Document 6dD9QQdw3b141zr4v7vpJpEm

IN THE UNITED STATES DISTRICT COURT . FOR THE EASTERN DISTRICT OF TEXAS VS. JOHNS-MANVILLE SALES CORPORATION, ET AL MASTER ASBESTOSFILE ANSWERS OF DEFENDANT THE CELOTEX CORPORATION, SUCCESSOR IN INTEREST TO PHILIP CAREY MANUFACTURING COMPANY, PHILIP CAREY CORPORATION, BRIGGS MANUFACTURINGCOMPANY AND PANACON CORPORATION TO PLAINTIFF'S INTERROGATORIES TO ALL ATTORNEYS OF RECORD: In accordance with Rule 33 of Federal Rules of Civil Procedure, THE CELOTEX CORPORATION, SUCCESSOR IN INTEREST TO PHILIP CAREY MANUFACTURING COMPANY, PHILIP CAREY CORPORATION, BRIGGS MANUFACTURING COMPANY AND PANACON CORPORATION, hereafter called "THE CELOTEX CORPORATION", makes and files this its Answer to Plaintiff's Interrogatories served on Defendant's counsel. PRELIMINARY STATEMENT Defendant reserves the right to amend or supplement its answers if it finds that inadvertent omissions or errors have been made or if additional or more accurate information becomes available that is required to be provided by said rules. THE CELOTEX CORPORATION is a successor-in-business to various companies and corporations which were engaged in the manufacture and sale of asbestos containing insulation products. THE CELOTEX CORPORATION'S involvement in the asbestos insulation business began with its purchase of Panacon Corp. in 1972. Prior to that date. Celotex did not have any interest whatsoever in the asbestos insulation field. Most all of the events which may be relevant to the issues presented in this and related cases, occurred prior to THE CELOTEX CORPORATION'S purchase of Panacon Corporation. For this reason and the fact that many of the matters inquired about took place several decades ago, information furnished in this response may be incomplete. Nevertheless, Celotex has endeavored to fully investigate all relevant happenings and circumstances and the following responses are based upon its investigation. However, THE CELOTEX CORPORATION cannot exclude the possibility that its continued investigation may reveal more complete information. Furthermore, a considerable amount of the information supplied in these responses was obtained from employees or predecessor corporations. Accordingly, THE CELOTEX CORPORATION can only relay this information; it cannot attest to the accuracy or truthfulness of such responses. Information of this nature is being supplied because it may lead to the discovery of admissible evidence. 1. Give the name of the person answering this interrogatory. Answer: The responses to these interrogatories are prepared by the legal department of the parent corporation of THE CELOTEX CORPORATION. They are signed by D. S. Gibson, Manager of Safety and Property Conservation as authorized officer of the corporation, and not on the basis of his personal knowledge of the facts stated therein. 2 (a) What is the official title or position or job of that person with the defendant? Answers See Answer above. (1) How long has that person occupied that position? Answers See Answer above. (b) State year by year all other positions, titles or jobs that person has held with the defendant. Answers See Answer above. (c) Why does that position(s), title(s), or job(s) qualify him/her to answer these questions. Answers See Answer above. 2. Give the name, address and position of each other person actually assisting with the answers to this interrogatory. Answers Refer to Answer to #1. 