Document ym6wVReeYB8Jg7yOGyLYB31R2
FILE NAME Kaiser Gypsum KG
DATE 1986 DOC KG042
DOCUMENT DESCRIPTION Legal - Responses to Interrogatories
0
PATRICK J. HAGAN ESQ CURTIS A. CANFIELD ESQ KINCAID GIANUNZIO CAUDLE & HUBERT
200 Webster Street
Oakland CA 94607-0828 415 465-5212
) 4]
Attorneys for Defendants KAISER and KAISER GYPSUM COMPANY INC
CEMENT
CORPORATION
7
8
9 10
11 12 13 14
IN IN
THE AND
SUPERIOR COURT OF THE STATE OF FOR THE CITY AND COUNTY OF SAN
DEPARTMENT 5
CALIFORNIA FRANCISCO
IN RE
COMPLEX ASBESTOS LITIGATION
/
NO
1327
a
KAISER CEMENT CORPORATION
AND KAISER GYPSUM COMPANY INC'S RESPONSES TO PLAINTIFF'S
STANDARD INTERROGATORIES TO
DEFENDANTS
15
16
PROPOUNDING PARTY
17
RESPONDING PARTY :
18
SET
3
19
DATE
:
20
Plaintiffs
Defendants
KAISER KAISER
CEMENT GYPSUM
CORPORATION
COMPANY INC
STANDARD
FEBRUARY 12 1986
21
COME NOW Defendants KAISER CEMENT CORPORATION herein-
22 after KAISER CEMENT and KAISER GYPSUM COMPANY INC herein-
23 after KAISER GYPSUM and in answer to the Standard Interrog-
24 atories propounded by Plaintiffs state as follows
25
26
27
| 28
OFFICES OF GIANUNZIO & CAUDLE HUBERT
A PROFESSIONAL CORPORATION
200 WEBSTER STREET OAKLAND CA 94607-3789
415 465-5212
KINCAID GIANUNZIO CAUDLE & HUBERT A Professional Corporation
ACSESQ By
(Yd
CURTIAS. CANFIELD
ESQ
(00%
INTRODUCTORY NOTE
a) ed
3
;
a
In order to answer these Interrogatories answering defendants conducted a thorough search of their existing
records and interviewed present and past employees of KAISER
CEMENT and KAISER GYPSUM The following answers are based
upon information presently known Discovery is continuing
and defendants reserve the right to supplement their answers
whenever additional and more accurate information becomes
known
Many of plaintiffs Interrogatories asked defendants to identify or attach documents Many of the records and documents requested are available and now in the custody of
KAISER CEMENT or KAISER GYPSUM However many documents
and records predating 1968 have either been destroyed
discarded or misplaced and are therefore unavailable of
course defendants will permit plaintiffs to inspect and copy any privileged relevant business records still in their possession upon reasonable notice The business records of KAISER CEMENT and KAISER GYPSUM are located at 100 Webster
Street Oakland California
GENERAL OBJECTIONS
KAISER CEMENT and KAISER GYPSUM object to these Interogatories to the extent that they call for information protected by the attorney privilege or work product doctrine
, Responding to these Interrogatories is not intended to be and does not constitute a waiver of any objections
//// ///
A PROFESSIONAL CORPORATION WE BSTER STREET
AKLAND CA 94607.3789
415 465-5212
ANSWER
1
a Donna M. Anderson
b
KAISER CEMENT CORPORATION 300 Lakeside
,
5
Drive Oakland California 94612
6
c Assistant Secretary of both KAISER CEMENT
5 and KAISER GYPSUM d Ms. Anderson was first employed by KAISER CEMENT
9
on May 20 1975 as a Secretary She was an Executive Secretary
10
from 1977 - June 1979 when she was elected Assistant Secretary
11
of KAISER CEMENT She was first employed by KAISER GYPSUM in
12
June 1979 upon her election as Assistant Secretary of that
13
company as well
14
ANSWER
15
2. Both KAISER CEMENT and KAISER GYPSUM are corporations
16
KAISER CEMENT
17
a
KAISER CEMENT CORPORATION
18
b
Delaware
19
c March 16 -1982 KAISER CEMENT a California
20 Corporation was originally incorporated 2/10/39 Through a
21
reincorporation merger effective May 4 1982 that company
2222
was merged with a Delaware corporation of the same name which had
2222
been incorporated in Delaware 3/16/82
2222
d
300 Lakeside Drive Oakland California 94612
25
e Yes 1939 to present
26
f
Yes
CT Corporation whose address is known
27
to plaintiffs attorney
28
g Not applicable.
