Document mb2peyN40OqzGoXQvje6ZRN7B

/3-03fc>2^ 1MOMM k iAOOK) KICXAIID & CAPfll rvnsticK u cappbu fICNAlO A. CHOftSN mraiN k MKfUAKIX Ji. a MicMAa. numna CWHMTOPWPI M. TBAMAN RAGGIO, CAPPEL. CHOZEN A BERN1ARD LAWYERS rarTH FLOOR MAGNOLIA UR BUILDING UKI CHARLES, LOUISIANA TOMS March 18, 1982 a. a box hi iNB miMlBl Mr. Robert H. Shemwe U. S. District Copfi Clerk 106 Joe D. Waggoner Federal Bldg. 500 Fannin SI Shreveport,/Louisiana 71161 RPR 19 1982 UDSi\4- L-'l-T K. t RE: Jerry Fontenot v. No. 79-0063-LC Fiberboard Corporation, et al Dear Mr. Shemwell: Enclosed please find Preliminary Statement and Answers to Interrogatories of Owens-Corning Fiberglas Corporation. Kindly file same in the above identified case. By copies of this letter we are sending copies of this document to all counsel of record. Thank you for your kind attention to this matter. GMB:dzd enclosures: **** 1 9 1982 . *>*4.** ''* v i' jl ` I i . - - :AiA,*' "f S< y t i 2 i*r i i f n- J'. i.#.-ii i. <* 1 r- > ' ^4 > s>.i - I iT Tll" -- -- UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION JERRY FONTENOT VERSUS FIBREBOARD CORPORATION, ET AL CIVIL ACTION NO. 79-0063-LC PRELIMINARY STATEMENT and ANSWERS TO INTERROGATORIES Many of the interrogatories which have been answered by Owens-Coming Fiberglas Corporation below refer to "prede cessor" corporations or companies which may have been purchased in the past by Owens-Corning Fiberglas Corporation. Owens- Coming Fiberglas Corporation has not purchased any company or corporation involved in the manufacture of asbestos containing products. As enumerated below in answer number 4, Owens-Corning Fiberglas Corporation has in the past purchased specific assets of Owens-Illinois and Unarco. Owens-Corning Fiberglas Corporation specifically denies that its purchase of specific assets of corporations which were involved in the manufacture of asbestos containing products qualifies it as a successor corporation to either Owens-Illinois or Unarco. 1. As to the person answering these interrogatories, state the name, title or position with defendant, and length of time employed by defendant. ANSWER - 1. Answers to these interrogatories were prepared based upon a search of presently existing corporate files and records regularly maintained in the ordinary course of business of Owens- Corning Fiberglas Corporation and also information obtained during interviews with various employees of the company. No single officer, employee or agent of the company has the direct knowledge or the proper documents necessary to supply each and every answer required. All answers are derived from a number of sources, persons and documents. The person signing the answers to these interrogatories does so solely to satisfy whatever requirement may exist under the applicable rule of civil procedure. The person signing the answers does not, however, have direct knowledge regarding any specific answer but is informed that the files, documents and interviews referred to above do support the responses based upon information available as of the date signature. If information is later obtained which changes, modifies or enlarges any of the answers here presented, such info rmation will be conveyed to the parties submitting these interrogators These interrogatories are signed by Daniel M. Phillips, Senior Counsel - Litigation, Owens-Coming Fiberglas Corporation, Fiberglas Tower, Toledo, Ohio 43659. The telephone number of the corporation is A/C 419/248-8000. 2. Has this defendant been sued under its correct name? If not, state the correct legal name of the defendant and the agent for service in Louisiana. ANSWER - 2. Yes. 3. As to any product containing asbestos in any form, has this defendant manufactured, sold or distributed such product, and if your answer is "Yes" to either question, then give the trade name of the product, the year the defendant first sold or distributed such a product. ANSWER - 3. Yes. See attached Exhibit I. 4. Has this defendant ever acquired another corporation, company, or business which manufactured, sold, processed, distributed or contracted to apply insulation products containing asbestos? ANSWER - 4. No. However, this defendant has acquired certain assets of other companies. This defendant is not, therefore, a successor corporation of such other companies. This defendant did purchase certain properties of the Kaylo Division, Berlin, New Jersey plant of Owens-Illinois in May, 1958, and the Chembest Division, Bloomington, Illinpis plant of Unarco in April, 1970, but this defendant did not purchase or acquire either corporation. 