3. Does the defendant now manufacture, sell or distribute any products containing asbestos? Answers Refer to attached Products List, marked Exhibit "A". , (a) If "yes", name each such product and explain exactly the defendant's connection with the manufacturing, selling or distributing of that product. Answers See Answer above. (b) If "no" when did the defendant cease manufacturing, selling or distributing products containing asbestos? Answers See Answer above. 3 4. State with exactness the precise period of time (including the beginning and ending year) when the defendant did manufacture, sell or distribute any products containing asbestos. Answer: Refer to attached Products List, marked Exhibit "A". 5. Name the companies, corporations or business entities of any kind whose asbestos products business was acquired in any manner whatsoever by the defendant. Answer: Refer to attached Corporate History, marked Exhibit "B". As The Celotex Corporation has assumed all of the ordinary liabilities of predecessors-in-business, further response is irrelevant. (a) Give the specific name or names of all such business entities. Answer: See Answer above. (b) As to each, state exactly when the acquisition took place and how it was accomplished - that is by merger, purchase, or in whatever manner. Answer: See Answer above. (c) If there is any written memoranda of any type concerning such acquisition or merger, attach a copy hereto. If you do not, then explain why you have not and in that instance, state in detail what the nature of the transaction was whereby the acquisition or merger was accomplished. In such event, also state whether the defendant became responsible for the liabilities of the business entities which were acquired. Answer: See Answer above. 4 (1) Specifically, state if the defendant became responsible for any damages for which the asbestos products of the acquired business entity is nor was responsible or might become responsible in the future. Answer: See Answer above. (d) It is the intention of this interrogatory to have you answer as to every single business entity whose asbestos products were acquired by you in any manner whatsoever. Answer: See Answer above. 6. As a reverse of the immediately preceding question, explain in detail any transaction by which you sold your asbestos business to any other company (whether or not it is one of your co defendants in this case). Explain in detail the transaction, the date, and your contentions as to whether or not the purchasing company became liable for any asbestos produced damages from your products. Answer: N/A 7. Beginning with the first year in which you either manu factured, sold or distributed any products containing asbestos, state chronologically all such products manufactured, sold or distributed by you year by year. As to each such product, state its actual name by which you manufactured, sold or distributed it and then state as to each such product any trade name or "nickname" by which each product was know. Answer: Refer to attached Products List, marked Exhibit "A". 5- *i I 8. Year by year state exactly how and by whom your products were sold or distributed in Texas. Answer: A.C.