ee eS a UN Ry PTO
SS
ave
ea
O De eaee er a
Te en ne ee ee Se es el
PORE
em Ss on
oy
KAISER GYPSUM
2
a
KAISER GYPSUM COMPANY INC
3
b Washington
>
c November 28 1927
5
d
KAISER GYPSUM no longer actively conducts any
6
business but the corporate headquarters are locateadt 300
7 Lakeside Drive Oakland California e Yes 1952 to present
9
f Yes C.T. Corporation whose address is known
10 to plaintiffs attorney
g KAISER GYPSUM is a wholly owned subsidiary of
11
12
KAISER CEMENT
13 ANSWER NO 3
14 KAISER CEMENT Yes Permanente Cement Company 1939 to 1964
15 KAISER CEMENT & GYPSUM CORPORATION 1964 to 1979
16
17
KAISER GYPSUM
18
No.
19
ANSWER NO 4
20 KAISER CEMENT
Yes
21
a Henry J. Kaiser Company 22
KAISER b As of August 1 1952
CEMENT purchased for
23
cash from Henry J. Kaiser Company the business and certain 24
assets of a division of that company engaged in the manufacture
25
of wallboard and related gypsum products
26
27
c Certain joint compounds and texture paints may have
28
////
contained small amounts of asbestos at the time of such
acquisition and contained asbesto fosr limited periods of
time therafter
4
KAISER GYPSUM
5
No.
5 ANSWER NO 5 KAISER CEMENT
8
No.
9
KAISER GYPSUM
10
No.
11
ANSWER NO 6
12
Objection vague ambiguous and overly broad Without
13
waiving these objections the defendants answer as follows
14
a The sales and purchase records of both KAISER CEMENT
15
and KAISER GYPSUM relatintgo sales and purchase made during
16
the years in which each company's products contained asbestos
17
which are still in existence are located at 100 Webster Street
18
Oakland California Other corporate records of both KAISER
19
CEMENT and KAISER GYPSUM are located at 300 Lakeside Drive
Oakland California
21
b The custodian of records for both KAISER ~ EMENT and
22
KAISER GYPSUM'S corporate records is CLIFF W. ROGERS Manager
2
Administrative Services KAISER CEMENT CORPORATION 300
2
Lakeside Drive Oakland California
25
ANSWER NO 7
2
KAISER CEMENT
27
a through h No.
28
KAISER GYPSUM
a through h No.
2
ANSWER NO 8
3
KAISER CEMENT
&
a Yes 1960 to 1977
5
b
No.
c
Yes
See a above
6d
Yes
See a above
8
e
Yes
See a above
9
Yes
See a above
10
g
Yes
See a above
11
ANSWER NO 9
KAISER GYPSUM
a Yes 1953
to 1978
b
No.
dae
Yes See a above
dae
Yes See a above
dae
Yes See a above
f
Yes See a above
g
Yes See a above
12
applicable for both KAISER CEMENT and KAISER GYPSUM
13
ANSWER NO 10
.
14
a Please refer to Exhibit A attached hereto
15
b
16
I.
Information unavailable
17
II
Information unavailable
18
III Please refer to Exhibit A attached hereto for
19
relevant dates
c
21
I. Please refer to Exhibit A attached hereto for
22
relevant dates
23
II applicable
24
d Objection this part is burdensome and
25
harassing Answering defendant's products were produced at
26
various manufacturing facilities in different regions of the
27
United States The percentage of asbestos and other materials
28
used in the manufacture of these products varied according to
-6-
the region in which the product was manufactured To attempt
to provide exact figures for each product produced at each
manufacturing
facility
would
be
burdensome
inordinately
In
lieu of a detailed answer and without waiving said objections
answering defendants volunteer the following general information
KAISER CEMENT PRODUCTS
Kaiser Plastic Gun Cement and Kaiser Plastic Cement hand
were composed primarily of powdered Portland Cement Additionally
each of these products contains small amounts of asbestos in the
10
percentages listed on Exhibit A. Kaiser Masonry Cement was compose
11
primarily of Portland Cement Additionally this product contained
12
approximately .4 asbestos
13
KAISER GYPSUM PRODUCTS
14
Joint compounds were composed of finely ground materials
15
including casein clay talcs limestone and mica In addition
16
each of these products contains small amounts of asbestos in the
17
percentages listed on Exhibit A.
