges, stoves, grates, electric ovens, sterilizers and roasters. No. 7 grade with stands temperatures up to 800' F.; No. 1 grade with stands temperatures up to 1000* F. Furnished in 42* x 48" sheets in thicknesses from V*' to 1*. ORGANIC FELTS Organic felts are available for economical weather proofing of piping and equipment. They do not have the aging characteristics of asbestos but will provide years of satisfactory protection. WARRANTY: We warrant our materials to be of good quality and will replace material proved defective. This warranty is in lieu of ail others express or implied and may not be extended by representatives, written sales information or drawings. While we recommend uses for our material based on tests believed reliable, we in no way guarantee particular methods of use or application or performance under special conditions. THE FMfL'P CAREY MFG. COMPANY CINCINNATI, OHIO 4S215 DISTRICT OFFICES AND WAREHOUSES ATLANTA 2011 Tuchu Ir.ouidial Hoad Tuck,,. Gor|>a 1C0S4 404-636-1101 BOSTON 761-0 Concoid Aana Candnot, wan 0213* 6i;-i;6-.'70o CHICAGO 2111 4 Marian Avcnua 8,11-ooa. Illmoii 60104 312-217-7232 CINCINNATI 316 Saudi warn, Ang Cincinnati. Ohio <1211 113 - 621-3000 CLEVELANO Oil w I60in Slitfl Cl,,,iand 0n<g <4131 216 671-6270 OEi wTH:cOlIT.cmon a.ei'w, Or'ian M-rn>can 4623* 313 363-2600 HOUSTON 11JO it Jim Toil Oak Hoad Mouiim. Im 77024 713 - 646-3141 INOIANAPOLIS IIi2 kt-ituckv Avenue Ini-anapuiii Indiana 46221 Itr 6,1-1314 MEMPHIS 1110 Oxnji Hoad Warnonu r,nn,it,, 36107 VI 126-0861 MONTREAL rue rn.iio Cart, Co . ud. 61 Simian Boulevard Villa SI laurani Mondial 6. * Q . Canada 114-748-6331 NEW YORK Smith Suatt i Vietery Snd64 hat IK Ambe*. N J. 06162 201 -626-66*1 PHILADELPHIA 24iii ana Seddev Aa. ftiuadalphij Pa. 1*19 2(5- 226 6430 PROVIOENCE 40 Paitan Hoad (ait Provioence. 61. 0261* 401 - 434 0210 ST. LOUIS IC347 Midmdl Indutliial (Ivd. 11 icun. Muiauo 63132 ll< <;j 1VM WASHINGTON 10710 Hanna Sdafl Bellsvilie Mi,,land 20701 3JI 414 4122 WEST COAST Lo* Angeles Area: I muiaini'ii Civilian 132 Su Monierev Pan Montctev Pan. Calil 61714 713 213 8117 Omar Than Los An.-ies Area: 13711 l'mc*4 0n*a Santa I, Sidm21. Calil. 60670 21J 864-6740 LithO in U.S.A. thermo-wall construction Popular Methods of Erecting and Fastening RECOMMENDED GIRT & PURLIN' F-. _ SPACINGS FOR THERMO -WALL K CONSTRUCTION Max. Girt Spacing! Max. Purlin Spacing! WARRANT! atWo warrant our oturiili to bo food quality ud will mplaaa material proved defective. Thie womacy io liau at U othara itpnu or iapiiad ood may aot bo oitoodod by mirmsotativoa. writtae oalea informaboo or drewiafa. Whila w* recommend ueee Cor our macanal boaad oo taoct believed reliable. wo ia oo way fuaruatae particular mothoda of uoe or appiicacioa or parfncmanta uador apodal cooditioaa. rwu oo. no ism i/it m V THERMO-BORO TV lit' THCR MO-BORO 8*0* 1M' THERMO-BORO ... - v_ 10*0* ----- -i- .' 2' THERMO-BORC lorr W 5's* 6'3* " .T , TV Jt THE PHILIP^teywMFO. COMPANY X.OCKXAND, CINCINNATI US, OHIO ^ Lf* District Sales Offices: Atlanta Chiceao Boatoo Charlotte Ciocsaoati Clcvdaad Detroit Houatea too Aaqalaa Now York . Philaddphia Pittaburph St. Louia Saa Ftanriawi Saattia Montreal. P.Q. a- - Daa Moiaaa Mamphia Xodiaoapolia -~~.it Z.dT-:*:< -- utM u> o.s.a. EXHIBIT M Commercial Asbestos Paper and Rollboard DESCRIPTION: Asbestos Pacer ana Rollbcara are composea of Caracian ascestos fibre combined with a smai! Quantity of extremeiy strong bmcing material. A sceciaily- ecuiccea pacer-maKing macnme turns the slurried com ponents into sneets. Tr.e snaets are thorcugnly cried and, finally, caienderea to a smooth finish. Asbestos Paper and P.oliboara are strong, flexible, fire-resistant sheets suitable fcr varied applications thrcugnout industry. Asbestos Paper ana Rcilboarc are cf one type and vary only in thicxness ana wiath of sneet roils. Gummed or plain Asbestos Paper Tape, made from standard 12-lb. stock, is also available. SIZES: Asbestos Paoer and Rollboard are furnished in stanaard widths of 18''. 24", 36" and 37'/s". Special sizes can be made to oraer. Stanaara weights and thicknesses of sheets are: Lbs./lOO Sq. Ft. (10%) 6 8 10 12 14 16 32 50 64 Approximate Thickness--Inches .015 .019 .022 .026 .029 .032 .0625 .094 .125 Asoestos Pacer lace is availaoie in 2" ana 3" .vice roils -- each 84 feet icng. The Tape is made from standard 12-lb. siock anc may be crcered gummed or plain. APPLICATIONS: Asbestos Paper and Rollboard are satis factory for a great variety of purposes. The 6 and 8-lb. papers are used in the manufacture of various pipe ana electrical insulations. The 10 and 12-lb. papers are used for wrapping hot air furnace pipes. Heavier weignts are used for lining stoves, ovens, gas ranges and for making gaskets, filters and discs. Other prospective applications for this material might include: Laboratory equipment insulators Dental molding forms Boiler jackets Protected metal siding Kitchen hot pads Table pads Electrical appliances Safes and strongboxes Dry kiln insulators Flooring base Welding mats and insulators Plastic roof system base Filing cabinet lining Household radiator covers Culvert pipe protection TYPICAL CHARACTERISTICS COMMERCIAL ASBESTOS ROLLBOARO 3/32* 1/8* Weight. Pounds 48-52 57-67 Thickness. Inches .094 .123 Tensile Strength, Dry Pounds. With Gram 35 35 Mullen Strength. Pounds Moisture. Per Cent 32 32 35 TYPICAL CHARACTERISTICS COMMERCIAL ASBESTOS PAPER 61b. 81b. 101b. Weight pounds per 100 sq. ft. 5.5-6.5 75-8.5 9.3-10.7 Thickness. Inches .015 .018 .022 Tensile Strength, Dry Pounds, With Grain 14-16 14-16 14-16 Mullen Strength, Pounds 10 11 12 Moisture. Per Cent 33 3 121b. 11-12.6 .025 15-17 12 3 14 lb. 13-15 .028 16-18 14 3 16 lb. 15-17 .032 16-18 14 3 3/84* 23-26 .045 18-20 20 3 2 Asbestos Insulating Paper Specialties CORRUGATED ASBESTOS PAPER DESCRIPTION: Corrugated Asoestos Pacer consists of a sheet of asbestos pacer, which has been corrugated, firmly cemented to a flat backing sheet of like material. The two sheets are joined by a suitable adhesive. Corrugated Asbestos Paper is a very light and flexible form of insulation, adaptable for wrapping around curved surfaces. SIZES: Corrugated Asbestos Paper is furnished in coarse corrugations ('/" thick per ply) in 36" to 37" wide rolls. It can be ordered in 250 sq. ft. or 500 sq. ft. rolls. APPLICATIONS: Corrugated Asbestos Paper can be used wherever a light and flexible, yet efficient, insulating mate* rial is required. It is especially valuable for wrapping hot air furnace pipes, and as insulation for hot air ducts in blower systems for large buildings. CAREYFOIL DESCRIPTION: Careyfoil is made from Corrugated As bestos Paper with a layer of aluminum foil adhered to the flat side only. This method of construction adds materially to its insulation value. Underwriters Approved: Material available upon request. SIZES: Careyfoil is furnished in 36" and 37" wide rolls, each containing 250 sq. ft. of material. APPLICATIONS: Careyfoil is used in the construction of low and medium heat ovens for residential and commercial use. It is also used with furnaces and hot water heaters. FOIL-FACED ASBESTOS PAPER DESCRIPTION: Foil-Faced Asbestos Paper consists of Commercial Asbestos Paper with aluminum foil adhered to one or both sides. One side foil paper is furnished in roll form, two side material is usually provided in sheets. SIZES: Foil-Faced Asbestos Paper is furnished in 36v cr 37' wide rolls. It can be ordered in 500 or 1,000 sq. ft. rc^s APPLICATIONS: Foil-Faced Asbestos Paper is used as insuiation and a lighting reflector for lighting fixtures, as in sulation for moderate temperature applications such as air conditioners, vending machines, radiators, baseboard heat ing units, etc. It is also a popular insulator for pipes and ducts. 3 Asbestos Millboard DESCRIPTION: Asbestos Millboard is made from Canadian asbestos fibre pulD mixed with binding materials and formed in sheets. Commercial Millboard is produced in two grades, No. 1 Haro and No. 7 Medium. No. 1 Grade withstands tem peratures up to 1000F., and No. 7 Grade withstands tem peratures up to 800F. These two grades satisfy the vast maiority of requirements. Special grades can be developed by Celotex laooratories. Asbestos Millboard with pin-point (knurled) finish can also be supplied. SIZES: Asbestos Millboard is furnished in 42* x 48* sheets in the following thicknesses: Thickness (Inchss) 1/16 5/64 3/32 1/8 5/32 3/16 1/4 5/16 3/8 1/2 5/8" 3/4" 1" Pounds* Por Shoot 4.1 5.1 6.2 8.3 10.3 12.4 16.5 20.6 24.8 33.0 39.0 44.5 66.5 Ouncss* _____Per Sq. Ft 4.7 5.8 7.1 9.5 11.8 14.2 18.9 22.9 28.3 37.7 44.6 50.9 76.0 * Typical weights. APPLICATIONS: Asbestos Millboard is used extensively in the eiectric heating field and glass industry. It may bt used in fire screens and partitions, as a lining for ceilings, walls, floors, elevator shafts, ranges, stoves, grates, electric ovens, sterilizers and roasters. Other typical applications for Asbestos Millboard include: Sheet glass lehr rolls Float glass conveyor rolls Gaskets Cores for metal-clad doors Stainless steel conveyor rolls Table and stove pads and mats Incinerators, home and commercial Heater and furnace lining Safe and strongbox lining Electric switch box lining Household appliances Kiln lining 4, ^ Product Application Form Your NameDate_________________________________ Comoany________________________________________________________________________________________________ Afloress C.tyState:-Zip---------------------------------------------------------------------------------------------Name of apDiication______ Type of material, if known.________ Quantity_________ ____________________ How often is this auantity purchased?---------------------------------------------------------------------------------------------------------------------------- DESIGN REQUIREMENTS: What is the intended use of the material?---- What conditions (temperature, exposure, impact, etc.) must the material withstand? What fluids or gases will material be exposed to? Please attach specification sheet, if available. $ART DESCRIPTION: 1. Rectangular sheets without holes: Give length____ , width. 2. Roll goods: Give outside diametercore diameter. ., thickness. tolerances. width. ., approximate weight per roll , thicknessdimensional tolerances 3. All other nonstandard parts: Attach sketches or prints, identified by part number: #. Dimensional toierances must be shown. PACKAGING: check all applicable boxes according to requirements: 1. Maximum gross weight allowed per unit package------------------------------------------------------------------------------------------- 2. On pallets? Returnable? Nonreturnable? 3. In cartons? 4. Other? Specify--------------------------------------------------------------------------------------------------------------------- SHIPPING INSTRUCTIONS: (include preference of carrier, if any.) OTHER INFORMATION: Die charge (if required). Should these charges be listed separately?. or included as part of the selling price?------------------------------------------------ Who is present supplier?