5. If this defendant has ever acquired another corporation, company or business which manufactured, sold, processed, distributed or applied insulation products containing asbestos, then give the trade name of the product and the year the predecessor first sold or distributed such product. ANSWER - 5. Kaylo was the name of the product manufactured by Owens-Illinois at its Berlin manufacturing plant. This defendant does not know when Owens-Illinois first sold or distributed Kaylo. Unarcoboard was the name of the product manufactured by Unarco when the Bloomington, Illinois plant (Chembest Division) was pur chased by this defendant. This defendant does not know when Unarco first sold or distributed Unarcoboard. 6. Did each of your insulation products or materials generally reach, or were packaged to reach, the consumer, insulation helper, insulation mechanic, or ultimate user, without substantial change in the condition in which it was sold? ANSWER - 6. Yes; however, see this defendant's response to interrogatory #9. 7. If your answer to Interrogatory No. 6 is "no," with respect to any product, explain in what way the defendant claims its products were altered or substantially changed after sale or distribution and before reaching the insulation helper or mechanic. ANSWER - 7. Not Applicable. 8< Do you admit that asbestos insulation applicators, helpers or mechanics, were foreseeable users of defendant's asbestos-con tained insulation products? ANSWER - 8. Yes. -2- 9. Based upon the material contents of your products, the method of manufacturing, and the method of application for the purpose of insulatin, can your products be generally applied by an insulator without creating dust? ANSWER - 9. In applying Kaylo and Fyrcor it was not always necessary to cut, saw or route the insulation. Dust would be created if the insulation was cut, sawed or routed but would not necessarily be created under other application procedures. 10. Prior to 1973, did you or your predecessor ever have any labor inspectors or anyone from your company whose job it was to go to areas where your products were being used or installed to make a dust level count? If so, state when this procedure started, the purpose of such procedure, and what action, if any, was taken in response to the findings. ANSWER -10. No, not to this defendant's present knowledge. 11. Did your company, or any precedessor, ever at any time give insulation contractors, insulation helpers, or insulation mechanics who would be using or applying your products instructions concerning safety precautions to use in applying such products? If so, describe such instructions, to whom they were given, the dates they were given, and the manner of giving such instructions. Thes NIMA programs were presented to contractors and distributors with the intention that this information would be passed on by the contractors and distributors to their employees. 12. Did your company, or your predecessor, ever install vacuum systems on equipment used in fabricating, processing, cutting, sawing, or handling asbestos or asbestos-containing materials, at your plants in the decades as follows: (a) 1930-1940, Yes or No. (b) 1940-1950, Yes or No. <c) 1950-1960, Yes or No. (d) 1960-1970, Yes or No. (e) 1970-1980, Yes or No. (f) 1980, to Present, Yes or NO ANSWER - 12.(a-b) This defendant did not have its inception until 1938 and thid defendant DID NOT COMMENCE the manufacture of asbestoscontaining insulation products until 1958 and ceased the manufacture of such products in 1972. A-12(c) Yes. A-12(d) Yes. A-12(e) Yes. A-12(f) New equipment was not installed since we dis continued themanufacture of asbestos-containing Kaylo in late 1972; however, even though the asbestos was totally removed from the pro cess, all the existing dust collection equipment was maintained. 