18
Kaiser Texture Paints were composed primarily of casein
19
limestone and mica In addition these products contained small
20
amounts of asbestos in the percentages listed on Exhibit A.
21
Kaiser Mineral Fiberboard was composed primarily of
22
various wood fibers clays starch and mineral wool In addition
23
this product contained approximately 1.6 asbestos
24
primarily KAISER GYPSUM Fire Wallboard was composed
25
of gypsum glass fiber and paper fiber Vermiculite was also added
26
to it
27
All KAISER GYPSUM products except KAISER GYPSUM Null
28
Wallboard contained the chrysotile type of asbestos KAISER GYPSUM
Fire Wallboard contained a very small amount of
7
a
(
.
i
ee
Tremolite which was totally encapsulated in the Vermiculite
Answering defendant believes that KAISER CEMENT products
contained the chrysotile type asbestos However answering defendant reserves the right to supplement this answer if
additional information is obtained In addition answering defendant understands that contractors typically mixed the KAISER
CEMENT products with three to five parts by weight of sand so
that the percentage of asbestos was less than % in the product
actually applied
10
e
Please refer to Exhibit A attached hereto
11
f
Please refer to Exhibit A attached hereto
12
Additionally answering defendants do not believe that their
13
products were subject to temperature limitations However
14
discovery is continuing and answering defendants reserve the
15
right to supplement their answer if additional information
16
becomes known
17
g Objection Vague ambiguous burdensome and irrelevant
18
Without waiving these objections defendants answer as follows
19
Unknown
20
h Raw asbestos for KAISER CEMENT products was purchased from
,
21
the following sources
22
Pacific Asbestos Corp. Copperopolis CA
Division 23
Asbestos Bonding Corp.
of Shute Corp.
24
Napa CA
25
Paul W. Wood address not known
26
Canadian Manville address not known
27
John K. Bice Company Inc. address unknown
29
E. S. Browning Company address unknown
-
8
-
to
Y
Shay, wan
)
Atlas Asbestos Company address unknown Hill Brothers address unknown
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8 ///
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10
|
11
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12
///
13
///
14
///
15
///
16
///
17
///
18
///
19
///
220
///
21
///
22
///
23
///
22
///
25
///
26
///
27
///
28
///
- 8a -
>
a
-ad
(
an
1 2 3 + 5 a 7 8 9 10 11 12 13 14 15 16 17 18
|
19 20 21 22 23 24 25 26 27 28
Raw Asbestos for KAISER GYPSUM products was purchased
from the following sources
Western Chemical Company Los Angeles California
Philip Carey Corp. Carey Canadian Asbestos P.O.
Box 15070 Cincinnati Ohio 45215
Manville Sales Corp. address unknown
Union Carbide Company address unknown
The time period of such supply is unknown to answering
defendants
i
Neither KAISER CEMENT nor KAISER GYPSUM has ever
sold any products containing asbestos to shipyards KAISER
CEMENT sold products containing small percentages of asbestos
to a large number of governmental
Arizona and Nevada from 1960 to 1977.