& S The Aber Company, Inc. Anco Insulations, Inc. B&B Contracting & Supply B&B Insulations Commercial Insul. Supply Econotherm Insul. Co. Maroco, Inc. Midcontinent Supply Co. Pamrod Inc. Precision Insulation Co. Sabine Industries Sadler Ind. Service, Inc. Standard Asbestos Mgf.Co. Stonaber, Inc. Styrothane, Inc. Thermo Tech Inc. Triple B. Corp. E. 0. Wood Company 9140 Premier Row P.0. Box 2683 7762 Braniff St. 4831 Lakawana P.0. Box 2531 8517 Directors Row P.0. Box 18247 P.0. Box 3756 P.0. Box 189 P.O. Box 335 7792 Braniff Rd. P.O. Drawer 1 P.O. Drawer 1 P.O. Box 1105 2508 Fairway Park Dr. P.O. Drawer GG P.O. Box 22209 P.O. Box 22209 712 1H. Beach Dallas, Tx. Houston, Tx. Houston, Tx. Dallas, Tx. Houston, Tx. Dallas, Tx. Houston, Tx. Pt. Arthur, Tx Ft. Worth, Tx. McQueeny, Tx, Houston, Tx. Orange, Tx. Clute, Tx. Borger, Tx. Houston, Tx. Freeport, Tx. Houston, Tx. Houston, Tx. Ft. Worth, Tx. (a) Name all wholesalers, jobbers or distributors of your products in Texas year by year in the asbestos business. As to each jobber, distributor or wholesaler, give its exact address and telephone number. As to each jobber, distributor or wholesaler, name the specific person or person with whom you dealt. Answer: See Answer above. 9. Please look as the following list of products containing asbestos and to the right of each product answer "yes" or "no" as to whether your company ever manufactured, sold or distributed that product or had any connecting with its whatsoever. If your answer is. "yes" to any product, in the far right hand column state what years you did manufacture, sell or distribute such product. Answer: Refer to attached Products List, marked Exhibit "A". 6 PRODUCT ABOGLAS ACCOBEST ACCOBEST AN-8012 ACOA AERTITE AFD AIRCEL AIRCELL AKOUSTIKOS FELT ALAND ALBASEAL ALUMA-SEAL ALUM-I-FLEX AMBERLITE AMBERBESTOS AMERICAN COLONIAL ANTI-SWEAT APAC APAC BOARD APPLON C TFE APPLON T TFE ARMATURO ASBESTOS TAPE ARMOR SPRAY ARMOR TEMP ARMSTRONG L T CORK COVERINGS "YES" OR "NO" . YEARS 7 PRODUCT ASBALTIC ASBESTALL ASBESTEX ASBESTIBEL ASBESTILE ASBESTITE ASBESTOBOARD ASBESTOCEL ASBESTOCITE ASBESTOGARD ASBESTOLUX ASBESTON ASBESTONE ASBESTONE STANDARD 400 ASBESTOROC ASBESTOS EBONY ASBESTOS-EBONY ASBESTOS FIBRATED ASBESTOS FIRETARD JACKET ASBESTOS GRAPEVINE FINISH FELT ASBESTOS LIQUID ASBESTOS LUMINCLAD ASBESTOS MILLBOARD ASBESTOS SPONGE ASBESTOS SPONGE FELT ASBESTOS ROLL FIRE FELT "YES" OR "NO" 8 YEARS PRODUCT ASBESTROLAN ASCARITE ATLAS AUBESTON BB BBA BELLOWSEAL BEST PELT BES-TOS BESTOLITE BESTOPHALT BESWICK BLACK TOP ASBESTOS JACKET BLASTAPE CALIDRIA ASBESTOS CAL TEMP CAPOSITE CARBAC CAREY CAREYBESTO-BORD CAREYCEL CAREYCLAD CAREY DUCT CAREYPLEX CAREYSOTE CAREYSTONE "YES" OR "NO" 9 YEARS PRODUCT CAREYTEMP CEDARGRAIN CELLAMITE CELL-O-TONE CEMESTO CEMESTO STRUCTURAL INSULATING PANELS CENTRIPAC CENTURY CENTURY APAC CERTAIN-TEED CHEMLON CHEMPAC CHEMSTONE CHEMTITE CHESTERTON SIXTY FOUR CHESTERTON 1000 CHROMATEX CHROMA-TONE CHROM-TEX CLEANGARD COGASA COHRLASTIC COLONIAL STONE COLORATOR COLORBESTOS COLOR GROUND "YES" OR "NO" 10 YEARS PRODUCT COLORLITH COLOR-TEX CONTICO COPPERCLAD CORONET COVERGARD CRYSTAL WHITE CUTNO CW DELTABESTON DESIGNER SOLIDS DOMINIQUE DOUBLEX DOUBLE SANDED ASBESTOS DUALAY * DUPLEX DURA-COLOR DURAFORM DURA SHAKE DUROCELL DU SHEILD EBONI2ED ASBESTOS ELECTROBESTOS ENDURO ETERNIT ETERNIT STONEWALL EXCELON "YES" OR "NO" 11 YEARS PRODUCT PACESPAN FEATHERWEIGHT PELBESTOS FI-ACS PIBEROCK FIBEROCK ASBESTOS FELT FIBER SHAKE FIBERSPRAY ASBESTOS FIBRA FLO FIBRE COATING ASBESTOS FIBRE KOTE FIBROCEL FIBRO-CELL FIBROFIL FIBRO-FILL FIBROID FIBROID STOVE PUTTY FIL-INSUL