Document pmwnwgggrBRRRKgnNQGk9xRgk

PRIVILEGED AND CONFIDENTIALNot To Bo Used Or Disseminated Except Upon Prior Permission By Georgia-Pacific Corporation In-House Counsel GEORGIA-PACIFIC PRODUCTS, USES, AND DISTRIBUTION As noted previously, there are a variety of gypsum-based products which were manufactured by Bestwall Gypsum Company from 1956 to 1965 and by Georgia-Pacific since 1965. It is important to note, however, that the majority of gypsum products produced and sold by Bestwall and Georgia-Pacific did not contain asbestos. A great many people in the litigation surrounding asbestos may recall the Bestwall or the Georgia-Pacific name. This recollection is usually based on having used non-asbestos containing products rather than the minor line of asbestos containing products manufactured by Bestwall/Georgia-Pacific. Other than wallboard and gypsum lath (board products), the products manufactured and sold by Bestwall/Georgia-Pacific fall into five general categories: ceiling and wall plasters, industrial plasters, acoustical plasters, joint systems and textures. Each will be discussed separately. Ceiling and Wall Plaster JProducts The vast majority of non-board sales in the Gypsum Division were in plaster products which never contained asbestos. Bestwall manufactured a line of wall and ceiling plasters for various uses in both residential and commercial projects. There was a line of SGP 0026932 PRIVILEGED AND CONFIDENTIALNot To B Used Or Disseminated Except Upon Prior Permission By Georgia-Pacific Corporation In-House Counsel molding plaster with the trade name Sunflower which many witnesses have recalled using, but which never contained asbestos. Likewise, various wall plasters which were used extensively prior to the wide use of gypsum drywall never contained asbestos. Despite names such as "fibered plaster", the plasters most often identified by witnesses are non-asbestos products. As a general rule, if a witness recalls a Bestwall or Georgia-Pacific plaster product even without specific trade name, it is likely that the product did not contain asbestos. The brand names of some of the Bestwall/Georgia-Pacific plaster products were: Neat Base Coat Plaster Lite-Mix Base Coat Plaster Wood Fibered Plaster Concrete Bond Plaster Gauging Plaster Molding Plaster Keene's Cement Prepared Sand Float Finish Plaster Dens - Cote Plaster Satin Spar Gauging Plaster Sunflower Molding Plaster -2- SGP 0026933 PRIVILEGED AND CONFIDENT!ALNot To Ba Used Or Disseminated Except Upon Prior Permission By Georgie-Psciflc Corporation In-House Counsel Plaster was usually applied in two or three coats, the first being the base or scratch coat, with an optional second "brown coat", and the third coat being the finish coat. The dry product shipped from the plant was mixed at the construction site with the addition of water and sometimes different aggregates such as sand, perlite or vermiculite. The wet plaster was troweled on by hand, in thicknesses ranging from 1/2" to 5/8" per coat for base coats and 1/8" for finish coats. The final coat could be given a "textured" pattern, if desired. Industrial Plasters Georgia-Pacific and Bestwall also had a line of industrial plasters which accounted for a large market share in this portion of the industry. Georgia-Pacific has produced plaster of paris for the crafts industry, molding plasters for various dental applications, plasters used in the glass industries, and metal casting plasters. None of these products ever contained asbestos, although some of them, such as the metal casting plasters, did contain asbestine talc. Although some plaintiffs' counsel like to -3- SGP 0026934 25fMD AND CONFIDENTIAL***> S? V*** Or Disseminated Except Upon Prior Permission By Geoye-Pecfte Corporation In-Nouse Counsel confuse talc with asbestos, there is in fact no basis mineralogically to associate the two, as has been confirmed by Dr. Art Langer, an expert in mineralogy. There is little likelihood of these products being an issue in most of our asbestos cases. Acoustical Plasters In the 1930's and 1940's, various companies developed acoustical plasters for use in buildings which needed enhanced acoustical properties, such as libraries, gymnasiums, auditoriums, churches, and other buildings with large assembly rooms. Bestwall's predecessor, Certain-Teed, joined in this marketing effort and developed a product named Kalite. Bestwall continued to market Kalite after its spin-off in 1956. The development of this product was an effort to