customers in California KAISER GYPSUM sold
products containing small percentages of asbestos to a large
Western number of governmental customers in the
United
States Texas and East Coast States from 1953 to 1978 The
sales records for KAISER CEMENT and KAISER GYPSUM have not
always been kept in a systematic or organized manner
Further most KAISER CEMENT and KAISER GYPSUM records pre-
dating 1968 have either been destroyed discarded or misplaced For the years 1968 through 1977 KAISER CEMENT and
KAISER GYPSUM have approximately eight hundred Bekins boxes
filled with individual sales orders and invoices which are
not categorized in any particular fashion other than by = year
To provide the specific information which has been requested would require extracting and compiling data from approximately
eight hundred Bekins boxes This would be excessively
-9-
-9-
-9-
ed
1 3
burdensome and oppressive Upon reasonable notice counsel
for plaintiff may review any such privileged documents
at 100 Webster Street Oakland California
j Please refer to answer to part i above
The present custodian of defendant's sales records is
6
Cliff Rogers Manager Administrative Services KAISER
7
CEMENT CORPORATION 300 Lakeside Drive Oakland California
8
ANSWER NO 11
9
Unknown as to both KAISER CEMENT and KAISER GYPSUM
10
ANSWER NO 12
11
Neither KAISER CEMENT nor KAISER GYPSUM entered into
12
any such rebranding agreements
13
ANSWER NO 13
14
applicable See Answer to Interrogatory No. 12
15
above
16
ANSWER NO 14
17
For both KAISER CEMENT and KAISER GYPSUM the answer
18
is No not to defendants knowledge
19
ANSWER NO 15
20
Yes Beginning in 1972 warning labels were placed on
21
containers of all products manufactured by both KAISER CEMENT
22
and KAISER GYPSUM which contained asbestos
23
a These labels were approximately 4 x " in size
24
and were brightly colored They were prominently displayed
25
on the side of each can or bag or product
Labels were never
26
placed on the products themselves since most the products
27
came in the form of either powder or paste The warning read
28
as follows Caution contains asbestos fiber avoid
-~
10
~
om
*
7
,
-
veh
5 f
}
breathing dust breathing asbestos dust may cause serious
bodily harm See Exhibit B attached hereto
1972 b
until the products no longer contained asbestos
c The warnings were never altered amended or changed
ANSWER NO 16
applicable
ANSWER NO 17
KAISER CEMENT
the name trademark etc. of KAISER CEMENT never
10
appeared on any of its products themselves because these
11
products were sold in the form of powder
12
KAISER GYPSUM
13
Most KAISER GYPSUM products were sold in the form of
14
either powder or paste The name and trade mark of KAISER
15
GYPSUM was placed on only KAISER GYPSUM Fire Type X
16 Wallboard a product which contained a minute asbestos impurtiy
17
in one of its components
The name KAISER GYPSUM and the
18
trade name Fire Type X appeared on the edge of each
19
sheet of such wallboard KAISER GYPSUM Null Wallboard
20
contained the name and trademark of its manufacturer during
21 the entire time in which it was produced 1969 through 1978 .
22
Obviously the purpose of such markings was to provide
23
the user with information regarding the type of product and
2
its manufacturer
2
ANSWER NO 18
2
KAISER CEMENT
27
Harlan C. Dupuis Katherine Maksim v Fibreboard San
28
Francisco Superior Court No. 768674 April 16 1985
- 11 -
.
A,
ads
!
,
James R. Latshaw David Littleton v ABEX Alameda Superior KET Court No. 588440-3 September 26 1985
KAISER GYPSUM
None
ANSWER NO 19
Other than as stated in Answer to Interrogatory No. 4
No for both KAISER CEMENT and KAISER GYPSUM
ANSWER NO 20
Objection overly broad burdensome and harassing
10
Without waiving these objections defendants answer as
11
follows Both KAISER CEMENT and KAISER GYPSUM have a large
12 13 14 15 16
... 18 19 20 21 22 23 24 25 26 27 28
number of brochures pamphlets catalogs and other product
listings Many of these documents do not differentiate
between asbestos containing products and asbestos
containing products and many of the documents arerepetitious For these reasons rather than attempt to identify each
individual document answering defendants will make all|
relevant files available for inspection at KAISER CEMENT'S headquarters 300 Lakeside Drive Oakland California
a See above
b For KAISER CEMENT products between 1960 and
1977 for KAISER GYPSUM products between 1953 and 1978
c
See answer to part b above
d
To provide the users with information about
the products
e
Some of these documents still exist
At KAISER CEMENT'S headquarters 300 Lakeside
Drive Oakland California
12
vk
-
g Cliff W. Rogers Manager Administrative Services
2
300 Lakeside Drive Oakland California
3
ANSWER NO 21
applicable in that neither KAISER CEMENT nor KAISER
GYPSUM ever distributed raw asbestos fibers
5 ANSWER NO 22
6 Not to the knowledge of either KAISER CEMENT or KAISER
8
GYPSUM
9
ANSWER NO 23
10
Neither KAISER CEMENT nor KAISER GYPSUM had contract
11
units
12
ANSWER NO 24
13
applicable
14
ANSWER NO 25
15
Both KAISER CEMENT and KAISER GYPSUM had liability
16
insurance during the period of time either of these entities
17
manufactured or sold any asbestos containing product
18
ANSWER NO 26
19
Please refer to ExhibiC t attached hereto
20
21
22
22
24
25
26
27
28
~ 13 -
VERIFICATION
The undersigned says
I am an officer wit Assistant Secretary of defendants KAISER CEMENT CORPORATION and KAISER GYPSUM
5 COMPANY INC herein the foregoing document is true of my
6 own knowledge except as to the matters which are therein
SE
7
stated on my information and belief and as to those matters
8
I believe them to be true
g
I declare under penalty of perjury that the foregoing
10 is true and correct
11
Executed this 234 day of
12
at Oakland California
13
October October October
, 1985
14 15 DONNA M. ANDERSON
16
17
18
19
21 22 23 24 25 26 27 28
_
ak}.
