Document wDV61VJBkrBQvLB2LgOLOZaw3

V Circuit, in and for Dade County Case Mo.: 91--80,000 (42) ARMSTRONG'S RESPONSES TO MASTER PRELIMINARY INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS GENERAL OBJECTION, STATEMENT AND LIMITATIONS These responses are based on facts known to or believed by Armstrong World Industries, Inc., at the time of answer. 3ecause much of the information is sought from many years ago and is therefore difficult or impossible to reconstruct or retrieve, we reserve the right to amend these responses as, and if, new or better information becomes available or if any error is discovered. These responses are from AWI's records and knowledge and not those of its former wholly-owned subsidiary, Armstrong Contracting & Supply Corporation (hereinafter ACandS), which operated independent of AWI. Although AWI manufactured Nonpareil asbestos-containing insulation materials from approximately 1910 until the early 1930's, AWI is not aware of any current personal injury claims with respect to those products; thus, no answers are given concerning those products. AWI's contract department expanded into the high temperature insulation contracting field at the beginning of World War II, and AWI last sold an asbestos-containing insulation product in mid-1969. The responses set forth herein are limited in time and place to asbestos-containing thermal insulation products to which Plaintiffs may allege exposure and which were manufactured or sold by AWI during this time period. Because virtually all cases against AWI refer to insulation products, no answer is made concerning.floor products, gaskets materials, roofing products, adhesives, board or such other non-insulation ...products.. To the extent this Interrogatory or request calls for information beyond this limitation stated above, an objection is made thereto as being irrelevant, immaterial, burdensome, oppressive and/or not calculated to lead to the discovery of admissible evidence. To the extent the information contained herein differs in any respect from any prior Preliminary Interrogatories: 1. Objection. It is impossible for AWI to answer this interrogatory. AWI has been involved in the asbestos litigation for many years. During the course of said litigation, its legal representatives have reviewed voluminous records of itself and others, have conferred with many current and former employees of AWI and others, and have conferred with legal representatives of others. It has thus become impossible to distinguish sources of information in an accurate and meaningful way. 2 2. (a) Armstrong World Industries, Inc. (b) Pennsylvania (c) Liberty and Charlotte Streets, Lancaster, Pennsylvania (headquarters were located in Pittsburgh, Pennsylvania from 1891 to 1929). (d) 8/9/38 (e) Objection. The information sought is irrelevant to matters between Plaintiff and AWI. 3. In 1860, a partnership named John D. Glass & Company was formed. In 1864, the partnership's name became Armstrong Brother & Company. In 1891, the business was incorporated as Armstrong Brother & Company, Inc. There are no predecessor corporations to AWI. Until late 1957, this company had an insulation contract department which operated under the insulation division. Insulation products, including some which contained asbestos and were manufactured by other companies, were installed by the insulation contract department. In late 1957, ACandS was formed as a wholly--owned subsidiary of this company for the purpose of assuming the contract insulation business effective January 1, 1958. This former subsidiary, which operated independently of this company, was sold in 1969 to the North Lime Corporation, 120 North Lime Street, Lancaster, Pennsylvania. ACandS was involved in the installation of insulation products. Documents which may expand upon these responses are available for inspection. 4. AWI was not in the business of mining asbestos. AWI was not in the business of processing raw asbestos. AWI was not in the business of selling raw asbestos. Documents which may expand upon these responses are available for inspection. 5. (a-d) See Attachment A. Under our record retention schedule, sales records (invoices, bills of lading, etc.) for asbestos-containing insulation products no longer exist. All contract documents went with ACandS upon its formation in late 1957. LT Cork Covering which contained only a small percent of asbestos in the outside paper wrapper and was used as low temperature insulation, was sold from 1956-1959. Armaspray, was sold only to ACandS 1966-1969. We have no knowledge of any sales being made to the specified locations. Documents which may expand upon these responses are available for inspection. (f) Objection. This interrogatory is vague and ambiguous. 6. Yes. See response to Interrogatory No. 5. 7. Objection. This interrogatory is vague and ambiguous. Without waiving these objections, see Attachment A. 8. (a) Name of manufacturing company. (b) Trade name. (c) Time period. (d) Volume of transfer. (e) Purchaser. 4 (a) Unarco. (b) Armabestoa. (c) 1954-1956. (d) Unknown. (e) AWI purchased this product for use in its contract installation services. (a) Ehret Magnesia Manufacturing Company. (b) AWI 85% Magnesia Pipe Covering (included Calcium Siiicace inner layer for higher temperature applications.) (c) 1957. (d) Unknown. (e) AWI purchased this product for use in its contract installa tion services. This name was later assigned to ACandS. (a) Eagle-Picher. (b) Armatemp 166 Cement. At the time AWI relabeled Armatemp 166 (1954-1957), AWI was unaware that it contained asbestos. Through the course of litigation, Eagle-Picher has provided information that suggests Armatemp 166 contained asbestos. (c) 1954-1957. (d) Unknown. (e) AWI purchased this product for use in its contract installation services. This name was later assigned to ACandS. After 1957, AWI was required to be the signatory on certain relabeling agreements between the manufacturer of the products and ACandS. These products were purchased by, delivered zo ana used by ACandS in contracts of installation. AWI did not purchase, sell, or install these products. 9. Objection. This interrogatory is vague and ambiguous. Without waiving these objections, under our record retention schedule, sales records (invoices, bills of landing, etc.) for asbestos-containing insulation products no longer exist. All contract documents went with ACandS upon its formation in late 1957. LT Cork Covering which contained only a small percent of asbestos in the outside paper wrapper and was used as low temperature insulation, was sold from 1956 - 1959. Armaspray, was sold only to ACandS 1966-1969. Documents which may expand upon these responses are available for inspection. 10. Documents which may expand upon these responses are available for inspection. 11. None to our knowledge. 