reproduce formulations of competitors by analyzing their product. Kalite contained approximately 2.5% asbestos. Kalite for our litigation purposes was marketed between 1956 and 1959 when a replacement product known as Lite Acoustic was introduced. -4 - SGP 0026935 PRIVILEGED AND CONFIDENTIALNot To Bo Used Or Disseminated Except Upon Prior Permission By Georgia-Pacific Corporation In-House Counsel Kalite was manufactured exclusively at Acme, Texas, and Akron, New York, when Lite Acoustic was introduced it was designed especially for machine spray-on application. The asbestos content of this product ranged from 25-30%, and the following plants had formulas on file, although the actual amount of production at each is unknown: Acme, Texas; Akron, New York; Grand Rapids, Michigan; Fort Dodge, Iowa; Blue Rapids, Kansas; Brunswick, Georgia; and Siguard, Utah. Lite Acoustic was manufactured until 1963, when it was voluntarily removed from the market, having been unable to successfully compete and gain a market share. Unfortunately, we do not have accurate sales records indicating where these products were marketed. In 1985, Georgia-Pacific estimated that Bestwall had manufactured enough acoustical plaster between 1956 and 1963, to cover approximately four million square feet. As a basis of comparison, the Georgia-Pacific Center is 1.4 million square feet so the total production was about enough to do 3 to 4 large (50 story) office buildings. In 1988, we retained Dr. Robert Hall, an economist with the -5- SGP 0026936 f.*rCLEi3E0 AND CONFIDENTIALJSLjj n* Usld0r Oitsaminatad SS5LUo"/rl?f P#rmi*sion By Hoover Institute at Stanford University, to evaluate Bestwall's share of the acoustical market. His estimate was almost exactly the same, 3,888,000 square feet. The EPA booklet. Asbestos in Buildings. states that 329,000 tons of acoustical plaster is installed in buildings. Bestwall's market share, then, would be .328% of the total. Kalite was generally troweled on while Lite Acoustic was generally sprayed on in a (1/2") half inch coat over a base coat of regular gypsum (non-asbestos) plaster. Lite Acoustic remained somewhat soft after drying while Kalite was a considerably harder material. These two products account for most of Georgia-Pacific's alleged liability in property damage cases. We are very suspect of individuals' identification of this product given its poor market acceptance. Certainly only plasterers would have been involved in its use, as opposed to drywall workers. It was not used as an insulation material so individuals employed in that industry would not have utilized the product. -6- SGP 0026937 PRIVILEGED AND CONF10ENT1ALNot To Be Used Or Disseminated Except Upon Prior Permission By Georgia-Pacific Corporation In-Houee Counsel Joint Systems While technically the term "joint systems" applies to a wide variety of related products, this section will discuss only those joint systems known as joint compounds. The production of joint compound by Bestwall/Georgia-Pacific has always been as an accommodation to the purchasers of our gypsum wallboard. Our market share in this particular product has never approached that of the wallboard itself; it has been estimated by our sales people to have been about 1/3 of our wallboard market -- no more than 5% of the total market for joint compound. A great many customers would buy our wallboard but would buy our competitor's joint compound to finish it. For example, the largest commercial contractor in New York was Star Circo. We have been told by former employees that they bought Georgia-Pacific wallboard but only U. S. Gypsum joint compound. In some areas of the country, Georgia-Pacific never successfully penetrated the joint systems market. In the 1960's -7- SGP 0026938 PRIVILEGED AND CONFIDE NT1ALNot To Be Used Or Disseminated Except Upon Prior Permission By Georgia-Pacific Corporation In-Nouse Counsel and 1970's, we had only a few gypsum salespeople covering the northeast U.S. Our sales in the San Francisco Bay Area consisted of 12 sales between 1970 and 1978. Prior to 1969 when the Marietta plant opened, Georgia-Pacific could not compete in the South Florida market because of the prohibitive shipping costs fron Acme, Texas. Consequently, it is believed that our share of these markets is miniscule. It is recognized by almost everyone we have talked with that U. S. Gypsum controlled 50% - 60% of the joint systems market; National Gypsum about 25% - 30% and everyone else shared the remaining 10% - 