VICTOR J NZIO ESQ
|
~
THOMAS F. CASTLE ESQ .
KINCAID GIANUNZIO CAUDLE | & HUBERT
WD 100 Webster Street Suite 300
Oakland California 94607-3789
oe
ae
7 .
=
-
2
HH Telephone 415 465-5212
HAGENBAUGH & MURPHY
OP 1301 West Second Street
|
Los Angeles CA 90026
.
Telephone 213 624-9861
6 Attorneys for Defendant
KAISER CEMENT CORPORATION
7
@f2
SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN DIEGO
oe
In the Matter of
199 SAN DIEGO ASBESTOS LITIGATION
-
;
199
NO 481189
Pmt
Ca
KAISER CEMENT CORPORATION
Tae
ANSWERS TO PLAINTIFFS
STANDARD FIRST SET OF
INTERROGATORIES
GENERAL OBJECTIONS
KAISER CEMENT CORPORATION responds to these interrogatories
subject to the general and specific objections previously raised
by it and other defendants Respondintgo said interrogatories
is not intended be and does not constitute a waiver of any
to! ee OPRe|RE
KINCAID OIANUNZIO
CAUBLEA HUREHT
A PROFESSIONAL CORP
JACK LONDON SOVARE
180 WERFTER STREET
GARLAND CA 84007
eID
**** 180 9419
objections
a
KAISER CEMENT CORPORATION further objects to these interrogatories to the extent they call for information protected by
the attorney privilege or product doctrine
Because the answers to numerous interrogatories require the identification of documents KAISER C^ MENTCORPORATION has indica-
ted it will make said responsive documents available for the
inspection of plaintiffs at the officoef KINCAID GIANUNZIO
CAUDLE & HUBERT in Oakland California Some of these documents
are responsive to a particular request while others are too
.
~
3
to
.
2 3
4
8 6 7 8 9 10
EEEEE
.
EEEEE
"
Policy Number
|
Fireman's Fireman's Fund Insurance Co.
a
XLX1269069
_ P. O. Box 3395
.
.
_
XLX129069
-
|
San Francisco CA 94119 .
.
XL1372XLX1372713
Trans Continental
CNA Plaza
;
Chicago Ill 60685 .
UM
7
Lloyds Underwriters
C.T. Bowring & Co. Ltd.
The Bowring Bldg Tower London EC3P 3BE
England .
-
Plaza .
a
UMB006496626
LUS LUS LUS LUS LUS
1294 1324 1325 1326 t.b.d.
Landmark Insurance 3550 Wilshire Blvd.
Los Angeles CA 90010
_ FE4001206
|. FE4001234
Industrial Indemnity
P.O. Box 3660
San Francisco CA 994120
JE8312723
EEEEE
Mutual Fire Marine & Inland Ins Co.
EL104518
|
1200 Three Parkway
EL104678
i
EEEEE
Philadelphia PA 19102
:
15
16
old Republic
P. O. Box 789
Greenburg PA
15601
OZX12430
17
Harbor Insurance Co.
HI163638
.
|
18 Los Angeles CA 90054
19
, Twin City Fire Insurance Co.
Hartford Plaza
20 Hartford Conn 06115
TXS100347
|
21
22
24
25 26 27
NGAID GIANUNZIO
GAUBLE & HUBERT
& PROFESSIONAL PROFESSIONAL COMP
JACK LONDON SQUARE IW WEBSTKA STREKT MAKLAND CA 94087
4 & Product
.
Trade Name
Approximate per- .
centage of asbesta
Joint
Joint
Compound
;
-
Kaiser Joint Compound
|
6.8 to 10.4 |
" - Finishing Compound 3.7 to 11 #
Com- nm
One Day Joint
- pound
co
|
3.3 to 3.4
Purpose 18 Three -
pound .