12. (a-c,e) The Beaver Falls Plant, Beaver Falls, Pennsylvania, commenced operation in 1903. Manufacturing operations ceased in 1969 at this facility, which was then used for a warehouse up to 1973, at which time the building was sold. The asbestos-containing insulation products manufactured by AWI at the Beaver Falls Plant were LT Cork Covering from 1956 to 1959 and Armaspray from 1966 to 1968. -b-- (d) When LT Cork Covering was manufactured, 2. Zinn (now deceased), was the plant manager. When Armaspray was manufactured, R. P. Steffe (now deceased) was the plant manager. (f) Under our record retention schedule, sales records for asbestos-containing insulation products no longer exist. All contract documents went with ACandS upon its formation in late 1957. Under our record retention schedule, sales records (invoices, bills of lading, etc.) for asbestos-containing insulation products no longer exist. All contract documents went with ACandS upon its formation in late 1957. LT Cork Covering which contained only a small percent of asbestos in the outside paper wrapper and was used as low temperature insulation, was sold from 1956-1959. Armaspray, was sold only to ACandS 1966-1969. We have no knowledge of any sales being made to the specified locations. Documents which may expand upon these responses are available for inspection. (g) See response to Interrogatory 4. 13. See Attachment A. In addition please refer to response to interrogatory no. 8 above regarding relabeled products. 14. (a-e) See Attachments A-E. (f) See Attachment C. (g) See Attachment A. (h) See Attachment D. 7 (i) The only manufacturing facility relevant to this litigation was the Beaver Falls Plant, Beaver Falls, Pennsylvania. The asbestos-containing insulation products manufactured by AWI at the Beaver Falls Plant were LT Cork Covering from 1956 to 1959 and Armaspray from 1966 to 1968. (j-k) See Attachment B. (1) See Attachment E. (ra) Under our record retention schedule, sales records for asbestos-containing insulation products no longer exist. All contract documents went with ACandS upon its formation in late 1957. We have no knowledge of any sales being made to specified geographic regions. Documents which may expand upon these responses are available for inspection. (n-q) Documents which may be relevant to these interrogatories are available for inspection. (r) LT-30 Cork Covering Trademark: Registered: November 8, 1955. Assigned to North Lime Corp.: August 1, 1969. (s) LT Cork Covering Patent: Patent Number: 2,776,231 Date of patent: January 1, 1957 Date of Application: June 28, 1954 (t) LT Cork Covering was first manufactured with a kraft paper cover. In 1956, asbestos paper was substituted for the kraft paper for the purpose of creating a more fire resistant surface. Armaspray originally contained a 6D5 chrysotile asbestos. In July, 1967, A. W. Araosite was substituted, and in January, 1968, S/33/65 asbestos was substituted. The initial asbestos change was due to the increased fiber length, greater wet strength and improved thermal conductivity of the 8 Amosrte. The next change was a resuit of the discontinuation of supply of A. w. Amosite, the substitution being based upon the supplier's recommendation. 15. Objection. This interrogatory/request contains an implicit assumption of matters not otherwise established, which renders the interrogatory/request as argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, not to our knowledge. 16. (a) AWX insulation mechanics employed by us were foreseeable users of asbestos-containing insulation products which AWI installed. Insulation mechanics employed by ACandS were foreseeable users of LT Cork Covering (1958 and 1959) and Armaspray (1966-1969). (b-c) Research continues with regard to the persons employed by AWI who were involved in the design of LT Cork Covering. W. G. Owens, Senior Research Scientist, and W. H. Yeager, Senior Lab Technician, participated in the design of Armaspray. Both Mr. Owens and Mr. Yeager have retired. Documents which may expand upon these responses are available for inspection. (d) Objection. This interrogatory is overly broad, vague and ambiguous. In addition, this interrogatory/request contains an implicit assumption of matters not otherwise established, which renders the interrogatory/request as argumentative, incapable of fair and correct answer. and without foundation. 17. 1 rider cur record retention schedule, sales racoros (invoices. sills of lading, etc.) for asbestos-containing insulation products no longer exist. All contract documents went with ACanaS upon its formation in late 1957. LT Cork Covering which contained only a smail percent of asbestos in the outside paper wrapper and was used as low temperature insulation, was sold from 1956-1959. Armaspray, was sold only to ACandS 1966-1969. We have no knowledge of any sales being made to the specified locations. Documents which may expand upon these responses are available for inspection. 18. This company has had sales offices nationwide over the years, including Jacksonville, Florida. 19. The asbestos fiber in Armaspray was purchased from Lake Asbestos of Quebec, Ltd. and from North American Asbestos Corporation. The asbestos paper in LT Cork Covering was purchased from Dobeckmun Company. Documents which may expand upon these responses are available for inspection. 20. Objection. The information sought by this interrogatory is currently at issue pending litigation. See Armstrong v. Aetna Casualty S Surety Company, et al. No. 31567, Los Angeles Superior Court. 21. AWI's understanding of the effects of asbestos on the health of workers may be generally summarized as follows: 10 AWI first: became aware of a potential risk of asbestosis to plant workers in \ the late 1930's at about the time that the Commonwealth of Pennsylvania listed asbestosis as a compensable disease in its Occupational Disease Act and regulations (1937). The payment of life insurance, weekly sickness and non-occupational benefits, total and permanent disability benefits, and retirement pensions were undertaken by Metropolitan Life Insurance Company in 1931 for AWI and it undertook a number of plant surveys over time in order to determine ratings for premiums and to identify and eliminate any potentially harmful conditions. Air samples were taken in 1939, and one sample was viewed as requiring a reduction of atmospheric dust for safety purposes. A survey in 1948 included a description of asbestosis and stated that "the threshold limit for asbestos dust adopted by the American Conference of Governmental Hygienists at their 1948 meeting is 5 million particles of asbestos per cubic foot of air." AWI now understands that such statement by Metropolitan was consistent with a report of the U.S. Public Health Service, authored by Dr. W. C. Dreessen in 1938, entitled "A Study of Asbestosis in the Asbestos Textile Industry," wherein Dr. Dreessen stated that the threshold concentration of dust should be the highest dust concentration that would not produce pneumoconiosis in an originally healthy workman during his entire working life, and that "5 million particles per cubic foot may be regarded tentatively as a threshold value for asbestos dust exposure until better data are available." Dr. Dreessen further stated that "it would seem that if the dust concentration in asbestos factories could be kept below 5 million particles . . ., new cases of asbestosis probably would not appear." 