25%. During the years of production, joint compound was marketed under various names, either as a dry powder or as a pre-mixed paste. The premixed paste (Ready Mix) was introduced in approximately 1964 and slowly gained preference over the dry products in most market areas. Ready Mix was sold in metal, and later plastic, buckets of 1 and 5 gallons and in 4 gallon plastic lined boxes in some areas of the country. Powdered joint -8- SGP 0026939 SEKFSssyusszssr"x- In-HouM Counsel compounds were manufactured for differing uses, with different compounds manufactured for the initial application (bedding) and for the final application (topping). Joint compound was used for filing joints between sheets of wallboard and covering nail holes in the wallboard. It could also be used in texturing applications and wall repairs. The joint compound was applied in a paste consistency, allowed to dry and then sanded. The asbestos content ranged from 2%-8\ and the exposure to asbestos fibers occurred either in the mixing of the powdered form, or the sanding of both the dry and the ready mix. After each application of compound, the compound was allowed to dry for 24 hours and then sanded smooth either before another application of the product or prior to finishing with paint or wallpaper. The use of drywall did not come into wide use in commercial buildings until approximately the 1960's. In the early years of drywall usage there was some amount of competition between the old plasters and the new drywallers. By in large, those who did plaster did not do drywall and visa versa. This is important -9- SGP 0026940 PRIVILEGED AND CONFIDENTIALNot To Ba Usad Or Disseminated Except Upon Prior Permission By Georgia-Pacific Corporation In-House Counsel information when confronted by individuals who claimed to have utilized our joint compounds. As a side note, these joint compounds were never used in any insulation or pipe and boiler applications. However, there were other products, unrelated to Georgia-Pacific, of a similar name which were used for pipe and boiler purposes. Joint compounds were marketed under the following names: All Purpose Triple Duty Topping Compound Speed Set/One Day Bedding compound Ready Mix Joint Compound lesturea Georgia-Pacific produced a line of ceiling textures for application to give decorative appearances to ceilings. These ceiling textures were more of a paint than a plaster and were used solely for decorative purposes. They were generally rolled on or sprayed on in a very thin coat (1/16"). They left an appearance - 10 - SGP 0026941 Privileged ano CONFIDE NTIAL- Not To Be Used Or disseminated Except Upon Prior Permission By Georgia-Pacific Corporation In-House Counsel of either stippled or swirled patterns and were used in both commercial and residential properties. The names of these products were as follows: Certex Bestex A Bestex B Bestex C Bestex D Bestex 1 Bestex 2 Georgia-Pacific Ceiling Texture Georgia-Pacific Wall Texture Denswall Wall Texture Denswall Ceiling Texture Dr. Hall has also attempted to assess our share of the national textures market but has been unable to provide us with a reliable estimation due to the lack of separate published data on this particular segment of the gypsum market. Since textures are included in the category of joint system, we assume that our market share for both joint compound and textures does not exceed 5% of the total national market. Miscellaneous Other Products There were various other products such as spackling compound, - 11 SGP 0026942 PRIVILEGED ANO CONFIDENT1ALNot To Bo Used Or Disseminated Except Upon Prior Permission Bv Georgia-Pacific Corporation lo-House Counsel patching plaster, drywall adhesive and laminating compound, which contained small amounts of asbestos. These products were used mostly for patching and repair work and were not a dominant force in the market. Bestwall and Georgia-Pacific also manufactured the following type of products which never contained asbestos Wall Board Ceiling Tiles Acoustical Ceiling Tiles Grabit (an adhesive for wallboards) The following charts (in part E) were prepared to give you a quick reference to Bestwall/Georgia-Pacific asbestos containing products. While all information is as accurate as possible, the specific dates must be used with caution. Often it is difficult, if not impossible to pinpoint the exact date of last sale, particularly from a specific location. Therefore, use all dates as general guidelines rather than exact dates. SGP 0026943