Document 2jggwZ9y8kko3LX6rVd6M9dwg

FILE NAME Talc TALC DATE 1973 Aug 27 DOC TALC451 DOCUMENT DESCRIPTION Memo RE Calculation of Asbestos in Food Grade Talc Proposed by FDA 8/28 CONFIDENTIAL ~ LIMITED DISTRIBUTION DM Manville Internal Correspond To R. S. Lamar DConter Date August 27 1973 : Fron V. E. Wolkodoff DCenter Coplesi : ie Subject FIBER PETROGRAPHIC TION OF CHRYSOTILE AND TREMOLITE CALCU IN TALCS BY FOOD GRADE TALC SPECIFICATIONS TO BE PROPOSED BY FDA AUGUST 20 1973 AS A GOOD MANUFACTURING PRACTICE Schulze Eisenberg petrographic and 1973 Washingtonoutlined L. The petrographic method is by - of the U.S. FDA D.C. dated February 1 The method was followed with only two exceptions as ce po magnification . follows a 500X was used rather the 400X mo recommended since 400x cannot beemployed for direct visual examination onthe Leitz Orthoplan b. Square cover slips 18 by 18 mm were used rather | . than circular cover slips with a diameter of 18 mm . permissable 2 As proposed byFDAthe maximum fibers are Tremolite - 1,000 1,000 fibers mg numberof oe - requires fibers Chrysotile .- 100 precisely method me on M material 1 mg particles 3 The of a slide for examination For a frame of reference the| total number of in 1 mg of Reeves . oO . ne ca . Milled talc is 6,720,000 6,720,000 6,720,000 nl 4 The results are as follows a Chrysotile | Tremolite | Fibers .. Fibers M-.aMtaeterriiaall e w r o Per mg _ Per mg Ls pe * : a M Cyclo . ms 0 47,040 Standard 70-34 oo - b M Cyclo 168 16,464 . a - Standard 70-33 ) , C. United Sierra Mistron 2 0 0 mS Talc No. 104 oo Vapor - M Talc a Reeves Jet 504 336 . , - Milled HazenConcentrate ms to RD 73201-1 ~ 000103 Page RS, 20. Lamar fe August 27 1973 percent 5 In the near future you will be receivinga report on fibers in 14 commercial talcs as studied by Chrysotile electron microscopy Only two tales transmission 599 and Charles Pfizer were found to Englehard Emtal The others be free of chrysot'le and tremolite contain chrysotile in amounts by volume ranging from about tenth of one Yellowstone Talc up e to tenths of one percent Italian Talc Grafite | Val Chisone Johnson and Johnson Baby Powder contains approximately tenth of one percent percent If TEM is ever introduced as part of the FDA microscopical procedure talcs could - then indeed only a very small percentage of qualify by the proposed new standards Please keep size that in mind that the lowest level of particle be determined with reasonable certainty by optical can method is on the order of 0.5 micron although petrographic be down to 0.25 micron whereas theoretically it can fibrils of approximately 2508 in dia- by TEM chrysotile detected and characterized meter can be easily generous is is - the maximum permissable numbeorf fibers 6 To the layman not For example an investi- _ may sound is 20 of view characterize gator settle fields slide there are at least 40,000 the microscopical _ fiber ticles in 20 fields and iftheonneumcbherrysooftilcehrysotile fibers found then by calculation 7 per mg is well over 100 | 7. You requested my opinion on the microscopical procedure There are many Eisenberg as outlined by Schulze of drawbacks and weak frames from viewpoints mineralogy and petrography The work is essentially a libraray search many of the references are outdated e.g.y of nine references are listed for the alpha index and these range from 1.493 weak but weak rupefrtaoct1i.o5n59forTecchhrnyiscoatlilley the paper is correct | paper also naive - a . | ae concidence iN but the first draft by Schulze and @. It may be is dated February 1 1973. At about this time Eisenberg and Johnson had unded a program at the Colorado Johnson School of Mines Research Institute to detect very small cosmetic grade talc We have percentages of asbestos in successful and that asbestos learned that the progmrialmliwoans could easily be detected and down to one part per without benefit of TEM it is my understanding | V. Wolkraoff V. Wolkodoff 000104 II