11 AWI employed union insulators in its insulation contracting business until the end of 1957. Upon information and belief, AWI's worker's compensation insurance carrier visited jobs in progress to inspect job conditions and observe if reasonable safety precautions were being taken: AWT. is not aware that any such visits resulted in any observation or finding that insulators were exposed to asbestos dust above the threshold limit values or that hazardous conditions relating to asbestos existed on its job sites. AWI was also informed that the.Massachusetts Department of Health Division of Industrial Hygiene concluded that there did not seem to be an apparent dust hazard in the occupation of pipe covering or in the mixing of cement for pipe and boiler covering. Furthermore, AWI was told by Keasbey & Mattison, the manufacturer of heat insulation materials it was installing, that its employees had been manufacturing the products for years without any ill effects. AWI now understands that the Massachusetts Department of Health Division of Industrial Hygiene Report was consistent with a 1946 study of pipecoverers entitled "A Health Survey of Pipe Covering Operations and Constructing Naval Vessels," authored by Dr. Fleischer, Professor Drinker and others, where they concluded that "it would appear that asbestos pipe covering of naval vessels is a relatively safe occupation." AWI now understands that the Fleischer/Drinker conclusions were not criticized in the American medical literature until about the time of Dr. Selikoff's pioneer publications in the mid-1960s. AWI first became aware of these pioneering studies of Dr. Selikoff in the late 1960s concerning the possible risk of asbestosis, lung cancer and mesothelioma to insulators. AWI is unaware that asbestos is 12 causally associated with any other form of cancer. Documents which may expand upon these responses are available for inspection. 22. See Attachment G. 23. AWI's understanding of the effects of asbestos on the health of workers may be generally summarized as follows: AWI first became aware of a potential risk of asbestosis to plant workers in the late 1930's at about the time that the Commonwealth of Pennsylvania listed asbestosis as a compensable disease in its Occupational Disease Act and regulations (1937). The payment of life insurance, weekly sickness and non-occupational benefits, total and permanent disability benefits, and retirement pensions were undertaken by Metropolitan Life Insurance Company in 1931 for AWI and it undertook a number of plant surveys over time in order to determine ratings for premiums and to identify and eliminate any potentially harmful conditions. Air samples were taken in 1939, and one sample was viewed as requiring a reduction of atmospheric dust for safety purposes. A survey in 1948 included a description of asbestosis and stated that "the threshold limit for asbestos dust adopted by the American Conference of Governmental Hygienists at their 1948 meeting is 5 million particles of asbestos per cubic foot of air." AWI now understands that such statement by Metropolitan was consistent with a report of the U.S. Public Health Service, authored by Dr. W. C. Dreessen in 1938, entitled "A Study of Asbestosis in the Asbestos Textile Industry," wherein Dr. Dreessen stated that the threshold concentration of dust should 13 be the highest dust concentration that wouid not produce pneumoconiosis in an originally healthy workman during his entire working life, and that "5 million particles per cubic foot may be regarded tentatively as a threshold value for asbestos dust exposure until better data are available." Dr. Dreessen further stated that "it would seem that if the dust concentration in asbestos factories could be kept below 5 million particles . . ., new cases of asbestosis probably would not appear." AWI employed union insulators in its insulation contracting business until the end of 1957. Upon information and belief, AWI's worker's compensation insurance carrier visited jobs in progress to inspect job conditions and observe if reasonable safety precautions were being taken: AWI is not aware that any such visits resulted in any observation or finding that insulators were exposed to asbestos dust above the threshold limit values or that hazardous conditions relating to asbestos existed on its job sites. AWI was also informed that the Massachusetts Department of Health Division of Industrial Hygiene concluded that there did not seem to be an apparent dust hazard in the occupation of pipe covering or in the mixing of cement for pipe and boiler covering. Furthermore, AWI was told by Keasbey & Mattison, the manufacturer of heat insulation materials it was installing, that its employees had been manufacturing the products for years without any ill effects. AWI now understands that the Massachusetts Department of Health Division of Industrial Hygiene Report was consistent with a 1946 study of pipecoverers entitled "A Health Survey of Pipe Covering Operations and Constructing Naval Vessels," authored by Dr. Fleischer, Professor Drinker and others, where they 14 concluded that "it would appear chat asbestos pipe covering of naval vessels is a relatively safe occupation." AWI now understands that the ?leischer/Drinker conclusions were not criticized in the American medical literature until about the time of Dr. Selikoff's pioneer publications in the mid-1960s. AWI first became aware of these pioneering studies of Dr. Selikoff in the late 1960s concerning the possible risk of asbestosis, lung cancer and mesothelioma to insulators. AWI is unaware that asbestos is causally associated with any other form of cancer. Documents which may expand upon these responses are available for inspection. 24. Objection. This interrogatory/request contains an implicit assumption of matters not otherwise established, which renders the interrogatory/request as argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, to our knowledge, no such studies were conducted. 25. Objection. This interrogatory/request contains an implicit assumption of matters not otherwise established, which renders the interrogatory/request as argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, to our knowledge, no such studies were conducted. 26. Objection. This interrogatory/request contains an implicit assumption of matters not otherwise established, which renders the interrogatory/request as argumentative, incapable of fair and correct answer, and without foundation. 15 27. Objection. This interrogatory/request contains an implicit assumption of matters not otherwise established, which renders the interrogatory/request as argumentative, incapable of fair and correct answer, and without foundation. Further, objection. The term "health study" is vague, ambiguous and unintelligible. Without waiving same, Armstrong did not direct to be performed, sponsor, finance or receive the results of any such tests or studies. The payment of life insurance, weekly sickness and non-occupational benefits, total and permanent disability benefits, and retirement pensions were undertaken by Metropolitan Life Insurance Company in 1931 for Armstrong and it undertook a number of plant surveys over time in order to determine ratings for premiums and to identify and eliminate any potentially harmful conditions. Similar surveys by other entities took place in later years. Documents which may expand upon these responses are available for inspection. 