13. Did you company, or your predecessor, ever require your employees at your mines, mills, factories, or plants to wear respirators? If your answer is "Yes", then state the first year that respirators were required. ANSWER - 13. This defendant was never involved in the mining or milling of asbestos, however, respirators were always available for use by defendant's plant employees. In 1971, plant rules made the use of respirators in designated areas and jobs a mandatory requirement -3- 14. Did your company, or your predecessor, ever place any warning signs on the containers in which asbestos insulation products were packaged? ANSWER -14. Yes. 15. If you have answered Interrogatory No. 14 in the affirmative, please state: a) On what date did your company, or your predecessor, issue an order directing a warning be placed on your insulation products, or containers? b) On what date was such warning actually first placed on your insulation products or containers? c) On what date did your insulation products, accompanied by such warning, first reach the insulation contractor? d) State the exact wording of the first warning. e) State the exact size of the warning printed on your asbestos insulation products or containers. f) Did your company, or its predecessor, dictate the exact size of the printed warning? g} . Why did your company or its predecessor place such warning on your asbestos insulation products or containers? h) Did your company or its predecessor place such warning on your asbestos insulation products or containers because you received a directive, command, suggestion, legal opinion, or any type of communication (written or otherwise) from any person, firm, corporation, governmental agency, committee, association attorney or institute? If so, from whom and on what date did you receive such directive, command, suggestion, legal opinion, or other type of communication. i) If the wording of the warning has ever been changed or altered, state when it was changed, and the exact change in the wording. ' ANSWER 15 (a) November, 1966. 15 (b) January, 1966, for Kaylo products; 1964 for SC- 30 and SC-40 cements; April, 1970 for Unarcoboard (Fyrcor) products. 15 (c) Unknown. 15 (d) See Exhibit 4 attached. 15 (e) See Exhibit 4 attached. 15 (f) Answering for this defendant, yes. 15 (g) The warning was placed on the bags containing cement products at the suggestion of Eagle-Pitcher with the con currence of this defendant. This defendant placed cautionary labels on its shipping containers as a result of more definitive information concerning the possible health hazards associated with the use of asbestos. 15 (h) On June 2, 1964, an employee of the Pacific Coast division of this defendant was informed that Eagle-Pitcher Company was planning to attach a cautionary note on its asbestos-containing cements. Eagle-Picher inquired of this defendant at this time as to whether or not it would have Eagle-Picher place such a warning on the cements it rebranded for this defendant. This defendant agreed to have such labels applied to the rebranded cement on June 5, 1964. At a meeting held on November 4, 1966, a decision was made -4- that an approprieate caution statement for asbestos-containing high temperature insulation be drafted by November 30, 1966. Subsequently, a warning label was place on Kaylo in December 1966. 15 (i) See Exhibit 5 attached. 16. Did your company or its predecessor ever place any warning on any of its asbestos insulation pipe covering, blocks, cloth, or millboard? ANSWER -16. Although this defendant did not directly place a warning on the product, it did place such language on the cartons of its asbestos-containing products. See response to Interrogatory NO. 15. 17. Did the warning inquired about in Interrogatories Nos. 14 and 16, or similar warning, ever appear in any of your sales literature? If so, attach copies of such sales literature, showing the date such literature was printed. ANSWER -17. Not to the present knowledge of this defendant. 18. Has your company, or your predecessor, ever devised a high temperature heat insulation which does not contain asbestos? If so, state the date that such insulation was first placed on the market. ANSWER 18. Yes. Early 1973. However, to our present knowledge, there is no product available that is completely equal to asbestos- containing pipe insulation. This defendant's asbestos-free and glass fiber products do not insulate up to the same temperature. 