FILPACO FIRE CHEX FIRE-CHEX FIRECLAD FIRE FELT FIREGARD FIREGUARD JACKETING FIRE HALT "YES" OR "NO" 12 YEARS PRODUCT FIRETARD FLAMEMASTER FLAMEGARD FLAMESAFE FLEXACHROME FLEXBOARD FLEXGOLD FLEX-SLATE FLEXSTONE FLINTITE FLUOROBESTOS FMC F. O.P. FORM PACK 2 FOSTER FROST PROOF GAF GUARDIAN LINE GARDWELL . GARDWELL PRODUCTS GLATEX GOETZE METALLIC GASKETS GOLD BOND GRAFIL GRALAM GRIZZLY G. T. RING "YES" OR "NO" 13 YEARS PRODUCT GUM-BESTOS HERCO HI SEAL HOODEX-22 HOPACO HORNEBLENDE HY TEMP IMPERIAL IMPERIAL EXCELON IMPERIAL PIPE COVERING INDUSTRIAL INDUSTRO-TILE INSULATION SEAL 820 INSULCOLOR ISOBESTOS JANOBESTOS JANOS JEWETT JM (OR JOHNS-MANVILLE) KAOBESTOS KAYLO KEARSARGE K-FAC KLINGERIT K & M AIRCELL KORNMETAL "YES" OR "NO" 14 YEARS PRODUCT K THERM LASCO LINABESTOS LK LO-CA LOK-TAB MARINITE MASTIC MATICOVE McKIM MICROBESTOS MIGHTYPLATE MIMCO MINKOTE MODERNAIRE _ MONOBESTOS MONOBLOCK MONTASITE MULTI-PLY MUNDET NEW ERA NIAGRITE NICOLET NON-CON-DUX NORISCELL NOVABESTOS ' "YES" OR "NO" . 15 YEARS PRODUCT NU GRAIN NU SIDE NU WAY OHMSTONE ONC ONE COTE CEMENT PABCO PAKMETAL PAL-LITE PALMETTO PALMETTO CUTNO PALMETTO SUPER SHEAT PAMCO PANELSTONE PERMABOARD PERMATHERM PERMATONE PIEDRA PLASTIC PLASTIBEST PLIABOARD PLASTICLAD PLASTICRYLIC PLIA-F-LEX PLUTO PORTUGESE ASBESTOS POWMINCO "YES" OR "NO" 16 YEARS PRODUCT PRASCO HIGH TEMPERATURE PRENITE PRISMATIC PROFILE PYROTEX FELT Q-BESTON QUINORGO QUINTERRA RANCH STYLE RED MASTITE RENDEZVOUS RESISTAL RING-TITE - RIPPLE TONE R-M (OR RAYBESTOS-MANHATTAN) RM 7504 R/M 24 H120 R/M E-66 ROCA ' ROCK SLATE ROMANAIRE RONDELLE RUBBERCOAT 3R SALAMANDER SALON SAL-MO "YES" OR "NOM 17 YEARS PRODUCT "YES" OR "NO" SCANDIVA SEA RING PACKING SELKO-FLO SERVICE SHEET PACKING & CUT GASKETS SHASTA SNOW SHEETFLEXTOS SHINGLE SEAL SIMCO SINDANYO SOUNDGARD SPINTEX SPIROFLEX SPIROTALLIC SPLASHGARD SPRAY-COTE SPRAY CRAFT . SPRAYED "LIMPET" ASBESTOS STA SAFE LONG LIFE STERLBESTOS STIK-ON STONE CHIP STONEGLOW STONEWALL STRATATE STRI-COLOR STRIP-N-LAY 18 YEARS PRODUCT SUMMIT SUPERBESTOS SUPER CUTNO SUPERHEAT SUPER X SUPER 66 SUPRADUR SURE-STIK TADPOLE TARGET TEMPCHECK TERRAFLEX TERRATEX THERMAL KOTE THERMALON THERMATITE THERMOBESTOS THERMO-BORD THERMOFELT THERM-O-FLAKE THERMOFLEX THERMOMAT THERMO-PAC THERMOSTONE THERMO-TAPE THERMOTEX B "YES" OR "NO" YEARS 19 PRODUCT THERMO-WRAP THRIFT-T THRUCHIP TILE-TEX TILOSTONE TK 33 TRANSHIELD TRANSITE TRANSITE-KORDUCT TRANSITOP TRU FLAME TROPAG U.F.P. ULTRA-FINE UNIBESTOS UNIBESTOS 750 UNIBESTOS 1200 ' UNI SYN UNI SYN STYLE NO. 239 V DENT VENTSULATION VICTOPAC VITRIBESTOS' VITROBESTOS VULCA-DEK WELDGARD WHITE TOP ASBESTOS JACKET "YES" OR "NO" 20 YEARS PRODUCT WHITE TOPE WHITTAKER WIREPAK , WOODFLEX YORK ASBESTOS ZEROGLOSS ZEROSEAL ZETABOND ZIP STIK 0-0-7-9 0-0-10-6 NO. 60 SERVICE SHEET 99 FINISHING CEMEMT NO. 100 KEARSARGE SHEET NO. 101 MOBILENE SHEET GRADE 115 CEMENT NO. 116 KEARSARGE GASKETS NO. 118 KEARSARGE GASKETS GRADE 214 CEMENT NO. 302 INSULATION CEMENT 303 ASBESTOS CEMENT 707 ASBESTOS CEMENT "YES OR NO" - YEARS , . 10. As to each such product to which you have answered "yes" above, do you agree that that product contains asbestos? 21 Answer: As to the products in the list designated as containing asbestos, yes. Refer to attached Products List, marked Exhibit "A" for those products. Some products on the list contained no asbestos as is noted. (a) Specifically name the percentage contents of asbestos and name the type of asbestos which the product contained (that is, amosite, crocidolite, chrysotile, etc.) Answer: See Answer above. 