28-32. AWI's understanding of the effects of asbestos on the health of workers may be generally summarized as follows: AWI first became aware of a potential risk of asbestosis to plant workers in the late 1930's at about the time that the Commonwealth of Pennsylvania listed asbestosis as a compensable disease in its Occupational Disease Act and regulations (1937). The payment of life insurance, weekly sickness and non-occupational benefits, total and permanent disability benefits, and retirement pensions were undertaken by Metropolitan Life Insurance Company in 1931 for AWI and it undertook a number of plant surveys over time in order to determine ratings for premiums and to identify and eliminate any potentially harmful conditions. Air samples were taken in 1939, and one sample was viewed as requiring a reduction of atmospheric dust for safety purposes. A 16 survey in 1948 included a description of asoestosis and stated that 'the threshold limit for asbestos dust adopted by the American Conference of Governmental Hygienists at their 1948 meeting i3 5 million particles of asbestos per cubic foot of air." AW I now understands that such statement by Metropolitan was consistent with a report of the U.S. Public Health Service, authored by Dr. W. C. Dreessen in 1938, entitled "A Study of Asbestosis in the Asbestos Textile Industry," wherein Dr. Dreessen stated that the threshold concentration of dust should be the highest dust concentration that would not produce pneumoconiosis in an originally healthy workman during his entire working life, and that "5 million particles per cubic foot may be regarded tentatively as a threshold value for asbestos dust exposure until better data are available." Dr. Dreessen further stated that "it would seem that if the dust concentration in asbestos factories could be kept below 5 million particles . . ., new cases of asbestosis probably would not appear." AWI employed union insulators in its insulation contracting business until the end of 1957. Upon information and belief, AWI's worker's compensation insurance carrier visited jobs in progress to inspect job conditions and observe if reasonable safety precautions were being taken: AWI is not aware that any such visits resulted in any observation or finding that insulators were exposed to asbestos dust above the threshold limit values or that hazardous conditions relating to asbestos existed on its job sites. AWI was also informed that the Massachusetts Department of Health Division of Industrial Hygiene concluded that there did not seem to be an apparent dust hazard in the occupation of pipe covering or in the mixing of cement for pipe 17 and boiier covering. Furthermore, AWI was told by Keasbey & Mattison, the manufacturer of heat insulation materials it was installing, that its employees had been manufacturing the products for years without any ill effects. AWI now understands that the Massachusetts Department of Health Division of Industrial Hygiene Report was consistent with a 1946 study of pipecoverers entitled "A Health Survey of Pipe Covering Operations and Constructing Naval Vessels," authored by Dr. Fleischer, Professor Drinker and others, where they concluded that "it would appear that asbestos pipe covering of naval vessels is a relatively safe occupation." AWI now understands that the Fleischer/Drinker conclusions were not criticized in the American medical literature until about the time of Dr. Selikoff's pioneer publications in the mid-1960s. AWI first became aware of these pioneering studies of Dr. Selikoff in the late 1960s concerning the possible risk of asbestosis, lung cancer and mesothelioma to insulators. AWI is unaware that asbestos is causally associated with any other form of cancer. Documents which may expand upon these responses are available for inspection. 33-35. Objection. This Interrogatory contains an implicit assumption of matters not otherwise established, which renders the Interrogatory as argumentative, incapable of fair and correct answer, and without foundation. Without waiving same and subject thereto, AWI states that since the beginning of World War II, AWI manufactured only two asbestos-containing thermal insulation products. LT Cork Covering which contained only a small percent of asbestos in the outside paper wrapper and was used as low temperature insulation, was sold from 1956 - 1959. Judge Robert M. Parker granted 18 Judgment N.O.V. in Graceriel v. Fibreboara Corporation, at al (E.D. Texas June 13, 1982) (Order attached) denying plaintiff's claims that LT Cork Covering was defective in design and marketing and holding that AWI "shall not be liable to the plaintiff for any exposure to plaintiff, if any, from LT Cork Covering." For Armaspray manufactured and sold only from August 1966 until mid-1969, Armstrong Contracting & Supply Corporation published safety precautions to be followed in all applications. This precaution was not placed on the container but is believed to have been presented in the Armstrong Contracting & Supply Corporation construction manual. It is our understanding that the specially trained insulation mechanics applying Armaspray were instructed according to the provisions of the construction manual. Armaspray was furnished by this Defendant exclusively to Armstrong Contracting & Supply Corporation. For applications of Armaspray with A-200 spray equipment, the safety precaution read: "Always wear a U.S. approved respirator when spraying. If tamping in the vicinity of the actual spray operator, the tamper should also wear a respirator." For application of Armaspray with the Armaspray junior spray machine, the safety precaution read: "Always wear an MSA approved respirator when spraying. If tamping in the vicinity of the actual spray operator, the tamper should also wear a respirator. 19 Armaspray was sold by this Defendant exclusively to Armstrong Contracting & Supply Corporation (now ACandS, Inc.) from 1966 to 1969. Armaspray was packaged in bags containing the Armstrong Contracting & Supply Corporation label. Documents which may expand upon these responses are available for inspection. 