19. Is your company, as of the date of answering these interr- ofatories, still manufacturing, selling or distributing any insulation products containing asbestos? If so, give the brand name of such products. ANSWER 19. No. 20. Has such high temperature heat insulation not containing asbestos performed satisfactorily; that is, is such insulation suitable for the purpose for which it is to be used? ANSWER 20. This defendant's non-asbestos containing insulation performs satisfactorily, except that it does not protect heated surfaces for as high a temperature control as did asbestos-containing insul ation. 21. State the decade that there first existed manufacturing technology for commercial purposes the use of chemicals and minerals for combining into a high heat insulation product a substitute for asbestos in insulation materials. ANSWER 21. 1970'S. 22. To your company's knowledge, in what decade was fiberglas first commercially available? ANSWER-22. Objection. The datesn which the first commercial use of fibrous glass insulation was begun is irrelevant to the issues in this lawsuit and not calculated to lead to the discovery of ad missible evidence. Without waiving this objection, however, this defendant states that in the 1930's fibrous glass was available. 23. To your company's knowledge, in what decade was calcium silicate first commercially available in the manufacturing process? ANSWER -23. Objection. This defendant did not begin the manu facture of an asbestos-containing insulation product until 1958. -5- 24. Please state whether or not any division of your company or subsidiary company engaged in the contract business of applying insulation products had any claims for lung diseases or death from lung disease attributable to asbestosis, mesothelioma or lung cancer. If the answer is "Yes," give the manes of such employees and attach copies of such claims. ANSWER-24 This defendant has had claims made by employees of its contracting units for lung diseases or death from lung diseases attributable to asbestosis and lung cancer. It is unknown whether or not claims were made for death as a result of mesothelioma. This defendant does not have records of such claims, however, defendant's insurance carrier may be able to supply the information. 25. Does your company have, has it ever had, or has your pre decessor ever had, a Medical Department? If so, give the year such Medical Department was established, and whether or not such Medical Department has operated continuously since being established. ANSWER -25. The Medical Department was established upon the hiring of Dr. Jon L. Konz.en on January 1, 1968, and it has operated con tinuously since then. RESPECTFULLY SUBMITTED: G. MICHAEL BOURGEOIS Raggio,Cappel, Chozen Berniard P. 0. Box 820 Lake Charles, Louisiana 70602 318/436-9481 CERTIFICATE OF SERVICE I certify that a copy of the foregoing pleading has bftn served upon counsel for all parties to this proCttijig ty mailing the same to each by First Class r\,fzUnited States Mail, properly addressed arid postage prepaid on this /& dejs of o fnopmci owi PrJiluct *.ru tear Predict* SappHod or Fold latt year Produced Supplied or Mid or tear tabeitet <oted Purpose For Mtcb Pro duct Intend ed Atbettot Content (S) Tear Ueralng Label Placed Ik Product Form of Product (Solid. Sraoulo. tc.) Product Cut. Sauod, etc. oa Job Site (TC1/N0) Product Mied etc. M Job SIM (Tet/Ho; ylo Cart xt tad IPS* (Prodneed) st Kaylo (or W. to 12WF. ylo 20-fei m.up to mi MT. KayIt (sold) Not. i*n (NFd) Early 1911 (Sold) Pipe Intulalion lN|b tMperature laduttrlal latulatloa ed-plpe Ml at ton th attal eket. rcohotrri T97B-------------"T57J------------ Core Insula mo mi (Produced) tion ttt|b nftd to tOMorature rtor la laduttrlal 71 latulatloa Approx. ISS by Height Jan. 1967 Ifbdi Not. 1970 Solid Apprei. Ill by Might yitJ if/i Sol Id In de fendant's MM contract i<tt it ait cut, tauod or routod ot necessary. do PretiMtd to'be cot, toned, or rootad. M 10 aylo mi brandMl r Cagle cher) nttoag isolation aylo Ml brandtd rew7*u-- (Produced) [aact date unlnom t orelent taiknoun at pretent (produced) ir Dr*. .rwi Cort) :-jo 19U K-tIO) :-4c IC-460) ents ?