------------------------------------------------------------------------ Give competitive product identification. Approximate price now being paid____ (FOLD. STAPLE AND MAIL) 5 FOLD H5=.E BUSINESS REPLY MAIL No postage necessary if mailed in United States Postage will be paid by THE CELOTEX CORPORATION 1500 NORTH DALE MABRY TAMPA, FLORIDA 33622 ATTN: INDUSTRIAL MARKETING DEPARTMENT FOLD HERE FIRST CLASS PERMIT =269 TAMPA. FLA. Specialty Asbestos and Organic Papers DESCRIPTION: Celotex produces a number of Specialty Asbestos and Organic Papers for a broad range of applica tions in varied Industries. Briefly these materials include: Asbestos Resin Saturating Paper -- A phenolic resin saturating type paper designed to be impregnated with thermo-setting resin. Saturated material is usually wrapped or ro`led. then heated to cure the resin and form a hard, heatresistant component. Asbestos Asphalt Saturating Paper -- Designed for use as a base for roofing ana dampproofing membrane by sat urating with roofing grades of asphalt and tar pitch. Asbestos Pipeline Wrapping Paper -- Reinforced with continuous filament glass fiber strands for high sheet strength. This material has many industrial uses in addition to its prin ciple aopiication as a corrosion-preventing pipeline wrap. Asbestos Paper, Inorganic Type -- A material with low organic fiber content to reduce smoke and odor emission. Asbestos Laminating Paper -- This product contains nat ural fiber for additional strength. It is specially formulated for use with galvanized steel pipe. Asbestos Muffler Paper -- This asbestos paper is in dented. or waffled, to provide greater overall caliper and flexibility. It is used widely in the automotive industry. Non-Flammable Protective Paper -- Thin, non-flam mable asbestos paper for use as a flame retardant in decora tive wall panfling. Asbestos Flooring Backer Sheet -- Latex bound asbes tos paper of the beater addition type which contributes resiliance. dimensional stability and durability to composite floor covering materia^^ Filter Felt -- Used as a filtering medium in automotive lubricating oil filters. Organic Flooring Felt -- Saturated with high quality as phalt and painted one side with a primer, this product is used by the flooring manufacturers as a base layer for enamel print flooring. Celotex Asbestos Gasket Materials -- Celotex manu factures a variety of gasket papers that are especially formu lated to meet demanding customer specifications. Typically these materials are made of asbestos fibers uniformly coated with synthetic rubber latices selected for specific require ments. They are resilient, non-corrosive, fungus resistant and dimensionally stable. CAUTION: Celotex specialty products contain asbestos fibers. Avoid creating dust. Breathing asbestos dust may cause serious bodily harm. 7 * 4- )UORTHERN DIVISION 64a PEARSON STREET DES PLAINEST ILLINOIS 60016 TELEPHONE: 3127298-1936 tannwfc pvooucn \ / THE CELOTEX CORPORATION TAMPA, FLORIDA 33622 * ^2/ mrv- -- . v 'i, y.. .JT'\ 'SOUTHERN DIVISION 1900 MAC ARTHUR BLVCL. N.W. r ATLANTA, GEORGIA 3001S TELEPHONE: 404/352-2128 rl Na lam PRINTED IA USA Commercial Asbestos* Asbestos Insulating* Paper and Rollboard Paper Specialties DESCRIPTION: Asces;cs Facer 3ra Raibca'c are zz~pcsea of Carao ar ascestcs `>cer co~cired with a sma ; quartity cf exr-e^eiy strong pmqirg maie'iai a sDeciaily-equiCceq cace'-~2' ng mac-tine rams :ne siumed components -me 'ctis Tre ~a;e'a s trc'Ougny qr;ea ana. finally caienae'so ;c a smeem `.n s~ Ascestcs Pacer ana Rcilbcarq are strong. flexib'e. f.re--es sta-: p-coucts sutace fcr vanes acc cat ons througnout maust-y Ascestcs Pacer ana Rcupcarc are or one type ana vary pn;> .n tn.excess ana wiqth of rciis Ascestos ace' Tace is ava-lacie in 2" and 3" woe rolls -- eac.n 8A *eet .eng. Tne Tape 'S mace frorr. stanaara f2-:b stock APPLICATIONS: Ascestos Pacer and Roiiboarc are sa;.s`actc-v `o- a great vane:, c* ourecses The 6 ana S-:b pace's may be -sea n tne manufacture of various insolations The tO an.c f 2- b oaoers nave ceen used for wrapping not air furnace pipes SIZES: Ascestos Pacer ana Rdlboard are furnished in stanbarc wiatnsof t8" 24" 36" ana 37' 2" Special sizes can be made to oraer. Standara we'gnts ana thicknesses of sneets are: CORRUGATED ASBESTOS PAPER DESCRIPTION: Corrugated Ascestcs Paoer oonssts of a snee: cf ascestos oacer, wmen has ceen oo"-gated `irmiy cemented tc a flat baenmg sneet of like mats'.a; 'he two sneets are joined by a su'tac.e adhesive. Corrugated Ascestos Pacer ,s a ve'y iignt ana !:e.<:c e `cm of nsuiat.cn. adactacie `or wrapping arcunc cu'vec solaces SIZES: Corrugated Ascestcs Paoer .s `um.s~sa n ooa'se cor rugations (V thiCK per piv) m 36" to 37" wice '0 is it can oe orcered .n 250 sq. ft. or 500 sq. ft. roils. APPLICATIONS: Corrugated Ascestos Pace' zan ce used wherever a Iignt and flexipie. yet efficient, msuiat ng material s 'eauired CAREYFOIL DESCRIPTION: Careyfoil is made from v" Corrugated Asbes tos Paper with a layer of aluminum foil adhered to the flat side only. This method of construction adds materially to ns insulation value. TYPICAL CHARACTERISTICS COMMERCIAL ASBESTOS ROLLBOARD We'gnt 3cur.os Tfiicuress 'nenes. Ncmmai Tensne Strengin. Drv Pounds Per inert W'in Grain Minimum Muiien Slrengtn.'* LDs eer nen Moisture. Per Gen Maximum 3/32" 18-52 094 35 32 3 1/8" 57-67 123 35 32 5 TYPICAL CHARACTERISTICS COMMERCIAL ASBESTOS PAPER 61b. 8lb. 101b. 121b. 141b. 161b. Weignt. gouncs oer 100 sa it. 5.5-6 5 7 5-8.5 9.3-10.7 11-12.6 13-15 15-17 Thickness lncr.es Nom 015 018 022 025 028 032 Tensile Strengin Dry PoundS/m. Witn G;aoe Mm 14 14 14 15 16 16 Mullen Strengin.*-* Pounds, m 10 11 12 12 14 14 Moisture. Percent 3 3 3 333 1/16"*+ 30-34 060-064 20 20 3 * Values are typical. Tests are not performed on routine Oasis. +t This material may also oe caiiea 116' Roiiboara Underwriters Classified: Material available upon request. SIZES: Careyfoil is furnished m 36" and 37" wide rolls, each containing 250 sq. ft. of material. APPLICATIONS: Careyfoil is used m the construction of fur naces for residential and commercial use. FOIL-FACED ASBESTOS PAPER DESCRIPTION: Foil-Faced Asbestos Paper consists of Commercial Asbestos Paper with aluminum foil adhered to one or both sides. One side foil paper is furnished m roll form, two side material is usually provided in sheets. SIZES: Foil-Faced Asbestos Paper is furnished in 36" or 37" wide rolls. It can be ordered in 500 or 1,000 sq. ft. roils. APPLICATIONS: Foil-Faced Asbestos Paper is used as insu lation and a ligntmg reflector for lighting fixtures, as insulation for moderate temperature applications. It is also -an insulator for pipes and ducts. UNDERWRITERS LABORATORIES INC* CLASSIFIED SHEATHING MATERIAL FIRE HAZARD CLASSIFICATION Flame Spread Fuel Contnbuted Smoke Developed 10 0 0 SEE UL CLASSIFIED BUILDING MATERIALS INDEX Asbestos * Millboard Specialty Asbestos* and Organic Papers DESCRIPTION: Asoes:cs Mnlbcarc is made `rom Ca asoesfcs `:i'e cu.c ^'xec .vm cmamg materials and formed m sneers. Cc--ismia. Vulbcaro s proauced m two grades. Mo. : Ha'd anc Me 7 Medium. Me 1 Grade withstands temperatures oc to *CCG;c anc Me 7 Grace withstands temceratures up to SOC:c T-ese two g-aces satisfy the vast maicnty of reauire"ents Soeo a graces can be develooea by Ceiotex iaooratc' es Asoestcs Millboard with pm-pomt (knurled) fimsn csr- a:sc cs SwCC'igc SIZES: Asce stos Mnibcara .s furnished m 42" x 48" sheets m the renewing thiCKnesses: TYPICAL CHARACTERISTICS COMMERCIAL ASBESTOS MILLBOARD Thickness Pounds-*' (Inches) Per Sheet 1 16 39 564 49 3.32 5.9 3 8 7.9 32 94 316 IT 8 1 4 15.8 .16 197 38 236 1.2 3i 5 5.8 37 6 3<t 45 2 1 60.2 Ounces*** Per Sq. Ft. 45 5.6 67 90 10.7 13.5 18.1 22.5 27.0 36.0 43 0 51.7 68.8 "'Typ,cai weignts. ^'^Avanaote in laminated form on a special order Oasis only. APPLICATIONS: Asbestos Millboard is used extensively in the eiectric heating field and glass industries. DESCRIPTION: Celctex produces a number cf Scec.a ty As bestos anc Organic Pacers for a broac range of accucations r ared industries 3r;etly these materials mciude Asbestos Resin Saturating Paper -- a pnenc; c resin saturating type paper cesigned to oe impregnated with tr.ermosert.ng resm. Saturated material 'S usually wraccec or roi'eo then heated to cure the resin and form a hard, neat-'es stan.t component. Asbestos Asphalt Saturating Paper -- Designed for use as a Case for roofing and damporoofing memorane by saturating witn roofing grades of asphalt and tar pitch. Asbestos Paper, Inorganic Type -- a material witn iow organic fiber content to reduce smoke and occr emission Asbestos Laminating Paper -- This product contains natural fiber for additional strength. It is soecially formulated for use with galvanized steel pipe. Asbestos Muffler Paper -- This asbestos paper is indented, or waffled, to provide greater overall caliper and flexibility, it is used widely in the automotive industry. Filter Felt -- Used as a filtering medium in automotive lubricat ing oil filters. Flooring Felt -- Saturated with high quality asphalt and painted one side with a primer, this product is used by the flooring manufacturers as a base layer for enamel print floor covering. Characteristics, properties, or performance of materials or systems nere'n described are cased on data obtained under controlled test conations. Ceiotex maxes no warranties, expressed or implied, as to their characteristics, properties, or performance under any variations from suen conditions .n actual construction.The Ceiotex Corporation assumes no responsioihty for the erfects of structural movement. Ceiotex Asbestos Gasket Materials -- Ceiotex manufac tures gasket papers that are especially formulated to meet cus tomer specifications. Typically these materials are made d as bestos fibers uniformly coated with synthetic rubber lat tes selected for specific requirements, they are resilient, noncorrosive, fungus resistant and dimensionally stable. 'WARNING These products contain asbestos fiber. The Occupational Safety and Health Administration (OSHA), an agency of the United States Government, believes that repeated inhalation of asbestos fiber Is a health hazard and may cause various diseases including cancer and asbestoeis. FOR ADDITIONAL INFORMATION CONTACT YOUR NEAREST CELOTEX REGIONAL OFFICE. -:*** Viy^y k :;;v ^* fc*` y \\ Y Y ' " ::-? ' .fv:V: v ,''; "'"y^.'-MZ / ' *; ' '' .: .' '' ' - . : . v K.` r /'a- :;^;' r;- ; i_-7%. V>':'-.iV.' ' `l :!:;V-; ',. ^ > ;..r-: . -i _ ..' 5 ; '' . ' , -' ' ,1 < - r-- :' .' .'.; -w } --* r<>-.r"- ; -ft * '-A.; -1 ,1_ ' >' 1 ..) \ ':' .,.i:- " .V '< t / `t\.\ *f -; % ;:-v', .' ' . . > . jy- y- Jy j. .H y'y ^ . r\-"*- r * NORTHERN DIVISION y64d PEARSON STREET ' OES PLAINES, ILLINOIS 60016 -TELEPHONE; 3127290-1936 FORMNO. 1070 Rw 7)77 THECELOTEX CORPORATION TAMPA, FLORIDA 33622 a jmnQaltercampany SOUTHERN DIVISION 1900 MACARTHUR BLVD, N.W ATLANTA, GEORGIA 30016 TELEPHONE 404/352-2126 ' SWWTEDWUSA G0 otemp$ 1500 Insulation > * CELOTEMP 1500 insulation is the latest development in industrial insulations from Celotex. It combines the chemical ana moisture resistance properties so important to industrial users, with impact resistance superior to any of its predeces sors. to provice an ideal insulation for high temperature picmg and equipment. CELOTEMP 1500 insulation contains no asbestos, so prob lems with OSHA regulations regarding the use of asbestos are eliminated. CELOTEMP 1500 insulation is made of expa.nced perlite, with millions of individual vitrified air cells bonaed together by special binders and reinforcing which resist moisture penetration and increase impact resistance. The increased resistance to crumbling and reduced break age facilitates installation and yields a longer lasting job. CELOTEMP 1500 possesses these properties which make it a umaue insulating matenal: Will not appreciaoly lower the auto ignition temperature of ethylene oxide-air mixtures. 'Can withstand face temperatures up to 1500F.t and maintain linear shrinkage of less than 2%. "Non wicking -- will not absorb large quantities of flamma ble liquids -- absorbs less than 7% as much water (by weight) as calcium silicate high temperature insulation. Helps to protect insulated equipment from external fires. 'Contains no lime, and thus will not contribute to the corro sion of aluminum jacketing. 'Contains less than 150 ppm chloride, does not contribute to corrosion of austenitic stainless steel. "Weighs approximately 20% less than most calcium sili cate high temperature insulations. All of these properties make CELOTEMP 1500 well suited to a variety of applications in process piping, refractory use and in chemical plants, refineries and power generating installations. CELOTEMP PREMOLDED ELBOW INSULATION To insure total insulation throughout the system, the use of CELOTEMP premolded elbows is recommended. Pre molded elbows help to eliminate voids and mitering seg ments, which helps reduce installation time and cost. Physical Properties' Temperature limits .................................. Maximum 1500F Continuous 15003F Cyclic 15005F Density (dry) ..................................................10-13 Ibs'cu. ft. Compressive strength..................... 5% deformation 90 psi. Linear shrinkage (percent) 1200F. for 24 hours......................................................... 70 1500F. for 24 hours..................................................... 1.60 Water absorption (percent) By volume 5 90% relative humidity 4 weeks............. 1.30 By volume, immersed 24 hours .............................. 2.7 Acid resistance (after 24 hours immersion) 25% sulfuric or hydrochloric acid ...................... No effect 100 ZOO 300 400 S00 600 Mean Temperature, degrees F 700 A.S.T.M. Specification ................................ C-610-67 tAll tests conducted according to standard ASTM test methods. CELOTEMP elbows are available in many iron pipe and copper tubing sizes in thick nesses to match adja cent insulation. Iron pipe sizes range from Vs" to 20" and thicknesses from 1 " to 4". Elbow fittings are also avail able for steam tracing purposes. 