36. Objection. This Interrogatory contains an implicit assumption of matters not otherwise established, which renders the Interrogatory as argumentative, incapable of fair and correct answer, and without foundation. Without waiving same and subject thereto, AWI states that since the beginning of World War II, AWI manufactured only two asbestos-containing thermal insul ation products. LT Cork Covering which contained only a small percent of asbestos in the outside paper wrapper and was used as low temperature insul ation, was sold from 1956 - 1959. Judge Robert M. Parker granted Judgment N.O.V. in Gracedel v. Fibreboard Corporation, et al (E.D. Texas June 13, 1982) (Order attached) denying plaintiff's claims that LT Cork Covering was defective in design and marketing and holding that AWI "shall not be liable to the plaintiff for any exposure to plaintiff, if any, from LT Cork Covering." For Armaspray manufactured and sold only from August 1966 until mid-1969, Armstrong Contracting & Supply Corporation published safety precautions to be followed in all applications. This precaution was not placed on the container but is believed to have been presented in the Armstrong Contracting & Supply Corporation construction manual. It is our understanding that the specially trained insulation mechanics applying Armaspray were instructed according to the provisions of the construction manual. Armaspray was furnished by this Defendant exclusively to Armstrong Contracting & Supply Corporation. For applications of Armaspray with A-200 spray equipment, the safety precaution read: "Always wear a U.S. approved respirator when spraying. If tamping in the vicinity of the actual spray operator, the tamper should also wear a respirator." For application of Armaspray with the Armaspray junior spray machine, the safety precaution read: "Always wear an MSA approved respirator when spraying. If tamping in the. vicinity of the actual spray operator, the tamper should also wear a respirator.M Armaspray was sold by this Defendant exclusively to Armstrong Contracting & Supply Corporation (now ACandS, Inc.) from 1966 to 1969. Armaspray was packaged in bags containing the Armstrong Contracting & Supply Corporation label. Documents which may expand upon these responses are available for inspection. 37. Objection. This interrogatory is overly broad. Without waiving same, (a) LT Cork Covering brochures and Armstrong Industrial Insulation brochures were prepared by us. (b) We have no records concerning the dates that the LT Cork Covering brochure was forwarded to customers but believe it would have been around 21 1956-1559. We believe the Armstrong Industrial Insulation brocnures were made available at various times during the period AWI had a contract unit. Documents which may expand upon these responses are available for inspection. 38. Because of the lapse of years, we are unable to state each and every magazine or trade publication in which our asbestos insulation products were advertised. We believe they may have been advertised in the usual trade publications. 39. The brochures described in response to interrogatory no. 37 contained instructions for proper installation and use. 40. Prior to 1958, when this company operated an insulation contracting unit, AWI believes it received a total of nine claims for alleged pulmonary illness, possibly related to alleged asbestos exposure. Not all of these claims resulted in a payment by AWI. Generally, AWI was only one of a number of employers named. During this same period, AWI received an average of 500 to 600 claims per year by its contact employees for workers' compensation, of which only the claims noted above may have allegedly related to asbestos. Upon receipt of the first claim in 1952, AWI also received a report from the Commonwealth of Massachusetts, Department of Labor and Industries, Division of Occupational Hygiene, that stated there did not seem to be an apparent dust hazard in the occupation of pipecovering or in the mixing of cement for pipe and boiler covering. 22 The Travelers Insurance Company insured AWI's contract operation, including the administration of workers' compensation claims, and visited selected jobs in progress to inspect job conditions and observe if reasonable safety precautions were being taken and at no time reported to AWI that insulators were exposed to asbestos dust above the threshold limit values or that hazardous conditions relating to asbestos existed on its job sites. AWI's insurance department, in providing insurance administrative services for ACandS, also received workers' compensation claims by employees of that company (until 1969) and others, including Armstrong Cork Company, alleging pulmonary illness possibly related to asbestos exposure. In reference to a second claim filed, AWI was assured by Keasbey & Hattison, the manufacturer of the heat insulation materials in question, that its employees had been manufacturing such products for years without any ill effects. In early 1957, Travelers advised AWI that Travelers' engineering department was planning to survey a current insulating job. Travelers stated that it was felt that it would be able to develop recommendations which would prevent or minimize this exposure, and that as soon as it had anything to report, it would submit its findings. AWI left the contracting business at the end of 1957 when that business was assumed by ACandS. AWI has no current record of Traveler's findings. In April 1968, Canadian Johns-Manville Company, Ltd., sent a mailing to numerous companies, including AWI, which contained the minutes of the first six meetings of the Scientific Committee of the Institute of Occupational and Environmental Health of the Quebec Asbestos Mining Association. AWI was never a member of QAMA or present at such 23 meetings. This literature was immediately sent on to ACandS with the comment from AWI's insurance manager that, prior to receiving this information, he had no idea of the extent of the research work being done in this field. Soon thereafter, ACandS assumed responsibility for monitoring its own workers' compensation claims. The products at issue in the workers' compensation claims were typically pipe covering and cements. AWI did not manufacture these products, and no product of any kind manufactured by AWI was ever found to be the cause of any condition of any claimant in any of these workers' compensation claims. See Attachment K. First Ten P.I. Suits Filed Against AWI Alleging Asbestos-Related Injury from Exposure to Asbestos Insulation Products Manufactured or Sold by AWI Caption, Docket No., Court, State, Date Filed (a) John A. Karjala v. Armstrong Cork Company, et al. No. 5-71-18; United States District Court, Fifth Division, Minnesota; May 3, 1971. (b) Floyd Gustafson v. Armstrong Cork Company, et al. No. 5-71-40; United States District Court, Fifth Division, Minnesota; May 20, 1971. (c) Evelyn Roderman, etc. v. Armstrong Cork Company, et al. No. C72-390; United States District Court, Northern District of Ohio; April 25, iS72. 24 (d) Thomas S. Hartweil v. Armstrong Cork Company, ec ai. No. 7313; United States District Court, Eastern District of Texas; April 12 1972. (e) Rose Ann Ricci, etc. v. Armstrong Cork Company, et al. No. C72-507; United States District Court, Northern District of Ohio; May 18, 1972. (f) Clarence A. Borel v. Armstrong Cork Company, et al. No. 6449; United States District Court, Eastern District of Texas; Filed October 20, 1969; Armstrong not named as a defendant until February 18, 1970. (g) Buena Mae McDaniel v. Armstrong, et al. No. 6967; United States District Court, Eastern District of Texas; June 24, 1971. (h) Carol Antholz, etc. v. Armstrong Cork Company, et al. No. 5-70 CIV 105; United States District Court, Fifth Division, Minnesota; January 7, 1971. (i) Samuel Potter v. Armstrong Cork Company, et al. No. 6329; United States District Court, Eastern District of Texas; February 24, 1970. (j) Betty Sedlock, etc. v. Armstrong Cork Company, et al. No. C72-395 25 United States District Court, Nortnern Di3tricr of Ohio; April 25, 1972. 