11. When do you claim that your company first placed any warnings on its asbestos products? Answer: Defendant's high temperature industrial insulation products were shipped in bags, boxes, crates and gallon drums. Application instructions were printed on predecessors' bags of MW-1 and MW-50 cement. Celotex is continuing its efforts to locate and review records of its predecessors-in-business, but cannot at this time state what other instructions, if any, were given by predecessors-in-business. Warning labels were placed on Celotex's products containing asbestos. Research indicates that warning labels first appeared on such products in 1972. Because or record retention policies, we do not have complete records of our predecessors-in-business. The warning label had the following information printed in bold, black letters on a white background: CAUTION CONTAINS ASBESTOS FIBERS . AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM . ' The above warning was revised and the following warning was used by The Celotex Corporation from 1976 to early 1979. This warning also appeared in the sales literature brochures of Celotex: 22 WARNING THIS PRODUCT IS (ASBESTOS FIBER) OR (CONTAINS ASBESTOS FIBER). THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRA TION (OSHA), AN AGENCY OF THE UNITED STATES GOVERNMENT BELIEVES THAT REPEATED INHALATION OF ASBESTOS FIBERS IS A HEALTH HAZARD AND MAY CAUSE VARIOUS DISEASES INCLUDING CANCER AND ASBESTOSIS. These warnings appeared on printed labels approximately 3x4 inches in size. In July, 1979, Celotex again revised the warning label to read as follows: CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM, INCLUDING CANCER AND ASBESTOSIS. IF DUST IS CREATED, PERSONS EXPOSED TO THIS MATERIAL SHOULD USE ADEQUATE PROTECTIVE DEVICES. SMOKING GREATLY INCREASES THE RISK OF SERIOUS BODILY HARM (a) What was the first warning? Thereafter, when and in what manner did the warning change? Answer: See Answer above. (b) Exactly why did you change the warnings? Answer: See Answer above. (c) Exactly why did you place the first warnings on your products? Answer: See Answer above. (d) Name the official or officials with the defendant's company who was responsible for making the decision to place the original warnings on your products and name each official who was thereafter responsible for making the decision to change your warnings. Answer: See Answer above. 12. When did any official with your company first form the belief that asbestos was capable of causing lung disease? 23 Answer: Defendant objects to this Interrogatory in that it requests a medical opinion. Defendant is not a medical expert and is not qualified to give a medical opinion. (a) Who was that person or official? Answer: See Answer above. (b) List all memoranda of any type available to support your answer to the above question. ' Answer: See Answer above. (c) Who has custody of that memoranda? Answer: See Answer above. 