2 Standard Sizes Copper tubing - V, IV'. 1 V\ 2V, 3V O.D. half sections Iron pipe - V through 24" IPS. half sections Thickness -1" through 3V, single layer Segmental - 12%'' wide curved sections through 60" O.D. Block insulation: Standard widths - 6", 12". and 24" Standard length - 36" Standard thickness -- 1 Vs" through 5", in Vs" increments. Asbestos-Free MW-One Insulating Cement MW-One is a combination insulating and finishing cement for temperatures up to 1Q0QF. Celotex mineral wool pellets and other ingredients, including rust inhibitor, are combined to form this monolithic, all-purpose, fast-setting finish cement that insulates as well as protects. MW-One is used for valves, fittings, tanks, ovens, hot air ducts. It can be aoolied directly over any insulation or it can be used as a finishing cement for MW-50. Furnished in multi-wall 50-lb. paper bags. Thermal conductivity: At 200'F. -.86. Asbestos-Free MW-50 Insulating Cement MW-50 Cement is a complete insulating material in itself. Special MW-50 nodular mineral fibers are combinea with bonding materials and a rust inhibitor to produce a mixture with excellent physical and thermal properties. MW-50 Cement is an excellent monolithic insulation for valves, fittings, expansion joints, heaters, exchangers, ac cess doors, water tube boiler walls, tanks, stills, drumheads and other heated equipment operating at temperatures up to 1800'F. It is particularly recommended for irregular surfaces. Furnished in multi-wall 50-lb. paper bags. Thermal conduc tivity: At 2Q0CF. -- .54 Fibrous Adhesive (Bonding)t Fibrous Adhesive is a fibrous plastic cement of thin troweling or brushing consistency composed of asbestos fibers, sili cate of soda and filler materials. It is designed for laying up insulating blocks and making fittings. It makes a very strong heat-proof bond that is unaffected by temperatures up to 800F. Furnished in 1 -gal. cans. 5-gal pails and 54-gal. drums. Thermotex-Bt Thermotex-B is a breathing-type weather-resistant coating for temperatures up to 200F. It is a combination of asbestos Insulation Seal is a ready mixed asbestos fibrated bitumi nous mastic. It is especially compounced for cold application over most types of insulating materials. It protects the insula tion against damage and loss of efficiency by the penetra tion of water and water vapor. Made in spray or trowel consistency. Insulation Seal can be used on pipes, curved and flat surfaces of all kinds.. It will hold its bond on horizontal, vertical, sloped or inverted surfaces Designed for aopiication over insulation such as asbestos cement, rock wool base cements, cellular glass, fiberglass, mineral wool blan kets. It is specially recommended for systems operating at temperatures below dew point, dual temperature systems (200'F. maximum surface temperature), and systems sub ject to long shut-down periods. Furnished in 1-gal. cans. 5-gal. pails. 54-gal. drums. No. 51 Emulsion No. 51 Emulsion is composed of asphalt, water and bento nite clay, with troweling consistency. May be used as a prime and bond coat for insulation and cold storage vault and other low temperature insulated construction, as well as for temp eratures up to 200CF. Mixes well with asbestos fiber and sand to make "on-thejob' finished coats. Furnished in 5-gal. pails and 54-gal. drums. Fireclad Jacketingt Fireclad Jacketing is a durable, weather-resistant jacketing specifically designed for the protection of outdoor pipe lines where the danger of fire must be minimized. Celotex Fireclad consists of a tough, substantial sheet of asphalt-saturated asbestos felt, over which is cemented on one side an unsatu rated asbestos sheet. The complete sheet is reinforced with a fabhc of tough, flexible glass threads. Fireclad Jacketing fibers, emulsified asphalt and mineral stabilizers. Forms a cold plastic water-resistant coating which is applied by trowel. Thermotex-B is recommended as a durable coating for insulation on hot equipment, ducts, vessels, breechings, tanks, towers, heat exchangers and fittings that are sub jected to weather conditions. It is especially suited for oil and chemical plant use because it resists acid and alkaline condi tions and can be installed over insulation that is not com pletely dry. After application over moist insulation, Thermotex-B allows the trapped water vapor to escape while remaining impervious to surface water. Furnished in 5 gal. pails and 52 gal. drums. will not drip asphalt in the presence of fire and is highly resistant to combustion. Furnished in approximately 50 lb. rolls 36" wide by 36' long, containing 108 sq. ft tWARNING This product contains asbestos fiber. The Occupational Safety and Health Administration (OSHA), an agency of the United States Government, believes that repeated inhala tion of asbestos fiber is a health hazard and may cause various diseases including cancer and asbestosis. The Celotex Corporation 3 tractenstics. precedes. or performance of ^ma:er:a!S or sys:ems nerem describee are cased on data obtained unaer controlled test conations. Ceictex .maxes no warranties, expressed or im plied as to tneircharacterstics. prooemes. or per formance oncer any variat ors from sucn condi tions :n actual construction. The Ceiotex Corpora tion assumes no respcnsioiiity for the effects of structural movement. INDUSTRIAL PRODUCTS incjsirai Saies Oeoartmeni (813) 871-4575 THE CELOTEX CORPORATION TAMPA. FLORIOA 33622 a Jim (falter company CELOTEMP 1500 insulation is the latest development in inaustnal insulations from Celotex. It combines the chemical and moisture resistance properties so important to industnal users, with impact resistance superior to any of its predeces sors. to provide an ideal insulation for high temperature piping and equipment. CELOTEMP 1500 insulation contains no asbestos, so prob lems with OSHA regulations regarding the use of asbestos are eliminated. CELOTEMP 1500 insulation is made of ex panded perlite, with millions of individual vitnfied air cells bonded together by special binders and reinforcing which resist moisture penetration and increase impact resistance. The increased resistance to crumbling and reduced break age facilitates installation and yields a longer lasting job. CELOTEMP 1500 possesses these properties which make it a unique insulating material: "Will not appreciably lower the auto ignition temperature of ethylene oxide-air mixtures. "Can withstand face temperatures up to 1500T., and maintain linear shrinkage of less than 2%. 'Non wicking - will not absorb large quantities of flamma ble liquids -- absorbs less than 7% as much water (by weight) as calcium silicate high temperature insulation. Helps to protect insulated equipment from external fires. "Contains no lime, and thus will not contribute to the corro sion of aluminum jacketing. 'Contains less than ISO ppm chloride, does not contribute to corrosion of austenitic stainless steel. "Weighs approximately 20% less than most calcium sili cate high temperature insulations. All of these properties make CELOTEMP 1500 well suited to a variety of applications in process piping, refractory use and in chemical plants, refineries and power generating installations. CELOTEMP PREMOLDED ELBOW INSULATION To insure total insulation throughout the system, the use of CELOTEMP premolded elbows is recommended. Pre molded elbows help to eliminate voids and mitering seg ments. which helps reduce installation time and cost CELOTEMP elbows are available in many iron pipe and copper tubing sizes in thick nesses to match adja cent insulation. Iron pipe sizes range from Vi" to 20" and thicknesses from 1" to 4". Elbow fittings are also avail able for steam tracing purposes. Physical Properties' Temperature limits .................................. Maximum 15G0T Continuous 1500'F Cyclic 15CCTF Density (dry) ................................................. 10-13 Ibs/cu. ft. Compressive strength.....................5% deformation 90 psi. Linear shrinkage (percent) 1200F. for 24 hours......................................................... 70 1 SOOT, for 24 hours......................................................1.60 Water absorption (percent) By volume (a 90% relative humidity 4 weeks............. 1.30 By volume, immersed 24 hours ................................ 2.7 Acid resistance (after 24 hours immersion) 25% sulfuric or hydrochloric acid......................... No effect 100 200 300 400 500 600 700 Mean Temperature, degrees F A.S.T.M. Specification ................................ C-610-67 'AH testa conducted according to standard ASTM test methods. Standard Sizes Copper tubing - W, IV'. 1%", 2W, ZW O.D. half sections Iron pipe -- V" through 24" IPS, half sections Thickness -- 1" through 3Vi", single layer Segmental --12%" wide curved sections through 60" O.D. Block insulation: Standard widths - 6", 12", and 24" Standard length - 36" Standard thickness -- 1 Vi" through 5", in Vi" increments. /977 / ' / ' Dsments and Adhesives Asbestos-Free MW-One Insulating Cement MW-One is a combination insulating anc finishing cement for temperatures up to lOOC'F. Ceictex mineral wool peilets and other mgreaients. mciucinc rust nncitor, are comfcmea to form this monolithic, all-purccse. fast-senmg finish cement that insulates as well as orctects. MW-One is used for valves, fittings, tanks, ovens, hot air ducts. It can be applieo directly over-any insulation or it can be used as a fimsnmg cement for MW-50. Furnished in multi-wall 50-ib. paoer bacs. Thermal conductivity: At 200'F. -.86. Asbestos-Free MW-50 Insulating Cement MW-50 Cement is a complete insulating material in itself. Special MW-50 nodular mineral fibers are combined with bonding materials and a rust inhibitor to produce a mixture with excellent physical and thermal properties. MW-50 Cement Is an excellent monolithic insulation for valves, fittings, expansion joints, heaters, exchangers, ac cess doors, water tube boiler walls, tanks, stills, drumheaas ana other heated equipment operating at temperatures up to 1800F. It is particularly recommenaed for irregular surfaces. Furnished in multi-wall 50-lb. paper bags. Thermal conduc ^titvivity: At 200F. -- .54 hibrous Adhesive (Bonding)* Fibrous Adhesive is a fibrous plastic cement of thin troweling or brushing consistency composed of asbestos fibers, sili cate of soda and filler materials. It is designed for laying up insulating blocks and making fittings. It makes a very strong heat-proof bond that is unaffected by temperatures up to 800CF. Furnished in i -gal. cans. 5-gal pails ano 54-gal. drums. Protective Coatings Thermotex-Bt Thermotex-B is a breathing-type weather-resistant coating for temperatures up to 200F. It is a combination of asbestos fibers, emulsified asphalt and mineral stabilizers. Forms a cold plastic water-resistant coating which is applied by trowel. Thermotex-B is recommended as a durable coating for insulation on hot equipment, ducts, vessels, breechings, tanks, towers, heat exchangers and fittings that are sub jected to weather conditions. It is especially suited for oil and chemical plant use because it resists acid and alkaline condi tions and can be installed over insulation that is not com pletely dry. After application over moist insulation. Thermotex-B allows the trapped water vapor to escape while remaining impervious to surface water. Furnished in 5 gal. l pails and 52 gal. drums. Insulation Seal* Insulation Seal is a reacy mixed asbestos fibrated bitumi nous mastic. It is especially compcunoec for cold aoplication over most types of insulating materials It protects tne insula tion against damage and loss of efficiency by the penetra tion of water and water vapor. Mace >n spray or trowei consistency. Insulation Seal can be used on Dipes. curved and flat surfaces of all kinds.. It will hold its bond on horizontal, vertical, sloped or inverted surfaces.Designed for aooiication over insulation such as asbestos cement, roc* wool base cements, cellular glass, fiberglass, mineral wooi blan kets. It is specially recommenaed for systems operating at temperatures below dew point, dual temperature systems (200"F. maximum surface temperature), and systems sub ject to long snut-aown periocs. Furmsneo in 1-cai. cans. 5-gal. paiis. 