Affidavit of Andrew McCampbell Gibson (Alston & Bird) Authenticating U.S. Gypsum and Georgia-Pacific Repository Documents, with Attached Exhibits (2003)

Affidavit of Union Carbide's outside counsel, filed in MDL 875 in connection with claims about Union Carbide's alleged supply of raw asbestos to U.S. Gypsum and Georgia-Pacific. It describes the USG and GP document repositories and lists, as Exhibits A through JJ, the documents he copied from them. The pages provided also include copies of several of those exhibits: a 1969 Union Carbide toxicology report, USG operating bulletins and memos, Gypsum Association letters and minutes, and a 1968 Calidria brochure.

What the document holds

• Pages 1-9: Affidavit of Andrew McCampbell Gibson listing Exhibits A-JJ, with signature page and a blank certificate of service
• Pages 10-11: Exhibit A: Union Carbide Industrial Medicine and Toxicology Department 'Asbestos Toxicology Report,' 5/8/69
• Page 12: Exhibit B: USG letter to its outside counsel (Scott, MacLeish & Falk) about a dust survey and asbestosis at Jersey City, stated in the affidavit to be dated Aug. 17, 1936 (date not clear in the OCR)
• Pages 13-14: Exhibit C: USG General Order 'Elimination of Dusty Conditions,' dated 8-24-43
• Pages 15-17: Exhibit D: USG amended General Order 'Elimination of Dusty Conditions,' dated 2-11-54 (3 pages)
• Pages 18-23: Exhibit E: USG 'Hazardous Chemicals Used in Paint Manufacture,' dated 9-3-48 (pages garbled/mirrored in OCR)
• Pages 24-25: Exhibit F: E. Maynard (USG) to Mr. Morris, Campbell Soup Company, Jan. 12, 1966, on hazards of Perf-a-Tape joint compounds
• Pages 26-27: Exhibit G: USG memo 'Hazardous Labelling - Joint Compounds,' Dec. 14, 1970
• Page 28: Exhibit H: USG memo from C. P. Kipp, 'Asbestosis Hazard,' June 11, 1970
• Page 29: Exhibit I: USG routing slip, Kipp to Zabor and Entz, 'Joint Treatment Compounds,' July 30, 1971 (largely illegible in OCR)
• Page 30: Exhibit J: R. P. Entz to C. P. Kipp, 'Joint Compounds, Asbestos Fiber,' Aug. 18, 1971
• Pages 31-32: Exhibit K: C. M. Howard, Jr., USG memo 'Status of Asbestos Free Joint Compound,' October 1972
• Pages 33-36: Exhibit L: Gypsum Association letter (H. B. Carlsen) to the Special Committee on Asbestos in Joint Treatment Compound, Aug. 15, 1973, stamped UC-5455
• Pages 37-38: Exhibit M: K. S. Freeman USG memo to J. N. Walker, 'Caution Labels for Joint Compounds,' Aug. 17, 1973, stamped UC-5467
• Pages 39-40: Exhibit N: Union Carbide Chemicals and Plastics brochure, 'Calidria' Asbestos SG-130 and SG-210 for tape joint compounds, October 1968 (GP 013011-12)
• Page 89: USG memo to C. C. Gramer and J. N. Walker, 'Warning Labels for Joint Treatment and Texture Paints,' 12/14/73 (apparently Exhibit HH)
• Pages 90-91: Minutes of Gypsum Association Safety Committee meeting, Buffalo, N.Y., Sept. 20, 1966
• Pages 92-93: Minutes of Gypsum Association Safety Committee meeting, Saddle Brook, N.J., dated Sept. 13, 1967 in the OCR

People and organizations

From Andrew McCampbell Gibson (Partner, Alston & Bird, LLP; counsel for Union Carbide Corporation).

• Campbell Soup Company (named)
• Georgia-Pacific Corporation (named)
• Gypsum Association (named)
• Gypsum Association Safety Committee (named)
• Industrial Medicine and Toxicology Department (named)
• National Gypsum Co. (named)
• Scott, MacLeish & Falk (named)
• Union Carbide Corporation (named)
• United States District Court for the Eastern District of Pennsylvania (named)
• United States Gypsum Company (named)

Related pages

Pages on our site about what this document covers: Calidria · Georgia Asbestos Exposure Sites: Worksites, Industries, and Trust Coverage · Illinois Asbestos Exposure Sites: Worksites, Industries, and Trust Coverage · New Jersey Asbestos Exposure Sites: Worksites, Industries, and Trust Coverage.

About this copy

This is document UC-5448 of the Union Carbide documents, documents produced and used as evidence in asbestos lawsuits against Union Carbide, 93 pages. Production numbers GP 013011 to opool 0321.