41. AWI belonged to the National Mineral Wool Association from 1947 to 1950 and again from 1953 until 1962. AWI has not been a member of any other national trade association or organization whose concern was the manufacture of asbestos-containing insulation products during the relevant time period that AWI manufactured and/or sold asbestos-containing insulation products. As a contractor, AWI's contract department belonged to numerous local contractor associations? AWI ceased such membership by the end of 1957 when it left the contracting business. Later, after AWI no longer manufactured or sold asbestos-containing insulation products, AWI had an associate membership in two National Trade Associations in order to market its low temperature insulation products such as Armaflex. Documents which may expand upon these responses are available for inspection. 42. AWI has a library in Lancaster, Pennsylvania which contains engineering and manufacturing information, but, there was no library established specifically for industrial hygiene, medicine or safety. Documents which may expand upon these responses are available for inspection. IOMMONWEALTH OF PENNSYLVANIA COUNTY OF LANCASTER SS I, the undersigned, J. H. Miller, Jr., being-first duly sworn according to law, depose and say that I am an Assistant Secretary of Armstrong World Industries, Inc. The information contained in the responses hereto was gathered pursuant to my overall guidance by employees of this company. I have no personal knowledge of same but am informed and therefore believe the answers to be true and correct. The responses have been prepared by counsel. I am executing this affidavit solely for the purpose of affixing the Company's signature hereto. DATED March 6. L992 ARMSTRONG WORLD INDUSTRIES, INC A Pennsylvania Corporation On this 6th day of March 1992, before me personally appeared J. H. Miller, Jr., to me known to be the person described herein, and who executed the foregoing instrument and -who acknowledged that he voluntarily executed the same. attachment A ARMSTRONG'S CONTRACT DEPARTMENT Armstrong historically was a cold storage manufacturer and contractor, supplying cork insulation products which were installed by its employees in dairies, ice houses, etc. Except for a limited high pressure product line manufactured 1910-1930, Armstrong's main involvement with asbestos-containing insulation products began at the beginning of World War II when its Contract Department was first able to install products manufactured by others. Although Armstrong remained primarily a cold storage contractor, the high temperature business grew until the end of 1957, when the contracting business was taken over by ACandS. Documents which may expand upon these responses are available for inspection. PRODUCTS MANUFACTURED BY OTHER COMPANIES AND TWSTnT.T-Bn RY ARMSTRONG CONTRACT EMPLOYEES Keasbey & Mattison (1939-1957) The following products were sold by Keasbey & Mattison Company for installation by Armstrong's contract department at various times and locations; not every product was available at all times and at every location. 85% Magnesia Pipe Covering & Block and Cement were used to insulate pipes and surfaces with temperatures up to 600F. Hy-Temp Pipe Covering & Block and Cement were used to insulate heat lines and surfaces with temperatures ranging from 600F to 1900F. Kamatt Pipe Covering was used to insulate pipes with temperatures up to 750F. Kaytherm Block was used to insulate surfaces with temperatures up to 1500F. Mani-Ply Insulations were used to insulate pipes with temperatures up to 500F. Bestfelt Pipe & Block & Sheet was used to insulate temperatures up to 700F. The pipe covering was used on lines subject to vibrations. Air Cell Insulations were used on lines or surfaces with temperatures up to 300F. Simplex Pipe Insulations were used to insulate lines with temperatures up to 300F where a water-repellant surface was needed. Duplex Wool Felt Pipe Insulation was used to insulate hot or cold water lines 40F to 210F. KSM Asbestos Insulating Cements: No. 151-smooth, hard surface; No. 152general utility cement; Velvet Hard Finish - hard gloss finish over blocks or cements; Mineral Wool - used in place of block insulation; Amblerex No. 2 - up to 1000F. K. P. Asbestos Floats were used to give a dense, tough, hard quality to the final asphalt plastic finish on walls of low temperature rooms (EX 25 asbestos in earlier years). Page 1 of 2 Uaarco (1954-'.956 ) : Arraabestos Pipe Covering & Block was used to insulate pipes with temperatures up to 750F or 1200F, or surfaces up to 1200F. Shret Magnesia (1957): 85% Magnesia Pipe Covering and Block (and Calcium Silicate Pipecovering for use as an inner layer with 85% magnesia) was used to insulate pipes and surfaces with temperatures ranging from 600F (85% Magnesia alone) to 1200F (both layers). Baldwin Hill (1951-1956): Baldwin-Hill #1 Insulating Cement, and later Mineral Wool (Powerhouse) Cement, was used for plastic insulation on irregular surfaces up to 1800F. Owens-Illinois (1957): Kaylo Pipe Covering & Block was used to insulate pipes and surfaces with temperatures up to 1200F; Kaylo-20, up to 1800F. Eagle-Picher (1954-1957): Armatemp 166 Cement was used as an all-purpose insulating material on surfaces up to 1800F. At the time AWI relabeled Armatemp 166 (1954-1957), AWI was unaware that it contained asbestos. Through the course of litigation, Eagle-Picher has provided information that suggests Armatemp 166 contained asbestos. PRODPCTS MAKPFACTPRED BY ARMSTRONG LT Cork Covering (1956-1959) was a pipe insulation, -120F to 200F. Armaspray (1966-1968) was used by AC&S to insulate large irregular surfaces, up to 1600F. Page 2 of 2 Attachment B ARMSTRONG'8 CONTRACT DEPARTMENT Armstrong historically was a low temperature insulation manufacturer and contractor, supplying cork insulation products which were installed by its employees in dairies, ice houses, etc. Except for a limited product line manufactured from approximately 1910-1933, Armstrong's main involvement with high-temperature asbestos-containing insulation products began -at the beginning of World War II, when its Contract Department first obtained the right to install products manufactured by Keasbey & Mattison. Armstrong remained primarily a cold storage contractor until the end of 1957, when the contracting business was taken over by ACandS. Documents which may expand upon these responses are available for inspection. PRODUCTS MANUFACTURED BY OTHER COMPANIES AND TWTT.T.ipi HY ARMSTRONG CONTRACT EMPLOYEES Keasbey & Mattison (1939-1957): The following products were sold by Keasbey & Mattison Company for installation by Armstrong's contract department at various times and locations; not every product was available at all times and at every location. 