5^-gai. arums. No. 51 Emulsion No. 51 Emulsion is ccmposea of asonalt. water and bento nite clay, with troweling consistency. May be useo as a prime and bond coat for insulation and cold storage vault and other low temperature insulated construction, as well as for temp eratures up to 200F. Mixes well with asbestos fiber and sand to make `on-thejob ' finished coats. Furmsned in 5-gal. pails ana 54-gal. drums. Insulation Jacketing Fireclad Jacketing* Fireclad Jacketing is a durable, weather-resistant jacketing specifically designed for the protection of outdoor pipe lines where the danger of fire must be minimized. Celotex Fireclad consists of a tough, substantial sheet of asphalt-saturated asbestos felt, over which is cemented on one side an unsatu- *t rated asbestos sheet. The complete sheet is reinforced wittv a fabric of tough, flexible glass threads. Fireclad Jacketing will not drip asphalt in the presence of fire and is highly resistant to combustion. Furnished in approximately 50 lb. rolls 36" wide by 36' long, containing 108 sq. ft. +WARNING This product contains asbestos fiber. The Occupational Safety and Health Administration (OSHA). an agency of the United States Government, believes that repeated inhala tion of asbestos fiber is a health hazard and may cause various diseases including cancer and asbestosis. Characteristics, properties, or performance of materials or systems herein described are based on data obtained under controlled test conditions. Celotex makes no warranties, expressed or im plied. as to their characteristics, properties, or per formance under any variations from such condi tions in actual construction. The Celotex Corpora tion assumes no responsibility for the effects of structural mo vement. THE CELOTEX CORPORATION TAMPA. FLORIDA 33622 IUUOINO MOOUCTS ^ a Jimvjalter company U-`: _i' > 4^2 * ' ' ?.-t '-y y\-v-''l^: y . ,.-: . V- ....- :rs. yy:V: ;;>'; . ;-..i,.. - . -* -------------' . . . c -. . -.* <T ~ - .. ;.. . ' . . .. . . . . -' - f ' ^*:? vj>,.r- y c':y- -r^-i - ' ;/ .. ...% .i> ' y-i ..y . -r;--y:~y ^ < zSk -< % :.y. v... ^ ^r* ^ . . v- y?* *. <i > . ?.;... ' .,.> .*.; - . 4 . *> - - ' -_- ", >" '-?? y* - -' ^ - v- , y ;rwV'`/v^ V.-y ; ; ' ^/y. "'/ ` , \' *,-. :y : -- r yy '-, - ". ^ V- ' ." y ---y yy *-y ; ;*?._ ;,vr- 'J / ' -y - ;Vr Z1" . -V-* -. .. ..:. - ^'..'-' y Cr -- / ,,.. : .; , Vv r. -. '' .: v . ...-: :,.-. jv.'**-.-.-^.- . V-.i: .- .r. :. .; ** . . .* v.... '..''' .^./ ry.v . ' . .- k;v: - v.`:y/-yyy:7y.y'_* ^ :i; .. %t . i\ -' ': - .... .'i - * . - *. , 1--.. " ^ yy -: industrial is,.;; Insulation * *-;> & ff,. - * ? k. . 4* . 'i~x - I si Products . Celctemp1500 High Temperature Pipe and Block Insulation CELOTEMP 1500 is a molded rigid high temperature insula tion.maae of expanded perlite, witn millions of inaividuai vitnfied air cells bonded together by soeciai binders and reinforc ing fibers. This patented Drocess combines the chemical and moisture resistance properties so important to industrial users. CELOTEMP 1500 is a superior, ligntweight high temperature pipe and block insulation recommenaed for use in power generating and process inaustnes on inaoor and outdoor pipes, vessels and eauioment operating continuous or cyclical at temperatures to 1500F. CELOTEMP 1500 possesses these properties which make it a unique insulating material: 'Will not aopreciably lower the auto ignition temperature of ethylene oxiae-air mixtures. Can withstand face temperatures up to 1500F.. and main tain linear shrinkage of less than 2%. Non wicking--will not absorb large quantities of water-- absoros less than 7% as much water (by weight) as cal cium silicate high temoerature insulation. 'Helps to protect insulated equipment from external fires. 'Contains no lime, and thus will not contnbute to the corro sion of aluminum. 'Contains less than 150 ppm chloride, does not contribute to stress corrosion of austenitic stainless steel. 'Weighs approximately 20% less than most calcium silicate high temperature insulations. All of these properties make CELOTEMP 1500 well suited to a variety of applications in process piping, refractory use and in chemical plants, refineries and power generating installations. CELOTEMP PREMOLDED ELBOW INSULATION To insure total insulation throughout the system, the use of CELOTEMP premolded elbows is recommended. Premolded elbows help to eliminate voids and mitenng segments, which helps reduce installation time and cost. CELOTEMP elbows are available in many iron pipe and copper tubing sizes in thicknesses to match adja cent insulation. Iron pipe sizes range from Vj'' to 20" and thicknesses from 1" to 4". Elbow fittings are also available for steam tracing purposes. Physical Properties' Temoerature limits....................................... Maximum 15C0=F Continuous 150CTF Cyclic 1500F Density (dry) ...................................................10-13 ibs. cu. ft. Compressive strength ...................... 5% deformation 90 psi. Lnear shrtnKage (percent) 1200R for 24 hours....................................................... 60 1500F. for 24 hours .......................................................1.50 Water acsorption (percent) By volume @ 90% relative numidity 4 weeks ............. 1 30 By volume, immersed 24 hours................................... 2.7 Acid resistance (after 24 hours immersion; 25% sulfuric or nydrocnlcric acid.......................... No effect 100 200 300 400 500 600 700 Mean Temperature, degrees F A.S.T.M. Specification...........................................C-610-67 All tests conducted according to standard ASTM test methods. Standard Sizes Pipe insulation--Vi" through 24" IPS, half sections Thickness--1" through 3", single layer Segmental--12%" wide curved sections through 60" O.D. Block insulation: Widths--6", 12", and 24" Length--36" Thickness--IVi" through 4", in Vi" increments. Mineral Fiber insulation IMF products are composed of high temperature mineral fiber bonded together with specially formulated binders. IMF-1900Block provides a temperature limit of 1900`F. The product is available in thicknesses ranging froml" to 4" in Vi" increments; width: 6", 12" and 24"; length: 18" and 36". F-1200 Block is recommencec for use to 120CF. This nonygroscopic procuct is prccucec in 12" x 36" and 24" x 36" zes in 1", IVj" and 2" thicknesses. F-1400 Blanket is bonded together with a very iow content of bmaer producing a flexible resilient insulation for use over practically any surface at temperatures up to 14C05F. Standard sizes: Thickness: 1" to 4" in 'V increments with single layer construction. Faced styles can be supplied with multiple laver construction to achieve greater tnicxness. Width: 24" Length: 48" and 96" IMF-1050 Board is available m 6. 3 or 10 lb. density for use on heated equipment ooerated at femceratures uo to 1050F. Available in 24" x48" sizes with tmcxnesses froml" to4" in Vi" increments. Cements and Adhesives MW-One Insulating and Finishing Cement Asbestos-Free MW-One is a combination insulating and finishing cement for temperatures up to 1000F. Celotex mineral wool pellets and other ingredients, including rust inhibitor, are comoined to form this monolithic, all-purpose, fast-setting finish cement that in sulates as well as protects. MW-One is used for valves, fittings, tanks, ovens, hot air ducts. It can be aoplied directly over any insulation or it can be used as a fimsnmg cement for MW-50. Furnished in multi-wall 50-lb. paper bags. Thermal conductivity: At 200F.--.86. MW-50 Insulating Cement Asbestos-Free MW-50 Cement is a complete insulating matenal in itself. Special MW-50 nodular mineral fibers are combined with bonding materials and a rust inhibitor to produce a mixture with excellent pnysical and thermal properties. MW-50 Cement is an excellent monolithic insulation for valves, fittings, expansion joints, heaters, exchangers, access doors, water tube boiler walls, tanks, stills, drumheads and other heated equipment operating at temperatures up to 1800F. It is particularly recommended for irregular surfaces. Furnished in multi-wall 50-lb. paper bags. Thermal conductiv ity: At 200F.--.54. Fibrous Adhesive (Bonding)t Fibrous Adhesive is a fibrous plastic cement of thin troweling or brushing consistency composed of asbestos fibers, silicate of soda and filler materials. It is designed for laying up insulat ing blocks and making fittings. It makes a very strong heat proof bond that is unaffected by temperatures up to 800F. Furnished in 1-gal. cans, 5-gal. pails and 54-gai. drums. Protective Coatings Thermotex-B* Thermotex-B is a breathing-type weather-resistant coating for temperatures up to 2005F. it is a comcination cf asbestos fibers, emulsified asDhalt and mineral stabilizers. Forms a cold plastic water-resistant coating whicn is applied by trowel. Thermotex-B is especially suited for oil ana cnemical piant use because it resists acid and alkaline conditions and can be installed over insulation that is not completely dry. After appli cation over moist insulation, Thermotex-B allows the trapoed water vaoor to escape while remaining impervious to surrace water. Furmsned in 5 gal. pails and 52 gal. drums. Insulation Seal* Insulation Seal is a ready mixed asbestos fibrated bituminous mastic. It is especially compounded for coid aoplication over most types of insulating matenals. It protects the insulation against damage and loss of efficiency by the penetration of water and water vapor. Insulation Seal will hold its bond on horizontal, vertical, slowed or inverted surfaces. It is specially recommended for systems operating at temperatures below dew point, dual temperature systems (200F. maximum surface temperature), and systems subject to long shut-down periods. Furnished in 1-gal. cans, 5-gal. pails. 54-gal. drums. Insuiation^acketing Fireclad Jacketingt Fireclad Jacketing is a durable, weather-resistant jacketing specifically designed for the protection of outdoor pipe lines where the danger of fire must be minimized. Ceiotex Fireclad consists of a tough, substantial sheet of asphalt-saturated asbestos felt, over which is cemented on one side an unsatu rated asbestos sheet. The complete sheet is reinforced with a fabric of tough, flexible glass threads. Fireclad Jacketing will not drip asphalt in the presence of fire and is highly resistant to . combustion. Furnished in approximately 50-lb. rolls 36" wide by 36' long, containing 108 sq. ft tWARNING This product contains asestos fiber. The Occupational Safety and Health Administration (OSHA), an agency of the United States Government, believes that repeated inhalation of as bestos fiber is a health hazard and may cause various dis eases including cancer and asbestosis. t ________________ , Commercial Asbestos* Asbestos Insulating* wT Paper and Rollboard Paper Specialties DESCRIPTION: Ascestcs Pacer ara Pcnbca'a ars comccsec c: Ca^ac an ascestcs fiber comcmed with a s~a > cuanfty of extreme'y strong pircmg marshal A scac-a* y-ecuiccea cace'-'^a-'.-ng machine turns me slurred ccmcc-ems mo rolls 7ne "-atenai :s mercugn'v ced anc. flna-y. caier'ce'rd to a s~ccm r -e- Ascestcs Pace' arc Pdibcard are strong. -'exicie t're-'es star: c-cc-dts sutace 'c* va-ed acc-ca: ons mrcugnCui mCuStry Ascestcs Pace' ar.a Poiiboard are of one tyoe ana va^y oniy m tr.cxness a^a wicm of rciis. Ascestcs Paoer face >s avakabie m 2" ana 3" wide 'oils -- eacn 5A -ee: eng The Tace s mace `rem stancarc t2-b. stccK. APPLICATIONS: A sbestes Paoer ana Rollboard are satisfac tory for a g'eat variety ot purposes The 6 ana 8-:b pacers may be used m the manufacture of various insulations. The 10 and 12-lb. paoers have been used for wrapping hot air furnace pipes. ft SIZES: Asbestos Paper and Rollboard are furnished in stan- y dara widths of 18". 24". 36"and37'/2" Special sizes can be made to order. Standard weignts ana thicknesses of sheets are: TYPICAL CHARACTERISTICS COMMERCIAL ASBESTOS ROLLBOARD 3/32" 1/8" Weigm 3ounos 48-52 57-67 Thicxness. Irenes. Nominal .094 123 Tensue Strenctn Drv Pounds Per men With Grain Minimum 35 35 Mullen Strengtn.** LAs. oer men 32 32 Moisture. Per Cent. Maximum 35 TYPICAL CHARACTERISTICS COMMERCIAL ASBESTOS PAPER 61b. 8lb. 10 lb. I2lb. 141b. 161b. 1/16"t+ Weignt. oounos oer I00sd.lt. 5.5-65 75-8.5' 93-10.7 11-12.6 13-15 15-17 30-34 Thickness Incnes Nom . 