Document nNbD9YOkjpErq4YJQZOKo01pm

FILE NAME: General Refractories Company (GRC) DATE: 1998 DOC#: GRC012 DOCUMENT DESCRIPTION: GRC Trial Presentation Index - Item List with Descriptions DRAFT 04/17/98 12:32 PM GENERAL REFRACTORIES COMPANY TRIAL PRESENTATION ITEM DESCRIPTION CORPORATE HISTORY In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 11-1 Grefco admits it is incorporated, has its principal place of business in PA and regularly conducted business in Maryland until June, 1982. Deposition of Joseph L. Stein, dated 9/15/93, p. 262 L.7 - L.9 General Refractories was incorporated in the early 1920's, although it existed before then. In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 1 Grefco incorporated in Pennsylvania in 1922. It purchased Ohio Lime Company in 1967, American Refractories Company in 1971 and the Mining and Mineral Division of Great Lakes Carbon Corporation in 1966. Deposition of Joseph L. Stein, dated 9/15/93, p. 160 L.4 - p. 170 L.9 Corporate history, who owns stock. Distinctions between Grefco and Grefco, Inc. Deposition of Joseph L. Stein, dated 9/15/93, p. 176 L.7 - L.16 In 1948 General Refractories sold internationally and had sales offices throughout the United States. Deposition of Robert Lee Everett, dated 2/10/94, p. 178 L.21 - p. 179 L.4 1520 Locust Street was the location of General Refractories corporate office in Philadelphia until about 1985. Deposition of Roland Howard King, dated 7/10/85, p. 40 L.15 p. 41 L.19 Past and present addresses of corporation headquarters, Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 2 Name and principal place of business: General Refractories Company Bala Cynwyd, PA Thurman v. A.P. Green, St. Louis, MO, dated 7/17/87, Interrogatory No. 4 GRC has acquired assets of company that mined, manufactured, marketed or distributed asbestos. DRAFT 04/17/98 12:32 PM Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 5 Companies involved with asbestos which GRC purchased are: Ohio Lime Company Great Lakes Carbon Corporation Bison Corporation Deposition of Robert Lee Everett, dated 2/10/94, p. 134 L.20 - p. 136 L.3 American Refractories is an installer owned by General Refractories. General Refractories ships them materials but they have no records prior to 1975. American Refractories is based in Reading, PA. They have been a subsidiary since he has been with the company. Deposition of Joseph L. Stein, dated 9/15/93, p. 173 L.6 - p. 174 L.5 American Refractories is an installer. Deposition of Robert Lee Everett, dated 2/10/94, p. 136 L.4 - p. 137 L.21 Furnco is a steel mill installation contractor which was owned by General Refractories. Material sometimes shipped to customer and sometimes to Furnco. Almost always shipped to American Refractories rather than customer. In Re: Bethlehem Steel. USDC. MD, dated 3/24/85, Interrogatory No. 2 Grefco regularly conducted business in Maryland up to June, 1982. PRODUCTS OC-GE-12 (PCC-GR-015) Undated General Refractories Co. catalog entitled, "U.S. Refractories Division General Catalog." Shows refractory products with descriptions, chemical analyses, technical data, physical properties & applications. OC-GE-24 (PCC-GR-055) 4/12/77 General Refractories Information Manual, Volume II. Manual discusses refractories and refractory products as manufactured by General Refractories. DRAFT 04/17/98 12:32 PM OC-GE-31 (PCC-GR-009) 1949 General Refractories Catalog entitled, "Refractories." Brochure lists: the history of refractories; the history of the General Refractories Company; the research, manufacture and uses of refractories; Grefco products, properties and uses; brick tables and general information. OC-GE-9 (PCC-GR-005) Undated Brochure from General Refractories Co., U.S. Refractory Div. entitled, "GREFCO", outlining General Refractories product lines. Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 8 General Refractories has engaged in the manufacture and sale of products containing asbestos. In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 13 Grefco admits it sold asbestos-containing products 1961-1976. In Re: Asbestos Cases, Baltimore City, MD, dated 5/13/92, Interrogatory No. 2 Listing of asbestos products, asbestos, usage, packaging, etc. Litecast 30 and 30G 1961-1973 Steelklad 60 BIAE 1967-1978 Fibrous adhesive 1955-1981 Grefco Insulating Cement 1955-1974 Grefco Insul-Finish 1960-1971 Martin v. Grefco, Alleahenv Ctv., PA, dated 1/18/84, Interrogatory No. 5 Products listed: Litecast 30 62-64 Steelklad 66-78 Fibrous Adhesive 63-73 MX17 Block Insulation 64-73 MX17 Insulating Cement 64-73 DRAFT 04/17/98 12:32 PM Thurman v. A.P. Green, St, Louis, MO, dated 7/17/87, Interrogatory No. 11 General Refractories asbestos products are: Litecast 30 Steelklad Dibond 60 BIAE Grefco Insulating Cement Fibrous Adhesive Purchased from JM 65-68 70-73 67-78 61-73 55-72 73-81 Also includes appearance of products. Deposition of Joseph L. Stein, dated 9/15/93, p. 238 L .1 0 -p . 239 L.2 Litecast 30G was designed to be gunned and contained asbestos. Deposition of Robert Lee Everett, dated 2/10/94, p. 80 L.1 4- L.20 Litecast 30 can be gunned. Deposition of Joseph L. Stein, dated 9/15/93, p. 245 L.21 - p. 246 L.4 Litecast 30 contained 23% asbestos. OC-GE-50 (PCC-GR-264) 9/30/65 Standard Mix Specification for Litecast 30. Read heading, manufacturing guide column. Specification lists Litecast 30 as containing 23% Asbestos 7K15. PCC-GR-281 Litecast 30 Standard Mix Specification Reissue dated August 11, 1970. Read heading, Mfg. Method, Manufacturing Guide. "Dry Mixer" "23% Asbestos 7K15" Deposition of Robert Lee Everett, dated 2/10/94, p. 15 L.9 - L.12, p. 16 L.1 - L.19 Responsible for production of all specialty products. Fibrous Adhesive and Litecast 30 had asbestos in them in 1963. DRAFT 04/17/98 12:32 PM OC-GE-5 (PCC-GR-001) Undated Raw Material Specification Issued by Materials Research Corp. - Research & Development Dept, re: Asbestos Fibre 7K15. Read entire specification. Chemical analysis and description of Asbestos Fibre 7K15 is given, along with primary use listed as fibrous adhesive. In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 53 Description of packaging for: Litecast 30 and 30G Steelklad Dibond 60 BIAE Grefco Insulating Cement Grefco Insul-Finish Cement Fibrous Adhesive Deposition of Robert Lee Everett, dated 2/10/94, p. 30 L.20 - p. 32 L.1 Use of asbestos in manufacture of Fibrous Adhesive. Deposition of Joseph L. Stein, dated 9/15/93, p .4 9 L .1 5 - p . 51 L.9, p. 51 L.12 Resale of Fibrous Adhesive up till 1981. General Refractories had previously sold. No warnings on Fibrous Adhesive or Steelklad. Deposition of Joseph L. Stein, dated 9/15/93, p. 83 L.13 - L.16 Fibrous Adhesive assembled by General Refractories from 1955 at least until 1972. Deposition of Joseph L. Stein, dated 9/15/93, p. 84 L.4 - L.7 1973 - 1981 Fibrous Adhesive was purchased from Johns-Manville for resale. Deposition of Robert Lee Everett, dated 2/10/94, p. 32 L.11 -p . 33 L.1 Use of asbestos in manufacture of Litecast 30. Deposition of Robert Lee Everett, dated 2/10/94, p. 42 L.1 - p. 43 L.6 Production of Fibrous Adhesive and Litecast 30 during 1965-1968 was very similar to the way it was done in St. Louis. Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 14 Provides patent numbers and dates for: Steelklad Dibond Litecast DRAFT 04/17/98 12:32 PM In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. II-7 Grefco admits it has manufactured a metal case refractory brick that has an asbestos strip. Deposition of Joseph L. Stein, dated 9/15/93, p. 44 L.21 - p. 45 L.1, p. 45 L.4 - p. 46 L.5, p. 46 L.7 - L.13 Asbestos inserts in Steelklad brick. HarbisonWalker and North American Refractories produced similar products. Deposition of Joseph L. Stein, dated 9/15/93, p. 46 1 - p. 49 L.14 Describes thermal expansion. Substitute was found for asbestos. Asbestos stopped being used around 1978. Martin v. Grefco, Allegheny Ctv., PA, dated 1/18/84, Interrogatory No. 8 Asbestos in Steelklad was a "small spacer unit in a very large block." Deposition of Roland Howard King, dated 7/10/85, p. 23 L.7 L.12 Nicolet was principal supplier of asbestos material for brick. Martin v. Grefco. Alleahenv Ctv., PA, dated 1/18/84, Interrogatory No. 61 Nicolet and/or Eagle Picher supplied the asbestos paper for Steelklad Dibond 60. Where other resale products were