Com-
oo
4.8 to 4.9
Dual Purpose Premix
Joint Compound
1.5 to 5.9
Pre Mix Topping
Compound
.
91 to 1.059
The above variations in asbestos content depend on the producing
.
-4- .
.
F
oo
composed oe
addition
,
plant above products | in addition sbestos are
clays _
primarily of finely ground materials including casein
,
tales limestone and mica . a i.
mo
4
Paint
'
.
Kaiser Cover Wall
48 to 78
|
Texture
.
fi Spray Ceiling
1.3 to 6.8
Texture
The above variations in asbestos content depend on the producing plant The above products are composed primarily of casein
limestone mica
Fire Rated Gypsum
Wallboard
Wallboard
.
Kaiser Fire
less
.5
than
The Gypsum rated wallboard is composed primarily of
Gypsum and glass fiber and paper fiber
. 922A4A97992
Fire Rated Mineral
1.56
922A4A97992
922A4A97992
The above mineral fiber board is composed primarily of
922A4A97992 || various wood fibers clays starch and mineral wool
922A4A97992
Plastic Cement =
% to %
922A4A97992
Masonry Cement
7
.48
4
.
922A4A97992
The above cement products are composed primariloyf Portland
21 || Cement with small amounts of asbestos and other lubricating agent
2
2
2
}
2
b
.
ae
Joint Compounds and Texture Paints
Fire Rated Gypsum Wallboard
Fire Rated Mineral Fiber Board
Plastic Cement
Masonry Cement
.
an
a
7s
.
1953 = 1976 1969 = 1978 1964 =~ 1973 1960 = 1973 1960 - 1962 1970 state 1977
ae
26 27
e. See b
d Kaiser Cement Corporation believes the type of asbestos
~~
28 || used
wow orereve
|) CAID BIANUNZIO
CAMOLE O HUDERT CAMOLE A PROFESSIONAL CORP JACK LONDON SQUARE 109 WEBSTER STEBES .. OAKLAND CA 94607 TS HIN 40 18
was
,
chrysotile
oS
2 -~ @- 3 wae
-!
_
compound , finishing on: id day joint /
compoundthree purpose compound and cover wall texture Whit
3 to white powder
Dual
purpose
mix
joint
compound
and
and
mix
topping
o compound White to white or light buff colored paste
eo
Spray ceiling texture White powder with polystyrene
aggregate |
8 Fire rated gypsum wallboard = 1/2 or 5/8 thick x 4
9 wide x 8 to 10 long sheets commonly known as sheetrock
20
thick
Pire
x 12 or
rated mineral fiber board =
24 wife x 12 24 48 or
1/2 5/8 and 3/4
60 long sheets with
AN A07 face side white in color and perforated or fissured design on face side for acoustical treatment
Plastic and masonry cement = Gray powdered portland
ANANA07 6 cement
# ANANA07
f Joint compounadnsd texture paints were used for finish
ing joints and surfaces of gypsum wallboard used for interior wal
AN A07 and ceilings Fire rated gypsum wallboard was used for interior walls and ceilings Pire rated mineral fiber board was used for accoustical
2
ceiling tile lay board and partition sound deadening board
Plastic cement is used to make stucco for the exterior
buildings of houses and other
;:
|
me Masonry cement is used in masonry mortar in building
construction-
ete e we
28
Vows eReeee
LAW OFFCC0-
CAIO CIANUNCIO } AUDLE & HUBERT
A PROFESSIONALPROFESSIONAL CORP
JACE LONDON SQUARE 100 WEPUTER STREET
PAKLAND PAKLAND CA POMO
epee
411 48L1218
Te 2
9 Maiser Spray Ceiling
e.
oe
&
bMyay 17 1974 and October13 1975
&&
ci In May 1974 the relative amounts of the various
ingredients were altered This primarily involved a decrease|
oe in the use of tale and an increase in the use of clay Hydrite.
The change in October 1975 primarily involved the elimination of
so asbestos .