015 018 022 025 .028 .032 060-064 Tensile Strength Dry Poundsrin. With Grade Min. 14 14 14 15 16 16 20 .. Mullen Strength** Pounds in. 10 11 12 12 14 14 20 Moisture. Percent 3 3 3 333 3 " Values are typical. Tests are not performed on routine Oasis. ** This material may also Oe caned in6"Rollboard CORRUGATED ASBESTOS PAPER DESCRIPTION: Co rrugated Ascestcs Pacer corsets of a sheet of asbestos caper, which ras been corrugated, firmly cemented to a hat Pacing sneet of like ~a;er'ai Tne Two sheets are ,omed by a suitable adhesive Corrugated Asbestos Pacer <s a very iigrt ana `lexifc.e `erm cf insulation, acactade for wraccmg arcunc curved surfaces SIZES: Corrugated Ascestos Pacer s fumisnec n coarse cor rugations (Vi* thick per oiyj m 36" tc 37" wide rciis. '! can be oraerea in 250 sq. ft. or 500 sq. ft. rolls. APPLICATIONS: Co rrugated Asbestos Pacer can ce used wherever a light and flexible, yet efficient, insulating material is required. CAREYFOIL DESCRIPTION: Careyfoil is made from V*"Corrugated Asbes tos Paoer with a layer of aluminum foil adhered to the flat side only. This method of construction adds materially to its insulation value. Underwriters Classified: Material available upon request. SIZES: Careyfoil is furnished in 36" and 37" wide rolls, each containing 250 sq. ft. of material. APPLICATIONS: Careyfoil is used in the construction of fur naces for residential and commercial use. FOIL-FACED ASBESTOS PAPER DESCRIPTION: Foil-Faced Asbestos Paper consists of Commercial Asbestos Paper with aluminum foil adhered to ore or both sides. One side foil paper is furnished m roll form, two side material is usually provided in sheets. SIZES: Foil-Faced Asbestos Paper is furnished in 36" or 37" wide rolls. It can be ordered in 500 or 1.000 sq. ft. rolls. APPLICATIONS: Foil-Faced Asbestos Paper is used as insu lation and a lighting reflector for lighting fixtures, as insulation for moderate temperature applications. It is also an insulator for pipes and ducts. UNDERWRITERS LABORATORIES INC* CLASSIFIED SHEATHING MATERIAL FIRE HAZARO CLASSIFICATION Flame Spread Fuel Contributed Smoke Developed 10 0 0 SEE UL CLASSIFIED BUILDING MATERIALS INDEX (elofex Asbestos* Millboard Specialty Asbestos* and Organic Papers DESCRIPTION: -sces:cs M ooard 'S mace from Carac an asoestcs f.ber puip --ixec vv:r pmamg materials and formed n sheets Commerc.a. Vuiccara s crccucea m two grades. Mo 1 Ha*c ana Me. 7 Vec cm. Me * Grace withsta.ncs temoe'atcres up to tCC0:c ana Me 7 G'ace witnstanas temperatures uc to SCCTr ~_ese two g-aces sat.sfv the vast majority of recuiremerts Scec.a; graces car oe ceveiocec by Ce'otex lacoratcr.es Ascestcs Muibcara with pin-pomt (knuriec) `misn car. aisc oe scop ec SIZES: A scestcs Millboard .s furnisned m 42" x 48" sheets m the `cucwir.g triCKnesses: TYPICAL CHARACTERISTICS COMMERCIAL ASBESTOS MILLBOARD Thickness Pounds*" (Inches) Per Sheet 1.16 5.64 3 32 i3 5 32 316 1,4 5.16 38 i2 58 3.4 +++ 1 tt+ 3.9 49 5.9 79 9.4 11.8 15.8 19 7 23 6 31 5 37 6 45.2 602 Ounces*" Per Sq. Ft. 45 5.6 6.7 90 10.7 13.5 18.1 225 27.0 36.0 43.0 51.7 68.8 `"Typical weignts. *'^Available m lammatea form on a special order basis only. APPLICATIONS: Asbestos Millboard is used extensively the eiectric heating field and glass industries. DESCRIPTION: C e.ctex produces a numcer or Scec.au> As bestos anc Organ c Pacers for a croac range of accucat crs n varied macstres Briefly these matenais ,nc;uce. Asbestos Resin Saturating Paper -- A or.enonc res.n saturating type pace: ces.gr.ec to oe impregnated <v;tr tr.ermcsetting resm Saturated materia: is usually wrapped or relied, men neatec to cu*e the *es:r arc form a ~a'd ''eat-'es,star: comoonent. Asbestos Asphalt Saturating Paper -- Des crec `or ^se as a oase for roofing ana aamoproofing memprare cy sat-rat.ng with rooting grades of asonalt ana tar pitch. Asbestos Paper, Inorganic Type -- A material with low organic fiber content to reduce smoke and odor emission. Asbestos Laminating Paper -- This product contains natural fiber for additional strength. It is specially formulated for use with galvanized steel pipe. Asbestos Muffler Paper -- This asbestos paper is indented, or waffled, to provide greater overall caliper and flexibility It's used widely m the automotive industry. Filter Felt -- Used as a filtering medium in automotive lubricat ing oil filters. Flooring Felt -- Saturated with high quality asphalt and painted one side with a primer, this product is used by the flooring manufacturers as a base layer for enamel print floor covering. Characteristics, properties, or performance of materials or systems nerem aescribeP are cased on data obtained under controlled test conations. Celotex maxes no warranties, express or implied, as to their characteristics, properties, or performance under any variations from sucn conations -n actual construction The Celotex Corporation assumes ho responsibility for the effects of structural movement. Celotex Asbestos Gasket Materials -- Celotex manufac tures gasket papers that are especially formulated to meet cus tomer specifications. Typically these materials are made of as bestos fibers uniformly coated with synthetic rubber latices selected for specific requirements. They are resilient, nor.corrosive. fungus resistant and dimensionally stable. 'WARNING These products contain asbestos fiber. The Occupational Safety and Health Administration (OSHA), an agency of the United States Government, believes that repeated inhalation of asbestos fiber is a health hazard and may cause various diseases including cancer and asbestosis. FOR ADDITIONAL INFORMATION CONTACT YOUR NEAREST CELOTEX REGIONAL OFFICE. -'V- : -. ^ ; - '; :* ; . i- ' - .. . "' ; ' .. r . : - ' V-;. ;'*' ' V ** "i..."*. * .... - 7, - T*VJ y^y ;.'-i - *' t ' *;. . <> . S- r. -4-.i-.v..v..' .. '=' - -.. .... 1 :'. X. r, ' *;: >V *S ri'.. >. J:,, * : '. ;, ^ V-' ' ' ' t' , . "T > .f t :. ,r -s'-.. '> > . ; V; * j'. ' ' t1` - - . - \ b>Y THE CELOTEX CORPORATION Sr TAMPA, FLORIDA 33622 v i a Jim\^/alter company . r ? ' ? i' . v- \ * ..." Industrial paper and felt products. Strong, versatile and fire-resistant. . ** . . j- r*t .X u nM ommerciai Asbestos aper end Rollboard. C"U testes Perce: smd mets are sacna, r.aaic ana a i.iiCul eraan Ur- strer.c bindir.a /-recessed- tc a smcc'Ct ruusn by a umque paper-makr.c system, irus pcpuicrr iln oi incmsincu. creduce has ccun'Jess uses m a w.ce rar.ee c: tr.dustr.es. From being used in the manufacturing of msuiaucr., Jo wrapping hot air furnace pipes, to various comrr.srzicu uss. ^^ --'*^v A c'^OC'*? Dcrcer r.clb card vary only a. thickness and viaa. c: roils. They come in standard 12". 15", 24" and 36" widths. iSceciai sices can be weights and thick ets are as fellows: Typical Characteristics Commercial Asbestos Paper 61b. 81b. 101b. 121b. 141b. 161b. 1/16"* per '.CD sq. it. 5.5-5.5 7..5-3.5 9. 3-10.7 11-12.5 2.i 5 15-17 30-24 Asbestos Millboard. Used extensively m the elecaic heating and glass-making indus tries. Celctex Asbestos Millboard ucr cu*c mixci vr.*r. Cinema It is produced m two gredes: ^1 Hard (withstands temperatures tc IGCCTj and -7 Medium (withstar.ds temperatures tc 800F). These two grades satisry most requirements. However, special '*`<**-1 C?/**'V*"1 rQ i by k_/ictx. /\scsics Miilcocra wru; pir.-pcin: 'knurled) brush can CISC C SUppilSC. Asbestos Millboard is furnished Inches. Nominal Tensile Strength Try Pcunds'in. With Grade Mm. Mullen Strength,* Pcundsin. Moisture, 1fcer Cent .015 .019 .022 .022 .028 14 14 10 11 33 14 15 16 12 12 14 3 33 ypical Characteristics Commercial Asbestos Rollboard 3/32" 1/8" Weight, Pounds 48-52 57-67 Thickness, Inches. Nominal .094 .123 Tensile Strength. Dry Pounds, m. With Grain Mm. 35 35 Mullen Strength.* Pounds; in. 32 32 .032 .060-. 064 in 42" x 48" sheets in the following thicknesses and weights: 16 20 Typical Characteristics Commercial Asbestos Millboard Thickness Pounds * * Ounces * * 14 20 (Inches) Per Sheet Per Sq. Ft. 1/16 3 3 5/64 3/32 1/8 5/32 3/16 1/4 5/16 3)8 1/2 5/8tf 3/4 tt ltt 3.9 4.9 .5.9 7.9 9.4 11.8 15.8 19.7 23.6 31.5 37.6 45.2 60.2 4.5 5.6 6.7 9.0 10.7 13.5 18.1 22.5 27.0 36.0 43.0 51.7 68.8 Moisture. Per Cent, Max. 35 m*Typical weights. "Verities are typical Tests are not performed on routine basis. ttAvailable in laminated form on a special order basis only. tinis material may also be called 1116" Rollboard. J m WARNING These products contain asbestos fiber. The Occupational Safety and Health - Administration (OSHA). an agency of the United States Government, believes that repeated inhalation of asbestos fiber is a health hazard and may cause various diseases including cancer and asbestosis. Smoking greatly increases the risk of serious bodily harm. a Jim C/alter company The Celotex Corporation, Tampa, Florida 33622 EXHIBIT N INTERNAL CORRESPONDENCE * 0: C. W. Wright - Lockland FROM: SUBJECT: T. R. Larimer CAUTION LABELS - ASBESTOS PAPER AND MILLBOARD DATE: July 19, 1972 CO E. A. DiSalvo L. J. Knippa S. A. Sauerland After reviewing the specimen stamped caution label you provided, I agree that it is satisfactory for use on shipping packages for all millboard materials and rolls of asbestos paper which do not use a standard label. I suggest the caution warning for.the printed label be done in the style and size of the warranty statement that is now included there. At this point, and until we have new labels printed, I can see no particular spot on the label that is better than any other. However, when we have new labels printed the caution warning should be adjacent to the warranty statement in the lower middle section. The following materials must carry the hazardous material caution label: All Commercial Papers and All Millboards Unsaturated Roofing Felt Unsaturated Glass Scrim Reinforced Flashing Membrane Unsaturated Pipeline Felt Armco Asbestos Paper Muffler Paper Section Paper TRL/ei Attachment CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAL'C: SERIOUS BODILY HARM m o /*?^ <_ -S/* ? ^ //'n<T-- >r^/? C C. O'/" * i//J GpZ* g^c* cJ /S*s~*0<s/St. 3^^^ ^/P^3-T'<. /^rr*Vrv"^ *- ^/rd^*l- '&''<?^/Sr-y^ ROLL' WEIGHT '": WIDTH 18"--24"--36" WARRANTY-we warrant our materials to ba of food quality and will replace material proved defective. Thia warranty is in lieu of ail others express or implied and may not be extended by representatives, written sales information or drawings. While we recommend oaes for our material based on tests believed reliable, we in no way guarantee particular methods of use or application or performance under special conditions. JTAND ON END USE NO HOOKS r=7 1 i L... /p> r?s-\r:.^^ ?&?:nry fT^T] ihtep.mal corccspohj-Ace V 0. A. Cifl*tiia - T.lnden "1*00 t. R. Larimer WHtCTt CAirnon TAnns - asbestos PAPER AND MILLBOARD DATE: July 19, 1972. cc F.. A. DtSalvo L. J. Knlppa S A. Sauerland Effective July 7, 1972, vi* were to conmrtnec labeling certain asbcatos papers and all mlllboon] p.ickagea with a caution vqrnlng regarding the alleged hazard experienced vhen working with ashesros fiber. The requironenta have been elaborated In "Occatpattonal Safety and Health Standards, Port 1910, Fedoral Register, Volume 37, ITo. 110.** This states that the label shall be- vrlrfen an follows: "CAUTl^H Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust May Cause Serious Bodily Haro" The label is further described ss follows: ** M shall be printed in letters of sufficient si<o and contrast as to be readily visible end legible." The following products require this label: Commercial Paper All Millboards Onoeturoted Roofing Felt Vnsaturated Class Serin Reinforced Fleshing Membrane Section Taper Fyrex Corrugated Asbestos Paper in Ail Forms, Including Aircell and AU Board All Asbestos Papers, Foil One Side. In funeral, it is y understanding that Intra-cor.pany shipments, (roofing shipnents to Perth Amboy and Celotex) do not require the label. The general criterion for the label requirement is this - Materials with adcouate binder (rubber latex, asphalt emulsion) r snturant, do not require a label. Those which do not have s Substantial binder, and this includes starch, do require the cautioning statement. Fleaae contact ne If you have questions In this matter. (cont'd) ! * IM I L!\MAk. V.WUUi.41 UiWwHVpS 0. A. Ctn*8ll* Pa*o 7 T. R. Larimer luojecn Caution Label* Asbestos Paper and Millboard oe. viim CG t. A. ElSnlvo LJ Knlppa S. A. Seucrland These materials, whether In cut fora, standard rolls, or bulk rolls, crust carry the above caution label. The lackland plant has prepared a stamp, copy attached, that will be used on nonlnbelcd cartons or rolls. Standard rolls of Cormerclal Paper ct the Lockland Plant are labeled. Every label will nov carry tho caution varnlne as a part of the standard Imprint. I surest that you have rubber otenps made which follow the Lockland format. The type sire they have used appears to be appropriate for Jumbo rolls and larpe cartons. I believe It Is too lorre for the small packages and standard commercial rolls. You mny wish to consider having a snail ourumed label printed In approximately the site of the vsrrsnty statement that is circled on the attached copy. TRL/el * i/ti * f $%&/ I AT: PHONE OR PERSONAL CALL I 1 NUMBER PHONE HIM I j RETURNED CALL I I WILL CALL AGAIN ATTACHMENTS FOR YOUR: INFORMATION a COMMENTS a APPROVAL I [ SIGNATURE DATE TIME______________ I | PLEASE RETURN MESSAGE: dL^a^T'Z.C J /dcvc i.rrir*S /?