13. When did any official with the company first believe that asbestos was a cancer causing agent? Answer: Refer to Response #12 above. (a) Name that official. Answer: See Answer above. (b) State all memoranda of every type available to support your answer to the above question. Answer: See Answer above. (c) Who has custody of that memoranda? Answer: See Answer above. Respectfully submitted, BUCHANAN, BARNETT, SCHOFIELD & KENT By:__________________________ Don W. Kent 231 S. College Tyler, Texas 75701 (214) 595-5025 State Bar No. 11316500 " ATTORNEYS FOR DEFENDANT THE CELOTEX CORPORATION 24 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument was mailed to all counsel of record on this the day of October, 1982. Don W. Kent 25 The undersigned,.D. S. Gibson, is Manager of Safety and Property Conservation for T.he Celotex Corporation and .at present he has responsibility for plant safety. However, he has no personal knowledge of the facts set forth herein, since the present Celotex organization did not control the personnel, and facilities involved at tiroes relevant to this lawsuit, and further, such facts are the result of the in vestigation by attorneys on behalf of Celotex, and he affirms ." ` * these Answers for purposes of taking necessary official .* action by The Celotex Corporation only. . . THE CELOTEX CORPORATION . INDUSTRIAL PRODUCTS DIVISION . .' STATE OF FLORIDA COUNTY OF HILLSBOROUGH By D. S. Gibson Its Manager of Safety ' Before'me the undersigned, a Notary Public in and for the County aforesaid, this day appeared D. S. Gibson, who . stated he is authorized to execute the foregoing Answers and Objections to Interrogatories on behalf of The Celotex Cor poration, and that the matters stated in said Answers are true and correct to the best of his knowledge, information . and belief. UdSUBSCRIBED AND SWORN TO BEFORE ME, this the day of ( UO. t-CLAJ# / 1981. a L Notftaarryy Public in and for S^Jate of Florida County of Hillsborough Notary Public State of Florida at Largs My Commissioji Expires Oct 7, 1984. EXHIBIT "A" ASBESTOS-CONTAINING INSULATION PRODUCTS MANUFACTURED BY CELOTEX, OR COMPANIES ACQUIRED THROUGH THE PURCHASE OF THE PANACON CORPORATION IN 1972 Name, Trade Name and Description Aircel Pipe Cov & Blk Careycel Pipe Cov & Blk Carocel Pipe Cov Defendex Pipe Cov Excel. Pipe Cov & Blk Closscell Cov & Blk Date of Manufacture Contents 1906 early 70's 4 ply corrugated asbestos paper 1920 's to 1960 12-14 ply Asb paper, indented 1925 to I960 8 ply corrugated asbestos paper WW II 20 ply indented asbestos paper 1925 to 1960 6 ply corrugated asbestos paper 1935 to 1960 Aircel with glossy exterior Multi-Ply Pipe Cov & Blk Asbestos Sponge Pipe Cov & Blk 1930 to 1960 1930 to 1960 Similar to Carey Asbestos Sponge 2-3% Asb spge, 30-40 ply creped asb paper ;x Pipe Cov. 85% Magnesia Pipe Cov, Blk & Cement Unk to iearly 70's 60+% Asb, organic, silicate 1906 to 1961 Basic magnesium carbonate, 11-15% Asb (filter molded) Super Light 85% Magnesia Pipe Cov & Blk 1951 to 1958 Normal carbonate magnesium, 15% Asb (precision molded) Alltemp Pipe Cov & Blk 1954 to 1958 60% Perlite, 20% magnesia plastic, 10% clay, 10% asbestos Tempcheck Pipe Cov, Blk & Cement 1942 to 1958 20% Magnesium plastic, 60% earth, 20% asbestos Hightemp #19 Pipe Cov, Blk & Cement 1906 to 1958 80% Dt. Earth, 20% asbestos Highterap (#12 & #15) Pipe Cov, Blk & Cement 1906 to 1952 60% Dt. Earth, 20% mag, 20% Asb Careytemp 1958 to 09/69 Perlite, clay, 6-7% Asb, binders Careytemp Adhesive 1961 to 1968 80% Silicate of soda, 15% Asb, diatomaceous earth & wetting agent Careytemp Aluminum Jacketed & Traced P- ->e Insul 1964 to 1968 Careytemp with aluminum or stainless steel jacket .eyterap 2000 Blk & Cement 1964 to 02/70 Diatomaceous earth, 6.4% Asb Dual Careytemp Pipe Cov 1964 to 1967 2% Clay, 17% starch, 19% phenolic resin,. 