8
d The May 17 1974 change was to undertaken improve
9 workability and customer acceptance The October 13 1975
10 alteration was undertaken to eliminate asbestos from the pro-
11 | duct's composition
12
10 KAISER CEMENT CORPORATION does not fully understand
13 this interrogatory in that interrogatory 8 made no mention of
16 any testing of products KAISER CEMENT CORPORATION has run tests
15 over the years during the development of products to determine
16
17
18
their workability characteristics No tests were performed on
the mentioned products relating to the omission of asbestos fibers from the product during use manufacture fabrication or
19 handling
8
20
11 See answer to interrogatory 8 and 10 above
21
,,See answer to interrogatory 8 9 and 10 above
22
23
24
25
26
27
28
LAW } OFFIC
GAID GIANUNZIO
,
AUBLE A HUDEAT
CORP OMT PROFESSIONAL onal JACE LUNGON SQUARE 140 WEYTTER SYRESY BAKLAND CA DAGAY bE 410 643812
,,Yes
a
a1 2
.3
4
5 6
7
Kaiser Joint and Finishing Compounds
Kaiser Texture Paints
Kaiser Spray Ceiling Texture
Kaiser Null Wallboard |
Kaiser Accoustical Mineral Fiber Board Permanente Plastic Cement
Permanente Masonry Cement
b Items 1 2 and 3 above asbestos was
eliminated from the product in 1976 and manufacture of the pro-
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KAISER | KAISER
BYPSUM BYPSUM
KAISER KAISER
GYPSUM
DUAL PURPOSE REDEMIX REDEMIX
PURPOSE 4
PURPOSE REDEMIXFIBERED HARDWALL
REDEMIX HARDWAL ; ; mill mixed with lighltight
PLASTER PLASTER
bHAaRDWALL PLASTER
weight aggregate 3 : mT
Pd
KAISER KAISER
BYPSUM
KAISER KAISER
GYPSUM GYPSUM
| SLOW SET. QUICK SET
GAUGING CASTING
PLASTER, PLASTER
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COMPOUND
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LIST OF IROUX UNTAINING AYUR
DESCRIPTION DESCRIPTION DESCRIPTION OF PRODUCT
COMPOSITICOMOPOSINTION
Approx )
YEARS CONTAINING
ASBESTOS
PLANTS WHICHE MANUFACTURE)D
REGION OF
DISTRIBUTIO}N
Reiser Joint Compound-
-
Dry Powder
Used to fill gypsum
board joints embed joint reinforcing
tape finish joints and to cover and finish nailheads and
metal corner bead
.
White to white
powder Packaged and sold in sacks of 25 to 50 lbs
Primarily finely ground materials including
casein clay talcs
limestone and mica The asbestos used in this product was chrysotile
Raiser Finishing Topping
Compound .
Used to top and finish gypsum board joints
Raiser Day Joint
Oxmpound =.
Used to fill gypsum board joints embed joint reintorcing tape finish joints
- and to cover and
finish nailhead and
Metal cornerbead
Kiss Purpose Compound
Used to tape top and finish gypsum board joints nailheads and metal cornerbead
Compound
Used to fill gypsum
board joints embed joint reinforcing tape finish joints
and to cover and
finish nailheads and
corner bead
white to white
or light but colored paste Packaged and sold in buckets ranging from 12 to 62 lbs
and in cartons ot 5 to 50 lbs
Used to top and finish
.
gypsum board joints
6.8-10.40 6.8-10.40
3.7-110 3.3-3.48
4.8-4.99 1.5-68
1953-75 1961-75 1968-75
1969-75 1960-75
1969-75
Santa Ana Calif
Antioch Calif) Seattle Wash) :
Delanco New Jersey
Jacksonville Pu
All western states
including Hawaii and Alaska New England
and all east coast
states
Used to fill gypsum board joints embed joint reinforcing tape finish joints and to cover and finish nailheads and metal cornerbead
White to white
or light but colored paste Packaged and sold in buckets ranging from 12 to 62 lbs
and in cartons of 5 to 50 lbs
Primarily finely ground materials including casein clay talcs
limestone and mica The
asbestos used in this
product was chrysotile
1.5-68
1960-75
ay
b
Santa Ana Calif #
Antioch
4
Calif Seattle (ie
Calif Jacksonville (Pla.
;
as
?
All western states and
England including Hawaii and
Alaska NNeeww
States
LIST OF HOD CONTAINING ASBESTOS
Man^"racured by
KAISER CEMENT CORPORATION
:
.