85% Magnesia Pipe Covering & -Block was molded. The pipe covering was furnished in 3' half sections (split horizontally) and furnished with a factory-applied canvas jacket, forming a hinge and lap. The block was furnished in 3' x 6" x 1-1/2" segments. 85% Magnesia Cement was.sold in powder form. Hy-Temp Pipe Covering & Block was molded. The pipe covering was furnished in 3' lengths or tubular half sections in thicknesses from 1" to 3" for pipe sizes 1/2" to 10" in diameter. The block was furnished in 3' lengths and 3", 6", 9" and 12" widths with thicknesses from 1" to 4". Hy-Temp Cement was sold in powder form. Kamatt, a molded pipe covering, was furnished in 3' lengths and thicknesses of 2", 2-1/2" or 3" for all pipe sizes over 12" in diameter. Kaytherm Block was precision molded and gray colored. It was furnished in 3' lengths by 6" widths with thicknesses of 1-1/2" or 2". Mani-Ply Insulation, a pipe covering, was furnished in 3' lengths in thicknesses of 1", 1-1/2" or 2". Bestfelt Pipe Covering was furnished in 3' lengths of 1" standard thicknesses for pipe sizes 1-1/2" to 24" in diameter. The Bestfelt Block and Sheets were furnished in 3' lengths and 6", 9", 18" or 36" widths with thicknesses from 1/2" to 4". Air Cell Insulations were available in pipe covering, sheet, or block form. The pipe covering was furnished in 3' lengths and thicknesses of 1/2" to 1", for pipe sizes 1/2" to 6" in diameter. The sheets and block were furnished in 6", 9", 12", 18", 36" or 72" lengths and 3" widths, with thicknesses from 1/2" to 4". Simplex Pipe Insulation was available only with 3 or 4 plies of felt per inch and 3' lengths for pipe sizes 1/2" to 8" in diameter. Page 1 of 2 Duplex Wool Felt Pipe Insulation had a white covering. It was furnished in 3' lengths and thicknesses from 1/2" to 2". K&M Asbestos Insulating Cements: Nos. 151, 152, Velvet Hard Finish, Mineral Wool and Amblerex No. 2 were sold in powder form. K. P. Asbestos Floats were sold in powder form (Ex #25 in earlier years). Unarco (1954-1956): Armabestos, a molded pipe covering and block, was a grayish, hard substance. The pipe covering was furnished in 3' lengths in thicknesses from 1" to 5" for pipe sizes 1/2" to 24" in diameter. The block was furnished in 3' lengths and 6", 12", 18" or 36" widths with thicknesses from 1" to 3". Khret Magnesia (1957): 85% Magnesia Pipe Covering (Calcium Silicate inner layer available), a molded material, was available for pipes 2" or greater in diameter. Baldwin Hill (1951-1956): Baldwin-Hill #1 Insulating Cement, and later Mineral Wool (Powerhouse) Cement, was sold in powder form. Owens-Illinois (1957): Kaylo, a molded pipe covering and block, was rigid, preformed, and white in appearance. Kaylo-20 was colored pink with iron oxide for identification purposes. The pipe covering was furnished in 3' lengths and thicknesses from 1" to 3" for pipe sizes 1/2" to 39" in diameter. The block was furnished in 18" or 36" lengths and 3", 6", 12" or 18" widths with thicknesses from 1" to 3". Eagle-Picher (1954-1957): Armatemp 166 Cement was sold in powder form. At the time AHI relabeled Armatemp 166 (1954-1957), AHI was unaware that it contained asbestos. Through the course of litigation, Eagle-Picher has provided information that suggests Armatemp 166 contained asbestos. PRODUCTS MANUFACTURED BY ARMSTRONG LT Cork Covering (1956-1959) consisted of precision cut segments of cork board adhered to a backing of aluminum foil with a 16/1000" outer covering of nonfriable asbestos paper. Armaspray (1966-1968), a spray-on insulation, was gray in color and granular. Page 2 of 2 ARMSTRONG'S CONTRACT DEPARTMENT Attachment c Armstrong historically was a low temperature insulation manufacturer and contractor, supplying cork insulation products which were installed by its employees in dairies, ice houses, etc. Except for a limited product line manufactured from approximately 1910-1933, Armstrong's main involvement with high-temperature asbestos-containing insulation products began at the beginning of World War II, when its Contract Department first obtained the right to install products manufactured by Keasbey & Mattison. Armstrong remained primarily a cold storage contractor until the end of 1957, when the contracting business was taken over by ACandS. Documents which may expand upon these responses are available for inspection. PRODUCTS MANUFACTURED BY OTHER COMPANIES AND TwaraT.T.wn BY ARMSTRONG CONTRACT EMPLOYEES Keasbey Mattison (1939-1957): The following products were sold by Keasbey & Mattison Company for installation by Armstrong's contract department at various times and locations; not every product was available at all times and at every location. 85% Magnesia Pipe Covering & Block and Cement contained approximately 10% asbestos. We have no knowledge as to the type. Hy-Temp Pipe Covering & Block and Cement contained approximately 13% asbestos. We have no knowledge as to the type. Kamatt Pipe Covering contained amosite asbestos. We have no knowledge as to the percentage. We have no knowledge as to the type or percentage of asbestos contained in Kaytherm Block. We have no knowledge as to the type or percentage of asbestos contained in Mani-Ply Insulation. We have no knowledge as to the type or percentage of asbestos contained in Bestfelt Pipe 6 Block & Sheet. Air Cell Insulations and Simplex Pipe Insulations consisted of layers of flat and corrugated asbestos felt which was approximately 75% asbestos bonded together with a sodium silicate, in a special laminating process. We have no knowledge as to the type of asbestos. Duplex WOol Felt Pipe Insulation was composed of creped felt, waterproof felt binder, and a canvas jacket in addition to asbestos paper. We have no knowledge as to the type or percentage of asbestos. We have no knowledge as to the type or percentage of asbsetos in the K&M Asbestos Insulating Cements (Nos. 151 and 152, Velvet Hard Finish, Mineral Wool and Amblerex No. 2) K. P. Asbestos Floats were asbestos; however, we have no knowledge as to the type of asbestos (Ex 25 asbestos in earlier years). Unarco (1954-1956): Armabestos Pipe Covering & Block contained approximately 50% amosite asbestos. Page 1 of 2 Ehret Magnesia (1957): He have no knowledge as to the percentage or type of asbestos contained in 85% Magnesia Pipe Covering (Calcium Silicate inner layer available). Baldwin Hill (1951-1956): We have no knowledge as to the type or percentage of asbestos in Baldwin-Hill /I Insulating Cement, and later Mineral Wool (Powerhouse) Cement. Owens-Illinois (1957): Kaylo Pipe Covering & Block contained chrysotile asbestos. Bagle-Picher (1954-1957): Armatemp 166 Cement contained mineral wool with a specially formulated binder. At the time AWI relabeled Armatemp 166 (1954-1957), AWI was unaware that it contained asbestos. Through the course of litigation, Eagle-Picher has provided information that suggests Armatemp 166 contained asbestos. PRODUCTS MANUFACTURED BY ARMSTRONG I*T Cork Covering (1956-1959) consisted of cork board adhered to a