*tj*rr<?*-/+ 2>r#-+Of* ru*rs': FROM: ?^T fOM ton i*. /n/re g ro S?-/C* -- * / r> -vw CAUTION * CONTAINS ASBESTOS FIBERS ? r' ' . *5 AVOID CREATING DOST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM THE (^22-OT^ COMPILATION OtNttAl OFFICE: t. O. OX 32602 TAMFA, FlOttOA 33622 Hathaway Steap Co. 627 Kain St. Cincinnati* Ohio 45202 PLANT PURCHASE ORDER P- 58574 *U INVO'CH amQ Oluv. TiCItTJ must I(aN Tnij Qt: SHI* TO DATE. Feb. 17 Colotex Corporation >20 S. t/ayna Are. Reload * Ohio 45215 .19. important MVO'CII MUST t( NUNlJHtD AS inO'C.TED TERMS flat 30 QUANTITY 2 ) a mark for Bldg. 28 - Seyfferle UNO 0iGinai INVOICE .NO Two COPIES TO The CElOTEX CO*FO*.TION .r destination O' Sni'mCnT SEND OllGIN.i INVOICE .no Two COFiES TO THE CEnEI.I OFFICE OF THE ClLO'tn C0*0*ti0n IN TamF. F. O. B. Delivered SHiP OU VIA rer/c; DESCRIPTION UNIT PRICE AMOUNT Stamps - 5 Lines 1/4" letters To reed as follows: CAOTIGS CONTAIH ASBESTOS FIBERS AVOID CREATED DUST BREATHER} ASBESTOS DUST KAT CAUSE SERIOUS BODILY HARM Advise *^7 2K? ^ x(*oh3 /4.3s___ Tf IMS AMO CONDITIONS I fki| 0*4#* 4 %9*4 i #* *4** <* H4 ||Ei4 |4*I bf--l * * 4v* * MtfFRII efcee ** <(6 .* t.p ! led*** n Mrtim W# .FfM 9*4 !! | |tmw B4NMl T* k* r,|k* , (*(1 fa.i ## #* #* e NfMitfi # hi *>aa4 * 49*9 %***l4 #** 'M > tkifp-Af <4 Hf f *h> < ** *--99*m*9 FfTIlMHI'M Hf pE4M 9*4 |kF|| N i l44 I k 4efaioe f IfpltH* 40i*4fc% $90 *MH MkiMI <41* 4mh<m 0t If 499% N# IMfl ! ^ n<uif>4 __ 609SSS*- mViT---------------- 4o^oY6 jL' OMMODITY 1HE O^LOTEX CORPORATION H. B. CLEVELAND VICE F6EU0ENT OF FuC*SinS .no TF.ruC C. 0. niTCHII. MANAGE* OF PURCHASING >Y_ (^irC**/* f (jpj&y . P-S8574 o*oe* numie* oat*_ Feb. 17,73 _eq no___232220 AMIOVAU O.II OaU THE 11 (.UKKUkaiiu OINE.tAl 6mCi: 1500 NOITH OAK MAEET TAMPA, FlOtlOA 33*07 ilAUIMC AOOttil: P. O. OX 32*03, TAMPA, HA. 33*23 % TO RRIstero Printing C*. P.O. Dsc 272 Toaja, Ftaida mei PURCHASE orl.k AU INVOICES 1K0 3iivfi TiOtM ujr IM.J OiCHO SHIP TO War M. DATE. Tbs C&&*es Cosporatioa 73 _ 19. 220 S. Xl'aya* Arenas CSacics3ti Cbte 42122 IMPORTANT: INVOICES MUST t( PUENISMEO AS indicated TERMS &* 26 QUANTITY Id,COO 8,000 8,000 y % MARK FOR. Asbestoa MIU [X I SEND ORIGINAL invoice anO TWO COPIES TO THE CELOTEX CORPORATION at destination O* Shipment | | SEND ORIGINAL INVOICE AND TWO COPIES TO AlOvE mailing ADOIESS 0 The CELOTEX CORPORATION in Tampa F o. B. DaM SHIP ON lteas U. D73 DESCRIPTION VIA 341 Mod* UNIT PRICE amount Labels 1/0* RoU Doc.rt Asbestos Paper Foss 7C3S Ear 6/7; Labels 1/B* Asbestos Paper Fcm 7034 Tor, G/73 labaU fee Asbestos Paper Pern 731 Ear. V73 m,2s/r * a,2s/b a./ MOTS: Each label most haws tbs followt&sr rtstassoot: CAUTION - Contains Asbestoa Fibers eveM cresting dust, breathing asbestos dust may causa serious bodily Print (si labels: Complies wfrh air mao&geasat regidaftSoi \ f, and the Cslctox wojrasty. CccRrrciag Fboas Cfcdar cf 5/30/72 To fright Ssmeets Dp MOT DUPLICATE. IIKMS ANO CONDITIONS 1 TV* takoiT til * s*4 4 NwmI 2 ft*4 4rpW'4 M 4* +* #4Sr# * ^4s*44 2 7lit ' # a ** *s4**f 4*4 ** Milif* 4 T**| #4 * i*MP4tM a| * N *4 I * ** !* M > ! 4 !>>4m4 4* 4#*S 4* wrffc* P4**4b<4 4 |fc.44*M ** n *4* **^4 4. A0**Ht#4S4M4 #4 tlta# 4*4 4 l**(' yf EtREMOAtlliM IB* **RM 41 M4fN*W V** * MRktW* 7 All mai#fi*4 k*|i 4 fc i*hH *4 n>4 I 4 b 4i44*im I 94* * *M<1 f# 4A 4>mm 4 *1 IM Bon 44* 4* *4 THI CELOTEX CORPORATIC H. B. CLEVELAND OllECTO* OP PURCHASING ANO TIAPPIC .IT, B, F. Cocawey. Purchasing Age *URCHASE REQUESTED IV. LocUand CHARGE ACCOUNT Q INVOICE TO EE VOUCHERED AT Destination OP shipment [ ] INVOICE TO IE VOUCHEES0 Al 4 I Tamp* GENERAL OPPiCE LABELS BGG/9* .DIVISION DATE, S/E/TS \ 29267 OROER num 249511 ,REQ. NO AFFBOVAU Date DATE r* A 21. R*. 7 7> PLANT OPERATING DEPT. 1 CAREY.J DEUVRR TO. AND SEND INVOICE. IN THE NUMBER OF COPIES INDICATED. ALONG WITH OF THE RATED BILL OF LADING. TO THE LOCATION BELOW. SHOWING THE "X". ORIGINAL and one cop j YT? > ^ /4 A. ) LOCKLAND. OHIO 4JHJ INVOICE COPIES 4 Smith Street & Victory Bn(J|* PERTH AMBOY. N. 1. 01(62 INVOICE COPIES 2 <1 ( 1)10 Orendi Rd. (P O. Boi 72J4) MEMPHIS. TENN. J6107 INVOICE COPIES J <1 1400 N. Pott Oik Rd, HOUSTON. TEX AS 77024 \ INVOICE COPIES 2 1 14 14 E Linden 4 ve < LINDEN. NEW JERSEY 070J6 l INVOICE COPIES 2 1 P ____________________ J WILMINGTON. ILLINOIS 604(1 1 INVOICE COPIES 2 r l_ -7-72 REQ. NO. 26536 ROUTE QUANTITY "I PURCHASE RECORD .BatKmsej Stacp Co., 627 Uala St., Cincinnati, 0 45202 TERMS: 2-10-30 F. O. B Delivered No. ,0. 33018 PC PLACE THIS PREFIX AND NUMBER ON ALL CORRESPONDENCE. PACKAGES. BOXES. IN VOICES, AND BILLS. BOXES AND PACKAGES SHALL ALSO SHOW YOUR NAVE. DATE REQUIRED ACCOUNT NO. 6000.46 * DEPARTMENT Pleat Offico/Sorffcrle itIF RAIL DELIVERY IS SPECIFIED: LOCKLAND BALTIMORE OHIO PERTH AMBOY CENTRAL OF N. J. HOUSTON - SOUTHERN PACIFIC RER/nga MEMPHIS UNION BELT WILMINGTON G. M. & O. LINDEN S. I. R. T. DESCRIPTION UNIT PRICE 4 Stamps - 5 lines 1/4" 1 etters To read as follows: Advise CAUTZGEf CGSfTAXES ASBESTOS PIESRS AVOID CRSATHJG DOST BBEATEZB6 ASBESTOS3 DUST XAT CAUSE SERIOUS BODILT HARM Taxable Deliver to Receiving Dept. w W/o - ACKNOWL. Promned INVOICE DATE PO.M Slot pc nrv M/K. A 'far* /.os -ho -- ------------ > QUANTITY AND DESCRIPTION J* 51 --------- - -- i INVOICE CaR initial AMOUNT A NUMBER D. T. Shirley Lockland Plane Asbestp* .PauM on Label June 14, 1976 G. Reynolds of our Legal Department has advised me that all industrial asbestos products (millboard, commercial papers, muffler paper, 77. natural rubber paper, Armco Paper, muffler paper, etc.) whether bulk-packed or in individual packages, cut-to-size or in full-size units, should carry the caution label which reads: CAUTION Contains asbestos fibers Avoid Creating Dust Breathing Asbestos Dust May cause serious bodily harm 1 believe you are doing this already but if not, please proceed immediately to do so. Thank you. TRLgf T. R. Larimer I & INTCR.OFFICE COKKCS^ONOtNCt D. T. Shirley Lockland Plane U. T. S. OFFICE 1976 Product Liability Please send me a sample label containing the health hazard warning for each industrial asbestos product shipped from the Lockland plant including Com mercial Papers, Armco Paper, Muffler Paper cut and in rolls, 77. Natural Rubber Asbestos Paper, and Millboard in sheets and cut pieces. These are needed for a meeting of the Product Liability Committee to be held on August 3, 1976, so 1 will need the labels before this date. Thank you. TRL/gf cc: E. A. DiSalvo R. G. Merriman R. Milhoan R. S. Miller f M. Bartke Lockland Plant U. T. S. ,/ jut 2 S 1976 \ Asbestos Warning Statement July 21, 1975 Confirming our July 20, 1976 telephone conversation, you are sending me one of the black aod white hazard warning labels printed and used by the Lockland Plant prior to incorporation of the warning in the various Commercial Paper and Millboard labels. This will be reviewed by the legal department for acceptability of lettering size and prominence only. After size approval is obtained you may then proceed to have new labeLs of similar size printed using the wording prescribed in specification 0-9-1-1, dated July 12, 1976 subject: Asbestos Warning Statement. The new labels will then be glued onto some conspicuous area of each in* dividual roll, package or other container of Industrial asbestos materials, being shipped to our customers, that does not already have a standard label. Standard labels for Commercial Asbestos Papers are now being revised. The new warning must also be placed on the Millboard cartons procured by Lockland Plant purchasing. Revision of the warning statement on these cartons should be made lmofedlately. If we have a substantial quantity on hand it may be possible to use the new label on these cartons to avoid scrapping them, but please use the new warning statement on all cartons ordered henceforth. TRL/gf CCt R. Hilhoan / 0. Shirley-' T. R. Larimer * * INTfROFFICC COWSJS^ONOCNCE July 22, 1976 To: T. R. Larimer - Tampa Marketing From: M. Hartke - Lockland Subj: Asbestos Warning .Statement IOCKLANO HANT Under separate cover (mailed today) I have sent you samples of labels and stickers used on our asbestos products. Included is the black and white "Caution" label used prior to the incorporation of the warning on our labels. # Please let me know if you require anything in addition. We have a label machine at Lockland that can print a label 5" x 8" or any size in between. cc E. A. DiSalvo D. T. Shirley R. G. Merriman R. Milhoan M. Hartke u. \ I JUL 2 >b/l July 22, 1976 R. P. Mllhoan Advertising Department ASBESTOS WAB5TNG STATEMENT The asbestos task force has recently recommended the following statement should be placed on each product shipped of asbestos fiber or asbestos fiber containing product. "This product is (asbestos fiber) or (contains asbestos fiber). The Occupational Safety and Health Administration (CSHA), an agency of the United Stafiaa Government, believes that repeated inhalation of asbestos fiber is a health hazard and may cause various diseases Including cancer and asbestoals." According to my records, the following Industrial insulation accessories contain asbestos: Thermotex B Insulation Seal Fibrous Adhesive 7H-C0 Asbestos Short Insulation Cement Fireclad Jacketing Please review our current labeling methods and coordinate with Lockland to have above statement Indicated on those products containing asbestos or asbestos fiber. If I can be of any assistance regarding this project, please advise. t th cc: R. Finn, Lockland / D. Shlrloy, Lockland " M. Interlan, Tampa Karl V. Holm * EXHIBIT 0 JMg CELOTEX CORPORATION finance dept, policy statement SUBJECT RECORDS RETENTION I. POLICY DATE EFFECTIVE IMMEDIATELY DISTRIBUTION B&E SUPERSEDES Book 1 Part 4 Section 2 DATE ISSUED April 8..1976 PROCEDURE NUMBER 01-11-00 DATED 7/1/71 PAGE OP 18 Records shall be retained only as long as they serve a necessary business purpose or are required by law. (Because state retention statutes vary widely on tax, unemployment, and workmen's compensation records, each operating unit should check with the Tax Commissioner of the state(s) in which it does business for specific details.) II. PURPOSE To establish the procedure for retention and destruction of records. III. DEFINITIONS A. Operating Unit - The general headquarters of each plant, division and/or subsidiary that constitutes Celotex Corporation. B. Record - A document used to record, analyze or report the business transaction of the Company. C. Storage - Housing of records in other than active files. D. Years - The period of time a record is to be retained for legal or corporate reasons. This period is in addition to the fiscal year in which the particular transaction, document or property expires or is completed, settled, cancelled, terminated, disposed of, refused, etc., as applicable. IV.. PROCEDURE A. Current Transactions - Records of transactions not closed will be retained for the prescribed period after close of transaction. B. Correspondence - Correspondence will not be retained longer than necessary and in no case for more than one (l)year unless it is part of a record to be retained for a longer period. C. Active Files - Records scheduled for retention shall be transferred from active files into storage not later than seven (7) months following the end of the fiscal year in which the transaction is completed. Exceptions to this rule may be made if a useful business purpose is regularly served by deferring transfer. fug reiOTEX roRPQHariow finance dept, policy statement SUBJECT . RECORDS.RETENTION V IV. PROCEDURE (Continued) date effective IMMEDIATELY DISTRIBUTION B&E SUPERSEDES Book I Part 4 Section 2" DATE ISSUED April 8, 1976 PROCEDURE NUMBER 01-11-00 DATED 7/1/71 pass 2 of 8 D. Storage Containers 1. Records being transferred to storage for a period of less than ten (10) years are to be contained in serially numbered cardboard transfer files, either letter or legal size as required. 