-branded jr OCf by aelf Plcber yla If branded I960 or (tF by tberboard (told only) o.) Pebco l. dual Maor atnoMi but el letid to 19M (told only) e Kaylo Rf branded or DCF by ohnt:anvllltl 'nlbettot Urly wi by Marco tad 'Httburgh kralng) lelleted to bate been uted la contract jo iyvt il 'atilt ualtt only. July 19*4 JCnCuTT" Pottlbly (Purcbated- at early Suppl ter at 1944 Mima) riberglas tar Pottlbly at early blanket W at 1941 Asbestos Paper Facial 197Z Rcltevtd to be 19(2 196* Ute 6fl`t or early Kl'l 1960 (Circa) Unknem at preteat April 1ST* Pottlbly at late at I9SN Pottlbly at late at 1*49 Same at Keyls Seat u Kaylo Sane at Kaylo Smc at Kaylo Sane At Kaylo sane at Kaylo Sane at Kaylo Sane at Kaylo Smo at Kaylo Sou at Kaylo ripe latula tloa See Pbyt- 1W4 Ical Comotttloa Co lean Granule (bolt) HO Pipe Intulatlen (HI pb Tempera ture Intelf tloa) IMaom dan. 1967 Solid Pipe latulatloa (HIgb ttMpera- ture intulatoa) UnknoMl Unknoua bather or not a uaralng labtl mi on product at tbit tMo Solid MrT-T--wBW- -a to be cot teued or routed Unkaoun HI 9b taoporf Unkaom tPiknomi turn latulatloa idMthar or not a uarolnp label uei on product at tbit tloa tatier far duct Lost than IMknom Joints U by uelobt ProtectIra flalti Unknoua no uarnlng oter tbe latulf labtl tloa ea pipe bollotad llaot. boilers, tb bate beta ductt^reocblatt, placed oo coorertort, dtertteri pad product Otbur equlMtat exposed to aoltture or uoatberlaa unknoua but bad NsWstoi ' nt naming to be special ranteat of label ordered. kaper balloted to Aabutot paper bat* boon not produced by ocr placed aa product Solid Unknoun Bet ' NO Ptitty Subttanca Heady No aliad piaitic fore of troullnf contlttency solid Uikaoun Smc at Kaylo Sane at Kaylo let Ha to IIP No No No Pbyttcal CMpoitttaa Mdlttml aad Type of CflMtl Aabettot la Product Aaotlte pad/or Cbryiatlle Atbettot. CaldM Silicate, organic aad inorganic bladeft aad Olttooaclout tarth Atbettot 1SK by Might Tbit product utt Manufactured In serious sleet and lengths. Product Color-Ptak/6rey/ kbit* saw at Kayla only Aaotlte Aabettot mod. smc et Kaylo Color net a frayis (ditto. AIm a Mall mow Ml afgd. ultb a blM and ubitr nottled aeoearanci Smc at Kaylo sane et Kaylo Sane at Kaylo SC-30 rarled Iron 3.9 to 9* Cbrytotllf SC-411 uarlod (r 3 to ST Chrytotllr Pretiaed to be Aaoiltc or Chrytotllc Protueed to bo /tootlto or CbryMtlle Unknoun (Tirytotlle Aipbait inuitloa to iditch loaf atbettot fibers boue been added Iptknoun SBOBaEBBSaB "USA . OWEN$/CORNING FIBERGLAS / 4& OWENS-CORNING FIBERGLAS CORPORATION February 15, 1980 FIBERGLAS TOWER. TOLEDO. OHIO 43659. (419) 245-6000 TO: ALL OUTSIDE COUNSEL RE: UPDATED PRODUCT CHART - OCE EXHIBIT #30 NEW EXHIBIT TO BE ADDED AS OCF EXHIBIT #16a Enclosed herewith is an updated Product Chart with additional items added and a couple of changes made in two columns. One change that has been made can be found for SC-30 and SC-40 i Cements in the column labeled "Physical Composition and Type of Asbestos in Product". Another change that has been made will be found for Kaylo in the column entitled "Year Warning Labe3 Placed on Product" and you will note we have added "and Nov. 1970". The reason for this addition is the result of recently discovering the attached Purchase Acceptance Standard dated 11-4-70 relative to a "re-worded" warning being placed on our asbestos containing Kaylo cartons at that time. Warning used from Jan. 67 to Nov. 70 Warning used from Nov. 70 until warning removed THIS PtOOUCT CONTAINS ASMSTOS FMI mm n aum* n mi momct t~*iq aod Mil nmm nc Rin. W IMUIR RMUnON COiMCi I tNrOVU.PLOMMUM, Of WIVtMt lQi AMMO CAUTION-- ftOOUCT CONTAINS ASKSTOS NKI MMitiOH ov mm m houm oyAwmti Mi iono niiqdi o m mr mhvm. mqommno md. o aDouiR DwnunON n mot ioimu, MAI NWWATOBS anvodo VrMU.l mMOmMuICIoNvOMuNrt. #oi n unarmini We have assigned OCF Exhibit #18a to this 11-4-70 Kaylo P.A.S. document and ask that you incorporate it with the OCF Exhibits in your possession. Please note three items have been added to the Product Chart following "Unibestos". At our Asbestosis Seminar in Houston, you received a packet of material with a four page memo from Joe Stancati which should help to explain these three items. Shortly before the Seminar held in Houston, we mailed to you the "60's" documents. We now ask that you assign OCF Exhibit #125 to this material and Incorporate it with