PRODUCT NAME
HURPOSE OF PRODUCT
DESCRIPTION DESCRIPTION DESCRIPTION
OF PRODUCT
COMPOSITION
% ASBESTOS
Approx)
Kaiser Plastic Gun Cement
: . ,
Used to make stucco
for the exterior of
houses and other
buildings applied
by gun
Kaiser Plastic Cement Hand
,
;
;
Used to make stucco for the exterior of
houses and other
buildings applied manually with a
trowel
Gray colored powder
Packaged and sold in sacks of varying
sizes and also in
bulk
8
Kaiser Masonry Cement
Used in masonry mortar in building construc-
tion
Primarily powdered port-
land cement The asbestos
used in this product was chrysotile ,
Primarily portland cement The asbestos used in this product was chrysotile
2-5 3 1-58 3 0.48 3
CONTAINING ASBESTUS 2 PLANIS WHERE MANUFACTURED
REGION OF
DISTRIBUTION 2
1960-74
.
1961-73
1972-77
Pemanente Calif Cushenbury Calif
:
"
Permanente ) Calif
Cushenbury Calif
1963-64 bnly
:
i
Cushenbury Calif
Northern and Southern
California
.
Arizona primarily
Phoenix )
4
.
1 Kaiser Cement Corporation was known as Permanente Cement Company from 1939-64 and as kaiser Cement & Gypsum Corporation from 1964-79
2 The information in the Years Containing Asbestos column pertains to the company as a whole -- the individual plants listed in the Planitns Where Manufactured column did not necessarily manufacture each product during all of the stated years Similarly the areas indicated the Region of Distribution column did not necessarily correspond to all of the stated years
3 Contractors typically mixed these products with three to five parts by weight of sand so the $ asbestos was less than 18 in the product
actually applied
|
|
85
- Sek
ae
a
.
NAME
FRODUCT NAME
Texture Paints
Kaiser Cover Hall
Texture
Kaiser Spray Ceiling
Texture ..
FURIUSE OF PRODUCT
DESCRIPTIDEOSCRIPNTION DESCRIPTION
PRODUCT
~s
ae
COMPOSITIONCOMPOSITION
ASBESTOS
_Approx
Used to produce tex-
ture effects over
gypsum wallboard wallboard
surfaces
White to white
powder Packaged
and sold in sacks
of 25 to 50 lbs
Primarily casein lime-
stone and mica The asbestos used in this
product was chrysotile
Used to produce tex- White powder with
ture over gypsum
polystyrene aggre-
wallboard or interior concrete ceilings
gate Packayed and sold in sacks
of 25 to 50 lbs
4-88 1.3-6.68
Ciling Board
Kaiser Mineral Fibreboard -
UL Rated Underwriters Laboratories
Inc. design
>
.
.
Used for acoustical ceiling tile and layin board and partition deadening board
:
1/2 or 5/8 thick
by 12 or 24 wide by 12 24 or 48 long sheets with face side white
Primarily mineral wool
= and various wood fibers clays and starch The asbestos used in this
product was chrysotile
or colored and
with perforated or fissured design for acoustical treatment Packaged and sold in boxes of various
i
quantities
1.60
:
Wallboard
Kaiser Gypsum Firefi Used for interior
Type X Hallboard
walls and ceilings
1
ah
/ or 5/8 thick
by 4 wide by 8 or 12 long sheets covered with gray or manila colored
paper Two sheets
were bound together
for purposes of sale
Primarily gypsum plus additives of glass fiber
paper fiber and vermiculite
The vermiculite contained two 100ths of 11 tremolite a type of asbestos which was considered an impurity
and was totally encapsulated
in the vermiculite
0.028
Page of 2
YEAR
CORDA FELK
ASHESTUSE PLAINS WHIHEMAJFACTURED
@
1956-75 e
e
1969-75
te
t
v
sy
;
"
National but 1965-74
Helene Oregon St. Helene Oregon
largely
1969-78 1969-78
LongAntioch Calif )
Seattle ( Wash Rosario New Mexico Delanco New Jersay Jacksonville Pla
,
All western states coast
states
,
i
.
Where did not necessarily time "
1 the information in the Years Containing Asbestos column pertains to the company as a whole - the individual plants listed in the Plants | :
Manufactured column
manufacture each product during all of the stated years Similarly the areas indicated in
. the Region of Distribution column did not necessarily correspond to all of the stated years for example the Jacksonville and Delanco
of -plants were not built until 1964 and 1965, respectivelyrespectively respectivelyrespectively thus, distribution distribution of productproductss on the east coast did not commence until some
_
after the plants were completed "
6/85 DMWVek
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