10% asbestos, 62% perlite  /' \ F Trade Name Description 707 Cement Super 606 Cement 100 Cement 303 Cement Careytemp Finishing Cement MW-40 Cement MW-50 Cement LF-20 Asbestos Cement Vitricel Cement (//10 & #19) A-101 Cement I17 Cement .rmo-bord 4.2 Carey Stone Sheets Industrial A-C Board Cemesto Board Careyflex Board Firefoil Board & Panel Vitricel Asbestos Sheets Marine Panel Panel Board Carey Stone Sheathing Asbestos Papers & Roll Boards .^Lboards Date of Manufacture Contents 1906 to 1960 1906 to 1960 43% Asb, 57% ground gypsum 30% Clay, 10% asb, 60% mineral wool 1906 to 1967 50% Asb, 50% gypsum 1906 to 1967 55% Asb, 35% gypsum, 10% clay 1966 to 1968 Cement, clay, perlite, 22% asb, limestone, silica, wetting agent 1950 to 1952 70% Mineral wool, 10% asb, 20% clay 1940 to 1967 90% Mineral wool, 10% asb Unk to 1967 60-70% Asb, clay & hardeners 1940 to 1967 15-25% Asb, 50% cement/slate flour 1906 to 1967 100% Asbestos Unk to ' 60's 83% Asb, 17% clay (sold only to Gulf Oil) 1925 to 1969 Non-asbestos insul covered with A-C sheets 1925 to 1970 78% Cement & 22% asbestos 1925 to 1970 ,78% Portland cement, 22% asb 1930's-early 60*s Same as Thermo-bord 1925 to 1969 75% Portland cement, 25% asb 1940 to 1960 Corrugated asb paper layered with silicate 1941 to 1960 Asb paper, sodium silicate & waterproofing solution 1941 to 1950 Aircel and asbestos cement 1941 to 1950 Corrugated asb felt, sodium silicate 1925 to 1969 22% Asb, 78% Portland'cement 1906 to 02/82 60-85% Asbestos, organic fibre, silicate 1906 to 02/82 Various formulations: 65-97% asb & Portland cement, clay and/or starch 2 } .. V , Tr.-ui* Name ..... DuscrLpt Lon Fireguard Firttcl.ad Jacketing Thermotex-B 228 Fibrated Emulsion InsuLation Seal Fire Resistant Insul Seal Fibrous Adhesive BTU Cement Asbestos Felts 45 pound Asbestos Waterproof Jacket Asbestos Tank Jackets < J Duct Carey Duct Adhesive Thermal, ite Asbestos Rope & Wick Date of Manufacture . 1950 to 1976 1965 to 1982 1906 to present 1906 to unknown 1930 to present Unknown 1906 to present 1930 to 1965 1960 to present 1906 to 1982 1906 to 1945 1940 to 1955 1940 to 1955 1906 to 1937 1925 to 1945 Contents 85% Asb, 15% asphalt 65% Asb, 35% asphalt, glass scrim 14% Asb, asphalt & mineral stablliz. Bentonite clay, asphalt, 3.6% asb 20% Asb, asphalt cutback, naphtha, mineral spirits 20% Asb, asphalt & chlorin. solvent 85% Sodium silicate, 15% asb 25-30% Asb, asphalt cutback 85% Asb, 12% fiber, 3% binders 85% Asb, asphalt, org/paper fillers 60% Asb, 25% org fiber, 15% sod. sil. 60-85% Asb, 15-40% starch 15% Asb, 85% sodium silicate 85% Asb, 15% sodium silicate 85% Asb, 15% cotton fiber 1/30/83 3 CORPORATE HISTORY OF THE PHILIP CAREY MANUFACTURING COMPANY The Philip Carey Manufacturing Company was organized in Ohio in 1888 and remained an independent company until 1966, when Glen Alden Corporation (a wholly-owned subsidiary of Rapid-American Corporation) acquired control. In 1968, The Philip Carey Manufacturing Company changed its name to Philip Carey Corporation. In April, 1970, Philip Carey Corporation was statutorially merged into Briggs Manufacturing Company, a Michigan corporation, and simultaneously, Briggs changed its name to Panacon Corporation. .On June 30, 1972, Panacon Corporation was merged into The Celotex Corporation, a Delaware corporation (a whollyowned subsidiary of Jim Walter Corporation, a Florida corporation). This merger was also statutory, and The Celotex Corporation assumed the' assets and ordinary liabilities of Panacon Corporation. ASBESTOS RELATED CLAIMS FILED RV MANUFACTURING PLANT EMPLOYEES BETWEEN THE YEARS 1949 - 1971 EMPLOYEE NAME Albert Johnson Herbert Gooch -Clarence Hulette DATE FILED 1949 1958 1958 STATE FILED Ohio Ohio Ohio Henry Hoerst 1960 Ohio Roosevelt Cross Earl Bolds - 1962 1964 Ohio Ohio Harlan . Williams 1966 Ohio Grover Hill 1967 Ohio Robert Heal 1969 Ohio Gilbert Daniel John Swikard 1971 1971 Ohio Ohio Mary E. Goodwin Unknown Penn. DISPOSITION Allowed for Asbestosis LAST KNOWN ADDRESS 3124 Fredonia Ave. Cincinnati,Oh.45229 Allowed for Asbestosis 624 Vine Street . Wyoming,Oh.45215 Allowed for Silicosis & Asbestosis \ 9515 Crestbrook Cincinnati,Oh.45231 ' Allowed for Asbestosis & Silicosis 10109 Wayne Ave. Lockland,Oh. Allowedfor Asbestosis 2484 Williamsburg Dr Cincinnati, Oh.45225 Allowed for Asbestosis, . Silicosis & others 625 Oak Street Wyoming, Oh.45215 Allowed for. Asbestos & ' silicosis *; 9880 Dick Road Harrison,Oh.45030 ' Allowed for Asbestosis 207 Sturgis Ave. Cincinnati,Oh.45217 Allowed for Asbestosis * Disallowed death Claim ` 1082 Jefferson Ave. Cincinna ti,Oh4 5246 Allowed for Asbestosis ` * Asbestosis with possible Mesothelioma 811 Leggett Ct. Cincinnati, Oh.45215 1345 w. North Bend Rd. Cincinnati,Oh.45224 ' Unknown Unknown The Celotex Corporation has reviewed all known records and to the best of its' knowledge the above is a complete listing of all com pensable asbestos related claims fllT5~d~by~~maTYUTacturing plant emp-- loyees from 1949 thru 1971. ' s* / / \/ A AVAILABLE RECORDS OF THE PHILIP CAREY CORPORATION ; INDICATE TIIE FOLLOWING COMPENSABLE ASBESTOS RELATED 4 WORKMAN'S COMPENSATION CLAIMS Year Employee's Filed Name 1949 Albert Johnson 1949 - 1971 Last Address Ohio Industrial Comm. Decision 3124 Fredonia Ave. Allowed for-Asbestosi Cincinnati, Oh. 45229 1958 Herbert Gooch 624 Vine Street Wyoming, Oh. 45215 Allowed for Asbestosi 1959 Clarence Hulette 9515 Crestbrook Allowed for Asbestosi Cincinnati, Oh. 45231 1960 Henry Hoerst 10109 Wayne Ave. Allowed for Asbestosi Death Claim allowed for Silicosis 1962 Roosevelt Cross 2484 Williamsburg Dr. Asbestosis Cincinnati, Oh. 45225 1964 Earl Bolds 625 Oak Street Wyoming, Oh. 45215 Silicosis and Asbestosis 1966 Harlan Williams 9880 Dick Road Harrison, Oh. 45030 Asbestosis 1967 Grover Hill 207 Sturgis Ave. Asbestosis Cincinnati, Oh. 45217 1969 Robert Neal 1082 Jefferson Ave* Asbestosis Cincinnati, Oh. 45246 Disallowed Death Claii 1970 Gilbert Daniel 811 Leggett Ct. Asbestosis Cincinnati, Oh.. 45215 ` 1971 John Swikard 1 1345 W. North Bend Rd Mesothelioma Cincinnati, Oh. 45224 *Ai ASBESTOS BELATED CLAIMS FILED BY MANUFACTURING PLANT EMPLOYEES BETWEEN THE YEARS 1949 - 1971 EMPLOYEE NAME Albert Johnson Herbert Gooch -Clarence Hulette DATE FILED 194? 1958 1958 STATE FILED Ohio Ohio Ohio Henry Hoerst 1960 Ohio Roosevelt Cross' Earl _ 1962 Ohio DISPOSITION Allowed for Asbestosis Allowed for Asbestosis . Allowed for Silicosis & Asbestosis ' Allowed for Asbestosis & Silicosis Allowedfor Asbestosis Allowed for LAST KNOWN ADDRESS 3124 Fredonia Ave. Cincinnati,Oh.45229 624 Vine Street . Wyoming,Oh.45215 %. 9515 Crestbrook Cincinnati,Oh.45231 10109 Wayne Ave. Lockland,0h. 2484 Williamsburg ] Cincinnati, Oh.4522!