2. Records being transferred to storage for a period of ten (10) years or more are to be contained in either serially numbered fireproof files or a vault. E. Records Identification - Each storage file is to be externally, prominently, and clearly identified with a permanent record of: Name of department and location originating the file File number File contents Period covered by contents Scheduled destruction date or marked "Permanent" if so scheduled. Waterproof, fade resistant paint, fade resistant marker and stencils are to be used for identification purposes. Gummed labels or other adhesives are not acceptable due to their lack of performance. F. Storage Facilities - Each location shall designate a storage area for those records scheduled for retention. Storage space is to be protected against disturbance or Intrusions by unauthorized persons and against fire, flood, heat, mildew, excessive dirt and other factors which ..cause undue deterioration. G. Records Retention Storage Log - Each location shall establish and permanently maintain a log for the purpose of identifying --individual files as to: Storage location (building & room) Row or aisle number --File, number - "Type of file'(letter or-legal, cardboard or metal) -'-Title or brief description of contents "Scheduled destruction date Actual destruction date. H.^-(Jhlisted Records - Records not listed in Part V of this % policy should be retained only as long as they regularly service a necessary business purpose. If it seems appropriate to establish a retention schedule for an unlisted record, a * * -* - 1 1 P* A RP fwrtW KO fUe C' 6LOTEX p0B0*TI0N FINANCE DEPT. POLICY STATEMENT SUBJECT RECORDS RETENTION * IV. PROCEDURE (Continued) . DATE EFFECTIVE IMMEDIATELY DISTRIBUTION B&F SUPERSEDES Book 1 Part S.errinn ? DATE ISSUED 4 April 8. 1976 PROCEDURE NUMBER ' 01-11-00 OATEO 7/1/71 PAGE 3, OF 8 I. Destruction 1. Each location is responsible for destruction of its own records. 2. Records are to be destroyed by incineration, shredding, or other positive means on expiration of the specified retention period, unless a written request has been received from the applicable department manager, approved by the operating units chief financial officer, specifying a longer retention. V. RETENTION SCHEDULES A. Finance Years 1. Accounts Payable Invoices: a. Regular 3(A) b. Capital Asset 3 (AD) 2. Accounts Receivable Ledger Cards 3 > 3. Accounts Receivable - Bad Debts 7(A) - 4. Audit Reports - External 5. Accounts Receivable Agings P 31 6. Bank Account Reconciliations 3(A) 7. Bank Deposit Slips 3(A) 8. Capital Project Authorizations 3 (AD) 9. Capital Asset Register 10. Cash Disbursements Journal P P '* * 11. Cash Receipts Journal P 12. Checks - Cancelled 3(A) ' 13. Credit Memos _ 7 ... 14.. Cost Records 7 15. Costs - Standard 7 18. Depreciation Records P 17~ Employee Earnings' Record 7 18. Employee Travel Expense Records 3(A) 19. Employee Relocation Expense 3(A) 20, Financial Statements: Z_: a. . Certified P 7_____ b. Interim 3(A) c. Year-End--------- -- :~--l. tt--. ----- ' t-- T. 3(A) - _ d. Work Papers - .. ... 3(A) 21* General Ledger __ P- 22.7. General Journal Entry P 23. General Journal Entry Support Data r__ 24. Income Tax Returns-- . -- 3(A) -P- 23T Income Tax Return Work Papers ...3(A) % -Inventory Summary & Work Papers: - -^u_---- m- -- ! --- -=.>- - Interim- --- - - ___- -- = - -ha; -- JME rELOTEX CORPORATION FINANCE DEPT. POLICY STATEMENT SUBUSCT RECORDS Kx.TtNi.IUN V. RETENTION SCHEDULES (Continued) date effective IMMEDIATELY DISTRIBUTION B&E SUPERSEDES Book 1 Part 4 Section 2 DATE ISSUED April 8, 1976 PROCEDURE NUMBER"' 01-11-00 DATED 7/1/71 PASS 4, OF 8_ - A. Finance (Continued) 27. Payroll: a. Journal b. Register c. Tax Returns d. Bond Purchase Records Years P P 7 7 28. Petty Cash Vouchers 29. Notes Receivable 30. Royalty Reports 31^. Sales: ''a. Contracts b. Invoices c. Journal d. Order e. Tax Exemption Certificates f. Tax-Monthly Work Papers g. Tax Return 7 3 (AS) 7 7 7 P 7 P 7 7 ;, \ 32. Subsidiary Ledgers P B. Data Processing 1. Machine-sensible data media used for recording, consolidating, and summarizing accounting trans actions and records that may become material in the administration of any Internal Revenue Law. 3(A) Typical of such data media are: Punched cards (*) Magnetic Tapes Discs Paper Tapes (*) (*) An exception is provided which makes it unnecessary to retain punched cards or other media which are used merely as a means.of input to the system and the in formation is duplicated on magnetic tapes, v discs or other machine sensible records. 2. System flow charts and documentation P MT *J*HE ^ELQTEX roRPQWATIQN FINANCE DEPT. POLICY STATEMENT SUSPECT RECORDS RETENTION V. RETENTION SCHEDULES (Continued) date effective IMMEDIATELY DISTRIBUTION B &E SUPERSEDES Book 1 Part 4 Sprrion 2 DATE ISSUED April 8, 1976 procedure NUMBER 01-11-00 DATED 7/1/71 PAGE , 5 OF 8 C. Employee Relations 1. Recruiting & Selection Years Application for Employment: 1. No interview 2. If interviewed, including interviewer's comments 3. If hired 3 10(AT) b. EEOC Records and Reports c. Advertisements for employment d. Affirmative Action Plans/Programs e. Turnover Reports f. Veteran's Reemployment Data P 2 P P P 2. Labor Relations a. Contract Negotiations After 10 years purge file and retain 1. Minutes 2. Cost detail of final settlement 3. Letters outlining final settlement 4. Copies of company offers 5. Union's original demands P P P P P ~b.* "Onion Agreements (signed documents) "c. "Union Agreements (printed copies) -d. Grievance Records N.L.R.B. Proceedings jE*.. Minutes of Labor/Managment Meetings P 3 (AT) P P P 3. Personnel Records "a. Employee Records/Personnel Files 1. Change in status notices 2. Termination Notices - z-.-J. Deduction Authorizations Contracts . r. rt5. Time Cards -_r. 10 AT 10 AT 10 AT 10 AT 3A b. r.-Gamishmenta i?--: c. c Patentright Protection Contracts 10 AT 10 AT T&. jasplovee Benefits _ a* Accident Report, Injury Claims, Settlement 3 b. Occupational Injury Frequency Data P Cm Profit Sharing Plan Records P jme rtioTEx Corporation FINANCE DEPT. POLICY STATEMENT subject RECORDS RETENTION i . . DATE EFFECTIVE IMMEDIATELY distribution PROCEDURE NUMBER 01-11-00 B&F SUPERSEDES Book 1 Part 4 Section 2_________ DATE ISSUED DATED 7/1/71 Anri1 8. 1976 PAGE 6 OP 8 V. RETENTION SCHEDULES (Continued) C. Employee Relations (Continued) Years d. Retirement/Pension Plans P e. O.S.H.A. Records and Reports P f. Employee Newsletters/Magazines P g. Employee Solicitations for Charitable Causes 1. United Fund 2 h. Suggestion Systems P 1. Suggestion System Records 10 i. Stock Purchase Plan P 1. Stock Purchase Plan Records 10(AT) j. Educational Assistance Plan P 1. Educational Assistance Plan Records 3 k. Scholarship Program P 5. Compensation Administration a. Salary Administration Records 1. Position Descriptions 2. Policies & Procedures 3. Salary Ranges b. Unclaimed Wages c. Wage and Benefit Surveys P 7 5 6. Training & Development a. Training and DevelopmentPrograms 1. Training Program RecordsAppraisals P 3 7. Miscellaneous a. Organization Charts b. Rules of Conduct - Safety Rules c. Disciplinary Action Records d. Wage, Equal Employment, Health& Safety Bulletins (Required to be posted by Government) 3 P P S D, Legal Records 1. Claims & Litigation Concerning Torts & Breach of Contract 2. Contracts, Bailments, Changes,Specifica tions, Procedures 3. General Agreements 4. Patent & Related Material 5. Trademarks & Copyrights P P 20(AT) 20 P pH reLOTEX rpRPORATION finance DEPT. POLICY STATEMENT SUBJECT m KfcUUKUO RETENTION DATE EFFECTIVE IMMEDIATELY DISTRIBUTION B &F supersedes Book 1 Part Section 2 DATE ISSUED 4 April 8, 1976 PROCEOURE NUMBER 01-11-00 DATED 7/1/71 PAoe op 78 V. RETENTION SCHEDULES (Continued) E. Purchasing Records 1. Bids, Awards 2. Capital Equipment Purchase Orders 3. Contracts 4. Purchase Orders 5. Purchase Order Requisitions 6. Quotations Years 3 (AT) 3 (AD) 3 (AT) 3 (AT) 3 (AT) 1 F. Traffic Records Aircraft Operating & Maintenance 2. ''Bills of Lading 3. Driver Reports 4. Export Records 5. Freight Claims 6. Freight Bills 7. Rates & Tariff 8. Receiving Documents 9. Routing \ 10. Shipping & Related Documents ' 11. Waybills P 2 3 3 3 (AS) 3 S 2-10 3 2-10 2 G. Engineering/Manufacturing Records 1. Bills of Material 2 Drawings & Drafting Records P 3. Product, Tooling, Design, Engineering Research Experiment & Specification Records 20 4. Stock Issuing Records 3 5. Tool Control 3 H. Corporate Records . , . 4mmm> trT 1. Annual Reports 2. Charter & By-Laws 3. Cancelled Stock Certificates -- 4. Contracts & Agreements . 5. Daily Stock Transfer Sheets 6. Fidelity Bonds, Surety Bonds - 2__ Incorporation Records 6. Leases 9.- Licenses 10. Minutes Hr- Mortgages " 12. Notes-cancelled 13; Option-After Expiration or Refusal to -- . Exercise ....... * 14r- Property Deeds ` 15. Real Estate Titles -- P P 7 20 (AT) P 3 (AT) P 7 (AT) C. P' 7 (AT) 7(AS) i; p p * TL r^gLOTEX rOffPOWATIQW FINANCE DEPT. POLICY STATEMENT SUBJECT BF.rnRDS RETENTION *. % V. RETENTION SCHEDULES (Continued). H. Corporate Records (Continued) 16. Stock Ledgers 17. Stockholders Lists 18. Stockholder Proxies I. Other Records 1. Directives from Officers 2* Forms Used, File Copy 3. Price Bulletins 4. Systems & Procedures Records 5 .'''-'Warranties DATE EFFECTIVE IMMEDIATELY DISTRIBUTION PROCEOURE NUMBER 01-11-00 B &E SUPERSEDES DATED Book 1 Part 4 7/1/71 DATE ISSUED PAoe 8 of 8 April 8. 1926------ Years P 7 3 (S) P 3 P 3 (AT) Legend: A -- After income tax returns for the year to which the -papers relate have been examined. AD - After Disposal AS - After Settlement AT - After Termination C - While Current P - 'Permanent S - ' Until Superseded uiNN A MC GINNIS E.4 0 MARKETING PROCEDURE Number RIOla April 1, 1981 (Supersedes R101 dated May 25, 1977) RECORD RETENTION PURPOSE: To supplement the Finance Record Retention Policy 01-11-00, dated 4/8/76, concerning specific records used for normal business purposes by market ing, regional sales offices, and plant sales order groups. GENERAL: Other records not listed should be retained only as long as they are re quired for normal business purposes. PROCEDURE: 1. Retain records based on the retention schedules listed in the Finance Policy and the attached supplement. . 2. Records retained beyond the published retention schedules must be authorized in writing by the corporate legal department. t u. i i. riwm , i iBiiayci Marketing Administration bg Attachment: Supplement to Finance Procedure 01-11-00 DISTRIBUTION: All Regional Sales Office Supervisors (10) All Regional Sales Managers All Field Sales Managers All Plant Managers All Plant Controllers All Plant & Warehouse Sales Order Groups (Index #36) J. Freeman - Legal Dept. L. Melrose - Legal Dept. M. Fisher - General Files Tampa interoffice #12 SUPPLEMENT TO FINANCE PROCEDURE 01-11-00 MARKETING ADMIN. TAMPA 1. Price lists, quotations, Requests for Exception to Price or Conditions of Sale-Forms 350 & 360, Request for Non- Standard Pricing or Special Condition of Sale-Form 330, Special Acoustical Product Request-Form 30, and customer trade classification forms. 4 AT 2. Copies of orders placed by customers for shipment from our plants. m -3. Copies of orders placed by customers for entry with outside suppliers. - 4. Copies of invoices, requests for cre dit, and credit memos. - 5. Copies of alTowed and collectable RDs. - 6. Internal correspondence; messages and memos (formal and informal) including correspondence with field representa- tlves. 1 7. Departmental systems and procedures. P S. Work papers and copies of plans and budgets of operations. 2 3L Copies of Territory Assignment Sheets. 10 10. Copies of data processing reports. 11.- Copies of settled complaints (NonBonded). 1 12. BUR Job Files cancelled prior to -bonding. - 13. BUR Bond Files Including service and Inspection records. - 14i Copies of new customer forms. Custo mer Data, New Account-Form 728, Customer Code Request- Form 686, and Blanket Certificate of Exemption From Sales Tax-Form 711. 