backing of aluminum foil with a thin (16/1000") coating of asbestos paper. The asbestos paper, purchased from Dobeckmun Company was presumably chrysotile; the percentage of asbestos contained therein is not known. Armaspray (1966-1968), a mineral wool product, contained about 8% asbestos, amosite or chrysotile. Page 2 of 2 Attachment D ARMSTRONG'S CONTRACT DEPARTMENT Armstrong historically was a low temperature insulation manufacturer and contractor, supplying cork insulation products which were installed by its employees in dairies, ice houses, etc. Except for a limited product line manufactured from approximately 1910-1933, Armstrong's main involvement with high-temperature asbestos-containing insulation products began at the beginning of World War ZI, when its Contract Department first obtained the right to install products manufactured by Keasbey & Nattison. Armstrong remained primarily a cold storage contractor until the end of 1957, when the contracting business was taken over by ACandS. Documents which may expand upon these responses are available for inspection. PRODUCTS MANUFACTURED BY OTHER COMPANIES AND TNSTAT.TJtD BY ARMSTRONG CONTRACT EMPLOYEES The following products were sold by Keasbey & Mattison Company for installation by Armstrong's contract department at various times and locations; not every product was available at all times and at every location. Keasbey & Mattison (1939-1957): 85% Magnesia Pipe Covering & Block and Cement were used to insulate pipes and surfaces with temperatures up to 600F. Hy-Temp Pipe Covering & Block and Cement were used to insulate heat lines and surfaces with temperatures ranging from 600F to 1900F. Kamatt Pipe Covering was used to insulate pipes with temperatures up to 750P. Kaytherm Block was used to insulate surfaces with temperatures up to 1500F. Mani-Ply Insulations were used to insulate pipes with temperatures up to 500F. Bestfelt Pipe 6 Block & Sheet was used to insulate temperatures up to 700F. The pipe covering was used on lines subject to vibrations. Air Cell Insulations were used on lines or surfaces with temperatures up to 300F. Simplex Pipe Insulations were used to insulate lines with temperatures up to 300F where a water-repellant surface was needed. Duplex Wool Felt Pipe Insulation was used to insulate hot or cold water lines 40F to 210F. K&M Asbestos Insulating Cements (Nos. 151 and 152, Velvet Hard Finish, Mineral Wool and Amblerex No. 2) were general utility cements which could also be used as insulating cements on surfaces with temperatures up to 1000F. K. P. Asbestos Floats were used to give a dense, tough, hard quality to the final asphalt plastic finish on walls of low temperature rooms (Ex 25 in earlier years). Unarco (1954-1956): Armabestos Pipe Covering & Block was used to insulate pipes with temperatures up to 750F or 1200F, or surfaces up to 1200F. Page 1 of 2 Ehret Magnesia (1957): 85% Magneaia Pipe Covering (Calcium Silicate inner layer available) was used to insulate pipes and surfaces with temperatures ranging to 600? (both layers to 1200F). Baldwin Hill (1951-1956): Baldwin-Hill #1 Insulating Cement, and later Mineral Wool (Powerhouse) Cement, was used for plastic insulation on irregular surfaces up to 1800F. Owens-Illinois (1957): Kaylo Pipe Covering & Block was used to insulate pipes and surfaces with temperatures up to 1200F. Kaylo-20 could be used on temperatures up to 1800F. Eagle-Pichar (1954-1957): Armatemp 166 Cement was used as an all-purpose insulating material on surfaces up to 1800F. At the time AWI relabeled Armatemp 166 (1954-1957), AWI was unaware that it contained asbestos. Through the course of litigation, Eagle-Picher has provided information that suggests Armatemp 166 contained asbestos. PRODUCTS MAHUFACTUKBD BT ARMSTRONG LT Cork Covering (1956-1959) was used to insulate pipes and fittings with temperatures ranging from -120F to 200F. Armaspray (1966-1968) was used to insulate large, irregular surfaces such as tanks and vessels with temperatures up to 1600F. Page 2 of 2 Attachment E ARMSTRONG'S CONTRACT DEPARTMENT Armstrong historically was a low temperature insulation manufacturer and contractor, supplying cork insulation products which were installed by its employees in dairies, ice houses., etc. Except for a limited product line manufactured from approximately 1910-1933, Armstrong's main involvement with high-temperature asbestos-containing insulation products began at the beginning of World War II, when its Contract Department first obtained the right to install products manufactured by Keasbey & Mattison. Armstrong remained primarily a cold storage contractor until the end of 1957, when the contracting business was taken over by ACandS. Documents which may expand upon these responses are available for inspection. I. PRODUCTS MANUFACTURED BY OTHER COMPANIES AND TWCTat.T.Fn BY ARMSTRONG CONTRACT EMPLOYEES Packaging Armstrong Cork Company was primarily an insulation contractor whose employees installed insulation products at specific job sites. Most of these asbestos-containing insulation products were manufactured by other companies. These products were packaged by the manufacturer according to its own specifications. Pipe coverings, block and sheet were packaged in cartons; cements and floats in bags. Labeling Most of these asbestos-containing insulation products were manufac tured by the Keasbey-Mattison Company and labeled with the Keasbey and Mattison name. They were not labeled with the Armstrong Cork Company name. Kaylo was labeled by Owens-Corning Fiberglas with its name. A limited number of asbestos-containing insulation products were relabeled by the manufacturers to include the Armstrong Cork Company trade name: Armabestos in 1954 - 1956 (manufactured by Unarco) 85% Magnesia Pipe Covering (included Calcium Silicate inner layer) in 1957 (manufactured by Ehret Magnesia Manufacturing Company) and Armatemp 166 Cement in 1954-1957 (manufactured by Eagle-Picher). II. PRODUCTS MANUFACTURED BY ARMSTRONG Packaoino and Labeling LT Cork Covering (1956-1959) was packaged in cardboard cartons with the trademark "Armstrong" with the letter "A" centered in a colored disc. Armaspray (1966-1968) was packaged in 50 lb. kraft paper bags printed with the name Armstrong Contracting & Supply Corporation, Lancaster, Pennsylvania. Page 1 of 1 Attachment G Armstrong has employed physicians and nurses at its plants for many years to provide emergency first aid and other on-site medication and care to employees who would be later referred to their own family physician for further treatment as necessary. The applicable emergency first aid personnel were at the Beaver Falls Plant: Dr. L. P. Atwell -- until 1966 (deceased) Dr. J. C. Sutton, Jr. -- 1966 to present Documents which may expand upon these responses are available for inspection. Page 1 of 1 A rm strong h is t o r ic a lly was a c o ld s to ra g e m a n u fa c tu re r and c o n tra c to r, s u p p ly in g c o rk in s u la tio n p ro d u c ts w hich were in s ta lle d by it s em ployees in d a ir ie s , ic e houses, e tc . 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