your other OCF Exhibits. Regards. Very truly yours, <f P- (Mrs.) E. P. Case Law Department EPC:mm ends. EXHIBIT * WARNING This product contains asbestos fibers. In halation of asbestos fibers in excessive quantities over long periods of . time may be harmful. Avoid breathing the dust. If adequate ventilation control is not possible, wear respirators of a type approved by the U.S. Bureau of Mines for pneumo coniosis producing dusts. u no Size: 4" x 3" Color: Rod to match Sleight & He I length *8198 "Dixie Red" PAS. 5.1.102 This warning was affixed to the Unarcoboard shipping containers as a matter of course after the purchase of the Chembest Division, Bloomington, Illinois, from Unarco. (The Unarcoboard name was changed to Fyrcor in Feb., 1971) UNARCOBOARD '' 33* UMABCe NDUITIII(| MIC -- CWlMlCII OlVtltOH Mil C*t ITBU1, kMMIMIOM, III IMl ym+mco tUNONwAiRraCitfOr BmOeARDCMi*M'3t6tn' OtVIBlM . HMf ITBtd, BlO^NMftTON, m, iihi UNARCOBOARD *22* NNAACO MDUITAlIt MIC. CNlMKIT in . <Mt fmci. aiooHiiitTON. hi aitoi CAVtlOM Caution OWENS-CORNING FIBERGLAS CORPORATION CONTINUED TO USE THESE UNARCO WARNINGS ON UNARCOBOARD/FYRCOR FROM THE DATE OF ACQUISITION OF THE CHEMBEST DIVISION OF UNARCO INDUSTRIES, INC.. APRIL 15, 1970 TO APPROXIMATELY MAY 17. 1971. The above 3 "Cautions" (warnings) are Identical. We've reproduced the "Caution" wording below for easier reading. CAUTION THIS- PRODUCT CONTAINS ASBESTOS FIBER. INHALATION OF ASBESTOS IN EXCESSIVE QUANTITIES OVER LONG PERIODS OF TIME MAY BE HARMFUL IF DUST IS CREATED WHEN THIS PRODUCT IS HANDLED AVOID BREATHING THE DUST. IF INADEQUATE VENTILATION CONTROL IS NOT POSSIBLE, WEAR RESPIRATORS APPROVED BY THTU.S. BUREAU OF MINES FOR PNEUMOCONIOSIS PRODUCING DUSTS. A-32 A-2? INSU LATION.I V:k -iVf KSjfci' "-i V^ A-ao6 ' '!' * ' \V1 > ., e Her*. > . ; * *' '* *< * i*' * A-a* / \ f a**r * 2 yv ' .illFOR**-*' ' :/;! TEMPERATUREST0I2OCTF. 1 *i ( ^ *h% *v.*;''.*. *. -.V \ . A-** THIS PROOUCT CONTAINS ASBESTOS FIBER IF DUST IS CREATED WHEN THIS PRODUCT IS HANDLED, AVOID BREATHING THE DUST. IF ADEQUATE VENTILATION CONTROL IS NOT POSSIBLE, WEAR RESPIRATOR APPROVED BY U.S. BUREAU OF MINES. A-a#o (?* * p.O Art elements shall be printed to match Glass Container Manufacturers Institute (GCMI) red Ink ^71 % EXHIBIT 6 CJCpRN FJBERGI^S SPECIFICATION DATE: Hoveaber 4, 1970 ISSUED BY: CONSTRUCTION MATERIALS PROCESS AND QUALITY CONTROL DEPARTMENT (Toledo) SUBJECT, specification Revision R^F' Purchase Acceptance Standard - PAS.2.1.U3 - Regular Slotted Printed Cartons and Accessary Materials for Shipping Kaylo Beveled Lag c Kaylo Block Ihe attached subject PAS has been revised as follows: 1 Revised carton artwork. Please cancel the the attached. Issue of this specification and replace with ( eC4UIBMI ma i / Sm*it*immtu--ttr HUM. Kaylo" A-a7t Handle with care A-a40 (7XC4M*) CAUTION-- nooucr contains askstos ran WHunoii 9 mm m uobm omimwt Ml lONO RMH 9 RM MV MM. moo muvmnq am. ff MOM VIMURON n MOV POttMt, Mil MMMVOM AMMI IfMU.i 9 MMeS BOB WMMOCOM1II MOCMCMM Ml A-a/-*/ (v2f*) A*2tO ( 8 ~ In wow W adminata prwlhla flwWwm Irani corpora* Wwntty. printtna dial OwuW ba ordarad tram Tha Parmtar Corporation. 307 SandiMfcy Straat. Ptttabiirph. Pannaylawiia 1M12. Spatity t atamant noiabar and tha tan*th Waampta: A-230, 13" tonal. If dia prtndnp dtaa m to ba ordarad atwwbara, a aNwy prim of dia arlpfnai wt may ba abialnad tram Pannlar. Par A-330 toaotypa 10" Iona id mm. Pm taaoi am (a) dwll maaaura 3V** bnp Pw A-330 lapatmi I" tony aouai to dia dhtanca tram ha taft adaa of dia lanar "l" to tha ripit adpr W dia print of loaol and dull bt readable ndian printed. Thaw dirnanaiana papain aa Art elements printed to match Block ink and PMS *2008 Rod ink. owtoa cowwwn waanouta cowotunod. tolxoo. onto mmssa^asm wssm pas. 2.1.43 fi'V-IO B-.-WujaaawaWa EXHIBIT 6 A?- r CAUTION: This product contains asbestos fiber. Inhalation of asbestos In excessive quantities over long periods of tine may be harmful. If dust Is created when this product Is handled, avoid breathing the dust. If adequate ventilation control Is not possible, wear respirators approved by the U. S. Bureau of Hines for pneumoconiosis producing dust. (This warning was printed on the bags of cement manufactured by Eagle-PIcher and re-branded for Owens-Cornlng FIberglas.)