purchased. Deposition of Roland Howard King, dated 7/10/85, p. 14 L.4 L.14 Dibond 70 could have had asbestos spacers. It was also used in open hearth roofs. Thurman v. A.P. Green, St. Louis, MO, dated 7/17/87, Interrogatory No. 18a. Describes how products are used: Litecast 30 Steelklad Dibond 60 BIAE Grefco Insulating Cement Fibrous Adhesive In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 55 Grefco Insulating Cement and Grefco Insul-Finish Cement were rebranded Eagle-Picher products and Fibrous Adhesive was at times a rebranded JohnsManville products. DRAFT 04/17/98 12:32 PM Deposition of Joseph L. Stein, dated 9/15/93, p. 8 0 L 1 1 ,p . 83 L.9 Grefco Insulating Cement was a rebranded EaglePicher product which contained asbestos. Can't rule out that some Eagle-Picher product was sold without being put in Grefco packaging. Grefco Insul-Finish was also a rebranded Eagle-Picher product with asbestos from 1960 through the early 1970's. Fibrous Adhesive was a product assembled by General Refractories. Deposition of Joseph L. Stein, dated 9/15/93, p. 237 L .1 9 -p . 238 L.7 Grefco Insulating Cement was shipped dry then mixed with water prior to use. Deposition of Robert Lee Everett, dated 2/10/94, p. 69 L.18 - p. 71 L.2 Grefco Insulating Cement was resold out of Sproul. Deposition of Robert Lee Everett, dated 2/10/94, p. 71 L.20 - p. 72 L.18 Macon v. AC&S, Dauphin Ctv., PA, Interrogatory No. 7 Recalls Grefco Insul-Finish Cement. He cannot say if these products were ever shipped to Maryland. Products sold by Grefco. Grefco Insulating Cement 1955-1973 purchased from E-P, usage, packaging. Macon v. AC&S. Dauphin Ctv., PA, Interrogatory No. 12 Asbestos products sold under rebranding agreements. Grefco Insulating Cement Grefco Insul-Finish Cement Fibrous Adhesive Deposition of Joseph L. Stein, dated 9/15/93, p. 89 L.16 - p. 90 L.5 MX-17 was only block insulation distributed by General Refractories. Deposition of Joseph L. Stein, dated 9/15/93, p. 186 L.7 - p. 188 L.15 1972 brochure says General Refractories insulation block had long fibre asbestos in it. DRAFT 04/17/98 12:32 PM PCC-GR-092 Deposition of Joseph L. Stein, dated 9/15/93, p. 190 L.1 - p. 191 L.10 In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 27 Deposition of Joseph L. Stein, dated 9/15/93, p. 79 L.8 - p. 80 L.2 Abate v. ACandS. Baltimore City, dated 12/27/93, Interrogatory No. 15 Abate v. ACandS. Baltimore City, dated 12/27/93, Interrogatory No. 12 In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 105 Deposition of Roland Howard King, dated 7/10/85, p. 20 L.2 p. 22 L.1 Boiler Refractories Manual -- General Refractories Company, copyright 1939. Read first page, page 19, section title (Expansion Joints), page 22, left colupnn, sentence two, page 23, right column, last sentence. "...easily compresible resilient material such as long fibre asbestos, asbestos ppe..." "All openings...should be neatly made and packed with long fibre asbestos..." Product brochures do not indicate Litecast 30 and Fibrous Adhesive had asbestos in them during a period in which Stein admits these products did contain asbestos. Asbestos was eliminated from the following products: Litecast 30 and 30G1973 Steelklad Dibond 60 BIAE 1978 Litecast 30 with asbestos manufactured from early 1960's to approximately 1973. Steelklad Dibond 60 BIAE manufactured from 1967 to 1977. Dates when asbestos eliminated from certain products: Litecast 30 and 30G 1973 Steelklad Dibond 60 BIAE 1978 Locations where asbestos-containing products were manufactured. Listing of Grefco facilities which manufactured asbestos products. Listing of facilities and product shipped direct from manufacturing plant. DRAFT 04/17/98 12:32 PM Deposition of Roland Howard King, dated 7/10/85, p. 47 L.13 p. 49 L.2 Research and Development lab location and responsibilities. Deposition of Joseph L. Stein, dated 9/15/93, p. 155 L.5 - p. 160 L.1 Lists facilities and mines owned in 1965. Deposition of Robert Lee Everett, dated 2/10/94, p. 190 L.20 - p. 191 L.7 Sproul plant is about 200,000 square feet. Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 45 Listing of locations where General Refractories made its asbestos-containing products. Abate v. ACandS. Baltimore City, dated 12/27/93, Interrogatory No. 203 Grefco had a manufacturing facility, warehouse and sales offices in Baltimore until 1979. In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 77 Grefco admits its employees mixed, cut and tested its asbestos-containing products during their manufacture. In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 82 Grefco admits it never conducted dust measurements in its own facilities. Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 74 General Refractories division or subsidiaries did engage in the contracting business of applying insulation products. American Refractories Company. Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 48 General Refractories never prepared any written material on how its asbestos-containing materials should be used or maintained. In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 28 Grefco never recommended to purchasers or users of its asbestos-containing products that they use respirators or wear protective clothing. DRAFT 04/17/98 12:32 PM Martin v. Grefco. Allegheny Cty., PA, dated 1/18/84, Interrogatory No. 13 Grefco did not test to see if inhalation of asbestos fibers is harmful, but Refractories Institute or the McIntyre Foundation might have In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 43 Grefco has never conduced any studies to determine what type of ventilation will reduce airborne asbestos fibers ip confined spaces. Abate v. ACandS. Baltimore City, dated 12/27/93, Interrogatory No. 151 Grefco never conducted any studies to determine what type of ventilation would reduce airborne asbestos fibers in confined spaces. Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 33 General Refractories never published any warnings concerning the possibility of injury from its asbestoscontaining products. Deposition of Robert Lee Everett, dated 2/10/94, p. 181 L .1 5 - L.20 No warning on Fibrous Adhesive. Deposition of Robert Lee Everett, dated 2/10/94, p. 184 L.10-L.12 MX-17 did not have a warning. Deposition of Joseph L. Stein, dated 9/15/93, p. 91 L.9 - p. 93 L.1 No asbestos warning on Litecast 30. Deposition of Joseph L. Stein, dated 9/15/93, p. 93 L.5 - p. 94 L.21 Steelklad Dibond 60 BIAE never had a warning. Grefco Insulating Cement had warning at some point. Grefco Insul-Finish Cement had warning at some point. Fibrous Adhesive did not have a warning. Deposition of Joseph L. Stein, dated 9/15/93, p. 1 3 2 L .1 9 -p . 133 L.12 Dibond 60 and Fibrous Adhesives never had label indicating they had asbestos but Eagle-Picher rebrands did. Deposition of Joseph L. Stein, dated 9/15/93, p. 1 3 3 L .1 8 L.21, p. 134 L .6 -L .9 Workers currently have the right to know what materials are hazardous. DRAFT 04/17/98 12:32 PM In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 81 Grefco has not conducted any studies to determine what type of respirator affords maximum protection against the inhalation o f asbestos fibers. Abate v. ACandS. Baltimore City, dated 12/27/93, Interrogatory No. 171 Grefco never conducted any studies to determine what type of respirator would afford maximum protection against the inhalation of asbestos fibers. Martin v. Grefco, Alleahenv Ctv.. PA, dated 1/18/84, Interrogatory No. 67 Grefco never performed tests on its products to determine the amount of asbestos fiber released during usage or handling. Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 43 General Refractories never conducted any studies to determine the extent of asbestos fiber exposure to users of its asbestos-containing products. Abate v. ACandS. Baltimore City, dated 12/27/93, Interrogatory No. 37 Grefco never conducted any air dust level counts at locations where its asbestos-containing products were being used. In Re. Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 49 Grefco admits it never conducted any field tests to determine how much dust containing fibers was created when its products were used. In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 50 Grefco admits it never conducted any field tests to determine how much dust containing asbestos fibers was created when its products were removed or torn out. In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 52 Grefco admits it never conducted any laboratory tests to determine asbestos emitted when its products were used. In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 53 Grefco admits it never conducted any laboratory tests to determine asbestos emitted when its products were removed. In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 55 Grefco admits it never provided funding for tests to determine how much asbestos was emitted when its products were used. DRAFT 04/17/98 12:32 PM In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 39 In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 69 In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 73 In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 74 Deposition of Robert Lee Everett, dated 2/10/94, p. 186 L.11 - L.15 Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 52 In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 32 In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 33 In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 34 Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 12 Grefco admits it never posted any signs, posters of warnings on job sites where its asbestos-containing products were being used. Grefco admits it never advised purchasers of its asbestos-containing products of the need to monitor asbestos emissions during usage. Grefco admits it never advised the users of its asbestos-containing products of the need to monitor asbestos emissions. Grefco admits it never provided written warnings to its distributors of possible asbestos health hazards. Never specifically told people they should wear respirators when working with asbestos. General Refractories never conducted any studies concerning the effect of the inhalation of asbestos dust caused by using its products. Grefco has not conducted any tests to determine the effects of its asbestos products on users of the products. Grefco has not conducted any tests to determine the effects of inhaling asbestos fibers from its products. Grefco has not conducted any studies with the purpose of minimizing the inhalation of asbestos fibers from its products. Prior to placing asbestos-containing products on the market General Refractories did not conduct any studies to determine whether they were hazardous. DRAFT 04/17/98 12:32 PM In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 41 In Re. Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 42 Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 21 Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 27 Abate v. ACandS. Baltimore City, dated 12/27/93, Interrogatory No. 36 In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 38 In Re. Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 88 In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 90 In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 40 Thurman v. A.P. Green, St. Louis, MO, dated 7/17/87, Interrogatory No. 57 Grefco has never contributed any funds to research concerning asbestos and its relation to disease. Grefco has never conducted any study of asbestosrelated disease. Prior to releasing its asbestos-containing products for sale General Refractories did not conduct any studies to determine their potential health hazards. After releasing its asbestos-containing products for sale General Refractories did not conduct any studies to determine their potential health hazards. Grefco did not conduct any tests or studies to determine the potential health hazards of its asbestos-containing products. Grefco has never hired a "medical director" with regard to its asbestos-containing products. Grefco admits it has never employed a full-time medical director. Grefco admits it has never consulted any physician concerning the health hazards from inhaling asbestos. Grefco has never hired an "industrial hygienist", per se. General Refractories never engaged physicians or industrial hygienists for research, investigation, or study regarding asbestos or asbestos-related diseases. KNOWLEDGE DRAFT 04/17/98 12:32 PM PCC-GR-061 1932 Transactions National Safety Congress, October 3-7, 1932. Read page 3, Executive Committee, Ernest W. Beck, U.S. Rubber Company, page 50, article, title and author, page 51, paragraph 1. "...within the last three years asbestos dust has also been shown to produce another specific type of reaction attended by symptoms differing in some respects from silicosis." PCC-GR-063 National Safety News, August 1933. Read front page, article heading "The Mechanical Control of Occupational Diseases", left column, paragraph 4, sentence 1. "...54 per cent for cases involving pneumoconiosis (including silicosis, asbestosis, etc.)