Document 6wZ66KVp4YoJ1jOR1xBJjoz84

2628 PEARL ROAD MEDINA, OHIO 44256 INTRA-ORGANIZATION MEMORANDUM CC: Julius Nemeth PLAINTIFF'S EXHIBIT BON - 01832 Cyprus Industrial Minerals Company 555 South Flower Street Los Angeles, California 90071 Telephone 213) 489-3700 September 15, 1977 TWX 910) To You, Our Customer We' would like to take this opportunity to clarify some of the confusion which appears to be building in terms of talc and asbestos. A number of significant develop ments have recently occurred which tend to cloud the regulatory aspects of the problem. t ft In May, 1977, OSHA published a booklet entitled "A Re port on the Fiber.Content of Eighty Industrial Talc Samples Obtained from, and Using the Procedures of the Occupational Safety and Health Administration". You may have received a letter from one of your suppliers analy zing the data presented in this OSHA report. We feel that this analysis.of the data was misleading in the manner in which it was offered. While we are of the opinion that the OSHA method of fiber analysis is not adequate to identify asbestos, OSHA does continue to employ this method. The conclusions drawn by the National Bureau of Standards in its discussion of the results states quite conclusively that- they also feel the OSHA method is in dire need of review. We quote from the NBS report, Section V, Conclusions, P. 17, as follows: "The variability of these results raises several questions regarding the OSHA procedure, particularly sampling technique, sample homogeneity, and determi ning fiber morphology. _It is the opinion of NBS that, even under favorable circumstances (e.g., homo geneous samples, easily identified fibers, etc.), the existing OSHA procedure is useful only for determining 'fiber1 content and not 'asbestos* content. Although careful manipulation of the mounting medium might make it possible to identify some of the fibers as 'asbestos', the problem of the definition of 'asbestos* still re mains . NBS believes that the resolution of the measure ment problem, including the definition and identification of asbestos, will be accomplished only by significant changes in the procedure and probably the method as well. BON-01833 CYPRUS Following this report, a "Workshop on Asbestos" was held 'at the National Bureau of Standards in Washington, July 18-20, 1977. Unfortunately, this workshop did not result in any change of test method but did serve to point out the extreme inadequacy of the procedure as it is presently constituted. We do not feel we should speak for the talc industry in general, but rather, will review our own situation as it presently stands. In this OSHA report, 16 samples were tested which were identified as Cyprus Industrial Minerals Company talc. The results of the tests on these 16 samples are shown below: CYPRUS INDUSTRIAL MINERALS COMPANY Mining Source Total Samples No Fiber Fiber Present Montana Texas California 4 1 11 40 10 47 CYPRUS THOMPSON, WEINMAN, COMPANY Georgia -1 1 0 As can be seen from this data, both our Montana and Texas talcs are indicated to be free of asbestifSrm material. Our California talcs contain only very minute quantities of tremolite in some instances. We do state that they are free of asbestiform impurities to the level of sensitivity as measured by X-ray Diffraction Techniques. This is approximately 0.1% to 0.3%. If certification to zero asbestiform level is deemed necessary, by your company, only our Montana talc based grades should be used. The one sample included in the survey from our Cyprus Thompson Weinman subsidiary is included only to illustrate the weakness of the OSHA analysis method.' This sample is analyzed as talc but is, in reality, a platey mica (sericite), not a talc material at all. Again, let us point out, the OSHA method of fiber an alysis by optical microscopy is incapable of identifying the exact mineral nature of the sample being inspected. In the manner in which the rulings are stated, fibers are not to be considered asbestos unless they are positively identified as being one of six minerals specifically stated in the Federal Register, 29 CFR 1910.1001 (a) Definitions. These minerals can best be posi tively identified by Transmission Electron Microscopy combined with Selected Area Electron Diffraction. BON-01834 CYPRUS Until such time as OSHA modifies its analytical method, 'it will be necessary to review every individual inspection decision at the time it is reported. Cyprus Industrial Minerals Company will be pleased to assist you, should you need clarification on any of the above points, or to work with you in terms of any OSHA inspection involving any of our products. Sincerely, Technical Director GJG:rh BON-01835