15. Customer Control Cards - Form 83. REGIONAL SALES OFFICE 1 AT PLANT SALES ORDER 1 AT 2 2- 2 - 2 11 S 1 C 1 1 AS 6 AT 1 AT C 5 1 C 1 - C .C IN THE CIRCUIT COURT FOR BALTIMORE CITY * * ALL CT-1 CASES * ALL CT-2 CASES * ALL CT-4 CASES * ALL CT-5 CASES * ******* CERTIFICATE/NOTICE OF SERVICE I HEREBY CERTIFY that on this 5th day of May, 1988, Defendants Owens-Illinois, Inc., Keene Corporation, The Celotex Corporation and Armstrong World Industries, Inc., sent their Answers to Plaintiffs' Master Interrogatories by hand-delivery or first class mail, postage prepaid, to the following parties: Gardner M. Duvall Whxteford, Taylor & Preston Signet Tower - Suite 1400 Seven Saint Paul Street Baltimore, Maryland 21202-1626 (301) 347-8700 WILLIAM D. KURTZ ESQ. VERDERAIME & DUBOIS, P.A. 1231 N. CALVERT ST. BALTIMORE, MARYLAND 21202 ATTORNEY FOR PLAINTIFF RICHARD M. BADER ESQ. 114 E. LEXINGTON STREET SUITE 700 BALTIMORE, MARYLAND 21202 ^ ATTORNEY FOR PLAINTIFF PETER G. ANGELOS ESQ. LAW OFFICES OF PETER G. ANGELOS 5905 HARFORD ROAD BALTIMORE, MARYLAND 21214 ATTORNEY FOR PLAINTIFF HARRY GOLDMAN JR. ESQ. 7 N. CALVERT STREET 1123 MUNSEY BUILDING BALTIMORE, MARYLAND 21202 ATTORNEY FOR PLAINTIFF JOHN T. ENOCH ESQ. GOODMAN, MEAGHER & ENOCH 111 NORTH CHARLES STREET BALTIMORE, MARYLAND 21201 ATTORNEY FOR PLAINTIFF PETER T. NICHOLL ESQ. ASHCRAFT & GEREL SUITE 805 10 EAST BALTIMORE STREET BALTIMORE, MARYLAND 21202 ATTORNEY FOR PLAINTIFF CARL E. TUERK JR. ESQ. COOPER, BECKMAN & TUERK 114 E. LEXINGTON STREET SUITE 700 BALTIMORE, MARYLAND 21202 ATTORNEY FOR PLAINTIFF ROBERT PAUL MANN ESQ. MANN & CLARK 1142 YORK ROAD LUTHERVILLE, MD 21093 ATTORNEY FOR PLAINTIFF STEPHEN J. NOLAN ESQ. NOLAN, PLUMHOFF & WILLIAMS SUITE 1105-HAMPTON PLAZA 300 EAST JOPPA ROAD TOWSON, MARYLAND 21204-3012 ATTORNEY FOR PLAINTIFF JOHN W. PFEIFER ESQ. PFEIFER AND FABIAN, P.A. 326 ST. PAUL PLACE BALTIMORE, MARYLAND 21202 ATTORNEY FOR PLAINTIFF CLIFFORD W. CUNIFF ESQ. 207 E. REDWOOD STREET MAGILL-YEARMAN BLDG. (STE. 612) BALTIMORE, MARYLAND 21202-3321 ATTORNEY FOR PLAINTIFF > EDWARD S. COHN ESQ. 1228 N. CALVERT ST. BALTIMORE, MARYLAND 21202 ATTORNEY FOR PLAINTIFF WILLIAM J. BLONDELL JR. ESQ. 628 EASTERN AVENUE BALTIMORE, MARYLAND 21221 ATTORNEY FOR PLAINTIFF BERNARD J. SEVEL ESQ. 1410 CENTRAL SAVINGS BANK BLDG. 201 NORTH CHARLES ST. BALTIMORE, MARYLAND 21201 ATTORNEY FOR PLAINTIFF BRIAN C. PARKER ESQ. GEBHARDT & SMITH THE WORLD TRADE CENTER 9TH FLOOR BALTIMORE, MD 21202 ATTORNEY FOR PLAINTIFF ALLEN HILLIARD LEGUM ESQ. LEGUM & HENLEY 208 DUKE OF GLOUCESTER ST. P.O. BOX 191 ANNAPOLIS, MD 21404 ATTORNEY FOR PLAINTIFF ROBERT J. LYNOTT, ESQ. MOORE, LIBOWITZ & THOMAS 334 SAINT PAUL STREET BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT A. W. CHESTERTON, INC. ROBERT E. CADIGAN, ESQ. SMITH, SOMERVILLE & CASE 100 LIGHT STREET, 6TH FLOOR BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT ABEX CHARLES G. BERNSTEIN, ESQ. BERNSTEIN, SAKELLARIS & WARD SUITE 2852 THE WORLD TRADE CENTER BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT ANCHOR PACKING JOHN W. BRASSEL, ESQ. BRASSEL & BALDWIN, P.A. 116-E CATHEDRAL STREET ANNAPOLIS, MARYLAND 21401 ATTORNEY FOR DEFENDANT BMI, INC. JOHN J. NAGLE III, ESQ. POWER AND MOSNER 21 WEST SUSQUEHANNA AVENUE TOWSON, MARYLAND 21204 ATTORNEY FOR DEFENDANT BABCOCK & WILCOX CO. GEORGE C. DOUB JR., ESQ. VENABLE, BAETJER AND HOWARD 2 HOPKINS PLAZA 1800 MERCANTILE BANK & TRUST BLDG. BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT BENDIX DONALD C. ALLEN, ESQ. ALLEN, THIEBLOT & ALEXANDER WORLD TRADE CENTER, SUITE 444 BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT C. TENNANT & SONS V M. BRADLEY HALLWIG III ESQ. ANDERSON, COE & KING 800 FIDELITY BUILDING 210 N. CHARLES STREET BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT CHRYSLER CORP. GEORGE P. ADAMS, ESQ. 343 NORTH CHARLES STREET BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT COMBUSTION ENGINEERING, INC JAMES R. EYLER ESQ. MILES & STOCKBRIDGE 10 LIGHT STREET BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT CORHART REFRACTORIES CO. DEBORAH L. ROBINSON ESQ. FRANK, BERNSTEIN, CONAWAY & GOLDMAN 300 EAST LOMBARD STREET BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT CRANE PACKING CO. (JOHN CRANE-HOUDAILLE, INC.) DAVID F. ALBRIGHT, ESQ. SEMMES, BOWEN & SEMMES 250 WEST PRATT STREET BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT CROKER, INC. PATRICK JAMES ATTRIDGE, ESQ. BROMLEY, BROWN & WALSH 806 GBS BUILDING 51 MONROE STREET ROCKVILLE, MARYLAND 20850 ATTORNEY FOR DEFENDANT ELTRA CORPORATION S. KENNON SCOTT, ESQ. HARTMAN & CRAIN 2660 RIVA ROAD 4TH FLOOR ANNAPOLIS, MARYLAND 21401 ATTORNEY FOR DEFENDANT GARLOCK, INC. PIPER & MARBURY 1100 CHARLES CENTER SOUTH 36 SOUTH CHARLES STREET BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT GENERAL MOTORS JEREMY W. NORTH, ESQ. LAW OFFICES OF DELVERNE A. 906 MUNSEY BUILDING CALVERT & FAYETTE STS BALTIMORE, MARYLAND 21202 DRESSEL ATTORNEY FOR DEFENDANT GENERAL REFRACTORIES CO. EDWARD S. DIGGES JR. ESQ DIGGES, WHARTON & LEVIN 225 DUKE OF GLOUCESTER STREET ANNAPOLIS, MARYLAND 21401-6610 ATTORNEY FOR DEFENDANT HARBISON WALKER REFRACTORIES CO EDWARD S. DIGGES JR. ESQ. DIGGES, WHARTON & LEVIN 225 DUKE OF GLOUCESTER STREET ANNAPOLIS, MARYLAND 21401-6610 ATTORNEY FOR DEFENDANT INTL. MINERALS & CHEMICALS CORP ROBERT P. SCHLENGER, ESQ. LORD & WHIP 800 ONE CENTER PLAZA 120 WEST FAYETTE STREET BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT INTERNATIONAL VERMICULITE EDWARD S. DIGGES JR. ESQ. DIGGES, WHARTON & LEVIN 225 DUKE OF GOUCESTER STREET ANNAPOLIS, MARYLAND 21401-6610 ATTORNEY FOR DEFENDANT KAISER ALUMINUM & CHEMICAL CORP. JOHN J. NAGLE III, ESQ. POWER & MOSNER 21 W. SUSQUEHANNA AVENUE TOWSON, MARYLAND 21204 ATTORNEY FOR DEFENDANT MCIC M. STANLEY RADCLIFFE ESQ. 608 BALTIMORE AVENUE TOWSON, MARYLAND 21204 ATTORNEY FOR DEFENDANT PACOR, INC. WILLIAM A. FRANCH, ESQ. FRANCH & JARASHOW, P.A. Ill CATHEDRAL ST./P.O. BOX 827 ANNAPOLIS, MARYLAND 21404 ATTORNEY FOR DEFENDANT PARAMOUNT PACKING AND RUBBER, INC. A. DOUGLAS OWENS, ESQ. A. DOUGLAS OWENS, P.A. SUITE 100 216 E. LEXINGTON STREET BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT PITTSBURGH METALS PURIFYING CO. JAMES R. EYLER ESQ. MILES & STOCKBRIDGE 10 LIGHT STREET BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT PROKO INDUSTRIES, INC JOHN B ISBISTER, ESQ. TYDINGS & ROSENBERG 26TH FLOOR 201 NORTH CHARLES STREET BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT RAYMARK INDUSTRIES, INC. JON W. BRASSEL, ESQ. BRASSEL & BALDWIN,PA 116-E CATHEDRAL ST ANNAPOLIS, MD. 21401 ATTORNEY FOR DEFENDANT ADIENCE COMPANY, L.P. EDWARD P. MURPHY, ESQ. 805 N. CALVERT STREET BALTIMORE, MD 21202 ATTORNEY FOR DEFENDANT STANDARD ASBESTOS MANUFACTURING & INSULATION CO. PATRICK JAMES ATTRIDGE, BROMLEY, BROWN & WALSH 51 MONROE ST SUITE 806 ROCKVILLE, MD 20850 ESQ. ATTORNEY FOR DEFENDANT U. S. MINERAL PROD. CO. GEORGE. C. DOUB JR., ESQ. VENABLE, BAETJER & HOWARD 2 HOPKINS PLAZA 1800 MERCANTILE BANK & TRUST BLDG. BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT UNIROYAL DAVID F. ALBRIGHT, ESQ. SEMMES, BOWEN & SEMMES 250 WEST PRATT STREET BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT UNIVERSAL REFRACTORIES DONALD C. ALLEN, ESQ. ALLEN, THIEBLOT & ALEXANDER 444 WORLD TRADE CENTER BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT WAGNER ELECTRIC CORP. KATHERINE THURLOW ESQ. THURLOW & NOLAN, P.A. SUITE 204 711 WEST 40TH STREET BALTIMORE, MD. 21211 ATTORNEY FOR DEFENDANT WALLACE INSULATION, INC. THOMAS F. MCDONOUGH ESQ. ROYSTON, MUELLER, MCLEAN & REID 102 WEST PENNSYLVANIA AVE. SUITE 600 TOWSON, MD 21204-4575 ATTORNEY FOR DEFENDANT DURABLA MANUFACTURING COMPANY ANDREW JANQUITTO ESQ. MUDD, HARRISON & BURCH 105 W. CHESAPEAKE AVENUE STE. 30O-JEFFERSON BLDG. TOWSON, MARYLAND 21204 ATTORNEY FOR DEFENDANT ALAN INSULATION, INC. ANDREW JANQUITTO ESQ. MUDD, HARRISON & BURCH 105 W. CHESAPEAKE AVENUE STE. 30O-JEFFERSON BLDG. TOWSON, MARYLAND 21204 ATTORNEY FOR DEFENDANT ALLEN INSUIATION KENNETH L. THOMPSON ESQ. PIPER & MARBURY 1100 CHARLES CENTER SOUTH 36 SOUTH CHARLES STREET BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT AQUA-CHEM, INC. (AND CLEAVER-BROOKS, DIV. OF AQUA-CHEM, INC.) JAMES L. KELLY, ESQ. DONAHUE, EHRMANTRAUT & MONTEDONICO 110 N. WASHINGTON STREET 5TH FLOOR ROCKVILLE, MARYLAND 20850 ATTORNEY FOR DEFENDANT ATLAS TURNER PATRICK G. CULLEN ESQ. ROLLINS, SMALKCN, RICHARDS & MACKIE 401 NORTH CHARLES STREET BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT ASBESTOS SPRAY CORPORATION JAMES R. EYLER ESQ. MILES AND STOCKBRIDGE 10 LIGHT STREET BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT BONDEX INTERNATIONAL INC. RICHARD H. LERCH ESQ. LERCH'AND HUESMAN 16 S. CALVERT STREET-STE. 504 BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT DURABOND PRODUCTS CO. MICHAEL B. MANN ESQ. MANN & WHELLEY SUITE 600 409 WASHINGTON AVENUE TOWSON, MARYLAND 21204 ATTORNEY FOR DEFENDANT EAGLE-PICHER INDUSTRIES, INC A. DOUGLAS OWENS, ESQ. 216 E. LEXINGTON STREET SUITE 100 BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT POSTER WHEELER CORP * S. KENNON SCOTT ESQ. HARTMAN & CRAIN 2660 RIVA ROAD 4TH FLOOR ANNAPOLIS, MD 21401 ATTORNEY FOR DEFENDANT J. HOWARD FRANZ, M.D. WILLIAM A. FRANCH, ESQ. FRANCH & JARASHOW, P.A. Ill CATHEDRAL ST./P.O. BOX 827 ANNAPOLIS, MARYLAND 21404 ATTORNEY FOR DEFENDANT GEORGIA-PACIFIC CORP. DONALD C. ALLEN ESQ. ALLEN, THIEBLOT & ALEXANDER 4TH FLOOR THE WORLD TRADE CENTER BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT GIRARD PAINT PRODUCTS CO. GEORGE HUBER JR. ESQ. HUBER & LUTCHE 326 ST. PAUL PLACE BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT HAJOCA COPORATION ROBERT C. HAZARD INDUSTRIAL INSULATION, INC. 34 ALANBROOK COURT TOWSON, MARYLAND 21204 ATTORNEY FOR DEFENDANT INDUSTRIAL INSULATION, INC. GEORGE C. DOUB JR. ESQ. VENABLE, BAETJER AND HOWARD 1800 MERCANTILE BANK & TRUST BLDG. 2 HOPKINS PLAZA BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT KAISER GYPSUM CO., INC. * JON W. BRASSEL ESQ. BRASSEL & BALDWIN 116 E. CATHEDRAL STREET ANNAPOLIS, MARYLAND 21401 ATTORNEY FOR DEFENDANT MELRATH SUPPLY AND GASKET COMPANY, INC. DEBORAH L. ROBINSON ESQ. FRANK, BERSTEIN, CONAWAY & GOLDMAN 300 EAST LOMBARD STREET BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT NOLAND COMPANY JOHN G. SAKELLARIS ESQ. BERNSTEIN, SAKELLARIS & WARD SUITE 2852 THE WORLD TRADE CENTER BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT PLIBRICO SALES AND SERVICE CO. JAMES' F. LEE JR. ESQ. CARR, GOODSON & LEE, P.C. 1919 PENNSYLVANIA AVE., N.W. WASHINGTON, D.C. 20006 4 ATTORNEY FOR DEFENDANT RUTLAND FIRE CLAY COMPANY R. WAYNE PIERCE ESQ. 929 N. HOWARD STREET BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT SCHUMACHER AND SELIER LEE H. OGBURN ESQ. KRAMON & GRAHAM, P.A. 6TH FL./SUN LIFE BLDG/CHARLES CTR 20 S. CHARLES STREET BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT THERMIC REFRACTORIES CO JON W. BRASSEL ESQ. MILLER, BRASSEL & BALDWIN^ P.A. 116 CATHEDRAL STREET ANNAPOLIS, MARYLAND 21401 ATTORNEY FOR DEFENDANT TNT LIQUIDATING CO. GEORGE C. DOUB JR., ESQ. VENABLE, BAETJER AND HOWARD 1800 MERCANTILE BANK & TRUST BLDG. 2 HOPKINS PLAZA BALTIMORE, MARYLAND 21201 ATTORNEY FOR DEFENDANT W. R. GRACE & CO. ROY L. MASON ESQ. DONAHUE, EHRMANTRAUT & MONTEDONICO 111 SOUTH CALVERT STREET SUITE 2800 BALTIMORE, MARYLAND 21202 ATTORNEY FOR DEFENDANT WALTER E. CAMPBELL CO., INC -Ce3 0-X/ G^rdnerf'L Duvall the wiiLir CAiu.Y :*ai:ui actui:~?:c* co. LOCI'!A IT) PLATT tlovenbcr G, 19-14 SAFETY EULLFTI?: r/5 ALL SUPERVISION RESPIRATORS 17o doubt v:c are all familiar with the old saying, "Thero is a reason for everything." So It is with the v/oarlng or respirators ^'hcro is r. r^nsc;for wearing then. It is-not the inteennt to punish er.ycnc by having them '"car a re spire,ter T?. have been provide cl to protect tho employeo against any dusts that v:c ; -7 that will prove harm"fu'l to tho respiratory tract. He have obtains 1 what wc think is the best possible respirator on the mark: that will do the job v;o have to do hero. L'nch cr.e has been approved by th. U. S. Bureau of hir.os and their approval number is stamped on* each one. But .regardless of how good it YJill do tho job -- it won't do it hung around th" nock as a medallion. It is only natural that we will have complaints against roarIng cf the respirator and \7o must all acres that it will bo r.ors comfortable to work without one. When we Investigate the complaint we find that it is worn too high, tc-o low, too loose, too tight> or tho filter needs ehnjgir.g. Some operations will necessitate tho chancing of the filter daily, Thcso can all bo qorroctod. You will also have complaints that tho rubber face pieco Irritates the ski.This can bo overcome by using the elastic cloth cover over tho rubber face piece* Tho rcapi.rators are issue.! from tho Store-room by requisition-of tho Fcrcrr... and arc in. all cases charged against the employee. Please impress upon th.: employee that it Is his equipment and is chargod against him and care for it as his own property. Instruct the employee to wash thorn frequently in warm, PC*!1 HOT, water. Periodically wa will' call thorn in to bo .sterilized. The Spfofcy Supervisor rill assit you in every possible manner. Te do v^ant to call your attention to the fact that tho respirator is only a temporary measure to bo used in dusty areas. It is our duty to olininato tho dust by mechanical means and by isolation of the areas., however, the respirator should bo worn until it is possible to control tho dust ccnditic Did you ever watch a baseball gano end noto all tho paraphernalia the catch roars? That is SAFETY F .'UIIT.EVT----------------- and ho WEARS IT ror.'FiiN------- and LIKES TO. f m^ II. Brunlc Safoty Supervisor