..." In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 114 Grefco admits it was a member of The Refractories Institute. In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. il-22 Grefco admits it was a member of the Industrial Hygiene Foundation from May, 1942 until January, 1962. ^ OC-GE-39 (PCC-GR-129) 11/7/46 Transactions of the Eleventh Annual Meeting of the Industrial Hygiene Foundation of America, Inc. Lists various articles and discussions on occupational health and diseases and lists General Refractories company as a member. A A DRAFT 04/17/98 12:32 PM OC-GE-41 (PCC-GR-136) Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 66 American Ceramic Society General Exhibits Deposition of Joseph L. Stein, dated 9/15/93, p. 122 L.21 - p. 125 L.6 11/20/47 Transactions of the Twelfth Annual Meeting of the Industrial Hygiene Foundation of America, Inc., entitled, "A Better Place to W ork Transactions Bulletin No. 9." Lists various articles and discussions on industrial health and lists General Refractories Company as a member. General Refractories was a member of the following organizations: Industrial Health Foundation American Industrial Hygiene Association National Safety Council Refractories Institute American Ceramics Society / General Refractories was a member of the American Ceramic Society at least in 1949, 1950, 1952, and 1958. Numerous employees were members starting in 1930. American Ceramic Society Abstracts list numerous articles concerning asbestosis and a combination of silicosis and asbestosis. [The American Ceramic Society Abstracts contain numerous references to asbestosis and silicosis/ asbestosis medical articles which provided notice of the diseases to all members of the ACS. One of the General Exhibits is an ACS application form which indicates that all members receive the abstracts. In addition, in the deposition I did this winter, Everett, a General Refractories employee, stated that the Abstracts and Journal were sent to all members until sometime in the mid 1960's when the ACS began charging separately for them. This deposition was noticed to all parties.] He is a member of American Ceramic Society since early 1960's. Has seen Bulletin, Journal and Abstracts. Company was also a member. a r~ DRAFT 04/17/98 12:32 PM Abate v. ACandS. Baltimore City, dated 12/27/93, Interrogatory No. 40 Dates of membership: Industrial Hygiene Foundation 1954-1981 The Refractories Institute 1961-present National Safety Council 1930-present American Industrial Hygiene Association -unknown Martin v. Grefco, Allegheny Ctv., PA, dated 1/18/84, Interrogatory No. 21 Grefco was a member of The Refractories Institute, Industrial Health Foundation, and the McIntyre Foundation. In Re: Asbestos Cases, Baltimore City, MD, dated 5/13/92, Interrogatory No. 106 Grefco was a member of the following organizations: Industrial Hygiene Foundation 1954-1982 Refractories Institute 1961 -present National Safety Council 1970-present American Industrial Hygiene Association - dates unknown Deposition of Robert Lee Everett, dated 2/10/94, p. 163 L .4 - L.9 Doesn't know Mr. Kurtz, Vice President of American Refractories Corp. Deposition of Robert Lee Everett, dated 2/10/94, p. 164 L.9 - p. 165 L.9, p. 165 L.12L.16 American Refractories at 1935 symposium. Abate v. ACandS. Baltimore City, dated 12/27/93, Interrogatory No. 44 Dr. Faulkner, MD, an independent contractor, represented General Refractories at the 1955 Saranac Symposium. Deposition of Joseph L. Stein, dated 9/15/93, p. 9 L.20 - p. 10 L.11 Awareness of silicosis during 1954-1958. In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 107 Robert Bodnar, past employee of Grefco attended meetings of the Safety and Health Committee of the Refractories Institute. In Re: Asbestos Cases, Baltimore City, MD, dated 5/13/92, Interrogatory No. 109 Grefco subscribed to the National Safety News. DRAFT 04/17/98 12:32 PM Deposition of Robert Lee Everett, dated 2/10/94, p. 152 L.18 - p. 153 L.21, p. 154 L.5 - p 156 L.11, p. 156 L.15 - p. 157 L.15, p. 157 L.1 9-L .20 , p. 158 L .2 -L .1 4 , p. 158 L.21 - p. 159 L.5, p. 159 L .8 - L.13, p. 159 L.16 - p. 160 L.1, p. 160 L.7 L.13, p. 160 L.19- 161 L.18, p. 161 L.21 -p . 