Document 5LDLpr58yrp0amMOLGBNM8jq4
PLAINTIFFS
EX H IBIT
CAM-262
CYPRUS
Industrial Minerals
9100 East Mineral Circle Post Office Box 3299 Englewood, Colorado 80155 (303) 643-5484 Fax: (303)643-5168
September 30, 1991
Richard J. Zazenski Vice President, Quality Assurance
Mr. Jack Paterno Synthetic Specialties P. 0. Box 120 Middletown, New Jersey
07748
Dear Mr. Paterno:
Subject: Asbestiform Mineral Testing - Cyprus Talc Products
Cyprus Industrial Minerals certifies that our talc products do not contain detectable quantities of asbestos or asbestiform minerals. This certification is maintained by an internal quality assurance testing program that was established nearly twenty years ago to ensure product purity. It is the policy of Cyprus Industrial Minerals that we will not sell talc products that contain detectable quantities of asbestos or asbestiform minerals.
Asbestos is a commercial term applied to a group of highly fibrous silicate minerals that readily separate into long, thin, strong fibers of sufficient flexibility to be woven. To date, six minerals have been identified to exist in an "asbestiform" structure. They are:
Chrysotile, or White Asbestos Crocidolite, or Blue Asbestos Amosite, or Brown Asbestos Anthophyllite Actinolite Tremolite
Chrysotile belongs to the mineral group called serpentines. The other five belong to a mineral group called amphiboles.
In our analyses of talc deposits around the world, we have found that both serpentine and amphibole minerals are commonly associated with talc. It appears rare, however, that these mineral groups contain the asbestiform varieties of the six aforementioned minerals. For instance, antigorite is a mineral common to the surrounding geology of a talc deposit. Antigorite is the non-asbestiform counterpart to chrysotile. Enclosed is a picture of the six asbestiform minerals and their nonasbestiform counterparts which illustrates the physical differences.
There are four types of analytical procedures generally utilized to
analyze for asbestos and asbestiform minerals in bulk talc samples. They are:
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1. Polarized Light Microscopy with dispersion staining (PLM); 2 Scanning Electron Microscopy with energy dispersive
spectroscopy (SEM/EDS); 3. Analytical Electron Microscopy with selected area electron
diffraction (STEM/SAED); and 4. High intensity, slow step scanning X-ray diffraction.
Each of these methods has limitations but when utilized together, provide the latest in technology for asbestos analysis. Cyprus Industrial Minerals has the capability and skilled technicians in-house to conduct all of these analyses.
Our current quality assurance/certification testing program reflects the fact that our products are not suspected to contain even trace amounts of asbestos or asbestiform minerals. Our massive data base of test results suggests that our talc deposits simply do not contain these undesirable impurities. Our current testing protocol for cosmetic and pharmaceutical talc products is as follows:
1. A composite sample from each production lot is analyzed by XRD for total amphibole minerals. The level of detection is 0.1% by weight. If any amphibole minerals are detected to be present, the product is quarantined pending positive identification of the amphibole by PLM.
2. On a monthly basis, a collection of these composite samples are analyzed by PLM for amphiboles and serpentine minerals. The level of detection is on the order of 100 ppm. The purpose of the PLM analyses is simply to confirm and document the absence of these minerals, regardless if they were asbestiform or otherwise.
3. Electron microscopy is now performed specifically for asbestos analysis on an audit basis only. However, if a talc sample is in the microscope for some other evaluation, the sample automatically is reviewed for fibers or suspect particles.
Enclosed is the test method for our routine control of asbestiform amphibole minerals. It was originally assembled by the Cosmetic, Toiletry and Fragrance Association (CTFA) to utilize in the control of cosmetic talcs.
I hope this information is of some value to you. Please let me know if I can be of any further assistance.
Enclosure
cc: M. A. Nordhauser (w/enclosure) R. Grexa/Cosmetic Specialties (w/enclosure)
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asbestiform
non-asbestiform
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