162 L.2, p. 162 L.6 -8 , p. 162 L.11 -1 4 , p. 162 L.17 - L.20 He has responsibility to provide safe and healthy working environment. 1939 PA Workmen's Compensation regulations discussed asbestos and silica. Doesn't know what he would have done if he had been told about asbestosis. In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 71 Grefco admits that it was in possession of written information concerning the health hazards of asbestos exposure prior to 1964. In Re: Asbestos Cases. Baltimore City, MD, dated 7/8/88, Requests for Admission No. 72 Abate v. ACandS, Baltimore City, dated 12/27/93, Interrogatory No. 25 Grefco admits it was informed orally o f health hazards relating to asbestos exposure prior to 1964. Grefco had no warning labels on the asbestoscontaining products it manufactured. Warning labels were put on rebranded Eagle-Picher products commencing June 9, 1964. Deposition of Joseph L. Stein, dated 9/15/93, p. 75 L.13 - p. 76 L.9, p. 77 L .8 - 18, p. 78 L.3 L.8 William W. Boyd was manager of specialty products. Manager at least from 1960 to late 60's when he retired. Specialty products includes castables and Fibrous Adhesive. Deposition of Joseph L. Stein, dated 9/15/93, p. 105 L.1 - p. 110 L.6 Eagle-Picher warnings in 1964. PCC-GR-006 Second Page of Document Written By J.M. Barnhart. This document should be attached to the EaglePicher letter sent to Boyd concerning warnings. It indicates that Johns-Manville was using warnings as of October 1964. DRAFT 04/17/98 12:32 PM Deposition of Joseph L. Stein, dated 9/15/93, p. 112 L.3 - p. 114 L.14, p. 114 L.17- p. 116 L.16 Boyd's reply to Eagle-Picher notice of warnings and labeling of Eagle-Picher rebrands. OC-GE-49 (OC Stipulation) 6/9/64 letter from William H. Boyd to John P. Harrington re: caution note. Read heading, paragraph 1. Letter from General Refractories to Eagle Picher states that, "I assume [the note] will be in rather small print and not too prominent on the bags, and therefore feel we may as well have the same caution note on our bags when they are reordered." Macon v. AC&S. Dauphin Cty., PA, Interrogatory No. 13 No warnings on products manufactured by Grefco. June 9, 1964 E-P put warning label on re-brand products. Warning is quoted. Deposition of Robert Lee Everett, dated 2/10/94, p. 166 L.11 -p . 167 L.13, p. 168 L.13L.16, p. 168 L.21 -p . 169 L.8, p. 169 L.11 - L.18, p. 169 L.21 - p. 170 L.2, p. 170 L .1 9 -p . 171 L.2, p. 171 L.9 - p. 172 L.13, p. 172 L.16 - p. 173 L 5 -L .1 1 , p. 173 L.15 Not aware of Eagle Picher warning. Doesn't know what he would have done if he had been told. Doesn't know what he would have told employees about respirators. He would like to know what materials he needs a respirator for. Deposition of Robert Lee Everett, dated 2/10/94, p. 36 L. 1 -L .8, p. 36 L .1 0 -L .1 3 Deposition of Joseph L. Stein, dated 9/15/93, p. 104 L.2 - L.17, p. 104 L.19- L.21 A t St. Louis he was not aware of any diseases including silicosis even though he worked with silica. Doesn't know if he would have told anyone about the diseases if he had known in 1967. Deposition of Robert Lee Everett, dated 2/10/94, p. 38 L.9 -p . 39 L.19, p. 40 L .1 -L .3 Doesn't clearly remember a safety program. Promoted to Plant Manager in 1968. Fibrous Adhesive and Litecast 30 produced there. Deposition of Robert Lee Everett, dated 2/10/94, p. 41 L.6 - L.19 Became aware of silicosis at Sproul. DRAFT 04/17/98 12:32 PM Deposition of Robert Lee Everett, dated 2/10/94, p. 53 L.12 - L.17 Respirators were made available to employees but they were not told when to wear them. Deposition of Robert Lee Everett, dated 2/10/94, p. 54 L.15 - p. 55 L.10, p. 55 L.12L.16 X-rays were taken due to use of silica. Deposition of Robert Lee Everett, dated 2/10/94, p. 58 L.12-L.13, p. 58 L.1 5-P . 59 L.5 There have been some awards for silicosis. Deposition of Robert Lee Everett, dated 2/10/94, p. 72 L .1 9 -p . 73 L.5 He had no knowledge at the time that the Grefco cement contained asbestos. Martin v. Grefco, Alleahenv Ctv.. PA, dated 1/18/84, Interrogatory No. 40 At least 25 employees are receiving disability payments. Martin v. Grefco. Alleahenv Ctv.. PA, dated 1/18/84, Interrogatory No. 41 Grefco does not know if any employees are suffering or have died from lung cancer. Martin v. Grefco. Alleahenv Ctv.. PA, dated 1/18/84, Interrogatory No. 42 Grefco does not know if any employees are suffering or have died from mesothelioma. Martin v. Grefco. Alleahenv Ctv.. PA, dated 1/18/84, Interrogatory No. 48 It appears at least some Grefco x-rays showed "pneumoconiosis." In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 68 Grefco did not place warnings on Litecast 30 and 30G and Fibrous Adhesive, but since 1970 has provided MSDS to customers upon request. Thurman v. A.P. Green. St. Louis, MO, dated 7/17/87, Interrogatory No. 73(b) General Refractories does not contend that prior to 1971 there was no substitute for asbestos for high and low heat insulation. Deposition of Robert Lee Everett, dated 2/10/94, p. 132 L.17 - p. 133 L.12 Does not recall problems in reformulating Litecast 30. DRAFT 04/17/98 12:32 PM Deposition of Robert Lee Everett, dated 2/10/94, p. 186 L.16 - 19 When switched over to asbestos free Litecast 30 they first used up the asbestos. Deposition of Robert Lee Everett, dated 2/10/94, p. 117 L.20 - p. 118 L.3 No effort to tell employees who worked with Litecast 30 and Fibrous Adhesive that they should be checked for asbestosis. Deposition of Robert Lee Everett, dated 2/10/94, p. 187 L.16-L.21 Abate v. ACandS. Baltimore City, dated 12/27/93, Interrogatory No. 219 Didn't tell workers they should take precautions after the decision was made to reformulate the products. Grefco did not recall any asbestos-containing products after it became aware of the potential health hazards of asbestos exposure. Deposition of Roland Howard King, dated 7/10/85, p. 24 L.6 p. 26 L.3 Admits found out about asbestos problem and started having Nicolet wax the edges. In Re: Asbestos Cases. Baltimore City, MD, dated 5/13/92, Interrogatory No. 50 Grefco's current document retention policy was implemented in January, 1973. Deposition of Robert Lee Everett, dated 2/10/94, p. 111 L.19 - p. 113 L.8 In 1973 they did not believe they should be handling asbestos so they started buying asbestos-containing fibrous adhesive from a vendor (it was J-M) rather then make it. In Re: Asbestos Cases, Baltimore City, MD, dated 7/8/88, Requests for Admission No. 70 Grefco admits that it did not recommend respirators for users of its products in 1964, 1966, 1968, 1970, 1972, and 1975. Deposition of Roland Howard King, dated 7/10/85, p. 12 L.16 p. 13 L.16 Asbestos removed from Dibond 60 in 1980. That is the first he was made aware of asbestos hazard. ,, Deposition of Joseph L. Stein, dated 9/15/93, p. 249 L.15 - p. 250 L.21 General Refractories was disposing of asbestos waste in 1980 so as not to be covered by new regulations. Deposition of Robert Lee Everett, dated 2/10/94, p. 124 L.17 - p. 125 L.15 First air sampling in the plant was conducted by OSHA in 1983 or 1984. DRAFT 04/17/98 12:32 PM Deposition of Robert Lee Everett, dated 2/10/94, p. 128 L.14 - p. 129 L.17, p. 129 L.20 p p. 130 L.1 He would still do air sampling even if it were not now required. Deposition of Robert Lee Everett, dated 2/10/94, p. 149 L.9 - L.14 General Refractories told him to start keeping records on hazardous materials in the late 1980's. Deposition of Joseph L. Stein, dated 9/15/93, p. 127 L.4 - L.12, p. 127 L.14 - p. 128 L.7, p. 128 L.12 - p. 129 L.11 President of company for seven years but doesn't know what their respiratory protection program is. Still, he is concerned about health of employees more than outsiders. [lisa\grefco\trlpres.doc]